diff --git a/vision-fixhub/ds9-unparsed-05/9d39afa7e8c74efcc7aaf180c44d1a4092ac3145e5438acc0eca32dbfa846157.md b/vision-fixhub/ds9-unparsed-05/9d39afa7e8c74efcc7aaf180c44d1a4092ac3145e5438acc0eca32dbfa846157.md
new file mode 100644
index 0000000000000000000000000000000000000000..f4c3fbba7ea45dc15da623cdaf8b06f65a738e4f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9d39afa7e8c74efcc7aaf180c44d1a4092ac3145e5438acc0eca32dbfa846157.md
@@ -0,0 +1,31 @@
+-
+HERMAN & MERMELSTEIN PA
+ATTORNEYS AT LAW
+18205 Biscayne Blvd.
+Suami, 21orida 33160
+ww.hermanlaw.com
+October 23, 2008
+VIA U.S. MAIL
+The United States Attorney's Office
+Southern District of Florida
+500 S. Australian Avenue
+Suite 400
+West Palm Beach, FL 33401
+sent to
+10/29/08
+ATTN: RECORDS CUSTODIAN
+per
+instructions
+Re:
+Jeffrey Epstein
+To Whom It May Concern:
+Please allow this correspondence to serve as a public records request for copies of
+your entire file, including but not limited to reports, office cards, written memoranda,
+handwritten notes, photographs, all investigation materials, and any and all other reports and
+records involving Jeffrey Epstein, including but not limited to any such materials produced.
+in the course of investigation by FBI Special Agents
+Please send the copies, along with your invoice, to my attention
+If you should have any questions please contact my office. Thank you for your
+attention to this matter.
+Sincerely,
+rj
diff --git a/vision-fixhub/ds9-unparsed-05/9d39afa7e8c74efcc7aaf180c44d1a4092ac3145e5438acc0eca32dbfa846157.receipt.json b/vision-fixhub/ds9-unparsed-05/9d39afa7e8c74efcc7aaf180c44d1a4092ac3145e5438acc0eca32dbfa846157.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e7bbcc6c5d4a0ee9e8320df5240be5a71d757d50
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9d39afa7e8c74efcc7aaf180c44d1a4092ac3145e5438acc0eca32dbfa846157.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "9d39afa7e8c74efcc7aaf180c44d1a4092ac3145e5438acc0eca32dbfa846157",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "2b43da880e4d7fc36486bdc27c785f8f38f3a863384f113b41c47afaea5d0cd5",
+  "output_sha256": "8b4d8cf1d1c051bc38e4b2c617f303ecd444caa2a80c6547d3a66b03d60b1225",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/9d5393b9dd261021e4de856a735795c7c9213ab076d04f3460936c5369cc4d27.md b/vision-fixhub/ds9-unparsed-05/9d5393b9dd261021e4de856a735795c7c9213ab076d04f3460936c5369cc4d27.md
new file mode 100644
index 0000000000000000000000000000000000000000..a104bc73f410f8e671b30007f3f8bdc597c72490
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9d5393b9dd261021e4de856a735795c7c9213ab076d04f3460936c5369cc4d27.md
@@ -0,0 +1,47 @@
+(USAFLS)
+From:
+Sent:
+To:
+Subject:
+I (USAFLS) <
+Wednesday, June 18, 2008 3:20 PM
+I. (USAFLS)
+RE: Epstein -- Call with Roy Black
+Nothing that I know of by way of final decision.
+From:
+. (USAFLS)
+Sent: Wednesday, June 18, 2008 1:53 PM
+To:
+(USAFLS);
+(USAFLS); [
+(USAFLS);
+Subject: Epstein - CAl WitS Roy Black
+(USAFLS)
+(USAFLS)
+and I spoke with Roy. Roy said that he had called because he had heard that
+had discussed the
+matter with
+and Roy wanted to see if there was any way to wrap this up before July 7". Roy
+also said that he had scen a letter from
+that said that the matter of incarceration would be left to the
+State. (I am not certain what letter he is referring to, but I think
+wrote a letter about not taking a position on
+where Epstein would be incarcerated, not the length of time.) So, Roy wondered whether we would go away if
+Epstein took
+| 60-day deal.
+explained that
+had not had substantive discussions with
+about the case and that all
+communication regarding the case is being handled by
+and me. In response to the question of whether
+there was anything that could "make this go away," we said that our position is that if Epstein stops the process
+in Washington and pleads in accordance with the terms of the signed agreement, then we will perform pursuant
+to the agreement.
+_explained that if Epstein pleads to something else or gets sentenced to a lower amount,
+then we will consider that a breach of our agreement and we will proceed accordingly.
+On that note, has there been any word from Washington?
+Thank you.
+Assistant U.S. Attorney
+08-80736-CV-MARRA
+65
+P-014976
diff --git a/vision-fixhub/ds9-unparsed-05/9d5393b9dd261021e4de856a735795c7c9213ab076d04f3460936c5369cc4d27.receipt.json b/vision-fixhub/ds9-unparsed-05/9d5393b9dd261021e4de856a735795c7c9213ab076d04f3460936c5369cc4d27.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d4065cdc76d39c3116c1c216d1211d7a1e4422bc
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9d5393b9dd261021e4de856a735795c7c9213ab076d04f3460936c5369cc4d27.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "9d5393b9dd261021e4de856a735795c7c9213ab076d04f3460936c5369cc4d27",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3ae51293112d8a5264f5e549b56c8affa16608501db421ad066af4c2c21713d8",
+  "output_sha256": "b4d4e8c6ec33ce1582f596889d81cfe0f6b75bce0a0bed5cae5fd05bf062a53d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/9db573f7a6dd226b1a6852ea37e0430c19b7f89bdc2e1bdaf5a67874b656f1e0.md b/vision-fixhub/ds9-unparsed-05/9db573f7a6dd226b1a6852ea37e0430c19b7f89bdc2e1bdaf5a67874b656f1e0.md
new file mode 100644
index 0000000000000000000000000000000000000000..5053f137eaf3018d062e19e386eac4bb54379fe7
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9db573f7a6dd226b1a6852ea37e0430c19b7f89bdc2e1bdaf5a67874b656f1e0.md
@@ -0,0 +1,3540 @@
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20.
+21
+22
+23
+24
+25
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+UNITED STATES OF AMERICA,
+Plaintiff,
+COPY
+VS.
+and
+Defendants.
+TESTIMONY
+OF
+SPECIAL AGENT I.
+Federal Grand Jury 07-103
+Federal Building
+U.S. Courthouse
+West Palm Beach,
+Tuesday, March
+Florida
+18, 2008
+APPEARANCES:
+Assistant United states Attorney
+Foreperson
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+The sworn testimony of SPECIAL AGENT
+taken before the
+Federal
+Grand Jury, West Palm Beach Division,
+Federal Building, U.S. Courthouse, Palm Beach
+County, State of Florida, on Tuesday, March 18,
+2008.
+• Certified Court
+Reporter and Notary Public, State of Florida,
+Official Reporting Service, LIC, 524 South Andrews
+Avenue,
+Suite 302N, Fort Lauderdale, Florida,
+33301, was authorized
+to and did report the
+SWOrn
+testimony.
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+23
+24
+25
+3
+(Witness enters the Grand Jury Room.)
+THE FOREPERSON: You do solemnly swear
+that the testimony you give will be the
+truth, the whole truth, and nothing but the
+truth, so help you God?
+THE WITNESS:
+I do.
+THE FOREPERSON: Thank you. Please be
+seated.
+EXAMINATION
+BY
+Good afternoon, Special Agent
+- Would you just remind the grand jury
+of your name and for whom you work?
+I am
+My official name is
+and I work for the FBI here
+in West Palm Beach.
+All right. And you are still one of the
+case agents on Operation Leap Year?
+Yes, I am.
+Have additional subpoenas been issued on
+behalf of this grand jury regarding Leap Year?
+Yes, they have.
+And have documents been received in
+response to those subpoenas?
+Yes, they have.
+
+
+.. "
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+4
+Q
+What subpoenas were
+items were received?
+issued and what
+The items
+that are received are in this
+box for your review at a later time, but starting
+with the first subpoena that we had received
+documents back for would be from American Express.
+The subpoena was issued and we
+received
+credit card account information.
+Q
+Okay.
+Do you want me just to --
+You can just go through them.
+A subpoena was issued to J. Epstein
+Virgin Island Foundation, Inc., J. Epstein and
+Company, Epstein Interests, Financial Trust
+Company, Inc., and we received documents on all
+three of those except for -- all four of those
+except for Jeffrey Epstein and Company --
+J. Epstein and Company, which we received a letter
+of no response.
+The next subpoena was issued to the Palm
+Beach County School Board and we received
+transcript request forms. The next grand jury
+subpoena was issued to Dan Tishler, Airport
+Executive, Town Car Services. We received a
+verbal that there were no records from Mr.
+
+
+5
+Tishler.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+We issued a grand jury subpoena to the
+custodian of records for Majestic Theater, which
+we received ticketing records for.
+We issued a grand jury subpoena or you
+issued a grand jury subpoena for the custodian of
+records at the Broward Center for the Performing
+Arts and we received ticketing records.
+We issued a subpoena for the custodian
+of records for the Kravis Center for the
+Performing Arts and received a letter of no
+records response.
+We issued a subpoena for the custodian
+of records for Live Nation Theatrical Broadway
+Across America. Again, received a response letter
+of no records.
+We issued another subpoena for the
+custodian of records from Live Nation Theatrical
+Broadway Across America and that we did receive
+some ticketing records.
+We issued a subpoena to Bear Sterns and
+Company, Inc., and we received personnel files and
+account information. We issued a grand jury
+subpoena for Wolf Camera and we received
+transaction records.
+
+
+1
+2
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+6
+We have issued a grand jury subpoena to
+Amazon.com and received order records. We issued
+grand jury subpoena to Federal Express and
+received shipping records, and all that is
+contained in this box.
+All right.
+BY
+And at the end of our
+preservation, you will be welcome to 1o0k
+through any of those records and we also will
+bring them to the next session.
+A GRAND JUROR: I have a question.
+: Yes.
+A GRAND JUROR: We subpoenaed
+information from theaters. I heard you say
+ticketing information or records from a few
+of them.
+Did we subpoena that information to
+establish location of the defendant or I
+guess he's not a defendant yet?
+THE WITNESS:
+Just as corroborating
+evidence of testimony provided by the girls.
+Their statements provided to us.
+A GRAND JUROR: Okay.
+L:
+Okay. Special Agent
+• each
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+7
+member of the grand jury has before them a copy of
+a chart. Do you also i
+have a copy of this chart
+entitled Revised Indictment Summary Chart
+(by victim)?
+Yes.
+And then you also provided to everyone a
+list of Jane Does with photographs?
+Yes, I did.
+Okay. Can you just explain to the grand
+jury how -- which Jane Does we are going to be
+talking about today?
+We are going to talk about Jane Does one
+through Six and Nine and Ten, and what you have
+here is a Jane Doe list of One through 19. We
+will be going through the first six and Nine and
+Ten.
+As you can see, if you 100k at these two
+columns you'll see in the indictment we have
+before you is going to have the new Jane Doe
+numbers and the column to the right of that shows
+you what their Jane
+Doe number used to be.
+So Jane Does Nine and Ten, when we spoke
+about those two before, and we will go through
+that a little bit later, we referred to those as
+Jane Does Six and Seven.
+From here on out, we
+
+
+8
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+will refer to them as Jane Does Nine and Ten.
+A GRAND JUROR: I have a question about
+Jane Doe Number One, and Amy pointed this
+out. The date of birth is August 1983. The
+range of activity dates is 1988 to 2003?
+THE WITNESS: That's a typo. That
+should be 1998.
+: Thank you for catching
+that.
+A GRAND JUROR: I was about ready to
+have a problem here. I was having a real
+problem. Yeah.
+1: Okay. Thank you.
+A GRAND JUROR: I was about to take the
+law into my own hands.
+THE WITNESS: Let there be noted on the
+summary chart, there is a typo correction for
+Jane Doe Number One.
+The range of activity
+for her is 1998 to 2003.
+This chart is a chart that we put
+together because I have testified in the past
+as well as you may have heard other testimony
+regarding some of the Jane Does, and we are
+going to be talking about them today and in a
+later session.
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+•23
+24
+25
+9
+We want -- we provided this to you sort
+of as an aid so that you can go back and
+access the grand jury transcripts and go to
+the date that the testimony was provided.
+If you look at the last column where it
+says, Grand Jury Transcript Pages, on this
+form it will tell you the date of the grand
+jury, who provided that testimony, and the
+page number where you can find testimony
+related to those specific Overt Acts and
+substantive counts.
+So the two columns next to that -- let's
+just take Jane Doe Number Iwo and run through
+that real quick.
+Jane Doe Number Iwo, we
+have not testified about before. So that is
+her number and will always remain her number.
+Her date of birth is January of 1987.
+The range of activity and that reflects the
+range of activity that we have her connected
+to Mr. Epstein and his assistants.
+The next two columns are the Overt Acts
+and the associated substantive counts. The
+Overt Acts support those substantive counts
+and again the last column you would at that
+point go to my testimony on May 8th, 2007,
+
+
+10
+and look on the transcript on Pages Six and
+Seven, and that would be my testimony for the
+Overt Acts, the supporting evidence and
+testimony for overt Acts One
+through 18.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY
+But, Special Agent
+just so
+that it is clear, when you testified back in May,
+you weren't testifying specifically about Jane Doe
+Number Iwo, but her name came up in -- with
+respect to one of the other Jane Does?
+Exactly.
+Okay. So any information related to
+those Jane Does would be in the transcript pages?
+Yes.
+:
+Does that make sense to
+everyone how we have organized that?
+BY
+L:
+Now Special Agent
+h, if you
+could look at the proposed indictment, and I'm
+looking at the Background section of the
+indictment specifically Paragraphs One through
+Nine, which deal with Mr. Epstein's background and
+who he employed.
+Have you testified about that material
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+11
+in the past?
+A Yes, I have.
+And let me just direct you to overt Two,
+which is at the top of Page Iwo. There is a
+reference to I.G., and I don't believe we have
+talked about L.G. before.
+Can you tell the grand jury who that is?
+L.G. is Lesley Groff and she is a
+personal assistant or an assistant for Mr. Epstein
+in his New York office.
+All right.
+And just for the court
+reporter, Lesley is I-E-S-L-E-Y, and Groff is
+G-R-O-F-F; is that correct?
+Yes, it is.
+Then Paragraph Ihree talks about three
+individuals,
+• .. and I. Can you tell
+the grand jury who those persons are?
+• is
+1. I. is
+I. is
+And if you look at the summary chart on
+the second page, there are columns for . and
+I Do you see those at the bottom of Page Iwo?
+Yes, I see them.
+And those refer to
+and
+where you have testified about
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+12
+them before or where
+was
+who
+testified about them?
+Yes.
+I know that you have testified about
+Mr. Epstein's residence here in Palm Beach, but if
+you could look at Paragraph Five of that
+introductory section, which is on Page Iwo.
+Are you -- can you provide the grand
+jury with the location of Mr. Epstein's New York
+residence?
+Mr. Epstein currently has a property
+located at 9 East 71st Street, New York, New York.
+If I could direct you to Page Five of
+the proposed indictment in Paragraphs 18 through
+25 of the introductory section.
+Can you tell the grand jury about where
+the various victims in this case attended high
+school?
+I can. Starting with Paragraph 18.
+Would you like me to just
+run through them?
+Sure.
+Jane Doe Number Four attended Wellington
+High School and Palm Beach Central High School.
+Jane Doe Number Five attended Wellington High
+School. Jane Doe Numbers Six, Eight, and 12,
+
+
+13
+attended Palm Beach Central High School.
+I should state that all of these high
+schools are located in Palm Beach County. Jane
+Doe Number Seven attended William I. Dwyer High
+School in Palm Beach County.
+Jane Doe Numbers Nine, 14,
+15, 16, 17.
+18, and 19 attended Royal Palm Beach High School
+in Palm Beach County. Jane Doe Number Ten
+attended Lake Worth High School in Palm Beach
+County.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Jane Doe Number 11 attended the
+Professional Performing Arts School, a public high
+school located in the New York area; New York, New
+York. Jane Doe Number 13 attended John I. Leonard
+High School in Palm Beach County, and the Jane
+Does attended these high schools during some point
+of the contact with Mr. Epstein.
+Now Special Agent
+I know
+that not each and everyone of the Jane Does is
+listed in this. Did some of the Jane Does leave
+school before they began their relationship with
+Mr. Epstein?
+Yes, they did.
+Now everyone was handed a copy of a
+document entitled, Merged Flight Manifests. If I
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+14
+could ask you to take a look at that, and in the
+proposed indictment if you could turn to Page 32.
+Special Agent
+, I'm going to
+ask you about Overt Acts 191 through 225. Can
+you tell the grand jury what the basis is for the
+allegations set forth in 191 through 225?
+We received through the issuance of a
+grand jury subpoena the flight manifest from Mr.
+Epstein's pilot and that is our evidence to show
+the travel that Mr. Epstein did, which is
+displayed in Overt Acts 191 through 225.
+And the chart that is entitled Merged
+Flight Manifests, what does that include?
+A This chart will show the grand jury that
+in January 2004 through -- basically, Mr.
+Epstein's travel in '04 and '05 on his two
+personal aircrafts, which would be the Boeing 727
+and the Gulfstream.
+If you look at this chart, the first
+column is the
+date of departure, the date that he
+left, and you'll see airport codes in the next
+column that tells you the airport that he left and
+what time he left would be the next time, the
+departure time.
+It will tell you what airport he was
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+15
+arriving in and what time he arrived at that
+airport, and the last would be the actual
+aircraft itself, which aircraft he was traveling
+on, and just to remind the grand jury, Hyperion
+is the Gulfstream and JEGE is the Boeing 727.
+• And who created this chart, the Merged
+Flight Manifests Chart?
+The FBI.
+And where did they gather this
+information from?
+We subpoenaed or the grand jury issued a
+subpoena to the pilot and pilots of Mr. Epstein
+and through counsel the pilots gave us a copy of
+the flight manifest for those two years and I have
+here a set of the flight manifests that were
+provided to us by the grand jury subpoena and have
+marked each of the Overt Acts from 191 to 225.
+So that if any time the grand jury would
+like to come and look at the actual manifest the
+pilots gave us, you'll be able to see the data
+that this form was taken from.
+okay. Thank you.
+: Before I go on, does
+anyone have any questions about those Overt
+Acts and where this information came from?
+
+
+16
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Yes, sir.
+A GRAND JUROR: Is there something that
+ties in these travel itineraries to the
+actual fact that there was a meeting or
+something planned?
+I
+mean, where does that
+tie together? Traveling is not against the
+law.
+: Right. The way that we
+had the indictment organized before was an
+attempt to do this in chronological order,
+which seems to be more confusing rather than
+less confusing.
+So when you look at the -- when you hear
+the testimony from Special Agent
+and when you look at the Overt Acts related
+to the victims and when he went to see them,
+you'll see that the dates of travel relate to
+the dates of his meeting with the victims.
+Does that make sense?
+A GRAND JUROR: Yes.
+BY
+Is there anything else, Special Agent
+, that I should add to that?
+No. It will become clear once we
+testify about the travel count.
+
+
+17
+A GRAND JUROR: Can I just ask which
+airport is ISM?
+THE WITNESS: You know, I can in the
+next session, I would be happy to bring the
+airport codes.
+A GRAND JUROR: Okay.
+THE WITNESS: Obviously, we focused in
+on his times when he traveled into the Palm
+Beach County area and that would be PBIA or
+PBI, but I can certainly provide all the
+airport codes at our next session.
+BY
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+All right. Now throughout the Overt
+Acts portion where there are discussions of
+various Jane Does, there will be mentioned a
+telephone call.
+So, for example, if you 1o0k at Page
+Ten, Paragraph 17, it says on or about April 23rd,
+2004, Defendant
+placed a telephone
+call to a telephone used by Jane Doe Number Iwo.
+Do you see that?
+Yes.
+And Special Agent
+what is
+the evidence that we have related to the telephone
+calls that are mentioned in the Overt Acts?
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+18
+We have issued administrative subpoenas
+to telecommunication companies for cell phone
+records for Mr. Epstein's assistants as well as
+many of the Jane Does.
+These specific Overt Acts are reflected
+in those telephone records and we have also
+prepared for the grand jury -- I brought with me
+today, and I will bring with me next time, all of
+the telephone records for -- that we have received
+via administrative subpoenas.
+Today I brought the ones pertaining to
+the Overt Acts and what we have done is we have
+taken those cell phone records and we have marked
+for the grand jury all the Overt Acts that are
+listed in the indictment.
+You'll note when you go to that page,
+there will be a little mark by the telephone call
+that we are specifically talking about in the
+Overt Acts.
+And can you just remind the grand jury
+what information will be on those records?
+It will be telephonic contact between
+oI
+telephonic contact between his
+assistants and the Jane Does.
+
+
+19
+Q
+It will show
+the telephone number that
+was called and the dates and time and length of
+the call?
+Yes, it will.
+All right.
+Any questions before we
+start talking about the sexual activity
+between the defendant and the victims? Okay.
+No questions.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY
+Let's talk first about Jane Does One and
+Two. They are grouped together in Overt Acts One
+through 18. Who is Jane Doe Number One?
+Jane Doe Number One is a white female.
+Her name is Virginia.
+She was born in August of
+1983 and she lived in the Palm Beach County area
+during the time that she had contact with Mr.
+Epstein.
+Has she been interviewed?
+Statements have been provided to the FBI
+by Jane Doe Number One.
+In addition to her statements, who else
+has provided information regarding Jane Doe Number
+One?
+Jane Doe Number Iwo and Jane Doe Number
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+20
+One's boyfriend at the time she had contact with
+Mr. Epstein, which is
+e Who is referred to as
+• in the
+indictment?
+Yes.
+During what period of time, did Jane Doe
+Number One have contact with Mr. Epstein?
+Jane Doe Number One met Mr. Epstein when
+she was 15. So that would be in the last half of
+1998 until 2003 that we are aware of.
+How did she meet Jeffrey Epstein?
+She met Mr. Epstein at age 15 and
+according to her boyfriend when she was 20, Mr.
+Epstein sent her to Thailand for massage therapy
+school.
+So she -- the time frame that she was
+with Mr. Epstein was from the age of 15 until we
+are aware of is age 20.
+never
+saw Jane Doe Number One again after she went to
+Thailand.
+She would contact him by telephone, but
+she never returned back.
+He stated he inherited
+her dog. She never came back that he is aware of.
+So the time frame that we had Jane Doe Number One
+with Mr. Epstein is from age 15 to 20.
+
+
+21
+I'm sorry, the question you asked me
+was: How did they meet? They met by a friend of
+Mr. Epstein's. Jane Doe Number One was working at
+Mar-a-Lago and a friend of Mr. Epstein's,
+Ghislaine Maxwell.
+Would you like the spelling?
+THE REPORTER: Yes, please.
+THE WITNESS: G-| I-S-L-A-I-N-•
+Maxwell, who was a friend of Mr. Epstein, met
+Jane Doe Number One at Mar-a-Lago and Jane
+Doe Number One soon after began working and
+providing massages for Mr. Epstein.
+BY
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+What sexual activity was Jane Doe Number
+One involved in with Jeffrey Epstein?
+Through the statements provided by Jane
+Doe Number Two, when Jane Doe Number Iwo was 14
+years of age, she saw Jane Doe Number One naked
+and engaged in what she believed to be sexual
+intercourse with Mr. Epstein.
+Now did Jane Doe Number One recruit any
+one else to go to Jeffrey Epstein's home?
+At this time, the only Jane Doe that we
+are aware of is Jane Doe Number Iwo or the only
+individual we are aware of is Jane Doe Number Iwo.
+
+
+22
+1
+2
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Okay. So let's talk about Jane Doe
+Number Iwo. Who is she?
+Jane Doe Number Iwo is a white female
+named Carolyn. She was born in January of 1987.
+She lived in Palm Beach County, Florida, at the
+time she had contact with Mr. Epstein.
+And how --
+has
+she been interviewed?
+Yes.
+During - how old was she during the
+time frame that Jane Doe Number Iwo was involved
+with Mr. Epstein?
+She was 14 at the time that she first
+met Mr. Epstein.
+And she was involved with him until she
+was 17?
+We have in or about the beginning of
+2001, which would make her 14 up until 2004.
+And how did she come to meet Mr.
+Epstein?
+Jane Doe Number One brought Jane Doe
+Number Iwo to Mr. Epstein's residence for the
+first time. Mr. Epstein was introduced to Jane
+Doe Number Iwo by Jane Doe Number One.
+There was a massage that took place with
+the two of them and then Jane Doe Number One
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+23
+engaged in sexual activity that I mentioned
+earlier where Jane Doe Number Iwo informed us that
+she sat on the couch and observed what she
+believed the two of them
+to engage in sexual
+intercourse.
+And at the time, Jane Doe Number One was
+17 and Jane Doe Number Two was 14?
+Yes.
+All right.
+And I'm not sure if that was actually
+the first or second visit that she went. So it
+was either the first visit or the second that the
+sexual activity that I described took place.
+They may have gone there the first time
+and just performed a massage for Mr. Epstein, but
+on the second occasion the sexual activity that I
+described took place.
+Jane Doe Number Iwo stated that, you
+know, the three years that we discussed from 2001
+to 2004, she provided Mr. Epstein with over, in
+that three-year period, over 100 massages and all
+but three of the massages were sexually in nature.
+How much was she paid for performing
+sexual massages for Epstein?
+She was paid between 200 and $400.
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+24
+Originally, she was paid $300 when she starting
+performing massages for Mr. Epstein. On at least
+two occasions, Mr. Epstein offered her $100 more
+if she would take off her underwear, which she
+did, and on those two occasions she was paid
+$400.
+When Jane Doe Number Iwo expressed to
+Mr. Epstein that she did not want him touching her
+vagina, Jane Doe Number Iwo informed us that he
+dropped the amount to $200.
+She would also receive $100 for bringing
+any girls.
+All right. Now you said that on all but
+three occasions with Jane Doe Number Iwo, the
+massages were sexual.
+Did Jeffrey Epstein
+masturbate during those massages?
+Yes, he did.
+• Did he instruct Jane Doe Number Iwo to
+do anything while he was masturbating?
+Yes. He asked her to rub and pinch his
+nipples.
+And these started when she was still 14?
+Yes.
+What was the involvement of
+with Jane Doe Number Iwo?
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+• 16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+25
+Sarah would schedule Jane Doe Number Iwo
+and sometimes Sarah would be out of town and be in
+New York and scheduled her to come and work, but
+primary role was to schedule or I
+guess she was the one that would schedule Jane Doe
+Number Iwo to come and perform the massages.
+Did
+lever actually lead Jane
+Doe Number Iwo upstairs up to the bedroom?
+Yes. After Jane Doe Number One took
+Jane Doe Number Iwo, Jane Doe Number Iwo started
+going by herself. The first time that Jane Doe
+Number Iwo arrived at Mr. Epstein's by herself,
+took Jane Doe Number Two from the
+kitchen and took her upstairs for the massage that
+was to be performed for Mr. Epstein.
+Now you mentioned the sexual activity
+that Jane Doe Number two observed between Jane Doe
+Number One and Mr. Epstein.
+Was there ever any
+other females involved in the sexual activity?
+Yes. Mr. Epstein introduced an
+unidentified female who performed oral sex on Jane
+Doe Number One -- I'm sorry, on Jane Doe Number
+Two while Mr. Epstein had sexual intercourse with
+the unidentified female.
+Now you mentioned that at some point,
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+26
+Mr. Epstein asked Jane Doe Number Iwo to start
+bringing girls; is that correct?
+Yes.
+And did he describe what exactly he
+wants, the type of person that he wanted her to
+bring? Did she report that he asked her if she
+had any younger friends that would be interested
+in performing massages?
+Yes. He asked her -- can I just have a
+moment?
+Of course, yes.
+I'm sorry. Jane Doe Number Iwo, Mr.
+Epstein asked her if she had any friends that
+would be interested in performing these massages
+and then he also inquired if she had any younger
+friends that would -- that she could bring to him
+and then he offered to pay her $100 for each
+person that she brought.
+• In addition to the sexual activity with
+Mr. Epstein, did
+ever involve Jane
+Doe Number Iwo in any specific activity?
+Yes.
+contacted Jane Doe
+Number Iwo by telephone and asked her to come to
+Mr. Epstein's residence that Mr. Epstein wanted
+Sarah to take pictures of Jane Doe Number Iwo.
+
+
+27
+Sarah paid Jane Doe Number Iwo $500 to
+take naked photographs of Jane Doe Number Iwo at
+Mr. Epstein's residence in and around the house
+and pool area at the request of Mr. Epstein.
+And approximately how old or how old
+does Jane Doe Number Two believe she was at the
+time?
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10'
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Jane Doe Number Iwo informed us that she
+was 16 years old when
+took the
+photographs of her naked.
+What did Jane Doe Number Iwo say about
+whether Jeffrey Epstein knew her true age?
+Jane Doe Number Iwo was informed by Jane
+Doe Number One to say if asked her age that she
+was -- she should respond that she was 17. When
+they went -- and went to Mr. Epstein's residence
+and were upstairs performing massages, Mr. Epstein
+asked Jane Doe Number Iwo her age.
+She responded four --. And then he
+said, so you're 14? And Mr. Epstein informed Jane
+Doe Number Iwo that they would just keep that
+between them.
+So in other words, he knew that she was
+14 when she started seeing him?
+Yes. She did not remember to say 17 and
+
+
+28
+just naturally came out four --. And then he
+finished that statement for her, so you're 14?
+And then stated that they would keep that between
+them.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Now is the -- can you summarize -- does
+your testimony cover the evidence supporting the
+allegations in Overt Acts One through 18?
+Yes, it does.
+And if I could ask you to refer to Count
+Two, which appears on Page 38. Is the evidence
+that you have just summarized the basis for the
+allegation that Jeffrey Epstein and
+procured Jane Doe Number Two to engage in
+commercial sex acts knowing that she was under 18?
+Yes.
+So is there anything else that you
+wanted to mention with respect to either Jane Doe
+Numbers One or Two?
+The only other thing I didn't bring up
+was the gifts that Mr. Epstein provided to Jane
+Doe Number Iwo and Mr. Epstein would provide her
+with lingerie.
+He gave her tickets to a concert, a
+local concert. He would also send her via FedEx
+packages to her residence, and in one of those
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+. 24
+25
+29
+packages
+Jane Doe Number Two informed us that
+there was a Massage for Dummies book that she
+received by FedEx from Mr. Epstein.
+And the grand jury should know that we
+have received records from FedEx which corroborate
+Mr. Epstein's address and packages going to Jane
+Doe Number Two's residence.
+And those records relate to Mr.
+Epstein's personal Federal Express account?
+Yes.
+A GRAND JUROR: Jane Doe Number Two, do
+we know how old she was when Mr. Epstein
+asked her to bring younger friends? Was she
+already in his eyes up there and he wanted
+them younger?
+THE WITNESS: When Jane Doe Number Two
+was 16, about midway through her 16th year,
+she became pregnant and at that point she did
+not provide Mr. Epstein with anymore
+massages.
+So I know she went away for a time
+period and when she came back, you know, she
+had a son and did not want to do massages
+anymore. So at that point, she may have
+brought her friends as well as prior to that.
+
+
+30
+BY
+Do you know exactly when she started
+bringing other girls?
+I don't know that I want to say that it
+was before or after.
+we just know that she was
+asked by Mr. Epstein to bring other females and he
+would pay $100.
+The only other thing we haven't talked
+about is we have message pads that were recovered
+in the execution of the state search warrant on
+Mr. Epstein's residence, and I think the grand
+jury has seen copies of some of those message
+pads.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+We do have a message pad for Jane Doe
+Number Iwo that gives you an example of -- and I
+can pull that out and read that to
+the grand jury,
+if you would like?
+Sure.
+This particular message pad is
+basically -- it's a carbon copy message that again
+was recovered during the execution of the state
+search warrant at Mr. Epstein's residence and this
+shows that this was dated on March 11, 2003.
+It's from Carolyn with her phone number
+land it's marked that
+she telephoned and it's
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+31
+marked, please call, and it was signed by one of
+Mr. Epstein's employees. So again the date that
+the contact here is March 11, 2003.
+Q
+And Jane Doe Number Iwo was still under
+the age of 18 at that
+time?
+Yes, she was.
+Okay. Now if we could turn to Jane Doe
+Number Three and who is she?
+Jane Doe Number Three is a white female
+named Cortney. She was born October 1987 and she
+lived in the Palm Beach County area.
+Has she been interviewed?
+Yes.
+And during what period of time did Jane
+Doe Number Three have
+contact with Jeffrey
+Epstein?
+Beginning in or around 2003 to up 2005.
+And how old was she during that time
+frame?
+Epstein.
+She was 15 when
+• she first met Mr.
+And how did she meet him?
+Jane Doe Number Two brought Jane Doe
+Number Three to Mr. Epstein's house. They
+traveled by taxi there.
+Jane Doe Number Iwo took
+
+
+32
+Jane Doe Number Three upstairs to meet Mr.
+Epstein.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+They provided Mr. Epstein a massage in
+their underwear. Mr. Epstein asked Jane Doe
+Number Iwo to leave and Jane Doe Number Three
+finished the massage.
+Mr. Epstein masturbated in front of Jane
+Doe Number Three on that first occasion, and Jane
+Doe Number Three, after the massage, she was paid
+$200 and she left the residence.
+All right.
+On other occasions after that,
+would be the one to contact Jane Doe Number
+Three to come to the residence to provide massages
+for Mr. Epstein.
+And you have phone records showing calls
+phone to Jane Doe Number
+from
+Three's phone?
+Yes, I do.
+In addition to that, the masturbation
+during that massage, was there other sexual
+activity that occurred between the two of them?
+Yes, there was. Mr. Epstein requested
+that Jane Doe Number Three rub his chest and
+nipples while he masturbated. He also used a
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+• 18
+19
+20
+21
+22
+23
+24
+25
+33
+massager slash vibrator on Jane Doe Number Three's
+vagina.
+He touched Jane Doe Number Three's
+vagina. He also instructed Jane Doe Number Three
+to straddle an unidentified female and fondle the
+unidentified female as he used she believed it was
+a vibrator or a
+massaging device on the
+unidentified female's vagina.
+And on each of those occasions was she
+paid?
+Yes, she was.
+And did she tell you about the range of
+of money that she would receive for each visit?
+She received $200 for the time period
+when she would provide Mr. Epstein during the
+massages.
+Did Jane Doe Number Three recruit anyone
+to go Mr. Epstein's house?
+Yes.
+And did she tell you anything about what
+Epstein's requests were in terms of who she should
+bring?
+Yes. Mr. Epstein asked her to bring
+other females. Jane Doe Number Three stated that
+Mr. Epstein's preferences were short little white
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+34
+girls. Jane Doe Number Three brought girls ages
+15 to 25 years of age.
+Were there girls whom Jane Doe Number
+Three brought to Mr.
+Epstein's home whom he did
+not like?
+A Yes. Mr. Epstein informed Jane Doe
+Number Three that he didn't want girls with
+tattoos, older girls, or black girls.
+He also expressed frustration with Jane
+Doe Number Three when she didn't have new females
+for him.
+• And how would he express that
+frustration?
+A He hung up on her. He telephoned her.
+He also would telephone her.
+and Mr.
+Epstein would call Jane Doe Number Three and on
+this particular occasion when she didn't have a
+female for him, he hung up.
+Now if we could go back to the girls
+whom Mr. Epstein didn't like. You said older
+girls, girls with tattoos, and black girls. When
+Jane Doe Number Three brought those girls to his
+home, did he allow them to massage him?
+No.
+So those girls were just sent away?
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+35
+coming.
+They were, but they were paid for
+Now if I could just refer you to overt
+Acts 29 and 31, which are on Page 12. There is a
+reference to two written telephone messages and
+could you just remind the grand jury of where that
+information comes from?
+I actually have copies. Overt Acts 29
+and 31 are message pads or carbon copy messages
+that were found at Mr. Epstein's residence when
+the Town of Palm Beach Police Department executed
+a state search warrant on his residence.
+The first one, Overt Act 29, is a
+message dated November 8, 2004. It was taken at
+1:15 p.m. The message is for Mr. Epstein from
+Cortney with her cell phone number and in
+quotations it says, I have a female for him. At
+the bottom is an employee of Mr. Epstein, the
+house manager, Alfredo Rodriguez.
+Overt Act 31 is a message for Mr.
+Epstein dated January 29, 2005. It 100ks like the
+time was 4:10 p.m. It is from Cortney with her
+phone number on it and in quotations, I have a
+female for him. Again, initialed by Mr. Epstein's
+house manager, Alfredo Rodriguez.
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+36
+Q
+Now does your testimony today summarize
+the evidence supporting the allegations in Overt
+Acts 19 through 31?
+Yes.
+And if I could just refer you to Count
+12, which appears on Pages 40 and 41 of the
+proposed indictment.
+Is this the evidence that
+you just summarized the basis for the allegations
+that Jeffrey Epstein and
+used a
+facility of interstate commerce to persuade,
+induce, and entice Jane Doe Number Three to engage
+in prostitution and in sexual activity for which a
+person can be charged with a criminal offense?
+Yes.
+Was Jane Doe Number Three under the age
+of 16 during part of her interactions with Mr.
+Epstein?
+Yes, she was.
+And under Florida law, could Mr. Epstein
+have been charged with lewd and lascivious
+molestation, lewd and lascivious conduct, and lewd
+and lascivious exhibition based upon his touching
+of Jane Doe Number Three's breasts, genitals, his
+solicitation of Jane Doe Number Three in a lewd
+and lascivious act and his masturbation and
+
+
+37
+exposure of his genitals to her?
+Yes.
+Q
+All right. Let's turn to Jane Does
+Four, Five, and Six, please, and could you tell
+the grand jury who Four,
+Five and Six are?
+A Jane Doe Four,
+Number Four is a white
+female named Danielle.
+She was born in August
+1986. She attended both Wellington High School
+and Palm Beach Central High School in Palm Beach
+County.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Jane Doe Number Five is a white female
+named
+She was born in October of 1986.
+she attended Wellington High School in Palm Beach
+County, Florida.
+Jane Doe Number Six is a white female
+named Jennifer. She was born in June of 1987 and
+she attended Palm Beach Central High School in
+Palm Beach County, Florida.
+Have the three Jane Does Four, Five, and
+Six been interviewed?
+Yes.
+And during what period of time did they
+have contact with Jeffrey Epstein?
+In or around the first half of 2004
+possibly going into the summer months is when we
+
+
+))
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+38
+first have them having contact, I believe, they
+have contact with Mr. Epstein.
+And how old were they during that time
+frame in early 2004?
+A Both Jane Doe Numbers Four and Five
+would have been 17 at that time, and Jane Doe
+Number Six would have been 16.
+What sexually activity did Jane Does
+Four and Five engage in with Jeffrey Epstein?
+Jane Doe Numbers Four and Five took a
+taxi to Mr. Epstein's house and went upstairs and
+provided Mr. Epstein a massage. Jane Doe Numbers
+Four and Five, the sexual contact that took place
+was or conduct was that Mr. Epstein masturbated in
+the presence of both Jane Doe Number Four and Jane
+Doe Number Five.
+He also instructed Jane Doe Number Four
+to play with his nipples and rub his chest. Both
+Jane Doe Numbers Four and Five were paid $200 for
+this. On a later massage, Jane Doe Number Four
+had additional sexual activity with Mr. Epstein
+and Mr. Epstein had instructed or requested Jane
+Doe Number Four to take off her clothing and wear
+her underwear, which she complied.
+During that massage, Jane Doe Number
+
+
+39
+Four's underwear was pulled aside by Mr. Epstein
+and he stroked her vagina.
+And she was paid following that massage
+as well?
+:)
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Yes, she was.
+Who led Jane Does Four and Five up to
+the bedroom during that first massage?
+Jane Does Four and Five went upstairs.
+They were taken upstairs by
+And what evidence is there regarding
+Jeffrey Epstein's knowledge of Jane Doe Number
+Four's true age?
+Jane Doe Number Four told Mr. Epstein
+how old she was.
+In respond to his question about her
+age?
+Yes. I'm sorry.
+Mr. Epstein asked her
+age and she informed Mr. Epstein of her true age
+at the time.
+& Now during -- you mentioned that the
+first massage that the two of them were together,
+Jane Does Four and Five, and did Mr. Epstein
+masturbate in front of them at that time?
+A Yes, he did, and I should say that Mr.
+Epstein requested them to remove their clothing
+
+
+40
+during that massage as well.
+• Okay. And did he ever instruct Jane Doe
+Number Four to play with his nipples?
+Yes.
+You said that Jane Doe Number Four
+returned after that first massage, correct?
+Yes.
+& How was she contacted to set up those
+later massages?
+Jane Doe Number Four was contacted by
+:)
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Via telephone?
+Via telephone, yes.
+Did Jane Doe Number Four bring anyone
+else to jeffrey Epstein's home?
+Jane Doe Number Four brought Jane Doe
+Number Six. Jane Doe Number Four and Jane Doe
+Number Six performed the massage together and then
+Jane Doe Number Four was asked to leave.
+At that point, the sexual activity that
+was performed on Jane Doe Number Six by Mr.
+Epstein was the digital penetration of Jane Doe
+Number Six's vagina as well as the use of a
+massager slash vibrator on Jane Doe Number Six's
+vagina. He did masturbate.
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+41
+He did pay Jane Doe Number Six $200 for
+that massage, and Jane Doe Number Six did not
+return again after that massage.
+& Did Mr. Epstein ask anything related to
+Jane Doe in terms of her age or something that
+would indicate her age?
+He asked them where they went to high
+school.
+And did she respond?
+Yes, she told him she went to Palm Beach
+Central.
+Does your testimony cover the evidence
+supporting the allegations in Overt Acts 32
+through 45?
+Yes.
+And if I could refer you to Count Three,
+which is on Page 39, is the evidence that you just
+summarized the basis for the allegation that
+Jeffrey Epstein and
+procured Jane Doe
+Number Four to engage in commercial sex acts
+knowing that she was under 18?
+Yes.
+e
+So in other words, Jeffrey Epstein knew
+her age before he asked her that the second time?
+Yes.
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+12
+And referring to Count 13, which is on
+Page 41 and 42, is this evidence that you just
+summarized the basis for the allegations that
+used a facility
+Jeffrey Epstein and
+of interstate commerce to persuade, induce, and
+entice Jane Doe Number Four to engage in
+prostitution?
+Yes. We have the testimony of Jane Doe
+Numbers Four, Five, and Six as well as others and
+we also have telephonic contact between Jane Doe
+Number Five by
+just shortly before
+her 18th birthday.
+• All right. If I could refer you to Jane
+Does Number Nine and Ten at this point. The Overt
+Acts related to them start on Page 17.
+Let's start with Jane Doe Number Nine.
+Can you remind the grand jury who Jane Doe Number
+Nine is?
+Jane Doe Number Nine is a white female
+named Alex. She was born in December of 1986 and
+she attended Royal Palm Beach High School.
+And have you testified about her
+previously?
+Yes.
+Is there anything that you want to
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+43
+either clarify or add regarding your earlier
+testimony?
+A There is one thing that I'd like to add
+that I didn't testify to earlier about an incident
+that occurred in November, specifically, November
+28, 2004.
+Jane Doe Number Nine was 17 years of age
+and we have a police document in the Town of Palm
+Beach that shows that Jane Doe Number One -- I
+mean, Jane Doe Number Nine was provided with an
+envelope filled with money
+i that Mr. Epstein had
+arranged for one of his employees to give Jane Doe
+Number Nine.
+The reason the Palm Beach Police
+Department were called in is the employee didn't
+recognize Jane Doe Number Nine's car, which was
+parked in the driveway. So he contacted the
+police.
+Once the police came out though, Mr.
+Epstein's employee went and retrieved an envelope
+and it had money in it. The employee told the
+police that Jane Doe Number Nine was a massage
+therapist and continued with the officer stating
+off the record that Mr. Epstein had many young
+girls that come over for that.
+
+
+14
+And that related to Overt Act Number 80
+on Page 18?
+Yes, it does.
+Okay. And can you just remind the grand
+jury during what period of time Jane Doe Number
+Nine had contact with Jeffrey Epstein?
+Jane Doe Number Nine had contract
+between July 2004 and September of 2005, during
+that time period.
+And how old was she during that time
+))
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+frame?
+She was 17 up until her birthday, which
+is the end of December of 2004, but continued to
+have contact with Mr. Epstein after she was 18.
+And can you summarize the sexual
+activity that Jane Doe Number Nine was involved in
+with Mr. Epstein?
+Yes. Mr. Epstein fondled Jane Doe
+Number Nine's breasts. Mr. Epstein masturbated
+in front of Jane Doe Number Nine. Mr. Epstein
+used a massager slash vibrator on Jane Doe Number
+Nine's vagina.
+He digitally penetrated Jane Doe Number
+Nine. He performed oral sex on Jane Doe Number
+Nine. Mr. Epstein forcibly inserted his penis
+OFFICIAL REPORTING SERVICE, LUC
+
+
+45
+into the vaginal of Jane Doe Number Nine.
+Jane Doe Number Nine watched per Mr.
+Epstein's request as Mr.
+Epstein engaged in oral
+sex and sexual intercourse with
+Mr. Epstein paid Jane Doe Number Nine to
+perform oral sex on
+When Jane
+Doe Number Nine didn't want to do that, Mr.
+Epstein offered her an additional $200 if Jane Doe
+Number Nine would perform oral sex on
+for five minutes, which Jane Doe Number
+Nine did.
+• And how much was Jane Doe Number Nine
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+paid?
+Jane Doe Number Nine was paid -- on the
+first visit we have that she was paid $200. She
+was paid anywhere from $300 to $1,000.
+And what did that depend on?
+The sexual activity. $300 to $600 was
+the sexual activity. The one time we have noted
+that she was given $1,000 was when he forcibly
+'inserted himself inside of her.
+& And you mentioned that Jane Doe Number
+Nine was still seeing Mr. Epstein after she turned
+18. What evidence do you have that corroborates
+her statements that these activities that we are
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+46
+talking about occurred before she was 18?
+We have phone records. We have message
+pads.
+We have obtained documents that are from
+Majestic Theater and from Jet Blue that indicate
+that Mr. Epstein purchased a ticket for Jane Doe
+Number Nine for her 18th birthday.
+She actually flew to New York on her
+18th birthday. Mr. Epstein thought it would be
+better for her to travel when she turned 18. So
+she traveled to New York and Mr. Epstein purchased
+tickets -- or paid for her to see the Phantom of
+the Opera, which was being performed at the
+Majestic Theater.
+Now when you say Mr. Epstein, who was
+actually making the calls?
+I'm sorry. Mr. Epstein's assistant,
+Okay. Let's talk about Jane Doe Number
+Ten as well because they are related. Can you
+remind the grand jury who Jane Doe Number Ten is?
+Jane Doe Number Ten is a white female
+named Britney and she was born in February 1987.
+She attended Lake Worth High School, and I talked
+about her prior.
+You have talked about her previously?
+
+
+47
+yes.
+Is there anything that you want to
+clarify or add related to that testimony?
+No, nothing.
+And can you remind the grand jury during
+what period of time Jane Doe Number Ten was
+involved with Mr. Epstein?
+She went to Mr. Epstein's residence in
+July of 2004 to November 2005. We have her still
+in contact with Mr. Epstein.
+And how old was she during that time
+1
+2
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+frame?
+She was 17. Up until February of 2005,
+she turned 18.
+And how is Jane Doe Number Ten related
+to Jane Doe Number Nine in connection with these
+events?
+Jane Doe Number Nine brought Jane Doe
+Number Ten to Mr. Epstein's residence.
+Now if I could refer you to overt Act
+Number 67, and it says on or about July 16, 2004,
+Defendant
+caused Jane Doe Number Nine
+to make one or more telephone calls to a telephone
+used by Jane Doe Number Ten.
+Do you see that?
+
+
+1
+2
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+18
+Yes.
+Can you tell us in addition to the
+testimony from Jane Doe Number Nine what the
+telephone records show?
+An examination of Jane Doe Number Nine's
+cell phone records show that she contacted Jane
+Doe Number Ten, and if you examine
+records you will see that there was contact
+between Jane Doe Number Nine and
+On the same day?
+On the same day.
+All right. What was the sexual activity
+that Jane Doe Number Ten was involved with, with
+Jeffrey Epstein?
+A I'm sorry. One second. I just want to
+1ook at this. Okay. I'm sorry. What was your
+question?
+What was the sexual activity that Jane
+Doe Number Ien was involved in with Mr. Epstein?
+Mr. Epstein fondled Jane Doe Number
+Ten's breasts. Mr. Epstein masturbated in front
+of Jane Doe Number Ten. Mr. Epstein used a
+massager slash vibrator on
+Jane Doe Number Ten's
+vagina, and he also touched Jane Doe Number Ten's
+vagina.
+
+
+49
+Q
+receive?
+How much did Jane Doe Number Ten
+Jane Doe Number Ten was paid $200.
+And she went to Mr. Epstein's home more
+than once?
+Yes.
+Can you give the grand jury an idea of
+how many phone calls there were between
+and Jane Doe Number Nine Alex?
+Yes. There were approximately 225 phone
+calls.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+And they are
+in the documents and
+records that you have?
+Yes.
+And what about Jane Doe Number Ten?
+There were over 100 phones calls between
+and Jane Doe Number Ten, and there
+were also phone calls between Jane Doe Number Ten
+and
+and those were approximately
+eight calls between Jane Doe Number Ten and
+with only one being prior to her 18th
+birthday.
+calls with I
+her 18th birthday.
+There were also approximately seven
+I with all but one after
+That one was actually on her
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+50
+18th birthday.
+• And those calls that you are referring
+to relate only to the cellular telephone records
+that you have, correct?
+Yes. i
+So if there were
+calls from Jeffrey
+Epstein's phone numbers
+to or from that number
+that couldn't necessarily be captured?
+No.
+Okay. Now if I could just ask you to
+look at Count Four.
+Does your testimony today and
+your prior testimony summarize the basis for the
+allegation that Jeffrey Epstein and
+procured Jane Doe Number Nine to engage in
+commercial sex acts knowing she was under 18?
+Yes.
+And in Count 15 is the evidence that you
+just summarized the basis for the allegation that
+Jeffrey Epstein and
+used a facility
+of interstate commerce to persuade, induce, and
+entice Jane Doe Number Nine to engage in
+prostitution?
+Yes.
+And also the offense charges using a
+facility of interstate commerce to persuade,
+
+
+51
+induce, and entice Jane Doe Number Nine to engage
+in sexual activity for which the person can be
+charged with a criminal offense.
+With respect to Jane Doe Number Nine,
+what is this offense
+that Mr. Epstein could have
+been charged with, with respect to that activity
+with her?
+The sexual intercourse where Mr. Epstein
+penetrated Jane Doe Number Nine's vagina with his
+penis.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25.
+And then with respect to Jane Doe Number
+Ten, Count Five charges that Jeffrey Epstein and
+procured Jane Doe Number Ten to
+engage in commercial
+sex acts knowing that she was
+under 18. How do you summarize for us the
+evidence supporting that?
+A Yes. The only thing I'd like to add to
+that is we also do have message pads that were
+obtained through the Town of Palm Beach with the
+execution of the search warrant at Mr. Epstein's
+residence as well as trash pulls that the Town of
+Palm Beach conducted in the spring of '05, 2005,
+and one of those trash pulls I believe -- is it
+Overt Act 81?
+Yes, 81.
+
+
+52
+The trash pull -- found in the trash
+pull conducted by the Town of Palm Beach was
+Jeffrey Epstein's letterhead and on it handwritten
+that says 10:30, Vanessa, and then Britney on
+Friday around 2:00, and then there's a "3"
+underneath it. This was obtained on April 1st,
+2005.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+And then the message pad that I referred
+to -- I'm sorry, the trash pull was Overt Act 147.
+The Overt Act was 81, and that message pad is --
+that message is from Jeffrey Epstein dated
+December 4, 2004. The time is 2:55 p.m.
+The message is from Sarah and it's
+written, Britney would like to work at 4:00 p.m.
+if possible, and then in parenthesis, Alex is
+scheduled for 5:00 today. At the bottom it says,
+the movie is at 7:30.
+And you said that was written by
+and it's addressed to
+Defendant
+Jeffrey Epstein?
+Yes.
+THE FOREPERSON: We need a break.
+Okay. Should we take
+ten minutes?
+THE FOREPERSON: Is this a good time?
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+53
+: This is fine.
+(Witness exits the Grand Jury Room.)
+(Thereupon, a short break was
+taken.)
+(Witness enters
+the Grand Jury Room.)
+: We are back on
+the
+record. Is there a quorum?
+THE FOREPERSON: Yes.
+BY
+:
+we were just finishing up with Jane Doe
+Number Ten. Special Agent |
+•. you
+summarized a lot of evidence relating to Jane Doe
+Number Ten.
+Is the evidence that you summarized also
+the basis for the allegation in Count 16 that
+Jeffrey Epstein and
+used a facility
+of interstate commerce
+to persuade, induce, and
+entice Jane Doe Number Ten to engage in
+prostitution?
+Yes.
+Okay.
+I just want to review with you,
+Special Agent
+• that you did, in fact,
+previously testify about background information
+regarding the defendants in this indictment?
+Yes.
+And that was in one of your earlier
+
+
+54
+transcripts?
+Yes.
+Okay. I also
+wanted to ask you about
+the victims who we have
+discussed today. We have
+discussed eight victims, Jane Does
+One through Six
+and Nine and Ten.
+Are you aware of whether any of those
+victims have used illicit drugs or have had
+mental health issues?
+Yes.
+And can you summarize that for the grand
+jury?
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Jane Doe Number -- we'll start with Jane
+Doe Number Iwo. After the contact or during the
+contact, but after she had met Mr. Epstein, Jane
+Doe Number Iwo started using between ages 15 and
+17.
+I guess what I am trying to say is that
+she first had contact with Mr. Epstein when she
+was 14 years of age. So when I interviewed Jane
+Doe Number Iwo, she informed me that her drug use
+started between the ages 15 to.17.
+She had a history of drug abuse.
+She
+informed us that she has used Xanax, Ecstasy,
+marijuana, cocaine and she has tried to commit
+OFFICIAL
+REPORTING SERVICE, LIC
+
+
+55
+suicide in the past.
+Her mother had
+her. Jane
+Doe Number Iwo told me that helped her withdraw
+from drug use. For those of you that are not
+familiar with the term Baker Act, if you are
+believed to be a danger to yourself or to others,
+you can be
+and that's what her mother
+did.
+Meaning you can be committed to a mental
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+institution?
+Yes. And did you ask me about mental
+health issues?
+I did.
+And she had also been in a mental
+facility, Columbia Pavilion, three or four times
+she was there between the ages of 15 and 17 and
+then once or twice after the age of 17.
+Jane Doe Number Iwo revealed to us that
+when she was very young, she was molested by a
+family member and has suffered from that ever
+since.
+Any other Jane Does?
+Yes. Jane Doe Number Three also has a
+history of drug abuse. Her drug abuse began at
+age 15. Her parents were addicted to cocaine and
+
+
+1
+2
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+56
+crack.
+She dropped out of school at an early age.
+Her drug use, some of the drugs she
+shared with us that she
+has used is Xanax, Lorcet,
+and Perocet. Jane Doe Number Three expressed that
+she just wanted to feel numb.
+She stayed with a lot of -- she did not
+stay at home a lot after age 15 due to the fact
+that her parents had such a drug -- addiction to
+drugs. And I'm not aware of, you know, any mental
+health issues with her.
+Okay.
+And then the last Jane Doe that we
+talked about would have been Jane Doe Number Nine,
+and we do have information that she has
+used
+marijuana in the past.
+With respect to those Jane Does, did you
+go about getting independent corroboration for
+their statements so that you weren't relying
+exclusive on what they told you about Mr. Epstein?
+Yes. We talked about that today.
+Specifically, with Jane Doe Number Iwo, we have
+her statement, but along with that statement we
+have telephone records.
+Those telephone records indicate
+telephonic contact with
+. We have the
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+57
+message pads recovered during the search warrant,
+recovered during the execution of the state search
+warrant that indicates the contact here.
+We have statements from other Jane Does
+and witnesses that corroborate.
+We also have
+received the FedEx records indicating packages
+were sent to Jane Doe Number Two from Mr.
+Epstein.
+When you look at Jane Doe Number Three,
+the same thing, we have telephone records that
+indicate telephonic contact. We have message pads
+recovered in the state
+search warrant, execution
+of the state search warrant.
+Then we have
+the statements of other
+Jane Does, and in regards to Jane Doe Number Nine,
+again, we have the telephone records which
+indicate telephonic contact with
+We
+have the message pads.
+In addition to that, we have the message
+pads that were recovered by the state search
+warrant and they also found her high school
+transcript. It was found at Mr. Epstein's
+residence.
+• We have statements from other Jane Does,
+and then we also have the records for her from the
+
+
+58
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Jet Blue, you know, showing the travel on her
+birthday. Majestic Theater showing that she
+attended the theater.
+We have -- after her 18th birthday, she
+was involved in a play where Mr. Epstein had his
+assistant deliver flowers
+to the high school. She
+was
+18 at the time, but we
+do have records showing
+the purchase of those flowers and a note with
+instructions for the house manager on what to do
+and how to pick up the flowers and deliver them,
+as well as rental car records.
+So we are not relying exclusively on
+their statements?
+No.
+Okay. Now I know that there has been
+some coverage in the press of civil lawsuits that
+were filed against Mr. Epstein. Are your aware of
+the press coverage?
+Yes.
+And those lawsuits were filed in the
+names of Jane Does Number One, Number Iwo and
+Number Three?
+Yes.
+Are those the Jane Does Number One,
+TwO,
+and Three in our Jane Doe lists?
+
+
+59
+No.
+And are those Jane Does at all in Jane
+Does One through 19 on our new list?
+No.
+If I could ask you to
+step outside. I want to find out if the
+grand jurors have any questions for you.
+(Witness exits the Grand Jury Room.)
+* * *
+(Witness enters the Grand Jury Room.)
+:)
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY
+:
+Special Agent
+, the first
+question was about your last comment relating to
+the civil lawsuits. Are there other victims of
+whom you are aware of or are not on the Jane Doe
+One through 19 list?
+Yes.
+Okay. Now there was a question about
+Jane Doe Number One. You testified that she had
+left to go to Thailand and her boyfriend,
+, her former boyfriend, hadn't had contact
+with her in a long while.
+Have other people had contact with her
+more recently?
+Yes.
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+60
+Including people from the i
+FBI?
+Yes.
+So there is no -- she's not in any harm
+or danger?
+No, and I didn't mean to imply. There
+is also a question of a $3,000 phone bill that
+Jane Doe Number One
+said that she would take care
+of when she got back. She never returned.
+Her stuff that was in their apartment,
+the dog, she never came back, and I think there
+was some concern on his part, but we know where
+Jane Doe Number One is.
+Just so the grand jury knows. Where is
+she living now?
+She's in Australia.
+There also was a question about Jane Doe
+Number Iwo. You testified that she became
+pregnant. Is Mr. Epstein the father of her baby?
+Not that we are aware of.
+okay.
+BY
+Those were all the
+questions. Any follow up on those three
+questions? Okay.
+:
+One of the things I wanted to just
+
+
+61
+discuss with the grand jury is our next
+presentation and I had asked you to bring all of
+the
+items
+that were procured under the grand jury
+subpoena.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Can you tell the grand jury about some
+particularly bulky items that you are hoping they
+will forgo?
+We have from the execution of the state
+search warrant by the Town of Palm Beach, they
+have three massage tables or one chiropractic
+table and two massage tables that are rather
+large, that if you would like to see them, we can
+bring two of the ones that were located upstairs.
+: So what I'd like to do
+is we are going to step outside to leave you
+with some time to review the transcripts of
+the earlier testimony.
+Before you leave, if you could decide
+whether or not you want us to bring those
+large massage tables up from the Miami lock
+up for you to see or if Special Agent
+• description is sufficient.
+A GRAND JUROR: Just bring a picture.
+A GRAND JUROR: How about a picture?
+A GRAND JUROR: Would that be
+
+
+62
+sufficient?
+1
+2
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+: We can do that. We will
+step outside and if that is what you decide,
+that is what we will do, and so what I'm
+going to do now is step outside.
+I have 13 -- I don't know why I
+picked
+13, but we have 13 copies all of the previous
+transcripts. Please take Your time reviewing
+them, and just let us know when you are
+finished and then we will collect all of the
+paperwork that we submitted to you and the
+transcripts and we will bring them the next
+time as well.
+Any questions before I go? We'll just
+be outside. Please feel free to call on us.
+Before we step outside, we also have left
+here the materials that were returned today
+as well as the phone records of the flight
+manifest if you want to take a look at
+those.
+the witness, and the
+court reporter exit the Grand Jury Room.)
+the witness, and the
+court reporter enter the Grand Jury Room.)
+MS.
+We are back on the
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+63
+record. I understand that there was a
+question regarding two of the CDs that were
+in one of the files.
+BY
+:
+Special Agent
+could you
+just tell the grand jury what those are in
+response to?
+These are in response to the subpoena
+that was issued to the custodian of records of
+Bear Sterns and it's basically account statements
+for Mr. Epstein.
+. Okay. And when we come back next time,
+are you planning on bringing computer equipment
+that will allow the grand jury to open the CDs
+that we have?
+Yes. We will have a cassette tape for
+audio tapes. We will have a DVD player. We will
+have a computer. We will have a TV with a VCR.
+We will have all kinds of audio videos and
+electronic equipment for you guys to be able to
+1ook at any of this as well as you will see in
+al1 the grand jury material that we have collected
+things that you may be interested in viewing on
+these visual aids or these audio visual.
+okay.
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+64
+: Any other questions?
+A GRAND JUROR: Are we
+going to get
+pictures of this table thing instead of
+bringing them in?
+A GRAND JUROR: We don't really care.
+picture is sufficient.
+: Okay. We will have
+pictures of the massage tables. Any other
+questions? Are you all finished for today?
+A GRAND JUROR: I don't know. Are we?
+A GRAND JUROR: Yeah, we are.
+: You are finished with
+me.
+Okay. Great. Thank you so much.
+THE WITNESS: Excuse me. Audio visual
+aids will be provided in the next grand jury
+session.
+(Witness was excused.)
+OFFICIAL R950R 469-BZOVICE, IIC.
+
+
+65
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+CERTIFICATE OF REPORTER
+I,
+• Certified Court
+Reporter and Notary Public, do certify that the
+transcript is a true and correct transcription of
+my stenotype notes of the testimony of
+SPECIAL AGENT I.
+the Federal
+Grand Jury, West Palm Beaçh,
+• taken before
+Florida.
+Certified Court
+CSR
+Reporter
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/9db573f7a6dd226b1a6852ea37e0430c19b7f89bdc2e1bdaf5a67874b656f1e0.receipt.json b/vision-fixhub/ds9-unparsed-05/9db573f7a6dd226b1a6852ea37e0430c19b7f89bdc2e1bdaf5a67874b656f1e0.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9cc0536e996ebff6e91bdf8d9681d349320747ab
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9db573f7a6dd226b1a6852ea37e0430c19b7f89bdc2e1bdaf5a67874b656f1e0.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -4088,
+  "dataset": "marble-joined",
+  "doc_id": "9db573f7a6dd226b1a6852ea37e0430c19b7f89bdc2e1bdaf5a67874b656f1e0",
+  "engine": "marble-apple-vision",
+  "event_count": 66,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "358fd441b89bcfbb3f084b8993643fb734b2a94ae42b7eb54da33302c2711625",
+  "output_sha256": "4a8e2302c08fe50f51a0f2dc53d7e86f7290b940707d6f0b84de9e51a10794e2",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/9e90cecfe42072bdde7452a3c3579106b657397dd40977d0ce7c6f8a84f60be2.md b/vision-fixhub/ds9-unparsed-05/9e90cecfe42072bdde7452a3c3579106b657397dd40977d0ce7c6f8a84f60be2.md
new file mode 100644
index 0000000000000000000000000000000000000000..a05cb8ec6b47e7574eb0abe70dacb8b9f3738afd
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9e90cecfe42072bdde7452a3c3579106b657397dd40977d0ce7c6f8a84f60be2.md
@@ -0,0 +1,34 @@
+LIr3S
+
+TOWN OF PALM BEACH
+POLICE DEPARTMENT
+A NATIONAL AND STATE ACCREDITED LAW ENFORCEMENT AGENCY
+July 24, 2006
+(POLICE!
+HAND DELIVERED
+Dear Mr.
+Your daughter
+was the victim of a crime which has been investigated by the Palm
+Beach Police Department and subsequently referred for prosecution lo the Palm Beach
+County State Attorney's Office. You may be aware that Jeffrey Epstein was indicted on
+charges of solicitation for prostitution by a State of Florida grand jury last week and turned
+himself in at the Palm Beach County jail on July 23, 2006. While I do not speak for them,
+it is my understanding that is the full context in which the Palm Beach County State
+Attorney's Office intends to address the charges that involved the crime in which your
+daughter was victim.
+Please know that it is the role and responsibility of law enforcement to investigate crime
+and to refer appropriate charges to the prosecutor for consideration. I believe that the
+Palm Beach Police Department has acted competently and responsibly in carrying out this
+role. Should you have any questions concerning the state prosecution of this matter, they
+are best addressed by the Palm Beach County State Attorney's Office.
+! do not feel that justice has been sufficiently served by the indictment that has been
+issued. Therefore, please know that his matter has been referred to the Federal Bureau
+of investigation to determine if violations of federal law have occurred. In the event that
+the FBI should choose to pursue this matter, the Palm Beach Police Department will assist
+them in their investigation of potential violations of federal law.
+Please feel free to contact me at
+should you have any questions.
+Sincerely,
+MSRint
+345 South Counly Road • Palm Beach. Floride 33480-4143 • (361) 838-5460 • Fox (561) 835.4700 - www.pelmbeachpoiice.com
+
diff --git a/vision-fixhub/ds9-unparsed-05/9e90cecfe42072bdde7452a3c3579106b657397dd40977d0ce7c6f8a84f60be2.receipt.json b/vision-fixhub/ds9-unparsed-05/9e90cecfe42072bdde7452a3c3579106b657397dd40977d0ce7c6f8a84f60be2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f0ed3b58897ef683938fdc29d9026848a788926b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9e90cecfe42072bdde7452a3c3579106b657397dd40977d0ce7c6f8a84f60be2.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -28,
+  "dataset": "marble-joined",
+  "doc_id": "9e90cecfe42072bdde7452a3c3579106b657397dd40977d0ce7c6f8a84f60be2",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "3a329d2d963600b481ab179d72be111c7d7cc55dd0b1696f060ede41a77c7cdd",
+  "output_sha256": "a415cc605b2f1757e22c8dd0892e7ccda72e81b5b3c54eb2264633d7161ab012",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/9ea6b207e24fb9d90e0f7b2c29a35355b7645e2c26f013ce5852877b5f3a2d3a.md b/vision-fixhub/ds9-unparsed-05/9ea6b207e24fb9d90e0f7b2c29a35355b7645e2c26f013ce5852877b5f3a2d3a.md
new file mode 100644
index 0000000000000000000000000000000000000000..734ea9d2ae5da560a82670e1f251751d9dabad0a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9ea6b207e24fb9d90e0f7b2c29a35355b7645e2c26f013ce5852877b5f3a2d3a.md
@@ -0,0 +1,852 @@
+Subject:
+Tuesday, February 19, 2008 2:03 PM
+| (USAFLS)
+Response to questions
+Hope you had a great weekend.
+Well it has not been easy and I dont know if you can make any sense of it.
+Facts:
+land had contact 9 times between (7/15/2004 - 10/26/2004)
+} and had contact 1 time (10/26/2004) This is appears to be
+have cellphone at the time and no calls with •
+Testimony:
+father's phone. We believe we
+and
+Sophomores 02-03
+brought) stated Spring of her Junior year. (Estimated to be Spring 2004)
+stated sophomore year -(this time line does not fit at all)
+and both estimated to be
+stated she went between January and May of Senior year which is believed to be Jan - May 2005. She turned
+18 in Feb 2005. I do not know if she was being truthful about the time of the year or if she was more concerned about
+when she turned 18.
+SOooooowho knows....
+Born in 1986
+graduated from
+graduated from
+12004
+2004
+1624
+P-014584
+
+
+- (USAFLS)
+Subject:
+Friday/ -ebruary 15, 2003 8:55 PM.
+Re: 1 am back with more questions
+I just recvd about 5 emails from you. I do not have my books here. I will
+about. We did hear back frous on and rey were a not ready talk
+with them next week. Sorry I did not get your emails sooner.
+----- Original Message .....-
+Sent: Fri Feb 15 12:56:16 2008
+Subject: RE: I am back with more questions
+Hi
+They both
+other says
+-- Just one more question, I hope. Where did
+go to school?
+a than wont
+to the same school, but one says
+High and the
+And do you know what year (s) they graduated?
+Thanks.
+-Original Messare=;
+Sent: Friday, February 15, 2008 10:36 AM
+Subject: Re: I am back with more questions
+Only pbpd spoke with
+(She was 18 @ the time) but we will interview her and I
+think she will be cooperative. We dont have time frame for
+went
+betwn 10/03-05/04.
+last visit.
+essage
+(USAFLS) <
+Sent: Fri Feb 15 10:10:14 2008
+Subject: RE: I am back with more questions
+Did you ever talk to
+Do we have any time frame, messages, or phone calls for
+Thanks.
+v>
+1626
+P-014585
+
+
+1627
+P-014586
+
+
+Subject:
+Fridav. February 15. 2008 4:48 PM
+High Schools
+(taken by
+(taken
+H.S. (went with
+H.S.(10th) &
+grade year while attending
+stated that both
+and herself were attending
+(taken by.
+(taken by
+11th) -
+believes she may have starting going her 10th
+was taken by
+her lith grade year(both girls born in 87) and
+(went with
+1630
+P-014587
+
+
+Subject:
+Fridav, February 15, 2008 4:50 PM
+RE: High Schools
+Thank you so much! Have a good weekend. I am headed out now, but will work on this at home.
+Itaken by
+-(taken
+H.S.(went with
+H.S.(10th) &
+grade year while attending
+stated that both.
+land herself were attendina
+(taken by,
+(taken by
+11th)
+was taken by
+her
+went with
+believes she may have starting going her 10th
+Tith grade year(both girls born in 87) and
+1632
+P-014588
+
+
+Subject:
+- (USAFLS)
+Friday, February 15, 2008 1:38 PM
+Timeline
+Hi
+senior year.
+- I read
+'s statement. She says she first went with
+She says on the second visit she went with
+This is weird because
+She says on the third visit, she went with
+Assuming |
+2004 (because
+is correct about the order of visits and that
+(called in July 2004).
+Is it safe to say that these events took place In or around the first half of 2004?
+-
+between January and May of her
+says she went with
+was with them on that trip, we are looking around July
+1635
+P-014589
+
+
+Subject:
+Friday. February 15, 2008 1:08 PM
+Do we have a timeframe or any numbers or calls for
+norame or any numbers or also a v
+Thanks.
+1636
+P-014590
+
+
+Subject:
+USAFLS)
+Fridav. February 15, 2008 1:09 PM
+RE: Do we have a timeframe or any numbers or calls for
+Thanks.
+1639
+P-014591
+
+
+Subject:
+Friday, February 15, 2008 12:56 PM
+RE: 1am back with more questions
+Hi
+- Just one more question, I hope. Where did
+go to school?
+They both say they want to the same school, but one says
+High and the
+other says
+• And do you know what year (5) they graduated?
+Thanks.
+-Original Message=.
+February 15, 2008 10:36 AM
+Subject: Re: I am back with more questions
+Only pbpd spoke with
+(She was 18 @ the time) but we will interview her and I
+think she will be cooperative. We dont have time frame for!
+went
+betwn 10/03-05/04.
+last visit.
+Message
+Sent: Fri Feb 15 10:10:14 2008
+Subject: RE: I am back with more questions
+Did you ever talk to
+Do we have any time frame, messages, or phone calls for
+Thanks.
+1640
+P-014592
+
+
+Subject:
+Friday, February 15. 2008 11:48 AM
+Re: 1am back with more questions
+only 1 message no date possible 05/05
+nal Message --
+Sent: Fri Feb 15 11:06:06 2008
+Subject: RE: I am back with more questions
+What is
+'s phone number? Thanks.
+-Original Message
+Faidan
+February 15, 2008 10:36 AM
+Subject: Re:
+I am back with more questions
+Only popd spoke with
+(She was 18 @ the time) but we will interview her and I
+think she will be cooperative. We dont have time frame for
+and
+went
+betwn 10/03-05/04.
+s last visit.
+Message
+Sent: Fri Feb 15 10:10:14 2008
+Subject: RE: I am back with more questions
+Did you ever talk to
+?
+Do we have any time frame, messages, or phone calls for
+Thanks.
+] • gov>
+1.?
+1642
+P-014593
+
+
+Subject:
+Friday. February 15, 2008 11:20 AM
+RE: Tam back with more questions
+I thought I had a complete set of the message pads here, but I only have the
+copies of the messages that have identified girls' names. Can you look through
+the message pads and tell me what the ones from
+say?
+Thank you (so sorry)
+-Original Message-..
+February 15, 2008 10:36 AM
+Subject: Re: I am back with more questions
+Only pbpd spoke with
+(She was 18 @ the time) but we will interview her and I
+think she will be cooperative. We dont have time frame for
+went
+betwn 10/03-05/04.
+last visit.
+Message
+Sent: Fri Feb 15 10:10:14 2008
+Subject: RE: I am back with more questions
+Did you ever talk to
+Do we have any time frame, messages, or phone calls for
+Thanks.
+1644
+P-014594
+
+
+Subject:
+What is
+Friday, February 15, 2008 11:06 AM
+RE: Tam back with more questions
+'s phone number?
+Thanks.
+•----Original Message....
+From: D
+Sent: Eniday February 15, 2008 10:36 AM
+Subject: Re: I am back with more questions
+Only pbpd spoke with
+(She was 18 @ the time) but we will interview her and I
+think she will be cooperative. We
+dont have time frame for !
+went
+betwn 10/03-05/04.
+last visit.
+Message
+USAFLS) <A
+Sent: Fri Feb 15 10:10:14 2008
+Subject: RE: I am back with more questions
+Did you ever talk to
+Do we have any time frame, messages, or phone calls for
+Thanks.
+?
+U.S.
+Attorney
+1646
+P-014595
+
+
+Subject:
+Fridav. February 15, 2008 10:36 AM
+Re: I am back with more questions
+Only pbpd spoke withi
+(She was 18 @ the time) but we will interview her and I
+think she will be cooperative. We dont have time frame for
+went
+betwn 10/03-05/04.
+s last visit.
+Message
+Sent: Fri Feb 15 10:10:14 2008
+Subject: RE: I am back with more questions
+Did you ever talk to
+.?
+Do we have any time frame, messages, or phone calls for
+Thanks.
+1648
+P-014596
+
+
+Fridav, February 15, 2008 10:31 AM
+Hi
+- Didn't you tell me that
+estimated that she brought 100 girls? It isn't in the 302. And did she
+explain what happened during that first massage with Epstein?
+Thanks.
+1650
+P-014597
+
+
+Subject:
+Friday, =ebruary 15, 2008 10:10 AM
+RE: I am back with more questions
+Did you ever talk to
+?
+Do we have any time frame, messages, or phone calls for
+Thanks.
+1654
+?
+P-014598
+
+
+Subject:
+Thursday. February 14, 2008 5:29 PM
+Draft Overt Acts
+Hi guys - Here is the most recent draft. I have only looked at the overt acts sections for the girls we are keeping. Can you
+go through those and check the facts? Also, can you figure out which trips we can drop from the overt acts? I think I only
+so if there are some calls 1 can add, please point those out, too.
+I will turn to the new girls tomorrow.
+Thanks.
+080214 revised
+indictment.pdf
+1658
+P-014599
+
+
+Subject:
+Thursday, February 14, 2008 3:13 PM
+RE: List of names
+I am having a really hard time e-mailing you guys. My e-mails are getting
+bounced back so I have to re-send numerous times until it goes through. Do you
+know if there is something wrong with the FBI's server?
+-Opininal Message....
+Sent: Thursday, February 14, 2008 3:11 PM
+Subject: RE: List of names
+-Original Message-
+Sent.
+Thursday,
+February 14, 2008 3:10 PM
+Subject: Re: List of names
+NYC or
+inal Ma
+Sent: Thu Feb 14 14:57:31 2008
+Subject: RE: List of names
+From: |
+Sentie Thursdave Februan a
+20981:43 PM
+Subject: List of names
+Here are the names of people I am intending to keep in the indictment:
+>
+P-014600
+
+
+eyewitness info only)
+- initials only, not a listed Jane Doe
+Not all will be in substantive counts, but they will be mentioned in the overt
+acts.
+1661
+P-014601
+
+
+sent
+Subject:
+Thursday. February 14, 2008 3:11 PM
+RE: List of names
+-----Original Message-....-
+From: m
+Sent: Thunsday.
+February 14, 2008 3:10 PM
+Subject: Re: List of names
+P?? NYC or
+Sent: Thu Feb 14 14:57:31 2008
+Subject: RE: List of names
+(USAFLS) <
+Subject: List of names
+Thursday, February 14, 2008 1.43 PM
+Here are the names of people I am intending to keep in the indictment:
+eyewitness info only)
+initials only, not a listed Jane Doe
+1664
+P-014602
+
+
+Not all will be in substantive counts, but they will be mentioned in the overt
+acts.
+1665
+P-014603
+
+
+Subject:
+Thursday, February 14. 2008 2:58 PM
+RE: List of names
+Sent: Thursday, February 14, 2008 1:43 PM
+Subject: List of names
+Here are the names of people I am intending to keep in the indictment:
+eyewitness info only)
+initials only, not a listed Jane Doe
+Not all will be in substantive counts, but they will be mentioned in the overt acts.
+1668
+P-014604
+
+
+Subject:
+- (USAFLS)
+Thursdav, February 14. 2008 2:39 PM
+I know you hate it when I do this, but ...
+I always seem to notice something new when I go through these records. In Janusz's notes, he shows a payment to
+Golden Cab on 6/17/05. Can you call and see if they have any records or any trips to El Brillo Way? Or a Dennis
+working there? And that long string of unknown numbers on
+s cell phone. Could those be a group of lines for
+Yellow Cab?
+Thanks.
+I am almost finished with the changes to the girls we are keeping. I will send that to you and then when I finish the new
+girls, I will send that portion.
+1670
+P-014605
+
+
+-rom
+10:
+Subject
+- (USAFLS)
+Thursday, February 14.200B#K3PM
+List of names
+Here are the names of people I am intending to keep in the indictment:
+eyewitness info only)
+initials only, not a listed Jane Doe
+Not all will be in substantive counts, but they will be mentioned in the overt acts.
+1672
+P-014606
+
+
+Subject:
+- (USAFLS)
+Inursday eruary 482003 1135 PM
+RE: DOBS
+Hi guys - sorry to bother you. On some of the new girls I don't have dobs.
+(the 302 says her dob is
+(and do we have a phone number?)
+Have you guys ever talked to
+Or |
+• Should I include them?
+1674
+P-014607
+
+
+Subject:
+- (USAFLS)
+Thursdav Fabriary 14, 2008 1:21 PM
+RE: Epstein Indictment
+Hi
+How old was
+- I didn't send the indictment yet. I was just asking for input on who to include and who to exclude.
+when she went with
+Sent: Thursday. February 14, 2008 1:00 PM
+Subject: RE: Epstein Indictment
+Hey
+There was no indictment attached to your email. Can you send it again.
+In addition to the two calls from
+we have two telephone calls from
+9:46 am and 2:30 pm.
+Message pads reflect 10 messages from
+taking the messages are
+Michael,
+Lon her cell phone 4/23/04 at 1:35 pm and 5/2/04 at 10:32 am,
+boyfriend) telephone on 03/04/2004 at
+beginning 03/11/2003 ending 03/01/2006. Individuals identified as
+and Alfredo Rodriguez.
+Sent: Thursday, February C. 2008 11:41 AM
+Subject: RE: Epstein Indictment
+FYI - Tell me what you think. Also, can you pull the messages from
+what the dates are and who took the messages? Thanks.
+And am I correct that we have only two phone calls with
+and see if you can tell
+• 4/23/04 and 5/2/04
+Sent: Thursday, February 14, 2008 11:22 AM
+Subject: Epstein Indictment
+1678
+P-014608
+
+
+Hi
+Our server was down for a few hours this morning, so 1 am very behind on my revisions. I wanted
+to talk about which girls we should drop.
+are the girls who have filed lawsuits. I have excluded them.
+With respect to the other girls brought by |
+. here are my thoughts. We can dron
+very easily. Both only gave 1 or 2 massages and did not disclose their ages.
+is a good witness
+because she shows that, if you aren't willing to do more sexual activity, Epstein stops the massage and doesn't
+want to see you anymore. She seems like someone whom we could get in as 404(b) because the probative
+nature outweighs its preiudice.
+I think we should drop |
+because I don't believe she will ever be completely truthful about the amount of
+sexual activity that occurred. (She is the girl that one of the witnesses described as
+")
+That only leaves
+who cried for the entire interview. I think that she may be worth
+keepine. We have such good documentary evidence related to her - message pads, car rental records, 156 calls
+and 2 calls with
+(we have very few phone calls with
+so this is
+What do you think?
+1679
+P-014609
+
+
+From:®
+Subject:
+Thursday Februan 14, 2008 1:00 PM
+| (USAFLS)
+RE: Epstein Indictment
+Hey L
+There was no indictment attached to your email. Can you send it again.
+In addition to the two calls from
+we have two telephone calls from
+9:46 am and 2:30 pm.
+Message pads reflect 10 messages from
+taking the messages are
+Michael,
+on her cell phone 4/23/04 at 1:35 pm and 5/2/04 at 10:32 am,
+boyfriend) telephone on 03/04/2004 at
+beginning 03/11/2003 ending 03/01/2006. Individuals identified as
+and Alfredo Rodriguez.
+(USAFLS) [Ann
+Sent: Thursdav, Februan 12. 2008 11:41 AM
+Subject: RE: Epstein Indictment
+FYI - Tell me what you think. Also, can you pull the messages from
+what the dates are and who took the messages? Thanks.
+And am I correct that we have only two phone calls with
+and see if you can tell
+4/23/04 and 5/2/04
+Sent: Thursday, February 14, 2008 11:22 AM
+Subject: Epstein Indictment
+Hil
+- Our server was down for a few hours this morning, so 1 am very behind on my revisions. I wanted
+to talk about which girls we should drop.
+and
+• are the girls who have filed lawsuits. I have excluded them.
+With respect to the other girls brought by
+here are my thoughts. We can drop
+and
+very easily. Both only gave 1 or 2 massages and did not disclose their ages.
+S. is a good witness
+because she shows that, if you aren't willing to do more sexual activity, Epstein stops the massage and doesn't
+want to see you anymore. She seems like someone whom we could get in as 404(b) because the probative
+nature outweighs its preindice.
+I think we should drop
+because I don't believe she will ever be completely truthful about the amount of
+sexual activity that occurred. (She is the girl that one of the witnesses described as "
+That only leaves
+who cried for the entire interview. I think that she may be worth
+keeping. We have such good documentary evidence related to her - message pads, car rental records, 156 calls
+1686
+P-014610
+
+
+with
+key).
+What do vou think?
+and 2 calls with
+we have very few phone calls with
+so this is
+1687
+P-014611
+
+
+- (USAFLS)
+Subject:
+Thursday. February 14, 2008 12:37 PM
+| (USAFLS)
+RE: Epstein Indictment
+I'm not supposed to be involved in any substantive decisions until I get word from "on high". However, my general
+thoughts are that you are correct.
+reluctant one. Am I correct to assume that
+have to be dealt with and it won't be easy, but | agree that they should be left in. The fact that their
+will
+were
+post-Epstein is good, but his attorneys are going to try to destroy them. Isl
+in as well? I thought that she was
+truthful. What about
+(USAFLS) [mailto
+Sent: Thursday, February I4, 2008 11:22 AM
+To: L
+Subject: Epstein Indictment
+Hi l
+Our server was down for a few hours this morning, so I am very behind on my revisions. I wanted
+to talk about which girls we should drop.
+and
+• are the girls who have filed lawsuits. I have excluded them.
+With respect to the other girls brought by
+here are my thoughts. We can drop
+and
+| is a good witness
+perauss she Shows ha, i you arent asling to doimore seel activity. Epstein stops the massage and doesn't
+want to see you anymore. She seems like someone whom we could get in as 404(b) because the probative
+nature outweighs its prejudice.
+I think we should drop |
+I because I don't believe she will ever be completely truthful about the amount of
+sexual activity that occurred. (She is the girl that one of the witnesses described as "
+That only leaves
+who cried for the entire interview. I think that she may be worth
+Weepine. We have sud cals wiumentary evidence related ave very fespion da arena record, 156 cals
+and 2 calls with
+key).
+What do you think?
+1690
+P-014612
+
+
+Subject:
+• (USAFLS)
+Thursday. February 14, 2008 11:41 AM
+RE: Epstein Indictment
+FYI - Tell me what you think. Also, can you pull the messages from
+dates are and who took the messages? Thanks.
+And am I correct that we have only two phone calls with
+and see if you can tell what the
+4/23/04 and 5/2/04
+Assistant U.S. Allorney
+Sent: Thursday, February 14, 2008 11:22 AM
+Subject: Epstein Indictment
+Hil
+- Our server was down for a few hours this morning, so 1 am very behind on my revisions. I wanted to talk
+about which girls we should drop.
+and
+L. are the girls who have filed lawsuits. I have excluded them.
+With respect to the other girls brought by
+. here are my thought We can drop
+and
+Ivery easily.
+Both only gave 1 or 2 massages and did not disclose their ages.
+is a good witness because she shows that, it
+ou aren't willing to do more sexual activity, Epstein stops the massage and doesn't want to see you anymore. She seem:
+like someone whom we could get in as 404(b) because the probative nature outweighs its prejudice.
+I think we should drop
+• because I don't believe she will ever be completely truthful about the amount of sexual
+activity that occurred. (She is the girl that one of the witnesses described as "
+")
+That only leave
+who cried for the entire interview. I think that she may be worth keeping.
+Ve have such good documentary evidence related to her - message par
+atal records, 156 calls with
+and 2 calls with
+we have very few phone calls witl
+o this is key).
+What do you think?
+1702
+P-014613
+
+
+Subject:
+I(USAFLS)
+Thursdav. February 14, 2008 11:28 AM
+FW: Epstein Indictment
+FYI - Tell me what you think. Also. can you pull the messages from
+dates are and who took the messages? Thanks.
+And am I correct that we have only two phone calls with
+and see if you can tell what the
+4/23/04 and 5/2/04
+Sent: Thursday, February 14, 2008 11:22 AM
+Subject: Epstein Indictment
+Hi
+Our server was down for a few hours this morning, so 1 am very behind on my revisions. I wanted to talk
+about which girls we should drop.
+and
+are the girls who have filed lawsuits. I have excluded them.
+With respect to the other girls brought by
+, here are my thoughts We can drop
+and
+very easily.
+Both only gave 1 or 2 massages and did not disclose their ages.
+is a good witness because she shows that, if
+you aren't willing to do more sexual activity, Epstein stops the massage and doesn't want to see you anymore. She seems
+like someone whom we could get in as 404(b) because the probative nature outweighs its prejudice.
+I think we should drop
+because I don't believe she will ever be completely truthful ahout the amount of sexual
+activity that occurred. (She is the girl that one of the witnesses described as *
+That only leaves
+who cried for the entire interview. I think that she may be worth keeping.
+We have such good documentary evidence related to her - message pads. car rental records, 156 calls with
+and 2 calls with
+we have very few phone calls with
+so this is key).
+What do you think?
+1704
+P-014614
+
+
+Subject:
+Thursdav, February 14, 2008 11:22 AM
+Epstein Indictment
+Hil
+Our server was down for a few hours this morning, so 1 am very behind on my revisions. I wanted to talk
+about which girls we should drop.
+and
+are the girls who have filed lawsuits. I have excluded them.
+With respect to the other girls brought by
+here are my thoughts. We can drop L
+and
+very easily.
+Both only gave 1 or 2 massages and did not disclose their ages.
+s a good witness because she shows that, i!
+ike someonilling de core sexual a 4vity, becain tope the mave nature duesn't want tresee you anymore. She seem:
+I think we should drop
+because I don't believe she will ever be completely truthful about the amount of sexual
+activity that occurred. (She is the girl that one of the witnesses described as "
+That only leaves
+who cried for the entire interview. I think that she may be worth keeping.
+We have such good documentary evidence related to her
+- message pads. car rental records, 156 calls with
+and 2 calls with
+we have very few phone calls with
+so this is key).
+What do you think?
+1706
+P-014615
+
+
+Subject:
+Tuesday, Trebruary 12, 2008 4:33 PM
+Telephone numbers
+Dr. Bard
+Can you e-mail me your summary chart, too? The Excel spreadsheet.
+Thanks.
+1713
+P-014616
+
+
+Subject:
+- (USAFLS)
+Tuesday, February 12, 2008 4:33 PM
+Telephone numbers
+Dr. Bard
+Can you e-mail me your summary chart, too? The Excel spreadsheet.
+Thanks.
+1714
+P-014617
+
+
+Subject:
+tuesday. February 12, 2008 3:19 PM
+Telephone charts and
+phone records
+- I am trying to get this indictment package finalized. Can you e-mail to me the final telephone charts for all of
+the girls and
+records electronically? Maybe we can
+search for phone numbers for some of the new girls, even though we don't have their phone records yet.
+Also, can you check on the lead to New York? Ideally, I would like to turn the package in on Thursday, so I need to know
+if we can include any of those girls.
+When you have a chance, please give me a call. I am in the U.S. Attorney's Office -
+1717
+P-014618
+
+
+Subject:
+Encav Febar 22.20082.08 PM.
+Re: Phone call info
+Ill fax it in 5 min(what fax #?)
+Message
+Sent: Fri Feb 22 14:07:06 2008
+Subject: Phone call info
+(USAFLS) <
+1>
+Hi
+- Can you e-mail or fax me the dates of the calls? I can add them to
+the indictment today. I think
+Tis going to try to finish her review over
+the weekend.
+Thanks.
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax
+1560
+P-014619
+
+
+Subject
+- (USAFLS)
+Friday. February 22, 2008 2:10 PM
+RE: Phone call info
+Thanks
+- -
+-Original Messape-
+Friday February 22
+2008 2:08 PM
+• (USAFLS)
+Subject: Re: Phone call info
+Ill fax it in 5 min(what fax #?)
+Ma
+Sent: Fri Feb 22 14:07:06 2008
+Subject: Phone call info
+(USAFLS) <
+Hi
+Can you e-mail or fax me the dates of the cálls? I can add them to
+the indictment today. I think
+is going to try to finish her review over
+the weekend.
+Thanks.
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax
+1562
+P-014620
+
+
+Subject:
+Erdew Gehrare 2008 2:07 PM
+Phone call info
+Can you e-mail or fax me the dates of the calls? I can add them to the indictment today. I think
+is going to try to finish her review over the weekend.
+Thanks.
+1564
+P-014621
+
+
+Subject:
+Erdav Februan 22 2008 12:07 PM
+Got the FedEx records
+last name is
+and her phone number is
+a cell phone number). They also show another corporate name:
+They show a phone number for Epstein and Eric Gany as
+They have an e-mail address for
+as:
+this may he an office number, not
+and show her phone number as
+The notes show that the
+at
+with company name "NYSG LLC"
+credit card was declined and then they show Bella Tsukeman
+They want us to be more specific about individual shipment records, so we will have to comb through what they
+gave us to identify specific shipments
+I am running to lunch but will be back this afternoon.
+Thanks.
+1567
+P-014622
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/9ea6b207e24fb9d90e0f7b2c29a35355b7645e2c26f013ce5852877b5f3a2d3a.receipt.json b/vision-fixhub/ds9-unparsed-05/9ea6b207e24fb9d90e0f7b2c29a35355b7645e2c26f013ce5852877b5f3a2d3a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3abfb864d25874b5d7c358e6e06a3ecab9d298a9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9ea6b207e24fb9d90e0f7b2c29a35355b7645e2c26f013ce5852877b5f3a2d3a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -2570,
+  "dataset": "marble-joined",
+  "doc_id": "9ea6b207e24fb9d90e0f7b2c29a35355b7645e2c26f013ce5852877b5f3a2d3a",
+  "engine": "marble-apple-vision",
+  "event_count": 40,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "c3f2a97b1a03283c0eaf6821029656482407d4c155a354009c0dd9b94dde0f56",
+  "output_sha256": "6f7a475fd173c69f99465ee94d358e10e75dd45429ca15cb468296fb1d6d52a0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/9ed857ea92ec354aa752e369f5a5babe0aba3e8c63cf23ad14f100c36f19a733.md b/vision-fixhub/ds9-unparsed-05/9ed857ea92ec354aa752e369f5a5babe0aba3e8c63cf23ad14f100c36f19a733.md
new file mode 100644
index 0000000000000000000000000000000000000000..17c7ff2c21c8e25463e34a32ffc656d0b91aa9a2
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9ed857ea92ec354aa752e369f5a5babe0aba3e8c63cf23ad14f100c36f19a733.md
@@ -0,0 +1,1437 @@
+OLY-17
+
+
+TO:
+CUSTODIAN OF RECORDS
+Clerk of Court and Comptroller
+15th Judicial Circuit of Florida
+Palm Beach County Courthouse
+205 North Dixie Highway
+West Palm Beach, FL 33401
+United States District C'ourt
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-17
+SUBPOENA FOR:
+• PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Room 4A
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+DATE AND TIME:
+August 18, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+Tapes or transcripts of any and all proceedings before the Grand Jury on Wednesday, July 19, 2006,
+referring or relating to Jeffrey Epstein and/or
+neluding but not limited to witnes
+estimony, statements made by any member of the State Attorney's Office, and instructions given by an
+member of the State Attorney's Office.
+Please coordinate vour compliance of this subpoena and confirm the date and time of your appearance with
+Special Agent
+Federal Bureau of Investigation, Telephone:
+Plcase see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+STATES DISTRICT
+DATE:
+JAT
+September 6, 2006
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+Cilm Imital Ginin
+*If not applicable, enter "none."
+Name, Address and Phone Number of Assistant U.S. Attorney
+300D0. Austratan zvene, ne 400
+West Palm Beach. FL 33401-6235
+Tel:
+x3047
+Fax
+To be used in lieu of AO110
+FORM ORD-227
+
+
+JAN.86
+ECEIVE
+Y SERVE
+SERVED
+SERVED ON (NAME)
+RETURN OF SERVICE
+DATE 96/06
+PLACE USAO
+DATE9/6/06 PLACENSAO Via fax
+Denise Coffman, Esg.
+SERVED BY L
+TILE AUSA
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service anc
+Statement of Service Fees is true and correct
+Executed on
+9/6/00
+Address of Server
+us Atoney's office
+ADDITIONAL INFORMATION
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+Rule 45(c), Federal Rules of Civil Procedure.
+2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+1825, Rule 17(b) Federal Rules of Criminal Procedure)"
+
+
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+September 6, 2006
+DELIVERY BY FACSIMILE
+Denise Coffman, Esq.
+Counsel to the Clerk of Court and Comptroller
+15th Judicial Circuit of Florida
+West Palm Beach, Florida
+Re: Federal Grand Jury Subpoena
+Dear Ms. Coffman:
+Thank you for your agreement to accept service of the attached subpoena by facsimile. As
+I discussed with Kim Collins, the Clerk of Court is the custodian of the transcripts' of the state grand
+jury proceedings. Ms. Collins asked me to inform you that the transcripts are kept in the Circuit's
+Criminal Department. Florida Statute Sections 905.17(1) and 905.27 discuss the disclosure of state
+grand jury transcripts. Pursuant to those statutes, a transcript can be released upon an order of"a
+court." The statutes do not require that the order be issued by the Palm Beach County Court.
+I have attached two cases regarding the procedures for obtaining state grand jury transcripts
+for use in federal grand jury investigations. The cases that I have enclosed suggest that the
+appropriate way is to issue a federal grand jury subpoena to the party currently in possession of the
+tapes and/or transcripts of the proceedings. The cases that I have enclosed both involve orders issued
+by a federal court that compel the production of the transcripts.
+If the Clerk of Court feels that she cannot comply with the grand jury subpoena absent an
+order from the United States District Court compelling the production, then you must file a motion
+to quash the grand jury subpoena before the United States District Judge who empaneled the federal
+grand jury. Alternatively, if you like, you can state in writing your inability to produce the transcript
+absent a court order, and I can proceed before the United States District Judge by filing a motion to
+'I do not know whether the grand jury proceedings have yet been transcribed. The enclosed
+subpoena calls for the tapes or the transcripts. If you would prefer to produce the tapes to be
+transcribed by one of our grand jury stenographers, that would satisfy the subpoena. If the Clerk of
+Court would prefer to have one of the state court stenographers do the transcription, production of
+the transcripts also would suffice.
+
+
+DENISE COFFMAN, ESQ.
+SEPTEMBER 6, 2006
+PAGE 2
+compel with a proposed order for the United States District Judge to sign. If you prefer to file your
+own motion, I can assist in notifying the Court of the motion, which should be filed ex parte and
+under seal in accordance with Federal Rule of Criminal Procedure 6(e)(5) and (6).
+The subpoena calls for the production of the tape(s) or transcripts by September 15, 2006.
+If you need any additional time, please let me know.
+If you have any questions or concerns, please do not hesitate to call me. Thank you for your
+assistance.
+Sincerely,
+R. Alexander Acosta
+United States Attorney
+By:
+Assistant United States Attorney
+CC:
+Special Agent
+F.B.I.
+
+
+TO: CUSTODIAN OF RECORDS
+Clerk of Court and Comptroller
+15th Judicial Circuit of Florida
+Palm Beach County Courthouse
+205 North Dixie Highway
+West Palm Beach, FL 33401
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-17
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Room 4A
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+DATE AND TIME:
+August 18, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+Tapes or transcripts of any and all proceedings before the Grand Jury on Wednesday, July 19, 2006
+referring or relating to Jeffrey Epstein and/or HIM, including but not limited to witness
+testimony, statements made by any member of the State Attorney's Office, and instructions given by any
+member of the State Attorney's Office.
+Please coordinate your compliance of this subpoena and confirm the date and time of your appearance with
+Special Agent l
+1, Federal Bureau of Investigation, Telephone:
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the United States of America
+| ^½
+A
+STATES DISTRICT
+DATE:
+September 6, 2006
+CAN DISTRICT OFTE
+Name, Address and Phone Number of Assistant U.S. Attorney
+*If not applicable, enter "none."
+300 so. Austamn Avenue, sure 400
+West Palm Beach, FL 33401-6235
+Tel:
+Fax:
+To be used in lieu of AO110
+FORM ORD-227
+
+
+832 F.2d 554, 24 Fed. R. Evid. Serv. 275
+(Cite as: 832 F.2d 554)
+United States Court of Appeals,
+Eleventh Circuit.
+In re GRAND JURY PROCEEDINGS--Subpoena to
+State Attorney's Office.
+Thomas H. Greene, Dawson A. McQuaig, Jake
+Godbold, Don McClure, Intervenors-
+Appellants.
+Nos. 87-3228, 87-3412-87-3414, and 87-3472.
+Oct. 26, 1987.
+Rehearing and Rehearing En Bane Denied Dec. 10,
+1987.
+Persons whose state grand jury testimony had been
+subpoenaed by a federal grand jury appealed from
+order of the United States District Court for the
+Middle District of Florida, Nos. MISC-J-86-183-14,
+MISC-J-86-183- 4, Susan H. Black, J., which
+denied motions to suppress subpoenas.
+The Court
+of Appeals, Tjoflat, Circuit Judge, held that: (1)
+appellants could appeal denial of the motions to the
+extent that they asserted a privilege, but (2) Florida
+statute imposing secrecy on grand jury does not
+create evidentiary privilege.
+Affirmed in part and dismissed in part.
+West Headnotes
+[1] Criminal Law 6- 1023(3)
+110k1023(3)
+Grand jury proceeding is not a "civil action" for
+purposes of statute permitting interlocutory appeals
+in civil actions with respect to controlling questions
+of law. 28 U.S.C.A. § 1292(b).
+[2] Criminal Law 8- 1023(3)
+110k1023(3)
+Persons whose state grand jury testimony had been
+subpoenaed by federal grand jury could appeal the
+denial of their motions to quash the subpoenas to
+the extent that they asserted a privilege as to the
+material, but could not raise issues of procedural
+violations or federal-state comity on appeal.
+[3] Criminal Law ©- 1023(3)
+110k1023(3)
+When party has been subpoenaed to testify or
+produce records for grand jury and third-party
+merely fears that privileged material may be
+disclosed along with other, nonprivileged material,
+Page 1
+the case is not ripe for appellate review until the
+subpoenaed party has actually been asked to reveal
+specific material covered by the assertive privilege.
+[4] Grand Jury @-36.9(2)
+193k36.9(2)
+Federal common-law presumption of grand jury
+secrecy cannot be asserted in the form of a privilege
+by those seeking to prevent disclosure to a federal
+grand jury of their state grand jury testimony.
+Fed.Rulés Cr.Proc.Rule 6(e), 18 U.S.C.A.
+[5] Grand Jury @-41.10
+193k41.10
+[5] Witnesses 8- 184(1)
+410k184(1)
+Florida statute imposing secrecy on grand jury
+proceedings does not create an evidentiary
+privilege.
+West's F.S.A. § 905.27; Fed. Rules
+Evid. Rule 501, 28 U.S.C.A.
+*555 Lamar Winegeart, III, Arnold, Stratford &
+Booth, Jacksonville, Fla., for Greene.
+Elizabeth L. White, Sheppard & White, William
+Sheppard, Jacksonville, Fla., for McQuaig.
+Lacy Mahon, Jr., Jacksonville, Fla., for appellants.
+Robert W. Merkle, Curtis S. Fallgatter, M. Alan
+Ceballos,
+Asst. U.S. Attys., U.S. Attorney's
+Office, Jacksonville, Fla., for appellee.
+Appeals from the United States District Court for
+the Middle District of Florida.
+Before TJOFLAT and KRAVITCH, Circuit
+Judges, and TUTTLE, Senior Circuit Judge.
+TJOFLAT, Circuit Judge:
+Appellants appeal from an order of the district
+court denying their motion to quash a federal grand
+jury subpoena directing a state prosecutor to
+produce transcripts of their testimony before a state
+grand jury. We affirm.
+I.
+In 1985, the State Attorney's Office for the Fourth
+Judicial Circuit of the State of Florida initiated a
+grand jury investigation into allegations of improper
+
+
+(Cite as: 832 F.2d 554, *555)
+influence peddling by certain public officials of the
+City of Jacksonville. Witnesses appearing before
+the state grand jury included the four appellants in
+this case: Jake Godbold, then the mayor of
+Jacksonville, Don McClure, Godbold's chief
+administrative aide, Dawson McQuaig, a former
+general counsel for the city, and Thomas Greene, a
+practicing attorney and an associate of Godbold's.
+Each of these witnesses appeared and testified
+voluntarily.
+No criminal charges resulted from the state grand
+jury investigation. In August 1985, however, the
+state grand jury issued a report that identified
+several instances in *556 which "political favors and
+game-playing for friends" had infected the City's
+process of awarding contracts for professional
+services.
+Godbold, McClure, McQuaig, and
+Greene each waived his right under Fla.Stat. §
+905.28(1) (1985) to suppress the report.
+report, however, did not contain the substance of
+their testimony.
+Meanwhile, federal prosecutors had initiated a
+federal grand jury
+investigation into substantially
+the same matters investigated by the state grand
+jury.
+Godbold, McQuaig, McClure, and Greene
+each indicated
+that he would assert the fifth
+amendment if subpoenaed to testify before the
+federal grand jury.
+Relying on the disclosure
+provisions of Fla.Stat. § 905.27(1)(c) (1985), [FN1]
+the United States in August 1985 petitioned a state
+judge to order the State Attorney to turn over to the
+federal grand jury the appellants' state grand jury
+testimony.
+The United States made no factual
+submission in support of its petition.
+The state
+judge refused to enter the order, characterizing the
+obtain the testimony as a "fishing
+expedition."
+FN1. Under this provision, a court may order
+disclosure of grand jury testimony for the purpose
+of "[f]urthering justice."
+In October 1986, the federal grand jury issued a
+subpoena duces tecum ordering the State Attorney
+to produce appellants' state grand jury testimony.
+The State Attorney moved the federal district court
+to quash the subpoena, arguing that disclosure of
+grand jury transcripts was unlawful under Florida
+law, that the United States had not demonstrated
+sufficient need for the transcripts, and that comity
+required the district court to honor the state court's
+Page 2
+ruling against disclosure. Greene and McQuaig
+then moved the court to permit them to intervene
+pursuant to Fed.R.Civ.P. 24 and to file similar
+motions to quash. In his motion to intervene,
+McQuaig asserted that prior to testifying before the
+state grand jury, he had received assurances from
+the State Attorney that Florida law prohibited any
+disclosure of his grand jury testimony. Greene did
+not allege in his motion that he had received similar
+assurances, but stated that he was entitled to
+intervene because "state grand jury proceedings
+[are] secret and confidential by virtue of the
+provisions of Chapter 905 of the Florida Statutes."
+The district court granted the motions to intervene,
+and subsequently permitted Godbold and McClure
+to intervene as well. [FN2]
+FN2. Godbold and McClure also based their
+motions to intervene on the Florida grand jury
+secrecy requirement.
+The substance of the
+privilege that appellants assert is discussed in Part
+Ill, infra.
+In November 1986, the district court entered an
+order inviting the United States to make an ex parte
+factual submission showing why. it needed the state
+grand jury transcripts. The government declined to
+accept the invitation and made no submission. The
+court then entered an order granting the motions to .
+Applying the balancing test set forth in
+Douglas Oil Co. v. Petrol Stops Northwest, 441
+U.S. 211, 99 S.Ct. 1667, 60 L.Ed.2d 156 (1979),
+the court found that the government had failed to
+establish a sufficient need for the testimony.
+Twenty-eight days after the court granted the
+motions to quash, the United States filed a "Motion
+for Reconsideration of Opinion and Order" along
+with an ex parte affidavit identifying facts
+supporting the grand jury's need for the testimony.
+The district court questioned the procedural
+correctness of the government's motion for
+reconsideration, and stated that under ordinary
+circumstances it would not consider the motion. In
+the court's view, however, denial of the motion
+would not prevent the United States from obtaining
+the testimony: the United States could simply
+reissue the subpoena and defeat any motion to quash
+on the strength of the information contained in the
+ex parte affidavit.
+The court concluded that the
+most efficient solution was to consider the newly
+submitted information in the context of the
+government's motion for reconsideration.
+After
+
+
+(Cite as: 832 F.2d 554, *556)
+considering the new information in camera, the
+district court entered an amended order in which it
+reversed its original order denying the motion to
+quash.
+The district court certified its amended
+order for interlocutory *557 appeal pursuant to 28
+U.S.C. § 1292(b) (1982 & Supp. II 1984), and this
+court granted permission to appeal. The four
+intervenors appealed, although the State Attorney
+did not.
+Appellants make two arguments before this court.
+First, they argue that the government's motion for
+reconsideration was untimely and that the district
+court therefore had no authority to hear it.
+According to appellants, the applicable time limit
+for the motion was the ten-day limit of
+Fed.R.Civ.P. 59(e), not,
+contends, the thirty-day limit of 18 U.S.C. § 3731
+(1982 & Supp. II 1984). Second, appellants argue
+that the district court's amended order was in error
+for the following reasons: (1) the government had
+failed to demonstrate a sufficient need for
+appellants' grand jury testimony, and (2) comity
+required the court to give greater deference to the
+state judge's decision against releasing the .
+Because of the nature of our ruling
+today, we do not reach the merits of these
+We first address the threshold issue whether we
+have jurisdiction to hear this appeal. Although this
+court granted the intervenors permission to appeal
+pursuant to section 1292(b), we must of course
+1979, 95 L. Ed.2d 819 (1987).
+Under section 1292(b), a district court may certify
+for appeal a non-final order entered in a civil action
+if the court is of the opinion that the order "involves
+a controlling question of law as to which there is
+substantial ground for difference of opinion" and
+that resolution of the question "may materially
+advance the ultimate termination of the litigation."
+By its terms, section 1292(b) applies only to orders
+in civil actions, and has no application to appeals in
+criminal cases. See United States v. Doucer, 461
+F.2d 1095 (5th Cir.1972); United States v. Lowe,
+433 F.2d 349 (5th Cir.1970). Therefore, we have
+no jurisdiction to hear this appeal pursuant to
+section 1292(b) unless the district court's order
+Page 3
+denying the motion to quash can be considered an
+order entered in a "civil action."
+[I] We hold that a grand jury proceeding is not a
+"civil action" for purposes of section 1292(b). Just
+in terms of the plain meaning of words, it seems
+self-evident that an order denying a motion to quash
+a subpoena issued by a grand jury investigating
+possible criminal violations is not part of a "civil
+action." We base our conclusion on more than a
+mechanical labeling of the proceedings below,
+however. By expressly limiting section 1292(b)'s
+application to "controlling question[s] of law" in
+"civil" cases, Congress clearly indicated its intent
+not to disturb well-established precedent forbidding
+piecemeal review of grand jury proceedings.
+Cobbledick v. United States, 309 U.S. 323, 60
+S.Ct. 540, 84 L.Ed. 783 (1940), decided eighteen
+years before Congress enacted section 1292(b), the
+Supreme Court held that a district court's denial of
+a motion to quash a grand jury subpoena was not an
+appealable final decision within the meaning of the
+predecessor section of 28 U.S.C. § 1291 (1982).
+Noting that the Constitution itself makes the grand
+jury part of the criminal process, the Court
+concluded that "filt is no less important to safeguard
+against undue interruption the inquiry instituted by a
+grand jury than to protect from delay the progress
+of the trial after an indictment has been found." Id.
+at 327, 60 S.Ct. at 542; see also Di Bella v. United
+States, 369 U.S. 121, 124, 82 S.Ct. 654, 656-57, 7
+L.Ed.2d 614 (1962) ("This insistence on finality and
+prohibition of piecemeal review discourage undue
+litigiousness and leaden-footed administration of
+justice, particularly damaging to the conduct of
+criminal cases.").
+Although Cobbledick was based on the principle of
+finality found in section 1291, that same principle
+finds expression in section 1292(b). We are unable
+conclude that Congress,
+by authorizing
+permissive interlocutory appeals of "controlling
+question[s] of law" in "civil" actions, intended to
+undermine the strong policy against permitting
+appellate interruption of grand jury *558
+proceedings. Accord In re April 1977 Grand Jury
+Subpoenas, 584 F.2d 1366, 1369 (6th Cir.1978)
+("[Section 1292(b) ] limits interim review of 'a
+controlling question of law' to civil cases only and,
+therefore, should not be read to allow interlocutory
+review of grand jury proceedings."), cert. denied,
+440 U.S. 934, 99 S.Ct. 1277, 59 L.Ed.2d 492
+(1979).
+
+
+(Cite as: 832 F.2d 554, *558)
+[2] We next examine whether there is a separate
+basis for appellate jurisdiction in this case.
+As we
+have already indicated, orders denying motions to
+quash grand jury subpoenas are ordinarily not
+appealable final orders under section 1291.
+The
+subpoenaed party can obtain review by refusing to
+comply with the subpoena and then contesting a
+contempt citation, which is immediately appealable.
+See United States v. Ryan, 402 U.S. 530, 532-33,
+91 S.Ct. 1580, 1582, 29 L.Ed.2d 85 (1971). The
+contempt route for obtaining review, however, is
+not open to a third party who claims a privilege of
+nondisclosure with respect to materials in the
+custody of the subpoenaed party.
+In such a case,
+the putative privilege-holder has no power to
+compel the subpoenaed party to incur a contempt
+And the subpoenaed party, unless he has
+either a particularly close relationship to the putative
+privilege-holder
+a personal
+nondisclosure of the material, is unlikely to risk a
+contempt citation simply to vindicate the rights of
+the third party. In this situation, the order denying
+the motion to quash is indeed final with respect to
+the putative privilege-holder, for any prejudice he
+suffers as a result of disclosure will remain forever
+unredressed unless appeal is permitted.
+Accordingly, this circuit follows the so-called
+Perlman exception to the general rule prohibiting
+interlocutory appeal of orders denying motions to
+quash grand jury subpoenas. See In re Grand Jury
+Proceedings (Twist), 689 F.2d 1351 (11th Cir. 1982)
+; In re Grand Jury Proceedings (Fine), 641 F.2d
+199 (5th Cir. Unit A Mar. 1981);
+International Horizons, Inc., 689 F.2d 996 (11th
+•Cir. 1982) (discovery order in bankruptcy
+proceedings).
+This exception,
+Perlman v. United States, 247 U.S. 7, 38 S.Ct.
+417, 62 L.Ed. 950 (1918), and confirmed in United
+States v. Nixon, 418 U.S. 683, 691, 94 S.Ct. 3090,
+3099, 41 L.Ed.2d 1039 (1974), permits an order
+denying a motion to quash to be "considered final as
+to the injured third party who is otherwise
+powerless to prevent the revelation." Fine, 641
+F.2d at 202.
+[3] The circumstances supporting application of the
+Perlman exception are present in this case.
+Relying on the Florida grand jury secrecy
+requirement, appellants in essence assert a privilege
+of nondisclosure.
+The material with respect to
+which they assert the privilege--transcripts of their
+state grand jury testimony-is in the custody of the
+Page 4
+State Attorney. The State Attorney has indicated
+his intention to produce the transcripts. In light of
+these circumstances, the order denying the motion
+to quash is a final order as far as appellants are
+concerned. We therefore have jurisdiction to hear
+their appeal. [PN3]
+FN3. We note that the only material sought from
+the subpoenaed party in this case is material that
+falls squarely within the privilege asserted by the
+third parties. This is not a case, then, where a
+party has been subpoenaed to testify or produce
+records and a third party merely fears that
+privileged material may be disclosed along with
+other, nonprivileged material. In the latter
+situation, the case is not ripe for appellate review
+until the subpoenaed party has actually been asked
+to reveal specific material covered by the asserted
+privilege.
+See In re Grand Jury Proceedings (Doe
+), 831 F.2d 222 (11th Cir.1987).
+III.
+In deciding that the narrow Perlman exception
+applies in
+this case, we have also necessarily
+defined the scope of the matters properly before us
+for review.
+Appellants raise several objections to
+disclosure, including procedural objections
+and
+objections based on comity considerations and the
+need to protect the integrity of the Florida grand
+jury system.
+However, the only matter that the
+Perlman exception gives us jurisdiction to review is
+the appellants' claim of
+privilege to prevent
+disclosure of their state grand jury testimony.
+*559 The rationale of the Periman exception
+extends only to appeals based on privileges personal
+to the third party seeking review: if the subpoenaed
+party has a direct or primary interest in the right or
+privilege in question, the concerns giving rise to the
+Perlman exception simply are not present.
+to the extent that their objections to disclosure are
+based on concerns relating to comity and the
+integrity of the Florida grand jury, appellants
+cannot argue that the subpoenaed party had no
+interest in seeking to vindicate their derivative
+rights. Indeed, the subpoenaed party--the State of
+Florida as represented by the State Attorney-- had
+as its primary interest the protection of its grand
+jury system. Accordingly, the Perlman exception
+does not give us jurisdiction to review
+the
+appellants' arguments concerning comity and the
+need to preserve the integrity of the Florida grand
+jury. [FN4] Nor does it give us jurisdiction to
+review their procedural arguments.
+Thus, we do
+not pass upon the district court's disposition of
+
+
+(Cite as: 832 F.2d 554, *559)
+those matters and we turn to appellants' claims of
+privilege.
+FN4. We should emphasize that this discussion
+relates only to appellants' right to appeal under the
+Periman exception.
+It does not relate to their
+standing to raise these claims before the district
+The appellants' motions to intervene in the district
+court proceedings reveal the nature of the privilege
+they assert. Appellant McQuaig's motion stated
+that "[p]rior to appearing before the [state] Grand
+Jury, Mr. McQuaig was advised by the State
+Attorney that pursuant to Section 905.27, Fla. Stat.
+(1985): a) none of the testimony he provided to the
+Grand Jury was disclosable under the law; and b)
+any disclosure of said testimony was
+a crime."
+Appellant Green's motion stated that "[the] state
+grand jury proceedings were secret and confidential
+by virtue of the provisions of Chapter 905 of the
+Florida Statutes."
+Appellant Godbold's motion
+stated that "testimony was provided with the
+understanding on the part of Jake Godbold that
+pursuant to § 905.27 of the Florida Statutes, his
+testimony would
+not and could not be disclosed
+under the law."
+Finally, appellant McClure's
+motion stated that "[t]he substantial interest of Don
+McClure is equal to or greater than that of the two
+other parties previously allowed to intervene."
+In essence, then, appellants derive the privilege
+they assert from the Florida statutory grand jury
+secrecy requirement.
+The statute imposing that
+requirement provides as follows:
+(1) A grand juror, state attorney, assistant state
+attorney, reporter, stenographer, interpreter, or
+any other person appearing before the grand jury
+shall not disclose the testimony of a witness
+examined before the grand jury or other evidence
+received by it except when required by a court to
+disclose the testimony for the purpose of:
+(a) Ascertaining whether it is consistent with the
+testimony given by the witness before the court;
+(b) Determining whether the witness is guilty of
+perjury; or
+(c) Furthering justice.
+Fla.Stat. § 905.27 (1985). [FNS]
+FN5. The remainder of section 905.27 provides as
+follows:
+(2) It is unlawful for any person knowingly to
+publish, broadcast, disclose, divulge, • or
+communicate to any other person, or knowingly to
+Page 5
+cause or permit to be published, broadcast,
+disclosed, divulged, or communicated to any other
+person, in any manner whatsoever, any testimony
+of a witness examined before the grand jury, or the
+content, gist, or import thereof, except when such
+testimony is or has been disclosed in a court
+proceeding. When a court orders the disclosure of
+such testimony pursuant to subsection (1) for use in
+a criminal case, it may be disclosed to the
+prosecuting attorney of the court in which such
+criminal case is pending, and by him to his
+assistants, legal associates, and employees, and to
+the defendant and his attorney, and by the latter to
+his legal associates and employees. When such
+disclosure is ordered by a court pursuant to
+subsection (I) for use in a civil case, it may be
+disclosed to all parties to the case and to their
+attorneys and by the latter to their legal associates
+testimony afforded such persons by the court can
+only be used in the defense or prosecution of the
+civil or criminal case and for no other purpose
+(3) Nothing in this section shall affect the attorneyclient relationship. A client shall have the right to
+communicate to his attorney any testimony given
+by the client to the grand jury, any matters
+involving the client discussed in the client's
+presence before the grand jury, and any evidence
+involving the client received by or proffered to the
+grand jury in the client's presence.
+(4) Persons convicted of violating this section shall
+be guilty of a misdemeanor of the first degree,
+punishable as provided in s. 775.083, or by fine
+not exceeding $5,000, or both.
+(5) A violation of this section shall constitute
+criminal contempt of court.
+[4] Federal Rule of Evidence 501 provides that
+privileges in federal court proceedings *560 shall
+be governed by the principles of the common law as
+they may be interpreted by the courts of the United
+States in the light of reason and experience." The
+privilege appellants assert, as stated in their motions
+to intervene, is based solely on state law. [FN6]
+We acknowledge that some federal courts have
+recognized state law evidentiary privileges in
+particular cases when to do so would not
+substantially burden federal policies.
+See, e.g.,
+Lora v. Board of Education, 74 F.R.D. 565, 576
+(E.D.N.Y.); J. ACLU v. Finch, 638 F.2d 1336,
+1342-45 (5th Cir. Unit A Mar, 1981).
+FN6. In their briefs, appellants suggest that the
+privilege they assert has an independent basis in the
+federal common law presumption of grand jury
+secrecy. That presumption, which is codified in
+
+
+(Cite as: 832 F.2d 554, *560)
+Fed.R.Crim.P. 6(e), relates to disclosure of federal
+grand jury records. It cannot be asserted in the
+form of a privilege by appellants, who seek to
+prevent disclosure of their state grand jury
+testimony.
+[5] We need not apply any such balancing test
+here, however, because we find that the privilege
+asserted by appellants is without a basis in Florida
+law. We find no evidence that the Florida courts
+derive an evidentiary privilege from Fla.Stat. §
+905.27. Indeed, the Florida Supreme Court has
+noted that
+rule of secrecy concerning matters
+transpiring in the grand jury room is not designed
+for the protection of witnesses before the grand
+jury, but for that of the grand jurors, and in
+furtherance of the public justice.
+A witness
+before the grand jury has no privilege of having
+his testimony there treated as a confidential
+State ex rel. Brown v. Dewell, 167 So. 687, 690
+(Fla. 1936).
+Florida case law directly construing
+section 905.27 fails to provide a contrary
+nterpretation of the relationship between the
+secrecy requirement and the rights of grand jury
+witnesses. [FN7] Accordingly, we conclude that
+Page 6
+appellants have no privilege of nondisclosure under
+state law. A federal court will not selectively reach
+into a state code and fashion evidentiary privileges
+merely to suit the purposes of the parties before it.
+FN7. Some Florida cases refer to the "privilege"
+of a grand jury witness, but only with reference to
+the general principle under Florida law that a
+witness' testimony in a judicial proceeding cannot
+be used as the basis of a defamation action. See,
+State V. Tillett, 111 So.2d 716
+(Fla. Dist.Cr.App. 1959).
+IV.
+In light of our conclusion that appellants have no
+imitations on our appellate jurisdiction discusse
+bove, we dismiss their appeal to the extent that it
+AFFIRMED in part; DISMISSED in part.
+832 F.2d 554, 24 Fed. R. Evid. Serv. 275
+END OF DOCUMENT
+
+
+(Cite as: 824 F.Supp. 330)
+C
+Page 11
+United States District Court,
+W.D. New York.
+In the Matter of Subpoena Duces Tecum Directed to
+the Honorable Kevin M.
+DILLON, District Attorney of Erie County.
+Civ. No. 92-13A.
+Feb. 20, 1992.
+State district attorney moved to quash subpoena
+duces tecum issued by federal grand jury seeking
+production of state grand jury records as part of
+investigation into whether police officers violated
+federal criminal civil rights statute when making
+arrests.
+The District Court, Arcara, J., held that
+federal grand jury was entitled to transcripts and
+tapes of state grand jury testimony of
+uncooperating police officers.
+Motion to quash denied.
+West Headnotes
+[1] Grand Jury @-25
+193k25
+Grand jury is to be afforded wide latitude in
+conducting its investigation.
+[2] Grand Jury @36.4(2)
+193k36.4(2)
+Federal
+grand jury subpoena may not be
+unreasonable or oppressive, it may not violate
+constitutional, common law or statutory privilege.
+Fed. Rules Cr.Proc.Rule 17(c), 18 U.S.C.A.
+[3] Grand Jury C-36.9(2)
+193k36.9(2)
+Federal grand jury subpoenas are presumed to be
+reasonable and party seeking to quash subpoena
+bears burden of showing that compliance would be
+unreasonable or
+oppressive.
+Fed. Rules
+Cr.Proc.Rule 17(c), 18 U.S.C.A.
+14] Grand Jury @36.4(2)
+193k36.4(2)
+Federal grand jury was entitled to subpoena
+transcripts and tapes of state grand jury testimony of
+police officers as part of investigation to determine
+whether officers violated federal criminal civil
+rights laws during or after arrests; disputed
+testimony was relevant and necessary to federal
+grand jury investigation after police officers refused
+to cooperate, subpoena was definite and did not call
+for production of unreasonable amount of
+documents, United States had strong interest in
+insuring just enforcement of its criminal laws, and
+privacy limitations on federal grand jury documents
+limited potential harm from disclosure. Fed. Rules
+Cr.Proc.Rules
+6(e),
+17,
+18 U.S.C.A.;
+N.Y.McKinney's CPL § 190.25, subd. 4.
+[5] Grand Jury @36.3(1)
+193k36.3(1)
+[5] States - 18.63
+360k18.63
+State statutes which preclude disclosure of state
+grand jury records to general public cannot be used
+to prevent federal grand juries from obtaining
+records through subpoena.
+[6] Grand Jury @-36.4(1)
+193k36.4(1)
+Custodian of records, who is proper party for
+service of federal grand jury subpoena, is person or
+entity who is in actual possession of documents at
+time subpoena is issued. N.Y.McKinney's CPL §
+190.25, subd. 4.
+[7] Grand Jury @-41.10
+193k41.10
+Basic purposes of New York grand jury secrecy
+laws are: to prevent accused from escaping before
+being indicted; to prevent tampering with
+witnesses; and to protect accused person who is not
+indicted
+from
+unwarranted
+exposure.
+N.Y.McKinney's CPL § 190.25, subd. 4.
+[8] Witnesses - 184(1)
+410k184(1)
+privileges protect confidential
+communications between persons in special
+relationships from disclosure and are generally
+disfavored in that privileges impede search for
+truth.
+19) Grand Jury @36.3(2)
+193k36.3(2)
+When faced with claim that grand jury should be
+denied evidence because of privilege, reviewing
+court must weigh potential harm from disclosure
+against benefits of disclosure.
+
+
+(Cite as: 824 F.Supp. 330, *331)
+*331 John J. DeFranks, J. Michael Marion, Asst.
+Eric County Dist. Attys. (Kevin Dillon, Erie
+County Dist. Atty., of counsel), Buffalo, NY.
+Russell P. Buscaglia, Asst. U.S. Atty. (Dennis C.
+Vacco, U.S. Atty., W.D.N.Y., of counsel),
+Buffalo, NY.
+DECISION AND ORDER
+ARCARA, District Judge.
+Presently before the Court is a motion to quash a
+subpoena duces lecum, pursuant to Fed.R.Crim.P.
+17, filed by Kevin M. Dillon, District Attorney for
+Erie County, New York. The District Attorney's
+motion seeks an order from this Court quashing a
+federal grand jury subpoena for state grand jury
+records.
+The parties were given an opportunity to
+brief and argue their respective positions.
+After
+reviewing the submissions of the parties and hearing
+argument from counsel, the Court denies the
+District Attorney's motion to quash the subpoena.
+BACKGROUND
+A federal grand jury investigation is currently
+being conducted
+regarding an incident which
+occurred on March 8, 1990 in the Main Place Mall,
+Buffalo, New York, involving the arrest of Mark
+Aiken and Steven Johnson by officers of the Buffalo
+Police Department.
+Specifically, a federal grand
+jury is investigating allegations that certain officers
+of the Buffalo Police Department violated federal
+criminal civil rights laws during and after the arrest
+of Mr. Aiken and Mr. Johnson. [FN1]
+FN1. The background and focus of the federal
+grand jury investigation is set forth in greater detail
+in an in camera submission of facts surrounding
+the federal grand jury investigation submitted by
+the United States.
+The District Attorney's Office prosecuted Mr.
+Aiken and Mr. Johnson on numerous state
+misdemeanor charges arising from this incident.
+During the state trial, only two of the six or more
+officers who were either involved in or witnessed
+the incident in question actually testified.
+Consequently, the state trial shed little light on the
+officers' versions of the allegations that are the
+focus of the federal criminal civil rights
+investigation.
+Page 12
+Following the conclusion of the state trial, the
+District Attorney's Office presented the case to an
+Erie County grand jury that considered whether the
+officers' actions during and after the arrest of Mr.
+Aiken and Mr. Johnson constituted violations of
+The United States, which was then
+conducting *332 its own investigation, delayed
+taking any action in the matter in order to prevent
+interference with the state investigation. The Erie
+County grand jury declined to return criminal
+charges against any of the police officers.
+result, the-state investigation into the police officers'
+conduct concluded in approximately November,
+When the District Attorney's Office concluded its
+investigation, the United States conducted
+independent review of the matter and concluded that
+a federal grand jury investigation was warranted.
+After further investigation, evidence was presented
+to a federal grand jury in October, 1991.
+The United States claims that the federal grand jury
+investigation has reached a logjam because of the
+refusal of the police officers to cooperate with the
+Federal
+Bureau
+of
+Investigation ("FBI").
+Moreover, none of the officers who are most
+seriously implicated in the investigation submitted
+any written reports regarding the alleged incident,
+nor did most of the officers who were present and
+should have witnessed the incident.
+Thus, the
+United States argues that reviewing the transcripts
+and tapes of the state grand jury testimony of the
+police officers is the only way that it will be able to
+learn the officers' versions of what happened.
+The United States initially attempted to obtain the
+state grand jury material through informal means.
+When these efforts failed, a grand jury subpoena
+was issued to the District Attorney's Office on
+October 25, 1991 for the production of the grand
+jury transcripts or tapes of all witnesses who
+testified in this matter before the Erie County grand
+jury. At the request of the District Attorney's
+Office, the return date was delayed until January 8,
+1992, in an effort to facilitate the resolution of this
+matter.
+When further efforts to resolve the matter failed,
+the District Attorney filed the present motion to
+quash, raising four objections to the production of
+the state grand jury material.
+First, the District
+Attorney argues that compliance would be
+
+
+(Cite as: 824 F.Supp. 330, *332)
+unreasonable because it would force him to violate
+state law relating to grand jury secrecy.
+Second,
+he argues that the subpoena was served upon the
+wrong party.
+Third, the District Attorney contends
+that compliance would be unreasonable because it
+would violate policies of comity. Finally, he
+contends that the subpoenaed grand jury records are
+privileged.
+Page 13
+DISCUSSION
+[1][2][3] It is well-established that a federal grand
+jury is to be afforded wide latitude in conducting its
+investigation.
+See United States v. R. Enters.,
+Inc., 498 U.S. 292, 297-98, 111 S.Ct. 722, 726,
+112 L.Ed.2d 795 (1991);
+United States V.
+Calandra, 414 U.S. 338, 94 S.Ct. 613, 38 L.Ed.2d
+561 (1974). "A grand jury investigation 'is not
+fully carried out until every available clue has been
+run down and all witnesses examined in every
+proper way to find if a crime has been committed.'
+Branzburg v. Hayes, 408 U.S. 665, 701, 92
+S.CI. 2646, 2667, 33 L.Ed.2d 626 (1972) (quoting
+United States v. Stone, 429 F.2d 138, 140 (2d
+Cir. 1970)); In re Grand Jury Subpoena for the
+Prod. of Certain New York State Sales Tax Records,
+382 F.Supp. 1205, 1206 (W.D.N.Y.1974) (quoting
+Stone, 429 F.2d at 140).
+In accordance with its
+broad mandate to investigate possible criminal
+activity, a federal grand jury has few limitations
+placed on its subpoena powers.
+R. Enters., 498
+U.S. at 297-98, 111 S.Ct. at 726. "A grand jury
+'may compel the production of evidence or the
+testimony of witnesses as it considers appropriate,
+and its operation generally is unrestrained by the
+technical procedural and evidentiary rules governing
+the conduct of criminal trials.' "
+Id. (quoting
+Calandra, 414 U.S. at 343, 94 S.Ct. at 617). The
+only restrictions that have been placed upon the
+grand jury concern reasonableness and privileges.
+A grand jury subpoena may not be unreasonable or
+oppressive, and it may not violate a constitutional,
+common law or statutory privilege. Branzburg, 408
+U.S. at 688, 92 S.Ct. at 2660; Fed.R.Crim.P.
+17(c).
+Grand jury subpoenas are presumed to be
+reasonable and the party seeking to quash the
+subpoena bears the burden of showing that
+compliance would be unreasonable or oppressive.
+R. Enters., 498 U.S. at 300-02, 111 S.Ct. at 728.
+*333 In this case, the District Attorney contends
+that compliance with the subpoena would be
+unreasonable. In order to meet his heavy burden
+of showing that compliance with the subpoena
+would be unreasonable or oppressive, the District
+Attorney must prove that (1) "there is no reasonable
+possibility that the category of materials the
+Government seeks will produce information relevant
+to the general subject of the grand jury's
+investigation;" or (2) the subpoena is too indefinite;
+or (3) compliance would be overly burdensome. Id.
+After applying these tests to the instant case, the
+Court finds that the District Attorney is unable to
+rebut the presumption that the federal grand jury
+subpoena is reasonable.
+[4] Regarding the relevancy question, the United
+States has set forth in some detail, both in its motion
+papers and in its in camera submission, the reasons
+underlying the need for the state grand jury records.
+The United States has been unable to obtain the
+information contained in the grand jury records
+from other sources because the police officers have
+been unwilling to cooperate with the investigation.
+Accordingly, the Court finds that the statements of
+the police officers and other witnesses who testified
+before the state grand jury are relevant and
+necessary to the federal grand jury investigation.
+It does not appear that the District Attorney
+challenges the subpoena as being too indefinite or
+overly burdensome.
+The Court notes that the
+subpoena is discreet and calls for the production of
+specific material stemming from a particular state
+grand jury investigation.
+Thus, the subpoena is
+sufficiently definite.
+Further, the subpoena does
+not call for the production of an unreasonable
+amount of documents.
+Consequently, producing
+the requested material would require minimal effort
+on the part of the District Attorney's Office and
+therefore would not be overly burdensome.
+The District Attorney argues that compliance with
+the subpoena would be unreasonable because it
+would place him in a position where he would be
+violating state law provisions relating to grand jury
+secrecy. Specifically, the District Attorney argues
+that N.Y.Crim.Proc.Law § 190.25, subd. 4,
+requires that state grand jury materials be kept
+secret and therefore prohibits him from turning over
+the subpoenaed grand jury records to the United
+States. He contends that the only way the United
+States can gain access to these materials is to file a
+motion
+in state
+court pursuant to
+N.Y.Crim.Proc.Law § 190.25, subd. 4. The
+Court finds this argument without merit.
+
+
+(Cite as: 824 F.Supp. 330, *333)
+[5] Federal courts have consistently held that state
+statutes which preclude disclosure of records to the
+general public cannot be used to prevent federal
+grand juries from obtaining the records through a
+subpoena.
+The cases of In re Grand Jury
+Subpoena for New York State Income Tax Records,
+468 F.Supp. 575 (N.D.N.Y.), appeal dismissed,
+607 F.2d 566 (2d Cir.1979), and In re Grand Jury
+Subpoena for the Prod. of Certain New York State
+Records,
+382 F.Supp.
+(W.D.N.Y.1974), are particularly relevant to the
+case at hand. Both cases involved federal grand
+jury subpoenas issued to officials of the New York
+State Department of Taxation for the production of
+certain tax records.
+The petitioners moved to quash
+the subpoenas on the grounds that compliance
+would be in violation of certain secrecy provisions
+of New York State tax laws. These laws are very
+similar to N.Y.Crim.Proc.Law § 190.25, subd. 4,
+which the District Attorney relies on in his motion.
+The courts in these cases explicitly rejected the
+argument that compliance was unreasonable because
+it would force the state officials to violate state law
+secrecy provisions.
+The courts ruled that the
+Supremacy Clause must prevail over the state
+nondisclosure provisions.
+As the court in In re
+Grand Jury Subpoena for New York State Income
+Tax Records stated:
+The Supreme Court has several times indicated
+that, by virtue of the supremacy clause, state
+legislation must yield whenever it comes into
+conflict with an Act of Congress or the superior
+authority of the Constitution.
+Thus, inasmuch as
+the federal *334 grand jury is a product of the
+Fifth Amendment and its powers, as a result of its
+long history and specific Congressional attention,
+conflict between
+confidentiality
+provisions and Congressional or constitutional
+investigatory powers has resulted in enforcement
+of federal grand jury subpoenas despite state
+prohibit
+In re Grand Jury Subpoena for New York State
+Income Tax, 468 F.Supp. at 577 (citations omitted).
+Courts in other Circuits, relying on the Supremacy
+Clause, have similarly rejected claims from state
+officials that compliance with a federal subpoena
+would force them to violate state confidentiality
+See, e.g., In re Special April 1977 Grand
+Jury, 581 F.2d 589, 593 n. 3 (7th Cir.), cert.
+denied, 439 U.S. 1046, 99 S.Ct. 721, 58 L.Ed.2d
+705 (1978); Carr v. Monroe Mfg. Co., 431 F.2d
+384, 388 (5th Cir.1970), cert. denied, 400 U.S.
+Page 14
+1000, 91 S.Ct. 456, 27 L.Ed.2d 451 (1971); In re
+1980 United States Grand Jury Subpoena Duces
+Tecum, 502 F.Supp. 576, 579-80 (E.D.La. 1980);
+United States v. Grand
+Jury Investigation, 417
+F.Supp. 389, 393 (E.D.Pa. 1976).
+Thus, the case
+law clearly establishes that state law provisions
+relating to grand jury secrecy do not preclude a
+federal grand jury from obtaining state grand jury
+records pursuant to a subpoena.
+[6] The District Attorney further argues that the
+grand jury subpoena was not served upon the proper
+party. Specifically, the District Attorney contends
+that pursuant to the state grand jury secrecy law,
+N.Y.Crim.P.Law § 190.25, subd. 4, the state court
+has the ultimate and exclusive control over the
+subpoenaed grand jury material and, therefore, is
+the actual custodian of the grand jury records.
+Thus, the District Attorney argues that the grand
+subpoena should have been served on the
+presiding state court judge rather than the District
+Attorney. The Court disagrees.
+A custodian of records is the person or entity who
+is in actual possession of the documents at the time
+the subpoena is issued. In re Grand Jury Impaneled
+Jan. 21, 1975, 541 F.2d 373, 377 (3d Cir.1976)
+(citations omitted). In order to testify competently
+as a records custodian, a witness must be able to
+verify the authenticity and completeness of the
+requested documents.
+In this case, the District Attorney does not dispute
+the fact that his office possesses the requested grand
+jury material, nor does he deny that the grand jury
+materials were generated as a result of an
+investigation
+Accordingly, the District Attorney's office is the
+sole entity that can competently testify as to the
+authenticity and completeness of the requested
+material. The presiding state court judge does not
+possess the subpoenaed materials nor would he or
+she have any knowledge concerning the authenticity
+or completeness of the grand jury records. Thus,
+the Court finds that the District Attorney's Office is
+the custodian of the state grand jury records and is
+therefore the proper party to be served with the
+subpoena.
+The District Attorney also contends that compliance
+with the federal grand jury subpoena would be
+unreasonable because it would violate policies of
+comity.
+Specifically, the District Attorney
+
+
+(Cite as: 824 F'.Supp. 330, *334)
+contends that, just as the federal government has an
+Page 15
+the District Attorney argues that, in order to show
+proper deference to the State's interest in the
+confidentiality of the grand jury records, the United
+States should be required to move initially for
+disclosure before the presiding state court judge.
+The Court finds that no such requirement exists.
+[7] The Court recognizes that "policies of comity
+and federalism require some deference to the
+objective
+sought to be achieved by state
+confidentiality provisions." In re Grand Jury
+Subpoena for New York State Income Tax Records,
+468 F.Supp. at 577.
+The basic purposes of the
+state grand jury secrecy laws in question are: (1) to
+prevent an accused from escaping before he is
+indicted; (2) to prevent tampering with witnesses;
+and (3) to protect an accused person who is not
+indicted from unwarranted exposure.
+People v.
+McAdoo, 45 Mise.2d 664, 257 N.Y.S.2d 763,
+aff'd, 51 Misc.2d 263, 272 *335 N.Y.S.2d 412,
+cert. denied, 386 U.S. 1031, 87 S.Ct. 1479, 18
+L.Ed.2d 592 (1967).
+In this case, compliance with the federal grand jury
+subpoena will not subvert New York's interest in
+maintaining the secrecy of grand jury proceedings
+because federal grand jury proceedings are also
+conducted secretly.
+The secrecy requirements of
+Fed.R.Crim.P. 6(e), will adequately ensure that
+none of the purposes of the state grand jury secrecy
+laws are undermined by compliance with the federal
+grand jury subpoena.
+See In re New York Grand
+Jury Subpoena for State Income Tax Records, 468
+F.Supp. at 577-78; see also United States v. Field,
+532 F.2d 404, 407-08 (5th Cir.1976), cert. denied,
+429 U.S. 940, 97 S.Ct. 354, 50 L.Ed.2d 309; In re
+Grand Jury Empaneled Jan. 21, 1975, 541 F.2d at
+377-78.
+Moreover, it is important to note that comity is a
+policy which must be balanced against "the
+necessity of thorough grand jury investigations into
+violations of federal law."
+In re Grand Jury
+Subpoena for New York State Income Tax Records,
+Id. 468 F.Supp. at 578.
+Finally, the District Attorney contends that the
+motion to quash should be granted because the
+subpoenaed materials are privileged. Specifically,
+he District Attorney argues that the state grand jur
+secrecy law creates a federal privilege unde
+Federal Rule of Evidence 501. The Court finds
+his argument without merit
+[8] Evidentiary privileges protect confidential
+communications between persons in special
+relationships from disclosure. By their very nature
+they impede the search for the truth and are
+therefore generally distavored. Trammel v. United
+States, 445 U.S. 40, 50, 100 S.Ct. 906, 912, 63
+L.Ed.2d 186 (1980); Herbert v. Lando, 441 U.S.
+153, 99 S.Ct. 1635, 60 L.Ed.2d 115 (1979);
+United States v. Nixon, 418 U.S. 683, 709-10, 94
+S.Ct. 3090, 3108- 09, 41 L.Ed.2d 1039 (1974).
+Accordingly, "the party asserting a privilege bears
+the burden of proving the applicability of the
+privilege," In re Bevill, Bressler & Schulman Asset
+Management Corp.,
+805 F.2d 120, 126 (3d
+Cir. 1986), and privileges,
+"whatever their origins
+... [should] not [be] lightly created or expansively
+construed." Nixon, 418 U.S. at 710, 94 S.Ct. at
+[9] When faced with a claim that a grand jury
+should be denied evidence because of privilege, the
+reviewing court must weigh the potential harm from
+disclosure against the benefits of disclosure.
+American Civil Liberties Union of Miss., Inc. v.
+Finch, 638 F.2d 1336, 1343 (5th Cir. 1981). In this
+case, the federal grand jury is investigating possible
+violations of federal criminal civil rights laws by
+police officers of the Buffalo Police Department.
+As fully explained in the United States' in camera
+statement of facts, the subpoenaed documents are.
+vital to the grand jury investigation and are not
+simply needed to assess credibility of potential
+witnesses.
+In addition, the information sought to
+be obtained from the subpoenaed material is not
+otherwise available since the police officers are
+unwilling to talk to the FBI. Thus, the grand jury
+may not be able to learn the truth of the allegations
+without the subpoenaed material.
+On the other side of the scale, the potential harm
+from disclosure of the state grand jury material is
+yield to the constitutional right and duty of the
+federal grand jury to conduct a broad investigation.
+minimal. Because Fed.R.Crim.P. 6(e) limits
+disclosure of federal grand jury material, the
+
+
+(Cite as: 824 F.Supp. 330, *335)
+secrecy of the subpoenaed documents would be
+closely guarded.
+Thus.
+since the benefits of
+disclosure in this case substantially outweigh the
+potential harm from disclosure, the Court finds that
+the state grand jury records are not privileged as a
+matter of federal common law.
+See Matter of
+Special April 1977 Grand Jury, 581 F.2d at 592-93;
+In re Grand Jury Proceeding, 563 F.2d 577, 582-85
+(3d Cir.1977);
+In re Grand Jury Empaneled
+January 21, 1975, 541 F.2d at 382-83.
+In sum, the United States has a strong interest in
+ensuring the just enforcement of its criminal laws.
+Public policy has long tavored giving the grand jury
+broad powers of investigation.
+Attorney, who has the burden of proving that the
+subpoena should be quashed, has failed to establish
+*336 that the subpoena is unreasonable or that it
+Page 16
+violates any recognized privilege. Furthermore,
+subpoena.
+CONCLUSION
+It is so ordered.
+END OF DOCUMENT
+
+
+U.S. Department Justice
+United States Attorney
+Southern District of Florida
+3UU South Australian Ave, Suite 400
+Tant Dalm D
+die Filmid 23401
+TO: DENISE COFFMAN, ESC.
+FAX NO.
+PHONE NO.
+FACSIMILE COVER SHEET
+DATE:
+September 6, 2006
+# OF PAGES:
+16
+RE:
+GRAND JURY SUBPOENA
+FROM:
+PHONE NO.
+COMMENTS:
+ASSISTANT U.S. ATTORNEY
+
+
+09/06/2006 20:48
+******************
+TX REPORT ***
+******
+USAO WPB FL
+0001
+TRANSMISSION OK
+TX/RX NO
+CONNECTION TEL
+SUBADDRESS
+CONNECTION ID
+ST. TIME
+USAGE T
+PGS. SENT
+RESULT
+2691
+
+09/06 20:41
+06'34
+16
+OK
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 South Australian Ave, Suite 400
+West Palm Beach, Florida 33401
+TO:
+DENISE COFFMAN, ESO.
+FAX NO.
+PHONE NO.
+FACSIMILE COVER SHEET
+DATE:
+# OF PAGES:
+RE:
+September 6, 2006
+16
+GRAND JURY SUBPOENA
+FROM:
+PHONE NO.
+COMMENTS:
+ASSISTANT U.S. ATTORNEY
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/9ed857ea92ec354aa752e369f5a5babe0aba3e8c63cf23ad14f100c36f19a733.receipt.json b/vision-fixhub/ds9-unparsed-05/9ed857ea92ec354aa752e369f5a5babe0aba3e8c63cf23ad14f100c36f19a733.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b57f02ff643644c6f89ceca3bd101f5b1a196622
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9ed857ea92ec354aa752e369f5a5babe0aba3e8c63cf23ad14f100c36f19a733.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1152,
+  "dataset": "marble-joined",
+  "doc_id": "9ed857ea92ec354aa752e369f5a5babe0aba3e8c63cf23ad14f100c36f19a733",
+  "engine": "marble-apple-vision",
+  "event_count": 23,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "30c0b69746fbd4c25bca8091cf09ebafcb30066159ed9067db742be0c50fd040",
+  "output_sha256": "1e5f7c46f8e0bbc288ca9fa4461f44d25d6c5a970b92f84f934e79e55e7ed9d5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/9f0eb34b7878d57a070d539fe70d0dce7643f2e6f19f4eabecf3f96445da1d3c.md b/vision-fixhub/ds9-unparsed-05/9f0eb34b7878d57a070d539fe70d0dce7643f2e6f19f4eabecf3f96445da1d3c.md
new file mode 100644
index 0000000000000000000000000000000000000000..136aa7211a9bad8f0b2a4d8060dc16a68ad9d868
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9f0eb34b7878d57a070d539fe70d0dce7643f2e6f19f4eabecf3f96445da1d3c.md
@@ -0,0 +1,2012 @@
+UNITED STATES OF AMERICA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+/
+PLEA AGREEMENT
+The United States Attorney for the Southern District of Florida ("the United
+States"), and Jeffrey Epstein (hereinafter referred to as the "defendant") enter into the
+following agreement:
+The defendant agrees to plead guilty to the Information which charges the
+defendant with two counts of knowingly and intentionally violating the privacy protection
+accorded to child victims by 18 U.S.C. § 3509; in violation of Title 18, United States
+Code, Section 403.
+The defendant is aware that the sentence will be imposed by the Court after
+considering the Federal Sentencing Guidelines and Policy Statements (hereinafter
+"Sentencing Guidelines"). The defendant acknowledges and understands that the Court
+will compute an
+advisory sentence under the Sentencing Guidelines and that the
+applicable guidelines will be determined by the Court relying in part on the results of a
+Pre-Sentence Investigation by the Court's probation office, which investigation will
+commence after the guilty plea has been entered. The defendant is also aware that, under
+9/13/2007 6:36pm
+1
+
+
+certain circumstances, the Court may depart from the advisory sentencing guideline range
+that it has computed, and may raise or lower that advisory sentence under the Sentencing
+Guidelines. The defendant is further aware and understands that the Court is required to
+consider the advisory guideline range determined under the Sentencing Guidelines, but is
+not bound to impose that sentence; the Court is permitted to tailor the ultimate sentence in
+light of other statutory concerns, and such sentence may be either more severe or less
+severe than the Sentencing Guidelines' advisory sentence. Knowing these facts, the
+defendant understands and acknowledges that the Court has the authority to impose any
+sentence within and up to the statutory maximum authorized by law for the offenses
+identified in paragraph 1 and that the defendant may not withdraw the plea solely as a
+result of the sentence imposed
+3.
+The defendant further understands and acknowledges that, as to cach of
+Counts 1 and 2 of the Information, the Court may impose a statutory maximum term of
+imprisonment of up to one (1) year, to be followed by a term of supervised release of up
+to a maximum of one (1) year. In addition to terms of imprisonment and supervised
+release, the Court may impose a fine of up to $100,000 as to each count.
+4.
+The defendant further understands and acknowledges that, in addition to
+any sentence imposed under paragraph 3 of this Agreement, a special assessment in the
+amount of $50 will be imposed on the defendant, which must be paid at or before the
+time of sentencing.
+The defendant understands that the Court will order that he must pay full
+restitution to all victims of the offense to which he is pleading guilty. The defendant
+understands that the amount of restitution owed to cach victim will be determined at or
+before sentencing.
+The defendant agrees that, if any of the victims identified in the federal
+investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the
+2
+•
+
+
+jurisdiction of the U.S. District Court for the Southern District of Florida over his person and/or
+the subject matter, and the defendant will not contest that the identified victims are persons who,
+while minors, were victims of violations of Title 18, United States Code, Sections(s) 2422 and/or
+2423. The United States agrees to provide the defendant's attorneys with a list of the identified
+victims, which will not exceed forty, after the defendant has signed this agreement and has been
+sentenced. The United States further agrees to make a motion with the United States District
+Court for the Southern District of Florida for the appointment of a guardian ad litem for the
+identified victims and the defendant's counsel may contact the identified victims through that
+guardian.
+The defendant agrees to plead guilty (not nolo contendere) to an Information
+filed by the Palm Beach County State Attorney's Office charging an offense for which the
+defendant must register as a sex offender, that is, solicitation of minors to engage in prostitution,
+in violation of Fl. Stat. 796.03. The defendant and the Palm Beach County State Attorney's
+Office shall make a joint, binding recommendation that the Court impose a sentence of at least
+thirty (30) months, to be divided as follows:
+(a)
+the defendant shall begin by serving at least twenty (20) months in prison,
+without any opportunity for withholding adjudication or sentencing, and
+without probation or community control in lieu of imprisonment; and
+(b)
+following the term of imprisonment, the defendant shall serve ten (10)
+months of community control/home confinement with electronic
+monitoring.
+8.
+The defendant shall waive all challenges to the Information filed by the State
+Attorney's Office and shall waive the right to appeal his conviction and sentence in the state
+court.
+The defendant shall provide to the U.S. Attorney's Office copies of all proposed
+3
+
+
+agreements with the Palm Beach County State Attorney's Office prior to entering into those
+agreements.
+The United States reserves the right to inform the Court and the probation
+office of all facts pertinent to the sentencing process, including all relevant information
+concerning the offenses committed, whether charged or not, as well as concerning the
+defendant and the defendant's background, and to respond to any questions from the
+Court and the Probation Office and to any misstatements of fact or law. Subject only to
+the express terms of any agreed-upon sentencing recommendations contained in this
+Agreement, this Office further reserves the right to make any recommendation as to the
+quality and quantity of punishment.
+11. The defendant is aware that the sentence has not yet been determined by the
+Court. The defendant also is aware that any estimate of the probable sentencing range or
+sentence that the defendant may receive, whether that estimate comes from the
+defendant's attorney, the government, or the probation office, is a prediction, not a
+promise, and is not binding on the government, the probation office or the Court. The
+defendant understands further that any recommendation that the government makes to the
+Court as to sentencing, whether pursuant to this agreement or otherwise, is not binding on
+the Court and the Court may disregard the recommendation in its entirety. The defendant
+understands and acknowledges, as previously acknowledged in paragraph 2 above, that
+the defendant may not withdraw his plea based upon the Court's decision not to accept a
+sentencing
+recommendation made by the defendant, the government, or a
+recommendation made jointly by both the defendant and the government.
+12.
+WAIVER OF RIGHT TO APPEAL AND COLLATERALLY
+ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code,
+Section 3742 affords the defendant the right to appeal the sentence imposed in this case.
+Acknowledging this, in exchange for the undertakings made by the United States in this
+4
+
+
+plea agreement,
+the defendant hereby waives all rights conferred by Section 3742 to
+appeal any sentence imposed, including any restitution order, or to appeal the manner in
+which the sentence was imposed, unless the sentence exceeds the maximum permitted by
+statute or is the result of an upward departure or upward variance from the guideline
+range that the Court establishes at sentencing. The defendant further voluntarily and
+expressly waives, to the maximum extent permitted by federal law, the right to
+collaterally attack his sentence in any postconviction proceeding, including a motion on any ground brought under 28 U.S.C. §
+2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further
+understands that nothing in this agreement shall affect the government's right and/or duty
+to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the
+United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant
+shall be released from the above waiver of appellate rights. By signing this agreement,
+the defendant acknowledges that he has discussed the appeal waiver set forth in this
+13.
+If the defendant fails in any way to fulfill each one of his obligations under
+this Plea Agreement,
+, the United States, and only the United States, may elect to be
+released from its commitments under this Plea Agreement. If the United States elects to
+void the Plea Agreement because of a breach by the defendant, then the United States
+agrees not to use the defendant's guilty plea against him. However, the United States
+may prosecute the defendant for any and all Federal crimes that he has committed related
+to this case and may seek any sentence for such crimes up to and including the statutory
+maximums.
+The defendant expressly waives any statute of limitations defense and any
+constitutional or statutory speedy trial defense to such a prosecution, except to the extent
+that such a defense exists as of the date he signs this Plea Agreement. Finally, the
+defendant understands that his violation of the terms of this Plea Agreement would not
+5
+
+
+
+
+14. This is the entire agreement and understanding between the United States
+and the defendant. There are no other agreements, promises, representations, or
+BY: R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+7
+
+
+UNITED STATES OF AMERICA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLEA AGREEMENT
+The United States Attorney for the Southern District of Florida ("the United
+States"), and Jeffrey Epstein (hereinafter referred to as the "defendant") enter into the
+following agreement:
+The defendant agrees to plead guilty to a two-count Information which
+charges that the defendant intentionally harassed two other persons, that is, S.K. and
+N.M., in an attempt to delay, prevent, and dissuade those persons from reporting to a law
+enforcement officer of the United States the commission of a federal offense; in violation
+of Title 18, United States Code, Sections 1512(d)(2) and 2.
+2.
+The defendant agrees and understands that the above charges involve his
+conduct, and the criminal conduct of others, between in and around early 2001 through in
+and around September 2007. This agreement resolves the federal criminal liability of the
+defendant and any co-conspirators in the Southern District of Florida growing out of any
+criminal conduct by those persons known to the United States Attorney's Office for the
+Southern District of Florida as of the date of this plea agreement.
+9/20/2007 3:52pm
+1
+ETA00194612
+
+The United States agrees that, upon entry of the defendant's guilty plea, its
+Grand Jury investigation will be suspended, and all pending litigation between the parties
+will be held in abeyance unless and until the defendant violates any term of this
+agreement, as explained in paragraph 18, infra. Both parties agree to maintain their
+evidence inviolate until all of the terms of this agreement have been satisfied.
+4.
+The defendant is aware that the sentence will be imposed by the Court after
+considering the Federal Sentencing Guidelines and Policy Statements (hereinafter
+"Sentencing Guidelines"). The defendant acknowledges and understands that the Court
+will compute an advisory sentence under the Sentencing Guidelines and that the
+applicable guidelines will be determined by the Court relying in part on the results of a
+Pre-Sentence Investigation by the Court's probation office, which investigation will
+commence after the guilty plea has been entered. The defendant is also aware that, under
+certain circumstances, the Court may depart from the advisory sentencing guideline range
+that it has computed, and may raise or lower that advisory sentence under the Sentencing
+Guidelines. The defendant is further aware and understands that the Court is required to
+consider the advisory guideline range determined under the Sentencing Guidelines, but is
+not bound to impose that sentence; the Court is permitted to tailor the ultimate sentence in
+light of other statutory concerns, and such sentence may be either more severe or less
+severe than the Sentencing Guidelines' advisory sentence. Knowing these facts, the
+defendant understands and acknowledges that the Court has the authority to impose any
+sentence within and up to the statutory maximum authorized by law for the offenses
+identified in paragraph 1 and that the defendant may not withdraw the plea solely as a
+result of the sentence imposed.
+The defendant further understands and acknowledges that, as to cach of
+Counts 1 and 2 of the Information, the Court may impose a statutory maximum term of
+imprisonment of up to one (1) year, to be followed by a term of supervised release of up
+2
+
+
+to a maximum of one (1) year. In addition to terms of imprisonment and supervised
+release, the Court may impose a fine of up to $100,000 as to each count.
+The defendant further understands and acknowledges that, in addition to
+any sentence imposed under paragraph 4 of this Agreement, a special assessment in the
+amount of $50 will be imposed on the defendant, which must be paid at or before the
+time of sentencing.
+The defendant understands that the Court will order that he must pay full
+restitution to all victims of the offenses to which he is pleading guilty. The defendant
+understands that the amount of restitution owed to each victim will be determined at or
+before sentencing.
+8.
+The parties agree to jointly recommend that the defendant receive a
+sentence of eighteen (18) months' imprisonment, to be followed by one (1) year of
+supervised release, and a fine of $200,000. The parties' further agree to jointly
+recommend that the Court impose one year of home confinement as a special condition of'
+supervised release.
+The defendant agrees that, if any of the victims identified in the federal
+investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the
+jurisdiction of the U.S. District Court for the Southern District of Florida over his person
+and/or the subject matter, and the defendant will not contest that the identified victims are
+persons who, while minors, were victims of violations of Title 18, United States Code,
+Sections(s) 2422 and/or 2423. The United States agrees to provide the defendant's
+attorneys with a list of the identified victims, which will not exceed forty, after the
+defendant has signed this agreement and has been sentenced. The United States further
+agrees to make a motion with the United States District Court for the Southern District of
+Florida for the appointment of a guardian ad litem for the identified victims and the
+defendant's counsel may contact the identified victims through that guardian.
+3
+
+
+10. The United States has reached this agreement with the defendant in
+response to the defendant's request to globally resolve his state and federal criminal
+liability. To do so, the defendant further understands and acknowledges that he must
+undertake certain actions with the State Attorney's Office for the 15th Judicial Circuit in
+and for Palm Beach County (hereinafter, "State Attorney's Office").
+In addition to entering a guilty plea in the instant case, the defendant agrees
+that, prior to his sentencing on the federal charges, he will plead guilty to an Information
+filed by the State Attorney's Office charging an offense for which the defendant must
+register as a sex offender, that is, solicitation of minors to engage in prostitution, in
+violation of FI. Stat. 796.03. The defendant agrees that he will waive all challenges to the
+Information filed by the State Attorney's Office and waive the right to appeal his
+conviction and sentence in the state court.
+12. The defendant agrees that he will make a binding recommendation that the
+15th Judicial Circuit Court impose a sentence of at least eighteen (18) months'
+imprisonment to be followed by at least twelve (12) months of community control/home
+confinement to be served upon the defendant's release from federal prison. The
+defendant further represents that he has had discussions with the State Attorney's Office,
+which has agreed to likewise make this recommendation. The sentences imposed by the
+15th Judicial Circuit Court may run concurrently with the federal sentence imposed
+pursuant to this agreement.
+13.
+The defendant agrees to provide to the U.S. Attorney's Office copies of all
+proposed agreements with the State Attorney's Office prior to entering into those
+agreements.
+The defendant agrees that the timely completion of these actions is material
+to this agreement and is supported by independent consideration and that a breach of any
+one of these conditions allows the United States to elect to terminate the agreement and to
+4
+
+
+investigate and prosecute the defendant for any and all federal offenses.
+15.
+The United States reserves the right to inform the Court and the probation
+office of all facts pertinent to the sentencing process, including all relevant information
+concerning the offenses committed, whether charged or not, as well as concerning the
+defendant and the defendant's background, and to respond to any questions from the
+Court and the Probation Office and to any misstatements of fact or law. Subject only to
+the express terms of any agreed-upon sentencing recommendations contained in this
+Agreement, this Office further reserves the right to make any recommendation as to the
+quality and quantity of punishment.
+16. The defendant is aware that the sentence has not yet been determined by the
+Court. The defendant also is aware that any estimate of the probable sentencing range or
+sentence that the defendant may receive, whether that estimate comes from the
+defendant's attorney, the government, or the probation office, is a prediction, not a
+promise, and is not binding on the government, the probation office or the Court. The
+defendant understands further that any recommendation that the government makes to the
+Court as to sentencing, whether pursuant to this agreement or otherwise, is not binding on
+the Court and the Court may disregard the recommendation in its entirety. The defendant
+understands and acknowledges, as previously acknowledged in paragraph 4 above, that
+the defendant may not withdraw his plea based upon the Court's decision not to accept a
+sentencing
+recommendation
+made by the defendant, the government, or a
+recommendation made jointly by both the defendant and the government.
+17.
+WAIVER OF RIGHT TO APPEAL AND COLLATERALLY
+ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code,
+Section 3742 affords the defendant the right to appeal the sentence imposed in this case.
+Acknowledging this, in exchange for the undertakings made by the United States in this
+plea agreement, the defendant hereby waives all rights conferred by Section 3742 to
+5
+
+
+appeal any sentence imposed, including any restitution order, or to appeal the manner in
+which the sentence was imposed, unless the sentence exceeds the maximum permitted by
+statute. The defendant further voluntarily and expressly waives, to the maximum extent
+permitted by federal law, the right to collaterally attack his sentence in any
+post-conviction proceeding, including a motion on any ground brought under 28 U.S.C. §
+2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further
+understands that nothing in this agreement shall affect the government's right and/or duty
+to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the
+United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant
+shall be released from the above waiver of appellate rights. By signing this agreement,
+the defendant acknowledges that he has discussed the appeal waiver set forth in this
+18.
+If the defendant fails in any way to fulfill each one of his obligations under
+this Plea Agreement,
+, the United States, and only the United States, may elect to be
+released from its commitments under this Plea Agreement. If the United States elects to
+void the Plea Agreement because of a breach by the defendant, then the United States
+agrees not to use the defendant's guilty plea against him. However, the United States
+may prosecute the defendant for any and all Federal crimes that he has committed related
+to this case and may seek any sentence for such crimes up to and including the statutory
+maximums.
+The defendant expressly waives any statute of limitations defense and any
+constitutional or statutory speedy trial defense to such a prosecution, except to the extent
+that such a defense exists as of the date he signs this Plea Agreement. Finally, the
+defendant understands that his violation of the terms of this Plea Agreement would not
+19.
+This is the entire agreement and understanding between the United States
+There are no other agreements, promises, representations, or
+
+
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+A. MARIE VILLAFAÑA
+ASSISTANT UNITED STATES ATTORNEY
+By: -
+COUNSEL TO DEFENDANT
+7
+
+
+UNITED STATES OF AMERICA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLEA AGREEMENT
+The United States Attorney for the Southern District of Florida ("the United
+States"), and Jeffrey Epstein (hereinafter referred to as the "defendant") enter into the
+following agreement:
+The defendant agrees to plead guilty to a two-count Information which
+charges that the defendant intentionally harassed two other persons, that is, S.K. and
+N.M., in an attempt to delay, prevent, and dissuade those persons from reporting to a law
+enforcement officer of the United States the commission of a federal offense; in violation
+of Title 18, United States Code, Sections 1512(d)(2) and 2.
+2.
+The defendant agrees and understands that the above charges involve his
+conduct, and the criminal conduct of others, between in and around carly 2001 through in
+and around September 2007. This agreement resolves the federal criminal liability of the
+defendant and any co-conspirators in the Southern District of Florida growing out of any
+criminal conduct by those persons known to the United States Attorney's Office for the
+Southern District of Florida as of the date of this plea agreement.
+9/20/2007 1:17pm
+
+
+The United States agrees that, upon entry of the defendant's guilty plea, its
+Grand Jury investigation will be suspended, and all pending litigation between the parties
+will be held in abeyance unless and until the defendant violates any term of this
+agreement, as explained in paragraph 18, infra. Both parties agree to maintain their
+evidence inviolate until all of the terms of this agreement have been satisfied.
+4.
+The defendant is aware that the sentence will be imposed by the Court after
+considering the
+Federal Sentencing Guidelines and Policy Statements (hereinafter
+"Sentencing Guidelines"). The defendant acknowledges and understands that the Court
+will compute an advisory sentence under the Sentencing Guidelines and that the
+applicable guidelines will be determined by the Court relying in part on the results of a
+Pre-Sentence Investigation by the Court's probation office, which investigation will
+commence after the guilty plea has been entered. The defendant is also aware that, under
+certain circumstances, the Court may depart from the advisory sentencing guideline range
+that it has computed, and may raise or lower that advisory sentence under the Sentencing
+Guidelines. The defendant is further aware and understands that the Court is required to
+consider the advisory guideline range determined under the Sentencing Guidelines, but is
+not bound to impose that sentence; the Court is permitted to tailor the ultimate sentence in
+light of other statutory concerns, and such sentence may be either more severe or less
+severe than the Sentencing Guidelines' advisory sentence. Knowing these facts, the
+defendant understands and acknowledges that the Court has the authority to impose any
+sentence within and up to the statutory maximum authorized by law for the offenses
+identified in paragraph 1 and that the defendant may not withdraw the plea solely as a
+result of the sentence imposed.
+The defendant further understands and acknowledges that, as to each of
+Counts 1 and 2 of the Information, the Court may impose a statutory maximum term of
+imprisonment of up to one (1) year, to be followed by a term of supervised release of up
+2
+
+
+to a maximum of one (1) year, In addition to terms of imprisonment and supervised
+release, the Court may impose a fine of up to $100,000 as to each count.
+The defendant further understands and acknowledges that, in addition to
+any sentence imposed under paragraph 4 of this Agreement, a special assessment in the
+amount of $50 will be imposed on the defendant, which must be paid at or before the
+time of sentencing.
+The defendant understands that the Court will order that he must pay full
+restitution to all victims of the offenses to which he is pleading guilty. The defendant
+understands that the amount of restitution owed to each victim will be determined at or
+before sentencing.
+8.
+The parties agree to jointly recommend that the defendant receive a
+sentence of eighteen (18) months' imprisonment, to be followed by one (1) year of
+supervised release, and a fine of $200,000. The parties' further agree to jointly
+recommend that the Court impose one year of home confinement as a special condition of
+supervised release.
+The defendant agrees that, if any of the victims identified in the federal
+investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the
+jurisdiction of the U.S. District Court for the Southern District of Florida over his person
+and/or the subject matter, and the defendant will not contest that the identified victims are
+persons who, while minors, were victims of violations of Title 18, United States Code,
+Sections(s) 2422 and/or 2423. The United States agrees to provide the defendant's
+attorneys with a list of the identified victims, which will not exceed forty, after the
+defendant has signed this agreement and has been sentenced. The United States further
+agrees to make a motion with the United States District Court for the Southern District of
+Florida for the appointment of a guardian ad litem for the identified victims and the
+defendant's counsel may contact the identified victims through that guardian.
+3
+
+
+10. The United States has reached this agreement with the defendant in
+response to the defendant's request to globally resolve his state and federal criminal
+liability. To do so, the defendant further understands and acknowledges that he must
+undertake certain actions with the State Attorney's Office for the 15th Judicial Circuit in
+and for Palm Beach County (hereinafter, "State Attorney's Office") in order to satisfy the
+United States' federal interest in the investigation and prosecution of his offenses, in
+accordance with the Justice Department's Petite policy.
+11.
+In addition to entering a guilty plea in the instant case, the defendant agrees
+that, prior to his sentencing on the federal charges, he will plead guilty to an Information
+filed by the State Attorney's Office charging an offense for which the defendant must
+register as a sex offender, that is, solicitation of minors to engage in prostitution, in
+violation of Fl. Stat. 796.03. The defendant agrees that he will waive all challenges to the
+Information filed by the State Attorney's Office and waive the right to appeal his
+conviction and sentence in the state court.
+12. The defendant agrees that he will make a binding recommendation that the
+15th Judicial Circuit Court impose a sentence of at least eighteen (18) months'
+imprisonment to be followed by at least twelve (12) months of community control/home
+confinement to be served upon the defendant's release from federal prison. The
+defendant further represents that he has had discussions with the State Attorney's Office,
+which has agreed to likewise make this recommendation. The sentences imposed by the
+15th Judicial Circuit Court may run concurrently with the federal sentence imposed
+pursuant to this agreement.
+13. The defendant agrees to provide to the U.S. Attorney's Office copies of all
+proposed agreements with the State Attorney's Office prior to entering into those
+agreements.
+The defendant agrees that the timely completion of these actions is material
+4
+
+
+to this agreement and is supported by independent consideration and that a breach of any
+one of these conditions allows the United States to elect to terminate the agreement and to
+investigate and prosecute the defendant for any and all federal offenses.
+15.
+The United States reserves the right to inform the Court and the probation
+office of all facts pertinent to the sentencing process, including all relevant information
+concerning the offenses committed, whether charged or not, as well as concerning the
+defendant and the defendant's background, and to respond to any questions from the
+Court and the Probation Office and to any misstatements of fact or law. Subject only to
+the express terms of any agreed-upon sentencing recommendations contained in this
+Agreement, this Office further reserves the right to make any recommendation as to the
+quality and quantity of punishment.
+16.
+The defendant is aware that the sentence has not yet been determined by the
+Court. The defendant also is aware that any estimate of the probable sentencing range or
+sentence that the defendant may receive, whether that estimate comes from the
+defendant's attorney, the government, or the probation office, is a prediction, not a
+promise, and is not binding on the government, the probation office or the Court. The
+defendant understands further that any recommendation that the government makes to the
+Court as to sentencing, whether pursuant to this agreement or otherwise, is not binding on
+the Court and the Court may disregard the recommendation in its entirety. The defendant
+understands and acknowledges, as previously acknowledged in paragraph 4 above, that
+the defendant may not withdraw his plea based upon the Court's decision not to accept a
+sentencing
+recommendation made by the defendant, the government, or a
+recommendation made jointly by both the defendant and the government.
+17.
+WAIVER OF RIGHT TO APPEAL AND COLLATERALLY
+ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code,
+5
+
+
+Section 3742 affords the defendant the right to appeal the sentence imposed in this case.
+Acknowledging this, in exchange for the undertakings made by the United States in this
+plea agreement, the defendant hereby waives all rights conferred by Section 3742 to
+appeal any sentence imposed, including any restitution order, or to appeal the manner in
+which the sentence was imposed, unless the sentence exceeds the maximum permitted by
+statute. The defendant further voluntarily and expressly waives, to the maximum extent
+permitted by federal law, the right to collaterally attack his sentence in any
+post-conviction proceeding, including a motion on any ground brought under 28 U.S.C. §
+2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further
+understands that nothing in this agreement shall affect the government's right and/or duty
+to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the
+United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant
+shall be released from the above waiver of appellate rights. By signing this agreement,
+the defendant acknowledges that he has discussed the appeal waiver set forth in this
+18.
+If the defendant fails in any way to fulfill each one of his obligations under
+this Plea Agreement, the United States, and only the United States, may elect to be
+released from its commitments under this Plea Agreement. If the United States elects to
+void the Plea Agreement because of a breach by the defendant, then the United States
+agrees not to use the defendant's guilty plea against him. However, the United States
+may prosecute the defendant for any and all Federal crimes that he has committed related
+to this case and may seek any sentence for such crimes up to and including the statutory
+maximums.
+The defendant expressly waives any statute of limitations defense and any
+constitutional or statutory speedy trial defense to such a prosecution, except to the extent
+that such a defense exists as of the date he signs this Plea Agreement. Finally, the
+defendant understands that his violation of the terms of this Plea Agreement would not
+
+
+19. This is the entire agreement and understanding between the United States
+There are no other agreements, promises, representations, or
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+A. MARIE VILLAFAÑA
+ASSISTANT UNITED STATES ATTORNEY
+BY JEFFREY EPSTEIN, DEFENDANT
+. By:
+COUNSEL TO DEFENDANT
+7
+
+
+Case No. _
+UNITED STATES OF AMERICA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLEA AGREEMENT
+The United States Attorney for the Southern District of Florida ("the United
+States"), and Jeffrey Epstein (hereinafter referred to as the "defendant") enter into the
+following agreement:
+The defendant agrees to plead guilty to a two-count Information which
+charges the defendant as follows. Count 1 charges that the defendant intentionally
+harassed another person, that is, L.G., in an attempt to delay, prevent, and dissuade L.G.
+from attending or testifying in an official proceeding, that is a Federal Grand Jury
+appearance in the Southern District of Florida, in violation of Title 18, United States
+Code, Sections 1512(d)(2) and 2; and Count 2 charges that the defendant intentionally
+harassed another person, that is, N.M., in an attempt to delay, prevent, and dissuade N.M.
+from reporting to a law enforcement officer of the United States the commission of a
+federal offense; in violation of Title 18, United States Code, Sections 1512(d)(2) and 2.
+The defendant agrees and understands that the above charges involve his
+conduct, and the conduct of others, between in and around early 2001 through in and
+9/18/07 12:22pm
+1
+
+
+around September 2007 involving a conspiracy to solicit minors to engage in prostitution
+and to travel in interstate commerce to engage in illicit sexual conduct. _This agreement
+resolves the federal criminal liability of the defendant and any co-conspirators in the
+Southern District of Florida growing out of any criminal conduct by those persons known
+to the United States Attorney's Office for the Southern District of Florida as of the date of
+this plea agreement, including but not limited to the above-described scheme.
+The United States agrees that, upon entry of the defendant's guilty plea, its
+Grand Jury investigation will be suspended, and all pending Grand Jury subpoenas will
+be held in abeyance unless and until the defendant violates any term of this agreement, as
+explained in paragraph 19, infra. The defendant likewise agrees to withdraw his pending
+motion to intervene and to quash certain grand jury subpoenas. The defendant further
+agrees that the current custodian of certain computer equipment shall maintain that
+evidence inviolate until all of the terms of this agreement have been satisfied.
+4. The defendant is aware that the sentence will be imposed by the Court after
+considering the Federal Sentencing Guidelines and Policy Statements (hereinafter
+"Sentencing Guidelines"). The defendant acknowledges and understands that the Court
+will compute an advisory sentence under the Sentencing Guidelines and that the
+applicable guidelines will be determined by the Court relying in part on the results of a
+Pre-Sentence Investigation by the Court's probation office, which investigation will
+commence after the guilty plea has been entered. The defendant is also aware that, under
+certain circumstances, the Court may depart from the advisory sentencing guideline range
+that it has computed, and may raise or lower that advisory sentence under the Sentencing
+Guidelines. The defendant is further aware and understands that the Court is required to
+consider the advisory guideline range determined under the Sentencing Guidelines, but is
+not bound to impose that sentence; the Court is permitted to tailor the ultimate sentence in
+light of other statutory concerns, and such sentence may be either more severe or less
+2
+
+
+severe than the Sentencing Guidelines' advisory sentence. Knowing these facts, the
+defendant understands and acknowledges that the Court has the authority to impose any
+sentence within and up to the statutory maximum authorized by law for the offenses
+identified in paragraph 1 and that the defendant may not withdraw the plea solely as a
+result of the sentence imposed.
+The defendant further understands and acknowledges that, as to each of
+Counts 1 and 2 of the Information, the Court may impose a statutory maximum term of
+imprisonment of up to one (1) year, to be followed by a term of supervised release of up
+to a maximum of one (1) year. In addition to terms of imprisonment and supervised
+release, the Court may impose a fine of up to $100,000 as to each count.
+The defendant further understands and acknowledges that, in addition to
+any sentence imposed under paragraph 3 of this Agreement, a special assessment in the
+amount of $50 will be imposed on the defendant, which must be paid at or before the
+time of sentencing.
+7.
+The defendant understands that the Court will order that he must pay full
+restitution to all victims of the offense to which he is pleading guilty. The defendant
+understands that the amount of restitution owed to each victim will be determined at or
+before sentencing.
+8.
+The parties agree to jointly recommend that the defendant receive a
+sentence of eighteen (18) months' imprisonment, to be followed by two (2) years of
+supervised release; and
+a fine of $200,000. The parties' further agree to jointly
+recommend that the Court impose one year of home confinement as a special condition of
+supervised release.
+9.
+The defendant agrees that, if any of the victims identified in the federal
+investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the
+jurisdiction of the U.S. District Court for the Southern District of Florida over his person
+3
+
+
+and/or the subject matter, and the defendant will not contest that the identified victims are
+persons who, while minors, were victims of violations of Title 18, United States Code,
+Sections(s) 2422 and/or 2423. The United States agrees to provide the defendant's
+attorneys with a list of the identified victims, which will not exceed forty, after the
+defendant has signed this agreement and has been sentenced. The United States further
+agrees to make a motion with the United States District Court for the Southern District of
+Florida for the appointment of a guardian ad litem for the identified victims and the
+defendant's counsel may contact the identified victims through that guardian.
+10. The defendant further understands and acknowledges that he must
+undertake certain actions with the State Attorney's Office for the 15th Judicial Circuit in
+and for Palm Beach County (hereinafter, "State Attorney's Office") in order to satisfy the
+United States' federal interest in the investigation and prosecution of his offenses, in
+accordance with the Justice Department's Petite policy. Epstein understands and
+acknowledges that the United States Attorney has no authority to require the State
+Attorney's Office to abide by any terms of this Agreement. Epstein understands that it is
+his obligation to undertake discussion with the State Attorney's Office to ensure
+compliance with these procedures.
+11.
+In addition to entering a guilty plea in the instant case, the defendant agrees
+to plead guilty to an Information filed by the Palm Beach County State Attorney's Office
+charging an offense for which the defendant must register as a sex offender, that is,
+solicitation of minors to engage in prostitution, in violation of Fl. Stat. 796.03. The
+defendant must enter this guilty plea before he is sentenced on the federal offenses.
+12. м
+The defendant agrees that he and the Palm Beach County State Attorney's
+Office will make a joint, binding recommendation that the Court impose a sentence of at
+least eighteen (18) months' imprisonment to be followed by at least twelve (12) months
+of community control/home confinement to be served upon the defendant's release from
+4
+
+
+federal prison. Those sentences may run concurrently with the federal sentence imposed
+pursuant to this agreement. [NB: The other option is: The defendant and the Palm
+Beach County State Attorney's Office shall make a joint, binding recommendation
+that the Court impose a sentence of at least sixty (60) months' probation, which will
+include at least twelve (12) months of community control/home confinement to be
+served upon the defendant's release from federal prison.]
+13.
+The defendant agrees to waive all challenges to the Information filed by the
+State Attorney's Office and to waive the right to appeal his conviction and sentence in the
+state court.
+The defendant agrees to provide to the U.S. Attorney's Office copies of all
+proposed agreements with the Palm Beach County State Attorney's Office prior to
+entering into those agreements.
+15.
+The defendant agrees that the timely completion of these actions is material
+to this agreement and is supported by independent consideration and that a breach of any
+one of these conditions allows the United States to elect to terminate the agreement and to
+investigate and prosecute Epstein for any and all federal offenses.
+16.
+The United States reserves the right to inform the Court and the probation
+office of all facts pertinent to the sentencing process, including all relevant information
+concerning the offenses committed, whether charged or not, as well as concerning the
+defendant and the defendant's background, and to respond to any questions from the
+Court and the Probation Office and to any misstatements of fact or law. Subject only to
+the express terms of any agreed-upon sentencing recommendations contained in this
+Agreement, this Office further reserves the right to make any recommendation as to the
+quality and quantity of punishment.
+17.
+The defendant is aware that the sentence has not yet been determined by the
+Court. The defendant also is aware that any estimate of the probable sentencing range or
+5
+
+
+sentence that the defendant may
+receive, whether that estimate comes from the
+defendant's attorney, the government, or the probation office, is a prediction, not a
+promise, and is not binding on the government, the probation office or the Court. The
+defendant understands further that any recommendation that the government makes to the
+Court as to sentencing, whether pursuant to this agreement or otherwise, is not binding on
+the Court and the Court may disregard the recommendation in its entirety. The defendant
+understands and acknowledges, as previously acknowledged in paragraph 4 above, that
+the defendant may not withdraw his plea based upon the Court's decision not to accept a
+sentencing
+recommendation made by the defendant, the government, or a
+recommendation made jointly by both the defendant and the government.
+WAIVER OF RIGHT TO APPEAL AND COLLATERALLY
+ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code,
+Section 3742 affords the defendant the right to appeal the sentence imposed in this case.
+Acknowledging this, in exchange for the undertakings made by the United States in this
+plea agreement, the defendant hereby waives all rights conferred by Section 3742 to
+appeal any sentence imposed, including any restitution order, or to appeal the manner in
+which the sentence was imposed, unless the sentence exceeds the maximum permitted by
+statute. The defendant further voluntarily and expressly waives, to the maximum extent
+permitted by federal law, the right to collaterally attack his sentence in any
+post-conviction proceeding, including a motion on any ground brought under 28 U.S.C. §
+2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further
+understands that nothing in this agreement shall affect the government's right and/or duty
+to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the
+United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant
+shall be released from the above waiver of appellate rights. By signing this agreement,
+the defendant acknowledges that he has discussed the appeal waiver set forth in this
+6
+
+
+19.
+If the defendant fails in any way to fulfill each one of his obligations under
+this Plea Agreement,
+the United States, and only the United States, may elect to be
+released from its commitments under this Plea Agreement. If the United States elects to
+void the Plea Agreement because of a breach by the defendant, then the United States
+agrees not to use the defendant's guilty plea against him. However, the United States
+may prosecute the defendant for any and all Federal crimes that he has committed related
+to this case and may seek any sentence for such crimes up to and including the statutory
+maximums. The defendant expressly waives any statute of limitations defense and any
+constitutional or statutory speedy trial defense to such a prosecution, except to the extent
+that such a defense exists as of the date he signs this Plea Agreement. Finally, the
+defendant understands that his violation of the terms of this Plea Agreement would not
+20.
+This is the entire agreement and understanding between the United States
+and the defendant. There are no other agreements, promises, representations, or
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+BY JEFFREY EPSTEIN, DEFENDANT
+7
+
+
+8
+
+
+UNITED STATES OF AMERICA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLEA AGREEMENT
+The United States Attorney for the Southern District of Florida ('the United
+States"), and Jeffrey Epstein (hereinafter referred to as the "defendant") enter into the
+following agreement:
+The defendant agrees to plead guilty to a two-count Information which
+charges the defendant as follows. Count 1 charges that the defendant intentionally
+harassed another person, that is, L.G., in an attempt to delay, prevent, and dissuade L.G.
+from attending or testifying in an official proceeding, that is a Federal Grand Jury
+appearance in the Southern District of Florida, in violation of Title 18, United States
+Code, Sections 1512(d)(2) and 2; and Count 2 charges that the defendant intentionally
+harassed another person, that is, Jane Doe #1, in an attempt to delay, prevent, and dissuade Jane
+Doe #1 from reporting to a law enforcement officer of the United States the commission of a
+federal offense; in violation of Title 18, United States Code, Sections 1512(d)(2) and 2.
+2.
+The defendant agrees and understands that the above charges involve
+his conduct, and the conduct of others, between in and around early 2001 through
+1
+9/18/07 12:07pm
+
+
+in and around September 2007 involving a conspiracy to solicit minors to engage
+in prostitution and to travel in interstate commerce to engage in illicit sexual
+conduct. _This agreement resolves the federal criminal liability of the defendant
+and any coconspirators in the Southern District of Florida growing out of any criminal
+conduct by those persons known to the United States Attorney's Office for the
+Southern District of Florida as of the date of this plea agreement, including but not
+limited to the above-described scheme.
+3.
+The United States agrees that, upon entry of the defendant's guilty
+plea, its Grand Jury investigation will be suspended, and all pending Grand Jury
+subpoenas will be held in abeyance unless and until the defendant violates any
+term of this agreement, as explained in paragraph _ below. The defendant
+likewise agrees to withdraw his pending motion to intervene and to quash certain
+grand jury subpoenas. The defendant further agrees that the current custodian of
+certain computer equipment shall maintain that evidence inviolate until all of the
+terms of this agreement have been satisfied.
+4. The defendant is aware that the sentence will be imposed by the Court after
+considering the Federal Sentencing Guidelines and Policy Statements (hereinafter
+"Sentencing Guidelines"). The defendant acknowledges and understands that the Court
+will compute an advisory sentence under the Sentencing Guidelines and that the
+applicable guidelines will be determined by the Court relying in part on the results of a
+Pre-Sentence Investigation by the Court's probation office, which investigation will
+commence after the guilty plea has been entered. The defendant is also aware that, under
+certain circumstances, the Court may depart from the advisory sentencing guideline range
+that it has computed, and may raise or lower that advisory sentence under the Sentencing
+Guidelines. The defendant is further aware and understands that the Court is required to
+2
+
+
+consider the advisory guideline range determined under the Sentencing Guidelines, but is
+not bound to impose that sentence; the Court is permitted to tailor the ultimate sentence in
+light of other statutory concerns, and such sentence may be either more severe or less
+severe than the Sentencing Guidelines' advisory sentence. Knowing these facts, the
+defendant understands and acknowledges that the Court has the authority to impose any
+sentence within and up to the statutory maximum authorized by law for the offenses
+identified in paragraph 1 and that the defendant may not withdraw the plea solely as a
+result of the sentence imposed.
+5.
+The defendant further understands and acknowledges that, as to each of
+Counts 1 and 2 of the Information, the Court may impose a statutory maximum term of
+imprisonment of up to one (1) year, to be followed by a term of supervised release of up
+to a maximum of one (1) year. In addition to terms of imprisonment and supervised
+release, the Court may impose a fine of up to $100,000 as to each count.
+The defendant further understands and acknowledges that, in addition to
+any sentence imposed under paragraph 3 of this Agreement, a special assessment in the
+amount of $50 will be imposed on the defendant, which must be paid at or before the
+time of sentencing.
+7.
+The defendant understands that the Court will order that he must pay full
+restitution to all victims of the offense to which he is pleading guilty. The defendant
+understands that the amount of restitution owed to each victim will be determined at or
+before sentencing.
+The parties agree to jointly recommend that the defendant receive a
+sentence of eighteen (18) months' imprisonment, to be followed by two (2) years of
+supervised release; and a fine of $200,000. The parties' further agree to jointly
+recommend that the Court impose one year of home confinement as a special condition of
+supervised release.
+3
+
+
+The defendant agrees that, if any of the victims identified in the federal
+investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the
+jurisdiction of the U.S. District Court for the Southern District of Florida over his person and/or
+the subject matter, and the defendant will not contest that the identified victims are persons who,
+while minors, were victims of violations of Title 18, United States Code, Sections(s) 2422 and/or
+2423. The United States agrees to provide the defendant's attorneys with a list of the identified
+victims, which will not exceed forty, after the defendant has signed this agreement and has been
+sentenced.
+• The United States further agrees to make a motion with the United States District
+Court for the Southern District of Florida for the appointment of a guardian ad litem for the
+identified victims and the defendant's counsel may contact the identified victims through that
+guardian.
+10. The defendant further understands and acknowledges that he must
+undertake certain actions with the State Attorney's Office for the 15th Judicial Circuit in
+and for Palm Beach County (hereinafter, "State Attorney's Office") in order to satisfy the
+United States' federal interest in the investigation and prosecution of his offenses, in
+accordance with the Justice Department's Petite policy. Epstein understands and
+acknowledges that the United States Attorney has no authority to require the State
+Attorney's Office to abide by any terms of this Agreement. Epstein understands that it is
+his obligation to undertake discussion with the State Attorney's Office to ensure
+compliance with these procedures.
+11.
+In addition to entering a guilty plea in the instant case, the defendant agrees
+to plead guilty to an Information filed by the Palm Beach County State Attorney's Office
+charging an offense for which the defendant must register as a sex offender, that is, solicitation
+of minors to engage in prostitution, in violation of Fl. Stat. 796.03. The defendant must enter
+this guilty plea before he is sentenced on the federal offenses.
+12.
+The defendant agrees that he and the Palm Beach County State Attorney's Office
+4
+
+
+will make a joint, binding recommendation that the Court impose a sentence of at least eighteen
+(18) months' imprisonment to be followed by at least twelve (12) months of community
+control/home confinement to be served upon the defendant's release from federal prison. Those
+sentences may run concurrently with the federal sentence imposed pursuant to this agreement.
+[NB: The other option is: The defendant and the Palm Beach County State Attorney's
+Office shall make a joint, binding recommendation that the Court impose a sentence of at
+least sixty (60) months' probation, which will include at least twelve (12) months of
+community control/home confinement to be served upon the defendant's release from
+federal prison.]
+13.
+The defendant agrees to waive all challenges to the Information filed by the State
+Attorney's Office and to waive the right to appeal his conviction and sentence in the state court.
+The defendant agrees to provide to the U.S. Attorney's Office copies of all
+proposed agreements with the Palm Beach County State Attorney's Office prior to entering into
+those agreements.
+15.
+The defendant agrees that the timely completion of these actions is material
+to this agreement and is supported by independent consideration and that a breach of any
+one of these conditions allows the United States to elect to terminate the agreement and to
+investigate and prosecute Epstein for any and all federal offenses.
+16.
+The United States reserves the right to inform the Court and the probation
+office of all facts pertinent to the sentencing process, including all relevant information
+concerning the offenses committed, whether charged or not, as well as concerning the
+defendant and the defendant's background, and to respond to any questions from the
+Court and the Probation Office and to any misstatements of fact or law. Subject only to
+the express terms of any agreed-upon sentencing recommendations contained in this
+Agreement, this Office further reserves the right to make any recommendation as to the
+quality and quantity of punishment.
+5
+
+
+17. The defendant is aware that the sentence has not yet been determined by the
+Court. The defendant also is aware that any estimate of the probable sentencing range or
+sentence that the defendant may receive, whether that estimate comes from the
+defendant's attorney, the government, or the probation office, is a prediction, not a
+promise, and is not binding on the government, the probation office or the Court. The
+defendant understands further that any recommendation that the government makes to the
+Court as to sentencing, whether pursuant to this agreement or otherwise, is not binding on
+the Court and the Court may disregard the recommendation in its entirety. The defendant
+understands and acknowledges, as previously acknowledged in paragraph 2 above, that
+the defendant may not withdraw his plea based upon the Court's decision not to accept a
+sentencing
+recommendation
+made by the defendant, the government, or a
+recommendation made jointly by both the defendant and the government.
+18. WAIVER OF RIGHT TO APPEAL AND COLLATERALLY
+ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code,
+Section 3742 affords the defendant the right to appeal the sentence imposed in this case.
+Acknowledging this, in exchange for the undertakings made by the United States in this
+plea agreement, the defendant hereby waives all rights conferred by Section 3742 to
+appeal any sentence imposed, including any restitution order, or to appeal the manner in
+which the sentence was imposed, unless the sentence exceeds the maximum permitted by
+statute. The defendant further voluntarily and expressly waives, to the maximum extent
+permitted by federal law,
+the right to collaterally attack his sentence in any
+post-conviction proceeding, including a motion on any ground brought under 28 U.S.C. §
+2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further
+understands that nothing in this agreement shall affect the government's right and/or duty
+to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the
+United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant
+6
+
+
+shall be released from the above waiver of appellate rights. By signing this agreement,
+the defendant acknowledges that he has discussed the appeal waiver set forth in this
+19.
+If the defendant fails in any way to fulfill each one of his obligations under
+this Plea Agreement, the United States, and only the United States, may clect to be
+released from its commitments under this Plea Agreement. If the United States elects to
+void the Plea Agreement because of a breach by the defendant, then the United States
+agrees not to use the defendant's guilty plea against him. However, the United States
+may prosecute the defendant for any and all Federal crimes that he has committed related
+to this case and may seek any sentence for such crimes up to and including the statutory
+maximums. The defendant expressly waives any statute of limitations defense and any
+constitutional or statutory speedy trial defense to such a prosecution, except to the extent
+that such a defense exists as of the date he signs this Plea Agreement. Finally, the
+defendant understands that his violation of the terms of this Plea Agreement would not
+20.
+This is the entire agreement and understanding between the United States
+There are no other agreements, promises, representations, or
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+7
+
+
+
+
+UNITED STATES OF AMERICA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLEA AGREEMENT
+The United States Attorney for the Southern District of Florida ("the United
+States"), and Jeffrey Epstein (hereinafter referred to as the "defendant") enter into the
+following agreement:
+The defendant agrees to plead guilty to the Information which charges the
+defendant as follows: Count 1 charges that the defendant intentionally harassed another
+person, that is, L.G., in an attempt to delay, prevent, and dissuade L.G. from attending or
+testifying in an official proceeding, that is a Federal Grand Jury appearance in the
+Southern District of Florida, in violation of Title 18, United States Code, Sections
+1512(d)(2) and 2; and Count 2 charges that the defendant, while in the special aircraft
+jurisdiction of the United States, did knowingly commit a simple assault on a person who
+was over the age of 16 years, that is, N.M., in violation of Title 18, United States Code,
+Section 113(a)(5); all in violation of Title 49, United States Code, Section 46506(1).
+2.
+The defendant is aware that the sentence will be imposed by the Court after
+considering the Federal Sentencing Guidelines and Policy Statements (hereinafter
+1
+9/16/07 4:42pm
+
+
+"Sentencing Guidelines"). The defendant acknowledges and understands that the Court
+will compute an advisory sentence under the Sentencing Guidelines and that the
+applicable guidelines will be determined by the Court relying in part on the results of a
+Pre-Sentence Investigation by the Court's probation office, which investigation will
+commence after the guilty plea has been entered. The defendant is also aware that, under
+certain circumstances, the Court may depart from the advisory sentencing guideline range
+that it has computed, and may raise or lower that advisory sentence under the Sentencing
+Guidelines. The defendant is further aware and understands that the Court is required to
+consider the advisory guideline range determined under the Sentencing Guidelines, but is
+not bound to impose that sentence; the Court is permitted to tailor the ultimate sentence in
+light of other statutory concerns, and such sentence may be either more severe or less
+severe than the Sentencing Guidelines' advisory sentence. Knowing these facts, the
+defendant understands and acknowledges that the Court has the authority to impose any
+sentence within and up to the statutory maximum authorized by law for the offenses
+identified in paragraph 1 and that the defendant may not withdraw the plea solely as a
+result of the sentence imposed.
+The defendant further understands and acknowledges that, as to Count 1 of
+the Information, the Court may impose a statutory maximum term of imprisonment of up
+to one (1) year, to be followed by a term of supervised release of up to a maximum of one
+(1) year. In addition to terms of imprisonment and supervised release, the Court may
+impose a fine of up to $100,000. The defendant further understands and acknowledges
+that, as to Count 2 of the Information, the Court may impose a statutory maximum term
+of imprisonment of up to six (6) months, to be followed by a term of supervised release
+of up to a maximum of one (1) year. In addition to terms of imprisonment and supervised
+release, the Court may impose a fine of up to $100,000.
+4. The defendant further understands and acknowledges that, in addition to
+2
+
+
+any sentence imposed under paragraph 3 of this Agreement, a special assessment in the
+amount of $50 will be imposed on the defendant, which must be paid at or before the
+time of sentencing.
+5.
+The defendant understands that the Court will order that he must pay full
+restitution to all victims of the offenses to which he is pleading guilty. The defendant
+understands that the amount of restitution owed to each victim will be determined at or
+before sentencing.
+The parties agree to jointly recommend that the defendant receive a
+sentence of eighteen (18) months' imprisonment, to be followed by two (2) years of
+supervised release; and a fine of $200,000.
+7.
+The defendant agrees that, if any of the victims identified in the federal
+investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the
+jurisdiction of the U.S. District Court for the Southern District of Florida over his person
+and/or the subject matter, and the defendant will not contest that the identified victims are
+persons who, while minors, were victims of violations of Title 18, United States Code,
+Sections(s) 2422 and/or 2423. The United States agrees to provide the defendant's
+attorneys with a list of the identified victims, which will not exceed forty, after the
+defendant has signed this agreement and has been sentenced. The United States further
+agrees to make a motion with the United States District Court for the Southern District of
+Florida for the appointment of a guardian ad litem for the identified victims and, the
+defendant's counsel may contact the identified victims through that guardian.
+8.
+The defendant agrees to plead guilty to the criminal charges in the
+Indictment as currently pending against him in the 15" Judicial Circuit in and for Palm
+Beach County and, in addition, agrees to plead guilty to a one-count Information charging
+the knowing procurement of a person under the age of 18 to engage in prostitution, in
+violation of F.S.A. § 796.03.
+3
+
+
+The defendant agrees that he and the Palm Beach County State Attorney's
+Office will resolve the criminal charges pending against him as follows:
+(a)
+the defendant will enter a plea agreement with the Palm Beach
+County State Attorney's Office forthwith and thereafter enter his
+plea of guilty to the indictment currently pending against him in the
+15"h Judicial Circuit in and for Palm Beach County (Case No.
+2006cf009495AXXXMB), and further agrees to plead guilty to a
+onecount information charging the knowing procurement of a person
+under the age of 18 to engage in prostitution, in violation of F.S.A. §
+796.03 on a date after his sentencing in the instant case;
+(b)
+within seven days of the defendant's sentencing in the instant case,
+but before the defendant begins serving his federal sentence, he will
+enter his plea of guilty to the indictment and information filed in the
+15h Circuit Judicial Court as described in paragraph (a);
+(c)
+the defendant and the Palm Beach County State Attorney's Office
+will make a joint, binding recommendation that the 15" Judicial
+Circuit Court impose a sentence as follows:
+(i)
+the defendant shall be placed on five (5) years' probation,
+with the following special conditions;
+(ii)
+the defendant shall serve the first eighteen (18) months of
+probation in custody, which will be served concurrently with
+the federal sentence imposed in the instant case;
+(iii)
+immediately following his release from custody, the
+defendant shall begin serving one (1) year of community
+control with electronic monitoring.
+4
+
+
+9.
+The defendant agrees to waive all challenges to the Information filed by the
+State Attorney's Office and to waive the right to appeal his conviction and sentence,
+unless the 15"h Judicial Circuit Court imposes a sentence that exceeds the terms of the
+joint recommendation in the state court.
+10. The defendant agrees that he will provide to the U.S. Attorney's Office
+copies of all proposed agreements with the Palm Beach County State Attorney's Office
+prior to entering into those agreements.
+11. The United States reserves the right to inform the Court and the probation
+office of all facts pertinent to the sentencing process, including all relevant information
+concerning the offenses committed, whether charged or not, as well as concerning the
+defendant and the defendant's background, and to respond to any questions from the
+Court and the Probation Office and to any misstatements of fact or law. Subject only to
+the express terms of any agreed-upon sentencing recommendations contained in this
+Agreement, this Office further reserves the right to make any recommendation as to the
+quality and quantity of punishment.
+12. The defendant is aware that the sentence has not yet been determined by the
+Court. The defendant also is aware that any estimate of the probable sentencing range or
+sentence that the defendant may receive, whether that estimate comes from the
+defendant's attorney, the government, or the probation office, is a prediction, not a
+promise, and is not binding on the government, the probation office or the Court. The
+defendant understands further that any recommendation that the government makes to the
+Court as to sentencing, whether pursuant to this agreement or otherwise, is not binding on
+the Court and the Court may disregard the recommendation in its entirety. The defendant
+understands and acknowledges, as previously acknowledged in paragraph 2 above, that
+the defendant may not withdraw his plea based upon the Court's decision not to accept a
+sentencing
+recommendation
+made by the defendant,
+the government,
+a
+5
+
+
+recommendation made jointly by both the defendant and the government.
+13. WAIVER OF RIGHT TO APPEAL AND COLLATERALLY
+ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code,
+Section 3742 affords the defendant the right to appeal the sentence imposed in this case.
+Acknowledging this, in exchange for the undertakings made by the United States in this
+plea agreement,
+, the defendant hereby waives all rights conferred by Section 3742 to
+appeal any sentence imposed, including any restitution order, or to appeal the manner in
+which the sentence was imposed, unless the sentence exceeds the maximum permitted by
+statute or is the result of an upward departure or upward variance from the guideline
+range that the Court establishes at sentencing. The defendant further voluntarily and
+expressly waives, to the maximum extent permitted by federal law, the right to
+collaterally attack his sentence in any postconviction proceeding, including a motion on any ground brought under 28 U.S.C. §
+2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further
+understands that nothing in this agreement shall affect the government's right and/or duty
+to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the
+United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant
+shall be released from the above waiver of appellate rights. By signing this agreement,
+the defendant acknowledges that he has discussed the appeal waiver set forth in this
+If the defendant fails in any way to fulfill each one of his obligations under
+this Plea Agreement, the United States, and only the United States, may elect to be
+released from its commitments under this Plea Agreement. If the United States elects to
+void the Plea Agreement because of a breach by the defendant, then the United States
+agrees not to use the defendant's guilty plea against him. However, the United States
+may prosecute the defendant for any and all Federal crimes that he has committed related
+6
+
+
+to this case and may seek any sentence for such crimes up to and including the statutory
+maximums. The defendant expressly waives any statute of limitations defense and any
+constitutional or statutory speedy trial defense to such a prosecution, except to the extent
+that such a defense exists as of the date he signs this Plea Agreement. Finally, the
+defendant understands that his violation of the terms of this Plea Agreement would not
+15.
+This is the entire agreement and understanding between the United States
+and the defendant. There are no other agreements, promises, representations,
+or
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+7
+
+
+UNITED STATES OF AMERICA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLEA AGREEMENT
+The United States Attorney for the Southern District of Florida ("the United
+States"), and Jeffrey Epstein (hereinafter referred to as the "defendant"') enter into the
+following agreement:
+1.
+The defendant agrees to plead guilty to the Information which charges the
+defendant as follows: Count 1 charges that the defendant intentionally harassed another
+person, that is, L.G., in an attempt to delay, prevent, and dissuade L.G. from attending or
+testifying in an official proceeding, that is a Federal Grand Jury appearance in the
+Southern District of Florida, in violation of Title 18, United States Code, Sections
+1512(d)(2) and 2; and Count 2 charges that the defendant, while in the special aircraft
+jurisdiction of the United States, did knowingly commit a simple assault on a person who
+was over the age of 16 years, that is, N.M., in violation of Title 18, United States Code,
+Section 113(a)(5); all in violation of Title 49, United States Code, Section 46506(1).
+2.
+The defendant is aware that the sentence will be imposed by the Court after
+considering the Federal Sentencing Guidelines and Policy Statements (hereinafter
+9/16/2007 12:09pm
+1
+
+
+"Sentencing Guidelines"). The defendant acknowledges and understands that the Court
+will compute an advisory sentence under the Sentencing Guidelines and that the
+applicable guidelines will be determined by the Court relying in part on the results of a
+Pre-Sentence Investigation by the Court's probation office, which investigation will
+commence after the guilty plea has been entered. The defendant is also aware that, under
+certain circumstances, the Court may depart from the advisory sentencing guideline range
+that it has computed, and may raise or lower that advisory sentence under the Sentencing
+Guidelines. The defendant is further aware and understands that the Court is required to
+consider the advisory guideline range determined under the Sentencing Guidelines, but is
+not bound to impose that sentence; the Court is permitted to tailor the ultimate sentence in
+light of other statutory concerns, and such sentence may be either more severe or less
+severe than the Sentencing Guidelines' advisory sentence. Knowing these facts, the
+defendant understands and acknowledges that the Court has the authority to impose any
+sentence within and up to the statutory maximum authorized by law for the offenses
+identified in paragraph 1 and that the defendant may not withdraw the plea solely as a
+result of the sentence imposed.
+The defendant further understands and acknowledges that, as to Count 1 of
+the Information, the Court may impose a statutory maximum term of imprisonment of up
+to one (1) year, to be followed by a term of supervised release of up to a maximum of one
+(1) year. In addition to terms of imprisonment and supervised release, the Court may
+impose a fine of up to $100,000. The defendant further understands and acknowledges
+that, as to Count 2 of the Information, the Court may impose a statutory maximum term
+of imprisonment of up to six (6) months, to be followed by a term of supervised release
+of up to a maximum of one (1) year. In addition to terms of imprisonment and supervised
+release, the Court may impose a fine of up to $100,000.
+4.
+The defendant further understands and acknowledges that, in addition to
+2
+
+
+any sentence imposed under paragraph 3 of this Agreement, a special assessment in the
+amount of $50 will be imposed on the defendant, which must be paid at or before the
+time of sentencing.
+The defendant understands that the Court will order that he must pay full
+restitution to all victims of the offenses to which he is pleading guilty. The defendant
+understands that the amount of restitution owed to each victim will be determined at or
+before sentencing.
+The parties agree to jointly recommend that the defendant receive a
+sentence of eighteen (18) months' imprisonment, to be followed by two (2) years of
+supervised release; and a fine of $200,000.
+The defendant agrees that, if any of the victims identified in the federal
+investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the
+jurisdiction of the U.S. District Court for the Southern District of Florida over his person
+and/or the subject matter, and the defendant will not contest that the identified victims are
+persons who, while minors, were victims of violations of Title 18, United States Code,
+Sections(s) 2422 and/or 2423. The United States agrees to provide the defendant's
+attorneys with a list of the identified victims, which will not exceed forty, after the
+defendant has signed this agreement and has been sentenced. The United States further
+agrees to make a motion with the United States District Court for the Southern District of
+Florida for the appointment of a guardian ad litem for the identified victims and the
+defendant's counsel may contact the identified victims through that guardian.
+8.
+The defendant agrees to plead guilty (not nolo contendere) to an
+Information filed by the Palm Beach County State Attorney's Office charging an offense
+for which the defendant must register as a sex offender, that is, solicitation of minors to
+engage in prostitution, in violation of Fl. Stat. 796.03. The defendant agrees that he and
+the Palm Beach County State Attorney's Office will make a joint, binding
+3
+
+
+recommendation that the Court impose a sentence of at least thirty (30) months, to be
+divided as follows:
+(a)
+the defendant shall begin by serving at least twenty (20) months in
+prison, without any opportunity for withholding adjudication or
+sentencing, and without probation or community control in lieu of
+imprisonment; and
+(b)
+following the term of imprisonment, the defendant shall serve ten
+(10)
+months
+of community control/home confinement with
+electronic monitoring.
+9.
+The defendant agrees to waive all challenges to the Information filed by the
+State Attorney's Office and to waive the right to appeal his conviction and sentence in the
+state court.
+The defendant agrees that he will provide to the U.S. Attorney's Office
+copies of all proposed agreements with the Palm Beach County State Attorney's Office
+prior to entering into those agreements.
+11.
+The United States reserves the right to inform the Court and the probation
+office of all facts pertinent to the sentencing process, including all relevant information
+concerning the offenses committed, whether charged or not, as well as concerning the
+defendant and the defendant's background, and to respond to any questions from the
+Court and the Probation Office and to any misstatements of fact or law. Subject only to
+the express terms of any agreed-upon sentencing recommendations contained in this
+Agreement, this Office further reserves the right to make any recommendation as to the
+quality and quantity of punishment.
+12.
+The defendant is aware that the sentence has not yet been determined by the
+Court. The defendant also is aware that any estimate of the probable sentencing range or
+sentence that the defendant may
+• receive, whether that estimate comes from the
+4
+
+
+defendant's attorney, the government, or the probation office, is a prediction, not a
+promise, and is not binding on the government, the probation office or the Court. The
+defendant understands further that any recommendation that the government makes to the
+Court as to sentencing, whether pursuant to this agreement or otherwise, is not binding on
+the Court and the Court may disregard the recommendation in its entirety. The defendant
+understands and acknowledges, as previously acknowledged in paragraph 2 above, that
+the defendant may not withdraw his plea based upon the Court's decision not to accept a
+sentencing
+recommendation made by the defendant, the government, or a
+recommendation made jointly by both the defendant and the government.
+13. WAIVER OF RIGHT TO APPEAL AND COLLATERALLY
+ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code,
+Section 3742 affords the defendant the right to appeal the sentence imposed in this case.
+Acknowledging this, in exchange for the undertakings made by the United States in this
+plea agreement, the defendant hereby waives all rights conferred by Section 3742 to
+appeal any sentence imposed, including any restitution order, or to appeal the manner in
+which the sentence was imposed, unless the sentence exceeds the maximum permitted by
+statute or is the result of an upward departure or upward variance from the guideline
+range that the Court establishes at sentencing. The defendant further voluntarily and
+expressly waives, to the maximum extent permitted by federal law, the right to
+collaterally attack his sentence in any postconviction proceeding, including a motion on any ground brought under 28 U.S.C. §
+2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further
+understands that nothing in this agreement shall affect the government's right and/or duty
+to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the
+United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant
+shall be released from the above waiver of appellate rights. By signing this agreement,
+5
+
+
+the defendant acknowledges that he has discussed the appeal waiver set forth in this
+If the defendant fails in any way to fulfill each one of his obligations under
+this Plea Agreement, the United States, and only the United States, may elect to be
+released from its commitments under this Plea Agreement. If the United States elects to
+void the Plea Agreement because of a breach by the defendant, then the United States
+agrees not to use the defendant's guilty plea against him. However, the United States
+may prosecute the defendant for any and all Federal crimes that he has committed related
+to this case and may seek any sentence for such crimes up to and including the statutory
+maximums. The defendant expressly waives any statute of limitations defense and any
+constitutional or statutory speedy trial defense to such a prosecution, except to the extent
+that such a defense exists as of the date he signs this Plea Agreement.
+Finally, the
+defendant understands that his violation of the terms of this Plea Agreement would not
+15. This is the entire agreement and understanding between the United States
+and the defendant. There are no other agreements, promises, representations, or
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+6
+
+
+7
+
+
+UNITED STATES OF AMERICA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+/
+PLEA AGREEMENT
+The United States Attorney for the Southern District of Florida ("the United
+States"), and Jeffrey Epstein (hereinafter referred to as the "defendant") enter into the
+following agreement:
+1.
+The defendant agrees to plead guilty to the Information which charges the
+defendant with two counts of intentionally harassing another person, that is, Jane Does #1 and
+2, in an attempt to delay, prevent, and dissuade Jane Does #1 and 2 from reporting to a law
+enforcement officer of the United States the commission of a federal offense; in violation of Title
+18, United States Code, Sections 1512(d)(2) and 2.
+2.
+The defendant is aware that the sentence will be imposed by the Court after
+considering the Federal Sentencing Guidelines and Policy Statements (hereinafter
+"Sentencing Guidelines"). The defendant acknowledges and understands that the Court
+will compute an advisory sentence under the Sentencing Guidelines and that the
+applicable guidelines will be determined by the Court relying in part on the results of a
+Pre-Sentence Investigation by the Court's probation office, which investigation will
+9/14/2007 8:53am
+1
+
+
+commence after the guilty plea has been entered. The defendant is also aware that, under
+certain circumstances, the Court may depart from the advisory sentencing guideline range
+that it has computed, and may raise or lower that advisory sentence under the Sentencing
+Guidelines. The defendant is further aware and understands that the Court is required to
+consider the advisory guideline range determined under the Sentencing Guidelines, but is
+not bound to impose that sentence; the Court is permitted to tailor the ultimate sentence in
+light of other statutory concerns, and such sentence may be either more severe or less
+severe than the Sentencing Guidelines' advisory sentence. Knowing these facts, the
+defendant understands and acknowledges that the Court has the authority to impose any
+sentence within and up to the statutory maximum authorized by law for the offenses
+identified in paragraph 1 and that the defendant may not withdraw the plea solely as a
+result of the sentence imposed
+The defendant further understands and acknowledges that, as to each of
+Counts 1 and 2 of the Information, the Court may impose a statutory maximum term of
+imprisonment of up to one (1) year, to be followed by a term of supervised release of up
+to a maximum of one (1) year. In addition to terms of imprisonment and supervised
+release, the Court may impose a fine of up to $100,000 as to each count.
+4.
+The defendant further understands and acknowledges that, in addition to
+any sentence imposed under paragraph 3 of this Agreement, a special assessment in the
+amount of $50 will be imposed on the defendant, which must be paid at or before the
+time of sentencing.
+The defendant understands that the Court will order that he must pay full
+restitution to all victims of the offense to which he is pleading guilty. The defendant
+understands that the amount of restitution owed to each victim will be determined at or
+before sentencing.
+The defendant agrees that, if any of the victims identified in the federal
+2
+
+
+investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the
+jurisdiction of the U.S. District Court for the Southern District of Florida over his person and/or
+the subject matter, and the defendant will not contest that the identified victims are persons who,
+while minors, were victims of violations of Title 18, United States Code, Sections(s) 2422 and/or
+2423. The United States agrees to provide the defendant's attorneys with a list of the identified
+victims, which will not exceed forty, after the defendant has signed this agreement and has been
+sentenced. The United States further agrees to make a motion with the United States District
+Court for the Southern District of Florida for the appointment of a guardian ad litem for the
+identified victims and the defendant's counsel may contact the identified victims through that
+guardian.
+The defendant agrees to plead guilty (not nolo contendere) to an Information
+filed by the Palm Beach County State Attorney's Office charging an offense for which the
+defendant must register as a sex offender, that is, solicitation of minors to engage in prostitution,
+in violation of FI. Stat. 796.03. The defendant and the Palm Beach County State Attorney's
+Office shall make a joint, binding recommendation that the Court impose a sentence of at least
+thirty (30) months, to be divided as follows:
+(a)
+the defendant shall begin by serving at least twenty (20) months in prison,
+without any opportunity for withholding adjudication or sentencing, and
+without probation or community control in lieu of imprisonment; and
+(b)
+following the term of imprisonment, the defendant shall serve ten (10)
+months of community control/home confinement with electronic
+monitoring.
+8.
+The defendant shall waive all challenges to the Information filed by the State
+Attorney's Office and shall waive the right to appeal his conviction and sentence in the state
+court.
+The defendant shall provide to the U.S. Attorney's Office copies of all proposed
+3
+
+
+agreements with the Palm Beach County State Attorney's Office prior to entering into those
+agreements.
+The United States reserves the right to inform the Court and the probation
+office of all facts pertinent to the sentencing process, including all relevant information
+concerning the offenses committed, whether charged or not, as well as concerning the
+defendant and the defendant's background, and to respond to any questions from the
+Court and the Probation Office and to any misstatements of fact or law. Subject only to
+the express terms of any agreed-upon sentencing recommendations contained in this
+Agreement, this Office further reserves the right to make any recommendation as to the
+quality and quantity of punishment.
+11. The defendant is aware that the sentence has not yet been determined by the
+Court. The defendant also is aware that any estimate of the probable sentencing range or
+sentence that the defendant may receive, whether that estimate comes from the
+defendant's attorney, the government, or the probation office, is a prediction, not a
+promise, and is not binding on the government, the probation office or the Court. The
+defendant understands further that any recommendation that the government makes to the
+Court as to sentencing, whether pursuant to this agreement or otherwise, is not binding on
+the Court and the Court may disregard the recommendation in its entirety. The defendant
+understands and acknowledges, as previously acknowledged in paragraph 2 above, that
+the defendant may not withdraw his plea based upon the Court's decision not to accept a
+sentencing
+recommendation
+made by the defendant, the government, or a
+recommendation made jointly by both the defendant and the government.
+12. WAIVER OF RIGHT TO APPEAL AND COLLATERALLY
+ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code,
+Section 3742 affords the defendant the right to appeal the sentence imposed in this case.
+Acknowledging this, in exchange for the undertakings made by the United States in this
+4
+
+
+plea agreement, the defendant hereby waives all rights conferred by Section 3742 to
+appeal any sentence imposed, including any restitution order, or to appeal the manner in
+which the sentence was imposed, unless the sentence exceeds the maximum permitted by
+statute or is the result of an upward departure or upward variance from the guideline
+range that the Court establishes at sentencing. The defendant further voluntarily and
+expressly waives, to the maximum extent permitted by federal law, the right to
+collaterally attack his sentence in any post-conviction proceeding, including a motion on
+any ground brought under 28 U.S.C. § 2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18
+U.S.C. § 3771. The defendant further understands that nothing in this agreement shall
+affect the government's right and/or duty to appeal as set forth in Title 18, United States
+Code, Section 3742(b). However, if the United States appeals the defendant's sentence
+pursuant to Section 3742(b), the defendant shall be released from the above waiver of
+appellate rights. By signing this agreement, the defendant acknowledges that he has
+discussed the appeal waiver set forth in this agreement with his attorney.
+13.
+If the defendant fails in any way to fulfill each one of his obligations under
+this Plea Agreement, the United States, and only the United States, may elect to be
+released from its commitments under this Plea Agreement. If the United States elects to
+void the Plea Agreement because of a breach by the defendant, then the United States
+agrees not to use the defendant's guilty plea against him. However, the United States
+may prosecute the defendant for any and all Federal crimes that he has committed related
+to this case and may seek any sentence for such crimes up to and including the statutory
+maximums. The defendant expressly waives any statute of limitations defense and any
+constitutional or statutory speedy trial defense to such a prosecution, except to the extent
+that such a defense exists as of the date he signs this Plea Agreement. Finally, the
+defendant understands that his violation of the terms of this Plea Agreement would not
+5
+
+
+
+
+This is the entire agreement and understanding between the United States
+There are no other agreements, promises, representations, or
+BY: R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+7
+
+
+D
+UNITED STATES OF AMERICA
+VS.
+JEFFREY EPSTEIN,
+Defendin
+PLEA AGREEMENT
+The United States Attorney forthe Southern District of Florida ("the United States"),
+and Jeffrey Epstein (hereinafter referred to as the "defendant") enter into the following
+agreement:
+The defendant agrees to plead guilty to the Information which charges the
+defendant as follows: Count 1 charges that thalfendant knowingly and intentionally
+violated the privacy protection accorded to child victims by 18 U.S.C. § 3509; in violation
+of Title 18, United States Code, Sections 403 and 2; and Count 2 charges that the defendant,
+while in an airplane over the high seas, did knowingly commit a simple assault on a person
+who was over the age of 16 years, that is, S.K.; in violation of Title 18, United States Code,
+Section 113(a)(5).
+The defendant is aware that the sentence will be imposed by the Court after
+considering the Federal Sentencing Guidelines and Policy Statements (hereinafter
+
+9/15/20072:46pm
+
+
+"Sentencing Guidelines"). The defendant acknowledges and understands that the Court will
+compute an advisory sentence under the Sentencing Guidelines and that the applicable
+guide if Till determined by the Court relying in part on the results of a PreSentence
+Investigation by the Court's probation office, which investigation will commence after the
+guilty plea has been entered. The defendant is also aware that, under certain circumstances,
+the Court may depart from the advisory sentencing guideline range that it has computed, and
+may raise or lower that arisory sentence under the Sentencing Guidelines. The defendant
+is further aware and understands that the Court is required to consider the advisory guideline
+range determined under the Sentencing Guidelines, but is not bound to impose that sentence;
+the Court is permitted to tailor the ulfugate sentence in light of other statutory concerns, and
+such sentence may be either more severe or less severe than the Sentencing Guidelines'
+advisory sentence. Knowing these facts, the defendant understands and acknowledges that
+the Court has the authority to impose any sentencerwithin and up to the statutory maximum
+authorized by law for the offenses identified in paragraph 1 and that the defendant may not
+withdraw the plea solely as a result of the sentence imposed.
+The defendant further understands and acknowledges that, as to Count 1 of the
+Information, the Court may impose a statutory maximum term of imprisonment of up to one
+(1) year, to be followed by a term of supervised release of up to a maximum of one (1) year.
+In addition to terms of imprisonment and supervised release, the Court may impose a fine of
+up to $100,000. The defendant further understands and acknowledges that, as to Count 2 of
+the Information, the Court may impose a statutory maximum term of imprisonment of up to
+
+
+
+six (6) months, to be followed by a term of supervised release of up to a maximum of one (1)
+year. In addition to terms of imprisonment and supervised release, the Court may impose a
+Tine of i 2 100,000.
+The defendant further understands and acknowledges that, in addition to any
+sentence imposed under paragraph 3 of this Agreement, a special assessment in the amount
+of $50 will be imposed on the defendant, which must be paid at or before the time of
+sentencing.
+R
+The defendant understands that the Court will order that he must pay full
+restitution to all victims of the offense to which he is pleading guilty. The defendant
+understands that the amount of restition owed to each victim will be determined at or
+before sentencing.
+The parties agree to jointly recommend that the defendant receive a sentence
+of eighteen (18) months' imprisonment, to be foltowed by two (2) years of supervised
+release; and a fine of $200,000.
+The defendant agrees that, if any of the victims identified in the federal
+investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the
+jurisdiction of the U.S. District Court for the Southern District of Florida over his person
+and/or the subject matter, and the defendant will not contest that the identified victims are
+persons who, while minors, were victims of violations of Title 18, United States Code,
+Sections(s) 2422 and/or 2423. The United States agrees to provide the defendant's attorneys
+with a list of the identified victims, which will not exceed forty, after the defendant has
+
+
+
+signed this agreement and has been sentenced. The United States further agrees to make a
+motion with the United States District Court for the Southern District of Florida for the
+appointment of a guardian ad litem for the identified victims and the defendant's counsel may
+contact the identified victims through that guardian.
+8.
+The defendant agrees to plead guilty (not nolo contendere) to an Information
+filed by the Palm Beach County State Attorney's Office charging an offense for which the
+defendant must register as a sex offender, that is, solicitation of minors to engage in
+prostitution, in violation of Fl. Stat. 796.03. The defendant agrees that he and the Palm
+Beach County State Attorney's Office will make a joint, binding recommendation that the
+Court impose a sentence of at least thirty (30) months, to be divided as follows:
+(a)
+the defendant shall begin by serving at least twenty (20) months in
+prison, without any opportunity for withholding adjudication or
+sentencing, and without probation or community control in lieu of
+imprisonment; and
+(b)
+following the term of imprisonment, the defendant shall serve ten (10)
+months of community control/home confinement with electronic
+monitoring.
+T
+The defendant agrees to waive all challenges to the Information filed by the
+State Attorney's Office and to waive the right to appeal his conviction and sentence in the
+state court.
+The defendant agrees that he will provide to the U.S. Attorney's Office copies
+
+
+
+of all proposed agreements with the Palm Beach County State Attorney's Office prior to
+entering into those agreements.
+D
+The United States reserves the right to inform the Court and the probation
+office of all facts pertinent to the sentencing process, including all relevant information
+concerning the offenses committed, whether charged or not, as well as concerning the
+defendant and the defendant's background, and to respond to any questions from the Court
+and the Probation Orite and to any misstatements of fact or law. Subject only to the express
+terms of any agreed-upon sentencing recommendations contained in this Agreement, this
+Office further reserves the right to make any recommendation as to the quality and quantity
+of punishment.
+A
+12.
+The defendant is aware that the sentence has not yet been determined by the
+Court. The defendant also is aware that any estimate of the probable sentencing range or
+sentence that the defendant may receive, whether that estimate comes from the defendant's
+attorney, the government, or the probation office, is a prediction, not a promise, and is not
+binding on the government, the probation office or the Court. The defendant understands
+further that any recommendation that the government makes to the Court as to sentencing,
+Whether pursuant to this agreement or otherwise, is not binding ole the Court and the Court
+may disregard the recommendation in its entirety. The defendant understands and
+acknowledges, as previously acknowledged in paragraph 2 above, that the defendant may not
+withdraw his plea based upon the Court's decision not to accept a sentencing
+recommendation made by the defendant, the government, or a recommendation made jointly
+
+
+
+by both the defendant and the government.
+13.
+WAIVER OF RIGHT TO APPEAL AND COLLATERALLY ATTACK
+THE SIN UNCE. The defendant is aware that Title 18, United States Code, Section 3742
+affords the defendant the right to appeal the sentence imposed in this case. Acknowledging
+this, in exchange for the undertakings made by the United States in this plea agreement, the
+defendant hereby waives all rights conferred by Section 3742 to appeal any sentence
+imposed, including any postitution order, or to appeal the manner in which the sentence was
+imposed, unless the sentence exceeds the maximum permitted by statute or is the result of
+an upward departure or upward variance from the guideline range that the Court establishes
+at sentencing. The defendant further yoluntarily and expressly waives, to the maximum
+extent permitted by federal law, the right to collaterally attack his sentence in any postconviction proceeding, including a motion on any ground brought under 28 U.S.C. § 2254,
+28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. §B771. The defendant further understands
+that nothing in this agreement shall affect the government's right and/or duty to appeal as set
+forth in Title 18, United States Code, Section 3742(b). However, if the United States appeals
+the defendant's sentence pursuant to Section 3742(b), the defendant shall be released from
+the above waiver of appellate rights. By signing this agreement, the defendant acknowledges
+that he has discussed the appeal waiver set forth in this agreement with his attorney.
+If the defendant fails in any way to fulfill each one of his obligations under this
+Plea Agreement, the United States, and only the United States, may elect to be released from
+its commitments under this Plea Agreement. If the United States elects to void the Plea
+
+
+
+Agreement because of a breach by the defendant, then the United States agrees not to use the
+defendant's guilty plea against him. However, the United States may prosecute the defendant
+for any indull Federal crimes that he has commited related to this case and may seck any
+sentence for such crimes up to and including the statutory maximums. The defendant
+expressly waives any statute of limitations defense and any constitutional or statutory speedy
+trial defense to such a prosecution, except to the extent that such a defense exists as of the
+date ho signs this Pleasemen. Final, the defendant understand that his violation of
+the terms of this Plea Agreement would not entitle him to withdraw his guilty plea.
+15. This is the entire agreement and understanding between the United States and
+the defendant. There are no other agents, promises, representations, or understandings.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+T
+JAY LEFKOWITZ., ESQ.
+
+
+
+UNITE
+BOATES OF AMERICA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+R
+PLEA AGREEMENT
+The United States Attorney for the Southern District of Florida ("the United States"),
+and Jeffiey Epstein (hercinafter refered to as thefitorindant) enter into the following
+agreement:
+The defendant agrees to plead guilty to the Information which charges the
+defendant as follows: Count 1 charges that the defendant intentionally harassed another person,
+that is Jane Doe 41, in an attempt to delay, prevent, and dissuade Jar-Doe t from reporting to a
+law enforcement officer of the United States the commission of a federal offense; in violation of
+Title 18, United States Code, Sections 1512(d)(2) and 2; and Count 2 charges that the defendant,
+while in an airplane over the high seas, did knowingly commit a simple assault on a person who was
+overthe as hat's ki idion of it 8, ried sues code, sociate s
+2.
+The defendant is aware that the sentence will be imposed by the Court after
+considering the Federal Sentencing Guidelines and Policy Statements (hereinafter
+
+9/14/20079:48am
+
+
+"Sentencing Guidelines"). The defendant acknowledges and understands that the Court will
+compute an advisory sentence under the Sentencing Guidelines and that the applicable
+guidelines will be determined by the Court relying in part on the results of a Pre-Sentence
+Investigation by the Court's probation office, which investigation will commence after the
+guilty plea has been entered. The defendant is also aware that, under certain circumstances,
+the Court may depart from the advisory sentencing guideline range that it has computed, and
+may raise or lower that advisary secule under the sentencing Guidelines. The defendant
+is further aware and understands that the Court is required to consider the advisory guideline
+range determined under the Sentencing Guidelines, but is not bound to impose that sentence;
+the Court is permitted to tailor the ultimate sentence in light of' other statutory concerns, and
+such sentence may be either more severe or less
+severe than the Sentencing Guidelines'
+advisory sentence. Knowing these facts, the defendant understands and acknowledges that
+the Court has the authority to impose any sentence within and up to the statutory maximum
+authoried by lav for the fires ioni red in pargriph andey he defendant may not
+withdraw the plea solely as a result of the sentence imposed.
+The defendant further understands and acknowledges that, as to Count 1 of the
+Information, the Court may impose a statutory maximum term of imprisonment of up to one
+(1) year, to be followed by a term of supervised release of up to a maximum of go (1) year.
+In addition to terms of imprisonment and supervised release, the Court may impose a fine of
+up to $100,000. The defendant further understands and acknowledges that, as to Count 2 of
+the Information, the Court may impose a statutory maximum term of imprisonment of up to
+
+
+
+six (6) months, to be followed by a term of supervised release of up to a maximum of one (1)
+year. In addition to terms of imprisonment and supervised release, the Court may impose a
+The defendant further understands and acknowledges that, in addition to any
+sentence imposed under paragraph 3 of this Agreement, a special assessment in the amount
+of $50 will be imposed on the defendant, which must be paid at or before the time of
+sentencing.
+R
+The defendant understands that the Court will order that he must pay full
+restitution to all victims of the offense to which he is pleading guilty. The defendant
+understands that the amount of restitution owed to each victim will be determined at or
+before sentencing.
+The parties agree to jointly recommend that the defendant receive a sentence
+of eighteen (18) months' imprisonment, to be followed by two (2) years of supervised
+release; and a fine of $200,000.
+7.
+The drea to oh, ray of victim let re into federal investigation.
+file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the jurisdiction of the U.S.
+District Court for the Southern District of Florida over his person and/or the subject matter, and the
+defendant will not contest that the identified victims are persons who, while minors, were victims
+of violations of Title 18, United States Code, Sections(s) 2422 and/or 2423. The United States
+agrees to provide the defendant's attorneys with a list of the identified victims, which will not
+exceed forty, after the defendant has signed this agreement and has been sentenced. The United
+
+
+
+States further agrees to make a motion with the United States District Court for the Southern District
+of Florida for the appointment of a guardian ad litem for the identified victims and the defendant's
+counsel may contact the identified victims through that guardian.
+The defendant agrees to plead guilty (not nolo contendere) to an Information filed
+by the Palm Beach County State Attorney's Office charging an offense for which the defendant must
+register as a sex offender, that is, solicitation of minors to engage in prostitution, in violation of Fl.
+Stat. 796.03. The defendant agrees that he and the Palm Beach County State Attorney's Office will
+make a joint, binding recommendation that the Court impose a sentence of at least thirty (30)
+months, to be divided as follows:
+(a)
+the defendant shall begin by serving at least twenty (20) months in prison,
+without any opportunity for withholding adjudication or sentencing, and
+without probation or community control in lieu of imprisonment; and
+(b)
+following the term of imprisonment, the defendant shall serve ten (10)
+months of community control/home confinement with electronic monitoring.
+9.
+The defendant agrees to waive all challenges to the Information filed by the State
+Attorney's Office and to waive the right to appeal his conviction and sentence in the state court.
+The defendant agrees that he will provide to the U.S. Attorney's Office copies of all
+proposed agreements with the Palm Beach County State Attorney's Office prior to entering into
+those agreements.
+The United States reserves the right to inform the Court and the probation
+office of all facts pertinent to the sentencing process, including all relevant information
+concerning the offenses committed, whether charged or not, as well as concerning the
+
+
+
+defendant and the defendant's background, and to respond to any questions from the Court
+and the Probation Office and to any misstatements of fact or law. Subject only to the express
+terms ofany agreed-upon sentencing recommendations contained in this Agreement, this
+Office fürther reserves the right to make any recommendation as to the quality and quantity
+of punishment.
+The defendant is aware that the sentence has not yet been determined by the
+Court. The defendant also is award hilt any estimate of the probable sentencing range or
+sentence that the defendant may receive, whether that estimate comes from the defendant's
+attorney, the government, or the probation office, is a prediction, not a promise, and is not
+binding on the government, the probation office or the Court. The defendant understands
+further that any recommendation that the governmen makes to the Court as to sentencing,
+whether pursuant to this agreement or otherwise, is not binding on the Court and the Court
+may disregard the recommendation in its entirety. The defendant understands and
+acknowledges, as previously acknowledged in paragraph 2 above that the defendant may not
+withdraw his plea based upon the Court's decision not to accept a sentencing
+recommendation made by the defendant, the government, or a recommendation made jointly
+by both the defendant and the government.
+13.
+WAIVEROF RIGHT TO APPEAL AND COLLATERAL ATTACK
+THE SENTENCE. The defendant is aware that Title 18, United States Code, Section 3742
+affords the defendant the right to appeal the sentence imposed in this case. Acknowledging
+this, in exchange for the undertakings made by the United States in this plea agreement, the
+
+
+
+defendant hereby waives all rights conferred by Section 3742 to appeal any sentence
+imposed, including any restitution order, or to appeal the manner in which the sentence was
+imposed,
+-unless the sentence exceeds the maximum permitted by statute or is the result of
+an upward departure or upward variance from the guideline range that the Court establishes
+at sentencing. The defendant further voluntarily and expressly waives, to the maximum
+extent permitted by federal law, the right to collaterally attack his sentence in any postconviction proceeding, including a pillon on any ground brought under 28 U.S.C. 2254,
+28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further understands
+that nothing in this agreement shall affect the government's right and/or duty to appeal as set
+forth in Title 18, United States Code, Section 3742(b). However, if the United States appeals
+the defendant's sentence pursuant to Section 3742 b) the defendant shall be released from
+the above waiver of appellate rights. By signing this agreement, the defendant acknowledges
+that he has discussed the appeal waiver set forth in this agreement with his attorney.
+If the defendant fails in any way to fulfill each one of his obligations under this
+Plea Agreement, the United States, and only the United States, may elect to be released from
+its commitments under this Plea Agreement. If the United States elects to void the Plea
+Agreement because of a breach by the defendant, then the United States agrees not to use the
+defendant's guilty pleagainsthim. However, the United States may prosecute ledetendant
+for any and all Federal crimes that he has committed related to this case and may seek any
+sentence for such crimes up to and including the statutory maximums. The defendant
+expressly waives any statute of limitations defense and any constitutional or statutory speedy
+
+
+
+• trial defense to such a prosecution, except to the extent that such a defense exists as of the
+date he signs this Plea Agreement. Finally, the defendant understands that his violation of
+the terms of this Plea Agreement would not entitle him to withdraw his guilty plea.
+This is the entire agreement and understanding between the United States and
+the defendant. There are no other agreements, promises, representations, or understandings.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+JEFFRI APSTEIN, DEFENDANT
+ATTORNEY FOR DEEMDANT
+T
+
+
+
+Case No. _
+UNITED STATES OF AMERICA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLEA AGREEMENT
+The United States Attorney for the Southern District of Florida ("the United
+States"), Jeffrey Epstein (hereinafter referred to as the "defendant"), and counsel for the
+defendant, subject to approval by the Court, have agreed upon a negotiated plea pursuant
+to Rule 11 of the Federal Rules of Criminal Procedure and governed in part by Rule
+11(c)(1)(C), the terms of which are as follows:
+1. The defendant agrees to plead guilty to the Information which charges that
+the defendant did knowingly and willfully combine, conspire, confederate and agree with
+persons known and unknown to commit an offense against the United States, that is, to
+use a facility or means of interstate or foreign commerce to knowingly persuade, induce,
+and entice individuals who had not attained the age of 18 years to engage in prostitution,
+in violation of Title 18, United States Code, Section 2422(b); all in violation of Title 18,
+United States Code, Section 37l.
+The defendant is aware that the statutory maximum sentence for the offense
+listed in paragraph one is five (5) years' imprisonment, to be followed by up to three
+1
+9/7/2007 9:31am
+
+
+years' supervised release. In addition to terms of imprisonment and supervised release,
+the Court may impose a fine of up to $250,000.
+The defendant also has been advised and understands that under the Sex
+Offender Registration and Notification Act, he must register as a sex offender and keep
+the registration current in each of the following jurisdictions: where he resides; where he
+is an employee; and where he is a student. The defendant understands and acknowledges
+that the requirements for registration include providing his name, his residence address,
+and the names and addresses of any places where he is or will be an employee or a
+student, among other information. The defendant further understands that, not later than
+three business days after any change of name, residence, employment, or student status,
+he must inform at least one jurisdiction in which he resides, is an employee, or is a
+student of such change. The defendant has been advised, and understands, that failure to
+comply with these obligations subjects him to prosecution for failure to register under
+federal law, 18 U.S.C. § 2250, which is punishable by a fine or imprisonment, or both.
+4.
+The defendant further understands and acknowledges that, in addition to
+any sentence imposed under paragraph 2 of this Agreement, a special assessment in the
+amount of $100 will be imposed on the defendant, which must be paid at or before the
+time of sentencing.
+The defendant understands that the Court will order that he must pay full
+restitution to all victims of the offense to which he is pleading guilty. The defendant
+understands that the amount of restitution owed to cach victim will be determined at or
+before sentencing.
+This Plea Agreement is governed, in part, by Federal Rule of Criminal
+Procedure 11(c)(1)(C). The parties have agreed that the defendant's sentence imposed by
+the Court shall be two (2) years' imprisonment to be followed by three (3) years'
+supervised release, and a $250,000 fine. If the Court accepts and imposes the agreed
+2
+
+
+term of imprisonment, the defendant may not withdraw this plea.
+The United States reserves the right to inform the Court and the probation
+office of all facts pertinent to the sentencing process, including all relevant information
+concerning the offenses committed, whether charged or not, as well as concerning the
+defendant and the defendant's background, and to respond to any questions from the
+Court and the Probation Office and to any misstatements of fact or law.
+8.
+The defendant understands and agrees that federal law mandates that he be
+taken into federal custody upon the entry of his guilty plea.
+WAIVER OF RIGHT TO APPEAL AND COLLATERALLY
+ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code,
+Section 3742 affords the defendant the right to appeal the sentence imposed in this case.
+Acknowledging this, in exchange for the undertakings made by the United States in this
+plea agreement, the defendant hereby waives all rights conferred by Section 3742 to
+appeal any sentence imposed, including any restitution order, or to appeal the manner in
+which the sentence was imposed, unless the sentence exceeds the maximum permitted by
+statute or is the result of an upward departure or upward variance from the guideline
+range that the Court establishes at sentencing. The defendant further voluntarily and
+expressly waives, to the maximum extent permitted by federal law, the right to
+collaterally attack his sentence in any postconviction proceeding, including a motion on any ground brought under 28 U.S.C. §
+2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further
+understands that nothing in this agreement shall affect the government's right and/or duty
+to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the
+United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant
+shall be released from the above waiver of appellate rights. By signing this agreement,
+the defendant acknowledges that he has discussed the appeal waiver set forth in this
+3
+
+
+If the defendant fails in any way to fulfill each one of his obligations under
+this Plea Agreement, the United States, and only the United States, may elect to be
+released from its commitments under this Plea Agreement. If the United States elects to
+void the Plea Agreement because of a breach by the defendant, then the United States
+agrees not to use the defendant's guilty plea against him. However, the United States
+may prosecute the defendant for any and all Federal crimes that he has committed related
+to this case and may seek any sentence for such crimes up to and including the statutory
+maximums.
+The defendant expressly waives any statute of limitations defense and any
+constitutional or statutory speedy trial defense to such a prosecution, except to the extent
+that such a defense exists as of the date he signs this Plea Agreement. Finally, the
+defendant understands that his violation of the terms of this Plea Agreement would not
+11.
+This is the entire agreement and understanding between the United States
+There are no other agreements, promises, representations, or
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+A. MARIE VILLAFAÑA
+ASSISTANT UNITED STATES ATTORNEY
+4
+
+
+
+
+UNITED STATES OF AMERICA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLEA AGREEMENT
+The United States Attorney for the Southern District of Florida ("the United
+States"), Jeffrey Epstein (hereinafter referred to as the "defendant"), and counsel for the
+defendant, subject to approval by the Court, have agreed upon a negotiated plea pursuant
+to Rule 11 of the Federal Rules of Criminal Procedure and governed in part by Rule
+11(c)(1)(C), the terms of which are as follows:
+1.
+The defendant agrees to plead guilty to the Information which charges that
+the defendant did knowingly and willfully combine, conspire, confederate and agree with
+persons known and unknown to commit an offense against the United States, that is, to
+use a facility or means of interstate or foreign commerce to knowingly persuade, induce,
+and entice individuals who had not attained the age of 18 years to engage in prostitution,
+in violation of Title 18, United States Code, Section 2422(b); all in violation of Title 18,
+United States Code, Section 371.
+2.
+The defendant is aware that the statutory maximum sentence for the offense
+listed in paragraph one is five (5) years' imprisonment, to be followed by up to three
+1
+9/7/2007 1:17pm
+
+
+years' supervised release. In addition to terms of imprisonment and supervised release,
+the Court may impose a fine of up to $250,000.
+The defendant also has been advised and understands that under the Sex
+Offender Registration and Notification Act, he must register as a sex offender and keep
+the registration current in each of the following jurisdictions: where he resides; where he
+is an employee; and where he is a student. The defendant understands and acknowledges
+that the requirements for registration include providing his name, his residence address,
+and the names and addresses of any places where he is or will be an employee or a
+student, among other information. The defendant further understands that, not later than
+three business days after any change of name, residence, employment, or student status,
+he must inform at least one jurisdiction in which he resides, is an employee, or is a
+student of such change. The defendant has been advised, and understands, that failure to
+comply with these obligations subjects him to prosecution for failure to register under
+federal law, 18 U.S.C. § 2250, which is punishable by a fine or imprisonment, or both.
+The defendant further understands and acknowledges that, in addition to
+any sentence imposed under paragraph 2 of this Agreement, a special assessment in the
+amount of $100 will be imposed on the defendant, which must be paid at or before the
+time of sentencing.
+The defendant understands that the Court will order that he must pay full
+restitution to all victims of the offense to which he is pleading guilty. The defendant
+understands that the amount of restitution owed to each victim will be determined at or
+before sentencing.
+This Plea Agreement is governed, in part, by Federal Rule of Criminal
+Procedure 11(c)(1)(C). The parties have agreed that the defendant's sentence imposed by
+the Court shall be two (2) years' imprisonment to be followed by three (3) years'
+supervised release, and a $250,000 fine. If the Court accepts and imposes the agreed
+2
+
+
+term of imprisonment, the defendant may not withdraw this plea. If the Court rejects the
+agreement, and the defendant elects to withdraw his plea, the United States may
+prosecute the defendant for any and all Federal crimes that he has committed related to
+this case and may seek any sentence for such crimes up to and including the statutory
+maximums.
+The United States reserves the right to inform the Court and the probation
+office of all facts pertinent to the sentencing process, including all relevant information
+concerning the offenses committed, whether charged or not, as well as concerning the
+defendant and the defendant's background, and to respond to any questions from the
+Court and the Probation Office and to any misstatements of fact or law.
+8.
+The defendant understands and agrees that federal law mandates that he be
+taken into federal custody upon the entry of his guilty plea.
+WAIVER OF RIGHT TO APPEAL AND COLLATERALLY
+ATTACK THE SENTENCE. The defendant is aware that Title 18, United States Code,
+Section 3742 affords the defendant the right to appeal the sentence imposed in this case.
+Acknowledging this, in exchange for the undertakings made by the United States in this
+plea agreement, the defendant hereby waives all rights conferred by Section 3742 to
+appeal any sentence imposed, including any restitution order, or to appeal the manner in
+which the sentence was imposed, unless the sentence exceeds the maximum permitted by
+statute or is the result of an upward departure or upward variance from the guideline
+range that the Court establishes at sentencing. The defendant further voluntarily and
+expressly waives, to the maximum extent permitted by federal law, the right to
+collaterally attack his sentence in any postconviction proceeding, including a motion on any ground brought under 28 U.S.C. §
+2254, 28 U.S.C. § 2255, 18 U.S.C. § 3572, or 18 U.S.C. § 3771. The defendant further
+3
+
+
+understands that nothing in this agreement shall affect the government's right and/or duty
+to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the
+United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant
+shall be released from the above waiver of appellate rights. By signing this agreement,
+the defendant acknowledges that he has discussed the appeal waiver set forth in this
+If the defendant fails in any way to fulfill each one of his obligations under
+this Plea Agreement, the United States, and only the United States, may elect to be
+released from its commitments under this Plea Agreement. If the United States elects to
+void the Plea Agreement because of a breach by the defendant, then the United States
+agrees not to use the defendant's guilty plea against him. However, the United States
+may prosecute the defendant for any and all Federal crimes that he has committed related
+to this case and may seek any sentence for such crimes up to and including the statutory
+maximums. The defendant expressly waives any statute of limitations defense and any
+constitutional or statutory speedy trial defense to such a prosecution, except to the extent
+that such a defense exists as of the date he signs this Plea Agreement. Finally, the
+defendant understands that his violation of the terms of this Plea Agreement would not
+11. This is the entire agreement and understanding between the United States
+There are no other agreements, promises, representations, or
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+4
+
+
+5
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/9f0eb34b7878d57a070d539fe70d0dce7643f2e6f19f4eabecf3f96445da1d3c.receipt.json b/vision-fixhub/ds9-unparsed-05/9f0eb34b7878d57a070d539fe70d0dce7643f2e6f19f4eabecf3f96445da1d3c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1ad4d936778f8ad9fb3949b210b8128b1222066e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9f0eb34b7878d57a070d539fe70d0dce7643f2e6f19f4eabecf3f96445da1d3c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -4077,
+  "dataset": "marble-joined",
+  "doc_id": "9f0eb34b7878d57a070d539fe70d0dce7643f2e6f19f4eabecf3f96445da1d3c",
+  "engine": "marble-apple-vision",
+  "event_count": 105,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "81cfef68bef5d35e84bd9ae60b83d240092628103ad50a5d444de328619d1172",
+  "output_sha256": "b94d76d11fb12f716f37dd5446d99f025368dddd834fe186134ac39321b60ba5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/9f2c2f266b3328c72b80c872ecfc894ecb7fe461cbb801efec13d5ec9f861b89.md b/vision-fixhub/ds9-unparsed-05/9f2c2f266b3328c72b80c872ecfc894ecb7fe461cbb801efec13d5ec9f861b89.md
new file mode 100644
index 0000000000000000000000000000000000000000..03d397dcd518b4cb91498afd170e3fb6356b0bfe
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9f2c2f266b3328c72b80c872ecfc894ecb7fe461cbb801efec13d5ec9f861b89.md
@@ -0,0 +1,92 @@
+From:
+Sent:
+To:
+Cc:
+Subject:
+(USAFLS)
+(USAFLS)
+Wednesday, September 17, 2008 12:00 PM
+Barry Krischer
+(USAFLS); |
+(USAFLS)
+Your inquiry regarding the Epstein case
+(USAFLS): |
+criminal case, to contact you regarding a possible suit by the Shiny Sheet.
+On another note, I also will be informing them that I believe that they still have not filed the complete
+agreement with the Court, as required by the Judge at the hearing.
+Thank you very much for reaching out to us when you received this request, and if you need any help from us,
+please let us know.
+Assistant U.S. Attorney
+52
+
+
+(USAFLS)
+From:
+Sent:
+To:
+Cc:
+Subject:
+Senior, Robert (USAFLS)
+Wednesday, September 17, 2008 11:25 AM
+(USAELS): Acosta, Alex (USAFLS); [
+Dexter (USAFI S);
+I (USAFLS)
+(USAFLS)
+RE: State |. Jeffrey Epstein
+(USAFLS); Lee,
+Given the non-disclosure agreement, aren't we left with telling the SAO that we have agreed to not disclose so it
+wouldn't be proper for us to now agree that unsealing is appropriate. Ultimately, it's the SAO's call because they will get
+the Florida Public Records Act request and they were not a signatory to the agreement. We should also notify defense
+counsel so that they can take whatever actions they believe are appropriate. Wait till others have had a chance to
+From:
+(USAFLS)
+Sent: Wednesday, September 17. 2008 10:50 AM
+To: Acosta, Alex (USAFLS);
+(USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS);
+(USAFLS)
+(USAFLS)
+Subject: FW: State l Sefrey Epstein
+Will it never end? Barry Krisher sent the e-mail below to Rolando this morning. How would you like to handle
+this issue?
+A. Marie Villafaña
+Assistant U.S. Attorney
+(USAFLS)
+Sent Wethesday, Sentember 17, 2008 10:48 AM
+1. (USAFLS)
+Subject: FW: State . Jeffrey Epstein
+From: Barry Krischer [mailto:Bkrische@sa15.state.fl.us]
+Sent: Wednesday, September 17, 2008 10:46 AM
+To:
+(USAFLS)
+Subject: FW: State |. Jeffrey Epstein
+Please advise how you would like us to proceed. The agreement referred to is the Federal Non-Prosecution agreement
+sealed in the file by the judge at the time of the Epstein plea.
+From: Lanna Belohlavek
+Sent: Tuesday, September 16, 2008 4:21 PM
+To: Barry Krischer
+Subject: FW: State |. Jeffrey Epstein
+53
+
+
+How to proceed? Lanna
+From: Bryce Albu [mailto:bryce@reederandreeder.com]
+Sent: Tuesday, September 16, 2008 3:52 PM
+To: Lanna Belohlavek
+Cc: Martin Reeder
+Subject: State |. Jeffrey Epstein
+Ms. Belohlavek,
+We represent The Palm Beach Daily News. The newspaper recently discovered that a non-prosecution agreement (and
+an addendum thereto) was filed under seal pursuant to an agreed order entered in the above-referenced case. Because
+the records are sealed, we cannot assess the propriety of the decision to seal them or even whether the newspaper is
+interested in the information contained therein. I was hoping you would discuss with me the nature of the agreement and
+the basis for sealing it so that we can advise our client on whether it should pursue an order unsealing the agreement.
+Please call me at your earliest convenience.
+Very truly yours,
+C. Bryce Albu
+Reeder & Reeder P.A
+250 S. Central Blvd., Suite 200
+Jupiter, FL 33458
+Direct Dial: (561) 575-9721
+Facsimile: (561) 575-9765
+bryce@reederandreeder.com
+54
diff --git a/vision-fixhub/ds9-unparsed-05/9f2c2f266b3328c72b80c872ecfc894ecb7fe461cbb801efec13d5ec9f861b89.receipt.json b/vision-fixhub/ds9-unparsed-05/9f2c2f266b3328c72b80c872ecfc894ecb7fe461cbb801efec13d5ec9f861b89.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..508fab099cec01c4d0085b838efe32adeda948c1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9f2c2f266b3328c72b80c872ecfc894ecb7fe461cbb801efec13d5ec9f861b89.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "9f2c2f266b3328c72b80c872ecfc894ecb7fe461cbb801efec13d5ec9f861b89",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "6b242dbdd3123559e2ea83671c8ca6e9e7ee302d51106cd91c140a1c8b8e9d26",
+  "output_sha256": "2dd9e16c2c60e05eca74f0c8ed81d91b178e5e96b7515350a59504b6c57266cb",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/9f39de56847ec8a16c4649e3c1cfb14186787eca67bf93f060930a48ad23eb2d.md b/vision-fixhub/ds9-unparsed-05/9f39de56847ec8a16c4649e3c1cfb14186787eca67bf93f060930a48ad23eb2d.md
new file mode 100644
index 0000000000000000000000000000000000000000..db1af230a07b3e6a3918a559688ed8cd9c628062
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9f39de56847ec8a16c4649e3c1cfb14186787eca67bf93f060930a48ad23eb2d.md
@@ -0,0 +1,249 @@
+Memorandum
+Subject
+Operation
+"Leap Year"
+USAO
+FC/FLS/
+Date
+September 11, 2006
+To
+AUSA, Criminal Division
+From
+AUSA, Asset Forfeiture
+I can be reached at
+
+
+From:
+Sent:
+To:
+Subject:
+Wednesday, September 06, 2006 6:10 PM
+• (USAFLS)
+FW: Jeffrey Epstein
+I am working with a on this case. Please open for me. Thanks. Toni
+(USAFLS)
+Nednesday, September 06, 2006 5:43 PN
+m.... (USAFLS)
+RE: Jeffrey Epstein
+-- It is captioned Operation Leap Year. The USAO number is
+From:
+Sent:
+To:
+Subject:
+Hi
+Thanks.
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach. Florida
+Phone
+From:
+A (USAFLS)
+Sent:
+wednesday september 06, 2006 5:10 PM
+Subject:
+USAFLS)
+Jeffrey Epstein
+, when you get a chance, could you send me the USAO # for the Jeffrey Epstein case. I need to open the case so !
+can work on the forfeitures. Thanks. Toni
+
+
+INITIA.
+IN/DISPOSITION - CRIMINAL FO.
+EITURE
+OPEN ADMIN RECORD
+_CLOSE PROPERTY RECORD CHANGE IN STATUS _
+USAO NO.
+2006RO1181
+AGENCY
+EBT
+COURT NO.
+A/F AUSA
+DATE:
+9/1/06
+*CASE TYPE (select one)
+AFAB - AF Airport Bulk Cash
+AFF - Asset Forfeiture Fraud
+AFS - Asset Forfeiture Structuring
+DISPOSITION CODES
+DM - DISMISSED
+GT - GUILTY
+NG - NOT GUILTY
+AGENCY CASE NO.
+CASE NAME:
+AUSA SIGNATURE
+Operation "Lean Vear"
+ASSET DESCRIPTION & CATS #
+AFAD - AF Airport Drug Related
+AFDR - Asset Forfeiture Drug Related
+AFG - Asset Forfeiture Gun
+AFML - Asset Forfeiture Money Laundering
+AFBM - AF Black Market Peso Exchange
+AFO - Asset Forfeiture Other
+DISPOSITION REASON CODES
+PFAH - FINAL ORDER OF FORFEITURE FOR GOV'T
+PNFA - FINAL ORDER IN FAVOR OF CLAIMANT
+FOFS - FINAL ORDER OF FORFEITURE (ASSET SUBSTITUTED)
+GWDD - DISMISSED BY GOVERNMENT
+******CASE CLOSING INFORMATION******
+APPR.
+VALUE
+DISP.
+DATE
+DISP.
+CODE
+DISP.
+REASON
+1.
+2.
+4.
+5.
+6.
+7.
+8.
+
+
+GCO 1|
+Case Name: Operation"T eap Year"
+Matter #:
+USAO#:
+18 U.S.C.§ 208 is a criminal conflict of interest statute that prohibits me from
+participating personally and substantially in an official capacity in any particular
+matter in which I have a financial interest or in which certain persons or
+organizations whose interests are imputed to me have a financial interest if the
+particular matter will have a direct and predictable effect on that interest. This
+statute is in addition to any state bar professional conduct rules that may apply.
+I understand that personal and substantial participation may
+encompass activities ranging from merely advising on strategy to
+signing pleadings or trying a case.
+I understand that a particular matter includes both specific party
+matters, as well as more general matters that focus on an identifiable
+group (e.g., a policy determination that more resources will be spent
+pursuing institutions] individuals committing health care fraud).
+I understand that financial interest is the potential for gain or loss as a
+result of governmental action and that such interests typically arise
+hrough ownership of stocks or sectored mutual funds, outside
+activities/employment, and spousal employment.
+I understand that those interests imputed to me include those of my
+spouse, minor children, general partners, any organization in which I
+serve as officer, director, trustee, general partner or employee, and any
+person or organization with whom I am negotiating for or have any
+arrangement concerning prospective employment.
+I understand that a direct and predictable effect occurs when there is a
+close causal relationship between the matter and my financial interest
+or the financial interest held by someone whose interests are imputed to
+me. The effect may be positive or negative. The magnitude of the
+gain or loss is immaterial.
+I certify that, to the best of my knowledge, this matter will not directly and
+predictably affect my financial interests or those interests imputed to me and my
+participation in this matter will not violate 18 U.S.C.$208.
+date 9/11/06
+
+5 C.F.R.§2635.502, the impartiality rules, prohibits me from participating in a
+specific party matter that I know is likely to affect the financial interests of a
+member of my household or in which someone with whom I have a covered
+relationship is or represents a party.
+I understand that I have a covered relationship with the following:
+anyone with whom I have or seek a business, contractual, or financial
+relationship;
+a relative with whom I have a close personal relationship;
+anyone for whom my spouse, parent or dependent child serves or seeks to serve
+as an officer, director, trustee, general partner, agent, attorney, consultant,
+contractor, or employee;
+anyone for whom I worked in the last year as an officer, director, trustee,
+general partner, agent, attorney, consultant, contractor, or employee; and
+an organization in which I am an active member.
+I certify that, to the best of my knowledge, this matter is not likely to affect the
+financial interest of a member of my household, and no one with whom I have a
+covered relationship is or represents a party in this matter. Therefore, my
+triolato 5 CT D S2625,502
+date 9 / 1/06
+Antonia J. Barnes
+(Printed Name)
+If you cannot certify to the above statement, do not take any action on the
+case and immediately contact vour supervisor or your Ethics Advisor.
+I acknowledge my ongoing responsibility to be aware of the potential for
+conflict or the appearance of a conflict and to disclose any financial or personal
+interest as described above that would become involved in or be affected by the
+matter as soon as it is known to me.
+date q/11/06
+Signed)
+Antonia J. Barnes
+Printed Name) |
+If you cannot certify to the above statement, do not take any action on the
+case and immediately contact your supervisor or your Ethics Advisor.
+Antonia J. Barnes
+(Printed Name)
+
+
+Memorandum
+Subject
+Completed Criminal Forfeiture Matter
+U.S. v. Operation "Leap Year""
+CCDETF No. FC/FLS/
+Date
+March 18, 2009
+Assistant United States Attorney
+Paralegal Specialist
+Asset Forfeiture Division
+Attached is the completed forfeiture file with regards to the above-referenced criminal matter.
+Please maintain this forfeiture file with your criminal case file.
+Should you have any questions, please feel free to call me at ‹
+attention to this matter.
+Thank you for your
+Attachment
+
+
+INITI
+'ON/DISPOSITION - CRIMINAL F
+FEITURE
+OPEN ADMIN RECORD
+USAO NO.
+2006R01181
+X CLOSE PROPERTY RECORD —CHANGE IN STATUS _
+AGENCY
+F.B.I.
+COURT NO.
+AGENCY CASE NO.
+3IE-MM-108062
+A/F AUSA
+CASE NAME:
+DATE:
+3/3/09
+*CASE TYPE (select one)
+AFAB - AF Airport Bulk Cash
+AFF - Asset Forfeiture Fraud
+AFS - Asset Forfeiture Structuring
+AUSA SIGNATURE
+AFHC - Asset Forfeiture Health Care Fraud
+AFAD - AF Airport Drug Related
+AFDR - Asset Forfeiture Drug Related
+AFG - Asset Forfeiture Gun
+AFML - Asset Forfeiture Money Laundering
+AFBM - AF Black Market Peso Exchange AFO - Asset Forfeiture Other
+DISPOSITION CODES
+DM - DISMISSED
+GT - GUILTY
+NG - NOT GUILTY
+DISPOSITION REASON CODES
+PFAH - FINAL ORDER OF FORFEITURE FOR GOV'T
+JTRD - JURY TRIAL VERDICT
+PNFA - FINAL ORDER IN FAVOR OF CLAIMANT
+FOFS - FINAL ORDER OF FORFEITURE (ASSET SUBSTITUTED)
+GWDD - DISMISSED BY GOVERNMENT
+ASSET DESCRIPTION & CATS #
+******CASE CLOSING INFORMATION******
+APPR.
+VALUE
+DISP.
+DATE
+DISP.
+CODE/
+REASON
+CATS #
+1. No assets
+2.
+4.
+5.
+6.
+7.
+8.
diff --git a/vision-fixhub/ds9-unparsed-05/9f39de56847ec8a16c4649e3c1cfb14186787eca67bf93f060930a48ad23eb2d.receipt.json b/vision-fixhub/ds9-unparsed-05/9f39de56847ec8a16c4649e3c1cfb14186787eca67bf93f060930a48ad23eb2d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..eb4e55f4dceeff13876653c95b7e7f2587b1675f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9f39de56847ec8a16c4649e3c1cfb14186787eca67bf93f060930a48ad23eb2d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -83,
+  "dataset": "marble-joined",
+  "doc_id": "9f39de56847ec8a16c4649e3c1cfb14186787eca67bf93f060930a48ad23eb2d",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "07222bc68d9366e9767f7bb5cdab087acf03359f89a3c915db7a5a963c9e9334",
+  "output_sha256": "dd80cdefcc3f97bf922ce5a661968ccac4fddd25cd8d57ebfafdd2245987d034",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/9f6f5d3fe31773e5c58a9b820f71f27428e225213f962b742b53d4cfbde62464.md b/vision-fixhub/ds9-unparsed-05/9f6f5d3fe31773e5c58a9b820f71f27428e225213f962b742b53d4cfbde62464.md
new file mode 100644
index 0000000000000000000000000000000000000000..ac1e7bb1725d4b360c9dbf1919e10aafe36ce70b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9f6f5d3fe31773e5c58a9b820f71f27428e225213f962b742b53d4cfbde62464.md
@@ -0,0 +1,1381 @@
+11/24/08 Letter to Black re breach
+
+
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 S. Australian Ave, Ste 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+November 24, 2008
+•
+DELIVERY BY ELECTRONIC MAIL
+Koy Black, Esq.
+Black Srebnick Kornspan & Stumpf P.A.
+201 S. Biscayne Blvd, Suite 1300
+Miami, FL 33131
+Re: Jeffrey Epstein
+Dear Roy:
+On Thursday I learned that Mr. Epstein applied for and was admitted to the Palm
+Beach County Sheriff's Office's work release program and that he has been on work release
+for the past few weeks. For the following reasons, the Office believes that Mr. Epstein's
+application to and participation in the work release program is a material breach of the Non-
+Prosecution Agreement. Accordingly, the United States demands that Mr. Epstein withdraw
+his application to participate in the program and complete his eighteen-month term of
+imprisonment in accordance with the Non-Prosecution Agreement.
+The Non-Prosecution Agreement provides that Epstein "shall be sentenced to
+consecutive terms of twelve (12) months and six (6) months in county jail for all charges,
+without any opportunity for withholding adjudication or sentencing, and probation or
+community control in lieu of imprisonment." I have more than a dozen e-mails between
+myself and Jay Lefkowitz discussing the U.S. Attorney's insistence on eighteen months of
+incarceration. You will recall that at one meeting you and Ms. Sanchez raised the idea of Mr.
+Epstein hiring Sheriff's Deputies to guard him as equivalent to imprisonment. Mr. Acosta
+specifically rejected that suggestion: It is our understanding from the Sheriff's Office that
+Mr. Epstein is paying off-duty Sheriff's Deputies to guard him while he "works" at Mr.
+
+
+
+Goldberger's office building each day.
+As you remember, shortly before Mr. Epstein's change of plea, Mr. Goldberger sent
+me a copy of the proposed plea agreement with the state. On June 27, 2008, I sent a letter
+containing the following language to you and Mr. Goldberger:
+The U.S. Attorney's Office hereby provides Notice that the proposed sentencing
+provision does not comply with the terms of the Non-Prosecution Agreement.
+The second sentencing paragraph of the proposed plea agreement reads:
+On 08CF009381 AMB, the Defendant is sentenced to 18 months Community Control
+1 (one). As a special condition of this Community Control, the Defendant must serve
+the first 6 months in the Palm Beach County Detention Facility ...
+The Non-Prosecution Agreement specifically provides:
+Epstein shall be sentenced to consecutive terms of twelve (12) months and six (6)
+months in county jail for all charges, ... without probation or community control in
+lieu of imprisonment.
+Thus, the proposed plea agreement with the State Attorney's Office does not comply
+with the terms of the Non-Prosecution Agreement. To comply with the Agreement,
+Mr. Epstein must make a binding recommendation of eighteen months imprisonment,
+which means confinement twenty-four hours a day at the County Jail, and the judge
+must accept that recommendation. Community control must follow that term of
+incarceration.
+(Emphasis in original.)
+As I specified in that letter, the Non-Prosecution Agreement calls for "confinement
+twenty-four hours a day." In response to that letter, Mr. Goldberger agreed that he would
+revise the state plea agreement to include the word "imprisonment" to make clear that Mr.
+Epstein would be incarcerated for the full eighteen months and would change the language
+of the state agreement to match the language of the federal agreement. Mr. Goldberger and
+I also discussed the situation and he made clear that Mr. Epstein would not be asking for or
+receiving work release and would remain in jail "around the clock."
+In early August, Karen Atkinson and I raised the same issue with you when we heard
+
+
+
+that Mr. Epstein was considering applying for work release. On August 6, 2008, Ms.
+Atkinson and I had a conference call with you wherein you again stated that Mr. Epstein
+would not apply for or receive work release and would spend his eighteen months
+incarcerated twenty-four hours a day at the Palm Beach County Stockade.
+In preparation for this letter, I obtained a certified copy of Mr. Epstein's state court
+file. On June 30, 2008, on the procurement of minors charge, Judge Pucillo entered the
+following sentence:
+The defendant is hereby committed to the custody of the Sheriff of Palm Beach
+County, Florida for a term of 6 mos. It is further ordered that the Defendant
+shall be allowed a total of 1 days [sic] as credit for time incarcerated prior to
+imposition of this sentence. It is further ordered that the composite term of all
+sentences imposed for the counts specified in the order shall run consecutive
+to the following: Specific sentences: 2006CF9454AXX.
+... the following provisions apply to the sentence imposed: ... Followed by
+a period of 12 mos on community control 1 under the supervision of the
+Department of Corrections ....
+As I learned on Friday when I received the state court file, you neglected to inform
+our Office that, on July 21, 2008, Judge MoSorley modified the judgment nune pro tune to
+an "Order of Community Control I." This same language was the basis for the objection in
+my letter of June 26, 2008 and directly contradicts the language of the Non-Prosecution
+Agreement. I also note that, on the state plea agreement, Mr. Goldberger did not insert the
+word "imprisonment" as agreed prior to the change of plea, instead the words "jail sentence"
+are included.
+The Office's Agreement not to prosecute Mr. Epstein was based upon its
+determination that eighteen months' incarceration (i.e., confinement twenty-four hours a day)
+was sufficient to satisfy the federal interest in Mr. Epstein's crimes. Accordingly, the U.S.
+Attorney's Office hereby gives notice that Mr. Epstein has violated the Non-Prosecution
+Agreement by failing to remain incarcerated twenty-four hours a day for the eighteen-month
+
+
+
+term of imprisonment. The United States will exercise any and all rights it has under the
+Non-Prosecution Agreement unless Mr. Epstein immediately ceases and desists from his
+breach of this Agreement.
+By:
+Sincerely,
+R. Alexander Acosta
+United States Attorney
+Alail illaban
+A. Marie Villafaña
+Assistant United States Attorney
+CC:
+Karen Atkinson, Chief, Northern Division
+
+
+IN RE:
+INVESTIGATION OF
+NON-PROSECUTION AGREEMENT
+IT APPEARING that the State Attorney's Office has charged Epstein by indictment
+with solicitation of prostitution, in violation of Florida Statutes Section 796.07;
+IT APPEARING that the United States Attorney's Office and the Federal Bureau of
+Investigation have conducted their own investigation into Epstein's background and any
+offenses that may have been committed by Epstein against the United States from in or
+around 2001 through in or around September 2007, including:
+(1) knowingly and willfully conspiring with others known and unknown to
+commit an offense against the United States, that is, to use a facility or means
+of interstate or foreign commerce to knowingly persuade, induce, or entice
+ninor females to engage in prostitution, in violation of Title 18, United States
+Code, Section 2422(b); all in violation of Title 18, United States Code, Section
+371;
+(2)
+knowingly and willfully conspiring with others known and unknown to travel
+in interstate commerce for the purpose of engaging in illicit sexual conduct, as
+defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18,
+United States Code, Section 2423(b); all in violation of Title 18, United States
+Code, Section 2423(e);
+(3) using a facility or means of interstate or foreign commerce to knowingly
+, or entice minor females to engage in prostitution; in
+violation of Title 18, United States Code, Sections 2422(b) and 2;
+(4)
+
+
+
+of Title 18, United States Code, Section 2423(b); and
+(5)
+knowingly, in and affecting interstate and foreign commerce, recruiting,
+enticing, and obtaining by any means a person, knowing that the person had
+not attained the age of 18 years and would be caused to engage in a
+commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title
+18, United States Code, Sections 1591(a)(1) and 2; and
+IT APPEARING that Epstein seeks to resolve globally his state and federal criminal
+liability and Epstein understands and acknowledges that, in exchange for the benefits
+provided by this agreement, he agrees to comply with its terms, including undertaking certain
+actions with the State Attorney's Office;
+IT APPEARING, after an investigation of the offenses and Epstein's background by
+both State and Federal law enforcement agencies, and after due consultation with the State
+Attorney's Office, that the interests of the United States, the State of Florida, and the
+Defendant will be served by the following procedure;
+THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for
+the Southern District of Florida, prosecution in this District for these offenses shall be
+deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the
+following conditions and the requirements of this Agreement set forth below.
+It the United States Attorney should determine, based on reliable evidence, that,
+during the period of the Agreement, Epstein willfully violated any of the conditions of this
+Agreement, then the United States Attorney may, within ninety (90) days following the
+expiration of the term of home confinement discussed below, provide Epstein with timely
+notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its
+prosecution on any offense within sixty (60) days' of giving notice of the violation. Any
+notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the
+United States learning of facts which may provide a basis for a determination of a breach of
+the Agreement.
+After timely fulfilling all the terms and conditions of the Agreement, no prosecution
+
+ETA00192631
+
+Terms of the Agreement:
+3.
+4.
+5.
+6.
+Epstein shall plead guilty (not nolo contendere) to the Indictment a
+currently pending against him in the 15th Judicial Circuit in and fo
+Palm Beach County (Case No. 2006-cf-009495AXXXMB) charging
+one (1) count of solicitation of prostitution, in violation of Fl. Stat. §
+796.07. In addition, Epstein shall plead guilty to an Information filed
+y the State Attorey's Office charging Epstein with an oftense th
+quires him to register as a sex offender, that is, the solicitation of
+minors to engage in prostitution, in violation of Florida Statutes Section
+796.03;
+Epstein shall make a binding recommendation that the Court impose a
+thirty (30) month sentence to be divided as follows:
+(a)
+Epstein shall be sentenced to consecutive terms of twelve (12)
+months and six (6) months in county jail for all charges, without
+ny opportunity for withholding adjudication or sentencing, an
+ithout probation or community control in lieu
+(b)
+Epstein shall be sentenced to a term of twelve (12) months of
+community control consecutive to his two terms in county jail
+as described in Term 2(a), supra.
+This agreement is contingent upon a Judge of the 15th Judicial Circuit
+ccepting and executing the sentence agreed upon between the Stat
+ttorney's Office and Epstein, the details of which are set forth in thi
+agreement.
+The terms contained in paragraphs | and 2, supra, do not foreclose
+Epstein and the State Attorney's Office from agreeing to recommend
+any additional charge(s) or any additional terms) of probation and/or
+incarceration.
+Epstein shall waive all challenges to the Information filed by the State
+Attorney's Office and shall waive the right to appeal his conviction and
+sentence, except a sentence that exceeds what is set forth in paragraph
+(2), supra.
+Epstein shall provide to the U.S. Attorney's Office copies of all
+
+
+
+8.
+9.
+10.
+11.
+proposed agreements with the State Attorney's Office prior to entering
+into those agreements.
+The United States shall provide Epstein's attorneys with a list of
+individuals whom it has identified as victims, as defined in 18 U.S.C.
+§ 2255, after Epstein has signed this agreement and been sentenced.
+Upon the execution of this agreement, the United States, in consultation
+with and subject to the good faith approval of Epstein's counsel, shall
+select an attorney representative for these persons, who shall be paid for
+by Epstein. Epstein's counsel may contact the identified individuals
+through that representative.
+If any of the individuals referred to in paragraph (7), supra, elects to
+Epstein's signature on this agreement also is not to be construed as an
+admission of civil or criminal liability or a waiver of any jurisdictional
+or other defense as to any person whose name does not appear on the
+list provided by the United States.
+Except as to those individuals who elect to proceed exclusively under
+18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's
+Epstein shall use his best efforts to enter his guilty plea and be
+
+
+
+12.
+sentenced not later than October 26, 2007. The United States has no
+bjection to Epstein self-reporting to begin serving his sentence no
+ater than January 4, 2008
+Epstein agrees that he will not be afforded any benefits with respect to
+gain time, other than the rights, opportunities, and benefits as any other
+inmate, including but not limited to, eligibility for gain time credit
+ased on standard rules and regulations that apply in the State of
+Florida. At the United States' request, Epstein agrees to provide ar
+accounting of the gain time he earned during his period of
+13.
+The parties anticipate that this agreement will not be made part of any
+public record. If the United States receives a Freedom of Information
+Act request or any compulsory process commanding the disclosure of
+the agreement, it will provide notice to Epstein before making that
+disclosure.
+Epstein understands that the United States Attorney has no authority to require the
+State Attorney's Office to abide by any terms of this agreement. Epstein understands that
+it is his obligation to undertake discussions with the State Attorney's Office and to use his
+best efforts to ensure compliance with these procedures, which compliance will be necessary
+to satisfy the United States' interest. Epstein also understands that it is his obligation to use
+his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding
+recommendation regarding the sentence to be imposed, and understands that the failure to
+do so will be a breach of the agreement.
+In consideration of Epstein's agreement to plead guilty and to provide compensation
+in the manner described above, if Epstein successfully fulfills all of the terms and conditions
+of this agreement, the United States also agrees that it will not institute any criminal charges
+against any potential co-conspirators of Enstein. including but not limited to
+Adriana Ross, Lesley Groff, or
+1. Further, upon execution of this
+reement and a plea agreement With the State Attorney's Office, the federal Grand Ju
+vestigation will be suspended, and all pending federal Grand Jury subpoenas will be he
+in abeyance unless and until the defendant violates any term of this agreement. The
+defendant likewise agrees to withdraw his pending motion to intervene and to quash certain.
+grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence
+requested by or directly related to the grand jury subpoenas that have been issued, an
+ncluding certain computer equipment, inviolate until all of the terms of this agreement hav
+been satisfied. Upon the successful completion of the terms of this agreement, all
+outstanding grand jury subpoenas shall be deemed withdrawn.
+
+
+
+By signing this agreement, Epstein asserts and certifies that each of these terms is
+material to this agreement and is supported by independent consideration and that a breach
+of any one of these conditions allows the United States to elect to terminate the agreement
+and to investigate and prosecute Epstein and any other individual or entity for any and all
+federal offenses.
+By signing this agreement, Epstein asserts and certifies that he is aware of the fact that
+he sixth Amendment to the Constitution of the United States provides that in all crimina
+rosecutions the accused shall enjoy the right to a speedy and public trial. Epstein furthe
+is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court
+may dismiss an indictment, information, or complaint for unnecessary delay in presenting
+a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein
+hereby requests that the United States Attorney for the Southern District of Florida defer such
+prosecution. Epstein agrees and consents that any delay from the date of this Agreement to
+the date of initiation of prosecution, as provided for in the terms expressed herein, shall be
+deemed to be a necessary delay at his own request, and he hereby waives any defense to such
+prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of
+the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the
+United States to a speedy trial or to bar the prosecution by reason of the running of the statute
+of limitations for a period of months equal to the period between the signing of this
+agreement and the breach of this agreement as to those offenses that were the subject of the
+grand jury's investigation. Epstein further asserts and certifies that he understands that the
+Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all
+felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees
+and consents that, if a prosecution against him is instituted for any offense that was the
+subject of the grand jury's investigation, it may be by way of an Information signed and filed
+by the United States Attorney, and hereby waives his right to be indicted by a grand jury as
+to any such offense.
+111
+11/
+
+
+
+By signing this agreement, Epstein asserts and certifies that the above has been read
+and explained to him. Epstein hereby states that he understands the conditions of this Non-
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Deal terrot
+By:
+A. MARIE VILLAFAÑA
+ASSISTANT U.S. ATTORNEY
+JEPPREY EPST
+GERALD LEFCOURT, ESQ.
+COUNSEL TO JEFFREY EPSTEIN
+
+
+
+By signing this agreement, Epstein asserts and certifies that the above has been read
+and explained to him. Epstein hereby states that he understands the conditions of this Non-
+Prosecution Agreement and agrees to comply with them
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+A. MARIE VILLAFANA
+ASSISTANT U.S. ATTORNEY
+Datod: 9/24/07
+Sell Fount
+COUNSEL TO JEFFREY EPSTEIN
+Pago 7 of 7
+
+
+By signing this agreement, Epstein asserts and certifies that the above has been read
+and explained to him. Epstein hereby states that he understands the conditions of this Non-
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+À. MARIE VILLAFANA
+ASSISTANT U.S. ATTORNEY
+GERALD LEFCOURT, ESQ.
+COUNSEL TO JEFFREY EPSTEIN
+Dated: 9-34-07
+LILI
+Y ANN SAN
+IGHEZ, ESQ.
+
+
+
+IN RE:
+INVESTIGATION OF
+ADDENDUM TO THE NON-PROSECUTION AGREEMENT
+IT APPEARING that the parties seck to clarify certain provisions of page 4, paragraph 7
+of the Non-Prosecution Agreement (hereinafter "paragraph 7"'), that agreement is modified as
+follows:
+7A.
+The United States has the right to assign to an independent third-party the responsibility
+for consulting with and, subject to the good faith approval of Epstein's counsel, selecting
+the attorney representative for the individuals identified under the Agreement. If the
+United States elects to assign this responsibility to an independent third-party, both the
+United States and Epstein retain the right to make good faith objections to the attorney
+representative suggested by the independent third-party prior to the final designation of
+the attorney representative.
+7B.
+The parties will jointly prepare a short written submission to the independent third-party
+regarding the role of the attorney representative and regarding Epstein's Agreement to
+pay such attorney representative his or her regular customary hourly rate for representing
+such victims subject to the provisions of paragraph C, infra.
+7C.
+Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision, however, shall not
+obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus,
+if after consideration of potential settlements, an attorney representative elects to file a
+contested lawsuit pursuant to 18 U.S.C, s 2255 or elects to pursue any other contested
+remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay reasonable
+attorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney
+representative, shall cease.
+
+
+Dated: 10-29-07
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+A STANTU ATTORNEY
+GERALD LEFCOURT, ESQ.
+COUNSEL TO JEFFREY EPSTEIN
+LILLY ANN SANCHEZ, ES
+ATTORNEY FOR JEFFREY EPSTEIN •
+
+
+By signing this Addendum, Epstein asserts and certifies that the above has been read and
+explained to him. Epstein herby states that he understands the clarifications to the Non-
+R. ALEXANDER AÇOSTA
+UNITED STATES ATTORNEY
+By:
+À, MARIE VILLAFAÑA
+ASSISTANT U.S. ATTORNEY
+Data 0/29/07
+DO Falcons
+BRALD LEFCOURT, ESQ
+COUNSEL TO JEFFREY EPSTEIN
+
+
+Sincerely,
+P. MA
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+=
+
+
+With this in mind, I have considered defense counsel arguments regarding the Section 2255
+portions of the Agreement. As I previously observed, our intent has been to place the victims in the
+same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.
+From our meeting, it appears that the defense agrees that this was the intent. During the course of
+negotiations that intent was reduced to writing in Paragraphs 7 and 8, which as I wrote previously,
+appear far from simple to understand. I would thus propose that we solve our disagreements over
+interpretations by saying precisely what we mean, in a simple fashion. I would replace Paragraphs 7
+and 8 with the following language:
+"Any person, who while a minor, was a victim of a violation of an offense enumerated in
+Title 18, United States Code, Section 2255, will have the same rights to proceed under
+Section 2255 as she would have had, if Mr. Epstein been tried federally and convicted of an
+enumerated offense. For purposes of implementing this paragraph, the United States shall
+provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority
+interpreting this provision, including any authority determining which evidentiary burdens if
+any a plaintiff must meet, shall consider that it is the intent of the parties to place these
+identified victims in the same position as they would have been had Mr. Epstein been
+convicted at trial. No more; no less."
+
+
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+99 N.E. 4 Street
+Miami, FL 33/32
+(305 50-0148 Tacione
+December 19, 2007
+DELIVERY BY FACSIMILE
+Lilly Ann Sanchez
+Fowler White Burnett, PA
+1395 Brickell Ave, 14" Floor
+Miami, FL 33131
+Re:
+Jeffrey Epstein
+Dear Ms. Sanchez:
+I write to follow up on the December 14"' meeting between defense counsel and the Epstein
+prosecutors, as well as our First Assistant, the Miami FBI Special Agent in Charge and myself.
+2 Section 2255 provides that: "[a)ny person who, while a minor, was a victim of a violation of [enumerated sections
+f Title 18] and who suffers personal injury as a result of such violation... may sue in any appropriate United State
+istrict Court and shall recover the actual damages such person sustains and the cost of the suit, including
+reasonable attorney's fce."
+
+
+By signing this Addendum, Epstein asserts and certifies that the above has been read and
+explained to him. Epstein, hereby, states that he understands the clarifications to the Non-
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+Das 142/17
+À. MARIE VILLAFANA
+ASSISTANT U.S. ATTORNEY
+SHERBY EPSTEIN
+Dated: _
+GERALD LEFCOURT, ESQ.
+COUNSEL TO JEFFREY EPSTEIN
+
+
+
+Westlaw.
+West's F.S.A. § 951.24
+Page 1
+Effective:[See Text Amendments]
+West's Florida Statutes Annotated Currentness
+Title XL. VII. Criminal Procedure and Corrections (Chapters 900-999) (Refs & Annos)
+Chapter 951. County and Municipal Prisoners (Refs & Annos)
+951.24. Extend the limits of confinement for county prisoners
+(1) Any county shall be deemed to have a work-release program upon the motion of that county's board of
+county commissioners which shall require the concurrence of the sheriff of the county.
+(2)(a) Whenever punishment by imprisonment in the county jail is prescribed, the sentencing court, in its discretion, may at any time during the sentence consider granting the privilege to the prisoner to leave the confines of
+the jail or county facility during necessary and reasonable hours, subject to the rules and regulations prescribed
+by the court, to work at paid employment, conduct his or her own business or profession, or participate in an
+educational or vocational training program, while continuing as an inmate of the county facility in which he or
+she shall be confined except during the period of his or her authorized release.
+(b) Any prisoner, at the time of sentencing or thereafter, may request the court in writing for the privilege of being placed on the work-release program. The Department of Corrections, upon the request of the court, is authorized to conduct such investigations as are necessary and to make recommendations to the court pertaining to the
+suitability of the plan for the prisoner and to supervise such prisoner if released under this program. Such a release may be granted by the court with the advice and consent of the sheriff and upon agreement by the prisoner.
+The court may withdraw the privilege at any time, with or without notice.
+(c) No person convicted of sexual battery pursuant to s. 794.011 is eligible for any work-release program or any
+other extension of the limits of confinement under this section.
+(3)(a) The wages or salary of prisoners employed under this program may be disbursed by the sheriff pursuant to
+court order for the following purposes in the order listed:
+1. Board of the prisoner.
+2. Necessary travel expense to and from work and other necessary incidental expenses of the prisoner.
+•3. Support of the prisoner's legal dependents.
+© 2008 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+httt://weh2.westlaw.com/nrint/nrintstream.asnx?nrf=HTMT.F&.ifm=NotSet&.destination
+11/24/9008
+
+
+
+West's F.S.A. § 951.24
+Page 2
+4. Payment, either in full or ratable, of the prisoner's obligations acknowledged by him or her in writing or
+which have been reduced to judgment.
+5. The balance to the prisoner upon discharge from his or her sentence, or until an order of the court is entered
+declaring that the prisoner has left lawful confinement, declaring that the balance remaining is forfeited, and directing the sheriff to deposit the funds in the general fund of the county to be spent for general purposes.
+(b) The sheriff may collect from a prisoner the wages or salary earned pursuant to this program. The sheriff shall
+deposit the same in a trust checking account and shall keep a ledger showing the status of the account of each
+prisoner. Such wages and salaries shall not be subject to garnishment in the hands of either the employer or the
+sheriff during the prisoner's sentence and shall be disbursed only as provided in this section.
+(c) Every prisoner gainfully employed is liable for the cost of his or her board in the jail as fixed by the county.
+The sheriff shall charge the prisoner's account, if he or she has one, for such board. If the prisoner is gainfully
+• self-employed he or she shall deposit with the sheriff an amount determined by the court sufficient to accomplish the provisions of subparagraphs (a)1.-5., in default of which his or her privileges under this section are
+automatically forfeited.
+d) The board of county commissioners of any county may, upon the recommendation of the sheritf, authoriz
+le person in charge of a county stockade or workcamp to implement paragraphs (a), (b), and (c), when such fa
+cility is not directly under the sheriff.
+(4) Any prisoner who willfully fails to remain within the extended limits of his or her confinement or to return
+within the time prescribed to the place of confinement shall be deemed an escapee from custody and shall be
+subject to punishment as prescribed by law.
+(5) Exchange for the purpose of work-release of county prisoners among other counties of the state that have implemented work-release programs is hereby authorized, with the concurrence of the sheriffs of the involved
+counties. For the purpose of this subsection, upon exchange, the prisoner shall be deemed a prisoner of the
+county where confined unless or until he or she is removed from extended confinement status. Prisoners from
+other jurisdictions, serving lawful sentences, may also be received into a county work-release program as above
+provided.
+CREDIT(S)
+11/4/000
+
+
+11/25/2888
+
+CINUUL CHIMINAL
+STATE OF FLORIDA
+Plaintiff
+- VS-
+JEFFREY E. EPSTEIN
+Defendant
+IN THE FIFTEENTE JUDICIAL
+CIRCUIT COURT, IN AND FOR
+PALM BEACH COUNTY
+CASE NUMBER
+502008CE0093H1AXXXME
+DIVISION
+MCSORLEY "W"
+DC NUMBER
+I35155
+CIRCUIT NUMBER:
+15-4LJAIL SPLIT
+ORDER OF COMMUNITY CONTROL I
+This cause coming before the Court to be heard, and you, the defendant, being now present before the court, and you,
+having
+entered a plea of guilty lo
+entered a plea of nolo contendere to
+been found guilty by Jury yerdiot of
+been found guilty by the court trying the care without a jury of
+Count 1
+PROCURE PERSON UNDERAGE OF 18EOR PROSTITUTION
+SECTIÓN 1: JUDGMENT OF GUIT
+The court hereby adjudges you to be guilty of the sbove offense(s).
+Now, therefore, it is ordered and adjudged that tho impooltion of sentence is hereby withhold and that you be placed
+ot Probatien I for a period of _ undor the superviaion of the Department of Corrections, aubject to Florida Law.
+SECTION 2: ORDER WITHHOLDING ADJUDICATION
+Now, therefore, it is ordered and adjudged that the adjudication of guilt is hereby withheld and that you be placed on
+Probation fora period of .. under the supervision of the Department of Corrections, subject to Florida law.
+SECTION 3: INCARCERATION DURING PORTION OF SUPERVISION SENTENCE
+It is horeby ordered and adjudged that you be:
+commited to the Department of Corrections
+confined in the County Jail
+for a term of with credit forjail time. After you have sitrved..._. of the teren, you shall be placed on
+Probation for a period of.
+_ under the súpervision of the Department of Corrootions, subject to Florida Jew.
+pr
+confined in the County Jail
+for a term of SIX (6) MONTHS AS TO COUNT 1 FOLLOWED BX TWELVE (12) MONTHS
+COMMUNITY CONTROL I CONSECUTIVI TO THE (122 MONTH SENTENCE IN
+•CASE 2008C009454AMB with credit for ONE (DAY Jail timo, as a special condition of
+supervision.
+0371E
+
+
+
+11/25/200B
+
+CASE#S02008CF009381AXXXMB
+XT IS FURTHER ORDERED that you shall comply with the following slandard conditions of aupervision as proylded by Flprida:
+law:
+(1) You will report to tho probation office as directed. Not later than the fifth day of each mooth, unless otherwise directed, you will
+rake a full and trithful report to four officer on the form provided for that purpque.
+(2) You will pay the State of Florida the amount of 950.00 per month, us well as 4% surcharge, toward the post of your supervision in
+acoordanoe with 8, 948,09, F.S, unless otherwiso exempted in compliance with Florida Stacures.
+(3) You will remain in a speolfied place.
+You will not change yout residence or amploymont or leave the county of your residence
+without first procuring the donsent of your officer.
+(4) You will not possess, carry or own any furearm or weapon, unless authorized by the court.
+(s) You will live without violating the low. A conviction in a court of law shall not be necessary for such a violation to congtituto a
+violstion of your probațion/ community control.
+(6) You will not associate with any person engaged in any criminal activity.
+(7) You will not use intoxicents to-excess or possess any drugs of narcotics unless presoribed by n physician. Nor will you visit.
+places whero intoxicants, drugs or othor dangerous pubstenoes are unlawfully gold, dispenaed or used.
+(8) You will work diligently at a lawful occupation, adviso your employer of your probation statan, and support any dependents to the
+best of your ability, as directed by your offiper.
+(9) You will promptly and truthfully answer all inquiries directed to you by the court or the officer, and allow your officer to visit in,
+your home, at your employment sile or elsowhere, and you will comply with all instructions your officer may give you:
+(10) You will pay restitution, court cous, and/or fees in accordence with special conditions imposed or in accordance with the attached
+orders.
+(11) You will submit to random testing ne directed by your officor or the professional staff of the treatment center where he/she is
+receiving treatment to devrmine the presence of alcohol or illegal drugs. You will bo required to pay for the tests unless exernpt
+by the court.
+(12) You will submit two biological specimens, as directed by your ofticer, for DNA anslysis as prescribed in es, 943.325 aro
+948.014. F.S.
+(13) You will report in person within 72 hours of your release from incureration to the probation office in KALM BEACH County,
+Florida, unless otherwise instrupted by the court or department. (Thie condition applies only if scotlop 3 on the previous page is
+oheoked.) Otherwise, you must roport immeditaly to the probation office located at 3444 SOUTH CONGRESS AVENUL
+LAKE WORTH. EL 33461,
+Page
+2
+of 8
+Fortn Revised 03-18-08
+
+
+11/25/200B
+
+FADE 037 co
+CASE#S0200BCFD09381AXXXIYTB
+SPECIAL CONDITIONS
+most Undergo & Drug nod Alcohol evaluation and, ff treatent i deemed necessary, you must successfully comple
+a treatment, and be rsponsible for the paymont of any costs inpurred while receiving said evaluation and treatment, unle
+waived by the court."
+Additional instructions ordered:
+2. You will make resitution to the following viotim(s, as dirtoted by the coviz, until the obligation is paid in full:
+"NAME:
+TOTAL AMOUNT; $.
+Additional instructions ordored, including specific monthly amount, begin deto, due dato, or joint & several: _
+NAME:
+TOTAL AMOUNT: 5.
+Additional instructions ordered, including speolfic monthly amount, begin date, due dato, or joist & several:
+SPECIAL CONDITIONS - CONTINUED
+3. You will enter the Department of Corcotion Non-Seours Dnig Treatment Program or other residontial treatment
+program/Probation and Restitution Conter for a period of successful completion as approved by your officer.
+You are to
+perein Until you successibly complete said Program and Aftercare. You are to comply with all Rules and Regulations of
+the Program. You shall be confined in the councy jail until placement in said program, and if you are contined in the jail,
+the Sheriff will transport you to aid program.
+4. You will abstain entirely from the upe of alcobol and/or illegal drugs, and you will not associate with anyone who in
+illegally using drugs of consuming alcohol.
+5. You will kubmit to urinalysis resting of a monthly basis to determine the prosence of alcahol ot illegal drugs, 'You will
+be required to pay for the lests unless axempt by the court.
+5. You will not visitiny establishment where the primary business is the aale and dispensing of alcoholie boverages.
+7. You will sucoesfully complese
+bours of community sorvice at a rate of _
+at a work sito approved by your
+officer.
+Additional instructions ordered: _
+8. You will remeln at your reaidence berween 10 p.m, and 6 a.ma, due to a ourfew imposed, unless otherwise directed by the
+9. You will submit to electronic monitoring, follow the rules of electronio monitoting, and pays,
+_ per month for the
+dost of the monitoring service, unless otherwise dirested by the court.
+10. You w/ll not associate with.
+_ during che period of supervision.
+11, You will have no contaot (direct or indirect) with the vistim or the victim's family during the period of supervision.
+12. You wll have no coac (direct or indirect) with _____ during the perlod of bupervision.
+13. You will maintin fall timo omployment or uttend school/vocational sobool full time or a combipation of school/work"
+during the term of your supervision.
+14. You will make a good faith effort toward oomploting basio or funtional literary skills or a bigh school equivalency
+diploma.
+15. You will succesfully completo the Probotion d Restination Program, abiding by all rales and regulations.
+
+:
+
+
+Ï1/25/20Đ8*• 15128
+d5b3626-
+CIRCUIT CKEMENAL'
+CASE#502008CF009381A72PXMB
+16. You will attend Alcoholics Anonymou or Narcotics Anonymous meetinge at least monthly, unlosa otherwise directed
+by the cout.
+17. You must successfully complete Anpot Menazement, aid be responsible for the payment of any oosts incurred while
+receiving said treatment, unless waived.
+If convicted of a Domestic Violence offenso, es delued in s. 741.28; F,S., yev
+must attond and succesafully complete a batterer's interventivu program, unless otherwise directed by the court:
+Additional instructions ordered: _
+18. You will attend in HIV/AIDS Awareness Program consisting of a oliss of not lean than two (2) hours or more than four
+(4) bours in longth, the cost for which will be paid by you.
+19. You shall submalt your person, property, place of residence, vehicle or personal effects to a witrantless search at any
+time, by uny probation or community contral officer or any law enforcement officer.
+20, DEFENDANT MUST REGISTER AS A SEXUAL OFFENDER WITHIN 48 HOURS OF RELEASE
+21, AS A SPECIAL CONDIXON OF HIS COMMUNITY CONTROL, THE DEFENDANT IS TO HAVE NO
+UNSUPERVISED CONTACT WITH MINORS, AND THE SUPERVISING ADULT MUST BE APPROVED BY
+THE DEPARTMENT OF CORRECTIONS
+22. THE DEFENDANT IS DESIGNATED AS A SEXUAL OFFENDER PURSUANT TO FLORIDA STATUTE
+943.05 AND MUST ABIDE BY ALL THE CORRESPONDING REQUIREMENTS OF THE STATUTE, A
+COPY OF WHICH IS ATTACHED HERETO AND INCORPORATED HEREIN
+23. DEFENDANT MUST PROVIDE A DNA SAMPLE IN COURT AT THE TIME OF THIS PLEA.
+24. SPECIFIED CONTACT WITH THE PAROLE AND PROBATION OFFICER
+25. CONFINEMENT TO AN AGREED-UPON RESIDENCE DURING HOURS AWAY FRÓM IMPLOYMENT
+AND PUBLIC SERVICE ACTIVITIES
+25, MANDATORY PUBLIC SERVICE
+SUPERVISION, BY THE DEPARTMENT DE CORRECTIONS BY MEANS OF -AN ELECTRONIC
+MONITORING DEVICE OR SYSTEM
+180
+27, ELECTRONIC MONITORING 14 HOURS PER DAY
+28. CONFINEMENT TO A DESIGNATED RESIDENCE DURING DESIGNATED HOURS
+AND, IF PLACED ON DRUG OFFENDER PROBATION, YOU WILL, COMPLY WITH THE FOLLOWING CONDITION.
+OF SUPERVISION IN ADDITION TO THE STANDARD CONDITIONS LISTED ABOVE AND ANY OTHER SPECIAL
+CONDITIONS ORDERED BY THE COURT:
+(14) You will participate in a specialized drug treatment prograri, either as an In-patient or out patient, no recommended by the
+treetment providor. You will attend all counseling açssions, submit to random urinalysis and, if an in patient, you will comply
+with all operating rules, regulations and provedures of the treetment facility. You will pay for all costs associated with rearment
+and testing unless otherwise directed.
+Additional instructions ordered: _
+(15) You will renain at your rcaidence between
+: P-rO, and
+directed by the court.
+- a.ms duo to a curfow imposed, unless otherwise
+AND, IF PLACED ON COMMUNITY CONTROL, XOU WILL COMPLY WITH THE FOLLOWING CONDITIONS, IN
+ADDITION TO THE STANDARD CONDITIONS LISTED ABOVE AND ANY OTHER SPECIAL CONDITIONS
+ORDERED BY THE COURT:
+Pago 4 of 8
+
+
+11/25/2008 15:28
+
+THE b57D0
+CASE#502008CF009381AXXXMIB
+(14) You will topoit to your officer as directed, it least one time a week, unless you have writen consent otherwise.
+(15) You will remain confined to your approved residence except for one half hour before and after your approved employment,.
+publie servico work, or any other special activities appioved by your officer.
+(16) You will maintain an hourly accounting of all your activities on a daily log, which you will submit to your officer ou request.
+(17) You will successfally completo
+_hours of community service at a rite of; at a work site approved by your officer.
+Additional instructions ordered;
+(18) You will submit to electronie monitoring, follow the rules of cleotronio monitoring, and pay $_
+per month
+for the cost of the monitpring service, unices otherwiss directed by the court.
+AND, IF PLACED ON PROBATION OR COMMUNITY CONTROL FOR A.SEX OFFENSE PROVIDED IN CHAPTER
+794, 8. 800.04, 6. 827.074, or 3. 847.0145, COMMITTED ON OR AFTER OCTOBER 1, 1225 YOU WILL COMPLY WITH
+THE FOLLOWING STANDARD SEX OFFENDER CONDITIONS, IN ADDITION TO THE STANDARD CONDITIONS
+•LISTED ABOVE AND ANY OTHER SPECIAL CONDITIONS ORDERED BY THE COURT:
+(14) A mandatory curfew from 10 p.m. to 6 a.m. The court may designate another 8-hour period if the offonder's employmens
+preoludes the above speolfied time, and the alternative is recommended by the Departmont of Corrections. If the court determineg
+that imposing a surfow would endanger the vlotim, the court inay corsider alternative sanctions.
+(15) If the wriotim was under the age of 18, a prohibition on living within 1,000 foot of a school, day cure center, park, playground, or
+other place where childron rogularly congregato, as prescribed by the court The 1,000-foot distanco shall be measured, in a
+etraight line from the offender's place of residense to the nearost boundary line of the school, day care center, park, playground, or
+• other piace where children congregate. The dietance may not be measured by a pedestrian route or automobilo route.
+(16) Active participation in and succesful completion of a ass offendor treatment program with qualified practitioner, specifically
+trained to treat sex offenders, at the offender's own expense. If a qualiled practitioner is not avallable within a 50-mile radius of
+the offender's residenoc, the offender shall participate in other appropriate therapy.
+(17) A prohibition on any connet with the victim, dirictly or indredly, including through a third person, unless approved by the
+victim, the offender's therapist, and the sentencing court.
+(18)If the victim was under the ago of 18, a problbition on contot with a child under the age of 18 except as provided in this
+paragraph. The court may approve supervised contact with-a child under the ago of 18 If the approval is based upon a
+recommendation for contret issued by a qualified practitioner who is basing the recommendation on a risk assessment. Further,
+the sex offender must be purrently enrolled in or have successfilly completed a sex offender therapy program. The court may not
+grant eupervised contaot with a child if the contact is not recommended by a quallfed practitioner und may deny supervised.
+contact with a chiid at any time,
+(19) If the victim was tunder age 18, a probfbition on working for pay or as à volunteer at any place where children regularly
+congregate, including, bat not limited to any school, day cure center, park, playground, pot store, library, zoo, theme park, or mall.
+(20) Unless otherwine indicatod in the treatnent plan provided by the sexual offender trealmens program, a prohibition on viowing,
+accessing, owning, or possessing any obacene, pornographic, or sezully stimulating visual or anditory material, inoluding
+telephone, clectronic media, computer progrems, or computer serviots that are relevant to the offender's devint behavior pattorn
+(21) A requirement that the offenser submit two specimeng orblood or other approved biologiol speomen to the Florida Department
+of Law Enforcement to be registorod with the DNA data bank.
+(22) A requirement that the offender make rostitution to the victim, as ordered by the court under s. '275.08D, for all nocessary medica!
+and related professional acrviccs relating to physical, payohistic, and paychological care.
+(23) Subrission to a warrantless scarch by the community control or probation officer of the offender's person, residence, or vehicle.
+
+
+
+117 20/ 2006 io: 20
+300002D
+iF Grinni
+JEFPREY EPSTEIN
+CASB#502008CF009381AXXXMB
+EFFECTIVE FOR PROBATIONER OR COMMUNITY CONTROLLEE WHOSE CRIME WAS COMMILIED ON OR
+AFTER OCTOBER 1, 1997 AND WHQ IS PLACED ON COMMUNITY CONTROL OR SEX OFFENDER PROBATION
+FOR A VIOLATION QE CHAPTER 794, 5. 800.04, 5. 827.071, or 8. 847.0145, IN ADDITION TO ANY OTHER PROVISION
+OF THIS SECTION, YOU MUST COMPLY WITH THE FOLLOWING CONDITIONS OF SUPERVISION!
+(24) As part of a treatroent program, participation at least annually in polygraph examinations to obtale Information necessary for risk.
+manegerent and treatment and to reduce the dex offonder's dealal mechanisms. A polygraph examination must be conducted by a
+polygrapher trained spectically in the use of the polygraph for the monitoring of sex offenders, where avalinble, and shall be padd
+(25) Maintenance of a driving log and a prohibition ngainst driving a motor vehicle alone without the prior approval of the supervising
+officer.
+(26) A probibition agalast obraining or using a post office box without the prior approval of the supervising officer.
+(27) If there woe bexun contac, a submission to, at the offender's expense, an HIV toss wish the resules to be roleased. to the victim
+and/or the victim's patent of guardian,
+(28) Electronio montforing when deemed necessary by the probation officer and superyloor, and ordered by the court at thie
+recommendation of the Department of Corrections,
+(29) Effective for an offender whose crime was committed on or after July 1, 2005, and who are plneed on supervision for
+vipiation of chapter 794, s. B00.D4, s. 27.071, or s. 847.0145, a prohibition on necessing the Internet or other computer services
+until the offender's sax offunder treatment progtam, after a risk assessment is completed, approves and implements a safety plan
+for the offender's accessing or using the Internet or other computer serviced.
+(30) Effectivo for offenders whose crime was committed on or nfter September 1, 2005, there is heroby imposed, in addition to
+any other provision in this section, mandatory olectronie monitoring as a condition of supervision for thoso who:
+" Are plnced on supervision for a violation of ohapter 794, 8, 800,04(4), (5), or (6), 8, 827.071, or 8, 847.0145 and the
+unlawful sexul activity involved a victim 15 years of nga or younger and the offender is 18 yenrs of age or older, or
+* Are designated as a sexual predator pursuent to 8, 775.21; or
+* Hrs previously been convioted o fa violation of obaptor 794, s, 800.04(4), (5), or (5), s. 827.071, or 6. 847,0145 and the
+unlawful sexual activity involved a yiotim 15 yeurs of age or younger and the offender is 18 years of ago or oider.
+You are hereby pinced on notice, that should you ylolate your probation or community control, and the conditions set forth in
+5, 948.003(1) or (2) are ratistied, whether your probation or community control is revoked or not revoked, you shall be placed on.
+electronio monitoring in accordanoo with F.S. 948.063.
+YOU ARE HEREBY PLACED ON NOTICE that the court may at any time regaind or modify any of the conditions of your
+probation, or may extend the poriod of probation as authorized by law, or' may discharge you from farther superviaion, If you violate
+any of the conditions of your probation, you may be arrosted and the court may revoke your probation, adjudionte you guilty If
+adjudication of guilt wao withheld, and impose any sentence that it might have imposed before placing you on probation or require
+you to serve. the balence of the sentence.
+
+Form Revised 03-18-08 -
+
+
+11/25/2008 15:28
+CASE#50200BCF009381AXXXMB
+IT IS FURTHER ORDERED that wlien you have biein instructed as to the conditions of probation, you shall be released frot
+custody if you are in austody; and if jou are at Jibeity on bond, the sureties thereon shall stand discharged from liability. (This
+paragraph applies only if section 1 or section 2 is checked.)
+• IT IS FURTHER ORDERED that the clerk of this oourt file this order in the clerk's offiet and provide certified copies of same to
+the officer for use in compliance with the requiramonte of law.
+DONE AND ORDERED, on,
+NUNC PRO TUNC D5-30-2008
+Quit, and
+• Sandra K. MoSarley, Circuir Tidge
+I acknowledge receipt of a copy of this order and that the conditions bave beeh
+explained to me and I agree to abide by them..
+Date:
+Instructed by:
+Defendant
+Supervising Officer
+ep/07-02-08
+PAge
+018
+Forma Revised 03-18-08
+
+
+112002008 1xb
+
+CASEH502008CF009381AXXXMB
+COURT ORDERED PAYMENTS
+CHECK ALL THAT ARE ORDERED:
+Total of fines assessed in sentonce, pursuent to s. 775,083 (1)(e) through (g) or Chapter 316, F.S.
+Statutorily mondated 5% surcharge/oopt if fine nsscased (on first line) parsuent to s. 938.04, F.S.
+520.00
+Crime Sloppers Trust Fund pursuent to s. 938.06(1), F.S. Blotutorily mandated it a fine A mansed
+MANDATORY COSTS IN ALL CARES
+$200.00
+5,50.00
+$ 50.00
+5 50,00
+3,00
+7.00
+Additlonal court cost for folony offense, pursuant to s. 938;05(1)(a), F.S.
+Additional couri cost for misdemeanor or criminal traffic offenpe, pursuent to s, 938.05(1)(b) or (e), F.S.
+Crimes Compensation Trebt Fund pursuant to s. 938.03(1), F,S,
+County Crime Prevention Fund pursunnt to s. 775.083(2), F.S.
+Additional Court Costs Clering Trust Fund pursuent to s, 938.01(1), F.S.
+Per thonth for tech month of supervision for Training Trust Fund Surcharge, purant to s, 948.09, F.S.
+MANDATORY COSTS IN SPECTIC TYPES OF CASES
+• $15LÓ0
+• 5201.00
+Rape Crisis Progrom Trust Fund, purunnt to 8, 938,085, F.S. for any violations of ss. 784.01.1, 784:021, 784,03, 784,041;
+784.045, 784.048, 784.07, 784.08, 784.081, 784.082, 784.083, 784,085, or 794.011, F.S.
+Domestic Yidlence Truat Fund, pursuent to a, 938.08, FIS. for any violations of ss, 784.011, 784.021, 784.03, 784,041, 784.045,
+784.048, 784.07, 784.08, 784.08L, 784.0B2, 784.083, 784.085, 794.011, or any offenge of Domestio Violence described in s
+.741.28, F.S.
+
+2115.00
+$ 3.00
+Certain Crimes Against Minors, pursuant to s. 938,10(1), P.B. for any violations of s. 784.085, ohapter 187, chapter 794, s.
+796.03, g, 800,04, chapter 827, s. 847.0145, or s, 995.70L, F.S.
+DUI Court Cests, pursuant so s, 938,07, F.B. for any violations of as. 316.193 or 327.35, F.$,
+Stare Agenay Law Enforcement Redin System Trust Fund, pursuent to s, 318.J8(17), F.S, for any violations of offenses listed
+in s. 378.17 incuding ss, 316.1935, 316.027, 316.06L, 877.111, chapter 893, ss. 316,193, 316.192, 316,067, 316.072(3),
+316.545(1), orsty other offense in chapter 916 which is olnsifiod as o oriminal violation.
+MANRATORY COURT COSTE AUTHORIZED BY LOCAL GOVERNMENTAL ENTITES
+Criminal Justice Education by Munleipalitfer and Countier, pursuant to s. 938.15, F.S.
+Addisonal court dosts for loen regulrements and other county funded programs pursuent to s. 939,185(1)(a), F.5.
+Teen Court pursuant to 3. 938.19(2), F.S.
+RISCRETIQNARY
+Per month during tho cem of supervision to the following nonprofit organization eatblished for the solo purposo of
+supplomenting (ho rehabllitat/vo effons of the Depottment of Correctiono, pursunnt so s, 948.039(2), F.S.
+•Publie Defender Application Fee, if not previously collerted or waived, pursuent to s. 27.52 and s, 938,29, F.S,
+Publie Defender Feta and Costs, pursuant to e, 938.29, F.S, es determined locally.
+Prosecution/Investigative Costs, pursuent to s. 938.27, F.S.
+5 2.00
+565.00
+3.00
+$ L.RR
+5.40.00
+$50.00
+Other:
+Other:
+@' $50,00
+• $100.00
+* TOTAL, $ 473.09
+RISCRETIONARY COSTS FOR SPECIFIC IYEES OF CARES
+County Alcohel and Other Drug Abuse Trust Fund, pursuant to s. 938.21 and s. 938.23, F.S, for violations of s. 316.193,
+s.856,011, g. 856.015, or ohapter 562, chapler 567, or chapter 568, F.S.
+Operating Trust Fond of the FDLE, pursant to 1, 938,25, F.S, for violations of s, 893.13. offenses
+PAYMENT IS TO BE MADE THROUGH AND PAYABLE TO: 12) Dupariment of Correations or
+• Clerk of Court
+(If collected by the Department of Corrections, n surcharge of 4% will bo edded to all payments ordored by the court, pursuant to 3, 545,31. P.B.)
+Court Costs/Fines Waived
+- Cour Costs/imos In the amount of,
+Court Costs/Fines in the pinount of
+_ community service houra
+reduced to civil judgmen!
+SPECIFIC INSTRUCTIONS FOR PAYMENT:,
+Page 8 of8
+
+
+ang senale
+02006CF009454X*2
+ST GF • FL.
+VS.
+FELONY OFFER TO COMIT PRUSTITUTION
+' JEFFRĘY
+EPSTEIN
+741.
+710708 D /0
+Co Judge
+00b73140
+5x000.:00
+Crt. Rep.
+x-0P(01xWU2)
+W/WO Def. Co.
+Ciot
+Esq/ PD--Pres / Not Pres.
+Before the Court fốr
+StAtüische
+F Granted
+D Denied • With / Without Prejudice
+• Withdrawn
+• ComtiReserves Ruling • Written Order to Follow
+Bond Forf
+ara Bor brech (Revoleda indate Bol omc Diol Reieaket
+• See-Belów
+.Also Covers. Osp Cond
+OSOR: Disch/Revoked/Reinstated
+7 Bord Forf Vacated EJ Previous Bond Reinstated, if Bondsman apré
+Q. State failed to tile chargés J Released O.R. / S.O.R.
+Deft — Indigént, O PD Appt O Erg only
+•: Couit Appts
+Evaluation for:
+O Drug Farm
+O. DOC Non-Secure Bed by
+O Pre:Plea: OpsI ordered by/within
+@.w/input from DJl/ Staffing
+"REFL' ENTERED A PLEA OF
+D NOT GUILTY
+D• BEST INTEREST
+. O,TO THE CQURD
+'s, Charged-Cts
+Lesser Charge
+Sw & Test XE Ady of Rts!
+L7 Naived PSI
+Lesser Cts
+-Lesser Charge
+ADJ GUILTY.as Charged as to Cts
+O: FOUND GUILTY as Charged as to Cts
+ADJ W/HBLD as to Cts +
+FOUND AND ADJUDICAȚED DELINQUENT as to Cts
+FOUND & APINOT GUILTY ai to Cis
+Prob /i Coini Control: O Révoked
+• Reinstate
+BE SiEod: (YiCn) Lamtin O. 73:084
+SENTENCE:
+• SENT W/HELD as to Cts
+O Pismiss
+LP Nolle Prosse Cts
+b Modified D Teii.
+Suceessfally / [Unsuóct
+si ouat Sexuat olie
+Nu Sexual Preiator
+tensoteund
+Cts
+doipo Cnetöfallowaila
+CW/Credit for
+-Days 1 AA00-19315.
+M Depi Remanded bert to remain om samie se
+Status pendin
+onc / Consec / Co-Term w/cases /
+Execution of Sentence Stayed
+O Sentence Suspended
+P Time servedjas tä Cts
+Youthful Off • Habitual Off- ; • Min / Mand:
+ABONE SENTENCE TO BE FOLLOWED By: L Probation
+D Drug / Sex O Prob
+Comm. Contro
+DRIVERS LICENSE TO BE SUSPENDED /REVOKED FOR
+LYBARS AS'A RESULT OF HES BLE
+DUA SWAB
+DiE:-ScoPg. 2
+Set / Remains Set / Reset
+Set / Remains Set/ Reset
+Div =
+Rm
+at
+• Div
+Rm
+at
+AM/PM
+Deft sign
+• Bondsman
+],Prob
+• DIJ O GAL'
+Notified by moai by:
+. ОД
+• County Courthouse
+Courtroom, Criminal Justice Bldg
+Courtroom, Criminal Justice Complex
+205. N. Dixie, West Palm Beach
+38844 State, Road 80, Bebe Glade
+3228. Gun Club Ra, West Palm Beach
+( YOU-AFE A PERSON WITH A DISABILITY WHO NEEDS'ANY ACCOMMODATION IN ORDÉR TO PARTICIPATE IN THIS-PRODEEDING, VOUIARE ENTTLED, AI-ND COST TO YOU, TO THE PROVISOWÖA!
+ÖERTAIN ASSISTANCE PLEASE CONTACT MARY JAFFE, ADA COORDINATOR IN THEJADMINISTRAȚIVE OFFICE OF THE COURT, PALM BEACH COUNTY COURTHOUSE, 20SN DDOE HiNY; RM 522800,
+WEST PALM BEACH, FL 33401; TELEPHONE (861) 355-4380, WITHIN 2 WORKING DAYS DF YOUR RÉCEIPT OF THIS NOTCE (IFYOU ÅRE. HEARING OR. MONCE IMPAIRED, CALG T-0p4gs5-8771.
+Inrm K11 END Dau 19/06
+
+
+Case No.
+Chatges,
+20D8CF009381AXX
+PROCURE PERSON UADER AGE
+DP 18
+TOR
+JEFFREY BESTEIN
+FROM 2006CF009454AXX)
+Bondht
+Date
+11213
+Judge
+•Rep
+FASA
+Aalolhy2z
+pen Ris Noores
+W/W2QwDet.G6
+.EsáRDBçe/Not Presi-y
+Betore the Court for:
+SAyis (pr
+Bormed O Doned a Wih Vithou biejudice
+-a oi
+ourt Reseryes Rulipg'
+Witteh Order-to.Follow
+O Bond SébatS
+See Belol C Also Coyers ESp Cond
+• Bond: Dischy Révokeds
+Disch/Revoked / Reinstated
+E Bónd öVgéatd?E1 Previpus BondŘeinsiated, if Bondsmamagrees
+e fdled to tile chat
+•2 Relensedi@ R//.S.O.R.
+T Dete indigent O BD Appe@-Higonly: PD Pres
+Coutt APP(
+Evaluation for
+Diye Haimi
+—Ö•Pre-PleawC-PSI-ördere@bylwithinz
+ays 0
+LEV Referred to BTLTA SNAP/PADD: Ek Case pläcedion the absentee docket
+DENT-ENTERED PLEA OR
+DINOTGUEIY N GULTY
+ONO CONTEST
+Sew/input-from-DJJr/-Staffing
+RESI SOVTO THE COURȚ
+eCharged Cts
+ser Cts
+watAdy-ofRrs Walyed. PSt
+Lesser Gts.
+ADICUILTY a Charged as to Cis.
+PEOUND GUT TY as Charged as to Cts
+CLADIWHE
+ELFOUNIDA
+JUDICATBE DELINQUENT as torCis:
+Fessir CI
+DESEN
+WHELD AStorCis
+1E: Dispöro
+emto fol|ow/-Biled
+D FOUND&
+NỌT GUI TY ai to. Cts -
+D NOl
+Prob/ Commi Coritrol:
+=-4m Revoked.
+AE Reinstaredl: E Modifeda Tem
+E Défi to pay inser complete
+his: Community Service of Serve.
+5-Stip/Found we iolent
+S1084-
+SMP Founa S exualOEende
+sefully 80
+L days PBCL:
+1 Predator
+SENTENCE, TEBOIC
+. W/Credit fors
+:Cts:
+citertemnaihçön sameirelastatus pending sente
+C Sentenee Suspenided O
+piéryedrastoiCts
+/Min:/Mand:
+NOE FO BE HOLLOWED By. a1 Bröbation : @:Dnig QirF/6b
+Ig Gomm, Contii
+SeeiPager
+ABOVESE
+BUF-
+D: Deft sign
+O. Breb
+Bl Jail.
+Debuiy cout
+2 205N Digie
+C DIEGAL
+St: Paj
+AM
+Ramains Set/-Reset
+Điy30Rmwaat=
+AN
+SELASA
+E Bondsman :-
+Notilied byumall bye
+• ОП
+"Coutroom, Criminat Juscice Bidg
+•: Courétoom, Criminal Justioe Compliéx
+38844 Staté Road 80, Belle Glade
+3228 Gun Club-Rd;, West Palmy Beach
+DERTO PARTCIRATEIN THÍS BROGÉEDING YÖU ARÉ ENTTLED AT NO COSTTO.YOU, TO THE PROVISIÓN OF
+ASTRATIVE OFFICE OETHE COURT PALM-BEACH COUNTY COURTHOUSE, 205 NDIJE-HWY/RM 5:2500)-
+IG DAYS OAYOUR RECEIPTOFTHIS NOTICE, IF VOU ARE HEARIÑG OR VOICE IMPAIRED; CALL 1-300-055-4771:
+
+
+FiT
+•DATE: 6/30/08
+- Page 2
+CASE NO 40080F 9831 AXY
+NAME:
+Je
+TERM-OF
+Prob/Sex Off7 Drug Off Prob C.C: 1) C.C. I!:
+mosy yte as. to Cts.
+Pisteiy
+congw: consec. w/
+Probation transferred to:
+SPECIAL CONDIȚIONS:
+Çomplete Originally Ordered Conditions
+Gurfew:
+-p.m., with the following exception:
+Deft to report to Prob, Dept. immediately upon-release
+Deft. not to have in care, custody, or control any unlawful of illegal material, subst., device, or object.
+Deft. to immediately notify Prob. Officer if place of residence or job changes.
+Restitution CRO filed
+Subject to all ordinary and special conditions of Probation
+Substance Abuse Eval. / Psychological Eval: / Psychosexual Eval. within / by:
+and deltato successfully complete recommended treatment
+@ Random Drug Alcohör Testing
+mA Bett's Expense
+'ECosts Waived
+No Consumption/Possession of Alcohol or Drugs or. Intoxicants without a Prescription.
+Attend
+_.AA and/or NA Meetings per. Week:
+Deft. not, to frequent any place of business whose primary purpose is the sale of alcohol,
+Complete.
+_ Hrs, of Community Sérvice to be done at the rate of
+License Revoked / Suspended for
+- mos/ yrs
+Attendiand successfully.complete.DUl school.and 1 session of Victim. Impact Panel
+No: Contact / No Violent Contact / No. Direct or:Indirect contact-w/Victim(s) or others listed:;
+Nộ Contact w/Minor Children w/o Adult Supervision aware of this case änd the disposition:
+* Cost of Supervision: $
+per month O Waived by Court.
+*E Enter and Successfully Complete DOC Non-Secure Bed-Program-and Any Recommended Aftercare:
+• Hold: in Custody, rélease only to DOC Non-Secure Bed Program Officer.
+I Enter and Successfully Complete PBSO Long 1, Short Traok Drug Farm and Any Rec: Aftercare.
+Forfeit Weapon / Money seized at the time of arrest to:
+Enter and Complete:
+• Anger Management:Program
+• Batterers Intervention Program
+El Theft Abatement Program:
+U
+Other:
+Defendant may apply for Early Termination after
+, provided all conds, are satisfied.
+Serve
+days / months in PBC, with credit for
+-days / months.
+• See All AlActed Documents
+Deft Must trziste nsA SexuaL Offendee.
+91 EN 48 hOuRs OF Prelinse
+
+
+"'=
+..
+RoY BLACK
+HOWARD M. SREBNICK
+SCOTT A. KORNSPAN
+LARRY A. STUMPE
+MARIA NEYRA
+JACKIE PERCZEK
+MARK A.J. SHAPIRO
+BLACK
+SREBNICK
+KORNSPAN
+& STUMPF
+=PA.
+JESSICA FONSECA-NADER
+KATHLEEN P. PHILLIPS
+MARCOS BEATON, JR.
+JENIFER J. SOULIKIAS
+JOSHUA SHORE
+E-Mail: RBlack@RoyBlack.com
+A. Marie Villafaña, Esq.
+Assistant United States Attorney
+United States Attorney's Office
+Southern District of Florida
+500 South Australian Avenue
+Suite 400
+West Palm Beach, Florida 33401
+May 18, 2010
+VIA EMAIL AND U.S. MAIL
+Jeff Sloman, Esq.
+United States Attorney
+99 N.E. 4* Street
+Miami, FL 33132
+Bob Senior, Esq.
+Assistant United States Attorney
+99 N.E. 4' Street
+Miami, FL 33132
+RE: Jeffrey Epstein
+Dear Counsel:
+We received notice this morning that Podhurst Orseck, P.A. has filed a civil
+complaint seeking over $2,000,000 in addition to the $526,000 they have already
+been paid by Jeffrey Epstein for their work as attorney representatives. As we
+communicated to you during our February 3, 2010 meeting and both before
+(January 20, 2010) and thereafter (February 18, 2010) by letter, see appended
+letters, there exists significant differences between fees that Mr. Epstein and his
+civil counsel believe are within his NPA obligations and additional amounts which
+the attorney representative is claiming are due.
+Mr. Epstein has in the past attempted to resolve issues relating to the
+outstanding invoices through efforts to review the particulars in the unpaid bills
+with the attorney representative, through settlement discussions with the attorney
+representative, and through his signing on February 16, 2010 a Special Masters
+Agreement which would allow a neutral third party to make a binding
+determination as to what portions of the invoices at issue were reasonable, non-
+201 S. Biscayne Boulevard, Suite 1300 - Miami, Florida 33131 • Phone: 305-371-6421 • Fax: 305-358-2006 • www.RoyBlack.com
+
+
+A. Marie Villafaña, Esq.
+Jeff Sloman, Esq.
+Bob Senior, Esq.
+May 18, 2010
+Page 2
+duplicative, and within Mr. Epstein's NPA-obligations. As a preliminary matter,
+Mr. Epstein had been requesting, but did not receive, an invoice including billing
+dating back to the end of 2009 until May 11, 2010 - and even this invoice was
+without the charges of certain of the outside contractors relied upon by the
+Podhurst firm.
+We regret that these efforts did not resolve the matter and that Podhurst
+Orseck, P.A. elected instead to litigate. Mr. Epstein is today, in response to the
+lawsuit, filing a motion for authority to place $2,000,000 in an account
+maintained at the Clerk's Office for the United States District Court pending the
+results of the litigation. Mr. Epstein has always agreed that he is entirely
+responsible for any settlement-related fees that are not excessive and will take no
+litigation position inconsistent with that understanding. However, we have
+contended as a matter of principle that given the unexpected enormity of the
+claims for legal fees, that absent additional detail on why the invoiced fees were
+not duplicative and excessive and outside the ambit of Mr. Epstein's NPA
+obligations, payment should depend on either an agreement with the attorney
+representative which never occurred or a determination by a neutral third party.
+Mr. Epstein will pay whatever amount Judge Gold or any selected Master
+determine he owes under the NPA.
+Respectfully submitted,
+MARTIN WEINBERG, ESQ.
+/wg
+Black, Srebnick, Kornspan & Stumpf, P.A.
+
+
+A LIMITED LIABILITY PARTNERSHIP
+J. MICHAEL BURMAN, PA.:2
+GREGORY W. COLEMAN, PA.
+ROBERT D. CRITTON, JR., PA.'
+BERNARD A. LEBEDEKER
+MARK T. LUTTIER, PA.
+MICHAEL J. PIKE
+MICHAEL L. SCHEVE
+DEAN T. XENICK
+DAVID A. YAREMA
+FLORIDA BOARD CERTIFIED CIVIL TRIAL LAWYER.
+ADMITTED TO PRACTICE IN FLORIDA AND COLORADO
+May 25, 2010
+OF COUNSM. RICCI
+Honorable Edward B.
+Akerman Senterfitt
+One SE Third Avenue
+Floor 28
+Miami, FL 33131-1715
+Re: Jeffrey Epstein
+Sent by email and
+by U.S. Mail to Judge
+only
+Dear Judge
+We are in receipt of Mr. Josefsberg's letter to you dated May 21, 2010. We confirm that
+Mr. Epstein settled each and every case brought by the attorney-representative selected by you.
+We write this response only to advise you that Mr. Epstein has never refused to pay
+reasonable settlement-related fees that are within the scope of the NPA. He has already paid
+the attorney-representative $526,000. The attorney-representative has not yet presented him
+with a final invoice for settlement-related work.
+The incomplete invoices that have been
+presented seek $2,000,000 in additional fees. Mr. Epstein has been advised by his attorneys
+that the requested fees include duplicative work, charges that relate to preparation for litigation
+not settlement (thus outside his NPA-fee obligations) and charges that are unreasonable and
+that should be reviewed by a Court rather than simply paid without meaningful review. A
+significant amount of the total fees (over $1,000,000) is for legal work that the invoices
+document were done by two outside attorneys who are not even attorneys with the Podhurst
+Orseck, P.A. law firm.
+Mr. Epstein's disputes the necessity for and redundancy of these
+charges.
+We respect Your Honor's selection and regret that the issue of disputed fees has resulted
+in litigation. Mr. Epstein is committed to paying whatever fees and costs are determined by the
+303 BANYAN BOULEVARD • SUITE 400 - WEST PALM BEACH, FL 33401 • PHONE: 561-842-2820 • FAX: 561-814-6929 • MAIL@BCLCLAW.COM
+WWW.BCLCLAW.COM
+
+
+May 25, 2010
+Page 2
+Court to be his obligation, if any, but he is not required to simply write a blank check. I have
+filed a motion in the case pursuant to F.R.Civ.P. 67, to allow him to deposit $2,000,000 in Trust
+with the Court pending the outcome of the Complaint which confirms his commitment.
+Cordially yours,
+Robeft D. Criton, Jr.
+RDC/JPL:ab
+Cc
+Jeffrey H. Sloman, AUSA - jeff.sloman@usdj.gov
+Ann Marie C. Villafana, AUSA - ann.marie.c.villatana@usdj.gov
+Robert Senior, AUSA - robert.senior@usdj.gov
+Jack Goldberger, Esq.
+@jgoldberger@agwpa.com
+Robert Josefsberg, Esq. @rjosefsberg@podhurst.com
+
+
+Jef email re
+test freng qun
+Brad - 954 315-7273
+Alfredo Rediguez
+11/04
+Alex Hall
+705 Epatein gets
+report+
+
+
+"Ex parte" communications
+unspectications,
+ations, singh of case
+"stuttiness" f aris
+leter to
+pors.
+aralipis
+asking John McMillan to rereviin mu
+analesis of 8AO's handling of case
+the grond yury
+using trust fund
+0ED. response
+equipenient. Conferred w/Ardy oure.
+-mail to Matt Merchel The
+responded. They used this as ther
+first mars claim a prosecutorial
+
+
+
+
+
+
+
+
+
diff --git a/vision-fixhub/ds9-unparsed-05/9f6f5d3fe31773e5c58a9b820f71f27428e225213f962b742b53d4cfbde62464.receipt.json b/vision-fixhub/ds9-unparsed-05/9f6f5d3fe31773e5c58a9b820f71f27428e225213f962b742b53d4cfbde62464.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..8efb80aed6e5e831f1d4ec28c6f491adf413ef60
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9f6f5d3fe31773e5c58a9b820f71f27428e225213f962b742b53d4cfbde62464.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1771,
+  "dataset": "marble-joined",
+  "doc_id": "9f6f5d3fe31773e5c58a9b820f71f27428e225213f962b742b53d4cfbde62464",
+  "engine": "marble-apple-vision",
+  "event_count": 76,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "532f472d9a1dda9e5912b8642347a031ef1a49791699cce5d4e440ca3d0ac0c4",
+  "output_sha256": "5eea0fa2a3ac676d474d454248bc33c0451214a0eba81bf89e47ba8675e71830",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/9f8b7e8fb6da428a52674dc329231449a1dbd136981980146c9632516ef52fa5.md b/vision-fixhub/ds9-unparsed-05/9f8b7e8fb6da428a52674dc329231449a1dbd136981980146c9632516ef52fa5.md
new file mode 100644
index 0000000000000000000000000000000000000000..011045f53e8e7e0d81041630831e2b5da9d2ed98
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9f8b7e8fb6da428a52674dc329231449a1dbd136981980146c9632516ef52fa5.md
@@ -0,0 +1,1250 @@
+Hillsborough County Sheriff's Office - Inquiries Online - Arrest Inquiry
+Important Notice:
+The data on this site provides only arrest and booking information and should not be relied upon to determine an individual's actual
+criminal record. This data may not reflect charging decisions made by the State Attorney's Office or the outcome of criminal trials
+An acquittal or dismissal of a criminal charge does not necessarily negate the validity of an arrest. To obtain the final disposition of
+any criminal charges, contact the Clerk of the Circuit Court,
+This report includes: Aliases Cell Location Charges
+
+STATUS: STATUS - IN JAIL
+BOND: NO BOND
+CASH: $0.00
+FINE: $0.00
+PURGE $0.00
+Rascanal Taformatior
+Race
+Sex
+Ethn
+POB
+DOB
+Arrest Age
+SSN
+Address
+Street Address
+City
+State
+Zip
+Aliases
+Aliases
+Date OF Birth
+Social Security Number
+###-#*-***#
+###-##-***#
+###-##-#*##
+###-##-#*##
+Arrest Information
+Arrest Agency
+TPD
+Arrest Date
+04/04/2016
+Arrest Time
+10:57
+Book Date
+04/04/2016
+Book Time
+14:07
+Arrest Location
+Jurisdiction
+TA
+Release Information
+Cell Location
+#*********
+Cell
+##########
+Last Classification Date & Time
+10/07/2016 18:40
+Property Location
+Additional Information
+OBTS
+Caution Ind.
+HLD
+Caution Remarks
+NEBIA/USM
+Attorney
+Address
+Phone
+JULIAN HAYES
+Next of Kin
+##********
+Address
+####*************#*#
+Relationship
+##****####
+http://www.heso.tampa.fl.us/PublicInquiry/ArrestInquiry/ViewArrest?id=16012899&k1=8d3f38.. 10/13/2016
+
+
+Hillsborough County Sheriff's Office - Inquiries Online - Arrest Inquiry
+Employer
+Occupation
+SELF EMPLOYED
+HOUSE CLEANE
+Charges
+No.
+1
+Charge Description
+Class Court
+DISP
+TRAFFICKING IN ILLEGAL DRUGS
+28 GRAM TO 30
+F1
+31
+Bond
+$25,000.00
+BP
+B
+Report #
+CT-Case #
+Date
+04/04/2016
+Agency
+TPD
+OBTS Number
+Remark
+METH
+BD SET $25000
+IN JAIL
+•
+No.
+2
+Charge Description
+Class Court
+DISP
+Bond
+FELONY PETIT THEFT
+F3
+31
+$10,000.00
+BP
+B
+Report #
+CT-Case #
+Date
+Agency
+TPD
+OBTS Number
+Remark
+BD INCR $10000
+No.
+3
+Charge Description
+Class
+Court
+DISP
+Bond
+BP
+RESISTING OFFICER WITHOUT
+VIOLENCE
+M1
+31
+$500.00
+B
+Report #
+CT-Case #
+Date
+Agency
+OBTS Number
+Remark
+No.
+4 VOP
+Charge Description
+Class Court
+NN
+31
+DISP
+Bond
+$0.00
+BP
+B
+Report #
+CT-Case #
+Date
+Agency
+OBTS Number
+Remark
+PC/VOP FELONY PETIT THEFT
+formation provided should be relied upon for any type of legal actio
+© 2016 Hilborough County Sheriffs Office all rights reserved
+Hearing 10/19/16
+Defense counsel-Julion Hayes
+Prosecubor Camaria Pettis- Mackle,,
+
+Address
+Fine
+Custody Charge
+Days
+Count
+192
+1
+Charge
+PROBABLE
+CAUSE
+Charge Code
+DRUG3914
+CRA Number
+Fine
+Custody Charge Charge
+Days
+Count
+Type
+192
+PROBABLE
+CAUSE
+Charge Code
+THEF7001
+CRA Number
+Fine
+Custody Charge Charge
+Days
+Count
+Type
+192
+1
+PROBABLE
+CAUSE
+Charge Code
+CRA Number
+Fine
+Custody Charge Charge Type
+Days
+Count
+192
+Charge Code
+VIOL OF
+PROBATION
+CRA Number
+http://www.hcso.tampa.fl.us/Publiclnquiry/ArrestInquiry/ViewArrest?id=16012899&k1=8d3f38... 10/13/2016
+
+
+Filing #
+E-Filed 04/12/2016 02:51:08 PM
+CASE NUMBER
+DIVISION
+IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT OF THE
+STATE OF FLORIDA IN AND FOR HILLSBOROUGH COUNTY
+CIRCUIT CRIMINAL DIVISION
+APR 12 2016
+- SPRING Term, 2016
+INFORMATION FOR:
+COUNT ONE
+TRAFFICKING IN
+AMPHETAMINE
+(28 TO 200 GRAMS)
+F.S. 893.135 (1) (E) 1b
+IN THE NAME AND BY THE AUTHORITY OF THE STATE OF FLORIDA, MARK A. OBER, STATE
+ATTORNEY OF
+THE THIRTENTH JUDICIAL CIRCUIT IN AND FOR THE COUNTY OF
+HILLSBOROUGH, CHARGES THAT:
+COUNT ONE
+in the County of Hillsborough and State Of Florida, did knowingly,
+unlawfully, and feloniously be in actual of constructive possession of
+twenty-eight (28) grams or more but less than 200 grams of Amphetamine as
+described in Section 893.03(2) (c)2, Florida Statutes, or Methamphetamine as
+described in Section 893.03(2) (c) 4, or of any mixture containing Amphetamine
+or Methamphetamine, or Phenylacetone, Phenylacetic acid or Pseudoephedrine or
+Ephedrine in conjunction with other chemicals and equipment utilized in the
+manufacture of Amphetamine or Methamphetamine, Contrary to the form of the
+statute in such cases made and provided, and against the peace and dignity
+of the State of Florida.
+
+Information
+
+
+COUNTY OF HILLSBOROUGH
+Personally appeared before me the undersigned Assistant State Attorney of the
+Thirteenth Judicial Circuit in and for Hillsborough County, Florida, who,
+being first duly sworn, says that this prosecution is set forth in the
+foregoing INFORMATION are based upon facts that have been sworn to as true by
+the material witness or witnesses for the offense and which, if true, would
+constitute the offense therein charged, and that the prosecution is being
+instituted in good faith.
+Assistant State Attorney of the
+Thirteenth Judicial Circuit in and
+For Hillsborough County, Florida
+Florida Bar #
+
+Sworn to and subscribed before
+me at Tampa, Florida
+This
+12th
+- day or April
+, 2016
+ARE SHIRP. Maxy Public - Stat
+Shit A MCas Borida
+Commission # FF 905505
+Expires September 7, 2019
+Dondes Thru Teny Fain Insurance 800-385-7019
+Print,
+_Type or Stamp Conmissioned Name of Notary
+And Date Commission Expires
+Personally known
+or Produced Identification
+Type of Identification Produced
+April 11, 2016
+JAMES I ROBERTS/jIk
+Parent
+(Open)
+
+
+
+Include N/A
+Consolidate N/A
+Agency:
+Tampa Police Department
+Page 3 02 1
+
+
+COUNT ONE
+TRAFFICKING IN
+AMPHETAMINE
+(28 TO 200 GRAMS)
+F.S. 893.135 (1) (E) 1b
+1ST DEGREE FELONY
+DRUG7906
+Page 1081
+
+
+GOD
+MARK A. OBER
+STATE ATTORNEY
+419 N. Pierce Street
+TAMPA FLORIDA 23602
+Notice to Clerk of Factors Relating to Division Assignment
+in accordance with Circuit Criminal Administrative Order
+Date:
+To:
+From:
+April 11, 2016
+Clerk of Court
+SAO Personnel
+Defendant's Name:
+Case Number:
+Division Proposed by Clerk: D
+Case should be assigned to the Proposed Division that has already been assigned by the Clerk because none
+of the following exceptions apply.
+-EXCEPTIONS-
+1 accordance with the current administrative order governing assignment of cases in the Circuit Criminal Divisio
+lease assign a division based on the following exceptions to the proposed division case assignmen
+Case meets the Drug Court criteria and therefore should be assigned to Division "Y."
+Case meets the Veterans Court criteria and therefore should be assigned to Division " "
+Defendant has multiple proposed divisions. Earliest assigned proposed division is
+_x Defendant has Pending Case with lowest pending case #:
+; Division
+B
+Co-Defendant has multiple proposed divisions. Earliest assigned proposed division is
+Co-Defendant has Pending Case with lowest pending case #:
+; Division
+Case is re-filed after SAO dismissed it. Original case assigned to Division
+Associated Cases:
+Page 1 of 1 Notice of Division
+
+
+Filing
+E-Filed 05/11/2016 02:33:12 PM
+IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
+OF STATE OF FLORIDA IN AND FOR HILLSBOROUGH COUNTY
+CIRCUIT CRIMINAL DIVISION
+VS
+DIVISION: B
+NOTICE OF DISCOVERY
+THE STATE OF FLORIDA, in response to defense counsel's written Request
+for Discovery, pursuant to Rule 3.220 Florida Rules of Criminal Procedure,
+furnishes the following information:
+1.
+Pursuant
+to Rule
+3.220(b) (1)(i), Florida Rules of Criminal
+Procedure, the names and addresses of all persons known to the State of Florida
+to have
+information
+1 which may be relevant to the offense charged or any
+defenses thereto or to any similar fact evidence to be presented at trial under
+F.S. 90.404 (2) are as follows:
+Al1
+F.R.CR.P.:
+other Category A Witnesses pursuant to Rule 3.220 (b) (1) (A) (i),
+STEPHEN HANILY,
+QUALIFIED AS EXPERT CHEMIST
+OFFICER
+QUALIFIED AS FIELD NARCOTICS INVESTIGATION EXPERT
+2.
+Below is a list of the information and material within the State's
+possession or control which will be produced for defense counsel to inspect,
+copy, test and photograph:
+A)
+Pursuant to Rule 3.220 (b) (1) (B), Florida Rules of Criminal Procedure,
+Statements by persons whose names are furnished in compliance with Rule
+3.220 (b) (1) (i), Florida Rules of Criminal Procedure.
+NONE.
+B)
+Pursuant to Rule 3.220(b) (1)(C), Florida Rules of Criminal Procedure,
+written, recorded and/or oral statements of the accused.
+NONE.
+
+- -
+= -.
+
+
+C)
+D)
+E)
+F)
+G)
+H)
+I)
+J)
+Pursuant to Rule 3.220(b) (1)(D), Florida Rules of Criminal Procedure,
+written recorded and/or oral statements of the co-defendants.
+NONE.
+Pursuant to Rule 3.220 (b) (1) (E),
+Florida Rules of Criminal Procedure,
+recorded Grand Jury minutes containing testimony of the accused.
+NONE.
+Pursuant to Rule 3.220 (b) (1) (F),
+Florida Rules of Criminal Procedure,
+tangible papers or objects obtained from or belonging to the accused.
+YES. Methamphetamine.
+Pursuant to Rule 3.220(b) (1)(G), Florida Rules of Criminal Procedure,
+material or information provided by a confidential informant.
+NONE.
+Pursuant to Rule 3.220 (b) (1)(H), Florida Rules of Criminal Procedure,
+electronic surveillance, pursuant to Chapter 934, Florida Statutes, of the
+premises of which the accused was a party, and documents relating thereto.
+NONE.
+Pursuant to Rule 3.220(b)(1)(I), Florida Rules of Criminal Procedure,
+whether there has been any search or seizure and any documents relating
+thereto.
+NONE.
+Pursuant to
+Rule 3.220(b) (b) (J), Florida Rules of Criminal Procedure,
+reports or statements by experts, including results of physical or mental
+examinations and of scientific tests, experiments or comparisons.
+YES. EDLE results & reports are being furnished via email. Field Reagent
+Stephen Hanily is qualified as Expert Chemist. Sigure R. O'Neal
+is qualified as Field Narcotics Investigation Expert.
+Pursuant to Rule 3.220(b) (1) (K), Florida Rules of Criminal Procedure,
+tangible papers or objects intended for use at hearing or trial which were
+K)
+L)
+NONE.
+Pursuant to Rule 3.220 (b) (1) (L),
+Florida Rules of Criminal Procedure, any
+tangible paper,
+objects or substances in the possession of law enforcement
+that could be tested for DNA.
+NONE.
+Pursuant to Rule 3.220(1) (b) (M), Florida Rules of Criminal Procedure,
+whether the state has any material or information that has been provided by
+an informant witness.
+NONE.
+Page 2
+0f4
+.....
+
+
+3.
+Pursuant to Rule 3.220(b) (2), Florida Rules of Criminal Procedure,
+the following material information is within the State's possession or control
+which tends to negate the guilt of the accused as to the offense charged:
+NONE.
+4.
+In addition, please be advised that any information contained in
+reports or other materials provided to you pursuant to your request for discovery
+is deemed to be included in this response even if not specifically noted above.
+5.
+At a time mutually convenient to the State of Florida and defense
+counsel, the State
+will disclose to defense counsel and permit him to inspect,
+copy:
+test and photograph all information and material within the State's
+possession and control pursuant to Florida Rules of Criminal Procedure
+3.220 (b) (iii) through (xi).
+6.
+Pursuant to Rule 3.220(d) (1), Florida Rules of Criminal Procedure,
+the State of Florida expects a written list of the names and addresses of all
+witnesses whom defense counsel expects to call as witnesses at the trial or
+hearing of this case within seven days after receipt of the witness list
+furnished by the State of Florida.
+7.
+Pursuant to Rule 3.220 (d) (2), Florida Rules of Criminal Procedure,
+the State of Florida expects a disclosure of the items set forth in subsections
+(i)-(iii) of Rule 3.220(d) within fifteen days after the corresponding disclosure
+by the State of Florida.
+8. In addition to the above, be advised of the following: A copy of TPD
+agency report number 2016-00190882 is being furnished via email.
+Scoresheet
+previously provided. Regarding statements of the accused see law
+enforcement
+reports and interview witnesses listed.
+All witnesses listed in police report
+and additional witnesses may be called to testify.
+
+--
+
+
+I HEREBY CERTIFY that a copy of the foregoing Notice of Discovery has
+been furnished by email to JULIAN A HAYES, JHAYES@HAYESATTORNEY.COM, P O BOX
+271682, TAMPA, FL 33688, attorney for defendant, COURTNEY ELIZABETH MOODY, this
+10th day of May, 2016.
+Respectfully submitted,
+MARK A. OBER
+STATE ATTORNEY
+LS/CAMARTA Z PETTIS-MACKLE
+CAMARIA 4. PEWIS-MACKLE
+ASSISTANT STATE ATTORNEY
+FLORIDA BAR# 66243
+STATE ATTORNRYIS OFRICE
+TAMPA,
+FL 33602-4022
+CZPM/njb
+
+.....
+
+
+GENCY NAME
+TAMPA
+PA REPORT: 16-190881
+Use Ballpoint Pen
+Press Firmly
+CRIMINAL REPORT AFFIDAVIT / NOTICE TO APPEAR
+COURT CASE/
+J.F. ID #
+AGENCY REPORT #
+SAO •
+AGENCY NAME TAMPA PA ORIA
+DATE OF
+OFFENSE
+OBTS•
+ADMINISTRATION
+LOCATION
+OFFENSE
+WITHIN:
+COURT:
+TAMPA COURT PLANT CITY CT O
+LOCATION O
+ARREST
+TIME OF
+OFFENSE
+TAMPAJO PLANT CITY O TEMPLE TERRACE O UNINCORPORATED AREA O SUPPLEMENTAL CRA ATTACHED D
+DATE OF
+ARREST
+BOOKING #
+SOID •
+WEAPON
+TYPE
+TIME OF
+ARREST
+WEAPON
+SEIZED
+Yes • No Jel
+ARREST
+• Probable Cause Adult
+• Capias
+• Juvenile
+• Fugitive Warrant C Delinquency
+TWOP/VOCC
+• Dependency
+• Warrant
+Brelony
+• Juvenile Pickup
+• Misdemeano
+REQUEST FOR:
+• Traffic MISD
+• Direct File/SAO
+• Traffic FEL
+Review
+• Ordinance
+• Warrant
+• Pickup
+• Summons
+• Other
+• Juvenile Pickup
+NOTICE TO APPEAR:
+• Arresting officer
+• Booking supervising officer
+NAME
+RACE:
+W-Whit
+Race
+LOCAL ADDRESS (Street, Apt. 4, Cly, State, Zp) A7
+Permanent Address (Street, Apt. #, City, State, Zip)
+Business Address (Street, Apt. 8, City, State, Zip)
+Dri
+No.
+State
+Gang Member: Yes • No
+Gang Name
+SCARS, MARKS, TATOOS,
+UNIQUE FEATURES (Los, Type, Desc.),
+IF JUVENILE:
+School Name
+Mother/Guardian
+Father/Guardian
+Released To: JACO
+Parent O
+Guardian O
+LARGE
+Ph #g
+SS #
+PLACE
+BIRTH.
+DOCT
+n371
+AVAILO
+_ Address
+_ Address
+Other Relationship O
+i2l Wd
+Ph a
+Ph 1:00
+• Other.
+Co-Defendant (Last, First, Middle
+Arrested O
+Co-Defendant (Last, First, Middle
+Arrested O
+At Large O
+At Large O
+Sex:
+Capias/Warrant Requested O
+Felony O
+Sex:
+Caplas/Warrant Requested O
+Felony O
+Race:
+Misdemeanor O
+Race: -
+Misdemeanor O
+DOB
+Juvenile O
+DOB
+Juvenile O
+STATUTE (subsec.) / ORD #
+948,06
+DV
+CP
+CHARGE
+BOND
+STATUS
+SET
+-
+-
+CHARGE
+VOP FELONY
+PETIT THEET
+TRAFFIC
+GHATION #
+DRUG
+ACT/TYPE
+CHARGE STATUS: F-Felony M-Misdemeanor
+T-Traffic O-Ordinance FT-Felony Traffic DV-Domestic Violence CP-Child Present
+ACTIVITY: N-N/A P-Possess
+S-Sell B-Buy
+T-Traffic
+R-Smuggle
+D-Deliver E-Use K-Dispense/Distribute M-Manufacture/Produce/Cultivate Z-Other
+Type: N-N/A A-Amphetamine B-Barbiturate C-Cocaine E-Heroin H-Hallucinogen M-Marijuana O-Opium/Deriv. P-Paraphemalia/Equipment S-Synthetic U-Unknown Z-Other
+A LIST OF TANGIBLE EVIDENCE (If none, write "None") (Evidence List must be provided for all NOTICES TO APPEAR)
+DESCRIPTION/AMOUNT PER UNIT
+RECOVERED BY
+GIVEN TO
+PRESENT LOCATION
+NOTICE TO APPEAR
+EVIDENCE LIST
+CHARGE(S)
+CO-DEFENDANT(S)
+Mandatory Appearance in Court O
+You need not appear in Court, but must comply with instructions on Reverse Side. D
+COURT INFORMATION: You must appear in County Court at the:
+COURTHOUSE TOWER ANNEX, 801 E. TWIGGS STREET O
+COUNTY OFFICE BUILDING, MICHIGAN & REYNOLDS STREET O
+(Comer of Jefferson & Twiggs Street), TAMPA, FLORIDA 33602
+PLANT CITY, FLORIDA 33566
+Division
+COURTROOM #
+_ ON
+20
+.. AT
+_am. O p.m. O
+I agree to appear at the time and place designated above to answer for the offense(s) charged or to pay the fine subscribed. I understand hat if I willfully fail to appear before
+the Court as required by the Notice to Appear, I may be held in contempt of Court and a warrant for my arrest shall be issued. You mar
+also be charged with the crime of
+Failure to Appear, F.S. 843.15. I certify that my address as listed above is correct and I further understand that I have a continuing duty To advise the Court of any changes
+in my address as set forth above.
+Signature ol Delandant tearie
+Pare or Castlen i kno
+
+
+AGENCY REPORT
+AGENCY NAME TAMPA PO
+State facts to establish probable cause that a crime was committed by the defendant or that the child is dependant.
+VOTIARS
+THE DEFENDANT
+WAS
+ARRESTED
+FOR
+DET
+ET THEY WHICH
+DIABATTAN WHICH STARTED
+VALA THE DOC WEBSETE
+IS LOAS VERIFIED
+AGENCY NAME _
+DA
+PD
+REPORT = 16-190881
+PROBABLE CAUSE STATEMENT
+VICTIM NOTIFICATION
+WITNESSES
+DEF ID VERBALLY A VA BOOMING PHOTO
+Judgement requested against defendant for agency investigative cost per Florida Statute 938.27: $ _
+OFFICER -
+I.D. #
+_ Dist. & Squad
+Tease Print The Above Informadon)
+SWORN TO AND SUBSCRIBED BEFORE ME THIS
+LL DAY OF-
+EPRIL
+POLICE RE
+OFFICER
+Dist. &
+Squad
+I SWEAR THAT THE ABOVE STATEMENTS ARE CORRECT TO THE BEST OF MY
+KNOWLEDGE. FOR NOTICES TO APPEAR, I ALSO CERTIFY THAT A COMPLETE
+LIST OF WITNESSES,
+D EVIDENCE KNOWN TO ME IS ATTACHED.
+MAMEN of Parson AusTi
+AFFIANT, Spree -
+AFFIANT, Praw/Type Name
+NOTE: The WHITE COPY of VICTIM'S / WITNESSES goes to the Clerk's Office ONLY
+on Notices To Appear. In all other cases, it should be removed. The Jail or JAC
+personnel will determine this for all defendants turned over to them. In all Notices
+To Appear issued by the Arresting Officer, the Arresting Officer should leave the
+WHITE copy of VICTIM'S / WITNESSES attached.
+CLERK OF COURT
+SAO FORM-425. 10/03
+Д-
+WITNESS STATUSA
+C
+TATUS
+Made
+Date of Been
+TAMPA
+Ft
+35612
+Phone
+STATUS
+Last
+First
+Face
+Ser
+Date of Beh
+Home Adiese (Dreet, Apartment Number)
+Cly
+Sule
+Phones
+Business Address (Street, Apartment Number
+Scale
+Phone
+STATUS
+Last
+Fired
+MOSH
+Race
+Sar
+Dale of Bith
+Home Airess (Brat, Apart Number
+City
+Sale
+Zipesce
+Phone
+Business Address (Breet, Apartmans Number
+Cly
+Stame
+Phone
+STARS
+First
+Mase
+Race
+Ser
+Date of Bit
+Home Address (Street Apartment Mumber
+Cly
+Дросси
+Phone
+Business Addres Seal, Apartmert Number!
+State
+Ipende
+Phone
+STATUS
+Last
+FirM
+Place
+Date a Bos
+Home Actress (Some. Aparters Number)
+Siate
+Fice
+Busines Addren (Street, Apertment Number
+Cly
+Sate
+Phone
+STATUS
+Last
+Firet
+Mate
+Rase
+Sex
+Das of Bie
+Horse Actreme (Shot, Apartment Number)
+City
+Sate
+Phone
+Bushes Alone (bow, Apartart Number)
+
+
+NEXT COURT DATE:
+5-2
+TECHNICAL VRO
+DIVISION B COURT ACTION CHECKLIST
+X REPORT CONTAINS CONFIDENTIAL INFORMATION
+JUDGE: Christopher C. Sabella
+P.O.:
+OFFICE: 133 TAMPA N.E.
+OFFENDER|
+DC#
+TERMINATION DATE: 12.16.2017
+VFOSC noted on VR, Affidavit & Warrant C
+SUSPENDED SENTENCE YES • NO
+**JLA ELIGIBLE YES • NOD
+ACTION REQUESTED
+• SIGN WARRANT
+• CRA ARREST- FILE AFFIDAVIT
+• PSI: RETURN DATE TO COURT:
+• Technical Notification Letter
+• Judge to Review
+] Modification
+] Early Termination
+• Other:
+• File Amended Affidavit
+# PRIOR VIOLATIONS 1
+SENTENCING DATE:
+2016 APR 14 AM 9: 53
+CLERK OF LEDIT COUT
+OFFICER CERTIFICATION (V ALL APPLICABLE)
+• WARRANT: ORIGINAL ONLY
+X AFFIDAVIT: ORIGINAL & 1 COPY
+MODIFICATION ORDER: ORIGINAL ONLY
+| VR, ADDENDUM VR, LETTER: ORIGINAL ONLY
+PSI: ORIGINAL ONLY
+(100.
+OFFICERAAGTALS
+SUPERVISOR INITIALS & DATE
+RECEIVED
+4PR 1 22016)
+3-C COURT UN
+INTAKE USE ONLY
+ATTENTION JUDICIAL ASSISTANT: ONCE PROCESSED
+X DELIVER TO CLERK
+•RETURN TO DEPARTMENT OF CORRECTIONS
+Revised 04/21/2015
+
+
+DEPARTMENT OF CORRECTIONS
+AMENDED AFFIDAVIT VIOLATION OF PROBATION
+Docket
+DC#:
+NAME:
+Judge
+SABEL
+Before me this day persona
+y appeared NAi
+duly sworn says that
+offender was sentencea
+accordance with
+Florida Statutes, as follows:
+Offense
+Date
+Offense
+Sentence
+Date
+County
+11/09/2015 FELONY PETIT THEFT 12/17/2015 HILLSBOROUGH
+LIE M. HOLTON who, being first
+i hereinatter referred to as the
+he provisions of Chapter 948,
+Case Number
+Ct. 1
+Supervision
+Length
+---------
+000X 24M 00D
+Affiant states that the offender was instructed on the conditions of
+Probation on 12.17.2015 and 2.25.2016 by the Court.
+Affiant further states that the offender has not properly conducted herself,
+but has violated the conditions of her Probation in a material respect by:
+Violation of Special Condition (1) of the Order of Probation, by failing
+to
+successfully complete or remain in
+substance abuse residential treatment
+until the provider determines that
+residential treatment is no longer
+necessary,
+for belief
+that
+the offender violated her. o
+probation,
+states
+that
+offender
+failed to successful
+complete the
+às
+50Lp
+Under penalties of perjury, I declare that
+and that the facts stated in it arg
+I have read the foregoing doc
+2016 APR 145
+AM
+FILED
+CLERK CF CUCU
+Officer,
+THIS AFFIDAVIT MUST BE NOTARIZED OR ATTESTED IO UNDER S. 117.10 OR 92.50,
+Florida Statutes
+Sworn to and subscribed before me this 7* (day) of April (month), A.D. 2016
+(year) by
+identification
+who is personally known to me or has produced
+Signature
+Statutes
+Otting officer Under S. 117
+Title:
+Cess Florida
+OR
+Notary Public
+State of Florida at Large
+for Hills
+rough County
+Approved by
+supervisor:
+Date:
+4-816
+Officer
+Telephone/E-Mail Address
+
+
+Docket #:
+NAME:
+Judge/Division: SABELLA/B
+Violation of Condition (3) of the Order of Probation, by changing her
+residence without first procuring the co
+sent of the probation officer, and
+as grounds for belief that the oftender Lolated her probation, Officer
+Holton states that on or about 3.24.2016, the offender did move from her last
+known place of residence at
+Tampa, Florida 33605, without procuring the consent of the probation officer,
+as told to
+and ner
+current whereabouts is unknown.
+Amended
+Violation of Condition (5) of the Order of Probation, by failing to live
+without violating any law by being arr
+ted for
+Felony Petit Theft (Hillsborough County Case
+the crimina
+offense
+in
+Hillsborough County, Florida, and as
+Grounds
+for beliet that the offende:
+violated he
+I probation,
+states that the offender was arrested
+on
+for the said
+ortense bi
+rampa Police Department
+as told to Officer Holton by Criminal Report Affidavit
+Violation of Condition (5) of the Order of Probation, by failing to live
+without violating any law by being arrested for the criminal offense of
+Resist Arrest Without Violence (Hillsborough County Case
+in Hillsborough County, Florida, and as grounds for belief that the
+offender violated her probation,
+Officer Holton states that the offender was
+arrested
+on 4.4.2016, for the said offense by Tampa Police Department Officer
+as told to
+by Criminal Report Affidavit
+Violation of Condition (5) of the Order of Probation, by failing to live
+without violating any law by being arrested for the criminal offense of
+Trafficking in Illegal Drugs - 28 to 30 Grams (Hillsborough County Case
+in Hillsborough County,
+beliel that
+the offender
+Department
+Affidavit
+the
+offender violated her probation,
+lorida.
+as grounas
+states that
+arrested
+for
+the said offense by Tampa Police
+as told to
+by Criminal Report
+IOr
+Violation of Condition (7) of the Order of Probation, by using intoxicants to
+excess or possessing any drugs or narcotics, unless prescribed by a
+physician,
+as arounds for belief that the offender violated her
+probation,
+states that the offender was arrested on
+for the oftense of Tratticking in Illegal Drugs - 28 to 30 Grams
+rough County Casi
+by Tampa Police Department
+as told to
+Criminal Report Affidavit
+2
+
+
+Docket #:
+DC#:
+NAME:
+Judge/Division: SABELLA/B
+Witnesses
+Correctional Probation Senior Officer
+Florida Department of Corrections
+7402 N. 56° Street,
+Suite 750
+Tampa, Florida 33617
+Tampa Police Department - District II
+9330 N. 30"* Street
+Tampa, Florida 33612
+3
+
+
+DEPARTMENT OF CORRECTIONS
+ADDENDUM TO VIOLATION REPORT DATED 4.1.2016
+**Report Contains Confidential Information**
+Date: 4.7.2016
+NAME Honorable Judge Christopher C. Sabella EE No:
+Circuit: TAMPA N.E.
+Case No:
+Scheduled Termination Date: 12.16.2017
+REQUESTING
+Warrant for Arrest Requested / Served 4.4.16
+TYPE OF REPORT
+Non-Compliance with Conditions / New Felony and Misdemeanor Charges
+2016 APR 14 AM 9:53
+CLERK OFEEDIT COURT
+LOCATION
+Absconder - Last Known Address:
+In Custody - Current Address:
+Tampa,
+Florida 33605
+Orient Road Jail
+1201 N. Orient Road
+Tampa, Florida 33619
+1) HOW VIOLATION OCCURRED: On 2.25.2016, the offender appeared before Your
+violation of probation and was ordered to enter and successfully
+Honor on
+complete
+3.24.2016,
+this
+officer
+was
+informed by
+Support Services
+Supervisor
+at
+that the offender had eloped from the
+facility.
+No staff members
+witnessed the offender leave. An emergency count
+was conducted and the offender was not present. Her current whereabouts are
+unknown, and she is considered
+an absconder by the Department of Corrections.
+at approximately 1057 hours, at the Walmart located at
+1720 E. Hillsborough Avenue, Tampa, Florida 33610, the offender concealed
+$21.26 worth of items in her bag and attempted to bypass all means of
+payment. Theft Prevention staff attempted to stop the offender and a
+struggle ensued.
+The offender was taken into custody and charged with Felony
+Theft and Resist Arrest Without Violence (Hillsborough County Casel
+Incident to arrest, the offender attempted to discard a
+
+
+plastic baggie containing a white,
+crystal-like substance which appeared to
+be methamphetamine.
+The substance field tested positive for methamphetamine,
+and the baggie weighed approximately 30 grams.
+At that point, the offender
+was also charged with Trafficking in Illegal Drugs - 28 to 30 Grams
+(Hillsborough County Case
+2) OFFENDER STATEMENT:
+The
+offender has absconded from supervision and is
+not available to provide a statement.
+3) HISTORY OF SUPERVISION:
+Current Community Supervision History
+Offense
+Date
+Offense
+Sentence
+Date
+County
+Case Number
+11/09/2015 FELONY PETIT THEFT 12/17/2015 HTLLSBCROUGH
+15-CF-016193 Ct. 1
+Supervision
+Length
+000Y 24M 00D
+Prior Community Supervision History
+of tense
+Sentence
+Offense
+Date
+• NO PRIOR HISTORY OF SUPERVISION-
+County
+Case Number
+Supervision
+Length
+Prior Violation of Supervision
+Date of
+Date of
+Violation
+Type of Violation
+Disposition
+Disposition of Violation
+------
+01/06/2016 VIOT-TECHNICAL VIOLATION 02/25/2016
+REINSTATED, MODIFIED
+RESIDENCE: The offender has absconded from supervision.
+EMPLOYMENT:
+The offender is unemployed.
+RESTITUTION:
+Case
+Number
+Payee Name
+- NO RESTITUTION ORDERED**
+Original
+Obligation
+Current
+Balance
+Amoust Paymente
+Date
+2
+
+
+COURT COSTS/FINES:
+Case
+Number
+-------
+Payee Name
+1516193 HILLSBOROUGH CO CLERK OF COURT
+Original
+Obligation
+$577.00
+Current
+Balance
+$577.00
+Last Payment
+Amount
+Date
+$.00
+OTHER:
+Payee Name
+DC DRUG TESTING
+COST OF SUPERVISION
+SURCHARGE
+Original
+Obligation
+Balance
+$30.00
+$30.00
+5960.00
+$840.00
+$62.68
+$57.88
+Current
+Amount
+$.00
+3.00
+Last Payment
+Date
+PUBLIC SERVICE WORK:
+Monthly minimum
+Hours Required Hours Ordered Hours Worked Hours Remaining
+.00
+50.00
+.00
+50.00
+TREATMENT STATUS:
+Treatment
+Date
+Program Description
+03/02/2016 NON-SECURE RESIDENTIAL
+Termination
+Date
+03/24/2016
+Status
+UNSUCCESSFUL
+Termination Reason
+UNEXCUSED ABSENCE
+STATUS OF OTHER SPECIAL CONDITIONS:
+Case
+Number
+Special Condition
+1516193 RESIDENTIAL SUB ABUSE TREATMNI
+1516193 COS WAIVED
+1516193 COURT COSTS/FINES
+1516193 NO ALCOHOL/ILLEGAL DRUGS
+1516193 PUBLIC SERVICE HOURS
+1516193 MAINTAIN FULL-TIME EMPLOY/SCHI
+1516193 MAY APPLY FOR EARLY TERM
+1516193 AFTERCARE
+1516193 OTHER
+Begin Date Due Jate
+02/25/2016 12/16/2017
+12/17/2015 12/16/2017
+12/17/2015 12/16/2017
+02/25/2016 12/16/2017
+12/17/2015 12/16/2017
+02/25/2016 12/16/2017
+12/17/2015 12/16/2017
+02/25/2016 12/16/2017
+02/25/2016 12/16/2017
+End Date
+Status
+IN VIOLATION
+NOT COMPLETED
+NOT COMPLETED
+NOT COMPLETED
+NOT COMPLETED
+NOT COMPLETED
+NOT COMPLETED
+NOT COMPLETED
+NOT COMPLETED
+4) RECOMMENDATION: YU: Honor, this officer is requesting that a warrant be
+issued for violation of probation.
+The offender has absconded from DACCO
+Residential and her current whereabouts is unknown. This is the second
+violation for the current term of supervision.
+This officer would recommend,
+upon apprehension, that the offender be sentenced to 364 days specified
+residency county jail, suspended upon completion of the in-jail substance
+abuse treatment program and bed space availability at DACCO Residential.
+advised that the offender was welcome back
+to the program after 60 days.
+3
+
+
+...
+Amended: Your Honor, because of the two new felony and one new misdemeanor
+charges, this officer would recommend that the current term of supervision be
+revoked and the offender be sentenced to 364 days specified residency county
+jail (suspended upon completion of the in-jail substance abuse treatment
+program and bed space availability at
+I followed by 12
+months community control followed by 36 months drug offender probation.
+ect to the best of my knowledge and belief.
+APPROVED:
+4
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/9f8b7e8fb6da428a52674dc329231449a1dbd136981980146c9632516ef52fa5.receipt.json b/vision-fixhub/ds9-unparsed-05/9f8b7e8fb6da428a52674dc329231449a1dbd136981980146c9632516ef52fa5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..bb8dcf18b97124bf48544f46c2892f0e7b9fd305
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9f8b7e8fb6da428a52674dc329231449a1dbd136981980146c9632516ef52fa5.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -502,
+  "dataset": "marble-joined",
+  "doc_id": "9f8b7e8fb6da428a52674dc329231449a1dbd136981980146c9632516ef52fa5",
+  "engine": "marble-apple-vision",
+  "event_count": 30,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "e1c278d932e55ba20fa38b47b3cb0377abb95752a4037131b64e0d2744184a03",
+  "output_sha256": "dffa2c07bc8777cd1dc0b9134c2f5073ef9fc1c718b03ba364facfd963b5ca4e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/9fb2248abdd61c602c3018edd4af38c0d47466fcae5dfa671ef3de28446298d3.md b/vision-fixhub/ds9-unparsed-05/9fb2248abdd61c602c3018edd4af38c0d47466fcae5dfa671ef3de28446298d3.md
new file mode 100644
index 0000000000000000000000000000000000000000..d85c1e419eab8a56d9fbf1c7b1d143c90a6b556e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9fb2248abdd61c602c3018edd4af38c0d47466fcae5dfa671ef3de28446298d3.md
@@ -0,0 +1,230 @@
+1
+2 Epstein in town
+3
+fist call
+4 Date
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+10/2/2004
+10/4/2004
+10/5/2004
+1/19/2005
+1/19/2005
+1/19/2005
+1/20/2005
+1/20/2005
+1/20/2005
+1/20/2005
+1/27/2005
+2/1/2005
+B
+Time
+Event
+Epstein's Flight
+arrives at PBIA
+9:49:00 PM (Boeing 727)
+12:34:00 PM Call
+Epstein's Flight
+departs from PBIA
+8:02:00 AM (Boeing 727)
+6:02:00 PM Call
+8:36:00 PM Call
+Epstein's Flight
+arrives at PBIA
+11:52:00 PM (Boeing 727)
+12:32:00 PM Call
+12:51:00 PM Call
+1:19:00 PM Call
+1:23:00 PM Call
+Epstein's Flight
+departs from PBIA
+7:46:00 PM (Boeing 727)
+11:16:23 AM Call
+D
+E
+From
+To
+1201-0247
+BLUE ME
+GILGER 30E
+F
+Call
+length/message
+info/Passengers
+0:01:00
+0:01:00
+0:01:00
+0:02:00
+0:01:00
+0:01:00
+0:01:00
+0:02:04
+
+
+1
+2 Epstein in town
+3 First call
+D
+E
+F
+4 Date
+Time
+Event
+From
+To
+Call
+length/message
+info/Passengers
+22
+23
+24
+25
+26
+27
+28
+213/2005
+2/3/2005
+217/2005
+2/10/2005
+2/14/2005
+2/14/2005
+2/15/2005
+Epstein's Flight
+arrives at PBIA
+12:40:00 AM (Boeing 727)
+3:28:00 PM Call
+Epstein's Flight
+departs from PBIA
+5:39:00 AM (Boeing 727)
+Epstein's Flight
+arrives at PBIA
+11:54:00 PM (Boeing 727)
+3:44:43 PM Call
+4:15:30 PM Call
+Epstein's Flight
+departs from PBIA
+5:42:00 PM (Boeing 727)
+0:04:00
+Jeffrey Epstein.
+0:00:28
+0:01:36
+Ghislaine Maxwell,
+29
+30
+31
+32
+33
+3/4/2005
+3/4/2005
+9:17:42 PM Call
+9:18:02 PM Call
+0:00:04
+0:00:35
+Ghislaine Maxwell,
+34
+35
+36
+Epstein's Flight
+arrives at PBIA
+3/4/2005
+11:45:00 PM (Boeing 727)
+Epstein's Flight
+departs from PBIA
+3/8/2005
+11:42:00 AM (Boeing 727)
+
+
+1
+3
+2 Epstein in town
+4 Date
+37
+38
+39
+40
+41
+42
+43
+44
+45
+46
+47
+48
+49
+50
+51
+3/10/2005
+3/18/2005
+3/22/2005
+8/18/2005
+8/21/2005
+8/21/2005
+8/21/2005
+8/22/2005
+9/9/2005
+9/10/2005
+9/11/2005
+B
+C
+D
+E
+Time
+Event
+11:00:00 AM Call
+Epstein's Flight
+arrives at PBIA
+12:48:00 PM (Boeing 727)
+Epstein's Flight
+departs from PBIA
+1:07:00 PM (Boeing 727)
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+3:19:00 PM 1159B)
+11:36:00 AM Call
+11:38:46 AM Call
+11:39:00 AM Message Pad
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+3:57:00 PM 1159B)
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+12:22:00 AM 1159B)
+5:14:00 PM Call
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+2:06:00 PM 1159B)
+From
+To
+Call
+length/message
+info/Passengers
+0:01:00
+Ghislaine Maxwell
+shiev D
+Mr. J. Epstein
+0:02:00
+0:00:26
+cannot work
+today and
+, will
+be here at 4:00PM
+0:01:00
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/9fb2248abdd61c602c3018edd4af38c0d47466fcae5dfa671ef3de28446298d3.receipt.json b/vision-fixhub/ds9-unparsed-05/9fb2248abdd61c602c3018edd4af38c0d47466fcae5dfa671ef3de28446298d3.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..5f87eacc8153acd206e90956cdcbba20f121a9c1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9fb2248abdd61c602c3018edd4af38c0d47466fcae5dfa671ef3de28446298d3.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -298,
+  "dataset": "marble-joined",
+  "doc_id": "9fb2248abdd61c602c3018edd4af38c0d47466fcae5dfa671ef3de28446298d3",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "994f5541448e79e8ea4e367743d606455da8f9d99cbda95925a8d1b569556c93",
+  "output_sha256": "4a6b024fffb0892f27fe469621c1ab6c1d5244588bdcda75288c5f63933459ff",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/9fdc6f8f3b9eb0b3026033ad6ffdfc527b76844ae1bc7a80ec2cb65438dc4f38.md b/vision-fixhub/ds9-unparsed-05/9fdc6f8f3b9eb0b3026033ad6ffdfc527b76844ae1bc7a80ec2cb65438dc4f38.md
new file mode 100644
index 0000000000000000000000000000000000000000..fd7eb579e15e4acaa0ffa57bd186dd023101dbca
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9fdc6f8f3b9eb0b3026033ad6ffdfc527b76844ae1bc7a80ec2cb65438dc4f38.md
@@ -0,0 +1,552 @@
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+COPY
+RE: OPERATION LEAP YEAR
+/
+-
+-
+-
+TESTIMONY
+OF
+SPECIAL AGENT
+-
+-
+Federal Grand Jury 07-103
+Federal Building
+Courthouse
+West Palm Beach, Florida
+Tuesday,
+April 24, 2007
+APPEARANCES:
+Assistant United states Attorney
+HELENA JOSETTE JONES-PARSONS,
+Foreperson
+
+
+2
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+The sworn testimony of SPECIAL AGENT
+was taken before the
+Federal Grand Jury, West Palm Beach Division,
+Federal Building, U.s. Courthouse, 'Palm Beach
+County, State of Florida, on Tuesday, April 24,
+2007.
+Paula E. Angelocci, Certified Court
+Reporter and Notary Public, State of Florida,
+Official Reporting Service, LIC, 524 South Andrews
+Avenue, Suite 302N, Fort Lauderdale, Florida,
+33301, was authorized
+to
+and did report the
+SWOrn
+testimony.
+OFFICIAL
+REPORTING SERVICE, LLC
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+3
+(Witness enters the Grand Jury Room.)
+THE FOREPERSON: You do solemnly swear
+that the testimony you give will be the
+truth, the whole truth, and nothing but the
+truth, so help you God?
+THE WITNESS: I do.
+THE FOREPERSON: Thank you. Please be
+seated.
+EXAMINATION
+BY
+Special
+, would you
+just remind the grand jurors who you are and who
+you work for?
+A
+My name is
+and I am
+a special agent with the FBI and I work here in
+Palm Beach.
+Special Agent
+" can you tell
+the grand jurors who will be appearing before them
+this afternoon?
+A One of our victims,
+• who was a
+minor at the time that she met Mr. Epstein.
+And have you previously testified about
+A
+Yes, I have.
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+4
+Did you attempt to interview her? She's
+going to be coming in, and she is not a minor
+anymore, so what is her full name?
+A
+Her name is
+and I did
+attempt to interview
+• and
+was
+interviewed by Palm Beach Police Department and
+because of the statements she provided to the
+police department, she felt as if she needed a
+lawyer. So when I attempted to interview her, we
+ended up going through her lawyer.
+And just so the grand jury has a little
+bit of background, the interview with the Palm
+Beach Police Department was quite some time ago?
+Yes, it was, in the fall of '05.
+And when I
+started that
+conversation with the police, she was very
+forthcoming?
+A
+Yes, she was.
+Fully cooperative?
+A
+Yes.
+And what happened in the middle of that
+interview with the police?
+A
+The police just let
+know that she
+could be charged because
+brought some of the
+girls. to Mr. Epstein and the police - - she was
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+5
+very cooperative, but the police at that point had
+to let
+know that what she had done that she
+could be facing charges.
+And that was
+after they had told her
+earlier that she didn't need an attorney present,
+correct?
+A
+Exactly.
+Okay.
+So this happens to her with the
+Palm Beach Police Department and did the Palm
+Beach Police actually present or propose charging
+?
+A
+against
+They did get a probable cause affidavit
+And is that why
+1 •
+and her
+attorney were concerned about her testimony here?
+Yes.
+Now was a subpoena issued for
+on behalf of this grand jury?
+A
+Yes, it was.
+And before .
+would comply with
+that, did she -- did her attorney request some
+sort of order?
+A
+A
+Yes.
+And what did he ask for?
+He asked for immunity for
+OFFICIAL REPORTING SERVICE, LIC
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+6
+And let me show you the order, that is a
+sealed order in these grand jury proceedings. Now
+the immunity that has been provided for
+keeps her statements that are made here from being
+used against her?
+A
+Yes, it does.
+It doesn't -- if she commits perjury and
+she lies to the grand jury, can she still be
+charged?
+A
+Yes, she can.
+Okay. Could you read that? I know it
+is only two pages.
+A
+Sealed order, on application of the
+United States Attorneys
+for the Southern District
+of Florida and it appearing to the satisfaction of
+the court that
+• has been called to
+testify and to provide other information before
+the United States District Court, the Southern
+District of Florida, including a grand jury
+impaneled therein..
+And number two, that in a judgment of
+the said United States Attorneys,
+has
+refused to testify and provide other information
+on the basis of her privilege against self
+incrimination.
+OFFICIAL REPORTING SERVICE, LIC
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+21
+25
+7
+And that number three, in the judgment
+of the United States Attorneys, the testimony and
+other information from
+made necessary
+to the public interest.
+And number four, that the aforesaid
+application has been
+made with the approval of the
+Assistant Attorney General in charge of the
+criminal division of the Department of Justice or
+a duly designated acting Assistant Attorney
+General pursuant to the authority vested in him by
+Title 18, United States Code, Section 6003, and
+Title 28, Code of Federal Regulations, Section
+0.175 and 0.132, small e.
+Now, therefore, it is ordered pursuant
+to Title 18, United States Code, Section 6002,
+that
+give testimony and provide other
+information which she refuses to give or to
+provide on the basis of her privilege against self
+incrimination as to all matters about which she
+may be interrogated before said United States
+District Court including a grand jury impaneled
+therein as well as any subsequent proceeding or
+trial.
+However, no testimony or other
+information compelled under this order or any
+OFFICIAL REPORTING SERVICE, ILC
+
+
+.1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+8
+information directly or indirectly derived from
+such testimony or other information may be used
+against
+in any criminal case except
+a
+prosecution for perjury giving a false statement
+otherwise failing to comply with this order.
+It is further ordered that this order
+shall be sealed in accordance with said Federal
+Regulations Criminal.
+BY
+:
+Federal Rule of Criminal Procedure.
+A
+Federal Rule of Criminal Procedure, it's
+abbreviated, 6, little e, 6, except that a copy of
+this order shall be provided to counsel for the
+United States who may disclose the existence of
+the order to members of the grand jury, to the
+witness, to the counsel for the witness, and to
+law enforcement officers engaged in the
+investigation pending before the grand jury.
+Those persons may review the order, but
+may not retain a copy of the order nor may it
+disclose the existence of the order to any others.
+Done and ordered the 16th day of April 2007, at
+West Palm Beach, Florida. The United States
+District Judge Donald M. Middlebrook, Marie
+• AUSA.
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+9
+All right. So has a copy or has this
+document been shown to counsel for .
+?
+A
+Yes, it has.
+And to
+A
+Yes.
+And will
+be here this
+afternoon?
+A
+A
+A
+Yes, she will.
+Have you had a chance to sit with her?
+Yes, we have.
+And she has been very forthcoming?
+She's very cooperative.
+Okay.
+: I don't have any further
+questions for the witness. Do you have any
+questions? All right.
+Seeing no questions,
+you are excused and I think that right now
+you are set to come back at 1:15. How does
+1:30 sound? Is that all right?
+THE FOREPERSON: Fine.
+(Witness
+was excused.)
+
+
+10
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+CERTIFICATE OF REPORTER
+I, Paula E. Angelocci, Certified Court
+Reporter and Notary Public, do certify that the
+transcript is a true and correct transcription of
+my stenotype notes of the
+testimony of
+SPECIAL AGENT E. NESBITT KUYRKENDALL, taken before
+the Federal Grand Jury, West Palm Beach, Florida.
+Paula LAngelacci
+ANGELt Reporter
+#4869
+18
+19
+20
+21
+22
+23
+24
+25
+OFFICIAL REPORTING SERVICE,
+LLC
+(954)
+467-8204
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/9fdc6f8f3b9eb0b3026033ad6ffdfc527b76844ae1bc7a80ec2cb65438dc4f38.receipt.json b/vision-fixhub/ds9-unparsed-05/9fdc6f8f3b9eb0b3026033ad6ffdfc527b76844ae1bc7a80ec2cb65438dc4f38.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..de8b64e714685e667ffb416bb9dbc2f5cd8ab4c5
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/9fdc6f8f3b9eb0b3026033ad6ffdfc527b76844ae1bc7a80ec2cb65438dc4f38.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -416,
+  "dataset": "marble-joined",
+  "doc_id": "9fdc6f8f3b9eb0b3026033ad6ffdfc527b76844ae1bc7a80ec2cb65438dc4f38",
+  "engine": "marble-apple-vision",
+  "event_count": 11,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "d2b9254a9c714734370635ad8e4f7df1eaf106e27202bbfa541e3d96300e5cbd",
+  "output_sha256": "0c2d036fc089d4bf5b4f17a3714b4b52c39d6ee31f644b6ac7d5160e2f787772",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a13e23d5c6690340e0f60f5552915c84ab79f9a6272b12df28becfd6f0c09ac3.md b/vision-fixhub/ds9-unparsed-05/a13e23d5c6690340e0f60f5552915c84ab79f9a6272b12df28becfd6f0c09ac3.md
new file mode 100644
index 0000000000000000000000000000000000000000..b7b61991949c05778fc27cf541a6c382d8ade6c5
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a13e23d5c6690340e0f60f5552915c84ab79f9a6272b12df28becfd6f0c09ac3.md
@@ -0,0 +1,47 @@
+OLY-44
+
+
+TO: Adult Video Warehouse
+Un.ied States District Court
+SOUTHERN DISTRICT OF FLORIDA
+• SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-44
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTIS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Juryof the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+May 1, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring, with you the following document(s) or objects):
+All records and information referring or relating to a transaction completed October 3, 2004 in the
+amount of $94.21 charged to Chase Mastercard account #
+in the name of
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+• on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+April 20, 2007
+This subpoena is issued upon application
+of the United States of America
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+Fax:
+*If not applicabic, enter "none."
+To be used in lieu of ADHO
+FORM ORD-227
+JAN.86
diff --git a/vision-fixhub/ds9-unparsed-05/a13e23d5c6690340e0f60f5552915c84ab79f9a6272b12df28becfd6f0c09ac3.receipt.json b/vision-fixhub/ds9-unparsed-05/a13e23d5c6690340e0f60f5552915c84ab79f9a6272b12df28becfd6f0c09ac3.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..014aa271884afc3fec364c0a14334971c34903ef
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a13e23d5c6690340e0f60f5552915c84ab79f9a6272b12df28becfd6f0c09ac3.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "a13e23d5c6690340e0f60f5552915c84ab79f9a6272b12df28becfd6f0c09ac3",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "53e973dcdf4071348bed00744463eabce46d90ecc56c4fd7c98bf23af215c19f",
+  "output_sha256": "3529c0196acac07598a3f0e844a89fb8796faf82d9b06c4dd105541f0ff04f48",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a1597068588876dfa9e893f8f5b91d8aec0f69409d51787de905c319c98dd07c.md b/vision-fixhub/ds9-unparsed-05/a1597068588876dfa9e893f8f5b91d8aec0f69409d51787de905c319c98dd07c.md
new file mode 100644
index 0000000000000000000000000000000000000000..a7630345dd6d9ac152f51c0d429baf8e8e6db8af
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a1597068588876dfa9e893f8f5b91d8aec0f69409d51787de905c319c98dd07c.md
@@ -0,0 +1,8351 @@
+OLY
+GRAND JURY LOS
+OLY -01
+THROUGH
+OLY -50
+
+
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Fri./No. OLY-80/2
+SUBPOENA FOR:
+X PERSON
+X
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Juryof the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+April 15,2008
+1:00pm
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+ANY AND ALL NOTES, LETTERS, CARDS, GIFTS, PAYMENTS, AND PHOTOGRAPHS YOU HAVE
+RECEIVED FROM JEFFREY EPSTEIN,
+LESLEY GROFF, AND/OR |
+OR ANY EMPLOYEE OF JEFFREY EPSTEIN.
+ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIGITAL, OF JEFFREY EPSTEIN,
+LESLEY GROFF, AND/OR
+ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS, OR
+TELEPHONE MESSAGES THAT YOU HAVE SENT TO AND/OR RECEIVED FROM JEFFREY EPSTEIN,
+LESLEY GROFF, AND/OR
+Please coordinate your compliance with this subpoena and confirm the date and time of
+your appearance with Special Agent
+Federal Bureau of
+Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+March 12, 2008
+This subpoena is issued upon application
+of the United States of America
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney*
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL. 33401-6235
+
+
+SERVED ON (NAME)
+To be used in lieu of ADL10
+PLACE
+PLACE
+FORM OR
++
+SERVED BY
+TITLE
+•STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service and
+Statement of Service Fees is true and correct.
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2. "Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Fri./No. OLY-81
+SUBPOENA FOR:
+X PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+April 15, 2008
+1:00pm
+YOU ARE ALSO COMMANDED to bring with you the following document (s) or object(s):
+ANY AND ALL NOTES, LETTERS, CARDS, GIFTS, PAYMENTS, AND PHOTOGRAPHS YOU HAVE
+RECEIVED FROM JEFFREY EPSTEIN,
+LESLEY GROFF, AND/OR |
+OR ANY EMPLOYEE OF JEFFREY EPSTEIN.
+ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIGITAL, OF JEFFREY EPSTEIN, I
+LESLEY GROFF, AND/OR
+ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS, OR
+TELEPHONE MESSAGES THAT YOU HAVE SENT TO AND/OR RECEIVED FROM JEFFREY EPSTEIN,
+LESLEY GROFF, AND/OR
+Please coordinate your compliance with this subpoena and confirm the date and time of
+your appearance with Special Agent
+Federal Bureau of
+Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+HATES DISTRI
+CLERK
+DATE:
+March 12, 2008
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the United States of America
+oncUillafara
+Name, Address and Phone Number of Assistant U.S. Attorney
+, Assistant U.S. Attorney'
+S00 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+
+
+SERVED ON (NAME)
+To be used in lice of AD110
+PLACE
+PLACE
++
+SERVED BY
+TITLE
+TRAVEL
+STATEMENT OF SERVICE FEES
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service an
+statement of Service Fees is true and correc
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+GRAND JURY SUBPOENA LI
+FBI Special Agent
+FGJ 05-02 (WPB) Fridays
+Investigative No. OLY
+SUBPOENA
+SUBPOENAED PARTY
+CONTROL #
+OLY-01
+[expiration 2/1/07]
+1, AUSA
+Transferred to FGJ 07-103 (WPB) Tuesdays
+RECORDS SOUGHT
+APPEARANCE
+DATE ON
+SUBPOENA
+08/18/2006
+ACTUAL
+RETURN
+
+OLY-02
+OLY-03
+OLY-04
+OLY-05
+OLY-06
+OLY-07
+OLY-08
+OLY -09
+OLY-10
+Colonial Bank
+Attn: Anita Muller
+Research Department
+1853 Data Drive
+Носут A1 35242
+Washington Mutual
+P.O. Box 9007
+Passanion CA 94566
+Capital One
+Subpoena Compliance
+15000 Capital One Dr.
+Famond VA 23238
+Chase
+Subpoena Compliance
+7610 W Washington St
+Fatanapolis. IN 46231
+Hyperion Air, Inc.
+103 Foulk Rd, Ste 202
+Wilmington, DE 19803
+JEGE Inc.
+103 Foulk Rd, Ste 202
+Wilmington, DE 19803
+David Neville Rodgers
+7318 Heathley Drive
+Lake Worth, FL 33467
+DTG Operations d/b/a
+Dollar Rent-a-car
+2401 Turnage Blvd.
+West Palm Beach, FL
+Royal Palm Beach
+Community High School
+15" Judicial District
+Acct. info. re: 1 VISA
+account and 6
+individuals
+Acct. info. re: 1 VISA
+account and 6
+individuals
+Acct. info. re: 1 VISA
+account and 6
+individuals
+Acct. info. re: 1 VISA
+account and 6
+individuals
+Flight Data
+Flight Data
+Testimony and Info
+re: flights
+Car rental agreements
+08/18/2006
+08/18/2006
+08/18/2006
+08/18/2006
+08/18/2006
+08/18/2006
+08/18/2006
+Student records
+Grand Jury Transcript
+08/18/2006
+08/18/2006
+
+
+FBI Special Agent
+FGJ 05-02 (WPB) Fridays
+Investigative No. OLY
+[expiration 2/1/07]
+SUBPOENA
+CONTROL #
+SUBPOENAED PARTY
+OLY-1012
+OLY-11
+OLY-12
+OLY-12/2
+OLY-13
+OLY-13/2
+OLY-13/3
+OLY-13/4
+OLY-14
+OLY-15
+OLY-16
+OLY-17
+OLY-18
+OLY-19
+OLY-20
+OLY-21
+State Attorney's Office
+(never
+served)
+(never
+served)
+Reimer Employment
+Agency
+Evidence Custodian
+Palm Beach Police Dept
+ustodian of Record:
+5 Judicial Distric
+Good Samaritan
+Hospital
+The Dalton School
+Extra Touch Flowers
+Bill Hammond (pilot)
+, AUSA
+Transferred to FGJ 07-103 (WPB) Tuesdays
+RECORDS SOUGHT
+Grand Jury Transcript
+none
+phones, notes, etc
+phones, notes, etc
+phones, notes, etc
+phones, notes, etc
+phones, notes, etc
+phones, notes, etc
+phones, notes, etc
+employment records
+seized evidence
+grand jury transcript
+billing records
+employment records
+records
+flight records
+employment records
+contact information
+Page -2-
+APPEARANCE
+DATE ON
+SUBPOENA
+09/15/2006
+08/25/2006
+08/25/2006
+09/01/2006
+08/25/2006
+09/01/2006
+10/27/2006
+4/17/2007
+08/25/2006
+09/01/2006
+09/01/2006
+09/15/2006
+09/22/2006
+09/22/2006
+11/17/2006
+12/01/2006
+ACTUAL
+RETURN
+w/drawn
+
+w/drawn
+
+
+FBI Special Agent
+FGJ 05-02 (WPB) Fridays
+Investigative No. OLY
+SUBPOENA
+SUBPOENAED PARTY
+CONTROL #
+OLY-22
+OLY-23
+OLY-23-2
+OLY-24
+OLY-24-2
+OLY-25
+OLY-26
+OLY-27
+OLY-28
+OLY-29
+OLY-30
+OLY-31
+OLY-32
+OLY-33
+Larry Visoski (pilot)
+Janusz Banasiak
+(property manager)
+Janusz Banasiak
+(property manager)
+(former assistant)
+(former assistant)
+Lilly Ann Sanchez
+Gerald Lefcourt
+Anthony Figueroa (pimp)
+Colonial Bank
+Palm Beach Nat'l Bank
+Western Union
+Western Union
+JP Morgan Chase
+Thomas Rofrano
+[expiration 2/1/07]
+a, AUSA
+Transferred to FGJ 07-103 (WPB) Tuesdays
+RECORDS SOUGHT
+flight records
+employment records
+contact information
+employment records
+contact informatoin
+employment records
+contact information
+employment records
+contact information
+massage appts
+employment records
+contact information
+massage appts
+Retainer Agreements
+Retainer Agreements
+phone records
+payment records
+bank records
+bank records
+wire transfer records
+wire transfer records
+bank records
+billing statements,
+record of payments,
+appointment books,
+treatment notes and
+correspondence
+APPEARANCE
+DATE ON
+SUBPOENA
+12/01/2006
+12/01/2006
+01/12/2007
+12/01/2006
+01/12/2007
+02/13/2007
+02/13/2007
+01/12/2007
+03/06/2007
+03/06/2007
+03/06/2007
+03/06/2007
+03/06/2007
+3/13/2007
+ACTUAL
+RETURN
+
+Page -3-
+
+
+FBI Special Agent I
+FGJ 05-02 (WPB) Fridays [expiration 2/1/07]
+Investigative No. OLY
+SUBPOENA| SUBPOENAED PARTY
+CONTROL #
+OLY-34
+AUSA
+Transferred to FGJ 07-103 (WPB) Tuesdays
+RECORDS SOUGHT
+billing statements,
+APPEARANCE
+DATE ON
+SUBPOENA
+3/13/2007
+ACTUAL
+RETURN
+
+OLY-35
+OLY-36
+OLY-37
+OLY-38
+Palm Beach County
+Health Dept.
+Perry Bard, DC
+OLY-39
+OLY-40
+OLY-41
+OLY-42
+OLY-43
+OLY-44
+OLY-45
+OLY-46
+Chase Bank USA, NA
+Attn: Jeff Sehr
+Adult Video Warehouse
+Eve's Garden
+Adult Video Warehouse
+New York Strategy
+Group, LLC
+Hyperion Air, Inc
+correspondence
+billing statements,
+record of payments,
+appointment books,
+treatment notes and
+correspondence
+Certified Birth
+Certificates
+phones, notes, etc
+billing statements,
+record of payments,
+appointment books,
+treatment notes and
+correspondence
+phones, notes, etc
+account records
+transaction records
+transaction records
+phones, notes, etc
+transaction records
+account records
+3/13/2007
+3/13/2007
+3/13/2007
+3/13/2007
+business records
+4/3/2007
+4/17/2007
+5/1/2007
+5/1/2007
+4/17/2007
+5/1/2007
+5/2/2007
+5/8/2007
+Page -4-
+
+
+FBI Special Agent
+FGJ 05-02 (WPB) Fridays
+Investigative No. OLY
+SUBPOENA
+CONTROL #
+SUBPOENAED PARTY
+OLY-47
+OLY-48
+OLY-49
+OLY-50
+OLY-51
+OLY-52
+OLY-53
+OLY-54
+OLY-55
+OLY-56
+OLY-57
+OLY-58
+OLY-59
+OLY-60
+OLY-61
+JEGE, Inc.
+American Express TRS
+Co., Inc.
+Paul A. Lavery
+Datena Motors, Inc
+J. Epstein Virgin Islands
+Foundation, Inc.
+J. Epstein & Company,
+Inc.
+Epstein Interests
+Financial Trust
+Company, Inc.
+Royal Palm Community
+High School
+Park A. Cadillac Limo
+Service
+All Star Taxi and Limo
+Service
+Airport Executive
+Towncar Service
+Dan Tischler
+Majestic Theatre
+Broward Center for the
+Performing Arts
+1, AUSA
+[expiration 2/1/07]
+Transferred to FGJ 07-103 (WPB) Tuesdays
+RECORDS SOUGHT
+business records
+account records
+computer equipment
+rental car agreements
+business records
+business records
+business records
+business records
+transcript request
+phones, notes, etc
+business records
+business records
+business records
+APPEARANCE
+DATE ON
+SUBPOENA
+5/8/2007
+5/29/2007
+5/29/2007
+6/12/2007
+6/12/2007
+6/12/2007
+6/12/2007
+6/12/2007
+6/12/2007
+6/26/2007
+6/26/2007
+6/26/2007
+6/26/2007
+6/26/2007
+6/26/2007
+ACTUAL
+RETURN
+
+ticket/reservation
+information
+ticket/reservation
+information
+Page -5-
+
+
+FBI Special Agent
+FGJ 05-02 (WPB) Fridays
+Investigative No. OLY
+SUBPOENA
+CONTROL #
+SUBPOENAED PARTY
+OLY-62
+OLY-63
+OLY-64
+OLY-65
+OLY-66
+OLY-67
+OLY-70
+OLY-71
+OLY-72
+OLY-73
+OLY-74
+OLY-75
+OLY-76
+OLY-77
+OLY-78
+OLY-79
+Kravis Center for the
+Performing Arts
+William Riley
+Riley Kiraly
+NES, LLC
+Guys and Dolls
+Live Nation
+Theatrical/Broadway
+Across America
+OLY-68
+OLY-69
+Bear Stearns
+Adam Perryland
+Leslie Groff
+Jean-Luc Brunel
+Harry Beller
+Sent to
+in NY
+Wolf Camera
+Amazon.com
+Federal Express
+1, AUSA
+[expiration 2/1/07]
+Transferred to FGJ 07-103 (WPB) Tuesdays
+RECORDS SOUGHT
+ticket/reservation
+information
+computer equipment
+computer equipment
+business records
+transaction records
+transaction records
+appearance
+appearance
+appearance
+documents
+appearance
+appearance
+appearance
+appearance
+documents
+account records
+account records
+APPEARANCE
+DATE ON
+SUBPOENA
+6/26/2007
+7/10/2007
+7/10/2007
+7/10/2007
+7/10/2007
+7/10/2007
+8/14/2007
+8/21/2007
+8/21/2007
+9/4/2007
+9/4/2007
+9/4/2007
+9/4/2007
+9/11/2007
+9/25/2007
+2/19/2008
+2/19/2008
+ACTUAL
+RETURN
+
+Page - 6-
+
+
+TO: Paul A. Lavery
+Paul A. Lavery and Associates
+Investigative Services, Inc.
+5325 West 20" Lane
+Hialeah, FL 33016
+Uni I States District Ce rt
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-49
+SUBPOENA FOR:
+[X] PERSON
+X
+DOCUMENTS OR OBJECTIS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+May 29, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+All computer equipment and electronic storage media removed from the residence located at 358 El Brillo
+Way, Palm Beach, Florida, including but not limited to central processing units ("CPUs"), laptop
+computers, keyboards, printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms,
+DVDs, floppy diskettes, digital cameras, and memory cards.
+All computer equipment and electronic storage media that currently belongs to, or has ever belonged to,
+Jeffrey Epstein, including but not limited to central processing units ("CUs"), laptop computers,
+keyboards, printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, floppy
+diskettes, digital cameras, and memory cards.
+*Please coordinate your compliance with this subpoena and confirm the date, time, and location of your
+appearance with S/A
+, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+May 21, 2007
+This subpoena is issued upon application
+Ciao Limited State
+*I not applicable, enter none.
+Name, Address and Phone Number of Assistant U.S. Attorney
+, Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. EL. 33401-6235
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+statedate sere falty of pre and der the laws of the United States of America that the foregoing information contained in the Returm of Service and
+Execulad on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+JEGE, Inc.
+Unuted States District Court
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-47
+SUBPOENA FOR:
+] PERSON
+X
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Juryofthe United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+May 8, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+All income tax returns, balance sheets, regulatory filings, minutes of board of directors meetings, and
+documents required by or filed with the Internal Revenue Service and/or the State of Delaware
+referring or relating to the period of 1/1/2003 to 12/31/2005.
+For the period 1/1/2003 to the present, the names of all employees, copies of all W-2s for all employees,
+and the names of all corporate directors, board members, and shareholders.
+Please coordinate your compliance with this subpoena and confirm the date and time, and location o
+your appearance with Special Agent
+'ederal Bureau of Investigation, Telephone
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+DATE:
+(BY) DEPUTY CLERK
+April 24, 2007
+This subpoena is issued upon application
+ofthe limited States of Amarico
+SO CES TRACT OF
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL. 33401-6235
+
+
+SERVED ON (NAME)
+DATE4/25/07 PLACE USAO
+DATE 4/2567 RACE USAO via e-mail'
+Bruce Lyons
+SERVED B
+TE AUSA
+'STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL —
+DECLARATION OF SERVICE
+Statement or Service Fees is prue ay core he laws of the united States of America that the foregoing information contained in the Retum of Service and
+Executed on
+1/25/07
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Crimina
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+U.S. Departmi
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401-6235
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+authenticity. Therefore, you may be able to avoid appearing personally at the grand
+jury/trial at the time and place specified by completely filling out the attached Certification
+and Inventory and immediately returning it with the records to Special Agent
+FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to May 8, 2007.
+Sincerely,
+
+
+position of
+, declare that 1 am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+
+
+
+
+
+Villafana, Ann {
+C. (USAFLS)
+From:
+Sent:
+To:
+Subject:
+Villafana, Ann
+c. (USAFLS)
+5:39 PM
+RE: Epstein Corporations
+Attachments: Hyperion Subpoena001.pdf; JEGE Subpoena001.pdf
+Hi Bruce -- I tried faxing these a couple of times but your fax machine wasn't picking up, so I just scanned
+them in.
+These are the JEGE and Hyperion Subpoenas. I will wait to hear from you about the other items. Thank you.
+Assistant U.S. Attorney
+From:
+Sent:
+*5, 2007 4:49 PM
+To: V
+- (USAFLS)
+Subject: Re: Epstein Corporations
+I will get you the information on his NY counsel and find out the other info you request.
+See what's free at AOL.com.
+4/25/2007
+
+
+Hyperion Air, Inc.
+Un ed States District Court
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-46
+SUBPOENA FOR:
+PERSON
+X
+DOCUMENTS OR OBJECTIS
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+May 8, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+All income tax returns, balance sheets, regulatory filings, minutes of board of directors meetings, and
+documents required by or filed with the Internal Revenue Service and/or the State of Delaware
+referring or relating to the period of 1/1/2003 to 12/31/2005.
+For the period 1/1/2003 to the present, the names of all employees, copies of all W-2s for all employees,
+and the names of all corporate directors, board members, and shareholders.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+STATES DISTRICT
+(BY) DEPUTY CLERK
+DATE:
+April 24, 2007
+This subpoena is issued unon application
+CHANCES TRIKET OF
+Name. Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FI. 33401-6235
+Fax: (561) 802-1787
+• но aes CHe Bone.
+
+
+RETURN OF SERVICE
+DAT 4/5/67
+PLACE USAO
+DATE 4/25/611
+PLACE USAO - Via e-mail
+SERVED ON (NAME) Bruce Lyons
+SERVED B
+TRAVEL
+TITLE AULSA
+STATEMENT OF SERVICE FEES
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service and
+Statement of Service Fees is true and correct.
+Executod on 1/25/07
+Address of Server
+Served via e-mail on cornal for corporation
+after fax was unsuccessful
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+
+
+U.S. Departm.
+O0 S. Australian Ave., Suite 40
+est Palm Beach, FL 33401-623
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+ecords may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to thei
+utnenticity. Ineretor
+ury/trial at the time and place specified by completely pinging personaled he gran
+and Inventory and immediately returning it with the records to Special Agent
+FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to May 8, 2007.
+Sincerely,
+
+
+position of
+_ declare that 1 am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+
+
+
+
+TO: Adult Video Warehouse
+Un..ed States District Court
+• SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-44
+SUBPOENA FOR:
+] PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Juryofthe United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+May 1, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+All records and information referring or relating to a transaction completed October 3, 2004 in the
+amount of $94.21 charged to Chase Mastercard account #
+in the name of!
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+April 20, 2007
+This subpoena is issued upon application
+of the United States of Ameri
+Name, Address and Phone Number of Assistant U.S. Attorney
+Ann
+C. Villafañia, Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+To be used in leu of AO110
+
+
+TO: Datena Motors Inc.
+1637 S. Military Trail
+West Palm Beach, FL
+Unued States District Court FILE COPY
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-50
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTIS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+May 1, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+For the period of January 1, 2004 to the present, all documents and information referring or relating to
+any rental agreement in the name of Alfredo Rodriguez, DOB: 4/12/1954.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+DATE:
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the United States of America
+May 31, 2007
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+To be usrd in lieu of ADIO
+
+
+PLACE
+PLACE
+SERVED ON (NAME)
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service anc
+Statement of Service Fees is true and correct
+Executed on _
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+
+
+00 S. Australian Ave, Suite 40
+est Palm Beach, FL 33401-62:
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provideo
+sufficiently in advance of trial to allow an opportunity for any challenges to thei
+autnenticity. I neretore
+ultrial at the time and place specified be completely along terror an
+and Inventory and immediately returning it with the records to Special Agent
+, FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to June 12, 2007.
+Sincerely,
+El. qu
+for
+ASSISTANI UNITED STATES ATTORNEY
+
+
+position of
+, declare that 1 am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+
+
+
+
+The attached subpoena duces tecum for records from your office is served upon
+you in connection with the investigation of suspected violations of federal criminal law.
+Pursuant to an official criminal investigation being conducted by this office, you are
+requested not to disclose the existence of this request or your compliance to anyone. Any
+such disclosure could obstruct and impede the investigation and thereby interfere with the
+
+
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-43
+SUBPOENA FOR:
+× PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+April 24, 2007
+1:00pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+ANY AND ALL NOTES, LETTERS, CARDS, GIFTS, PAYMENTS, AND PHOTOGRAPHS YOU HAVE
+RECEIVED FROM JEFFREY EPSTEIN,
+AND/OR|
+ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIGITAL, OF JEFFREY EPSTEIN,
+AND/OR
+ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS, OR
+TELEPHONE MESSAGES THAT YOU HAVE SENT TO AND/OR RECEIVED FROM JEFFREY EPSTEIN,
+LAND/OR
+*Please coordinate your compliance with this subpoena and confirm the date and time of your appearance
+with Special Agent
+, Federal Bureau of Investigation, Telephone: |
+of the court.
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+April 16, 2007
+This subpoena is issued upon application
+BAN DESTRICT CES
+Name, Address and Phone Number of Assistant U.S. Attorney
+Ann
+_ C. Villafaña, Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+To he used in lieu of AQ110
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+Statemento service falls is pril and or the laws of the United States of America that the foregoing information contained in the Retum of envice and
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2 to a miles red not the rendered to the idea pes or i or sure is do federal rules or criminali
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+TO: Eve's Garden
+119 W 57" Street #1201
+New York, NY 10019
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-42
+SUBPOENA FOR:
+] PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+Grand Jury Room
+DATE AND TIME:
+May 1, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+All records and information referring or relating to Sale No. 5011509 dated 3/3/2005, includingallrecords
+and information referring or relating to transactions with
+- and/or Jeffrey Epstein.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+DATE:
+NOS
+April 16, 2007
+CLERK
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the linited Stater of Americ
+*If пог аррисаые, спет попе:
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. FL 33401-6235
+
+
+U.S. Departme of Justice
+500 S. Australian Ave, Surite 400
+Vest Palm Beach, FL 3340J-623
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+luthenticity. Theretore, you may be able to avoid appearing personally at the gran
+ury/trial at the time and place specified by completely filling out the attached Certificatio
+and Inventory and immediately returning it with the records to Special Agent
+,, FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to May 1, 2007.
+Sincerely,
+
+
+position of
+_ declare that 1 am:
+_ in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+
+
+
+
+TO: Adult Video Warehouse
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-41
+SUBPOENA FOR:
+7 PERSON
+DOCUMENTS OR OBJECTIS]
+YOUARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+May 1, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+All records and information referring or relating to invoice # 679654 dated 7/23/05, including all records
+and information referring or relating to transactions with
+, and/or Jeffrey Epstein.
+*Please coordinate your compliance with this subnnena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+DATE:
+April 16, 2007
+(BY) DEPUTY CLERK
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+300 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+To be used in lieu of ADI 10
+
+
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401-6233
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+and Inventory and immediately returning it with the records to Special Agent
+, FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to May 1, 2007.
+Sincerely,
+
+
+position of
+_ declare that 1 am:
+in the
+_and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+
+
+
+
+TO: Chase Bank USA, N.A.
+National Subpoena Processing
+7610 W. Washington Street
+IN1-4054
+Indianapolis, IN 46231
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-40
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTIS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+April 17, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following document(s) or objects):
+See attachments
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+DATE:
+April 4, 2007
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+i no appeare, enter none.
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. FL. 33401-6235
+To be used in lieu of AO11O
+
+
+DATE +|t/01
+SERVED ULA FAX
+9 Fedex
+1/011
+Race Indianapoles, IN
+Fiel, legal Processin, Specialist, Chase Bank WSt Ns
+washine Street, TN1-4054 Indianapoleo, IN
+SERVED AN
+TITLE
+Legal Assistaut
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service and
+Statement of Service Fees is true and correct
+Executed on
+4/4/07
+5005 Australian Aur, WPB. FL
+Address of Server
+Fedex hackeng # 1902-1752-7947
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the Unite
+¡tates or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Crimina
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+FGJ 07-103 OLY-40
+1. For the period of 1/1/04 through 12/31/06, all monthly billing statements, individual
+charge invoices, payment records disclosing the dates, amounts, and method of payment,
+and checks
+used to make payments (front and back) for account number
+2. All account applications, account openina documents. signature cards, and
+correspondence related to account number
+3. Any and all documents and information related to the following transactions for account
+number
+Date
+6/28/04
+8/10/04
+8/10/04
+9/3/04
+12/23/04
+6/1/05
+7/13/05
+12/21/05
+2/9/05
+Payee
+WesternUnion.com
+WesternUnion.com
+WesternUnion.com
+WesternUnion.com
+WesternUnion.com
+WesternUnion.com
+WesternUnion.com
+WesternUnion.com
+WesternUnion.com
+Amount
+$1364.95
+$115.00
+$115.00
+$115.00
+$222.00
+$367.50
+$222.00
+$222.00
+$329.00
+Reference #
+5MWE
+EN2E
+EN26
+Q100
+NGXO
+6Y68
+X044
+For account number
+Date
+10/03/04
+Payee
+Adult Video Warehouse
+Amount
+$94.21
+Reference #
+WFMJ
+
+
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-40
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+/ ROOM:
+Grand Jury Room
+DATE AND TIME:
+April 17, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):
+See attachments
+Ale?
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+vour appearance with Special Agent
+1, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+DATE4/4/07
+February 14, 2007
+CLERK
+(BY) DEPUTY CLERK
+This une ta sued apon apication.
+Name. Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+
+
+SERVED ON (NAME)
+RETURN OF SER ICE
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Returnof Service an
+tatement of Service Fees is true and correct
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+
+
+-GJ 07-103 OLY -40
+1. For the period of 1/1/04 through 12/31/06, all monthly billing statements, individual
+charge invoices, payment records disclosing the dates, amounts, and method of payment,
+checks used to make payments (front and back) for account number
+2. All account applications, account openina documents, signature cards, and
+correspondence related to account number
+3. Any and all documents and information related to the following transactions for account
+number
+Date
+6/28/04
+8/10/04
+8/10/04
+9/3/04
+12/23/04
+6/1/05
+7/13/05
+12/21/05
+2/9/05
+Payee
+WesternUnion.com
+WesternUnion.com
+WesternUnion.com
+WesternUnion.com
+WesternUnion.com
+WesternUnion.com
+WesternUnion.com
+WesternUnion.com
+WesternUnion.com
+Amount
+$1364.95
+$115.00
+$115.00
+$115.00
+$222.00
+$367.50
+$222.00
+$222.00
+$329.00
+Reference #
+5MWE
+EN2E
+EN26
+Q100
+NGXO
+6Y68
+X044
+For account number
+Date
+10/03/04
+Payee
+Adult Video Warehouse
+Reference #
+WFMJ
+
+
+L. 'ed States District « ourt
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-39
+SUBPOENA FOR:
+PERSON
+X
+DOCUMENTS OR OBJECTISI
+Q.
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Juryof the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States Distric
+701 Clematis Street
+West Palm Beach, F
+NOT SERVED
+YOU ARE ALSO C
+ANY AND ALL NOTE
+FROM JEFFREY EPS!
+ANY AND ALL PHOT
+AND/OR
+ANY AND ALL E-MA
+MESSAGES THAT Y
+AND/OR
+*Please coordinate
+your appearance w
+This subpoena shall
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+DOM:
+rand Jury Room
+ATE AND TIME:
+pril 3, 2007
+:00pm*
+›bjects):
+YOU HAVE RECEIVED
+TEIN,
+MAILS, OR TELEPHONE
+TEIN,
+d time, and location of
+vestigation, Telephone:
+t or by an officer acting on behalf
+DATE:
+March 20, 2007
+This subpoena is issued upon application
+...- Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. FL 33401-6235
+To be used in lieu of ADI10
+3IEMm-1 08062-509-44
+
+
+TO: Perry Bard, DC
+Health First Chiropractic Center
+4275 Okeechobee Blvd.
+West Palm Beach, FL 33409
+United States District C'ourt
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-38
+UMENTS OR OBJECTS]
+YOU ARE HEREB!
+Court at the place, date and t
+PLACE:
+United States District
+701 Clematis Street
+West Palm Beach, Flo
+ALSA
+ofthe United States District
+YOU ARE ALSO COI
+All documents referrin
+record of payments, ap
+OM:
+nd Jury Room
+TE AND TIME:
+ch 13, 2007
+1pm*
+ect (s):
+pilling statements,
+*Please coordinate you
+your appearance with S
+This subpoena shall rema
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+1e, and location of
+gation, Telephone:
+oy an officer acting
+DATE:
+March 2, 2007
+This subpoena is issued upon application
+of the Unite
+d States of America
+CARVillapre
+* If not applicable, enter "none."
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+
+
+FILE
+SUBPOENA TO TESTIFY COPY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-37
+SUBPOENA FOR:
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMA
+Court at the place, date and time specifi
+PLACE:
+United States District Courthous
+701 Clematis Street
+West Palm Beach, Florida 33401
+ed States District
+NOT SERVED
+›om
+TIME:
+07
+YOU ARE ALSO COMMAND
+ANY AND ALL NOTES, LETT!
+RECEIVED FROM JEFFREY E
+LAND ALL PHOTOGRAPE
+AND/OR
+ANY AND ALL E-MAILS, IN
+TELEPHONE MESSAGES THA
+,, AND/OR
+*Please coordinate your compl
+your appearance with Special
+This subpoena shall remain in e
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the United States of America
+OU HAVE
+L.
+N,
+MAILS, OR
+/ EPSTEIN,
+I location of
+Telephone:
+officer acting
+TE:
+March 16, 2007
+еши
+WEST OSTRIC
+With
+Name, Address and Phone Number of Assistant U.S. Attorne
+Ann Mario/C. Villafaña, Assistant U.S. Attorne
+500 So. Australian Avenue, Suite 400
+West Palm Beach. FL. 33401-6235
+To be used in lieu of AOLO
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+TRAVEL
+STATEMENT OF SERVICE FEES
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+Statemeat of sentice fates is pre and correhe laws of the United Stales of America that the foregoing information contained in the Relum of Service and
+Executed on _
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+• Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the Unite
+tates or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Crimin:
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+TO: Palm Beach County Health Department
+Office of Vital Statisțics
+1150 45* Street
+West Palm Beach, FL
+United States District c'ourt
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-36
+SUBPOENA FOR:
+PERSON
+X
+DOCUMENTS OR OBJECTS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 13, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring, with you the following documents) or object(s):
+See attachments
+CLERK
+(BY) DEPUTY CLERK
+* Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+Your appearance with Special Agent
+, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+DATE:
+March 2, 2007
+This subpoena is issued upon application
+f the United States of America
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. FL. 33401-6235
+
+
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-35
+SUBPOENA FOR:
+X PERSON
+X
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 13, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring.with you the following documents) or objects):
+All documents referring or relating to Jeffrey Epstein, including but not limited to billing statements,
+record of payments, appointment books, treatment notes, and correspondence.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+_ Federal Bureau of Investigation, Telephone:
+•
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+DATE:
+March 2, 2007
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the United Stater of America
+Name, Address and Phone Number of Assistant U.S. Attorney
+• Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. FL. 33401-6235
+To be used in lieu of AO 10
+
+
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-34
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOUARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 13, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring, with you the following documents) or objects):
+All documents referring or relating to Jeffrey Epstein, including but not limited to billing statements,
+record of payments, appointment books, treatment notes, and correspondence.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+• on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+March 2, 2007
+This subpoena is issued upon application
+of the United Stater of Amarior
+Name. Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. EL. 33401-6235
+To be used in lies of AO110
+
+
+TO: Thomas Rofrano
+United States District court
+."*
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-33
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 13, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring, with you the following documents) or object(s):
+All documents referring or relating to Jeffrey Epstein, including but not limited to billing statements,
+record of payments, appointment books, treatment notes, and correspondence.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+•on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+March 2, 2007
+This subpoena is issued upon application
+of the United States of America
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+To be used in lies of AD11O
+JAN.8G
+
+
+Unvied States District Court
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-32
+SUBPOENA FOR:
+| PERSON
+DOCUMENTS OR OBJECTIS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 6, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):
+See attachments
+*Please coordinate your compliance with this subnoena and confirm the date and time, and location of
+your appearance with Special Agent
+, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+STINCT COURTY
+DATE:
+February 14, 2007
+CLERK
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+Name Address and Phone Number of Assistant U.S. Attorney
+C. Villafaña, Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach BI. 33401-6235
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+TRAVEL
+STATEMENT OF SERVICE FEES
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+Statemento Service Fees is pre and orrthe laws of the United States of America that the foregoing information contained in the Return of Service and
+Execuled on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the Unite
+lates or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Crimir
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+JP Morgan Chase
+FGJ 07-103 OLY-32
+1. For the period of 1/1/04 through 12/31/06
+For the following individuals/entities:
+Janusz Banasiak [or Banasiar]
+Ghislaine Maxwell
+Jeffrey Epstein
+(a) All account applications, account opening documents, signature cards, deposit slips,
+correspondence, account statements; and canceled checks (front and back).
+(b) For any and all credit cards, debit cards, lines of credit, mortgages, and/or loans, all
+monthly billing statements, individual charge invoices, payment records disclosing the
+dates, amounts, and method of payment, and checks used to make payments (front and
+back).
+This includes but is not limited to, the following VISA accounts:
+2. Any and all documents and information related to the following transaction:
+Date
+12/13/05
+Payee
+Amount
+FL Drivers Lic/Veh Svcs
+$379.20
+
+
+
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401-6235
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+authenticity. Therefore, you may be able to avoid appearing personally at the grand
+jury/trial at the time and place specified by completely filling out the attached Certification
+and Inventory and immediately returning it with the records to Special Agent
+, FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to March 6, 2007.
+Sincerely,
+
+
+position of
+, declare that 1 am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+.:.
+
+
+
+
+Purchase Order, Receiving Report)
+This form shall only be used when requesting financial records of individuals ad partnerships of five or fewer individuals.
+1 Purchase Order Number:
+2 Date Order Prepared:
+2/14/2007
+Section A - Authorization and Purchase Order
+4 Name and Address of Financial Institution:
+JP Morgan Chase
+3 Case Number: (Optional)
+FGJ 07-103(WPB) No. OLY-32
+5 Deliver To: FBI Special Agent
+at
+16 Retum Date:
+3/6/2007
+7 Remarks:
+FOR REIMBURSEMENT PLEASE RETURN THIS FORM, THE RECORD OF
+SERVICES, AND A COPY OF THE SUBPOENA.
+8 Name of Roquestor: (Type or Print)
+AUSA
+9 Telephone Number:
+10 Date of request:
+2/14/2007
+Section B - Financial Institution Invoice
+No Payment Shall Be Made Unless Expenses Are Itemized Below Or On Your Form To Be Attached.
+11 Service/Financial Records Provided:
+Quantity
+Unit Price
+- Amount
+Cost
+Per
+FOR PROMPT PAYMENT INCLUDE TAXI.D. NUMBER.
+Please note that reimbursement cannot be made for the records pertaining to
+corporations or large partnerships of six or more. IMPORTANT: The DCIA
+Mandates the use of EFT/DD. In order to receive payment complete the
+attached EFT enrollment form.
+0.25
+Copy
+11.00
+Hour Clerical
+Tech
+17.00
+Hour Manger
+or
+Supervisor
+Do get proceed with comeline: style do (05 - 67rlor approvator
+12 Signature of Financial Institution Official:
+13 Date Signed:
+Section C - Receiving Report
+16 Disallowance
+(See Attached)
+14 1 certify that the articles and services listed were received:
+15 Date Received:
+17 Net to
+Financial
+Institution
+18 Right to Financial Privacy Act - Public Law 95-630
+(12 U.S.C. 3401-3422) Request Pursuant To: (Check One Only)
+19 Signature of Approving Official:
+SECTION
+• 3404
+Customer Authorization
+• 3405
+Administrative Subpoena or Summons
+• 3406
+Search Warrant
+• 3407
+Judicial Subpoma
+• 3408
+Formal Written Request
+• 3413 1
+Grand Jury Subpoena
+• 3414
+Special Procedures
+CLASS
+2540
+2541
+2542
+2543
+2544
+2545
+2546
+20 Accounting Classification Code
+FY/FC
+1
+2
+3
+4
+21 Schedule and Voucher Number:
+DC#
+5
+22 Remarks:
+Funds Available
+Budget Officer:
+This form was electronically produced by Elile Federal Forms, Inc.
+:
+0.00
+[PROJ
+
+
+as is a mutt-purpose form designed to sene as an Authorization, Purchase Order, Itemized Invoice, Receiving Report and Payment voucher
+nyuncton with "requests for firancial information," pursuant to the Right toFinancial Privacy Act of 1978, P.L. 95-630, Tide XI, 12 U.S.C. 34
+NOTE:
+Payments under this purchase order will be due on the 30th calendar day after the date of actual receipt of a proper invoice in the office designated to receive
+the invoice. the date of the check issued in payment shall be considered to be the date payment is made.
+The ros Paymes or public payne, 7, sprop a sc 150, sa plebie do po of entered dre i pur mas ende and eires the prentis of
+the Prompt Payment Act and the Office of Management and Budget Circular A-125.
+PREPARATION INSTRUCTIONS
+ITEM 1 - A Purchase Order Number will be preprinted on each form. This number will be used for reference purposes on any correspondence relating to this spedfic
+request for financial information.
+ITEM 2 - Self explanatory.
+ITEM 3 - This block may be used to identify the specific case for which the firancial information is required. This block may be left blank.
+SECTION A - AUTHORIZATION AND PURCHASE ORDER (To be completed by the requestingofficial).
+ITEM 4 - Enter the name and mailing address of the financial institution beingrequested to fumish financial information.
+ITEM 5 - Enter the name and address to which the financial information is to besent by the financial institution. This will normally be the name and addressof the
+requesting official.
+ITEM 6 - Enter the date the financial information is required.
+ITEM 7 - Include, if appropriate, any pertinent information related to the purhase order not provided for elsewhere on the form.
+ITEM 8, 9 and 10 - Self-explanatory.
+SECTION B - FINANCIAL INSTITUTION INVOICE (To be completed by the financial intitution).
+ITEM 11 - Self-explanatory. Completion of this block constutes an itemized bill or invoice for reimbursement for the costs incurred in providing the infomation
+requested.
+ITEM 12 and 13 - Self-explanatory.
+SECTION C - RECEIVING REPORT (To be completed by the requesting official, whenthe requested financial information has been delivered).
+ITEM 14 and 15 - Self-explanatory.
+ITEM 16 - This block should be used to reflect any differences between the amount claimed by the financial institution and the correct amount to be reimbursed
+Differences may result from computation erros, or failure of the financial intitution to deliver information requested.
+ITEM 17 - Enter the amount certified to be proper for payment.
+ITEM 18 - Check the box which identifies the appropriate procedure authorized by the Act, which necessitates the request for financial information.
+ITEM 19 and 20 - These blocks must be signed and dated by an official of the oganization whose funds will be charged. His or her signature constitutes a statement that the
+records to which the invoice refers were required for official business and were provided by the financial institution in accordance with the ordering instrunent.
+ITEM 21 - The Schedule and Voucher Number will be entered by the office which atually schedules the approved amount for payment by the Treasury Department.
+ITEM 22 - Enter, if appropriate, any data not provided for elsewhere on the reviving report, such as, reasons for any claim amounts disallowed.
+
+
+Please comply to this information if you have not done so already
+PAYEE/COMPANY INFORMATION:
+Vendor Company Name:
+Address:
+Taxpayer ID Number
+Contact Person Name
+Telephone Number
+FINANCIAL INSTITUTION INFORMATION:
+Bank Name
+Bank Address
+Bank Phone Number
+Nine Digit ABA Routing Transit Number
+Type of Account (Checking or Saving)
+Depositor Account Number
+lame & Title of Authorizin
+Officia
+Please Return or Fax to:
+U.S. Attorney's Office
+Fax Number:
+If you haven is hens regarding the delivery of the remittance information, please contact the financial institution where
+If you have any questions on the completion of this form, please contact Claudia Castellanos, at
+
+
+
+Unwed States District Court
+TO: Western Union Financial Services
+20 Corporate Hills Drive
+St. Charles, MO 63301
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-31
+SUBPOENA FOR:
+• PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury ofthe United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 6, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):
+See attachments
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+DATE:
+February 14, 2007
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. FL 33401-6235
+To be used in lieu of AOIIO
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+Statemeato Seer cerales is pre anunder the laws of the United States of America that the foregoing information contained in the Returm of Service and
+Execuled on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+
+
+Western Union Financial Services
+20 Corporate Hills Drive
+St. Charles, MO 63301
+FGJ 07-103 OLY-31
+Any and all documents referring or relating to transfers of funds for the fallawing
+amounts and on the following dates using VISA credit card number
+This includes, but is not limited to any handwritten or completed formo.
+and the recipient/receiver.
+Date
+06/28/2004
+08/10/2004
+12/23/2004
+06/01/2005
+07/13/2005
+07/26/2005
+12/21/2005
+02/09/2006
+Amount
+$1364.95
+$115.00
+$222.00
+$367.50
+$222.00
+$882.00
+$222.00
+$329.00
+
+
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401-6235
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+authenticity. Therefore
+any/tral at the time and place specified by completely ringing person do ar
+and Inventory and immediately returning it with the records to Special Agent
+FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to March 6, 2007.
+Sincerely,
+ASSISTANT UNITED STATES AYTORNEY
+
+
+position of
+_ declare that l am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+
+
+
+
+Unued States District Court
+TO: Western Union Financial Services
+20 Corporate Hills Drive
+St. Charles, MO 63301
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-30
+SUBPOENA FOR:
+PERSON
+X
+DOCUMENTS OR OBJECTISI
+YOUARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 6, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following document (s) or objects):
+See attachments
+*Please coordinate your compliance with this subnoena and confirm the date and time, and location of
+Your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+DATE:
+February 14, 2007
+CLERK
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+Name. Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach EL. 33401-6235
+To be used in lieu of AQI 10
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+Statemear of erice fates is pre and nor the laws of the United States of America that the foregoing information contained in the Retum of Service and
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+Western Union Financial Services
+20 Corporate Hills Drive
+St. Charles, MO 63301
+FGJ 07-103 OLY-30
+All documents and records referring ot relating to any and all transactions from the
+elow-listed senders sent from or the the states of New Jersey, New York, and Florida
+Juring the period of 10/01/2003 to 12/31/2006. This includes, but is not limited to any and
+all handwritten or completed forms made by the recipient/receiver and the sender.
+Jeffrey Epstein
+Ghislaine Maxwell
+
+
+U.S. Departme of Justice
+500S. Australian Ave, Suite 400
+West Palm Beach, FL 33401-6235
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+authenticity. Therefore, you may be able to avoid appearing personally at the grand
+jury/trial at the time and place specified by completely filling out the attached Certification
+and Inventory and immediately returning it with the records to Special Agent
+, FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to March 6, 2007.
+Sincerely,
+ASSISTANT UNITED STATES ĂTTORNEY
+
+
+position of
+, declare that l am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+
+
+
+
+TO: Palm Beach National Bank & Trust Company
+3931 RCA Blvd.
+Suite 3102
+Palm Beach Gardens, FL 33410
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-29
+SUBPOENA FOR:
+] PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury ofthe United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 6, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+See attachments
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+LATES DISTRICT
+DATE:
+February 14, 2007
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+SA DENICT OF T9
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+To be used in lies of AOT 10
+
+
+SERVED ON (NAME)
+RETURN OF SERVICE
+PLACE
+PLACE
+SERVED BY
+TITLE
+TRAVEL
+STATEMENT OF SERVICE FEES
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+Statemeat or Senice Fales is pole and nore laws of the United Stales of America that the foregoing information contained in the Return of Service and
+Executied on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2. "Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+Palm Beach National Bank and Trust Company
+3931 RCA Blvd.
+Suite 3102
+Palm Beach Gardens, FL 33410
+FGJ 07-103 OLY-29
+For the period of 1/1/04 through 12/31/06
+For the following individuals/entities:
+Jeffrey Epstein
+NES, LLC
+Jeffrey Epstein Household
+Janusz Banasiak [or Banasiar]
+JEGE, Inc.
+Alfredo Rodriguez
+(1) All account applications, account opening documents, signature cards, deposit slips,
+correspondence, account statements; and canceled checks (front and back).
+(2) For any and all credit cards, debit cards, lines of credit, mortgages, and/or loans, all
+monthly billing statements, individual charge invoices, payment records disclosing the
+dates, amounts, and method of payment, and checks used to make payments (front and
+back).
+This includes but is not limited to, the following VISA accounts:
+.:
+
+
+O0 S. Australian Ave, Suite 40
+Zest Pala Beach, FL 33401-623
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+authenticity. Theretore, you may be able to avoid appearing personally at the grand
+jury/trial at the time and place specified by completely filling out the attached Certification
+and Inventory and immediately returning it with the records to Special Agent
+, FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to March 6, 2007.
+Sincerely,
+
+
+position of
+, declare that 1 am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+
+
+
+
+Purchase Order, Receiving Report)
+This form shall only be used when requesting financial records of individuals ad partnerships of five or fewer individuals.
+1 Purchase Order Number:
+2 Date Order Prepared:
+2/14/2007
+3 Case Number: (Oprional)
+FGJ 07-103(WPB) No. OLY-29
+Section A - Authorization and Purchase Order
+4 Name and Address of Financial Institution: Palm Beach National Bank & Trust Company, 3931 RCA Blvd., Suite 3102, Palm Beach
+Gardens, FL 33410
+§ Deliver To: FBI Special Agent
+at
+6 Retum Date:
+3/6/2007
+7 Remarks:
+FOR REIMBURSEMENT PLEASE RETURN THIS FORM, THE RECORD OF
+SERVICES, AND A COPY OF THE SUBPOENA.
+8 Name of Requestor: (Cype or Print)
+AUSA
+9 Telephone Number:
+10 Date of request:
+|2/14/2007
+Section B - Financial Institution Invoice
+No Payment Shall Be Made Unless Expenses Are Itemized Below Or On Your Fonn To Be Attached.
+11 Service/Financial Records Provided:
+Quantity
+Unit Price
+- Amount
+Cost
+Per
+FOR PROMPT PAYMENT INCLUDE TAX I.D. NUMBER.
+Please note that reimbursement cannot be made for the records pertaining to
+corporations or large partnerships of six or more. IMPORTANT: The DCIA
+Mandates the use of EFT/DD. In order to receive payment complete the
+attached EFT enrollment form.
+0.25
+Copy
+11.00
+[Hour Clerical
+Tech
+17.00
+Hour Manger
+or
+Supervisor
+Doge proceed nith compliano: cat i et to shot prior approvalor
+12 Signature of Financial Institution Official:
+13 Date Signed:
+Section C - Receiving Report
+14 I certify that the articles and services listed were received:
+15 Date Received:
+Total Amount Claimed
+By Financial Institution
+16 Disallowance
+(See Attached)
+17 Net to
+Financial
+Institution
+19 Signature of Approving Official:
+0.00
+18 Right to Financial Privacy Act - Public Law 95-630
+(12 U.S.C. 3401-3422) Request Pursuant To: (Check One Only)
+SECTION
+• 3404
+13405
+• 3413 1
+] 3414
+Customer Authoriztion
+Administrative Subpoena or Summons
+Search Warrant
+Judicial Subpoena
+Formal Written Request
+Grand Jury Subpoena
+Special Procedures
+ОВЛЕСТ
+CLASS
+2540
+2541
+2542
+2543
+2544
+2545
+2546
+20 Accounting Classification Code
+FY FC
+1
+2
+3
+4
+5
+PROJ
+21 Schedule and Voucher Number:
+DCH
+22 Remarks:
+] Funds Available
+Budget Officer:
+This form was electronicaly produced by Elle Federal Forms, Inc
+
+
+is is a multi-purpose form designed to serve as an Authorization, Purchase Oder, Itemized Invoice, Receiving Report and Payment voucher
+junction with "requests for firancial information." pursuant to the Ripht toFinancial Privacy Act of 1978, P.L. 95-630, Title XI. 12 U.S.C. 34
+NOTE:
+Payments under this purchase order will be due on the 30th calendar day after t he date of actual receipt of a proper invoice in the office designated to receive
+the invoice. the date of the check issued in payment shall be considered to be the date payment is made.
+he Prompt Payment Act, Public Law 97-177, 96 Stat. 85 (31 U.S.C, 180), is applicable to payments under this purchase order and requires the payment
+ntractors of interest or overdue payments and improperly taken discounts. Determination of interest due will be made in accordance with the provisions
+the Prompt Payment Act and the Office of Management and Budget Circular A-125.
+PREPARATION INSTRUCTIONS
+ITEM 1 - A Purchase Order Number will be preprinted on each form. This number will be used for reference purposes on any correspondence relating to this speific
+request for financial information.
+ITEM 2 - Self explanatory.
+ITEM 3 - This block may be used to identify the specific case for which the firancial information is required. This block may be left blank.
+SECTION A - AUTHORIZATION AND PURCHASE ORDER (To be completed by the requestingofficial).
+ITEM 4 - Enter the name and mailing address of the financial institution beingrequested to furnish financial information.
+ITEM 5 - Enter the name and address to which the financial information is to besent by the financial institution. This will normally be the name and addressof the
+requesting official.
+ITEM 6 - Enter the date the financial information is required.
+ITEM 7 - Include, if approprize, any pertinent information related to the pushase order not provided for elsewhere on the form.
+ITEM 8, 9 and 10 - Sdf-explanatory.
+SECTION B - FINANCIAL INSTITUTION INVOICE (To be completed by the financial intitution).
+ITEM 11 - Self-explanatory. Completion of this block constitutes an itemized till or invoice for reimbursement for the costs incurred in providing the information
+requested.
+ITEM 12 and 13- Self-explanatory.
+SECTION C - RECEIVING REPORT (To be completed by the requesting official, whenthe requested financial information has been delivered).
+ITEM 14 and 15 - Self-explanatory.
+ITEM 16 - This block should be used to reflect any differences between the amount claimed by the financial institution and the correct amount to be reimbursed
+Differences may result from computation erros, or failure of the financial insitution to deliver information requested.
+ITEM 17 - Enter the amount certified to be proper for payment.
+ITEM 18 - Check the box which identifies the appropriate procedure authorized by the Act, which necessitates the request for financial information.
+ITEM 19 and 20 - These blocks must be signed and dated by an official of the oganization whose funds will be charged. His or her signature constitutes a statement that the
+records to which the invoice refers were required for official business and were provided by the financial institution in accordance with the ordering instrunent.
+ITEM 21 - The Schedule and Voucher Number will be entered by the office which actually schedules the approved amount for payment by the Treasury Department.
+ITEM 22 - Enter, if appropriate, ay data not provided for elsewhere on the reeiving report, such as, reasons for any claim amounts disallowed.
+
+
+Please comply to this information if you have not done so already
+PAYEE/COMPANY INFORMATION:
+Vendor Company Name:
+Address:
+Taxpayer ID Number
+Contact Person Name
+Telephone Number
+E-mail Address (If you woul
+ike to be notified via e-mail
+FINANCIAL INSTITUTION INFORMATION:
+Bank Name
+Bank Address
+Bank Phone Number
+Nine Digit ABA Routing Transit Number
+Type of Account (Checking or Saving)
+Depositor Account Number
+Name & Title of Authorizing
+Official
+Please Return or Fax to:
+U.S. Attorney's Office
+99 NE 4 street, Suite 200
+Miami, 32102
+Attention:
+Fax Number:
+If you have questions regarding the delivery of the remittance information, please contact the financial institution where
+your account is held
+If you have any questions on the completion of this form, please contact Claudia Castellanos, at
+
+
+
+TO: Colonial Bank
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-28
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOUARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 6, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):
+See attachments
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+February 14, 2007
+This subpoena is issued upon application
+Name. Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach EL. 33401-6235
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+Stal dear ol searce aley is pre ay under the laws of the United States of America that the foregoing information contained in the Returm or Service and
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+Colonial Bank
+FGJ 07-103 OLY-28
+For the period of 1/1/04 through 12/31/06
+For the following individuals/entities:
+Jeffrey Epstein
+NES, LLC
+Jeffrey Epstein Household
+Janusz Banasiak [or Banasiar]
+JEGE, Inc.
+Alfredo Rodriguez
+(1) All account applications, account opening documents, signature cards, deposit slips,
+correspondence, account statements; and canceled checks (front and back).
+(2) For any and all credit cards, debit cards, lines of credit, mortgages, and/or loans, all
+monthly billing statements, individual charge invoices, payment records disclosing the
+dates, amounts, and method of payment, and checks used to make payments (front and
+back).
+This includes but is not limited to, the following VISA accounts:
+
+
+500 S. Australian Ave, Suite 400
+Vest Palm Beach, FL 33401-623:
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+authenticity. Therefore, you may be able to avoid appearing personally at the grand
+jury/trial at the time and place specified by completely filling out the attached Certification
+and Inventory and immediately returning it with the records to Special Agent
+, FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to March 6, 2007.
+Sincerely,
+BY
+
+
+position of
+_, declare that I am:
+_ in the
+_and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+:
+
+
+
+
+Reaches or financial nirmaion Authorization,
+This form shall only be used when requesting financial records of individuals ad partnerships of five or fewer individuals.
+I Purchase Order Number:
+2 Date Order Prepared:
+2/14/2007
+Section A - Authorization and Purchase Order
+4 Name and Address of Financial Institution:/
+Colonial Bank
+3 Case Number: (Optional)
+FGJ 07-103(WPB) No. OLY-28
+5 Deliver To:
+FBI Special Agent
+at
+T6 Return Date:
+3/6/2007
+7 Remarks:
+FOR REIMBURSEMENT PLEASE RETURN THIS FORM, THE RECORD OF
+SERVICES, AND A COPY OF THE SUBPOENA.
+8 Name of Requestor: (Zype or Print)
+AUSA
+9 Telephone Number:
+T1o Date of request:
+2/14/2007
+Section B - Financial Institution Invoice
+No Payment Shall Be Made Unless Expenses Are Itemized Below Or On Your Forn To Be Attached.
+11 Service/Financial Records Provided:
+Quantity
+Unit Price
+Cost
+Per
+FOR PROMPT PAYMENT INCLUDE TAX I.D, NUMBER.
+Please note that reimbursement cannot be made for the records pertaining to
+corporations or large partnerships of six or more. IMPORTANT: The DCIA
+Mandates the use of EFT/DD. In order to receive payment complete the
+attached EFT enrollment form.
+0.25
+Copy
+11.00
+Hour Clerical
+Tech
+17.00
+Hour Manger
+or
+Supervisor
+Do not proceed with compliance: If cost will exceed 5500 without prior approval of
+Budget Officer Lazaro Feliciano Fax any request to (305) 530-7679
+12 Signature of Financial Institution Official:
+|13 Date Signed:
+otal Amount Claime
+ly Financial Institutic
+Section C - Receiving Report
+14 I certify that the articles and services listed were received:
+16 Disallowance
+(See Attached)
+15 Date Received:
+17 Net to
+Financial
+Institution
+18 Right to Financial Privacy Act - Public Law 95-630
+(12 U.S.C. 3401-3422) Request Pursuant To: (Check One Only)
+19 Signature of Approving Official:
+SECTION
+• 3404
+• 3413 1
+| 3414
+Customer Authorization
+Administrative Subpoena or Summons
+Search Warrant
+Judicial Subpoena
+Formal Written Request
+Grand Jury Subpoena
+Special Procedures
+OBJECT
+CLASS
+2540
+2541
+2542
+2543
+2544
+2545
+2546
+20 Accounting Classification Code
+FYFC | 2 3| 4
+21 Schedule and Voucher Number:
+DCH
+22 Remarks:
+• Funds Available
+Budget Officer:
+This form was electranicaly produced by Elle Federal Forms, Ina
+Amount
+0.00
+PROJ
+
+
+This on it pee for derance to sere at an urination, rese on direly At 17, PL. 350, Tre 1, 12 US C 3415.
+NOTE:
+Payments under this purchase order will be due on the 30th calendar day after the date of actual receipt of a proper invoice in the office designated to receive
+the invoice. the date of the check issued in payment shall be considered to be the date payment is made.
+The rep Pret or rubie pay z 7, sir pet use so presen parent endre is please ate and aces he prit or
+the Prompt Payment Act and the Office of Management and Budget Circular A-125.
+PREPARATION INSTRUCTIONS
+ITEM 1 - A Purchase Order Number will be preprinted on each form. This number will be used for reference purposes on any correspondence relating to this speáfic
+request for financial information.
+ITEM 2 - Self explanatory.
+ITEM 3 - This blod: may be used to identify the specific case for which the fincial information is required. This block may be left blank.
+SECTION A - AUTHORIZATION AND PURCHASE ORDER (To be completed by the requestingofficial).
+ITEM 4 - Enter the name and mailing address of the financial institution beingrequested to furnish financial information.
+ITEM 5 - Enter the name and address to which the financial information is to be sent by the financial institution. This will normally be the name and addressof the
+requesting official.
+ITEM 6 - Enter the date the financial information is required.
+ITEM 7 - Include, if appropriate, any pertinent information related to the purhase order not provided for elsewhere on the form.
+ITEM 8, 9 and 10 - Self-explanatory.
+SECTION B - FINANCIAL INSTITUTION INVOICE (To be completed by the financial insitution).
+ITEM 11 - Self-explanatory. Completion ofthis block constitutes an itemized bill or invoice for reimbursement for the costs incurred in providing the information
+requested.
+ITEM 12 and 13 - Self-explanatory.
+SECTION C - RECEIVING REPORT (To be completed by the requesting official, whenthe requested financial information has been delivered).
+ITEM 14 and 15 - Self-explanatory.
+TEM 16 - This block shoukl be used to reflect any differences between the amount claimed by the financial instiution and the correct amount to be reimburst
+illerences may result from computation erros, or failure of the financial institution to deliver information requeste
+ITEM 17 - Enter the amount certified to be proper for payment.
+ITEM 18 - Check the box which identifies the appropriate procedure authorized by the Act, which necessitates the request for financial information.
+rEM 19 and 20- These blocks must be signed and dated by an official of the oganization whose funds will be charged. His or her signature constitutes a statement that tf
+cords to which the invoice refers were required for official business and wee provided by the financial institution in accordance with the ordering instrunen
+ITEM 21 - The Schedule and Voucher Number will be entered by the office which actually schedules the approved amount for payment by the Treasury Department.
+ITEM 22 - Enter, if appropriate, any data not provided for elsewhere on the reliving report, such as, reasons for any claim amounts disallowed.
+
+
+Please comply to this information if you have not done so already
+PAYEE/COMPANY INFORMATION:
+Vendor Company Name:
+Address:
+Taxpayer ID Number
+Contact Person Name
+Telephone Number
+FINANCIAL INSTITUTION INFORMATION:
+Bank Name
+Bank Address
+Bank Phone Number
+Nine Digit ABA Routing Transit Number
+Type of Account (Checking or Saving)
+Depositor Account Number
+Name & Title of Authorizing
+Official
+Please Return or Fax to:
+U.S. Attorney's Office
+19 NE 4 street, Suite 20
+Miami, FL
+33132
+Attention:
+Fax Number:
+The Debt Collection Improvement Act of 1996 requires that payments made by the Federal government, including vendor
+payments, must be made by electronic funds transfer (EFT). A benefit of receiving payments by EFT is that your funds
+are directly deposited to your account at a financial institution and are available to you on the date of payment
+If you have questions regarding the delivery of the remittance information, please contact the financial institution where
+your account is held
+If you have any questions on the completion of this form, please contact Claudia Castellanos, at
+
+
+
+TO: Anthony Figueroa
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-27
+SUBPOENA FOR:
+X PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+January 12, 2007
+9:30 am*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+Any and all documents, correspondence, telephone records, address books, and/or e-mails referring
+or related to Jeffrey Epstein and/or
+- Any and all information regarding methods to contact
+Jeffrey Epstein directly or via any secretaries/assistants from 1/1/2003 to the present, including but not
+limited to, telephone numbers, cellular telephone numbers, Blackberry addresses, e-mail addresses, and
+mailing addresses. Documentation of any payments received from Jeffrey Epstein and/or
+including but not limited to bank account statements.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+COURTI
+DATE:
+December 18, 2006
+This subpoena is issued upon application
+IN DESTRICT CET
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. EL. 33401-6235
+
+
+SERVED ON (NAME)
+RETURN OF SERVICE
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE?
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service and
+Statement of Service Fees is true and correct
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+
+
+Gerald Lefcourt
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-26
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+United States District Courthouse
+Grand Jury Room
+701 Clematis Street
+West Palm Beach, Florida 33401
+DATE AND TIME:
+February 13, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following document (s) or object (s):
+All retainer agreements, representation agreements, and all documents referring or relating to payments
+for representation and the scope of your representation of Jeffrey Epstein and/or any current or former
+employee or associate of Jeffrey Epstein.
+A list of all current or former employees or associates of Jeffrey Epstein whom you claim to represent and the
+identity of the person(s) paying for that representation.
+All joint defense agreements, whether formal or informal, and all documents referring or relating to joint defense
+agreements and/or the sharing of information related to the investigation of Jeffrey Epstein and/or any current
+or former employees or associates of Jeffrey Epstein.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+DATE:
+February 1, 2007
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the United States of America
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. FL. 33401-6235
+To be used in Fica of ADIO
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service and
+Statement of Service Fees is true and correct
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(dl), Federal Rules of Criminal
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+TO: Lilly Ann Sanchez
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-25
+SUBPOENA FOR:
+X PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+United States District Courthouse
+Grand Jury Room
+701 Clematis Street
+West Palm Beach, Florida 33401
+DATE AND TIME:
+February 13, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or object(s):
+All retainer agreements, representation agreements, and all documents referring or relating to payments
+for representation and the scope of your representation of Jeffrey Epstein and/or any current or former
+employee or associate of Jeffrey Epstein.
+A list of all current or former employees or associates of Jeffrey Epstein whom you claim to represent and the
+identity of the person(s) paying for that representation.
+All joint defense agreements, whether formal or informal, and all documents referring or relating to joint defense
+agreements and/or the sharing of information related to the investigation of Jeffrey Epstein and/or any current
+or former employees or associates of Jeffrey Epstein.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+_ Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+DATE:
+February 1, 2007
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the United States of America
+*IF not applicable, enter "none."
+SAN DESTRICT TS
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. EL. 33401-6235
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+Statemeate strice fee of pete and nor he laws of the united States of America that the foregoing information contained in the Retum or service and
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+
+
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-24-2
+SUBPOENA FOR:
+] PERSON
+X
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+January 12, 2007
+9:30 am*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+Any and all records related to your employment with Jeffrey Epstein, including but not limited to
+paystubs, W-2 forms, correspondence, employment applications, and employment reviews. Any and all
+information regarding methods to contact Jeffrey Epstein directly or via any secretaries/assistants from
+1/1/2004 to the present, including but not limited to, telephone numbers, cellular telephone numbers,
+Blackberry addresses, e-mail addresses, and mailing addresses. Any and all information regarding
+appointments for massages performed on Jeffrey Epstein in Palm Beach, Florida or elsewhere.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+December 18, 2006
+This subpoena is issued upon application
+*If not applicable, enter "hone."
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. FL. 33401-6235
+To be used in lica of AOIIO
+
+
+SERVED ON (NAME)
+RETURN OF SERVICE
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service an
+Statement of Service Fees is true and correc
+Executed on DATE
+Signature of Server
+Address of Server
+.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, o
+lule 45(c), Federal Rules of Civil Procedure
+2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-24
+SUBPOENA FOR:
+x PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Grand Jury Room
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+DATE AND TIME:
+December 1, 2006
+9:30 am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+Any and all records related to your employment with Jeffrey Epstein, including but not limited to
+paystubs, W-2 forms, correspondence, employment applications, and employment reviews. Any and all
+information regarding methods to contact Jeffrey Epstein directly or via any secretaries/assistants from
+1/1/2004 to the present, including but not limited to, telephone numbers, cellular telephone numbers,
+Blackberry addresses, e-mail addresses, and mailing addresses. Any and all information regarding
+appointments for massages performed on Jeffrey Epstein in Palm Beach, Florida or elsewhere.
+Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+JAT
+DATE:
+November 13, 2006
+This subnoena is issued unon application
+Name, Address and Phone Number of Assistant U.S. Attorney
+• Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. EL. 33401-6235
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+Statement or Senio Fols of pal ay or he laws of the United Statos of America that the foregoing information contained in the Return of Service and
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+
+
+TO: Janusz Banasiak
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-23-2
+SUBPOENA FOR:
+X PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+United States District Courthouse
+Grand Jury Room
+701 Clematis Street
+West Palm Beach, Florida 33401
+DATE AND TIME:
+January 12, 2007
+9:30 am*
+YOU ARE ALSO COMMANDED to bring with you the following document (s) or objects):
+Any and all records related to your employment, including but not limited to paystubs, W-2 forms,
+correspondence, employment applications, and employment reviews. Any and all information regarding
+methods to contact Jeffrey Epstein directly or via any secretaries/assistants from 1/1/2004 to the present,
+including but not limited to, telephone numbers, cellular telephone numbers, Blackberry addresses, e-mail
+addresses, and mailing addresses.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+December 18, 2006
+This subpoena is issued upon application
+afthe Linitad Stater of A marior
+not appeare, cater tone.
+Name. Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+300 So. Australian Avenue, Suite 400
+West Palm Beach. EL. 33401-6235
+To be used in licu of AO1IO
+
+
+RECEIVEL
+Y SERVER
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+Statemear or Serice frles is true and correct laws of the United States of America that the foregoing information contained in the Returm of Senice and
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+1825, Rule 17(b) Federal Rules of Criminal Procedure*
+
+
+TO: Janusz Banasiak
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-23
+SUBPOENA FOR:
+[X PERSON
+DOCUMENTS OR OBJECTIS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+United States District Courthouse
+Grand Jury Room
+701 Clematis Street
+West Palm Beach, Florida 33401
+DATE AND TIME:
+December 1, 2006
+9:30 am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+Any and all records related to your employment, including but not limited to paystubs, W-2 forms,
+correspondence, employment applications, and employment reviews. Any and all information regarding
+methods to contact Jeffrey Epstein directly or via any secretaries/assistants from 1/1/2004 to the present,
+including but not limited to, telephone numbers, cellular telephone numbers, Blackberry addresses, e-mail
+addresses, and mailing addresses.
+Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+November 13, 2006
+This subpoena is issued upon application
+* I not applicable, enter "none."
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. FL. 33401-6235
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+Statement or Serice Faey of pee and or the laws of the United States of America that the foregoing information contained in the Return of Service and
+Execuled on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+
+
+TO: Larry Visoski
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-22
+SUBPOENA FOR:
+x PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+December 1, 2006
+9:30 am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+Any and all information and records related to Jeffrey Epstein, Gulfstream Aircraft N909JE, and Boeing
+Aircraft N908JE, including but not limited to flight records, maintenance records, and passenger manifest
+records. Any and all records related to your employment, including but not limited to paystubs, W-2
+forms, correspondence, employment applications, and employment reviews. Any and all information
+regarding methods to contact Jeffrey Epstein directly or via any secretaries/assistants from 1/1/2004 to
+the present, including but not limited to, telephone numbers, cellular telephone numbers, Blackberry
+addresses, e-mail addresses, and mailing addresses.
+Please coordinate your compliance with this subpoena and confirm the date and time of your appearance
+with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+TEA DISTRICT COL
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+November 13, 2006
+This subpoena is issued upon application
+of the United States of America
+Name, Address and Phone Number of Assistant U.S. Attorney
+_C. Villafaña, Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. EL. 33401-6235
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+Statement or Service Faes is prue and orrect laws of the United Stales of America that the foregoing information contained in the Retum of Service and
+Execuled on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+• Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the Unite
+tates or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Crimin
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+TO: Bill Hammond
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-21
+SUBPOENA FOR:
+X PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+United States District Courthouse
+Grand Jury Room
+701 Clematis Street
+West Palm Beach, Florida 33401
+DATE AND TIME:
+December 1, 2006
+9:30 am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+Any and all information and records related to Jeffrey Epstein, Gulfstream Aircraft N909JE, and Boeing
+Aircraft N908JE, including but not limited to flight records, maintenance records, and passenger manifest
+records. Any and all records related to your employment, including but not limited to paystubs, W-2
+forms, correspondence, employment applications, and employment reviews. Any and all information
+regarding methods to contact Jeffrey Epstein directly or via any secretaries/assistants from 1/1/2004 to
+the present, including but not limited to, telephone numbers, cellular telephone numbers, Blackberry
+addresses, e-mail addresses, and mailing addresses.
+Please coordinate your compliance with this subpoena and confirm the date and time of vour appearance
+with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+ст сог
+DATE:
+November 13, 2006
+This subpoena is issued upon application
+NOSTRICT C
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. EL. 33401-6235
+To be used in lieu of AO 10
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+Statement or service fals is pre and or the laws of the United Statos of America that the foregoing information contained in tho Returm of Service and
+Execuled on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+
+
+TO: Extra Touch Flowers
+420 Clematis Street
+West Palm Beach, FL
+Unued States District Court
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-20
+SUBPOENA FOR:
+] PERSON
+DOCUMENTS OR OBJECTIS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+November 17, 2006
+9:30 am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or object (s):
+ANY AND ALL DOCUMENTS OR INFORMATION RELATING OR REBERRING TO ALEREDO
+RODRIGUEZ,
+JEFFREY EPSTEIN, AND/OR
+Please coordinate your compliance of this subpoena and confirm the date and time of your
+ppearance with Special Agent
+• Federal Bureau of Investigation,
+Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+A BUBTRICT COURT
+DATE:
+October 23, 2006
+(BY) DEPUTY CLERK
+ON DISTRICT CRIT
+This subpoena is issued upon application
+of the United States of America
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL. 33401-6235
+
+
+SERVED ON (NAME)
+RETURN OF SERVICE
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service and
+Statement of Service Fees is true and correct
+Executed on!
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Crimina
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 US
+
+
+U.S. Departm. • of Justice
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401-6235
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+uthenticity. Theretore, you may be able to avoid appearing personally at the gran
+ury/trial at the time and place specified by completely filling out the attached Certificatior
+and Inventory and immediately returning it with the records to Special Agent
+, FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to November 17, 2006.
+Sincerely,
+
+
+position of
+_ declare-that 1 am:
+in the
+_and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+
+
+
+
+THE DALTON SCHOOL
+108 EAST 89 STREET
+NEW YORK, NY 10128
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-19
+SUBPOENA FOR:
+] PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+Palm Beach County Courthouse
+ROOM:
+Room 4-A
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+DATE AND TIME:
+(Temporary location for the United States District Courthouse, West Palm Beach)
+September 29, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+ANY AND ALL INFORMATION, DOCUMENTS, AND RECORDS (INCLUDING INFORMATION,
+DOCUMENTS, AND RECORDS IN ELECTRONIC STORAGE) REFERRING OR RELATING TO JEFFREY
+EPSTEIN, INCLUDING BUT NOT LIMITED TO CORRESPONDENCE, E-MAILS, EMPLOYMENT
+APPLICATIONS, EMPLOYMENT REVIEWS, DISCIPLINARY RECORDS, PAYMENT RECORDS,
+STUDENTS AND/OR PARENT COMMENTS, AND AWARDS.
+Please coordinate your compliance of this subpoena and confirm the date and time of your
+appearance with Special Agent
+Telephone:
+Federal Bureau of Investigation,
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+DATE:
+September 21, 2006
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+ON DESTRICT OF
+Name. Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. EL, 33401-6235
+
+
+SERVED ON (NAME)
+PLACE
+•PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+i declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service an
+statement of Service Fees is true and correc
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal
+Procedure or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+U.S. Departr t of Justice
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401-6235
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+jury/trial at the time and place specified by completely filling out the attached Certification
+FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to September 29, 2006.
+Sincerely,
+
+
+position of
+_ declare that 1 am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+
+
+
+
+TO: GOOD SAMARITAN MEDICAL CENTER
+SUBPOENA TO TESTIFY
+1309 North Flagler Drive
+West Palm Beach, FL
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-018
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Room 4-A
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+DATE AND TIME:
+September 22, 2006
+9:30am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+All documents and information referring or relating to
+_and/or b
+- DOB:
+- including but not limited to medical records, billing records and
+information, payment records and information, and records in electronic storage.
+Please coordinate your compliance of this subpoena and confirm the date and time of your appearance with
+Federal Bureau of Investigation, Telephone:|
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+URT
+DATE:
+September 13, 2006
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL. 33401-6235
+To be used in lieu of ADITO
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+TRAVEL
+STATEMENT OF SERVICE FEES
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+Statement of Service Fees of rue and or the laws of the United States of America that the foregoing information contained in the Return of Service and
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+
+
+U.S. Departn
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+authenticity. Therefore, you may be able to avoid appearing personally at the grand
+jury/trial at the time and place specified by completely filling out the attached Certification
+and Inventory and immediately returning it with the records to Special Agent
+,, FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to September 22, 2006.
+Sincerely,
+
+
+position of
+_ declare that 1 am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+
+
+
+
+CUSTODIAN OF RECORDS
+Clerk of Court and Comptroller
+15th Judicial Circuit of Florida
+Palm Beach County Courthouse
+205 North Dixie Highway
+West Palm Beach, FL 33401
+United States District C'ourt
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-17
+SUBPOENA FOR:
+] PERSON
+DOCUMENTS OR OBJECTS]
+X
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Room 4-A
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+DATE AND TIME:
+August 18, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+Tapes or transcripts of any and all proceedings before the Grand Jury on Wednesday, July 19, 2006,
+referring or relating to Jeffrey Epstein and/or
+including but not limited to witness
+testimony, statements made by any member of the State Attorney's Office, and instructions given by any
+member of the State Attorney's Office.
+Please coordinate your compliance of this subpoena and confirm the date and time of your appearance with
+Federal Bureau of Investigation, Telephone:
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+DATE:
+September 6, 2006
+(BY) DEPUTY CLERK
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+300 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+
+
+DATE 9/6/06
+PLACE USAO
+DATE9/6/06
+PLACEUSAO Via fax
+SERVE NAME Denise Coffman, Esg.
+SERVED B
+TITLE AUSA
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+Statemento Service Faes is pue ay under the laws of the United States of America that the foregoing information contained in the Return of Service and
+Executed on _
+9/6/00
+Address of Server
+was Atoney's Office
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+
+
+TO: EVIDENCE CUSTODIAN
+CITY OF PALM BEACH
+POLICE DEPARTMENT
+PALM BEACH, FL
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-16
+SUBPOENA FOR:
+7 PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+ROOM:
+Room 4-A
+DATE AND TIME:
+September 1, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following document(s) or objects):
+ANY AND ALL EVIDENCE RECEIVED, SEIZED, AND/OR COLLECTED IN CONNECTION WITH
+THE INVESTIGATION OF JEFFREY EPSTEIN AND/OR ANY EMPLOYEE OR ASSOCIATE OF
+JEFFREY EPSTEIN.
+Please coordinate your compliance of this subpoena and confirm the date and time of your appearance with
+Federal Bureau of Investigation, Telephone:
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+August 25, 2006
+This subpoena is issued upon application
+of tho Limitad Stator of d
+SAFAN DESTINET ON
+Name, Address and Phone Number of Assistant U.S. Attorney
+, Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+
+
+SERVED ON (NAME)
+RETURN OF SERVICE
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service an
+statement of Service Fees is true and correct
+Executed on DATE
+Signature of Server
+Address of Server
+1. As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+* fes or an olear ree not the rendered the ries ple of ie fra care le do beat oftes or rinal J
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+REIMER EMPLOYMENT AGENCY
+249 PERUVIAN AVE, STE R1
+PALM BEACH, FL 33480
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-15
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTIS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+Palm Beach County Courthouse
+ROOM:
+Room 4-A
+Juvenile Courts Building
+205 N. Dixie Highway
+DATE AND TIME:
+West Palm Beach, Florida 33401
+September 1, 2006
+(Temporary location for the United States District Courthouse, West Palm Beach)
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+ANY AND ALL RECORDS REFERRING OR RELATING TO JEFFREY EPSTEIN AND/OR
+GHISLAINE MAXWELL, INCLUDING BUT NOT LIMITED TO PERSONNEL RECORDS,
+RECORDS OF PAYMENTS, AND CLIENT PROFILE.
+lease coordinate vour comnliance of this subpoena and confirm the date and time of vour annearance wit
+ederal Bureau of Investigation, Telephone:
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+GATES DISTRET
+DATE:
+August 23, 2006
+BAN DISTRICT GET
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach EL. 33401-6235
+
+
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-14
+SUBPOENA FOR:
+X PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States Distric
+'ourt at the place, date and time specified below
+PLACE:
+ROOM:
+Room 4-A
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+DATE AND TIME:
+West Palm Beach, Florida 33401
+August 25, 2006
+(Temporary location for the United States District Courthouse, West Palm Beach)
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+ANY AND ALL NOTES, LETTERS, CARDS, GIFTS, PAYMENTS, AND PHOTOGRAPHS YOU HAVE
+RECEIVED FROM JEFFREY EPSTEIN,
+| AND/OR |
+ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIGITAL, OF JEFFREY EPSTEIN, |
+AND/OR
+ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS, OR
+TELEPHONE MESSAGES THAT YOU HAVE SENT TO AND/OR RECEIVED FROM JEFFREY EPSTEIN,
+AND/OR
+Please coordinate your compliance of this subpoena and confirm the date and time of your
+appearance with Special Agent
+Federal Bureau of Investigation,
+Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+STATES DISTANCY
+CLERK
+COLE
+DATE:
+August 18, 2006
+(BY) DEPUTY CLERK
+This subpoena is issued upon applicatior
+if the United States of America
+ter
+ad Phone Number of Assistant U.S. Attorney
+Ann
+7C. Villafañia, Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+Staleat of erice fole is prue and oree laws of the Unild States of America that the foregoing information contained in the Return of Service and
+Execuled on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the Unite
+states or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Crimina
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-13/4
+SUBPOENA FOR:
+| PERSON
+X
+DOCUMENTS OR OBJECTIS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Grand Jury Room
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+DATE AND TIME:
+April 24, 2007
+1:00pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+ANY AND ALL NOTES, LETTERS, CARDS, GIFTS, PAYMENTS. AND PHOTOGRAPHS YOU HAVE
+RECEIVED FROM JEFFREY EPSTEIN,
+AND/OR
+ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIGITAL, OF JEFFREY EPSTEIN,
+AND/OR
+ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS, OR
+TELEPHONE MESSAGES THAT YOU HAVE SENT TO AND/OR RECEIVED FROM JEFFREY EPSTEIN,
+1 AND/OR
+Please coordinate your compliance with this subpoena and confirm the date and time of your apnearance
+with Special Agent
+Immigration and Customs Enforcement, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+INTES DISTRICE
+(BY) DEPUTY CLERK
+DATE:
+April 16, 2007
+This subpoena is issued upon application
+SAY DISTRICT OF
+Name. Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. EL. 33401-6235
+
+
+SERVED ON (NAME)
+RETURN OF SERVICE
+PLACE
+PLACE
+SERVED BY
+TITLE
+TRAVEL
+STATEMENT OF SERVICE FEES
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service an
+statement of Service Fees is true and correc
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+Un 'ed States District i urt
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ O5-02(WPB)-Fri./No. OLY-13/23
+SUBPOENA FOR:
+] PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States
+District Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Courtroom
+Fourth District Court of Appeals
+1525 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+DATE AND TIME:
+October 27, 2006
+1:00pm
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+ANY AND ALL NOTES, LETTERS, CARDS, GIFTS, PAYMENTS, AND PHOTOGRAPHS YOU HAVE
+RECEIVED FROM JEFFREY EPSTEIN,
+LAND/OR
+ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIGITAL, OF JEFFREY EPSTEIN,
+AND/OR
+ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS, OR
+TELEPHONE MESSAGES THAT YOU HAVE SENT TO AND/OR RECEIVED FROM JEFFREY EPSTEIN,
+AND/OR
+Please coordinate your compliance with this subpoena and confirm the date and time of
+your appearance with Special Agent
+Immigration and Customs
+Enforcement, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+*If not applicable, enter "none.
+SATES ASTRICT
+DATE:
+October 19, 2006
+THE STRICT OF T
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+300 So. Australian Avenuc, Suite 400
+West Palm Beach, FL 33401-6235
+≤AD -72
+
+
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-13/2
+SUBPOENA FOR:
+x PERSON
+X
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Room 4-A
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+DATE AND TIME:
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+Sepamber 1, 2006
+YOU ARE ALSO COMMANDED to bring with you the following document (s) or objects):
+ANY AND ALL NOTES, LETTERS, CARDS, GIFTS, PAYMENTS, AND PHOTOGRAPHS YOU HAVE
+RECEIVED FROM JEFFREY EPSTEIN, L
+_ AND/OR L
+ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIGITAL, OF JEFFREY EPSTEIN,
+AND/OR
+ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS, OR
+TELEPHONE MESSAGES THAT YOU HAVE SENTTO AND/OR RECEIVED FROM JEFFREY EPSTEIN,
+AND/OR
+Please coordinate your compliance of this subpoena and confirm the date and time of your
+appearance with Special Agent
+Federal Bureau of Investigation,
+Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+DATE:
+August 23, 2006
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+Name. Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. FL. 33401-6235
+
+
+SEP-06-2006 15:06
+FBI WEST PALM BEACH RA
+P.01/01
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-13
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+Palm Beach County Courthouse
+ROOM:
+Room 4-A
+Juvenile Courts Building
+205 N. Dixie Highway
+DATE AND TIME:
+West Palm Beach, Florida 33401
+September 8, 2006
+(Temporary location for the United States District Courthouse, West Palm Beach)
+11:00am
+XOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+ANY AND ALL NOTES, LETTERS, CARDS, GIFTS, PAYMENTS, AND PHOTOGRAPHS YOU HAVE
+RECEIVED FROM JEFFREY EPSTEIN,
+1. AND/OR
+ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIGITAL, OF JEFFREY EPSTEIN,
+1, AND/OR
+ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS, OR
+TELEPHONE MESSAGES THAT YOU HAVE SENT TO AND/OR RECEIVED FROM JEFFREY EPSTEIN,
+, AND/OR
+Please coordinate your compliance of this subpoena and confirm the date and time of your
+appearance with Special Agent |
+, Federal Bureau of Investigation,
+Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+DATE:
+September 1, 2006
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the United States of America
+asistant U.S. Attorney
+Or son
+C. Vil alaid, Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Bench. 1. 33401-6235
+TOTAL P.ai
+
+
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-13
+SUBPOENA FOR:
+X PERSON
+X
+DOCUMENTS OR OBJECTISI
+YOUARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Room 4-A
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+DATE AND TIME:
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+August 25, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following document(s) or objects):
+ANY AND ALL NOTES, LETTERS, CARDS, GIFTS, PAYMENTS, AND PHOTOGRAPHS YOU HAVE
+RECEIVED FROM JEFFREY EPSTEIN
+, AND/OR
+ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIGITAL, OF JEFFREY EPSTEIN,
+AND/OR
+ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS, OR
+TELEPHONE MESSAGES THAT YOU HAVE SENTTO AND/OR RECEIVED FROM JEFFREY EPSTEIN,
+AND/OR
+Please coordinate your compliance of this subpoena and confirm the date and time of your
+appearance with Special Agent
+, Federal Bureau of Investigation,
+Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+STATES DISTRICT
+CLERK
+URT
+DATE:
+August 18, 2006
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the United States of America
+-Phone Number of Assistant U.S. Attorney
+1 Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. EL 33401-6235
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service and
+Statement of Service Fees is true and correct.
+Execuled on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2. "Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+ates or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Crimir
+ocedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 US
+
+
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-12/2
+SUBPOENA FOR:
+[X PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States Distric
+'ourt at the place, date and time specified below.
+PLACE:
+ROOM:
+Room 4-A
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+DATE AND TIME:
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+September 1, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+ANY AND ALL NOTES, LETTERS, CARDS, GIFTS, PAYMENTS, AND PHOTOGRAPHS YOU HAVE
+RECEIVED FROM JEFFREY EPSTEIN,
+AND/OR
+ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIGITAL, OF JEFFREY EPSTEIN,
+, AND/OR
+ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS, OR
+TELEPHONE MESSAGES THAT YOU HAVE SENT TO AND/OR RECEIVED FROM JEFFREY EPSTEIN,
+AND/OR
+Appearance rate yurial glance this subpoena and entral threat and into your,
+Federal Bureau of Investigation,
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+DATE:
+August 23, 2006
+(BY) DEPUTY CLERK
+HEY OSTRICT OF T
+Name. Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. FL. 33401-6235
+To be used in lica of AO110
+
+
+Unuted States District Court
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-12
+SUBPOENA FOR:
+X PERSON
+DOCUMENTS OR OBJECTIS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury ofthe United States Distric
+'ourt at the place, date and time specified below
+PLACE:
+ROOM:
+Room 4-A
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+DATE AND TIME:
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+August 25, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+ANY AND ALL NOTES, LETTERS, CARDS, GIFTS, PAYMENTS, AND PHOTOGRAPHS YOU HAVE
+RECEIVED FROM JEFFREY EPSTEIN,
+AND/OR
+ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIGITAL, OF JEFFREY EPSTEIN,
+AND/OR
+ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS, OR
+TELEPHONE MESSAGES THAT YOU HAVESENT TO AND/OR RECEIVED FROM JEFFREY EPSTEIN,
+AND/OR
+Please coordinate your compliance of this subpoena and confirm the date and time of your
+appearance with Special Agent
+Federal Bureau of Investigation,
+Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the United States of America
+DATE:
+August 18, 2006
+fer
+nd Phone Number of Assistant U.S. Attomney
+, Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. FI. 33401-6235
+To be used in lieu of AtIO
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+1 declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service and
+Statement of Service Fees is true and correct.
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+itates or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Crimina
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 US
+
+
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-12
+SUBPOENA FOR:
+X PERSON
+X
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+Palm Beach County Courthouse
+ROOM:
+Room 4-A
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+DATE AND TIME:
+August 25, 200
+(Temporary location for the United States District Courthouse, West Palm Beach)
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+ANY AND ALL NOTES, LETTERS, CARDS, GIFTS, PAYMENTS, AND PHOTOGRAPHS YOU HAVE
+RECEIVED FROM JEFFREY EPSTEIN,
+TAND/OR |
+ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIGITAL, OF JEFFREY EPSTEIN,
+AND/OR
+ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS, OR
+TELEPHONE MESSAGES THAT YOU HAVE SENT TO AND/OR RECEIVED FROM JEFFREY EPSTEIN,
+AND/OR
+Please coordinate your compliance of this subpoena and confirm the date and time of your
+appearance with Special Agent
+Federal Bureau of Investigation,
+Telephone: |
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+DATE:
+August 18, 2006
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+300 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+Statement or Service Pales of priu and ore he laves of the United States of America that the foregoling information contained in the Retum of Service and
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-11
+SUBPOENA FOR:
+] PERSON
+DOCUMENTS OR OBJECTISI
+YOUARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+ROOM:
+Room 4-A
+DATE AND TIME:
+August 25, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or object(s):
+Please coordinate your compliance of this subpoena and confirm the date and time of your
+appearance with Special Agent
+Federal Bureau of Investigation,
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+TATES DISTRICT
+COURT
+DATE:
+August 15, 2006
+CAN DESTRICT OFFA
+Name Address and Phone Number of Assistant U.S. Attorney
+_ Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL, 33401-6235
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contalned in the Return of Service an
+statement of Service Fees is true and correc
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+STATE ATTORNEY'S OFFICE
+15th Judicial Circuit of Florida
+Palm Beach County
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY -10/2
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Room 4-A
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+DATE AND TIME:
+September 15, 2006
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+Tapes or transcripts of any and all proceedings before the Grand Jury on Wednesday, July 19, 2006,
+referring or relating to Jeffrey Epstein and/or
+, including but not limited to witness
+testimony, statements made by any member of the State Attorney's Office, and instructions given by any
+member of the State Attorney's Office.
+Please coordinate vour compliance of this subpoena and confirm the date and time of your appearance wit!
+Federal Bureau of Investigation, Telephone:
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+DATE:
+August 28, 2006
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+SER OSTRICT OR TO
+Name Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+Wes Palm Bench. FI. 3401-6235
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service an
+tatement of Service Fees is true and correc
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+. Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the Unitec
+tates or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Crimina
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+15th Judicial Circuit of Florida
+Palm Beach County Courthouse
+205 North Dixie Highway
+West Palm Beach, FL 33401
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-10
+SUBPOENA FOR:
+] PERSON
+DOCUMENTS OR OBJECTIS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury ofthe United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Room 4-A
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+DATE AND TIME:
+August 18, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+relating to Jeffrey Epstein and/or
+Attorney's Office.
+Please coordinate vour compliance of this subpoena and confirm the date and time of your appearance with
+, Federal Bureau of Investigation, Telephone:
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+DATE:
+August 2, 2006
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+
+
+SERVED ON (NAME)
+RETURN OF SERVICE
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service an
+¡tatement of Service Fees is true and correc
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+1825, Rule 17(b) Federal Rules of Criminal Procedure*
+
+
+Unwed States District Court
+ROYAL PALM BEACH
+COMMUNITY HIGH
+10600 Okeechobee Blvd
+Royal Palm Beach, FL 33411
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-09
+SUBPOENA FOR:
+• PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Room 4-A
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+DATE AND TIME:
+August 18, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+Copies of any and all information and records related to the individuals listed on Attachment A, including
+but not limited to transcripts, disciplinary records, correspondence, awards, and guidance records.
+Please coordinate your compliance of this subpoena and confirm the date and time of your appearance with
+Federal Bureau of Investigation, Telephone:
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+DATE:
+August 2, 2006
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+Ethe Init
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. EL. 33401-6235
+To be used in lies of AO110
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+Stateneat of serpe fals of prue and orrehe laws of the United States of America that the foregoing information contained in the Retum of Service and
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+
+
+ATTACHMENT A
+Student Name
+Date of Birth
+
+
+TO: DTG OPERATIONS d/b/a
+Dollar Rent-a-Car
+2401 Turnage Blvd
+West Palm Beach, FL
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-08
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+ROOM:
+Room 4-A
+DATE AND TIME:
+August 18, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following document(s) or objects):
+Any and all information and records related to rental agreements utilizing VISA credit card number
+and/or the names of Jeffrey Epstein,
+Janusz Banasiak,
+and Alfredo Rodriguez.
+Please coordinate your compliance of this subpoena and confirm the date and time of your appearance with
+Federal Bureau of Investigation, Telephone:
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+DATE:
+August 2, 2006
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+if the linited States of Amerien
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL. 33401-6235
+To be used in licu of AO110
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service an
+tatement of Service Fees is true and corre
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+"Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the Unite
+tates or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Crimin
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+825, Rule 17(b) Federal Rules of Criminal Procedure)'
+
+
+David Neville Rodgers
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-07
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+Palm Beach County Courthouse
+ROOM:
+Room 4-A
+Juvenile Courts Building
+205 N. Dixie Highway
+DATE AND TIME:
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+August 18, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+Any and all information and records related to Jeffrey Epstein, Gulfstream Aircraft N909JE, and Boeing
+Aircraft N908JE, including but not limited to flight records, maintenance records, and passenger manifest
+records. Any and all records related to your employment, including but not limited to paystubs, W-2
+forms, correspondence, employment applications, and employment reviews.
+Please coordinate your compliance of this subpoena and confirm the date and time of your appearance with
+, Federal Bureau of Investigation, Telephone:
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+STATES DISTANCY
+DATE:
+August 2, 2006
+This subpoena is issued upon application
+Name Address and Phone Number of Assistant U.S. Attorney
+, Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Reach. EL. 33401-6235
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service an
+Statement of Service Fees is true and correc
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+
+
+TO: JEGE INC
+103 Foulk Road, Suite 202
+Wilmington, DE 19803
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-06
+SUBPOENA FOR:
+T PERSON
+X
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Room 4-A
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+DATE AND TIME:
+August 18, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+For the period of January 1, 2004 to the present, all flight data records, all records of incoming and
+outgoing flights to Palm Beach International Airport, and all passenger manifests for Boeing Aircraft
+N908JE, Model 727-31.
+All records relating to the ownership of Boeing Aircraft N908JE, Model 727-31.
+All records relating to the creation, incorporation, and management of JEGE Inc., including but not
+limited to shareholder names, names of board members, and employee names.
+Please coordinate your compliance of this subpoena and confirm the date and time of your appearance with
+Federal Bureau of Investigation, Telephone:
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+INTES DISTNEY
+COURT
+(BY) DEPUTY CLERK
+DATE:
+August 2, 2006
+CON OSTRICT OF T
+This subpoena is issued upon application
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL. 33401-6235
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+TRAVEL
+STATEMENT OF SERVICE FEES
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service and
+Statement of Service Fees is true and correct
+Executed on _
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+states or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Crimina
+rocedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 US
+
+
+HYPERION AIR INC
+103 Foulk Road, Suite 202
+Wilmington, DE 19803
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-05
+SUBPOENA FOR:
+7 PERSON
+X
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Room 4-A
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+DATE AND TIME:
+August 18, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+For the period of January 1, 2004 to the present, all flight data records, all records of incoming and
+outgoing flights to Palm Beach International Airport, and all passenger manifests for Gulfstream Aireraft
+N909JE, Model G1159B.
+All records relating to the ownership of Gulfstream Aircraft N909JE, Model G1159B.
+All records relating to the creation, incorporation, and management of Hyperion Air Inc., including but
+not limited to shareholder names, names of board members, and employee names.
+Please coordinate your compliance of this subpoena and confirm the date and time of your appearance with
+Federal Bureau of Investigation, Telephone:
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+DATE:
+August 2, 2006
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the United States of America
+PORN DISTRICT OF O
+Name, Address and Phone Number of Assistant U.S. Attorney
+• Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+
+
+SERVED ON (NAME)
+To be used in lies of AO110
+PLACE
+PLACE
+SERVED BY
+TITLE
+TRAVEL
+STATEMENT OF SERVICE FEES
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service and
+Statement of Service Fees is true and correct.
+Executed on _
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+
+
+TO: CHASE
+Subpoena Compliance
+7610 West Washington Street
+Indianapolis, IN 46231
+Fax
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-04
+SUBPOENA FOR:
+7 PERSON
+DOCUMENTS OR OBJECTISI
+YOUARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Room 4-A
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+DATE AND TIME:
+August 18, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+All applications, signature cards, credit or background investigations conducted, and correspondence
+related to Jeffrey Epstein,
+Janusz. Banasiak,
+Alfredo Rodriguez, and/or Mastercard Account Number
+For the period of January 1, 2004 to the present, all monthly billing statements, individual charge
+invoices, repayment records disclosing the dates, amounts, and method of renayment, and checks used
+to make repayments (front and back) for Mastercard Account Number
+Please coordinate your compliance of this subpoena and confirm the date and time of vour appearance with
+Federal Bureau of Investigation, Telephone:
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+DATE:
+August 2, 2006
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the Unitad Stato
+PSY ONS TRICT OR T
+Name. Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+1 declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service and
+Statement of Service Fees is true and correct.
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+
+
+TO: CAPITAL ONE
+Subpoena Compliance
+15000 Capital One Drive
+Richmond, VA 23238
+Fax
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY -03
+SUBPOENA FOR:
+] PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Palm Beach County Courthouse
+Room 4-A
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+DATE AND TIME:
+August 18, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+All applications, signature cards, credit or background investigations conducted, and correspondence
+related to Jeffrey Epstein,
+Janusz Banasiak,
+, Alfredo Rodriguez, and/or Mastercard Account Number
+For the period of January 1, 2004 to the present, all monthly billing statements, individual charge
+invoices, repayment records disclosing the dates, amounts, and method of repayment, and checks used
+to make repayments (front and back) for Mastercard Account Number
+'lease coordinate your compliance of this subpoena and confirm the date and time of your appearance witl
+Federal Bureau of Investigation, Telephone:
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+August 2, 2006
+This subpoena is issued upon application
+of the Inited States of Americ:
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. EL. 33401-6235
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Retum of Service an
+statement of Service Fees is true and correc
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+
+
+WASHINGTON MUTUAL
+P.O. BOX 9007
+Pleasanton, CA 94566
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-02
+SUBPOENA FOR:
+7 PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Room 4A
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+DATE AND TIME:
+August 18, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+All applications, signature cards, credit or background investigations conducted, and correspondence
+related to Jeffrey Epstein,
+- Janusz Banasiak,
+• Alfredo Rodriguez, and/or VISA Account Number
+For the period of January 1, 2004 to the present, all monthly billing statements, individual charge
+invoices, repayment records disclosing the dates, amounts, and method of renayment, and checks used
+to make repayments (front and back) for VISA Account Number
+Please coordinate your compliance of this subpoena and confirm the date and time of your appearance with
+Federal Bureau of Investigation, Telephone:
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+STATES DISTANCE
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+August 2, 2006
+This subpoena is issued upon application
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL. 33401-6235
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service anc
+Statement of Service Fees is true and correct
+Executed on DATE
+Signature of Server
+Address of Server
+1 is to ho ederal as of Civil Proced the manner of its service see Rule 17d). Federal Rules of Criminal Proceduro, or
+
+
+TO: COLONIAL BANK
+Attn: Anita Muller
+Research Department
+1853 Data Drive
+Hoover, AL 35243
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-01
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Room 4-A
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+DATE AND TIME:
+August 18, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following document(s) or objects):
+All applications, signature cards, credit or background investigations conducted, and correspondence
+related to Jeffrey Epstein,
+Janusz Banasiak,
+, Alfredo Rodriguez, and/or VISA Account Number
+For the period of January 1, 2004 to the present, all monthly billing statements, individual charge
+invoices, repayment records disclosing the dates, amounts, and method of repayment, and checks used
+to make repayments (front and back) for VISA Account Number
+Please coordinate vour compliance of this subpoena and confirm the date and time of your appearance with
+Special Agent/
+Federal Bureau of Investigation, Telephone:|
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+DATE:
+August 2, 2006
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+ON CASTACT OF FAN
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+To be used in lica of A0110
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service an
+Statement of Service Fees is true and correc
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+
+
+U.S. Departn
+: of Justice
+500 South Australian Avenue, Suite 400
+West Balm Reach, FL 33401
+(Fax)
+May 16, 2007
+United States District Court Judge
+701 Clematis Street
+West Palm Beach, Florida 33401
+RE: Grand Jury 07-103(WPB), Disclosure of Grand Jury Material
+Dear Judge Middlebrooks:
+This office wishes to report to the court, consistent with Fed. R. Crim. P. 6(e)(3)(B), the
+disclosure to government personnel of grand jury material. The disclosure is deemed necessary by an
+attorney for the government to assist an attorney for the government in the enforcement of such
+attorney's duty to enforce federal criminal law, as provided in Fed. R. Crim. P. 6(e)(3)(A)(ii).
+The disclosure, of material of Federal Grand Jury 07-103(WPB), in regard to Investigative
+Matter, In Re: Operation Leap Year, has been and will be made to additional persons listed on the
+attached sheet. This material is being re-presented due to the expiration of Federal Grand Jury 05-
+02(WPB). These persons have been advised of their obligation of secrecy under Fed. R. Crim. P. 6(e).
+It is requested that the court direct that the letter and list be placed in the subject grand jury file,
+and that the court return a copy of the acknowledged letter and list in the enclosed envelope for
+maintenance in the files of this office.
+Sincerely,
+
+
+The Court acknowledges receipt of the above letter with attached list and directs the
+Clerk of the Court to place a copy in the subject grand jury file.
+Done and ordered this. 18 day or M
+
+
+Disclosure of material of Federal Grand Jury 07-103(WPB) in regard to Investigative
+Matter, In Re: Matter of Operation Leap Year, has been and will be made to the additional
+government personnel listed below:
+FBI - 505 S. Flagler Drive, Suite 500, West Palm Beach, FL 33401
+Investigative Analyst
+Paralegal Specialist
+Investigative Support Specialist
+Investigative Support Specialist
+
+
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+Fax)
+May 16, 2007
+United States District Court Judge
+701 Clematis Street
+West Palm Beach, Florida 33401
+RE: Grand Jury 07-103(WPB), Disclosure of Grand Jury Material
+Dear Judge Middlebrooks:
+This office wishes to report to the court, consistent with Fed. R. Crim. P. 6(e)(3)(B), the
+disclosure to government personnel of grand jury material. The disclosure is deemed necessary by an
+attorney for the government to assist an attorney for the government in the enforcement of such
+attorney's duty to enforce federal criminal law, as provided in Fed. R. Crim. P. 6(e)(3)(A)(ii).
+The disclosure, of material of Federal Grand Jury 07-103(WPB), in regard to Investigative
+Matter, In Re: Operation Leap Year, has been and will be made to additional persons listed on the
+attached sheet. This material is being re-presented due to the expiration of Federal Grand Jury 05-
+02(WPB). These persons have been advised of their obligation of secrecy under Fed. R. Crim. P. 6(e).
+It is requested that the court direct that the letter and list be placed in the subject grand jury file,
+and that the court return a copy of the acknowledged letter and list in the enclosed envelope for
+maintenance in the files of this office.
+Sincerely,
+LINITED STATES MORNEV
+By
+
+
+The Court acknowledges receipt of the above letter with attached list and directs the
+Clerk of the Court to place a copy in the subject grand jury file.
+Done and ordered this
+_day of
+, 2007.
+
+
+Disclosure of material of Federal Grand Jury 07-103(WPB) in regard to Investigative
+Matter, In Re: Matter of Operation Leap Year, has been and will be made to the additional
+government personnel listed below:
+FBI - 505 S. Flagler Drive, Suite 500, West Palm Beach, FL 33401
+, Investigative Analyst
+Paralegal Specialist
+, Investigative Support Specialist
+, Investigative Support Specialist
+
+
+U.S. Departr
+at of Justice
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+(Fax)
+February 13, 2007
+United States District Court Judge
+701 Clematis Street
+West Palm Beach, Florida 33401
+RE: Grand Jury 07-103(WPB), Disclosure of Grand Jury Material
+Dear Judge Middlebrooks:
+This office wishes to report to the court, consistent with Fed. R. Crim. P. 6(e)(3)(B), the
+disclosure to government personnel of grand jury material. The disclosure is deemed necessary by an
+attorney for the government to assist an attorney for the government in the enforcement of such
+attorney's duty to enforce federal criminal law, as provided in Fed. R. Crim. P. 6(e)(3)(A)(ii).
+The disclosure, of material of Federal Grand Jury 07-103(WPB), in regard to Investigative
+Matter, In Re: Operation Leap Year, has been and will be made to persons listed on the attached sheet.
+This material is being re-presented due to the expiration of Federal Grand Jury 05-02(WPB). These
+persons have been advised of their obligation of secrecy under Fed. R. Crim. P. 6(e).
+It is requested that the court direct that the letter and list be placed in the subject grand jury file,
+and that the court return a copy of the acknowledged letter and list in the enclosed envelope for
+maintenance in the files of this office.
+Sincerely,
+UNITED STATES AVIORNEY
+
+
+Disclosure of material of Federal Grand Jury 07-103(WPB) in regard to Investigative
+Matter, In Re: Matter of Operation Leap Year, has been and will be made to government
+personnel listed below:
+FBI - 505 S. Flagler Drive, Suite 500, West Palm Beach, FL 33401
+Clerical Assistant
+
+
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+(Fax)
+February 13, 2007
+United States District Court Judge
+701 Clematis Street
+West Palm Beach, Florida 33401
+RE: Grand Jury 07-103(WPB), Disclosure of Grand Jury Material
+Dear Judge Middlebrooks:
+This office wishes to report to the court, consistent with Fed. R. Crim. P. 6(e)(3)(B), the
+disclosure to government personnel of grand jury material. The disclosure is deemed necessary by an
+attorney for the government to assist an attorney for the government in the enforcement of such
+attorney's duty to enforce federal criminal law, as provided in Fed. R. Crim. P. 6(e)(3)(A)(ii).
+The disclosure, of material of Federal Grand Jury 07-103(WPB), in regard to Investigative
+Matter, In Re: Operation Leap Year, has been and will be made to persons listed on the attached sheet.
+This material is being re-presented due to the expiration of Federal Grand Jury 05-02(WPB). These
+persons have been advised of their obligation of secrecy under Fed. R. Crim. P. 6(e).
+It is requested that the court direct that the letter and list be placed in the subject grand jury file,
+and that the court return a copy of the acknowledged letter and list in the enclosed envelope for
+maintenance in the files of this office.
+Sincerely,
+ASSISTANI UNITED STATES ATTORNEY
+
+
+The Court acknowledges receipt of the above letter with attached list and directs the
+Clerk of the Court to place a copy in the subject grand jury file.
+day of
+_, 2007.
+
+
+Disclosure of material of Federal Grand Jury 07-103(WPB) in regard to Investigative
+Matter, In Re: Matter of Operation Leap Year, has been and will be made to government
+personnel listed below:
+FBI - 505 S. Flagler Drive, Suite 500, West Palm Beach, FL 33401
+Clerical Assistant
+
+
+U.S. Departr
+500 South Australian Avenue, Suite 40
+Vest Palm Beach, FL 3340
+(Fax)
+January 24, 2007
+United States District Court Judge
+701 Clematis Street
+West Palm Beach, Florida 33401
+RE: Grand Jury 07-103(WPB), Disclosure of Grand Jury Material
+Dear Judge Middlebrooks:
+This office wishes to report to the court, consistent with Fed. R. Crim. P. 6(e)(3)(B), the
+disclosure to government personnel of grand jury material. The disclosure is deemed necessary by an
+attorney for the government to assist an attorney for the government in the enforcement of such
+attorney's duty to enforce federal criminal law, as provided in Fed. R. Crim. P. 6(e)(3)(A)(ii).
+The disclosure, of material of Federal Grand Jury 07-103(WPB), in regard to Investigative
+Matter, In Re: Operation Leap Year, has been and will be made to persons listed on the attached sheet.
+This material is being re-presented due to the expiration of Federal Grand Jury 05-02(WPB). These
+persons have been advised of their obligation of secrecy under Fed. R. Crim. P. 6(e).
+It is requested that the court direct that the letter and list be placed in the subject grand jury file,
+and that the court return a copy of the acknowledged letter and list in the enclosed envelope for
+maintenance in the files of this office.
+Sincerely,
+INITED STATES ATTORNEY
+
+
+The Court acknowledges receipt of the above letter with attached list and directs the
+Clerk of the Court to place a copy in the subject grand jury file.
+Done and ordered this?
+Honorablé Donald M. Middlebrooks
+
+
+Disclosure of material of Federal Grand Jury 07-103(WPB) in regard to Investigative
+Matter, In Re: Matter of Operation Leap Year, has been and will be made to government
+personnel listed below:
+FBI - 505 S. Flagler Drive, Suite 500, West Palm Beach, FL 33401
+, Supervisory Special Agent
+, Analyst
+Analyst
+ICE - 501 S. Flagler Drive, Suite 501, West Palm Beach, FL 33401
+Group Supervisor
+Resident Agent-In-Charge
+
+
+i Justice
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL. 33401
+(Fax)
+January 24, 2007
+United States District Court Judge
+701 Clematis Street
+West Palm Beach, Florida 33401
+RE: Grand Jury 07-103(WPB), Disclosure of Grand Jury Material
+Dear Judge Middlebrooks:
+This office wishes to report to the court, consistent with Fed. R. Crim. P. 6(e)(3)(B), the
+disclosure to government personnel of grand jury material. The disclosure is deemed necessary by an
+attorney for the government to assist an attorney for the government in the enforcement of such
+attorney's duty to enforce federal criminal law, as provided in Fed. R. Crim. P. 6(e)(3)(A)(ii).
+The disclosure, of material of Federal Grand Jury 07-103(WPB), in regard to Investigative
+Matter, In Re: Operation Leap Year, has been and will be made to persons listed on the attached sheet.
+This material is being re-presented due to the expiration of Federal Grand Jury 05-02(WPB). These
+persons have been advised of their obligation of secrecy under Fed. R. Crim. P. 6(e).
+It is requested that the court direct that the letter and list be placed in the subject grand jury file,
+and that the court return a copy of the acknowledged letter and list in the enclosed envelope for
+maintenance in the files of this office.
+Sincerely,
+
+
+Disclosure of material of Federal Grand Jury 07-103(WPB) in regard to Investigative
+Matter, In Re: Matter of Operation Leap Year, has been and will be made to government
+personnel listed below:
+FBI - 505 S. Flagler Drive, Suite 500, West Palm Beach, FL 33401
+Supervisory Special Agent
+Analyst
+Analyst
+ICE - 501 S. Flagler Drive, Suite 501, West Palm Beach, FL 33401
+Group Supervisor
+Resident Agent-In-Charge
+
+
+The Court acknowledges receipt of the above letter with attached list and directs the
+Clerk of the Court to place a copy in the subject grand jury file.
+day of
+- 2007.
+
+
+COPY
+U.S. Departmen. f Justice
+500 Australian Avenue, Suite 400
+West Pala Beach Florida 33401
+August 23, 2006
+Honorable Daniel T.K. Hurley
+United States District Court Judge
+701 Clematis Street
+West Palm Beach, Florida 33401
+RE: Grand Jury 05-02(WPB), Disclosure of Grand Jury Material
+Dear Judge Hurley:
+This office wishes to report to the court, consistent with Fed. R. Crim. P. 6(e)(3)(B), the
+disclosure to government personnel of grand jury material. The disclosure is deemed necessary by
+an attorney for the government to assist an attorney for the government in the enforcement of such
+attorney's duty to enforce federal criminal law, as provided in Fed. R. Crim. P. 6(e)(3)(A)(ii).
+The disclosure, of material of Federal Grand Jury 05-02(WPB), in regard to Investigative
+Matter, In Re: Operation Leap Year, has been and will be made to persons listed on the attached
+sheet. These persons have been advised of their obligation of secrecy under Fed. R. Crim. P. 6(e).
+It is requested that the court direct that the letter and list be placed in the subject grand jury
+file, and that the court return a copy of the acknowledged letter and list in the enclosed envelope for
+maintenance in the files of this office.
+Sincerely,
+ASSISTANT UNITED STATES ĂTTORNEY
+
+
+
+СОБЛ
+
+The Court acknowledges receipt of the above letter with attached list and directs the
+Clerk of the Court to place a copy in the subject grand jury file.
+day of _
+- 2006.
+Honorable Daniel T.K. Hurley
+
+
+Disclosure of material of Federal Grand Jury 05-02(WPB) in regard to Investigative
+Matter, In Re: Matter of Operation Leap Year, has been and will be made to government
+personnel listed below:
+FBI - 505 S. Flagler Drive, Suite 500, West Palm Beach, FL 33401
+Supervisory Special Agent
+,, Special Agent
+r, Special Agent
+ICE - 501 S. Flagler Drive, Suite 501, West Palm Beach, FL 33401
+Group Supervisor
+. Resident Agent-In-Charge
+* Special Agent
+, Special Agent
+15'" JUDICIAL CIRCUIT COURT OF FLORIDA - Main Judicial Complex, 205 N. Dixie
+Highway, Room 5.2500, West Palm Beach, FL 33401
+Honorable Chief Judge Kathleen Kroll
+STATE ATTORNEY'S OFFICE - 401 N. Dixie Highway, West Palm Beach, FL 33401
+State Attorney
+, Assistant State Attorney
+
+
+Federal Express
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-79
+SUBPOENA FOR:
+X PERSON
+X
+DOCUMENTS OR OBJECTISI
+YOUARE HEREBY COMMANDED to appear and testify beforethe Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+spay 19, 2008
+YOU ARE ALSO COMMANDED to bring with you the following document(s) or objects):
+See attachments
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+STATES INSTAIGH
+RIT
+DATE:
+January 29, 2008
+This subpoena is issued upon application
+IN OSTRICT OF TON
+Name, Address and Phone Number of Assistant U.S. Attorney
+L Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. EL. 33401-6235
+
+
+3Y SERVER
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+TRAVEL
+STATEMENT OF SERVICE FEES
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service a
+tatement of Service Fees is true and corre
+Executed on.
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+
+
+FEDERAL EXPRESS
+FGJ 07-103 OLY-79
+(1)
+For the period of January 1, 2001 to the present:
+All documents and information referring or relating to shipments from or to any of
+the following individuals, addresses, or account numbers::
+Federal Express Account #
+Jeffrey Epstein
+Lesley Groff
+358 El Brillo Way, Palm Beach, FL
+Little St. James, U.S. Virgin Islands
+J. Epstein & Company
+Financial Trust Company
+Epstein Interests
+New York Strategy Group
+Janusz Banasiak
+1430 Suwanee Drive, West Palm Beach, FL 33409
+J. Epstein Virgin Islands Foundation
+The information requested includes, but is not limited to, account information
+(including user name(s), passwords), payment information, billing information, billing
+address(es) and e-mail address(es)), shipment addresses, addressee names,
+correspondence, e-mail correspondence, and credit card/payment information.
+
+
+OLY-79 ADDRESSED TO
+FEDERAL EXPRESS
+/
+CERTIFICATION REGARDING DOMESTIC RECORDS
+OF REGULARLY CONDUCTED ACTIVITY
+Federal Express, in the position of
+→ declare that I am employed by
+, and, by reason of my
+position, am authorized and qualified to make this declaration.
+Through my employment with Federal Express, I am familiar with the business
+records it maintains.
+2.
+(a)
+I certify that the records attached to this certification:
+(b)
+(c)
+were made at or near the time of the occurrence of the matters set forth
+therein, by or from information transmitted by, a person with knowledge of
+those matters;
+were kept in the course of regularly conducted business activity; and
+were made by the regularly conducted activity as a regular practice.
+2.
+Among the records so maintained are the attached records itemized in Appendix A
+
+
+
+I further certify that the documents attached hereto are responsive to the Grand Jury
+Subpoena served upon Federal Express.
+Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing
+information is true and correct.
+Executed this
+day of
+_ 2008.
+
+
+
+
+
+The attached subpoena duces tecum for records from your office is served upon
+you in connection with the investigation of suspected violations of federal criminal law.
+Pursuant to an official criminal investigation being conducted by this office, you are
+requested not to disclose the existence of this request or your compliance to anyone. Any
+such disclosure could obstruct and impede the investigation and thereby interfere with the
+
+
+Amazon.com
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-78
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+February 19, 200
+1:00pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+See attachments
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+January 29, 2008
+This subpoena is issued upon application
+file limitad Orator
+Name, Address and Phone Number of Assistant U.S. Attorney
+, Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+To be used in licu of AOI10
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+TRAVEL
+STATEMENT OF SERVICE FEES
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service and
+Statement of Service Fees is true and correct
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+. Fees and mileage need not be tendered to the witness upon service of à subpoena issued on behalf of the Uniter
+states or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Crimina
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+AMAZON.COM
+FGJ 07-103 OLY-78
+(1)
+For the period of January 1, 2001 to the present:
+All documents and information referring or relating to orders from and/or shipments
+to any of the following individuals or addresses:
+Jeffrey Epstein
+Lesley Groff
+358 El Brillo Way, Palm Beach, FL
+Little St. James, U.S. Virain Islands
+J. Epstein & Company
+Financial Trust Company
+Epstein Interests
+New York Strategy Group
+Janusz Banasiak
+(2)
+All documents and information referring or relating to
+Order I.D. #
+with shipping date September 4, 2005.
+The information requested includes, but is not limited to, account information
+(including user name(s), password(s), payment information, billing information, billing, e-
+mail, and shipment addresses), IP address records, e-mail correspondence, and credit
+card/payment information.
+
+
+OLY-78 ADDRESSED TO
+AMAZON.COM
+CERTIFICATION REGARDING DOMESTIC RECORDS
+OF REGULARLY CONDUCTED ACTIVITY
+declare that I am employed by
+Amazon.com, in the position of
+and, by reason of my
+position, am authorized and qualified to make this declaration.
+1.
+Through my employment with Amazon.com, I am familiar with the business records
+it maintains.
+I certify that the records attached to this certification:
+(a)
+(b)
+(c)
+were made at or near the time of the occurrence of the matters set forth
+therein, by or from information transmitted by, a person with knowledge of
+those matters;
+were kept in the course of regularly conducted business activity; and
+were made by the regularly conducted activity as a regular practice.
+2.
+Among the records so maintained are the attached records itemized in Appendix A
+
+
+
+I further certify that the documents attached hereto are responsive to the Grand Jury
+Subpoena served upon Amazon.com.
+Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing
+information is true and correct.
+Executed this
+day of
+2008.
+
+
+
+
+
+The attached subpoena duces tecum for records from your office is served upon
+you in connection with the investigation of suspected violations of federal criminal law.
+Pursuant to an official criminal investigation being conducted by this office, you are
+requested not to disclose the existence of this request or your compliance to anyone. Any
+such disclosure could obstruct and impede the investigation and thereby interfere with the
+
+
+Live Nation Theatrical/Broadway
+Across America
+500 E. Broward Boulevard
+Fort Lauderdale, FL
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-67/2
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTIS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+July 17, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+The will call lists) dated February 1 and 2, 2005 pertaining to the David Copperfield performances.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+CATES DISTNGTCO
+DATE:
+June 27, 2007
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the United States of America
+"If not applicable, enter "none."
+fo
+Ann
+Phone Number of Assistant U.S. Attorney
+C. Villafaña, Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+To be used in lieu of AOI10
+
+
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401-6235
+(561) 820-8711
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+authenticity. Therefore, you may be able to avoid appearing personally at the grand
+jury/trial at the time and place specified by completely filling out the attached Certification
+and Inventory and immediately returning it with the records to Special Agent
+, FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to July 17, 2007.
+Sincerely,
+fr
+
+
+OLY-67 ADDRESSED TO
+LIVE NATION THEATRICAL/BROADWAY
+ACROSS AMERICA
+CERTIFICATION REGARDING DOMESTIC RECORDS
+OF REGULARLY CONDUCTED ACTIVITY
+_ declare that I am employed by
+Live Nation Theatrical/Broadway Across America, in the position of
+_ and, by reason of my position, am authorized and qualified
+to make this declaration.
+Through my employment with Live Nation Theatrical/Broadway Across America,
+I am familiar with the business records it maintains.
+I certify that the records attached to this certification:
+(a)
+were made at or near the time of the occurrence of the matters set forth
+therein, by or from information transmitted by, a person with knowledge of
+those matters;
+(b)
+were kept in the course of regularly conducted business activity; and
+(c)
+were made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A
+
+
+
+3.
+I further certify that the documents attached hereto are responsive to the Grand Jury
+Subpoena served upon Live Nation Theatrical/Broadway Across America.
+Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing
+information is true and correct.
+Executed this
+day of
+_ 2007.
+
+
+
+
+
+TO: Chase Bank USA, N.A.
+National Subpoena Processing
+7610 W. Washington Street
+IN1-4054
+Indianapolis, IN 46231
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-32
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 13, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):
+See attachments
+*Please coordinate your compliance with this subnoena and confirm the date and time, and location of
+your appearance with Special Agent
+, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+DATE:
+March 2, 2007
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+Erho Ilaitor
+* If not applicable, enter "none."
+Name. Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. EL 33401-6235
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service an
+statement of Service Fees is true and correct
+Executed on.
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+
+
+FGJ 07-103 OLY-32
+1. For the period of 1/1/04 through 12/31/06
+For the following individuals/entities:
+Janusz Banasiak [or Banasiar]
+Ghislaine Maxwell
+Jeffrey Epstein
+(a) All account applications, account opening documents, signature cards, deposit slips,
+correspondence, account statements; and canceled checks (front and back).
+(b) For any and all credit cards, debit cards, lines of credit, mortgages, and/or loans, all
+monthly billing statements, individual charge invoices, payment records disclosing the
+dates, amounts, and method of payment, and checks used to make payments (front and
+back).
+This includes but is not limited to, the following VISA accounts:
+2. Any and all documents and information related to the following transaction:
+Date
+Pavee
+Amount
+
+
+500 S. Australian Ave., Suite 400
+Hes Palm Bicach, FL 33401-6235
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+authenticity. Therefore, you may be able to avoid appearing personally at the grand
+jury/trial at the time and place specified by completely filling out the attached Certification
+and Inventory and immediately returning it with the records to Special Agent
+, FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to March 13, 2007.
+Sincerely,
+
+
+position of
+_. declare that l am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+
+
+
+
+Purchase Order, Receiving Report)
+This form shall only be used when requesting financial records of individuals ad partnerships of five or fewer individuals,
+1 Purchase Order Number:
+2 Date Order Prepared:
+3/2/2007
+Section A - Authorization and Purchase Order
+4 Name and Address of Financial Institution:
+3 Case Number: (Oprional)
+FGJ 07-103(WPB) No. OLY-32
+5 Deliver To:
+FBI Special Agent
+16 Return Date:
+3/13/2007
+7 Remarks:
+FOR REIMBURSEMENT PLEASE RETURN THIS FORM, THE RECORD OF
+SERVICES, AND A COPY OF THE SUBPOENA.
+8 Name of Requestor: (Type or Print)
+AUSA
+9 Telephone Number:
+10 Date of request:
+3/2/2007
+Section B - Financial Institution Invoice
+No Payment Shall Be Made Unless Expenses Are Itemized Below Or On Your Form To Be Attached.
+| Service/Financial Records Provided:
+Quantity
+Unit Price
+- Amount
+Cost
+Per
+FOR PROMPT PAYMENT INCLUDE TAX I.D. NUMBER.
+Please note that reimbursement cannot be made for the records pertaining to
+corporations or large partnerships of six or more. IMPORTANT: The DCIA
+Mandates the use of EFT/DD. In order to receive payment complete the
+attached EFT enrollment form.
+0.25
+Copy
+11.00
+Hour Clerical
+Tech
+17.00
+Hour Manger
+or
+Supervisor
+Do not proceed with compliance: If cost will exceed $500 without prior approval of
+Budget Officer Lazaro Feliciano. Fax any request to (305) 530-7679
+12 Signature of Financial Institution Official:
+13 Date Signed:
+Total Amount Claimed
+By Financial Institutior
+Section C - Receiving Report
+16 Disallowance
+(See Attached)
+14 I certify that the articles and services listed were received:
+15 Date Received:
+17 Net to
+Financial
+Institution
+18 Right to Financial Privacy Act - Public Law 95-630
+19 Signature of Approving Official:
+(12 U.S.C. 3401-3422) Request Pursuant To: (Check One Only)
+SECTION
+• 3404
+Customer Authorization
+• 3405
+Administrative Subpoena or Summons
+• 3406
+Search Warrant
+• 3407
+Judicial Subpoma
+• 3408
+Formal Written Request
+• 3413 1 Grand Jury Subpoena
+• 3414
+Special Procedures
+ОВЛЕСТ
+CLASS
+2540
+2541
+2542
+2543
+2544
+2545
+2546
+20 Accounting Classification Code
+FY FC
+1
+2
+3
+4
+21 Schedule and Voucher Number:
+DCN
+5
+22 Remarks:
+• Funds Available
+Budget Officer:
+This form was electronically produced by Elite Federal Forms, Inc
+0.00
+PROJ
+FORM OBD-21
+APR. 8
+
+
+This is a multi-purpose form designed to serve as an Authorization, Purchase Order, Itemized Invoice, Receiving Report and Payment voucher in
+conjunction with "requests for financial information," pursuant to the Right toFinancial Privacy Act of 1978, P.L. 95-630, Title XI, 12 U.S.C. 3415
+NOTE:
+Payments under this purchase order will be due on the 30th calendar day after the date of actual receipt of' a proper invoice in the office designated to receive
+the invoice. the date of the check issued in payment shall be considered to be the date payment is made.
+The Prop Paymen Are rubie pay 2-17 proper is is a pelicable to parentered ere it pur mace one and receives the promenas or
+the Prompt Payment Act and the Office of Management and Budget Circular A-125.
+PREPARATION INSTRUCTIONS
+ITEM 1 - A Purchase Order Number will be preprinted on each form. This number will be used for reference purposes on any correspondence relating to this spedfic
+request for financial information.
+ITEM 2 - Self explanatory.
+ITEM 3 - This block may be used to idatify the specific case for which the fimncial information is required. This bloc may be left blank.
+SECTION A - AUTHORIZATION AND PURCHASE ORDER (To be completed by the requestingofficial).
+ITEM 4 - Enter the name and mailing address of the financial institution beingrequested to fumish financial information.
+ITEM 5 - Enter the name and address to which the financial information is to besent by the financial institution. This will normally be the name and addressof the
+requesting official.
+ITEM 6 - Enter the date the financial information is required.
+ITEM 7 - Include, if appropriate, any pertinent information related to the purhase order not provided for elsewhere on the form.
+ITEM 8, 9 and 10 - Seif-explanatory.
+SECTION B - FINANCIAL INSTITUTION INVOICE (To be completed by the financial intitution).
+ITEM 11 - Self-explanatory. Completion of this block constitutes an itemized bill or invoice for reimbursement for the costs incurred in providing the information
+requested.
+ITEM 12 and 13 - Self-explanatory.
+SECTION C - RECEIVING REPORT (To be completed by the requesting official, whenthe requested financial information has been delivered).
+ITEM 14 and 15 - Self'-explanatory.
+ITEM 16 - This block should be used to reflect any differences between the amount claimed by the financial instiution and the correct amount to be reimbursed
+Ditferences may result from computation erros, or failure of the financial inditution to deliver information mauested.
+ITEM 17 - Enter the amount certified to be proper for payment.
+TEM 18 - Check the box which identifies the appropriate procedure authorized by the Act, which necessitates the request for financial information.
+TEM 19 and 20 - These blocks must be signed and dated by an official of the oganization whose funds will be charged. His or her signature constitutes a staement that the
+records to which the invoice refers were required for official business and were provided by the financial institution in accordance with the ordering instrunent
+ITEM 21 - The Schedule and Voucher Number will be entered by the office which actually schedules the approved amount for payment by the Treasury Department.
+ITEM 22 - Enter, if appropriate, any data not provided for elsewhere on the reeiving report, such as, reasons for any claim amounts disallowed
+
+
+Please comply to this information if you have not done so already
+PAYEE/COMPANY INFORMATION:
+Vendor Company Name:
+Address:
+Taxpayer ID Number
+Contact Person Name
+Telephone Number
+FINANCIAL INSTITUTION INFORMATION:
+Bank Name
+Bank Address
+Bank Phone Number
+Nine Digit ABA Routing Transit Number
+Type of Account (Checking or Saving)
+Depositor Account Number
+Name & Title of Authorizing
+Official
+Please Return or Fax to:
+U.S. Attorney's Office
+99 NE 4 street, Suite 200
+Miami, FL
+33132
+Attention:
+Fax Number:
+if you have questions regarding the delivery of the remittance information, please contact the financial institution where
+your account is held
+If you have any questions on the completion of this form, please contact Claudia Castellanos, at
+APR. 34
+Page 3 of3
+
+
+JPMorganChase G
+MR20060809059376 B
+February 27, 2007
+S/A
+Federal Bureau of Investigation
+05 South Flagler Drive, Suite 50
+Vest Palm Beach. Florida 33401-592
+RE: Grand Jury Subpoena - Janusz Banasiak
+Dear S/A
+Chase Bank USA, N.A. is in receipt of the above referenced request. In order for you to
+obtain information relating to a Chase Bank USA, N.A. credit card account customer,
+your subpoena must be issued to:
+National Subpoena Processing
+7610 W. Washington St., IN1-4054
+Indianapolis, IN 46231
+The Bank will be pleased to comply with your request upon receipt of this properly
+addressed subpoena. You may fax this back
+to my attention at
+Should you have any questions regarding this matter, please do not hesitate to contact me
+Very truly yours,
+Jeff Sehr
+Legal Processing Specialist
+JPMorgan Chase Bank, N.A. • 7610 West Washington Street, Indianapolis, IN 46231
+Telephone:
+• Facsimile:
+
+
+FEB-26-2007 14:57
+FBI WEST PALM BEACH RF
+#820000809019378.
+United States District Couri
+P.01
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-32
+SUBPOENA FOR:
+PERSON
+X
+DOCUMENTS OR OBJECTS):
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District .
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 6, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or object(s):
+See attachments
+•
+07 FEB 27 AM 8: 19
+INCIANAPOLIS
+SUBPOENA PROCESSING
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone: :
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+February 14, 2007
+This subpoena is issued upon application
+of the United Stares of America-
+•If nol applicable, chier "nonc."
+Name, Address and Phone Number of Assistant U.S. Anorney
+Assistant U.S. Attorney
+S00 So. Australian Avenuo, Suite 400
+West Palm Beach, FL 33401-6235
+To be wed in leu of AO110
+JAN B0
+
+
+12007
+14:58
+FBI WEST PALM BEACH
+RA
+P.02
+JP Morgan Chase
+FGJ 07-103 OLY-32
+1. For the period of 1/1/04 through 12/31/08
+For the following individuals/entities:
+Janusz Banasiak [or Banasiar]
+Ghislaine Maxwell
+Jeffrey Epstein
+(a) All account applications, account opening documents, signature cards, deposit slips,
+correspondence, account statements; and canceled checks (front and back).
+(b) For any and all credit cards, debit cards, lines of credit, mortgages, and/or loans, all
+monthly billing statements, individual charge invoices, payment records disclosing the
+dates, amounts, and method of payment, and checks used to make payments (front and
+back).
+• This includes but is not limited to, the following VISA accounts:
+2. Any and all documents and information related to the following transaction:
+Date
+Pave
+Amount
+
+
+TO: Perry Bard, DC
+Health First Chiropractic Center
+4275 Okeechobee Blvd.
+West Palm Beach, FL 33409
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-38
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 13, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or object(s):
+All documents referring or relating to Jeffrey Epstein, including but not limited to billing statements,
+record of payments, appointment books, treatment notes, and correspondence.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of t
+COURT
+DATE:
+March 2, 2007
+PEN DETACT OR IS
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+*If noteppreadie, enter tone:
+To be used in lieu of AO11O
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service and
+Statement of Service Fees is true and correct.
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2. "Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+states or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Crimina
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 US
+
+
+00 S. Australian Ave, Suite 40
+Yest Palm Beach, FL 33401-623
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+authenticity. Theretore, you may be able to avoid appearing personally at the grand
+Jury/trial at the time and place specified by completely filling out the attached Certification
+and Inventory and immediately returning it with the records to Special Agent
+, FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to March 13, 2007.
+Sincerely,
+
+
+position of
+, declare that 1 am:
+in the
+_and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters. set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+
+
+
+
+TO: Thomas Rofrano
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-33
+SUBPOENA FOR:
+X PERSON
+DOCUMENTS OR OBJECTIS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 13, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+All documents referring or relating to Jeffrey Epstein, including but not limited to billing statements,
+record of payments, appointment books, treatment notes, and correspondence.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+March 2, 2007
+This subpoena is issued upon application
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+To be used in lieu of AQLIO
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+TRAVEL
+STATEMENT OF SERVICE FEES
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service ar
+atement of Service Fees is true and corre
+Execuled on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on' behalf of the United
+States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+ecoras may be admitted at trial through the declaration of a custodian, if they are provide
+ufficiently in advance of trial to allow an opportunity for any challenges to thei
+autnenticity. Therefore, you may be able to avoid appearing personally at the grand
+ury/trial at the time and place specified by completely filling out the attached Certification
+and Inventory and immediately returning it with the records to Special Agent
+FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+• West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to March 13, 2007.
+Sincerely,
+
+
+position of
+, declare that 1 am:
+in the
+_and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regulariy conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+
+
+
+
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-34
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 13, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+All documents referring or relating to Jeffrey Epstein, including but not limited to billing statements,
+record of payments, appointment books, treatment notes, and correspondence.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+March 2, 2007
+This subpoena is issued upon application
+HEY DETACT CATER
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+To be used in lieu of AOTIO
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+statemeanor serce fate i pre and cor the laws of the United Stalos of America that the foregoing information contained in the Retum of Service and
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+tates or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Crimin
+rocedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 US
+1825, Rule 17(b) Federal Rules of Criminal Procedure)
+
+
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401-6235
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sutticiently in advance of trial to allow an opportunity for any challenges to their
+authenticity. Therefore, you may be able to avoid appearing personally at the grand
+jury/trial at the time and place specified by completely filling out the attached Certification
+and Inventory and immediately returning it with the records to Special Agent
+FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to March 13, 200Z.
+Sincerely,
+B
+
+
+position of
+_ declare that I am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+1 declare under penalty of perjury that the foregoing is true and correct.
+
+
+
+
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-35
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 13, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+All documents referring or relating to Jeffrey Epstein, including but not limited to billing statements,
+record of payments, appointment books, treatment notes, and correspondence.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+March 2, 2007
+This subpoena is issued upon application
+sErb Imita Stan
+IN OSTRICT OF NO
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+JAN.B6
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+TRAVEL
+STATEMENT OF SERVICE FEES
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+Statement of Service Fres is tre and orrect. laws of the United States of America that the foregoing information contained in the Returm of Sonice and
+Executed on
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+if they are providec
+authenticity. Therefore, you may be able to avoid appearing personally at the grand
+jury/trial at the time and place specified by completely filling out the attached Certification
+and Inventory and immediately returning it with the records to Special Agent
+FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to March 13, 2007.
+Sincerely,
+
+
+position of
+, declare that l am:
+in the
+_and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+
+
+
+
+TO: Palm Beach County Health Department
+1150 45" Street
+West Palm Beach, FL
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-36
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 13, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following document(s) or objects):
+See attachments
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+March 2, 2007
+This subpoena is issued upon application
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+To be used in lieu of ADI10
+
+
+SERVED ON (NAME)
+• RETURN OF SERVICE'
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE'
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service and
+Statement of Service Fees is true and correct.
+Executed on DATE
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+
+
+Palm Beach County Health Department
+FGJ 07-103 OLY-36
+Please provide certified copies of birth certificates for the following individuals:
+
+
+O S. Anstralian Ave., Suite 4l
+st Palm Beach, FL 33401-62
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sutticiently in advance of trial to allow an opportunity for any challenges to their
+authenticity. Therefore, you may be able to avoid appearing personally at the grand
+jury/trial at the time and place specified by completely filling out the attached Certification
+and Inventory and immediately returning it with the records to Special Agent
+FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to March 13, 2007.
+Sincerely,
+UNITED STATES AMORNEY
+."2%
+
+
+position of
+_, declare that l am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and •
+'3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+
+
+
+
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tue./No. OLY-37
+SUBPOENA FOR:
+X PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 13, 2007
+1:00pm"
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+2.
+3.
+ANY AND ALL NOTES, LETTERS, CARDS, GIFTS, PAYMENTS, AND PHOTOGRAPHS YOU
+HAVE RECEIVED FROM JEFFREY EPSTEIN,
+AND/OR
+ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIGITAL, OF JEFFREY EPSTEIN,
+AND/OR
+ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS, OR
+TELEPHONE MESSAGES THAT YOU HAVE SENT TO AND/OR RECEIVED FROM JEFFREY EPSTEIN,
+AND/OR
+*Please coordinate your compliance with this subpoena and confirm the date and time of
+your appearance with Special Agent
+Federal Bureau of
+Investigation, Telephone:
+of the court.
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+CLERK
+(BY) DEPUTY CLERK
+STATES DISTRICT
+DATE:
+March 2, 2007
+This subpoena is issued upon application
+of the United States of America
+*If not applicable, enter "nome."
+DDESTHICT C
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. FL. 33401-6235
+To be lesed in lieu of ADIO
+
+
+SERVED ON (NAME)
+PLACE
+PLACE
+SERVED BY
+TITLE
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE-
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service anc
+statement of Service Fees is true and correct
+Executed on.
+Signature of Server
+Address of Server
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+
+
+Palm Beach County Health Department
+FGJ 07-103 OLY-36
+Please provide certified copies of birth certificates for the following individuals:
+
+
+^.
+NOTES FrOm FEDEX RECORDS
+12/8/05
+12/3/03 G.M. +J.E. sent 5lb pkg to
+"tactress)
+12/3/03 GM-JE sent 5 lb a to
+12/8/03)
+allcustomer packaging
+12/5/03 GMT JE sent 5lb pea to Del. Del.12/8/03
+12/5/03 0. EPSTEIN (2) sent Ilboka to Del. 12/10/03
+12/8/03
+to
+12/12/03 another pra
+customer
+12/8/03
+oking Del 12/1003
+- 1 lb pea Dd 1210/03
+(same address as obove)
+I sent 5lb pka to
+
+
+12/9/03
+Del.
+12/9/13 LAUREN KWINTNER F Who is chr
+Sent pkq to MICHAEL FRIEDMAN Q
+DNUSG LEC a0 of 1/7/04
+entés
+kato
+Packago to RonBurke, Ira Magaziher, Vin Gupta,
+hris Tucker, Les Wexner
+12/10/03
+fromtE's gfice sent
+arr 12/12/03 tlb pkg to
+U.S. SECRET SERVICE
+300 ALA MOANA BLUD BOX 50046
+Honolulu, H 1 96850
+sent 5lb pkg (customer pkaing) to
+JuLE McMAHON,
+12/12/03
+or 12/15/03
+12/15/03
+Sent 1 lb pea t
+tard Gardner at Hanard
+G. MAXWELL ADDRESS-
+ALSO
+ADDRESS ON 117/04 pka
+
+
+(2
+OF "LeSTEIN INTORESTS"
+# MILES ALEXANDER 5- possible boat captain in
+St. Thomas
+12/22/03
+sands Zlb custoner pea to
+12/22/03 GM sendo 5lb custoner pea to
+Del 12/24 ISABE MAXWELL
+12/24/03
+sent da to
+Glen Dubin,
+** 12/9/03 JE sent 15 lb customerpea to
+T. MARSH
+012/11/03
+**
+no do address shown
+Tracking IS 837133954215
+12/24/03
+Lsunt 5 lb customer pea to
+MATETA
+os < another secretary?
+
+
+1/12/04
+Jean Luc Brue ent 1 lb envelope tu
+Kanas Modelina Asinc
+1/22/04 JE sent 1 lb envelope to
+ERIC NONACS
+DEFICE OF WILLIAM CLINTON
+2/10/04 JE sent 4lb customer sha to
+2/13/04
+= another possible secretary?
+2/26/04 LAUKEN KWINTNER sent 1lb envelopeto
+DARREN INDYKE (home?)
+318/04
+sends 2 lb cust pea to
+(same oddress as abac)
+3/30/04
+sent 1 lb envelope to
+Royal Iron + Aluminum
+2903 Hillsboro Rd
+WPB, EL 33405
+Paekages sent to Mark Badovick at Schumacher
+Automotire on Northlake Blud
+
+
+3
+3/30/04. TE sent a 41 lb customer pla to
+arr. 3/31/04
+we need to ash
+"ORANGE" mears.
+4/7/04
+to
+what the Reference
+sends a 2 lb cust ple
+at same address as abr
+5/6/04
+sent a 2 lb FedEx box to
+5/11/04
+seat a 1 lb envelope to
+• - property mar at
+358 El Brillo?
+
+
+6/7/04
+Teala Davis
+sends pkqto
+6/24/04 JE sent pla to
+possible additional business name:
+Epstein Helesys
+possible addition lassistant.
+Invo 2/04 JE sent sulb custoner pta to
+Invoice 195644249
+8/5/04 5 Dave Rodaers sent FedEx envelope to
+Inspector
+u.s. Customs service
+1210 Carbin St
+Elizabeth, No 07201
+8/16
+at FedEx envelope to
+
+
+4
+Several packages from Lauren Kwintner of
+VUSG LLO
+to Jeff Schontz,
+break in time btur invoices
+T- 9/10/04
+- 9/26/05
+9/26/05
+sent FedEx Pak to
+David Kothell
+Ref: Eric
+9/29/05
+Sandu Berger,
+Come of many packages)
+4/12/05 JE sent FedEx Box to
+4/19/60
+sent Fed Ex envelope to
+Gent Nesten Clark.
+4/27/85
+sent Fed Ex Park to
+
+
+4/29/05
+Sent FedEx envelope to
+Marira Karin Models
+846 Lindn Rd
+Miami, FL 33139
+5/12/05 JE sent Fed Ex erareloa to
+Invoice 386165245
+5/31/05 JE sent Fed Ex envelope to
+Dr. Bruce Moskowitz
+Invoice 394460378
+7/15/05
+sent Fed Ex enelore to
+Alan Dershowitz at Harvard
+Invoice 401292229
+11|15|01
+sent Fed Ex, buy to
+Jule shay,
+Invoice 401324579
+11/16/01
+Kanother asst?) Snt
+Fed Ex envelope to
+Kirstie Fergusion. Ferguson
+
+
+11/16/01
+Marlowe Holt
+sackaq h
+amily member?)
+sent a lleb
+CPossible
+11/28/01
+conds anelod tu
+Invoice 401353488
+11/29/01
+unds 2 lb customerpka to
+1/28/01 JE sendo 20lk customerpky to
+12/10/01
+seads Fed el enveloje to
+Invoice 406051547
+12/18/01 JE sent 3 lb customer pla to
+Panela
+Karin Models
+% Jean-Luc Brunelo Office
+
+
+Invoice 406055 bl
+12/18/01
+sent a 5lb to customerska tu
+Wendy Schoepf,
+Invoice 406055801
+12/18/01 JE sent a 5lb customer oka to
+12/18700
+sent a 5 lb customer peg t
+Invojae
+1/3/02
+~ sent Fed Ex envelope to
+Ad Traffic Manager, yoga Journal
+2054 University Ave, # 501, Berkeley, CA
+1/3/00
+Invoice 406181192
+1/14/02 JE sent a customerska to
+Paula Epstein,
+2/12/02
+sent a FadEr envelins to
+
+
+6/26/02
+sent a Fedex box to
+_
+7/2/02
+sent another porkage to
+7/24/02
+John Melk
+MushaCay
+1 Fisher Island Dr
+Miami Beach, FL 33109
+I sat a FatEx entelope to.
+8/5/02
+unt a Fed Ex envelope to
+duas
+ound
+elapelli
+Sung
+8/8/02
+sent a FedEx envelope do
+
+
+Invoice 411669026
+2/1/02
+GM seet FedEx envelope to INS
+Invoice 411705135
+2/1/02 Karl Heinz-Schwabe fromNyst LUC
+sent FedEx Pak to U.S. Department. &
+Sate, Visa Board, 1005 convention
+Plaza, St. Louis, MO 63101
+Invoice 415735704
+3/22/02
+Leslly Taylor sent FedEx envelope
+to Mihui Paek at Bear Fearns.
+Invice
+1/3/02
+sent Fedex envelope to
+Bab Crosswhite at Al Packer Ford,
+10601 Southern Blud,, WPB, AL. 33411
+Invoice 425065822
+5/23/02
+Illegble framE's ghere sent FedEx
+envelope to Skytel Pagers, 5360 I-55 N,
+Jackson, MS 39211
+- anther assistant?
+
+
+A
+8/12|02
+8/13/02
+Richardson fort a remor
+sent a Fed Ex envie to
+sent a customer peg to
+Inoice 434916654
+8/19/02 JE sent a FedEx envelope to
+Nerli Gonzalez
+8/20/02
+Sent a FedEr envelope to
+Invoice 434953488
+8/27/02 Dave Rogers sent another envelope to
+uSCS Inspector
+8/29/02 JE sunt FedEx envelge to
+
+
+9/6/02
+
+sent a Fedex envelose
+to Edwina Sermonds
+Invoice 438113231
+9/9/02
+Kusing Madison Ave address)
+Sent a Fed Ex envelope to
+at Ensteisintrest Inc.,
+Invoice 43950/037
+9/17/02 Darree Induke sust a FedEr enclose ta
+9/6/02
+Doron Ofir,
+Invoice 439627871
+9/9/02 Bella Klein sunt a tolEn esselina to
+Darnis Afir
+9/18/02
+sent a FedEx envelope t
+# 9/19/02 GM sent a customer pea to
+
+
+B
+9/26/02
+10|4/02
+10/4/02
+1014|02
+10/1/02
+Sent a customer pa to
+TE at "NES-LLC "
+ust a FedEr cease to
+sent a FedEx envelope To
+Admissions, Emporer's College, 1807 B. Wilshire
+Blud, Santa Monica, CA 90403
+L cust a FedEx Box to
+sent a Fed Ex envelope to
+BOLD
+Invoice 444700847
+10/17/02
+JE sent a customer sea to Dr. Perru
+Bourd
+10/28/02
+10/28/02
+11/12/02
+Tanta Fedes envelou
+GM seet a FedEx envelope to Alan Dershowitz
+snt a Fed Ex envelope to
+Mat TRian Dill Unknod, 20 anth
+
+
+11/14/02
+seant a FedEx envelope to
+AlTel Ind. of South Horida, 425 Industrial
+Street #4, Lake Warth, FL
+Invoicel
+11/11/02
+sent a FedEx pak to
+Conrad Black
+11/14/02
+sent a red Ex envelope
+to My Tisinn Workshop
+11/19/02
+sent a FedEx envelope to
+Fred Canova Proict solutions
+12/2/02
+sent a Fedex Pak to
+Jean Lue Brunel Karin Models,
+12/3/02
+sent a Fed Er Pak to
+12/9/02 GM sent a FedEr Pak TO
+12111/02 Alan Dershowitz sunt a Fed Ex estaline to
+Edwina Simmonds,
+Invoice 449575031
+12/12/02 TE sent a FedEr customar skate
+
+
+12/12/02 JE sent a FedEx Pak to
+12/12/02 JE sent a clustomer pago package to
+12/16/02
+sent custimer ph tu
+Pamela Meiselman, Kara KARIN Models
+Invoice 453560012
+1/15/03 Lauren Kintrer sent Fedex enselets
+Chris Gaie
+1/17/03 Lauren Kwintner sent a fedEx envelope to
+Francis Ward,
+Invoice 453545uen Kwintner sent redEx envelope ti
+Francis Ward
+12/24/02
+Lent a FedEr Pak to
+Told Meister,
+1/7/03
+sent a Fed Ex envelope to
+the Office of the Bursar at Cornell University
+
+
+Invoice 45412|015
+112/03 Andrea Mitrovich sent a customer peg to
+2/3/03
+sent a FedEr anseloa to
+2/5/03 JE sent a FedEx envelope to
+2 / 11103
+sente a fedEx envelope to
+Randy Bowie
+2/11/03
+2/13/03
+sent a FedEx Pak to
+sent a fed Ex Pak to
+Sabrina Gardner
+2/12/03
+Sent a customer paq to
+
+
+2126/03.
+Sent a FedEx box to
+Ref: GIFT
+2/28/03 JE sent a FedEx Pak to
+2/28/03
+"Uncle F" at the Madison Ave adress
+sent a custoser pka to
+3/5/03
+JE from El Brillo adress sent a fedEx
+envelope to
+3/5/03
+Premium Processing, 15 Lower werdens,
+St Albans, VT 05479, sent a package
+tO JE at NES LLC,
+Invoice 463481383
+3/12/03
+Larry Morrison sent a FedEx enveloe
+to Inspector
+Fort Lauderdale, FL
+Ref: REV3 JEGE MOINT PROGRAM
+3/27/03
+sent a FedEx envelip to
+
+
+Invoice 467691369
+4/21/03 LaurenKwintner from NySG LLC Sent a
+FedEx Box to Caryl Philips,
+Invoice 468326558
+4/24/03
+sent a customer dalto
+Ref: Gift
+Invoice 468339263
+4/28/03 Larry Visoski of "Air Ghislaine llnc."
+I sent a package to Air Center
+Helicopteri in St. Thomas
+Invoice 473250493
+on Jeffrey Epstein Acct
+5/20/03
+Lori IF 125, Vermont Sue Center, T5 Lower
+welden Street, st. Albans, VT 05479 sent a
+Fedex envelope to
+Matthew T. Cinato
+Karin Models LLC
+Invoice 473327541
+4/2/03
+bust an anciate
+Ref: Check
+
+
+Invoice 473369614
+4/9/03 JE sent a customer pea to
+Julie Eversen
+Invoice 478023715
+6/18/03 JE sent a FedEx envelope to that
+Duchess of Lork
+- another assistant
+Invoice 481856743
+7/23/03
+Darren Indyke sent a Fed Ex enrelopeto
+Sandy Berger
+Invoice 482689274
+8/1/03 Bella seet a Fed Ex envelope to so
+SL Powers Telecom
+1252-B Old Okeechobee Rd
+WPB, FL 33401
+nva8/2483619284
+Nysa LC sent a fedEx envelge to
+Business office
+The Trullard School -
+→ (Juilliard?)
+60 Lincon Center Plaza
+New york, Ny 10023
+
+
+Invoice 487409579
+8/25/03 Dave Rodgers sents FedEx envelge to
+Inspector
+U.S. Customs service
+1210 Corbin St. Sealand Bldg
+Elizabeth, NJ 07201
+
+
+500 South Australian Averne, Suite 400
+West Paln Beach, FL 33401
+(Fax)
+March 14, 2008
+United States District Court Judge
+701 Clematis Street
+West Palm Beach, Florida 33401
+RE:
+Grand Jury 07-103(WPB), Disclosure of Grand Jury Material
+Dear Judge Middlebrooks:
+This office wishes to report to the court, consistent with Fed. R. Crim. P. 6(e)(3)(B), the
+disclosure to government personnel of grand jury material. The disclosure is deemed necessary by an
+attorney for the government to assist an attorney for the government in the enforcernent of such
+attorney's duty to enforce federal criminal law, as provided in Fed. R. Crim. P. 6(e)(3)(A)(ii).
+The disclosure, of material of Federal Grand Jury 07-103(WPB), in regard to Investigative
+Matter, In Re: Operation Leap Year, has been and will be made to additional persons listed on the
+attached sheet. These persons have been advised of their obligation of secrecy under Fed. R. Crim. P.
+It is requested that the court direct that the letter and list be placed in the subject grand jury file,
+and that the court return a copy of the acknowledged letter and list in the enclosed envelope for
+maintenance in the files of this office.
+Sincerely,
+LINITED STATES ATTORNEY
+
+
+The Court acknowledges receipt of the above letter with attached list and directs the
+Clerk of the Court to place a copy in the subject grand jury file.
+_day of
+- 2008.
+
+
+Disclosure of material of Federal Grand Jury 07-103(WPB) in regard to Investigative
+Mate ten perme is operation I cap Year, has been and wilbe made to the aditional
+FBI - New York, NY
+• Special Agent
+
+
+20 South Australian Avenue, Suite 40
+est Palm Beach, FL 3341
+(Fax)
+March 14, 2008
+United States District Court Judge
+701 Clematis Street
+West Palm Beach, Florida 33401
+RE: Grand Jury 07-103(WPB), Disclosure of Grand Jury Material
+Dear Judge Middlebrooks:
+This office wishes to report to the court, consistent with Fed. R. Crim. P. 6(e)(3)(B), the
+disclosure to government personnel of grand jury material. The disclosure is deemed necessary by an
+attorney for the government to assist an attorney for the government in the enforcement of such
+attorney's duty to enforce federal criminal law, as provided in Fed. R. Crim. P. 6(e)(3)(A)(ii).
+The disclosure, of material of Federal Grand Jury 07-103(WPB), in regard to Investigative
+Matter, In Re: Operation Leap Year, has been and will be made to additional persons listed on the
+attached sheet. These persons have been advised of their obligation of secrecy under Fed. R. Crim. P.
+6(e).
+It is requested that the court direct that the letter and list be placed in the subject grand jury file,
+and that the court return a copy of the acknowledged letter and list in the enclosed envelope for
+maintenance in the files of this office.
+Sincerely,
+
+
+The Court acknowledges receipt of the above letter with attached list and directs the
+Clerk of the Court to place a copy in the subject grand jury file.
+Done and ordered this 18 day of Maкс4, 2008.
+
+
+Disclosure of material of Federal Grand Jury 07-103(WPB) in regard to Investigative
+Matter, In Re: Matter of Operation Leap Year, has been and will be made to the additional
+government personnel listed below:
+FBI - New York, NY
+
+
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+(Fax)
+June 5, 2007
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Ms.
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. No grand jury material
+may be utilized by you for civil or administrative proceedings, nor for any other purpose that the
+enforcement of federal criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters
+occurring before the grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt
+of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+Date: 96/27/2007
+
+
+500 South Australian Avenue, Suite 400
+West Balon Beach, FL 33401
+(Fax)
+June 5, 2007
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Ms.
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. No grand jury material
+may be utilized by you for civil or administrative proceedings, nor for any other purpose that the
+enforcement of federal criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters
+occurring before the grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt
+of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+Date: 06/25/01
+By
+
+
+U.S. Depart
+t of Justice
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+Fax)
+June 5, 2007
+Teueral Bureau or Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Ms.
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. No grand jury material
+may be utilized by you for civil or administrative proceedings, nor for any other purpose that the
+enforcement of federal criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters
+occurring before the grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt
+of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+TINUED STARS THADNTY
+Byl
+Date: Ce/25/2007
+Sign
+
+
+500 South Australian Avenwe, Suite 400
+West Pale floach, FL 33401
+(Fax)
+May 16, 2007
+Mr.
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Mr.
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose than the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+SOTANT ONITEDSTATES ATTORNEY
+1 acknowledge that I have read this letter 4
+Date: 5/25/2007
+Signati
+
+
+500 South Australian Avenue, Suite 400
+West Palm Reach, FL 33401
+(Fax)
+May 16, 2007
+Mr.
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Mrl
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose than the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+Date: 5/21/07
+
+
+500 South Australian Avenwe, Suite 400
+West Palm Beach, FL 33401
+(Fax)
+May 16, 2007
+Ms.
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Ms
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose than the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+Date: 5/2127
+By
+I acknowledge that I have read this letter and u
+
+
+500 South Australian Avenue, Swite 400
+West Palm Reach, FL 33401
+(Fax)
+May 16, 2007
+Mr.
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Mr.
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose than the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+By
+Date: 5/21/02
+
+
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+Fax)
+May 16, 2007
+Ms.
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Ms.
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose than the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+
+
+500 South Australian Avenue, Suite 400
+Wert Palm Beach, FL 33401
+(Fax)
+May 16, 2007
+Mr.
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Mr
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose than the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+
+
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+(Fax)
+May 16, 2007
+Mr..
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Mr.
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose than the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+
+
+500 South Australian Avenue, Suite 400
+West Pain Reach, FL 33401
+I (Fax)
+May 16, 2007
+Mr.
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Mrl
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose than the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+
+
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+(Fax)
+February 13, 2007
+Ms.
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Ms.
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose that the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+I acknowledge that I have read this letter and
+Date: 2/14/07
+
+
+500 South Australian Avenue, Suite 40
+Vest Palm Reach, FL 3340
+(Fax)
+January 24, 2007
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Mr
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose that the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+Date: 01/30/07
+I acknowledge that I have read this letter
+Signa
+
+
+500 South Australian Avenue, Suite 400
+West Balm Beach, FL 3340
+(Fax)
+January 24, 2007
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Mr.
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose that the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+Date: 1/31/2006
+
+
+500 South Australian Avenue, Swite 400
+West Palm Beach, FL 33401
+Fax)
+January 24, 2007
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Ms.
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose that the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+Date: 01/31/2007
+1 acknowledge that I have read this letter and un
+
+
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+Fax)
+January 24, 2007
+Supervisory Special Agent
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Mi
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose that the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+Date: 1/25/07
+I acknowledge that I have read this letter and u
+
+
+U.S. Departm:
+500 South Australian Avenue, Suite 400
+War Palm Bench, FL 33401
+I (Fax)
+January 24, 2007
+Resident Agent-In-Charge
+United States Immigration & Customs Enforcement
+501 S. Flagler Drive, Suite 501
+West Palm Beach, Florida 33401
+Dear Mr.
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose that the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+1 acknowledge that I have read this letter and
+Date: 01-30-07
+
+
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+(Fax)
+January 24, 2007
+Group Supervisor
+United States Immigration & Customs Enforcement
+501 S. Flagler Drive, Suite 501
+West Palm Beach, Florida 33401
+Dear Mr
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose that the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+I acknowledge that I have read this letter and unders
+Da: 1/30/01
+Signa
+
+
+500 South Australian Avenue, Svite 400
+West Palm Beach, FL 33401
+Fax)
+January 24, 2007
+United States Immigration & Customs Enforcement
+501 S. Flagler Drive, Suite 501
+West Palm Beach, Florida 33401
+Dear Mr
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose that the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+Date: 01/30/2007
+Signature: _
+
+
+U.S. Departm.
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+(Fax)
+January 24, 2007
+United States Immigration & Customs Enforcement
+501 S. Flagler Drive, Suite 501
+West Palm Beach, Florida 33401
+Dear Mr
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose that the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+Date: 1/50/07
+I acknowledge that I have read this letter and
+
+
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+(Fax)
+January 24, 2007
+Group Supervisor
+United States Immigration & Customs Enforcement
+501 S. Flagler Drive, Suite 501
+West Palm Beach, Florida 33401
+Dear Mr.
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose that the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+
+
+• U.S. Departme
+COPY
+500 South Australian Avenue, Suite 400
+West Pain Beach, FL 33401
+(Fax)
+January 24, 2007
+Resident Agent-In-Charge
+United States Immigration & Customs Enforcement
+501 S. Flagler Drive, Suite 501
+West Palm Beach, Florida 33401
+Dear Mr.
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose that the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+
+
+U.S. Departme.
+FILE
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+Fax)
+January 24, 2007
+United States Immigration & Customs Enforcement
+501 S. Flagler Drive, Suite 501
+West Palm Beach, Florida 33401
+Dear Mr
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose that the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+
+
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+Fax)
+January 24, 2007
+United States Immigration & Customs Enforcement
+501 S. Flagler Drive, Suite 501
+West Palm Beach, Florida 33401
+Dear Mr. Stine:
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose that the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+
+
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+(Fax)
+January 24, 2007
+Supervisory Special Agent
+Federal Bureau of Investigation
+SOS S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Mr.
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose that the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+
+
+500 South Australian Avenue, Suite 400
+West Palm Beach. FL 33401
+Fax)
+January 24, 2007
+Special Agent 1
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Ms.
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose that the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+LS ATTORNEY
+
+
+500 South Australian Avenne, Suite 400
+West Palm Beach, FL 33401
+Fax)
+January 24, 2007
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Mr. Slater:
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose that the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+
+
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL. 33401
+Fax)
+January 24, 2007
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Mr.
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose that the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+By
+
+
+U.S. Departme.
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+(Fax)
+January 24, 2007
+Analyst
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Ms
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose that the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
+BOBTANT ONITEDSTATES ATTORNEY
+
+
+500 South Australion Avenue, Suite 400
+West Palm Beach, FL 33401
+(561) 820-3711 (Fax)
+January 24, 2007
+Analyst
+Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500
+West Palm Beach, Florida 33401
+Dear Ms.
+Your name has been reported to the United States District Court for the Southern District of Florida
+as a person who has been given access to materials of Federal Grand Jury 07-103(WPB), in regard to
+Investigative Matter, In Re: Operation LeapYear. This disclosure has been and will be made to you
+because it is deemed necessary by an attorney for the government to assist the attorney for the government
+in the performance of such attorney's duty to enforce federal criminal law.
+Your access to grand jury materials, including testimony and documents, is for the sole purpose of
+assisting the government attorneys involved in the grand jury investigation in the performance of their duties
+to enforce federal criminal law, and shall be utilized by you for no other purpose. This material is being represented due to the expiration of Federal Grand Jury 05-02(WPB). No grand jury material may be utilized
+by you for civil or administrative proceedings, nor for any other purpose that the enforcement of federal
+criminal law. Grand Jury proceedings are secret. Unauthorized disclosure of matters occurring before the
+grand jury is a violation of Fed. R. Crim. P 6(e), and may be punished as a contempt of court.
+I request that you acknowledge receipt of this letter by returning a signed copy to me. If you have
+any questions about it, please call me at
+Sincerely,
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/a1597068588876dfa9e893f8f5b91d8aec0f69409d51787de905c319c98dd07c.receipt.json b/vision-fixhub/ds9-unparsed-05/a1597068588876dfa9e893f8f5b91d8aec0f69409d51787de905c319c98dd07c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..5988d4b8dcaaac6becf6e0f172cb590a09eb5c04
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a1597068588876dfa9e893f8f5b91d8aec0f69409d51787de905c319c98dd07c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -39518,
+  "dataset": "marble-joined",
+  "doc_id": "a1597068588876dfa9e893f8f5b91d8aec0f69409d51787de905c319c98dd07c",
+  "engine": "marble-apple-vision",
+  "event_count": 356,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "a33a9ea0de80e5d249ce377a38fbf7a56d6a22df7ee9e55b88ab963f13f23684",
+  "output_sha256": "e6c90158a2b23d4e829ffd8938b3c29e38c73afdbbb5451fd1a56231e17ea6e0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a16595faa272c0ba4b36a1f16c7f78752e8aa8c2c6aa0673e691698b91042098.md b/vision-fixhub/ds9-unparsed-05/a16595faa272c0ba4b36a1f16c7f78752e8aa8c2c6aa0673e691698b91042098.md
new file mode 100644
index 0000000000000000000000000000000000000000..957ae976e1110f75cd5ece0b2190dae05f5ecfac
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a16595faa272c0ba4b36a1f16c7f78752e8aa8c2c6aa0673e691698b91042098.md
@@ -0,0 +1,3409 @@
+Statements
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ••••••••••••••••••••••I/I/
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ...................../..................
+Your Message. ..............................I.....
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 28, 2003
+3
+4
+5
+Hollandlold
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+....
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+245
+5,768,829
+$5,769,074
+....
+5,764,918
+4,156
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+$5.769,074
+$5,764,918
+Current market value
+Last statement's market value
+Important Message
+If any information regarding
+2003interest, dividends,
+miscellaneous income,
+gross proceeds or original
+issue discount is required
+to be reported to the IRS for
+Chinsolidated Form 1099
+will be mailed to you by
+DeMarch 15,2004. a 10425
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The surren s four or ratanal purposes rear die Set revere date for portant iformation.
+01/01/04;12:54 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Stearns & Co. Ine.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+OpeningBalance
+Money Fund
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERIOD
+5245.45
+4,155.65
+$4,155.65
+-4,155.65
+$-4. 155.65
+$245.45
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+4,155.65
+0.00
+54.155.65
+Portfolio Composition
+Cash/Cash Equivalent
+Tota
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+245.45
+$245.45
+GLOSING
+245.45
+$245.45
+..........
+027
+YEAR TO DATE
+66,125.96
+131.13
+*-------.
+$66,257.09
+5,769,074
+$5,769,074
+01/01/04;12:54 001
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 28, 2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+.....
+DREYFUS CASH MANAGEMENT-CLA
+NSTITUTIONAL SHARE!
+ST, 30 DAY AVG YIELD .8000%
+TOTAL CASH & CASH EQUIVALENTS
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 28, 2003
+SYMBOLCUSIP
+DICXX
+QUANTITY
+5,768,828.89
+PRICE
+1.0000
+MARKET
+VALUE
+245
+5,768,829
+$5,769,074
+ESTIMATEL
+NUAL INCON
+51,919
+$51,919
+*****•
+0.9000
+$51,919
+$5,769,074
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+11/29/03
+12/01/03
+"DIVIDEND
+12/01/03
+REINVEST
+DESCAIPTION
+OPENINGBALANCE
+BREYFUS CASH MANAGEMENT-CLA
+MONTHLY DID ENDRES
+DREYFUS CASH MANAGEMENT-CLA
+STITUTIONAL SHAR
+VIDEND REINVES
+SYMBOUCUSIP
+DICXX
+QUANTITY
+5.764,673.24
+PRICE
+DEBIT AMOUNT
+CREDIT AMOUNT
+4,155.65
+4,155.65
+4,155.65
+027
+
+
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MODAY
+12/31/03
+TOTAL
+TRANSACTION
+DESCRIPTION
+CLOSINGBALANCE
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUCUSIP
+Your messages
+I As part of the National Association of Securities Dealers (NASD) Investor
+ducation Program, you may obtain information on the NASD's Publi
+isclosure Program by contacting the NASD at telephone number (800
+89-9999 or via the internet address which is www.nasdr.com, In addition,
+rochure explaining the Public Disclosure Program is available from the NAS
+STOP
+****** End of Statement******
+QUANTITY
+5,768,828.89
+PRICE
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 28, 2003
+DEBIT AMOUNT
+CREDIT AMOUNT
+$-4,155.65
+$4,155.65
+LP Excess SIPC Account Protection Update
+Bear, Stearns Securities Corp. ('BSS'), a member of the Securities Investor
+Protection Corporation ('SIPC"), provides account protection for the net equity
+of a customer's funds and securities positions, SIPC provides $500,000 of
+primary net equity protection, including $100,000 for claims for cash ("SIPC
+Coverage'). Visit www.sipc.org for more information about SIPC Coverage.
+BSSC provides the additional protection ("Excess SIPC") through a commercial
+nsurer, Effective February 16, 2004, the commercial insurer for Excess SIPO
+will change to Customer Asset Protection Company ("CAPCO"), a licensed New
+York insurance company. Account protection applies when a SIPC member
+firm fails financially and is unable to meet its obligations to its securities
+registered as securities.
+027
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail .................................
+Fund Activity ...................../...................
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 31,2003
+3
+4
+4
+Hollandlold
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+....
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+245
+5,764,673
+$5,764,918
+5,760,632
+4,286
+here are no Stop Loss" orders or other pending bu
+r sell open orders on file for your account
+Market Value of Your Portfolio
+Cash & Equivalent
+$5,764,918
+$5,760,632
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800 6341428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The wireman is four ratanal furyce red de Set revere date for portant iformation.
+11/29/03:08:43 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+11/29/03:08:43 001
+
+
+Bear, Stearns & Co. Ine.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+OpeningBalance
+Money Fund
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERIOD
+245.4
+•......
+4.286.45
+14,286.45
+-4,286.45
+
+$245.45
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+4,286.45
+0.00
+$4.286.45
+Portfolio Composition
+Cash/Cash Equivalent
+Tota
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+245.45
+$245.45
+GLOSING
+245.45
+$245.45
+..........
+027
+YEAR TO DATE
+61,970.31
+131.13
+.....
+$62,101.44
+5,764,918
+$5.764,918
+11/29/03:08:43 001
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 31,2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+DREYFUS CASH MANAGEMENT-CLA
+NSTITUTIONAL SHARE!
+ST, 30 DAY AVG YIELD .8900%
+TOTAL CASH & CASH EQUIVALENTS
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 31, 2003
+SYMBOLCUSIP
+DICXX
+QUANTITY
+5,764,673.24
+PRICE
+1.0000
+MARKET
+VALUE
+245
+5,764,673
+$5,764,918
+ESTIMATED
+ANNUAL INCOME
+51,882
+$51,882
+0.9000
+$51,882
+$5,764,918
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+TRANSACTION
+11/01/03
+11/03/03
+"DIVIDEND
+11/03/03
+"REINVEST
+DESCAIPTION
+OPENINGBALANCE
+BREYFUS CASH MANAGEMENT-CLA
+MONTHLY DA SNARES
+DREYFUS CASH MANAGEMENT-CLA
+STITUTIONAL SHAR
+VIDEND REINVES
+SYMBOUCUSIP
+DICXX
+DICXX
+QUANTITY
+5,760,386.79
+PRICE
+DEBIT AMOUNT
+CREDIT AMOUNT
+4,286.45
+4.286.45
+4,286.45
+027
+11/2903:08:43 001
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+RATELY
+11/28/03
+TOTAL
+TRANSACTION
+DESCRIPTION
+CLOSINGBALANCE
+SYMBOUCUSIP
+QUANTITY
+5,764,673.24
+PRICE
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 31,2003
+DEBIT AMOUNT
+CREDIT AMOUNT
+$-4,286.45
+$4.286.45
+STOP
+End of Statement******
+027
+11/29/03;08:43 001
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail .................................
+Fund Activity ...................../...................
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 30,2003
+3
+Hollandlold
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+....
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+245
+5,760,387
+$5,760,632
+5,878,647
+- 118,015
+here are no Stop Loss" orders or other pending bu
+r sell open orders on file for your account
+Market Value of Your Portfolio
+Cash & Equivalent
+$5.760,632
+$5.878.647
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four ratanal purger red de Set revere date for portant iformation.
+11/01/03:14:02 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+11/01/03:14:02001
+
+
+3 or 5
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Funds Deposited
+Amount Credited
+Money Fund
+Funds Withdrawn
+mount Debite
+************
+Net Cash Activity
+Closing Balance,
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+3530.45
+126,269.72
+6,000.00
+$132,269.72
+•........
+-4,269.72
+-128,285.00
+...... 132.554,72
+-285.00
+5245.45
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+530.45
+$530.45
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+4,269.72
+0.00
+$4,269.72
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+027
+CLOSING
+245.45
+$245.45
+.....
+YEAR TO DATE
+57,683.86
+131.13
+......
+$57.814.99
+5,760,632
+35.760,632
+11/01/03:14:02 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 30,2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+........
+DREYFUS CASH MANAGEMENT-CLA
+NSTITUTIONAL SHARE!
+ST, 30 DAY AVG YIELD .8900%
+TOTAL CASH & CASH EQUIVALENTS
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+DICXX
+QUANTITY
+5,760,386.79
+PRICE
+1.0000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+10/01/03
+1009/03
+10/10/03
+TRANSACTION
+END WIRED
+CHECK
+CHECK
+DESCRIPTICN
+MDAI
+INDS WIRED TO
+ARMORTEEN RHASE BANK
+ARERVATIONAL CHANABLE
+GEORGE DESO ON ACCT
+MARKET
+VALUE
+245
+5,760,387
+$5,760,632
+ESTIMATED
+ANNUAL INCOME
+51,843
+$51,843
+$51,843
+$5,760,632
+**••***
+0.9000
+DEBIT AMOLNT
+116,285.00
+6,000.00
+6,000.00
+CREDIT AMOUNT
+027
+11/01/03:14:02 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 30,2003
+
+
+Transaction Detail (continued)
+DEPOSITS AND WITHDRAWALS (continued)
+
+TRANSACTION
+DEPOSIT
+TOTAL
+MONEY FUND ACTIVITY
+DESCRIPTION
+CHECK REDEPOSIT
+INTER CHARIT
+DATE
+MO/DAY
+10/01/03
+TRANSACTION
+10/01/03
+''SOLD
+10/01/03 DIVIDEND
+10/01/03
+REINVEST
+10/09/03
+SOLD
+10/31/03
+TOTAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DEBIT AMOUNT
+$-128,285.00
+DESCAIPTION
+OPENINGBALANCE
+BREYFUS CASH MANAGEMENT-CLA'
+INSTITUTIONAL SHARES
+DREYFUS CASH MANAGEMENT-CLA'''
+DIVIDEND
+DREYFUS CASH MANAGEMENT-CLA
+DIVIDEND RENESTES
+INSTONAL SHANACEMENT-CLA
+CLOSINGBALANCER
+SYMBOU/CUSIP
+DICXX
+DICXX
+CREDIT AMOUNT
+5,000.00
+$6,000.00
+QUANTITY
+5,878,117.07
+-116,000
+4,269.72
+-6,000
+5,760,386.79
+PRICE
+1.0000
+027
+11/01/03;14:02 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 30,2003
+DEBIT AMOUNT
+CREDIT AMOUNT
+116,000000
+4,269.72
+$-4,269.72
+6,000.00
+$126,269.72
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ...................../...................
+Your Message. ...........................I....
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 29, 2003
+3
+3
+5
+6
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+530
+5,878,117
+$5,878,647
+5,891,471
+-12,824
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+$5,878,647
+$5,891,471
+Current market value
+Last statement's market value
+Important Message
+Bear Stearns is pleased to
+announce our conversion to
+a calendar month-end
+statement. Effective this
+month, your account
+statement reflects all
+activity and account
+valuation up to and
+including the last business
+day of the month.
+Flease raport any dierence or nonreceipt of chocks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The surren s four ratanal purpose red de Set revere dae for portant iformation.
+10/01/03;11:21 001
+
+
+2 of 7
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+10/01/03:11:21001
+
+
+3 or 7
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Money Fund
+Funds Withdrawn
+Amount Debited
+Net Cash Activity
+Closing Balance
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+551.833.96
+20,480.12
+$20,480.12
+4,480.12
+-17,303.51
+...
+$-21,783.63
+.. . .
+-1,303.51
+$530.45
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+SYMBOLCUSIP
+QUANTITY
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+1,833.96
+$1,833.96
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+4,480.12
+0.00
+$4,480.12
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+FRICE
+MARKET
+VALUE
+530
+ESTIMATED
+ANNUAL INCOME
+CLOSING
+530.45
+$530.45
+........
+YEAR TO DATE
+53,414.14
+131.13
+$53.545.27
+5,878,647
+55.878.647
+027
+CURRENT
+YELD IN
+......
+10/01/03;11:21 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 29,2003
+Your Portfolio
+Allocation
+Cash & Equivalent —
+Unshaded portions denote debe balance andor short
+from the absolute market value of your portolio.
+
+
+4 of 7
+Your Portfolio Holdings (continued)
+CASH & CASH EQUIVALENTS (continued)
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+EST, 30 DATA SNEED 9200%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+DICXX
+QUANTITY
+5,878,117.07
+PRICE
+1.0000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+09/30/03
+TRANSACTION
+FND WIRED
+TOTAL
+DESCRIPTION
+WIRED TO
+ENGELASE BEN
+MARKET
+VALUE
+5,878,117
+$5,878,647
+ESTIMATED CURRENT
+ANNUAL INCOME
+YIELD 1%)
+52,903
+0.9000
+$52,903
+$52,903
+$5,878,647
+DEBIT AMOLNT
+17,303.51
+$-17,303.51
+CREDIT AMOUNT
+027
+10/01/03:11:21 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 29, 2003
+
+
+5 of 7
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTKN
+08/30/03
+09/02/03
+"DIVIDEND
+09/02/03
+REINVEST
+09/30/03
+• SOLD
+09/30/03
+TOTAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCAIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT-CL A
+STITUTIONAL SHARE
+ONTHLY DIVIDEN
+*DREYFUS CASH MANAGEMENT-CLA
+REST TONAL SHANCE ENTIC A
+CLOSINGBALANCE
+SYMBOUCUSIP
+DICXX
+DICXX
+DICXX
+QUANTITY
+5,889,636.95
+4,480.12
+-16,000
+5,878,117.07
+027
+PRICE
+1.0000
+10/01/03:11:21 001
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD August 30,2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 29,2003
+DEBIT AMOUNT
+CREDIT AMOUNT
+4,480.12
+4,480.12
+.........--..
+16,000.00
+$-4,480.12
+$20,480.12
+
+
+6 of 7
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your messages
+Bear, Stearns Securities Corp, Net Capital and Net Capital Requirements:
+At May 31, 2003 and July 31, 2003, the Company's net capital of
+A complete copy of the Bear, Stearns Securities Corp, Statement of Financial
+Condition is available on the web site www.bearsteams.com. Alternatively, to
+request a free printed copy please call - toll free 1-866-299-9331,
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+August 29, 2003
+Securities and other assets in your account are the firm's collateral for any
+margin loan made to you. If the securities and other assets in your account
+decline in value, so does the value of the collateral supporting your loan, and,
+as a result, the firm can take action, such as issue a margin call and/or sell
+securities or other assets in any of your accounts held with the member, in
+order to maintain the required equity in the account. It is important that you
+ully understand the risks involved in trading securities on margin, These risk:
+include the following:
+* You can lose more funds than you deposit in the margin account.
+* The firm can force the sale of securities or other assets in you
+accounts).
+* The firm can sell your securities or other assets without contacting you.
+* You are not entitled to choose which securities or other assets in your
+accounts) are liquidated or sold to meet a margin call.
+• any time an is notse is no to promie you ace and in rea nomients at
+* You are not entitled to an extension of time on a margin call,
+027
+10/01/03;11:21 001
+V9Ta
+
+
+7 of 7
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+I This statement is provided to explain Bear, Stears & Co, Inc, 's ('BSC)
+than favorable executions or executions of limit orders at no additional charge.
+STOP
+End of Statement******
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 29, 2003
+Pursuant to SEC Rule 11Ac1-6, please note the following:
+ear, Stearns & Co. Inc, will post its quarterly routing statistics at the followin
+reb link: http://www.bearstearns.com/, Click on Individual Investor, Click or
+Equities, Click on Order Routing Practices.
+Customers of Bear, Stearns & Co, Inc, may request information on any order
+executed within the prior six months from the time of the request, Specifically,
+you may request the identity of the venue to which the identified orders were
+routed for execution, whether the order was directed by you to that venue, and
+the time of the executions, if any, that resulted from such orders.
+027
+10/01/03:11:21 001
+V913
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary •••••••••••••••••••••••I/I/
+Your Portfolio Holdings
+Transaction Detail ..................................
+Fund Activity ............../....../....................
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 25, 2003
+3
+4
+4
+Hollandlold
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+1,834
+5,889,637
+5,891,47
+5,886,827
+4,644
+here are no Stop Loss" orders or other pending bu
+r sell open orders on file for your accoun
+Market Value of Your Portfolio
+Cash & Equivalent
+$5,891,471
+$5,886,827
+Current market value
+Last statement's market value
+Important Message
+Bear Stearns is pleased to
+announce our conversion to
+a calendar month-end
+statement. Effective
+September 2003,your
+account statement will
+reflect all activity and
+account valuation up to and
+including the last business
+day of the month.
+Flease raport any dierence or non-receipt of chacks or stocks, indicated as delivered to you.
+to Client Services at 800 634-1428; or Writa to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+09/30103;13:45 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+09/30/03;13:45 001
+
+
+Bear, Stearns & Co. Ine.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERICO
+51.833.96
+4,643.84
+54,643.84
+-4,643.84
+
+$1,833.96
+Income Summary
+Dividends
+Credit Balance Int.
+Total L
+THIS PERIOD
+4,643.84
+0.00
+54.64384
+Portfolio Composition
+Cash/Cash Equivalent
+Tota
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+1,833.96
+$1,833.96
+CLOSING
+1,833.96
+....
+$1,833.96
+...
+027
+YEAR TO DATE
+48,934.02
+131.13
+****---.
+$49,065.15
+_....
+5,891,471
+$5,891,471
+09/30/03;13:45 001
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 25, 2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+.....
+DREYFUS CASH MANAGEMENT-CLA
+NSTITUTIONAL SHARE!
+ST, 30 DAY AVG YIELD .9100%
+TOTAL CASH & CASH EQUIVALENTS
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 25, 2003
+SYMBOLCUSIP
+DICXX
+QUANTITY
+5,889,636.95
+PRICE
+1.0000
+MARKET
+VALUE
+1,834
+5,889,637
+$5,891,471
+ESTIMATED
+ANNUAL INCOME
+53,007
+$53,007
+0.9000
+$53,007
+$5,891,471
+Transaction Detail
+MONEY FUND ACTIVITY
+TRANSACTION
+07/26/03
+080103*
+"DIVIDEND
+08/01/03
+REINVEST
+DESCAIPTION
+OPENINGBALANCE
+"BREYFUS CASH MANAGEMENT-CLA
+MONTHLY DIVIDENDRES
+DREYFUS CASH MANAGEMENT-CLA
+NSTITUTIONAL SHARE
+IMIDEND REINVESTE
+SYMBOLCUSIP
+DICXX
+QUANTITY
+5,884,993.11
+PRICE
+DEBIT AMOUNT
+CREDIT AMOUNT
+4,643.84
+4.643.84
+4,643.84
+027
+09/3003;13:45 001
+V912
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MONDAY
+08/29/03
+TOTAL
+TRANSACTION
+DESCRIPTION
+CLOSINGBALANCE
+SYMBOUCUSIP
+QUANTITY
+5,889,636.95
+PRICE
+LEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 25,2003
+DEBIT AMOUNT
+CREDIT AMOUNT
+$-4,643.84
+$4.643.84
+STOP
+End of Statement******
+027
+09/30/03;13:45 001
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN, IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ....
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 27, 2003
+5
+Hollandlold
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+....
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+1,834
+5,884,993
+85,886,827
+7,742,571
+-1,855,744
+here are no "Stop Loss" orders or other pending bu
+sell open orders on file for your accoun
+Cash & Equivalent
+Market Value of Your Portfolio
+$5.886.827
+฿ $7,742,571
+Current market value
+Last statement's market value
+Flease report any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+07/26/03:10:09001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+07/26/03:10:09 001
+
+
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Money Fund
+Funds Withdrawn
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+.52405.96
+1,868,828.21
+
+-6,828.21
+-116,286.00
+-1,746,286.00
+$-1,869,400.21
+-572.00
+51. 833.96
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+2,405.96
+$2,405.96
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+6,828.21
+0.00
+$6,828.21
+Portfolio Composition
+Cash/Cash Equivalent
+Total.
+027
+CLOSING
+1,833.96
+$1,833.96
+--....
+YEAR TO DATE
+44,290.18
+131.13
+44,421.3
+5,886,827
+$5,886,827
+••••
+07/26/03:10:09 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 27, 2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+V811
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+CASH BALANCE
+......
+DREYFUS CASH MANAGEMENT-CLA
+NSTITUTIONAL SHARE!
+ST, 30 DAY AVG YIELD 9100%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+DICXX
+QUANTITY
+5,884,993.11
+PRICE
+1.0000
+MARKET
+VALUE
+1,834
+5,884,993
+$5,886,827
+ESTIMATED
+ANIVUAL INCOME
+64,735
+$64,735
+1.1000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+$64,735
+$5,886,827
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+07/01/03
+TRANSACTION
+FND WIRED
+DESCRIPTION
+MDA#
+TOTAL
+ENDS WIRED TO
+DEBIT AMOLNT
+116,286.00
+$-116,286.00
+CREDIT AMOUNT
+027
+07/26/03:10:09 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 27,2003
+V811
+
+
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+06/28/03
+07/01/03
+"SOLD
+07/01/03 DIVIDEND
+07/01103 REINVEST
+07/25/03
+TOTAL
+MISCELLANEOUS
+DATE
+MODAY
+07/01/03
+TOTAL
+TAMNSACTION
+JOURNAL
+DESCRIPTION
+TO 047-30185
+PER LOA
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+OPENINGBALANCE
+INSTIONAL SHAREEMENT CLA
+DREYFUS CASH MANAGEMENT-CLA
+MONTHLY DO ENDRES
+(REYFUS CASH MANAGEMENT-CL
+INSTITUTIONAL SHARES
+DIVIDEND REINVESTED
+CLOSINGBALANCE
+SYMBOUGUSIP
+DICXX
+DICX
+QUANTITY
+7,740,164.90
+- 1,862,000
+6,828.21
+5,884,993.11
+PRICE
+1.0000
+DEBIT AMOUNT
+1,746,286.00
+$-1,746,286.00
+CREENT AMOUNT
+027
+07/26/03;10:09 001
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 27, 2003
+DEBIT AMOUNT
+CREDIT AMOUNT
+1.862,000.00
+5,828.21
+6,828.21
+$-6,828.21
+$1,868,828.21
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN. IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ....
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .......
+Your Messages
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 30, 2003
+3
+4
+4
+5
+Hollandlold
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+....
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+2,406
+7,740,165
+$7,742,571
+7,735,303
+7,268
+here are no "Stop Loss" orders or other pending bu
+sell open orders on file for your accoun
+Market Value of Your Portfolio
+Cash & Equivalent
+$7.742,571
+$7,735,303
+Current market value
+Last statement's market value
+Important Message
+Confirmation: Unless we
+hear from you to the
+contrary, it is our
+understanding that any free
+redit balances in your
+account are bein
+maintained to facilitate
+such amount through us.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634 1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+TPC This summary is for informational purposes only. It is not intended as a tax docum
+: This statement should be retained for your records. See reverse side for important informati
+06/28/03;12:00 001
+v909
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+06/28/03:12:00 001
+4909
+
+
+3 ofs
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Money Fund
+Amount Debited
+losing Balanc
+THIS PERICO
+52.405.-96
+7,268.17
+7,268.1
+-7,268.17
+3-7.268.17
+52.405.96
+Income Summary
+Dividends
+Credit Balance Int.
+Total.
+THIS PERIOD
+7,268.17
+0.00
+57.268.17.
+Portfolio Composition
+Cash/Cash Equivalent
+Tota
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+2,405.96
+$2,405.96
+CLOSING
+2,405.96
+......
+$2,405.96
+027
+YEAR TO DATE
+37,461.97
+131.13
+$37,593.10
+7,742,571
+57.742,571
+06/28/03:12:00 001
+LEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 30,2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+V908
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+.....
+DREYFUS CASH MANAGEMENT-CLA
+STITUTIONAL SHARE
+T, 30 DAY AVG YIELD 1,0200
+TOTAL CASH & CASH EQUIVALENTS
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 30,2003
+SYMBOLCUSIP
+DICXX
+QUANTITY
+7,740,164.90
+PRICE
+1.0000
+MARKET
+VALUE
+2,406
+7,740,165
+$7,742,571
+ESTIMATED
+ANNUAL INCOME
+85,142
+$85,142
+1.1000
+$85,142
+$7,742,571
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MODAY
+05/31/03
+TRANSACTION
+06/02/03
+"DIVIDEND
+06/02/03
+REINVEST
+DESCAIPTION
+OPENINGBALANCE
+BREYFUS CASH MANAGEMENT CLA
+MONTHLY DIVIDENRES
+DREYFUS CASH MANAGEMENT-CLA
+STITUTIONAL SHAR
+VIDEND REINVESTE
+SYMBOL/CUSIP
+DICXX
+DICXX
+QUANTITY
+7,732,896.73
+PRICE
+DEBIT AMOUNT
+CAEDIT AMOUNT
+7,268.17
+7,268.17
+7,268.17
+027
+06/28/03;12:00 001
+V90e
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MODAY
+06/27/03
+TOTAL
+TRANSACTION
+DESCAIPTION
+CLOSINGBALANCE
+SYMBOUCUSIP
+Your messages
+LeP With interest rates at their lowest in 45 years, income oriented clients
+are reminded of the risks inherent in attempting to maintain or
+increase the average yield on a fixed income portfolio. Generally,
+securities carrying a higher yield come with some combination of
+added credit risk, extended maturities, reduced liquidity, or special
+call features. Rising interest rates can cause a decline in the
+STOP
+****** End of Statement******
+QUANTITY
+7,740,164.90
+027
+PRICE
+LEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 30,2003
+DEBIT AMOUNT
+CREDIT AMOUNT
+$-7,268.17
+$7,268.17
+06/28/03:12:00 001
+V908
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail .................................
+Fund Activity ......••••••••••••••••••••III••IIII
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 25,2003
+3
+Hollandlol
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+....
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+2,406
+7,732,897
+$7,735,303
+7,727,732
+7,571
+here are no "Stop Loss" orders or other pending bu
+sell open orders on file for your accoun
+Market Value of Your Portfolio
+Cash & Equivalent
+$7.735,303
+$7,727.732
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+05/31/03:15:30 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+05/31/03;15:30 001
+
+
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Funds Deposited
+Amount Credited
+Money Fund
+Amount Debited.
+Net Cash Activity
+Closing Balance
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+1,960.1
+......
+7,124.91
+445.86
+$7,570.77
+•........
+-7,124.91
+.. . .
+$-7,124.91
+445.86
+$2.405.96
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+1,960.10
+$1,960.10
+CLOSING
+2,405.96
+$2,405.96
+........
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+7,124.91
+0.00
+$7.124.91
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+YEAR TO DATE
+30,193.80
+131.13
+$30.324.93
+7,735,303
+57.735.303
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+SYMBOUCUSIP
+QUANTITY
+FRICE
+MAAKET
+VALUE
+2,406
+ESTIMATED
+ANNUAL INCOME
+027
+CURRENT
+YIELD (%)
+....
+05/31/03;15:30 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 25,2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debit balance andor short
+market values. The alocation percentage is derived
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+CASH & CASH EQUIVALENTS (continued)
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST, 30 DAY AVG YIELD 1,1200%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+DICXX
+QUANTITY
+7,732,896.73
+PRICE
+1.0000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+05/23/03
+TRANSACTION
+DEPOSIT
+TOTAL
+DESCRIPTION
+KENES POINTERN. CHARITABLE
+CHASE
+MARKET
+VALUE
+7,732,897
+$7,735,303
+ESTIMATED CURREN
+ANNUAL INCOME
+YELD IN)
+85,062
+1.1000
+$85,062
+$85,062
+$7,735,303
+DEBIT AMOLNT
+CREDIT AMOUNT
+445.86
+$445.86
+027
+05/31/03;15:30 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 25,2003
+
+
+5 ors
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+04/26/03
+05/01703 DIVIDEND
+05/01/03
+"REINVEST
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCHIPTION
+OPENINGBALANCE
+RESHONASS MALAGEMENT-CLA
+MONTHLY DIVIDEND
+DIVIDEND REINVESTED
+CLOSINGBALANCE
+SYMBOUCUSIP
+BICXX
+DICXX
+05/30/03
+TOTAL
+STOP
+****** End of Statement******
+QUANTITY
+7,725,771.82
+7,124.91
+7,732,896.73
+027
+PRICE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 25,2003
+DEBIT AMOUNT
+CREDIT AMOUNT
+7,12491
+7,124.91
+$-7,124.91
+$7,124.91
+05/31/03;15:30 001
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail .................................
+Fund Activity ….....•.•..•••••••••••••II•II
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29,2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 28, 2003
+3
+Hollandlold
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+....
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+1,960
+7,725,772
+$7,727,732
+7,824,093
+-96,361
+here are no "Stop Loss" orders or other pending bu
+sell open orders on file for your accoun
+Market Value of Your Portfolio
+Cash & Equivalent
+$7.727.732
+$7.824,093
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal furyce rebr de Set revere ase for portant iformation.
+04/26/03;12:12 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+04/26/03:12:12 001
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Funds Withdrawn
+Amount Debiter
+Net Cash Activity
+Closing Balance
+THIS PERICO
+51,948.20
+.. . .
+61,626.73
+11.90
+$61,638.63
+-7,626.73
+-104,000.00
+5.111.626.73
+-49,988.10
+1.960.10
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+51,948.20
+$51,948.20
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+7,626.73
+11.90
+$7,638.63
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+027
+CLOSING
+1,960.10
+$1,960.10
+......
+YEAR TO DATE
+23,068.89
+131.13
+$23.200.02
+7,727,732
+57.727.732
+04/26/03:12:12 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29, 2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 28,2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+CASH BALANCE
+... . . .
+DREYFUS CASH MANAGEMENT-CLA
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+DICXX
+QUANTITY
+arisaaaaaa
+7,725,771.82
+PRICE
+1.0000
+MARKET
+VALUE
+1,960
+7,725,772
+$7,727,732
+92,709
+$92,709
+1.2000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+$92,709
+$7,727,732
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+04/01/03
+TRANSACTION
+FND WIRED
+DESCRIPTION
+TOTAL
+DEBIT AMOUNT
+104,000.00
+$-104,000.00
+CREDIT AMOUNT
+027
+04/26/03:12:12 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29, 2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 28, 2003
+
+
+5 ors
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+03/29/03
+64/01/05 SOLD
+04/01703DIVDEND
+04/01/03
+''REINVEST
+04/25/03
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+04/21/03
+INTEREST ONCREDIT BALANCE
+AT 0 3/4% 03/21 THRU 04/20
+TOTAL
+STOP
+****** End of Statement******
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCHIPTION
+OPENINGBALANCE
+RENA®S MANAGEMENT-CLA
+ONTHLY DIVIDEN
+RATHONE SNANAGEMENFCLA
+DIVIDEND REINVESTED
+CLOSINGBALANCE
+SYMBOUCUSIP
+BICXX
+DICXX
+DICXX
+SYMBOUCUSIP
+QUANTITY
+QUANTITY
+7,772,145.09
+54,000
+7.626.73
+7,725,771.82
+RATE (%)
+0.7500
+027
+1.0000
+DEBIT AMOUNT
+04/26/03:12:12 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29, 2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 28,2003
+DEBIT AMOUNT
+CREDIT AMOUNT
+54,000.00
+7,626.73
+7,626.73
+$-7,626.73
+$61,626.73
+CREDIT AMOUNT
+11.90
+$11.90
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary •••••••••••••••••••••••/I/
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ............../....../....................
+Your Messages .....................................
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+February 28,2003
+3
+3
+4
+5
+Hollandlold
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTIN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+51,948
+7,772,145
+$7,824,093
+7,816,974
+7,119
+here are no "Stop Loss" orders or other pending bu
+sell open orders on file for your accoun
+Market Value of Your Portfolio
+Cash & Equivalent
+$7.824,093
+$7,816,974
+Current market value
+Last statement's market value
+Flease report any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800 634-1428; or Writa to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3669.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+03/29/03:11:19 001
+
+
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited.
+Net Cash Activity
+Closing Balance.
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+$51,917.91
+....
+7,088.84
+30.29
+$7,119.13
+-7,088.84
+....
+$-7,088.84
+.......
+30.29
+651.948.20
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+51,917.91
+$51,917.91
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+7,088.84
+30.29
+$7,119.13
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+CLOSING
+51,948.20
+$51,948.20
+...........
+YEAR TO DATE
+15,442.16
+119.23
+.....
+$15.561.39
+7,824,093
+$7,824,093
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+SYMBOUCUSIP
+QUANTITY
+FRICE
+MARKET
+VALUE
+51,948
+ESTIMATED
+ANNUAL INCOME
+027
+CURRENT
+YIELD (%)
+....
+03/29103;11:19 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+February 28,2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28,2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+February 28,2003
+Your Portfolio Holdings (continued)
+CASH & CASH EQUIVALENTS (continued)
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST, 30 DAY AVG YIELD 1,1500%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+DICXX
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+QUANTITY
+7,772,145.09
+PRICE
+1.0000
+MARKET
+VALUE
+7,772,145
+$7,824,093
+ESTIMATED
+CURRENT
+ANNUAL INCOME
+YELD IN)
+85,494
+1.1000
+$85,494
+$85,494
+$7,824,093
+Transaction Detail
+MONEY FUND ACTIVITY
+TRANSACTION
+03/01/03
+03/03/09 DIVIDEND
+03/03/03 REINVEST
+03/28/03
+TOTAL
+ESCAIPTICY
+OPENINGBALANCE
+PRETE ONAS MANAGEMENTECTA
+MONTHLY DIVIDEND
+DIVIDEND REINVESTED
+CLOSINGBALANCE
+SYMBOUCUSIP
+"DiCXX
+"DICXX"
+QUANTITY
+7,765,056.25
+7.088.84
+7,772,145.09
+027
+PRICE
+DEBIT AMOUNT
+
+$-7,088.84
+CREDIT AMOUNT
+7,088.84
+$7,088.84
+
+
+5 of5
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+03/21/03
+INTEREST ON CREDIT BALANCE
+AT O 3/4% 02/21 THRU 03/20
+TOTAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOL/CUSIP
+Your messages
+Bear, Stearns Securities Corp. Net Capital and Net Capital
+Requirements:
+At November 30, 2002 and January 31, 2003, the Company's net
+capital of approximately $2.4 billion and $2.4 billion was
+approximately 7% and 7% of aggregate debit items and exceeded
+the minimum regulatory net capital requirement of approximately
+$716.3 million and $684,1 million by approximately $1.7 billion and
+$1.7 billion, all respectively,
+A complete copy of the Bear, Stears Securities Corp. Statement
+of Financial Condition is available on the web site
+www.bearstearns.com, Alternatively, to request a free printed copy
+please call - toll free - 1-866-299-9331.
+STOP
+****** End of Statement******
+QUANTITY
+RATE (%)
+0.7500
+DEBIT AMOUNT
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28,2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+February 28,2003
+CREDIT AMOUNT
+30.29
+$30.29
+Pursuant to SEC Rule 11Ac1-6, please note the following:
+Bear Stearns & Co. Inc, will post its quarterly routing statistics at the
+ollowing web link: http://www.bearstearns.com/
+Customers of Bear, Stearns & Co, Inc, may request information on any
+order executed within the prior six months from the time of the request,
+Specifically, you may request the identity of the venue to which the
+dented by or that vete an execution of there tires i any, that.
+027
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail ..................................
+Fund Activity ............../....../....................
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 1,2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+January 31, 2003
+3
+4
+4
+Hollandlold
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+....
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+51,918
+7,765,056
+$7,816,974
+7,808,587
+8,387
+oh sel apen orstes on i re your ator pending buy
+Market Value of Your Portfolio
+Cash & Equivalent
+$7.816,974
+$7,808,587
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800 634-1428; or Writa to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3669.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited.
+Net Cash Activity
+Closing Balance
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+$51,884.40
+....
+8,353.32
+33.51
+$8,386.83
+-8,353.32
+....
+$-8,353.32
+.....
+33.51
+651.917.91
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+51,884.40
+$51,884.40
+CLOSING
+51,917.91
+551.91731
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+8.353.32
+33.51
+$8,386.83
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+YEAR TO DATE
+8,353.32
+88.94
+вааааааааааа
+$8.442.26
+7,816,974
+$7,816,974
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+SYMBOUCUSIP
+QUANTITY
+FRICE
+MARKET
+VALUE
+51,918
+027
+ESTIMATED
+ANNUAL INCOME
+CURRENT
+YIELD (%)
+....
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 1, 2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+January 31,2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 1,2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+January 31,2003
+Your Portfolio Holdings (continued)
+CASH & CASH EQUIVALENTS (continued)
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+NSTITUTIONAL SHARES
+ST, 30 DAY AVG YIELD 1,1800°
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+DICXX
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+QUANTITY
+7,765,056.25
+PRICE
+1.0000
+MARKET
+VALUE
+7,765,056
+$7,816,974
+ESTIMATED
+CURREN
+ANNUAL INCOME
+YELD IN
+93,181
+1.2000
+$93,181
+$93,181
+$7,816,974
+Transaction Detail
+MONEY FUND ACTIVITY
+TRANSACTION
+02/01/03
+02/03/09 DIVIDEND
+ö2/03/03 REINVEST
+02/28/03
+TOTAL
+ESCAIPTICY
+OPENINGBALANCE
+PETE HAS MANACEMENFCLA
+MONTHLY DIVIDEND
+DIVIDEND REINVESTED
+CLOSINGBALANCER
+SYMBOUCUSIP
+"DiCXX
+"DICXX"
+QUANTITY
+7,756,702.93
+8,353.32
+7,765,056.25
+027
+PRICE
+DEBIT AMOUNT
+CREDIT AMOUNT
+8,353.32
+8,353.32
+$-8,353.32
+$8,353.32
+VE41
+
+
+5 of 5
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+02/21/03
+INTEREST ON CREDIT BALANCE
+AT O 3/4% 01/21 THRU 02/20
+TOTAL
+SYMBOL/CUSIP
+QUANTITY
+RATE (%)
+0.7500
+STOP
+*** End of Statement******
+027
+DEBIT AMOUNT
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 1,2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+January 31,2003
+CREDIT AMOUNT
+33.51
+$33.51
+VB41
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary •••••••••••I
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ........../../............................
+Your Messages .....................................
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+December 31, 2002
+3
+5
+6
+Hollandlold
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+...
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+51,884
+7,756,703
+$7,808,587
+9,460,332
+-1,651,745
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+57.808.58 S9.460,332
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+
+
+2 of 6
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 orB
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Funds Withdrawn
+Miscellaneous
+Amount Debited.
+Net Cash Activity
+Closing Balance.
+THIS PERICO
+$113,828.97
+1,610,200.12
+55.43
+$1.610,255.55
+-10,200.12
+-104,000.00
+-1,558,000.00
+5-1.672.200.12
+-61,944.57
+$51,884.40
+Income Summary
+THIS PERIOD
+Credit Balance Int.
+55.43
+Total
+$55.43
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+113,828.97
+$113,828.97
+CLOSING
+51,884.40
+$51,884.40
+1.••...
+027
+YEAR TO DATE
+55.43
+.........
+.. $55.43
+7,808,587
+57,808,587
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+December 31, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+market values. The alocation percentage is derived
+
+
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+CASH BALANCE
+... . . .
+DREYFUS CASH MANAGEMENT-CLA
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+DICXX
+QUANTITY
+7,756,702.93
+PRICE
+1.0000
+MARKET
+VALUE
+51,884
+7,756,703
+$7,808,587
+*******•//--.
+100,837
+1.3000
+$100,837
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+$100,837
+$7,808,587
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+01/07/03
+TRANSACTION
+FND WIRED
+TOTAL
+DESCRIPTION
+MR TASER ENDS WIRED TO
+DEBIT AMOUNT
+104,000.00
+$-104,000.00
+CREDIT AMOUNT
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+December 31, 2002
+
+
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+5 orB
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+TRANSACTION
+01/01/03
+ö0203RE
+01/02/03
+"DIVIDEND
+0176703 SOLD
+DESCAIPTION
+OPENINGBALANCE
+PREYFUS CASH MANAGEMENT-CLA
+DIVIDEND REINVESTED
+STAMANAGEMENT CLA
+AMT INCLUDED IN 2002 - 1099
+RETTONS SHARE MENTICLA
+01/31/03
+TOTAL
+CLOSINGBALANCE
+INTEREST
+DATE
+DESCRIPTION
+01/21/03
+INTEREST ONCREDIT BALANCE
+AT 0 34% 12/21 THRU 12/30
+
+•'INTEREST ONCREDIT BALANCE
+AT 0 3/4% 12/31 THRU 01/20
+TOTAL
+SYMBOUCUSIP
+SYMBOUCUSIP
+BICXX
+DICXX
+DICXX
+QUANTITY
+QUANTITY
+9,346,502.81
+10,200.12
+1,600,000
+7.756,702.93
+RATE (SL
+0.7500
+0.7500
+027
+PRICE
+120000*
+DEBIT AMOUNT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+December 31, 2002
+DEBIT AMOUNT
+CREDIT AMOUNT
+10,200.12
+10,200.12
+1,600,000.00
+$-10,200.12
+$1,610,200.12
+CREDIT AMOUNT
+23.71
+31.72
+$55.43
+VB40
+
+
+6 of 8
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+December 31, 2002
+Transaction Detail (continued)
+MISCELLANEOUS
+DATE
+MO/DAY
+01/07/03
+TRANSACTION
+JOURNAL
+TOTAL
+DESCRIPTION
+TO 047-30185
+PER LOA
+DEBIT AMOUNT
+1,558,000.00
+$-1,558,000.00
+CRECIT AMOUNT
+Your messages
+The interest, if any, charged to your account
+during December 2002 was computed on
+the net debit balance through December 30,
+The interest, if any, charged to your account
+during January 2003 is computed from
+December 31, 2002,
+STOP
+****** End of Statement******
+027
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/a16595faa272c0ba4b36a1f16c7f78752e8aa8c2c6aa0673e691698b91042098.receipt.json b/vision-fixhub/ds9-unparsed-05/a16595faa272c0ba4b36a1f16c7f78752e8aa8c2c6aa0673e691698b91042098.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4ea98fedd15b71b6b1f907ad9520abdd5a83a49b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a16595faa272c0ba4b36a1f16c7f78752e8aa8c2c6aa0673e691698b91042098.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -6401,
+  "dataset": "marble-joined",
+  "doc_id": "a16595faa272c0ba4b36a1f16c7f78752e8aa8c2c6aa0673e691698b91042098",
+  "engine": "marble-apple-vision",
+  "event_count": 71,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "0323b2418b3efb7022ea6a2abfcc276772affea90fdd9f27c45b829a8368bc78",
+  "output_sha256": "587f328ce8e1235db8b4cbb293e465b6bbe1079430d761f686079959d54103c9",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a18b9571c19aa4426ffe68efc0ec172288ab8148351123331eff9e4b977590d6.md b/vision-fixhub/ds9-unparsed-05/a18b9571c19aa4426ffe68efc0ec172288ab8148351123331eff9e4b977590d6.md
new file mode 100644
index 0000000000000000000000000000000000000000..d7389429403f4c9a7b15aee9c4e0c9297dc6b957
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a18b9571c19aa4426ffe68efc0ec172288ab8148351123331eff9e4b977590d6.md
@@ -0,0 +1,31 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+West Palm Beach, FL 33401
+500 South Australian Ave., Suite 400
+Facsimile:
+May 15, 2007
+VIA FACSIMILE
+Jack A. Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+One Clearlake Centre, Suite 1400
+250 Australian Ave S.
+West Palm Beach, FL 33401-5015
+Re: Subpoenas to JEGE, Inc. and Hyperion Air, Inc.
+Dear Mr. Goldberger:
+It was a pleasure speaking with you today. As we discussed, the deadlines for complying with the
+subpoenas to JEGE, Inc. and Hyperion Air, Inc. have been extended to May 29, 2007. If there are any
+categories for which no documents exist, please ask the Custodian of Records to provide a certificate of
+nonexistence of records.
+Also, following our conversation I received a voicemail from Lilly Ann Sanchez addressing the
+subpoenas. Since you have provided a written statement that you represent JEGE and Hyperion, I will
+assume that you alone serve as their counsel unless you tell me otherwise. With that in mind, pursuant to
+Rule 6(e), I do not intend to discuss matters related to these subpoenas with other attorneys.
+Thank you again for your assistance.
+By:
+Sincerely,
+R. Alexander Acosta
+United States Attorney
+Assistant United States Attorney
+cc:
+FBI
diff --git a/vision-fixhub/ds9-unparsed-05/a18b9571c19aa4426ffe68efc0ec172288ab8148351123331eff9e4b977590d6.receipt.json b/vision-fixhub/ds9-unparsed-05/a18b9571c19aa4426ffe68efc0ec172288ab8148351123331eff9e4b977590d6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..38c3c87221c359f0097f4121218399931a366b86
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a18b9571c19aa4426ffe68efc0ec172288ab8148351123331eff9e4b977590d6.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "a18b9571c19aa4426ffe68efc0ec172288ab8148351123331eff9e4b977590d6",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "36aee08c079708f451a3b142b175e2266c8cf4ce1bbcfc78e471b129fbbd4414",
+  "output_sha256": "aadc7a1593de442c1af808694f606ba24d867326f6b9264a54a9e9d7b026b612",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a19414f9522aa1402a5b40f673bd94eb8dc1c9b0d7b5bc98e91a198ac97e27fd.md b/vision-fixhub/ds9-unparsed-05/a19414f9522aa1402a5b40f673bd94eb8dc1c9b0d7b5bc98e91a198ac97e27fd.md
new file mode 100644
index 0000000000000000000000000000000000000000..e1b6f49f1196630fd2231a2bf0e7fa0d74592ebe
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a19414f9522aa1402a5b40f673bd94eb8dc1c9b0d7b5bc98e91a198ac97e27fd.md
@@ -0,0 +1,27 @@
+Villafana, Ann Marie C. (USAFLS)
+From:
+Sent:
+To:
+Cc:
+Subject:
+Villafana, Ann Marie C. (USAFLS)
+Friday, September 21, 2007 9:49 AM
+Acosta, Alex (USAFLS)
+Garcia, Rolando (USAFLS); Atkinson, Karen (USAFLS); Lourie, Andrew
+Epstein indictment package
+Good morning, Alex. I have not received my promised phone call from Mr. Lefkowitz, and, based upon
+yesterday's conversations and Andy's most recent e-mails, it looks like we will be indicting Mr. Epstein on
+Tuesday. The package has been reviewed and approved by my immediate supervisor, Karen, and is with
+Rolando now. Do you want anyone in Miami to review it as well? I think Jeff is back on Monday and he has
+familiarity with the case, so we can wait for him, or I can send everything to Bob and/or Ed. Just let me know.
+Thank you.
+A. Marie Villataña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+Tracking:
+3005
+08-80736-CV-MARRA
+P-014161
diff --git a/vision-fixhub/ds9-unparsed-05/a19414f9522aa1402a5b40f673bd94eb8dc1c9b0d7b5bc98e91a198ac97e27fd.receipt.json b/vision-fixhub/ds9-unparsed-05/a19414f9522aa1402a5b40f673bd94eb8dc1c9b0d7b5bc98e91a198ac97e27fd.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..48be9a5efe07659a0c9f487ab9192efd533b46a1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a19414f9522aa1402a5b40f673bd94eb8dc1c9b0d7b5bc98e91a198ac97e27fd.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "a19414f9522aa1402a5b40f673bd94eb8dc1c9b0d7b5bc98e91a198ac97e27fd",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "0f4f0e966c9983322dd99799fc7c9910ffd678e68254021e2e1de363cb5d923b",
+  "output_sha256": "c2a1fbf0250f9c98fa2403684cefb42883d41677c45f9fd3c5ebe41d83356c78",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a1acedf4df2e584b59cb9d0800ba0c80118e30ef2b2dc6f445c8c85d57b7297b.md b/vision-fixhub/ds9-unparsed-05/a1acedf4df2e584b59cb9d0800ba0c80118e30ef2b2dc6f445c8c85d57b7297b.md
new file mode 100644
index 0000000000000000000000000000000000000000..71fb49de4447b7fe6d0455d4dd95c4688208e085
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a1acedf4df2e584b59cb9d0800ba0c80118e30ef2b2dc6f445c8c85d57b7297b.md
@@ -0,0 +1,5889 @@
+Statements
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .....
+Your Messages
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 30, 2001
+3
+9
+C/O AMERICAN YACHT HARBOR *
+6100 RED HOOK SUITE B-3
+QUARTERS #2
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+29,406.395
+11,290
+37,523,003
+S66,940,688
+•••••••••••••••••••••
+89,939,338
+-22,998,650
+ere are no "Stop Loss' orders or other pending bu
+r sell open orders on file for your accoun
+Cash & Equivalent
+Equities
+Market Value of Your Portfolio
+$37,534,293
+$26,677,280
+$30,526,395 : $-1,120,000
+Current market value
+Last statement's market value
+Short market value
+$63,792,058
+: $-530,000
+Important Message
+If any information regarding
+2001 interest, dividends,
+miscellaneous income,
+gross proceeds or original
+issue discount is required
+to be reported to the IRS for
+his account,
+Consolidated Form 1095
+will be mailed to you by
+Da March 152022: 10425
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The surren s four erratanal purposes rear die Set revere date for portant iformation.
+
+
+2 of 9
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+
+
+3 or 9
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Money Fund
+Funds Withdrawn
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+$3.002, 139.76
+....
+22,427,836.16
+4,047,863.33
+151,829.43
+13,518,953.25
+340.146-48217
+-18,289,468.42
+-17,847,863.33
+-6,000,000.00
+-1,000,000.00
+S.43.137.331.75
+-2,990,849.58
+11,290.18
+Income Summary
+Dividends
+Substitute Payment
+Credit Balance Int.
+Total
+Foreign Tax Withheld
+Margin Int. Paid
+THIS PERIOD
+197,580.93
+0.00
+2,111.83
+$199,692.76
+0.00
+0.00
+Portfolio Composition
+SHORT
+Cash/Cash Equivalent
+Equities
+Total
+1,120,000
+$1,120,000
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+3,002,139.76
+$3,002,139.76
+CLOSING
+11,290.18
+....
+$11,290.18
+027
+YEAR TO DATE
+1,286,480.16
+76,725.66
+38,425.74
+1.401,631.56
+-150.00
+-48,516.34
+LONG
+37,534,293
+30,526,395
+568,060,688
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 30, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent
+55%
+Equities
+44%
+- Short Equities
+1%
+Unshaded portions denote debe balance andor short
+market values. The alocation percentage is derived
+
+
+4 of g
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+... .
+DREYFUS CASH MANAGEMENT-CLA
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRPTION
+CNH GLOBAL
+•••••• • •••••••••••••••
+TOO INC
+CALL TOO ING
+JAN 025 CBOE
+EXP 01/19/2002
+.. . .
+ALL TOO IN
+EB 025CB0
+EXP 02/16/2002
+CALL TOOING FEB
+FEB ОЗОСВОЕ
+EXP 02/16/2002
+VECTOR GROUP LTD
+SENTIGEN HOLDING CP ASTD
+Total Equities& Options
+TOTAL EQUITIES
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+DICCX
+QUANTITY
+37,523,003.02
+1.0000
+SYMBCUCUSIP
+CNH
+TOO
+TOOAE
+TOOBE
+TOOBF
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+250,000
+550,000
+-3,000
+-500
+-2,000
+374,294
+333,334
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 30, 2001
+MARKET
+VALUE
+11,290
+37,523,003
+$37,534,293
+STIMATE
+ANUAL INCON
+863,029
+$863,029
+2.3000
+6.0900
+27.5000
+... ..
+6500
+3.3000
+0.8000
+32.8500
+4.7500
+MARKET
+VALUE
+1,522,500
+15,125,000
+795,000
+-165,000
+- 160.000
+12,295,558
+1,583,337
+$29,406,395
+$29,406,395
+ESTIMATED
+SURREN
+ANNUAL INCOM
+YIELD IS
+138,000
+9.0640
+•••••••••••••••••••••••••••••••
+598,870
+$736,870
+$736,870
+4.8706
+027
+
+
+5 org
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SEEMENT TRE
+12/18/01
+12/13/01
+12/18/01
+12/20/01
+12/17701"BOUGHT
+
+
+'SOLD"
+LADENBURG THALMANN FINL SVCS
+UNSOLICITED
+SAME
+AT&T CORP
+UNSOLICITED
+ATaT CORP
+AS OF TRADE
+AS OF 12/17101.
+$1,599,899
+$66,940,688
+SYMBOLCUSP
+LTS
+QUANTITY
+-130,254
+1.00370
+-7,000,000
+1,102,200
+-1, 102,200
+16.53360
+16.53360
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 30, 2001
+CRECAT AMOUNT
+127,993.75
+18.289,468.42
+18,222,723.97
+
+
+6 of g
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SETTLEMENT TRADE
+12/20/01
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+12/2001
+"DELIVERED
+
+12/18/01
+12/2101
+12/20/01 SOLD
+
+12/26/01
+'''12/2401SOLB*
+1226/01
+''12/24701"SOLB*
+12/26/01
+JOURNAL"
+LADENBURG THALMANN FINL SVCS
+SECTOR GROUP LID I SHS
+121 VNN PAY 122010
+OF 12/11/
+ESTEE LAUDER COMPANIES INC
+DEL TO 00005
+TELIGENT INC-CLA
+CALL "TOO ING "JAN 025 CBOE"
+EXP 01/19/2002
+CHEN CONTRACT
+TOO INC
+JAL FM L
+PER INTX'S
+CALL 100 ING "JAN 025CBOE
+EXP 01/19/2002
+ISOLICITE
+EN CONTRAI
+CALL TOO ING FEB 025CBOE
+XP 02/16/2002
+INSOLICITEL
+OPEN CONTRACT
+AS OF 12/24/01
+TOO INC
+JAL FM
+PER INTX'S
+SYMBOLGUSP
+ITS
+EL
+T00
+TOO
+027
+QUANTITY
+130,254
+- 100,000
+-60,000
+2,500
+100,000
+500"
+500*
+50,000
+0.00550
+- 235000
+*2:75000
+'3.35000
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+November 30, 2001
+CRECIT AMOUNT
+3,196,753.23
+152.48
+578,727.91
+135,742.91
+165,741.91
+$-18,289,468.42
+$22,427,836.16
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+7 of g
+Transaction Detail (continued)
+DEPOSITS AND WITHDRAWALS
+
+FND WIRED
+12/1401
+""FND WIRED"
+FNDS WIRED TO
+TAMERSEAK
+1219781*#ND WIRED***
+WIRED" 10"
+12/27/01
+FND WIRED
+$ COMING FROM DREYFUS TODAY
+CHBED TO
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+12/01/01
+126381 BIMBEND"
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 30, 2001
+2,000,000.00
+1,000,000.00
+"2,000,000.00"
+1,000,000.00
+$-6,000,000.00
+1205/01
+12/1401
+12/19/01
+DESCAIPTON
+OPENINGBALANCER
+MONTHLY DIVIDEND
+ALYFUS CASHMANAGEMENT-EL'
+STITUTIONAL SHARE
+DIVIDEND REINVESTED
+RATE AS ANAGEMENTCLA
+STITONS SHANAGEMENTCLA
+RESENORASS MANAGEMENT CLA
+SYMBOUCUSIP
+''''BICEX"
+"DICCX
+"DICCX
+DICCX
+QUANTITY
+23,675,139.69
+47:86333
+"M,400,000
+000,000
+2,000,000
+027
+n47,883:33
+••••••••••••••••••••••*47.863:33***
+1.0000"
+0000
+.0000
+11:400.000.00
+000:00
+2,000,000.00
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+8 of g
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+12/20/01
+12/2101
+"SOLD"
+
+"BOUGHI
+DESCAIPTION
+RETYEHIONASS MANAGEMENT-CLA
+RESIGNASE MANAGEMENT CLA
+12/31/01
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+12/20/01
+VECTOR GROUP LTD
+REC 12/10/01 PAY 12/20/01
+SYMBOL/CUSIP
+VGR
+INTEREST
+DATE
+12/21/01
+
+SYMBOUCUSIP
+INTEREST ON CREDIT BALANCE
+AT 1 1/2% 11/19 THRU 12/10
+"DICCX
+QUANTITY
+374,294
+QUANTITY
+QUANTI
+3,400,00
+000,000
+3.000,000
+37,523,003.02
+RATE (S)
+0.4000
+RATE (%)
+1.2500
+1.5000
+027
+1.0000
+0000
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+November 30,2001
+3,400,000.00
+000,000.00
+3,000,000.00
+$-17,847,863.33
+$4,047,863.33
+149,717.60
+$149,717.60
+28.64
+2,083.19
+$2,111.83
+01/03/02:08:34 001
+
+
+9 org
+Transaction Detail (continued)
+MISCELLANEOUS
+DATE
+MO/DAY
+12/04/01
+i22101
+i22401
+ANSACTI
+URNA
+JOURNAL"
+CASH-LIEU
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+1226/01
+COL REC LOA FROM |
+0 353-01417"
+"LADENBURG THALMANN FINL SVOS"
+ASH IN LIEU OF ,31201
+ECTOR GROUP LT
+SPINOFF VS V021 1220101
+AT&T CORP
+DERIVATIVE SETTLEMENT
+Your messages
+As part of the National Association of Securities Dealers (NASD)
+Investor Education Program, you may obtain information on the
+JASD's Public Disclosure Program by contacting the NASI
+t telephone number (800) 289-9999 or via the internet address whic
+Public Discosure Program is aval able form the AS upon request.
+STOP
+****** End of Statement******
+1,000,000.00
+10.479.583.05
+031
+3.039,369.89
+$-1,000,000.00
+$13,518,953.25
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 30, 2001
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail .................................
+Fund Activity ...................../...................
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD October 27, 2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 26,2001
+3
+7
+C/O AMERICAN YACHT HARBOR *
+6100 RED HOOK SUITE B-3
+QUARTERS #2
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+63.262.058
+3,002,140
+23,675,140
+$89,939,338
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+60,689,473
+29,249,865
+ere are no "Stop Loss' orders or other pending bu
+r sell open orders on file for your accoun
+Cash & Equivalent -
+Equities
+Market Value of Your Portfolio
+$26,677,280
+$28,224,245
+$63,792,058
+: $-530,000
+• $34,495,728 : S-2,030,500
+Current market value
+Last statement's market value
+Short market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal purpose rearde Set revere dae for portant iformation.
+12/01/01:10:46 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+12/01/01:10:46 001|
+
+
+Cash Flow Analysis
+THIS PERICO
+Opening Balance
+5813,411-91
+Securities Sold
+3,325,883.81
+Money Fund
+3,864,306.54
+Dividends/Interest
+869.82
+Amount Credited
+$7,191,060.17
+.......
+Securities Bought
+-457,002.50
+Money Fund
+-64,306.54
+Funds Withdrawn
+-100,000.00
+Dividends/Interest Charged
+-23.28
+Miscellaneous
+-4,381,000.00
+Amount Debited
+5-5.002.332.32
+Net Cash Activity
+2,188,727.85
+Closing Balance
+__ 83,02.139.76
+Same day transfers of cash between acocurt types are not included in thi
+section; such transfers, as well as details for all other transactions this period
+appear in Transaction Detal.
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+608,039.20
+205,372.71
+$813,411.91
+Income Summary
+Dividends
+Substitute Payment
+Credit Balance Int.
+.. . .
+Total
+Foreign Tax Withheld
+Margin Int. Paid
+THIS PERIOD
+64,306.54
+0.00
+869.82
+$65
+176.36
+0.00
+-23.28
+Portfolio Composition
+SHORT
+Cash/Cash Equivalent
+Equities
+Total
+530,000
+$530,000
+027
+CLOSING
+3,002,139.76
+0.00
+$3,002,139.76
+YEAR TO DATE
+1,088,899.23
+76,725.66
+36,313.91
+--..
+201,938.80
+-150.00
+-48,516.34
+LONG
+26,677,280
+63,792,058
+590,469,338
+1201/01:10:46 001
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD October 27, 2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 26,2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+29%
+Short Equities
+<1%
+• Equities
+Unshaded portions denote debit balance andor shart
+from the absolute market value of your portfolio.
+
+
+4 of a
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+. . . .
+DREYFUS CASH MANAGEMENT-CLA
+S30 DAY SHARE 23800%
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRPTION
+CNH GLOBAL
+••••••••••••••••••••••••••••••••••••••••
+ESTEE LAUDER COMPANIES INC
+TOO INC
+CALL TOO ING FEB ОЗОСВОЕ
+EXP 02/16/2002
+VECTOR GROUP LTD
+SENTIGEN HOLDING CP ASTD
+Total Equities& Options
+TOTAL EQUITIES
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+DICCX
+QUANTITY
+23,675,139.69
+1.0000
+SYMBOUCUSIP
+CNH
+EL
+TGNTQ
+TOO
+TOOBF
+VGR.
+CASH
+CASH
+CASH
+--...
+CASH
+CASH
+CASH
+QUANTITY
+250,000
+....
+100,000
+60,000
+1,400,000
+........
+-2,000
+374,294
+333,334
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD October 27, 2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 26,2001
+MARKET
+VALUE
+3,002,140
+23,675,140
+$26,677,280
+ESTIMATED
+ANIVUAL INCOME
+662,904 2.8000
+$662,904
+5.1900
+33.3700
+0.1000
+29.3700
+............
+2.6500
+43.9500
+4.7500
+MARKET
+VALUE
+1,297,500
+••••••••••••
+3,337,000
+6,000
+¡aaaaaaaaaaaani
+41,118,000
+.....
+-530,000
+.....
+16.450,221
+1,583,337
+$63,262,058
+$63,262,058
+ESTIMATED
+ANNUAL INCOME
+138,000
+20,000
+SURREN
+MELD (3
+10.6358
+0.5993
+598,870
+$756,870
+$756,870
+3.6405
+027
+12/01/01:10:46 001
+
+
+5 or 8
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SETILEMENT TRADE
+DATE
+11/06/01
+DATE
+RECEIVED
+
+11715/01
+
+11715/01
+'BÖUGHT
+11716/01
+ESTEE LAUDER COMPANIES INC
+REEV FROM 00005
+CALL TOOING FEB 030CB0E
+
+UNSOLICITED
+OPEN CONTRACT
+ALL TOO ING "NOV 025CB0
+CLOSING CONTRACT
+"TOO INC
+PER L0A7-30185
+$1,419,774
+$89,939,337
+SYMBOLGUSP
+EL
+SH6EE6068.
+QUANTITY
+100,000
+2,000
+2,000
+000,000
+1.65000
+2.25000
+027
+12/01/01:10:46 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD October 27,2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 26,2001
+3,181,000.00
+322,986.50
+457,00250
+
+
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SETLEMENT TRADE
+11/19/01
+1772001 77719/01"SOLD
+11728/01
+17728/01
+11/28/01
+11/28/01
+DEPOSITS AND WITHDRAWALS
+DATE
+11/29/01
+END WIRED
+BARK OF RIOUR SCOTIA
+OFFICE SERVICING YOUR ACOOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CALL VECTOR GRP NOV 28.625****
+ADJ 5% STOCK DIVIDEND
+EE 114720 ASSIGNED 01459
+VECTOR GROUP LTD
+AVE NOTES: ON 1000 ASSIGNED
+"ENH GLOBAL" L
+JOURNAL FROM TYPE 2 TO 1
+VECTOR GROUP LiD
+JOURNAL FROM TYPE 2 TO 1
+NH GLOBAL T
+URNAL FROM TYPE 2 TO
+.. . . .
+VECTOR GROUP LTD
+JOURNAL FROM TYPE 2 TO 1
+WIRED TO
+SYMBOL/CUSIP
+92240M9K6
+VGR
+"CNH
+100,000.00
+$-100,000.00
+027
+QUANTITI
+1,000
+105,000
+250,000
+374,294
+250,000
+374,294
+28.62500
+12/01/01:10:46 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD October 27, 2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 26, 2001
+3,002,897.31
+$-3,638,002.50
+$3,325,883.81
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+7 of a
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+TRANSACTKN
+10/27/01
+1170101ÖMDEND
+11/01/01
+"REINVEST
+11705/01 SOLD
+11708/01 SOLD
+11/19/01
+'SOLD"
+DESCHIPTION
+OPENINGBALANCE
+PREYFUS CASH MANAGEMENT-CLA
+MONTHLY DIVIDEND
+RETCHONAS MANAGEMENT-CLA
+DIVIDEND REINVESTED
+RETONA MANAGEMENTECTA
+SO SELL
+ANANA MANACEMENTCLA
+RENASE MAAGEMENFCEA
+11/30/01
+CLOSINGBALANCE
+INTEREST
+DATE
+11/21/01
+INTEREST ON CREDIT BALANCE
+
+AT 1 1/2% 11/06 THRU 11/20
+'''INEREST ON CAEBY BALANCE"
+AT 2,000% 10/21 THRU 11/05
+1/21/0
+BALM 110 AVAL 101.2002344%
+AVAL 101,604
+SYMBOUCUSIP
+SYMBOUCUSIP
+DICCX
+"DICCX
+QUANTITY
+QUANTITY
+27,410,833.15
+64,306.54
+-2,400,000
+1,200,000
+200,000
+23,675,139.69
+RATE (%)
+1.5000
+2.0000
+2.7500
+027
+1.0000
+10000*
+1.0000
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD October 27, 2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 26, 2001
+64,306.54
+64,306.54
+2,400,000.00
+,200,000.00
+200,000.00
+$3,864,306.54
+23.28
+$-23.28
+12/01/01:10:46 001
+$-64,306.54
+13.50
+856:32
+$869.82
+
+
+8 of a
+Transaction Detail (continued)
+MISCELLANEOUS
+DATE
+MO/DAY
+11/05/01
+11/05/01
+17768/01
+19728/01
+11/28/01
+ANSACTI
+URNA
+JOURNAL"
+JOUANAL
+JOURNAL'
+JOURNAL FROM TYPE 2101
+JOURNAL FROM TYPE 2101
+*T0 102-25423
+JOURNAL FROM TYPE 2T01
+JOURNAL FROM TYPE 2 TO 1
+205,372.71
+1,200,000.00
+3,002,874.03
+$-4,408,246.74
+STOP
+****** End of Statement******
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD October 27, 2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 26,2001
+205,372.71
+3,002,874.03
+$3.208.246.74
+12/01/01:10:46001
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ............../....../....................
+Your Message. ............................I.....
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 28, 2001
+3
+5
+7
+C/O AMERICAN YACHT HARBOR *
+6100 RED HOOK SUITE B-3
+QUARTERS #2
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+32,465,228
+813,412
+27,410,833
+$60,689,473
+58,387,666
+2,301,807
+Cash & Equivalent
+Equities
+Market Value of Your Portfolio
+$28,224.245
+$27,743,103
+$34,495,728
+: S-2,030,500
+$32,167,063 : $-1,522,500
+Current market value
+Last statement's market value
+Short market value
+ere are no "Stop Loss" orders or other pending bu
+sell open orders on file for your accoun
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four or ratanal furycer rear die Set revere date for portant iformation.
+10/27/01;09:11001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+10/27/01:09:11 001|
+
+
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Money Fund
+Amount Debited.
+Net Cash Activity
+Closing Balance.
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+204,178.90
+205,352.75
+$409,531.65
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERIOD
+409,531.6
+..........
+402,983.83
+77,261.81
+876.47
+19.96
+$481,142.07
+....
+-77,261.81
+... .
+5-77,261.81
+403,880.26
+....
+$813,411.91
+Income Summary
+Dividends
+Substitute Payment
+Credit Balance Int.
+Total
+Foreign Tax Withheld
+Margin Int. Paid
+THIS PERIOD
+77,261.81
+0.00
+876.47
+.$78,138.28
+0.00
+0.00
+Portfolio Composition
+SHORT
+Cash/Cash Equivalent
+Equities
+Total
+2,030,500
+$2,030,500
+CLOSING
+608,039.20
+205,372.71
+$813,411.91
+..........
+027
+YEAR TO DATE
+1,024,592.69
+76,725.66
+35,444.09
+36.762.4
+-150.00
+-48,493.06
+LONG
+28,224,245
+34,495,728
+$62,719,973
+10/27/01:09:11001
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 28, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent/
+44%
+Equities
+53%
+Short Equities-
+3%
+Unshaded portions denole debi balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+......
+DREYFUS CASH MANAGEMENT-CLA
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRPTION
+CNH GLOBAL
+TELIGENT INC-CLA
+TOO ING
+.. . . .
+CALL TOO ING
+NOV 025 CBOE
+EXP 11/17/2001
+VECTOR GROUP LTD
+CALL VECTOR GRP NOV 28.625****
+ADJ 5% STOCK DIVIDEND
+EXP 11/17/2001
+SENTIGEN HOLDING CP RSTD
+Total Equities& Options
+TOTAL EQUITIES
+OFFICE SERVICING YOUR ACOOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+DICCX
+QUANTITY
+27,410,833.15
+1.0000
+SYMECUCUSIP
+CNH
+TGNTQ
+.......
+TOO
+... .
+TOOKE
+VGR
+XGQK28
+MRGN
+CASH
+... ..
+CASH
+MAGN
+CASH
+QUANTITY
+250,000
+60,000
+....
+00,00
+-2,000
+479,294
+1,000
+333,334
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 28, 2001
+MARKET
+VALUE
+813,412
+27,410,833
+$28,224,245
+ESTIMATED
+ANNUAL INCOME
+*******•//--.
+904,557 3.3000
+$904,557
+5.4000
+0.2300
+.....
+27.4100
+2.7500
+42.6000
+14.1000
+5.2500
+MARKET
+VALUE
+1,350,000
+13,800
+0,964,000
+-550,000
+20.417,924
+-1,480,500
+1,750,004
+$32,465,228
+$32,465,228
+ESTIMATED
+ANNUAL INCOME
+138,000
+SURREN
+YIELD 15%
+10.2222
+766,870 3.7559
+$904,870
+$904,870
+027
+10127101;09:11 001
+
+
+5 ol7
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+10/12/01
+10/11/01
+MONEY FUND ACTIVITY
+09/29/01
+... ...
+DESCRPTION
+CALL TOO ING NOV025CBOE
+EXP 11/17/2001
+OPEN CONTRAC
+IS OF 10/11/01
+OPENINGBALANCE
+REMBRAMANAGEMENTOLA'
+MONTHLY DIVIDEND
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 28, 2001
+$1,809,427
+$60,689,472
+SYMBOLCUSP
+OTOOKE
+QUANTITY
+-2,000
+2.05000
+CREDIT ANNOUNT
+402,983.83
+$402,983.83
+SYMBOUCUSIP
+QUANTITY
+27,333,571.34
+77,261.81
+027
+10/27/01;09:11001
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of 7
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+T0/01/01
+REINVEST
+.......
+10/26/01
+REFIGHBRASS MANAGEMENT-CLA
+DIVIDEND REINVESTED
+CLOSINGBALANCE
+INTEREST
+DATE
+10/22/01
+INTEREST ON CREDIT BALANCE
+AT 1 1/2% 09/21 THRU 09/23
+10/22/01 INTEREST ON CREDIT BALANCE
+AT 2 1/2% 09/24 THRU 10/01
+10122/01
+AN 200% 102 R 10202
+SYMBOUCUSIP
+MISCELLANEOUS
+10/01/01
+CASH-LIEU
+VECTOR GROUP LTD
+CASH IN LIEU OF 55000
+REC 09/21/01 PAY 09/28/01
+SYMBOUCUSIP
+DICCX
+QUANTITY
+77,261.81
+27,410,833.15
+QUANTITY
+RATE (S
+1.5000
+
+2.0000
+027
+CRECIT AMOUNT
+19.96
+$19.96
+10/27/01;09:11 001
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 28, 2001
+77,261.81
+$-77,261.81
+$77,261.81
+65.87
+'176.80
+• 633.80
+$876.47
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 28, 2001
+Your messages
+13F
+We are pleased to announce that we have moved
+ur world headquarters, previously located at
+245 Park Avenue, to:
+383 Madison Avenue
+New York, New York 10179
+While our telephone numbers and e-mail addresses
+remain the same, some fax numbers have changed,
+Please check with your Account Executive.
+STOP
+****** End of Statement******
+027
+10/27/01;09:11 001
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ............../....../....................
+Your Message. ............................I.....
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 31, 2001
+3
+5
+8
+C/O AMERICAN YACHT HARBOR *
+6100 RED HOOK SUITE B-3
+QUARTERS #2
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+30,644.563
+409,532
+27,333,571
+$58,387,666
+62,284,004
+-3,896,339
+Cash & Equivalent
+Equities
+Market Value of Your Portfolio
+S27.743,103
+$29,122,764
+$32,167,063
+: $-1,522,500
+$35,413,740 : $-2,252,500
+Current market value
+Last statement's market value
+Short market value
+ere are no "Stop Loss" orders or other pending bu
+r sell open orders on file for your accoun
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal furyce rear die Set revere date for portant iformation.
+09/29/01;10:55 001
+
+
+2 of 9
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+09/29/01:10:55 001|
+
+
+3 org
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Money Fund
+Miscellaneous
+Amount Debited.
+Net Cash Activity
+losing Balanc
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+0.00
+322,764.35
+$322,764.35
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+THIS PERICO
+5322, 764.35
+1,533,571.34
+184,760.90
+2,006.40
+....
+$1,720,338.64
+... .
+-33.571.34
+-1,600,000.00
+5 1. 638.571.34
+86,767.30
+....
+5409,531.65
+Income Summary
+Dividends
+Substitute Payment
+Credit Balance Int.
+Total
+Foreign Tax Withheld
+Margin Int. Paid
+THIS PERIOD
+214,153.34
+2,006.40
+4,178.90
+....
+$220,338.64
+0.00
+0.00
+Portfolio Composition
+SHORT
+Cash/Cash Equivalent
+Equities
+Total
+1,522,500
+$1,522,500
+CLOSING
+204,178.90
+205,352.75
+5409.531.65
+027
+YEAR TO DATE
+947,330.88
+76,725.66
+34,567.62
+58.624.1
+-150.00
+-48,493.06
+LONG
+27,743,103
+32,167,063
+$59,910,166
+09/29/01;10:55 001
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 31, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent,
+46%
+Short Equities
+2%
+Equities
+52%
+Unshaded portions denote debe balance andior short
+
+
+4 of g
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+....
+DREYFUS CASH MANAGEMENT-CLA
+ISTITUTIONAL SHARES
+OTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+DICCX
+EQUITIES
+Equities & Options
+CNH GLOBAL
+•.....
+TELIGENT INC-CLA
+100 INC
+VECTOR GROUP LTD
+CALL VECTOR GAP NOV 28.625
+ADJ 5% STOCK DIVIDEND
+EXP 11/17/2001
+......
+SENTIGEN HOLDING CP RSTD
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOUCUSIP
+CNH
+TGNTO
+TOO
+VGR
+XGOK28
+-
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+QUANTITY
+27,333,571.34
+1.0000
+MRGN
+CASH
+ASI
+MRGN
+MAGN
+CASH
+QUANTITY
+250,000
+60,000
+400,000
+79,294
+1,000
+333,334
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 31, 2001
+MARKET
+VALUE
+409,532
+27,333,571
+$27,743,103
+STIMATED
+NUAL INCON
+1,011,342 3.7000
+$1,011,342
+5.7700
+......
+0.1700
+20.9900
+42.7400
+14.5000
+5.5000
+MARKET
+VALUE
+1,442,500
+10,200
+8,396,000
+20.485,026
+-1,522,500
+1,833,337
+$30,644,563
+$30,644,563
+$1,916.
+$58.387,665
+027
+ESTIMATE
+VNUAL INCOM
+138,000
+766,870
+$904,870
+$904,870
+CURREN
+YIELD (%)
+9.5667
+.....
+3.7436
+09/29101:10:55 001
+
+
+5 org
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TREE
+09/19/01
+RANSACTIO
+JUANA
+05/19/61
+09/26/01
+09/28/01
+09/21/01
+"EXPIRED
+MONEY FUND ACTIVITY
+DATE
+MODAY
+09/01/01
+09/0401
+"DIVIDEND"
+09/04/01
+''REINVEST
+09/17/01
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+CALL VECTOR GROUP NOV 030 AMEX
+EXP 11/17/2001
+J 5% STOCK D
+SEC NUN
+CALL VECTOR CRP NOV 28.625****
+ADJ 5% STOCK DIVIDEND
+EXP 11/17/2001
+CALL 100 INC "SEP 025CB0E
+EXP 09/22/2001
+REC 09/21/01 PAY 09/28/0
+AS OF 09/21/0
+SYMBOL/CUSIP
+92240M9K6
+QUANTITY
+1,000
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+August 31, 2001
+CRECIT AMOUNT
+
+VGR
+- 3,050
+22,823
+OPENINGBALANCE
+EYFUS CASH MANAGEMENT-CL
+STITUTIONAL SHAR
+MONTHLY DIVIDEND
+REHENAS SHANAGEMENTOLA
+DIVIDEND REINVESTED
+RETS CASE MANAGEMENT CLA
+SYMBOUGUSIP
+"DICCX*
+"DICEX"
+DICCX
+QUANTITY
+28,800,000
+33.571.34
+1.000,000
+33571.34
+1.0000
+33,571.34
+1,000,000.00
+220
+09/29101;10:55 001
+
+
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+6 of 9
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+09/18/01
+REEKEY NASE MANAGEMENT-CLA
+.......
+09/28/01
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+09/28/01
+VECTOR GROUP LTD
+REC 09/21/01 PAY 09/28/01
+SYMBOUCUSIP
+VGR
+SUBSTITUTEPAYMENTS
+DATE
+09/28/01
+VECTOR GROUP LTD
+SYMBOUCUSIP
+VGR
+SYMBOUCUSIP
+DICCX
+QUANTITY
+451,455
+QUANTITY
+QUANTITY
+-500,000
+27,333,571.34
+RATE (S)
+0.4000
+RATE (S)
+027
+1.0000
+09/29/01:10:55 001
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 31, 2001
+500,000.00
+$-33,571.34
+$1,533,571.34
+CAEDIT AMCUNT
+180,582.00
+$180,582.00
+2,006.40
+$2,006.40
+
+
+7 of g
+Transaction Detail (continued)
+INTEREST
+DATE
+09/21/01
+INTEREST ON CREDIT BALANCE
+AT O 1/2% 09/19 THRU 09/19
+09121701 "INTEREST ON CREDIT BALANCE
+AT 1 1/2% 09/20 THRU 09/20
+09/21/01
+"INTEREST ON CREDIT BALANCE
+AT 2 1/2% 09/17 THRU 09/18
+09/21/01
+AT 3,00% 0C2i THE 0ANG
+MISCELLANEOUS
+DATE
+MO/DAY
+09/18/01
+08/19/01 JOURNAL
+09/21301"OUANAL
+09i2401
+TO
+SAME NAME
+TO
+SAME
+245 Pai An o. Inc.
+New York, New York 10167
+SYMBOL/CUSIP
+QUANTITY
+RATE (%)
+0.5000
+1.5000
+2.5000
+3.0000
+400,000.00
+400,000.00**
+"500,000.00
+300,000.00
+$-1,600,000.00
+027
+CRECIT AMOUNT
+09/29/01:10:55 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 31, 2001
+14.21
+42.62
+190.66
+3,931.41
+$4,178.90
+
+
+8 of 9
+Bear, Stears & Co. Ind
+245 Park Avenue
+New York, New York 10167
+LEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 31,2001
+Your messages
+This statement is provided to explain Bear, Steams & Co,
+Inc's ("BSC") payment for order flow practices.
+BSC routes a majority of orders for customer securities
+transactions to the primary market for such securities.
+Beginning October 31, 2001, you may request the identity
+of the venue to which any of your orders were routed for
+execution (if the order was within the six months prior t
+the request or July 2, 2001, whichever is a later date),
+whether the order was directed by you to that venue, and
+the time of the executions, if any, that resulted from such
+orders,
+(NBBO). BSC receives no cash payment or other
+consideration for such order routing other than favorable
+executions or executions of limit orders at no additional
+027
+09/29/01:10:55 001
+
+
+9 org
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York. New York 10167
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 31, 2001
+Bear, Stearns Securities Corp. Net Capital and Net Capital
+Requirements:
+At May 25, 2001 and July 27, 2001, the Company's net
+capital of $2,7 billion and $2,7 billion was approximatel
+3.9% and 9.2% of aggregate debit items and exceeded th
+minimum regulatory net capital requirement of $605.5
+million and $585,5 million by $2,1 billion and $2,1 billion,
+all respectively.
+A complete copy of the Bear, Stearns Securities
+Corp, Statement of Financial Condition is
+available on the web site www.bearstearns.com
+Alternatively, to request a free printed copy please call
+-toll free 1-866-299-9331
+Securities and other assets in your account are the firm's
+collateral for any margin loan made to you, If the securities
+and other assets in your account decline in value, so does
+the value of the collateral supporting your loan, and, as a
+result, the firm can take action, such as issue a margin call
+and/or sell securities or other assets in any of your accounts
+held with the member, in order to maintain the required equity
+in the account, It is important that you fully understand the
+risks involved in trading securities on margin, These risks include
+the following:
+You can lose more funds than you deposited in the
+margin account,
+The firm can force the sale of securities or other assets
+in your accounts).
+The firm can sell your securities or other assets without
+contacting you.
+You are not entitled to choose which securities o
+other assets in your accounts) are liquidated or solo
+to meet a margin call.
+le firm can increase it's "house" maintenan‹
+quirements at any time and is not required to provi
+you advance written notice.
+You are not entitled to an extension of time on a margin call.
+STOP
+****** End of Statement******
+027
+09/29/01:10:55 001
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail .................................
+Fund Activity ...................../...................
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOO July 28, 2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 27, 2001
+3
+6
+C/O AMERICAN YACHT HARBOR *
+6100 RED HOOK SUITE B-3
+QUARTERS #2
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+Market Value of Your Portfolio
+$29,122,764
+$497,904
+33,161,240
+322,764
+28,800,000
+S62.284,004
+47,678,411
+14,605,594
+Cash & Equivalent
+Equities
+$35,413,740
+: $-2,252,500
+$48,385,947 : $-1,205,440
+Current market value
+Last statement's market value
+Short market value
+here are no "Stop Loss' orders or other pending bu
+r sell open orders on file for your accoun
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four ratanal purger red de Set revere date for portant iformation.
+09101/01;10:37 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+09.01/01:10:37 001
+
+
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Miscellaneous
+THIS PERIOD
+497,903.6
+.. . .
+36,459,808.11
+5,000,000.00
+59,492.12
+5,560.46
+Amount Credited
+$41,524,860.69
+Money Fund
+-33,800,000.00
+Miscellaneous
+-7,900,000.00
+Amount Debited
+:41,700,000.00
+Net Cash Activity
+- 175,139.31
+Closing Balance..
+... $322.764.35
+Same day ransiers of cash between accourt types are not included in this
+section: such transfers, as well as details for all other transactions this period.
+appear in Transaction Detail.
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Income Summary
+Dividends
+Substitute Payment
+Credit Balance Int.
+Total
+Foreign Tax Withheld
+Margin Int. Paid
+THIS PERIOD
+52,439.54
+5,560.46
+7,052.58
+...
+$65,052.58
+0.00
+0.00
+Portfolio Composition
+SHORT
+Cash/Cash Equivalent
+Equities
+Total
+2,252,500
+$2,252,500
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+216,490.16
+281,413.50
+$497,903.66
+CLOSING
+0.00
+322,764.35
+....
+$322,764.35
+027
+YEAR TO DATE
+733,177.54
+74,719.26
+30,388.72
+$838.285.52
+-150.00
+-48,493.06
+LONG
+29,122,764
+35,413,740
+$64,536,504
+09101/01;10:37 001
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOO July 28, 2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 27,2001
+Your Portfolio
+Allocation
+Cash & Equivalent/
+44%
+Equities
+53%
+Short Equities -
+3%
+Unshaded portions denole debit balance and'or short
+
+
+4 of a
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+....
+DREYFUS CASH MANAGEMENT-CLA
+ISTITUTIONAL SHARES
+OTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+CNH GLOBAL
+TELIGENT ING-CLA
+TOO INC
+CALL TOOING
+SEP 025 CBOE
+EXP 09/22/2001
+VECTOR GROUP LTD
+CALL VECTOR GROUP NOV 030 AMEX
+EXP 11/17/2001
+SENTIGEN HOLDING CP RSTD
+Total Equities& Options
+TOTAL EQUITIES
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+SYMBOLCUSIP
+DICCX
+QUANTITY
+28,800,000
+1.0000
+SYMBOUCUSIP
+CNH
+TGNTO
+TOO
+TOOIE
+VGR
+VGRK30
+MRGN
+CASH
+CASH
+CASH
+MRGN
+CASH
+QUANTITY
+250,000
+60,000
+400,000
+3,050
+456,471
+-1,000
+333,334
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOO July 28, 2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 27,2001
+MARKE
+ALUE
+322,764
+28,800,000
+$29,122,764
+1,123,200
+3.9000
+$1,123,200
+7.5000
+0.1300
+••*••••••
+27.5200
+•.....
+2.5000
+44.9600
+14.9000
+6.0000
+MARKET
+VALUE
+1,875,000
+7,800
+11.008,000
+762,50
+20,522,936
+-1,490,000
+2,000,004
+$33,161,240
+$33,161,240
+$1,991,554
+$62,284,004
+027
+ANAL TAC
+INCOME
+138,000
+CURRENT
+YIELD (%)
+7.3600
+730.354
+3.5587
+$868,354
+$868,354
+09101/01:10:37 001
+
+
+5 or8
+Transaction Detail
+INVESTMENT ACTIVITY
+SATE EMENT TATE
+DATE
+08/01/01
+07/31/01
+08/03/01 07/31/01$ÖLD
+68763781 07731781"SOLB
+08/03/01
+08/02/01
+08/17/01
+"JOURNAL
+08/2001
+"JOURNAL"
+
+
+JOURNAL'
+08/21/0108/17701
+
+ö82201
+08/2001 SOLD*
+08/20/01
+OFFICE SERVICING YOUR ACOOUNT
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+CALL TOO INC
+SEP 025 CBOE
+EXP 09/22/2001
+00 ING
+NSOLICITE
+'188 IN''
+UNSOLICITED
+AS OF 07/31/01
+CALL TOO ING "SEP 025 CBE"
+EXP 09/22/2001
+UNSOLICITED
+"CALL VECTOR GROUP AUG 030 AMEX
+EXP DRASSIONED 00006
+AVE OTOCHE ASSIGNED 00561
+CALL VECTOR GROUP AUG22. 50AMEX
+EXP 08/18/2001
+ASSIGNED 00591
+"CALL VECTOR GROUP AUG OSAMEX
+EXP 08/18/2001
+ASSIGNED 00592
+VECTOR GROUP LT*
+SEE NOTE "S ON BACK
+AVE
+6 ASSIGNED
+100G
+ALE QTOOHE
+1000 ASSIGNED
+VECTOR GROUP LTD
+SEE NOTE IS: ON BACK
+34 ASSIGNED
+SYMBOL/CUSP
+OTOOLE
+T00
+'''700
+"OTOOIE"
+"VER
+*100
+"VGR
+027
+QUANTITY
+-50
+3,000
+497,000**
+-1,000*
+6
+1,000
+736
+34
+600
+- 100,000
+3,400
+1.00000
+- 24.90000*
+• 2325000"
+0.80000
+:30.00000
+' 25.00000
+3000000"
+09101/01:10:37 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOO July 28, 2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 27, 2001
+4,847.33
+74,517.51
+71,554,862.32
+76,994.83
+17,946.90
+2.497,414.16
+101,911.60
+
+
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SETTLEMENT TRADE
+DATE
+08/22/01
+08/20/01
+08/24101 08/23/01"S0LB"
+08/24701
+ö8/27/01
+0B/27/01
+08/22/01
+08/22/01
+MONEY FUND ACTIVITY
+DATE
+MODAY
+07/28/01
+0808/01
+08/13/01
+88/2481500**••*•
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+VECTOR GROUP LTD
+SEE NOTE'S ON BACK
+736 ASSIGNED
+"CALL TOO IN SEP 025CB8E"
+EXP 09/22/2001
+INSOLICITEL
+OPEN CONTRAC
+BOSTON PAOPEATES INC
+JAL FM I
+I PER INTXS
+"BOSTON PROPERTIES INC
+UNSOLICITED
+...................
+BOSTON PROPERTIES INC
+UNSOLICITED
+OPENINGBALANCE
+REHRASS ALGEMENTELA
+REYFUS CASH MANAGEMENT-CL
+STITUTIONAL SHARE
+SD BUY
+SELL
+SYMBOLCUSP
+VGR
+*EXP
+*BXP
+BXP
+QUANTITY
+-73,600
+2,000
+400,000
+250,000
+- 250,000
+22.50000
+••: 0000°
+* 40.33590
+40.52370
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOO July 28, 2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 27, 2001
+1,654, 102.30
+292,987.50
+10,068,638.86
+10,115,584.80
+$36,459,808.11
+CAEDIT AMOUNT
+SYMBOUCUSIP
+DICCX
+DICCX
+QUANTITY
+0.00
+11.000,000
+800,000
+1.0000
+1.0000*
+11,000,000.00
+800,000.00
+027
+09101/01:10:37 001
+
+
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MODAY
+08/24/01
+Ö8/28/01 BOUGHT
+88/30181*30LB*
+08/31/01
+DIVIDENDS
+RETYEHIONASS MANAGEMENT-CLA
+RETITONAS SHANAGEMENT-CLA"
+SELL
+CLOSINGBALANCE
+DATE
+07/30/01
+BOSTON PROPERTIES INC
+EC 06/29/01 PAY 07/30/01
+SYMBOUCUSIP
+BXP
+SYMBOUCUSIP
+DICCX
+QUANTITY
+90,413
+QUANTITY
+-2,000,000
+22,000,000
+
+28,800,000
+RATE (5)
+0.5800
+120
+1.0000
+1.0000
+1:000'
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOO July 28, 2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 27, 2001
+2,000,000.00
+''22,000,000.00***
+*2,000,000.00
+$-33,800,000.00
+$5,000.000.00
+CREDIT AMCUNT
+52,439.54
+$52,439.54
+09101/01;10:37 001
+
+
+8 ora
+Transaction Detail (continued)
+SUBSTITUTEPAYMENTS
+DATE
+07/30/01
+BOSTON PROPERTIES INC
+SEC STAN ON A 5738H0L
+INTEREST
+DATE
+08/21/01
+INTEREST ON CREDIT BALANCE
+AT 3 1/4% 07/21 THRU 08/20
+MISCELLANEOUS
+DATE
+MODAY
+08/24/01
+08/24/01
+JOURNAL'
+08/30/07
+"JOUANAL"
+08/3001OÜANAL
+08/31/01
+TO
+SAME
+SAME
+''JOURNAL FROM TYPE 2T0T"
+''JOUANAL HOM " WE 2181
+INL TO 353-01502ER LOA
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SYMBOUCUSIP
+BXP
+QUANTITY
+RATE (5)
+SYMBOUCUSIP
+QUANTITY
+RATE (%)
+3.2500
+DEBIT AMOUN
+1,900,000.00
+4,000,000.00
+...27,974,833.61
+2,000,000.00
+$-29,874,833.61
+21,974,833.61
+$21,974,833.61
+027
+09/01/01:10:37 001
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD July 28, 2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 27, 2001
+5,560.46
+-
+$5,560.46
+7,052.58
+$7,052.58
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+....
+Transaction Detail
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD June 30, 2001
+THROUGH
+July 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 29, 2001
+3
+4
+5
+C/O AMERICAN YACHT HARBOR *
+6100 RED HOOK SUITE B-3
+QUARTERS #2
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+47,180,507
+497,904
+$47.678.411
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+51,051,668
+-3,373,258
+There are no "Stop Loss' orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$497,904
+$280.529
+Cash & Equivalent
+Equities
+$48,385,947 : $-1,205,440
+$51,963,539 : S-1,192,400
+Current market value
+Last statement's market value
+Short market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as delivered to you.
+to Client Services at 800 634-1428; or Write to Cient Services at Bear, Steams Securities
+Corp.. One Metrolech Center North, Brooklyn, N.Y. 11201-3659.
+SP The suremen s four ratanal purger red de Set revere date for portant iformation.
+07/28/01;09:42 001
+
+
+2 of 6
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+07/28/01:09:42 001|
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+Dividends/Interest Charged
+Amount Debited
+Net Cash Activity
+Closing Balance,
+THIS PERIOD
+$280,529.40
+.. . .
+216,490.16
+953.56
+$217,443.72
+-69.46
+.....
+5-69.46
+.. .
+217,374.26
+$497.903.66
+CLOSING
+216,490.16
+281,413.50
+497,903.66
+......
+Income Summary
+THIS PERIOD
+Dividends
+0.00
+Substitute Payment
+0.00
+Credit Balance Int.
+953.56
+Total
+$953.56
+Foreign Tax Withheld
+0.00
+Margin Int. Paid
+-69.46
+Portfolio Composition
+SHORT
+Cash/Cash Equivalent
+Equities
+Total
+1,205,440
+$1,205,440
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+0.00
+280,529.40
+$280,529.40
+027
+YEAR TO DATE
+680,738.00
+69,158.80
+23,336.14
+773.232.9
+-150.00
+-48,493.06
+LONG
+497,904
+48,385,947
+48,883,851
+07/28/01:09:42 001
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD June 30, 2001
+THROUGH
+July 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 29, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+* 1%
+Short Equities-
+2%
+Equities
+97%
+Unshaded portions denote debe balance andor short
+
+
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+BOSTON PROPERTIES INC
+TELIGENT INC-CL A
+TOO ING
+CALL TOO ING
+"AUG 025CBOE
+EXP 08/18/2001
+VECTOR GROUP LTD
+CALL VECTOR GROUP AUG22.SOAMEX
+EXP 08/18/2001
+CALL VECTOR GROUP AUG 030 AMEX
+EXP 08/18/2001
+CALL VECTOR GROUP NOV 030 AMEX
+EXP 11/17/2001
+SENTIGEN HOLDING CP RSTD
+Total Equities& Options
+TOTAL EQUITIES
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SIMBOLCUSP
+QUANTITY
+SIMBOLCUSIP
+BXP
+CNH
+TGNTO
+TOO
+TOOHE
+VGR
+VGRH22
+VGRH30
+VGRK30
+-
+MRGN
+MAGN
+CASH
+CASH
+CASH
+MRGN
+MRGN
+MRGN
+CASH
+QUANTITY
+100,000
+...
+250,000
+60,000
+1,000,000
+1,000
+534,071
+-736
+-40
+1,000
+333,334
+39.2800
+7.1500
+0.2800
+23.6200
+0.4500
+32.0500
+......
+9.9000
+2.9500
+4.2000
+5.7500
+MARKET
+VALUE
+497,904
+$497,904
+MARIE
+3,928,000
+,787,501
+16,800
+23.620,000
+-45,000
+.17.116.976
+-728,640
+-11,800
+420,000
+1,916,671
+$47,180,507
+$47,180,507
+027
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD June 30, 2001
+THROUGH
+July 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 29, 2001
+ESTIMATE
+NNUAL INCON
+ANNUAL MONE
+232,000
+138,000
+CURRENT
+YIELD IN
+5.9063
+7.7203
+854,514
+4.9922
+$1.224,514
+$1,224,514
+07/28/01;09:42 001
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York. New York 10167
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT TRADE
+07/03/01 07/02/01
+CALL TOO ING AUG 025 CBOE
+EXP 08/18/2001
+JNSOLICITEC
+OPEN CONTRACT
+07713/01GUANAL
+07/13/01"JOURNAL"
+JOURNAL FROM TYPE 1 TO 2
+$1,224,514
+$47,678,410
+SYMBOLCUSP
+OTOOHE
+QUANTITY
+- 1,000
+102,000*
+102,000
+2.20000
+027
+07/28/01;09:42 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD June 30, 2001
+THROUGH
+July 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 29, 2001
+216,490.16
+$216,490.16
+
+
+6 of 8
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Transaction Detail (continued)
+INTEREST
+DATE
+07/23/01
+FROM 06/21 THRU 06/26 @43/4%
+BAL 66,901- AVAL 87,736
+07/23/01 ' INTEREST ON CREDIT BALANCE"
+AT 3 1/2% 06/21 THRU 06/26
+07/2301
+INTEREST ON CREDIT BALANCE
+AT 3 1/4% 06/27 THRU 07/20
+SYMBOL/CUSIP
+STOP
+****** End of Statement******
+QUANTITY
+RATE (%)
+4.7500
+• 3.5000
+3.2500
+027
+69.46
+$-69.46
+07/28/01:09:42 001
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOO June 30, 2001
+THROUGH
+July 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 29,2001
+- 32.52
+921.04
+$953.56
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Your Messages
+.......
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 25, 2001
+3
+7
+C/O AMERICAN YACHT HARBOR *
+6100 RED HOOK SUITE B-3
+QUARTERS #2
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+....
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+50,771,139
+280,529
+551,051,668
+38,154,227
+12,897,442
+here are no Stop Loss" orders or other pending bu
+r sell open orders on file for your account
+Market Value of Your Portfolio
+$280,529
+$313,146
+Cash & Equivalent
+Equities
+$51,963,539 : S-1,192,400
+$39,241,081 : $-1,400,000
+Current market value
+Last statement's market value
+Short market value
+Important Message
+Please note: You may find
+more than one statement
+in this envelope. Beginning
+this month, all statements
+with the same Address and
+Social Security number /
+Taxpayer Identification
+number are being mailed in
+one envelope. For further
+details, please contact your
+account executive.
+Flease raport any dierence or non-receipt of chacks or stocks, indicated as delivered to you.
+to Client Services at 800-634-1428; or Write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3659.
+SP The suremen s four ratanal purpose rear de Set revere ase for portant iformation.
+06/30/01;23:28 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+06/30/01:23:28 001|
+
+
+Cash Flow Analysis
+THIS PERICO
+Opening Balance
+$313,145.78
+....
+Securities Sold
+1,159,796.20
+Dividends/Interest
+214,941.22
+Amount Credited
+51.374,737.42
+•........
+Securities Bought
+-1,405,181.30
+Dividends/Interest Charged
+-1,998.50
+Miscellaneous
+-174.00
+Amount Debited
+$-1,407,353.80
+Net Cash Activity
+-32,616.38
+Closing Balance.
+_ 6280.529.40
+Same day transfers of cash between acount types are not included in this
+section; such transfers, as well as details for all other transactions this period,
+appear in Transaction Detal.
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Income Summary
+Dividends
+Substitute Payment
+Credit Balance Int.
+Total
+Foreign Tax Withheld
+Margin Int. Paid
+THIS PERIOD
+214,628.40
+0.00
+312.82
+... .
+5214.941.22
+-150.00
+-1,998.50
+Portfolio Composition
+SHORT
+Cash/Cash Equivalent
+Equities
+1,192,400
+Total
+$1,192,400
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+313,145.78
+$313,145.78
+CLOSING
+280,529.40
+......
+$280,529.40
+......
+120
+YEAR TO DATE
+680,738.00
+69,158.80
+22,382.58
+$772.279.38
+-150.00
+-48,423.60
+LONG
+280,529
+51,963,539
+$52,244,068
+06/30/01:23:28 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 25,2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+* 1%
+Short Equities-
+2%
+Equities
+97%
+Unshaded portions denole debt balance andor short
+market values. The alocation percentage is derived
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+BOSTON PROPERTIES INC
+CNH GLOBAL LI
+ONH GLOBAL
+TELIGENT INC-CLA
+TOO INC
+VECTOR GROUP LTD
+CALL VECTOR GROUP AUG22. SOAMEX
+EXP 08/18/2001
+........
+CALL VECTOR GROUP AUG 030 AME
+EXP 08/18/2001
+.....
+CALL VECTOR GROUP NOV030 AMEX
+XP 11/17/200
+... . .
+SENTIGEN HOLDING CP RSTD
+Total Equities& Options
+TOTAL EQUITIES
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SIMBOLCUSP
+QUANTITY
+SIMBOLCUSIP
+BXP
+CNH
+CNH
+TGNTQ
+TOO
+VGR
+VGRH22
+VGRH30
+VGRK30
+-
+MRGN
+CASH
+MRGN
+CASH
+CASH
+MAGN
+MRGN
+MRGN
+MAGN
+CASH
+QUANTITY
+100,000
+02,000
+48,000
+60,000
+100,00
+34,07
+-736
+-40
+1,000
+333,334
+40.9000
+5.9300
+5.9300
+0.1800
+27.4000
+31.9500
+9.5000
+3.3000
+4.3000
+5.7500
+280,529
+$280,529
+MARKET
+VALUE
+4,090,000
+304,860
+877,640
+10,800
+27,400,000
+17,063,568
+-699,200
+-13,200
+480,000
+1,916,671
+$50,771,139
+$50,771,139
+027
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 25,2001
+ESTIMATE
+NNUAL INCON
+ANNUAL MONE
+232,000
+56,304
+81,696
+854,514
+CURRENT
+YIELD IN
+5.6724
+9.3086
+9.3086
+5.0078
+...........
+$1,224,514
+$1,224,514
+06/30101:23:28 001
+
+
+5 ol7
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SEEN TAE
+05/29/01
+05/23/01
+05/2901
+05723/01
+'''*BOUGHT"
+05/30101
+
+
+05/24701
+05/25/01
+*06/64/01"
+"SOLE
+CNH GLOBAL L
+UNSOLICITED
+ENGLOBAL W
+UNSOLICITED
+AS OF 05/23/01
+"ENH GLOBAL' •
+UNSOLICITED
+CNH GLOBAL W:
+UNSOLICITED
+CAL VECTOR "CAOUP NOVOSOAMEX"
+EXP 11/17/2001
+UNSOLICITED
+OPEN CONTRACT
+$1,224,514
+$51,051,668
+SYMBOLCUSIP
+CNH
+*ENH
+QUANTITY
+3,000
+3,000*
+102,000
+48,000
+1,800*
+6.42000
+6.47530
+
+6.68390
+027
+06/30101:23:28 001
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 25, 2001
+19,442.50
+19.605.90
+688920.70"
+323,709.70
+566,478.50
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+6 of 7
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SETTLEMENT TRADE
+DATE
+06/05/01
+06/04/01
+ö6/1/01
+08/12/01**
+JOÜRNAL"
+"JOURNAL"
+ö6/20/01
+06/22/01
+06/20/01
+06/25/01
+DIVIDENDS
+DATE
+05/31/01
+REC 0S1701 PAY 05/31101
+GENCY FEE ,0024 PEF
+FOREIGN TAX WITHHELI
+06/29/01
+TEC 0220 PA 0 2301
+CALL VECTOR GROUP JUN 030 AMEX
+EXP 06/16/2001
+CLOSING CONTRACT
+POSTON OPATES ING
+BOSTON PROPEATES INC
+TO
+SAME
+"CALL VECTOR GROUP AUG22. 50AMEX
+EXP 08/18/2001
+ASSIGNED 00001
+VECTOR GROUP LT.........
+SEE NOTES: ON BOK,
+264 ASSIGNED
+TOO INC
+FROM 047-30185
+PER LOA
+SVMBOUCUSIP
+CNH
+VER
+SYMBOLCUSIP
+92240M9F7
+BXP
+VGR
+TOO
+QUANTITY
+10,000
+WH
+534,071
+RATE (S)
+0.1000
+0.4000
+027
+3.50000
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 25, 2001
+353,502.50
+QUANTITY
+1,000
+200,000
+200,000"
+264
+26,400
+1,000,000
+22.50000"
+593,317.76
+100.00
+$-100.00
+06/30101:23:28 001
+$-1,405,181.30
+REDIT AMOUNT
+1,000.00
+213,628.40
+$214,628.40
+$1,159,796.20
+
+
+Transaction Detail (continued)
+INTEREST
+DATE
+06/21/01
+FROM 05/21 THRU 06/20 @43/4%
+BAL 524,731
+AVBAL 488,597
+062101 TE OUR DANCE
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SYMBOL/CUSIP
+MISCELLANEOUS
+DATE
+MO/DAY
+05/30/01
+65/30/01
+05/31/01
+0601/01
+JOURNAL"
+JOURNAL"
+JOURNAL FROM TYPE 2 TO 1
+JOURNAL FROM TYPE 2101
+ENH GLOBAL
+AGENCY PROCESSING FEE
+Your messages
+QUANTITY
+RATE (%)
+4.7500
+3.5000
+688,920.70
+24.00
+50.00
+$-688,994.70
+027
+1,998.50
+$-1,998.50
+CRECIT AMOUNT
+688,920.70
+$688,920.70
+06/30/01:23:28 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 25, 2001
+312.82
+$312.82
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+Trades Not Yet Settled
+........
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD April 28, 2001
+THROUGH
+May 25, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 27,2001
+3
+7
+C/O AMERICAN YACHT HARBOR *
+6100 RED HOOK SUITE B-3
+QUARTERS #2
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+37,841,081
+NET CREDIT BALANCE
+313,146
+NET EQUITY THIS PERIOD
+$38,154,227
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+38,312,367
+-158,140
+"This portfolio indudes one or more unpriced securtles that are not
+relected in the Total Value of Securites and the Net Equity This Period
+Market Value of Your Portfolio
+$313,146
+$-3,396,898
+Cash & Equivalent -
+Equities -
+$39,241,081 : $-1,400,000
+$44,655,685 : S-2,946,420
+Current market value
+Last statement's market value
+Short market value
+Important Message
+In an effort to deliver
+statements to you more
+efficiently, Bear Steams
+has enhanced the
+distribution of statements
+to household accounts.
+Bimings win the same
+Address and Social Security
+number/ Taxpayer
+identification number will
+be mailed in a single
+envelope. For further
+details, please contact your
+account executive.
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The surren s four or ratanal purposes rebr die Set revere date for portant iformation.
+05/26/01;10:08 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+05/26/01:10:08 001|
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+Securities Bought
+Dividends/Interest Charged
+THIS PERICO
+3,396,898.2
+... .
+4,065,351.64
+265,000.00
+S4.330,351.64
+•........
+-610,844.82
+-9,462.84
+Amount Debited.
+........20.307.66
+Net Cash Activity
+3,710,043.98
+Closing Balance,
+8313-4.76
+me day tansfers of cash between account types are not included in t
+etion; such transfers, as well as details for all other transactions this peri
+appear in Transaction Detail.
+Income Summary
+Dividends
+Substitute Payment
+Credit Balance Int.
+Total
+Margin Int. Paid
+THIS PERIOD
+265,000.00
+0.00
+0.00
+$265.000.00
+-9,462.84
+Portfolio Composition
+SHORT
+Cash/Cash Equivalent
+Equities
+Total
+1,400,000
+$1,400,000
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+-3,396,898.20
+$-3,396,898.20
+CLOSING
+313,145.78
+$313,145.78
+027
+YEAR TO DATE
+466,109.60
+69,158.80
+22,069.76
+$557.338.16
+-46,425.10
+LONG
+313,146
+39,241,081
+$39,554,227
+05/26/01;10:08 001
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD April 28, 2001
+THROUGH
+May 25, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 27, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+* 1%
+Short Equities-
+3%
+Equities
+96%
+Unshaded portions denote debit balance and'or short
+from the absolute market value of your portlolo.
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+BOSTON PROPERTIES INC
+CNH GLOBAL WI
+TELIGENT INC-CLA
+VECTOR GROUP LTD
+CALL VECTOR GROUP JUN 030 AMEX
+SYMBOLCUSIP
+BXP
+CNH
+TGNGE
+VGR
+VGRF30
+CALL VECTOR GROUP AUG22. 50AMEX
+VGRH22
+EXP 08/18/200
+CALL VECTOR GROUP AUG 030 AMEX
+VGRH30
+EXP 08/18/2001
+SENTIGEN HOLDING CP RSTD
+-
+Total Equities& Options
+TOTAL EQUITIES
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SIMBOLCUSP
+QUANTITY
+MRGN
+MRGN
+CASH
+VIRGN
+ARGN
+MRGN
+CASH
+QUANTITY
+500,000
+...
+94,000
+60,000
+560,471
+1,000
+- 1,000
+-40
+333,334
+MARKET
+VALUE
+313,146
+$313,146
+40.4200
+6.8900
+0.5600
+32.7400
+700
+10.1000
+5.0000
+Unpriced
+MARKET
+VALUE
+20,210,000
+647,660
+33,600
+18,349,821
+370,00
+-1,010,000
+20,000
+$37,841,081
+$37,841,081
+$2.108.642
+$38,154,226
+027
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD April 28, 2001
+THROUGH
+May 25, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 27,2001
+ESTIMATE
+NNUAL INCON
+STIMATE
+NNUAL INCOM
+1,160,000
+51,888
+896,754
+CURRENT
+YIELD IN
+5.7397
+8.0116
+4.8870
+$2,108,642
+$2,108,642
+05/26/01:10:08 001
+
+
+5 or7
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT TRADE
+DATE
+04/30/01
+04/25/01
+04730781 "84/25701'SOLB"
+050170104726/01
+05/01/01
+04/27/01
+05/10/01
+ö5/11/01
+05/08/01
+05/14/01
+05/1701
+RECEIVED
+"SOLD
+05/1401
+05/11701
+"SOLD
+05715/01
+05/15/0104/2701
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+CHILDRENS PLACE RETAIL STORES
+UNSOLICITED
+"CHILDRENS PLACE RETAIL'STORES
+INSOLICITED
+AVG PRICE: DETAILS ON REQUES
+CHILDRENS PLACE RETAIL STORES
+AND PAGE DENIS ON PROSTY
+5 ASSIGNED
+"SENTIGEN HOLDING CP RSTD"
+UNSOLICITED
+CALL VECTOR GROUP AUG OSAMEX"
+EXP 08/18/2001
+OPEN CONTRAC
+S OF 05/11/01
+"CALL VECTOR GROUP JUN 030 AMEX
+EXP 06/16/2001
+UNSOLICITED
+CLOSING CONTRACT
+VECTOR GROUP LTD"
+SEE NOTE E'S ON BACK
+AO SID 05101/01 5 ASSIGNED
+AS OF 04/27/01
+TO CXL PREVIOUS SELL
+"VECTOR GROUP LTD****
+SEE NOTE 'S' ON BACK
+ORIGINAL SID OSIO AS
+5 ASSIGNED
+AS OF 04/27/01
+SYMBOLCUSP
+PLCE
+PLCE
+VGR
+CNH
+"NGR
+027
+QUANTITY
+-10,000
+22,700
+27,300
+500*
+333,
+10,000
+40%
+- 1,000
+500°
+22.68000
+• 2267120
+'22.65730
+20.00000
+5.80000
+* 4:40000
+3.08600
+'220000
+20.00000
+05/26/01:10:08 001
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD April 28, 2001
+THROUGH
+May 25, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+April 27,2001
+226,189.94
+*511 895.73
+616,883.17
+9,947.16
+58,602.50
+17,456.91
+305,087.21
+9,947:16
+*9,984.66
+
+
+6 of 7
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+DATE
+05/16/01
+04/27101
+CANCEL SELL
+OFFICE SERVICING YOUR ACOOUNT
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+05/16/01 04/27701 SOLD
+ö5/16/01
+
+05/21/01
+05/23/01
+05/21/01
+05125/01
+05/22/01 BOUGHT
+DIVIDENDS
+DATE
+04/30/01
+BOSTON PROPERTIES INC
+REC 03/30/01 PAY 04/30/01
+VECTOR GROUP LTD
+SEE NOTE "S' ON BACK
+ORIGINAL SID 05/01/01
+A/O S/D 05/15/01
+AS OF 04/27/01
+TO CXL PREVIOUS SELL
+VECTOR GROUP LTD
+SEE NOTE 'S: ON BACK
+5 ASSIGNED
+ORIGINAL SID 05/01/01
+AS OF 04/27/01
+"VECTOR GROUP LTD
+UNSOLICITED
+SEE NOTE "S" ON BACK
+CALL VECTOR GROUP MAY OZOAMEX
+EXP 05/19/2001
+_ ASSIGNED 01607
+VECTOR GROUP LTD
+SEE NOTE 'S' ON BACK
+AVE
+1086 ASSIGNED
+CONSOLE
+SYMBOUGUSIP
+BXP
+SYMBOLGUSIP
+VGR
+VGR
+VGR
+QUANTITY
+500,000
+RATE (5)
+0.5300
+027
+QUANTITY
+500
+20.00000
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD April 28, 2001
+THROUGH
+May 25, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 27, 2001
+9,984.66
+-500
+-6,100
+1,086
+108,600
+84,000
+20.00000
+'31000410
+20.00000
+6.27700
+532,310.50
+$-610,844.82
+9,947.16
+188,750.20
+2,169,210.10
+$4,065.351.64
+265,000.00
+$265,000.00
+05/26/01:10:08 001
+
+
+Transaction Detail (continued)
+INTEREST
+DATE
+05/21/01
+FROM 05/15 THRU 05/20 @43/4%
+BAL 1314,290 AVAL 1345,743
+0521/01 FROM 04/21 THRU 05/14 @51/4%
+BAL 1768,041 AVBAL 2399,273
+MISCELLANEOUS
+DATE
+MO/DAY
+05/16/01
+05/16/01
+JOURNAL FROM TYPE 1702
+JOURNAL FROM TYPE 1T02
+Trades Executed Pending Settlement
+BATEMENT TREE
+05/29/01
+05/23/01
+5/29/0-
+05/30/01
+05/23/01
+05/24101
+
+05/25/01
+*BOUGHT
+OUGH
+DESCAIPTION
+CNH GLOBAL L
+The above trades do not appear in any other section of this statemere
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SYMBOL/CUSIP
+QUANTITY
+RATE (%)
+4.7500
+5.2500
+265,000.00
+$-265,000.00
+SIMBOLCUSP
+CNH
+CNH
+CNH
+CNH
+027
+CLEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD April 28, 2001
+THROUGH
+May 25, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 27, 2001
+1,065.38
+397.4
+$-9,462.84
+CRECIT AMOUNT
+265,000.00
+$265,000.00
+QUANTITY
+3,000.00
+3,000.00
+02,000.00
+48.000.00
+6.4200
+6.4753
+5.6941
+1683
+0526/01:10:08001
+19,442.50
+19,605.90
+688,920.70
+23,709.7
+$1,051,678.80
+$0.00
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Trades Not Yet Settled
+......
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD March 31, 2001
+THROUGH
+April 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 30, 2001
+3
+4
+6
+C/O AMERICAN YACHT HARBOR *
+6100 RED HOOK SUITE B-3
+QUARTERS #2
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET DEBIT BALANCE
+NET EQUITY THIS PERIOD
+...
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+41,709,265
+-3,396,898
+38.312.36
+31,254,039
+7,058,328
+here are no Stop Loss" orders or other pending bu
+r sell open orders on file for your account
+Market Value of Your Portfolio
+$-3,396,898
+$-3,283,402
+Cash & Equivalent
+Equities -
+$44,655,685 : S-2,946,420
+$34,889,731 : S-352,290
+Current market value
+Last statement's market value
+Short market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3659.
+SP The suremen is four or ratanal purpose rear de Set revere dae for portant iformation.
+
+
+2 of 6
+027
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Amount Credited
+Securities Bought
+Dividends/Interest Charged
+Amount Debited
+Net Cash Activity
+Closing Balance,
+THIS PERICO
+$-3,283,401.83
+....
+316,486.83
+$316,486.83
+-413,502.50
+-16,480.70
+S.429.083.20
+.........
+- 113,496.37
+3.396,898.20
+Income Summary
+Dividends
+Substitute Payment
+Credit Balance Int.
+Total
+Margin Int. Paid
+THIS PERIOD
+0.00
+0.00
+0.00
+50.00
+-16,480.70
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+SHORT
+3,396,898
+2,946,420
+$6.343.318
+Cash Balance Summary
+Margin
+.....
+Net Cash Balance
+OPENING
+-3,283,401.83
+$-3,283,401.83
+CLOSING
+-3,396,898.20
+$-3,396,898.20
+YEAR TO DATE
+201,109.60
+69,158.80
+22,069.76
+6292.338.16
+-36,962.26
+LONG
+44,655,685
+$44,655,685
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD March 31, 2001
+THROUGH
+April 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 30,2001
+Your Portfolio
+Allocation
+Short Cash & Equivalent-
+6%
+Short Equities
+5%
+Equities
+89%
+Unshaded portions denote debit balance and or shart
+
+
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+BOSTON PROPERTIES INC
+SYMBOLCUSIP
+BXP
+HILDRENS PLACE RETAIL STORE
+INC
+TELIGENT INC-CLA
+VECTOR GROUP LTD
+ALL VECTOR GROUP MAY 020 AME
+TGNT
+VGR
+VGRE20
+XP 05/19/200
+ELECTO GROUP AUG2S0AMEX VGRH22
+Total Equities& Options
+TOTAL EQUITIES
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SIMBOLCUSP
+QUANTITY
+MRGN
+MAGN
+CASH
+MAGN
+MAGN
+MAGN
+QUANTITY
+500,000
+30,000
+60,000
+675,671
+1,086
+-1,000
+MARKET
+VALUE
+-3,396,898
+$-3,396,898
+39.1800
+23.1500
+0.4700
+35.0000
+14.7000
+13.5000
+MARKET
+VALUE
+19,590,000
+1,389,000
+28,200
+23,648,485
+-1,596,420
+-1,350,000
+$41,709,265
+$41,709,265
+$2,141.074
+$38.312,366
+ESTIMATE
+INNUAL INCOM
+ESTIMATE
+INUAL INCON
+1,060,000
+1.081,074
+$2,141,074
+$2,141,074
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD March 31, 2001
+THROUGH
+April 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 30,2001
+CURREN
+YELD IN
+5.4109
+4.5714
+1LPA
+
+
+5 or 8
+Transaction Detail
+INVESTMENT ACTIVITY
+SEEMENT T
+04/11/01
+04/11701
+ANSACTN
+URNA
+"JÖURNAL"
+04/11701
+64/11701
+JOUANAL'
+84/17701 04/16/01"SOLD
+04/1701
+**04/16/01"BÖUGHT"
+0427/01
+INTEREST
+DATE
+DESCHIPTION
+04/23/01
+-ROM 04/18 THRU 04/20 @5 1/49
+AL 3380,417 AVAL 3380,41
+04/2301
+FROM 03/21 THRU 04/17 @5344%
+BAL 3380,417 AVAL 3354,433
+OFFICE SERVICING YOUR ACOOUNT
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+BOSTON PROPERTIES INC
+JOURNAL FROM TYPE 1 TO 2
+"CHILDRENS PLACE RETAIL'STORES
+JOURNAL FROM TYPE 1 TO 2
+BOSTON PROPERTES INC
+JOURNAL FROM TYPE 1 TO 2
+"CHILBRENS PLACE RETAIL" STORES"
+JOURNAL FROM TYPE 1 TO 2
+"CALL VECTOA" GROUP AUG22 5ÖAMEX"
+EXP 08/18/2001
+UNSOLICITED
+OPEN CONTRACT
+CALL VECTOR GROUP APR 020AMEX"
+EXP 04/21/2001
+UNSOLICITED
+CLOSING CONTRACT
+SYMBOUGUSIP
+SYMBOLGUSIP
+BXP
+"PLCE
+*EXP
+"PILCE
+QUANTITY
+RATE (5)
+5.2500
+5.7500
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD March 31, 2001
+THROUGH
+April 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 30, 2001
+QUANTITY
+-500,000
+60,000
+500,000
+60,000
+:1,000
+1,000
+5
+1,478.93
+5,001.7
+$-16,480.70
+027
+
+4.10000
+**316,486.83
+413,502.50
+$-413,502.50
+$316,486.83
+
+
+6 of 8
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Trades Executed Pending Settlement
+SEE MENT TREE
+04/30/01
+04/25/01
+04/30101
+04/25/01
+05101/01
+04/26/01
+05/01/01
+04/27/01 SOLD
+CHILDRENS PLACE RETAIL STORES
+CHILDRENS PLACE RETAIL STORES
+.........••••
+CHILDRENS PLACE RETAIL STORES
+VECTOR GROUP LTD
+The above trades do not appear in arry other section of this statement.
+STOP
+****** End of Statement******
+SYMBOLCUSP
+PLCE
+PLCE
+3071
+VGR
+QUANTITY
+-10,000.00
+-22,700.00
+-27,300.00
+-500.00
+22.6800
+22.6112
+22.6573
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD March 31, 2001
+THROUGH
+April 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 30, 2001
+226,189.94
+511,895.13
+616,883.17
+$0.00
+9.947.16
+$1,364,915.40
+027
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+Your Messages
+.......
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD February 24,2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 660-56-7418
+February 23,2001
+3
+7
+C/O AMERICAN YACHT HARBOR *
+6100 RED HOOK SUITE B-3
+QUARTERS #2
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET DEBIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+34,537,441
+-3,283,402
+$31,254,039
+31,778,424
+-524,385
+Cash & Equivalent
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Equities -
+Market Value of Your Portfolio
+$-3,283,402
+$-4,270,779
+$34,889,731 : $-352,290
+$36,644,933 : S-595,730
+Current market value
+Last statement's market value
+Short market value
+Important Notice
+Decimal Trading is Here for
+Nasdaq! (
+Decimal Trading is the shift
+from fractional pricing
+(e.g. 21 1/2) to decimal
+pricing (e.g.$21.50)for
+equities and options.
+Nasdaq securities have
+been phased in during March
+and the remaining securities
+Do chis unt to be rading in.
+For details, visit our website at
+www.bearsteamns.
+com.
+Flease raport any dierence or non-receipt of chacks or stocks, indicated as delivered to you.
+to Client Services at 800 6341428; or Write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3659.
+SP The surren s four or ratanal purposes rearde Set revere date for portant iformation.
+
+
+027
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+
+
+Cash Flow Analysis
+THIS PERICO
+Opening Balance
+$-4,270,779.33
+......
+Securities Sold
+800,593.16
+Dividends/Interest
+201,109.60
+Miscellaneous
+1,069,158.80
+Amount Credited
+$2,070,861.56
+Securities Bought
+-63,002.50
+Dividends/Interest Charged
+-20,481.56
+Miscellaneous
+-1,000,000.00
+Amount Debited
+5-1.083-484.06
+Net Cash Activity
+987,377.50
+losing Balanc
+... $3.283.401.83
+Same day tansfers of cash between account types are not included in this
+rection; such transfers, as well as details for all other transactions this period
+appear in Transaction Detail.
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Income Summary
+Dividends
+Substitute Payment
+Credit Balance Int.
+Total
+Margin Int. Paid
+THIS PERIOD
+201,109.60
+69,158.80
+0.00
+$270,268.40
+-20,481.56
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+SHORT
+3,283,402
+352,290
+$3.635,692
+Cash Balance Summary
+Margin
+Not Cash Balance
+OPENING
+-4,270,779.33
+CLOSING
+-3,283,401.83
+$-4,270,779.33
+$-3,283,401.83
+..............
+YEAR TO DATE
+201,109.60
+69,158.80
+22,069.76
+$292.338.16
+-20,481.56
+LONG
+34,889,731
+...
+$34,889.731
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD February 24, 2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 660-56-7418
+February 23,2001
+Your Portfolio
+Allocation
+Short Cash & Equivalent-
+Short Equities-
+<1%
+Equities
+91%
+Unshaded portions denote debit balance and or shart
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+BOSTON PROPERTIES INC
+HILDRENS PLACE RETAIL STORE
+INC
+TELIGENT INC-CLA
+VECTOR GROUP LTD
+ALL VECTOR GROUP APR 020 AME
+*P 04421/200
+4LL VECTOR GROUP MAY 020 AME
+P 05/19/200
+Total Equities& Options
+TOTAL EQUITIES
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SIMBOLCUSP
+QUANTITY
+SYMBOLCUSIP
+BXP
+TGNT
+VGR
+VGRD20
+VGRE2O
+CASH
+CASH
+CASH
+MAGN
+MAGN
+MAGN
+QUANTITY
+500,000
+30,000
+60,000
+675,671
+1,000
+-1,091
+MARKET
+VALUE
+-3,283,402
+$-3,283,402
+38.4500
+4.000
+0.5940
+21.0000
+1.4500
+1.9000
+MARKET
+VALUE
+19,225,000
+440,00
+35,640
+14,189,091
+-145,000
+-207,290
+$34,537,441
+$34,537,441
+$2,141,074
+$31,254,039
+ESTIMATE
+NNUAL INCON
+ANNA MONE
+1,060,000
+1.081,074
+$2,141,074
+$2,141,074
+027
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD February 24,2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 660-56-7418
+February 23,2001
+CURREN
+YELD IN
+5.5137
+76191
+
+
+5 of 7
+Transaction Detail
+INVESTMENT ACTIVITY
+SATE EMENT TATE
+DATE
+03/14/01
+03/13/01
+03/14/01*03/13/01BÖÜGHT
+03/19/01
+3/21/0
+03/19/01
+DIVIDENDS
+DATE
+03/28/01
+VECTOR GROUP LTD
+REC 03/21/01 PAY 03/28/01
+SUBSTITUTEPAYMENTS
+DATE
+03/28/01
+VECTOR GROUP LTD
+OFFICE SERVICING YOUR ACOOUNT
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+CALL VECTOR GROUP APR 020 AMEX
+EXP 04/21/2001
+OPEN CONFRACT
+CALL"VECTOR GROUP MAR 020AMEX
+EXP 03/17/2001
+UNSOLICITED
+CLOSING CONTRACT
+CALL VECTOR GROUP MAR 020AMEX*
+EXP 03/17/2001
+AVE
+| ASSIGNED 00274
+.. . .
+VECTOR GROUP LTD
+AVE
+350 ASSIGNED
+SYMBOUGUSIP
+VGR
+SYMBOUCUSIP
+VGR
+SYMBOLGUSF
+VGR
+QUANTITY
+502,774
+RATE (5)
+0.4000
+QUANTITY
+RATE (S)
+1.05000
+= 0.60000
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD February 24,2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+660-56-7418
+February 23, 2001
+101,494.00
+63,002.50
+QUANTITY
+-1,000
+1,000
+350
+-35,000
+20.00000
+699,099.16
+$800,593.16
+027
+$-63,002.50
+201,109.60
+$201,109.60
+69,158.80
+$69,158.80
+03/31/01;17:01 001
+
+
+6 of 7
+Transaction Detail (continued)
+INTEREST
+DATE
+03/21/01
+FROM 03/20 THRU 03/20 @53/4%
+BAL 4232,287 AVBAL 4232,287
+032101 FROM 02/21 THRU 03/19 ©61/4%
+BAL 4232,287 AVBAL 4225,188
+MISCELLANEOUS
+DATE
+MO/DAY
+03/12/01
+63/2/01
+03/12/01
+
+OURNAL
+ÖUANAL"
+ESCRIPTIO
+OURNAL FROM TYPE 1 TO
+JOURNAL FROM TYPE 1TO2"
+OURNAL
+PER LOA
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SYMBOL/CUSIP
+QUANTITY
+RATE (%)
+5.7500
+6.2500
+1,000,000.00
+1.000,000.00
+$-2,000,000.00
+675.99
+9,805.5
+$-20,481.56
+CRECIT AMOUNT
+000,000.00
+1,000,000.00
+$2.000.000.00
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD February 24, 2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 660-56-7418
+February 23,2001
+
+
+ear, Stears & Co. In
+45 Park Avenue
+New York, New York 10167
+Your messages
+Bear, Stearns Securities Corp, Net Capital and
+Net Capital Requirements:
+At November 30, 2000 and January 26, 2001, the
+Company's net capital of $2,620,960,000 and
+$2,202,436,000, all respectively.
+A complete copy of the Bear, Stearns Securities
+Corp, Statement of Financial Condition is available
+on the web site www.bearstearns.com, Alternatively,
+to request a free printed copy please call -
+toll free 1-866-299-9331,
+STOP
+****** End of Statement******
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD February 24,2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 660-56-7418
+February 23,2001
+027
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Your Messages
+.........
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+660-56-7418
+January 26, 2001
+3
+4
+8
+C/O AMERICAN YACHT HARBOR *
+6100 RED HOOK SUITE B-3
+QUARTERS #2
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET DEBIT BALANCE
+36,049,203
+-4,270,779
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+$31,778,424
+15,059,764
+16,718,660
+Cash & Equivalent
+Equities -
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$-4,270,779
+$160,421
+$36.644,933 : S-595,730
+$15,016,583 : $-117,240
+Current market value
+Last statement's market value
+Short market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal purpose rear de Set revere dae for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+
+
+Cash Flow Analysis
+THIS PERIOD
+Opening Balance
+$160.421.16
+Securities Sold
+1,195,456.89
+Funds Deposited
+14,504,392.82
+Dividends/Interest
+14,792.30
+Amount Credited
+515.714.64201
+Securities Bought
+-195,842.50
+Funds Withdrawn
+-19,950,000.00
+Amount Debited
+5 20.145842.50
+Net Cash Activity
+-4,431,200.49
+losing Balance
+..............
+__ 54270,779,.33
+Same day ransfers of cash between account types are not included in this
+section; such transfers, as well as details for all other transactions this period,
+appear in Transaction Detall.
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+160,421.16
+0.00
+$160,421.16
+Income Summary
+Credit Balance Int.
+Total
+THIS PERIOD
+14,792.30
+$14,792.30
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+SHORT
+4,270,779
+595,730
+$4,866,509
+CLOSING
+0.00
+4,270,779.33
+....
+$-4.270,779.33
+YEAR TO DATE
+22,069.76
+22,069.7
+LONG
+36,644,933
+36,644,93
+027
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+660-56-7418
+January 26, 2001
+Your Portfolio
+Allocation
+Shoot Cash & Equivalent.-
+Short Equities-
+1%
+Equities
+89%
+Unshaded portions denote debit balance andor shart
+from the absolute market value of your portfolio.
+
+
+4 of a
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+BOSTON PROPERTIES INC
+CHILDRENS PLACE RETAIL STORES
+INC
+....
+TELIGENT ING-CLA
+......
+VECTOR GROUP LTD
+CALL VECTOR GROUP MAR 020AMEX
+EXP 03/17/2001
+ALL VECTOR GROUP MAY 020 AME›
+EXP 05/19/2001
+Total Equities& Options
+TOTAL EQUITIES
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SIMBOLCUSP
+QUANTITY
+SIMBCLCUSIP
+BXP
+PLCE
+TGNT
+VGR
+VGRC20
+VGRE2O
+CASH
+CASH
+CASH
+MAGN
+MRGN
+MRGN
+QUANTITY
+500,000
+60,000
+60,000
+710,671
+-1,350
+-1,091
+MARKET
+VALUE
+-4,270,779
+$4,270,779
+40.2000
+21.1250
+1.6250
+21.3600
+2.1500
+2.8000
+MARKET
+VALUE
+20,100,000
+1,267,500
+97,500
+15,179,933
+- 290,250
+-305,480
+$36,049,203
+$36,049,203
+$2,197,074
+$31,778,423
+ESTIMATE
+NNUAL INCON
+1,060,000
+1,137,074
+$2,197,074
+$2,197,074
+CURRENT
+YIELD IN
+5.2736
+7.4906
+027
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 660-56-7418
+January 26,2001
+
+
+5 or8
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT TRADE
+DATE
+01/29/01
+01/26/01
+01/29701
+"RECEIVED"
+ö1730701 01725/01
+01730/01
+
+01/29/01
+01/26/01
+"SOLD
+*SOLD
+
+ö2/07/01
+01729/01
+RECEIVED
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+CALL VECTOR GROUP MAR 020AMEX
+EXP 03/17/2001
+USIP NUMBER TO FOLLOW
+NSOLICITEI
+OPEN CONTRACT
+ASIA GLOBAL CAOSSING LTS"
+CLA
+0015
+ASIA GLOBAL CROSSING LTD
+CLA
+INSOLICITEI
+NG PACE DETAILS ON RECUTE
+UNIT PRICE
+0.060000
+CALL VECTOR GROUP MAR 020AMEX
+EXP 03/17/2001
+UNSOLICITED
+OPEN CONTRACT
+ASIA GLOBAL CROSSING LTD
+DEFERENCE 9 10,0000
+0,060000
+ASIA GLOBAL CROSSING LTD
+UNIT PRICE
+8,760400
+DIFFERENCE -
+0,060000
+SYMBOLGUSF
+"AGCX
+"AGCX
+AGCX
+"AGCX"
+"AGCX
+QUANTITY
+-350
+15,000
+15,000
+-1,000
+25,000
+85,000
+60,000
+1.01790
+- 828580
+0.80000
+9.05250
+8.70040
+027
+CLEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+660-56-7418
+January 26, 2001
+34,397.81
+124,280.35
+77,494.83
+226,302.45
+522,004.09
+
+
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SETTLEMENT TRADE
+DATE
+02/12/01
+02/09/01
+OFFICE SERVICING YOUR ACOOUNT
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+62/121* 0209/01*S0LВ
+
+02/21/01
+ö2/21/01
+
+02/21/01
+ö22101
+02221(01
+"RECEIVED******
+JOURNALI
+"JÖURNAL
+"OURNAL"
+JOURNAL"
+CALL VECTOR GROUP FEB 019AMEX
+ADJ 5% STOCK DIVIDEND
+EXP 02/17/2001
+UNSOLICITED
+CLOSING CONTRACT
+"CALL VECTOR GROUP MAY 020 AMEX
+EXP 05/19/2001
+JNSOLICITED
+OPEN CONTRACT
+BOSTON PROPERTIES INC
+DWAC
+VECTOR GROUP LTD
+OURNAL FROM TYPE 1 TO 2
+"CALL VECTOR GROUP MAR 020 AMEX
+EXP 03/17/2001
+JOURNAL FROM TYPE 2 TO 1
+CALL VECTOR GROUP MAY 020 AMEX
+EXP 05/19/2001
+JOURNAL FROM TYPE 2 TO 1
+PECTOR GROUP
+OURNAL FROM TYPE 1 TO 2
+"CALL VECTOR GROUP MAR OZ0AMEX"
+SO DA FROM PE 2 TO 1
+CALL VECTOR GROUP MAY 020AMEX
+JOURNAL FROM TYPE 2 TO 1
+SYMBOLGUSP
+*EXP
+VGR
+QUANTITY
+1,020
+:1,071
+**500,000
+710,671
+1,350
+1,091
+
+1,350
+1,091
+1.80000
+• 200000"
+027
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 660-56-7418
+January 26, 2001
+195,842.50
+CRECIT AMOUNT
+''270377.36
+$-195,842.50
+$1,195,456.89
+
+
+7 of a
+Transaction Detail (continued)
+DEPOSITS AND WITHDRAWALS
+02/05101
+FUNDS REC
+ö2/1601
+"FUNDS REC"
+02/21/01 ND WIRED"
+BARSENRER TO CITIBANK FROM
+HER TOOTBANK FROM
+WIRED TO
+BARIN RETRIAK
+(PUT DIFF. ON MARGIN)
+INTEREST
+DATE
+02/21/01
+INTEREST ON CREDIT BALANCE
+AT 5 1/2% 01/21 THRU 01/30
+02/24/07NTEREST ON CREDIT BALANCE*
+AT 5.000% 01/31 THRU 02/20
+MISCELLANEOUS
+DATE
+MODAY
+02/21/01
+02/21/01
+02/22/01
+JOURNAL"
+JOURNAL FROM TYPE 2 T0 1
+JOURNAL FROM TYPE 2 TO 1
+JOURNAL FROM TYPE T 102"
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+4,392.82
+14,500,000.00
+19,950,000.00
+$-19,950,000.00
+$14.504.392.82
+SYMBOL/CUSIP
+QUANTITY
+RATE (%)
+5.5000
+4,285,571.63
+14,792.30
+4,285,571.63
+027
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+660-56-7418
+January 26, 2001
+1,427.38
+$14,792.30
+
+
+8 ora
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+660-56-7418
+January 26, 2001
+Transaction Detail (continued)
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+02/22/01
+JOURNAL FROM TYPE 1 10 2
+$-4,300,363.93
+14,792.30
+$4,300,363.93
+Your messages
+manuary 20r is compute for Documber 23, 2000.
+STOP
+****** End of Statement******
+027
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Trades Not Yet Settled
+......
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 30, 2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 660-56-7418
+December 29,2000
+3
+4
+6
+C/O AMERICAN YACHT HARBOR *
+6100 RED HOOK SUITE B-3
+QUARTERS #2
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+14,899,343
+160,421
+15,059,76
+12,972,111
+2,087,653
+Cash & Equivalent
+Equities -
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$160,421
+$402,990
+$15,016,583
+: $-117,240
+$12,569,121
+Current market value
+Last statement's market value
+Short market value
+Important Message
+Decimal Trading is Coming!
+Decimal Trading is the shift
+from fractional pricing
+(e.g.,21 1/2) to decimal
+pricing (e.g.,$21.50)for
+equities and options.
+All trading on NYSE, AMEX,
+and regional exchanges
+will be in decimals effective
+as of 1/29/01.
+For details, visit our website
+at www.bearsteams.com.
+Flease raport any dierence or non-receipt of chacks or stocks, indicated as delivered to you.
+to Client Services at 800-634-1428; or Write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3659.
+SP The suremen s foul ratanal purger red de Set revere die for portant iformation.
+01/27/01;13:44 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+
+
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Funds Deposited
+Dividends/Interest
+Amount Credited
+Miscellaneous
+nount Debite
+Net Cash Activity
+Closing Balance
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+THIS PERIOD
+102,989.8
+......
+87,653.22
+44,707,021.63
+7,277.46
+$44,801,952.31
+-45,044,521.00
+.............S.45.044.521.00
+-242,568.69
+5160421.16
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+402,989.85
+$402,989.85
+Income Summary
+THIS PERIOD
+Credit Balance Int.
+Total
+7,277.46
+87.277.46
+Portfolio Composition
+SHOAT
+Cash/Cash Equivalent
+Equities
+Total
+117,240
+$117,240
+CLOSING
+160,421.16
+$160,421.16
+YEAR TO DATE
+7,277.46
+57277.46
+LONG
+160,421
+15,016,583
+S15.177.004
+027
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 30, 2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 660-56-7418
+December 29,2000
+Your Portfolio
+Allocation
+(sh & Equinalent.
+Short Equities-
+< 1%
+Equities
+98%
+Unshaded portions denote debit balance andor short
+from the absolute marker value of your portlia.
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+CHILDRENS PLACE RETAIL STORES
+TELIGENT INC-CLA
+VECTOR GROUP LTD
+CALL VECTOR GROUP FEB 019AMEX
+ADJ 5% STOCK DIVIDEND
+EXP 02/17/2001
+53 6120 POUR MAY OZOANEX
+Total Equities& Options
+TOTAL EQUITIES
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SIMBOLCUSP
+QUANTITY
+SYMBOUCUSIP
+PLCE
+TGNT
+VGR
+GVXB19
+VGRE20
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+60,000
+60,000
+710,671
+-1,020
+160,421
+$160,421
+20.7500
+3.0000
+19.1250
+1.0620
+1.7500
+MARKET
+VALUE
+1,245,000
+180,000
+13,591,583
+-113,740
+-3,500
+$14,899,343
+$14,899,343
+$1,137,074
+$15,059,764
+STIMATE
+NNUAL INCON
+ESTIMATE
+NNUAL INCON
+1.137.074
+$1,137,074
+$1,137,074
+SURREN
+ELD (:
+8.3660
+027
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 30, 2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 660-56-7418
+December 29,2000
+
+
+5 of7
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT TRADE
+DATE
+01/16/01 01/12/01
+OFFICE SERVICING YOUR ACOOUNT
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+01/19/01 01/18/01 SOLD
+01/23/01
+01/22/01
+DEPOSITS AND WITHDRAWALS
+DATE
+01/11/01
+FUNDS REC
+01/18/01
+FUNDS REC
+01/23/01
+FUNDS REC
+EWIRED TO CITIBANK FROM
+NIS MARACES TANK FRO
+ENDS WIRED TO CHIBANK FROM
+CALL VECTOR GROUP MAY 020 AMEX
+EXP 05/19/2001
+CHEN CONTRACT POLON.
+CALL VECTOR GROUP FEB 019AMEX
+BXP 021720K WIDEND
+ONEN CONTRACT
+CALL VECTOR GROUP FEB 019AMEX
+ADJ 5% STOCK DIVIDEND
+EXP 02/17/2001
+NSOLICITE
+PEN CONTRAC
+SYMBOL/GUSP
+QGVXB19
+OGVXB19
+DEBIT AMOLNT
+QUANTITY
+-20
+-20
+- 1,000
+25,000,000.00
+3,527,760.91
+16,179,260.72
+$44,707,021.63
+1.37500
+0.93750
+0.81500
+027
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 30, 2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+660-56-7418
+December 29,2000
+2,677.40
+906.1
+....
+83,069.64
+$87,653.22
+
+
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+6 of 7
+Transaction Detail (continued)
+INTEREST
+DATE
+01/22/01
+INTEREST ONCREDIT BALANCE
+AT 6.000% 12/29 THRU 01/02
+01/2201
+A 800 32 1 1205
+
+........
+MISCELLANEOUS
+DATE
+MODAY
+01/12/01
+01/23/01
+TO
+SYMBOL/CUSIP
+Trades Executed Pending Settlement
+SETTE MENT TRE
+01/29/01
+01/26/01
+01/30101
+01/25/01
+CALL VECTOR GROUP MAR 020AMEX
+ASIA GLOBAL CROSSING LTD
+CLA
+QUANTITY
+RATE INI
+6.0000
+6.0000
+5.5000
+25,044,521.00
+20,000,000.00
+$-45,044.521.00
+SYMBOLCUSP
+AGCX
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD December 30,2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 660-56-7418
+December 29,2000
+CAEDIT AMOUNT
+335.82
+455.67
+6,485.97
+$7.277.46
+CRECIT AMOUNT
+QUANTITY
+350.00
+15,000.00
+1 0179
+8 2858
+34,397.81
+124,280.35
+.......
+027
+
+
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Trades Executed Pending Settlement
+(continued)
+SETLEMENT TRIE
+01/31/01 01/26/01
+SANETON
+ASIA GLOBAL CROSSING LTD
+CLA
+The above trades do not appear in arry other section of this statement.
+SIMBOLCUSP
+AGCX
+QUANTITY
+-25,000.00
+9 0525
+STOP
+****** End of Statement******
+027
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 30, 2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+660-56-7418
+December 29,2000
+226,302.45
+$0.00
+$384,980.61
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/a1acedf4df2e584b59cb9d0800ba0c80118e30ef2b2dc6f445c8c85d57b7297b.receipt.json b/vision-fixhub/ds9-unparsed-05/a1acedf4df2e584b59cb9d0800ba0c80118e30ef2b2dc6f445c8c85d57b7297b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..94e65d822704b01b49a3f477414fe1126de057ee
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a1acedf4df2e584b59cb9d0800ba0c80118e30ef2b2dc6f445c8c85d57b7297b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -16782,
+  "dataset": "marble-joined",
+  "doc_id": "a1acedf4df2e584b59cb9d0800ba0c80118e30ef2b2dc6f445c8c85d57b7297b",
+  "engine": "marble-apple-vision",
+  "event_count": 122,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "5011f878fb71403ae23bec27ef3cc39e6574a543d7e488ebbdbe025e7f30e7e5",
+  "output_sha256": "312b437c5291f2faf01d0afa7c44ce69f016709b9ac4814cc302ad3aed3848d1",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a2089bb63d3fa288f86f6dd53c0e8ba8c910c085715b284fa4cf30de76606fab.md b/vision-fixhub/ds9-unparsed-05/a2089bb63d3fa288f86f6dd53c0e8ba8c910c085715b284fa4cf30de76606fab.md
new file mode 100644
index 0000000000000000000000000000000000000000..9d12179d2e9f19ee36eb5be5e03d02e275bf20e8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a2089bb63d3fa288f86f6dd53c0e8ba8c910c085715b284fa4cf30de76606fab.md
@@ -0,0 +1,49 @@
+OLY-15
+
+
+TO: CUSTODIAN OF RECORDS
+REIMER EMPLOYMENT AGENCY
+249 PERUVIAN AVE, STE R1
+PALM BEACH, FL 33480
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-15
+SUBPOENA FOR:
+] PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+ROOM:
+Room 4-A
+DATE AND TIME:
+September 1, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+ANY AND ALL RECORDS REFERRING OR RELATING TO JEFFREY EPSTEIN AND/OR
+GHISLAINE MAXWELL, INCLUDING BUT NOT LIMITED TO PERSONNEL RECORDS,
+RECORDS OF PAYMENTS, AND CLIENT PROFILE.
+Please coordinate your compliance of this subpoena and confirm the date and time of vour annearance with
+Special Agent
+Federal Bureau of Investigation, Telephone:
+Please sce additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+August 23, 2006
+This subpoena is issued upon application
+Name Address and Phone Number of Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+25101-6235
+Westri
+Tel:
+Fax:
diff --git a/vision-fixhub/ds9-unparsed-05/a2089bb63d3fa288f86f6dd53c0e8ba8c910c085715b284fa4cf30de76606fab.receipt.json b/vision-fixhub/ds9-unparsed-05/a2089bb63d3fa288f86f6dd53c0e8ba8c910c085715b284fa4cf30de76606fab.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6937e2907e8a85bd5b6d2ee04ed4fc31751b560e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a2089bb63d3fa288f86f6dd53c0e8ba8c910c085715b284fa4cf30de76606fab.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "a2089bb63d3fa288f86f6dd53c0e8ba8c910c085715b284fa4cf30de76606fab",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "7ce0ce589d27f34863cf70f4d5ae05d3cc68fbf1d9dd0e43b29c6d42dca3ed87",
+  "output_sha256": "6558398e6fd5429ab12b38331a8ff254c933cfb59d2156ae554de495dd9c6f2e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a26c6280529794cfda5b8e4be677a7890d4f4243c73b3a78a5b4ac026f62f0b6.md b/vision-fixhub/ds9-unparsed-05/a26c6280529794cfda5b8e4be677a7890d4f4243c73b3a78a5b4ac026f62f0b6.md
new file mode 100644
index 0000000000000000000000000000000000000000..a34f6a90732e8a2df05715b6d901a6bc5d178cd2
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a26c6280529794cfda5b8e4be677a7890d4f4243c73b3a78a5b4ac026f62f0b6.md
@@ -0,0 +1,1361 @@
+Statements
+
+
+ACCOUNT EXECUTIVE
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+GNMA GOVT BOND
+What's In This Statement
+Financial Summay ..!
+Transaction Detail
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 1, 2005
+THROUGH
+September 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Avallable
+LAST STATEMENT
+August 31, 2005
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN &
+6100 RED HOOK QUARTER STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Miscellaneous
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+70,059,355.53
+178,502.21
+8,398,617.18
+$78,636,474.92
+-57,674,007.79
+-20,962,467.13
+$.78.636.474.92
+$0.00
+Income Summary
+Govt. Agency Int.
+Corp. Bond Int.
+......
+Total
+THIS PERICO
+67,456.24
+111,045.97
+6178.502 2
+YEAR TO DATE
+67,456.24
+111.045.97
+$178,502.21
+SIP The surenes four or ratanal purposes red die Set revere date for portant iformation.
+
+
+2 org
+Transaction Detail
+INVESTMENT ACTIVITY
+SATE EMENT TATE
+DATE
+TRANSACTION
+09/14/05 08/19/05
+CANCEL SELL
+09/14/05 08/19/05
+SOLD
+09/20/05
+09/15/05
+SOLD
+0B/20/05
+09/15/05
+SOLD
+....
+09/20/05
+09/15/05"
+SOLD
+09/20/05
+09/15/05
+SOLD
+09/20/05
+09/15/05
+SOLD
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+FNMA-30YR(FNMA)GTD
+DUE 090112085 05 0005
+S OF US/TSIUS
+-
+O CXL PREVIOUS SEL
+FNMA 30YRFMAJGTD
+SETT. 09/05
+DUE 090112085 05 000%
+REF #
+................
+FANNIE MAE CMO/SERIES 2003-13
+S ROR-VO FLTR
+DUE 03/25/2033 M 358%
+5 OF U371570:
+BS
+FEDERAL NATIONAL MIG ASSN
+SERIES 2003-49 CLASS SW
+DUE 01/25/2033 03 3582
+AS OF 0916105
+BS
+FANNIE MAE MOISERIES 2003-52
+KS-VO FLTR
+REF #7/25/2017.03 158%
+AS OF 03715:05
+GOVERNMENT NATIONAL MG ASSN
+SERIES 2004-5 CLASS PS
+DUE 02/20/2033 02 2/05
+BS
+... . .
+GOVERNMENT NATIONAL MTG ASSI
+SERIES 2004-30 CLASS SU
+DUE 02/20/2032 03 59054
+REF #
+AS OF 08715105
+BS
+SYMBOL/CUSIP
+QUANTITY
+50,000,000
+PRICE
+98.55078
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 1, 2005
+THROUGH
+September 30,2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Avallable
+LAST STATEMENT
+August 31, 2005
+DEBIT AMOUNT
+49,275,390.63
+CREDIT AMOUNT
+----..
+-50,000,000
+-23,543,127
+- 11,861,918
+16,565,865
+44,000,000
+98.55078
+9.87500
+ACCR. INT.
+6.96875
+ACCR. INT.
+6.96875
+ACCR. INT.
+11.15625
+-23,561,075
+6.03125
+49,275,390.63
+2,324,883.79
+71,262.10
+826,627.47
+27,667.10
+1,154,433.75
+39,789.14
+4,908,750.00
+1,421,027.35
+027
+
+3 org
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SATEMENT TREE
+DATE
+TRANSACTION
+09/20/05 09/15/05
+SOLD
+09/20/05 09/15/05 SOLD
+09/20/05
+09/15/05
+SOLD
+09/20/05
+RECEIVED
+09/20/05
+RECEIVED
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+09/20/05
+09/20/05
+RECEIVED
+RECEIVED
+DESCRIPTION
+GOVERNMENT NATIONAL MIG ASSN
+SERIES 2004-035 CLASS SP
+I BS
+FREDDIE MAC CMOISERIES 2886
+SU 07A F2019 09 59154
+AS OF 03715105
+BS
+... . .
+ALTERNATIVE LOAN TRUST
+SERIES 2004-30CB CLASS 1-A-8
+DUE 02/2512035 01 4585
+AS OF USES
+BS
+FANNIE MAE CMOVSERIES 2003-13
+S RCR-VO FLTR
+4,358 DUE 03/25/33
+NE 03/2512037
+1,358
+FEDERAL NATIONAL MG ASSN
+3,35E 200112 CLASS SV
+IF 01 25/2033
+3358
+FANNIE MAE CMO/SERIES 2003-52
+KS-NO FLTR
+3,458 DUE 07/25/17
+Masa 525930083158
+GOVERNMENT NATIONAL MTG ASSN
+SERIES 2004-5 CLASS PS
+3,340 DUE 02/20/33
+DUE 02/20/2033
+3,340
+SYMBOLICUSIP
+027
+QUANTITY
+-14,296,550
+3,074,61
+-35,363,806
+23,543,127
+PRICE
+4.53125
+.....
+7.2812!
+ACCR. INT.
+1.45313
+ACCR. INT.
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 1, 2005
+THROUGH
+September 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+August 31, 2005
+DEBIT AMOUNT
+CREDIT AMOUNT
+647,812.46
+__...
+87,932.51
+3,960.82
+........
+513,880.31
+35,823.05
+2,396,145.89
+......
+11,861,918
+854,294.57
+98 999 91
+44,000,000
+1,194,222.89
+4,908,750.00
+........
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+4 of g
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SATEMENT TREE
+09/20/05
+TRANSACTION
+RECEIVED
+DESCRIPTION
+GOVERNMENT NATIONAL MIG ASSN
+SERIES 2004-30 CLASS SU
+3,590 DUE 02/20/32
+BUE 02/20/2032
+3,590
+09/20/05
+RECEIVED
+SERIES 200 03S CASE SATG ASSI
+3.5202012220120 590
+09/20/05
+RECEIVED
+FREDDIE MAC CMOVSERIES 2886
+SC-V/O FLTR
+3,531 DUE 07/15/1:
+DUE 07/15/2019
+09/20/05
+RECEIVED
+.. . .
+ALTERNATIVE LOAN TRUS
+SERIES 2004-30CB CLASS 1-A-8
+1,458 DUE 02/25/35
+DIE 02/25/2035
+1458
+09/21/05
+09/15/05
+CANCEL SELL
+GOVERNMENT NATIONAL MTG ASSN
+ERIES 2004-5 CLASS F
+UE 02/20/2033 03 160
+9/21/0
+09/15/05
+SOLD
+TO CXL PREVIOUS SELL
+....
+GOVERNMENT NATIONAL MIG ASSA
+SERIES 2004-5 CLASS P
+DUE 02/20/2033 03 1605
+REF #
+AS OF 1DOBNEY05 50 03720/05
+INTR COMPUTED TO 09/20105
+SYMBOL/CUSIP
+027
+QUANTITY
+23.561,075
+14,296,550
+8.074,610
+35,363,806
+44,000,000
+PRICE
+• 11.15625
+-44,000,000
+1.1562
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 1, 2005
+THROUGH
+September 30,2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+August 31, 2005
+DEBIT AMOUNT
+1,421,027.35
+CRECIT AMOUNT
+647,812.46
+... . .
+591,893.41
+549,703.36
+"4,908,750.00
+,908,750.0
+
+
+5 org
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+DATE
+TRANSACTION
+09/21/05
+09/15/05
+CANCEL SELL
+09/21/05
+09/15/05
+SOLD
+19/21/0
+09/15/05
+CANCEL SELL
+19/21/05
+09/15/05
+"SOLD
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+GOVERNMENT NATIONAL MIG ASSN
+SUE 202030 GAS SU
+REF#
+AS OF 1D U3715705 SD 03/20/05
+AS OF 09/15/05
+TO CXL PREVIOUS SELL
+GOVERNMENT NATIONAL MG ASSN
+SERIES 2004-30 CLASS SU
+DUE 02020/2032 08 41105
+AS OF 1508N605 30 0872005
+AS OF 09/15/05
+NTR COMPUTED TO 09/20/05
+AS OF BOSMETUS 3008208S
+AS OF 09/15/05
+TO CXL PREVIOUS SELL
+GOVERNMENT NATIONAL MIG ASSN
+09/27/05
+09/15/05
+CANCEL SELL
+GOVERNMENT NATIONAL MG ASSN
+SERIES 2004-30 CLASS SU
+SYMBOLCUSIP
+027
+QUANTITY
+23,561,075
+PRICE
+6.03125
+-23,561,075
+6.03125
+14,296,550
+4.53125
+14,296,550
+4.53125
+23,561,075
+6.03125
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 1, 2005
+THROUGH
+September 30,2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+August 31, 2005
+DEBIT AMOUNT
+1,421,027.35
+CREDIT AMOUNT
+1,421,027.35
+647,81246
+647,812.46
+1,421,027.35
+
+
+6 of 9
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+DATE
+TRANSACTION
+09/27/05 09/15/05
+SOLD
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+DESCRIPTION
+GOVERNMENT NATIONAL MIG ASSN
+TOTAL
+MISCELLANEOUS
+MATSAY
+09/21/05
+TRANSACTION
+RECEIVED
+09/21/05
+DiK
+DESCRIPTION
+BOVERNMENT NATIONAL MTG ASSN
+SERIES 2004-5 CLASS PS
+3.160 DUE 02/20/33
+3 160
+COUPON FATE 3,1537
+09/21/05
+RECEIVED
+SOUPON RATE 3,3406
+GOVERNMENT NATIONAL MG ASSN
+SERIES 2004-30 CLASS SU
+3.410 DUE 02/20/32
+DIE 02/20/2032
+3 410
+COUPONFATE 3,4037
+SYMBOLCUSIP
+DEBIT AMOUNT
+4,908,750.00
+1,421,027.35
+027
+QUANTITY
+-23,561,075
+PRICE
+6.03125
+CREDIT AMOUNT
+4,908,750.00
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 1, 2005
+THROUGH
+September 30,2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+August 31, 2005
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,421,027.37
+$-70,237,857.72
+$70,237,857.74
+
+
+7 of g
+Transaction Detail (continued)
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+09/21/05
+TRANSACTION
+D/K
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+09/21/05
+RECEIVED
+09/21/05
+BIK®
+09/27/05
+RECEIVED
+GOVERNMENT NATIONAL MTG ASSN
+SERIES 2004-30 CLASS SU
+410 DUE 02/20/32
+COUPON HATE 3,5906
+SORES 2005 AS PITCASN
+3.103 DE2/20/29 2103
+COUPON FATE 3.4037
+SEES 20405 AS PT ASS
+3.403 DUE 12/20/29
+COUFON FATE 3,5906
+GOVERNMENT NATIONAL MTG ASSN
+SERIES 2004-30 CLASS SU
+3.193 D2N102220/32
+-3403
+COUPON FATE 3.4037
+647,812.46
+1,421,027.37
+09/27/05
+DIK
+09/27/05
+DIK
+COUPON FATE 3.4037
+COME 20430 AS MIG ASSN
+3403 DUE 02/20/32
+S-DIFF
+027
+CRECIT AMOUNT
+1,421,027.35
+647,812-46
+1,421,027.35
+0.02
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 1, 2005
+THROUGH
+September 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Avallable
+LAST STATEMENT
+August 31, 2005
+DEBIT AMOUNT
+
+
+8 of 9
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+MISCELLANEOUS (continued)
+DATE
+MODAY
+09/28/05
+TOTAL
+TRANSACTION
+JOURNAL
+DESCRIPTION
+BAL ACCT
+DEBIT AMOUNT
+0.02
+$-8,398,617.20
+CRECIT AMOUNT
+$8,398,617.18
+STOP
+****** End of Statement******
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 1, 2005
+THROUGH
+September 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Avallable
+LAST STATEMENT
+August 31, 2005
+
+
+9 of 9
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+GNMA GOVT BOND
+What's In This Statement
+Trades Not Yet Settled......................
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD July 30,2005
+THROUGH
+August 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+July 29,2005
+1
+FINANCIAL TRUST CO INC
+CIO JEFFREY EPSTEIN &
+6100 RED HOOK QUARTER STE B3
+ST THOMAS VI 00802
+Trades Executed Pending Settlement
+SETLEMENT TRADE
+TRANSACTION
+09/14/05 08/19/05
+SOLD
+TOTAL
+DESCRPTION
+FNMA-30YA(FNMA)GTD
+SETT,09/05
+DUE 09401/2035 05 0000%
+REF #
+The above trades do not appear in any ather section of this statement
+SYMBOLCUSIP
+QUANTITY
+-50,000,000.00
+PRICE
+98.5507
+DEBIT AMOUNT
+CREDIT AMOUNT
+49,275,390.63
+$0.00
+$49,275,390.63
+STOP
+****** End of Statement******
+This summary is for informational purposes only. it is not intended as a tax documen
+PC This statement should be retained ter our redral See reense did at important information
+09/01/05;14:14 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+09/01/05:14:14 001
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+GNMA GOVT BOND
+What's In This Statement
+Financil Summar .mm l.
+Transaction Detail
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocktyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD July 1,2005
+THROUGH
+July 29, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Avallable
+LAST STATEMENT
+June 30,2005
+#olholllmlll
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN &
+6100 RED HOOK QUARTER STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Amount Credited
+Securities Bought
+Amount Debited
+Closing Balance
+THIS PERICO
+$0.00
+95,987,109.38
+$95,987,109.38
+-95,987,109.38
+$-95,987,109.38
+$0.00
+STP Thie urener s foul er ratanel ptr yer rebr de Set revere date fr postamt itformation.
+07/30105;11:13 001
+V895
+
+
+2 org
+Transaction Detail
+INVESTMENT ACTIVITY
+SATE EMENT TATE
+TRANSACTION
+07/14/05
+06/03/05
+BOUGHT
+07/1405
+05/06/05
+'CANCEL SELL
+07/14/05
+06/03/05
+CANCEL BUY
+07/14/05
+05/06/05
+SOLD
+07/14/05
+06/03/05
+CANCEL SELL
+07/14/05
+06/03/05
+SOLD
+TOTAL
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+-NMA 3OYR TBA GTL
+SETT, 07/05
+DUE 070112035 05 0005
+ENMA SOYA TBA GTD
+SETT, 07/0S
+DUE 07/01/2035. 05.000
+REF #
+S OF 05106.03
+O CXL PREVIOUS SEL
+...
+NMA 30YR TBA GT
+SETT. 07/05
+DUE 07012035 05 0005
+REF #
+S OF DEFUSNU
+• CXL PREVIOUS BU
+....
+FNMA 3OYR TBA GTD
+SEIT, 07/05
+DUE 07/01/2035 05.000
+.. . .
+SET: 700E GT
+REF 77012085.06. 0006
+TO OR PREMIUS SELL
+SETT. 07/05
+REF #7/012085 06 002%.
+SYMBOL/GUSP
+027
+QUANTITY
+15,000,000
+30,000,000
+PRICE
+100.21875
+98.51953
+-15,000,000
+100.21875
+-30,000,000
+50,000,000
+98.51953
+102.79688
+-50,000,000
+' 102.79688
+07/30/05;11:13 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOO July 1,2005
+THROUGH
+July 29, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+June 30, 2005
+DEBIT AMOUNT
+15,032,812.50
+CREDIT AMOUNT
+29,555,859.38
+15,032,812.50
+29,555,859.38
+51,398.437.50
+$-95,987,109.38
+51,398.437.50
+$95,987,109.38
+V99S
+
+
+3 of 3
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+07/30/05:11:13 001
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+GNMA GOVT BOND
+What's In This Statement
+Trades Not Yet Settled........................
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 1,2005
+THROUGH
+June 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+May 31, 2005
+1
+FINANCIAL TRUST CO INC
+CIO JEFFREY EPSTEIN &
+6100 RED HOOK QUARTER STE B3
+ST THOMAS VI 00802
+Trades Executed Pending Settlement
+SETLEMENT
+07/14/05
+07714/05
+07/14/05
+TOTAL
+06/03/05
+05/06/05
+06/03/05
+TRANSACTION
+BOUGHT
+SOLD
+SOLD
+DESCRIPTION
+FNMA 30YA TBA GTD
+SETT, 07/05
+DUE 07401/2035. 05.000
+REF #
+ENMA SOYA TBA GTD
+SETT, 07/05
+DUE 07012035. 05.0002
+REF #
+MA 30YR GT
+SETT, 07/05
+REE 870120250600T
+REF #
+The above trades do not appear in any ather section of this statement.
+SYMBOL/CUSIP
+QUANTITY
+15,000,000.00
+30,000,000.00
+PRICE
+100.2187
+98.5195
+DEBIT AMOUNT
+15,032,812.50
+CREDIT AMOUNT
+29,555,859.38
+-50,000,000.00
+102.7968
+$15,032,812.50
+51.398.437.50
+$80,954,296.88
+SPC The serman to it matal prose end ended a parame tomatio.
+07/01/05;11:16 001
+VASSIP
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+07/01/05:11:16 001
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+GNMA GOVT BOND
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+@rocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 30,2005
+THROUGH
+May 31,2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Avallable
+LAST STATEMENT
+April 29,2005
+What's In This Statement
+Financial Summ...........................
+Transaction Detail
+Trades Not Yet Settled
+1
+2
+3
+Hollandlml
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN &
+6100 RED HOOK QUARTER STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+'Amount Credited
+Securities Bought
+Amount Debited
+Closing Balance
+THIS PERICO
+$0.00
+79,271,875.00
+......
+$79,271,875.00
+-79,271,875.00
+$-79.271,875.00
+$0.00
+STP Thie urener s foul er ratanel ptr yer redr de Set revere date fr postamt itformation.
+06/01/05;09:42 001
+
+
+2 or 4
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEEMENT TATE
+DATE
+TRANSACTION
+05/12/05 04/07/05
+CANCEL SELL
+05/12/05 04/07/05
+SOLD
+05/12/05
+: 04/07/05
+''CANCEL SELL
+05/12/05
+04/07/05
+SOLD
+TOTAL
+Bear, Stearns & Co. Ine.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+FNMA-30YR(FNMA)GTD
+DUE 05M 1/2035. 05.0005
+S OF U4T077US
+TO CXL PREVIOUS SEL
+FNMA 30YRFMAJGTD
+-
+SETT.05/09
+SUE 05012025 05 500
+AS CA PREVIOUS SELL
+SET. 0505 (FNMA)GTD
+DUE 05012035 05 500%
+SYMBOL/CUSIP
+027
+QUANTITY
+40,000,000
+PRICE
+97.92188
+-40,000,000
+40,000,000
+97.92188
+••••••••••••
+100.25781
+40,000,000
+100.25781
+06/01/05;09:42 001
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 30, 2005
+THROUGH
+May 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+April 29,2005
+DEBIT AMOUNT
+39,168,750.00
+CREDIT AMOUNT
+39,168,750.00
+*.......
+40,103, 125.00
+40,103,125.00
+$-79,271,875.00
+$79.271.875.00
+
+
+3 or a
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Trades Executed Pending Settlement
+BETTE MENT TRE
+TRANSACTION
+07/14/05 05/06/05 SOLD
+TOTAL
+DESCRIPTION
+FNMA 30YR TBA GID
+SETT, 07/05
+REF 2025 0500 T
+REF #
+The above trades do not appear in any other section of this statement.
+STOP
+****** End of Statement******
+SYMBOLCUSIP
+QUANTITY
+-30,000,000.00
+PRICE
+98.5195
+027
+06/01/05;09:42 001
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 30, 2005
+THROUGH
+May 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Avallable
+LAST STATEMENT
+April 29,2005
+DEBIT AMOUNT
+CREDIT AMOUNT
+29,555,859.38
+$0.00
+$29,555,859.38
+
+
+4 of 4
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+06/01/05;09:42 001
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+GNMA GOVT BOND
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 1, 2005
+THROUGH
+April 29, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Avallable
+LAST STATEMENT
+March 31, 2005
+What's In This Statement
+Financial Summ...........................
+Transaction Detail
+Trades Not Yet Settled
+1
+2
+2
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN &
+6100 RED HOOK QUARTER STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Amount Credited
+Securities Bought
+Amount Debited
+Closing Balance
+THIS PERICO
+$0.00
+24,611,718.75
+$24,611,718.75
+-24,611,718.75
+$-24,611,718.75
+$0.00
+SIP The surren s four or ratanal purposes red die Set revere ate for portant iformation.
+04/30105;13:39 001
+V977
+
+
+2 or 4
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEEMENT TATE
+DATE
+TRANSACTION
+04/13/05 03/09/05
+CANCEL SELL
+04/13/05 03/09/05
+SOLD
+04/13/05
+03/16/05
+BOUGHT
+04/13/05
+03/16/05
+CANCEL BUY
+TOTAL
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+FNMA 30YR GTD
+SETT. 04/05
+DUE 04/01/2035 05.000
+S OF USTUSTUS
+TO CXL PREVIOUS SEL
+FNMA 3OVR GTD
+SETT, 04/05
+DUE 04m 12085 05 000%
+AS OF 03103105
+MA 30YR GE
+SETT. 04/05
+DUE 04M01/2035 05 5005
+REF #
+SETT. 04/05
+DUE 0401/2035 05.500:
+REF #
+AS OF USFTGUS
+TO CXL PREVIOUS BUY
+Trades Executed Pending Settlement
+SATEMENT DARE
+05/12/05
+04/07/05
+TRANSACTION
+SOLD
+DESCRIPTION
+NMA-30YR(FNMA)GT
+ETT, 05/0
+REF #
+SYMBOL/CUSIP
+QUANTITY
+20,000,000
+-20,000,000
+5,000,000
+-5,000,000
+PRICE
+97.99219
+97.99219
+••••••••••••••••
+100.26563
+100.26563
+SYMBOLCUSIP
+QUANTITY
+-40,000,000.00
+PRICE
+97.9218
+027
+04/30105;13:39 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 1, 2005
+THROUGH
+April 29, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Avallable
+LAST STATEMENT
+March 31,2005
+DEBIT AMOUNT
+19,598,437.50
+CREDIT AMOUNT
+19.598,437.50
+......
+5.013,281.25
+$-24,611,718.75
+5,013,281.2
+$24,611.718.75
+DEBIT AMOUNT
+CREDIT AMOUNT
+39,168,750.00
+V977
+
+
+3 or a
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Trades Executed Pending Settlement
+(continued)
+SETTEMENT TRADE
+DATE
+05/12/05 04/07/05
+TRANSACTION
+SOLD
+DESCRIPTION
+FNMA-30YR(FNMA)GTD
+SETT, 05/05
+BE 1202505506 m
+REF #
+SYMBOL/CUSIP
+QUANTITY
+-40,000,000.00
+PRICE
+100.2578
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 1, 2005
+THROUGH
+April 29, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Avallable
+LAST STATEMENT
+March 31,2005
+DEBIT AMOUNT
+CREDIT AMOUNT
+40,103,125.00
+TOTAL
+The stove trades do not appear in any other section of this statement.
+$0.00
+$79,271,875.00
+STOP
+****** End of Statement******
+027
+04/30/05;13:39 001
+V877
+
+
+4 of 4
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+04/30/05;13:39 001
+V877
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+GNMA GOVT BOND
+What's In This Statement
+Trades Not Yet Settled........................
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 1, 2005
+THROUGH
+March 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+October 29,2004
+1
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN &
+6100 RED HOOK QUARTER STE B3
+ST THOMAS VI 00802
+Trades Executed Pending Settlement
+SETLEMENT
+TRADE
+DATE
+04/13/05
+03/09/05
+TRANSACTION
+SOLD
+DESCRIPTION
+FNMA 30YR GTD
+04/13/05 03/16/05
+BOUGHT"
+TOTAL
+REF #
+EMA SOYA GTD
+BUT 005025 05 500
+REF #
+The above trades do nat appear in any other section of this statement.
+SYMBOL/CUSIP
+QUANTITY
+-20,000,000.00
+PRICE
+97.9921
+DEBIT AMOUNT
+CREDIT AMOUNT
+19,598,437.50
+5,000,000.00
+- 100.2656
+5.013,281.25
+$5,013.281.25
+$19,598,437.50
+STOP
+****** End of Statement******
+SPC The remany store ratanal purpose end on ente as a potame tomation.
+04/01/05:10:29 001
+V976
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+04/01/05;10:29 001
+V976
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/a26c6280529794cfda5b8e4be677a7890d4f4243c73b3a78a5b4ac026f62f0b6.receipt.json b/vision-fixhub/ds9-unparsed-05/a26c6280529794cfda5b8e4be677a7890d4f4243c73b3a78a5b4ac026f62f0b6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d67bd1479b03124fb01591c56d71abe949b6f78c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a26c6280529794cfda5b8e4be677a7890d4f4243c73b3a78a5b4ac026f62f0b6.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1820,
+  "dataset": "marble-joined",
+  "doc_id": "a26c6280529794cfda5b8e4be677a7890d4f4243c73b3a78a5b4ac026f62f0b6",
+  "engine": "marble-apple-vision",
+  "event_count": 26,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "384525a1edae5917313b404f2739aa8e72c6d1e7e2a77bdfb7f7822cfdb7c30d",
+  "output_sha256": "db1be04ed2fd82d6229beb9c891ef8ee2283dcdf8a1a27adb77aa1510ec4a383",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a2cb41bcf64e515d7a5d38fc28fce157cae2a665136db47a7c1554ab9fc7312c.md b/vision-fixhub/ds9-unparsed-05/a2cb41bcf64e515d7a5d38fc28fce157cae2a665136db47a7c1554ab9fc7312c.md
new file mode 100644
index 0000000000000000000000000000000000000000..e25d2c683fd0388a7b0d51f1b7d53a27f7970f0c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a2cb41bcf64e515d7a5d38fc28fce157cae2a665136db47a7c1554ab9fc7312c.md
@@ -0,0 +1,487 @@
+
+GCO 1
+Case Name:
+U.S. _ OPERATION LEAP YEAR
+Matter #:
+USAO#:
+18 U.S.C. § 208 is a criminal conflict of interest statute that prohibits me from
+participating personally and substantially in an official capacity in any particular
+matter in which I have a financial interest or in which certain persons or
+organizations whose interests are imputed to me have a financial interest if the
+particular matter will have a direct and predictable effect on that interest. This
+statute is in addition to any state bar professional conduct rules that may apply.
+I understand that personal and substantial participation may encompass
+activities ranging from merely advising on strategy to signing pleadings or
+trying a case.
+I understand that a particular matter includes both specific party matters,
+as well as more general matters that focus on an identifiable group (e.g., a
+policy determination that more resources will be spent pursuing
+institutions [. individuals committing health care fraud).
+I understand that financial interest is the potential for gain or loss as a
+result of governmental action and that such interests typically arise
+through ownership of stocks or sectored mutual funds, outside
+activities/employment, and spousal employment.
+I understand that those interests imputed to me include those of my
+spouse, minor children, general partners, any organization in which I
+serve as officer, director, trustee, general partner or employee, and any
+person or organization with whom I am negotiating for or have any
+arrangement concerning prospective employment.
+I understand that a direct and predictable effect occurs when there is a
+close causal relationship between the matter and my financial interest or
+the financial interest held by someone whose interests are imputed to me.
+The effect may be positive or negative. The magnitude of the gain or loss
+is immaterial.
+I certify that, to the best of my knowledge, this matter will not directly and
+predictably affect my financial interests or those interests imputed to me and my
+S.C. $ 208.
+105/23/06
+(Signed)
+(Printed Name)
+If you cannot certify to the above statement, do not take any action on the case
+and immediately contact your supervisor or your Ethics Advisor.
+
+5 C.F.R. § 2635.502, the impartiality rules, prohibits me from participating in a
+specific party matter that I know is likely to affect the financial interests of a
+member of my household or in which someone with whom I have a covered
+I understand that I have a covered relationship with the following:
+anyone with whom I have or seek a business, contractual, or financial relationship;
+a relative with whom I have a close personal relationship;
+anyone for whom my spouse, parent or dependent child serves or seeks to serve as
+an officer, director, trustee, general partner, agent, attorney, consultant, contractor,
+or employee;
+anyone for whom I worked in the last year as an officer, director, trustee, general
+partner, agent, attorney, consultant, contractor, or employee; and
+an organization in which I am an active member.
+I certify that, to the best of my knowledge, this matter is not likely to affect the
+financial interest of a member of my household, and no one with whom I have a
+covered relationship is or represents a party in this matter. Therefore, my
+(Printed Name)
+If you cannot certify to the above statement, do not take any action on the case
+and immediately contact vour supervisor or vour Ethics Advisor.
+I acknowledge my ongoing responsibility to be aware of the potential for conflict
+or the appearance of a conflict and to disclose any financial or personal interest as
+described above that would become involved in or be affected by the matter as
+(Siened)
+(Printed Name)
+T
+
+U.S. ATTORNEY'S OFFICE
+SOUTHERN DISTRICT OF FLORIDA
+CRIMINAL MATTER/CASE INITIATION FORM
+MAG NO.
+RELATED CASE NO.
+USAOID.
+COURT NO.
+PARTICIPANTS:
+8. OPERATION LEAP YEAR
+D.
+E.
+F.
+SUMMARY OF FACTS: Internet Solicitation - Interstate travel to have sex with a minor.
+PRIMARY CHARGE: 18 USC 2422(b), 2423(b)
+EST FINANCIAL MAGNITUDE:
+OFFENSE DATE FROM
+DATE TO
+PRIORITY: (Check one)
+N National Priority Only -
+D District Priority Only -
+* eth atiana not Discret Friority
+AGENCY INFORMATION:
+Who is the investigating agency?
+Agency Name:
+FBI
+Agency File Number:
+Agent Name and Telephone Number: S/A
+Second Agency Name:
+Second Agency's File Number:
+Second Ageney's Agent Name and Telephone Number:
+CHECK ALL THAT APPLY:
+This case involves TRIGGERLOCK Defendants)
+Offense discovered as results of (NICS) Brady
+This case involves Victim(s)
+Non Government Witnesses
+Forfeiture of Assets may be involved.
+Operation Name:
+OCDETF Number: FC/FLS/
+_ Special targets or subjects are involved:
+_ Members of the Medical Profession
+_No
+or both.
+cell
+Tax, Environmental, FDA and Civil Rights Cases)
+DOJ Division:
+DOJ File or Tax Division Number:_
+DOJ Attorney and Telephone Number:
+REVIEWED FOR ACCURACY & COMPLETENESS; ACCEPTED FOR CASE INITIATION
+ASSIGNED TO: AUSA
+SUPERVISORY AUSA SIGNATURE:
+DATE
+5/31/06
+USAO 001 (01CRM07a) REV.(08/12/02)
+
+
+PROGRAM CATEGORY (Check ALL categories that apply)
+(priorities are listed in parentheses)
+OFFICIAL CORRUPTION
+Fed. Corruption-Procurement (N-ALL)
+Fed. Corruption-Program (N-ALL)
+Fed. Corruption-Law Enforcement (N-ALL)
+Fed. Corruption-Other (N-ALL)
+State Corruption (N-High Officials)
+Local Corruption (N-High Officials)
+Other Official Corruption
+ORGANIZED CRIME
+Organized Crime-Traditional
+Organized Crime-Emerging Organizations
+(011)
+(012)
+(013)
+(014)
+(015)
+(016)
+(012)
+(020)
+(021)
+WHITE -COLOR CRIME/FRAUD
+Fed. Procurement Fraud (N=$25,000 +)
+Fed. Program Fraud (N-$25,000 +)
+Tax Fraud (N-DOJ Tax Authorized)
+OFinancial Institution Fraud
+Bankruptcy Fraud (N-$100,000 +)
+Advance Fee Schemes (N-$1000,000 + 10 or more victims]
+Other Fraud Against Business (Credit Card] Fraud
+Consumer Fraud (N-$100,000 + or 25 or more victims)
+Securities Fraud (N-$100,000 +)
+Commodities Fraud (N-$100,000 +)
+Other Investment Fraud (N-$100,000 +)
+Computer Fraud (N-ALL)
+Health Care Fraud (N-$25,000 + or bribes]
+Fraud Against Insurance Providers (N-$100K + /Arson-$250K +] (03H)
+Telemarketing Fraud
+Insider Fraud Against Insurance Providers (N-ALL)
+MEWA/MET (Multiple Employer Welfare Arrangements and
+(031)
+(032)
+(033)
+(036)
+(037)
+(038)
+(039)
+(03A)
+(03B)
+(03C)
+(03D)
+(03F)
+(03G)
+(038)
+(03J]
+(03K)
+Multiple Employer Trust Fraud (N-$100,000 +)
+Antitrust Violations-Airlines
+Antitrust Violations-Banking
+Antitrust Violations-Defense Procurement
+Antitrust Violations-Extraterritorial Application
+Antitrust Violations-Financial Markets other than banking
+Antitrust Violations-Other (if no specific code applies)
+Other White-Collar Crime/Fraud
+(03M)
+(03N)
+(03P)
+(03Q)
+(03R)
+(03E)
+(03Z)
+DRUGS
+Drug Dealing (N-CCE; RICO; DEA Class I violator;
+(040)
+movement of $100,000 +; level 38 drug amounts;
+large criminal drug trafficking organization]
+Simple Drug Possession (21 :00844 only]
+OCDETF (N-ALL)
+(045)
+(047)
+CIVIL RIGHTS
+Other (If no specific code applies)
+Law Enforcement
+Slavery / Involuntary Servitude
+Racial Violence
+Access to Clinic Entrances (18 U.S.C §248)
+Hate Crimes Sep 11, 2001 Terrorist Attacks on the U.S.
+(050)
+(0SD)
+(05E)
+(05F)
+(05G)
+(05H)
+OPERATION TRIGGERLOCK
+-
+Firearms cases
+_ Firearms cases (Brady Violation)
+(053)
+(054)
+18 U.S.C. 922(a)(6), 924(a)(1)(A), 1001
+IMMIGRATION
+Immigration & Nationality Act
+(055)
+CRIMES AGAINST GOVERNMENT PROPERTY
+DOMESTIC VIOLENCE
+Crimes Against Government Property
+GOVERNMENT REGULATORY OFFENSES
+Counterfeiting and forgery of U.S. Government Currency
+or Securities (N-ALL)
+Customs-Duty (N-$25,000/one or $500,000 more than one)
+(056)
+(061)
+(062)
+Customs-Currency
+(N-$25,000/one or $50,000/more than one]
+Energy Pricing & Related Fraud (N-$500,000 or illegal pricing)
+Health & Safety-Employees (N-life endangering)
+Copyright Violations (N-$500,000 + and three or more states
+Trafficking in Contraband Cigarettes (N-$100,000+)
+Wildlife Protection
+Marine Resources
+Energy Violations
+Environmental Crime
+Money Laundering/Structuring (Narcotics)
+Money Laundering/Structuring (Other)
+Other Government Regulatory Offenses
+INDIAN OFFENSES
+United States had jurisdiction
+INTERNAL SECURITY OFFENSE
+Internal Security
+ANTI-TERRORISM
+International Terrorism
+Domestic Terroriam (N-ALL)
+Terrorism Related Hoaxes
+Terrorist Financing
+OCDETF - Anti-Terrorism/Environment
+OCDETF - Anti-Terrorism/Identity Theft
+OCDETF - Anti-Terrorism/Immigration
+OCDETF - Anti-Terrorism/OCDETF Drugs
+OCDETF - Anti-Terrorism/ Non-OCDETF Drugs
+OCDETF - Anti-Terrorism/Violent Crime
+-
+OCDETF - Anti-Terrorism/ All Others
+OFFENSES INVOLVING THE ADMINISTRATION OF JUSTICE
+Offenses Involving the Administration of Justice
+INTERSTATE THEFT
+ITSP - 18 U.S.C. 659, 2117, 2314, etc....
+LABOR MANAGEMENT OFFENSE
+Union Official Corruption-Pension, Benefit Funds.
+Union Official Corruption-Bribery, Kickbacks (N-$5,000+)
+Other Labor/Management Offenses
+FUGITIVE CRIMES
+Escape, Failure to Appear, Bond Jump
+18 U.S.C. 1708, 1709, 495, 510, etc..
+BANK ROBBERY
+18 U.S.C. 0007(3), 0013, etc....
+ELECTION FRAUD
+18 U.S.C. 371, 911, 1341-1343
+PORNOGRAPHY/OBSCENITY
+18 U.S.C. 2251-2256 (Child Protection Act of 1984)
+18 U.S.C. 1461-1465 (Obscenity)
+THEFT OF GOVERNMENT PROPERTY
+U.S.C. 641, etc... Excluding white collar under 031-03Z
+18 U.3.C. 1461, 1465 or U.S.C. 22
+THER CRIMINAL PROSECUTION
+DOMESTO VIOLENCE
+All Others Not Covered Above
+_ 18 U.S.C. 2261-2262; 922(l(8), 922(s(9)
+REGION/DIVISION/SECTION CODES
+SOUTHERN REGION
+ECS
+ECONOMIC CRIMES SECTION
+ENS
+ENVIRONMENTAL CRIMES SECTION
+NAH HIDTA
+PCS
+PUBLIC CORRUPTION SECTION
+SMP MAJOR PROSECUTIONS SECTION
+SNS
+NARCOTICS SECTION
+CRD,
+CIVIL RIGHTS SECTION
+EXE
+EXECUTIVE DIVISION
+CENTRAL REGION
+- COLCENTRAL CRIT
+OCS ORGANIZED CRIME
+NORTHERN REGION
+N: (EVasquez\ Villafaria, A. Marie - Cases \Operation Leap Year| CASE INITIATION FORMS| Criminal Matter-Case Initiation Form. wpd
+(063)
+(064)
+(066)
+(069)
+(06A)
+(06B)
+(06C)
+(06D)
+(06E)
+(06F)
+(06G)
+(062)
+(065)
+(070)
+(071)
+(072)
+(073)
+(076)
+(07A)
+(07B)
+(07C)
+(07D)
+(07E)
+(07F)
+(07G)
+(074]
+(075)
+(OBA)
+(08B)
+(OBC)
+(0BZ)
+(081)
+(082)
+(083)
+(084)
+(085)
+(086)
+(087)
+(087)
+(088)
+(089)
+(090)
+(091)
+
+
+06/01/2006 17:10 FAX 5618021787
+USAO WPB FL
+$8฿
+TX REPORT
+*********************
+C001
+TRANSMISSION OK
+TX/RX NO
+CONNECTION TEL
+SUBADDRESS
+CONNECTION ID
+ST. TIME
+USAGE T
+PGS. SENT
+RESULT
+1699
+
+06/01 17:09
+00 49
+OK
+United States Attorney's Office
+Southern District of Florida
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401-6235
+DATE: June 1, 2006
+TO:
+, Docketing
+ORGANIZATION: USAO/Ft. Lauderdale
+FAX#:
+SUBJECT: In the Matter of: Operation Leap Year
+FROM:
+Legal Assistant
+, Extension 3032
+_ (Fax)
+NUMBER OF PAGES, INCLUDING THIS PAGE: 4
+COMMENTS: Please see attached case that needs a USAO/LIONS #.
+If you have any questions or concerns, please feel free to contact me.
+Thanks!
+
+
+United States Attorney's Office
+Southern District of Florida
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401-6235
+DATE: June 1, 2006
+TO:
+Docketing
+ORGANIZATION: USAO/Ft. Lauderdale
+FAX #:
+SUBJECT: In the Matter of: Operation Leap Year
+FROM:
+Legal Assistant
+, Extension 3032
+(Fax)
+NUMBER OF PAGES, INCLUDING THIS PAGE: 4
+COMMENTS: Please see attached case that needs a USAO/LIONS #.
+If you have any questions or concerns, please feel free to contact me.
+Thanks!
+Original document:
+To follow via regular mail
+To follow via Federal Express
+To follow via interagency mail
+To follow via hand delivery
+To follow via email
+_X Nothing to follow, FAX = original
+10.205,64,1131
+
+
+USAO ID NO.:
+SOUTHERN DISTRICT OF FLORIDA
+LIONS INPUT SHEET
+DISTRICT COURT NO.:
+ENTERED IN LIONS:
+AUSA:
+A. MARIE VILLAFAÑA
+OCDETE Operation Name:
+NAME OF CO-COUNSEL:
+OCDETF #: FC/ELS/
+U.S. I. OPERATION LEAP YEAR
+DEFENDANT NAME:
+Operation Leap Year
+DATE
+EVENT
+Declination (Give reason for declining matter/defendant on reverse)
+Complaint Filed (Magistrate No. _
+Arrest Warrant Issued
+Defendant Arrested
+BOND HEARING (Fill out type and amount on reverse)
+Indictment Returned/Information Filed or True Bill Returned (Circle One)
+Arraignment/Initial Appearance
+Change of Plea/ Defendant Pled Guilty before or during trial (Fill out charge disposition on reverse)
+[ex. Ct. 1 - 21:846; Ct. 3 - 21:841; Ct. 2/4/5 Dismissed]
+Defendant became a Fugitive (Indicate event for which defendant did not appear on reverse.)
+Pretrial Diversion Commenced or Completed (Circle One)
+Superseding Indictment/Information Filed (Circle One)
+Jury Trial Commenced
+Jury Trial Completed (Fill out charge Disposition for each defendant on reverse) [ex. Ct. 1 - 21:846; C
+3 - 21:841; Ct. 2/4/5 Dismissed]
+Bench Trial Commenced
+Bench Trial Completed (Fill out charge disposition for each defendant on reverse)[ex. Ct. 1 - 21:846; Ct.
+3 - 21:841: Ct. 2/4/5 Dismissed]
+Defendant Acquitted or Mistrial/Hung Jury
+Rule 20 Out (Indicate Transfer District)
+Sentencing (Describe on reverse) [If an OCDETF Defendant, complete questions on reverse)
+Other (Explain on reverse)
+
+Rev. 05/03
+
+
+Remarks:
+Please "X" all that apply to the Sentencing for the OCDETF defendant:
+O Defendant received sentencing guidelines enhancement as an organizer, leader, manager or supervisor
+1 Defendant recommended for drug/alcohol treatment progra
+] Defendant is a Consolidated Priority Organization Target (CPOT) or part of the command structure of a CPO
+• Defendant is connected to a CPOT
+• Defendant is a regional priority target or part of the command structure of a regional priority target
+• Defendant is connected to a regional priority target
+• Defendant is a fugitive
+
+
+
+PALM BEACH POLICE DEPARTMENT
+CRIMINAL INVESTIGATIONS UNIT
+POLICE
+345 S. COUNTY ROAD
+PALM BEACH, FLORIDA 33480-4443
+www.palmbeachpoilee.com
+DIRECT -
+OFFICE: (561) 898-5.
+MAIN: I
+544-161 638-0491
diff --git a/vision-fixhub/ds9-unparsed-05/a2cb41bcf64e515d7a5d38fc28fce157cae2a665136db47a7c1554ab9fc7312c.receipt.json b/vision-fixhub/ds9-unparsed-05/a2cb41bcf64e515d7a5d38fc28fce157cae2a665136db47a7c1554ab9fc7312c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4bc6560636792e4a5db8e456cf9181f2141f3030
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a2cb41bcf64e515d7a5d38fc28fce157cae2a665136db47a7c1554ab9fc7312c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -140,
+  "dataset": "marble-joined",
+  "doc_id": "a2cb41bcf64e515d7a5d38fc28fce157cae2a665136db47a7c1554ab9fc7312c",
+  "engine": "marble-apple-vision",
+  "event_count": 12,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "47039ccf0db66282663fb796af228b92313c4e5e7d0688de59992cae6d403880",
+  "output_sha256": "33ce8d23eae323f6341c50c90f4324d6ef81927514f244e9b688e7c1cd75a19f",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a2d9fc6117c53195b293d403eef539da708d8db849464dfe07f68763c34cfb93.md b/vision-fixhub/ds9-unparsed-05/a2d9fc6117c53195b293d403eef539da708d8db849464dfe07f68763c34cfb93.md
new file mode 100644
index 0000000000000000000000000000000000000000..b9fb7ee5f250eb01476ac60dc7b970f96bf0186f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a2d9fc6117c53195b293d403eef539da708d8db849464dfe07f68763c34cfb93.md
@@ -0,0 +1,47 @@
+OLY-33
+
+
+TO: Thomas Rofrano
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+;* •
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-33
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTIS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 13, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring, with you the following document(s) or objects):
+All documents referring or relating to Jeffrey Epstein, including but not limited to billing statements,
+record of payments, appointment books, treatment notes, and correspondence.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+vour annenrance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+DATE:
+(BY) DEPUTY CLERK
+March 2, 2007
+This subpoena is issued upon application
+of the United States of America
+Name Address and Phone Number of Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach EL 33401-6235
+x3047
+Fax
+*If not applicable, enter "none."
+To be used in lieu of A0110
+FORM ORD-227
+JAN.86
diff --git a/vision-fixhub/ds9-unparsed-05/a2d9fc6117c53195b293d403eef539da708d8db849464dfe07f68763c34cfb93.receipt.json b/vision-fixhub/ds9-unparsed-05/a2d9fc6117c53195b293d403eef539da708d8db849464dfe07f68763c34cfb93.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e7a623bf0e84319a27c32bfcc8ad1e3c9b88cc39
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a2d9fc6117c53195b293d403eef539da708d8db849464dfe07f68763c34cfb93.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "a2d9fc6117c53195b293d403eef539da708d8db849464dfe07f68763c34cfb93",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "7baee518cdb1314d10ef567b69d6697cf912493d9d94a6d287f92093a7151aa7",
+  "output_sha256": "7fb842570acb444a6e231e02063b62b3dff525eb532ec67d88e6ad8700de4bf0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a2e15e89192cebf19358b01bd64225d344ba5f21583158a9df6b7463fe5bbf1e.md b/vision-fixhub/ds9-unparsed-05/a2e15e89192cebf19358b01bd64225d344ba5f21583158a9df6b7463fe5bbf1e.md
new file mode 100644
index 0000000000000000000000000000000000000000..49d3a305b67413442f10bbe32b71153d588b80d8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a2e15e89192cebf19358b01bd64225d344ba5f21583158a9df6b7463fe5bbf1e.md
@@ -0,0 +1,1746 @@
+2 Append pes
+Mayll
+To be Argued By:
+JAY P. LEFKOWITZ
+New York County Clerk's Index No. 30129/2010
+New Hark Supreme Court
+APPELLATE DIVISION-FIRST DEPARTMENT
+PEOPLE OF THE STATE OF NEW YORK,
+-against-
+JEFFREY E. EPSTEIN,
+Respondent,
+Defendant-Appellant.
+BRIEF FOR DEFENDANT-APPELLANT
+JAY P. LEPKOWITZ
+SANDRA LYNN MUSUMECI
+KIRKLAND & ELLIS LLP
+601 Lexington Avenue
+New York, New York 10022
+Attorneys for Defendant-Appellant
+REPRODUCED ON RECYCLED PAPER
+
+
+
+
+TABLE OF CONTENTS
+PRELIMINARY STATEMENT ........
+QUESTIONS PRESENTED....
+STATEMENT OF FACTS........
+1.
+II.
+The Underlying Offense....
+Sex Offender Registration...
+III.
+The Board's Recommendation
+IV. Pre-Hearing Investigation By the District Attorney
+V. SORA Hearing ..
+ARGUMENT..
+II.
+THE COURT'S LEVEL 3 DETERMINATION IS NOT
+SUPPORTED BY CLEAR AND CONVINCING EVIDENCE AS
+REQUIRED BY SORA AND AS A MATTER OF FEDERAL
+CONSTITUTIONAL LAW....
+A. The People's Investigation Revealed That The Board's
+Recommendation Could Not Be Proven By Clear and
+Convincing Evidence......
+B.
+The Court Improperly Relied on the Board's Recommendation
+Where the Facts Cited Therein Were Disputed and No Further
+Evidence Was Presented. ...
+C.
+Determining Appellant To Be a Level 3 Offender Based on
+Factors That Were Not Proven by Clear and Convincing
+Evidence Violated Appellant's Federal Due Process Rights.
+THE COURT BASED ITS LEVEL 3 DETERMINATION UPON
+IMPROPER CONSIDERATIONS.
+A.
+The Court Improperly Assessed Points Against Appellant for
+Conduct That Is Not Scoreable Under SORA.
+1
+2
+3
+4
+6
+..7
+11
+12
+.16
+.17
+20
+25
+.32
+36
+.36
+i
+
+
+
+
+B. The Court Improperly Allowed Personal Feelings and Matters
+Outside the Record to Influence Its SORA Determination.
+II. THE COURT'S ORDER DOES NOT COMPLY WITH THE
+MANDATES OF SORA AND CONSTITUTIONAL DUE
+PROCESS AND MUST BE VACATED.
+CONCLUSION.
+38
+.45
+49
+ii
+
+
+
+
+TABLE OF AUTHORITIES
+Cases
+Doe v. Pataki,
+3 F. Supp. 2d 456 (S.D.N.Y. 1998)
+32, 33, 35, 36
+E.B. v. Verniero,
+119 F.3d 1077 (3d Cir. 1997),
+cert. denied, 522 U.S. 1109 (1998).
+34, 35
+Fresh Del Monte Produce N. V. v. Eastbrook Caribe,
+40 A.D.3d 415 (1st Dep't 2007)..
+43
+Goldberg v. Kelly,
+397 U.S. 254 (1970)
+48
+Matthews v. Eldridge,
+424 U.S. 319 (1976).
+32
+New York State Bd. of Sex Exam'rs v. Ransom,
+249 A.D.2d 891 (4th Dep't 1998) ..
+18
+People v. Arotin,
+19 A.D.3d 845 (3d Dep't 2005).
+.24
+People v. Boncic,
+15 Misc. 3d 1139(A), 841 N.Y.S.2d 281 (Sup. Ct. N.Y. Cty. 2007)
+.31
+People v. Brooks,
+308 A.D.2d 99 (2d Dep't 2003)..
+...34
+People v. Coffey,
+45 A.D.3d 658 (2d Dep't 2007)..
+24
+People v. Curthoys,
+77 A.D.3d 1215 (3d Dep't 2010)...
+27
+People v. David W.,
+95 N.Y.2d 130 (2000)
+...32
+iii
+
+
+
+
+- -
+People v. Dominie,
+42 A.D.3d 589 (3d Dep't 2007)
+People v. Donk,
+39 A.D.3d 1268 (4th Dep't 2007) ….
+People v. Ferguson,
+53 A.D.3d 571 (2d Dep't 2008)....
+People v. Gilbert,
+78 A.D.3d 1584 (4th Dep't 2010) ..
+People v. Jimenez,
+178 Misc. 2d 319, 679 N.Y.S.2d 510 (Sup. Ct. Kings Cty. 1998)
+People v. Johnson,
+11 N.Y.3d 416 (2008)
+People v. Jordan,
+31 A.D.3d 1196 (4th Dep't 2006) ..
+People v. Judson,
+50 A.D.3d 1242 (3d Dep't 2008).
+People v. Mabee,
+69 A.D.3d 820 (2d Dep't 2010)...
+People v. Mingo,
+12 N.Y.3d 563 (2009)
+People v. Miranda,
+24 A.D.3d 909 (3d Dep't 2005).
+People v. Rampino,
+55 A.D.3d 348 (1st Dep't 2008)....
+People v. Redcross,
+54 A.D.3d 1116 (3d Dep't 2008)....
+People v. Sherard,
+73 A.D.3d 537 (1st Dep't 2010).
+.19
+31
+..39
+.47
+18
+39
+27
+27
+26
+47
+43
+..31
+.43
+iv
+
+
+
+
+People v. Smith,
+66 A.D.3d 981 (2d Dep't 2009).
+People v. Strong,
+77 A.D.3d 717 (2d Dep't 2010).
+People v. Wasley,
+73 A.D.3d 1400 (3d Dep't 2010)....
+Rossi v. Hartford Fire Ins. Co.,
+103 A.D.2d 771 (2d Dep't 1984).
+10m. 2 43 1st Dept 1989).
+Statutes
+14 V.I.C. § 1722(b)
+14 V.I.C. § 1724(d)
+14 V.I.C. § 1724(e)
+Correction Law § 168-a(2)
+Correction Law § 168-a(2)(a)..
+Correction Law § 168-a(2)(a)(1)
+Correction Law § 168-a(2)(d) (ii)
+Correction Law § 168-a(7)
+Correction Law § 168-k
+Correction Law § 168-k(2).
+Correction Law § 168-1(6)
+Correction Law § 168-1(6)(c)
+• Correction Law § 168-n
+.24
+47
+27
+.19
+19
+7
+7
+7
+9
+5,9
+. 3, 37
+9,17
+45
+. 17,45
+... passim
+..8
+..8
+.45
+V
+
+
+
+
+Correction Law § 168-n(2)
+CPLR 5513
+CPLR 5515
+Fla. Stat. § 775.21
+Fla. Stat. § 794.05(1)
+Fla. Stat. § 796.03
+Fla. Stat. § 796.07(2)(f)
+Fla. Stat. § 796.07(4)(c)
+Fla. Stat. § 800.04(5)
+Fla. Stat. § 943.0435
+N.Y. Penal Law § 230.25
+16, 18
+16
+.. 16
+6
+21,28
+1,4, 6
+.1
+4
+21,28
+4, 5, 6, 9
+9
+Rules
+Prince, Richardson on Evidence § 3-205 (Farrell 11th ed.).
+19
+Sex Offender Registration Act: Risk Assessment Guidelines and
+Commentary, Commentary (2006) .
+22, 31, 41
+vi
+
+
+
+
+--
+PRELIMINARY STATEMENT
+Appellant Jeffrey E. Epstein seeks to vacate the final decision and
+order of the New York Supreme Court, Criminal Term, New York
+County,
+determining him to be a Level 3 sex offender, without
+designation, under New York's Sexual Offender Registration Act
+(SORA), Correction Law Article 6-C, based on a 2008 Florida conviction
+by plea of guilty to Procuring a Person Under 18 for Prostitution, Fla.
+Stat. § 796.03, and Felony Solicitation of Prostitution, Fla. Stat.
+§ 796.07(2)(f), for which Appellant was sentenced to consecutive terms
+of 12 months and 6 months incarceration, followed by 12 months of
+Community Control. (Pickholz, J. at SORA hearing). Appellant seeks
+to vacate the Order because the Court's risk level determination was
+not supported by clear and convincing evidence, was based on improper
+considerations, and was made without affording the parties an
+opportunity to present evidence concerning disputed relevant issues.
+More specifically, in making its determination, the Court summarily
+adopted the recommendation of the Board of Examiners of Sex
+Offenders (the "Board"), notwithstanding the position of the District
+Attorney's Office that the Board's recommendation was legally infirm
+1
+
+
+
+
+and not supported by provable evidence. Additionally, the Court issued
+a facially defective Order that fails to set forth findings of fact and
+conclusions of law, as required by law. Accordingly, the Order
+determining Appellant to be a Level 3 offender should be vacated, and
+Appellant's risk level should be recalculated based solely on those
+factors that may be properly considered under SORA and which are
+proven by clear and convincing evidence.
+QUESTIONS PRESENTED
+May the Court determine Appellant's risk level under SORA
+based on factors that are not proven by clear and convincing evidence?
+2.
+Is the Court entitled to adopt the Board's recommendation in
+full, without hearing any further evidence, where Appellant disputes
+numerous unprosecuted allegations contained therein and the District
+Attorney, as representative of the State, disclaims the Board's
+recommendation
+as unreliable, based on allegations that were
+determined to be not prosecutable, and not provable by clear and
+convincing evidence?
+In calculating Appellant's risk level under SORA, may the
+Court score points for consensual prostitution-related conduct involving
+-
+2
+
+
+
+
+women who were seventeen years of age or over, particularly where
+SORA provides that such conduct is only registerable where the person
+patronized "is in fact less than seventeen years of age," Correction Law
+§ 168-a(2)(a) (i)?
+4.
+Where the Court's Order assigning Appellant a risk level of 3
+under SORA does not include any findings of fact or conclusions of law
+to support a Level 3 determination, must that Order be vacated?
+STATEMENT OF FACTS
+Defendant-Appellant Jeffrey E. Epstein is a 58-year old financial
+advisor and philanthropist whose primary residence is in the U.S.
+Virgin Islands and who also maintains vacation properties in New York
+and Florida. See A.53 (Letter of M. Weinberg of Aug. 16, 2010).1
+Appellant does not live in New York, and since the commission of the
+Florida offense that forms the basis of this matter, he has not stayed at
+his New York property for periods of ten days or more at a time. See
+A.53 (Letter of M. Weinberg of Aug. 16, 2010); A.87:21-25, 88:21-
+89:3
+_(Tr.). 2
+1
+References to the Record on appeal are denoted herein as "A." followed by the
+applicable Appendix number.
+References to the transcript of the January 18, 2011 SORA hearing are
+denoted herein as "Tr." followed by the applicable page and line citation.
+3
+
+
+
+
+",
+-
+I.
+The Underlying Offense
+On June 30, 2008, Appellant pleaded guilty in the Circuit Court
+for Palm Beach County, Florida under an Information to the charge of
+Procuring a Person Under 18 for Prostitution, Fla. Stat. § 796.03, an
+offense which required him to register under Florida's sexual offender
+registration statute, Fla. Stat. § 943.0435. See A.31 (Information for
+Procuring Person Under 18 for Prostitution, dated June 26, 2008); A.32
+(Guilty Plea, dated June 30, 2008). This single registerable charge was
+brought in connection with a consensual, commercial arrangement in
+which Appellant received massages and engaged in sexual conduct with
+A.D., a young woman who was over the age of consent under New York
+law but just under 18 when the offense in the Information occurred
+back in 2005. See A.53 (Letter from M. Weinberg, dated Aug. 16, 2010,
+at 1, 3). Appellant concurrently pleaded guilty to an Indictment
+charging him with one count of Felony Solicitation for Prostitution, Fla.
+Stat. §§ 796.07(2)(f), (4)(c) -- a solicitation offense which does not include
+any elements of sexual contact with underage women and which is not
+registerable under either Florida or New York law. See A.26 (2006
+Grand Jury Indictment of Felony Solicitation of Prostitution); A.32
+4
+
+
+
+
+(Guilty Plea, dated June 30, 2008); Fla. Stat. § 943.0435; Correction
+. Law § 168-a(2)(a).
+Despite an extensive investigation by Florida
+prosecutors regarding various other complaints alleged against him and
+reported in police paperwork, Appellant was never charged with any
+other crimes or prosecuted on allegations made by any other
+complainants.
+See A.26 (2006 Grand Jury Indictment of Felony
+Solicitation of Prostitution); A.31 (Information for Procuring Person
+Under 18 for Prostitution, dated June 26, 2008); A.83:23-84:6, 85:19-
+86:1, 90:16-91:15, 95:14-18 (Tr.).
+As a result of his two concurrent Florida convictions -- the first
+and only criminal convictions of his life -. Appellant was sentenced to
+consecutive terms of 12 months and 6 months incarceration in a Palm
+Beach County Detention Facility, followed by 12 months of Community
+Control supervision. See A.32 (Guilty Plea, dated June 30, 2008); A.34
+(Sentence, dated Jun. 30, 2008). Appellant satisfactorily served 13
+months of incarceration (during which time he was granted permission
+to participate in the Sheriff's work release program) and completed a
+subsequent period of 12 months Community Control (during which the
+. Court trusted him, for business purposes, to travel outside of Florida
+5
+
+
+
+
+with prior notice and approval by his supervising probation officer
+without incident. See A.49 (Letter from Florida Department of
+Corrections, dated Jul. 21, 2010); A.50 (Letter from Palm Beach
+Sheriff's Office, dated Aug. 12, 2010); A.51 (Letter from J. Goldberger,
+dated Aug. 12, 2010); A.48 (Order Granting Motion for Travel, dated
+Dec. 18, 2009); A.53 (Letter from M. Weinberg, dated Aug. 16, 2010, at
+4). Appellant has had no subsequent instances of misconduct of any
+kind. See A.53 (Letter from M. Weinberg, dated Aug. 16, 2010, at 1).
+II. Sex Offender Registration
+As required under Florida law in connection with his conviction
+for Procuring a Person Under 18 for Prostitution, Fla. Stat. § 796.03,
+Appellant registered as a sex offender with Florida authorities and was
+designated at the lowest level under that state's sex offender
+registration act. See A.88:6-15 (Tr.); see also A.51 (Letter from J.
+Goldberger, dated Aug. 12, 2010); Fla. Stat. §§ 775.21, 943.0435.
+Appellant also registered in his home jurisdiction of the U.S. Virgin
+Islands (where Appellant maintains his primary residence and actually
+lives), where authorities reviewed Appellant's Florida offenses and
+6
+
+
+
+
+determined that he is only subject to that jurisdiction's lowest reporting
+: obligations. See A.88:1-5 (Tr.); see also 14 V.I.C. §8 1722(b), 1724(d), (e).
+Although he does not actually reside in New York, before the
+completion of his term of Community Control, Appellant notified the
+New York State Division of Criminal Justice Services ("the Division") of
+his registerable Florida conviction and his ownership of a secondary
+residence in New York. See A.88:21-24 (Tr.).
+Since May 2010,
+Appellant has been registered with the Sexual Offender Monitoring
+Unit (SOMU) of the New York Police Department. See A.88:21-89:3
+(Tr.).
+II. The Board's Recommendation
+On or about August 26, 2010, Appellant received notice that a
+SORA hearing had been scheduled to determine a risk assessment level,
+accompanied by a copy of the recommendation of the Board. See A.67
+(Letter
+from
+Supreme
+Court,
+dated
+Aug. 26, 2010); A.65
+(Recommendation of Board of Examiners of Sex Offenders ("Board
+Recommendation").). In stark contrast to the other jurisdictions to have
+considered Appellant's Florida convictions (including Florida), the
+Board recommended that Appellant be assigned the highest risk level ..
+7
+
+
+
+
+Level 3, representing a high risk of repeat offense -- without further
+designation.
+See A.67 (Letter from Supreme Court, dated Aug. 26,
+2010); A.65 (Board Recommendation); see also Correction Law § 168-
+1(6) (c).
+The Board's recommendation included a Risk Assessment
+Instrument (RAI) that improperly calculated a total risk factor score of
+130. See A.65 (Board Recommendation). Almost all of the points scored
+by the Board were based on "Current Offense" factors,4 including: 10
+points for "Use of Violence" (forcible compulsion); 25 points for "Sexual
+Contact with Victim" (sexual intercourse and deviate sexual
+intercourse); 30 points for "Number of Victims" (3 or more); 20 points for
+"Duration of Offense Conduct with Victim" (continuing course of sexual
+misconduct); and 20 points for "Age of Victim" (11 through 16). See A.65
+(Board Recommendation). The Board's RAI did not assign Appellant
+SORA requires the Board to recommend an offender's notification level of 1,
+2, or 3, pursuant to Correction Law § 168-1(6), and to recommend whether any
+designations defined in Correction Law § 168-a(7) apply. See Correction Law
+The Board also assessed Appellant 5 points for "Criminal History," even
+though the Board itself noted that it was assessing points "absent specific
+information." See A.65 (Board Recommendation). Appellant submits that this
+scoring is unsupported by the Record.
+8
+
+
+
+
+any points under the "Post-Offense Behavior" and "Release
+• Environment" categories. See A.65 (Board Recommendation).
+In its "Case Summary," the Board noted that Appellant was
+convicted of just two Florida sex offenses: (1) Procuring a Person Under
+18 for Prostitution, and (2) Felony Solicitation of Prostitution.° See A.65
+(Board Recommendation). The Board then aggregated into just over a
+single page a host of uncharged allegations made by "numerous
+females," including "female participants [who] were age 18 or older,"
+regarding "massages and unlawful sexual activity" that allegedly took
+place at Appellant's Florida residence.
+See A.65 (Board
+Recommendation). The case summary referred to "vaginal intercourse"
+and various other forms of sexual contact allegedly taking place without
+connecting specific females to such allegations, and more significantly,
+without identifying the age of the participants -- some of whom the
+Board noted were "age 18 or older" -- specifically at the time of such
+Only one of these charges .. the procurement charge --. is registerable under
+SORA, and that charge is registerable under SORA only because it is registerable in
+Florida. See Correction Law § 168-a(2)(d)(ii). (Notably, the New York cognate of
+this offense, Promoting Prostitution in the Third Degree, N.Y. Penal Law § 230.25,
+is not itself a registerable offense under SORA. See Correction Law § 168-a(2).) The
+charge of Felony Solicitation of Prostitution, Fla. Stat. § 796.07(2)(f), (4)(c) -- which
+does not include any age-related elements and pertains solely to consensual
+commercial conduct -- is not a registerable offense under either Florida or New York
+law. See Fla. Stat. § 943.0435; Correction Law § 168-a(2)(a).
+9
+
+
+
+
+alleged conduct.
+See A.65 (Board Recommendation).
+Although
+Appellant was only convicted of two prostitution-related offenses and
+was neither charged with nor convicted of any rape, sexual abuse, or
+violent offenses, the case summary highlighted hearsay-based claims
+in police paperwork -- namely a probable cause affidavit signed by a
+Palm Beach Police detective that did not result in any of the charges
+sought - involving alleged sexual abuse of underage girls and an
+alleged forcible rape (which claims were found by the Florida
+prosecutors to be unreliable to support charges against Appellant), and
+assessed points against Appellant based on these unprosecuted
+allegations. See A.65 (Board Recommendation).
+The Board recognized Appellant's conduct on Community Control
+as satisfactory and noted that he has no history of substance abuse. See
+A.65 (Board Recommendation). The Board also credited Appellant with
+accepting
+responsibility
+for his
+actions.
+See A.65 (Board
+Recommendation).
+6
+The only registerable charge for which Appellant was prosecuted and
+convicted pertained to consensual, commercial, non-violent interaction with one
+woman, A.D., who was 17 years old (and therefore over the age of consent in New
+York but not in Florida) at the time of the relevant conduct. See A.31 (Information
+for Procuring Person Under 18 for Prostitution, dated June 26, 2008); A.53 (Letter
+of M. Weinberg of Aug. 16, 2010, at 1, 3); A.91:20-92:7 (Tr.).
+10
+
+
+
+
+IV. Pre-Hearing Investigation By the District Attorney
+The SORA hearing, originally scheduled for September 15, 2010,
+was adjourned on consent of the parties until January 18, 2011 to
+provide the New York District Attorney ("the People"), which
+represented the State of New York at the SORA hearing, an
+opportunity to investigate Appellant's Florida convictions and assess
+the validity of the Board's recommendation. See A.81 (Handwritten
+Notations on Court Jacket); A.89:22-90:8 (Tr.). As part of their
+investigation, the People were in contact with members of the Palm
+Beach County State's Attorney's Office to understand the investigation
+and prosecution of the allegations at issue in this SORA matter. See
+A.83:14-84:19 (Tr.).
+Based on these interactions with Florida
+prosecutors, the People determined that they could not rely on the
+Board's recommendation and the underlying probable cause affidavit
+(which the Florida prosecutors determined not to be reliable, and which
+therefore certainly could not satisfy the heightened standard of clear
+and convincing evidence), and would score Appellant based only on the
+conduct for which he was actually prosecuted, and not on the
+11
+
+
+
+
+unprosecuted allegations in the probable cause affidavit cited by the
+: Board. See A.83:14-84:19 (Tr.).
+Although the People presented Appellant a new SORA risk
+assessment instrument (RAI) immediately before the SORA hearing
+itself, scoring Appellant as a Level 1, the People apparently did not
+present their proposed alternative RAI or any other written submission
+setting forth their departure from the Board's recommendation to the
+Court, as no such statement is in the Court's file.
+See Appendix
+generally.
+V. SORA Hearing
+On January 18, 2011, a SORA hearing was conducted in New
+York Supreme Court, Criminal Term, New York County, Part 66 before
+Hon. Ruth Pickholz.
+See A.81 (Handwritten Notations on Court
+Jacket); A.82 (Tr. generally). At the hearing, the People made a record
+that based on their investigation and contact with the Florida
+authorities who handled Appellant's prosecution, the probable cause
+affidavit underlying the Board's recommendation could not be relied
+upon. See A.83:14-18 (Tr.). Specifically, the People informed the Court
+that many of the women referenced as complainants in the police
+12
+
+
+
+
+affidavit were not cooperative with Florida prosecutors, and
+accordingly, the Florida authorities chose not to prosecute any
+allegations other than those reflected by the two offenses to which
+Appellant ultimately pleaded guilty. See A.84:2-6, 14-19 (Tr.). The
+People further noted that in light of Florida's decision not to prosecute
+the majority of the allegations in the affidavit, (and under the SORA
+statute and guidelines), only the conduct pertaining to the sole
+registerable crime for which Appellant was charged and to which he
+pleaded - Procuring a Person Under 18 for Prostitution, involving a
+single complainant -. could be proven and should be considered in
+evaluating Appellant's SORA score. See A.85:11-16, 85:24-86:1 (Tr.).
+Counsel for Appellant corroborated the record made by the People
+that the Florida Assistant State Attorney who prosecuted Appellant
+determined, after a full investigation, that there were "no victims" and
+that the only crime that could be presented to the grand jury was the
+single solicitation offense to which Appellant pleaded guilty. See
+A.89:22-90:21, 95:12-18 (Tr.).
+Appellant disputed many of the
+allegations contained in the Board's case summary, both with respect to
+specific facts (such as the suggestion of any forcible compulsion and the
+13
+
+
+
+
+• -
+exact age of complainant A.D. at the time of specific conduct) and more
+broadly by noting that the Board's recommendation was based on police
+documentation that was not credible and that contained hearsay
+allegations that the lead sex crimes prosecutor in Florida decided not to
+prosecute. See A.90:9-12, 92:13-21, 95:12-18 (Tr.). Further, Appellant
+advised the Court that there was sworn testimony from many of the
+women referenced in the police paperwork and the Board's case
+summary which expressly disclaimed allegations attributed to them.
+See A.95:19-23 (Tr.).
+Notwithstanding the clear record that facts underlying the
+Board's recommendation were disputed, the Court announced that it
+was relying on the Board's case summary and adopting the Board's
+calculation and recommendation in full. See A.93:21, 94:6-95:9 (Tr.).
+The Court did not conduct any factual hearing as to specific claims for
+which points were assessed. See A.82 (Tr. generally). The Court scored
+Appellant for factors such as number of victims, use of violence / forcible
+compulsion, duration of offense, and sexual intercourse, based on
+allegations that the People -- as the party bearing the burden of proof --
+asserted on the record could not be supported by clear and convincing
+14
+
+
+
+
+evidence. See A.94:7-95:9 (Tr.). Despite the legal and factual position of
+the People that the Board's recommendation could not be relied on and
+that allegations concerning all complainants but the one in the
+Information could not be proven, the Court ruled that it was relying on
+the Board's recommendation in full and adjudicating Appellant a Level
+3 sex offender with no additional designation. See A.93:21, 93:25-94:3
+(Tr.).
+On the record, the Court recited the scoring of the Board in
+abbreviated form, without identifying any particular facts or allegations
+to support each factor. See A.94:6-95:9 (Tr.). In its written Order, the
+Court indicated a final risk level determination of Level 3 by merely
+circling a pre-printed form. See A.4 (Order Appealed From, dated Jan.
+18, 2011). The Court failed to articulate any findings of fact or
+conclusions of law, as required under SORA. See A.4 (Order Appealed
+From, dated Jan. 18, 2011); A.82 (Tr. generally).
+Appellant was served with a copy of the Court's Order on or about
+January 19, 2011. See A.78 (Letter from Supreme Court, dated Jan. 19,
+2011). Appellant served a Notice of Entry of the Court's Order on
+February 9, 2011, and on the same day filed a Notice of Appeal to
+15
+
+
+
+
+invoke this Court's jurisdiction. See A.4 (Order of Appealed From,
+dated Jan. 18, 2011, with Notice of Entry); A.3 (Appellant's Notice of
+Appeal, dated Feb. 9, 2011). Appellant now respectfully files this
+appeal as of right, pursuant to Correction Law §§ 168-k(2), 168-n(2) and
+CPLR 5513, 5515, to vacate the legally erroneous and factually
+unsupportable Order and re-calculate Appellant's SORA risk level
+based solely on those factors that may properly be considered under
+SORA and that have been proven by clear and convincing evidence.?
+ARGUMENT
+The Court's reliance on allegations that were flatly rejected by the
+Florida prosecutors who investigated them and which, by the People's
+own admission, could not be proven by clear and convincing evidence,
+constitutes clear legal error and a violation of Appellant's due process
+rights, warranting vacatur of the Court's Order. Specifically, the Court
+calculated a risk assessment score based on untrustworthy double and
+7
+Appellant asks this Court to render its own findings of fact and conclusions of
+Landispated facts in the Record proven by clean appropiate endantion or ne
+Appellant's conviction. To the extent this Court is unable to issue findings of fact
+and conclusions of law based on the present Record, Appellant seeks remand to the
+lower court before a different Justice for a recalculation in which the parties are
+afforded an opportunity to present evidence regarding contested relevant issues, if
+necessary. See Section II(B), infra.
+16
+
+
+
+
+triple hearsay allegations cited in the Board's recommendation that
+were squarely rejected as a basis for state prosecution in Florida, were
+disputed by Appellant, and did not constitute registerable conduct
+under New York law, all in violation of SORA and its guidelines and
+Appellant's constitutionally guaranteed right to due process. Moreover,
+the Court abused its discretion and failed to abide by the guidelines and
+mandates set forth in SORA, including by improperly considering
+factors outside the record and issuing a legally deficient Order that fails
+to set forth the findings of fact and conclusions of law on which the
+Court's determination was based.
+THE COURT'S LEVEL 3 DETERMINATION IS NOT
+SUPPORTED BY CLEAR AND CONVINCING EVIDENCE
+AS REQUIRED BY SORA AND AS A MATTER OF
+FEDERAL CONSTITUTIONAL LAW.
+The SORA statute sets forth a formal procedure to determine the
+required level of notification for those individuals convicted of a
+qualifying out-of-state offense, based on a systematic assessment of the
+risk of reoffense posed by the particular individual. See Correction Law
+§ 168-k. After the Board generates an initial recommendation based on
+Appellant's Florida conviction for Procuring a Person Under 18 for
+rostitution is a qualifying "sex offense" under SORA solely pursuant to Correctio
+aw $ 168-a(2)(d)(ii), which makes an out-of-state offense registerable under SOR
+if that particular offense is registerable in the jurisdiction where it was committed.
+17
+
+
+
+
+its review of the out-of-state offense and other factors, the Court has the
+duty of conducting a hearing to consider the Board's recommendation
+and other evidence presented in order to reach its own independent
+determination of an offender's SORA registration level. See Correction
+Law §§ 168-k(2), 168-n(2); People v. Johnson, 11 N.Y.3d 416, 421 (2008)
+(holding that "the Board's duty is to make a recommendation to the
+sentencing court... and the court, applying a clear and convincing
+evidence standard, is to make its determination after considering that
+recommendation, and any other materials properly before it") (internal
+statutory citation omitted); see also New York State Bd. of Sex Exam'rs
+v. Ransom, 249 A.D.2d 891, 891-92 (4th Dep't 1998) (holding the "Board
+... serves only in an advisory capacity ... similar to the role served by a
+probation department in submitting a sentencing recommendation.");
+see also People V. Jimenez, 178 Misc. 2d 319, 322-23, 679 N.Y.S.2d 510,
+513 (Sup. Ct. Kings Cty. 1998) (observing "the Legislature did not
+intend to place upon the criminal courts of this State a burden to act
+merely as a regulatory body to confirm the determination of the Board,"
+and noting that a SORA hearing is a "judicial proceeding in which the
+court must make a de novo determination."). Yet the Court's authority
+18
+
+
+
+
+to determine a SORA risk level is not unfettered; instead, SORA
+requires the Court to determine an offender's risk level based on an
+evaluation of evidence in accordance with the guidelines promulgated
+by the Board. See Correction Law
+§$ 168-k(2), 168-n(2) ("It shall be
+the duty of the court applying the guidelines established [by the Board
+under SORA] to determine the level of notification...."). Moreover, the
+Court's determination must be wholly based on facts that are provable
+by clear and convincing evidence. See Correction Law §§ 168-k(2), 168-
+n(2).
+Under New York law, "clear and convincing evidence" is defined
+as evidence that makes it 'highly probable' that the alleged activity
+actually occurred." People v. Dominie, 42 A.D.3d 589, 590 (3d Dep't
+2007); see also Prince, Richardson on Evidence § 3-205, at 104 (Farrell
+11th ed.). Clear and convincing evidence is "a higher, more demanding
+standard" than the preponderance standard, Rossi v. Hartford Fire Ins.
+Co., 103 A.D.2d 771, 771 (2d Dep't 1984), in that it is evidence "that is
+neither equivocal nor open to opposing presumptions." Solomon v. State
+of New York, 146 A.D.2d 439, 440 (1st Dep't 1989). Under SORA, the
+"burden of proving the facts supporting the determinations sought by
+19
+
+
+
+
+clear and convincing evidence" is assigned to the District Attorney,
+which represents the State in the proceeding. Correction Law §§ 168-
+k(2), 168-n(2).
+In the instant case, the Court did not conduct its own inquiry of
+relevant facts to determine Appellant's risk level in accordance with the
+SORA guidelines. Instead, as described further below, the Court
+improperly adopted a Board recommendation that had been rejected by
+both the People and Appellant as unreliable. Without any meaningful
+consideration of other evidence, the Court made its risk assessment
+determination based on allegations that did not -- and indeed could not,
+as a matter of law -- constitute clear and convincing evidence. Such a
+determination was made in contravention of SORA and its guidelines
+and violated Appellant's federal due process rights under the U.S.
+Constitution. For these reasons, the Court's determination should be
+vacated.
+The People's Investigation Revealed That The Board's
+Recommendation Could Not Be Proven By Clear and
+Convincing Evidence.
+The People began the SORA hearing by advising the Court that
+their own investigation and communications with the Florida State
+20
+
+
+
+
+Attorney's Office that handled Appellant's case revealed that the
+majority of allegations in the Board's recommendation (and in the police
+affidavit on which the recommendation was based°) were not prosecuted
+by Florida authorities and could not be proven by other evidence. See
+A.83:14-84:19 (Tr.). In relevant part, the People made the following
+record:
+I tried to reach -- I reached the authorities in
+Florida to try to see if they had all the interview
+notes or other things
+that
+we
+can then
+subsequently rely on that might be considered
+clear
+and convincing evidence, if they had
+interviewed these women on their own, and they
+never did. No one was cooperative and they did
+not go forward on any of the cases and none of
+them were indicted. So I don't know.
+A.85:19-86:1 (Tr.). As explained by the People, Appellant's Florida case
+was not one where a host of allegations were encompassed within a plea
+deal, but rather, the only charges
+that were determined to be
+It bears noting that the police affidavit upon which the Board based its case
+summary and recommendation appears not even to have been drafted to sustain
+charges against Appellant, but instead, recited numerous allegations based on
+double and triple hearsay directed toward filing charges against a defendant named
+Sarah Kellen. See A.6 (Palm Beach Police Department - Probable Cause Affidavit of
+J. Recarey, dated May 1, 2006). Furthermore, the Florida State Attorney expressly
+rejected the claims asserted in the police affidavit (which sought to charge Kellen as
+an accomplice to Appellant) by determining that there was not sufficient probable
+cause and not charging Appellant with the serious second-degree felony offenses
+which the affidavit sought to support, to wit, Unlawful Sexual Activity with a
+Minor, Fla. Stat. § 794.05(1), and Lewd and Lascivious Molestation, Fla. Stat.
+§ 800.04(5).
+21
+
+
+
+
+prosecutable were the charges for which Appellant was ultimately
+convicted:
+So it is unlike a situation where everything was
+indicted and then we get to sort of assess points
+for all of the victims, if it was part of a plea
+bargain. They did not actually choose to go
+forward on any except for the one victim.
+A.84:2-6 (Tr.). Given this history, the People advised the Court that it
+should depart from the Board's recommendation, both as a matter of
+fact and as a matter of law, in accordance with the SORA guidelines.
+See A.83:14-84:19, 85:11-16, 87:10-12 (Tr.).
+The SORA guidelines are intended to provide clear guidance to the
+Court and the parties with respect to how various potential risk factors
+should be evaluated, including allegations that have not been
+prosecuted. While, in general, conduct not directly encompassed by the
+crime of conviction may be considered in scoring for given factors on the
+RAI, the SORA guidelines deem, "Points should not be assessed for a
+factor... unless there is clear and convincing evidence of the existence of
+that factor." Sex Offender Registration Act: Risk Assessment Guidelines
+and Commentary, Commentary (2006), at 5, 1 7 (emphasis added).
+Indeed, in deciding how to evaluate allegations outside of the crime of
+22
+
+
+
+
+conviction, the SORA guidelines expressly caution, "the fact that an
+offender was arrested or indicted for an offense is not, by itself, evidence
+that the offense occurred."
+Sex Offender Registration Act: Risk
+Assessment Guidelines and Commentary, Commentary (2006), at 5, 9 7.
+More to the point here, the guidelines emphasize, "[T]he fact that an
+offender was not indicted for an offense may be strong evidence that the
+offense did not occur," amplified with a relevant example:
+For example, where a defendant is indicted for
+rape in the first degree on the theory that his
+victim was less than 11 years old, but not on the
+theory that he used forcible compulsion, the
+Board or court should be reluctant to conclude
+that the offender's conduct involved forcible
+compulsion.
+Sex Offender Registration Act: Risk Assessment Guidelines and
+Commentary, Commentary (2006), at 5, 1 7 (emphasis in original,
+internal statutory citations omitted).10
+In other words, SORA and its guidelines clearly prescribe that
+where allegations were reported to and investigated by law enforcement
+but not prosecuted (and not encompassed within a broader plea
+10
+Of note, at one point during the SORA proceeding, the Court seemingly
+lismissed out of hand the SORA guidelines concerning uncharged allegations. See
+A. 84:7-13 (Tr.) (Court expressing skepticism toward the Board's guidelines that "it
+somebody is not indicted it is strong evidence that it did not occur.").
+23
+
+
+
+
+bargain), they should not be scored on the RAI or factored into a risk
+- determination in the absence of other evidence to corroborate their
+validity.
+See Sex Offender Registration Act:
+Risk Assessment
+Guidelines and Commentary, Commentary (2006), at 5, 1 7; see also
+People v. Smith, 66 A.D.3d 981, 983 (2d Dep't 2009) (holding that
+defendant's alleged use of knife was not proven by clear and convincing
+evidence and could not be scored against defendant in SORA hearing
+where testimony about use of knife was presented to grand jury but
+grand jury did not indict on weapons charge); People v. Coffey, 45
+A.D.3d 658 (2d Dep't 2007) (holding that it was improper for court to
+consider allegations concerning a charge that was dismissed in
+evaluating defendant's SORA risk level); People v. Arotin, 19 A.D.3d 845
+(3d Dep't 2005) (holding that defendant could not be scored under
+SORA for deviate sexual intercourse where defendant was not indicted
+for such an offense and the only evidence of such conduct came from
+triple hearsay in a police report used by the Board).
+Significantly, here, the People did not merely apply the SORA
+guideline suggesting that uncharged allegations may not be reliable
+evidence of an offense. Instead, the People had actual information from
+24
+
+
+
+
+the Florida State Attorney's Office that the complainants referenced by
+the Board in connection with uncharged claims were not cooperative
+with authorities, prompting the Florida State Attorney's Office to decide
+not to pursue charges in connection with those unsupported allegations.
+See A.84:14-19, 85:19-86:1, 86:10-12 (Ir.).
+Moreover, the People
+acknowledged that they had no corroborating materials - such as
+interview notes, sworn statements, or affidavits -- which would permit
+them to meet their burden of proving disputed allegations by clear and
+convincing evidence. See A.84:14-19, 85:19-86:1, 86:10-12 (Tr.). As a
+result, the People advanced the position that the law compelled they
+take - advising the Court that the Board's recommendation was wrong
+and that a Level 3 determination was not supported by the provable
+evidence.
+B. Recommendation Where ty Facts Cited Therein Weard's
+Disputed and No Further Evidence Was Presented.
+Notwithstanding the reasoned, evidence-based disavowal by the
+People of the Board's
+recommendation (based on the People's
+communications with the Florida prosecutor), the SORA Court relied
+wholesale upon the Board's recommendation. See A.93:21, 94:6-95:9
+25
+
+
+
+
+(Tr.). The Court improperly overlooked the burden of proof statutorily
+• imposed on the People and its own duty to evaluate the evidence, and
+adopted the Board's recommendation, seemingly as a per se matter. See
+A.85:11-18 (Tr.) (the Court opining, without factual basis, that the
+Board "obviously took [their own guidelines] into consideration" when
+assessing points for uncharged conduct). Indeed, although the Court
+cited no specific information to suggest that the Board itself
+communicated with Florida prosecutors in preparing the case summary,
+the Court attempted to justify its blind reliance on the Board's
+recommendation by stating, "I feel the board looked into all of this,
+made their recommendation, found him to have 130 points and I see no
+reason to disturb that." A.96:11-13 (Tr.).
+While the Court of Appeals has recognized that a Board-generated
+case summary may constitute "reliable hearsay" upon which the Court
+may base a SORA risk calculation, the law is equally clear that a
+Board's case summary is not per se reliable, particularly in the face of
+countervailing evidence. See People v. Mingo, 12 N.Y.3d 563, 572-73,
+(2009) ("Of course, information found in a case summary ... need not
+always be credited -- it may be rejected when it is unduly speculative or
+26
+
+
+
+
+its accuracy is undermined by other more compelling evidence"); see also
+People v. Mabee, 69 A.D.3d 820 (2d Dep't 2010) (finding Board's case
+summary did not constitute clear and convincing evidence to support
+scoring under SORA where it provided only very limited information
+pertaining to the particular factor). Indeed, information contained in a
+Board's case summary does not by itself clear the hurdle of "clear and
+convincing evidence" -- a higher standard than mere "reliable evidence"
+-- where the offender disputes the relevant contents of that evidence.
+See People v. Judson, 50 A.D.3d 1242 (3d Dep't 2008) (holding that case
+summary alone could not satisfy state's burden of proving factors by
+clear and convincing evidence to support level 3 determination where
+defendant contested certain factual allegations related to those factors);
+cf. People v. Wasley, 73 A.D.3d 1400, 1401 (3d Dep't 2010) (holding
+"evidence included in the case summary may provide clear and
+convincing evidence in determining a defendant's risk assessment level
+where defendant did not dispute its contents insofar as relevant.")
+(emphasis added); People v. Curthoys, 77 A.D.3d 1215, 1216 (3d Dep't
+2010) (noting that the "uncontested contents of a case summary can
+satisfy the People's burden of demonstrating ... clear and convincing
+27
+
+
+
+
+evidence") (emphasis added). Thus, it certainly follows that a Board's
+case summary cannot, as a matter of law, constitute the sole requisite
+"clear and convincing evidence" required to support a SORA
+determination where the People, as the party representing the Board,
+also expressly disclaim the reliability of that case summary.
+Here, the Board's case summary was based almost entirely on
+double and triple hearsay allegations described in an affidavit
+submitted by police to the Florida prosecutor.
+See A.65 (Board
+Recommendation); A.6 (Palm Beach Police Department - Probable
+Cause Affidavit of J. Recarey, dated May 1, 2006). The allegations,
+even when aggregated, were not deemed by the Florida prosecutor who
+reviewed them to constitute sufficient "probable cause" to warrant the
+return of a complaint, information, or indictment as to any of the
+charges that the affidavit sought." And, of course, because the
+requested charges were never brought, no court ever reviewed or
+authorized the affidavit's allegations to make a judicial finding of
+"probable cause" as to any such allegations. Even had the Florida
+11
+Although the affidavit considered by the Board was submitted with respect t
+defendant other than Appellant, it appears that the allegations in the affidavi
+were intended to establish probable cause to charge Appellant with Unlawful
+Sexual Activity with a Minor, Fla. Stat. § 794.05(1), and Lewd and Lascivious
+Molestation, Fla. Stat. § 800.04(5) -- charges that were never brought.
+28
+
+
+
+
+•
+prosecutor decided to arrest and charge Appellant based on allegations
+contained in the affidavit, the mere fact of an arrest or charge is not
+sufficiently trustworthy by itself to support the assessment of points
+against Appellant under SORA. See Sex Offender Registration Act:
+Risk Assessment Guidelines and Commentary, Commentary (2006), at
+5, 1 7 ("the fact that an offender was arrested or indicted for an offense
+is not, by itself, evidence that the offense occurred"). Such allegations
+cannot be deemed reliable - never mind satisfying the elevated
+standard of clear and convincing evidence -- where, as here, the People
+had specific information from the Florida prosecutor that Florida made
+the decision not to pursue such charges based precisely on the
+insufficiency of the evidence. See A.83:23-84:19, 85:19-86:1 (Tr.).
+In short, the People directly disputed the reliability of the Board's
+case summary and recommendation, based on information that was not
+before the Board following communications with the Florida prosecutor.
+See
+A.83:14-84:19,
+85:11-87:12 (Tr.); see also A.65 (Board
+Recommendation) (noting that Board's assessment was based on review
+of "inmate's file" and not citing specific contact with Florida
+authorities).
+Appellant also disputed the validity of many of the
+29
+
+
+
+
+•
+allegations contained therein, both generally and with regard to specific
+allegations. See A. 90:9-12, 92:13-21, 95:12-18 (Tr.). Notwithstanding
+the obvious existence of disputed relevant issues, the Court did not
+provide the parties with any opportunity to present evidence on
+contested issues, nor did the Court conduct any factual inquiry on its
+own.
+Even though there was no sufficient evidentiary basis to support
+the Board's recommendation, the Court announced that it was relying
+on the Board's case summary and adopting the Board's calculation and
+SORA determination in full. See A.93:21, 96:11-13 (Tr.). Indeed, at one
+point in adopting the Board's scoring, the Court openly acknowledged
+that it was assessing points against Appellant in the face of the People's
+position that the evidence of that factor was "not reliable":
+Number of victims, three or more. He only plead
+[sic] guilty to one, but apparently there were
+more than one and I think the People concede
+that although they say it was not reliable.
+A.94:10-13 (Tr.). This reliance on alleged conduct that the People, as
+the party bearing the burden of proof, expressly stated they could not
+prove by clear and convincing evidence, was plainly erroneous as a
+matter of law. (
+See Correction Law §§ 168-k(2), 168-n(2) (stating that
+30
+
+
+
+
+the facts supporting the court's determination shall be supported by
+clear and convincing evidence). Accordingly, the Court's Level 3
+determination, based specifically on unproven alleged conduct, cannot
+stand, and the Court's Order should be vacated. 12
+12
+Even if the Court had a lawful evidentiary basis to adopt the Board's case
+summary in full (which it did not), the case summary does not establish by clear
+and convincing evidence all of the factors for which points were assessed against
+Appellant. For example, the facts alleged in the case summary, even if taken as
+true, do not set forth, by clear and convincing evidence, a continuing course of
+sexual misconduct, which requires a specific finding of either "(i) two or more acts of
+sexual contact, at least one of which is an act of sexual intercourse, oral sexual
+conduct, anal
+sexual conduct, or aggravated sexual contact, which acts are
+separated in time by at least 24 hours, or (ii) three or more acts of sexual contact
+over a period of at least two weeks" with an underage victim. See Sex Offender
+Registration Act: Risk Assessment Guidelines and Commentary, Commentary
+(2006), at 10 ("Factor 4: Duration of Offense Conduct with Victim"); see also People
+v. Redcross, 54 A.D.3d 1116 (3d Dep't 2008) (holding that continuing course of
+sexual misconduct was not supported by clear and convincing evidence where record
+was silent as to dates that incidents of sexual conduct occurred in relation to each
+other); People v. Donk, 39 A.D.3d 1268, 1269 (4th Dep't 2007) (modifying SORA risk
+assessment where there was not clear and convincing evidence to establish
+continuing course of sexual misconduct under specific definition set forth by SORA);
+People v. Boncic, 15 Misc. 3d 1139(A), 841 N.Y.S.2d 281 (Sup. Ct. N.Y. Cty. 2007)
+(holding that there must be a finding of "actual sexual contact" with the underage
+victim to score for the continuing course of conduct factor under SORA). Here, the
+case summary only speaks of certain allegations generally and provides no detail
+regarding the timing of specific alleged acts of sexual contact, the number of times
+Appellant allegedly engaged in specific acts with individual complainants, or the
+age of the complainants at the time of the relevant acts. Similarly, the case
+summary does not establish by clear and convincing evidence several other factors
+for which points were assessed against Appellant, including the "use of violence"
+(e.g. case summary provides only conclusory allegations of "forcible rape" without
+establishing the element of "forcible compulsion"); "sexual contact with victim" (e.g
+case summary does not specify the age of each complainant at the time of alleged
+relevant sexual contact to determine whether each complainant was underage and
+therefore a "victim"); "number of victims" (same); and "age of victim" (same).
+31
+
+
+
+
+C.
+Determining Appellant To Be a Level 3 Offender Based on
+Factors That Were Not Proven by Clear and Convincing
+Evidence Violated Appellant's Federal Due Process Rights.
+In addition, the Court's assessment of points against Appellant
+based on allegations that were not and could not be proven by clear and
+convincing evidence constituted a clear violation of Appellant's federal
+due process rights.
+It is settled as a matter of federal constitutional law that those
+persons convicted of a sex offense and required to register under a state
+registration and notification scheme like SORA have a protected liberty
+interest that entitles them to procedural due process. See Doe v. Pataki,
+3 F. Supp. 2d 456, 468 (S.D.N.Y. 1998); see also People v. David W., 95
+N.Y.2d 130, 138 (2000) (holding that the imposition of a Level 3 SORA
+determination implicates liberty interests and triggers due process
+safeguards).
+Courts evaluating that liberty interest under the
+procedural due process analysis articulated by the U.S. Supreme Court
+in Matthews v. Eldridge, 424 U.S. 319 (1976) (balancing the private
+interest affected by state action, the risk of erroneous deprivation of
+that interest, and the interests of the state) have determined that "the
+nature of the [sex offender] classification proceeding is serious enough"
+32
+
+
+
+
+and "carries with it a high risk of error," such that the state must afford
+an individual facing such a risk classification a constitutionallymandated minimum level of due process. Doe, 3 F. Supp. 2d at 469, 471
+(citing Doe v. Poritz, 142 N.J. 1, 662 A.2d 367 (1995)). While "the due
+process protections required for a risk level classification proceeding are
+not as extensive as those required in a plenary criminal or civil trial,"
+Id. at 470, federal due process is only satisfied when a person being
+assessed under SORA is afforded a "pre-notification hearing
+accompanied by a
+comprehensive set of procedural safeguards,"
+including each of the following:
+(1)
+a judicial determination of his risk level
+classification [by hearing];
+(2)
+notice of the classification proceeding,
+sufficiently in advance of the hearing to...
+prepare a challenge;
+(3)
+notice of the proceeding must contain a
+statement of [its] purpose and the Board's
+recommended risk level classification;
+(4)
+an opportunity to retain counsel;
+(5) pre-hearing discovery;
+(6) the state must prove the facts supporting
+each risk factor by clear and convincing
+evidence; and
+(7)
+the right to appeal.
+33
+
+
+
+
+See id. at 471-72 (articulating the above seven procedures as essential
+to satisfy procedural due process when assigning risk levels under
+SORA) (emphasis added); see also People v. Brooks, 308 A.D.2d 99, 103
+(2d Dep't 2003) (same).
+This sixth constitutional factor -- the requirement that the State
+bear the burden of proof and prove the facts supporting each risk factor
+upon which a risk assessment is based by the elevated standard of clear
+and convincing evidence -- is of particular significance, in that it is a
+recognition of the severe injurious impact upon liberty, reputation, and
+opportunity that an unjustified notification level can have on an
+offender:
+...
+Because "the possible injury to the individual
+[registrant] is significantly greater than any
+possible harm to the state," the registrant,
+consistent with due process, cannot "be asked to
+share equally with society the risk of error"....
+It necessarily follows that the Due Process Clause
+requires that the state prove its case by clear and
+convincing
+evidence in
+a Megan's Law
+proceeding.
+E.B. v. Verniero, 119 F.3d 1077, 1111 (3d Cir. 1997), cert. denied, 522
+U.S. 1109 (1998) (citing Addington v. Texas, 441 U.S. 418, 427 (1979));
+see also Brooks, 303 A.D.2d at 105 (observing "a SORA determination
+34
+
+
+
+
+- -
+undeniably has a profound impact on a defendant's liberty interest due
+to the registration and community notification provisions"). In other
+words, because a SORA hearing "threaten[s] the individual involved
+with a significant deprivation of liberty or stigma," due process
+demands "more than average certainty on the part of the factfinder."
+E.B., 119 F.3d at 1110-11 (citing Santosky v. Kramer, 455 U.S. 745, 756-
+58 (1982)). Accordingly, "registrants are entitled to have the burden of
+persuasion placed on the state, with the state obligated to prove the
+proposed level and manner of notification by clear and convincing
+evidence." Doe, 3 F. Supp. 2d at 471; see also David W., 95 N.Y.2d at
+140 (holding "Due process requires that the State bear the burden of
+proving, at some meaningful time, that a defendant deserves the
+classification assigned.").
+Here, the Court's Level 3 determination, made without regard to
+the People's presentation and advocacy at the hearing and unsupported
+by clear and convincing evidence, failed to satisfy these basic
+constitutional requirements regarding both the allocation of the burden
+of persuasion (upon the People) and the standard of proof (by clear and
+convincing evidence) for a
+SORA hearing.
+The Court's complete
+35
+
+
+
+
+reliance on the unsupported, unprosecuted, and disputed hearsay
+allegations in the Board's case summary to buttress a Level 3
+determination violated Appellant's due process rights, as set forth by
+Doe v. Pataki, and accordingly, the Court's Order should be reversed.
+II. THE COURT BASED ITS LEVEL 3 DETERMINATION
+UPON IMPROPER CONSIDERATIONS.
+In addition to basing Appellant's risk level determination on
+uncharged allegations that, both in fact and as a matter of law could not
+be proven by clear and convincing evidence, the Court improperly
+assessed Appellant as a Level 3 offender based on additional factors and
+considerations that should not have weighed into its RAI calculation.
+Namely, the Court improperly penalized Appellant for conduct that was
+not scoreable under SORA, even with respect to the complainant from
+his single registerable crime of conviction. In addition, the record lays
+bare that the Court allowed personal bias and irrelevant factors outside
+the record in Appellant's
+case to influence the Court's SORA
+determination.
+The Court Improperly Assessed Points Against Appellant
+for Conduct That Is Not Scoreable Under SORA.
+First, the SORA Court improperly scored Appellant for alleged
+conduct that is not registerable, and in some cases is not even criminal,
+36
+
+
+
+
+under New York law with respect to the sole complainant at issue in
+Appellant's single registerable Florida conviction. For example, the
+Court adopted the Board's assessment of points for "sexual intercourse,"
+even though the People themselves conceded that the complainant at
+issue was 17 (and therefore over New York's age of consent) when she
+allegedly engaged in consensual intercourse with Appellant.
+See
+A.92:1-7 (Tr.). This scoring for sexual intercourse was in clear
+contravention to the SORA statute, which states that prostitution
+offenses are only registerable under SORA where there is clear and
+convincing evidence that the prostitute was "in fact" under 17 at the
+time of the alleged sexual conduct. Correction Law § 168-a(2)(a)(i). 13
+Additionally, the Court appears to have scored Appellant 20
+points for this same complainant under the "age of victim" factor, even
+though the People made a record that the complainant was "either 16 or
+17" when she met Appellant for the first time. A.92:1-3 (Tr.). The fact
+that, even in the People's view, the specific age of the complainant when
+13
+Of course, the exact allegations for which the Court assessed points against
+Appellant are nearly impossible to identify given the Court's failure to articulate
+findings of fact and conclusions of law supporting its scoring of particular factors.
+See A.4 (Order Appealed From, dated Jan. 18, 2011); A.82 (Tr. generally); see also
+Section III, infra. Nor did the Board's recommendation tie its scoring to particular
+facts in its case summary, which lumped a host of facts together in the aggregate.
+See A.65 (Board Recommendation).
+37
+
+
+
+
+she first met Appellant -- no less when she may have engaged in sexual
+conduct with him -- could not be ascertained precludes a finding that
+this element was proven by clear and convincing evidence. See Solomon
+v. State of New York, 146 A.D.2d 439, 440 (1st Dep't 1989) (defining
+clear and convincing evidence as evidence "that is neither equivocal nor
+open to opposing presumptions"). Yet the Court disregarded the burden
+of proof and made clear that it was scoring Appellant for this factor. 14
+See A.92:13-93:12 (Tr.). These improper assessments of points on the
+RAI should render the Court's Level 3 determination invalid.
+B. The Court Improperly Allowed Personal Feelings and
+Matters Outside the Record to Influence Its SORA
+Determination.
+Next, the Court abused its discretion by allowing an apparent
+personal distaste for Appellant, the nature of the crime for which he
+pleaded guilty and was convicted, and the quantity and nature of
+unproven,
+unprosecuted
+allegations
+cited in
+the
+Board's
+recommendation to impinge upon the Court's duty to follow the law.
+The Court demonstrated a remarkable disdain and lack of judicial
+14
+Again, the specific basis upon which the Court scored Appellant for certain
+factors cannot be ascertained from the legally deficient Order, see A.4 (Order
+Appealed From, dated Jan. 18, 2011), although the Court's comments at the hearing
+revealed the Court's belief that points should be assessed against Appellant for
+"procuring" this complainant when "she was either 16 or 17." See A.92:1-23 (Tr.).
+38
+
+
+
+
+objectivity in its response to hearing the District Attorney disavow the
+reliability of the Board's recommendation, in receiving the arguments of
+counsel for Appellant, and in rendering its Order as a whole.
+First, although the SORA statute clearly contemplates that the
+District Attorney may depart from the Board's recommendation based
+upon its own evaluation of the evidence,15 see Correction Law §§ 168-
+15
+For example, SORA expressly provides, "If the district attorney seeks a
+determination that differs from the recommendation submitted by the board, at
+least ten days prior to the determination proceeding the district attorney shall
+provide to the court and the sex offender a statement setting forth the
+determinations sought by the district attorney together with the reasons for seeking
+such determinations." Correction Law §§ 168-k(2), 168-n(2). While the more
+common application of this provision involves the People seeking a higher risk level
+than the Board, the provision clearly encompasses any deviation from the Board's
+recommendation, including the People's discretion to recommend a lower risk level.
+See, e.g., People v. Ferguson, 53 A.D.3d 571, 572 (2d Dep't 2008) (holding that 10-
+day notice requirement applies not only to changes in RAI scoring, but to changes in
+factual predicates for RAI scoring).
+Incidentally, it bears noting that the People failed to comply with these
+procedural mandates, constituting a further procedural flaw in these proceedings.
+See Correction Law §$ 168-k(2), 168-n(2). While the People provided Appellant with
+a written alternative RAI immediately prior to the SORA hearing -- and not ten
+days prior to the hearing, as required by SORA -- it appears that the People failed
+to submit their RAI to the Court at all. See Appendix generally. Before rejecting
+out of hand the People's stance that a Level 3 determination could not be supported
+by sufficient evidence, the Court should have adjourned the matter to receive and
+review a written statement of the People's recommended determination and
+supporting reasons. See People v. Ferguson, 53 A.D.3d at 572 (reversing SORA
+order where defendant and court did not receive proper 10-day notice of People's
+revised RAI; cf. People v. Jordan, 31 A.D.3d 1196, 1196 (4th Dep't 2006) (holding
+People's failure to provide sufficient notice of revised RAI was cured where Court
+adjourned matter to allow meaningful opportunity to consider revised RAI). The
+Court's failure to enforce the procedural mandates of the SORA statute was
+prejudicial to Appellant, in that the Court did not have sufficient opportunity to
+39
+
+
+
+
+k(2), 168-n(2), here, the Court rejected the investigation and advocacy of
+the People. Indeed, the Court went so far as to express "shock" that the
+People would support a lower risk level determination than that
+recommended by the Board, almost as a matter of principle. See A.86:9
+(Tr.). The Court disregarded the detailed evidentiary investigation and
+careful parsing of allegations that the People undertook in evaluating
+the Board's recommendation. Ignoring the record at issue concerning
+Appellant and the evidence pertaining to him, the Court focused instead
+on the irrelevant facts of some unidentified case completely unrelated to
+Appellant's:
+I have to tell you, I am a little overwhelmed
+because I have never seen the prosecutor's office
+do anything like this. I have never seen it. I had
+a case with one instance it was a marine who
+went to a bar, and I wish I had the case before
+me, but he went to a bar and a 17 year old, he
+was an adult obviously, he was a Marine, a 17
+year did came up to had sex one ther and the
+People would not agree
+to a downward
+modification on that.
+understand the compelling reasons for the alternative RAI calculation that the
+People promoted. See id.
+40
+
+
+
+
+So I am a little overwhelmed here because I see --
+mean I read everything here, I am just a little
+verwhelmed that the People are making this
+application.
+I could cite many many, I have done many
+SORAs much less troubling than this one where
+the People would never make a downward
+departure like this. 16
+A.84:21-85:10 (Tr.).
+Later,
+when Appellant's counsel disputed that
+there were any credible -. much less prosecuted -. allegations that
+Appellant ever used force, the Court again began comparing Appellant's
+case to the same irrelevant case about "a marine" -- a matter completely
+unknown to Appellant and having no connection whatsoever to
+Appellant's case
+- seemingly to suggest that Appellant should
+nevertheless be scored as Level 3 under SORA:
+There was no allegation of force in the marine
+either, who met a girl in a bar, a young girl 17,
+there was no force there.
+16
+Notably, the People were not asking the Court to make a downward
+departure from the RAI calculation, but were advising the Court that the evidence
+required a recalculation of Appellant's risk level based on the RAI factors. See Sex
+Offender Registration Act:
+Risk Assessment Guidelines
+and Commentary,
+Commentary (2006) at 4-5, 11 5, 6.
+41
+
+
+
+
+A.90:13-15 (Tr.).1 The Court's subjective comparison of Appellant's
+case to some unidentified, unrelated case was improper and highly
+irregular, and it clearly interfered with the Court's duty to make an
+assessment based on the law.
+Similarly, in response to an argument by counsel regarding the
+implications that a Level 3 assignment would have on Appellant, who
+does not actually reside in New York, the Court abandoned any
+semblance of judicial objectivity by dismissively suggesting that he
+should "give up his New York home if he does not want to come every 90
+days." A.93:18-19 (Tr.). Rather than giving reasoned consideration to
+whether Appellant's residence outside of New York might be a relevant
+factor in its overall risk assessment (such as for a downward departure
+from an RAI calculation), the Court improperly allowed its judgment to
+be clouded by apparent personal disdain for Appellant.
+Furthermore, the Court's apparent distaste for Appellant has
+eliminated any likelihood that Appellant will receive a fair
+redetermination hearing should this matter be remanded back to the
+. -
+17
+Significantly, the Court in fact scored 10 points against Appellant for forcible
+compulsion, despite the parties' agreement that there was no legitimate evidentiary
+basis to score Appellant for the use of force or violence. See A.94:7-8 (Tr.).
+42
+
+
+
+
+same Justice. Indeed, this Court has recognized that reassignment of a
+matter to a different Justice following appeal is warranted and
+appropriate where the apparent impartiality of the lower court has been
+legitimately questioned, as it most certainly has here. See, e.g., People
+v. Rampino, 55 A.D.3d 348, 349 (1st Dep't 2008) (remanding
+resentencing matter to a different Justice where the "appearance of
+fairness and impartiality [was] compromised by the actions of the
+Justice to whom defendant's application was assigned"); Fresh Del
+Monte Produce N.V. v. Eastbrook Caribe, 40 A.D.3d 415, 421 (Ist Dep't
+2007) (remanding matter to a different Justice where "a reasonable
+concern about the appearance of impartiality" had been raised on
+appeal).
+Accordingly, should this Court deem remand the only
+appropriate mechanism for recalculating Appellant's risk assessment
+level, Appellant respectfully asks that the SORA proceeding be
+reassigned to a different Justice.
+In sum, a court only has discretion to go beyond the factors
+outlined in the SORA guidelines in evaluating a person's risk level
+where justified by clear and convincing evidence. See People v. Sherard,
+73 A.D.3d 537, 537 (Ist Dep't 2010) (citing People v. Miller, 854 N.Y.2d
+43
+
+
+
+
+138 (2008), Iv. denied 10 N.Y.3d 711, 860 N.Y.S.2d 483 (2008)) (holding
+that where a court exercises discretion to depart from the evidencebased scoring of an RAI, the court must base such departure on "clear
+and convincing evidence of aggravating factors to a degree not taken
+into account" in the RAI); see also Sex Offender Registration Act: Risk
+Assessment Guidelines and Commentary, Commentary (2006) at 4-5, 911l
+5, 6. Here, the Court's SORA determination, made in the express
+absence of clear and convincing evidence, 18
+constituted an abuse of
+discretion, warranting reversal of the Court's Level 3 determination and
+Order.
+Moreover, given the Court's demonstrated lack of judicial
+objectivity toward Appellant, should remand be required, Appellant
+respectfully requests that this matter be reassigned to a different
+Justice in the Supreme Court.
+18
+The Court did not -- and could not -- cite any factors within or outside of the
+Board's consideration, proven by clear and convincing evidence, that would justify a
+Level 3 determination under RAI scoring or constitute lawful grounds for an
+upward departure. See A.82 (Tr. generally). Instead, the Court fully adopted the
+Board's calculation, scoring Appellant a presumptive rating of Level 3, without
+meaningful inquiry into any of the underlying allegations or any consideration of'
+other evidence which could bear upon Appellant's risk level. See A.93:21, 94:6-95:9,
+96:11-13 (Ir.).
+44
+
+
+
+
+III. THE COURT'S ORDER DOES NOT COMPLY WITH THE
+MANDATES OF SORA AND CONSTITUTIONAL DUE
+PROCESS AND MUST BE VACATED.
+Finally, the Court's Order determining Appellant to be a Level 3
+sex offender is itself facially defective in numerous regards and should
+be vacated as legally invalid. In addition, the Court's failure to set forth
+any factual basis for its Level 3 determination renders the Order
+constitutionally infirm, warranting reversal on federal due process
+grounds as well.
+SORA provides that it is the "duty of the court" to determine,
+pursuant to the SORA guidelines, both the "level of notification"
+required of an offender and whether any designations defined in section
+168-a(7) apply. Correction Law §§ 168-k(2), 168-n(2). In addition,
+SORA mandates that the court "render an order" which sets forth "its
+determinations and the findings of fact and conclusions of law on which
+the determinations are based." Correction Law §§ 168-k, 168-n.
+Here, the Court's compliance with these requirements fell
+woefully short. The only order issued by the Court in this matter was a
+standard boilerplate form where the Court circled a pre-printed number
+and provided a signature and date. See A.4 (Order Appealed From,
+45
+
+
+
+
+..
+dated Jan. 18, 2011). Indeed, upon close examination of the only
+"order" in this matter, it appears that the form Order is actually
+intended to be a cover sheet to accompany a more formal order, with
+written findings of fact and conclusions of law, upon submission to the
+Division. See A.4 (Order Appealed From, dated Jan. 18, 2011) (stating,
+"A copy of the order setting forth the risk level and designation
+determinations, and the findings and conclusions of law on which such
+determinations are based, shall be submitted to the Division of
+Criminal Justice Services' Sex Offender Registry Unit by the Court. In
+addition, please complete and attach this form indicating the offender's
+risk level and designation to the Court's order."). Yet this legally
+insufficient Order was served on Appellant following the SORA
+proceeding and was sent to the Division so that the Level 3
+determination could be executed and enforced. See A.78 (Letter of
+Supreme Court, dated Jan. 19, 2011).
+The appellate courts have consistently held that cursory, nonspecific "findings" issued after SORA hearings - including the
+wholesale adoption of a Board recommendation or recitation of RAI
+factors without further explanation, as the Court offered here - are
+46
+
+
+
+
+legally insufficient under SORA. See, e.g. People v. Strong, 77 A.D.3d
+717, 717-18 (2d Dep't 2010) (reversing SORA order issued without
+findings of fact and conclusions of law, where court relied on RAI but
+failed to introduce the RAI in evidence or indicate any evidence relied
+upon); People v. Gilbert, 78 A.D.3d 1584, 1584 (4th Dep't 2010) (holding
+that the SORA court's conclusory recitation that it reviewed the parties'
+submissions and was adopting the Board's case summary and
+recommendation was insufficient to fulfill SORA's statutory mandate);
+People v. Miranda, 24 A.D.3d 909, 910-11 (3d Dep't 2005) (holding that
+the court's adoption of the Board's RAI scores and "generic listing of
+factors" failed to "fulfill the statutory mandate" of SORA and precluded
+"meaningful appellate review of the propriety of the court's risk level
+assessment").
+In addition, the Order in this case is constitutionally deficient, in
+that the Court's failure to set forth any factual or legal bases for its
+Level 3 determination falls short of the minimum due process rights
+guaranteed by the U.S. Constitution. In the landmark case of Goldberg
+v. Kelly, the U.S. Supreme Court held that, in relevant part, to
+demonstrate compliance with the procedural due process requirement
+47
+
+
+
+
+that the decision maker's conclusion rest solely on the legal rules and
+evidence adduced at hearing, "[the] decision maker should state reasons
+for his determination and indicate evidence he relied on, though his
+statement need not amount to a full opinion or even formal findings of
+fact and conclusions of law." Goldberg v. Kelly, 397 U.S. 254, 271 (1970)
+(internal citations omitted), 19 In short, the minimal due process
+requirement that the order set forth the basis for the court's
+determination is designed to provide some assurance that the court's
+conclusion rested on sufficient reliable evidence--which in Appellant's
+case, it did not.
+The utterly deficient Order issued by the Court in this matter
+itself provides an independent basis for reversal of the Court's Level 3
+determination, on both state statutory and federal constitutional
+grounds.
+SORA, by specifically requiring the Court to issue findings of fact and
+conclusions of law to support its determination, therefore sets forth a higher
+standard than is required by federal due process. See Correction Law §$ 168-k, 168-
+n (requiring the court to "render an order setting forth its determinations and the
+findings of fact and conclusions of law on which the determinations are based").
+48
+
+
+
+
+CONCLUSION
+For the reasons stated herein, Appellant Jeffrey E. Epstein
+respectfully submits that the January 18, 2011 Order of the New York
+Supreme Court determining Appellant Jeffrey E. Epstein to be a Level
+3 sex offender, without designation, should be vacated, and Appellant's
+SORA level should be recalculated -- either by this Court based on the
+present record or upon remand to a different Justice in the lower court
+-- in accordance with the law, based solely on the evidence that can be
+proven by clear and convincing evidence, to wit, the undisputed conduct
+encompassed by Appellant's registerable crime of conviction.
+February 22, 2011
+Sandra Lynn Musumeci
+sandra.musumeci@kirkland.com
+KIRKLAND & ELLIS LLP
+601 Lexington Avenue
+New York, New York 10022
+Telephone:
+Facsimile: (
+Counsel for Defendant-Appellant
+Jeffrey E. Epstein
+
+
+
+
+PRINTING SPECIFICATION STATEMENT
+This computer generated brief was prepared using a
+proportionally spaced typeface.
+Name of Typeface:
+Century Schoolbook
+Point Size:
+14-point type
+Line Spacing:
+Double-spaced
+The total number of words in the brief, inclusive of point headings
+and footnotes and exclusive of pages containing the table of contents,
+table of authorities, and printing specification statement is 10,522.
+50
+
+
+
+
+CERTIFICATE OF DIGITAL-SUBMISSION COMPLIANCE
+The undersigned hereby certifies that:
+(1) all required privacy redactions have been made and, with the
+exception of those redactions, every document submitted in Digital
+Form or scanned PDF format is an exact copy of the written document
+filed with the Clerk; and
+(2) the digital submissions have been scanned for viruses with the
+most recent version of a commercial virus scanning program (McAfee
+Enterprise 8.5 Virus Scan, updated as of March 9, 2009) and, according
+to the program, are free of viruses.
+Sandra Lynn Musumeci
+KIRKLAND & ELLIS LLP
+601 Lexington Avenue
+New York, New York 10022
+Telephone:
+Facsimile:
+
+
+
+
+
+
+
+
+SUP FOR THE STATE OF NEW YORK
+PEOPLE OF THE STATE OF NEW YORK,
+Plaintiff-Respondent,
+Index No.: 30129-2010
+PRE-ARGUMENT STATEMENT
+- against -
+JEFFREY E. EPSTEIN,
+Defendant-Appellant.
+1. TITLE OF ACTION: As set forth in caption.
+2. FULL NAMES OF ORIGINAL PARTIES AND ANY CHANGE IN THE PARTIES:
+As set forth in caption. There has been no change in the parties.
+OR PENTION ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR APPELLANT
+Jay P. Lefkowitz, P.C
+Sandra Lynn Musumeci
+KIRKLAND & ELLIS LLP
+601 Lexington Avenue
+New York, New York 10022-4611
+4. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR
+RESPONDENT:
+Cyrus R. Vance, Jr.
+NEW YORK DISTRICT ATTORNEY'S OFFICE
+One Hogan Place
+New York, NY 10013
+Telephone:
+5. COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL
+IS TAKEN: New York Supreme Court (Criminal Term), New York County.
+6. THE NATURE AND OBJECT OF THE CAUSE OF ACTION OR SPECIAL
+PROCEEDING: Sex Offender Registration Act (SORA) hearing, pursuant to Article 6-C of the
+Correction Law.
+7. RESÜLT REACHED IN THE COURT OF ADMINISTRATIVE BODY BELOW:
+Supreme Court, New York County, adjudged appellant Jeffrey E. Epstein to be a Level 3 sexual
+offender, without additional designation.
+GROUNDS FOR SEEKING REVERSAL, ANNULMENT, OR MODIFICATION: The
+Court's designation of appellant Jeffrey E. Epstein as a Level 3 sexual offender was an abuse of
+
+
+
+
+discretion and constituted reversible legal error based, in part, on the following: (1) the Court
+improperly relied on untrustworthy double and triple hearsay contained in the recommendation
+of the Board of Examiners of Sex Offenders, even though the District Attorney, as the party
+appearing on behalf of the State, rejected much of the Board's recommendation as not
+constituting clear and convincing evidence to support a Level 3 designation where such hearsay
+allegations were rejected as a basis for state prosecution; (2) the Court failed to provide the
+parties with an opportunity to present evidence on contested issues, as required by statute, and
+instead relled wholesale upon the recommendation of the Board, over the objection of the
+District Attorney, without any inquiry; (3) the Court did not apply the guidelines established by
+the Board, as required by statute; and (4) the Court failed to set forth the findings of fact and
+conclusions of law on which its determinations in support of a Level 3 designation were based,
+as required by statute.
+9. THERE IS NO RELATED ACTION OR PROCEEDING NOW PENDING IN ANY
+COURT OF THIS OR ANY OTHER JURISDICTION.
+10. THERE IS NO ADDITIONAL APPEAL PENDING IN THIS ACTION.
+Dated: February 9, 2011
+Lefkowitz, P.C.
+Sandra Lynn Musumeci
+KIRKLAND & ELLIS LLP
+601 Lexington Avenue
+New York, New York 10022-4611
+elephone
+acsimile
+Ispreneys for Defendant-Appellane Jeffrey E.
+-2-
+
+
+
+
+RECEIVED
+FEB 23 2011
+AP EALO
+RECORD PRESS, INC., 229 West 36th Street, N.Y. 10018-28828-(212) 619-4949
+www.recordpress.com
diff --git a/vision-fixhub/ds9-unparsed-05/a2e15e89192cebf19358b01bd64225d344ba5f21583158a9df6b7463fe5bbf1e.receipt.json b/vision-fixhub/ds9-unparsed-05/a2e15e89192cebf19358b01bd64225d344ba5f21583158a9df6b7463fe5bbf1e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c3cf2d088dbf65766bba7eda4cffe08d30cc650e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a2e15e89192cebf19358b01bd64225d344ba5f21583158a9df6b7463fe5bbf1e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1511,
+  "dataset": "marble-joined",
+  "doc_id": "a2e15e89192cebf19358b01bd64225d344ba5f21583158a9df6b7463fe5bbf1e",
+  "engine": "marble-apple-vision",
+  "event_count": 127,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "0467c4208a2510f7cf0e98c62d224b84661f31ddf208694eac9cdd09329edb75",
+  "output_sha256": "ab508a8c2bba4f0259f377689284d3e3a6fe7bd05f87f9ef113a9c024ddc917d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a2f30477d0569ef2b2be53818feef2f681814f86f305e06c195ebf372024be3f.md b/vision-fixhub/ds9-unparsed-05/a2f30477d0569ef2b2be53818feef2f681814f86f305e06c195ebf372024be3f.md
new file mode 100644
index 0000000000000000000000000000000000000000..b7fc27d09b9774c382256dd94d6642f06f2eb79c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a2f30477d0569ef2b2be53818feef2f681814f86f305e06c195ebf372024be3f.md
@@ -0,0 +1,156 @@
+Subject:
+Friday, July 18, 2008 4:51 PM
+Re: Well, our victim notification letter has been filed in court
+Thanks for the update. Have a great weekend!
+---- Original Message -...
+Sent: Fri Jul 18 16:48:47 2008
+Subject: Well, our victim notification letter has been filed in court
+Our victim notification letter has been filed in court in connection with one of the federal civil suits against Epstein.
+About 10 letters have gone out so far. The FBI's victim coordinator is updating the addresses on the rest and they will go out on
+Monday.
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+244
+P-015075
+
+
+Subject:
+Friday, July 18, 2008 4:55 PM
+RE: Well, our victim notification letter has been filed in court
+Thanks,
+Thanks.
+Whenever you have a chance, can you send the corrected address list to me?
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+----Original Message-....
+Sent: Friday, July 18, 2008 4:51 PM
+Subject: Re: Well, our victim notification letter has been filed in court
+Thanks for the update. Have a great weekend!
+--- Original Message -...-
+Sent: Fri Jul 18 16:48:47 2008
+Subject: Well, our victim notification letter has been filed in court
+Our victim notification letter has been filed in court in connection with one of the federal civil suits against Epstein.
+About 10 letters have gone out so far. The FBI's victim coordinator is updating the addresses on the rest and they will go out on
+Monday.
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+245
+P-015076
+
+
+Subject:
+Friday, July 18, 2008 5:30 PM
+Re: Well, our victim notification letter has been filed in court
+Sure. sorry I was in Miami all day. I'll send it Mon.
+--- Original Message --.
+From: I
+Sent: Fri Jul 18 16:54:49 2008
+Subject: RE: Well, our victim notification letter has been filed in court
+Thanks,
+Whenever you have a chance, can you send the corrected address list to me?
+Thanks.
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+----Original Message.....
+Sent: Friday, July 18, 2008 4:51 PM
+Subject: Re: Well, our victim notification letter has been filed in court
+Thanks for the update. Have a great weekend!
+--- Original Message -....
+Sent: Fri Jul 18 16:48:47 2008
+Subject: Well, our victim notification letter has been filed in court
+Our victim notification letter has been filed in court in connection with one of the federal civil suits against Epstein.
+About 10 letters have gone out so far. The FBI's victim coordinator is updating the addresses on the rest and they will go out on
+Monday.
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+246
+P-015077
+
+
+Subject:
+Monday, July 21, 2008 12:31 PM
+RE: Addresses
+Are there any girls who have not been contacted yet?
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Sent: Monday, July 21, 2008 11:23 AM
+Subject: Addresses
+Here is a copy of the most up-to-date addresses.
+was telling her that Edwards has been
+talking to some of the victims that she is counseling and that he is encouraging them that 18 months is not long enough
+of a sentence for Epstein. I am not sure who she is referring to but that
+is having to provide additional
+counseling. If you have any questions regarding this you might want to speak directly to
+Talk to you soon.
+247
+P-015078
+
+
+Subject:
+Monday, July 21, 2008 12:33 PM
+Re: Addresses
+Yes, I will get an update from
+--- Original Message -....
+Sent: Mon Jul 21 12:31:13 2008
+Subject: RE: Addresses
+Are there any girls who have not been contacted yet?
+and let u know. I am also out this Thur and Fri. Have a good time on your B-Day.
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+From: /
+Sent: Monday, July 21, 2008 11:23 AM
+To: |
+Subject: Addresses
+Here is a copy of the most up-to-date addresses.|
+Iwas telling her that Edwards has been talking to some of
+the victims that she is coring in und that he is entain in then ad i made i in rear are eins rearing i
+not sure who she is referring to but that
+you might want to speak directly to
+Talk to you soon.
+248
+P-015079
+
+
+Subject:
+Monday, July 21, 2008 12:35 PM
+RE: Addresses
+Thank you.
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+----Original Message-....
+From: D
+Sent: Monday, July 21, 2008 12:33 PM
+Subject: Re: Addresses
+Yes, I will get an update from Twiler and let u know. I am also out this Thur and Fri. Have a good time on your B-Day.
+- Original Message -....
+From
+Sent: Mon Jul 21 12:31:13 2008
+Subject: RE: Addresses
+Are there any girls who have not been contacted yet?
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+From: L
+Sent: Monday, July 21, 2008 11:23 AM
+Subject: Addresses
+249
+P-015080
+
+
+Here is a copy of the most up-to-date addresses. [
+told me that IT was telling her that Edwards has been talking to some of
+the victims that she is counseling and that he is encouraging them that 18 months is not long enough of a sentence for Epstein. I am
+not sure who she is referring to but that
+Tis having to provide additional counseling. If you have any questions regarding this
+you might want to speak directly to ?
+Talk to you soon.
+250
+P-015081
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/a2f30477d0569ef2b2be53818feef2f681814f86f305e06c195ebf372024be3f.receipt.json b/vision-fixhub/ds9-unparsed-05/a2f30477d0569ef2b2be53818feef2f681814f86f305e06c195ebf372024be3f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..356651b6e9758b2942b2f4261d438d4dad42572a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a2f30477d0569ef2b2be53818feef2f681814f86f305e06c195ebf372024be3f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -363,
+  "dataset": "marble-joined",
+  "doc_id": "a2f30477d0569ef2b2be53818feef2f681814f86f305e06c195ebf372024be3f",
+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "59725cc1873b468c891915622f6afaa9c0f3257a8a7b69953531463c05962050",
+  "output_sha256": "6987c5817f6e20c6c913ade2e4e875ad92ac6ec2dff36d828cdc463314079da0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a30e0dfd45ceb415178588da2b663e04f2e53707b8c30f7aa44abd554cb2c60d.md b/vision-fixhub/ds9-unparsed-05/a30e0dfd45ceb415178588da2b663e04f2e53707b8c30f7aa44abd554cb2c60d.md
new file mode 100644
index 0000000000000000000000000000000000000000..8568ccaabb335cedc872ab7be79605cc149508bb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a30e0dfd45ceb415178588da2b663e04f2e53707b8c30f7aa44abd554cb2c60d.md
@@ -0,0 +1,9587 @@
+• Case 9:09-cv-80656-KAM Document 5
+
+CASE NO.: 09-80656-CIV-Ryskamp
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant,
+RESPONSE IN OPPOSITION TO MOTION TO PROCEED ANONYMOUSLY
+AND
+EPSTEIN'S MOTION TO COMPEL AND/OR IDENTIFY
+IN
+THE STYLE OF THIS CASE AND MOTION TO IDENTIFY
+THIRD-PARTY SUBPOENAS FOR PURPOSES OF DISCOVERY, WITH
+INCORPORATED MEMORANDUM OF LAW
+Defendant, JEFFREY EPSTEIN ("Epstein" or "Defendant"), by and
+through his undersigned attorneys, hereby files his Response In Opposition to
+Plaintiff,
+Motion to Proceed Anonymously and files his Motion
+requesting that this Court enter an order identifying in the style of this case the
+complete
+• legal
+name of the Plaintiff,
+0, to
+substitute her complete legal name in this case in place of
+ind,
+equally important, allowing Defendant to identify her in various subpoenas that
+Epstein must serve so Epstein can defend this case. In support, Mr. Epstein
+states as follows:
+1
+
+
+• Case 9:09-cv-80656-KAM
+
+denied, but Epstein's Motion to Identify Jane Doe must be granted. Despite
+Plaintiff's allegations in the Motion to Proceed Anonymously, this Court has not
+"allowed" any Plaintiff to proceed anonymously. Quite simply, that is the way
+each Plaintiff chose to file each of their respective cases, all of which are
+currently being challenged in those other matters by Motion to Identify.
+4.
+Importantly, JANE DOE claims that she has and will suffer "..
+•physical injury, pain and suffering, emotional distress, psychological and
+psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss
+of educational opportunities, loss of self-esteem, loss of dignity, invasion of her
+privacy, separation from her family.
+•, and medical and psychological
+expenses..., loss on income, loss of the capacity to earn income in the future,
+and loss of the capacity to enjoy life" 11128, Comp., DE 1; see also 11136, 40, 44,
+48, 52, 56, 61, 65, and 69, Comp., DE 1.
+Epstein has a constitutional due process right to defend himself and
+to seek the production of information that will assist in his defense of the
+allegations in the Complaint. In this case, Plaintiff's counsel intends on serving
+subpoenas on Plaintiff's treating physicians and other third parties. Thus, this
+motion seeks not only a denial Plaintiff's Motion to Proceed Anonymously but to
+identify JANE DOE in the style of this case and to identify JANE DOE in various
+third-party subpoenas for discovery purposes.
+The undersigned's experience in "Jane Doe" lawsuits is that once a
+Plaintiff is identified, other individuals come forward in the discovery phase with
+information which often directly contradicts allegations as to the events and
+
+
+• Case 9:09-cv-80656-KAM Document 5
+Entered on FLSD Docket 05/11/2009 Page 5 of 12
+agreed that the subpoenas filed with the clerk would be redacted. Several
+attorneys agreed to this procedure in those cases. In Federal Court, subpoenas
+are not filed with the clerk. Thus, in this matter, the undersigned offered to serve
+the third-party subpoenas with plaintiff's full name, date of birth and social
+security number (last four digits) and would agree to redact any identifying
+information on any documents filed with this court if that ultimately became
+necessary.
+9. Moreover, when an order from the court is attached to the
+Subpoena, treaters and other third parties produce the records and show up to
+the depositions with the records requested because the deponent knows what to
+bring by virtue of knowing the identity of the Plaintiff.
+10. Epstein's counsel intends to serve and depose witnesses duces
+tecum. If Epstein is not permitted to identify JANE DOE (thus allowing her to
+proceed anonymously), how will any deponent know who the parties are and
+what to bring to the deposition pursuant to the duces tecum? Further, how will
+Epstein be able to defend the claims. Just like the Plaintiff, Epstein is entitled to
+due process.
+If the Court allows Jane Doe to proceed anonymously, Jane Doe
+will be permitted to present her case and Epstein will be limited in his defenses.
+11.
+While it is within the sound discretion of this court to allow a party to
+proceed anonymously, Plaintiff should not attempt to utilize that discretion as a
+shield from legitimate and necessary discovery. Epstein has a fundamental due
+process right to conduct discovery.
+5
+
+
+Case 9:09-cv-80656-KAM
+
+b.
+whether the party defending the suit would be prejudiced;
+c.
+whether the plaintiff is required to disclose information of
+utmost intimacy;
+whether the plaintiff is compelled to admit an intention to
+engage in illegal conduct, thereby risking criminal
+prosecution;
+whether the Plaintiff would risk suffering injury if identified;
+f.
+whether the interests of children are at stake; and
+g.
+whether there are less drastic means of protecting the
+legitimate interests of either party.
+• Doe v. Frank, 951 F.2d at 323.
+Plaintiff does not fall under any of the factors. Moreover, even if she did
+meet one of the factors, "Ithe fact that [a] Doe [Plaintiff] may suffer some
+personal embarrassment, standing alone, does not require the granting of a
+request to proceed under a pseudonym." Id; see also Doe v. Rostker, 89 F.R.D.
+159 (N.D. Calif. 1981). Any substantial privacy interests JANE DOE has must
+outweigh the customary and constitutionally embedded presumption of openness
+to judicial proceedings. Doe v. Frank, 951 F.2d at 323; Doe v. Bergstron, 2009
+WL 528623 (C.A.9(Or.)) (denying request to proceed anonymously in civil action
+by Plaintiff where Plaintiff's arrest, prosecution and acquittal were matters of
+public record).
+14.
+In Sweetland v. State, 535 So.2d 646 (Fla. 1" DCA 1988), the court
+reasoned that the purpose of discovery is to eliminate the likelihood of surprise
+and to insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure
+1.280(b)(1); see also Surf Drugs, Inc., V. Vermette, 236 So.2d 108, 111 (Fla.
+
+
+• Case 9:09-cv-80656-KAM
+Entered on FLSD Docket 05/11/2009 Page 9 of 12
+damages. Plaintiff is claiming emotional/psychological damages. Therefore,
+Epstein is entitled to know her psychological condition(s) before and after the
+alleged incidents) she references in the Complaint. In particular, JANE DOE
+alleges specific disorders as a result of Epstein's alleged conduct - suffer "..
+•physical injury, pain and suffering, emotional distress, psychological and
+psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss
+of educational opportunities, loss of self-esteem, loss of dignity, invasion of her
+privacy, separation from her family ..., and medical and psychological
+expenses..., loss on income, loss of the capacity to earn income in the future,
+and loss of the capacity to enjoy life." (Emphasis Added). See supra. Epstein is
+also entitled to know, among other things, whether she had any physical
+complaints or whether there was ever any evidence of physical battery on JANE
+DOE's body from the acts she complains of in the Complaint. The need to serve
+third-party subpoenas on medical doctors is a basic discovery need related to the
+claims alleged by JANE DOE for which Plaintiff's counsel refuses to compromise.
+Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5"* DCA 1997), rev. denied, 719 So.2d 286
+(Fla. 1998)(discoverability of Plaintiff's history of sexual activity is relevant to
+damages); United States v. Bear Stops, 997 F.2d 451 (8' Cir. 1993)(deals with
+"admissibility of other acts of sexual abuse by individuals other than the
+defendant to explain why a victim of abuse exhibited behavioral manifestations of
+a sexually abused child.") If Plaintiff saw a psychologist or other physician
+during or after the time periods she claims she was assaulted by Epstein but
+either did not discuss or did discuss the incidents (or lack thereof) would be
+
+
+•Case 9:09-cv-80656-KAM Document 5
+Entered on FLSD Docket 05/11/2009 Page 11 of 12
+was charged with any crimes. If Jane Doe was charged with crimes, Epstein is
+entitled to obtain certified copies of those crimes Plaintiff may have committed for
+purposes of discovery and impeachment. Questions will be asked regarding
+those crimes (e.g., Have you been convicted of a crime of dishonesty or false
+statement? If so, how many times? Have you been convicted of a felony? If so,
+how many times?) To hold otherwise would not only prevent broad discovery but
+would ultimately result in reversible error at any trial.
+II. Conclusion and Prayer for Relief
+22. Epstein requests the following relief:
+a.
+That JANE DOE's Motion to Proceed Anonymously be denied;
+b.
+That this Court grant Epstein's Motion and that JANE DOE be
+identified by her legal name in the style of this case; and
+c.
+That Epstein be granted leave to identify JANE DOE by her
+legal name in Third-Party Subpoenas (but not file them in Court
+or, if required, in a redacted form).
+WHEREFORE, Epstein, Jeffrey Epstein, respectfully requests that this
+Court enter said order granting the relief requested above, and for such other
+and further relief as this Court may deem just and proper.
+ele
+D. CRITTON, JR., ESQ.
+MICHAEL J. PIKE, ESQ.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically
+filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing
+document is being served this day on all counsel of record identified on the
+following Service List in the manner specified by CM/ECF on this 8 day of
+May, 2009
+
+
+Page 1 of7
+AEV
+Doe No. 102 v. Epstein
+Assigned to: Judge Kenneth A. Marra
+Lead case: 9:08-cv-80119-KAM
+Member case: (View Member Case)
+Cause: 28:1391 Personal Injury
+Plaintiff
+U.S. Ditrict Court
+CIVIL DOCKET FOR CASE #: 9:09-cv-80656-KAM
+Date Filed: 05/01/2009
+Jury Demand: Plaintiff
+Nature of Suit: 360 P.I.: Other
+Jurisdiction: Federal Question
+represented by Katherine Warthen Ezell
+Podhurst Orseck Josefsberg et al
+City National Bank Building
+25 W Flagler Street
+Suite 800
+Miami , FL 33130-1780
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Robert C. Josefsberg
+Suite 800
+Miami , FL 33130-1780
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Defendant
+Jeffrey Epstein
+represented by Robert Deweese Critton, Jr.
+Burman Critton Luttier & Coleman
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?825839498761356-L_801_0-1
+
+
+
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Amicus
+United States of America
+represented by
+Jnited States Attorney's Offic
+00 East Broward Blvc
+7th Floor
+Et Lauderdale, FL. 33394
+ext. 3546
+Fax: 1
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Date Filed
+05/01/2009
+05/01/2009
+05/01/2009
+05/01/2009
+05/11/2009
+05/11/2009
+05/11/2009
+# clear Docket Text
+1
+COMPLAINT and Demand for Jury Trial against Jeffrey Epstein. Filing fee
+$350.00. Receipt No. 100030, filed by
+caw) (Entered:
+05/04/2009)
+2
+Summons Issued as to Jeffrey Epstein. (caw) (Entered: 05/04/2009)
+Sealed Document. (igo) (Entered: 05/04/2009)
+4
+5
+Sealed Document. (igo) (Entered: 05/04/2009)
+RESPONSE/REPLY to 4 Sealed Document, 3 Sealed Document
+Opposition to Motion to Proceed Anonymously by Jeffrey Epstein. (Critton,
+Robert) (Entered: 05/11/2009)
+NOTICE of Attorney Appearance by Robert Deweese Critton, Jr on behalf
+of Jeffrey Epstein (Critton, Robert) (Entered: 05/11/2009)
+7
+MOTION to Compel and/or identify jane doe #102 in the style of this case
+(Responses due by 5/29/2009), MOTION to identify!
+in the
+third-party subpoenas for purposes of discovery, with incorporated
+memorandum of law by Jeffrey Epstein.(see docket entry 5 for image) (tas)
+(Entered: 05/12/2009)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|?825839498761356-L_801_0-1
+
+
+/05/12/2009
+8
+
+05/13/2009
+10
+11
+12
+13
+14
+15
+Clerks Notice of Docket Correction and Instruction to Filer re 5
+Response/Reply (Other) Error - Two or More Document Events Filed as
+One; Correction - Additional event(s) 7 MOTION to Compel and/or
+identify jane doe #102 in the style of this case MOTION to identify.
+in the third-party subpoenas for purposes of discovery, with
+incorporated memorandum of law. docketed by Clerk. Instruction to Filer -
+In the future, please select all applicable events. It is not necessary to refile
+his document. (tas) (Entered: 05/12/2009)
+ORDER of Transfer/REASSIGNING CASE. Case reassigned to Judge
+Kenneth A. Marra for all further proceedings. Senior Judge Kenneth L.
+Ryskamp no longer assigned to case. Signed by Senior Judge Kenneth L.
+Ryskamp on 5/12/2009. (tas) (Entered: 05/14/2009)
+Cases associated. (ir) (Entered: 05/14/2009)
+ORDER CONSOLIDATING CASES. Hereinafter all motions and other
+court filings that relate to discovery and all procedural motions that relate t
+multiple cases shall be styled with all of the case names and numbers and
+shall be filed in Case No. 08-80119-CIV-MARRA. Signed by Judge
+Kenneth A. Marra on 5/14/2009. Associated Cases: 9:08-cv-80119-KAM et
+ORDER REQUESTING UNITED STATES PROVIDE POSITION TO
+MOTION TO STAY. Signed by Judge Kenneth A. Marra on 5/14/2009.
+(Attachments: # 1 Appendix Motion to Stay DE 51) Associated Cases:
+9:08-cv-80119-KAM et al. (ir) (Entered: 05/14/2009)
+ORDER terminating 7 Motion to Compel; terminating 7 Motion. See Urder
+consolidating cases. See procedural motions pending: DE 91 in 08-80119..
+Signed by Judge Kenneth A. Marra on 5/14/2009. (Ic3) (Entered:
+05/14/2009)
+NOTICE by
+of Filing Withdrawal of Previously Raised Objections
+to Defendant, Jeffrey Epstein's Motion to Compel And/Or Identifi
+in the Style of This Case and Motion to Identify
+• in Third-Party
+Subpoenas for Purposes of Discovery, Or, Alternatively, Motion to Dismiss
+Sua Sponte, With Inorporated Memorandum of Law Associated Cases:
+9:08-cv-80119-KAM et al.(Hill, Jack) (Entered: 05/20/2009)
+ORDER STRIKING in all Epstein cases EXCEPT case no. 08-80119:
+1. of Filing Withdrawal of Previously Raised Objections to
+Epstein's Motion to Compel and/or Identify. This Notice should only be
+filed in 08-80119, not in all of the Epstein cases.. Signed by Judge Kenneth
+A. Marra on 5/20/2009. Associated Cases: 9:08-cv-80119-KAM et al. (Ic3)
+(Entered: 05/20/2009)
+Clerks Notice of Docket Correction and Instruction to Filer re 13 Notice
+(Other), Notice (Other) filed by
+.. Error - Incorrect Document
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|7825839498761356-L_801_0-1
+
+
+
+05/26/2009
+16
+17
+18
+19
+20
+Link/No Link;. Instruction to filer - In the future, please link the document
+to the proper entry. It is not necessary to refile this document. (IS) (Entered:
+05/22/2009)
+Plaintiff's MOTION to Preserve Evidence Plaintiffs ,
+and
+Motion for an Order for the Preservation of Evidence
+and Incorporated Memorandum of Law byl
+•(Attachments: # 1 Exhibit "A",
+', # 2 Exhibit "B", # 3 Text of Proposed
+Order)Associated Cases: 9:08-cv-80119-KAM, 9:09-cv-80591-KAM, 9:09-
+cv-80656-KAM(Ezell, Katherine) (Entered: 05/26/2009)
+ORDER terminating(28) Motion to Preserve Evidence in case 9:09-cv-
+80591-KAM; terminating(16) Motion to Preserve Evidence in case 9:09-
+cv-80656-KAM This motion is pending ONLY in case no. 08-80119..
+Signed by Judge Kenneth A. Marra on 5/27/2009. (Ic3) (Entered:
+NOTICE by
+(111 in 9:08-cv-80119-KAM) Plaintiff's MOTION
+for Extension of Time to File Response as to (91 in 9:08-cv-80119-KAM)
+Defendant's MOTION to Compel Identity of Doe in Style of Case and
+Third-Party Subpoenas (replaces Docket entry 90)Plaintiff's MOTION for
+Extension of Time to File Response as to (91 in 9:08-cv-80119-KAM)
+Defendant's MOTION to Compel Identity of Doe in Style of Case and
+Third-Party Subpoenas (replaces Docket entry 90) (Attachments: # 1 Text
+of Proposed Order)Associated Cases: 9:08-cv-80119-KAM et al.(Horowitz,
+Adam) (Entered: 05/27/2009)
+ORDER STRIKING Notice by Jane Doe in all Epstein cases EXCEPT in
+case 08-80119. This Notice should only be filed in 08-80119, not in all of
+Associatin Cases. -0-c-301 9- Met al. 3) Enter d: 05282009)
+on behalf of
+21
+D (Entered: 05/29/2009)
+RESPONSE to Motion re (72 in 9:08-cv-80380-KAM) Defendant's
+MOTION to Stay re (62) Amended Complaint, (57 in 9:08-cv-80232-
+KAM) Defendant's MOTION to Stay re (50) Amended Complaint, (24 in
+9:08-cv-80893-KAM) Defendant's MOTION to Stay re (1) Complaint, (23
+in 9:08-cv-80994-KAM) Defendant's MOTION to Stay re (18) Amended
+Complaint, (22 in 9:08-cv-80993-KAM) Defendant's MOTION to stay re
+(19) Amended Complaint, (65 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Stay re (56) Amended Complaint, (68 in 9:08-cv-80381-
+KAM) Defendant's MOTION to Stay re (60) Amended Complaint, (51 in
+9:08-cv-80811-KAM) Defendant's MOTION to Stay re (40) Amended
+Complaint and or Continue Action Filed Pursuant to Court's Order
+Requesting Government's Position filed by United States of America.
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?825839498761356-L_801_0-1
+
+
+
+06/01/2009
+22
+23
+24
+25
+26
+27
+Replies due by 6/8/2009. Associated Cases: 9:08-cv-80119-KAM et al.
+) (Entered: 05/29/2009)
+RESPONSE in Opposition re (90 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Compel Identify Doe in Style of Case and in Third-Party
+Subpoenas, (91 in 9:08-cv-80119-KAM) Defendant's MOTION to Compel
+Identity of Doe in Style of Case and Third-Party Subpoenas (replaces
+Associated
+Cases: 9:08-cv-80119-KAM et al.(Ezell, Katherine) (Entered: 05/29/2009)
+ORDER STRIKING (124 in 9:08-cv-80119-KAM, 105 in 9:08-cv-80811-
+KAM, 74 in 9:08-cv-80993-KAM, 72 in 9:08-cv-80893-KAM, 106 in 9:08-
+cv-80232-KAM, 123 in 9:08-cv-80380-KAM, 35 in 9:09-cv-80591-KAM,
+25 in 9:09-cv-80469-KAM, 60 in 9:08-cv-80994-KAM, 22 in 9:09-cv-
+80656-KAM, 107 in 9:08-cv-80381-KAM) Response in Opposition to
+Motion, filed by
+DO NOT FILE IN
+EVERY EPSTEIN CASE. SEE ORDER CONSOLIDATING CASES..
+Signed by Judge Kenneth A. Marra on 5/29/2009. Associated Cases: 9:08-
+cv-80119-KAM et al. (Ic3) (Entered: 05/29/2009)
+MOTION for Leave to File UNDER SEAL RESPONSE IN OPPOSITION
+TO DEFENDANTS MOTION TO STAY OR, IN THE ALTERNATIVE TO
+UNSEAL THE NONPROSECUTION AGREEMENT by
+Associated Cases: 9:08-cv-80119-KAM et al. (Ezell,
+Katherine) (Entered: 05/29/2009)
+MOTION for Hearing MOTION TO RESCHEDULE HEARING by Jane
+• Associated Cases: 9:08-cv-80119-KAM et
+al. (Josefsberg, Robert) (Entered: 05/29/2009)
+ORDER STRIKING (28 in 9:09-cv-80469-KAM, 126 in 9:08-cv-80380-
+KAM, 109 in 9:08-cv-80232-KAM, 25 in 9:09-cv-80656-KAM, 77 in 9:08-
+cv-80993-KAM, 38 in 9:09-cv-80591-KAM, 110 in 9:08-cv-80381-KAM,
+63 in 9:08-cv-80994-KAM, 75 in 9:08-cv-80893-KAM. 108 in 9:08-cv-
+80811-KAM) Motion to Continue Hearing filed by
+(76 in 9:08-Cv-80993-KAM, 109 in 9:08-CV-80381-KAM,
+108 in 9:08-cv-80232-KAM, 62 in 9:08-cv-80994-KAM, 125 in 9:08-cv-
+80380-KAM, 74 in 9:08-cv-80893-KAM, 24 in 9:09-cv-80656-KAM, 37 in
+9:09-Cv-80591-KAM, 107 in 9:08-cv-80811-KAM. 27 in 9:09-cv-80469-
+KAM) Motion for Leave to File, filed by
+•THESE DOCUMENTS SHOULD BE FILED ONLY IN 08-80119.
+SEE CASE MANAGEMENT ORDER.. Signed by Judge Kenneth A.
+Marra on 6/1/2009. (Ic3) (Entered: 06/01/2009)
+REPLY to Response to Motion re (113 in 9:08-cv-80119-KAM) Plaintiff's
+MOTION Plaintiffs
+Motion for No-
+Contact Order Plaintiffs
+Reply
+to Defendant Jeffrey Epstein's Response to Plaintiff
+and
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?825839498761356-L_801_0-1
+
+
+
+28
+06/08/2009
+29
+06/08/2009
+30
+31
+32
+on for a No-Contact Order filed by
+Associated Cases: 9:08-cv-80119-KAM et al.
+(Ezell, Katherine) (Entered: 06/04/2009)
+ORDER STRIKING (112 in 9:08-cv-80381-KAM, 111 in 9:08-cv-80232-
+KAM, 136 in 9:08-cv-80119-KAM, 111 in 9:08-cv-80811-KAM, 128 in
+9:08-cv-80380-KAM, 65 in 9:08-cv-80994-KAM, 79 in 9:08-cv-80893-
+KAM, 42 in 9:09-cv-80591-KAM, 27 in 9:09-cv-80656-KAM, 32 in 9:09-
+cv-80469-KAM, 79 in 9:08-cv-80993-KAM) Reply to Response to Motion,
+Document stricken for failure
+to follow Court's orders. DO NOT FILE A DOCUMENT IN EVERY
+EPSTEIN CASE if it is to be filed only in 08-80119. See Case Management
+Order and contact CM/ECF Support for assistance in proper filing.. Signed
+by Judge Kenneth A. Marra on 6/4/2009. Associated Cases: 9:08-cv-80119-
+KAM et al. (Ic3) (Entered: 06/04/2009)
+RESPONSE to Motion re (91 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Compel Identity of Doe in Style of Case and Third-Party
+Subpoenas (replaces Docket entry 90) filed by Jane Doe. Replies due by
+6/18/2009. (Attachments: # 1 Exhibit A, # 2 Exhibit B)Associated Cases:
+9:08-cv-80119-KAM et al.(Horowitz, Adam) (Entered: 06/08/2009)
+NOTICE by Jane Doe re (113 in 9:08-cv-80119-KAM) Plaintiff's MOTION
+Plaintiffs
+Motion for No-Contact
+Order -Plaintiffs Jane Does 2-7 Notice of Joinder Associated Cases: 9:08-
+cv-80119-KAM et al.(Horowitz, Adam) (Entered: 06/08/2009)
+Clerks Notice of Docket Correction and Instruction to Filer re 29 Response
+to Motion, filed by Jane Doe. Error - Document Incomplete, i.e. Missing
+Page 1 on Attachments: #2 Exhibit B . (Is) (Entered: 06/10/2009)
+Clerks Notice of Docket Correction and Instruction to Filer re 30 Notice
+(Other), Notice (Other) filed by Jane Doe. Error - Wrong Event Selected;.
+Instruction to Filer - In the future, please select the proper event, i.e. Notice
+of Adoption. It is not necessary to refile this document. (Is) (Entered:
+06/10/2009)
+or
+Download Selected
+PACER Service Center
+Transaction Receipt
+06/10/2009 14:37:13
+du4480
+Client Code:
+PACER
+Login:
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?825839498761356-L_801_0-1
+
+
+
+Description:
+Docket
+Report
+Billable
+4
+Pages:
+Search
+Criteria:
+Cost:
+19:09-cv-80656-
+KAM
+0.32
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|?825839498761356-L_801_0-1
+
+
+.. Case 9:08-CV-80993-KAM Document 19
+Entered on FLSD Docket 02/27/2009 Page 1 of 8
+CASE NO.: 08-80993-CIV-MARRA/JOHNSON
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+/
+AMENDED COMPLAINT
+Plaintiff,
+Epstein, as follows:
+rings this Complaint against Jeffrey
+Parties, Jurisdiction and Venue
+s a citizen and resident of the State of Florida, and is sui juris.
+This Complaint is brought under a fictitious name to protect the identity of the
+Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a
+minor.
+Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
+4.
+This is an action for damages in excess of $50 million.
+This Court has jurisdiction of this action and the claims set forth herein pursuant to 28
+U.S.C. §1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs;
+and (ii) is between citizens of different states.
+Additionally, this Court has jurisdiction pursuant to 28 U.S.C. §1331 because
+Plaintiff alleges a claim under the laws of the United States. This Court has supplemental
+- 1-
+
+
+Case 9:08-cv-80993-KAM Document 19
+Entered on FLSD Docket 02/27/2009 Page 3 of 8
+generally $200 to $300 per "massage" session - and who were perceived as less likely to complain to
+authorities or have credibility if allegations of improper conduct were made. This was an important
+element of Epstein's plan.
+12.
+Epstein's plan and scheme reflected a particular pattern and method. The underage
+victim would be brought to Epstein's mansion, where she would be introduced to
+Epstein's assistant. Ms
+would then bring the girl up a flight of stairs to a bedroom that
+contained a massage table in addition to other furnishings. The girl would then find herself alone in
+the room with Epstein, who would be wearing only a towel. He woulddirect he rig! to give him a
+massage. Epstein would then perform one or more lewd, lascivious and sexual acts, including
+13.
+Consistent with the foregoing plan and scheme, when Jane Doe was 16 years old, she
+was recruited by
+to give Epstein a massage for monetary compensation. Jane was
+brought to Epstein's mansion in Palm Beach. Once there, Jane was introduced to
+who led her up the flight of stairs to the room with the massage table. In this room, Jane was
+directed by Epstein to give him a massage. During this massage, Epstein sexually assaulted Jane and
+Epstein then paid Jane money.
+14.
+Jane returned on many occasions to the Palm Beach mansion to provide Epstein with
+massages for money. On those occasions, Epstein engaged in sexual contact and activity with Jane,
+which included, among other things, Epstein touching Jane's
+placing
+on her
+This sexual abuse continued over a period of approximately 18-24
+months.
+15.
+As a result of these encounters with Epstein, Jane experienced confusion, shame,
+humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
+- 3-
+
+
+, Case 9:08-CV-80993-KAM Document 19
+Entered on FLSD Docket 02/27/2009
+
+in mental or sexual injury that caused or were likely to cause Jane Doe's mental or emotional health
+to be significantly impaired.
+26.
+Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had
+reason to know that his intentional and outrageous conduct would cause emotional distress and
+damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing
+severe emotional distress to Jane Doe.
+27.
+As a direct and proximate result of Epstein's intentional or reckless conduct, Jane
+Doe, has suffered and will continue to suffer severe mental anguish and pain.
+WHEREFORE, Plaintiff
+demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this
+Court deems just and proper.
+COUNT III
+Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422
+28.
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 15 above.
+29.
+Epstein used a facility or means of interstate commerce to knowingly persuade,
+induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or
+sexual activity for which any person can be charged with a criminal offense.
+30.
+On June 30, 2008, Epstein entered a plea of guilty to violations of Florida §$ 796.07
+and 796.03, in the 15th Judicial Circuit in and for Palm Beach County (Case nos. 2008-cf-
+009381AXXXMB and 2006-cf-009454AXXXMB), for conduct involving the same plan and
+scheme as alleged herein.
+31.
+Asto Plaintiff Jane Doe, Epstein could have been charged with criminal violations of
+Florida Statute §796.07(2) (including subsections (c), (d), (e), (f), (g), and (h) thereof), and other
+- 5-
+
+
+Case 9:08-cv-80993-KAM
+Document 19
+Entered on FLSD Docket 02/27/2009
+
+Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those
+parties who are not authorized to receive electronically Notices of Electronic Filing.
+/s/ Adam D. Horowitz
+- 7-
+
+
+Caso 9:08-CV-80993-KAM Document 86
+Entered on FLSD Docket 06/10/2009 Page 1 of 10
+Plaintiff,
+V.
+JEFFREY EPSTEIN,
+Defendant.
+J
+DEFENDANT EPSTEIN'S FIRST AMENDED ANSWER & AFFIRMATIVE
+DEFENSES TO PLAINTIFF'S (FIRST) AMENDED COMPLAINT
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his
+undersigned attorneys, files his Answer to Plaintiff's Amended Complaint [DE 19] and
+states:
+1. Without knowledge and deny.
+2. As to the allegations in paragraphs 2, Defendant asserts his Fifth Amendment
+privilege against self-incrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d
+1099 (Fla. 4" DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth
+Amendment's Self-Incrimination Clause applies to the states through the Due Process
+Clause of the Fourteenth Amendment - "ilt would be incongruous to have different
+standards determine the validity of a claim of privilege based on the same feared
+prosecution, depending on whether the claim was asserted in state or federal court."); 5
+Fed.Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-
+Incrimination ("...court must treat the defendant's claim of privilege as equivalent to a
+specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. -
+
+
+Case 9:08-CV-80993-KAM Document 86 Entered on FLSD Docket 06/10/2009
+
+Epstein
+7. As to the allegations in paragraphs 7 through 15 of Plaintiff's Second Amended
+Complaint, Defendant exercises his Fifth Amendment Privilege against selfincrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4" DCA
+1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-
+Incrimination Clause applies to the states through the Due Process Clause of the
+Fourteenth Amendment - "ilt would be incongruous to have different standards
+determine the validity of a claim of privilege based on the same feared prosecution,
+depending on whether the claim was asserted in state or federal court."); 5 Fed.Prac. &
+Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-Incrimination
+("...court must treat the defendant's claim of privilege as equivalent to a specific
+denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. - "... a civil
+defendant who raises an affirmative defense is not precluded from asserting the
+privilege [against self-incrimination], because affirmative defenses do not constitute the
+kind of voluntary application for affirmative relief" which would prevent a plaintiff bringing
+a claim seeking affirmative relief from asserting the privilege.
+8. In response to the allegations of paragraph 16, Defendant realleges and adopts
+his responses to paragraphs 1 through 15 of the Second Amended Complaint set forth
+in paragraphs 1 through 7 above herein.
+9. Defendant asserts the Fifth Amendment Privilege against self-incrimination to
+the allegations set forth in paragraphs 17 through 22 of the Second Amended
+Complaint.
+See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4"' DCA 1983);
+Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination
+
+
+.. Case 9:08-CV-80993-KAM Document 86
+
+v. Epstein
+Page 5
+§1280 Effect of Failure to Deny - Privilege Against Self-Incrimination (... court must
+treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24
+Fla.Jur.2d Evidence §592. Defendants in civil actions. - "... a civil defendant who raises
+an affirmative defense is not precluded from asserting the privilege [against selfincrimination], because affirmative defenses do not constitute the kind of voluntary
+application for affirmative relief" which would prevent a plaintiff bringing a claim seeking
+affirmative relief from asserting the privilege.
+12. In response to the allegations of paragraph 29, Defendant realleges and adopts
+his responses to paragraphs 1 through 15 of the Second Amended Complaint set forth
+in paragraphs 1 through 7 above herein.
+13. Defendant asserts the Fifth Amendment Privilege against self-incrimination to
+the allegations set forth in paragraphs 30 through 35 of the Second Amended
+Complaint. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4" DCA 1983);
+Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination
+Clause applies to the states through the Due Process Clause of the Fourteenth
+Amendment - "ift would be incongruous to have different standards determine the
+validity of a claim of privilege based on the same feared prosecution, depending on
+whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc, Civ. 3d
+§1280 Effect of Failure to Deny - Privilege Against Self-Incrimination ("...court must
+treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24
+Fla.Jur.2d Evidence §592. Defendants in civil actions, - "... a civil defendant who raises
+an affirmative defense is not precluded from asserting the privilege [against self-
+
+
+Gase 9:08-cv-80993-KAM Document 86
+
+v. Epstein
+7. Plaintiff's claims are barred by the applicable statute of limitations.
+8. As to Plaintiff's claims for punitive damages in Count I - "Sexual Assault &
+Battery," and Count II - "Intentional Infliction of Emotional Distress," such claims are
+subject to the limitations as set forth in §768.72, et seq., Florida Statutes.
+9. As to Plaintiff's claims for punitive damages in Count | - "Sexual Assault &
+Battery," and Count II - "Intentional Infliction of Emotional Distress," such claims are
+subject to the constitutional limitations and guideposts as set forth in BMW of North
+America v. Gore, 116 S.Ct 1589 (1996); Philip Morris USA v. Williams, 127 S.Ct. 1057
+(2007); State Farm v. Campbell, 123 S.Ct 1513 (2003); Engle v. Ligget Group, Inc., 945
+So.2d 1246 (Fla. 2006). The Due Process Clause of the Fourteenth Amendment of the
+United States Constitution and Florida's Constitution, Art. I, §§2 and 9, prohibit the
+imposition of grossly excessive or arbitrary punishments
+10. As to Plaintiff's claims for punitive damages in Count | - "Sexual Assault &
+Battery," and Count II - "Intentional Infliction of Emotional Distress," the determination of
+whether or not Defendant is liable for punitive damages is required to be bifurcated from
+a determination of the amount to be imposed.
+11. Plaintiff has failed to state a cause of action for sexual assault and/or battery
+under Count I.
+12. As to Count III, Plaintiff has failed to plead a cause of action as she does not and
+can not show a violation of a predicate act under 18 U.S.C. §2255 (2005).
+
+
+Case 9:08-cv-80993-KAM Document 86
+
+1. Epstein
+Page 9
+applying a novel construction of a criminal statute to conduct that neither the statute nor
+any prior judicial decision has fairly disclosed to be within its scope.
+16. The applicable version of 18 U.S.C. §2255 creates a cause of action on behalf of
+a "minor." Plaintiff had attained the age of majority at the time of filing this action, and
+accordingly, her cause of action is barred.
+17. Because Plaintiff has no claim under 18 U.S.C. §2255, this Court is without
+subject matter jurisdiction as to all claims asserted.
+18. Application of the 18 U.S.C. §2255, as amended, effective July 27, 2006, is in
+violation of the constitutional principles of due process, the "Ex Post Facto" clause, and
+the Rule of Lenity, in that in amending the term "minor" to "person" as to those who may
+bring a cause of action impermissibly and unconstitutionally broadened the scope of
+persons able to bring a §2255 claim.
+19.18 U.S.C. §2255 violates the Equal Protection Clause of the 14 Amendment
+under the U.S. Constitution, and thus Plaintiff's claim thereunder is barred.
+20. 18 U.S.C. §2255 violates the constitutional guarantees of procedural and
+substantive due process. Procedural due process guarantees that a person will not be
+deprived of life, liberty or property without notice and opportunity to be heard.
+Substantive due process protects fundamental rights. Accordingly, Plaintiff's cause of
+action thereunder is barred.
+WHEREFORE Defendant requests that this Court deny the relief sought by Plaintiff.
+Robert D. Critton, Jr.
+Attorney før Defendant Epstein
+
+
+Case 9:08-CV-80893-KAM Document 38
+
+Case No.: 08-CIV-80893 - MARRA/JOHNSON
+JANE DOE,
+Plaintiff,
+V.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFF'S FIRST AMENDED COMPLAINT
+Parties, Jurisdiction and Venue
+Plaintiff, Jane Doe, hereby brings this First Amended Complaint against
+Defendant, Jeffrey Epstein, and states as follows:
+1.
+This is an action for damages in an amount in excess of $50,000,000.00,
+exclusive of interest and costs.
+2.
+This First Amended Complaint is brought under a fictitious name in order
+to protect the identity of Plaintiff, Jane Doe, because this Complaint makes allegations
+of sexual assault and child abuse of a then minor.
+At all times material to this cause of action, Plaintiff, Jane Doe, was a
+resident of Palm Beach County, Florida.
+4.
+At all times material to this cause of action, Defendant, Jeffrey Epstein,
+was a resident of the State of New York.
+5.
+At all times material to this cause of action, Defendant, Jeffrey Epstein,
+had a residence located in Palm Beach County, Florida.
+
+
+
+12.
+Plaintiff Jane Doe was contacted by Defendant Jeffrey Epstein himself or
+HE or other unknown employees or assistants of Defendant Epstein on
+numerous occasions, and she was often times brought to Defendant Epstein's
+residence with the assistance of Defendant Epstein's assistants.
+13.
+Hor other employees/assistants of Defendant Epstein would
+often arrange with the Yellow Cab cab company to take minor girls, including Jane Doe,
+to Defendant Epstein's house.
+14.
+Once the then minor girl, including Plaintiff Jane Doe, arrived at Epstein's
+house, the assistants and employees left the then minor Plaintiff and other minor girls
+alone in a room at the defendant's mansion. Subsequently, Defendant, Jeffrey Epstein,
+himself would appear, remove his clothing, and direct the then minor Plaintiff to remove
+her clothing. He would then perform one or more lewd, lascivious, and sexual acts,
+including, but not limited to, masturbation, touching of the then minor Plaintiffs sexual
+organs, using vibrators or sexual toys on the then minor Plaintiff, and digitally
+penetrating the then minor Plaintiff.
+15.
+Defendant Epstein traveled to his mansion in Palm Beach for the purpose
+of luring minor girls to his mansion to sexually abuse or batter them; he used the
+telephone to contact these minor girls for the purpose of coercing them into acts of
+prostitution and to enable himself to commit sexual battery against them and acts of
+lewdness in their presence, and he conspired with others, including his assistants l
+HILL and
+to further commit these acts and to avoid police
+detection.
+3
+
+
+
+Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should
+have known of the plaintiff, Jane Doe's minority.
+21. The above-described acts were perpetrated upon the person of the then
+minor Plaintiff regularly and on dozens of occasions.
+22.
+In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County,
+Florida, Defendant, Jeffrey Epstein, entered pleas of "guilty" to various Florida state
+crimes involving the solicitation of minors for prostitution and the procurement of minors
+for the purposes of prostitution, for which Defendant Epstein was sentenced to 18
+months incarceration in Palm Beach County jail to be followed by 12 months community
+control (house arrest).
+COUNT !
+Sexual Battery upon a Minor
+The Plaintiff, Jane Doe, repeats and realleges paragraphs 1 through 21
+23.
+above.
+24. On numerous occasions, Defendant Epstein did in fact intentionally touch
+Plaintiff, Jane Doe, on her person against her will and/or without her legal consent.
+25.
+Defendant Epstein battered her sexually, in that he touched her in intimate
+areas of her body and person in an offensive manner while she was a minor child, and
+therefore the touchings were without legal consent.
+26.
+Defendant Epstein touched her in intimate areas of her body on dozens of
+occasions between approximately February 2003 and approximately June 2005.
+27.
+The conduct described in this count constitutes battery against the person
+of the then minor Plaintiff.
+5
+
+
+Case 9:08-cv-80893-KAM Document 38 Entered on FLSD Docket 04/17/2009
+
+federal offenses, the Defendant, Jeffrey Epstein, entered into a Non-Prosecution
+Agreement with the Federal Government, wherein he acknowledged Plaintiff Jane Doe
+as a victim of certain criminal offenses he committed against Jane Doe.
+32. The Plaintiff, Jane Doe, was in fact a victim of one or more offenses
+enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause
+of action against the Defendant, Jeffrey Epstein, pursuant to this Section of the United
+States Code and the agreement between the Defendant, Jeffrey Epstein, and the
+United States Government.
+33.
+Specifically, Defendant Epstein:
+(a)
+knowingly conspired with others known and unknown to use a
+facility or means of interstate commerce to knowingly persuade, induce, or entice
+minor females, including Plaintiff Jane Doe, to engage in prostitution, in violation
+of title 18, United States Code, Section 2422(b).
+(b)
+knowingly and willfully conspired with others known (such as
+and unknown to travel in interstate commerce for the purpose of
+engaging in illicit sexual conduct with minors, including Plaintiff Jane Doe, as
+defined in 18 U.S.C. § 2423(f), with minor females, in violation fo Title 18, United
+States Code, Section 2423(b); all in violation of Title 18, United States Code,
+Section 2423(e);
+(c)
+used a facility or means of interstate or foreign commerce to
+knowingly persuade, induce, or entice minor females, including Plaintiff Jane
+Doe, to engage in prostitution; in violation of Title 18, United States Code,
+Section 2422(b);
+7
+
+
+
+COUNT !!!
+Intentional Infliction of Emotional Distress
+35.
+Plaintiff, Jane Doe, adopts and realleges paragraphs 1 through 22 above.
+36. Defendant Jeffrey Epstein's inappropriate sexual conduct towards the then
+minor Plaintiff was extreme and outrageous; under the circumstances, his conduct was
+outrageous and so extreme in degree that it should not be tolerated in a civilized
+community.
+37. Defendant Jeffrey Epstein acted with the intent to cause severe emotional
+distress or with reckless disregard of the high probability of causing severe emotional
+distress upon the then minor Plaintiff.
+38.
+Defendant Jeffrey Epstein was well aware that Plaintiff was a minor child,
+and yet he continued to sexually abuse her, intentionally and recklessly causing Plaintiff
+to suffer extreme emotional distress.
+39.
+Defendant Jeffrey Epstein's intentional, deliberate and reckless conduct
+caused severe emotional distress to the Plaintiff, Jane Doe. Defendant, at the time he
+committed these numerous sexual assaults on Plaintiff, Jane Doe, had a specific intent
+to harm the then minor Plaintiff, and his conduct did so harm the Plaintiff.
+40.
+As a direct and proximate result of Defendant, Jeffrey Epstein's intentional
+and reckless conduct, Plaintiff, Jane Doe, has in the past suffered and in the future will
+continue to suffer severe emotional distress, physical injury, pain and suffering,
+psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem,
+loss of dignity, invasion of her privacy and other damages associated with Defendant,
+Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and
+9
+
+
+Case 9:08-cv-80893-KAM
+
+violation of Florida Statutes §772.103(3)-(4), as further outlined in detail in the RICO
+statement filed with this court.
+44. This enterprise was separate and distinct from Epstein himself and had a
+definite hierarchical structure. Epstein served informally but effectively as the leader,
+C.E.O, or "boss" of this organization, directing his underlings how to recruit and procure
+young girls for his sexual activities and when to bring the girls to his mansion. Epstein's
+key "lieutenant" in the organization was
+who served as both his scheduler and a
+recruiter/procurer of the girls.
+also served as a recruiter and helped Epstein
+satisfy his criminal sexual desires by, on occasion, directly participating in sexual abuse
+and prostitution of the minor girls. Epstein also used otherwise-legitimate business
+activities to help further the purpose of the criminal enterprise. These apparently
+legitimate activities provided "cover" for Epstein and his associates to commit the
+crimes.
+Epstein and his associates maintained the appearance of running an
+upstanding investment business, as well as other legitimate businesses with
+connections to modeling agencies and other powerful business and political people, to
+discourage the minor girls from reporting the abuse to law enforcement.
+45. Defendant Jeffrey Epstein participated in this enterprise through a pattern
+of criminal activity in that he engaged in at least two incidents of criminal activity, as
+defined in Florida Statute 772.102 and as described below, that have the same or
+similar intents, results, accomplices, victims, or methods of commission and are not
+isolated incidents.
+46.
+Defendant Jeffrey Epstein engaged in criminal activity by committing,
+attempting to commit, conspiring to commit or soliciting, coercing or intimidating another
+11
+
+
+Case 9:08-cv-80893-KAM
+
+47. The criminal acts of Defendant Epstein occurred repeatedly over a
+substantial period of time and were not isolated events.
+48.
+Under Defendant, Jeffrey Epstein's plan, scheme, and enterprise,
+Defendant, Jeffrey Epstein, paid employees and underlings, including but not limited to
+to bring him minor girls to his Palm Beach mansion in order for the
+Defendant to solicit, induce, coerce, entice, compel or force such girls to engage in acts
+of prostitution and sexual misconduct with Defendant Epstein and sometimes
+, and to otherwise commit acts of sexual battery thereon.
+49. Plaintiff, Jane Doe, was the victim of Defendant, Jeffrey Epstein's plan,
+scheme, and enterprise and was so injured by reason of his violations of the provisions
+of s. 772.104. Plaintiff, Jane Doe, was called on the telephone by Defendant Epstein
+and other employees of his, including
+. and transported to the Defendant,
+Jeffrey Epstein's residence, where she was placed in a room along with the Defendant,
+enticed to commit acts of prostitution, and had acts of sexual battery and sexual
+exploitation committed against her. Defendant, Jeffrey Epstein, conspired with his
+assistants and employees in order to accomplish their common motive or intent of
+seeking out, gaining access to, and exploiting minor children such as the Plaintiff, Jane
+Doe, in the aforementioned ways, and he further conspired with his employees,
+assistants and underlings to ensure that the crimes of this criminal enterprise were
+concealed or undetected by law enforcement.
+50.
+After law enforcement began to detect the criminal activities of Defendant
+Epstein and the other persons involved in the criminal enterprise, the enterprise used
+resources and information to conceal the illegal activities of the enterprise, threaten the
+13
+
+
+Entered on FLSD Docket 04/17/2009 Page 15 of 18
+COUNT V
+Cause of Action Pursuant to Florida Statute 796.09
+Against Defendant, Jeffrey Epstein
+Plaintiff adopts and realleges paragraphs 1 through 22 above.
+55. The allegations contained herein in Count I| are a separate and distinct
+54.
+legal remedy.
+56.
+57.
+Defendant, Jeffrey Epstein, was a wealthy and powerful man, and Plaintiff
+was an economically disadvantaged and impressionable minor.
+Defendant, Jeffrey Epstein, used his vast wealth and power to coerce
+Plaintiff into prostitution and/or coerced her to remain in prostitution.
+58.
+Defendant, Jeffrey Epstein, coerced Plaintiff into prostitution in one or
+more of the following ways:
+A.
+Domination of her mind and body through exploitive techniques;
+B. Inducement;
+C. Promise of greater financial rewards;
+D. Exploitation of a condition of developmental disability, cognitive
+limitation, affective disorder, and/or substance dependency;
+E. Exploitation of human needs for food, shelter or affection;
+F. Exploitation of underprivileged and vulnerable economic condition
+or situation;
+G.
+Use of a system of recruiting other similarly situated minor girls to
+further coerce and induce Plaintiff into the lifestyle of prostitution; and
+15
+
+
+Case 9:08-CV-80893-KAM
+
+Respectfully Submitted,
+Plaintiff, by One of Her Counsel,
+s/ Bradley J. Edwards
+Bradley J. Edwards
+ROTHSTEIN ROSENFELDT ADLER
+Las Olas City Centre
+401 East Las Olas Blvd., Suite 1650
+Fort Lauderdale, Florida 33301
+Florida Bar No: 542075
+CERTIFICATE OF SERVICE
+1 HEREBY CERTIFY that on April 17, 2009, I electronically filed the foregoing
+document with the Clerk of Court using CM/ECF. I also certify that the foregoing is
+being served this day upon all counsel of record identified on the attached Service List
+in the manner specified, either via transmission of Notices of Electronic Filing generated
+by CM/ECF or in some other authorized manner for those counsel or parties who are
+not authorized to receive electronically Notices of Electronic Filing.
+s/ Bradley J. Edwards
+Bradley J. Edwards
+17
+
+
+'Case 9:08-cv-80993-KAM Document 52
+
+CASE NO.: 08-CV-80993-MARRA
+Plaintiff,
+v.
+JEFFREY EPSTEIN,
+Defendant.
+MOTION TO COMPEL AND/OR IDENTIFY
+N THE STYLE OF
+THIS CASE AND MOTION TO IDENTIFY JANE DOE IN THIRD-PARTY
+SUBPOENAS FOR PURPOSES OF DISCOVERY, OR ALTERNATIVELY,
+MOTION TO DISMISS SUA SPONTE, WITH INCORPORATED
+MEMORANDUM OF LAW
+Defendant, JEFFREY EPSTEIN ("Epstein" or "Defendant"), by and
+through his undersigned attorneys, hereby requests that this Court enter an order
+identifying in the style of this case the complete legal name of the Plaintiff, JANE
+o substitute her complete legal name in this case in
+place of "JANE DOE" and, equally important, allowing Defendant to identify her in
+various subpoenas that Epstein must serve so Epstein can defend this case or,
+alternatively, Motion to Dismiss Entire Action Sua Sponte. In support, Mr.
+Epstein states as follows;
+• Several of the discovery responses attached to this Motion and to the
+companion
+"Motions to Identify" filed in other related matters
+markedly different.
+Therefore, each requires the court's attention on
+an individual basis.
+1
+
+
+'Case 9:08-cv-80993-KAM |
+Document 52
+
+Coercion and Enticement to Sexual Activity in violation of 18 U.S.C. §2422,
+plaintiff claims entitlement to recover for "...personal injury, including mental,
+psychological and emotional damages" 1733, Am. Comp., DE 19. See also
+Exhibit "A", Interrogatory Response Number 9. Plaintiff also claims entitlement
+to "punitive damages" and "actual and compensatory damages." DE 19.
+6.
+Epstein has a constitutional due process right to defend himself and
+to seek the production of information that will assist in his defense of the
+allegations in the Amended Complaint. In this case, Plaintiff's counsel objected
+to Epstein serving subpoenas on Plaintiff's treating physicians and other third
+parties. Thus, this motion seeks to identify JANE DOE in the style of this case, to
+identify JANE DOE in various third-party subpoenas for discovery purposes and,
+• alternatively, to dismiss this entire action sua sponte. The undersigned's
+experience in "Jane Doe" lawsuits is that once a Plaintiff is identified, other
+individuals come forward in the discovery phase with information which often
+directly contradicts allegations as to the events and damages. For instance,
+witnesses may testify that Plaintiff was paid by others for similar sexual acts she
+claims Mr. Epstein forced upon her or that she willingly participated in certain
+acts) that would negate or lessen her damages. This goes directly to Plaintiff's
+damage claim.
+Likewise, subpoenas must be issued to third-party treaters and
+current and former employers, and those subpoenas will seek to obtain records
+related directly to Plaintiff's claims and her damages (i.e., her claim for severe
+and permanent traumatic injuries, including mental, psychological and emotional
+
+
+Case 9:08-CV-80993-KAM Document 52
+
+is not the case when a Plaintiff places her mental, emotional, psychological and
+physical condition at issue.
+Moreover, when an order from the court is attached to the
+Subpoena, treaters and other third parties produce the records and show up to
+the depositions with the records requested because the deponent knows what to
+bring by virtue of knowing the identity of the Plaintiff.
+10.
+Epstein's counsel intends to serve and depose witnesses duces
+tecum. If Epstein is not permitted to identify JANE DOE, how will any deponent
+know who the parties are and what to bring to the deposition pursuant to the
+duces tecum? Further, how will Epstein be able to defend the claims. Just like
+the Plaintiff, Epstein is entitled to due process.
+11.
+While it is within the sound discretion of this court to allow a party to
+proceed anonymously, Plaintiff should not attempt to utilize that discretion as a
+shield from legitimate and necessary discovery. Epstein has a fundamental due
+process right to conduct discovery.
+b. Motion To Identify JANE DOE In Style Of This Case
+12. As discussed below, Epstein has fundamental due process right to
+defend himself in this civil litigation.
+While JANE DOE travels under a
+pseudonym, various newspaper articles identifying Epstein have been released
+discussing the alleged claims against him. Allowing JANE DOE to litigate this
+matter under a pseudonym is preventing Epstein from defending this suit
+including, but not limited to, preventing him from locating individuals that may
+have information about this lawsuit and information about JANE DOE that may
+
+
+Case 9:08-CV-80993-KAM Document 52 Entered on FLSD Docket 05/07/2009
+
+Doe v. Frank, 951 F.2d at 323.
+Plaintiff does not fall under any of the factors. Moreover, even if she did
+meet one of the factors, "ItJhe fact that [a] Doe [Plaintiff] may suffer some
+personal embarrassment, standing alone, does not require the granting of a
+request to proceed under a pseudonym." Id; see also Doe v. Rostker, 89 F.R.D.
+159 (N.D. Calif. 1981). Any substantial privacy interests JANE DOE has must
+outweigh the customary and constitutionally embedded presumption of openness
+to judicial proceedings. Doe v. Frank, 951 F.2d at 323; Doe v. Bergstron, 2009
+WL 528623 (C.A.9(Or.))(denying request to proceed anonymously in civil action
+by Plaintiff where Plaintiff's arrest, prosecution and acquittal were matters of
+public record).
+14. In Sweetland v. State, 535 So.2d 646 (Fla. 18" DCA 1988), the court
+reasoned that the purpose of discovery is to eliminate the likelihood of surprise
+and to insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure
+1.280(b)(1); see also Surf Drugs, Inc., v. Vermette, 236 So.2d 108, 111 (Fla.
+1970)(stating that the rules of discovery should be afforded broad and liberal
+treatment to effectuate their purpose), citing, Hickman v. Taylor, 329 U.S. 495,
+501, 507 (1947).
+15.
+Next, the right to go to court to resolve disputes is a fundamental right.
+D.R. Lakes, Inc. v. Brandsmart U.S.A. of West Palm Beach, 819 So.2d 971 (Fla. 4"*
+DCA 2002). All litigants are afforded an equal opportunity. Lingle v. Dion, 776
+So.2d 1073 (Fla. 4' DCA 2001). The Florida Constitution establishes the right
+commonly known as access to courts. Mitchell v. Moore, 786 So.2d 521 (Fla.
+7
+
+
+•Case 9:08-cv-80993-KAM Document 52 Entered on FLSD Docket 05/07/2009
+
+others, diminished sense of future prospects, corruption of morals, distorted and
+disrupted development, loss of normal adolescent ideals." (Emphasis Added).
+Id. Epstein is also entitled to know, among other things, whether she had any
+physical complaints or whether there was ever any evidence of physical battery
+on JANE DOE's body from the acts she complains of in the Amended Complaint.
+The need to serve third-party subpoenas on medical doctors is a basic discovery
+need related to the claims alleged by JANE DOE for which Plaintiff's counsel
+refuses to compromise. Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5' DCA 1997),
+rev. denied, 719 So.2d 286 (Fla. 1998)(discoverability of Plaintiff's history of
+sexual activity is relevant to damages); United States v. Bear Stops, 997 F.2d
+451(8" Cir. 1993)(deals with "admissibility of other acts of sexual abuse by
+individuals other than the defendant to explain why a victim of abuse exhibited
+behavioral manifestations of a sexually abused child.") If Plaintiff saw a
+psychologist or other physician during or after the time periods she claims she
+was assaulted by Epstein but either did not discuss or did discuss the incidents
+(or lack thereof) would be directly relevant to her damage claims. Plaintiff seeks
+physical and emotional/mental personal injury type damages, and the Epstein
+No valid discovery
+must conduct his own discovery thereon.
+See supra.
+objections or exemptions exist preventing necessary and reasonable discovery.
+To hold otherwise prevents Mr. Epstein from preparing and defending this matter.
+19.
+In defending this lawsuit, Mr. Epstein should be permitted broad
+discovery, whether admissible at trial or not. Fed.R.Civ.Pro. 26 provides, in
+pertinent part, that "parties may obtain discovery regarding any matter, not
+
+
+Case 9:08-CV-80993-KAM Document 52
+
+would ultimately result in reversible error at any trial.
+Il. Conclusion
+22.
+Epstein requests the following relief:
+That JANE DOE be identified by her legal name in the style of
+this case;
+That Epstein be granted leave to identify JANE DOE by her
+legal name in Third-Party Subpoenas (but not file them in Court
+or, if required, in a redacted form); and
+That, on an alternative basis, this court dismiss this action Sua
+Sponte until such time as JANE DOE identifies herself in the
+style of this matter. Doe v. Rostker, 89 F.R.D.at 163.
+WHEREFORE, Epstein, Jeffrey Epstein, respectfully requests that this
+Court enter said order granting the relief requested above, and for such other
+and further relief as this Court may deem just and nraner
+ROBERTO. CRITTON, JR., ESQ.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically
+filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing
+document is being served this day on all counsel of record identified on the
+following Service List in the manner specified by CM/ECF on this finday of May
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami. FI 33160
+ssm@sexabuseattorney.com
+11
+
+
+CM/ECF / Live Database - flsd
+
+LRJ, MEDREQ, REF_DISCOV
+U.S. District Court
+CIVIL DOCKET FOR CASE #: 9:08-cv-80993-KAM
+Jane L
+. Epstein
+Assigned to: Judge Kenneth A. Marra
+Referred to: Magistrate Judge Linnea R. Johnson
+Lead case: 9:08-cv-80119-KAM
+Member case: (View Member Case)
+Case: 2:09-cv-80802-KAM
+Cause: 28:1391 Personal Injury
+Plaintiff
+Jane
+Date Filed: 09/10/2008
+Naty e or Sult: io Labor: Fair
+Standards
+Jurisdiction: Federal Question
+represented by Adam D. Horowitz
+Mermelstein & Horowitz PA
+18205 Biscayne Boulevard
+Suite 2218
+Miami , FL 33160
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Jeffrey Mare Herman
+Herman & Mermelstein
+18205 Biscayne Boulevard
+Suite 2218
+Miami . FL 33160
+Fax: 931-0877
+Email: jherman@hermanlaw.com
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Stuart S. Mermelstein
+Mermelstein & Horowitz PA
+18205 Biscayne Boulevard
+Suite 2218
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?667278296697325-L_801_0-1
+
+
+CM/ECF , Live Database - flsd
+
+Miami , FL 33160
+Fax: 931-0877
+Email: 1
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+V.
+Defendant
+Jeffrey Epstein
+Amicus
+United States of America
+epresented by Robert Deweese Critton, Jr
+Burman Critton Luttier & Colemar
+West Palm Beach , FL 33401-2918
+ATTORNEY TO BE NOTICED
+Michael James Pike
+Burman Critton Luttier & Coleman
+Fax: 515-3148
+ATTORNEY TO BE NOTICED
+represented by
+United States Altomeys Office
+500 East Broward Blvd
+7th Floor
+Ft Lauderdale , FL 33394
+ext.3546
+Fax: 356-7336
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl7667278296697325-L_801_0-1
+
+
+Date Filed
+09/10/2008
+#
+clear Docket Text
+1
+COMPLAINT against Jeffrey Epstein Filing fee $ 350.00. Receipt#:
+463.9
+544158, filed by
+(vt) (Entered: 09/10/2008)
+09/10/2008
+2
+Summons Issued as to Jeffrey Epstein. (vt) (Entered: 09/10/2008)
+
+09/15/2008
+10/14/2008
+10/20/2008
+10/21/2008
+10/21/2008
+10/22/2008
+10/31/2008
+11/10/2008
+3
+4
+5
+8
+10.
+11
+12
+NOTICE of Attorney Appearance by Robert Deweese Critton, Jr on behalf
+130.8
+of Jeffrey Epstein (Critton, Robert) (Entered: 09/15/2008)
+ACKNOWLEDGMENT OF SERVICE Executed as to 2 Summons Issued,
+82.8 | 1 Complaint Acknowledgement filed by
+(Herman, Jeffrey)
+(Entered: 10/03/2008)
+26.1
+KB
+by
+NICE Of Striking terman, eley) Entered: 100 fizd b
+SUMMONS (Affidavit) Returned Executed by
+Epstein served on 9/23/2008, answer due 10/14/2008. (Herman, Jeffrey)
+(Entered: 10/03/2008)
+Defendant's MOTION to Dismiss 1 Complaint, MOTION for More
+1.1
+MB
+Definite Statement by Jeffrey Epstein. Responses due by 10/31/2008
+(Critton, Robert) (Entered: 10/14/2008)
+ORDER OF TRANSFER. Case is transferred to Judge Kenneth A. Marra
+for all further proceedings. Judge Daniel T. K. Hurley no longer assigned to
+46.3
+KB
+case. Signed by Judge Daniel T. K. Hurley on 10/17/2008 and Judge
+Kenneth A. Marra on 10/17/2008. (jdo) (Entered: 10/20/2008)
+CERTIFICATION AND ORDER OF TRANSFER TO MAGISTRATE
+JUDGE. Case Transferred to Magistrate Judge Linnea R. Johnson as
+referral judge in case. Magistrate Judge James M. Hopkins no longer
+assigned as referral judge(s) in case. Signed by Magistrate Judge James M.
+Hopkins on 10/21/08. (Iwl) (Entered: 10/21/2008)
+Magistrate Judge Linnea R. Johnson added per Order at DE 2. (bb)
+(Entered: 10/28/2008)
+Order Requiring Counsel to Confer and File Joint Scheduling Report.
+Signed by Judge Kenneth A. Marra on 10/21/2008. (ir) (Entered:
+10/22/2008)
+MEMORANDUM in Opposition re 7 Defendant's MOTION to Dismiss 1
+Complaint MOTION for More Definite Statement filed by
+(Attachments: # 1 Exhibit A)(Herman, Jeffrey) (Entered: 10/31/2008)
+RESPONSE/REPLY to 11 Memorandum in Opposition to Defendant's
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?667278296697325-L_801_0-1
+
+
+
+290.8 Motion to Dismiss filed by Jeffrey Epstein. (Critton, Robert) (Entered:
+11/10/2008)
+12/17/2008
+13
+NOTICE of Filing Discovery: Joint Scheduling and Discovery Report by
+Jeffrey Epstein. (Pike, Michael) (Entered: 12/17/2008)
+12/17/2008
+15
+JOINT SCHEDULING REPORT - Rule 16.1. See image DE 13 (Ik)
+(Entered: 12/18/2008)
+12/18/2008
+14
+SCHEDULING ORDER: Jury Trial set for 2/8/2010 09:00 AM in West
+Palm Beach Division before Judge Kenneth A. Marra., Calendar Call set
+for 2/5/2010 10:00 AM in West Palm Beach Division before Judge
+Kenneth A. Marra., Amended Pleadings due by 2/2/2009., Discovery due
+82.5 by 10/5/2009., Dispositive Motions due by 10/23/2009. ORDER
+REFERRING CASE to Magistrate Judge Linnea R. Johnson tor Discovery
+Proceedings, ORDER REFERRING CASE to Mediation. 15 days to
+appoint mediator. Signed by Judge Kenneth A. Marra on 12/17/2008. (ir)
+(Entered: 12/18/2008)
+12/18/2008
+16
+Clerks Notice of Docket Correction and Instruction to Filer re 13 Notice of
+Filing Discovery filed by Jeffrey Epstein. ERROR - Wrong Event
+Selected; Correction - Redocketed by Clerk as Scheduling Report-Rule 26
+(9 103 Cetuati o to File this doce future, please sered: 12 1812008)
+, please select the proper event. I
+02/12/2009
+17
+OPINION AND ORDER granting in part and denying in part 7 Motion to
+100.6
+Dismiss; denying Z Motion for More Definite Statement. Signed by Judge
+KB
+Kenneth A. Marra on 2/12/2009. (ir) (Entered: 02/12/2009)
+02/23/2009
+18
+NOTICE by
+f Change of Name of Plaintiff's Counsel
+(Horowitz., Adam) (Entered: 02/23/2009)
+02/27/2009
+19
+AMENDED COMPLAINT, filed by
+(Horowitz, Adam)
+3B (Entered: 02/27/2009)
+03/04/2009
+20
+Defendant's MOTION for Extension of Time to File Kesponse as to 19
+376 Amended Complaint with proposed Order by Jeffrey Epstein. (Critton,
+Robert) (Entered: 03/04/2009)
+03/05/2009
+21
+ENDORSED ORDER granting 20 Motion for Extension of Time to
+Answer Complaint. Jeffrey Epstein response due 4/3/2009. Signed by
+Judge Kenneth A. Marra on 3/5/2009. (ir) (Entered: 03/05/2009)
+03/25/2009
+22
+Defendant's MOTION to Stay re 19 Amended Complaint by Jeffrey
+Epstein. Responses due by 4/13/2009 (Attachments: # 1 Exhibit A, # 2
+Exhibit B)(Pike, Michael) (Entered: 03/25/2009)
+03/27/2009
+23
+MOTION for Protective Order and to Quash Subpoena for Deposition of
+Motion to Consolidate Cases for Purposes of Discovery,
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl7667278296697325-L_801_0-1
+
+
+
+03/27/2009
+03/30/2009
+04/02/2009
+04/02/2009
+04/02/2009
+04/06/2009
+04/07/2009
+04/10/2009
+24
+25
+26
+27
+28
+29
+30
+31
+and Incorporated Memorandum of Law in Support by
+1353 (Attachments: # 1 Exhibit A, # 2 Exhibit 3)(Mermelstein, Stuart) Entered:
+03/27/2009)
+MOTION to Consolidate Cases for purposes of discovery ( Responses due
+by 4/13/2009), MOTION to Quash by |
+See image DE 23
+(Ik) (Entered: 03/30/2009)
+Clerks Notice of Docket Correction and Instruction to Filer re 23 MOTION
+for Protective Order and Incorporated Memorandum of Law in Support
+Time Relief: Cored so AT CASE 24 MOTION TO CUASH
+ERROR - Motion with Multiple Reliefs Filed as
+AND MOTION CONSOLIDATE CASES docketed by Clerk. Instruction
+to filer - In the future, please select all applicable reliefs. It is not necessary
+to refile this document. (Ik) (Entered: 03/30/2009)
+Defendant's MOTION to Compel Response to Ist RTP by Jeffrey Epstein.
+2.4
+MB
+Responses due by 4/20/2009 (Attachments: # 1 Exhibit A, # 2 Exhibit B, #
+3 Exhibit C, # 4 Exhibit D)(Critton, Robert) (Entered: 04/02/2009)
+Defendant's MOTION to Compel Answers to Ist Interrogs by Jeffrey
+Epstein. Responses due by 4/20/2009 (Attachments: # 1 Exhibit A, # 2
+Exhibit B, # 3 Exhibit C)(Critton, Robert) (Entered: 04/02/2009)
+Defendant's ANSWER and Affirmative Defenses to Amended Complaint
+(Second) by Jeffrey Epstein. (Critton, Robert) (Entered: 04/02/2009)
+Defendant's MOTION for Extension of Time to File Response as to 24
+MOTION to Consolidate Cases MOTION to Quash, 23 MOTION for
+Protective Order and to Quash Subpoena for Deposition o
+Motion to Consolidate Cases for Purposes of Discovery, and Incorporated
+Memorandum of Law in Support by Jeffrey Epstein. (Pike, Michael)
+(Entered: 04/06/2009)
+ENDORSED ORDER granting 29 Motion for Extension of Time to
+Respond re 24 MOTION to Consolidate Cases MOTION to Quash, 23
+MOTION for Protective Order and to Quash Subpoena for Deposition of
+Motion to Consolidate Cases for Purposes of Discovery,
+and Incorporated Memorandum of Law in Support. Responses due by
+4/13/2009. Signed by Judge Kenneth A. Marra on 4/7/2009. (ir) (Entered:
+04/07/2009)
+Defendant's MOTION for Extension of Time to File Response as to 30
+Order on Motion for Extension of Time to File Response/Reply/Answer, 23
+MOTION for Protective Order and to Quash Subpoena for Deposition of
+1330
+Motion to Consolidate Cases for Purposes of Discovery,
+nd Incorporated Memorandum of Law in Support (Amended) by Jeffre
+ostein. (Pike. Michael) (Entered: 04/10/2009
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?667278296697325-L_801_0-1
+
+
+/04/13/2009|32
+
+04/13/2009
+33
+04/14/2009
+34
+04/16/2009
+35
+ENDORSED ORDER granting (73) Motion for Extension of Time to
+Respond re (66 in 9:08-cv-80119-KAM) MOTION for Protective Order
+and to Quash Subpoena for Deposition ofl
+• Motion to
+Consolidate Cases for Purposes of Discovery, and Incorporated
+Memorandum of Law in Support in case 9:08-cv-80119-KAM; granting
+(65) Motion for Extension of Time to Respond re (66 in 9:08-cv-80119-
+KAM) MOTION for Protective Order and to Quash Subpoena for
+Deposition of
+Motion to Consolidate Cases for Purposes of
+Discovery, and Incorporated Memorandum of Law in Support in case 9:08-
+cv-80232-KAM; granting (80) Motion for Extension of Time to Respond re
+(66 in 9:08-cv-80119-KAM) MOTION for Protective Order and to Quash
+Subpoena for Deposition o
+Motion to Consolidate Cases
+for Purposes of Discovery, and Incorporated Memorandum of Law in
+Support in case 9:08-cv-80380-KAM; granting (31) Motion for Extension
+of Time to Respond re (66 in 9:08-cv-80119-KAM) MOTION for
+Protective Order and to Quash Subpoena for Deposition of
+Motion to Consolidate Cases for Purposes of Discovery, and Incorporatea
+Memorandum of Law in Support in case 9:08-cv-80993-KAM in case 9:08-
+cv-80119-KAM. Responses due by 4/16/2009. Signed by Judge Kenneth A
+Marra on 4/13/2009. (ir) (Entered: 04/13/2009)
+Unopposed MOTION for Extension of Time to File
+Response /Memorandum in Opposition to Motion to Stay and/or Continue
+Action by
+(Attachments: # 1 Text of Proposed Order)
+(Mermelstein, Stuart) (Entered: 04/13/2009)
+ENDORSED ORDER granting (75) Motion for Extension of Time to
+Respond re (65 in 9:08-cv-80119-KAM) Defendant's MOTION to Stay re
+(56) Amended Complaint in case 9:08-cv-80119-KAM; granting (67)
+Motion for Extension of Time to Respond re (65 in 9:08-cv-80119-KAM)
+Defendant's MOTION to Stay re (56) Amended Complaint in case 9:08-cv-
+80232-KAM; granting (82) Motion for Extension of Time to Respond re
+(65 in 9:08-cv-80119-KAM) Defendant's MOTION to Stay re (56)
+Amended Complaint in case 9:08-cv-80380-KAM; granting (73) Motion
+for Extension of Time to Respond re (65 in 9:08-cv-80119-KAM)
+Defendant's MOTION to Stay re (56) Amended Complaint in case 9:08-cv-
+80381-KAM; granting (33) Motion for Extension of Time to Respond re
+(65 in 9:08-cv-80119-KAM) Defendant's MOTION to Stay re (56)
+Amended Complaint in case 9:08-cv-80993-KAM; granting (27) Motion
+for Extension of Time to Respond re (65 in 9:08-cv-80119-KAM)
+Defendant's MOTION to Stay re (56) Amended Complaint in case 9:08-cv-
+80994-KAM in case 9:08-cv-80119-KAM. ( Responses due by 4/23/2009).
+Signed by Judge Kenneth A. Marra on 4/14/2009. (ir) (Entered:
+04/14/2009)
+Defendant's MOTION for Extension of Time to File Response as to 23
+MOTION for Protective Order and to Quash Subpoena for Deposition of
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl7667278296697325-L_801_0-1
+
+
+
+04/23/2009
+04/27/2009
+04/27/2009
+36
+37
+38
+39
+40
+41
+Motion to Consolidate Cases for Purposes of Discovery,
+and Incorporated Memorandum of Law in Support by Jeffrey Epstein.
+(Pike, Michael) Modified on 4/20/2009 (Is). (Entered: 04/16/2009)
+ENDORSED ORDER granting (77) Motion for Extension of Time to
+Respond re (66 in 9:08-cv-80119-KAM) MOTION for Protective Order
+and to Quash Subpoena for Deposition of 1
+Motion to
+Consolidate Cases for Purposes of Discovery, and Incorporated
+Memorandum of Law in Support in case 9:08-cv-80119-KAM; granting
+(84) Motion for Extension of Time to Respond re (66 in 9:08-cv-80119-
+KAM) MOTION for Protective Order and to Quash Subpoena for
+Deposition of
+Motion to Consolidate Cases for Purposes of
+Discovery, and Incorporated Memorandum of Law in Support in case 9:08-
+cv-80380-KAM; granting (35) Motion for Extension of Time to Respond re
+(66 in 9:08-CV-80119-KAM) MOTION for Protective Order and to Quash
+Subpoena for Deposition of
+Motion to Consolidate Cases
+for Purposes of Discovery, and Incorporated Memorandum of Law ir
+Support in case 9:08-cv-80993-KAM in case 9:08-cv-80119-KAM.
+(Responses due by 4/24/2009). Signed by Judge Kenneth A. Marra on
+4/17/2009. (ir) (Entered: 04/17/2009)
+RESPONSE to Motion re 23 MOTION for Protective Order and to Quash
+| Subpoena for Deposition of.
+Motion to Consolidate Cases
+3396 for Purposes of Discovery, dra mcorporated Memorandum of Law in
+Support filed by Jeffrey Epstein. Replies due by 4/27/2009. (Pike, Michael)
+(Entered: 04/17/2009)
+Unopposed MOTION for Extension of Time to File Response as to 27
+Defendant's MOTION to Compel Answers to Ist Interrogs, 26 Defendant's
+42.2
+MOTION to Compel Response to Ist RTP by J
+(Attachments: # 1 Text of Proposed Order)(Mermelstein, Stuart) (Entered:
+04/17/2009)
+RESPONSE in Opposition re 22 Defendant's MOTION to Stay re 12
+Amended Complaint filed byl
+(Mermelstein, Stuart)
+(Entered: 04/23/2009)
+ORDER Granting 38 Unopposed Motion for Extension of Time to File
+Memorandum in Opposition to 27 Defendant's MOTION to Compel
+Answers to 1st Interrogatories, 26 Defendant's MOTION to Compel
+Response to First Request to Produce. Response due by 4/29/2009. Signed
+by Magistrate Judge Linnea R. Johnson on 4/27/2009. (sa) (Entered:
+04/27/2009)
+MEMORANDUM in Support re 23 MOTION for Protective Order and to
+Quash Subpoena for Deposition of
+Motion to Consolidate
+Cases for Purposes of Discovery, and Incorporated Memorandum of Law
+(Mermelstein, Stuart) (Entered: 04/27/2009)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?667278296697325-L_801_0-1
+
+
+/ 04/29/2009
+42
+
+04/29/2009
+43
+44
+45
+Г
+ORDER granting 23 Motion for Protective Order and Consolidating Cases
+For Purposes of Discovery. Signed by Judge Kenneth A. Marra on
+4/28/2009. (cqs) (Entered: 04/29/2009)
+Unopposed MOTION for Extension of Time to File Response as to 27
+Defendant's MOTION to Compel Answers to Ist Interrogs, 26 Detendant's
+42.3
+кв
+MOTION to Compel Response to 1st RTP by |
+(Attachments: # 1 Text of Proposed Order)(Mermelstein, Stuart) (Entered:
+04/29/2009)
+MEMORANDUM in Opposition re 42 Order on Motion for Protective
+2786
+Order by Jeffrey Epstein. (Pike, Michael) (Entered: 05/04/2009)
+RESPONSE TO ORDER TO SHOW CAUSE by Jeffrey Epstein. (Pike,
+Michael) (Entered: 05/05/2009)
+46
+48
+47
+49
+Defendant's MOTION for Extension of Time to File Reply as to 39
+R Response in Opposition to Motion to Stay by Jeffiey Epstein. (Pike,
+Michael) (Entered: 05/05/2009)
+MOTION for clarification 42 Order on Motion for Protective Order by
+Jeffrey Epstein. Responses due by 5/22/2009. See image DE 45 (lk)
+(Entered: 05/06/2009)
+ENDORSED ORDER granting (89) Motion for Extension of Time to Reply
+re (65 in 9:08-cv-80119-KAM) Defendant's MOTION to Stay re (56)
+Amended Complaint; granting (81) Motion for Extension of Time to Reply
+re (65 in 9:08-cv-80119-KAM) Defendant's MOTION to Stay re (56)
+Amended Complaint in case 9:08-cv-80232-KAM; granting (97) Motion
+for Extension of Time to Reply re (65 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Stay re (56) Amended Complaint in case 9:08-cv-80580-
+KAM; granting (82) Motion for Extension of Time to Reply re (65 in 9:08-
+cv-80119-KAM) Defendant's MOTION to Stay re (56) Amended
+Complaint in case 9:08-cv-80381-KAM; granting (46) Motion for
+Extension of Time to Reply re (65 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Stay re (56) Amended Complaint in case 9:08-cv-80993-
+KAM; granting (37) Motion for Extension of Time to Reply re (65 in 9:08-
+cv-80119-KAM) Defendant's MOTION to Stay re (56) Amended
+Complaint in case 9:08-cv-80994-KAM in case 9:08-cv-80119-KAM.
+(Replies due by 5/20/2009.). Signed by Judge Kenneth A. Marra on
+5/5/2009. (ir) (Entered: 05/06/2009)
+Clerks Notice of Docket Correction and Instruction to Filer re 45 Response
+to Order to Show Cause filed by Jeffrey Epstein. ERROR - Two or More
+Document Events Filed as One; Correction - Additional events) 48
+MOTION FOR CLARIFICATION docketed by Clerk. Instruction to Filer -
+In the future, please select all applicable events. It is not necessary to refile
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl7667278296697325-L_801.
+
+
+
+50
+51
+05/07/2009
+52
+05/07/2009
+53
+05/08/2009
+54
+05/11/2009
+55
+05/13/2009
+56
+57
+58
+59
+this document. (Ik) (Entered: 05/06/2009)
+RESPONSE in Opposition re 27 Defendant's MOTION to Compel Answers
+to Ist Interrogs and for an Award of Reasonable Expenses hiled by
+Horowitz, Adam) (Entered: 05/06/2009
+RESPONSE in Opposition re 26 Defendant's MOTION to Compel
+348*
+Response to Ist RTP, Overrule Obiections and for an Award of
+Reasonable Expenses filed by
+(Attachments: # 1 Exhibit
+A)(Horowitz, Adam) (Entered: 05706/2009)
+Defendant's MOTION to Compel and/or Identify Doe #7 in the Style of this
+Case and in Third-Party Subpoenas by Jeffrey Epstein. Responses due by
+0.8
+MB
+5/26/2009 (Attachments: # 1 Exhibit A)(Pike, Michael) (Entered:
+05/07/2009)
+Alternative MOTION to Dismiss 1 Complaint by Jeffrey Epstein.
+Responses due by 5/26/2009. See image DE 52 (Ik) (Entered: 05/08/2009)
+Clerks Notice of Docket Correction and Instruction to Filer re 52
+Defendant's MOTION to Compel and/or Identify Doe #7 in the Style of this
+Case and in Third-Party Subpoenas filed by Jeffrey Epstein. ERROR -
+Motion with Multiple Reliefs Filed as One Relief; Correction -
+Additional relief(s) 53 MOTION TO DISMISS docketed by Clerk.
+Instruction to filer - In the future, please select all applicable reliets. It is
+not necessary to refile this document. (Ik) (Entered: 05/08/2009)
+Defendant's MOTION Require Plaintiff to Use Proper Case Style by
+203.0
+KB
+Jeffrey Epstein. (Critton, Robert) (Entered: 05/11/2009)
+RESPONSE/REPLY to 39 Response in Opposition to Motion to Stay
+and/or Continue Action by Jeffrey Epstein. (Pike, Michael) (Entered:
+05/13/2009)
+Cases associated. (dg) (Entered: 05/14/2009)
+ORDER CONSOLIDATING CASES. Hereinafter all motions and other
+court filings that relate to discovery and all procedural motions that relate to
+multiple cases shall be styled with all of the case names and numbers and
+106S
+shall be filed in Case No. 08-80119-CIV-MARRA. Signed by Judge
+Kenneth A. Marra on 5/14/2009. Associated Cases: 9:08-cv-80119-KAM et
+al. (ir) (Entered: 05/14/2009)
+ORDER REQUESTING UNITED STATES PROVIDE POSITION TO
+MOTION TO STAY. Signed by Judge Kenneth A. Marra on 5/14/2009.
+1.3
+MB
+| (Attachments: # 1 Appendix Motion to Stay DE 51) Associated Cases:
+9:08-cv-80119-KAM et al. (ir) (Entered: 05/14/2009)
+ORDER denying as moot 48 Motion for Clarification; denying as moot 55
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?667278296697325-L_801_
+
+
+
+05/18/2009
+05/19/2009
+60
+61
+62
+63
+64
+65
+66
+Motion; denying as moot 24 Motion to Consolidate Cases; denying as
+Kenneth A Mano on 5)4.200 der stered: 05/4720009)
+Signed by Judge
+ORDER terminating 52 Motion to Compel; terminating 53 Motion to
+Dismiss; terminating 22 Motion to Stay. See Order consolidating cases. See
+procedural motions pending: DE 65 and DE 91 in 08-80119.. Signed by
+Judge Kenneth A. Marra on 5/14/2009. (lc3) (Entered: 05/14/2009)
+Defendant's MOTION for Extension of Time to File Reply as to (39 in
+9:08-cv-80994-KAM) Response in Opposition to Motion, (40 in 9:08-cv-
+174.3
+80994-KAM) Response in Opposition to Motion by Jeffrey Epstein.
+Associated Cases: 9:08-cv-80119-KAM et al.(Pike, Michael) (Entered:
+05/18/2009)
+Defendant's MOTION to Strike Cases from Current Trial Docket by
+| Jeffrey Epstein. Responses due by 6/8/2009 (Attachments: # 1 Exhibit A)
+0.8
+MB
+Associated Cases: 9:08-cv-80119-KAM et al.(Pike, Michael) (Entered:
+05/19/2009)
+ORDER terminating (93) Motion to Strike ; terminating (94) Motion in
+case 9:08-cv-80232-KAM; terminating (110) Motion to Strike ; terminating
+(111) Motion in case 9:08-cv-80380-KAM; terminating (95) Motion to
+Strike ; terminating (96) Motion in case 9:08-cv-80381-KAM; terminating
+(90) Motion to Strike ; terminating (91) Motion in case 9:08-cv-80811-
+KAM; terminating (62) Motion to Strike in case 9:08-cv-80893-KAM;
+terminating (62) Motion to Strike in case 9:08-cv-80993-KAM; terminating
+(50) Motion to Strike in case 9:08-cv-80994-KAM. Signed by Judge
+Kenneth A. Marra on 5/20/2009. (Ic3) (Entered: 05/20/2009)
+Clerks Notice of Docket Correction and Instruction to Filer re 62 MOTION
+to Strike filed by Jeffrey Epstein. Error - Motion with Multiple Reliets
+Filed as One Relief;. Instruction to filer - In the future, please select all
+applicable reliefs. It is not necessary to refile this document. (Is) (Entered:
+NOTICE by
+1. of Filing Withdrawal of Previously Raised Objections
+to Defendant, Jeffrey Epstein's Motion to Compel And/Or Identify
+in the Style of This Case and Motion to Identify
+in Third-Party
+3631฿
+Subpoenas for Purposes of Discovery, Or, Alternatively, Motion to Dismiss
+Sua Sponte, With Inorporated Memorandum of Law Associated Cases:
+9:08-cv-80119-KAM et al.(Hill, Jack) (Entered: 05/20/2009)
+ORDER STRIKING in all Epstein cases EXCEPT case no. 08-80119:
+Notice by L
+. of Filing Withdrawal of Previously Raised Objections to
+Epstein's Motion to Compel and/or Identity. This Notice should only be
+filed in 08-80119, not in all of the Epstein cases.. Signed by Judge Kenneth
+A. Marra on 5/20/2009. Associated Cases: 9:08-CV-80119-KAM et al. (Ic3)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl2667278296697325-L_801_0-1
+
+
+
+05/21/2009
+67
+68
+69
+70
+71
+(Entered: 05/20/2009)
+Plaintiff's MOTION for Extension of Time to File Response as to (91 in
+9:08-cv-80119-KAM) Defendant's MOTION to Compel Identity of Doe in
+Style of Case and Third-Party Subpoenas (replaces Docket entry 90) by
+Associated Cases: 9:08-cv-80119-KAM et al.
+(Mermelstein, Stuart) (Entered: 05/21/2009)
+ORDER terminating (100) Motion for Extension of Time to Respond in
+case 9:08-cv-80232-KAM; terminating (117) Motion for Extension of Time
+to Respond in case 9:08-cv-80380-KAM; terminating (101) Motion for
+Extension of Time to Respond in case 9:08-cv-80381-KAM; terminating
+(67) Motion for Extension of Time to Respond in case 9:08-cv-80993-
+KAM; terminating (54) Motion for Extension of Time to Respond in case
+9:08-cv-80994-KAM. The attorneys are instructed again to ONLY file this
+type of motion in case no. 08-80119. See Order consolidating cases for
+details.. Signed by Judge Kenneth A. Marra on 5/22/2009. (Ic3) (Entered:
+05/22/2009)
+Clerks Notice of Docket Correction and Instruction to Filer re 65 Notice
+(Other), Notice (Other) filed by
+... Error - Incorrect Document
+Link/No Link;. Instruction to filer - In the future, please link the document
+to the proper entry. It is not necessary to refile this document. (IS) (Entered:
+05/22/2009)
+NOTICE by Jane Doe re (111 in 9:08-cv-80119-KAM) Plaintiff's
+MOTION for Extension of Time to File Response as to (91 in 9:08-cv-
+80119-KAM) Defendant's MOTION to Compel Identity of Doe in Style of
+Case and Third-Party Subpoenas (replaces Docket entry 90) Plaintiff's
+MOTION for Extension of Time to File Response as to (91 in 9:08-cv-
+80119-KAM) Defendant's MOTION to Compel Identity of Doe in Style of
+Case and Third-Party Subpoenas (replaces Docket entry 90) (Attachments:
+# 1 Text of Proposed Order)Associated Cases: 9:08-cv-80119-KAM et al.
+(Horowitz, Adam) (Entered: 05/27/2009)
+ORDER STRIKING Notice by Jane Doe in all Epstein cases EXCEPT in
+case 08-80119. This Notice should only be filed in 08-80119, not in all of
+72
+11.6
+KB
+73
+NOTICE of Attorney Appearance by
+on behalf of
+United States of America Associated Cases: 9:08-cv-80119-KAM et al.
+D (Entered: 05/29/2009)
+RESPONSE to Motion re (72 in 9:08-cv-80380-KAM) Defendant's
+MOTION to Stay re (62) Amended Complaint, (57 in 9:08-cv-80232-
+KAM) Defendant's MOTION to Stay re (50) Amended Complaint, (24 in
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?667278296697325-L_801_0-1
+
+
+
+06/01/2009
+74
+75
+76
+77
+78
+43.3
+KB
+24.5
+19.5
+9:08-cv-80893-KAM) Defendant's MOTION to Stay re (1) Complaint, (23
+in 9:08-cv-80994-KAM) Defendant's MOTION to Stay re (18) Amended
+Complaint, (22 in 9:08-cv-80993-KAM) Defendant's MOTION to Stay re
+(19) Amended Complaint, (65 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Stay re (56) Amended Complaint, (68 in 9:08-cv-80381-
+KAM) Defendant's MOTION to Stay re (60) Amended Complaint, (51 in
+9:08-cv-80811-KAM) Defendant's MOTION to Stay re (40) Amended
+Complaint and or Continue Action Filed Pursuant to Court's Order
+Requesting Government's Position filed by United States of America.
+Replies due by 6/8/2009. Associated Cases: 9:08-cv-80119-KAM et al.
+) (Entered: 05/29/2009)
+RESPONSE in Opposition re (90 in 9:08-cv-80119-KAM) Detendant's
+MOTION to Compel Identify Doe in Style of Case and in Third-Party
+Subpoenas, (91 in 9:08-cv-80119-KAM) Defendant's MOTION to Compel
+Identity of Doe in Style of Case and Third-Party Subpoenas (replaces
+Cases: 9.08-- 019-KAM et al(Bell, Katherine (Entered: 051202109)
+ORDER STRIKING (124 in 9:08-cv-80119-KAM, 105 in 9:08-cv-80811-
+KAM, 74 in 9:08-cv-80993-KAM, 72 in 9:08-cv-80893-KAM, 106 in 9:08-
+cv-80232-KAM, 123 in 9:08-cv-80380-KAM, 35 in 9:09-cv-80591-KAM,
+25 in 9:09-cv-80469-KAM, 60 in 9:08-cv-80994-KAM, 22 in 9:09-cv-
+80656-KAM, 107 in 9:08-cv-80381-KAM) Response in Opposition to
+Motion, filed by
+DO NOT FILE IN
+EVERY EPSTEIN CASE. SEE ORDER CONSOLIDATING CASES..
+Signed by Judge Kenneth A. Marra on 5/29/2009. Associated Cases: 9:08-
+cv-80119-KAM et al. (Ic3) (Entered: 05/29/2009)
+MOTION for Leave to File UNDER SEAL RESPONSE IN OPPOSITION
+TO DEFENDANTS MOTION TO STAY OR, IN THE ALTERNATIVE, TO
+UNSEAL THE NONPROSECUTION AGREEMENT by
+Associated Cases: 9:08-cv-80119-KAM et al.(Ezell,
+Katherine) (Entered: 05/29/2009)
+MOTION for Hearing MOTION TO RESCHEDULE HEARING by
+Associated Cases: 9:08-cv-80119-KAM et
+al. (Josefsberg, Robert) (Entered: 05/29/2009)
+ORDER STRIKING (28 in 9:09-cv-80469-KAM, 126 in 9:08-cv-80380-
+KAM, 109 in 9:08-cv-80232-KAM, 25 in 9:09-cv-80656-KAM, 77 in 9:08-
+cv-80993-KAM, 38 in 9:09-cv-80591-KAM, 110 in 9:08-cv-80381-KAM,
+63 in 9:08-cv-80994-KAM, 75 in 9:08-cv-80893-KAM, 108 in 9:08-cv-
+80811-KAM) Motion to Continue Hearing filed by
+(76 in 9:08-cv-80993-KAM, 109 in 9:08-cv-80381-KAM,
+108 in 9:08-cv-80232-KAM, 62 in 9:08-cv-80994-KAM, 125 in 9:08-cv-
+80380-KAM, 74 in 9:08-cv-80893-KAM, 24 in 9:09-cv-80656-KAM, 37 in
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|?667278296697325-L_801_0-1
+
+
+
+06/01/2009
+06/08/2009
+06/08/2009
+06/09/2009
+79
+80
+81
+82
+83
+9:09-Cv-80591-KAM, 107 in 9:08-cv-80811-KAM, 27 in 9:09-cv-80469-
+KAM) Motion for Leave to File, filed byl
+THESE DOCUMENTS SHOULD BE FILED ONLY IN 08-80119.
+SEE CASE MANAGEMENT ORDER.. Signed by Judge Kenneth A.
+Marra on 6/1/2009. (Ic3) (Entered: 06/01/2009)
+Reset Scheduling Order Deadlines: Calendar Call set for 5/28/2010 10:00
+AM in West Palm Beach Division before Judge Kenneth A. Marra., Jury
+Trial set for 6/1/2010 09:00 AM in West Palm Beach Division before Judge
+Kenneth A. Marra., Discovery due by 12/11/2009., Dispositive Motions
+due by 1/8/2010. (ir) (Entered: 06/01/2009)
+REPLY to Response to Motion re (113 in 9:08-cv-80119-KAM) Plaintiffs
+MOTION Plaintiffs J
+Motion for No-
+Contact Order Plaintiffs
+ply
+349.0 | to Defendant Jeffrey Epstein's Response to Plaintiffs
+nd
+Motion for a No-Contact Order filed by
+Associated Cases: 9:08-cv-80119-KAM et al.
+(Ezell, Katherine) (Entered: 06/04/2009)
+ORDER STRIKING (112 in 9:08-cv-80381-KAM, 111 in 9:08-cv-80232-
+KAM, 136 in 9:08-cv-80119-KAM, 111 in 9:08-cv-80811-KAM, 128 in
+9:08-cv-80380-KAM, 65 in 9:08-cv-80994-KAM, 79 in 9:08-cv-80893-
+KAM, 42 in 9:09-cv-80591-KAM, 27 in 9:09-cv-80656-KAM, 32 in 9:09-
+cv-80469-KAM, 79 in 9:08-cv-80993-KAM) Reply to Response to Motion,
+filed byl
+Document stricken for failure
+to follow Court's orders. DO NOT FILE A DOCUMENT IN EVERY
+EPSTEIN CASE if it is to be filed only in 08-80119. See Case Management
+Order and contact CM/ECF Support for assistance in proper filing.. Signed
+by Judge Kenneth A. Marra on 6/4/2009. Associated Cases: 9:08-cv-80119-
+KAM et al. (Ic3) (Entered: 06/04/2009)
+RESPONSE to Motion re (91 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Compel Identity of Doe in Style of Case and Third-Party
+Subpoenas (replaces Docket entry 90) filed by Jane Doe. Replies due by
+6/18/2009. (Attachments: # 1 Exhibit A, # 2 Exhibit B)Associated Cases:
+9:08-cv-80119-KAM et al. (Horowitz, Adam) (Entered: 06/08/2009)
+NOTICE by Jane Doe re (113 in 9:08-cv-80119-KAM) Plaintiff's
+MOTION Plaintiffs
+Motion for No-
+106.1
+KB
+Contact Order -Plaintiffs
+Totice of Joinder Associated
+Cases: 9:08-cv-80119-KAM et al. (Horowitz., Adam) (Entered: 06/08/2009)
+Unopposed MOTION to Amend/Correct 28 Answer to Amended
+Complaint by Jeffrey Epstein. Responses due by 6/26/2009 (Attachments: #
+1 Exhibit "A", # 2 Exhibit "B", # 3 Text of Proposed Order Order)(Pike,
+Michael) (Entered: 06/09/2009)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|?667278296697325-L_801_0-1
+
+
+CM/ECF , Live Database - flsd
+06/10/2009|84
+85
+86
+0.5
+MB
+Or
+Download Selected
+
+ENDORSED ORDER granting 83 Motion to Amend affirmative defenses.
+Defendant must separately file affirmative defenses. Signed by Judge
+Kenneth A. Marra on 6/9/2009. (ir) (Entered: 06/10/2009)
+Clerks Notice of Docket Correction and Instruction to Filer re 82 Notice
+(Other), Notice (Other) filed by Jane Doe. Error - Wrong Event Selected;.
+Instruction to Filer - In the future, please select the proper event, i.e. Notice
+of Adoption. It is not necessary to refile this document. (Is) (Entered:
+06/10/2009)
+AMENDED DOCUMENT by Jeffrey Epstein. Amendment to 19 Amended
+Complaint, 28 Answer to Amended Complaint. (Pike, Michael) (Entered:
+06/10/2009)
+Total filesize of selected documents (MB): Г
+Maximum filesize allowed (MB): 10
+PACER
+Login:
+Description:
+Billable
+Pages:
+PACER Service Center
+Transaction Receipt
+06/10/2009 14:04:28
+du4480
+Client Code:
+Docket
+Search
+Report
+Criteria:
+9
+Cost:
+9:08-cv-80993-
+KAM
+0.72
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?667278296697325-L_801_0-1
+
+
+• Case 9:09-cv-80469-KAM Document 1
+Entered on LSD Docket 03125/2009 ELEM 1885 DI
+Mar. 24, 2009
+- D. OF FLA. - MIAM
+09-80469-Civ-RYSKAMP/VITUNAC
+CASE NO.:
+Plaintiff,
+-
+VS.
+JEFEREY EPSTEIN.
+and
+Defendants.
+1.
+)
+COMPLAINT
+Plaintiff, JANE DOE I, hereby sues JEFFREY EPSTEIN and
+and states:
+JURISDICTION AND VENUE
+2.
+This is an action for damages in excess of $75,000, exclusive of interests,
+costs and attorney's fees.
+3.
+Venue is proper in this Court as all acts occurred in Palm Beach County and
+all parties reside and/or do business herein.
+PARTIES
+Ms. DOE Il is a natural person residing in Palm Beach County, Florida. During
+the events giving rise to this claim, she was a minor but has now reached majority. She files
+this suit under a pseudonym to protect her privacy because the acts alleged occurred while
+she was a minor.
+SCANNED
+1 of 5
+
+
+09-80469-GiveRYSKAMR/MITUNAGered on FLSD Docket 03/25/2009 Page 3 of 5
+11.
+From about June, 2003 until on or about February, 2005, Defendants
+EPSTEIN and
+persuaded, induced, or enticed the Plaintiff to come to Defendant
+EPSTEIN's home and provide Defendant EPSTEIN with "massages" which escalated into
+sexual encounters between Defendant EPSTEIN and the Plaintiff designed to fulfill his
+unnatural sexual desires for young women or even younger girls who were minors. These
+acts included Defendant EPSTEIN's request that he wanted the encounter to be like a
+"porn video." Defendant EPSTEIN would script lines for the Plaintiff to say, including calling
+out his name and requesting that he perform a certain sexual act "harder,"while he touched
+the Plaintiff's
+or with
+alternately, he would g
+the presence of the Plaintiff after demanding her to disrobe and walk in front of him in
+provocative sexual poses. Defendant EPSTEIN would pay the Plaintiff a fee of $200 on
+each occasion after he
+while
+in the presence of the Plaintiff.
+12. Defendant EPSTEIN touched Plaintiff's |
+or
+Plaintiff's
+on multiple occasions, during the time that
+Plaintiff was a minor, causing personal injury to her.
+13. In violation of 18 U.S.C. §2422(b), Defendants EPSTEIN and
+knowingly persuaded, induced, or enticed the Plaintiff to engage in acts of prostitution, when
+the Plaintiff was under the age of 18, approximately on or about the following dates that
+Plaintiff can document based on payments received: 6/16/03, 7/2/03, 4/9/04, 6/7/04,
+7/30/04, 8/30/04, 10/9/04, 10/12/04, 10/30/04 and 11/9/04. In addition, Plaintiff believes that
+there were as many as 10 to 20 other occasions during this time frame that Defendant
+EPSTEIN solicited her and procured her to perform prostitution services, all during the time
+that she was a minor.
+3
+3 of s
+
+
+09-80469-Gix-BYSKAMPAUTNNAC Entered on LSD Docket 03/25/2009 FiLeage 5BB5
+=/S 44" (Rev. 2/08)
+CIVIL COVER SHEET
+The JS 44 civil coyer sheet and the information contained herein ncither replaçe nor supplement the filing and service of plcadings or other papers a:
+y local rules of court. This form, approved by the Judicial Conference of the United States in Soptembor 1974, is required for the use of the Clerk
+tho civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)
+I. (a) PLAINTIFFS
+JANE DOE II
+DEFENDANTS
+JEFFREY EPSTEIN AND
+Mar. 24, 2009
+STEVEN M. LARIMORE
+CLERK
+U.s.
+DIST.
+CT.
+OF
+FLA. - MIAMI
+(b) County of Residence of First Listed Plaintiff PALM BEACH
+(EXCEPT IN U.S. PLAINTIFF CASES)
+• Attomey's (Firm Name, Address, and Telephone Number)
+GARCIA LAW FIRM, P.A.
+224 DATURA STREETM SUITE 900
+WEST PALM BEACH, FL 33401
+County of Residence of First Listed Defendant
+PALM BEACH
+(IN U.S. PLAIN TIFF CASES ONLY)
+NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT
+LAND INVOLVED.
+Altomays (If Known)
+ROBERT D. CRITTON, ESQ
+JACK A. GOLDBERGER, ESQ
+(a) Check County Where Action Arose: O MIAMI DADE O MONROE
+• BROWARD O PALM BEACH O MARTIN O ST. LUCIE 7 INDIAN RIVER O OKEECHOBEE
+II. BASIS OF JURISDICTION (Place an "*" in One Box Only)
+III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" is Ons Box for Plaintitr
+• I U.S. Goverment
+(For Diversity Cases Only)
+VO 3 Federal Quention
+and One Box for Defendant)
+Plaintift
+(0.5. Govemment Not a Party)
+DEF
+Chises of This State
+Incorporated or Principal Place
+04
+of Business In This State
+O 2 U.S. Government
+3 4 Diversity
+Defendant
+Citizen of Another State
+• =
+2 Incorporated and Principal Plase
+• 5
+3 5
+09CV 80469
+(Indicate Citizenship of 1
+of Business In Anather State
+KLR /AEV
+Citizen or Subjeci of a •
+3 3 Foreign Nation
+a 6 36
+Fargien Country
+IV. NATURE OF SUIT (Place as "X" in Ons Box Only
+CONTRACT
+TORTS
+FORFEITUR PENALTY
+O 110 Insurance
+PERSONAL INJURY
+BANKRUPTCY
+OTHER STATUTES
+PERSONAL INJURY
+O 120 Marine
+610 Agriculture
+• 310 Airplane
+• 423 Appesl 28 USC 158
+362 Personal Injury -
+400 Stase Reapparionnient
+• 130 Miller Act
+J 315 Airplane Product
+620 Diber Food & Drug
+• 423 Withdrawal
+410 Astlirust
+3 140 Negotiable Instrument
+Mad. Malpractice
+625 Drug Related Seleure
+Liability
+28 USC 157
+• 150 Recovery of Overpaymeat
+365 Pensotal Injury -
+of Properly 21 USC 8$1
+430 Banks and Banking
+O 320 Assault, Libel A
+450 Commerce
+Product Liability
+A Enforcement of Jadgment
+630 LIquer Laws
+Slander
+PROPERTY RIGHTE
+• 368 Asbestos Persosal
+460 Doperiation
+• 15l Modicare Act
+640 R.R. A Truck
+O 330 Federal Emplayers'
+• 820 Copyrighs
+Injury Product
+470 Racketeer Influenced and
+• 152 Recovery of Defaulted
+650 Airline Rega.
+Liability
+• 830 Patont
+Liability
+Corrupt Organizations
+660 Occupational
+Student Loans
+• 340 Marine
+• 840 Trademark
+480 Consumer Credit
+PERSONAL PROPERTY
+Safety/Healin
+(Excl. Veterans)
+@ 145 Marine Freduct
+490 Cable/Sai TV
+0
+370 Other Fraud
+690 Other
+3 153 Recovery of Overpaymesi
+Liability
+371 Truth in Lending
+SID Selective Service
+• 160 Stockholdens" Suits
+380 Other Personal
+LABOR
+of Veteran's Benefits
+• 350 Motor Vehicle
+SOCIAL SECURITY
+850 Scouritice/Commodicies/
+710 Fair Labor Standards
+• 861 HIA (1393(7)
+• 355 Mesor Vehicle
+Exchange
+Property Damage
+Act
+• 190 Other Contreat
+D 862 Black Lung (923)
+Product Liability
+• 385 Property Domegr
+• 875 Customer ChallengE
+• 195 Contract Product Liability
+120 Labor/Mgmt, Relations
+I 360 Osher Personal
+863 DIWC/DIWW (405(g))
+12 USC 1410
+Produet Lisbality
+3 196 Franchiss
+130 Labor/M gmt.Reporting
+• 864 SSID Title XVI
+890 Other Statutory Actions
+& Disclosure Act
+REAL PROPERTY
+• 865 RS1 (405(g))
+CIVIL RIGHTS
+891 Agricultural Aris
+PRISONER PETITIONS
+740 Railway Labor Act
+O 210 Land Condemaation
+O 441 Voting
+FEDERAL TAX SUITS
+892 Economic Stabilization Act
+• 220 Foreclosure
+510 Mollons la Vacain
+790 Other Labor Litigation
+• 870 Taxes (U.S. Plaintif
+O 442 Employment
+3 230 Rent Lesse & Ejectment
+Sentence
+893 Environmental Matters
+O 443 Housing)
+791 Empl. Ret. Inc. Security
+or Defendant)
+• 240 Teria to Land
+Habeas Corpus:
+894 Energy Allocation Act
+Accommodations
+330 General
+• 871 INS-Third Party
+O 245 Tors Product Liability
+• 444 Wolfare
+26 USC 7609
+895 Freedom of Information Act
+535 Dosth Penally
+IMAIGRATION
+3 290 All Other Real Property
+445 Amer. w/Disabilities
+Employment
+540 Mandemus & Other
+462 Naturalization
+• 900 Appesi of Fee Detersicatior
+Application
+Undar Equal Access lo Justice
+446 Amer. w/Disabilities
+Otber
+350 Civil Rights
+463 Haboas Corpus-Alien
+Deleinee
+a 14o Orter Civil Rights
+• 135 Prison Conditien
+465 Other Immigration
+Actions
+o 950 Constitutisnality of Siair
+Statutes
+V. ORIGIN
+• 1 Original
+Proceeding
+72 Removed from
+12 Removed from x onl
+| 3 Re-filed-
+State Court
+(see VI below)
+• 4 Reinstatad or O 5 another distion 5 6 Militariet
+another district
+07
+VI. RELATED/RE-FILED
+CASE(S).
+a) Re-filed Case • YES ONO
+(specify)
+Appeal to District
+Judge from
+Magistrule
+Jadement
+b) Related Cases YES CINO
+(Sea instructions
+"cond page):
+JUDGE
+DOCKET NUMBER 9:08-CV-80069 KAM
+Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite Jurisdietional statutes unless
+diversity):
+VII. CAUSE OF ACTION 18 U.S.C. §2422(b)
+LENOTH OF TRIAL via
+VIII. REQUESTED IN
+days estimated (for both sidos to try entire casc
+• CHECK JE THIS IS A CLASS ACTION
+DEMAND S
+COMPLAINT:
+JNDER i
+ABOVE INFORMATION IS TRUE & CORRECT TO
+THE BEST OF MY KNOWLEDGE
+CHECK YES only if demanded in complaint:
+JURY DEMAND:
+d'Yes F No
+DATE
+March 19, 2009
+FOR OFFICE USE ONLI
+
+
+Case 9:09-CV-80469-KAM Document 31
+Entered on FLSD Docket 06/01/2009 Page 1 of 11
+CASE NO.: 09-CIV- 80469 - MARRA/JOHNSON
+Plaintiff,
+V.
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT EPSTEIN'S REPLY TO & MOTION TO STRIKE PORTIONS OF PLAINTIFF'S
+MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT'S MOTION TO DISMISS
+Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned
+attorneys, replies to and moves to strike Point 4 of Plaintiff's Memorandum Of Law In
+Opposition To Defendant Epstein's Motion To Dismiss, dated May 22, 2009, ("MOL").
+Accordingly, Defendant states:
+1. Legal Standard (pp. 1-2 of Plaintiff's MOL)
+Plaintiff's reliance on Conley v. Gibson, 355 U.S. 41, 45-46 (1957), as the Rule
+12(b)(6) pleading standard is misplaced. As discussed in Defendant's motion to
+dismiss, (pp. 16 - 17), the standard as detailed in Bell Atlantic Corp. V. Twombly, 127
+S.Ct. 1955 (2007), is now the applicable standard, not Conley. Although the complaint
+need not provide detailed factual allegations, the basis for relief in the complaint must
+state "more than labels and conclusions, and a formulaic recitation of the elements of a
+cause of action will not do." Twombly, at 1965. Further, "flactual allegations must be
+enough to raise a right to relief above the speculative level... on the assumption that all
+the allegations in the complaint are true (even if doubtful in fact)." Id. The United States
+Supreme Court very recently made clear in Ashcroft v. Iqbal, No. 07-1015 (U.S. May 18,
+
+
+
+counter and does not appear to directly dispute Defendant's position that the state court
+would have concurrent jurisdiction over the claim brought pursuant to 18 U.S.C. §2255.
+Secondly, Plaintiff's assertion, (MOL, p.2, fn. 1), that it is somehow improper to
+attach a copy of this same Plaintiff's Complaint from the state court proceeding in
+support of Defendant's motion is ridiculous. It is completely proper and in essence
+required of any party to give notice to a court of a related pending proceeding. (See for
+example, Loc. Gen. Rule 3.8 (S.D. Fla. 2009).' The fact that there does exists a
+previously filed action by Plaintiff against Defendant is directly relevant to this Court's
+decision of whether or not to exercise jurisdiction over the §2255 claim when there
+exists a previously filed proceeding in which the claim might also be brought. Needless
+to say, whether or not a Court exercises jurisdiction over a matter is a critical issue.
+Finally, Plaintiff completely mischaracterizes what she herself alleged in
+paragraph 15 of her Complaint. In her MOL, p. 7, Plaintiff falsely asserts that in par. 15
+she "pled that Defendant made an agreement with the United States Attorney's Office to
+not contest the jurisdiction of this Court in exchange for avoiding prosecution under
+federal law for solicitation of minors for prostitution." What is actually alleged in par. 15
+is the following: "Defendant EPSTEIN has made an agreement with the United
+States Attorney's Office to not contest liability for claims brought exclusively
+'See also Bray & Gillespie Management LLC v. Lexington Ins. Co., 2008 WL 4826115, 1 (M.D.
+Fla. 2008) - "[Jhe Court 'may take notice of proceedings in other courts, both within and without
+the federal judicial system, if those proceedings have a direct relation to matters at issue.' St.
+Smith, 738 F.2d 1199,
+opportunity to be heard as to the propriety of taking judicial notice. Fed.R.Civ.P. 201(e)." Here,
+Plaintiff filed the state court action and is, thusly, well of aware of its existence and details.
+
+
+
+does not provide for a multiplier and speaks in terms of "personal injury" suffered and
+"actual damages."
+Supporting the fact that Defendant properly raised these issues in his motion to
+dismiss are the allegations set forth in Plaintiff's complaint. In paragraph 11, Jane Doe
+Il alleges that - "From about June, 2003 until about February, 2005, Defendants,
+EPSTEIN and_
+persuaded, induced, or enticed Plaintiff to come to Defendant
+EPSTEIN's home and provide Defendant EPSTEIN with 'massages' ...." In paragraph
+13, Plaintiff further alleges - "In violation of §2422(b), Defendants EPSTEIN and
+knowingly persuaded, induced, or enticed the Plaintiff to engage in acts of
+prostitution, when the Plainitff was undr the age of 18, approximately on or about the
+following dates that Plaintiff can document based on payments received: 6/16/03,
+712/03, 4/9/04, 6/7/04, 7/30/04, 8/30/04, 10/9/04, 10/12/04 and 11/9/04. ...." In
+paragraph 14, Plaintiff alleges - "Plaintiff seeks damages for personal injury in
+accordance with 18 U.S.C. §2255(a) for each of the acts of prostitution set forth above
+which Defendants solicited her, $150,000 for each violation, for a total range of
+damages between $1.5 million dollars and $4.5 million dollars, jointly and severally, and
+a reasonable attorney's fees and costs, as permitted by the statute."
+Plaintiff chooses to analyze whether the statute in effect at the time of the alleged
+conduct or the amended statute applies under a procedural versus substantive analysis.
+Plaintiff, in short, argues that "the change in the civil remedies available of a statute is a
+procedural, not a substantive change in the law, and procedural changes to a statute
+are routinely applied retroactively." (MOL, p. 9). Clearly, the change to the statute was
+
+
+Document 31
+
+Jane Doe I| v. Epstein, et al.
+quoting as it confirms and supports that an amendment to a statute, such as in the
+instant case - increasing the penalty or liability for damages by at least triple fold, or
+under Plaintiff's analysis, by 90 times from $50,000 to $4.5 million! - and with no
+expression that it is to apply retroactively - will not be interpreted to apply retroactively.
+Congress may prescribe the temporal reach of a statute by stating that it
+applies to pre-enactment conduct, the first step in the Landgraf analysis, or a
+statute may be silent regarding temporal reach, in which case courts
+apply the judicial presumption against retroactivity. This presumption and
+analysis, however, are unwarranted when Congress states its unambiguous
+intention that the
+statute apply retroactively to pre-enactment conduct, in
+language comparable to § 1658(b), that the new or amended statute applies to
+proceedings commenced on or after enactment. See Landgraf, 511 U.S. at 259-
+60, 114 S.Ct. at 1494 (stating that, if had Congress intended retroactive
+application, then "it surely would have used language comparable to ... 'shall
+apply to all proceedings pending on or commenced after the date of enactment'
+") (citation omitted); accord INS v. St. Cyr, 533 U.S. 289, 318-19 & n. 43, 121
+S.Ct. 2271, 2289-90 & n. 43, 150 L.Ed.2d 347 (2001) (collecting examples of
+unambiguous temporal statutory language providing that the statute applies to
+actions filed "on or after" the date of enactment, which includes violative
+conduct that occurred prior to the effective date of the statute); Martin v. Hadix,
+527 U.S. 343, 354, 119 S.Ct. 1998, 2004, 144 L.Ed.2d 347 (1999) (stating that"
+'new provisions shall apply to all proceedings pending on or commenced after
+the date of enactment, " referenced in Landgraf, "unambiguously addresses the
+temporal reach of the statute" (citation omitted)); Lindh v. Murphy, 521 U.S.
+320, 329 n. 4, 117 S.Ct. 2059, 2064 n. 4, 138 L.Ed.2d 481 (1997) (recognizing
+from Landgraf that statutory language such as, " '[This Act] shall apply to all
+proceedings pending on or commenced after the date of enactment of this Act,
+"might possibly have qualified as a clear statement for retroactive effect"
+(quoting Landgraf, 511 U.S. at 260, 114 S.Ct. at 1494)); Rivers v. Roadway
+express, Inc., 511 U.S. 298, 307-08, 114 S.Ct. 1510, 1517, 128 L.Ed.2d 274
+(1994) (noting that the subject statute omitted a provision in the bill that the
+amendment "'shall apply to all proceedings pending on or commenced after' " a
+tixed date and describing the bill as containing "express retroactivity
+provisions")....
+Unlike other statutory enactments or amendments (cited above) where Congress
+unambiguously expressed its intent regarding retroactive application, there is no
+expression with respect to Masha's Law, the 2006 amended version of §2255. An
+
+
+Entered on FLSD Docket 06/01/2009 Page 9 of 11
+Page g
+discussed in Part III, A. of Defendant's motion to dismiss, unlike other statutes, there is
+absolutely no language in the statute that suggest that the presumptive damages
+amount is subject to multiplication on a per violation/incident basis. The statute on its
+face speaks in terms of "actual damages" and "personal injury suffered."
+The recent case of United States v. Berdeal, 595 F.Supp.2d 1326 (S.D. Fla.
+2009), further supports Defendant's argument that the "rule of lenity," (Part.
+_ of
+Defendant's motion), requires that the Court resolve the statutory interpretation conflict
+in favor of Defendant. Assuming for the sake of argument that Plaintiff's multiple
+causes of action, leading to a multiplication of the statutory damages amount, is a
+reasonable interpretation, like Defendant's reasonable interpretation, under the "rule of
+lenity," any ambiguity is resolved in favor of the least draconian measure. In Berdeal,
+applying the rule of, lenity, the Court sided with the Defendants' interpretation of the
+Lacey Act which makes illegal the possession of snook caught in specified jurisdictions.
+The snook had been caught in Nicaraguan waters. The defendants filed a motion to
+dismiss asserting the statute did not encompass snook caught in foreign waters. The
+United States disagreed. Both sides presented reasonable interpretations regarding the
+reach of the statute. In dismissing the indictment, the Court determined that the rule of
+lenity required it to accept defendants' interpretation.
+Point 4. Point 4 is required to be stricken as Plaintiff attempts to argue facts not
+alleged in the Complaint, and misrepresents what is alleged in the Complaint.
+Point 4 of Plaintiff's MOL, p. 15-17, is required to be stricken as it not only argues
+facts outside of the four corners of the complaint, but it continues to misrepresent what
+is actually alleged in paragraph 15 of Plaintiff's complaint. See discussion under "Point
+
+
+Case 9:09-CV-80469-KAM Document 31
+
+Isidro M. Garcia, Esq.
+Garcia Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+F
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+illii lii
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+Respectfull
+By: _
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Elorida Bar. #617296
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+(Co-counsel for Defendant Jeffrey Epstein)
+
+
+Case 9:09-Cv-80469-KAM Document 20
+Entered on FLSD Docket 05/22/2009 Page 1 of 20
+CASE NO.: 09-80469-CIV-MARRA
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+and
+Defendants.
+PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION
+TO DEFENDANT EPSTEIN'S MOTION TO DISMISS
+Plaintiff, JANE DOE II, through counsel, opposes Defendant's RICHARD EPSTEIN's
+Motion to Dismiss. Defendant's argument for a dismissal is premised on the following: 1)
+Plaintiff is not permitted to file a claim under Florida law in a State of Florida court and then
+file a federal claim in a federal court; 2) the remedies amendment to 18 U.S.C.§2255 are
+not retroactive based on the dates Defendant EPSTEIN is alleged to have violated the
+statute; 3) damages under §2255 cannot be obtained on a per incident basis, but must
+be lumped together into a single recovery despite multiple violations occurring in temporally
+distinct time frames, and therefore being different incidents; 4) Plaintiff has failed to state a
+cause of action under §2255 because she has failed to "allege facts constituting a predicate
+act"; and 5) Plaintiff has failed to state a cause of action for conspiracy to violate §2255.
+I.
+LEGAL STANDARD
+Defendant's motion to dismiss must be denied unless it appears beyond doubt that
+the plaintiff can prove no set of facts in support of her claims that would entitle her to relief.
+
+
+
+under many circumstances.?
+28 U.S.C. §1367, "supplemental jurisdiction," provides that:
+©) The district courts may decline to exercise supplemental jurisdiction over
+a claim under subsection (a) if--
+(1) the claim raises a novel or complex issue of State law,
+(2) the claim substantially predominates over the claim or claims over which
+the district court has onginal jurisdiction,
+(3) the district court has dismissed all claims over which it has original
+jurisdiction, or
+(4) in exceptional circumstances, there are other compelling reasons for
+declining jurisdiction.
+Courts routinely "are obligated to raise and decide issues of subject matter jurisdiction
+sua sponte any time it appears subject matter jurisdiction is absent." Carias v. Lenox
+Financial Mortgage Corporation, 2008 U.S. DIST. LEXIS 20345 *1 (N.D. Cal. March 5,
+2008). In Carias, after granting summary judgment on the sole federal claim, the Court
+remanded the State claims to state court, stating: "The Court declines to exercise pendent
+jurisdiction over the state law claims and remands the action to state court. The Court finds
+that the issues of economy, convenience, fairness and comity collectively weigh in favor of
+remand. See Harrell, 934 F.2d at 205. Comity weighs especially strong, given that the
+remaining claims are pure state law claims with no connection to federal law. Economy
+also weighs in favor of remand as state courts are better equipped to efficiently handle state
+2
+In United Mine Workers v. Gibbs, 383 U.S. 715 (1966), a jury's verdict
+against a union based on State law claims was reversed, in part, because the federal
+law claim failed. The Court noted that: "It has consistently been recognized that
+pendent jurisdiction is a doctrine of discretion, not of plaintiff's right. Its justification lies
+in considerations of judicial economy, convenience and fairness to litigants; if these are
+not present a federal court should hesitate to exercise jurisdiction over state claims,
+even though bound to apply state law to them, Erie R. Co. v. Tompkins, 304 U.S.
+64.Needless decisions of state law [by a federal court] should be avoided both as a
+matter of comity and to promote justice between the parties, by procuring for them a
+surer-footed reading of applicable law."
+3
+
+
+: Case 9:09-cv-80469-KAM Document 20 Entered on FLSD Docket 05/22/2009 Page 5 of 20
+inapplicable to this case. Only in "exceptional" circumstances, to promote conservation of
+judicial resources and comprehensive disposition of litigation, would a federal court be
+authorized to dismiss federal parallel claims that are initiated in state court. Colorado River
+Water Conservation District v. United States, 424 U.S. 800 (1976). However, for the
+Colorado River doctrine to even apply, there must be clear Congressional direction that
+would preclude a federal court's "virtually unflagging obligation ...to exercise federal
+jurisdiction." Id. at 817. In that case, the Supreme Court found that clear Congressional
+direction from the McCarran Amendment, which the Court read to counsel against
+"piecemeal litigation" concerning issues of water rights in a river system, favored abstention
+Id. at 819. Even with this clear Congressional direction, if other factors had not favored
+abstention, it may not have been ordered. Id. at 820.
+Defendant EPSTEIN does not offer any evidence of any Congressional direction that
+would direct this Court to abstain for claims under 18 U.S.C. §2255. Further, the Colorado
+River doctrine only applies when federal courts are presented with "difficult questions of state
+*The federal claims that are the subject matter of this action are not necessarily
+parallel, although the incidents that gave rise to both the federal and state claims arise
+from the same series of events. A Florida appellate court, for example, has refused to
+apply principles of res judicata to bar State discrimination claims after the plaintiff lost
+federal discrimination claims. Andujar v. National Property & Casualty Underwriters, 659
+So. 2d 1214 (Fla. 4th DCA 1995) (adverse judgment against plaintiff in federal court for
+federal discrimination claims did not bar subsequent action under state discrimination
+laws). Here, although some of the elements for some of the claims may be similar, they
+are sufficiently different that application of Andujar would preclude res judicata. To
+determine whether a case is parallel, courts have looked to whether the same issues
+are being litigated. Calvert Fire Ins. Co. v. American Mut. Reins. Co., 600 F.2d 1228,
+1229, n. 1 (7th Cir. 1979); the issues in the State court and in this Court are not the
+same.
+"The Supreme Court said that Congressional direction is the "Im]ost important
+factor." Id. at 819.
+5
+
+
+: Case 9:09-cv-80469-KAM
+
+Colorado River doctrine has been applied to a federal claim under §2255. The cases cited
+by Defendant EPSTEIN do not support a decision by this Court to abstain over what is a
+purely federal claim. In American Bankers Ins. Co. v. First State Ins. Co., 891 F.2d 882 (11h
+Cir. 1990), the District Court dismissed a purely state law claim for equitable subrogation
+because there had been an earlier claim for declaratory relief in State Court; the Eleventh
+Circuit reversed, concluding
+...that no exceptional circumstances require dismissal of this case in
+deference to the pending state court proceeding. If it were simply a question
+of judicial economy, this litigation probably should proceed in the New York
+court. A federal court cannot properly decline to exercise its statutory
+jurisdiction, however, simply because judicial economy might be served by
+deferring
+to a state
+• court. Federal courts have a 'virtually unflagging
+obligation' to exercise the jurisdiction given them.' Colorado River, 424 U.S.
+at 816, 96 S. Ct. at 1246. The interest in preserving federal jurisdiction
+mandates that this action not be dismissed.
+891 F.2d at 886.
+Finally, Plaintiff has pled that Defendant EPSTEIN has made an agreement with the
+United States Attorney's Office to not contest the jurisdiction of this Court in exchange for
+a avoiding prosecution under federal law for solicitation of minors for prostitution. Complaint,
+115. Defendant EPSTEIN appears to be violating the agreement in contesting the jurisdiction
+of this Court; at a minimum, at this stage of the pleadings he should be estopped from
+contesting jurisdiction, since the allegations of 115 must be accepted as true.®
+Point 2.
+The retroactivity of the amendments to §2255 is not appropriately
+addressed in a motion to dismiss; but if the Court is so inclined to
+consider it, there are insufficient facts pled in the Complaint to
+render the 2006 amendments inapplicable to the case at bar.
+•Plaintiff acknowledges that Defendant EPSTEIN's agreement is between the
+United States and he; however, the Plaintiff and the other victims of his sexual
+predation may be considered third party beneficiaries to the agreement.
+7
+
+
+: Case 9:09-cv-80469-KAM Document 20 Entered on FLSD Docket 05/22/2009
+
+issue would be better addressed on a summary judgment motion, and again, has nothing
+to do with whether Plaintiff has pled a cause of action pursuant to Rule 12(b)(6), Fed. R. Civ.
+P.
+Plaintiff agrees with the general proposition that a new law that creates new
+substantive rights, absent Congressional direction to the contrary, does not have retroactive
+effect, but this is not a new law. §2255 was amended in 2006, to, inter alia, provide an
+enhanced minimum recovery for damages caused by sexual predators such as Defendant
+EPSTEIN. However, the change in the civil remedies available of a statute is a procedural,
+not a substantive change in the law, and procedural changes to a statute are routinely
+applied retroactively,® Where substantive changes in a law are made by Congress, a slim
+majority of the Supreme Court has declined retroactive application, even where the law was
+ostensibly enacted to overrule a Court precedent that had itself, in the view of Congress,
+overruled earlier Court precedents. Rivers v. Roadway Express, 511 U.S. 298, 308 (1994).°
+•Defendant EPSTEIN also cites to United States v. Siegel, 153 F.3d 1256 (11"*
+Cir. 1998), wherein, based on a defendant's inability to pay restitution mandated by a
+penal statute, the Court reversed a restitution order. An amendment to the statute
+removed from consideration the defendant's ability to pay restitution; the Court said
+such an amendment could not be applied retroactively because the provision amounted
+to a punishment under a penal statute, and would violate the ex post facto provision in
+the U. S. Constitution, This case is clearly distinguished our case: the statute here is a
+civil, not a penal remedy; the amendment to the statute modifies the minimal exposure
+of the Defendant, but does not, as in the Siegel case, dispense with a substantive
+defense to a restitution claim. United States v. Whiting, 165 F.3d 631 (8'" Cir. 1999),
+where a conviction for possession of child pornography was upheld, despite the tact
+that the conduct of the defendant was arguably not specifically proscribed by statute at
+the time the images were possessed; the Court held the legislative amendment was a
+mere clarification of the prior legislation and not an ex post facto law.
+• Justice Scalia cited the statement of purpose of the Civil Rights Act of 1991, to
+hold that, for example, the amendments specifically designed to overrule Patterson v.
+McLean Credit Union, 491 U.S. 164, 105 L. Ed. 2d 132, 109 S. Ct. 2363, should be
+9
+
+
+Case 9:09-CV-80469-KAM
+Entered on FLSD Docket 05/22/2009 Page 11 of 20
+that the compensatory damages provisions smack of a "retributive" or other
+suspect legislative purpose. Section 102 reflects Congress' desire to afford
+victims of discrimination more complete redress for violations of rules
+established more than a generation ago in the Civil Rights Act of 1964. At
+least with respect to its compensatory damages provisions, then, § 102 is not
+in a category in which objections to retroactive application on grounds of
+fairness have their greatest force.
+Nonetheless, the new compensatory damages provision would operate
+"retrospectively" if it were applied to conduct occurring before November 21,
+1991. Unlike certain other forms of relief, compensatory damages are
+quintessentially backward looking. Compensatory damages may be intended
+mechanism that affects the liabilities of defendants. They do not
+to compensatory damages is also the type of legal change that would have
+an impact on private parties' planning. In this case, the event to which the new
+damages provision relates is the discriminatory conduct of respondents' agent
+John Williams; if applied here, that provision would attach an important new
+legal burden to that conduct. The new damages remedy in § 102, we
+conclude, is the kind of provision that does not apply to events antedating its
+enactment in the absence of clear congressional intent.
+In cases like this one, in which prior law afforded no relief, § 102 can be
+seen as creating a new cause of action, and its impact on parties' rights
+is especially pronounced. Section 102 confers a new right to monetary relief
+on persons like petitioner who were victims of a hostile work environment but
+were not constructively discharged, and the novel prospect of damages
+liability for their employers. Because Title VII previously authorized recovery
+of backpay in some cases, and because compensatory damages under §
+102(a) are in addition to any backpay recoverable, the new provision also
+resembles a statute increasing the amount of damages available under a
+preestablished cause of action. Even under that view, however, the provision
+would, if applied in cases arising before the Act's effective date, undoubtedly
+impose on employers found liable a "new disability" in respect to past events.
+See Society for Propagation of the Gospel, 22 F. Cas, at 767. The extent of
+a party's liability, in the civil context as well as the criminal, is an important
+legal consequence that cannot be ignored. Neither in Bradley itself, nor in
+any case before or since in which Congress had not clearly spoken, have we
+read a statute substantially increasing the monetary liability of a private party
+to apply to conduct occurring before the statute's enactment. See Winfree v.
+Northern Pacific R. Co., 227 U.S. 296, 301, 57 L. Ed. 518, 33 S. Ct. 273
+(1913) (statute creating new federal cause of action for wrongful death
+11
+
+
+
+statutory enactments is simply not present here, and the record is devoid of any factual
+material that would support such a conclusion. As Justice Blackmun said in dissent in
+Landsgraf, there is no vested right to break the law."
+Bottom line is, a motion to dismiss a claim is not the correct procedural mechanism
+to determine the retroactivity of a statute. Landsgraf was decided after a trial on the merits
+of the claim, wherein the trial court determined that although the sexual harassment was
+serious, the employer, upon learning of it, had taken prompt remedial measures to correct
+it, and the plaintiff did not have sufficient cause to warrant quitting her job. Id. at 247-48.
+Rivers v. Roadway Express, 511 U.S. 298 (1994) was decided after a trial on the merits as
+well, wherein the Court dismissed the 1981 claims based on the holding in Patterson, supra,
+and exonerated the Defendant on the Title VII claims in a bench trial. On appeal, the plaintiff
+sought relief under the 1991 Civil Rights Act amendments, which overruled Patterson. These
+10 Although outside the pleadings and not appropriate for consideration on a
+Motion to Dismiss, Defendant EPSTEIN has refused to answer any substantive
+questions in the only two (2) depositions he has given in all these cases, including in
+the State court case involving this Plaintiff. Accordingly, Plaintiff has not been able to
+ascertain whether Defendant EPSTEIN had settled expectations about the limits of his
+civil liability under §2255.
+11"At no time within the last generation has an employer had a vested right to
+engage in or to permit sexual harassment; 'there is no such thing as a vested right to do
+wrong.' Freeborn v. Smith, 69 U.S. 160, 2 Wall. 160, 175, 17 L. Ed. 922 (1865). See
+also 2 N. Singer, Sutherland on Statutory Construction § 41.04, p. 349 (4th rev. ed.
+1986) (procedural and remedial statutes that do not take away vested rights are
+presumed to apply to pending actions). Section 102 of the Act expands the remedies
+available for acts of intentional discrimination, but does not alter the scope of the
+employee's basic right to be free from discrimination or the employer's corresponding
+legal duty. There is nothing unjust about holding an employer responsible for injuries
+caused by conduct that has been illegal for almost 30 years." Id. at 297. Similarly in this
+case, soliciting minors for acts of prostitution, has been unlawful and the civil remedy
+associated therewith has long preceded the acts in question.
+13
+
+
+
+minimum 'actual damages, Id. at 1379, but there is no suggestion in this Opinion that the
+Plaintiff was so limited, no reference to whether Plaintiff sought the relief being sought here
+or that the events she complained of occurred on multiple occasions. In fact, it appears clear
+from the Opinion that the pro se Defendant that Plaintiff prevailed against by default was
+sued for a singular violation of recording the Plaintiff's sexually oriented performance at a
+Spring Break gathering. There is no indication that the conduct that was recorded by the
+defaulted Defendant occurred on multiple occasions, as here.
+Point 4.
+The Eleventh Circuit has foreclosed Defendant EPSTEIN's
+argument that for a violation of 18 U.S.C. 2422(b) to occur, he must
+travel in interstate commerce; moreover, he has waived his right
+to contest the jurisdiction of the Court according to the allegations
+of the Complaint.
+In United States v. Yost, 479 F.3d 815 (11" Cir. 2007), a defendant was convicted of
+two counts of attempting to induce persons he believed were minors (they were government
+agents posing as minors) to commit acts of prostitution under 18 U.S.C. §2422(b); he sought
+to void his convictions on appeal because he didn't get to the meeting place. The Court
+rejected the argument, holding:
+We are not convinced by Yost's argument that his failure to arrive at the
+meeting place precludes a finding of a substantial step. Although this is the
+first time we have been confronted with an attempt conviction under 18 U.S.C.
+§ 2422(b) where travel is not involved, two other circuits have examined the
+issue and determined travel is not necessary to sustain such a conviction. In
+United States v. Bailey, 228 F.3d 637, 639-40 (6th Cir. 2000), the Sixth Circuit
+affirmed a conviction under Section 2422(b) where the defendant sent e-mails
+proposing oral sex and attempted to set up meetings with minor females,
+albeit unsuccessfully. Similarly, in United States v. Thomas, 410 F.3d 1235,
+1246 (10th Cir. 2005), the Tenth Circuit affirmed a Section 2422(b) attempt
+conviction, despite a lack of evidence of travel. The Tenth Circuit stated:
+"Thomas crossed the line from 'harmless banter' to inducement the moment
+he began making arrangements to meet [the minor], notwithstanding the lack
+of evidence that he traveled to the supposed meeting place." Id. Viewing the
+15
+
+
+Case 9:09-CV-80469-KAM Document 20
+Entered on FLSD Docket 05/22/2009 Page 17 of 20
+sexual services he paid the Plaintiff for. Defendant
+resides and is believed to have
+resided in New York at all times relevant to this suit, although she was present at Defendant
+EPSTEIN's home on some of the occasions when the Plaintiff appeared after being
+summoned there. However, since she used a cellular phone, that is clearly a facility of
+interstate commerce as contemplated by 18 U.S.C. 2422(b), which encompasses conduct
+where "any facility or means of interstate commerce" is used.'3 The Eleventh Circuit has
+recognized that "[the telephone system is clearly a 'facility of interstate.. commerce."
+United States v. Covington, 2009 U.S. App. LEXIS 8263 (11" Cir. April 22, 2009).
+Defendant EPSTEIN is alleged in the Complaint to have waived the right to contest
+the jurisdiction of this Court for claims under §2255, he should therefore be estopped from
+asserting the failure to allege predicate acts, particularly when he has refused to answer any
+questions based on his claimed right against self incrimination. However, if the Court is of
+the view that these predicate facts must be alleged despite the agreement, then Plaintiff
+requests leave to do so.
+Point 5.
+Plaintiff has pled sufficient facts to establish a conspiracy to
+violate §2255.
+_A civil conspiracy is an agreement by two or more persons, to do an unlawful act
+or a lawful act by unlawful means, the doing of an overt act in furtherance of the
+13 "(b) Whoever, using the mail or any facility or means of interstate or
+foreign commerce, or within the special maritime and territorial jurisdiction of the
+United States knowingly persuades, induces, entices, or coerces any individual who has
+17
+
+
+
+inappropriate for the Defendant to seek to limit his minimum statutory exposure on a Motion
+to Dismiss, where there is no factual record or legislative history to determine the retroactivity
+of an enhanced damages provision to a cause of action that existed at the time of the
+wrongful acts. §2255 claims permit a Plaintiff to assert multiple claims for multiple violations
+that occur in temporally distinct time frames, no differently than any claim, whether based
+on tort or statutory law, that encompasses multiple events that occur at different times.
+Defendant EPSTEIN has waived the right to contest the issue of whether his conduct
+impacted interstate commerce; but Plaintiff is prepared to allege, if the Court deems it
+necessary, how his employee and co-conspirator, Defendant
+used an
+instrumentality of interstate commerce, her cell phone, to solicit the Plaintiff, then a minor,
+on behalf of Defendant EPSTEIN who solicited her sexual services for money. Finally,
+Plaintiff has pled all necessary elements to establish a civil conspiracy to violate §2255. For
+these reasons, Defendant EPSTEIN's Motion to Dismiss must be denied; however, if the
+Court determines otherwise, Plaintiff respectfully requests leave to amend.
+Respectfully submitted,
+BY: s/ Isidro M. Garcia
+ISIDRO M. GARCIA
+Florida Bar No. 437883
+GARCIA LAW FIRM, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+Telephone:
+Telecopier:
+19
+
+
+Case 9:09-Cv-80469-KAM Document 13
+
+CASE NO.: 09-CIV - 80469 - MARRA/JOHNSON
+Plaintiff,
+V.
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT EPSTEIN'S MOTION TO DISMISS PLAINTIFF'S
+COMPLAINT, AND SUPPORTING MEMORANDUM OF LAW
+Defendant, Jeffrey Epstein, (hereinafter "Epstein"), by and through his
+undersigned attorneys, moves to dismiss Plaintiff's Complaint for failure to state a cause
+of action, and for more definite statement. Rule 12(b)(6), (e), Fed.R.Civ.P. (2008);
+Local Gen. Rule 7.1 (S.D. Fla. 2008). In support of dismissal, Defendant states:
+At the outset, Defendant gives notice to the Court that issues pertaining to 18
+U.S.C. §2255 in this motion to dismiss are also raised in the case of |
+1: V. Jeffrey
+Epstein, Case No. 08-CV-80811-MARRA/JOHNSON, in Defendant's Motion to Dismiss
+directed to Plaintiff
+'s Amended Complaint, Plaintiff |
+I's Response, and
+Defendant's reply to
+'s response (which has yet to be filed).
+In this action, Plaintiff's Complaint attempts to allege a cause of action pursuant
+to 18 U.S.C. §2255 - Civil Remedies for Personal Injuries. Significantly, Plaintiff
+previously a filed lawsuit on July 10, 2008, based on the same facts as alleged herein in
+the Fifteenth Judicial Circuit In and For Palm Beach County, State of Florida, Case No.
+
+
+• Casé 9:09-CV-80469-KAM Document 13
+
+Jane Doe Il v. Epstein, et al.
+federal actions reveals that they are almost identical. Based on the same allegations, in
+the state action, Plaintiff attempts to assert claims based on state law for Sexual Battery
+(Count I) and Civil Conspiracy (Count II); in this action, Plaintiff is attempting to assert a
+cause of action pursuant to 18 U.S.C. §2255, which applicable version provides -
+PART I-CRIMES
+CHAPTER 110--SEXUAL EXPLOITATION AND OTHER ABUSE OF CHILDREN
+§ 2255. Civil remedy for personal injuries
+(a) Any minor who is a victim of a violation of section 2241(1, 2242, 2243, 2251,
+2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suffers personal
+injury as a result of such violation may sue in any appropriate United States District
+our and shall recover the actual damages such minor sustains and the cost of the
+suit, including a reasonable attorney's fee. Any minor as described in the preceding
+sentence shall be deemed to have sustained damages of no less than $50,000 in
+value.
+(b) Any action commenced under this section shall be barred unless the complaint is
+tiled within six years after the right of action first accrues or in the case of a person
+under a legal disability, not later than three years after the disability.
+CREDIT (S)
+(Added Pub.L. 99-500, Title I, § 101(b) [Title VII, § 703(a)], Oct, 18, 1986, 100 Stat.
+1783-75, and amended Pub.L. 99-591, Title I, § 101(b) [Title VII, § 703(a)]. Oct. 30,
+1986, 100 Stat. 3341-75; Pub.L. 105-314, Title VI, § 605, Oct. 30, 1998, 112 Stat.
+2984.)
+(Emphasis added).
+Plaintiff is likely to argue that the jurisdiction of the federal court over §2255 claims
+is exclusive. However, unlike other Congressional enactments, there is no language in
+the statute which expressly states that jurisdiction of such cause of action lies
+exclusively with the federal courts. Furthermore, there is a presumption of concurrent
+jurisdiction of state courts. See generally, Yellow Freight System, Inc. v. Donnelly, 494
+U.S. 820, 823, 110 S.Ct. 1566, 1568-69 (1990). "Under our 'system of dual sovereignty,
+we have consistently held that state courts have inherent authority, and are thus
+
+
+Case 9:09-cv-80469-KAM Document 13 Entered on FLSD Docket 05/06/2009
+
+Page 5
+the principles articulated in Colorado River Water Conserv. Dist. v. United States, 424
+U.S. 800, 96 S.Ct. 1236, 47 L.Ed.2d 483 (1976) and Moses H. Cone Memorial Hosp. V.
+Mercury Constr., 460 U.S. 1, 103 S.Ct. 927, 74 L.Ed.2d 765 (1983)."
+The six factors considered are (1) whether one of the courts has assumed
+jurisdiction over property; (2) the inconvenience of the federal forum; (3) the potential for
+piecemeal litigation; (4) the order in which the forums obtained jurisdiction; (5) whether
+state or federal law will be applied; and (6) the adequacy of the state court to protect the
+parties' rights.
+"The test for determining when exceptional circumstances exist,
+therefore, involves the careful balancing of six factors. The weight to be given any one
+factor may vary greatly depending on the case; however, the balance is "heavily
+weighted" in favor of the federal court exercising jurisdiction. Id. at 16, 103 S.Ct. at 937."
+American Bankers Ins. Co. of Florida v. First State Ins. Co., 891 F.2d 882, 884 (11th
+Cir. 1990). The list of factors is neither exhaustive, nor is it a mechanical checklist. See
+AM.JUR. FED. COURTS, § 1114.
+In the instant case, the third, fourth, fifth, and sixth factors are implicated.
+Clearly, more than a "potential" for piecemeal litigation exists if Plaintiff were allowed to
+proceed in two separate forums alleging the identical facts against the identical parties.
+Discovery and rulings thereon would involve the same set of facts, yet could result in
+inconsistent and varying rulings thereon. Should the cases proceed separately to trial,
+factual findings and judgments rendered in one could be inconsistent with the other.
+Appeals would proceed separately and in a piecemeal fashion. The piecemeal effect
+would be both excessive and deleterious if these cases were to proceed in parallel
+
+
+. Case 9:09-cv-80469-KAM
+
+(quoted above). See endnote 1 hereto, Complaint 111, 13.' It is an axiom of law that
+"retroactivity is not favored in the law." Bowen, 488 U.S., at 208, 109 S.Ct., at 471
+(1988). As eloquently stated in Landgraf v. USI Film Products, 114 S.Ct. 1483, 1497,
+511 U.S. 244, 265-66 (1994):
+jurisprudence, and embodies a legal doctrine centuries older than our Republic.
+Elementary considerations of fairness dictate that individuals should have an
+opportunity to know what the law is and to conform their conduct accordingly; settled
+expectations should not be lightly disrupted.*i® For that reason, the "principle that the
+legal effect of conduct should ordinarily be assessed under the law that existed when
+the conduct took place has timeless and universal appeal." Kaiser, 494 U.S., at 855,
+110 S.Ct., at 1586 (SCALIA, J., concurring). In a free, dynamic society, creativity in
+both commercial and artistic endeavors is fostered by a rule of law that gives people
+confidence about the legal consequences of their actions.
+FN18. See General Motors Corp. v. Romein, 503 U.S. 181, 191, 112 S.Ct. 1105,
+1112, 117 L.Ed.2d 328 (1992) ("Retroactive legislation presents problems of
+unfairness that are more serious than those posed by prospective legislation,
+because it can deprive citizens of legitimate expectations and upset settled
+transactions"); [Further citations omitted].
+It is therefore not surprising that the antiretroactivity principle finds expression in
+several provisions of our Constitution. The Ex Post Facto Clause flatly prohibits
+retroactive application of penal legislation. N19 Article I, § 10, cl. 1, prohibits States from
+passing another type of retroactive legislation, laws "impairing the Obligation of
+Contracts." The Fifth Amendment's Takings Clause prevents the Legislature (and other
+government actors) from depriving private persons of vested property rights except for
+a "public use" and upon payment of "just compensation." The prohibitions on "Bills of
+Attainder" in Art. I, S§ 9-10, prohibit legislatures from singling out distavored persons
+and meting out summary punishment for past conduct. See, e.g., United States v.
+Brown, 381 U.S. 437, 456-462, 85 S.Ct. 1707, 1719-1722, 14 L.Ed.2d 484 (1965). The
+Due Process Clause also protects the interests in fair notice and repose that may be
+compromised by retroactive legislation; a justification sufficient to validate a statute's
+prospective application under the Clause "may not suffice" to warrant its retroactive
+application. Usery v. Turner Elkhorn Mining Co., 428 U.S. 1, 17, 96 S.Ct. 2882, 2893,
+49 L.Ed.2d 752 (1976).
+FN19. Article | contains two Ex Post Facto Clauses, one directed to Congress (§ 9,
+applicable only to penal legislation. See Calder v. Bull, 3 Dall. 386, 390-391, 1 L.Ed.
+648 (1798) (opinion of Chase, J.).
+
+
+. Case 9:09-cv-80469-KAM
+Document 13 Entered on FLSD Docket 05/06/2009
+
+Page 9
+1998); and generally, Calder v. Bull, 3 U.S. 386, 390, 1 L.Ed. 648, 1798 WL 587
+(Calder) (1798).
+The United States Constitution provides that "injo Bill of Attainder or ex post
+facto Law shall be passed" by Congress. U.S. Const. art. I, § 9, cl. 3. A law
+violates the Ex Post Facto Clause if it " 'appli[es] to events occurring before its
+enactment ... [and] disadvantage[s] the offender affected by it' by altering the
+definition of criminal conduct or increasing the punishment for the crime." Lynce
+y. Mathis, 519 U.S. 433, 117 S.Ct. 891, 137 L.Ed.2d 63 (1997) (quoting Weaver
+y. Graham, 450 U.S. 24, 29, 101 S.Ct. 960, 67 L.Ed.2d 17 (1981)).
+U.S. v. Siegel, 153 F.3d 1256, 1259 (11'" Cir. 1998).
+In improperly attempting to multiply the presumptive minimum actual damages
+amount, Plaintiff's Complaint alleges a time period "from about June, 2003 until on or
+about February, 2005." See endnote 1. In paragraph 14 of her Complaint, Plaintiff
+references the 2006 amended version of §2255 which raised the presumptive actual
+damages amount from $50,000 to $150,000; Plaintiff also improperly claims that she is
+entitled to "$150,000 for each violation, for a total range of damages between $1.5
+million dollars to $4.5 million dollars, jointly and severally, .... " 1|14.
+§2255 is contained in Title 18 of the United States Codes - "Crimes and Criminal
+Procedure, Part I. Crimes, Chap. 110. Sexual Exploitation and Other Abuse of
+Children." 18 U.S.C. §2255 (2005), is entitled Civil remedy for personal injuries, and
+imposes a presumptive minimum of damages in the amount of $50,000, should Plaintiff
+prove any violation of the specified criminal statutes and that she suffered personal
+injury with actual damages sustained. Thus, the effect of the 2006 amendments,
+effective July 27, 2006, would be to triple the amount of the statutory minimum
+previously in effect during the time of the alleged acts. If one were to take Plaintiff's
+
+
+
+penalty or punishment, "Title II - Punishing Sexual Predators," Sec. 206, from House
+Report No. 105-557, 5-6, specifically includes reference to the remedy created under
+§2255 as an additional means of punishing sexual predators, along with other penalties
+and punishments. Senatorial Comments in amending §2255 in 2006 confirm that the
+creation of the presumptive minimum damage amount is meant as an additional penalty
+against those who sexually exploit or abuse children. 2006 WL 2034118, 152 Cong.
+Rec. S8012-02. Senator Kerry refers to the statutorily imposed damage amount as
+"penalties." Id.
+The cases of U.S. v. Siegel, supra (11" Cir. 1998), and U.S. v. Edwards, supra
+(3d Cir. 1998), also support Defendant's position that application of the current version
+of 18 U.S.C. §2255 would be in clear violation of the Ex Post Facto Clause. In Siegel,
+the Eleventh Circuit found that the Ex Post Facto Clause barred application of the
+Mandatory Victim Restitution Act of 1996 (MVRA) to the defendant whose criminal
+conduct occurred before the effective date of the statute, 18 U.S.C. §3664(f)(1)(A), even
+though the guilty plea and sentencing proceeding occurred after the effective date of the
+statute. On July 19, 1996, the defendant Siegel pleaded guilty to various charges under
+18 U.S.C. §371 and §1956(a)(1)(A), (conspiracy to commit mail and wire fraud, bank
+fraud, and laundering of money instruments; and money laundering). He was
+sentenced on March 7, 1997. As part of his sentence, Siegel was ordered to pay
+$1,207,000.00 in restitution under the MVRA which became effective on April 24, 1996.
+Pub.L. No. 104-132, 110 Stat. 1214, 1229-1236. The 1996 amendments to MVRA
+required that the district court must order restitution in the full amount of the victim's loss
+
+
+Case 9:09-cv-80469-KAM Document 13
+Entered on FLSD Docket 05/06/2009 Page 13 of 29
+Page 13
+Clause." Id, at 1259. In determining that the application of the 1996 MVRA would
+indeed run afoul of the Constitution's Ex Post Facto Clause, the Court agreed with the
+majority of the Circuits that restitution under the 1996 MVRA was an increased penalty?
+"The effect of the MVRA can be detrimental to a defendant. Previously, after
+considering the defendant's financial condition, the court had the discretion to order
+restitution in an amount less than the loss sustained by the victim. Under the MVRA,
+however, the court must order restitution to each victim in the full amount." Id, at 1260.
+See also U.S. v. Edwards, 162 F.2d 87 (31 Circuit 1998).
+In the instant case, in answering the first question, it is clear that that imposition of
+a minimum amount of damages, regardless of the amount of actual damages suffered
+by a minor victim, is meant to be a penalty or punishment. See statutory text and
+House Bill Reports, cited above herein, consistently referring to the presumptive
+minimum damages amount under §2255 as "punishment" or "penalties." According to
+the Ex Post Facto doctrine, although §2255 is labeled a "civil remedy," such label is not
+dispositive; "if the effect of the statute is to impose punishment that is criminal in nature,
+the ex post facto clause is implicated." See generally, Roman Catholic Bishop of
+Oakland v. Superior Court, 28 Cal.Rptr. 3d 355, at 360, citing Kansas v. Hendricks, 521
+U.S. 346, 360-61 (1997). The effect of applying the 2006 version of §2255 would be to
+triple the amount of the presumptive minimum damages to a minor who proves the
+2 The Eleventh Circuit, in holding that "the MVRA cannot be applied to a person whose criminal
+conduct occurred prior to April 24, 1996," was "persuaded by the majority of districts on this
+issue." "Restitution is a criminal penalty carrying with it characteristics of criminal punishment."
+Siegel, supra at 1260. The Eleventh Circuit is in agreement with the Second, Third, Eighth,
+- Circuits. See U.S. v. Futrell, 209 F.3d 1286, 1289-90 (11" Cir. 2000).
+
+
+
+Page 15
+application. As noted, 18 U.S.C. §2255 is entitled "Civil remedy for personal injuries."
+Notwithstanding this label, the statute was enacted as part of the criminal statutory
+scheme to punish those who sexually exploit and abuse minors.
+Regardless of the
+actual damages suffered or proven by a minor, as long as a minor proves violation of a
+specified statutory criminal act under §2255 and personal injury, the defendant is held
+liable for the statutory imposed minimum.
+As explained by the Landgraf court, supra at 280, and at 1505,?
+When a case implicates a federal statute enacted after the events in suit, the court's
+first task is to determine whether Congress has expressly prescribed the statute's
+proper reach. If Congress has done so, of course, there is no need to resort to judicial
+default rules. When, however, the statute contains no such express command, the
+court must determine whether the new statute would have retroactive effect, l.e.,
+whether it would impair rights a party possessed when he acted, increase a party's
+liability for past conduct, or impose new duties with respect to transactions already
+completed. If the statute would operate retroactively, our traditional presumption
+teaches that it does not govern absent clear congressional intent favoring such a
+result.
+Here, there is no clear expression of intent regarding the 2006 Act's application to
+conduct occurring well before its enactment. Clearly, however, as discussed in part B
+herein, the presumptive minimum amount of damages of $150,000 was enacted as an
+punishment or penalty upon those who sexually exploit and abuse minors. See
+discussion of House Bill Reports and Congressional background above herein. The
+amount triples the previous amount for which a defendant might be found liable,
+regardless of the amount of actual damages a plaintiff has suffered and proven. The new
+3 In Landgraf, the United States Supreme Court affirmed the judgment of the Court of Appeals
+and refused to apply new provisions of the Civil Rights Act of 1991 to conduct occurring before
+he effective date of the Act. The Court determined that statutory text in question, §102, was
+subject to the presumption against statutory retroactivity.
+
+
+• Case 9:09-cv-80469-KAM
+Entered on FLSD Docket 05/06/2009 Page 17 of 29
+Page 17
+allegations must be enough to raise a right to relief above the speculative level... on the
+assumption that all the allegations in the complaint are true (even if doubtful in fact)." Id.
+On a motion to dismiss, the well pleaded allegations of plaintiff's complaint are taken as
+true and construed in the light most favorable to the plaintiff. M.T.V. v. DeKalb County
+Sch. Dist., 446 F.3d 1153, 1156 (11th Cir.2006).
+In discussing Twombly, the Eleventh Circuit in Watts v. Fla. International Univ.,
+495 F.3d 1289, 1295 (11 Cir. 2007), noted - "The Supreme Court's most recent
+formulation of the pleading specificity standard is that 'stating such a claim requires a
+complaint with enough factual matter (taken as true) to suggest' the required element."
+In order to sufficiently allege the claim, the complaint is required to identify "facts that
+are suggestive enough to render [the element) plausible." Watts, 495 F.3d at 1296
+(quoting Iwombly. 127 S.Ct. at 1965).
+Pursuant to Rule 12(e), a party may move for more definite statement of a
+pleading to which a responsive pleading is allowed where the pleading "is so vague or
+ambiguous that the party cannot reasonably frame a response." The motion is required
+to point out the defects and the desired details. Id. As to the general rules and form of
+pleading, Rules 8 and 10, a claim for relief must contain "a short plain statement of the
+claim showing that the pleader is entitled to relief;" Rule 8(a)(3); and may contain
+alternative claims within a count or as many separate claims. Rule 10(d)(2) and (3).
+A. 18 U.S.C. $2255(a) does not allow the Plaintiff to multiple the presumptive
+minimum damages amount on a per incident or per violation basis.
+In attempting to allege a §2255 claim, Plaintiff alleges that she is entitled to a
+multiplication of the presumptive minimum damages amount based on the number of
+
+
+Case 9:09-cv-80469-KAM Document 13
+Entered on FLSD Docket 05/06/2009 Page 19 of 29
+Page 19
+Martinez v. White, 492 F.Supp.2d 1186, 1188 (N.D. Cal. 2007), (emphasis added). 18
+U.S.C.A. §2255 "merely provides a cause of action for damages in 'any appropriate
+United States District Court.'" Id, at 1189. In Tilton v. Playboy Entertainment Group,
+Inc., 554 F.3d 1371 (11" Cir. Jan. 15, 2009), the District Court granted plaintiff "the
+minimum 'actual damages' prescribed by §2255(a)," wherein plaintiff alleged that
+defendants had violated three of the statutory predicate acts; there was no multiplying of
+the award.
+It is well settled that in interpreting a statute, the court's inquiry begins with the
+plain and unambiguous language of the statutory text. CBS, Inc. v. Prime Time 24
+Venture, 245 F.3d 1217 (11" Cir. 2001); U.S. v. Castroneves, 2009 WL 528251, *3
+(S.D. Fla. 2009), citing Reeves v. Astrue, 526 F.3d 732, 734 (11"' Cir. 2008); and Smith
+V. Husband, 376 F.Supp.2d at 610 ("When interpreting a statute, la court's] inquiry
+begins with the text."). "The Court must first look to the plain meaning of the words, and
+scrutinize the statute's language, structure, and purpose." Id. In addition, in construing
+a statute, a court is to presume that the legislature said what it means and means what
+it said, and not add language or give some absurd or strained interpretation. As stated
+in CBS, Inc., supra at 1228 - "Those who ask courts to give effect to perceived
+legislative intent by interpreting statutory language contrary to its plain and
+unambiguous meaning are in effect asking courts to alter that language, and "Icourts
+have no authority to alter statutory language.... We cannot add to the terms of [the]
+provision what Congress left out. Merritt, 120 F.3d at 1187." See also Dodd v. U.S.,
+125 S.Ct. 2478 (2005); 73 Am.Jur.2d Statutes §124.
+
+
+
+Page 21
+had intended to abrogate the forum non conveniens doctrine in a §2255 action; the
+District Court noted that the statute does not contain a mandatory venue provision. Had
+Congress wanted to get rid of the forum non-conveniens doctrine, it would have said so
+in the statute. Also, in Smith v. Husband, 428 F.Supp. 432; and 376 F.Supp.2d 603, the
+plaintiff invoked "the accompanying civil remedy for these criminal violations, stating that
+she has sustained and continues to sustain physical and mental damages, humiliation,
+and embarrassment as a result of Defendant's criminal acts." In other words, she
+brought a single cause of action, based on allegations of multiple violations of the §2255
+predicate acts. Furthermore, the court refused to add a venue interpretation that simply
+was not written into the statutory text. See other §2255 cases cited herein.
+For an example of a statute wherein the legislature included the language "for
+each violation" in assessing a "civil penalty," see 18 U.S.C. §216, entitled "Penalties and
+injunctions," of Chapter 11 - "Bribery, Graft, and Conflict of Interests," also contained in
+Title 18 - "Crimes and Criminal Procedure." Subsection (b) of §216 gives the United
+States Attorney General the power to bring a "civil action ... against any person who
+engages in conduct constituting an offense under" specified sections of the bribery,
+graft, and conflicts of interest statutes. The statute further provides in relevant part that
+"upon proof of such conduct by a preponderance of the evidence, such person shall be
+subject to a civil penalty of not more than $50,000 for each violation or the amount of
+compensation which the person received or offered for the prohibited conduct, which
+ever amount is greater." As noted, 18 U.S.C. §2255 does not include such language.
+
+
+
+, et al.
+rage zo
+commerce, or within the special maritime and territorial jurisdiction of the United States
+knowingly persuades, induces, entices, or coerces any individual who has not attained
+the age of 18 years, to engage in prostitution or any sexual activity for which any person
+can be charged with a criminal offense, or attempts to do so, ...."
+Plaintiff appears to be relying solely on an "agreement with the United States
+Attorney's Office to not contest liability for claims brought exclusively pursuant to 18
+U.S.C. §2255, in exchange for avoiding federal prosecution under 18 U.S.C. §2422(b)."
+Complaint, 115. As noted above herein, Plaintiff already has additional claims against
+EPSTEIN pending in state court. See Exhibit A hereto. Even taking Plaintiff's allegation
+in paragraph 15 as true, Plaintiff is not proceeding exclusively under §2255.
+Accordingly, under the standard of pleading as established in Twombly, supra, Plaintiff
+has failed to sufficiently allege the requisite elements of a §2255 claim, thus requiring
+dismissal for failure to state a cause of action.
+C. In the alternative, pursuant to constitutional law principles of statutory
+interpretation, 18 U.S.C. $2255 is required to be interpreted as creating a
+single "civil remedy" or cause of action on behalf of a minor plaintiff
+against a defendant. The "civil remedy" afforded is not on a "per violation"
+or "per incident" basis.
+As set forth above, it is Defendant's position that the text of 18 U.S.C. §2255
+does not allow a Plaintiff to pursue the damages afforded under the statute on a "per
+violation" or "per incident" basis. In the alternative, if one were to assume that the
+language of §2255 were vague or ambiguous, under the constitutional based
+protections of due process, judicial restraint, and the rule of lenity applied in construing
+a statute, Defendant's position as to the meaning of the statute would prevail over
+
+
+
+Page 25
+Plaintiff's position would subject Defendant EPSTEIN to a punishment that is not
+clearly prescribed - an unwritten multiplier of the "actual damages" or the presumptive
+minimum damages. The rule of lenity requires that Defendant's interpretation of the
+remedy afforded under §2255 be adopted.
+As noted above, Plaintiff's interpretation
+would allow Plaintiff to multiply her recovery without any regard to what the actual
+damages are.
+In addition, under the Due Process Clause's basic principle of fair warning -
+... a criminal statute must give fair warning of the conduct that it makes a
+crime
+.... As was said in United States v. Harriss, 347 U.S. 612, 617, 74
+S.Ct. 808, 812, 98 L. Ed. 989,
+'The constitutional requirement of definiteness is violated by a criminal
+statute that fails to give a person of ordinary intelligence fair notice that
+his contemplated conduct is forbidden by the statute. The underlying
+principle is that no man shall be held criminally responsible for conduct
+which he could not reasonably understand to be proscribed.'
+Thus we have struck down a [state] criminal statute under the Due Process
+Clause where it was not 'sufficiently explicit to inform those who are subject
+to it what conduct on their part will render them liable to its penalties.'
+Connally v. General Const. Co., 269 U.S. 385, 391, 46 S.Ct. 126, 127, 70
+application violates the first essential of due process of law, ibid., and that
+'No one may be required at peril of life, liberty or property to speculate as to
+the meaning of penal statutes. All are entitled to be informed as to what the
+State commands or forbids! Lanzetta v. New Jersey, 306 U.S. 451, 453, 59
+S.Ct. 618, 619, 83 L.Ed. 888
+Thus,
+applying
+these well-entrenched constitutional principles of statutory
+interpretation and application, Plaintiff's cause of action attempting to multiply the
+presumptive amount of damages is required to be dismissed for failure to state a cause
+of action.
+
+
+
+Page 27
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following service list in the
+mang ay i hate 20ge of Notes of Election fling generated by MECH
+Isidro M. Garcia, Esq.
+Garcia Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff
+| Fax
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+Respectful
+By: _
+ROBERT D. CRITTON, JR., ESQ.
+Ford Bala. 224182
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+(Co-counsel for Defendant Jeffrey Epstein)
+ENDNOTES:
+' In paragraph 11 of her Complaint, Jane Doe Il alleges that - "From about June, 2003
+until about February, 2005, Defendants, EPSTEIN and
+persuaded, induced, or
+
+
+Entered on FLSD Docket 05/06/2009 Page 29 of 29
+Page 29
+102, 112 Stat. 2975; Apr. 30, 2003, Pub.L. 108-21, Title I, § 103(a)(2)(A), (B), (b)(2)(A),
+117 Stat. 652, 653.)
+Amendments
+2006 Amendments. Subsec. (b). Pub.L. 109-248, § 203, struck out "not less than 5
+years and not more than 30 years" and inserted "not less than 10 years or for life".
+
+
+
+AEV
+Doe II v. Epstein et al
+Assigned to: Judge Kenneth A. Marra
+Lead case: 9:08-cv-80119-KAM
+Member case: (View Member Case)
+Cause: 28:1331 Federal Question
+Plaintiff
+U.S. District Court
+CIVIL DOCKET FOR CASE #: 9:09-cv-80469-KAM
+Date Filed: 03/24/2009
+Jury Demand: Plaintiff
+Nature of Suit: 360 P.I.: Other
+Jurisdiction: Federal Question
+represented by Isidro Manuel Garcia
+Garcia Elkins & Boehringer
+224 Datura Avenue
+Suite 900
+West Palm Beach , FL 33401
+Fax: 832-7137
+Email: 1
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+V.
+Defendant
+Jeffrey Epstein
+epresented by Michael James Pike
+Burman Critton Luttier & Colemal
+Fax: 515-3148
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Robert Deweese Critton, Jr.
+Burman Critton Luttier & Coleman
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl7945531146089634-L_801_0-1
+
+
+
+Pax:
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Defendant
+Amicus
+United States of America
+represented by United States Atomey sOfice
+500 East Broward Blvd
+7th Floor
+Ft Lauderdale, FL 33394
+ext. 3546
+Fax: 356-7336
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Date Filed
+03/24/2009
+03/24/2009
+03/25/2009
+03/26/2009
+03/30/2009
+04/28/2009
+# clear Docket Text
+1
+COMPLAINT against Jeffrey Epstein,
+Filing fee $ 350.00.
+Receipt#: 725609, filed by
+) (Entered: 03/25/2009)
+2
+Summons Issued as to Jeffrey Epstein,
+(dj) (Entered:
+03/25/2009)
+3
+ORDER OF PRETRIAL PROCEDURES. Signed by Senior Judge Kenneth
+L. Ryskamp on 3/25/2009. (sh) (Entered: 03/25/2009)
+4
+ORDER REASSIGNING CASE. Case reassigned to Judge Kenneth A.
+Marra for all further proceedings. Senior Judge Kenneth L. Ryskamp no
+longer assigned to case. Signed by Senior Judge Kenneth L. Ryskamp on
+3/24/2009. (cqs) (Entered: 03/26/2009)
+5
+Order Requiring Counsel to Confer and File Joint Scheduling Report.
+Signed by Judge Kenneth A. Marra on 3/30/2009. (ir) (Entered:
+03/30/2009)
+ORDER TO SHOW CAUSE why cases should not be consolidated for
+discovery purposes Show Cause Response due by 5/5/2009.. Signed by
+Judge Kenneth A. Marra on 4/28/2009. (cqs) (Entered: 04/29/2009)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl7945531146089634-L_801_0-1
+
+
+/ 05/01/2009
+
+8
+2
+10
+05/15/2009
+05/19/2009
+12
+13
+14
+15
+16
+17
+Defendant's MOTION for Extension of Time to File Response as to 1
+Complaint by Jeffrey Epstein. (Pike, Michael) (Entered: 05/01/2009)
+ENDORSED ORDER granting 7 Motion for Extension of Time to Answer
+Complaint. Jeffrey Epstein response due 5/6/2009. Signed by Judge
+Kenneth A. Marra on 5/4/2009. (ir) (Entered: 05/04/2009)
+MEMORANDUM in Opposition re 6 Order to Show Cause by Jeffrey
+Epstein. (Pike, Michael) (Entered: 05/04/2009)
+Clerks Notice of Docket Correction and Instruction to Filer re 9
+Memorandum in Opposition filed by Jeffrey Epstein. Error - Wrong Event
+Selected; Correct event "Response to ORder to Show Cause" In the future
+Please select the proper event. It is not necessary to refile this document.
+(tp) (Entered: 05/05/2009)
+MOTION for Leave to File Excess Pages by Jeffrey Epstein. (Critton,
+Robert) (Entered: 05/05/2009)
+ENDORSED ORDER granting 11 Motion for Leave to File Excess Pages.
+Signed by Judge Kenneth A. Marra on 5/5/2009. (ir) (Entered: 05/06/2009)
+Defendant's MOTION to Dismiss 1 Complaint by Jeffrey Epstein.
+Responses due by 5/26/2009 (Attachments: # 1 Exhibit A, # 2 Exhibit B)
+(Pike, Michael) Modified on 5/7/2009 (Is). [Modified description of
+Attachments) from Motions to Dismiss to Exhibit A and Exhibit B]
+(Entered: 05/06/2009)
+Cases associated. (dg) (Entered: 05/14/2009)
+ORDER CONSOLIDATING CASES. Hereinafter all motions and other
+court filings that relate to discovery and all procedural motions that relate to
+multiple cases shall be styled with all of the case names and numbers and
+shall be filed in Case No. 08-80119-CIV-MARRA. Signed by Judge
+Kenneth A. Marra on 5/14/2009. Associated Cases: 9:08-cv-80119-KAM et
+ORDER REQUESTING UNITED STATES PROVIDE POSITION TO
+MOTION TO STAY. Signed by Judge Kenneth A. Marra on 5/14/2009.
+(Attachments: # 1 Appendix Motion to Stay DE 51) Associated Cases:
+9:08-cv-80119-KAM et al. (ir) (Entered: 05/14/2009)
+First MOTION for Extension of Time to File Response as to 13 Defendant's
+MOTION to Dismiss 1 ComplaintDefendant's MOTION to Dismiss 1
+Complaint by
+(Garcia, Isidro) (Entered: 05/15/2009)
+ENDORSED ORDER denying as moot 16 Motion for Extension of Time to
+espond to Motion to Dismiss. Plaintiff's response is due 5/26/09. Signe
+y Judge Kenneth A. Marra on 5/18/2009. (ir) (Entered: 05/19/2009
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?945531146089634-L_801.
+
+
+05/20/2009|18
+
+19
+20
+21
+22
+23
+24
+NOTICE by|
+1. of Filing Withdrawal of Previously Raised Objections
+to Defendant, Jeffrey Epstein's Motion to Compel And/Or Identify
+in the Style of This Case and Motion to Identify
+• in Third-Party
+Subpoenas for Purposes of Discovery, Or, Alternatively, Motion to Dismiss
+Sua Sponte, With Inorporated Memorandum of Law Associated Cases:
+9:08-cv-80119-KAM et al.(Hill, Jack) (Entered: 05/20/2009)
+ORDER STRIKING in all Epstein cases EXCEPT case no. 08-80119:
+1. of Filing Withdrawal of Previously Raised Objections to
+Epstein's Motion to Compel and/or Identify. This Notice should only be
+filed in 08-80119, not in all of the Epstein cases.. Signed by Judge Kenneth
+A. Marra on 5/20/2009. Associated Cases: 9:08-cv-80119-KAM et al. (Ic3)
+(Entered: 05/20/2009)
+RESPONSE in Opposition re 13 Defendant's MOTION to Dismiss 1
+| ComplaintDefendant's MOTION to Dismiss 1 Complaint filed by |
+(Garcia, Isidro) (Entered: 05/22/2009)
+NOTICE byl
+(111 in 9:08-cv-80119-KAM) Plaintiff's MOTION
+for Extension of Time to File Response as to (91 in 9:08-cv-80119-KAM)
+Defendant's MOTION to Compel Identity of Doe in Style of Case and
+Third-Party Subpoenas (replaces Docket entry 90)Plaintifi's MOTION tor
+Extension of Time to File Response as to (91 in 9:08-cv-80119-KAM)
+Defendant's MOTION to Compel Identity of Doe in Style of Case and
+Third-Party Subpoenas (replaces Docket entry 90) (Attachments: # 1 Text
+of Proposed Order)Associated Cases: 9:08-cv-80119-KAM et al.(Horowitz,
+Adam) (Entered: 05/27/2009)
+ORDER STRIKING Notice by
+in all Epstein cases EXCEPT in
+case 08-80119. This Notice should only be filed in 08-80119, not in all of
+sociated Case.. -ed 011. 4M et al. . Eatened: 052812009)
+NOTICE of Attorney Appearance by
+on behalf of
+United States of America Associated Cases: 9:08-cv-80119-KAM et al.
+) (Entered: 05/29/2009)
+RESPONSE to Motion re (72 in 9:08-cv-80380-KAM) Defendant's
+MOTION to Stay re (62) Amended Complaint, (57 in 9:08-cv-80232-
+KAM) Defendant's MOTION to Stay re (50) Amended Complaint, (24 in
+9:08-cv-80893-KAM) Defendant's MOTION to Stay re (1) Complaint, (23
+in 9:08-cv-80994-KAM) Defendant's MOTION to Stay re (18) Amended
+Complaint, (22 in 9:08-cv-80993-KAM) Defendant's MOTION to Stay re
+(19) Amended Complaint, (65 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Stay re (56) Amended Complaint, (68 in 9:08-cv-80381-
+KAM) Defendant's MOTION to Stay re (60) Amended Complaint, (51 in
+9:08-CV-80811-KAM) Defendant's MOTION to Stay re (40) Amended
+Complaint and or Continue Action Filed Pursuant to Court's Order
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?945531146089634-L_801_0-1
+
+
+
+06/01/2009
+25
+26
+27
+28
+29
+Requesting Government's Position filed by United States of America.
+Replies due by 6/8/2009. Associated Cases: 9:08-cv-80119-KAM et al.
+D (Entered: 05/29/2009)
+RESPONSE in Opposition re (90 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Compel Identify Doe in Style of Case and in Third-Part
+lubpoenas, (91 in 9:08-cv-80119-KAM) Defendant's MOTION to Compe
+Identity of Doe in Style of Case and Third-Party Subpoenas (replaces
+Associated
+Cases: 9:08-cv-80119-KAM et al.(Ezell, Katherine) (Entered: 05/29/2009)
+ORDER STRIKING (124 in 9:08-cv-80119-KAM, 105 in 9:08-cv-80811-
+KAM, 74 in 9:08-cv-80993-KAM, 72 in 9:08-cv-80893-KAM, 106 in 9:08-
+cv-80232-KAM, 123 in 9:08-cv-80380-KAM, 35 in 9:09-cv-80591-KAM,
+25 in 9:09-cv-80469-KAM, 60 in 9:08-cv-80994-KAM, 22 in 9:09-cv-
+80656-KAM, 107 in 9:08-cv-80381-KAM) Response in Opposition to
+Motion, filed by 1
+DO NOT FILE IN
+EVERY EPSTEIN CASE. SEE ORDER CONSOLIDATING CASES..
+Signed by Judge Kenneth A. Marra on 5/29/2009. Associated Cases: 9:08-
+cv-80119-KAM et al. (Ic3) (Entered: 05/29/2009)
+MOTION for Leave to File UNDER SEAL RESPONSE IN OPPOSITION
+TO DEFENDANTS MOTION TO STAY OR, IN THE ALTERNATIVE, TO
+UNSEAL THE NONPROSECUTION AGREEMENT by
+Associated Cases: 9:08-cv-80119-KAM et al.(Ezell,
+Katherine) (Entered: 05/29/2009)
+MOTION TO RESCHEDULE HEARINGRescheduling Hearing or Appear
+By Telephone by -
+Associated Cases:
+9:08-cv-80119-KAM et al.(Josefsberg, Robert) Modified on 6/1/2009 (tp).
+(Entered: 05/29/2009)
+Clerks Notice of Docket Correction and Instruction to Filer re 28 Motion to
+Continue Hearing filed by
+The Filer
+06/01/2009
+30
+(Entered: 06/01/2009)
+ORDER STRIKING (28 in 9:09-cv-80469-KAM, 126 in 9:08-cv-80380-
+KAM, 109 in 9:08-cv-80232-KAM, 25 in 9:09-cv-80656-KAM, 77 in 9:08-
+cv-80993-KAM, 38 in 9:09-cv-80591-KAM, 110 in 9:08-cv-80381-KAM,
+63 in 9:08-cv-80994-KAM, 75 in 9:08-cv-80893-KAM, 108 in 9:08-cv-
+80811-KAM) Motion to Continue Hearing tiled by
+76 in 9:08-cv-80993-KAM, 109 in 9:08-cv-80381-KAM,
+108 in 9:08-cv-80232-KAM, 62 in 9:08-cv-80994-KAM, 125 in 9:08-cv-
+80380-KAM, 74 in 9:08-cv-80893-KAM, 24 in 9:09-cv-80656-KAM, 37 in
+9:09-cv-80591-KAM, 107 in 9:08-cv-80811-KAM, 27 in 9:09-cv-80469-
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?945531146089634-L_801.
+
+
+CM/ECF »Liye Database - flsd
+06/01/2009
+31
+32
+33
+06/08/2009
+34
+06/08/2009
+35.
+
+KAM) Motion for Leave to File, filed by
+A THESE DOCUMENTS SHOULD BE FILED ONLY IN 08-80119.
+SEE CASE MANAGEMENT ORDER.. Signed by Judge Kenneth A.
+Marra on 6/1/2009. (lc3) (Entered: 06/01/2009)
+REPLY to Response to Motion re 13 Defendant's MOTION to Dismiss 1
+ComplaintDefendant's MOTION to Dismiss 1 Complaint filed by Jeffrey
+Epstein. (Pike, Michael) (Entered: 06/01/2009)
+REPLY to Response to Motion re (113 in 9:08-cv-80119-KAM) Plaintiff's
+MOTION Plaintiffs M
+lotion for No-
+Contact Order Plaintiffs
+Reply
+to Defendant Jeffrey Epstein's Response to Plaintiffs I
+and
+-..
+ило солись отды тос оу зано соо
+Associated Cases: 9:08-cv-80119-KAM et al.
+(Ezell, Katherine) (Entered: 06/04/2009)
+ORDER STRIKING (112 in 9:08-cv-80381-KAM, 111 in 9:08-cv-80232-
+KAM, 136 in 9:08-cv-80119-KAM, 111 in 9:08-cv-80811-KAM, 128 in
+9:08-cv-80380-KAM, 65 in 9:08-cv-80994-KAM, 79 in 9:08-cv-80893-
+KAM, 42 in 9:09-cv-80591-KAM, 27 in 9:09-cv-80656-KAM, 32 in 9:09-
+cv-80469-KAM, 79 in 9:08-cv-80993-KAM) Reply to Response to Motion,
+filed by
+Document stricken for failure
+to follow Court's orders. DO NOT FILE A DOCUMENT IN EVERY
+EPSTEIN CASE if it is to be filed only in 08-80119. See Case Management
+Order and contact CM/ECF Support for assistance in proper filing.. Signed
+by Judge Kenneth A. Marra on 6/4/2009. Associated Cases: 9:08-cv-80119-
+KAM et al. (Ic3) (Entered: 06/04/2009)
+RESPONSE to Motion re (91 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Compel Identity of Doe in Style of Case and Third-Party
+Subpoenas (replaces Docket entry 90) filed by Jane Doe. Replies due by
+6/18/2009. (Attachments: # 1 Exhibit A, # 2 Exhibit B)Associated Cases:
+9:08-cv-80119-KAM et al.(Horowitz, Adam) (Entered: 06/08/2009)
+NOTICE by Jane Doe re (113 in 9:08-cv-80119-KAM) Plaintiff's MOTION
+Plaintiffs
+and.
+Motion for No-Contact
+Order -Plaintiffs
+Wotice of Joinder Associated Cases: 9:08-
+cv-80119-KAM et al.(Horowitz., Adam) (Entered: 06/08/2009)
+or
+Download Selected
+PACER Service Center
+Transaction Receipt
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|?945531146089634-L_801_0-1
+
+
+CM/ECF »Live Database - flsd
+
+PACER
+Login:
+Deseription:
+Billable
+Pages:
+06/10/2009 14:29:53
+du4480
+Client Code:
+Docket
+Report
+4
+Search
+Criteria:
+Cost:
+9:09-cv-80469-
+KAM
+10.32
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?945531146089634-L_801_0-1
+
+
+
+LRJ
+Doe No. 101 v. Epstein
+Assigned to: Judge Kenneth A. Marra
+Lead case: 9:08-cv-80119-KAM
+Member case: (View Member Case)
+Cause: 28:1331 Fed. Question: Personal Injury
+Plaintiff
+U.S. District Court
+CIVIL DOCKET FOR CASE #: 9:09-cv-80591-KAM
+Date Filed: 04/17/2009
+Jury Demand: Plaintiff
+Nature of Suit: 360 P.I.: Other
+Jurisdiction: Federal Question
+represented by Katherine Warthen Ezell
+Podhurst Orseck Josefsberg et al
+City National Bank Building
+25 W Flagler Street
+Suite 800
+Miami , FL 33130-1780
+Email: KEzell@podhurst.com
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Robert . Josefsberg
+Podhurst Orseck Josefsberg et al
+City National Bank Building
+25 W Flagler Street
+Suite 800
+Miami, FL 33130-1780
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Defendant
+Jeffrey Epstein
+represented by Mirhad James Piter & Coleman
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl7716393569552562-L_801_0-1
+
+
+CM/ECF - Live Database - fsd
+
+Fax: 515-3148
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Robert Deweese Critton, Jr.
+Burman Critton Luttier & Coleman
+Email: rcrit@bclclaw.com
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Jay P. Lefkowitz
+Kirkland & Ellis
+655 15th Street NW
+Suite 1200
+Washington , DC 20005
+PRO HAC VICE
+ATTORNEY TO BE NOTICED
+Michael D. Shumsky
+Kirkland & Ellis
+655 15th Street NW
+Suite 1200
+Washington . DC 20005
+Email: michael.shumsky@kirkland.com
+PRO HAC VICE
+ATTORNEY TO BE NOTICED
+Amicus
+United States of America
+represented by
+United States Attorney's Office
+500 East Broward Blvd
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?716393569552562-L_801_0-1
+
+
+CM/ECF - İ ive Database - Asd
+Page 3 of9
+7th Floor
+Ft Lauderdale , FL 33394
+, ext. 3546
+Fax: 356-7336
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Date Filed
+04/21/2009
+04/28/2009
+05/01/2009
+05/01/2009
+05/01/2009
+#
+1
+2
+3
+4
+5
+6
+1
+8
+2
+10
+11
+clear Docket Text
+COMPLAINT and Demand for Jury Trial against Jeffrey Epstein. Filing
+fee $ 350.00. Receipt#: 999318, filed byl
+Isl) (Entered:
+04/20/2009)
+Summons Issued as to Jeffrey Epstein. (asl) (Entered: 04/20/2009)
+Sealed Document. (igo) (Entered: 04/20/2009)
+Sealed Document. (igo) (Entered: 04/20/2009)
+Order Requiring Counsel to Confer and File Joint Scheduling Report.
+Signed by Judge Kenneth A. Marra on 4/21/2009. (ir) (Entered:
+04/21/2009)
+ORDER TO SHOW CAUSE why cases should not be consolidated for
+60.2
+discovery purposes Show Cause Response due by 5/5/2009.. Signed by
+Judge Kenneth A. Marra on 4/28/2009. (cqs) (Entered: 04/29/2009)
+First AMENDED COMPLAINT and Demand for Jury Trial, filed by
+l.(Ezell, Katherine) (Entered: 05/01/2009)
+RESPONSE TO ORDER TO SHOW CAUSE by
+Ezell,
+Katherine) (Entered: 05/01/2009)
+First AMENDED COMPLAINT and Demand For Jury Trial, filed by
+Ezell, Katherine) (Entered: 05/01/2009)
+NOTICE of Striking 1 Amended Complaint filed by|
+by
+147.2
+KB
+(Ezell, Katherine) Modified on 5/6/2009 (Is). (Entered:
+05/04/2009)
+Defendant's MOTION for Extension of Time to File Response as to 9
+126.7
+Amended Complaint by Jeffrey Epstein. (Pike, Michael) (Entered:
+KB
+05/04/2009)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?716393569552562-L_801_0-1
+
+
+CM/ECF - Live Database - Asd
+| 05/04/2009
+12
+
+13
+05/07/2009
+05/11/2009
+05/11/2009
+05/18/2009
+05/19/2009
+15
+16
+17
+18
+19
+20
+21
+22
+MEMORANDUM in Opposition re 6 Order to Show Cause by Jeffrey
+Epstein. (Pike, Michael) (Entered: 05/04/2009)
+ENDORSED ORDER granting 11 Motion for Extension of Time to
+Inswer Complaint. Jeffrey Epstein response due 5/26/2009. Signed b
+udge Kenneth A. Marra on 5/5/2009. (ir) (Entered: 05/05/2009
+NOTICE by
+Notice of Filing (Attachments: # 1 Motion
+342 to Proceed Anonymously and Incorporated Memorandum of Law) Ezell,
+Katherine) (Entered: 05/06/2009)
+orie in on, race red Dev Criton, it on behalf
+RESPONSE/REPLY to 14 Notice (Other) Opposition to Motion to Proceed
+MiB Anonymously by Jeffrey Epstein. (Critton, Robert) (Entered: 05/11/2009)
+MOTION to Compel and/or identify!
+in the style of this case
+a the third party subpoenas for
+purposes of discovery with incorporated memorandum of law by Jeffrey
+Epstein. Responses due by 5/29/2009 (see docket entry 16 for image)(tas)
+Cases associated. (dg) (Entered: 05/14/2009)
+ORDER CONSOLIDATING CASES. Hereinafter all motions and other
+court filings that relate to discovery and all procedural motions that relate
+to multiple cases shall be styled with all of the case names and numbers and
+I shall be filed in Case No. 08-80119-CIV-MARRA. Signed by Judge
+Kenneth A. Marra on 5/14/2009. Associated Cases: 9:08-cv-80119-KAM et
+al. (ir) (Entered: 05/14/2009)
+ORDER REQUESTING UNITED STATES PROVIDE POSITION TO
+MOTION TO STAY. Signed by Judge Kenneth A. Marra on 5/14/2009.
+1.3
+MB
+(Attachments: # 1 Appendix Motion to Stay DE 51) Associated Cases:
+9:08-cv-80119-KAM et al. (ir) (Entered: 05/14/2009)
+See procedural minions pending: 91 in 08-8019. Signed by lucases
+Signed by Judg
+Kenneth A. Marra on 5/14/2009. (Ic3) (Entered: 05/14/2009)
+| Defendant's MOTION for Leave to File Excess Pages on Defendant's
+148.9
+| Motion to Dismiss First Amended Complaint by Jeffrey Epstein. (Pike,
+Michael) (Entered: 05/18/2009)
+ENDORSED ORDER granting 21 Motion for Leave to File Excess Pages.
+Signed by Judge Kenneth A. Marra on 5/19/2009. (ir) (Entered:
+05/19/2009)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?716393569552562-L_801_0-1
+
+
+CM/ECE - Live Database - flsd
+23
+363.
+24
+
+NOTICE by
+.. of Filing Withdrawal of Previously Raised Objections
+to Defendant, Jeffrey Epstein's Motion to Compel And/Or Identify
+in the Style of This Case and Motion to Identify
+. in Third-Party
+Subpoenas for Purposes of Discovery, Or, Alternatively, Motion to Dismiss
+Sua Sponte, With Inorporated Memorandum of Law Associated Cases:
+9:08-cv-80119-KAM et al.(Hill, Jack) (Entered: 05/20/2009)
+ORDER STRIKING in all Epstein cases EXCEPT case no. 08-80119:
+Notice by L
+1. of Filing Withdrawal of Previously Raised Objections to
+Epstein's Motion to Compel and/or Identify. This Notice should only be
+filed in 08-80119, not in all of the Epstein cases.. Signed by Judge Kenneth
+A. Marra on 5/20/2009. Associated Cases: 9:08-cv-80119-KAM et al. (Ic3)
+(Entered: 05/20/2009)
+05/21/2009
+05/21/2009
+05/26/2009
+05/26/2009
+05/26/2009
+26
+28
+29
+Certification of Jay P. Lefkowitz, # 2 Text of Proposed Order Proposed
+Order Granting Motion for Limited Appearance of Jay P. Lefkowitz)
+(Critton, Robert) (Entered: 05/21/2009)
+MOTION for Leave to Appear Limited Appearance Pro Hac Vice by
+Jeffrey Epstein. Responses due by 6/8/2009 (Attachments: # 1 Certification
+2672 of Shumsky, # 2 Text of Proposed Order Granting Motion for Limited
+Appearance of Michael D. Shumsky)(Critton, Robert) (Entered:
+05/21/2009)
+Clerks Notice of Instruction to Filer Regarding Pro Hac Vice Motion.
+Pursuant to 2B in the Administrative Procedures, a motion to make a
+limited appearance must be filed in the conventional manner along with the
+applicable filing fee. LOCAL COUNSEL IS INSTRUCTED TO 1. FILE A
+NOTICE TO STRIKE DE# 26 MOTION for Leave to Appear Limited
+Appearance Pro Hac Vice filed by Jeffrey Epstein, 25 MOTION for Leave
+to Appear Limited Appearance Pro Hac Vice filed by Jeffrey Epstein AND
+2. CÖNVENTIONALLY FILE AN ORIGINAL MÓTION TO MAKE A
+LIMITED APPEARANCE ALONG WITH THE APPLICABLE FILING
+FEE. (Is) (Entered: 05/26/2009)
+Plaintiff's MOTION to Preserve Evidence Plaintiffs
+ind
+Motion for an Order for the Preservation of Evidence
+ind Incorporated Memorandum of Law by
+1.7
+MB
+Attachments: # 1 Exhibit "A".
+' # 2 Exhibit "B"
+", # 3 Text of
+Proposed Order)Associated Cases: 9:08-cv-80119-KAM, 9:09-cv-80591-
+KAM, 9:09-cv-80656-KAM(Ezell, Katherine) (Entered: 05/26/2009)
+Defendant's MOTION to Dismiss 7 Amended Complaint or in the
+Alternative, for a More Definate Statement by Jeffrey Epstein. Responses
+5.3
+MB
+due by 6/12/2009 (Attachments: # 1 Exhibit "A", # 2 Exhibit "B")(Critton,
+Robert) (Entered: 05/26/2009)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?716393569552562-L_801_0-1
+
+
+CM/ECR - Live Database - flsd
+30
+
+31
+33.
+34
+35
+36
+ORDER terminating(28) Motion to Preserve Evidence in case 9:09-cv-
+80591-KAM; terminating(16) Motion to Preserve Evidence in case 9:09-
+cv-80656-KAM This motion is pending ONLY in case no. 08-80119..
+Signed by Judge Kenneth A. Marra on 5/27/2009. (Ic3) (Entered:
+05/27/2009)
+NOTICE by
+[111 in 9:08-cv-80119-KAM) Plaintiff's
+MOTION for Extension of Time to File Response as to (91 in 9:08-cv-
+80119-KAM) Defendant's MOTION to Compel Identity of Doe in Style of
+Case and Third-Party Subpoenas (replaces Docket entry 90)Plaintift's
+MOTION for Extension of Time to File Response as to (91 in 9:08-cv-
+80119-KAM) Defendant's MOTION to Compel Identity of Doe in Style of
+Case and Third-Party Subpoenas (replaces Docket entry 90) (Attachments:
+# 1 Text of Proposed Order)Associated Cases: 9:08-cv-80119-KAM et al.
+(Horowitz, Adam) (Entered: 05/27/2009)
+ORDER STRIKING Notice by Jane Doe in all Epstein cases EXCEPT in
+case 08-80119. This Notice should only be filed in 08-80119, not in all of
+Associatin Case. igned 801 9. Met al. (le Entered: 5282009)
+NOTICE of Attorney Appearance by
+on behalf of
+United States of America Associated Cases: 9:08-cv-80119-KAM et al.
+D (Entered: 05/29/2009)
+RESPONSE to Motion re (72 in 9:08-cv-80380-KAM) Defendant's
+MOTION to Stay re (62) Amended Complaint, (57 in 9:08-cv-80232-
+KAM) Defendant's MOTION to Stay re (50) Amended Complaint, (24 in
+9:08-cv-80893-KAM) Defendant's MOTION to Stay re (1) Complaint, (23
+in 9:08-cv-80994-KAM) Defendant's MOTION to Stay re (18) Amended
+Complaint, (22 in 9:08-cv-80993-KAM) Defendant's MOTION to Stay re
+(19) Amended Complaint, (65 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Stay re (56) Amended Complaint, (68 in 9:08-cv-80381-
+KAM) Defendant's MOTION to Stay re (60) Amended Complaint, (51 in
+9:08-cv-80811-KAM) Defendant's MOTION to Stay re (40) Amended
+Complaint and or Continue Action Filed Pursuant to Court's Order
+Requesting Government's Position filed by United States of America.
+Replies due by 6/8/2009. Associated Cases: 9:08-cv-80119-KAM et al.
+D (Entered: 05/29/2009)
+RESPONSE in Opposition re (90 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Compel Identify Doe in Style of Case and in Third-Party
+Subpoenas, (91 in 9:08-cv-80119-KAM) Defendant's MOTION to Compel
+Identity of Doe in Style of Case and Third-Party Subpoenas (replaces
+Associated
+Cases: 9:08-cv-80119-KAM et al.(Ezell, Katherine) (Entered: 05/29/2009)
+ORDER STRIKING (124 in 9:08-cv-80119-KAM, 105 in 9:08-cv-80811-
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|7716393569552562-L_801_0-1
+
+
+
+37
+06/01/2009
+38
+39
+40
+41
+42
+KAM, 74 in 9:08-cv-80993-KAM, 72 in 9:08-cv-80893-KAM, 106 in 9:08-
+cv-80232-KAM, 123 in 9:08-cv-80380-KAM, 35 in 9:09-cv-80591-KAM,
+25 in 9:09-cv-80469-KAM, 60 in 9:08-cv-80994-KAM, 22 in 9:09-cv-
+80656-KAM, 107 in 9:08-cv-80381-KAM) Response in Opposition to
+Motion, filed by I
+DO NOT FILE IN
+EVERY EPSTEIN CASE. SEE ORDER CONSOLIDATING CASES..
+Signed by Judge Kenneth A. Marra on 5/29/2009. Associated Cases: 9:08-
+cv-80119-KAM et al. (lc3) (Entered: 05/29/2009)
+MOTION for Leave to File UNDER SEAL RESPONSE IN OPPOSITION
+TO DEFENDANTS MOTION TO STAY OR, IN THE ALTERNATIVE, TO
+24.5
+UNSEAL THE NONPROSECUTION AGREEMENT by
+Associated Cases: 9:08-cv-80119-KAM et al.(Ezell,
+Katherine) (Entered: 05/29/2009)
+MOTION for Hearing MOTION TO RESCHEDULE HEARING by |
+ssociated Cases: 9:08-cv-80119-KAM et
+al.(Josefsberg, Robert) (Entered: 05/29/2009)
+ORDER STRIKING (28 in 9:09-cv-80469-KAM, 126 in 9:08-cv-80380-
+KAM, 109 in 9:08-cv-80232-KAM, 25 in 9:09-cv-80656-KAM, 77 in 9:08-
+cv-80993-KAM, 38 in 9:09-cv-80591-KAM, 110 in 9:08-cv-80381-KAM,
+63 in 9:08-cv-80994-KAM, 75 in 9:08-cv-80893-KAM, 108 in 9:08-cv-
+80811-KAM) Motion to Continue Hearing filed by
+(76 in 9:08-cv-80993-KAM, 109 in 9:08-cv-80381-KAM,
+108 in 9:08-cv-80232-KAM, 62 in 9:08-cv-80994-KAM, 125 in 9:08-cv-
+80380-KAM, 74 in 9:08-cv-80893-KAM, 24 in 9:09-cv-80656-KAM, 37 in
+9:09-cv-80591-KAM, 107 in 9:08-cv-80811-KAM, 27 in 9:09-cv-80469-
+KAM) Motion for Leave to File, filed by .
+THESE DOCUMENTS SHOULD BE FILED ONLY IN 08-80119.
+SEE CASE MANAGEMENT ORDER.. Signed by Judge Kenneth A.
+Marra on 6/1/2009. (lc3) (Entered: 06/01/2009)
+MOTION for Limited Appearance, Consent to Designation and Request to
+281.7 Electronically Receive Notices of Electronic Filings for Michael D.
+Shumsky, Filing Fee $75.00, Receipt #725905. (cw) (Entered: 06/04/2009)
+MOTION for Limited Appearance, Consent to Designation and Request to
+272.3 | Electronically Receive Notices of Electronic Filings for Jay P. Lefkowitz,
+Filing Fee $75.00, Receipt #725904. (cw) (Entered: 06/04/2009)
+REPLY to Response to Motion re (113 in 9:08-cv-80119-KAM) Plaintiff's
+MOTION Plaintiffs
+Motion for No-
+Contact Order Plaintiffs
+Reply
+349.0 | to Defendant Jeffrey Epstein's Response to Plaintiffs!
+Motion for a No-Contact Order filed by
+Associated Cases: 9:08-cv-80119-KAM et al.
+(Ezell, Katherine) (Entered: 06/04/2009)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl7716393569552562-L_801_0-1
+
+
+43
+
+ORDER STRIKING (112 in 9:08-cv-80381-KAM, 111 in 9:08-cv-80232-
+KAM, 136 in 9:08-cv-80119-KAM, 111 in 9:08-cv-80811-KAM, 128 in
+9:08-cv-80380-KAM, 65 in 9:08-cv-80994-KAM, 79 in 9:08-cv-80893-
+KAM, 42 in 9:09-cv-80591-KAM, 27 in 9:09-cv-80656-KAM, 32 in 9:09-
+cv-80469-KAM, 79 in 9:08-cv-80993-KAM) Reply to Response to Motion,
+filed by!
+Document stricken for failure
+to follow Court's orders. DO NOT FILE A DOCUMENT IN EVERY
+EPSTEIN CASE if it is to be filed only in 08-80119. See Case
+Management Order and contact CM/ECF Support for assistance in proper
+filing.. Signed by Judge Kenneth A. Marra on 6/4/2009. Associated Cases:
+9:08-cv-80119-KAM et al. (Ic3) (Entered: 06/04/2009)
+06/07/2009
+47
+06/08/2009
+06/08/2009
+06/08/2009
+06/09/2009
+06/09/2009
+44
+45
+46
+48
+51
+49
+106.1
+KB
+53.4
+KB
+06/09/2009)
+RESPONSE to Motion re (91 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Compel Identity of Doe in Style of Case and Third-Party
+Subpoenas (replaces Docket entry 90) filed by Jane Doe. Replies due by
+6/18/2009. (Attachments: # 1 Exhibit A, # 2 Exhibit B)Associated Cases:
+9:08-cv-80119-KAM et al.(Horowitz, Adam) (Entered: 06/08/2009)
+NOTICE by Jane Doe re (113 in 9:08-cv-80119-KAM) Plaintiff's
+MOTION Plaintiffs
+Motion for No-
+Contact Order -Plaintiffs
+Notice of Joinder Associated
+Cases: 9:08-cv-80119-KAM et al.(Horowitz, Adam) (Entered: 06/08/2009)
+ORDER granting 41 Motion for Limited Appearance, Consent to
+Designation and Request to Electronically Receive Notices of Electronic
+Filings. Signed by Judge Kenneth A. Marra on 6/8/2009. (ail) (Entered:
+06/09/2009)
+Plaintiff's MOTION for Extension of Time to File Response as to 29
+Defendant's MOTION to Dismiss 7 Amended Complaint or in the
+Alternative, for a More Definate StatementDefendant's MOTION to
+Dismiss 1 Amended Complaint or in the Alternative, for a More Definate
+Motion for Enlargement of Time
+and Page Limits for Response to Defendant's Motion to Dismiss the First
+Amended Complaint or, in the Alternative, for a More Definite Statement
+by
+(Attachments: # 1 Text of Proposed Order)(Ezell,
+Katherine) (Entered: 06/09/2009)
+MOTION for Leave to File Excess Pages byl
+SEE
+IMAGE 48 (ail) (Entered: 06/10/2009)
+ENDORSED ORDER granting 48 Motion for Extension of Time to
+Respond re 29 Defendant's MOTION to Dismiss 1 Amended Complaint or
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|7716393569552562-L_801_0-1
+
+
+
+50
+Or
+in the Alternative, for a More Definate Statement. Responses due by
+6/26/2009. Page limit is set at 36 pages. Signed by Judge Kenneth A. Marra
+on 6/9/2009. (ir) (Entered: 06/10/2009)
+Clerks Notice of Docket Correction and Instruction to Filer re 45 Notice
+(Other), Notice (Other) filed by
+. Error - Wrong Event Selected;.
+Instruction to Filer - In the future, please select the proper event, i.e. Notice
+of Adoption. It is not necessary to refile this document. (Is) (Entered:
+06/10/2009)
+Total filesize of selected documents (MB): /.
+Maximum filesize allowed (MB): 10
+Download Selected
+PACER
+Login:
+Description:
+Billable
+Pages:
+PACER Service Center
+Transaction Receipt
+06/10/2009 14:44:15
+du4480
+Client Code:
+Docket
+Search
+Report
+Criteria:
+5
+Cost:
+9:09-cv-80591-
+KAM
+0.40
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?716393569552562-L_801_0-1
+
+
+Case 9:08-cv-80811-KAM Document 113
+Entered on FLSD Docket 06/05/2009
+
+CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON
+Plaintiff,
+VS.
+JEFFREY EPSTEIN and
+Defendants.
+PLAINTIFF,
+'S, CONDITIONAL NOTICE OF INTENT TO EXCLUSIVELY RELY
+ON STATUTORY DAMAGES PROVIDED BY 18 U.S.C. §2255
+Plaintiff,
+.. by and through her undersigned counsel, hereby files her
+Conditional Notice of Intent to Exclusively Rely on Statutory Damages Provided by 18
+U.S.C. §2255, and in support thereof states as follows:
+This is an action to recover money damages against Defendant,
+JEFFREY EPSTEIN, for acts of sexual abuse and prostitution committed upon the thenminor,
+2.
+Plaintiff has plead thirty separate counts against EPSTEIN for separate
+incidences of abuse committed by EPSTEIN against Plaintiff pursuant to 18 U.S.C.
+§2255. 18 U.S.C. §2255, entitled "Civil remedy for personal injuries", creates a private
+right of action for minor children who were the victim of certain enumerated sex
+offenses. 18 U.S.C. §2255 also creates a statutory floor for the amount of damages a
+
+
+Document 113 Entered on FLSD Docket 06/05/2009 Page 2 of 4
+victim can recover for a violation of same. Plaintiff has also alleged a single count of
+Sexual Battery against EPSTEIN as well.
+3.
+There presently exists between the Plaintiff and EPSTEIN a disagreement
+as to whether the statutory damage floor established in 18 U.S.C. §2255 is recoverable
+for each commission of an enumerated sex offense listed in 18 U.S.C. §2255, or
+whether the statutory damage floor can only be enforced once, regardless of how many
+times a defendant perpetrates an enumerated sex offense against a minor victim.
+4. This disagreement between the parties is properly the subject of
+Defendant's Motion to Dismiss First Amended Complaint For Failure to State a Cause
+of Action, and Motion For More Definite Statement; Motion to Strike, and Supporting
+Memorandum of Law (D.E. 47) which is currently pending before this Court.
+5. In the event that the Court rules that the Plaintiff is entitled to recover the
+statutory damages created by 18 U.S.C. §2255 for each violation', Plaintiff will be
+pursuing only those statutory damages, and will not pursue damages available at
+common law.
+6. Should the Court rule however, that the statutory damage floor can only
+be applied once, Plaintiff will be pursuing any and all damages available to her, whether
+they be pursuant to statute or by common law.
+" The parties also disagree about the amount the statutory damage floor should be for this case. 18
+U.S.C. §2255 was amended in 2006 to increase the floor from $50,000 to $150,000. The parties
+essentially disagree about which version of 18 U.S.C. §2255 should apply in this case.
+
+
+Document 113
+Entered on FLSD Docket 06/05/2009 Page 3 of 4
+Respectfully submitted,
+Is/Jack P. Hill
+NACK SCAROLA
+JACK PA HILL
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach. Florida 33409
+Attorneys for Plaintiff,
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on June 5th, 2009, I electronically filed the foregoing
+document with the Clerk of Court using CM/ECF. I also certify that the foregoing
+document is being served this day on all counsel of record identified on the attached
+counsel list via transmission of Notices of Electronic Filing generated by CM/ECF.
+Is/Jack P. Hill
+JACK SCAROLA
+Florida Bar No. 169440
+JACK P. HILL
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach. Florida 33409
+Attorneys for Plaintiff, L
+
+
+Document 113
+Entered on FLSD Docket 06/05/2009
+
+COUNSEL LIST
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S.
+West Palm Beach, FL 33401
+Bruce E. Reinhart, Esquire
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+Robert Critton, Esquire
+Burman Critton Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33414
+Richard H. Willits, Esquire
+Richard H. Willits, P.A.
+2290 10th Avenue North
+Suite 404
+Lake Worth, FL 33461
+
+
+Case 9:08-CV-80811-KAM Document 35
+Entered on FLSD Docket 01/07/2009 Page 1 of 7
+CASE NO.: 08-CV-80811-MARRAIJOHNSON
+V.
+Plaintiff,
+JEFFREY EPSTEIN and i
+Defendants,
+DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS
+COMPLAINT FOR FAILURE TO STATE A CAUSE OF ACTION
+Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned
+counsel, moves to dismiss Count I of Plaintiffs Complaint for failure to state a cause of
+action. Rule 12(b)(6), Fed.R.Civ.P. (2008). Count I is directed only to Defendant
+who has not yet been served. In support of dismissal, Defendant states:
+Plaintiff,
+attempts to assert a cause of action against EPSTEIN in Count |
+of her Complaint. A review of the inadequate Complaint allegations establishes that
+Plaintiff has failed to state a cause of action under either common or statutory law, and
+thus, Count I against EPSTEIN is required to be dismissed. Rule 12(b)(6), Fla.R.Civ.P.
+Count I alleges in part that while Plaintiff was a minor, beginning when she was 14 -
+6. On numerous occasions .... JEFFREY EPSTEIN intentionally induced
+and/or seduced the Plaintiff into performing various acts of lewd and lascivious
+conduct and/or sexual performances in his presence....
+7. On numerous occasions ..., JEFFREY EPSTEIN performed various acts of
+lewd and lascivious conduct in the presence of the Plaintiff. ...
+
+
+Document 35
+Entered on FLSD Docket 01/07/2009 Page 2 of 7
+Page 2
+8. On numerous occasions .... JEFFREY EPSTEIN touched the Plaintiff's
+breasts and genitilia.
+9. As a result, the Plaintiff suffered mental anguish, mental pain and suffering,
+psychic trauma, and a loss of the capacity for the enjoyment of life.
+(Plaintiff alleges in her Complaint, 12, that she is presently 21 years old. The suit
+was originally filed in Florida state court, Palm Beach County Circuit Court, on February
+21,2008.)
+Count I is lacking in sufficient factual allegations to allege the necessary
+elements to state a cause of action either under common or statutory law. In fact,
+Count I fails to allege any recognizable elements. There is absolutely no reference in
+Count 1 as to whether Plaintiff is attempting to assert some type of common law cause
+of action or as to whether she is relying on some type of Federal or State of Florida
+statute that might give rise to a civil cause of action. In addition, the Complaint
+generally alleges that "on numerous occasions," as opposed to alleging specific dates
+and times. Finally, the Complaint very generally references "lewd and lascivious
+conduct and/or sexual performances" without any underlying factual allegations.
+Accordingly, Count I is subject to dismissal for failure to state a cause of action.
+As established by the Supreme Court in Bell Atlantic Corp. V. Twombly, 127
+S.Ct. 1955(2007), a motion to dismiss should be granted if the plaintiff does not plead
+"enough facts to state a claim to relief that is plausible on its face." Id, at 1974.
+Although the complaint need not provide detailed factual allegations, the basis for relief
+in the complaint must state "more than labels and conclusions, and a formulaic
+
+
+Case 9:08-CV-80811-KAM Document 35 Entered on FLSD Docket 01/07/2009 Page 3 of 7
+• v. Epstein, et al.
+recitation of the elements of a cause of action will not do." Id, at 1965. Further, "factual
+allegations must be enough to raise a right to relief above the speculative level ... on the
+assumption that all the allegations in the complaint are true (even if doubtful in fact)." Id.
+On a motion to dismiss, the well pleaded allegations of plaintiff's complaint are taken as
+true and construed in the light most favorable to the plaintiff. M.T.V. v. DeKalb County
+Sch. Dist., 446 F.3d 1153, 1156 (11th Cir.2006).
+Significantly, the Supreme Court in Bell Atlantic Corp. V. Twombly abrogated the
+often cited observation that "a complaint should not be dismissed for failure to state a
+claim unless it appears beyond doubt that the plaintiff can prove no set of facts in
+support of his claim that would entitle him to relief." Id, (abrogating and quoting Conley
+y. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)). The Supreme
+Court rejected the notion that "a wholly conclusory statement of claim [can] survive a
+motion to dismiss whenever the pleadings le[ave] open the possibility that a plaintiff
+might later establish some 'set of [undisclosed] facts' to support recovery." Id. As
+explained by the Supreme Court in Bell Atlantic Corp., supra at 1664-65:
+While a complaint attacked by a Rule 12(b)(6) motion to dismiss does not
+need detailed factual allegations,
+ibid. Sanjuan V. American Bd. of
+Psychiatry and Neurology, Inc., 40 F.3d 247, 251 (| / 1994), a plaintiff's
+obligation to provide the "grounds" of his "entitle[ment] to relief" requires
+more than labels and conclusions, and a formulaic recitation of the elements
+of a cause of action will not do, see Papasan v. Allain, 478 U.S. 265, 286,
+106 S.Ct. 2932, 92 L.Ed.2d 209 (1986) (on a motion to dismiss, courts "are
+not bound to accept as true a legal conclusion couched as a factual
+allegation"). Factual allegations must be enough to raise a right to relief
+above the speculative level, see 5. Wright & A. Miller, Federal Practice and
+Procedure § 1216, pp. 235-236 (3d ed.2004) (hereinafter Wright & Miller)
+(IT]he pleading must contain something more ... than ... a statement of facts
+that merely creates a suspicion [of] a legally cognizable right of action), on
+the assumption that all the allegations in the complaint are true (even if
+
+
+Document 35 Entered on FLSD Docket 01/07/2009 Page 4 of 7
+Page 4
+doubtful in fact), see, e.g., Swierkiewicz v. Sorema N. A., 534 U.S. 506, 508,
+n. 1, 122 S.Ct. 992, 152 L.Ed.2d 1 (2002); Neitzke v. Williams, 490 U.S. 319,
+327, 109 S.Ct. 1827, 104 L.Ed.2d 338 (1989) (" Rule 12(b)(6) does not
+countenance ... dismissals based on a judge's disbelief of a complaint's
+factual allegations"); Scheuer v. Rhodes, 416 U.S. 232, 236, 94 S.Ct. 1683,
+40 L.Ed.2d 90 (1974) (a well-pleaded complaint may proceed even if it
+appears "that a recovery is very remote and unlikely").
+In discussing Iwombly, the Eleventh Circuit in Watts v. Fla. International Univ.,
+495 F.3d 1289, 1295 (11" Cir. 2007), noted - "The Supreme Court's most recent
+formulation of the pleading specificity standard is that 'stating such a claim requires a
+complaint with enough factual matter (taken as true) to suggest' the required element."
+In order to sufficiently allege the claim, the complaint is required to identify "facts that
+are suggestive enough to render [the element] plausible." Watts, 495 F.3d at 1296
+(quoting Iwombly, 127 S.Ct. at 1965).
+As jurisdiction is based on diversity, it is well settled that this Court is to apply
+Florida substantive law in this action. Erie R.Co. v. Tompkins, 58 S.Ct. 817 (1938).
+On its face, Count I completely fails to allege either the necessary elements of
+any cause of action or the necessary underlying factual allegations. As quoted above,
+Count 1 makes general references to "lewd and lascivious conduct and/or sexual
+performances" without any specific statutory or common law reference.
+Florida Statutes, Chapter 800, Title XLVI - CRIMES, entitled "Lewdness,
+Indecent Exposure," are criminal statutes'. Assuming for the sake of argument that
+Plaintiff means to rely on these statutes, none of the statutes contained in Chapter 800
+create a private right of action. See §§800.02, 800.03, 800.04, Fla. Stat. Rather, the
+' This action began in Florida state court, Palm Beach County 15'" Judicial Circuit Court, and
+was removed to Federal Court pursuant to a Notice of Removal filed by Defendants.
+
+
+Document 35 Entered on FLSD Docket 01/07/2009 Page 5 of 7
+. v. Epstein, et al.
+Page 5
+statutes set forth acts subject to criminal prosecution and the criminal penalties therefor,
+if proven. See generally, Am. Home Assurance Co. v. Plaza Materials Corp., 908 So.2d
+360, 374 (Fla. 2005)("not every statutory violation carries a civil remedy"); and Miami
+Herald Pub. Co. v. Ferre, 636 F.Supp. 970 (S.D. Fla. 1985)(violation of Florida's
+criminal extortion statute does not give rise to civil cause of action for damages).
+According, Count I is required to be dismissed as Chapter 800, which references lewd
+conduct, does not create a private right of action. Mantooth v. Richards, 557 So.2d 646
+(Fla. 4"' DCA 1990), per curiam, (Dismissal of plaintiff's civil complaint affirmed where
+parental kidnapping statutes concerned only criminal violations and did not create a civil
+remedy).
+As well, the Count I allegations make absolutely no reference to any viable
+common law cause of action; Defendant should not be required to guess or speculate
+as to the nature of Plaintiff's cause of action. Even if Defendant were to speculate as to
+the supposed cause of action, these causes of action (common law or otherwise) have
+not been sufficiently alleged. On its face, Count I is completely lacking as to any
+common law elements or the underlying factual allegations to support each element,
+and thus, Count I is required to be dismissed.
+Finally, as noted, there are no allegations as to time regarding the alleged
+"numerous occasions." Pursuant to Rule 9(f), Fed.R.Civ.P., "pleadings of time or place
+is material when testing the sufficiency of a pleading."
+Conclusion
+
+
+Case 9:08-CV-80811-KAM Document 35|
+Entered on FLSD Docket 01/07/2009 Page 6 of 7
+Page 6
+Pursuant to applicable law, Count I of Plaintiff's Complaint is required to be
+dismissed for failure to state a cause of action. On its face, Count I fails to allege a
+cause of action either under statutory or common law against Defendant EPSTEIN.
+Count I fails to plead any requisite elements or the necessary underlying facts.
+WHEREFORE, Defendant requests that Count | of Plaintiff's Complaint be
+dismissed for failure to state a cause of action.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this 7" day of January, 2009:
+Richard Horace Willits, Esq.
+Richard H. Willits, P.A.
+2290 10* Avenue North
+Suite 404
+Lake Worth, FL. 33461
+Counsel for Plaintit
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+jagesq@bellsouth.net
+Counsel for Defendants Jeffrey Epstein
+and
+Jack Scarola, Esq.
+Jack P. Hill, Esq.
+Bruce Reinhart, Esq.
+Search Denney
+Scarola Barnhart & Bruce E. Reinhart, P.A.
+Shipley, P.A.
+250 S. Australian Avenue
+2139 Palm Beach Lakes Boulevard
+Suite 1400
+West Palm Beach, FL 33409
+West Palm beach, FL 33401
+isx@searcylaw.com
+iph@searcylaw.com
+Co-Counsel for Plaintiff
+Respectfully submitted,
+
+
+Document 35
+Entered on FLSD Docket 01/07/2009 Page 7 of 7
+ROBERT D. CRITTON, JR. ESQ.
+wes
+(Counsel for Defendant Jeffrey Epstein)
+
+
+
+LSS, MEDIATION, REF_DISCOV
+U.S. District Court
+CIVIL DOCKET FOR CASE #: 9:08-cv-80811-KAM
+Date Filed: 07/21/2008
+Jury Demand: Plaintiff
+Nature of Suit: 360 P.I.: Other
+Jurisdiction: Diversity
+v. Epstein et al
+Assigned to: Judge Kenneth A. Marra
+Referred to: Magistrate Judge Linnea R. Johnson
+Lead case: 9:08-cv-80119-KAM
+Member case: (View Member Case)
+Case: 9:09-cv-80802-KAM
+Cause: 28:1332 Diversity
+Plaintiff
+represented by Richard Horace Willits
+Richard H Willits PA
+2290 10th Avenue North
+Suite 404
+Lake Worth, FL 33461
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Jack Patrick Hill
+Searcy Denney Scarola Barnhart &
+Shipley
+2139 Palm Beach Lakes Boulevard
+PO Drawer 3626
+West Palm Beach, FL 33402-3626
+Fax: 227-0799
+Email: J
+ATTORNEY TO BE NOTICED
+V.
+Defendant
+Jeffrey Epstein
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p1?985369616841682-L_801_0-1
+represented by Bruce Reinhart
+Bruce E. Reinhart, P.A.
+
+
+
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Guy Alan Lewis
+Lewis Tein
+3059 Grand Avenue
+Suite 340
+Coconut Grove , FL 33133
+Fax: 442-6744
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach , FL 33401-5012
+Fax: 835-8691
+Email: J|
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Michael Ross Tein
+Lewis Tein
+3059 Grand Avenue
+Suite 340
+Coconut Grove , FL 33133
+Fax: 442-6744
+Email: tein@lewistein.com
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Michael James Pike
+Burman Critton Luttier & Colemar
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?985369616841682-L_801_0-1
+
+
+Defendant
+Amicus
+United States of America
+
+West Palm Beach , FL 33401-2918
+Fax: 515-3148
+Email: MPike@bclclaw.com
+ATTORNEY TO BE NOTICED
+Robert Deweese Critton , Jr.
+Burman Critton Luttier & Coleman
+нах:
+Email: !I 11
+ATTORNEY TO BE NOTICED
+represented by Bruce Reinhart
+(See above for address)
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Guy Alan Lewis
+(See above for address)
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Jack Alan Goldberger
+(See above for address)
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Michael Ross Tein
+(See above for address)
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+represented by |
+United States Attorney's Office
+500 East Broward Blyd
+7th Floor
+Ft Lauderdale, FL 33394
+, ext. 3546
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl7985369616841682-L_801_0-1
+
+
+
+Fax: 356-7336
+ERAD ALTORNEY
+ATTORNEY TO BE NOTICED
+Date Filed
+07/21/2008
+#
+1
+clear Docket Text
+NOTICE OF REMOVAL Filing fee $350 Receipt#: 724505, filed by
+Jeffrey Epstein,
+(rb) (Entered: 07/21/2008)
+07/22/2008
+2
+ORDER of Instructions. Signed by Judge William J. Zloch on 7/22/2008.
+(bc) (Entered: 07/22/2008)
+07/25/2008
+MOTION for Hearing Defendants' Request for Oral Argument by Jeffrey
+KB Epstein, d
+(Tein, Michael) (Entered: 07/25/2008)
+07/25/2008
+4
+MOTION for Extension of Time to File Answer Defendants Motion for
+57.9 | Enlargement of Time to Answer or Otherwise Respond to Complaint by
+Jeffrey Epstein,
+- (Tein, Michael) (Entered: 07/25/2008)
+07/25/2008
+5
+NOTICE by Jeffrey Epstein, {
+Notice of Related Actions
+52B (Tein, Michael) (Entered: 07/25/2008)
+07/25/2008
+6
+Sealed Document. (igo) UNSEALED see DE 32 Modified on 1/7/2009
+(ral). (Entered: 07/25/2008)
+07/25/2008
+7
+Sealed Document. (igo) UNSEALED see DE 33 Modified on 1/7/2009
+(ral). (Entered: 07/25/2008)
+07/25/2008
+32
+UNSEALED MOTION to File Under Seal by Jeffrey Epstein,
+1 (previously filed as 6 sealed document) (ral) (Entered:
+01/07/2009)
+07/25/2008
+33
+UNSEALED MOTION to Stay by Jeffrey Epstein,
+(previously filed as 7 sealed document)(ral) (Entered: 01/07/2009)
+07/29/2008
+8
+ORDER denying without prejudice 4 Motion for Extension of Time to
+92.1
+KB
+Respond to Complaint. Signed by Judge William J. Zloch on 1/20/2008.
+(bc) (Entered: 07/29/2008)
+07/30/2008
+2
+MOTION for Extension of Time to File Answer Defendants' Renewed
+Motion for Enlargement of Time to Answer or Otherwise Respond to
+Complaint by Jeffrey Epstein,
+• (Attachments: # 1 Text of
+Proposed Order Proposed Order)(Tein, Michael) (Entered: 07/30/2008)
+| 07/30/2008
+10
+PAPERLESS ORDER denying 3 Motion for Hearing. Signed by Judge
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p1?985369616841682-L_801_0-1
+
+
+
+William J. Zloch on 7/30/2008. (bc) (Entered: 07/30/2008)
+08/06/2008
+11
+PAPERLESS ORDER granting 2 Motion for Extension of Time to
+Respond to Complaint. Signed by Judge William J. Zloch on 8/6/2008.
+(bc) (Entered: 08/06/2008)
+08/07/2008
+12
+Г
+17.7
+MOTION to Reassign Case TO JUDGE KENNETH MARRA by
+KB
+| (Willits, Richard) (Entered: 08/07/2008)
+08/07/2008
+13
+MEMORANDUM in Opposition re 6 Sealed Document, 7 Sealed
+34.1 | Document TO MOTION TO STAY filed by |
+.. (Willits, Richard)
+| (Entered: 08/07/2008)
+08/14/2008
+14
+'APERLESS ORDER denying 12 Motion to Reassign Case. Signed D
+udge William J. Zloch on 8/14/2008. (bc) (Entered: 08/14/2008
+08/18/2008
+15
+MOTION for Extension of Time to File Reply Defendants' Motion for An
+92.0
+Enlargement of Time to File Reply Under Seal Because of Tropical Storm
+KB
+Fay by Jeffrey Epstein,
+1 (Attachments: # 1 Text of Proposed
+Order)(Tein, Michael) (Entered: 08/18/2008)
+08/18/2008
+16
+SCHEDULING REPORT- Rule 26(f). (Tein, Michael) (Entered:
+403 08/18/2008)
+08/20/2008
+17
+Sealed Document. (rb) UNSEALED see DE 34 Modified on 1/7/2009
+(ral). (Entered: 08/20/2008)
+08/20/2008
+UNSEALED REPLY in Support of 33 MOTION to Stay filed by Jeffrey
+Epstein,
+• (previously filed as 17 sealed document) (ral)
+(Entered: 01/07/2009)
+08/25/2008
+18
+PAPERLESS ORDER granting 15 Motion for Extension of Time to
+Respond. Signed by Judge William J. Zloch on 8/25/2008. (bc) (Entered:
+08/25/2008)
+08/27/2008
+19
+• NOTICE by Jeffrey Epstein Notice of Appearance (Pike, Michael)
+1433 (Entered: 08/27/2008)
+08/28/2008
+Clerks Notice of Docket Correction and Instruction to Filer re 19 Notice
+(Other) filed by Jeffrey Epstein. Error - Wrong Event Selected;
+Correction - Redocketed by Clerk as NOTICE of Attorney Appearance.
+Instruction to Filer - In the future, please select the proper event. It is not
+necessary to refile this document. (ail) (Entered: 08/28/2008)
+08/28/2008
+20
+NOTICE of Attorney Appearance by Michael James Pike, Robert
+Deweese Critton, Jr on behalf of Jeffrey Epstein. Redocketed SEE Image
+19 (ail) (Entered: 08/28/2008)
+09/03/2008
+21
+ORDER REASSIGNING CASE. Case reassigned to Judge Kenneth A.
+Marra for all further proceedings. Judge William J. Zloch no longer
+https://ecf.fsd.uscourts.gov/cgi-bin/DktRpt.pl2985369616841682-L_801_0-1
+
+
+
+09/06/2008
+09/06/2008
+09/09/2008
+09/15/2008
+12/01/2008
+12/10/2008
+22
+23
+24
+25
+26
+50.8 assigned to case. Signed by Judge William J. Zloch on 8/29/2008. (tb)
+(Entered: 09/03/2008)
+MOTION to Preserve Evidence by
+.. (Willits, Richard) (Entered:
+09/06/2008)
+MOTION to Expedite certain discovery by
+.. (see image 22) (tb)
+(Entered: 09/09/2008)
+Clerks Notice of Docket Correction and Instruction to Filer re 22
+MOTION to Preserve Evidence filed by L
+.. Error - Motion with
+Multiple Reliefs Filed as One Relief; Correction - Additional reliefs)
+23
+docketed by Clerk. Instructions to filer - In the future, please
+select all applicable reliefs. It is not necessary to refile this document. (tb)
+(Entered: 09/09/2008)
+Г
+ORDER denying in part 22 Motion to Preserve Evidence; granting in part
+60.4 | 23 Motion to Expedite. Signed by Judge Kenneth A. Marra on 9/14/08.
+| (ir) (Entered: 09/15/2008)
+NOTICE of Attorney Appearance by Jack Patrick Hill on behalf of
+32.4
+кв
+I (Hill, Jack) (Entered: 12/01/2008)
+ORDER SETTING TRIAL DATE & Discovery Deadlines; ORDER
+REFERRING CASE to Mediation, ORDER REFERRING CASE to
+Magistrate Judge Linnea R. Johnson for Discovery Proceedings: (Jury
+Trial set for 12/14/2009 in West Palm Beach Division before Judge
+12/17/2008
+27
+12/17/2008
+28
+12/19/2008
+29
+Substantive Pretrial Motions due by 7/30/2009.), **Please see Order for
+further details** Signed by Judge Kenneth A. Marra on 12/10/2008. (gp)
+(Entered: 12/11/2008)
+ORDER DENYING MOTION TO SEAL re 6 Sealed Document, 17
+Sealed Document, 7 Sealed Document. The clerk shall unseal docket
+67.9
+кв
+entries 6, 7 and 17 and make them available for public inspection through
+CM/ECF at the earliest possible time. Signed by Judge Kenneth A. Marra
+on 12/16/2008. (ir) (Entered: 12/17/2008)
+ORDER DENYING MOTION TO STAY 6 Sealed Document, 7 Sealed
+Document. Per this Court's Order DE 27 the Clerk shall unseal and
+terminate these pending documents. Signed by Judge Kenneth A. Marra
+on 12/16/2008. (ir) (Entered: 12/17/2008)
+Defendant's MOTION for Extension of Time to File Response to
+360.! Complaint by Jeffrey Epstein. (Critton, Robert) (Entered: 12/19/2008)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?985369616841682-L_801_
+
+
+12/19/2008
+30
+
+12/30/2008
+01/07/2009
+01/22/2009
+01/23/2009
+02/05/2009
+02/09/2009
+02/09/2009
+02/10/2009
+02/10/2009
+02/10/2009
+02/10/2009
+31
+35
+36
+37
+38
+39
+40
+41
+42
+ENDORSED ORDER granting 29 Motion for Extension of Time to
+Answer Complaint. Jeffrey Epstein response due 1/7/2009. Signed by
+Judge Kenneth A. Marra on 12/19/2008. (ir) (Entered: 12/19/2008)
+Notre: 12/3oy Epstein of Withdrawal as Co-Counsel (Tein, Michael)
+Defendant's MOTION to Dismiss 1 Notice of Removal Complaint for
+0.8
+MB
+Failure to State a Cause of Action by Jeffrey Epstein. Responses due by
+1/26/2009 (Critton, Robert) (Entered: 01/07/2009)
+MOTION for Extension of Time to File Response as to 35 Defendant's
+19.0 MOTION to Dismiss 1 Notice of Removal Complaint for Failure to State
+a Cause of Action by
+.. (Hill, Jack) (Entered: 01/22/2009)
+ENDORSED ORDER granting 36 Motion for Extension of Time to
+Respond re 35 Defendant's MOTION to Dismiss 1 Notice of Removal
+Complaint for Failure to State a Cause of Action. Amended Complaint
+due by 2/9/2009. Signed by Judge Kenneth A. Marra on 1/22/2009. (IT)
+(Entered: 01/23/2009)
+MOTION for Entry of an Amended Scheduling Order re 26 Scheduling
+Order,, Order Referring Case to Mediation,,, Order Referring Case to
+3260
+Magistrate Judge,, byl
+.. (Attachments: # 1 Exhibit Proposed
+Amended Order Setting Trial Date)(Hill, Jack) (Entered: 02/05/2009)
+AMENDED COMPLAINT, filed byl
+..(Hill, Jack) (Entered:
+4.0
+MB
+02/09/2009)
+AMENDED COMPLAINT, filed by
+.. (Hill, Jack) (Entered:
+4.0
+MB
+02/09/2009)
+ORDER denying as moot 35 Motion to Dismiss Complaint. Signed by
+55.6 | Judge Kenneth A. Marra on 2/10/2009. (ir) (Entered: 02/10/2009)
+Plaintiff's MOTION for Extension of Time to File Selection of Mediator
+.. (Hill, Jack) (Entered: 02/10/2009)
+ORDER granting 38 Motion for entry of an Amended Scheduling Order.
+182.4
+Signed by Judge Kenneth A. Marra on 2/10/2009. (ir) (Entered:
+KB
+02/10/2009)
+Reset Scheduling Order Deadlines: Calendar Call set for 2/19/2010 10:00
+AM in West Palm Beach Division before Judge Kenneth A. Marra. Jury
+Trial set for 2/22/2010 09:00 AM in West Palm Beach Division before
+Judge Kenneth A. Marra. Amended Pleadings due by 3/16/2009.
+Discovery due by 8/28/2009. Expert Discovery due by 6/29/2009. Joinder
+of Parties due by 3/16/2009. Dispositive Motions due by 10/15/2009. (ir)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|7985369616841682-L_801_0-1
+
+
+
+02/11/2009
+02/17/2009
+02/17/2009
+03/12/2009
+03/12/2009
+03/16/2009
+03/19/2009
+03/24/2009
+03/25/2009
+03/26/2009
+04/02/2009
+44
+45
+47
+48
+(Entered: 02/10/2009)
+ENDORSED ORDER denying as moot 42 Motion for Extension of
+Deadline for parties to select mediator. Amended scheduling order entered
+on 2/10/09. Signed by Judge Kenneth A. Marra on 2/11/2009. (ir)
+(Entered: 02/11/2009)
+Defendant's MOTION for Extension of Time to File Response as to 40
+420.3| Amended Complaint with proposed Agred Order by Jeffrey Epstein.
+(Critton, Robert) (Entered: 02/17/2009)
+ORDER granting 45 Motion for Extension of Time to Answer First
+31.4 | Amended Complaint. Jeffrey Epstein response due 3/12/2009. Signed by
+Judge Kenneth A. Marra on 2/17/2009. (ir) (Entered: 02/17/2009)
+Defendant's MOTION to Dismiss 40 Amended Complaint (First) by
+2.8
+| Jeffrey Epstein. Responses due by 3/30/2009 (Pike, Michael) (Entered:
+MB
+03/12/2009)
+NOTICE of Cancelling Deposition (ail) (Entered: 03/13/2009)
+49
+50
+51
+52
+53
+54
+Defendant's MOTION for Extension of Time to File Motion to Compel
+483.1 Answers to Interrogs and Production of Documents w/ Proposed Order by
+Jeffrey Epstein. (Critton, Robert) (Entered: 03/16/2009)
+ORDER Granting 49 Motion for Extension of Time to File Motions to
+Compel Answers to Interrogatories and Production of Documents directec
+40.1 | to Plaintiff. Defendant shall file Motions on or before 4/6/09. Signed by
+Magistrate Judge Linnea R. Johnson on 3/19/2009. (sa) (Entered:
+03/19/2009)
+Defendant's MOTION to Stay re 40 Amended Complaint and or Continue
+2.9
+MB
+0.9
+MB
+2.6
+MB
+03/24/2009)
+Plaintiff's MOTION for Extension of Time to File Response as to 47
+Defendant's MOTION to Dismiss 40 Amended Complaint (First) by
+|| |L.. (Hill, Jack) (Entered: 03/25/2009)
+ENDORSED ORDER granting 52 Motion for Extension of Time to
+Respond re 47 Defendant's MOTION to Dismiss 40 Amended Complaint
+(First). Responses due by 4/13/2009. Signed by Judge Kenneth A. Marra
+on 3/26/2009. (ir) (Entered: 03/26/2009)
+Defendant's MOTION to Compel Response to Ist RIP and Ist Interrogs
+by Jeffrey Epstein. Responses due by 4/20/2009 (Attachments: # 1 Exhibit
+A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Critton, Robert) (Entered:
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?985369616841682-L_801_0-1
+
+
+
+04/09/2009
+04/10/2009
+04/13/2009
+04/13/2009
+04/14/2009
+04/20/2009
+04/20/2009
+04/22/2009
+04/24/2009
+55
+56
+57
+58
+59
+60
+61
+62
+63
+64
+04/02/2009)
+| Plaintiff's MOTION for Extension of Time to File Response as to 51
+4Kl® Defendant's MOTION to Stay re 40 Amended Complaint and or Continue
+Action by ! !!.. (Hill, Jack) (Entered: 04/09/2009)
+ENDORSED ORDER granting 55 Motion for Extension of Time to
+Respond re 51 Defendant's MOTION to Stay re 40 Amended Complaint
+and or Continue Action. Responses due by 4/24/2009. Signed by Judge
+Kenneth A. Marra on 4/10/2009. (ir) (Entered: 04/10/2009)
+NOTICE of Mediator Selection: Mark Buckstein selected.(Hill, Jack)
+16 (Entered: 04/13/2009)
+RESPONSE to Motion re 47 Defendant's MOTION to Dismiss 40
+Amended Complaint (First) filed by
+.. Replies due by 4/23/2009.
+(Hill, Jack) (Entered: 04/13/2009)
+NOTICE by
+of Filing Correction to Page Four of Plaintiff's
+Memorandum of Law in Response to Defendant, Jeffrey Epstein's Motion
+to Dismiss First Amended Complaint for Failure to State a Cause o
+06.8 Action, and Motion for More Definite Statement; Motion to Strike, ano
+Supporting Memorandum of Law filed on April 13, 2009 (Hill, Jack)
+(Entered: 04/14/2009)
+Defendant's MOTION for Extension of Time to File Reply as to 58
+158.6 Response to Motion by Jeffrey Epstein. (Pike, Michael) (Entered:
+04/17/2009)
+ENDORSED ORDER granting 60 Motion for Extension of Time to Reply
+re 47 Defendant's MOTION to Dismiss 40 Amended Complaint (First).
+Replies due by 5/8/2009. Signed by Judge Kenneth A. Marra on
+4/20/2009. (ir) (Entered: 04/20/2009)
+RESPONSE in Opposition re 54 Defendant's MOTION to Compel
+1.2
+MB
+Response to Ist RTP and Ist Interrogs filed by
+.. (Hill, Jack)
+(Entered: 04/20/2009)
+MOTION for Leave to Fild
+Motion For Leave to
+File Brief as Amicus Curiae in Support of Plaintiff's Response in
+Opposition to Defendant Jeffrey Epstein's Motion to Dismiss and
+337.0
+KB
+Certification of Having Conferred Pursuant to S.D. Fla. L.R. 7.1.A.3 by
+(Attachments: # 1 Text of Proposed Order) (Josefsberg,
+Robert) (Entered: 04/22/2009)
+RESPONSE in Opposition re 51 Defendant's MOTION to Stay re 40
+Amended Complaint and or Continue Action filed by
+2.5
+MB
+(Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Hill, Jack) (Entered:
+04/24/2009)
+htts://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl7985369616841682-L_801_0-1
+
+
+| 04/27/2009
+65
+
+04/27/2009
+04/28/2009
+04/29/2009
+04/29/2009
+04/30/2009
+66
+68
+67
+69
+70
+71
+72
+73
+74
+| Defendant's MOTION for Leave to File Excess Pages in his Reply to
+i Plainti's Memo in Response to Motion to Dismiss by Jeffrey Epstein.
+| (Pike. Michael) (Entered: 04/27/2009)
+ENDORSED ORDER granting 65 Motion for Leave to File Excess Pages.
+Reply may exceed 10 pages. Signed by Judge Kenneth A. Marra on
+4/27/2009. (ir) (Entered: 04/27/2009)
+ORDER TO SHOW CAUSE why cases should not be consolidated for
+| discovery purposes Show Cause Response due by 5/5/2009.. Signed by
+Judge Kenneth A. Marra on 4/28/2009. (cqs) (Entered: 04/29/2009)
+Defendant's MOTION to Compel and/or Identify
+in the Style of
+This Case and Motion to Identify !
+in Third Party Subpoenas for
+Purposes of Discovery, or Alternatively, Motion to Dismiss Sua Sponte ,
+1.2
+MB
+with Incorporated Memorandum of Law by Jeffrey Epstein. Responses
+| due by 5/18/2009 (Attachments: # 1 Motion to Compel and or Identity, #
+2 Motion to Compel and or Identify) (Pike, Michael) (Entered:
+04/29/2009)
+Defendant's MOTION for Extension of Time to File Reply to Plaintiff's
+15g Stay and or Cote Aton for Time Certain Based on Paraled Chil and
+Criminal Proceedings by Jeffrey Epstein. (Pike, Michael) (Entered:
+04/29/2009)
+REPLY to Response to Motion re 54 Defendant's MOTION to Compel
+Response to 1st RTP and Ist Interrogs, and to Overrule Objections, ano
+for an Award of Defendant's Reasonable Expenses filed by Jetfrey
+Epstein. (Attachments: # 1 Exhibit A to Defendant Epstein's Reply to
+Response in Opposition to Motion to Compel, # 2 Exhibit A-1 to Det.
+Epstein's Reply)(Pike, Michael) (Entered: 04/30/2009)
+ENDORSED ORDER granting 69 Motion for Extension of Time to Reply
+re 51 Defendant's MOTION to Stay re 40 Amended Complaint and or
+Continue Action. Replies due by 5/11/2009. Signed by Judge Kenneth A.
+Marra on 5/4/2009. (ir) (Entered: 05/04/2009)
+RESPONSE TO ORDER TO SHOW CAUSE by
+• (Hill, Jack)
+6S (Entered: 05/04/2009)
+• MEMORANDUM in Opposition re 68 Order to Show Cause by Jeffrey
+278,6 Epstein. (Pike, Michael) (Entered: 05/04/2009)
+MOTION for clarification 68 Order to Show Cause by Jeffrey Epstein.
+Responses due by 5/21/2009. See image DE 73 (k) Modified link on
+5/5/2009 (Ik). (Entered: 05/05/2009)
+Clerks Notice of Docket Correction and Instruction to Filer re 73.
+|05/05/2009
+75
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl7985369616841682-L_801_0-1
+
+
+
+05/08/2009
+05/08/2009
+05/11/2009
+05/13/2009
+76
+77
+79
+80
+Memorandum in Opposition filed by Jeffrey Epstein. Error - Two or
+More Document Events Filed as One; Correction - Additional event(S)
+74 MOTION FOR CLARIFICATION docketed by Clerk. Instruction to
+Filer - In the future, please select all applicable events, UNDER
+MOTIONS. It is not necessary to refile this document. (IK) (Entered:
+05/05/2009)
+Defendant's MOTION for Extension of Time to File Reply as to 64
+145.3 | Response in Opposition to Motion by Jeffrey Epstein. (Critton, Robert)
+KB
+(Entered: 05/05/2009)
+ENDORSED ORDER granting 76 Motion for Extension of Time to Reply
+re 51 Defendant's MOTION to Stay re 40 Amended Complaint and or
+Continue Action. Replies due by 5/15/2009. Signed by Judge Kenneth A.
+Marra on 5/5/2009. (ir) (Entered: 05/06/2009)
+REPLY to Response to Motion re 47 Defendant's MOTION to Dismiss 40
+Amended Complaint (First) filed by Jeffrey Epstein. (Critton, Robert)
+(Entered: 05/08/2009)
+Defendant's MOTION for Extension of Time to File Response as to 63
+Motion For Leave to
+sen opposita mies date he pray anon 1 Repons and
+Certification of Having Conferre by Jeffrey Epstein. (Pike, Michael)
+(Entered: 05/08/2009)
+ENDORSED ORDER granting 79 Motion for Extension of Time to
+Respond re 63 MOTION for Leave to File
+Motion
+For Leave to File Brief as Amicus Curiae in support of Plaintyr s
+Response in Opposition to Defendant Jeffrey Epstein's Motion to Dismiss
+and Certification of Having Conferre.. Responses due by 5/15/2009.
+Signed by Judge Kenneth A. Marra on 5/11/2009. (ir) (Entered:
+81
+82
+83
+RESPONSE/REPLY to 64 Response in Opposition to Motion to Stay
+383.3
+and/or Continue Action by Jeffrey Epstein. (Pike, Michael) (Entered:
+05/13/2009)
+Cases associated. (dg) (Entered: 05/14/2009)
+ORDER CONSOLIDATING CASES. Hereinafter all motions and other
+court filings that relate to discovery and all procedural motions that relate
+1065 to multiple cases shall be styled with all of the case names and numbers
+and shall be filed in Case No. 08-80119-CIV-MARRA. Signed by Judge
+Kenneth A. Marra on 5/14/2009. Associated Cases: 9:08-cv-80119-KAM
+et al. (ir) (Entered: 05/14/2009)
+ORDER REQUESTING UNITED STATES PROVIDE POSITION TO
+httms://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p1?985369616841682-L_801_0-1
+
+
+
+05/15/2009
+05/15/2009
+05/18/2009
+05/18/2009
+05/19/2009
+05/19/2009
+84
+85
+86
+87
+88
+89
+90
+91
+92
+MOTION TO STAY. Signed by Judge Kenneth A. Marra on 5/14/2009.
+1.3
+(Attachments: # 1 Appendix Motion to Stay DE 51) Associated Cases:
+MB
+9:08-cv-80119-KAM et al. (ir) (Entered: 05/14/2009)
+ORDER denying as moot 74 Motion for Clarification. See Order
+consolidating cases.. Signed by Judge Kenneth A. Marra on 5/14/2009.
+(Ic3) (Entered: 05/14/2009)
+ORDER terminating 51 Motion to Stay; terminating 67 Motion to
+Compel. See Order consolidating cases. See procedural motions pending:
+DE 65 and DE 91 in 08-80119.. Signed by Judge Kenneth A. Marra on
+5/14/2009. (lc3) (Entered: 05/14/2009)
+Plaintiffs MOTION for Extension of Time to File Response to
+Defendant's Motion to Identijy L
+in Third-Party Subpoenas for
+Purposes of Discovery, or Alternatively, Motion to Dismiss Sua Sponte,
+With Incorporated Memorandum of Law by
+.. Associated Cases:
+9:08-cv-80119-KAM, 9:08-cv-80811-KAM(Hill, Jack) (Entered:
+05/15/2009)
+RESPONSE in Opposition re 63 MOTION for Leave to Filel
+Motion For Leave to File Brief as Amicus Curiae in Support of
+(Pike, Michael) (Entered: 05/15/2009)
+ORDER terminating 86 Motion for Extension of Time to Respond. Filing
+motion in 08-80119 is sufficient, as the underlying motion to compel
+identity is pending in 08-80119 for all the cases.. Signed by Judge
+Kenneth A. Marra on 5/18/2009. (lc3) (Entered: 05/18/2009)
+| Plaintiff's MOTION to Strike 78 Reply to Response to Motion to Dismiss
+0.6
+MB
+First Amended Complaint by
+.. Responses due by 6/5/2009 (Hill,
+Jack) (Entered: 05/18/2009)
+Defendant's MOTION to Strike Cases from Current Trial Docket by
+0.8
+Jeffrey Epstein. Responses due by 6/8/2009 (Attachments: # 1 Exhibit A)
+MB
+Associated Cases: 9:08-cv-80119-KAM et al.(Pike, Michael) (Entered:
+05/19/2009)
+MOTION for Leave to Withdraw as Co-Counsel by Jeffrey Epstein.
+| (Attachments: # 1 Text of Proposed Order)(Tein, Michael) Event
+Modified on 5/20/2009 (ail). (Entered: 05/19/2009)
+ORDER terminating (93) Motion to Strike ; terminating (94) Motion in
+case 9:08-cv-80232-KAM; terminating (110) Motion to Strike ;
+erminating (111) Motion in case 9:08-cv-80380-KAM; terminating (9:
+lotion to Strike : terminating (96) Motion in case 9:08-cv-80381-KAN
+terminating (90) Motion to Strike ; terminating (91) Motion in case 9:08-
+httms://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?985369616841682-L_801_0-1
+
+
+
+05/21/2009
+05/21/2009
+94
+95
+96
+97
+98
+99
+cv-80811-KAM; terminating (62) Motion to Strike in case 9:08-cv-80893-
+KAM; terminating (62) Motion to Strike in case 9:08-cv-80993-KAM;
+terminating (50) Motion to Strike in case 9:08-Cv-80994-KAM. Signed by
+Judge Kenneth A. Marra on 5/20/2009. (Ic3) (Entered: 05/20/2009)
+of Filing Withdrawal of Previously Raised
+Objections to Defendant, Jeffrey Epstein's Motion to Compel And/Or
+in the Style of This Case and Motion to Identify (
+in
+363.1 Third-Party Subpoenas for Purposes of Discovery, Or, Alternatively,
+Motion to Dismiss Sua Sponte, With Inorporated Memorandum of Law
+Associated Cases: 9:08-cv-80119-KAM et al. (Hill, Jack) (Entered:
+05/20/2009)
+RESPONSE in Opposition re 89 Plaintiff's MOTION to Strike 18 Reply to
+191 Response to Motion to Dismiss First Amended Complaint for Failure to
+State a Cause of Action filed by Jeffrey Epstein. (Critton, Robert)
+(Entered: 05/20/2009)
+Clerks Notice of Docket Correction and Instruction to Filer re 91
+MOTION Motion for Leave to Withdraw as Co-Counsel filed by Jeffrey
+Epstein. The Filer selected the wrong motion relief when docketing the
+Motion. The correction was made by the Clerk. It is not necessary to refile
+this document but future motions filed must include all applicable relief
+events. (ail) (Entered: 05/20/2009)
+ORDER STRIKING in all Epstein cases EXCEPT case no. 08-80119:
+of Filing Withdrawal of Previously Raised Objections
+to Epstein's Motion to Compel and/or Identify. This Notice should only be
+filed in 08-80119, not in all of the Epstein cases.. Signed by Juage
+Kenneth A. Marra on 5/20/2009. Associated Cases: 9:08-cv-80119-KAM
+et al. (Ic3) (Entered: 05/20/2009)
+RESPONSE/REPLY
+Reply to Defendant's Response
+in Opposition to
+Motion for Leave to File Brief as
+361.9
+KB
+Amicus Curiae in Support of Plaintiff's Reponse In Onnosition to
+I Defendant Jeffrey Epstein's Motion to Dismiss by
+(Ezell, Katherine) (Entered: 05/21/2009)
+RESPONSE/REPLY to 89 Plaintiffs MOTION to Strike 78 Reply to
+Response to Motion to Dismiss First Amended Complaint Plaintiffs
+Response in Support of Plaintifi
+Is Motion to File Surreply to Defendant's Reply to Plaintyj's
+2632
+Memorandum in Response to Defendant's Motion to Dismiss First
+Amended Complaint For Failure to State a Cause of Action and Motion
+for More Definite Statement byl
+(Ezell, Katherine)
+(Entered: 05/21/2009)
+NOTICE by Jane Doe re (111 in 9:08-cv-80119-KAM) Plaintiff's
+httns://ecf.flsd.uscourts.eov/czi-bin/DktRpt.pl?985369616841682-L_801_0-1
+
+
+
+100
+101
+102
+103
+MOTION for Extension of Time to File Response as to (91 in 9:08-cv-
+80119-KAM) Defendant's MOTION to Compel Identity of Doe in Style of
+Case and Third-Party Subpoenas (replaces Docket entry 90) Plaintiff's
+MOTION for Extension of Time to File Response as to (91 in 9:08-cv-
+80119-KAM) Defendant's MOTION to Compel Identity of Doe in Style of
+Case and Third-Party Subpoenas (replaces Docket entry 90)
+(Attachments: # 1 Text of Proposed Order)Associated Cases: 9:08-CV-
+80119-KAM et al.(Horowitz, Adam) (Entered: 05/27/2009)
+ORDER STRIKING Notice by Jane Doe in all Epstein cases EXCEPT in
+case 08-80119. This Notice should only be filed in 08-80119, not in all of
+the Epstein cases... Signed by Judge Kenneth A. Marra on 5/28/2009
+Associated Cases: 9:08-cv-80119-KAM et al. (Ic3) (Entered: 05/28/2009)
+ORDER denying 63 Motion for Leave to File Brief; denying 89 Motion to
+Strike. Signed by Judge Kenneth A. Marra on 5/28/2009. (ir) (Entered:
+05/28/2009)
+NOTICE of Attorney Appearance by
+on behalf of
+United States of America Associated Cases: 9:08-cv-80119-KAM et al.
+) (Entered: 05/29/2009)
+RESPONSE to Motion re (72 in 9:08-cv-80380-KAM) Defendant's
+MOTION to Stay re (62) Amended Complaint, (57 in 9:08-cv-80232-
+KAM) Defendant's MOTION to Stay re (50) Amended Complaint, (24 in
+9:08-cv-80893-KAM) Defendant's MOTION to Stay re (1) Complaint, (23
+in 9:08-cv-80994-KAM) Defendant's MOTION to Stay re (18) Amended
+Complaint, (22 in 9:08-cv-80993-KAM) Defendant's MOTION to Stay re
+104
+105
+KAM) Defendant's MOTION to Stay re (60) Amended Complaint, (51 in
+9:08-cv-80811-KAM) Defendant's MOTION to Stay re (40) Amended
+Complaint and or Continue Action Filed Pursuant to Court's Order
+Requesting Government's Position filed by United States of America.
+Replies due by 6/8/2009. Associated Cases: 9:08-cv-80119-KAM et al.
+1) (Entered: 05/29/2009)
+Defendant's MOTION to Strike 98 Response/Reply (Other),
+223.6 | Response/Reply (Other), Response/Reply (Other) by Jeffrey Epstein.
+KB | Responses due by 6/15/2009 (Pike, Michael) (Entered: 05/29/2009)
+RESPONSE in Opposition re (90 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Compel Identify Doe in Style of Case and in Third-Party
+Subpoenas, (91 in 9:08-cv-80119-KAM) Defendant's MOTION to
+Compel Identity of Doe in Style of Case and Third-Party Subpoenas
+(replaces Docket entry 90) filed by
+Associated Cases: 9:08-cv-80119-KAM et al.(Ezell, Katherine) (Entered:
+05/29/2009)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|?985369616841682-L_801_0-1
+
+
+/05/29/2009|106
+
+107
+108
+06/01/2009
+109
+06/01/2009
+|110
+111
+112
+ORDER STRIKING (124 in 9:08-cv-80119-KAM, 105 in 9:08-cv-80811-
+KAM, 74 in 9:08-cv-80993-KAM, 72 in 9:08-cv-80893-KAM, 106 in
+9:08-cv-80232-KAM, 123 in 9:08-cv-80380-KAM, 35 in 9:09-cv-80591-
+KAM, 25 in 9:09-cv-80469-KAM, 60 in 9:08-cv-80994-KAM, 22 in 9:09-
+cv-80656-KAM, 107 in 9:08-cv-80381-KAM) Response in Opposition to
+DO NOT FILE IN
+EVERY EPSTEIN CASE. SEE ORDER CONSOLIDATING CASES..
+Signed by Judge Kenneth A. Marra on 5/29/2009. Associated Cases: 9:08-
+cV-80119-KAM et al. (lc3) (Entered: 05/29/2009)
+MOTION for Leave to File UNDER SEAL RESPONSE IN OPPOSITION
+TO DEFENDANTS MOTION TO STAY OR, IN THE ALTERNATIVE, TO
+A UNSEAL THE NONPROSECUTION AGREEMENT by a
+Associated Cases: 9:08-cv-80119-KAM et al.(Ezell,
+Katherine) (Entered: 05/29/2009)
+MOTION for Hearing MOTION TO RESCHEDULE HEARING by
+Associated Cases: 9:08-cv-80119-KAM
+et al. (Josefsberg, Robert) (Entered: 05/29/2009)
+ORDER STRIKING (28 in 9:09-cv-80469-KAM, 126 in 9:08-Cv-80380-
+KAM, 109 in 9:08-cv-80232-KAM, 25 in 9:09-cv-80656-KAM, 77 in
+9:08-cv-80993-KAM, 38 in 9:09-cv-80591-KAM, 110 in 9:08-cv-80381-
+KAM, 63 in 9:08-cv-80994-KAM, 75 in 9:08-cv-80893-KAM, 108 in
+9:08-cv-80811-KAM) Motion to Continue Hearing filed by
+76 in 9:08-cv-80993-KAM, 109 in 9:08-cv-
+80381-KAM, 108 in 9:08-cv-80232-KAM, 62 in 9:08-cv-80994-KAM,
+125 in 9:08-cv-80380-KAM, 74 in 9:08-cv-80893-KAM, 24 in 9:09-cv-
+80656-KAM, 37 in 9:09-cv-80591-KAM, 107 in 9:08-Cv-80811-KAM. 27
+in 2:09-cv-80469-KAM Motion for Leave to File, filed by
+THESE DOCUMENTS SHOULD BE FILED
+ONLY IN 08-80119. SEE CASE MANAGEMENT ORDER.. Signed by
+Judge Kenneth A. Marra on 6/1/2009. (Ic3) (Entered: 06/01/2009)
+ENDORSED ORDER denying as moot 104 Motion to Strike. See DE 101
+denying motion to strike or to file sur-reply. Signed by Judge Kenneth A.
+Marra on 5/29/2009. (ir) (Entered: 06/01/2009)
+REPLY to Response to Motion re (113 in 9:08-cv-80119-KAM) Plaintiff's
+MOTION Plaintiffs
+Motion for No-
+Contact Order Plaintiff
+Reply
+to Defendant Jeffrey Epstein's Response to Plaintiffs
+Motion for a No-Contact Order filed by Janu bo
+Associated Cases: 9:08-cv-80119-KAM et al.
+(Ezell, Katherine) (Entered: 06/04/2009)
+ORDER STRIKING (112 in 9:08-cv-80381-KAM, 111 in 9:08-cv-80232-
+KAM, 136 in 9:08-cv-80119-KAM, 111 in 9:08-cv-80811-KAM, 128 in
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?985369616841682-L_801_0-1
+
+
+
+06/05/2009
+113
+06/05/2009
+114
+06/08/2009
+115
+06/08/2009
+116
+|9:08-cv-80380-KAM, 65 in 9:08-cv-80994-KAM, 79 in 9:08-cv-80893-
+KAM, 42 in 9:09-cv-80591-KAM, 27 in 9:09-cv-80656-KAM, 32 in 9:09.
+cv-80469-KAM, 79 in 9:08-cv-80993-KAM) Reply to Response to
+Motion, filed byL
+Document stricken
+for failure to follow Court's orders. DO NOT FILE A DOCUMENT IN
+EVERY EPSTEIN CASE if it is to be filed only in 08-80119. See Case
+Management Order and contact CM/ECF Support for assistance in proper
+filing... Signed by Judge Kenneth A. Marra on 6/4/2009. Associated Cases:
+9:08-cv-80119-KAM et al. (Ic3) (Entered: 06/04/2009)
+NOTICE by
+,. of Filing Conditional Notice of Intent to Exclusively
+38 Rentered: 0605/2 Damages Provided by 18 U.S.C. 25 (Hill, Jack)
+Plaintiff's MOTION for Protective Order Regarding Treatment Records
+From Parent-Child Center Inc. and Dr. Serge Thys and Incorporated
+Memorandum of Law by
+.. (Hill, Jack) (Entered: 06/05/2009)
+RESPONSE to Motion re (91 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Compel Identity of Doe in Style of Case and Third-Party
+Subpoenas (replaces Docket entry 90) filed by Jane Doe. Replies due by
+6/18/2009. (Attachments: # 1 Exhibit A, # 2 Exhibit B)Associated Cases:
+9:08-cv-80119-KAM et al.(Horowitz, Adam) (Entered: 06/08/2009)
+NOTICE by Jane Doe re (113 in 9:08-cv-80119-KAM) Plaintiff's
+MOTION Plaintiffs
+Motion for No-
+106.1
+KB
+Contact Order -Plaintiffs
+Notice of Joinder Associated
+Cases: 9:08-cv-80119-KAM et al.(Horowitz, Adam) (Entered:
+06/08/2009)
+or
+Total filesize of selected documents (MB): |
+Maximum filesize allowed (MB): 10
+Download Selected
+PACER
+Login:
+Description:
+Billable
+Pages:
+PACER Service Center
+Transaction Receipt
+06/10/2009 13:34:47
+du4480
+Client Code:
+Docket
+Report
+10
+Search
+Criteria:
+Cost:
+19:08-cv-80811-
+KAM
+10.80
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|?985369616841682-L_801_0-1
+
+
+Entered on FLSD Docket 03/12/2009 Page 1 of 21
+CASE NO.: 08-CV-80811-MARRA/JOHNSON
+LA.,
+Plaintiff,
+V.
+Defendants,
+DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS FIRST
+AMENDED COMPLAINT FOR FAILURE TO STATE A CAUSE OF ACTION,
+AND MOTION FOR MORE DEFINITE STATEMENT; MOTION TO STRIKE,
+AND SUPPORTING MEMORANDUM OF LAW
+Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned
+counsel, moves to dismiss Count I through XXXI of Plaintiff's First Amended Complaint
+for failure to state a cause of action, and for more definite statement, or to strike, as
+specified herein. Rule 12(b)(6), (e) and (f), Fed.R.Civ.P. (2008); Local Gen. Rule 7.1
+(S.D. Fla. 2008). In support of dismissal, Defendant states:
+The First Amended Complaint attempts to allege 32 counts. Counts I through
+XXX are purportedly brought pursuant to 18 U.S.C. §2255 - Civil Remedies for
+Personal Injuries; Count XXXI is entitled "Sexual Battery," and Count XXXII is entitled
+"Conspiracy to Commit Tortious Assault only against Defendant,
+" Under
+the heading
+"Factual Allegations" of the First Amended Complaint, Plaintiff also
+references numerous federal and state criminal statutes, but fails to allege whether or
+not she is attempting to assert claims based on these statutes. (115, 1st Am. Comp.).
+
+
+Case 9:08-CV-80811-KAM Document 47
+Entered on FLSD Docket 03/12/2009 Page 3 of 21
+assumption that all the allegations in the complaint are true (even if doubtful in fact)." Id.
+On a motion to dismiss, the well pleaded allegations of plaintiff's complaint are taken as
+true and construed in the light most favorable to the plaintiff. M.T.V. v. DeKalb County
+Sch. Dist.., 446 F.3d 1153, 1156 (11th Cir.2006).
+Significantly, the Supreme Court in Bell Atlantic Corp. V. Twombly abrogated the
+often cited observation that "a complaint should not be dismissed for failure to state a
+claim unless it appears beyond doubt that the plaintiff can prove no set of facts in
+support of his claim that would entitle him to relief." Id, (abrogating and quoting Conley
+y. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)). The Supreme
+Court rejected the notion that "a wholly conclusory statement of claim [can] survive a
+motion to dismiss whenever the pleadings le[ave] open the possibility that a plaintiff
+might later establish some 'set of [undisclosed] facts' to support recovery." Id. As
+explained by the Supreme Court in Bell Atlantic Corp., supra at 1664-65:
+While a complaint attacked by a Rule 12(b)(6) motion to dismiss does not
+need detailed factual allegations, ibid.; Sanjuan v. American Bd. of
+Psychiatry and Neurology, Inc., 40 F.3d 247, 251 (C.A.7 1994), a plaintiff's
+obligation to provide the "grounds" of his "entitle[ment] to relief" requires
+more than labels and conclusions, and a formulaic recitation of the elements
+of a cause of action will not do, see Papasan v. Allain, 478 U.S. 265, 286,
+106 S.Ct. 2932, 92 L.Ed.2d 209 (1986) (on a motion to dismiss, courts "are
+not bound to accept as true a legal conclusion couched as a factual
+allegation). Factual allegations must be enough to raise a right to relief
+above the speculative level, see 5 C. Wright & A. Miller, Federal Practice and
+Procedure § 1216, pp. 235-236 (3d ed.2004) (hereinafter Wright & Miller)
+n. 1, 122 S.Ct. 992, 152 L.Ed.2d 1 (2002); Neitzke v. Williams, 490 U.S. 319,
+327, 109 S.Ct. 1827, 104 L.Ed.2d 338 (1989) (" Rule 12(b)(6) does not
+countenance ... dismissals based on a judge's disbelief of a complaint's
+
+
+Entered on FLSD Docket 03/12/2009 Page 5 of 21
+A. v. Epstein, et al.
+Page 5
+Contrary to Plaintiff's attempted assertion of 30 separate counts pursuant to 18
+U.S.C.A. §2255 - Civil Remedy for Personal Injuries, this statute creates a single federal
+cause of action or "civil remedy" for a minor victim of sexual, abuse, molestation and
+exploitation.
+Under the plain meaning of the statutory text, §2255 does not create
+separate causes of action on behalf of a minor against a defendant on a "per violation"
+basis. No where in the statutory text is there any reference to the civil remedy afforded
+by this statute as being on a "per violation" basis. 18 U.S.C. 2255(a) creates a civil
+remedy for "a minor who is a victim of a violation of section 2241(c), 2242, 2243, 2251,
+2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suffers personal
+injury as a result of such violation ...." See Smith v. Husband, 428 F.Supp.2d 432
+(E.D. Va. 2006); Smith v. Husband, 376 F.Supp.2d 603 (E.D. Va. 2006); Doe v.
+Liberatore, 478 F.Supp.2d 742, 754 (M.D. Pa. 2007); and the recent cases in front of
+this court on Defendant's Motions to Dismiss and For More Definite Statement - Doe
+No. 2 v. Epstein, 2009 WL 383332 (S.D. Fla. Feb. 12, 2009); Doe No. 3 v. Epstein,
+2009 WL 383330 (S.D. Fla. Feb. 12, 2009); Doe No. 4 v. Epstein, 2009 WL 383286
+(S.D. Fla. Feb. 12, 2009); and Doe No. 5 v. Epstein, 2009 WL 383383 (S.D. Fla. Feb.
+12, 2009).
+There is no reported case supporting Plaintiff's tortured and nonsensical
+interpretation of §2255. In all of these cases (cited above), each of the Plaintiffs brought
+a single count or cause of action attempting to allege numerous violations of the
+"predicate acts" specifically identified in §2255. "18 U.S.C. §2255 gives victims of
+sexual conduct who are minors a private right of action." Martinez v. White, 492
+
+
+Entered on FLSD Docket 03/12/2009 Page 7 of 21
+V. Husband, 376 F.Supp.2d at 610 ("When interpreting a statute, [a court's] inquiry
+begins with the text."). "The Court must first look to the plain meaning of the words, and
+scrutinize the statute's language, structure, and purpose." Id. In addition, in construing
+a statute, a court is to presume that the legislature said what it means and means what
+it said, and not add language or give some absurd or strained interpretation. As stated
+in CBS, Inc., supra at 1228 - "Those who ask courts to give effect to perceived
+legislative intent by interpreting statutory language contrary to its plain and
+unambiguous meaning are in effect asking courts to alter that language, and "[clourts
+have no authority to alter statutory language.... We cannot add to the terms of [the]
+provision what Congress left out.' Merritt, 120 F.3d at 1187." See also Dodd v. U.S.,
+125 S.Ct. 2478 (2005); 73 Am.Jur.2d Statutes §124.
+Title 18 of the U.S.C. is entitled "Crimes and Criminal Procedure." §2255 is
+contained in "Part I. Crimes, Chap. 110. Sexual Exploitation and Other Abuse of
+Children." 18 U.S.C. §2255 (2003), is entitled Civil remedy for personal injuries, and
+provides:
+(a) Any minor who is a victim of a violation of section 2241(c), 2242, 2243, 2251,
+2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suiters
+personal injury as a result of such violation may sue in any appropriate United
+States District Court and shall recover the actual damages such minor sustains
+and the cost of the suit, including a reasonable attorney's fee. Any minor as
+described in the preceding sentence shall be deemed to have sustained
+damages of no less than $50,000 in value.
+(b) Any action commenced under this section shall be barred unless the complaint
+is filed within six years after the right of action first accrues or in the case of a
+person under a legal disability, not later than three years after the disability.
+Reading the entire statute in context, no where is there any language indicating
+that a minor plaintiff has a private right of action against a defendant "per violation."
+
+
+Entered on FLSD Docket 03/12/2009 Page 9 of 21
+Page 9
+brought a single cause of action, based on allegations of multiple violations of the §2255
+predicate acts. Furthermore, the court refused to add a venue interpretation that simply
+was not written into the statutory text. See other §2255 cases cited herein.
+For an example of a statute wherein the legislature included the language "for
+each violation" in assessing a "civil penalty," see 18 U.S.C. §216, entitled "Penalties and
+injunctions," of Chapter 11 - "Bribery, Graft, and Conflict of Interests," also contained in
+Title 18 - "Crimes and Criminal Procedure." Subsection (b) of §216 gives the United
+States Attorney General the power to bring a "civil action ... against any person who
+engages in conduct constituting an offense under" specified sections of the bribery,
+graft, and conflicts of interest statutes. The statute further provides in relevant part that
+"upon proof of such conduct by a preponderance of the evidence, such person shall be
+subject to a civil penalty of not more than $50,000 for each violation or the amount of
+compensation which the person received or offered for the prohibited conduct, which
+ever amount is greater." As noted, 18 U.S.C. §2255 does not include such language.
+Accordingly, Plaintiff's multiple counts brought pursuant to §2255 are required to
+be dismissed for failure to state multiple causes of action.
+B. Also requiring dismissal Plaintiff has failed to sufficiently allege
+the requisite §2255 predicate acts.
+Also requiring dismissal of Plaintiff's purported §2255 claims) is Plaintiff's failure
+to sufficiently allege any violation of a requisite predicate act as specifically identified in
+subsection (a) of the statute quoted above. Relevant to Plaintiff's complaint, 18 U.S.C.
+2255(a) creates a civil remedy for "a minor who is a victim of a violation of section
+2241(c), 2242, 2243, 2251, 2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title
+
+
+Entered on FLSD Docket 03/12/2009 Page 11 of 21
+the standard of pleading as established in Iwombly, supra, Plaintiff has failed to
+sufficiently allege the requisite elements of a §2255 claim, thus requiring dismissal; for
+failure to state a cause of action.
+C. 18 U.S.C. §2255 does not allow for the recovery of punitive damages.
+Thus, Plaintiff's request for punitive damages under §2255 is required to be
+dismissed or stricken.
+In each of the improperly asserted Counts I through XXX, Plaintiff also seeks
+punitive damages. A plain reading of 18 U.S.C. §2255, quoted above herein,
+establishes that the statute does not allow for the recovery of punitive damages. Had
+Congress wanted to allow for such a recovery, it could have easily written such
+language into the damages provision of the statute. The legislative body chose not to
+write a punitive damages component into §2255 as it has done in other statutes
+affording civil remedies. In relevant part, §2255 reads - Any minor who is a victim of a
+violation of section ... of this title and who suffers personal injury as a result of such
+violation may sue in any appropriate United States District Court and shall recover the
+actual damages such minor sustains and the cost of the suit, including a
+reasonable attorney's fee. Any minor as described in the preceding sentence shall be
+deemed to have sustained damages of no less than $50,000 in value." See discussion
+of rules of statutory construction in part III.A. herein. See subsection (f)(2) of 18 U.S.C.
+§2252A, entitled Certain activities relating to material constituting or containing child
+pornography, also contained in Chapter 110, Part I, Crimes, within which specific
+reference is made to "compensatory and punitive damages" in setting forth the relief
+which may be afforded to a plaintiff in bringing a civil action under §2252A(f).
+
+
+Entered on FLSD Docket 03/12/2009 Page 13 of 21
+Page 13
+statute prohibits a number of activities involving criminal 'proceeds." Id, at 2023. Noting
+that the term "proceeds" was not defined in the statute, the Supreme Court stated the
+well settled principle that "when a term is undefined, we give it its ordinary meaning." Id,
+at 2024. Under the ordinary meaning principle, the government's position was that
+proceeds meant "receipts," while the defendant's position was that proceeds meant
+"profits." The Supreme Court recognized that under either of the proffered "ordinary
+meanings," the provisions of the federal money-laundering statute were still coherent,
+not redundant, and the statute was not rendered "utterly absurd." Under such a
+situation, citing to a long line of cases and the established rule of lenity, "the tie must go
+to the defendant." Id, at 2025. See portion of Court's opinion quoted above. "Because
+the 'profits' definition of 'proceeds' is always more defendant friendly that the 'receipts'
+definition, the rule of lenity dictates that it should be adopted." Id.
+Plaintiff's position would subject Defendant EPSTEIN to a punishment that is not
+clearly prescribed - an unwritten multiplier of the "actual damages" or the presumptive
+damages. The rule of lenity requires that Defendant's interpretation of the remedy
+afforded under §2255 be adopted
+In addition, under the Due Process Clause's basic principle of fair warning -
+... a criminal statute must give fair warning of the conduct that it makes a
+crime ... As was said in United States v. Harriss, 347 U.S. 612, 617, 74
+S.Ct. 808, 812, 98 L.Ed. 989,
+'The constitutional requirement of definiteness is violated by a criminal
+statute that tails to give a person of ordinary intelligence fair notice that
+his contemplated conduct is forbidden by the statute. The underlying
+principle is that no man shall be held criminally responsible for conduct
+which he could not reasonably understand to be proscribed.'
+
+
+Entered on FLSD Docket 03/12/2009 Page 15 of 21
+.. v. Epstein, et al.
+Page 15
+offenses outlined in Chapter 800 of the Federal Codes, as well as those designated in
+Florida Statutes §796.03, §796.07, $796.045, $796.04, §39.01; and §827.04." In 7203
+Plaintiff also alleges that Defendant's "tortious commission of sexual battery upon
+.. were (sic) done willfully and maliciously."
+Supporting Defendant's position that Plaintiff has failed to state a cause of action
+in Count XXXI, 18 U.S.C. §§2241(c), not §2241 in its entirety, as discussed above, is
+one of the predicate acts, along with 2242, 2243, 2421, and 2423, designated in the
+federal civil remedy statute - 18 U.S.C. §2255. Plaintiff attempted and failed to allege
+such a claim in the previous counts. Defendant can find no criminal offenses in any
+"Chapter 800 of the Federal Codes" which give rise to a civil cause of action.
+The same is true for Plaintiff's reference to the Florida Statutes. Not one of the
+statutes referenced creates a private cause of action or affords a civil remedy on behalf
+of the alleged victim of the criminal offense.' (Except for Florida Statute §39.01, all of
+the statutes referenced by Plaintiff are contained Title XLVI. Crimes of the Florida
+Statutes). The referenced criminal statutes set forth acts subject to criminal prosecution
+and the criminal penalties therefor, if proven. See generally, Am. Home Assurance Co.
+y. Plaza Materials Corp., 908 So.2d 360, 374 (Fla. 2005)("not every statutory violation
+carries a civil remedy"); Miami Herald Pub. Co. v. Ferre, 636 F.Supp. 970 (S.D. Fla.
+1985)(violation of Florida's criminal extortion statute does not give rise to civil cause of
+^ Florida Statutes §§796.03 - Procuring person under age 18 for prostitution; 796.04 -
+Forcing, compelling, or coercing another to become a prostitute; 796.045 (which did not
+become effective until Oct. 1, 2004) - Sex trafficking; penalties; 796.07 - Prohibiting
+prostitution, etc.; evidence; penalties; definitions; and §39.01, entitled "Definitions," is
+contained in Title V - Judicial Branch, Chapter 39 - "Proceedings relating to Children."
+
+
+Entered on FLSD Docket 03/12/2009 Page 17 of 21
+Page 17
+Defendant EPSTEIN, but rather allows Plaintiff to attempt to assert a single civil remedy
+if she can prove a violation of any of the statutory enumerated predicate acts. Further,
+Plaintiff has failed to sufficiently allege a requisite predicate act under §2255. In
+addition, §2255 does not allow for recovery of punitive damages. Count XXXI is also
+subject to dismissal with prejudice for failure to state a cause of action, as Plaintiff has
+failed to allege a legally viable or recognizable cause of action.
+WHEREFORE, Defendant requests that this Court grant his motion to dismiss
+Counts I through XXXI, or alternative motion for more definite statement, and motion to
+strike.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of recorg identified on the following Service List in the
+manner specified by CM/ECF on this (2
+Richard Horace Willits, Esq.
+Richard H. Willits, P.A.
+2290 10" Avenue North
+Suite 404
+Lake Worth. FL 33461
+Counsel for Plaintiff .M.A.
+reelrhw@hotmail.com
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+jagesq@bellsouth.net
+counsel for Defendants Jeffrey Epstei
+Jack Scarola, Esq.
+Jack P. Hill, Esq.
+Searcy
+Denney
+Scarola Barnhart
+Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+Bruce Reinhart, Esq.
+• Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm beach, FL 33401
+
+
+Entered on FLSD Docket 03/12/2009 Page 19 of 21
+Page 19
+attained the age of 16 years (and is at least 4 years younger than the person so
+engaging), or attempts to do so, shall be fined under this title and imprisoned for not
+less than 30 years or for life. If the defendant has previously been convicted of another
+Federal offense under this subsection, or of a State offense that would have been an
+offense under either such provision had the offense occurred in a Federal prison, unless
+the death penalty is imposed, the defendant shall be sentenced to life in prison.
+§ 2242. Sexual abuse
+Whoever, in the special maritime and territorial jurisdiction of the United States or in
+a Federal prison, or in any prison, institution, or facility in which persons are held in
+custody by direction of or pursuant to a contract or agreement with the head of any
+Federal department or agency, knowingly--
+(1) causes another person to engage in a sexual act by threatening or placing that
+other person in fear (other than by threatening or placing that other person in fear that
+any person will be subjected to death, serious bodily injury, or kidnapping); or
+(2) engages in a sexual act with another person if that other person is--
+(A) incapable of appraising the nature of the conduct; or
+(B) physically incapable of declining participation in, or communicating
+unwillingness to engage in, that sexual act;
+or attempts to do so, shall be fined under this title and imprisoned for any term of years
+or for life.
+§ 2243. Sexual abuse of a minor or ward
+(a) Of a minor.--Whoever, in the special maritime and territorial jurisdiction of the
+United States or in a Federal prison, or in any prison, institution, or facility in which
+persons are held in custody by direction of or pursuant to a contract or agreement with
+the head of any Federal department or agency, knowingly engages in a sexual act with
+another person who--
+(1) has attained the age of 12 years but has not attained the age of 16 years; and
+(2) is at least four years younger than the person so engaging;
+or attempts to do so, shall be fined under this title, imprisoned not more than 15 years,
+or both.
+(b) Of a ward.--Whoever, in the special maritime and territorial jurisdiction of the United
+States or in a Federal prison, or in any prison, institution, or facility in which persons are
+held in custody by direction of or pursuant to a contract or agreement with the head of
+any Federal department or agency, knowingly engages in a sexual act with another
+person who is--
+
+
+Entered on FLSD Docket 03/12/2009 Page 21 of 21
+. v. Epstein, et al.
+Page 21
+(c) Engaging in illicit sexual conduct in foreign places.--Any United States citizen or
+alien admitted for permanent residence who travels in foreign commerce, and engages
+in any illicit sexual conduct with another person shall be fined under this title or
+imprisoned not more than 30 years, or both.
+(d) Ancillary offenses.-Whoever, for the purpose of commercial advantage or private
+financial gain, arranges, induces, procures, or tacilitates the travel of a person knowing
+that such a person is traveling in interstate commerce or foreign commerce for the
+purpose of engaging in illicit sexual conduct shall be fined under this title, imprisoned
+not more than 30 years, or both.
+(e) Attempt and conspiracy.--Whoever attempts or conspires to violate subsection (a),
+(b), (C), or (d) shall be punishable in the same manner as a completed violation of that
+subsection.
+(f) Definition.--As used in this section, the term "illicit sexual conduct" means (1) a
+sexual act (as defined in section 2246) with a person under 18 years of age that would
+be in violation of chapter 109A if the sexual act occurred in the special maritime and
+territorial jurisdiction of the United States; or (2) any commercial sex act (as defined in
+section 1591) with a person under 18 years of age.
+(g) Defense.--In a prosecution under this section based on illicit sexual conduct as
+defined in subsection (f)(2), it is a defense, which the defendant must establish by a
+preponderance of the evidence, that the defendant reasonably believed that the person
+with whom the defendant engaged in the commercial sex act had attained the age of 18
+years.
+
+
+Case 9:08-CV-80811-KAM Document 81
+Entered on FLSD Docket 05/13/2009 Page 1 of 7
+CASE NO.: 08-CIV-80811-MARRA/JOHNSON
+Plaintiff,
+V.
+HEEBEY EPSTEIN and a
+Defendants,
+Defendant, Jeffrey Epstein's Reply to Plaintiff's Response In Opposition To Defendant's Motion To
+Stay And/Or Continue Action For Time Certain With Incorporated Memorandum Of Law
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his
+undersigned attorneys, hereby files his Reply to Plaintiff's Response In Opposition to
+Defendant's Motion to Stay and/or Continue Action (DE 64), and states:
+I.
+Introduction and Argument
+Plaintiff, in the instant matter, did not draft her own Response to the Motion to Stay.
+Instead, Plaintiff incorporated Plaintiffs' responses to the motion to stay in certain related matters
+(DE 64), and adopted those arguments as her own.!
+Plaintiff's Response in Opposition challenging the stay should not prevail when 5'h
+Amendment principles are at issue and when there exists a real, substantial and not remote
+possibility that Epstein may face criminal prosecution by the United States Attorneys' Office
+("USAO") if the USAO unilaterally determines that Epstein somehow violated that certain Non-
+Prosecution Agreement dated June 30, 2008 ("NPA") and/or if Epstein is forced to waive those
+5"" Amendment rights and participate in civil discovery in order to defend this civil action.
+'Accordingly, Epstein adopts his arguments set forth in the Reply to Jane Doe's Response In Opposition
+filed in 08-CIV-80893 (DE 54) and incorporates same herein by reference.
+
+
+Document 81 Entered on FLSD Docket 05/13/2009 Page 3 of 7
+significant fact that a stay may be issued in light of an ongoing investigation. It is clear from the
+NPA and Jack Goldberger's Affidavit (attached to the Motion to Stay) "...that the criminal
+matters against Epstein remain ongoing until the NPA expires by its terms in late 2010. .,, and
+the threat of criminal prosecution against Epstein by the USAO continues presently and through
+late 2010." See Jack Goldberger's Affidavit, 45 (attached to the Motion to Stay)(DE 51). In
+fact, the FBI refused to provide information regarding this case and other related cases filed
+against Epstein ".. stating the materials are at this time exempt from disclosure because they are
+in an investigative file, i.e., the matter is still an ongoing criminal investigation." See Jack
+Goldberger's Affidavit, 17 (attached to the Motion to Stay)(DE 51).
+Additionally, Plaintiff's response downplays the fact that civil discovery may result in the
+USAO claiming a breach of the NPA. Epstein wishes to vigorously defend this case and others
+filed against him; however, he does not wish to risk waiver of his 5* Amendment privileges, at
+least before the NPA expires or any investigation is closed.
+Further, Plaintiff adopts the arguments set forth in Jane Doe's Response to the Motion to
+Stay filed in 08-CIV-80893, which asserts that the NPA is not attached to Epstein's Motion to
+Stay. The Court has a copy of the NPA. While it may be sealed, this Court may review same, in
+camera. As such, Plaintiff's Best Evidence argument (as adopted) is entirely misplaced and
+should be disregarded.
+a.
+Justice Requires The Entry of A Stay
+As set out in the Motion to Stay, once the NPA expires, EPSTEIN intends to testify to all
+relevant and non-objectionable inquiries made to him in discovery be it a deposition, in
+interrogatories or in production requests. However, the current circumstances are such that by
+3
+
+
+Document 81
+Entered on FLSD Docket 05/13/2009 Page 5 of 7
+Page 5
+for a stay of the civil case until the criminal aspects/investigation of Defendant's companion case
+are closed).
+Here, Epstein is not required to "contemplate an in haec verba iron-clad comparison of
+separate issues by direct proof." St. Paul Fire and Marine Insurance Company v. U.S., 24 CI.C1
+at 516. Instead, a reading of the complaint, the NPA (in camera), the pleadings in support of and
+against Epstein's Motion to Stay along with other pleadings in the clerk's file, makes it clear that
+the facts in the instant matter and those in the ongoing investigation are "related" and/or
+"substantially similar." Id. As such, permitting this civil action to go forward would create a
+hardship on Epstein in that he will be forced to invoke his 5' Amendment Privilege and risk
+loosing this case by virtue of not being able to present evidence, or waive that right and risk a
+potential criminal prosecution. Eastwood v. U.S., 2008 WL 5412857, *1 (E.D. Tenn.))("When a
+party to a civil action is subject to criminal proceedings and/or investigations that relate to such
+civil action, courts will often stay the civil proceeding so as to prevent the use of civil discovery
+and evidentiary procedures to obtain evidence for use in the criminal matter). Id. Courts will
+also stay a civil case to preserve 5' Amendment rights. Id. Further, a comparison of Fed.R.Civ.
+Pro. 26 may expand the rights of criminal discovery beyond the limits of Fed.R.Crim.Pro. 16(b).
+Epstein satisfies the requirements to stay this action as set forth in St. Paul Fire and in Eastwood,
+including the similarity of issues underlying the civil litigation and ongoing criminal
+investigation. As such, a stay should be entered in the instant matter. See also U.S. v.
+$75,020.00 In United States Funds, et al., 2009 WL 1010359 (M.D. G.a. 2009).
+5
+
+
+Case 9:08-Cv-80811-KAM Document 81
+Entered on FLSD Docket 05/13/2009 Page 7 of 7
+Richard Horace Willits, Esq.
+Richard H. Willts, P.A.
+2290 10* Avenue North
+Suite 404
+Lake Worth. EL 33461
+Jack Scarola, Esq.
+Jack P. Hill, Esq.
+Searcy Denney Scarola Barnhart
+Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+jsx@searcylaw.com
+jph@searcylaw.com
+Co-Counsel for Plaintiff
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A
+& 250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+Respastfullv submitte
+500h, 1500
+7
+
+
+Entered on FLSD Docket 05/08/2009 Page 1 of 25
+CASE NO.: 08-CV-80811-MARRA/JOHNSON
+Plaintiff,
+V.
+JEFFREY EPSTEIN and
+Defendants,
+DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM IN RESPONSE
+TO DEFENDANT, JEFFREY EPSTEIN'S, MOTION TO DISMISS FIRST AMEDNED
+COMPLAINT FOR FAIURE TO STATE A CAUSE OF ACTION, AND MOTION FOR
+MORE DEFINITE STATEMENT; MOTION TO STRIKE, AND SUPPORTING
+MEMORANDUM OF LAW, (dated April 13, 2009)
+Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned
+counsel, files his reply to Plaintiff's Memorandum in Response to Defendant, JEFFREY
+EPSTEIN's, Motion to Dismiss First Amended Complaint For Failure to State A Cause
+of Action; And Motion for More Definite Statement; Motion to Strike, And Supporting
+Memorandum of Law, dated April 13, 2009, (hereinafter "Plaintiff's response"). In reply
+to Plaintiff's response and further supporting Defendant's motion to dismiss Count I
+through XXXI of Plaintiff's First Amended Complaint for failure to state a cause of
+action, and for more definite statement, or to strike, [DE 47], dated April 12, 2009,
+(hereinafter "Defendant's motion"), Defendant states:
+1. The 2003 version of 18 U.S.C. §2255 applies to this action.
+A.
+The statute in affect during the time the alleged acts occurred is the applicable
+version of 18 U.S.C. §2255; in this action - the 2003 version (quoted at p. 1,
+
+
+Case 9:08-CV-80811-KAM Document 78 Entered on FLSD Docket 05/08/2009 Page 3 of 25
+A. v. Epstein, et al.
+These provisions demonstrate that retroactive statutes raise particular
+concerns. The Legislature's unmatched powers allow it to sweep away settled
+expectations suddenly and without individualized consideration. Its responsivity
+to political pressures poses a risk that it may be tempted to use retroactive
+legislation as a means of retribution against unpopular groups or individuals. As
+Justice Marshall observed in his opinion for **1498 the Court in Weaver v.
+Graham, 450 U.S. 24, 101 S.Ct. 960, 67 L.Ed.2d 17 (1981), the Ex Post Facto
+Clause not only ensures that individuals have "fair warning" about the effect of
+criminal statutes, but also "restricts governmental power by restraining arbitrary
+and potentially vindictive legislation." Id., at 28-29, 101 S.Ct., at 963-964
+(citations omitted). FN20
+FN20. See Richmond v. J. A. Croson Co., 488 U.S. 469, 513-514, 109 S.Ct. 706,
+732, 102 L.Ed.2d 854 (1989) ("Legislatures are primarily policymaking bodies that
+promulgate rules to govern future conduct. The constitutional prohibitions against
+the enactment of ex post facto laws and bills of attainder reflect a valid concern
+about the use of the political process to punish or characterize past conduct of
+private citizens. It is the judicial system, rather than the legislative process, that is
+best equipped to identify past wrongdoers and to fashion remedies that will create
+the conditions that presumably would have existed had no wrong been committed")
+(STEVENS, J., concurring in part and concurring in judgment); James v. United
+States, 366 U.S. 213, 247, n. 3, 81 S.Ct. 1052, 1052, n. 3, 6 L.Ed.2d 246 (1961)
+(retroactive punitive measures may reflect "a purpose not to prevent dangerous
+conduct generally but to impose by legislation a penalty against specific persons or
+classes of persons").
+As discussed more fully below herein, these well entrenched constitutional
+protections and presumptions against retroactive application of legislation establish that
+the version of 18 U.S.C. §2255 (2003) in effect at the time of the alleged conduct
+applies to the instant action, and not the amended version as claimed by Plaintiff.
+B.
+Not only is there no clear express intent stating that the statute is to apply
+retroactively, but applying the current version of the statute, as amended in 2006, would
+be in clear violation of the Ex Post Facto Clause of the United States Constitution as it
+would be applied to events occurring before its enactment and would increase the
+
+
+Case 9:08-cv-80811-KAM|
+Entered on FLSD Docket 05/08/2009 Page 5 of 25
+.. V. Epstein, et al.
+Page 5
+2006 amended version of §2255 without any legal discussion supporting a retroactive
+application. (See p. 3 of Plaintiff's response).
+§2255 is contained in Title 18 of the United States Codes - "Crimes and Criminal
+Procedure, Part I. Crimes, Chap. 110. Sexual Exploitation and Other Abuse of
+Children." 18 U.S.C. §2255 (2003), is entitled Civil remedy for personal injuries, and
+imposes a presumptive minimum of damages in the amount of $50,000.00, should
+Plaintiff prove a violation of the specified criminal statutes, and suffer personal injury
+with actual damages. Thus, the effect of the 2006 amendments, effective July 27, 2006,
+would be to triple the amount of the statutory minimum previously in effect during the
+time of the alleged acts. (Taking Plaintiff's position that the presumptive minimum is
+meant to be multiplied per violation - the damages would be 4.5 million. The express
+language of the statute has no multiplier.)
+No case has yet decided the specific issue before this Court - whether application
+of the 2006 version of §2255, which increased the statutorily presumed minimum
+damages from $50,000 to $150,000, regardless of the actual amount of damages
+suffered and proven, is prohibited from application under the Ex Post Fact Clause to the
+specified criminal acts occurring prior to the statutes effective date of July 27, 2006.
+The statute, as amended in 2006, contains no language stating that the application is to
+be retroactive. Thus, there is no manifest intent that the statute is to apply retroactively,
+and, accordingly, the statute in effect during the time of the alleged conduct is to apply.
+Landgraf v. USI Film Products, supra, at 1493, ("A statement that a statute will become
+
+
+• Case 9:08-CV-80811-KAM Document 78
+Entered on FLSD Docket 05/08/2009 Page 7 of 25
+Mandatory Victim Restitution Act of 1996 (MVRA) to the defendant whose criminal
+conduct occurred before the effective date of the statute, 18 U.S.C. §3664(f)(1)(A), even
+though the guilty plea and sentencing proceeding occurred after the effective date of the
+statute. On July 19, 1996, the defendant Siegel pleaded guilty to various charges under
+18 U.S.C. §371 and §1956(a)(1)(A), (conspiracy to commit mail and wire fraud, bank
+fraud, and laundering of money instruments; and money laundering). He was
+sentenced on March 7, 1997. As part of his sentence, Siegel was ordered to pay
+$1,207,000.00 in restitution under the MVRA which became effective on April 24, 1996.
+Pub.L. No. 104-132, 110 Stat. 1214, 1229-1236. The 1996 amendments to MVRA
+required that the district court must order restitution in the full amount of the victim's loss
+without consideration of the defendant's ability to pay. Prior to the enactment of the
+MVRA and under the former 18 U.S.C. §3664(a) of the Victim and Witness Protection
+Act of 1982 (VWPA), Pub.I. No. 97-291, 96 Stat. 1248, the court was required to
+consider, among other factors, the defendant's ability to pay in determining the amount
+of restitution.
+When the MVRA was enacted in 1996, Congress stated that the amendments to
+the VWPA "shall, to the extent constitutionally permissible, be effective for sentencing
+proceedings in cases in which the defendant is convicted on or after the date of
+enactment of this Act [Apr. 24, 1996]." Siegel, supra at 1258. The alleged crimes
+occurred between February, 1988 to May, 1990. The Court agreed with the defendant's
+position that 1996 MVRA "should not be applied in reviewing the validity of the court's
+
+
+Entered on FLSD Docket 05/08/2009 Page 9 of 25
+Page 9
+In the instant case, in answering the first question, it is clear that that imposition of
+a minimum amount of damages, regardless of the amount of actual damages suffered
+and proven by a minor victim, is meant to be a penalty or punishment. See statutory
+text and House Bill Reports, cited above herein, consistently referring to the
+presumptive minimum damages amount under §2255 as "punishment" or "penalties."
+According to the Ex Post Facto doctrine, although §2255 is labeled a "civil remedy,"
+such label is not dispositive; "if the effect of the statute is to impose punishment that is
+criminal in nature, the ex post facto clause is implicated." See generally, Roman
+Catholic Bishop of Oakland v. Superior Court, 28 Cal.Rptr.3d 355, at 360, citing Kansas
+y. Hendricks, 521 U.S. 346, 360-61 (1997). The effect of applying the 2006 version of
+§2255 would be to triple the amount of the presumptive minimum damages to a minor
+who proves the elements of her §2255 claim. (Under Plaintiff's attempted approach -
+the presumptive minimum would potentially increase from 1.5 million to 4.5 million
+($50,000 X 30; $150,000 X 30). The fact that a plaintiff proceeding under §2255 has to
+prove a violation of a criminal statute to recover damages thereunder, further supports
+that the imposition of a minimum amount, regardless of the amount of a victim's actual
+damages sustained, is meant and was enacted as additional punishment or penalty for
+violation of criminal sexual exploitation and abuse of minors.
+Accordingly, this Court is required to apply the statute in effect at the time of the
+alleged criminal acts. Not only is there no language in the 2006 statute stating that it is
+to apply retroactively, but further, such application of the 2006 version of 18 U.S.C.
+§2255 to acts that occurred prior to its effective date would have a detrimental and
+
+
+• Case 9:08-CV-80811-KAM Document 78 Entered on FLSD Docket 05/08/2009 Page 11 of 25
+i. v. Epstein, et al.
+When a case implicates a federal statute enacted after the events in suit, the
+court's first task is to determine whether Congress has expressly prescribed the
+statute's proper reach. If Congress has done so, of course, there is no need to
+resort to judicial default rules. When, however, the statute contains no such
+express command, the court must determine whether the new statute would
+have retroactive effect, i.e., whether it would impair rights a party possessed
+when he acted, increase a party's liability for past conduct, or impose new
+duties with respect to transactions already completed. If the statute would
+operate retroactively, our traditional presumption teaches that it does not
+govern absent clear congressional intent favoring such a result.
+Here, there is no clear expression of intent regarding the 2006 Act's application to
+conduct occurring well before its enactment. Clearly, however, as discussed in part B
+herein, the presumptive minimum amount of damages of $150,000 was enacted as a
+punishment or penalty upon those who sexually exploit and abuse minors. See
+discussion of House Bill Reports and Congressional background above herein. The
+amount triples the previous amount for which a defendant might be found liable,
+regardless of the amount of actual damages sustained and proven. The new statute
+imposes a substantial increase in the monetary liability for past conduct. (As discussed
+below, Plaintiff also proposes that the minimum damage amount is to apply on a per
+violation basis; the absurdity of such position is further magnified when one considers
+that the presumptive damages amount was tripled to $150,000).
+As stated in Landgraf, "the extent of a party's liability, in the civil context as well as
+the criminal, is an important legal consequence that cannot be ignored." Courts have
+consistently refused to apply a statute which substantially increases a party's liability to
+conduct occurring before the statute's enactment. Landgraf, supra at 284-85. Even if
+the effective date of the Act. The Court determined that statutory text in question, §102, was
+subject to the presumption against statutory retroactivity.
+
+
+Entered on FLSD Docket 05/08/2009 Page 13 of 25
+1. v. Epstein, et al.
+Page 13
+count complaint, including a single cause of action pursuant to 18 U.S.C. §2255 (Count
+1), along with 11 other counts based on state law ranging from negligence to intentional
+and negligent infliction of emotional distress. The defendants moved to dismiss Count I
+because "plaintiffs have not pled sufficient facts to satisfy one of the predicate felonies
+mentioned in the statute."
+In describing the remedy created under 18 U.S.C. §2255(a), the Eastern District
+of Pennsylvania stated that the statute "authorizes a civil remedy for personal injuries
+suffered by a minor victim of certain federal felonies, ...." Id, at 4. In other words, a
+minor, who is a victim of any of the specified predicate criminal acts, may bring a §2255
+claim "to recover the actual damages such minor sustains," regardless if a plaintiff
+proves one or multiple violations. As long as a plaintiff proves any violation of a
+specified criminal act and that he or she suffered personal injury, he or she is entitled to
+the presumptive minimum of damages imposed by the applicable statute - $50,000 in
+the instant case, even if the amount of actual damages proven is less. Again, the
+statute says nothing about the presumptive damages amount being for each violation or
+incident alleged.
+In her response, (pp. 3-9), Plaintiff at one point states that the express language
+allows for "a separate cause of action for each separate incident," but then goes on to
+rely on statutory interpretation principles applied when the language is vague or
+ambiguous. See p. 4 of response where Plaintiff states - "A review of the wording of 18
+U.S.C. §2255 demonstrates no ambiguity." Plaintiff then references a portion of the
+legislative history and background on "Masha's Law." Plaintiff can cite to no case law
+
+
+Case 9:08-CV-80811-KAM Document 78 Entered on FLSD Docket 05/08/2009 Page 15 of 25
+i. v. Epstein, et al.
+Page 15
+Plaintiff's reliance on In re Hawaiian Airlines, Inc. (Konop v. Hawaiin Airlines,
+Inc.), 355 B.R. 225 (D. Hi. 2006), is misplaced. Unlike the Stored Communications Act,
+18 U.S.C. §2707(c), endnote', at issue in the Hawaiian Airlines case, the presumptive
+minimum is tied to the minor or person proving that she or he has suffered personal
+injury, along with actual damages sustained, as a result of any violation. To even bring
+a cause of action under §2255, a "minor/person" must prove a violation of enumerated
+criminal statute and "suffer personal injury as a result of such violation." Only then
+"shall" such minor "recover the actual damages such minor sustains ... . Any
+minor/person as described in the preceding sentence shall be deemed to have
+sustained damages of no less than $50,000/$150,000 in value." The statute at issue in
+Hawaiian Airlines does not address personal injury type damages, Significantly, the
+court found that the Stored Communications Act does not even require that the plaintiff
+prove actual damages or profits made by the violator to recover the statutory cap.
+Recovery under §2255, unlike the Stored Communications Act, is limited to a
+minor/person "who suffers personal injury" and mandates a recover of "actual
+damages," no matter how little is actually proven, of the statutory minimum.
+Hawaiian Airlines actually supports Defendant's position. The Court discussed
+and distinguished the Privacy Act, relying on Doe v. Chao, 540 U.S. 614, 124 S.Ct.
+1204(2004), which contained similar language to the Stored Communications Act, but
+concluded that $1,000 minimum damage award under the Privacy Act was not subject
+to multiplication on a per violation basis because it was limited to a plaintiff who proves
+actual damages. See endnote 2 for relevant text of Privacy Act.? In Doe v. Chao, the
+
+
+Entered on FLSD Docket 05/08/2009 Page 17 of 25
+r. Epstein, et al.
+Page 17
+applying the rule of lenity, the Court sided with the Defendants' interpretation of the
+Lacey Act which makes illegal the possession of snook caught in specified jurisdictions.
+The snook had been caught in Nicaraguan waters. The defendants filed a motion to
+dismiss asserting the statute did not encompass snook caught in foreign waters. The
+United States disagreed. Both sides presented reasonable interpretations regarding the
+reach of the statute. In dismissing the indictment, the Court determined that the rule of
+lenity required it to accept defendants' interpretation.
+Ill.
+Also requiring dismissal Plaintiff has failed to sufficiently allege
+the requisite §2255 predicate acts. (Plaintiff's Response, p. 10)
+Also requiring dismissal of Plaintiff's purported §2255 claims) is Plaintiff's failure
+to sufficiently allege any violation of a requisite predicate act as specifically identified in
+subsection (a) of the statute. Plaintiff in her response, p. 10, agrees that she has failed
+to sufficiently allege the predicate acts) required by §2255. Defendant has no objection
+to Plaintiff attempting to amend, but Plaintiff should be required to plead a single cause
+of action under §2255 (2003), without seeking to multiply the presumptive minimum
+damages.
+IV. 18 U.S.C. $2255 does not allow for the recovery of punitive damages.
+Thus, Plaintiff's request for punitive damages under §2255 is required to be
+dismissed or stricken. (Plaintiff's Response, Part III, p. 11-18).
+Plaintiff's reliance on Tachiona v. Mugabe, 216 F.Supp.2d 262 (S.D.N.Y. 2002),
+is misplaced as the federal statute at issue, the Torture Victim Protection Act (TVPA), is
+clearly distinguishable. (Plaintiff's response, p. 11). See endnote 3 for relevant text.?
+Unlike §2255 which expressly provides that a successful plaintiff "shall recover the
+actual damages such minor/person sustains," the TVPA simply states that an individual
+
+
+Case 9:08-cv-80811-KAM Document 78
+Entered on FLSD Docket 05/08/2009 Page 19 of 25
+.. v. Epstein, et al.
+Page 19
+sustained" and imposes a minimum damages amount should plaintiff prove the
+elements of her claim.
+Plaintiff's reference, at p. 13 of her response, to the fact that the legislature
+eliminated a proposed three-fold damages provision in favor of the "actual damages"
+language also supports Defendant's position. Remember, this statute was enacted as
+part of the criminal statutory scheme to punish those who sexually abuse and exploit
+children. In addition to facing the payment of "actual damages" to a minor/person who
+suffered personal injury as a result of predicate act violation, such an individual also
+faces criminal prosecution and the additional accompanying penalties of spending many
+years in jail. Despite Plaintiff's attempted reliance on the legislative discussions and
+history prior to the passage of §2255, the ultimate decision is reflected in the language
+of the statute itself which allows for the recovery of "actual damages," and does not
+include punitive damages. Accordingly, Plaintiff's claim for punitive damages under 18
+U.S.C. §2255 is required to be dismissed/stricken.
+Count XXXI - "Sexual Battery" is required to be dismissed for failure to
+state a cause of action. In the alternative, Plaintiff should be required to more
+definitely state whether she is attempting to allege a claim under Florida
+common or statutory law, or some federal law, and further allege the required
+In her response, at p. 16, Plaintiff claims that "Count XXXI - Sexual Battery" is
+brought pursuant to Florida common law. Defendant stands on his original motion. If
+Plaintiff is proceeding under Florida common law, then she should more definitely state
+such cause of action pleading the requisite elements of a common law sexual battery
+
+
+Case 9:08-Cv-80811-KAM
+Entered on FLSD Docket 05/08/2009
+
+Page 21
+By:
+ROBERT D. (BITTON, JR., ESQ.
+Florida Bar No/ 224162
+то0
+West Palm Beach, FL 33401
+li!!
+(Counsel for Defendant Jeffrey Epstein)
+' See 18 U.S.C. §2707(d. of the Stored Communications Act for provision at issue.
+Title 18. Crimes and Criminal Procedure
+Part I. Crimes
+Chapter 121. Stored Wire and Electronic Communications and Transactional
+Records Access
+§ 2707. Civil action
+(a) Cause of action.--Except as provided in section 2703(e), any provider of
+electronic communication service, subscriber, or other person aggrieved by any
+violation of this chapter in which the conduct constituting the violation is engaged in
+with a knowing or intentional state of mind may, in a civil action, recover from the
+person or entity, other than the United States, which engaged in that violation such
+relief as may be appropriate.
+(b) Relief.--In a civil action under this section, appropriate relief includes--
+(1) such preliminary and other equitable or declaratory relief as may be appropriate;
+(2) damages under subsection (c); and
+(3) a reasonable attorney's fee and other litigation costs reasonably incurred.
+(c) Damages,--The court may assess as damages in a civil action under this
+
+
+Entered on FLSD Docket 05/08/2009 Page 23 of 25
+Page 23
+functions of the officer or governmental entity making the disclosure, is a violation of
+this chapter. This provision shall not apply to information previously lawfully
+disclosed (prior to the commencement of any civil or administrative proceeding
+under this chapter) to the public by a Federal, State, or local governmental entity or
+by the plaintiff in a civil action under this chapter.
+2
+See §552a(g)(4), in bold, for relevant section of statute.
+Title 5. Government Organization and Employees
+Part I. The Agencies Generally
+Chapter 5. Administrative Procedure
+Subchapter II. Administrative Procedure
+→§ 552a. Records maintained on individuals
+(g)(1) Civil remedies.-Whenever any agency
+(A) makes a determination under subsection (d)(3) of this section not to amend
+an individual's record in accordance with his request, or fails to make such review in
+conformity with that subsection;
+(B) refuses to comply with an individual request under subsection (d)(1) of this
+section;
+(C) fails to maintain any record concerning any individual with such accuracy,
+relevance, timeliness, and completeness as is necessary to assure fairness in any
+determination relating to the qualifications, character, rights, or opportunities of, or
+benefits to the individual that may be made on the basis of such record, and
+consequently a determination is made which is adverse to the individual; or
+(D) fails to comply with any other provision of this section, or any rule
+promulgated thereunder, in such a way as to have an adverse effect on an
+individual,
+the individual may bring a civil action against the agency, and the district courts of
+the United States shall have jurisdiction in the matters under the provisions of this
+subsection.
+(2)(A) In any suit brought under the provisions of subsection (g) (1)(A) of this
+section, the court may order the agency to amend the individual's record in
+accordance with his request or in such other way as the court may direct. In such a
+case the court shall determine the matter de novo.
+
+
+Entered on FLSD Docket 05/08/2009 Page 25 of 25
+Page 25
+(Emphasis addied).
+
+
+
+CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON
+Plaintiffs),
+VS.
+JEFFREY EPSTEIN and
+Defendants).
+/
+FIRST AMENDED COMPLAINT
+Parties, Jurisdiction and Venue
+COMES NOW the Plaintiff,
+, and brings this First Amended Complaint
+against the Defendants, JEFFREY EPSTEIN and
+and states as
+follows:
+1. This is an action for damages in excess of $75,000.00, exclusive of
+interest and costs.
+This Complaint is brought under a fictitious name in order to protect the
+, because this Complaint makes allegation of sexual
+identity of the Plaintiff,
+assault and child abuse of a then minor.
+3.
+At all times material to this cause of action, the Plaintiff,
+resident of Palm Beach County, Florida.
+., was a
+
+
+
+Defendant, JEFFREY EPSTEIN'S, residence by the Defendant's employees and
+assistants. When the employees and assistants left the then minor Plaintiff and other
+minor girls alone in a room at the Defendant's mansion, the Defendant, JEFFREY
+EPSTEIN, himself would appear, remove his clothing, and direct the then minor Plaintiff
+to remove her clothing. He would then perform one or more lewd, lascivious, and
+sexual acts, including, but not limited to, masturbation, touching of the then minor
+Plaintiff's breasts and buttock, and solicitation and enticement of the then minor Plaintiff
+to engage in sexual acts with another female in JEFFREY EPSTEIN'S presence.
+11. The Plaintiff,
+, was the first brought to the Defendant, JEFFREY
+EPSTEIN'S, mansion in late May or early June of 2002, when she was fifteen-years old
+and in middle school.
+12. The Defendant, JEFFREY EPSTEIN, a wealthy financier with a lavish
+home, significant wealth, a network of assistants and employees, used his resources
+and his influence over a vulnerable minor child to engage in a systematic pattern of
+sexually exploitive behavior.
+13.
+Beginning in approximately late May or early June of 2002, and continuing
+until approximately August of 2003, the Defendant coerced and enticed the
+impressionable, vulnerable, and economically deprived then minor Plaintiff to commit
+various acts of sexual misconduct. These acts occurred, on average, one to three times
+per week from late May or early June of 2002 until August of 2003. At a bare minimum,
+3
+
+
+Entered on FLSD Docket 02/09/2009 Page 5 of 91
+exploitation of minor children, prostitution, sexual performance by a child, lewd and
+lascivious assaults, sexual battery, contributing the delinquency of a minor and other
+crimes, specifically including, but not limited to, those crimes designated in 18 USC
+§2241, §2242, §2243, §2421, and §2423, criminal offenses outlined in Chapter 800 of
+the Federal Codes, as well as those designated in Florida Statutes $796.03, §796.07,
+§796.045, §796.04, §39.01; and §827.04.
+16. The above-described acts took place in Palm Beach County, Florida, at
+the residence of the Defendant, JEFFREY EPSTEIN. Any assertions by the Defendant,
+JEFFREY EPSTEIN, that he was unaware of the age of the then minor Plaintiff are
+belied by his actions and rendered irrelevant by the provisions of applicable Florida
+Statutes concerning the sexual exploitation and abuse of a minor child. The Defendant,
+JEFFREY EPSTEIN, at all times material to this cause of action, knew and should have
+known of the Plaintiff,
+'s minority.
+17. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County,
+Florida, the Defendant, JEFFREY EPSTEIN, entered pleas of "guilty" to various Florida
+state crimes involving the solicitation of minors for prostitution and the procurement of
+minors for the purpose of prostitution.
+18.
+As a condition of that plea, and in exchange for the Federal Government
+not prosecuting the Defendant, JEFFREY EPSTEIN, for numerous federal offenses,
+Defendant,
+JEFFREY EPSTEIN, additionally entered into an agreement with the
+5
+
+
+Entered on FLSD Docket 02/09/2009 Page 7 of 91
+1. vs. Epstein, et al.
+21. In late May or early June of 2002,
+was first introduced to
+Defendant, JEFFREY EPSTEIN.
+was brought to JEFFREY EPSTEIN'S
+residence by a female friend of hers.
+sat on the couch while the female friend
+took off her own clothes, mounted JEFFREY EPSTEIN who was wearing only a towel
+and lying on a table, and performed a sexual act upon JEFFREY EPSTEIN in the
+presence of
+In exchange for her participation as an observer of JEFFREY
+EPSTEIN'S lewd and lascivious conduct,
+was paid $300 by JEFFREY
+EPSTEIN.
+22. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+7
+
+
+Entered on FLSD Docket 02/09/2009 Page 9 of 91
+. vs. Epstein, et al.
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff
+will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff,
+., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT !!
+Cause of Action Pursuant to 18 USC §2255
+June 2002- Incident 2
+26. The Plaintiff,
+., adopts and realleges paragraphs 1 through 19
+above.
+27.
+Approximately one week after the first incident,
+received a
+telephone call from JEFFREY EPSTEIN requesting that she return to his residence. On
+this occasion, JEFFREY EPSTEIN directed
+to undress to her brassiere and
+underwear and to provide him with a massage. At the conclusion of the massage,
+JEFFREY EPSTEIN masturbated himself in
+'s presence. JEFFREY EPSTEIN
+$300 for this encounter.
+9
+ETA00175374
+
+Entered on FLSD Docket 02/09/2009 Page 11 of 91
+Case No.: OBsten 0f11-CIN-MARRAJOHNSON
+30. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff,
+., and as such he must effectively admit liability unto the
+Plaintiff,
+31. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+.. has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff,
+., will in
+the future suffer additional medical and psychological expenses. The Plaintiff,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff,
+.., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff,
+. demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+11
+
+
+Entered on FLSD Docket 02/09/2009 Page 13 of 91
+1. vs. Epstein, et al.
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+35.
+The Plaintiff,
+., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+United States Government.
+36.
+Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+., and as such he must effectively admit liability unto the
+against the Plaintiff,
+Plaintiff, C.M.A.
+37.
+As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering,
+emotional distress, psychological trauma, mental anguish, humiliation,
+13
+
+
+Entered on FLSD Docket 02/09/2009 Page 15 of 91
+_. vs. Epstein, et al.
+38. The Plaintiff,
+., adopts and realleges paragraphs 1 through 19
+above.
+39. For the second time in July of 2002,
+again returned to JEFFREY
+EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed
+I to fully undress and to provide him with a massage. Defendant, JEFFREY
+EPSTEIN, fondled the breasts and buttocks of the then minor
+At the conclusion
+of the massage, JEFFREY EPSTEIN masturbated himself in
+'s presence.
+JEFFREY EPSTEIN paid
+40. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+15
+
+
+Entered on FLSD Docket 02/09/2009 Page 17 of 91
+C.M.A. vs. Epstein, et al.
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff,
+.. will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT V
+Cause of Action Pursuant to 18 USC $2255
+August of 2002 - Incident 1
+44.
+The Plaintiff,
+• adopts and realleges paragraphs 1 through 19
+above.
+45.
+In August of 2002,
+again returned to JEFFREY EPSTEIN'S
+residence at his request. On this occasion, JEFFREY EPSTEIN directed
+to fully
+undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled
+the breasts and buttocks of the then minor
+JEFFREY EPSTEIN masturbated himself in
+At the conclusion of the massage,
+I's presence. JEFFREY EPSTEIN
+17
+
+
+Entered on FLSD Docket 02/09/2009 Page 19 of 91
+48.
+Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff,
+., and as such he must effectively admit liability unto the
+Plaintiff,
+49.
+As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+.. has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff,
+will in
+the future suffer additional medical and psychological expenses. The Plaintiff,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff,
+., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff,
+.. demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+19
+
+
+Entered on FLSD Docket 02/09/2009 Page 21 of 91
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+53. The Plaintiff,
+., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+United States Government.
+54. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff,
+., and as such he must effectively admit liability unto the
+Plaintiff,
+55.
+As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+., has in the past suffered, and will in the future suffer, physical injury, pain and
+21
+
+
+Entered on FLSD Docket 02/09/2009 Page 23 of 91
+57. In September of 2002, I
+again returned to JEFFREY EPSTEIN'S
+residence at his request. On this occasion, JEFFREY EPSTEIN directed
+to fully
+undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled
+the breasts and buttocks of the then minor
+At the conclusion of the massage,
+JEFFREY EPSTEIN masturbated himself in
+I's presence. JEFFREY EPSTEIN
+paid |
+58. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+23
+
+
+Entered on FLSD Docket 02/09/2009 Page 25 of 91
+1. vs. Epstein, et al.
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff,
+., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff,
+., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT VIII
+Cause of Action Pursuant to 18 USC $2255
+September of 2002 - Incident 2
+62. The Plaintiff,
+., adopts and realleges paragraphs 1 through 19
+above.
+63. For the second time in September of 2002,
+again returned to
+JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN
+directed
+to fully undress and to provide him with a massage. Defendant,
+JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor
+At the
+conclusion of the massage, JEFFREY EPSTEIN masturbated himself in
+'s
+presence. JEFFREY EPSTEIN paid I|
+
+
+Entered on FLSD Docket 02/09/2009 Page 27 of 91
+| vs. Epstein, et al.
+66. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff,
+and as such he must effectively admit liability unto the
+Plaintiff,
+67. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+,, has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff,
+will in
+the future suffer additional medical and psychological expenses. The Plaintiff,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff,
+., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, l
+,, demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+27
+
+
+Entered on FLSD Docket 02/09/2009 Page 29 of 91
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr: Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+71. The Plaintiff,
+., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+United States Government.
+72.
+Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff,
+., and as such he must effectively admit liability unto the
+Plaintiff,
+73.
+As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+., has in the past suffered, and will in the future suffer, physical injury, pain and
+29
+
+
+Entered on FLSD Docket 02/09/2009 Page 31 of 91
+|i vs. Epstein, et al.
+74. The Plaintiff,
+adopts and realleges paragraphs 1 through 19
+above.
+75. For the second time in October of 2002,
+again returned to
+JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN
+directed | to fully undress and to provide him with a massage. Defendant,
+JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor
+At the
+conclusion of the massage, JEFFREY EPSTEIN masturbated himself in
+'s
+presence. JEFFREY EPSTEIN paid
+76.
+As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+31
+
+
+Entered on FLSD Docket 02/09/2009 Page 33 of 91
+1. vs. Epstein, et al.
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff,
+.., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff,
+., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XI
+Cause of Action Pursuant to 18 USC $2255
+November of 2002 - Incident 1
+80.
+The Plaintiff,
+, adopts and realleges paragraphs 1 through 19
+above.
+81.
+In November of 2002, L
+again returned to JEFFREY EPSTEIN'S
+residence at his request. On this occasion, JEFFREY EPSTEIN directed
+to fully
+undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled
+the breasts and buttocks of the then minor
+. At the conclusion of the massage,
+I's presence. JEFFREY EPSTEIN
+JEFFREY EPSTEIN masturbated himself in
+33
+
+
+Entered on FLSD Docket 02/09/2009 Page 35 of 91
+84. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff,
+, and as such he must effectively admit liability unto the
+Plaintiff,
+85. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff,
+, Will in
+the future suffer additional medical and psychological expenses. The Plaintiff,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff,
+,, will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, I
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+35
+
+
+Entered on FLSD Docket 02/09/2009 Page 37 of 91
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+89.
+The Plaintiff,
+., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+United States Government.
+90.
+Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff,
+., and as such he must effectively admit liability unto the
+Plaintiff,
+91. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+37
+
+
+Case 9:08-Cv-80811-KAM Document 39
+
+1. vs. Epstein, et al.
+93. In December of 2002,
+again returned to JEFFREY EPSTEIN'S
+residence at his request. On this occasion, JEFFREY EPSTEIN directed
+to fully
+undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled
+the breasts and buttocks of the then minor
+At the conclusion of the massage,
+JEFFREY EPSTEIN masturbated himself. in |
+L's presence. JEFFREY EPSTEIN
+paid C.M.A. in excess of $200 for this encounter.
+94. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mir. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+39
+
+
+Entered on FLSD Docket 02/09/2009 Page 41 of 91
+!. vs. Epstein, et al.
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff,
+1, will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XIV
+Cause of Action Pursuant to 18 USC $2255
+December of 2002 - Incident 2
+98. The Plaintiff,
+, adopts and realleges paragraphs 1 through 19
+above.
+99. For the second time in December of 2002,
+again returned to
+JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN
+directed
+to fully undress and to provide him with a massage. Defendant,
+JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor
+At the
+conclusion of the massage, JEFFREY EPSTEIN masturbated himself in EM.A.s
+presence. JEFFREY EPSTEIN paid || |
+. in excess of $200 for this encounter.
+41
+
+
+Entered on FLSD Docket 02/09/2009 Page 43 of 91
+102. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff,
+, and as such he must effectively admit liability unto the
+Plaintiff,
+103. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+1l, has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff,
+, Will in
+the future suffer additional medical and psychological expenses. The Plaintiff,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff,
+, will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, L
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+
+
+Entered on FLSD Docket 02/09/2009 Page 45 of 91
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+107. The Plaintiff,
+., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+United States Government.
+108.
+Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff,
+..and as such he must effectively admit liability unto the
+Plaintiff,
+109. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+., has in the past suffered, and will in the future suffer, physical injury, pain and
+45
+
+
+Entered on FLSD Docket 02/09/2009 Page 47 of 91
+111. For the second time in January of 2003,
+again returned to
+JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN
+directed
+to fully undress and to provide him with a massage. Defendant,
+JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor
+At the
+conclusion of the massage, JEFFREY EPSTEIN masturbated himself in
+'s
+presence. JEFFREY EPSTEIN paid
+. in excess of $200 for this encounter.
+112. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+47
+
+
+Entered on FLSD Docket 02/09/2009 Page 49 of 91
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff,
+., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff,
+., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XVII
+Cause of Action Pursuant to 18 USC $2255
+February of 2003 - Incident 1
+116. The Plaintiff,
+, adopts and realleges paragraphs 1 through 19
+above.
+117. In February of 2003, L
+• again returned to JEFFREY EPSTEIN'S
+residence at his request. On this occasion, JEFFREY EPSTEIN directed
+to fully
+undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled
+the breasts and buttocks of the then minor
+1. At the conclusion of the massage,
+JEFFREY EPSTEIN masturbated himself in
+.'s presence. JEFFREY EPSTEIN
+49
+
+
+Entered on FLSD Docket 02/09/2009 Page 51 of 91
+1. vs. Epstein, et al.
+120. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff,
+.., and as such he must effectively admit liability unto the
+Plaintiff,
+121. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+.. has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff,
+., will in
+the future suffer additional medical and psychological expenses. The Plaintiff,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, L
+.. will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+
+
+Entered on FLSD Docket 02/09/2009 Page 53 of 91
+1. vs. Epstein, et al.
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+125. The Plaintiff,
+., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+United States Government.
+126. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff,
+, and as such he must effectively admit liability unto the
+Plaintiff,
+127. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+53
+
+
+Entered on FLSD Docket 02/09/2009 Page 55 of 91
+129. In March of 2003,
+again returned to JEFFREY EPSTEIN'S
+residence at his request. On this occasion, JEFFREY EPSTEIN directed [
+to fully
+undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled
+the breasts and buttocks of the then minor
+At the conclusion of the massage,
+JEFFREY EPSTEIN masturbated himself in
+I's presence. JEFFREY EPSTEIN
+130. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+55
+
+
+Entered on FLSD Docket 02/09/2009 Page 57 of 91
+. vs. Epstein, et al.
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff,
+.. will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff,
+., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XX
+Cause of Action Pursuant to 18 USC $2255
+March of 2003 - Incident 2
+134. The Plaintiff,
+., adopts and realleges paragraphs 1 through 19
+above.
+135. For the second time in March of 2003,
+• again returned to JEFFREY
+EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed
+to fully undress and to provide him with a massage. Defendant, JEFFREY
+EPSTEIN, fondled the breasts and buttocks of the then minor
+At the conclusion
+of the massage, JEFFREY EPSTEIN masturbated himself in
+'s presence.
+JEFFREY EPSTEIN paid
+57
+
+
+Entered on FLSD Docket 02/09/2009 Page 59 of 91
+1. vs. Epstein, et al.
+138. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff,
+.. and as such he must effectively admit liability unto the
+Plaintiff,
+139. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff,
+., will in
+the future suffer additional medical and psychological expenses. The Plaintiff,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life.
+These injuries are permanent in nature and the
+Plaintiff,
+.. will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff,
+demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+59
+
+
+Entered on FLSD Docket 02/09/2009 Page 61 of 91
+. vs. Epstein, et al.
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+143. The Plaintiff,
+., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+United States Government.
+144. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff,
+. and as such he must effectively admit liability unto the
+Plaintiff,
+145. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,.
+, has in the past suffered, and will in the future suffer, physical injury, pain and
+61
+
+
+Entered on FLSD Docket 02/09/2009 Page 63 of 91
+1. vs. Epstein, et al.
+147. For the second time in April of 2003,
+again returned to JEFFREY
+EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed
+to fully undress and to provide him with a massage. Defendant, JEFFREY
+EPSTEIN, fondled the breasts and buttocks of the then minor
+At the conclusion
+of the massage, JEFFREY EPSTEIN masturbated himself in
+I's presence.
+JEFFREY EPSTEIN paid
+148. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+63
+
+
+Entered on FLSD Docket 02/09/2009 Page 65 of 91
+25e No.: OB-Cin 1-CIV-MARRAUIOHNSON
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff,
+, will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XXIII
+Cause of Action Pursuant to 18 USC $2255
+May of 2003 - Incident 1
+152. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+above.
+153. In May of 2003,
+•. again returned to JEFFREY EPSTEIN'S residence
+at his request. On this occasion, JEFFREY EPSTEIN directed |
+to fully undress
+and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the
+breasts and buttocks of the then minor
+At the conclusion of the massage,
+JEFFREY EPSTEIN masturbated himself in
+I's presence. JEFFREY EPSTEIN
+paid l
+65
+
+
+Entered on FLSD Docket 02/09/2009 Page 67 of 91
+156. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff,
+.., and as such he must effectively admit liability unto the
+Plaintiff,
+157. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff,
+.. will in
+the future suffer additional medical and psychological expenses. The Plaintiff,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff,
+., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff,
+., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+67
+
+
+Entered on FLSD Docket 02/09/2009 Page 69 of 91
+. vs. Epstein, et al.
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+161. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+United States Government.
+162.
+Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN; is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff,
+..and as such he must effectively admit liability unto the
+Plaintiff,
+163. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+., has in the past suffered, and will in the future suffer, physical injury, pain and
+69
+
+
+Case 9:08-Cv-80811-KAM Document 39
+
+Case No.: 08-CV-80811-CIV-MARRAJOHNSON
+165. In June of 2003, LI
+again returned to JEFFREY EPSTEIN'S
+residence at his request. On this occasion, JEFFREY EPSTEIN directed
+to fully
+undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled
+the breasts and buttocks of the then minor
+At the conclusion of the massage,
+JEFFREY EPSTEIN masturbated himself in i
+'s presence. JEFFREY EPSTEIN
+166. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+71
+
+
+
+158 No.: OB-Cin,O61 MARRAJOHNSON
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff,
+., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff,
+., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XXVI
+Cause of Action Pursuant to 18 USC $2255
+June of 2003 - Incident 2
+170. The Plaintiff,
+, adopts and realleges paragraphs 1 through 19
+above.
+171. For the second time in June of 2003, L
+again returned to JEFFREY
+EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed
+I to fully undress and to provide him with a massage. Defendant, JEFFREY
+EPSTEIN, fondled the breasts and buttocks of the then minor
+At the conclusion
+of the massage, JEFFREY EPSTEIN masturbated himself in
+'s presence.
+JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.
+
+
+Entered on FLSD Docket 02/09/2009 Page 75 of 91
+Case No.: 0B-CV- 0811-CIV-MARRAJOHNSON
+174. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, i, and as such he must effectively admit liability unto the
+Plaintiff,
+175. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+,, has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff,
+will in
+the future suffer additional medical and psychological expenses. The Plaintiff,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, L
+,, will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+
+
+
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+179. The Plaintiff,
+., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+United States Government.
+180. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff,
+..and as such he must effectively admit liability unto the
+Plaintiff,
+181. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+., has in the past suffered, and will in the future suffer, physical injury, pain and
+77
+
+
+
+1. vs. Epstein, et al.
+183. For the second time in July of 2003,
+• again returned to JEFFREY
+EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed
+to fully undress and to provide him with a massage. Defendant, JEFFREY
+EPSTEIN, fondled the breasts and buttocks of the then minor
+At the conclusion
+of the massage, JEFFREY EPSTEIN masturbated himself in
+.'s presence.
+JEFFREY EPSTEIN paid
+184. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+79
+
+
+Entered on FLSD Docket 02/09/2009 Page 81 of 91
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, |
+,, will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XXIX
+Cause of Action Pursuant to 18 USC $2255
+August of 2003 - Incident 1
+188. The Plaintiff,
+., adopts and realleges paragraphs 1 through 19
+above.
+189. In August of 2003,
+again returned to JEFFREY EPSTEIN'S
+residence at his request. On this occasion, JEFFREY EPSTEIN directed
+to fully
+undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled
+the breasts and buttocks of the then minor
+• At the conclusion of the massage,
+JEFFREY EPSTEIN masturbated himself in
+'s presence.
+JEFFREY EPSTEIN
+81
+
+
+Entered on FLSD Docket 02/09/2009 Page 83 of 91
+Case No.: 08-CV-80811-CIV-MARRAJJOHNSON
+192. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff,
+1, and as such he must effectively admit liability unto the
+Plaintiff,
+193. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+,, has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff,
+, will in
+the future suffer additional medical and psychological expenses. The Plaintiff, |
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, I
+.., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff,
+., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+83
+
+
+Entered on FLSD Docket 02/09/2009 Page 85 of 91
+Case No.: 08-CV-80811-CIV-MARRAIJOHNSON
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+197. The Plaintiff,
+, was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+United States Government.
+198. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff,
+and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+199. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+, has in the past suffered, and will in the future suffer, physical injury, pain and
+85
+
+
+Entered on FLSD Docket 02/09/2009 Page 87 of 91
+ase No: 0B-Ci-.O81-CIV-MARRNJOHNSON
+201. Between late May or early June of 2002 and August of 2003, Defendant,
+JEFFERY EPSTEIN, engaged in dozens of illegal and depraved sexual acts against
+Plaintiff, L
+202. As described more fully in the above paragraphs, Defendant, JEFFERY
+EPSTEIN, intentionally inflicted harmful and/or offensive sexual contact on the person of
+203. Defendant, JEFFREY EPSTEIN'S, tortuous commission of sexual battery
+upon
+- were done willfully and maliciously.
+204. As a direct and proximate result of JEFFREY EPSTEIN'S battery on
+, she has suffered and will continue to suffer severe and permanent traumatic
+injuries, including mental, psychological and emotional damages.
+WHEREFORE, the Plaintiff,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XXXII
+Conspiracy to Commit Tortious Assault Against Defendant, I
+205. Plaintiff incorporates into this count the allegations of paragraphs 1
+through 19.
+87
+
+
+Entered on FLSD Docket 02/09/2009 Page 89 of 91
+ase No: OB-Cin, 0811-CIV-MARRAJOHNSON
+self-esteem, loss of dignity, invasion of personal privacy and other damages associated
+with JEFFREY EPSTEIN'S controlling, manipulating, and coercing
+into a
+perverse and unconventional way of life for a minor. The then minor Plaintiff incurred
+medical and psychological expenses and the Plaintiff,
+., will in the future suffer
+additional medical and psychological expenses. The Plaintiff,
+has suffered a
+loss of income, a loss of the capacity to earn income in the future, and a loss of the
+capacity to enjoy life. These injuries are permanent in nature and the Plaintiff,
+will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff,
+, for compensatory damages of at least the minimum amount provided
+by law, punitive damages, attorney's fees, costs, and such other and further relief as
+this Court deems just and proper, and hereby demands trial by jury on all issues triable
+as of right by a jury.
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on the 9th day of February, 2009, I electronically filed
+the foregoing with the Clerk of the Court by using CM/ECF system, which will send a
+notice of electronic filing to all counsel of record on the attached service list.
+89
+
+
+
+1 vs. Epstein, et al
+case No.: OB-CV-80811-CIV-MARRA/JOHNSON
+irst Amended Complain
+age 91 of 9
+COUNSEL LIST
+Richard H. Willts, Esquire
+Richard H. Willits, P.A.
+2290 10th Avenue North, Suite 404
+Lake Worth, FL 33461
+Robert Critton, Esquire
+Burman Critton Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33414
+Jack A. Goldberger, Esquire
+Afterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South
+West Palm Beach, FL 33401
+Bruce E. Reinhart, Esquire
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue
+Suite 1400
+West Palm Beach, FL. 33401
+91
+
+
+CM/ECR - Live Database - flsd
+
+LRJ, MEDREQ, REF_DISCOV
+U.S. Distriet Court
+CIVIL DOCKET FOR CASE #: 9:08-cv-80893-KAM
+Date Filed: 08/13/2008
+Jury Demand: Plaintiff
+Nature of Suit: 360 P.L.: Other
+Jurisdiction: Federal Question
+Doe v. Epstein
+Assigned to: Judge Kenneth A. Marra
+Referred to: Magistrate Judge Linnea R. Johnson
+Lead case: 2:08-cv-80119-KAM
+Member case: (View Member Case)
+Case: 9:09-cv-80802-KAM
+Cause: no cause specified
+Plaintiff
+Jane Doe
+represented by Bradley James Edwards
+Rothstein Rosenfeldt Adler
+401 East Las Olas Blvd
+Suite 1650
+Ft. Lauderdale , FL 33301
+Email: L
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Paul G. Cassell
+Email: I
+PRO HAC VICE
+ATTORNEY TO BE NOTICED
+V.
+Defendant
+Jeffrey Epstein
+represented by Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+Fax: 835-8691
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?859999798355213-L_801_0-1
+
+
+
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Robert Deweese Critton, Jr.
+Burman Critton Luttier & Coleman
+Fax: 1
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Michael James Pike
+Burman Critton Luttier & Coleman
+Fax: 515-3148
+ATTORNEY TO BE NOTICED
+Amicus
+United States of America
+represented by
+United States Attorney's Office
+500 East Broward Blvd
+7th Floor
+Ft Lauderdale, FL 33394
+, ext. 3546
+Fax: 356-7336
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Date Filed
+#
+1
+clear Docket Text
+COMPLAINT against Jeffrey Epstein Filing fee $ 350. Receipt#: 724605,
+filed by Jane Doe.(rb) (Entered: 08/14/2008)
+2
+MOTION to Proceed Anonymously by Jane Doe. (rb) (Entered:
+2360 08/14/2008)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p1?859999798355213-L_801_0-1
+
+
+3
+• | MOTION to keep True Name in Sealed Envelope by Jane Doe. (rb)
+1193
+(Entered: 08/14/2008)
+4
+Summons Issued as to Jeffrey Epstein. (rb) (Entered: 08/14/2008)
+
+08/21/2008
+08/25/2008
+09/15/2008
+09/30/2008
+10/01/2008
+10/02/2008
+10/02/2008
+10/02/2008
+69.8
+KB
+5
+7
+8
+Sealed Document. (rb) (Entered: 08/14/2008)
+MOTION for Limited Appearance, Consent to Designation and Request to
+96.6| Electronically Receive Notices of Electronic Filing for Paul G. Cassell,
+Filing Fee $75, Receipt #724636. (cw) (Entered: 08/25/2008)
+ENDORSED ORDER granting Paul G. Cassell 6 Motion for Limited
+Appearance, Consent to Designation and Request to Electronically Receive
+Notices of Electronic Filings. Signed by Judge Kenneth A. Marra on
+8/25/08. (ir) (Entered: 08/25/2008)
+NOTICE of Attorney Appearance by Robert Deweese Critton, Ji on behalf
+1294 of Jeffrey Epstein (Critton, Robert) (Entered: 09/15/2008)
+ORDER TO RESPOND re 3 MOTION to keep True Name in Sealed
+Envelope filed by
+MOTION to Proceed Anonymously filed by
+Jane Doe. Responses due by T0/15/2008. Signed by Judge Kenneth A.
+Marra on 9/30/08. (ir) (Entered: 09/30/2008)
+MOTION FOR EXTENSTION OF TIME TO RESPOND to 1 Complaint
+Extension to Respond to Complaint and Require Plaintiff to File Rico filed
+459.6 by Jeffrey Epstein. (Attachments: # 1 Extension to Respond to Complaint
+and Require Plaintiff to File Rico)(Critton, Robert) Modified on 10/2/2008
+(ir). (Entered: 10/01/2008)
+Clerks Notice of Docket Correction and Instruction to Filer re 10
+RESPONSE/REPLY for Extension of Time filed by Jeffrey Epstein. Error -
+Wrong Event Selected; Correction - Redocketed by Clerk as MOTION for
+Extension of Time to Answer, Instruction to Filer - In the future, please
+select the proper event. It is not necessary to refile this document. (ir)
+11
+12
+13
+ENDORSED ORDER granting 10 Motion for Extension of Time to
+Answer Complaint. Jeffrey Epstein response due 10/10/2008. Plaintiff must
+file the Rule 12.1 Civil RICO statement by 10/3/08. Signed by Judge
+Kenneth A. Marra on 10/2/08. (ir) (Entered: 10/02/2008)
+RESPONSE to Motion re 2 MOTION to Proceed Anonymously filed by
+160.0 Jeffrey Epstein. Replies due by 10/14/2008, (Critton, Robert) (Entered:
+10/02/2008)
+NOTICE of Attorney Appearance by Jack Alan Goldberger on behalf of
+51.7
+Jeffrey Epstein (Goldberger, Jack) (Entered: 10/03/2008)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?859999798355213-L_801_0-1
+
+
+CM/ECF « Live Database - flsd
+KB
+
+14
+10/06/2008
+15
+10/10/2008
+16
+10/16/2008
+17
+10/27/2008
+18
+12/04/2008
+19
+12/10/2008
+20
+03/04/2009
+03/12/2009
+22
+NOTICE by Jane Doe of Filing Civil RICO Case Statement Pursuant to
+1.6
+MB
+Local Rule 12.1 (Attachments: # 1 Supplement Civil RICO Case Statement
+Pursuant to Local Rule 12.1)(Edwards, Bradley) (Entered: 10/03/2008)
+ORDER granting 2 Motion to Proceed Anonymously ; granting 3 Motion to
+Keep True Name in Sealed Envelope. The Clerk shall SEAL the true name
+affidavit of the Plaintiff. Signed by Judge Kenneth A. Marra on 10/6/08.
+(ir) (Entered: 10/06/2008)
+Defendant's MOTION to Dismiss 1 Complaint, MOTION for More
+Definite Statement, MOTION to Strike 1 Complaint by Jeffrey Epstein.
+Responses due by 10/30/2008 (Critton, Robert) (Entered: 10/10/2008)
+RESPONSE to Motion re 16 Defendant's MOTION to Dismiss 1
+Complaint MOTION for More Definite Statement MOTION to Strike 1
+Complaint filed by Jane Doe. Replies due by 10/27/2008. (Edwards,
+Bradley) (Entered: 10/16/2008)
+REPLY to Response to Motion re 16 Defendant's MOTION to Dismiss 1
+Complaint MOTION for More Definite Statement MOTION to Strike 1
+Complaint filed by Jeffrey Epstein. (Attachments: # 1 Order inl
+•(Critton, Robert) (Entered: 10/27/2008)
+SCHEDULING REPORT - Rule 26(f). (Critton, Robert) (Entered:
+482.7
+KB
+12/04/2008)
+ORDER Setting Trial Date & Discovery Deadlines, Referring Case to
+mediation & Referring Discovery Motions to United States Magistrate
+Judge. SCHEDULING ORDER: (Jury Trial set for 2/22/2010 in West
+Palm Beach Division before Judge Kenneth A. Marra., Calendar Call set
+for 2/19/2010 10:00 AM in West Palm Beach Division before Judge
+82.5
+KB
+Kenneth A. Marra., Amended Pleadings due by 2/2/2009., Discovery due
+by 10/1/2009., Pretrial Motions due by 10/20/2009), ORDER
+REFERRING CASE to Mediation. 15 days to appoint mediator., ORDER
+REFERRING CASE to Magistrate Judge Linnea R. Johnson for Discovery
+Proceedings. Signed by Judge Kenneth A. Marra on 12/10/2008. (tas)
+(Entered: 12/11/2008)
+Defendant's MOTION for Extension of Time to File Motions to Compel
+Directed to Plaintiff's Answers and Responses to discovery by Jeffrey
+Epstein. (Critton, Robert) (Entered: 03/04/2009)
+ORDER granting 21 Motion for Extension of Time to File Motion to
+Compel Directed to Plaintiff's Answers to Defendant's First Set of
+42.4
+Interrogatories and to Plaintiff's Response to Detendant'S First Kequest tor
+KB
+Production to on or before April 3, 2009. Signed by Magistrate Judge
+Linnea R. Johnson on 3/12/2009. (kza) (Entered: 03/12/2009)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|?859999798355213-L_801_0-1
+
+
+03/19/2009
+123
+
+03/26/2009
+24
+03/30/2009
+25
+04/01/2009
+29
+04/02/2009
+26
+04/02/2009
+27
+04/02/2009
+28
+04/09/2009
+30
+04/09/2009
+31
+04/09/2009
+32
+04/09/2009
+34
+04/13/2009
+33
+ORDER Setting Hearing on Motion 16 Defendant's MOTION to Dismiss 1
+Complaint MOTION for More Definite Statement MOTION to Strike 1
+56.8
+KB
+Complaint : Motion Hearing set for 4/1/2009 01:00 PM in West Palm
+Beach Division before Judge Kenneth A. Marra. Signed by Judge Kenneth
+A. Marra on 3/19/2009. (ir) (Entered: 03/19/2009)
+Defendant's MOTION to Stay re 1 Complaint by Jeffrey Epstein.
+| Responses due by 4/13/2009 (Attachments: # 1 Exhibit A, # 2 Exhibit B)
+(Pike, Michael) (Entered: 03/26/2009)
+Notice of Supplemental Authority re 16 Defendant's MOTION to Dismiss 1
+Complaint MOTION for More Definite Statement MOTION to Strike 1
+Complaint by Jeffrey Epstein (Pike, Michael) (Entered: 03/30/2009)
+Minute Entry for proceedings held before Judge Kenneth A. Marra: Motion
+Hearing held on 4/1/2009 re 16 Defendant's MOTION to Dismiss 1
+Complaint MOTION for More Definite Statement MOTION to Strike 1
+Complaint filed by Jeffrey Epstein. Court Reporter: Stephen Franklin,
+(ir) (Entered: 04/08/2009)
+ORDER granting 16 Motion to Dismiss; granting 16 Motion for More
+56.2
+Definite Statement; terminating 16 Motion to Strike. Signed by Judge
+Kenneth A. Marra on 4/2/2009. (ir) (Entered: 04/02/2009)
+Defendant's MOTION to Compel Response to Ist RIP by Jetfrey Epstein.
+440.3 | Responses due by 4/20/2009 (Attachments: # 1 Exhibit A)(Pike, Michael)
+KB
+(Entered: 04/02/2009)
+Defendant's MOTION to Compel Response to Ist Interrogs by Jeffiey
+210.0
+Epstein. Responses due by 4/20/2009 (Pike, Michael) (Entered:
+KB
+04/02/2009)
+"WRONG EVENT USED, RE-DOCKETED AS ENTRY 34 " NOTICE by
+Jane Doe of Change of Firm Affiliation (Edwards, Bradley) Modified on
+4/13/2009 (Is). (Entered: 04/09/2009)
+RESPONSE in Opposition re 24 Defendant's MOTION to Stay re 1
+Complaint filed by Jane Doe. (Edwards, Bradley) (Entered: 04/09/2009)
+MOTION to Strike Reference to Non Prosecution Agreement by Jane Doe.
+Responses due by 4/27/2009 (Edwards, Bradley) (Entered: 04/09/2009)
+NOTICE of Change of Address and Firm Affiliation by Bradley James
+Edwards [See Image at DE #30] (Is) (Entered: 04/13/2009)
+Clerks Notice of Docket Correction and Instruction to Filer re 30 Notice
+(Other) filed by Jane Doe. Error - Wrong Event Selected; Correction -
+Redocketed by Clerk as Notice of Change of Address. Instruction to Filer -
+In the future, please select the proper event. It is not necessary to refile this
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p1?859999798355213-L_801_0-1
+
+
+
+04/15/2009
+35
+04/15/2009
+36
+04/15/2009
+37
+38
+04/22/2009
+39
+04/23/2009
+40
+04/27/2009
+41
+04/27/2009
+42
+04/28/2009
+43
+04/29/2009
+44
+05/01/2009
+45
+document. (Is) (Entered: 04/13/2009)
+Defendant's MOTION to Compel Response to Defendant's First Set of
+Interrogatories by Jeffrey Epstein. Responses due by 5/4/2009
+1.8
+MB
+| (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit (Pike, Michael)
+(Entered: 04/15/2009)
+RESPONSE in Opposition re 27 Defendant's MOTION to Compel
+13.4
+Response to Ist RTP filed by Jane Doe. (Edwards, Bradley) (Entered:
+04/15/2009)
+RESPONSE in Opposition re 28 Defendant's MOTION to Compel
+25.3
+KB
+Response to Ist Interrogs filed by Jane Doe. (Edwards, Bradley) (Entered:
+04/15/2009)
+First AMENDED COMPLAINT, filed by Jane Doe. (Attachments: #1
+Exhibit A)(Edwards, Bradley) (Entered: 04/17/2009)
+Defendant's MOTION for Extension of Time to File Reply as to 31
+1451 Response in Opposition to Motion to Defendan's Motion ta Stay by Jeffrey
+Epstein. (Pike, Michael) (Entered: 04/22/2009)
+ENDORSED ORDER granting 39 Motion for Extension of Time to Reply
+re 24 Defendant's MOTION to Stay re 1 Complaint. Replies due by
+5/12/2009. Signed by Judge Kenneth A. Marra on 4/23/2009. (ir) (Entered:
+04/23/2009)
+| Defendant's MOTION for Extension of Time to File Reply as to 36
+150.6 | Response in Opposition to Motion to Compel Production of Tax Returns by
+KB
+Jeffrey Epstein. (Pike, Michael) (Entered: 04/27/2009)
+Defendant's MOTION for Extension of Time to File Reply as to 37
+153.4
+Response in Opposition to Motion tọ Compel Plaintiff to Respond to First
+KB
+Set Interrogatories by Jeffrey Epstein. (Pike, Michael) (Entered:
+04/27/2009)
+ORDER TO SHOW CAUSE why cases should not be consolidated for
+discovery purposes Show Cause Response due by 5/5/2009.. Signed by
+Judge Kenneth A. Marra on 4/28/2009. (cqs) (Entered: 04/29/2009)
+Defendant's MOTION for Extension of Time to File Response as to 32
+MOTION to Strike Reference to Non Prosecution Agreement or, in the
+141.6 alternative, to Lift Protective Order Barring Jane Doe's Attorney's from
+Revealing Provision in the Agreement by Jeffrey Epstein. (Pike, Michael)
+(Entered: 04/29/2009)
+ORDER Granting 41 Motion for Extension of Time in which to file reply in
+support of Motion to Compel Tax Records ; Granting 42 Motion tor
+Extension of Time to file reply in support of Motion to Compel Response
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl2859999798355213-L_801_0-1
+
+
+
+82.2 | to First set of Interrogatories; Granting 44 Motion for Extension of Time to
+Respond to Motion to Strike References to Non-Prosecution Agreement.
+Signed by Magistrate Judge Linnea R. Johnson on 5/1/2009. (sa) (Entered:
+05/01/2009)
+46
+REPLY to Response to Motion re 27 Defendant's MOTION to Compel
+Response to Ist RTP, 41 Defendant's MOTION for Extension of Time to
+8 File Reply as to 36 Response in Opposition to Motion to Compel
+Production of Tax Returns filed by Jeffrey Epstein. (Attachments: # 1
+Exhibit Exhibit A)(Pike, Michael) (Entered: 05/04/2009)
+47
+RESPONSE TO ORDER TO SHOW CAUSE by Jane Doe. (Edwards,
+2196
+Bradley) (Entered: 05/04/2009)
+48
+REPLY to Response to Motion 37 Response in Opposition to Motion to
+Compel Plaintiff to Respond to First Set Interrogatories, 35 Defendant's
+0.5
+MB
+MOTION to Compel Response to Defendant's First Set of Interrogatories
+filed by Jeffrey Epstein. (Attachments: # 1 Exhibit Exhibit A)(Pike,
+Michael) Modified link on 5/5/2009 (Ik). (Entered: 05/04/2009)
+49
+MEMORANDUM in Opposition re 43 Order to Show Cause by Jeffrey
+2733
+Epstein. (Pike, Michael) (Entered: 05/04/2009)
+50
+RESPONSE TO ORDER TO SHOW CAUSE by Jeffrey Epstein. See
+image DE 49 (Ik) (Entered: 05/05/2009)
+Clerks Notice of Docket Correction and Instruction to Filer re 49
+Memorandum in Opposition filed by Jeffrey Epstein. ERROR - Wrong
+Event Selected; Correction - Redocketed by Clerk as 50 RESPONSE TO
+ORDER TO SHOW CAUSE. Instruction to Filer - In the future, please
+select the proper event, UNDER OTHER
+ANSWERS/RESPONSES/REPLIES. It is not necessary to refile this
+document. (Ik) (Entered: 05/05/2009)
+52
+Defendant's MOTION for Extension of Time to File Response as to 38
+Amended Complaint by Jeffrey Epstein. (Critton, Robert) (Entered:
+05/05/2009)
+53
+ENDORSED ORDER granting 52 Motion for Extension of Time to
+Signed by mended Comph i. Marao petrin response dies: 85062009)
+05/12/2009
+54
+RESPONSE/REPLY to 31 Response in Opposition to Motion to Stay
+344.8 | and/or Continue Action for Time Certain by Jeffrey Epstein. (Pike,
+KB
+Michael) (Entered: 05/12/2009)
+05/13/2009
+55.
+SUPPLEMENT to 54 Response/Reply (Other) to Plaintiff's Response in
+80.8 | Opposition to Defendant's Motion to Stay and/or Continue Action by
+Jeffrey Epstein. (Pike, Michael) (Entered: 05/13/2009)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?859999798355213-L_801_0-1
+
+
+CM/ECE + Live Database - flsd
+
+56
+05/18/2009
+05/19/2009
+05/19/2009
+57
+58
+59
+60
+Cases associated. (dg) (Entered: 05/14/2009)
+ORDER CONSOLIDATING CASES. Hereinafter all motions and other
+court filings that relate to discovery and all procedural motions that relate to
+multiple cases shall be styled with all of the case names and numbers and
+106.5
+shall be filed in Case No. 08-80119-CIV-MARRA. Signed by Judge
+Kenneth A. Marra on 5/14/2009. Associated Cases: 9:08-cv-80119-KAM et
+al. (ir) (Entered: 05/14/2009)
+ORDER REQUESTING UNITED STATES PROVIDE POSITION TO
+MOTION TO STAY. Signed by Judge Kenneth A. Marra on 5/14/2009.
+(Attachments: # 1 Appendix Motion to Stay DE 51) Associated Cases:
+9:08-cv-80119-KAM et al. (ir) (Entered: 05/14/2009)
+ORDER terminating 24 Motion to Stay. Signed by Judge Kenneth A. Marra
+on 5/14/2009. (Ic3) (Entered: 05/14/2009)
+ORDER denying 32 Motion to Strike, without prejudice to re-file
+procedural motions relating to multiple cases in case no. 08-80119. See
+Order consolidating cases... Signed by Judge Kenneth A. Marra on
+5/14/2009. (lc3) (Entered: 05/14/2009)
+MOTION for Extension of Time to File Response to Plaintiff's first
+1259
+Amended Complaint by Jeffrey Epstein. (Pike, Michael) (Entered:
+61
+62
+63
+64
+ENDORSED ORDER granting 60 Motion for Extension of Time to
+Judge conch 4. Mart on 9i reso due ed: 00 grad by
+Defendant's MOTION to Strike Cases from Current Trial Docket by
+Jetfrey Epstein. Responses due by 6/8/2009 (Attachments: # 1 Exhibit A)
+| Associated Cases: 9:08-cv-80119-KAM et al.(Pike, Michael) (Entered:
+05/19/2009)
+ORDER terminating (93) Motion to Strike ; terminating (94) Motion in
+case 9:08-cv-80232-KAM; terminating (110) Motion to Strike ; terminating
+(111) Motion in case 9:08-cv-80380-KAM; terminating (95) Motion to
+Strike ; terminating (96) Motion in case 9:08-cv-80381-KAM; terminating
+(90) Motion to Strike ; terminating (91) Motion in case 9:08-cv-80811-
+KAM; terminating (62) Motion to Strike in case 9:08-cv-80893-KAM;
+terminating (62) Motion to Strike in case 9:08-cv-80993-KAM; terminating
+(50) Motion to Strike in case 9:08-cv-80994-KAM. Signed by Judge
+Kenneth A. Marra on 5/20/2009. (Ic3) (Entered: 05/20/2009)
+Clerks Notice of Docket Correction and Instruction to Filer re 62 MOTION
+to Strike filed by Jeffrey Epstein. Error - Motion with Multiple Reliets
+Filed as One Relief,. Instruction to filer - In the future, please select all
+applicable reliefs. It is not necessary to refile this document. (Is) (Entered:
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?859999798355213-L_801_0-1
+
+
+
+65
+66
+67
+68
+69
+70
+71
+05/20/2009)
+NOTICE by il
+•. of Filing Withdrawal of Previously Raised Obiections
+to Defendant, Jeffrey Epstein's Motion to Compel AndLOr Identify L
+in the Style of This Case and Motion to Identify
+in Third-Party
+3638
+Subpoenas for Purposes of Discovery, Or, Alternatively, Motion to Dismis
+Sua Sponte, With Inorporated Memorandum of Law Associated Cases:
+9:08-cv-80119-KAM et al.(Hill, Jack) (Entered: 05/20/2009)
+ORDER STRIKING in all Epstein cases EXCEPT case no. 08-80119:
+Notice by
+•. of Filing Withdrawal of Previously Raised Objections to
+Epstein's Motion to Compel and/or Identify. This Notice should only be
+filed in 08-80119, not in all of the Epstein cases.. Signed by Judge Kenneth
+A. Marra on 5/20/2009. Associated Cases: 9:08-cv-80119-KAM et al. (IC3)
+(Entered: 05/20/2009)
+Clerks Notice of Docket Correction and Instruction to Filer re 65 Notice
+(Other), Notice (Other) filed by
+... Error - Incorrect Document
+Link/No Link;. Instruction to filer - In the future, please link the document
+to the proper entry. It is not necessary to refile this document. (Is) (Entered:
+05/22/2009)
+NOTICE by Jane Doe re (111 in 9:08-cv-80119-KAM) Plaintiff's
+MOTION for Extension of Time to File Response as to (91 In 9:06-cv-
+80119-KAM) Defendant's MOTION to Compel Identity of Doe in Style of
+Case and Third-Party Subpoenas (replaces Docket entry 90) Plaintiff's
+52.0
+KB
+MOTION for Extension of Time to File Response as to (91 in 9:08-cv-
+80119-KAM) Defendant's MOTION to Compel Identity of Doe in Style of
+Case and Third-Party Subpoenas (replaces Docket entry 90) (Attachments:
+# 1 Text of Proposed Order)Associated Cases: 9:08-cv-80119-KAM et al.
+(Horowitz, Adam) (Entered: 05/27/2009)
+ORDER STRIKING Notice by Jane Doe in all Epstein cases EXCEPT in
+case 08-80119. This Notice should only be filed in 08-80119, not in all of
+the Epstein cases... Signed by Judge Kenneth A. Marra on 5/28/2009.
+Associated Cases: 9:08-cv-80119-KAM et al. (lc3) (Entered: 05/28/2009)
+NOTICE of Attorney Appearance by
+on behalf of
+United States of America Associated Cases: 9:08-Cv-80119-KAM et al.
+) (Entered: 05/29/2009)
+RESPONSE to Motion re (72 in 9:08-cv-80380-KAM) Defendant's
+MOTION to Stay re (62) Amended Complaint, (57 in 9:08-cv-80232-
+KAM) Defendant's MOTION to Stay re (50) Amended Complaint, (24 in
+9:08-Cv-80893-KAM) Defendant's MOTION to Stay re (1) Complaint, (23
+in 9:08-cv-80994-KAM) Defendant's MOTION to Stay re (18) Amended
+Complaint, (22 in 9:08-cv-80993-KAM) Defendant's MOTION to Stay re
+(19) Amended Complaint, (65 in 9:08-cv-80119-KAM) Defendant's
+37.7
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl7859999798355213-L_801_0-1
+
+
+
+KB
+MOTION to Stay re (56) Amended Complaint, (68 in 9:08-cv-80381-
+KAM) Defendant's MOTION to Stay re (60) Amended Complaint, (51 in
+9:08-cv-80811-KAM) Defendant's MOTION to Stay re (40) Amended
+Complaint and or Continue Action Filed Pursuant to Court's Order
+Requesting Government's Position filed by United States of America.
+replies due by 18/2009. Associated Cases: 9:08-cv-80119-KAM et al.
+D (Entered: 05/29/2009)
+72
+RESPONSE in Opposition re (90 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Compel Identify Doe in Style of Case and in Thira-Party
+Subpoenas, (91 in 9:08-cv-80119-KAM) Defendant's MOTION to Compel
+Identity of Doe in Style of Case and Third-Party Subpoenas (replaces
+Docket entry 90) filed by
+Associated
+Cases: 9:08-cv-80119-K AM et al.(Ezell, Katherine) (Entered: 05/29/2009)
+73
+ORDER STRIKING (124 in 9:08-cv-80119-KAM, 105 in 9:08-cv-80811-
+KAM, 74 in 9:08-cv-80993-KAM, 72 in 9:08-cv-80893-KAM, 106 in 9:08-
+cv-80232-KAM, 123 in 9:08-cv-80380-KAM, 35 in 9:09-cv-80591-KAM,
+25 in 9:09-cv-80469-KAM, 60 in 9:08-cv-80994-KAM, 22 in 9:09-cv-
+80656-KAM, 107 in 9:08-cy-80381-KAM) Response in Opposition to
+Motion, filed bi
+DO NOT FILE IN
+EVERY EPSTEIN CASE. SEE ORDER CONSOLIDATING CASES..
+Signed by Judge Kenneth A. Marra on 5/29/2009. Associated Cases: 9:08-
+cv-80119-KAM et al. (Ic3) (Entered: 05/29/2009)
+74
+MOTION for Leave to File UNDER SEAL RESPONSE IN OPPOSITION
+TO DEFENDANTS MOTION TO STAY OR, IN THE ALTERNATIVE. TO
+24.5
+UNSEAL THE NONPROSECUTION AGREEMENT by
+KB
+Associated Cases: 9:08-cv-80119-KAM et al.(Ezell,
+Katherine) (Entered: 05/29/2009)
+75
+MOTION for Hearing MOTION TO RESCHEDULE HEARING by J
+19.5
+KB
+Associated Cases: 9:08-cv-80119-KAM et
+al. (Josefsberg, Robert) (Entered: 05/29/2009)
+06/01/2009
+76
+ORDER STRIKING (28 in 9:09-cv-80469-KAM, 126 in 9:08-cv-80380-
+KAM, 109 in 9:08-cv-80232-KAM, 25 in 9:09-cv-80656-KAM, 77 in 9:08-
+cv-80993-KAM, 38 in 9:09-cv-80591-KAM, 110 in 9:08-cv-80381-KAM,
+63 in 9:08-Cv-80994-KAM, 75 in 9:08-cv-80893-KAM, 108 in 9:08-cv-
+80811-KAM) Motion to Continue Hearing filed by
+(76 in 9:08-cv-80993-KAM, 109 in 9:08-cv-80381-KAM,
+T08 in 9:08-cv-80232-KAM, 62 in 9:08-cv-80994-KAM, 125 in 9:08-cv-
+80380-KAM, 74 in 9:08-cv-80893-KAM, 24 in 9:09-cv-80656-KAM, 37 in
+9:09-cv-80591-KAM, 107 in 9:08-cv-80811-KAM, 27 in 9:09-cv-80469-
+KAM) Motion for Leave to File, filed by
+I THESE DOCUMENTS SHOULD BE FILED ONLY IN 08-80119.
+SEE CASE MANAGEMENT ORDER.. Signed by Judge Kenneth A.
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?859999798355213-L_801_0-1
+
+
+
+06/03/2009
+77
+78
+79
+06/08/2009
+06/08/2009
+06/08/2009
+80
+81
+82
+83
+84
+Marra on 6/1/2009. (Ic3) (Entered: 06/01/2009)
+Defendant's MOTION for Extension of Time to File Response as to 38
+Amended Complaint Unopposed by Jeffrey Epstein. (Attachments: # 1 Text
+of Proposed Order Order)(Pike, Michael) (Entered: 06/03/2009)
+ENDORSED ORDER granting 77 Motion for Extension of Time to
+Answer First Amended Complaint. Jeffrey Epstein response due 6/10/2009.
+Signed by Judge Kenneth A. Marra on 6/4/2009. (ir) (Entered: 06/04/2009)
+REPLY to Response to Motion re (113 in 9:08-cv-80119-KAM) Plaintiff's
+MOTION Plaintiffs
+Motion for No-
+Contact Order Plaintiffs
+Reply
+349.0
+to Defendant Jeffrey Epstein's Response to Plaintiff
+KB
+Motion for a No-Contact Order filed byl
+Associated Cases: 9:08-cv-80119-KAM et al.
+(Ezell, Katherine) (Entered: 06/04/2009)
+ORDER STRIKING (112 in 9:08-cv-80381-KAM, 111 in 9:08-cv-80232-
+KAM, 136 in 9:08-cv-80119-KAM, 111 in 9:08-cv-80811-KAM, 128 in
+9:08-CV-80380-KAM, 65 in 9:08-cv-80994-KAM, 79 in 9:08-cv-80893-
+KAM, 42 in 9:09-cv-80591-KAM, 27 in 9:09-cv-80656-KAM, 32 in 9:09-
+cv-80469-KAM, 79 in 9:08-cv-80993-KAM) Reply to Response to Motion,
+Document stricken for failure
+to follow Court's orders. DO NOT FILE A DOCUMENT IN EVERY
+EPSTEIN CASE if it is to be filed only in 08-80119. See Case Management
+Order and contact CM/ECF Support for assistance in proper filing.. Signed
+by Judge Kenneth A. Marra on 6/4/2009. Associated Cases: 9:08-cv-80119-
+KAM et al. (lc3) (Entered: 06/04/2009)
+| Defendant's MOTION for Extension of Time to File Response as to 38
+Amended Complaint by Jeffrey Epstein. (Attachments: # 1 Text of
+Proposed Order)(Pike, Michael) (Entered: 06/08/2009)
+RESPONSE to Motion re (91 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Compel Identity of Doe in Style of Case and Third-Party
+3.8
+Subpoenas (replaces Docket entry 90) filed by Jane Doe. Replies due by
+MB
+6/18/2009. (Attachments: # 1 Exhibit A, # 2 Exhibit B)Associated Cases:
+9:08-cv-80119-KAM et al.(Horowitz, Adam) (Entered: 06/08/2009)
+NOTICE by Jane Doe re (113 in 9:08-cv-80119-KAM) Plaintiff's
+MOTION Plaintiffs
+Motion for No-
+Contact Order -Plaintiffs
+Notice of Joinder Associated
+Cases: 9:08-cv-80119-KAM et al.(Horowitz, Adam) (Entered: 06/08/2009)
+ENDORSED ORDER granting 81 Motion for Extension of Time to
+Signed A edged Conch i. Matto prin 9 or dered 02002009)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|?859999798355213-L_801_0-1
+
+
+185
+
+or
+Download Selected
+Clerks Notice of Docket Correction and Instruction to Filer re 83 Notice
+(Other), Notice (Other) filed by Jane Doe. Error - Wrong Event Selected;:
+Instruction to Filer - In the future, please select the proper event, i.e. Notice
+of Adoption. It is not necessary to refile this document. (Is) (Entered:
+06/10/2009)
+Total filesize of selected documents (MB): | .
+Maximum filesize allowed (MB): 10
+PACER
+Login:
+Description:
+Billable
+Pages:
+PACER Service Center
+Transaction Receipt
+06/10/2009 13:53:26
+du4480
+Client Code:
+Docket
+Report
+7
+Search
+Criteria:
+Cost:
+9:08-cv-80893-
+KAM
+10.56
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|?859999798355213-L_801_0-1
+
+
+1. Need a New Encase Image OF file folder
+11A-51-2-2, •E35 has missing/and or
+Corrupied files.
+
+
+Entered on FLSD Docket 04/20/2009
+
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+IN THE UNITED STATES DISTRICT COURT
+FOR THE SOUTHERN DISTRICT OF FLORIDA
+09-80591
+Civil Action No.
+CIV-MARRA
+FEAR ASS
+MAGISTRATE JUDGE
+APR 17 2009
+JOHNSON
+STEVENS OT
+S.D. OF FLA. MIAMI
+COMPLAINT AND
+DEMAND FOR JURY TRIAL
+COMPLAINT AND DEMAND FOR JURY TRIAL
+brings this Complaint against Defendant,
+Plaintiff,
+Jeffrey Epstein, and states as follows:
+PARTIES, JURISDICTION, AND VENUE
+1.
+At all times material to this cause of action, Plaintiff, Jane Doe, was a resident of
+Palm Beach County, Florida.
+2. This Complaint is hrought under a fictitious name to protect the identity of
+Plaintiff, Jane Doe, because this Complaint makes sensitive allegations of sexual assault and
+abuse of a then minor.
+3.
+At all times material to this cause of action, Defendant, Jeffrey Epstein, had a
+residence located at 358 El Brillo Way, West Palm Beach, Palm Beach County, Florida.
+4.
+Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he is
+currently incarcerated in the Palm Beach County Stockade.
+5.
+At all times material to this cause of action, Defendant, Jeffrey Epstein, was an
+adult male born in 1953.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami|
+
+
+Entered on FLSD Docket 04/20/2009 Page 2 of 19
+6.
+This Court has jurisdiction of this action and the claims set forth herein pursuant
+to 18 U.S.C. § 2255.
+7. This Court has venue of this action pursuant to 28 U.S.C. § 1391(a), as a
+substantial part of the events giving rise to the claim occurred in this District.
+STATEMENT OF FACTS
+8.
+At all relevant times, Defendant, Jeffrey Epstein, was an adult male,
+approximately 50 years old. Epstein is known as a billionaire financier and money manager with
+a secret clientele limited exclusively to billionaires. He is a man of tremendous wealth, power,
+and influence. He owns a fleet of aircraft that includes a Gulfstream IV, a helicopter, and a
+Boeing 727. Until his incarceration, he maintained his principal place of residence in the largest
+home in Manhattan, a 51,000-square-foot eight-story mansion on the Upper East Side. Upon
+information and belief, he also owns a $6.8 million mansion in Palm Beach, Florida, a $30
+million 7,500-acre ranch in New Mexico he named "Zorro," and a 70-acre private island known
+as Little St. James in St. Thomas, U.S. Virgin Islands. The allegations herein concern
+Defendant's conduct while at his lavish estate in Palm Beach.
+9.
+Upon information and belief, Defendant has a sexual preference for underage
+minor girls. He engaged in a plan, scheme, or enterprise in which he gained access in his home
+to countless relatively economically disadvantaged minor girls, sexually assaulted or molested
+these girls, and then gave them money.
+10. Beginning in or around 2001 through in or around September 2007, Defendant
+used his resources and his influence over vulnerable minor children to engage in a systematic
+pattern of sexually exploitative behavior.
+11.
+Defendant's plan and scheme reflected a particular pattern and method.
+Defendant coerced and enticed impressionable, vulnerable, and relatively economically less
+2
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami
+IM • Fort Lauderdale I
+
+
+Entered on FLSD Docket 04/20/2009 Page 3 of 19
+fortunate minors to participate in various acts of sexual misconduct that he committed upon
+them. Defendant's scheme involved the use of underage girls as well as other individuals to
+recruit other underage girls. Upon information and belief, Defendant or an authorized agent
+would call and alert Defendant's assistants shortly before or after he arrived at his Palm Beach
+residence. His assistants would seek out economically disadvantaged and underage girls from
+West Palm Beach and surrounding areas who would be enticed by the money being offeredgenerally $200 to $300 per "massage" session—and who Defendant and/or his assistants
+perceived as less likely to complain to authorities or have credibility issues if allegations of
+improper conduct were made. The then minor Plaintiff and other minor girls, some as young as
+14 years old, were transported to Defendant's Palm Beach county mansion by Defendant's
+employees, agents, and/or assistants in order to provide Defendant with "massages."
+Defendant would pay the procurer of each girl's "appointment" approximately
+$200. Many of the instances of illegal sexual conduct committed by Defendant were perpetrated
+with the assistance, support, and facilitation of at least three assistants who helped him
+orchestrate this child exploitation enterprise. These assistants would often arrange times for
+underage girls to come to Defendant's residence, transport or cause the transportation of
+underage girls to Defendant's residence, escort the underage girls to the massage room where
+Defendant would be waiting or would enter shortly thereafter, urge the underage girls to remove
+their clothes, deliver cash from Defendant to the underage girls and/or their procurers at the
+conclusion of each "massage appointment," and, upon information and belief, take nude
+photographs and/or videos of the underage girls' for Defendant without their knowledge.
+Epstein designed the scheme to secure a private place in Defendant's mansion
+where only persons employed and invited by Epstein would be present, so as to reduce the
+chance of detection of Defendant's sexual abuse and prostitution as well as to make it more
+3
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami l
+I • Fort Lauderdale l
+
+
+Entered on FLSD Docket 04/20/2009 Page 4 of 19
+difficult for the minor girls to flee the premises and/or to credibly report his actions to law
+enforcement or other authorities. The girls were usually transported by his employees, agents,
+and/or assistants or by a taxicab paid for by Defendant in order to make it difficult for the girls to
+flee his mansion.
+14. Upon arrival at Defendant's mansion, each underage victim would generally be
+introduced to one of Defendant's assistants, who would gather the girl's personal contact
+information. The minor girl would then be led up a flight of stairs to a room that contained a
+massage table and a large shower. The staircase leading to the room was plastered with nude
+photographs of young girls, including some photographs depicting two or more young girls
+engaged in lewd acts. Upon information and belief, Defendant, Jeffrey Epstein, had such
+photographs in each of his four homes and on his computer.
+15.
+At times, if it was the girl's first "massage" appointment, another female would
+be in the room to "lead the way" until Defendant would have her leave. Generally, Defendant
+would start his massage wearing only a small towel, which eventually would be removed.
+Defendant would direct the girl to massage him, giving her specific instructions as to where and
+how he wanted to be touched, and then direct her to remove her clothing. He would then
+perform one or more lewd, lascivious, and sexual acts, including masturbation, fondling the
+minor's breasts and/or sexual organs, touching the
+with a li
+and/or
+her
+performing
+and/or coercing or attempting to coerce the girl to engage in lewd acts and/or prostitution. The
+exact degree of molestation and frequency with which the sexual crimes took place varied and is
+not yet completely known; however, at least when Defendant was in Palm Beach, Florida, such
+acts occurred usually on a daily basis and, in most instances, several times a day.
+Podhurst Orseck, P.A.
+4
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami MINI
+M Fax HAMAMA • Fort Lauderdale MEL
+
+
+Entered on FLSD Docket 04/20/2009 Page 5 of 19
+16.
+As previously stated in paragraph 14, Defendant displayed nude photographs of
+underage girls throughout his homes in New York, Palm Beach, New Mexico, and the U.S.
+Virgin Islands.
+Upon information and belief, some of the photographs in the possession of
+Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the
+day of his arrest, police found two hidden cameras and photographs of underage girls on a
+computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may
+have taken lewd photographs of Plaintiff, Jane Doe, with his hidden cameras and may have
+transported lewd photographs of Plaintiff (among many other victims) to his other residences and
+elsewhere using a facility or means of interstate commerce.
+17.1
+Consistent with the foregoing plan and scheme, Defendant used his money,
+wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff.
+Plaintiff, Jane Doe, was recruited by one of Defendant's agents to give Defendant a massage for
+compensation.
+Plaintiff was apprehensive, but needed the money and finally agreed to go.
+Plaintiff was first brought to Defendant's mansion in or about the spring of 2003, when she was
+merely 17 years old and in high school. Epstein's procurer drove her to Jeffrey Epstein's
+mansion. Plaintiff was led up a flight of stairs by a blonde woman to a spa room with a shower
+and a massage table, where she was left alonc. A woman with dark hair, an accent, and naked
+from the waist up entered and tried to coax Plaintiff to remove her shirt, but Plaintiff refused.
+After the woman showed Plaintiff how to use the lotions that were there, the woman left.
+Defendant walked in wearing only a small towel. He lay down on the massage table still
+wearing the small towel, and Plaintiff began to massage his shoulders and neck. Nervously, she
+asked him what he did for a living. Defendant responded that he was a scientist. Defendant
+asked Plaintiff what year she would graduate high school, to which Plaintiff honestly replied that
+she would graduate in 2004. Plaintiff massaged Defendant's lower back and calves. Defendant
+Podhurst Orseck, P.A.
+5
+25 West Flagler Street, Suite 800, Miami, FL. 39130, Miami
+IMMI - Fort Lauderdale I
+
+
+Entered on FLSD Docket 04/20/2009 Page 6 of 19
+told her to remove his towel. Defendant told her that he had just worked out and wanted his
+buttocks massaged. Although disgusted, she was afraid to refuse and did it. At some point,
+Defendant ordered Plaintiff to remove her clothes. In shock, fear, and trepidation, Plaintiff partly
+complied, removing only her shirt and bra. When Defendant turned over, Plaintiff was afraid
+and embarrassed and she wanted to leave. Defendant repeatedly told her to relax and
+complimented her, saying that she had a nice body. Defendant then pulled Plaintiff closer to
+him. He began masturbating and then began fondling her breasts. He asked her to do more and
+mentioned more money, which she adamantly declined. Defendant continued masturbating until
+he ejaculated. Plaintiff next recalls that she received $200 and was transported by the procurer,
+whom she later learned received $200 for having brought her to Epstein's mansion.
+Defendant thereafter lured the then minor Plaintiff to the Epstein mansion on at
+18.
+least one and perhaps two other occasions in the spring and/or summer of 2003. The procurer
+made another appointment for her to return, but Plaintiff didn't want to see Defendant. By
+having his assistants continue to contact Plaintiff and attempt to lure her to the mansion for other
+sexual acts, Defendant engaged in a continuous course of conduct that injured Plaintiff upon
+each instance of contact and/or abuse.
+19.
+In addition to the direct sexual abuse and molestation of the then minor Plaintiff,
+Defendant used his money, wealth, and power to unduly and improperly manipulate and
+influence the then minor Plaintiff to bring him another minor girl in a promised exchange for
+money. Rather than go herself, Plaintiff and the procurer took another girl there one time.
+20.
+As a result of these encounters with Defendant, Plaintiff, Jane Doe, has in the past
+suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
+6
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami THI
+I • Fort Lauderdale L
+
+
+Entered on FLSD Docket 04/20/2009 Page 7 of 19
+other damages associated with Defendant's controlling and manipulating her into a perverse and
+unhealthy way of life.
+21.
+Any assertions by Defendant that he was unaware of the age of the then minor
+Plaintiff are belied by her telling him her high school graduation year, as well as his own actions,
+and are rendered irrelevant by the provision of applicable federal statutes concerning the sexual
+exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this
+cause of action, knew and should have known of Plaintiff's age of minority. In fact, his
+preference for underage girls was well-known to those who regularly procured them for him.
+22.
+Defendant, Jeffrey Epstein, committed the above-referenced acts upon the then
+minor Plaintiff in violation of federal statutes condemning the coercion and enticement of a
+minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual
+conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual
+depictions of a minor engaging in sexually explicit conduct, transport of child pornography, child
+exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes
+designated in 18 U.S.C. § 2422(b), § 2423(b), § 2423(e), § 2251, § 2252, § 2252A(a)(1), §
+2252A(g)(1), and § 1591.
+23.
+After investigations by the Palm Beach Police Department, the Palm Beach State
+Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's Office
+for the Southern District of Florida, Defendant, Jeffrey Epstein, entered pleas of "guilty" to
+various Florida state crimes involving the solicitation of minors for prostitution and the
+procurement of minors for the purposes of prostitution in June 2008 in the Fifteenth Judicial
+Circuit in Palm Beach County, Florida. Defendant, Jeffrey Epstein, is in the same position as if
+he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such,
+Podhurst Orseck, P.A.
+7
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax ||
+HE • Fort Laaderdale
+
+
+Entered on FLSD Docket 04/20/2009 Page 8 of 19
+must admit liability unto Plaintiff, Jane Doe. Plaintiff hereby exclusively seeks civil remedies
+pursuant to 18 U.S.C. § 2255.
+COUNT ONE
+(Cause of Action for Coercion and Enticement of Minor to Engage in Prostitution or
+Sexual Activity pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2422(b))
+24.
+Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by
+reference the allegations contained in paragraphs 1 through 23 above.
+25.
+Defendant, Jeffrey Epstein, used a facility or means of interstate commerce to
+knowingly persuade, induce, or entice Jane Doe, when she was under the age of 18 years, to
+engage in prostitution and/or sexual activity for which any person can be charged with a criminal
+offense pursuant to 18 U.S.C. § 2255 in violation of 18 U.S.C. § 2422(b).
+26.
+Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C.
+§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
+Section of the United States Code.
+27.
+As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
+other damages associated with Defendant's manipulating and leading her into a perverse and
+unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
+and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
+capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
+suffer these losses in the future.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Sulte 800, Miami, FL 33130, Miami HI
+8
+HI • Fort Lauderdale
+
+
+Entered on FLSD Docket 04/20/2009 |
+
+WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
+Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual
+and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
+Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
+a jury.
+COUNT TWO
+(Cause of Action for Travel with Intent to Engage in Illicit Sexual Conduct pursuant to 18
+U.S.C. $ 2255 in Violation of 18 U.S.C. § 2423(b))
+28.
+Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by
+reference the allegations contained in paragraphs 1 through 23 above.
+29.
+Upon information and belief, Defendant, Jeffrey Epstein, traveled in interstate
+commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. §
+2423(f), with minor females, in violation of 18 U.S.C. § 2423(b).
+30.
+Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C.
+§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
+Section of the United States Code.
+31.
+As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
+other damages associated with Defendant's manipulating and leading her into a perverse and
+unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
+and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has
+suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
+9
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami 305,358.2800 Fax
+_ • Fort Lauderdale
+
+
+Entered on FLSD Docket 04/20/2009 Page 10 of 19
+capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
+suffer these losses in the future.
+WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffiey
+Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual
+and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
+Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
+a jury,
+COUNT THREE
+(Cause of Action for Sex Trafficking of Children pursuant to 18 U.S.C. § 2255 in Violation
+of 18 U.S.C. § 1591(a))
+32.
+Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by
+reference the allegations contained in paragraphs 1 through 23 above.
+33.
+Defendant, Jeffrey Epstein,
+knowingly, in or affecting interstate or foreign
+commerce, recruited, enticed, and obtained Plaintiff, Jane Doe, knowing that she had not attained
+the age of 18 years and would be caused to engage in a commercial sex act as defined in 18
+U.S.C. § 1591(c)(1), in violation of 18 U.S.C. § 1591(a)(1).
+34. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C.
+§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
+Section of the United States Code.
+35.
+As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
+other damages associated with Defendant's manipulating and leading her into a perverse and
+Podhurst Orseck, P.A.
+10
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami
+• • Fort Lauderdale
+
+
+Entered on FLSD Docket 04/20/2009 Page 11 of 19
+unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
+and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
+capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
+suffer these losses in the future.
+WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
+Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual
+and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
+Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
+a jury.
+COUNT FOUR
+(Cause of Action for Sexual Exploitation of Children pursuant to 18 U.S.C. § 2255 in
+Violation of 18 U.S.C. § 2251)
+36.
+Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by
+reference the allegations contained in paragraphs 1 through 23 above.
+37.
+Defendant, Jeffrey Epstein, knowingly induced, enticed, or coerced then minor
+Plaintiff Jane Doe to engage in sexually explicit conduct for the purpose of producing a visual
+depiction of such conduct in violation of 18 U.S.C. § 2251. As previously stated in paragraphs
+14 and 16, Defendant displayed a myriad of photographs of underage girls throughout his homes
+in New York, Palm Beach, New Mexico, and the U.S. Virgin Islands. Upon information and
+belief, many of the photographs in the possession of Defendant were taken with hidden cameras
+set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden
+cameras and photographs of underage girls on a computer in Defendant's home. Upon
+information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of
+Plaintiff, Jane Doe, with his hidden cameras and may have transported lewd photographs of
+Podhurst Orseck, P.A.
+11
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale
+
+
+Entered on FLSD Docket 04/20/2009 Page 12 of 19
+Plaintiff (among many other victims) to his other residences and elsewhere using a facility or
+means of interstate commerce.
+38.
+Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C.
+§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
+Section of the United States Code.
+39.
+As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
+other damages associated with Defendant's manipulating and leading her into a perverse and
+unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
+and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
+capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
+suffer these losses in the future.
+WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
+Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual
+and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
+Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
+a jury.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Sulte 800, Miami, FL. 33130, Miami |
+• • Fort Lauderdale
+
+
+Entered on FLSD Docket 04/20/2009 Page 13 of 19
+COUNT FIVE
+(Cause of Action for Transport of Visual Depiction of Minor Engaging in Sexually Explicit
+Conduct pursuant to 18 U.S.C. $ 2255 in Violation of 18 U.S.C. $ 2252(a)(1))
+40.
+Plaintiff, Jane Doc, hereby adopts, repeats, realleges, and incorporates by
+reference the allegations contained in paragraphs 1 through 23 above.
+41.
+Defendant, Jeffrey Epstein, knowingly mailed, transported, or shipped in
+interstate or foreign commerce child pornography in violation of 18 U.S.C. § 2252(1). As
+previously stated in paragraphs 14, 16, and 37, upon information and belief, Defendant displayed
+a myriad of photographs of underage girls throughout his homes in New York, Palm Beach, New
+Mexico, and the U.S. Virgin Islands. Upon information and belief, many of the photographs in
+the possession of Defendant were taken with hidden cameras set up throughout his home in Palm
+Beach. On the day of his arrest, police found two hidden cameras and photographs of underage
+girls on a computer in Defendant's home. Upon information and belief, Defendant, Jefficy
+Epstein, may have taken lewd photographs of Plaintiff, Jane Doe, with his hidden cameras and
+may have transported lewd photographs of Plaintiff (among many other victims) to his other
+residences and elsewhere using a facility or means of interstate commerce.
+42.
+As previously stated in paragraph 21, any assertions by Defendant that he was
+unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by
+the provision of applicable federal and state statutes concerning the sexual exploitation and abuse
+of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew
+and should have known of Plaintiff's age of minority. In fact, his preference for underage girls
+was well-known to those who regularly procured them for him.
+43.
+Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C.
+§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
+Section of the United States Code.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami
+13
+
+
+Entered on FLSD Docket 04/20/2009 Page 14 of 19
+44.
+As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
+other damages associated with Defendant's manipulating and leading her into a perverse and
+unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
+and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
+capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
+suffer these losses in the future.
+WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
+Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual
+and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
+Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
+a jury.
+COUNT SIX
+(Cause of Action for Transport of Child Pornography pursuant to 18 U.S.C. § 2255 in
+Violation of 18 U.S.C. $ 2252A(a)(1))
+45.
+Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by
+reference the allegations contained in paragraphs 1 through 23 above.
+46.
+Defendant, Jeffrey Epstein, knowingly mailed, transported, or shipped in
+interstate or foreign commerce child pornography in violation of 18 U.S.C. § 2252A(a)(1).
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800, Miami, F1. 33130, Miami |
+14
+www..podhurst.com
+
+
+Entered on FLSD Docket 04/20/2009 Page 15 of 19
+47.
+Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C.
+§ 2255, and, as such asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
+Section of the United States Code.
+Defendant, Jeffrey Epstein, is in the same position as if he had been tried and
+convicted of the sexual offenses committed against Plaintiff and, as such, must admit liability
+unto Plaintiff, Jane Doe.
+49.
+As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
+other damages associated with Defendant's manipulating and leading her into a perverse and
+unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
+and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
+capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
+suffer these losses in the future.
+WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
+Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual
+and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
+Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
+a jury.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami
+15
+I • Fort Lauderdale
+
+
+Entered on FLSD Docket 04/20/2009 Page 16 of 19
+COUNT SEVEN
+(Cause of Action for Engaging in a Child Exploitation Enterprise pursuant to 18 U.S.C.§
+2255 in Violation of 18 U.S.C. § 2252A(g))
+50.
+Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by
+reference the allegations contained in paragraphs 1 through 23 above.
+51.
+Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise,
+as defined in 18 U.S.C. § 2252A(g)(2), in violation of 18 USC § 2252A(g) (1). As more fully set
+forth above in paragraphs 9 through 19, Defendant's actions involved countless victims and
+countless incidents of abuse, and he committed those offenses against minors in concert with at
+least three other persons.
+52.
+Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C.
+§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
+Section of the United States Code.
+53.
+As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
+other damages associated with Defendant's manipulating and leading her into a perverse and
+unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
+and Plaintiff will in the future suffer additional medical and psychological expenses.
+Plaintiff
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
+capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
+suffer these losses in the future.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami
+16
+
+
+Entered on FLSD Docket 04/20/2009
+
+WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
+Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual
+and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
+Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
+a jury.
+Date: April 17, 2009
+Robert C. Josefsberg, Bar No. 040856
+Katherine W. Ezell, Bar No. 114771
+'odhurst Orseck, P.A.
+5 West Flagler Street, Suite 800
+Miami, Florida 33130
+(fax)
+Attorneys for Plaintiff
+DEMAND FOR JURY TRIAL
+Plaintiff demands to have her case tried before a jury.
+Robert Josefsberg, Bar No. 040836
+Katherine W. Ezell, Bar No. 114771
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami. Florida 33130
+(fax)
+riosefsberg@podhurst.com
+kezell@podhurst.com
+Attorneys for Plaintiff
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite B00, Miami, FL 33130, Miami
+
+
+Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 18 of 19
+QJS 44 (Rev. 11/05)
+CIVIL COVER SHEET
+The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filling and service of pleadings or other papers as required by law, excepi as provide
+by local rules of court. This fonn, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiatin
+the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)
+NOTICE: Attorneys MUST Indicate All Re-filed Cases Below.
+LaL PLAINTIEES
+DEFENDANTS
+Jeffrey Epstein
+(b) County of Residence of First Listed Plaintiff
+West Palm Beach
+(EXCEPT IN U.S. PLAINTIFF CASES)
+(c) Attorney's (Firm Name, Address, and Telephone Number)
+Robert C. Josefsberg, Esq./Katherine W. Ezell, Esq.
+County of Residence of First Listed Defendant
+(IN U.S. PLAINTIFF CASINTAKE
+FIND 495 007
+NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT
+LAND INVOLVED.
+APR 1 7 2009
+25 W. Flagler St., Suite 800
+Jack A. Goldberger, Esq, Atterbury Goldbergaku a 021С
+11171 09-CV-80591 - Marra/SShne
+ash Australian Ave., #1400, West Palm Beach, PD. 05Eamsehhert P.m
+(d) Check County Where Action Arose: MIAMI-DADE MONROEO BROWARD A PALM BEACH O MARTIN OST.LUCIEO INDIAN RIVER O OKEECHOBEE
+HIGHLANDS
+II. BASIS OF JURISDICTION (Place an "*" in One Box Only)
+II. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" in One Box for PlaintifT
+(For Diversity Cases Only)
+and One Box for Defendant)
+• | U.S. Covement
+Plaintiff
+O 3 Foderal Question
+(U.S. Goverment Not a Party)
+PTF
+DEF
+DEF
+Citizen of This Stale
+1 1
+Incorporuled or Principal Place
+of Business In This Stale
+O2 U.S. Goverment
+Defendant
+0 4
+Diversity
+Citizen of Another State 0
+2
+• 2 Incorporated and Principal Place
+0 5 05
+of Business In Another State
+(Indicate Citizenship of Partics in Iiem I!!)
+Citizen or Subject ofa O 3 O 3 Foreign Nation
+Foreign Country
+• 6 06
+IV. NATURE OF SUIT (Place an "X" in One Box Only)
+CONTRACT
+TARTS
+• 110 Insurance
+PERSONAL INJURY
+• 120 Marine
+• 310 Airplane
+• 130 Miller Act
+O 315 Airplane Product
+• 140 Negotiable Instrument
+Liability
+• 150 Recovery of Overpayment
+• 320 Assault, Libel &
+& Enforcement of Judgment
+Slander
+• 151 Medicare Act
+O.330 Federal Employers'
+• 152 Recovery of Defaulted
+Liability
+Student Loans
+• 340 Marine
+(Excl, Veterans)
+• 345 Marine Product
+• 153 Recovery of Overpayment
+Liability
+of Veteran's Benefits
+• 350 Molor Vehicle
+• 160 Stockholders" Suits
+• 355 Motor Vehick
+190 Other Contract
+Product Lisbility
+• 195 Contract Product Liability
+IS 360 Other Personal
+O. 196 Franchise
+Injury
+REAL PROPERTY
+CIVIL RIGHTS
+C 210 Land Condemnation
+• 441 Voting
+• 220 Foroclosure
+O 442 Employnsent
+• 230 Rent Lease & Ejectment
+0443 Housing/
+• 240 Torts to Land
+Accommodations
+• 245 Ton Product Liability
+• 444 Welfare
+• 290 All Other Real Property
+• 445 Amer. w/Disabilities -
+Employment
+O 446 Amer, w/Disabilities-
+Other
+O 440 Other Civil Rights
+PERSONAL INJURY
+362 Personal Injury -
+Med. Malpractice
+365 Personal Injury -
+Product Liability
+368 Asbestos Personal
+Injury Product
+Liability
+PERSONAL PROPERTY
+370 Other Fraud
+371 Truth in Lending
+380 Other Personal
+Property Damage
+385 Property Demage
+Product Liability
+FORFEITURE/PENALTY
+610 Agriculture
+620 Other Food & Drug
+625 Drug Related Seizure
+of Property 21 USC 88I
+630 Liquor Laws
+640 R.R. & Truck
+650 Airline Regs.
+660 Occupational
+Safety/Health
+690 Other
+TARTE
+710 Fair Labor Standards
+Act
+720 Laboe Mgmt. Relations
+730 Labor/Mgmi. Reporting
+& Disclosure Act
+740 Railway Labor Act
+790 Other Labor Litigation
+791 Finpl. Ret. Inc.
+Security Act
+BANKRUPICY
+• 422 Appeal 28 USC 158
+• 423 Wihdrawal
+28 USC 157
+PROPERTY REMINA
+• 820 Copyrights
+• 830 Patent
+• 840 Trademark
+PRISONER PETTIONS
+510 Motions to Vacate
+Science
+Habeas Corpus:
+530 General
+535 Death Penalty
+540 Mandamus & Other
+550 Civil Rights
+555 Prison Condition
+SOCIAL SECURITY
+• 851 HIA (1395f)
+• 862 Black Lung (923)
+• 863 DIWC/DIWW (405(g))
+• 864 SSID Title XVI
+• 865 RSI (405(g))
+FEDERAL TAX SUITS
+• 870 Taxes (U.S. Plaintiff
+or Defendant)
+O 871 IRS Third Party
+26 USC 7609
+OTHER STATUES
+400 State Reapportionment
+410 Antitrust
+430 Barks and Banking
+450 Commerce
+460 Deportation
+470 Racketeer Influenced and
+Compt Organizations
+480 Consumer Credit
+490 Cable/Sat TV
+8ID Selective Service
+850 Securities/C'ommodities/
+Exchange
+875 Customer Challenge
+12 USC 3410
+0
+890 Other Statutory Actions
+891 Agricultural Acts
+892 Economic Stabilization Act
+893 Environmencal Matters
+894 Energy Allocation Act
+895 Freedom of infomation
+Act
+• 900Appeal of Fee Determination
+Under Equal Access
+so Justice
+• 950 Constinutionality of
+State Statutes
+V. ORIGIN
+J! Original
+Proceeding
+(Place an "X" in One Box Only)
+0 2
+Removed from
+0 3
+State Court
+Re-filed-
+• 4 Keinstaled or O
+(see VI below)
+a) Re-filed Case O YES PINO
+Transfered from O 6 Multidistrict
+another district
+Appeal to District
+Magistrate
+(specify)
+b) Related Cases /YES O NO
+VI. RELATED/RE-FILED
+CASE(S).
+(Sce instructions
+second page):
+DOCKET
+JUDGE Kenneth A. Marra
+UMBER See Attacher
+Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless
+diversity):
+VII. CAUSE OF
+ACTION
+18 U.S.C. 2255 (Predicate Statutes 18 U.S.C. 2422(b), 2423(b), 2423(e), 2251, 2252, 2252A(a)(1), 2252A(g)(1)
+and 159h)
+LENGTH OF TRIAL via 4
+_ days estimated (for both sides to try entire case)
+VIlI. REQUESTED IN
+• CHECK IF THIS IS A CLASS ACTION
+DEMANDS
+COMPLAINT:
+UNDER •
+1. 23
+ABOVE INFORMATION IS TRUE & CORRECT TO
+SIGNATURE OF ATTORNEY OF RECORD
+THE BEST OF MY KNOWLEDGE
+Katherine w. Ezell
+CHECK YES only if demanded in complaint:
+JURY DEMAND:
+lives p No
+DATE
+4/16 09
+FOR OFFICE USE ONLY,
+AMOUNT $3520 RECEIPT N
+
+04/17/09
+
+
+Entered on FLSD Docket 04/20/2009 Page 19 of 19
+WEST PALM BEACH DIVISION
+ATTACHMENT TO CIVIL COVER SHEET
+VI. RELATED/RE-FILED CASE(S):
+08-80069
+08-80119
+08-80232
+08-80380
+08-80381
+08-08804
+08-80811
+08-80893
+08-80993
+08-80994
+08-80469
+
+
+: Case 9:09-cv-80591-KAM Document 9 Entered on FLSD Docket 05/01/2009 Page 1 of 22
+IN THE UNITED STATES DISTRICT COURT
+FOR THE SOUTHERN DISTRICT OF FLORIDA
+Plaintiff,
+Civil Action No. 9:09-cv-80591-KAM
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+FIRST AMENDED COMPLAINT AND
+DEMAND FOR JURY TRIAL
+FIRST AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL
+Plaintiff,
+and states as follows:
+prings this Complaint against Defendant, Jeffrey Epstein,
+-
+PARTIES, JURISDICTION, AND VENUE
+At all times material to this cause of action, Plaintiff,
+was a
+resident of Palm Beach County, Florida.
+This Complaint is brought under a fictitious name to protect the identity of
+ecause this Complaint makes sensitive allegations of sexual assault
+Plaintiff
+and abuse of a then minor.
+3. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a
+residence located at 358 El Brillo Way, Palm Beach, Palm Beach County, Florida.
+4.
+Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he is
+currently incarcerated in the Palm Beach County Stockade.
+5.
+At all times material to this cause of action, Defendant, Jeffrey Epstein, was an
+adult male born in 1953.
+
+
+Entered on FLSD Docket 05/01/2009
+
+11. Defendant's plan and scheme reflected a particular pattern and method.
+Defendant coerced and enticed impressionable, vulnerable, and relatively economically less
+fortunate minors to participate in various acts of sexual misconduct that he committed upon
+them. Defendant's scheme involved the use of underage girls as well as other individuals to
+recruit other underage girls. Upon information and belief, Defendant or an authorized agent
+would call and alert Defendant's assistants shortly before or after he arrived at his Palm Beach
+residence. His assistants would seek out economically disadvantaged and underage girls from
+West Palm Beach and surrounding areas who would be enticed by the money being offered—
+generally $200 to $300 per "massage" session—and who Defendant and/or his assistants
+perceived as less likely to complain to authorities or have credibility issues if allegations of
+improper conduct were made. The then minor Plaintiff and other minor girls, some as young as
+14 years old, were transported to Defendant's Palm Beach county mansion by Defendant's
+employees, agents, and/or assistants in order to provide Defendant with "massages."
+12.
+Many of the instances of illegal sexual conduct committed by Defendant were
+perpetrated with the assistance, support, and facilitation of at least three assistants who helped
+him orchestrate this child exploitation enterprise. These assistants would often arrange times for
+underage girls to come to Defendant's residence, transport or cause the transportation of
+underage girls to Defendant's residence, escort the underage girls to the massage room where
+Defendant would be waiting or would enter shortly thereafter, urge the underage girls to remove
+their clothes, deliver cash from Defendant to the underage girls and/or their procurers at the
+conclusion of each "massage appointment," and, upon information and belief, take sexually
+explicit photographs and/or videos of the underage girls' for Defendant without their knowledge.
+Defendant would pay the procurer of each girl's "appointment" hundreds of dollars.
+3
+
+
+Case'9:09-cv-80591-KAM Document 9
+Entered on FLSD Docket 05/01/2009 Page 5 of 22
+enticing the then minor girl to engage in sexual acts with another female in Defendant's
+presence. The exact degree of molestation and frequency with which the sexual crimes took
+place varied and is not yet completely known; however, at least when Defendant was in Palm
+Beach, Florida, such acts occurred usually on a daily basis and, in most instances, several times a
+day. In order to facilitate the daily exchanges of money for sexual assault and abuse, Defendant
+kept U.S. currency readily available.
+16.
+As previously stated in paragraph 14, Defendant displayed photographs of nude
+underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S.
+Virgin Islands. Upon information and belief, some of the photographs Defendant's possession of
+Defendant were taken with hidden cameras set up in his home in Palm Beach. On the day of his
+arrest, police found two hidden cameras and photographs of underage girls on a computer in
+Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken
+with his hidden cameras and may have
+lewd photographs of Plaintiff,
+transported lewd photographs of Plaintiff (among many other victims) to his other residences and
+elsewhere using a facility or means of interstate and/or foreign commerce. Upon information
+and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were
+confiscated by the Palm Beach Police Department during its execution of a search warrant of
+Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those
+photographs are still in the custody of law enforcement.
+17.
+Defendant, Epstein, traveled to his mansion in Palm Beach for the purpose of
+luring minor girls to his mansion to sexually abuse and/or batter them. He used the telephone to
+contact these minor girls for the purpose of coercing them into acts of prostitution and to enable
+himself to commit sexual battery against them and/or acts of lewdness in their presence, and he
+conspired with others, including assistants and/or his drivers) and/or pilots), and his socialite
+5
+
+
+Case 9:09-cv-80591-KAM Document 9
+Entered on FLSD Docket 05/01/2009 Page 7 of 22
+complimented her, saying that she had a nice body. Defendant then pulled Plaintiff closer to
+him. He began masturbating and then began fondling her breasts. He asked her to do more and
+mentioned more money, which she adamantly declined. Defendant continued masturbating until
+he ejaculated. Plaintiff next recalls that she received $200 and was transported by the procurer,
+whom she later learned received $200 for having brought her to Epstein's mansion.
+19.
+Defendant thereafter lured the then minor Plaintiff to the Epstein mansion on at
+least one and perhaps two other occasions in the spring and/or summer of 2003. The procurer
+made another appointment for her to return, but Plaintiff didn't want to see Defendant. By
+having his assistants continue to contact Plaintiff and attempt to lure her to the mansion for other
+sexual acts, Defendant engaged in a continuous course of conduct that injured Plaintiff upon
+each instance of contact and/or abuse.
+20.
+In addition to the direct sexual abuse and molestation of the then minor Plaintiff,
+Defendant used his money, wealth, and power to unduly and improperly manipulate and
+influence the then minor Plaintiff to bring him another minor girl in a promised exchange for
+money. Rather than go herself, Plaintiff and the procurer took another girl there one time.
+21.
+As a result of these encounters with Defendant, Plaintiff,
+has in
+the past suffered, and will in the future continue to suffer, physical injury, pain and suffering,
+emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation,
+confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity,
+invasion of her privacy, and other damages associated with Defendant's controlling and
+manipulating her into a perverse and unhealthy way of life.
+22.
+Any assertions by Defendant that he was unaware of the age of the then minor
+Plaintiff are belied by her telling him her high school graduation year, as well as his own actions,
+and are rendered irrelevant by the provision of applicable federal statutes concerning the sexual
+7
+
+
+Entered on FLSD Docket 05/01/2009 Page 9 of 22
+26. Defendant, Jeffrey Epstein, used a facility or means of interstate and/or foreign
+commerce to knowingly persuade, induce, entice, or coerce
+when she was
+under the age of 18 years, to engage in prostitution and/or sexual activity for which any person
+can be charged with a criminal offense, or attempted to do so, pursuant to 18 U.S.C. § 2255 in
+violation of 18 U.S.C. § 2422(b).
+27. Plaintifi
+was a victim of one or more offenses enumerated in
+18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein,
+pursuant to this Section of the United States Code.
+28.
+As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future continue to suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
+other damages associated with Defendant's manipulating and leading her into a perverse and
+unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
+and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
+capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
+suffer these losses in the future.
+WHEREFORE, Plaintiff,
+demands judgment against Defendant,
+Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation,
+actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as
+this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right
+by a jury.
+9
+
+
+Entered on FLSD Docket 05/01/2009 Page 11 of 22
+actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as
+this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right
+by a jury.
+COUNT THREE
+(Cause of Action for Sexual Exploitation of Children pursuant to 18 U.S.C. $ 2255 in
+Violation of 18 U.S.C. § 2251)
+33.
+Plaintiff,
+hereby adopts, repeats, realleges, and incorporates by
+reference the allegations contained in paragraphs 1 through 24 above.
+34.
+Defendant, Jeffrey Epstein, knowingly persuaded, induced, enticed, or coerced the
+then minor Plaintiff
+, to engage in sexually explicit conduct for the purpose of
+producing a visual depiction of such conduct in violation of 18 U.S.C. § 2251. As previously
+stated in paragraphs 14 and 16, Defendant displayed a myriad of photographs of underage girls
+throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands.
+Upon information and belief, many of the photographs in the possession of Defendant were
+taken with hidden cameras set up in his home in Palm Beach. On the day of his arrest, police
+found two hidden cameras and photographs of underage girls on a computer in Defendant's
+home.
+Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd
+photographs of Plaintiff
+with his hidden cameras and may have transported
+lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere
+using a facility or means of interstate and/or foreign commerce. Upon information and belief,
+one or more sexually explicit photographs of Plaintiff that were taken when she was a minor
+were confiscated by the Palm Beach Police Department during its execution of a search warrant
+of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those
+photographs are still in the custody of law enforcement.
+
+
+Entered on FLSD Docket 05/01/2009 Page 13 of 22
+COUNT FOUR
+(Cause of Action for Transport of Visual Depiction of Minor Engaging in Sexually Explicit
+Conduct pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2252(a)(L)
+37. Plaintiff,
+hereby adopts, repeats, realleges, and incorporates by
+reference the allegations contained in paragraphs 1 through 24 above.
+38.
+Defendant, Jeffrey Epstein, upon information and belief, knowingly mailed,
+transported, shipped, or sent via computer and/or facsimile in or affecting interstate or foreign
+commerce at least one visual depiction of the minor Plaintiff engaging in sexually explicit
+conduct in violation of 18 U.S.C. § 2252(a)(1). As previously stated in paragraphs 14, 16, and
+34, upon information and belief, Defendant displayed a myriad of nude photographs of underage
+girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin
+Islands. Upon information and belief, many of the photographs in the possession of Defendant
+were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his
+arrest, police found two hidden cameras and photographs of underage girls on a computer in
+Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken
+with his hidden cameras and may have
+lewd photographs of Plaintiff,
+transported lewd photographs of Plaintiff (among many other victims) to his other residences and
+elsewhere using a facility or means of interstate and/or foreign commerce. Upon information
+and belief, one or more sexually explicit photographs of Plaintiff that were taken when she was a
+minor were confiscated by the Palm Beach Police Department during its execution of a search
+warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief,
+those photographs are still in the custody of law enforcement.
+39.
+As previously stated in paragraph 22, any assertions by Defendant that he was
+unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by
+the provision of applicable federal and state statutes concerning the sexual exploitation and abuse
+13
+
+
+• Case 9:09-cv-80591-KAM Document 9 Entered on FLSD Docket 05/01/2009 Page 15 of 22
+COUNT FIVE
+(Cause of Action for Transport of Child Pornography pursuant to 18 U.S.C. § 2255 in
+Violation of 18 U.S.C. § 2252A(a)(1))
+42. Plaintiff,
+hereby adopts, repeats, realleges, and incorporates by
+reference the allegations contained in paragraphs 1 through 24 above.
+43. Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via
+computer or facsimile in or affecting interstate and/or foreign commerce child pornography in
+violation of 18 U.S.C. § 2252A(a)(1). As previously stated in paragraph 16, Defendant displayed
+a myriad of nude photographs of underage girls throughout his homes, including his homes in
+New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Upon information and
+belief, many of the photographs in the possession of Defendant were taken with hidden cameras
+set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden
+cameras and nude photographs of underage girls on a computer in Defendant's home. Upon
+information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of
+Plaintiff,
+with his hidden cameras and may have transported lewd
+photographs of Plaintiff (among many other victims) to his other residences and elsewhere using
+a facility or means of interstate and/or foreign commerce. Upon information and belief, one or
+more nude photographs of Plaintiff that were taken when she was a minor were confiscated by
+the Palm Beach Police Department during its execution of a search warrant of Defendant's Palm
+Beach mansion on October 20, 2005. Upon information and belief, those photographs are still
+in the custody of law enforcement.
+44.
+As previously stated in paragraph 22, any assertions by Defendant that he was
+unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by
+the provision of applicable federal and state statutes concerning the sexual exploitation and abuse
+of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew
+15
+
+
+Case 9:09-cV-80591-KAM Document 9
+Entered on FLSD Docket 05/01/2009 Page 17 of 22
+COUNT SIX
+(Cause of Action for Engaging in a Child Exploitation Enterprise pursuant to 18 U.S.C.§
+2255 in Violation of 18 U.S.C. § 2252A(g))
+47. Plaintiff,
+, hereby adopts, repeats, realleges, and incorporates by
+reference the allegations contained in paragraphs 1 through 24 above and Counts One through
+Five.
+48.
+Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise,
+as defined in 18 U.S.C. § 2252A(g)(2), in violation of 18 USC § 2252A (g)(1). As more fully
+above, Defendant engaged in actions that constitute countless violations of 18 U.S.C. § 1591 (sex
+trafficking of children), Chapter 110 (sexual exploitation of children in violation of 18 U.S.C. §§
+2251, 2252(a)(1), and 2252(A)(a)(1)), and Chapter 117 (transportation for illegal sexual activity
+in violation of 18 U.S.C. §§ 2422, and 2423). As more fully set forth above in paragraphs 9
+through 19, Defendant's actions involved countless victims and countless separate incidents of
+abuse, and he committed those offenses against minors in concert with at least three other
+persons.
+49.
+Plaintiff,
+was a victim of one or more offenses enumerated in
+18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein,
+pursuant to this Section of the United States Code.
+50.
+As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future continue to suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
+other damages associated with Defendant's manipulating and leading her into a perverse and
+unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
+17
+
+
+: Case 9:09-CV-80591-KAM Document 9(
+Entered on FLSD Docket 05/01/2009 Page 19 of 22
+DEMAND FOR JURY TRIAL
+Plaintiff demands to have her case tried before a jury.
+s/Katherine W. Ezell
+Robert _. Josefsberg, Bar No. 040856
+Katherine W. Ezell, Bar No. 114771
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, Florida 33130
+(fax)
+Attorneys for Plaintiff
+19
+
+
+Case 9:09-Cv-80591-KAM Document 9 Entered on FLSD Docket 05/01/2009 Page 21 of 22
+SERVICE LIST
+V. JEFFREY EPSTEIN
+Case No. 08-CV-80591-MARRA/JOHNSON
+United States District Court, Southern District of Florida
+Robert Critton, Esq.
+Burman, Critton, Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+Jack Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Bruce E. Reinhart, Esq.
+Bruce B. Reinhart, P.A.
+250 South Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Co-counsel for Defendant, Jeffrey Epstein
+Jack Scarola, Esq.
+Jack P. Hill, Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+jsx@searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff
+Adam Horowitz, Esq.
+Stuart Mermelstein, Esq.
+Herman & Mermelstein
+18205 Biscayne Blvd.
+Suite 2218
+Miami, FL 33160
+21
+
+
+'Case 9:08-CV-80119-KAM Document 151 Entered on FLSD Docket 06/10/2009 Page 1 of 11
+CASE NO.:
+VS.
+Plaintiff,
+JEFFREY EPSTEIN
+Defendant.
+CASE NO.:
+Plaintiff,
+VS.
+JEFFREY EPSTEIN
+Defendant.
+CASE NO.:
+Plaintiff,
+VS.
+JEFFREY EPSTEIN
+Defendant.
+CASE NO.:
+Plaintiff,
+Vs.
+JEFFREY EPSTEIN,
+Defendant.
+
+
+' •Casé 9:08-Cv-80119-KAM Document 151|
+Entered on FLSD Docket 06/10/2009 Page 2 of 11
+Page 2
+CASE NO.:
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.:
+Plaintiff,
+JEFFREY EPSTEIN
+Defendant.
+CASE NO.:
+Plaintiff,
+JEFFREY EPSTEIN
+Defendant.
+Plaintiff,
+JEFFREY EPSTEIN et al,
+Defendants.
+Plaintiff,
+JEFFREY EPSTEIN et al,
+Defendants.
+
+
+•Case 9:08-Cv-80119-KAM Document 151
+Entered on FLSD Docket 06/10/2009 Page 3 of 11
+Page 01 v. Epstein
+CASE NO
+Plaintiff,
+JEFFREY EPSTEIN
+Defendant.
+CASE NO
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT JEFFREY EPSTEIN'S RESPONSE, TO PLAINTIFES
+MOTION FOR AN ORDER FOR THE PRESERVATION OF
+EVIDENCE & INCORPORATED MEMORANDUM OF LAW (dated 5/26/09, DE 114)
+Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned
+attorneys responds to the Plaintiffs'
+"Plaintiffs")
+Motion For And Order For The Preservation Of Evidence And Incorporated Memorandum Of
+Law, [DE 114], and states:
+Plaintiffs once again mislead and mischaracterize the criminal counts to which
+EPSTEIN pled guilty. Contrary to Plaintiffs' representations in 9[1 of their motion and in their
+memorandum of law, EPSTEIN pled guilty to one count of felony solicitation (which was not
+related to a minor), under $796.07(2)(f), Fla.Stat., and one count of procuring a minor for
+prostitution under §796.03, Fla. Stat. Plaintiffs' reference to the "pleas of 'guilty' ... to various
+Florida state crimes involving the solicitation of minors for the prostitution and procurement of
+
+
+Case 9:08-CV-80119-KAM Document 151
+Entered on FLSD Docket 06/10/2009 Page 4 of 11
+Page 4
+pled guilty.
+minors for the purposes of prostitution" mischaracterizes the specific counts to which EPSTEIN
+As to Plaintiffs' allegations in 19l 2 and 3, many of the Plaintiffs' allegations are
+without any factual basis and know such assertions to be false and untrue.
+3.
+Defendant agrees with Plaintiff's assertion that the Palm Beach Police
+Department (PBPD) executed a search warrant at EPSTEIN's Palm Beach mansion on October
+25, 2005. See 4 Plaintiffs' motion.
+4. Defendant's attorneys have no objection to an order to preserve evidence similar
+to the one entered in the case of Doe v. Epstein, et al, Case No. 08-80804-CIV-
+MARRA/JOHNSON, [DE 20], and attached hereto as Exhibit A. EPSTEIN's attorneys are
+unaware of any items referenced in Plaintiffs' motion, I5-6, having been returned to EPSTEIN or
+his attorneys, but will agree to a preservation of such items to the extent such items exist.
+As to 117 of Plaintiffs' motion, EPSTEIN and his attorneys have no objection to
+the referenced authorities, (PBPD, FBI, USAO, and PBSAO), preserving items to the extent such
+items even exist, in a manner that said authorities deem appropriate.
+6.
+As to 9918, 9, and 10 of Plaintiffs' motion re: documents, Defendant has asserted
+in other matters and asserts here, specific legal objections as well as his U.S. constitutional
+privileges, as follows: My attorneys have counseled me that at the present time I cannot select,
+authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal
+constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the
+United States Constitution. Drawing an adverse inference under these circumstances would
+
+
+•Case 9:08-CV-80119-KAM
+Entered on FLSD Docket 06/10/2009 Page 5 of 11
+Page 5
+unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and
+would therefore violate the Constitution. In addition to and without waiving his constitutional
+privileges, the information sought is privileged and confidential, and inadmissible pursuant to the
+terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 408, and $90.410,
+Fla. Stat. Further Defendants objects as the request to preserve evidence is overly broad and
+includes information that is neither relevant to the subject matter of the pending action not does
+it appear to be reasonably calculated to lead to the discovery of admissible evidence.
+Responding to the grossly overly broad list and categories of documents and items
+alleged in Plaintiff's motion (18-10) involves a testimonial component. The Fifth Amendment
+Privilege extends to the act of production where, as here, it involves a self-incriminating
+testimonial communication or "a compelled testimonial aspect." United States v. Hubbell, 530
+U.S. 27, 120 S.Ct. 2037 (2000); Fisher v. United States, 425 U.S. 391 (1976); McCormick on
+Evidence, Title 6, Chap. 13. The Privilege Against Self-Incrimination, 8138 (6" Bd.). See also
+Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Clause
+applies to the states through the Due Process Clause of the Fourteenth Amendment - "[i]t would
+be incongruous to have different standards determine the validity of a claim of privilege based on
+the same feared prosecution, depending on whether the claim was asserted in state or federal
+court."); Hoffman v. U.S., 71 S.Ct. 814, 818 (1951), and progeny).
+The Fifth Amendment Privilege may be invoked in a civil action where a litigant or
+witness is being asked to provide information or respond to a question that may incriminate him
+in a crime. See generally, DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4* DCA
+1983). The privilege against self-incrimination may be asserted during discovery when a litigant
+
+
+Case 9:08-CV-80119-KAM
+Entered on FLSD Docket 06/10/2009 Page 6 of 11
+Page 6
+has "reasonable grounds to believe that the response would furnish a link in the chain of
+evidence needed to prove a crime against a litigant." A witness, including a civil defendant, is
+entitled to invoke the Fifth Amendment privilege whenever there is a realistic possibility that the
+answer to a question could be used in anyway to convict the witness of a crime or could aid in
+the development of other incriminating evidence that can be used at trial. Id: Pillsbury Company
+y. Conboy, 495 U.S. 248, 103 S.Ct. 608 (1983).
+The United States Supreme Court has made clear that the scope of the Fifth Amendment
+Privilege includes the circumstances as here "the act of producing documents in response to a
+subpoena (or production request) has a compelled testimonial aspect." United States v. Hubbell,
+530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000). In explaining the application of the privilege, the
+Supreme Court stated:
+We have held that "the act of production" itself may implicitly communicate
+"statements of fact." By "producing documents in compliance with a subpoena, the
+witness would admit that the papers existed, were in his possession or control, and
+were authentic."EN12
+Moreover, as was true in this case, when the custodian of
+documents responds to a subpoena, he may be compelled to take the witness stand and
+answer questions designed to determine whether he has produced everything
+demanded by the subpoena. IN2l The answers to those questions, as well as the act of
+production itself, may certainly communicate information about the existence,
+custody, and authenticity of the documents. Whether the constitutional privilege
+protects the answers to such questions, or protects the act of production itself, is a
+question that is distinct from the question whether the unprotected contents of the
+documents themselves are incriminating.
+EN19. 'The issue presented in those cases was whether the act of producing
+subpoenaed documents, not itself the making of a statement, might nonetheless
+have some protected testimonial aspects. The Court concluded that the act of
+production could constitute protected testimonial communication because it might
+entail implicit statements of fact: by producing documents in compliance with a
+subpoena, the witness would admit that the papers existed, were in his possession
+or control, and were authentic. United States v. Doe, 465 U.S., at 613, and n. 11,
+104 S.C1. 1237; Fisher: 425 U.S, at 409-410, 96 S.Ct. 1569; id., at 428, 432, 96
+S.Ct. 1569 (concurring opinions). See Braswell v. United States, [487 U.S.,] at
+
+
+'Case 9:08-cv-80119-KAM
+Document 151 Entered on FLSD Docket 06/10/2009 Page 7 of 11
+104, 108 S.Ct. 2284: [ td.,] at 122, 108 S.Ct. 2284 (dissenting opinion). Thus, the
+Court made clear that the Fifth Amendment privilege against self-incrimination
+applies to acts that imply assertions of fact."... An examination of the Court's
+application of these principles in other cases indicates the Court's recognition that,
+in order to be testimonial, an accused's communication must itself, explicitly or
+implicitly, relate a factual assertion or disclose information. Only then is a person
+compelled to be a 'witness' against himself." Doe v. United States, 487 U.S., at
+209-210, 108 S.Ct. 2341 (footnote omitted).
+EN20. See App. 62-70. Thus, for example, after respondent had been duly sworn
+by the grand jury foreman, the prosecutor called his attention to paragraph A of
+the Subpoena Rider (reproduced in the Appendix, infra, at 2048-2049) and asked
+whether he had produced "all those documents." App. 65.
+Finally, the phrase "in any criminal case" in the text of the Fifth Amendment might
+evidence even though the statements themselves are not incriminating and are not
+introduced into evidence. Thus, a half century ago we held that a trial judge had
+erroneously rejected a defendant's claim of privilege on the ground that his answer to
+the pending question would not itself constitute evidence of the charged offense. As
+we explained:
+"The privilege afforded not only extends to answers that would in themselves
+support a conviction under a federal criminal statute but likewise embraces those
+which would furnish a link in the chain of evidence needed to prosecute the claimant
+for a federal crime." Hoffman v. United States, 341 U.S. 479, 486, 71 S.Ct. 814, 95
+L.Ed. 1118 (1951).
+Compelled testimony that communicates information that may "lead to
+Doe i tie video is U.S. 201, zen i n. 6. 108 .C. 2341, 100 L.C.2 154.
+(1988).
+It's the Fifth Amendment's protection against the prosecutor's use of
+incriminating information derived directly or indirectly from the compelled testimony
+of the respondent that is of primary relevance in this case.
+In summarizing its holding regarding the application of the Fifth Amendment Privilege to
+a production request, the Hubbell Court left "no doubt that the constitutional privilege against
+self incrimination protects" not only "the target of a grand jury investigation from being
+compelled to answer questions designed to elicit information about the existence of sources of
+
+
+•Case 9:08-CV-80119-KAM
+Entered on FLSD Docket 06/10/2009 Page 8 of 11
+Page 8
+potentially incriminating evidence," but the privilege also "has the same application to the
+testimonial aspect of a response to a subpoena seeking discovery of those sources." At 43, and
+2047. Here, Plaintiffs' motion to preserve evidence by listing a large inventory of items is in
+reality no different that propounding a discovery request upon Defendant, and thus, Defendant is
+afforded the protection of the Constitutional privileges asserted herein.
+8.
+As stated above, Defendant and Defendant's attorneys have no objection to the
+entry of an order similar to Exhibit A hereto.
+WHEREFORE, Defendant requests that the Court enter an order similar to that as entered
+in Exhibit A hereto.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day on all counsel of record identified on the following Service List in the manner specified by
+CM/ECE on this 12 day of June, 2009
+
+
+Case 9:08-cv-80119-KAM
+Entered on FLSD Docket 06/10/2009 Page 9 of 11
+Page 9
+Respectfully
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+MICHADRI, PIKE. ESQ.
+BURMAN, CRITTON, LUTTER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+(Counsel for Defendant Jeffrey Epstein)
+
+
+Case 9:08-cv-80119-KAM
+Entered on FLSD Docket 06/10/2009 Page 10 of 11
+Page 10
+Case No. 08-CV-80119-MARRA/JOHNSON
+Stuart S. Mermelstein, Esq.
+dam D. Horowitz, Esq.
+Aermelstein & Horowitz, P.A
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+Brad Edwards, Esq.
+Rothstein Rosenfeldt Adler
+401 East Las Olas Boulevard
+Suite 1650
+Fort Landerdale, EL 33301
+Cossel for Plaint in Related Case No. O8.
+Counsel for Plaintiffs in Related Cases Nos.
+08-80069, 08-80119, 08-80232, 08-80380, 08-
+80381, 08-80993, 08-80994
+Paul G. Cassell, Esq.
+Pro Hac Vice
+Richard Horace Willits, Esq.
+332 South 1400 E, Room 101
+Richard H. Willits, P.A.
+Salt Lake City, UT 84112
+2290 10" Avenue North
+Suite 404
+Lake Worth. FL 33461
+Co-counsel for Plaintiff Jane Doe
+Counsel for Plaintiff in Related Case No. 08- Isidro M. Garcia, Esq.
+80811
+Garcia Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+Jack Scarola, Esq.
+Jack P. Hill, Esq.
+Searcy Denney Scarola Barnhart & Shipley,
+P.A.
+Counsel for Plaini in Related Case No. O8.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+Robert I. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Po yes agler street, Suite 800
+Viami F1. 33130
+Counsel for Plaintifi,
+
+
+Case 9:08-cv-80119-KAM Document 151
+Entered on FLSD Docket 06/10/2009 Page 11 of 11
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Ricci-Leopold, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL. 33410
+Counsel for Plaintiff in Related Case No. 08-
+08804
+Counsel for Plaintiffs in Related Cases Nos.
+09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+Counsel for Defendant Jeffrey Epstein
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/a30e0dfd45ceb415178588da2b663e04f2e53707b8c30f7aa44abd554cb2c60d.receipt.json b/vision-fixhub/ds9-unparsed-05/a30e0dfd45ceb415178588da2b663e04f2e53707b8c30f7aa44abd554cb2c60d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..fd1913403c1f5115a23be4fa759f142ce21b0296
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a30e0dfd45ceb415178588da2b663e04f2e53707b8c30f7aa44abd554cb2c60d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -21735,
+  "dataset": "marble-joined",
+  "doc_id": "a30e0dfd45ceb415178588da2b663e04f2e53707b8c30f7aa44abd554cb2c60d",
+  "engine": "marble-apple-vision",
+  "event_count": 384,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.flight-log-tables.normalize\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "7b374e517b23217c876ec69c8d0b982c3b233b2de19258c7fe09f8ecc167980d",
+  "output_sha256": "db4ebd8911fa4fd4fa25b65279fa974656780b1a3cb993e3283e56ee08b089b6",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a3169424e859857680d0d40bec7835a6fac67970aa77aa6a8de9a8b36e45010f.md b/vision-fixhub/ds9-unparsed-05/a3169424e859857680d0d40bec7835a6fac67970aa77aa6a8de9a8b36e45010f.md
new file mode 100644
index 0000000000000000000000000000000000000000..75e94d3fcefb61898f9300afd099eebf41e25c04
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a3169424e859857680d0d40bec7835a6fac67970aa77aa6a8de9a8b36e45010f.md
@@ -0,0 +1,230 @@
+Be 2/5/02 Lefcount to Villatana
+
+
+A PROFESSIONAL CORPORATION
+148 EAST 78™ STREE
+NEW YORK, NEW YORK 10021
+GERALD B. LEFCOURT
+lefcourt@lefcourtlaw.com
+HERHONE,
+LEASEMI EN
+February 5, 2007
+VIA FEDERAL EXPRESS
+A. Marie Villafaña, Esq., Assistant United States Attorney
+Office of the United States Attorney
+Southern District of Florida
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epstein
+Dear Ms. Villafaña:
+Thank you for meeting with us last week regarding our client, Jeffrey Epstein. I write to
+arify statements we made concerning the significance of the debit/credit card statement v
+'oduced. As it stands. I am afraid my failure to inform you that Mr. Epstein's birthday i
+January 20"h,
+", may have left some confusion as to how the statement relates to the allegations. For
+ease of reference an additional copy of the statement is annexed hereto.
+The debit/credit card statement is from
+s Chase account. It reflects a
+$122.21 purchase at Guys and Dolls, an adult video store located in West Palm Beach.
+According to the statement, the purchase was made on January 20, 2005 - Jeffrey Epstein's
+birthday - at a time when
+I, whose date of birth is December 30, 1986, was clearly
+18 years of age.
+At our meeting on February 1, 2007, you asked how we were sure this statement related
+to the events in question. The best response would have been to refer you to
+I own words.
+In her sworn statement of October 11, 2005, she referred several times to an occasion when she
+and
+• purchased and used sex tovs, an event which
+herself described as a
+"birthday gift" to Epstein. Specifically,
+| stated that ".. for [Epstein's] birthday
+and I
+went shopping. And um, we got a bunch of toys, [laughs] ...". She later reiterated, "...on his
+birthday ...Um, we went shopping at this like sex place ... and um we bought a bunch of stuff
+and then we just went at it in front of him".
+| further made it clear that the purchase was in
+
+
+A. Marie Villafaña, Esq., Assistant United States Attorney
+Office of the United States Attorney
+Southern District of Florida
+February 5, 2007
+Page 2
+connection with Epstein's birthday (January 20, 2005, the date reflected on the statement): "Um,
+it was a [birthday] gift, I guess you could call it a [birthdayl gift from me and
+In light of the foregoing, there should be no doubt that the credit card statement provided
+allegations and that this encounter occurred at a time when
+was 18
+relates directly to l
+years old.
+Very truly yours,
+erry
+erald B. Lefcourt
+Cc:
+Andrew Lourie, Esq., Deputy Chief, Northern Region
+Lilly Ann Sanchez, Esq.
+Roy Black, Esq.
+
+
+-TN
+NADIA
+MARCINKOVA
+10021
+OVERVIEW
+January 19- February 15, 2005
+
+Chase Statement
+Customer Sarvice
+ServioLine:
+836-0035 trem
+616. 714, 718 4 d14 area
+codes.
+Olhervie,
+osil 1-800-895-9835.
+Hearing Impained
+GEN 1-800-CHASETO
+Acoets Assaunia.
+Pay Bis, Trenafor Money
+Fast, Easy.
+Fros with Chase Oring
+www.aheea.com/bank
+Primary
+Acount Number:
+Number of Cheeks
+Enciosad:
+Checking
+Onase Exua Checking
+Chese Extra Savinge
+Total
+THIS ENDS YOUR STATEMENT OVERVIEW
+Summaty
+Opening Balance
+Addlions
+Deductions
+Ending Balance
+Average
+Activity
+Date
+Desaription
+Balance
+(orzo
+01/24
+6022
+Guye And Dodi,
+CBC Purchas On 01/21; Card p **** 6022
+
+
+A PROFESSIONAL CORPORATION
+48 EAST 78™ STREE
+EW YORK, NEW YORK 100%
+GERALD B. LEFCOURT
+lefcourt@lefcourtlaw.com
+TELEPHONE
+FACSIMILE
+SHERYL E. REICH
+relch@lefoourtlaw.com
+NATO C. STABIL
+bille@lefcourtlaw.c
+FAITH A. FRIEDMAN
+tfriedman@lefoourtlaw.com
+February 5, 2007
+VIA FEDERAL EXPRESS
+A. Marie Villafaña, Esq., Assistant United States Attorney
+Office of the United States Attorney
+Southern District of Florida
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epstein
+Dear Ms. Villataña:
+Thank you for meeting with us last week regarding our client, Jeffrey Epstein. I write to
+clarify statements we made concerning the significance of the debit/credit card statement we
+produced. As it stands, I am afraid my failure to inform you that Mr. Epstein's birthday is
+January 20",
+', may have left some confusion as to how the statement relates to the allegations. For
+ease of reference an additional copy of the statement is annexed hereto.
+The debit/credit card statement is from
+Chase account. It reflects a
+$122.21 purchase at Guys and Dolls, an adult video store located in West Palm Beach.
+According to the statement, the purchase was made on January 20, 2005 - Jeffrey Epstein's
+birthday - at a time when _
+• whose date of birth is December 30, 1986, was clearly
+18 years of age.
+At our meeting on February 1, 2007, you asked how we were sure this statement related
+to the events in question. The best response would have been to refer you to
+own words.
+In her sworn statement of October 11, 2005, she referred several times to an occasion when she
+and
+purchased and used sex toys, an event which herself described as a
+"birthday gilt" to Epstein. Specifically,
+stated that ".. for [Epstein's] birthday,
+and I
+went shopping. And um, we got a bunch of toys, [laughs] ...". She later reiterated, ".. on his
+birthday ...Um, we went shopping at this like sex place ... and um we bought a bunch of stuff
+and then we just went at it in front of him". L
+further made it clear that the purchase was in
+
+
+A. Marie Villafaña, Esq., Assistant United States Attorney
+Office of the United States Attorney
+Southern District of Florida
+February 5, 2007
+Page 2
+connection with Epstein's birthday (January 20, 2005, the date reflected on the statement): "Um,
+it was a [birthday] gift, I guess you could call it a [birthday] gift from me and
+In light of the foregoing, there should be no doubt that the credit card statement provided
+allegations and that this encounter occurred at a time when
+was 18
+relates directly to
+years old.
+Very truly yours,
+erry
+jerald B. Lefcourt
+cc:
+Andrew Lourie, Esq., Deputy Chief, Northern Region
+Lilly Ann Sanchez, Esq.
+Roy Black, Esq.
+
+
+NADIA MARCINKOVA
+-TN
+HISh YORK ATY
+10021
+OVERVIEW
+January 19 - February 15, 2005
+
+Chase Statement
+Customer Service
+ServioLine:
+836-0038 trem
+516. 710, 748 4 014 area
+codes.
+Olherwise:
+call 1-000-935-9835
+Huaring Impaired dek 1-B00-CHASETD
+Accass Acciate Ray Büs. Tranafer Money
+Fast, Easy, Free with Chase Oning
+www.dhees.com/bank
+Primary Acount Number:
+Number
+of Checks Enclosad:
+Checking
+Chase Exua Chocking
+Chase Extro Savinga
+Total
+Agpouri Number
+Qp
+THIS ENDS YOUR STATEMENT OVERVIEW
+Summaty
+Opaning Balance
+Addlions
+Deductions
+Ending Balance
+Average Seance
+Activity
+Date
+Desariotion
+Balanca
+01/24
+CBC Purchase
+CBC Purchase On 0121: Card I*** 6022
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/a3169424e859857680d0d40bec7835a6fac67970aa77aa6a8de9a8b36e45010f.receipt.json b/vision-fixhub/ds9-unparsed-05/a3169424e859857680d0d40bec7835a6fac67970aa77aa6a8de9a8b36e45010f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..91076abd373a01ae5c0c742b5359c5c1dd2d2859
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a3169424e859857680d0d40bec7835a6fac67970aa77aa6a8de9a8b36e45010f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -267,
+  "dataset": "marble-joined",
+  "doc_id": "a3169424e859857680d0d40bec7835a6fac67970aa77aa6a8de9a8b36e45010f",
+  "engine": "marble-apple-vision",
+  "event_count": 10,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "3b2d4d989aa3ebdfd0037b372b1730e956fa90414a89507ee6e713b163e193ad",
+  "output_sha256": "2e1489960416d37d35d5aa5caad69423232fa981069d097e98856c6286d06c5f",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a374b1cd08457cdd94819c1bb1ee1f36998b41279f026d730b786b38599d7c6d.md b/vision-fixhub/ds9-unparsed-05/a374b1cd08457cdd94819c1bb1ee1f36998b41279f026d730b786b38599d7c6d.md
new file mode 100644
index 0000000000000000000000000000000000000000..5c3158d0f87028fcb6879288ddec59da534020c4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a374b1cd08457cdd94819c1bb1ee1f36998b41279f026d730b786b38599d7c6d.md
@@ -0,0 +1,4630 @@
+Jay P. Lolkowiz, P.C.
+To Gol Wilr Ditclly:
+lerkcwtagarxand.com
+KIRKLAND & ELLİS LLP
+AND AFTILIATED PARTHERSHIFS
+Citigroup Center
+453 East 53rd Street
+New York, Now York 10022-4611
+www.kirkland.com
+September 2, 2008
+VIA FACSIMILE (561) 820-8777
+A. Marie Villatana
+United States Attorney's Office
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epstein
+Dear Marie:
+. In response to your letter dated August 26, 2008, I am confirming that Mr. Goidberger
+should continue to be listed as the contact person in the ämended victim notificatior letters and
+should receive the carbon copies of those letters as they are sent.
+Also, we plan on speaking to Mr. Josefsberg this weik to discuss a procedure for paying
+his fees. We intend to comply fully with the agreement and Mr. Epstein will pay Mr. Jostsberg's
+usual and customary hourly rates for his work pursuant to the agreement facilitating settlements
+under 2255.
+Sincerely,
+Jay f. M
+Lefkowitz
+co:
+Jack Goldberger
+Roy Black
+Chloago
+Hong Kong
+London
+Los Angelas
+Ben Franciaco
+Wushington, D.C.
+
+
+ROBERT C. JOSEFSBERG
+To:
+ROBERT C. JOSEFSBERG
+Tuesday, February 03, 2009 2:16 PM
+'RBLACK@royblack.com'
+Re: Epstein
+Roy - I need to go on record regarding Mr Epsteins message that without any settlements
+there will be a "push back" on any future payments. First, Mr Epstein has no authority to
+"push back" on payments. Secondly, although I am vey interested in settling some cases, I
+will not let Mr Epstein coerce me
+into settling for some clients so that I can get paid
+representing others. It would be unethical for me to settle any
+cases in order to
+avoid Mr Epstins threatened "push back". If I do settle any cases, it will have nothing to
+do with Mr epstein waving the money carrot in front of me. Third, on friday, Jan 23rd, (or
+Sat the 24th) you advised that Mr Epstein would promptly pay all costs and all legal fees
+through and including 1/23. I told you that I questioned his authity to "stop" paying for
+time and costs incurred after 1/23. BUT - I appreciated the fact that he would promptly
+pay our next bill - covering only through 1/23. I told you that I would not send out this
+new bill untill Mr epstein paid our prior, 120 and 90 day overdue statements. I didn't
+want a "new" statement to delay payment on the old overdue statments. Does your last email
+mean that Mr epstein is breaching his agreement to promptly pay for all time/costs
+incurred up to 1/23 ? I will send a new statement covering everything from approx 12/15
+through 1/23. Please Let me
+know whether Mr Epstein will comply with your message of
+1/23, or he will "push back" on this next statement. My next statement will be sent the
+day after Mr Epstein pays the other old staements.
+If he did actually send the check
+today, I should have the next statment mailed by thurs or fri. Thus far Mr Epstein has
+made 3 changes re where I should send the statements. In order to avoid further delay and
+contusion, please let me know where you want me to send the next statements. I apologize
+if this email has typos!, eto but its the best I can do while I'm in trial. I do not
+apologize for the tone of this note - I am hurt and upset - I think that Mr Epstein is
+taking advantage of me,
+and taking
+advantage of our (Roy/Bob) relationship. Will further
+discuss this w you by phone or in personm. Thanks
+Original Message
+From: Roy BLACK <RBLACK@royblack.com>
+To: ROBERT C. JOSEFSBERG
+Sent: Tue Feb 03 12:47:59 2009
+Subject: Epstein
+Bob: I am told a check went out today. I am also told there will be push back on further
+expenses without a settlement. So we need to discuss settling the cases. Jeffrey will not
+pay more for the fees and expenses without the start of settlement negotiations. So let's
+
+
+L
+BERT PATTON
+To:
+ROBERT C. JOSEFSBERG
+Wednesday, February 11, 2009 12:47 PM
+AW: Epstei Evelyn Sheehan: KATHERINE W. EZELL; BERT PATTON
+-----Original Message--..
+From: Roy BLACK [mailto:RBLACK@royblack.com]
+Bent: Monday, February 09, 2009 8:53 AM
+To: ROBERT C. JOSEFSBERG
+Subject: Re: Epstein
+The elLent has informed me and I will send you a note today on bla position. Harry for the
+>>> "ROBERT C. JOSEFSBERG" <RJOSEFSBERG@PODHURST. com» 2/6/2009 2:39 PM
+>>>>>>
+Having not heard from you, I assume that you still do not have sufficient direction, or
+are still lacking client input. I've had 3 or 4 issues pending since our conversation of
+1/23 or 1/24. I've waited two weeks for your responses, and + am running out of time. I
+understand and sympathize with your situation. I wish someone would attempt to understand
+my situation. You are leaving me very limited alternatives.
+----- Original Message
+From: Roy BLACK <RBLACK@royblack, com›
+To: ROBERT C. JOSEFSBERG
+Sent: Thu Feb 05 12:04:21 2009
+Subject: Re: Epstein
+I am talking to the client this afternoon. So I have no direction yet.
+Roy - you wrote on 2/3 that you were advised that "a check went out today". It did not.
+This morning 100,000 was wired. There was 200, 000 that was more than 90 daya overdue. The
+50 percent payment is not acceptable. Unfortunately, this matter is going to blow up. My
+partner,
+Podhurgt wants to bring this to a head by tomorrow. I will try to reach you
+during the lunch break in my arbitration. You were supposed to get back to me on yesterday
+- after you received "client input". I understand your situation - but it is apparent that
+your client does not care about his agreements, and is. Making everything impossible. I
+though it was appropriate to let you know before we take further action.
+B22E22EE
+----- Original Message
+From: Roy BLACK <RBLACk@royblack.com>
+To: ROBERT C. JOSEFSBERG
+Sent: Tue Feb 03 13:41:21 2009
+Subject: Re: Epatein
+no problem. I will keep you informed.
+>>> "ROBERT C. JOSBESBERG" <RJOSEFSBERG@PODHURST. com» 2/3/2009 1:33 PM
+>>>>>>
+'Il be at my arbitration from approx 9 till 6. I'll try to call you during a break - o
+ou can call me after 6. Why don't you email me after you get your client input - and I'I
+call you after that.
+---- Original Message -----
+From: Roy BLACK CRBLACK@royblack, com»
+To: ROBERT C. JOSEFSBERG
+Sent: Tue Feb 03 13:19:40 2009
+Subject: Re: Epstein
+1
+
+
+Bob let's talk tomorrow. I need more input from the client before we discuss this.
+»›> "ROBERT C: JOSEFSBERG" <RJOSEFSBERG@PODHURST. com> 2/3/2009 1:11 PM
+Roy
+- I'm not satisfied with my last
+email to you - am in a rush because I'm in an B day
+arbitration. I need to talk to you - will you (at the milt hirsch function tonight? I'11
+try to get there btwn 6:45 and 7:30 - if we don't talk there, please call me after 7:30 -
+at 632 9230
+---- Original Message
+From: ROBERT C. JOSEFSBERG
+To: 'RBLACK@royblack.com'
+<RBLAck@royblack.com
+Sent: Tue Feb 03 12:55:53 2009
+Subject: Re: Epstein
+Fine - can we settle
+- as to the "delay" in talking about settlement ,
+when I met with Jay I
+early Dee he said that Jeff would not be ready to talk about
+settling till the end of Jan. Both you and Jay did not return my 3 or 4 calls to each of
+you between Jan 10 and approx Jan 25 when I finally dpoke to you.
+---- Original Message
+From: Roy BLACK <RBLACK@royblack.com>
+To: ROBERT C. JOSEFSBERG
+Sent: Tue Feb 03 12:47:59 2009
+Subject: Epatein
+Bob: I am told a check went out today. I am also told there will be push back on further
+expenses without a settlement. So we need to discuss settling the cases. Jeffrey will not
+pay more for the fees and expenses without the start of settlement negotiations. So let's
+2
+
+
+13/2009 13:11 FAX
+2002/003
+To Call Writer Directly:
+lerkowitz@kirkland.com
+AND AFFILIATED PARTNERSHIP'S
+Citigroup Center
+153 East 53rd Street
+Now York, New York 10022-4611
+www.kirkland.com
+
+February 13, 2009
+Chicago
+VIA FACSIMILE
+Robert C. Josefsberg, Esq.
+City National Bank Building
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+Dear Bob,
+We have received copies of your firm's invoices for the last several months as related
+your representation of a select group of individuals in connection with a matter between
+Mr. Epstein and the United States Attorney's Office in the Southern District of Florida (the
+"USAO"). We write this letter to (1) address issues raised by those invoices and (2) suggest a
+resolution to this matter that would benefit all parties involved.
+First and foremost, after thoroughly reviewing the invoices from your firm, it is clear that
+the services you have provided to the women at issue far exceed the scope of services for which
+Mr. Epstein agreed to pay under the federal Deferred Prosecution Agreement (the "Agreement"
+and Addendum. Pursuant to the relevant Agreement and Addendum, Mr. Epstein agreed to pay
+the attorney representative for his representation of a select group of individuals at "his or her
+regular customary hourly rate."
+Importantly, the Addendum limits the scope of this
+representation and specifies that the Agreement "shall not obligate Epstein to pay the fees and
+costs of contested litigation filed against hirn." The Addendum further provides that Mr.
+Epstein's obligation to pay the fees of an attorney representative ceases when the work
+performed is aimed at pursuing "a contested lawsuit pursuant to 18 U.S.C. § 2255" or "any other
+contested remedy." Simply put, the Agreement and Addendum only require Mr. Epstein to pay
+fees expended in connection with negotiating a settlement for each of the relevant individuals,
+not for services relating to any type of pre-litigation effort. Thus, any charges related to work
+performed beyond, or extraneous to, reaching a settlement should not be Mr. Epstein's"
+responsibility. Mr. Epstein fully intends to fulfill his agreement and pay for all fees associated
+with settlement at your firm's regular hourly rates. However, Mr. Epstein will not pay for any
+services beyond those directed towards reaching a settlement. To resolve this matter, we are
+Hong Kong
+London
+Los Angeles
+
+
+• 02/13/2009 13:12 FAX
+41003/003
+
+February 13, 2009
+available and ready to discuss the invoices with you on a line-by-line basis and believe that we
+can come to an agreeable resolution as to the fees accumulated to date. During the same
+discussion, we hope to clarify with you the exact number of women who have agreed to utilize
+your services for the purpose of reaching a settlement with Mr. Epstein.
+Second, upon serious consideration and discussion, Mr. Epstein is prepared to offer your
+clients a settlement that we believe will serve to compensate each individual appropriately. As a
+final resolution to this matter, Mr. Epstein would pay each individual who agrees to relinquish
+any and all potential civil claims against him $50,000.00, which is the statutory amount provided
+by 18 U.S.C. § 2255, at the time of the alleged violations. Each individual would receive this
+amount, without any need to offer proof of claim or injury and without any further delay. We
+hope that you discuss this offer with your clients in the next 30 days, as Mr. Epstein's offer to
+settle will remain open until March 13, 2009.
+Very truly yours,
+el Lefkowitz
+
+
+ROBERT C. JOSEFSBERG
+To:
+ROBERT C. JOSEFSBERG
+Tuesday, February 03, 2009 2:16 PM
+'RBLACK@royblack.com'
+Re: Epstein
+Roy - I need to go on record regarding Mr Epsteins message that without any settlements
+there will be a "push back" on any future payments. First, Mr Epstein has no authority to
+"push back" on payments. Secondly, although I am vey interested in settling some cases, I
+will not let Mr Epstein coerce me into settling for some clients so that I can get paid
+for representing others. It would be unethical for me to settle any cases in order to
+avoid Mr Epstins threatened "push back", If I do settle any cases, it will have nothing to
+do with Mr epstein waving the money carrot in front of me. Third, on friday, Jan 23rd, (or
+Sat the 24th) you advised that Mr Epstein would promptly pay all costs and all legal fees
+through and including 1/23. I told you that I questioned his authity to "stop" paying for
+time and costs incurred after 1/23. BUT - I appreciated the fact that he would promptly
+pay our next bill - covering only through 1/23. I told you that I would not send out this
+new bill untill Mr epstein paid our prior, 120 and 90 day overdue statements. I didn't
+want a "new" statement to delay payment on the old overdue statments. Does your last email
+mean that Mr epstein is breaching his agreement to promptly pay for all time/costs
+incurred up to 1/23 ? I will send a new statement covering everything from approx 12/15
+through 1/23. Please let me know whether Mr Epstein will comply with your message of
+1/23, or he will "push back" on this next statement. My next statement will be sent the
+day
+after Mr Epstein pays the other old staements. If he did actually send the check
+today,
+I should have the
+next statment mailed by thurs or fri. Thus far Mr Epstein has
+made 3 changes re where I should send the statements. In order to avoid further delay and
+confusion, please let me know where you want me to send the next statements. I apologize
+if this email has typos!, ete but its the best I can do while I'm in trial. I do not
+apologize for the tone
+of this note - I an hurt and upset - I think that Mr Epstein is
+taking advantage of me, and taking advantage of our (Roy/Bob) relationship. Will further
+discuss this w you by phone or in personm. Thanks
+----- Original Message -----
+From: Roy BLACK <RBLACK@royblack.com>
+To: ROBERT C. JOSEFSBERG
+Sent: Tue Feb 03 12:47:59 2009
+Subject: Epstein
+Bob: I am told a check went out today. I am also told there will be push back on further
+expenses without a settlement.
+need to discuss settling the cases. Jeffrey will not
+pay more for the fees and expenses without the start of settlement negotiations. So let's
+
+
+Jay P. Leftowitz, P.C,
+To Cell
+Bec Dimelly:
+and carr
+AND AMELIATED PAKTNERSHIPS
+Oll|group Center
+163 East Gard Street
+New York, New York 10022-4811
+www.kirkdand.com
+Enosimila:
+) 445-4000
+September 2, 2008
+YIA FACSIMILE (561) 820-8777
+'A. Marie Villafans
+United States Attorney's Office
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epstein
+Dear Marie:
+In response to your letter dated August 26, 2008, I am confirming thet Mr. Goldberger
+should continue to be listed as the contact person in the ämended victim notificatiori letters and
+should receive the carbon copies of those letters as they are sent.
+Also, we plan on speaking to Mi. Josefsberg this week to discuss a procedure for paying
+his fees. We intend to comply fully with the agreement and Mir. Epstein will pay Mr. Josfsberg's
+usual and customary curly rates for his work pursuant to the agreement facilitating settlements
+under 2255.
+neerely,
+Jack Goldberget
+Roy Black
+Chloego
+Hong Kong
+London
+Los Angeles
+. San Francisco
+Washington, D.C,
+aled
+06IS-292-90E
+1Aa03 010
+Wd60: S
+6002 80
+Ø6TS ZSC S0E 6T:8T
+6002/80/90
+unI
+
+
+Aaron S. Podhurst
+Robert C. losefsber
+oel DA
+Steven C. Marks
+Victor M. Diaz, Jr.
+Katherine W. Ezell
+Stephen F. Rosenthal
+Robert Orseck (1934-1978)
+Walter H. Beckham, Jr.
+Karen Podhurst Dem
+Of Counsel
+February 20, 2009
+John Gravante, III
+Kirkland & Ellis LLP
+Citigroup Center
+153 East 53" Street
+New York, NY 10022-4611
+Dear Mr. Lefkowitz:
+I received your letter dated February 13, 2009. What your client is doing is obvious, and it
+is in breach of his Non-Prosecution Agreement. The agreement speaks for itself. Enclosed is a copy
+of the marching orders I received from Mr. Sloman. Pursuant to these directions and the ethical
+requirements of the legal profession to zealously represent myclients, I have attempted to efficiently
+and effectively pursue my clients' claims against Mr. Epstein. Perhaps your client thought that he
+could victimize and intimidate countless underage girls, that he would then agree to provide minimal
+compensation to them for the damage he inflicted upon them and that I would then simply let them
+come in and "sign the paperwork" for the absolute minimum recovery. My role is not a clerical one
+where I merely document a settlement that simply offers the statutory minimum even though courts
+have provided recovery for each occurrence. What's more, your letter presumes that I should allow
+my clients to accept such an offer without fully evaluating their claims. Settling their cases in a
+vacuum would amount to malpractice.
+As we see it, each of our 9 or 10 clients has three choices: to do nothing, to settle, or to sue
+your client. In order to make an educated decision, we are required to conduct a comprehensive
+review of each client's personal history, the events surrounding their abuse at the hands of Mr.
+Epstein and what has happened to them since he sexually exploited and abused them. Collateral
+interviews and psychological evaluations are crucial components of corroborating facts and assessing
+a fair damages calculation. Extensive legal research into their potential legal claims and resulting
+damages must also take place. Such an investigation is, of course, going to be helpful at trial if any
+of them choose to litigate their claims. This, however, does not change the fact that everything
+we've done is necessary in order to determine if we should settle: As a matter of fact, you and I
+discussed hiring Sandy Marks, a jury consultant. Again, such an exercise would be extremely
+helpful at trial, but an analysis of what would happen at trial is exceptionally beneficial at the
+settlement stage.
+Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800, Miuri, FL 33130
+Miami 905.358.2800 Fax 305.358.23B2 • Fort Lauderdale 954.463.4346
+
+
+February 20, 2009
+You are welcome to set up a conference call or visit us so we can go through my bills line
+by line in search of "any charges related to work performed beyond, or extraneous to, reaching a
+settlement." To be clear, nothing in our bills is extraneous to settlement of our clients' claims. Our
+bills represent our work on behalf of 9 or 10 clients. I will take this opportunity to remind you that
+of the $412,827.76 that we have sent you itemized bills for, only $163, 992.15 has been paid. Mr.
+Black wrote on February 3" that he was advised that a check had been sent out that day. It had not.
+By the time we got 50% of outstanding fees, outstanding bills were more than 90 days overdue.
+Failure to pay our fees jeopardizes your client's agreement with the United States Attorney's Office.
+My exchange with Mr, Black (copies of e-mails are attached) illustrates that promises that
+have been written or said by you or Mr. Black have been breached. I find myself in a position where
+I do not know if Mr. Epstein is bound by what you or Mr. Black say. Before we go further, I need
+confirmation that you and/or Roy Black can commit Mr. Epstein,
+One of Mr. Black's e-mails clearly states that "Jeffrey will not pay more for the fees and
+expenses without the start of settlement negotiations." I am frankly baffled by your client's
+misguided pretense. When I met with you on November 26, 2008, you said Mr. Epstein would not
+be ready to talk about settling until the end of January. Both you and Mr. Black did not return three
+or four calls to each of you between January 10 and approximately January 25. Just so the record
+is clear, we have diligently pursued reaching the stage of active settlement negotiations and have
+been stonewalled by your side, until your February 13"h "take it or leave it" $50,000 per client offer.
+In addition, T'have attempted to tackle any procedural and logistical problems in an efficient,
+economical and timely manner. At each step, I have either encountered delay or a complete lack
+of response. For example, I wasted a lot of time and energy on your client's frivolous claim that I
+cannot represent my clients at trial. You shocked me with that position on November 21" and
+promised to get back to me to discuss it. Since we met in November, we haven't received a response
+regarding this issue. You apparently have finally abandoned this position. In addition, at that
+November meeting, I told you that some victims have severe psychological problems and that their
+claims warranted far in excess of $150,000 but that we are sensitive to concerns about them using
+the money otherwise. As a result, we discussed putting the money in special trusts expressly
+restricted for payment of psychological treatment. Again, I have received no response.
+Finally, the March 13" cutoff date is nonsensical. I trust that you wouldn't dare be
+attempting to say that Mr. Epstein's offer is withdrawn after that. As I said before, your client is in
+clear breach of his Non-Prosecution Agreement. I am at a loss as to why he would be willing to face
+the prospect of numerous civil trials, which will be ugly for him, and a federal prosecution in order
+to avoid fairly compensating my clients for the harm he inflicted upon them.
+Very truly yours,
+port
+Robert C. Josefsbe
+Roy Black
+Alan Dershowitz
+
+
+City National Bank Building
+ams, Foride Set, Suite Suite -
+GATES POSTAG
+Ty
+PITNEY BOWES
+02 1M
+$ 00.44°
+
+JUN 24 2009
+MAILED FROM ZIPCODE 33130
+A. Marie Villafana
+Assistant U.S. Attorney
+Office of the U.S. Attorney
+Seventh District of Florida
+500 East Broward Blvd., 7* Floor
+Fort Lauderdale, FL 33394
+33394*3016 C001
+
+
+"03/03/2068 18:32 FAX
+2002/004
+Jay P. Letkowitz, P.C.
+To Call Writer Directly:
+lefkowitz@dfkland.com
+ANG ATALIATED FARTNERSHIPS
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4811
+www.kirkland.com
+Faesimile:
+
+For Settlement Purposes Oniy
+March 3, 2009
+VIA FACSIMILE
+Robert C. Josefsberg, Esq.
+City National Bank Building
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+Dear Mr. Josefsberg,
+I write in response to your letter dated February 20, 2009. First, there is no merit whatsoever to
+your contention that Mr. Epstein has breached the Non-Prosecution Agreement, and your
+implication that he has is simply unsupported by the facts. As you state in that letter, the
+"agreement speaks for itself" and should be honored as such. My February 13, 2009 letter to you
+was an attempt to ensure that the portion of the Agreement concerning restitution be carried out
+as intended and written. Indeed, our objections to your expanded role in representing the alleged
+victims and to Mr. Epstein's obligations to pay fees incurred outside of the settlement context are
+valid. Furthermore, nowhere in the Agreement or Addendum does it state that a fee dispute or
+contentions as to the exact role of the attorney representative constitute a breach of that
+Agreement. In fact, there is a requirement that fee disputes be resolved with a special master.
+As I further explain below, your letter and accompanying documents, as well as the description
+of services performed in your invoices, lead us to believe that there has been a misunderstanding
+as to your role.
+With your letter, you enclosed & communication from Mr. Stoman to Judge
+October 25, 2007 and an additional document, presumably also from Mr. Sloman, entitled
+"PROPOSAL FOR PROCEEDING ONCE ATTORNEY IS SELECTED." While you refer to
+these documents as your "marching orders," neither document is pari of the signed Agreement
+between Mr. Epstein and the United States Attorney's Office ("USAO"). The October 25, 2007
+letter was not even addressed to you, but rather to Judge
+the individual responsible for
+selecting an appropriate attorney representative. And since the October 2007 letter was drafted,
+there have been several communications between Mr. Epstein's defense team and the USAO
+which served to further clarify the Agreement with respect the role of the attorney representative.
+Chicago
+Hong Kong
+London
+Los Angeles
+
+
+03/03/2009 18:33 FAX
+2003/004
+
+March 3, 2009
+and regarding Epstein's Agreement to pay such attorney representative his or her regular
+customary hourly rate.
+.." (emphasis added). However, you never inquired as to the existence
+if such a joint statement to help inform you of your defined role. Indeed, you failed to reach ou
+to anyone on Mr. Epstein's defense team to obtain such a document.
+Even though the October 2007 letter does not provide any direct instructions as to your particular
+responsibilities, it does quote relevant portions of the Agreement which expressiy limit Mr.
+Epstein's obligation to pay the attorney representative. Specifically, the Agreement "shall not
+obligate Epstein to pay the fees and costs of contested litigation filed against him." Furthermore,
+the proposed instructions are represented in a document that was not agreed upon between the
+USAO and Mr. Epstein's defense team. Indeed, we clearly rejected the notion that (1) the
+selected attorney be able to fulfill any role beyond negotiating a settlement, and (2) that Epstein
+would pay for any services beyond those incurred while trying to reach a settlement.
+While we have no objections to your representation of the relevant individuals, we believe that
+your role, as made clear in the Agreement, is limited to settlement negotiations. In other words,
+under the Agreement, if an individual wants to consider any measure beyond settlement with
+Mr. Epstein, she must pursue those avenues through another lawyer. Based on the language of
+the Agreement, it is our position that you are not responsible for pursing your clients' claims, as
+you state in your letter.
+Furthermore, Mr. Ipstein is certainly not trying to "victimize and intimidate" anyone. The offer
+to settle was an earest effort to avoid any further delay in resolving this matter. Notably, the
+government has expressly provided that it takes no position regarding potential claims of
+government witnesses.! Given this lack of support. Mr. Enstein's offer of $50,000 to resolve
+claims that are not time-barred (as we believe |
+i claim to be), without any
+On several occasions, USAO representatives have asserted that the goverment takes no position as to the
+aims of the individuals identified as alleged victims. For the sake of confidentiality, we will not produce th
+elevant documents. One such communication, however, was made in a December 6, 2007 letter from Unite
+States Attomey Acosta to myself, in which he stated that "the Office has no intention to take any position in any
+civil litigation arising between Mr. Epstein and any individual victim ..."
+
+
+• 03/03/2009 18:34 FAX
+2004/004
+
+March 3, 2009
+requirement to verify the allegations made, is more than reasonable.? And while you are surely
+Epstein's offer and consider potential litigation against Mr. Epstein, another lawyer, not paid by
+Mr. Epstein, will have to perform that work
+1 hope these matters can be resolved in an amicable manner. I would welcome the opportunity to
+meet with you face-to-face so that we are able to move forward. I am certain that a great deal of
+the confusion can be resolved through an in-person meeting. Due to the fact that there are many
+lawyers involved, 1 fear that some your past correspondence was not returned in a timely
+manner. I will endeavor to make certain that this does not happen again.
+Very truly yours,
+2
+$50,000 represents the statutory minimum under 18 U.S.C. § 2255,
+i constitutionally questionably statute for
+mere to stil hits wes he relevant time of the pursued conde torn of te reme for with thr patein
+
+
+Aaron S. Podhurst
+Joel D. Eaton
+Steven C. Marks
+Victor M. Diaz, JI.
+Katherine W. Ezell
+Stephen F. Rosenthal
+Ricardo M. Martinez-Cid
+Ramon A. Rasco
+Alexander T. Rundlet"
+John Gravante, III
+Robert Orseck (1934-1978)
+Walter H. Beckham, Jr.
+Karen Podhurst Dern
+Of Counsel
+June 8, 2009
+Via Fax and U.S. Mail
+sq.
+Burman, Critte
+Luttier
+& Coleman, I
+515 North Flagrer Drive, Suite 400
+West Palm Beach, FL 33401
+Re: Epstein Case
+Our File No.: 30608
+Dear Bob:
+I was shocked when I heard from Bob Josefsberg that Jeffrey Epstein and counsel do not
+recall, or have decided to ignore, his contractual obligation to pay this firm's fees and costs relating
+to any of his victims/our clients who elect to settle their claims without filing suit. You asked Bot
+to put his position in writing, and this letter is our rough attempt to do so.
+The Agreement
+Paragraph 7 of the Non-Prosecution Agreement ("NPA") provides for the selection of an
+attorney representative ("Atty Rep") for the individuals who are on a list of individuals whom the
+United States has identified as victims, as defined in 18 U.S.C. § 2255 (Victims"), which list was
+to be provided and was provided to Epstein's attorneys, Jack Goldberger and Michael Tien, after
+Epstein signed the NPA and was sentenced.
+Subsequently, there was an Addendum to the Non-Prosecution Agreement ("Addendum"),
+the stated intent of which was to clarify certain provisions of page 4, paragraph 7 of the NPA. In
+paragraph A of the Addendum, it was agreed that the United States had the right to assign to an
+independent third-party, the responsibility of selecting the Atty Rep, subject to the good taith
+approval of Epstein'scounsel. As you know, former Chief Judge Edward Davis was the independent
+third-party chosen by the United States in consultation with and with the good faith approval of
+Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800, Miami, FL 39130
+Miami 305.358.2800 Fax 305,358.2382 • Fort Lauderdale 954.463.4346
+
+
+Robert Critton, Esq.
+June 8, 2009
+Epstein's counsel. Judge L
+in turn and in accordance with paragraph 7, selected our partner
+Robert C. Josefsberg as Atty Rep for the victims. Both parties had the right to object to his selection
+prior to his final designation. Mr. Josefsberg was formally designated as Atty Rep on or about
+September 2, 2008, without objection from either side.
+Pursuant to paragraph 7 of the NPA, Mr. Josefsberg is to be paid for his services as Atty
+Rep] by Epstein. Paragraph 7B of the Addendum directed the Parties to jointly prepare a short
+written submission to Judge L
+regarding the role of the Atty Rep and Epstein's Agreement to
+ay such Alty Rep his customary hourly rate for to presentinet the yoins. bicted. Notates
+repared a proposal and submitted it to Judge
+did neither Epstein nor his counsel deign to join with the United States in preparing such a proposal,
+but they failed and refused to submit their own proposed protocol. In that circumstance, Epstein
+clearly. waived his right to submit a joint proposal or any proposal at all. Accordingly, he has no
+right to object to the proposal submitted by the United States. A clear reading of the Addendum at
+7B demonstrates that there was no disagreement, nor could there have been any misunderstanding
+regarding what is referred to as "Epstein's Agreement to pay ... [Mr. Josefsberg's] regular
+customary hourly rate."
+This obligation is reiterated in the first sentence of paragraph 7C. Epstein's choosing not to
+submit a proposal as to the role of the Atty Rep in no way relieved him of his obligation to pay the
+Atty Rep his regular hourly rate for his representation of the designated victims, so long as they are
+engaged in the settlement process. This is particularly apt when Epstein chose to avail himself of
+this settlement opportunity so as to preclude the Atty Rep's filing of a lawsuit on behalf of the
+victim. Epstein's obligation to pay the Atty Rep's fees and costs pursuant tot he NPA and its
+Addendum ceases only in the event that the Atty Rep files contested litigation against Epstein on
+behalf of a victim.
+The Recent Settlement
+During the last six months there have been meetings, emails and phone conversations
+between Roy Black, Jay Lefkowitz and Bob Josefsberg that corroborate our position. Please check
+with Jay and Roy as to their recollection of these matters.
+Despite his putting up one road block after another, Mr. Epstein, through you as his counsel,
+and the Atty Rep recently settled the claim of one of Epstein's listed and identified victims, our client
+Skye
+This firm is in the process of putting together our final bill relating to our
+representation of Ms.
+I and will be submitting it to you or Mr. Goldberger as soon as the
+entitlement issue is resolved. We fully expect Jeffiey Epstein to honor his agreement by paying the
+fees and costs related to this representation according to the terms of the NA and the Addendum.
+We are also prepared to make a second settlement proposal (for another client) and expect similar
+
+
+Robert Critton, Esq.
+June 8, 2009
+treatment of attorney fees in that matter.
+Remedies
+There are several alternatives available to us, should Jeffrey Epstein refuse to honor his
+agreement to pay according to those terms. Both our victim clients and the Atty Rep and his firn
+are and were intended to be third party beneficiaries of the NPA and the Addendum. As such, we
+have the right to bring suit for specific performance of and/or declaratory judgment regarding the
+terms of the agreement between Epstein and the United States. In the alternative, other Epstein
+counsel have stated that all fee disagreements should be resolved by a special master. We are not
+averse to that. I am sure that I need not remind you that with regard to the Atty Rep's work thus far,
+there has been complete performance on our side and partial performance by the Defendant. Epstein
+did make partial payment of our initially invoiced fees earlier in these proceedings. When he
+stopped paying, his counsel communicated that he would start paying again when there were
+settlements. This in itself constitutes an acknowledgment of his obligation to do so. Having initially
+paid and thus inducing continued performance by the Atty Rep, Epstein is now equitably estopped
+to deny his contractual obligation. The Atty Rep, on the other hand, has fully completed his part of
+the bargain by providing the necessary services to make it possible for
+her claim without filing a contested lawsuit, and the Atty Rep is entitled to be paid in fill for those
+services by Epstein. Finally, there is the implied obligation of good faith and fair dealing inherent
+in every contract, including those intended to benefit third parties.
+Please advise us of your position prior to Friday's hearing, because your position may
+influence our involvement at that hearing.
+Very truly yours,
+calcine W. Ezell
+Katherine W. Ezell
+KWE/mce
+
+
+Attachments:
+20030516162817672 pot
+i had attache dis us to to ol 01 be ating that i undes blen are after in ting that..
+
+
+To:
+Letter from Critton Denying any Fees and hearing tomorow
+tomorrow. Kathy
+
+
+jay.lefkowitz@kirkland.com
+AND AFFILIATED PARTNERSHIPS
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4611
+www.kirkland.com
+June 12, 2009
+Facsimile:
+VIA FEDERAL EXPRESS
+United States Attorney's Office
+500 South Australian Ave., Suite 400
+West Palm Beach, Florida 33401
+Re:
+Jeffrey Epstein
+Dear Ms. Villafana,
+I am in possession of your June 12, 2009 letter giving notice of breach. I respectfully
+submit that the Motion to Dismiss that is referenced therein did not constitute a willful breach of
+Mr. Epstein's obligations under the non-prosecution agreement. Mr. Epstein's counsel
+unanimously determined that the filing of this Motion to Dismiss was not a breach of the nonprosecution agreement, and the Motion to Dismiss was filed by counsel without Mr. Epstein's
+final approval.
+I want to inform you that immediately upon receipt of your letter, Mr. Epstein directed his
+counsel to file the attached Notice withdrawing all but issue number VIII of the previously filed
+Motion to Dismiss. The same issue also is described briefly in subparagraph D on page 3 of the
+Motion, which likewise was not withdrawn. Please note that this issue relates exclusively to the
+damages available under § 2255. The Notice has already been filed. If your continued review of
+the civil dockets causes you to have additional concerns about any other filing, consistent with
+the notice provisions of the non-prosecution agreement and consistent with our prior practice
+regarding such matters, please provide me with notice and the opportunity to address the same
+with you.
+I believe that with today's filing withdrawing these issues Mr. Epstein, through counsel,
+has fully remedied any perceived breach. Please advise if you for any reason disagree.
+Respectfully submitted,
+ay P. Lefkowitz, P.C
+Chicago
+Hong Kong
+London
+Los Angeles
+
+
+CC: Jeffrey Sloman, Esq.
+
+
+Case 9:09-Cv-80591-KAM Document 53
+Entered on FLSD Docket 06/12/2009 Page 1 of 2
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 09-CIV - 80591 - KAM
+JANE DOE NO. 101,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT JEFFREY EPSTEIN'S NOTICE OF WITHDRAWL OF ARGUMENTS I
+THROUGH VII OF THE DEFENDANT'S MOTION TO DISMISS PLAINTIFE'S FIRS!
+AMENDED COMPLAINT (DE29)
+Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, hereby
+withdraws arguments I through VII as set forth in the Defendant's Motion to Dismiss the
+Plaintiff's First Amended Complaint (FAC) [DE 29], dated May 26, 2009. Defendant withdraws
+his arguments contained subparagraphs A, B, C and Sections I (The Complaint Must Be
+Dismissed Because Plaintiff Is Not A Minor), II (The FAC Must Be Dismissed Because The
+Defendant Has Not Been Convicted Of A Predicate Offense), III (Count One Of The FAC Must
+Be Dismissed Because It Does Not Please A Violation Of 18 U.S.C. § 2422(b)), IV (Count Two
+Must Be Dismissed Because It Does Not Plead A Violation Of 18 U.S.C. §2423(b)), L (Count
+Three Must Be Dismissed Because It Does Not Plead A Violation Of 18 U.S.C. § 2251, VI
+(Counts Four and Five Must Be Dismissed Because They Do Not Plead Violation of 18 U.S.C.
+88 2252(a)(1) Or 2252(a)(1), and VII (Count Six Must Be Dismissed Because 18 U.S.C. §
+2252A(g) Was Not Enacted Until 2006).
+Defendant will rely only on those arguments set forth in subparagraph D, on page 3, and
+Paragraph VIII (Any Surviving Count Should Be Merged Into A Single Count) of the
+
+
+Case 9:09-cv-80591-KAM
+Document 53
+Entered on FLSD Docket 06/12/2009 Page 2 of 2
+Defendant's Motion to Dismiss the First Amended Complaint Or, In The Alternative, For A
+More Definite Statement [DE 29] dated May 26, 2009.
+Counsel or Dopendant EPSTEIN
+Certificate of Service
+I HEREBY CBRTIFY that a true copy of the foregoing was electronically filed with the
+'Terk of the Court using CM/BCE. I also certify that the foregoing document is being served this
+a ta out i or ented on the along sense it in the manger specified by
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Counsel for Plaintiff
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-86917
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Respectfully submitted.
+ROBERT D, CRITTON, JR., ESQ.
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+(Counsel for Defendant Jeffrey Epstein)
+
+
+To Call Writer Directly:
+LILL
+AND AFFILLATED PARTNERSHIPS
+Citigroup Center
+53 East 53rd Stree
+low York, New York 10022-461
+www.kirkland.com
+Facsimile
+June 15, 2009
+VIA FACSIMILE
+United States Attorney's Office
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epstein
+Dear Marie:
+I am attaching a letter authored by my co-counsel, Robert Critton, on today's date. It
+represents our agreement with a proposal that Kathy Ezell indicated in a letter dated June 8, 2009
+would be fully acceptable to her and Bob Josefsberg as a means to resolve expeditiously all
+outstanding fee issues regarding the attorney representative. Mr. Epstein has directed his counsel
+to take immediate steps to address and resolve the attorney representative's outstanding feerelated issues and we are doing so without delay. The suggestion of a Special Master, agreed to
+by both parties, to resolve the issues in the immediate future, will assure all parties that there will
+be no delay and no need for adversarial litigation regarding fees.
+More generally, I want to assure you that Mr. Epstein has directed all counsel to make
+sure that there is no filing that could constitute a breach of the NPA. Accordingly, a new internal
+screening process has been established to provide focused decision-making on each filing. To
+the extent we believe any filing may be perceived as implicating any of the issues generically
+addressed in the NPA (a document including sentences within paragraph 8 that even Mr. Acosta
+agreed were "far from simple"), we intend to address such issues with you prior to any filing and
+hope that you will agree to review the draft filing and inform us whether or not from your
+perspective it would, if filed, constitute a "breach". This will be especially important regarding
+issues that we believe fall at the intersection of Section 2255 and the civil litigation. We reserve
+our right, if you believe a proposed filing to conflict with the NPA or if you wish not to address
+these issues with us, thereafter to address such substantive issues with the Court.
+Chicago
+Hong Kong
+London
+Los Angeles
+
+
+June 15, 2009
+We hope that these proposals-in combination with our immediate withdrawal of the
+previously filed Motion to Dismiss-resolve all outstanding issues at the intersection of the NPA
+and 2255. Please advise if any remain.
+Enclosure
+
+
+1. MICHAEL BURMAN, P.A.!
+A LIMITED LIABILITY PARTNERSHIP
+ICHABL 1, PIK
+BATHER MCNAMARA RUD
+HORIA LAD CERTIED
+June 15, 2009
+BARBARA M. McKENNA
+SHLIE STOKEN-BARIN
+BETTY STOKES
+PARALEGALS
+RITA H. BUDNYK
+OF COUNSEL
+Sent by E-mail and U.S. Mail
+Robert Josefsberg, Esq
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+Re:
+Epstein Matter
+Dear Bob:
+On June 8, 2009, Kathy Ezell wrote a letter to me regarding outstanding fee
+payment issues. At page 3, she stated that she was not adverse to an earlier proposal
+that had been discussed amongst the parties to rely on a Special Master to resolve
+outstanding fee-related issues. We agree with Kathy's "proposal" that we rely on a
+Special Master to resolve all outstanding fee issues. Let's work during our Wednesday
+meeting to select an appropriate Special Master and let's agree to see whether, in the
+interim, we can resolve these issues even before they are submitted to the S.M.
+Cordially yours.
+Roberyo
+. Critton, Jr.
+RDC/clz
+CC:
+Jack Goldberger, Esq.
+L'A • W
+* Y
+515 N. FLAGLER DRIVB / SUITE 400 / WEST PALM BBACH, FLORIDA 33401
+mail@bclelaw.com
+
+
+500 S. Australian Ave, Ste 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+June 17, 2009
+DELIVERY BY ELECTRONIC MAIL
+Jay P. Lefkowitz, Esq.
+Kirkland & Ellis LLP
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4675
+Re:
+Jeffrey Epstein
+Dear Jay:
+Thank you for your letter of June 15, 2009. I did not receive your letter until late
+yesterday afternoon because I am shuttling back and forth between the Fort Lauderdale and
+West Palm Beach offices. The best way to reach me is via e-mail.
+With respect to the substance of your letter, the Office has not completed its review
+of Mr. Epstein's civil filings and correspondence related to the payment of the attorney
+representative's fees, so I cannot confirm that all outstanding issues have been resolved. If
+and when additional breaches are identified, timely notice will be provided in accordance
+with the terms of the Non-Prosecution Agreement.
+As to your proposal, our Office cannot and will not become involved in the civil suits
+filed against Mr. Epstein; as counsel for Mr. Epstein has expressed on several occasions, it
+is inappropriate for the government to involve itself in civil litigation. We likewise do not
+think it is appropriate to review civil pleadings in order to provide advisory opinions, even
+at your request.
+The duty to stay within the bounds of the Non-Prosecution Agreement lies with Mr.
+Epstein and he alone has the power to remain in compliance. Mr. Epstein has a highly skilled
+team to assist him, and compliance with the Agreement is not difficult, as you suggest. For
+example, it is not complicated to understand that, when a named victim files a claim
+
+
+JAY P. LEFKOWITZ, ESQ.
+JUNE 17,2009
+
+exclusively under Section 2255, Mr. Epstein cannot assert that there is no liability, just as
+providing the state plea agreement to our Office in advance of entering the state guilty plea
+was not complicated.
+I remain hopeful that Mr. Epstein will take all of his obligations seriously and elect
+to err on the side of caution in making decisions that relate to the performance of his duties.
+Sincerely,
+Jeffrey H. Sloman
+Acting United States Attorney
+→ Manitillafare
+A. Marie Villafaña
+Assistant United States Attorney
+Jack Goldberger, Esq.
+Roy Black, Esq.
+
+
+Jay P. Lefkowitz, P.O
+To Call Writer Directly
+AND AFFLIATED PARTNERSHIPS
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4611
+www.kirkland.com
+Facsimile:
+June 15, 2009
+VIA FACSIMILE
+United States Attorney's Office
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epstein
+Dear Marie:
+I am attaching a letter authored by my co-counsel, Robert Critton, on today's date. It
+represents our agreement with a proposal that Kathy Ezell indicated in a letter dated June 8, 2009
+would be fully acceptable to her and Bob Josefsberg as a means to resolve expeditiously all
+outstanding fee issues regarding the attorney representative. Mr. Epstein has directed his counsel
+to take immediate steps to address and resolve the attorney representative's outstanding feerelated issues and we are doing so without delay. The suggestion of a Special Master, agreed to
+by both parties, to resolve the issues in the immediate future, will assure all parties that there will
+be no delay and no need for adversarial litigation regarding fees.
+Chicago
+Hong Kong
+London
+Los Angeles
+
+
+June 15, 2009
+We hope that these proposals-in combination with our immediate withdrawal of the
+previously filed Motion to Dismiss- resolve all outstanding issues at the intersection of the NPA
+and 2255. Please advise if any remain.
+Enclosure
+cc: VKaren Atkinson, Esq.
+
+
+A LIMITED LIABILITY PARTNERSHIP
+HEATHER MEN AMARA RUDA
+PORTAL LAD CERTI
+June 15, 2009
+ARBARA M. MOKENNA
+ASHLIE STOKEN-BARING
+BETTY STOKES
+PARALEOALS
+RITA H. BUDNYK
+OF COUNSEL
+Sent by E-mail and U.S. Mail
+Robert Josefsberg, Esq.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+Re: Epstein Matter
+Dear Bob:
+On June 8, 2009, Kathy Ezell wrote a letter to me regarding outstanding fee
+payment issues. At page 3, she stated that she was not adverse to an earlier proposal
+that had been discussed amongst the parties to rely on a Special Master to resolve
+outstanding fee-related issues. We agree with Kathy's "proposal" that we rely on e
+Special Master to resolve all outstanding fee issues. Let's work during our Wednesday
+meeting to select an appropriate Special Master and let's agree to see whether, in the
+interim, we can resolve these issues even before they are submitted to the S.M.
+Cordially you,
+RDC/clz
+CC:
+Jack Goldberger, Esq.
+L'A•W •Y •E•R•S
+515 N. FLAGLER DRIVE / SUITE 400 / WEST PALM BBACH, FLORIDA 33401
+mail@bclclaw.com
+
+
+Jay P. Lefkowitz, P.C
+ro Call Writer Directly
+AND AFFILIATED PARTNERSHIPS
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4611
+www.kirkland.com
+Facsimile:
+VIA FEDERAL EXPRESS
+United States Attorney's Office
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epstein
+Dear Marie,
+I appreciate your letter of June 17, 2009. I sincerely hope that any and all issues that
+could generate an adversarial relationship between Mr. Epstein and the United States Attorney's
+Office are in our past. Like you, we hope that the ongoing, complex, and at times vigorous
+litigation will not again require your involvement, nor result in any belief on your part that any
+legal position taken by Mr. Epstein's counsel conflicts with the Non-Prosecution Agreement
+(''NPA").
+In order to avoid future misunderstandings, however, I would like to have a discussion
+with you specifically about our ongoing obligations as you understand them under the NPA. As
+you know from past experience, and as Mr. Acosta previously acknowledged in letters to my
+partner Ken Starr (on December 4, 2007) and Lilly Ann Sanchez (on December 19, 2007), the
+language of 9| 8 is "far from simple," and, in certain respects, subject to significant ambiguity.
+I believe it is both necessary and appropriate to seek immediate clarification from the
+government about its understanding of a few provisions in the NPA. It is likely by no fault of our
+own that these issues will come before a judge or an independent third party, whose job it will be
+to interpret the intent of the parties. In those circumstances, I think the court would most likely
+turn to both of us and directly seek our views, as the drafters of the agreement, before rendering
+its own opinion. Therefore, I believe it would bring about the finality that we both seek in a
+much reduced time frame if we could discuss several of the more ambiguous provisions
+contained in the NPA.
+Chicago
+Hong Kong
+London
+Los Angeles
+
+
+One specific example comes to mind. First, we clearly understood during the course of
+negotiating the NPA, and believe that both the language of the NPA and our prior
+correspondence with your Office confirm, that the waiver of liability set forth in Paragraph 8 at
+most was designed to allow an identified individual the right to assert a single violation of a
+section 2255 predicate. The waiver of liability does not embrace situations where a particular
+plaintiff asserts multiple violations. Thus, compliance with paragraph 8's waiver of liability
+would require at most that Mr. Epstein stipulate to the existence of a single enumerated predicate
+that would entitle an otherwise eligible plaintiff to actual damages (or the applicable statutory
+minimum damages where actual damages fall short of that floor), leaving aside the issue of
+whether the waiver is applicable to contested litigation or only the cases where there would be
+agreed damage resolutions. In addition, if we believe that a predicate act is time-barred, as
+indeed we understand was the case with respect to all such acts in relation to one plaintiff, a
+proper construction of the waiver of liability would not preclude the reliance on a statute of
+limitations defense.
+Given your Office's prior acknowledgements that the language of the NPA is far from
+clear, we very much would appreciate an opportunity to discuss Paragraph 8 with you in the very
+near future in order to clarify a few pivotal questions raised by the NPA. I assure you that
+Mr. Epstein intends to abide fully by the terms of the NPA. And it is my sincere hope that our
+discussion can avert future risks that anything we do will cause you to believe that there has been
+a breach of the NPA.
+Finally, I enclose a letter in response to your June 15 letter in order to provide you with
+our perspective on the issues you raised. I hope our differing views on certain events over the
+past several years as reflected in my letter will not in anyway divert us from a common goal of
+having Mr. Epstein complete his NPA obligations without further tension with your Office.
+Sincerely,
+Jayp. hel
+Enclosures
+
+
+To Call Writer Directly:
+AND AFFILIATED PARTNERSHIPS
+Citigroup Center
+Now York, Now Work 10022-4611
+www.kirkland.com
+Facsimile:
+VIA FEDERAL EXPRESS
+United States Attorney's Office
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epstein
+Chicago
+Dear Marie:
+We prepared this answer in response to your letter dated June 15, 2009 and before
+receiving your follow up letter of June 17, 2009. At this point it has been almost three years
+since the federal government first intervened in what was originally a matter investigated and
+charged by state prosecutorial authorities. It has been almost a year since Mr. Epstein pleaded
+guilty in state court and began serving his sentence in county jail, pursuant to the terms and as a
+direct result of the federal Non-Prosecution Agreement (the "NPA"). When Mr. Epstein was
+sentenced, the U.S. Attorney promised me and my co-counsel that the United States Attorney's
+Office's involvement would cease with Mr. Epstein's execution of the NPA and incarceration in
+state custody. We were also promised that the federal government would not intervene in
+discretionary state or county decisions regarding the implementation of Mr. Epstein's sentence.
+We take this opportunity to address in detail each of the alleged instances you describe to
+support your position that Mr. Epstein has engaged in a pattern of breaching the NPA.
+Mr. Epstein's overriding commitment is, and has always been, to complete his jail sentence,
+fulfill his other obligations under the NPA, and reach final settlements of pending section 2255
+cases with plaintiffs who are agreeable to such settlements. We respectfully submit (and support
+through documentary evidence) that there have been no past breaches of the NPA. There have
+been no "willful" breaches of the NPA. There has been no pattern of breaches of the NPA.
+As an initial matter, it is important to consider your letter of June 15 and its contents in
+context. Mr. Epstein has satisfied, and continues to satisfy, his obligations pursuant to the NPA.
+Mr. Epstein pleaded guilty to a registerable state offense. He has already registered as a sex
+Hong Kong
+London
+Los Angeles
+Washington, D.C
+
+
+offender, and has served over 11 months of his sentence in county jail. While such a plea and
+punishment were not otherwise sought by the State Attorney, Mr. Epstein agreed to the plea, the
+sentence, and the obligation to register as a sex offender as a direct result of obligations he
+agreed to undertake pursuant to the NPA. Furthermore, Mr. Epstein has already paid over
+$300,000 in civil settlements and fees for the attorney representative, and has agreed to submit
+issues regarding further fees to a Special Master pursuant to a proposal suggested by the attorney
+representative himself. The claimants whose matters have already been settled were identified
+by you as victims and, in one case, as a sign of good faith, Mr. Epstein paid a settlement to an
+individual he had no recollection of ever meeting, solely because she appeared on your July 2008
+list.
+We are prepared to address cach of the statements contained in your June 15 letter. First,
+your statement that Mr. Epstein did not use his "best efforts" to enter his guilty plea and to be
+sentenced is, respectfully, without merit. Exhibit 1, June 15, 2009 Letter at 2. The date of entry
+of the state plea was deferred with the express written consent of United States Attorney Acosta,
+who recognized and expressly provided us with the opportunity to pursue an independent
+assessment of this matter by the Justice Department. The subsequent nine-month "delay" was a
+direct result of the Justice Department's determination that it was appropriate to convene an
+intense and time-consuming review. Thus, the delay was not dictated at all by Mr. Epstein, but
+instead, by the review process agreed to and, if you recall, initiated by Mr. Acosta.
+On June 23, 2008, the Justice Department concluded its final review and only seven days
+later, Mr. Epstein promptly entered his plea (on June 30, 2008) and immediately began serving
+his sentence. As the following timeline of events leading up to Mr. Epstein's entry of plea
+makes clear, the facts do not support your conclusion that Mr. Epstein willfully breached the
+NPA by delaying his sentence, and, instead, compellingly demonstrates that Mr. Epstein's
+participation in high-level Department of Justice reviews cannot factually or legally ground a
+claim that he "willfully" breached the NPA:
+• The NPA, signed on September 24, 2007, provides that Mr. Epstein "begin serving his
+sentence not later than January 4, 2008." See Exhibit 2, NPA 9 11.
+• On November 28, 2007, Mr. Epstein's defense counsel contacted Assistant Attorney
+General Alice Fisher to request a review of certain provisions of the NPA. We informed
+the USAO of this request the very next day in a letter to Mr. Acosta. See Exhibit 3,
+November 29, 2007 Letter from J. Lefkowitz to U.S. Attorney Acosta at 4.
+• In a December 4, 2007 letter, Mr. Acosta stated that he supported the defense's appeal to
+Washington. See Exhibit 4, December 4, 2007 letter from U.S. Attorney Acosta to K.
+Starr with a copy to AAG Alice Fisher at 5 ("I do not mind this Office's decision being
+
+
+appealed to Washington, and have previously directed our prosecutors to delay filings in
+this case to provide defense counsel with the option of appealing our decision.").
+• On December 11, 2007, pursuant to Mr. Acosta's request, the defense team sent him
+submissions detailing the defense's concerns related to the NPA.
+See Exhibit 5,
+December 11, 2007 Letter from K. Starr to U.S. Attorney Acosta.
+• On December 14, 2007, Mr. Acosta met with members of the defense team to discuss the
+serious issues raised about the NPA.
+• In a December 19, 2007 letter, Mr. Acosta stated that "the issues raised are important and
+must be fully vetted irrespective of timeliness concerns." See Exhibit 6, December 19,
+2007 Letter from U.S. Attorney Acosta to Attorney Lilly Ann Sanchez at 3. He also
+stated that he had spoken with AAG Fisher to ask that she review this matter and to
+expedite the process. Id.
+• In the beginning of January, 2008, Mr. Acosta and I discussed the need for further
+consideration of the issues raised by the defense. He postponed the plea and sentencing
+until the Child Exploitation and Obscenity Section (CEOS) was finished with its review
+of the case.
+• In a February 29, 2008 email I sent to Mr. Acosta, I confirmed that that "there were
+significant irregularities with the deferred prosecution agreement" and that he would ask
+CEOS to evaluate the matter. I also confirmed Mr. Acosta's agreement to postpone the
+state plea deadline until after the matter was reviewed. On that same day, First Assistant
+U.S. Attorney Sloman responded in writing as follows: "Please be assured that it has not,
+and never has been, this Office's intent to interfere or restrict the 'review process' for
+either Mr. Epstein or CEOS. I leave it to you and CEOS to figure out how best to
+proceed and will await the results of that process." See Exhibits 7 and 8, February 29,
+2008 Emails to U.S. Attorney Acosta and from Assistant U.S. Attorney Sloman.
+• Given that CEOS determined that it would not review many of the defense's objections
+and that its review would be limited on the rest of the objections, CEOS's decision,
+rendered on May 15, 2008, left open the need for a more thorough review of critical
+issues by others at the Justice Department.
+• In a May 28, 2008 email from Mr. Sloman to myself, Mr. Sloman further postponed the
+deadline to plead until the Deputy Attorney General's Office (DAG) completed its
+review. See Exhibit 9, May 28, 2008 Email from Assistant U.S. Attorney Sloman to J.
+Lefkowitz.
+
+
+Page 4
+• A final letter of determination was not issued by the Department of Justice until June 23,
+2008.
+Just one week after that date, Mr. Epstein promptly entered his plea and immediately
+began serving his state sentence on June 30, 2008.
+While you state that a breach occurred because Mr. Epstein and the defense team did not
+provide you with the state plea documents until the last business day before the plea, neither
+Mr. Epstein nor his counsel bear sole responsibility for timing of the delivery of these
+documents. It was the responsibility of the State Attorney's Office to provide the defense with
+the plea agreement. Defense counsel did not receive the plea agreement from the State until
+10:00 A.M. on June 27, 2008 (the Friday before the plea). See Exhibit 10, June 27, 2008 Email
+from State Attorney Lanna Belohlavek to J. Goldberger. Once the plea agreement was reviewed
+by Mr. Epstein's defense team, Mr. Goldberger sent it to you that same afternoon. At 5:55 P.M.
+on June 27, 2008, following your receipt of the agreement sent to you by Mr. Goldberger,
+Messrs. Black and Goldberger received a responsive letter from you alleging that the plea
+agreement violated the NPA. See Exhibit 11, June 27/28, 2008 Email String between Assistant
+U.S. Attorney Villafana and R. Black and J. Goldberger (attaching Notice of Non-Compliance).
+Second, you state that language contained in the first draft of the plea agreement
+proposed by the State violated the NPA, because it called for community control in lieu of jail.
+Exhibit 1, June 15, 2009 Letter at 2. You now suggest that this "error" evidences Mr. Epstein's
+alleged efforts to undermine the NPA. I respectfully submit that you are mistaken in both cases.
+The language in the first draft of the plea agreement was prepared by the State and, as stated
+above, it was not sent to the defense until the very day that it was sent to you.
+Moreover, as Mr. Goldberger confirmed to you in a telephone conversation on the same
+day that he received your June 27 letter, the plea agreement, as originally drafted by the State,
+would have resulted in the exact same 12-month and 6-month consecutive jail sentences,
+followed by one year of community control, as was required by the NPA and ultimately imposed
+on Mr. Epstein. Although defense counsel asked the State to change the language of the plea
+agreement to alleviate your concerns, the same exact sentence and period of incarceration as
+required by the NPA would have been imposed on Mr. Epstein had the language of the State's
+first draft been allowed to apply. See Exhibit 11, June 27/28, 2008 Email String between
+Assistant U.S. Attorney Villafana and R. Black and J. Goldberger (confirming a telephone
+conversation between the parties on June 27 that the state plea agreement was in compliance
+with the NPA and indicating a request by Assistant U.S. Attorney Villafana to modify the
+language in the state plea agreement); see also Exhibit 12, the initial version and the signed
+version of the state plea agreements.
+
+
+Page 5
+The bottom line here is that while Florida counsel for Mr. Epstein fully believed that the
+initial language in the State's draft would result in a sentence identical to the mandates of the
+NPA, changes were made solely to conform to your requests. Neither the USAO or the
+administration of federal criminal justice suffered any prejudice: lawyers often make linguistic
+alterations of form; we did so here. The changes were made in short order, namely, during the
+Friday and Saturday before Mr. Epstein's state plea; the plea and plea agreement completely
+complied with the NPA as did Mr. Epstein's sentence; and there was neither a breach, nor harm.
+Moreover, all communications were through counsel. Mr. Epstein was not a party to these
+communications and in no way can be considered, factually or legally, to have committed a
+"willful" breach of the NPA in this regard.
+Third, you state that defense "counsel obstructed [your] ability to abide by [your]
+obligations to notify the victims of the outcome of the federal investigation." Exhibit 1, June 15,
+2009 Letter at 2. We believe that this statement misconstrues the intentions and conduct of the
+defense team and, does not support any charge of "obstruction" against Mr. Epstein, as would be
+required to sanction him for a "willful" breach of the NPA. In October 2007, a full nine months
+the alleged victims be contacted by the selected attorney representative. See Exhibit 13, October
+10, 2007 Letter from J. Lefkowitz to U.S. Attorney Acosta at 4-5.
+Then, on November 28, 2007, you sent defense counsel the proposed victim notification
+letter indicating that the alleged victims had a federal right to be notified of the resolution of this
+matter pursuant to the Crime Victims' Rights under § 3771. See Exhibit 14, November 29, 2007
+Draft Victim Notification Letter from Assistant U.S. Attorney Villafana. Mr. Epstein's counsel
+objected to your draft letter and the proposed method and procedure for notifying the alleged
+victims and challenged whether you were in fact obligated to notify these individuals pursuant to
+18 U.S.C. § 3771. Those objections were made in a timely and appropriate manner and our
+dialogue regarding notification issues continued. As you know, the notification letter was not
+finalized for several months.
+The key point here is that our objections to the letter were made in good faith and were
+well-founded. After all, on December 6, 2007, Mr. Acosta agreed to many of our objections and
+adopted several of our modifications to resolve problems raised by the draft notification letter.
+See Exhibit 15, December 6, 2007 Letter from U.S. Attorney Acosta to J. Lefkowitz. This fact
+confirms both the good-faith nature of our objections and that neither Mr. Epstein nor his counsel
+could be considered to have violated the NPA by raising those objections in the first place.
+Fourth, Mr. Epstein did not, as you stated, refuse "to fulfill promptly Mr. Epstein's
+obligation to secure the services of an attorney representative for the victims." Exhibit 1, June
+ETA00194724
+
+Page 6
+15, 2009 Letter at 2.
+It was the United States' obligation to select a suitable attorney
+representative, subject to the good-faith approval of Mr. Epstein's counsel. See Exhibit 2, NPA
+17. Indeed, due to a concern we had raised, your Office specifically modified the procedure to
+select an attorney representative and delegated that task to Judge
+• See Exhibit 16,
+Addendum to NPA 91 7A. Again, the fact that your Office accommodated our concerns validates
+their legitimacy and undermines any claim that the NPA was breached by raising those concerns
+with you. To the contrary, Mr. Epstein executed the Addendum in an attempt to resolve
+outstanding, highly unorthodox and complex issues at the intersection of civil and criminal law.
+A letter to Judge |
+| (authored by then FAUSA Sloman) dated October 25, 2007 followed.
+See Exhibit 17, October 25, 2007 Letter to Judge
+Once Mr. Podhurst's firm was selected by Judge
+, Mr. Epstein did not object to the
+selection. Moreover, as you have acknowledged to the court, the open issues involving the
+attorney representative portions of the NPA were not finally resolved until September 3, 2008.
+See Exhibit 18, December 22, 2008 Villafana Supplemental Declaration at 3 1 9. Only five days
+later, on September 8, 2008, I sent a letter to Robert Josefsberg advising him that Mr. Epstein
+would pay his fees pursuant to the NPA for his role as an attorney representative. See Exhibit
+19, September 8, 2008 Letter from J. Lefkowitz to R. Josefsberg. Furthermore, in an effort to
+comply with the obligations under the NPA, Mr. Epstein already has paid Mr. Podhurst's firm
+over $160,000 in legal fees, despite significant concerns over the scope of the work for which he
+is billing Mr. Epstein, and has agreed with Mr. Josefsberg's proposal that a Special Master be
+empowered to resolve any fee related issues that the Podhurst firm and Mr. Epstein's civil
+counsel cannot resolve. See Exhibit 20, June 15, 2009 Letter from Robert Critton to Kathy Ezell.
+There is nothing about the exchanges between counsel and the USAO regarding the attorney
+representative that even begins to approach a "willful" breach by Mr. Epstein.
+Fifth, you suggest that Mr. Epstein willfully breached the NPA because of the actions of
+Mr. Tein and Mr. Goldberger, whom you state failed to approve the victim notification letter that
+contained incorrect information. See Exhibit 1, June 15, 2009 Letter at 2. The incorrect
+information in the letter was a proposed unilateral modification to the NPA without prior
+approval by Mr. Epstein or any member of the defense team. It was only first suggested by your
+Office in a letter from Mr. Acosta on December 19, 2007. We never agreed to that language. In
+fact, I personally raised several objections to the suggested modification in my letter to Mr.
+Acosta, dated December 21, 2007. See Exhibit 21, December 21, 2007 Letter from J. Lefkowitz
+to U.S. Attorney Acosta. I personally became aware of the inclusion of that language on
+Wednesday, August 13, 2008 and discussed the matter with you immediately. See Exhibits 22
+and 23, August 13 and 15, 2008 Letters from Assistant U.S. Attorney Villafana to J. Lefkowitz
+(confirming that the "December modification" is not a part of the NPA). Again, that oversight
+was not a willful breach or an expression of intent to violate the terms of the Agreement, but
+instead represented the efforts of counsel, acting in good faith, in an attempt to insure that the
+letter contained only previously agreed-upon language.
+
+
+Page 7
+Sixth, you raise the issue of a delayed withdrawal of a motion to quash. See Exhibit 1,
+June 15, 2009 Letter at 2-3. There is no motion to quash that still remains pending. The fact that
+the motion was not withdrawn for some time was merely due to an administrative oversight that
+has long been remedied, but at no time did it prejudice the Government in any way. Nor did it
+result from an effort by myself or co-counsel to gain some tactical advantage. Furthermore, no
+effort was made by any counsel to seek a judicial decision on the pending motion. The motion
+had no adverse effect on the Government, and the delay in its withdrawal is legally and factually
+unrelated to the type of material and willful breach that alone could warrant remedies—-not least
+of all because Mr. Epstein has suffered irreversible prejudice by complying with the core
+provisions of the NPA. Again, he has been imprisoned, he has pled guilty, he is registered, he
+has paid sums to claimants, all to comply with his obligations under the NPA.
+Seventh, you state that additional issues arose in November regarding the issuance of
+work release to Mr. Epstein. Exhibit 1, June 15, 2009 Letter at 3. We have previously reviewed
+this very matter with you and other individuals in your Office in November 2008. At that time,
+Mr. Roy Black met with you, Karen Atkinson, Bob Senior, and Jeffrey Sloman in Miami to
+review the work release issue. Among other significant documents shown to you, we presented
+you with your own email in which you had previously acknowledged that the sheriff had
+discretion in the matter. See Exhibit 24, July 3, 2008 Email from Assistant U.S. Attorney
+Villafana to Michael Gauger ("If Mr. Epstein is truly eligible for the [work release] program, we
+have no objection to him being treated like any other similarly situated prisoner ...").
+Furthermore, Mr. Acosta, as already stated, had previously assured me and other counsel that the
+USAO would not interfere in the ordinary implementation of discretionary administrative
+decisions by state or county officials. We believe we were under no obligation (in the NPA or
+anywhere else) to notify you of such discretionary and ordinary state-made decisions, and the
+fact that your Office confirmed that Mr. Epstein was entitled to the same discretionary
+administrative decisions as other similarly situated inmates fundamentally undermines any claim
+that Mr. Epstein breached the NPA in connection with the state and county officials' decision. In
+any event, after thoroughly reviewing and evaluating Mr. Epstein's application, the Palm Beach
+County Sheriff's Office properly exercised its discretion, in full compliance with its stated
+requirements, policies and procedures, to grant Mr. Epstein work release. In addition, after the
+Sheriff's Office received a multi-page letter from you to Captain Sleeth, which recited the very
+allegations of errors on Mr. Epstein's work release application to which you refer in your latest
+letter, each allegation was fully reviewed, and the Sheriff's office found its initial decision
+appropriate.
+Eighth, it is both unreasonable and unjustifiable to hold Mr. Epstein responsible-never
+mind declare him in breach—with regard to Judge McSorley's nunc pro tunc order. Exhibit 1,
+June 15, 2009 Letter at 3. Neither Mr. Epstein nor defense counsel had anything to do with and
+certainly no prior knowledge of this order. Defense counsel only learned of it after you brought
+it to our attention. The facts are as follows: the Department of Corrections requires an order
+
+
+Page 8
+placing someone on community control before the Department of Corrections will supervise that
+person. Judge Pucillo, the retired judge that took Mr. Epstein's plea, inadvertently neglected to
+enter the order placing Mr. Epstein on Community Control 1. When Judge McSorley learned of
+this, she properly entered the order nunc pro tunc to the date of the plea. See Exhibit 25, Order
+of Community Control. If you will note on the 3-page court event form, circled at the top of
+page 2, is "C.C.1" (community control 1). Mr. Epstein was properly placed on community
+control 1 on the day of his plea to begin only after he completes his jail sentence, and the nunc
+pro tunc order simply ratifies the oral pronouncement made by the court at the time of the plea.
+Given that the NPA expressly provides that Mr. Epstein is to serve a sentence of 12 months in
+"community control consecutive to his two terms in county jail," Exhibit 2, NPA 9 2(b), your
+assertion that the inclusion of community control "directly contradicted the terms of the" NPA is
+incorrect.
+Finally, the motion to dismiss that was the topic of discussion on June 12 has been
+withdrawn. As indicated in the letter I sent you on June 15, we have adopted an internal
+screening process aimed at eliminating future concerns about anything that reasonably could be
+considered a breach of the NPA. See Exhibit 26, June 15, 2009 Letter from J. Lefkowitz to
+Assistant U.S. Attorney Villafana. Mr. Epstein has directed all counsel to make certain that no
+filing could be construed as a breach of the NPA. Furthermore, we proposed a supplemental new
+process, as stated in my June 15 letter to you, that would have provided you, if you chose, the
+opportunity to review any such filing before it is submitted to the court so that you may
+determine whether or not it constitutes a breach.
+That being said, I wish to reiterate our firm belief that the NPA allowed Mr. Epstein the
+right to contest litigation whenever an express waiver of all other state, federal or common law
+claims or the right to bring contested litigation in the future was not sufficiently or correctly
+pleaded. As you know, we spent several weeks negotiating the language of the NPA with you
+and Mr. Acosta. We firmly believe that the motion to dismiss that was recently filed (and then
+promptly withdrawn) did not constitute a violation.
+First, Paragraph 8 of the NPA clearly limits those who may benefit from any waivers by
+Mr. Epstein to an "identified individual" who "elects to proceed exclusively under 18 USC 2255,
+and agrees to waive any other claim for damages, whether pursuant to state, federal, or common
+law". Exhibit 2, NPA 118. More is required of a plaintiff than to simply allege, as did Jane Doc
+101, that she "exclusively seeks civil remedies pursuant to 18 USC 2255." Exhibit 27, Amended
+Complaint 9 24. Such an averment satisfies only the exclusivity portion of the twin conditions
+set forth in the NPA at 9| 8. The word "and" followed by the requirement of an affirmative
+waiver of any other claims, federal, state, or common law mandates an additional affirmative act
+by the plaintiff. No such waiver was filed or even pled. Jane Doe 101 did no more than restate
+that her complaint in civil action no 9:09-cv-80591-KAM was only for 2255 damages. She
+never affirmatively waived all future claims in state or federal court, as required by the NPA.
+
+
+Page 9
+Because of this threshold issue, Jane Doe 101 did not, through the attorney representative, satisfy
+the NPA 1 8 requirements.! While Mr. Epstein's counsel still believe for these reasons that the
+motion did not conflict with Mr. Epstein's obligations under the NPA, the motion was in relevant
+part withdrawn at Mr. Epstein's insistence further demonstrating that Mr. Epstein has
+prioritized his desire to avoid contentious additional litigation with the USAO over this matter.
+In short, our good-faith efforts to raise litigation issues will be more carefully scrutinized
+in the future as to limit the possibility of being construed by your Office as supporting a notice
+that Mr. Epstein is in "willful" breach. Issues regarding the scope of the 9l 8 waivers are
+unorthodox and even unprecedented. They result in part from the NPA being executed before
+you identified the individuals listed, see Exhibit 2, NPA 1 7, and, importantly, given the
+evolution of the civil litigation, before any joint statement as required by the terms of the NPA
+was provided to Mr. Josefsberg. Nevertheless, as we stated on June 15, we had intended to
+provide you with future filings in advance so that we could discuss their interaction with the
+NPA before rather than after any filing, However given your rejection of that procedure, in a
+good faith attempt to avoid future conflict, we would nevertheless hope to clarify some of the
+more ambiguous parts of 9|8 of the agreement with you as soon as possible. To repeat, it is
+Mr. Epstein's overriding intent to fulfill his obligations under the NPA -- an intent we as his
+attorneys will do everything in our power to effectuate.
+The facts demonstrate that Mr. Epstein has clearly not committed any breach of the NPA,
+much less a willful breach.
+As we have reiterated and as has been proven by Mr. Epstein's own
+actions, Mr. Epstein has no intention of breaching the NPA and has never had any such intention.
+Although you claim that Mr. Epstein received the benefits of the NPA and the Government only
+its burdens, I believe the reality is to the contrary. Mr. Epstein has suffered significant and
+irreversible prejudice: he has been imprisoned in a county jail for almost a year, he has pleaded
+guilty to a state felony that required sex registration and has, in fact, registered as a sex offender,
+he accepted civil burdens in his ongoing litigation that may result in millions of dollars of future
+payments, he has settled cases that could be won, in deference to the NPA and he is paying and
+1
+That Jane Doe 101 did not meet the threshold requirements for the imposition of the waiver of liability portion
+of Paragraph 8 of the NPA is demonstrated by the filings of Jane Doe II in 09-80469-CIV-Marra, a federal
+lawsuit filed in March, 2009 seeking "exclusively 2255" damages, while Jane Doe II already had a pending
+state court suit filed in July of 2008 seeking damages against Epstein for sexual assault and conspiracy. Jane
+Doe II in her federal complaint alleged Epstein could "not contest liability for claims brought exclusively
+pursuant to 18 U.S.C. §2255". Exhibit 27, Amended Complaint 1 24. In her response to Epstein's Motion to
+Dismiss in which Epstein challenged the "exclusivity" claim, she argued at page 7 that "Epstein appeared to be
+violating the agreement... [NPA]". However, her attorney withdrew that claim at the June 12, 2009 hearing
+(and in her subsequent Amended Response) agreeing that the state filing negated the "exclusivity" of the federal
+2255 lawsuit. On the current record, nothing prevents Jane Doe 101 from filing a parallel state court claim.
+
+
+Page 10
+will pay hundreds of thousands of dollars in legal fees for his adversaries to pursue him in court.
+The Government may have endured some delays and administrative costs due to certain of its
+own its decision — such as to evaluate the Sheriff's exercise of discretionary authority in
+implementing the Sheriff's own work release program but neither the Government nor any
+civil plaintiff has suffered any harm, any prejudice, or any disadvantage as a result of the events
+you have identified. We signed a contract -- the NPA -- with you in good faith, and in exchange,
+Mr. Epstein gave consideration that cannot be returned (12 months of his freedom and his
+reputation). He is legally entitled to its benefits. He committed no "willful breach." As such,
+we believe it would constitute both a contractual and constitutional error to seek further remedy
+or to in any way withdraw from the NPA.
+We will continue to make our best efforts to communicate with you about any potential
+problems and hope, in the interest of fairness, you will do the same.
+Sincerely,
+Say P hel
+Enclosures
+
+
+DEDICATUD TO JUSTICE & SAFETY
+LEOPOLD-KUVIN™
+July 6, 2009
+A. Maria Villafana, Esq.
+Assistant U.S. Attorney
+500 E. Broward Blyd, 7th Floor
+Ft. Lauderdale, FL 33394
+Re: B.B. J. JEFFREY EPSTEIN
+OUR FILE NO.: 080303
+Dear Ms. Villafana:
+As you are aware, this firm represents Plaintiff, Jane Doe, a/k/a/ B.B. in the civil litigation
+against Jeffrey Epstein styled B.B. I. Jeffrey Epstein, case no.: 502008CA037319 MB AB. We
+are hereby requesting that a copy of the non-prosecution agreement be provided to my office as
+If there are any questions or concerns regarding the production of this agreement, please contact
+me at once.
+Sincerely,
+PENCER T. KOVI
+STK/mlb
+":"
+2925 PGA Boulevard i Suite 200 :; Palm Beach Gardens 5 Florida 33410 :: 561.515.1400 : fax 561.515.1401 : leopoldkuvin.com
+CRASHWORTHINESS • MANAGED CARE ABUSE • CONSUMER CLASS ACTIONS • PERSONAL INJURY • WRONGFUL DEATH
+
+
+500 E. Broward Boulevard, 7th Floor
+Ft. Lauderdale, FI. 33394
+(954) 356-7255
+July 7, 2009
+DELIVERY BY ELECTRONIC MAIL
+Jay P. Lefkowitz, Esq.
+Kirkland & Ellis LLP
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4675
+Re:
+Jeffrey Epstein
+Dear Jay:
+Thank you for your letters of June 19th. From your letters, it appears that you have
+misconstrued the Office's past efforts at alleviating Mr. Epstein's unfounded fears of
+disparate treatment. You seem to have interpreted those efforts as either: (1) an
+acknowledgement of the validity of those fears, or (2) an acquiescence to the efforts of Mr.
+Epstein to avoid the full terms of the Non-Prosecution Agreement. So, for example, you
+write that, in an email to Mr. Acosta, you "confirmed that 'there were significant
+irregularities with the deferred prosecution agreement,'" and that "Mir. Acosta agreed to
+many of our objections and adopted several of our modifications ... [and] ItJhis fact
+confirms both the good-faith nature of our objections and that neither Mr. Epstein not his
+counsel could be considered to have violated the NPA by raising those objections in the first
+place." Neither your e-mails nor Mr. Acosta's consistent attempts to maintain a good
+working relationship with you act as modifications to the NPA or indications that the Office
+agreed or acquiesced to your positions.
+While your letter provides great detail regarding all of the objections that you raised'
+'In an effort to terminate the endless "battle of letters" that this case has become, I have
+the procedure to select an attorney representative and delegated that task to Judge
+
+
+JAY P. LEFKOWITZ, ESQ.
+JULY 7,2009
+
+throughout the nine-month delay between the signing of the NPA and Mr. Epstein's
+commencement of performance, you neglect to mention that all of your objections were
+soundly rejected at each and every level of review, from West Palm Beach, to Miami, to the
+Child Exploitation and Obscenity Section, and, finally, to the highest levels of review at the
+Department of Justice. As Senior Associate Deputy Attorney General John Roth stated:
+Even if we were to substitute our judgment for that of the U.S. Attorney, we
+believe that federal prosecution of this case is appropriate. Moreover, having
+reviewed your allegations of prosecutorial misconduct, and the facts
+underlying them, we see nothing in the conduct of the U.S. Attorney's Office
+that gives us any reason to alter our opinion.
+With regard to your proposal to engage in additional discussions regarding the scope
+of the NPA, we respectfully decline. A great deal of time and effort went into the negotiation
+and signing of the NPA, and the Agreement speaks for itself. Contrary to your assertion,
+both the government and the victims have suffered harm and prejudice due to the willful
+breaches of the NPA by Mr. Epstein. The Office will continue to evaluate its position and
+will proceed accordingly.
+By:
+Sincerely,
+Jeffrey H. Sloman
+Acting United States Attorney
+s/A. Marie Villafaña
+A. Marie Villafaña
+Assistant United States Attorney
+CC:
+Jack Goldberger, Esq.
+Roy Black, Esq.
+fact that your Office accommodated our concerns validated their legitimacy ..." As you have been
+told repeatedly, the decision to delegate that task to a Special Master was made independently and
+before any of Mr. Epstein's attorneys voiced a concern about that process. Mr. Lefkowitz, you were
+provided with a list of potential attorney representatives and with information in writing regarding
+the alleged "conflict of interest," and you made the selection that you later claimed was problematic.
+Notwithstanding your agreement on the selection of the attorney-representative, our Office,
+independently, elected to ask an independent third party to make the final decision.
+
+
+A LIMITED LIABILITY PARTNERSHIP
+DELQUI J. BENAVEN
+RALEGAL/ INVESTIGATO
+MARK T. LUTTIER, PA.
+MICHAEL J. PIKE
+HEATHER MONAMARA RUDA
+July 8, 2009
+RITA H. BUDNYK
+OF COUNSEL
+SENT BY FEDERAL EXPRESS
+A. Marie Villafana, Esq.
+Assistant U.S. Attorney
+500 East Broward Boulevard, 7" Floor
+Ft. Lauderdale, FL 33394
+Re:
+Jane Doe No. 81 Jeffrey Epstein
+Case No. 09-CV-80802-Marra/Johnson
+Dear Ms. Villatana:
+As you are aware, I am Mr. Epstein's attorney in the civil cases that have been
+filed against him. While I am certainly familiar with the NPA, it is clear to me that my
+interpretation of it may differ from yours (USAO) or one of the many plaintiffs' attorneys
+as it relates to what I can do or assert in defense of Mr. Epstein.
+As I expressed to Judge Marra, my charge from Mr. Epstein is to take no action
+that could reasonably be considered to be a violation of the NPA. With that in mind, I
+am sending our motion to dismiss in Jane Doe #8, along with a copy of her complaint.
+While I know you expressed to Mr. Lefkowitz that you (USAO) were not inclined
+to review pleadings and offer advisory opinions, I would ask that you reconsider and
+review our motion.
+The Plaintiff Jane Doe No. 8 is not exclusively asserting a claim pursuant to 18
+U.S.C. §2255, and thus, the terms of the NPA are not implicated. In fact, Jane Doe No.
+8's counsel, Adam Horowitz, who also is counsel for Plaintiffs Jane Does Nos. 2 through
+7 in other civil actions against Mr. Epstein, in the June 12, 2009 hearing before U.S.
+District Judge Kenneth Marra (at which you were also present) conceded that -
+The provision (of the NPA) relating to Mr. Epstein being unable to contest
+liability pertains only to those plaintiffs who have chosen as their sole remedy
+L'A•W•Y•E•R•S
+515 N. FLAGLER DRIVE / SUITE 400 / WEST PALM BEACH, FLORIDA 33401
+mail@bclclaw.com
+
+
+July 8, 2009
+the federal statute. My clients, Jane Doe 2 through 7, have elected to bring
+additional causes of action, and it's for that reason we were silent when you
+said does anyone here find Mr. Epstein to be in breach of the nonprosecution agreement. This provision, as we understand it, it does not
+relate to our clients.
+June 12, 2009, Transcript of hearing in Jane Doe, et al I. Epstein, Case No. 08-
+80119-Civ-Marra, U.S. District Ct., S.D. Fla., p. 29, line 19-25, p. 30, line 1. A
+copy of the relevant portions of the hearing transcript is enclosed.
+I agree with his comments as they relate to all of his clients, including Jane Doe 8.
+I believe that nothing in this motion involves any aspect of the NPA. It you disagree,
+would you please contact me as soon as possible. I must file this motion by July 14
+per my extension agreement with Mr. Horowitz. However, I stand ready to have a
+discussion or meeting with you regarding this motion or any other civil related pleadings
+or matter that may implicate the NPA. I look forward to your response.
+Cordially yours,
+Robert D. Critton, Jr.
+RDC/clz
+cc by pdf:
+Jack A. Goldberger, Esq.
+Martin G. Weinberg, Esq.
+Roy Black, Esq.
+Jay Lefkowitz, Esq.
+
+
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 09-CV-80802-MARRA-JOHNSON
+JANE DOE NO. 8
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT EPSTEIN'S MOTION TO DISMISS PLAINTIFF'S COMPLAINT
+Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his attorneys, moves
+to dismiss Counts I and III of Plaintiff's Complaint as the causes of action are barred by
+the applicable statute of limitations.' Rule 12(b)(6); Local Gen. Rule 7.1 (S.D. Fla.
+2009). In support of dismissal, Defendant states:
+Plaintiff's Complaint attempts to allege three Counts; the first two counts are
+pursuant to state common law, and the third count is brought pursuant to 18 U.S.C.
+§2255. Civil remedy for personal injuries. Count | attempts to allege a cause of action
+for "Sexual Assault and Battery," Count II for "Intentional Infliction of Emotional
+Distress;" and Count Ill for "Coercion and Enticement to Sexual Activity in Violation of
+18 U.S.C. §2422," pursuant to 18 U.S.C. §2255.
+' Plaintiff's Complaint attempts to assert both state common law claims and a claim pursuant to
+18 U.S.C. §2255. Since Jane Doe 8 did not relinquish her state claims and correspondingly did
+not file her complaint relying, exclusively, on 18 USC 2255, she is not entitled to the litigation
+benefits including certain waivers that directly or indirectly accrue to other civil plaintiffs from the
+defendant's fulfilling obligations resulting from his separate confidential agreement with the
+United Staes Attorney's Office. Plaintiff's counsel conceded that the provisions of the NPA are
+not implicated where a plaintiff brings additional causes of action and does not proceed
+exclusively under §2255. See June 12, 2009, Hearing Transcript in Jane Doe, et al . Epstein,
+Case No. 08-80119-Civ-Marra, p. 29, line 19-25, p. 30, line 1.
+
+
+Pursuant to the allegations on the face of Plaintiff's complaint, Count I, based on
+Florida's common law of assault and battery, and Count III, brought pursuant to 18
+U.S.C. §2255, are barred by the applicable statute of limitations. Although a statute of
+limitations bar to a claim is an affirmative defense, and a plaintiff is not required to
+negate an affirmative defense in her complaint, a Rule 12(b)(6) dismissal on statute of
+limitations grounds is appropriate where, as here, "it is 'apparent from the face of the
+complaint' that the claim is time-barred." See generally, La Grasta |. First Union
+Securities, Inc., 358 F.3d 840, 845-846 (11" Cir. 2004).
+Count I is barred by the applicable statute of limitations.
+As to Count I, which is plead pursuant to state law, it is well settled that this Court
+is to apply Florida law. Erie R.Co. |. Tompkins, 58 S.Ct. 817 (1938). Pursuant to
+Florida law, the statute of limitations for assault and battery is four years, §95.11(3)(o).,
+Fla. Stat. §95.11(3)(o), Fla. Stat., provides -
+Actions other than for recovery of real property shall be commenced as
+follows:
+*
+(3) Within four years.—
+(0) An action for assault, battery, false arrest, malicious prosecution,
+malicious interference, false imprisonment, or any other intentional tort,
+except as provided in subsections (4), (5), and (7).
+In her Complaint, Plaintiff alleges in relevant part that -
+9. ... In or about 2001, Jane Doe, then approximately 16 years old, fell
+into Epstein's trap and became one of his victims.
+According to the allegations of the Complaint, Jane Doe had one encounter with
+Defendant at his Palm Beach mansion in or about 2001 when Jane was approximately
+
+
+Jane Doe No. 8 | Epstein
+16 years old. See Complaint, 113, endnote 1 hereto.' Based on the allegations of the
+Complaint, it has been at least 8 years since the alleged conduct by EPSTEIN, well past
+the four year statute of limitations, thus requiring dismissal of Count I. Based on the
+allegations, Plaintiff is now at least 24 years old.
+Subsections (4) and (5) referenced in §95.11(3)(o) are not applicable. Plaintiff
+may attempt to argue that subsection (7) of §95.11, Fla. Stat. applies. See endnote 2
+hereto for statutory text of subsection (7), including statutes referenced therein?
+However, a review of Plaintiff's allegations in Count I establish that Plaintiff is attempting
+to assert a cause of action based on the elements of Florida's common law assault and
+battery to which a four year statute of limitation applies. (Compare Count II, 124,
+wherein Plaintiff tracks the language §39.01(2), Fla. Stat. (2001), pertaining to "abuse.").
+Pursuant to Florida law, although the term "assault and battery" is most
+commonly referred to as if it were a legal unit, or a single concept, "assault and battery
+are separate and distinct legal concepts, assault being the beginning of an act which, if
+consummated, constitutes battery." 3A Fla.Jur.2d Assault §1. An assault and battery
+are intentional acts. See generally, Spivey |. Battaglia, 258 So.2d 815 (Fla. 1972); and
+Travelers Indem. Co. |. PCR, Inc., 889 So.2d 779 (Fla. 2004).
+On the face of the Complaint, the applicable four year statute of limitations has
+expired, and accordingly, Count I is barred an required to be dismissed.
+Count III - 18 U.S.C. §2255
+
+
+Page 4
+As to the applicable statute of limitations for Count Ill which is brought pursuant to
+18 U.S.C. §2255, §2255(b), (both the 2001 version, which Defendant asserts is the
+applicable statute, and the amended version, effective July 27, 2006), provides:
+(b) Statute of limitations.—Any action commenced under this section
+shall be barred unless the complaint is filed within six years after the right
+of action first accrues or in the case of a person under a legal disability,
+not later than three years after the disability.
+As noted above, according to the allegations of the Complaint, Jane Doe had one
+encounter with Defendant at his Palm Beach mansion in or about 2001 when Jane was
+approximately 16 years old. See Complaint, 113, endnote 1 hereto. Based on the
+allegations of the Complaint, it has been at least 8 years since the alleged conduct by
+EPSTEIN, well past the six year statute of limitations, thus requiring dismissal of Count
+III. Based on the allegations, Plaintiff is now at least 24 years old, well pass the age of
+majority. (The age of majority under both federal and state law is 18 years old. See 18
+U.S.C. §2256(1), defining a "minor" as "any person under the age of eighteen years;"
+and §1.01, Definitions, Fla. Stat., defining "minor" to include "any person who has not
+attained the age of 18 years."). Thus, on the face of the Complaint, Count Ill is timed
+barred and required to be dismissed.
+Conclusion
+Accordingly, Counts I and III of Plaintiff's Complaint are subject to dismissal. On
+the face of the Complaint, the causes of action which Plaintiff attempts to allege are
+barred by the applicable statute of limitations of 4 and 6 years, respectively.
+WHEREFORE, Defendant requests that this Court dismiss Counts I and Ill of
+Plaintiff's Complaint with prejudice.
+
+
+Jane Doe No. 8 I. Epstein
+Page 5
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this
+_day of
+, 2009:
+Stuart S. Mermelstein, Esq.
+Jack Alan Goldberger, Esq.
+Adam D. Horowitz, Esq.
+Atterbury Goldberger & Weiss, P.A.
+18205 Biscayne Boulevard
+250 Australian Avenue South
+Suite 2218
+Suite 1400
+Miami, FL 33160
+West Palm Beach, FL 33401-5012
+305-931-2200
+561-659-8300
+Fax: 305-931-0877
+Fax: 561-835-8691
+ahorowitz@hermanlaw.com
+jagesq@bellsouth.net
+Irivera@hermanlaw.com
+Counsel for Defendant Jeffrey Epstein
+Counsel for Plaintiff Jane Doe #8
+Respectfully submitted,
+& COLEMAN, LLP
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+(561) 842-2820
+By:
+Robert D. Critton, Jr.
+Florida Bar #224162
+Michael J. Pike
+Florida Bar #617296
+Counsel for Defendant Jeffrey Epstein
+rcrit@bclclaw.com
+mpike@bclclaw.com
+'Complaint, 113 alleges in relevant part -
+... Jane Doe was recruited by another girl, who told her that she could make some
+money, but did not tell her what was involved. At all relevant times, the girl who
+recruited Jane Doe was acting on behalf of and as an agent for Epstein. Jane was
+
+
+Page 6
+contacted by this girl by telephone. Jane was then picked up and brought to
+Epstein's mansion in Palm Beach. Once there, she was lead up a flight of stairs to
+the room with the massage table. Epstein came into the room and directed Jane
+to remove her clothes and give him a massage. Jane was frightened and felt
+trapped. As directed by Epstein, Jane removed her clothes. Epstein then during
+the massage touched Jane on her breasts and vagina, and he grabbed her hand
+and placed it on his penis. Epstein masturbated himself during the massage.
+Epstein then left money for Jane.
+2 §95.11(7), Fla. Stat. -
+(7) For intentional torts based on abuse.--An action founded on alleged abuse,
+as defined in s. 39.01, s. 415.102, or s. 984.03, or incest, as defined in s. 826.04,
+may be commenced at any time within 7 years after the age of majority, or within 4
+years after the injured person leaves the dependency of the abuser, or within 4
+years from the time of discovery by the injured party of both the injury and the
+causal relationship between the injury and the abuse, whichever occurs later.
+§39.01(2), Fla. Stat. (2001) -
+(2) "Abuse" means any willful act or threatened act that results in any physical,
+mental, or sexual injury or harm that causes or is likely to cause the child's
+physical, mental, or emotional health to be significantly impaired. Abuse of a child
+includes acts or omissions. Corporal discipline of a child by a parent or legal
+custodian for disciplinary purposes does not in itself constitute abuse when it does
+not result in harm to the child.
+§415.102(1), Fla. Stat. (2001) -
+(1) "Abuse" means any willful act or threatened act that causes or is likely to cause
+significant impairment to a vulnerable adult's physical, mental, or emotional
+health. Abuse includes acts and omissions.
+§984.03 (2), Fla. Stat. (2001) -
+"Abuse" means any willful act that results in any physical, mental, or sexual injury
+that causes or is likely to cause the child's physical, mental, or emotional health to
+be significantly impaired. Corporal discipline of a child by a parent or guardian for
+disciplinary purposes does not in itself constitute abuse when it does not result in
+harm to the child as defined in s. 39.01.
+
+
+Herman &Mermelsteln, P
+02:33:18p.m. 01-06-2009
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 09-CV-80802-Marra-Johnson
+JANE DOE NO. 8,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+May 28, 2009
+COMPLAINI
+Plaintiff, Jane Doe No. 8 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey
+Epstein, as follows:
+Parties, Jurisdiction and Venue
+Jane Doe No. 8 ("Jane Doe") is a citizen and resident of the State of Florida, and is
+sui juris.
+This Complaint is brought under a fictitious name to protect the identity of the
+Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a
+minor.
+Defendant Jeffrey Epstein is a oitizen and resident of the State of New York, and
+presently serving a prison sentence in Palm Beach County, Florida for, inter alía, solicitation of
+prostitution and solicitation of minors to engage in prostitution..
+This is an action for damages in excess of $50 million.
+This Court has jurisdiction of this action and the claims set forth herein pursuant to 28
+U.S.C. § 1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs;
+MERMELSTEIN & HOROWITZ, P. A.
+www.sexabusealtomney.com
+- 1-
+1 otT
+
+
+02:33:35 p.m.
+01-06-2009
+5/8
+and (ii) is between citizens of different states.
+6. Additionally, this Court has jurisdiction pursuant to 28 U.S.C. §1331 because
+Plaintiff alleges a claim under the laws of the United States. This Court has supplemental
+jurisdiction pursuant to 28 U.S.C. §1367(a) over all other claims set forth herein which form part of
+the same case or controversy.
+7.
+This Court has venue of this action pursuant to 28 U.S.C. §§1391(a) and 1391(b) as a
+substantial part of the events or omissions giving rise to the claim occurred in this District.
+Factual Allegations
+At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male in his
+early 50's. Epstein is a financier and money manager with a secret clientele limited exclusively to
+billionaires. He is himself a man of tremendous wealth, power and influence. He maintains his
+principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach,
+FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach.
+Upon information and belief, Epstein has a sexual preference and obsession for
+underage minor girls. He engaged in a plan and scheme in which he gained access to primarily
+economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave
+them money. In or about 2001, Jane Doe, then approximately 16 years old, fell into Epstein's trap
+and became one of his victims.
+10. Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted
+girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas.
+11. Epstein's scheme involved the use of young girls to recruit underage girls. These
+underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation
+Mermelstein & HorowITz, P. A.
+- 2-
+
+
+02:34:03 p.m.
+01-06-2009
+6/8
+•
+in his Palm Beach mansion. Epstein, upon information and belief, generally sought out economically
+disadvantaged underage girls from Palm Beach County who would be enticed by the money being
+offered - generally $200 to $300 per "massage" session - and who were perceived as less likely to
+complain to authorities or have credibility if allegations of improper conduct were made.
+12.
+Epstein's plan and scheme reflected a particular pattern and method. The underage
+victim would be brought or directed to Epstein's mansion, where she would be led up a flight of
+stairs to a room that contained a massage table in addition to other furnishings. The girl would then
+find herself alone in the room with Epstein, who would be wearing only a towel. He would then
+remove his towel and lie naked on the massage table, and direct the girl to remove her clothes.
+Epstein would then perform one or more lewd, lascivious and sexual acts.
+13.
+Consistent with the foregoing plan and scheme, Jane Doe was recruited by another
+girl, who told her that she could make some money, but did not tell her what was involved. At all
+relevant times, the girl who recruited Jane Doe was acting on behalf of and as agent for Epstein.
+Jane was contacted by this girl by telephone. Jane was then picked up and brought to Epstein's
+mansion in Palm Beach. Once there, she was led up the flight of stairs to the room with the massage
+table. Epstein came into the room and directed Jane to remove her clothes and give him a massage.
+Jane was frightened and felt trapped. As directed by Epstein, Jane removed her clothes. Epstein
+then during the massage touched Jane on her breasts and vagina, and he grabbed her hand and placed
+it on his penis. Epstein masturbated himself during the massage. Epstein then left money for Jane.
+14.
+As a result of this encounter with Epstein, Jane experienced confusion, shame,
+humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
+MErMELSTEIN & Horowitz, P. A.
+- 3-
+
+
+02:35:06 p.m.
+01-06-2009
+7/8
+24.
+Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted
+in mental or sexual injury that caused or were likely to cause Jane Doe's mental or emotional health
+to be significantly impaired.
+25. Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had
+reason to know that his intentional and outrageous conduct would cause emotional distress and
+damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing
+severe emotional distress to Jane Doe.
+26.
+As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe
+has suffered and will continue to suffer severe mental anguish and pain, psychological and emotional
+injuries and los of enjoyment of life..
+WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this
+Court deems just and proper.
+COUNT III
+Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422
+27. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+28. Epstein used a facility or means of interstate commerce to knowingly persuade,
+induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or
+sexual activity for which any person can be charged with a criminal offense.
+29. On June 30, 2008, Epstein entered a plea of guilty to violations of Florida §§ 796.07
+and 796.03, in the 15th Judicial Circuit in and for Palm Beach County (Case nos. 2008-cf-
+009381AXXXMB and 2006-cf-009454AXXXMB), for conduct involving the same plan and
+scheme as alleged herein.
+MERMELStEIN & HOroWITz, P. A.
+- 5-
+
+
+Herman &Mermelsteln, P
+02:35:42 p.m.
+01-06-2009
+8/8
+30.
+As to Plaintiff Jane Doe, Epstein could have been charged with criminal violations of
+Florida Statute §796.07(2) (including subsections (c), (d), (c), (t), (g), and (b) thereof), and other
+criminal offenses including violations of Florida Statutes $§798.02 and 800.04 (including
+subsections (5), (6) and (7) thereof).
+31.
+Epstein's acts and conduct are in violation of 18 U.S.C. §2422.
+32.
+As a result of Epstein's violation of 18 U.S.C. §2422, Plaintiff has suffered personal
+injury, including mental, psychological and emotional damages.
+33.
+Plaintiff hired Mermelstein & Horowitz, P.A. (f/k/a Herman & Mermelstein, P.A.), in
+this matter and agreed to pay them a reasonable attorneys' fee..
+WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey
+Epstein for all damages available under 18 U.S.C. §2255(a), including without limitation, actual and
+compensatory damages, costs of suit, and attorneys' fees, and such other and further relief as this
+Court deems just and proper.
+JURY TRIAL DEMAND
+Plaintiff demands a jury trial in this action on all claims so triable.
+Dated: May 27,2009
+Respectfully submitted,
+By:
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No, 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiff
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: 305-931-2200
+Fax: 305-931-0877
+MERMELSTEIN & HoRowITz, P. A.
+- 6-
+
+
+1
+2
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+SOUTHERN DISTRICT OF FLORIDA
+WEST PALM BEACH DIVISION
+CASE NO. 08-80119-CIV-MARRA
+WEST PALM BEACH, FLORIDA
+JANE DOE, et al..
+Plaintiffs,
+JUNE 12, 2009
+v8.
+JEFFREY EPSTEIN,
+Defendant.
+TRANSCRIPT OF MOTION HEARING
+BEFORE THE HONORABLE KENNETH A. MARRA,
+UNITED STATES DISTRICT JUDGE
+APPEARANCES:
+FOR THE PLAINTIFFS:
+ADAM D. HOROWITZ, ESQ.
+Mermelstein & Horowitz
+18205 Biscayne Boulevard
+Miami, FL 33160
+For Jane Doe
+305.931.2200
+BRADLEY J. EDWARDS, ESQ-
+Rothstein Rogenfeldt Adler
+401 East Las Olas Boulevard
+Fort Lauderdale, PL 33301
+Jane Doe 3, 4, 5, 6, 7
+954.522.3456
+ISIDRO M. GARCIA, ESQ.
+Garcia Elkins Boehringer
+224 Datura Avenue
+West Palm Beach, PL 33401
+Jane DOE II
+561.832.8033
+RICHARD H. WILLITS, ESQ.
+2290 10th Avenue North
+Lake Worth, FL 33461
+For C.M.A.
+561.582.7600
+
+
+2
+3
+4
+5
+6
+7
+8
+FOR THE DEFENDANT:
+10
+11
+12
+13
+14
+15
+16
+17
+19
+20
+21
+22
+23
+24
+25
+REPORTED BY:
+ROBERT C. JOSEFSBERG, ESQ.
+Podhurst Orseck Josefsberg
+25 West Flagler Street
+Miami, FL 33130
+For Jane Doe 101
+305.358.2800
+(Via telephone)
+KATHERINE W. EZELL, ESQ.
+Podhurst Orseck Josefsberg
+25 West Flagler Street
+Miami, FL 33130
+For Jane Doe 101
+305.358.2800
+ROBERT D. CRITTON, JR., ESQ.
+MICHAEL BURMAN, ESQ.
+Burman Critton, etc.
+515 North Flagler Street
+West Palm Beach, FL 33401
+561.842.2820
+JACK A. GOLDBERGER, ESQ.
+Atterbury Goldberger Weiss
+250 Australian Avenue South
+West Palm Beach, FL 33401
+561.659.8300
+ANN MARIE VILLAFANA, ESQ.
+Assistant U.S. Attorney
+500 East Broward Boulevard
+Fort Lauderdale, FL 33394
+For U.S.A.
+954.356.7255
+MARTIN G. WEINBERG, ESQ.
+20 Park Plaza
+Boston MA 02116
+(Via telephone)
+617.227.3700
+JAY LEFKOWITZ, ESQ.
+(Via telephone)
+LARRY HERR, RPR-RMR-FCRR-AB
+Official United States Court Reporter
+Federally Certified Realtime Reporter
+400 North Miami Avenue, Room 8N09
+Miami, FL 33128
+305.523.5290
+
+
+1
+THE COURT: We are here in the various Doe vs. Epstein
+2
+cases.
+3
+4
+May I have counsel state their appearances?
+MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs
+5
+6
+Jane 2 through Jane Doe 7.
+THE COURT: Good morning.
+7
+MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane
+8 Doe.
+9
+THE COURT: Good morning.
+10
+MR. GARCIA: Good morning, Your Honor. Sid Garcia for
+11
+12
+Jane Doe II.
+THE COURT: Good morning.
+13
+MR. WILLITS: Good morning, Your Honor. Richard
+14
+Willits, here on behalf of the plaintiff C.M.A..
+15
+THE COURT: Good morning.
+16
+MS. EZELL: Good morning, Your Honor. I'm Katherine
+17
+Bzell from Podhurst Orseck, here with Amy Adderly and Susan
+18 Bennett, and I believe my partner, Bob Josefsberg, is going to
+19
+20
+21
+appear by telephone.
+THE COURT: MI. Josefsberg, are you there?
+MR. JOSEFSBERG: I am, Your Honor.
+22
+THE COURT: Good morning.
+23
+24
+MR. JOSEFSBERG: Good morning.
+THE COURT: All right. Do we have all the plaintiffs
+25
+stated their appearances?
+okay.
+
+
+2
+3
+4
+5
+7
+8
+9
+29
+as a shield against the plaintiffs that he was supposed to make
+restitution for.
+And, certainly, he can take my client's depo. He's
+done extensive discovery in the state court case -- very
+Intrusive, I might add. And we don't care, because we can win
+this case with the prosecution agreement or without the
+prosecution agreement. We are ready to go forward.
+THE COURT: You're not going to assert to the United
+States Government that what he's doing in defending the case is
+a violation for which he should be further prosecuted?
+MR. GARCIA: Absolutely not.
+THE COURT: Anyone else for the plaintiffs?
+MR. HOROWITZ: Judge, Adam Horowitz, counsel for
+plaintiffs Jane Doe 2 through 7.
+I just wanted to address a point that I think you've
+articulated it. I just want to make sure it's crystal clear,
+which is that we can't paint a broad brush for all of the
+cases.
+11
+12
+13
+14
+15
+16
+17
+18
+19
+The provision relating to Mr. Epstein being unable to
+20
+contest liability pertains only to those plaintiffs who have
+21
+chosen as their sole remedy the federal statute. My clients,
+22
+Jane Doe 2 through 7, have elected to bring additional causes
+23
+of action, and it"s for that reason we were silent when you
+24
+said does anyone here find Mr. Epstein to be in breach of the
+25
+I non-prosecution agreement. That provision, as we understand
+
+
+30
+2
+3
+4
+5
+6
+7
+it, it doesn't relate to our clients.
+THE COURT: okay. But, again, you're in agreement
+with everyone else so far that's spoken on behalf of a
+plaintiff that defending the case in the normal course of
+conducting discovery and filing motions would not be a breach?
+MR. HOROWITZ: Subject to your rulings, of course,
+yes.
+THE COURT: Thank you.
+Anyone else have anything to say from the plaintiffs?
+10
+Ma. Villafana, if you would be so kind as to maybe
+11 help us out. I appreciate the fact that you're here, and I
+12
+know you're not a party to these cases and under no obligation
+13
+to respond to my inquiries. But as I indicated, it would be
+14 helpful for me to understand the Government's position.
+15
+MS. VILLAFANA: Thank you, Your Honor. And we, of
+16
+course, are always, happy to try to help the Court as much as
+17
+possible. But we are not a party to any of these lawsuits, and
+18
+in some ways we are at a disadvantage because we don't have
+19
+access. My access is limited to what's on Pacer. So I don't •
+20
+really know what positions Mr. Epstein may have taken either in
+21
+correspondence or in discovery responses that aren't filed in
+the case file.
+23
+24
+25
+But your first order was really just what do you think
+about a stay, and then the second order related to this hearing
+and asked a much more specific question, which is whether we
+
+
+DIDICATED TO TUSTICE A SALLTY
+LEOPOLD-KUVIN.
+July 31, 2009
+A. Maria Villafana, Esq.
+Assistant U.S. Attorney
+500 E. Broward Blvd, 7th Floor
+Ft. Lauderdale, FL 33394
+Re: B.B. L JEFFREY EPSTEIN
+OUR FILE NO.: 080303
+Dear Ms. Villafana:
+I am following up on my letter of July 6, 2009, regarding the non-prosecution agreement
+between the U.S. Attorneys office and Jeffrey Epstein.
+Please advise whether or not this document will be produced.
+STK/mlb
+2925 PGA Boulevard = Suite 200 : Palm Beach Gardens : Florida 33410 : 561.515.1400 : fax 561.515.1401 : leopoldkuvin.com
+CRASHWORTHINESS • MANAGED CARE ABUSE • CONSUMER CLASS ACTIONS • PERSONAL INJURY • WRONGFUL DEATH
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+August 4, 2009
+VIA ELECTRONIC MAIL
+Spencer T. Kuvin, Esq.
+Leopold~Kuvin, P.A.
+2925 PGA Boulevard
+Suite 200
+Palm Beach Gardens, FL. 33410
+Re: Jeffrey Epstein/B.B. - Requested Disclosure of Non-Prosecution Agreement
+Dear Mr. Kuvin:
+Thank you for your letter regarding the disclosure of the Non-Prosecution Agreement
+signed by Jeffrey Epstein. I understand that you are asking for a copy of that Agreement in
+connection with your representation of "B.B." As you are aware, the Agreement contains a
+confidentiality provision. Based upon a lawsuit filed by some of Mr. Epstein's victims, U.S.
+District Judge Kenneth Marra has issued a Protective Order requiring the U.S. Attorney's Office
+to provide copies of the Agreement to certain individuals under certain circumstances. The
+Order states:
+If any individuals who have been identified by the USAO [U.S. Attorney's
+Office] as victims of Epstein and/or any attorney(s) for those individuals request
+the opportunity to review the Agreement, then the USAO shall produce the
+Agreement to those individuals, so long as those individuals also agree that they
+shall not disclose the Agreement or its terms to any third party absent further
+court order, following notice to and an opportunity for Epstein's counsel to be
+heard...
+(Court File No. 08-CV-80737-MARRA, DE 26, 1 (e).)
+The language "individuals who have been identified by the USAO as victims of Epstein"
+refers to a specific list of individuals who were the subject of the federal investigation. A list
+of those individuals was provided to Mr. Epstein's attorney. Your client, B.B., was not
+identified during that investigation, and, therefore was not on the list. By stating this 1 am not,
+in any way, denigrating any harm that your client may have suffered. I am simply stating that,
+given time and resource limitations that we faced during the investigation, B.B. was not a person
+who was positively identified, such that she would have been the subject of charges within a
+
+
+SPENCER T. KUVIN, ESQ.
+AUGUST 4, 2009
+PAGE 2
+possible federal indictment.
+For this reason, your client is not covered by the Court's Protective Order and the
+Agreement's confidentiality provision remains intact. If you are unable to get a copy of the
+Agreement via the civil discovery process in the lawsuit that you have filed against Mr. Epstein,
+please ask his counsel if they will consent to my production of the Agreement to you and I will send
+a copy to you.
+By:
+Sincerely,
+Jeffrey H. Sloman
+Acting United States Attorney
+o/A. Marie Villafaña
+A. Marie Villafaña
+Assistant U.S. Attorney
+CC.
+
+
+ROY BIACK
+3COTT A. KORNSPAN
+LARRY A STUMPE
+• MARIA NEYRA
+JACKIE PERCZEK
+MARK A.J. SHAPIRO
+JARED
+BLACK
+SREBNICK
+KORNSPAN
+STUMPF
+JESSICA FONSECA-NADER
+KATHLEEN P. PHILLIPS
+AARON ANTHON
+MARCOS BEATON, JR
+E-Mail: RBlack@RoyBlack.com
+September 1, 2009
+Jeffrey Sloman, Esq.
+Assistant U.S. Attorney
+United States Attorney's Office
+99 N.E. 4* Street
+Miami, Florida 33132
+RE: Jeffrey Epstein
+Dear Jeff:
+Once again I need to send you a note about Jeffrey Epstein, mainly to keep
+ou in the loop so we don't inadvertently violate any provision of his agreemen
+ith your office. As I am sure you are aware, Mr. Epstein has finished th
+incarceration portion of his sentence and is now serving the one year of
+community control as mandated by both his state plea and the terms of the nonprosecution agreement with the United States Attorney's Office for the Southern
+District of Florida.
+Mr. Epstein is in compliance with all terms of his community control and
+is applying for transfer of his supervision from the State of Florida to his primary
+residence, the Virgin Islands. This transfer is being requested through the
+Intrastate Compact for Transfer of Adult Supervision (ICAOS). The ICAOS is the
+mechanism for which transfers of probation and community control are
+effectuated. The process requires the offender to seek the approval of the sending
+state (in this case Florida) and, if they agree, the receiving state (in this case the
+United States Virgin Islands) and the United States Virgin Islands after
+investigation has pre-approved the transfer under the same exact conditions of
+supervision as imposed in Mr. Epstein's community control sentence in the State
+of Florida.
+Even though Mr. Epstein is requesting the transfer he is still at the home
+201 5. Biscayne Boulevard, Suite 1300 - Miami, Florida 33131 • Phone: 305-371-6421 • Fax: 305-358-2006 - www.RoyBlack.com
+
+
+='
+..-
+Jeffrey Sloman, Esq.
+September 1, 2009
+in Palm Beach following the rules of state community control. As Mr. Epstein's
+have taken to heart your previous suggestion of erring on the side of caution and
+I am happy to discuss this with you at any time. I did not want to set an
+appointment to see you on this issue since I imagine you have more pressing
+matters to deal with than a transfer of a state community control matter.
+Roy Black
+RB/ wg
+
+
+500 S. Australian Ave, Ste 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 18, 2009
+DELIVERY BY ELECTRONIC MAIL
+Roy Black, Esq.
+Black Srebnick Kornspan & Stumpf P.A,
+201 S. Biscayne Blvd, Suite 1300
+Miami, FL 33131
+Re:
+Jeffrey Epstein
+Dear Roy:
+I write in response to your letter to Mr. Sloman regarding the transfer of supervision
+of Mr: Epstein's community control to the Virgin Islands. I requested from Mr. Goldberger
+a copy of the documentation that Mr. Epstein submitted in support of his request and a copy
+of the interstate compact that you had mentioned. I have not received these documents.
+Rather than wait any longer, I am advising you of our Office's preliminary concerns. The
+Office may have additional concerns upon receipt of the requested items.
+The Non-Prosecution Agreement called for Mr. Epstein to serve eighteen months in
+county jail followed by twelve months of community control. Mr. Epstein's eighteen-month
+jail term was reduced to slightly more than twelve months based upon Mr. Epstein's "work
+release" of more than twelve hours per day, seven days per week. Mr. Epstein has been on
+community control for less than two months and he is already asking that he be allowed to
+transfer his supervision. The request comes on the heels of an instance where Mr. Epstein
+was found by the Palm Beach Police Department walking on the beach. I understand that
+he told the police that he was "walking to work," despite the fact that his "office" was more
+than eight miles away, and the beach where he was found was not en route from his
+residence to his workplace.
+Throughout the negotiation of the NPA, representations were repeatedly made by you
+and your colleagues that Mr. Epstein would serve his complete sentence, including
+community control, in Palm Beach County. During his change of plea and sentencing, Mr.
+
+
+RoY BLACK, EsQ.
+SEPTEMBER 18, 2009
+
+Epstein told the Court that he intended to remain in Palm Beach County during his period of
+community control - a fact that was important to Judge Pucillo in making her decision
+whether or not to accept the plea agreement. Mr. Epstein's presence in Palm Beach County
+was important to the Court, our Office, and, presumably, the State Attorney's Office, because
+it allowed all of these entities to monitor Mr. Epstein's performance of his obligations.
+Relocating to the Virgin Islands, where Mr. Epstein lives on a private island without any
+independent law enforcement presence, would eliminate that ability.
+The Office's ability to determine whether Mr. Epstein has breached the NPA and to
+file charges against him when/if he breaches that Agreement was a key piece of consideration
+for the decision to enter that Agreement. Another key piece was the ability of victims to
+pursue claims against Mr. Epstein under 18 U.S.C. § 2255.
+Your September 1, 2009 letter to Mr. Sloman, in essence, asked whether it would be
+the Office's position that Mr. Epstein's move to his private island would violate the terms
+of the NPA. For the reasons stated above, even upon our preliminary review, it is the
+position of the Office that the transfer of community control would frustrate the purpose of
+the agreement and thereby violate its terms. No final decision has been made, of course,
+because Mr. Epstein has not yet moved. However, if Mr. Epstein elects to go forward with
+the transfer of community control with the knowledge of the Office's objection, that will be
+considered, along with all of the previous violations by Mr. Epstein, as set forth in my letters
+of June 15 and July 7, 2009, in determining the Office's final course of action.
+I look forward to receiving the materials requested from Mr. Goldberger.
+Sincerely,
+Jeffrey H. Sloman
+Acting United States Attorney
+By: A. Marie Villafaña
+A. Marie Villafaña
+Assistant United States Attorney
+CC:
+
+
+BT DIG
+LEOPOLD-KUVIN.
+January 4, 2010
+A. Maria Villafana, Esq.
+Assistant U.S. Attorney
+500 E. Broward Blvd, 7th Floor
+Ft. Leuderdale, FL. 33394
+Re: B.B. [. JEFFREY EPSTEIN
+OUR FILE NO.: 080303
+Dear Ms. Villafana:
+After taking the deposition of Police Chief, Michael Reiter, it came to our attention that
+apparently a computer which was initially seized during the search warrant conducted on Mr.
+Epstein's home was returned by the FBI to a private investigator employed by Mr. Epstein. We
+would like to determine who this computer was returned to, and when it was returned. It would
+assist us greatly if you could check your records to determine when, and if, this was ever done.
+Additionally, according to the sworn testimony of Chief Reiter, his department was provided
+with a letter containing a list of potential victims of Mr. Epstein. This letter contained language
+pursuant to a previously unknown Federal Statute which apparently directed him to destroy the
+letter after reading it. We hereby request that your office advise what Statute or Code that letter
+was referring to. Finally, we would like to schedule the depositions of FBI Special Agents
+Nesbitt Kirkendall, Junior Ortiz and Mr. Solomon. Please let me know who we need to direct
+our subpoenas to in order to schedule these depositions.
+I appreciate your immediate attention to this matter. Should you have any additional questions
+about these issues, please do not hesitate to contact me at once.
+:.!
+STK:mlb
+2925 PGA Boulevard • Sulte 200 : Palm Beach Gardens :: Florida 33410 .- 561.515.1400 :: fax 561.515.1401 leopoldkuvin.com
+CRASHWORTHINESS - MANAGED CARE ABUSE « CONSUMER CLASS ACTIONS • PERSONAL INJURY - WRONGFUL DEATH
+
+
+LARRY A. STUMPE
+MARIA NEVRA
+JACKIE PERCZEK
+MARK A.J. SHAPIRO
+JARED
+BLACK
+SREBNICK
+KORNSPAN
+& STUMPF
+JESSICA FONSECA-NADER
+KATHLEEN P. PHILLIPS
+AARON ANTHON
+MARCOS BEATON, JR.
+MATTHEW P. O'BRIEN
+JENIPER J. SOULKIAS
+E-Mail: RBlack@RoyBlack.com
+January 20, 2010
+A. Marie Villafaña, Esq.
+Assistant United States Attorney
+United States Attorney's Office
+500 South Australian Avenue
+Suite 400
+West Palm Beach, Florida 33401
+RE: Jeffrey Epstein
+Dear Marie:
+We are now facing a difficult issue about the attorney's fees in the civil cases
+brought against Mr. Epstein related to your prior criminal investigation. I
+broached this subject with you on the phone a couple of weeks ago, but I could
+see our discussion was not fruitful at that time. Since we could not come to any
+agreement on how to handle this, we must proceed ahead based on our
+understanding of the non-prosecution agreement.
+Mr. Epstein has paid the attorney representative $526,000 and accepts his
+obligation under the NPA to pay additional reasonable legal fees that precede
+litigation claims under 17C of the Addendum. However we believe that the
+request by the attorney representative for over $1.5M additional fees is both
+unreasonable and outside the Addendum's criteria for payment.
+Litigation may ensue since we have been unable to resolve these matters
+through an agreement. We never contemplated that the legal fee agreement would
+result in a bill for $2. 1M when the Addendum was entered. We understand you
+and Jay had different views on whether an attorney representative could both sue
+Epstein for some clients and remain as counsel to settle other cases. We believe
+that the attorney representative could either settle the cases and be paid hourly
+or litigate and be paid out of the judgment, but not both. The language of the NPA
+is in need of legal construction regarding whether Epstein's obligations end when
+201 S. Biscayne Boulevard, Suite 1300 • Miami, Florida 33131 • Phone: 305-371-6421 • Fax: 305-358-2006 • www.RoyBlack.com
+
+
+A. Marie Villafaña, Esq.
+January 20, 2010
+the attorney representative brings a lawsuit for any of his clients - a matter that
+a court should settle free from any consideration that initiating litigation to resolve
+this outstanding issue would be perceived as a breach.
+Just to be sure, Mr. Epstein will pay whatever fees a court determines are
+owed and we only want assurance that litigating the legal and factual issues over
+such liability will be consistent with and not violate the NPA. We don't think it is
+the government's position that Epstein must simply pay any bill he receives,
+regardless of the amount and type of work done, particularly one for $2. IM. So we
+have no alternative but to go to court to resolve this issue. We are sending you
+this letter because the attorney representative is using the threat of a breach as
+leverage to get his fees. I don't believe the government's power to indict and
+incarcerate should be used to assist a private lawyer in collecting an exorbitant
+legal fee. Thus we are putting you on notice, and asking that if you disagree with
+our legal opinion that a suit is not in conflict with the NPA, to tell us without
+delay.
+Cordially yours,
+Martin G. Weinberg, Esq.
+- Tay
+MW:RC:RB/wg
+
+
+To:
+Cc:
+Roy BLACK [RBLACK@royblack.com]
+Thursday, January 21, 2010 2:59 PM
+owlmgw@worldnet.att.net
+Yesterday's Letter
+Dear Marie: On second thought my letter yesterday went too far in one respect. So that there is no misunderstanding of
+the last paragraph of yesterday's letter, our concern is not that the attorney representative in fact has used the threat of
+a breach as leverage to get his fees, only that there exists the legitimate concern that the agreement could be so used
+and the reality that any concern about such use significantly and unfairly burdens Mr Epstein's right to resort to the
+courts to resolve outstanding legal Issues regarding the criteria for payment and the amount of payment owed. I hope
+this clarifies our concern in this one area. Thanks Roy
+
+
+500 S. Australian Ave, Ste 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+February 11, 2010
+DELIVERY BY ELECTRONIC MAIL
+Roy Black, Esq.
+Black Srebnick Kornspan & Stumpf P.A.
+201 S. Biscayne Blvd, Suite 1300
+Miami, FL 33131
+Re:
+Jeffrey Epstein
+Dear Mr. Black:
+Thank you for meeting with our Office last week. During our discussion, you and your
+colleagues raised three issues: (1) whether our Office would consider it a breach of the Non-
+Prosecution Agreement for Mr. Epstein to file suit against the victim's attorney-representative
+relating to the amount of attorney's fees; (2) whether our Office would consider it a breach of the
+Non-Prosecution Agreement for Mr. Epstein to argue that he has no hability for claims raised
+exclusively under 18 U.S.C. § 2255 as to any of the victims on the identified list; and (3) whether
+our Office would have any objection to Mr. Epstein applying for early termination of his community
+control.
+As we have told you before, our Office cannot give advisory opinions as to what will and will
+not be a breach of the Non-Prosecution Agreement. Furthermore, as to the first item, your colleagues
+admitted that efforts to reach an agreement with Robert Josefsberg regarding the amount of fees
+owed have not been completed. Similarly, as to the second item, your colleagues admitted that there
+are no currently pending cases arising exclusively under 18 U.S.C. § 2255 as to any of the victims
+on the identified list. Given that these matters may never arise and, if they do arise, there will be
+innumerable legal and factual issues that have not been shared with our Office, we again decline to
+provide any advisory opinions. As discussed during the meeting, the purpose of having the parties
+and a Special Master involved at the beginning of the process in the selection of the attorneyrepresentative was to avoid dealing with this issue at the end of the process. As with all matters
+related to the Agreement, we expect that Mr. Epstein will act in good faith and comply with the letter
+and spirit of the NPA.
+As to the third item, we have reviewed your letter to Mr. Sloman of February 8, 2010. While
+Mr. Acosta did state in his letter of December 19, 2007, that he did not believe that the Office was
+
+
+ROY BLACK, ESQ.
+FEBRUARY 11,2010
+
+obligated to notify the victims identified through the federal investigation of proceedings occurring
+in state court, the U.S. Department of Justice's position may have changed in the interim in light of
+internal guidance regarding prosecutors' obligations pursuant to 18 U.S.C. § 3771, 42 U.S.C. §
+10607, and Fed. R. Crim. P. 60 (effective December 1, 2008).
+In light of Mr. Acosta's prior statements to Mr. Epstein's counsel that Mr. Epstein would be
+eligible for any benefit available to other similarly-situated state defendants, the Office agrees that
+Mr. Epstein may apply for early termination or modification of community control in accordance
+with Fl. Stat. §9 948.05 and 948.10(4), assuming that Mr. Epstein has completed "the sanctions
+imposed in the community control plan." The Office takes no position regarding such an
+application; it is entirely within the discretion of the State Attorney's Office and the Palm Beach
+County Circuit Court Judge as to whether it is in "the best interests of justice and the welfare of
+society" to allow Mr. Epstein to terminate prematurely his community control. Mr. Epstein and his
+counsel may not make a representation to the State Attorney's Office, the Court, or any victim that
+the U.S. Attorney's Office agrees with, joins in, or does not oppose such a motion. In light of prior
+erroneous statements in court filings, we respectfully request that a copy of any court filing be
+provided to our office.
+If such a motion is made, in accordance with your proposal, the U.S. Attorney's Office will
+notify the federal victims that the application was filed and, if a hearing is scheduled, the date, time,
+and location of such hearing. The communication will consist merely of a notification and will
+neither encourage nor discourage attendance or submission of materials related to the application.
+Sincerely,
+Jeffrey H. Sloman
+By:
+s/A. Marie Villafaña
+A. Marie Villafaña
+Assistant United States Attorney
+
+
+LARRY A. STUMPE
+MARIA NETRA
+JACKIE PERCZEK
+MARK A.J. SHAPIRO
+JARED
+BLACK
+SREBNICK
+KORNSPAN
+& STUMPF
+=PA.=
+JESSICA FONSECA-NADER
+KATHLEEN P. PHILLIPS
+MARCOS BEATON, JR.
+MATTHEW P. O BRIEN
+ENIFER J. SOULIKIA
+JOAH FO
+E-Mail: RBlack@RoyBlack.com
+February 18, 2010
+Assistant United States Attorney
+99 N.E. 4'h Street
+Miami, FL 33132
+RE: Jeffrey Epstein
+Dear Ms Villafana:
+Thank you for your letter of February 11, 2010. We write to update you
+about ongoing efforts to reach an agreement with Robert Josefsberg regarding the
+amount of fees and costs properly owed to him by Mr. Epstein pursuant to the
+NPA.
+On February 16, 2010 Mr. Epstein's principal civil counsel Bob Critton
+advised Mr. Josefsberg in writing that he and Mr. Epstein would meet with Mr.
+Josefsberg on two occasions between now and March 1, 2010 to review Mr.
+Josefsberg's outstanding bills on a line-by-line basis and attempt to reach a nonadversarial resolution of all outstanding fee issues. Mr. Critton also transmitted
+to Mr. Josefsberg an Agreement for Special Master to Determine Amount of
+Attorneys' Fees and Costs ("Special Master Agreement"), signed by Mr. Epstein,
+containing terms and conditions previously agreed to by Mr. Josefsberg, which
+would mandate binding mediation before a neutral third party in the event the
+proposed settlement discussions did not resolve all outstanding issues in an
+expeditious manner.
+We want to assure you that Mr. Epstein fully intends to fulfill his obligations
+under the NPA. We regret that issues remain unresolved regarding whether all of
+the fees and costs being sought by the attorney representative - which now total
+$1,947,000 exclusive of the $526,466 already paid by Mr. Epstein - meet the
+criteria set forth by the NPA. We assure you that both Mr. Epstein's prior civil
+counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the NPA
+language, and Mr. Critton, each strongly believe that significant amounts of the
+fees and costs billed by Mr. Josefsberg are outside the scope of Mr. Epstein's fee-
+201 S. Biscayne Boulevard, Suite 1300 • Miami, Florida 3313l - Phone: 305-371-6421 • Fax: 305-358-2006 • www.RoyBlack.com
+
+
+1
+February 18, 2010
+related payment obligations under the NPA. We hope that the fee-related issues
+can be resolved by further settlement discussions or by relying on the Special
+Master Agreement signed Tuesday February 16, 2010 by Mr. Epstein. Mr. Epstein
+and his counsel believe that these options are consistent with the NPA, are good
+faith alternatives to contested litigation, and are reasonable given the unexpected
+magnitude of the bills and their inclusion of charges for legal work that was
+clearly related to the preparation of litigation and thus outside Par 7C of the
+Addendum as well as for extensive work performed by attorneys from outside Mr.
+Josefsberg's law firm.
+Mr. Josefsberg previously advocated for settling outstanding issues through
+a Special Master Agreement nearly identical to the one executed Tuesday by Mr.
+In fact, Mr. Josefsberg and Mr. Epstein had each agreed in the past to
+a specific Master as a third-party neutral to conduct proceedings to resolve the fee
+issues. However, the selected Master withdrew.
+We hope that the Special Master Agreement will provide a basis for a prompt
+resolution of any issue not resolved by the parties through further discussions.
+Respectfully submitted,
+MARTIN WEINBERG, ESQ.
+ROY
+LACK, ESQ.
+In Bach
+/ wg
+Jeffrey Sloman, Esq.
+Robert Senior, Esq.
+
+
+LARRY A. STUMPF
+MARIA NEYRA
+JACKIE PERCZEK
+MARK A.J. SHAPIRO
+JARED I
+BLACK
+SREBNICK
+KORNSPAN
+& STUMPF
+=PA.=
+JESSICA FONSECA-NADER
+MATTHEW P. O'BRIEN
+JENIPER J. SOULIKIAS
+NOAH FOx
+E-Mail: RBlack@RoyBlack.com
+March 5, 2010
+99 N.E. 4" Street
+Miami, FL 33132
+Assistant United States Attorney
+99 N.E. 4t Street
+Miami, FL 33132
+Assistant United States Attorney
+99 N.E. 4ü Street
+Miami, FL 33132
+RE: Jeffrey Epstein
+Dear Counsel:
+We write this letter to renew our request that the United States Attorney's
+Office provide us, as Mr. Epstein's counsel in the federal NPA matter, with clarity
+is to what legal issues we can advise his civil counsel can be litigated without
+ausing you to consider the raising of legal issues to be in breach of Mr. Epstein'?
+blipations under paragraph 8 of the NPA. A letter from civil counsel Rober
+Critton is attached. On February 11, 2010, you advised us that for reasons
+including the fact that at the time there were "no currently pending cases arising
+exclusively under 18 USC §2255 as to any of the victims on the identified list" you
+would "decline to provide any advisory opinions" in response to our requests
+during our meeting of February 3.
+Since February 11, 2010, a lawsuit has been filed by the attorney
+representative on behalf of Jane Doe 103. Her identity is known by us and she
+is on the "identified list." Her lawsuit raises only §2255 claims. Although she has
+not waived her right to file any other state or federal or common law claim so as
+to fit squarely within the letter of 98 of the NPA, she does, in her lawsuit, quote
+18 and claim rights as a beneficiary of that agreement, see Case No. 10-80309
+(S.D. Fla.), Complaint, 1925-26, thus requiring that civil counsel consider
+201 5. Biscayne Boulevard, Suite 1300 • Miami, Florida 3313l • Phone: 305-371-6421 • Fax: 305-358-2006 • www.RoyBlack.com
+
+
+March 5, 2010
+responsive motions that relate to the scope of waiver of liability that is
+memorialized in the NPA. Additionally, Mr. Epstein and his counsel have
+scheduled a meeting to review the attorney representatives outstanding bills but
+have been told that if there is no settlement agreement, then the attorney
+representative intends to initiate litigation rather than adopt the Special Master
+procedure that we referred to in our February 18, 2010 correspondence to you.
+It is the intention of Mr. Epstein's civil counsel to not contest that at least
+one predicate §2255 offense was committed believing that such a "waiver"
+satisfies, facially, Mr. Epstein's obligations under the NPA, see attached letter from
+Mr. Critton. As we said during our meeting on February 3, we have an obligation
+to provide advice to Mr. Epstein's civil counsel, Robert Critton, whether his raising
+of certain legal challenges to the Complaint will be perceived as being in conflict
+with Mr. Epstein's NPA obligations. These issues include:
+1.
+Whether Mr. Epstein can contend that any waiver of liability is
+satisfied by his not contesting the occurrence of a single rather than
+multiple predicate offenses as to each claimant? This issue is pertinent
+since Jane Doe 103 has brought six separate claims for §2255 relief each
+implicating the statutory minimum damage recovery.
+Amongst the
+predicates alleged include a predicate offense allegation of a statute that
+was not even enacted until 2006, i.e., over a year after Jane Doe 103 turned
+18, and substantially after her last alleged contact with Mr. Epstein. Any
+requirement that Mr. Epstein not contest liability for that predicate would
+violate the ex post facto laws. Two other predicates are not supported by
+trustworthy evidence. It is our contention that Mr. Epstein satisfies his
+NPA obligations by not contesting that he committed at least one predicate
+offense. Prior correspondence from your office is not inconsistent with our
+belief that the required scope of waiver was to a predicate offense in the
+singular, see, e.g., Mr.Acosta's letter to Ken Starr, December 4, 2007, p.2
+("were Mr. Epstein convicted at trial, the plaintiff-victims would not have to
+show that a violation of an enumeration section of Title 18 took place")?
+2.
+Whether Mr. Epstein can contend that the statutory provisions of
+§2255 in effect at the time of the offense (e.g., 2004-5) govern the minimum
+statutory damage amount ($50,000 rather than $150,000) under ex post
+facto laws, see United States |. Scheidt, 2010 W.L. 144837 (E.D. Cal., 2010)
+(indicating that the statute in effect at the time of the violation governs the
+minimum damage remedy)?
+
+
+March 5, 2010
+3.
+Whether personal injury is a separate §2255 element from the
+predicate offense element so that Mr. Epstein could "agree" to the occurrence
+of a predicate pursuant to his NPA obligations but still contest that the
+plaintiff was injured, see United States |. Scheidt, supra (finding each to be
+a separate element) and the letter from Mr. Acosta to Mr. Starr, supra
+December 4, 2007 letter at p.2 which agrees that Mr. Epstein can contest the
+injury element under the NPA ("were Mr. Epstein convicted at trial, the
+plaintiff-victims in a subsequent Section 2255 suit would still have had some
+burden to prove that they were 'victims')?
+4. Whether the 6-year civil statute of limitations contained in 18 USC
+§2255 could be raised as an affirmative defense if the facts or allegations
+demonstrate a greater than 6-year period between the accruing of the cause
+of action and the complaint, i.e., whether Mr. Epstein can "agree" (for civil
+§2255 purposes) to the occurrence of a predicate offense and still claim it
+occurred greater than 6 years before the filing of a Complaint?
+5. Whether Mr. Epstein can contest certain claims that are unsupported
+by trustworthy proof (or in certain cases by any proof at all) so long as he has
+waives his right to deny the occurrence of at least one predicate offense as
+required by 18 of the NPAP
+6.
+Whether damages are to be awarded based on injury to a plaintiff or
+based on the number of separately proven claims, see United States
+Baker, 2009 WL 4572785 (E.D.Tex., 2009) where the Court rejected the
+contention that damages were to be allocated per violation?
+We are not asking the government to adopt our legal positions; instead we
+are simply seeking the right for Mr. Epstein's civil counsel to raise principled good
+faith legal issues without fear of the irreparable collateral consequences that
+would result from any notice by you that you believed that a litigation position
+adopted by Mr. Epstein's civil counsel constituted a willful breach. Paragraph 8
+and its waiver provisions are not clear (or as stated by Mr. Acosta are "far from
+simple," see Mr. Acosta letter to Ms. Sanchez, December 19, 2007). Paragraph 8
+does not "speak for itself." That the provisions of 98 are "far from simple" is
+illustrated in the construction of those paragraphs by Mr. Epstein's prior counsel,
+Jay Lefkowitz, who repeatedly advised Mr. Acosta, by letter, that he considered the
+waiver of liability to be limited to those who agreed to damages, and was
+inapplicable to those who chose to litigate, see, e.g., letters from Jay Lefkowitz to
+
+
+March 5, 2010
+Page 4
+Alex Acosta October 10, 2007, p.4 and November 29, 2007, p.2. Again, we are
+any of the legal arguments outlined above would violate the NPA
+Respectfully submitted,
+MARTIN WEINBERG, ESQ.
+ROY BLACK, ESQ.
+By.
+Kay
+/ wg
+
+
+( BURMAN, CRITTO!
+LUTTIERCOLEMANDI
+YOUR TRUSTED ADVOCATES
+A LIMITED LIABILITY PARTNERSHIP
+. MICHAEL BURMAN, P.A.!
+GREGORY W. COLEMAN, P.A
+ROBERT D. CRITTON, JR, P.A'
+BERNARD A. LEBEDEKER
+MARK T. LUTTIER, P.A.
+MICHAEL ). PIKE
+DAVID A. YAREMA
+"FLORIDA BOARD CERTIFIED CIVIL TRIAL LAWYER
+ADMITTED TO PRACTICE IN FLORIDA AND COLORADO
+March 4, 2010
+BOSB M. MORENMA
+ALA SOENBAINO
+O COROM. RICCI
+Roy Black, Esq.
+Black, Srebnick, Kornspan & Ptumpf
+201 S. Biscayne Boulevard, Suite 1300
+Miami, FL 33131
+Martin G. Weinberg, Esq.
+Martin G. Weinberg, PC
+20 Park Plaza, Suite 1000
+Boston, MA 02116
+Re:
+Jeffrey Epstein
+Dear Roy and Marty:
+This letter represents my thoughts on issues concerning the NPA and my ability to
+fully defend Mr. Epstein in the civil case recently filed by Mr. Josefsberg.
+Based on a State criminal court ruling last summer, the Non-Prosecution Agreement
+("NPA") was made available to the public. With regard to the civil aspect of the NPA,
+specifically paragraphs 7 and 8 (including the Addendum), our interpretation has been
+substantially different from that of the attorney representative, Mr. Josefsberg, and other
+attorneys representing alleged victims.
+They have interpreted those civil portions of the
+agreement to assist them in their civil cases in a manner which we believe is inconsistent
+with both the written word and the intent of the NPA.
+Mr. Epstein has continued to fulill his responsibilities under all aspects of the NPA.
+Mr. Josefsberg has represented or currently represents tweive individuals. Of those
+twelve individuals, eleven have resolved their claims. Of those eleven claims, only two
+individuals filed contested litigation, Jane Doe 101 and Jane Doe 102.
+Mr. Epstein and Mr. Josefsberg have attempted to resolve the issue associated with
+attorneys fees and costs. Mr. Epstein has, as you know, paid an excess of $500,000.00
+toward the claimed outstanding fees and costs. It is the belief of all attorneys who
+represent Mr. Epstein that the fees and costs incurred by the attorney representative (for
+many attorneys and consultants) are excessive and duplicative. Mr. Epstein provided Mr.
+Josefsberg a signed Special Master Agreement for resolving the fees/costs issues in
+February 2010, in substantially the same format which was agreed upon as of December
+of 2009. The only significant change was use of an out-of-state special master. We were
+advised by Mr. Josefsberg and Mr. Podhurst that they no longer agree with using that
+process.
+303 BANYAN BOULEVARD • SUITE 400 • WEST PALM BEACH, FL 33401 • PHONE: 561-842-2820 • FAX: 561-844-6929 • MAIL@BCLCLAW.COM
+WWW.BCLCLAW.COM
+
+
+March 4, 2010
+Jane Doe 103 now has been filed. While Mr. Epstein clearly recognizes his
+obligation under the NPA to waive liability to a single predicate offense, Mr. Josefsberg
+has filed an action asserting multiple counts against Mr. Epstein based on multiple
+predicate acts, including one wherein the statute was not even in effect at the time of the
+alleged violation. Mr. Josefsberg is also aware and agreed that Mr. Epstein could file a
+declaratory action related to the interpretation of the NPA. Mr. Josefsberg reserved the
+right to contest issues that might be raised in such an action.
+It is facially unfair, unjust and inconsistent with the spirit and intent of the NPA that
+Mr. Epstein be precluded from fully defending himself (except for the waiver of liability as
+to a single act) especially where no facts exist to support the claim, a statute was not in
+effect at the time of the alleged incident, etc.
+It is my understanding that you are sending a letter to the USAO. I have no
+objection to your including my letter which expresses some of my concerns with which Mr.
+Epstein is now confronted based on Mr. Josefsberg's interpretation of the NPA. While |
+am not asking the USAO to confirm Mr. Epstein and his attorneys' interpretation of the
+NPA and/or its spirit and intent, I would request that the USAO give Mr. Epstein the
+opportunity to fully defend himself, in the civil suit, except for that which is specifically
+required of him under the NPA.
+Cordially yours
+Robey D. Critton, Jr.
+RDC/ciz
+
+
+500 S. Australian Ave, Ste 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+April 2, 2010
+DELIVERY BY ELECTRONIC MAIL
+Roy Black, Esq.
+Black Srebnick Kornspan & Stumpf P.A.
+201 S. Biscayne Blvd, Suite 1300
+Miami, FL 33131
+Re: Jeffrey Epstein
+Dear Mr. Black:
+The Office is in receipt of your letter of March 29, 2010. We have had a series of
+correspondence, telephone calls, and meetings regarding the issue of Mr. Epstein's obligation to his
+victims. We have repeatedly stated that Mr. Epstein is expected to abide by the letter and spirit of
+the Non-Prosecution Agreement. And we have repeatedly informed you that the U.S. Attorney's
+Office does not intend to provide advisory opinions to Mr. Epstein or his attorneys regarding the
+handling of the civil suits filed against him. Yet again, you have asked us to provide such an
+advisory opinion. The request relates to Mr. Epstein's Motion to Dismiss in toto the suit filed
+against him by Jane Doe 103, whom we understand is one of the victims identified through the 2006
+through 2007 investigation that culminated in the signing of the Non-Prosecution Agreement.
+Jane Doe 103 is represented by Robert Josefsberg, the attorney-representative selected by the
+Special Master in accordance with the Non-Prosecution Agreement, and the Complaint raises claims
+exclusively under 18 U.S.C. § 2255. As such, Mr. Epstein has waived his right to contest liability.
+Despite this waiver, Mr. Epstein and his attorneys want the Court to dismiss the Complaint. In a
+word, yes, the Office believes that this is a breach of the Non-Prosecution Agreement.
+Sincerely,
+Jeffrey H. Sloman
+A. Marie Villafaña
+Assistant United States Attorney
+
+
+ROY BLACK, ESQ.
+APRIL 2, 2010
+
+
+
+Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket.03/09/2010 Page 1 of 19
+i.
+unsealad 03/09/10
+Sealed
+IN THE UNITED STATES DISTRICT COURT
+FOR THE SOUTHERN DISTRICT OF FLORIDA
+Civil Action No.
+10 -80309
+JANE DOE No. 103,
+Plaintiff,
+FILED by SB D.c.
+FEB 2 3 2010
+STEVEN M. LARIMORE
+CLERKU S DIST. CT
+S.D. ot FLA - MIAMI
+JEFFREY EPSTEIN,
+Defendant.
+COMPLAINT AND DEMAND FOR JURY TRIAL
+Plaintiff, Jane Doe No. 103 ("Plaintiff"), brings this Complaint against Defendant, Jeffrey
+Epstein ("Defendant"), and states as follows:
+PARTIES, JURISDICTION, AND VENUE
+1. Atall times material to this cause of action, Plaintiff was a resident of Palm Beach
+County, Florida.
+2. This Complaint is brought under a fictitious name to protect the identity of
+Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse of a then
+minor.
+3.
+At all times material to this cause of action, Defendant owned a residence located
+at 358 El Brillo Way, Palm Beach, Palm Beach County, Florida.
+4.
+Defendant is presently a citizen of the United States Virgin Islands. Pursuant to
+the plea agreement entered by the Defendant in state court and the sentencing which occurred on
+J une 30, 2008, Defendant is curenty under community control in Palim Beach Couns elerida
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miaini 305.358,2800 Fax 305.358.23B2 • Fort Landerdale 954.463.4346
+latt
+
+
+• Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 2 of 19
+.:
+5.
+Defendant is an adult male born on January 20, 1953.
+6.
+This Court has jurisdiction over this action and the claims set forth herein
+pursuant to 18 U.S.C. § 2255.
+7.
+This Court has venue of this action pursuant to 28 U.S.C. § 1391(b), as a
+substantial part of the events giving rise to the claim occurred in this District.
+STATEMENT OF FACTS
+At all relevant times, Defendant was an adult male spanning the ages of 45 and 55
+years old. Defendant is known as a billionaire financier and money manager with a secret
+clientele limited exclusively to billionaires. He is a man of tremendous wealth, power, and
+influence. He owns a fleet of aircraft that includes a Gulfstream IV, a helicopter, and a Boeing
+727, as well as a fleet of motor vehicles. Until his incarceration pursuant to the plea entered and
+sentencing, which occurred on June 30, 2008, he maintained his principal place of residence in
+the largest dwelling in Manhattan, a 51,000-square-foot eight-story mansion on the Upper East
+Side. He also owns a $6.8 million mansion in Palm Beach, Florida, a $30 million 7,500-acre
+ranch in New Mexico he named "Zorro," a 70-acre private island known as Little St. James in
+the U.S. Virgin Islands, a mansion in London's Westminster neighborhood, and another
+residence in the Avenue Foch area of Paris. The allegations herein concern Defendant's conduct
+while at his lavish residence in Palm Beach and numerous other locations both nationally and
+internationally.
+9.
+Defendant has a sexual preference for underage minor girls. He engaged in a
+plan, scheme, or enterprise in which he gained access to countless vulnerable and relatively
+economically disadvantaged minor girls, and sexually assaulted, molested, and/or exploited these
+girls, and then gave them money.
+2
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miarni 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+• Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 3 of 19
+•.
+10.
+Beginning in or around 1998 through in or around September 2007, Defendant
+used his resources and his influence over vulnerable minor girls to engage in a systematic pattern
+of sexually exploitative behavior.
+11.
+Defendant's plan and scheme reflected a particular pattern and method.
+Defendant coerced and enticed impressionable, vulnerable, and relatively economically less
+fortunate minor girls to participate in various acts of sexual misconduct that he committed upon
+them. Defendant's scheme involved the use of underage girls, as well as other individuals, to
+recruit underage girls. Defendant and/or an authorized agent would call and alert Defendant's
+assistants shortly before or after he arrived at his Palm Beach residence. His assistants would
+call economically disadvantaged and underage girls from West Palm Beach and surrounding
+areas who would be enticed by the money being offered and who Defendant and/or his assistants
+perceived as less likely to complain to authorities or have credibility issues if allegations of
+improper conduct were made. The then minor Plaintiff and other minor girls, some as young as
+14 years old, were transported to Defendant's Palm Beach mansion by Defendant's employees,
+agents, and/or assistants in order to provide Defendant with "massages."
+12. Many of the instances of illegal sexual conduct committed by Defendant were
+perpetrated with the assistance, support, and facilitation of at least three assistants who helped
+him orchestrate this child exploitation enterprise. These assistants would arrange times for
+underage girls to come to Defendant's residence, transport or cause the transportation of
+underage girls to Defendant's residence, escort the underage girls to the massage room where
+Defendant would be waiting or would enter shortly thereafter, urge the underage girls to remove
+their clothes, deliver cash from Defendant to the underage girls and/or their procurers at the
+conclusion of each "massage appointment," and assist Defendant in taking nude photographs
+3
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 /
+
+
+• Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 4 of 19
+and/or videos of the underage girls with and/or without their knowledge. Defendant would pay
+the procurer of each girl's "appointment" hundreds of dollars.
+13.
+Defendant designed this scheme to secure a private place in Defendant's Palm
+Beach mansion where only persons employed and invited by Defendant would be present, so as
+to reduce the chance of detection of Defendant's sexual abuse and/or exploitation, as well as to
+make it more difficult for the minor girls to flee the premises and/or to credibly report his actions
+to law enforcement or other authorities. The girls were usually transported by his employee(s),
+agents), and/or assistants) and/or by taxicab(s) and/or motor vehicle(s) paid for by Defendant,
+which also made it difficult for the girls to flee his mansion.
+14. Upon her initial arrival at Defendant's Palm Beach mansion, each underage
+victim would generally be introduced to one of Defendant's assistants, who would gather the
+girl's personal contact information. The minor girl would be led up a remote flight of stairs to a
+room that contained a massage table and a large shower.
+15. At times, if it was the girl's first "massage" appointment, another female would
+be in the room to "lead the way." Generally the other female would leave, or Defendant would
+dismiss her. Often, Defendant would start his massage wearing only a small towel, which
+eventually would be removed. Defendant and/or the other female would direct the girl to
+massage him, giving the minor girl specific instructions as to where and how he wanted to be
+touched, and then direct her to remove her clothing. Defendant would then perform one or more
+lewd, lascivious, and sexual acts, including masturbation; fondling the minor's breasts and/or
+sexual organs; touching the minor's vulva, vagina, and/or anus with a vibrator, back massager,
+his fingers), and/or his penis; digitally penetrating her vagina; performing intercourse, oral sex,
+and/or anal sex; and/or coercing or attempting to coerce the girl to engage in lewd acts and/or
+4
+25 West Flagler Street, Suite 800, Miami, PL. 33130, Miami 305.35.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 T
+
+
+Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 5 of 19
+: .
+prostitution and/or enticing the then minor girl to engage in sexual acts with another female in
+Defendant's presence.
+The exact degree of molestation and frequency with which the sexual
+exploitations took place varied and is not yet completely known; however, Defendant committed
+such acts regularly on a daily basis and, in most instances, several times a day. In order to
+facilitate the daily exchanges of money for sexual assault and abuse, Defendant kept U.S.
+currency readily available.
+16.
+Defendant traveled out of Florida to Palm Beach for the purpose of luring
+minor girls to his mansion to sexually abuse and/or batter them. He used the telephone to contact
+these minor girls for the purpose of coercing them into acts of prostitution and to enable himself
+to commit sexual battery against them and/or acts of lewdness in their presence, and he conspired
+with others, including his employee(s), assistant(s), driver(s), pilot(s), and/or agent(s), to
+facilitate these acts and to avoid police detection. Defendant's systematic pattern of sexually
+exploitative behavior described above also occurred in Defendant's other domestic and/or
+international residences, places of lodging, and/or modes of transportation.
+17.
+Consistent with the foregoing plan and scheme, Defendant used his money,
+wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff.
+A vulnerable young girl, Plaintiff was merely a seventeen year old high school student when she
+was first lured into Defendant's sexually exploitative world in or about January 2004. Plaintiff
+was recruited while at work by a co-worker, one of the minor victims Defendant paid to procure
+underage females. Plaintiff went to Defendant's Palm Beach mansion accompanied by this coworker. Upon arriving, Plaintiff was led by one of Defendant's assistants up a flight of stairs to a
+spa room with a shower and a massage table. Defendant entered this room wearing only a towel.
+Defendant suddenly removed his towel, exposing his naked body, and then lay on the massage
+5
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+• Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 6 of 19
+table. Defendant told Plaintiff to massage his back and take off her clothing, which she refused
+to do. Defendant then began to try to touch the minor Plaintiff and/or take off her clothing.
+After Defendant's relentless pawing, she reluctantly removed some of her clothing. During this
+encounter, Defendant turned over on his back and fondled Plaintiff's breasts, despite her
+repeatedly telling him not to do so. As Plaintiff massaged Defendant, Defendant proceeded to
+masturbate until ejaculation. Defendant then paid Plaintiff two hundred dollars, and Plaintiff
+was escorted out of Defendant's mansion and left Defendant's property.
+18. A similar pattern of grooming continued, and the sexual exploitation
+progressively escalated, over the course of approximately seventeen months during which
+Defendant would often travel to Palm Beach. Prior to arriving and while in Palm Beach,
+Defendant and/or his agents) would frequently call. Plaintiff at her home telephone number
+and/or other telephone numbers, arranging for encounters with her for Defendant, sometimes
+twice daily. While usually such contacts were made by his assistants, Defendant personally
+called Plaintiff repeatedly, despite being told to leave Plaintiff alone. After the first few
+encounters, Defendant coerced Plaintiff to remove all her clothing, and Defendant penetrated the
+minor Plaintiff's vagina digitally. Defendant sexually abused and/or battered and/or exploited
+Plaintiff at least a hundred times between approximately January 2004 and May 2005. Such
+exploitation included, but was not limited to, Defendant's sexual abuse and battery of Plaintiff
+with vibrator(s), back massager(s), his fingers), and his penis. At times, Defendant manipulated
+Plaintiff to interact sexually with another female. During one encounter, Defendant penetrated
+the minor Plaintiff's vagina with his penis, all the while narrating and demonstrating his sexual
+battery of Plaintiff to another female present in the room. While some of the precise dates that
+Defendant's acts of sexual exploitation occurred are unknown to Plaintiff, these dates are known
+6
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+• Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 7 of 19
+to Defendant, as he and/or his assistants kept written records, some of which are in the custody
+of law enforcement, of each instance in which he committed lewd acts upon minor girls,
+including the then minor Plaintiff.
+19.
+Defendant's preference for underage girls was well-known to those who regularly
+procured them for him. The above-described acts of abuse began to occur during a time when
+Defendant knew that Plaintiff was a minor. Defendant, at all times material to this cause of
+action, knew and/or should have known of Plaintiff's age of minority. In fact, Defendant
+repeatedly urged the minor Plaintiff to become legally emancipated in order to accompany him
+as he traveled, both nationally and internationally. Additionally, Defendant, knowing that
+Plaintiff was merely seventeen years old, lured her by inviting her to stay with him at his
+mansion in Manhattan and arranging and/or paying for airplane tickets, theater tickets, and a
+personal chauffeur as gifts for her upcoming birthday.
+20.
+As part of Defendant's persistent process of grooming Plaintiff and immersing her
+in his lewd and abusive lifestyle, Defendant regularly showered the adolescent Plaintiff with
+gifts, including, but not limited to lingerie, flowers, bikini bathing suits), art books), purse(s),
+envelopes of U.S. currency, use of a car, and/or other accoutrements.
+21.
+Defendant possessed photographs of nude underage girls, some of which may
+have been taken with hidden cameras set up in his residence in Palm Beach. On the day of
+Defendant's arrest, police found two hidden cameras and photographs of underage girls in
+Defendant's mansion. Defendant took lewd photographs of Plaintiff with his hidden cameras
+and transported lewd photographs of Plaintiff and other victims elsewhere using a facility or
+means of interstate and/or foreign commerce. On one occasion, Defendant manipulated the
+minor Plaintiff to pose nude for him and photographed her using several rolls of film. One or
+25 West flagler Street, Suite 800, Miami, PL. 3130, Miami 305.358 2800 Fax 305.358 2382 • Fort Lauderdale 954-469.1346 T
+
+
+• Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 8 of 19
+.:
+more of those nude photographs of Plaintiff that were taken by the Defendant when she was a
+minor were confiscated by the Palm Beach Police Department during its execution of a search
+warrant of Defendant's Palm Beach mansion on October 20, 2005.
+22.
+Defendant was particularly skillful at discerning his minor victims' respective
+hopes, dreams, and ambitions. As he did with many of his victims, Defendant lured Plaintiff
+early-on with modeling opportunities, impressing her with his modeling business and contacts
+with supermodels, indicating that he could help her with a modeling career.
+23. Knowing that the minor Plaintiff was an excellent student and desired to attend
+New York University or Columbia University, Defendant pretended to show great interest in her
+college. admission, and offered to help her with her applications and to assist her with her
+tuition. Defendant had told Plaintiff of his substantial connections within the academic
+community, a matter about which he often bragged. Defendant took it upon himself to take
+control of Plaintiff's college application process and led Plaintiff to believe that he was sincere
+about helping her. Even though she had earned a Bright Futures Scholarship to the Florida
+college of her choice, Defendant insisted that she would not need it, and that, with his
+involvement, she would be admitted into one or both of the universities in New York. As a
+result of Defendant's manipulation, Plaintiff did not apply timely for the Bright Futures
+Scholarship or to any college, and therefore missed the fall semester of her freshman year. When
+the Palm Beach Police Department executed the search warrant on Defendant's mansion, among
+the artifacts found and confiscated were Plaintiff's high school transcript.
+24.
+In June 2008, after an investigation by the Palm Beach Police Department, the
+State Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's
+Office, Defendant entered pleas of "guilty" to one count of solicitation of prostitution, in
+25 West flagler Stret, Sulte 800, Miami, L. 3130, Man/ 305.358 200 Fax 305.358.232 • Fort Lauderdale 954463-4346 T
+
+
+• Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 9 of 19
+violation of Fla. Stat. § 796.07, and one count of solicitation of a minor to engage in prostitution,
+in violation of Fla. Stat. § 796.03 in the Fifteenth Judicial Circuit in Palm Beach County, Florida.
+25.
+As a condition of that plea, Defendant entered into a Non-Prosecution Agreement,
+Addendum, and Affirmation (collectively, the "NPA") with the United States Attorney's Office
+for the Southern District of Florida on September 24, 2007, October 29, 2007, and December 7,
+2007, respectively. In so doing, Defendant acknowledged that Plaintiff was one of his victims
+and agreed to the following provisions of the NPA:
+8. If any of the [acknowledged victims] elects to file suit pursuant to 18 U.S.C.
+§2255, Epstein will not contest the jurisdiction of the United States District Court
+for the Southern District of Florida over his person and/or the subject matter, and
+Epstein waives his right to contest liability and also waives his right to contest
+damages up to an amount agreed to between the identified individual and Epstein,
+so long as the identified individual elects to proceed exclusively under 18 U.S.C.
+§2255, and agrees to waive any other claim for damages, whether pursuant to
+state, federal or common law.
+10. Except as to those individuals who elect to proceed exclusively under 18
+U.S.C. §2255, as set forth in paragraph (8), supra, neither Epstein's signature on
+this agreement, nor its terms, nor any resulting waivers or settlements by Epstein
+are to be construed as admissions of evidence or evidence of civil or criminal
+liability or a waive of any jurisdictional or other defense as to any person, whether
+or not her name appears on the list provided by the United States (emphasis
+added).
+26.
+Plaintiff was among the individuals identified by the United States Attorney's
+Office as victims of Defendant upon whose testimony it intended to base its federal prosecution
+of Defendant for his illegal conduct. Consequently, Defendant is estopped by his state court plea
+and the Non-Prosecution Agreement from denying the acts alleged in this Complaint and must
+effectively admit liability to Plaintiff, Jane Doe No. 103.
+COUNT ONE
+25 West flagler Street, Suite 800, Miami, FL. 3130, Miami 305358.2800 Fax 305.258.2382. • Fort Lauderdale 951463-4346 T
+
+
+'Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 10 of 19
+(Cause of Action for Coercion and Enticement of Minor to Engase in Prostitution or
+Sexual Activity pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2422(b))
+27.
+Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
+allegations contained in paragraphs 1 through 26 above.
+28.
+Defendant used a facility or means of interstate and/or foreign commerce to
+knowingly persuade, induce, entice, or coerce Plaintiff, when she was under the age of 18 years,
+to engage in prostitution and/or sexual activity for which any person can be charged with a
+criminal offense, or attempted to do so, pursuant to 18 U.S.C. § 2255 in violation of 18 U.S.C. §
+2422(b).
+29.
+Plaintiff was a victim of one or more offenses enumerated in 18 U.S.C. § 2255,
+and, as such, asserts a cause of action against Defendant pursuant to this Section of the United
+States Code.
+30.
+As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future continue to suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy,
+separation from her family, and other damages associated with Defendant's manipulating and
+luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
+and psychological expenses, and Plaintiff will in the future incur additional medical and
+psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn
+income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in
+nature, and Plaintiff will continue to suffer these losses in the future.
+10
+25 West Flagler Street, Suite 800, Miami, FL. 3130, Miami 305358-2800 Fax 305358-2782 • Port Lauderdale 951.4634346
+
+
+'Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 11 of 19
+WHEREFORE, Plaintiff demands judgment against Defendant for all damages available
+under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages,
+attorney's fees, costs of suit, and such other further relief as this Court deems just and proper,
+and hereby demands trial by jury on all issues triable as of right by a jury.
+COUNT TWO
+(Cause of Action for Travel with Intent to Engage in Illicit Sexual Conduct pursuant
+to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2423(b))
+31.
+Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
+allegations contained in paragraphs 1 through 26 above.
+32.
+Defendant traveled in interstate and/or foreign commerce for the purpose of
+engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females,
+including the then minor Plaintiff, in violation of 18 U.S.C. § 2423(b).
+33. Plaintiff was a victim of one or more offenses enumerated in 18 U.S.C. § 2255,
+and, as such, asserts a cause of action against Defendant pursuant to this Section of the United
+States Code.
+34. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future continue to suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy,
+separation from her family, and other damages associated with Defendant's manipulating and
+luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
+and psychological expenses, and Plaintiff will in the future incur additional medical and
+psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn
+11
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 12 of 19
+income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in
+nature, and Plaintiff will continue to suffer these losses in the future.
+WHEREFORE, Plaintiff demands judgment against Defendant for all damages available
+under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages,
+attorney's fees, costs of suit, and such other further relief as this Court deems just and proper,
+and hereby demands trial by jury on all issues triable as of right by a jury.
+COUNT THREE
+(Cause of Action for Sexual Exploitation of Children pursuant to 18 U.S.C. § 2255 in
+Violation of 18 U.S.C. §2251)
+35.
+Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
+allegations contained in paragraphs 1 through 26 above.
+36.
+Defendant knowingly persuaded, induced, enticed, or coerced the then minor
+Plaintiff to engage in sexually explicit conduct for the purpose of producing a visual depiction of
+such conduct, in violation of 18 U.S.C. § 2251.
+37.
+Plaintiff was a victim of one or more offenses enumerated in 18 U.S.C. § 2255,
+and, as such, asserts a cause of action against Defendant pursuant to this Section of the United
+States Code.
+38.
+As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future continue to suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy,
+separation from her family, and other damages associated with Defendant's manipulating and
+luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
+12
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.23B2 • Fort Lauderdale 954.463.4346
+
+
+Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 13 of 19
+and psychological expenses, and Plaintiff will in the future incur additional medical and
+psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn
+income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in
+nature, and Plaintiff will continue to suffer these losses in the future.
+WHEREFORE, Plaintiff demands judgment against Defendant for all damages available
+under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages,
+attorney's fees, costs of suit, and such other further relief as this Court deems just and proper,
+and hereby demands trial by jury on all issues triable as of right by a jury.
+COUNT FOUR
+(Cause of Action for Transport of Visual Depiction of Minor Engaging in Sexually Explicit
+Conduct pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2252(a)(1))
+39.
+Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
+allegations contained in paragraphs 1 through 26 above.
+40.
+Defendant knowingly mailed, transported, shipped, or sent via computer and/or
+facsimile in or affecting interstate and/or foreign commerce at least one visual depiction of the
+minor Plaintiff engaging in sexually explicit conduct, in violation of 18 U.S.C. § 2252(a)(1).
+41.
+Defendant transported lewd photographs of Plaintiff and other victims elsewhere
+using a facility or means of interstate and/or foreign commerce.
+42. Plaintiff was a victim of one or more offenses enumerated in 18 U.S.C. § 2255,
+and, as such, asserts a cause of action against Defendant pursuant to this Section of the United
+States Code.
+43.
+As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future continue to suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+13
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+www.padlhurst.com
+
+
+' Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 14 of 19
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy,
+separation from her family, and other damages associated with Defendant's manipulating and
+luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
+and psychological expenses, and Plaintiff will in the future incur additional medical and
+psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn
+income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in
+nature, and Plaintiff will continue to suffer these losses in the future.
+WHEREFORE, Plaintiff demands judgment against Defendant for all damages available
+under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages,
+attorney's fees, costs of suit, and such other further relief as this Court deems just and proper,
+and hereby demands trial by jury on all issues triable as of right by a jury.
+COUNT FIVE
+(Cause of Action for Transport of Child Pornography pursuant to 18 U.S.C. § 2255
+in Violation of 18 U.S.C. § 2252A(a)(1))
+44.
+Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
+allegations contained in paragraphs 1 through 26 above.
+45.
+Defendant knowingly mailed, transported, shipped, or sent via computer and/or
+facsimile in or affecting interstate and/or foreign commerce child pornography, in violation of 18
+U.S.C. § 2252A(a)(1).
+46. Defendant transported lewd photographs of Plaintiff and other victims elsewhere
+using a facility or means of interstate and/or foreign commerce.
+47. Plaintiff was a victim of one or more offenses enumerated in 18 U.S.C. § 2255,
+and, as such, asserts a cause of action against Defendant pursuant to this Section of the United
+States Code.
+14
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2900 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 15 of 19
+48.
+As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future continue to suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy,
+separation from her family, and other damages associated with Defendant's manipulating and
+luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
+and psychological expenses, and Plaintiff will in the future incur additional medical and
+psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn
+income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in
+nature, and Plaintiff will continue to suffer these losses in the future.
+WHEREFORE, Plaintiff demands judgment against Defendant for all damages available
+under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages,
+attorney's fees, costs of suit, and such other further relief as this Court deems just and proper,
+and hereby demands trial by jury on all issues triable as of right by a jury.
+COUNT SIX
+(Cause of Action for Engaging in a Child Exploitation Enterprise pursuant to 18
+U.S.C. § 2255 in Violation of 18 U.S.C. § 2252A(g))
+49.
+Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
+allegations contained in paragraphs 1 through 26 above and Counts One through Five above.
+50.
+Defendant knowingly engaged in a child exploitation enterprise, as defined in 18
+U.S.C. § 2252A(g)(2), in violation of 18 U.S.C. § 2252A(g)(1). As more fully set forth above,
+Defendant engaged in actions that constitute countless violations of 18 U.S.C. § 1591 (sex
+trafficking of children), Chapter 110 (sexual exploitation of children in violation of 18 U.S.C. §§
+15
+25 West Flagler Street, Sulte 800, Miami, FL. 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+' Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 16 of 19
+2251, 2252(a)(1), and 2252(A)(a)(1)), and Chapter 117 (transportation for illegal sexual activity
+in violation of 18 U.S.C. §§ 2421. 2422(b), and 2423(b)). As more fully set forth above in
+paragraphs 1 through 26, Defendant's actions involved countless victims and countless separate
+incidents of sexual abuse, which he committed against minors, including Plaintiff, in concert
+with at least three other persons.
+51.
+Plaintiff was a victim of one or more offenses enumerated in 18 U.S.C. § 2255,
+and, as such, asserts a cause of action against Defendant pursuant to this Section of the United
+States Code.
+52.
+As a direct and proximate result of the offenses enumerated in 18 U.S.C. $ 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future continue to suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy,
+separation from her family, and other damages associated with Defendant's manipulating and
+luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
+and psychological expenses, and Plaintiff will in the future incur additional medical and
+psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn
+income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in
+nature, and Plaintiff will continue to suffer these losses in the future.
+WHEREFORE, Plaintiff demands judgment against Defendant for all damages available
+under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages,
+16
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954463.4346
+
+
+• Case 9:10-cv-80309-WJZ Document 1
+Entered on FLSD Docket 03/09/2010 Page 17 of 19
+attorney's fees, costs of suit, and such other further relief as this Court deems just and proper,
+and hereby demands trial by jury on all issues triable as of right by a jury.
+Date:
+Februay 23,2010.
+By:
+Respectfully Submitted,
+Rolent C. Gaufahengby Kist
+Bar No. 040856
+Katherine W. Ezell
+Bar No. 114771
+25 West Flagler St., Suite 800
+Miami, Florida 33130
+Telephone: (305) 358-2800
+Fax: (305) 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Attorneys for Plaintiff
+17
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+• Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010
+
+115 4c"
+(Rev. 2/08)
+CIVIL COVER SHEET
+Wist
+10 SOUL
+The JS 44 civil cover sheet and the information contained hercin ncither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided
+the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)
+ty civil docket shed. (SEE INSTRUCTVONS ON THE REVERSE OF FORM NOTS torney MUST Indicatedled Cases Belone purpose of initiating
+Oled Cases Below;
+I. (a) PLAINTIFFS
+Jane Doe No. 103
+10-80310 u
+(b) County of Residence of First Listed Plaintiff
+West Palm Beach
+(EXCEPT IN U.S. PLAIN TIFF CASES)
+(c) Altomey's (Firm Name, Address, and Telephone Number)
+FILED by Ef
+D.C.
+County of Residence of First Listed Defertlant
+United States Virgin I lanr
+(IN U.S. PLAINTER CASES ONLY)
+NOTE: IN LAND CONDEMNATION CASES. FEB: 2631T2010 THE TRACT
+LAND INVOLVED.
+Robert C. Josefsberg, Esq./Katherine W. Ezell, Esq.
+STEVEN M. LARIMORE
+Attomcys (if Known)
+CLERK U. S. DIST. CT.
+25 W. Flagler St., Suite 800
+Robert D. Critton, Esq., Burman, Crital; LadieS COUABL, LIP,
+Miami FI
+77170
+303 Banyan Bivd., Suite 400, West Palm Beach, FL 33401
+(e) Check County Where Action Arose: O MIAMI DADE O MONROE O BROWARD
+VO PALM BEACH O MARTIN
+• ST. LUCIE O INDIAN RIVER
+• OKEECHOBEE
+HIGHLANDS
+II. BASIS OF JURISDICTION (Plsce an "X" in One llex Only)
+Ill. CITIZENSHIP OF PRINCIPAL PARTIES(Pince an "X" in One Box for Piaintiff
+(For Diversity Cases Only)
+and One Box for Defendant)
+O I U.S. Goverseseat
+PlaintifT
+NO Federal Question
+(U.S. Government Not a Party)
+Chizen of This State
+PTF
+Incorporased or Principal Place
+4
+DEF
+• 4
+of Business In This State
+O 2 U.S. Goverament
+Defendant
+34
+Diversity
+(Indicate Citizenship of Parsics Is Item II1)
+* Chizen of Anciher State O
+2
+P 2 Incorporaled and Principal Place
+al Business Is Aneiher State
+1O 3 Porcien Nation
+• 5
+0 5
+Citizen or Subject of: O
+Foreign Country
+• 6 as
+IV. NATURE OF SUIT (Place an "X" in One Has Onta
+CONTRACT
+TORTS
+• IIO Insurance
+• 120 Marise
+130
+Act
+140 Negotiable Instrument
+• 150 Recovery of Overpayment
+& Enforcement of Judgment
+• 151 Medicare Act
+• 152 Recovery of Defaulted
+Student Loans
+(Excl. Veterans)
+O 153 Recovery of Overpayment
+of Veteran's Benefits
+• 160 Stockbolders' Sults
+• 190 Other Conirect
+• 195 Costract Product Liabilky
+• 196 Franchise
+REAL PROPERTY
+• 210 Land Condemnaiion
+• 220 Foreclosure
+• 230 Rent Lease & Ejectmont
+O 240 Torts to Land
+• 245 Tort Product Liability
+• 290 All Other Real Property
+PERSONAL INJURY
+• 310 Airplane
+O 315 Airplane Product
+Libility
+• 320 Aswalt, Libel &
+Slander
+C] 330 Federal Employers'
+Liability
+O 340 Marine
+O 345 Marine Product
+Liability
+O 350 Meter Vehicle
+O 355 Motor Vehicle
+Product Liability
+J0 360 Other Personal
+Iniury
+CIVIL RIGHTS
+O 441 Voting
+O 442 Employneat
+• 443 Housiag/
+Accommodations
+• 444 Welfare
+445 Amer.
+• Empleyment
+w/Disabilities
+- Obe Amer. w/Disabillies o
+3 440 Other Civil Rights
+FORFEITURE TENALTY
+PERSONAL INJURY
+610 Agriculture
+362 Personal Isjury -
+620 Other Food & Drug
+Med. Malpractice
+625 Drug Related Seizare
+365 Personal Injury •
+of Property 21 USC 881
+Product Liability
+368 Asbestos Personal
+Injury Product
+0 0
+630 Liquor Laws
+640 R.R. & Truck'
+650 Airlino Regs.
+Liability
+660 Occupational
+BANKRUPTCY
+• 422 Appoal 28 USC 158
+• 423 Wichdrawal
+28 USC 157
+PROPERTY RIGHTE
+• 820 Copyrights
+• 830 Patent
+• 840 Trademark
+PERSONAL PROPERTY
+Safoly/calth
+370 Other Fraud
+• 690 Other
+371 Truth in Lending
+LAHOR
+SOCIAL SECURITY
+380 Other Personal
+710 Fair Labor Standards
+• 861 HIA (139560
+Proporty Demeage
+Act
+• 862 Black Lung (923)
+385 Properly Damage
+720 Labor/Mgmt. Relations
+O 863 DIWC/DIWW (405(g))
+Product Liability
+730 LaboniMgmt.Reporting
+• 864 SSID Tide XVI
+& Disclosure Act
+• 865 RSI (405(g))
+PRISONER PETITIONS O
+740 Railway Labor Act
+FEDERAL TAX SUITS
+510 Motions lo Vacalo
+790 Other Labor Litigasion
+• 870 Taxes (U.S. Plaintiff
+Sentence
+79| Empl. Ret. Inc. Security
+or Defendant)
+Habeas Corpus:
+O 87Í IRS-Thied Party
+530 General
+26 USC 7609
+555 Death Pemalty
+540 Mandamas & Other
+550 Civil Rights
+555 Prison Condition
+IN MUGRATION
+462 Naturalization
+Application
+463 Habeas Corpus-Alien
+Delainte
+465 Other Immigration
+Actions
+OTHER STATUTES
+400 Sinte Reapportionment
+410 Antitrust
+430 Banks and Banking
+450 Commerce
+460 Deportation
+• 470 Racketeer Influenced and
+Corrupt Organizations
+480 Consumer Credit
+490 Cable/Sat TV
+810 Solactive Service
+850 Securities/Commoditios/
+Exchange
+875 Customer Challenge
+12 USC 3410
+890 Other Statutory Actons
+891 Agricultural Acts
+892 Economic Stabilization Act
+893 Environmoncal Matters
+894 Ensrgy Allocation Act
+895 Freedom of Information Act
+1 900 Appeal of Foo Determination
+lader Equal Accosa to Jestioc
+950 Constitutionality of State
+Statuses
+• ORIGIN
+p I Original
+Proceeding
+(Pluce an "X" in One Box Only)
+• 2 Romoved from
+State Court
+3. Re-filc
+4 Reinstated or • 5
+Transferred from
+ee VI belon
+another district
+• 6 Multidistrict
+7
+Reopened
+(specify)
+Litigation
+Appeal to District
+Judge from
+Magistrate
+Judement
+a) Re-filed Case O YES PINO
+b) Related Cases Ø/YES O NO
+VI. RELATED/RE-FILED
+CASE(S).
+(See instructions
+second page:
+JUDGE Kenneth A. Marra
+DOCKET NUMBER See Attached.
+Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdietional statules untess
+diversity):
+VII. CAUSE OF ACTION 18 U.S.C. 2255 (Predicate Statutes 18 U.S.C. 2422(b), 2423(b), 2423(e), 2251, 2252, 2252A(a)(1), 2252A(g)(1)
+LENGTH OF TRIAL via J
+days estimated (for both sides to try entire case)
+VIII. REQUESTED IN
+• CHECK IF THIS IS A CLASS ACTION
+COMPLAINT:
+CHECK YES only if demanded in complaint:
+UNDER F.R.C.P. 23
+ABOVE INFORMATION IS TRUE & CORRECT TO
+THE BEST OF MY KNOWLEDGE
+SIGNATURE OF ATTORNEY OF RECORD
+IN excesS o€ $15,000." JURY DEMANDI
+Sealed No
+s/ Katheine W. Ezell
+2/53/10
+AMOUNT 350.00
+RECEIPT • 10/8042 "P
+2/23/10
+
+
+• • Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 19 of 19
+*
+VI.
+SOUTHERN DISTRICT OF FLORIDA
+WEST PALM BEACH DIVISION
+ATTACHMENT TO CIVIL COVER SHEET
+FOR: Jane Doe 103 | Jeffrey Epstein
+RELATED PENDING CASES
+08-80119 - KAM
+08-80232 - KAM
+08-80380 - KAM
+08-80381 - KAM
+08-80811 - KAM
+08-80893 - KAM
+08-80993 - KAM
+08-80994 - KAM
+09-80469 - KAM
+09-80802 - KAM
+09-81092 - KAM
+
+
+LARRY A. STUMPF
+JACKIE PERCZEK
+MARK A.J. SHAPIRO
+JARED 1
+BLACK
+SREBNICK
+KORNSPAN
+& STUMPF
+JESSICA FONSECA-NADER
+KATHLEEN P. PHILLIPS
+JENIFER J. SOULIKIAS
+NOAH FOX
+E-Mail: RBlack@RoyBlackcom
+March 29, 2010
+99 N.E. 4' Street
+Miami, FL 33132
+Assistant United States Attorney
+99 N.E. 4' Street
+Miami, FL 33132
+A. Marie Villafana, Esq.
+Assistant United States Attorney
+500 South Australian Avenue
+West Palm Beach, FL 33401-6223
+RE: Jeffrey Epstein
+Dear Counsel:
+Jeffrey Epstein has an April 5, 2010 deadline for the filing of a Motion to
+Dismiss, and thereafter an Answer, to claims brought by Jane Doe 103 pursuant
+to 18 USC $2255 that were referenced in our earlier letter to you dated March 5,
+2010, to which there has been no response. We firmly believe that the issues
+raised in the draft motion that is appended to this letter do not conflict with, nor,
+if filed, breach Mr. Epstein's obligations under the NPA.
+Please advise if any of the issues in the draft motion authored by his civil
+counsel Robert Critton are, from your perspective, in conflict with the §2255
+provisions of the NPA so that we may reassess our legal opinion that Mr. Epstein's
+civil counsel can litigate the legal issues contained in the draft motion without fear
+that the litigation will be construed by your office as being in violation of the NPA.
+Il the government believes that any of the issues intended to be raised in defense
+of the Jane Doe 103 lawsuit are in breach of Mr. Epstein's obligations under the
+NPA, we request notice so that we could decide before any filing whether to file a
+201 5. Biscayne Boulevard, Suite 1300 • Mlami, Florida 33131 • Phone: 305-371-6421 • Fax: 305-358-2006 • www.RoyBlack.com
+
+
+A. Marie Villafana, Esq.
+March 29, 2010
+Declaratory Judgment action asking the Court presiding over the Jane Doe 103
+lawsuit to determine whether the raising of the issue by motion or delense would
+be in conflict with Mr. Epstein's contractual duties under the NPA or to withdraw
+the issue to the extent we become convinced that your position, if in conflict with
+ours, is correct.
+Again, Mr. Epstein's paramount priority, and ours, is that the terms of Mr.
+Epstein's agreement with the government be followed and fulfilled.
+Your truly,
+MARTIN WEINBERG, ESQ.
+OY BLACK, ESQ
+By-
+An Head
+/ wg
+Black, Srebnick, Komspan & Stumpi, P.A. •
+
+
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 10-80309-CIV-
+JANE DOE No. 103,
+VS.
+JEFFERY EPSTEIN,
+Plaintiff,
+Defendant.
+/
+DEFENDANT EPSTEIN'S MOTION TO DISMISS, & FOR MORE
+DEFINITE STATEMENT & STRIKE DIRECTED TO PLAINTIFF
+JANE DOE NO. 103'S COMPLAINT [dated 2/23/2010]
+Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned
+counsel, moves to dismiss Counts One through Six of Plaintiff JANE DOE 103's
+Complaint for failure to state a cause of action, as specified herein. Rule 12(b)(6),
+Fed.R.Civ.P. (2009); Local Gen. Rule 7.1 (S.D. Fla. 2009). Defendant further moves for
+more definite statement and to strike. Rule 12(e) and (f), In support of his motion,
+Defendant states:
+The Complaint attempts to allege 6 counts, all of which are purportedly brought
+pursuant to 18 U.S.C. §2255 — Civil Remedies for Personal Injuries. Dismissal is
+required on the following grounds: (1) 18 U.S.C,A. §2255 allows for a single recovery of
+"actual damages."
+(A.) Statutory Considerations: the statute does not allow for the
+Plaintiff to allege multiple counts, six in this case, or multiple predicate act violations or
+incidents, in an effort to multiply or seek duplicate recoveries of her "actual damages"
+1
+
+
+based on the number of predicate act violations or incidents. The statutory minimum is
+just that - a minimum; nothing prevents a plaintiff from proving and recovering "actual
+damages" in excess of the minimum amount. (B.) Constitutional Considerations: in
+the alternative, constitutional principles require that the statute be interpreted as allowing
+for a single recovery of one's damages. Thus, to the extent Plaintiff is seeking to
+improperly multiply or seek duplicate recoveries of her actual damages, the action is
+required to be dismissed. (2) The statute in effect during the time of the alleged conduct
+applies - the version in effect from 1999 to July 26, 2006, not the statute as amended in
+2006, effective July 27, 2006. To the extent Plaintiff is attempting to rely on the
+amended version of the statute, such reliance is improper and also requires dismissal of
+the entire action. (3) Count VI is also subject to dismissal because the predicate act relied
+upon by Plaintiff did not come into effect until July 27, 2006, well after the conduct
+alleged by Plaintiff occurred.
+Supporting Memorandum of Law
+Principles of Statutory Interpretation
+It is well settled that in interpreting a statute, the court's inquiry begins with the
+plain and unambiguous language of the statutory text. CBS, Inc. . Prime Time 24
+Venture, 245 F.3d 1217 (11"' Cir. 2001); U.S. . Castroneves, 2009 WL 528251, *3 (S.D.
+Fla. 2009), citing Reeves ]. Astrue, 526 F.3d 732, 734 (11" Cir. 2008); and Smith I
+Husband, 376 F.Supp. 2d at 610 ("When interpreting a statute, [a court's] inquiry begins
+with the text.").
+"The Court must first look to the plain meaning of the words, and
+scrutinize the statute's 'language, structure, and purpose.'" Id. In addition, in construing
+a statute, a court is to presume that the legislature said what it means and means what it
+said, and not add language or give some absurd or strained interpretation. As stated in
+2
+
+
+CBS, Inc., supra at 1228 - "Those who ask courts to give effect to perceived legislative
+intent by interpreting statutory language contrary to its plain and unambiguous meaning
+are in effect asking courts to alter that language, and '[c]ourts have no authority to alter
+statutory language.... We cannot add to the terms of [the] provision what Congress left
+out.' Merritt, 120 F.3d at 1187." • See also Dodd | U.S., 125 S.Ct. 2478 (2005); 73
+Am.Jur.2d Statutes §124.
+Title 18 of the U.S.C. is entitled "Crimes and Criminal Procedure." §2255 is
+contained in "Part I. Crimes, Chap. 110. Sexual Exploitation and Other Abuse of
+Children." 18 U.S.C. §2255 (2002)', is entitled Civil remedy for personal injuries, and
+provides:
+(a) Any minor who is a victim of a violation of section 2241(c), 2242, 2243, 2251,
+2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suffers
+personal injury as a result of such violation may sue in any appropriate United
+States District Court and shall recover the actual damages such minor sustains
+and the cost of the suit, including a reasonable attorney's fee. Any minor as
+described in the preceding sentence shall be deemed to have sustained damages
+of no less than $50,000 in value.
+(b) Any action commenced under this section shall be barred unless the complaint
+is filed within six years after the right of action first accrues or in the case of a
+person under a legal disability, not later than three years after the disability.
+See endnote 1 hereto for statutory text as amended in 2006, effective July 27,
+2006. Prior to the 2006 amendments, the version of the statute quoted above was in
+effect beginning in 1999.!
+' The above quoted version of 18 U.S.C. §2255 was the same beginning in 1999 until
+amended in 2006, effective July 27, 2006.
+3
+
+
+Motion to Dismiss
+(1) The remedy afforded pursuant to 18 U.S.C. $2255 allows for a single
+recovery of "actual damages" by a plaintiff against a defendant. The recovery
+afforded is not on a per violation or per incident or per count basis.'
+(A.)
+Statutory Considerations. 18 U.S.C.A. §2255 - Civil Remedy for Personal
+Injuries, creates a federal cause of action or "civil remedy" for a minor victim of sexual,
+abuse, molestation and exploitation, and allows for a single recovery of the "actual
+damages" sustained and proven by a "minor who is a victim of a violation" of an
+enumerated predicated act and who suffers personal injury as a result of such violation."
+"18 U.S.C. §2255 gives victims of sexual conduct who are minors a private right of'
+action." Martinez. |. White, 492 F.Supp.2d 1186, 1188 (N.D. Cal. 2007). 18 U.S.C.A.
+§2255 "merely provides a cause of action for damages in any appropriate United States
+District Court."" Id, at 1189.
+Under the plain meaning of the statute, §2255 does not allow for the actual
+damages sustained to be duplicated or multiplied on behalf of a plaintiff against a
+defendant on a "per violation" or "per incident" or "per count" basis. No where in the
+2 In other 82255 actions filed against Defendant, Defendant has previously asserted the
+position that 18 U.S.C. §2255's creates a single cause of action on behalf of a plaintiff
+against a defendant, as opposed to multiple causes of action on a per violation basis or as
+opposed to an allowance of a multiplication of the statutory presumptive minimum
+damages or "actual damages." EPSTEIN asserts his position regarding the single
+recovery of damages in order to properly preserve all issues pertaining to the proper
+application of §2255 for appeal. EPSTEIN will fully honor his obligations as set forth
+in the Non-Prosecution Agreement with the United States Attorney's Office;
+principally, as related to the claims made in this case by Jane Doe 103, the
+obligations as set forth in paragraph 8 of that Agreement. In particular, EPSTEIN
+will not contest the allegation that he committed at least one predicate offense as
+alleged by Jane Doe 103, a waiver sufficient to satisfy the 2255 statutory condition
+that Jane Doe 103 was a victim of the commission of one of the enumerated
+predicate violations as required.
+4
+
+
+statutory text is there any reference to the recovery of damages afforded by this statute as
+being on a "per violation" or "per incident" or "per count" basis. 18 U.S.C. 2255(a)
+creates a civil remedy for "a minor who is a victim of a violation of section 2241(c),
+2242, 2243, 2251, 2251A, 2252, 2252A; 2260, 2421, 2422, or 2423 of this title and who
+suffers personal injury as a result of such violation ...." The statute speaks in terms of
+the recovery of the "actual damages such minor sustains and the cost of suit, including
+attorney's fees." See 18 U.S.C. §2255(a) (2002). See Smith |. Husband, 428 F.Supp.2d
+432 (E.D. Va. 2006); Smith |. Husband, 376 F.Supp.2d 603 (E.D. Va. 2006); Doe |
+Liberatore, 478 F.Supp.2d 742, 754 (M.D. Pa. 2007); and the recent cases in front of this
+court on Defendant's Motions to Dismiss and For More Definite Statement - Doe No. 2
+1. Epstein, 2009 WL 383332 (S.D. Fla. Feb. 12, 2009); Doe No. 3 |. Epstein, 2009 WL
+383330 (S.D. Fla. Feb. 12, 2009); Doe No. 4 |. Epstein, 2009 WL 383286 (S.D. Fla. Feb.
+12, 2009); and Doe No. 5||. Epstein, 2009 WL 383383 (S.D. Fla. Feb. 12, 2009); see also
+U.S. |. Scheidt, Slip Copy, 2010 WL. 144837, fn. 1 (E.D.Cal. Jan. 11, 2010); U.S. |.
+Renga, 2009 WL 2579103, fn. 1 (E.D. Cal. Aug. 19, 2009); U.S. |. Ferenci, 2009 WL
+2579102, fn. 1 (E.D. Cal. Aug. 19, 2009); U.S. |. Monk, 2009 WL 2567831, fn. 1 (E.D.
+Cal. Aug. 18, 2009); U.S. _. Zane, 2009 WL 2567832, fn.1 (E.D. Cal. Aug. 18 2009).
+As to the meaning of "actual damages," the Eleventh Circuit in McMillian |
+F.D.I.C., 81 F.3d 1041, 1055 (11th Cir. 1996)?, succinctly explained:
+" In McMillian, the 11* Circuit was faced with the task of the interpretation of the
+statutory term "actual direct compensatory damages" under FIRREA, 12 U.S.C.
+§1821 (e)(3)(i). In doing so, the Court began with the plain meaning of the phrase. See
+Perrin | United States, 444 U.S. 37, 42-43, 100 S.Ct. 311, 314, 62 L.Ed.2d 199 (1979)
+("A fundamental canon of statutory construction is that, unless otherwise defined, words
+Will be interpreted as taking their ordinary, contemporary common meaning."); United
+States |. McLymont, 45 F.3d 400, 401 (11th Cir.), cert. denied, 514 U.S. 1077, 115 S.Ct.
+5
+
+
+... "Compensatory damages" are defined as those damages that "will
+compensate the injured party for the injury sustained, and nothing more; such
+as will simply make good or replace the loss caused by the wrong or injury."
+Black's Law Dictionary (6th Ed.1991). "Actual damages," roughly
+synonymous with compensatory damages, are defined as "[r]eal,
+substantial and just damages, or the amount awarded to a complainant
+'Finally, "[d]irect
+damages are such as follow immediately upon the act done." Id. Thus,
+"actual direct compensatory damages" appear to include those damages,
+flowing directly from the repudiation, which make one whole, as opposed
+to those which go farther by including future contingencies such as lost
+profits and opportunities or damages based on speculation. [Citation
+omitted]. ...
+FN15. According to Corpus Juris Secundum, " "Compensatory damages'
+and 'actual damages' are synonymous terms ... and include| | all
+damages other than punitive or exemplary damages." 25 C.J.S.
+Damages § 2 (1966).
+(Emphasis added).
+See also, Fanin r. U.S. Dept. of Veteran Affairs, 2009 WL 1677233 (11" Cir. June
+17, 2009), citing Fitzpatrick . IRS, 665 F.2d 327, 331 (11" Cir. 1982), abrogated on
+other grounds by Doc. Chao, 540 U.S. 614, 124 S.Ct. 1204 (2004) "Actual damages".
+recoverable under the Privacy Act are "proven pecuniary losses and not for generalized
+mental injuries, loss of reputation, embarrassment or other non-qualified injuries;" and
+the statutory minimum of $1,000 under the Privacy Act is not available unless the
+plaintiff suffered some amount of "actual damages.").
+Considering the plain meaning of "actual damages" and the purpose of such
+damages is to "make one whole," to allow a duplication or multiplication of the actual
+damages sustained is in direct conflict with the well entrenched legal principle against
+duplicative damages recovery. See generally, E.E.O.C. I. Waffle House, Inc., 534 U.S.
+1723, 131 L.Ed.2d 581 (1995) ("IT]he plain meaning of this statute controls unless the
+language is ambiguous or leads to absurd results.").
+6
+
+
+279, 297, 1228.CL 754, 766(2002 " As we have noted, it goes without saying that the
+courts can and should preclude double recovery by an individual."), citing General
+Telephone, 446 U.S., at 333, 100 S.Ct. 1698.
+The purpose of damages recovery where a Plaintiff has suffered personal injury
+as a result of Defendant's misconduct is to make the plaintiff whole, not to enrich the
+plaintiff. See 22 Am.Jur.2d Damages §36, stating the settled legal principle that -
+The law abhors duplicative recoveries, and a plaintiff who is injured by a
+defendant's misconduct is, for the most part, entitled to be made whole, not
+enriched. Hence, for one injury, there should be one recovery, irrespective of
+the availability of multiple remedies and actions. Stated otherwise, a party
+cannot recover the same damages twice, even if recovery is based on
+different theories.
+, a plaintiff who alleges separate causes of action is not permitted to recover
+more than the amount of damages actually suffered. There cannot be a
+double recovery for the same loss, even though different theories of liability
+are alleged in the complaint. ....
+See also, 22 Am.Jur.2d Damages § 28 -
+The law abhors duplicative recoveries; in other words, a plaintiff who is
+injured by reason of a defendant's behavior is, for the most part, entitled to be
+made whole, not to be enriched. The sole object of compensatory damages is
+to make the injured party whole for losses actually suffered; the plaintiff
+cannot be made more than whole, make a profit, or receive more than one
+recovery for the same harm. Thus, a plaintiff in a civil action for damages
+cannot, in the absence of punitive or statutory treble damages, recover more
+than the loss actually suffered. The plaintiff is not entitled to a windfall, and
+the law will not put him in a better position than he would be in had the
+wrong not been done or the contract not been broken.
+See also recent case of U.S. |. Baker, 2009 WL 4572, at *8, (E.D. Tx. Dec. 7,
+2009), wherein the Court was inclined to agree with the defendant's interpretation of
+§2255(a) of allowing for a single recovery of the statutory minimum damages amount as
+opposed to the government's argument that "the minimum amount of damages mandated
+by 18 U.S.C. §2255(a) applies to cach of (pornographic) image produced by
+7
+
+
+[defendant]." The government attempted to argue that restitution should be equal to the
+statutory minimum amount times the 55 photos produced by defendant. In rejecting the
+government's argument, the Court reiterated that the statutory minimum is a floor for
+damages
+- in other words, a mandated minimum. Nothing prevents a plaintiff from
+proving that he or she suffered damages in a greater amount.
+In attempting to bring six counts pursuant to §2255, Plaintiff's complaint alleges in
+part that "Plaintiff was merely a seventeen year old high school student when she was
+first lured into Defendant's sexually exploitive world in or about January 2004."
+Complaint, 917. According to the allegations, Plaintiff "was recruited while at work by a
+co-worker, one of the minor victims Defendant paid to procure underage females." Id.
+The Complaint further alleges, 1117-26, that Defendant "sexually abused and/or battered
+and/or exploited Plaintiff at least 100 times between January 2004 and May 2005." If
+Plaintiff were 17 in January, 2004, she was at least 18 (the age of majority) in January
+2005, if not sooner.*
+Plaintiff alleges identical damages in each of the six counts. Complaint, 1930, 34,
+38, 43, 48, and 52. See endnote 2 hereto for Complaint allegations? In other words,
+Plaintiff is alleging and seeking recovery of duplicative damages in each of the six
+counts.
+To the extent Plaintiff is seeking to duplicate her "actual damages" on a per
+incident or per violation or per count basis, Plaintiff's action is required to be dismissed
+for failure to state a cause of action.
+^ Defendant is moving for more definite statement requiring Plaintiff to specifically state
+her date of birth because her age and when she reached the age of majority may impact
+her ability to even pursue a §2255 claim.
+8
+
+
+Had Congress wanted to write in a multiplier of actual damages recoverable it
+could have easily done so. For an example of a statute wherein the legislature included
+the language "for each violation" in assessing a "civil penalty," see 18 U.S.C. §216,
+entitled "Penalties and injunctions," of Chapter 11 - "Bribery, Graft, and Conflict of
+Interests," also contained in Title 18 - "Crimes and Criminal Procedure." Subsection (b)
+of §216 gives the United States Attorney General the power to bring a "civil action ...
+against any person who engages in conduct constituting an offense under" specified
+sections of the bribery, graft, and conflicts of interest statutes. The statute further
+provides in relevant part that "upon proof of such conduct by a preponderance of the
+evidence, such person shall be subject to a civil penalty of not more than $50,000 for
+each violation or the amount of compensation which the person received or offered for
+the prohibited conduct, which ever amount is greater." As noted, 18 U.S.C. §2255 does
+not include such language.
+B.
+Constitutional Considerations. As set forth above, it is Defendant's
+position that the text of 18 U.S.C. §2255 does not allow a Plaintiff to pursue the recovery
+of actual damages or the minimum afforded under the statute on a "per violation" or "per
+incident" basis by attempting to allege multiple counts thereunder. In the alternative, if
+one were to assume that the language of §2255 were vague or ambiguous, under the
+constitutional based protections of due process, judicial restraint, and the rule of lenity
+applied in construing a statute, Defendant's position as to the meaning of the statute
+would prevail.
+See United States |. Santos, 128 S.Ct. 2020, 2025 (2008). As
+summarized by the United States Supreme Court in Santos, supra, at 2025:
+See argument in sections (2) and (3) that follow which represent the predicate for the rule of
+lenity issue discussed in B
+9
+
+
+... The rule of lenity requires ambiguous criminal laws to be interpreted in
+J. 0t, 06, d, d, S.Ct. ub7, Gl GIL. d. 851 (19U7); Marie i. United States
+J.S. 476. 483
+283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931); United States |. Bass,
+404 U.S. 336, 347-349, 92 S.Ct. 515, 30 L.Ed.2d 488 (1971). This venerable
+rule not only vindicates the fundamental principle that no citizen should be
+held accountable for a violation of a statute whose commands are uncertain,
+or subjected to punishment that is not clearly prescribed. It also places the
+weight of inertia upon the party that can best induce Congress to speak more
+clearly and keeps courts from making criminal law in Congress's stead. ...
+In Santos, the Court was faced with the interpretation of the term "proceeds" in
+the federal money laundering statute, 18 U.S.C. §1956. "The federal money-laundering
+statute prohibits a number of activities involving criminal "proceeds.'" Id, at 2023.
+Noting that the term "proceeds" was not defined in the statute, the Supreme Court stated
+the well settled principle that "when a term is undefined, we give it its ordinary
+meaning." Id, at 2024. Under the ordinary meaning principle, the government's position
+was that proceeds meant "receipts," while the defendant's position was that proceeds
+meant "profits." The Supreme Court recognized that under either of the proffered
+"ordinary meanings," the provisions of the federal money-laundering statute were still
+coherent, not redundant, and the statute was not rendered "utterly absurd." Under such a
+situation, citing to a long line of cases and the established rule of lenity, "the tie must go
+to the defendant." Id, at 2025. See portion of Court's opinion quoted above. "Because
+the 'profits' definition of 'proceeds' is always more defendant friendly that the "receipts'
+definition, the rule of lenity dictates that it should be adopted." Id.
+The recent case of United States |. Berdeal, 595 F.Supp.2d 1326 (S.D. Fla, 2009),
+further supports Defendant's argument that the "rule of lenity" requires that the Court
+resolve any statutory interpretation conflict in favor of Defendant. Assuming for the sake
+of argument that Plaintiff's multiple counts, leading to a multiplication of the statutory
+10
+
+
+damages
+amount, is a
+reasonable interpretation, like Defendant's reasonable
+interpretation, under the "rule of lenity," any ambiguity is resolved in favor of the least
+draconian measure. In Berdeal, applying the rule of lenity, the Court sided with the
+Defendants' interpretation of the Lacey Act which makes illegal the possession of snook
+caught in specified jurisdictions. The snook had been caught in Nicaraguan waters. The
+defendants filed a motion to dismiss asserting the statute did not encompass snook caught
+in foreign waters. The United States disagreed. Both sides presented reasonable
+interpretations regarding the reach of the statute. In dismissing the indictment, the Court
+determined that the rule of lenity required it to accept defendants' interpretation.
+To allow a duplication or multiplication would subject Defendant EPSTEIN to a
+punishment that is not clearly prescribed - an unwritten multiplier of the "actual
+damages" or the presumptive minimum damages. The rule of lenity requires that
+Defendant's interpretation of the remedy afforded under §2255 be adopted.
+In addition, under the Due Process Clause's basic principle of fair warning -
+... a criminal statute must give fair warning of the conduct that it makes a
+crime
+As was said in United States |. Harriss, 347 U.S. 612, 617, 74
+S.Ct. 808, 812, 98 L.Ed. 989,
+*The constitutional requirement of definiteness is violated by a criminal
+statute that fails to give a person of ordinary intelligence fair notice that
+his contemplated conduct is forbidden by the statute. The underlying
+principle is that no man shall be held criminally responsible for conduct
+which he could not reasonably understand to be proscribed.'
+Thus we have struck down a [state] criminal statute under the Due Process
+Clause where it was not 'sufficiently explicit to inform those who are subject
+to it what conduct on their part will render them liable to its penalties.'
+Connally |. General Const. Co., 269 U.S. 385, 391, 46 S.Ct, 126, 127, 70
+L.Ed. 322. We have recognized in such cases that 'a statute which either
+forbids or requires the doing of an act in terms so vague that men of common
+intelligence must necessarily guess at its meaning and differ as to its
+application violates the first essential of due process of law,' ibid., and that
+11
+
+
+'No one may be required at peril of life, liberty or property to speculate as to
+the meaning of penal statutes. All are entitled to be informed as to what the
+State commands or forbids.' Lanzetta |. New Jersey, 306 U.S. 451, 453, 59
+S.Ct. 618, 619, 83 L.Ed. 888.
+Thus, applying
+the statutory analysis, in A. and these well-entrenched
+constitutional principles of statutory interpretation and application in B., Plaintiff's cause
+of action - Counts One through Six - to the extent Plaintiff is attempting to multiply
+actual damages or the presumptive amount of damages, is required to be dismissed for
+failure to state a cause of action.
+(2) In addition, if Plaintiff is relving on the amended version of 18 U.S.C. $2255,
+such reliance is improper and requires dismissal of the entire action. It is
+Defendant's position that 18 U.S.C. §2255. in effect prior to the 2006
+amendments applies to this action.
+(3) Further, Count Six is also required to be dismissed as it relies on a predicate
+act that was not in effect at the time of the alleged conduct."
+Plaintiff does not specifically allege in her Complaint on which version of 18
+U.S.C. §2255 she is relying. However, in the purported Count Six of her Complaint, 50,
+she alleges that Defendant "knowingly engaged in a child exploitation enterprise, as
+defined in 18 U.S.C. §2252A(g)(2), in violation of 18 U.S.C. §2252A(g)(I)." §2252A is
+one of the specified predicate acts under 18 U.S.C. §2255, However, subsection (g) of
+§2252 was not added to the statute until 2006. Thus, to the extent that Plaintiff is relying
+on the amended version, such reliance is improper and the entire action is required to be
+dismissed. Further, in the alternative, Count Six is required to be dismissed as it relies on
+a statutory predicate act that did not exist at the time of the alleged conduct.
+The statute in effect during the time the alleged conduct occurred is 18 U.S.C.
+§2255 (2005) - the version in effect prior to the 2006 amendment, eff. Jul. 27, 2006,
+® Points (2) and (3) are addressed together as the legal arguments overlap.
+12
+
+
+(quoted above), and having an effective date of 1999 through July 26, 2006. See
+endnote 1 hereto. Plaintiff's Complaint alleges that Defendant's conduct occurred during
+the time period from the age of 17, January 2004 until approximately May 2005.
+Complaint, 9917, 18. Thus, the version in effect in 2004-2005 of 18 U.S.C. §2255
+applies.
+Under applicable law, the statute in effect at the time of the alleged conduct
+applies. See U.S. |. Scheidt, Slip Copy, 2010 WL 144837, fn. 1 (E.D.Cal. Jan. 11, 2010);
+U.S. . Renga, 2009 WL 2579103, fn. 1 (E.D. Cal. Aug. 19, 2009); U.S. |- Ferenci, 2009
+WL 2579102, fn. 1 (E.D. Cal. Aug. 19, 2009); U.S. |. Monk, 2009 WL 2567831, fn. 1
+(E.D. Cal. Aug. 18, 2009); U.S. | Zane, 2009 WL 2567832, fn.1 (E.D. Cal. Aug. 18
+2009). In each of these cases, the referenced footnote states -
+Prior to July 27, 2006, the last sentence in Section §2255(a) read "Any
+person as described in the preceding sentence shall be deemed to have
+sustained damages of no less than $50,000 in value." Under the civil statute,
+the minimum restitution amount for any violation of Section 2252 (the
+predicate act at issue) is $150,000 for violations occurring after July 27, 2006
+and $50,000 for violations occurring prior to $50,000.
+Even with the typo (the extra "$50,000") at the end of the quoted sentence, it is
+clear that the Court applied the statute in effect at the time of the alleged criminal conduct
+constituting one of the statutorily enumerated predicate acts, which is consistent with
+applicable law discussed more fully below herein.
+It is an axiom of law that "retroactivity is not favored in the law." Bowen, 488
+U.S., at 208, 109 S.Ct., at 471 (1988). As eloquently stated in Landgraf. USI Film
+Products, 114 S.Ct. 1483, 1497, 511 U.S. 244, 265-66 (1994):
+... the presumption against retroactive legislation is deeply rooted in our
+jurisprudence, and embodies a legal doctrine centuries older than our Republic.
+Elementary considerations of fairness dictate that individuals should have an
+opportunity to know what the law is and to conform their conduct accordingly; settled
+13
+
+
+expectations should not be lightly disrupted.™ For that reason, the "principle that the
+legal effect of conduct should ordinarily be assessed under the law that existed when the
+conduct took place has timeless and universal appeal," Kaiser, 494 U.S., at 855, 110
+S.Ct., at 1586 (SCALIA, J., concurring). In a free, dynamic society, creativity in both
+commercial and artistic endeavors is fostered by a rule of law that gives people
+confidence about the legal consequences of their actions.
+FN18. See General Motors Corp. |. Romein, 503 U.S. 181, 191, 112 S.Ct. 1105,
+1112, 117 L.Ed.2d 328 (1992) (*Retroactive legislation presents problems of
+unfairness that are more serious than those posed by prospective legislation, because
+it can deprive citizens of legitimate expectations and upset settled transactions");
+[Further citations omitted].
+It is therefore not surprising that the antiretroactivity principle finds expression in
+several provisions of our Constitution. The Ex Post Facto Clause flatly prohibits
+retroactive application of penal legislation.'NI9 Article I, § 10, cl. 1, prohibits States
+from passing another type of retroactive legislation, laws "impairing the Obligation of
+Contracts." The Fifth Amendment's Takings Clause prevents the Legislature (and other
+government actors) from depriving private persons of vested property rights except for
+a "public use" and upon payment of "just compensation." The prohibitions on "Bills of
+Attainder" in Art, I, §§ 9-10, prohibit legislatures from singling out disfavored persons
+and meting out summary punishment for past conduct. See, e.g. United States |
+Brown, 381 U.S. 437, 456-462, 85 S.Ct. 1707, 1719-1722, 14 L.Ed.2d 484 (1965). The
+Due Process Clause also protects the interests in fair notice and repose that may be
+compromised by retroactive legislation; a justification sufficient to validate a statute's
+prospective application under the Clause "may not suffice" to warrant its retroactive
+application. Usery |. Turner Elkhorn Mining Co., 428 U.S. 1, 17, 96 S.Ct. 2882, 2893,
+49 L.Ed.2d 752 (1976).
+FN19. Article I contains two Ex Post Facto Clauses, one directed to Congress (§ 9,
+cl. 3), the other to the States (§ 10, cl. I). We have construed the Clauses as
+applicable only to penal legislation. See Calder I. Bull, 3 Dall. 386, 390-391, 1
+L.Ed. 648 (1798) (opinion of Chase, J.).
+These provisions demonstrate that retroactive statutes raise particular concerns. The
+Legislature's unmatched powers allow it to sweep away settled expectations suddenly
+and without individualized consideration. Its responsivity to political pressures poses a
+risk that it may be tempted to use retroactive legislation as a means of retribution
+against unpopular groups or individuals. As Justice Marshall observed in his opinion for
+**1498 the Court in Weaver |. Graham, 450 U.S. 24, 101 S.Ct. 960, 67 L.Ed.2d 17
+(1981), the Ex Post Facto Clause not only ensures that individuals have "fair warning"
+'about the effect of criminal statutes, but also "restricts governmental power by
+restraining arbitrary and potentially vindictive legislation." Id., at 28-29, 101 S.Ct., at
+963-964 (citations omitted).
+FN20. See Richmond |. J. A. Croson Co., 488 U.S. 469, 513-514, 109 S.Ct. 706,
+732, 102 L.Ed.2d 854 (1989) ("Legislatures are primarily policymaking bodies that
+promulgate rules to govern future conduct. The constitutional prohibitions against
+the enactment of ex post facto laws and bills of attainder reflect a valid concern
+about. the use of the political process to punish or characterize past conduct of
+14
+
+
+rivate citizens. It is the judicial system, rather than the legislative process, that i
+est equipped to identify past wrongdoers and to fashion remedies that will creat
+the conditions that presumably would have existed had no wrong been committed)
+(STEVENS, J., concurring in part and concurring in judgment); James . United
+States, 366 U.S. 213, 247, n. 3, 81 S.Ct. 1052, 1052, n. 3, 6 L.Ed.2d 246 (1961)
+(retroactive punitive measures may reflect "a purpose not to prevent dangerous
+conduct generally but to impose by legislation a penalty against specific persons or
+classes of persons").
+These well entrenched constitutional protections and presumptions against
+retroactive application of legislation establish that 18 U.S.C. §2255 (2005) in effect at the
+time of the alleged conduct applies to the instant action, and not the amended version.
+B. Not only is there no clear express intent stating that the statute is to apply
+retroactively, but applying the current version of the statute, as amended in 2006, would
+be in clear violation of the Ex Post Facto Clause of the United States Constitution as it
+would be applied to events occurring before its enactment and would increase the penalty
+or punishment for the alleged crime. U.S. Const. Art. 1, 89, cl. 3, §10, cl. 1. U.S. |
+Seigel, 153 F.3d 1256 (11" Cir. 1998); U.S. |. Edwards, 162 F.3d 87 (3d Cir. 1998); and
+generally, Calder |. Bull, 3 U.S. 386, 390, 1 L.Bd. 648, 1798 WL 587 (Calder) (1798).
+The United States Constitution provides that "Injo Bill of Attainder or ex
+post facto Law shall be passed" by Congress. U.S. Const, art. I, § 9, cl. 3. A law
+violates the Ex Post Facto Clause if it " 'appli[es] to events occurring before its
+enactment .. [and] disadvantage[s] the offender affected by it' by altering the
+definition of criminal conduct or increasing the punishment for the crime."
+Lynce ||, Mathis, 519 U.S. 433, 117 S.Ct. 891, 137 L.Ed.2d 63 (1997) (quoting
+Weaver |. Graham, 450 U.S. 24, 29, 101 S.Ct. 960, 67 L.Ed.2d 17 (1981)).
+U.s. |. Siegel, 153 F.3d 1256, 1259 (11"" Cir. 1998).
+§2255 is contained in Title 18 of the United States Codes - "Crimes and Criminal
+Procedure, Part I. Crimes, Chap. 110. Sexual Exploitation and Other Abuse of Children."
+18 U.S.C. §2255 (2005), is entitled Civil remedy for personal injuries, and imposes a
+presumptive minimum of damages in the amount of $50,000, should Plaintiff prove any
+15
+
+
+violation of the specified criminal statutes and that she suffered personal injury and
+sustained actual damages. Thus, the effect of the 2006 amendments, effective July 27,
+2006, would be to triple the amount of the statutory minimum previously in effect during
+the time of the alleged acts.
+The statute, as amended in 2006, contains no language stating that the application
+is to be retroactive.
+Thus, there is no manifest intent that the statute is to apply
+retroactively, and, accordingly, the statute in effect during the time of the alleged conduct
+is to apply. Landgraf || USI Film Products, supra, at 1493, ("'A statement that a statute
+will become effective on a certain date does not even arguably suggest that it has any
+application to conduct that occurred at an earlier date.").
+This statute was enacted as part of the Federal Criminal Statutes targeting sexual
+predators and sex crimes against children. H.R. 3494, "Child Protection and Sexual
+Predator Punishment Act of 1998;" House Report No. 105-557, 11, 1998 U.S.C.A.N.
+678, 679 (1998). Quoting from the "Background and Need For Legislation" portion of
+the House Report No. 105-557, 11-16, H.R. 3494, of which 18 U.S.C. §2255 is included,
+is described as "the most comprehensive package of new crimes and increased penalties
+ever developed in response to crimes against children, particularly assaults facilitated by
+computers."
+Further showing that $2255 was enacted as a criminal penalty or
+punishment, "Title II - Punishing Sexual Predators," Sec. 206, from House Report No.
+105-557, 5-6, specifically includes reference to the remedy created under §2255 as an
+additional means of punishing sexual predators, along with other penalties and
+punishments. Senatorial Comments in amending §2255 in 2006 confirm that the creation
+of the presumptive minimum damage amount is meant as an additional penalty against
+16
+
+
+those who sexually exploit or abuse children. 2006 WL 2034118, 152 Cong. Rec. S8012-
+02. Senator Kerry refers to the statutorily imposed damage amount as "penalties." Id.
+The cases of U.S. . Siegel, supra (11" Cir. 1998), and U.S. _. Edwards, supra (3d
+Cir. 1998), also support Defendant's position that application of the current version of 18
+U.S.C. §2255 would be in clear violation of the Ex Post Facto Clause. In Siegel, the
+Eleventh Circuit found that the Ex Post Facto Clause barred application of the Mandatory
+Victim Restitution Act of 1996 (MVRA) to the defendant whose criminal conduct
+occurred before the effective date of the statute, 18 U.S.C. §3664(f)(1)(A), even though
+the guilty plea and sentencing proceeding occurred after the effective date of the statute.
+On July 19, 1996, the defendant Siegel pleaded guilty to various charges under 18 U.S.C.
+§371 and §1956(a)(1)(A), (conspiracy to commit mail and wire fraud, bank fraud, and
+laundering of money instruments; and money laundering). He was sentenced on March
+7, 1997. As part of his sentence, Siegel was ordered to pay $1,207,000.00 in restitution
+under the MVRA which became effective on April 24, 1996. Pub.L. No. 104-132, 110
+Stat. 1214, 1229-1236. The 1996 amendments to MVRA required that the district court
+must order restitution in the full amount of the victim's loss without consideration of the
+defendant's ability to pay. Prior to the enactment of the MVRA and under the former 18
+U.S.C. §3664(a) of the Victim and Witness Protection Act of 1982 (VWPA), Pub.I. No.
+97-291, 96 Stat. 1248, the court was required to consider, among other factors, the
+defendant's ability to pay in determining the amount of restitution.
+When the MVRA was enacted in 1996, Congress stated that the amendments to the
+VWPA "shall, to the extent constitutionally permissible, be effective for sentencing
+proceedings in cases in which the defendant is convicted on or after the date of enactment
+17
+
+
+of this Act [Apr. 24, 1996]." Siegel, supra at 1258. The alleged crimes occurred between
+February, 1988 to May, 1990. The Court agreed with the defendant's position that 1996
+MVRA "should not be applied in reviewing the validity of the court's restitution order
+because to do so would violate the Ex Post Facto Clause of the United States
+Constitution. See U.S. Const. art I, §9, cl. 3."
+The Ex Post Facto analysis made by the Eleventh Circuit in Siegel is applicable to
+this action. In resolving the issue in favor of the defendant, the Court first considered
+whether a restitution order is a punishment. Id, at 1259. In determining that restitution
+was a punishment, the Court noted that §3663A(a)(1) of Title 18 expressly describes
+restitution as a "penalty." In addition, the Court also noted that "[a]lthough not in the
+context of an ex post facto determination, ... restitution is a "criminal penalty meant to
+have strong deterrent and rehabilitative effect.' United States |. Twitty, 107 F.3d 1482,
+1493 n. 12 (11th Cir.1997)." Second, the Court considered "whether the imposition of
+restitution under the MVRA is an increased penalty as prohibited by the Ex Post Facto
+Clause." Id, at 1259. In determining that the application of the 1996 MVRA would
+indeed run afoul of the Constitution's Ex Post Facto Clause, the Court agreed with the
+majority of the Circuits that restitution under the 1996 MVRA was an increased penalty?
+"The effect of the MVRA can be detrimental to a defendant. Previously, after considering
+the defendant's financial condition, the court had the discretion to order restitution in an
+amount less than the loss sustained by the victim. Under the MVRA, however, the court
+" The Eleventh Circuit, in holding that "the MVRA cannot be applied to a person whose
+with the Second, Third, Eighth, Ninth, and D.C. Circuits. See U.S. |. Futrell, 209 F.3d
+1286, 1289-90 (11" Cir. 2000).
+18
+
+
+must order restitution to each victim in the full amount." Id, at 1260. See also U.S. |
+Edwards, 162 F.2d 87 (3" Circuit 1998).
+In the instant case, in answering the first question, it is clear that that imposition of
+a minimum amount of damages, regardless of the amount of actual damages suffered by a
+minor victim, is meant to be a penalty or punishment. See statutory text and House Bill
+Reports, cited above herein, consistently referring to the presumptive minimum damages
+amount under §2255 as "punishment" or "penalties." According to the Ex Post Facto
+doctrine, although §2255 is labeled a "civil remedy," such label is not dispositive; "if the
+effect of the statute is to impose punishment that is criminal in nature, the ex post facto
+clause is implicated." See generally, Roman Catholic Bishop of Oakland |. Superior
+Court, 28 Cal.Rptr.3d 355, at 360, citing Kansas |. Hendricks, 521 U.S. 346, 360-61
+(1997). The effect of applying the 2006 version of §2255 would be to triple the amount
+of the presumptive minimum damages to a minor who proves the elements of her §2255
+claim. The fact that a plaintiff proceeding under §2255 has to prove a violation of a
+criminal statute and suffer personal injury to recover damages thereunder, further
+supports that the imposition of a minimum amount, regardless of a victim's actual
+damages sustained, is meant and was enacted as additional punishment or penalty for
+violation of criminal sexual exploitation and abuse of minors.
+Accordingly, this Court is required to apply the statute in effect at the time of the
+alleged criminal acts. Not only is there no language in the 2006 statute stating that it is to
+apply retroactively, but further, such application of the 2006 version of 18 U.S.C. §2255
+to acts that occurred prior to its effective date would have a detrimental and punitive
+19
+
+
+effect on Defendant by tripling the presumptive minimum of damages available to a
+plaintiff, regardless of the actual damages suffered.®
+C. As discussed above, 18 U.S.C. §2255 was enacted as part of the criminal
+statutory scheme to punish and penalize those who sexually exploit and abuse minors,
+and thus, the Ex Post Fact Clause prohibits a retroactive application of the 2006 amended
+version. Even if one were to argue that the statute is "civil and the damages thereunder
+are "civil" in nature,
+under the analysis provided by the United States Supreme Court in
+Landgraf |. USI Film Products, 511 U.S. 244, 114 S.Ct. 1483 (1994), pertaining to civil
+statutes, not only is there no express intent by Congress to apply the new statute to past
+conduct, but also, the clear effect of retroactive application of the statute would be to
+increase the potential liability for past conduct from a minimum of $50,000 to $150,000,
+and thus in violation of the constitutional prohibitions against such application. As noted,
+18 U.S.C. §2255 is entitled "Civil remedy for personal injuries." Notwithstanding this
+label, the statute was enacted as part of the criminal statutory scheme to punish those who
+sexually exploit and abuse minors.
+Regardless of the actual damages suffered or proven
+by a minor, as long as a minor proves violation of a specified statutory criminal act under
+§2255 and personal injury, the defendant is held liable for the statutory imposed
+minimum.
+Notwithstanding the above legal analysis, in the recent case of Individual Known
+to Defendant As 08MIST096.JPG and 08mist067.jpg |. Falso, 2009 WL 4807537 (N.D.
+N.Y. Dec. 9, 2009), United States District Court for the Northern District of New York
+8 Plaintiff has attempted to allege 6 counts pursuant to 18 U.S.C. §2255. If it is Plaintiff's
+20
+
+
+addressed the issue of whether §2255 is a civil or criminal statute for purposes of the
+constitutional prohibition against double jeopardy. The New York Court stated that
+"looking to the plain language of §2255(a), it is clear that the statutory intent was to
+provide a civil remedy. This is exemplified by the title ... and the fact that the statute
+aims to provide compensation to individuals who suffered personal injury as a result of
+criminal conduct against them." The New York Court in analyzing whether §2255
+violated the Constitutional prohibition against double jeopardy, concluded that although
+the behavior to which §2255 is criminal, it did not find that the "primary aim" was
+"retribution and deterrence." "The statute serves civil goals." The "primary aim" is "the
+compensation for personal injuries sustained as a result of criminal conduct."
+Therefore, because Jane Doe 103 has invoked the provisions of the criminal Non-
+Prosecution Agreement (NPA) between EPSTEIN and USAO (see paragraphs 25 and 26
+of complaint), plaintiff cannot avoid the full protection of the rule of lenity and due
+process to which EPSTEIN is entitled in the context of these unique factual
+circumstances.
+Although there does not exist any definitive ruling of whether the damages
+awarded under §2255 are meant as criminal punishment or a civil damages award,
+Defendant is still entitled to a determination as a matter of law that the statute in effect at
+the time of the alleged criminal conduct applies.
+As explained by the Landgraf court, supra at 280, and at 1505,?
+" In Landgraf, the United States Supreme Court affirmed the judgment of the Court of Appeals
+and refused to apply new provisions of the Civil Rights Act of 1991 to conduct occurring before
+the effective date of the Act. The Court determined that statutory text in question, §102, was
+subject to the presumption against statutory retroactivity.
+21
+
+
+When a case implicates a federal statute enacted after the events in suit, the court's
+first task is to determine whether Congress has expressly prescribed the statute's proper
+reach. If Congress has done so, of course, there is no need to resort to judicial default
+rules. When, however, the statute contains no such express command, the court must
+determine whether the new statute would have retroactive effect, i.e., whether it would
+impair rights a party possessed when he acted, increase a party's liability for past
+conduct, or impose new duties with respect to transactions already completed. If the
+statute would operate retroactively, our traditional presumption teaches that it does not
+govern absent clear congressional intent favoring such a result.
+Here, there is no clear expression of intent regarding the 2006 Act's application to
+conduct occurring well before its enactment. Clearly, however, as discussed in part B
+herein, the presumptive minimum amount of damages of $150,000 was enacted as a
+punishment or penalty upon those who sexually exploit and abuse minors. See discussion
+of House Bill Reports and Congressional background above herein. The amount triples
+the previous amount for which a defendant might be found liable, regardless of the
+amount of actual damages a plaintiff has suffered and proven. The new statute imposes a
+substantial increase in the monetary liability for past conduct.
+As stated in Landgraf, "the extent of a party's liability, in the civil context as well as
+the criminal, is an important legal consequence that cannot be ignored." Courts have
+consistently refused to apply a statute which substantially increases a party's liability to
+conduct occurring before the statute's enactment. Landgraf, supra at 284-85. Even if
+plaintiff were to argue that retroactive application of the new statute "would vindicate its
+purpose more fully," even that consideration is not enough to rebut the presumption
+against retroactivity. Id, at 285-86. "The presumption against statutory retroactivity is
+founded upon sound considerations of general policy and practice, and accords with long
+held and widely shared expectations about the usual operation of legislation." Id.
+Thus, Plaintiff's action should be dismissed and she should be required to plead her
+action under the applicable version of 18 U.S.C. §2255.
+22
+
+
+Motion For More Definite Statement and To Strike, Rule 12(e) and (f, F.R.C.P.
+As noted above, Plaintiff alleges that she was 17 year old high school student as
+of January, 2004, and that the alleged conduct involving EPSTEIN, occurred "between
+approximately January 2004 and May 2005. Thus, Plaintiff had to be 18 (no longer a
+minor) by January of 2005. Under the principles of statutory construction, the language
+of §2255(a) is clear - "Any minor who is a victim of a violation of section ...of this title
+and who suffers personal injury as a result of such violation may sue in any appropriate
+United States District Court and shall recover the actual damages such minor sustains
+and the cost of the suit, including a reasonable attorney's fee. Any minor as described in
+the preceding sentence shall be deemed to have sustained damages of no less than
+$50,000 in value."
+As Plaintiff's date of birth is significant to her §2255 claim, she should be
+required to more definitely state her date of birth so that Defendant and this Court are
+able to determine precisely when she reached the age of majority. (The age of majority
+under both federal and state law is 18 years old. See 18 U.S.C. §2256(1), defining a
+"minor" as "any person under the age of eighteen years;" and §1.01, Definitions, Fla.
+Stat., defining "minor" to include "any person who has not attained the age of 18 years.")
+In addition, when Plaintiff reached the age of majority may impact her ability to even
+assert a §2255 claim. See §2255(b).
+To the extent that Plaintiff is relying on any alleged conduct that occurred after
+her 18 birthday as an element of her §2255 claim, such allegations should be stricken as
+immaterial and she should be required to more definitely state the dates of the alleged
+conduct. See Rule 12(f). Defendant also seeks to strike 1910, 11, 12, 13, 14, 15, and 16,
+23
+
+
+-
+of Plaintiff's Complaint as immaterial and impertinent. None of the allegations in those
+paragraphs specifically pertain to the Plaintiff. Not until 917 does Plaintiff assert
+allegations pertaining to her and the conduct of Defendant directly involving her. What
+EPSTEIN may or may not have allegedly done with respect to other alleged girls does
+not effect Plaintiff's claim brought pursuant to §2255. The allegations in 9910-16 are not
+related to the elements of Plaintiff's §2255 claim and, thus, are required to be stricken.
+Conclusion
+Pursuant to the above, Plaintiff entire action is required to be dismissed. 18
+U.S.C. §2255 allows for a single recovery of the actual damages sustained in proven;
+neither the "actual damages" sustained not the statutory minimum is subject to
+duplication or multiplication on a per violation or per count or per incident basis. Also,
+the statute in effect during the time of the alleged conduct applies, not the version as
+amended, effective July 27, 2006. Count VI is also required to be dismissed as it relies
+on a statutory predicate act that did not take effect until 2006. In addition, Plaintiff
+should be required to more definitely state her date of birth, and any conduct occurring
+after her 18* birthday should be stricken, and 1910 - 16 of the Complaint should also be
+stricken.
+WHEREFORE, Defendant requests that this Court dismiss the entire action
+against him, and further grant his motion for more definite statement and to strike.
+Robert D. Critton, Esq.
+Attorney for Defendant
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is
+24
+
+
+being served this day on all counsel of record identified on the following Service List in
+the manner specified by CM/ECF on this.
+. day of
+, 2010.
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Counsel for Plaintiff
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Respectfully submitted,
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+VICHAEL J. PIKE, ESQ
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+18 USCA §2255 (1999-Julv 26, 2006):
+PART I--CRIMES
+CHAPTER 110-SEXUAL EXPLOITATION AND OTHER ABUSE OF
+CHILDREN
+§ 2255. Civil remedy for personal injuries
+(a) Any minor who is a victim of a violation of section 2241(c), 2242,
+2243, 2251, 2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title
+25
+
+
+and who suffers personal injury as a result of such violation may sue in
+any appropriate United States District Court and shall recover the actual
+damages such minor sustains and the cost of the suit, including a
+reasonable attorney's fee. Any minor as described in the preceding
+sentence shall be deemed to have sustained damages of no less than
+$50,000 in value.
+(b) Any action commenced under this section shall be barred unless the
+complaint is filed within six years after the right of action first accrues or
+in the case of a person under a legal disability, not later than three years
+after the disability.
+CREDIT(S)
+(Added Pub.L. 99-500, Title I, § 101(b) [Title VII, § 703(a)], Oct. 18,
+1986, 100 Stat. 1783-75, and amended Pub.L. 99-591, Title I, § 101(b)
+[Title VII, § 703(a)], Oct. 30, 1986, 100 Stat. 3341-75; Pub.L. 105-314,
+Title VI, § 605, Oct. 30, 1998, 112 Stat. 2984.)
+18 U.S.C. §2255, as amended 2006, Effective July 27, 2006:
+PART I--CRIMES
+CHAPTER 110-SEXUAL EXPLOITATION AND OTHER ABUSE OF
+CHILDREN
+§ 2255. Civil remedy for personal injuries
+(a) In general.--Any person who, while a minor, was a victim of a violation
+of section 2241(c), 2242, 2243, 2251, 2251A, 2252, 2252A, 2260, 2421,
+2422, or 2423 of this title and who suffers personal injury as a result of such
+violation, regardless of whether the injury occurred while such person was a
+ninor, may sue in any appropriate United States District Court and shall
+recover the actual damages such person sustains and the cost of the suit
+including a reasonable. attorney's fee. Any person as described in the
+than $150,000 in value.
+(b) Statute of limitations.-Any action commenced under this section shall
+be barred unless the complaint is filed within six years after the right of
+action first accrues or in the case of a person under a legal disability, not later
+than three years after the disability.
+CREDIT(S)
+(Added Pub.L. 99-500, Title I, § 101(b) [Title VII, § 703(a)], Oct. 18, 1986,
+100 Stat. 1783-75, and amended Pub. L. 99-591, Title I, § 101(b) [Title VII, §
+703(a))], Oct. 30, 1986, 100 Stat. 3341-75; Pub.L.. 105-314, Title VI. § 605,
+26
+
+
+Oct. 30, 1998, 112 Stat. 2984; Pub.I.. 109-248, Title VII, § 707(b), (c), July
+27, 2006, 120 Stat. 650.)
+2 Paragraphs 30, 34, 38, 43, 48, and 52 of Plaintiff's Complaint alleges:
+30. As a direct and proximate result of the offenses enumerated in 18 U.S.C. §2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the
+past suffered, and will in the future continue to suffer, physical injury, pain and
+suffering, emotional distress, psychological and/or psychiatric trauma, mental
+anguish, humiliation, confusion, embarrassment, loss of educational opportunities,
+loss of self-esteem, loss of dignity, invasion of her privacy, separation from her
+family, and other damages associated with Defendant manipulating and leading her
+into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
+and psychological expenses, and Plaintiff will in the future suffer additional medical
+and psychological expenses. Plaintiff has suffered a loss of income, a loss of the
+capacity to earn income in the future, and a loss of the capacity to enjoy life. These
+injuries are permanent in nature, and Plaintiff will continue to suffer these losses in
+The "Wherefore" clauses in each of the six counts are also identical -
+WHEREFORE Plaintiff demands judgment against Defendant for all damages
+available under 18 U.S.C. §2255, including, without limitation, actual and
+compensatory damages, attorney's fees, costs of suit, and such other relief this Court
+deems just and proper, and hereby demands trial by jury on all issues triable as of
+right by a jury.
+27
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/a374b1cd08457cdd94819c1bb1ee1f36998b41279f026d730b786b38599d7c6d.receipt.json b/vision-fixhub/ds9-unparsed-05/a374b1cd08457cdd94819c1bb1ee1f36998b41279f026d730b786b38599d7c6d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9a4a841e5b6408695a31fba8473c5581474a2451
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a374b1cd08457cdd94819c1bb1ee1f36998b41279f026d730b786b38599d7c6d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -8230,
+  "dataset": "marble-joined",
+  "doc_id": "a374b1cd08457cdd94819c1bb1ee1f36998b41279f026d730b786b38599d7c6d",
+  "engine": "marble-apple-vision",
+  "event_count": 155,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "6b0e135ddb4be6f7261562928f2035cbfc7e49706360ed1ae1babe592460e3a8",
+  "output_sha256": "70a32dbfdfeaa7edcb6c3b8674a42a89e65bedc24fad5766366800af340cbb0c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a3834ee2226ece031e9cfac27bc944e47ea5c067e8f67fc98857dde584dc4a34.md b/vision-fixhub/ds9-unparsed-05/a3834ee2226ece031e9cfac27bc944e47ea5c067e8f67fc98857dde584dc4a34.md
new file mode 100644
index 0000000000000000000000000000000000000000..8efb16476efb02d080da8cd19b866880b74dcf32
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a3834ee2226ece031e9cfac27bc944e47ea5c067e8f67fc98857dde584dc4a34.md
@@ -0,0 +1,6724 @@
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+IDENTIFIED VICTIM
+¡ NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+Ms. L
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your altorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+Ms. |
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. FI. Court File No. 08-80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+cC.
+
+
+500 South Australian Ave, Suite 400
+West Palm Beach, FI. 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 10, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave, Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 10, 2008
+VIA FACSIMILE AND U.S. MAIL
+Jeffrey Herman, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, Florida 33160
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+|: NOTIFICATION OF
+Dear Mr. Herman:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following notice to your client,
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+
+
+
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+had been tried federally and convicted of an enumerated offense. For purposes
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that your client,
+, is an individual whom the United States was prepared to name as a victim of an
+enumerated offense.
+Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you contact him at Alterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an
+enumerated offense, please provide written documentation of that denial to the undersigned.
+Please thank your client for all of her assistance during the course of this investigation
+and express the heartfelt regards of myself and Special Agents
+and
+for
+the health and well-being of Ms.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suite 400
+Vest Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 10, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 10, 2008
+VIA FACSIMILE AND U.S. MAIL
+Jeffrey Herman, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, Florida 33160
+Re:
+Jeffrey Epstein
+IDENTIFIED VICTIM
+I: NOTIFICATION OF
+Dear Mr. Herman:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following notice to your client,
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+
+
+JEFFREY HERMAN, EsQ.
+
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+had been tried federally and convicted of an enumerated offense. For purposes
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that your client,
+,, is an individual whom the United States was prepared to name as a victim of an
+enumerated offense.
+Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an
+enumerated offense, please provide written documentation of that denial to the undersigned.
+Please thank your client for all of her assistance during the course of this investigation
+and express the heartfelt regards of myself and Special Agents
+and
+for
+the health and well-being of Ms.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+VILLAFAÑA
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 10, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 10, 2008
+VIA FACSIMILE AND U.S. MAIL
+Jeffrey Herman, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, Florida 33160
+Re: Jeffrey Epstein/
+Garcia (née
+Dear Mr. Herman:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following notice to your client,
+Garcia.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+
+
+NOTIFICATION OF IDENTIFIED VictIm
+
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+had been tried federally and convicted of an enumerated offense. For purposes
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that your client,
+Garcia (née
+), is an individual whom the United States was prepared to name as a
+victim of an enumerated offense.
+Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an
+enumerated oflense, please provide written documentation of that denial to the undersigned.
+Please thank your client for all of her assistance during the course of this investigation
+and express the heartfelt regards of myself and Special Agents
+and
+for
+the health and well-being of Ms. Garcia.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+IZ,A.C., M.L., Y. L
+00 South Australian Ave., Suite 40
+Yest Palm Beach, FL 3340
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 10, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 10, 2008
+VIA FACSIMILE AND U.S. MAIL
+Jeffrey Herman, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, Florida 33160
+Re: Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Mr. Herman:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following notice to your client,
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+
+
+
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+had been tried federally and convicted of an enumerated offense. For purposes
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that your client,
+is an individual whom the United States was prepared to name as a victim of an enumerated
+offense.
+Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an
+enumerated offense, please provide written documentation of that denial to the undersigned.
+Please thank your client for all of her assistance during the course of this investigation
+and express the heartfelt regards of myself and Special Agents
+and
+for
+the health and well-being of Ms.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Abid illafara
+A.
+VILLAFANA
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 9, 2008
+VIA FACSIMILE
+Brad Edwards, Esq.
+The Law Offices of Brad Edwards & Associates, LLC
+2028
+Street, Suite 202
+Hollywood, Florida
+33020.
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+NOTIFICATION OF
+Dear Mr. Edwards:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following notice to your client,
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+
+
+NOTIFICATION OF IDENTIFIED VICTIM ma
+JULY 9,2008
+
+had been tried federally and convicted of an enumerated offense. For purposes
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that your client,
+,, is an individual whom the United States was prepared to name as a victim of an
+enumerated offense.
+Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an
+enumerated offense, please provide notice of that denial to the undersigned.
+Please thank your client for all of her assistance during the course of this examination
+and express the heartfelt regards of myself and Special Agents
+and
+for
+the health and well-being of Ms.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Alaw illafore
+_VILLAFAÑA
+
+
+500 South Australian Ave., Swite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 9, 2008
+VIA FACSIMILE
+Brad Edwards, Esq.
+The Law Offices of Brad Edwards & Associates, LLC
+2028
+Street, Suite 202
+Hollywood, Florida 33020.
+Re: Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Mr. Edwards:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following notice to your client,
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+
+
+JULY 9, 2008
+
+had been tried federally and convicted of an enumerated offense. For purposes
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that your client,
+is an individual whom the United States was prepared to name as a victim of an enumerated
+offense.
+Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an
+enumerated offense, please provide notice of that denial to the undersigned.
+Please thank your client for all of her assistance during the course of this examination
+and express the heartfelt regards of myself and Special Agents
+and
+for
+the health and well-being of Ms.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+IDENTIFIED VICTIM
+¡ NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Cabriellafana
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL. 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+6003ed by am said ya sentence a prone tale by wisement to br
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+1. An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+for your
+health and well-being.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+•and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+
+Goldberger, asks that you have your attorney contact Mr: Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+is lafare
+
+
+500 South Australian Ave, Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josetsberg elect to file a contested
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josetsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. FI. Court File No. 08-80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Mantillafara
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+CONNECTION
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josetsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+egarding the disclosure of the entire agreement between the United States and Mr. Epstein
+Ar. Josefsberg can provide further guidance on this issue, or if you select another attorne
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Manitelalane
+VILLAFAÑA
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+PROCEEDING:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+)09381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+ollowed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of theatre yo represent ose berg, as minteina you attor like am.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Joseisberg elect to ile a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Maid illafaria
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+)09381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+represend rive, dy, po oblig air stu pay ore tos bof thie attorney
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+• regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Alarie Villafara
+VILLAFANA
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL. 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+: AMENDED
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+1. . An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+
+
+MS. RHIANNON
+
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josetsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+As I stated in my carlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Abi Villafra
+
+
+- 500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+: AMENDED NOTIFICATION
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+
+
+
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney:
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Maurillafare
+
+
+500 South Australian Ave. Suite 400
+Yest Palm Beach, FL 3340
+561) 820-871
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+IDENTIFIED VICTIM
+AMENDED NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255; Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+AMENDED NOTIFICATION OF IDENTIfIED VICTIM
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. FI. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave, Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+: AMENDED
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+AMENDED NOTIFICATION OF IdenTIfIED VIctIM
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Alie Allafona
+
+
+500 South Australian Ave., Swite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+: AMENDED NOTIFICATION
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+
+
+
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. FI. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Albir Cellafara
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+: AMENDED NOTIFICATION
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+ferred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Section
+96.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage i
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+
+
+
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you clect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+00 South Australian Ave., Suite 40
+Yest Palm Beach, FL 3340
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Miss
+Re:
+Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+:AMENDED NOTIFICATION
+Dear Miss
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave, Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+: AMENDED
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Obie Allafaña
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+: AMENDED NOTIFICATION
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A.., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+AMENDED NOTIFICATION OF IDENTIFIED VicTIM
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suire 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+: AMENDED NOTIFICATION
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+AMENDED NOTIFICATION OF IdentifIED VICTIM
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suite 100
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+United States Allorney
+500 South Australian Ave., Stite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+: AMENDED
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. FI. Court File No. 08-80736-CIV-MARRA.
+Aș I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+ace ellatera
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 3, 2008
+VIA UNITED STATES MAIL
+Brad Edwards, Esq.
+2028
+Street, Suite 202
+Hollywood, Florida
+33020
+Re: Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+1: AMENDED NOTIFICATION
+Dear Mr: Edwards:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following amended notice to your client,
+Some of the information contained in the July 9, 2008 letter to Ms.
+was inaccurate, so
+please advise her of the following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims in connection with civil
+
+
+
+litigation between the victims and Mr. Epstein. The Special Master
+selected Robert Josefsberg, Esq. of the firm Podhurst Orseck, P.A., a
+is not obligated
+to use Mr. Josefsberg as her civil attorney, but, as explained in greater
+detail below, Mr. Josefsberg's services will be provided at no cost to
+because Mr. Epstein is obligated to pay the costs and fees of
+the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact Ms.
+[via Mr. Josefsberg, assuming that she would like
+Mr. Josefsberg to serve as her attorney.
+elects to file suit against Mr. Epstein pursuant to Title 18,
+United States Code, Section 2255, Mr. Epstein will not contest the
+jurisdiction of the United States District Court for the Southern District
+of Florida over his person and/or the subject matter, and Mr. Epstein
+waives his right to contest liability and also waives his right to contest
+damages up to an amount as agreed to between Ms.
+and Mr.
+Epstein, so long as Ms.
+elects to proceed exclusively under 18
+U.S.C. § 2255, and she waives any other claim for damages, whether
+pursuant to state, federal, or common law. Notwithstanding this
+waiver, Epstein's agreement with the United States, his waivers and
+failure to contest liability and such damages in any suit are not to be
+construed as an admission of any criminal or civil liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, Ms.
+and Mr. Josefsberg clect to file a
+contested lawsuit pursuant to 18 U.S.C. § 2255 or she elects to pursue
+any other contested remedy, the obligation to pay the costs of the
+attorney representative, as opposed to any statutory or other obligations
+to pay reasonable attorneys fees and costs such as those contained in
+Section 2255, shall cease.
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+
+
+AMENDED NOTIFICATION OF IDENTIFiED VICTIM I
+
+has selected other counsel to represent her, or if she does so in the future,
+and she decides to pursue a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+Goldberger, asks that he be contacted at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you and your client for all of her assistance during the
+course of this investigation.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Aleistillafara
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 3, 2008
+VIA COURIER
+Re: Jeffrey
+IDENTIFIED VICTIM
+NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Please contact either myself at
+or Justice
+Department Victim- Witness Specialist
+at
+with a good
+telephone number and/or e-mail address, so that we may provide Mr. Josefsberg with a
+timely means of communicating with you. If you would like to contact Mr. Josefsberg
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, United States District Court for the Southern District of Florida Court File No. 08-
+80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation. Thank you for all of your
+assistance during the course of the federal and state investigations and please accept the
+heartfelt regards of myself and Special Agents
+, and
+for your
+health and well-being.
+Sincerely,
+R. Alexander Acosta
+By:
+Assistant United States Attorney
+CC.
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 3, 2008
+VIA UNITED STATES MAIL
+Brad Edwards, Esq.
+2028
+Street, Suite 202
+Hollywood, Florida 33020
+Re: Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+1: AMENDED NOTIFICATION
+Dear Mr. Edwards:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following amended notice to your client.
+Some of the information contained in the July 9, 2008 letter to Ms.
+was inaccurate,
+so please advise her of the following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims in connection with civil
+
+
+BRAD EDWARDS, ESQ
+
+litigation between the victims and Mr. Epstein. The Special Master
+selected Robert Josefsberg, Esq. of the firm Podhurst Orseck, P.A., a
+is not obligated
+to use Mr. Josetsberg as her civil attorney, but, as explained in greater
+detail below, Mr. Josefsberg's services will be provided at no cost to
+because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact Ms.
+via Mr. Josefsberg, assuming that she would
+like Mr. Josefsberg to serve as her attorney.
+elects to file suit against Mr. Epstein pursuant to Title 18,
+United States Code, Section 2255, Mr. Epstein will not contest the
+jurisdiction of the United States District Court for the Southern District
+of Florida over his person and/or the subject matter, and Mr. Epstein
+waives his right to contest liability and also waives his right to contest
+damages up to an amount as agreed to between Ms.
+and Mr.
+Epstein, so long as Ms.
+elects to proceed exclusively under 18
+U.S.C. § 2255, and she waives any other claim for damages, whether
+pursuant to state, federal, or common law. Notwithstanding this
+waiver, Epstein's agreement with the United States, his waivers and
+failure to contest liability and such damages in any suit are not to be
+construed as an admission of any criminal or civil liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party, This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, Ms. |
+and Mr. Josefsberg elect to file a
+contested lawsuit pursuant to 18 U.S.C. § 2255 or she elects to pursue
+any other contested remedy, the obligation to pay the costs of the
+attorney representative, as opposed to any statutory or other obligations
+to pay reasonable attorneys fees and costs such as those contained in
+Section 2255, shall cease.
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+
+
+
+has selected other counsel to represent her, or if she does so in the
+future, and she decides to pursue a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+Goldberger, asks that he be contacted at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you and your client for all of her assistance during the
+course of this investigation.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Mire Villafaro
+
+
+COPY
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LA W,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+CONNECTION
+WITH A
+DUPLICATES
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+VIA UNITED STATES MAIL.
+Miss
+Re: Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Miss
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+had been tried federally and convicted of an enumerated offense. For purposes
+
+
+
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that you,
+, are
+an individual whom the United States was prepared to name as a victim of an enumerated
+offense.
+Should you decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that you are a victim of an enumerated
+offense, please provide written documentation of that denial to the undersigned.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+ClarieVillafara
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL. 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+VIA UNITED STATES MAIL
+Miss
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Miss
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+had been tried federally and convicted of an enumerated offense. For purposes
+
+
+NOTIFICATION OF IDEnTIfIED VICTIM
+
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that you,
+are an individual whom the United States was prepared to name as a victim of an enumerated
+offense.
+Should you decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you have your attorney contact Jack Goldberger at Atterbury
+Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL
+33401, (561) 659-8300.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that you are a victim of an enumerated
+offense, please provide written documentation of that denial to the undersigned.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being, and best wishes for continued success with your studies.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave, Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+CONNECTION
+
+
+500 South Australian Ave. Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+VIA UNITED STATES MAIL
+Miss
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Miss
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+09381AXXXMB) and was sentenced to a term of twelve months' imprisonment to b
+ollowed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+had been tried federally and convicted of an enumerated offense. For purposes
+
+
+
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that you,
+, are an
+individual whom the United States was prepared to name as a victim of an enumerated
+offense.
+Should you decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL. 33401, (561)
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that you are a victim of an enumerated
+offense, please provide written documentation of that denial to the undersigned.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(56]) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+VIA UNITED STATES MAIL
+1
+Re: Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+: NOTIFICATION
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+had been tried federally and convicted of an enumerated offense. For purposes
+
+
+
+of'implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that you,
+, are an individual whom the United States was prepared to name as a victim of
+an enumerated offense.
+Should you decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that you are a victim of an enumerated
+offense, please provide written documentation of that denial to the undersigned.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+A.
+VILLARANA
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+09381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+ollowed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+
+
+NOTIFICATION OF IDENTIfIED VIcTIM
+
+had been tried federally and convicted of an enumerated offense. For purposes
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that you,
+,, are
+an individual whom the United States was prepared to name as a victim of an enumerated
+offense.
+Should you decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, it you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that you are a victim of an enumerated
+offense, please provide written documentation of that denial to the undersigned.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Audillafina
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+•
+July 21, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+IDENTIFIED VICTIM
+1: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cfobved y an adional sie month imprison, beloved by are mento be
+ollowed by an additional six months' 1l
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+had been tried federally and convicted of an enumerated offense. For purposes
+
+
+
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that you,
+, are
+an individual whom the United States was prepared to name as a victim of an enumerated
+offense.
+Should you decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that you are a victim of an enumerated
+offense, please provide written documentation of that denial to the undersigned.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+• R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+A.
+VILLAFAÑA
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave, Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cfobowed by an additional sic month o imprim men, beloved by neive mont to bl
+llowed by an additional six months" ir
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+had been tried federally and convicted of an enumerated offense. For purposes
+
+
+
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that you,
+,, are
+an individual whom the United States was prepared to name as a victim of an enumerated
+offense.
+Should you decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+• and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that you are a victim of an enumerated
+offense, please provide written documentation of that denial to the undersigned.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Alave Villafaro
+
+
+500 South Australian Ave. Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein
+IDENTIFIED VICTIM
+1: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+had been tried federally and convicted of an enumerated offense. For purposes
+
+
+NOTIFICATION OF IdEnTIfIED VICTIM
+
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that you,
+, are
+an individual whom the United States was prepared to name as a victim of an enumerated
+offense.
+Should you decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you have your attorney contact Jack Goldberger at Atterbury
+Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL
+33401, (561) 659-8300.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that you are a victim of an enumerated
+offense, please provide written documentation of that denial to the undersigned.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being, and best wishes for continued success with your studies.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Place Villafara
+
+
+United States Allorney
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+•
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+o owed Xy am idional sik mored to a prisoner, led by face mant to
+ollowed by an additional six months' it
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+had been tried federally and convicted of an enumerated offense. For purposes
+
+
+
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that you,
+, are an
+individual whom the United States was prepared to name as a victim of an enumerated
+offense.
+Should you decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that you are a victim of an enumerated
+offense, please provide written documentation of that denial to the undersigned.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+and Allafara
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+had been tried federally and convicted of an enumerated offense. For purposes
+
+
+
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that you,
+, are an
+individual whom the United States was prepared to name as a victim of an enumerated
+offense.
+Should you decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL. 33401, (561)
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that you are a victim of an enumerated
+offense, please provide written documentation of that denial to the undersigned.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Swite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 21, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+109381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+numerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+had been tried federally and convicted of an enumerated offense. For purposes
+
+
+NOTIFICATION OF IDENTIFIED VicTIM
+
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that you,
+are an individual whom the United States was prepared to name as a victim of an enumerated
+offense.
+Should you decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that you are a victim of an enumerated
+offense, please provide written documentation of that denial to the undersigned.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Abualillafara
+
+
+August 4, 2006
+August 1, 2006 (2 side)
+March 15, 2007
+2. side
+Sue 1, 2007
+2 side
+1.10,2008
+July 21, 2008
+Dept 2, 2008
+Sept 3
+2008
+Aest 12, 2008
+sept 15, 2008
+Nov. 14
+, 2008
+Dee 8, 2008
+Dee 9, 2008
+Dec 12, 7008
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Miss
+Re:
+Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+AMENDED NOTIFICATION
+Dear Miss
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (telony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+
+ri
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+clect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+MIsS
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. FI. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+: AMENDED
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. FI. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Cobie Allafaña
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Richard H. Willits, P.A.
+2290 10th Avenue North, Suite 404
+Lake Worth, FL 33461
+Re: Jeffrey Epstein/
+: AMENDED
+Dear Mr. Willits:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following amended notice to your client,
+Some of the information contained in the July 10, 2008 letter to Ms.
+was inaccurate, so please advise her of the following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinatter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims in connection with civil
+litigation between the victims and Mr. Epstein. The Special Master
+
+
+RICHARD H. WILLITS, ESQ.
+
+selected Robert Josefsberg, Esq. of the firm Podhurst Orsec, Pis not
+obligated to use Mr. Josefsberg as her civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+because Mr. Epstein is obligated to pay the costs
+and fees of the attorney-representative. Also, Mr. Epstein and his
+attorneys can only contact Ms.
+via Mr. Josefsberg, assuming
+that she would like Mr. Jpsefsberg to serve as her attorney.
+elects to file suit against Mr. Epstein pursuant to Title
+18, United States Code, Section 2255, Mr. Epstein will not contest the
+jurisdiction of the United States District Court for the Southern District
+of Florida over his person and/or the subject matter, and Mr. Epstein
+waives his right to contest liability and also waives his right to contest
+damages up to an amount as agreed to between Ms.
+and Mr.
+Epstein, so long as Ms.
+elects to proceed exclusively under
+18 U.S.C. § 2255, and she waives any other claim for damages, whether
+pursuant to state; federal, or common law. Notwithstanding this
+waiver, Epstein's agreement with the United States, his waivers and
+failure to contest liability and such damages in any suit are not to be
+construed as an admission of any criminal or civil liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, Ms. L
+and Mr. Josefsberg elect to file a
+contested lawsuit pursuant to 18 U.S.C. § 2255 or she elects to pursue
+any other contested remedy, the obligation to pay the costs of the
+attorney representative, as opposed to any statutory or other obligations
+to pay reasonable attorneys fees and costs such as those contained in
+Section 2255, shall cease.
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+
+
+RICHARD H. WILLITS, ESQ.
+
+has selected other counsel to represent her, or if she does so in the
+future, and she decides to pursue a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+Goldberger, asks that he be contacted at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States anciects another
+Mr. Josefsberg can provide further guidance on this issue, or if Ms.
+attorney to represent her, that attorney can review the Court's order in the matter of In re
+Jane Does 1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you and your client for all of her assistance during the
+course of this investigation.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+AMane Villafone
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Ms. Britany
+Re:
+Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+: AMENDED NOTIFICATION
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (telony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 1 5th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL. 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIl
+Re:
+Jeffrey Epstein/
+: AMENDED
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to. pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+MS. I
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Maio ellafara
+
+
+500 South Australian Ave., Stite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Jeffrey Herman, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Blvd., Ste 2218
+Miami, FL 33160
+Re:
+Jeffrey Epstein/
+: AMENDED
+Dear Mr. Herman:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following amended notice to your client,
+• Some of the information contained in the July 10, 2008 letter to Ms.
+was inaccurate, so please advise her of the following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinatter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims in connection with civil
+
+
+
+litigation between the victims and Mr. Epstein. The Special Master
+sighted spect and experience of atriry. thurs Ock, Pis not
+obligated to use Mr. Josefsberg as her civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to Ms.
+_ because Mr. Epstein is obligated to pay the costs
+and fees of the attorney-representative. Also, Mr. Epstein and hi
+attorneys can only contact Ms.
+via Mr. Josefsberg, assuming
+that she would like Mr. Josefsberg to serve as her attorney.
+elects to file suit against Mr. Epstein pursuant to Title
+18, United States Code, Section 2255, Mr. Epstein will not contest the
+jurisdiction of the United States District Court for the Southern District
+of Florida over his person and/or the subject matter, and Mr. Epstein
+waives his right to contest liability and also waives his right to contest
+damages up to an amount as agreed to between Ms.
+and Mr.
+Epstein, so long as Ms.
+elects to proceed exclusively under
+18 U.S.C. §2255, and she waives any other claim for damages, whether
+pursuant to state, federal, or common law. Notwithstanding this
+waiver, Epstein's agreement with the United States, his waivers and
+failure to contest liability and such damages in any suit are not to be
+construed as an admission of any criminal or civil liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, Ms. L
+and Mr. Josefsberg elect to file a
+contested lawsuit pursuant to 18 U.S.C. § 2255 or she elects to pursue
+any other contested remedy, the obligation to pay the costs of the
+attorney representative, as opposed to any statutory or other obligations
+to pay reasonable attorneys fees and costs such as those contained in
+Section 2255, shall cease.
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+
+
+AMENDED NOTIFICATION OF IDENTIFIED VICTIM L
+
+has selected other counsel to represent her, or if she does so in the
+future, and she decides to pursue a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+Goldberger, asks that he be contacted at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if Ms.
+selects another
+attorney to represent her, that attorney can review the Court's order in the matter of In re
+Jane Does 1 and 2, S.D. FI. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you and your client for all of her assistance during the
+course of this investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL. 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+: AMENDED NOTIFICATION
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage it
+rostitution), in the 1 5th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+MS.|
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. FI. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Ms. Ashley
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cftowed Xy am slaida sie moned to apronment, beloved by niement to bee
+followed by an additional six months' i
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+deter federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+NOTIFICATION OF IDEnTIfIED VICTIM
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (56J) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hercinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cot eaten because i prei so i, Eep to pay the ots and res
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+
+Goldberger, asks that you have your attorney contact Mr. Goldbergerat Alterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+bilallafara
+VILLAFAÑA
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein
+OF IDENTIFIED VICTIM
+: AMENDED NOTIFICATION
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+eterred 1o as
+1% au west in) cited advisa d on lu to 3uolations oforida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+
+
+
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Mail ellafara
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/l
+IDENTIFIED VICTIM
+NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+09A y an alidal sie month to imprisonment ve moved by yeive mento bov
+ollowed by an additional six months' i
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+oste you because entire is Mi. led to pay the osts and ce.
+f the attornev-representative. Also..
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL. 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Abillafere
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-877
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) ANDFLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Theodore J. Leopold, Esq.
+Ricci-Leopold, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Re:
+Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+1: AMENDED NOTIFICATION
+Dear Mr. Leopold:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following amended notice to your client,
+Some of the information contained in the July 10, 2008 letter to Ms.
+was
+inaccurate, so please advise her of the following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims in connection with civil
+
+
+THEODORE J. LEOPOLD, ESQ.
+
+litigation between the victims and Mr. Epstein. The Special Master
+selected Robert Josefsberg, Esq. of the firm Podhurst Orseck, P.A., a
+is not
+obligated to use Mr. Josefsberg as her civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to Ms.
+because Mr. Epstein is obligated to pay the costs
+and fees of the attorney-representative. Also, Mr. Epstein and his
+attorneys can only contact Ms.
+via Mr. Josefsberg, assuming
+that she would like Mr. Josefsberg to serve as her attorney.
+elects to file suit against Mr. Epstein pursuant to Title
+18, United States Code, Section 2255, Mr. Epstein will not contest the
+jurisdiction of the United States District Court for the Southern District
+of Florida over his person and/or the subject matter, and Mr. Epstein
+waives his right to contest liability and also waives his right to contest
+damages up to an amount as agreed to between Ms.
+and Mr.
+Epstein, so long as Ms.
+elects to proceed exclusively under
+18 U.S.C. § 2255, and she waives any other claim for damages, whether
+pursuant to state, federal, or common law. Notwithstanding this
+waiver, Epstein's agreement with the United States, his waivers and
+failure to contest liability and such damages in any suit are not to be
+construed as an admission of any criminal or civil liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, Ms.
+and Mr. Josefsberg elect to file a
+contested lawsuit pursuant to 18 U.S.C. § 2255 or she elects to pursue
+any other contested remedy, the obligation to pay the costs of the
+attorney representative, as opposed to any statutory or other obligations
+to pay reasonable attorneys fees and costs such as those contained in
+Section 2255, shall cease.
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+
+
+THEODORE J. LEOPOLD, ESQ.
+
+has selected other counsel to represent her, or if she does so in the
+future, and she decides to pursue a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+Goldberger, asks that he be contacted at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if Ms.
+selects another
+attorney to represent her, that attorney can review the Court's order in the matter of In re
+Jane Does 1 and 2, S.D. FI. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you and your client for all of her assistance during the
+course of this investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008.
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+I WITH A LEGAL
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+:: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 790.07 (telony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+ETA00183266
+
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+AMENDED NOTIFICATION
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+referred to as
+A to au were previously advisa gnity to iolations offlorida statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+
+
+
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. FI. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+Albie allafara
+VILLAFAÑA
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+: AMENDED
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court:
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+1. An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Urseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Burcau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Marie lafina
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL. 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+NOTIFICATION OF IdentifiED VictIm
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+Southern Districi of Florida
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2; 2008
+VIA UNITED STATES MAIL
+Jeffrey Herman, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Blvd., Ste 2218
+Miami, FL 33160
+Re:
+Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+: AMENDED NOTIFICATION
+Dear Mr. Herman:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following amended notice to your client.
+Some of the information contained in the July 10, 2008 letter to Ms.
+was inaccurate,
+so please advise her of the following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims in connection with civil
+
+
+JEFFREY HERMAN, ESQ
+AMENDED NOTIFICATION OF IDENTIFIED VICTIM P
+
+litigation between the victims and Mr. Epstein. The Special Master
+selected Robert Josefsberg, Esq. of the firm Podhurst Orseck, P.A., a
+is not obligated
+to use Mr. Josefsberg as her civil attorney, but, as explained in greater
+detail below, Mr. Josefsberg's services will be provided at no cost to
+because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact Ms.
+via Mr. Josefsberg, assuming that she would
+like Mr. Josefsberg to serve as her attorney.
+elects to file suit against Mr. Epstein pursuant to Title 18,
+United States Code, Section 2255, Mr. Epstein will not contest the
+jurisdiction of the United States District Court for the Southern District
+of Florida over his person and/or the subject matter, and Mr. Epstein
+waives his right to contest liability and also waives his right to contest
+damages up to an amount as agreed to between Ms.
+and Mr.
+Epstein, so long as Ms.
+elects to proceed exclusively under 18
+U.S.C. § 2255, and she waives any other claim for damages, whether
+pursuant to state, federal, or common law. Notwithstanding this
+waiver, Epstein's agreement with the United States, his waivers and
+failure to contest liability and such damages in any suit are not to be
+construed as an admission of any criminal or civil liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, Ms.
+and Mr. Josefsberg elect to file a
+contested lawsuit pursuant to 18 U.S.C. § 2255 or she elects to pursue
+any other contested remedy, the obligation to pay the costs of the
+attorney representative, as opposed to any statutory or other obligations
+to pay reasonable attorneys fees and costs such as those contained in
+Section 2255, shall cease.
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+
+
+AMENDED NOTIFICATION OF IDENTIFIED VICTIM _
+
+has selected other counsel to represent her, or if she does so in the
+future, and she decides to pursue a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+Goldberger, asks that he be contacted at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if Ms.
+selects another
+attorney to represent her, that attorney can review the Court's order in the matter of In re
+Jane Does 1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you and your client for all of her assistance during the
+course of this investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Jeffrey Herman, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Blvd., Ste 2218
+Miami, FL 33160
+Re:
+Jeffrey Epstein
+OF IDENTIFIED VICTIM
+I: AMENDED NOTIFICATION
+Dear Mr. Herman:
+of Florida asks that you provide the following amended notice to your client.
+By vittue of this icter, the United States Attorney's Office for the Southern Pistig.
+Some of the information contained in the July 10, 2008 letter to Ms.
+• was inaccurate,
+so please advise her of the following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinatter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims in connection with civil
+
+
+
+litigation between the victims and Mr. Epstein. The Special Master
+selected Robert Josefsberg, Esq. of the firm Podhurst Orseck, P.A., a
+is not obligated
+to use Mr. Josefsberg as her civil attorney, but, as explained in greater
+detail below, Mr. Josefsberg's services will be provided at no cost to
+because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact Ms.
+via Mr. Josefsberg, assuming that she would
+like Mr. Josefsberg to serve as her attorney.
+elects to file suit against Mr. Epstein pursuant to Title 18,
+United States Code, Section 2255, Mr. Epstein will not contest the
+jurisdiction of the United States District Court for the Southern District
+of Florida over his person and/or the subject matter, and Mr. Epstein
+waives his right to contest liability and also waives his right to contest
+damages up to an amount as agreed to between Ms.
+and Mr.
+Epstein, so long as Ms.
+elects to proceed exclusively under 18
+U.S.C. § 2255, and she waives any other claim for damages, whether
+pursuant to state, federal, or common law. Notwithstanding this
+waiver, Epstein's agreement with the United States, his waivers and
+failure to contest liability and such damages in any suit are not to be
+construed as an admission of any criminal or civil liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, Ms.
+and Mr. Josefsberg elect to file a
+contested lawsuit pursuant to 18 U.S.C. § 2255 or she elects to pursue
+any other contested remedy, the obligation to pay the costs of the
+altorney representative, as opposed to any statutory or other obligations
+to pay reasonable attorneys fees and costs such as those contained in
+Section 2255, shall cease..
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+
+
+AMENDED NOTIFICATION OF IDENTIFIED VICTIM_
+
+has selected other counsel to represent her, or if she does so in the
+future, and she decides to pursue a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+Goldberger, asks that he be contacted at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if Ms.
+selects another
+attorney to represent her, that attorney can review the Court's order in the matter of In re
+Jane Does 1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you and your client for all of her assistance during the
+course of this investigation.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Mbitillafara
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Stite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+: AMENDED NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+1. An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+MS.|
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Manillafara
+
+
+500 South Australian Ave. Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+PROCEEDING:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at n‹
+ost to you because Mr. Epstein is obligated to pay the costs and fee
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+represend tve dy, prosebigain to pay or toss of the alto pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+NOTIFICATION Of IDenTIfIeD VICTIM
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. FI. Court File No. 08-80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+04 Last South Stree
+)rlando, EL 32801
+Re:
+Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+: AMENDED NOTIFICATION
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinatter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+
+
+
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+Ms. I
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+As I stated in. my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+ME NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+Ms. HAIL
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+• If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+• regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Clair Villafara
+A.
+VILLAFAÑA
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Michael E. Dutko, Esq.
+Bogenschutz & Dutko
+600 S. Andrews Ave, Suite 500
+Fort Lauderdale, FL 33301-2802
+Re:
+Jeffrey Epstein
+OF IDENTIFIED VICTIM
+: AMENDED NOTIFICATION
+Dear Mr. Dutko:
+By virtue of this letter, the United States Attorney's Office for the Southerp District
+of Florida asks that you provide the following amended notice to your client,
+Some of the information contained in the July 10, 2008 letter to Ms.
+was inaccurate,
+so please advise her of the following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims in connection with civil
+
+
+MICHAEL E. DUTKO, ESQ.
+AMENDED NOTIFICATION OF IDENTIFIED VICTIM I
+
+litigation between the victims and Mr. Epstein. The Special Master
+selected Robert Josefsberg, Esq. of the firm Podhurst Orseck, P.A., a
+is not
+obligated to use Mr. Josefsberg as her civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+because Mr. Epstein is obligated to pay the costs
+and fees of the attorney-representative. Also, Mr. Epstein and his
+attorneys can only contact Ms.
+]via Mr. Josefsberg, assuming
+that she would like Mr. Josefsberg to serve as her attorney.
+elects to file suit against Mr. Epstein pursuant to Title
+18, United States Code, Section 2255, Mr. Epstein will not contest the
+jurisdiction of the United States District Court for the Southern District
+of Florida over his person and/or the subject matter, and Mr. Epstein
+waives his right to contest liability and also waives his right to contest
+damages up to an amount as agreed to between Ms.
+and Mr.
+Epstein, so long as Ms.
+elects to proceed exclusively under 18
+U.S.C. § 2255, and she waives any other claim for damages, whether
+pursuant to state, federal, or common law. Notwithstanding this
+waiver, Epstein's agreement with the United States, his waivers and
+failure to contest liability and such damages in any suit are not to be
+construed as an admission of any criminal or civil liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, Ms.
+and Mr. Josefsberg elect to file a
+contested lawsuit pursuant to 18 U.S.C. § 2255 or she elects to pursue
+any other contested remedy, the obligation to pay the costs of the
+attorney representative, as opposed to any statutory or other obligations
+to pay reasonable attorneys fees and costs such as those contained in
+Section 2255, shall cease.
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+
+
+MICHAEL E. DUTKO, EsQ.
+
+has selected other counsel to represent her, or if she does so in the
+future, and she decides to pursue a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that he be contacted at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if Ms.
+selects another
+attorney to represent her, that attorney can review the Court's order in the matter of In re
+Jane Does 1 and 2, S.D. FI. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you and your client for all of her assistance during the
+course of this investigation.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+artillafare
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+600 Evelyn Court
+West Palm Beach, EL
+Re: Jeffrey Epstein/
+: AMENDED
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+45 you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+
+
+
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Abir Villalan
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 2, 2008
+VIA UNITED STATES MAIL
+Jeffrey Herman, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Blvd., Ste 2218
+Miami, FL 33160
+Re:
+Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+: AMENDED NOTIFICATION
+Dear Mr. Herman:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following amended notice to your client,
+Some of the information contained in the July 10, 2008 letter to Ms.
+was inaccurate, so
+please advise her of the following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinatter
+reterred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims in connection with civil
+
+
+JEFFREY HERMAN, EsQ.
+
+litigation between the victims and Mr. Epstein. The Special Master
+selected Robert Josefsberg, Esq. of the firm Podhurst Orseck, P.A., a
+is not obligated
+to use Mr. Josefsberg as her civil attorney, but, as explained in greater
+detail below, Mr. Josefsberg's services will be provided at no cost to
+because Mr. Epstein is obligated to pay the costs and fees of
+the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact Ms.|
+via Mr. Josefsberg, assuming that she would like
+Mr. Josefsberg to serve as her attorney.
+elects to file suit against Mr. Epstein pursuant to Title 18,
+United States Code, Section 2255, Mr. Epstein will not contest the
+jurisdiction of the United States District Court for the Southern District
+of Florida over his person and/or the subject matter, and Mr. Epstein
+waives his right to contest liability and also waives his right to contest
+damages up to an amount as agreed to between Ms.
+and Mr.
+Epstein, so long as Ms.
+elects to proceed exclusively under 18
+U.S.C. § 2255, and she waives any other claim for damages, whether
+pursuant to state, federal, or common law. Notwithstanding this
+waiver, Epstein's agreement with the United States, his waivers and
+failure to contest liability and such damages in any suit are not to be
+construed as an admission of any criminal or civil liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, Ms.
+and Mr. Josefsberg elect to file a
+contested lawsuit pursuant to 18 U.S.C. § 2255 or she elects to pursue
+any other contested remedy, the obligation to pay the costs of the
+attorney representative, as opposed to any statutory or other obligations
+to pay reasonable attorneys fees and costs such as those contained in
+Section 2255, shall cease.
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+
+
+
+has selected other counsel to represent her, or if she does so in the future,
+and she decides to pursue a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+Goldberger, asks that he be contacted at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if Ms.
+selects another
+attorney to represent her, that attorney can review the Court's order in the matter of In re
+Jane Does 1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you and your client for all of her assistance during the
+course of this investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 3, 2008
+VIA COURIER
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+I NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Please contact either myself at
+or Justice
+Department Victim- Witness Specialist
+telephone number and or e-mail address, so that we may provide Mr. Jose berg with a
+timely means of communicating with you. If you would like to contact Mr. Josefsberg
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, United States District Court for the Southern District of Florida Court File No. 08-
+80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation. Thank you for all of your
+assistance during the course of the federal and state investigations and please accept the
+heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+By:
+Sincerely,
+R. Alexander Acosta
+Mare Allafora
+Villafaña
+Assistant United States Attorney
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 3, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 3, 2008
+VIA UNITED STATES MAIL
+Brad Edwards, Esq.
+2028
+Street, Suite 202
+Hollywood, Florida
+33020
+Re:
+Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+: AMENDED NOTIFICATION
+Dear Mr. Edwards:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following amended notice to your client.
+Some of the information contained in the July 9, 2008 letter to Ms.
+was inaccurate,
+so please advise her of the following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims in connection with civil
+
+
+
+litigation between the victims and Mr. Epstein. The Special Master
+selected Robert Josefsberg, Esq. of the firm Podhurst Orseck, P.A., a
+is not obligated
+to use Mr. Josefsberg as her civil attorney, but, as explained in greater
+detail below, Mr. Josefsberg's services will be provided at no cost to
+because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact Ms.
+| via Mr. Josefsberg, assuming that she would
+like Mr. Josefsberg to serve as her attorney.
+IfMs.
+elects to file suit against Mr. Epstein pursuant to Title 18,
+United States Code, Section 2255, Mr. Epstein will not contest the
+jurisdiction of the United States District Court for the Southern District
+of Florida over his person and/or the subject matter, and Mr. Epstein
+waives his right to contest liability and also waives his right to contest
+damages up to an amount as agreed to between Ms.
+and Mr.
+Epstein, so long as Ms.
+elects to proceed exclusively under 18
+U.S.C. § 2255, and she waives any other claim for damages, whether
+pursuant to state, federal, or common law. Notwithstanding this
+waiver, Epstein's agreement with the United States, his waivers and
+failure to contest liability and such damages in any suit are not to be
+construed as an admission of any criminal or civil liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, Ms.
+and Mr. Josefsberg elect to file a
+contested lawsuit pursuant to 18 U.S.C. § 2255 or she elects to pursue
+any other contested remedy, the obligation to pay the costs of the
+attorney representative, as opposed to any statutory or other obligations
+to pay reasonable attorneys fees and costs such as those contained in
+Section 2255, shall cease.
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+
+
+
+has selected other counsel to represent her, or if she does so in the
+future, and she decides to pursue a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+Goldberger, asks that he be contacted at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assis
+n civil litigation, but we again thank you and your client for all of her assistance during th
+course of this investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY-
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 3, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 3, 2008
+VIA COURIER
+Re: Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Please contact either myself at
+or Justice
+Department Victim-Witness Specialist
+at
+telephone number and/or e-mail address, so that we may provide Mr. Josefsberg with a
+timely means of communicating with you. If you would like to contact Mr. Josefsberg
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, United States District Court for the Southern District of Florida Court File No. 08-
+80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation. Thank you for all of your
+assistance during the course of the federal and state investigations and please accept the
+heartfelt regards of myself and Special Agents
+, and
+for your
+health and well-being.
+By:
+Sincerely,
+R. Alexander Acosta
+Marie illafara
+Assistant United States Attorney
+
+
+500 South Australian Ave., Swite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 3, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 3, 2008
+VIA COURIER
+Re: Jeffrey
+IDENTIFIED VICTIM
+7: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit ir
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+Please contact either myself at
+or Justice
+Department Victim-Witness Specialist
+with a good
+telephone number and/or e-mail address, so that we may provide Mr. Josefsberg with a
+timely means of communicating with you. If you would like to contact Mr. Josefsberg
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, United States District Court for the Southern District of Florida Court File No. 08-
+80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation. Thank you for all of your
+assistance during the course of the federal and state investigations and please accept the
+heartfelt regards of myself and Special Agents
+, and
+for your
+health and well-being.
+Sincerely,
+R. Alexander Acosta
+By:
+Assistant United States Attorney
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 3, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 3, 2008
+VIA UNITED STATES MAIL
+Brad Edwards, Esq.
+2028
+Street, Suite 202
+Hollywood, Florida
+33020
+Re:
+Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+AMENDED NOTIFICATION
+Dear Mr. Edwards:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following amended notice to your client,
+Some of the information contained in the July 9, 2008 letter to Ms.
+was inaccurate, so
+please advise her of the following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims in connection with civil
+
+
+
+litigation between the victims and Mr. Epstein. The Special Master
+selected Robert Josefsberg, Esq. of the firm Podhurst Orseck, P.A., a
+is not obligated
+to use Mr. Josefsberg as her civil attorney, but, as explained in greater
+detail below, Mr. Josefsberg's services will be provided at no cost to
+because Mr. Epstein is obligated to pay the costs and fees of
+the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact Ms.
+via Mr. Josefsberg, assuming that she would like
+Mr. Josefsberg to serve as her attorney.
+elects to file suit against Mr. Epstein pursuant to Title 18,
+United States Code, Section 2255, Mr. Epstein will not contest the
+jurisdiction of the United States District Court for the Southern District
+of Florida over his person and/or the subject matter, and Mr. Epstein
+waives his right to contest liability and also waives his right to contest
+damages up to an amount as agreed to between Ms.
+and Mr.
+Epstein, so long as Ms.
+elects to proceed exclusively under 18
+U.S.C. § 2255, and she waives any other claim for damages, whether
+pursuant to state, federal, or common law. Notwithstanding this
+waiver, Epstein's agreement with the United States, his waivers and
+failure to contest liability and such damages in any suit are not to be
+construed as an admission of any criminal or civil liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, Ms.
+and Mr. Josefsberg elect to file a
+contested lawsuit pursuant to 18 U.S.C. § 2255 or she elects to pursue
+any other contested remedy, the obligation to pay the costs of the
+attorney representative, as opposed to any statutory or other obligations
+to pay reasonable attorneys fees and costs such as those contained in
+Section 2255, shall cease.
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+
+
+
+has selected other counsel to represent her, or if she does so in the future,
+and she decides to pursue a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+Goldberger, asks that he be contacted at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you and your client for all of her assistance during the
+course of this investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 12, 2008
+alectron
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-ct-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+
+
+SEPTEMBER 12, 2008
+
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+
+
+SEPTEMBER 12, 2008
+
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josetsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+for your
+health and well-being.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Man lafana
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 15, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cfowed X am alid as sentenced to perm of eye velvets imprisonment to bu
+ollowed by an additional six months' i
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fee
+of the attorney-representative. Also, Mr. Epstein and his attorneys car
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL. 33401, (561)
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. FI. Court File No. 08-80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (56J) 820-8777
+September 15, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+AMENDED NOTIFICATION
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+is you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinatte
+eferred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Section:
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-
+009454AXXXMB and 2008-cf-009381AXXXMB) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+
+
+
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-représentative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. FI. Court File No. 08-80736-CIV-MARRA.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Marillagera
+Jeffrey Herman, Esq.
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+November 14, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense. A copy of this letter was sent to you in September but was returned because
+we had an incorrect address. Thank you for providing us with an updated address.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+
+
+MS. |
+
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+As mentioned above, you have no obligation to select Mr. Josefsberg as your counsel.
+If you would like to have Mr. Josefsberg represent you, you must contact him or his partner,
+Katherine Ezell, directly at
+, Please note that, even if you decide not to pursue
+a claim against Mr. Epstein, Ms. Ezell has put together a team of counselors who can assist
+you with any counseling or other services that you might need. You also can continue to
+
+
+
+contact the FBI's Victim Services Coordinator,
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL. 33401, (561)
+659-8300. It also is important that you inform me if you hire an attorney so that I may
+communicate with you through that attorney, or if you change your address or telephone
+number.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being. If you have any questions regarding this letter, please feel free to
+contact me at 561-820-8711.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+November 14, 2008
+VIA HAND DELIVERY
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+
+
+Ms.|
+
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+As mentioned above, you have no obligation to select Mr. Josefsberg as your counsel.
+If you would like to have Mr. Josefsberg represent you, you must contact him or his partner,
+Katherine Ezell, directly at
+,. Please note that, even if you decide not to pursue
+a claim against Mr. Epstein, Ms. Ezell has put together a team of counselors who can assist
+you with any counseling or other services that you might need. You also can continue to
+contact the FBI's Victim Services Coordinator,
+at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, (561)
+659-8300. It also is important that you inform me if you hire an attorney so that I may
+communicate with you through that attorney, or if you change your address or telephone
+number.
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of In re Jane Does
+1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MARRA.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+for your
+health and well-being. If you have any questions regarding this letter, you can contact me
+at the address and telephone number shown above.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+
+
+V.S. Department of Justice
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+December 8, 2008
+VIA HAND DELIVERY
+Re:
+Jeffrey Epstein/Molly
+: Notification of Work Release
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office hereby provides you with notice
+that the U.S. Attorney's Office has learned that Jeffrey Epstein has applied to participate in the Palm
+Beach County Sheriff's Office's ("PBSO") work release program, and PBSO has granted that
+application. Mr. Epstein is reportedly working for The Florida Science Foundation at 250 South
+Australian Avenue, Suite 1404, West Palm Beach, FL. 33401. After work each day, Mr. Epstein
+returns to the Palm Beach County Stockade.
+While outside the Stockade, Mr. Epstein is
+electronically monitored via a GPS system and an ankle bracelet. Pursuant to the work release rules,
+Mr. Epstein is to go directly from the Stockade to his office, remain at the office throughout the work
+day, and then return directly to the Stockade.
+We regret that we were unable to inform you of these developments prior to Mr. Epstein's
+release, but our Office was never notified of Mr. Epstein's application, and we only learned of his
+release more than six weeks after he began participating in the program. Should you have any
+questions regarding the work release program, please direct your inquiries to Captain David Sleeth,
+Palm Beach Sheriff's Office, 561-688-3595.
+R. Alexander Acosta
+By:
+Assistant U.S. Attorney
+
+
+500 South Australian Ave., Swite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+December 9, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+: Notification of Work Release
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office hereby provides you with notice
+that the U.S. Attorney's Office has learned that Jeffrey Epstein has applied to participate in the Palm
+Beach County Sheriff's Office's ("PBSO") work release program, and PBSO has granted that
+application. Mr. Epstein is reportedly working for The Florida Science Foundation at 250 South
+Australian Avenue, Suite 1404, West Palm Beach, FL 33401. After work each day, Mr. Epstein
+returns to the Palm Beach County Stockade. While outside the Stockade, Mr. Epstein is
+electronically monitored via a GPS system and an ankle bracelet. Pursuant to the work release rules,
+Mr. Epstein is to go directly from the Stockade to his office, remain at the office throughout the work
+day, and then return directly to the Stockade.
+We regret that we were unable to inform you of these developments prior to Mr. Epstein's
+release, but our Office was never notified of Mr. Epstein's application, and we only learned of his
+release more than six weeks after he began participating in the program. Should you have any
+questions regarding the work release program, please direct your inquiries to Captain David Sleeth,
+Palm Beach Sheriff's Office, 561-688-3595. You also can ask Captain Sleeth to add the addresses
+where you live, work, and/or attend school to the list of Mr. Epstein's "Exclusionary Zones," which
+are programmed into his GPS system.
+It is my understanding that you have not retained counsel to represent you with regard
+to any litigation against Mr. Epstein. It is important that you inform me if you do hire an
+attorney so that I may communicate with you through that attorney, or if you change your
+address or telephone number. As 1 mentioned in my earlier correspondence, Robert
+Josefsberg and his firm were selected by an independent Special Master to represent the
+identified victims of Mr. Epstein with certain limitations, which Mr. Josefsberg can explain.
+
+
+NOTIFICATION OF WOrK RELEASE
+DECEMBER 9, 2008
+
+Again, you have no obligation to select Mr. Josefsberg as your counsel, but if you would like
+to have Mr. Josefsberg represent you, you must contact him or his partner, Katherine Ezell,
+directly at
+via e-mail at
+and
+kezell@podhurst.com. (If you contact them via e-mail please reference Mr. Epstein in your
+e-mail.) Please note that, even if you decide not to pursue a claim against Mr. Epstein, Ms.
+Ezell has put together a team of counselors who can assist you with any counseling or other
+services that you might need. You also can continue to contact the FBI's Victim Services
+Coordinator,
+My best wishes for a peaceful holiday season.
+R. Alexander Acosta
+By:
+Assistant U.S. Attorney
+ce:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+December 9, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein
+: Notification of Work Release
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office hereby provides you with notice
+that the U.S. Attorney's Office has learned that Jeffrey Epstein has applied to participate in the Palm
+Beach County Sheriff's Office's ("PBSO) work release program, and PBSO has granted that
+application. Mr. Epstein is reportedly working for The Florida Science Foundation at 250 South
+Australian Avenue, Suite 1404, West Palm Beach, FL 33401. After work each day, Mr. Epstein
+returns to the Palm Beach County Stockade. While outside the Stockade, Mr. Epstein is
+electronically monitored via a GPS system and an ankle bracelet. Pursuant to the work release rules,
+Mr. Epstein is to go directly from the Stockade to his office, remain at the office throughout the work
+day, and then return directly to the Stockade.
+We regret that we were unable to inform you of these developments prior to Mr. Epstein's
+release, but our Office was never notified of Mr. Epstein's application, and we only learned of his
+release more than six weeks after he began participating in the program. Should you have any
+questions regarding the work release program, please direct your inquiries to Captain David Sleeth,
+Palm Beach Sheriff's Office, 561-688-3595. You also can ask Captain Sleeth to add the addresses
+where you live, work, and/or attend school to the list of Mr. Epstein's "Exclusionary Zones," which
+are programmed into his GPS system.
+It is my understanding that you have not retained counsel to represent you with regard
+to any litigation against Mr. Epstein. It is important that you inform me if you do hire an
+attorney so that I may communicate with you through that attorney, or if you change your
+address or telephone number. As I mentioned in my earlier correspondence, Robert
+Josefsberg and his firm were selected by an independent Special Master to represent the
+identified victims of Mr. Epstein with certain limitations, which Mr. Josefsberg can explain.
+
+
+Ms.|
+NOTIFICATION OF WorK RELEASE
+DECEMBER 9, 2008
+
+Again, you have no obligation to select Mr. Josefsberg as your counsel, but if you would like
+to have Mr. Josefsberg represent you, you must contact him or his partner, Katherine Ezell,
+directly at
+or
+via e-mail at
+and
+kezell@podhurst.com. (If you contact them via e-mail please reference Mr. Epstein in your
+e-mail.) Please note that, even if you decide not to pursue a claim against Mr. Epstein, Ms.
+Ezell has put together a team of counselors who can assist you with any counseling or other
+services that you might need. You also can continue to contact the FBI's Victim Services
+Coordinator,
+at
+My best wishes for a peaceful holiday season.
+R. Alexander Acosta
+By:
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/a3834ee2226ece031e9cfac27bc944e47ea5c067e8f67fc98857dde584dc4a34.receipt.json b/vision-fixhub/ds9-unparsed-05/a3834ee2226ece031e9cfac27bc944e47ea5c067e8f67fc98857dde584dc4a34.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b474cc4f5b1afb163f038eb128ea64c9afedf625
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a3834ee2226ece031e9cfac27bc944e47ea5c067e8f67fc98857dde584dc4a34.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -41024,
+  "dataset": "marble-joined",
+  "doc_id": "a3834ee2226ece031e9cfac27bc944e47ea5c067e8f67fc98857dde584dc4a34",
+  "engine": "marble-apple-vision",
+  "event_count": 406,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "23a60a1e3232f4188e449c00a4bec627f177ec147874a848faa2c84314d31418",
+  "output_sha256": "712efb8e4a4930c0ab8656b7b1b128d508d44a71c05d357c7f746d49417d769d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a3a714811230faf06e6be3a45e930800b691c2a521b2cd67db626589a97cada3.md b/vision-fixhub/ds9-unparsed-05/a3a714811230faf06e6be3a45e930800b691c2a521b2cd67db626589a97cada3.md
new file mode 100644
index 0000000000000000000000000000000000000000..5e5851bda69622466085dd8b90b52329dcbf45cd
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a3a714811230faf06e6be3a45e930800b691c2a521b2cd67db626589a97cada3.md
@@ -0,0 +1,14 @@
+U.S. Department of Justice
+Suited su Destit one orida
+Facsimile
+FACSIMILE COVER SHEET
+TO: Colonia Bank, attn: Anita Muller
+DATE: June 19, 2007
+FAX NO.
+PHONE NO.
+FROM: I
+# OF PAGES:
+RE: Grand Jury Subpoenas OLY-01 & OL.Y-28
+Assistant U.S. Attorney
+PHONE NO.
+COMMENTS:
diff --git a/vision-fixhub/ds9-unparsed-05/a3a714811230faf06e6be3a45e930800b691c2a521b2cd67db626589a97cada3.receipt.json b/vision-fixhub/ds9-unparsed-05/a3a714811230faf06e6be3a45e930800b691c2a521b2cd67db626589a97cada3.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c0416e4eae639de3f4b37ad0efbe0049325835fb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a3a714811230faf06e6be3a45e930800b691c2a521b2cd67db626589a97cada3.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "a3a714811230faf06e6be3a45e930800b691c2a521b2cd67db626589a97cada3",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "fc9c086626a67ae591c955fcf830b7bb997ac4057b786a55ff3e2e837955534d",
+  "output_sha256": "bfbfdaf62708f71e9eeb7f3ed3276994b95a563bdd1a7293ab47b81ced1342f0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a3d6550cdec6b8c8cd2f1928d2297db0ed48988a023f5d05960eb1499a28c8a1.md b/vision-fixhub/ds9-unparsed-05/a3d6550cdec6b8c8cd2f1928d2297db0ed48988a023f5d05960eb1499a28c8a1.md
new file mode 100644
index 0000000000000000000000000000000000000000..e55b1d49bf8a6edb5aaf9d8b87dca6b243198824
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a3d6550cdec6b8c8cd2f1928d2297db0ed48988a023f5d05960eb1499a28c8a1.md
@@ -0,0 +1,92 @@
+ATTACHMENT 1
+USER LITIGATION HOLD NOTICE AND CERTIFICATION FORM
+PRIVACY ACT PROTECTED
+I. NOTICE
+Please be advised that, by and through this Notice, we, the United States Attorney's Office for the Southern District of
+Florida ("USAO"), have instituted a "Litigation Hold" in connection with the claims set forth in Jane Does #1 and #2 l
+United States, Case No.: 08-80736-CIV-MARRA/Johnson regarding alleged violation of the petitioners' rights
+under the Crime Victim's Rights Act ("CVRA").
+To institute this Litigation Hold, we are implementing preservation procedures regarding any and all records, data, or other
+information, whether they exist in paper form or as electronically stored information ("ESI"), within the USAO's possession,
+custody or control relating to the Complaint/Claims (collectively, "Information"). The USAO's obligation to preserve this
+Information pertains not only to paper copies, or "hard copies" (whether in draft or final, partial or complete, versions), but
+also to ESI in its originally-created, or "native" format, as it exists on any computer system (whether it be on the USAO's
+system or your personal computer), as well as removable or portable electronic storage media. Specific examples of
+Information subject to this Litigation Hold include, but are not limited to, e-mails and other electronic communications,
+word processing documents, records, spreadsheets, databases, calendars, telephone logs, internet usage files, network
+access information, and information on other kinds of media, including PDAs (such as Palm Pilots, BlackBerries, and cell
+phones), thumb drives, CDs, as well as digital voicemail and text messages.
+Because the USAO must take reasonable steps to preserve such Information in whatever form it has been created and
+maintained, the USAO's Lit Hold Coordinator and Systems Manager must coordinate with all those who may have such
+Information. We therefore require your assistance to both identify and preserve any and all Information relating to the
+Complaint/Claims, whether or not the Information is ultimately discoverable. Furthermore, we must confirm that you
+understand and accept your preservation obligations under this Litigation Hold.
+Accordingly, you are required to take the two following steps: (1) Identify to us all such Information and where it resides (in
+Section il below); and (2) Certify having received notice of this Litigation Hold and understanding and accepting your
+preservation obligations under this Litigation Hold (in Section I|I below). [NOTE: While seeking to identify all such
+Information, please refrain to the maximum extent possible from opening emails/files you believe to be relevant.]
+Il. IDENTIFY ALL INFORMATION SUBJECT TO THE LITIGATION HOLD
+Please identify all locations where the Information described above may exist: CHECK ALL THAT APPLY
+Hard Copy Documents:
+• Printed Emails
+• Case Files/Logs
+• Calendars/Appointment Books
+USAO System - Microsoft Outlook:
+• Email Messages
+• Calendar Items
+• Notes
+• Public Folders
+• PST Files ("Archive") O Office Communicator
+(continued on next page).
+USAO System - EVole:
+• Telephone Data
+• Tasks
+• Contacts
+• Other
+Attachment 1, USAP 3-13.300.003
+Pagel1
+
+
+ATTACHMENT 1
+(continued from previous page)
+USAO System - Network Data (i.e., documents/files and folders residing on network drives);
+• Personal (N, H & M) Drive Document/Files/Folders • Shared Files/Folders
+• Inter- and Intra-net • Other
+• LIONs/Alcatraz/USA-5
+USAO System - Mobile PIN/SMS:
+• Blackberry/Other
+USAO System - Classified/Special Data:
+• Document/Files/Folders/Other
+Non-Network Dato (i.e,, documents/files and folders residing on local hard drives and thumb drives):
+• Local (C & D) Drives •] Portable Media/Thumb Drives • Deleted Items (Recycle Bin)
+Personal Non-Metwork Data (located or residing somewhere other than the USAO System):
+• Document/Files/Folders • InternetO Email Messages
+• Portable Media/Thumb Drives
+• PDAs/Other
+Ill. CERTIFICATION
+By this Notice and Certification, I acknowledge that I have received, understand, and accept my obligations to preserve any
+and all Information (as defined above) I may have now, as well as all such Information I may subsequently receive, create or
+modify. I further understand and accept that my continuing Litigation Hold obligations require that I preserve all such
+Information in "native" format and, conversely, that I not delete or destroy any such Information until | receive formal
+written notice that this Litigation Hold is discontinued. To fulfill these continuing obligations, I will undertake the necessary
+steps to preserve this Information, be it "hard copy" and/or ESI, in coordination with the USAO's Lit Hold Coordinator and
+Systems Manager.
+***
+Please be advised that failure to preserve and retain this Information may result in sanctions and/or implicate professional
+conduct rules. Consequently, if you are unsure whether certain information should be preserved, err on the side of caution
+and preserve the information until you have spoken to the USAO's Lit Hold Coordinator about it. If you have any questions
+about whether to preserve certain ESI, or its native formatting, please contact the USAO's Lit Hold Coordinator or Systems
+Manager.
+Please sign below to acknowledge you have read this Notice and Certification and understand and accept your preservation
+obligations, then return the executed copy to the USAO's Lit Hold Coordinator. Thank you.
+User Signatu
+Date of User Signature:
+11/5/10
+CC:
+USAO Lit Hold Coordinator
+National Preservation Officer
+USAO Systems Manager
+INFORMATION CONTAINED IN THIS FORM MAY CONSTITUTE PRIVATE, CONFIDENTIAL AND/OR SENSITIVE, AS
+WELL AS PERHAPS ALSO PRIVILEGED AND/OR OTHERWISE PROTECTED, INFORMATION
+Attachment 1, USAP 3-13.300.003
+Page |2
diff --git a/vision-fixhub/ds9-unparsed-05/a3d6550cdec6b8c8cd2f1928d2297db0ed48988a023f5d05960eb1499a28c8a1.receipt.json b/vision-fixhub/ds9-unparsed-05/a3d6550cdec6b8c8cd2f1928d2297db0ed48988a023f5d05960eb1499a28c8a1.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..cf76657f9c9e43e35513f15a7f8e58037b5b1320
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a3d6550cdec6b8c8cd2f1928d2297db0ed48988a023f5d05960eb1499a28c8a1.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "a3d6550cdec6b8c8cd2f1928d2297db0ed48988a023f5d05960eb1499a28c8a1",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e3bb234f072400ce1339bc84354ce6a59ec6732b862b16e0c8281eb3a06faf2a",
+  "output_sha256": "8b1510fd63ad6063d87dee31e2f3851011b9357497a3eba45b3382abe0c1b4d0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a41057524f754e4f7d764d2a03063abffcbad9d164f85bb902e6508cdfb64fe9.md b/vision-fixhub/ds9-unparsed-05/a41057524f754e4f7d764d2a03063abffcbad9d164f85bb902e6508cdfb64fe9.md
new file mode 100644
index 0000000000000000000000000000000000000000..43d90c2470ff8afbd43140e72d7566cc5a270edd
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a41057524f754e4f7d764d2a03063abffcbad9d164f85bb902e6508cdfb64fe9.md
@@ -0,0 +1,395 @@
+Statements
+
+
+OFFICE SERVICING YOUR ACCOUNT
+1001 Nineteenth Street North
+VISIT OUR WEBSITE
+www.fbr.com
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO., INC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30, 2003
+Important Message
+If any information regarding 2003 interest, dividends,
+discola is required to beep red other or i re
+is required to be reported to the IRS for this
+February 2,2004 or a 10425y arch 15, mailed to you by
+FINANCIAL TRUST CO., INC
+600 REDHOOK QUARTER STE B-3
+ST THOMAS US
+US VI 00802
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TO
+12/17/03
+TRANSACTION
+DELIVERED
+TOTAL
+DESCRIPTION
+FRANKLIN BANK CORP
+DEL TO OBEDITED INS
+SYMBOLICUSIP
+QUANTITY
+-100,000
+PRICE
+DEBIT AMOUNT
+CREDIT AMOUNT
+SIP The suremen is four ratanal purger red de Set revere dise for portant iformation.
+
+
+OFFICE SERVICING YOUR ACCOUNT
+1001 Nineteenth Street North
+Alephone (03) 312900722
+•ax (703) 312 9501
+E-Mail info@fbr.con
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+2 ord
+Your messages
+As part of the National Association of Securities Dealers (NASD) Investor
+FINANCIAL TRUST CO., INC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+September 30, 2003
+LE IMPORTANT NOTICE TO CLIENTS: Disclosure of Order Execution and Routing
+Practices Sec Rule 11Ac1-5 (Monthly report) requires "market centers" that
+trade Nasdaq National Market, Nasdag Small Cap securities and
+xchange-listed securities to make publicly available standardized, month!
+tatistical information about "covered order" executions, as defined by the rule
+cross-market comparisons, the Rule establishes uniform measures of
+execution quality, among them effective spread, rate of price improvement, fill
+rate and execution speed, The rule also requires the statistics to be
+categorized by individual security, order type and size (100-499 shares,
+500-1999, 2000-4999, 5000-999). It is important to note that orders for
+10,000 shares or more are exempt from the rule and are therefore not
+included in the statistics.
+027
+
+
+3 of 4
+STOP
+OFFICE SERVICING YOUR ACCOUNT
+1001 Nineteenth Street North
+alephone (703) 32295-0722
+Fax (703) 312 9501
+E-Mail info@fbr.com
+Bear, Steams Securities Carp.
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO., INC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30, 2003
+Excess SIPC Account Protection Update
+ear, Stearns Securities Corp, ('BSS'), a member of the Securities Investo
+rotection Corporation ("SIPC"), provides account protection for the net equit
+available the monthly and quarterly reports in electronic form, free of charge
+and available for downloading from an internet site. This information is
+available via our website at www.fbr.com, This information is presented in
+accordance with the SEC Rule 11Ac1-5 and 1-6 requirements, A written copy
+of the quarterly report is available upon request,
+Additional information regarding the rule, interpretations and exemptions can
+be obtained directly from the SEC at www sec,gov and the NASD at
+www.nasd.com,
+insurer, Effective February 16, 2004, the commercial insurer for Excess SIPC
+will change to Customer Asset Protection Company ("CAPCO"), a licensed New
+York insurance company. Account protection applies when a SIPC member
+firm fails financially and is unable to meet its obligations to its securities
+customers, but does not apply to losses from the rise or fall in the market
+value of investments or to SIPC ineligible assets such as options, futures,
+foreign exchange transactions, or any investment contracts that are not
+registered as securities,
+****** End of Statement******
+027
+
+
+4 of 4
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO., INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+V818
+
+
+OFFICE SERVICING YOUR ACCOUNT
+1001 Nineteenth Street North
+VISIT OUR WEBSITE
+www.fbr.com
+Important Message
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+FINANCIAL TRUST CO., INC
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 27, 2003
+reflects all activity and account valuation up to and
+including the last business day of the month
+FINANCIAL TRUST CO., INC
+600 REDHOOK QUARTER STE B-3
+ST THOMAS US
+US VI 00802
+Your Portfolio Holdings
+EQUITIES
+Equities & Options
+DESCRIPTION
+RANKLIN BANK CORR
+LA ACCREDITED INVS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOL/CUSIP
+ACCT
+TYPE
+CASH
+QUANTITY
+100,000
+PRICE
+Unpriced
+MARKET
+VALUE
+ESTIMATED
+ANNUAL INCOME
+$0
+$0
+$0
+$o
+CURRENT
+YIELD (%)
+SPC The sermany to it real purpose on ended as a pera tomation.
+10/01/03;15:17 001
+V913
+
+
+OFFICE SERVICING YOUR ACCOUNT
+1001 Nineteenth Street North
+Aripon: (03) 322090722
+ax (703) 312 950
+-Mail info@ibr.cor
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+2 org
+Your messages
+Bear, Stearns Securities Corp, Net Capital and Net Capital Requirements:
+At May 31, 2003 and July 31, 2003, the Company's net capital of
+FINANCIAL TRUST CO., INC
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+June 27, 2003
+Securities and other assets in your account are the firm's collateral for any
+margin loan made to you. If the securities and other assets in your account
+decline in value, so does the value of the collateral supporting your loan, and
+A complete copy of the Bear, Stears Securities Corp, Statement of Financial
+Condition is available on the web site www.bsscfinancialstatement.com.
+Alternatively, to request a free printed copy please call - toll free
+1-866-299-9331.
+* You can lose more funds than you deposit in the margin account.
+* The firm can force the sale of securities or other assets in you
+accounts).
+* The firm can sell your securities or other assets without contacting you.
+* You are not entitled to choose which securities or other assets in your
+accounts) are liquidated or sold to meet a margin call.
+The time can i nose us no spr mail oace ma in reuniments at
+* You are not entitled to an extension of time on a margin call,
+STOP
+****** End of Statement******
+027
+10/01/03;15:17 001
+V9Ta
+
+
+3 of 3
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO., INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+10/01/03:15:17 001
+V813
+
+
+OFFICE SERVICING YOUR ACCOUNT
+1001 Nineteenth Street North
+VISIT OUR WEBSITE
+www.fbr.com
+Important Message
+Confirmation: Unless we hear from you to the contrary, it is
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+FINANCIAL TRUST CO., INC
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2003
+FINANCIAL TRUST CO., INC
+600 REDHOOK QUARTER STE B-3
+ST THOMAS US
+US VI 00802
+Your Portfolio Holdings
+EQUITIES
+Equities & Options
+DESCRIPTION
+RANKLIN BANK CORR
+LA ACCREDITED INVS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOL/CUSIP
+ACCT
+TYPE
+CASH
+QUANTITY
+100,000
+PRICE
+Unpriced
+MARKET
+VALUE
+ESTIMATED
+ANNUAL INCOME
+CURRENT
+YIELD (%)
+$0
+$0
+$0
+$o
+SPC The remany to it real purpose end ente as a portant tomation..
+06/28/03:14:30 001
+V90S
+
+
+2 of 2
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO., INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+06/28/03;14:50 001
+V908
+
+
+OFFICE SERVICING YOUR ACOUNT
+1001 Nineteenth Street North
+VISIT OUR WEBSITE
+www.fbr.com
+What's In This Statement
+Your Portfolio Holding.........•••••••
+Your Messages....
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+FINANCIAL TRUST CO., INC
+STATEMENT PERIOD March 1, 2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2002
+FINANCIAL TRUST CO., INC
+600 REDHOOK QUARTER STE B-3
+ST THOMAS US
+US VI 00802
+Your Portfolio Holdings
+EQUITIES
+Equities & Options
+DESCRIPTION
+FRANKLIN BANK CORP
+CL A ACCREDITED INVS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOUCUSIP
+CASH
+QUANTITY
+100,000
+PRICE
+Unpriced
+$0
+$0
+ANNUAL COME
+$0
+$0
+SPC The remany a termal purpose on do rented a potame tomation..
+03/29103;15:39 001
+
+
+2 org
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams Securities Carp.
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO., INC
+STATEMENT PERIOD March 1, 2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+December 31, 2002
+NOTICE OF CHANGE PURSUANT TO THE TRUTH IN LENDING SEC
+Your messages
+Bear, Stearns Securities Corp, Net Capital and Net Capital
+Requirements:
+t November 30, 2002 and January 31, 2003, the Company's ne
+apital of approximately $2.4 billion and $2.4 billion wa
+716,3 million and $684.1 million by approximately $1.7 billion ar
+A complete copy of the Bear, Stearns Securities Corp, Statement
+of Financial Condition is available on the web site
+www.bsscfinancialstatement.com. Alternatively, to request a free
+printed copy please call - toll free 1-866-299-9331
+Bear Stearns at our main office in New York, Factors affecting the
+determination of the BSSC Base Lending Rate will include the
+short-term market interest rates quoted by money center banks and the
+Federal Reserve and the rate that Bear Stearns Securities is charged for
+borrowing money, The BSSC Fed Fund rate is the rate for U,S,
+dollar funds, as quoted by an independent broker or such funds selected
+by Bear Stearns Securities for the last transaction completed prior to
+9:30 a,m, (Eastern Time) on the business day on which such rate is
+determined. The annual rate of interest will be no more than 400 basis
+points above the BSSC Base Lending Rate or 500 basis points
+above either the BSSC Fed Funds Rate or LIBOR and
+will appear on your monthly statements, Since the rate of interest
+charged is related to the BSSC Base Lending Rate, the BSSC
+Fed Funds Rate or LIBOR, any changes in these rates will
+cause corresponding changes in the rate charged to your account, which
+changes will be made without prior notice to you, If for any other reason
+Bear Stears Securities changes the rate of interest it charges you, we
+will give you at least 30 days prior notice.
+The Statement of Interest Charges Pursuant to the "Truth-in-Lending"
+SEC Rule 10b-16 previously provided to you remains in effect except
+to the extent specifically amended by this notice.
+027
+03/29/03;15:39 001
+
+
+3 of 3
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO., INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+03/29/03;15:39 001
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/a41057524f754e4f7d764d2a03063abffcbad9d164f85bb902e6508cdfb64fe9.receipt.json b/vision-fixhub/ds9-unparsed-05/a41057524f754e4f7d764d2a03063abffcbad9d164f85bb902e6508cdfb64fe9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..60373b01c8b6bb1dfc36b7c7838c0a1dd3f31600
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a41057524f754e4f7d764d2a03063abffcbad9d164f85bb902e6508cdfb64fe9.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1117,
+  "dataset": "marble-joined",
+  "doc_id": "a41057524f754e4f7d764d2a03063abffcbad9d164f85bb902e6508cdfb64fe9",
+  "engine": "marble-apple-vision",
+  "event_count": 14,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "23b3316e2673ae2840d47aa10ca7b8b130c81064729dacccfa8d9eba8b215ac3",
+  "output_sha256": "7d8dae69eed37e8bd18be6ce08da9775e547020a562e7324e18a9458ef0aec22",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a421290a3f39d9d10d2afad4bb750c9db8c308a9ed14863338e3e1c7304eced2.md b/vision-fixhub/ds9-unparsed-05/a421290a3f39d9d10d2afad4bb750c9db8c308a9ed14863338e3e1c7304eced2.md
new file mode 100644
index 0000000000000000000000000000000000000000..d5081b82f1a82b0ba55e40b1e4e088d7e21b0393
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a421290a3f39d9d10d2afad4bb750c9db8c308a9ed14863338e3e1c7304eced2.md
@@ -0,0 +1,59 @@
+From:
+To:
+Subject: DOJ EXECSEC / TRIM DOCUMENT : 19/DO/2690 : (Rec'd from OLA via email)
+Requesting a briefing on the 2007 non-prosecution agreement between the USAO, S.D. OF
+Florida and Mr. Jeffrey Epstein, and any related commission of professional misconduct by
+Date: Mon, 22 Jul 2019 15:28:24 +0000
+Importance: Normal
+Priority: normal
+Attachments: (Rec_d_from_OLA_via_email)_Requesting_a_briefing_on_the_2007_nonprosecution_agreement_between_the_USAO,_~_USA_Alexander_Acosta._Expressing_con
+cern.PDF
+Classification: UNCLASSIFIED
+(U) INFORMATION ONLY: DD, ADD, COS, DCOS, SCTD, OCA, EAD/CCRSB, OGC, OPA, VSD, CID,
+SACMM LEORGE L. PIRO, ADIC NY WILLIAM F. SWEENEY & C. MENCINI.
+
+
+(U) Instructions:
+(U) Attached is correspondence referred to the FBI by the U.S. Department of Justice (DOJ Executive
+Secretariat, FOR INFORMATION ONLY. IT DOES NOT REQUIRE ANY FBI ACTION; however, it is being
+referred to you for your information in the event you may be contacted by the DOJ entity tasked with handling
+the response.
+(U) IMPORTANT NOTE: If you represent an FBI Field Division and are receiving this e-mail, you are being
+provided a copy of correspondence which has come to the attention of the Director, or other FBI executive. You
+are not being tasked with any action in this regard by the FBI's Office of the Executive Secretariat. You are being
+provided a courtesy copy only.
+--_< HPE Records Manager record Information >----
+Record Number : 19/DO/2690
+Addressee :
+All contacts : Office of Congressional Affairs (Other)
+Deputy Director (Other)
+Associate Deputy Director (Other)
+Chief of Staff (Other)
+Deputy Chief of Staff (Other)
+Special Counsel to the Director (Other)
+EAD-Criminal, Cyber, Response, and Services (Other)
+Office of General Counsel (Other)
+Office of Public Affairs (OPA) (Other)
+AD-Victim Services Division (Other) Business Phone
+AD-Criminal Investigative Division (Other)
+SAC-Miami (Other) Business Phone:
+ADIC-New York (Other)
+Mencini, Courtenay (Other)
+Current action : FOR INFORMATION ONLY (Responsibility of: Executive, Secretariat, Due 07/22/2019 at 9:56
+AM (Overdue 1 hour, 27 minutes))
+Mail Type : DOJ EXEC SEC
+Date Due :
+Type of Communication: CONGRESSIONAL PRIORITY
+Access DB or Workflow : 4297700
+Notes : SUBJECT: regarding reports of Mr. Epstein's repeated and longstanding sexual abuse of young girls.
+Mentions investigative reporting by the Miami herald details Mr. Epstein's alleged abuse of at least three dozen
+girls in his Florida and New York homes forcing them to engage in sex acts and coercing them to recruit future
+victims. Despite the fact that federal prosecutors had drafted a 53 page indictment and an 82-page prosecution
+memo for Mr. Epstein, then-USA Acosta signed a non-prosecution agreement that absolved Mr. Epstein of
+federal prosecution and ended the related FBI inquiry. Further, Mr. Epstein's victims were purportedly not made
+aware of the non-prosecution agreement, preventing them from voicing opposition and possibly violating the
+Crime Victims' Right Act. Members of the House Judiciary Subcomte on Crime, Terrorism and Homeland
+Security request a briefing and any relevant documents by 07/24/2019. Ltr also signed by 11 other MCs. See
+related corres in ECMS. (PB)
+"Monday, July 22, 2019 at 9:39:06 AM (GMT+04:00) Wallace-Bowser, Sherie L.:"
+Classification: UNCLASSIFIED
diff --git a/vision-fixhub/ds9-unparsed-05/a421290a3f39d9d10d2afad4bb750c9db8c308a9ed14863338e3e1c7304eced2.receipt.json b/vision-fixhub/ds9-unparsed-05/a421290a3f39d9d10d2afad4bb750c9db8c308a9ed14863338e3e1c7304eced2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ca062407c383cda91ce62f45f16dc8b3204403e4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a421290a3f39d9d10d2afad4bb750c9db8c308a9ed14863338e3e1c7304eced2.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -26,
+  "dataset": "marble-joined",
+  "doc_id": "a421290a3f39d9d10d2afad4bb750c9db8c308a9ed14863338e3e1c7304eced2",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "2c4c1054d25ac1127254cb1d0466fd0a001b4209fad98d93945ea089a6fea988",
+  "output_sha256": "75fb94908437079132cb9793902244ce89948cee76426786a390d2f2c89c63d6",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a51660c44dc87cdea685a28461116d6903aedf567e016286c77e90a95cef5020.md b/vision-fixhub/ds9-unparsed-05/a51660c44dc87cdea685a28461116d6903aedf567e016286c77e90a95cef5020.md
new file mode 100644
index 0000000000000000000000000000000000000000..42d16617e6580f40846f291eb7410bb631fd3e51
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a51660c44dc87cdea685a28461116d6903aedf567e016286c77e90a95cef5020.md
@@ -0,0 +1,776 @@
+To:
+Subject:
+Wednesday, October 31, 2007 11:40 AM
+Sloman, Jeff (USAFLS)
+RE: Epstein
+Maybe make the changes underlined below? Either way is fine.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach. FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+From: Sloman, Jeff (USAFLS)
+Sent: Wednesday, October 31, 2007 11:36 AM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: RE: Epstein
+Marie.
+Here's my proposed response to Jay. What do you think?
+Jeff
+Jay.
+contest liability and also braives his right to contest damages un to an amount as agreed lo berween the
+identified individual and Epstein. so long as the identified
+and agrees to waive any other claim for damages ....
+not want to he copied on anything related to discovery. Monitoring the status of the negotiations/litigation is
+limited to insuring that the terms and conditions of the Non-Prosecution Agreement are not breached.
+From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com]
+Sent: Tuesday, October 30, 2007 4:54 PM
+To: Sloman, Jeff (USAFLS)
+Cc: Acosta, Alex (USAFLS)
+Subject: Re: Epstein
+Thanks Jeff.
+I haven't heard anything from Judge
+I assume he is still willing to take on the role you asked him to take on, but can you please
+let me know if that is not the case!
+no, we are eping a tink abouts or alicing we a de ra. tries ly lip a sang car your fict does
+2650
+P-014252
+
+
+Thanks - Jay
+-- Original Message ----
+From: "Sloman, Jeff (USAFLS)" [Jeff.Sloman@usdoj.gov]
+Sent: 10/30/2007 02:42 PM AST
+To: Jay Lefkowitz
+Ce: "Acosta, Alex (USAFLS)" <Alex.Acosta @usdoj.gov»
+Subject: Epstein
+Jay,
+Jeff
+Here is an executed version of the addendum. Please Fed Ex the original signature pages to me. Thanks,
+<<epstein addendum 10 30.pdf>>
+***************************************:
+The information contained in this communication is
+confidential, may be attorney-client privileged, may
+constitute inside information, and is intended only for
+the use of the addressee. It is the property of
+Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
+Unauthorized use, disclosure or copying of this
+communication or any part thereof is strictly prohibited
+and may be unlawful. If you have received this
+communication in error, please notify us immediately by
+return e-mail or by e-mail to postmaster@kirkland.com, and
+destroy this communication and all copies thereof,
+including all attachments.
+********
+Tracking:
+2651
+P-014253
+
+
+To:
+Subject:
+Wednesday, October 31, 2007 11:00 AM
+Sloman, Jeff (USALS)
+RE: Epstein
+Hi Jeff - There are two issues that could arise.
+First, if. in the context of litigation or settlement negotiations with one of the Victims, Epstein tries to contest
+liability or otherwise violate the particular terms related to the victims, the victim's attorney should file suit in
+District Court asking to enforce the agreement as an intended third party beneficiary.
+Second. if Epstein violates this or any other term of the agreement, the agreement says that we must give timely
+notice to Epstein of his breach and then file an indictment/information within 60 days of providing notice of the
+breach. This is one of the reasons why we shouldn't be completely blocked from communicating with the
+attorney for any of the named victims. He/she will be the only person who can tell us about the breach.
+A. Marie Villațaña
+Assistant U.S.
+500 S. Australian Ave. Suite 400
+West Palm Beach. FL. 33401
+Phone 56l 209-1047
+Fax 561 820-8777
+From: Sloman, Jeff (USAFLS)
+Sent: Wednesday, October 31, 2007 10:00 AM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: RE: Epstein
+Here's what | propose to send to Jay. BTW, what is the mechanism to resolve such potential disputes?
+Jay.
+The agreement says that your client will not contest liability as to the victims on our list. The way I read the
+Gement discoveryday be elevan ture ise of hermount of due dies uttered but not the veracily of the
+From: Villafana, Ann Marie C. (USAFLS)
+ent: Wednesday, October 31, 2007 9:52 A
+o: Sloman, Jeff (USAFLS
+Subject: RE: Epstein
+fi Jeff - The agreement says that they will not contest liability as to the girls on our list. Discovery may be
+elevant to the issue of the amount of damages suffered, but not the veracit of the claim:
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+2653
+P-014254
+
+
+Phone 561 209-1047
+Fax 561 820-8777
+From: Sloman, Jeff (USAFLS)
+Sent: Tuesday, October 30, 2007 5:39 PM
+To: Jay Lefkowitz
+Subject: RE: Epstein
+Jay.
+I called Judge
+before I sent him the agreed upon letter. He indicated his willingness to serve as the "decider." I will
+call him tomorrow to see whether anything has changed and when we can anticipate a decision. Regarding the
+subpoena question, let me think about that overnight. Thanks,
+Jeff
+From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com]
+Sent: Tuesday, October 30, 2007 4:54 PM
+To: Sloman, Jeff (USAFLS)
+Cc: Acosta, Alex (USAFLS)
+Subject: Re: Epstein
+Thanks Jeff.
+I haven't heard anything from Judge
+let me know if that is not the case?
+I assume he is still willing to take on the role you asked him to take on, but can you please
+Also, we are beginning to think about what discovery we may need to take to verify any claims. I am assuming that your office does
+not want to be copied on any subpoenas or anything related to discovery. But please let me know if that is an incorrect assumption.
+Thanks - Jay
+*--- Original Message -**-
+From: "Sloman, Jeff (USAFLS)" [Jeff.Sloman@usdoj.gov]
+Sent: 10/30/2007 02:42 PM AST
+To: Jay Lefkowitz
+Ce: "Acosta, Alex (USAFLS)" < Alex.Acosta@usdoj.gov>
+Subject: Epstein
+Jay,
+Jeff
+Here is an executed version of the addendum. Please Fed Ex the original signature pages to me. Thanks,
+<<epstein addendum 10 30.pdf>>
+2654
+P-014255
+
+
+*******************************************
+The information contained in this communication is
+confidential, may be attorney-client privileged, may
+constitute inside information, and is intended only for
+the use of the addressee. It is the property of
+Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
+Unauthorized use, disclosure or copying of this
+communication or any part thereof is strictly prohibited
+and may be unlawful. If you have received this
+communication in error, please notify us immediately by
+return e-mail or by e-mail to postmaster@kirkland.com, and
+destroy this communication and all copies thereof,
+including all attachments.
+*********************
+*****
+******
+***
+******
+Tracking:
+2655
+P-014256
+
+
+To:
+Subject:
+Sloman, Jeff (USAFLS)
+Wednesday, October 31, 2007 10:00 AM
+RE: Epstein
+Here's what I propose to send to Jay. BTW, what is the mechanism to resolve such potential disputes?
+Jay.
+The agreement says that your client will not contest liability as to the victims on our list. The way I read the
+agreement, discovery may be relevant to the issue of the amount of damages suffered, but not the veracity of the
+claims. That being said, I do not view our office as the mediator of such dispuțes.
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Wednesday, October 31, 2007 9:52 AM
+To: Sloman, Jeff (USAFLS)
+Subject: RE: Epstein
+Hi Jeff - The agreement says that they will not contest liability as to the girls on our list. Discovery may be
+relevant to the issue of the amount of damages suffered, but not the veracity of the claims.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL. 33401
+Phone 561 209-1047
+Fax 56l 820-8777
+From: Sloman, Jeff (USAFLS)
+Sent: Tuesday, October 30, 2007 5:39 PM
+To: Jay Lefkowitz
+Subject: RE: Epstein
+Jay,
+I called Judge
+before I sent him the agreed upon letter. He indicated his willingness to serve as the "decider." I will
+call him tomorrow to see whether anything has changed and when we can anticipate a decision. Regarding the
+subpoena question, let me think about that overnight. Thanks,
+Jeff
+From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com]
+Sent: Tuesday, October 30, 2007 4:54 PM
+To: Sloman, Jeff (USAFLS)
+Cc: Acosta, Alex (USAFLS)
+Subject: Re: Epstein
+2657
+P-014257
+
+
+Thanks Jeff.
+I haven't heard anything from Judge
+let me know if that is not the case?
+I assume he is still willing to take on the role you asked him to take on, but can you please
+Also, we are beginning to think about what discovery we may need to take to verify any claims. I am assuming that your office does
+not want to be copied on any subpoenas or anything related to discovery. But please let me know if that is an incorrect assumption.
+Thanks - Jay
+•-=-- Original Message -----
+From: "Sloman, Jeff (USAFLS)" [Jeff.Sloman@usdoj.gov]
+Sent: 10/30/2007 02:42 PM AST
+Ce: "Acosta, Alex (USAFLS)" <Alex.Acosta@usdoj.gov>
+Subject: Epstein
+Jay,
+Jeff
+Here is an executed version of the addendum. Please Fed Ex the original signature pages to me. Thanks,
+<<epstein addendum 10 30 pdf>>
+******************
+*****
+The information contained in this communication is
+confidential, may be attorney-client privileged, may
+constitute inside information, and is intended only for
+the use of the addressee. It is the property of
+Kirkland & Ellis LLP or Kirkland & Ellis International LL.P.
+Unauthorized use, disclosure or copying of this
+communication or any part thereof is strictly prohibited
+and may be unlawful. If you have received this
+communication in error, please notify us immediately by
+return e-mail or by e-mail to postmaster@kirkland.com, and
+destroy this communication and all copies thereof,
+including all attachments.
+*****************************
+******
+**********************
+2658
+P-014258
+
+
+To:
+Subject:
+Wednesday. October 31, 2007 9:52 AM
+Sloman. Jeff (USAFLS)
+RE: Epstein
+Hi Jeff - The agreement says that they will not contest liability as to the girls on our list. Discovery may be
+relevant to the issue of the amount of damages suffered, but not the veracity of the claims.
+A. Marie Villatana
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach. FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+From: Sloman, Jeff (USAFLS)
+Sent: Tuesday, October 30, 2007 5:39 PM
+To: Jay Lefkowitz
+Subject: RE: Epstein
+Jay.
+I called Judge
+before I sent him the agreed upon letter. He indicated his willingness to serve as the "decider." I will
+call him tomorrow to see whether anything has changed and when we can anticipate a decision. Regarding the
+subpoena question, let me think about that overnight. Thanks,
+Jeff
+From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com]
+Sent: Tuesday, October 30, 2007 4:54 PM
+To: Sloman, Jeff (USAFLS)
+Cc: Acosta, Alex (USAFLS)
+Subject: Re: Epstein
+Thanks Jeff.
+I haven't heard anything from Judge
+let me know if that is not the case?
+I assume he is still willing to take on the role you asked him to take on, but can you please
+Thanks - Jay
+----- Original Message -----
+From: "Sloman, Jeff (USAFLS)" [Jeff.Sloman@usdoj.gov]
+Sent: 10/30/2007 02:42 PM AST
+To: Jay Lefkowitz
+2659
+P-014259
+
+
+Ce: "Acosta, Alex (USAFLS)" <Alex.Acosta@usdoj.gov>
+Subject: Epstein
+Jay,
+Jeff
+Here is an executed version of the addendum. Please Fed Ex the original signature pages to me. Thanks,
+<<epstein addendum 10 30 pdf»>
+*************************»
+*********************************
+The information contained in this communication is
+confidential, may be attorney-client privileged, may
+constitute inside information, and is intended only for
+the use of the addressee. It is the property of
+Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
+Unauthorized use, disclosure or copying of this
+communication or any part thereof is strictly prohibited
+and may be unlawful. If you have received this
+communication in error, please notify us immediately by
+return e-mail or by e-mail to postmaster@ kirkland.com, and
+destroy this communication and all copies thereof,
+including all attachments.
+**********************
+*********************
+Tracking:
+2660
+P-014260
+
+
+To:
+Subject:
+Sloman, Jeff (USAFLS)
+Tuesday, October 30, 2007 4:18 PM
+RE: Letter to Jay
+Marie,
+I think you should emphasize that they should treat this as they would any similarly situated matter and not try to
+influence the outcome of the civil litigation. In other words, once the criminal investigation is over, their involvement
+should cease. I had a similar situation in private practice. I'll never forget trying to get information from the FBI agents
+concerning a convicted pedophile who had been hired to work at a school for autistic children. In representing some of
+the children, we thought the FBI would find a way to provide us with information we were looking for. The FBI refused
+to provide anything and claimed that their investigative work was privileged. I assume that the same would apply here.
+The victims' lawyer(s) will interview the girls and hopefully piece together the important aspects of each case. Any legal
+steps taken to compel testimony or evidence would be handled by FBI general counsel who will respond accordingly.
+Regarding Bert Ocariz, Lefkowitz stated that he seems like a solid lawyer but that since you were involved in his potential
+appearance in this matter they would probably object to his selection. Lefkowitz put an additional insidious spin on it
+that I can't quite remember. I hope that you understand that these ad hominem attacks against you do not diminish in
+our eyes what you and the agents have accomplished. Take care,
+Jeff
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Tuesday, October 30, 2007 3:51 PM
+To: Sloman, Jeff (USAFLS)
+Subject: Letter to Jay
+Hi Jeff - You don't have to show me the letter to Jay before it goes out, I would just appreciate a copy for the
+file.
+Thank you for the advice and the pep talk. The funny thing is that I had never met (and still haven't met) or
+spoken to Bert Ocariz before I asked him if he would be willing to take on this case. I just figured if Judge
+Jordan and E.J. trusted him completely, he would be willing to go to the mat for the victims. But as soon as you
+mentioned the aper. lipstory that he deterise ales on me rise harm the victimhe Special Master
+1 am singing sut up the met in with he Fler ans fog in pa this larckat you want he o eilencussion
+Thanks.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 56l 820-8777
+2664
+P-014261
+
+
+To:
+Subject:
+Tuesday. October 30, 2007 3:51 PM
+Sloman, Jeff (USAFLS)
+Letter to Jay
+Hi Jeff - You don't have to show me the letter to Jay before it goes out, I would just appreciate a copy for the
+Thank you for the advice and the pep talk. The funny thing is that I had never met (and still haven't met) or
+spoken to Bert Ocariz before I asked him if he would be willing to take on this case. I just figured if Judge
+Jordan and E.J. trusted him completely, he would be willing to go to the mat for the victims. But as soon as you
+mentioned the appearance problem, I saw where the problem would arise and agreed that the Special Master
+would be a safer route. I just worry that the defense's attacks on me could harm the victims.
+I am going to set up the meeting with the FBI agents for later this week. Other than the general discussion
+about staying out of the civil litigation, is there anything in particular that you want me to tell them?
+Thanks.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+Tracking:
+2666
+P-014262
+
+
+To:
+subject
+Tuesday. October 30, 2007 1:48 PM
+Sloman, Jeff (USAFLS
+RE: Addendun
+Hi Jeff -- I would feel more comfortable if you signed it, if that i
+And I look forward to Alex's letter.
+I haven't heard from Judge
+hoping to call him tomorrow to ask if he has made a selection yet.
+all over me for a name.
+" right.
+The FBI is
+Thanks.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+-----Original Message-
+From: Sloman, Jeff (USAFLS)
+Sent: Tuesday, October 30, 2007 9:56 AM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: FW: Addendum
+Marie,
+Do you want me to sign for you or do you want to sign? Regarding your concerns
+about Jay's letter, we voiced those concerns with Jay. Alex is planning on
+responding to Jay's letter.
+Jeff
+-----Original Message--.
+From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com]
+Sent: Monday, October 29, 2007 4:32 PM
+To: Sloman, Jeff (USAFLS)
+Subject: Addendum
+Jeff - pls send me a fully executed copy when you have a chance.
+Thanks,
+Jay
+----- Original Message
+.-...-
+2669
+P-014263
+
+
+From: Jay Lefkowitz
+Sent: 10/29/2007 04:24 PM EDT
+To: Jay Lefkowitz
+Subject: Addendum
+(See attached file: Addendum.pdf)
+***********************:
+*****
+********
+The information contained in this communication is confidential, may be attorneyclient privileged, may constitute inside information, and is intended only for
+the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland
+& Ellis International LLP.
+Unauthorized use, disclosure or copying of this communication or any part thereof
+is strictly prohibited and may be unlawful. If you have received this
+communication in error, please notify us immediately by return e-mail or by e-
+mail to postmaster@kirkland.com, and destroy this communication and all copies
+thereof, including all attachments.
+***********************************************************
+Tracking:
+2670
+P-014264
+
+
+To:
+Subject:
+Attachments:
+Sloman, Jeff (USAFLS)
+Tuesday, October 30, 2007 9:56 AM
+Marie,
+Do you want me to sign for you or do you want to sign? Regarding your concerns
+about Jay's letter, we voiced those concerns with Jay. Alex is planning on
+responding to Jay's letter.
+Jeff
+...--Original Message-...
+From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com]
+Sent: Monday, October 29, 2007 4:32 PM
+To: Sloman, Jeff (USAFLS)
+Jeff - pls send me a fully executed copy when you have a chance.
+Thanks,
+Jay
+...-- Original Message -....-
+From: Jay Lefkowitz
+Sent: 10/29/2007 04:24 PM EDT
+To: Jay Lefkowitz
+Subject: Addendum
+(See attached file: Addendum.pdf)
+***********************************************************
+The information contained in this communication is confidential, may be attorneyclient privileged, may constitute inside information, and is intended only for
+the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland
+& Ellis International LLP.
+Unauthorized use, disclosure or copying of this communication or any part thereof
+is strictly prohibited and may be unlawful. If you have received this
+ommunication in error, please notify us immediately by return e-mail or by e-
+mail to postmaster@kirkland. com, and destroy this communication and all copies
+thereof, including all attachments.
+********
+**************************************************
+2672
+P-014265
+
+
+To:
+Subject:
+Monday, October 29, 2007 9:38 AM
+Sloman, Jeff (USALS)
+Letter to Jay Lefkowitz
+Hi Jeff'- I am hoping that you haven't sent off your letter to Jay yet. Two of the things in Jay's letter that
+troubled me were: (1) the mentions of the possibility that Epstein may get a lesser sentence and (2) the
+limitations on our ability to speak with the State Attorney's Office and others. The terms of the agreement
+specify that Epstein shall make a binding recommendation of a 30 month sentence to be served with 18 months"
+imprisonment followed by 12 months' home confinement. I had included a term that Epstein would actually
+serve at least 80% of his term of incarceration. The defense objected to that term, and we negotiated the
+language in paragraphs 3 and 5 that limit the agreement if the judge rejects the binding recommendation - in
+other words, if E got a higher sentence he could appeal and if he got a lesser sentence, our obligations would
+cease. The agreement also requires Epstein to use his best efforts to achieve the goals of the agreement. One of
+those (the plea and sentencing date) already has been moved. We need to be able to communicate with the
+State Attorney's Office and others (including, possibly, any attorney for the victims) to insure that Epstein is
+abiding by the terms of the agreement.
+Can you include these thoughts in your letter to Jay?
+Thank you much!
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 56l 209-1047
+Fax 56l 820-8777
+Tracking:
+2674
+P-014266
+
+
+To:
+Subject:
+Wednesday, October 24, 2007 4:57 PM
+Sloman, Jeff (USAFLS)
+RE: Epstein - Addendum and Letter to Judge |
+Thank you. Sorry to be a bother.
+From: Sloman, Jeff (USAFLS)
+Sent: Wed 10/24/2007 3:59 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: RE: Epstein - Addendum and Letter to Judge
+I'll communicate them to Judge
+Don't worry.
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Wednesday, October 24, 2007 3:58 PM
+To: Sloman, Jeff (USAFLS)
+Subject: RE: Epstein - Addendum and Letter to Judge
+Hi Jeff -- Why are the criteria gone? Will we be allowed to communicate those criteria directly to Judge
+? I don't
+want him to pick a sole practitioner who doesn't have the means or capacity to handle possibly contested lugation.
+From: Sloman, Jeff (USAFLS)
+Sent: Wed 10/24/2007 3:45 PM
+To: Jay Lefkowitz
+Ce: Villarana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS)
+Subject: Epstein - Addendum and Letter to Judge
+<<Addendum.wpd>> <<071015 Special Master Letter 4.wpd>>
+Jay,
+Pursuant to our conversation, here is the revised letter and a new addendum. The only change to the
+addendum is that I renumbered the new paragraphs from A,B, and C to 7A, 7B, and 7C. Once you approve, I
+will contact Judge
+and send him the letter. Please execute the addendum, PDF the executed original to
+me as soon as possible and Fed Ex the original to me thereafter.
+Jeff
+2681
+P-014267
+
+
+To:
+Subject:
+Sloman, Jeff (USAFLS)
+Wednesday. October 24, 2007 4:00 PM
+RE: Epstein - Addendum and Letter to Judge Davis
+I'll communicate them to Judge
+Don't worry.
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Wednesday, October 24, 2007 3:58 PM
+To: Sloman, Jeff (USAFLS)
+Subject: RE: Epstein - Addendum and Letter to Judge
+Hi Jeff -- Why are the criteria gone? Will we be allowed to communicate those criteria directly to Judge
+want him to pick a sole practitioner who doesn't have the means or capacity to handle possibly contestecrigation.
+From: Sloman, Jeff (USAFLS)
+Sent: Wed 10/24/2007 3:45 PM
+To: Jay Lefkowitz
+Cc: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (LISAFLS)
+Subject: Epstein - Addendum and Letter to Judge
+<<Addendum.wpd>> <<071015 Special Master Letter4.wpd>>
+Jay,
+Pursuant to our conversation, here is the revised letter and a new addendum. The only change to the
+addendum is that I renumbered the new paragraphs from A,B, and C to 7A, 7B, and 7C. Once you approve, I
+will contact Judge and send him the letter. Please execute the addendum, PDF the executed original to
+me as soon as possible and Fed Ex the original to me thereafter.
+Jeff
+2682
+P-014268
+
+
+To:
+Subject:
+Wednesday, October 24, 2007 3:58 PM
+Sloman, Jeff (USAFLS)
+RE: Epstein - Addendum and Letter to Judge
+Hi Jeff - Why are the criteria gone? Will we be allowed to communicate those criteria directly to Judge
+? I don't
+want him to pick a sole practitioner who doesn't have the means or capacity to handle possibly contestecritigation.
+From: Sloman, Jeff (USAFLS)
+Sent: Wed 10/24/2007 3:45 PM
+To: Jay Lefkowitz
+Cc: Villafana, Ann Marie C. (USAFLS); Acosta, Alex SAFLS)
+subject: Epstein - Addendum and Letter to Judae l
+<<Addendum.wpd>> <<071015 Special Master Letter4.wpd>>
+Jay,
+Pursuant to our conversation, here is the revised letter and a new addendum. The only change to the
+addendum is that I renumbered the new paragraphs from A,B, and C to 7A, 7B, and 7C. Once you approve, !
+will contact Judge
+and send him the letter. Please execute the addendum, PDF the executed original to
+me as soon as possible and Fed Ex the original to me thereafter.
+Jeff
+2683
+P-014269
+
+
+rom
+sent
+Го:
+Subject
+Wednesday, October 24, 2007 12:23 PM
+Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+RE: This has to stop.
+Alex and Jeff --
+I am free this afternoon at 5:00. Tomorrow I will be driving back to Florida, so 1 am free any time after 1:00, but I don'
+know how good the cellular reception will be. I can't believe that they have managed,to drag this out for almost fou
+weeks.
+Thanks.
+From: Acosta, Alex (USAFLS)
+Sent: Tue 10/23/2007 9:40 PM
+To: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS)
+Subject: This has to stop.
+Just read the letter.
+hi We specialty refused ag include thsingviose waying that we would not communicate. If recall the conference call, we told
+2. The purpose of the agreement was not an out of court settlement.
+Seems that they can't take no. Let's talk re how to proceed. I'm not sure we will ever agree on a letter at this point.
+Sent from my BlackBerry Wireless Handheld
+2685
+P-014270
+
+
+To:
+Subject:
+Acosta, Alex (USAFLS)
+Tuesday, October 23, 2007 9:40 PN
+/illafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS
+Just read the letter.
+1. We specifically refused to include the provision saying that we would not
+communicate. If I recall the conference call, we told him we could not agree to
+a gag order using those words.
+2. The purpose of the agreement was not an out of court settlement.
+Seems that they can't take no. Let's talk re how to proceed. I'm not sure we
+will ever agree on a letter at this point.
+------------
+Sent from my BlackBerry Wireless Handheld
+2686
+P-014271
+
+
+To:
+Subject:
+Tuesday, October 23, 2007 5:58 PM
+Sloman, Jeff (USAFLS)
+RE: Letter from Jay Lefkowitz
+Welcome to my world. I love the way that they want to interpret this agreement. First, during the negotiations, I
+repeatedly told Jay that we could not bind the girls to Epstein's desired out-of-court settlement strategy and, therefore, the
+agreement could not try to bind them in that way.
+The $50,000/$150,000 thing is a complete red herring, and Jay keeps calling it a "limit," when it is actually a floor, not a
+ceiling.
+It also looks like they are planning to ask for and receive a sentence far lower than the one we agreed to. Has
+anyone talked to Barry about this? Maybe this is the real reason for the delay in entering the guilty plea? We
+also have to contact the victims to tell me about the outcome of the case and to advise them that an attorney will
+be contacting them regarding possible claims against Mr. Epstein. If we don't do that, it may be a violation of
+the Florida Bar Rules for the selected attorney to "cold call" the girls.
+Their complaint about the 24-year-old concerns me only because their continued dragging out of this matter is
+possibly going to foreclose other girls. The language of the agreement with Epstein and the letter to Judge
+both refer to persons we have identified as victims as defined in 2255, it says nothing about whether the
+girls' claims are necessarily valid. I have no idea whether the girl who currently is 24 either wants to sue
+Epstein or has any viable state or other federal claims -- that is why we are TRYING to get them a lawyer. And
+they have always known that most of the girls are now over the age of 18 -- goodness -- the time period of the
+violations was from 2001 to 2005 and it is now the end of 2007!
+Why don't we agree to mutual recission and indict him?
+From: Sloman, Jeff (USAFLS)
+Sent: Tue 10/23/2007 5:13 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: FW: Letter from Jay Lefkowitz
+Wait to you see this one.
+From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com]
+Sent: Tuesday, October 23, 2007 4:57 PM
+To: Acosta, Alex (USAFLS)
+Cc: Sloman, Jeff (USAFLS)
+Subject: Letter from Jay Lefkowitz
+Dear Alex and Jeff.
+Here is my response to Jeff's email from late yesterday.
+Please let me know if you want to speak later this evening. I am also available any time tomorrow
+2687
+P-014272
+
+
+Thanks -- Jay
+************************
+***********
+****
+*********
+information contained in this communication is
+confidential,
+may be attorney-cllent privileged, may
+constitute inside information, and is intended only for
+the use of the addressee. It is the property of
+Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
+Unauthorized use, disclosure or copying of this
+communication or
+any part thereof is strictly prohibited
+and may be unlawful. If you have received this
+communication in error, please notify us immediately by
+return e-mail or by e-mail to postmaster@kirkland.com, and
+destroy this communication and all copies thereof,
+including all attachments.
+*************
+*********
+2688
+P-014273
+
+
+To:
+Subject:
+Attachments:
+Sloman, Jeff (USAFLS)
+Tuesday. October 23, 2007 5:13 PN
+FW: Letter from Jay Lefkowitz
+10-23-07 Letter from JPL to RAA.od
+Wait to you see this one.
+From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com]
+Sent: Tuesday, October 23, 2007 4:57 PM
+To: Acosta, Alex (USAFLS)
+Cc: Sloman, Jeff (USAFLS)
+Subject: Letter from Jay Lefkowitz
+Dear Alex and Jeff,
+Here is my response to Jeff's email from late yesterday.
+Please let me know if you want to speak later this evening. I am also available any time tomorrow.
+Thanks - Jay
+***********************
+********
+The information contained in this communication is
+confidential, may be attorney-client privileged, may
+constitute inside information, and is intended only for
+the use of the addressee. It is the property of
+Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
+Unauthorized use, disclosure or copying of this
+communication or any part thereof is strictly prohibited
+and may be unlawful. If you have received this
+communication in error, please notify us immediately by
+return e-mail or by e-mail to postmaster@kirkland.com, and
+destroy this communication and all copies thereof,
+including all
+attachments.
+****
+*********
+2689
+P-014274
+
+
+To:
+Subject:
+Monday, October 22, 2007 8:44 PM
+Sloman, Jeff (USAFLS)
+Epstein
+Hi Jeff - The number of girls that you should put in the letter is 34. That includes a couple of girls who FBI has
+not been able to locate (both are married and the FBI thinks they are living on military bases, but it hasn't been
+confirmed), but there are telephone records establishing how old they were and how often they went and
+statements from other girls who either recruited them or were recruited by them to go to Epstein's house. There
+also is one girl for whom there is similar evidence. She has been located by does not want to speak to the FBI
+because she has an active warrant on a shoplifting charge.
+One of the 34 is a girl who told the Palm Beach Police Department that she was over 18 at the time she went to
+Epstein's house, but the phone records show that she was 17 at the time.
+Also, so you know, when I told Bert Ocariz that the Office had decided to use a Special Master to make the
+selection, he asked who it was and I told him it was Judge
+I do not know if he has contacted Judge
+or not.
+Thank you for all your work on this and on the other matter. Have a good night.
+A. Marie Villafaña
+Assistant U.S. Attorney
+561 209-1047
+Fax 561 820-8777
+2690
+P-014275
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/a51660c44dc87cdea685a28461116d6903aedf567e016286c77e90a95cef5020.receipt.json b/vision-fixhub/ds9-unparsed-05/a51660c44dc87cdea685a28461116d6903aedf567e016286c77e90a95cef5020.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..09ab373c285201dc10f95197810d3598ca26f998
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a51660c44dc87cdea685a28461116d6903aedf567e016286c77e90a95cef5020.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -2003,
+  "dataset": "marble-joined",
+  "doc_id": "a51660c44dc87cdea685a28461116d6903aedf567e016286c77e90a95cef5020",
+  "engine": "marble-apple-vision",
+  "event_count": 27,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "d90f5d38d79da7b5e8039d2b380fc28df74816964d59626eb915eed14089ce07",
+  "output_sha256": "9a749e5c0341738e96c4548d6babf9c45f0fd071553efc540695c3e85c8dbbc1",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a545729f4aacbd5cbcaa343df12b6b6915083abfeb7b2de6a1e1d5032c999be1.md b/vision-fixhub/ds9-unparsed-05/a545729f4aacbd5cbcaa343df12b6b6915083abfeb7b2de6a1e1d5032c999be1.md
new file mode 100644
index 0000000000000000000000000000000000000000..3b890fa379ee24c86c18642150ef49334d02434f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a545729f4aacbd5cbcaa343df12b6b6915083abfeb7b2de6a1e1d5032c999be1.md
@@ -0,0 +1,98 @@
+. (USAFLS)
+To:
+Subject:
+- (FBI) <
+Thursday, December 04, 2008 5:03 PM
+(USAFLS)
+Re: Overseas Victim Notifications
+I rovd email from Bogota a few weeks ago that they had rovd letter and would be delivering it. Her address is correct. I will
+place a call to Austraila first thing in the AM. I'll update u then. B of America really giving employee grief for calling FBI but
+she is still working on SAR. This may have more to do with Atty Alan D and Br Sins than E. We should have it tomorrow.
+(USAFLS)
+To:
+Sent: Thu Dec 04 16:51:40 2008
+Subject: Overseas Victim Notifications
+Hi
+- Can you tell me whether the victim notifications to
+and
+ever made it to
+them? And did we get good addresses for them? I need to send the notifications of Epstein's release.
+Thanks.
+Assistant U.S. Attorney
+630
+P-015264
+
+
+(USAFLS)
+To:
+Subject:
+1. (FBI) <
+Thursday, December 04, 2008 5:05 PM
+- (USAFLS)
+Re: Overseas Victim Notifications
+Sure!
+(USAFLS)
+To:
+Sent: Thu Dec 04 17:05:25 2008
+Subject: RE: Overseas Victim Notifications
+Thanks. When you hear back from them, can you send me
+address and the info on
+Assistant U.S. Attorney
+- (FBI)
+Sent: Thursday, December 04, 2008 5:03 PM
+To:
+1. (USAFLS)
+Subject: Re: Overseas Victim Notifications
+I rovd email from Bogota a few weeks ago that they had rovd letter and would be delivering it. Her address is correct. I will
+place a call to Austraila first thing in the AM. I'll update u then. B of America really giving employee grief for calling FBI but
+she is still working on SAR. This may have more to do with Atty Alan D and Br Stns than E. We should have it tomorrow.
+(USAFLS)
+To:
+Sent: Thu Dec 04 16:51:40 2008
+Subject: Overseas Victim Notifications
+Hi
+- Can you tell me whether the victim notifications to
+and
+ever made it to
+them? And did we get good addresses for them? I need to send the notifications of Epstein's release.
+Thanks.
+Assistant U.S. Attorney
+631
+P-015265
+
+
+632
+P-015266
+
+
+(USAFLS)
+To:
+Subject:
+- (USAFLS) <
+Thursday, December 04, 2008 5:05 PM
+I. (MM) (FBI)
+RE: Overseas Victim Notifications
+Thanks. When you hear back from them, can you send me
+address and the info on
+Assistant U.S. Attorney
+(FBI)
+Sent: Thursday, December 04, 2008 5:03 PM
+To:
+• (USAFLS)
+Subject: Re: Overseas Victim Notifications
+I rovd email from Bogota a few weeks ago that they had rovd letter and would be delivering it. Her address is correct. I will
+place a call to Austraila first thing in the AM. I'll update u then. B of America really giving employee grief for calling FBI but
+she is still working on SAR. This may have more to do with Atty Alan D and Br Stns than E. We should have it tomorrow.
+(USAFLS)
+To:
+Sent: Thu Dec 04 16:51:40 2008
+Subject: Overseas Victim Notifications
+Hi
+- Can you tell me whether the victim notifications to
+and
+ever made it to
+them! And did we get good addresses for them? I need to send the notifications of Epstein's release.
+Thanks.
+Assistant U.S. Attorney
+633
+P-015267
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/a545729f4aacbd5cbcaa343df12b6b6915083abfeb7b2de6a1e1d5032c999be1.receipt.json b/vision-fixhub/ds9-unparsed-05/a545729f4aacbd5cbcaa343df12b6b6915083abfeb7b2de6a1e1d5032c999be1.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4a5677c95103f452ca4f2aea89802f2914365600
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a545729f4aacbd5cbcaa343df12b6b6915083abfeb7b2de6a1e1d5032c999be1.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -193,
+  "dataset": "marble-joined",
+  "doc_id": "a545729f4aacbd5cbcaa343df12b6b6915083abfeb7b2de6a1e1d5032c999be1",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "3b2eba61fec7010bb59aea68a442665a832dbd2f7f8301d9ee37313ff525a2c1",
+  "output_sha256": "d6453b3345ebfedad6e53dfb88a4dfd7ac81d219d0bdd0c5f93be5b37a1913b6",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a57d7972cbb41478e3f8529325d4d9791d6ab6ada3527a34726cc1ff84e99084.md b/vision-fixhub/ds9-unparsed-05/a57d7972cbb41478e3f8529325d4d9791d6ab6ada3527a34726cc1ff84e99084.md
new file mode 100644
index 0000000000000000000000000000000000000000..1eae9baf25867ac71d63c320fd8904759e29fe0e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a57d7972cbb41478e3f8529325d4d9791d6ab6ada3527a34726cc1ff84e99084.md
@@ -0,0 +1,66 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+West Palm Beach, FL 33401
+(561) 820-8711
+500 South Australian Ave., Suite 400
+Facsimile: (561) 820-8777
+March 27, 2007
+DELIVERY BY FACSIMILE
+Michael E. Dutko, Esq.
+Bogenschutz & Dutko
+600 S. Andrews Ave, Suite 500
+Fort Lauderdale, FL 33301-2802
+Re:
+Dear Mr. Dutko:
+I am writing to clarify the ground rules for the interview with your client,
+("your client"), to occur April 2, 2007.
+Ms.
+is not a target of this investigation, but instead is being interviewed as a
+victim/witness.
+However, to address any concern about criminal exposure, if your client
+complies with every provision of this agreement, then no testimony or other information
+provided by your client, or any information directly or indirectly derived therefrom, will be used
+by the United States Attorney's Office for the Southern District of Florida ("this Office") against
+your client in any criminal case, except a prosecution for perjury or giving a false statement.
+Your client agrees to be fully interviewed, that is, to provide information concerning your
+client's knowledge of, and participation in criminal activity, including but not limited to the
+procurement of prostitutes. The protection of this letter applies to an interview that will be
+conducted by this Office, Special Agents of the Federal Bureau of Investigation, and any other
+federal law enforcement agency this Office may require. The protection provided by this letter
+requires your client to provide information that is truthful, complete, and accurate.
+If your client gives materially false, incomplete, or misleading information, then this
+Office may use such information in any matter or proceeding and your client is subject to
+prosecution for perjury, obstruction of justice, and making false statements to government
+agencies. Any such prosecution may be based upon information provided by your client during
+the course of the interview, and such information, including your client's statements, Will be
+admissible against your client in any grand jury or other proceeding.
+This Office also may use statements made by your client in the interview and all evidence
+derived directly or indirectly therefrom for the purpose of impeachment or cross-examination if
+she testifies at any trial or hearing. This provision is necessary to ensure that your client does not
+make or offer any false representation or statement in any proceeding or to a government agency
+or commit perjury during any testimony.
+Your client further agrees that attorneys from this Office may be present at the interview,
+and agrees not to seck disqualification of any such attorney from any proceeding or trial because
+of their participation at the interview.
+The entire agreement between this Office and your client is set forth in this letter. No
+additional promises, agreements, or conditions have been entered into and none will be entered
+into unless in writing and signed by all parties.
+If the foregoing accurately reflects the understanding and agreement between this Office
+and your client, it is requested that you and your client execute this letter as provided below.
+Sincerely,
+
+
+R. Alexander Acosta
+United States Attorney
+By:
+Assistant United States Attorney
+I have received this letter from my attorney, Michael E. Dutko, Esquire, have read it and
+discussed it with my attorney, and I hereby acknowledge that it fully sets forth my understanding
+and agreement with the Office of the United States Attorney for the Southern District of Florida.
+I state that there have been no additional promises or representations
+made to me by any official of the United States Government or by my attorney in connection with this
+matter.
+Dated:
+Witnessed by:
+Michael E. Dutko, Esquire
diff --git a/vision-fixhub/ds9-unparsed-05/a57d7972cbb41478e3f8529325d4d9791d6ab6ada3527a34726cc1ff84e99084.receipt.json b/vision-fixhub/ds9-unparsed-05/a57d7972cbb41478e3f8529325d4d9791d6ab6ada3527a34726cc1ff84e99084.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..dcd2cb81b4dd1b8aacbda98a6b7f1d121566ed2d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a57d7972cbb41478e3f8529325d4d9791d6ab6ada3527a34726cc1ff84e99084.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "a57d7972cbb41478e3f8529325d4d9791d6ab6ada3527a34726cc1ff84e99084",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "8225e7b10ee4eae38d272d1f1428c73d7b0176d1cd9ce35dc74555c2dc583e6d",
+  "output_sha256": "6e99b0f55f90a812b4c47b2f1a14bfe17843b6bad45593f57a9d55d166cee79f",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a5f3afb19be8d038577d602cdc68aa577eaa11775ddc0e7d72e46e447eb05bdf.md b/vision-fixhub/ds9-unparsed-05/a5f3afb19be8d038577d602cdc68aa577eaa11775ddc0e7d72e46e447eb05bdf.md
new file mode 100644
index 0000000000000000000000000000000000000000..672db2b7f327257b1f08017c33874021285554bf
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a5f3afb19be8d038577d602cdc68aa577eaa11775ddc0e7d72e46e447eb05bdf.md
@@ -0,0 +1,353 @@
+99 N.E. 4* Street
+Miami, FL 33132-2111
+Facsimile:
+December 6, 2007
+DELIVERY BY FACSIMILE
+Jay P. Lefkowitz, Esq.
+Kirkland & Ellis LLP
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4675
+Re:
+Jeffrey Epstein
+Dear Jay:
+I write in response to your recent e-mails and letters regarding victim notification and other
+issues. Our Office is trying to perform our contractual obligations under the Agreement, which we
+feel are being frustrated by defense counsel's objections. The Office also is concerned about Mr.
+Epstein's nonperformance.
+More than three weeks ago we spoke about the failure to set a timely plea and sentencing
+date. At that time, you assured me that the scheduling delay was caused by the unavailability of
+Judge MeSorley. You promised that a date would be set promptly. On November 15th, Rolando
+Garcia met with Barry Krisher on another matter, and was told by Mr. Krisher that he had just
+spoken with Jack Goldberger, and that Mr. Epstein's plea and sentencing were set to occur on
+December 14, 2007. Since that time, we have tried to confirm the date and time of the hearing in
+order to include that information in the victim notification letters. You continue to refer to the plea
+and sentencing as though it will be in January; Mr. Krisher's office has not confirmed any date; and
+Mr. Goldberger recently told
+that "there is no date."
+I must reiterate that a delayed guilty plea and sentencing - now more than two months
+beyond the original deadline - is unacceptable to the Office. As you will recall, the plea and
+sentençing hearing originally was to occur in early October 2007, but was delayed until October 26th
+to allow Mr. Goldberger to attend. It was delayed again until November to allow you to attend.
+Rather than using your best efforts to insure that the plea and sentencing occur in November, we
+recently learned that a plea conference had been scheduled with Judge MeSorley for November 20,
+2007, but was canceled at the request of the parties, not the judge. Judge MeSorley has not been
+away for any extended period, and there is no basis for your assertion that the judge is the cause of
+ExhibitB- 12
+
+
+
+any past or future delay. Mr. Epstein currently has four Florida Bar members on his defense team,
+so attorney scheduling is not an adequate basis for delay.
+Three weeks ago I also asked you to provide our Office with the terms of the Plea Agreement
+with the State Attorney's Office. It is now more than two months since the signing of the Non-
+Prosecution Agreement and we have yet to see any formal agreement, or even a list of essential terms
+of such an agreement.
+Next, let me address your allegation that attorneys in our office and agents of the FBI have
+leaked information to the press in an effort to affect possible civil litigation with Mr. Epstein. This
+is untrue. There has been no contact between any member of the press and any employee of our
+office or the FBI since you incorrectly accused investigators of telling "Vanity Fair" about Mr.
+Starr's employment by Mr. Epstein several months ago. We intend to continue to refrain from
+commenting or providing information to the press. We would ask that your client and all of his
+representatives do the same.
+I also want to address your interpretation of several statements that were included in
+correspondence - at your insistence - as proof that the designated victims have invalid claims. Let
+me make clear that each of the listed individuals are persons whom the Office identified as victims
+as defined in Section 2255, that is, as persons "who, while a minor, was a victim of a violation of
+section... 2422 or 2423 of this title." In other words, the Office is prepared to indict Mr. Epstein
+based upon Mr. Epstein's "interactions" with these individuals.' This conclusion is based upon a
+thorough and proper investigation - one in which none of the victims was informed of any right to
+receive damages of any amount prior to the investigation of her claim. The Office agrees that it is
+not a party to, and will not take a role in, any civil litigation, but the Office can say, without
+hesitation, that the evidence demonstrates that each person on the list was a victim of Mr. Epstein's
+criminal behavior. Mr. Starr's letter also suggests that the number of victims to whom Mr. Epstein
+is exposed by the Agreement is limitless. As you know, early drafts of the Agreement contained a
+numerical limit of 40 victims, which was removed at your request. The Office repeatedly confirmed
+that the number would not exceed 40; and the list is significantly shorter than that. Once the list is
+provided to you, if you have a good faith basis for asserting that a victim never met Mr. Epstein, we
+remain willing to listen and to modify the list if you convince us of your position.
+Finally, let me address your objections to the draft Victim Notification Letter. You write that
+you don't understand the basis for the Office's belief that it is appropriate to notify the victims.
+Pursuant to the "Justice for All Act of 2004," crime victims are entitled to: "The right to reasonable,
+accurate, and timely notice of any public court proceeding ... involving the crime" and the "right
+'Unlike the State's investigation, the federal investigation shows criminal conduct by Mr.
+Epstein at least as early as 2001, so all of the victims were minors at the time of the offense.
+RFP MIA 000018
+
+
+
+not to be excluded from any such public court proceeding .. " 18 U.S.C. § 3771(a)(2) & (3).
+Section 3771 also commands that "employees of the Department of Justice... engaged in the
+detection, investigation, or prosecution of crime shall make their best efforts to see that crime victims
+are notified of, and accorded, the rights described in subsection (a)." 18 U.S.C. § 3771(c)(1).
+Additionally, pursuant to the Victims' Rights and Restitution Act of 1990, our Office is
+obligated to "inform a victim of any restitution or other relief to which the victim may be entitled
+under this or any other law and [the] manner in which such relief may be obtained." 42 U.S.C. §
+10607(c)(1)(B). With respect to notification of the other information that we propose to disclose,
+the statute requires that we provide a victim with the earliest possible notice of: the status of the
+investigation; the filing of charges against a suspected offender; and the acceptance of a plea. 42
+U.S.C. § 10607(c)(3). Just as in 18 U.S.C. § 3771, these sections are not limited to proçeedings in
+a federal district court. Our Non-Prosecution Agreement resolves the federal investigation by
+allowing Mr. Epstein to plead to a state offense. The victims identified through the federal
+investigation should be appropriately informed, and our Non-Prosecution Agreement does not
+require the U.S. Attorney's Office to forego its legal obligations.
+With respect to your assertion that we are seeking to "federalize" the state plea, our office
+is simply informing the victims of their rights. It does not command them to appear at the hearing
+or to file a victim impact statement. In fact, the letter recommends the sending of any statement to
+the State Attorney's Office so that
+can determine which, if any, statements are
+appropriate to file with the Court.
+Next, you assert that our letter mischaracterizes Mr. Epstein's obligation to pay damages to
+the victims. To avoid that suggestion, 1 have asked AUSA
+to simply quote the terms of
+the Agreement directly into the Notification Letter. We also have no objection to referring to Mr.
+Epstein as a "sexual offender" rather than a "predator."
+We have no objection to using the conjunction "and/or" in referring to the particular
+offense(s) of which the recipient was a victim. We will not include the language that we take no
+position as to the validity of any claims. While the Office has no intention to take any position in
+any civil litigation arising between Mr. Epstein and any individual victim, as stated above, the Office
+believes that it has proof beyond a reasonable doubt that each listed individual was a victim of Mr.
+Epstein's criminal conduct while the victim was a minor. The law requires us to treat all victims
+"with fairness and with respect for the victim's dignity and privacy." 18 U.S.C. § 3771(a)(8). We
+will not include any language that demeans the harm they may have suffered.
+The letter's assertions regarding representation by the Podhurst firm and Mr. Josefsberg are
+accurate. Judge Davis conferred with Messrs. Podhurst and Josefsberg to insure their willingness
+to undertake this assignment prior to finalizing his selection.
+RFP MIA 000019
+
+
+
+Lastly, you object to personal communication between the victims and federal attorneys or
+agents. We have no objection to sending the letters through the mail but we will not remove the
+language about contacting AUSA
+or Special Agent
+with questions or
+concerns. Again, federal law requires that victims have the "reasonable right to confer with the
+attorney for the Government in this case." 18 U.S.C. § 3771(a)(5). The three victims who were
+notified prior to your objection had questions directed to Mr. Epstein's punishment, not the civil
+litigation. Those questions are appropriately directed to law enforcement. If questions arise related
+to the civil litigation, AUSA
+and Special Agent
+will recommend that the
+victims direct those questions to Mr. Josefsberg.
+I have attached a revised letter incorporating the changes on which we can agree. Please
+provide any further comments by the close of business on Friday. In addition, please provide us with
+a definitive statement, signed by your client, of his intention to abide by each and every term of the
+Agreement by close of business on Friday, December 7, 2007. By that time, you must also provide
+us with the agreements) with the State Attorney's Office and a date and time certain for the plea and
+sentencing, which must occur no later than December 14, 2007. There must be closure in this
+matter.
+Sincerely,
+R. Alexander Acosta
+By:
+First Assistant United States Attorney
+Enclosure
+cc:
+R. Alexander Acosta, U.S. Attorney
+AUSA |
+"This is contingent, however, on being able to provide adequate notice of the change of
+plea and spiencing. The ero If your you firedes, wea i have tie ly atehone personat
+REP MIA 000020
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+December 6, 2007
+DELIVERY BY UNITED STATES MAIL
+Miss
+Re:
+Crime Victims' Rights - Notification of Resolution of Epstein Investigation
+Dear Miss
+Several months ago, 1 provided you with a letter notifying you of your rights as a
+victim pursuant to the Justice for All Act of 2004 and other federal legislation, including:
+(1)
+(2)
+(3)
+roceeding involving the crime or of any release or escape of the accused
+The right not to be excluded from any public court proceeding, unless the cour
+(4)
+(5)
+The reasonable right to confer with the attorney for the United States in the
+case.
+(6)
+The right to full and timely restitution as provided in law.
+(7) The right to proceedings free from unreasonable delay.
+(8)
+The right to be treated with fairness and with respect for the victim's dignity
+and privacy.
+1 am writing to inform you that the federal investigation of Jeffrey Epstein has been
+completed, and that Mr. Epstein and the U.S. Attorney's Office have reached an agreement
+containing the following terms.
+RFP MIA 000021
+
+
+MIss
+PAGE 2
+First, Mr. Epstein agrees that he will plead guilty to two state offenses, including the
+offense of soliciting minors to engage in prostitution, which will require him to register as
+a sexual offender for the remainder of his life.
+Second, Mr. Epstein has agreed to make a binding recommendation of 18 months'
+imprisonment to the state court judge who sentences him. Mr. Epstein will serve that
+sentence of imprisonment at the Palm Beach County Jail.
+Third, Mr. Epstein has agreed that he will compensate you for damages you hav
+hofered, under the following circumstances. That portion of the agreement that relates tr
+The United States shall provide Epstein's attorneys with a list of
+individuals whom it has identified as victims, as defined in 18 U.S.C.
+§ 2255, after Epstein has signed this agreement and been sentenced.
+Upon the execution of this agreement, the United States, in consultation
+with and subject to the good faith approval of Epstein's counsel, shall
+select an attorney representative for these persons, who shall be paid for
+by Epstein. Epstein's counsel may contact the identified individuals
+through that representative.
+If any of the individuals referred to in paragraph (?), supra, elects to
+file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the
+jurisdiction of the United States District Court for the Southern District
+of Florida over his person and/or the subject matter, and Epstein waives
+his right to contest liability and also waives his right to contest damages
+up to an amount as agreed to between the identified individual and
+Epstein, so long as the identified individual elects to proceed
+exclusively under 18 U.S.C. § 2255, and agrees to waive any other
+claim for damages, whether pursuant to state, federal, or common law.
+Notwithstanding this waiver, as to those individuals whose names
+appear on the list provided by the United States, Epstein's signature on
+this agreement, his waivers and failures to contest liability and such
+damages in any suit are not to be construed as an admission of any
+criminal or civil liability.
+9.
+Epstein's signature on this agreement also is not to be construed as an
+admission of civil or criminal liability or a waiver of any jurisdictional
+RFP MIA 000022
+
+
+MISS
+PAGE 3
+10.
+or other defense as to any person whose name does not appear on the
+list provided by the United States.
+Except as to those individuals who elect to proceed exclusively under
+18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's
+defense as to any person, whether or not her name appears on the list
+provided by the United States.
+Pursuant to the terms of the agreement and an addendum, to assist you in making such
+a claim, the U.S. Attorney's Office has asked an independent Special Master to select
+attorneys to represent you. Those attorneys are Aaron Podhurst and Robert ("Bob")
+Josefsberg with the law firm of Podhurst Orseck, P.A. They can be reached at
+. I anticipate that someone from their law firm will be contacting you shortly. I must
+also advise you that you are not obligated to use these attorneys. In fact, you have the
+absolute right to select your own attorney, so you can decide not to speak with Messis.
+Podhurst/Josefsberg at all, or you can speak with them and decide at any time to use a
+different attorney. If you do decide to seek damages from Mr. Epstein and you decide to use
+Messrs. Podhurst/Josefsberg as your attorneys, Mr. Epstein will be responsible for paying
+attorney's fees incurred during the time spent trying to negotiate a settlement. If you are
+unable to reach a settlement with Mr. Epstein, you and Mr. Josefsberg can discuss how best
+to proceed.
+As 1 mentioned above, as part of the resolution of the federal investigation, Mr.
+Epstein has agreed to plead guilty to state charges. Mr. Epstein's change of plea and
+sentencing will occur on December 14, 2007, at
+_ a.m., before Judge Sandra K.
+McSorley, in Courtroom 11F at the Palm Beach County Courthouse, 205 North Dixie
+Highway, West Palm Beach, Florida. Pursuant to Florida Statutes Sections 960.001(1)(k)
+and 921.143(1), you are entitled to be present and to make a statement under oath. If you
+choose, you can submit a written statement under oath, which may be filed by the State
+Attorney's Office on your behalf. If you elect to prepare a written statement, it should
+address the following:
+the facts of the case and the extent of any harm, including social,
+psychological, or physical harm, financial losses, loss of earnings directly or
+indirectly resulting from the crime for which the defendant is being sentenced,
+RFP MIA 000023
+
+
+MISS
+PAGE 4
+and any matter relevant to an appropriate disposition and sentence. Fl. Stat.
+921.143(2).
+You also are entitled to notification when Mr. Epstein is released from imprisonment
+at the end of his prison term and/or if he is allowed to participate in a work release program.
+To receive such notification, please provide the State Attorney's Office with the following
+information:
+1.
+2.
+3.
+4.
+5.
+Your name
+Your address
+Your home, work, and/or cell phone numbers
+Your e-mail address
+A notation of whether you would like to participate in the "VINE system,"
+which provides automated notification calls any time an inmate is moved. (To
+use this system, your calls must go to you directly, not through a switchboard.)
+Thank you for all of your help during the course of the investigation. If you have any
+questions or concerns, please do not hesitate to contact me or Special Agent
+at
+Sincerely,
+R. Alexander Acosta
+By:
+Assistant United States Attorney
+cc:
+Special Agent
+, F.B.I.
+Victim-Witness Coordinator, U.S. Attorney's Office
+RFP MIA 000024
+
+
+12/08/07- THU 15:25 FAX
+EXECUTIVE OFPICE
+********************
+**•
+TX REPORT
+..
+@001
+TRANSMISSION OK
+TX/RX NO
+CONNECTION TEL
+SUBADDRESS
+CONNECTION ID
+ST. TIME
+USAGE T
+PGS.
+RESULT
+3413
+12/08 15:22
+03'18
+UNITED STATES ATTORNEY'S OFFICE
+SOUTHERN DISTRICT OF FLORIDA
+99 NE 4TH STREET
+MIAMI, FLORIDA 33132-2111
+First Assistant U.S. Attorney
+Staff Assistant
+fax
+FACSIMILE TRANSMISSION
+COVER SHEET
+DATE: December 6, 2007
+TO:
+Jay Lefkowitz, Esquire
+FAX NUMBER:
+SUBJECT: Epstein
+NUMBER OF PAGES, INCLUDING THIS PAGE: 9
+Case No. 08-80736-CV-MARRA
+P-009124
+
+
+UNITED STATES ATTORNEY'S OFFICE
+SOUTHERN DISTRICT OF FLORIDA
+99 NE 4™ STREET
+MIAMI, FLORIDA 33132-2111
+First Assistant U.S. Attorney
+Staff Assistant
+fax
+FACSIMILE TRANSMISSION
+COVER SHEET
+DATE:
+December 6, 2007
+TO:
+Jay Lefkowitz, Esquire
+FAX NUMBER:
+SUBJECT:
+Epstein
+NUMBER OF PAGES, INCLUDING THIS PAGE: 9
+Message/Comments:
+(Includes Victim Notification Letter)
+Case No. 08-80736-CV-MARRA
+P-009125
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/a5f3afb19be8d038577d602cdc68aa577eaa11775ddc0e7d72e46e447eb05bdf.receipt.json b/vision-fixhub/ds9-unparsed-05/a5f3afb19be8d038577d602cdc68aa577eaa11775ddc0e7d72e46e447eb05bdf.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..841961e648c765f21e053f90842acec5dc5833ad
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a5f3afb19be8d038577d602cdc68aa577eaa11775ddc0e7d72e46e447eb05bdf.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -690,
+  "dataset": "marble-joined",
+  "doc_id": "a5f3afb19be8d038577d602cdc68aa577eaa11775ddc0e7d72e46e447eb05bdf",
+  "engine": "marble-apple-vision",
+  "event_count": 14,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "f9344b84ba1ee0bd549ab2d80541fc1bb1fcafa74f8c0c4d81a014fa5250b5d2",
+  "output_sha256": "c319d82865a306e12c2b28ba61a365470b5c33614ce2beab89c45ac95ca86bb0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a62fc6803040aaffbc928e158097b2506bb38c0b521c85ef30cf0b38e4cb6274.md b/vision-fixhub/ds9-unparsed-05/a62fc6803040aaffbc928e158097b2506bb38c0b521c85ef30cf0b38e4cb6274.md
new file mode 100644
index 0000000000000000000000000000000000000000..11926fd056593dd630f539cd3694f31916b9e69c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a62fc6803040aaffbc928e158097b2506bb38c0b521c85ef30cf0b38e4cb6274.md
@@ -0,0 +1,51 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+West Palm Beach, FL 33401
+(561) 820-8711
+500 South Australian Ave., Suite 400
+Facsimile: (561) 820-8777
+July 10, 2008
+VIA CERTIFIED MAIL
+Jack A. Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+One Clearlake Centre, Suite 1400
+250 Australian Ave S.
+West Palm Beach, FL 33401-5015
+Re: Jeffrey Epstein
+Dear Mr. Goldberger:
+FINAL NOTIFICATION OF IDENTIFIED VICTIMS
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea of
+guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and
+796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for
+Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-009381AXXXMB) and
+was sentenced to a term of twelve months' imprisonment to be followed by an additional six
+months' imprisonment, followed by twelve months of Community Control 1, with conditions of
+community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to defer
+federal prosecution in favor of this state plea and sentence, subject to certain conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same rights
+to proceed under Section 2255 as she would have had, if Mr. Epstein had been tried
+federally and convicted of an enumerated offense. For purposes of implementing
+this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of
+individuals whom it was prepared to name in an Indictment as victims of an
+enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining which evidentiary burdens if any a
+plaintiff must meet, shall consider that it is the intent of the parties to place these
+identified victims in the same position as they would have been had Mr. Epstein
+been convicted at trial. No more; no less."
+Through this letter, this Office hereby provides Notice that the individuals identified
+below are individuals whom the United States was prepared to name as victims of an enumerated
+offense.
+Identified Individuals
+
+
+cc:
+Sincerely,
+R. Alexander Acosta
+United States Attorney
+By:
+Assistant United States Attorney
+AUSA
diff --git a/vision-fixhub/ds9-unparsed-05/a62fc6803040aaffbc928e158097b2506bb38c0b521c85ef30cf0b38e4cb6274.receipt.json b/vision-fixhub/ds9-unparsed-05/a62fc6803040aaffbc928e158097b2506bb38c0b521c85ef30cf0b38e4cb6274.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4f6a463575d89f45b84e82007be48df98daefba9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a62fc6803040aaffbc928e158097b2506bb38c0b521c85ef30cf0b38e4cb6274.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "a62fc6803040aaffbc928e158097b2506bb38c0b521c85ef30cf0b38e4cb6274",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "0038ff5dce296601db7b56242a4175b8582a2a9c1a5b5b493be423831888c107",
+  "output_sha256": "f272d0140041d80648fac131fb3d97b9599fccb93531763364fee89504a77300",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a769909450db0221266d267fdcdcbbc676d8db96de1bd5428028213cb5f91eac.md b/vision-fixhub/ds9-unparsed-05/a769909450db0221266d267fdcdcbbc676d8db96de1bd5428028213cb5f91eac.md
new file mode 100644
index 0000000000000000000000000000000000000000..41280e3b1adae8fe8e5bc5ba8d3c6dc00402220d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a769909450db0221266d267fdcdcbbc676d8db96de1bd5428028213cb5f91eac.md
@@ -0,0 +1,8063 @@
+Page 81
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE No.08-CV-80119-CIV-MARRA/JOHNSQN
+JANE DOE NO. 2,
+Plaintiff,
+-VS-
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+8-80232, 08-80380, 98-80381, 08-80994,
+08-80993, 08-80811,
+08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+VIDEOTAPED DEPOSITION OF JUAN ALESSI
+VOLUME II
+Tuesday, September 8, 2009
+10:12 a.m. - 3:45 p.m.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33401
+Reported By:
+sandra W. Townsend, FPR
+Notary Public, State of Florida
+PROSE COURT REPORTING AGENCY
+West Palm Beach Office
+lectronically signed by Sandra Townsend (401-
+lectronically signed by Sandra Townsend (401-
+
+
+Page 82
+1
+2
+3
+4
+5
+APPEARANCES:
+On behalf of the Plaintiffs:
+RICHARD WILLITS,
+ESQUIRE
+RICHARD H. WILLITS, P.A.
+2290 10th Avenue North, Suite 404
+Lake Worth, Florida
+33461
+Phone:
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+STUART MERMELSTEIN, ESQUIRE
+MERMELSTEIN & HOROWITZ, P.A.
+18205 Biscayne Boulevard, Suite 2218
+Miami, Florida
+33160
+Phone:
+WILLIAM J. BERGER, ESQUIRE
+ROTHSTEIN ROSENFELDT ADLER
+401 East Las Olas Boulevard, Suite 1650
+Fort Lauderdale, Florida 33301
+Phone:
+KATHERINE W. EZELL, ESQUIRE
+PODHURST ORSECK, P.A.
+25 West Flagler Street,
+Suite 800
+Miami, Florida 33130
+Phone:
+ADAM J. LANGINO, ESQUIRE
+LEOPOLD KUVIN
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, Florida 33410
+Phone:
+Electrenical signed by Sandra Townsend (4074
+
+
+Page 83
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+On behalf of the Defendant:
+ROBERT J. CRITTON, ESQUIRE
+BURMAN, CRITTON
+LUTTIER
+515 North Flagler Drive, Suite 400
+West Palm Beach, Florida
+33401
+Phone:
+Electronicaly signed by Sandra Townsend (401 l
+
+
+Page 84
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+PROCEEDINGS
+--
+Deposition taken before Sandra W. Townsend, Court
+Reporter and Notary Public in and for the State of
+Florida at Large, in the above cause.
+-
+-
+(Continued from Volume I.)
+VIDEOGRAPHER: We're going back on the record
+at 12:52.
+CROSS EXAMINATION
+BY MR. LANGINO:
+Hello. My name is Adam Langino and I
+represent
+I'll have fewer questions than the rest
+of everybody, since I'm going next in line. But one of
+the things I wanted to ask you --
+MR. CRITTON: Before you get started, let me
+just put on my objection.
+Adam, your client is
+., who alleges that
+she was at Mr. Epstein's house sometime, I think,
+on one occasion in the summer of '03.
+This witness is neither relevant, nor
+material, nor can
+it lead to the admissibility of
+any relevant information regarding my client. So I
+understand -- so you certainly can notice him, but
+I'll move to strike all of the questions and
+
+
+Page 85
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+answers in response to your questions.
+MR. LANGINO: Thank you.
+BY MR. LANGINO:
+Q. One thing I wasn't sure about was the date of
+your employment. When did you start with Mr. Epstein?
+A. I am not sure, sir, but I think I started full
+time on my salary, I was on the roll in 1991.
+1991,
+January 1, 1991.
+In 1991, you started full time with
+Mr. Epstein?
+A. Yes, working for him alone. I left all my
+clients, I left -- dissolved my company.
+e.
+And in what year did you start part time at
+his house?
+A. 1990. 190.
+You mentioned earlier that some of the massage
+therapists you paid with checks?
+A. Yes.
+2. And some of the massage therapists you paid
+with cash?
+A.
+Sorry. Can you repeat the question?
+e.
+Sure. You mentioned earlier that you paid
+some of the massage therapists with checks and some with
+cash?
+A. Yes, sir.
+Electronicaly signed by Sandra Towns 1401 L
+Jafc3ca0-c86e-4b9f-8d01-ba20bcae87de
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 86
+l. Were there any general differences between
+those massage therapists that you paid with checks and
+those that you paid with cash?
+A. No, sir. It was -- when I was there always
+was a hundred dollars an hour rate. That was for
+everybody.
+Q. Did you ever hear Jeffrey Epstein talk about
+his massages?
+A.
+No, sir.
+l. At one point you said that you're not -- this
+might be summarizing your testimony -- that you may not
+be the best guesser of ages. Is that something that you
+may have said earlier today?
+MR. CRITTON: Form.
+THE WITNESS: Yeah. Yeah. I think I -- you
+can be thirties, twenties. I don't know.
+BY MR. LANGINO:
+e. Do you have any children?
+A. I have two. One is a doctor in psychology.
+And one is a financial manager and he starts his own
+company.
+Are either of your children female?
+A.
+e.
+No.
+Do you have any grandchildren?
+A. I have one granddaughter.
+Electronicaly signed by Sandra Townsen (401)
+
+
+Page 87
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+l. How old is she?
+A. She is five.
+e. Do you have any relative that you had spent a
+significant amount of time with that would be a female
+teenager?
+BY MR. LANGINO:
+MR. CRITTON: Form.
+THE WITNESS: No, except my daughter.
+Cousin?
+A.
+My daughter, no.
+l. Before when we first started speaking with
+you, you talked a little bit about your business. Are
+you still working?
+A.
+No. I disabled.
+You owned that business; is that correct?
+Yeah. Yeah. It was my -- my - it was me,
+A.
+only me.
+You mentioned that one of your children is a
+doctor?
+A.
+My daughter is a doctor in psychology.
+e.
+Are any of your children or any of your family
+members continuing the business that you started?
+A.
+No. They have their own business.
+You mentioned a few times today that you were
+never told to check the identification of any of the
+
+
+Page 88
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+massage therapists that came to give massages?
+A. That's correct.
+2. How come you said that a couple of times
+today?
+MR. CRITTON: Form.
+THE WITNESS: You asked me. They asked me.
+I
+think I just answer questions.
+BY MR. LANGINO:
+l. As you reflect back in your time working for
+Mr. Epstein, today do you believe you turned a blind eye
+to some of the ages of the women or females that worked
+for Jeffrey Epstein with massages?
+MR. CRITTON: Form.
+THE WITNESS: Can you repeat the question?
+BY MR. LANGINO:
+Q. Sure. As you sit here today and reflect back
+on your time working for Jeffrey Epstein, do you believe
+you turned a blind eye or ignored, purposely ignored the
+ages of the females that gave him massages?
+MR. CRITTON: Form.
+THE WITNESS: I don't know. I don't -- I
+cannot -- I'm not a judge. I don't know. I don't
+know. I don't think so. Sincerely, I don't think
+So.
+BY MR. LANGINO:
+
+
+1
+2
+3
+Page 89
+e. When you were working for Mr. Epstein, did you
+have any doubt that the girls who provided him massages
+were not of the proper age or not older than 18 years
+old?
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR. CRITTON: Form.
+THE WITNESS: No.
+BY MR. LANGINO:
+e. Did you keep up with Mr. Epstein's -- keep
+informed of Mr. Epstein's criminal case while it was in
+the paper?
+A. Only what was on tv. What it was on tv,
+that's how I found out.
+How do you feel about Mr. Epstein today?
+A. I feel bad, sincerely I feel bad, because he
+was - with me, with my family, with my wife, he was a
+very generous guy, extremely -- I don't know what the
+word is in English -- but he would press for perfection.
+I mean, and that was a very stressful job. But,
+otherwise, I have no problems with him at all. And I
+Ieel bad about it, what's happened in his life.
+Have you had any contact with Mr. Epstein
+after you ended working there?
+A. After I work -- after I end working with him?
+Yes, I did.
+When this case, when this criminal case
+Electronical signed by Sandra Townson 1(401-
+Зafc3ca0-c86e-4b9f-Bd01-ba20bcae87de
+
+
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 90
+started, I got home and I had a card, a business card
+from a police officer. I think it was Paul from the
+Palm Beach Police Department.
+And -- and I got scared. And I was trying to
+find out what it's all about. Because it was an
+occasion with Mr. Epstein that we had a disagreement.
+We settled that. Everything was well and we went our
+friendly ways and never heard from him again.
+And I received this from the police department
+that we need to talk to you. And, so, I got scared.
+And I called the office in New York.
+I says, I would like to speak to Mr. Epstein.
+And he come on, and I said, I told him, I
+says, Jeffrey, what's going on? What's happening? I
+thought it was related to the problem that I had
+personally with him settled.
+And I says -- no, he says. And he says to me,
+no, John, it's nothing to do with that, has nothing to
+do with it. I've been -- I don't know if he told me I
+been sued or I been -- it's a problem with me, they're
+investigating something and I cannot talk to you. That
+was the end. And that's it.
+Any other conversations with Mr. Epstein --
+A.
+No.
+e.
+-- since that conversation?
+Electronicaly signed by Sandra Townsend (401-
+
+
+Page 91
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A. No.
+Q. At some points you were caught stealing from
+Mr. Epstein; is that true?
+A. We settled with him as a borrowing money from
+him. Okay?
+MR. BERGER: As what?
+THE WITNESS: Borrowing.
+MR. LANGINO: Borrowing.
+BY MR. LANGINO:
+e.
+A. Yes, sir.
+When you took the money from Mr. Epstein, -
+-- did he give you permission to take that
+money?
+A.
+No.
+l. At any point did you take a firearm from
+Mr. Epstein?
+A. No.
+l. At any point did you enter Mr. Epstein's
+property when you were not allowed to be there?
+A.
+Yes.
+l. And was that the incident where you took some
+money from him?
+A.
+Yes.
+e. Can you explain to me how you and Mr. Epstein
+came to an agreement that the cops would not be called?
+Electronicaly signed by Sandra Townsend 1401
+
+
+Page 92
+A.
+He called me and he say, John, we need to
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+talk.
+I says, okay. Where?
+And -- and we met at a luncheonette in Palm
+Beach and we have a friendly conversation. He asked
+about my kids, about my family.
+Then -- is this related to Mr. Epstein's case?
+It is.
+A.
+Because I prefer to keep this -- this -- I was
+not incriminated. I was not -- I went to the police
+department. I made my statement and there was no
+charges filed.
+I don't think I would like to continue with
+this.
+MR. CRITTON: Let me just put on the record as
+I think it's completely irrelevant, immaterial,
+it's not calculated to lead to the --
+THE WITNESS: And it was after --
+MR. CRITTON: Let me just finish putting my
+objection on.
+As I understand it, it occurred long before he
+ever got the card from the police. I think you're
+harassing him. I think you're trying to intimidate
+him and I think it's inappropriate.
+BY MR. LANGINO:
+Electronicaly signed by Sandra Towind 401-
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+20
+21
+22
+23
+24
+25
+Page 93
+How did you feel about Mr. Epstein being loyal
+to you as an employee for him by not getting you into
+further trouble with the police?
+MR. CRITTON: Form.
+THE WITNESS: I feel that it was part of a
+relationship over 13 years that I did a lot of
+extra work. And I was more or less says, hey,
+John, you did it for me, I do it for you. And that
+was it. And we end up as friends.
+We did not
+break it apart.
+BY MR. LANGINO:
+As you sit here today, do you have a sense of
+personal loyalty to Mr. Epstein?
+A. No. No. Matter of fact, that job has left me
+a lot of sequels, psychological problems. It was
+extremely damaging to my marriage. Right after I left
+we broke up with my wife.
+I walk away. I left my
+house. I left my family. I end up with a woman that
+she need the money and that's why I went in there and
+got the money.
+And that's what I think you wanted to hear.
+And I want to end it there.
+I have no -- nothing -- I think my stay there,
+in reflecting the job, I was not paid well enough for
+what we did. And too late now.
+Erectronical aligned by Sandra Townsend 401)
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+211
+22
+23
+24
+25
+Page 94
+e. The overall theme of my question is: The fact
+that Mr. Epstein chose not to get you in trouble with
+the police further, trouble with the police --
+A.
+Uh-huh.
+R.
+-- so many years ago, has today that caused
+you or pressed upon you to maybe soften your testimony
+or change your testimony at all?
+A.
+Absolutely not.
+Have you ever spoken with any independent
+investigators regarding the actions, the criminal
+actions that occurred at Jeffrey Epstein's home?
+A. Yes.
+Q. When did that occur?
+A. Right after I receive a card from the police
+department, when I call Jeffrey and I ask him, what's
+going on?
+He says, I cannot talk to you. Somebody will
+talk to you.
+And then I got a call from this guy that I
+cannot recall his name now. Talked to me and we met at
+Carabbas. And we talked -- what? -- about 15 minutes.
+And he asked me questions just like you guys are asking
+me and I says exactly the same answers.
+And he says, well, there's an investigation
+against Jeffrey. You has
+nothing to do with it. You
+Electronitaly signed by Sandra Townson 1401-1
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 95
+have nothing to do, nothing to worry about it, but if
+you want to hire a lawyer to protect yourself.
+And I asked -- my question to him was, I don't
+want to get incriminated into something that, you know,
+somebody trying to incriminate me for -= for my job.
+And he says, no, no, no. But if you want to
+get a lawyer, that's fine.
+And that's where I got Mr. Murrell and he just
+came to us, to sign this, to = that was the end ef it.
+e.
+A.
+Who got Mr. Murrell for you?
+Who got it? Mr. Epstein.
+When you met with this investigator at
+Carabbas, --
+A.
+Yes.
+e.
+-- did he record your conversation --
+A.
+No.
+- in any way?
+After this meeting at Carabbas, did you meet
+with any other investigators?
+A.
+No.
+l. After -- during your inspection of the massage
+room after these massages had been completed with
+Mr. Epstein, --
+A.
+Uh-huh.
+-- do you remember seeing any -- anything that
+
+
+Page 96
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+you would describe as blood?
+A. No, never.
+Q. Do you remember seeing anything that you would
+describe as a sexual fluid?
+A. No, never.
+When you worked for Jeffrey Epstein, the woman
+that you were married to, what is her name or -- what is
+her name?
+A.
+The woman that I was married to?
+l. I think - the reason I'm asking is because
+earlier today when you first spoke, I thought I
+remembered you saying that you -- both you and your
+wife --
+A.
+That's my --
+-- worked for Mr. Epstein?
+A. It's still my wife. It's still my wife. We
+didn't -- we got two ways away from a divorce and the
+lawyers were taking my money by pipeline.
+e.
+And what is her name?
+A. And we decide not to divorce and we still
+together.
+Sorry. I missed that. But what is her name?
+A.
+e.
+Maria Alessi.
+Let me just look through my notes to see if I
+have any other questions.
+Electronicaly signed by andra Townsend 14011
+
+
+Page 97
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A. Okay.
+e. Thank you very much.
+A.
+Welcome.
+CROSS EXAMINATION
+BY MR. MERMELSTEIN:
+l. Good afternoon, Mr. Alessi.
+A. Yes, sir.
+l. My name is Stuart Mermelstein. I represent a
+group of the Plaintiffs in these cases and I have some
+questions for you as well.
+Your wife, Maria, does she live at the same
+address as you now?
+A.
+Yes, she does.
+Now, when you began working full time for
+Mr. Epstein, I believe you said that was around 1991; is
+that correct?
+A.
+Yes.
+Was your wife, was she hired at the same time
+as you?
+A.
+No. She was hired three years after.
+And how did that come about that your wife was
+hired?
+A.
+My wife was hired because we had a housekeeper
+that she was doing the cleaning and she left. Then we
+had another housekeeper, Polish girl, and she left.
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 98
+And then by that time my kids went to college
+and my wife was at home. And I suggest my wife to come
+to work with me, to help me.
+l. So you recommended to Mr. Epstein that he hire
+your wife?
+A. Yes.
+2. And he did?
+A.
+Yes, he did.
+And what were her job duties there?
+A.
+Her only job duties were shopping, basically
+the shopping, getting movie tickets, show tickets, buy
+books, bring the food to Mrs. Epstein's -- Mr. Epstein's
+mother, sometimes drive Mrs. Epstein to the doctors.
+She was not involved -- and sometimes she did
+some cleaning for me.
+Q.
+Did she live with you in the upstairs
+apartment?
+A. Most of the nights we had an apartment right
+across the bridge on Flagler that it was my -- my
+property. And we had an apartment there.
+So she went home. She didn't like to stay
+there. But I had to stay there because my job starts
+from 5:00 in the morning to 10:00 at night.
+And did Maria leave her employment the same
+time as you?
+Electronically signed by Sandra Townsend (401-1
+
+
+Page 99
+1
+2
+3
+A.
+Yes, we did at the same time.
+e. You testified that you would come into the
+bedroom and clean up after massages; is that correct?
+A.
+That's correct.
+4
+5
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+l. Did you -- were there occasions where you had
+your wife help you with that?
+A. No. No.
+l. Were there -- did she have occasion to go into
+the master bedroom?
+A. It was occasions before that she will help to
+set up the tables once in a while, set up the oils and
+the tables. But I will do the clean up after.
+l. Is there a reason for that?
+A. I was more involved into the final appearance
+of the house. And it was my responsibility to make sure
+that every room was perfect after they left and before
+they went to bed.
+Q. Was there anyone else who assigned your wife
+work other than you?
+A. No. Ms. Maxwell, sometimes she would tell my
+wife, go buy some stuff, go get this and go get that.
+She was mostly -- my wife was mostly out of the house.
+She was -- this house was Mr. Epstein would says, go get
+me this book, go get me this magazine, go get me
+tickets, movie tickets for this show and this show and
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 100
+this show. And she would have to travel -- and I was on
+the phone with my wife constantly, buy this, get this,
+get this - and the food, and the food because it was a
+five-star hotel.
+l. Did Ms. Maxwell or Mr. Epstein ever instruct
+your wife to do housecleaning tasks?
+A. No. I was blamed for everything.
+Q. You were blamed for everything?
+A. I was blamed for the good and the bad.
+l. Did you -- during the time your wife was
+there, did you also have a hired housekeeper?
+A.
+We have a crew of housecleaners. We have a
+crew of people that would come to the house and do a
+serial -- I mean, deep cleaning, you know, to the house.
+Was that every day?
+A.
+Once a week -- no, it was twice a week. It
+was Tuesday and Fridays.
+It depends on Mr. Epstein's schedule because
+he didn't - he didn't want nobody at the house while he
+was at the house: So we have to rearrange days for the
+clean-up crew to come in. And I usually did that. As
+soon as they left I bring the cleaning crew, get the
+house ready and -- and get set for them for the next
+trip.
+Did you have a housekeeper who did
+Electronically signed by Sandra Townsend (401-
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 101
+housekeeping tasks on an everyday basis while you were
+employed there?
+A.
+No.
+Before my wife went in?
+l. No. After your wife.
+A. No. No. Not a full-time housekeeper.
+l. But you said your wife was hired after the
+housekeeper left?
+A.
+Yes.
+l. But -- so the person who left before your wife
+came, was she doing housekeeping chores?
+A. Yes, she was doing the housekeeping chores.
+Well, who did it then after your wife became
+employed there, because she wasn't doing the
+housekeeping?
+A. I was. I was doing it and then we hire people
+for to help us.
+So you were the main person doing the
+housecleaning?
+A.
+Yeah.
+e. And during -- between that time that your wife
+started and when you left the employment, was there a
+separate housekeeper employed during that time?
+A. No. Full time? No.
+l. Full-time housekeeper?
+Electronicaly signed by Sandra townsend 401)
+3afc3ca0-c86c-4b9f-8d01-ba20bcae87de
+
+
+Page 102
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+No.
+e. What about a part-time housekeeper?
+A.
+No. Like I told you, daily basis we call this
+company. And then they will come in with four or five
+girls and clean the whole house.
+l. This is the crew you were talking about?
+A. The crew.
+l. But the crew didn't come when Mr. Epstein was
+there?
+A. Right.
+e.
+So on an everyday basis when Mr. Epstein was
+there, you were the only person who was cleaning?
+A.
+Me - yeah, or my wife will help.
+e.
+At your instruction?
+A.
+That's right.
+l. But you don't ever remember her cleaning up
+after massages?
+A.
+No. No.
+Is it possible that you instructed her to
+clean up?
+A. It's possible, but --
+MR. CRITTON: Form. Asking him to speculate.
+BY MR. MERMELSTEIN:
+You can answer.
+A. It's possible.
+Electronically signed by Sandra Townsend (4011
+
+
+1
+2
+3
+Page 103
+When girls would come to give a massage, where
+would they come in the house? Would they come to the
+front door?
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A. Mostly came to the back kitchen door.
+l. The back kitchen door?
+A. Uh-huh.
+Q. Okay. And is there a bell there? Would they
+knock or how would they --
+A. There's a door bell.
+l. A door bell? They would ring the door bell?
+A. Uh-huh.
+2. And who generally would answer the door?
+A.
+Me or my wife.
+So you would let them in?
+A. Uh-huh.
+MR. CRITTON: Stuart, can I just ask you? You
+use the term, girls. I assume you just mean, that
+means female woman. It can mean anything? It has
+no age bracket to it?
+MR. MERMELSTEIN: That's correct. I'm not
+referring specifically to ages right now.
+THE WITNESS: No.
+BY MR. MERMELSTEIN:
+l. So as I understand it, the girl would come to
+the kitchen entrance, which is the service entrance,
+Electrenicaly signed by Sandra Townsen 401 )
+3afc3ca0-c860-4b9f-Bd01-ba20bcae87de
+
+
+Page 104
+1
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+correct?
+A. Uh-huh.
+l. You have to say yes or no.
+A. Yes, sir.
+l. If you answer uh-huh, that's not clear, so you
+have to answer yes or no.
+A. Okay.
+Q. And you would typically open the door?
+A.
+Yes, sir.
+l. And what would happen then?
+A. Then I will keep her in the kitchen and go to
+Mr. Epstein and find out where they want to have the
+massage, or if it was for him or for Ms. Maxwell. And I
+immediately, if they were repeat girls that are -- they
+will know exactly where to go. And I will go up with
+them, set the tables, and they will wait for him or her
+to go in the room and they sit there until they come up.
+e. So did you generally already know that they
+were coming at the time that they knocked on the door?
+A.
+Yes, uh-huh.
+e. So you had an appointment schedule?
+A. Yeah. Because most of the times I was doing
+the calling, you know. I called J., come in at 3:00
+this afternoon. And she will told me, no, I cannot, get
+somebody else. And I knew it the time they were coming.
+Electronicaly signed by Banda Toman 1401)
+
+
+Page 105
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+So I was expecting them most of the time.
+So you would expect them, they would come in
+and then you would escort them upstairs?
+A. Uh-huh.
+SO --
+A. I'm sorry, sir.
+Q. Yes?
+A. Yes.
+l. But first you would find Mr. Epstein and check
+to see if he's ready or find Ms. Maxwell to check to see
+if she's ready?
+A. Yes.
+l. And which staircase would you -- would you
+take them up?
+A. Either way.
+Q. You would take them either the main staircase
+or the servant staircase?
+A. Yes.
+Why would you take the main staircase, since
+you're already in the kitchen?
+A.
+That's what I says, either way. We can go
+through the main staircase or we go to the kitchen
+staircase. So we use both.
+R.
+Okay. Well, I'm talking specifically to
+escort a girl upstairs.
+
+
+Page 106
+A. I escort the girls up there either way, both
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ways.
+And, so, when you walked to the upstairs
+bedroom, let's take the example of when Mr. Epstein is
+getting a massage?
+A. Yes.
+e.
+Mr. Epstein wouldn't be up there yet; is that
+correct?
+A. That's correct.
+Q. He would be downstairs somewhere?
+A. Uh-huh.
+e. Would there be a place -
+MR. CRITTON: Form.
+BY MR. MERMELSTEIN:
+l. - where he would normally be while, you know,
+he's waiting for the massage to be set up and ready?
+A. Yes.
+I. Where is that? Where would he be?
+A.
+Either at his desk or the pool house.
+l. And those were on the first floor?
+A. Yes.
+e. And, so, when you arrived at the top of the
+stairs with the girl for the massage, what would you do
+then?
+A.
+Go back to my duties.
+Electronicaly signed by Sandra Townsen 1401-7
+
+
+1
+2
+3
+4
+5
+Page 107
+You would just leave? Would the massage table
+already be set up?
+A. He knew already that the girls -- the girl
+went upstairs and it was up to him to come up.
+Did you have conversations with any of these
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+girls?
+A.
+Sometimes.
+e.
+What kind of things would you talk about?
+A.
+Regular things. Nothing that I can remember.
+Nothing. Just...
+l. Did any of them ever tell you their ages?
+A.
+No, sir.
+Did any of them ever assure you that they were
+18?
+MR. CRITTON: Form.
+BY MR. MERMELSTEIN:
+l. Or over?
+A. No, sir.
+No one ever mentioned anything about age?
+A.
+No, sir.
+l. How did the girls appear to you? Did they
+appear to be very young?
+MR. CRITTON: Form.
+THE WITNESS: Again, the same question you ask
+me. Everybody ask me the same thing. They could
+
+
+1
+2
+3
+4
+5
+6
+7
+Page 108
+have been 16 or 20. Most of them were, I would
+says, over 20. And some woman, it was over 60.
+And one time she came to the door. The husband was
+waiting outside. And Ms. Maxwell saw this woman,
+that somebody recommend her. And Maxwell says to
+me, John, you have to find an excuse. We don't
+want her;
+So I had to pay this woman and find an excuse
+that they going to have to go. And she -- they
+never had a massage with her.
+But there was -- most of them were womans.
+They were not girls.
+BY MR. MERMELSTEIN:
+e. So the woman who was over 60 was sent away;
+she was rejected, correct?
+MR. CRITTON: Form.
+THE WITNESS: It was -- I was told to send her
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+away.
+BY MR. MERMELSTEIN:
+l. And it was your understanding when you were
+told to send her away, it was because of her age,
+correct?
+MR. CRITTON: Form.
+THE WITNESS: I don't know. I don't know. I
+was told to send her away.
+Electronical signed by Sandra Townsend 401)
+
+
+Page 109
+1
+2
+3
+4
+5
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY MR. MERMELSTEIN:
+2. What was your understanding as to why they
+were sending her away?
+MR. CRITTON: Form. Asked and answered nine
+times now.
+MR. MERMELSTEIN: He hasn't -- he hasn't
+answered my question yet.
+MR. CRITTON: He has.
+MR. MERMELSTEIN: Go ahead.
+THE WITNESS: Why?
+BY MR. MERMELSTEIN:
+l. Please answer the question.
+A. Can you repeat the question?
+e. What was your understanding as to why they
+sent her away?
+MR. CRITTON: Form.
+THE WITNESS: My understanding was either they
+were busy or they didn't want her.
+BY MR. MERMELSTEIN:
+l. What was your understanding as to why they
+didn't want her?
+MR. CRITTON: Form. Harassing.
+THE WITNESS: I don't know. I didn't -- I
+didn't make too much of it.
+BY MR. MERMELSTEIN:
+Electronicaly signed by Sandra Townsen 1401])
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 110
+l. But every other woman or female who came over
+to give a massage was much, much younger, correct?
+A. Yes.
+e.
+exception, correct?
+BY MR. MERMELSTEIN:
+So this 60 year old woman was a significant
+MR. CRITTON: Form. Argumentative.
+Q. You can answer.
+A.
+ask me to --
+I don't know how to answer that question. You
+Let me ask you this.
+MR. CRITTON: Why don't you let him answer the
+question before you interrupt him.
+BY MR. MERMELSTEIN:
+e. All right.
+Go ahead. Please answer. It
+didn't look like you were --
+A. I don't know how to answer that question, you
+asking me what is your opinion of that.
+And I told you, my opinion of that, either
+they saw the girl -- I don't think Mr. Epstein ever saw
+the woman. But Ms. Maxwell saw the woman in the
+kitchen. And she told me, John, pay her and send her
+away.
+R.
+Okay.
+A.
+That was it.
+Electronicaly signed by Sandra Townsend (4014
+
+
+Page 111
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+e.
+So Ms. Maxwell looked at the woman?
+A. Right.
+e. Did she have a conversation with her?
+A. No.
+2. She just looked at her and then said to you to
+send her away, correct?
+A. Yeah. Pay her and send her away.
+2. Do you recall seeing women who came to give
+massages who were in their 50s?
+A. Yes.
+e.
+There were women in the 50s?
+A.
+Yes.
+How often did that happen?
+A. Not too often, but it was -- it was woman that
+they were in the 50s. I says, again, could have been
+49, 45. I don't know. I don't know the ages, but it
+older woman.
+2. How many middle-age women do you recall coming
+over to give massages?
+MR. CRITTON: Form.
+THE WITNESS: I don't remember how many, but I
+would says. D.D.
+D.D. was, I would says, in the 40s. And she
+came very, very often. And I understand she was a
+massage specialist and a yoga instructor, too, at
+Electronical signed by Sandra Townsend 1401 l
+
+
+Page 112
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+the same time.
+So that was one of -- and there was another
+woman that she was
+supposed to be a teacher at the
+school of massage therapy that I can't remember her
+name. But that's it. I mean...
+BY MR. MERMELSTEIN:
+l. So those two you remember who were older?
+A. Iwo. And it was a couple guys that were older
+that -- some guys that were older, too, guys.
+Did Mr. Epstein ever have massages done by
+men?
+A.
+Yes.
+e.
+these older women?
+And did Mr. Epstein ever have massages done by
+A. Yes.
+When you escorted the female in this case for
+the massage to the upstairs bedroom -- correct? -- you
+would then leave?
+A.
+Yes.
+e.
+You would then walk back downstairs?
+A.
+Yes.
+Correct?
+And would you then -- would you -- you had
+already told Mr. Epstein that she's there, correct?
+A.
+That's correct.
+Ectronialy signed by Sandra Town on 14011
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 113
+And at some point later then Mr. Epstein would
+come upstairs, correct?
+A.
+That's correct.
+And where would you go?
+A.
+Io my duties, to the kitchen or to my office.
+l. And I think you testified earlier that the
+doors of the bedroom would be closed during this
+massage?
+A. He would close the door.
+e.
+So Mr. Epstein, when he would arrive upstairs,
+would close the door?
+A.
+Yes, sir.
+e. And about how long would the massage last
+generally?
+A.
+Usually an hour.
+e.
+And what would happen at the end?
+A.
+They would come down. Most of the repeat
+girls, they would bring the towels themselves and dump
+it by the kitchen by the laundry room we had there, in
+order to help us. Other girls, they just left it up
+there and they would come down.
+Either Mr. Epstein will pay or I will pay
+them.
+Did they --
+A.
+Or Ms. Maxwell will pay them.
+3afc3ca0-c86е-4b9f-8d01-ba20bcae87de
+
+
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 114
+Q. Did Mr. Epstein walk down with the girls or
+did he stay upstairs?
+A.
+Sometimes, sometimes no.
+Sometimes he took a
+nap or he took a shower. I don't know what they did in
+the room. I don't know. I don't know. Sometimes he
+went down right away. Sometimes he stay up there.
+So when they came down, they would go to the
+kitchen; is that correct?
+A.
+e.
+Yeah, most of it.
+And were you there waiting for them or did you
+have --
+A.
+My office was right next to the kitchen, so I
+was there -- and the kitchen was the focal point of the
+house basically. So they have to go to the kitchen
+either to get pay or to go to their cars.
+Q.
+Did you converse with any of the girls when
+they came down after the massage?
+A. Very little. Very little.
+e.
+Did you ever observe a girl who appeared
+upset, surprised, shocked, anything of that nature when
+they came down?
+A.
+Never. Never.
+e.
+And sometimes you would pay them, correct?
+A.
+That's correct.
+e.
+How much would you --
+
+
+Page 115
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A. A hundred dollars a massage..
+l. A hundred dollars a massage? Were there ever
+any exceptions?
+A.
+That's the -- I never pay any more than a
+hundred dollars per massage.
+Were there times when two girls came?
+A.
+Iwo girls came at the same time?
+Correct.
+A. Yeah. There were times when two girls come in
+at the same time and one will go to one room, the other
+will go to the other room. Or one -- I would set up two
+tables in his room or I will ask him, where you want to
+set the massages? He will told me, set in the blue room
+and set them in my room. Or set them in Ghislaine's
+room and the red room, depends on who people were there.
+But there were times where two of the girls at the same
+time, yes.
+e. Was there ever occasions where there was a
+girl who waited downstairs while one -- while the other
+girl went upstairs?
+A. No.
+e.
+That never happened?
+A.
+I cannot remember.
+Was there ever an occasion where you paid a
+girl who waited and didn't actually give a massage?
+Electronicaly signed by Sandra Townsend 401l
+
+
+Page 116
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+No.
+That never happened?
+Never happened.
+Q. You mentioned that Mr. Epstein put you in
+contact with Mr. Murrell; is that correct?
+MR. CRITTON: Form.
+THE WITNESS: Not Mr. Epstein.
+BY MR. MERMELSTEIN:
+Huh?
+A.
+It wasn't Mr. Epstein.
+l. Mr. Epstein's investigator put you in contact
+with Mr. Murrell?
+A. That's correct. He gave me his name.
+e.
+And did you pay Mr. Murrell out of your own
+pocket?
+A.
+No, I didn't pay nothing.
+e. Who is -- what was your understanding as to
+who was paying for Mr. Murrell?
+A.
+I don't know. I don't know who was paying for
+it.
+bill?
+e.
+A.
+You never asked Mr. Murrell who was paying his
+No, he never send me a bill.
+Did you think that Mr. Murrell was doing it
+for free?
+Electronical signed by Sandra Townsend 4011
+
+
+Page 117
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+20
+21
+22
+23
+24
+25
+A.
+I don't know.
+e. You don't know. As far as you know,
+Mr. Murrell could have been providing you legal services
+for free?
+A. No, I don't think it was provided me for free.
+I don't think he ever -- that question ever come out of
+Mr. Murrell. I was in Mr. Murrell's office for about
+ten minutes.
+And he says, well, I meet you tomorrow
+there -- and that's it -- in order to protect you so
+they don't incriminate you in any way. We left it at
+that. He never send me a bill. He never send me -- I
+never talk to Mr. Murrell again, never saw him again.
+l. And you never had any kind of understanding
+with him as to how --
+A.
+NO.
+- how his bill was going to be paid?
+A. No.
+e. Did you sign any kind of what we call, a
+retainer agreement, anything where you hired him?
+A. No.
+MR. CRITTON: Just so you know, you have an
+attorney -- nobody's going to tell you this
+apparently.
+You have an attorney/client privilege. Any
+Electronicaly signed by Sandra Townsend 40-11
+Зafe3ca0-c86e-4b9f-Bd01-ba20bcae87de
+
+
+Page 118
+1
+2
+3
+conversation that you had with Mr. Murrell, you and
+your wife, is completely protected, as long as you
+want to assert that privilege.
+4
+You can either assert it or not assert it.
+5
+That's your right. But nobody's apparently going
+6
+to tell you that, at least Mr. Mermelstein is not
+7
+going to tell you that.
+8
+MR. MERMELSTEIN: Well, I was trying to
+9
+avoid --
+10
+MR. CRITTON: Well, you're asking questions of
+11
+what he said.
+12
+MR. MERMELSTEIN: I'm not asking them what
+13
+they said.
+14
+MR. CRITTON: Same thing.
+15
+MR. MERMELSTEIN: I'm asking him how he got
+16
+paid.
+17
+MR. CRITTON: No, you were -- read back your
+18
+questions where you were.
+19
+Anyhow, that's a right you have, so...
+20
+So much for the law.
+21
+MR. MERMELSTEIN: I was not asking him what
+22
+was said during any conversation. I asked him if
+23
+he signed a retainer. That's a fair question.
+21
+BY MR. MERMELSTEIN:
+25
+l. Do you remember a girl who came to give
+Electronicaly signed by Sandra Townsen 401 I
+
+
+Page 119
+.? Does that name
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+massages there by the name of
+sound familiar at all?
+A. No.
+l. Do you remember an
+A.
+No.
+What about a
+the name of
+.? Do you remember anyone by
+A. No.
+Was it frequent that girls would come just
+once and not appear again?
+A. Frequently.
+These girls that would come, would they come
+with their own equipment or supplies?
+A.
+No. Some girls, they come in with a table,
+the new girls they come in with a table. And I would
+told them, no, you don't need the table. They will
+leave it in the kitchen because we have tables in every
+room in the house.
+Some of the girls, the first time they came
+they didn't have anything, right?
+A. They come with that table, one of the tables
+they hang it in the shoulders, portable tables. But we
+didn't have portable tables
+: in the room. They were all
+custom-made tables.
+Did some girls come without -- for the first
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 120
+time without any supplies at all, whether equipment or
+lotions or anything of that nature?
+A. Probably.
+l. Did you have a question in your mind as to
+whether they were professional at this business?
+A.
+No.
+Q. At massaging?
+A.
+No.
+e. Why not?
+A. It was not my job.
+MR. CRITTON: Form.
+BY MR. MERMELSTEIN:
+Q. You just didn't think about it?
+MR. CRITTON: Form.
+THE WITNESS: If I was told that a girl is
+coming, my job was to open the door, let her in and
+let Mr. Epstein decide where he wants his massage.
+And that was the end of it.
+BY MR. MERMELSTEIN:
+Q. Are you aware that sexual conduct between an
+adult male and an underage female is criminal; it's
+against the law?
+MR. CRITTON: Form.
+THE WITNESS:
+Of course I do.
+BY MR. MERMELSTEIN:
+Electronical signed by Sandra Townsend 4012)
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 121
+e. Did you have any concerns while you were
+working there that criminal acts were occurring with the
+girls who were coming to the door?
+MR. CRITTON: Form.
+THE WITNESS: I had no idea what was going on
+between them.
+BY MR. MERMELSTEIN:
+Q. Let me just give you some other names. Tell
+me if you recognize any of these names.
+1.?
+A.
+(Nods head.)
+Name does not ring a bell?
+A.
+(Nods head.)
+MR. CRITTON: You have to answer out loud.
+BY MR. MERMELSTEIN:
+You need to say yes or no.
+No.
+A.
+e.
+A.
+e.
+second name?
+A.
+e.
+A.
+Can you repeat that?
+would be the first name.
+No.
+П.?
+No.
+•.?
+Electronicaly signed by Sandra Townsend 1401-
+would be the
+
+
+Page 122
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+No.
+_.?
+A.
+e.
+A.
+No. None of those girls' --
+None of those girls ring a bell at all?
+-- name familiar to me.
+Either they came one time, one day and they
+didn't even told me their names or -- or he paid for it
+that I don't have -- but none of those names sound
+familiar to me.
+e. You testified that there were -- about the sex
+toys that you would pick up after -- after there were
+massages, correct?
+MR. CRITTON: Form.
+BY MR. MERMELSTEIN:
+l. The vibrators, correct?
+MR. CRITTON:
+Form.
+BY MR. MERMELSTEIN:
+e. You can answer.
+Yes.
+A.
+e. And you mentioned there was a basket with
+these vibrators or toys in them, correct?
+A.
+Yes.
+e.
+A.
+e.
+Where was the basket kept?
+In Ms. Maxwell's closet.
+And that was in the master bedroom?
+Electronically signed by Sandra Townsen (4014
+
+
+Page 123
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR. CRITTON: Form.
+BY MR. MERMELSTEIN:
+l. Or off the master bathroom?
+A.
+Her bathroom.
+Huh?
+A.
+Her bathroom.
+e. And the closet was -- the entrance to the
+closet was in her bathroom?
+A.
+That's correct.
+l. And it was a portable basket, she could move
+it around, correct?
+A.
+Uh-huh.
+e.
+A.
+You have to say yes or no.
+Yes, sir.
+And -- and that's where the, I think you used
+the word dildo, correct? That's where they were
+located?
+A.
+Yes, sir.
+Was there occasions where you would -- the
+dildo, one or more dildos would be out and you would
+clean them up after a massage that only Mr. Epstein had,
+not Ms. Maxwell?
+A. It was -- I will says that it was about three
+or four occasions that I had to take this dildos and put
+it back where they supposed to be. And I took it with
+Electronicall signed by Sandra Townsend 401)
+
+
+Page 124
+1
+gloves and towels and stick it in the sink and throw it
+2
+in there.
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+Sometimes Ms. Maxwell will have a massage.
+And sometimes I find it after she's supposed to have a
+massage, those things. And also when Mr. Epstein had
+the massage. So I don't know who use it on who.
+Because sometimes they all disappear up there,
+Mr. Epstein, Ms. Maxwell and whoever was up there.
+e.
+So as I understand it, you couldn't isolate a
+particular instant where --
+A.
+I cannot.
+e.
+-- Ms. Maxwell wasn't there, only Mr. Epstein
+had gotten a massage and then you found the sex toys?
+A.
+I cannot isolate that.
+e.
+But it's possible that either Mr. Epstein used
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+it or Ms. Maxwell used it; is that correct?
+MR. CRITTON: Form. Form.
+THE WITNESS: I have no idea to know.
+MR. MERMELSTEIN: All right. I have nothing
+further.
+MR. BERGER: How about if we take a break?
+Would you like a break for a couple minutes?
+THE WITNESS: No, that's fine.
+MR. BERGER: Mr. Willits, would it be possible
+if I could sit there, because I've got a couple
+Electronical signed by Sandra Toman 401)
+
+
+Page 125
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Exhibits I'm going to show him?
+MR. WILLITS: Sure.
+MR. BERGER: Thanks.
+CROSS EXAMINATION
+BY MR. BERGER:
+e.
+Okay. Good afternoon, sir.
+A. Afternoon, sir.
+l. My name is William J. Berger and I represent
+three of the Plaintiffs in this case.
+Did you ever hear of the name I., a young
+woman named I.?
+A.
+No, sir.
+How about a young woman named
+?
+A.
+No, sir.
+Okay. You know, you've referred several times
+to a falling out or a disagreement that you had with
+Mr. Epstein?
+A. Yes.
+R.
+Was that in -- was that the year that you left
+his employment?
+A. Right after -- right after I left.
+Q.
+So you had a falling out with him after you
+left his employment?
+A.
+Yes.
+Well, why did you leave his employment?
+Electronical signed by Sandra Townsen 401)
+
+
+Page 126
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+Why?
+Q. Yeah.
+A.
+Because I was sick. I was extremely sick. I
+was bleeding, internally bleeding, and I was bleeding
+from my butt and I have
+• fistulas in my colon. And I was
+sick of the job and we had enough. We had good pay, but
+we had enough of the job, especially because of
+Ms. Maxwell's attitude
+towards us.
+Now, you said you had good pay, but we had
+enough. What was your pay in 2002?
+A.
+2002, right before I left? I think it was 50,
+either 55, something like that. And my wife was 30 or
+35. I could be wrong.
+e. So you think that you were paid $55, 000 in
+2002?
+A.
+2.
+A.
+e.
+A.
+e.
+A.
+Uh-huh.
+Is that correct?
+That's correct.
+And you believe your wife was paid how much?
+Thirty, $30,000.
+$30,000 in 2002?
+Uh-huh.
+Is that correct?
+A. Yes, sir.
+2. How about 2001, what was your salary and your
+Electronicaly signed by Sandra Townsend 4071,
+
+
+Page 127
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+wife's?
+A.
+Same thing.
+2. Okay. And in 2000?
+A. I was at the same. It never -- we never got
+raises. We never got --
+I think you said at the very beginning --
+A.
+Yes.
+Q.
+-- of the deposition that you were paid 45,000
+when you were first hired full time?
+A.
+Yeah.
+In 2002, you were earning 55, 000?
+A.
+Uh-huh.
+So you did get some raise?
+A.
+Yeah. In the matter of 11 years. Yeah, but
+we didn't get a raise every six months or every year in
+any specific date. And the raises were set by the
+company. Automatically they would come from New York.
+It was not a negotiate point between me and Mr. Epstein.
+2. And then you said earlier with me, you said we
+had enough, you and your wife. You said, we had enough;
+is that correct?
+A.
+That's correct.
+What do you mean by that?
+A. It was extremely stressful job. It was a lot
+of pressure on us -- on me, on me -- I have to
+Electronical signed by Sandra Transen 401)
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 128
+correct -- on me. Everything was blamed on me. If a
+chef cook a bad meal, it was my fault. And if the table
+was not proper set royalty style, it was my fault. And
+the hours were terrible, never have a holiday, Saturdays
+and Sundays. We were working between 60 and 70 hours a
+week. And my health was, I think, the most important
+thing. And also the relation with my wife, it was a big
+factor in us leaving the company.
+Now, you said that you were blamed for things?
+A.
+Yes, sir.
+e.
+Who would blame you? Who is it that would say
+that you were blamed?
+A. I don't know who did the blaming, but I will
+get my ass chewed out by Ms. Maxwell --
+She was the one?
+A.
+Most of the times, yes.
+Who else did that?
+e.
+A.
+Sometimes I had disagreements with him.
+e.
+"Him, " being, who?
+A.
+Mr. Epstein.
+e.
+About what?
+A.
+Simple things. For me, it's stupid things,
+nothing -- if this paper -- if this pencil was not put
+in right there, they will complain.
+Okay. And is it correct that you left the
+Electronicaly signed by Sandra Town 401 1
+Jafc3ca0-c86e-4b9f-Bd01-ba20bcae87de
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 129
+employment of Mr. Epstein in December of 2002? Does
+that sound correct?
+A.
+That's correct.
+l. And the -- now, were you arrested in 2003?
+A. I was never arrested.
+You did speak to the police?
+Yes.
+A.
+2. And you did have your statement taken at the
+State Attorney's Office?
+A.
+Yes.
+Q. But you - but that was by an Assistant State
+Attorney, correct?
+A.
+Yes.
+A.
+e.
+A.
+The questioning?
+(Nods head.)
+Is that correct?
+That's correct.
+e.
+You spoke separately with police officers
+though, correct?
+MR. CRITTON: Form.
+BY MR. BERGER:
+l. In other words, the date of that statement is
+in October of 2003; is that correct?
+A.
+Yes.
+2. And by "that statement, " I mean, the
+Electronically signed by Sandra Townsend 401-
+
+
+Page 130
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+transcript that I gave you earlier?
+A.
+At what date, sir?
+MR. MERMELSTEIN: 2005.
+MR. BERGER: I'm sorry. You're correct.
+Thank you. Sorry.
+THE WITNESS: 2005.
+MR. BERGER: In fact, let's -- Ms. Reporter,
+would you mark the transcript if anybody needs it?
+MR. CRITTON: It's Exhibit 2 now?
+MR. BERGER: Is that how you're doing it, just
+consecutively?
+MR. CRITTON: Yeah, let's do it; otherwise,
+it's going to be an awful mess, have five different
+Exhibit number 1s by everybody.
+(Exhibit number 2 was marked for
+identification purposes.)
+BY MR. BERGER:
+l. You see Exhibit 2? It's a transcript; is that
+correct?
+A.
+That's correct.
+Is that the transcript of the sworn statement
+that you gave to the Assistant State Attorney in 2005?
+A.
+Yes, sir.
+And during the lunch break, did you have an
+opportunity to read it?
+Electronical signed by Sandra Townsen 401-1
+
+
+Page 131
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A. Yes, sir.
+e. And do you remember that you were placed under
+oath when you gave that statement?
+A. Yes, sir.
+l. And is everything that you say in here
+truthful and correct?
+A. As far as I know, yes, sir.
+l. Okay. Now, in connection with the incident in
+October of 2003 involving Mr. Epstein's house and your
+entering his house, that incident?
+A.
+It was in October 2003?
+When do you remember that it was?
+A.
+I can't remember.
+l. Okay. All right. You spoke with police
+officers in connection with that though, correct?
+A.
+I went to the Palm Beach Police Department.
+Why did you go to the --
+A.
+I speak to one officer.
+And why did you go there?
+A.
+Because Mr. -- when I spoke to Mr. Epstein and
+we settle the dispute, Mr. Epstein says, you just need
+to go to the police department and make a statement.
+MR. WILLITS: Could I have Exhibit number 2,
+please?
+Thank you.
+
+
+Page 132
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+21
+25
+BY MR. BERGER:
+l. Let me see if I understand this correctly.
+I think you testified earlier that you found a
+card or you were given a card from a police officer; is
+that correct?
+A. That's correct.
+Q. And as a result of that, you called
+Mr. Epstein, correct?
+A.
+That's correct.
+Before you got that card, did you have any
+idea that the police were involved in your life?
+A. No.
+MR. CRITTON: Form.
+BY MR. BERGER:
+l. And you called Mr. Epstein after you got that
+card, correct?
+A. Yes.
+e.
+Now, how did you get it? Was it mailed to
+you?
+A.
+door.
+No. It was putted in my door. I was not
+home. And they went to my house and they left it in the
+A.
+And did it have a note on it, please call?
+Yes.
+Or was it just a card?
+Electronical signed by Sandra Townsen 1401)
+
+
+Page 133
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+It was a -- it was a Palm Beach Police
+Department, please call.
+e.
+Mr. Epstein first, right?
+Okay. And you didn't call though; you called
+A.
+Yeah. Because I was scared.
+e. Why were you scared?
+A. Because I thought it was of the incident that
+happens previously.
+And what was that incident?
+A.
+You know that incident.
+I'd like to hear you describe it for me.
+A.
+That incident is, I went to the house and I
+got some money.
+A.
+Night.
+What time of day did you go to the house?
+A.
+e.
+A.
+Was anybody home?
+No.
+Where did you get the money?
+Out of his bag.
+l. Out of his?
+A. Bag.
+l. Bag. Briefcase? Bag?
+A. Briefcase.
+l. Briefcase?
+A. Yes.
+Electronicaly lined by Sandra Townsend 4014
+Заfс3ca0-c86в-4b95-8d01-ba20bcae87de
+
+
+Page 134
+1
+How did you -- did you know that there was
+2
+3
+money in the briefcase?
+A.
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Yes.
+How did you know that?
+A.
+Because I replenish that case many times
+before.
+2. Now, how many months after you left
+Mr. Epstein's employment did this occur?
+A.
+I don't have -- I would says, three to four
+months.
+l. I would just ask a favor of you. The court
+reporter needs to see your face so she can understand
+what you're saying. She's looking -- you put your hand
+in front of your mouth. That's all.
+Now, when you worked for Mr. Epstein, did you
+learn that he kept money in that briefcase?
+A. Yes.
+l. And, so, when you went to his house on that
+occasion, did you just assume that there would be money
+in the briefcase?
+A.
+Yes.
+briefcase?
+Q. And -- and did you take money out of that
+A.
+Yes.
+Now, is that the only time that you took money
+lectronically signed by Sandra Townsend (41
+ectronically signed by Sandra Townsend (41
+
+
+Page 135
+1
+2
+3
+4
+5
+out --
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+No.
+-- of his briefcase?
+A.
+It was twice.
+When was the other time?
+A.
+Couple weeks
+before.
+What time of day was that?
+A.
+At night.
+And how much did you take out the first time?
+A. It was a total of $6,300.
+That's for both times?
+A.
+Yeah.
+l. Can you break them down?
+A. I think one time was $1,500. Another time was
+the rest.
+Now, you left in December of 2002 and then
+there were these two incidents that you just described?
+A. Uh-huh.
+Did you have any contact with Mr. Epstein in
+between leaving his employment and the first of these
+two instances?
+A.
+None.
+And as far as you knew, did anybody see you
+take the money on either occasion?
+A.
+None.
+Electronicaly signed by Sandra Townsend 401 l
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 136
+e.
+And, so, when you saw the card from the
+police, you assumed it had to do with these two
+instances?
+A. Yes, sir.
+l. And there was no other reason why you thought
+it had to do with Mr. Epstein?
+A. No, sir.
+Q. And when you called him, did you discuss these
+two incidents with him?
+A.
+When I call Mr. --
+You said you got the card -
+A.
+No.
+e.
+A.
+-- and then you called him?
+No, we did not discuss that money or nothing
+involved.
+I ask him, what's going on, Jeffrey? What's
+happening? I got this and I thought that this was all
+over.
+No, he says, John, it has nothing to do with
+that money.
+l. Did you ever read the incident report by the
+police, the Palm Beach Police Department? Did you ever
+read it?
+A.
+No.
+MR. CRITTON: Regarding what?
+Electronicaly signed by Sandra Townson 1401-1
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 137
+MR. BERGER: Regarding these incidents.
+BY MR. BERGER:
+Q. You never read it?
+A. No.
+Q. Let me hand you this.
+MR. CRITTON: Is there an extra copy?
+MR. BERGER: Yeah.
+BY MR. BERGER:
+What I'm showing you, have you ever seen this
+before?
+A.
+No.
+MR. BERGER: Let's have this marked as Exhibit
+3, please.
+MR. CRITTON: Can I keep this?
+(Exhibit number 3 was marked for
+identification purposes.)
+BY MR. BERGER:
+l. It appears to be about 20 pages and it has,
+Palm Beach Police Department Incident Report, on the top
+page.
+Turn to the third page.
+And you see where it starts the narrative, the
+paragraph? Do you see where that starts?
+A. Yes, sir.
+2. And it says: "On Sunday, October 5, '03 at
+Electronicaly signed by Sandra Townsend 4014
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 138
+approximately 8:24 hours, I was dispatched to a burglary
+at 358 El Brillo Way."
+Do you see that?
+A.
+Yeah.
+2. Now, October 5, 2003, do you recall that that
+was about when the time you took the money from
+Mr. Epstein's briefcase was?
+A.
+Yes. I don't recall. But if they say it, I
+have to agree with it.
+e.
+Well, you left in December of 2002. And
+before I showed you this document, you said that these
+incidents occurred about three or four months later. So
+apparently they occurred more than three or four months
+later; is that correct?
+A.
+Apparently, yes.
+l. Well, now after -- after looking at this, sir,
+do you actually recall that it occurred more than three
+or four months later?
+A.
+After looking at this?
+Yeah.
+A.
+It could be.
+l. But do you actually remember it being more
+than three or four months?
+A. I don't remember if it was more than three
+months.
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+20
+21
+22
+23
+24
+25
+Page 139
+e.
+Okay. Okay. Now, if you look further down,
+you'll see it says, quote, Epstein further advised a
+black Glock handgun was taken from the book shelf
+located behind the desk, unquote.
+Do you see that?
+A.
+Yes.
+A.
+Did you take a black Glock handgun from him?
+Absolutely not.
+l.
+Do you know if anybody did?
+A.
+No, sir.
+l. Is this the first time that you ever heard
+that Mr. Epstein may have told the police --
+A. No. This question I was asked by the police.
+l. Okay. Now, you see the next sentence? It
+says: "Epstein advised he suspected cash had been taken
+from his briefcase on two other occasions while he was
+in town for the weekend. The first was over the Labor
+Day weekend, August 30 to September 1. The second time
+was a weekend in mid-September 2003."
+Do you see --
+A.
+Yeah.
+-- the mention of those two incidents?
+A.
+Uh-huh.
+e. Yes?
+A. Uh-huh.
+Electronically signed by Sandra Townsond 401)
+
+
+Page 140
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+e.
+A.
+You've got to say yes or no.
+Yes, sir.
+Now, look up at the top of that paragraph.
+You see where it says: "After" -- it's about the fourth
+sentence -- "Epstein advised that on Saturday evening,
+October 4, 2003, he left his briefcase at his desk and
+went to bed at approximately 12:30 a.m. Epstein said
+when he left his briefcase, it contained approximately
+$5,000 U.S. currency."
+A.
+Uh-huh.
+Do you see that?
+A. Yes.
+l. And then it goes further on, it says - after
+a sentence or two, it says: "Epstein stated at
+approximately 7:15 hours on Sunday, October 5, 2003,
+while sitting at his desk, he noticed the briefcase had
+been opened and some of the cash was missing. Epstein
+believed approximately $3,500 was taken from the
+briefcase."
+A.
+Do you see that?
+Yes.
+Now, when you read this whole paragraph here,
+do you agree that Mr. Epstein is -- and assuming that
+the police took this down accurately -- that Mr. Epstein
+is describing three separate instances --
+
+
+Page 141
+1
+2
+3
+4
+5
+6
+A.
+No.
+e.
+-- where he believes money was taken?
+MR. CRITTON: Form.
+THE WITNESS: I don't agree with this.
+BY MR. BERGER:
+No?
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+No.
+e.
+Well, he says: "The first" -- at the bottom,
+it says: "The first was over Labor Day weekend, August
+30 to September 1, 2003."
+You see it says that at the bottom? The very
+bottom.
+"The first was over Labor Day weekend,
+August 30 to September 1, 2003."
+Do you see that?
+A.
+Uh-huh.
+Yes or no?
+A.
+Yes.
+Q. And then it says: "The second time was a
+weekend in mid-September 2003."
+Do you see that?
+A. Yes.
+Q. And then above, do you see where he talked
+about October 4, 2003? You see mention of that? Or
+October 5, 2003?
+
+
+Page 142
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A. Right here.
+2. Right in the middle, it says: "Epstein stated
+at" -- yes.
+A.
+No. I don't agree with this. I never saw
+this.
+l. I'm not asking -- that's not what I'm asking.
+What I'm saying, sir, do you see though that
+the police report refers to three instances; is that
+correct?
+A. No.
+l. Okay. But it's correct that the police report
+refers to three instances, correct?
+MR. CRITTON: Form.
+BY MR. BERGER:
+l. The police talk about three instances, right?
+A. That's correct.
+MR. CRITTON: Form.
+BY MR. BERGER:
+Now, how many times did you take cash from
+Mr. Epstein?
+A. Iwice.
+e. So do you have any idea what he's talking
+about here?
+A.
+No.
+Now, the first time that you took cash, was it
+
+
+Page 143
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+on August 30 to September 1, 2003?
+A. I can't remember.
+Q. Or September -- mid-September 2003?
+A. I can't remember.
+l. Okay. Is the third incident accurate where it
+talks about October 5 or October 4, 2003?
+A. I don't know if it's accurate or not, but I
+know that I went to the house twice.
+Not three times?
+A. Not three times.
+e. Any idea why Mr. Epstein would talk about
+three times?
+A. No idea, sir.
+l. And any idea why he would talk about a Glock
+handgun?
+A.
+No, sir.
+MR. CRITTON: Form.
+BY MR. BERGER:
+e.
+Now, you said that -- that you had a -- okay.
+I've put this aside. I'm going to ask you another
+question, so why don't you -- I don't want to distract
+you.
+Now, you said that your disagreement or your
+falling out with Mr. Epstein was after you left his
+employment. Do you remember saying that?
+Electronicaly signed by Sandra Townsend 1401)
+
+
+Page 144
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A. Yes. After -- after this incident.
+Q. And what did that disagreement have to do
+with? Did it have to do with these incidents?
+A. Of course. I screw it up.
+l. Okay. And do you know who Mr. Adam Fetterman
+is?
+A. Yes.
+e. Who is he?
+A.
+He's my Lawyer.
+l. And did Mr. Epstein pay for Mr. Fetterman's
+legal services for you?
+A.
+No. I pay on my own pocket.
+Now, let me ask you some questions about some
+property in Palm Beach County, Mr. Alessi.
+Do you remember that in or around 1983 you and
+your wife bought a home at Bilbao Street in Royal Palm
+Beach?
+A.
+I didn't bought it. I build it.
+You built it. You didn't buy it?
+A.
+No.
+And do you remember that in April of 1995, you
+and your wife purchased a single-family home in -- on
+Northumberland Court in Wellington? Do you remember
+that?
+A.
+It was a lot.
+Electronicaly signed by Sandra Townsend (401)
+
+
+Page 145
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+It was a lot. Okay.
+A. Yes, we purchase that.
+Q. okay.
+about built home?
+MR. CRITTON: What was the first date you gave
+MR. BERGER: July 1983.
+MR. CRITTON: Thank you.
+BY MR. BERGER:
+that correct --
+l. And does the purchase price of $22, 600; is
+A. Sounds familiar.
+e. - for the -- for the Northumberland Court
+lot; is that correct?
+A. Uh-huh.
+e. Yes or no?
+A.
+What date was that?
+l. April of 1995.
+A. That's correct.
+Now, do you recall that in December of 1997
+you and your wife bought apartment number 1902 at 1515
+South Flagler Drive --
+A. That's correct.
+R.
+-- in West Palm Beach; is that right?
+A. Yes, sir.
+l. And does the purchase price of $105,000; is
+Electronical signed by Sandra Townsen 1401)
+
+
+Page 146
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+that accurate?
+A.
+That's correct.
+l. Now, do you recall that in November of 1998
+you and your wife bought apartment 1901 at 1515 South
+Flagler?
+A.
+Yes.
+e.
+And the purchase price was $159, 000?
+A.
+That's correct.
+e.
+So in -- so did you -- as of November of 1998,
+did you own both apartment 1902 and apartment 1901 at
+the 1515 building?
+A.
+Yes. But I didn't own the house in Royal Palm
+Beach. I didn't -- I sold that. With that money we
+bought that apartments.
+address?
+A.
+e. You built the house at the Royal Palm Beach
+Yes.
+After buying the lot?
+A.
+Yes. We bought the lot years, years back.
+Now, in October of 2001, do you remember
+buying a multi-family residential property at Yarmouth
+Drive in Wellington?
+A.
+I still have it.
+e.
+And do you remember the purchase price being
+$310,000?
+Electronicaly signed by Sandra Townsend 401-1
+
+
+Page 147
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+•
+23
+24
+25
+A.
+Yes, sir.
+And this is while you worked for Mr. Epstein,
+correct?
+A.
+2001, October 2001?
+Yeah.
+And you still own it; is that what you said?
+A.
+e.
+A.
+Yes.
+And is that a rental apartment building?
+Yeah, it's a rental.
+And now, do you recall that in September of
+2002 you and your wife purchased a multi-family
+residential property at
+in West Palm
+Beach?
+A.
+That's correct.
+And the purchase price was $590, 000? Do you
+remember that?
+A.
+Yes.
+l. And then in October of 2004 you bought the --
+you bought a multi-family residential property -- strike
+that.
+In October of 2004 your wife purchased a
+multi-family residential property at
+A.
+e.
+A.
+That is not correct. That is a house.
+That's where you live now?
+That's where we live now.
+Electronical signed by Sandra Townsend 4014
+Зafc3ca0-c86e-4b9f-8d01-ba20bcae87de
+
+
+Page 148
+1
+2
+3
+4
+5
+6
+7
+8
+And that's just a single-family home?
+A.
+That's a single-family home.
+l. Okay. And now, did Mr. Epstein contribute any
+money to the purchase of any of these properties?
+A. He contribute the -- he contribute the $20,000
+towards the purchase of the first property.
+A.
+Well, the first property was back in 1983?
+No. No. The first property at
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+That's apartment 1902?
+A.
+1902.
+e. Did he contribute any other money towards any
+of the other properties?
+A.
+No.
+e.
+So you paid $590,000 for the property at
+without the assistance of Jeffrey Epstein?
+A.
+That's correct. I had a loan, took a big loan
+on that.
+e.
+So he had absolutely nothing to do with your
+purchase of that property?
+A.
+Nothing.
+And he contributed nothing towards any -- to
+the purchase of any of the other properties that I
+mentioned?
+A.
+Nothing.
+Electronically igned by Sandra Townsend 401)
+
+
+Page 149
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Okay.
+MR. BERGER: Mark this as Exhibit 4, please.
+(Exhibit number 4 was marked for
+identification purposes.)
+BY MR. BERGER:
+l. Look at Exhibit 4, sir. It's two pages. And
+it's from Florida Department of State, Division of
+Corporations?
+A.
+Yeah.
+e. And would you turn to the next page, the
+second page?
+On the second page, do you see your signature
+and your wife's?
+A.
+Yes.
+e.
+And do you recognize this as an application
+for registration of a fictitious name?
+A.
+Yes.
+e.
+And is that - did you and your wife apply for
+registration of a fictitious name?
+A.
+Right. This was done by our lawyer,
+Fetterman.
+Q. And was that done in January of 2003? Look in
+the upper right.
+A.
+Yes.
+l. Is that correct?
+
+
+Page 150
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+e.
+A.
+Uh-huh.
+Yes?
+Yes.
+l. And the fictitious name was Las Villas Alessi
+Properties, correct?
+A.
+That's correct.
+l. And did Jeffrey Epstein have anything
+whatsoever to do with the registration of this
+fictitious name?
+A.
+Absolutely nothing.
+MR. BERGER: Mark this as the next Exhibit.
+(Exhibit number 5 was marked for
+identification purposes.)
+MR. WILLITS: Spell the name of that last --
+MR. BERGER: It's Las Villas, V-I-I-L-A-S,
+Alessi Properties.
+MR. WILLITS: Thank you.
+BY MR. BERGER:
+The next Exhibit, sir, has papers from the
+Department of State, Division of Corporations. Do you
+see it makes reference to Alessi Properties, LIC? Up at
+the top.
+It says: "Detail by officer/registered agent
+name." And then under that it says, "Florida limited
+liability company."
+Electronicaly signed by Sandra Townsen 1401)
+
+
+Page 151
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+Where is that, sir? Just point it.
+Then it says, Alessi Properties, LIC; is that
+right?
+A. Yes, sir.
+l. Then do you see the next couple pages includes
+a letter from Adam Fetterman to the Department of State?
+Do you see that?
+A. Yes,
+sir.
+e.
+And then the next -- the next page is an
+articles -- articles of organization for Florida limited
+liability company. Do you see that?
+A.
+Yes, sir.
+l. And then on the very last page, is that your
+signature?
+A. Yes, sir.
+l. Okay. Is that your application to organize
+the Florida limited liability company, Alessi
+Properties, LLC?
+A.
+Yes. I just sign it. This was done by the
+lawyer.
+Did Jeffrey Epstein have anything to do with
+the creation of this company?
+A.
+Absolutely nothing.
+e.
+Did Jeffrey Epstein pay for Mr. Fetterman's
+services to do this?
+Electronical signed by Sandra Townson 1401-1
+3afc3ca0-c86c-4b9f-8d01-ba20bcae87de
+
+
+Page 152
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+Absolutely no.
+e.
+Now, this was
+-- this Alessi Properties, LLC,
+it appears to have been incorporated in August of 2003.
+Do you recall that? Does that sound correct?
+A.
+Yeah.
+And between December of 2002, when you left
+Mr. Epstein's employment, and August of 2003, when you
+incorporated Alessi Properties, LIC, did you speak to
+Jeffrey Epstein?
+A.
+Never spoke again.
+l. Or with anybody on his behalf, such as his
+staff or an investigator for him? Anybody?
+A.
+Nothing.
+Okay. Did you go to his home between January
+and August of 2003?
+A. No. Except twice, the two incidents that it
+happened.
+e.
+But those -- and those happened later, after
+August of 2003, correct? Those happened either --
+A. Yeah. I never went to the home for any reason
+to talk to him or to anybody.
+Okay. So in September and October when you
+e.
+went to Mr. Epstein's house --
+A.
+Yeah.
+R.
+-- uninvited, --
+
+
+Page 153
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+Uh-huh.
+e.
+-- you just assumed that he would have money
+in his briefcase?
+A. I assume.
+Q. You hadn't talked to him in nine months; is
+that your testimony?
+A. That's my testimony.
+e. And you said that you needed that money
+because of a woman that you were mixed up with?
+A.
+That's correct.
+What's her name?
+A.
+Eva DaSilva (phonetics).
+And where does she --
+A. I'm sorry. Vonia DaSilva (phonetics). I
+already forgot the name.
+Vonia?
+A.
+Vonia DaSilva.
+Where is she now?
+Where does she live?
+A.
+I have no idea. She left -- she left the
+state. She was a girl from Brazil. The biggest mistake
+of my life.
+Q.
+And then you said during the questioning of
+one or two of the attorneys that you entered into a
+separation agreement with Mr. Epstein that included a
+confidentiality agreement and a release. Do you
+
+
+Page 154
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+remember saying that?
+A.
+Yeah.
+MR. CRITTON: Form.
+BY MR. BERGER:
+Q. And those were signed by you?
+A. And Mr. Epstein.
+l. And was that signed after the October
+incident?
+A.
+No. This was signed in January 2003.
+When you left?
+A.
+Right after I left.
+Okay.
+A. Right after I left, it was done through the
+office in New York. Mr. Epstein never spoke to me
+again. It was done through the lawyers in New York.
+They send me the paper via Fed Ex. They send us a
+check. That was the end of it. That happened in
+January, January 2003.
+e.
+Do you have a copy of those documents?
+A.
+Not in here.
+e.
+Do you have them at home?
+A.
+Yes, I do.
+And let me just make sure I know what the
+documents are.
+There's a separation agreement?
+Electronical signed by Sandra Townsend (4011
+3afc3ca0-c86e-4b9t-8d01-ba20bcae87de
+
+
+Page 155
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+Just a separation agreement.
+And that includes a confidentiality provision?
+A. It was a -- there's a provision inside.
+l. And it also includes in it a release or is the
+release separate?
+A. I don't know.
+Lawyer terms. I'm not familiar
+with that.
+l. Did you have a lawyer represent you in
+connection with that?
+A.
+No. I never need it.
+l. And you said Mr. Epstein paid you $30, 000 to
+you and $20,000 to your wife?
+A.
+That's correct.
+And how was that paid to you?
+A. Cash -- I mean, check. It was a check but it
+was taken -- taxes were taken out. So it was minus
+taxes.
+Was it one check for each of you?
+A. Yes.
+MR. CRITTON: Can we take a five-minute break?
+MR. BERGER: Sure.
+MR. CRITTON: Do you want to finish one line
+of questioning?
+MR. BERGER: No, go ahead. Go ahead.
+VIDEOGRAPHER: Off the record at 2:15.
+etonialy sland by and Tom 401)
+
+
+Page 156
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+(Brief recess.)
+VIDEOGRAPHER: we're back on the record at
+2:21.
+BY MR. BERGER:
+e. How many times have you talked with
+investigators of Mr. Epstein?
+A. One time.
+And that's the one time that you've mentioned
+already?
+A. Yes.
+e. And have you met -- talked to Mr. Critton
+before today?
+A.
+Oh, wait a minute. Sorry. I have to go back
+on that. Iwice. One time when the criminal case
+started when they, like, find the card and Jeffrey says,
+I cannot talk to you, somebody will call you. I talked
+the investigator that I told you.
+And the second time was, I guess, you - I
+don't know who was it, but they send -- they send me
+the -- I don't know if it was an investigator or they
+just give me your notice that I was going to be
+subpoena.
+MR. CRITTON: I think that came from
+Mr. Willits' office.
+MR. WILLITS: Jack Hill's office.
+Electronicaly signed by Sandra Townsend (401-
+
+
+1
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 157
+MR. CRITTON: That wasn't an investigator. It
+was a subpoena server?
+THE WITNESS: Yeah.
+BY MR. BERGER:
+l. Process server. Process server.
+Now, this is Mr. Robert Critton. Have you
+talked to him before today?
+A. Yes, sir.
+e.
+A.
+How many times have you talked to Mr. Critton?
+Once in my house. And we talk about ten
+minutes yesterday? Monday? Monday?
+e.
+Yesterday?
+A.
+Yesterday.
+Okay. And what did you discuss?
+A. Discuss the same questions that you telling
+me. And he told me basically, say the truth. Tell the
+truth, nothing but the truth. And be firm and be —-
+speak your mind and don't be afraid.
+I thought that this incident about my life
+never would have come out. I wish it would have never
+come out. But I guess it come out and it's too late.
+Well, you know what this case is about, don't
+you?
+A. Of course. I think it's a case against
+Mr. Epstein. But it's not a case against me, is it?
+Electrenialy lined by Sandra Townsend 401-1
+
+
+Page 158
+1
+2
+3
+e.
+A.
+e.
+No.
+Oh.
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+21
+25
+And you know it's --
+(Brief interruption.)
+BY MR. BERGER:
+Q. And you know it's a serious case for the
+people that are bringing it?
+THE COURT: Form.
+THE WITNESS: Absolutely.
+BY MR. BERGER:
+e. So you had this conversation with Mr. Critton
+yesterday?
+A. Not about the seriousness, no.
+R.
+No. No. But the conversation that you had
+with Mr. Critton was yesterday, correct?
+A. Yes. Told him he -- he told me basically he
+was going to be here, that a bunch of lawyers were going
+to ask me questions and that I should be truthful and
+nothing else, basically.
+e.
+Well, what else did he say?
+A.
+What else did Mr. Critton says? Nothing. He
+asked me about my health, because I was in the hospital
+this week. He asked me how I felt.
+And I says, well, I want to get this done. I
+want to get it over, done, and go on with my life for
+Electronicaly signed by Sandra Townsend (401 )
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+Page 159
+the rest of my life. I want to finish with this. I
+don't want nothing to do with Jeffrey Epstein or this
+case, once and for all.
+l. Did you talk to him about the confidentiality
+agreement that you mentioned?
+A.
+No.
+Or the separation agreement?
+A.
+No.
+Or the arrest?
+A.
+e.
+A.
+No.
+Or the $30,000 that you were paid?
+No.
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Did he tell you that this case that we're here
+about --
+A.
+$30,000 where? What $30, 000?
+You said you were paid $30,000 and your wife
+was paid $20,000.
+A.
+Yes. Yes. The separation agreement.
+No.
+No.
+e.
+A.
+You didn't talk about that?
+No.
+e.
+Did he tell you there were young women suing
+Mr. Epstein? Did he tell you that yesterday?
+A. No. He mentioned to me that it was a lot of
+lawsuits against Mr. Epstein, criminal and civil suits.
+Electronicaly signed by Sandra Townsen 1401-7
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 160
+And -- not yesterday, but when he was in my house with
+his secretary.
+Not yesterday?
+A. Not yesterday.
+e. When was he was at your house with the
+secretary?
+A. About two months ago, a month and a half ago.
+You can't look to him to answer. You've got
+to answer.
+A. I cannot remember exactly the date, but I
+would say it was about a month ago.
+Maybe I misunderstood. Was Mr. Critton at
+your house yesterday?
+A.
+No. He called me yesterday.
+e.
+He called you yesterday?
+A.
+Yes, sir.
+e. And you talked for about ten minutes yesterday
+on the phone?
+A.
+No more.
+l. Did you tell me everything that you and
+Mr. Critton talked about yesterday?
+A.
+Yes.
+Now, he visited your house --
+A.
+Yes.
+-- a month and a half or two months ago --
+Electronicaly signed by Sandra Townsend 401,
+
+
+Page 161
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+A.
+e.
+A.
+A.
+e.
+A.
+A.
+e.
+A.
+e.
+A.
+Absolutely.
+-- with his secretary?
+Yes.
+And did she take notes?
+Yes, she did.
+Pardon me?
+She did.
+She took notes.
+Just by pen and paper?
+Pen and paper.
+Not a machine like the court reporter?
+No.
+Were you taped? Did somebody tape record you?
+No.
+Did he show you the notes that she took down?
+No.
+No.
+Typed up and show you the transcript?
+A.
+e.
+No? Now, how long was Mr. Critton at your
+house then?
+A.
+For about half an hour.
+And did you know that he was coming? Did he
+call ahead of time?
+A.
+Yeah.
+And, so, what did you expect was going to
+happen?
+Electronitaly signed by Sandra Townsen 1401)
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 162
+A. He was going to come in and ask questions
+about this case.
+So what did he say?
+A.
+Same questions that you guys are asking me,
+exactly the same questions.
+Nothing more?
+A.
+Basically what you saw, what you did, what
+your job description was, what you did, how you start
+your day, how was your day and how was -- what time you
+started, what time you finish and what you did, and what
+was your responsibilities. And that was it.
+Okay. And were you paid anything for that?
+A. Absolutely not. The only money that I got, it
+was from you for this $47 check for coming in here.
+Okay.
+A. And I will take no money from nobody.
+Q. Okay. Were there -- were there any other
+times that you talked to either Mr. Critton or anybody
+from his office?
+A.
+No.
+You described every time that you've ever
+talked to either Mr. Critton or people from his office?
+A.
+e.
+No, sir.
+You've described all those times that you've
+talked to Mr. Critton or people from his office? I'm
+
+
+Page 163
+1
+2
+3
+4
+5
+6
+7
+not asking the question clearly.
+Did you talk to Mr. Critton any other time?
+A. No. I talked to Mr. Critton twice, once in my
+house, once yesterday.
+Now, how about Mr. Jack Goldberger,
+Mr. Epstein's criminal defense attorney, did you ever
+talk to him?
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+No.
+of these matters?
+Did you ever talk to Alan Dershowitz about any
+A.
+No, sir.
+2.
+Or Roy Black?
+A.
+No, sir.
+l. Now, I'm just going back over some different
+things that you mentioned.
+You said that there was a Roladex that you
+created of names of women?
+A.
+Not it was a name just woman. It was
+companies, air condition companies. It was cleaning
+companies. It was suppliers. And it was -- it was a
+Roladex that I left it there.
+Did you have a list of girls on your Roladex?
+MR. CRITTON: Form.
+THE WITNESS: No. We had a list of girls in
+a -- in a -- in a sheet with plastic that we have
+Electronitaly signed by Sandra Townsen (401-4
+3afc3ca0-c8Ge-4b9f-8d01-ba20bcae87de
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 164
+all the massage therapists. It was two pages or
+three pages of people in a plastic sheet that we
+had it where -- by the telephones. That was it.
+BY MR. BERGER:
+e.
+A.
+2.
+A.
+Uh-huh.
+A.
+e.
+A.
+A.
+A.
+Have the names?
+Names and phones.
+Telephone numbers?
+What about addresses?
+No, no addresses.
+What about dates?
+No, sir.
+And who prepared the list?
+Either Ms. Maxwell -- Ms. Maxwell.
+Was it typed?
+Yeah. They were types.
+No. Typed.
+A.
+Yeah.
+Who typed it?
+A. I don't know who type it, but it came from New
+York.
+The list?
+A. Yeah.
+l. Did you -- did you give the information that
+went into the list?
+3afc3ca0-c86e-4b9t-8d01-ba20bcae87de
+
+
+Page 165
+1
+2
+3
+4
+5
+6
+7
+8
+A.
+No.
+Where was the list kept?
+A. In many places. It was in Mrs. Maxwell's
+desk. It was one in the kitchen, one in my office, one
+in my room because sometimes I was in my room and I have
+to call these people. It was one in the new house when
+they build the new house. It was all over. And it was
+also those -- those files for the house -- the house
+running operation.
+Was it the same list that was in all those
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+places?
+A.
+A.
+Basically, yes.
+Was the list updated?
+Yes.
+Did you keep a copy of the list?
+A.
+No, I don't have a copy of the list.
+Q.
+When you left Mr. Epstein's employment, you
+didn't take a copy with you?
+A.
+Not at all.
+Q. And when you worked for Mr. Epstein, you
+didn't write notes about what you did and what you saw?
+A.
+NO.
+No?
+A.
+No. I had too much to do.
+e.
+You didn't put anything in a computer about
+
+
+Page 166
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+what you saw at the house?
+A.
+No, sir.
+l. Did you ever talk to your wife about what you
+saw at the house?
+A.
+Like what? Saw about what?
+2. About the dildos. About the massages. Did
+you ever talk to your wife about that?
+A. Yeah. And that's one of the reasons that I
+never send my wife after -- this hap -- these dildos and
+things like that happened right at the end of my stay
+there. It never happened before. Right at the last
+couple months before I left. And that --
+e.
+And that's when young girls --
+MR. CRITTON: Let him finish his answer.
+THE WITNESS: And my -- my worry about was
+that my wife will panic. And I never send her up
+there to clean up the rooms or anything else.
+BY MR. BERGER:
+Is that when young girls started coming to the
+house?
+MR. CRITTON: Form.
+THE WITNESS: One girl that I can think of.
+BY MR. BERGER:
+e. Just one?
+A. One girl. That girl that she show me the
+Electronical lined by Sandra Townsen 401)
+
+
+Page 167
+1
+2
+3
+4
+5
+6
+7
+8
+picture.
+e.
+1?
+A.
+That's the only one that I can think she was
+young, but I don't know how old.
+2. Do you still have the transcript from -- from
+the police in front of you, from the State Attorney's
+Office?
+It's below that. It's at the bottom. Keep
+going.
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+You see? Turn to page 9.
+Page 9. Now, look at me. It says, page 10,
+but it also says page 9.
+So you got page 9?
+A.
+Page 9 and page 10.
+Okay.
+A.
+2.
+oh, okay. Page 9. Okay.
+I want you to see page 9.
+MR. CRITTON: You want the transcript page 9?
+MR. BERGER: Yeah.
+BY MR. BERGER:
+l. Let me just make sure you're on the right
+page. Yeah.
+Look at line 13.
+It says, answer: "No, sir. Mostly no. We
+saw one or two young ones in the last year."
+Electronically signed by Sandra Townsend 401-1
+
+
+Page 168
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Do you see that?
+MR. CRITTON: Form. It's taken out of
+context. There's no question.
+BY MR. BERGER:
+Do you see those words?
+A. Did they seem -- did they seem young to you?
+No, sir, mostly were no. We saw two young ones in the
+last year.
+l. Well, it actually says, "we saw one or two
+young ones in the last year."
+A.
+"We saw one or two young ones in the last
+year. Before that they were all adults."
+Q. The one or two young ones in the last year
+that you're referring to, who are they?
+A.
+One was I. and the another one was
+l. Don't write on that. Okay? Don't write on
+that with your pen.
+Look at paragraph -- look at line 19.
+A.
+Yes.
+It says, quote, I remember one girl was young,
+unquote.
+Do you see that?
+A.
+Yeah.
+MR. CRITTON: Form.
+BY MR. BERGER:
+Electronicaly signed by Sandra Townsen 1(401)
+
+
+Page 169
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+e.
+Who were you referring to?
+A.
+Q. And then you see under that at line 22, it
+says, quote, but I imagine she was 16, 17. In my
+judgment she was 16, 17, unquote.
+Do you see that?
+MR. CRITTON: Form.
+THE WITNESS: Yeah.
+BY MR. BERGER:
+Were you referring to
+?
+MR. CRITTON: Form.
+THE WITNESS: I think so, yeah.
+Oh, can I read this again?
+BY MR. BERGER:
+l. Sure, go ahead. Take your time.
+A. "During the last year while you were working
+for him, what do you mean, they look young? Did they
+look like they were still in high school? Yes. And the
+only one that I knew was in high school was N. I
+remember one girl was young. We never ask her how old
+she was. I never asked N. how old she was. I think she
+was in the last year of high school.
+Right. Understand.
+Question.
+But I imagine she was 16, 17. I don't know.
+Electronical signed by Sandra Townsend 4014
+
+
+Page 170
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+In my judgment she was 16, 17."
+I was talking about, I was referring about N.
+at that time.
+l. So at line 22, 1o0k at line 22.
+A. Yes, sir.
+e.
+It says, quote, but I imagine she was 16, 17,
+unquote.
+You were referring to who?
+A.
+e.
+To N.
+Okay. You can put that down.
+You mentioned Joe Joe. You said Joe Joe was
+the house man in New York?
+A.
+Yes. I met Joe Joe.
+And do you know
+his full name?
+A.
+Joe Joe work with his wife. They were
+Funtanella (phonetics), Funtanella. Joe Joe and Lynn
+was his wife, Funtanella.
+When is the last time you talked to them?
+Wow.
+Never talked to them again in over ten
+A.
+years.
+e.
+Now, you mentioned in response to Ms. Ezell's
+questions, you said something about 's father. Do you
+remember talking about that?
+A.
+Uh-huh.
+e.
+How do you know that person was her father?
+Electronical signed by Sandra Townsend 4011,
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 171
+A.
+Because either she told me or Ms. Maxwell told
+me that her father used to work at Donald Trump's place.
+And she -- I think he is the one who bring her to the
+house that afternoon, the first time I san
+drive in
+at this -- Donald Trump's house.
+Now, you said you know -- you knew who Alan
+Dershowitz or you know who Alan Dershowitz is, right?
+A. Many times.
+e.
+And he was at the house?
+A.
+He's been at the house a lot of times.
+Was he ever at the house when there were naked
+women at the house?
+A.
+No.
+No?
+A.
+They were never naked woman at the house, sir.
+I remember one occasion when one English
+girl -- I think she was English or German girl -- came
+to the house. And usually in Europe they use topless,
+they don't wear anything. But she was taking the sun
+outside and she came to the house with nothing on and I
+chase them out. I says, not in this house. You don't
+do it. You go outside, put the towel and come in here.
+Because she came to get something from the kitchen
+wearing nothing. And I did not allow that.
+l. But when Alan Dershowitz was there, were there
+
+
+Page 172
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+any women that were topless?
+A.
+e.
+No, not that I can remember.
+What about when Prince Andrew was there?
+A.
+Not that I can remember, sir.
+l. Did you ever see Alan Dershowitz walking
+around naked?
+A. No, sir.
+How about Prince Andrew?
+A.
+No, sir.
+You mentioned your divorce, that it cost - it
+cost money. Did Jeffrey Epstein pay for anything
+connected with the divorce?
+A.
+Absolutely nothing.
+e.
+Let me go back for a minute to the
+confidentiality provision in the separation agreement.
+Did you - did you discuss with anybody why
+there had to be a confidentiality provision? Did you
+talk to somebody about that?
+A.
+No. No. I discuss it with Mr. Epstein when
+he told me, he finally come out and says, John -- I know
+they were going to try to replace us. And -- and we got
+upset because I was not ready to leave yet. But at the
+same time we were expecting to be left out. And I left
+there before they decide to let me go.
+And I went to -- I remember very clearly, I
+Electronical signed by Sandra Townsend 401)
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 173
+went to his office in the pool house and it was -- I
+talk to him and says, John, -- I went with some faxes
+that came to my office and they were people interviewing
+* for my job. So I feel very pissed about it.
+And I went to his office and said, Jeffrey,
+what is this? And what is this? And what is this?
+He says, well, that's Ghislaine. I'm not
+involved into that.
+And I says, okay. We're going to leave,
+Jeffrey. That's it. We're done. And what you going to
+do for me?
+And he says, well, what you want?
+And I says, give me at least a year's salary.
+And that's what it turn out to be, around
+$50,000, plus the van.
+And he says, okay, John, wish you good luck.
+And the last day I was there we shake hands and we left.
+But my relationship with him, it was good. It
+was friendly. At the beginning of the -- my job was
+very friendly. Then he changed when Ms. Maxwell come
+in. I didn't like to work for her. She was a bitch.
+And she make us life hell. And that's why we left. But
+it was not with Mr. Epstein.
+Do you know why there was a confidentiality
+provision in your agreement?
+Electronicaly signed by Sandra Townsend 1401/
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+Page 174
+No. That's lawyer stuff. I don't know.
+MR. BERGER: Okay. That's all I have.
+CROSS EXAMINATION
+BY MR. CRITTON:
+Mr. Alessi, my name is Bob Critton, as you
+know, and I represent Mr. Epstein.
+A. Yes, sir.
+l. You've been -- this deposition started at
+10:00. It's almost -- it's closing in on 3:00 but for
+about 45 minutes or an hour that we took for lunch. I'm
+going to try to be relatively brief so we can get you
+out of here. Okay?
+A.
+Okay, sir.
+l. You've been asked questions by five different
+lawyers who represent various Plaintiffs in this case.
+A.
+Yes, sir.
+l. In some instances you've been asked the same
+question multiple times?
+A.
+Yes, sir.
+e. The testimony -- you've also been asked a
+number of questions about your separation from
+Mr. Epstein sometime at the end of December of '02 and
+the entrance or your entering into a separation
+agreement with him?
+A.
+Uh-huh.
+Electronitaly signed by Sandra Townsend (4011
+3afc3ca0-c86o-4b9f-8d01-ba20bcae87de
+
+
+Page 175
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Correct?
+A.
+Yes.
+e. And subsequently there was an incident in 2003
+that you've described in some detail, based on the
+questions that have been asked, and you and Mr. Epstein
+reached an amicable agreement; you repaid him the monies
+that you had taken and you parted?
+A.
+Yes.
+e.
+Is that a fair statement?
+A. And I will have to add something to that.
+When we talk at the luncheonette, we have coffee, he
+says, John, if you were not my best employee that I ever
+have and that you would not take care of my mother, I
+would have put you away. And that's the way he come out
+to me.
+And I says, I like you and let's -- just pay
+me back in one or two weeks, because I send the money
+back and it got lost. So he give me another -- not him,
+but his lawyer says, you got another month to pay. So
+between I got the money -- the money order was lost in
+the mail. So I send it back. I pay everything, $6,310.
+I think it was 6310. And that was it.
+And I'm more interested, not so much in the
+details, Mr. Alessi, but the color, so to speak, the
+lawyers have put on this, is, is that as a result of
+
+
+Page 176
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+your separation from Mr. Epstein in late-2002 and the
+incident in 2003, that somehow you have colored your
+testimony to help Mr. Epstein today.
+And my question to you is: Have you told us
+the truth today as to every question that's been asked
+and the questions that are going to be asked of you?
+A. To every one of you.
+MR. WILLITS: Object to the form of the
+question.
+BY MR. CRITTON:
+e. And with regard to the agreements that you
+entered into with Mr. Epstein, in particular the
+confidentiality agreement, you were asked a question by
+Ms. Ezell whether you understood that you're not bound
+by confidentiality today. And you responded in the
+affirmative, right? You understand that you're to tell
+us - to answer every question fully to the best of your
+knowledge?
+A.
+Absolutely.
+e.
+And that you have done today?
+A.
+Yes.
+Okay.
+MR. WILLITS: Object to the form of the
+question.
+BY MR. CRITTON:
+Electronitaly signed by Sandra Townsend 1401-
+3afc3ca0-c860-4b91-8d01-ba20bcae87de
+
+
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 177
+e. You told us off the record -- and I don't know
+whether it was on the record, so I want to be clear
+because you've been sitting here a long time. You're
+currently under care and treatment for having
+chemotherapy; is that correct, sir?
+A.
+Yes, I have.
+Q. And I think you told us earlier that you were
+in the hospital two days last week?
+A. Last week, yeah.
+l. And, so, we've -- you've done great. You've
+probably done better than the lawyers today. But you'd
+like to get this over today and finished?
+A.
+I hope so.
+All right. There have been a lot of questions
+about your job description and duties at Mr. Epstein's.
+And if I understood it correctly, is basically, once you
+became the full-time house manager, you were responsible
+for all aspects of the operation of the El Brillo
+residence?
+A.
+I was.
+MR. WILLITS: Object to the form of the
+question.
+BY MR. CRITTON:
+And during the time that you were responsible
+for all aspects of the El Brillo residence, that
+Electronical signed by Sandra Townsen (401l)
+
+
+Page 178
+1
+2
+3
+4
+5
+included not only maintenance and repair, but
+appropriate staffing, laundry, cleaning, shopping,
+cooking, whatever -- whatever needed to be done at the
+home?
+A.
+That's correct.
+MR. WILLITS: Object to the form of the
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+question.
+BY MR. CRITTON:
+And during the time that you were there as the
+full-time -- as the house manager from 1992 up until
+December of 2002, you did all those different types of
+responsibilities; is that a fair statement?
+A.
+Yes.
+MR. WILLITS: Object to the form of the
+question.
+BY MR. CRITTON:
+l. And at some point -- let me strike that.
+The original deal, so to speak, that you cut
+was with Mr. Epstein; that is, when you became the
+full-time house manager; is that true?
+A.
+That's true.
+l. And some point within -- what?
+-- a year or
+so, I think Eva -- Eva --
+A. Eva.
+l. Anderson --
+
+
+Page 179
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+Left.
+e.
+-- was no longer Mr. Epstein's -- Dr. Eva
+Anderson was no longer Mr. Epstein's girlfriend, --
+A.
+That's correct.
+e.
+-- and a new girlfriend came in and that was
+Ghislaine Maxwell?
+A. That's correct.
+l. And when Ms. Maxwell came in, she, in essence,
+took over as your immediate supervisor?
+A. That's correct.
+l. During the time that you worked for
+Mr. Epstein, did you have a good, excellent, fair, what
+was -- how would you describe your relationship with
+him?
+A.
+Good, excellent or fair.
+I will think good.
+l. And did you interact with him very much or
+does he interact with anybody very much?
+A.
+He doesn't interact very much. At the early
+years, yes, he did come to the kitchen and we used to
+sit down in the kitchen and he would discuss my kids, my
+family, his family, and he will talk to me.
+At the end of my stay there, it was - I
+was -- we were told not even to look at his face. Not
+even to -- this was done by -- this was even done by,
+
+
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 180
+they hire a Countess from Europe to write this book and
+to write ideas of how the house of royalty should be.
+And that's the way Ms. Maxwell wanted the house to run,
+as a royal house. And I was pissed off at that and I
+never agreed with that and I never went with the book.
+I threw the book away. And that was it.
+MR. CRITTON: Let me move as non-responsive to
+my question. Move to strike.
+MR. WILLITS: He should allowed to finish what
+he thinks is responsive to your question, even if
+you don't agree.
+BY MR. CRITTON:
+Were you finished, sir?
+A.
+Yes, I finish.
+MR. CRITTON: See, he's finished.
+MR. WILLITS: He wasn't, but okay.
+BY MR. CRITTON:
+I'm trying to -- listen carefully to my
+question because I'm trying to get you out of here
+sooner rather than later.
+If I understood your testimony is, is that,
+you had -- you considered your relationship with
+Mr. Epstein to be good during those years?
+A.
+Good.
+And would you describe your relationship with
+Electronical signed by Sandra Townsend 1401 L
+
+
+Page 181
+1
+2
+3
+4
+5
+Ms. Maxwell as not being as good?
+A. Yes.
+e. When -- you were -- you had an opportunity
+over lunch, Mr. Berger gave you a copy of a statement
+that you gave to the State Attorney's Office on
+November 21, 2005, we've marked as Exhibit, I think,
+Exhibit --
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR. CRITTON: What did we mark it as, 2?
+THE WITNESS: At what page?
+MR. WILLITS: Yes.
+It was 2.
+MR. CRITTON: Thank you.
+BY MR. CRITTON:
+No, just statement, the whole statement.
+You had an opportunity to look at it over
+lunch?
+A.
+Yes.
+November 21st of 2005?
+And that's a statement you gave back on
+A.
+Uh-huh.
+e.
+A.
+Is that correct?
+That's correct.
+Q. And at that time you were there with
+Mr. Murrell, who was your attorney. And you gave a
+statement and I think as well your wife spoke with the
+State Attorney's Office?
+
+
+Page 182
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+That's correct.
+2. And whatever questions the State Attorney
+asked of you at that time, I assume you fully answered;
+is that correct?
+A.
+Absolutely.
+e. And then page 9 where Mr. Berger took you with
+regard to the questions -- and before I get -- I'm going
+to come back to page 9 in a minute.
+But if I understood your earlier testimony in
+response to one of the lawyers who asked you questions,
+is, there were a number of European women, all who you
+deemed to be 20-plus years old, that would travel with
+Mr. Epstein to various places and as well would come to
+the house from time to time?
+A.
+That's correct.
+2. And I think you testified in response to
+Mr. Berger's questions today, is that the only female
+that you understood that came to the house during the
+time that you were the house manager who you knew to be
+under the age of 18 was
+1.?
+A.
+That's correct.
+Q. And you knew she was under 18 because you
+would pick her up from high school?
+A. That's correct.
+2. And that's a young girl who I think you
+
+
+Page 183
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+said --
+A.
+16, 17.
+l. And I think you said she never was involved in
+giving any massages to Mr. Epstein?
+A.
+I don't think so, never.
+e. And the times that you saw her, Mr. Epstein
+was mentoring her on a career which ultimately turned
+into her becoming an actress?
+A. I think so. Yeah, that was the main purpose.
+e. And on multiple occasions when she would be
+over, she would be over there at Mr. Epstein's home with
+her mother; is that correct?
+A. Yes, that's correct.
+Q. And of the girls that came or the women that
+came to give massages to Mr. Epstein over the years you
+were there, I think you've described on page 9 of your
+deposition that you may have seen a hundred or 200
+different massage therapists?
+A.
+It could be less. I don't think it's more
+than 200, but it could be less than 200, yes. It was --
+it was 11 years or 12 years or 13 years of constant
+people going in and out and people that were coming to
+the house, he will bring for another state, he will
+bring in his planes. People that it came from Europe,
+massage therapists, there were men and woman. They live
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 184
+in Miami, we -- so it was so many that I cannot remember
+how many.
+Okay. And I understand that. I'm just
+referring back to your statement where it says at page
+9, line 9, the question was:
+"Yeah. Yeah. Not the
+same girl. I mean, during 11 years I probably saw a
+hundred, 200 different massage therapists."
+Do you see that?
+A.
+Yes.
+l. All right. And if I understood your testimony
+is, the ones the -- that is, of the massage therapists,
+as you've just described, you saw some men?
+A.
+Yes.
+e.
+You saw more women?
+A.
+More woman.
+l. And all of the women, at least from your
+viewpoint, were 18, 19 or older?
+A.
+Yes.
+MR. CRITTON: Why don't you change your tape
+right now.
+VIDEOGRAPHER: Off the record at 2:54.
+(Brief recess.)
+VIDEOGRAPHER:
+We're back on the record at
+2:55.
+BY MR. CRITTON:
+3afc3ca0-с8бе-4b9f-8d01-ba20bcae87de
+
+
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 185
+l. Mr. Alessi, in the 11 years that you worked
+for Mr. Epstein, with regard to the massage
+therapists -- and I'm talking about all of them, women,
+men, the ones that were 18, 19, 20, or the ones that
+were older -- did you ever see -- or, first of all, did
+you ever hear any complaints about - from the massage
+therapists about the massage they had given to
+Mr. Epstein?
+A.
+No.
+l. Did you ever see a massage therapist during
+those 11 years that appeared to you to be distraught?
+A.
+e.
+A.
+Never.
+To be in some form of a shock?
+Never.
+To be scared?
+A.
+I never see anybody scared.
+l. Did you ever see someone who looked like they
+were upset or crying?
+A.
+No, sir.
+e. I think you, in response to Mr. -- well, not
+sure who asked the question -- but they -- you were
+asked whether you ever spoke to the individuals --
+A.
+Yes.
+-- when they came down. And I think you said
+from time to time you might have some small talk with
+
+
+Page 186
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+them afterward?
+A.
+Yeah.
+l. Did you usually see them if they came down?
+A.
+Yeah.
+e. So you would have had an opportunity to
+observe their appearance, correct?
+A. That's correct.
+l. Have you seen people who look distraught, in
+shock, scared, upset, angry in the past -- not massage
+therapists -- have you seen people in your life
+experiences?
+A.
+Oh, yeah, yes.
+MR. MERMELSTEIN: Object to the form.
+BY MR. CRITTON:
+Q.
+So if -- well, let me ask it this way: In
+your life experiences before you worked for Mr. Epstein,
+and, in fact, during the time you worked for
+Mr. Epstein, have you seen individuals not associated
+with Mr. Epstein who appeared to be distraught, in
+shock, scared, upset, angry or injured?
+A. Yes.
+MR. MERMELSTEIN: Object to form.
+BY MR. CRITTON:
+e. Have you seen people who appeared to you to
+have been traumatized by a particular event?
+Electentaly lined sy sandra Townsen 401-l
+
+
+Page 187
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR. MERMELSTEIN: Object to form.
+THE WITNESS: Yes.
+BY MR. CRITTON:
+R.
+Have you seen people who seem to be -- well, I
+assume you've seen people who have yelled or screamed as
+a result of some event that had occurred in your
+presence?
+A.
+Yes.
+On the massage therapists that you saw at
+Mr. Epstein's house from 1992 up until the time you left
+in December of '02, did you ever see any type of
+reaction, distraught, shock, scared, upset, crying,
+disheveled, injured, disoriented, yelling or screaming
+for help at any time?
+A.
+e.
+No, sir.
+Once the massage -- once -- let me strike
+that.
+If I understood your testimony, you helped set
+up -- either you set up the room or you helped set up
+the massage room?
+A.
+Uh-huh.
+And you might be the person or it might be
+someone else who would lead the massage therapists or
+the female up to the room, the male or the female up to
+the room?
+
+
+Page 188
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+A.
+Yes, sir.
+l. Once that person was upstairs, you then would
+come back down and resume your multiple duties
+downstairs?
+A.
+Absolutely.
+l. As to what occurred during the course of a
+massage, do you have any personal knowledge during the
+11 years you were there?
+A.
+There was absolutely no way to know or to get
+into the room. The windows were what they have, those
+automatic electric shutters. They were completely dark,
+completely a hundred percent dark, the rooms. And it
+was -- nobody saw it. I knew it when I was at the house
+that I never saw anything was going on inside.
+e.
+So you have no personal knowledge what
+occurred during any particular massage?
+A.
+Nothing.
+e.
+And I think you said - well, let me strike
+that.
+21
+22
+23
+24
+25
+In other individuals whom you have done work
+for at big houses in Palm Beach, did those people from
+time to time have massages, too?
+A. I never work in a house inside as I did work
+for Mr. Epstein.
+l. Yours was outside maintenance work?
+Electronical signed by Sandra Townsend 401 l
+
+
+Page 189
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+I was the maintenance guy outside.
+All right. And if -- well, let me strike
+that.
+You're aware that there's all sorts of spas.
+The Breakers? PGA? Trump?
+A. Absolutely.
+Q. The Ritz Carlton? The Four Seasons? And
+probably a thousand other places in Palm Beach County?
+MR. WILLITS: Object to the form of the
+question.
+BY MR. CRITTON:
+l. Well, let me strike that.
+Are you aware that there's more than ten
+places that someone can get a massage in Palm Beach
+County?
+A.
+Of course.
+Are you aware that there's probably more than
+a hundred places, maybe a thousand places in Palm Beach
+County from Boca Raton up through Jupiter and all the
+way out west where people can get a therapeutic or a
+massage?
+A.
+Yes.
+e.
+And I assume you were aware that -- or were
+you aware of that during the time period that you worked
+for Mr. Epstein?
+
+
+Page 190
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+Yes.
+Q. And I think you told us that you were aware
+that there were massage schools?
+A. Yes.
+e.
+And is it your understanding that generally
+massages are given in a -- in a room with a table where
+the lights are generally turned down?
+A.
+And music on, yeah.
+l. All right. You were asked a question about
+vibrators or I think that the word was sex toys.
+If you'll turn to page 20 of your statement,
+sir.
+If you look at page -- if you just glance at
+line 9 --
+A.
+e.
+Okay.
+- through line 22. Take a chance. If you'll
+just look at that, then I'll ask you a couple questions.
+Read to yourself, please. Otherwise, the
+court reporter will have to take down everything you
+say.
+A.
+Yeah.
+Q. And at least the statement that you gave back
+in -- on November 21st of 2005, almost -- almost four
+years ago now, you describe that there were -- that you
+saw two types of massagers or vibrators; is that
+Electronitaly signed by Sandra Townsend (4011
+
+
+Page 191
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+correct?
+A.
+That's correct.
+l. And is that your best recollection, as you sit
+here today?
+A. That's the best recollection.
+And one of the vibrators, you said was, as you
+described earlier, looked like a dildo?
+A. Right.
+And --
+MR. WILLITS: Object to the form of the
+question.
+BY MR. CRITTON:
+Well, let me ask you this: Was the item that
+you described, that's described at lines 12, 13 and 14,
+and 15 - 12, 13 and 14 on page 20, is that what you
+described, is that what you were talking about as the
+dildo?
+A. Yes.
+And I assume you're familiar with what a dildo
+is?
+A.
+I know that it's one of those --
+e.
+You don't have to describe it. Just are you
+familiar with what one is?
+A.
+No, I don't. I'm not really familiar with
+that type of instruments. But what did I saw it and is
+Electronically signed by Sandra Townsen 1401 l
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+21
+25
+Page 192
+it true now, is it true when I make this statement, it
+was a big rubber man's --
+l. Penis?
+A.
+-- looking penis, with double head, two heads.
+e. And --
+A. And I don't know how is it even called. And I
+am sorry. It's a little unpleasant.
+R.
+That's all right.
+The second item that you described was a neck
+and back vibrator; is that correct?
+A.
+Yeah. They have this vibrators, they have the
+cordless and they have these balls and they have
+different types of those vibrators, too.
+Like you can get them at Brookstone or
+something like that?
+A.
+Yeah. Yeah. Yes, sir.
+l. So at least when you were at Mr. Epstein's,
+and I think as you described in response to lawyer's
+questions today, is during the last couple of months
+that you worked at Mr. Epstein's you saw these two
+vibrators?
+A.
+Yes.
+e. And on those two occasions you'd take those
+vibrators, if you went up to clean afterwards, you'd put
+on your gloves, pick them up with a towel and you'd
+Electronicaly signed by Sandra townsend 4011
+
+
+Page 193
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+11
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+clean them off and you'd put them back in
+Mrs. Maxwell's --
+A.
+Closet.
+-- closet in her bathroom?
+MR. WILLITS: Object to the form of the
+question.
+THE WITNESS: I put it back in the closet and
+inside the closet there was a laundry basket that
+is where she had those.
+BY MR. CRITTON:
+2. And as to whether or not someone actually used
+those items or how they were used, all you know is you
+found them --
+A.
+I find it in the sink.
+MR. BERGER: Objection. Mr. Critton is
+testifying. Leading.
+MR. WILLITS: Objection, also, to the form.
+BY MR. CRITTON:
+e.
+Let me ask you this: Do you know, if I
+understand it correctly, you found the two vibrators,
+one for the neck and back and the other one that you
+described as a dildo, you found them in the sink on
+those few occasions near the end of your employment?
+A.
+Yes.
+MR. BERGER: Objection. Testifying. Leading.
+
+
+Page 194
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+THE WITNESS: I find it in the sink.
+BY MR. CRITTON:
+e. And then you would clean up and put it back in
+Ms. --
+A. I will put my rubber gloves, get a towel, put
+them under the sink, run the water and put them in the
+closet.
+Q. And you put them back in Ms. Maxwell's closet?
+A.
+Closet.
+e.
+Why? Why into her closet?
+A.
+Because they were always kept there.
+l. All right. You testified earlier, is that if
+you were going to call someone for a massage, it would
+either be you or Ms. Maxwell, if I understood you
+correctly?
+A.
+Yeah.
+l. Okay.
+A. At the end -- at the end of my stay was also
+another girl, Sarah, Sarah that came. And then she was
+handling everything, as far as calls to these girls.
+l. Did Mr. Epstein ever make these calls?
+A. I never heard.
+l. If Mr. Epstein was not in residence, that is,
+if he was in New York or some place else other than Palm
+Beach, did you and your wife still stay at the home or
+
+
+Page 195
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+would you go to one of your apartment?
+No. We went to our apartment.
+l. And then when he wasn't there, would you have
+pretty more regular hours around the house?
+A.
+Pretty much. Pretty much, yeah. That was the
+days that we had to have the cleaning crew, I still had
+to go to the house and oversee the cleaning operation,
+oversee the gardener because there was not, when they
+were there the gardener weren't supposed to make noise,
+so we have to take care of the pool, the chlorine and
+all that stuff.
+l. So you would still do your regular but you
+could finish pretty much 9:00 to 5:00?
+A. Yes. That was much easier.
+e. And when he was -- how often would he
+generally be in Palm Beach?
+A. Too much.
+l. All right. But if -- would he be here at
+least a couple --
+A. I would says, at least three times a year -- a
+month, three weeks a month, three weekends a month.
+Usually they come in on a Thursday. Either they left a
+Monday or Tuesday.
+e. And then they go wherever else they were going
+and then things would get back to more of a 9:00 to 5:00
+Electronically signed by Sandra Townsend (40°
+
+
+Page 196
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+type routine?
+A.
+That's right.
+8.
+And if he was in residence, that's when your
+job became much more all encompassing?
+A. Exhausting.
+l. Okay. You were asked about a female named
+• I think you originally thought it was |
+•, but
+1.?
+A.
+Yeah.
+e.
+You recall now; is that correct?
+A. Yes. Yes.
+e. And I think you described her, I think your
+recollection was, is that you remember her being at the
+house the last few months that you worked for
+Mr. Epstein?
+A.
+Yeah. The last few months.
+l. And that's the only time that you remember her
+actually being there?
+A.
+Yeah.
+Q. Because you actually recall when she used to
+work at Mar-a-lago, and then you recall her starting to
+come to --
+A.
+To the house.
+e.
+-- Mr. Epstein's home?
+A. Right.
+Electronicaly signed by Sandra Townsend 14071
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+Page 197
+l. And I think you testified that at one time you
+had to pick her up and she lived at her house or she was
+living with her boyfriend at some house out in Royal
+Palm Beach; is that correct?
+A.
+That's right.
+l. Did you know anything about
+A. Not necessarily. Not that I can remember. I
+knew the one time either Ms. Maxwell or Mr. Epstein told
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+me that she was arrested because she was working in --
+in the restaurant and she took her -- the tips, her tips
+for that day. And the next day she was arrested and the
+money have to be returned and -- it was something about
+that, but that's it.
+That's all I know.
+l. Okay. Was it -- let me ask you this: Do you
+remember her stealing some money from the Roadhouse
+Restaurant where she was working?
+A. That's what I heard, that it was a report,
+there was a police report.
+All right. And, so, at least you understood
+from Mr. Epstein or Ms. Maxwell that she had stolen
+money from her employment?
+A.
+Yeah.
+Again, you never saw the police report?
+A.
+No.
+Nor the date of it?
+
+
+Page 198
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+No.
+That's correct?
+A.
+That's correct.
+l. And as to whether she repaid the money or what
+happened with that criminal charge, do you know?
+A.
+No, I don't.
+Q. Do you know whether there's an arrest out for
+her -- a warrant out for her arrest at the current time?
+A.
+No, sir.
+e.
+Were you aware of any of her other background;
+that is, before she ever met Mr. Epstein, were you aware
+that she, back in, say, 1997, that she was involved in a
+sexual battery between with her and three girls and
+three boys that were engaged in sexual or lewd acts and
+they were found by some individuals in, as was
+described, compromising positions with the males on top
+of the females, including her, and she was intoxicated?
+Did she ever talk about that with you?
+A.
+No.
+MR. BERGER: Objection. Compound question.
+And Counsel is testifying.
+MR. WILLITS: Object to the form.
+MS. EZELL: Join.
+BY MR. CRITTON:
+Were you aware that she had, prior to the time
+Electronicaly signed by Sandra Townson (401-4
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+21
+25
+Page 199
+she ever met Mr. Epstein, that she had -- her mother
+described her as having significant drug problems?
+MR. BERGER: Objection. Counsel is
+testifying.
+THE WITNESS: No.
+BY MR. CRITTON:
+l. Mrs. Ezell used -- she referred to a
+MS. EZELL: Santiago.
+THE WITNESS: Santiago.
+BY MR. CRITTON:
+--
+Have you ever heard of a
+MS. EZELL: Thank you. You're right.
+THE WITNESS: I know that his name was
+but I don't know if it was Santiago or
+don't remember the last name. I never spoke to
+him, except ask him to move his car one time.
+BY MR. CRITTON:
+l.
+And did Mr. - got it wrong - did
+Mr.
+bring
+1. to the Epstein house on more
+than one occasion?
+A.
+I
+Yes.
+And did you consider her, at least from your
+viewpoint, was she one of the individuals who came to
+give massages?
+A.
+She was supposed to be a massage therapist.
+
+
+Page 200
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+l. And, so, Mr. -- at least Mr.
+--
+-- assuming, if I asked you to assume his name was
+was he aware that his live-in girlfriend was
+coming to Mr. Epstein's house to give him a massage?
+A. I don't know if he was aware of it. He was
+waiting outside.
+All right. And you understood that she, that
+isI
+• and Mr.
+or
+• al
+lived together
+out in Royal Palm Beach?
+A. Yes.
+l. And as to what their relationship was and as
+to what -- that is, their internal relationship was and
+whether there was abuse, either physical or verbal,
+associated with that, do you have any personal
+knowledge?
+A. Not except that that time that I went to pick
+her up and she was crying and she told me the furniture,
+the couch was slit with like a razor blade or a knife,
+and also the screen porch at the entrance, it was cut.
+And I ask, I said, what happened here?
+She says, well, my boyfriend got mad and he
+did it.
+And she indicate -- she,
+her boyfriend that caused all that damage?
+A. Yeah.
+Electronical signed by Sandra Town 41 L
+., told you it was
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 201
+With regard to
+•., did it ever appear to you
+that she was forced to come to Mr. Epstein's home?
+A. I don't think so. I don't know if it was
+forced between them, but I never saw force. I never
+saw -- I was there the first time Ms. Maxwell met her
+immediately that she went into the spa, when she was
+walking into the spa. And I was surprised to see that
+afternoon she was at the house.
+R.
+Did you ever see anyone forcing
+• onto
+the Epstein's premises; that is, either by grabbing her
+by the arm or by the hand and dragging her in?
+A.
+No. Either her or nobody else.
+l. Did you ever see Ms. --
+• when she came to
+the home where she appeared to be -- that is, when she
+arrived at the home to be upset or angry or distraught?
+A.
+No.
+l. And specifically with regard to
+•, when she
+left on those occasions where you saw her in person
+leave the house, did she appear to be in the same, I'd
+say, overall demeanor and mood when she left as she had
+been when she came?
+A.
+e.
+A.
+Yeah.
+Yeah, normal. She was normal.
+Did she smile?
+Say hello to you?
+Electrenicaly signed by Sandra Townsen 401 ]
+
+
+Page 202
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+They all smile after they got paid.
+MR. CRITTON: All right. That's all I have.
+Thank you, Mr. Alessi.
+THE WITNESS: You're welcome.
+MR. WILLITS: I don't have any questions.
+MR. BERGER: Okay.
+MS. EZELL: I do.
+RECROSS EXAMINATION
+BY MS. EZELL:
+l. Sorry. Let me find my place, here.
+First of all, forgive me. I didn't mean to
+mislead anyone. It is
+, not Santiago. I think
+he lived on Santiago Street.
+A.
+Yeah. Santiago Street in Royal Palm Beach.
+e. Right. And I confused the two.
+A. My head is not going very well now, so...
+l. Do you need to take a break?
+A. Please. No, I am fine. I am fine.
+Well, it was my head that wasn't going very
+well then.
+You mentioned that your wife, I believe you
+said that -- let me start over.
+I believe you said one reason you wanted to
+stay was that it was causing psychological problems --
+A.
+Yes, it is.
+
+
+Page 203
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+- and problems with your marriage?
+A.
+Absolutely.
+l. What kind of psychological problems?
+A.
+I say, psychological problems. I says,
+marital problems. That would be a better answer it.
+Because the
+stressful was
+on me. If there was a dust,
+spot of dust, they never came to her. And she was able
+to -- she was over involved with the cleaning crew, but
+it was never from Mr. Epstein or Ms. Maxwell yell, they
+will never go to Mari to ask, hey, Mari, why this
+doesn't look good.
+And, so, I had all the blame. And the only
+person I have to take it out was my wife, unfortunately.
+And that was the worst mistake, to have my wife working
+in there.
+l. Did she ever complain to you or seem disturbed
+by what she thought was going on there?
+A. No. She never saw anything.
+Was there ever a guest there by the name of
+Tommy Matola?
+A.
+Tommy Matola? No. Not when I was there.
+You mentioned this morning that there were
+some visitors who were very important men, Noble Prize
+winners?
+A.
+Yes, ma'am.
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 204
+Are you -- do you recall a Martin Nowak?
+A. I think that sounds familiar. If he is an old
+guy, old man?
+I think so. Mathematician?
+A.
+Yes.
+Q. Biologist?
+A.
+Yes. His name Martin. I recall that, yes.
+And do you recall a guest, Murray Gell-Mann?
+A.
+Mary Gell-Mann?
+MR. WILLITS: I think you said --
+MS. EZELL: Murray.
+MR. WILLITS: -- Murray and he said Mary.
+BY MS. EZELL:
+l. Murray, Murray Gell-Mann. And, again, I'm
+speaking of these -- these
+--
+A.
+Is that a man or a woman?
+l. I believe it's a man.
+A.
+Murray Gell-Mann. Could be, but I don't
+recall.
+Do you recall the name Jerry Edelman?
+A.
+No.
+What about -- can't read my own writing
+here -- Henry Risorski (phonetics)?
+A.
+Henry Risorski, yes. Yes.
+Was he a frequent visitor or --
+
+
+Page 205
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+Not too frequent. But, also, he was a
+science -- I think so, he was into the science.
+Q. And Larry Summers?
+A. Larry Summers. Yes. Larry Summers was a
+lawyer?
+l. I think perhaps he was the president of a
+college?
+A.
+I don't know.
+No?
+A.
+No.
+e. Well, then among those that you recall,
+Mr. Nowak, the biologist and Mr. Risorski, did they ever
+have massages that you can recall?
+A. I cannot recall, no.
+Was it your impression that Mr. Epstein liked
+to surround himself with extraordinarily bright people?
+A. Yes.
+MR. CRITTON: Form.
+BY MS. EZELL:
+l. And is it your impression, also, that he's
+rather bright and brilliant himself?
+A.
+Yes.
+MR. WILLITS: Form.
+BY MS. EZELL:
+e.
+Did -- did you ever gain the impression that
+
+
+Page 206
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+20
+21
+22
+23
+24
+25
+he was some sort of brain scientist?
+MR. CRITTON: Form.
+THE WITNESS: No. No. No. I know his
+background. And I -- over the years I learn how he
+come up and into the business and how he make his
+fortune. And I don't think he was a brain
+scientist.
+BY MS. EZELL:
+l. Nobody ever told you that?
+A.
+No.
+Q. If you take a look again at page 9 of the
+transcript, Exhibit 2?
+A. Okay.
+l. Let me call your attention to line 2, which
+begins with the question: "Did he have girls come over
+to give massages?"
+A. Yes.
+e.
+And you said:
+"Yes."
+A.
+Yes.
+The next question is: "How many massages
+would he have in one day?"
+And I think you said earlier, maybe --
+sometimes they'd have three a week?
+A.
+No. No. That was not the question.
+Sometimes he had one, two or three a day.
+lectronically signed by Sandra Townsend (40'
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 207
+e. That's what I wanted to ask you. Up to three
+a day sometimes?
+A. Up to three a day.
+e. And did that happen often?
+A. Very often. Or he had yoga in the morning or
+in the afternoon it was a massage. I don't know that
+again. When it was yoga, it was in the pool house.
+When it was massage, it was upstairs. So I don't what
+they did when closed doors, you know. But it was a
+couple of these girls that were yoga experts and they
+were massage therapists at the same time, so I don't
+know. But there were -- many times there were two,
+three massages a day.
+Also, she had a massage just about every day.
+Meaning, Ghislaine?
+A. Yes.
+l. Then on line 12, the question was: "Did the
+massage therapists seem young to you?"
+And you said: "Mostly, no. You saw one or
+two young ones in the last year."
+A. Yeah.
+Then, again, still --
+MR. CRITTON: Object to form.
+BY MS. EZELL:
+-- still talking about the massage therapist,
+Electronicaly lined by Sandra Townsend 401-1
+
+
+1
+2
+3
+4
+5
+Page 208
+they asked you: "What do you mean, when they looked
+young?" On line 17.
+Do you see that?
+MR. CRITTON:
+Form.
+THE WITNESS: Yeah.
+BY MS. EZELL:
+l. Then you go on to say: "I remember one girl
+was young. We never asked how old she was. It was not
+my job."
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+And the questioner said: "Right.
+I
+understand."
+And you said: "I imagine she was 16 or
+17," -
+A.
+e.
+A.
+That's correct.
+-- "in my judgment."
+Yes.
+MR. CRITTON: Form, I think.
+BY MS. EZELL:
+There was —- the only people being discussed
+in all of this conversation were the massage therapists,
+right?
+MR. CRITTON: Form.
+THE WITNESS: Well, we discuss about N., this
+girl that I mention in here. I thinking about her
+because -- what's her name?
+
+
+Page 209
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY MS. EZELL:
+e. V.?
+A. V. I think she was a massage therapist for
+sure, because we set up the tables for her. But at
+this -
+MS. EZELL: Let me just -- excuse me. Just a
+minute. Let's make it
+- That's all.
+MR. CRITTON: Okay. I'm sorry.
+THE WITNESS:
+And I lost my
+concentration.
+MR. CRITTON: Why don't you read his response
+to him?
+She can read it back to you.
+(Previous answer was read.)
+THE WITNESS: Yeah. I was -- in this
+statement I was thinking of her,
+-- no, V.
+BY MS. EZELL:
+R.?
+A.
+Sorry again.
+It was
+. that I knew she was underage and I
+knew it because I went to the high school and pick her
+up.
+A.
+But she was not a massage therapist, --
+No, she was not.
+-- as far as you know?
+
+
+Page 210
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17'
+18
+19
+20
+21
+22
+23
+24
+25
+A. As far as I know, she was not.
+e. And you were talking throughout this page
+about those girls that came to give massages?
+MR. CRITTON: Form.
+BY MS. EZELL:
+e. Correct?
+MR. CRITTON: Form. Argumentative. Asked and
+answered.
+THE WITNESS: No. If I says she was a massage
+therapist, I would says, no. But, then again, I
+don't know if she was a massage therapist, too.
+BY MS. EZELL:
+l. Okay. You do mention
+on page 21 of your
+statement.
+If you look at line 7, you mention a young
+girl, but she was not a massage therapist?
+A.
+Let me take a look. Page 21.
+e. At about line 7.
+A.
+Line 7.
+MR. CRITTON: But it in the context of your
+answer --
+MS. EZELL: Sure.
+MR. WILLITS: And the question, too.
+THE WITNESS:
+Question: "How" -- let me start
+it from the beginning -- from the end.
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 211
+Many of the -- it's been a while. It was|
+It was
+It was
+It was so many,
+It was
+so many names, that I think if you name -- if
+you -- any girl's name, she's been there probably,
+It was also a young girl but she was not a
+massage therapist. She came to the house as a
+friend.
+I talking about
+because I knew she was not
+a massage therapist because she went to high school
+and she was a singer, an opera singer and she was
+brought to the house by her mother. So I knew they
+had nothing to do with massages. They were friends
+and they were going to the movie with her, dinner
+with her. And she had -- I think she travelled
+with her, too. They travel.
+l. My only point is, that on page 9 you were
+talking about the massage therapists. And you said that
+you remember that there were a couple of young ones the
+last year.
+And, so, among the young massage therapists
+that you might remember in the last year, would
+be
+that person or --
+MR. CRITTON: Form.
+BY MS. EZELL:
+
+
+Page 212
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+-- would be the young one?
+A.
+Yeah.
+e. You stated that Ms. Maxwell was very hard on
+you and you got blamed for everything, and that you --
+you liked the job and you liked Mr. Epstein, but you
+didn't like working for Mrs. Maxwell?
+A. That's correct.
+2. Can you tell me why, other than that she
+blamed you for everything?
+A. She came from a very wealthy family and she
+was -- just my opinion; I give my personal opinion --
+that she was rotten spoiled and she tried to drive the
+house like a palace and not a home.
+I was -- I discussed it with her, many, many
+times we have discussions. And sometimes I even
+refuse
+to do her orders, knowing that I was going to be backed
+up by Mr. Epstein or do the right thing, my thinking of
+running the house should be. But we never had a good
+relationship at all from the beginning, I don't think
+so. But I was -- have to be her driver and she will go
+and shop all over the malls and I will have to go behind
+her, pay for it and bring the bags to the car.
+Next day or the same day she will do shopping
+and buy and say, John, go to this store and get it. It
+was a lot of work. It was a lot that she created and
+Electronical and by sandra Townsend 401 M
+
+
+Page 213
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+most of this jobs that she created.
+e. And one of those things you also had to do
+with her was to take her to different spas?
+A. Yes.
+Q. And there she would recruit young women to
+come and do massages?
+A. Because she was English. And she didn't know
+the area too much as well as I knew. So she -- she
+says, John, make a list of all the massage -- the spas
+in the area from Jupiter to Boca Raton. And we went to
+all the main spas. And then we went to the schools for
+massage therapists, and all the massage parlors, and
+massage, the small massage.
+So I make a list from the telephone book and
+we would go from one to the another one. I would wait
+in the car and she goes in.
+And sometime she took a couple minutes and
+walk out with cards, business cards. And that -- she
+did the recruiting.
+And from then, she pick up the girls and that
+was the end of it. I never did any recruiting and I
+never really saw him doing it.
+You really never saw?
+A.
+Never saw Mr. Epstein recruiting anybody.
+MS. EZELL: All right. I have no other
+Electronical signed by Sandra Townsend 4011
+
+
+Page 214
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+questions. Thank you, sir.
+MR. MERMELSTEIN: I just have a couple follow
+up.
+RECROSS EXAMINATION
+BY MR. MERMELSTEIN:
+l. Mr. Alessi, I'll be very brief.
+You testified that a process server came and
+gave you the subpoena to appear here today, correct?
+Yes.
+A.
+2.
+A. Yes.
+For your deposition?
+l. Did you call anyone after you received the
+subpoena to talk to them about this?
+A.
+No.
+e.
+You didn't call anyone?
+A.
+No.
+Q. Did you -- how did you come in contact with
+Mr. Critton's office to set up the meeting that you
+discussed?
+A. His -- his secretary left me a messages on
+my -- in my machine.
+And then you called back?
+A.
+Then I called back.
+l. And you set up the meeting that you mentioned?
+A. And we set up a meeting for the Labor Day,
+Electronial signed by Sandra Townsend 401-
+
+
+Page 215
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Labor Day, Monday.
+e.
+What about -- but you said a month and a half
+ago -- oh, this was before you were subpoenaed, is when
+you had the meeting at your house with Mr. --
+A.
+Yes, before I was
+subpoenaed.
+l. How did that meeting come about? How did that
+get set up? Who called who?
+A.
+Okay. Before -- I am stuck on this question.
+I don't know. I think it was Mr. Critton office. I
+think it was Mr. Critton office. They call me. And
+they left me a message that I must discuss -- call Mr.
+-- yeah. I had a message in my phone that to call
+Mr. Critton because he would like to speak to me about
+Jeffrey Epstein. That was the message.
+And I call it. Then I spoke to him. We set
+up an appointment. I was sick at that time. And he
+came to my house and we discussed it.
+l. Other than Mr. Critton, --
+A.
+Yes.
+e.
+-- in the last few months have you spoken to
+anyone about the civil cases or your testimony?
+A.
+No, not even my kids.
+Did you discuss this with your wife?
+A.
+My wife, yes. My kids, no.
+What did you and your wife talk about?
+Electronicaly signed by Sandra Townsend 14014
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 216
+A.
+Same thing, what's going on. How bad the
+situation was.
+What do you mean, "how bad the situation was?"
+A.
+How -- I guess how he got into this mess.
+e.
+How Mr. Epstein got into this mess?
+A.
+(Nods head.)
+2. Can you be more specific as to what you and
+your wife said?
+A.
+No. It was just the publicity, you know, that
+his name was on the -- on the magazines and the paper
+and tv. And I thought that that would never happen.
+e.
+And you and your wife felt bad for Mr. Epstein
+because of that?
+A. You know, after you know somebody and he
+becomes a friend of yours for ten years, I think you
+feel bad, no matter how bad he has made. And I don't
+know what he has done or what -- what the final results
+of this will be. I still will feel bad about it, just
+because the person that he was and how generous he was
+with me and other people.
+l. Just to be clear, other than Mr. Critton and
+your wife, you haven't spoken to anyone else about the
+civil cases or your deposition testimony?
+No, sir.
+MR. MERMELSTEIN: All right. That's all I
+Electronical signed by Sandra Townsend 1401-
+
+
+Page 217
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+have.
+MR. CRITTON: I have one last question.
+RECROSS EXAMINATION
+BY MR. CRITTON:
+l. I want to just clear up one thing, Mr. Alessi.
+Go to page 9.
+A. Page 9, looks like the one that is important.
+e. That's right. We've belabored this one to
+death.
+MR. WILLITS: I think the ink has worn off the
+page by now.
+BY MR. CRITTON:
+l. It's Exhibit 2. This is the statement that
+you gave to the State Attorney's Office on November 21st
+of '05.
+Mr. Berger asked you questions about the young
+girl. Ms. Ezell just asked you some questions about
+that.
+So what I want to do is clarify, so that I
+know what -- so there's no confusion, at least in the
+record.
+On page 9, line 16, it says: "During the last
+year when you were working with him, what do you mean
+they looked young? Did they look like they were still
+in high school?"
+Electrical signed by Sandra Treason 401-1
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 218
+And your answer was: "I remember one girl was
+young. We never asked how old she was. It was not my
+job."
+Did I read that question and answer correctly?
+A.
+That's correct.
+l. If I understood your testimony in response to
+Mr. Berger, the girl that you were referring to, because
+there's a reference to high school, was
+1.?
+A.
+Yeah, that's correct.
+e.
+Not
+A.
+No.
+• didn't look to me like a 16 year
+old.
+MR. WILLITS: All right. Thank you. That's
+all I have.
+MR. WILLITS: You have the right to read and
+sign this deposition if it's typed up. I'm not
+going to be ordering it, but if somebody types it
+up you have the right to read and sign it or you
+can waive that right. It's up to you entirely. If
+you want to waive the right to read it, tell the
+court reporter you want to waive the right.
+THE WITNESS: Can you repeat that again?
+MR. CRITTON: Why don't we go off the record.
+(Discussion held off the record.)
+THE WITNESS: I waive that right. I don't
+Electrical signed by sandra To send 401)
+
+
+Page 219
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+think I need to
+see.
+(Witness excused.)
+(l'eposition was
+concluded.)
+Lectronitaly signed by Sandra Townsend (4014
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/a769909450db0221266d267fdcdcbbc676d8db96de1bd5428028213cb5f91eac.receipt.json b/vision-fixhub/ds9-unparsed-05/a769909450db0221266d267fdcdcbbc676d8db96de1bd5428028213cb5f91eac.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e448d95581392749c8337e0877160dbb9da526ce
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a769909450db0221266d267fdcdcbbc676d8db96de1bd5428028213cb5f91eac.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -13833,
+  "dataset": "marble-joined",
+  "doc_id": "a769909450db0221266d267fdcdcbbc676d8db96de1bd5428028213cb5f91eac",
+  "engine": "marble-apple-vision",
+  "event_count": 140,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "8f47daa51796da07eb8168b52e9dc304c89d2cae721ec2038934d499cf8e5e69",
+  "output_sha256": "fbb40f18546af811c918570ffad59a21db3f425249e49b11cef45d0d9fba903e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a8b4d58278a198106268a2176a9f7bb041d39794df49cf74db2f211ad422d4ee.md b/vision-fixhub/ds9-unparsed-05/a8b4d58278a198106268a2176a9f7bb041d39794df49cf74db2f211ad422d4ee.md
new file mode 100644
index 0000000000000000000000000000000000000000..c5ffe1e966ef6d5a03d686e3d6139d1a7e4a6f9a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a8b4d58278a198106268a2176a9f7bb041d39794df49cf74db2f211ad422d4ee.md
@@ -0,0 +1,84 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+Miami, FL 33132-2111
+99 NE. 4 * Street
+Facsimile:
+November 14, 2007
+DELIVERY BY FACSIMILE
+Jay P. Lefkowitz, Esq
+Kirkland & Ellis LLP
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4675
+Re: Jeffrey Epstein
+Dear Jay:
+I write in response to your letter of November 8, 2007.
+Most importantly, I want to reiterate that a guilty plea and sentencing more than two months
+beyond the original deadline is unacceptable to the Office. Contrary to your assertion, the Non-
+Prosecution Agreement does not contemplate a staggered plea and sentencing (that was contemplated
+only in a federal plea, where the federal rules provide for such staggering). Instead, the Agreement
+contemplates a combined plea and sentencing followed by a later surrender date for Mr. Epstein to begin
+serving his jail sentence. As you will recall, the plea and sentencing hearing originally was to occur in
+early October 2007, but was delayed until October 26th to allow Mr. Goldberger to attend. It was
+delayed again until November to allow you to attend. You have provided no showing of how you and
+your client have used your best efforts to insure that the plea and sentencing occur in November. A
+prompt hearing would end speculation by the press and others about Mr. Epstein's intentions and, more
+importantly, would show the U.S. Attorney's Office and the FBI that Mr. Epstein intends to comply with
+all of the terms of the Non-Prosecution Agreement. Accordingly, I again advise you that the Office
+requires Mr. Epstein to make his best efforts to enter his guilty plea and to be sentenced forthwith. Please
+advise me of the new date and time so that someone from our Office can be present.
+Your letter asserts that Mr. Epstein and the State Attorney's Office have reached an agreement as
+to the terms of Mr. Epstein's plea and sentencing, but no such agreements have yet been provided to us.
+As you know, the Non-Prosecution Agreement requires Mr. Epstein to provide copies of all proposed
+agreements prior to entering into any agreement - not just prior to signing an agreement. Please
+immediately provide us with the terms of any agreements that have been negotiated with the State
+Attorney's Office on Mr. Epstein's behalf, whether or not they have yet been reduced to writing, so that
+we have adequate time to review them prior to the change of plea and sentencing to determine that Mr.
+Epstein is complying with the terms of the Non-Prosecution Agreement.
+As to the type of sentence that Mr. Epstein hopes to receive, the Agreement clearly indicates that
+Mr. Epstein is to be incarcerated. In addition to the terms of the Agreement, the Florida Department of'
+Corrections does not allow persons who are registered sex offenders to participate in "community
+release" (which includes "work release"). Since Mr. Epstein will have to register as a sex offender
+promptly after his guilty plea and sentencing, he will not be eligible for such a program. Thus, the U.S.
+Attorney's Office is simply putting you on notice that it intends to make certain that Mr. Epstein is
+"treated no better and no worse than anyone else" convicted of the same offense. If Mr. Epstein is
+somehow allowed to participate in a work release program despite the Department of Corrections' rules
+and practices, the Office intends to investigate the reasons why an exception was granted in Mr. Epstein's
+case.
+Finally, as to the matters related to contacting the victims and the civil litigation, let me address
+your issues in turn. First, one of the material terms of the Non-Prosecution Agreement was Mr. Epstein's
+agreement to waive the right to contest the "veracity" of the victims' claims. Second, the questions put to
+the victims who have already been contacted did not address the "veracity" of their claims. Instead, the
+investigators' questions were limited to whether they had been contacted by any law enforcement
+
+
+officers and told that there would be a civil settlement. Third, the Non-Prosecution Agreement did not
+anticipate such a lengthy delay in the selection of an attorney representative, and the victims would have
+been "represented parties" without such delay; thus, the use of the phrase "may contact" meant "has
+permission to contact." Hopefully, that issue will soon be moot. I anticipate that Judge Davis will
+announce the selection of a lawyer/firm in the near future. Upon the lawyer/firm's formal acceptance, I
+will contact the lawyer/firm and request that he/she contact you after conferring with the victims. In the
+meantime, please treat all of the victims as represented parties who must be contacted only through their
+Your concerns regarding the § 2255 litigation are unfounded. As you know, Mr. Ocariz had been
+told that he would be the attorney representative for the victims. As a matter of professional courtesy, he
+was informed that the Office decided to use a Special Master in the selection of the attorney
+representative. His decision to contact Judge Davis to express his interest in continuing to work on the
+case was no more "lobbying" than contacts made by your colleagues to Judge Davis to persuade him to
+select your choice of an attorney and to persuade him that the non-prosecution agreement's terms did not
+contemplate litigation. You state that you are concerned that the Office has continued to insist that a
+primary criteria for the appointment of counsel is the ability to handle litigation against Mr. Epstein, yet
+your continued reference to challenging the "veracity" of the victims" claims, your contacting of victims
+o comply with victim notification rules, and your client's consistent attacks upon the victims in the pres
+Il confirm the need for appointed counsel to be prepared for such litigatior
+he Agreement, your client gave up the right to "objec
+Please provide me with the terms of the agreements) with the State Attorney's Office and the new
+date for the change of plea and sentencing by Friday, November 16, 2007.
+Sincerely,
+R. Alexander Acosta
+United States Attorney
+By:
+Jeffrey Sloman
+First Assistant United States Attorney
+cc: R. Alexander Acosta, U.S. Attorney
+AUSAI
diff --git a/vision-fixhub/ds9-unparsed-05/a8b4d58278a198106268a2176a9f7bb041d39794df49cf74db2f211ad422d4ee.receipt.json b/vision-fixhub/ds9-unparsed-05/a8b4d58278a198106268a2176a9f7bb041d39794df49cf74db2f211ad422d4ee.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0ecbb9a730306bfc8cf23a866ee1ad8adef44500
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a8b4d58278a198106268a2176a9f7bb041d39794df49cf74db2f211ad422d4ee.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "a8b4d58278a198106268a2176a9f7bb041d39794df49cf74db2f211ad422d4ee",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "aab545db4faf25760d6978771ad02d684d9e7a619c35b61c5bff48182ac44e82",
+  "output_sha256": "e80cb98e4db4d163205cee7f47d2e5b723d51ec364c529731f92a07780b82ffe",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a945844f2a61da709428cb158f940382204a7d289ab58a5a75973cfc0997e4e0.md b/vision-fixhub/ds9-unparsed-05/a945844f2a61da709428cb158f940382204a7d289ab58a5a75973cfc0997e4e0.md
new file mode 100644
index 0000000000000000000000000000000000000000..685acf2c1a024aac75f4ab9a3dfbfa4d5c7e862a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a945844f2a61da709428cb158f940382204a7d289ab58a5a75973cfc0997e4e0.md
@@ -0,0 +1,39 @@
+Villafana, Ann Marie C. (USAFLS)
+From:
+Sent:
+To:
+Subject:
+Oosterbaan, Andrew
+Wednesday, August 08, 2007 5:53 PM
+Villafana, Ann Marie C. (USAFLS)
+RE: Epstein
+Thanks very much, Marie. And, you'll have all the help from us you want. If you guys end up wanting a CEOS attorney
+on the team, the assignment might be different than if we're just helping with motions and responses (which would be
+fine). So, for now, if you need anything or want to discuss the case just contact me and I'll make sure you get what you
+need. Of course, feel free to contact Myesha directly if you think she can better assist you because of her background on
+a particular issue you've already discussed with her.
+Thanks again.
+From: Villatana, Ann Marie C. (USAFLS) [mailto:Ann. Marie. C.Villatana @usdo].gov]
+Sent: Wednesday, August 08, 2007 4:26 PM
+To: Oosterbaan, Andrew
+Subject: Epstein
+Hi Drew - I have attached a plea term sheet and the guideline calculation that was given to Mr. Epstein's
+attorneys on July 31". Lilly's letter of August 2°° is sort of in response to that.
+Several months ago when the pros memo was first sent to you, you mentioned adding a CEOS attorney to the
+team. We probably should wait until this attempt at plea negotiations is finished, but I hope to have a few
+motions/responses "in the bag" before I indict. The two that spring to mind most readily are an appeal to the
+district court if he is released on bond and a response to a motion to dismiss the indictment on the basis that one
+or all of the statutes is unconstitutional. Myesha Braden and I have spoken about the case a few times when I
+was doing research, and she has been wonderful, but if there is someone else that you think would be better, I
+am all up for the help.
+Thank you.
+<<FEDERAL SENTENCING GUIDELINES CALCULATION(Using November 1.wpd>> <<Conf Plea Negotiations
+final. wpd>>
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+08-80736-CV-MARRA
+P-014051
diff --git a/vision-fixhub/ds9-unparsed-05/a945844f2a61da709428cb158f940382204a7d289ab58a5a75973cfc0997e4e0.receipt.json b/vision-fixhub/ds9-unparsed-05/a945844f2a61da709428cb158f940382204a7d289ab58a5a75973cfc0997e4e0.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..658dea005baea8eebc1e9ec38a3bba3c1cdf0d6d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a945844f2a61da709428cb158f940382204a7d289ab58a5a75973cfc0997e4e0.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "a945844f2a61da709428cb158f940382204a7d289ab58a5a75973cfc0997e4e0",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "1ba1b049f2f65cacb184cae1e8a0d92e053b92247b6c4f31e2b6ec1cac4a38c6",
+  "output_sha256": "b6a934c1c32a23d0ac50c13d86b1dea7e9557d681d90aead0e8957120572fb9c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a961f7ff35ed36b22ad94bb959c6ad8de4d9b0924e69c4aeb3e2a7a78bdec67e.md b/vision-fixhub/ds9-unparsed-05/a961f7ff35ed36b22ad94bb959c6ad8de4d9b0924e69c4aeb3e2a7a78bdec67e.md
new file mode 100644
index 0000000000000000000000000000000000000000..0adf1126b294eaa2cae8a9d4795e820ceb84cf2e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a961f7ff35ed36b22ad94bb959c6ad8de4d9b0924e69c4aeb3e2a7a78bdec67e.md
@@ -0,0 +1,2007 @@
+
+Farmer, Jaffe, Weissing,
+Edwards, Fistos & Lehrman, P.L.
+Class Action
+Personal Injury
+Wrongful Death
+Whistleblower Claims
+Commercial Liciation
+WWW.PATHTOJUSTICE.COM
+425 North Andrews Avenue • Suite 2
+Fort Lauderdale, Florida 33301
+Dexter Lee
+A. Marie Villafaña
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401
+SAVES POSTAGE
+UNITED,
+PITNEY DOWES
+02
+1F
+$003.500
+0006936643 JAN 21 2015
+MAILED FROM ZIP CODE 3330 1
+
+JANE DOE #1 and JANE DOE #2,
+Petitioners,
+UNITED STATES,
+Respondent.
+
+
+JANE DOE #1 and JANE DOE #2,
+Petitioners,
+UNITED STATES,
+Respondent.
+4:06
+J..
+SEALED DOCUMENT
+MOTION TO SEAL
+Petitioners Jane Doe No. 1 and Jane Doe No. 2, joined by movants Jane Doe No. 3 and
+Jane Doe No. 4, move to file the attached pleading and supporting exhibit 30 under seal. A
+public pleading has been filed that has one sentenced redacted. That sentence comes from
+exhibit 30, which is correspondence sent by Alan Dershowitz and Gerald Lefcourt, attorneys for
+Jeffrey Epstein.
+As the Court is aware, the parties are currently briefing issues surrounding whether such
+correspondence should be kept under seal or filed in the public court file. See DE 286
+(requesting justification for a motion for a supplemental protective order). To give the Court the
+opportunity to rule on that issue before this correspondence is released, the victims are filing this
+under seal. It is the victims' view that these materials should be included in the public court file,
+for reasons articulated in the Opposition to Epstein's Motion for a Protective Confidentiality
+Order (DE 251). The victims intend to elaborate on their position in a filing they will make
+shortly.
+1
+
+
+WHEREFORE, Petitioners respectfully request that attached pleading and supporting
+exhibit 30 be sealed until further order of the Court. Alternatively, if the Court denies the instant
+motion to seal, then Petitioners respectfully request that their attached pleading and supporting
+exhibit 30 be filed in the public file and docketed as of today's date, as timely filed
+DATED: January 21, 2015.
+Respectfully Submitted,
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+And
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile: 801-585-6833
+-Mail: cassellp@law.utah.edu
+Attorneys for Jane Doe #1 and Jane Doe #2
+* This daytime business address is provided for identification and correspondence
+purposes only and is not intended to imply institutional endorsement by the University of Utah
+2
+
+
+CERTIFICATE OF SERVICE
+I certify that the foregoing document was served on January 21, 2015, on the following via
+US Mail:
+Dexter Lee
+A. Marie Villafaña
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Fax: (561) 820-8777
+E-mail: Dexter. Lee@usdoj.gov
+E-mail: ann.marie.c.villafana@usdoj.gov
+Attorneys for the Government
+Thomas Scott
+thomas.scott@csklegal.com
+COLE, SCOTT & KISSANE, P.A.
+Dadeland Centre II
+9150 South Dadeland Boulevard, Suite 1400
+Miami, Florida 33156
+Telephone: (305) 350-5300
+Facsimile: (305) 373-2294
+-and-
+Kendall Coffey
+kcoffey@coffeyburlington.com
+Gabriel Groisman
+ggroisman@coffeyburlington.com
+Benjamin H. Brodsky
+bbrodsky@coffeyburlington.com
+COFFEY BURLINGTON, P.L.
+2601 South Bayshore Drive, PH 1
+Miami, Florida 33133
+Telephone: (305) 858-2900
+Facsimile: (305) 858-5261
+Attorneys for Alan Dershowitz
+Is/ Bradley J. Edwards
+3
+
+
+JANE DOE #1 and JANE DOE #2,
+Petitioners,
+1
+UNITED STATES,
+Respondent.
+ORDER GRANTING MOTION TO SEAL
+It is hereby ordered that the Unredacted version of Plaintiff's Response to Motion for
+Limited Intervention by Alan M. Dershowitz and Exhibit 30 of said Response be sealed until
+further order of this Court.
+DONE AND ORDERED in Chambers at Palm Beach County, Florida, this
+- day of
+January, 2015.
+KENNETH A. MARRA
+UNITED STATES DISTRICT JUDGE
+
+
+JANE DOE #1 and JANE DOE #2,
+Petitioners,
+UNITED STATES,
+Respondent.
+
+
+CASE NO. 9:08-cv-80736-KAM
+E0 .
+JANE DOE #1 and JANE DOE #2,
+Petitioners,
+VS.
+UNITED STATES OF AMERICA,
+Respondent.
+IN 21
+PI: 4: 06
+/
+PLAINTIFFS RESPONSE TO MOTION FOR
+LIMITED INTERVENTION BY ALAN M. DERSHOWITZ
+COME NOW petitioners Jane Doe No. 1 and Jane Doe 2, as well as movants Jane Doe
+No. 3 and Jane Doe No. 4 ("the victims'"'), to respond in opposition to Mr. Dershowitz's motion
+for limited intervention (DE 282). Dershowitz moves to intervene to strike a proffer made by
+Jane Doe No. 3 of facts that support her pending motion to join this action. The Court should
+deny the motion. Dershowitz has not established any direct interest in this Crime Victims"
+Rights Act (CVRA) action that would entitle him to intervene as of right under Fed. R. Civ. P.
+24(a). Nor has he met Rule 24(b)'s standards for discretionary intervention for four reasons:
+First, Dershowitz has another forum in which to litigate and defend his reputational interests - a
+pending defamation action regarding this very case; second, Dershowitz (and other persons Jane
+Doe No. 3 specifically alleged abused her) have not availed themselves of other opportunities to
+defend their reputational interests; third, Dershowitz lacks any basis to strike allegations that are
+directly relevant to pending issues in this case; and fourth and finally, Jane Doe No. 3 attests in a
+1
+
+
+sworn affidavit (attached as Exhibit 1) that all her allegations are true - an affidavit consistent
+with compelling corroborating evidence.
+BACKGROUND AND COURSE OF PROCEEDINGS
+Because this case has been proceeding for more than six-and-a-half years, it is useful to
+summarize some of the events pertinent to Dershowitz's intervention motion and Jane Doe No.
+3's related and pending motion for joinder. As the Court is aware, on July 7, 2008, a young
+woman identified as Jane Doe No. 1 filed an emergency petition to enforce her rights under the
+Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, alleging that the Government had failed
+to provide her rights with regard to a plea arrangement it was pursuing with Jeffrey Epstein. The
+Court rapidly held a hearing. During that hearing, victim's counsel (having previously made a
+proffer of the relevant circumstances to Government counsel) orally moved to have Jane Doe
+No. 2 added into the case as another "victim" under the CVRA. Government counsel had no
+objection to adding her to the case, apparently believing that, in light of the sexual abuse
+perpetrated against her, she met the "victim" definition in the statute. DE 15 (Tr. July 11, 2008)
+at 14.
+The Court then instructed the parties to attempt to reach a stipulated set of facts. Over the
+next several years, the Government took conflicting positions on whether it would stipulate to
+facts provided by Jane Doe No. 1 and Jane Do. 2, ultimately refusing to stipulate to any facts.
+See generally DE 225-1 at 2-4. Unable to obtain stipulations by the Government, in 2011 the
+victims filed a summary judgment motion alleging 53 proposed undisputed facts (DE 48), along
+with a motion to have the Court accept those facts because of the Government's failure to contest
+them (DE 49). On September 26, 2011, the Court allowed the case to move forward. DE 99.
+The Court, however, declined to accept victims' argument that it should simply accept their facts
+2
+
+
+because of the Government's failure to contest their facts, directing instead that discovery should
+proceed. Id. at 11.
+In light of the Court's direction, on October 11, 2011, the victims filed discovery requests
+with the Government, including requests specifically seeking information about Dershowitz,
+Prince Andrew, and others.
+Further efforts from the Government to avoid any discovery
+followed (see generally DE 225-1 at 4-5),? ultimately leading to a further Court ruling in June
+2013 that the Government should produce documents. DE 189. The Government then produced
+about 1,500 pages of irrelevant materials to the victims (DE 225-1 at 5), while simultaneously
+submitting 14,825 pages of relevant materials under seal to the Court. The Government claimed
+that these pages were "privileged" for various reasons, attaching an abbreviated privilege log.
+Jane Doe No. 1 and Jane No. 2 objected to those claims of privilege, see generally DE 225 and
+DE 265, and also to the Government's failure to specify in its privilege log the names of all the
+persons involved in the materials (DE 265 at 1-2). These issues remain pending today.?
+In the summer of 2014, undersigned counsel for Jane Doe No. 1 and Jane Doe No. 2
+contacted Government counsel to request their agreement to add an additional victim to this case:
+a young woman Jeffrey Epstein sexual abused when she was under age. On August 20, 2014,
+counsel sent a letter to U.S. Attorney Wilfredo Ferrer requesting the Government's consent to a
+stipulated motion to simply add her into the case (as had been done earlier with Jane Doe No. 2).
+Counsel attached a draft proposed motion that would have blandly recounted that she was
+similarly situated to Jane Doe No. 1 and Jane Doe No. 2. See Exhibit 2. The proposed motion
+" Jeffrey Epstein also attempted to block discovery of materials in this case, leading to an Eleventh Circuit
+ruling that the victims' discovery efforts were proper. Doe . Epstein, 749 F.3d 999 (11th Cir. 2014).
+" Remarkably, even though the Court directed the Government to begin producing discovery in June
+2013, the Government has yet to finish that production some 19 months later.
+3
+
+
+did not include any of the facts surrounding her abuse, relying instead on a stipulation to secure
+the Court's anticipated approval.
+Three months later, having received no response from the Government, victims' counsel
+sent an additional letter to Mr. Ferrer, requesting agreement to add an additional victim to the
+case - a young woman identified in current pleadings as Jane Doe No. 34:
+Dear Mr. Ferrer:
+I sent you a letter in August requesting your office's stipulation to our
+adding Jane Doe #[4] in this case. Unfortunately, we did not receive a response
+from your office. We are hopeful that your lack of a response was simple
+oversight.
+In addition to following up on the August letter, we are now requesting
+your Stipulation to the adding of Jane Doe #[3] as well. Her true name is
+[redacted].... As we expressed in our personal meetings a couple years ago, we
+don't understand the tactical decision to be adversarial to victims of known sexual
+abuse on every point in this litigation.
+Now that many of those issues we
+discussed have been resolved in our favor, it seems to make even more sense to
+avoid engaging in unnecessary battles that could only serve the purpose of
+delaying the victims' rights to have this case resolved on its merits.
+As 1 indicated in my August letter requesting your stipulation to the
+adding of Jane Doe #[4], adding Jane Doe #[3] will also not delay matters, so long
+as we can stipulate to her being added. Without a stipulation, we foresee
+litigation over this point, which will produce nothing but additional delay - and
+further question about your Office's commitment to full protection of victims"
+rights under the Crime Victims Rights Act.
+Your office is very familiar with [redacted] and her circumstance. She
+was sexually trafficked and abused by Mr. Epstein (and others at the direction of
+Mr. Epstein) not only in this jurisdiction but throughout the United States and
+beyond.
+... [E]ven if you were to object and prevail on the motion to add her to
+the current litigation, the only consequence would be that Ms. [name redacted]
+would then file a separate CVRA lawsuit, something she is entitled to do because
+the CVRA contains no time limit. ... We have, throughout this case, consciously
+avoided filing anything that would unnecessarily cast your office in a bad light,
+and it is again with that in mind that we request your stipulation here. We need
+this stipulation by December 10, 2014 to avoid delaying any other aspects of this
+case. We will not file any pleadings on this subject before that date.
+* In the letter to Mr. Ferrer, the woman identified in current court pleadings as Jane No. 3 is referred to as
+"Jane Doe No. 4." For consistency with the court pleadings, the designations in correspondence have
+been modified here - as indicated by brackets - to track the current designation in the pleadings.
+4
+
+
+See Exhibit 3. Weeks went by and the Government - once again -- did not respond to counsel's
+request for a stipulation. This prompted a further email from counsel to the AUSA's handling
+this matter to inquire about the status of request:
+When we spoke a few months ago, I told you that we represented [Jane
+that I have attached to this email. I was hoping for a response letting me know
+that the Office would not oppose the amendments adding Doe 3 and 4.... I realize
+our 11/19 letter asked for a response by the 10th. However, I was hoping you
+to adding these Plaintiffs then I want to get the Motion prepared.
+See Exhibit 4; see also Exhibit 5 (short response regarding trying to get an answer).
+On December 10, 2014, despite having had four months to provide a position, the
+Government responded by email to counsel that it was seeking more time, indicating that the
+Government understood that victims' counsel might need to file a motion with the court on the
+matter immediately: "The U.S. Attorney is on travel and I do not have an answer for you on
+whether the government will agree to the addition of two new petitioners. I appreciate you not
+filing your motion until December [15], 2014. If you need to file the motion, we understand.
+Thanks." See Exhibit 6.
+Rather than file a motion immediately, victims' counsel waited and continued to press the
+Government for a stipulation. See Exhibits 7, 8, and 9. Finally, on December 23, 2014 - more
+than four months after the initial request for a stipulated joinder into the case - the Government
+tersely indicated its objection, without indicating any reason: "Our position is that we oppose
+adding new petitioners at this stage of the litigation." See Exhibit 10.
+5
+
+
+Because the Government now contested the joinder motion, undersigned counsel
+prepared a more detailed pleading explaining the justification for granting the motion. One week
+after receiving the Government's objection, on December 30, 2014, Jane Doe No. 3 and Jane
+Doe No. 4 filed a motion (and later a corrected motion) seeking to join the case. DE 279 and DE
+280." Uncertain as to the basis for the Government's objection, the motion briefly proffered the
+circumstances of Jane Doe No. 3 and Jane Doe No. 4 that would qualify them as "victims"
+eligible to assert rights under the CVRA. See 18 U.S.C. 3771(e) ("For the purposes of this
+chapter, the term 'crime victim' means a person directly and proximately harmed as a result of
+the commission of federal offense ...."). With regard to Jane Doe No. 3, the motion indicated
+that when she was a minor, Jeffrey Epstein had trafficked her to Dershowitz and Prince Andrew
+(among others) for sexual purposes. Jane Doe No. 3 stated that she was prepared to prove her
+proffer. See DE 280 at 3 ("If allowed to join this action, Jane Doe No. 3 would prove the
+following .... "). The motion also provided specific reasons why Jane Doe No. 3's participation
+was relevant to the case, including the pending discovery issues regarding Dershowitz and Prince
+Andrew. DE 280 at 9-10 (explaining several reasons participation of new victims was relevant
+to existing issues).
+After the motion was filed, various news organizations published articles about it.
+Dershowitz also made numerous media statements about the filing, including calling Jane Doe
+No. 3 "*a
+serial liar" who
+"has lied through her teeth about many world leaders."
+http://www.cnn.com/2015/01/06/us/dershowitz-sex-allegation/.
+Dershowitz also repeatedly
+Dershowitz argues that Jane Doe No. 3 violated Local Rule 15.1 by failing to attach a proposed
+amended complaint. DE 282 at 2. But Jane Doe No. 3 was simply following the same approach that Jane
+Doe No. 2 had taken earlier, by filing a motion to join rather than a proposed amendment to pleadings
+6
+
+
+called undersigned legal counsel for Jane Doe No. 3 "two sleazy, unprofessional, disbarable
+lawyers." Id. On January 5, 2015, Dershowitz filed the pending motion to intervene. DE 282.
+DISCUSSION
+Dershowitz's motion to intervene relies on Fed. R. Civ. P. 24(a) (mandatory intervention)
+and 24(b) (permissive intervention). Neither argument for intervention is well-founded.
+I.
+DERSHOWITZ'S ALLEGED "REPUTATIONAL" INTERESTS DO NOT
+SATISFY RULE 24(A)'S REQUIREMENTS FOR INTERVENTION AS OF
+RIGHT.
+Dershowitz first claims that he meets Rule 24(a)'s requirements for mandatory
+intervention. Rule 24(a) requires that the Court allow a person to intervene in a case if that
+person "claims an interest relating to the property or transaction that is the subject of that action
+and is so situated that disposing of the action may as a practical matter impair or impede the
+movant's ability to protect his interest, unless existing parties adequately represent that interest."
+Dershowitz contends he meets Rule 24(a)'s requirements because he has a "reputational" interest
+in the matter, specifically an interest in contesting Jane Doe No. 3's allegation that Jeffrey
+Epstein trafficked her to Dershowitz for sexual purposes.
+Numerous courts have declined to allow a mere "reputational" interest to justify
+mandatory intervention. For example, Calloway I. Westinghouse Elec. Corp., 115 F.R.D. 73
+(M.D. Ga. 1987), denied a motion to intervene where the alleged interest was a doctor's "own
+reputation and academic credibility." Id. at 74. The court denied intervention because "a
+witness" interest in his reputation alone... does not constitute the required 'interest relating to
+the property or transaction which is the subject of the present action' necessary to allow
+intervention as a matter of right. To find otherwise would invite intervention every time a court
+is required to determine the credibility of a witness." Id.
+• Similarly, Flynn l. Hubbard, 82 F.2d
+7
+
+
+1084, 1093 (Ist Cir. 1986), affirmed the denial of the Church of Scientology's request for
+intervention in part because "the church "merely claim[ed] a generalized injury to reputation
+[that] identifies no legal detriment arising from a default judgment against Hubbard." Id. at 1093
+(Coffin, J., concurring). See also Edmondson y. State of Neb. ex. rel. Meyer, 383 F.2d 123, (8th
+Cir. 1967) ("The mere fact that Edmondson's reputation is thereby injured is not enough [to
+support intervention]. Edmondson's representative has pointed to no legal detriment flowing
+from this possible finding of the trial court, and we can find none."); Forsyth County f. U.S.
+Army Corps of Engineers, No. 2:08-CV-0126-RWS, 2009 WL 1312511, at *2 (N.D. Ga. May
+8, 2009) (denying intervention because an "interest in protecting its reputation ... is not direct,
+substantive, or derived from a legal right").°
+The Court has previously considered - and rejected - a similar effort to intervene on a
+"reputational" claim. That claim was made by Bruce Reinhart who - like Dershowitz - had
+previously represented Jeffrey Epstein's interests in related litigation. Reinhart moved to
+intervene in this case to contest the victims' allegations that Reinhart (a former prosecutor in the
+U.S. Attorney's Office investigating Epstein) received confidential, non-public information
+about the investigation. The victims specifically alleged that Reinhart had "joined Epstein's
+payroll shortly after important decisions were made limiting Epstein's criminal liability" and that
+Reinhart had gone on to improperly represent Epstein-related witnesses in various civil suits.
+See DE 99 at 12 (discussing DE 48 at 23). Reinhart filed a sworn affidavit admitting that he had
+represented Epstein-related clients, but claiming that he did not possess any such confidential
+information. He sought to intervene to challenge the victims" arguments.
+'Dershowitz cites dicta in Sackman | Liggett Grp., Inc., 167 F.R.D. 6, 20-21 (E.D.N.Y. 1996), that a
+eputational interest can support intervention. But Sackman did not analyze the issue; rather it simpl
+il), other case, Penthouse analysis of the is frany suchs holin 663 F-2d 371, 373, 392 (2d Cir
+8
+
+
+After a hearing, the Court denied Reinhart's motion, finding that his interest in litigating
+the validity of the victims' allegations was too attenuated to support intervention. DE 99 at 13?
+The Court's rationale applies equally here and should lead the Court to deny Dershowitz's
+motion. Dershowitz claims that his situation is distinguishable in view of how "harmful" (DE
+282 at 6) he believes the current allegations are. But the degree of indignation at allegations is
+not a sound basis for allowing intervention. As the Court previously explained, it "cannot permit
+anyone slighted by allegations in court pleadings to intervene and conduct mini-trials to
+vindicate their reputation." DE 99 at 13.
+Dershowitz does have an alternative ground he could try to advance for intervention. As
+Jane Doe No. 3 pointed out in her motion to join the case, Dershowitz personally helped to
+negotiate the non-prosecution agreement (NPA) at issue in this case, which bars his prosecution
+in the Southern District of Florida as a "potential co-conspirator of Epstein." DE 280 at 4
+(quoting NPA at 5). The Court has previously allowed Epstein to prospectively intervene in any
+proceedings that might involve invalidating the NPA. DE 246. Dershowitz can make a similar
+motion if he identifies himself as a potential co-conspirator involved in crimes covered by the
+NPA. But lacking
+such an allegation, his existing motion does not allege any concrete
+impairment of his interests supporting mandatory intervention.
+II.
+DERSHOWITZ HAS NOT SHOWN THAT THE COURT SHOULD ALLOW
+PERMISSIVE INTERVENTION UNDER RULE 24(B).
+Epstein case with other prosecutors.").
+9
+
+
+Dershowitz also contends that the Court should exercise its discretion to allow permissive
+intervention in this case under Fed. R. Civ. P. 24(b). The rule grants discretion to the court to
+allow intervention by a person who has "a claim or defense that shares with the main action a
+common question of law or fact." Fed. R. Civ. P. 24(b); accord Mi. Hawley Ins. Co. I Sandy
+Lake Properties, Inc., 425 F.3d 1308, 1311 (11th Cir. 2005) (permissive intervention allowed
+only where "a claim or defense and the main action have a question of law or fact in common
+and the intervention will not unduly prejudice or delay the adjudication of the rights of the
+original parties."). A district court's ruling on such intervention is reviewed only for abuse of
+discretion. Stone |. First Union Corp., 371 F.3d 1305, 1309 (11th Cir. 2004); see also AT&T
+Corp. | Sprint Corp., 407 F.3d 560, 561-62 (2nd Cir. 2005) ("[a] denial of permissive
+intervention has virtually never been reversed" because of the considerable discretion afforded to
+district courts).
+In ruling on a motion for permissive intervention, the Court must consider all relevant
+factors, including "the nature and extent of the intervenor's interest." Perry | Proposition 8
+Official Proponents, 587 F.3d 947, 955 (9th Cir. 2009). Here, Dershowitz lacks a "claim or
+defense" in common with the CVRA action. Instead, Dershowitz intends to advance satellite
+arguments,
+including
+raising
+questions about the credibility of crime victims that the
+Government apparently does not intend to present.® Allowing his intervention would thus create
+a clear risk of adding undue delay to what is already a long-running case. Cf. id. (affirming
+district court decision to deny intervention that would "consume additional time and resources of
+" For example, in the media Dershowitz has called Jane Doe No. 3 - an alleged victim of international sex
+trafficking while she was a minor - "a serial perjurer, serial liar, serial prostitute." Washington Post,
+ttp://www.washingtonpost.com/news/morning-mix/wp/2015/01/06/alan-dershowit
+kes-legal-action-after-being-named-with-prince-andrew-in-sex-ring-case/
+10
+
+
+both the Court and the parties that have a direct stake in the outcome of the proceedings").
+Moreover, several other important factors weigh against allowing intervention.
+A. DERSHOWITZ CAN LITIGATE HIS REPUTATIONAL INTERESTS IN A
+PENDING DEFAMATION ACTION IN BROWARD COUNTY CIRCUIT
+COURT.
+In the opening paragraph of his court pleading, Dershowitz claims he has "no remedy" to
+defend his reputation. DE 81 at 1. And yet, in his statements to the media, Dershowitz has made
+clear that he intends to defend his reputational interests in a pending defamation action. The
+Court need not allow duplicative litigation on the same reputational issues.
+After Jane Doe No. 3 filed her motion to intervene, Dershowitz attacked her in the media
+as a "serial perjurer." He also repeatedly named and attacked her attorneys - i.e., undersigned
+legal counsel Edwards and Cassell - branding them, among other disparaging names, "two
+sleazy, unprofessional, disbarable lawyers." Dershowitz repeated his attacks on numerous
+worldwide media outlets, saying such things as victims' counsel are prepared to lie, cheat and
+steal. These are unethical lawyers" (CNN Program "The World Right Now with Hala Gorani,"
+Jan. 5, 2015) and that counsel "willfully and deliberately made this up in order to gain a
+litigation advantage, [to] line their pockets with money" (The Last Word with
+O'Donnell - MSNBC (Jan. 8, 2015).
+Following these statements, on January 6, 2015, attorneys Edwards and Cassell,
+represented by Jack Scarola, Esq., filed a defamation action in Broward County Circuit Court.
+See Exhibit 11 at 9| 17 (alleging Dershowitz has "initiated a massive public media assault on the
+reputation and character" of undersigned counsel, by "accusing them of intentionally lying in
+their filings, of having leveled knowingly false accusations against [Dershowitz], without ever
+conducting any investigation of the credibility of the accusations"). The attorneys also served
+11
+
+
+discovery requests on Dershowitz, as well as a notice of deposition. Dershowitz has yet to agree
+to a deposition date.
+Faced with a defamation action against him, Dershowitz stated that he was "thrilled" by
+the development because it "gives me a chance to litigate the case. I can expose their corruption.
+I can show how fraudulent the allegations are. This makes my day." Wall St. Journal Law Blog,
+http://blogs.wsj.com/law/2015/01/06/jane-doe-lawyers-sue-dershowitz-for-defamation/ (Jan. 6,
+2015); see also UMAR News,
+(Jan. 4, 2015)
+("I just need a legal proceeding ... to call witnesses ... to prove my case" (emphasis added)).
+Given that Dershowitz has the opportunity to litigate his concerns in the other case, this
+Court need not - and should not - allow permissive intervention in this one. See, eg. Morgan |
+Sears,
+, Roebuck & Co., 124 F.R.D. 231 (1988) (declining intervention in one case where
+litigation on a similar issue was already underway elsewhere). Permissive intervention in this
+case would, for example, presumably lead to Dershowitz (and, in turn, undersigned legal
+counsel) seeking duplicative discovery to that which is already being sought in Broward County
+Circuit Court. One forum is enough to litigate reputational issues.
+B. DERSHOWITZ SHOULD NOT BE ALLOWED TO INTERVENE IN THIS
+ACTION WHEN HE HAS DECLINED TO DEFEND HIS REPUTATION IN
+OTHER ACTIONS.
+Dershowitz also claims that he has not been given an opportunity to address his
+connection to Epstein's sex trafficking. DE 282-1 at 3. This is untrue. Indeed, Dershowitz has
+been given (at least) three separate opportunities to provide information concerning his
+involvement in Epstein's offenses. Because Dershowitz has not availed himself of any of those
+prior opportunities, the Court should deny his motion to intervene now.
+2009
+
+
+On about September 17, 2009, one of undersigned counsel (Brad Edwards) arranged to
+have Dershowitz served with a subpoena for deposition in connection with a civil case brought
+by one of the underage females who had sued Epstein (Doe | Epstein, No. 9:08-cv-80893-KAM
+(S.D. Fla.)). At that point, Dershowitz understood that counsel for many of Epstein's victims
+believed that mounting evidence pointed toward his role extending beyond merely being an
+attorney for Epstein. That deposition ultimately did not occur, and Dershowitz made no effort to
+provide information about his knowledge of relevant information.
+2011
+In 2011, in the state case of Epstein | Edwards (No. 502009CA040800XXXXMBAG
+(Palm Beach Cty. Cir. Ct.)), counsel for Edwards (Jack Scarola, Esq.) contacted Dershowitz to
+seek his cooperation in answering questions about his knowledge of Epstein's sex trafficking.
+On August 15, 2011, Dershowitz indicated that he wanted more information before would decide
+whether to cooperate: "If you would let me know what non-privileged information you would
+seek from me, I would then be able to decide whether to cooperate." See Exhibit 12 (emphasis
+added).
+On August 23, 2011, Scarola sent a letter to Dershowitz, explaining that there was no
+intent to inquire about attorney-client information, but adding: "[w]e do, however, have reason to
+believe that you have personally observed Jeffrey Epstein in the presence of underage females,
+and we would like the opportunity to question you under oath about these observations." See
+Exhibit 13. Dershowitz declined to cooperate, so on September 7, 2011, Scarola again sent a
+letter to Dershowitz, noting that while there was "no obligation" to disclose the basis for wanting
+a deposition, the reason was that "[multiple individuals have placed you in the presence of
+Jeffrey Epstein on multiple occasions and in various locations when Jeffrey Epstein was in the
+13
+
+
+company of underage females subsequently identified as victims of Mr. Epstein's criminal
+molestations. This information is derived from both sworn testimony and private interviews."
+Exhibit 14. Despite providing Dershowitz with the basis for wanting his deposition, and the
+assurance that questions regarding privileged information would not be asked, Dershowitz did
+not cooperate.
+2015
+After Jane Doe No. 3 moved to intervene in this case, Dershowitz said "what they
+[victims' counsel] have done is so under-handed ... not giv[ing] me an opportunity to disprove
+it. That's Kafkaesque." UMAR News,
+Following public statements such as these, on January 3, 2015, attorney Jack Scarola
+immediately sent an e-mail to Dershowitz, requesting an opportunity to take his deposition:
+Dear Mr. Dershowitz:
+knowledge of Jeffrey Epstein's extensive abuse of underage females as well as
+your alleged personal participation in those activities. As I am sure you will
+we welcome your change of heart. Perhaps a convenient time would be in
+connection with your scheduled appearance in Miami on January 19. I assume a
+request, but please let us know promptly if that assumption is inaccurate.... Thank
+you for your anticipated cooperation.
+Exhibit 15. As of the date of this filing, Dershowitz has completely ignored this request, while
+simultaneously continuing to publicly protest his inability to challenge the allegations against
+him in a legal proceeding.
+14
+
+
+In light of these opportunities that have been extended to Dershowitz previously to
+answer any questions about his knowledge of (and even participation in) Epstein's sex
+trafficking, his claim that he needs a forum in this Court to defend his reputation rings hollow.?
+For the sake of completeness - and to show a sinister pattern - it is also worth noting that
+each of the other four individuals Jane Doe No. 3 identified by name in her motion (Jeffrey
+Epstein, Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have also all been afforded
+opportunities to explain themselves - and all four have declined to take them.
+Epstein. The Court is familiar with Jeffrey Epstein's repeated invocations of the Fifth
+Amendment when asked questions about his sexual abuse of young girls, including Jane Doe No.
+1, Jane Doe No. 2, and Jane Doe No. 3. See generally Exhibit 16 at 1-7.
+Maxwell. In 2009, undersigned counsel (Brad Edwards) served Ghislaine Maxwell with
+a subpoena for a deposition in a civil case against Jeffrey Epstein. After extensive discussion
+and coordinating a convenient time and place, as well as ultimately agreeing to a confidentiality
+agreement prepared by Maxwell's attorney, at the eleventh hour Maxwell's attorney informed
+the undersigned that Maxwell's mother was very ill and that consequently Maxwell was leaving
+the country with no plans to return. The deposition was cancelled. Yet a short time later,
+Maxwell was photographed at Chelsea Clinton's wedding in Rhinebeck, New York, confirming
+the suspicion that she was indeed still in the country and willing to say anything to avoid her
+deposition.
+9 The difficulty in scheduling this deposition also fits into a pattern for Dershowitz. In around 2005 to
+2006, Dershowitz was Jeffrey Epstein's "primary" lawyer. When the Palm Beach Police Department
+Ct. Nov. 23, 2009).
+15
+
+
+Brunel. In 2009, undersigned counsel (Brad Edwards, representing Jane Doe) served
+Jean Luc Brunel with a subpoena for a deposition before this court in Doe |. Epstein, No. 9:08-
+cv-80119-KAM (S.D. Fla.). Brunel's attorney asked counsel for Jane Doe to postpone the
+scheduled deposition date. Jane Doe's counsel agreed, and then Brunel's attorney cancelled the
+rescheduled deposition date. Brunel's counsel represented that Brunel was outside the country
+and thus unavailable. But later sworn deposition testimony revealed that Brunel was actually
+inside the country at this time - indeed, he was hiding at Epstein's Palm Beach home. All this
+was brought to the Court's attention via a motion for sanctions. DE 483. This is just another
+example of the inner circle of Epstein's friends refusing depositions to answer questions.
+Prince Andrew
+In 2011, Jack Scarola, representing Brad Edwards in the Epstein
+Edwards case, faced procedural impediments to obtaining a sworn deposition from a member of
+the British Royal family. Accordingly, he publicly invited the voluntary testimony of Prince
+Andrew, explaining: "We would be very keen to speak with Prince Andrew, given his
+relationship with Jeffrey Epstein.... We have reason to believe that Prince Andrew has been in
+the company of Mr. Epstein while Mr. Epstein has been in the company of under-aged children."
+http://efliefolkerts.blogspot.com/2011/03/convicted-paedophile-jeffrey-epstein-is.html.
+Prince
+Andrew never responded.
+Two weeks ago, after Jane Doe No. 3 and Jane Doe No. 4 moved to join in this action, a
+spokesperson for Prince Andrew denied Jane Doe No. 3's allegations, without providing any
+explanation of what the Prince was doing with this minor girl late at night in a private setting.
+Accordingly, on January 14, 2015, Jack Scarola sent Prince Andrew a certified letter requesting
+his voluntary cooperation in answering questions about his sexual interactions with Jane Doe No.
+16
+
+
+3. See Exhibit 17. The letter requested an opportunity to take a statement under oath from
+Prince Andrew. Federal Express has informed us that the letter has been refused by the recipient.
+In light of these avoided opportunities by Dershowitz - as well as Epstein, Maxwell,
+Brunel, and Prince Andrew - to answer questions under oath regarding Epstein's trafficking of
+young girls, there is no good reason that the Court should now allow a special, discretionary
+opportunity to intervene to respond to the allegations.
+C. DERSHAN REEVA NOT BEEN INTERE TO STRIKE
+The Court should also deny Dershowitz's motion for intervention because it would be a
+pointless exercise.
+Citing Rule 12(t) of the Federal Rules of Civil Procedure, Dershowitz seeks to intervene
+to strike "immaterial, impertinent, or scandalous matter." DE 282 at 7. Dershowitz contends
+that Jane Doe No. 3's allegations regarding sexual contacts with him "have nothing to do with
+any relevant issues in this case." Id. at 3. Courts generally "disfavor the motion to strike ...."
+Moore's Federal Practice § 12.37[1] (3d ed. 2014) (internal citation omitted). "Striking
+allegations from a pleading 'is a drastic remedy to be resorted to only when required for the
+purposes of justice,' and only when the allegations to be stricken have 'no possible relation to the
+controversy."' Larise Atlantis, Inc. I. Pac. Ins. Co., No. 10-61583-CIV, 2011 WL 1584359 at *2
+(S.D. Fla. 2011) (quoting Augustus |. Bd. of Pub. Instruction, 306 F.2d 862, 868 (5th Cir. 1962)).
+"If there is any doubt as to whether the allegations might be an issue in the action, courts will
+deny the motion." In re 2TheMart.com, Inc. Sec. Litig., 114 F. Supp. 2d 955, 965 (C.D. Cal.
+2000) (emphasis in original).
+Just as with a motion to dismiss for failure to state a claim, in
+ruling on a motion to strike "the Court must view the pleadings in a light most favorable to the
+17
+
+
+pleading party." Id. Any motion to strike by Dershowitz would be meritless, because Jane Doe
+No. 3's allegations are pertinent to at least eight pending issues.
+1. The Pending Motion to Intervene.
+Of course, the first reason that Jane Doe No. 3 made her allegations was to support her
+pending motion to join this action. As the Court has seen from the chronology recounted above,
+victims' counsel engaged in months of efforts to reach a stipulated motion for joinder by Jane
+Doe No. 3 and Jane Doe No. 4 that would not have required reciting any specific factual
+allegations. The U.S. Attorney's Office refused to provide any answer to that request, until
+finally tersely objecting (without providing any rationale). Once the joinder motion became
+contested, Jane Doe No. 3 then needed to proffer allegations supporting her entry into the case.
+To join this CVRA action, Jane Doe No. 3 must first show that she is the "victim" of a
+federal crime, 18 U.S.C. § 3771(e) - and, further, that the crime is one that implicates persons
+covered by the NPA. Jane Doe No. 3 alleged that she was sexually abused by Jeffrey Epstein.
+But she also focused much of her joinder motion on the fact that she was the victim of a "sex
+trafficking scheme" organized by Epstein. DE 280 at 3. To prove she is a victim of sex
+trafficking in violation of 18 U.S.C. § 1591, Jane Doe must demonstrate that she was recruited,
+transported, or harbored while under the age of 18 and "cause[d] to engage in a commercial sex
+act." Accordingly, she briefly described the trafficking scheme, including identifying several
+persons to whom she was trafficked (i.c., Dershowitz and Andrew).'° The fact that Dershowitz
+1 In his motion, Dershowitz alleges that Jane Doe No. 3 identified these two names solely to stir up
+media attention. DE 282 at 2. But Dershowitz does not address the obvious reasons for the identification
+- i.e., that he was an attorney who helped draft the NPA and that a sex act with Prince Andrew in London
+affected "foreign commerce" - part of a jurisdictional requirement of the statute. See 18 U.S.C. §
+1591(a)(1). In addition, Jane Doe No. 3 has also alleged that she was trafficked to "many other powerful
+men, including politicians and powerful business executives." Ex. 1 at 1 58. The names of these persons
+could have been included in her pleading and would have created significantly more media attention than
+18
+
+
+(and Prince Andrew) engaged in a "sex act" with her is simply a required element of her proof
+that she is the victim of a sex trafficking crime.
+Sexual trafficking is not the only crime that could support Jane Doe No. 3's joinder in
+this case. There are also various federal sex offenses, such as travel with intent to engage in
+illicit sexual conduct, 18 U.S.C. § 2423(b), which Jane Doe No. 3's proffer supported. And
+perhaps most obviously, Jane Doe No. 3 was the victim of a conspiracy under 18 U.S.C. § 371.
+Dershowitz, of course, was a co-conspirator against her - thereby directly implicating the NPA.
+In her pleading, Jane Doe No. 3 alleged only the fact that a sex act took place, not the nature of
+the sex act nor any "unnecessary detail." Begay |. Public Service Co. of New Mexico, 710
+F.Supp.2d 1161 (D. N. Mex. 2010)."
+2. The Pending Discovery Issues.
+Another reason Jane Doe No. 3 cited in her pleading for specifically naming Dershowitz
+(and Prince Andrew) is that the Court has before it a pending discovery dispute involving
+documents relating to these two people. See DE 280 at 10 (citing DE 225 at 7-8 (discussing DE
+48 at 16-18)). As the Court is aware, on December 1, 2011, Jane Doe No. 1 and Jane Doe No. 2
+propounded a Request for Admission (RFA) asking the Government to admit that it possesses
+"documents, correspondence or other information reflecting contacts with the Department
+the names that she did include. If the Court would like proof of this assertion, counsel would request
+leave to provide an ex parte, sealed submission of the names of the other immediately recognizable
+persons who either observed or participated in the trafficking of Jane Doe No. 3.
+" Where sexual issues are relevant to a case, they must not be stricken. See, e.g. Zdenek . School Bd. of
+Broward County, No. 07-CV-61110, 2007 WL 4521489, at *2 (S.D. Fla. Dec. 19, 2007) ("given the
+Eleventh Circuit standards on what constitutes actionable sexual harassment, the allegations in question
+that the defendants' financial misconduct stemmed in part from an intention to cover up sexual
+misconduct. As such, the court agrees that the allegations are no more scandalous than those that would
+be asserted in any cause of action relating to sexual harassment.*).
+19
+
+
+between May 2007 and September 2008 on behalf of Jeffrey Epstein by ... (b) Andrew Albert
+Christian Edward (a/k/a Prince Andrew, Duke of York); (c) Harvard Law Professor Alan
+Dershowitz." While the Government denied that it had documents reflecting contacts by Prince
+Andrew, it specifically admitted possessing documents reflecting contacts by Dershowitz. Gov't
+Answer to RFA #6. The two victims further requested the Government admit that it possessed
+"information (including telephone logs and emails) reflecting contacts between Bruce E.
+Reinhart and persons/entities affiliated with Jeffrey Epstein (including ... Harvard Law
+Professor Alan Dershowitz). The Government admitted this fact. Gov't Answers to RFA #16.
+These RFA's tie into a major discovery battle that is currently before the Court. Related
+to the RFA's, on October 3, 2011, Jane Doe No. 1 and Jane Doe No. 2 propounded Request for
+Production (RFP) #8, seeking "all correspondence, documents, and other information regarding
+Epstein's lobbying efforts to persuade the Government to give him a more favorable plea
+arrangement and/or non-prosecution agreement,
+, including efforts by ... Andrew Albert
+Christian Edward (a/k/a Prince Andrew, Duke of York), [and] Harvard Law Professor Alan
+Dershowitz." The two vietims also propounded RFP #21, requesting all documents relating to
+the NPA, including documents in the Government's possession from "defense attorneys
+representing Epstein (including ... Alan Dershowitz)" and from "agents acting in support of
+Epstein (including ... Andrew Albert Christian Edward (a/k/a Prince Andrew Duke of York))."
+The Government responded to these (and other RFPs) by asserting privilege over 14,825
+pages of documents that it provided to the Court.? But contrary to the Court's specific direction,
+the Government did not provide a log that "clearly identifies each document] by authors),
+addressee(s), recipients), date, and general subject matter
+…..." DE 190 at 2. Accordingly,
+12 The Government has also raised relevancy objections to producing the documents, as discussed below.
+20
+
+
+there is no way to determine which of the documents that the Government has provided to the
+Court are responsive to which of the victims' discovery requests - including which documents
+relate to Dershowitz. See DE 265 at 1-2. The Government then asserted a host of privileges,
+including qualified privileges, such as deliberative process privilege, investigative privilege, and
+the work product doctrine. Qualified privileges require the Court to engage in a far-ranging
+inquiry that balances competing interests. As the victims have recounted in their (currentlypending) objections to the Government's assertion of privilege, the Court must weigh such things
+as "the 'seriousness' of the litigation" (DE 265 at 9), "the importance of the information sought
+to the plaintiff's case" (DE 265-1 at 22), and whether there is a "compelling need" for disclosure
+(DE 265 at 14). Clearly Jane Doe No. 3's allegations factor into this balancing of interests about
+production of documents relating to Dershowitz (and others).
+3. Motive
+When the Court ultimately rules on the underlying substantive issue of whether the
+Government violated the victims' rights, motive will be a central issue. The Government has
+repeatedly asserted benign motivations for not revealing the NPA to the victims, and the victims
+have strongly contested those assertions. See, e.g.. DE 266 at 10 ("Motive is clearly in dispute in
+this case ...."). The NPA itself contains several unusual provisions that invite debate over how
+they came into existence - such as the "confidentiality" provision that illegally barred disclosure
+to the victims and the "blank check" co-conspirator immunity provision discussed immediately
+below. An important question is whether these strange provisions were crafted accidentally - or
+as part of a deliberate plan to keep the victims in the dark, as the victims are contending. See,
+eg.. DE 48 at 11 (alleging that the Government and defense counsel decided that the NPA
+should be "kept from public view because of the intense public criticism that would have
+21
+
+
+resulted from allowing a politically-connected billionaire who had sexually abused more than 30
+identified minor girls to escape from federal prosecution with only a county court jail sentence").
+The fact that an important attorney on the defense team had strong personal reasons for resolving
+the case without a public trial bears directly on this question, by showing motivation to reach a
+secret deal. Dershowitz's need to keep his abuse secret, and his direct personal knowledge of
+Epstein's abuse, also goes to issues revolving around whether the defense team engaged in a
+"yearlong assault on the prosecution and prosecutors," as alleged by former U.S. Attorney
+Alexander Acosta. See DE 266 at 12.'3
+Issues pertaining to motive can always be pursued, particularly when a case is in an early
+discovery phase. See, e.g., Gelabert |. State, 407 So. 2d 1007, 1010 (Fla. 5th DCA 1981). And
+"motive is always relevant in a criminal case, even if it is not an element of the crime." United
+States | Hill, 643 F.3d 807, 843 (11th Cir. 2011) (internal quotation omitted).
+When speaking not to the Court but rather to the media, Dershowitz has clearly admitted
+the relevance of Jane Doe No. 3's allegations about him to issues of motive. Speaking on CNN,
+for example, Dershowitz stated that he was being "targeted" precisely because his involvement
+in Epstein's sexual trafficking would help "blow up" the plea agreement:
+1 In his Supplement to his Motion for Limited Intervention, Dershowitz claims that only information
+relevant to this case is information known by the Government before September 24, 2007 - the latest date
+on which, according to Dershowitz, the Government made the decision not to pursue federal criminal
+charges against Epstein. DE 285 at 1. Dershowitz appears to be unaware that the Government told the
+victims well after that date that the Government was still "investigating" the case. DE 48 at 16. In
+addition, what knowledge the Government had of Epstein's trafficking crimes before September 24, 2007,
+is very much a disputed issue. For example, the victims believe that among the 14,825 pages of discovery
+currently before the Court in camera are many documents proving the Government's had knowledge
+while it was negotiating the NPA that Epstein was trafficking underage girls for sex to Dershowitz and
+others. Indeed, it is likely that documents pertaining to the trafficking of Jane Doe No. 3 herself are found
+in those pages, and she would ask the Court to pay particular attention to such documents as part of its in
+camera review. This evidence provides a further reason the Government wanted to conceal the NPA
+from the victims - and the public: to avoid the outcry that would have arisen if it was known that
+prosecutors were giving such a lenient deal to an international sex trafficker.
+22
+
+
+[The victims] want to be able to challenge the plea agreement. I was one of the
+lawyers who organized the plea agreement. I got the very good deal for Jeffrey
+Epstein. ... And if they [i.e., victims' counsel] could find a lawyer who helped
+draft the agreement who also was a criminal, having sex - wow - that could help
+them blow up the agreement. So they sat down together, the three of them - these
+two sleazy, unprofessional, disbarrable lawyers, Paul Cassell, a former federal
+judge [and] current professor, and another sleazy lawyer from Florida, Brad
+Edwards - ... and said who would fit into this description: A lawyer, who knows
+Epstein, who helped draft ...? Ha, Dershowitz! So they and the woman got
+together and contrived and made this up.!
+Similarly, on the Meredith Vieira Show, Dershowitz alleged that allegations against him "fit the
+profile" of what it could take to vacate the plea.! Of course, Jane Doe No. 3 (and her attorneys)
+are prepared to show they did not "contrive" the allegations. Dershowitz's name was not drawn
+from a hat. Rather, he was added to the pleading because Jane Doe No. 3 identified him as one
+of her abusers. And once she proves the truth of her sworn allegations, then - as Dershowitz
+himself colorfully puts it - the victims have additional relevant evidence that will help them to
+"blow up" the plea.
+4.
+The NPA's "Blank Check" Co-Conspirator Immunity Provision and the Scope of
+the Remedy that the Victims Might Obtain.
+Jane Doe No. 3 explained in her motion to intervene that Dershowitz helped negotiate a
+NPA that contained a sweeping provision that provided immunity in the Southern District of
+Florida not only to Epstein, but also to '"any potential co-conspirators of Epstein." DE 280 at 4
+(quoting NPA at 5)." This provision is very unusual - a proverbial "blank check" blocking
+federal criminal prosecution of people who are not specifically identified - raising an inference
+http://www.cnn.com/2015/01/06/us/dershowitz-sex-allegation/ (Jan. 6, 2015) (emphasis added).
+http://meredithvieirashow.com/videos/alan-dershowitz-defends-himself/ (Jan. 8, 2015).
+23
+
+
+that the defense team may have had ulterior or unidentified motives for pressing for the
+provision.
+More broadly, knowledge of the persons who are covered by this provision is directly
+relevant to the scope of the remedy that the victims may be able to obtain from the Court if they
+prevail on the merits of their claim. The Court has already received briefing from the victims
+and the Government on the remedy issue - and has prospectively allowed Epstein to intervene on
+any issue involving rescission of the NPA. DE 246. The victims all intend to seek rescission of
+the co-conspirator provision as part of any relief in this case. The fact that several of Jane Doe
+No. 3's sexual abusers - i.e., Dershowitz, Maxwell, Brunel, and Prince Andrew - are currently
+covered by the provision will thus be relevant to the scope of the remedy that the victims can
+obtain and the persons that they can seek to have prosecuted.
+5. Interface Issues.
+The Court has previously ruled that the victims' CVRA claim "implicates a fact-sensitive
+equitable defense which must be considered in the factual context of the entire interface between
+Epstein, the relevant prosecutorial authorities and the federal offense victims ...." DE 189 at 12
+n.б. Part of that "entire interface" is Epstein's defense team - which included Dershowitz. And
+Jane Doe No. 3 is one of the victims - indeed, an international sex trafficking victim. Her
+important factual allegations about extremely serious international trafficking crimes being swept
+under the rug in a dubious and secret non-prosecution agreement provide a critical piece of the
+"factual context" that the Court must consider.
+6. The "Crime/Fraud" Exception to the Attorney-Client Privilege and Other Privileges.
+Jane Doe No. 1 and Jane Doe No. 2 have specifically raised the argument that a
+crime/fraud/misconduct exception applies to the Government's assertion of attorney-client
+24
+
+
+privilege over various documents. DE 265 at 5-6. Based on Jane Doe No. 3's allegations,
+communications between the Epstein defense team and the Government appear to furthered a
+crime - i.e., Dershowitz's conspiracy with Epstein to engage in, and conceal, sex trafficking.
+And Government prosecutors' internal discussions may have unwittingly furthered that crime.
+See In re Grand Jury Investigation, 445 F.3d 266, 275-76 (3rd Cir. 2006) (attorney's lack of
+knowledge of the crime being furthered not relevant to crime-fraud exception).
+7. Right to be "Treated with Fairness " Issues.
+In his "supplemental" pleading, Dershowitz seems to assume that the victims are raising
+only a claim about their right to "confer" with prosecutors. DE 285 at 1-2. But Jane Doe No. 1
+and Jane Doe No. 2 also have a much broader, over-arching claim of a violation of their right "to
+be treated with fairness" under 18 U.S.C. § 3771(a)(8). See DE 48 at 36. Jane Doe No. 3 was
+known to the United States Attorney's Office at the time of the Epstein investigation, as
+evidenced by her inclusion in the NPA's attachment identifying known victims. The fact that
+Jane Doe No. 3 - a victim of international sex trafficking - was kept in the dark about the plea
+deal will provide further evidence of a violation of the right to be treated with fairness. The
+scope of her abuse - and the fact that the prosecution of crimes against her in the Southern
+District of Florida is now blocked by an agreement negotiated by one of her abusers - also all go
+to violations of the fairness right.
+8. Jane Doe No. 3 Will Be a Witness for Jane Doe No. 1 and Jane Doe No. 2 at Trial.
+Finally, the record in this case should reflect that Jane Doe No. 1 and Jane Doe No. 2
+intend to call Jane Doe No. 3 as a witness in any hearing or trial that the Court may schedule in
+this matter. The Government's violation of her rights is clearly evidence of a common scheme
+25
+
+
+or plan to keep crime victims in the dark, made admissible in any hearing by virtue of Fed. R.
+Evid. 404(b).
+For each of these eight reasons, Jane Doe No. 3's allegations against Dershowitz are
+plainly relevant to this case and therefore his attempt to intervene to strike them is futile."
+D.
+DESHOWITZ SHOULD NOT BE ALLOWED TO INTEVENE TO
+STRIKE JANE DOE NO. 3'S ALLEGATIONS BECAUSE SHE HAS
+SWORN TO THEIR TRUTH AND THEY ARE ALL SUPPORTED BY
+STRONG CORROBORATING EVIDENCE.
+Dershowitz finally claims that he should be allowed to intervene because Jane Doe No.
+3's allegations against him are false. In support of this position, he attaches a carefully-crafted,
+self-serving declaration. But a litigant's mere claim that contrary allegations are false provides
+no legal basis for striking them. See Moore's Federal Practice § 12.37[3A] (3d ed. 2014) ("Rule
+12 does not provide any authority to strike pleadings on the basis of falsity" because doing so
+would "effectively [be] a resolution on the merits, which is not appropriate at the pleading
+stage."). At early stages of litigation, "It]he court accepts all well-pleaded allegations as true"
+and views factual allegations "in the light most favorable to the non-moving party," Johnson
+Nobu Associates South Beach, LP, No. 9:10-cv-21691-KAM, 2011 WL 780028 at *2 (S.D. Fla.
+2011). In any event, to rebut Dershowitz's false claims directly, Jane Doe No. 3 now provides
+her own sworn affidavit, attached as Exhibit 1,'® repeating under oath the allegations that her
+" A ninth reason now also exists that the allegations are relevant, given that the Government recentlyaised the argument that the Jane Doe No. 3 has failed to meet a six-year statute of limitations specified in
+18 U.S.C. § 2401. DE 290. Jane Doe No. 3 will contest whether that statute of limitations even applies
+But Jane Doe also intends to raise an equitable estoppel argument - that the statute was tolled while she
+was in hiding in Australia due to the danger posed by Epstein and his powerful friends. Her factual
+allegations - including the specific identities of those powerful persons - are clearly relevant to
+demonstrating the factual underpinnings for her estoppel argument.
+'' In paragraph 52 of Exhibit 1, the name of a sexual participant and eye-witness was redacted out of an
+abundance of caution, because while she was not a minor at the relevant time she is believed to have
+26
+
+
+attorneys proffered in her earlier motion - i.e., that Epstein sexually trafficked Jane Doe No. 3 to
+numerous persons, including Dershowitz. If the Court believes it would be useful, Jane Doe No.
+3 requests an evidentiary hearing to prove she is telling the truth ' and directs the Court's
+attention the following substantial information supporting her sworn statement." To be clear,
+what follows is just part of the compelling information supporting Jane Doe No. 3's allegations.
+Any assessment of Jane Doe No. 3's sworn statement (and Dershowitz's protestations of
+innocence) must begin with two incontestable facts: First, Dershowitz is an extremely close
+personal friend of Epstein's. In fact, in 2005 (before the scandal of the criminal prosecution
+broke) Dershowitz stated "T'm on my 20th book. ... The only person outside of my immediate
+family that I send drafts to is Jeffrey." The Talented Mr. Epstein, by Vicky Ward, in Vanity Fair
+(Jan. 2005).2' Dershowitz has also been quoted as saying that, even if Epstein went bankrupt, "I
+would be as interested in him as a friend if we had hamburgers on the boardwalk in Coney Island
+and talked about his ideas." Vanity Fair Reminds Us When Jeffrey Epstein Wasn't a Creep, by
+Ray Gustini, in The Wire (June 21, 2011).
+Second, Jeffrey Epstein brazenly abused numerous girls in his Florida mansion, his New
+York mansion, and several other places that Dershowitz apparently admits he visited. See DE
+282-1 at 1-3 (Dershowitz affidavit discussing visits to Epstein). Proof of the notorious abuse
+originally been a victim of Epstein's sexual abuse while a minor. She is now a well-known actress whose
+identity we have unilaterally protected in this context.
+19 Jane Doe No. 3 asks that the evidentiary hearing be held after discovery phase in this case is completed,
+because she believes that the Government possesses significant information that, if disclosed, would fully
+support her allegations. She requests the Government acknowledge this fact in any response it files.
+2° Cf. The Last Word with
+O'Donnell - MSNBC (Jan. 8, 2015), http://www.msnbc.com/thelast-word/watch/alan-dershowitz-on-allegations--totally-false-381942851573 (Dershowitz: "Right now,
+they have accused me of these ... things without a single affidavit, without a single piece of evidence.")
+' More recently, Dershowitz has disclaimed knowing Epstein well, stating that during the relevant time
+he was a mere "social acquaintance" and that "I was at [Epstein's] home for parties with a large number
+of mostly scientists, mostly men, dinner parties, intellectual gatherings." UMAR News,
+(Jan. 4, 2015).
+27
+
+
+starts with the NPA, under which Epstein agreed to register as a sex offender and provide
+compensation to approximately forty girls who he had sexually abused. Additional girls who he
+abused (such as movant Jane Doe No. 4) were not included in the NPA. Combined with the
+sworn testimony in the underlying civil cases, the NPA demonstrates persuasively that Epstein
+committed hundreds and hundreds of acts of sexual abuse against young girls - ostensibly
+"massage therapists" - during the relevant time period. See Exhibit 16 at 2 (collecting
+testimony). A small sample of the girls that Epstein sexually abused includes Jane Does Nos. 1,
+2, 3, and 4, as well as S.G., A.D.,
+., N.R., J.S.,
+., J.A., J.E., M.L., M.D., D.D, and D.N. -
+all girls between the ages of 13 and 17. Id. at 7-8.
+Given the astonishing number of victims, and the detailed descriptions from many of
+them, Epstein's abuse of young girls clearly occurred on a "daily" basis. See Ex. 1 at 9 17.
+Indeed, according to his scheduled appointments, evidenced by the message pads retrieved by
+the Palm Beach Police Department, on some days Epstein engaged in sex with multiple girls.?
+In 2009, one of Epstein's household employees, Juan Alessi, was deposed about the
+parade of young "massage therapists" entering Epstein's Palm Beach mansion. He started
+working for Epstein in about January 1999. He testified that Jane Doe No. 3"3 was one of the
+girls who came to Epstein's mansion regularly when she was in the age range of 15 to 19. Juan
+Alessi Depo. at 46:21-47:4, 48:18-25, Jane Doe No. 2 | Epstein, No. 9:08-Cv-80119-cv-KAM
+(S.D. Fla. Sept. 8, 2009) (excerpts attached as Exhibit 18).
+Alessi also saw many celebrities came to the Florida mansion, including not only Prince
+Andrew and his wife Sarah but also "a very famous lawyer that I'm sure you know, Alan
+" Upon request, victims counsel could provide the Court with these materials for review. The materials
+contain the names of minor victims of sexual assault, so sealed transmission would be necessary.
+' In the deposition, Jane Doe No. 3 is identified by initials.
+28
+
+
+Dershowitz." Id. at 70:9-25. Alessi testified that Dershowitz came to the mansion "pretty often .
+.. at least four or five times a year" and would stay "two [or] three days." Id. at 73:22-25. Jane
+Doe No. 3 came to the house when Dershowitz was there. Id. at 73:18-20. And - importantly -
+Dershowitz got massages while he was visiting Epstein's home. Alessi answered "yes" when
+asked whether Dershowitz "had massages sometimes when he was there," and explained that
+"[a] massage was like a treat for everybody." Id. at 74:1-4. The private, upstairs room where
+Dershowitz got his "massages" was one that contained a lot of vibrators - Maxwell had a
+laundry basket ... full of those toys" in that room. Id. at 76:11-15.
+In 2009, one of Epstein's most trusted employees was also deposed: Alfredo Rodriguez,
+the butler at Epstein's Palm Beach mansion. Rodriguez testified under oath that Dershowitz was
+at Epstein's mansion when underage girls were there to give massages. Alfredo Rodriguez
+Depo. at 278:13-25, 279:9-280:2, Jane Doe No. 2 |. Epstein (excerpts attached as Exhibit 19).34
+Rodriguez also testified that Dershowitz stayed at the house in his role as Epstein's friend, as
+opposed to being his lawyer (id. at 279:5-8; 385:1-6) and that Dershowitz was present alone at
+the home of Jeffery Epstein, without his family, in the presence of young girls. Id. at 199:12-13,
+279:9-12, 426:16-25, 427:1. In fact, Rodriguez described that when the underage girls would
+come over, Dershowitz would drink wine and read books on the couch. Id. at 426:16-25; 427:1.
+As is familiar to this Court, after Rodriguez's deposition, he attempted to sell a 97-page
+document that he appropriated from Epstein's computer. The document contained Epstein's
+telephone directory - as well as a list of apparent young girls in various locations, including
+* According to press reports, Rodriguez recently passed away, See "Houseman who cleaned pedophile
+Jeffrey Epstein's sex toys and feared he would make him 'disappear" takes billionaire's secrets to the
+grave after he died just law week," http://www.dailymail.co.uk/news/article-2897939/Houseman-cleanedpedophile-Jeffrey-Epstein-s-sex-toys-feared-billionaire-make-disappear-takes-secrets-grave.html (Jan. 6,
+2015).
+29
+
+
+
+
+Nadia Marcinkoval
+
+
+
+
+professor at Harvard. B.B. y. Epstein, No. 502008CA03731XXXXMB, Epstein Depo. Tr. at 122
+(Palm Beach Cty. Cir. Ct. Oct. 8, 2009).
+In short, all the key conspirators in Epstein's sexual trafficking ring who could be asked
+about Derhowitz's involvement took the Fifth." This "[s]ilence is ... evidence of the most
+persuasive character:" United States ex rel. Bilokumsky : Tod, 263 U.S. 149, 153-54 (1923)
+(Brandeis, J.), quoted in Baxtery. Palmigiano, 425 U.S 308, 319 (1976). And that silence takes
+on an even more sinister cast when combined with the fact that Epstein's sexual interest in young
+girls would have been obvious to someone like Dershowitz, Epstein's close personal friend who
+was present at the very locations when abuse was taking place. See Ex. 1 at 9| 17.
+Additional credibility to Jane Doe No. 3's sworn statement is provided by clear evidence
+of a common scheme or plan, admissible under Fed. R. Evid. 404(b). As is clear from the
+evidence recounted l
+above, Jane Doe No. 3's allegations against Jeffrey Epstein are
+overwhelmingly corroborated by numerous other girls and Epstein's private flight logs
+demonstrating Jane Doe No. 3's travel with him while under 18 years old. In addition, her
+allegations against Prince Andrew are strongly corroborated. For example, while Buckingham
+Palace has recently denied that Prince Andrew had sexual contact with Jane Doe No. 3, it has not
+attempted to explain what led to the Prince having his picture taken with his arm around a 17-
+year-old American girl at night in London in an intimate setting in a private residence. Nor has
+the Palace explained what Ghislaine Maxwell is doing there and who took that picture - while
+Jane Doe No. 3 has provided a sworn affidavit that the photographer was Prince Andrew's close
+friend (as well as sex trafficker and now-registered sex offender): Jeffrey Epstein. Jane Doe No.
+" As noted earlier, two other key conspirators - Ghislaine Maxwell and Jean Luc Brunel - evaded
+depositions to avoid answering any questions under oath.
+33
+
+
+3 has also made strong, credible claims against Jean Luc Brunel - corroborated allegations that
+parallel those made by others. See Exhibit 16 at 22.
+In contrast to this interlocking web of corroborating evidence, the Court should examine
+what Dershowitz says in his affidavit - and, more important, fails to say. The Court will notice
+that Dershowitz devotes only a single sentence in his affidavit to his activities at Epstein's Palm
+Beach and New York mansions. See DE 282-1 at 3 ("As to Mr. Epstein's homes in New York
+City and Palm Beach, I categorically state that I never had any sexual contact with Jane Doe
+#3."). The Court may immediately wonder about the following questions: How long did
+Dershowitz spend at these homes? Was he with his wife and family, as he has suggested in
+television interviews? How many times was he there overnight? Did Dershowitz ever see any of
+the dozens and dozens of young girls whom Epstein was sexually abusing? Did Dershowitz ever
+get a "massage" from one of these young girls?
+The Court may also wish to contrast Dershowitz's very narrow affidavit with his more
+sweeping statements to the media. On popular television programs, Dershowitz has emphatically
+denounced Jane Doe No. 3 as a liar and said he can prove "conclusively" that he has never even
+met her." Yet in his sworn affidavit, Dershowitz does not repeat that broad claim." Nor does
+Dershowitz ever address his knowledge of other young girls, in addition to Jane Doe No. 3,
+abused by Epstein in those houses.
+30 See, e.g., http://www.cnn.com/2015/01/05/europe/prince-andrew-sex-abuse-allegations/index.html ("Q:
+"Have you ever met this woman named [Jane Doe No. 3]?" A: "No. Absolutely not, I don't know who
+she is."); CNN News Day
+http://www.cnn.com/videos/tv/2015/01/05/bts-newday-alan-dershowitz-prince-andrew-sex-scandalallegations.cnn (Jan. 5, 2015) ("I never met this woman. I never touched her. I was never massaged by
+her. There was no contact, no contact whatsoever - and I will prove it conclusively.").
+3' In the media, Dershowitz has also offered to execute a waiver of the statute of limitations to enable
+Jane Doe No. 3 to file charges against him. Shortly after Dershowitz first made that offer, Jack Scarola,
+Esq., provided Dershowitz with a waiver form for him to sign. Dershowitz declined to sign the form and
+later advised, through his counsel, that he was "considering" whether to waive the statute of limitations.
+34
+
+
+In his affidavit, Dershowitz also cagily states that he sent a letter to an attorney who was
+seeking a deposition, recounting that in that letter he (Dershowitz) said he was "not a witness to
+any alleged crimes." DE 282-1 at 3. But Dershowitz does not repeat under oath the broad claim
+that he never witnessed any alleged crimes - presumably because he is aware of certain child
+abuse reporting obligations that might be at issue if he did so.
+Against this mounting evidence of guilt, Dershowitz suggests in his affidavit that aircraft
+flight manifests will exonerate him. DE 282-1 ('I was on that plane on several occasion as the
+manifests will show, but never under circumstances where it would have been possible to have
+sex with Jane Doe #3."). In media statements, Dershowitz has repeatedly brought up the
+manifests as proof of innocence. Coincidentally and remarkably, it was Dershowitz himself,
+acting as Epstein's attorney, who personally collected and then provided flight manifests to the
+Palm Beach Police Department. See, e.g., Police Detective Joe Recarey Depo. at 281, Jane Doe
+No. 2 |. Epstein, No. 9:08-Cv-80119-KAM (Mar. 19, 2010). (excerpts attached as Exhibit 29)
+Dershowitz provided manifests covering just the 10 months: January 1, 2005, through October
+17, 2005, During civil litigation, believing that these flight manifests were grossly incomplete,
+counsel subpoenaed Epstein for complete flight logs. Epstein failed to provide any information
+at all. Counsel were then forced to request flight logs from Epstein's various private pilots.
+One of Epstein's pilots, David Rogers, provided certain flight logs covering some flights
+from a much broader time frame: 1997-2005. This production confirmed that the flight
+32 See, e.g.. The Today Show, Jan. 5, 2015 ("She claims I had sex with her in the airplanes, manifests of
+the flights will show I was never on the airplanes with her."); Hala Gorani - CNN Live, Jan. 5, 2015 ("As
+far as the planes are concerned, there are flight manifests. They will prove I was never on any private
+
+
+information Dershowitz provided to police was incomplete. A comparison of the flight
+manifests and logs confirms that the flight logs provided by Rogers were also incomplete. A
+cursory review of both logs reveals that together the logs produced cover only a small fraction of
+the flights taken and the passengers on board. While this is obvious for multiple reasons, a few
+examples may help to make this point. For instance, the flight records provided by Dershowitz
+for a February 3, 2005, flight from CMH (Columbus, Ohio) to PBI (Palm Beach, Florida),
+indicate that in addition to Jeffrey Epstein,
+and Jean Lue
+Brunel, on board were three "females." The existence of these three "females" is conspicuously
+absent from the Rogers' logs. Compare Composite Exhibit 25 with Composite Exhibit 26
+(Rodgers Logs). Other flights, such as the March 18, 2005 flight from New York to Florida,
+taken by Maxwell, Epstein and
+are missing altogether from the Rogers logs.
+Likewise, flights that appear on the Rogers logs are missing from the logs produced by
+Dershowitz. Multiple examples lead to the clear conclusion that all produced logs are
+incomplete and may well have been heavily sanitized. For example, on February 9, 1998,
+Dershowitz flew on Epstein's private plane from Palm Beach, Florida, to Teterboro, New Jersey.
+One of the passengers is listed as "1 female." Exhibit 27. Who is that "female" - and what is
+her age? Similarly, Jane Doe No. 3 appears on a July 16, 2001, flight from Santa Fe, New
+Mexico to Teterboro, New Jersey, along with Epstein, Maxwell and
+Yet there is
+no earlier flight that would have landed Jane Doe No. 3 in New Mexico. According to the logs,
+the next flight is from Palm Beach to the U.S. Virgin Islands on July 23, 2001, although Jane
+Doe No. 3 does not appear. The impression is that she remained in the New Jersey area.
+However, on July 28, 2001, Jane Doe No. 3 is on a flight with Epstein from the Virgin Islands
+back to Palm Beach. See Exhibit 26. How did she get to the Virgin Islands?
+36
+
+
+The flight logs provide evidence of some of the individuals who were on some of the
+flights - nothing more. Accordingly, it would not be surprising to find that some of these flight
+logs do not mention Dershowitz, because they were likely designed to hide evidence of criminal
+activity - or perhaps later cleansed of such evidence. With that said, some interesting things do
+appear in the flight logs. Unlike any other of Epstein's numerous criminal defense attorneys,
+Dershowitz appears in the flight logs for flights on Epstein's private planes produced by pilot
+Rogers on numerous occasions.
+Dershowitz also appears on flights with various females,
+including Epstein's known procurer of underage girls,
+And, in contrast to recent
+media suggestions by Dershowitz, his family does not appear on any of the flights with him.
+Jane Doe No. 3 is listed on the logs as a passenger at a time when she is under age 18.
+While the logs do not show Dershowitz on the same flight with her, it is abundantly clear that the
+logs do not contain evidence of all of the flights that she was on and that they are grossly
+incomplete. The flight logs do confirm that she was transported by Epstein to Florida, New York,
+London, New Mexico, and the U.S. Virgin Islands - locations where she states under oath that
+Epstein forced her to have sex with various individuals, including Dershowitz.
+Finally, in Dershowitz's vociferous attacks on Jane Doe No. 3, the Court will see an eerie
+parallel to the Jeffrey Epstein criminal investigation. Back in 2005, when the Palm Beach Police
+Department was first investigating Epstein's sexual abuse, it interviewed more than a dozen
+minor girls. These girls all provided information about abuse similar to the abuse that Jane Doe
+No. 3 says she suffered in Florida. The Department accumulated overwhelming evidence
+placing underage girls at Epstein's residence with no obvious legal purpose. The logical
+explanation was that these young girls were being truthful when they told law enforcement that
+Epstein (and others) were sexually abusing them.
+37
+
+
+Rather than acknowledge sexual abuse of these girls, Dershowitz blustered down to
+Florida to meet with the State Attorney and to viciously attack the credibility of these victims -
+to call them liars, defame them as prostitutes, and convince the State Attorney that these girls
+could not even believably establish that they had ever even gone to Epstein's mansion. See, e.g..
+Depo. of Police Chief Michael Reiter at 53-55, 102-06, B.B. |. Epstein, No. 502008CA037319
+XXXX-MB-AB (Palm Beach Cty. Cir. Ct. Nov. 23, 2009) (excerpts attached as Exhibit 28); see
+also Depo. of Police Detective Joe Recarey at 301-302 and 309-10, Jane Doe No. 2 |. Epstein,
+No. 9:08-cv-80119-KAM (S.D. Fla. Mar. 19, 2010) (excerpts attached as Exhibit 29) Later,
+Dershowitz would write to tell the Justice Department that "Epstein never targeted minors."
+Letter from Gerald Lefcourt & Alan Dershowitz, July 6, 2007 to U.S. Atty.'s Office for the S.D.
+Fla (attached as Exhibit 30). Now, nearly a decade later, there should be no doubt in anyone's
+mind that the minor girls who cooperated with the authorities told the truth about their sexual
+abuse inside Epstein's home -- and that Dershowitz's attack on their credibility was duplicitous.
+In fact, according to credible eyewitness testimony recounted above, Dershowitz was clearly
+present in the home while some of these girls were being abused. The Court should not allow
+Dershowitz's similar bullying tactics to succeed in this case.?3
+CONCLUSION
+Dershowitz's motion for intervention (DE 282) should be denied.
+' In the media, Dershowitz has said that he will prove that Jane Doe No. 3 is lying "beyond any doubt by
+physical and documentary evidence." The Last Word with
+along with his reply brief.
+38
+
+
+DATED: January 21, 2015
+Respectfully Submitted,
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+Telephone (954) 524-2820
+Facsimile (954) 524-2822
+E-mail: brad@pathtojustice.com
+and
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile: 801-585-6833
+E-Mail: cassellp@law.utah.edu
+Attorneys for Jane Doe #1 and Jane Doe #2
+" This daytime business address is provided for identification and correspondence purposes only and is
+not intended to imply institutional endorsement by the University of Utah
+39
+
+
+CERTIFICATE OF SERVICE
+I certify that the foregoing document was served on January 21, 2015, on the following
+using the Court's CM/ECF system:
+Dexter Lee
+A. Marie Villafaña
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Fax: (561) 820-8777
+E-mail: Dexter.Lee@usdoj.gov
+E-mail: ann.marie.c.villafana@usdoj.gov
+Attorneys for the Government
+Thomas Scott
+thomas.scott@csklegal.com
+COLE, SCOTT & KISSANE, P.A.
+Dadeland Centre II
+9150 South Dadeland Boulevard, Suite 1400
+Miami, Florida 33156
+Telephone: (305) 350-5300
+Facsimile: (305) 373-2294
+-and-
+Kendall Coffey
+kcoffey@coffeyburlington.com
+Gabriel Groisman
+ggroisman@coffeyburlington.com
+Benjamin H. Brodsky
+bbrodsky@coffeyburlington.com
+COFFEY BURLINGTON, P.L.
+2601 South Bayshore Drive, PH 1
+Miami, Florida 33133
+Telephone: (305) 858-2900
+Facsimile: (305) 858-5261
+Attorneys for Alan Dershowitz
+/s/ Bradley J. Edwards
+40
+
+
+
+
+
+A PROFESSIONAL CORPORATION
+148 EAST 78™* STREET
+NEW YORK, NEW YORK 10021
+GERALD B. LEFCOURT
+lefcourt@lefcourtlaw.com
+SHERYL E. REICH
+relch@lefcourtiaw.com
+RENATO C. STABILE
+stabile@lefcourtlaw.com
+FAITH A. FRIEDMAN
+friedman@lefcourtlaw.com
+July 6, 2007
+BY FEDERAL EXPRESS
+Jeffrey Sloman, Esq., First Assistant United States Attorney
+Matthew Menchel, Esq., Chief, Criminal Division
+The United States Attorney's Office
+Southern District of Florida
+99 NE 4" Street
+Miami, Florida 33132
+Andrew Lourie, Deputy Chief, Northern Region
+A. Marie Villafaña, Assistant United States Attorney
+The United States Attorney's Office
+Southern District of Florida
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+WhERERNE
+Jeffrey Epstein
+Dear Messrs. Sloman, Menchel and Lourie and Ms. Villafaña:
+you make on how and whether to proceed.
+I.
+18 U.S.C. §2422(b) Has No Applicability to the Facts Here.
+Even assuming the facts as you believe them to be, as demonstrated below, a
+prosecution under 18 U.S.C. §2422(b) would violate the explicit terms of the statute, pose
+insurmountable constitutional barriers, and be unprecedented, unwise, and utterly
+inappropriate. This statute, with its mandatory minimum sentence' was designed to reach
+'The statute in effect during the events at issue carries a mandatory five-year period of
+incarceration. The current ten-year mandatory minimum was instituted in 2006.
+MIA_CEOS_00077
+
+
+GERALD B. LEFCOURT. PC.
+A. Marie Villafaña, Esq.
+The United States Attorney's Office
+Southern District of Florida
+those who deliberately, knowingly, and intentionally target and exploit children through
+chanters, Though that the slangue may superti balsed ply rosevider area of
+traditionally been viewed as state offenses, even if some facility or means of interstate
+commerce can be said to have been used by someone at some point during the course of
+events.
+1.
+Congress's Purpose
+H.R. Conf. Rep. No. 104-458, at 193 (1996), quoted in United States I Searcy, 418 F.3d
+1193, 1197 (11" Cir. 2005); see also K. Seto, "Note: How Should Legislation Deal with
+Children and the Victims and Perpetrators of Cyberstalking?" 9 Cardozo Women's L.J. 67
+(2002).
+In enacting the statute, Congress recognized that young people were using the
+internet in ever-increasing numbers, and it was proving to be a dangerous place.
+According to a DOJ study, one in five youths (aged 10 to 17) had received a sexual
+approach or solicitation over the internet in the previous year. One in 33 had received an
+"aggressive sexual solicitation", in which a predator had asked a young person to meet
+somewhere or called a young person on the phone. U.S.D.O.J., Office of Justice
+Programs, OVC Bulletin," Internet Crimes Against Children" (12/2001);
+www.ojp.usdoj.gov/ovc/publications/bulletons/internet_" 2_2001/internet_2_01_6.html.
+internet, which occurs in private, and the secrecy and deception that acting in cyberspace
+presented pecial law enforcement problems a ce icul for any local jurisdiction to
+tackle. The 'mandatory minimum sentence for a violation of this section was increased
+from five years to ten years in 2006, by virtue of the Adam Walsh Child Protection and
+Safety Act of 2006, which also eliminated any statute of limitations. See 18 U.S.C.
+MIA_CEOS_00078
+
+
+Andrew Lourie, Esq.
+Page 3
+minimum penalties for the most serious crimes against our children." 2006
+U.S.C.C.A.N. S35, 2006 WL 3064686 (emphasis added). The five-year mandatory
+minimum it replaced was itself established as part of the PROTECT Act of 2003, another
+law designed to strengthen the government's ability to deal with certain dangerous sexual
+predators who exploited children in ways the states had been unable to address fully.?
+2.
+General Overview
+It must be remembered that §2422(b), by using the phrase "any sexual activity fo
+which any person can be charged with a criminal offense"
+"," in some sense incorporates
+all the sex offense laws of all 50 states, in all their variety and in all their ambiguity. This
+in itself raises questions of the utmost seriousness, implicating fairness and the due
+process clause. It also constitutes an extreme example of federal pre-emption, or, more
+precisely, the wholesale annexation of the enforcement responsibility of each of the 50
+states' sex-related crime statutes - whether felony, misdemeanor or violation - wherever
+there has been use of the ever-present wires. To make every state sex "offense" involving
+a person under 18 potentially into a mandatory minimum ten-year federal felony without
+any statute of limitations is certainly not what Congress had in mind when it enacted
+§2422(b).
+" Other federal crimes with ten-year mandatory minimum involve very serious acts. See, e.g., 18
+U.S.C. §2113(e) (bank robbery where a person is killed or kidnapped); 18 U.S.C. §924 (involving
+discharge of firearm).
+3 Section 2422(b) has always carried a substantial penalty. When first enacted, the maximum
+se main pm was id reased to 95, Pars. Pub. 10, 314, Tie 1, Sec, 120, 12 slat. 2975 (ha.,
+30, 1998 to April 29, 2003).
+"A phrase which, by itself, and in the context of the remainder of the statute, raises mindnumbing questions as to what, exactly, is proscribed.
+MIA_CEOS_00079
+
+
+ORRALD B. LEFCOURT, P.C.
+Matthew Menchel, Esq.
+Andrew Lourie, Esq.
+A. Marie Villafaña, Esq.
+The United States Attorney's Office
+Southern District of Florida
+The bulk importation of complex bodies of state law is highly problematic, and
+strongly counsels that such matters should be left to the states except in those rare
+circumstances where both a federal interest is clear and weighty, and the states are for
+some reason incapable of acting. Like issues of family law, these issues are
+quintessentially of state concern within our federal system.
+State laws regarding both sexual activity and the age of consent to engage therein
+are hugely varied, reflecting different histories, values, politics, and personalities. See
+Richard A. Posner & Katharine B. Silbaugh, A Guide to America's Sex Laws (1996). The
+various and shifting societal reasons underlying those laws, and the societal pressures
+operating in the area, where sexual mores change over time, complicate the matter even
+further. See generally Richard A. Posner, Sex and Reason (1992). The history of the
+Mann Act confirms the caution with which the federal government should approach this
+entire area. For example, historically, the Act was used by some prosecutors in some
+jurisdictions to prosecute acts - such as a man traveling with his paramour - which, we
+submit, never implicated a legitimate federal concern. See generally D.J. Langum,
+Crossing the Lines: Legislating Morality Under the Mann Act (1994).
+Even where there is broad agreement that certain conduct should be criminalized,
+the various states treat the very same conduct differently; to apply such laws selectively
+by different federal prosecutors would undermine further what uniformity does exist. In
+New York, for example, a 50 year old man who patronizes a 15 year old prostitute is
+guilty of a Class A misdemeanor. New York Penal Law §230.04. If §2422(b) were read
+expansively, then such person would face a 10-year mandatory minimum if he used the
+telephone to set-up his date with the young prostitute, even if the date never happened.
+And that would be so even if the prostitute were 17 ½ (and despite the fact that in New
+York the age of consent is 17, since prostitution is a "sexual offense" in New York).
+Clearly, these are applications and outcomes Congress did not contemplate when it
+enacted the law.
+Instead, these are matters best left to state law and state law enforcement. In the
+state, prosecutors and law enforcement authorities, who have far more experience dealing
+with sexual crimes, can exercise their discretion as to whom to prosecute and for what
+charges, taking into account both local attitudes and the wide range of circumstances that
+may exist when sexual offenses, or possible sexual offenses, involving minors were, or
+may have been, committed. That is particularly so since state laws generally permit the
+exercise of sentencing discretion, allowing the punishment to fit both the crime and the
+MIA_CEOS_00080
+
+
+Matthew Menchel, Esq.
+Andrew Lourie, Esq.
+A. Marie Villafaña, Esq.
+The United States Attorney's Office
+Southern District of Florida
+July 6, 2007
+perpetrator. Section 2422(b), with its ten-year mandatory minimum is far too blunt a tool
+to use in any circumstances except the narrow, clear-cut, and egregious circumstances
+Congress had in mind when it enacted this law.
+Though §2422(b) is susceptible to multiple interpretations, it was designed to
+ddress a specific a problem with which Mr. Epstein's case has nothing in common. I
+tretched to reach beyond the core concern of the statute, a host of problems immediatel
+arise. A simple reading of the words of the statute leaves any reasonable reader with far
+more questions than answers as to what is illegal. Any attempt to apply the statute to Mr.
+Epstein's situation highlights the many problems of vagueness, overbreadth, and simple
+incomprehensibility lurking in or just below the statute's text.
+3. The Statute's Text And Its Thrust
+Section 2422(b) currently provides:
+nterstate or toreign commerce, or within the specia
+naritime and territorial jurisdiction of the Unite
+years or for life.
+The statutory language and reported decisions confirm the statute's important, but
+narrow, focus: the luring of children over the internet. Unlike 18 U.S.C. §82241 et seq.,
+tional unter state statut and Explized Childrenticement elease can be a Ario ding to it
+ational center for Missing ar
+sider. Sisten emis miasily online enticemen as a cans, generaly wages she vicin is 14 or
+discretion to sentence offenders to less than one year in prison
+/missingkids/servlet/NewsEventServlet?LanguageCountry=en... 6/28/2007.
+MIA_CEOS_00081
+
+
+GERALD B. LEFCOUrT, PC.
+Andrew Lourie, Esq.
+Page 6
+"inducement", "enticement" or "coercion" be done "using the mail or any facility or
+means of interstate. commerce" (emphasis added). Any other reading would violate
+constitutional principles of fair warning, notice, lenity and due process. Additionally, any
+broader reading would violate the clearly stated intent of Congress that enacted the law
+and the President who signed it. It would also exceed the authority of Congress under the
+Commerce Clause by federalizing virtually all state sex offenses involving people under
+the age of 18.
+Section 2422(b) defines a crime of communication, not of contact. It makes
+unlawful a narrow category of communications, ones not protected by the First
+Amendment. Both the attempt and the substantive crime defined by §2422 are complete
+at the time when communication with a minor or purported minor takes place; the essence
+of the crime occurs before any face-to-face meeting or any sexual activity with a minor,
+and regardless of whether any meeting or activity ever occurs.
+Turning the statute on its head by first looking at the alleged sexual activities and
+then seeking to find a mailing, a use of the wires, or the involvement of another facility or
+means of interstate commerce as a pretext for the invocation of federal jurisdiction would
+be without precedent and make a narrowly-focused statute into virtually a complete
+federalization of all state sex offenses involving minors.
+4. The Statute Is Violated Only If A Facility Or Means Of Interstate
+Commerce Is Used To Do the Persuading Or Inducing
+Though the statute raises several difficult issues of construction, on one point it is
+clear and unambiguous: To be guilty of a crime under §2422(b), the mail or a facility or
+means of interstate commerce must be used to do the persuading or inducing. As the
+Court wrote in United States
+2006), to prove a violation, the government must show "(1) the use of a facility of
+interstate commerce; (2) to knowingly persuade, induce, entice or coerce, as well as
+the other elements. See also United States + Bolen, 136 Fed. Appx. 325, 2005 WL
+1475845 (11" Cir. 2005).
+MIA_CEOS_00082
+
+
+Matthew Menchel, Esq.
+Andrew Lourie, Esq.
+A. Marie Villafaña, Esq.
+The United States Attorney's Office
+• Southern District of Florida
+July 6, 2007
+Page 7
+The statutory language can bear no other construction. The words "whoever,
+using …. knowingly persuades .. "
+" necessarily requires that the "whoever" must "use"
+the interstate facility to knowingly persuade. That is, the word "using" is in the present,
+not the past, tense. Thus, the "using" must occur at the same time as the "persuading". If
+the statute meant otherwise, it could and would have been drafted differently: "whoever
+having used the mail and knowingly persuades" or "whoever uses the mail and
+knowingly persuades"
+'. But, as it is written, the actor must use the interstate facility to
+persuade or to entice, or to attempt to do so; use of the instrumentality cannot be
+incidental or peripheral.
+Indeed, assuming, arguendo, that the grammar and structure of the statute would
+allow another interpretation - which we believe it does not - nevertheless the obvious,
+straightforward reading controls. Anything else would violate the rule of lenity, requiring
+strict construction of penal statutes, as well as the requirement of fair notice guaranteed
+by the due process clause. ' As Thomas Jefferson put it in 1823: "Laws are made for men
+of ordinary understanding, and should therefore be construed by the ordinary rules of
+common sense. Their meaning is not to be sought for in metaphysical subtleties, which
+may make any thing mean every thing or nothing, at pleasure".
+According to one of the world's leading experts on grammar and specifically, the
+syntax and semantics of verbs, these rules of "ordinary understanding" and "common
+sense" dictate that
+applying to persuasion (etc.) done subsequent to the use of
+• We note that the structure of this statute is radically different from the structure of §1341, the
+using the mail to knowingly persuade is the essence of the crime.
+MIA_CEOS_00083
+
+
+GERALD B. LEFCOURT, P.C
+Matthew Menchel, Esq.
+Andrew Lourie, Esq.
+A. Marie Villafañia, Esq.
+The United States Attorney's Office
+Southern District of Florida
+July 6, 2007
+he mail, phone, etc., would be an unnatural an
+grammatically inaccurate reading of the language
+That the statute is so limited is also confirmed by the fact that prosecutors have
+clearly understood this limitation. After conducting extensive research, we find no case
+of a defendant being prosecuted under §2422(b) where he has used the internet or the
+telephone, and then, by some other means, such as personal contact, attempted to
+persuade, induce, or entice. On the contrary, all §2422(b) prosecutions we have reviewed
+are premised on a defendant's use of the internet (or occasionally the text messaging on a
+phone) as the vehicle of the inducement. See, e.g., United States . Murrel, 368 F.3d
+1283, 1286 (11"* Cir. 2004) (government must... prove that Murrell, using the internet,
+acted with a specific intent to persuade a means to engage in unlawful sex).
+In fact, we have reviewed every indictment filed in the Southern District of
+Florida in which there is at least one allegation of a violation of §2422(b). To the extent
+the facts could be discerned from the indictment, we found no case brought where the use
+of the means of communication was rémote from the persuading, coercion, etc.®
+Such prosecutorial restraint is in full accord with the legislative intent, which, as
+set forth above, was to go after internet predators who use the means of communication
+to persuade, coerce, etc. That the statute also makes reference to the mails and facilities
+or means of interstate commerce other than the internet does not suggest that the statutory
+purpose was broader: it is a common modus operandi of internet predators to continue to
+pursue young people whom they first contact on the internet. If the statute were read to
+make it viren, the induce or ped satep hete in it nude that pereas had id not otion
+yver the wires.
+of making a federal crime. Given the ubiquity of the telephone in modern life, especially
+" To confirm our view of the "plain meaning" of the words, we asked Steven Pinker, Johnstone
+annexed at Tab "A" at 3.
+& Annexed at Tab "B" is a chart in which each of the cases and its relevant facts are listed.
+MIA_CEOS_00084
+
+
+GERALD B. LEFcOURT, PC.
+Matthew Menchel, Esq.
+Andrew Lourie, Esq.
+1. Marie Villafaña, Esq
+The United States Attorney's Office
+Southern District of Florida
+Page 9
+mandatory ten-year minimum sentence.
+Indeed, given that the interstate highway system is itself an avenue of interstate
+commerce, United States | Horne, 474 F.2d 1004, 1006 (7" Cir. 2007), allowing a
+prosecution wherever a means or facility of interstate commerce is used and a forbidden
+inducement later occurs, would mean that anyone who used the interstate highways, and
+then, at some other time, induced a minor face-to-face to engage in forbidden activity (or
+attempted to do so), would be subject to the mandatory ten years. The complete
+federalization of sex crimes involving children would have occurred, though there is no
+indication whatsoever that such a sea change in the federal/state balance was intended or
+is even needed.
+Moreover, such an expansive reading, even if permissible, would very likely
+exceed the Commerce Clause power as the Supreme Court presently construes it. In
+United States F
+,, 514 U.S. 549 (1995), the Supreme Court struck down the Gun-
+Free School Zones Act, holding that it exceeded Congress's Commerce Clause authority.
+In so ruling, the Court reaffirmed a set of fundamental principles, including that the
+powers delegated to the federal government are few and defined, and that this
+"constitutionally mandated division of authority was adopted by the Framers to ensure
+protection of our fundamental liberties." Id. at 552, quoting Gregory & Ashcroft, 501
+U.S. 452, 458 (1991). The
+majority concluded that the statute before the Court
+"upsets the federal balance to a degree that renders it an unconstitutional assertion of the
+commerce power." Id. at 580. In so ruling, the Court expressed its concern that an
+overly expansive view of the interstate Commerce Clause "would effectively obliterate
+the distinction between what is national and what is local and create a completely
+centralized government." Id. at 557.
+Making it clear that the Court meant what it said in
+United States . Morrison, 529 U.S. 598 (2000), the Court struck down the civil remedy
+provision of the Violence Against Women Act of 1994, ruling that it, too, was beyond
+Congress's Commerce Clause powers. Once again, the majority expressed concern that
+"Congress might use the Commerce Clause to completely obliterate the Constitution's
+MIA_CEOS_00085
+
+
+Matthew Menchel, Esq.
+Andrew Lourie, Esq.
+A. Marie Villafaña, Esq.
+The United States Attorney's Office
+Southern District of Florida
+Page 10
+To the extent that §2422(b) criminalizes the use of the internet (or telephone) by a
+sexual predator to target a vulnerable minor and to convince, or to try to convince, her to
+engage in conduct proscribed by law, the statute may not be unconstitutional on its face.
+See United States | Tykarsky, 446 F.3d 458, 470 (3d Cir. 2006) (both §§ 2422(b) and
+2423(b) "fall squarely within Congress's power to regulate the first two categories of
+activities described in
+"). The statute would, however, be plainly unconstitutional if
+it were applied to situations like Mr. Epstein's, where neither the telephone nor the
+internet was used in that fashion, and where the use of the telephone was, at most, a
+tenuous link in a chain of events that may, or may not, have preceded or followed sexual
+contact with a minor? In other words, if the instrumentality of commerce is not the
+vehicle used to facilitate the harm Congress is trying to address, but is simply a
+"jurisdictional hook," the hook is too weakly connected to the problem (sexual crimes
+against minors) to sustain the statute as a proper exercise of Commerce Clause power.
+Questions about the nature of federalism, and, specifically, just how far the
+federal government may go into matters of traditionally state concern, will continue to
+arise and will be answered case-by-case. As Justice O'Connor said in her dissent in
+Gonzales | Raich, 545 U.S. 1, 47 (2005), "... the task is to identify a mode of analysis
+that allows Congress to regulate more than nothing ... and less than everything..."
+(O'Connor, J. dissenting). United States . Ballinger, 395 F.3d 1218 (11" Cir. 2005),
+illustrates the difficulty of the task. In that case, the deeply split en banc Court
+considered whether and to what extent the Commerce Clause authority included the
+power to punish a church arsonist who had traveled in interstate commerce to commit his
+arsons.
+Though clearly not settled, what is clear is that Congress's specification of a
+jurisdictional element such as the use of an instrumentality or channel of interstate
+' As can be readily noted on the chart at Tab "B", to the extent discernable, every case brought
+under §2422(b) in this district includes use of the internet. There are only four reported cases in
+the Eleventh Circuit involving use of the phones only: three of them concern telephone calls to
+ravel agencies advertising overseas underage sex tours and involved explicit talk of sexua
+ctivity with known minors. A fourth is United States k Evans, 476 F.3d 1176 (11" Cir. 2007
+(11th Cir, 2007). But there, in facts far different from those presented here, the defendant
+"admitted using both a cellular telephone and a land-line telephone to entice Jane Doe to engage
+in prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution
+here, since there is no evidence the phones were used "to entice".
+MIA_CEOS_00086
+
+
+GERALD B. LEFCOUrT. PC.
+Matthew Menchel, Esq.
+Andrew Lourie, Esq.
+A. Marie Villafaña, Esq.
+The United States Attorney's Office
+Southern District of Florida
+July 6, 2007
+Page 11
+commerce does not, in and of itself, end the inquiry. Where the use of such
+instrumentality is far removed from the conduct being targeted (in the case of §2422(b),
+sexual exploitation of children), the lack of any basis for federal jurisdiction presents
+itself squarely.
+In Mr. Epstein's case, since the crime being considered (as Congress intended) is
+the use of the internet by internet predators to target and lure vulnerable children to
+engage in illicit sex, the law is arguably within Congress' Commerce Clause powers. But
+Mr. Epstein's conduct would be outside the law's scope. If you were to contend that any
+use of the telephone which is connected in any fashion to an act of sexual misconduct
+with a minor is within the statute's scope, Congress would then have reached well into
+traditional state spheres, and there is a powerful argument that Congress would have been
+acting in excess of its Commerce Clause authority.
+Elimination of Constitutional uncertainty regarding §2422(b) depends upon
+confining it to situations where an instrumentality of interstate commerce has itself been
+used for an immoral or injurious purpose. Statutes must be read to eliminate serious
+doubts as to Constitutionality, as long as such a reading is not plainly contrary to the
+intent of Congress. United States a X-Citement Video, Inc., 513 U.S. 64, 78 (1994),
+citing Edward J. DeBartolo Corp. | Florida Gulf Coast Building & Constr: Trades
+Council, 485 U.S. 568 (1988). At the least, to eliminate questions as to its
+constitutionality, §2422(b)'s reach must be limited to situations where there is a very
+close connection between the use of an instrumentality of interstate commerce and the
+persuasion or attempted persuasion that the statute makes a crime.
+is so attenuated that no such federal prosecution should be brought.
+rostitution or other illegal conduct.
+MIA_CEOS_00087
+
+
+GERALD B. LEFCOUrT, P.C.
+Matthew Menchel, Esq.
+Andrew Lourie, Esq.
+A. Marie Villafaña, Esq.
+The United States Attorney's Office
+Southern District of Florida
+July 6, 2007
+Page 12
+and knowledge and, critically, that the shared intent and knowledge existed at the time of
+sexual activity or to engage in prostitution, there can be no federal crime.
+If the telephone call in question were simply to schedule a topless massage, then
+the call lacked the essential element of inducement, persuasion, enticement, or coercion.
+If the telephone call in question was to schedule a topless massage (or even more) with a
+woman whose age was not known by Mr. Epstein to be under 18, it also fails to satisty
+the requirements of §2422(b). If Mr. Epstein had not formed the intent to engage in
+unlawful sexual activity as of the time of the communication (even if he did form the
+intent thereafter), an essential element of the federal statute is again lacking. If the
+person making the call had knowledge or a criminal intent or belief not fully shared by
+Mr. Epstein (for example, Mr. Epstein did not know the telephone call was intended to
+induce a minor to engage in unlawful activity), the essential element of shared intent and
+shared knowledge is again lacking." Finally, even if there were a call to schedule a
+second meeting with someone who had previously been to the Epstein residence, this call
+lacks the necessary element of persuasion, inducement, or enticing even if the person
+receiving the call hoped or expected remuneration from the return visit. That is so
+because the statute focuses on the content of the communication, not on any quid pro quo
+that occurs thereafter at a meeting. The latter conduct is exclusively within the ambit of
+state prosecution.
+5. Other Reasons Why § 2422(b) Does Not Apply
+As we demonstrate above, this statute is addressed to those who purposely and
+' Indeed, this last problem is best illustrated by any calls
+to solicit persons to massage Mr. Epstein. Though Ms.
+women at least 18 years of age. (Video Interview of
+MIA_CEOS_00088
+
+
+GERALD B. LEFCOURT, PC
+The United States Attorney's Office
+Southern District of Florida
+1299 (11" Cir. 2003) (scienter requirement discourages "unscrupulous enforcement" and
+clarifies §2422(b)). Directed towards those who commit "the most serious crimes against
+chil may i cam on properly be used as a trap for -homan ate innervise interacall
+improperly with persons who turn out to be minors.
+A prosecution of Mr. Epstein would violate the teachings of Bailey and Panfil. As
+we believe we persuaded you at the June 26 meeting, Mr. Epstein never targeted minors.
+On the contrary, what he did - at worst - was akin to putting up a sign saying to all, come
+in if you are interested in giving a massage for $200. A few among those who accepted
+the general invitation may have in fact been under 18 (though they lied about that age and
+said they were 18), but that is, at its worst, comparable to "posting) messages for all
+internet users, either adults or children, to seek out and read at their discretion," which the
+courts have held does not violate §2422(b).
+Thus, for this reason as well, Mr. Epstein's case is far outside the parameters of
+the §2422(b) cases that have been prosecuted. A key factor common to cases brought
+under §2422(b) is not present here: Prosecutions under this statute have focused on a
+sexual predator who used the internet to identify and to communicate with a child or
+purported child (or a person with influence over such child or purported child), and did so
+with the intent to arrange to engage in sexual activity with the child, with full knowledge
+that sexual activity with an individual of that age was illegal. In light of this common and
+well-accepted understanding, the cases decided under §2422(b) take as a given that its
+proper application lies only where the defendant knows or believes the person with whom
+he is interacting is a child.
+Virtually all of the prosecutions brought under §2422(b) resulting in published
+fact pans in involved undercover propertie and voting ase of maily tandard
+conversations on line an undercover agent pretends to be a young teenager. In each of the
+cases, the prosecution had, from the very words used by the defendant, an all but
+irrefutable case showing the clear knowledge and intent of the defendant. A prototypical
+case is United States . Farner, 251 F.3d 510 (5" Cir. 2001), where the defendant
+participated, over time, in instant messaging, e-mail, and follow-up telephone calls with a
+person who identified herself as 14 years old, engaged in explicit internet conversation,
+sent her pornographic pictures, persuaded her to meet with him for sexual activity,
+arranged such a meeting, and traveled to the meeting place. The Fifth Circuit held that
+MIA_CEOS_00089
+
+
+Matthew Menchel, Esc
+ndrew Lourie, Esc
+In the context of this standard fact pattern involving the internet's use by
+predators, other Circuits, including the Eleventh, have been unanimous in holding that the
+ion-existence of an actual minor was of no moment; defendant's belief that he was
+lealing with a minor was sufficient to make out the crime. See United States 1 Root, 29(
+F.3d 1222, 1227-32 (11" Cir. 2002); United States | Sims, 428 F.3d 945, 959 (10" Cir.
+2005); United States | Helder, 452 F.3d 751 (8"" Cir. 2006); United States 1 Meek, 366
+F.3d 705, 717-20 (9" Cir. 2004). Likewise, the Circuits have rejected void for vagueness,
+overbreadth, and First Amendment challenges to the statute, brought in the context of
+these prototypical prosecutions where the internet was the vehicle of communication and
+enticement, and the defendant demonstrated in writing his belief that he was dealing with
+a child well below the age of consent. E.g., United States | Tykarsky, 446 F.3d 458, 47:
+(3d Cir. 2006); United States | Thomas, 410 F.3d 1235, 1243-44 (10"" Cir. 2005); Unitea
+States | Panfil, supra, 338 F.3d at 1300-01 (11" Cir. 2003)."
+There are approximately two dozen Eleventh Circuit cases that include a prosecution under
+92422(b), most of which involve the prototypical fact pattern. See, e.g., United States | Morton
+364 F.3d 1300 (11" Cir. 2004), judgment vacated for Booker consideration, 125 S. Ct. 1338
+(2006); United States | Orrega, 363 F.3d 1093 (11" Cir. 2004); United States l Miranda, 348
+Appx. 647 (11" Cir. 2005); United States | Rool, 296 F.3d 1222 (11" Cir. 2002).
+United States | Murrell, 368 F.3d 1283 (11" Cir. 2004), is in the same mold, except that, in that
+sting operation, the defendant communicated, not with the purported 13 year old girl, but with an
+undercover agent holding himself out to be the imaginary girl's father. The initial contacts
+between Murrell and the agent occurred in internet chatrooms named "family love" and "Rent F
+Vry Yng." Over time, Murrell sought to make arrangements with the girl's father to make his
+daughter available for sex in exchange for money. After the initial internet communications
+concerning renting the girl for sexual purposes, further negotiations between the defendant and
+the undercover occurred via the phone, per the defendant's suggestion. The Eleventh Circuit,
+framing the issue to be whether the defendant must communicate directly with the minor or
+supposed minor to violate §2422(b), answered the question in the negative, reasoning that "the
+MIA_CEOS_00090
+
+
+Matthew Menchel, Esq.
+Andrew Lourie, Esq.
+A. Marie Villafaña, Esq.
+The United States Attorney's Office
+Southern District of Florida
+Page 15
+In light of this common and well-accepted understanding, the cases decided under
+§2422(b) take as a given that its proper application lies only where the facts demonstrate
+beyond dispute that the defendant knows or believes the person with whom he is
+interacting is a minor.
+The Ninth Circuit has so held. United States | Meek, 366 F.3d 705, 718 (9" Cir.
+2004), held that the term "knowingly" refers both to the verbs - "persuades", "induces",
+Staples | United States, 511 U.S. 606 (1994). The Meek Court wrote:
+he statute requires mens rea, that 1s
+intends to do. In this case, knowledge is subjective - it is
+what is in the mind of the defendant.
+The very lengthy sentence under §2422(b) speaks against strict liability,
+especially since it applies in cases where there is no sexual contact at all with any
+person, let alone with a real minor. The Eleventh Circuit's decision in United States
+that, eld supra, relicts thia o andio of the state Th the green must
+that, under the *
+efficacy of §2422(b) would be eviscerated if a defendant could circumvent the statute simply b
+mploying an intermediary to carry out his intended objective. Id. at 1287. Fact patterns simila
+to Murrell's exist in United States | Hornaday, 392 F.3d 1306 (11 Cir. 2004); United States F
+Houston, 177 Fed. Appx. 57 (11" Cir. 2006); United States • Searcy, 418 F.3d 1193 (11"" Cir
+2005); United States k Scott, 426 F. 3d 1324 (11" Cir. 2005); and United States k. Bolen, 136 Fed.
+Appx. 325 (11" Cir. 2002).
+1? Several Courts of Appeal have held that, in a prosecution under §2422(a), the defendant need
+not know that the individual that a defendant has persuaded, induced, enticed, or coerced to
+travel in interstate commerce is under the age of 18. United States e Jones, 471 F.3d 535 (4"
+Cir. 2006), is one of these cases, though its facts are very different, and much more egregious
+han Mr. Epstein's. Assuming Jones was correctly decided and that the government need no
+prove defendant's knowledge under §2422(a), that still does not answer the question under
+§2422(b). The two are very different statutes, with different histories and different purposes.
+And §2422(a), unlike subsection (b), carries no mandatory minimum sentence, let alone ten years.
+MIA_CEOS_00091
+
+
+GERALD B. LeFcourt, PC
+Matthew Menchel, Esq.
+Andrew Lourie, Esq.
+A. Marie Villafaña, Esq.
+The United States Attorney's Office
+Southern District of Florida
+July 6, 2007
+first prove that Murrell, using the internet, acted with a specific intent to persuade a
+("Root's statement to task force agents upon his arrest confirmed that he believed he
+would meet a 13-year-old girl for sex, which he said he knew was wrong but 'exciting"").
+See also United States y: Rojas, 145 Fed. Appx. 647 (11" Cir. 2005) (unpublished). This
+mens rea requirement applies equally where the completed crime occurs.!4
+Finally, actus non facit reum, nisi mens sit rea - the act alone does not amount to
+guilt; it must be accompanied by a guilty mind. This principle of concurrence mandates
+that the actus reus and the mens reus concur in time. See Paul H. Robinson, Criminal
+Law §4.1 at 217 (1997) (concurrence requirement "means that the required culpability as
+to the element must exist at the time of the conduct constituting the offense"); LaFave,
+Substantive Criminal Law §3.11(a) (West 1986) (noting that Concurrence is a basic
+rinciple of criminal law and "the better view is that there is concurrence when th
+lefendant's mental state actuates the physical conduct"). See also United States I: Baile
+supra, 444 U.S. at 402. In this case, the requisite actus reus is absent; likewise the
+required mental state. Even if those two fatal defects could be set aside, nevertheless,
+there was no concurrence of guilty mind and evil act, providing an additional reason why
+a successful prosecution under §2422(b) could not be brought.
+6. Conclusion
+In Mr. Epstein's case, there was no use of the internet to induce, etc., and, given
+the legislative history and purpose, that is itself dispositive. Nor does the case present
+any of the dangers associated with internet predators and cyberspace. Not surprisingly
+• Otherwise, the police could, for example, conduct a sting operation with a 17 year-old
+retending to be an 18 year-old. Such an absurd operation is surely not intended by the statute
+'Even the completed crime does not require any sexual activity. Arguably, one commits the
+attempt offense when the actor, on the internet, asks a known or believed-to-be minor to have sex,
+even if she says no. The completed offense occurs when he takes an additional step, even befor
+any sexual activity and regardless of whether one ever takes place.
+MIA_CEOS_00092
+
+
+Matthew Menchel, Esq.
+Andrew Lourie, Esq.
+A. Marie Villafaña, Esq.
+The United States Attorney's Office
+Southern District of Florida
+July 6, 2007
+then, the statutory language does not fit: Mr. Epstein did not use any facility of interstate
+commerce to do the forbidden act - to persuade, entice, induce, or coerce - nor did he
+appointments, personal training, physical therapy and massages. Even if Mr. Epstein
+could be held responsible for the use of the telephone on his behalf, nevertheless, calls
+made by others regarding massages were not the statutorily proscribed persuasions or
+enticements of a known minor to do acts known to be illegal. Within his home, even if
+Mr. Epstein may arguably have persuaded or induced individuals to engage in forbidden
+conduct with him, he did not violate §2422(b). If he engaged in such persuasion or
+inducement, it occurred only face to face and spontaneously.
+If such conduct constituted a crime, it would be a classic state offense. The state
+is the appropriate forum for addressing these issues. Though in our meeting it was
+asserted that cases under §2422(b) are often brought where there was simply use of a
+telephone, and casual use at that, it would not from our survey appear to be so on either
+count - that is, use of a telephone rather than the internet, and use of the means of
+communication remote from the enticing, etc. This is neither the defendant, nor the
+factual context, to break new ground
+II. Mr. Epstein Warrants Declination to Prosecute as Exercise of Discretion.
+We believe strongly that no federal case would lie under the facts here. Moreover,
+as we discussed, there is a pending state case against Mr. Epstein which can be resolved
+in a way that vindicates the state's rights and obligations in this matter.
+In considering an appropriate disposition in a case such as this, where the
+and both the reliability and somsblity of much at the evidence i our sins,
+to consider how best to use the broad discretion you enjoy in choosing whether to
+prosecute. In this regard, we suggest that having a greater understanding of who Jeffrey
+Epstein is as a person may help inform how best to proceed.
+Jeffrey Epstein was raised in a middle class neighborhood in Brooklyn, New
+York, by hardworking parents. His father was a laborer and his mother a secretary. They
+word ethic in lin, bud growing up he ans a variety of Epstei supertimi, do strong
+work ethic in him,
+MIA_CEOS_00093
+
+
+Matthew Menchel, Esq
+Andrew Lourie, Esq.
+A. Marie Villafaña, Esq.
+The United States Attorney's Office
+Southern District of Florida
+July 6, 2007
+driving a taxi cab to working as a mechanic. Any notion that he was born with a "silver
+spoon in his mouth" should be dismissed.
+Although Mr. Epstein is self-made and worked long and hard, he could not have
+achieved his successes without the personal guidance and support of others. These key
+people first identified the promise in Mr. Epstein and brought him to Bear Stearns and
+Company, Inc. There, starting in 1976 at the age of 23 as a floor trader's junior assistant,
+he became in 1980 a limited partner. Among the very many benefits that his experience
+there provided was an introduction to the people who ultimately became his clients.
+Early in his professional career, Mr. Epstein realized the profound impact that
+even one person can have on the life of another. His gratitude for the assistance he
+personally received, and his sense of obligation to provide similar assistance and
+guidance to others, is in large part, the motive for the primacy of philanthropy in his life
+or his particular philanthropic interests. Mr. Epstein has devoted a substantial portion of
+his time, efforts and financial resources to helping others, both on an individual basis and
+on a more far reaching scope. Mr. Epstein gives generously, of both his time and his
+financial resources equally to individuals whom he knows personally and well and to
+those with whom he has had little or no personal contact. Just a few examples:
+Some time ago, the two year old son of an employee was diagnosed with retinal
+blastoma. When told, Mr. Epstein not only gave the employee unlimited time off to
+attend to his son and promised whatever financial support was needed, but Mr. Epstein
+made the full list of his medical and research contacts available. The employee was put
+in contact with a former colleague who was then conducting eye research at Washington
+University. Mr. Epstein organized several meetings to determine how the colleague could
+be of assistance, includin by arrang son for unhey me is swian opervis Washington
+University. Though the employee's son lost one eye,
+twelve year old who attends private school along with his five siblings, the expenses of
+MIA_CEOS_00094
+
+
+OKRALD B. LEFCOURT, P.C.
+Matthew Menchel, Esq.
+Andrew Lourie, Esq.
+A. Marie Villafaña, Esq.
+The United States Attorney's Office
+Southern District of Florida
+was acquainted and assigned personnel to assist the employee with administrative and
+secretarial needs that arose in seeking a solution to the problem. Mr. Epstein is now the
+godfather of the employee's seven-year old twins.
+Recently, both a second employee and a consultant of Mr. Epstein each confided
+that they and their respective spouses were experiencing similar fertility problems.
+Again, Mr. Epstein offered to pay the uncovered medical costs. The consultant and his
+wife are now expecting their first child. The second employee continues with infertility
+treatments.
+Two years ago, a building workman approached Mr. Epstein with news that the
+workman's wife needed a kidney transplant and that the workman's sister-in-law in
+Colombia was a willing donor. The non English speaking workman had neither the
+financial resources nor the know-how to get the sister-in-law to the United States. Mr.
+Epstein arranged for immigration counsel to expedite a visa for the sister-in-law and
+purchased the plane tickets for the sister-in-law's visit to the United States. The surgery
+was a success and both patients recovered completely. The sister-in-law flew back to
+Colombia at Mr. Epstein's expense.
+Mr. Epstein is a devoted advocate of personal improvement through education.
+As a former board member of Rockefeller University, Mr. Epstein has made available
+academic scholarships to worthy students, most of whom he has had no prior connection
+to whatsoever. In addition, Mr. Epstein covers the tuition required to send the family
+members of his employees to nursery, private elementary, middle and secondary schools
+and colleges. He has funded and personally encouraged continuing education programs
+for his adult employees and professional consultants.
+Among his other acts:
+• On a trip to Rwanda to inspect the genocide camps, Mr. Epstein
+their second year of studies, both are expected to graduate with honors
+from the City University of New York in 2008. Notes from each of them
+are annexed at Tab "C".
+MIA_CEOS_00095
+
+
+GERALD B. LeFcoUrT, PC.
+Andrew Lourie, Esq.
+A. Marie Villafaña, Esq.
+he United States Attorney's Offic
+outhern District of Florid
+Page 20
+monthly with a teenage building workman whose expenses of vocational
+school are being paid by Mr. Epstein. Each month, Mr. Epstein reviews
+he workman's school progress and discusses career opportunities. One of
+he monthly reports is annexed at Tab "D"
+• In addition, Mr. Epstein blocks out time each week to meet with young
+professionals to discuss their career prospects and counsel them regarding
+appropriate next steps.
+Although Mr. Epstein is deeply committed to helping others in very personal and
+meaningful ways, he has also sought to use his good fortune to help others on a broader
+basis. Mr. Epstein has sponsored more than 70 athlete wellness programs, building
+projects, scholarship funds and community interest programs in the United States Virgin
+Islands alone.
+Moreover, Mr. Epstein has given generously to support philanthropic
+organizations across the United States and around the world, including America's
+Agenda; Robin Hood; Alliance for Lupus Research; Ovarian Cancer Research Fund;
+Friends of Israel Defense Forces; Seeds of Peace; the Jewish National Fund; the Hillel
+Foundation; the National Council of Jewish Women; and the Intrepid Fallen Heroes Func
+- to name only a few.
+In a feature article about Mr. Epstein in New York Magazine, former President
+Clinton aptly described Mr. Epstein as "a committed philanthropist with a keen sense of
+global markets and an in-depth knowledge of twenty-first-century science." President
+Clinton reached this conclusion during a month-long trip to Africa with Mr. Epstein,
+which Mr. Epstein hosted. The purpose of that trip was to increase AIDS awareness; to
+work towards a solution to the AIDS crisis; and to provide funding to reduce the costs of
+delivering medications to those inflicted with the disease.
+MIA_CEOS_00096
+
+
+Matthew Menchel, Esq.
+Andrew Lourie, Esq.
+A. Marie Villafaña, Esq.
+The United States Attorney's Office
+Southern District of Florida
+Mr. Epstein was part of the original group that conceived the Clinton Global
+health, and religious and ethnic conflicts.
+Mr. Epstein has sought to improve people's lives through active participation in
+worthy scientific and academic research projects, as well. He spent hundreds of hours
+researching the world's best scientists, and he himself studied as a Harvard Fellow in
+order to increase his own knowledge in fields that he believed could provide solutions to
+the world's most difficult problems. He is committed to helping the right researchers find
+those solutions, especially in the fields of medical science, human behavior and the
+environment.
+In the past four years alone, Mr. Epstein has made grants to research programs at
+major institutions under the supervision of some of the most highly regarded research
+professionals and scholars in their fields, including Martin Nowak, a mathematical
+biologist who studies, among other things, the dynamics of infectious diseases and cancer
+genetics; Martin Seligman, known for his work on Positive Psychology - that is to say
+the psychology of personal fulfillment; Roger Schank, a leading researcher in the
+application of cognitive learning theory to the curricula of formal education; the renown
+physicist/cosmologist
+Krauss, and many others. Institutions funded include
+Harvard University; Penn State University; Lenox Hill Hospital (New York); the
+Biomedical Research and Education Foundation; the Santa Fe Institute; Massachusetts
+Institute of Technology; Case Western Reserve University; and Harvard Medical School's
+Institute for Music and Brain Science.
+Moreover, Mr. Epstein has sponsored and chaired symposia that have provided a
+raro intric for the into These reschs tars and research proposan and oshare ideas
+topics, including the origin of life, systems for understanding human behavior, and
+personal genomics.
+In order to expand the pool of qualified research professionals actively engaged in
+addressing the world's numerous problems, Mr. Epstein co-founded, and served as a
+rustee and actively participated in the selection committee of, the Scholar Rescue Fund
+The Scholar Rescue Fund (SRF) is a program of the Institute of International Education,
+the group that, inter alia, administers the Fulbright Scholarship program. The SRF
+provides support and safe haven to scholars at risk from around the world. Over the past
+MIA_CEOS_00097
+
+
+OERALD B. LEFCOURT. PC.
+Matthew Menchel, Esq.
+Andrew Lourie, Esq.
+A. Marie Villafañia, Esq.
+The United States Attorney's Offic
+outhern District of Florida
+July 6, 2007
+Page 22
+five years, SRF has made 155 grants to scholars from more than 37 countries. Scholars
+since the conflict there began. Mr. Epstein is a highly valued member of the selection
+committee. Just a few articles mentioning these and other projects are annexed at Tab
+"E".
+Even a casual review of the good works large and small in which he has involved
+himself leads one to conclude that he has a powerful instinct to help others. He does this
+not simply because he can, but because he has a deeply ingrained desire to do so. In fact,
+he believes that, as a result of his good fortune, he is obligated to do so.
+Since 2000, Mr. Epstein has funded educational assistance, science and research
+and community and civic activities. As you can see, his philanthropy is not limited to
+financial support. To the contrary, it has involved the dedication of a remarkable amount
+of his time and effort and has yielded admirable results. It is noteworthy that a majority
+of the people he has helped over the years have been those with whom he has had little or
+no contact, which further confirms that he derives no personal benefit from his good
+works, other than the personal satisfaction derived from using his good fortune to help
+others.
+The sincere devotion to others evidenced by Mr. Epstein's philanthropic activities
+is no less apparent in his interpersonal relationships. Mr. Epstein has maintained both
+long term significant, intimate as well as professional relationships. He remains close
+personal friends with people with whom he went to high school and, to this day,
+maintains close business contacts with his former colleagues at Bear Stearns. Those who
+know Mr. Epstein well describe him admittedly as quirky but certainly not immoral; and
+despite the lui endios and on during tied Wory have restigated staunch supporers
+Mr. Epstein acknowledges that the activities under investigation, as well as the
+outstanding charges in the state would put an appropriate end to the matter for everyone.
+MIA_CEOS_00098
+
+
+GERALD B. LeFcourT. PC.
+Matthew Menchel, Esq.
+Andrew Lourie, Esq.
+A. Marie Villafaña, Esq.
+She tri district lord's office
+Again, we and our colleagues thank you for your attention at the June 26 meeting.
+I welcome any questions or comments you may have and am available to discuss this and
+any other issues at your earliest convenience.
+Very truly yours,
+Guild B. Liferent
+Gerald B. Lefcourt
+Alan Deshow, th
+Alan Dershowitz
+cc: Lilly Ann Sanchez, Esq.
+Roy Black, Esq.
+MIA_CEOS_00099
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/a961f7ff35ed36b22ad94bb959c6ad8de4d9b0924e69c4aeb3e2a7a78bdec67e.receipt.json b/vision-fixhub/ds9-unparsed-05/a961f7ff35ed36b22ad94bb959c6ad8de4d9b0924e69c4aeb3e2a7a78bdec67e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b73c4927bb36b8365400b559cb64a2c1cfe224ad
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a961f7ff35ed36b22ad94bb959c6ad8de4d9b0924e69c4aeb3e2a7a78bdec67e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -2367,
+  "dataset": "marble-joined",
+  "doc_id": "a961f7ff35ed36b22ad94bb959c6ad8de4d9b0924e69c4aeb3e2a7a78bdec67e",
+  "engine": "marble-apple-vision",
+  "event_count": 79,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "8c9eccd0afe3aff015a8a426fbf3d1250669f9750055b755b754d8f97fa13869",
+  "output_sha256": "2fff8d10b18b247bc8dcd73bad09b725e6310a6662637c7e05b3b8d53413dc31",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a9e004e0a4cdc891816a1ea84a130bc4f46f5cf23286f8bdcaaff4bc35876979.md b/vision-fixhub/ds9-unparsed-05/a9e004e0a4cdc891816a1ea84a130bc4f46f5cf23286f8bdcaaff4bc35876979.md
new file mode 100644
index 0000000000000000000000000000000000000000..e4f482105fff7525eb5c0ad895ff39975da0c06d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a9e004e0a4cdc891816a1ea84a130bc4f46f5cf23286f8bdcaaff4bc35876979.md
@@ -0,0 +1,2148 @@
+
+LRJ
+U.S. Distriet Court
+Southern District of Florida (West Palm Beach)
+CIVIL DOCKET FOR CASE #: 9:08-cv-80381-KAM
+Doe No. 5 _. Epstein
+Assigned to: Judge Kenneth A. Marra
+Lead case: 9:08-cv-80119-KAM
+Member case: (View Member Case)
+Case: 2:09-cv-80802-KAM
+Cause: 28:1332 Diversity
+Plaintiff
+Jane Doe No. 5
+Date Filed: 04/14/2008
+Jury Demand: Plaintiff
+Nature of Suit: 360 P.I.: Other
+Jurisdiction: Diversity
+represented by Adam D. Horowitz
+Mermelstein & Horowitz PA
+18205 Biscayne Boulevard
+Fax:
+Email:
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Jeffrey Mare Herman
+Miami , FL 33160
+Fax:[
+Email:
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Stuart S. Mermelstein
+Mermelstein & Horowitz PA
+18205 Biscayne Boulevard
+Suite 2218
+Miami. FL 33160
+Fax: 931-0877
+Email: 1
+LEAD ATTORNEY
+https://ecf.flsd.uscourts.gov/egi-bin/DktRpt.pl2302073795169544-L_801_0-1
+
+
+
+ATTORNEY TO BE NOTICED
+Defendant
+Jeffrey Epstein
+represented by Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+Email: ]
+ATTORNEY TO BE NOTICED
+Michael James Pike
+Burman Critton Luttier & Coleman
+515 N Flagler Drive
+Suite 400
+West Palm Beach, FL 33401-2918
+Email:
+ATTORNEY TO BE NOTICED
+Michael Ross Tein
+Lewis Tein
+3059 Grand Avenue
+Suite 340
+Coconut Grove , FL 33133
+Email:
+ATTORNEY TO BE NOTICED
+Robert Deweese Critton, Jr.
+Burman Critton Luttier & Coleman
+515 N Flagler Drive
+Suite 400
+West Palm Beach, FL 33401-2918
+Fax:
+Email:
+ATTORNEY TO BE NOTICED
+Amicus
+United States of America
+represented by
+United States Attorney's Office
+500 East Broward Blvd
+7th Floor
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl7302073795169544-L_801_0-1
+
+
+CM/ECF - Live Database - fsd
+
+Et Lauderdale, FL 33394
+, ext. 3546
+Fax:E
+Email:
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Date Filed
+04/14/2008
+04/14/2008
+04/17/2008
+05/22/2008
+05/29/2008
+06/02/2008
+06/05/2008
+06/13/2008
+06/13/2008
+06/19/2008
+06/20/2008
+06/20/2008
+#
+Docket Text
+1
+COMPLAINT against Jeffrey Epstein Filing fee $ 350. Receipt#: 542770,
+filed by Jane Doe No. 5.(dj) (Entered: 04/15/2008)
+2
+Summons Issued as to Jeffrey Epstein. (di) (Entered: 04/15/2008)
+Order Requiring Counsel to Confer and File Joint Scheduling Report.Signed
+by Judge Kenneth A. Marra on 4/16/08.(ir) (Entered: 04/17/2008)
+4
+AFFIDAVIT of Service for Summons and Complaint served on Jeffrey
+Epstein on May 7, 2008, filed by Jane Doe No. S. (Herman, Jeffrey) (Entered:
+05/22/2008)
+5 | Plaintiff's MOTION for Entry of Default by Clerk Against Defendant by Jane
+Doe No. 5. (Attachments: # 1 Exhibit A and B, # 2 Text of Proposed Orde
+Default Order)(Horowitz, Adam) (Entered: 05/29/2008
+Clerks Entry of Default as to Jeffrey Epstein terminated 5 Motion for Entry of
+Default by Clerk (ail) (Entered: 06/02/2008)
+1 | Plaintiff's MOTION for Judgment Upon Default and Order Setting Hearing
+on Damages by Jane Doe No. 5. (Attachments: # 1 Text of Proposed Order)
+(Horowitz, Adam) (Entered: 06/05/2008)
+8
+NOTICE of Attorney Appearance by Jack Alan Goldberger on behalf of
+Jeffrey Epstein (Goldberger, Jack) (Entered: 06/13/2008)
+MOTION to Set Aside Clerk's Default by Jeffrey Epstein. (Attachments: # 1
+Affidavit of Richard Barnett)(Goldberger, Jack) (Entered: 06/13/2008)
+10 | RESPONSE in Opposition re 7 Plaintiff's MOTION for Judgment Upon
+Default and Order Setting Hearing on Damages (DE #7) filed by Jeffiey
+Epstein. (Goldberger, Jack) (Entered: 06/19/2008)
+| | Defendant's MOTION to Stay by Jeffrey Epstein. Responses due by 7/10/200
+Goldberger, Jack) (Entered: 06/20/2003
+12 | Defendant's MOTION for Extension of Time to File Answer or Otherwise
+Respond To Complaint by Jeffrey Epstein. (Goldberger, Jack) (Entered:
+06/20/2008)
+06/25/2008
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?302073795169544-L_801_0-1
+
+
+
+| 06/25/2008
+07/01/2008
+07/07/2008
+07/07/2008
+07/08/2008
+07/08/2008
+07/08/2008
+07/08/2008
+07/10/2008
+07/10/2008
+07/10/2008
+07/10/2008
+07/10/2008
+07/16/2008
+14 | RESPONSE to Motion re 2 MOTION to Set Aside Clerk's Default filed by
+Jane Doe No. 5. Replies due by 7/7/2008. (Herman, Jeffrey) (Entered:
+06/25/2008)
+NOTICE by Jeffrey Epstein Concerning Motion To Stay [DE 11]
+(Attachments: # 1 Exhibit "A" Final Disposition Sheets) (Goldberger, Jack)
+(Entered: 07/01/2008)
+16
+NOTICE of Attorney Appearance by Michael Ross Tein on behalf of Jeffrey
+Epstein (Tein, Michael) (Entered: 07/07/2008)
+17
+MOTION Epstein's Reply in Support of Motion [DE9] to Set Asside Clerk's
+Default by Jeffrey Epstein, (Tein, Michael) (Entered: 07/07/2008)
+18
+RESPONSE in Support re 2 MOTION to Set Aside Clerk's Default filed by
+leffrey Epstein. (Goldberger, Jack) (Entered: 07/08/2008)
+12 | NOTICE by Jeffrey Epstein re 18 Response in Support of Motion [DE 9] To
+Set Aside Člerk's Default (Goldberger, Jack) (Entered: 07/08/2008)
+NOTICE of Instruction to Filer: re 17 MOTION Epstein's Reply in Support of
+Motion [DE9] to Set Asside Clerk's Default filed by Jeffrey Epstein Error:
+Wrong Event Selected; Instruction to Filer: Counsel is instructed to re-file
+document using the correct event REPLY TO RESPONSE TO MOTION; In
+the future please select the proper event. (dg) (Entered: 07/08/2008)
+21 | REPLY to Response to Motion re 17 MOTION Epstein's Reply in Support of
+Motion [DE9] to Set Asside Clerk's Default, 2 MOTION to Set Aside Clerk's
+Default Epstein's Reply in Support of Motion [DE9] to Set Aside Clerk'
+Default filed by Jeffrey Epstein. (Tein, Michael) (Entered: 07/08/2008
+22 | Plaintiff's MOTION for Extension of Time to File Response as to Il
+Defendant's MOTION to Stay by Jane Doe No. S. (Attachments: # 1 Text of
+Proposed Order)(Horowitz, Adam) (Entered: 07/10/2008)
+23
+Sealed Document. (yc) UNSEALED see DE 27 Modified on 7/17/2008 (tb).
+(Entered: 07/10/2008)
+24
+Sealed Document. (yc)UNSEALED see DE 28 . Modified on 7/17/2008 (tb).
+(Entered: 07/10/2008)
+27 | UNSEALED MOTION to seal by Jeffrey Epstein. (previously filed as 23
+sealed document) (tb) (Entered: 07/17/2008)
+UNSEALED Notice of Continued Pendency of Federal Criminal Action by
+Jeffrey Epstein (previously filed as 24 sealed document) (tb) (Entered:
+07/17/2008)
+25 | ORDER denying motion to file Ex Parte and Under Seal. The Clerk shall
+unseal DE 23 and 24 and make them available for public inspection through
+CM/ECF at the earliest possible time. Signed by Judge Kenneth A. Marra on
+7/16/08. (ir) (Additional attachments) added on 7/17/2008: # 1 docket sheet)
+07/16/2008
+26 OPINION AND ORDER denying without prejudice 2 Motion to Set Aside
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|2302073795169544-L_801_0-1
+
+
+
+07/18/2008
+07/21/2008
+07/25/2008
+07/25/2008
+07/28/2008
+07/28/2008
+07/28/2008
+07/28/2008
+07/29/2008
+07/30/2008
+08/05/2008
+| Default. The Defendant has ten days to file a second motion to vacate the
+default. Signed by Judge Kenneth A. Marra on 7/16/08. (ir) (Entered:
+07/16/2008)
+22
+RESPONSE to Motion re 11 Defendant's MOTION to Stay and Memorandum
+of Law filed by Jane Doe No. 5. Replies due by 7/28/2008. (Attachments: # 1
+Exhibit A)(Herman, Jeffrey) (Entered: 07/18/2008)
+30
+AFFIDAVIT signed by : Jeffrey M. Herman. Regarding Service of Process
+(Intered 07121 Oder to Show Cause by Jane Doc No. S. (Herman, Jefficy)
+31
+MOTION for Hearing Defendant's Request for Oral Argument by Jeffrey
+Epstein. (Tein, Michael) (Entered: 07/25/2008)
+32
+ORDER vacating 26 Order on Motion to Set Aside, vacating 6 Clerks Entry of
+Default filed by Jeffrey Epstein, granting 9 MOTION to Set Aside Clerk's
+Default filed by Jeffrey Epstein. Signed by Judge Kenneth A. Marra on
+33
+UNSEALED Sealed Document. (tas) Modified on 8/12/2008 **Please see DE
+# 41 for Image** (gp). (Entered: 07/28/2008)
+34
+UNSEALED Sealed Document. (tas) Modified on 8/12/2008 **Please see DE
+# 42 for Image** (gP). (Entered: 07/28/2008)
+41 | UNSEALED MOTION for Leave to File by Jeffrey Epstein. {Originally DE #
+33} (gp) (Entered: 08/12/2008)
+42
+UNSEALED REPLY to Response to Motion re 11 Defendant's MOTION to
+Stay filed by Jeffrey Epstein. (Originally DE # 34) (gp) (Entered:
+08/12/2008)
+35 | NOTICE by Jeffrey Epstein Defendant's Notice of Filing Exhibits
+(Attachments: # 1 Exhibit A, # 2 Exhibit B)(Tein, Michael) (Entered:
+07/29/2008)
+36 | NOTICE by Jeffrey Epstein Waiver of Service (Tein, Michael) (Entered:
+07/30/2008)
+37
+ORDER DENYING MOTION TO SEAL. The Clerk shall unseal DE 33
+Sealed Document, 34 Sealed Document and make them available for publi
+inspection through CM/ECF. Signed by Judge Kenneth A. Marra on 8/4/08.
+08/05/2008
+08/06/2008
+08/07/2008
+39
+Joint MOTION to Approve Stipulation for Acceptance of Service of Process
+and Agreed Date for Defendant's Responses to Complaints by Jane Doe No. 5.
+# 2 Text of Proposed Order Approvin
+40 ENDORSED ORDER granting 39 Motion to Approve Stipulation for
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl7302073795169544-L_801_0-1
+
+
+
+08/07/2008
+08/27/2008
+08/28/2008
+08/28/2008
+09/04/2008
+09/22/2008
+09/22/2008
+09/23/2008
+09/23/2008
+09/25/2008
+09/30/2008
+10/06/2008
+10/24/2008
+Acceptance of Service of Process and Agreed Date for Defendant's Responses
+to Complaints. Signed by Judge Kenneth A. Marra on 8/6/08. (ir) (Entered:
+08/07/2008)
+Reset Answer Due Deadline: Jeffrey Epstein response due 9/4/2008. (ir)
+(Entered: 08/07/2008)
+43
+NOTICE by Jeffrey Epstein Notice of Appearance (Pike, Michael) (Entered:
+08/27/2008)
+Clerks Notice of Docket Correction and Instruction to Filer re 43 Notice
+(Other) filed by Jeffrey Epstein. Error - Wrong Event Selected; Correction -
+Redocketed by Clerk as NOTICE of Attorney Appearance. Instruction to Filer
+- In the future, please select the proper event. It is not necessary to refile this
+document. (ail) (Entered: 08/28/2008)
+44 | NOTICE of Attorney Appearance by Michael James Pike, Robert Deweese
+Critton, Jr on behalf of Jeffrey Epstein (ail) (Entered: 08/28/2008)
+45
+Defendant's MOTION to Dismiss 1 Complaint by Jeffrey Epstein. Responses
+due by 9/22/2008 (Tein, Michael) (Entered: 09/04/2008)
+46
+MEMORANDUM in Opposition re 45 Defendant's MOTION to Dismiss 1
+Complaint filed by Jane Doe No. 5. (Herman, Jeffrey) (Entered: 09/22/2008)
+47
+AMENDED COMPLAINT, filed by Jane Doe No. 5.(Herman, Jeffrey)
+(Entered: 09/22/2008)
+48
+ENDORSED ORDER denying as moot 2 Motion for Judgment upon Default.
+Clerk's entry of default vacated on 7/25/08. See DE 32 . Signed by Judge
+Kenneth A. Marra on 9/23/08. (ir) (Entered: 09/23/2008)
+49
+| ORDER denying as moot 45 Motion to Dismiss; denying as moot 12 Motion
+for Extension of Time to Respond to Complaint. Signed by Judge Kenneth A.
+Marra on 9/23/08. (ir) (Entered: 09/23/2008)
+50
+SCHEDULING REPORT- Rule 26(1). (Herman, Jeffrey) (Entered:
+09/25/2008)
+51 | SCHEDULING ORDER: Jury Trial set for 1/25/2010 09:00 AM in West
+Palm Beach Division before Judge Kenneth A. Marra. Calendar Call set for
+1/22/2010 10:00 AM in West Palm Beach Division before Judge Kenneth A.
+Marra., Amended Pleadings due by 12/1/2008. Discovery due by 8/3/2009.
+Motions due by 8/31/2009. ORDER REFERRING CASE to Magistrate Judge
+Linnea R. Johnson for Discovery Proceedings, ORDER REFERRING CASE
+o Mediation. 15 days to appoint mediator. Signed by Judge Kenneth A. Marra
+on 9/29/08. (ir) (Entered: 09/30/2008)
+52
+Defendant's MOTION to Dismiss 47 Amended Complaint and for More
+Definite Statement by Jeffrey Epstein. Responses due by 10/24/2008 (Critton,
+Robert) (Entered: 10/06/2008)
+53
+Unopposed MOTION for Extension of Time to File Response as to 52
+Defendant's MOTION to Dismiss 47 Amended Complaint and for More
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|7302073795169544-L_801_0-1
+
+
+
+10/27/2008
+54
+Definite Statement by Jane Doe No. 5. (Attachments: # 1 Text of Proposed
+Order)(Herman, Jeffrey) (Entered: 10/24/2008)
+ORDER granting (47 in 9:08-cv-80119-KAM) Unopposed MOTION for
+Extension of Time to File Response as to (46) Defendant's MOTION to
+Dismiss (42) Amended Complaint and for More Definite Statement
+(Responses due by 10/31/2008) in case 9:08-cv-80119-KAM; granting (43)
+Motion for Extension of Time to Respond re (47 in 9:08-cv-80119-KAM)
+Unopposed MOTION for Extension of Time to File Response as to (46)
+Defendant's MOTION to Dismiss (42) Amended Complaint and for More
+Definite Statement in case 9:08-cv-80232-KAM; granting (55) Motion for
+Extension of Time to Respond re (47 in 9:08-cv-80119-KAM) Unopposed
+MOTION for Extension of Time to File Response as to (46) Defendant's
+MOTION to Dismiss (42) Amended Complaint and for More Definite
+Statement in case 9:08-cv-80380-KAM; granting (53) Motion for Extension of
+Time to Respond re (47 in 9:08-cv-80119-KAM) Unopposed MOTION for
+Extension of Time to File Response as to (46) Defendant's MOTION to
+10/28/2008
+10/31/2008
+11/10/2008
+12/30/2008
+02/12/2009
+02/23/2009
+02/27/2009
+03/02/2009
+03/04/2009
+Reset Deadlines as to Defendant's MOTION to Dismiss (49) Amended
+Complaint and for More Definite Statement. Responses due by 10/31/2008.
+(ir) (Entered: 10/28/2008)
+55
+MEMORANDUM in Opposition re 52 Defendant's MOTION to Dismiss 47
+Amended Complaint and for More Definite Statement filed by Jane Doe No.
+5. (Attachments: # 1 Exhibit A)(Herman, Jeffrey) (Entered: 10/31/2008)
+RESPONSE/REPLY to 55 Memorandum in Opposition to Defendant's Motion
+to Dismiss filed by Jeffrey Epstein. (Critton, Robert) (Entered: 11/10/2008)
+57 | NOTICE by Jeffrey Epstein of Withdrawal as Co-Counsel (Tein, Michael)
+(Entered: 12/30/2008)
+58
+OPINION AND ORDER granting in part and denying in part 52 Motion to
+Dismiss. Signed by Judge Kenneth A. Marra on 2/12/2009. (ir) (Entered:
+02/12/2009)
+59 | NOTICE by Jane Doe No. 5 of Change of Name of Plaintiff's Counsel
+(Horowitz., Adam) (Entered: 02/23/2009)
+60
+AMENDED COMPLAINT (Second), filed by Jane Doe No. 5.(Horowitz,
+Adam) (Entered: 02/27/2009)
+61
+Plaintiff's MOTION to Compel Answers to Interrogatories and Production of
+Documents and Incorporated Memorandum of Law in Support by Jane Doe
+Jo. 5. Responses due by 3/19/2009 (Attachments: # 1 Exhibit A. # 2 Exhibi
+3) (Horowitz, Adam) (Entered: 03/02/2009
+62
+Defendant's MOTION for Extension of Time to File Response as to 60
+Amended Complaint with proposed Order by Jeffrey Epstein. (Critton
+Robert) (Entered: 03/04/2009)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl7302073795169544-L_801_0-1
+
+
+
+| 03/05/2009
+03/06/2009
+03/18/2009
+03/19/2009
+03/25/2009
+03/25/2009
+04/02/2009
+04/02/2009
+64
+ENDORSED ORDER granting 62 Motion for Extension of Time to Answer
+Complain 357209. i represe dis 4/2009, Signed by Judge Kenneth
+Defendant's MOTION for Extension of Time to File Response as to 61
+Plaintiff's MOTION to Compel Answers to Interrogatories and Production of
+Documents and Incorporated Memorandum of Law in Support with proposed
+Order by Jeffrey Epstein. (Critton, Robert) (Entered: 03/06/2009)
+Defendant's MOTION for Leave to File Excess Pages with proposed Order in
+Response to 61 Motion to Compel Answers and Interrogatories ano
+Production of Documents, Including Supporting Memorandum of Law by
+Jeffrey Epstein. (Critton, Robert) Modified link and text on 3/19/2009 (tas).
+66
+Clerks Notice of Docket Correction and Instruction to Filer re 65 Defendant's
+MOTION for Leave to File Excess Pages with proposed Order filed by Jeffrey
+Epstein. Error - Incorrect Document Link/No Link; Correction - Document
+relinked properly by Clerk. Instruction to filer - In the future, please link the
+document to the proper entry. It is not necessary to refile this document. (tas)
+67.
+RESPONSE to Motion re 61 Plaintiff's MOTION to Compel Answers to
+Interrogatories and Production of Documents and Incorporated Memorandum
+of Law in Support filed by Jeffrey Epstein. Replies due by 4/6/2009.
+(Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit _(Critton, Robert)
+(Entered: 03/25/2009)
+68 Defendant's MOTION to Stay re 60 Amended Complaint by Jeffrey Epstein.
+Responses due by 4/13/2009 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3
+Exhibit _(Pike, Michael) (Entered: 03/25/2009)
+69
+Defendant's MOTION to Compel Respnse to Ist RTP by Jeffrey Epstein.
+Responses due by 4/20/2009 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3
+Exhibit , # 4 Exhibit D)(Critton, Robert) (Entered: 04/02/2009)
+70. | Defendant's MOTION to Compel Answers to Ist Interrogs by Jeffrey Epstein.
+04/02/2009
+04/03/2009
+04/13/2009
+04/14/2009
+11 | Defendant's ANSWER and Affirmative Defenses to Amended Complaint
+(Second) by Jeffrey Epstein. (Critton, Robert) (Entered: 04/02/2009)
+72 | Unopposed MOTION for Extension of Time to File Reply as to 67 Response
+to Motion, to Compel Answers to Interrogatories and Production of
+Documents by Jane Doe No. 5. (Attachments: # 1 Text of Proposed Order)
+(Mermelstein, Stuart) (Entered: 04/03/2009)
+73
+Unopposed MOTION for Extension of Time to File Response /Memorandum
+in Opposition to Motion to Stay and/or Continue Action by Jane Doe No. S.
+(Attachments: # 1 Text of Proposed Order)(Mermelstein, Stuart) (Entered:
+74 ENDORSED ORDER granting (75) Motion for Extension of Time to Respond
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|2302073795169544-L_801_0-1
+
+
+CM/ECF - Live Database - fisd
+
+04/17/2009
+04/20/2009
+04/23/2009
+04/28/2009
+04/29/2009
+05/04/2009
+05/05/2009
+05/05/2009
+05/06/2009
+re (65 in 9:08-cv-80119-KAM) Defendant's MOTION to Stay re (56)
+Amended Complaint in case 9:08-cv-80119-KAM; granting (67) Motion for
+Extension of Time to Respond re (65 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Stay re (56) Amended Complaint in case 9:08-cv-80232-KAM;
+granting (82) Motion for Extension of Time to Respond re (65 in 9:08-cv-
+80119-KAM) Defendant's MOTION to Stay re (56) Amended Complaint in
+case 9:08-cv-80380-KAM; granting (73) Motion for Extension of Time to
+Respond re (65 in 9:08-cv-80119-KAM) Defendant's MOTION to Stay re (56)
+Amended Complaint in case 9:08-cv-80381-KAM; granting (33) Motion for
+Extension of Time to Respond re (65 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Stay re (56) Amended Complaint in case 9:08-cv-80993-KAM;
+granting (27) Motion for Extension of Time to Respond re (65 in 9:08-cv-
+80119-KAM) Defendant's MOTION to Stay re (56) Amended Complaint in
+case 9:08-cv-80994-KAM in case 9:08-cv-80119-KAM. ( Responses due by
+4/23/2009). Signed by Judge Kenneth A. Marra on 4/14/2009. (ir) (Entered:
+04/14/2009)
+75
+Unopposed MOTION for Extension of Time to File Response as to 70
+Defendant's MOTION to Compel Answers to Ist Interrogs, 69 Defendant's
+MOTION to Compel Respnse to Ist RTP by Jane Doe No. 5. (Attachments: #
+1 Text of Proposed Order)(Mermelstein, Stuart) (Entered: 04/17/2009)
+76
+MEMORANDUM in Support re 61 Plaintiff's MOTION to Compel Answers
+to Interrogatories and Production of Documents and Incorporated
+lemorandum of Law in Support by Jane Doe No. 5. (Mermelstein, Stuat
+Entered: 04/20/2000
+77 | RESPONSE in Opposition re 68 Defendant's MOTION to Stay re 60
+Amended Complaint filed by Jane Doe No. 5. (Mermelstein, Stuart) (Entered:
+04/23/2009)
+78 ORDER TO SHOW CAUSE why cases should not be consolidated for
+discovery purposes Show Cause Response due by 5/5/2009.. Signed by Judge
+Kenneth A. Marra on 4/28/2009. (cgs) (Entered: 04/29/2009)
+• Unopposed MOTION for Extension of Time to File Response as to 70
+Defendant's MOTION to Compel Answers to Ist Interrogs, 69 Defendant's
+MOTION to Compel Respnse to Ist RTP by Jane Doe No. 5. (Attachments: #
+1 Text of Proposed Order) (Mermelstein, Stuart) (Entered: 04/29/2009)
+80 | MEMORANDUM in Opposition re 78 Order to Show Cause by Jeffrey
+Epstein. (Pike, Michael) (Entered: 05/04/2009)
+81
+RESPONSE TO ORDER TO SHOW CAUSE by Jane Doe No. 5.
+(Mermelstein, Stuart) (Entered: 05/05/2009)
+82 Defendant's MOTION for Extension of Time to File Reply as to 77 Response
+in Opposition to Motion to Stay by Jeffrey Epstein. (Pike, Michael) (Entered:
+05/05/2009)
+83
+ENDORSED ORDER granting (89) Motion for Extension of Time to Reply re
+(65 in 9:08-cv-80119-KAM) Defendant's MOTION to Stay re (56) Amended
+Complaint; granting (81) Motion for Extension of Time to Reply re (65 in
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?302073795169544-L_801_0-1
+
+
+
+9:08-Cv-80119-KAM) Defendant's MOTION to Stay re (56) Amended
+05/06/2009
+05/06/2009
+05/06/2009
+05/11/2009
+05/13/2009
+05/13/2009
+05/14/2009
+05/14/2009
+05/14/2009
+Motion for Extension of Time to Reply re (65 in 9:08-cv-80119-KAM)
+Defendant's MOTION to Stay re (56) Amended Complaint in case 9:08-CV-
+80381-KAM; granting (46) Motion for Extension of Time to Reply re (65 in
+9:08-cv-80119-KAM) Defendant's MOTION to Stay re (56) Amended
+Complaint in case 9:08-cv-80993-KAM; granting (37) Motion for Extension
+of Time to Reply re (65 in 9:08-cv-80119-KAM) Defendant's MOTION to
+Stay re (56) Amended Complaint in case 9:08-cv-80994-KAM in case 9:08-
+cv-80119-KAM. (Replies due by 5/20/2009.). Signed by Judge Kenneth A.
+Marra on 5/5/2009. (ir) (Entered: 05/06/2009)
+84
+RESPONSE in Opposition re 70 Defendant's MOTION to Compel Answers to
+S. heroes, and am Intered of loanable Expenses filed by Jane Doe No.
+85
+RESPONSE in Opposition re 69 Defendant's MOTION to Compel Respnse to
+by Jane DoeNo. S. beacon and for a bit A a Reasonable mere ele
+05/06/2009)
+86
+Defendant's MOTION to Compel Identity of Doe #5 in Style of Case and
+Third-Party Subpoenas by Jeffrey Epstein. Responses due by 5/26/2009
+(Attachments: # 1 Exhibit A)(Pike, Michael) (Entered: 05/06/2009)
+87
+Defendant's MOTION for Order requiring that plaintiff use Proper Case Style
+in all Filings by Jeffrey Epstein. (Critton, Robert) Modified on 5/13/2009 (Is).
+(Text modified by Clerk] (Entered: 05/11/2009)
+88
+Clerks Notice of Docket Correction and Instruction to Filer re 87 Defendant's
+MOTION Require Plaintiff to Use Proper Case Style filed by Jeffrey Epstein.
+Error - Docket text does not match document; Correction - Docket text
+modified by Clerk. It is not necessary to refile this document. (Is) (Entered:
+05/13/2009)
+89
+RESPONSE/REPLY to 17 Response in Opposition to Motion to Stay and/or
+Continue Action by Jeffrey Epstein. (Pike, Michael) (Entered: 05/13/2009)
+Cases associated. (dg) (Entered: 05/14/2009)
+20
+ORDER CONSOLIDATING CASES. Hereinafter all motions and other court
+filings that relate to discovery and all procedural motions that relate to
+multiple cases shall be styled with all of the case names and numbers and shall
+e filed in Case No. 08-80119-CIV-MARRA. Signed by Judge Kenneth /
+/агта on 5/14/2009. Associated Cases: 9:08-cv-80119-KAM et al. (i
+ORDER REQUESTING UNITED STATES PROVIDE POSITION TO
+MOTION TO STAY. Signed by Judge Kenneth A. Marra on 5/14/2009.
+(Attachments: # 1 Appendix Motion to Stay DE 51) Associated Cases: 9:08-
+cv-80119-KAM et al. (ir) (Entered: 05/14/2009)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|2302073795169544-L_801_0-1
+
+
+
+|05/14/2009
+05/14/2009
+05/18/2009
+05/19/2009
+05/19/2009
+05/20/2009
+05/20/2009
+92 ORDER denying as moot 87 Motion. See Order consolidating cases... Signed
+by Judge Kenneth A. Marra on 05/15/2009. (Ic3) (Entered: 05/14/2009)
+93
+ORDER terminating 68 Motion to Stay; terminating 86 Motion to Compel.
+See Order consolidating cases. See procedural motions pending: DE 65 and
+DE 91 in 08-80119.. Signed by Judge Kenneth A. Marra on 5/15/2009. (lc3)
+(Entered: 05/14/2009)
+94
+Defendant's MOTION for Extension of Time to File Reply as to (39 in 9:08-
+cy-80994-KAM) Response in Opposition to Motion, (40 in 9:08-cv-80994-
+KAM) Response in Opposition to Motion by Jeffrey Epstein. Associated
+Cases: 9:08-cv-80119-KAM et al. (Pike, Michael) (Entered: 05/18/2009)
+95
+Defendant's MOTION to Strike Cases from Current Trial Docket by Jeffrey
+Epstein. Responses due by 6/8/2009 (Attachments: # 1 Exhibit A)Associated
+Cases: 9:08-cv-80119-KAM et al.(Pike, Michael) (Entered: 05/19/2009)
+96 | MOTION for Leave to Withdraw as Co-Counsel by Jeffrey Epstein.
+(Attachments: # 1 Text of Proposed Order)(Tein, Michael) Event Modified on
+5/20/2009 (ail). (Entered: 05/19/2009)
+97
+ORDER terminating (93) Motion to Strike ; terminating (94) Motion in case
+9:08-cv-80232-KAM; terminating (110) Motion to Strike ; terminating (111)
+Motion in case 9:08-cv-80380-KAM; terminating (95) Motion to Strike ;
+terminating (96) Motion in case 9:08-cv-80381-KAM; terminating (90)
+Motion to Strike : terminating (91) Motion in case 9:08-cv-80811-KAM;
+terminating (62) Motion to Strike in case 9:08-cv-80893-KAM; terminating
+(62) Motion to Strike in case 9:08-cv-80993-KAM; terminating (50) Motion
+to Strike in case 9:08-cv-80994-KAM. Signed by Judge Kenneth A. Marra on
+5/20/2009. (Ic3) (Entered: 05/20/2009)
+98
+NOTICE by
+1. of Filing Withdrawal of Previously Raised Obiections to
+Defendant, Jeffrey Epstein's Motion to Compel And/Ur laentijy
+in the
+Style of This Case and Motion to Identify
+1. in Third-Party Subpoenas
+for Purposes of Discovery, Or, Alternatively, Motion to Dismiss Sua Sponte,
+With Inorporated Memorandum of Law Associated Cases: 9:08-cv-80119-
+KAM et al.(Hill, Jack) (Entered: 05/20/2009)
+05/20/2009
+99
+05/20/2009
+05/21/2009
+correction was made by the Clerk. It is not necessary to refile this document
+but future motions filed must include all applicable relief events. (ail)
+(Entered: 05/20/2009)
+100 | ORDER STRIKING in all Epstein cases EXCEPT case no. 08-80119: Notice
+1. of Filing Withdrawal of Previously Raised Objections to Epstein's
+Motion to Compel and/or Identify. This Notice should only be filed in 08- •
+80119, not in all of the Epstein cases.. Signed by Judge Kenneth A. Marra on
+5/20/2009. Associated Cases: 9:08-cv-80119-KAM et al. (Ic3) (Entered:
+05/20/2009)
+101
+Plaintiff's MOTION for Extension of Time to File Response as to (91 in 9:08-
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl7302073795169544-L_801_0-1
+
+
+
+05/22/2009
+102
+cv-80119-KAM) Defendant's MOTION to Compel Identity of Doe in Style of
+Case and Third-Party Subpoenas (replaces Docket entry 90) by Jane Doe No.
+6, Jane Doe No. 7, Jane Doe, Jane Doe No. 5, Jane Doe No. 4, Jane Doe No.
+3. Associated Cases: 9:08-cv-80119-KAM et al.(Mermelstein, Stuart)
+(Entered: 05/21/2009)
+ORDER terminating (100) Motion for Extension of Time to Respond in case
+9:08-cv-80232-KAM; terminating (117) Motion for Extension of Time to
+05/27/2009
+05/28/2009
+erminating (54) Motion for Extension of Time to Respond in case 9:08-cv
+0994-K.AM. The attorneys are instructed again to ONLY file this type o
+notion in case no. 08-80119. See Order consolidating cases for details
+signed by Judge Kenneth A. Marra on 5/22/2009. (lc3) (Entered: 05/22/2009
+103 | NOTICE by Jane Doe re (111 in 9:08-cv-80119-KAM) Plaintiff's MOTION
+for Extension of Time to File Response as to (91 in 9:08-cv-80119-KAM)
+Defendant's MOTION to Compel Identity of Doe in Style of Case and Third-
+Party Subpoenas (replaces Docket entry 90)Plaintiff's MOTION for Extension
+of Time to File Response as to (91 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Compel Identity of Doe in Style of Case and Third-Party
+Subpoenas (replaces Docket entry 90) (Attachments: # 1 Text of Proposed
+Order)Associated Cases: 9:08-cv-80119-KAM et al.(Horowitz, Adam)
+(Entered: 05/27/2009)
+104
+ORDER STRIKING Notice by Jane Doe in all Epstein cases EXCEPT in case
+08-80119. This Notice should only be filed in 08-80119, not in all of the
+Epstein cases... Signed by Judge Kenneth A. Marra on 5/28/2009. Associated
+Cases: 9:08-cv-80119-KAM et al. (lc3) (Entered: 05/28/2009)
+105
+NOTICE of Attorney Appearance by
+on behalf of
+United States of America Associated Cases: 9:08-cv-80119-KAM et al.
+) (Entered: 05/29/2009)
+106
+RESPONSE to Motion re (72 in 9:08-cv-80380-KAM) Defendant's MOTION
+to Stay re (62) Amended Complaint, (57 in 9:08-cv-80232-KAM) Defendant's
+MOTION to Stay re (50) Amended Complaint, (24 in 9:08-cv-80893-KAM)
+Defendant's MOTION to Stay re (1) Complaint, (23 in 9:08-cv-80994-KAM)
+Defendant's MOTION to Stay re (18) Amended Complaint, (22 in 9:08-cv-
+80993-KAM) Defendant's MOTION to Stay re (19) Amended Complaint, (65
+in 9:08-cv-80119-KAM) Defendant's MOTION to Stay re (56) Amended
+Complaint, (68 in 9:08-cv-80381-KAM) Defendant's MOTION to Stay re (60)
+Amended Complaint, (51 in 9:08-cv-80811-KAM) Defendant's MOTION to
+Stay re (40) Amended Complaint and or Continue Action Filed Pursuant to
+Court's Order Requesting Government's Position filed by United States of
+America. Replies due by 6/8/2009. Associated Cases: 9:08-cv-80119-KAM et
+I (Entered: 05/29/2009)
+107
+RESPONSE in Opposition re (90 in 9:08-cv-80119-KAM) Defendant's
+MOTION to Compel Identify Doe in Style of Case and in Third-Party
+Subpoenas. (91 in 9:08-cv-80119-KAM) Defendant's MOTION to Compel
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?302073795169544-L_801_0-1
+
+
+
+06/01/2009
+06/01/2009
+06/04/2009
+Identity of Doe in Style of Case and Third-Party Subpoenas (replaces Docket
+- 19 cal. (el, Katherine (tered: 05220200d)
+2, Jane Doe No. 101. Associated Cases:
+108
+ORDER STRIKING (124 in 9:08-cv-80119-KAM, 105 in 9:08-cv-80811-
+KAM, 74 in 9:08-cv-80993-KAM, 72 in 9:08-cv-80893-KAM, 106 in 9:08-
+cv-80232-KAM, 123 in 9:08-cv-80380-KAM, 35 in 9:09-cv-80591-KAM, 25
+in 9:09-cv-80469-KAM, 60 in 9:08-cv-80994-KAM, 22 in 9:09-cv-80656-
+KAM, 107 in 9:08-cv-80381-KAM) Response in Opposition to Motion, filed
+by Jane Doe No. 102, Jane Doe No. 101 DO NOT FILE IN EVERY
+EPSTEIN CASE. SEE ORDER CONSOLIDATING CASES.. Signed by
+Judge Kenneth A. Marra on 5/29/2009. Associated Cases: 9:08-cv-80119-
+KAM et al. (Ic3) (Entered: 05/29/2009)
+109
+MOTION for Leave to File UNDER SEAL RESPONSE IN OPPOSITION TO
+DEFENDANTS MOTION TO STAY OR, IN THE ALTERNATIVE, TO
+UNSEAL THE NONPROSECUTION AGREEMENT by Jane Doe No. 102,
+Jane Doe No. 101. Associated Cases: 9:08-cv-80119-KAM et al.(Ezell,
+Katherine) (Entered: 05/29/2009)
+110 | MOTION for Hearing MOTION TO RESCHEDULE HEARING by Jane Doe
+No. 102, Jane Doe No. 101. Associated Cases: 9:08-cv-80119-KAM et al.
+(Josefsberg, Robert) (Entered: 05/29/2009)
+111
+ORDER STRIKING (28 in 9:09-cv-80469-KAM, 126 in 9:08-cv-80380-
+KAM, 109 in 9:08-cv-80232-KAM, 25 in 9:09-cv-80656-KAM, 77 in 9:08-
+cv-80993-KAM, 38 in 9:09-cv-80591-KAM, 110 in 9:08-cv-80381-KAM, 63
+in 9:08-cv-80994-KAM, 75 in 9:08-cv-80893-KAM, 108 in 9:08-cv-80811-
+KAM) Motion to Continue Hearing filed by Jane Doe No. 102, Jane Doe No.
+101, (76 in 9:08-cv-80993-KAM, 109 in 9:08-cv-80381-KAM, 108 in 9:08-
+cv-80232-KAM, 62 in 9:08-cv-80994-KAM, 125 in 9:08-cv-80380-KAM, 74
+in 9:08-cv-80893-KAM, 24 in 9:09-cv-80656-KAM, 37 in 9:09-cv-80591-
+KAM, 107 in 9:08-cv-80811-KAM, 27 in 9:09-cv-80469-KAM) Motion for
+Leave to File, filed by Jane Doe No. 102, Jane Doe No. 101. THESE
+DOCUMENTS SHOULD BE FILED ONLY IN 08-80119. SEE CASE
+MANAGEMENT ORDER.. Signed by Judge Kenneth A. Marra on 6/1/2009.
+(Ic3) (Entered: 06/01/2009)
+Reset Scheduling Order Deadlines: Calendar Call set for 5/28/2010 10:00 AM
+in West Palm Beach Division before Judge Kenneth A. Marra., Jury Trial set
+for 6/1/2010 09:00 AM in West Palm Beach Division before Judge Kenneth
+A. Marra., Discovery due by 12/11/2009., Dispositive Motions due by
+1/8/2010. (ir) (Entered: 06/01/2009)
+112
+REPLY to Response to Motion re (113 in 9:08-cv-80119-KAM) Plaintiff's
+MOTION Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No-
+Contact Order Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Reply to
+Defendant Jeffrey Epstein's Response to Plaintiffs Jane Doe No. 101 and Jane
+Doe No. 102's Motion for a No-Contact Order filed by Jane Doe No. 101.
+Jane Doe No. 102. Associated Cases: 9:08-cv-80119-KAM et al.(Ezell,
+Katherine) (Entered: 06/04/2009)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl7302073795169544-L_801_0-1
+
+
+
+| 06/04/2009
+06/08/2009
+06/08/2009
+06/09/2009
+113 | ORDER STRIKING (112 in 9:08-cv-80381-KAM, 111 in 9:08-cv-80232-
+KAM, 136 in 9:08-cv-80119-KAM, 111 in 9:08-cv-80811-KAM, 128 in 9:08-
+cv-80380-KAM, 65 in 9:08-ev-80994-KAM, 79 in 9:08-cv-80893-KAM, 42
+in 9:09-cv-80591-KAM, 27 in 9:09-cv-80656-KAM, 32 in 9:09-cv-80469-
+KAM, 79 in 9:08-cv-80993-KAM) Reply to Response to Motion, filed by
+Jane Doe No. 102, Jane Doe No. 101 Document stricken for failure to follow
+Court's orders. DO NOT FILE A DOCUMENT IN EVERY EPSTEIN CASE
+if it is to be filed only in 08-80119. See Case Management Order and contact
+CM/ECF Support for assistance in proper filing.. Signed by Judge Kenneth A.
+Marra on 6/4/2009. Associated Cases: 9:08-cv-80119-KAM et al. (Ic3)
+(Entered: 06/04/2009)
+114
+RESPONSE to Motion re (91 in 9:08-cv-80119-KAM) Defendant's MOTION
+to Compel Identity of Doe in style of Case and Third-Party Subpoenas
+(replaces Docket entry 90) filed by Jane Doe. Replies due by 6/18/2009
+(Attachments: # 1 Exhibit A, # 2 Exhibit B)Associated Cases: 9:08-cv-80119-
+KAM et al.(Horowitz, Adam) (Entered: 06/08/2009)
+115 | NOTICE by Jane Doe re (113 in 9:08-cv-80119-KAM) Plaintiff's MOTION
+Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No-Contact Order
+-Plaintiffs Jane Does 2-7 Notice of Joinder Associated Cases: 9:08-cv-80119-
+KAM et al.(Horowitz, Adam) (Entered: 06/08/2009)
+Unopposed MOTION to Amend/Correct 71 Answer to Amended Complaint
+by Jeffrey Epstein. Responses due by 6/26/2009 (Attachments: # 1 Exhibit
+"A", # 2 Exhibit "B", # 3 Text of Proposed Order Order)(Pike, Michael)
+(Entered: 06/09/2009)
+PACER Login: du4480
+Description:
+Billable Pages: 10
+PACER Service Center
+Transaction Receipt
+06/09/2009 16:46:09
+Client Code:
+9:08-cv-80381-
+Docket Report Search Criteria:
+KAM
+Cost:
+0.80
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|7302073795169544-L_801_0-1
+
+
+• Case 9:08-cv-8 31-KAM Document 52
+... FLSD Docket 10/(
+'008 Page 1 of 10
+CASE NO.: 08-CV-80381-MARRA-JOHNSON
+JANE DOE NO. 5
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT'S, EPSTEIN, MOTION TO DISMISS AND MOTION FOR MORE
+DEFINITE STATEMENT DIRECTED TO PLAINTIFF'S AMENDED COMPLAINT
+Defendant, JEFFERY EPSTEIN, by and through his undersigned counsel, moves
+to dismiss and for more definite statement of Plaintiff JANE DOE NO. 5's Amended
+Complaint. Rules 12(b)(6), and 12(e) and (f), Fed.R.Civ.P. (2008). In support of his
+motion, Defendant states:
+Introduction
+Defendant is filing similar motions to dismiss and for more definite statement
+directed to the Amended Complaints filed against Defendant in this Court in JANE DOE
+NO. 2, JANE DOE NO. 3, JANE DOE NO. 4 and JANE DOE NO. 5. The motions are
+directed to the Counts for "Sexual Assault and Battery," and "Coercion and Enticement
+to Sexual Activity in Violation of 18|
+• §2422" in each of the respective complaints.
+However, there are distinctions in the four motions filed based on the complaint
+allegations. For example, Defendant challenges the Plaintiffs' allegations as to assault
+in all four actions, and challenges the battery allegations in JANE DOE NOS. 2 and 3,
+but not in JANE DOE NOS. 4 and 5. Defendant moves to dismiss the §2422 count in all
+four actions.
+
+
+31-KAM Document 52 Entered ... FLSD Docket 10/(
+Page No. 2
+.008 Page 2 of 10
+Motion
+1. Counts I and III of the Amended Complaint are required to be dismissed for
+failure to state a claim upon which relief can be granted. Rule 12(b)(6). Plaintiff has
+failed to allege sufficient factual allegations in the Counts and instead alleges labels and
+conclusions, and an attempted formulaic recitation of the elements in each Count.
+2. In the alternative, Defendant seeks more definite statement of Count I and III. In
+Count I, the Plaintiff is required to more definitely allege in the context of the claim for
+assault underlying factual allegations pertaining to the creation in Plaintiff of "imminent
+fear of peril;"; what EPSTEIN said and did, if anything, to create fear and apprehension
+in Plaintiff. In Count III, Plaintiff is required to more definitely state the underlying factual
+allegations to support her claim as set forth in the statute, 18
+92422(b) and
+§2455. Rule 12(e). See discussion of law below herein.
+3. Also, Plaintiff's reference in Count III to 28
+• §2255, pertaining to habeas
+corpus proceedings is required to be stricken as immaterial. Rule 12(f). Plaintiff is
+required to more definitely state what statutory provision she is relying on. Rule 12 (e).
+WHEREFORE, Defendant respectfully requests that this Court dismiss Counts I and
+IlI, strike the immaterial statutory reference, and require Plaintiff to more definitely plead
+the underlying elements of her claims.
+Supporting Memorandum of Law
+Standard on Rule 12(b)(6) Motion To Dismiss
+As established by the Supreme Court in Bell Atlantic Corp.. Twombly, 127
+S.Ct. 1955 (2007), a motion to dismiss should be granted if the plaintiff does not plead
+"enough facts to state a claim to relief that is plausible on its face." Id, at 1974.
+Although the complaint need not provide detailed factual allegations, the basis for relief
+
+
+11-KAM Document 52 Entered .. FLSD Docket 10|
+008 Page 3 of 10
+Page No. 3
+in the complaint must state "more than labels and conclusions, and a formulaic
+recitation of the elements of a cause of action will not do." Id, at 1965. Further, "factual
+allegations must be enough to raise a right to relief above the speculative level ... on the
+assumption that all the allegations in the complaint are true (even if doubtful in fact)." Id.
+On a motion to dismiss, the well pleaded allegations of plaintiff's complaint are taken as
+true and construed in the light most favorable to the plaintiff.
+L. Dekalb County
+Sch. Dist., 446 F.3d 1153, 1156 (11th Cir.2006).
+Significantly, the Supreme Court in Bell Atlantic Corp. . Twombly abrogated the
+often cited observation that "a complaint should not be dismissed for failure to state a
+claim unless it appears beyond doubt that the plaintiff can prove not set of facts in
+support of his claim that would entitle him to relief." Id, (abrogating and quoting Conley
+. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)). The Supreme
+Court rejected the notion that "a wholly conclusory statement of claim [can] survive a
+motion to dismiss whenever the pleadings le[ave] open the possibility that a plaintiff
+might later establish some 'set of [undisclosed] facts' to support recovery." Id. As
+explained by the Supreme Court in Bell Atlantic Corp., supra at 1664-65:
+While a complaint attacked by a Rule 12(b)(6) motion to dismiss does not
+need detailed
+factual allegations,
+ibid.; Sanjuan.
+• American Bd. of
+Psychiatry and Neurology, Inc., 40 F.3d 247, 251 (
+17 1994), a plaintiff's
+obligation to provide the "grounds" of his "entitle(ment] to relief" requires
+more than labels and conclusions, and a formulaic recitation of the elements
+of a cause of action will not do, see Papasan . Allain, 478 U.S. 265, 286,
+106 S.Ct. 2932, 92 L.Ed.2d 209 (1986) (on a motion to dismiss, courts "are
+not bound to accept as true a legal conclusion couched as a factual
+allegation"). Factual allegations must be enough to raise a right to relief
+above the speculative level, see 5 . Wright & A. Miller, Federal Practice and
+Procedure § 1216, pp. 235-236 (3d ed.2004) (hereinafter Wright & Miller)
+(IThe pleading must contain something more ... than ... a statement of facts
+that merely creates a suspicion [of] a legally cognizable right of action"), on
+the assumption that all the allegations in the complaint are true (even if
+
+
+Case 9:08-Cv-{ 81-KAM Document 52 Entere. ... FLSD Docket 10/,
+Page No. 4
+doubtful in fact), see, e.g., Swierkiewicz |: Sorema N. A., 534 U.S. 506, 508,
+n. 1, 122 S.Ct. 992, 152 L.Ed.2d 1 (2002); Neitzke : Williams, 490 U.S. 319,
+327, 109 S.Ct. 1827, 104 L.Ed.2d 338 (1989) (" Rule 12(b)(6) does not
+countenance ... dismissals based on a judge's disbelief of a complaint's
+factual allegations"); Scheuer . Rhodes, 416 U.S. 232, 236, 94 S.Ct. 1683,
+40 L.Ed.2d 90 (1974) (a well-pleaded complaint may proceed even if it
+appears "that a recovery is very remote and unlikely").
+2008 Page 4 of 10
+Pursuant to Rule 12(e), a party may move for more definite statement of a
+pleading to which a responsive pleading is allowed where the pleading "is so vague or
+ambiguous that the party cannot reasonably frame a response." The motion is required
+to point out the defects and the desired details. Id.
+Count I - "Sexual Assault and Battery" is subject to dismissal as Plaintiff has
+failed to state a claim upon which relief can be granted.
+It is well settled that this Court is to apply Florida substantive law in this action.
+Erie R.Co. |. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, although the term
+"assault and battery" is most commonly referred to as if it were a legal unit, or a single
+concept, "assault and battery are separate and distinct legal concepts, assault being the
+beginning of an act which, if consummated, constitutes battery." 3A Fla.Jur.2d Assault
+§1. An assault and battery are intentional acts. See generally, Spivey | Battaglia, 258
+So.2d 815 (Fla. 1972); and Travelers Indem. Co. . PCR, Inc., 889 So.2d 779 (Fla.
+2004).
+An "assault" is an intentional, unlawful offer of corporal injury to another by force,
+or exertion of force directed toward another under such circumstances as to create a
+reasonable fear of imminent peril. See Lay | Kremer, 411 So.2d 1347 (Fla. 1st DCA
+1982). It must be premised upon an affirmative act - a threat to use force, or the actual
+exertion of force. See 3A Fla.Jur.2d Assault §1 ("The essential element of the tort of
+assault is the violence offered, and not actual physical contact.").
+
+
+• Case 9:08-cv-8
+11-KAM Document 52 Entered.. FLSD Docket 10f
+Page No. S
+008 Page 5 of 10
+As further explained in Florida Jurisprudence, 2d, Assault §1 -
+An assault is defined as an intentional unlawful offer of corporal
+injury to another by force, or force unlawfully directed toward the person of
+another, under circumstances as to create a fear of imminent peril,
+coupled with the apparent present ability to effectuate the attempt. At
+common law, a tortious assault is an act that puts another in reasonable
+apprehension of immediate bodily harm.
+In 912 of her Amended Complaint, Plaintiff does plead the requisite
+"touching" element of "battery," so that aspect of the assault and battery claim is not
+being challenged. With the standard of pleading established in Twombly, supra, in the
+context of assault, Plaintiff has failed to state a claim upon which relief can be granted.
+Rule 12(b)(6). As to the elements of assault, there are no factual allegations as to what
+was said or done to Plaintiff such that it constituted an "intentional, unlawful offer of
+corporal injury to another by force, or exertion of force directed toward another under
+such circumstances as to create a reasonable fear of imminent peril." See 912-13 of
+Am. Comp. In 113 alleges that JANE DOE NO. 5 (and another unidentified girl) "were
+then able to get dressed, leave the room and go back downstairs. Esptein gave both
+girls money for this 'massage." Allegations as to circumstances creating a fear of
+imminent peril are lacking.
+Under applicable law, Plaintiff is required to give more than labels and
+conclusions, and a formulaic recitation of the elements of a cause of action. Iwombly,
+supra. Plaintiff is required to allege the facts of what was done to her; what EPSTEIN
+said and did, if anything, to create fear and apprehension in Plaintiff.
+As noted in the introduction and as this Court is well aware, there is more than
+one action brought against this Defendant attempting to allege similar sounding claims.
+With all due respect, the details as to a particular claim asserted by a particular Plaintiff
+
+
+Case 9:08-cv-f "81-KAM Document 52 Enterel . FLSD Docket 10/,
+2008 Page 6 of 10
+Page No. 6
+are important to give this Defendant fair notice of Plaintiff's claim so he may properly
+respond. Accordingly, under applicable law, Plaintiff has failed to state a claim for
+"sexual assault and battery" has Plaintiff has failed to plead requisite factual allegations
+concerning the assault.
+In the alternative to dismissing Count I, Defendant requests that Plaintiff be
+required to give more definite statement as to what was done to her; what EPSTEIN
+said and did, if anything, to create fear and apprehension in Plaintiff; in pleading the
+elements of assault. Rule 12(e).
+Count III - "Coercion and Enticement to Sexual Activity in Violation of 18
+§2422" - is subject to dismissal as Plaintiff has failed to state a claim
+upon which relief can be granted. Rule 12(b)(6). Count III also contains an
+immaterial reference to 28
+: §2255, which is required to be stricken
+and more definitely stated.
+Count III of Plaintiff's Complaint attempts to assert a claim for "Coercion and
+Enticement to Sexual Activity in Violation of 18
+1. $2422." In her prayer for relief in
+Count III, Plaintiff
+"demands judgment against Defendant Jeffrey Epstein for all
+damages available under 28
+§2255(a),...."
+Although the reference to "28
+§2255," pertaining to habeas corpus
+proceedings - federal custody and remedies on motion attacking sentence, is probably
+a typographical error by Plaintiff, and the reference to "28" was meant to be "18,"
+Defendant requests that Plaintiff correct this error so that Defendant may have fair
+notice of the claim Plaintiff is attempting to assert. Whether or not the "28" is
+typographical error, Defendant is still entitled to dismissal of the count.
+The applicable version of these statutory provisions, (pre-2006 Amendments, as
+the Amended Complaint alleges a time period of "in or about 2002-2003," 18), provides:
+
+
+Case 9:08-Cv-8 31-KAM Document 52 Entered
+‚FLSD Docket 10
+008 Page 7 of 10
+Page No. 7
+CHAPTER 117-TRANSPORTATION FOR ILLEGAL SEXUAL ACTIVITY
+AND RELATED CRIMES
+§ 2422. Coercion and enticement
+(a) Whoever knowingly persuades, induces, entices, or coerces any
+individual to travel in interstate or foreign commerce, or in any Territory o
+Possession of the United States, to engage in prostitution, or in any sexual
+activity for which any person can be charged with a criminal offense, or
+attempts to do so, shall be fined under this title or imprisoned not more than
+20 years, or both.
+(b) Whoever, using the mail or any facility or means of interstate or foreign
+commerce, or within the special maritime and territorial jurisdiction of the
+United States knowingly persuades, induces, entices, or coerces any
+individual who has not attained the age of 18 years, to engage in prostitution
+or any sexual activity for which any person can be charged with a criminal
+offense, or attempts to do so, shall be fined under this title and imprisoned
+CHAPTER 110-SEXUAL EXPLOITATION AND OTHER ABUSE OF
+CHILDREN
+§ 2255. Civil remedy for personal injuries
+(a) Any minor who is a victim of a violation of section 2241(, 2242, 2243.
+2251, 2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who
+suffers personal injury as a result of such violation may sue in any
+appropriate United States District Court and shall recover the actual
+damages such minor sustains and the cost of the suit, including a reasonable
+attorney's tee. Any minor as described in the preceding sentence shall be
+deemed to have sustained damages of no less than $50,000 in value.
+(b) Any action commenced under this section shall be barred unless the
+complaint is filed within six years after the right of action first accrues or in
+'The above-quoted version of 18
+§2422 is the post-2003 amendments which
+amended the statute as follows:
+2003 Amendments. Subsec. (a). Pub.L. 108-21, § 103(a)(2)(A), struck out "10"
+and inserted "20".
+Subsec. (b). Pub.L. 108-21, § 103(a)(2)(B), struck out "15" and inserted "30".
+Pub.L. 108-21, § 103(b)(2)(A)(i), struck out", imprisoned" and inserted "and
+imprisoned not less than 5 years and".
+Pub.L. 108-21, § 103(b)(2)(A)(ii), struck out", or both" at end of subsec. (b).
+Defendant is not waiving his right to claim that the pre-2003 amended version of the
+statute is applicable in this action. However, for purposes of this motion, the relevant
+statutory language is the same.
+
+
+Case 9:08-cv- 81-KAM Document 52 Entere 1 FLSD Docket 10/
+Page No. 8
+the case of a person under a legal disability, not later than three years after
+the disability.
+2008 Page 8 of 10
+Relevant to Plaintiff's complaint, 18
+;. 2255(a) creates a civil remedy for "a
+minor who is a victim of a violation of section ... 2422 ... of this title and who suffers
+personal injury as a result of such violation ...." Plaintiff has failed to plead any factual
+allegations whatsoever pertaining to violations of 18
+. 2422. Rather, Plaintiff has
+alleged conclusory allegations simply attempting to track parts of the statutory language
+in the statute without underlying factual allegations pertaining to the Plaintiff and any
+conduct by Defendant. See T29 of Am. Comp. Plaintiff's allegations, (or lack of factual
+allegations), are precisely what the standard set forth by the Supreme Court in Bell
+Atlantic Corp. prohibits - Plaintiff's complaint alleges only "labels and conclusions, and
+a (partial) formulaic recitation of the elements."
+First, the Amended Complaint fails to designate whether Plaintiff is relying on
+§2422(a) or §2422(b). Second, although the complaint does contain a partial tracking of
+the language in 18
+: §2422(b), it contains absolutely no factual allegations
+concerning the requisite "using the mail or any facility or means of interstate or foreign
+commerce" by Plaintiff to state a cause of action based on a violation of 18
+2422(b). As well, there are no underlying factual allegations involving this Plaintiff as to
+the requisite elements that a defendant knowingly persuaded, induced, enticed, or
+coerced any individual (Plaintiff in this case) who has not attained the age of 18 years,
+to engage in prostitution or any sexual activity for which any person can be charged with
+a criminal offense, or attempted to do so. See 18
+1. 2422(b); i.e. with what criminal
+offense could Plaintiff and Defendant have been charged. Again, a Plaintiff cannot
+simply track the language of a statute without some underlying factual allegations to
+
+
+Case 9:08-cv- 81-KAM Document 52 Enterel .. FLSD Docket 10/|
+2008 Page 9 of 10
+Page No. 9
+state a claim upon which relief can be granted. Accordingly, Count Ill is required to be
+dismissed, and the reference to 28 USC 2455 be stricken.
+In the alternative, Plaintiff should be required to more definitely state the
+underlying factual allegations to support her claim as set forth in the statute, 18]
+§2422(b) and §2455.
+Conclusion
+As discussed above herein, under the pleading standard established in Twombly,
+supra, and law concerning the elements of Count I and III, Plaintiff has failed to state
+claims upon which relief can be granted. Rule 12(b)(6). Plaintiff's complaint lack
+underlying factual allegations and, thus, Plaintiff is required to more definitely state the
+requisite factual allegations. Finally, Plaintiff should correct any improper statutory
+references.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this fth day of October, 2008:
+Adam D. Horowitz, Esq.
+Jack Alan Goldberger, Esq.
+Jeffrey Marc Herman, Esq.
+Atterbury Goldberger & Weiss, P.A.
+Stuart S. Mermelstein, Esq.
+250 Australian Avenue South
+18205 Biscayne Boulevard
+Suite 1400
+Suite 2218
+West Palm Beach, FL 33401-5012
+Miami, FL 33160
+Fax:
+Fax:
+jagesq@bellsouth.net
+ahorowitz@hermanlaw.com
+Counsel for Defendant Jeffrey Epstein
+jherman@hermanlaw.com
+Irivera@hermanlaw.com
+Counsel for Plaintiff Jane Doe #5
+
+
+Document 52
+Page No. 10
+Entered ... FLSD Docket 10| 008 Page 10 of 10
+Michael R. Tein, Esq.
+Lewis Tein, P.L.
+3059 Grand Avenue, Suite 340
+Coconut Grove, FL 33133
+Fax:
+Counsel for Defendant Jeffrey Epstein
+tein@lewistein.com
+Respectfully submitted,
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar/No. 224162
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+Phone
+Fax
+
+
+'Case 9:08-Cv-{ 31-KAM Document 60
+‹FLSD Docket 02/2
+009
+
+CASE NO.: 08-80381-CIV-MARRA/JOHNSON
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+SECOND AMENDED COMPLAINT
+Plaintiff, Jane Doe No. 5 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey
+Epstein, as follows:
+Parties, Jurisdietion and Venue
+Jane Doe No. 5 is a citizen and resident of the Commonwealth of Virginia, and is sui
+juris.
+2.
+This Complaint is brought under a fictitious name to protect the identity of the
+Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a
+minor.
+4.
+Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
+This is an action for damages in excess of $50 million.
+This Court has jurisdiction of this action and the claims set forth herein pursuant to 28
+§1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs;
+and (ii) is between citizens of different states.
+6.
+This Court has venue of this action pursuant to 28]
+• §1391(a) as a substantial
+- 1-
+
+
+'Case 9:08-cv-{
+31-KAM Document 60 Entere
+I FLSD Docket 02/2
+009 Page 2 of 8
+part of the events or omissions giving rise to the claim occurred in this District.
+Factual Allegations
+7.
+At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52
+years old. Epstein is a financier and money manager with a secret clientele limited exclusively to
+billionaires. He is himself a man of tremendous wealth, power and influence. He maintains his
+principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach,
+FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach.
+Upon information and belief, Epstein has a sexual preference and obsession for
+underage girls. He engaged in a plan and scheme in which he gained access to primarily
+economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave
+them money. In or about 2002-2003, Jane Doe, then approximately 15-16 years old, fell into
+Epstein's trap and became one of his victims.
+9.
+Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted
+girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas.
+10.
+Epstein's scheme involved the use of young girls to recruit underage girls. These
+underage girls were recruited ostensibly to give a wealthy man a massage for monetary
+compensation in his Palm Beach mansion. The girls would be contacted when Epstein was planning
+to be at his Palm Beach residence or soon after he had arrived there. Upon information and belief,
+Epstein generally sought out economically disadvantaged underage girls from western Palm Beach
+County who would be enticed by the money being offered - generally $200 to $300 per "massage"
+session - and who were perceived as less likely to complain to authorities or have credibility if
+allegations of improper conduct were made. This was an important element of Epstein's plan.
+11.
+Epstein's plan and scheme reflected a particular pattern and method. The underage
+- 2-
+
+
+'Case 9:08 cv-1
+31-KAM Document 60 Entered
+1 FLSD Docket 02/2
+309 Page 3 of 8
+victim would be brought to the kitchen entrance of Epstein's mansion, where she would be
+introduced to
+Epstein's assistant. Ms.
+would then bring the girl up a flight of
+stairs to a room that contained a massage table in addition to other furnishings, and a bathroom.
+The girl would then find herself alone in the room with Epstein, who would be wearing only a towel.
+He would then remove his towel and lie naked on the massage table, and direct the girl to remove
+her clothes. Epstein would then perform one or more lewd, lascivious and sexual acts, including
+masturbation a
+12. Consistent with the foregoing plan and scheme, when Jane Doe was approximately
+15-16 years old, she was recruited to give Epstein a massage for monetary compensation. Jane and
+another girl were brought to Epstein's mansion in Palm Beach, to the kitchen entrance. Once there,
+they were introduced to
+who led them up the flight of stairs to the room with the
+massage table. Jane and the other girl were directed by Epstein to remove their clothes and give
+him a massage. Jane and the other girl removed their clothes except for their panties and bras, and
+complied with Epstein's instructions. While on the massage table,
+himself
+and touched both girls on their
+and 1
+13.
+After Epstein had completed the sexual assault, both girls were then able to get
+dressed, leave the room and go back down the stairs. Epstein gave both girls money for this
+"massage."
+14.
+As a result of this encounter with Epstein, Jane experienced confusion, shame,
+humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
+COUNT I
+Sexual Assault and Battery
+- 3-
+
+
+'Case 9:08-cv-{
+31-KAM Document 60 Enterel
+1 FLSD Docket 02/2
+009 Page 4 of 8
+15.
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+16.
+Epstein acted with intent to cause an offensive contact with Jane Doe, or an imminent
+apprehension of such a contact, and Jane Doe was thereby put in such imminent apprehension.
+17.
+Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane
+Doe, creating a reasonable fear of imminent peril.
+Epstein intentionally inflicted harmful or offensive contact on the person of Jane Doe,
+with the intent to cause such contact or the apprehension that such contact is imminent.
+19.
+Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein's acts
+were intentional, unlawful, offensive and harmful.
+20.
+Epstein's plan and scheme in which he committed such acts upon Jane Doe were
+done willfully and maliciously.
+21.
+As a direct and proximate result of Epstein's assault on Jane, she has suffered and
+will continue to suffer severe and permanent traumatic injuries, including mental, psychological and
+emotional damages.
+WHEREFORE, Plaintiff Jane Doe No. 4 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this
+Court deems just and proper.
+22.
+23.
+COUNT II
+Intentional Infliction of Emotional Distress
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+Epstein's conduct was intentional or reckless.
+24.
+Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds
+of decency.
+-4-
+
+
+'Case 9:08-cv-f
+Document 60
+• FLSD Docket 02/2
+109 Page 5 of 8
+25.
+Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted
+in mental or sexual injury to Jane Doe, that caused or were likely to cause Jane Doe's mental or
+emotional health to be significantly impaired.
+26.
+Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had
+reason to know that his intentional and outrageous conduct would cause emotional distress and
+damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing
+severe emotional distress to Jane Doe.
+27.
+As a direct and proximate result of Epstein's intentional or reckless-conduct, Jane
+Doe, has suffered and will continue to suffer severe mental anguish and pain.
+WHEREFORE, Plaintiff Jane Doe No. 5 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this
+Court deems just and proper.
+COUNT III
+Coercion and Enticement to Sexual Activity in Violation of 18
+. §2422
+28.
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+29. Epstein used a facility or means of interstate commerce to knowingly persuade,
+induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or
+sexual activity for which any person can be charged with a criminal offense.
+30.
+On June 30, 2008, Epstein entered a plea of guilty to violations of Florida §§ 796.07
+and 796.03, in the 15th Judicial Circuit in and for Palm Beach County (Case nos. 2008-cf-
+009381AXXXMB and 2006-cf-009454AXXXMB), for conduct involving the same plan and
+scheme as alleged herein.
+31.
+As to Plaintiff Jane Doe, Epstein could have been charged with criminal violations of
+- 5-
+
+
+Case 9:08-cv-{
+31-KAM Document 60 Enteres
+FLSD Docket 02/2
+309 Page 6 of 8
+Florida Statute §796.07(2) (including subsections (I), (d), (e), (f), (g), and (h) thereof), and other
+criminal offenses including violations of Florida Statutes §§ 798.02 and 800.04 (including
+subsections (5), (6) and (7) thereof).
+32.
+Epstein's acts and conduct are in violation of 18
+. 82422.
+. §2422, Plaintiff has suffered personal
+33.
+As a result of Epstein's violation of 18
+injury, including mental, psychological and emotional damages.
+34.
+Plaintiff hired Herman & Mermelstein, P.A., in this matter and agreed to pay them a
+reasonable attorneys' fee.
+WHEREFORE, Plaintiff Jane Doe No. 5 demands judgment against Defendant Jeffrey
+Epstein for all damages available under 18
+§2255(a), including without limitation, actual
+and compensatory damages, costs of suit, and attorneys' fees, and such other and further relief as
+this Court deems just and proper.
+JURY TRIAL DEMAND
+Plaintiff demands a jury trial in this action on all claims so triable.
+Dated: February 27, 2009
+Respectfully submitted,
+By:-
+Adam D. Horowitz (FL. Bar No. 376980)
+MERMELSTEIN & HOROWITZ, P.A.
+Horneys for Plaintif
+8205 Biscayne Blvd., Suite 221
+Miami, Florida 33160
+Tel:
+Fax:
+- 6-
+
+
+Case 9:08-cv-í
+Document 60 Enterel
+1 FLSD Docket 02/2
+109 Page 7 of 8
+CERTIFICATE OF SERVICE
+I hereby certify that on February 27, 2009, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day to all parties on the attached Service List in the manner specified, either via transmission of
+Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those
+parties who are not authorized to receive electronically Notices of Electronic Filing.
+/sl Adam D. Horowitz.
+- 7-
+
+
+Case 9:08-cv-1
+31-KAM Document 60
+Entere
+I FLSD Docket 02/2
+109 Page 8 of 8
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+Robert D. Critton, Esq.
+Is/ Adam D. Horowitz_
+- 8 -
+
+
+11-KAM Document 71
+FLSD Docket 04
+009 Page 1 of 7
+CASE NO.: 08-CV-80381-MARRA-JOHNSON
+JANE DOE NO. 5
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT EPSTEIN'S ANSWER & AFFIRMATIVE
+DEFENSES TO PLAINTIFF'S SECOND AMENDED COMPLAINT
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his
+undersigned attorneys, files his Answer to the Second Amended Complaint and states:
+1. Without knowledge and deny.
+2. As to the allegations in paragraphs 2, Defendant asserts his Fifth Amendment
+privilege against self-incrimination. See DeLisi |. Bankers Ins. Company, 436 So.2d
+1099 (Fla. 4' DCA 1983); Malloy |. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth
+Amendment's Self-Incrimination Clause applies to the states through the Due Process
+Clause of the Fourteenth Amendment - "filt would be incongruous to have different
+standards determine the validity of a claim of privilege based on the same feared
+prosecution, depending on whether the claim was asserted in state or federal court."); 5
+Fed.Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-
+Incrimination ("...court must treat the defendant's claim of privilege as equivalent to a
+specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. -
+"... a civil defendant who raises an affirmative defense is not precluded from asserting
+
+
+Document 71
+FLSD Docket 041
+009 Page 2 of 7
+Jane Doe No. 5 M Epstein
+Page 2
+the privilege [against self-incrimination], because affirmative defenses do not constitute
+the kind of voluntary application for affirmative relief" which would prevent a plaintiff
+bringing a claim seeking affirmative relief from asserting the privilege.
+3. As to the allegations in paragraph 3, deny.
+4. As to the allegations in paragraph 4, deny.
+5. As to the allegations in paragraph 5, without knowledge and deny.
+6. As to the allegations in paragraphs 6, Defendant asserts his Fifth Amendment
+privilege against self-incrimination. See DeLisi | Bankers Ins. Company, 436 So.2d
+1099 (Fla. 4* DCA 1983); Malloy | Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth
+Amendment's Self-Incrimination Clause applies to the states through the Due Process
+Clause of the Fourteenth Amendment - "[ilt would be incongruous to have different
+standards determine the validity of a claim of privilege based on the same feared
+prosecution, depending on whether the claim was asserted in state or federal court."); 5
+Fed.Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-
+Incrimination ("...court must treat the defendant's claim of privilege as equivalent to a
+specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. -
+"... a civil defendant who raises an affirmative defense is not precluded from asserting
+the privilege [against self-incrimination], because affirmative defenses do not constitute
+the kind of voluntary application for affirmative relief" which would prevent a plaintiff
+bringing a claim seeking affirmative rellef from asserting the privilege.
+7. As to the allegations in paragraphs 7 through 14 of Plaintiff's Second Amended
+Complaint,
+Defendant exercises his Fifth Amendment Privilege against self-
+
+
+Document 71 Entered
+FLSD Docket 04
+009 Page 3 of 7
+Jane Doe No. 5 | Epstein
+Page 3
+incrimination. See DeLisi |. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4" DCA
+1983); Malloy |. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-
+Incrimination Clause applies to the states through the Due Process Clause of the
+Fourteenth Amendment - "[ilt would be incongruous to have different standards
+determine the validity of a claim of privilege based on the same feared prosecution,
+depending on whether the claim was asserted in state or federal court."); 5 Fed.Prac. &
+Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-Incrimination
+("...court must treat the defendant's claim of privilege as equivalent to a specific
+denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. - "... a civil
+defendant who raises an affirmative defense is not precluded from asserting the
+privilege [against self-incrimination], because affirmative defenses do not constitute the
+kind of voluntary application for affirmative relief" which would prevent a plaintiff bringing
+a claim seeking affirmative relief from asserting the privilege.
+8. In response to the allegations of paragraph 15, Defendant realleges and adopts
+his responses to paragraphs 1 through 14 of the Second Amended Complaint set forth
+in paragraphs 1 through 6 above herein.
+9. Defendant asserts the Fifth Amendment Privilege against self-incrimination to
+the allegations set forth in paragraphs 16 through 21 of the Second Amended
+Complaint. See DeLisi |. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4" DCA 1983);
+Malloy |. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination
+Clause applies to the states through the Due Process Clause of the Fourteenth
+Amendment - "[ilt would be incongruous to have different standards determine the
+
+
+Casé 9:08-CV-8
+11-KAM Document 71 Entered FLSD Docket 04/ 009 Page 4 of 7
+Jane Doe No. 5 V Epstein
+Page 4
+validity of a claim of privilege based on the same feared prosecution, depending on
+whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d
+§1280 Effect of Failure to Deny - Privilege Against Self-Incrimination ("...court must
+treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24
+Fla.Jur.2d Evidence §592. Defendants in civil actions. - "... a civil defendant who raises
+an affirmative defense is not precluded from asserting the privilege [against selfincrimination], because affirmative defenses do not constitute the kind of voluntary
+application for affirmative relief" which would prevent a plaintiff bringing a claim seeking
+affirmative relief from asserting the privilege.
+10. In response to the allegations of paragraph 22, Defendant realleges and adopts
+his responses to paragraphs 1 through 14 of the Second Amended Complaint set forth
+in paragraphs 1 through 6 above herein.
+11. Defendant asserts the Fifth Amendment Privilege against self-incrimination to
+the allegations set forth in paragraphs 23 through 27 of the Second Amended
+Complaint. See DeLisi |, Bankers Ins. Company, 436 So.2d 1099 (Fla. 4" DCA 1983);
+Malloy | Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination
+Clause applies to the states through the Due Process Clause of the Fourteenth
+Amendment - "It would be incongruous to have different standards determine the
+validity of a claim of privilege based on the same feared prosecution, depending on
+whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d
+§1280 Effect of Failure to Deny - Privilege Against Self-Incrimination ("...court must
+treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24
+
+
+Document 71 Entered
+FLSD Docket 04/ 009 Page 5 of 7
+Jane Doe No. 5 y Epstein
+Page 5
+Fla.Jur.2d Evidence §592. Defendants in civil actions. - "... a civil defendant who raises
+an affirmative defense is not precluded from asserting the privilege [against selfincrimination], because affirmative defenses do not constitute the kind of voluntary
+application for affirmative relief' which would prevent a plaintiff bringing a claim seeking
+affirmative relief from asserting the privilege.
+12. In response to the allegations of paragraph 28, Defendant realleges and adopts
+his responses to paragraphs 1 through 14 of the Second Amended Complaint set forth
+in paragraphs 1 through 6 above herein.
+13. Defendant asserts the Fifth Amendment Privilege against self-incrimination to
+the allegations set forth in paragraphs 29 through 34 of the Second Amended
+Complaint. See DeLisi | Bankers Ins. Company, 436 So.2d 1099 (Fla. 4" DCA 1983);
+Malloy | Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination
+Clause applies to the states through the Due Process Clause of the Fourteenth
+Amendment - "Tilt would be incongruous to have different standards determine the
+validity of a claim of privilege based on the same feared prosecution, depending on
+whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d
+§1280 Effect of Failure to Deny - Privilege Against Self-Incrimination ("...court must
+treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24
+Fla.Jur.2d Evidence §592. Defendants in civil actions. - "... a civil defendant who raises
+an affirmative defense is not precluded from asserting the privilege [against selfincrimination], because affirmative defenses do not constitute the kind of voluntary
+
+
+11-KAM Document 71. Entered
+FLSD Docket 041l
+009 Page 6 of 7
+Jane Doe No. 5 / Epstein
+Page 6
+application for affirmative relief" which would prevent a plaintiff bringing a claim seeking
+affirmative relief from asserting the privilege.
+WHEREFORE, Defendant requests that this Court deny the relief sought by Plaintiff.
+Affirmative Defenses
+1. As to all counts, Plaintiff consented to and was a willing participant in the acts
+alleged.
+2. As to all counts alleged, Plaintiff consented to and participated in conduct similar
+and/or identical to the acts alleged with other persons which were the sole or
+contributing cause of Plaintiff's alleged damages
+3. As to all counts, Defendant reasonably believed that the Plaintiff had attained the
+age of 18 years old at the time of the alleged acts.
+4. Plaintiff's claims are barred by the applicable statute of limitations.
+WHEREFORE Defendant requests that this Court deny the relief sought by Plaintiff.
+Robert D. Critton, Jr.
+Attorney for/Defendant Epstein
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+he Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this L day of April, 2009:
+
+
+Casé 9:08-cv-& 11-KAM Document 71
+FLSD Docket 04
+009 Page 7 of 7
+Page Doo No. 5 I Epstin
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami. FL 33160
+Fax:
+Counsel for Plaintiff Jane Doe #5
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+Fax:
+Co-Counsel for Defendant Jeffrey Epstein
+Respectfully submitted,
+ROBERT D. CRITTON, JR., ESO.
+Florida Bar No. 224162
+crit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+Phone
+Fax
+
+
+Case 9:08 cv-.-381-KAM Documen.
+Enteré. un FLSD Docket 10/06..
+
+CASE NO.: 08-CV-80381-MARRA-JOHNSON
+JANE DOE NO. 5
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+Defendant, JEFFERY EPSTEIN, by and through his undersigned counsel, moves
+to dismiss and for more definite statement of Plaintiff JANE DOE NO. 5's Amended
+Complaint. Rules 12(b)(6), and 12(e) and (f), Fed.R.Civ.P. (2008). In support of his
+motion, Defendant states:
+Introduction
+Defendant is filing similar motions to dismiss and for more definite statement
+directed to the Amended Complaints filed against Defendant in this Court in JANE DOE
+NO. 2, JANE DOE NO. 3, JANE DOE NO. 4 and JANE DOE NO. 5. The motions are
+directed to the Counts for "Sexual Assault and Battery," and "Coercion and Enticement
+to Sexual Activity in Violation of 18
+- §2422" in each of the respective complaints.
+However, there are distinctions in the four motions filed based on the complaint
+allegations. For example, Defendant challenges the Plaintiffs' allegations as to assault
+in all four actions, and challenges the battery allegations in JANE DOE NOS. 2 and 3,
+but not in JANE DOE NOS. 4 and 5. Defendant moves to dismiss the §2422 count in all
+four actions.
+
+
+Case 9:08-1/--v381-KAM Documen. --
+Page No. 2
+Entere. un FLSD Docket 10/06._-v8 Page 2 of 10
+Motion
+1. Counts 1 and III of the Amended Complaint are required to be dismissed for
+failure to state a claim upon which relief can be granted. Rule 12(b)(6). Plaintiff has
+failed to allege sufficient factual allegations in the Counts and instead alleges labels and
+conclusions, and an attempted formulaic recitation of the elements in each Count.
+2. In the alternative, Defendant seeks more definite statement of Count I and Ill. In
+Count I, the Plaintiff is required to more definitely allege in the context of the claim for
+assault underlying factual allegations pertaining to the creation in Plaintiff of "imminent
+fear of peril;"; what EPSTEIN said and did, if anything, to create fear and apprehension
+in Plaintiff. In Count III, Plaintiff is required to more definitely state the underlying factual
+allegations to support her claim as set forth in the statute, 18
+§2422(b) and
+§2455. Rule 12(e). See discussion of law below herein.
+3. Also, Plaintiff's reference in Count III to 28
+. §2255, pertaining to habeas
+corpus proceedings is required to be stricken as immaterial. Rule 12(f). Plaintiff is
+required to more definitely state what statutory provision she is relying on. Rule 12 (e).
+WHEREFORE, Defendant respectfully requests that this Court dismiss Counts I and
+li, strike the immaterial statutory reference, and require Plaintiff to more definitely plead
+the underlying elements of her claims.
+Supporting Memorandum of Lav
+standard on Rule 12(b)(6) Motion To Dismiss
+As established by the Supreme Court in Bell Atlantic Corp. Twombly, 127
+S.Ct. 1955 (2007), a motion to dismiss should be granted if the plaintiff does not plead
+"enough facts to state a claim to relief that is plausible on its face." Id, at 1974.
+Although the complaint need not provide detailed factual allegations, the basis for relief
+
+
+Case 9:08-cv-v381-KAM Documen. --
+Entere. un FLSD Docket 10/06-. v8
+
+Page No. 3
+in the complaint must state "more than labels and conclusions, and a formulaic
+recitation of the elements of a cause of action will not do." Id, at 1965. Further, "factual
+allegations must be enough to raise a right to relief above the speculative level ... on the
+assumption that all the allegations in the complaint are true (even if doubtful in fact)." Id.
+On a motion to dismiss, the well pleaded allegations of plaintiff's complaint are taken as
+true and construed in the light most favorable to the plaintiff.
+I DeKalb County
+Sch. Dist., 446 F.3d 1153, 1156 (11th Cir.2006).
+Significantly, the Supreme Court in Bell Atlantic Corp.. Twombly abrogated the
+often cited observation that "a complaint should not be dismissed for failure to state a
+claim unless it appears beyond doubt that the plaintiff can prove not set of facts in
+support of his claim that would entitle him to relief." Id, (abrogating and quoting Conley
+• Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)). The Supreme
+Court rejected the notion that "a wholly conclusory statement of claim [can] survive a
+motion to dismiss whenever the pleadings le[ave] open the possibility that a plaintiff
+might later establish some 'set of [undisclosed] facts' to support recovery." Id. As
+explained by the Supreme Court in Bell Atlantic Corp., supra at 1664-65:
+While a complaint attacked by a Rule 12(b)(6) motion to dismiss does not
+need detailed factual allegations, ibid.; Sanjuan.
+American Bd. of
+Psychiatry and Neurology, Inc., 40 F.3a 247, 251 (
+.7 1994), a plaintiff's
+obligation to provide the "grounds" of his "entitle[ment] to relief" requires
+more inan labels and conclusions, and a tormulaic recitation of the elements
+ot a cause of action will not do, see Papasan . Allain, 478 U.S. 265, 286
+106 S.Ct. 2932, 92 L.Ed.2d 209 (1986) (on a motion to dismiss, courts "are
+not bound to accept as true a legal conclusion couched as a factual
+allegation"). Factual allegations must be enough to raise a right to relief
+above the speculative level, see 5]
+. Wright & A. Miller, Federal Practice and
+Procedure § 1216, pp. 235-236 (3d ed.2004) (hereinafter Wright & Miller)
+("IT]he pleading must contain something more ... than ... a statement of facts
+that merely creates a suspicion [of] a legally cognizable right of action"), on
+the assumption that all the allegations in the complaint are true (even if
+
+
+Case 9:08-cv-vu381-KAM Documen. --
+Entere. un FLSD Docket 10/06 ...d
+
+Page No. 4
+doubtful in fact), see, e.g., Swierkiewicz|: Sorema N. A., 534 U.S. 506, 508,
+n. 1, 122 S.Ct. 992, 152 L.Ed.2d 1 (2002); Neitzke |. Williams, 490 U.S. 319,
+321, 109 S.Ct. 1827, 104 L.Ed.2d 338 (1989) (" Rule 12(b)(6) does not
+40 L.Ed.2d 90 (1974) (a well-pleaded complaint may proceed even if it
+appears "that a recovery is very remote and unlikely").
+Pursuant to Rule 12(e), a party may move for more definite statement of a
+pleading to which a responsive pleading is allowed where the pleading "is so vague or
+ambiguous that the party cannot reasonably frame a response." The motion is required
+to point out the defects and the desired details. Id.
+Count I - "Sexual Assault and Battery" is subject to dismissal as Plaintiff has
+failed to state a claim upon which relief can be granted.
+It is well settled that this Court is to apply Florida substantive law in this action.
+Erie R.Co. |. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, although the term
+"assault and battery" is most commonly referred to as if it were a legal unit, or a single
+concept, "assault and battery are separate and distinct legal concepts, assault being the
+beginning of an act which, if consummated, constitutes battery." 3A Fla.Jur.2d Assault
+§1. An assault and battery are intentional acts. See generally, Spivey |. Battaglia, 258
+So.2d 815 (Fla. 1972); and Travelers Indem. Co. . PCR, Inc., 889 So.2d 779 (Fla.
+2004).
+An "assault" is an intentional, unlawful offer of corporal injury to another by force,
+or exertion of force directed toward another under such circumstances as to create a
+reasonable fear of imminent peril. See Lay |. Kremer, 411 So.2d 1347 (Fla. 1st DCA
+1982). It must be premised upon an affirmative act - a threat to use force, or the actual
+exertion of force.
+See 3A Fla.Jur.2d Assault §1("The essential element of the tort of
+assault is the violence offered, and not actual physical contact.").
+
+
+Case 9:08-cv--.381-KAM Documen. ..
+Page No. 5
+Entere.. un FLSD Docket 10/06.... -8
+
+As further explained in Florida Jurisprudence, 2d, Assault §1 -
+An assault is defined as an intentional unlawful offer of corporal
+injury to another by force, or force unlawfully directed toward the person of
+another, under circumstances as to create a fear of imminent peril,
+coupled with the apparent present ability to effectuate the attempt. At
+common law, a tortious assault is an act that puts another in reasonable
+apprehension of immediate bodily harm.
+In 112 of her Amended Complaint, Plaintiff does plead the requisite
+"touching" element of "battery," so that aspect of the assault and battery claim is not
+being challenged. With the standard of pleading established in Iwombly, supra, in the
+context of assault, Plaintiff has failed to state a claim upon which relief can be granted.
+Rule 12(b)(6). As to the elements of assault, there are no factual allegations as to what
+was said or done to Plaintiff such that it constituted an "intentional, unlawful offer of
+corporal injury to another by force, or exertion of force directed toward another under
+such circumstances as to create a reasonable fear of imminent peril." See 912-13 of
+Am. Comp. In 113 alleges that JANE DOE NO. 5 (and another unidentified girl) "were
+then able to get dressed, leave the room and go back downstairs. Esptein gave both
+girls money for this 'massage." Allegations as to circumstances creating a fear of
+imminent peril are lacking.
+Under applicable law, Plaintiff is required to give more than labels and
+conclusions, and a formulaic recitation of the elements of a cause of action. Iwombly.
+supra. Plaintiff is required to allege the facts of what was done to her; what EPSTEIN
+said and did, if anything, to create fear and apprehension in Plaintiff.
+As noted in the introduction and as this Court is well aware, there is more than
+one action brought against this Defendant attempting to allege similar sounding claims.
+With all due respect, the details as to a particular claim asserted by a particular Plaintiff
+
+
+Case 9:08-cv-
+-381-KAM Documen
+Entere
+. un FLSD Docket 10/06.
+,8 Page 6 of 10
+Page No. 6
+are important to give this Defendant fair notice of Plaintiff's claim so he may properly
+respond. Accordingly, under applicable law, Plaintiff has failed to state a claim for
+"sexual assault and battery" has Plaintiff has failed to plead requisite factual allegations
+concerning the assault.
+In the alternative to dismissing Count I, Defendant requests that Plaintiff be
+required to give more definite statement as to what was done to her; what EPSTEIN
+said and did, if anything, to create fear and apprehension in Plaintiff; in pleading the
+elements of assault. Rule 12(e).
+Gount II! - "Coercion and Enticement to Sexual Activity in Violation of 18
+. $2422" - is subject to dismissal as Plaintiff has failed to state a claim
+upon which relief can be granted, Rule 12(b)(6). Count Ill also contains an
+immaterial reference to 28]
+. §2255, which is required to be stricken
+and more definitely stated.
+Count III of Plaintiff's Complaint attempts to assert a claim for "Coercion and
+Enticement to Sexual Activity in Violation of 18
+i. S2422." In her prayer for relief in
+Count III, Plaintiff "demands judgment against Defendant Jeffrey Epstein for all
+damages available under 28
+. §2255(a),...."
+Although the reference to "28
+§2255," pertaining to habeas corpus
+proceedings - federal custody and remedies on motion attacking sentence, is probably
+a typographical error by Plaintiff, and the reference to "28" was meant to be "18,"
+Defendant requests that Plaintiff correct this error so that Defendant may have fair
+notice of the claim Plaintiff is attempting to assert. Whether or not the "28" is
+typographical error, Defendant is still entitled to dismissal of the count.
+The applicable version of these statutory provisions, (pre-2006 Amendments, as
+the Amended Complaint alleges a time period of "in or about 2002-2003," 18), provides:
+
+
+Case 9:08-Cv .381-KAM Documen... Entere. un FLSD Docket 10/06,... 8
+Page No. 7
+CHAPTER 117-TRANSPORTATION FOR ILLEGAL SEXUAL ACTIVITY
+AND RELATED CRIMES
+§ 2422. Coercion and enticement
+(a) Whoever knowingly persuades, induces, entices, or coerces any
+ndividual to travel in interstate or foreign commerce, or in any Territory o
+'ossession of the United States, to engage in prostitution, or in any sexua
+activity for which any person can be charged with a criminal offense, or
+attempts to do so, shall be fined under this title or imprisoned not more than
+20 years, or both.
+(b) Whoever, using the mail or any facility or means of interstate or foreign
+commerce, or within the special maritime and territorial jurisdiction of the
+United States knowingly persuades, induces, entices, or coerces any
+ndividual who has not attained the age of 18 years, to engage in prostitutior
+or any sexual activity for which any person can be charged with a crimina
+ontense, or attempts to do so
+not less than 5 years and not more than 30y under this title and imprisoned
+CHAPTER 110-SEXUAL EXPLOITATION AND OTHER ABUSE OF
+CHILDREN
+§ 2255. Civil remedy for personal injuries
+(a) Any minor who is a victim of a violation of section 2241g), 2242, 2243,
+2251, 2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who
+suffers personal injury as a result of such violation may sue in any
+appropriate United States District Court and shall recover the actual
+damages such minor sustains and the cost of the suit, including a reasonable
+attorney's tee. Any minor as described in the preceding sentence shall be
+deemed to have sustained damages of no less than $50,000 in value.
+(D) Any action commenced under this section shall be barred unless the
+complaint is filed within six years after the right of action first accrues or in
+'The above-quoted version of 18)
+• §2422 is the post-2003 amendments which
+amended the statute as follows:
+2003 Amendments. Subsec. (a). Pub.L. 108-21, § 103(a)(2)(A), struck out "10"
+and inserted "20".
+Subsec. (b). Pub.L. 108-21, § 103(a)(2)(B), struck out "15" and inserted "30".
+Pub.L. 108-21, § 103(b)(2)(A)(i), struck out", imprisoned" and inserted "and
+imprisoned not less than 5 years and".
+Pub.L. 108-21, § 103(b)(2)(A)(ii), struck out ", or both" at end of subsec. (b).
+Defendant is not waiving his right to claim that the pre-2003 amended version of the
+statute is applicable in this action. However, for purposes of this motion, the relevant
+statutory language is the same.
+
+
+
+Case 9:08-Cv--381-KAM Documer. Documer... Entere.. un LSD Docket 10/06....8 Page 8 of 10
+Page No. 8
+the case of a person under a legal disability, not later than three years after
+the disability.
+Relevant to Plaintiff's complaint, 18
+. 2255(a) creates a civil remedy for "a
+minor who is a victim of a violation of section ... 2422 ... of this title and who suffers
+personal injury as a result of such violation ...." Plaintiff has failed to plead any factual
+allegations whatsoever pertaining to violations of 18
+f. 2422. Rather, Plaintiff has
+alleged conclusory allegations simply attempting to track parts of the statutory language
+in the statute without underlying factual allegations pertaining to the Plaintiff and any
+conduct by Defendant. See 129 of Am. Comp. Plaintiff's allegations, (or lack of factual
+allegations), are precisely what the standard set forth by the Supreme Court in Bell
+Atlantic Corp. prohibits - Plaintiff's complaint alleges only "labels and conclusions, and
+a (partial) formulaic recitation of the elements."
+First, the Amended Complaint fails to designate whether Plaintiff is relying on
+§2422 (a) or §2422(b). Second, although the complaint does contain a partial tracking of
+the language in 18
+• §2422(b), it contains absolutely no factual allegations
+concerning the requisite "using the mail or any facility or means of interstate or foreign
+commerce" by Plaintiff to state a cause of action based on a violation of 18l
+2422(b). As well, there are no underlying factual allegations involving this Plaintiff as to
+the requisite elements that a defendant knowingly persuaded, induced, enticed, or
+coerced any individual (Plaintiff in this case) who has not attained the age of 18 years,
+to engage in prostitution or any sexual activity for which any person can be charged with
+a criminal offense, or attempted to do so. See 18
+1. 2422(b); i.e. with what criminal
+offense could Plaintiff and Defendant have been charged. Again, a Plaintiff cannot
+simply track the language of a statute without some underlying factual allegations to
+
+
+Case 9:08-cv-
+..381-KAM Documen.
+Entere. on FLSD Docket 10/06..
+8 Page 9 of 10
+Page No. 9
+state a claim upon which relief can be granted. Accordingly, Count Ill is required to be
+dismissed, and the reference to 28 USC 2455 be stricken.
+In the alternative, Plaintiff should be required to more definitely state the
+underlying factual allegations to support her claim as set forth in the statute, 18|
+§2422(b) and §2455.
+Conclusion
+As discussed above herein, under the pleading standard established in Twombly,
+supra, and law concerning the elements of Count | and III, Plaintiff has failed to state
+claims upon which relief can be granted. Rule 12(b)(6). Plaintiff's complaint lack
+underlying factual allegations and, thus, Plaintiff is required to more definitely state the
+requisite factual allegations. Finally, Plaintiff should correct any improper statutory
+references.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this 6" day of October, 2008:
+Adam D. Horowitz, Esq.
+Jack Alan Goldberger, Esq.
+Jeffrey Marc Herman, Esq.
+Atterbury Goldberger & Weiss, P.A.
+Stuart S. Mermelstein, Esq.
+250 Australian Avenue South
+18205 Biscayne Boulevard
+Suite 1400
+Suite 2218
+West Palm Beach, FL 33401-5012
+Miami. FL 33160
+Fax:
+Fax:
+Counsel for Defendant Jeffrey Epstein
+Counsel for Plaintiff Jane Doe #5
+
+
+Case 9:08-Cv-i
+..381-KAM Documeni
+Page No. 10
+Enterel -1 FLSD Docket 10/06/...S Page 10 of 10
+Michael R. Tein, Esq.
+Lewis Tein, P.L.
+3059 Grand Avenue, Suite 340
+Coconut Grove, FL 33133
+Fax:
+Counsel for Defendant Jeffrey Epstein
+Respectfully submitted,
+ROBERT D. CRITTON, JR., ESQ.
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+• Phone
+• Fax
+
+
+Case 9:08-cv. 381-KAM Documen...
+Entert
+on FLSD Docket 09/22.
+.--J8
+
+CASE NO.: 08-80381-CIV-MARRA/JOHNSON
+JANE DOE NO. 5,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+AMENDED COMPLAINT
+Plaintiff, Jane Doe No. 5 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey
+Epstein, as follows:
+1.
+Parties, Jurisdiction and Venue
+Jane Doe No. 5 is a citizen and resident of the Commonwealth of Virginia, and is sui
+• juris.
+This Complaint is brought under a fictitious name to protect the identity of the
+Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a
+minor.
+Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
+This is an action for damages in excess of $50 million.
+5.
+This Court has jurisdiction of this action and the claims set forth herein pursuant to 28
+§1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs;
+and (ii) is between citizens of different states.
+6.
+This Court has venue of this action pursuant to 28
+• §1391(a) as a substantial
+www.hermanlaw.com
+- 1-
+
+
+Case 9:08- ~ 1381-KAM
+Documer....
+Enter on FLSD Docket 09/22.
+.-J8 Page 2 of 8
+part of the events or omissions giving rise to the claim occurred in this District.
+Factual Allegations
+At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52
+years old. Epstein is a financier and money manager with a secret clientele limited exclusively to
+billionaires. He is himself a man of tremendous wealth, power and influence. He maintains his
+principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach,
+FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach.
+8.
+Upon information and belief, Epstein has a sexual preference and obsession for
+underage girls. He engaged in a plan and scheme in which he gained access to primarily
+economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave
+them money. In or about 2002-2003, Jane Doe, then approximately 15-16 years old, fell into
+Epstein's trap and became one of his victims.
+9.
+Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted
+girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas.
+10.
+Epstein's scheme involved the use of young girls to recruit underage girls. These
+underage girls were recruited ostensibly to give a wealthy man a massage for monetary
+compensation in his Palm Beach mansion. The girls would be contacted when Epstein was planning
+to be at his Palm Beach residence or soon after he had arrived there. Upon information and belief,
+Epstein generally sought out economically disadvantaged underage girls from western Palm Beach
+County who would be enticed by the money being offered - generally $200 to $300 per "massage"
+session - and who were perceived as less likely to complain to authorities or have credibility if
+allegations of improper conduct were made. This was an important element of Epstein's plan.
+11.
+Epstein's plan and scheme reflected a particular pattern and method. The underage
+Herman & Mermelstein, P. A.
+- 2-
+
+
+Case 9:08-Cv.-381-KAM Documen. ..
+Entert.. on FLSD Docket 09/22... 8 Page 3 of 8
+victim would be brought to the kitchen entrance of Epstein's mansion, where she would be
+introduced to
+Epstein's assistant. Ms.
+I would then bring the girl up a flight of
+stairs to a room that contained a massage table in addition to other furnishings, and a bathroom.
+The girl would then find herself alone in the room with Epstein, who would be wearing only a towel.
+He would then remove his towel and lie naked on the massage table, and direct the girl to remove
+her clothes. Epstein would then perform one or more lewd, lascivious and sexual acts, including
+and
+12.
+Consistent with the foregoing plan and scheme, when Jane Doe was approximately
+15-16 years old, she was recruited to give Epstein a massage for monetary compensation. Jane and
+another girl were brought to Epstein's mansion in Palm Beach, to the kitchen entrance. Once there,
+they were introduced to
+who led them up the flight of stairs to the room with the
+massage table.
+Jane and the other girl were directed by Epstein to remove their clothes and give
+him a massage. Jane and the other girl removed their clothes except for their panties and bras, and
+complied with Epstein's instructions. While on the massage table, Epstein
+and touched both girls on theirl
+and with a 1
+13. After Epstein had completed the sexual assault, both girls were then able to get
+dressed, leave the room and go back down the stairs. Epstein gave both girls money for this
+"massage."
+14.
+As a result of this encounter with Epstein, Jane experienced confusion, shame,
+humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
+COUNT I
+Sexual Assault and Battery
+- 3-
+
+
+Case 9:08-CV _J381-KAM Documer...
+Enter... on FLSD Docket 09/22.
+.-J8
+
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+16.
+Epstein acted with intent to cause an offensive contact with Jane Doe, or an imminent
+apprehension of such a contact, and Jane Doe was thereby put in such imminent apprehension.
+17.
+Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane
+Doe, creating a reasonable fear of imminent peril.
+18.
+Epstein intentionally inflicted harmful or offensive contact on the person of Jane Doe,
+with the intent to cause such contact or the apprehension that such contact is imminent.
+19.
+Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein's acts
+were intentional, unlawful, offensive and harmful.
+20.
+Epstein's plan and scheme in which he committed such acts upon Jane Doe were
+done willfully and maliciously.
+21.
+As a direct and proximate result of Epstein's assault on Jane, she has suffered and
+will continue to suffer severe and permanent traumatic injuries, including mental, psychological and
+emotional damages.
+WHEREFORE, Plaintiff Jane Doe No. 4 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this
+Court deems just and proper.
+22.
+23.
+COUNT II
+Intentional Infliction of Emotional Distress
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+Epstein's conduct was intentional or reckless.
+24.
+Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds
+of decency.
+- 4-
+
+
+Case 9:08-fv:- 381-KAM Documen. ..
+Entert... un FLSD Docket 09/22.
+...v8
+
+25.
+Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted
+in mental or sexual injury to Jane Doe, that caused or were likely to cause Jane Doe's mental or
+emotional health to be significantly impaired.
+26.
+Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had
+reason to know that his intentional and outrageous conduct would cause emotional distress and
+damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing
+severe emotional distress to Jane Doe.
+27.
+As a direct and proximate result of Epstein's intentional or reckless conduct, Jane
+Doe, has suffered and will continue to suffer severe mental anguish and pain.
+WHEREFORE, Plaintiff Jane Doe No. 5 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this
+Court deems just and proper.
+COUNT II
+Coercion and Enticement to Sexual Activity in Violation of 18]
+L. $2422
+28.
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+29. Epstein used a facility or means of interstate commerce to knowingly persuade,
+induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or
+sexual activity for which any person can be charged with a criminal offense.
+30.
+Epstein's acts and conduct are in violation of 18|
+§2422.
+. §2422, Plaintiff has suffered personal
+31.
+As a result of Epstein's violation of 18|
+injury, including mental, psychological and emotional damages.
+32.
+Plaintiff hired Herman & Mermelstein, P.A., in this matter and agreed to pay them a
+reasonable attorneys' fee.
+- 5-
+
+
+Case 9:08-CV -J381-KAM Documer.
+Entert. on FLSD Docket 09/22 _ 08 Page 6 of 8
+WHEREFORE, Plaintiff Jane Doe No. 5 demands judgment against Defendant Jeffrey
+Epstein for all damages available under 28
+§2255(a), including without limitation, actual
+and compensatory damages, costs of suit, and attorneys' fees, and such other and further relief as
+this Court deems just and proper.
+JURY TRIAL DEMAND
+Plaintiff demands a jury trial in this action on all claims so triable.
+Dated: September 22, 2008
+Respectfully submitted,
+By:_
+s/ Jeffrey M. Herman
+Jeffrey M. Herman (FL Bar No. 521647)
+Stuart S. Mermelstein (FL. Bar No. 947245)
+Adam D. Horowitz (FL Bar No. 376980)
+HERMAN & MERMELSTEIN, P.A.
+Attorneys for Plaintiff
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel:
+Fax:
+www.hermanlaw.com
+- 6-
+
+
+Case 9:08-fv
+- 381-KAM Documer. .
+Entert. un FLSD Docket 09/22.
+8 Page 7 of 8
+CERTIFICATE OF SERVICE
+I hereby certify that on September 22, 2008, I electronically filed the foregoing document
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day to all parties on the attached Service List in the manner specified, either via
+transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized
+manner for those parties who are not authorized to receive electronically Notices of Electronic
+Filing.
+Is/ Jeffrey M. Herman
+HerMAn & MerMelsteIn, P. A.
+- 7-
+-
+
+
+Case 9:08-cv
+. 1381-KAM Documer.
+Enteri
+on FLSD Docket 09/22.
+... 8 Page 8 of 8
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+CASE NO.: 08-CV-80380-MARRA/JOHNSON
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+Michael R. Tein, Esq.
+Robert D. Critton, Esg.
+Michael Pike, Esq.
+Is/ Jeffrey M. Herman
+- 8-
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/a9e004e0a4cdc891816a1ea84a130bc4f46f5cf23286f8bdcaaff4bc35876979.receipt.json b/vision-fixhub/ds9-unparsed-05/a9e004e0a4cdc891816a1ea84a130bc4f46f5cf23286f8bdcaaff4bc35876979.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..db0e866317ff7d7a3cb7e9ca049b8fe1b7a19c8a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a9e004e0a4cdc891816a1ea84a130bc4f46f5cf23286f8bdcaaff4bc35876979.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -2896,
+  "dataset": "marble-joined",
+  "doc_id": "a9e004e0a4cdc891816a1ea84a130bc4f46f5cf23286f8bdcaaff4bc35876979",
+  "engine": "marble-apple-vision",
+  "event_count": 84,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "86269889a6ad8714baeeb7a969635beff220eb742f86a2157e847b2fa5fccd4b",
+  "output_sha256": "be3df4e99944eda555a084c0daf5c3de7edaaec654a9ca4435536f6dad0d2032",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/a9f113472d2e829ee8b6d84ac71bcba4ded40280bb28c0d7fadbd2da9bbc1fbb.md b/vision-fixhub/ds9-unparsed-05/a9f113472d2e829ee8b6d84ac71bcba4ded40280bb28c0d7fadbd2da9bbc1fbb.md
new file mode 100644
index 0000000000000000000000000000000000000000..046baf56be9f5bfb35e7defd85ea4c4363bcbae9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a9f113472d2e829ee8b6d84ac71bcba4ded40280bb28c0d7fadbd2da9bbc1fbb.md
@@ -0,0 +1,121 @@
+MEETING TIMELINE
+P-009104
+
+
+
+JEFFREY EPSTEIN
+Timeline-Summary
+2/20/2007--Meeting (US:
+and Junior
+Ortiz, DEF: Lilly Sanchez and Gerald Lefcourt) .
+6/26/2007--Meeting (US:
+vittatana, Junior Ortiz,
+DEF: Alan
+Dershowitz, Roy Black, Gerald Lefcourt and Lilly Sanchez).
+• Defense argument--Travel has to be for "the" sole
+purpose of engaging
+in sexual activity not "a"
+purpose.
+Defense became aware of the Government's strategy to
+charge Epstein with Enticement in addition to the
+Traveling charges.
+7/26/2007--Meeting (US:
+"conference call), Valerie Parlave, Junior
+ortiz,
+• US Attorney's Office presented a State two-year
+incarceration plea agreement.
+7/31/2007--Meeting (US:
+DEF: Roy Black, Gerald Lefcourt and Lilly Sanchez) .
+• Defense stance was jail time was not an option.
+8/31/2002--Meeting (US:
+• Case briefing to DOJ representative.
+9/7/2007--Meeting (US:
+Alexander Acosta,
+John McMillan, DEF: Kenneth Starr, Jay
+Lefkowitz, Lilly Sanchez) .
+9/12/2007--Meeting (US:
+Vitatana, DEF:
+Jay Lefkowitz, Gerald Lefcourt and Jack
+Goldberger,
+STATE OF FLORIDA: Barry Krisher and Lanna
+Belohlavek).
+9/18/2007--Rescheduled date for computer hearing. (Hearing
+initially set for 9/13/2007).
+9/24/2007--Non-Prosecution Agreement signed.
+9/25/2007--Scheduled date for Federal Indictment.
+P-009105
+
+
+-.
+10/29/2007--Deadline date for Epstein's plea and sentencing
+according to Non-Prosecution Agreement.
+11/2007--USAO extends deadline for Epstein's plea and sentencing
+per request of Epstein's counsel.
+11/23/2007--Unscheduled meeting between Jay Lefkowitz, Alan
+Dershowitz and Jeff Sloman. (Drop in by Lefkowitz and
+Dershowitz) •
+01/04/2008--Scheduled date for Epstein's self surrender according
+to the Non-Prosecution Agreement.
+01/08/2008--Trial date set for State of Florida vs. Epstein.
+P-009106
+
+
+FEDERAL SENTENCING GUIDELINES CALCULATION
+(Using November 1, 2004 Guidelines Manual)
+Each count of §§ 1591, 2422(b) and 2423(b):
+Base Offense Level under 2G1.3:
+Offense involved sexual contact:
+24
++2
+26
+Counts do not group, so add 5 levels for more than 5 units, pursuant to 3D1.4
+Offense Level 31
+Apply Repeat and Dangerous Sex Offender against Minors enhancement at 4B1.5
+Total Offense Level 36
+Assuming Criminal History Category I, advisory guideline range is 188 - 235 months with
+lifetime supervised release.
+P-009107
+
+
+JEFFREY EPSTEIN
+Timeline-Summary
+2/20/2007--Meeting
+(US:
+Ortiz, DEF: Lilly Sanchez and Gerald Lefcourt) .
+a and Junior
+6/26/2007--Meeting (US: -
+ru, Junior Ortiz, Nesbitt Kuyrkendall, DEF: Alan
+Dershowitz, Roy Black,
+Gerald Lefcourt and Lilly Sanchez).
+• Defense argument--Travel has to be for "the" sole
+purpose of engaging
+in sexual activity not "a"
+pur pesense became aware of the Government's strategy to
+charge Epstein with Enticement in addition to the
+Traveling charges.
+7/26/2007--Meeting (US: SerT
+мась менспет, магто
+¡ference call), Valerie Parlave, Junior
+Ortiz,
+• US Attorney's Office presented a State two-year
+incarceration plea agreement.
+7/31/2007--Meeting (US: Jell Stoman, Matt Menchel, Marie
+DEF: Roy Black, Gerald Lefcourt and Lilly Sanchez) .
+• Defense stance was jail time was not an option.
+8/31/2007--Meeting (US: Deal Dastardo
+Madio 12116 fans
+• Case briefing to DOJ representative.
+9/7/2007--Meeting (US: Alexander Acosta,
+Marie Willafara, John McMillan, DEF: Kenneth Starr, Jay
+Lefkowitz, Lilly Sanchez) .
+9/12/2007--Meeting (US:
+•DEF:
+Jay Lefkowitz, Gerald iefcourt and Jack
+Goldberger,
+STATE OF FLORIDA: Barry Krisher and Lanna
+Belohlavek) •
+9/18/2007--Rescheduled date for computer hearing. (Hearing
+initially set for 9/13/2007).
+9/24/2007--Non-Prosecution Agreement signed.
+9/25/2007--Scheduled date for Federal Indictment.
+P-009108
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/a9f113472d2e829ee8b6d84ac71bcba4ded40280bb28c0d7fadbd2da9bbc1fbb.receipt.json b/vision-fixhub/ds9-unparsed-05/a9f113472d2e829ee8b6d84ac71bcba4ded40280bb28c0d7fadbd2da9bbc1fbb.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f4f48bdb50195524b2e3caf531f35b838fe2a095
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/a9f113472d2e829ee8b6d84ac71bcba4ded40280bb28c0d7fadbd2da9bbc1fbb.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -215,
+  "dataset": "marble-joined",
+  "doc_id": "a9f113472d2e829ee8b6d84ac71bcba4ded40280bb28c0d7fadbd2da9bbc1fbb",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "d49c316f034d815baa536fc309e270ae3720e9aff9c8b6cf48d1cdb8afdfe865",
+  "output_sha256": "d2c2ceafd627087a03824cf1ab0852a704e25eac8731c74513e0497946919ada",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/abc1e09f9f5ca28f44647ac8e5a94cb4ab209bbd4755cb70a7dd5e4df25c19d7.md b/vision-fixhub/ds9-unparsed-05/abc1e09f9f5ca28f44647ac8e5a94cb4ab209bbd4755cb70a7dd5e4df25c19d7.md
new file mode 100644
index 0000000000000000000000000000000000000000..b63b50b3c6e344bef7c182af0537455a505d980a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/abc1e09f9f5ca28f44647ac8e5a94cb4ab209bbd4755cb70a7dd5e4df25c19d7.md
@@ -0,0 +1,162 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+Miami, FL 33132-2111
+(305) 961-9299
+99 NE. 4 * Street
+Facsimile: (305) 530-6444
+November 30, 2007
+DELIVERY BY FACSIMILE
+Jay P. Lefkowitz, Esq
+Kirkland & Ellis LLP
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4675
+Re: Jeffrey Epstein
+Dear Jay:
+I write in response to your recent e-mails and letters regarding victim notification and other
+issues. Some of these issues also are addressed in the U.S. Attorney's letter to Mr. Starr, but in light of
+our discussions, I believe a separate response is needed
+In a recent e-mail, you write that you were surprised at the tone of my e-mail of November 27,
+2007. That tone was engendered by the continuing failures to abide by the terms of the Non-Prosecution
+Agreement, unfounded allegations of misconduct on the part of our office, attacks upon our investigation
+and the victims in the press, and the mounting evidence that you did not enter into our plea negotiations
+in good faith. This letter and U.S. Attorney Acosta's letter are the last opportunity for your client and his
+entire defense team to conform unwaveringly to all of the terms of the Non-Prosecution Agreement. As
+stated by the U.S. Attorney in his letter:
+Accordingly, please provide us with a definitive statement, signed by your client, of his
+intention to abide by each and every term of the Agreement by close of business on
+Tuesday, December 4, 2007. By that time, you must also provide us with the agreements)
+with the State Attorney's Office and a date and time certain for the plea and sentencing,
+which must occur no later than December 14, 2007. If we do not receive these items by
+that time, we will deem the agreement to be rescinded and will proceed with the
+prosecution. There must be closure in this matter.
+Before I address your continued allegations of some sort of misconduct on the part of the Office
+for trying to abide by both the letter of the Agreement and of the law, I need to address you and your
+client's failure to comply with the Agreement.
+Three weeks ago we spoke about the failure to set a timely plea and sentencing date. At that time,
+you assured me that a new prompt date would be set, and that the delay in scheduling the date was caused
+by the unavailability of Judge MeSorley. You promised that a date would be set promptly. On November
+15th, Rolando Garcia met with Barry Krisher on another matter, and was told by Mr. Krisher that he had
+just spoken with Jack Goldberger, and Mr. Epstein's plea and sentencing were set to occur on December
+14, 2007. Since that time, we have tried to confirm the date and time of the hearing, to include that
+information in the victim notification letters. You continue to refer to the plea and sentencing as though it
+will be in January; Mr. Krisher's office has not confirmed any date; and Mr. Goldberger told
+hat "there is no date."
+I have repeatedly told you that a delayed guilty plea and sentencing - now more than two months
+beyond the original deadline - is unacceptable to the Office. Contrary to your past assertions, the Non-
+Prosecution Agreement does not contemplate a staggered plea and sentencing. Instead, the Agreement
+contemplates a combined plea and sentencing followed by a later surrender date for Mr. Epstein to begin
+serving his jail sentence. As you will recall, the plea and sentencing hearing originally was to occur in
+early October 2007, but was delayed until October 26th to allow Mr. Goldberger to attend. It was
+delayed again until November to allow you to attend. You have provided no showing of how you and
+your client have used your best efforts to insure that the plea and sentencing occur in November. In fact,
+we recently learned that a plea conference had been scheduled with Judge MeSorley for November 20,
+
+
+2007, but was canceled at the request of the parties, not the judge. Judge MeSorley has not been away
+for any extended period, and there is no basis for your assertion that the judge is the cause of any past or
+future delay. Mr. Epstein currently has four Florida Bar members on his defense team, so attorney
+scheduling is not an adequate basis for delay.
+Three weeks ago I also asked you to provide our Office with the terms of the Plea Agreement with
+the State Attorney's Office. It is now more than two months since the signing of the Non-Prosecution
+Agreement and we have yet to see any formal agreement, or even a list of essential terms of such an
+agreement. The only conclusion that we can draw is that you are trying to avoid providing the Office
+with adequate time to review your agreement prior to the change of plea and sentencing to determine
+whether Mr. Epstein is complying with the terms of the Non-Prosecution Agreement.
+Your letters make reference to a failure by the United States to abide by the "spirit" of the
+Agreement, but recent correspondence shows that Mr. Epstein hopes to serve his sentence on "work
+release." This is plainly contrary to both the terms and spirit of the Agreement. The Agreement clearly
+indicates that Mr. Epstein is to be incarcerated, and during your joint meeting with representatives of our
+office and the State Attorney's Office, the parties specifically discussed that Mr. Epstein would serve his
+time in solitary confinement at the Palm Beach County Jail to obviate your safety concerns. In addition
+to the terms of the Agreement, the Florida Department of Corrections does not allow persons who are
+registered sex offenders to participate in "community release" (which includes "work release"). Since
+Mr. Epstein will have to register as a sex offender promptly after his guilty plea and sentencing, he will
+not be eligible for such a program. Thus, the U.S. Attorney's Office is simply putting you on notice that
+it intends to make certain that Mr. Epstein is "treated no better and no worse than anyone else" convicted
+of the same offense. If Mr. Epstein is somehow allowed to participate in a work release program despite
+the Department of Corrections' rules and practices, the Office intends to investigate the reasons why an
+exception was granted in Mr. Epstein's case.
+Next, let me address various accusations that you and Mr. Starr, amongst others, have raised. You
+have repeatedly alleged that attorneys in our office and agents of the FBI have leaked information to the
+press in an effort to affect possible civil litigation with Mr. Epstein. This is untrue. There has been no
+contact between any member of the press and any employee of our office or the FBI since you incorrectly
+accused investigators of telling "Vanity Fair" about Mr. Starr's employment by Mr. Epstein several
+months ago. As you have been told before, prior to that, the press had provided information to the FBI,
+but no comment was ever made about the ongoing investigation, it was simply referred to as an "open
+investigation." Your accusations on this point are ironic in light of the amount of information that Mr.
+Epstein's team has provided to the press, much of which is completely inaccurate and which is obviously
+intended to intimidate your client's victims. We intend to continue to refrain from commenting or
+providing information to the press. We would ask that your client and all of his representatives do the
+same.
+Mr. Starr's letter to Assistant Attorney General
+* contains several false statements and
+accusations. First, Mr. Epstein was never forced to enter into any agreement and all terms of the
+agreement were fully negotiated, including the terms regarding the payment of monetary damages to the
+victims under 18 U.S.C. § 2255. In fact, some of those terms were re-negotiated as part of the
+Addendum. Second, if Mr. Epstein's cadre of attorneys was concerned about a way to test the validity of'
+the victims" claims prior to placing the names of those victims on the list prepared by our office, that term
+could have been negotiated. In fact, at one of our early meetings, Roy Black raised that concern, and
+possible solutions were contemplated by our office prior to the negotiations. However, since none of Mr.
+Epstein's team of attorneys requested the inclusion of such a term, it was omitted from the Agreement.
+To the extent that you now object to the Agreement that you negotiated, this is akin to "buyer's
+remorse." However, you and Mr. Starr have, instead, made claims to the Justice Department that these
+thoroughly negotiated terms "leave[] wide open the opportunity for misconduct by federal investigators."
+You then misinterpret several statements that were included in correspondence - at your insistence - as
+proof that the designated victims have invalid claims.
+Let me make clear that each of the listed
+individuals are persons whom the Office identified as victims as defined in Section 2255, that is, as
+persons "who, while a minor, was a victim of a violation of section ... 2422 or 2423 of this title." In
+other words, the Office is prepared to indict Mr. Epstein based upon what Mr. Starr refers to as Mr.
+Epstein's "interactions" with these individuals. This conclusion is based upon a thorough and proper
+
+
+investigation - one in which none of the victims was informed of any right to receive damages of any
+amount prior to the investigation of her claim. Each of the victims' claims was corroborated - again,
+prior to anyone being notified of a potential civil claim for damages. In fact, after the Agreement was
+signed, the FBI only had the opportunity to inform three victims of the resolution of the matter before
+you raised complaints and, in deference to your request, the Office asked that they defer further
+notifications. The Office agrees that it is not a party to, and will not take a role in, any civil litigation, but
+the Office can say, without hesitation, that each person on the list was a vietim of Mr. Epstein's criminal
+behavior.
+Mr. Starr's letter also suggests that the number of victims to whom Mr. Epstein is exposed by the
+Agreement is limitless. As you know, early drafts of the Agreement contained a numerical limit of 40
+victims. At your request, that number was removed. The Office repeatedly confirmed that the number
+would not exceed 40, after conducting additional investigation, it was reduced to 34, and we recently
+removed another name because, despite the fact that Mr. Epstein offensively touched the victim, in our
+opinion, the touching was not "sexual" enough to properly include her as a victim as defined in Section
+2255. Once the list is provided to you, if you have a good faith basis for asserting that a victim never met
+Mr. Epstein, we remain willing to listen and to modify if you convince us of your position.
+Mr. Starr also asserts that the Office has "improperly insisted that the chosen attorney
+representative should be able to litigate the claims of individuals, which violates the terms of the
+Agreement and deeply infringes upon the spirit and nature of the Agreement." Again, this was a term
+that could have been discussed and negotiated prior to entering into the Agreement. At least five
+extremely experienced attorneys reviewed the Agreement prior to its execution. Your failure to consider
+what would happen if a victim refused to accept the minimum settlement you offered to her does not
+render the Agreement void, unconscionable, or violative of Due Process. Whether counsel for the victims
+decides that there is a conflict is something to be addressed by him, but the Agreement speaks for itself.
+Finally, let me address your objections to the draft Victim Notification Letter.
+Your concerns regarding the § 2255 litigation are unfounded. As you know, Mr. Ocariz had been
+told that he would be the attorney representative for the victims. As a matter of professional courtesy, he
+was informed that the Office decided to use a Special Master in the selection of the attorney
+representative. His decision to contact Judge Davis to express his interest in continuing to work on the
+case was no more "lobbying" than contacts made by your colleagues to Judge Davis to persuade him to
+select your choice of an attorney and to persuade him that the non-prosecution agreement's terms did not
+contemplate litigation. You state that you are concerned that the Office has continued to insist that a
+primary criteria for the appointment of counsel is the ability to handle litigation against Mr. Epstein, yet
+your continued reference to challenging the "veracity" of the victims" claims, your contacting of victims
+whom you knew were soon to be represented, your attempts to muzzle the Office's and the FBI's abilities
+to comply with victim notification rules, and your client's consistent attacks upon the victims in the press
+all confirm the need for appointed counsel to be prepared for such litigation.
+Lastly, the statement at the end of your letter that you "reserve [the] right to object to certain
+aspects of the $2255 provisions of the Agreement" needs explanation. The provisions regarding $2255
+Please provide me with the terms of the agreements) with the State Attorney's Office and the new
+date for the change of plea and sentencing by Friday, November 16, 2007.
+Sincerely,
+R. Alexander Acosta
+United States Attorney
+By:
+First Assistant United States Attorney
+cc: R. Alexander Acosta, U.S. Attorney
+AUSA A. Marie Villafaña
diff --git a/vision-fixhub/ds9-unparsed-05/abc1e09f9f5ca28f44647ac8e5a94cb4ab209bbd4755cb70a7dd5e4df25c19d7.receipt.json b/vision-fixhub/ds9-unparsed-05/abc1e09f9f5ca28f44647ac8e5a94cb4ab209bbd4755cb70a7dd5e4df25c19d7.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..39c500fabf2e421ef0e34cb5d2a057d9233501db
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/abc1e09f9f5ca28f44647ac8e5a94cb4ab209bbd4755cb70a7dd5e4df25c19d7.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "abc1e09f9f5ca28f44647ac8e5a94cb4ab209bbd4755cb70a7dd5e4df25c19d7",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "6fda59cdd7f06039f10de552b3a219198a932cca440df11360ded73d21ad5ae3",
+  "output_sha256": "4d8436963cce6c86b5d543b2349157b838c9c22365761faeb440fa603fbfc5e0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ad0cc5358e6450f52786139312caf71e615248c7b074aa704b31dee057bc0e2a.md b/vision-fixhub/ds9-unparsed-05/ad0cc5358e6450f52786139312caf71e615248c7b074aa704b31dee057bc0e2a.md
new file mode 100644
index 0000000000000000000000000000000000000000..b20c51dfcf940657e21792a0aad5b0440c461a03
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ad0cc5358e6450f52786139312caf71e615248c7b074aa704b31dee057bc0e2a.md
@@ -0,0 +1,154 @@
+To:
+Cc:
+Subject:
+Tuesday, May 27, 2008 6:46 PM
+RE: Epstein
+Hey
+Sorry to bother you on vour vacation. Apparently the DAG is inclined to allow Epstein's counsel to present further arguments.
+and I to prepare, in email format, arguments to present to the DAG supporting why the case should not
+be stalled any further.
+mentioned statute of limitation issues. I don't know what the specific statute of limitations are (if there
+are any) for the various counts. Seems like the statute of limitations was for the life of the victim but I'm not certain. Other points that
+can be made include the private investigators continuing to contact the victims and the relocation of our victims to various parts of the
+country. Do you have any suggestions as to what would be our best course of persuasion? Thanks and happy travels.
+(USAPLS) |
+Sent: Tuesday.
+May 27, 2008 2:54 PM
+To:
+Cc:
+(USAFLS)
+Subject: Epstein
+Hi L
+sent me an email about epstein wanting to do less time. I hope that his request will be denied. The original deal was
+supposed to be 2 years so he has already gotten a big break. Plus we have identified more victims since we agreed to the 18 months
+Please keep me posted. Thanks.
+P-014929
+
+
+I. (USAFLS)
+To:
+Subject:
+(USAFLS) <AVillafana@usa.doj.gov>
+Tuesday, May 27, 2008 11:45 PM
+R. (MM) (FBI);
+(USAFLS);
+Re: Epstein
+(FBI)
+The statute of limitations issue is the state statute of limitations. I think joe says it is two years. The issue is implicated in two ways.
+to depose and harass those victims.)
+Second, our "state resolution" of the case requires epstein to plead to something that hasn't been charged yet so further delay will
+allow him to escape one of the terms of the deal he signed several months ago. (There also is a sol on the private cause of action
+under 2255 pursuant to which he must pay damages to the girls. The delay will allow him to escape responsibility for that term, too.)
+Then they testig tim old practial one on preins arguments.
+epstein's arguments will be that he did not know they were minors. The older they ar
+The grand jury we are using will expire soon. We have already presented more than a dozen hours of testimony and the grand jury is
+invested and wants to indict.
+We promised the girls swift justice so they could move on with their lives. [
+is a perfect example of why this is needed. The
+delay so far has led many to reach out to private lawyers which, in turn, let's e argue that they are only in it for money.
+Why give him more time? He has had more than a year's delay already for no reason other than the names of the attorneys he can
+afford to hire. This is not a white collar or other non-violent crime. This is a child exploitation crime with more than 20 known child
+victims. We are mandated by statute and doj policy to prosecute those cases vigorously and in a timely fashion - whether the children
+were prostitutes or unwilling victims. Why is this case being treated so differently?
+---- Original Message -....
+To:
+R. (FBI)
+L. (USAFLS)
+Ce:
+Sent: Tue May 27 18:45:37 2008
+Subject: RE: Epstein
+Hey l
+Sorry to bother you on your vacation. Apparently the DAG is inclined to allow Epstein's counsel to present further arguments.
+be stalled any further. T
+46
+P-014930
+
+
+To:
+Ce:
+Subject: Epstein
+L (USAFLS)
+Sent: Tuesday. May 27, 2008 2:54 PM
+(USAFLS); [
+(USAFLS)
+(USAFLS)
+i posed to be 2 eas an email already geir anting re o es in a ve petit time wil eve The riginal a vas
+lease keep me posted. Thank
+47
+P-014931
+
+
+- (USAFLS)
+To:
+Subject:
+(FBI) <
+Wednesday, May 28, 2008 6:33 PM
+LL. (USAFLS)
+Re: Epstein
+Hey we emailed
+MOST:) of your comments re any further delays and added a few of our own. The US Atty Gen was here today
+in MM. I would love to know if Epstein came up.
+and Acosta were going to present to the DAG reasons not to delay any further.
+Hopefully they were successful and we r still on for Tues. We interviewed SR today. She told Epstein her true age, she belvd was 14
+or 15. Phone records show contact @ age 16. She said Epstein told her he did not care about age. She also said that E
+told her he had f***d TM. TM brought SR. Anyways, I'll fill u in later. NY getting close to locating ML.. We have cell and good
+address. Keep your fingers crossed. Talk to u soon.
+---- Original Message
+To:
+R.;
+Sent: Tue May 27 23:45:06 2008
+Subject: Re: Epstein
+AELS) 4
+(USAFLS);
+The statute of limitations issue is the state statute of limitations. I think joe says it is two years. The issue is implicated in two ways.
+First, because of the state's leniency for the first set of girls, the second set have been presented only to us for prosecution. If we
+cannot go forward, then there will be no prosecution of those crimes. (In response to the argument that joe should just present them
+now, we believe that some of the victims are unknown to the defense and disclosing them further weakens our case by allowing them
+to depose and harass those victims.)
+Sccond, our "state resolution" of the case requires epstein to plead to something that hasn't been charged yet so further delay will
+allow him to escape one of the terms of the deal he signed several months ago. (There also is a sol on the private cause of action
+under 2255 pursuant to which he must pay damages to the girls. The delay will allow him to escape responsibility for that term, too.)
+Other reasons:
+The victims are getting older. Clearly one of epstein's arguments will be that he did not know they were minors. The older they are
+when they testify the more plausible epstein's argument becomes.
+The grand jury we are using will expire soon. We have already presented more than a dozen hours of testimony and the grand jury is
+invested and wants to indict.
+We promised the girls swift justice so they could move on with their lives.
+is a perfect example of why this is needed. The
+delay so far has led many to reach out to private lawyers which, in turn, let's e argue that they are only in it for money.
+Why give him more time? He has had more than a year's delay already for no reason other than the names of the attorneys he can
+afford to hire. This is not a white collar or other non-violent crime. This is a child exploitation crime with more than 20 known child
+victims. We are mandated by statute and doj policy to prosecute those cases vigorously and in a timely fashion - whether the children
+were prostitutes or unwilling victims. Why is this case being treated so differently?
+---- Original Message
+To:
+(EBI)
+L. (USAFLS)
+Cc:
+(FBI)
+Sent: Tue May 27 18:45:37 2008
+Subject: RE: Epstein
+Hey
+Sorry to bother you on your vacation. Apparently the DAG is inclined to allow Epstein's counsel to present further arguments.
+has requested
+be stalled any further.
+Land I to prepare, in email format, arguments to present to the DAG supporting why the case should not
+mentioned statute of 08-80786sGiV/-MoRRAv what the specific statute of limitations are P+Ql4932
+50
+
+
+are any) for the various counts. Seems like the statute of limitations was for the life of the victim but I'm not certain. Other points that
+can be made include the private investigators continuing to contact the victims and the relocation of our victims to various parts of the
+country. Do you have any suggestions as to what would be our best course of persuasion? Thanks and happy travels.
+• (USAFLS)
+Sent: Tuesday. May 27, 2008 2:54 PM
+To:
+LUSAFLS):
+Cc:
+(USAFLS)
+Subject: Epstein
+(USAFLS)
+sent me an email about epstein wanting to do less time. I hope that his request will be denied. The original deal was
+supposed to be 2 years so he has already gotten a big break. Plus we have identified more victims since we agreed to the 18 months.
+Please keep me posted. Thanks.
+P-014933
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/ad0cc5358e6450f52786139312caf71e615248c7b074aa704b31dee057bc0e2a.receipt.json b/vision-fixhub/ds9-unparsed-05/ad0cc5358e6450f52786139312caf71e615248c7b074aa704b31dee057bc0e2a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3f6fa055116693f2c8058c49c5d719fd9ed13338
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ad0cc5358e6450f52786139312caf71e615248c7b074aa704b31dee057bc0e2a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -205,
+  "dataset": "marble-joined",
+  "doc_id": "ad0cc5358e6450f52786139312caf71e615248c7b074aa704b31dee057bc0e2a",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "762d3aa849fd76d1b2994095ce00465d091d5d807fc4e359a4dfe995ede81fec",
+  "output_sha256": "a301585bf867600acbcdf074c7e986b8dcd2060bd52ace7a5d34ab9011354f31",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ae5f470ae3e7f752b787e354b4c2a699bbbdbcc383e598d7976984edd03f6ab9.md b/vision-fixhub/ds9-unparsed-05/ae5f470ae3e7f752b787e354b4c2a699bbbdbcc383e598d7976984edd03f6ab9.md
new file mode 100644
index 0000000000000000000000000000000000000000..33abd64204401593a271b6a60d5ac2d334219dce
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ae5f470ae3e7f752b787e354b4c2a699bbbdbcc383e598d7976984edd03f6ab9.md
@@ -0,0 +1,2497 @@
+2008 NOT-FOR-PROFIT CORPORATION REINSTATEMENT
+DOCUMENT# N96000002084
+Entity Name: THE KONI FOUNDATION, INC
+FILED
+Secretary of State
+Current Principal Place of Business:
+New Principal Place of Business:
+1 CLEARLAKE CENTER, #1402
+250 AUSTRALIAN AVENUE
+WEST PALM BEACH, FL 33401
+Current Mailing Address:
+New Mailing Address:
+3265 LAWSON BLVD
+OCEANSIDE, NY 11572
+FEI Number: 65-0676162
+1 Mordance l 5. 607. 193(2). Fot corporation did not receive the prior app
+El Number Not Applicable (
+Certificate of Status Desired ()
+Name and Address of Current Registered Agent:
+Name and Address of New Registered Agent:
+SIEGEL, HOWARD
+250 AUSTRALIAN AVE S, #1402
+WEST PALM BEACH, FL 33401 US
+The above named entity submits this statement for the purpose of changing its registered office or registered agent, or both,
+in the State of Florida.
+SIGNATURE: HOWARD SIEGEL
+Electronic Signature of Registered Agent
+OFFICERS AND DIRECTORS:
+Title:
+Name:
+Address:
+City-St-Zip:
+D
+( ) Delete
+SIEGEL, HOWARD
+Date
+ADDITIONS/CHANGES TO OFFICERS AND DIRECTORS:
+() Change ( ) Addition
+Title:
+D
+( ) Delete
+Name:
+KAPNER, LEWIS
+Address:
+250 AUSTRALIAN AVENUE
+City-St-Zip:
+WEST PALM BEACH, FL 33401
+Title:
+Name:
+Address:
+City-St-Zip:
+D
+() Delete
+WIENER, HOWARD
+777 S FLAGER DR WEST TWR STE 1601
+WEST PALM BEACH, FL 33401
+Title:
+Name:
+Address:
+City-St-Zip:
+Title:
+Name:
+Address:
+City-St-Zip:
+Title:
+Name:
+Address:
+City-St-Zip:
+() Change ( ) Addition
+() Change ( ) Addition
+SIGNATURE: HOWARD SIEGEL
+Electronic Signature of Signing Officer or Director
+D
+11/03/2008
+Date
+
+
+
+
+www.sunbiz.org - Department of State
+FLORIDA DEPARTMENT OF STATE
+DIVISION OF CORPORATIONS
+Home
+Contact Us
+E-Filing Services
+Previous on List Next on List
+Events
+No Name History
+Return To List
+Detail by Entity Name
+Florida Non Profit Corporation
+THE KONI FOUNDATION, INC.
+Filing Information
+Document Number N96000002084
+FEl Number
+
+Date Filed
+04/18/1996
+State
+FL
+Status
+ACTIVE
+Effective Date
+05/01/1996
+Last Event
+CANCEL ADM DISS/REV
+Event Date Filed
+11/03/2008
+Event Effective Date NONE
+Principal Address
+1 CLEARLAKE CENTER, #1402
+250 AUSTRALIAN AVENUE
+WEST PALM BEACH FL 33401
+Changed 03/26/2002
+Mailing Address
+3265 LAWSON BLVD
+OCEANSIDE NY 11572
+Changed 09/05/2006
+Registered Agent Name & Address
+SIEGEL, HOWARD
+250 AUSTRALIAN AVE S, #1402
+WEST PALM BEACH FL 33401 US
+Name Changed: 06/03/2005
+Address Changed: 06/03/2005
+Officer/Director Detail
+Name & Address
+Title D
+SIEGEL, HOWARD
+
+wwwSunbiz.org
+Document Searches
+Forms
+Help
+Entity Name Search
+http://www.sunbiz.org/scripts/cordet.exe?action=DETFIL&ing_doc_number=N96000002084&i...
+12/12/2008
+
+
+www.sunbiz.org - Department of State
+Title D
+KAPNER, LEWIS
+250 AUSTRALIAN AVENUE
+WEST PALM BEACH FL 33401
+Title D
+WIENER, HOWARD
+777 S FLAGER DR WEST TWR STE 1601
+WEST PALM BEACH FL 33401
+Annual Reports
+Report Year Filed Date
+2006
+09/05/2006
+2007
+10/16/2007
+2008
+11/03/2008
+Document Images
+11/03/2008 -- REINSTATEMENT
+10/16/2007 - REINSTATEMENT
+09/05/2006 - ANNUAL REPORT
+06/03/2005 - ANNUAL REPORT
+08/05/2004 - ANNUAL REPORT
+05/02/2003 - ANNUAL REPORT
+03/26/2002 - ANNUAL REPORT
+07/06/2001 - ANNUAL REPORT
+03/22/2001 - DEBIT MEMO
+03/09/2001 - DEBIT MEMO
+12/21/2000 - ANNUAL REPORT
+04/18/1996 - DOCUMENTS PRIOR TO 1997
+View image in PDF format
+View image in PDF format
+View image in PDF format
+View image in PDF format
+View image in PDF format
+View image in PDF format
+View image in PDF format
+View image in PDF format
+View image in PDF format
+View image in PDF format
+View image in PDF format
+View image in PDF format
+Note: This is not official record. See documents if question or conflict.
+Previous on List Next on List
+Events
+No Name History
+Return To List
+
+Entity Name Search
+Home Contact us Document Searches E-Filing Services Forms Help
+Copyright and Privacy Policies
+Copyright iD 2007 State of Florida, Department of State.
+http://www.sunbiz.org/scripts/cordet.exe?action=DETFIL&ing_doc_number=N96000002084&i.. 12/12/2008
+
+
+2007 NOT-FOR-PROFIT CORPORATION REINSTATEMENT
+DOCUMENT# N96000002084
+secretary de State
+Entity Name: THE KONI FOUNDATION, INC.
+Current Principal Place of Business:
+1 CLEARLAKE CENTER, #1402
+250 AUSTRALIAN AVENUE
+WEST PALM BEACH, FL 33401
+Current Mailing Address:
+New Principal Place of Business:
+New Mailing Address:
+FEl Number: 65-0676162
+FEI Number Applied For ( )
+El Number Not Applicable (
+Certificate of Status Desired (X)
+accordance with s. 607.193(2)(b), F.S., the corporation did not receive the prior notic
+Name and Address of Current Registered Agent:
+Name and Address of New Registered Agent:
+SIEGEL, HOWARD
+250 AUSTRALIAN AVE S, #1402
+WEST PALM BEACH, FL 33401 US
+The above named entity submits this statement for the purpose of changing its registered office or registered agent, or both,
+in the State of Florida.
+SIGNATURE: HOWARD SIEGEL
+Electronic Signature of Registered Agent
+OFFICERS AND DIRECTORS:
+Title:
+Name:
+Address:
+City-St-Zip:
+SIEGEL, HOWARD
+( ) Delete
+Date
+ADDITIONS/CHANGES TO OFFICERS AND DIRECTORS:
+() Change ( ) Addition
+Title:
+D
+( ) Delete
+Name:
+KAPNER, LEWIS
+Address:
+250 AUSTRALIAN AVENUE
+City-St-Zip:
+WEST PALM BEACH, FL 33401
+Title:
+Name:
+Address:
+City-St-Zip:
+D
+() Delete
+WIENER, HOWARD
+777 S FLAGER DR WEST TWR STE 1601
+WEST PALM BEACH, FL 33401
+Title:
+Name:
+Address:
+City-St-Zip:
+Title:
+Name:
+Address:
+City-St-Zip:
+Title:
+Name:
+Address:
+City-St-Zip:
+() Change ( ) Addition
+() Change ( ) Addition
+hereby certify that the information supplied with this filing does not qualify for the exemption stated in Chapter 11
+orida Statutes. I further certify that the information indicated on this report or supplemental report is true and accurate and tha
+SIGNATURE: STEVEN KAPLANSKY
+Electronic Signature of Signing Officer or Director
+DIR
+10/16/2007
+Date
+
+
+
+mportant: The Public Records and commercially available data sources used on reports have errors. Data is sometime
+entered poorly, processed incorrectly and is generally not free from defect. This system should not be relied upon a
+definitively accurate. Before relying on any data this system supplies, it should be independently verified. For Secretary o
+state documents, the following data is for information purposes only and is not an official record. Certified copies may b
+Your DPPA Permissible Use: Court, Law Enforcement or Government Agencies
+Your GLBA Permissible Use: Law Enforcement Purposes
+omprehensive Business Repo
+ate: 12/09/0
+Company Information:
+Company Name: THE C.O.U.Q. FOUNDATION, INC
+Address: 250 S AUSTRALIAN AVE STE 1404, WEST PALM BCH FL 33401-5016
+Name Variations:
+Company Name: THE C.O.U.Q. FOUNDATION, INC
+Address Variations:
+Address: 250 S AUSTRALIAN AVE 1404, WEST PALM BCH FL 33401
+County: PALM BEACH
+Msa Description: West Palm Beach-Boca Raton, FL
+Phone Variations:
+arent Company:
+Address
+Comprehensive Business Report Summary: (Click on Link to see detail)
+Industry Information:
+Company ID Numbers:
+1 Found
+Bankruptcies:
+Liens and Judgments:
+Corporation Filings:
+1 Found
+Registered Agents:
+Business Registration:
+UCC Filings for Business:
+Associated Businesses:
+1 Found
+Business Contacts:
+Motor Vehicles:
+Properties:
+FAA Aircrafts:
+Watercrafts:
+Internet Domain Names Registered to Business:
+IRS 5500:
+
+
+
+Business Filings:
+Industry Information:
+Company ID Numbers:
+Stator Number: F08000003048
+Bankruptcies:
+Liens & Judgments:
+Corporation Filings:
+Corporation Filings #1
+THE C.O.U.Q. FOUNDATION, INC. - As of: 10/16/2008
+Name Type: LEGAL
+Address: 250 S AUSTRALIAN AVE STE 1404, WEST PALM BEACH FL 33401-5016
+Address Type: MAILING
+Status: ACTIVE
+Business Type: FOREIGN NON PROFIT
+Foreign Incorporation Date: 07/09/2008
+Registered Agent: C T CORPORATION SYSTEM
+Registered Agent Address: PLANTATION, FL 33324
+Place Incorporation: DELAWARE
+THE C.O.U.Q. FOUNDATION, INC. - As of: 07/11/2008
+Name Type: LEGAL
+Address: 250 S AUSTRALIAN AVE STE 1404, WEST PALM BEACH FL 33401-5016
+Address Type: MAILING
+Status: ACTIVE
+Business Type: FOREIGN NON PROFIT
+Foreign Incorporation Date: 07/09/2008
+Registered Agent: C T CORPORATION SYSTEM
+Registered Agent Address: PLANTATION, FL 33324
+Place Incorporation: DELAWARE
+OME DAREI MOTE DE 20 REO HOR OTAS STEBS SIT THONA 00213418
+Officer: RICHARD KAHN, DIRECTOR
+Registered Agents:
+Business Registration:
+UCC Filings for Business:
+Associated Businesses:
+Name: THE KONI FOUNDATION, INC
+Address: 250 S AUSTRALIAN AVE STE 1402, WEST PALM BCH FL 33401-5015
+Associated People:
+Business Contacts:
+
+
+
+Assets:
+Motor Vehicles:
+roperties
+FAA Aircraft:
+Watercraft:
+Internet Domain Names Registered to Business:
+IRS 5500
+
+
+
+mered pony, procese more any and i generally not be arm defect. Id system talente read semes.
+finitively accurate. Before relying on any data this system supplies, it should be independently verified. For Secretary
+late documents, the following data is for information purposes only and is not an official record. Certified copies may t
+obtained from that individual state's Department of State.
+Your DPPA Permissible Use: Court, Law Enforcement or Government Agencies
+Your GLBA Permissible Use: Law Enforcement Purposes
+Date: 12/09/08
+Company Information monto Na
+Address:
+Name Variations:
+Company Name: THE C.O.U.Q. FOUNDATION, INC
+Address Variations:
+Address: 110 E 59TH ST, NEW YORK NY 10022
+County: NEW YORK
+Msa Description: New York, NY
+Phone Variations:
+Comprehensive Business Report Summary: (Click on Link to see detail)
+Industry Information:
+Company ID Numbers:
+1 Found
+Bankruptcies:
+Liens and Judgments:
+Corporation Filings:
+1 Found
+Registered Agents:
+Business Registration:
+UCC Filings for Business:
+Associated Businesses:
+Business Contacts:
+Motor Vehicles:
+Properties:
+FAA Aircrafts:
+Watercrafts:
+Internet Domain Names Registered to Business:
+IRS 5500:
+Business Filings:
+
+
+
+Industry Information:
+Company ID Numbers:
+State or Number: 2360817
+Bankruptcies:
+Liens & Judgments:
+Corporation Filings:
+Corporation Filings #1
+THE C.O.U.Q. FOUNDATION, INC. - As of: 10/22/2008
+Name Tyne: LEGA
+Address
+Address Type: PROCESS ADDRESS
+Status: ACTIVE • GOOD STANDING STATUS CAN ONLY BE DETERMINED BY PERFORMING A SEARCH IN
+THE RECORDS OF BOTH THE DEPARTMENT OF STATE CORPORATION RECORDS AND THE DEPARTMENT OF
+TAX AND FINANCE
+Business Type: FOREIGN NOT FOR PROFIT
+Filing Date: 03/26/1999
+Date Incorporated: 03/26/1999
+Foreign Incorporation Date: 03/16/1998
+Term: PERPETUAL
+Type: EFFECTIVE DATE
+Place Incorporation: DELAWARE
+THE C.O.U.Q. FOUNDATION, INC. - As of: 07/23/2008
+Name Type: LEGAL
+Address-,.-con
+Address Type: PROCESS ADDRESS
+Status: ACTIVE - GOOD STANDING STATUS CAN ONLY BE DETERMINED BY PERFORMING A SEARCH IN
+THE RECORDS OF BOTH THE DEPARTMENT OF STATE CORPORATION RECORDS AND THE DEPARTMENT OF
+TAX AND FINANCE
+Business Type: FOREIGN NOT FOR PROFIT
+Filing Date: 03/26/1999
+Date Incorporated: 03/26/1999
+Foreign Incorporation Date: 03/16/1998
+Term: PERPETUAL
+Type: EFFECTIVE DATE
+Place Incorporation: DELAWARE
+THE C.O.U.Q. FOUNDATION, INC. - As of: 04/21/2008
+Name Type: LEGAL
+Business Type: FOREIGN NOT FOR PROFIT
+Filing Date: 03/26/1999
+Date Incorporated: 03/26/1999
+Foreign Incorporation Date: 03/16/1998
+Term: PERPETUAL
+Type: EFFECTIVE DATE
+Annual Report Filings
+Status: MICROFILM NBR: 990326000255
+Filed Date: 03/26/1999
+Status: MICROFILM_ NBR :990326000255
+Filed Date: 03/26/1999
+Microfilm Number: 9903260002
+Status: MICROFILM_NBR : 990326000255
+Filed Date: 03/26/1999
+
+
+
+Microfilm Number: 9903260002
+Registered Agents:
+Business Registration:
+UCC Filings for Business:
+Associated Businesses:
+Associated People:
+Business Contacts:
+Assets:
+Motor Vehicles:
+Properties:
+FAA Aircraft:
+Watercraft:
+Internet Domain Names Registered to Business:
+IRS 5500
+
+
+
+obtained from that individual state's Department of State.
+Your DPPA Permissible Use: Court, Law Enforcement or Government Agencies
+Your GLBA Permissible Use: Law Enforcement Purposes
+Date: 12/09/08
+Company Information:
+Company Name: THE KONI FOUNDATION INC
+Address:
+Name Variations:
+Company Name: NICOLAUS KONI FOUNDATION
+Company Name: THE C.O.U.Q. FOUNDATION, INC.
+Company Name: THE KONI FOUNDATION, INC.
+Address Variations:
+Address: 250 S AUSTRALIAN AVE, WEST PALM BEACH FL 33401
+County: PALM BEACH
+Msa Description: West Palm Beach-Boca Raton, FL
+Address: 250 S AUSTRALIAN AVE 1402, WEST PALM BCH FL 33401
+County: PALM BEACH
+Msa Description: West Palm Beach-Boca Raton, FL
+Address: 250 S AUSTRALIAN AVE 1404, WEST PALM BCH FL 33401
+County: PALM BEACH
+Msa Description: West Palm Beach-Boca Raton, FL
+Address:
+County: NASSAU
+Msa Description: Nassau-Suffolk, NY
+Phone Variations:
+Phone: 516-241-1521
+Comprehensive Business Report Summary: (Click on Link to see detail)
+Industry Information:
+Company ID Numbers:
+1 Found
+Bankruptcies:
+Liens and Judgments:
+Corporation Filings:
+3 Found
+Registered Agents:
+1 Found
+Business Registration:
+1 Found
+UCC Filings for Business:
+Associated Businesses:
+23 Found
+Business Contacts:
+6 Found
+Motor Vehicles:
+
+
+
+Properties:
+FAA Aircrafts:
+Watercrafts:
+Internet Domain Names Registered to Business:
+2 Found
+IRS 5500
+4 Found
+Business Filings:
+Industry Information:
+Company ID Numbers:
+State of Origin: FL
+Charter Number: F08000003048
+State of Origin: FL
+Charter Number: N96000002084
+State of Origin: NY
+Charter Number: 2821493
+Bankruptcies:
+Liens & Judgments:
+(None Found]
+Corporation Filings:
+Corporation Filings #1
+THE KONI FOUNDATION INC. - As of: 10/22/2008
+Name Type: LEGAL
+Address
+Address Type: PROCESS ADDRESS
+Status: ACTIVE - GOOD STANDING STATUS CAN ONLY BE DETERMINED BY PERFORMING A SEARCH IN
+THE RECORDS OF BOTH THE DEPARTMENT OF STATE CORPORATION RECORDS AND THE DEPARTMENT OF
+TAX AND FINANCE
+Business Type: FOREIGN NOT FOR PROFIT
+Filing Date: 10/10/2002
+Date Incorporated: 10/10/2002
+Foreign Incorporation Date: 04/18/1996
+Term: PERPETUAL
+Type: EFFECTIVE DATE
+Place Incorporation: FLORIDA
+THE KONI FOUNDATION INC. - As of: 07/23/2008
+Name Type: LEGAL
+Address
+Address
+Status: ACTIVE • GOOD STANDING STATUS CAN ONLY BE DETERMINED BY PERFORMING A SEARCH IN
+THE RECORDS OF BOTH THE DEPARTMENT OF STATE CORPORATION RECORDS AND THE DEPARTMENT OF
+TAX AND FINANCE
+Business Type: FOREIGN NOT FOR PROFIT
+Filing Date: 10/10/2002
+Date Incorporated: 10/10/2002
+Foreign Incorporation Date: 04/18/1996
+Term: PERPETUAL
+Type: EFFECTIVE DATE
+Place Incorporation: FLORIDA
+THE KONI FOUNDATION INC. - As of: 04/21/2008
+Name Type: LEGAL
+Address:
+Address Type
+Status: ACTIVE - GOOD STANDING STATUS CAN ONLY BE DETERMINED BY PERFORMING A SEARCH IN
+
+
+
+THE RECORDS OF BOTH THE DEPARTMENT OF STATE CORPORATION RECORDS AND THE DEPARTMENT OF
+TAX AND FINANCE
+Business Type: FOREIGN NOT FOR PROFIT
+Filing Date: 10/10/2002
+Date Incorporated: 10/10/2002
+Foreign Incorporation Date: 04/18/1996
+Term: PERPETUAL
+Type: EFFECTIVE DATE
+Annual Report Filings
+Status: MICROFILM NBR: 021010000338
+Filed Date: 10/10/2002
+Status: MICROFILM_NBR : 021010000338
+Filed Date: 10/10/2002
+Microfilm Number: 0210100003
+Status: MICROFILM_NBR :021010000338
+Filed Date: 10/10/2002
+Microfilm Number: 0210100003
+Corporation Filings #2
+THE C.O.U.Q. FOUNDATION, INC. - As of: 10/16/2008
+Name Type: LEGAL
+Address: 250 S AUSTRALIAN AVE STE 1404, WEST PALM BEACH FL 33401-5016
+Address Type: MAILING
+Status: ACTIVE
+Business Type: FOREIGN NON PROFIT
+Foreign Incorporation Date: 07/09/2008
+Registered Agent: C T CORPORATION SYSTEM
+Registered Agent Address: PLANTATION, FL 33324
+Place Incorporation: DELAWARE
+THE C.O.U.Q. FOUNDATION, INC. - As of: 07/11/2008
+Name Type: LEGAL
+Address: 250 S AUSTRALIAN AVE STE 1404, WEST PALM BEACH FL 33401-5016
+Address Type: MAILING
+Status: ACTIVE
+Business Type: FOREIGN NON PROFIT
+Foreign Incorporation Date: 07/09/2008
+Registered Agent C T CORPORATION SYSTEM
+Registered Agent Address: PLANTATION. FL 33324
+Place Incorporation: DELAWARE
+Officers and Directors:
+THE C.O.U.Q. FOUNDATION, INC. - As of: 10/16/2008
+Officer: JEFFREY E EPSTEIN, DP, 6100 RED HOOK QTRS STE B3, ST THOMAS VI 00802-1348
+Officer: DARREN K INDYKE, DVS, 1
+Officer: RICHARD KAHN, DIRECTOR,
+Corporation Filings # 3
+THE KONI FOUNDATION, INC. - As of: 10/16/2008
+Name Type: LEGAL
+Address:
+Address Type. MAILING
+Status: INACTIVE
+Business Type: DOMESTIC NON PROFIT
+Date Incorporated: 05/01/1996
+Registered Agent: SIEGEL HOWARD
+Registered Agent Address: WEST PALM BEACH, FL 33401
+FEIN: 65-0676162
+Place Incorporation: FL
+THE KONI FOUNDATION, INC. - As of: 07/18/2008
+Name Type: LEGAL
+Address:
+Address Type. WAIInO
+Status: ACTIVE
+Business Type: DOMESTIC NON PROFIT
+Date Incorporated: 05/01/1996
+Registered Agent: SIEGEL HOWARD
+Registered Agent Address: WEST PALM BEACH, FL 33401
+FEIN: 65-0676162
+
+
+
+Place Incorporation: FL
+THE KONI FOUNDATION, INC. - As of: 03/31/2008
+Name Type: LEGAL
+Address
+Address Type: MAILING
+Status: ACTIVE
+Business Type: DOMESTIC NON PROFIT
+Date Incorporated: 05/01/1996
+Registered Agent: SIEGEL HOWARD
+Registered Agent Address: 250 S AUSTRALIAN AVE STE 1402, WEST PALM BEACH FL 33401-5015
+FEIN: 65-0676162
+Place Incorporation: FL
+Officers and Directors:
+THE KONI FOUNDATION, INC. - As of: 10/16/2008
+Officer: LEWIS KAPNER, DIRECTOR, 250 S ALISTRALIAN AVE WEST BALM BEACH EL 22401-5018
+Officer: HOWARD SIEGEL, DIRECTOR,
+Officer: HOWARD WIENER, DIRECTOR, 777 S FLAGLER DR STE 1601, WEST PALM BEACH FL 33401-6102
+Officer: LEWIS KAPNER, DIRECTOR, 250 $ AUSTRALIAN AVE. WEST PALM BEACH FL 33401-5018
+Officer: HOWARD SIEGEL, DIRECTOR,
+Officer: HOWARD WIENER, DIRECTOR, 777 S FLAGLER DR STE 1601, WEST PALM BEACH FL 33401-6102
+Officer: HOWARD WIENER, DIRECTOR, 222 LAKEVIEW AVE FL 4, WEST PALM BEACH FL 33401-6147
+Officer: LEWIS KAPNER, DIRECTOR, 250 S AUSTRALIAN AVE, WEST PALM BEACH FL 33401-5018
+Oticer: HOWARD WIENER, RECTOR, 777S FLAGLER DR STE 1601, WEST PALM BEACH FL 33401-6102
+Annual Report Filings:
+Filing Year: 2007
+Filed Date: 10/16/2007
+Filing Year: 2006
+Filed Date: 09/05/2006
+Filing Year: 2005
+Filed Date: 06/03/2005
+iling Year: 200
+iled Date: 06/03/200
+iling Year. 200
+iled Date: 08/05/200
+ling Year. 20
+ed Date: 05/02/20
+Filing Year: 2002
+Status: 2002
+Filed Date: 03/26/2002
+Filing Year: 2001
+Status: 2001
+Filed Date: 07/06/2001
+Events:
+Date: 09/26/2008
+Event: ADMIN DISSOLUTION FOR ANNUAL REPORT
+Date: 10/16/2007
+Event: CANCEL ADM DISS/REV
+Date: 09/14/2007
+Event: ADMIN DISSOLUTION FOR ANNUAL REPORT
+Date: 12/21/2000
+Event: REINSTATEMENT
+Date: 09/26/1997
+Event: ADMIN DISSOLUTION FOR ANNUAL REPORT
+Registered Agents:
+Name: SIEGEL HOWARD
+Address: 250 S AUSTRALIAN AVE STE 1402, WEST PALM BCH FL 33401-5015
+Date Last Seen: 3/31/2008
+
+
+
+Business Registration:
+Name: THE KONI EOUNDATIONINC
+Mailing Address: 3
+Filing Number: 021010000558
+Corporation Code: SOS
+Expiration Date: 10/30/2003
+UCC Filings for Business:
+Associated Businesses:
+Name: ADD-ON PROPERTIES LLC CO
+Name: AMERICAN MEDICAL ALERT CORP
+Address:
+Name: AMERICAN MEDICONNECT ACQUISITION CORP
+Address:
+Name: ANSWER CONNECTICUT ACQUISITION CORP
+Address:
+Name: BASE PROPERTIES LLC
+Address
+Name: DO IT ENTERPRISES INC
+Address:
+Name: H C I ACQUISITION CORP
+Address:
+Name: H CLACOLISITIONS CORP
+Address:
+Name: HI ACQUISITION CORP
+Address
+Name: HEALTH BUDDY
+Address
+Name: HOWARD M. SIEGEL
+Address:
+Name: LIVE MESSAGE AMERICA ACQUISITION CORP
+Addres!
+Name: MD ONCALL ACQUISITION CORP.
+Address:
+Name: NEW FOCUS SPORTSWEAR INC, A CORPORATION
+Address: OCEANSIDE, NY
+Name: NM CALL CENTER, INC
+Address: |
+Name: NORTH SHORE ANSWERING SERVICE, INC.
+Address:
+Name: SAFE COM INC
+Address:
+Name: SAFECOM SILENT PARTNER, INC.
+Address
+
+
+
+Name: SIEGEL HOWARD M
+Address:
+Name: THE KONI FOUNDATION, INC
+Address: 250 S AUSTRALIAN AVE STE 1402, WEST PALM BCH FL 33401-5015
+Name: TRIPS IN RESIN, INC.
+Address
+Associated People:
+Business Contacts:
+Name: JOHNSON JAMES
+Contact Title - DOMAIN TECHNICAL CONTACT
+Address:
+Date Last Seen: 4/1/2002
+Name: ALLISON KAPNER
+Contact Title - DOMAIN ADMINISTRATIVE CONTACT
+Address: 250 S AUSTRALIAN AVE STE 1402, WEST PALM BCH FL 33401-5015
+Date Last Seen: 6/13/2002
+Name: LEWIS KAPNER
+SSN: xxx-xx-xxxx
+Contact Title - DIRECTOR, DIRECTOR
+Address: 250 S AUSTRALIAN AVE, WEST PALM BCH FL 33401-5018
+Date Last Seen: 7/18/2008
+Name: HOWARD SIEGEL
+Contact Title - DIRECTOR DIRECTOR BROCESS ADDRESS CONTACT
+Address:
+Date Last Seen: 7/18/2008
+Name: HOWARD WIENER
+Contact Title - DIRECTOR, DIRECTOR
+Address: 222 LAKEVIEW AVE FL 4, WEST PALM BEACH FL 33401-6147
+Date Last Seen: 7/18/2008
+Name: HOWARD WIENER
+Contact Title - DIRECTOR
+Address:
+Date Last Seen: 312002
+Assets:
+Motor Vehicles:
+Properties:
+[None Found)
+FAA Aircraft:
+Watercraft:
+Internet Domain Names Registered to Business:
+(Click name to ao to eh site assaciated with that name)
+IRS 5500
+
+
+
+Name: HOWARD SIEGEL
+Contact Title - DIRECTOR, DIRECTOR
+Date Last Seen: 7/18/2008
+Name: HOWARD WIENER
+Contact Title - DIRECTOR, DIRECTOR
+Date Last Seen: 7/18/2008
+Name: LEWIS KAPNER
+Contact Title - DIRECTOR, DIRECTOR
+Date Last Seen: 7/18/2008
+Name: HOWARD WIENER
+Contact Title - DIRECTOR
+Date Last Seen: 3/2002
+
+
+
+Important: The Public Records and commercially available data sources used on reports have errors. Data is sometimes
+entered poorly, processed incorrectly and is generally not free from defect. This system should not be relied upon as
+Jefinitively accurate. Before relying on any data this system supplies, it should be independently verified. For Secretary of
+State documents, the following data is for information purposes only and is not an official record. Certified copies may be
+obtained from that individual state's Department of State.
+Your DPPA Permissible Use: Court, Law Enforcement or Government Agencies
+Your GLBA Permissible Use: Law Enforcement Purposes
+Date: 12/09/08
+Company Information:
+Company Name: FLORIDA SCIENCE FOUNDATION
+Address: 250 S AUSTRALIAN AVE, WEST PALM BCH FL 33401-5018
+Phone: 561-366-0084
+Name Variations:
+Company Name: THE FLORIDA SCIENCE FOUNDATION, INC.
+Address Variations:
+Address: 250 S AUSTRALIAN AVE, WEST PALM BCH FL 33401
+County: PALM BEACH
+Msa Description: West Palm Beach-Boca Raton, FL
+Address: 250 S AUSTRALIAN AVE 1400, WEST PALM BCH FL 33401
+County: PALM BEACH
+Msa Description: West Palm Beach-Boca Raton, FL
+Phone Variations:
+Phone: 561-366-0084
+Comprehensive Business Report Summary: (Click on Link to see detail)
+Industry Information:
+Company ID Numbers:
+1 Found
+Bankruptcies:
+Liens and Judgments:
+Corporation Filings:
+1 Found
+Registered Agents:
+Business Registration:
+1 Found
+UCC Filings for Business:
+Associated Businesses:
+Business Contacts:
+Motor Vehicles:
+Properties:
+FAA Aircrafts:
+Watercrafts:
+Internet Domain Names Registered to Business:
+IRS 5500:
+
+
+
+Business Filings:
+Industry Information:
+Company ID Numbers:
+State of Origin: FL
+Charter Number: N0700001068
+Bankruptcies:
+Liens & Judgments:
+Corporation Filings:
+Corporation Filings # 1
+THE FLORIDA SCIENCE FOUNDATION, INC. - As of: 10/16/2008
+Name Type: LEGAL
+Address: 250 S AUSTRALIAN AVE STE 1400, WEST PALM BEACH FL 33401-5016
+Address Type: MAILING
+Status: ACTIVE
+Business Type: DOMESTIC NON PROFIT
+Date Incorporated: 11/01/2007
+Registered Agent: C T CORPORATION SYSTEM
+Registered Agent Address: PLANTATION, FL 33324
+Place Incorporation: FL
+THE FLORIDA SCIENCE FOUNDATION, INC. - As of: 07/18/2008
+Name Type: LEGAL
+Address: 250 S AUSTRALIAN AVE STE 1400, WEST PALM BEACH FL 33401-5016
+Address Type: MAILING
+Status: ACTIVE
+Business Type: DOMESTIC NON PROFIT
+Date Incorporated: 11/01/2007
+Registered Agent: C T CORPORATION SYSTEM
+Registered Agent Address: PLANTATION, FL 33324
+Place Incorporation: FL
+THE FLORIDA SCIENCE FOUNDATION, INC. - As of: 03/31/2008
+Name Type: LEGAL
+Address: 250 S AUSTRALIAN AVE STE 1400, WEST PALM BEACH FL 33401-5016
+Address Type: MAILING
+Status: ACTIVE
+Business Type: DOMESTIC NON PROFIT
+Date Incorporated: 11/01/2007
+Registered Agent: C T CORPORATION SYSTEM
+Registered Agent Address: 1200 S PINE ISLAND RD, PLANTATION FL 33324-4413
+Place Incorporation: FL
+Officers and Directors:
+THE FLORIDA SCIENCE FOUNDATION, INC. - As of: 10/16/2008
+Officer: DARREN K INDYKE, ASSISTANT DIRECTOR, 457 MADISON AVE, NEW YORK NY 10022-6843
+Annual Report Filings:
+Filing Year: 2008
+Filed Date: 09/17/2008
+Registered Agents:
+Business Registration:
+Name: THE FLORIDA SCIENCE FOUNDATION INC
+Mailing Address: 250 S AUSTRALIAN AVE STE 1400, WEST PALM BEACH FL 33401-5016
+Filing Number: N07000010684
+State of Registration: FL
+
+
+
+Status: Active
+Corporation Code: SOS
+Expiration Date: 5/1/2008
+UCC Filings for Business:
+Associated Businesses:
+Associated People:
+Business Contacts:
+Assets:
+Motor Vehicles:
+Properties:
+FAA Aircraft:
+Watercraft:
+Internet Domain Names Registered to Business:
+IRS 5500
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+VET450 1.000
+
+
+
+
+SE 1450 1.000
+
+
+
+
+JSA
+GE1470 2.000
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+PE1492 1.000
+
+
+
+
+
+
+
+
+STATE OF NEW YORK
+County of New York, s:
+Leslie Francis, being duly sworn, says that she is the PRINCIPAL
+CLERk of the Publisher of the NEW YORK LAW JOURNAL,
+a Daily Newspaper; that the Advertisement hereto annexed has
+or the scal year ended Feb
+ruary 29, 2000 Is available at it
+110
+New
+Managei
+MEPPREYEOPSTEIN
+TO WIT: JANUARY 5, 2001
+SWORN TO BEFORE ME, this 5th day
+Of January, 2007
+Christine A. Allen
+Notary Public, State of New York
+• No. 0IAL5072870
+Qualified in Nassau County
+• Commission Expires Feb. 10, 2001
+
+
+
+
+Y/E 02/29/00
+FORM 990PF
+STATEMENT 1
+PART I, LINE 1
+CONTRIBUTIONS RECEIVED
+Jeffrey E. Epstein
+6100 Red Hook Quarters #2
+St. Thomas, VI 00802
+John J. Hannan
+clo Apollo Management. IP
+• 75,000
+166,667
+William Mack
+c/o Apollo Management, LP
+IS
+166,666
+Leon Black
+c/o Apollo Management, LP
+166,667
+575,000
+STATEMENT 2
+PART I, LINE, 23
+OTHER EXPENSES
+Bank Charges
+Research
+Filing Fees
+Health Insurance
+Miscellaneous
+Office Expense
+Payroll Expense
+Telephone
+Total
+21
+75,000
+619
+3,436
+25
+850
+1,402
+2,758
+84,111
+
+
+
+
+Y/E 02/29/00
+FORM 990PF
+STATEMENT 3
+PART II, LINE, 10(b)
+INVESTMENTS, CORPORATE STOCK
+Book Value
+7,650 SH AT&T
+405,581
+Market Value
+343,294
+STATEMENT 4
+PART XV, LINE 3
+CONTRIBUTIONS PAID
+05/03/99
+World Economic Forum
+$3,000
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+Y/E 02/28/01
+FORM 990PF
+STATEMENT 1
+PARTI LINE 23
+OTHER EXPENSES
+Bank Charges
+Consulting & Research
+Filing Fees
+Health Insurance
+Office Expense
+Payroll Expense
+Telephone
+Total
+36
+50,000
+180
+3,974
+145
+1,284
+226
+55,845
+STATEMENT 2
+PART II, LINE 10(b)
+INVESTMENTS, CORPORATE STOCK
+Book Value
+2,100 SH AT&T
+111,329
+Market Value
+44,100
+STATEMENT 3
+PART XY. LINE 3
+CONTRIBUTIONS PAID
+07/06/00
+05/04/00
+World Economic Forum
+lonia, Inc.
+Total
+$50,000
+$50,000
+$100,000
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+FORM 990-PF - Y/E 2/28/02
+STATEMENT 1
+Part J, Line I and Part VII-A, Line 10
+Contrbutions Received
+From Leshe H Wexner, as Grantor of
+The Wexner Children's Trust
+600,000 shares of Too, Inc common stock having a market value of
+$11,205,000 at date of gift recorded on the Foundation's books at the
+donor's basis
+
+
+
+
+-
+FORM 990-PF - Y/E 2/28/02
+STATEMENT 2
+PART I, LINE 23
+OTHER EXPENSES
+Bank Charges
+Consulting & Rescarch
+Filing Fees
+Office Expense
+Total
+85
+50,000
+419
+305
+50,809
+
+
+
+
+FORM 990-PF - Y/E 2/28/02
+PART IV, CAPITAL GAINS AND LOSSES
+Number
+of Shares
+2,000
+23,000
+3,200
+50,000
+15,700
+18,800
+70,000
+17,300
+2,100
+100,000
+143,600
+136,200
+Descuption
+Too, Inc
+Too, Inc
+Too, Inc
+Too, Inc
+Too, Inc
+How
+Acqured
+D
+D
+Date
+Acquired
+4/23/01
+4/23/01
+42301
+4/23/01
+4/23/01
+4/23/01
+4/23/01
+6/8/99
+4/23/01
+4/23/01
+4/23/01
+Date
+Sold
+4/22/01
+4/27/01
+5/2/01
+5/8/01
+5/10/01
+5/10/01
+5/16/01
+5/17/01
+5/21/01
+5/24/01
+5/31/01
+6/6/01
+Sales
+Price
+38,939
+444,802
+63,901
+932,799
+297,830
+353,692
+1,333,687
+365,487
+44,883
+2,433,051
+3,321,141
+3,583,100
+13,213,312
+STATEMENT 3
+Cost
+1
+2
+2
+∞ w
+2
+5
+111,361
+Gaun
+(Loss)
+38,938
+444,800
+63,900
+932,796
+297,828
+353,689
+1,333,684
+365,485
+-66,446
+2,433,046
+3.321,136
+3,583,095
+13.101,951
+:
+
+
+
+
+THE C.O.U.Q. FOUNDATION, INC..
+FORM 990-PF Y/E 2/28/02
+STATEMENT 4
+PART I, LINE 25 AND PART LINE 3
+CONTRIBUTIONS PAID
+UNRESTRICTED
+6/11/01
+6/15/01
+6/21/01
+7/27/01
+8/24/01
+10/2/01
+10/9/01
+10/9/01
+12/20/01
+2/28/01
+University of Maryland
+Institute of Advanced Study
+Nelson Mandela Children's Fund
+UNM Foundation
+Edge Foundation
+Ackerman Institute for the Family
+The Prize for Promise
+New York University School of Medicine
+Harvard Unrversity
+The Prize for Promise
+50,000
+400,000
+50,000
+100,000
+25,000
+125,000
+25,000
+845,000
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+FORM 990-PF - Y/E 02/28/03
+STATEMENT 1
+PART I, LINE 23
+OTHER EXPENSES
+Bank Charges
+Filing Fees
+Total
+60
+855
+215
+
+
+
+
+FORM 990-PF Y/E 2/28/03
+STATEMENT 2
+PART I, LINE 25 AND PART LINE 3
+CONTRIBUTIONS PAID
+UNRESTRICTED - CASH
+516/02
+5/6/02
+5/14/02
+5/28/02
+5/30/02
+6/20/02
+9/3/02
+9/3/02
+9/5/02
+919/02
+9/11/02
+9/23/02
+10/4/02
+11/11/02
+2/1/03
+2/7/03
+2/19/03
+2/25/03
+Stockholm School of Economics
+Santa Fe Institute
+Engines for Education
+The Prize for Promise
+Harvard University
+Engines for Education
+Council on Foreign Relations
+Trilateral Commission
+New York University
+The Prize for Promise
+Santa Fe Institute
+Massachusetts Institute of Technology
+Ballet Florida
+The Schneider Fund
+Neurosciences Research Foundation, Inc.
+The Dalton School
+Harvard University
+Edge Foundation, Inc.
+25,000
+50,000
+62,500
+10,000
+200,000
+62,500
+25,000
+25,000
+71,000
+100,000
+100,000
+15,000
+7,000
+250,000
+75,000
+110,000
+50,000
+1,245,000
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+Form 8566(12-2000)'
+• If you are filing for an Additional (not automatic) 3-Month Extension, complete only Part Il and check this box
+Note: Only complete Part il if you have already been granted an automatic 3-month extension on a previously filed Form 8868.
+• If you are filing for an Automatic 3-Month Extension, complete only Part i (on page 1).
+Additional (not automatic) 3-Month Extension of Time - Must File Original and One Copy.
+Emanlamar Identifeation number
+Type or
+File by the
+extended
+due date for
+fling the
+See
+instructions
+Form 990
+THE C.O.U.Q. FOUNDATION,
+Number, street, and room or suite no. If a P.O. box, see instructions
+C/O GEORGE V. DELSON ASSOCIATES
+City. town or nost office, state, and ZIP code For a foreign address, see instructions
+For IRS use only
+Check type of return to be filed (File a separate application for each return)
+Form 990-EZ
+Form 990-T (sec 401(a) or 408(a) trust)
+Form 1041-A
+Form 5227
+Form 8870
+X For 990-PF
+Form 990-T (trust other than above)
+STOP: Do not complete Part I if you were not already granted an automatic 3-month extension on a previously filed Form 8868.
+• If the organization does not have an office or place of business in the United States, check this box.
+• If this is for a Group Return, enter the organization's four digit Group Exemption Number (GEN)
+for the whole group, check this box •
+If it is for part of the group, check this box
+and attach a list with the
+names and EINs of all members the extension is for
+4 I request an additional 3-month extension of time until January 15, 2005
+5 For calendar year
+, or other tax year beginning March 1, 2003
+and ending February 29, 2004
+6 If this tax year is for less than 12 months, check reason
+_ Initial return
+Final return
+_ Change in accounting period
+7
+State in detail why you need the extension Certain information necessary for the proper completion of
+the return is not yet available.
+8a
+If this application is for Form 990-BL, 990-PF, 990-T, 4720, or 6069, enter the tentative tax, less any
+nonrefundable credits See instructions
+5,000
+b If this application is for Form 990-PF, 990-T, 4720, or 6069, enter any refundable credits and estimated
+tax payments made. Include any prior year overpayment allowed as a credit and any amount paid
+previously with Form 8868
+5,000
+- Balance Due. Subtract line 8b from line Ba. include your payment with this form, or, if required, deposit
+with FTD coupon or, if required, by using EFTS (Electronic Federal Tax Payment System). See
+instructions
+Signature and Verification
+EXTENSION APPROVED
+Unduf penaltes of perjury 1 declare that I have exammed this form, including accompanying schedules and statements, and lo the best of my knowledge and belt.
+it is true, correct, and complele, and that 1 am authonzed to prepare this form
+OCT 25 2004
+Signature
+CPA
+Notice to Applicant - To Be Completed by the IRS
+SUBMISSIONPROCESSING,OGDEN
+We have approved this application. Please attach this form to the organization's return.
+We have not approved this application. However, we have granted a 10-day grace period from the later of the date shown below or the due
+date of the organization's retum (including any prior extensions). Thus grace period is considered to be EXTENSIN APPROVELiOnS
+otherwise required to be made on a timely return. Please attach this form to the organization's return.
+Weave nor approved this a pication. Aler considering the reasons slated in item 7, we cannot grant your rot 2 3 28 gion of time
+to file. We are not granting a 10-day grace period.
+We cannot consider this application because it was filed after the due date of the return for which an extension i Gue DORMECTOR.
+Other
+By
+SUBMISSION-PROCESSING OGET
+Director
+Date-
+Alternate Mailing Address - Enter the address if you want the copy of this application for an additional 3-month extension
+returned to an address different than the one entered above.
+Name
+George V. Delson Associates
+Type or
+Number and street (include suite, room, or apt. no.) Or a P.O. box number
+CAN on dee, and country (including postal or ZIP code)
+
+Form 8868(12-2000)
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+Form Bose (12-2000)'
+Page
+• If you are filing for an Additional (not automatic) 3-Month Extension, complete only Part Il and check this box
+.. •
+Note: Only complete Part Il if you have already been granted an automatic 3-month extension on a previously filed Form 8868.
+• If you are filing for an Automatic 3-Month Extension, complete only Part | (on page 1).
+Part I! Additional (not automatic) 3-Month Extension of Time - Must File Original and One Copy.
+Name of Exempt Organization
+Type or
+THE C.O.U.Q. FOUNDATION,
+File by the
+Number, street, and room or suite no. If a P.O. box, see instructions
+For IRS use only
+extended
+due date for
+C/O GEORGE V. DELSON ASSOCIATES,
+filing the
+City, town or post office, state, and ZIP code For a foreign address, see instructions
+retum See
+instructions
+Check type of return to be filed (File a separate application for each return):
+Form 990
+Form 990-EZ
+Form 990-T (sec 401(a) or 408(a) trust)
+Form 990-BL X Form 990-PF
+Form 990-T (trust other than above)
+Form 1041-A
+Form 4720
+Form 5227
+Form 8870
+Form 6069
+STOP: Do not complete Part Il if you were not already granted an automatic 3-month extension on a previously filed Form 8868.
+• If the organization does not have an office or place of business in the United States, check this box, ..
+...
+• If this is for a Group Return, enter the organization's four digit Group Exemption Number (GEN)
+for the whole group, check this box •
+If it is for part of the group, check this box
+and altach a list with the
+names and EINs of all members the extension is for.
+4
+I request an additional 3-month extension of time until January 15, 2005
+5
+For calendar year
+, or other tax year beginning March 1, 2003
+_and ending Fabruary 29, 2004
+6
+If this tax year is for less than 12 months, check reason
+_ initial return
+L Final return
+J Change in accounting period
+7
+State in detail why you need the extension Certain information necessary for the proper completion of
+the return is not yot available.
+If this application is for Form 990-BL, 990-PF, 990-T, 4720, or 6069, enter the tentative tax, less any
+nonrefundable credits See instructions
+b
+If this application is for Form 990.PF, 990-T, 4720, or 6069, enter any refundable credits and estimated
+tax payments made. Include any prior year overpayment allowed as a credit and any amount paid
+previously with Form 8868
+Balance Due. Subtract line Bb from line 8a. Include your payment with this form, or, if required, deposit
+with FTD coupon or, if required, by using EFPS (Electronic Federal Tax Payment System). See
+instructions
+5,000
+5,000
+Signature and Verification
+EXTENSIONAPPROVED
+Under penalies of perjury, I declare that I have examined this form, including accompanying schedules and statements, and to the best of my knowledge and belief.
+if is tfue, correct, and complete, and that 1 am authonzed to prepare this form
+OCT 2 5 2004
+Signature
+CPA
+Notice to Applicant - To Be Completed by the IRS
+SUBMISSINPROCESSING,OGDEN
+We have approved this application. Please attach this form to the organization's return.
+We have not approved this application. However, we have granted a 10-day grace period from the later of the date shown below or the due
+date of the organization's retum (including any prior extensions). This grace period is considered to be EXTENSION APPROVEDiOnS
+otherwise required to be made on a timely return. Please attach this form to the organization's return.
+We have not approved this application. After considering the reasons stated in item 7, We cannot grant your ta 2 5 208/i on of time
+to file. We are not granting a 10-day grace period.
+We cannot consider this application because it was filed after the due dale of the return for which an extensio we lue dOMECTOR.
+SUBISSION PROCESSING OGDENT
+Alternate Mailing Address - Enter the address if you want the copy of this application for an additional 3-month extension
+returned to an address different than the one entered above.
+Name
+George V. Delson Associates
+Type or
+rite, room, or apt. no.) Or a P.O. box number
+and country (including postal or ZIP code)
+
+Fom 8868(12-2000)
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+Form 8658 (Rev 12-2004)
+• If you are filing for an Additional (not automatic) 3-Month Extension, complete only Part Il and check this box
+• 7
+Note. Only complete Part If if you have already been granted an automatic 3-month extension on a previously filed Form 8868.
+• If you are filing for an Automatic 3-Month Extension, complete only Part | (on page 1).
+Part I
+Additional (not automatic) 3-Month Extension of Time Must File Original and One Copy.
+Type or
+Name of Exempt Organization
+on number
+The C.O.U.G Foundation, Inc.
+File by the
+Number, street, and room or suite n
+extended
+due date for
+c/o George V. Delson Associates
+tructions
+For IRIS use only
+filing the
+retum
+See
+a, state, and 2P code For a foregn address, see instructions
+instructions
+Check type of return to be filed (File a separate application for each return).
+• Form 990
+• Form 990-T (sec. 401(a) or 408(a) trust)
+• Form 990-BL
+Form 990-T (trust other than above)
+Form 990-EZ
+Form 1041-A
+• Form 5227
+• Form 6069
+• Form 8870
+[Z Form 990-PF
+Form 4720
+STOP: Do not complete Part il if you were not already granted an automatic 3-month extension on a previcusly filed Form B868.
+• The books are in the care off Harry Beller
+Telephone No. •
+FAX No
+• If the organization does not have an office or place of business in the United States, check this box
+• If this is for a Group Return, enter the organization's four digit Group Exemption Number (GEN)
+for the whole group, check this box
+D. If it is for part of the group, check this box •
+- If this Is
+• and attach a list with the
+names and EiNs of all members the extension is for
+4
+1 request an additional 3-month extension of time until
+_January 15
+5
+.20.06
+For calendar year …... or other tax year begınning . ...
+......20.04. and ending... February 28
+6
+...... 20.95
+If this tax year is for less than 12 months, check reason. • Initial return • Final return Change in accounting period
+7
+State in detail why you need the extension Certain information necessary for the proper completion of the return is ...
+not yet available.
+Ba If this application is for Form 990-BL, 990-PF, 990-T, 4720, or 6069, enter the tentative fax, less any
+nonrefundable credits. See instructions
+27,679
+b If this application is for Form 990-PF, 990-T, 4720, or 6069, enter any refundable credits and estimated
+tax payments made. Include any prior year overpayment allowed as a credit and any amount paid
+previously with Form 8868
+27,679
+c Balance Due. Subtract line 8b from line Ba. Include your payment with this form, or, if requred, deposit
+with FTD coupon or. if required, by using EFTS (Electronic Federal Tax Payment System). See instructions.
+$
+0
+Signature and Verification
+Jnder penalties of perury,/ declare that, have examined this form, including accompanying schedules and statements, and to the best of my knowledge and belie
+it is true, correct, and complete
+fat, ham authonzed to prepare this for
+Signature •
+Date!
+mulolus.
+Title •
+Notice to Applicant-To Be Completed by the IRS
+We have approved this application Please attach this form to the organization's retum.
+ve have not approved this application However, we have granted a 10-day grace period from the later of the date shown below or the du
+ate of the organization's return (including any pror extensions) This grace period is considered to be a valid extension of time for electior
+otnerwise required to be made on a timely return Please attach this form to the organization's return
+we have not approved this application After considering the reasons stated in item 7, we cannot grant your request for an extension of time
+to file We are not granting a 10-day grace penod
+We cannot consider this application because it was filed after the extended due date of the return for which an extension was requested
+Other
+• By -
+Director
+Date
+Alternate Mailing Address - Enter the address if you want the copy of this application for an additional 3-month extension
+returned to an address different than the one entered above
+Name
+George V. Delson Associates
+L...
+Murabne and storet finchide suite, room, or apt. no.) or a P.O. box number
+Type or
+state, and country (including postal or ZIP code)
+Form 8868 (Rev 12-2004)
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+Form 8868 (Rev 12-2004)
+you are tiling for an Additional (not automatic) 3-Month Extension, complete only Part I and check this bo
+lote. Only complete Part Il if you have already been granted an automatic 3-month extension on a previously filed Form B86
+• if you are filing for an Automatic 3-Month Extension, complete only Part | (on page 1).
+Part I
+Additional (not automatic) 3-Month Extension of Time--Must File Original and One Copy.
+Type or
+Name of Exempt Organization
+Employer identification number
+File by the
+Number Street, and room or suite on If a BO bar coo instactions.
+extended
+For IRS use only
+due date for
+filing the
+rotum
+See
+City, town or post office, state, and ZIP code. For a foreign address, see instructions.
+instructions.
+Check type of return to be filed (File a separate application for each return):
+• Form 990
+Form 990-T (sec. 401(a) or 408(a) trust)
+• Form 990-BL
+Form 990-T (trust other than above)
+• Form 990-EZ
+Form 1041-A
+• Form 5227
+• Form 6069
+• Form 8870
+Form 990-PF
+Form 4720
+STOP: Do not complete Part Il If you were not already granted an automatic 3-month extension on a previously filed Form 8868.
+• The books are in the care of - HARRY BELLER
+Telephone No. • (
+• If the organization does not have an office or place of business in the United States, check this box
+• If this is for a Group Retum, enter the organization's four digit Group Exemption Number (GEN)
+for the whole group, check this box
+O. If it is for part of the group, check this box •
+names and EINs of all members the extension is for.
+4 I request an additional 3-month extension of time until
+JANUARY 15
+- 20.07
+5
+For calendar year ........ or other tax year beginnıng.......
+MARCH 1
+....20.05, and ending... FEBRUARY 28
+.,20.06.
+If this tax year is for less than 12 months, check reason:
+• Initial retum
+7
+• Final retum • Change in accounting period
+State in detail why you need the extension CERTAIN INFORMATION NECESSARY FOR THE PROPER COMPLETION...
+OF THE RETURN IS NOT YET AVAILABLE:
+Ba if this application is for Form 990-BL, 990-PF, 990-T, 4720, or 6069, enter the tentative tax, less any
+nonrefundable credits. See instructions
+37,767
+b if this application is for Form 990-PF, 990-T, 4720, or 6069, enter any refundable credits and estimated
+tax payments made. Include any prior year overpayment allowed as a credit and any amount paid
+previously with Form 8868
+$
+37,767
+© Balance Due. Subtract line 8b from line Ba. Include your payment with this for, or, if required, deposit
+with FTD coupon or, if required, by using EFTS (Electronic Federal Tax Payment System). See instructions.
+Signature and Verification
+Under penaltes of peury, I declare that i have exarned thes form, including accompanying schedules and statements, and to the best of my knowledge and beiet,
+it is true, correct, and complete, and that I am authonzed to prepare this form
+Signature •
+/S/ GEORGE V DELSON
+Date •
+10/16/06
+Title P
+Notice to Applicant-To Be Completed by the IRS
+We have approved this application. Please attach this form to the organization's retum.
+We have not approved this application However, we have granted a 10-day grace period from the later of the date shown below or the due
+date of the organization's retum (including any prior extensions). This grace penod is considered to be a valid extension of time for elections
+otherwise required to be made on a timely retum. Please attach this form to the organization's retum.
+We have not approved this application. After considering the reasons stated in item 7, we cannot grant your request for an extension of time
+to file. We are not granting a 10-day grace penod,
+We cannot consider this application because it was filed after the extended due date of the retum for which an extension was requested.
+Other
+By.
+Director
+Alternate Mailing Address - Enter the address if you want the copy of this application for an additional 3-month extension
+returned to an address different than the one entered above
+Name
+GEORGE V. DELSON ASSOCIATES
+Type or
+Humbar and strant finchuda suito, room, or apt. no.) or a P.O. box number
+and country (including postal or ZIP code)
+Form 8868 (Rew 12-2004)
+
+
+
+
+Form
+8868
+Application for Extension of Time To File an
+(Rev. December 2004)
+Exempt Organization Return
+OMB No 1545-1709
+Department of the Treasury
+Internal Revenue Service
+• File a separate application for each return.
+• If you are filing for an Automatic 3-Month Extension, complete only Part 1 and check this box.
+• If you are filing for an Additional (not automatic) 3-Month Extension, complete only Part I (on page 2 of this form).
+Do not complete Part Il unless you have already been granted an automatic 3-month extension on a previously filed Form 8868.
+Part|
+Automatic 3-Month Extension of Time-Only submit original (no copies needed)
+Form 990-T corporations requesting an automatic 6-month extension-check this box and complete Part I only .
+...
+All other corporations (including Form 990-C filers) must use Form 7004 to request an extension of time to file income tax retums.
+Partnerships, REMICs, and trusts must use Form 8736 to request an extension of time to file Form 1065, 1066, or 1041.
+Electronic Filing (e-file). Form 8868 can be filed electronically if you want a 3-month automatic extension of time to file one of the
+retums noted below (6 months for corporate Form 990-T filers). However, you cannot file it electronically if you want the additional
+(not automatic) 3-month extension, instead you must submit the fully completed signed page 2 (Part il) of Form 8868. For more
+details on the electronic filing of this form, visit www.irs.gov/efile.
+Type or
+Name of Exempt Organization
+The C.O.U.Q. Foundation
+Employer identification number
+13: 3996471
+File by the
+due date for
+15.
+fling your
+return. See
+Instructions.
+City, lown or post office, state, and ZIP code. For a foreign address, see instructions.
+Check type of return to be filed (file a separate application for each return):
+• Form 990
+• Form 990-BL
+• Form 990-EZ
+/ Form 990-PF
+• Form 990-T (corporation)
+• Form 990-T (sec. 401(a) or 408(a) trust)
+• Form 990-T (trust other than above)
+• Form 1041-A
+• Form 4720
+• Form 5227
+• Form 6069
+• Form 8870
+• The books are in the care of Harry. Beller.
+Telephone No. •
+FAX No. •
+• If the organization does not have an office or place of business in the United States, check this box
+• If this is for a Group Return, enter the organization's four digit Group Exemption Number (GEN).
+is for the whole group, check this box D. If it is for part of the group, check this box
+and attach a list with the
+names and EINs of all members the extension will cover.
+1
+I request an automatic 3-month (6-months for a Form 990-T corporation) extension of time until October 15.
+,20.06.
+to file the exempt organization return for the organization named above. The extension is for the organization's retum for:
+• • calendar year 20... or
+7 tax year beginning
+March 1
+.20.05, and ending
+February..
+, 2006.
+2 If this tax year is for less than 12 months, check reason: • Initial return Final retum • Change in accounting period
+3a If this application is for Form 990-BL, 990-PF, 990-T, 4720, or 6069, enter the tentative tax, less any
+nonrefundable credits. See instructions
+37,767
+b If this application is for Form 990-PF or 990-T, enter any refundable credits and estimated tax payments
+made. Include any prior year overpayment allowed as a credit
+$
+12,767
+c Balance Due. Subtract line 3b from line 3a. Include your payment with this form, or, if required, deposit
+with FTD coupon or, if required, by using EFTS (Electronic Federal Tax Payment System). See
+Caution. If you are going to make an electronic fund withdrawal with this Form 8868, see Form 8453-EO and Form 8879-E0
+for payment instructions.
+For Privacy Act and Paperwork Reduction Act Notice, see Instructions.
+Cat No. 27916D
+Fom 8868 (Rev 12-2004)
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+Form
+8868
+Application for Extension of Time To File an
+(Rev Apni 2007)
+Exempt Organization Return
+OMB No 1545-1709
+Department of the Treasury
+Internal Revenue Service
+• File a separate application for each return.
+• If you are filing for an Automatic 3-Month Extension, complete only Part I and check this box
+• 7
+• If you are filing for an Additional (not automatic) 3-Month Extension, complete only Part I (on page 2 of this form).
+Do not complete Part i unless you have already been granted an automatic 3-month extension on a previously filed Form 8868.
+Part
+Automatic 3-Month Extension of Time. Only submit original (no copies needed).
+Section 501(c) corporations required to file Form 990-T and requesting an automatic 6-month extension-check this box and
+complete Part I only
+• O
+All other corporations (including 1120-C filers), partnerships, REMICs, and trusts must use Form 7004 to request an extension of
+time to file income tax retums.
+Electronic Filing (e-file). Generally, you can electronically file Form 8868 if you want a 3-month automatic extension of time to file
+one of the retums noted below (6 months for section 501(c) corporations required to file Form 990-T). However, you cannot file Form
+8868 electronically it (1) you want the additional (not automatic) 3-month extension or (2) you file Forms 990-BL, 6069, or 8870, group
+retums, or a composite or consolidated Form 990-T. Instead, you must submit the fully completed and signed page 2 (Part Il) of Form
+8868. For more details on the electronic filing of this form, visit www.irs.gov/efile and click one-file for Charities & Nonprofits.
+Type or
+Name of Exempt Organization
+File by the
+due date for
+Number, street, and room or suite no. If a BO. bax, aas nain ations.
+filing your
+return
+See
+instructions
+state, and ZIP code. For a foreign address, see instructions.
+Check type of return to be filed (file a separate application for each return):
+• Form 990
+• Form 990-T (corporation)
+• Form 990-BL
+• Form 990-T (sec. 401(a) or 40B(a) trust)
+• Form 990-EZ
+• Form 990-T (trust other than above)
+7l Form 990-PF
+• Form 1041-A
+• Form 4720
+• Form 5227
+• Form 6069
+• Form 8870
+• The books are in the care of • Harry. Beller
+Telephone No
+• If the organization does not have an office or place of business in the United States, check this box
+• If this is for a Group Return, enter the organization's four digit Group Exemption Number (GEN)
+for the whole group, check this box......• • . If it is for part of the group, check this box
+..•
+.. If this is
+and attach
+a list with the names and EiNs of all members the extension will cover.
+1 request an automatic 3-month (6 months for a section 501(c) corporation required to file Form 990-T) extension of time
+..., to file the exempt organization return for the organization named above. The extension is
+for the organization's retum for:
+• calendar year 20....... or
+....20.06, and ending.
+2 If this tax year is for less than 12 months, check reason: Initial return Final return • Change in accounting period
+3a if this application is for Form 990-BL, 990-PF, 990-T, 4720, or 6069, enter the tentative tax,
+less any nonrefundable credits. See instructions.
+b If this application is for Form 990-PF or 990-T, enter any refundable credits and estimated tax
+payments made. Include any prior year overpayment allowed as a credit.
+8,000
+18.872
+• Balance Due. Subtract line 3b from line 3a. Include your payment with this form, or, if required
+Jeposit with FTD coupon or, if required, by using EFTPS (Electronic Federal Tax Paymen
+System). See instructions.
+Caution. if you are going to make an electronic fund withdrawal with this Form 8868, see Form 8453-EO and Form 8879-EO
+for payment instructions.
+For Privacy Act and Paperwork Reduction Act Notice, see instructions.
+Cat No 27916D
+Form 8868 (Rev. 4-2007)
+
+
+
+
+Form 8808 (Rev. 4-2007)
+• If you are filing for an Additional (not automatic) 3-Month Extension, complete only Part Il and check this box
+Note. Only complete Part il if you have already been granted an automatic 3-month extension on a previously filed Form 8868
+• If you are filing for an Automatic 3-Month Extension, complete only Part | (on page 1).
+Part I!
+Additional (not automatic) 3-Month Extension of Time. You must file original and one copy.
+Type or
+Name of Exempt Organization
+prnt
+THE C.0.U.Q. FOUNDATION, INC.
+File by the
+extended
+Number, street, and room or suite no It a B0 hor see instructions
+For IRS use only
+due date for
+c/o GEORGE V. DELSON ASSOCIATES,
+filing the
+diate, and ZIP code For a foreign address, see instructions,
+•; -
+•. %
+retum. Sea
+instructions.
+Check type of retum to be filed (File a separate application for each retum):
+• Form 990
+I2 Form 990-PF
+Form 1041-A
+Form 6069
+Form 990-BL
+• Form 990-T (sec. 401(a) or 408(a) trust)
+Form 4720
+Form 8870
+Form 990-EZ
+• Form 990-T (trust other than above)
+Form 5227
+STOP! Do not complete Part Il if you were not already granted an automatic 3-month extension on a previously filed Form 8868.
+• The books are in the cars of HARRY BELLER
+Telephone No. *
+• If the organization
+Goes not have an olice of place of business in the United States, check this box
+• If this is for a Group Retum, enter the organization's four digit Group Exemption Number (GEN)
+if this is
+for the whole group, check this box ....
+.. • O. If it is for part of the group, check this box.
+• • and attach a
+list with the names and EINs of all members the extension is for.
+4 I request an additional 3-month extension of time until
+JANUARY 15
+20.08
+5 For calendar year........, or other tax year beginning...
+MARCH 1
+...20.06, and ending
+FEBRUARY 28
+...20.07..
+6
+If this tax year is for less than 12 months, check reason:
+• Intial return
+L Final retum
+7
+• Change in accounting period
+State in detail why you need the extension CERTAIN INFORMATION NECESSARY FOR A COMPLETE AND ACCURATE RETURN
+IS NOT YET AVAILABLE
+Ba: If this application is for Form 990-BL, 990-PF, 990-T, 4720, or 6069, enter the tentative tax,
+less any nonrefundable credits. See instructions.
+8a
+$ 8,000
+b If this application is for Form 990-PF, 990-T, 4720, or 8069, enter any refundable credits and
+estimated tax payments made. Include any prior year overpayment allowed as a credit and any
+amount paid previously with Form 8888
+8b $ 18,872
+c Balance Due. Subtract line 8b from line Ba. Include your payment with this form, or, if required, deposit
+with FTD coupon or, if required, by using EFTPS (Electronic Foderal Tax Payment System). See instructions.
+8c $.0
+Signature and Verification
+Under penaltes of perjury, I declare that I have examined this form, including accompanying schedules and stataments, and to the best of my knowledge and belief,
+it is true, correct, and complate, and that I am authonzed to prepare this form.
+Signature •
+Date F
+L
+Notice to Applicant. (To Be Completed by the IRS)
+We have approved this application Please attach this form to the organization's return.
+le have not approved this application However, we have granted a 10-day grace perlod from the later of the date shown below or the di
+late of the organization's return (including any prior extensions). This grace period is considered to be a valid extension of time for electior
+otherwise required to be made on a timely refum. Pisase attach this form to the organization's ratum.
+ve have not approved this application. After considering the reasons stated in item 7, We cannot grant your request for an extension of tim
+o file. We are not granting a 10-day grace perio
+We cannot consider this application because it was filed after the extended due date of the retum for which an extension was requested
+Other..
+By: -
+Diractor
+Date
+Alternate Mailing Address. Enter the address if you want the copy of this application for an additional 3-month extension
+returned to an address different than the one entered above.
+Name
+Type or
+Number and street (include sulte, room, or apt. no.) or a P.O. box number
+City or town, province or state, and country (Including postal or ZIP code)
+Form 8868 (Rov 4-2007)
+
diff --git a/vision-fixhub/ds9-unparsed-05/ae5f470ae3e7f752b787e354b4c2a699bbbdbcc383e598d7976984edd03f6ab9.receipt.json b/vision-fixhub/ds9-unparsed-05/ae5f470ae3e7f752b787e354b4c2a699bbbdbcc383e598d7976984edd03f6ab9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2f4c0a7f5d86c68454b368eb3d56e85d70fc52b8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ae5f470ae3e7f752b787e354b4c2a699bbbdbcc383e598d7976984edd03f6ab9.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -7430,
+  "dataset": "marble-joined",
+  "doc_id": "ae5f470ae3e7f752b787e354b4c2a699bbbdbcc383e598d7976984edd03f6ab9",
+  "engine": "marble-apple-vision",
+  "event_count": 349,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "91ab929776f2ca03c041182d1281b110d293f70bbde1e8345a25e711fb17efe4",
+  "output_sha256": "7cf4532cec59e95e39f404b5bfbb3022ec3b996af33077f5547aba09c2beba71",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/aea0c63b87812d7cf83907a65d6639e7f7a8adb406da4c3eab532bcfff7023a4.md b/vision-fixhub/ds9-unparsed-05/aea0c63b87812d7cf83907a65d6639e7f7a8adb406da4c3eab532bcfff7023a4.md
new file mode 100644
index 0000000000000000000000000000000000000000..a0a059de2394541d392e14c7786fd0483689f6d8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/aea0c63b87812d7cf83907a65d6639e7f7a8adb406da4c3eab532bcfff7023a4.md
@@ -0,0 +1,62 @@
+ATTACHMENT TO PETITE POLICY WAIVER REQUEST
+RE JEFFREY EPSTEIN
+Continuation of Description of Acts Resulting in Prior Prosecution:
+Epstein delayed his guilty plea and sentencing for nine months, while he tried to renegotiate
+the terms of the Agreement. Finally, on June 30, 2008, Epstein pled to the state charges and was
+sentenced to the 18 months. Rather than serve his sentence in the state prison system, he was
+sentenced to the Palm Beach County Stockade, a low-security "camp" in West Palm Beach. Epstein
+also was placed on "work release" within three months of starting his sentence. Under the "work
+release" program, Epstein is picked up by his chauffeur every morning and transported to his
+attorney's office in West Palm Beach, where he stays all day. According to news reports, the Palm
+Beach Sheriff's Office spokesperson states that Epstein is allowed out on "work release" from 7:00
+a.m. to 11:00 p.m. every day of the week. Epstein also earns additional "gain time" for "working"
+while in jail, so he is expected to be released from his term of imprisonment on June 24, 2009 -
+serving less than one year.
+Epstein also has fought the payment of restitution to the named victims of the federal
+offenses. The federal distriet judge presiding over all of the civil suits filed by the victims has
+ordered the U.S. Attorney's Office to appear in court on Friday, June 12, 2009 to address the issue
+of whether Epstein has breached his agreement with the U.S. Attorney's Office by opposing the
+payment of damages to the victims. After a careful review of Epstein's pleadings in those cases, the
+Office has determined that Epstein is in breach. Notification of that breach will be delivered to
+Epstein at the hearing. On Tuesday, June 16, 2009, the U.S. Attorney's Office would like to present
+an indictment charging Epstein and three of his assistants with violations of Title 18, United States
+Code, Sections 371, 1591(a), 1591(b), 2422(b), 2423(b), and 2423(e). The proposed indictment
+contains charges and overt acts related to 19 victims, including
+The federal charges do not
+overlap with the state charges and the federal indictment will charge Epstein's co-conspirators, not
+just Epstein.
+As explained below, the federal sentence for these offenses will likely be approximately 15
+years' imprisonment, with a mandatory minimum sentence of five years' imprisonment, followed by
+lifetime supervised release. The inclusion of
+. in the indictment will not have an effect on
+Epstein's guideline sentence (under the Guidelines, Epstein's advisory range will remain the same
+if he is convicted for violations related to 5 girls or more).
+is, however, an intricate part of the
+proof against Epstein and, importantly, against his assistants, who were not prosecuted at all by the
+State Attorney's Office. At this time, it is anticipated that we may seek a superseding indictment,
+depending on possible cooperation by one or more of Epstein's assistants and based upon the victims
+who were identified but not positively confirmed. It is possible that
+. will be added to the
+superseding indictment. Again, the addition of
+1. Will not affect Epstein's advisory guideline
+range, but including her would help to explain how Epstein's crimes were brought to the attention
+of law enforcement.
+In light of the extremely lenient sentence that Epstein received, Epstein's refusal to
+compensate his victims for their injuries, and the fact that Epstein's co-conspirators have received
+
+
+no punishment for their criminal activity, I respectfully request that OEO determine that the Petite
+policy does not apply to the prosecution of Epstein and his co-conspirators or that waiver of the
+policy is appropriate under these circumstances.
+Continuation of Discussion of Federal Interest:
+Although all of the victims who will be mentioned in the current indictment resided in the
+Southern District of Florida at the time of the offenses, victims from other Districts throughout the
+United States have been identified and it is anticipated that some will be part of a superseding
+indictment. From the investigation, several victims reported Epstein's constant demand for "new"
+and "fresh faces," leading to the enticement of more and more victims.
+The state prosecution resulted in a very lenient sentence based on only two victims, despite
+the State Attorney's knowledge of the existence of many more, and Epstein has received preferential
+treatment while serving that sentence. The federal investigation resulted in the identification of an
+even larger number-more than 30 confirmed, which also warrants federal prosecution. Finally,
+Epstein's co-conspirators have received no criminal punishment whatsoever, and the federal victims
+have received no restitution for the damages that they have suffered.
diff --git a/vision-fixhub/ds9-unparsed-05/aea0c63b87812d7cf83907a65d6639e7f7a8adb406da4c3eab532bcfff7023a4.receipt.json b/vision-fixhub/ds9-unparsed-05/aea0c63b87812d7cf83907a65d6639e7f7a8adb406da4c3eab532bcfff7023a4.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..be322e4125d00eac97edd5ab87abfe75e6ffd1c5
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/aea0c63b87812d7cf83907a65d6639e7f7a8adb406da4c3eab532bcfff7023a4.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "aea0c63b87812d7cf83907a65d6639e7f7a8adb406da4c3eab532bcfff7023a4",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "6d2a15b30ca9ee74c5dd2f8394d0fa0f9a90bf857d1695ca811bdc1e793d74cf",
+  "output_sha256": "b22f7f8a4903d0966f829915c8bddc68556f7ea8ac14b49facb88f1cf256e304",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/afaf8bbee0338e274f6258e75a9aeddaa53f5868906381bf4988802c5735f937.md b/vision-fixhub/ds9-unparsed-05/afaf8bbee0338e274f6258e75a9aeddaa53f5868906381bf4988802c5735f937.md
new file mode 100644
index 0000000000000000000000000000000000000000..0de9204ca5f203bdd3a63b68ba2bd2fdec2f1483
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/afaf8bbee0338e274f6258e75a9aeddaa53f5868906381bf4988802c5735f937.md
@@ -0,0 +1,29 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+West Palm Beach, FL 33401
+(561) 820-8711
+500 South Australian Ave., Suite 400
+Facsimile: (561) 820-8777
+April 9, 2008
+VIA FACSIMILE
+Richard H. Willets, Esq.
+Mr. Michael Danchuk
+2290 10th Avenue North, Suite 404
+Lake Worth, FL 33461
+Re:
+Dear Messrs. Willits and Danchuk:
+Thank you for your letter of March 28, 2008, regarding)
+. Pursuant to the
+rict rules of grand jury secrecy, I am not able to provide you with the intormation that you hav
+quested. I believe that some of the information vou are seeking is available from publi
+sources on the internet. We also do not have any photographs of Ms!
+I regret that I cannot be of more assistance. I would appreciate it if you would keep me
+updated on the course of the civil litigation.
+By:
+Sincerely,
+R. Alexander Acosta
+United States Attorney
+Assistant United States Attorney
+cc
+FBI
diff --git a/vision-fixhub/ds9-unparsed-05/afaf8bbee0338e274f6258e75a9aeddaa53f5868906381bf4988802c5735f937.receipt.json b/vision-fixhub/ds9-unparsed-05/afaf8bbee0338e274f6258e75a9aeddaa53f5868906381bf4988802c5735f937.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..27d80cfb29ef31ff8bbfaf15743a3da04f53b150
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/afaf8bbee0338e274f6258e75a9aeddaa53f5868906381bf4988802c5735f937.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "afaf8bbee0338e274f6258e75a9aeddaa53f5868906381bf4988802c5735f937",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "88431102a68bfb01ae5ce205a71b1dc99dc28df3c93875aec19a88e40e234bd0",
+  "output_sha256": "9b73e6624916b52f055352606006769bbf78b176fa53e12aeeeaab13bfc18d41",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b032196deb92cf91ce464b64e4b0bb726f34b76339bd9059cd9ca9ec85684336.md b/vision-fixhub/ds9-unparsed-05/b032196deb92cf91ce464b64e4b0bb726f34b76339bd9059cd9ca9ec85684336.md
new file mode 100644
index 0000000000000000000000000000000000000000..f0c082db8e94f71b06ed361686ba2db5fe0fbb24
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b032196deb92cf91ce464b64e4b0bb726f34b76339bd9059cd9ca9ec85684336.md
@@ -0,0 +1,2833 @@
+-
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-CIV-Marra/Matthewman
+JANE DOE #1 and JANE DOE #2,
+Petitioners,
+v.
+UNITED STATES OF AMERICA,
+Respondent.
+UNITED STATES' RESPONSE TO
+PETITIONERS' FIRST REQUEST FOR ADMISSIONS TO THE GOVERNMENT
+The United States (hereinafter the "government") hereby responds to Jane Doe #1 and
+Jane Doe #2's First Request for Admissions to the Government Regarding Questions Relevant to
+Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Request for
+Admissions"), and states as follows:*
+1. The government admits that the FBI and the U.S. Attorney's Office for the Southern
+District of Florida ("USAO") conducted an investigation into Jeffiey Epstein
+("Epstein") and developed evidence and information in contemplation of a potential
+federal prosecution against Epstein for many federal sex offenses.
+Except as
+otherwise admitted above, the government denies Request No. 1.
+Senith les of which appenie st assraiy sath go mamen ali defined the request of
+
+
+:
+2. (a) The government admits that, after Epstein's attorneys learned of the notification
+that the government planned to provide to Jane Doe #2, who claimed that she was
+not a victim, Epstein's attorneys contacted the USAO and objected to the
+procedures for notification and the legal bases therefor. The government further
+admits that the USAO considered those objections when evaluating what
+notification to provide to victims.
+Except as otherwise admitted above, the
+government denies Request No. 2(a).
+(b) Admitted.
+(c) The government admits that, as a result of objections lodged by Epstein's
+attorneys, the government reevaluated the notifications that it had intended to
+provide to victims and, as a result of that reevaluation, the USAO altered the
+scope, nature, and timing of notifications that it had contemplated providing to
+victims.
+With regard to Jane Doe #2, the government further admits that, as a
+result of representations made by Jane Doe #2 that she was not a victim and
+objections lodged by Epstein's attorneys, the USAO stopped making notifications
+to Jane Doe #2.
+Except as otherwise admitted above, the government denies
+Request No. 2(c).
+(d) The government admits that, after the USAO received objections to victim
+notifications from Epstein's counsel and reevaluated its victim notification
+obligations, the USAO altered the language that was ultimately contained in the
+July 9, 2008 notification letter to Jane Doe #1 in care of Bradley Edwards.
+Except as otherwise admitted above, the government denies Request No. 2(d).
+2
+
+
+(e) The government admits that, at least in part as a result of objections lodged by
+Epstein's lawyers to victim notifications, the USAO reevaluated its obligations to
+provide notifications to victims, and Jane Doe #1 was thus not told that the USAO
+had entered into a non-prosecution agreement with Epstein until after the
+agreement was signed. The government further admits that Jane Doe #2 was not
+told that the USAO had entered into a non-prosecution agreement with Epstein
+until after the agreement was signed, but denies that the USAO did not inform
+Jane Doe #2 as a result of any negotiations involving Epstein or any objections
+lodged by Epstein's lawyers; the USAO did not consider Jane Doe #2 a victim
+after she informed the USAO and the FBI that she was not a victim of any offense
+committed by Epstein, and, as a result, the USAO did not consider informing Jane
+Doe #2 about the non-prosecution agreement. Except as otherwise admitted
+above, the government denies Request No. 2(e).
+3. Denied.
+4. Denied.
+5. The government admits that, during the negotiations with Jeffiey Epstein regarding
+the non-prosecution agreement, at least one experienced attorney within the USAO
+subscribed to the position that the CVRA required notifications to the victims in this
+case and that position was communicated to Epstein's counsel. To the extent that
+Request No. 5 seeks admissions regarding the positions held by attorneys within the
+USAO that were not communicated to non-government personnel regarding whether
+or not the CVRA ultimately required notifications to the victims in this case, the
+government objects to Request No. 5 as violative of the deliberative process privilege.
+3
+
+
+6. (a) Denied.
+(b) Denied.
+(c) Admitted.
+(d) Admitted.
+(e) Admitted to the extent that the reference to "Lillian Sanchez" was meant to refer
+to Lilly Ann Sanchez.
+(f) Admitted.
+(g) Admitted.
+7. The government admits that, on about January 10, 2008, when Jane Doe #1 and Jane
+Doe #2 were sent letters advising them that "this case is currently under
+investigation," the U.S. Attorney's Office had already signed a non-prosecution
+agreement with Jeffrey Epstein, but that, on that date, the non-prosecution agreement
+nonetheless remained in a state of some flux and was subject to being set aside as
+Epstein was challenging the propriety of the non-prosecution agreement and seeking
+further review from the Department of Justice.
+8. Denied.
+9. (a) The government admits that, at Epstein's insistence, the USAO agreed to a
+provision in the non-prosecution agreement that provided as follows: "The parties
+anticipate that this agreement will not be made part of any public record. If the
+United States receives a Freedom of Information Act request or any compulsory
+process commanding the disclosure of the agreement, it will provide notice to
+Epstein before making that disclosure." Except as otherwise admitted above, the
+government denies Request No. 9(a).
+4
+
+
+(b) Admitted.
+(c) Denied.
+(d) Denied.
+(e) The government admits that, during the period from September 24, 2007 through
+June 2008, the USAO did not notify Jane Doe #2 of the existence of the nonprosecution agreement. The government further admits that, although FBI agents
+notified Jane Doe #1 of the existence and substance of the agreement at the
+request of the USAO on or about October 27, 2007, no employee of the USAO
+personally notified Jane Doe #1 of the existence of the non-prosecution agreement
+during the period from September 24, 2007 through June 2008. Except as
+otherwise admitted above, the government denies Request No. 9(e).
+10. (a) Admitted. Because Request No. 10 appears directed solely to the communications between FBI agents and Jane Doe #l during their meeting on or about
+October 26, 2007, the government responses to Requests No. 10(b) through 10(g)
+address only that meeting.
+(b) The government admits that, on or about October 26, 2007, FBI agents explained
+to Jane Doe #1 that Epstein would plead guilty to state charges for procuring
+minors to engage in prostitution; that Epstein would be required to register as a
+sex offender; that Jane Doe #1 would be entitled to seek damages from Epstein;
+and that, if she desired, Jane Doe #1 would be entitled to use the services of an
+attorney at no expense to her in seeking those damages from Epstein. The
+government denies that the FBI agents explained that the state charges
+"involv[ed] another victim."
+5
+
+
+(c) The government denies that the FBI agents did not explain to Jane Doe #1 that an
+agreement had already been signed; denies that the FBI agents did not explain to
+Jane Doe #1 that the agreement resolved the investigation of the federal case
+involving Jane Doe #1; and denies that the FBI agents did not explain to Jane Doe
+#1 other terms of that agreement Except as otherwise admitted above, the
+government denies Request No. 10(c).
+(d) Denied.
+(e) Denied.
+(f) Denied.
+(g) Denied.
+11. The government admits that, on or about November 28, 2007, A. Marie Villafaña of
+the USAO sent a draft of a crime victim notification letter to Jay Lefkowitz, counsel
+for Jeffrey Epstein, and that the draft notification letter stated, in part: "I am writing
+to inform you that the federal investigation of Jeffiey Epstein has been completed,
+and Mr. Epstein and the U.S. Attorney's Office have reached an agreement
+containing the following terms ...." The government further admits that, in part as a
+result of objections lodged by Epstein's lawyers, the USAO reevaluated its
+obligations to provide notifications to victims, and, as a result of that reevaluation and
+other considerations and developments, the USAO never sent victims the draft
+notification letter that was sent to Jay Lefkowitz on or about November 28, 2007.
+Except as otherwise admitted above, the government denies Request No. 11.
+12. The government admits that, prior to July 3, 2008, the USAO had already entered a
+binding non-prosecution agreement with Jeffrey Epstein. The government is without
+6
+
+
+knowledge of precisely when "Bradley J. Edwards was working on a letter to the U.S.
+Attorney's Office concerning the need to federally prosecute Epstein for sex offenses
+committed against Jane Doe #1 and Jane Doe #2," and, accordingly, the government
+denies the assertion that Edwards worked on that letter on July 3, 2008. Except as
+otherwise admitted above, the government denies Request No. 12.
+13. (a) The government admits that, when Epstein pled guilty to state charges on June 30,
+2008, Jane Doe #2 had not been informed by the USAO of the existence of the
+non-prosecution agreement. The government further admits that, although the
+USAO, through FBI agents, had notified Jane Doe #1 of the existence of the nonprosecution agreement prior to Epstein's June 30, 2008 guilty plea, no employee
+of the USAO had personally notified Jane Doe #1 at that time of the existence of
+the non-prosecution agreement. Except as otherwise admitted above, the
+government denies Request No. 13(a).
+(b) The government denies that, by the time of Epstein's June 30, 2008 guilty plea, an
+attorney for the government working at the USAO had not already conferred with
+Jane Doe #1 and Jane Doe #2 about their opinions regarding how the federal
+investigation
+and potential prosecution of Epstein should proceed. The
+government admits that the USAO had not conferred with Jane Doe #2 about the
+non-prosecution agreement prior to Epstein's June 30, 2008 guilty plea. The
+government further admits that, although the USAO had communicated with Jane
+Doe #l about the non-prosecution agreement through FBI agents prior to
+Epstein's June 30, 2008 guilty plea, no employee of the USAO had personally
+conferred with Jane Doe #l about the non-prosecution agreement prior to
+7
+
+
+Epstein's guilty plea. Except as otherwise admitted above, the government denies
+Request No. 13(b).
+(c) Although the government was aware that Jane Doe #2 had been represented by
+counsel paid for by Epstein, the government is unaware of the extent of Epstein's
+defense attorneys' awareness of the USAO's communications with Jane Doe #1
+and Jane Doe #2 about the agreement, as described in the responses to Requests
+No. 13(a) and 13(b), and therefore can neither deny nor admit Request No. 13(c).
+Except as otherwise admitted above and in the responses to Requests No. 13(a)
+and 13(b), the government denies Request No. 13(c).
+(d) The government admits that Epstein's attorneys negotiated with the USAO for a
+provision in the non-prosecution agreement that ultimately provided as follows:
+"The parties anticipate that this agreement will not be made part of any public
+record. If the United States receives a Freedom of Information Act request or any
+compulsory process commanding the disclosure of the agreement, it will provide
+notice to Epstein before making that disclosure." Except as otherwise admitted
+above, the government denies Request No. 13(d).
+14. The government admits that, when Epstein was pleading guilty to the state charges
+discussed in the non-prosecution agreement, the USAO and Epstein's defense
+attorneys sought to keep the document memorializing the non-prosecution agreement
+confidential, but denies that they sought at that time to keep the existence of the nonprosecution agreement confidential. Except as otherwise admitted above, the
+government denies Request No. 14.
+8
+
+
+:
+15. (a) The government admits that, while Bruce E. Reinhart was an Assistant U.S.
+Attorney, he learned confidential, non-public information about the Epstein
+matter.
+(b) The government admits that, while Bruce E. Reinhart was an Assistant U.S.
+Attorney, he discussed the Epstein matter with another Assistant U.S. Attorney
+working on the Epstein matter,
+(c) Denied.
+16. Admitted.
+17. Admitted.
+18. (a) Denied.
+(b) Denied
+19. To the extent that Request No. 19 is directed to the business or personal relationships
+of the 93 U.S. Attorneys and over 5,400 Assistant U.S. Attorneys serving across this
+country, or the countless individuals who have formerly served as U.S. Attorneys and
+Assistant U.S. Attorneys throughout this nation, the government objects to Request
+No. 19 as overly broad and burdensome and not calculated to lead to or involve
+information relevant to the instant matter. The government denies possessing or
+having any knowledge or information about a personal or business relationship
+between Jeffrey Epstein and either the U.S. Attorney or any Assistant U.S. Attorney
+serving in the Southern District of Florida. Except as otherwise admitted above, the
+government denies Request No. 19.
+20. Admitted.
+21. Denied.
+
+
+22. (a) Admitted.
+(b) Admitted.
+(c) Admitted.
+23. The government admits that the non-prosecution agreement signed by the USAO and
+Jeffrey Epstein currently blocks the USAO from prosecuting sex offenses committed
+by Epstein against Jane Doe #1 and Jane Doe #2 in the Southern District of Florida
+from in or around 2001 through in or around September 2007, provided that those
+offenses are set out on pages 1 and 2 of the non-prosecution agreement, were the
+subject of the joint investigation by the FBI and the USAO, or arose from the federal
+grand jury investigation. Except as otherwise admitted above, the government denies
+Request No. 23.
+24. Admitted; Jeffrey Epstein provided valuable consideration to the federal government
+through the non-prosecution agreement he entered with the USAO.
+25. Denied.
+26. The government objects to Request No. 26 because it seeks information protected
+from disclosure by the law enforcement investigative privilege.
+111
+111
+10
+
+
+Respectfully submitted,
+WIFREDO A. FERRER
+UNITED STATES ATTORNEY
+By:
+/s Dexter A. Lee
+Dexter A. Lee
+Assistant United States Attorney
+Florida Bar No. 0936693
+99 N.E. 4th Street
+Miami, Florida 33132
+Tel: (305) 961-9320; Fax: (305) 530-7139
+Email: dexter:lee@usdoj.gov
+A. Marie Villafaña
+Assistant United States Attorney
+Florida Bar No. 0018255
+500 S. Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+Tel: (561) 820-8711; Fax: (561) 820-8777
+Email: ann.marie.c.villafana@usdoj.gov
+Eduardo I. Sánchez
+Assistant United States Attorney
+Florida Bar No. 877875
+99 N.E. 4th Street
+Miami, Florida 33132
+Tel: (305) 961-9057; Fax: (305) 536-4676
+Email: eduardo.i.sanchez/@usdoj.gov
+Attorneys for United States
+CERTIFICATE OF SERVICE
+I hereby certify that a true and correct copy of the foregoing United States' Response to
+Petitioners' First Request for Admissions to the Government was served via CM/ECF on this
+19th day of July, 2013, on the parties and counsel appearing on the attached service list.
+Is Dexter A. Lee
+Assistant United States Attorney
+
+
+SERVICE LIST
+Jane Does 1 and 2 l. United States,
+Case No. 08-80736-CIV-MARRA/MATTHEWMAN
+United States District Court, Southern District of Florida
+Brad Edwards, Esq.,
+Farmer, Jaffe, Weissing,
+Edwards, Fistos & Lehrman, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+(954) 524-2820
+Fax: (954) 524-2822
+E-mail: brad@pathtojustice.com
+Paul G. Cassell
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, Utah 84112
+(801) 585-5202
+Fax: (801) 585-6833
+E-mail: casselp@law.utah.edu
+Attorneys for Jane Doe # 1 and Jane Doe #2
+Roy Black, Esq.
+Jackie Perczek, Esq.
+Black, Srebnick, Kornspan & Stumpf, P.A.
+201 South Biscayne Boulevard, Suite 1300
+Miami, FL 33131
+(305) 371-6421
+Fax: (305) 358-2006
+E-mail: pleading@royblack.com
+Martin G. Weinberg
+MARTIN G. WEINBERG, P.C.
+20 Park Plaza
+Suite 1000
+Boston, MA 02116
+Office: (617) 227-3700
+Fax: (617) 338-9538
+Email: owlmgw@att.net
+Jay P. Lefkowitz
+Kirkland &Ellis, LLP
+601 Lexington Avenue
+New York, NY 10022
+Fax:
+Email: lefkowitz@kirkland.com
+12
+
+
+
+From: (561) 820-8711
+USAO - MCrossen
+Department of Justice
+500 S. Australian Avenue
+Suite 400
+West Palm Beach, FL 33401
+Origin ID: PBIA
+SHIP TO: (954) 524-2820
+Brad Edwards, Esq.
+Farmer Jaffe Weissing Edwards
+425 N. Andrews Avenue
+Suite 2
+FORT LAUDERDALE, FL 33301
+FedEx.
+E
+J1512150023031M
+BILL SENDER
+Ship Date: 23JUN15
+/ActiNgt: 05LB
+CAD: 8097846/NET3610
+Dolvery Address Bar Code
+Rof #t
+Invoice #
+PO#
+Dept #
+(20 7738 9191 3028
+32 HWOA
+WED - 24 JUN AA
+STANDARD OVERNIGHT
+33301
+FL.US
+FLL
+537 JIBADE/EE4B
+https://www.fedex.com/shipping/shipAction.handle?method=doContinue
+6/23/2015
+
+
+
+From: (561) 820-8711
+USAO - MCrossen
+Department of Justice
+500 S. Australian Avenue
+Suite 400
+West Palm Beach, FL 33401
+Origin ID: PBIA
+SHIP TO: (801) 585-5202
+Paul G. Cassell
+University of Utah
+SJ Quinney College of Law
+332 S. 1400 E.
+SALT LAKE CITY, UT 84112
+FedEx.
+E
+J1512150023031N
+BILL SENDER
+I SAiD 052015
+CAD: 8097846/NET3610
+Dolvery Adross Bar Code
+Ref #
+Invoice #
+TRKA
+7738 9192 3670
+0201
+XH NPHA
+WED - 24 JUN AA
+STANDARD OVERNIGHT
+84112
+UT-US
+SLC
+537J1/BA0E/E4B
+https://www.fedex.com/shipping/shipAction.handle?method=doContinue
+6/23/2015
+
+
+Brad Edwards, Esq.,
+Farmer Jaffe Weissing Edwards Fistos Lehrman
+425 N Andrews Ave Ste 2
+Fort Lauderdale, FL 33301-3268
+brad@pathtojustice.com
+954-524-2820
+Fax: 954-524-2822
+Paul G. Cassell
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 B.
+Salt Lake City, Utah 84112
+(801) 585-5202
+Fax: (801) 585-6833
+E-mail: casselp@law.utah.edu
+This is correct.
+Hi Maggie -
+Can you sind
+these two
+Fed Exes?
+I don't need any
+copies.
+Thank you!
+
+
+P-000001
+thru
+P-000039
+Box #I
+P-000040
+thru
+P-000549
+PRIVILEGE LOG
+File folder entitled "CORR RE G
+SUBPOENAS" containing correspondence
+related to various grand jury subpoenas and
+attorney (Villafaña) handwritten notes
+Operation Leap Year Grand Jury Log
+ontaining subpoenas OLY-01 through OLY-81
+P-000550
+thru
+P-000621
+File folder entitled "Ritz Compact Flash SW"
+containing copies of a sealed search warrant
+application, warrant, and supporting documents
+P-000622
+thru
+P-000693
+File folder entitled PNY Technologies Compact
+lash SW" containing copies of a sealed searc
+arrant application, warrant, and supportir
+documents
+P-000694
+thru
+P-000781
+P-000782
+thru
+P-000803
+P-000804
+thru
+P-000854
+File folder entitled "JE Corporations" containing
+attorney research on Epstein-owned corporations
+and prior litigation
+conting serpen a copies ondence
+File folder entitled "DTG Operations/Dollar
+Rent-a-Car" containing subpoena and responsive
+
+Contains documents subject
+this litigation
+Contains information subject
+to investigative privilege
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+this litigation
+Contains information subject
+to investigative privilege
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+this litigation
+Contains information subject
+to investigative privilege
+
+
+Box #I
+P-000855
+thru
+P-000937
+P-000938
+thru
+P-000947
+P-000948
+thru
+P-000982
+File folder entitled "JP Morgan Chase"
+containing subpoena, correspondence, and
+responsive documents
+File folder entitled "Washington Mutual"
+containing subpoena, correspondence, and
+responsive documents
+File folder entitled "Computer Search &"
+containing legal research on computer search and
+handwritten notes on indictment preparation
+P-000983
+thru
+P-001007
+File folder entitled "Attorney Notes from
+Document Review" containing typed and
+handwritten attorney (Villafaña) notes, target
+letters, correspondence re grand jury subpoena
+Box #I
+P-001008
+thru
+P-001056
+File folder entitled "Notes from Fed Ex Records"
+ontaining handwritten and typed attorne
+Villafaña) notes and screen shots of FedE
+subpoena response electronic file
+P-001057
+thru
+P-001959
+P-001960
+P-002089
+File folder entitled "Colonial Bank Records"
+containing records received in response to grand
+jury subpoena
+File folder entitled "OLY Grand Jury Log Vol 2:
+correspondence
+
+Contains documents and
+information subject to
+investigative privilege
+Contains documents and
+information subject to
+investigative privilege
+Attorney-Client
+Contains information subject
+to investigative privilege.
+Also contains information
+ubject to privacy rights o
+ictims who are not parties t
+this litigation
+Contains information subject
+to investigative privilege.
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+this litigation
+Contains information subject
+to investigative privilege.
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+this litigation
+'ontains information subje
+o investigative privileg
+Contains information subject
+this litigation
+
+
+P-002090
+P-002169
+Box #l
+P-002170
+P-002246
+P-002247
+P-002265
+P-002266
+P-002386
+File folder entitled "Epstein Corporate Records:
+OLY-51, OLY-52, OLY-53, OLY-54" containing
+subpoenas, records received in response to
+subpoenas, and related correspondence
+File folder entitled "Colonial Bank" containing
+subpoenas, correspondence related to subpoenas,
+records received in response to subpoenas
+File folder entitled "JEGE & Hyperion from
+Goldberger OLY-46 & OLY-47" containing
+documents received in response to subpoenas
+Indictment preparation binder containing:
+Grand jury subpoena log, evidence/activity
+summary chart, witness/victim names and contact
+list, attorney (Villafaña) handwritten notes, 302s,
+portions of state investigative file, attorney
+(Villafaña) typed notes, of individuals listed as
+Box #I
+P-002387
+P-002769
+Indictment preparation binder containing:
+Grand jury subpoena log, evidence/activity
+summary chart, witness/victim names and contact
+list, attorney (Villafaña) handwritten notes, 302s,
+portions of state investigative file, attorney
+(Villafaña) typed notes, relevant pieces of grand
+jury materials, telephone records/flight records
+analysis charts, victim/witness photographs
+DAVID records, NCICs, and related materials for
+P-002770
+P-003211
+
+Contains information and
+documents subject to
+investigative privilege
+Contains information and
+documents subject to
+investigative privilege
+Contains information and
+documents subject to
+ivestigative privileg
+ork produ
+Contains information and
+documents subject to
+investigative privilege. Also
+contains information and
+documents subject to privacy
+rights of victims who are no
+Contains information and
+documents subject to
+investigative privilege. Also
+
+
+P-003212
+P-003545
+Indictment preparation binder containing metaanalysis charts of telephone/flight/grand jury
+information for a number of victim/witnesses
+and
+P-003546
+P-003552
+FBI Reports of March 2008 interviews of
+additional witness/victim located in New York
+Box #I
+P-003553
+P-003555B
+P-003556
+P-003562
+Box #I
+P-003563
+P-003629
+P-003630
+P-003633
+P-003634
+P-003646
+Printout of filenames from Federal Express
+subpoena response with Attorney notations
+Document entitled "Identified Numbers" with
+accompanying handwritten attorney list compiled
+from grand jury materials and attorney analysis of
+records
+Folder entitled "Flight Manifests" containing
+manifests received pursuant to grand jury
+subpoena
+File folder entitled "Recent Attorney Notes"
+containing handwritten attorney (Villafaña) notes
+regarding document review and case strategy
+File folder bearing victim name containing FBI
+
+Contains information and
+documents subject to
+investigative privilege. Also
+Contains information subject
+to investigative privilege
+Contains information and
+documents subject to
+investigative privilege
+Debrate process
+Attorney-client privilege
+
+
+P-003647
+P-003651
+File folder entitled "Summary of Sexual Activity"
+P-003652
+P-003663
+P-003664
+P-003678
+P-003679
+P-003680
+P-003681
+P-003687
+P-003688
+P-003693
+P-003694
+P-003711
+File folder entitled "Victim Civil Suits"
+File folder entitled "Research re JE Websites"
+containing attorney research
+File folder entitled "Serene Cano (N.Y. AUSA)"
+containing attorney (Villafaña) handwritten notes
+ile folder entitled "Dr. Anna Salter" containing
+attorney (Villafaña) memo to expert witness anc
+handwritten attorney notes
+File folder entitled "Il] GI Interview" containing
+attorney handwritten notes of interview, and
+attorney handwritten notes regarding potential
+Also contains informatior
+subject to privacy rights of
+victims who are not parties to
+this litigation
+P-003712
+
+
+
+P-003713
+P-003746
+P-003747
+P-003751
+P-003752
+P-004295
+P-004296
+P-004350
+File folder entitled "T[] M[]" containing grand
+jury subpoenas, motion and order to compel
+testimony, and correspondence regarding same
+File folder entitled
+containing
+subpoena and correspondence regarding same
+File folder entitled "PBPD Investigative File"
+obtained via subpoena
+File folder bearing name of victim/witness
+ontaining meta-analysis chart showing telephon
+alls, travel, and grand jury materials relevant to
+possible charges
+Box #I
+P-004351
+P-004381
+P-004382
+P-004478
+P-004479
+P-004551
+P-004552
+P-004555
+File folder entitled !
+Documents
+53909-004" containing attorney research related
+to bias issue
+File Folder entitled "FEDEX" containing
+documents obtained via subpoena
+File Folder entitled "State of Delaware Records"
+containing documents obtained in preparation for
+indictment
+File folder entitled "Jet Blue Records" containing
+documents obtained via subpoena
+P-004556
+P-004560
+File folder entitled "FL EMPLOYMENT
+RECORDS" containing FDLE records on targets
+and witnesses obtained at attorney reguest
+
+Documents under seal
+pursuant to court order
+Investigative privileg
+Also contains information an
+docus on i cumise to are acy
+Invest epivilege
+
+
+P-004561
+P-004565
+P-004566
+P-004716
+Filed folder entitled "JANUSZ BANASIAK"
+containing attorney (Villafaña) handwritten notes
+of interview
+File folder entitled "JANUSZ BANASIAK
+RECORDS 23-0001 THROUGH 23-" containing
+documents obtained via subpoena
+P-004717
+P-004722
+P-004723
+P-004725
+P-004726
+P-004819
+P-004820
+P-004959
+P-004960
+P-005059
+File folder entitled "IGOR ZINOVIEV"
+containing attorney research regarding witness
+File folder entitled "BEAR STEARNS
+RESEARCH" containing attorney research
+regarding potential witness and subpoena
+recipient
+File folder entitled "LAWSUITS INVOLVING
+EPSTEIN CORP'S containing attorney research
+regarding Epstein's past personal and business
+litigative practices
+Filed folder entitled "SEC RECORDS"
+containing attorney research regarding Epstein
+financial relationships
+File folder entitled "Message Pads" containing
+selected items from evidence obtained via
+subpoena
+Also contains information and
+His rigine to areact
+Investigative privileg
+P-005060
+P-005081
+P-005082
+P-005083
+File folder bearing name of victim/witness
+containing correspondence with counsel for
+victim/witness, attorney witness outline with
+attorney handwritten notes, attorney handwritter
+notes regarding witness reports and case
+preparation
+File folder entitled "New York Trip" containing
+attorney notes re witness interview
+
+
+
+P-005108
+P-005193
+P-005194
+P-005300
+P-005084 thru P-005107 are non responsive
+ile folder entitled "ANNA SALTER" containing
+attorney research on select expert, use of expert:
+at trials in child exploitation cases, and additional
+research materials on offenders and victims
+neta-analysis chart and 302's of victim/witnesse
+ised in preparing indictment packag
+Box #I
+P-005301
+P-005331
+P-005332
+P-005341
+P-005342
+P-005387
+Box #I
+P-005388
+P-005442
+File folder entitled "JUAN ALESSI
+STATEMENT" containing transcript obtained via
+subpoena
+File folder entitled "KEN LANNING" containing
+attorney research on select expert, including
+attorney handwritten notes
+File folder entitled "Info re Planes" containing
+correspondence regarding subpoenas and
+documents received in response to subpoenas
+File folder entitled "Police Reports & PC
+and attorney handwritten notes, photographs and
+DAVID information, and additional attorney
+Box #I
+P-005443
+P-005496
+P-005497
+P-005556
+File folder entitled "Bear Stearns Subpoena
+Resp." containing material received in response
+
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+
+
+P-005557
+P-005576
+Box#1
+P-005578
+P-005583
+P-005584
+P-005606
+U.S. Attorney's Office Criminal Case File Jacket
+containing file opening documents, expert
+witness payment documents
+U.S. Attorney's Office Asset Forfeiture Case File
+Jacket containing file opening and file closing
+File folder entitled "6001 Immunity Request"
+ntaining internal memoranda seeking witne
+amunity and correspondence with counsel fi
+P-005607
+P-005914
+File folder entitled "MASTER PHONE
+RECORDS" containing meta-analysis of all
+phone, travel, and grand jury data for all
+victim/witnesses for indictment preparation
+P-005915
+P-005977
+File folder bearing name of victim/witness
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+indictment preparation
+P-005978
+P-006050
+File folder bearing name of victim/witness
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+P-006051
+P-006065
+File folder bearing name of victim/witness
+ontaining meta-analysis of all phone, travel, ar
+and jury data related to that victim/witness f
+indictment preparation
+
+Work product and
+deliberative process (as to
+internal memoranda)
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+
+
+P-006066
+P-006220
+File folder entitled "JANE DOE #4" containing
+meta-analysis of all phone, travel, and grand jury
+data related to that victim/witness for indictment
+preparation
+P-006221
+P-006222
+File folder entitled «*JANE DOE #12" containing
+leta-analysis of all phone, travel, and grand jur
+ata related to that victim/witness for indictmer
+preparation
+P-006223
+P-006522
+File folder entitled "CORRECTED PHONE
+RECORDS 5/31/07" containing meta-analysis of
+all phone, travel, and grand jury data related to all
+victims/witnesses for indictment preparation
+P-006523
+P-006802
+File folder entitled "[Victim Name] Phone
+Records" containing telephone records received
+in response to subpoena
+P-006803
+P-006860
+File folder entitled "Lists of Identified Phone
+Numbers" containing charts of information culled
+from grand jury materials, interviews, and other
+investigation, with attorney handwritten notes,
+and information to issue follow-up grand jury
+subpoena
+File folder entitled "EPSTEIN
+CELL
+P-006861
+P-007785
+
+Also contains information anc
+ris of victims to are not
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+Also contains information and
+
+
+P-007786
+P-008120
+Folder entitled "OLY GRAND JURY LOG:
+OLY-01 THROUGH OLY-50" containing
+P-008121
+P-008139
+P-008140
+P-008298
+P-008299
+P-008363
+Handwritten flight logs received in response to
+subpoena
+Grand jury presentation folder containing
+attorney handwritten notes, typed outline with
+additional handwritten notes, complete indictment
+package dated 2/19/2008, victim list with
+identifying information, photographs, and
+summary of activity
+File folder entitled "FINAL AGREEMENTS"
+containing subtolder entitled
+sate Court (F-000-P-0 327 not being
+withheld as privileged - have been produced to
+opposing counsel]); signed Non-Prosecution
+Agreement, Addendum, and operative portion of
+12/19/2007 Sanchez-Acosta letter (P-008328-P-
+008343 [not being withheld as privileged - have
+been produced to opposing counsel]); subfolder
+entitled "12/19/07 Acosta-Sanchez Ltr"
+containing unredacted copies of that letter (P-
+P-008364
+P-008382
+P-008383
+P-008516
+Circuit)
+File folder entitled 1
+Immunity Request"
+containing internal memoranda, Justic
+Department documentation, and subpoen
+
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+Also contains information an
+rights of veins to are not
+Also contains information and
+locuments subject to privac
+ights of victims who are no
+
+
+P-008517
+P-008535
+P-008536
+P-008542
+P-008543
+P-008549
+P-008550
+P-008615
+6/25/2007 Letter from Gerald Lefcourt to Jeffrey
+[pursuant to Court's Order, not being withheld as
+privileged - will be produced to opposing counsel
+upon lift of stay by Il" Circuit]
+Handwritten attorney notes to prepare for
+Handwritten attorney notes regarding May 8,
+2007 grand jury presentation
+File folder entitled "Most Recent Indictment &
+Good Cases" egin resedat indictment and
+P-008616
+P-008686
+File folder entitled "FBI Summary Charts"
+containing chart prepared at direction of AUSA,
+containing victim names, identifying information,
+summary of activity, and other information
+P-008687
+P-008776
+File folder entitled "[Victim name]/Jane Doe #4"
+P-008777
+P-008808
+File folder entitled "[Victim name//Jane Doe #5"
+
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+
+
+P-008809
+P-008847
+P-008848
+P-008862
+P-008863
+P-008890
+P-008891
+P-009103
+P-009104
+P-009111
+P-009112
+P-009113
+P-009114
+P-009115
+P-009116
+P-009125
+File folder entitled "[Victim name]/Jane Doe #6"
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+indictment preparation
+File folder entitled "[Victim name]/Jane Doe #7"
+ontaining meta-analysis of all phone, travel, an
+rand jury data related to that victim/witness fo
+indictment preparation
+File folder entitled "[Victim namel/Jane Doe #8"
+phone, travel, an
+grand iny met renated is ofall icine traves, an
+indictment preparation
+File folder entitled "Certified Copy of State Case"
+ontaining certified copy of Epstein state crimina
+ases and change of plea transcript not bein
+withheld as privileged - copy provided to
+opposing counsel]
+File folder entitled "Meeting Timeline"
+containing Villafaña typed notes summarizing
+meetings with opposing counsel prepared at
+request of R. Alexander Acosta, with handwritten
+correction and typed guideline estimate
+11/26/2008 Email from Roy Black to A. Marie
+Villafaña and Karen Atkinson re Jeffrey Epstein
+(work release)
+[pursuant to Court's Order, not being withheld as
+privileged - will be produced to opposing counsel
+
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+who are not parties to this suit
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+
+
+P-009126
+P-009134
+P-009135
+P-009141
+P-009141A
+P-009141C
+P-009142
+P-009152
+P-009153
+P-009156
+P-009157
+P-009208
+P-009209
+P-009213
+File folder entitled "[Victim name]/Jane Doe #9"
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+indictment preparation
+File folder entitled "[Victim name]/Jane Doe
+13" containing meta-analysis of all phone
+travel, and grand jury data related to tha
+victim/witness for indictment preparation
+ile folder entitled "[Victim name]/Jane Do
+12" containing meta-analysis of all phone
+travel, and grand jury data related to that
+victim/witness for indictment preparation
+File folder entitled "L
+containing meta-analysis of all phone, travel, and
+grand jury data related to that individual for
+indictment preparation
+File folder entitled
+containing meta-analysis of all phone, travel, and
+grand jury data related to that individual for
+indictment preparation
+File folder entitled "[Victim name]/Jane Doe #I"
+ontaining meta-analysis of all phone, travel, al
+rand jury data related to that victim/witness f
+File folder entitled "[Victim name]/Jane Doe #2"
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Vork produc
+contains in formation subjec
+ho are not parties to this su
+
+
+P-009214
+P-009271
+P-009272
+P-009354
+P-009355
+P-009403
+P-009404
+P-009536
+P-009537
+P-009574
+P-009575
+P-009603
+P-009604
+P-009711
+P-009712
+P-009819
+P-009820
+P-009965
+P-009966
+P-010096
+File folder entitled "[Victim namel/Jane Doe #3"
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+indictment preparation
+File folder entitled "Purpose of Travel Cases"
+containing attorney research and handwriten
+File folder entitled "Interstate Commerce Cases"
+containing attorney research and handwritten
+notes
+File folder entitled "Attorney Conflict Research"
+containing attorney research and handwritten
+notes
+File folder entitled "Mann Act/Travel to Have
+Sex w/Minor" containing attorney research and
+handwritten notes
+File folder entitled "Travel Act" containing
+attorney research and handwritten notes
+File folder entitled "Florida
+Prostitution/Lewdness Statutes" containing
+attorney research and handwritten notes
+Booklet entitled "Attorney General Guidelines for
+Victim and Witness Assistance" [not being
+withheld as privileged - produced to opposing
+counsel]
+File folder entitled "Corporate Liability Rsrch"
+containing attorney research and handwritten
+File folder entitled "Research re Knowledge of
+Age Unnecessary" containing attorney research
+and handwritten notes and copy of grand jury
+subpoena
+Contains information subject
+to privacy rights of victims
+who are nork pries to this suit
+
+
+
+P-010097
+P-010276
+P-010277
+P-010394
+P-010395
+P-010488
+P-010489
+P-010509
+P-010510
+P-010525
+P-010526
+P-010641
+File folder entitled "Money Laundering"
+containing attorney research and handwritten
+notes
+File folder entitled "1960 & Aiding/Abetting"
+containing attorney research and handwritten
+notes
+File folder entitled "18 USC § 2255 Cases"
+containing attorney research and handwritten
+notes
+Winess Testimony Rich toney resear
+and handwritten notes
+File folder entitled "Extradition" containing
+attorney research and handwritten notes
+File folder entitled "Rsrch re Crime Victims
+Rights" containing attorney research, handwritten
+notes, draft victim notification letter, and draft
+correspondence to Jay Lefkowitz
+(Also contains a November 28, 2007 letter from
+Kenneth Starr to Alice S. Fisher; and a November
+29, 2007 letter from Jay Lefkowitz to R.
+Alexander Acosta (P-010528 thru P-010530 and
+P-010556 thru P-010559). Pursuant to the
+P-010642
+P-01650
+P-010651
+P-010659
+P-010660
+P-010757
+witnesses
+Homey research and corespondence related to
+
+
+
+P-010758
+P-010793
+P-010794
+P-010829
+P-010830
+P-010853
+P-010854
+P-010876
+P-010877
+P-010920
+P-010921
+P-011049
+P-011050
+P-011212
+P-011213
+P-011237
+P-011238
+P-011319
+P-011320
+P-011361
+P-011362
+P-011374
+File folder entitled "Original Proposed Ind."
+containing draft indictment
+File folder entitled "Epstein" containing sample
+indictments and attorney research re potential
+charges with attorney notes
+File folder entitled "1591 & Money Laundering"
+containing attorney research and handwritten
+notes
+File folder entitled "18 USC 2425" containing
+attorney research and handwritten notes
+File folder entitled "Knowledge of Age"
+containing attorney research and handwritten
+notes
+File folder entitled 2423(b) Constitutionality and
+Purpose of Travel" containing attorney research
+and handwritten notes
+File folder entitled "Mistake not a
+Defense" containing attorney research and
+handwritten notes
+File folder entitled "Research re 'Pandering'"
+containing attorney research and handwritten
+notes
+File folder entitled "Research re Grand Jury
+Instructions" containing attorney research and
+handwritten notes
+File folder entitled "Telephone = Facility of
+Commerce" containing attorney research and
+handwritten notes
+File folder entitled "Def of Prostitution"
+containing attorney research and handwritten
+notes
+
+
+
+P-011375
+P-011456
+P-011457
+P-011626
+P-011627
+P-011662
+P-011663
+P-011698 and
+P-012189 thru
+P-012361
+(gap was
+scanning error)
+P-011699
+P-011777
+P-011778
+P-011788
+P-011789
+P-011879
+P-011880
+P-011922
+conting atomy research and landites"
+File folder entitled "Unit of Prosecution
+Research" containing attorney research and
+handwritten notes
+File folder entitled "Attorney Notes" containing
+attorney handwritten and typed notes
+File folder entitled "Drafts" containing draft
+indictments with attorney handwritten notes, draft
+internal memoranda, relevant witness interview
+eports and grand jury material and attorney
+handwritten note
+File folder entitled "6/9/09 Signed Indictment"
+containing signed indictment package dated
+6/9/2009 with corrections
+File folder entitled "6/12/09 Victim Notif. Log"
+containing chart with victim contact informatior
+and attorney notes regarding dates and type of
+File folder entitled "Breach Memo" containing
+memorandum analyzing breach of Non-
+Prosecution Agreement with attachments
+ile folder entitled "Overt Act Lists" containir
+andwritten notes cross-checking all overt ac
+alleged in draft indictment by victim and typec
+overt act summary charts for indictment
+preparation
+
+Contains information subject
+to privacy rights of victims
+who are not parties to this
+Attorney-client privilege
+
+
+P-011923
+P-011966
+Folder entitled "Responses to Arguments from JE
+Counsel" containing:
+to Andrew Lourie
+7A202 we Lorie Wily handwichen
+attorney (Lourie) notes;
+• 6/25/2007 letter from Gerald Lefcourt to
+P-011967
+P-012016
+P-012017
+P-012055
+P-012056
+P-012088
+P-012089
+P-012129
+P-012130
+P-012150
+P-012151
+P-012167
+Affidavit of Roy Black, Esq. in Support of
+Motion of Jeffrey Epstein to Intervene and to
+United States' Response to Motion of Jeffrey
+Epstein to Intervene and to Quash Grand Jury
+Subpoenas and Cross-Motion to Compel
+Declaration of Joseph Recarey
+* Parte Declaration Number One in Support o
+nited States' Response to Motion to Quas
+Subpoenas
+
+Contains information subject
+to privacy rights of victims
+who are not parties to this
+litigation
+
+
+P-012168
+P-012170
+P-012171
+P-012173
+P-012174
+P-012176
+P-012177
+P-012178
+P-012179
+P-012188
+Ex Parte Declaration Number Two in Support of
+United States' Response to Motion to Quash
+Subpoenas
+Supplement to Ex Parte Declaration Number One
+in Support of United States' Response to Motion
+to Quash Subpoenas
+Draft of September 2009 letter from Marie
+Villafaña to Roy Black regarding breach of Non
+Prosecution Agreement with handwritten attorney
+(Villafaña) notes
+Undated handwritten attorney (Villafaña) notes
+regarding negotiations and allegations
+File Folder entitled "FBI G.J. Log" containing
+copy of FBI grand jury subpoena log with
+attorney (Villafaña) handwritten notes
+P-012362
+P-012451
+P-012451
+P-012452
+File folder entitled "Key Documents" containing
+correspondence between AUSA and case agent
+regarding indictment prep questions, victim
+identification information, corrections to draft
+indictment, indictment preparation timeline, key
+grand jury material
+File folder entitled "Victim List" containing list
+of victims with dates of birth and age information
+
+Also contains information
+rubject to privacy rights of
+ictims who are not parties t
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+this litigation
+Attorney-Client privilege
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+
+
+P-012453
+P-012623
+Complete indictment package marked "Originals
+12/12/07"
+P-012624
+P-012653
+P-012654
+P-012864
+P-012865
+P-013226
+Folder entitled "(Victims) Additional 302's"
+containing reports of interviews conducted in
+June 2007, October 2007, and March 2008.
+3-ring binder entitled "Child Molesters: A
+Behavioral Analysis" with attorney (Villafaña)
+handwritten notes
+vitness/victim list with identifying information
+exual activity summary, telephone call summar
+P-013227
+P-013226
+P-013230
+P-013231
+P-013239
+14
+April 23, 2008 Memo from Jeffrey Sloman to
+April 21, 2008 Letter from Jeffrey Sloman to
+Office of Professional Responsibility re Self
+Reporting
+\pril 22, 2008 Letter from A. Marie Villafaña to
+Deport of Allegeson of Contionsibie se Self
+
+Work-product
+Also contains documents
+subject to investigative
+privilege
+Also contains documents
+subinet to privacy patis to
+this litigation
+Also contains documents
+Also contains documents
+subject to investigative
+
+
+P-013240
+P-013247
+P-013248
+P-013251
+April 21, 2008 Letter from Jeffrey Sloman to
+Office of Professional Responsibility re Self
+Reporting with attachments
+Emails between Richard Sudder, Assistant
+General Counsel, Executive Office for United
+P-013252
+P-013253
+P-013254
+P-013257
+P-013258
+P-013259
+Emails between Richard Sudder, Assistant
+General Counsel, Executive Office for United
+Assistant Uns and Be Sin reber Fist
+Issistant U.S. Attorney,
+August 3, and August 24, 2011
+between
+Jeneral Counsel, Executive Office for United
+States Attorneys, and Benjamin Greenberg, First
+Assistant U.S. Attorney, Southern District of
+lorida, regarding Formal Notice of Office-wide
+lecusal of Southern District of Florida date
+Emails
+between
+Richard Sudder, Assistant
+General Counsel, Executive Office for United
+States Attorneys, and Benjamin Greenberg, First
+Assistant U.S. Attorney, Southern District of
+Florida, regarding Formal Notice of Office-wide
+Recusal of Southern District of Florida dated July
+P-013260
+P-013262
+
+
+
+P-013263
+P-013271
+Emails between
+'lorida, dated July 29
+memorandad from 2. Marie Vil attached
+Benjamin Crenberg
+P-013272
+P-013278
+and 17, 2010, with attached letter from Paul
+Cassell to Wifredo A. Ferrer, dated December 10.
+
+
+
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 S. Australian Ave, Ste 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 19, 2013
+DELIVERY BY FEDERAL EXPRESS
+Brad Edwards, Esq.,
+Farmer Jaffe Weissing Edwards Fistos Lehrman
+425 N Andrews Ave Ste 2
+Fort Lauderdale, FL 33301-3268
+Re:
+Jane Doe #1 and Jane Doe #2 v. United States
+Dear Brad:
+Enclosed please find:
+(1)
+(2)
+(3)
+(4)
+(5)
+(6)
+(7)
+(8)
+One DVD containing documents Bates Stamped 000001 thru 000979;
+Documents bearing Bates Nos. P-003652 thru P-003663;
+Documents bearing Bates Nos. P-008300 thru P-008343;
+Documents bearing Bates Nos. P-008891 thru P-009103;
+Documents bearing Bates Nos. P-009114 thru P-009115;
+Documents bearing Bates Nos. P-009712 thru P-009819;
+A copy of the Privilege Log that was filed with the Court; and
+A copy of the Responses to your Requests for Admissions that were filed with the
+Court.
+Please let me know if you have any difficulties with any of the copies.
+Sincerely,
+Wifredo A. Ferrer
+By:
+Assistant United States Attorney
+cc:
+Dexter Lee, Esq.
+
+
+SECOND SUPPLEMENTAL PRIVILEGE LOG
+Box #4
+P-013970
+thru
+2
+3
+4
+5
+6
+7
+8
+9
+5/18/2007 email from Marie Villafaña to
+Matt Menchel informing him of intent to
+subpoena Roy Black's private investigator
+and steps taken to obtain DOJ authorization
+5/21/2007 email from Marie Villafaña to
+Myesha Braden (CEOS) re 2423(b) charging
+question
+5/21/2007 email from Marie Villafaña to
+Matt Menchel and Jeff Sloman regarding
+guidance on grand jury presentation
+6/12/2007-7/6/2007 series of emails between
+Marie Villafaña and AUSAs Serene Nakano
+and James Cott re an earlier unrelated
+investigation of Epstein
+7/3/2007-7/13/2007 email chain between
+Matt Menchel and Marie Villafaña regarding
+disagreement on Menchel's plea negotiations
+and written request for meeting between
+USAO management and victims
+7/16/2007 email from Marie Villafaña to
+Matt Menchel and Andrew Lourie regarding
+correspondence from Roy Black and Motion
+to Quash
+7/18/2007 emails from Marie Villafaña to
+Andrew Lourie and Matt Menchel regarding
+lotion to Quash grand jury subpoena an
+upporting affidavit filed by Roy Black
+/19/2007 email chain between Marie
+Villafaña, Andrew Lourie, Matt Menchel.
+S/A Jason Richards and S/A Eliasib Ortiz
+regarding potential service of target letters
+7/26/2007 email from Marie Villafaña to
+att Menchel and Andrew Lourie regardir
+roposed changes to the indictme
+
+
+
+10
+8/2/2007 email drom Marie Villafaña to Jeff
+Sloman, Matt Menchel, and Andrew Lourie
+with draft response to Epstein counsel
+11
+14
+15
+16
+17
+18
+3/3/2007 Email from Marie Villafaña to Matt
+Menchel. Andrew Lourie, Jeff Sloman, and
+Caren Atkinson regarding draft response to
+correspondence from Epstein counsel and
+cannot be reached.
+Emails dated 8/6/2007 from Marie Villafaña
+to Cyndee Campos/Frederica Devlin and Jeff
+Sloman regarding Matt Menchel's
+correspondence prior to his departure.
+8/7/2007 email chain between Marie
+Villafaña, Cyndee Campos, and Alex Acosta
+regarding meeting to discuss Epstein matter
+8/7/2007 email from Marie Villafaña to
+Andy Lourie regarding deadline set for
+Epstein plea and Epstein's plan to demand a
+meeting with CEOS
+8/7/2007 email from Marie Villafaña to
+Andrew Oosterbaan regarding Epstein
+meeting
+8/7/2007 email chain from Jeff Sloman to
+Alex Costerbaring Fies i made, and
+8/8/2007 emails between Marie Villafaña
+and Andrew Oosterbaan (CEOS) regarding
+case staffing and plea negotiations
+8/8/2007 email chain between Andrew
+Oosterbaan, Alex Acosta, Marie Villafaña,
+'yndee Campos, Jeff Sloman, and Andrew
+‚ourie regarding "The meeting on Epstein'
+8/10/2007 Electronic correspondence from
+Marie Villafaña to expert witness regarding
+topics for expert testimony
+9/21/2007 emails between Marie Villafaña
+and Andrew Lourie, Rolando Garcia, Karen
+Atkinson, and John McMillan regarding
+revisions to the non-prosecution agreement
+
+
+
+22
+23
+24
+25
+26
+27
+28
+29
+9/24/2007 series of emails between Marie
+Villafaña, Alex Acosta, and Andrew Lourie
+regarding plea negotiations and revisions to
+non-prosecution agreement
+9/23/2007-9/24/2007 series of emails
+between Alex Acosta, Marie Villafaña,
+Andrew Lourie, Rolando Garcia, and Jeff
+Sloman regarding proposed revisions to nonprosecution agreement
+4/29/2008 email from Marie Villafaña to
+Robert Senior, Jeff Sloman, Karen Atkins,
+on Rolando Garcia re grand jury presentation
+5/23/2008-5/27/2008 emails between Marie
+Villafaña, Robert Senior, Jeff Sloman, Karen
+Atkinson,
+(FBI), and
+(FBI) re status of
+investigation, indictment review, grand jur
+preparation, and Epstein's attempt to revisi
+plea negotiations
+5/22/2007 email from Andy Lourie to Matt
+Menchel and Jeff Sloman (cc: Marie
+Villafaña) re letter received from Gerald
+Lefcourt discussing a meeting to discuss
+Epstein investigation
+5/23/2007 email from Jason Richards to
+Marie Villafaña re extradition research
+5/23/2007 emails between Karen Atkinson
+and Marie Villafaña regarding decision to
+meet with counsel for Epstein
+Alex Acosta, Jeff Sloman, Karen Atkinson,
+Lefkowitz and Ken Starr to speak with Alex
+Acosta and instructions to direct question to
+3/19/2008-3/21/2008 emails between Marie
+Villafaña, Drew Oosterbaan (CEOS),
+Gelber (CEOS), Jeff Sloman, and
+Especie Sense and e and elep
+questions
+
+Work Production
+AVC privilege
+
+
+31
+32
+34
+4/4/2008-4/7/2008 emails between Marie
+Villafaña, Robert Senior, Andrew
+Oosterbaan, and Jeff Sloman regarding status
+of CEOS review of Epstein matter
+4/11/2008-4/23/2008 emails between Marie
+Villafaña, Jeff Sloman, and Dexter Lee
+5/15/2008-5/16/2008 emails between Jeff
+Sloman, Marie Villafaña, and Robert Senior
+regarding receiving final approval from DC
+5/7/2008-5/9/2008 emails between Marie
+35
+36
+37
+38
+regarding awaiting approval from DC and
+status of ongoing investigation
+5/2/2008 emails between Robert Senior,
+Marie Villafaña, Karen Atkinson,
+regarding
+developments in Epstein investigation and
+impact on grand jury presentation
+4/29/2008-5/2/2008 emails between Marie
+Villatafia and Jeff Sloman regarding contact
+by Epstein counsel and victims and draft
+letter to counsel for Epstein
+11/29/2006-12/1/2006 emails between Marie
+Villafaña and prison employee regarding
+attempted contact with potential witness
+7/19/2007 email from Marie Villafaña to
+Andrew Lourie and Matt Menchel regarding
+planned service of target letters
+39
+40
+7/3/2007-7/4/2007 emails between Marie
+extension of time to respond to subpoenas
+requested by Lilly Ann Sanchez and possible
+resolution of case
+9/19/2007-9/20/2007 emails between Marie
+Villafaña, Andrew Lourie, and Rolando
+¡arcia regarding plea negotiations witl
+ounsel for Epstei
+
+
+
+42
+43
+45
+46
+47
+48
+49
+7/31/2007 email from Marie Villafaña to Jeff
+Sloman, Matt Menchel, and Andrew Lourie
+summarizing proposed plea terms as per
+8/8/2007 email from Marie Villafaña to
+Drew Oosterbaan regarding plea
+negotiations, guideline calculations, and
+assistance in preparing case for trial
+8/8/2007 email from Marie Villafaña to Alex
+Acosta, Cyndee Campos, Jett Sloman,
+Andrew Lourie, and Drew Oosterbaan
+regarding planning meeting with Epstein
+counsel and service of target letters
+6/14/2007-6/21/2007 emails between Marie
+Villafaña, Karen Atkinson, Andrew Lourie,
+Matt Menchel, and Jeff Sloman regarding
+addendum to Pros Memo, grand jury
+presentation and changes to indictment, and
+8/2/2007 emails between Matt Menchel, Jeff
+Sloman, Andy Lourie, and Marie Villafaña
+regarding letter received from Lilly Ann
+Sanchez
+3/19/2008-3/27/2008 emails between Jeff
+Sloman, Bob Senior, Karen Atkinson,
+Rolando Garcia, Nesbitt Kurykendall, and
+Jason Richards regarding waiting for DC's
+lecision regarding Epstein's challenges to
+PA; status of ongoing investigation;
+
+Privileges) Asserted
+avestigative Privileg
+eliberative Proces
+
+
+50
+3/31/2008 emails between Marie Villafaña,
+Jeff Sloman, Robert Senior, and Nesbitt
+51
+from Washington, DC, and problems with
+4/10/2008-4/18/2008 emails between Marie
+Villafaña, Robert Senior, Karen Atkinson,
+52
+53
+ongoing investigation
+4/21/2008-5/1/2008 emails between Marie
+Villafaña, Robert Senior, Jeff Sloman, Karen
+Atkinson,
+and Drew
+presenting case to grand jury due to failure to
+receive decision from DC, status of grand
+Jury presentation and ongoing investigation
+taffing of case for purposes of trial, an
+presentation
+5/19/2008-5/22/2008 emails between Marie
+Villafaña, Karen Atkinson, Robert Senior,
+54
+and status of ongoing investigation
+Alex Acosta, Jeff Sloman, Robert Senior,
+Karen Atkinson, and Dexter Lee containing
+draft response to 8/15/2008 email from Jay
+efkowitz regarding implementation of th
+IPA. (Redacted version produced to
+12/3/2007-12/5/2007 correspondence
+between Alex Acosta, Jeff Sloman, Marie
+
+Work Produc
+investigative Privilege
+
+
+56
+57
+58
+12/18/2007 emails from other AUSAs to
+Marie Villafaña regarding other instances of
+charging 2422(b) based only on the use of a
+telephone
+11/28/2007 correspondence between Marie
+Villafaña, Andrew Lourie, Drew Oosterbaan,
+and Rolando Garcia regarding Lefkowitz
+11/27/2007 email discussing presentation to
+DAAG
+11/19/2007-11/28/2007 emails between
+Marie Villafaña.
+and Jeff Sloman regarding drafting
+victim notification letter of upcoming plea
+59
+60
+62
+64
+12/11/2007 email from Marie Villafaña to
+Jeff Sloman and Alex Acosta regarding call
+with lawyer for Jane Doe #2 (T.M.)
+12/3/2007 emails between Marie Villafaña,
+Alex Acosta, and Jeff Sloman regarding
+history of plea negotiations and drafting
+response to correspondence from Jay
+Lekowitz and Ken Starr
+8/10/2007 email from Marie Villafaña to
+Andrew Lourie regarding target letters and
+staying motion to compel production of
+computers
+8/30/2007 email from Marie Villafaña to Jeff
+Sloman, Andrew Lourie, Drew Oosterbaan,
+John McMillan, and Karen Atkinson
+regarding press coverage of meeting with
+9/4/2007-9/6/2007 emails between Marie
+Villafaña and Jeff Sloman regarding planned.
+participation of FBI ASAIC at 9/7/2007
+9/6/2007 emails between Marie Villafaña,
+Jeff Sloman, Andrew Lourie Drew
+Josterbaan, and Rolando Garcia regarding
+status a plento canier vira vietmements,
+
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+this litigation
+
+
+65
+66
+68
+69
+70
+71
+72
+73
+9/11/2007 emails between Marie Villafaña,
+John McMillan, Drew Oosterbaan,
+regarding
+changes to the draft indictment and status of
+plea negotiations
+9/10/2007-9/11/2007 emails between Marie
+Villafaña, Alex Acosta, and Jeff Sloman
+regarding modifications to the proposed
+Non-Prosecution Agreement
+9/13/2007 emails from Marie Villafaña to
+Andrew Lourie, Alex Acosta, Jeff Sloman,
+Rolando Garcia, and Karen Atkinson
+regarding plea to federal charges
+recommending 18 USC 403 or 1512(d), or
+4/ USC 223(a)(1)(B); response that Epstein
+was only willing to plead to assault on the
+plane; and rejection of facts supporting
+assault on the plane charge
+9/13/2007-9/14/2007 emails regarding Marie
+Villafaña research regarding victim trust
+fund set up in Alaska child exploitation case
+9/17/2007-9/19/2007 emails between Marie
+Villafaña, Rolando Garcia, Andrew Lourie,
+Alex Acosta, Karen Atkinson, and John
+McMillan regarding negotiations of a federal
+plea and a non-prosecution agreement
+9/20/2007 emails between Marie Villafaña
+and Andrew Lourie regarding plea
+agreement to federal charges and factual
+proffer
+9/20/2007-9/24/2007 emails between Alex
+Acosta, Marie Villafafia, and Andrew Lourie
+regarding revisions to the non-prosecution
+9/21/2007 email from Marie Villafaña to
+Alex Acosta, Rolando Garcia, Karen
+Atkinson, and Andrew Lourie regarding
+review of Epstein indictment package
+9/24/2007 emails between Marie Villafaña
+and Rolando Garcia regarding notifying
+alm Beach Police Chief and victims abou
+agreement
+
+
+
+74
+77
+78
+79
+9/24/2007-9/25/2007 emails between Alex
+Acosta, Marie Villafaña, Andrew Lourie, and
+Rolanda Garcia regarding Lefkowitz email
+about keeping agreement from becoming
+ublic and confidentiality provision in
+agreement
+10/5/2007-10/16/2007 emails between Marie
+Villafaña, Jeff Sloman, and Alex Acosta re
+selection of Special Master and negotiation
+of revision/addendum to Non-Prosecution
+Agreement
+11/14/2007-11/19/2007 emails between
+AMCV, Jason Richards, Jeff Sloman,
+Rolando Garcia, Alex Acosta, and Karen
+Atkinson regarding communications with
+State Attorney's Office and Sheriff's Office
+in an attempt to insure that Epstein was
+ineligible for work release
+11/19/2007 emails between AMCV, Jeff
+Sloman, and Rolando Garcia about efforts by
+Epstein's counsel to change date for change
+of plea
+11/8/2007-11/14/2007 emails between
+AMCV, Jett Stoman, Karen Atkinson, and
+Jason Richards regarding response to
+objections raised by Epstein counsel and
+efforts to change date for guilty plea
+10/31/2007 email from
+to AMCV regarding attempts to interview
+additional witnesses/victims
+80
+81
+10/22/2007-10/31/2007 emails between Jeff
+negotiation of Addendum to Non-
+Prosecution Agreement and drafting of
+coMaster saltire and selecon or spicial
+AMCV regarding Special Master's Selection
+of Attorney Representative
+
+Privileges) Asserted
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+this litigation
+
+
+82
+83
+84
+1/2/2007-11/5/2007 emails between AMC\
+and Jeff Sloman regarding drafting
+85
+86
+87
+88
+89
+90
+victims
+12/6/2007 emails between AMCV, Andrew
+Lourie, Cyndee Campos, Jeff Sloman, Alex
+Acosta, Karen Atkinston, and Nesbitt
+Kuyrkendall regarding correspondence from
+Ken Starr, request for a meeting from
+Epstein counsel, and need to notify victims
+of upcoming plea
+12/6/2007-12/7/2007 emails between
+AMCV, Cyndee Campos, Karen Atkinson,
+Jeff Sloman, and Alex Acosta regarding draft
+victim notification letter
+9/10/2007-/14/2007 emails between AMCV,
+Andrew Lourie, Jeff Sloman, Karen
+Atkinson, Rolando Garcia, Shawn Ball, and
+Alex Acosta regarding final plea
+negotiations, finalizing details with State
+Attorney's Office and final revisions to
+indictment package
+9/10/2007 email from AMCV to Jeff Sloman
+and John McMillan regarding Acosta inquiry
+about FBI investigation into State grand jury
+proceeding
+11/29/2007-12/1/2007 emails between
+AMCV, Alex Acosta, Jeff Sloman, Cyndee
+Campos, and Andrew Lourie regarding draft
+response to Jay Lefkowitz and victim
+notification letters
+12/6/2007-12/7/2007 emails between
+AMCV,
+1 Jeft Sloman, Cyndee Campos,
+Annette Castillo, Karen Atkinson, and
+Shawn Ball regarding request from State
+Attorney's Office for draft plea proffer
+
+IP
+IP
+
+
+91
+92
+94
+95
+96
+97
+counsel
+12/14/2007 email from AMCV to Alex
+Acosta, Jeff Sloman, Rolando Garcia, and
+Karen Atkinson with draft letters to State
+Attorney's Office and victims
+12/9/2007-12/12/2007 emails between
+AMCV, Jeff Sloman,
+Annette Castillo, Karen
+Atkinson, and Rolando Garcia regarding
+drafting response to personal attacks and
+upcoming meeting with Ken Starr
+12/12/2007 emails between AMCV,
+Frederica Devlin, and Bob Senior regarding
+planning indictment review
+12/17/2007 email from AMCV to Jett
+Sloman inquiring about case status and
+informing Sloman regarding agent concern
+about victim notifications
+3/10/2008-3/12/2008 emails between
+AMCV, Robert Senior, Myesha Braden,
+Krishna Patel,
+1, E.J.
+Yera, and Karen Atkinson about Epstein
+attempts to contact victims and finding
+counsel for victims
+3/12/2008-3/17/2008 emails between
+AMCV,
+and E.J. Yera
+regarding search warrant application and
+execution of search warrant
+98
+3/14/2008-3/17/2008 emails between
+AMCV.
+- and Robert Senior regarding
+corrections to indictment package and
+proposed grand jury presentation
+
+Attorney-client privilege
+Attorney client privilege
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+this litigation
+this litigation
+
+
+99
+100
+101
+102
+3/14/2008-3/19/2008 emails between
+AMCV,
+, Jason
+Richards, Robert Senior, Jeff Sloman, Karen
+Atkinson, and Rolando Garcia about Epstein
+attempts to contact victims and finding
+counsel for victims
+3/14/2008 emails between AMCV, Rolando
+Garcia, Karen Atkinson, Frederica Devlin,
+and Shawn Ball regarding complete
+indictment package for Robert Senior final
+3/12/2008 emails between AMCV, Drew
+Oosterbaan, and Myesha Braden regarding
+CEOS meeting with Epstein counsel
+3/5/2008-3/6/2008 emails between AMCV,
+Alex Acosta, Jell Sloman, Drew Oosterbaan,
+Robert Senior, Myesha Braden, Rolando
+Garcia, and Karen Atkinson regarding
+meeting in DC, additional information to
+prepare for meeting, and new information
+from ongoing investigation
+Attorney-client privilege
+Alict to pins in rimation
+ictims who are not parties t
+this litigation
+IP
+103
+
+
+
+P-013279
+P-013280
+P-013281
+SUPPLEMENTAL PRIVILEGE LOG
+3/15/08 Emails between A. Acosta and A. Marie
+Villafaña, R. Senior, D. Lee and K. Atkinson ro
+proposed correspondence to Jay Lefkowitz
+Handwritten note re Epstein investigation
+P-013282
+P-013283
+P-013284
+P-013285
+7/9/08 Email from A. Maric Villafaña to A.
+Acosta, J. Sloman, K. Atkinson, and FBI re
+roposed response to Goldberger letter re victin
+notification
+eliberative Proces
+
+
+
+P-013293
+P-013299
+P-013300
+P-0133303
+P-013304
+P-013325
+P-013326
+P-013329
+P-013330
+P-013333
+P-013334
+P-013337
+File folder entitled "8/15/08 AMCV e-mail re
+Agrmt" containing 8/15/08 e-mails from A. Marie
+Villataña to A. Acosta, J. Sloman, R. Senior, K.
+Atkinson, D. Lee re follow up on Agreement and
+from A. Acosta to Ann Marie Villafana on issue
+of Special Master with attached 8/15/08 emails
+from A. Marie Villafaña to A. Acosta, J. Sloman,
+• Senior, K. Atkinson, D. Lee re Agreement;
+8/15/08 email from J. Lefkowitz to A. Marie
+Villafana, K. Atkinson, R. Black, M. Weinberg re
+Agreement; 8/14/08 emails from A. Marie
+Villataña to J. Lefkowitz, K. Atkinson, R. Black
+re interpretation of Agreement; email from J.
+Lefkowitz to A. Marie Villafaña, K. Atkinson re
+questions re Agreement; email from A. Marie
+Villalaña to J. Lefkowitz, K. Atkinson re
+production of Agreement to victims
+File folder entitled "8/18/08 Lefkowitz Ltr to
+AMCV" containing A.
+handwritten draft notes for proposed letter to J.
+Lefkowitz; 5/22/07 e-mail from A. Lourie to M.
+Menchel, J. Sloman, A. Marie Villafaña re
+meeting with G. Lefcourt with attached email
+File folder entitled "6/25/07 Lefcourt to Sloman
+Lefkowitz containing 9/17/07 e-mail from A.
+Marie Villafaña to R. Garcia, A. Lourie and from
+Seawi re sues arising during pendency or
+File folder entitled 11/13/07 Sloman to
+efkowitz (was this sent?)" containing draf
+1/13/07 letter from J. Sloman responding to J
+Lefkowitz's letter
+
+
+
+P-013338
+
+P-013342
+P-013350
+P-13351
+P-013361
+P-013362
+P-013366
+P-013367
+P-013372
+P-013373
+P-013503
+P-013504
+P-013507
+P-013508
+P-013514
+*12/6/07
+Sloman to
+Lokowitz containing 12/5/07 faxed eter wo
+cover sheet from K. Starr and J. Lefkowitz to A.
+Acosta
+File folder entitled "12/05/07 Starr to Acosta"
+with handwritten notes and edits by A. Marie
+File folder
+entitled "12/21/07 Lefkowitz to
+Acosta" containing handwritten notes by A
+Marie Villafaña, 12/21/07 letter from J
+Lefkowitz to A. Acosta re performance of NPA
+and appeal to Washington
+with attorney
+File folder labeled *12/26/07 Lefkowitz t
+Acosta" containing 2 copies of draft letter fron
+A. Acosta to J. Lefkowitz (with 12/28/07 fax
+header)
+File folder labeled "Draft Itr from Sloman to
+Lefkowitz re termination" containing draft letter
+dated "April , 2008" from J. Sloman to J.
+Lefkowitz concerning the compliance with the
+File folder labeled "Internal Corr." containing
+11/28/07 c-mails from J. Sloman to A. Marie
+Villafaña re responding to 11/28/07 e-mail from
+1. Lefkowitz to J. Sloman regarding victim
+
+[Not considered
+privileged. Will be
+roduced to opposing
+ounsel upon lifting o
+
+
+P-013525
+P-013526
+P-013527
+P-013528
+P-013530
+P-013532
+P-013537
+P-013531
+P-013538
+P-013553
+P-013554
+Draft 11/30/07 letter from A. Acosta to K. Stari
+co'd to J. Sloman and A. Marie Villafaña re
+compliance with Agreement and internal emails
+from J. Sloman, A. Acosta, and A. Lourie re
+items to address in letter
+5/23/07 e-mail from A. Marie Villafaña to K.
+Atkinson re draft proposed internal e-mail about
+nanding 01
+and attached email
+orrespondence between Andrew Lourie and G
+Lefcourt
+Handwritten notes by A. Marie Villafana dated
+9/21 re telephone conference with possible victim
+representative, conflict check with names and
+cmail listed, list of names of potential victim
+representatives,
+guideline calculation, email containing contact
+info for potential victim representative, draft Non
+Prosecution Agreement dated 9/10/07 4:17 pm
+Typed note addressed to "Dear David" re
+response to grand Jury subpoena
+File folder labeled "Notes Re Post-Agreement
+Communications" containing handwritten notes
+by A. Marie Villafaña
+File
+folder
+labeled "E-mails
+Re
+Plea
+Negotiations" containing:
+• 11/28/07 e-mail from A. Lourie to A
+Marie Villafaña, A. Oosterbaan, R. Garcia
+re non-prosccution agreement, with
+• 9/19/07 e-mail from A. Marie Villafaña to
+1. Louric, R. Garcia, K. Atkinson ro
+negotiating
+• 9/18/07 e-mail from A. Marie Villafaña to
+A. Acosta, A. Louric, R. Garcia, K.
+Atkinson, J. MeMillan re negotiating
+strategy;
+• 9/17/07 e-mail from A. Marie Villafaña to
+• Acosta re negotiatior
+9/17/07 e-mail from A. Marie Villafaña
+R. Garcia, A. Acosta, A. Lourie, K.
+Atkinson, j. McMillan re negotiations;
+• 9/17/07 e-mail from A. Marie Villafaña to
+
+
+
+R. Garcia, A. Lourie
+re negotiation
+strategy:
+• 9/14/07 e-mail from A. Marie Villafaña to
+J. Sloman, A. Acosta, R. Garcia, A.
+Louric, K. Atkinson, S. Ball re proposed
+lea agreement and Information
+• 9/14/07 e-mail from A. Marie Villafaña t
+J. Sloman, A. Acosta, A. Lourie, R.
+Garcia, K. Atkinson, J. McMillan, S. Ball
+re plea negotiations;
+• 9/13/07 e-mail from A. Maric Villafaña to
+K. Atkinson, S. Ball, J. McMillan re
+indictment package;
+• 9/13/07 e-mail from A. Marie Villafaña to
+A. Oosterbaan re trust agreement with
+attached correspondence;
+• 9/13/07 c-mail from A. Marie Villafaña to
+A. Oosterbaan re trust agreement;
+• 9/13/07 e-mail from A. Marie Villafaña to
+R. Garcia, J. Sloman re conference call
+with J. Lefkowitz;
+• 9/13/07 e-mail from A. Marie Villafaña to
+A. Lourie
+re plea negotiations with
+attached correspondence;
+• 9/13/07 e-mail from A. Marie Villafaña to
+A. Lourie re charging strategy with
+attached correspondence;
+• 9/13/07 e-mail from A. Marie Villafaña to
+K. Atkinson, S. Ball, J. McMillan re
+indictment package;
+• 9/13/07 e-mail from A. Marie Villafaña to
+A. Acosta, J. Sloman, R. Garcia, K
+Atkinson, A. Lourie re plea negotiations;
+• 9/11/07 e-mail from A. Marie Villafaña to
+. Lourie re meeting w/ G. Lefcourt wit
+• 9/11/07 e-mail from A. Marie Villafaña to
+J. Sloman re non-prosecution agreement
+with attached correspondence:
+
+
+
+J. Sloman re negotiations; 9/10/07 e-mail
+with attached correspondence;
+• 9/14/07 e-mail from J. Sloman to A
+Marie Villafaña, A. Acosta, R. Garcia, A
+Lourie, K. Atkinson, S. Ball, re finalizing
+documents;
+• 9/14/07 e-mail from A. Lourie to A. Marie
+Villafaña
+charging
+strategy with
+attached correspondence;
+• 9/13/07 e-mail from A. Oosterbaan to A.
+Marie Villataña re setting up trust fund;
+• 9/13/07 e-mail from A. Lourie to A.
+Marie Villafaña re final negotiations with
+attached correspondence;
+• 9/11/07 e-mail from A. Lourie to A. Marie
+Villafaña
+scheduling
+a meeting
+regarding finalizing the agreement with
+attached correspondence
+• 9/11/07 e-mail from J.
+. Sloman to A.
+Marie
+Villafaña
+non-prosecution
+agreement
+edits
+attached
+correspondence;
+• 9/11/07 e-mail from J. Sloman to A.
+Marie
+Villafaña
+Te
+non-prosecution
+agreement
+edits
+with
+correspondence;
+attached
+• 9/11/07 e-mail from A. Oosterbaan to A.
+Marie Villafaña re negotiations with
+P-013609
+P-013615
+strategy
+File folder entitled "I Target Letter" containing
+copy of signed letter and contact info for counsel
+
+
+
+P-013616
+P-013621
+P-013622
+P-013643
+P-013644
+P-013653
+P-013654
+P-013745
+P-0013747
+P-013811
+P-013833
+P-013834
+Through
+P-013835
+File folder entitled "Atty Notes re Revised
+Indictment" containing handwritten notes by A.
+Marie Villafaña
+File folder entitled "Research Re Possible
+Misdemeanors" containing attorney research
+| File folder entitled "Notes Re Plea Negotiations"
+containing
+9/17/07 e-mail from A. Maric
+Villafaña to J. Richards, N. Kuyrkendall re status
+update; undated and typed handwritten notes by
+A. Marie Villafaña re items to be completed on
+case, strength of case, victim
+summary of evidence, guidelines calculations
+File folder entitled "Plea Agreement Drafts"
+containing several draft plea agreements some
+with handwritten notes by A. Marie Villafaña;
+copies of draft non-prosecution agreement some
+with handwritten notes by A. Marie Villafaña;
+copy of a draft Information
+File folder entitled "Draft Non-Prosecution
+Agreements" containing several draft non-
+| Also contains information
+subject to privacy rights of
+victims who are not
+Circuit Court; copies of draft Information; draft
+plea proffer; draft motion and order to seal; draft
+›enalty sheet; draft plea agreement
+ile folder entitled "Information Packet Drafts
+containing several drafts of Informations, anc
+omplete draft Information packet
+Two pages of filed document, D.E. 62, page 2 of
+54 my pages 6 of 54, containing handwritten
+
+
+
+P-013836
+P-013837
+P-013838
+P-013841
+P-013842
+P-013843
+P-013844
+P-013845
+P-013846
+P-013847
+P-013849
+P-013850
+P-013851
+P-013853
+P-013854
+P-013855
+P-013856
+P-013857
+Atly work-product
+underlines, written notes, and comments by DOJ
+attorney
+Email from Dexterr Lee to Ruth Plagenhoef
+OPR), February 25, 2011, 4:31 p.m., Re
+equest for OPR Investigation - Jeffrey Epstei
+Non-Prosecution Agreement
+E-mail, Marie Villafana to Andrew Lourie,
+Rolando Garcia, and Karen Atkinson, September
+19, 2007, 4:33 p.m., RE: Plea Agreement
+E-mail, Andrew Lourie to Marie Villafana,
+September 19, 2007, 4:21 p.m., RE: Epstein
+with internal
+J.S. Attorney's Office e-mail:
+attached
+c-mail, (
+Fando Garcia, and Karen Akinson, Septembie,
+18, 2007, 11:43 a.m., RE: Draft Agreements?,
+with e-mail from Jay Lefkowitz (September 18,
+2007, 11:09 a.m.) attached
+E-mail, Marie Villatana to Alex Acosta, Andrew
+Lourie, Rolando Garcia, Karen Atkinson, and
+John McMillan, September 18, 2007, 9:31 a.m.,
+RE: Epstein Negotiations
+E-mail, Marie Villafana to Rolando Garcia and
+Andrew Lourie, September 17, 2007, 10:35 a.m.
+RE:
+Epstein [providing update re plea
+E-mail, Marie Villafana to Andrew Oosterbaan,
+September 13, 2007, 8:10 p.m., RE: Epstein,
+with e-mail from Andrew Oosterbaan (September
+13, 2007, 7:54 p.m.), attached
+Indrel Lauric, Silar 00. 2007. 524 p.m.
+E-mail, Marie Villafana to Jeff Sloman
+September 6, 2007, 5:47 p.m., RE: Epstein, with
+c-mail from Jeff Sloman (September 6, 2007,
+5:35 p.m.), attached
+atty-client privilege
+Ally work-product
+Alty work-product
+
+
+
+P-013858
+P-013859
+Through
+P-013860
+P-013861
+P-013865
+P-013866
+P-013867
+P-013868
+P-013869
+P-013870
+P-013871
+Email, Marie
+Villafana
+September 6, 2007, 9:29 a.m.,
+email. Gerald Lefcour to Maric Villafana, Lilly
+Ann Sanchez, Roy Black, re: Jeffrey Epstei
+[Not considered
+privileged. Will be
+slay]
+atty-client privilege
+E-mail, Marie Villafana to Matthew Menchel,
+July 13, 2007, 3:14 p.m., RE: Epstein, with e-
+mail from Menchel (July 5, 2007, 3:30 p.m.),
+Villafana to Menchel (July 4, 2007, 5:16 p.m.),
+and Sloman to Villafana (July 3, 2007, 1:47
+P-013872
+Gerald Lefcourt to Andrew
+Villafana, and Lilly Ann Sanchez (May 22, 2007,
+-mail, Andrew Lourie to Matthew Menchel, Jel
+loman, and Marie Villafana, May 22. 2007. 3:1
+P-013873
+
+
+
+P-013874
+Through
+P-013875
+P-013876
+P-013877
+P-013878
+P-013879
+Inadvertently marked as privileged, will be
+produced
+E-mail, Villafana to Louric,
+Garcia, and
+with e-mail from
+Lefkowitz to Villafana (September 19, 2007, 3:44
+p.m.), and Lefkowitz to Villafana (September 19
+P-013880
+P-013882
+P-013883
+P-013884
+P-013886
+P-013887
+P-013888
+Villafana and Garcia (September 19, 2007, 3:50
+p.m.), Villafana to Lourie (September 19 2007,
+2:36 p.m.), Lourie to Villafana (September 19,
+2007, 2:33 p.m.), and Villafana to Lourie and
+Garcia (September 19, 2007, 2:31 p.m.), attached
+E-mail,
+Villafana
+to Lourie,
+Arkinson, September 18, 2007, l.4a a.m., and
+(September 18, 2007, 10 ai, and Villa ana
+to Lefkowitz (September 18, 2007, 9:14 a.m.),
+ande Lefkowitz to Villafana (September 18
+2007, 8:59 a.m.), attached
+E-mail, Villafana to Acosta, Louric, Garcia,
+Atkinson, and McMillan, September 18, 2007,
+9:31 a.m., RE: Epstein Negotiations
+E-mail,
+Villafana to Garcia and Lourie,
+September 17, 2007 10:35 a.m., RE: Epstein.
+with e-mail from Garcia (September 17, 2007,
+E-mail, Marie Villafana to Andrew Oosterbaan,
+13, 2007, 7:54 p.m.), attache
+E-mail, Maric Villafana to Jeff Sloman and
+Andrew Lourie, September 10, 2007, 5:24 p.m.,
+RE: FBI
+
+
+
+P-013889
+P-013890
+P-013891
+P-013892
+Through
+P-013893
+P-013894
+P-013898
+P-013899
+P-013900
+P-013901
+P-013902
+P-013903
+P-013904
+P-013905
+E-mail,
+Marie
+Villafana to
+Jeff Sloman,
+September 6, 2007, 5:47 p.m., RE: Epstein, with
+e-mail from Jeff Sloman (September 6, 2007,
+5:35 p.m.), attached
+Email,
+Villafana
+september 6, 2007, 9:29 a.m.,
+Re: MesSing on
+Email, Gerald Lefcourt to Marie Villafana, Lilly
+Ann Sanchez, Roy Black, re: Jeffrey Epstein
+[Not considered
+privileged. Will be
+E-mail, Marie Villafana to Matthew Menchel,
+July 13, 2007, 3:14 p.m., RE: Epstein, with e-
+mail from Menchel (July 5, 2007, 3:30 p.m.),
+Villafana to Menchel (July 4, 2007, 5:16 p.m.),
+and Sloman to Villafana (July 3, 2007, 1:47
+atty-client privilege
+E-mail, Marie Villafana to Matthew Menchel,
+Jeft Sloman, Andrew Lourie, and Karen
+mail from Gerald
+Jerald Lefcourt to Andrew. Lourie Marie
+Villafana, and Lilly Ann Sanchez (May 22, 2007.
+2:05 p.m.), attached
+Soman, and Marie Villana, May 21, 207, 3.11
+FW: Jeffrey Epstein, with e-mail from
+Lefcourt to Louric, Villafana, and Lilly Ann
+Sanchez (May 22, 2007, 2:05 p.m.), attached
+
+
+
+P-013906
+P-013907
+Through
+P-013908
+P-013909
+P-013911
+P-013912
+P-013914
+P-013915
+P-013918
+produced
+Memorandum, Lisa Howard, Assistant Counsel,
+Department of Justice, Office of
+Professional Responsibility (OPR), to Ruth
+Plagenhoef, Acting Associate Counsel, OPR,
+undated, Subject: Recommendation
+Memorandum, Lisa Howard, Assistant Counsel,
+OPR, to Ruth Plagenhoef, Acting Associato
+Counsel, OPR, Subject: Recommendation, witt
+handwritten note dated 5/4/11
+Memorandum, Lisa Howard, Assistant Counsel,
+OPR,
+to Ruth Plagenhoef, Acting Associate
+Counsel, OPR, Subject: Recommendation, with
+P-013919
+P-013921
+P-013922
+P-013924
+P-013925
+P-013927
+P-013928
+P-013930
+P-013931
+P-013933
+of the two page memorandum
+Draft letter, marked "Confidential", from Robin
+C. Ashton, Counsel, Office of Professional
+Responsibility to Wifredo A. Ferrer, United
+States Attorney, with handwritten corrections,
+strikethroughs, and added text
+Draft Letter, marked "Confidential", from Robin
+C. Ashton,
+to Wifredo A. Ferrer, with
+handwritten corrections
+Draft Letter, from Robin C. Ashton to Professor
+Paul G. Cassell, with handwritten correction
+Draft Letter, from Robin C. Ashton to Professor
+Paul G. Cassell, with handwritten corrections
+Draft Letter, from Robin C. Ashton to Professor
+Paul G. Cassell, with handwritten corrections,
+circled text, strikethroughs, and additional text
+
+Privilege; atty workproduct
+Privilege, atty workproduct
+Privilege; atty workproduct
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+
+
+P-013934
+P-013936
+P-013937
+P-013939
+P-013940
+P-013942
+P-013943
+P-013944
+P-013945
+P-013946
+P-013947
+P-013948
+P-013951
+Draft Letter, marked "Confidential," from Robin
+C. Ashton to Wifredo A. Ferrer, with handwritten
+corrections
+Draft Letter, Robin C. Ashton to Profcssor Paul
+G. Cassell, with handwritten corrections
+Draft Letter, marked "Confidential: To Be
+Opened by Addressce Only," Robin C. Ashton t
+Wifredo A. Ferrer, with handwritten corrections
+E-mail, Ruth Plagenhoef to Lisa Howard, May 5,
+2011, 11:19 a.m., RE: Re-write of Epstein letter:
+for your review, with c-mail from Lisa Howard to
+Ruth Plagenhoef (May 5, 2011, 11:08 a.m.), and
+Plagenhoef to Howard (May 5, 2011, 11:10 a.m.),
+and Howard to Plagenhoef (May 5, 2011, 10:41
+a.m.), attached
+E-mail, Plagenhoef to Howard, May 5, 2011,
+11:17 a.m., RE: Re-write of Epstein letters for
+your review, with
+e-mail from Howard to
+Plagenhoef (May
+5, 2011, 11:08
+a.m.),
+Plagenhoef to Howard (May 5, 2011, 11:01 a.m.),
+and Howard to Plagenhoef (May 5, 2011, 10:41),
+attached
+E-mail, Plagenhoef to Howard, May 4, 2011, 5:01
+p.m., RE: draft letters in Epstein matter, with e
+mail from Howard to Plagenhoef (May 4, 2011,
+4:57 p.m.), attached
+E-mail, Plagenhoef to Robin C. Ashton, May 4,
+2011, 4:08 p.m., RE: FYI on the Florida matter
+E-mail, Paul Cassell to Plagenhoef, May 3, 2011,
+12:23 p.m., RE: OPR Inquiry - request for
+information, with post-it note attached with
+landwritten attorney notes on telephone call
+etween Plagenhoef and Howard with Dexter Let
+and Marie Villafana
+E-mail, Plagenhoef to Howard and Robin C.
+Ashton, May 3, 2011, 12:30 p.m., FW: OPR
+Inquiry - request for information, with attached
+e-mails.
+Handwritten attorney notes on margin
+
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+Privilege
+Privilege
+Law Enforcement
+investigatory record, atty
+work product; deliberative
+tty work product; la
+inforcement investigatio
+record
+
+
+P-013952
+P-013953
+P-013954
+P-013955
+P-013956
+P-013846
+BE
+E-mail, Dexter Lee to Ruth Plagenhoef, March
+16, 2011, 10:52 a.m., RE: Referral of Cassell
+Request for Investigation, with e-mail from Paul
+Cassell to Dexter Lee and Marie Villafana
+(March 15, 2011, 7:21 p.m.), attached
+Plagenhoef to Neil Hurley, OPR,
+December 16, 2010, 10:59 a.m., FW: OPR
+Referral - Allegation of Misconduct - U.S.
+Attorney's Office, S.D.Fla., with e-mail from
+Dexter Lee to Plagenhoef (December 16, 2010,
+10:22 a.m.), attached. Handwritten attorney
+notations.
+Fourteen (14) pages of handwritten attorney notes
+on case, telephone interviews with DOJ attorneys
+P013969
+atty work-product; atty
+lient privilegi
+atty work-product, attyclient privilege
diff --git a/vision-fixhub/ds9-unparsed-05/b032196deb92cf91ce464b64e4b0bb726f34b76339bd9059cd9ca9ec85684336.receipt.json b/vision-fixhub/ds9-unparsed-05/b032196deb92cf91ce464b64e4b0bb726f34b76339bd9059cd9ca9ec85684336.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d9ff55d174008a4a7792fac6d17d7308449b03fd
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b032196deb92cf91ce464b64e4b0bb726f34b76339bd9059cd9ca9ec85684336.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -17164,
+  "dataset": "marble-joined",
+  "doc_id": "b032196deb92cf91ce464b64e4b0bb726f34b76339bd9059cd9ca9ec85684336",
+  "engine": "marble-apple-vision",
+  "event_count": 128,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "458946262d2220a8e8537248447771c5be90af73625ecd878738c53716466b0e",
+  "output_sha256": "4b30238fd0b9bbdd949fe0834b325feff7eb3d5c5f37099ebfb3bf2c1e943a67",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b04febde0fda7219802f4d6570b7f31e3199d53461fc3e9e68c1707edf5e649a.md b/vision-fixhub/ds9-unparsed-05/b04febde0fda7219802f4d6570b7f31e3199d53461fc3e9e68c1707edf5e649a.md
new file mode 100644
index 0000000000000000000000000000000000000000..8c704f0d84c1f4ee25430fbb858c839e03666474
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b04febde0fda7219802f4d6570b7f31e3199d53461fc3e9e68c1707edf5e649a.md
@@ -0,0 +1,177 @@
+Kellen
+Marcinkova
+
+
+Subject: RE: Draft Plea Agreement
+Pls send me your factual proffer
+-----Original Message-----
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.gov]
+Sent: Wednesday, September 19, 2007 4:06 PM
+To: Garcia, Rolando (USAFLS); Lourie, Andrew
+Subject: FW: Draft Plea Agreement
+Here are their new versions.
+A. Marie Villafaña
+Assistant U.S. Attorney
+561 209-1047
+-----Original Message-..--
+From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com]
+Sent: Wednesday, September 19, 2007 3:44 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Fw: Draft Plea Agreement
+
+For settlement purposes only
+Marie - I wanted to get this to you before I took off for nyc. I am landing at 7
+and would like to speak shortly thereafter.
+I am still considering which of the options you suggested Sunday. In this email,
+I am sending you a redline of your federal resolution. I am also working on a
+deferred prosecution agreement because it may well be that we cannot reach
+agreement here.
+aleement still onto have therer de castiny also like per are ton
+from Sunday that we consider a C plea.
+I know that Alex would have to sign off on it and that he has not done so as of
+now.
+Regarding my schedule, I am available tonight to speak, all afternoon tomorrow (I
+am in fed court in nyc on another criminal matter tomorrow am), and then all day
+Friday.
+I will plan on seeing you Monday. I am confident that one of the approaches we
+have discussed will work out.
+Jay
+...-- Original Message -.....
+3018
+P-014151
+
+
+From: Jay Lefkowitz
+Sent: 09/19/2007 03:35 PM EDT
+To: Jay Lefkowitz
+Subject: Draft Plea Agreement
+(See attached file: 9.19.07 Draft Plea Agreement
+(Clean) . doc)
+(See attached file: 9.19.07 Draft Plea Agreement
+(Redlined). doc)
+***********************************************************
+The information contained in this communication is confidential, may be attorneyclient privileged, may constitute inside information, and is intended only for
+the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland
+& Ellis International LLP.
+Unauthorized use, disclosure or copying of this communication or any part thereof
+is strictly prohibited and may be unlawful. If you have received this
+communication in error, please notify us immediately by return e-mail or by e-
+mail to postmaster@kirkland.com, and destroy this communication and all copies
+thereof, including all attachments.
+***********************************************************
+3019
+P-014152
+
+
+To:
+Subject:
+Thursday, September 20, 2007 3:35 PM
+Lourie, Andrew
+RE: small thoughts re agreement
+Hi Andy - I haven't seen a new non-pros agreement. but the last one they sent had all the same problems that
+were in their plea agreement. If I get one. I will let you know.
+A. Marie Villataña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL. 33401
+Phone 561 209-1047
+Fax 56l 820-8777
+From: Lourie, Andrew
+Sent: Thursday, September 20, 2007 2:52 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: RE: small thoughts re agreement
+I don't like 10, esp the reference to the petite policy. I sent an email to Alex telling him my thoughts. He will let you know
+directly what he wants you to do. Sorry but I am out of pocket until about 6:00 so you will have to send it. But as I said, I
+think Jay wants to go with the nonpros, which I have not even reviewed yet.
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie. C. Villafana@usdoj.gov]
+Sent: Thursday, September 20, 2007 1:56 PM
+To: Lourie, Andrew
+Subject: RE: small thoughts re agreement
+Importance: High
+Hi Andy - Here is the latest plea agreement, incorporating your thoughts and Alex's thoughts (see my earlier c-
+mail about paragraph 10) and the proposed Information. Can you take one last look, and then send it off to Jay?
+[jlefkowitz@kirkland.com] And in your e-mail can you tell him that this is the agreement approved by the U.S.
+Attorney and I need to know by tomorrow at 2:00 or so, so I can file the Info, get a judicial assignment, and try
+Thank you!
+P.S. Are you sure you don't want to review the indictment rather than making Rolando wade through
+everything?
+A. Marie Villațaña
+Assistant U.S. Attorney
+500 S. Australian Ave. Suite 400
+West Palm Beach. FL. 33401
+Phone 561 209-1047
+Fax 561 820-8777
+3027
+P-014153
+
+
+From: Lourie, Andrew
+Sent: Thursday, September 20, 2007 11:02 AM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: FW: small thoughts re agreement
+Marie, I think Alex's changes are all good ones. Please try to incorporate his suggestions, change the signature block to
+your name and send as final to Jay. Thanks
+3028
+P-014154
+
+
+To:
+Subject:
+Attachments:
+Thursday, September 20, 2007 1:56 PM
+Lourie, Andrew
+RE: small thoughts re agreement
+070919 Information charging 1512. wpd; 070920 10.05 am Plea Agreement 1512 counts. wpd
+Importance:
+High
+Hi Andy - Here is the latest plea agreement, incorporating your thoughts and Alex's thoughts (see my earlier e-
+mail about paragraph 10) and the proposed Information. Can you take one last look, and then send it off to Jay?
+[ilefkowitz@kirkland.com] And in your e-mail can you tell him that this is the agreement approved by the U.S
+Attorney and I need to know by tomorrow at 2:00 or so, so I can file the Info, get a judicial assignment, and try
+to set up an arraignment and change of plea for Monday? You also might want to remind them that there is at
+least 70 days between the plea and sentencing (plus the post-sentencing time to self-surrender). so they will
+have plenty of time to do everything else and to get Jeffrey's businesses wrapped up.
+Thank you!
+P.S. Are you sure you don't want to review the indictment rather than making Rolando wade through
+everything?
+•
+A. Marie Villatana
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL. 33401
+Phone 56l 209-1047
+Fax 561 820-8777
+From: Lourie, Andrew
+Sent: Thursday, September 20, 2007 11:02 AM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: FW: small thoughts re agreement
+Marie, I think Alex's changes are all good ones. Please try to incorporate his suggestions, change the signature block to
+your name and send as final to Jay. Thanks.
+3029
+P-014155
+
+
+To:
+Subject:
+Thursday, September 20, 2007 12:45 PM
+Lourie, Andrew
+RE: small thoughts re agreement
+Hi Andy - Just one question about paragraph 10
+y. I now remember
+why that was added. That was Alex's suggestion in one of the previous versions. I am going to try to combine
+all of the thoughts in one paragraph, and can you look at it before it goes out? It should be ready in about 15
+minutes.
+A. Marie Villafaña
+Assistant U.S. Attorne|
+500 S. Australian Ave. Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+From: Lourie, Andrev
+Sent: Thursday, September 20, 2007 11:02 AM
+To: Villatana, Ann Marie C. (USAFLS)
+Subject: FW: small thoughts re agreement
+Marie, I think Alex's changes are all good ones. Please try to incorporate his suggestions, change the signature block to
+your name and send as final to Jay. Thanks.
+3031
+P-014156
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/b04febde0fda7219802f4d6570b7f31e3199d53461fc3e9e68c1707edf5e649a.receipt.json b/vision-fixhub/ds9-unparsed-05/b04febde0fda7219802f4d6570b7f31e3199d53461fc3e9e68c1707edf5e649a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..8e6ed0b9a1510512cd376c40f24efe635dff4fda
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b04febde0fda7219802f4d6570b7f31e3199d53461fc3e9e68c1707edf5e649a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -441,
+  "dataset": "marble-joined",
+  "doc_id": "b04febde0fda7219802f4d6570b7f31e3199d53461fc3e9e68c1707edf5e649a",
+  "engine": "marble-apple-vision",
+  "event_count": 10,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "614d49ac6611728b199f56612358fde41d7b1c174d7235853acd6487507d604c",
+  "output_sha256": "59dd2130f7df788fa4a31ea5517c133c0d327aee93fb8877fb03df94a7ece4f9",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b0a76fa79bfdf87ea0949390e82f2f368bb5d9a8a05dd2309c4bfcb62b2c497e.md b/vision-fixhub/ds9-unparsed-05/b0a76fa79bfdf87ea0949390e82f2f368bb5d9a8a05dd2309c4bfcb62b2c497e.md
new file mode 100644
index 0000000000000000000000000000000000000000..84d984f061f66d73fbc1a3b6d428341bcabf1f45
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b0a76fa79bfdf87ea0949390e82f2f368bb5d9a8a05dd2309c4bfcb62b2c497e.md
@@ -0,0 +1,12376 @@
+Statements
+
+
+Bear, Stearns & Co. Inc.
+What's In This Statement
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+Transaction Detail
+INTERNATIONAL CHARITABLE
+INTERESTS I| 8-30-94
+C/O FINANCIAL TRUST COMPANY *
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+3,324
+-3,324
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent - 80.
+$3.324
+This summary is for informational purposes only. It is not intended as a tax document
+SPC This statements four beratined purposes cedr lt ne reene date at docume intomation
+10/26/02;11:59 001
+
+
+2 of 4
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+10/26/02;11:58 001
+V637
+
+
+3 of 4
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+53.323.52
+2.03
+5,221,438.33
+$5,221,440.36
+-5,224,763.88
+$-5,224,763.88
+....
+-3,323.52
+$0.00
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+2,869.25
+454.27
+$3,323.52
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+Foreign Tax Withheld
+THIS PERIOD
+0.00
+2.03
+$2.03
+0.00
+027
+CLOSING
+0.00
+0.00
+--...
+$0.00
+YEAR TO DATE
+47,672.19
+6,641.63
+$54.313.82
+-98.70
+10/26/02;11:58 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+V637
+
+
+4 of 4
+Transaction Detail
+INTEREST
+DATE
+10/08/02
+POST AND CLOSE CA INT
+TOTAL
+MISCELLANEOUS
+10/08/02
+10108/02
+10/08/02
+"JOURNAL
+10708/02
+10/08/02
+
+JOURNAL'
+10/14/02
+"JOUANAL"
+10/1402
+"JOURNAL
+10/21.02
+10/2102
+"JOUANAL
+10/2102 JOANAL
+i021/02
+JOURNAL"
+TOTAL
+SYMBOUCUSIP
+TO:
+FROM: SIZI
+* JRL *
+FROM SZ
+* JRL
+* JAL *
+• JAL
+* JAL
+* JAIL *
+FROM: SUZ
+TO CLOSE
+CASH
+TO CLOSE LINE
+CASH
+TO CLOSE LINE
+-1-USD
+I2US0
+i-USD*
+-T:USD
+-T-USD
+T2-USD**
+T1:USD
+QUANTITY
+RATE (SI
+DEBIT AMOUNT
+3,225.55
+2.03
+*454.27
+100.00
+100.00
+5.063,307.81
+157,57422
+$-5,224.763.88
+027
+DEBIT AMOUNT
+203
+*454.27
+100.00
+5,063,307.81
+*157.574.22
+$5,221,438.33
+10/26/02;11:58 001
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27, 2002
+2.03
+$2.03
+VB37
+
+
+Bear, Stearns & Co. Inc.
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+What's In This Statement
+Financial Summa...................
+Your Portfolio Holdings
+Transaction Detail
+4
+INTERNATIONAL CHARITABLE
+INTERESTS I| 8-30-94
+C/O FINANCIAL TRUST COMPANY *
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+3,324
+$3,324
+......
+3,320
+4
+There are no "Stop Loss' orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+$3.324
+$3,320
+Current market value
+This summary is for informational purposes only. It is not intended as a tax documen
+C pet tement should be retained for our records. See roverue side for important information
+09/28/02;15:02 001
+
+
+2 of 4
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+09/28/02;15:02 001
+VE36
+
+
+3 or a
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance.
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+2,869.25
+450.65
+$3,319.90
+Bear, Steams & Co. Inc.
+THIS PERIOD
+$3,319.90
+3.62
+$3.62
+3.62
+5. 32352
+CLOSING
+2,869.25
+454.27
+$3.322.52
+Income Summary
+THIS PERIOD
+Dividends
+0.00
+Credit Balance Int.
+3.62
+.......
+Total
+$3.62
+....-.
+Foreign Tax Withheld
+0.00
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+QUANTITY
+MARKE
+/ALUE
+3,324
+$3,324
+027
+YEAR TO DATE
+47,672.19
+6,639.60
+654,311.79
+.....
+-98.70
+3,324
+$3,324
+09/28/02;15:02 001
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+from the absolute market value of your portfolio.
+V636
+
+
+4 of 4
+Your Portfolio Holdings (continued)
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INTEREST
+DATE
+09/23/02 INT CR
+TOTAL
+SYMBOL/CUSIP
+SEP 02
+STOP
+****** End of Statement******
+QUANTITY
+$3,324
+RATE (%)
+027
+DEBIT AMOUNT
+09/28/02;15:02 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+CAEDIT AMOUNT
+3.62
+$3.62
+VE36
+
+
+Bear, Steams & Co. Inc.
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+What's In This Statement
+Financial Summary.....
+Your Portfolio Holdings
+Transaction Detail ..............................
+Fund Activity ....
+3
+4
+5
+INTERNATIONAL CHARITABLE
+INTERESTS I| 8-30-94
+C/O FINANCIAL TRUST COMPANY *
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+3,320
+$3,320
+.....
+9,536,275
+-9,532,956
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent -
+- 83.320
+Equities —
+$0
+$733,650
+Current market value
+$8.802,625
+SP This satement stori for retanal for oes retrie, Spot reverse das a a doctant intration.
+08/31/02;14:56 001
+
+
+2 of 7
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+08/31/02;14:56 001
+
+
+3 or 7
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+175,339.4
+........
+8,330, 152.62
+450.65
+8,326,355.49
+.....
+S16.656.958.76
+-17,128,978.34
+$-17,128.978.34
+-472,019.58
+63.319.90
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+Foreign Tax Withheld
+THIS PERIOD
+2,866.25
+450.65
+$3.316.90
+0.00
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+475,000.00
+339.48
+$475,339.48
+CLOSING
+2,869.25
+450.65
+$3,319.90
+.......
+027
+YEAR TO DATE
+47,672.19
+6,635.98
+.....
+$54,308.17
+_...
+-98.70
+3,320
+$3,320
+08/31/02;14:56 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+100%
+Unshaded portions denole debt balance and'or short
+
+
+4 of 7
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+SIMBOUCUSIP
+QUANTITY
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT THE
+07/31/02
+07731/02
+ö7731/02
+JÖURNAL'
+07731/02
+........
+DESCRPTION
+TONDIESING 1-USO
+TORE
+CACHEING NEW"
+TO:
+I-1-USD
+•JAL
+FINLAY ENTERPRISES INC
+-1-USD
+* JAL
+G-APPAREL GROUP LID
+TO:
+-1-USD
+ESTIMATED
+NUAL INCON
+CURREN
+(ELD (:
+3.320
+$3,320
+$3,319
+SYMBOLCUSIP
+CAND
+*FLY
+GIll
+QUANTITY
+-27,300
+7,150
+10,300
+-20,850
+027
+08/31/02;14:56 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+DEBIT AMOUNT
+
+
+5 of 7
+Transaction Detail (continued)
+SETLEMENT TRADE
+07/31/02
+07751/02
+
+
+
+JOUANAL
+
+7/31/0
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MODAY
+07/27/02
+07/30102
+"SOLD"
+DESCAIPTION
+OPENINGBALANCE
+OFFICE SERVICING YOUR ACOUNT
+HEARUSA INC
+NEW
+TO:
+JAI
+MANYIN
+* JAL
+HEAD NI
+NY REGISTRY
+TO:
+-1-USD
+-1-USD
+- 1-USD
+MAXWELL
+SHOE CO INC-CLA"
+TO:
+-1-USD
+•JRI
+NOVEL DENIM HOLDINGS LTD
+To:
+-1-USD
+JAL
+UNITED RETAIL CROUP INC
+TO:
+-1-USD
+* JAL
+CANDIES ING
+TO:
+7-1-USD
+* JAL
+SYMBOLCUSIP
+EAR
+"HED
+MAXS
+"VLD
+"URGI
+CAND
+QUANTITY
+-10,300
+1,500
+5,000
+1,200
+12,250
+15,150
+-1,420
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+July 26, 2002
+DEBIT AMOUNT
+SYMBOUCUSIP
+GrOX
+QUANTITY
+8,327,286.37
+5,000
+027
+1.0000
+08/31/02;14:56 001
+DEBIT AMOUNT
+5,000.00
+
+
+Bear, Steams & Co. Inc.
+6 of7
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+08/01/02
+68/01/02
+'''SOLD
+08/02/02 DVDEND
+DIVIDEND CLOSEOUT
+08/02/02 DIVIBEND
+DIVIDEND CLOSEOUT
+08/02/02 FUND
+ADJUST POSITION
+08/30/02
+TOTAL
+CLOSINGBALANCE
+INTEREST
+DATE
+08/21/02
+INT CR
+TOTAL
+SYMBOL/CUSIP
+AUG 02
+MISCELLANEOUS
+DATE
+MO/DAY
+07/31/02
+TO:
+* JRI
+- 1-USD
+SYMBOUCUSIP
+GIDXX
+"GTXX
+QUANTITY
+-8,318,333.38
+3,952.99
+1.0000
+1.0000
+0.00
+QUANTITY
+RATE (%)
+DEBIT AMOUNT
+DEBIT AMOUNT
+480,339.48
+027
+08/31/02;14:56 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+DEBIT AMOUNT
+8,318,333.38
+3,952.99
+2,639.90
+''226.35
+$8.330.152.62
+450.65
+$450.65
+
+
+7 of 7
+Transaction Detail (continued)
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+07/31/02
+TOURNIN
+07731/02
+"JOURNAL"
+08/02/02
+ö8/02/02*
+JOUANAL
+08/0202JOÜANAL
+08/02/02
+"GUANAL"
+08708/02 JOURNAL
+08/08/02
+IOURNAL
+TOTAL
+FROM: SJZ
+* JAL *
+*07/02 CLA CHG]
+• JAL *
+•'T0:SJ2
+• JRL •
+• JAL
+ГО: SJi
+• JAL *
+FROM: SJZ
+• JRL *
+OFFICE SERVICING YOUR ACOUNT
+12-USD
+-USD"
+-15
+T2:US0
+DEBIT AMOUNT
+339.48
+2:USD*
+T1-USD
+3952.99
+8.322.286.37
+3,322,060.02
+$-17,128,978.34
+STOP
+****** End of Statement******
+027
+339.48
+3.00
+3,952.99
+8.322,060.02
+$8,326,355.49
+08/31/02;14:56 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+
+
+Bear, Steams & Co. Inc.
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+What's In This Statement
+Financial Summayy•.•.•••••.•••••••••••••I''
+Your Portfolio Holdings
+........
+Transaction Detai..........*/
+Fund Act................................
+3
+4
+5
+7
+INTERNATIONAL CHARITABLE
+INTERESTS I| 8-30-94
+C/O FINANCIAL TRUST COMPANY *
+ATIN LARRY KEMP
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+733,650
+475,339
+8,327,286
+$9.536,275
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+9,629,476
+-93.201
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+Equities -
+$8.802,625
+$8,740,612
+$733,650
+$888,864
+Current market value
+SP This satement store for atanal por oes recorde Set reverse das a a doctant intormation.
+07/27/02;19:19 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+07/27/02;19:19 001
+
+
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Money Fund
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERIOD
+458,554.3
+51,289.59
+485,229.17
+495.50
+703.69
+$537,717.95
+-520,229.17
+-703.69
+S. 620.932.88
+16,785.09
+$475.339.48
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+458,006.72
+547.67
+$458,554.39
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+Foreign Tax Withheld
+THIS PERIOD
+10,229.17
+495.50
+510.724.67
+0.00
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+CLOSING
+475,000.00
+339.48
+$475,339.48
+YEAR TO DATE
+44,805.94
+6,185.33
+-______.
+50,991.2
+-98.70
+8,802,625
+733,650
+9.536,275
+07/27/02;19:19 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+Your Portfolio
+Allocation
+Equities
+7%
+Cash & Equivalent—
+93%
+Unshaded portions denole debt balance and'or short
+
+
+4 of a
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+THE TREASURERS FUNDING
+DOMESTIC PRIME MAM PORTFOLIO.
+THE TREASURERS FUNDING
+DOMESTIC PRIME MIM PORTFOLIO
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+CANDIES INC
+CANDIES INC
+CACHE INC NEW
+FINLAY ENTERPRISES INC
+G I APPAREL GROUP LTD
+HEARUSA ING
+NEW
+.....••••...
+I-MANY INC
+HEAD NV
+NY REGISTRY
+... ..
+MAXWELL SHOECO INC-CLA
+•••••••••••••••••••••••••••••••••••••••••••••
+JOVEL DENIM HOLDINGS LTD
+SYMBOLCUSIP
+GTOXX
+GTDXX
+QUANTITY
+3.323,333.3
+3,952.99
+1.0000
+1.0000
+SYMBOL CUSIP
+CAND
+CAND
+CACH
+FNLY
+GIIl
+EAR
+IMNY
+«авианали.
+HED
+MAXS
+CASH
+MAGN
+CASH
+CASH
+............
+CASH
+CASH
+QUANTITY
+27,300
+1,420
+7,150
+.......
+10,300
+20,850
+10,300
+ASI
+CASH
+1,500
+...........
+5,000
+.....
+CASH
+1,200
+''CASH *12:258•
+12,250
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+MARKET
+VALUE
+475,339
+....
+8,323,333
+3,953
+$8.802,625
+ESTIMATED
+ANNUAL INCOME
+125,682
+60
+$125,742
+.510
+.......
+1.5178
+3.3000
+3.3000
+15.0000
+16.2500
+7.2400
+0.6700
+2.6300
+.....
+2.6600
+11.3000
+6.0600
+MARKET
+VALUE
+90,090
+4,686
+107,250
+167,375
+150,954
+6,901
+3,945
+.....
+13,300
+13,560
+74,235
+ESTIMATEC
+ANNUAL INCOME
+CURRENT
+YIELD (%)
+475
+- 35714
+027
+
+
+5 org
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+UNITED RETAIL GROUP INC
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+URGI
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+CASH
+QUANTITY
+15,150
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT TRADE
+DATE
+07/01/02 06/26/02
+07/02/02 06/27/02 SOLD"
+COSTCO WHOLESALE CORP-NEW
+EXECUTION BY OPCO
+VS 500 02-25-02
+COMMISSION
+SEC FEE
+-26.00
+AS OF 06/26/02
+CACHE ING NEW"
+EXECUTION BY INE
+IS 200 06-21-99
+COMMISSION
+SEC FEE
+16,00
+6.6900
+MARKE
+101,354
+$733,650
+$733,650
+$126,217
+$9,536,275
+ESTIMATED
+ANNUAL INCOME
+$475
+CURRENT
+YIELD (%)
+SYMBOL/CUSP
+COST
+'CACH
+QUANTITY
+-500
+-200
+36.95540
+''16:95000
+027
+07127/02;19:19 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+DEBIT AMOUNT
+18,437.14
+3,368.89
+
+
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+07/02/02
+06/20/02
+CANCEL BUY
+07/08/02 07/02/02 SOLD
+20/2H20
+07/09/02
+
+07/09/02
+'SOLD"
+07/22/02
+*07/17/02 SOLD
+POLO RALPH LAUREN CORP-CLA
+SEE NOTE 'S' ON BACK
+VS 200 06-20-02
+COMMISSION
+12,00
+AVO S/D 06/25/02
+TO CXL PREVIOUS BUY
+MAXWELL" SHOECO INC-CLA"
+XECUTION BY SLI
+S 600 08-16-0
+COMMISSION
+SEC FEE
+30.00
+AS OF 07/02/02
+I-MANY..........
+EXECUTION BY INET
+VS 100 07-05-01
+DOMMISSION
+SEC FE
+103.00
+SYMBOL TECHNOLOGIES INC
+VG PRICE SHOWN-DETAILS ON RE
+CTUAL CONFIRM TO YOUR AGEN
+UNSOLICITED
+0460/200 S
+VS 600 06-21-99
+COMMISSION
+SEC FEE
+AS OF 07/17102
+- 30.00
+TOTAL
+SYMBOLCUSP
+"MAXS
+IMNY
+*CACH
+027
+QUANTITY
+-200
+*600
+23.92500
+
+-100
+800
+600
+
+DELES L
+• 16.20620
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+DEBIT AMOUNT
+4,812.00
+8,786.73
+226.56
+5,976.85
+- 9,681.42
+$51,289.59
+
+
+T ora
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MODAY
+06/29/02
+07/03/02 BOUGHT
+07/10/02 BOUGHT
+67/18/02 BOUGHT
+67723/02 BOUGHT
+07/23/02 DIVIDEND
+DESCAIPTION
+OPENINGBALANCE
+DOES RE PORTFOLIO
+DOMESTIC PRIME MAM PORTFOLIO
+07/23/02
+DIVIDEND
+07/23/02**REINVEST
+MONTHLY DIVIDEND
+DOMEST PRINCE PORTOLD
+MONTHLY DIVIDEND
+HE TREASURERS" FUND INC*
+JOMESTIC PRIME MAM PORTFOLIO
+MONTHLY DIVIDEND REINVESTED
+67/23102 HEINVEST
+07/24/02 "SOLD
+MONTHLY DIVIDEND REINVESTED
+DOMESTIC PRE MAM PORTFOLIO
+CLOSINGBALANCE
+07/26/02
+TOTAL
+SYMBOUCUSIP
+GTOX
+GTOXX
+"GTOXX
+"GTOXX
+QUANTITY
+8,282,057.20
+15,000
+5,000
+11,000
+479,000
+9,413.70
+815.47
+475,000
+8,327,286.37
+027
+1.0000
+1.0000
+1.0000
+1.0000
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28,2002
+DEBIT AMOUNT
+15,000.00
+5,000.00
+11,000.00
+479,000.00
+..........
+9,413.70
+*315.47
+*9,413.70
+*815.47
+1.0000
+$-520,229.17
+475,000.00
+$485,229.17
+
+
+8 of a
+Transaction Detail (continued)
+INTEREST
+DATE
+07/22/02
+INT CR
+TOTAL
+JUL 02
+MISCELLANEOUS
+DATE
+MO/DAY
+07/24/02
+07/24/02
+TOTAL
+TRANSACTICN
+FROM: SIZ
+• JRL
+TO: SJZ
+* JAL *
+OFFICE SERVICING YOUR ACOUNT
+SYMBOUCUSIP
+12-USD
+-USD
+STOP
+****** End of Statement******
+QUANTITY
+RATE (SI
+DEBIT AMOUNT
+703.69
+$-703.69
+027
+DEBIT AMOUNT
+CRECIT AMOUNT
+703.69
+$703.69
+07/27/02;19:19 001
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+495.50
+$495.50
+
+
+ear, Steams & Co. In
+83 Madison AvenL
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOO June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+May 31,2002
+What's In This Statement
+Financial Summary.....
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity.....
+Trades Not Yet Settled
+aaaaaaaaaaaaaaaaaaaaaaaaaa
+3
+4
+5
+8
+INTERNATIONAL CHARITABLE
+INTERESTS I| 8-30-94
+C/O FINANCIAL TRUST COMPANY *
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+888,864
+458,554
+8,282,058
+$9,629,476
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+9,675,524
+-46,048
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+Equities -
+$8,740,612
+$8,709,241
+$888,864
+$966,283
+Current market value
+SP This satement stori for ratanal for you retrie. Spot revere did or dotan itormation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 ora
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Miscellaneous
+Amount Credited.
+Securities Bought
+Money Fund
+Miscellaneous
+Amount Debited.
+Net Cash Activity
+Closing Balance
+THIS PERIOD
+34,910.2
+....
+25,349.22
+109,726.37
+1,205.67
+13,211.44
+$149,492.70
+-4,812.00
+-207,726.37
+-13,310.14
+... .
+225,848.5
+.........
+-76,355.81
+.!!!
+$458.554.39
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+Foreign Tax Withheld
+THIS PERIOD
+10,384.37
+547.67
+$10.932.04
+-98.70
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+531,673.45
+3,236.75
+$534,910.20
+CLOSING
+458,006.72
+547.67
+$458,554.39
+.......
+027
+YEAR TO DATE
+34,576.77
+5,689.83
+....
+$40,266.60
+.....
+-98.70
+8,740,612
+888,864
+••••••••••••••••••••
+$9,629,476
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+May 31, 2002
+Your Portfolio
+Allocation
+Equities
+9%
+Cash & Equivalent—
+91%
+Unshaded portions denole debt balance and'or short
+
+
+4 ofa
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+THE TREASURERS FUND INC
+DOMESTIC PRIME MAM PORTFOLO.
+THE TREASURERS FUNDING
+DOMESTIC PRIME MIM PORTFOLIO
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+COSTCO WHOLESALE CORP-NEW
+CANDIES INC
+CANDIES INC
+CACHE INC NEW
+FINLAY ENTERPRISES INC
+GII APAREL GROUP LTD
+HEARX LTD
+COM NEW
+..........
+I-MANY INC
+HEAD NI
+NY REGISTRY
+BESIII••••••••••••••••••••••••••••••••
+MAXWELL SHOE CO INC-CL /
+.. . . . .
+NOVEL DENIM HOLDINGS LTD
+SYMBOLCUSIP
+GTDXX
+GTDXX
+QUANTITY
+8,278,919.68
+3,137.52
+1.0000
+1.0000
+MARKET
+VALUE
+458,554
+asasamaggaaaaaa.
+8,278,920
+3,138
+$8,740,612
+SYMBOUOUSIP
+COST
+CAND
+CAND
+CACH
+FNLY
+GIll
+EAR
+IMNY
+HED
+MAXS
+•........
+NVLD
+QUANTITY
+CASH
+500
+CASH
+38.6200
+27,300
+4.0500
+MRGN
+1,420
+1.0500
+CASH
+7,950
+13.6500
+CASH
+10,300
+16.4700
+CASH®
+20,850
+CASH*
+7.6500
+.....
+10,300
+0.8500
+CASH
+1,600
+2.7490
+.. . .
+.. . .
+CASH
+5,000
+3.1900
+'''E8*******••/••*•*******'••••••'''
+1,800
+CASH
+.... .
+15.8500
+.... ..
+12,250
+7.1500
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocktyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAPAYER NUMBER
+LAST STATEMENT
+May 31, 2002
+ESTIMATED
+ANNUAL INCOME
+123,356
+1.4900
+47
+1.4978
+$123,403
+ESTIMATEC
+ANNUAL INCOME
+CURRENT
+YELD (N)
+19,310
+110,565
+5,751
+108,518
+169,641
+159,503
+3,753
+4,398
+15,950
+8,53
+87,588
+475
+2.9781
+nasasanasasaaıııssansnsssnnanaar
+027
+
+
+5 or8
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+POLO RALPH LAUREN CORP-CL A
+SYMBOUCUSIP
+RL
+SBL
+UNITED RETAIL GROUP ING
+URGI
+Total Equities& Options
+TOTAL EQUITIES
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+CASH
+CASH
+.. . .
+CASH
+QUANTITY
+200
+800
+15,150
+Transaction Detail
+INVESTMENT ACTIVITY
+BATEMENT TRE
+06/13/02
+06/13/02
+JOURNAL"
+DESCRPTION
+CACHE ING NEW
+TO: SJZ
+-2-USD
+"CACHE ING NEW**
+FROM: SJZ
+• 1-USD
+* JRL »
+22.4000
+8.5000
+10.5000
+MARKET
+VALUE
+4,480
+.....
+6,800
+159,075
+$888,864
+$888,864
+$123,894
+$9,629,476
+ANNUAL INCOME
+CURRENT
+YIELD (S
+160.2353
+0.2353
+... .
+$491
+$491
+SIMBOLCUSP
+CACH
+'CACH
+QUANTITY
+-600
+• 600
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+May 31, 2002
+DEBIT AMOUNT
+
+
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+06/17/02
+06/12/02
+66/19/02 06/14/02**SOLB
+06/25/02 06/20/02
+2. BOUGHT
+TOTAL
+MONEY FUND ACTIVITY
+OPENINGBALANCE
+06/01/02
+06/03/02 SOLD
+08/04/02BOUGHT
+06/13/02 BOUGHT
+08/17702 BOUGHT
+06/24/02 DIVIDEND
+EXECUTION BY SLKC
+VS 600 06-21-99
+NOISSIWWOO
+SEC FEE
+"HOT TOPIC INC..
+EXECUTION BY NITE
+/S 600 03-05-02
+SEC FEE
+,30.00
+SEE NOTE "S* ON BACK
+VS 200 06-20-02
+COMMISSION
+12,00
+SYMBOLICUSIP
+CACH
+QUANTITY
+-600
+600
+16.70000
+- 25.65000
+_ 200 23.92500
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+May 31, 2002
+DEBIT AMOUNT
+9,974.69
+*15,37453
+4,812.00
+$-4,812.00
+$25,349.22
+SYMBOUGUSIP
+QUANTITY
+8,174,330.83
+100,000
+153,000
+10,000
+15,000
+1.0000
+10000"
+1.0000
+1.0000
+DEBIT AMOUNT
+153.000.00
+'10,000.00"
+15.000.00
+100,000.00
+"DOMESTO PRIME AM PORTFOLIO
+MONTHLY DIVIDEND
+*8.943.41
+027
+
+
+Bear, Steams & Co. Inc.
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+06/21/02 DIVIDEND
+DOMESTE SHEES PRANSLO
+MONTHLY DIVIDEND
+06/2102 REINVEST
+06/24702 REINVEST**
+88/28/02 8008AN'*
+MONTHLY DIVIDEND REINVESTED
+DOMEST PRESEN PORFOLIO
+MONTHLY DIVIDEND REINVESTED
+"ONESE PRE A PORTFOL
+06/28/02
+TOTAL
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+06/17/02
+HEAD NV
+NY REGISTRY
+EC 05/29/02 PAY 06/14/0:
+OREIGN TAX WITHHELI
+SYMBOL/CUSIP
+HED
+TOTAL
+INTEREST
+DATE
+06/21/02 INT CRI
+TOTAL
+SYMBOL/CUSIP
+JUN 02
+SYMBOUCUSIP
+•*******
+QUANTITY
+5,000
+WH
+QUANTITY
+QUANTITY
+8.943.41
+782.96
+***#**20,000
+8,282,057.20
+RATE (S)
+0.1316
+RATE (S
+027
+'•1:8008
+DEBIT AMOUNT
+98.70
+$-98.70
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+May 31, 2002
+DEBIT AMOUNT
+782.96
+8,943.41
+78238•
+*20,000.88
+$-207,726.37
+$109.726.37
+658.00
+$658.00
+DEBIT AMOUNT
+547.67
+$547.67
+
+
+8 of a
+Transaction Detail (continued)
+MISCELLANEOUS
+DATE
+MO/DAY
+ANSACTI
+06/14/02
+URNI
+06/14/02 JOURNAL
+TOTAL
+FROM: Suz
+* JAL *
+.....
+0: sJZ
+Bear, Steams & Co. Inc.
+12-USD
+Trades Executed Pending Settlement
+SEE MENT TRE
+07/01/02
+06/26/02
+07/02/02 06%
+06/27/02
+o2 SOLD
+TOTAL
+COSTCO WHOLESALE CORP-NEW
+CACHE ING NEW
+The above trades do not appear in arry other section of this statemere
+STOP
+****** End of Statement******
+DEBIT AMOUNT
+13,211.44
+$-13,211.44
+SYMBOLCUSP
+COST
+CACH
+027
+CRECIT AMOUNT
+13.211.44
+$13,211.44
+QUANTITY
+-500.00
+00.0
+36.9554
+16.9500
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+May 31,2002
+DEBIT AMOUNT
+$0.00
+18,437.14
+3.368.89
+$21,806.03
+
+
+Bear, Steams & Co. Inc.
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+April 26, 2002
+What's In This Statement
+Financial Summary.........................
+Your Portfolio Holdings
+Transaction Detail...........................
+Fund Actii...............
+3
+5
+7
+INTERNATIONAL CHARITABLE
+INTERESTS I| 8-30-94
+C/O FINANCIAL TRUST COMPANY *
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+Market Value of Your Portfolio
+966.283
+534,910
+8,174,331
+$9,675,524
+••••••••/••••••••••••
+9,532,004
+143,520
+Cash & Equivalent
+Equities -
+$8.709.241
+$8,636.162
+$966,283
+$895,842
+Current market value
+ere are no "Stop Loss" orders or other pending bu
+r sell open orders on file for your accoun
+SP This satement stori for ratanal for our red de. not revere did ora dotan itormation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or8
+Bear, Steams & Co. Inc.
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+3570.392.14
+63,926.51
+108,560.74
+626.55
+.......
+$173,113.80
+•••
+-208,560.74
+-35.00
+.. . .
+$-208,595.74
+-35,481.94
+$534,910.20
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+567,781.94
+2,610.20
+$570,392.14
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+8,560.74
+626.55
+59.187.29
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+CLOSING
+531,673.45
+3,236.75
+•...........
+$534,910.20
+YEAR TO DATE
+24,192.40
+5,142.16
+... ..
+29.334.5
+8,709,241
+966,283
+3,675,52
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+April 26, 2002
+Your Portfolio
+Allocation
+Equities
+9%
+Cash & Equivalent-
+91%
+Unshaded portions denole debit balance andor short
+
+
+4 of a
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+THE TREASURERS FUNDING
+DOMESTIC PRIME MAM PORTFOLIO.
+THE TREASURERS FUNDING
+DOMESTIC PRIME MIM PORTFOLIO
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+COSTCO WHOLESALE CORP-NEW
+CANDIES INC
+CANDIES INC
+CACHE ING NEW
+........
+FINLAY ENTERPRISES INC
+.. . .
+G-III APPAREL GROUP LTD
+HOT TOPIC INC
+HEARX LTD
+COM NEW
+I-MANY INC
+....
+HEAD N
+NY REGISTRY
+MAXWELL SHOE CO INC-CLA
+SYMBOLCUSIP
+GTOXX
+GTDXX
+QUANTITY
+8,171,976.27
+2,354.56
+1.0000
+1.0000
+SYMBOUCUSIP
+COST
+CAND
+CAND
+•......
+CACH
+........
+FNLY
+GIll
+HOTT
+........
+EAR
+IMNY
+......
+HED
+MAXS
+CASH
+CASH
+MRGN
+CASH
+............
+CASH
+CASH
+CASH
+CASH
+CASH
+... .
+CASH
+CASH
+QUANTITY
+500
+27,300
+1,420
+8,550
+10,300
+20,850
+600
+10,300
+1,600
+.. . .
+5,000
+1,800
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+April 26, 2002
+MARKET
+VALUE
+534,910
+....
+8,171,976
+2,355
+$8,709,241
+ESTIMATED
+ANNUAL INCOME
+122,580
+1.5000
+.......
+35
+1.4862
+39.2700
+4.6600
+4.6600
+17.0500
+15.8500
+8.3000
+25.6000
+0.9000
+4.3200
+3.2200
+13.6900
+MARKET
+VALUE
+19,635
+127,218
+6,617
+145,778
+163,255
+173,055
+15,360
+9,270
+6,912
+... .
+16,100
+24,642
+ESTIMATED
+ANNUAL INCOME
+CURRENT
+YIELD (%)
+475 29503
+2.9503
+027
+
+
+5 or8
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+NOVEL DENIM HOLDINGS LTD
+SYMBOL TECHNOLOGRES NE
+UNITED RETAIL GROUP INC
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLICUSIP
+NVLD
+SBL
+URGI
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+CASH
+•........
+MASH
+.. . .
+CASH
+QUANTITY
+12,250
+800
+15,150
+Transaction Detail
+INVESTMENT ACTIVITY
+SEEMENT TA
+04/29/02 04/24/02
+VS 200 02-20-02, 200 02-19-02
+COMMISSION
+00'82
+SEC FEE
+.27
+9.3500
+....
+8.5700
+9.0460
+MARKET
+VALUE
+114,538
+6,856
+137,047
+$966,283
+$966,283
+$123,106
+$9,675,524
+ANNE NONE
+CURRENT
+YIELD (S
+16 0.2334
+0.2334
+$491
+$491
+SYMBOLCUSP
+cc
+QUANTITY
+-400
+21.89000
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+April 26, 2002
+DEBIT AMOUNT
+8,712.73
+
+
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+04/29/02
+04/24/02
+05/03/02 04/30/02$ÖLD
+05/08/02
+
+05/08/02
+05/01702
+05/15/02 05/10/02
+Bear, Steams & Co. Inc.
+05/17702
+05714/02
+05/23/02
+0520/02
+HOT TOPIC INC
+EXECUTION BY MON
+SEC 00 03-05-02
+.08
+"CIRCUIT CITY STORES INC
+0-61-2000
+OMMISSIO
+SEC FEE
+,20.00
+"CIRCUIT CITY STORES INC
+CIRCUIT CITY GROUP
+EXECUTION BY RHCO
+VS 300 02-19-02
+COMMISSION
+SEC FEB
+21.00
+"HOT TOPIC INC***
+EXECUTION BY WEDB
+VS 300 03-05-02
+SEC FEE
+CIRCUIT CITY STORES INC
+CIRCUIT CITY GROUP
+EXECUTION BY BUCI
+COMMISSION -02
+SEC FEI
+113:00
+S OF 05/10/02
+"CIRCUIT CITY STORES INC
+ANGIE SHOWN DETALS ON REC
+UNSOLGIENFRM TO YOUR AGENT
+"MAXWELL"SHOE GO INCOLA"
+SYMBOLGUSIP
+HOTT
+"HOTT
+MAXS
+027
+QUANTITY
+-100
+300
+300*
+23.94670
+21.08590
+21.16800
+-300
+200*
+'22.27000
+
+600
+23.97670
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+April 26, 2002
+DEBIT AMOUNT
+2,379.59
+6,289.57
+,314.2
+6,665.79
+4,84285
+11,952.98
+
+
+7 of a
+Transaction Detail (continued)
+SETLEMENT TREE
+DATE
+05/24/02 05/21/02
+Bear, Steams & Co. Inc.
+POLO RALPH LAUREN CORP-CL A
+SEE NOTE 'S' ON BACK
+SE OF 0512102)
+36,00
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+04/27/02
+05/17/02 SOLD
+05/21702 BOUGHT
+ö5/24/02DIVIDEND
+05/21/02 DIVIDEND
+05/21/02*
+"REINVEST
+65/21702 REINVEST
+05/22702 BOUGHT
+DESCAIPTION
+OPENINGBALANCE
+DOES PAME PORTFOLIO
+MONTHLY DIVIDEND
+DOMEST PRIE A PORTFOLIO
+MONTHLY DIVIDEND
+MONTHLY DIVIDEND REINVESTED
+DOMEST REM PORTFOL
+MONTHLY DIVIDEND REINVESTED
+SYMBOLCUSIP
+RL
+QUANTITY
+-600
+28.36720
+CLEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+April 26, 2002
+DEBIT AMOUNT
+16,968.80
+$63,926.51
+SYMBOUCUSIP
+QUANTITY
+8,065,770.09
+100,000
+''100,000
+1:0000
+10000**
+DEBIT AMOUNT
+"100,000.00"
+100,000.00
+*7,859.58
+701.16
+"GTOXX
+7,859.58
+707:16
+100,000
+
+7,859.58
+"701:18
+180,000.00
+027
+
+
+8 of a
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MODAY
+05/31/02
+TOTAL
+TRANSACTKN
+CLOSINGBALANCE
+INTEREST
+DATE
+05/21/02 INT CR
+TOTAL
+MAY 02
+MISCELLANEOUS
+05/03/02
+TOTAL
+04/02 CLR CHG |
+STOP
+****** End of Statement******
+SYMBOL/CUSIP
+-15
+SYMBOUCUSIP
+QUANTITY
+8,174,330.83
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+April 26, 2002
+DEBIT AMOUNT
+$-208,560.74
+$108.560.74
+QUANTITY
+RATE (S)
+DEBIT AMOUNT
+626.55
+$626.55
+DEBIT AMOUNT
+35.00
+$-35.00
+CRECIT AMOUNT
+120
+
+
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+March 28, 2002
+What's In This Statement
+Financial Summary .............................
+Your Portfolio Holdings
+Transaction Detail ..............................
+FudA..............................
+Trades Not Yet Settle.................
+3
+4
+5
+INTERNATIONAL CHARITABLE
+INTERESTS I| 8-30-94
+C/O FINANCIAL TRUST COMPANY *
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+895.842
+570,392
+8.065.770
+$9,532,004
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+9,693,778
+-161,774
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+Equities -
+$8.636.162
+$8.827,945
+$895,842
+$865,833
+Current market value
+SP This satement stori for retanal for oes recorde, Spot reverse das a a doctant intration.
+
+
+2 of 9
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+04/27/02;13:44001
+
+
+3 org
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Money Fund
+Funds Withdrawn
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERIOD
+57.969.231.72
+80,158.22
+807,057.22
+3,456.20
+282,454.00
+$1,173,125.64
+-8,007,057.22
+-282,454.00
+-282,454.00
+8,571,965.2
+-7,398,839.58
+5570.392.14
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+7,903.22
+2,610.20
+.510.513.42
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total.
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+7,969,231.72
+0.00
+$7,969,231.72
+CLOSING
+567,781.94
+2,610.20
+$570,392.14
+.........
+027
+YEAR TO DATE
+15,631.66
+4,515.61
+**........
+20,147.2
+8,636,162
+895,842
+....
+$9,532,004
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+March 28, 2002
+Your Portfolio
+Allocation
+Equities
+9%
+Cash & Equivalent—
+91%
+Unshaded portions denole debt balance and'or short
+
+
+4 of g
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+THE TREASURERS FUNDING
+DOMESTIC PRIME MAM PORTFOLIO.
+THE TREASURERS FUNDING
+DOMESTIC PRIME MIM PORTFOLIO
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+COSTCO WHOLESALE CORP-NEW
+CANDIES INC
+CANDIES INC
+CACHE INC NEW
+CIRCUIT CITY STORES INC
+CIRCUIT CITY GROUP
+... . .
+FINLAY ENTERPRISES INC
+G-III APPAREL GROUP LTD
+HOT TOPIC INC
+.........
+HEARX LTD
+COM NEW
+••••••///••••••••••••••••••••••///•••••••••••••••
+I-MANY INC
+HEAD NI
+NY REGISTRY
+.......-...........
+SYMBOLCUSIP
+GTOXX
+GTDXX
+QUANTITY
+8,064,116.69
+1,653.40
+1.0000
+1.0000
+SYMBOUOUSIP
+COST
+CAND
+CAND
+CACH
+GIII
+.....
+HOTI
+....
+EAR
+HED
+CASH
+CASH
+MRGN
+CASH
+CASH
+CASH
+CASH
+CASH
+•......
+ASH
+CASH
+QUANTITY
+500
+27,300
+1,420
+8,550
+1,700
+10,300
+20,850
+.....
+.. ...
+10,300
+5,000
+MARKET
+VALUE
+570,392
+8,064,117
+1,653
+$8,636,162
+39.9200
+3.2500
+3.2500
+11.3300
+21.7900
+13.0000
+8.0500
+....
+23.7600
+... .
+1.0200
+.. !!!!
+5.0500
+......
+3.2000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+March 28, 2002
+ESTIMATED
+ANNUAL INCOME
+118,543
+.470
+-....
+24 1.4519
+$118,567
+ESTIMATE
+ANNUAL INCOME
+CURRENT
+YIELD (%)
+19,960
+88,725
+4,615
+96,872
+37,043
+33,900
+167,843
+....
+23,760
+10,506
+3,080
+....
+16,000
+119
+0.3212
+027
+....................•....•••
+920
+5.7500
+04/27102;13:44 001
+
+
+5 of g
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+MAXWELL SHOE CO INC-CLA
+NOVEL DENIM HOLDINGS LTD
+POLO RALPH LAUREN CORP-CLA
+YMBOL TECHNOLOGIES INC
+.. . . . .
+UNITED RETAIL GROUP INC
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+MAXS
+NVLD
+RL
+*SBL
+URGI
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+CASH
+.....
+CASH
+******..
+CASH
+CASH
+......
+CASH
+QUANTITY
+1,200
+12,250
+600
+800
+15,150
+Transaction Detail
+INVESTMENT ACTIVITY
+BATLEMENT TRIED
+DATE
+04/11/02
+04/08/02
+HOT TOPIC ING
+EXECUTION BY RSSF
+VS 700 03-05-02
+SEC FEE
+.47
+19.7000
+8.5500
+28.4700
+... .
+8.4100
+9.0000
+MARKET
+VALUE
+23,640
+/...
+104,738
+7,08
+•.......
+3,728
+136,350
+$895,842
+$895,842
+$119,622
+$9,532,004
+ANNUAL INCOME
+CURRENT
+YELD IN
+... . .
+16 0.237
+0.2378
+.........
+$1,055
+$1,055
+SYMBOLCUSIP
+HOTT
+QUANTITY
+-700
+22.23390
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+March 28,2002
+DEBIT AMOUNT
+15,548.26
+
+
+6 of g
+Transaction Detail (continued)
+SATEMENT TREE
+DATE
+04/11/02
+04/08/02
+04/23/02 04/18/02 SOLD"
+04/23702
+34/18/01
+04/24/02
+04/19/02
+''SOLD*
+04/24/02"
+04/19/02
+4/24/0
+04/19/02
+TOTAL
+POLO RALPH LAUREN CORP-CLA
+SEE NOTE 'S' ON BACK
+XECUTION BY BUC
+L0-62-50000 S
+SEC FISSION
+21.00
+"OFFICE DEPOT INC
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY MLOO
+VS 300 03-08-02
+COMMISSION
+SEC FEE
+121.00
+"TIMBERLAND CO-CLA
+VS 400 03-11-02
+COMMISSION
+SEC FEE
+31.00
+AS OF 04/18/02
+"CIRCUIT CITY STORES INC
+CIRCUIT CITY GROUP
+VS 100 02-20-02
+COMMISSION
+SEC FEE
+09.00
+"SYMBOL TECHNOLOGIES INC
+EXECUTION BY SBSH
+VS 400 06-29-01, 300 06-21-01,
+100 07-13-01
+COMMISSION
+SEC FEE
+28.00
+TIMBERLAND CO-CLA
+VS 500 03-11-02
+DOMMISSION
+SEC FEE
+180.00
+SYMBOLCUSP
+*ODP
+'SBL
+TBL
+027
+QUANTITY
+-400
+-300
+400
+-100
+800
+-500
+27.58740
+19.72000
+* 41.55420
+22.74000
+9.60070"
+42.65550
+04/27102;13:44 001
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+March 28, 2002
+DEBIT AMOUNT
+10,995.62
+5,879.82
+4+2859L
+2,252.93
+7,617.32
+21,282.10
+$80,158.22
+
+
+7 of g
+Transaction Detail (continued)
+DEPOSITS AND WITHDRAWALS
+DATE
+04/10/02
+CHECK
+PL 11OS301-03/1802
+BUCKINGHAM CAPITAL
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+03/29/02
+04/01/02
+64/03/02
+BOUGH
+BOUGHI
+04/09/02
+04/10/02
+*BOUGHT
+04/11702
+04/23/02
+"DIVIDEND
+OPENINGBALANCE
+"DOMESTE PRIME AN PORTFOLIO
+04/23/02
+MONTHLY DIVIDEND
+"DIVIDEND'
+04/23/02
+REINVEST
+MONTHLY DIVIDEND
+DAGER THE MESALO
+MONTHLY DIVIDEND REINVESTED
+04/23/02
+''REINVEST
+MONTHLY DIVIDEND REINVESTED
+DEBIT AMOUNT
+282,454.00
+$-282,454.00
+SYMBOUCUSIP
+*GTOXX
+"GTOXX
+"GTOXX
+QUANTITY
+858,712.87
+7.000,000
+400,000
+-700,000
+600,000
+- 100,000
+1.0000
+T.0000
+1.0000
+1.0000
+1000*
+6.240.57
+816.65
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+March 28, 2002
+DEBIT AMOUNT
+7,000,000.00
+00.000.0
+600,000.00
+700,000.00
+100,000.00
+6,240.57
+816.65
+6,240.57
+816.65
+
+
+8 of 9
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MONDAY
+04/26/02
+TOTAL
+TRANSACTKN
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+04/01/02
+BROWN SHOE COMPANY
+REC 03/18/02 PAY 04/01/02
+04/05/02
+'SYMBOL TECHNOLOGIES INC
+REC 03/11/02 PAY 04/05/02
+04/15/02 CIRCUT CITY STORES INC
+CIRCUIT CITY GROUP
+REC 03/29/02 PAY 04/15/02
+V/15/0
+FAMILY DOLLAR STORES INC
+REC 03/15/02 PAY 04/15/02
+TOTAL
+INTEREST
+DATE
+04/22/02
+INT CR
+TOTAL
+APR 02
+Bear, Stearns & Co. Inc.
+SYMBOUCUSIP
+SYMBOUGUSIP
+BWS
+FDO
+QUANTITY
+6,500
+4,100"
+1,800
+1,900
+SYMBOUCUSIP
+QUANTITY
+QUANTITY
+8,065,770.09
+RATE (S)
+0.1000
+0.0100
+0.0175
+0.0650
+RATE (%)
+027
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+March 28, 2002
+DEBIT AMOUNT
+$-8,007,057.22
+$807,057.22
+DEBIT AMOUNT
+650.00
+41.00
+31.50
+123.50
+$846.00
+DEBIT AMOUNT
+2,610.20
+$2,610.20
+
+
+9 or g
+Transaction Detail (continued)
+MISCELLANEOUS
+DATE
+MO/DAY
+04/12/02
+ANSACTIO
+JURN.
+04/12/02 JOURNAL"
+TO: SIZ
+COVER 4/T0 PTO
+* JRL *
+FROM: SiZ
+COVER 4/10 PO
+•JAL *
+TOTAL
+Bear, Steams & Co. Inc.
+2-USD
+11-USD
+DEBIT AMOUNT
+282,454.00
+$-282,454.00
+Trades Executed Pending Settlement
+SATEEMENT TRE
+04/29/02 04/24/02
+04/29/02 04/24/02 SOLD
+CIRCUIT CITY STORES INC
+CIRCUIT CITY GROUP
+HOT TOPIC INC***
+TOTAL
+The above trades do not appear in arry other section of this statemere
+SYMBOLGUSIP
+CC
+"HOTT
+STOP
+****** End of Statement******
+027
+CRECIT AMOUNT
+282,454.00
+$282,454.00
+QUANTITY
+-400.00
+21.8900
+100.00
+
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+March 28, 2002
+DEBIT AMOUNT
+$0.00
+8,712.73
+2.379.59
+$11,092.32
+
+
+Bear, Steams & Co. Inc.
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22,2002
+What's In This Statement
+Financial Summary .............................
+Your Portfolio Holdings
+Transaction Detail ........................
+Fund Activi................
+3
+4
+6
+38
+INTERNATIONAL CHARITABLE
+INTERESTS I| 8-30-94
+C/O FINANCIAL TRUST COMPANY *
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+865,833
+7,969,232
+858,713
+$9,693,778
+•••••••/••••••••••••
+9,003,940
+689,838
+Cash & Equivalent
+Equities
+Market Value of Your Portfolio
+$1,637,396
+$865,833
+Current market value
+358.827.045
+$7,366,544
+here are no "Stop Loss" orders or other pending bu
+r sell open orders on file for your account
+SP This satement stori for retanal for our record, Set reverse das a a doctant intormation.
+
+
+2 of 41
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 of 41
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Money Fund
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+35529.588.15
+8,644,609.56
+550,926.17
+2,195.49
+144,632.78
+$9,342,364.00
+-1,457,183.18
+-300,904.47
+-144,632.78
+....
+$ 1.902,720.43
+7,439,643.57
+$7,969,231.72
+Income Summary
+THIS PERIOD
+Dividends
+2,534.30
+Credit Balance Int.
+587.36
+Total
+$3.121.66
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total.
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+528,962.92
+625.23
+$529,588.15
+CLOSING
+7,969,231.72
+0.00
+$7,969,231.72
+.........
+027
+YEAR TO DATE
+7,728.44
+1,905.41
+$9,633.85
+8,827,945
+865,833
+$9,693,778
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+Your Portfolio
+Allocation
+Equities
+8%
+Cash & Equivalent -
+92%
+Unshaded portions denole debt balance and'or short
+
+
+4 of 41
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+THE TREASURERS FUNDING
+DOMESTIC PRIME MAM PORTFOLIO.
+THE TREASURERS FUNDING
+DOMESTIC PRIME MIM PORTFOLIO
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+COSTCO WHOLESALE CORP-NEW
+CANDIES INC
+CANDIES INC
+CACHE INC NEW
+CIRCUIT CITY STORES INC
+CIRCUIT CITY GROUP
+... . .
+FINLAY ENTERPRISES INC
+G-III APPAREL GROUP LTD
+HOT TOPIC INC
+.........
+HEARX LTD
+COM NEW
+••••••///••••••••••••••••••••••///•••••••••••••••
+I-MANY INC
+HEAD NI
+NY REGISTRY
+.......-...........
+SYMBOLCUSIP
+GTOXX
+GTDXX
+QUANTITY
+•:857,876.12
+836.75
+1.0000
+1.0000
+SYMBOUOUSIP
+COST
+CAND
+CAND
+CACH
+GIII
+.......
+HOTI
+.....
+EAR
+HED
+CASH
+CASH
+MRGN
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+500
+27,300
+1,420
+8,550
+1,800
+10,300
+20,850
+... ..
+1,700
+.. . .
+10,300
+1,600
+5,000
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+MARKET
+VALUE
+7,969,232
+....
+857,876
+837
+$8,827,945
+ESTIMATED
+ANNUAL INCOME
+12,268
+.430
+.......
+12 1.4337
+$12,280
+39.8200
+2.2000
+2.2000
+6.9500
+8.0400
+12.0000
+8.0000
+....
+20.9000
+... ..
+1.0500
+4.9600
+......
+3.2900
+MARKET
+VALU
+19,910
+60,060
+3,124
+59,423
+32,472
+123,600
+166,800
+.......
+35,530
+.. . .
+10,815
+7,936
+....
+16,450
+ESTIMATED
+ANNUAL INCOME
+CURRENT
+YIELD (%)
+126
+0.3880
+027
+...•••••••••••••••••••••••••••••
+920
+5.5927
+
+
+5 or 41
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+MAXWELL SHOE CO INC-CL A
+NOVEL DENIM HOLDINGS LTD
+POLO RALPH LAUREN CORP-CLA
+OFFICE DEPOT INC
+SYMBOL TECHNOLOGIES INC
+BERLAND COCAI
+UNITED RETAIL GROUP ING
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+MAXS
+NVLD
+RL
+ODP
+SBL
+™BL
+URGI
+CASH
+.....
+CASH
+CASH
+CASH
+CASH
+CASH
+..... .
+CASH
+QUANTITY
+1,200
+12,250
+300
+1,600
+900
+15,150
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+16.0000
+9.3000
+. . .
+29.1800
+_...
+19.8500
+11.2400
+42.2500
+6.9600
+MARKET
+VALUE
+19,200
+113,925
+29,180
+5,955
+17,984
+8,02
+105,444
+$865,833
+$865,833
+$13,358
+$9,693,777
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22,2002
+ESTIMATE
+INNUAL INCOM
+CURRENT
+YELD IN
+... . .
+.. . .
+••••••••••••••••••••••
+0.1779
+32 0.1779
+$1,078
+$1,078
+
+
+6 of 41
+Transaction Detail
+INVESTMENT ACTIVITY
+DATE
+02/25/02
+0225/02 02/20/02 "BOUGHT
+02/25/02
+"BÖUGHT
+02/25/02 02/20/02
+02/25/02
+BOUGHI
+ö2/26/02
+''''02721/02 "BOUGHT
+02/26/02 02/21/02 BOUGHT
+KENNETH COLE PRODUCTIONS ING
+78,00
+"CIRCUIT CITY STORES INC"
+COMMISSION
+18,00
+AS OF 02/20102
+SWISS ING-CLA
+EXECUTION BY VIKCO
+VS 300 02-20-02
+AS OF 02/20/02
+"NAUTICA ENTERPRISES INC
+EXECUTION BY RSSF
+
+.05
+TOMMY HILFIGER CORP-ORD
+1S 700 02 20-0204
+42,00
+AS OF 02/20102
+AMERICAN EAGLE OUTFITERS INC
+5000221-02
+"BEBE STORES ING
+EXECUTION BY RSS
+/S 300 02-21-02
+SYMBOLCUSIP
+KCP
+NAUT
+TOM
+"AEOS
+"BEBE
+027
+QUANTITY
+1,300
+18.09860
+300
+24:40000
+300
+200%
+700
+*300
+
+13.66000
+11.52490
+25.60750
+'21:50000
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+23,621.18
+7,353.00
+9,570.00
+2,716.95
+8,124.43
+25,622.50
+6,465.00
+
+
+7 of 41
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+02/26/02
+02/21/02
+62/26/02 02/2102**BOUGAT
+20192/20
+
+02/26/02
+02/21/02
+"SÖLD"
+New York. New York 10179
+02726/02 02/21/02 BOUGHT
+02727/02
+02/22/02
+02727/02
+02/22/02
+KENNETH COLE PRODUCTIONS ING
+NOISSINIO
+36,00
+24,00
+"NAUTICA ENTERPRISES INC
+EXECUTION BY JPHO
+VS 800 11-13-01
+SEC FEE
+17
+JC PENNEY CO INC
+SEE NOTE "S" ON BACK
+VS 1400 02-11-02
+COMMISSION
+SEC FEE
+84,00
+QUIKSILVER INC
+0 AS 02 21-02
+120,00
+"CIRCUIT CITY STORES INC
+RCUIT CITY GROL
+ECUTION BY BU
+VS 900 02-22-02
+COMMISSION
+54.00
+BRECUTON BY NET
+VS MMSS0222-02
+30.00
+SYMBOLCUSIP
+KCP
+NAUT
+JCP
+"LOK
+CC
+HOTT
+027
+QUANTITY
+600
+400°
+800
+1,400
+18.65120
+#29.75000***
+13.74590
+20.95290
+2,000*
+*900
+*1150850
+16.24670
+
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+11,241.72
+''11;939:00
+10,981.55
+29,234.61
+** 39,152.00
+1,691.0
+20,011.70
+
+
+8 of 41
+Transaction Detail (continued)
+SATE EMENT TATE
+DATE
+02/22/02
+0227702 02/22/02 SOLD"
+02727/02
+
+
+02/25/02
+02/28/02
+02/25/02
+02728/02
+'02725/02
+02/28/02
+'''02725/02
+02/28/02
+02/25/02
+ESTEE LAUDER COMPANIES ING
+VS 600 02-12-02
+SEMMISSION
+26.00
+"NAUTICA ENTERPRISES INC
+SEE 920 20 12801
+''SKECHERS USA INC
+40 30530222-02
+78.00
+"COSTCO WHOLESALE CORP NEW
+S 50 02 25 02KC
+COLUMBIA SPORTSWEAR CO
+TS 180002-25020
+"CIRCUIT CITY STORES INC
+CIRCUIT CITY GROUP
+S 1000022502
+COMMISSION
+20,00
+DOLLAR GENERAL CORP*****
+VS 500 02-25-02
+DOMMISSION
+30.00
+"SKECHERS USA INC
+VS 700 02-25-02
+COMMISSION
+42,00
+SYMBOLCUSIP
+EL
+NAUT
+SKX®
+COST
+COLM
+DG
+*SKX
+027
+QUANTITY
+-600
+29.39540
+700
+1,300
+500°
+1,800
+700
+
+13.91690
+44.41000
+30.98500
+16.95000"
+*14.24510
+' 13.50000"
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22,2002
+DEBIT AMOUNT
+17,585.97
+*9,447.94
+18,184.97
+22,220.00
+55.788.00
+16,985.00
+7,167.55
+9,507.00
+
+
+9 of 41
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+02/28/02
+02/25/02
+62/28/02 02/25/02*"BOUGAT
+03/01/02 02/26/02 SOLD
+03/01/02
+02/26/02
+"SÖLD"
+03/01/02
+02/26/02
+ö3/0102
+02/28/02"
+03/01/02
+02/26/02
+03/01/02
+02/26/02
+TARGET CORP
+SEE NOTE "S' ON BACK
+VS 200 02-25-02
+COMMISSION
+12,00
+"TIX"COMPANIES ING NEW
+VS 500 02-25-02
+XECUTION BY JPHO
+'S 400 01-28-02
+SEC FEE
+,21
+GADZOOKS INC
+EXECUTION BY RHCO
+VS 300 08-27-01, 200 10-05-01
+i TOPIC IN
+ECUTION BY RS
+VS 300 02-08-02, 300 02-07-02
+LOWES COMPANIES INC
+XECUTION BY BUC
+S 400 02-26-02
+COMMISSION
+24.00
+NAUTICA ENTERPRISES N***
+EXECUTION BY JPHO
+SEC FE 11-28-01, 100 11-27-01
+SEC FEE
+"WAL-MART STORES INC"
+VS 500 02-26-02
+COMMISSION
+30,00
+SYMBOLCUSP
+TGT
+GADZ
+"HOTT
+LOW
+NAUT
+wMT
+027
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22,2002
+DEBIT AMOUNT
+8,885.00
+CRECIT AMOUNT
+' 17,210.00
+QUANTITY
+200
+44.29000
+*500
+￾''34:33000"
+40034.05800..
+500%
+15.96250
+-600
+22.15000
+*400
+46.39840
+600*
+# 13:73000
+500%
+'62. 10000"
+*13,607.99
+7,966.13
+13,274.80
+18,598.36
+8.222.87
+31,095.00
+
+
+10 of at
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+02/27102
+63/64/02 02/27/02**SOLB"
+
+ö3/04/02
+03/04/02 0227(02"
+
+AMERICAN EAGLE OUTFITERS ING
+NEW
+EXECUTION BY INET
+VS 900 02-27-02
+COMMISSION
+27.00
+HERES PLACE RETATE STORES
+SE E 1 2 02 20012902
+COACHN
+VS 300 02-05-02, 100 02-07-02
+COMMISSION
+SEC FEE
+- 21.00
+KENNETH COLE PRODUCTIONS ING"
+VS 500 02-27-02
+COMMISSION
+30.00
+EXECUTION BY SOCO
+EE FE 100501. 10006-29.01
+HOT TOPIC INC***
+EXECUTION BY RSSF
+VS 600 02-07-02
+SEC FEE
+,20
+LIZ CLAIBORNE INC
+VS 400 12-05-01, 600 12-19-01
+COMMISSION
+SEC FEE
+- 45.00
+SYMBOLCUSIP
+AEOS
+"PLCE"
+KCP
+"GADZ"
+HOTT
+LIZ
+027
+QUANTITY
+900
+300
+400%
+500°
+300*
+600*
+24.75000
+''34:24500"
+49.55000
+18.21170
+= 7:57500
+22.14170
+9.9333
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+22,317.00
+*10,258.34
+9,780.7
+9,150.85
+5, 257:42
+13,269.82
+29,857.85
+
+
+11 of 41
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+03/0402 02/27/02 "BOUGHT"
+
+03/05/02
+02/28/02
+03705/02
+®02/28/02
+OFFICE DEPOT INC
+WITH RIGHTS TO PURCHASE PREFRD
+K UNDER CERTAIN CIRCUMSTANO
+ECUTION BY BU
+00000227-02
+36.00
+"PACIFIC SUNWEAR OF CALIFORNIA"
+ECUTION BY RS:
+: 1200 02-27-
+AS OF 02/27/02
+"QUIKSILVER INC
+24.00
+"WET SEALING-CLA
+EXECUTION BY SLKC
+VS 600 01-10-02
+SEC FEE
+WOLVERINE WORLD WIDE INC
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+VSMMIS38027-02
+42,00
+CHICOS FAS INC
+3300022400K
+COMMISSION
+18.00
+.21
+AS OF 02/28/02
+SYMBOLGUSIP
+ODP
+"PSUN"
+ZaK
+"WISLA
+www
+CHS
+HOTT
+027
+QUANTITY
+600
+19.25000
+1,200
+400°
+600
+700
+*300
+600*
+2436800"
+18.73500
+"32.14000
+16.01730
+*''34-12680
+•'2286500
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22,2002
+DEBIT AMOUNT
+11,601.00
+' 29,256.60
+7,533.00
+19,268.71
+11,269.11
+10,271.04
+13,703.79
+
+
+12 or 41
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+03/05/02
+DATE
+02/28/02
+63/66702 03761702 "SOLB"
+20/90/E0
+03101/02
+ö3/06/02
+03/01/02
+"SÖLD"
+03/06/02
+03/01/02
+03/06/02283/01/02BOUGHT
+/ 03/01702 SOL
+03/06/02
+*03/01/02
+TARGET CORP
+SEE NOTE "S' ON BACK
+VS 300 02-28-02
+COMMISSION
+18,00
+"BEBE "STORES INC
+/S 300 02-21-02
+DOMMISSION
+SEC FEE
+19.00
+"BEST BUY COMPANY INC
+VS 200 03-01-02
+COMMISSION
+12,00
+NIL RENS PLACE RETAIL STORES"
+EXECUTION BY JPHO
+VS 600 01-29-02
+SEC FEE
+.32
+"CHICOS FAS INC"
+XECUTION BY BUO
+S 1200 03-01-0
+COMMISSION
+72,00
+BOLLAR GENERAL CORP... G
+S 800 03-01-02
+OMMISSIO
+48.00
+"HOT TOPIC INC***
+EXECUTION BY MONT
+SEC FE 02-07-02, 60002-15-02
+"SHARPER IMAGE CORP
+EXECUTION BY NITE
+SS FO 12-27-01, 20012-24-01
+SEC FEE
+SYMBOLICUSIP
+TGT
+"BEBE
+*BBY
+PLCE
+CHS
+"HOTT
+"SHAP
+027
+QUANTITY
+300
+300
+002.
+-600
+1,200
+800
+-600
+43.02500
+*'23.92710"
+68.00000
+34.76500
+34.63430
+***14.20000*******
+*''23.28070
+'14.62000
+CLEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22,2002
+DEBIT AMOUNT
+12,940.50
+*7,154.02
+13,627.00
+89 EP8'OZ.
+41,648.16
+1,423.00
+23,265.35
+8,756.86
+
+
+13 o 41
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+03/06/02
+03/01/02
+63/66702 03761702 "SOLB"
+
+ö3/07/02
+"SÖLD"
+03/07/02
+0304/02
+03/07/02
+03/04/0
+03707/02
+TARGET CORP
+SEE NOTE "S' ON BACK
+VS 300 03-01-02
+COMMISSION
+TALBOT INC
+18,00
+500 1002, 150911802
+SEC FEE
+"WET SEAL INC-CLA
+EXECUTION BY MONT
+VS 600 01-10-02
+SEC FEE
+LORENS PLACE RETAIL STORES
+EXECUTION BY JPHO
+/S 700 01-29-02, 200 01-30-0
+SEC FEE
+VS 500 02-07-02, 100 12-04-01
+OMMISSIO
+SEC FE
+26.00
+"GYMBOREE CORP
+EXECUTION BY INET
+VS 600 02-04-02, 1000 02-06-02
+COMMISSION
+48,00
+SEC FEE
+,34
+HOT TOPIC INC****
+EXECUTION BY MONT
+SEC 002-15-02, 1700 02-06-02
+SYMBOLICUSIP
+TGT
+WISLA
+"PLCE
+"GYMB
+HOTT
+027
+QUANTITY
+300
+750
+600
+900°
+-600
+-7,600
+-1,900
+42.67710
+4071510"
+33.77500
+34.62080
+'51.90840
+13.89070
+'''23.29270
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+12,836.13
+'30,475.87
+20,249.69
+31,143.25
+31,093.57
+22,161.78
+44,240.46
+
+
+14 o141
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+03/07/02
+03/08/02 03/05/02 SOLD*
+20180/E0
+03/05/02
+03/05/02
+"BÖUGHT
+03/08/02 03/05/02*
+3/05/0
+03/05/02
+PACIFIC SUNWEAR OF CALIFORNIA
+EXECUTION BY INET
+20-10-50001S0
+12,00
+"AMERICAN EAGLE OUTFITERS INC
+NEW
+TS 140001-30-2, 100 01-28-02
+SEC FEE
+"ANNAYLOR STORES CORP
+SEE NOTE 'S' ON BACK
+EXECUTION BY GMO
+VS 300 03-05-02
+COMMISSION
+21.00
+"COSTCO WHOLESALE CORP NEW
+EXECUTION BY INET
+VS 300 03-05-02
+COMMISSION
+9.00
+COLUMBIA SPORTSWEAR CO
+EXECUTION BY SLKC
+SEC FE 12-19-01
+.40
+"COACH INC
+VS 200 12-04-01, 100 11-12-01
+COMMISSION
+18,00
+SEC FEE
+.22
+"CHICOS FAS INC
+VS 700 03-01-02
+COMMISSION
+SEC FEE
+12,00
+SYMBOLICUSIP
+PSUN
+"AEOS
+ANN
+"COST
+"COLM
+COH
+CHS
+027
+QUANTITY
+400
+1,500
+300°
+300
+800*
+300
+700°
+23.75000
+''25 21780
+39.81000
+
+
+47.80000
+35.20300
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22,2002
+DEBIT AMOUNT
+9,527.00
+37,811.13
+11,979.00
+11,708.88
+26,056.60
+14,306.78
+24,584.73
+
+
+15 of 41
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+DATE
+03/05/02
+63/08/02 03/05/02*"SOLD
+03/05/02
+03/05/02
+03/08/02 03/05/02* BOUGHT
+J90/E
+03/08/02 03/05/02 SOLD
+FOOTSTAR INC
+'S 200 01-15-02
+OMMISSION
+SEC FEE
+-02.00
+FEDERATE" DEPAHTMENT STOAES"
+28,00
+FOSSIL INC
+EXECUTION BY REDI
+VS 200 12-19-01, 300 12-31-01
+COMMISSION
+10,00
+.20
+"GADZOOKS INC
+EXECUTION BY RHCO
+SE 00 06-29-01
+13
+"HOT TOPIC INC
+EXECUTION BY INE
+51.00
+ESTEE LAUDER COMPANIES INC
+DEST L 0 02102
+SEC FISSION
+18.00
+.15
+"MASCO CORP"'***
+WITH RIGHTS TO PURCHASE PREFRO
+STK UNDER CERTAIN CIRCUMSTANCE
+VS 400 12-11-01
+COMMISSION
+SEC FEE
+21.00
+SYMBOLCUSP
+FTS
+FOSL
+"GADZ
+'HOI
+EL
+MAS
+027
+QUANTITY
+-200
+400
+-500*
+500
+'1,700**
+300
+400
+26.41380
+•42:34000"
+26.08980
+• 17.09500
+*228700
+31.19000
+- 28.31950
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+5,255.68
+'17,132.74
+13,019.70
+8.532.37
+** 13.973.90
+9,323.85
+11,288.63
+
+
+16 or a1
+Transaction Detail (continued)
+
+03/08/02 03/05/02 SOLD
+03105/02
+03/05/02
+03/08/02 03/05/02*
+03711.02
+03/06/02
+0371170203/06/02BOUGHT
+Bear, Steams & Co. Inc.
+PACIFIC SUNWEAR OF CALIFORNIA
+SKECHERS USA INC
+EXECUTION BY VECO
+0S MISSION -02, 100 70.23-02
+COMMISSION
+,25
+TUX COMPANIES ING NEW
+VS 100 11-13-01, 300 12-03-01
+COMMISSION
+SEC FEE
+21.00
+WAL-MART STORES INC
+EXECUTION BY GKMC
+VS 500 02-26-02
+COMMISSION
+SEC FEE
+15.00
+"ZALE COAP NEW"
+0SMMS52026-01, 100 12,0801
+COMMISSION
+SEC FEE
+,20
+AMERICAN EAGLE OUTFITTERS INC
+EXECUTION BY INET
+: 1200 03-06-0
+IMMISSIO
+36.00
+"ANNTAYLOR STORES CORP
+SEE NOTE "S' ON BACK
+EXECUTION BY LEHM
+VS 2800 03-06-02
+DOMMISSION
+196.00
+SYMBOL/GUSP
+PSUN
+*SEX
+WMT
+"ANN
+220
+QUANTITY
+800
+23.44250
+16.05290
+400
+-500*
+300
+2,800
+*37.01100
+61.25070
+:42.64100
+'25.58330
+40.36810
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+18,769.00
+15,967.65
+14,765.17
+30,574.89
+12,759.10
+30,750.96
+113,241.68
+
+
+17 of a1
+Transaction Detail (continued)
+DATE
+03/11/02
+03/06/02
+03/11/0203/06/02BÖÜGHT
+03/17702 03/08/02 "BOUGHT"
+
+BOUGHi
+03711/02
+03/06/02
+03717702 03/06/02"SOLD"
+03/17/02
+03/06/02
+63/11702
+03/06/02
+*SOLD"
+Bear, Steams & Co. Inc.
+BED BATH & BEYOND INC
+EXECUTION BY INET
+400006-02
+18,00
+COSTCO WHOLESALE CORP-NEW
+IS 700 05 06-92
+CHRISTOPHER & BANKS CORP
+EXECUTION BY INET
+COME 0206-02
+63.00
+"COACHING
+COMNIS906-02
+27.00
+IRCUT CITY STORES ING
+RCUIT CITY GROL
+VS 300 03-06-02
+COMMISSION
+18,00
+"FOOT LOCKER INC
+OMMISSIO
+"FEDERATED DEPARTMENT STORES
+INC-DEL
+VS 200 03-06-02
+COMMISSION
+12,00
+"GADZOOKS INC
+EXECUTION BY RHCO
+VS 300 06-29-01
+SEC FEE
+.08
+SYMBOLCUSIP
+BBBY
+COST
+COH
+FD
+"GADZ
+027
+QUANTITY
+600
+700
+2,100
+450
+300
+800
+200°
+300
+31.32660
+- 38.85000
+
+46.90000
+19.98000
+
+42.56000
+17.01000
+CLEARED THROUGH IT:
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+18,828.96
+27,210.00
+54,698.37
+24,147.00
+6,027.00
+13,809.19
+8,539.00
+5,087.92
+
+
+18 of 41
+Transaction Detail (continued)
+03/11/02
+
+03/11702 03/06/02 "BOUGHT
+03/11/02
+•*03/06/02
+
+*03/08/02
+03/11002 03/06/02*
+'' BOUGHT
+03/12/02
+03/07702
+03/12/02
+03/07/02
+BOUGH
+
+'''83/07/02"
+GENESCO INC
+WITH RIGHTS TO PURCHASE PREFRD
+K UNDER CERTAIN CIRCUMSTAN
+ECUTION BY BU
+00MMIS300-02
+54,00
+"GYMBOREE CORP"
+EXECUTION BY INET
+VS 600 03-06-02
+COMMISSION
+18,00
+'ESTEE LAUDER COMPANIES INC
+00M053021-02
+18.00
+"SYMBOL TECHNOLOGIES INC
+EXECUTION BY SBSH
+VS 900 03-06-02
+COMMISSION
+63.00
+"TIMBERLAND CO-CLA"
+48.00
+ALLOY INC
+......
+(FRM ALLOY ONLINE ING)
+EXECUTION BY NITE
+VS 1400 03-07-02
+BROWN SHOE COMPANY
+VS 700 03-07-02
+COMMISSION
+42,00
+"BEST BUY COMPANY INC
+VOMMIS5507-02
+48.00
+SYMBOLGUSIP
+GCO
+"GYMB
+"'SBL
+TBL
+ALOY
+BWS*
+"BBY
+027
+QUANTITY
+900
+600
+*300
+900°
+800°
+1,400
+700°
+800"
+24.65800
+
+30.95470
+• 10.89300
+*37:44260
+'73.30000
+18.57640
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22,2002
+DEBIT AMOUNT
+22,261.20
+7,380.12
+9,253.27
+9,881.70
+BO'LL0'OE....
+18,635.00
+13,060.48
+57,983.80
+
+
+19 or 41
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+03/12/02
+03/07/02
+03712/02 03/07/02"S0LD"
+03/12/02 03/07/02 BOUGHT
+03/12/02
+03/07/02
+*BOUGHT
+03/12/02
+''*03/07/02BÖÜGHT
+03/12/02 03/07/02
+'SOLD"
+03/12/0283/07/02 BOUGHT
+03/13/02
+'*03/08/02 SOLD
+CATO CORP CLA
+EXECUTION BY SLKC
+VS 1000 03-07-02
+"FOOT LOCKER "INE"
+EXECUTION BY RSSF
+VS 800 12-31-01
+COMMISSION
+SEC FEE
+56.00
+HOT TOPIC IN****
+EXECUTION BY INET
+VOMISS 007-02
+6.00
+LOWES COMPANIES INC
+VS 600 03-07-02
+COMMISSION
+36.00
+"STEVEN MADDEN LTD
+EXECUTION BY NITE
+VS 1200 03-07-02
+SHARPER IMAGE CORP
+EXECUTION BY NITE
+VS 600 12-24-01
+SEC FEE
+"14
+"TARGET CORP.
+SEE NOTE 'S' ON BACK
+VS 900 03-07-02
+SOMMISSION
+54.00
+BEST BUY COMPANY ING
+VS 300 01-07-02
+COMMISSION
+SEC FEE
+- 38,00
+SYMBOLCUSIP
+CACOA
+HOTT
+LOW
+SH00
+"SHAP
+*BBY
+027
+QUANTITY
+800
+200
+600
+1,200
+600"
+*900
+*300
+20.18500
+
+21.34000
+43.25910
+- 15.00000
+- 15.05850
+43.31000
+75.15570
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+20,200.00
+13,840.23
+"4.289.00
+26,006.46
+18,015.00
+39,048.00
+9,019.96
+22,51337
+
+
+20 or 41
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+03/13/02
+63/13/02 03/08/02*"SOLD
+ZOVEL/EO
+03708/02
+ZOVEL/EO
+03/13/02 03/08/02: BOUGHT
+03/13.02
+3/08/0
+03/13/02
+BOUGH
+CHICOS FAS INC
+/S 500 03-01-02, 300 02-28-0:
+DOMMISSION
+48,00
+SEC FEE
+.43
+FOOT LOCKER INC'**
+VS 1400 12-31-01, 200 10-12-01
+, 700 11-14-01
+SEC FESSION
+1538,00
+"GADZOOKS INC
+EXECUTION BY RHCO
+SEC FE 0629-01, 100007-0201
+KOHLS CORP'
+VS 20011-06-01
+COMMISSION
+SEC FEE
+22.00
+LOWES COMPANIES ING
+18.00
+NAUTICA ENTERPRISES INC
+SEE 1201. 00 10601
+OFFICE DEPOT INC
+WITH RIGHTS TO PURCHASE PREFRO
+STK UNDER CERTAIN CIRCUMSTANCE
+VS 300 03-08-02
+COMMISSION
+18,00
+SYMBOLCUSIP
+CHS
+"GADZ
+KSS*
+ODP
+027
+QUANTITY
+-800
+2,300
+35.49710
+' 17:66630
+1,400
+200
+'300
+-7,600
+300
+16.83940
+69.00000
+15.16750
+20.0500đ
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22,2002
+DEBIT AMOUNT
+28,334.25
+*40,478:88
+23,559.80
+13,772.79
+
+24,252.63
+6,048.00
+
+
+21 or 41
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+03/13/02
+63/13/02 03/08/02 SOLD
+03/13/02
+03/13/02
+03708/02
+03/13/02
+03/13/02 03/08/02"SOLD"
+03/14/02
+03/11702
+"BÖUGHT
+QUIKSILVER INC
+EXECUTION BY SIMM
+VS 700 02-21-02
+COMMISSION
+49,00
+SEC FEE
+,22
+"SKECHERS USAINC***
+CLA
+EXECUTION BY SIMM
+VS 400 01-23-02, 600 01-08-02
+200 01-10-02
+COMMISSION
+SEC FEE
+-34.00
+"STAGE STORES INC
+NEW
+EXECUTION BY INET
+VS 500 01-07-02
+OMMISSION
+25.00
+TIMBERLAND CO-CLA
+VS 700 03-08-02
+COMMISSION
+42,00
+BRECUTON BY SKE
+SEC 50 06-27-01, 450 12-03-01
+"ZALE CORP NEW"
+EXECUTION BY MDLD
+S 300 12-18-01, 300 12-12-01
+00 12-13-01, 300 12-14-0
+COMMISSION
+112,00
+SEC FEE
+CHILDRENS FLACE FRETAIL STORES"
+EXECUTION BY JPHO
+VS 300 03-11-02
+SYMBOLGUSIP
+ZOK
+*SKX
+*WTSLA
+027
+QUANTITY
+-700
+-1,200*
+500
+700
+-800
+-1,600
+300
+20.87380
+- 17:38630
+29.61260
+*38.09710
+32.76630
+40.84400
+*32.87500
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22,2002
+DEBIT AMOUNT
+14,547.44
+''20,764.24
+14,776.07
+26,724.97
+26,197.64
+65,222.41
+'9,877.50
+
+
+22 or 41
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+03/14/02
+03/11/02
+03/14/02 03/11/02 BOUGHT
+03/14/02 03/11/02
+03714/02 03/71/02"BOUGHT
+03/14702
+03/17702
+03/14/024
+
+'SOLD
+Bear, Steams & Co. Inc.
+03/14/02
+03/11/02
+BOUGH
+83795702 0372702BOUGHT
+800 03-11-0
+MMISSIO
+48,00
+FOOTSTAR ING*
+ECUTION BY BU
+: 500 03-11-0
+COMMISSION
+30,00
+"FOOT LOCKER ING
+VS 100 11-14-01, 600 01-03-02
+SEC FISSION
+LIZ CLAIBORNE INC
+VS 700 03-11-02
+COMMISSION
+42.00
+"LOWES COMPANIES INC
+(ECUTION BY BUC
+24.00
+TALBOTS INC
+EXECUTION BY GSCO
+VS 450 01-16-02, 300 02-04-02,
+400 02-05-02, 200 11-27-01, S
+00 11-28-01, 50 12-05-0
+SEC FESSION
+993.00
+TIMBERLAND CO-CLA
+CUTO BYGON
+OOMISSION -02
+63,00
+JONES APPAREL "GROUP'ING"
+05MMISS03 12-02
+60,00
+SYMBOLGUSIP
+COH
+PTS
+LOW
+UNY
+027
+QUANTITY
+800
+500
+700°
+700
+400
+-1,900
+900
+1,000*
+48.18830
+• 31.18360
+17:23370
+28:30000
+41.79800
+34.43430
+39.97630
+' 35.45300
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22,2002
+DEBIT AMOUNT
+38,613.64
+15,636.80
+"12,006.40
+19,867.00
+16,758.20
+65,276.18
+36,056.67
+35,528:00
+
+
+23 or al
+Transaction Detail (continued)
+03/15/02
+03712/02
+03/15/02 03/12/02 SOLD
+03/18/02 03/13/02 BOUGHT
+03/18/02 03/13/02 "SOLD
+03/18/02
+03/13/02
+20/8L/E0
+3/13/0
+03/19/02
+*03/14/02
+OFFICE SERVICING YOUR ACOUNT
+LIZ CLAIBORNE ING
+EXECUTION BY GSCO
+VOMMIS301-02
+21,00
+TALBOTS INC'***
+TS 700 12 05 BUCK
+OMMISSION
+EC FE
+CONG NG39.00
+VS 300 03-13-02
+COMMISSION
+18.00
+JONES APPAREL GROUP INC
+EXECUTION BY FCA
+/S 1000 03-12-0
+COMMISSION
+50.00
+AS OF 03/13/02
+"GUISILVER INC"
+EXECUTION BY RHCO
+VS 900 02-21-02
+COMMISSION
+SEC FEE
+83.00
+TOX COMPANIES ING NEW
+EXECUTION BY RHCO
+VS 500 12-03-01, 500 02-25-02
+COMMISSION
+70,00
+SEC FEE
+,58
+PRENCE STORES INC
+EXECUTION BY INET
+VS 500 01-07-02, 1300 01-02-02
+, 200 12-26-01
+SEC FEE
+80.00
+SYMBOLGUSP
+TIZ
+"COH
+SOLS
+027
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22,2002
+DEBIT AMOUNT
+8,520.00
+24,483.16
+QUANTITY
+300
+28.28000
+700°
+35.05790
+*300
+- 49.54260...
+-1,000
+35.90000
+900
+22.21810
+-7,000
+38.58900
+2,000
+27.79840
+14,895.78
+35,874.46
+19,917.99
+38,503.42
+55,520.96
+
+
+24 o141
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+03/19/02
+03/14/02
+63/20/02 03/15/02 *SOLD
+03/20/02
+03/15/02
+03/2002: *03/15/02**S0LB
+03/20/02"
+03/15/02
+03/20/02
+03/15/02
+SHARPER IMAGE CORP
+EXECUTION BY NITE
+400 12221010002123101.
+SEC FEE
+"AMERICAN EAGE OUTIES NEG
+EXECUTION BY JPHQ
+2, 1200 03-20-02, 1900 02-1-0
+2, 400 01-31-02
+SEC FEE
+2.45
+CHARMING SHOPPES ING
+EXECUTION BY NITE
+VS 1700 07-18-01, 1900 02-13-0
+SEC FEE
+41
+FOOT LOCKER INC
+EXECUTION BY RYAN
+VS 500 01-03-02, 2000 12-04-01
+, 400 10-26-01, 1100 01-04-02,
+3700 10-01-01, 600 01-15-02.
+600 10-05-01, 2500 01-22-02,
+00 02-08-02
+FOSSILING
+VS 1600 12XF.O1, 1200 01.040
+SEC FE 01-18-02, 1720021-13-01
+2.02
+GENESCONC****
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+IS 900 03-06-02, 300 01-30-02
+700 01-24-0
+COMMISSION
+114,00
+SYMBOLGUSIP
+SHAP
+"AEOS
+"CHAS
+FOSL
+"GCO
+027
+QUANTITY
+-2,200
+5,800
+3,600
+'11,500
+16.19360
+228:09680
+7.48150
+'16.72310
+5,000
+1,900
+26.88040
+27.15000
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22,2002
+DEBIT AMOUNT
+35,610.38
+'162,943.99
+26,917.99
+191,492.76
+134,384.98
+51,455.22
+
+
+25 or 41
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+03/20/02
+03/15/02
+03/20/02 03/15/02 SOLD
+03/20/02
+03/20/02
+*03/15/02
+03/21/02
+03718/02
+03721702"
+*03/18/02
+03/21/02 03/18/02
+GYMBOREE CORP
+EXECUTION BY FLT
+SS 00 03-06-02
+.12
+K-SWISS ING-CLA
+EXECUTION BY INET
+VS 300 02-20-02, 900 10-01-01
+COMMISSION
+NEW
+EXECUTION BY SBSH
+VS 900 12-26-01, 700 12-24-01,
+1400 12-21-01
+SEC FEE
+1,28
+WOLVERINE WORLD WIDE ING
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+VS 700 02-27-02, 400 02-13-02
+COMMISSION
+66.00
+SEC FEE
+AMERICAN EAGLE OUTFITERS INC
+EXECUTION BY JPHO
+1300 01-29-02, 1900 02-01
+1200 03-06-02, 1000 02-21
+SEС 00 01-31-02, 1930 02-04-02
+3.22
+JOSEPH A BANK CLOTHIERS INC
+EXECUTION BY JEFF
+SEC FEE 05-23-01, 30004-12-01
+SEC FEE
+"CHRISTOPHER & BANKS CORP
+EXECUTION BY FLIT
+VS 2100 03-06-02
+SEC FEE
+1.00
+SYMBOLCUSIP
+GYMB
+"SWS
+"STES
+www
+AEOS
+JOse
+027
+QUANTITY
+-600
+1,200
+12.96250
+• 39.16300
+3,000
+* 28.23500
+-1,100
+16.79740
+7,700
+27.84230
+-1,400
+2,100
+11.01000
+'31.55000
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+7,762.38
+46,943.89
+- 84,688.72
+18,395.86
+214,367.49
+15,398.76
+66,239.00
+
+
+26 or 41
+Transaction Detail (continued)
+03/21/02
+
+03/21/02 03/18/02 SOLD
+03/27702
+03/18/02
+03/21/02 03/18/02
+03/21102
+03718/02
+03/27/02 03/18/02 SOLD"
+KENNETH COLE PRODUCTIONS ING
+0-02-z00
+OMMISSIO
+SEC FEE
+633.00
+"FOOT LÖCKER INC
+EXECUTION BY WEDB
+VS 1000 02-08-02
+COMMISSION
+20.00
+GUITAR CENTER INC
+EXECUTION BY NITE
+VS 1400 11-14-01
+SEC FEE
+.34
+"LIZ CLAIBORNE ING
+VS 300 03-12-02, 700 03-11-02,
+SE 1S801. 1500 01-73.08
+174,00
+1.27
+....
+RESTORATION HARDWARE ING DE
+EXECUTION BY JPHO
+VS 200 12-19-01, 2700 12-14-01
+SEC FEE
+"TALBOTS ING*
+S 250 12-05-01, 1200 12-04-0
+500 12-17-01, 200 11-05-0
+50 10-29-01, 300 10-30-01
+COMMISSION
+150,00
+SEC FEE
+SYMBOLGUSIP
+KCP
+"GTAC
+OISH.
+027
+QUANTITY
+-1,900
+21.80000
+1,400
+2,900
+2,900
+-2,500
+=16.40000
+15.80400
+- 29.18850
+12.60750
+' 35.27570
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22,2002
+DEBIT AMOUNT
+41,271.37
+16,314.75
+'22,110.26
+84,456.38
+36,546.20
+88,022.92
+
+
+27 or 41
+Transaction Detail (continued)
+DATE
+03/21/02
+03/18/02
+03/21/02 03/18/02 SOLD
+03/22/02
+03/19/02
+03/22/02
+03/22/02
+03/25/02
+03/20/022
+03725/02 *83/20/02*SOLB
+TOMMY HILFIGER CORP-ORD
+. 200 02-1502, 22 02-21-3202
+0600 02:1902
+SEC FEE
+1,28,00
+WET SEAL INC-CLA
+EXECUTION BY MONT
+VS 350 12-03-01, 300 08-23-01,
+300 08-20-01, 450 07-19-01,
+00 07-24-01, 600 07-16-01, 201
+) 07-13-01
+EC FE
+2,20
+AMERICAN EAGLE OUTFITTERS INC
+NEW
+EXECUTION BY RSSF
+VS 200 02-04-02, 600 02-15-02
+SEC FEE
+"COSTCO WHOLESALE CORP-NEW
+TO: SAZ
+-2-USD
+COSTCO WHOLESAE
+CORP-NEW
+FROM: SZ
+•1-USD
+* JAL
+AMERICAN EAGLE OUTFITTERS INC
+EXECUTION BY JPHO
+VS 200 02-15-02, 500 02-07-02,
+350 12-13-01, 2000 12-17-01
+SEC FEE
+1,32
+"ALLOY'INC"
+(FRM ALLOY ONLINE INC)
+EXECUTION BY NITE
+VS 1400 03-07-02
+SEC FEE
+.29
+SYMBOL/GUSP
+TOM
+WISLA
+"AEOS
+*COST
+COST
+"ALOY
+027
+QUANTITY
+-5,800
+4,300
+14.79660
+''33.97500
+-800
+-3,500
+3,500
+3,050
+28.53330
+'28.63930
+7,400*
+''13.55000
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+85,455.99
+146,075.30
+22,811.29
+87,333.55
+18,35471
+
+
+28 or 41
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+03/25/02
+03/20/02
+03/25/02 03/20/02 SOLD"
+03/25/02
+03/20/02
+03/25/02
+''''03/20/02
+'''**SOLD
+03/25/02 03/20/02 SOLD
+03/25/02 03/20102*
+"SOLD*
+ANNTAYLOR STORES CORP
+SEE NOTE 'S' ON BACK
+EXECUTION BY MOKE
+VS 2800 03-06-02, 300 03-05-02
+SEC FESSION
+217,00
+2.03
+BROWN SHOE COMPANY"
+EXECUTION BY MOKE
+1000 1122-71. 3000111-001.
+400 08-27-01, 400 08-28-01, 13
+00 08-24-01
+COMMISSION
+301.00
+JOSEPH A BANK CLOTHIERS INC
+EXECUTION BY SLKC
+VS 1400 04-12-01, 1500 10-04-0
+COMMISSION
+145,00
+SEC FEE
+59
+BED BATH & BEYOND INC
+EXECUTION BY NITE
+VS 600 03-06-02
+SEC FEB
+.30
+"BEST BUY COMPANY INC
+EXECUTION BY GSCO
+800 03-07-02, 300 02-19-02. 2.
+0080, 20023000
+CHILDRENS PLACE RETAIL STORES
+EXECUTION BY JPHO
+VS 300 03-11-02, 300 01-30-02
+500 01-04-02, 500 01-07-02, 4
+09-02.02. 230022001: 3200
+SYMBOLICUSIP
+ANN
+*WS
+JOSE
+BBBY
+"BBY
+"PLE
+027
+QUANTITY
+-3,100
+4,300
+2,900
+-600
+2,000
+43.48110
+19.50590
+13.37980
+- 32.56050
+= 79.35000
+10,900
+'34-76230
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22,2002
+DEBIT AMOUNT
+134,557.38
+83,558.11
+8,640.8
+19,521.00
+158,542.61
+*378,888.38
+
+
+Bear, Stearns & Co. Inc.
+29 0141
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+03/25/02
+03/20/02
+03/25/02 03/20/02 SOLD
+COLUMBIA SPORTSWEAR CO
+EXECUTION BY FLTT
+SEC FE 12-19-01, 181.08-25-02
+XECUTION BY GSC
+'S 300 03-13-02, 800 03-11-0:
+03/25/02
+03/20/02
+03/25/02
+03/20/02
+03/25/02 03/20/02
+03/25/02
+'03/20/02
+•'''SOLD
+03725/02 *83/20/02*SOLB
+10-03-01
+CANDIES INC
+EXECUTION BY REDI
+VS 1420 02-15-02, 280 12-26-00
+COMMISSION
+34.00
+06
+"CATO COAP CL'A"
+EXECUTION BY SLKO
+VS 1000 03-07-02, 900 11-29-01
+SEC FEE
+KENNET COLE PRODUCTIONS INC
+ES 1UD0 1-0901, 600 02-08-02
+100 02-11-02
+519.00
+BIRECT FOCUS INC
+SE 0 2 0 01 00 02 102
+SEC FEE
+"BEE SHOPSINC
+ECUTION BY SL
+: 800 03-07-0
+SEC FEE
+.34
+SYMBOLGUSIP
+COLM
+*COH
+CAND
+"CACOA
+KCP*
+"BEBS
+027
+QUANTITY
+-2,100
+4,850
+33.34930
+•52.33410"
+1,700
+1,900
+-1,700*
+2.17330
+• 22.92000
+- 2053150*
+- 1,500%
+800
+35.18400
+•''27.52000
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22,2002
+DEBIT AMOUNT
+70,017.47
+253,462.08
+3,645.55
+43.532.34
+34,769.02
+52,760.20
+22,000.66
+
+
+30 of 41
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+03/25/02
+03/20/02
+63/25 02 03/20/02**SOLD
+03/25/02
+03/20/02
+03/25/02
+
+03/25/02 03/20/02 SOLD
+83/25/02 83720/02'SOB
+DOLLAR TREE STORES INC
+EXECUTION BY INET
+1 MMIS51031-02, 70° 00030-02
+DOMMISSION
+SEC FEE
+.52
+"BOLLAR GENEHAL CORP'***
+VS 1000 02-04-02, 500 02-25-02
+561,00
+FOOTSTAR INC
+EXECUTION BY MOKE
+COMMISSION -02, 18006100502
+161,00
+"FOOT LOCKER INC
+VS 900 02-08-02, 700 01-17-02,
+00 01-23-02, 1100 01-24-02
+00 09-18-01, 4100 01-29-0
+SEC PASSION
+468,00
+AMILY DOLLAR STORES IN
+ECUTION BY GS
+OMMISSIO
+9 MISS00-28-02, 30033,07-0
+"FEDERATED DEPARTMENT STORES
+INC-DEL
+EXECUTION BY FCAP
+VS 200 03-06-02, 700 12-12-01,
+1400 12-04-01, 400 12-11-01,
+0OMMS531001. 200 10.14500
+SYMBOLGUSIP
+DLTR
+"BG
+FTS
+FDO
+027
+QUANTITY
+-1,000
+2,300
+2,300
+7,800
+34.13090
+''' 17:05950"
+30.85000
+16.94330
+-1,900
+• 33.73000
+3,500
+*42.78000"
+CLEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22,2002
+DEBIT AMOUNT
+34,085.38
+''39,060.26
+70,777.93
+131,672.75
+"63,938.03
+*149,787.75
+
+
+31 or 41
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+03/25/02
+03/20/02
+63/2502 03/20/02 *"SOLD
+03/25/02 03/20/02 SOLD
+03/25/02 03/20/02
+'SOLD
+03/25/02
+:*03/20/02
+03/25/02
+ö3/25/02
+*03/20/02
+*03/20/02
+"SOLB"
+SÖLD*
+SÖL®
+GUITAR CENTER INC
+EXECUTION BY FLTT
+1. 200 120301. 70000-22-310
+SEC FEE
+"GARY' SPORTS CO"
+EXECUTION BY FLIT
+SEC FEE 01-1-02, 30001-3-02
+"GALYANS TRADING INC
+EXECUTION BY NITE
+VS 1100 01-23-02
+SEC FEE
+.25
+"HOT TOPIC INC***
+EXECUTION BY RSSF
+VS 3000 02-06-02, 1000 02-22-0
+2, 200 03-07-02, 1200 11-12-01
+1425 11-26-01, 1600 02-06-02
+, 1050 10-25-01, 450 11-05-01,
+450 11-06-01
+"HOME DEPOT ING"
+EXECUTION BY FCAP
+VS 700 01-24-02, 300 01-25-02
+COMMISSION
+70,00
+SEC FEE
+74
+K-SWISS ING-CLA
+VS 1100 10-01-01, 500 10-02-01
+SEC FEE
+KOHLS CORP"
+EXECUTION BY FCAP
+VS 1100 11-06-01, 450 11-05-01
+COMMISSION
+108.50
+SEC FEE
+1.64
+SYMBOLCUSIP
+GIRC
+"GATS
+"GLYN**********
+"HOTT
+KSWS
+KSS
+027
+QUANTITY
+-3,400
+16.48880
+:1,400°
+•':3:18000°
+1,100
+- 14.62700........
+-10,375
+22.58460
+EARED THAOUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocktyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOO February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+56,046.07
+*43,636:34
+16,074.45
+234,296.71
+-1,000
+1,600
+1,550
+-130000
+*41.07020"
+"70.35000
+49,214.26
+65,696.33
+108,917.56
+
+
+32 or 41
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+03/25/02
+03/20/02
+Bear, Steams & Co. Inc.
+03/25/02 03/20/02 SOLD
+03/25/02
+03/20/02
+03/25/02
+03/20/02
+037250203/20/02'SOLD
+LIZ CLAIBORNE INC
+- 500 10-10-01, 2600 1 10-811
+00 2201 00 23101 10
+"LOWES COMPANIES INC
+VS 400 02 26 02, 300 03-08-02,
+200 03-07-02
+COMMISSION
+SEC FEE
+-63.00
+STEVEN MADDENLTD
+EXECUTION BY JEFF
+VS 400 12-04-00, 500 02-02-01,
+700 02-07-02, 1400 02-08-02.
+700 06-19-01, 1900 02-11-02,
+00 01-30-02, 1000 01-29-02,
+00 03-07-02, 700 01-16-0
+10
+"MAXWELL" SHOECO INCOLA
+EXECUTION BY FLIT
+1 0 20 00 23201
+SEC FEB
+"POLO RALPH LAUREN CORP-CLA
+8801-69. 0 0-1601.
+1000 07-1-01. 900 07-20-01; 8
+00 07-06-01, 900 07-19-01, 500
+SIZBOUCUSP
+LOW
+SHOO
+MAXS
+''AL
+027
+QUANTITY
+-8,700
+-900
+29.78250
+- 43.80000
+10,100
+16.91280
+3,700
+15.95000
+6,900
+-29.46260
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+258,566.86
+39,341.40
+170,801.71
+58,999.11
+202, 859.89
+VS5S
+
+
+33 or 41
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+03/25/02
+03/20/02
+Bear, Steams & Co. Inc.
+03/25/02 03/20/02 SOLD
+03/25/02
+03/20702
+03/25/02
+n''032002
+03/25/02
+03/20/02
+03/25/02 03/20/02 SOLD"
+03725/02 *83/20/02*SOLB
+PACIFIC SUNWEAR OF CALIFORNIA
+ECUTION BY ASS
+S 1200 02-27-02, 400 03-04-0
+- 300 02-1502, 5200219022.
+800 12-19-01
+"PAXAR "CORP*
+TS 3000201-02, 500 01-21402.
+1000 01-23-02
+COMMISSION
+SEC FEE
+126.00
+QUIKSILVER INC
+RESTORATION HARDWARE ING DEL
+EXECUTION BY JEFF
+VS 1600 12-14-01, 3000 12-07-0
+SEC FEE
+SKECHERS USA INC
+200 2301. 30 02 08 9201
+COMMISSION
+348,00
+RENE STORES INC
+SEE 1280 30 120501
+SEC FEE
+"SHOE CARNIVAL INCIND"
+ECUTION BY FL
+5 2500 12-08-00, 2900 11-30
+SEC FEE
+1,21
+SYMBOLICUSIP
+PSUN
+PXR
+*ZOK
+"RSTO
+SKX
+027
+QUANTITY
+-5,900
+1,800
+12,800
+4,600
+-5,800
+26.03470
+16.40320
+24.21900
+
+16.62670
+1,700
+5,400
+'''25.09000
+• 1490000"
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22,2002
+DEBIT AMOUNT
+153,587.42
+29,384.31
+309,215.54
+"54,500.16
+96.070.41
+42,637.36
+*80,443.79
+
+
+34 or 41
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+03/25/02
+03/20/02
+03/25/02 03/20/02 SOLD"
+03/25/02
+03/20/02
+03/25/02
+03/20102
+'''SOLD
+03/25/02
+*03/20/02
+03/2502
+
+SYMBOL TECHNOLOGIES INC
+EXECUTION BY MOKE
+S0003-0-321, 1200 02-15-02
+SEC FISSION
+175,00
+"TARGET CORP"***
+SEE NOTE 'S' ON BACK
+EXECUTION BY DAE
+/S 200 02-25-02, 900 03-07-02
+400 02-07-02, 300 02-28-02, 3
+00 03-01-02, 600 01-30-02
+COMMISSION
+189,00
+TANGER FACTORY OUTLET CENTERS
+VS 80001-17-02, 90001-15-02
+COMMISSION
+SEC FEE
+.69
+"TIMBERLAND CO-CLA
+VS 3150 01-02-02, 800 03-06-02
+, 700 03-08-02
+COMMISSION
+SEC FEE
+2275,00
+OMMY HILFIGER CORP-OF
+ECUTION BY BUY
+SE RESEN
+WET SEAL INC-CLA
+XECUTION BY MON
+'S 700 08-02-01, 1000 08-03-0
+SEC FEE
+.86
+SYMBOLGUSIP
+SBL
+TGT
+SKT
+TBL
+TOM
+WISLA
+027
+QUANTITY
+-2,500
+2,700
+-1,700
+11.32830
+'44:35000"
+26.70560
+4,650
+• 39.39970
+5,800
+14.38180
+1,700
+'33.67330
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+28,130.32
+EB LBZ ST
+119,539.20
+182,911.86
+83,050.18
+57,228.75
+VS5S
+
+
+35 of 41
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+03/25/02
+03/20/02
+63/26/02 03/21702 SOLD
+03/26/02
+
+20/92/50
+03/21/02
+03/26/02
+20/9Z/E0
+03/26/02
+03/21/02
+03/21/02
+03/21/022
+ZALE CORP NEW
+EXECUTION BY DBAB
+/S 500 12-14-01
+DOMMISSION
+SEC FEE
+35.00
+"BROWN"SHBE COMPANY"
+501 30 02 10 0 201
+132,00
+"CANDIES INC
+EXECUTION BY REDI
+COMMISSION
+SEC FEE
+- 50.00
+"KENNETH COLE PRODUCTIONS ING"
+VS 500 02-20-02, 1500 02-11-02
+OMMISSIO
+120,00
+EC FE
+.62
+CIRCUIT CITY STORES INC
+CIRCUIT CITY GROUP
+INSOLICITE
+SP 2/22/0
+CIRCUIT CITY STORES INC
+CIRCUIT CITY GROUP
+UNSOLICITED
+VSP 2/25/02
+DEB SHOPSING**
+EXECUTION BY FLTT
+VS 700 11-14-01, 600 12-05-01,
+SEC F1-06-01
+.57
+SYMBOLCUSIP
+"EWS
+"CAND
+KCP
+027
+QUANTITY
+-500
+2,200
+2,500
+2,000
+40.52390
+2.17000
+20.63420
+-900
+1,400
+18.66000
+18.66000
+''27:14200
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+20,211.64
+*42,642.13
+5,359.91
+41,132.78
+16,730.74
+18,589.72
+37,983.23
+
+
+BEARR
+36 of 41
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+03/26/02
+03/21/02
+03726/02 03/21/02*S0LB
+03/26/02 03/21/02 "SOLB"
+20193/E0
+'*03/21702
+''SÖLD
+Bear, Stearns & Co. Inc.
+03/26/02
+03/21/02
+03/26/02
+13/21/0
+20/92/60
+03/21/02
+*SÖLÖ
+"SOLB
+LIZ CLAIBORNE INC
+EXECUTION BY OPCO
+S 2900 12-31-0
+OMMISSION
+203,00
+SEC FEE
+1,27
+LOWES COMPANIES INC"
+UNSOLICITED
+STEVEN MADDEN LTD
+EXECUTION BY NITE
+VS 500 01-24-02, 800 01-28-02,
+SEC F01-17-02, 400 09-10-01
+POLO RALPH LAUREN CORP-CL'A
+SEE NOTE 'S' ON BACK
+EXECUTION BY OPOO
+SEC FEE
+"OFFICE DEPOT INC"
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+UNSOLICITED
+VSP 2/13/02
+"OFFICE DEPOT INC"
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+UNSOLICITED
+VSP 2/27/02
+"OFFICE DEPOT INC"
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+UNSOLICITED
+VSP 2/13/02
+SYMBOLCUSIP
+TIZ
+LÖW
+SH00"
+ODP
+*ODP
+*OBP
+027
+QUANTITY
+-2,900
+:800
+3,700
+2,900
+400
+600*
+B00*
+29.04730
+*''44:83000
+16.75230
+''29 14300
+19.72000
+'19.72000"
+•'19.72000
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+DEBIT AMOUNT
+February 22,2002
+84,017.90
+'35,807.46
+61,967.58
+84,295.43
+*7,859.88
+11,789.82
+15,719.76
+
+
+37 or 41
+Transaction Detail (continued)
+SETLEMENT TATE
+DATE
+03/26/02
+03/21/02
+03/26/02 03/21/02 SOLD
+03/26/02
+03/21702
+03/26/02
+''''03/21/02
+*''*SOLD
+SKECHERS USA INC
+8001 02 0 0 02
+0 02-04-02, 1400 02-05-0
+00 02-11-02, 300 12-26-01,
+300 02-22-02, 700 02-06-02
+STAGE STORES INC
+EXECUTION BY INET
+VS 1000 12-21-01, 500 12-05-01
+COMMISSION
+45.00
+SEC FEE
+.58
+SHOE CARNIVAL INC-IND
+EXECUTION BY REDI
+VS 1000 11-28-00, 800 11-16-00
+700 11-30-0
+OMMISSIO
+SEC FEE
+-50.00
+TROPICAL SPORTWEAR
+INTERNATIONAL CORP
+EXECUTION BY REDI
+VS 500 02-11-02, 1300 01-30-02
+COMMISSION
+SEC FEE
+03/26/02"
+03/21/02
+300 01 0 1 0201
+234.50
+03/26/02
+03/21702
+WET SEALING-CLA
+EXECUTION BY MONT
+VS 1150 07-13-01, 500 07-26-01
+, 500 08-09-01, 2100 07-12-01
+500 08-03-01
+SEC FEE
+2,38
+SYMBOLGUSIP
+SKX
+'STGS
+TSIC
+TOM
+WISLA
+027
+QUANTITY
+-8,800
+1,500
+2,500
+1,800
+15.99900
+''25.54500
+14.97590
+• 23.56060
+3,350
+14.36200
+4,750
+
+EARED THROUGH I
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22,2002
+DEBIT AMOUNT
+140,158.08
+38,256.92
+37,374.18
+42,357.44
+47,862.47
+158,019.87
+
+
+38 of 41
+Transaction Detail (continued)
+DATE
+03/26/02
+03/21/02
+Bear, Steams & Co. Inc.
+03/27/02 03/22/02 SOLD
+ö3/27/02
+03/22/02
+03/27/02
+03/22/02
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MONDAY
+TRANSACTKN
+02/23/02
+02/2502
+02/2802 SOLD
+ESCRIPTION
+COSTCO WHOLESALE CORP-NEW
+EXECUTION BY MONT
+700 10-18-01. 300 12 10-01, 6
+00 12-12-01, 300 03-05-02, 700
+03-06-02
+SEC FEE
+"DEB SHOPSING**
+SF70011-8Y 01. 900 03-07-01
+SEC FEE
+LIZ CLAIBORNE INC
+VS 600 01-17-02, 1400 12-31-01
+COMMISSION
+120,00
+SEC FEE
+.85
+....
+POLO RALPH LAUREN CORP-CLA
+SEE NOTE 'S' ON BACK
+VS 150 04-20-01, 400 02-05-02,
+30.00 10202: 50
+OPENINGBALANCE
+"DOMESTIC PRIME MA PORTFOLIO
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+143,420.19
+SYMBOLCUSIP
+COST
+DEBS
+RL
+QUANTITY
+-3,500
+1,600
+2,000
+2,700
+40.98210
+26.63000
+28.32880
+28.50420
+42,592.36
+56,521.75
+76,783.18
+$-1,457,183.18
+SYMBOUCUSIP
+"GTOXX
+QUANTITY
+1,107,808.40
+50,000
+200,000
+027
+0000
+0000
+DEBIT AMOUNT
+$8.644,609.56
+50,000.00
+200,000.00
+
+
+39 or 41
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+03/01/02 DIVIDEND
+03/05/02 "BOUGHT
+03/05/02 JOURNAL
+83/65/02**JOUANAL
+03/07/02
+DIVIDEND
+03/11/02
+03/12/02
+03/14/02
+03/21/02
+BOUG
+BOUGH
+DIVIDEND
+03/21/02
+DIVIDEND
+03/21/02 REINVEST
+DIVIDEND
+DOMEST PATERS MPDATFOUO
+FAL: 5/2
+-2-USD
+DOMESTIC PRIME MI
+TO: SJZ
+1-USD
+* JRL *
+DIVIDEND CLOSEOUT
+DOES SALESM PORTFOLIO
+MONTHLY DIVIDEND
+DOMEST PAINE AM PORTFOLIO
+MONTHLY DIVIDEND
+DOMEST FRE PORT OLD
+MONTHLY DIVIDEND REINVESTED
+SYMBOUCUSIP
+'''GOXX"
+"GDXX
+"GTDXX
+"GIDXX
+QUANTITY
+00,000
+1,114.34
+1,11434
+100,000
+200,000
+100,000
+50,000
+50,000
+67.72
+027
+.0000
+1.0000
+1.0000
+1.0000"
+10000*
+1.0000"
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+14.52
+100,000.00
+100,000.00
+200,000.00
+7.18
+100,000.00
+1000.0
+50,000.00
+67.72
+836.75
+'67.72
+
+
+40 or 41
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+03/21/02
+REINVEST
+.......
+03/28/02
+TOTAL
+DOMESTE SHREE PRANSLO
+MONTHLY DIVIDEND REINVESTED
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+02/28/02
+TUX COMPANIES ING NEW
+REC 02/07/02 PAY 02/28/02
+03/11902 "LI2 "CLAIBORNE INC*****
+03/11/02
+REC 02/19/02 PAY 03/11/02
+TARGET CORP*"
+REC 02/20/02 PAY 03/10/02
+13/25/02 "CATO CORP CLA.'
+IEC 03/11/02 PAY 03/25/0:
+03/25/022
+REC 03/11/02 PAY 03/25/02
+03/28/02 HOME DEPOT INC......
+HOME DEPOT INC
+REC 03/14/02 PAY 03/28/02
+TOTAL
+Bear, Stearns & Co. Inc.
+SYMBOUCUSIP
+GTDXX
+QUANTITY
+836.75
+858,712.87
+SYMBOUCUSIP
+TUX
+LIZ
+* CACOA
+QUANTITY
+RATE (SI
+900
+0.0450
+16,500
+'0.0562
+0.0600
+900•• 01350
+5,100
+0.0800
+0.0500
+027
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+836.75
+$-300.904.47
+$550,926.17
+DEEIT AMOUNT
+40.50
+928.13
+60.00
+- 121.50
+408.00
+50.00
+$1,608.13
+
+
+41 or 41
+Transaction Detail (continued)
+INTEREST
+DATE
+03/21/02
+INT CR
+TOTAL
+MAR 02
+MISCELLANEOUS
+DATE
+MODAY
+03/05/02
+03/05/02
+"JOUANAL
+03725/02
+• OURNAL
+03/25/02
+OURNAL
+TOTAL
+FROM: SIZ
+• JRL
+*TO: SJZ
+* JRL *
+* JAL
+TO: SJZ
+* JRL *
+OFFICE SERVICING YOUR ACOUNT
+SYMBOUCUSIP
+12-USD
+FUSD™
+12:USD*
+-USD
+STOP
+****** End of Statement******
+QUANTITY
+RATE (SI
+DEBIT AMOUNT
+625.23
+144.007.55
+$-144,632.78
+027
+DEBIT AMOUNT
+CRECIT AMOUNT
+625.23
+144,007.55
+$144,632.78
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 22, 2002
+587.36
+$587.36
+
+
+lear, Steams & Co. In
+83 Madison AvenL
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+What's In This Statement
+Financial Summary ••••••••••...•..................
+Your Portfolio Holdings
+Transaction Detail ...........
+Fund Activity.......
+Trades Not Yet Settled
+4
+8
+28
+31
+INTERNATIONAL CHARITABLE
+INTERESTS I| 8-30-94
+C/O FINANCIAL TRUST COMPANY *
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+Market Value of Your Portfolio
+$1,637,396
+$2,220,577
+7,366,544
+529,588
+1,107,808
+$9,003,940
+8,894,740
+109,200
+Cash & Equivalent
+Equities
+| $7,366,544
+$6,674,163
+Current market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account
+SP This satement stori for ratanal for our recorde, Set reverse das a a doctant intormation.
+
+
+2 of 32
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 of 32
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Money Fund
+Miscellaneous
+Amount Debited.
+Net Cash Activity
+Closing Balance
+THIS PERIOD
+5604-250.11
+1,387,852.33
+611,481.33
+2,041.73
+2,078.46
+$2,003,453.85
+-1,974,521.02
+-101,481.33
+-2,113.46
+.. . .
+S2.078.115.81
+-74,661.96
+3529.586.15
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+2,897.83
+625.23
+33.523,06
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+603,557.29
+692.82
+$604,250.11
+CLOSING
+528,962.92
+625.23
+$529,588.15
+........
+027
+YEAR TO DATE
+5,194.14
+1,318.05
+.....
+$6.512.19
+1,637,396
+7,366,544
+$9,003,940
+... .
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+19%
+Equities
+81%
+Unshaded portions denole debi balance and'or short
+from the absolute market value of your portolio.
+
+
+4 of 32
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+THE TREASURERS FUNDING
+DOMESTIC PRIME MAM PORTFOLIO.
+THE TREASURERS FUNDING
+DOMESTIC PRIME MIM PORTFOLIO
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AMERICAN EAGLE OUTFITTERS INC
+NEW
+BROWN SHOE COMPANI
+JOSEPHIA BANK CLOTHIERS INC
+BEST BUY COMPANY INC
+CHILDRENS PLACE RETAIL STORES
+INC
+COSTCO WHOLESALE CORP-NEW
+COLUMBIA SPORTSWEAR CO
+.....
+....
+CANDIES INC
+.........------
+CACHE INC NEW
+SYMBOLCUSIP
+GTOXX
+GTDXX
+QUANTITY
+1,106,694.06
+1,114.34
+1.0000
+1.0000
+SYMBOUOUSIP
+AEOS
+BWS
+JOSB
+BBY
+PLCE
+COST
+g/elel
+CAND
+•......
+CACH
+CASH
+CASH
+CASH
+......
+CASH
+CASH
+CASH
+CASH
+... ..
+CASH
+CASH
+CASH
+QUANTITY
+15,750
+5,800
+4,300
+1,300
+12,800
+2,500
+1,100
+......
+4,600
+... ..
+31,500
+1,420
+8,550
+MARKET
+VALUE
+529,588
+aaaaaaaaaaaaaaaa
+1,106,694
+1,114
+$1,637,396
+24.9000
+15.4000
+8.2500
+67.6100
+32.3800
+45.2300
+....
+30.5300
+44.7500
+......
+2.3000
+•••••••••••••••
+2.3000
+......
+5.2600
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+ESTIMATED
+ANNUAL INCOME
+16,600
+17
+.500
+.......
+1.5260
+$16,617
+MARKET
+VALUE
+392,175
+89,320
+35,475
+87,893
+414,464
+113,075
+33,583
+.. . .
+205,850
+.......
+72,450
+3,266
+....
+44,973
+ESTIMATED
+ANNUAL INCOME
+2,320
+CURRENT
+YIELD (%)
+2.5974
+027
+
+
+5 of 32
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+CATO CORP CLA
+CHARMING SHOPPES INC
+KENNETH COLE PRODUCTIONS INC
+CLA
+CIRCUIT CITY STORES INC
+CIRCUIT CITY GROUP
+DIRECT FOCUS INC
+DEB SHOPS INC
+DOLLAR
+TREE STORES INC
+DOLLAR GENERAL CORP
+FOOTSTAR INC
+FOOT LOCKER INC
+FAMILY DOLLAR STORES INC
+..........
+FEDERATED DEPARTMENT STORES
+INC-DEL
+FINLAY ENTERPRISES INC
+SYMBOLICUSIP
+CACOA
+CHRS
+KCP
+DEXI
+DEBS
+DLTR
+DG
+FTS
+FDO
+FD
+GADZOOKS INC
+GUITAR CENTER INC
+GART SPORTS CO
+GM APPAREL GROUP LID
+GALYANS TRADING INC
+GENESCO INC
+.....
+GYMBOREE CORP
+FNLY
+FOSL
+GADZ
+aaaaaaaai
+GTRC
+GRTS
+GIII
+GLYN
+GCO
+GYMB
+CASH
+.....
+CASH
+*----.
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+900
+3,600
+3,200
+1,200
+,500
+3,800
+2,000
+24,900
+1,900
+3,700
+10,300
+.......
+5,500
+3,000
+4,800
+1,400
+20,850
+1,100
+,600
+20.0500
+6.5900
+19.0000
+16.5500
+28.
+23.
+29
+38.3600
+10.7500
+.......... i
+24.7000
+15.6100
+16.5400
+24.5000
+7.8800
+12.0600
+24.7100
+13.7500
+MARKET
+VALUE
+18,045
+23,724
+60,800
+19,860
+43,065
+90,706
+29,250
+14,000
+52,660
+404.625
+62.624
+141,932
+110,725
+135,850
+46,830
+79,392
+34,300
+164.298
+13,266
+24,710
+22,000
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+ANNUAL INCOME
+486
+84
+1,140
+128
+494
+CURRENT
+YIELD (S
+2.6933
+aaaaaaaaaaaaaal
+.. . .
+0.4230
+1.2568
+0.9143
+0.7888
+
+
+6 of 32
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+HOT TOPIC INC
+HEARX LTD
+COM NEW
+I-MANY INC
+HEAD NI
+NY REGISTRY
+HOME DEPOT INC
+K-SWISS INC-CL A
+KOHLS CORP
+ESTEE LAUDER COMPANIES INC
+CLA
+.•••..
+LIZ CLAIBORNE INC
+STEVEN MADDEN LTD
+MAXWELL SHOE CO INC-CL A
+MASCO CORP
+NOVEL DENIM HOLDINGS LTD
+••••••••••••••••••••••••••••••••••••
+NAUTICA ENTERPRISES IN
+POLO RALPH LAUREN CORP.CL A
+OFFICE DEPOT INC
+PACIFIC SUNWEAR OF CALIFORNIA
+INC
+PAXAR CORP
+NEPENNEY COINC
+QUIKSILVER INC
+RESTORATION HARDWARE ING DEL
+SYMBOLCUSIP
+HOTT
+EAR
+IMNY
+HED
+HD
+KSWS
+KSS
+EL
+LIZ
+SHOO
+MAXS
+MAS
+NVLD
+NAUT
+RL
+ODP
+PSUN
+PXR
+ICP
+ZOK
+RSTO
+CASH
+.......
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+13,875
+10,300
+1,600
+5,000
+2,500
+1,750
+800
+16,500
+12,600
+4,900
+......
+400
+12,250
+•••••••••••
+3,900
+13,500
+1,200
+.....
+3,500
+1,800
+1,400
+12,000
+7,500
+20.8900
+1.0200
+5.9900
+....
+3.3600
+29.
+28.
+.....
+26.3300
+10.7300
+13.9000
+27.7000
+18.8500
+21.4400
+16.3000
+••••
+20.2800
+18.7400
+11.0000
+MARKET
+VALUE
+289,849
+10,506
+9,584
+.....
+16,800
+000
+84,438
+15,203
+23,992
+476.685
+188.874
+78,890
+....
+10,532
+131,443
+••••••••••••
+54,210
+373,950
+22,620
+75,040
+29,340
+28,392
+224,880
+82,500
+027
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+ANNUAL INCOME
+920
+200
+150*
+160
+3,713
+216
+CURRENT
+YIELD (S
+5.4762
+0.3922
+0.1776
+0.6669
+0.7789
+2.0509
+2.4655
+
+
+7 of32
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+SKECHERS USA INC
+CLA
+•..........
+TAGE STORES IN
+NEW
+SHARPER IMAGE CORP
+SHOE CARNIVAL INC-IND
+SYMBOL TECHNOLOGIES INC
+TROPICAL SPORTWEAR
+INTERNATIONAL CORP
+TARGET CORP
+TIX COMPANIES INC NEW
+banansalıaanaaaananaanannananaasııaanı
+TANGER FACTORY OUTLET CENTERS
+SYMBOLICUSIP
+SKX
+STGS
+SHRP
+SCVL
+SBL
+TSIC
+TGT
+SKT
+TALBOTS INC
+TIMBERLAND CO-CLA
+TOMMY HILFIGER CORP-ORD
+UNITED RETAIL GROUP INC
+WET SEAL INC-CLA
+VOLVERINE WORLD WIDE IN
+ZALE CORP NEW
+Total Equities& Options
+TOTAL EQUITIES
+TLB
+TBL
+URGI
+WTSLA
+www
+zLC
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+14,800
+8,700
+3,400
+7,900
+3,200
+1,800
+900
+.......
+1,700
+5,850
+. . . .
+3,150
+.. . .
+14,250
+15,150
+12,750
+400
+2,400
+13.6000
+26.9500
+13.7000
+15.7100
+7.4000
+21.0000
+44.3900
+35.7700
+3.490
+36.5800
+34.7600
+. . .
+12.5000
+8.1200
+30.2000
+16.0000
+42.5500
+MARKET
+VALLE
+201,280
+234,465
+46,580
+124,109
+23,680
+37,800
+44,390
+32,193
+39,933
+213,993
+109,494
+178,125
+123,018
+385,050
+6,400
+102,120
+$7,366,544
+$7,366,544
+027
+CLEARED THROUGH IT:
+HOLLY OWNED SUBSIDIAR'
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocktyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOO January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+ESTIMATE
+NNUAL INCON
+CURRENT
+YELD IN
+.. . .
+64
+0.2703
+240
+162
+4,148
+1,872
+0.5407
+0.5032
+10.3874
+0.8748
+1.1250
+$17,269
+$17,269
+
+
+8 of 32
+OFFICE SERVICING YOUR ACOUNT
+Bear, Steams & Co. Inc.
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SETLEMENT TRIES
+01/28/02 01/23/02 BOUGHT
+
+81728/02 01723/02
+*BOUGHT
+01/28/02
+
+AMERICAN EAGLE OUTFITTERS INC
+NEW
+EXECUTION BY RSS
+/S 1000 01-23-0
+'BLEWATER CREEKING"
+EXECUTION BY JEFF
+VS 500 12-03-01, 100 11-28-01
+SEC FEE
+"FOOT LOCKER ING"
+EXECUTION BY MONT
+VS 700 01-23-02
+DOMMISSION
+49,00
+"GERBER CHILDRENSWEAR INC
+VS 3300 12-08-99
+COMMISSION
+165.00
+$33,886
+$9,003,940
+SYMBOLGUSIP
+AEOS
+'EWA
+QUANTITY
+'800
+700
+3,300
+27.86500
+• 1676308°
+
+6.50000
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+27,880.00
+18,042.64
+10,236.19
+21,269.67
+
+
+9 of 32
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+01/28/02
+01/23/02
+09728782 8123702 SOLB"
+01728/02 01/23/02 BOUGHT
+01728/02
+01723/02
+01/28/02
+
+*01/24/02
+61729/02
+21 8172402
+GALYANS TRADING ING
+EXECUTION BY SLKC
+VS 1100 01-23-02
+"HOT TOPIC IN'***
+WITH DUE BILL SPLT 3:2
+ECUTION BY MON
+S 1050 01-16-02, 200 01-15-0
+SEC FEE
+,64
+PAXAR CORP
+CS MMISS00-23-02
+60,00
+VS 500 01-23-02
+COMMISSION
+30.00
+"TOMMY HILFIGER CORP-ORD"
+ECUTION BY FCA
+: 150 08-07-01, 650 08-17-
+COMMISSION
+SEC FEE
+- 56.00
+FOOT LOCKER ING
+EXECUTION BY BUC
+OMMISSION
+66,00
+AS OF 01/24/02
+WITH RIGHTS TO PURCHASE PREFRD
+BE 001 A NI CROASTACE
+42,00
+SYMBOLCUSIP
+GLYN
+*PXR
+SKX
+"TOM
+027
+QUANTITY
+1,100
+-1,250
+13.22540
+
+*800
+1,100
+700
+15.02200
+''15.93380
+14.74840
+14.54820
+*23.98800
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+DEBIT AMOUNT
+14,562.94
+January 25, 2002
+42,352:24
+15,097.00
+8,011.90
+16.084.02
+16,848.60
+
+
+10 of 32
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+01/29/02
+01/24/02
+0172902 01/24/02 "BOUGHT
+01/2902
+*'*01724/02BÖUGHT
+01729/02 01724/02"SOLD
+01/29/02
+01/24/02
+01729/02"
+01724/02
+01/29/02
+101724(02
+HOT TOPIC INC
+5 01 02 0 1301.
+SEC 11-20-01
+1.03
+"HOME DEPOT INC
+
+42,00
+STEVEN MADDENLTD
+1S 80001-2482
+"PACIFIC SUNWEAR OF CALIFORNIA"
+EXECUTION BY RSSF
+SEC FE 1-03-02, 400 07-08-02
+AXAR COR
+ECUTION BY BU
+OSMMIS31024-02
+30.00
+"ROSS STORES ING
+570001-0802
+SEC FEE
+TOYS A USING .....*
+WITH RIGHTS TO PURCHASE COMMON
+STK UNDER CERTAIN CIRCUMSTANCE
+IS 1400 01-24-02
+OMMISSION
+84,00
+SYMBOLCUSIP
+HOTT
+"HD
+SHOO
+"PSUN
+*PXA
+ROST
+"TOY
+027
+QUANTITY
+-2,000
+34.25171
+700
+500
+500
+700°
+48.02000
+16.59000
+
+15.15460
+34.53670
+'18.92840
+02/2302;11:32 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+68,487.38
+''33,671.00
+8,310.00
+11,275.48
+7,622.30
+24,160.32
+26,598.76
+
+
+11 of 32
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+01/29/02
+01/24/02
+0173002 01/25/02 "BOUGHT
+' 01725/02
+"BÖUGHI
+01731/02
+01/28/02
+01731/02
+01/28/02
+01731/020728/02BOUGHT
+01731/02 01/28/02 SOLD*
+01731702 01728/02"OUGHT
+TOMMY HILFIGER CORP-ORD
+18 5501-81701. 1300 08-1601
+SONISSION
+114.00
+"HOME BEPOT INC
+VS 300 01-25-02
+COMMISSION
+18,00
+NORDSTROM INC"
+OS 1MSS00-25-02
+78.00
+ANNTAYLOR STORES CORP
+SEE NOTE "S" ON BACK
+VS 400 01-28-02
+COMMISSION
+24.00
+"CHILDRENS PLACE RETAIL'STORES
+EXECUTION BY JPHO
+VS 500 01-28-02
+FAMILY DOLLAR STORES IN*
+S 1600 01-28-0
+OMMISSIO
+96.00
+"FEDERATED DEPARTMENT STORES
+INC-DEL
+VS 400 12-31-01
+COMMISSION
+SEC FEE
+21.00
+*STEVEN MADDEN LTD
+XECUTION BY SLK
+/S 800 01-28-02
+SYMBOL/GUSP
+TOM
+PLCE
+•*••••••••••••'''*#DO
+027
+QUANTITY
+-1,900
+300
+1,300
+400°
+500
+14.90840
+47.15000
+24-67660
+00006LE.
+32.84880
+1,600***
+# 32.14000***•••*
+400
+*''41.21730"
+800"
+•15.98000
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+28,196.53
+• 14,178:00
+15,199.00
+16,439.40
+***** 51,535.00
+16,447.67
+12,799.00
+
+
+12 of 32
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+01/31/02
+01/28/02
+Bear, Steams & Co. Inc.
+01731/02 01/28/02 SOLD
+
+01729/02
+02/01702*01/2902*BOUGHT
+
+01/29/02
+
+:01/29/02BOUGHT
+0270170201729/02 BOUGHT
+TOYS A US INC
+: 1400 01-24-6
+IMMISSIO
+SEC FEE
+191.00
+"TOMMY HILFIGER CORP-ORD
+ES 1450 BY 801. 300 10-17-01
+, 350 10-26-01
+COMMISSION
+SEC FEE
+126.00
+AMERICAN EAGLE OUTFITTERS INC
+HELPENS PLACE REAL STORE"
+
+COMMISSION
+SEC FEE
+FOOT LOCKER ING
+SMS 028-02
+"HOT TOPIC INC'****
+WITH DUE BILL SPLT 3: 2
+EXECUTION BY MON
+VS 2500 01-29-02
+246.00
+TOM
+"AEOS
+"PLE
+COH
+"HOTT
+027
+JUANTIT
+1,40
+2,100
+1,400
+1,500
+700
+4,100
+2,500
+19.71970
+15.52510
+26.28500
+''32:6700
+46.10680
+13.63600
+31.30670
+02/23/02:11:32 001
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+27,508.16
+32,461.22
+36.814.00
+49,020.00
+32,217.27
+56,768.60
+"78,281.75
+
+
+13 of 32
+Transaction Detail (continued)
+DATE
+02/01/02
+01/29/02
+ö2/01/0201/29/02$ÖLD
+02/04/02
+01730/02
+"BÖUGHI
+02/04/02
+01/30/02
+ö2/04/02
+01/30/02
+02/04/0201/30/02BOUGH
+02/04/02
+'' 01730/02
+' BOUGHT
+02704702*81/3002
+Bear, Steams & Co. Inc.
+STEVEN MADDEN LTD
+EXECUTION BY INET
+: 1000 01-29-0
+IMMISSION
+30.00
+TOMMY HILFIGER CORP-ORD
+IS 5010-2601. 60 10-11-01.
+50 10-22-0
+OMMISSIO
+66.00
+"AMERICAN EAGLE OUTFITTERS INC
+NEW
+XECUTION BY JPH
+S 1900 01-30-0
+WE SHENS PLACE RETA STORES
+
+'S 300 12-11-01
+OMMISSIO
+SEC FEE
+24:00
+•DOLLAR TREE STORES..
+EXECUTION BY SSH
+VS 700 01-30-02
+"GART SPORTS CO"
+XECUTION BY NIT
+S 300 01-30-02
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIACUMSTANCE
+EXECUTION BY VKCO
+S 300 01-30-0:
+OMMISSIO
+21.00
+SYMBOL/CUSP
+SH0O
+TOM
+"AEOS
+PLCE
+COH
+GATS
+027
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+14,692.00
+16,608.05
+QUANTITY
+1,100
+1,900
+500°
+-300
+14.64700
+15.17210**
+26.50250
+32.20250
+44.82810
+50,369.75
+16,116.25
+'*700****••***32.59500**•**•••* 22,831.50
+*300
+• 20.38000
+6,129:00
+300*
+'*24:18008
+7288:00
+13,415.22
+
+
+14 of 32
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+02/04/02
+01/30/02
+02764702 "81730702"BOUGAT
+02/04/02 01730/02 SOLD
+02/04/02
+01730/02
+ö2/04/02
+01730/02
+Bear, Steams & Co. Inc.
+02/04/02 01730/02"SOLD
+027040201730/02 BOUGHT
+KOHLS CORP
+20-01-10 006 S/
+DOMMISSION
+SEC FEE
+'STEVEN MADDENLYD
+VS 1500 01-30-02
+COMMISSION
+29.00
+SE 20 0 2 00 2301
+QUIKSILVER INC"
+S 1500 01-30-0
+OMMISSIO
+90.00
+REEBOK INTERNATIONAL LTD
+WITH RIGHTS TO PURCHASE COMMON
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY BUCI
+VS 300 10-03-01
+COMMISSION
+SEC FEE
+18.00
+ROSS STORES INC
+EXECUTION BY GSCO
+VS 100 01-08-02, 200 01-08-02
+SE MISSION
+15,00
+.16
+"SKECHERS USAIING
+00MM51030-02
+54,00
+SYMBOLGUSIP
+KSS
+"3H00
+"BE***********''•
+*ZOK
+*ABK
+ROST
+QUANTITY
+-300
+63.83050
+1,500
+- 902286000
+1,500
+18.02950
+300°
+29.50500
+300°
+35. 28890
+*900
+15.12480
+027
+02/23/02:11:32 001
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+19,112.86
+•21,882.00
+*20,558.69
+27,149.25
+8,818.36
+10,556.51
+
+
+
+15 of 32
+Transaction Detail (continued)
+STENT TATE
+DATE
+02/04/02
+01/30/02
+ö204/0201/30/02"BÖÜGHT
+Bear, Steams & Co. Inc.
+02/04/02
+
+02/05/02
+01731/02
+02/05/02
+01731/02
+02705/02
+*01731702 SOLD"
+02/05/02
+'''01731702
+'SOLD"
+0265702 81739702'SOB
+TROPICAL SPORTWEAR
+INTERNATIONAL CORP
+"TARGET CORP***
+AVG PRICE SHOWN-DETAILS ON REQ
+"TOMMY HILFIGER CORP-ORD
+EXECUTION BY MSCO
+VS 2700 01-30-02
+COMMISSION
+189,00
+AMERICAN EAGLE OUTFITTERS INC
+S 00 01-31-02
+DOLLAR TREE STORES INC
+1S 30001-91-025
+NO DATED DEPARTMENT STORES"
+VS 200 12-31-01, 100 12-12-01
+COMMISSION
+SEC FEE
+118.00
+JONES APPAREL GROUP INC
+VS 400 12-11-01
+COMMISSION
+SEC FEE
+22.00
+R'SWISS INC:CLA
+EXECUTION BY VKCO
+VS 300 10-03-01
+SEC FEE
+.17
+SYMBOLCUSP
+TSIC
+TGT
+TOM"
+"AEOS
+BLTA
+FD
+'SWS
+027
+QUANTITY
+1,300
+600
+2,700
+2,000
+300
+*300
+400
+300
+20.50000
+• 41.45700
+12.25710
+25.48200
+33.12000
+41.20000
+*''33.10350
+• 3760000"
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+26,665.00
+24,916.20
+*33,298.17
+50,979.00
+9,951.00
+12,326.81
+13,202.20
+T,26483
+
+
+16 of 32
+Transaction Detail (continued)
+DATE
+02/05/02
+01/31/02
+02/06/02 02/01702BOÜGHT
+02/06/02
+02/01/02
+02/06/02 *02/01/02*SOLD
+......
+2/06/0
+2 02/01/02
+0206/02
+*02/01/02
+02708/02
+02/01/02
+500 11-13-0
+MMISSI
+SEC FEE
+35.00
+AMERICAN EAGLE OUTFITTERS INC
+NEW
+EXECUTION BY RSSE
+/S 1900 02-01-0
+ANNTAYLOR STORES CORP
+SEE NOTE "S' ON BACH
+VS 300 01-28-02
+COMMISSION
+SEC FEE
+118,00
+BOADERS GAOUP INC"*
+VS 750 01-08-02
+COMMISSION
+SEC FEE
+25.00
+"COLUMBIA SPORTSWEAR CO
+EXECUTION BY GSCO
+VS 300 01-04-02
+OMMISSION
+EC FE
+115.00
+"FOOTSTAR INC
+EXECUTION BY BUC
+/S 300 01-15-02
+COMMISSION
+SEC FEE
+118.00
+"FEDERATED DEPARTMENT STORES
+INC-DEL
+VS 200 12-12-01
+COMMISSION
+SEC FEE
+13.00
+SYMBOLGUSIP
+ABK
+AEOS
+ANN
+COLM
+FTS
+FD"
+027
+QUANTITY
+-500
+29.65000
+1,900
+300°
+750
+300
+300"
+200°
+
+37.98000
+**23:66110
+2.3253
+27.65930
+40.77130
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+14,774.77
+'49,219.30
+11,360.82
+*17,685.56
+9,667.44
+8,264.66
+8,127.13
+
+
+17 of 32
+Transaction Detail (continued)
+DATE
+02/06/02
+02/01/02
+02/06/02 0201/02$ÖLD
+0208/02
+'''02/01702"BÖUGHT
+02/06/02 02/01702"SOLD
+02107/02 02/04/02 BOUGHT
+02/07/02
+02/04/02
+''''SOLD
+02/07/02 02/04/02 BOUGHT
+FOSSIL INC
+EXECUTION BY JEFF
+SEC FE 12-19-01
+"PACIFIC SUNWEAR OF CALIFOANIA
+SEC FEE
+VS 300 02-01-02
+COMMISSION
+18,00
+"REEBOK INTERNATIONAL LTD
+VS 300 11-13-01
+COMMISSION
+18.00
+SEC FEE
+"AMERICAN EAGLE OUTHITTEAS INC
+NEW
+50002-04020
+AS OF 02/04/02
+COLUMBIA" SPORTSWEAR CO
+S 20012-19-050°
+AS OF 0204102
+.10
+"CHICOS FAS ING"
+15 160002-0-02
+AS OF 020A02
+96.00
+SYMBOLCUSP
+FOSL
+*PSUN
+*ABK
+"AEOS
+COLM
+'CHS
+027
+QUANTITY
+-300
+23.73400
+700
+•23.02600
+300
+16.50000
+-300
+• 29.50000
+5000**
+200
+1,600
+*216540
+31.48000
+• 30.09640
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+7,105.09
+16,102.95
+4,983.00
+8,816.86
+123,092.00
+6,280.90
+48,265.24
+
+
+18 of 32
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+02/07/02
+02/04/02
+626762 02/04/02**"SOLD"
+0207/02
+*02/04/02
+02/0702 02/04/02*BOUGHT
+
+02/04/02
+82787702'
+AS OF 02/04/02
+FEDERATED" DEPAHTMENT STOAES
+25.00
+AS OF 02/04/02
+GADZOOKS INC****
+SE00 2 34 00 05-1001
+SE OF 02/04102
+GUMBOREE CORP
+EXECUTION BY SBSH
+AS OF 02000022
+HOT TOPIC INC**
+ITH DUE BILL SPLT 3:
+CECION BY MON
+VS 2500 01-29-02, 100 11-20-01
+SE F0 1 1 2901
+2.07
+AS OF 02/04/02
+JONES APPAREL " GROUP INC"
+ECUTION BY BUC
+300 12-11-01, 400 01-02-
+SAS OF 0204102
+160.00
+SYMBOLCUSP
+DG
+"GADZ
+HOTT
+027
+QUANTITY
+400
+-600°
+600
+4,200
+16.46020
+4002750"
+14.25000
+• 13.80000
+32.74900
+:7,000
+*32.41300
+02/23/02:11:32 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+16,535.20
+*15,971.75
+8,534.87
+1'962
+137,528.73
+32,337.51
+
+
+19 of 32
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+02/07/02
+02/04/02
+626702 02/0402S0LВ"
+Bear, Stears & Co. Ine.
+0207/02
+02/04/02
+02/0702 *02/04/02**SOLD
+02/07/02
+02/04/02
+AS OF 02/04/02
+.18
+MAS88 384P...
+WITH RIGHTS TO PURCHASE PREFRD
+STE UNION BE BIAN CIRCUMSTANCE
+VS 300 12-11-01
+COMMISSION
+SEC FEE
+119,00
+NAUTICA ENTERPRISES INC
+EXECUTION BY RSSF
+SEC FEE 1-26-01
+.09
+AS OF 02/04/02
+I SUNWEAR OF CALORNIA
+SS OF 020402
+"SKECHERS USA INC
+
+''02/04/02
+"TALBOTS INC
+0020402CK
+AS OF 020A02
+36.00
+18.00
+SYMBOLCUSIP
+KSWS
+"MAS
+NAUT
+"PSUN"
+SKX
+027
+QUANTITY
+-300
+300
+400
+'1,700
+600
+300
+38.02000
+' 2679530"
+13.91000
+''**22.34700
+15.03490
+- 3527280
+02/23/02:11:32 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+11,390.82
+*8,005.46
+5,548.91
+27:97433
+9,071.94
+10,614.84
+
+
+20 of 32
+Transaction Detail (continued)
+DATE
+02/08/02
+02/05/02
+ö2/08/02 0205/02$ÖLD
+02/08/02"
+02/05/02
+02/08/02
+02/05/02
+SÖLD
+02/08/02
+02/05/02
+BOUGH
+20/80/20
+*02/05/02
+02708/02 02/05/02*BOUGHT
+Bear, Steams & Co. Inc.
+5 300 02-05-02
+OMMISSIO
+18,00
+HOT TOPIC ING****
+NITH DUE BILL SPLT 3:2
+EXECUTION BY MON
+УS0 11-0-01, 50 10-107 35.
+0 11-26-01
+SEC FEE
+1.11
+"POLO RALPH LAUREN CORP CLA
+COMMISSION
+24.00
+"PACIFIC SUNWEAR OF CALIFORNIA
+/SC FE 12-19-01
+QUIKSILVER INC
+VSMISS200502
+"SKECHERS USA INC
+: 1400 02-05-0
+IMMISSIO
+"TALBOTS INC
+VS 400 02-05-02
+COMMISSION
+.07
+24,00
+84,00
+24.00
+SYMBOL/CUSP
+COH
+"HOTT
+RL
+"PSUN
+*ZaK
+*SKX
+027
+QUANTITY
+300
+2,300
+400°
+200%
+400
+1,400
+*400
+43.95930
+31.93410
+25.99000
+• 21.58000
+17.13300
+14.68500"
+- 3463360"
+02/23/02:11:32 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+13,220.79
+73,432.32
+10,435.00
+4,300.93
+6,892.20
+20,658.00
+13.892.44
+
+
+21 of 32
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+02/11/02
+02/06/02
+62/11/02 02/06/02***BOUGAT
+02/11/02 02/06/02 BOUGHT.
+20/11/20
+02/06/02
+"BÖUGHT
+
+02/06/02
+BOUGH
+20/2/20
+''0220702
+02/12702 02/0702 SOLD
+GADZOOKS INC
+EXECUTION BY SLKO
+SE 0 05-10-01, 100 09-04-01
+AS OF 02/06/02
+GYMBOREE "CORP"*
+AS 0 0 0 0 2
+"HOT TOPIC ING****
+WITH DUE BILL SPLT 3: 2
+EXECUTION BY INE
+VS 2000 02-06-02
+COMMISSION
+60.00
+AS OF 02/06/02
+HOT TOPIC INC***
+WITH DUE BILL SPLT 3:2
+EXECUTION BY REDI
+VS 2200 02-06-02
+DOMMISSIO
+44.00
+S OF 02/06/0:
+SKECHERS USA INC
+SECUTION BY BUCK
+VS 1000 02-06-01
+OMMISSIO
+60,00
+OF 02/06/
+AMERICAN EAGLE OUTFITTERS INC
+DO 0 O OT PEND
+"ANNTAYLOA STORES CORP
+SEE NOTE 'S' ON BACK
+ES 10001.38 02, 50 12-11-01.
+850 12-03-01
+OMMISSIO
+EC FE
+72.00
+SYMBOLCUSIP
+QUANTITY
+GADZ®
+-400
+"GYMB
+13.90000
+'H*************''•
+-2,000 30.09250
+HOTT
+SKX
+"AEOS
+"ANN
+00zz
+*500
+7,000*
+30.50650
+
+24.171000
+*40.83740"
+027
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+5,544.91
+60,260.00**'"'
+67,173.30
+13.824.80
+'12,070.00
+40,751.78
+VS27
+
+
+22 of 32
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+02/12/02
+02/07/02
+02212/02020702 BOUGHT
+02/12/02 02/07/02
+''BOUGHT
+0242/02
+02/07/02
+BÖUGHi
+02/12/02
+2/077
+02/12/02
+02/07/02
+02/12/02
+02/0702
+"BÖUGHi
+02/12/02
+'*02/07/02
+0272702 02/07702'BOUGAT
+5 600 02-07-02
+OMMISSIO
+36.00
+FAMILY DOLLAR STORES INC
+1S 30002 07-02
+COMMISSION
+18,00
+HOT TOPIC INC
+STK SPLIT ON
+3050 SHS
+REC 01/23/02 PAY 02/06/02
+"HOT TOPIC INC'***
+EXECUTION BY INET
+: 1900 02-07-
+MMISSI
+57,00
+BEDTON BENTO
+VS 700 02-07-02
+NAUTICA ENTERPRISES INC
+EXECUTION BY JPHQ
+SEC FE 11-26-01
+.03
+PACIFIC SUNWEAR OF CALFORNIA
+5200020-020
+ROSS STORES INC
+XECUTION BY MON
+S 1200 01-08-0
+SEC FEE
+.65
+"TARGET CORP"***
+SEE NOTE 'S' ON BACK
+VS 400 02-07-02
+COMMISSION
+24,00
+SYMBOLGUSIP
+COH
+*FDO
+"HOT
+HOTT
+SHOO
+NAU
+*PSUN
+ROST
+027
+QUANTITY
+600
+300
+1,525
+1,900
+700
+-100*
+1,200
+-1,200
+400
+41.95000
+32.03800
+'''21.09910
+14.05000
+13.70000
+'21:46200
+35.93570
+* 43:21000
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+25,221.00
+9,644.40
+40,160.29
+9,850.00
+1,354.97
+25,769.40
+43,107.19
+17,323.00
+
+
+23 of 32
+Transaction Detail (continued)
+DATE
+02/12/02
+02/07/02
+Bear, Steams & Co. Inc.
+02/12/02 02/07/02 "BOUGHT
+02713/02
+'''02/08/02*BÖUGHT
+02713/02 02/08/02
+"BOUGHI
+02/13/02
+02/08/02
+Ö2/13/02
+02708/02
+20/E120
+02/08/02
+
+*02708/02 SO
+TIMBERLAND CO-CLA
+EXECUTION BY FCAP
+700 01-11-02, 800 01-10-0
+0 01-04-02, 1600 01-03-1
+SEC FISSION
+,245.00
+"HOT TOPIC INC.
+4200 SHS
+SEC 0123002 PAY 0206602
+BEST BUY COMPANY INC***
+EXECUTION BY BUCI
+VS 100 02-08-02
+COMMISSION
+6.00
+HEARETH COLE PRODUCTIONS INE"
+CHECUTION BY BUCK
+COMMIS 203-02
+36.00
+JOT LOCKER IN
+ECUTION BY BU
+
+120,00
+"HOT TOPIC INC*
+3000-0802T
+NORDSTROM INC
+VS 300 01-25-02
+COMMISSION
+SEC FEE
+18,00
+SYMBOLGUSP
+TBL
+"HOTT
+188
+KCP"
+HOTT
+SHOO
+027
+QUANTITY
+-3,500
+32.39850
+2,100
+100
+- 68.00000
+600
+16.00000
+2,000
+*300
+1,400
+*300
+14.93030
+21.09000
+14.25000
+22.95000
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+113,133.04
+6,821.00
+9,651.00
+29,995.60
+6,342.00
+19,965.00
+6,851.89
+
+
+Bear, Steams & Co. Inc.
+24 of 32
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+02/13/02
+02/08/02
+62/14/02 02/11702**BOUGAT
+02/14/02 "02/11/02"BOUGHT"
+TIMBERLAND CO-CLA
+VS 150 01-03-02, 450 01-02-02
+COMMISSION
+36.00
+SEC FEE
+NEERICAN EAGLE OUTERS INC
+
+"KENNETH COLE PRODUCTIONS INC
+96.00
+02/14/02
+02/11/02
+20171/20
+
+02714702 02/71702"BOUGHT"
+02/14/02
+''02711702
+02/14/02
+2/11/0
+"BÖUGHT
+DIRECT FOCUS INC
+59002-1020
+*STEVEN MADDEN LTD
+LECUTION BY JE
+S 1900 02-11-
+"PENNEY CO INC
+SEE NOTE 'S' ON BACI
+VS 1400 02-11-02
+COMMISSION
+84.00
+AS OF 02/11/02
+"SKECHERS USA INC
+CLA
+COMMISSION 1-02
+186,00
+"TROPICAL SPORTWEAR
+INTERNATIONAL CORP
+EXECUTION BY NITE
+VS 500 02-11-02
+SYMBOLGUSIP
+TBL
+KCP"
+DEXI
+SHOO
+JCP
+TSIC
+027
+QUANTITY
+-600
+400
+1,600
+900°
+1,900
+1,400
+31.51260
+16.4047
+29.15080
+DEBSttI.
+'''21.85940
+3,100
+500
+*'14:35510
+21:0000
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+18,856.27
+'9995.00
+26,358.52'
+26,250.72
+27,485.77
+*30,702.16
+44,701.81
+... ••
+10,565.00
+
+
+25 of 32
+Transaction Detail (continued)
+SETILEMENT TRADE
+DATE
+DATE
+02/15/02
+02/12/02
+62/15/02 02/12/02***BOUGAT
+02/15/02
+''*02/12702
+"SOLD"
+02/15/02
+02/12/02
+"SÖLD"
+02715/02
+02/12/02
+02/13/02 BOUGHT
+02/13/02
+'''SOLD"
+New York. New York 10179
+CHICOS FAS INC
+/S 700 02-04-02
+VOISSINIO
+SEC FEE
+-12,00
+"ESTEE LAUDER COMPANIES INC
+CLA
+COMMISSION
+48,00
+"NAUTICA ENTERPRISES INC
+EXECUTION BY JPHO
+VS 200 11-26-01
+SEC FEE
+.05
+NORDSTROM INC
+VS 1000 01-25-02
+COMMISSION
+SEC FEE
+,30.00
+REEBOK INTERNATIONAL LTD
+NITH RIGHTS TO PURCHASE COMMON
+STK UNDER CERTAIN CIRCUMSTANO
+EXECUTION BY WEDB
+COMMISSION
+ODMMISSION-01, 700 10,0001
+"CHARMING SHOPPES ING
+EXECUTION BY NITE
+VS 1900 02-13-02
+NAUTICA ENTERPRISES INC
+EXECUTION BY RSSF
+VS 100 11-26-01, 300 12-21-01
+400 11-13-0
+SEC FEE
+.17
+SYMBOL/GUSP
+CHS
+NAUT
+ABK
+"CHAS
+NAUT
+027
+QUANTITY
+-700
+800
+*200
+-7,300
+32.97200
+'3052680
+13.65250
+23.35840
+28.33000
+1,900
+800
+
+13.67880
+02/23/02:11:32 001
+CLEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+23,023.05
+• 24,484.44
+2,715.45
+23,283.04
+36,722.44
+11,719.00
+10,927.87
+
+
+26 of 32
+Transaction Detail (continued)
+
+02/19/02 02/13/02 BOUGHT
+*02/13/02
+"BÖUGHT
+02719/02
+02/13/02
+02/13/02
+BOUGH
+02713/02
+02720/02 *02/14/02*SOLB
+OFFICE DEPOT INC
+WITH RIGHTS TO PURCHASE PREFRD
+TK UNDER CERTAIN CIRCUMSTANO
+ECUTION BY BUC
+V0100021302
+24,00
+"OFFICE DEPOT INC
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY INET
+VS 800 02-13-02
+COMMISSION
+16.00
+"PACIFIC SUNWEAR OF CALIFORNIA"
+EXECUTION BY JPHO
+VS 500 02-13-02
+"RESTORATION HARDWARE ING DEL
+EXECUTION BY INET
+VS 800 12-19-01
+OMMISSIO
+SEC FE
+- 21.00
+TOMMY HILFIGER CORP-ORD
+5 60 02 Y 020
+IMMISSIO
+36,00
+WOLVERINE WORLD WIDE INC
+EXECUTION BY BUCI
+/S 400 02-13-02
+COMMISSION
+24.00
+"AMERICAN EAGLE OUTFITTEAS" INC"
+NEW
+EXECUTION BY JPHO
+VS 1000 01-23-02, 600 01-17-02
+, 600 01-22-02, 600 01-14-02,
+SEC FE: 1-02, 500 01-2-02
+SYMBOLGUSIP
+ODP
+*ODP
+*PSUN
+"RSTO
+TOM
+www
+"AE8S
+027
+QUANTITY
+400
+18.00000
+800
+800°
+600
+*400
+3,800
+01703580"
+21.71400
+• 10.00160
+
+15.60000
+*''2503650
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+7,239.00
+00ZL5'OL.
+13.659.64
+7,962.15
+7,621.74
+6,279.00
+*95.122.27
+
+
+27 of 32
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+02/14/02
+ö2/20/0202/14/02"BÖÜGHT
+RECEIVED
+02/21/02 02/15/02"BOUGHT"
+02/21/02
+' 02/15/02
+02721/02
+*02/15/02
+02/21/02 02/15/02 "BOUGHT
+02/21/02
+02/15/02
+
+GADZOOKS INC
+EXECUTION BY JEFF
+SEC FE 03-04-01. 300 08-27-01
+"PACIFIC SUNWEAR OF CALIFORNIA
+EXECUTION BY JPHO
+VS 1000 02-14-02
+CANDIES INC'***
+AMERICAN EAGLE OUTFITERS INC
+NEW
+EXECUTION BY RSSF
+VS 800 02-15-02
+"HOT TOPIC INC'****
+EXECUTION BY WEDB
+VS 800 02-15-02
+NAUTICA ENTERPRISES INC
+EXECUTION BY JPHO
+VS 200 11-13-01
+SEC FEE
+.05
+"SYMBOL TECHNOLOGIES INC
+/S 1200 02-15-02
+OMMISSIO
+60,00
+TOMMY HILFIGER CORP-ORD
+VS 200 02-15-02
+COMMISSION
+12.00
+ANNAYLOR STORES CORP"
+SEE NOTE "S" ON BACK
+EXECUTION BY BUCI
+/S 450 12-03-01
+COMMISSION
+SEC FEE
+27.00
+SYMBOLGUSIP
+GADZ
+*PSUN
+CAND
+"AEOS
+NAUT
+'SEL
+TOM"
+ANN
+QUANTITY
+-900
+1,420
+800
+800°
+*200
+1,200
+200
+:450
+15.28100
+21.22600
+24.52220
+20.50000
+13.92500
+* 8.24170
+11.62920
+....
+10.8031
+027
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+13,737.69
+**21,241.00
+19,632.76
+16,415.00
+2,769.95
+9,965.04
+2,352.84
+ZEGLE'BI
+
+28 of 32
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+02/22/02
+02/22/02 02/19/02$0
+
+02/22/02
+BEST BUY COMPANY INC
+
+18,00
+CHICOS FAS INC
+VS 9002-0-82CK
+SOCMISSION
+$5.00
+CIRCUIT CITY STOREST.
+CIRCUIT CITY GROUP
+VS 1200 02-19-02
+COMMISSION
+72.00
+TOMMY HILFIGER CORP-ORD
+VS 2000 02-19-02
+COMMISSION
+120,00
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+01/26/02
+01/28/02
+OPENINGBALANCE
+01/28/02
+"JOURNAL"
+ROM: SJZ
+72-USD
+DONE SEES M PATIENO
+TO: SUZA
+- 1-USD
+* JRL
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+20,823.00
+28,447.79
+SYMBOLCUSIP
+BBY
+CHS
+TOM
+QUANTITY
+300
+69.30000
+900
+• 31.68580
+1,200
+- 22.42630
+2,000
+11.44590
+26.998.56
+23,026.80
+$-1,974,521.02
+$1,387,852.33
+SYMBOUGUSIP
+GTOXX
+QUANTITY
+1,616,327.07
+859.05
+859.05
+DEBIT AMOUNT
+027
+
+
+Bear, Steams & Co. Inc.
+29 or 32
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+01/30/02
+01/31/02
+02/11702
+02/12/02
+0215/02
+62/21102
+ö2/21/02
+BOUGH
+DIVIDEND
+DOMEST PAME MAN PORTFOLIO
+"DOMEST PRIME PORTFOLIO
+MONTHLY DIVIDEND
+ö2/21/02
+DIVIDEND
+MONTHLY DIVIDEND
+62/21/02
+'''REINVEST
+02/24702
+'''REINVEST
+MONTHLY DIVIDEND REINVESTED
+02/22102
+TOTAL
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+02/11/02
+MASCO CORP
+REC 01/11/02 PAY 02/11/02
+SMARCUSP
+SYMBOUCUSIP
+GIDXX
+GTXX
+"GTOXX
+GTЫXX
+QUANTITY
+700
+QUANTI
+60,000
+200,000
+50,000
+200,000
+100,000
+100,000
+366.99
+1,114.34
+1,107,808.40
+RATE (S)
+0.1350
+027
+1.0000
+0000
+.0000
+1.0000"
+1.0000
+CLEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+60,000.00
+200,000.00
+50,000.00
+200,000.00
+100,000.00
+100,000.00
+-366.99
+1,114.34
+366.99
+1,114.34
+$-101,481.33
+$611,481.33
+DEBIT AMOUNT
+94.50
+
+
+30 of 32
+Transaction Detail (continued)
+DIVIDENDS (continued)
+
+TANGER FACTORY OUTLET CENTERS
+REC 01/31/02 PAY 02/15102
+02219/02 BE SHOP
+REC 01/31/02 PAY 02/19/02
+TOTAL
+INTEREST
+DATE
+02/21/02 INT CR
+TOTAL
+FEB 02
+DISTRIBUTION
+DATE
+02/11/02
+TRANSACTON
+DISTR
+02/11/02
+2 DISTR
+SK SPLIC IN 4200 SHS
+REC 01/23/02 PAY 02/06/02
+............
+TO SOLD WITH DE
+REC 01/23/02 PAY 02/06/07
+TOTAL
+New York. New York 10179
+SYMBOUGUSIP
+SKT
+DEBS
+QUANTITY
+1,700
+3,800
+SYMBOUCUSIP
+QUANTITY
+SYMBOUCUSIP
+HOTT
+HOTT
+RATE (S)
+0.6100
+0.0750
+RATE (SI
+CUANTITY
+2,100
+2,100
+027
+DEBIT AMOUNT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+1,037.00
+285.00
+$1,416.50
+DEBIT AMOUNT
+625.23
+$625.23
+RATE (S)
+DEBIT AMOUNT
+
+
+Bear, Steams & Co. Inc.
+31 01 32
+Transaction Detail (continued)
+MISCELLANEOUS
+DATE
+MO/DAY
+02/01/02
+02715/02
+JOURNAL'
+0271502** (OUANAL"
+ö2/15/02 JOURNAL"
+02/15/02
+'''OÜANAL"
+JOURNAL'
+TOTAL
+ESCRIPTIO
+11/02 CLA CHI
+FROM: SIZ
+* JAL *
+* JAIL
+1-15
+12-USD
+12050°
+-1:USD
+* JAL *
+nT0:SJ2
+• JAL *
+* JAIL *
+FROM: SIZ
+• JAL •
+[2-US0
+T 1-USD
+Trades Executed Pending Settlement
+SATEMENT
+TRADE
+DATE
+02/25/02
+02/25/02
+02/25/02
+02225/02
+
+BOUGH
+KENNETH COLE PRODUCTIONS ING
+IRCUIT CITY STORES IN
+ACUIT CITY GROL
+K-SWISSING CLA
+NAUTICA ENTERPRISES INC
+OMMY HILFIGER CORPOR
+DEBIT AMOUNT
+35.00
+692.82
+692.82
+692.82
+$-2,113.46
+SIMBOLCUSP
+KCP
+KSWS
+NAUT
+027
+CRECIT AMOUNT
+692.82
+892.82
+692.82
+$2.078.46
+QUANTITY
+1,300.00
+300.00
+300.00
+00.0
+700.00
+18.0986
+24.4000
+31.8500
+13.6600
+11.5249
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+23,621.18
+7,353.00
+9,570.00
+8,124.43
+2,716.95
+
+
+Bear, Stearns & Co. Inc.
+32 of 32
+Trades Executed Pending Settlement
+(continued)
+SEE MENT TREE
+02/26/02
+02/21/02
+02/26/02
+02/21/02"
+02226/02
+02/21/02
+BOUGH
+ö2/26/02
+02/21/02 BOUGHT
+02/26/02
+......
+02/21/02
+02/26/02
+02/26/02
+02/21/02
+02/21/02
+*BOUGHT
+__..
+02/22/02
+02/22/02
+... .
+02/22/02
+02227/02
+02/22/02
+2/22/0
+*BOUGHT
+TOTAL
+AMERICAN EAGLE OUTFITTERS ING
+NEW
+BEBE STORES ING
+.........
+KENNETH COLE PRODUCTIONS INO
+CLA
+'ESTEE LAUDER COMPANIES INC
+CLA
+NAUTICA ENTERPRISES INC
+JC PENNEY COINC
+QUIKSILVER INC
+....
+IRCUIT CITY STORES IN
+CIRCUIT CITY GROUP
+HOT TOPIC INC
+.. . . .
+ESTEE LAUDER COMPANIES INC
+CLA
+...... . .
+JAUTICA ENTERPRISES INC
+...............
+SKECHERS USA INC
+CLA
+The above trades do not appear in arry other section of this statement.
+STOP
+End of Statement******
+SYMBOLCUSP
+AEOS
+BEBE
+KCP
+EL
+NAUT
+ZQK
+CC
+HOTT
+NAUT
+SKX
+120
+QUANTITY
+1,000.00
+300.00
+600.00
+400.00
+-800.00
+-1,400.00
+2,000.00
+... .
+900.00
+1,000.00
+....
+300.0
+-700.00
+.....
+0'00€*
+25.6075
+21.5000
+18.6512
+29.7500
+13.7459
+.....
+20.9529
+19.5085
+.. . .
+16.2467
+19.9667
+... . .
+29.3954
+13.5187
+13.9169
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 25, 2002
+DEBIT AMOUNT
+25,622.50
+6,465.00
+....
+11,241.72
+11,939.00
+10,981.55
+........
+29.234.61
+39,152.00
+14,691.03
+20,011.70
+7,585.9
+9,447.94
+18,184.97
+$195,976.53
+$69,967.02
+
+
+lear, Steams & Co. In
+83 Madison AvenL
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+What's In This Statement
+Financial Summary ••••••••••••••••••//III I''
+Your Portfolio Holdings
+.....
+Transaction Detail ..............................
+Fund Activity.......
+Trades Not Yet Settled
+4
+8
+22
+24
+INTERNATIONAL CHARITABLE
+INTERESTS I| 8-30-94
+C/O FINANCIAL TRUST COMPANY *
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+6,674,163
+604,250
+1,616,327
+$8,894,740
+••••••••••••
+8,556,789
+337,952
+here are no "Stop Loss" orders or other pending bu
+r sell open orders on file for your account
+Market Value of Your Portfolio
+$2.220,577
+$3,233,750
+Cash & Equivalent
+Equities
+$6,674,163
+$5.323,039
+Current market value
+SP This satement stori for atanal for our red de, ol revere did ora dotan itormation.
+
+
+2 of 25
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 of 25
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Funds Deposited
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Money Fund
+Funds Withdrawn
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+470,371.51
+0.00
+$470,371.51
+THIS PERICO
+470,371.5
+... ...
+860,061.93
+1,252,949.15
+10,691.28
+1,449.82
+2,968,081.41
+$5,093,233.59
+-1,866,906.87
+-102,949.15
+-21,382.56
+-2,968,116.41
+54.959.354.39
+133,878.60
+3604250.11
+Income Summary
+Dividends
+Credit Balance Int.
+Total L
+THIS PERIOD
+2,296.31
+692.82
+$2.989.13
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total.
+CLOSING
+603,557.29
+692.82
+•..•.•
+$604,250.11
+027
+YEAR TO DATE
+2,296.31
+692.82
+**...------.
+$2,989.13
+2,220,577
+6,674,163
+$8,894,740
+.. . .
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+25%
+Equities
+75%
+Unshaded portions denole debi balance and'or short
+from the absolute market value of your portolio.
+
+
+4 of 25
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+THE TREASURERS FUNDING
+DOMESTIC PRIME MAM PORTFOLIO.
+THE TREASURERS FUNDING
+DOMESTIC PRIME MIM PORTFOLIO
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AMERICAN EAGLE OUTFITTERS INC
+NEW
+ANNTAYLOR STORES CORP
+BROWN SHOE COMPANY
+JOSEPH A BANK CLOTHIERS INC
+BEST BUY COMPANY INC
+....
+BORDERS GROUP INC
+COLDWATER CREEK INC
+CHILDRENS PLACE RETAIL STORES
+INC
+•....
+COSTCO WHOLESALE CORP-NEW
+••••••••••••••••••••••••••••••••••••••••••••••
+COLUMBIA SPORTSWEAR CO
+.. . . . .
+nanaaaaaaaaaaaan
+SYMBOLCUSIP
+GTOXX
+GTDXX
+QUANTITY
+.615,468.0
+859.05
+1.0000
+1.0000
+SYMBOUCUSIP
+AEOS
+ANN
+BWS
+JOSB
+*BBY
+BGP
+CWTR
+....
+PLCE
+COST
+COLM
+.....
+COH
+ACCT
+CASH
+CASH
+CASH
+CASH
+CASH
+... ..
+CASH
+CASH
+........
+CASH
+CASH
+CASH
+QUANTITY
+4,650
+1,350
+5,800
+4,300
+900
+750
+600
+10,300
+2,500
+1,600
+.......
+4,700
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+MARKET
+VALUE
+604,250
+....
+1,615,468
+859
+$2.220,577
+ESTIMATED
+ANNUAL INCOME
+29,078
+15
+$29,093
+1,8000
+.......
+1.7462
+28.0200
+36.5300
+15.5000
+7.0700
+72.1900
+.. . .
+23.3400
+16.6800
+....
+32.000đ
+44.2000
+33.7300
+... ....
+44.2900
+MARKET
+VALUE
+130,293
+49,316
+89,900
+30,401
+64.971
+....
+17,505
+10,008
+329,600
+110,500
+53,968
+... ..
+208,163
+ESTIMATED
+ANNUAL INCOME
+2,320
+CURRENT
+YIELD (%)
+2.5806
+027
+
+
+5 of 25
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+CANDIES INC
+..........
+CACHE INC NEV
+CATO COAP CLA
+CHARMING SHOPPES INC
+KENNETH COLE PRODUCTIONS INC
+CL A
+•-------.
+DIRECT FOCUS INI
+BEB SHOPS INC
+FOOTSTAR INC
+FOOT LOCKER ING
+FEDERATED DEPARTMENT STORES
+INC-DEL
+....
+FINLAY ENTERPRISES INC
+.......
+FOSSIL INC
+GADZOOKS INC
+GUITAR CENTER INC
+....
+GART SPORTS CO
+GIl APPAREL GROUP LTD
+GERBER CHILDRENSWEAR INC
+HOT TOPIC ING
+HEARX LTD
+COM NEW
+I-MANY INC
+..........
+HEAD NI
+NY REGISTRY
+SYMBOLCUSIP
+CAND
+CACH
+:ACO
+CHRS
+KCP
+DEXI
+DEBS
+FTS
+FNLY
+FOSL
+GADZ
+.. . .
+GTRC
+GATS
+GIII
+GCW
+........
+HOTT
+EAR
+IMNY
+.......
+HED
+CASH
+.....
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+.........
+CASH
+CASH
+CASH
+............
+CASH
+QUANTITY
+31,500
+....
+8,550
+900
+1,700
+600
+3,800
+2,300
+17,000
+5,000
+10,300
+5,800
+.......
+4,900
+4,800
+1,100
+20,850
+3,300
+10,300
+10,300
+1,600
+*.......
+5,000
+2.3900
+6.0500
+... . .
+20.3500
+5.3100
+17.2000
+36.5000
+25.5400
+23.2000
+14.
+1100
+40.4000
+9.7700
+20.5400
+14.5000
+15.9000
+22.9900
+7.0500
+6.6000
+33.3500
+1.1000
+8.6000
+.....
+3.3100
+MARKET
+VALLE
+75,285
+51,728
+18,315
+9,027
+17,200
+21,900
+97,052
+53,360
+239,870
+202,000
+100,631
+119,132
+71,050
+76,320
+25,289
+146,993
+21,780
+343,505
+11,330
+13,760
+16,550
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+ESTIMATE
+INNUAL INCOM
+CURRENT
+YIELD (S
+486 2.6536
+......
+1,140
+1.1746
+920
+5.5589
+
+
+6 of 25
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+JONES APPAREL GROUP INC
+.. . . .
+(-SWISS INC-CLA
+... . .
+KOHLS CORP
+........
+Z CLAIBORNE IN
+STEVEN MADDEN LTD
+MAXWELL SHOE CO ING-CLA
+.. . .
+MASCO CORP
+NOVEL DENIM HOLDINGS LTD
+NAUTICA ENTERPRISES
+INC
+••••••••••••••••••••••••••••••••••••
+POLO RALPH LAUREN CORP-CL A
+......
+PACIFIC SUNWEAR OF CALIFORNIA
+INC
+....
+QUIKSILVER INC
+RESTORATION HARDWARE ING DEL
+REEBOK INTERNATIONAL LTD
+ROSS STORES INC
+.........
+SKECHERS USA INC
+SYMBOLICUSIP
+JNY
+KSWS
+KSS
+SHOO
+MAXS
+MAS
+NVLD
+NAUT
+RL
+PSUN
+ZOK
+RSTO
+RBH
+ROS
+SKX
+STAGE STORES INC
+....
+SHARPER IMAGE CORP
+SHOE CARNIVAL INC-IND
+SYMBOL TECHNOLOGIES INC
+.......
+TUX COMPANIES INC NEW
+STGS
+SHRP
+SCVL
+SBL
+TJX
+CASH
+.....
+CASH
+.....
+CASH
+CASH
+CASH
+CASH
+.....
+CASH
+........
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+'CASH"*
+.....
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+............
+CASH
+QUANTITY
+1,400
+3,100
+........
+2,050
+16,500
+4,800
+4,900
+700
+12,250
+5,600
+13,100
+4,800
+10,100
+... ..
+8,300
+2,400
+....
+2,200
+... ..
+7,300
+8,700
+3,400
+7,900
+2,000
+900
+32.9800
+36.7600
+66.3400
+......
+26.3000
+16.4000
+16.7400
+26.8500
+1.0000
+13.8400
+27.7100
+23.0000
+18.2100
+10.1000
+8.880
+34.9700
+•........
+15.8800
+25.3500
+10.5600
+14.3500
+15.8800
+40.0000
+46,172
+113,956
+135,997
+433,950
+78,720
+82,026
+18,795
+134.750
+77,504
+63,00
+110,400
+183,921
+83,830
+69,312
+6,934
+115,924
+220,545
+35,904
+113,365
+31,760
+36,000
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+ANNA NONE
+186
+3,71:
+378
+CURRENT
+YELD IN
+0.1632
+0.8556
+.....
+2.0112
+374
+0.4861
+40
+.......
+162
+0.1259
+).4500
+
+
+7 of 25
+Your Portfolio Holdings (continued)
+Bear, Steams & Co. Inc.
+Equities & Options (continued)
+TANGER FACTORY OUTLET CENTERS
+TALBOTS INC
+TIMBERLAND CO-CLA
+TOMMY HILFIGER CORP-ORD
+UNITED RETAIL GROUP INC
+ZALE CORP NEW
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLICUSIP
+SKT
+ILB
+TBL
+TON
+URGI
+WTSLA
+ZLC
+CASH
+CASH
+....
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+1,700
+5,150
+7,250
+14.650
+15,150
+12,750
+2,400
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+23.1700
+17.4200
+38.6500
+.....
+5.2000
+6.9500
+22.5900
+43.9100
+MARKET
+39,389
+192,713
+280,213
+... .
+222,680
+105,293
+39,023
+105,384
+$6,674,163
+$6,674,163
+$44,608
+$8,894,740
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+ESTIMATE
+NNUAL INCOM
+4,148
+CURRENT
+YIELD (%)
+10.5309
+1,648 0.8552
+.....
+....
+$15,515
+$15,515
+
+
+8 of 25
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT TRADE
+DATE
+01/02/02
+12/27/01
+01762782 72727701"SOLB"
+
+* *12731701
+'''*BOUGHT
+
+01704/02
+12/31/01
+12/3101
+01/04/02
+12/31/01
+BOUGH
+01/04/02
+12/31/01
+01/04/02
+12/31/01
+01704/02
+*BOUGHT"
+ö1/04/02
+
+SHARPER IMAGE CORP
+EXECUTION BY SLKC
+VS 400 12-27-01
+"WILSONS LEATHER "EXPERTS INC
+502 0601
+"CHILDRENS PLACE RETAIL STORES
+ING
+EXECUTION BY JPHO
+VS 2300 12-31-01
+FOOT LOCKER INC
+AS OF 12/31/01
+"FEDERATED DEPARTMENT STORES'
+INC-DEL
+VS 900 12-31-01
+COMMISSION
+54.00
+FINLAY EN
+TERPRISES INC
+EXECUTION BY SLKC
+VS 1900 12-31-01
+FOSSILIN
+GUITAR CENTER INC
+EXECUTION BY NITE
+VS 1500 12-31-01
+"HOT TOPIC INC....
+EXECUTION BY SSH
+VS 700 12-31-01
+LIZ CLAIBORNE INC
+WITH DUE BILL SPLT 2:1
+VS 2400 12-31-01
+COMMISSION
+144,00
+SYMBOLCUSIP
+SHAP
+NSTM.
+"GTRC
+027
+QUANTITY
+400
+:1,950
+2,300
+2,500
+1,900
+1,900
+1,500
+700
+2,400
+11.73000
+• 1:74000*
+
+15.83890
+40.45470
+9.08910
+21.12400
+13.67640
+• 31.97000
+50.00010
+LEARED THROUGH
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+DEBIT AMOUNT
+4,707.00
+December 31, 2001
+*21,707.27
+62,859.05
+39,772.25
+36.478.23
+7,284.21
+*40,150.60
+20,529.60
+22,394.00
+120,159.24
+
+
+9 of 25
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+01/04/02
+12/31/01
+BOUGhT
+01/04/02 12/31701"BOUGHT
+01704/02 12731701
+01/07/02
+01702/02
+BOUGH
+ö1/07/02
+01/02/02
+
+• 01702702
+''''BOUGHT"
+01707702 81/02/02"BOUGHT
+01707/02 01/02/02 "BOUGHT"
+89:887028183/02*8008A
+NOVEL DENIM HOLDINGS LTD
+EXECUTION BY REDI
+V0700523101
+14,00
+PACIFIC SUNWEAR OF CALIFORNIA
+SHARPER IMAGE CORP
+1500 123101
+ONLORENS PLACE RETAIL STORES
+3 9000102.040
+24.00
+POLO RALPH LAUREN CORP-CL'A*
+SEE NOTE 'S' ON BACK
+VS 400 01-02-02
+COMMISSION
+24.00
+"STAGE STORES INC
+
+"TIMBERLAND CO-CLA
+VS 3600 01-02-02
+COMMISSION
+216,00
+NEW
+EXECUTION BY JPHI
+IS 600 01-03-02
+SYMBOLCUSP
+NVLD
+*PSUN
+"SHAP
+"PLCE
+SNY
+SiGS
+220
+QUANTITY
+700
+600°
+500°
+*900
+*400
+400
+1,300
+*3,600
+"500***
+11.18570
+20.16130
+• 11.62650
+27.92370
+32.99150
+26.10000
+''2325000"
+37.07050
+••*27:12250
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+DEBIT AMOUNT
+7,858.99
+12,111.78
+5,828.25
+5.146 S
+3.235.60
+10,479.00
+*30,240.00
+133,684.80
+"16,288.50
+
+
+10 of 25
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+01/08/02
+01/03/02
+01768702 81/63702"BÖ0GAT
+01/08/0201/03/02"BOÜGHT
+
+01/03/02 BOUGHT
+01709/02 01/04/02"BOUGHT
+01709/02 81/04/02"BOUGHT
+01709/02
+''01/04/02BOUGHT"
+01709/02 81/04/02"BÖUGHT
+ANNTAYLOR STORES CORP
+SEE NOTE 'S' ON BACK
+VS 300 01-03-02
+COMMISSION
+18,00
+FOOTLOCKER" INC
+UNSOLICITED
+AS OF 01/03/02
+"PACIFIC SUNWEAR OF CALIFORNIA"
+(ECUTION BY RS
+0-60-10 0005
+TALBOTS INC..
+20-60L00
+COMMISSION
+18,00
+"TIMBERLAND CO-CLA
+VS 1750 01-03-02
+NOISSINWOO
+105,00
+"AMERICAN EAGLE OUTFITTERS INC
+NEW
+ECUTION BY RSS
+S 750 01-04-0
+LORENS PLACE RETAIL STORES
+COLUMBIA" SPORTSWEAR CO
+XECUTION BY MON
+'S 300 01-04-02
+"FOOT LOCKER INC"
+VS 1100 01-04-02
+COMMISSION
+66.00
+SYMBOLCUSIP
+ANN
+"SUN
+TBL
+"AEOS
+"PLCE"
+COLM
+220
+QUANTITY
+300
+1,700
+400°
+*300
+1,750
+*750
+500
+300"
+1,100
+35.35200
+2150000"
+- 3760590
+37.91060
+'''28.73750
+29.23870
+35.50000
+15.49600
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+DEBIT AMOUNT
+10,638.60
+CRECIT AMOUNT
+"17,33776
+"8,615.00
+11,31477
+66,463.55
+21568.13
+14,63435
+10,665.00
+17,126.60
+
+
+Bear, Steams & Co. Inc.
+11 of 25
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+01/09/02
+01/04/02
+BOUGhT
+09769782 "81784702'฿O0GAN"
+6170902* 01764/02 "BOUGHT
+ö1/09/02
+01704/02
+*BÖUGHT
+FINLAY ENTERPRISES INC
+EXECUTION BY WAWP
+
+S 1200 01-04 02
+"NAUTICA ENTERPRISES INC
+EXECUTION BY MONT
+VS 500 01-04-02
+AS OF 01/04/02
+"SKECHERS USAINC
+54,00
+01/09102
+/01/04/02
+
+1• 01707/02
+01/10/02"
+*01/07/02
+
+MBERLAND CO-CL
+(ECUTION BY BUC
+COMMISSION -02
+24,00
+ANNTAYLOR STORES CORP*
+SEE NOTE 'S' ON BACK
+VS 300 01-03-02, 200 12-13-01
+COMMISSION
+SEC FEE
+20.00
+"BUS WHOLESALE CLUB INC
+VS 50001-07-02
+COMMISSION
+30,00
+BEBE STORES INC
+EXECUTION BY RSSF
+VS 900 12-24-01
+SEC FEE
+.33
+SYMBOLGUSIP
+FNLY
+SKX
+™BL
+ANN
+027
+QUANTITY
+500
+900
+400
+500
+"900
+9.15000
+' 2065590"
+#13.77880
+• 16:77780
+38.86520
+- 35.95000
+42.02000
+123:50000
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+DEBIT AMOUNT
+4,590.00
+24,802.08"
+''6,904.40
+2969575.
+15,585.08
+*17,929.73
+21,055.00
+21,49487
+
+
+12 of 25
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+DATE
+01/10/02
+01/07/02
+01710/02 01767702"BOUGHT
+01710102 01707/02 BOUGHT
+01710/02 0107/02 "BOUGHT
+
+''01708/02 SOLD
+Bear, Steams & Co. Inc.
+01711/02*81/08/02OUGH**
+
+BEST BUY COMPANY INC
+07000-07-02
+42,00
+CHILDRENS PLACE RETAIL STORES
+$ 500 01-07-120
+FEDERATED BEPARTMENT STORES
+ING-DEL
+VS 300 01-07-02
+COMMISSION
+18,00
+'STAGE STORES INC
+NEW
+CUTOBY AZ
+'S 1000 01-07-0
+AMERICAN EAGLE OUTFITTERS INC
+.27
+AS OF 01/08/02
+'BOADERS GROUP IN***
+117,00
+OF 01/08
+CHILDRENS PLACE RETAIL"STORES
+NECUTION BY SPO
+20-80-10008 5A
+AS OF 01/08/02
+SYMBOLCUSIP
+BBY
+FD
+*STGS
+"AEOS
+PLCE
+027
+QUANTITY
+700
+500
+0OE.
+600
+74.47500
+-28.62380
+43.05000
+24.10000
+29.16500
+800
+27.96750
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+DEBIT AMOUNT
+52,189.50
+CRECIT AMOUNT
+14,326.90
+008+6ZL
+17,483.73
+22,389.00
+
+
+13 of 25
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+01/11/02
+01/08/02
+01711702 01708/02 SOLD"
+01711/02
+01706/02
+
+01717802 "01708/02"BÖUGHT"
+
+01708/02 BOUGHT
+01711702 81708/02 BOUGHT
+10-61271 008 S0
+
+18,00
+"DOLLAR TREE STORES ING
+CONSON 0. 1001-24-01
+COMMISSION
+SEC FEE
+AS OF 01/08/02
+KOHLS CORP''***
+XECUTION BY BUCH
+'S 200 11-30-01, 100 12-03-0
+COMMISSION
+18,00
+AS OF 01/0802
+,32
+"PACIFIC SUNWEAR OF CALFORNIA
+EXECUTION BY RSSF
+/S 1000 01-08-02
+S OF 01/08/0:
+"ROSS STORES INC
+EXECUTION BY SLKC
+AS 050101-0202
+ROSS STORES INC
+EXECUTION BY MON
+VS 1400 01-08-02
+AS OF 01/08/02
+"SKECHEAS USAINE"
+BEATEN BE BUCK
+COMMISSION
+36,00
+AS OF 01/08/02
+SYMBOL/GUSP
+COH
+BLTR
+PSUN
+"ROST
+ROST
+SKX
+027
+QUANTITY
+-300
+1,300
+300°
+1,300
+1,400
+600
+43.35000
+'''2967100"*
+69.92790
+21.12000
+33.83000
+33.57050
+1570618"
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+DEBIT AMOUNT
+12,971.80
+*38,530.72
+20,945.05
+24,135.00
+43,994.00
+47,013.70
+9,474.66
+
+
+14 of 25
+Transaction Detail (continued)
+SETTLEMENT TRADE
+01/14/02
+D7T0902
+0171402 01709/02 "BOUGHT
+01/14/02
+501/03/02
+''BOUGHT
+ö1714/02
+01/09/02
+01714/02 01/09/02
+01714/02
+11/09/0
+01715/02"
+
+"SÖLD"
+ANNTAYLOR STORES CORP
+SEE NOTE 'S' ON BACK
+ECUTION BY BUC
+5 800 12-13-01, 400 12-11-
+SEC FESSION
+72,00
+.65
+"CHILDRENS PLACE RETAIL' STORES
+s4000-09-020
+HOT TOPIC INC****
+EXECUTION BY INET
+VS 600 01-09-02
+COMMISSION
+18.00
+KOHLS CORP"
+EXECUTION BY BUCH
+VS 500 12-03-01, 500 11-07-01
+200 11-06-01
+COMMISSION
+SEC FEE
+122:00
+NAUTICA ENTERPRISES INC
+EXECUTION BY JPHO
+VS FO 11-19-01, 100 01-01-02
+ROSS STORES INC
+EXECUTION BY SLKO
+/S 1000 01-09-02
+"AMERICAN EAGLE OUTAITERS INC
+LES 15001-0402. 500 01-03-02,
+00 12-20-01, 1200 12-11-01
+00 12-18-01, 450 12-13-0
+SEC FEE
+SYMBOL/GUSP
+ANN
+"PLCE"
+"HOTT
+NAUT
+ROST
+"AEOS
+027
+QUANTITY
+-1,200
+36.07830
+*400
+600
+1,200
+600
+7,000
+3,500
+
+33.01000
+70.27010
+13:57330
+33.95000
+2829130"
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+DEBIT AMOUNT
+43,206.31
+•11,438.32
+19,839.00
+84,235.85
+8,128.85
+3,965.0
+99,003.06
+
+
+15 of 25
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+DATE
+01/15/02
+01/10/02
+61/15/02 01710/02**"BOUGAT
+01715/02 01/10/02 SOLD
+01715/02 01710/02 "BOUGHT
+01/15/02
+01/10/02
+01715/02 01/10/02SOLD
+01715/02
+01/10/02
+BOUGHi
+01716/02 01771702*"OUGHT
+Bear, Steams & Co. Inc.
+BJS WHOLESALE CLUB ING
+'S 500 01-07-02
+OMMISSION
+SEC FEE
+.30.00
+KOHLS COPP'''***
+VS 300 01-10-02
+DOMMISSION
+
+.09
+*SKECHERS USA INC
+42.00
+TIMBERLAND CO-CLA
+EXECUTION BY MLCO
+IS 800 01-10-02
+JOMMISSION
+56.00
+AS OF 01/10/02
+TOMMY HILFIGER CORP-ORD"
+VS 600 08-20-01
+SEC MISSION
+136.00
+WET SEALING-CLA
+EXECUTION BY INE
+VS 1200 01-10-02
+COMMISSION
+36.00
+AS OF 01/10/02
+AMERICAN EAGLE OUTFITERS INC
+NEW
+EXECUTION BY JPHO
+VS 500 01-11-02
+SYMBOLCUSP
+BJ
+"KSS
+NAUT
+SKX
+TBL
+WISLA
+"AEOS
+027
+LEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+DEBIT AMOUNT
+20,686.33
+''''20,718.00
+QUANTITY
+-500
+41.46330
+300
+- 685500•-
+40013.51500..
+*700
+15.17170
+800
+39.10510
+'600
+***15.37440******
+1,200
+26.80200
+500
+"27.10900
+5,390.91
+10,677.18
+31,355.08
+***9,175.50
+32,213.40
+13,569.50
+
+
+16 of 25
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+01/16/02
+01/11/02
+01716/02 01719702 SOLD
+01716/02 01711702 SOLD
+01716/02"
+01/11/02
+01716/02
+
+01716/0201/71/02 SOLD
+01716/02
+'*01711702
+89798702 89779702'BO0BRT
+BEST BUY COMPANY INC
+S0031-11-02
+BORDERS GROUP INC
+12,00
+ING-DEL
+VS 300 01-07-02, 300 12-31-01
+COMMISSION
+SEC FEE
+36.00
+"HOT TOPIC INC
+EXECUTION BY MON
+VS 300 01-09-02
+SEC FEE
+16
+NAUTICA ENTERPRISES INC
+XECUTION BY NIT
+S 500 11-14-0
+SEC FEE
+•BEHE SUVER OF CAFR
+EXECUTION BY RSSF
+VS 300 01-03-02
+.10
+ROSS STORES INC
+EXECUTION BY SBSH
+VS 300 01-09-02
+SEC FEE
+.15
+"TIMBERLAND" CO-CLA
+COMMISSION -02
+42,00
+SYMBOLCUSIP
+BBY
+"BGP
+'FB
+HOTT
+NAUT
+''''SUN
+ROST
+027
+QUANTITY
+200
+73.24800
+500
+21.47860
+60042.10000**
+300°
+33.79000
+500°
+13.62000
+-300
+* 22.15000******
+300
+32.73330
+700*
+' 3934160"
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+DEBIT AMOUNT
+14,676.60
+10,694.13
+*****25,208.62
+10,121.84
+6,794.89
+:.629.90
+9,804.84
+27:598.12
+
+
+17 of 25
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+DATE
+01/16/02
+01/11/02
+61/1762 01714/02**"BOUGAT
+01717/02 01/14/02 SOLD
+Bear, Steams & Co. Inc.
+01717702 01/14/02 SOLD
+01/18/02
+0175/02
+01718/02 01715/02 BOUGHT
+01/18/02 01/15/02 BOUGHT
+TOMMY HILFIGER CORP-ORD
+VS 300 08-20-01
+COMMISSION
+SEC FEE
+118.00
+"ARERAN EARLE OUTERS INC"
+EXECUTION BY PHO
+/S 600 01-14-02
+"HOT TOPIC ING**''
+EXECUTION BY MONT
+1 20 1202 0 01-020
+"TOMMY HILFIGER CORP-ORD
+VS 200 08-20-01, 400 08-24-01,
+600 08-08-01
+SEC FISSION
+72,00
+138,00
+ECUTION BET BUCK
+COMMISSION 5-02
+36.00
+"HOT TOPIC INC
+55110001-15-02
+SYMBOLGUSIP
+TOM
+"AEOS
+"HOTT
+"TOM"
+FTS
+"HOTT
+027
+QUANTITY
+-300
+600
+15.37000
+*27:7267
+3,500
+0033.90380
+-1,200
+15.44620
+2,300
+600*
+1,100
+24.04600
+*15.03680"
+34.16250
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+DEBIT AMOUNT
+4,577.93
+'' 16,297.02
+**aaaaaaaaa•***118,646.52
+18.448.16
+55,458.80
+*9,073.08
+37,593.75
+
+
+18 of 25
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+DATE
+01/18/02
+01/15/02
+61/2202**01716/02S0LВ
+01/22/02
+*'*01716/02BÖUGHT"
+01722/0201/18/02"BOUGHT"
+01722/02 01/16/02 BOUGHT
+01722/02
+'''21/18/02•'S0LD
+01722/02 01/16/02 SOLD
+01722/02
+'*01718/02 BOUGHT
+TANGER FACTORY OUTLET CENTERS
+VS 900 01-15-02
+COMMISSION
+54,00
+BOADERS GAOUP INC.**
+§ 700 01-08-0
+IMMISSION
+SEC FEE
+22.00
+GART SPORTS CO"
+XECUTION BY SLK
+S 1100 01-16-0
+"HOT TOPIC INC'***
+5 2300 01-1682
+"STEVEN MADDEN LTD
+ROSS STORES INC
+SEC FEE
+,35
+*TIX COMPANIES ING NEW
+VS 400 12-04-01, 200 11-13-01
+DOMMISSION
+36.00
+SEC FEE
+,35
+"TALBOTS INC
+VS 900 01-16-02
+COMMISSION
+54.00
+SYMBOLCUSIP
+SKT
+"BEP
+"GRTS
+SH00
+ROST
+027
+QUANTITY
+900
+700°
+1,100
+2,300
+700
+*700
+-600
+900°
+22.51980
+2267000"
+20.51140
+''34.40250
+- 15.18000
+'32.79230
+38.66430
+35.62831
+LEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+DEBIT AMOUNT
+20,336.82
+CRECIT AMOUNT
+'15,811.76
+22,577.54
+79,140.75
+10,641.00
+22,939.26
+"23,147.23
+32,134.48
+
+
+19 of 25
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+01/22/02
+01/16/02
+61/23/02 0171702**BO0GAT
+61723/02 "01/17/02"BOUGHT'
+01723/02 01717702 "BOUGHT"
+Ö1/23/02
+01717/02 BOUGHT
+01723/02 07717702"OUGHT
+01723/02 07717/02"BÖUGHT
+01723/02
+n*017702
+#''"SOLD
+Bear, Steams & Co. Inc.
+TOMMY HILFIGER CORP-ORD
+/S 200 08-08-01, 500 08-09-0
+DOMMISSION
+42,00
+SEC FEE
+"AMERICAN EAGE OUTIES NE"
+EXECUTION BY JPHO
+VS 600 01-17-02
+"FOOT LOCKER ING
+EXECUTION BY BUCH
+VS 700 01-17-02
+COMMISSION
+LIZ CLAIBORNE INC
+42,00
+TK SPLIT O
+7200 SHS
+EC 12/31/01 PAY 01/16/0
+LIZ CLAIBORNE INC
+EXECUTION BY BUCH
+VS 2100 01-17-03
+COMMISSION
+126,00
+"STEVEN MADDEN LTD
+ECUTION BY VK
+$ 2000 01-17-
+TANGER FACTORY OUTLET CENTERS
+: 800 01-17-0
+MISSIO
+48.00
+"TOMMY HILFICER CORP ORD
+ECUTION BY BUC
+: 200 08-09-01, 400 08-03-
+COMMISSION
+36.00
+SEC FEE
+14
+SYMBOLCUSIP
+TOM
+"AEOS
+SH00
+'SKT
+"TOM
+027
+QUANTITY
+-700
+15.32230
+600
+*27:3583
+700
+00 14.72730
+7,200
+2,100
+- 25.17480
+2,000
+• 15.88000
+*800
+22.96610
+800%
+15.15510
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+DEBIT AMOUNT
+10,668.44
+'''16,429.38
+10,366.11'''
+53,008.08
+"31,775.00
+18,435.88
+9,041.92
+
+
+20 of 25
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+01/24/02
+01/18/02
+01724/02 01/18/02 SOLD
+Bear, Steams & Co. Inc.
+01724/02"
+01/18/02
+01724/02 01/18/02
+ö1/24/02
+
+81725/02 01722/02"BOUGHT"
+01/25/02 01/22/02 "BOUGHT
+FOSSIL INC
+EXECUTION BY SLKC
+GERBER CHILDRENSWEAR INC
+/S 2400 12-06-99, 1700 12-08-5
+9
+DOMMISSION
+SEC FE
+.205.00
+AS OF 01/18/02
+K-SWISS INC-CLA
+(ECUTION BY VKO
+5 300 10-10-01, 300 10-05-0
+AS OF 01/18/02
+ROSS STORES INC
+EXECUTION BY GSCO
+VS 500 01-08-02
+COMMISSION
+SEC FEE
+25.00
+AS OF 01/18/02
+TOMMY HILFIGER CORP-ORD
+TS 45008 03-01. 400 08-2201,
+600 11-14-01, 50 08-07-01
+COMMISSION
+90,00
+SEC FEE
+.34
+AS OF 01/18/02
+AMERICAN EAGLE OUTFITERS INC
+NEW
+EXECUTION BY JPHO
+VS 600 01-22-02
+"FOOT LOCKER INC
+VS 2500 01-22-02
+COMMISSION
+150,00
+SYMBOLCUSIP
+FOSL
+GOW
+KSWS
+"ROST
+TOM
+"AEOS
+027
+QUANTITY
+500
+4,100
+-600
+500°
+20.22000
+= 6.55700
+35.30000
+'32. 43580"
+1,500
+14.97300
+600"
+2,500
+27.28670
+1497480"
+CLEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+DEBIT AMOUNT
+10,125.00
+26,663.29
+21,164.68
+16,177.65
+22,354.16
+16,387.02
+*37,602.00
+
+
+21 of 25
+Transaction Detail (continued)
+SETTLEMENT TRADE
+DATE
+01/25/02
+01/22/02
+6172502* 01722/02**SOLB
+HOT TOPIC INC
+SEC FEE
+"REEBOK INTEANATONAL L1B..
+WITH RIGHTS TO PURCHASE COMMON
+STK UNDER CERTAIN CIRCUMSTANCE
+COMMISSION
+SEC FEE
+113.00
+....
+TOMMY HILFIGER CORP-ORD
+VS 600 08-07-01
+COMMISSION
+SEC FEE
+• 36,00
+01/25/02
+01/22/02
+TOTAL
+DEPOSITS AND WITHDRAWALS
+DATE
+01/14/02
+CHECK
+01723/02
+"CHECK"
+01/23/02
+FUNDS REC
+FEES 7R 01101102-03/31/02
+BUCKINGHAM CAPITAL MGMT
+K51010102-0333102
+BUCKINGHAM CAPITAL
+ÇES TA UTU1N220331102
+BUCKINGHAM CAPITAL
+TOTAL
+SYMBOLCUSIP
+HOTT
+"ABK
+TOM
+DEBIT AMOUNT
+10,691.28
+10,691.28
+$-21,382.56
+027
+QUANTITY
+-1,250
+*300
+600
+34.29500
+•28.50000"
+14.93350
+10,691.28
+$10,691.28
+LEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+DEBIT AMOUNT
+42,853.10
+51687
+$-1,866,906.87
+8,908.96
+$860,061.93
+
+
+22 or 25
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MODAY
+01/01/02
+ö1/02/02S0LD
+01702/02 "REINVEST
+0170202 DIVIDEND
+01/02/02
+REINVEST
+01/02/02
+DIVIDEND
+01/03/02
+01/03/02
+01/03/02
+"JOURNAL
+ö1/ö702
+01/07/02
+01/08/02
+ö1/14/02
+01/18/02
+SOLD"
+DESCAIPTION
+OPENINGBALANCE
+MONTHLY DIVIDEND REINVESTE
+"OLEST SANE AM PERFOLD
+AMT INCLUDED IN 2001 - 1099
+MONTHLY DIVIDEND REINVESTED
+AMT INCLUDED IN 2001 - 1099
+DOMESTIC PRIME A PORTFOLIO
+FAL: SUZI
+TO: SUZ
+-1-USD
+* JRL *
+DOES PREM PORTFOLIO
+DOES PANE PRANGLO
+DOMEST PRIME A PORTFOLIO
+Bear, Stearns & Co. Inc.
+SYMBOU/CUSIP
+GTXX
+GTOXX
+"GbXX"
+''"TDXX"
+"GTOXX"
+QUANTITY
+2,763,377.92
+350,000
+882.12
+527.72
+250,000
+527.72
+527.72
+:100,000
+200,000
+:150,000
+100,000
+*200,000
+027
+1.0000
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+DEBIT AMOUNT
+350,000.00
+882.12
+882.12
+527.72
+1.0000
+527.72
+250,000.00
+7.0000
+1000
+1.0000
+1.0000
+1.0000
+100,000.00
+100,000.00
+200,000.00
+150,000.00
+200,000.00
+
+
+23 of 25
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+01/23/02
+DIVIDEND
+DOMESTE SHEES PRANSLO
+MONTHLY DIVIDEND
+01/23/02 "DIVIDEND*
+MONTHLY DIVIDEND
+01723/02'''HEINVEST**
+01/2302#AEINVESY
+""HE TREASURERS FUND' INCR
+DOMESTIC PRIME MIM PORTFOLIO
+MONTHLY DIVIDEND REINVESTED
+CLOSINGBALANCE
+01/25/02
+TOTAL
+DIVIDENDS
+01702/02
+BROWN SHOE COMPANY
+REC 12/17/01 PAY 01/02/02
+SYMBOUCUSIP
+BWS
+00/15/02
+TOTAL
+REC 12/24/01 PAY 01/07/02
+K-SWISS INC-CLA
+REC 12/31/01 PAY 01/15/02
+KSWS
+SYMBOUCUSIP
+GIDXX
+QUANTITY
+'''GOXX"
+68026
+859.05
+1.616,327.07
+QUANTITY
+RATE (SI
+5,800
+0.1000
+900**0:1350*
+3,700
+0.0150
+027
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+DEBIT AMOUNT
+680.26
+859.05
+****••*••***802******•
+''859.05
+$-102,949.15
+DEBIT AMOUNT
+580.00
+••••*••••••••••••••••••••••••••*121:50
+55.50
+$757.00
+$1,252,949.15
+
+
+24 of 25
+Transaction Detail (continued)
+INTEREST
+DATE
+01/22/02
+INT CR
+TOTAL
+SYMBOUCUSIP
+JAN 02
+MISCELLANEOUS
+DATE
+MO/DAY
+01/03/02
+01703/02 ANAL'
+1/07/0
+TOTAL
+OFFSET FROM BKD P&L
+''CASH'**••••••••••••••••••••••••
+MOVE BKD P&L TO BOOKKEEPING
+12/01 CLA CHG |
+-15
+Trades Executed Pending Settlement
+SEEMENT TRE
+01/28/02
+01/23/02
+01/28/02
+01/23/02
+3/02 SOLD
+01/28/02
+01/23/02
+01/28/02
+01/2302
+01/28/02
+01/2302
+01/28/02
+01/23/02
+AMERICAN EAGLE OUTFITTERS ING
+NEW
+"COLDWATER CREEK INC
+FOOT LOCKER INC
+GERBER CHILDRENSWEAR INC
+GALYANS TRADING INC
+HOT TOPIC INC
+QUANTITY
+RATE (SI
+DEBIT AMOUNT
+•2,968,081.41
+35.00
+$-2,968,116.41
+SYMBOLCUSP
+AEOS
+"WTR
+GLYN
+HOTI
+027
+DEBIT AMOUNT
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+692.82
+$692.82
+CRECIT AMOUNT
+2,968,081.41
+$2,968,081.41
+QUANTITY
+1,000.00
+600.00
+8.......
+700.00
+3,300.00
+1,100.00
+1,250.00
+27.8650
+6.7630
+14.5317
+6.5000
+13.2254
+33.8943
+DEBIT AMOUNT
+27,880.00
+10,236.19
+14,562.94
+10,042.64
+11.269.6
+42,352.24
+
+
+25 of 25
+Trades Executed Pending Settlement
+(continued)
+SETLEMENT TRIE
+01/28/02
+01/23/02
+01728/02
+/*01/23/02
+01/23/02
+01/24/02
+01/24/02
+•.....
+01/29/02
+01/24/02
+…aaaaaaaaaaaa...a.aaa.
+01/29/02
+01/24/02
+.. ..
+01/29/02
+01/24/02
+bananananaanaıaaınaananaaaananaanaaannallıanaan
+01/29/02
+01/24/02
+01/29/02
+*---••••
+01/29/02
+..-•
+1/29/0
+01/24/02
+01/24/02
+01/24/02
+BOUGH
+01/29/02
+..-_.
+01/30/02
+...........
+01/30/02
+TOTAL
+01/24/02
+01/25/02
+01/25/02
+BOUGH"
+PAXAR CORP
+*SKECHERS USA INC
+CLA
+TOMMY HILFIGER CORP-ORD
+FOOT LOCKER ING
+GENESCO ING
+WITH RIGHTS TO PURCHASE PREFRD
+HOT TOPIC N.....
+HOME DEPOT INC
+... . .
+STEVEN MADDEN LTD
+PACIFIC SUNWEAR OF CALIFORNIA
+INC
+PAXAR CORP
+ROSS STORES INC
+TOYS R USINC
+WITH RIGHTS TO PURCHASE COMMON
+TOMMY HILFIGER CORP-ORD
+HOME DEPOT INC
+NORDSTROM ING
+The above trades do not appear in ary other section of this statement.
+SYMBOLICUSIP
+PXR
+SKX
+TOM
+HOTT
+HD*
+......
+SHOO
+PSUN
+PXR
+ROST
+TOY
+TOM
+ie
+027
+QUANTITY
+1,000.00
+500.00*
+800.00
+1,100.00
+700.00
+2,000.00
+700.00
+*...••*•••••
+500.00
+-500.00
+500.00
+-700.00
+1,400.00
+1,900.00
+300.00
+.300.00
+15.0220
+15.9338
+14.7484
+14.5482
+23.9880
+34.2517
+48.0200
+_.........
+16.5900
+.......
+22.5813
+15.1546
+..........
+34.5367
+18.9284
+14.9084
+... .
+47.1500
+..........
+24.6766
+Bear, Steams Secuities Corp.
+One Metratech Center North
+Brocktyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOO January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAPAYER NUMBER
+LAST STATEMENT
+December 31, 2001
+DEBIT AMOUNT
+15,097.00
+8,011.90
+11,727.54
+16,084.02
+16,848.60
+68,487.38
+33,671.00
+..................
+8,310.00
+11,275.48
+......
+7,622.30
+26,598.76
+24,160.32
+28,196.53
+4,178.00
+32.172.58
+$231,273.29
+$217,511.80
+VB20
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/b0a76fa79bfdf87ea0949390e82f2f368bb5d9a8a05dd2309c4bfcb62b2c497e.receipt.json b/vision-fixhub/ds9-unparsed-05/b0a76fa79bfdf87ea0949390e82f2f368bb5d9a8a05dd2309c4bfcb62b2c497e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..320e54e38da374412faa8d0223f87b2ece764886
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b0a76fa79bfdf87ea0949390e82f2f368bb5d9a8a05dd2309c4bfcb62b2c497e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -33654,
+  "dataset": "marble-joined",
+  "doc_id": "b0a76fa79bfdf87ea0949390e82f2f368bb5d9a8a05dd2309c4bfcb62b2c497e",
+  "engine": "marble-apple-vision",
+  "event_count": 240,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "ecc906428985cea0784d20510164c3ff4401bbcfdfd96654656242df12505d6a",
+  "output_sha256": "d8945072966e61267228e41262999cada5159f42535ff9d21b3dc4e2cb7435c3",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b120b5e647496167a0bbcc6e4ffc1aa493b742aa291271475f3478ed9f6698e3.md b/vision-fixhub/ds9-unparsed-05/b120b5e647496167a0bbcc6e4ffc1aa493b742aa291271475f3478ed9f6698e3.md
new file mode 100644
index 0000000000000000000000000000000000000000..e6632fe6f91ca1f0006f0acfdaf569acadb98a0c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b120b5e647496167a0bbcc6e4ffc1aa493b742aa291271475f3478ed9f6698e3.md
@@ -0,0 +1,624 @@
+relalos stomacatkowitz
+
+
+99 N.E. 4'* Street
+Miami, FL 33132-2111
+(305) 961-9299
+Facsimile: (305) 530-6444
+December 6, 2007
+DELIVERY BY FACSIMILE
+Jay P. Lefkowitz, Esq.
+Kirkland & Ellis LLP
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4675
+Re: Jeffrey Epstein
+Dear Jay:
+I write in response to your recent e-mails and letters regarding victim notification and other
+issues. Our Office is trying to perform our contractual obligations under the Agreement, which we
+feel are being frustrated by defense counsel's objections. The Office also is concerned about Mr.
+Epstein's nonperformance.
+More than three weeks ago we spoke about the failure to set a timely plea and sentencing
+date. At that time, you assured me that the scheduling delay was caused by the unavailability of
+Judge McSorley. You promised that a date would be set promptly. On November 15th, Rolando
+Garcia met with Barry Krisher on another matter, and was told by Mr. Krisher that he had just
+spoken with Jack Goldberger, and that Mr. Epstein's plea and sentencing were set to occur on
+December 14, 2007. Since that time, we have tried to confirm the date and time of the hearing in
+order to include that information in the victim notification letters. You continue to refer to the plea
+and sentencing as though it will be in January; Mr. Krisher's office has not confirmed any date; and
+Mr. Goldberger recently told Marie Villafaña that "there is no date."
+I must reiterate that a delayed guilty plea and sentencing - now more than two months
+beyond the original deadline - is unacceptable to the Office. As you will recall, the plea and
+sentencing hearing originally was to occur in early October 2007, but was delayed until October 26th
+to allow Mr. Goldberger to attend. It was delayed again until November to allow you to attend.
+Rather than using your best efforts to insure that the plea and sentencing occur in November, we
+recently learned that a plea conference had been scheduled with Judge MeSorley for November 20,
+2007, but was canceled at the request of the parties, not the judge. Judge McSorley has not been
+away for any extended period, and there is no basis for your assertion that the judge is the cause of
+
+
+
+any past or future delay. Mr. Epstein currently has four Florida Bar members on his defense team,
+so attorney scheduling is not an adequate basis for delay.
+Three weeks ago I also asked you to provide our Office with the terms of the Plea Agreement
+with the State Attorney's Office. It is now more than two months since the signing of the Non-
+Prosecution Agreement and we have yet to see any formal agreement, or even a list of essential terms
+of such an agreement.
+Next, let me address your allegation that attorneys in our office and agents of the FBI have
+leaked information to the press in an effort to affect possible civil litigation with Mr. Epstein. This
+is untrue. There has been no contact between any member of the press and any employee of our
+office or the FBI since you incorrectly accused investigators of telling "Vanity Fair" about Mr.
+Starr's employment by Mr. Epstein several months ago. We intend to continue to refrain from
+commenting or providing information to the press. We would ask that your client and all of his
+representatives do the same.
+I also want to address your interpretation of several statements that were included in
+correspondence - at your insistence - as proof that the designated victims have invalid claims. Let
+me make clear that each of the listed individuals are persons whom the Office identified as victims
+as defined in Section 2255, that is, as persons "who, while a minor, was a victim of a violation of
+section ... 2422 or 2423 of this title." In other words, the Office is prepared to indict Mr. Epstein
+based upon Mr. Epstein's "interactions" with these individuals.' This conclusion is based upon a
+thorough and proper investigation - one in which none of the victims was informed of any right to
+receive damages of any amount prior to the investigation of her claim. The Office agrees that it is
+not a party to, and will not take a role in, any civil litigation, but the Office can say, without
+hesitation, that the evidence demonstrates that each person on the list was a victim of Mr. Epstein's
+criminal behavior. Mr. Star's letter also suggests that the number of victims to whom Mr. Epstein
+is exposed by the Agreement is limitless. As you know, early drafts of the Agreement contained a
+numerical limit of 40 victims, which was removed at your request. The Office repeatedly confirmed
+that the number would not exceed 40; and the list is significantly shorter than that. Once the list is
+provided to you, if you have a good faith basis for asserting that a victim never met Mr. Epstein, we
+remain willing to listen and to modify the list if you convince us of your position.
+Finally, let me address your objections to the draft Victim Notification Letter. You write that
+you don't understand the basis for the Office's belief that it is appropriate to notify the victims.
+Pursuant to the "Justice for All Act of 2004," crime victims are entitled to: "The right to reasonable,
+accurate, and timely notice of any public court proceeding ... involving the crime" and the "right
+'Unlike the State's investigation, the federal investigation shows criminal conduct by Mr.
+Epstein at least as early as 2001, so all of the victims were minors at the time of the offense.
+
+
+
+not to be excluded from any such public court proceeding ..." 18 U.S.C. § 3771(a)(2) & (3).
+Section 3771 also commands that "employees of the Department of Justice ... engaged in the
+detection, investigation, or prosecution of crime shall make their best efforts to see that crime victims
+are notified of, and accorded, the rights described in subsection (a)." 18 U.S.C. § 3771(c)(1).
+Additionally, pursuant to the Victims' Rights and Restitution Act of 1990, our Office is
+obligated to "inform a victim of any restitution or other relief to which the victim may be entitled
+under this or any other law and [the] manner in which such relief may be obtained." 42 U.S.C. §
+10607(c)(1)(B). With respect to notification of the other information that we propose to disclose,
+the statute requires that we provide a victim with the earliest possible notice of: the status of the
+investigation; the filing of charges against a suspected offender; and the acceptance of a plea. 42
+U.S.C. § 10607(c)(3). Just as in 18 U.S.C. § 3771, these sections are not limited to proceedings in
+a federal district court. Our Non-Prosecution Agreement resolves the federal investigation by
+allowing Mr. Epstein to plead to a state offense. The victims identified through the federal
+investigation should be appropriately informed, and our Non-Prosecution Agreement does not
+require the U.S. Attorney's Office to forego its legal obligations.
+With respect to your assertion that we are seeking to "federalize" the state plea, our office
+the State Attorney's Office so that ASA Belohlavek can determine which, if any, statements are
+appropriate to file with the Court.
+Next, you assert that our letter mischaracterizes Mr. Epstein's obligation to pay damages to
+the victims. To avoid that suggestion, I have asked AUSA Villafaña to simply quote the terms of
+the Agreement directly into the Notification Letter. We also have no objection to referring to Mr.
+Epstein as a "sexual offender" rather than a "predator."
+We have no objection to using the conjunction "and/or" in referring to the particular
+offense(s) of which the recipient was a victim. We will not include the language that we take no
+position as to the validity of any claims. While the Office has no intention to take any position in
+any civil litigation arising between Mr. Epstein and any individual victim, as stated above, the Office
+believes that it has proof beyond a reasonable doubt that each listed individual was a victim of Mr.
+Epstein's criminal conduct while the victim was a minor. The law requires us to treat all victims
+"with fairness and with respect for the victim's dignity and privacy." 18 U.S.C. § 3771(a)(8). We
+will not include any language that demeans the harm they may have suffered.
+The letter's assertions regarding representation by the Podhurst firm and Mr. Josefsberg are
+accurate. Judge
+conferred with Messrs. Podhurst and Josefsberg to insure their willingness
+to undertake this assignment prior to finalizing his selection.
+
+
+
+Lastly, you object to personal communication between the victims and federal attorneys or
+agents. We have no objection to sending the letters through the mail? but we will not remove the
+language about contacting AUSA Villafaña or Special Agent Kuyrkendall with questions or
+concerns. Again, federal law requires that victims have the "reasonable right to confer with the
+attorney for the Government in this case." 18 U.S.C. § 3771(a)(5). The three victims who were
+notified prior to your objection had questions directed to Mr. Epstein's punishment, not the civil
+litigation. Those questions are appropriately directed to law enforcement. If questions arise related
+to the civil litigation, AUSA Villafaña and Special Agent Kuyrkendall will recommend that the
+victims direct those questions to Mr. Josefsberg.
+I have attached a revised letter incorporating the changes on which we can agree. Please
+provide any further comments by the close of business on Friday. In addition, please provide us with
+a definitive statement, signed by your client, of his intention to abide by each and every term of the
+Agreement by close of business on Friday, December 7, 2007. By that time, you must also provide
+us with the agreements) with the State Attorney's Office and a date and time certain for the plea and
+sentencing, which must occur no later than December 14, 2007. There must be closure in this
+matter.
+Sincerely,
+R. Alexander Acosta
+By:
+First Assistant United States Attorney
+Enclosure
+cc:
+R. Alexander Acosta, U.S. Attorney
+AUSA A. Marie Villafaña
+"This is contingent, however, on being able to provide adequate notice of the change of
+plea and sentencing. The sooner that you schedule that hearing with Judge MeSorley, the sooner
+we can dispatch these letters. If you delay further, we will have to rely on telephone or personal
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+December 6, 2007
+DELIVERY BY UNITED STATES MAIL
+Miss
+Re:
+Crime Victims' Rights - Notification of Resolution of Epstein Investigation
+Dear Miss
+Several months ago, I provided you with a letter notifying you of your rights as a
+victim pursuant to the Justice for All Act of 2004 and other federal legislation, including:
+(1)
+(2)
+(3)
+(4)
+(5)
+(б)
+(7)
+(8)
+involving release, plea, or sentencing.
+The reasonable right to confer with the attorney for the United States in the
+case.
+The right to full and timely restitution as provided in law.
+The right to proceedings free from unreasonable delay.
+The right to be treated with fairness and with respect for the victim's dignity
+and privacy.
+I am writing to inform you that the federal investigation of Jeffiey Epstein has been
+completed, and that Mr. Epstein and the U.S. Attorney's Office have reached an agreement
+containing the following terms.
+
+
+MISS
+PAGE 2
+First, Mr. Epstein agrees that he will plead guilty to two state offenses, including the
+offense of soliciting minors to engage in prostitution, which will require him to register as
+a sexual offender for the remainder of his life.
+Second, Mr. Epstein has agreed to make a binding recommendation of 18 months'
+imprisonment to the state court judge who sentences him. Mr. Epstein will serve that
+sentence of imprisonment at the Palm Beach County Jail.
+Third, Mr. Epstein has agreed that he will compensate you for damages you have
+suose clims read as loving circumsiances. That portion of the agreement that relates to
+The United States shall provide Epstein's attorneys with a list of
+individuals whom it has identified as victims, as defined in 18 U.S.C.
+§ 2255, after Epstein has signed this agreement and been sentenced.
+Upon the execution of this agreement, the United States, in consultation
+with and subject to the good faith approval of Epstein's counsel, shall
+select an attorney representative for these persons, who shall be paid for
+by Epstein. Epstein's counsel may contact the identified individuals
+through that representative.
+8.
+If any of the individuals referred to in paragraph (7), supra, elects to
+5, Epstein will not contest the
+firi suit purst the toiled States Districs our eir thill outer Distinc
+9.
+Epstein, so long as the identified individual elects to proceed
+exclusively under 18 U.S.C. § 2255, and agrees to waive any other
+claim for damages, whether pursuant to state, federal, or common law.
+Notwithstanding this waiver, as to those individuals whose names
+appear on the list provided by the United States, Epstein's signature on
+this agreement, his waivers and failures to contest liability and such
+damages in any suit are not to be construed as an admission of any
+criminal or civil liability.
+Epstein's signature on this agreement also is not to be construed as an
+admission of civil or criminal liability or a waiver of any jurisdictional
+
+
+MISS
+PAGE 3
+10.
+or other defense as to any person whose name does not appear on the
+list provided by the United States.
+Except as to those individuals who elect to proceed exclusively under
+18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's
+signature on this agreement, nor its terms, nor any resulting waivers or
+settlements by Epstein are to be construed as admissions or evidence of
+divine as to any patin, ore earn of er yami appear on othet
+Pursuant to the terms of the agreement and an addendum, to assist you in making such
+a claim, the U.S. Attorney's Office has asked an independent Special Master to select
+attorneys to represent you. Those attorneys are Aaron Podhurst and Robert ("Bob")
+Josefsberg with the law firm of Podhurst Orseck, P.A. They can be reached at (305) 358-
+2800. I anticipate that someone from their law firm will be contacting you shortly. Lmust
+also advise you that you are not obligated to use these attorneys. In fact, you have the
+absolute right to select your own attorney, so you can decide not to speak with Messrs.
+Podhurst/Josefsberg at all, or you can speak with them and decide at any time to use a
+different attorney. If you do decide to seek damages from Mr. Epstein and you decide to use
+Messrs. Podhurst/Josefsberg as your attorneys, Mr. Epstein will be responsible for paying
+attorney's fees incurred during the time spent trying to negotiate a settlement. If you are
+unable to reach a settlement with Mr. Epstein, you and Mr. Josefsberg can discuss how best
+to proceed.
+As I mentioned above, as part of the resolution of the federal investigation, Mr.
+Epstein has agreed to plead guilty to state charges. Mr. Epstein's change of plea and
+sentencing will occur on December 14, 2007, at
+_a.m., before Judge Sandra K.
+McSorley, in Courtroom 11F at the Palm Beach County Courthouse, 205 North Dixie
+Highway, West Palm Beach, Florida. Pursuant to Florida Statutes Sections 960.001(1)(k)
+and 921.143(1), you are entitled to be present and to make a statement under oath. If you
+choose, you can submit a written statement under oath, which may be filed by the State
+Attorney's Office on your behalf. If you elect to prepare a written statement, it should
+address the following:
+the facts of the case and the extent of any harm, including social,
+psychological, or physical harm, financial losses, loss of earnings directly or
+indirectly resulting from the crime for which the defendant is being sentenced,
+
+
+MIsS
+PAGE 4
+and any matter relevant to an appropriate disposition and sentence. Fl. Stat.
+921.143(2).
+You also are entitled to notification when Mr. Epstein is released from imprisonment
+at the end of his prison term and/or if he is allowed to participate in a work release program.
+To receive such notification, please provide the State Attorney's Office with the following
+information:
+2.
+3.
+4.
+5.
+Your name
+Your address
+Your home, work, and/or cell phone numbers
+Your e-mail address
+• notation of whether you would like to participate in the "VINE system.
+hich provides automated notification calls any time an inmate is moved. (T
+use this system, your calls must go to you directly, not through a switchboard.)
+Thank you for all of your help during the course of the investigation. If you have any
+questions or concerns, please do not hesitate to contact me or Special Agent Nesbitt
+Kuyrkendall at (561) 822-5946.
+Sincerely,
+R. Alexander Acosta
+By:
+A. Marie Villafaña
+Assistant United States Attorney
+CC.
+Special Agent Nesbitt Kuyrkendall, F.B.I.
+Ms. Clearetha Wright, Victim-Witness Coordinator, U.S. Attorney's Office
+
+
+12/06/07 THU 15:25 FAX 305 530 6440
+EXECUTIVE OFFICE
+$...
+***
+TX REPORT $**
+*****
+10001
+TRANSMISSION OK
+TX/RX NO
+CONNECTION TEL
+SUBADDRESS
+CONNECTION ID
+ST. TIME
+USAGE T
+PGS.
+RESULT
+3413
+
+12/06 15:22
+03'18
+9
+OK
+UNITED STATES ATTORNEY'S OFFICE
+SOUTHERN DISTRICT OF FLORIDA
+99 NE 4TH STREET
+MIAMI, FLORIDA 33132-2111
+Jeffrey H. Sloman
+First Assistant U.S. Attorney
+305 961 9299
+Cyndee Campos
+Staff Assistant
+305 961 9461
+305 530-6444 fax
+FACSIMILE TRANSMISSION
+COVER SHEET
+DATE:
+TO:
+December 6, 2007
+Jay Lefkowitz, Esquire
+FAX NUMBER:
+SUBJECT:
+Epstein
+NUMBER OF PAGES, INCLUDING THIS PAGE: 9
+
+
+UNITED STATES ATTORNEY'S OFFICE
+SOUTHERN DISTRICT OF FLORIDA
+99 NE 4TH STREET
+MIAMI, FLORIDA 33132-2111
+Jeffrey H. Sloman
+First Assistant U.S. Attorney
+305 961 9299
+Cyndee Campos
+Staff Assistant
+305 961 9461
+305 530-6444 fax
+FACSIMILE TRANSMISSION
+COVER SHEET
+DATE:
+December 6, 2007
+TO:
+Jay Lefkowitz, Esquire
+FAX NUMBER:
+SUBJECT:
+Epstein
+NUMBER OF PAGES, INCLUDING THIS PAGE: 9
+Message/Comments:
+(Includes Victim Notification Letter)
+This facsimile contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the
+original facsimile to us at the above address via the U.S. Postal Service. Thank you.
+
+
+geffetr
+99 N.E. 4* Street
+Miami, FL 33132-2111
+(305) 961-9299
+Facsimile: (305) 530-6444
+November 30, 2007
+DELIVERY BY FACSIMILE
+Jay P. Lefkowitz, Esq.
+Kirkland & Ellis LLP
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4675
+Re: Jeffrey Epstein
+Dear Jay:
+I write in response to your recent e-mails and letters regarding victim notification and other
+issues. Some of these issues also are addressed in the U.S. Attorney's letter to Mr. Starr, but in light
+of our discussions, I believe a separate response is needed.
+In a recent e-mail, you write that you were surprised at the tone of my e-mail of November
+27, 2007. That tone was engendered by the roadblocks that you continue to erect as we try to
+perform our contractual obligations coupled with Mr. Epstein's nonperformance. This letter and
+U.S. Attorney Acosta's letter setforth the last opportunity for your client and his entire defense team
+to conform unwaveringly to all of the terms of the Non-Prosecution Agreement. As stated by the
+U.S. Attorney in his letter:
+Accordingly, please provide us with a definitive statement, signed by your client, of
+his intention to abide by each and every term of the Agreement by close of business
+on Tuesday, December 4, 2007. By that time, you must also provide us with the
+agreements) with the State Attorney's Office and a date and time certain for the plea
+and sentencing, which must occur no later than December 14, 2007. If we do not
+receive these items by that time, we will deem the agreement to be rescinded and will
+proceed with the prosecution. There must be closure in this matter.
+Before I address your continued allegations of some sort of misconduct on the part of the
+'Office for trying to abide by both its legal and contractual obligations, I must address your client's
+failures to comply with the Agreement.
+
+
+
+Three weeks ago we spoke about the failure to set a timely plea and sentencing date. At that
+time, you assured me that the scheduling delay was caused by the unavailability of Judge MeSorley.
+You promised that a date would be set promptly. On November 15th, Rolando Garcia met with
+Barry Krisher on another matter, and was told by Mr. Krisher that he had just spoken with Jack
+Goldberger, and that Mr. Epstein's plea and sentencing were set to occur on December 14, 2007.
+Since that time, we have tried to confirm the date and time of the hearing in order to include that
+information in the victim notification letters. You continue to refer to the plea and sentencing as
+though it will be in January; Mr. Krisher's office has not confirmed any date; and Mr. Goldberger
+told Marie Villafaña that "there is no date."
+I have repeatedly told you that a delayed guilty plea and senteneing - now more than two
+months beyond the original deadline - is unacceptable to the Office. Contrary to your past
+assertions, the Non-Prosecution Agreement does not contemplate a staggered plea and sentencing.
+Instead, the Agreement contemplates a combined plea and sentencing followed by a later surrender
+date for Mr. Epstein to begin serving his jail sentence. As you will recall, the plea and sentencing
+hearing originally was to occur in early October 2007, but was delayed until October 26th to allow
+Mr. Goldberger to attend. It was delayed again until November to allow you to attend. You have
+provided no showing of how you and your client have used your best efforts to insure that the plea
+and sentencing occur in November. In fact, we recently learned that a plea conference had been
+scheduled with Judge MeSorley for November 20, 2007, but was canceled at the request of the
+parties, not the judge. Judge McSorley has not been away for any extended period, and there is no
+basis for your assertion that the judge is the cause of any past or future delay. Mr. Epstein currently
+has four Florida Bar members on his defense team, so attorney scheduling is not an adequate basis
+for delay.
+Three weeks ago I also asked you to provide our Office with the terms of the Plea Agreement
+with the State Attorney's Office. It is now more than two months since the signing of the Non-
+Prosecution Agreement and we have yet to see any formal agreement, or even a list of essential terms
+of such an agreement. The only conclusion that we can draw is that you are trying to avoid providing
+the Office with adequate time to review your agreement prior to the change of plea and sentencing
+to determine whether Mr. Epstein is complying with the terms of the Non-Prosecution Agreement.
+Your letters make reference to a failure by the United States to abide by the "spirit" of the
+Agreement, but recent correspondence shows that Mr. Epstein hopes to serve his sentence on "work
+release." This is plainly contrary to both the terms and spirit of the Agreement. The Agreement
+clearly indicates that Mr. Epstein is to be incarcerated, and during your joint meeting with
+representatives of our office and the State Attorney's Office, the parties specifically discussed that
+Mr. Epstein would serve his time in solitary confinement at the Palm Beach County Jail to obviate
+your safety concerns. In addition to the terms of the Agreement, the Florida Department of
+Corrections does not allow persons who are registered sex offenders to participate in "community
+release" (which includes "work release"). Since Mr. Epstein will have to register as a sex offender
+
+
+
+promptly after his guilty plea and sentencing, he will not be eligible for such a program. Thus, the
+U.S. Attorney's Office is simply putting you on notice that it intends to make certain that Mr. Epstein
+is "treated no better and no worse than anyone else" convicted of the same offense. If Mr. Epstein
+is somehow allowed to participate in a work release program despite the Department of Corrections'
+rules and practices, the Office intends to investigate the reasons why an exception was granted in Mr.
+Epstein's case.
+Isentitledtolearn
+Next, let me address various accusations that you and Mr. Starr, amongst others, have raised.
+You have repeatedly alleged that attorneys in our office and agents of the FBI have leaked
+information to the press in an effort to affect possible civil litigation with Mr. Epstein. This is
+untrue. There has been no contact between any member of the press and any employee of our office
+or the FBI since you incorrectly accused investigators of telling "Vanity Fair" about Mr. Starr's
+employment by Mr. Epstein several months ago. As you have been told before, prior to that, the
+press had provided information to the FBI, but no comment was ever made about the ongoing
+investigation, it was simply referred to as an "open investigation." Your accusations on this point
+are ironic in light of the amount of information that Mr. Epstein's team has provided to the press,
+much of which is completely inaccurate and which is obviously intended to intimidate your client's
+victims. We intend to continue to refrain from commenting or providing information to the press.
+We would ask that your client and all of his representatives do the same.
+Mr. Starr's letter to Assistant Attorney General Alice Fisher contains several false statements
+and accusations. First, Mr. Epstein was never forced to enter into any agreement and all terms of
+the agreement were fully negotiated, including the terms regarding the payment of monetary damages
+to the victims under 18 U.S.C. § 2255. In fact, some of those terms were re-negotiated as part of the
+Addendum. Second, if Mr. Epstein's cadre of attorneys was concerned about a way to test the
+validity of the victims' claims prior to placing the names of those victims on the list prepared by our
+office, that term could have been negotiated. In fact, at one of our carly meetings, Roy Black raised
+that concern, and possible solutions were contemplated by our office prior to the negotiations.
+However, since none of Mr. Epstein's team of attorneys requested the inclusion of such a term, it
+was omitted from the Agreement.
+To the extent that you now object to the Agreement that you negotiated, this is akin to
+"buyer's remorse." However, you and Mr. Starr have, instead, made claims to the Justice
+Department that these thoroughly negotiated terms "leave[] wide open the opportunity for
+misconduct by federal investigators." You then misinterpret several statements that were included
+in correspondence - at your insistence - as proof that the designated victims have invalid claims.
+Let me make clear that each of the listed individuals are persons whom the Office identified as
+victims as defined in Section 2255, that is, as persons "who, while a minor, was a victim of a
+violation of section ... 2422 or 2423 of this title." In other words, the Office is prepared to indict
+Mr. Epstein based upon what Mr. Starr refers to as Mr. Epstein's "interactions" with these
+individuals. This conclusion is based upon a thorough and proper investigation - one in which none
+
+
+
+of the victims was informed of any right to receive damages of any amount prior to the investigation
+of her claim. Each of the victims' claims was corroborated — again, prior to anyone being notified
+of a potential civil claim for damages. In fact, after the Agreement was signed, the FBI only had the
+opportunity to inform three victims of the resolution of the matter before you raised complaints and,
+in deference to your request, the Office asked that they defer further notifications. The Office agrees
+that it is not a party to, and will not take a role in, any civil litigation, but the Office can say, without
+nesitation, thatyeach person on the list was a victim of Mr. Epstein's criminal behavior
+he evidence dennonstrates that
+Mr. Starr's letter also suggests that the number of victims to whom Mr. Epstein is exposed
+by the Agreement is limitless. As you know, early drafts of the Agreement contained a numerical
+limit of 40 victims. At your request, that number was removed. The Office repeatedly confirmed
+that the number would not exceed 40; after conducting additional investigation, it was reduced to
+34, and we recently removed another name because, despite the fact that Mr. Epstein offensively
+touched the victim, in our opinion, the touching was not "sexual" enough to properly include her as
+a victim as defined in Section 2255. Once the list is provided to you, if you have a good faith basis
+for asserting that a victim never met Mr. Epstein, we remain willing to listen and to modify the list
+if you convince us of your position.
+Mr. Starr also asserts that the Office has "improperly insisted that the chosen attorney
+representative should be able to litigate the claims of individuals, which violates the terms of the
+Agreement and deeply infringes upon the spirit and nature of the Agreement." Again, this was a
+term that could have been discussed and negotiated prior to entering into the Agreement. At least
+five extremely experienced attorneys reviewed the Agreement prior to its execution. Your failure
+to consider what would happen if a victim refused to accept the minimum settlement you offered to
+her does not render the Agreement void, unconscionable, or violative of Due Process. Whether
+counsel for the victims decides that there is a conflict is something to be addressed by him, but the
+Agreement speaks for itself.
+Finally, let me address your objections to the draft Victim Notification Letter. You write that
+you don't understand the basis for the Office's belief that it is appropriate to notify the victims. The
+"Justice for All Act of 2004" amended Title 18 by adding Section 3771, entitled "Crime victims'
+rights." Those rights include: "The right to reasonable, accurate, and timely notice of any public
+court proceeding ... involving the crime" and the "right not to be excluded from any such public
+court proceeding..." 18 U.S.C. § 3771(a)(2) & (3). Inour opinion, the broad language of Section
+3771 encompasses the change of plea and sentencing of Mr. Epstein, especially because Section
+3771 uses the term "distriet court" when it seeks to limit its application to a foderal distriet court
+proceeding. Section 3771 also commands that "employees of the Department of Justice... engaged
+in the detection, investigation, or prosecution of crime shall make their best efforts to see that crime
+victims are notified of, and accorded, the rights described in subsection (a)." 18 U.S.C. § 3771(c)(1).
+Additionally, the Victims' Rights and Restitution Act of 1990 enacted Title 42, United States
+thing
+happened'
+
+
+
+Code, Section 10607, entitled "Services to victims." Pursuant to that statute, our Office is obligated
+to "inform a victim of any restitution or other relief to which the victim may be entitled under this
+or any other law and [the] manner in which such relief may be obtained." 42 U.S.C. §
+10607(c)(1)(B).! With respect to notification of the other information that we propose to disclose,
+the statute requires that:
+(3)
+During the investigation and prosecution of a crime, a responsible official
+shall provide a victim the earliest possible notice of -
+(A) the status of the investigation of the crime, to the extent it is
+appropriate to inform the victim and to the extent that it will not
+interfere with the investigation;..
+(C) the filing of charges against a suspected offender; ...
+(F)
+the acceptance of a plea of guilty or nolo contendere or the rendering
+of a verdict after trial.
+42 U.S.C. § 10607(c)(3). Again, these sections are not limited to proceedings in a federal district
+court. Our Non-Prosecution Agreement resolves the federal investigation by allowing Mr. Epstein
+to plead to a state offense. The victims identified through the federal investigation should be
+appropriately informed, and our Non-Prosecution Agreement does not and cannot require the U.S.
+Attorney's Office to forego its legal obligations. As noted, Section 10607 commands our office to
+make these notifications at "the earliest possible opportunity." The unnecessary delays engendered
+by your continued objections to the Office's performance of its contractual and legal obligations will.
+•no longer be tolerated. must eno
+Your claim that, by notifying victims of their legal rights, we are seeking to "federalize" the
+state plea is incorrect. Our office is simply informing the victims of their rights. It does not
+command them to appear at the hearing or to file a victim impact statement. In fact, the letter
+recommends the sending of any statement to the State Attorney's Office so that ASA Belohlavek can
+determine which, if any, statements are appropriate to file with the Court.
+Next, you assert that our letter mischaracterizes Mr. Epstein's obligation to pay damages to
+the victims. It does not. The Agreement provides:
+If any of the [identified victims] elects to file suit pursuant to 18 U.S.C. § 2255,
+'Based upon the language of this statute, your statement that our notification must be
+limited only to the right to restitution is incorrect.
+
+
+NovEMBER 30, 2007
+
+Epstein will not contest the jurisdiction of the United States District Court for the
+Southern District of Florida over his person and/or the subject matter, and Epstein
+waives his right to contest liability up to an amount as agreed to between the
+identified individual and Epstein, so long as the individual elects to proceed
+exclusively under 18 U.S.C. § 2255 and agrees to waive any other claim for damages,
+whether pursuant to state, federal, or common law.
+Contrary to your assertion, this Agreement specifically contemplates possible litigation - it would
+be nonsensical to include a waiver of personal jurisdiction in the District Court if the Agreement was
+supposed to bar any victim from filing suit. A violation of this provision, by contesting jurisdiction
+or otherwise, will be considered a material breach.
+It had been my suggestion to AUSA Villafaña that we simply quote the terms of the
+Agreement directly into the Notification Letter or include a photocopy of the relevant sections. If
+you would prefer that we proceed in that manner, that is acceptable. We also have no objection to
+referring to Mr. Epstein as a "sexual offender" rather than a "predator."
+Your objection to the use of the term "minor victim" is unfounded. The letter states that the
+United States has identified the person as a "minor victim," and Section 2255 requires that the victim
+be a minor at the time of the commission of the offense. As I stated above, each and every person
+contained in our list was a "minor victim" as defined in Section 2255. The federal investigation
+found that Mr. Epstein's illegal conduct occurred at least as early as 2001, so all of the victims were
+minors at the time of the criminal conduct. Our "imprimatur" is neither incendiary nor unwarranted.
+We have no objection to using the conjunction "and/or" in referring to the particular
+offense(s) of which the recipient was a victim. We will not include the language that we take no
+position as to the validity of any claims. While the Office has no intention to take any position in
+any civil litigation arising between Mr. Epstein and any individual victim, as stated above, the Office
+believes that it has proof beyond a reasonable doubt that each listed individual was a victim of Mr.
+Epstein's criminal conduct while the victim was a minor. The law requires us to treat all victims
+"with fairness and with respect for the victim's dignity and privacy." 18 U.S.C. § 3771(a)(8). We
+will not include any language that demeans the harm they have suffered. Our Office's obligation to
+remain uninvolved in the civil litigation cannot be used by your client as both a shield and a sword.?
+Thus, while we will not involve ourselves in the civil litigation, we will not allow you to use that
+neutrality to create a false impression that we do not believe in the validity of the victims' claims.
+2You may want to review United States |. Crompton Corp., 399 F. Supp. 2d 1047 (N.D.
+Cal. 2005), where the district court would not allow an unindicted co-conspirator to have his
+name redacted from a plea agreement in order to assist him in defending or avoiding civil claims.
+
+
+
+The letter's assertions regarding representation by the Podhurst firm and Mr. Josefsberg are
+accurate and will not be changed. Judge
+conferred with Messrs. Podhurst and Josefsberg to
+insure their willingness to undertake this assignment prior to finalizing his selection. As I stated in
+my earlier correspondence, there is no legitimate basis for you to object to the firm or the individual
+attorney. Also, contrary to your assertion, the Podhurst firm was recommended to you as early as
+October 5th, as one of the firms that should be included on a list of firms for Judge
+to consider
+in making his selection. No further investigation is required and attempts to convince Messrs.
+Podhurst and Josefsberg to rescind their agreement to undertake this assignment would be yet
+another example of your attempts to stop the United States from effectuating the terms of the Non-
+Prosecution Agreement.
+Lastly, you object to personal communication between the victims and federal attorneys or
+agents. We have no objection to sending the letters through the mail' but we will not remove the
+language about contacting AUSA Villafaña or Special Agent Kuyrkendall with questions or
+concerns. Again, federal law requires that victims have the "reasonable right to confer with the
+attorney for the Government in this case." 18 U.S.C. § 3771(a)(5). We will not undermine that
+right. The three victims who were notified prior to your objection had questions directed to Mr.
+Epstein's punishment, not the civil litigation. Those questions are appropriately directed to law
+enforcement. If questions arise related to the civil litigation, AUSA Villafaña and Special Agent
+Kuyrkendall will recommend that the victims direct those questions to Mr. Josefsberg.
+I have attached a revised letter incorporating the changes on which we can agree. Please
+provide any further comments by the close of business on Tuesday.
+Sincerely,
+R. Alexander Acosta
+By:
+Jeffrey Sloman
+First Assistant United States Attorney
+cc:
+R. Alexander Acosta, U.S. Attorney
+AUSA A. Marie Villafaña
+This is contingent, however, on being able to provide adequate notice of the change of
+plea and sentencing. The sooner that you schedule that hearing with Judge McSorley, the sooner
+we can dispatch these letters. If you delay further, we will have to rely on telephone or personal
+notification.
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/b120b5e647496167a0bbcc6e4ffc1aa493b742aa291271475f3478ed9f6698e3.receipt.json b/vision-fixhub/ds9-unparsed-05/b120b5e647496167a0bbcc6e4ffc1aa493b742aa291271475f3478ed9f6698e3.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..49b06958b597a29e5e2192a25e8692436737d680
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b120b5e647496167a0bbcc6e4ffc1aa493b742aa291271475f3478ed9f6698e3.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1194,
+  "dataset": "marble-joined",
+  "doc_id": "b120b5e647496167a0bbcc6e4ffc1aa493b742aa291271475f3478ed9f6698e3",
+  "engine": "marble-apple-vision",
+  "event_count": 29,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "05b903c4c917047455fc74164c5a6b5bd9ef872226232b1bc0a7b91fad63f9ba",
+  "output_sha256": "c44b41aadfcbd2cba9a8e17c7484d5be3e1afc79ff8ce98f622d898b2a87092d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b1a05c98f41bd36e2d92194c781743de17b84754c1daad70f8ceb4f9d06baa8c.md b/vision-fixhub/ds9-unparsed-05/b1a05c98f41bd36e2d92194c781743de17b84754c1daad70f8ceb4f9d06baa8c.md
new file mode 100644
index 0000000000000000000000000000000000000000..a6bd19e11c2eb9996235a9bb0e8bd34e5ec99ef6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b1a05c98f41bd36e2d92194c781743de17b84754c1daad70f8ceb4f9d06baa8c.md
@@ -0,0 +1,21 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 S. Australian Ave, 4th Floor
+West Palm Beach, Florida 33401
+(561) 820-8711
+A. Marie Villafaña
+Facsimile (561) 820-8777
+FACSIMILE COVER SHEET
+TO: David Peteresak
+FAX NO. 917-849-2172
+PHONE NO. _
+CC: Dennis Block, Esq-
+FAX NO.
+DATE: September 6, 2007
+PHONE NO. _
+# OF PAGES:
+RE:Bear Stearns Subpoena
+FROM: A. MARIE VILLAFANA, Assistant U.S. Attorney
+PHONE NO. 561 209-1047
+COMMENTS:
diff --git a/vision-fixhub/ds9-unparsed-05/b1a05c98f41bd36e2d92194c781743de17b84754c1daad70f8ceb4f9d06baa8c.receipt.json b/vision-fixhub/ds9-unparsed-05/b1a05c98f41bd36e2d92194c781743de17b84754c1daad70f8ceb4f9d06baa8c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b0f5e3095e3e8abc1b1c5e74de0be4d812be47a6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b1a05c98f41bd36e2d92194c781743de17b84754c1daad70f8ceb4f9d06baa8c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "b1a05c98f41bd36e2d92194c781743de17b84754c1daad70f8ceb4f9d06baa8c",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "836be28d802911792db2574e2c850081867d90210b267c40d3dff58bc771063b",
+  "output_sha256": "35ae475227934bef2e396b456249d655577a2ad43e36ba0f6e0ec500f454f304",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b1f47845ecf6380791d17503e4c42ea755d27d864649ecb28dea9f8fcbafaaa5.md b/vision-fixhub/ds9-unparsed-05/b1f47845ecf6380791d17503e4c42ea755d27d864649ecb28dea9f8fcbafaaa5.md
new file mode 100644
index 0000000000000000000000000000000000000000..dc0d97e5023d0fc9a7c3004501dbc38fc6606fc7
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b1f47845ecf6380791d17503e4c42ea755d27d864649ecb28dea9f8fcbafaaa5.md
@@ -0,0 +1,8709 @@
+'Case 9:08-CV-80119-KAM Document 152 Entered on FLSD Docket 06/10/2009 Page 1 of 8
+INITED STATES DISTRICT COUR
+OUTHERN DISTRICT OF FLORID
+CASE NO.: 08-CV-80119-MARRA/JOHNSON
+JANE DOE NO. 2,
+JANE DOE NO. 3,
+CASE NO.: 08-CV-80232-MARRA/JOHNSON
+CASE NO.: 08-CV-80380-MARRA/JOHNSON
+JANE DOE NO. 4,
+JANE DOE NO. 5,
+
+
+Case 9:08-Cv-80119-KAM Document 152
+Entered on FLSD Docket 06/10/2009 Page 2 of 8
+Page 2
+JANE DOE NO. 6,
+JANE DOE NO. 7,
+CASE NO.: 08-80994-CIV-MARRA/JOHNSON
+CASE NO.: 08-80993-CIV-MARRA/JOHNSON
+CASE NO.: 08-80811-CIV-MARRA/JOHNSON
+JEFFREY EPSTEIN et al,
+Defendants.
+DOE II,
+JEFFREY EPSTEIN et al,
+Defendants.
+CASE NO.: 08-80893-CIV-MARRA/JOHNSON
+CASE NO.: 09-80469-CIV-MARRA-JOHNSON
+
+
+'Case 9:08-CV-80119-KAM Document 152
+Entered on FLSD Docket 06/10/2009 Page 3 of 8
+Page 3
+JANE DOE NO. 101,
+CASE NO.: 09-80591-CIV-MARRA-JOHNSON
+JANE DOE NO. 102,
+CASE NO.: 09-80656-CIV-MARRA/JOHNSON
+DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFES JANE DOE NOS. 101 AND 102'S
+MOTION FOR LEAVE TO FILE UNDER SEAL RESPONSE IN OPPOSITION TO
+DEFENDANT'S MOTION TO STAY OR, IN THE ALTERNATIVE, TO UNSEAL THE
+NONPROSECUTION AGREEMENT (dated 5/29/02, IDE 128]
+Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned
+attorneys responds to the Plaintiffs' Jane Doe No. 101 and Jane Doe No. 102 ("Plaintiffs")
+Motion For Leave To File Under Seal Response In Opposition To Defendant's Motion To Stay
+Or, In The Alternative, To Unseal The Nonprosecution Agreement, and states:
+This Court has already entered orders preserving the confidentiality of the Non-
+Prosecution Agreement ("NPA) and denying prior attempts to have the document unsealed. See
+Court's Orders, attached hereto as Exhibit A and Exhibit B, respectively, entered in In Re: Jane
+Does 1 and 2, Petitioners, Case No. 08-80736-CIV-MARRA/JOHNSON, A. Order To Compel
+Production And Protective Order, [DE 26], dated August 21, 2008, and B. Order [DE 36], dated
+February 12, 2009, on Petitioners' Motion To Unseal Non-Prosecution Agreement [DE 28].
+Both of these Orders are clear that the terms of the NPA are to remain confidential and remain
+
+
+'Case 9:08-Cv-80119-KAM Document 152 Entered on FLSD Docket 06/10/2009 Page 4 of 8
+protected from being disclosed to third parties. The NPA is an agreement between the United
+States Attorney's Office and EPSTEIN. Plaintiffs' motion presents nothing in support of this
+Court modifying its prior orders.
+2.
+Significantly, even the United States Attorney's Office (USAO), along with
+Defendant, has strongly opposed making the NPA public. Attached as Exhibit C hereto is
+Respondent United States of America's Opposition To Victims' Motion To Unseal Non-
+Prosecution Agreement, dated October 8, 2008, [DE 29], also filed in In Re: Jane Does 1 and 2,
+Petitioners, Case No. 08-80736-CIV-MARRA/JOHNSON. In opposing the petitioners' attempts
+to make public the terms of the NPA, the United States in the Response, Exhibit C, stated:
+Since the Agreement (NPA) has not been filed under seal with this Court, the
+legal authority cited by petitoners regarding sealing of documents, United States v.
+Ochoa-Vasque, 428 F.3d 1015 (11" Cir. 2005), is inapposite. The parties who
+negotiated the Agreement, the United States Attorney's Office and Jeffrey Epstein,
+determined the Agreement should remain confidential. They were free to do so, and
+violated no law in making such an agreement. Since the Agreement has become
+relevant to the instant lawsuit, petitioners have been given access to it, upon the
+condition that it not be disclosed further. Petitioners have no legal right to disclose
+the Agreement to third parties, or standing to challenge the confidentiality provision.
+After the United States' response, Exhibit C, this Court entered its Order, Exhibit B,
+agreeing with the United States' position and maintaining the confidentiality of the NPA in
+accordance with its prior Order, Exhibit A. The "victims" who were provided a copy of the
+NPA were and are required to maintain the NPA's confidentiality and not disclose the terms to
+third parties.
+3.
+Other parties in the consolidated cases have been able to file their responses
+without a similar request being made. Defendant believes that these Plaintiffs can fully respond
+without the need to file under seal; and reference provisions generally. However if the Court is
+
+
+'Case 9:08-cv-80119-KAM Document 152
+
+inclined to grant this Order, then in order to continue to protect the confidentiality of the NPA
+and to comply with the Court's prior Orders, Exhibit A and Exhibit B, Defendant would agree
+to allow Plaintiff to file under seal her response and reference only those portions (identified
+herein) of the NPA which are potentially relevant to the issues arising under claims brought
+pursuant to 18 U.S.C. §2255 and thus, that may have impact on Defendant's motion for stay and
+Plaintiff's response thereto. Specifically, the only portions relevant for this Court to make a
+decision on Defendant's motion and Plaintiffs' response are paragraphs 7, 8, 9, and10 of the
+NPA, and paragraphs 7A, 7B, and 7C of the Addendum To The NPA.
+WHEREFORE, Defendant requests that this Court enter an Order denying any attempts
+by Plaintiffs to unseal or make public or to disclose to third parties the terms of the NPA, and to
+deny Plaintiffs move to file their response under seal; or if the Court is inclined to grant the
+motion, to allow Plaintiff to file her response to the motion to stay and only the specified
+portions of the NPA and Addendum thereto under seal.
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the
+Cleo it out use de. alo chity that the foregoing documen a brin pered thi
+CM/ECF on this _10th_ day of June , 2009
+Respectfully submited,
+By: _
+ROBERT D, CRITTON, JR., ESQ.
+Florida Bar No.
+MICHAEL J. PIKE, ESQ.
+Florida Bar:
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+
+
+Document 152
+
+1 Phone
+8 Fax
+
+
+Case 9:08-CV-80119-KAM Document 152
+Entered on FLSD Docket 06/10/2009 Page 7 of 8
+Page 7
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/JOHNSON
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+Brad Edwards, Esq.
+Rothstein Rosenfeldt Adler
+401 East Las Olas Boulevard
+Suite 1650
+Fort Landerdale. EL 33301
+Faxe
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No. 08-
+80893
+Counsel for Plaintiffs in Related Cases Nos.
+08-80069, 08-80119, 08-80232, 08-80380, 08-
+80381, 08-80993, 08-80994
+Paul G. Cassell, Esq.
+Pro Hac Vice
+Richard Horace Willits, Esq.
+332 South 1400 E, Room 101
+Richard H. Willits, P.A.
+Salt Lake City, UT 84112
+2290 10" Avenue North
+Suite 404
+Lake Worth, FL 33461
+Co-counsel for Plaintiff Jane Doe
+Counsel for Plaintiff in Related Case No. 08- Isidro M. Garcia, Esq.
+80811
+Garcia Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+I lE
+Jack Scarola, Esq.
+Jack P. Hill, Esq.
+Searcy Denney Scarola Barnhart & Shipley,
+P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+Counsel for Plaintiff in Related Case No. 08-
+80469
+Counsel for Plaintiff.
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, EL 33130
+Fax: h
+
+
+Case 9:08-cv-80119-KAM Document 152
+Entered on FLSD Docket 06/10/2009 Page 8 of 8
+Page 8
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Ricci-Leopold, P.A.
+2925 PGA Blvd., Suite 200
+Malm Beach Gardens, PL 33410
+Counsel for Plaintiff in Related Case No. 08-
+08804
+Counsel for Plaintiffs in Related Cases Nos.
+09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A
+250 Australian Avenue South
+Suite 1400
+
+
+
+JANE DOE NO. 7
+CASE NO.: 08-CV-80993-MARRA-JOHNSON
+DEFENDANT EPSTEIN'S FIRST AMENDED ANSWER & AFFIRMATIVE
+DEFENSES TO PLAINTIFF'S (FIRST) AMENDED COMPLAINT
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his
+undersigned attorneys, files his Answer to Plaintiff's Amended Complaint [DE 19] and
+states:
+1. Without knowledge and deny.
+2. As to the allegations in paragraphs 2, Defendant asserts his Fifth Amendment
+privilege against self-incrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d
+1099 (Fla. 4" DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth
+Amendment's Self-Incrimination Clause applies to the states through the Due Process
+Clause of the Fourteenth Amendment - "it would be incongruous to have different
+standards determine the validity of a claim of privilege based on the same feared
+prosecution, depending on whether the claim was asserted in state or federal court."); 5
+Fed.Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-
+Incrimination ("...court must treat the defendant's claim of privilege as equivalent to a
+specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. -
+
+
+Case 9:08-cv-80993-KAM
+Document 86
+
+Page 2
+"... a civil defendant who raises an affirmative defense is not precluded from asserting
+the privilege [against self-incrimination], because affirmative defenses do not constitute
+the kind of voluntary application for affirmative relief" which would prevent a plaintiff
+bringing a claim seeking affirmative relief from asserting the privilege.
+3. As to the allegations in paragraph 3, deny.
+4. As to the allegations in paragraph 4, deny.
+5. As to the allegations in paragraph 5, without knowledge and deny.
+6. As to the allegations in paragraphs 6, Defendant asserts his Fifth Amendment
+privilege against self-incrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d
+1099 (Fla. 4" DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth
+Amendment's Self-Incrimination Clause applies to the states through the Due Process
+Clause of the Fourteenth Amendment - "ilt would be incongruous to have different
+standards determine the validity of a claim of privilege based on the same feared
+prosecution, depending on whether the claim was asserted in state or federal court."); 5
+Fed.Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-
+Incrimination ("...court must treat the defendant's claim of privilege as equivalent to a
+specific denial.").
+See also 24 Fla.Jur.2d Evidence §592, Defendants in civil actions. -
+"... a civil defendant who raises an affirmative defense is not precluded from asserting
+the privilege [against self-incrimination], because affirmative defenses do not constitute
+the kind of voluntary application for affirmative relief" which would prevent a plaintiff
+bringing a claim seeking affirmative relief from asserting the privilege.
+
+
+Case 9:08-cv-80993-KAM Document 86 Entered on FLSD Docket 06/10/2009 Page 3 of 10
+Page 3
+7. As to the allegations in paragraphs 7 through 15 of Plaintiff's Second Amended
+Complaint, Defendant exercises his Fifth Amendment Privilege against selfincrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4* DCA
+1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-
+Incrimination Clause applies to the states through the Due Process Clause of the
+Fourteenth Amendment - "ilt would be incongruous to have different standards
+determine the validity of a claim of privilege based on the same feared prosecution,
+depending on whether the claim was asserted in state or federal court."); 5 Fed.Prac. &
+Proc. Civ. 3d $1280 Effect of Failure to Deny - Privilege Against Self-Incrimination
+("...court must treat the defendant's claim of privilege as equivalent to a specific
+denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. - "... a civil
+defendant who raises an affirmative defense is not precluded from asserting the
+privilege [against self-incrimination], because affirmative defenses do not constitute the
+kind of voluntary application for affirmative relief" which would prevent a plaintiff bringing
+a claim seeking affirmative relief from asserting the privilege.
+8. In response to the allegations of paragraph 16, Defendant realleges and adopts
+his responses to paragraphs 1 through 15 of the Second Amended Complaint set forth
+in paragraphs 1 through 7 above herein.
+9. Defendant asserts the Fifth Amendment Privilege against self-incrimination to
+the allegations set forth in paragraphs 17 through 22 of the Second Amended
+Complaint. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4'' DCA 1983);
+Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination
+
+
+Case 9:08-cv-80993-KAM Document 86 Entered on FLSD Docket 06/10/2009 Page 4 of 10
+Clause applies to the states through the Due Process Clause of the Fourteenth
+Amendment - "it would be incongruous to have different standards determine the
+validity of a claim of privilege based on the same feared prosecution, depending on
+whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d
+§1280 Effect of Failure to Deny - Privilege Against Self-Incrimination (...court must
+treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24
+Fla.Jur.2d Evidence §592. Defendants in civil actions. - "... a civil defendant who raises
+an affirmative defense is not precluded from asserting the privilege [against selfincrimination], because affirmative defenses do not constitute the kind of voluntary
+application for affirmative relief" which would prevent a plaintiff bringing a claim seeking
+affirmative relief from asserting the privilege.
+10. In response to the allegations of paragraph 23, Defendant realleges and adopts
+his responses to paragraphs 1 through 15 of the Second Amended Complaint set forth
+in paragraphs 1 through 7 above herein.
+11. Defendant asserts the Fifth Amendment Privilege against self-incrimination to
+the allegations set forth in paragraphs 24 through 28 of the Second Amended
+Complaint. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4" DCA 1983);
+Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination
+Clause applies to the states through the Due Process Clause of the Fourteenth
+Amendment - "it would be incongruous to have different standards determine the
+validity of a claim of privilege based on the same feared prosecution, depending on
+whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d
+
+
+Case 9:08-cv-80993-KAM Document 86 Entered on FLSD Docket 06/10/2009
+
+§1280 Effect of Failure to Deny - Privilege Against Self-Incrimination (... court must
+treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24
+Fla.Jur.2d Evidence §592. Defendants in civil actions. - "... a civil defendant who raises
+an affirmative defense is not precluded from asserting the privilege [against selfincrimination], because affirmative defenses do not constitute the kind of voluntary
+application for affirmative relief" which would prevent a plaintiff bringing a claim seeking
+affirmative relief from asserting the privilege.
+12. In response to the allegations of paragraph 29, Defendant realleges and adopts
+his responses to paragraphs 1 through 15 of the Second Amended Complaint set forth
+in paragraphs 1 through 7 above herein.
+13. Defendant asserts the Fifth Amendment Privilege against self-incrimination to
+the allegations set forth in paragraphs 30 through 35 of the Second Amended
+Complaint. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4"* DCA 1983);
+Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination
+Clause applies to the states through the Due Process Clause of the Fourteenth
+Amendment - "It would be incongruous to have different standards determine the
+validity of a claim of privilege based on the same feared prosecution, depending on
+whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d
+§1280 Effect of Failure to Deny - Privilege Against Self-Incrimination ("... court must
+treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24
+Fla.Jur.2d Evidence §592. Defendants in civil actions. - "... a civil defendant who raises
+an affirmative defense is not precluded from asserting the privilege [against self-
+
+
+
+incrimination], because affirmative defenses do not constitute the kind of voluntary
+application for affirmative relief" which would prevent a plaintiff bringing a claim seeking
+affirmative relief from asserting the privilege.
+WHEREFORE, Defendant requests that this Court deny the relief sought by Plaintiff.
+•Affirmative Defenses
+1. As to all counts, Plaintiff actually consented to and was a willing participant in the
+acts alleged, and therefore, her claims are barred, or her damages are required to be
+reduced accordingly.
+2. As to all counts alleged, Plaintiff actually consented to and participated in
+conduct similar and/or identical to the acts alleged with other persons which were the
+sole or contributing cause of Plaintiff's alleged damages.
+3. As to all counts, Plaintiff impliedly consented to the acts alleged by not objecting
+and by going to Defendant's home with other females and/or by bringing other females
+to Defendant's home for which Plaintiff received money, and therefore, her claims are
+barred, or her damages are required to be reduced accordingly.
+4. As to all counts, Defendant reasonably believed or was told that the Plaintiff had
+attained the age of 18 years old at the time of the alleged acts.
+5. As to all counts, Plaintiff's claims are barred as she said she was 18 years or
+older at the time.
+6. As to all counts, Plaintiff's alleged damages were caused in whole or part by
+events and/or circumstances completely unrelated to the incidents) alleged in the
+complaint.
+
+
+Case 9:08-cv-80993-KAM Document 86 Entered on FLSD Docket 06/10/2009
+
+Page 7
+7. Plaintiff's claims are barred by the applicable statute of limitations.
+8. As to Plaintiff's claims for punitive damages in Count | - "Sexual Assault &
+Battery," and Count I| - "Intentional Infliction of Emotional Distress," such claims are
+subject to the limitations as set forth in §768.72, et seq., Florida Statutes.
+9. As to Plaintiff's claims for punitive damages in Count | - "Sexual Assault &
+Battery," and Count II - "Intentional Infliction of Emotional Distress," such claims are
+subject to the constitutional limitations and guideposts as set forth in BMW of North
+America v. Gore, 116 S.Ct 1589 (1996); Philip Morris USA v. Williams, 127 S.Ct. 1057
+(2007); State Farm v. Campbell, 123 S.Ct 1513 (2003); Engle v. Ligget Group, Inc., 945
+So.2d 1246 (Fla. 2006). The Due Process Clause of the Fourteenth Amendment of the
+United States Constitution and Florida's Constitution, Art. I, §S2 and 9, prohibit the
+imposition of grossly excessive or arbitrary punishments
+10. As to Plaintiff's claims for punitive damages in Count | - "Sexual Assault &
+Battery," and Count II - "Intentional Infliction of Emotional Distress," the determination of
+whether or not Defendant is liable for punitive damages is required to be bifurcated from
+a determination of the amount to be imposed.
+11. Plaintiff has failed to state a cause of action for sexual assault and/or battery
+under Count I.
+12. As to Count III, Plaintiff has failed to plead a cause of action as she does not and
+can not show a violation of a predicate act under 18 U.S.C. §2255 (2005).
+
+
+Case 9:08-cv-80993-KAM Document 86 Entered on FLSD Docket 06/10/2009 Page 8 of 10
+Page 8
+13. As to Count IlI, the version of 18 U.S.C. §2255 in effect at the time of the alleged
+conduct applies, and, thus, the presumptive minimum damages amount should Plaintiff
+prove the elements of such claim is $50,000, and not subject to any multiplier.
+14. As to Count III, application of the amended version of 18 U.S.C. §2255, effective
+July 27, 2006, would be in violation of the legal axiom against retroactive application of
+an amended statute, and also in violation of such constitutional principles, including but
+not limited to, the "Ex Post Facto" Clause, U.S. Const. Article I, §9, cl. 3, §10, cl. 1, and
+procedural and substantive due process, U.S. Const. 14" Amend., 5" Amend. The
+statute in effect during the time of the alleged conduct applies.
+15. As to Count III, application of the amended version of 18 U.S.C. §2255, effective
+July 27, 2006, is prohibited pursuant to the vagueness doctrine and the Rule of Lenity.
+A criminal statute is required to give " fair warning ... in language that the common
+world will understand, of what the law intends to do if a certain line is passed. To make
+the warning fair, so far as possible the line should be clear.' " United States v. Lanier,
+520 U.S. 259, 265, 117 S.Ct. 1219, 137 L.Ed.2d 432 (1997) (quoting McBoyle v. United
+States, 283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931)) (omission in original). The
+"three related manifestations of the fair warning requirement" are: (1) the vagueness
+doctrine bars enforcement of a statute which either forbids or requires the doing of an
+act in terms so vague that men of common intelligence must necessarily guess at its
+meaning and differ as to its application; (2) the canon of strict construction of criminal
+statutes, or rule of lenity, ensures fair warning by so resolving ambiguity in a criminal
+statute as to apply it only to conduct clearly covered; (3) due process bars courts from
+
+
+
+Page 9
+applying a novel construction of a criminal statute to conduct that neither the statute nor
+any prior judicial decision has fairly disclosed to be within its scope.
+16. The applicable version of 18 U.S.C. §2255 creates a cause of action on behalf of
+a "minor." Plaintiff had attained the age of majority at the time of filing this action, and
+accordingly, her cause of action is barred.
+17. Because Plaintiff has no claim under 18 U.S.C. §2255, this Court is without
+subject matter jurisdiction as to all claims asserted.
+18. Application of the 18 U.S.C. §2255, as amended, effective July 27, 2006, is in
+violation of the constitutional principles of due process, the "Ex Post Facto" clause, and
+the Rule of Lenity, in that in amending the term "minor" to "person" as to those who may
+bring a cause of action impermissibly and unconstitutionally broadened the scope of
+persons able to bring a §2255 claim.
+19. 18 U.S.C. §2255 violates the Equal Protection Clause of the 14" Amendment
+under the U.S. Constitution, and thus Plaintiff's claim thereunder is barred.
+20. 18 U.S.C. §2255 violates the constitutional guarantees of procedural and
+substantive due process. Procedural due process guarantees that a person will not be
+deprived of life,
+liberty or property without notice and opportunity to be heard.
+Substantive due process protects fundamental rights. Accordingly, Plaintiff's cause of
+action thereunder is barred.
+WHEREFORE Defendant requests that this Court deny the relief sought by Plaintiff.
+Robert D. Critton, Ji
+Attorney før Defendant Epsteir
+
+
+
+Page 10
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami. FL 33160
+Counsel for Plaintiff Jane Doe #7
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+Co-Counsel for Defendant Jeffrey Epstein
+Respectfully submitted,
+By:
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No.
+MICHAEL J. PIKE, ESQ.
+Florida Bar
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+(Co-Counsel for Defendant Jeffrey Epstein)
+
+
+Case 9:08-CV-80119-KAM Document 149
+
+CASE NO.: 08-CV-80119-MARRA/JOHNSON
+JANE DOE NO. 2,
+JANE DOE NO. 3,
+CASE NO.: 08-CV-80232-MARRA/JOHNSON
+CASE NO.: 08-CV-80380-MARRA/JOHNSON
+JANE DOE NO. 4,
+JANE DOE NO. 5,
+
+
+Case 9:08-CV-80119-KAM Document 149
+
+CASE NO.: 08-80994-CIV-MARRA/JOHNSON
+JANE DOE NO. 6,
+CASE NO.: 08-80993-CIV-MARRA/JOHNSON
+JANE DOE NO. 7,
+CASE NO.: 08-80811-CIV-MARRA/JOHNSON
+CASE NO.: 08-80893-CIV-MARRA/JOHNSON
+
+
+Casé 9:08-CV-80119-KAM Document 149
+
+Page 3
+JEFFREY EPSTEIN et al,
+Defendants.
+DOE II,
+CASE NO.: 09-80469-CIV-MARRA-JOHNSON
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+CASE NO.: 09-80591-CIV-MARRA-JOHNSON
+JANE DOE NO. 102,
+CASE NO.:
+09-80656-CIV-MARRA/JOHNSON
+DEFENDANT, JEFFREY EPSTEIN'S REPLY TO JANE DOE NO. 101 AND JANE DOE
+NO. 102'S RESPONSE IN OPPOSITION TO MOTION TO COMPEL AND IDENTIFY
+JANE DOE NUMBERS 101 AND 102 IN THIRD PARTY SUBPOENAS FOR PURPOSES
+OF DISCOVERY
+
+
+Case 9:08-cv-80119-KAM Document 149 Entered on FLSD Docket 06/09/2009
+
+Defendant, Jeffrey Epstein, ("Mr. Epstein"), by and through his undersigned attorneys,
+hereby files his Reply To Jane Doe No. 101 And Jane Doe No. 102's Response In Opposition To
+Motion To Compel and Identify Jane Doe Numbers 101 and 102 in Third Party Subpoenas For
+Purposes of Discovery:
+Plaintiffs' Response in Opposition is set forth in DE 124. Plaintiffs' response is
+drafted in a calculated effort to continue to argue issues relating to 18 U.S.C. 2255 rather than
+deal solely with the issue of identification of the Plaintiffs. Obviously, Plaintiffs' identification
+takes a second seat to Plaintiffs' attempt to continue to argue issues that are or may be set forth
+in their opposition to Epstein's motion to dismiss, which largely deals with issues surrounding 18
+U.S.C. 2255. See Defendant's Motion to Identify Jane Doe 101 [DE 16].
+2.
+In their response, Plaintiffs seem to forget that they brought this lawsuit against
+Epstein. Plaintiffs claim they will suffer physical injury, pain and suffering, emotional distress,
+psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy,
+separation from her family, medical and psychological expenses, loss on income, loss of the
+capacity to earn income in the future, and loss of the capacity to enjoy life. See e.g., 1928,
+Comp., DE 1; see also 1136, 40, 44, 48, 52, 56, 61, 65, and 69, Comp., DE 1. Jane Doe 101 and
+102 came to Defendant's home on a number of occasions. Jane Doe 101 brought her friend,
+(referenced by name in a number of actions) to experience this same "trauma" - it
+does not make sense. Jane Doe 101 had issues associated with law enforcement involving drugs,
+battery, fleeing police; Jane Doe 102 claims to have been raped by two (2) individuals in 1998;
+pre any involvement with Epstein. This type of information is relevant, and Defendant is entitled
+
+
+Case 9:08-cv-80119-KAM Document 149 Entered on FLSD Docket 06/09/2009 Page 5 of 13
+to fully explore it. As such, Plaintiffs' have placed their past and medical history as well as
+education, social, work, interpersonal, recreational legal, criminal and other aspects of their past
+and current lives at issue in light of the allegations they allege in their respective complaints.
+Despite Plaintiffs contention and effort to mislead this court, Epstein does not wish to publicize
+Plaintiffs' names in an effort to embarrass them. On the contrary, Epstein wishes to defend the
+claims made against him and dispute the damages Plaintiffs' claim by conducting discovery.
+Again, Plaintiffs allege substantial economic and non-economic personal injury damages. If this
+Court prevents Epstein from serving Third-Party Subpoenas identifying Plaintiffs, Epstein will
+be denied his due process rights by Plaintiffs in that he will be prevented from conducting broad,
+open and liberal discovery. The undersigned must serve subpoenas on medical doctors to obtain
+medical information related to Plaintiffs' alleged psychological and physical damages and or
+other third parties such as employees for other damages as same goes to the heart of Epstein's
+defenses and Plaintiffs' damages.
+Plaintiffs' intent is to have Epstein try this case without
+having obtained relevant and meaningful discovery. Plaintiff's proposal will chill Defendant's
+ability to fully and fairly access and obtain discovery. See infra.
+3.
+Plaintiffs' counsel are competent trial attorneys well versed in many areas of the
+law, including that of personal injury. Despite the foregoing, Plaintiff's counsel, in some
+highlighted effort to resolve the discovery issues Plaintiffs have intentionally created in an effort
+to chill discovery, offers to provide only the documents that Plaintiffs' counsel obtains from third
+parties through its own selective procedures, and only after Plaintiffs' counsel has been able to
+cull through same.
+
+
+Case 9:08-cv-80119-KAM Document 149 Entered on FLSD Docket 06/09/2009 Page 6 of 13
+4.
+It is hard to believe that any competent law firm responsible to his/her client
+would ever allow an opposing party to request records and provide those records to the
+requesting firm only after the opposing firm had an opportunity to review and filter through
+same. Plaintiffs, in this case, seck thousands if not millions in damages, including physical and
+emotional/mental and personal injury type, and Epstein must and is entitled to conduct his own
+discovery thereon. No valid discovery objections or exemptions exist preventing necessary and
+reasonable discovery. To hold otherwise prevents Mr. Epstein from preparing and defending this
+matter and denies to him his right to fully and fairly defend these cases.
+5.
+Plaintiffs cite a host of cases for the proposition that anonymity should be granted
+when, for instance, a fear of retaliation or ostracism exists. Inconsistent with the cases Plaintiffs
+cite, not once do they state that Plaintiffs will be embarrassed, ostracized, or psychologically and
+emotionally unable to proceed with the action. Even so, embarrassment alone is not enough. See
+Response to Motion to Proceed Anonymously. In determining whether to allow a party to
+proceed with litigation anonymously, a court must consider whether the identification poses a
+risk of retaliatory physical or mental harm to the requesting party or even more critically, to
+innocent non-parties. Doe. No. 2 v. Kolko, 242 F.R.D. 193, 195-98 (E.D.N.Y. 2006), citing,
+Fed. Rules Civ.Proc.Rule 10(a), 28 U.S.C.A. Further, Plaintiffs cite cases wherein a psychologist
+opined that plaintiff suffered or will suffer sever emotional distress. Id. Here, no such affidavit
+has been provided and/or submitted to this court to justify Plaintiff's requests to proceed
+anonymously. Good cause must also be shown in order to proceed anonymously. Good cause
+for a protective order, which Plaintiffs have not filed here, is established upon a showing that
+disclosure will work a clearly defined and serious injury to the party seeking closure; the injury
+
+
+Case 9:08-cv-80119-KAM Document 149
+
+Page 7
+must be shown with specificity. See Doe v. Evans, 202 F.R.D. 173, 176 (E.D. P.A. 2001). Thus,
+Plaintiffs have not met their burden of persuasion. Id. Plaintiffs fail to show good cause in that
+they have not clearly defined what injury they will sustain if not permitted to proceed
+anonymously; they have only offered speculation. Such a failure is fatal to their request to
+proceed anonymously. See infra.
+In Kolko, a case cited by the Defendants, the court specifically found that
+proceeding anonymously (i.e., in the style of the case only) would not inhibit discovery. Here,
+preventing
+Epstein
+from identifying Plaintiffs' in subpoenas and other type discovery
+overwhelmingly inhibits discovery. See Doe v. Evans, 202 F.R.D. at 176 (E.D. P.A. 2001)
+(denying protective order where alleged sexual assault victim did not demonstrate a serious
+specific injury and allowing Defendants to identify Plaintiff in discovery because holding
+otherwise would "chill defendants ability to conduct discovery"). Plaintiffs obviously cannot
+cite one case preventing open and broad discovery or preventing the identification of Plaintiffs in
+third-party subpoenas or in other discovery. While Plaintiffs cite to each of above cases, it is
+misleading for Plaintiffs to suggest the case did not allow for the service of third party subpoenas
+with the correct names.
+Next, Plaintiffs' cite a host of criminal cases and statutes which this court has an
+obligation to distinguish when attempting to in artfully apply same in the civil context. For
+instance, while Fla. Stat. §794.024 and §794.026 appear to prevent the disclosure of the identity
+of a sexual assault victim, Fla. Stat. §794.024 only applies to public employees (and to
+investigations and state prosecutions related to claims of rape) and §794.026 only applies if
+disclosure is being done "with a reckless disregard for the highly offensive nature of the
+
+
+Case 9:08-cv-80119-KAM Document 149 Entered on FLSD Docket 06/09/2009 Page 8 of 13
+Page 8
+publication." Rather, disclosure is being requested in order to properly litigate and defend this
+matter. Further, §794.026 does not (emphasis added) prevent the disclosure of the name of a
+sexual assault victim - it only allows for civil remedy as a result thereof assuming one meets the
+criteria to recover (i.e., disclosure with a reckless disregard for the highly offensive nature of the
+publication). Again, Epstein agreed to enter into a confidentiality agreement and, if required by
+this court, to redact full names from any document filed with the Court.
+8.
+Next, the language of Fla. Stat. §92.56 makes it clear that the statute only applies
+criminal proceedings brought by the State of Florida, not civil proceedings. As set forth by the
+Office of Attorney General, Fla. Stat. §92.56 and Fla. Stat. §794.024 "were created by the Crime
+Victims Protection Act." See 2003 WL 22971082 (Fla. A.G.). Even though Fla. Stat. §92.56
+only applies to criminal proceedings, subsection (2) thereof allows for the accused to apply for
+an order of disclosure to prepare a defense in a criminal proceeding.
+9.
+In addition, Plaintiffs cite to Fed.R.Evid. 412. The Advisory Committee Notes to
+Rule 412, Fed.R.Evid, makes clear that the procedures to determine admissibility of an alleged
+victim's/plaintiff's sexual conduct or activity in civil cases does not apply to discovery of such
+information. Rather, discoverability of such information is governed by Rule 26, Fed.R.Civ.P..,
+pursuant to which the scope of discovery is broad. Rule 412, entitled "Sex Offense Cases;
+Relevance of Alleged Victim's Past Sexual Behavior or Alleged Sexual Predisposition," provides
+in relevant part -
+(a) Evidence generally inadmissible.--The following evidence is not admissible in any
+civil
+... proceeding involving alleged sexual misconduct except as provided in
+subdivisions (b) and (c):
+(1) Evidence offered to prove that any alleged victim engaged in other sexual
+behavior.
+
+
+
+Page 9
+(2) Evidence offered to prove any alleged victim's sexual predisposition.
+(b) Exceptions.-
+*
+(2) In a civil case, evidence offered to prove the sexual behavior or sexual
+admissible only if it has been placed in controversy by the alleged victim.
+(c) Procedure to determine admissibility.--
+(1) A party intending to offer evidence under subdivision (b) must--
+(A) file a written motion at least 14 days before trial specifically describing the
+evidence and stating the purpose for which it is offered unless the court, for good cause
+requires a different time for filing or permits filing during trial; and
+(B) serve the motion on all parties and notify the alleged victim or, when
+appropriate, the alleged victim's guardian or representative.
+(2) Before admitting evidence under this rule the court must conduct a hearing in
+camera and afford the victim and parties a right to attend and be heard. The motion,
+related papers, and the record of the hearing must be sealed and remain under seal
+unless the court orders otherwise.
+In confirming that Rule 412 does not control the discoverability of such information, the
+Advisory Committee Notes (1994 Amendments) state -
+The procedures set forth in subdivision (c) do not apply to discovery of a victim's
+past sexual conduct or predisposition in civil cases, which will be continued to be
+governed by Fed. R. Civ. P. 26. In order not to undermine the rationale of Rule 412,
+however, courts should enter appropriate orders pursuant to fed. R. CIV. P. 20 (c) to
+protect the victim against unwarranted inquiries and to ensure confidentiality. Courts
+should presumptively issue protective orders barring discovery unless the party
+seeking discovery makes a showing that the evidence sought to be discovered
+would be relevant under the facts and theories of the particular case, and cannot
+be obtained except through discovery. In an action for sexual harassment, for
+instance, while some evidence of the alleged victim's sexual behavior and/or
+predisposition in the workplace may perhaps be relevant, non-work place conduct will
+
+
+Entered on FLSD Docket 06/09/2009 Page 10 of 13
+Page 10
+usually be irrelevant. Cf. Burns v. McGregor Electronic Industries, Inc., 989 F.2d 959,
+962-63 (8th Cir. 1993) (posing for a nude magazine outside work hours is irrelevant to
+issue of unwelcomeness of sexual advances at work). Confidentiality orders should be
+presumptively granted as well.
+(Emphasis added).
+In accordance with Rule 412 and Rule 26, Epstein seeks discovery of Plaintiffs' physical,
+emotional and psychological history. We are not at the admissibility phase, which Rule 412
+addresses. We are at the discovery phase, and identification of the Plaintiffs is required in order
+to properly litigate and defend the claims against Epstein. Defendant has no other means of
+obtaining any information about the Plaintiffs' without being permitted to identify Plaintiffs in
+recognized this conundrum and
+third party subpoenas and in discovery. Counsel for
+and other attorneys in the state court cases and in one of the federal
+agreed to identifying
+matters have agreed to serve subpoenas with full indentifying information as long as the
+documents do not disclose the name in the court file. See Exhibit "A".
+WHEREFORE, Defendant, Mr. Epstein, requests this court allow it to identify Plaintiffs
+in the style of this case and that Defendant be permitted to identify Plaintiffs in discovery ang for
+such other and further relief as this court deems just and proper.
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day on all counsel of record identified on the following Service List in the manner specified by
+CM/ECF on this L day of _
+June
+- 2009.
+
+
+Entered on FLSD Docket 06/09/2009 Page 11 of 13
+Page 11
+Respectfully suit
+By:.
+ROBERT-D.
+CRÍTTON, IR., ESQ.
+Florida Bar No.
+MICHAEL J. PIKE, ESQ.
+Florida Bart...
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+I Phone
+& Fax
+
+
+Case 9:08-cv-80119-KAM Document 149
+
+Page 12
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/JOHNSON
+Stuart S. Mermelstein, Esq.
+\dam D. Horowitz, Esq
+Mermelstein & Horowitz, P.A
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+Brad Edwards, Esq.
+Rothstein Rosenfeldt Adler
+401 East Las Olas Boulevard
+Suite 1650
+Fort Lauderdale, FL 33301
+Counsel for Plaintiff in Related Case No. 08-
+80893
+Counsel for Plaintiffs in Related Cases Nos.
+08-80069, 08-80119, 08-80232, 08-80380, 08-
+80381, 08-80993, 08-80994
+Richard Horace Willits, Esq.
+Richard H. Willits, P.A.
+2290 10" Avenue North
+Suite 404
+Lake Worth, FL 33461
+Paul G. Cassell, Esq.
+Pro Hac Vice
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+Co-counsel for Plaintiff Jane Doe
+Counsel for Plaintiff in Related Case No. 08- Isidro M. Garcia, Esq.
+80811
+Garcia Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+Jack Scarola, Esq.
+F
+Jack P. Hill, Esq.
+Searcy Denney Scarola Barnhart & Shipley,
+P.A.
+Soused for Plained in Related Case No. O8.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+Counsel Jor Plainty,
+
+
+
+Page 13
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Ricci-Leopold, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+Counsel for Plaintiff in Related Case No. 08-
+08804
+!!!!!111
+Counsel for Plaintiffs in Related Cases Nos.
+09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+
+
+08/05/2009 10:00 FAX
+@001
+RRA
+FACSIMILE COVER SHEET
+Rothstein Rosenfeldt Adler
+Attorneys ot Law
+TO:
+FAX NUMBER:
+=
+Esq.
+FROM:
+Bradley J. Edwards, Esq. -Susan Stirling |
+DATE:
+June 5, 2009
+RE:
+v. Epstein
+Our File No. 09-22784
+MESSAGE:
+Marie, as you probably know, the Palm Beach Post filed a
+separate Motion to unseal the NPA. We noliced that the Post
+did not notice you personally, so I have enclosed a courtesy
+copy of that Motion and Notice. I hope this finds you well.
+*Please have your assistant let Susan know that you got this
+fax. I understand you are in a new office.
+# OF PAGES 11
+_ (including cover sheet)
+IF YOU DO NOT RECEIVE THE DESIGNATED NUMBER OF PAGES, OR IF YOU EXPERIENCE
+ANY PROBLEM WITH THE TRANSMISSION OF THIS DOCUMENT, PLEASE CALL OUR FAX
+OPERATOR AT
+THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT
+IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL
+AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. IF THE READER OF THIS
+MESSAGE IS NOT THE INTENDED RECIPIENT, OR THE EMPLOYEE OR AGENT RESPONSIBLE
+FOR DELIVERING THE MESSAGE TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED
+THAT ANY DISSEMINATION, DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS
+STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE
+NOTIFY US IMMEDIATELY BY TELEPHONE AND RETURN THE ORIGINAL MESSAGE TO US AT
+THE ABOVE ADDRESS VIA THE U.S. POSTAL SERVICE. THANK YOU.
+Reply To: Las Olas City Centre - 401 East Las Olas Boulevard - Suite 1650 • Fort Lauderdale, Florida 33301 Telephone: |
+FORT LAUDERDALE • BOCA RATON • TAMPA - TALLAHASSEE • NEW YORK CITY - LOS ANGELES
+www.rra-law.com
+- Fax: (954)527-8663
+
+
+06-04-' 09 15:18 FROM-THOMAS & LOCICERO
+
+IHOMAS LOCICERO
+@002
+T-997 PØ01/003 F-849
+400 N. Ashley Drive•Suite 1100• Tampa, FL 33602
+813-984-3060 (Phone)=813-984-3070 (Fax)
+Toll Free: 866-395-7100
+facsimile transmittal...
+To:
+From:
+Re:
+Cc:
+R. Alexander Acosta, Esq.
+Judith Stevenson Arco, Esq.
+Michaci MeAullife, Esq.
+Jack Alan Goldberger, Esq.
+Bradley J. Edwards, Esq.
+William J. Berger, Esq.
+Deanna K. Shullman, Esg.
+State v. J. Epstein
+Marilyn Judicial Assistant to Judge
+Colbath
+Date:
+06/04/2009
+Pages:
+6
+[Urgent D]
+For review D
+Please comment 1]
+Please see attached Motion to Intervene and Petition for Access
+T Please reply C
+| Please recycle
+CONFIDENTIALITY STATEMENT
+In error, please notify de by telephone L
+1 immediately. Thankyou for your cooperation.
+2S Circular 230 Disclosure. To the extent this correspondence contains federal tax advice, such advice was not intended to be used, and canno
+e used by any taxpayer, for the purpose of (i) avoiding ponalties under the Internel Revenue Code or (f) promoting, marketing, o
+recommending to another party any transaction or matter addressed heroin. If you would like us to prepare written do advice designed to provide
+penalty protection, please contact us and we will be happy to discuss che matter with you in more detail
+
+
+
+06-04-'09 15:19 FROM-THOMAS & LOCICERO
+
+2003
+T-997 P002/003 F-849
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CRIMINAL DIVISION
+STATE OF FLORIDA
+JEFFREY EPSTEN
+Case Nos.: 2006-CF9454-AXX &
+2008-9381CF-AXX
+NOTICE OF HEARING
+PLEASE TAKE NOTICE that Palm Beach Newspapers, Inc., d/b/a The Palm Beach Post
+will call up for hearing its Motion to Intervene and Petition for Access before the Honorable
+Jeffrey Colbath, Palm Beach County Courthouse, 205 N. Dixie Hwy, Room 11F, West Palm
+Beach on June 10, 2009 at 10:40 a.m. or as soon thereafter as counsel may be heard.
+Time reserved: 10 Minutes
+THOMAS, LOCICERO & BRALOW PL
+James B. Lake
+400 North Ashley Drive, Suite 1100
+P.O. Box 2602 (33601)
+ampa, FL 3360
+elephone: !...
+Facsimile:
+Attorneys for The Palm Beach Post
+
+
+06-04-' 09 15:19
+
+State v. Epstein
+Case No. 2006-CF9454 & 2008-9381CF
+Notice of Hearing on Palm Beach Post's Motion to Intervene
+@004
+T-997 PØ03/003 F-849
+WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
+via S/U.S. Mail; /Facsimile; D Overnight Delivery to R. Alexander Acosta, United States
+Attorney's Office - Southern District, 500 S. Australian Ave., Ste. 400, West Palm Beach, FL
+33401; Judith Stevenson Arco, Esq., State Attorney's Office - West Palm Beach, 401 North
+Dixie Highway, West Palm Beach, FL 33401; William J. Berger, Esq., ROTHSTEIN
+ROSENFELDT ADLER, 401 East Las Olas Blvd., Ste. 1650, Fort Lauderdale, FL. 33394;
+Bradley J. Edwards, Esq, ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas Blvd., Ste.
+1650, Fort Lauderdale, FL 3394; Jack Alan Goldberger, Esq., Atterbury Goldberger, et al., 250
+S. Australian Ave., Ste. 1400, West Palm Beach, FL, 33401 on this
+4% day of June,
+2009.
+cc: Judicial Assistant (Via Fax and U.S. Mail)
+Esquire Court Reporting
+2
+
+
+06-Ø1-'09 15:35 FROM-THOMAS & LOCICERO
+
+@005
+T-989 P001/007 F-845
+400 N. Ashley Drive•Suite 1100 Tampä, FL 33602
+(Phone)d
+(Fax)
+facsimile transmittal
+To:
+R. Alexander Acosta, Esq.
+Judith Stevenson Arco, Esq.
+Michael McAuliffe, Esq.
+Jack Alan Goldberger, Esq.
+Bradley J. Edwards, Esq.
+William J. Berger, Esq.
+From: Deanna K. Shullman, Esq.
+Re:
+State v. J. Epstein
+=
+Date:
+Pages: 6
+06/01/2009
+[Urgent O
+For review M
+Please comment ]
+- Please reply O
+Please see attached Motion to Intervene and Petition for Access
+] Please recycle O
+CONFIDENTIALITY STATEMENT
+IRS Circular 230 Disclosure, To the extent this correspondence contains federal tax advice, such advice was not intended to be used, and cannot
+he used by any taxpayer, for the purpose of (i) avoiding penaliles under the Internal Revenue Code or (®) promoting, marketing, or
+recommending to another party any transaction or matter addressed herein, If you would like us to prepare written tax advice designed to provide
+renalty protection, please contset us and wo will be happy to discuss the matter with you in more detail
+
+
+
+06-01-'09 15:35
+
+_THOMAS LOCICERO
+4006
+T-989 P002/007 F-845
+YarN. Abiley Dr, Sl. 1100. Tampo, FL. 35602
+100B0
+D in
+Ш toll frall
+Ft. Laudordale
+101 N.E. Thied Ave., Ste. 1500
+pall fra
+New York City
+220 E. 42nd SL, 10th Floor
+3 fax
+www.ticlaw/lim.com
+Direct Dial: I
+Deanna.Shullman@tiolawfirm.com
+Reply To Tampa
+June 1, 2009
+VIA FEDERAL EXPRESS OVERNIGHT MAIL
+The Honorable Jeffrey Colbath
+Fifteenth Judicial Circuit-Palm Beach
+Palm Beach County Courthouse
+Main Judicial Complex
+205 N. Dixie Highway, Room 11F
+West Palm Beach, FL 33401
+Re:
+Dear Judge Colbath:
+Enclosed is a courtesy copy of non-party Palm Beach Newspapers, Inc. d/b/a The Palm
+Beach Post's (the "Post") Motion to Intervene and Petition for Access to certain court records in
+this case. It is our understanding that Bradley Edwards and William Berger of Rothstein
+Rosenfeldt Adler have filed a similar motion on behalf of a non-party known as
+and that
+I motion is set for hearing on June 10, 2009. The Post requests an opportunity to be heard
+on the issue of access to these records at that time.
+Thank you for your consideration in this matter. Please do not hesitate to contact me
+with any questions or comments.
+Sincerely,
+THOMAS, LOCICERO & BRALOW PL
+Deanna K. Shullman
+Deanna K. Shullman
+cc:
+Counsel of Record
+
+
+08/05/2009 10:01 FAX
+
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CRIMINAL DIVISION
+@1007
+T-989 P003/007 F-845
+STATE OF FLORIDA
+Case Nos.: 2006-CF9454-AXX &
+2008-9381CF-AXX
+!
+PALM BEACH POST'S MOTION TO INTERVENE
+AND PETITION FOR ACCESS
+Palm Beach Newspapers, Inc., d/b/a The Palm Beach Post (the "Post"*) moves to
+intervene in this action for the limited purpose of seeking access to documents filed under seal.
+The documents relate directly to the Defendant's guilty plea and sentence. Thus, the sealed
+documents go to the heart of the disposition of this casc. But in requesting that Judge Pucillo
+seal these documents, the parties failed to comply with Florida's strict procedural and substantive
+requirements for sealing judicial records. In addition, continued sealing of these documents is
+pointless, because these documents have been discussed repeatedly in open court records. For all
+of these reasons, the documents must be unsealed. As grounds for this Motion, the Post states:
+The Post is a daily newspaper that has covered this matter and related
+proceedings. In an effort to inform its readers concerning these matters, the Post relies upon
+(among other things) law enforcement records and judicial records.
+2.
+As a member of the news media, the Post has a right to intervene in criminal
+proceedings for the limited purpose of seeking access to proceedings and records. See Barron v.
+Florida Freedom Newspapers, Inc., 531 So. 2d 113, 118 (Fla. 1988) (news media have standing
+to challenge any closure order); Miami Herald Publ'g Co. v. Lewis, 426 So. 2d 1, 7 (Fla. 1982)
+(news media must be given an opportunity to be heard on question of closure).
+
+
+
+10008
+T-989 P004/007 F-845
+The particular documents under seal in this case are a non-prosecution agreement
+that was docketed on July 2, 2008, and an addendum docketed on August 25, 2008. Together,
+these documents apparently restrict any federal prosecution of the Defendant for offenses related
+to the conduct to which he pleaded guilty in this case. Judge Pucillo accepted the agreement for
+filing during a bench conference on June 30, 2008. The agreement, Judge Pucillo found, was "a
+significant inducement in accepting this plea." Such agreements and related documents typically
+are public record. See Oregonian Publishing Co. v. United States District Court, 920.2d 1462,
+1465 (9th Cir. 1990) ("plea agreements have typically been open to the public"); United States v.
+Kooistra, 796 F.3d 1390, 1390-91 (1 1th Cir. 1986) (documents relating to defendant's change of
+plea and sentencing could be sealed only upon finding of a compelling interest that justified
+denial of public access).
+4.
+The Florida Constitution provides that judicial branch records generally must be
+open for public inspection. See Art. I, § 24(a), Fla. Const. Closure of such records is allowed
+only under narrow circumstances, such as to "prevent a serious and imminent threat to the fair,
+impartial and orderly administration of justice," or to protect a compelling governmental interest.
+See Fla. R. Jud. Admin. 2.420(c)(9)(A). Additionally, closure must be effective and no broader
+than necessary to accomplish the desired purpose, and is lawful only if no less restrictive
+measures will accomplish that purpose. See Fla. R. Jud. Admin. 2. 420(c)(9)(B) & (C); Lewig,
+426 So. 2d at 3.
+In this case, the non-prosecution agreement and, later, the addendum were sealed
+without any of the requisite findings. Rather, it appears from the record, the documents were
+sealed merely because the Defendant's counsel represented to Judge Pucillo that the nonprosecution agreement "is a confidential document." See Plea Conference Transcript page 38
+2
+
+
+
+@009
+T-989 P005/007 F-845
+(June 30, 2008). Such a representation falls well short of demonstrating a compelling interest, a
+genuine necessity, narrow tailoring, and that no less restrictive measures will suffice.
+Consequently, the sealing was improper and ought to be set aside.
+In addition, at this time good cause exists for unsealing the documents because of
+their public significance. Since the Defendant pleaded guilty to soliciting a minor for
+prostitution, he has been named in at least 12 civil lawsuits that - like the charges in this case -
+allege he brought and paid teenage girls to come his home for sex and/or "massages."' At least
+11 cases are pending. In another lawsuit, one of the Defendant's accusers has alleged that
+federal prosecutors failed to consult with her regarding the disposition of possible charges
+against the Defendant.? Stare prosecutors also have been criticized: The Palm Beach Police
+Chief has faulted the State Attorney's handing of these cases as "highly unusual" and called for
+the State Attorney's disqualification. Consequently, this case - and particularly the Defendant's
+agreements with prosecutors - are of considerable public interest and concern.
+The Defendant's non-prosecution agreement with federal prosecutors also was
+important to Judge Pucillo. As she noted in the June 2008 plea conference, "I would view (the
+non-prosecution agreement] as a significant inducement in accepting this plea." See Plea
+Conference Transcript page 39. Florida law recognizes a strong public right of access to
+documents a court considers in connection with sentencing. See Sarasota Herald Tribune, Div.
+' See, e.Su Doe v. Epstein, Case No. 08-80069 (S.D. Fla. 2008); Doe No. 2 v. Epstein,
+Case No. 08-80119 (S.D. Fla. 2008); Doe No. 3. v. Epstein, Case No. 08-80232 (S.D. Fla. 2008);
+Doe No. 4. v. Epstein, Case No. 08-80380 (S.D. Fla. 2008); Doe No. 5 v. Epstein, Case No. 08-
+80381 (S.D. Fla. 2008); |
+. v. Epstein, Case No. 08-80811 (S.D. Fla. 2008); Doe v. Epstein,
+Case No. 08-80893 (S.D. Fla. 2008); Doe No. 7y. Epstein, Case No. 08-80993 (S.D. Fla. 2008);
+Doe No. 6 v. Epstein, Case No. 08-80994 (S.D. Fla. 2008); Doe Il v. Epstein, Case No. 09-80469
+(S.D. Fla. 2009); Doe No. 101 v. Epstein, Case No. 09-80591 (S.D. Fla. 2009); Doe No. 102 v.
+Epstein, Case No. 09-80656 (S.D. Fla. 2009); Doe No. 8 v. Epstein, Case No. 09-80802 (S.D.
+Fla. 2009).
+' See In re: Jane Doe, Case No. 08-80736 (S.D. Fla. 2008).
+3
+
+
+06-01-'09 15:37 FROM-THOMAS & LOCICERO
+
+@010
+T-989 P006/007 F-845
+of the New York Times Co. v. Holtzendorf, 507 So. 2d 667, 668 (Fla. 2d DCA 1987) ("While a
+judge may impose whatever legal sentence he chooses, if such sentence is based on a tangible
+proceeding or document, it is within the public domain unless otherwise privileged."). In this
+case, no interest justifies continued sealing of these "significant" documents that Judge Pucillo
+considered in accepting the plea and sentencing the Defendant. The lack of any such
+compelling interest - as well as the parties' failure to comply with the standards for sealing
+documents initially - provide good cause for unsealing the documents at this time.
+8.
+Finally, continued closure of these documents is pointless, because many portions
+of the sealed documents already have been made public. For example, court papers quoting
+excerpts of the agreement have been made public in related federal proceedings.? As the Florida
+Supreme Court has noted, "there would be little justification for closing a pretrial hearing in
+order to prevent only the disclosure of details which had already been publicized." Lewis, 426
+So. 2d at 8. Similarly, in this case, to the extent that information already has been made public,
+continued closure is pointless and, therefore, unconstitutional.
+9.
+The Post has no objection to the redaction of victims" names (if any) that appear
+in the sealed documents. In addition, insofar as the Defendant or State Attorney seek continued
+closure, the Post requests that the Court inspect the documents in camera in order to assess
+whether, in fact, continued closure is proper.
+' See, e fu "Defendants Jeffrey Epstein and
+Motion for Stay,"
+Epstein, Case No. 08-80811 (S.D. Fla. July 25, 2008) (filed publicly Jan. 7, 2009).
+4
+
+
+
+R011
+T-989 P007/007 F-845
+WHEREFORE, the Post respectfully requests that this Court unseal the non-prosecution
+agreement and addendum and grant the Post such other relief as the Court deems proper.
+Respectfully submitted,
+THOMAS, LOCICERO & BRALOW PL
+hacut trgpete tar
+Jeanna K. Shullma
+Florida Bar No.:
+James B. Lake
+Florida Bar No.:
+101 N.E. Third Avenue, Suite 1500
+Fort Lauderdale, FL 33301
+relephone:
+Attorneys for The Palm Beach Post
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
+via facsimile and U.S. Mail to: R. Alexander Acosta, United States Attorney's Office - Southern
+District, 500 S. Australian Ave., Ste. 400, West Palm Beach, FL 33401 (fax:
+Michael McAuliffe, Esg., and Judith Stevenson Arco, Esq., Stare Artomey's Office - West
+Palm Beach, 401 North Dixie Highway, West Palm Beach, FL 33401 (fax:
+); Jack
+Alan Goldberger, Esq., Atterbury Goldberger, et al., 250 S. Australian Ave., Ste. 1400, West
+Palm Beach, FL 33401 (fax:)
+); and Bradley J. Edwards, Esq. and William J.
+Berger, Esq., Rothstein Rosenfeldt Adler, 401 East Las Olas Blvd., Suite 1650, Fort Lauderdale,
+FL 33394 (fax:
+on this Ist day of June, 2009.
+Racue sAngatt
+5
+Fla Bar#
+
+
+
+H
+Page 1
+United States Court of Appeals,
+Eleventh Circuit.
+UNITED STATES of America, Plaintiff-Appellant,
+Leon J. WOOD, III, Defendant-Appellee.
+No. 85-3261.
+Jan. 21, 1986.
+In prosecution for violations of the Racketeer Influenced and Corrupt Organizations Act, the United
+States District Court for the Middle District of Florida, Hodges,
+Chief Judge, dismissed indictment
+against defendant, concluding that nonprosecution agreement entered into by the Government
+and defendant barred prosecution, and the Government appealed. The Court of Appeals held that defendant's failure to disclose his part in possible
+drug deal amounted to a substantial breach of
+agreement nullifying Government's promise not to
+prosecute defendant, even though defendant was
+acquitted on drug charges arising out of incident in
+question.
+Reversed and remanded.
+West Headnotes
+Criminal Law 110 Em 42.5(3)
+110 Criminal Law
+110I1 Defenses in General
+110k42 Immunity to One Furnishing Information or Evidence
+110k42.5 Agreements Granting Immunity
+110k42.5(3)
+Performance
+and
+Breach. Most Cited Cases
+(Formerly 110k42)
+Fact that alleged drug deal was not under investigation and that the Government did not specifically
+inquire about incident did not justify defendant's
+failure to disclose his knowledge of drug deal,
+where defendant admitted that he understood that
+he was required pursuant to reprosecution agreement with Government to fully disclose all information he possessed concerning drug activities, and
+thus, defendant's failure to disclose his part in such
+incident amounted to a substantial breach of agreement nullifying Government's promise not to prosecute defendant, even though defendant was acquitted on charges arising out of alleged drug deal.
+* John M. Fitzgibbons, Asst. U.S. Atty., Tampa,
+Fla., for plaintiff-appellant.
+Frank Regano, Tampa, Fla., for defendant- appellee.
+Appeal from the United States District Court for the
+Middle District of Florida.
+Before HILL and HENDERSON, Circuit Judges,
+and TUTTLE, Senior Circuit Judge.
+PER CURIAM:
+This is an appeal from the government's unsuccessful attempt to prosecute Leon J. Wood, Ill for violations of the Racketeer Influenced and Corrupt Or-
+ganizations Act, 18 U.S.C. § 1962(c) and (d). The
+United States District Court for the Middle District
+of Florida, adopting the magistrate's report and recommendation, dismissed the indictment against
+Wood, concluding that a non-prosecution agreement entered into by the government and Wood
+barred the prosecution. We reverse.
+On May 20, 1983, while Wood was incarcerated at
+Florida's Lake Butler Correctional Facility for narcotics violations, he entered into a covenant with
+the government in which the government agreed
+not to prosecute Wood if he consented to
+*930 fully and truthfully disclose to law enforcement everything that he knows concerning offers
+to, or the actual bribery of any public official concerning any matter, about any other matter, includ-
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt.. 6/8/2009
+
+
+
+. 780 F.2d 929
+ing drug importation and drug distribution conspiracies now under investigation, and about any other
+matter as to which the Government may inquire and
+shall not at any time willfully fail to disclose any
+fact material to any such inquiry or matter.
+The agreement also provided that if Wood "should
+fail in any way to fulfill completely each and every
+one of his obligations, then the Government will be
+free from its obligations to Mr. Wood."
+Between May and December 1983, the FBI interviewed Wood on numerous occasions asking him
+about various matters relating to bribery attempts
+and drug trafficking. On January 12, 1984, Wood
+was arrested on narcotics charges
+for activities
+which allegedly took place in the Jacksonville area.
+He was subsequently acquitted by a jury of those
+charges. In April, 1984, government agents informed Wood that he had breached the immunity
+agreement. After the parties met unsuccessfully to
+work out their differences, the government indicted
+Wood in the case currently pending before this court.
+An evidentiary hearing was held before a United
+States Magistrate
+on August 22, 1984. Subsequently, in a written report and recommendation,
+the magistrate concluded that the government failed
+to establish a "substantial breach of the specific
+terms of the agreement" and that Wood was entitled
+to "specific enforcement of the agreement." Magistrate's Report and Recommendation at 6. The district court adopted the report on March 7, 1985 and
+subsequently dismissed the indictment.
+On appeal, the government first contends that the
+district court improperly applied a substantial compliance standard to Wood's obligations under the
+agreement instead of a strict compliance criterion.
+Second, it maintains that the district court's finding
+that Wood substantially complied with the contract
+is clearly erroneous. Because we agree with the latter argument, we need not decide whether the district court erred by adopting a substantial compli-
+Page 2
+The government alleges that on numerous occasions Wood withheld information pertaining to
+bribery attempts or drug transactions until he was
+confronted with independent facts establishing that
+he actually had knowledge of the relevant incidents.
+For example, United States Attorney Joseph Magri
+testified at the hearing before the magistrate that
+the government learned that Wood had sold cocaine
+to John Tamargo but Wood did not admit to the sale
+until after Magri challenged this denial with facts
+derived from another source. Supplemental Record
+on Appeal, Vol. III at 209, 212. Also, the government contends that Wood initially told them that he
+money. Subsequently, the government discovered
+that Wood had again furnished the money to Bedami and when they confronted him with that fact,
+he admitted that he did give the money to Bedami
+on a second occasion. Supplemental Record on Ap-
+peal, Vol. III at 135. The government urges that
+these incidents, along with numerous others, FNI
+demonstrate a breach of the agreement.
+FN1. Wood admitted at the hearing that he
+initially did not tell the government about
+the involvement of David Grimes in drug
+transactions because Grimes was "like a
+brother to him." Wood did tell the government about Grimes' drug activities in subsequent interviews. See Appendix to Ap-
+pellant's Brief at 193.
+In response, Wood simply claims that he eventually
+cured all of these alleged violations and that the
+district court's finding that he did not breach the
+agreement because of the corrections should be
+not disclosing the drug activities*931 leading up to
+his arrest in Jacksonville.
+Wood admitted at the hearing before the magistrate
+that he attempted to set up a drug deal with Robert
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+Grogan in Jacksonville. Supp. Record on Appeal,
+Vol. Il at 28, 34. He was arrested for these activities and subsequently acquitted by a jury. He testified at his trial that he was acting as a quasi-law enforcement officer attempting to set up Grogan and
+that he never intended to actually consummate the
+drug transaction. He reaffirmed this position in the
+hearing before the magistrate. Id. at 36. He also admitted that he did not tell the government about
+these efforts. He testified as follows before the magistrate:
+. You were engaged in an undercover operatio
+n your own; is that your testimony
+A. Yes, sir, I was.
+Q. And you had knowledge that other individuals
+were attempting to commit a crime involving a
+large amount of narcotics; isn't that correct?
+A. They were talking about it, yes, sir.
+Q. And you did not reveal that information to
+Agent Wooldrige?
+A. No, sir....
+Id.
+Wood defends his failure to inform the government
+about the Jacksonville drug scheme on the ground
+that he was never asked about it. He stated that he
+was only asked about drug activities in the Tampa
+Bay area and not in Jacksonville. Assuming the
+truth of that testimony, it is nonetheless clear that
+Wood breached the agreement by intentionally
+withholding the information. Wood described his
+obligations under the agreement:
+My understanding was that I would give information, tell them everything I knew about bribe attempts or drug importation and trafficking that was
+then under investigation or that I had knowledge of
+and in return I would not be prosecuted in any way
+by the federal government. (emphasis added).
+Page 3
+Id. at 10.
+In light of this concession, Wood's explanation for
+his failure to tell the government about the drug
+activities in Jacksonville does not satisfy the requirements of his contract. He admitted that he
+knew about a possible drug deal and yet failed to
+disclose that information to the government purportedly because they did not specifically mention
+Jacksonville in their inquiry.™Nz Under his own interpretation of his duties under the contract,
+however, he had a continuing obligation to reveal
+that information regardless of whether he was specifically asked about it. In our view, this failure to
+disclose the Jacksonville drug activities, standing
+alone, constitutes a substantial breach of the contract.
+FN2. Wood also testified that he didn't tell
+the government about his dealings in Jacksonville because he wanted to acquire all
+the information at one time and then "put
+everything in their lap for them." Otherwise he was afraid that the government
+"would have blown the whole case for
+me." Supp. Record on Appeal, Vol. II at
+40. This reason does not excuse Woods'
+clear breach of the contract in light of the
+fact that he never came forward and told
+the government about the Jacksonville
+activities.
+The district court held that Wood's failure to tell the
+government agents of his Jacksonville activities did
+not amount to a substantial breach of the contract
+because the "matter was not under investigation at
+the time of the agreement, the Government did not
+make specific inquiry concerning the matter [and]
+the incidental references to possible police corruption has [sic] been fully disclosed by Mr. Wood
+both at trial and thereafter. Mr. Wood was acquitted
+by a jury that must have found his testimony credible in arriving at its conclusion." Record Excerpts
+at 110. The fact that the Jacksonville episode may
+not have been under investigation and that the government may not have made specific inquiry about
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+it does not justify Wood's failure to disclose his
+knowledge of the drug scheme in light of his admission that he understood that he was required to fully
+disclose all information that he possessed concern-
+END OF DOCUMENT
+has admitted that he had knowledge of people attempting to engage in illegal drug pursuits. It is
+simply not germane that a jury believed Wood
+when he testified that his participation in those
+transactions was for a lawful purpose.
+N3. Wood's version of his obligations i
+onsistent with the wording of the agree
+ment and the government's understanding
+of the agreement.
+We hold that Wood's failure to disclose his part in
+the Jacksonville drug undertaking amounted to a
+substantial breach of the contract and the district
+court's finding to the contrary is clearly erroneous.
+of the agreement,
+Wood's failure to comply with his obligations nullifies the government's promise not to prosecute him
+and the government is entitled to have the indict-
+FN4. Wood argues that it would be unfair
+to allow the government to use statements
+that he made after the time that the government considered the contract breached.
+This issue, however, relates to the admissibility of those statements not to the question of whether Wood violated the agreement. We express no opinion as to the admissibility of any statements made by
+Wood either before or after the breach of
+the contract.
+REVERSED and REMANDED.
+C.A.11 (Fla.), 1986.
+U.S. v. Wood
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt.. 6/8/2009
+
+
+
+(Cite as: 162' F.3d 832)
+Page 1
+United States Court of Appeals,
+Fifth Circuit.
+UNITED STATES of America, Plaintiff-Appellee,
+V.
+Raymond CASTANEDA, Defendant-Appellant.
+No. 97-40307.
+Dec. 9, 1998.
+Defendant was convicted in the United States Disrict Court for the Southern District of Texas
+ilemon B. Vela, J.. of Racketeer Influenced an
+Circuit Judge, held that government failed to prove
+that defendant materially breached nonprosecution
+agreement providing defendant with transactional
+immunity.
+Reversed, sentence vacated, and remanded.
+West Headnotes
+[1] Criminal Law Em 42.5(1)
+110k42.5(1) Most Cited Cases
+(Formerly 110k42)
+[1] Criminal Law Em 42.5(3)
+110k42.5(3) Most Cited Cases
+(Formerly 110K42)
+Nonprosecution agreements, like plea bargains, are
+contractual in nature, and are therefore interpreted
+in accordance with general principles of contract
+[3] Criminal Law Em 42.5(3)
+110k42.5(3) Most Cited Cases
+(Formerly 110k42)
+[3] Criminal Law Em 42.7(2)
+110k42.7(2) Most Cited Cases
+(Formerly 110k42)
+When the government believes that a defendant has
+breached the terms of a nonprosecution agreement
+and wishes to be relieved of performing its part of
+the bargain, the government must prove to the court
+by a preponderance of the evidence that (1) the defendant breached the agreement, and (2) the breach
+is suficiently material to warrant rescission.
+[4] Criminal Law Em 42.7(3)
+110k42.7(3) Most Cited Cases
+(Formerly 110k42)
+If the pleadings show no factual dispute, the court
+may determine defendant's breach of terms of nonprosecution agreement as a matter of law.
+[5] Criminal Law €m1139
+110k1139 Most Cited Cases
+Where district court issued no factual findings, appellate court would review defendant's claim of
+breach of a nonprosecution agreement de novo.
+[6] Criminal Law Cw 42.5(3)
+110k42.5(3) Most Cited Cases
+(Formerly 110k42)
+Government failed to prove that defendant materially breached nonprosecution agreement providing
+defendant with transactional immunity regarding
+2] Constitutional Law Em 452
+2k4526 Most Cited Case
+(Formerly 92k257.5)
+When the government believes that a defendant has
+government could not rescind agreement, although
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prid=ia744d85200000121c174f. 6/8/2009
+
+
+
+defendant omitted some information, where defendant provided volumes of both direct and indirect
+leads, and government failed to show that omissions were intentional or prejudicial to government.
+U.S.C.A. Const.Amend. 5.
+[7] Criminal Law Em42.5(3)
+110k42.5(3) Most Cited Cases
+(Formerly 110k42)
+In determining the materiality of a breach in the
+context of nonprosecution agreements, if a party's
+nonperformance is innocent, does not thwart the
+purpose of the bargain, and is wholly dwarfed by
+that party's performance, the breaching party has
+substantially performed under the contract, and the
+non-breaching party is not entitled to rescission.
+*833 Michael R. Dreeben, Jonathan Goldman Ce-
+darbaum, Jessie Acker Allen, U.S. Dept. of Justice,
+Washington, DC, Paula Camille Offenhauser, Asst.
+U.S. Atty., Houston, TX, for Plaintiff-Appellee.
+Lawrence Irwin Zinn, San Antonio, TX, for De-
+fendant-Appellant.
+Appeal from the United States District Court for the
+Southern District of Texas.
+Before WISDOM, WIENER and DENNIS, Circuit
+Judges.
+WIENER, Circuit Judge:
+In this direct criminal appeal, defendant-appellant
+Raymond Castaneda challenges his conviction of
+RICO conspiracy under 18 U.S.C. § 1962(d), alleging errors at both the indictment and trial stages
+of his case. Concluding that the district court erred
+in failing to dismiss Castaneda's indictment on the
+Page 2
+William Weaver worked as an investigator in the
+Cameron County Attorney's Office in Brownsville. During these years, Castaneda and Weaver
+conspired to solicit bribes from individuals accused
+of driving while intoxicated (DWI) in exchange for
+getting the charges dismissed or sentences reduced. Castaneda's role in this conspiracy was that
+of middleman, referring "clients" to Weaver, arranging meetings, receiving payments, and suggesting
+strategies for accomplishing fixes. Weaver's role
+on the other hand was that of principal, making the
+necessary arrangements within the County Attorney's Office to have the charges reduced or disappear.
+Suspecting corruption, the FBI began an investigation of the County Attorney's Office. As part of
+this activity, Special Agent Jose Louis Cisneros
+sought Castaneda's cooperation. This, in turn, led
+AUSA Mervyn Milton Mosbacker and Castaneda to
+enter into an informal, written proffer agreement on
+January 24, 1995, pursuant to which Castaneda was
+granted
+use immunity. [FN1] Sometime later,
+AUSA Mosbacker and Castaneda entered into another agreement [FN2]- this one oral--in which
+Castaneda was granted transactional immunity in
+exchange for his obligation to "tell everything he
+knew" about Weaver's criminal activity. [FN3]
+FN1. According to the terms of this agreement, Castaneda was granted "use" but not
+"derivative use"
+immunity. In
+other
+words, the government promised not to use
+any
+of the information or statements
+provided by Castaneda directly against him
+in any criminal proceeding, but reserved its
+right to pursue investigative leads derived
+om Castaneda's statements and use tt
+lerivative" evidence against hir
+FN2. Although there is some question as to
+and remand for entry of a judgment of acquittal.
+I
+FACTS AND PROCEEDINGS
+Castaneda owned an auto repair shop and towing
+service in Brownsville, Texas. From 1990 to 1994,
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prid=ia744d85200000121c174f.. 6/8/2009
+
+
+
+FN3. Pursuant to this
+agreement,
+Castaneda also agreed to provide information about the illegal activities of Alex
+Perez, the Sheriff of Cameron County.
+Page 3
+[FN4] (2) Julio Gonzalez, [FN5] (3) Jeff Lewis,
+[FN6] (4) Chuy Hinojosa, [FN7] (5) Guadalupe Ba-
+rajas, [FN8] (6) Federico Morales, [FN9] (7) *835
+Alejandro Cano, [FN10] and (8) Mario Meliton
+Garcia. [FN||]
+FN4. Castaneda told the government that,
+in addition to Reyes's involvement in drug
+trafficking, he often paid large sums of
+cash to Sheriff Perez (presumably as political contributions). On many of these occasions,
+admitted Castaneda, he served as
+the conduit between Reyes and Perez.
+FN5. Castaneda told
+the government that
+he was approached by Julio Gonzalez in
+1992 for assistance in getting his DWI case
+Gonzalez
+$1,000 to pass on to Weaver as payment
+for the fix. Castaneda acknowledged keeping approximately $100 for himself.
+FN6. Castaneda advised the government
+that Gonzalez approached him on another
+occasion for assistance in getting dismissed a DWI for Jeff Lewis.
+was unsure if Weaver had ultimately been
+successful in fixing the case.
+FN7. Castaneda told the government that
+an individual known
+"Chuy" Hinojosa
+had approached Weaver and given him an
+inknown amount of money. When Weave
+vas unable to fix the case, Hinojosa
+FN8. Castaneda told the government that
+barajas--who was on probation and afrai
+he would fail a urine test--paid Weav
+$6,000 to have the test fixed.
+FN9. Castaneda told the investigators that
+Morales was arrested for DWI and possession of a firearm and that he paid Weaver
+$1,000 to get the case dismissed.
+Castaneda admitted that, although he did
+not receive any money directly from this
+transaction, Weaver paid him $1,000 on a
+separate occasion to "keep [him] happy."
+FN10. Castaneda told the government that
+Cano paid Weaver $15,000 to fix a cocaine
+possession charge. When Weaver was unable to get the case dismissed or reduced,
+the money was returned to Cano's family.
+FN11. Castaneda informed the agents that
+Melion charge plise iscal or sod ced.l an
+of that money, Castaneda admitted to having kept $50.
+On October 22, 1996--almost one year after the
+November, 1995 interview with Castaneda, and at
+the end of the grand jury's deliberations-the government wrote to Castaneda advising that, because
+he had "failed to provide ... relevant and material
+he was well aware," he had violated the transaction-
+FN12. Count One alleged a pattern of rack
+eteering activity through predicate acts o
+bribery and extortion--the taking of pay-
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prid=ia744d85200000121c174f.
+6/8/2009
+
+
+
+nents for fixing DWI and marijuana possession prosecutions--in violation of 18
+U.S.C. § 1962(c) (RICO). Count Two alleged a conspiracy to engage in the same
+pattern of racketeering activity, in violation of 18 U.S.C. § 1962(d). Counts Three
+through Six alleged specific acts of extortion involving both defendants, in violation
+Act). Count Seven concerned an act of extortion involving only Weaver.
+FN13. Weaver pled guilty to the RICO
+substantive count, and his sentence was reduced to approximately 17 months. The
+reduction of Weaver's sentence was contingent on his willingness to testify truthfully
+against Castaneda at trial.
+Castaneda filed two motions to dismiss the indictment had breatf ed ich ne arend nba toh proover-
+[FN14] After an evidentiary hearing, the district
+court denied Castaneda's motion without reasons.
+FN14. In his other
+motion,
+Castaneda
+sought to have the indictment dismissed on
+the
+ground that the government
+breached its proffer agreement by using his
+immunized testimony
+in the grand jur
+proceeding. The district court denied this
+motion but we do not reach it.
+Thereafter, Castaneda was convicted by a jury of
+Rerered conspira y area e hi ce er er
+dict, and sentenced Castaneda to 33 months in prisvis ed re ist, and by int of e,00.0 as sanerappeals his conviction. [FN16]
+'N15. The jury acquitted Castaneda of the
+RICO
+substantive count and the
+four
+Hobbs Act counts. The count on which
+Castaneda was convicted identified as predicate acts five DWI cases that he and
+Weaver conspired to fix. Named as the
+bribe-payors/extortion victims in these
+cases are Julio Gonzalez (a participant in
+two transactions--his own and that involving Maurice Middleton), Meliton Garcia, Rafael Gonzalez and Sammy Snodgrass (a participant in the transaction involving Jeff Lewis). Predicate Act Six--
+referring to the dismissal of a marijuana
+charge for Silverio Garza-- pertained only
+to Weaver.
+FN16. On appeal, Castaneda asserts four
+distinct errors that allegedly warrant the reversal of his conviction. Because we conclude that the government breached its
+transactional immunity agreement and that
+the district court erred in failing to dismiss
+Castaneda's indictment on this ground, we
+do not reach Castaneda's other three assignments of error.
+ANALYSIS
+Castaneda argues that the district court should have
+granted his motion to dismiss the indictment because the government breached its oral agreement
+not to prosecute. Implicit in this claim is the
+charge that the government failed to show by a preponderance of the evidence that Castaneda materially breached the immunity agreement, without
+which the government could not repudiate the contract and prosecute him. We agree.
+[1][2][3][4][5] Nonprosecution
+agreements,
+plea bargains, are contractual in nature, and are
+therefore interpreted in accordance with general
+principles of contract law. [FN17] Under these
+principles, if a defendant lives up to his end of the
+bargain, the government is bound *836 to perform
+its promises. [FN18] If a defendant "materially
+breaches" his commitments under the agreement,
+however, the government can be released from its
+reciprocal obligations. [FN19] When the government believes that a defendant has breached the
+terms of a nonprosecution agreement and wishes to
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prid=ia744d85200000121c174f. 6/8/2009
+
+
+
+be relieved of performing its part of the bargain-
+-here, retraining from prosecuting the defendantue process prevents the government from makir
+is determination and nullifying the agreeme
+unilaterally. [FN20] Instead, the government must
+prove to the court by a preponderance [FN21] of
+agreement, and (2) the breach is sufficiently material to warrant rescission. [FN22] If the pleadings
+show no factual dispute, however, the court may
+determine breach as a matter of law. [FN23] Be-
+cause the district court issued no factual findings in
+this case, we review Castaneda's claim of breach of
+a nonprosecution agreement de novo. [FN24]
+FN17. United States v. Moulder, 141 F.3d
+568, 571 (5th Cir.1998); United States v.
+Ballis, 28 F.3d 1399, 1409 (5th Cir.1994);
+United States v. Fitch, 964 F.2d 571, 574
+(6th Cir.1992): United States v. Brown,
+801 F.2d 352, 354 (8th Cir. 1986).
+FN18. United States v. Tilley, 964 F.2d 66,
+70 (Ist Cir. 1992)
+FN19. Ballis, 28 F.3d at 1409; Tilley, 964
+F.2d at 70; United States v. Crawford, 20
+F.3d 933, 935 (8th Cir. 1994).
+According to Castaneda, the government's
+sole remedy for his alleged breach would
+be prosecution for perjury, not rescission
+of the agreement. Castaneda claims that
+the government is limited to the remedies
+stated in the agreement. Because the oral
+agreement did not specifically contemplate
+prosecution for immunized crimes in the
+event he failed to provide full and truthful
+information, argues Castaneda, the government may not revoke its grant of transacional immunity. In support of this pro
+osition, Castaneda cites United States v
+Fitch, 964 F.2d 571, 575 (6th Cir. 1992).
+FN20. United States v. Verrusio, 803 F.2d
+Bara33s 730 %Supriea Siles 12
+Tarrant,
+F.Supp.
+1990).
+FN21. United States v. Price, 95 F.3d 364,
+367 (5th Cir.1996) (stating that, in determining whether government's actions have
+breached terms of plea agreement, defendant bears burden of demonstrating underlying facts that establish breach by preponderance of evidence); United States v. Wittie, 25 F.3d 250, 262 (5th Cir.1994), aff'd,
+515 U.S. 389, 115 S.Ct. 2199, 132 L.Ed.2d
+351 (1995) (same); Tilley, 964 F.2d at 71
+(holding that before government may revoke agreement, it must show by a preponderance of evidence that the defendant has
+committed a substantial breach); United
+States v. Packwood, 848 F.2d 1009, 1011
+(9th Cir.1988) (same).
+We recognize, however, that not all courts
+have adopted this standard. See, e.g.
+United States v. Gonzalez-Sanchez, 825
+F.2d 572, 578 (Ist Cir.1987) (holding that
+government bears the burden of demonstrating by adequate evidence that there
+has been a substantial breach by defendant); State v. Rivest 106 Wis.2d 406, 316
+N.W.2d 395, 398-99 (Wis.1982) (adopting
+a beyond a reasonable doubt standard);
+United States v. Skalsky, 616 F.Supp. 676,
+681 (D.N.J.1985) (requiring proof of material breach by clear and convincing evidence).
+FN22. See Packwood, 848 F.2d at 1011;
+Tarrant, 730 F.Supp. at 32.
+FN23.
+Packwood, 848 F.2d at 1011;
+United States v. Calabrese, 645 F.2d 1379,
+1390 (10th Cir: 1981).
+FN24. Moulder, 141 F.3d at 571; Price, 95
+F.3d at 367; United States v. Laday, 56
+F.3d 24, 26 (Sth Cir.1995); Wittie, 25 F.3d
+at 262; United States v. Valencia, 985 F.2d
+758, 760 (5th Cir. 1993).
+The government argues that the appropri-
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prid=ia744d85200000121c174f. 6/8/2009
+
+
+
+ate standard of review is clear error. See
+United States v. Gibson, 48 F.3d 876, 878
+(5th Cir.1995); Ballis, 28 F.3d at 1409.
+We agree that this is the appropriate standard for reviewing a district court's findings
+Bre ach. in unde aisence s t satch factual
+findings, however, we must conduct a de
+novo review of every aspect of Castaneda's
+purported breach.
+[6] In the instant case, the government promised not
+to prosecute Castaneda for his role in the bribery
+scheme in exchange for his full and truthful disclosure of information implicating Weaver. After dealing with Castaneda for more than a year, the government rescinded this agreement at the eleventh
+hour, and Castaneda was indicted by the grand jury
+one day later. At a pretrial hearing on Castaneda's
+motion to dismiss his indictment, [FN25] the gov-
+tion
+of
+which
+he
+was
+well
+aware."
+[FN26] Because of these alleged omissions, contended the government,
+it was
+entitled to rescind
+the agreement and be relieved of its obligation not
+to prosecute. Castaneda countered that he gave the
+government considerable, accurate, and incriminating information about Weaver, and that any omissions Castaneda made were essentially inadvertent
+or duplicative and thus did not amount to a material
+breach of the agreement. [FN27] In so many words,
+he argued substantial performance.
+FN25. The government did not seek a judicial determination of breach until after
+Castaneda
+had been indicted,
+Castaneda does not contend that a hearing
+nad to have been held prior to this time
+For the purposes of this opinion, therefore
+ve do not pass on the issue of when, dur
+ing the progress of a criminal investigation, a judicial determination of breach is
+required to comport with due process. See
+FN26. All of the evidence presented at the
+pretrial hearing pertained to Castaneda'
+omission of information about illega
+activities involving Weaver. It appear
+hat the government introduced evidence ir
+camera regarding Castaneda's alleged
+omissions about activities involving Sheriff Alex Perez. It is not clear whether the
+court took this evidence into account when
+determining Castaneda's breach, and this
+evidence is not in the record on appeal.
+Although the government maintains its position that Castaneda breached the nonprosecution agreement with regards to both
+Weaver and Perez, the government has
+failed to cite any specific omissions involving Perez and has failed to see to it
+that its in camera inculpatory evidence is
+included in the record on appeal.
+Castaneda's
+lawyer--Ernesto
+Gamez, Jr.--wrote a letter to AUSA Mosbacker, dated December 12, 1996, in which
+he argued
+that Castaneda's inadvertent
+omission of some names does not amount
+to a lie. Forgetfulness, argued Gamez, is
+not the same as noncompliance. Furthermore, Gamez contended, the government
+"either already possessed [the omitted
+names] or acquired this additional information from [Castaneda's] statements." In
+and that he had been led to believe that the
+government was fully satisfied with the in
+formation provided by Castaneda. Gamez
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prid=ia744d85200000121c174f 6/8/2009
+
+
+
+agreed to contact him in the event the government needed additional information.
+There is no clear Fifth Circuit law on the issue of
+Page 7
+reach is not material unless the non-breaching
+arty is deprived of the benefit of the bargain
+[FN29] The less the non-breaching party is deprived of the expected benefits, the less material the
+breach. [FN30]
+FN28. For some of the circumstances in
+which courts have allowed the government
+to rescind plea agreements, see Ballis, 28
+F.3d at 1409 (withholding of information,
+untruthful testimony, and
+inducement of
+plea agreement by
+fraud); Hentz v. Hargelt, 71 F.3d 1169, 1172-75 (Sth Cir.1996)
+(informing prosecutor of intent to change
+testimony
+circumstance
+amounting to
+anticipatory repudiation which justifies revocation
+agreement); Tarrant, 730
+F.Supp. at 32-33 (refusing to cooperate by
+failing to meet with government representfailing to testify before grand jury
+and fleeing jurisdiction to avoid cooperation); United States v. Donahey, 529 F.2d
+831, 832 (5th Cir.1976) (providing evasive, misleading
+answers,
+could not be verified, and refusing to answer questions).
+FN29. Hanson Prod. Co. v. Americas Ins.
+Co., 108
+627, 630 (5th Cir.1997)
+(relying on
+Hernandez v. Gulf Group
+691,
+692-92
+(Tex.1994) in holding that, where an insurer is not prejudiced by a breach, the
+breach is not material, the insurer has not
+been deprived of the benefit of the bargain,
+and it should not be relieved of its obligation to provide coverage).
+The "benefit of the bargain" standard has
+been adopted, at least in part, by the Eighth
+Circuit in determining breach of an immunity agreement. In United States v.
+Crawford, 20 F.3d 933 (8th Cir.1994), the
+court relied on the following three factors-
+-borrowed from the Restatement of Contracts--to guide their determination: (1) the
+extent to which the injured party will be
+deprived of the benefit which he reasonably expected; (2) the likelihood that the
+party failing to perform will cure his failure; and (3) the extent to which the behavior of the party failing to perform comports
+with standards of good faith and fair dealing. Id. at 935. The other considerations
+listed in the Restatement as significant in
+determining the materiality of a breach include (1) the extent to which the injured
+party can be adequately compensated for
+the part of that benefit of which he will be
+deprived; and (2) the extent to which the
+party failing to perform or to offer to perform will suffer forfeiture. Restatement
+(Second) of Contracts § 241 (1981).
+In United States v. Fitch, the Sixth Circuit
+adopted a somewhat more rigorous standard, holding that the government must
+prove a "bad faith, intentional, substantial
+omission" on the part of the defendant before it can be released from its obligations.
+964 F.2d at 574 (adopting the standard set
+forth in United States v. Castelbuono, 643
+F.Supp. 965, 971 (E.D.N.Y.1986)).
+FN30. Hernandez v. Gulf Group Lloyds,
+875 S.W.2d 691, 693 (Tex.1994).
+[7] Courts within this Circuit have clarified the
+concept of material breach by comparing it with the
+CoNSi) uing i aura, l pary ape.
+formance ... is innocent, does not thwart the purpose of the bargain, and is wholly dwarfed by that
+party's performance," the breaching party has substantially performed under the contract, and the
+non-breaching party is not entitled to rescission.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prid=ia744d85200000121c174f. 6/8/2009
+
+
+
+[FN32] We think that this approach is equally applicable in determining the materiality of a breach
+in the context of nonprosecution agreements.
+[FN33] Given the government's burden of proof,
+our de novo application of this test demonstrates
+that the relatively insignificant omissions by
+Castaneda did nothing to frustrate the government's
+prosecution of Weaver. Moreover, these omissions
+pale by comparison to the plethora of information
+delivered by Castaneda.
+FN31. See White Hawå Ranch, Inc. v. Hopkins, No. CIV.A.91-CV29-DD, 1998 WL
+94830, at *3 (N.D.Miss. Feb.12, 1998).
+See also 2 E. Allan Farnsworth, Farnsworth on Contracts § 8.16 at 442 (2d ed.
+1990)
+(recognizing that substantial
+performance is performance without a material breach, and a material breach results in
+performance that is not substantial).
+FN32.
+White
+Hawk
+Ranch,
+CIV.A.91-CV29-DD, 1998 WL 94830, at *
+FN33. The government cites United States
+Gerant,
+995 F.2d
+505,
+509 (4th
+Cir. 1993) in support of its argument that
+should not be overlooked simply because
+furnished the government with some
+useful information. In Gerant, however,
+the court concluded
+that the defendant's
+breach of the nonprosecution agreement
+had "seriously impaired ongoing drug investigations and prosecutions," thereby entitling the government to rescission of the
+agreement. Id. In other words, the government had been prejudiced by the defendant's breach. Moreover, the court was careful to point out that there may be cases
+"where the extent of information and cooperation provided by a defendant who has
+trivially breached a nonprosecution agreement is so great that the court is persuaded
+that the defendant substantially complied
+Page 8
+with the agreement." Id. at 509 n. 4.
+Thus, while the Fourth Circuit rejected the
+defendant's substantial compliance argument under the particular facts of the case,
+Gerant does not stand for a per se rejection
+The government argues that Castaneda committed a
+material breach of the agreement by failing to reveal Weaver's involvement in the dismissal of
+DWIs for Meliton Garcia, Maurice Middleton and
+Rafael Gonzalez, as well as the dismissal of a gun
+charge for Jose Galvan. [FN34] Although it is clear
+that Castaneda omitted some information during his
+interviews with the government, it is anything but
+clear that, when viewed in the context of what the
+government already knew or learned derivatively
+from other sources, these omissions rise to the level
+of a material breach, even collectively.
+FN34. Agent Cisneros testified at the pretrial hearing that the government knew
+about the cases of Meliton Garcia, Maurice
+Middleton and Rafael Gonzalez before interviewing either Castaneda or Weaver.
+The government conducted interviews with
+Weaver on February 27, 1995, March 22,
+1995, May 31, 1995 and January 29, 1996.
+Castaneda provided the government with substantial, detailed accounts of bribery involving Weaver
+and seven other individuals--Julio Gonzalez, Jeff
+Lewis, Chuy Hinojosa, Guadalupe Barajas, Federico Morales, Alejandro Cano, and Meliton Garcia. Weaver's illegal activities with three of these
+individuals eventually formed the basis for predicte racketeering acts and Hobbs Act counts in ih
+ndictment. [FN35
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prid=ia744d85200000121c174f.. 6/8/2009
+
+
+
+through Sammy Snodgrass for dismissal of
+Lewis's DWI). Illegal activities with these
+same individuals formed the basis of
+Counts Three, Four, and Six--Hobbs Act
+Page 9
+Castaneda failed entirely to provide information
+was Jose Galvan--for dismissal of a gun charge tha
+did not serve as the basis for any count in the in
+ation about the dismissal of an assault charge; he
+merely failed to mention the dismissal of a DWI
+charge as well. Thus, Castaneda led the government to the right source, even if his tip was not
+Likewise, although Castaneda did not disclose information
+about Weaver's dismissal
+of Maurice
+Middleton's DWI, [FN36] Castaneda did provide
+accurate information about his own involvement as
+a go-between for Weaver and Julio Gonzalez-and,
+thereafter, Gonzalez confessed to the government
+that he had contacted Castaneda for help getting
+DWIs *839
+dismissed both
+for himself
+and
+Middleton, as well as for Jeff Lewis. Thus,
+Castaneda did indirectly that about which the government faults him for not doing directly.
+FN36. Maurice Middleton was named in
+predicate Act Three of the indictment.
+Finally, with regard to Rafael Gonzalez [FN37],
+Agent Cisneros and AUSA Mosbacker were inconsistent about the extent of information Castaneda
+provided. In the pretrial motion hearing, Agent
+Cisneros repeatedly testified that Castaneda had
+discussed Rafael's DWI, only to recant this assertion on further questioning. AUSA Mosbacker admitted that he thought Castaneda had discussed illegalities in which Weaver and Rafael were involved, but maintained that Castaneda did not mention the DWI. Even if Castaneda failed to reveal
+any direct information about Rafael, though, it is
+undisputed that he did provide substantial information about Jose Reyes--a source intimately connected with Rafael Gonzalez. Thus, it appears that the
+Weaver-related individual
+FN37. Rafael Gonzalez was named in predicate Act Four and Count Five.
+FN38. In addition,
+it appears that
+Castaneda did not provide any informatior
+bout an alleged DWI dismissal for an in
+dividual named Perez (first name unknown). When asked during the pretrial
+hearing to list the omissions constituting
+Castaneda's breach, however, AUSA Mosbacker did not mention this transaction.
+Neither is the Perez omission mentioned in
+the government's brief to this Court.
+We note that, in addition to dismissals of
+charges against Julio Gonzalez, Meliton
+Garcia, Maurice Middleton, Rafael Gonzalez, and Jeff Lewis, the indictment identified as a predicate act for the substantive
+RICO count the dismissal of a marijuana
+charge for Silverio Garza (Act Six). This
+same transaction formed the basis of Count
+Seven. Castaneda was not named in Act
+Six or Count Seven, however, and the government does not assert that he had any
+knowledge of this transaction.
+Having reviewed the briefs of the parties, heard oral argument, and thoroughly reviewed the record,
+we are now satisfied that, despite Castaneda's relatively insignificant omissions, the government got
+the benefit of its bargain and has failed to carry its
+burden of proving a material breach by Castaneda.
+The government granted Castaneda transactional
+immunity with the intention of receiving in return
+leads and information pertinent to its investigation
+of Weaver and corruption in the Cameron County
+Attorney's Office. Castaneda provided both direct
+and indirect leads, and volumes of such information
+as well. In fact, Castaneda gave the government
+significant quantities of detailed information about
+Weaver's involvement in at least seven illegal trans-
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prid=ia744d85200000121c174f... 6/8/2009
+
+
+
+actions conducted through the County Attorney's
+Office. [FN39] Although it appears that Castaneda's
+performance was not perfect--that he did not literally "tell everything he knew," as he was technically required to do under the agreement--the government has failed to show that these omissions
+were intentional or, more importantly, that the government was prejudiced. Much of
+the relatively
+little that Castaneda omitted was already known to
+the government before interrogating Castaneda, or
+was discovered from other sources. When viewed
+in light of the overwhelming quantity of information he furnished about numerous individuals and
+incidents involving Weaver, much that Castaneda
+omitted must be classified either as cumulative or
+surplusage. In the absence of proof of substantial
+or intentional omissions by Castaneda constituting
+prejudice to the government, the district court erred
+n permitting the government to revoke the nonproecution agreement with Castaneda and prosecut
+him in this case.
+dismissals for Julio
+Gonzalez, Jeff "Lewis,
+Chuy Hinojosa,
+Guadalupe Barajas, Federico Morales, Alejandro Cano, and Meliton Garcia. The information that Castaneda provided regardinegal ateyies of heri Perene bet toe
+III
+CONCLUSION
+Page 10
+own revelations. Yet, this is precisely what we
+perceive to have happened here, and due process
+cannot abide such behavior. For the reasons explained above, we conclude that the district court
+erred in failing to grant Castaneda's motion to dismiss the indictment, which was obtained in violation of a transactional immunity agreement, that the
+government failed to prove was materially
+breached. Castaneda's conviction of RICO conspiracy is reversed, the sentence imposed in accordance with that conviction is vacated, and the case is
+remanded to the district court for entry of a judgment of acquittal.
+REVERSED; sentence VACATED; and RE-
+MANDED with instructions.
+END OF DOCUMENT
+stantial leads and information that literally make
+the government's case against the "big fish" while
+coincidentally giving the government a lay-down
+*840 winning hand against the cooperating coconspirator; then, at the last moment, rely on some
+technical or relatively minor deficiency in performance to pull the rug from under the cooperating informant by claiming a breach and proceed to prosecute him in a slam-dunk case based largely on his
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prid=ia744d85200000121c174f.. 6/8/2009
+
+
+
+Westlaw Delivery Summary Report for ATKINSON,KAREN
+Your Search:
+non-prosecution agreement breached by defendant, do have to
+give time to cure breach
+Date/Time of Request:
+Monday, June 8, 2009 15:08 Central
+Client Identifier:
+DOJ
+Database:
+ALLFEDS
+Citation Text:
+Lines:
+203
+Documents:
+Images:
+!
+The material accompanying this summary is subject to copyright. Usage is governed by contract with Thomson Reuters,
+West and their affiliates.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+H
+Page 1
+United States District Court,
+N.D. Texas,
+Dallas Division.
+UNITED STATES of America
+V.
+Sean Christian TARRANT, Jon Lance Jordan,
+Christopher Barry Greer, Michael Lewis Lawrence,
+Daniel Alvis Wood.
+Crim. A. No. 3-89-293-H.
+Jan. 16, 1990.
+Defendant who allegedly breached nonprosecution agreement moved to dismiss indictment or to
+suppress statements. The District Court, Sanders,
+Chief Judge, held that: (I) defendant, who refused
+to cooperate by failing to meet with Government
+representatives, failing to testify before grand jury,
+and eventually fleeing Texas to avoid cooperation
+altogether, substantially and materially breached
+pretrial proffer agreement, and (2) defendant's
+substantial material breach of agreement permitted Government to indict defendant on charges that
+were subject to agreement, even if indictment were
+issued as a result of statements defendant made under agreement.
+Motion denied.
+See also, 732 F.Supp. 56.
+West Headnotes
+[1] Criminal Law 110 €-42.5(1)
+110 Criminal Law
+110Il Defenses in General
+110k42 Immunity to One Furnishing Information or Evidence
+110k42.5 Agreements Granting Immunity
+110k42.5(1) k. In General. Most Cited
+(Formerly 110k42)
+Pretrial agreements, like plea bargains, are con
+tractual in nature
+[2] Criminal Law 110 €m 42.5(1)
+110 Criminal Law
+I10Il Defenses in General
+110k42 Immunity to One Furnishing Information or Evidence
+I10K025 () K. is Geaeral. Most Clied
+(Formerly 110k42)
+Although principles of contract law generally apply
+to pretrial agreements, constitutional ramifications
+of agreements require judicial supervision to safeguard defendant's rights.
+[3] Criminal Law 110 Cm42.5(3)
+110 Criminal Law
+110Il Defenses in General
+110k42 Immunity to One Furnishing Information or Evidence
+110k102.5 greements Performame nity
+110k42.5(3)
+Breach. Most Cited Cases
+(Formerly 110k42)
+Criminal Law 110 €m42.7(2)
+110 Criminal Law
+11011 Defenses in General
+110k42 Immunity to One Furnishing Information or Evidence
+110k42.7 Enforcement of Grant of Im-
+munity
+110k42.7(2) k. Evidence. Most Cited
+Cases
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+court by preponderance of evidence that defendant
+materially breached agreement.
+14] Criminal Law 110 €~42.5(3)
+110 Criminal Law
+110II Defenses in General
+110k42 Immunity to One Furnishing Information or Evidence
+110k42.5 Agreements Granting Immunity
+110k42.5(3)
+Performance
+and
+Breach. Most Cited Cases
+(Formerly 110k42)
+Defendant, who refused to cooperate by failing to
+meet with government representatives, failing to
+testify before grand jury, and eventually fleeing
+Texas to avoid cooperation altogether, substantially
+and
+materially
+breached
+pretrial proffer
+agreement, despite defendant's attempts to characterize his actions as "inarticulate way of withdrawing from an agreement about which he had regrets.".
+15] Criminal Law 110 € 42.5(1)
+110 Criminal Law
+110Il Defenses in General
+110k42 Immunity to One Furnishing Information or Evidence
+110k42.5 Agreements Granting Immunity
+110k42.5(1) k. In General. Most Cited
+Cases
+(Formerly 110k42)
+Criminal Law 110 Cm 273.1(2)
+110 Criminal Law
+110XV Pleas
+110k272 Plea of Guilty
+110k273.1 Voluntary Character
+110K273.1(2)
+Representations,
+Promises, or Coercion; Plea Bargaining. Most Cited
+Cases
+Plea and nonprosecution agreements must be interpreted according to objective standards.
+[6] Criminal Law 110 Cm 42.5(3)
+Page 2
+110 Criminal Law
+110I| Defenses in General
+110k42 Immunity to One Furnishing Information or Evidence
+110k42.5 Agreements Granting Immunity
+110k42.5(3)
+k.
+Performance
+and
+Breach. Most Cited Cases
+(Formerly 110k42)
+Where nonprosecution agreement confers immunity for defendant, parties must look to and are
+governed by agreement for the remedies arising
+17] Criminal Law 110 €m42.5(3)
+110 Criminal Law
+110I1 Defenses in General
+110k42 Immunity to One Furnishing Information or Evidence
+110k42.5 Agreements Granting Immunity
+110k42.5(3)
+k.
+Performance
+and
+Breach. Most Cited Cases
+(Formerly 110k42)
+Where cooperation agreement so provides, Government may use defendant's statements against
+him in event of defendant's breach.
+[8] Criminal Law 110 Em 42.5(3)
+110 Criminal Law
+110Il Defenses in General
+110k42 Immunity to One Furnishing Information or Evidence
+110k42.5 Agreements Granting Immunity
+110k42.5(3)
+k.
+Performance
+and
+Breach. Most Cited Cases
+(Formerly 110k42)
+Defendant's substantial material breach of nonprosecution agreement by failing to testify before
+grand jury and eventually fleeing jurisdiction permitted Government to indict defendant on charges
+that were subject to nonprosecution agreement,
+even if indictment was issued as a result of statements defendant made; Government was not limited to holding defendant in contempt for failure to
+testify as would have been case had defendant
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+been granted statutory immunity. 18 U.S.C.A. §9
+6002, 6003; U.S.C.A. Const.Amend. 5.
+19] Criminal Law 110€408
+110 Criminal Law
+110XVII Evidence
+110XVII(L) Admissions
+.10k408 k. Negotiations for Com
+promise. Most Cited Cases
+Rule prohibiting admission of statement made in
+course of plea discussions if no plea occurs or plea
+is withdrawn applies only to statements leading up
+to agreement and not those made after agreement.
+Fed.Rules Cr.Proc.Rule 11(e)(6), 18 U.S.C.A.
+*31 James P. Turner, Acting Asst. Atty. Gen., Civ.
+Rights Div., U.S. Dept. of Justice, Barry Kowalski
+& Suzanne Drouet, Attys., Crim. Section, Washington, D.C., for U.S.
+Craig Jett, Dallas, Tex., for defendant Wood.
+Page 3
+MEMORANDUM OPINION AND ORDER
+SANDERS, Chief Judge.
+Before the Court is Defendant Wood's Motion to
+Dismiss Indictment or To Suppress Statements of
+Defendant, filed December 15, 1989; and the Government's Response, filed January 2, 1990. Defendant Wood moves the Court to dismiss the indictment against him or in the alternative to exclude
+from evidence (1) certain statements made by him
+to law enforcement authorities and (2) any evidence
+derived therefrom.
+agreed to cooperate with the federal and state allthorities in their investigation of racist criminal
+activity in the Dallas area in exchange for (1) a
+promise that Wood would not be prosecuted further
+and (2) a grant of protection for Wood and his family. The parties memorialized the agreement in a
+three-page, single-spaced letter which included
+handwritten modifications and a typed addendum
+(hereinafter the "Proffer Agreement" or " non-prosecution agreement").
+Section TWO of the Proffer Agreement clearly
+states that Wood could be prosecuted for perjury,
+false statement, or obstruction of justice in the
+event he gave false, misleading, or incomplete information. Section THREE specifically informed
+the Defendant that failure to perform any of his obligations under the agreement would release the
+government to prosecute him for any crime and permit the government to use evidence against him
+from any source,
+"including [his] own admissions."
+FNI In an addendum to the agreement, it is reemphasized that Wood would
+not be
+"except as set forth in TWO and THREE." Prosecuted
+FN1. The agreement states:
+TWO: You will at all times give complete, truthful and accurate information
+and testimony and must not commit any
+further violation of state or federal law
+whatsoever. Nothing in this agreement
+shall be construed to protect you in any
+way from prosecution or perjury, false
+statement or false declaration, in violation of 18 U.S.C. §§ 1001, 1621, or
+1623, or obstruction of justice, in violation of 18 U.S.C. §§ 1503, 1505, and
+1510 in the event it is determined that
+you have intentionally given false, misleading or incomplete information. Not
+I. FACTS
+Following his conviction for criminal mischief in
+state court, Defendant Wood was sentenced to imprisonment for ten years. Soon thereafter, Wood
+and his attorney met with representatives of both
+the federal and state government. After some discussion, the parties reached a deal whereby Wood
+date of this agreement or any criminal
+offense committed by you which resul-
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+ted in the serious bodily injury or death
+of another.
+THREE: It is also understood that, if it is
+determined that you have intentionally
+given false, misleading or incomplete in
+ormation or violated any other term of
+this agreement, then:
+(1) You will be subject to prosecution
+for any criminal violations of which the
+present at the time of execution. See De-
+fendant's Motion at 2, 8; Government's Re-
+sponse at 3, 9-10.
+(1) failed on more than one occasion t
+(2) All statements made by you to the
+United States and/or any other law enforcement officials,
+and all testimony
+given by you, and all leads from such
+statements or testimony, will be admissible in evidence against you. It is the intent of this agreement that you waive
+any and all rights which you may have
+under the United States Constitution, any
+statute or any Federal rule to seek suppression of these statements in the event
+that you violate any of the terms of this
+agreement.
+After signing the Proffer Agreement on February
+16, 1989, F2 Defendant spent several days providing information to the government. Several weeks
+later, however,*32 Wood decided that he no longer
+wished to cooperate and attempted to avoid giving
+any further information to law enforcement authorities.FNJ Sometime after his release from incarceration, Wood left Texas to avoid giving testimony
+efore a federal grand jury to which he had beer
+ubpoenaed to testify. F
+FN2. The Court finds that Defendant voluntarily and knowingly entered into this
+agreement, having discussed it with his
+foms to the a rement, and having counse
+(2) failed to meet government attorneys,
+as promised, on the day prior to his
+scheduled
+grand jury
+appearance
+(Blecksmith Aff. 11 5, 6);
+(3) failed to appear for his scheduled
+grand jury appearance on May 3, 1989
+(Blecksmith Aff. 17);
+(4) attempted to avoid service of a further subpoena on May 16, 1989
+(Blecksmith Aff. 19);
+(5) failed to appear for the rescheduled
+grand jury appearance on May 25, 1989
+(Blecksmith Aff. 1 11);
+) was convicted of violating 18 U.S.
+1074, unlawful flight to avoid prosec
+tion, for leaving Texas; in the factual resume accompanying his plea of guilty,
+which plea Defendant made before this
+very Court, Defendant specifically admitted leaving Texas to avoid testifying
+FN4. See supra n. 3.
+ment impermissibly
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMIE&ifm=NotSet&mt.. 6/8/2009
+
+
+
+provided under the Proffer Agreement as evidence
+to support his indictment. Alternatively, the De-
+fendant moves to suppress any statements, oral or
+written, that he made to law enforcement officials
+pursuant to the agreement and any evidence derived
+therefrom. The government responds asserting that
+the agreement permits the use of Wood's statements
+and urging the Court to deny Defendant's motion in
+total.
+II. DISCUSSION
+A. Breach of the Proffer Agreement.
+[1][2][3] Pretrial agreements, like plea bargains, are
+contractual in nature. United States v.
+Fulbright,
+804 F.2d 847, 852 (5th Cir.1986). Although principles of contract law
+generally apply to such
+these agreements require judicial supervision in order to safeguard a defendant's rights. United States
+v. Calabrese, 645 F.2d 1379, 1390 (10th Cir.1981),
+cert. denied, 454 U.S. 831, 102 S.Ct. 127, 70
+L.Ed.2d 108 (1982). When the government believes
+that a defendant has breached the terms of a proffer
+agreement and then wishes to rescind its part of the
+bargain, the government may not make this determination unilaterally. Instead,
+the government must
+prove to the court by a preponderance of the evidence that the defendant materially breached the
+agreement. United States v. Packwood, 848 F.2d
+1009, 1011 (9th Cir.1988); United States v. Verrusio, 803 F.2d 885, 891 (7th Cir.1986) ENs Where
+the facts are not in dispute, the court may determine
+breach as a matter of law. Calabrese, supra, 645
+F.2d at 1390.
+FN5. Courts are not unanimous about the
+precise level of the government's burden of
+persuasion on the issue of breach. See, eg
+United States v. Gonzalez-Sanchez, 825
+F.2d 572, 578 (Ist Cir.), (burden of proof
+by "adequate evidence"), cert. denied, 484
+U.S. 989, 108 S.Ct. 510, 98 L.Ed.2d 508
+(1987); United States v. Skalsky, 616
+F.Supp. 676, 681 (D.N.J.1985) (proof by
+clear and convincing evidence), aff'd, 857
+F.2d 172 (3d Cir. 1988). However, this
+Court is in agreement with the Seventh and
+Ninth Circuits that adequate protection for
+a defendant's rights is provided for by the
+preponderance standard, since the government must still establish beyond a reasonable doubt that the defendant did in fact
+commit the offense so charged. See Packwood, supra, 848 F.2d at 1109; Verrusio,
+supra, 803 F.2d at 890-91.
+[4] It is uncontroverted that the Defendant breached
+the agreement by a failure to meet his obligations
+required thereunder. Although Wood characterizes
+his actions as an inarticulate way of withdrawing
+from an agreement about which he had regrets,
+this phraseology does not conceal the fact that De-
+fendant does not actually contest the government's
+evidence of breach (e.g., failure to cooperate by
+meeting with government representatives, failure to
+appear before grand jury). Indeed,
+, *33 the Defendant has admitted to perhaps the most egregious asserted breach-that he fled Texas to avoid testifying,
+an admission of which the Court takes judicial notice. See supra n. 3. Because Wood refused to cooperate by failing to meet with government representatives,
+failing to testify before the grand jury,
+and eventually fleeing the jurisdiction to avoid cooperation altogether, the Court holds as matter of
+law that Wood has substantially and materially
+breached the Proffer Agreement. See United
+States v. Donahey, 529 F.2d 831, 832 (5th Cir.) (per
+curiam) (defendant breached cooperation agreement by giving evasive and misleading answers
+and refusing to answer certain questions),
+cert.
+denied, 429 U.S. 828, 97 S.Ct. 85, 50 L.Ed.2d 91
+(1976); United States v. Reardon, 787 F.2d 512,
+516 (10th Cir.1986) ( defendant breached agreement by failing to provide full accounting of his
+own activities); United States v. Irvine, 756 F.2d
+708, 710-11 (9th Cir. 1985) (defendant breached
+cooperation agreement by soliciting bribe even
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+though agreement only required defendant to be
+truthful; defendant's acts subverted "overriding
+purpose" of agreement).
+truthfully or refuses to testify the statute limits the
+government's remedy to a prosecution for perjury or
+contempt. The reason for this is clear: since the witness is compelled to testify over his or her fifth
+amendment privilege, the statute is constitutional
+"only if the immunity granted is equal to the constitutional protection it supplants." Irvine, 756 F.2d at
+B. The Government's Remedy.
+[5][6][7] Plea and non-prosecution agreements
+must be interpreted according to objective standards. Johnson V. Beto, 466 F.2d 478, 480 (Sth
+Cir. 1972) (per curiam). Where a non-prosecution
+agreement confers immunity for a defendant, the
+parties must look to and are governed by the agreement for their remedies arising from a breach.
+United States v. Castelbuono, 643 F.Supp. 965, 969
+(E.D.N.Y.1986). Thus, where a cooperation agreement so provides, the government may use the defendant's statements against him in the event of a
+defendant's breach. Irvine, supra, 756 F.2d at 712;
+States v. Doe, 671 F.Supp. 205, 208
+(E.D.N.Y.1987); Castelbuono, 643 F.Supp. at 969;
+United States v. Skalsky, 616 F.Supp. 676, 680
+(D.N.J.1985), aff'd, 857 F.2d 172 (3d Cir. 1988).
+[8] Wood argues that the government has adequate
+remedies other than using his statements to prosecute him, and that use of his statements would allow
+the government to have the benefit of the bargain
+while depriving Wood of the same. Specifically, the
+Defendant contends that the appropriate remedy is
+to hold him in contempt for failure to testify before
+the grand jury under a grant of immunity, as would
+be the case had the Defendant been
+granted
+"statutory immunity" pursuant to 18 U.S.C. §5
+6002-6003.
+18 U.S.C. §§ 6002 and 6003 set forth a procedure
+whereby, upon request of the United States Attorney, a court may order the testimony of an individual who asserts his or her fifth amendment privilege. However, the statute provides that no testimony or other information compelled under the order, or any information directly or indirectly derived therefrom, may be used against the individual
+in any criminal case, with this exception: where a
+defendant, granted statutory immunity, testifies un-
+Unlike statements given by a defendant pursuant to
+statutory immunity, however, those given by Wood
+under the Proffer Agreement were made voluntarily
+in exchange for a promise of nonprosecution.
+Wood's fifth amendment rights are not implicated
+in this situation. No As the government points out,
+it was only willing to take Mr. Wood's statements
+and promise not to prosecute him under the conditions that the statements were made voluntarily and
+that Wood acknowledged that a breach of the *34
+agreement's terms would result in a waiver of any
+rights to suppress the statements. The government
+was at all times prepared to give the Defendant the
+benefit of the bargain and continued to make attempts to get him to fulfill the agreement. NT
+FN6. See Irvine, 756 F.2d at 712:
+[The defendant] testified pursuant to an
+agreement entered into freely on his own
+initiative and for his own purposes. [He]
+was free to agree to conditions that could
+not have been imposed upon him had he
+chosen to claim his Fifth Amendment
+privilege.
+FN7. See supra n. 3.
+Thus, Defendant's complaint that the government is
+"having its cake and eating it too" is specious. As
+the Court stated in Irvine, "[t]here is no issue of
+compelled self-incrimination in this case. [The defendant] was not required to testify." Irvine, 756
+F.2d at 712. He did testify, freely and voluntarily,
+and his failure to continue testifying before the
+grand jury and his ultimate refusal to cooperate
+should not limit the government's remedies to those
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+provided for in a grant of statutory immunity.'*
+FN8. Furthermore, should the government
+be deprived of using Wood's statements,
+then Wood and other defendants might attempt to manipulate investigations and
+prosecutions without fear of any consequences. As the Castelbuono court
+noted, this would
+result in a bad public policy.... If this
+Court held that the Government was limited to a prosection for perjury or false
+statement in those cases where defendants in bad faith did not fully comply
+their obligations,
+would be reluctant ever to enter into a
+cooperation agreement and a useful investigative tool would be lost. Defendants facing the possibility of extensive
+criminal charges would be eager to enter
+into
+cooperation agreements
+knowing
+that if they were poorly drafted ... and
+did not specify
+with particularity the
+consequences related to
+every possible
+breach, it might be possible in bad faith
+not to comply with the demands of the
+agreement and still limit one's exposure
+to a charge of perjury. Also, a defendant
+could make no false
+statement at all,
+simply refuse to cooperate or cooperate
+in a very limited way, thereby selectively
+immunizing himself and face little, if
+any, penalty. The Court will not encourage such absurd results.
+Castelbuono,
+(emphasis added).
+643 F.Supp. at 969-70
+Instead, the remedial provisions contained in the
+Proffer Agreement govern the consequences resulting from Wood's breach, and they should be given
+effect.*N9
+As one
+noted, proffer
+agreements"cannot be unilaterally broken with impunity or without consequence." Reardon, supra,
+787 F.2d at 516 (citing Calabrese, 645 F.2d at
+Page 7
+1390). Having failed to perform his obligations, the
+Proffer Agreement provides that the Defendant is
+no longer entitled to the government's promise of
+non-prosecution or the promise that his statements
+would not be used against him.Enid See Castelbuono, 643 F.Supp. at 969. Thus, the Defendant's
+indictment was wholly proper even if it was issued
+as a result of statements he made under the agreement and his request that these statements be suppressed must be denied. NI!
+FN9. See supra p. 33.
+FNI0. See supra n. 2.
+FNI1. Defendant's reliance on United
+States v. Brown, 801 F.2d 352 (8th
+Cir.1986), is misplaced. In Brown, the
+Eighth Circuit determined that the defendant had breached a cooperation agreement, thus permitting the government to
+prosecute him for the criminal conduct
+forming the basis of the agreement. The
+court also ruled that the government could
+not use any information, directly or indirectly, that was obtained under the plea
+agreement including the defendant's admissions. Although the court did not explicitly say so, this result was dictated by the
+fact that the agreement specifically prohibited the use of these statements except
+in a prosecution for perjury or false statement. Id. at 353. Again, the remedies
+available upon the occurrence of a breach
+were prescribed by the agreement itself
+like Sections TWO and THREE of Wood's
+the government's remedies
+C. Fed.R. Crim.P. 11(e) (6).
+[9] Federal Rule of Criminal Procedure 11(e)(6) of
+fers no help to the Defendant. This rule prohibits
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt.. 6/8/2009
+
+
+
+admission of "any statement made in the course of
+plea discussions with an attorney for the government which do not result in a plea of guilty or
+Rule 11(e)(6), however, applies only to those statements leading up to the agreement and not those
+made subsequent to it. United States v. Stirling, 571
+F.2d 708, 731-32 (2d Cir.) (purpose of the rule is to
+facilitate free and fearless negotiations to encourage
+pleas; policy not served by ruling inadmissible
+testimony given after *35 agreement reached), cert.
+denied, 439 U.S. 824, 99 S.Ct. 93, 58 L.Ed.2d 116
+(1978); see also United States v. Davis, 617 F.2d
+677, 685 (D.C.Cir.1979) (ruling post-agreement
+statements inadmissible would permit defendant to
+"renounce the agreement and return to the status
+quo ante whenever he chose, even though the Government has no parallel power to rescind the compromise unilaterally"; holding that drafters of Rule
+11(e)(6) could not have contemplated such a res- ult).
+Since the Defendant and the government attorneys
+negotiated, modified, and signed the Proffer Agreement prior to Wood's making of the statements and
+notes sought to be suppressed, these statements
+were not made in the course of plea discussions.
+Consequently, Fed. R.Crim.P. 11(e)(6) does not protect them from evidentiary use.
+Page 8
+III. CONCLUSION
+For the reasons stated above, no hearing is necessary to resolve Defendant Wood's Motion to Dismiss Indictment or to Suppress Statements. The undisputed facts and arguments before the Court dictate that Defendant's Motion be, and it is hereby,
+DENIED.
+SO ORDERED.
+N.D.Tex.,1990.
+U.S. v. Tarrant
+END OF DOCUMENT
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt.. 6/8/2009
+
+
+
+H
+United States District Court,
+S.D. New York.
+UNITED STATES of America,
+V.
+Steven HOFFENBERG, Defendant.
+No. 94 Cr. 0273 (RWS).
+Dee. 18, 1995.
+After government terminated cooperation agreement with defendant due to defendant's untruthfulness, defendant moved to enforce agreement. The
+District Court, Sweet, J., held that: (1) defendant
+breached agreement, and (2) government did not act
+in bad faith in refusing to move for downward departure after learning of defendant's untruthfulness.
+Motion denied.
+Page 1
+At postconviction hearing, government has burden
+to prove breach of plea agreement by preponder
+ance of evidence; such standard is consistent with
+standard of proof courts have required to resolve
+other postconviction disputes, such as disputed sentencing issues.
+[3] Criminal Law 110 ~ 273.1(2)
+110 Criminal Law
+110XV Pleas
+110k272 Plea of Guilty
+110k273.1 Voluntary Character
+110k273.1(2)
+k. Representations,
+Promises, or Coercion; Plea Bargaining. Most Cited
+Where defendant has promised to disclose truthfully all information about which government inquires, any false statement, misleading statement,
+or omission concerning defendant's activity for area
+about which government has inquired, is material
+breach of plea agreement.
+[4] Criminal Law 110 €~ 273.1(2)
+110 Criminal Law
+110XV Pleas
+110k272 Plea of Guilty
+110k273.1 Voluntary Character
+110K273.1(2)
+k. Representations,
+Promises, or Coercion; Plea Bargaining. Most Cited
+West Headnotes
+[1] Criminal Law 110 €~ 273.1(2)
+110 Criminal Law
+110XV Pleas
+110k272 Plea of Guilty
+110k273.1 Voluntary Character
+110k273.1(2)
+k. Representations,
+Promises, or Coercion; Plea Bargaining. Most Cited
+Party who materially breaches cooperative or plea
+agreement may not claim its benefits.
+[2] Criminal Law 110 €m1615
+110 Criminal Law
+110XXX Post-Conviction Relief
+110XXX(C) Proceedings
+|10XXX(C)2 Affidavits and Evidence
+110k1615 k. Degree of Proof. Most
+Cited Cases
+(Formerly 110k997.15(6), 110k997.15(2))
+agencies, defendant breached terms of plea agreement, which obligated him to truthfully disclose all
+information concerning matters about which the
+government inquired, to inform government of any
+new business ventures, and to refrain from committing further crimes, where he lied about his involvement in the operation of a collections agency and
+about the independence of its president, and he
+failed to disclose his involvement in a second collections agency.
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+15] Criminal Law 110 Em 42.5(3)
+110 Criminal Law
+110Il Defenses in General
+110k42 Immunity to One Furnishing Information or Evidence
+110k42.5 Agreements Granting Immunity
+110k42.5(3) k. Performance
+and
+Breach. Most Cited Cases
+(Formerly 110k42)
+Opportunity to cure doctrine does not apply to cooperation agreements, as that doctrine operates
+only in civil contexts.
+[6] Criminal Law 110 € 42.5(3)
+110 Criminal Law
+110II Defenses in General
+110k42 Immunity to One Furnishing Information or Evidence
+110k42.5 Agreements Granting Immunity
+110k42.5(3) k. Performance and
+Breach. Most Cited Cases
+(Formerly 110k42)
+Before terminating cooperation agreement due to
+breach, government was only required to give defendant opportunity to confront allegations that he
+had breached agreement and provide innocent explanation.
+17] Sentencing and Punishment 350H Ev2947
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(H) Proceedings
+350HIV(H)1 In General
+350Hk947 k. Effect of Cooperation
+Agreement or Other Promise or Representation.
+Most Cited Cases
+(Formerly 110k1306)
+When cooperation agreement allows for a substanment's evaluation of defendant's cooperation, government has wide discretion in determining whether
+to make such a motion. U.S.S.G. § 5K1.1, 18
+U.S.C.A.
+Page 2
+[8] Senteneing and Punishment 350H Em 947
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(H) Proceedings
+350HIV(H)1 In General
+350Hk947 k. Effect of Cooperation
+whether government acted in bad faith. U.S.S.G. §
+SK1.1, 18 U.S.C.A.
+[9] Criminal Law 110 Em 273.1(2)
+110 Criminal Law
+110XV Pleas
+110k272 Plea of Guilty
+110k273.1 Voluntary Character
+110k273.1(2)
+k.
+Representations,
+Promises, or Coercion; Plea Bargaining. Most Cited
+Cases
+Sentencing and Punishment 350H @m0947
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(H) Proceedings
+350HIV(H)| In General
+350Hk947 k. Effect of Cooperation
+Agreement or Other Promise or Representation.
+(Formerly 110k1306)
+assistance moan by reging on mas a subtial
+at time it entered into agreement; such decision
+[10] Criminal Law 110 Em 273.1(2)
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt... 6/8/2009
+
+
+
+Page 3
+110 Criminal Law
+110XV Pleas
+110k272 Plea of Guilty
+110k273.1 Voluntary Character
+110k273.1(2)
+Representations,
+Promises, or Coercion; Plea Bargaining. Most Cited
+Cases
+Sentencing and Punishment 350H €m 947
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(H) Proceedings
+350HIV(H)| In General
+350Hk947 k. Effect of Cooperation
+Agreement or Other Promise or Representation.
+Most Cited Cases
+(Formerly 110k1306)
+Where government enters into cooperation agreement in good faith, believing defendant's representations, and government subsequently learns that defendant has lied and breached terms of agreement,
+government's dissatisfaction with defendant's performance, and a refusal to make a substantial assistance motion, are justified. U.S.S.G. § 5K1.1, 18
+U.S.C.A.
+[11] Sentencing and Punishment 350H €m947
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(H) Proceedings
+350HIV(H)| In General
+350Hk947 k. Effect of Cooperation
+Agreement or Other Promise or Representation.
+Most Cited Cases
+(Formerly 110k1306)
+Sentencing and Punishment 350H €m 989
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(H) Proceedings
+350HIV(H)3 Hearing
+350Hk989 k. Necessity for Hearing.
+Most Cited Cases
+(Formerly 110k1316)
+When defendant claims that government has acted
+in bad faith in refusing to move for downward departure, as agreed upon in cooperation agreement,
+government may then rebut allegation, explaining
+its reason for refusing to so move; defendant must
+then make some showing of bad faith to trigger
+hearing on issue. U.S.S.G. § 5K1.1, 18 U.S.C.A.
+[12] Sentencing and Punishment 350H Em0947
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(H) Proceedings
+350HIV(H)| In General
+350Hk947 k. Effect of Cooperation
+Agreement or Other Promise or Representation.
+Most Cited Cases
+(Formerly 110k1306)
+Despite some early knowledge of defendant's
+breach of cooperation agreement, government did
+not act in bad faith in finally terminating agreement
+and in refusing to move for downward departure
+from Sentencing Guidelines, since defendant's
+failure to comply with agreement, by repeatedly
+correcting and changing his story and helping subor perjury, made his information not entirely useful. U.S.S.G. § 5K1.1, 18 U.S.C.A.
+[13] Sentencing and Punishment 350H Em947
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(H) Proceedings
+350HIV(H)| In General
+350Hk947 k. Effect of Cooperation
+[14] Sentencing and Punishment 350H Em0947
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(H) Proceedings
+350HIV(H)| In General
+350Hk947 k. Effect of Cooperation
+Agreement or Other Promise or Representation.
+Most Cited Cases
+(Formerly 110k1306)
+n evaluating degree of defendant's cooperation un
+ler plea agreement, it is proper for government to
+consider defendant's truthfulness; defendant must
+be honest if he hopes to achieve benefit of provision for motion for downward departure of sentencing. U.S.S.G. § 5K1.1, 18 U.S.C.A.
+[15] Criminal Law 110 € 273.1(2)
+110 Criminal Law
+110XV Pleas
+110k272 Plea of Guilty
+110k273.1 Voluntary Character
+110k273.1(2)
+Representations,
+Promises, or Coercion; Plea Bargaining. Most Cited
+Cases
+Under cooperation agreement, government may
+permit defendant to cure his dishonesty, but it is not
+required to do so and need not do so continuously.
+[16] Sentencing and Punishment 350H €947
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(H) Proceedings
+350HIV(H)| In General
+350Hk947 k. Effect of Cooperation
+Agreement or Other Promise or Representation.
+Most Cited Cases
+(Formerly 110k1306)
+Even if defendant's untruths are not central to cooperation agreement with government, if lies are
+deemed material to evaluation of truthfulness, government, absent unconstitutional or bad faith motivation, is free not to move for downward departure
+of sentencing. U.S.S.G. § 5K1.1, 18 U.S.C.A.
+*1266 Mary Jo White, United States Attorney for
+Southern District of New York, New York City, for
+United States of America; Amy E. Millard, Jonathan Rosenberg, Assistant U.S. Attorney of counsel.
+Hoffman & Pollok New York City, for defendant;
+Jeffrey Hoffman, Susan C. Wolfe, of counsel.
+SWEET, District Judge.
+has moved under the unusual circumstances de
+scribed below to enforce the Cooperational Plee
+of September 23,
+Agement) between offenberg and the United
+States Attorneys for the Southern District of New
+York and the Northern District of Illinois (the
+"Government").
+Upon the hearing on contested facts, the prior proceedings and the facts and conclusions set forth below, the motion is denied.
+The Issues
+This proceeding sets the framework for the final
+resolution of the responsibility of Hoffenberg for
+the massive frauds at his company, Towers Financial Corporation ("Towers") in the early 90's which
+resulted in more than $400 million in losses. While
+other cases involving the fraud remain open, Hoffenberg's sentence upon his criminal liability may
+well turn upon the applicability of the Section
+5K1.1(a)(1)-(5) exception
+to
+the
+Sentencing
+Guidelines which he has sought to enforce in this
+proceeding.
+This determination must resolve the following issues: (1) the applicable standard and procedures for
+the enforcement of cooperation agreements, (2) the
+factual findings as to the conduct of Hoffenberg
+and the Government, (3) the effect of any partial
+*1267 performance by the Government, and (4) the
+propriety of the Government's refusal to comply
+with the Agreement. It is anticipated that with these
+determinations in hand the Government and Hoffenberg will proceed to a sentencing hearing.
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft-HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+Prior Proceedings
+The prior proceedings have been described in prior
+opinions of this Court familiarity with which is assumed. See United States v. Hoffenberg.
+859
+F.Supp. 698 (S.D.N.Y.1994) (the "July Opinion"),
+United States v. Hoffenberg. 1995 WL 10840
+(S.D.N.Y. Jan. 12, 1994). Some restatement is required in the interest of continuity.
+Sometime prior to 1991, Hoffenberg and a number
+of corporate entities with which he was associated,
+including Towers, and others, came under investigation by the Securities & Exchange Commission
+("SEC"). The SEC filed an action in this District
+against Hoffenberg and others on February 8, 1993,
+and on February 17, 1993, Hoffenberg and certain
+other defendants agreed to a preliminary injunction
+issued by the Honorable Whitman
+Knapp (the
+"Consent Order") which, among other things, enjoined Hoffenberg and "each of his controlled, related, or affiliated
+entities .. to hold and retain
+within their control, and otherwise prevent any
+withdrawal, transfer, pledge, encumbrance, assignment, dissipation, concealment, or other disposal of
+any funds, or other properties." It also allowed for
+"ordinary living and business expenses...."
+In 1993 the United States Attorney for the Southern
+District of New York began a criminal investigation
+against Hoffenberg and others for conspiracy to obstruct the SEC's
+investigation during
+1991 and
+1992, and for various other criminal violations of
+the securities laws.
+In March 1993 Hoffenberg, through counsel, initiated a number of meetings which culminated in an
+oral understanding. Pursuant to that understanding,
+Hoffenberg agreed to talk to representatives of the
+United States Attorney's Office for the Southern
+District of New York and the Northern District of
+On September 24, 1993, Hoffenberg and the Government entered into the Agreement dated September 23, 1993.
+On January 27, 1994, and on February 14, 1994, the
+Government confronted Hoffenberg with allegations that he had violated his obligations under the
+Agreement. On February 17 he was advised that the
+Agreement had been terminated, and he was arres-
+On April 19, 1994 he was indicted in the Northern
+District of Illinois on fraud charges. On April 20,
+1994 he was indicted in the Southern District of
+New York and charged with the four counts contemplated in the Agreement, as well as six additional counts alleging substantive securities fraud violations in connection with the sale of notes and bonds
+of Towers; additional violations of the mail fraud
+statute, and obstruction of justice by disobeying an
+order of the United States District Court for the
+Southern District of New York.
+Hoffenberg moved to enforce the Agreement and
+by opinion dated July 21, 1994 (the "July Opinion"), see United States v. Hoffenberg, 859 F.Supp.
+698 (S.D.N.Y.1994), his motion was denied as premature. He then moved to reargue his earlier motion and to suppress the statements which he had
+made in reliance upon the Agreement, which motion was denied by an opinion rendered on January
+11, 1995 (the "January Opinion").
+After the filing of the Indictment against him, the
+Government continued to permit him to plead to the
+charges as had been set forth in the Agreement and
+tax evasion.
+his proffers or debriefings.
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+in Section 5K1.1(a)(1)-(5) of the Sentencing
+Guidelines (the "SK1 Letter"). The parties in a pretrial conference*1268 agreed upon the necessity of
+a hearing to resolve the factual contentions. From
+June 5 to June 14, 1995, the parties submitted evidence by way of testimony and exhibits. Post hearing
+briefs were filed. On September 12, 1995 final argument was heard. A final submission was made to
+the Court on December 1, 1995 and the issues were
+considered fully submitted at that time.
+Facts
+The Background and the Agreement
+Sometime in 1991 Hoffenberg and a number of corporate entities with which he
+was
+associated, including Towers, came under investigation by the
+SEC for securities fraud arising out of the affairs of
+Towers. On February 8, 1993, the SEC filed an action in this District. See SEC v. Towers Financial
+Corporation, et al., 93 Civ. 0744, 1993 WL 276935
+(1993) (WK) (the "SEC Action"'). As it related directly to Hoffenberg, the complaint alleged that he
+violated the anti-fraud provisions of the securities
+laws by false and misleading
+statements to investors who had purchased $215 million in promissory notes issued by Towers. The SEC also charged
+Hoffenberg with failing to register the offerings of
+promissory notes with
+the SEC, and selling his
+Towers common stock while in possession of inside
+information that the stock was worthless.
+In early 1993, the United States Attorney for the
+Southern District of New York commenced the
+criminal investigation against Hoffenberg and others for conspiracy to obstruct the SEC's investiga-
+District of Illinois with respect to a scheme to defraud the Illinois Department of Insurance and two
+Illinois insurance companies acquired by Towers.
+In March 1993, Hoffenberg and the Government
+agreed that Hoffenberg would talk to representatives of the United States Attorney's Office for the
+Southern District of New York and Northern District of Illinois, the FBI and the SEC and receive
+limited immunity for these proffers. On at least 22
+separate occasions, Hoffenberg and his counsel met
+with representatives of the Government who were
+interested in the subject matter of Hoffenberg's de-
+On September 24, 1993, the parties entered into the
+Agreement, dated September 23, which provided
+that Hoffenberg would be charged with the four
+felony counts in a Southern District Information. It
+was further agreed that Hoffenberg would plead
+guilty to and be sentenced in this District on an information filed in the Northern District of Illinois,
+charging him with one count of mail fraud.
+The Agreement also provided in relevant part as
+follows:
+If Steven Hoffenberg fully complies with the understandings specified in this Agreement, he will not
+be further prosecuted by the Offices for any crimes
+related to his participation in: (i) the fraudulent sale
+of unregistered debt securities, namely, promissory
+notes and bonds, of Towers Financial Corporation
+("Towers") from in or about 1986 through in or
+about February 1993; (ii) making illegal payments
+to representatives of pension funds to induce the
+purchase of Towers' securities,
+from in or about
+1989 to in or about February, 1993; (iii) making illegal payments to representatives of a foreign country in order to secure a loan to Towers from that
+country's bank, from in or about 1989 to in or about
+February 1993; (iv) obstructing the Securities and
+Exchange Commission's investigation of the fraud
+ulent sale of Towers' securities from in or abou
+1988 to in or about September 1993; (v) a scheme
+to illegally convert to Towers' use monies collected
+by Towers as collection agent for its clients, from
+in or about 1980 to in or about April 1993; (vi) the
+failure to report on his Individual U.S. Income Tax
+Returns for the calendar years 1987 through 1991
+income Steven Hoffenberg obtained by having cor-
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+porate entities controlled by him pay his personal
+expenses; and (vil) a scheme to defraud, misappropriate, and misuse the funds and assets of two
+Chicago insurance companies, from in or about Oc-
+tober 1987 to in or about 1992. In addition, if
+Steven Hoffenberg fully complies with the understandings specified in *1269 this agreement, no
+testimony or other information given by him (or
+any other information directly or indirectly derived
+from such testimony or other information) will be
+used against him in any prosecution for criminal tax
+violations not described above. This Agreement
+does not provide any protection against prosecution
+for any crimes except as set forth above.
+The understandings are that Steven Hoffenberg
+shall truthfully disclose all information with respect
+to the activities of himself and others concerning all
+matters about which the Offices inquire of him,
+shall cooperate fully with the Offices, the Securities
+and Exchange Commission, the Federal Bureau of
+Investigation, the
+Internal Revenue Service, the
+United States Postal Inspection Service and any
+other law enforcement agency so designated by the
+Offices, shall attend all meetings at which his presence is requested with respect to the matters about
+which the Offices inquire of him, and further, shall
+truthfully testify before the grand jury and/or at any
+trial or other court proceeding with respect to any
+matters about which the Offices may request his
+testimony. Any assistance Steven Hoffenberg may
+provide to federal criminal investigators shall be
+pursuant to the specific instructions and control of
+the Offices and those investigators. This obligation
+of truthful disclosure includes an obligation upon
+Steven Hoffenberg to provide to the Offices, upon
+request, any document, record or other tangible
+Page 7
+not and do not make any promise or representation
+as to what sentence Steven Hoffenberg will receive,
+nor will they recommend any specific sentence to
+the sentencing judge. However, the Offices will inform the sentencing judge and the Probation De-
+partment of: (i) this Agreement; (ii) the nature and
+extent of Steven Hoffenberg's activities with respect to this case; and (iii) the full nature and extent
+of Steven Hoffenberg's cooperation with the Of-
+fices and the date when such cooperation commenced. In addition, if it is determined by the Of-
+fices that Steven Hoffenberg has provided substantial assistance in an investigation or prosecution,
+and if Steven Hoffenberg has otherwise complied
+with the terms of this Agreement, the Offices will
+file a motion, pursuant to Section SK1.1 of the Sentencing guidelines, advising the sentencing judge of
+all relevant facts pertaining to that determination
+and requesting the Court to sentence Steven Hoffenberg in light of the factors set forth in Section
+5K1.1 (a)(1)-(5).
+******
+It is further understood that Steven Hoffenberg
+must at all times give complete, truthful, and accurate information and testimony and must not commit
+any further crimes whatsoever. Should Steven Hoffenberg commit any further crimes or should it be
+determined that he has given false, incomplete, or
+misleading testimony or information, or should he
+otherwise violate any provisions of this Agreement,
+Steven Hoffenberg shall thereafter be subject to
+prosecution for any federal criminal violation of
+which the Offices have knowledge, including,
+but
+not limited to, perjury and obstruction of justice.
+(emphasis added).
+The Cooperation
+******
+It is further understood that the sentence to be imposed upon Steven Hoffenberg is within the sole
+discretion of the sentencing judge. The Offices can-
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt.. 6/8/2009
+
+
+
+("Nardello") who was responsible for the criminal
+investigation surrounding the affairs of Towers. He
+also testified before the grand jury on January 13
+and 14, 1994 and at the Government's direction engaged in recorded conversation.
+The Government does not contend that Hoffenberg
+failed to perform the agreement by refusing to give
+information with respect *1270 to Towers or to perform requested acts. However, during the latter
+quarter of 1993 and the early part of 1994, agents
+of the SEC advised the United States Attorney's Of-
+fice that Hoffenberg was not complying with the
+Consent Order of February 17, 1993, but rather that
+he made statements and representations which were
+false in connection with ongoing matters involving
+the Consent Order and thereby violated the Agreement.
+Page 8
+The Representations
+Throughout 1993 the Government remained conabout Hoffenberg's compliance
+with the
+Consent Order entered in the SEC Action which
+had required Hoffenberg to provide an accounting
+of all his assets. Of particular concern was Hoffenberg's involvement with Diversified Credit Corporation ("DCC"), anther collections corporation
+which Hoffenberg set up prior to the termination of
+his relationship with Towers. DCC was to do business in a manner similar to that conducted by
+Towers. A second area of concern relating to the
+Consent Order related to certain payments made to
+Hoffenberg and finally his relationship to Stratford
+Credit Corporation ("Stratford") which was started
+in December 1993.
+a. DCC
+Following his termination from Towers, Hoffenfice, nor any real influence over DCC's independent
+president, Lawrence Lowy ("Lowy").
+These representations were significant. In a collection business, such as had been conducted by DCC
+or its predecessor Towers, the operations side controlled the money collected on behalf of clients.
+According to the SEC and the Government, certain
+of the fraudulent activity at Towers centered around
+the failure of operations employees, at the direction
+of Hoffenberg and his co-conspirators, to remit
+funds to Towers' clients. By the representation of
+separation from the collections side of DCC, Hoffenberg gave assurances that (1) he would not defraud DCC collections clients as he had done at
+Towers, and (2) DCC would not be used as a
+vehicle to violate the Consent Order.
+In June 1993, Hoffenberg told Nardello that he was
+not receiving any money from DCC. At a proffer
+session on August 25, 1993, Nardello again confronted Hoffenberg with concerns that his role at
+DCC was greater than he had revealed. As of Au-
+gust 25, 1993, the SEC had provided Nardello with
+a list of questions and allegations to use in confronting Hoffenberg on the issue of whether DCC
+fell within the Consent Order with respect to assets.
+In addition, on August 25, 1993, the SEC faxed to
+Nardello a summary of allegations concerning the
+issue of Hoffenberg's control of DCC. That summary included allegations (1) that Hoffenberg
+provided funding for DCC, a fact that Hoffenberg
+had already told the Government, and (2) that Hoffenberg made decisions at DCC. The allegations
+about Hoffenberg's decision-making at DCC came
+from an officer of DCC who worked in the Midwest
+who stated that (I) he and Hughes reported to Hofself to DCC's clients as the decision-maker.
+At that proffer session on August 25, 1993, when
+Nardello confronted Hoffenberg with his concerns
+that Hoffenberg's role was greater than he had revealed, Hoffenberg admitted that DCC had been
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt.. 6/8/2009
+
+
+
+paying for his chauffeur, his maids, and his boat
+captain, but denied any greater involvement in the
+company than what he had already revealed. He insisted that he was not involved in collections or operations. Hoffenberg stated at this meeting that he
+held preferred, non-voting stock in DCC and therefore could not make the financial decisions. He acknowledged his desire to protect his substantial investment and his hope that, if DCC were successful, he could ultimately reach an agreement with the
+SEC allowing him to earn money from DCC. Nardello told Hoffenberg that his use of DCC to pay
+his expenses constituted a violation of the Consent
+Order, that it would have to be disclosed to the
+SEC, and that it would have to "stop *1271 immediately." Hoffenberg's admission that he had violated the Consent Order with specific payments supported the Government's view that Hoffenberg then
+understood his obligations under the Agreement.
+Nardello agreed to execute the Agreement with
+Hoffenberg one month later after obtaining Hoffenberg's assurances that he understood his obligations
+under the Agreement, that he would thereafter walk
+the straight and narrow, and that he had disclosed
+all his bad acts.
+Hoffenberg maintained throughout his meetings
+with Nardello that Lowy was "running" DCC, that
+Lowy was independent, and that Hoffenberg could
+not influence Lowy's decisions. When DCC went
+out of business in or about January 1994, Hoffenberg stated that Lowy had "run it into the ground."
+Hoffenberg stated that when he had met with Lowy
+in connection with the latter's testimony he had
+done so only to refresh Lowy's recollection.
+formation indicating his representations relating to
+DCC were false, Hoffenberg told Nardello that his
+Page 9
+b. Stratford
+Nardello was concerned about the potential impact
+of any new business venture on Hoffenberg's utility
+as a witness and cooperator. His compliance with
+the Consent order, as the Government saw it, required that any new business venture had to be
+cleared with the SEC in order to ensure that such
+venture did not violate the Consent Order and that
+Hoffenberg was not positioning himself to revert to
+the criminal practices he had purported to leave behind. Consequently, Nardello instructed Hoffenberg
+that he notify the Government of any contemplated
+business venture. In October 1993, Nardello gave
+this specific instruction and Hoffenberg agreed.
+In December 1993, as DCC became insolvent, Hoffenberg started a new collections company, Stratford Credit Corporation. Hoffenberg did not advise
+Nardello that he had started Stratford.
+On December 22, 1993 Nardello asked Hoffenberg
+wad an usiness. in tier stared par iating ork
+and Haley Capital and omitted any mention of
+Stratford.
+When questioned point blank about Stratford, Hoffenberg stated that he had been "approached by others" to join Stratford, which he characterized as an
+ongoing business, formed by some ex-Towers employees, and that nothing had come of it. Nardello
+instructed Hoffenberg not to take any further action
+in Stratford until the matter could be considered
+involved with collections.
+The Falsity of the Representations
+Throughout 1993 the SEC had continued its investigation into Hoffenberg's compliance with the Consent Order. At the same time the United States At-
+torney's Office continued its investigation into the
+affairs of Towers. Meanwhile, Towers had filed a
+petition in bankruptcy, a Trustee had been appointed, and he too conducted hearings related to
+Towers' assets. As a consequence of these investig-
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+ations, the misrepresentations of Hoffenberg were
+discovered.
+Page 10
+a. DCC
+In May 1993, Hoffenberg was advised by one of his
+counsel, Martin Brecker of Anderson Kill that in
+order to avoid the terms of the Consent Order with
+respect to DCC, Hoffenberg needed to establish
+that, notwithstanding the legalities, Hoffenberg did
+not, in fact, control DCC. Further, in order to avoid
+losing DCC to the Towers Trustee in bankruptcy,
+Hoffenberg needed to show that he was not using
+DCC for his own benefit to the detriment of DCC.
+Hoffenberg instructed employees at the Long Island
+office to tell the public that he was just a consultant
+and that his only office was in New York.
+However, Hoffenberg closely supervised DCC's
+collections activities at the Long Island office. Re-
+gina Loveless ("Loveless") was an employee in the
+Long Island office from March 1993 through *1272
+the middle of October 1993. She testified that beginning in May and continuing until she left DCC,
+Hoffenberg was actively involved in the superviginning in May 1993, it seemed "like there was a
+higher management above Larry and Brian [Lowy]."
+During his first meeting with Loveless, Hoffenberg
+discussed with her "strategy and tactics" for the accounts assigned to her, instructed her to be more
+aggressive with debtors and to refer more cases to
+litigation, and to obtain the litigation fees from the
+DČC creditors, and directed her to provide him
+with a weekly status report on all cases referred to
+the legal department. In June 1993, Hoffenberg installed his longtime confidante Michael Rosoff as
+he head of the DCC legal department. Hoffenberg
+told Loveless that whenever she needed to discuss
+ollections matter and could not reach Rosoff, sh
+hould call Hoffenberg. But for any settlement ove
+$50,000, Hoffenberg instructed Loveless to confer
+with him, whether or not Rosoff was available.
+Hoffenberg also instructed Loveless not to discuss
+settlements with clients.
+From May 1993 until her departure in October
+1993, Loveless spoke with Hoffenberg over the
+telephone about her cases three to four times per
+month. Hoffenberg also visited the Long Island office once or twice per week for several hours a vis-
+. During those visits, Hoffenberg regularly me
+with John Hannon, the manager of the collection
+staff, and would conduct detailed debriefings of
+Hannon regarding the status of collections. If any
+large collection matter was pending, Hoffenberg
+would go directly to the collector assigned to the
+account and obtain detailed information. During his
+visits, Hoffenberg would walk around the office
+asking collectors "how much did you collect for me
+today?"
+Beginning in May 1993, the same time that Hoffenberg became involved with operations at the Long
+Island office, Loveless was instructed at least once
+a month by Sidney Friedfertieg, the manager of
+customer service, "not to tell the clients about any
+payments we received." Friedfertieg told Loveless
+to lie to clients inquiring about their money by
+telling them that "the computer was down." When
+Loveless asked why she should conduct business
+this way, Friedfertieg responded that it was what
+Hoffenberg wanted. In addition, Hoffenberg was
+present when Lowy instructed Loveless not to insert in DCC's computer records DC's collection of
+more than $100,000 for Loew's Hotel Corporation.
+According to Lowy, soon after Hoffenberg was dis-
+1993, ad byoh Ting us banketal or Truse in April
+He [Hoffenberg] wanted to know the amount of
+collections everyday, he wanted to know what th
+deposits were everyday. He came out usually once
+or twice a week at that time and took payroll registers and sometimes the registers in the checkbook to see what was being deposited.
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+* 908 F.Supp. 1265
+Lowy further testified that in approximately August
+1993, Hoffenberg replaced him as head of the Long
+Island
+office
+with Charles
+Chugerman
+("Chugerman"), an associate of Hoffenberg at
+Towers. Thereafter, Chugerman supervised Loveless's accounts, and told Loveless that she should
+call Hoffenberg on any matter whenever she could
+not reach Chugerman or Rosoff:
+Martin Brecker never mentioned to Hoffenberg the
+term "Chinese Wall."
+Lowy was not independent but was dominated by
+Hoffenberg. Lowy had worked for Hoffenberg for
+years and owed essentially his entire career to Hoffenberg.
+Hoffenberg controlled Lowy's activities at DCC
+from small management decisions, such as changing the name of Frederick Lawrence Associates to
+DCC, to hiring employees.
+In April 1993, Hoffenberg
+"basically took over the
+company," according to Lowy, and thereafter Lowy
+reported to him on nearly every detail of DCC's
+business. When a group of Towers employees indicated that they did not want to work at DCC if it
+meant working for Lowy, Hoffenberg assured them
+that they would be working for him. Beginning in
+May 1993, the ultimate authority to *1273 whom
+DCC collectors in the Long Island office were supposed to report was Hoffenberg, not Lowy. When
+Lowy complained to Hoffenberg about the burgeoning payroll in the spring of 1993, Hoffenberg
+rebuffed him by saying it was his company. When
+Hoffenberg needed employees for Her New York,
+he took them from DCC. When Hoffenberg felt it
+appropriate to oust Lowy as a supervisor in the
+Long Island office, he did so, and installed Chuger-
+Lowy retained Alan Fraade for DC's corporate
+work. Fraade had a longstanding relationship with
+Hoise counsed at Tolera: orien berg seles
+and discharged lawyers to defend Lowy's depos-
+Page 11
+ition before the SEC. When Lowy spoke with Frank
+Wohl about the nature of his representation of
+Lowy, Hoffenberg instructed Lowy never to speak
+with a lawyer outside his presence, and discharged
+Wohl. Lowy accepted Brecker's representation,
+who had been selected by Hoffenberg, notwithstanding his knowledge that Brecker had a preexisting relationship with Hoffenberg, and that if a conflict arose, Brecker would represent Hoffenberg
+Thereafter, Hoffenberg frequently discussed with
+Brecker the status of Brecker's representation of
+Lowy, including whether Lowy should refuse to
+testify based on his Fifth Amendment privilege.
+Hoffenberg also involved his long-time associate
+and counsel Michael Rosoff into Lowy's representation.
+Hoffenberg also extracted money from DCC in
+ways not revealed to Nardello. Hoffenberg obtained
+blank checks from DCC, which he used for his own
+personal benefit, which was not disclosed until
+January 27, 1994, when he was again confronted by
+Nardello and told that the Government was contemplating the repudiation of the Agreement. Hoffenberg also arranged for DCC to pay certain of his
+personal American Express bills. Additionally,
+Hoffenberg obtained free labor at DCC's expense
+by using several employees on DCC's payroll to do
+the work of his publication, Her New York. This information was admitted by Hoffenberg at his February 14, 1994 session.
+Hoffenberg had met with Lowy in May 1993 and
+knew that meeting with a witness to influence his
+future testimony was criminal conduct. Hoffenberg
+knew that Lowy's truthful testimony regarding their
+activities at DCC would be harmful to his litigation
+position and therefore told Lowy what to say.
+to this ring the Governient, Low had to else.
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+public as just a DCC consultant.
+Lowy and Joseph Hughes ("Hughes") testified
+falsely before the Towers' Trustee in bankruptcy.
+Each, at Hoffenberg's behest, minimized the appearance of Hoffenberg's control of, and role in,
+DCC. At his SEC deposition on May 26, Lowy testified as to Hoffenberg's role as a sales consultant.
+Lowy testified on September 28 before the bankruptcy trustee that Frederick Lawrence Associates
+was a successful business doing "several million
+dollars a year in gross sales" before it became
+DCC, that Hoffenberg had no control over the disposition of Diversified Holding's funds, that those
+funds were solely within Lowy's control, that Lowy
+ran DCC, and that Lowy had no substantive discussion with Hoffenberg about his deposition testimony.
+Hughes testified that Lowy ran the New York office
+of DCC, that Hoffenberg did not have an office at
+DCC, and that Hughes had not spoken to Hoffenberg about his deposition.
+Hughes and Lowy had previously made false statements and covered up for Hoffenberg. During the
+1980's, when Hoffenberg's business, Westwood Pa-
+per and Hardware,
+was in bankruptcy, Low
+obeyed Hoffenberg's instructions to
+destroy the
+company's books and records. In 1992, when
+Towers was in litigation with Dunn & Bradstreet,
+Hughes followed Hoffenberg's and Rosoff's instructions to perjure himself in deposition testimony and
+affidavits.
+*1274 Hughes testified that Hoffenberg influenced
+his testimony and that during early 1994, Hoffenberg and Rosoff arranged for him and two others to
+sign affidavits falsely characterizing the respective
+roles of Hoffenberg and Lowy at DCC and that in
+Hoffenberg and gave false testimony in a deposition before the trustee in Bankruptcy, at Hoffenberg's behest regarding the management of DCC,
+including the party line that he (Hoffenberg) was
+merely a consultant, and that his January 4, 1994
+Page 12
+affidavit was prepared by Rosoff and that the affi-
+Hughes testified in this proceeding that he had in
+davi or Jad at 4, 199 which he had signed at
+Hoffenberg's request
+b. Stratford
+By November 1993, Chugerman had closed the
+DCC sales offices and terminated much of the sales
+force. Notwithstanding, remittances were not being
+made to the DCC clients, which resulted in a state
+investigation and indictment to which Lowy pled
+guilty. He also pled guilty under a cooperation
+agreement to charges of obstructing the SEC and
+bankruptcy investigation.
+Both Lowy and Hughes demonstrated a willingness
+to falsify testimony but their testimony concerning
+Hoffenberg's influence on their testimony is confirmed by Loveless and by Hoffenberg's admission
+that he met with Lowy before the latter testified. On
+this issue the balance of credibility tilts in favor of
+Lowy and Hughes.
+Hoffenberg started Stratford in early December
+1993 without first notifying the Government. In approximately November 1993, one month after Hoffenberg had signed the Agreement, Hoffenberg
+called Hughes into a meeting with Rosoff and
+stated that he was starting a new collections business. Hoffenberg further indicated his desire to
+nove quickly with this new collections business b
+asking Rosoff "[w]here is it faster to incorporate
+New York or Delaware?" Hoffenberg selected
+Hughes as president. When Hughes declined the appointment, Hoffenberg stated,
+• "[y]eah, 1 guess
+you're right, you have too much baggage."
+Hoffenberg then selected Steven Drylus ("Drylus")
+to run the new company. Dryfus had previously
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+worked for Hoffenberg at Towers and was now
+working for Hoffenberg at Haley Capital, which
+was located in the Trump Tower. In late December
+1993, Hoffenberg
+took Dryfus into the hallway
+where he could not be overheard and asked Dryfus
+to be the executive of his new collections company.
+That company, which Hoffenberg had by then incorporated, was Stratford. Hoffenberg made Dryfus
+president
+of Stratford,
+and
+Gene
+("Sherman"), Hoffenberg's uncle, vice-president. At
+DCC, Sherman had blank checks available for Hoffenberg and put up the money to start Her New
+York and had made payments on Hoffenberg's
+apartment and boat mortgage. Stratford started operations in late December 1993 by taking on a few
+collections claims.
+Hoffenberg instructed Dryfus in early January 1994
+to mischaracterize Hoffenberg's participation in
+she rode in Seated, or be
+cause Hoffenberg was physically present in Stratford's office every day, he took on the title of consultant, as he had at DCC. As Dryfus put it, "that
+was the spin. He was not a principal with the firm,
+but he was working as a consultant." In accordance
+Hoffenberg, was running Stratford. Hoffenberg instructed Dryfus to tell counsel that Hoffenberg was
+just a consultant and that Dryfus was in business
+lowed Hoffenberg's instructions.
+Hoffenberg spoke
+With Dratus every day bout stateds businese
+He kept track of how much money Stratford was
+pany, supervised the collectors, and kept apprised
+of, and signed off on the company's business *1275
+development. Hoffenberg funded the business by
+infusing approximately $50,000 in cash during late
+January and early February. Dryfus testified that all
+of this occurred before the Government's February
+17, 1994 announcement of the termination of Hof-
+Page 13
+fenberg's cooperation.
+Hoffenberg's infusion of cash into Stratford in
+January and February 1994 further violated the
+Consent Order and Nardello's instructions. The
+business was operated by avoiding the use of
+checks and resorting to cash deliveries.
+Dryfus testified that Hoffenberg gave him $24,000
+in cash from an accordion folder, that he and Hofdirection, used it to pay Stratford's bills.
+Approximately three to five days later, Hoffenberg
+gave Dryfus a sealed, unaddressed, Federal Express
+package containing $26,000 in cash. Dryfus also
+used these funds to pay Stratford's bills, including
+Hoffenberg's $250 per month parking expenses.
+In his affidavit of November 28, 1994, in this proceeding, Hoffenberg admitted that he
+"disregarded
+[Nardello's] instructions to avoid any involvement
+with that business." He related how difficult it was
+for him, even months after he signed the Agreement, to break the habit of conducting business dishonestly.
+The Performance of the Agreement
+As set forth above, there is no evidence in this record that Hoffenberg failed to perform his agreement with respect to the affairs of Towers. It is his
+failure to perform the Agreement with respect to his
+own affairs in 1993 that is at issue.
+The Government also acted in conformity with the
+Agreement throughout 1993 from September 24
+Ber 2, ere no ingenie hotel me concerning DCC or Stratford.
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+fus. Lowy's cooperation began in November, and he
+was interviewed by an Assistant United States At-
+torney on December 22. Hughes recounted his recollection of events to James Nauwens, an investigator of the United States Attorney's Office on
+December 27, 1993.
+Nardello was on vacation and upon his return on
+January 10, 1994, he arranged to have Hoffenberg
+testify before the grand jury on January 14, 1994.
+He did not obtain Nauwens' information nor learn
+of Lowy's cooperation until after Hoffenberg's
+grand jury appearance.
+The Government thus called upon Hoffenberg to
+perform the Agreement with knowledge in its possession that Hoffenberg had lied about DCC and
+Stratford and after it had procured statements from
+Hughes and Lowy on the subject. When Nardello
+learned of Lowy's and Hughes' cooperation, he
+challenged Hoffenberg on January 24, and Hoffenberg conceded certain of the information relating to
+his involvement in Stratford and sought to " cure"
+his conduct. Nardello met with Hoffenberg again on
+January 27 and February 14, and recommended that
+the Agreement be terminated. Hoffenberg was arrested on February 17.
+Page 14
+Discussion
+The Government in Refusing to Perform the
+Agreement Acted in Good Faith
+[1] A party who materially breaches a cooperation
+or plea agreement may not claim its benefits.
+United States v. Merritt, 988 F.2d 1298, 1313 (2d
+124 L.Ed.2d 683 (1993); United States v. Tilley,
+964 F.2d 66, 70 (Ist Cir. 1992) (if defendant fails to
+fulfill his or her promises, the Government is released from its obligations under the agreement);
+United States v. Gonzalez-Sanchez, 825 F.2d 572,
+578 (Ist Cir.), cert. denied, 484 U.S. 989, 108 S.Ct.
+510, 98 L.Ed.2d 508 (1987).
+[2] At post-conviction hearings, the Government
+has the burden to prove breach of a plea agreement
+by a preponderance of the evidence. United States
+v. Verrusio, 803 F.2d 885, 894 (7th Cir. 1986)
+(Government must prove that the defendant
+breached the *1276 plea bargain by a preponderance of the evidence"); United States v. Tilley, 964
+F.2d at 71. Such a standard is consistent with the
+standard of proof courts have required to resolve
+other post-conviction disputes, such as disputed
+sentencing issues. United States v. Guerra, 888
+F.2d 247, 251 (2d Cir.1989), cert. denied, 494 U.S.
+1090, 110 S.Ct. 1833, 108 L.Ed.2d 961 (1990); see
+United States v. Merritt, 988 F.2d at 1313.
+Hoffenberg suggests that United States v. Leonard,
+50 F.3d 1152, 1158 (2d Cir. 1995), suggests a higher standard of proof. In Leonard, the Second Circuit
+instructed that "the district court should consider
+any evidence with a significant degree of probative
+value, and should rest its finding on evidence that
+provides a basis for [appellate] review." Leonard,
+50 F.3d at 1157. A requirement that evidence have
+a significant degree of probative value is not equivalent to the enunciation of an enhanced standard
+of proof. It is similar to the requirement described
+by the Guidelines for resolution of disputed sentencing issues, clearly governed by a preponderance of
+the evidence standard. Guidelines, § 6A1.3. ("[T]he
+court may consider relevant evidence without regard to its admissibility ... provided that the information has sufficient indicia of reliability to support
+its probable accuracy.").
+Hoffenberg has also cited United States v. Martin,
+25 F.3d 211, 217 (4th Cir.1994). There, at the time
+of sentence, the Government announced that it
+would make a motion, pursuant to Fed.R.Crim.P
+35(b) within the year because the defendant had cooperated fully before sentence, but it was hoped
+that he would provide additional cooperation following sentence. Technically, there was no mechanism for the Court to provide post-sentencing reief for the pre-sentencing cooperation. The Cour
+of Appeals held that the Government's failure t
+make the motion at sentencing resulted in a
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt.. 6/8/2009
+
+
+
+deprivation of the defendant's due process rights,
+and remanded for resentencing. In Martin, there
+were no disputed issues, leaving nothing to be resolved in any hearing. It is undisputed that Martin
+reiterated the Circuit's position that the burden of
+proving a breach is on the party that alleges the
+Page 15
+] Courts have generally looked to the terms of ti
+reement itself and to the parties' anticipated ben
+fits to determine whether a material breach has occurred. See, e.g., United States v. Crawford, 20
+F.3d 933, 934-35 (8th Cir. 1994); United States v.
+Tilley, 964 F.2d at 71; United States v. Wood, 780
+F.2d 929, 931 (11th Cir. 1986), cert. denied, 479
+U.S. 824, 107 S.Ct. 97, 93 L.Ed.2d 48 (1986).
+Where, as here, a defendant has promised to disclose truthfully all information about which the
+Government inquires, any false statement, misleading statement, or omission concerning the defendant's activity or an area about which the Government has inquired, is a material breach of the agreement.
+[4] By the terms of the Agreement, Hoffenberg was
+obligated to
+"truthfully disclose
+all information
+with respect to the activities of himself and others
+concerning all matters about which the Offices inquire of him" to "cooperate fully with the Offices,
+the Securities and Exchange Commission ..." and
+that Hoffenberg "must at all times give complete,
+truthful, and accurate information" and "must not
+commit any further crimes." Authorities dealing
+with similar breaches include United States v.
+Crawford, 20 F.3d at 934-35 (in non-prosecution
+agreement, defendant agreed to provide complete
+and truthful cooperation; Government justified in
+holding defendant in breach where Government
+dubious about defendant's reliability after he implicated co-defendant in interview with agents, but
+admitted sole responsibility for crime in conversations with others); United States v. Gerant, 995
+F.2d 505, 507-08 (4th Cir.1993). When defendant
+agreed to cooperate fully and provided substantial
+information about drug operations, defendant
+breached agreement by lying about his role in two
+deals, amount of money he earned, and status as
+Government informant); United States v. Tilley,
+964 F.2d at 71 ( defendant agreed to testify fully,
+honestly, truthfully and completely; defendant
+breached agreement by false testimony as to his
+additional involvement in drug deal); United States
+v. Britt, 917 F.2d 353,
+355-56, 360-61 (8th
+Cir. 1990) ( defendant agreed to fully and completely cooperate with the United States and, * over
+the course of a year, had several debriefings, recorded phone conversations, participated in controlled
+buy; defendant breached agreement by not disclosing the full extent of his drug dealing), cert.
+denied, 498 U.S. 1090, 111 S.Ct. 971, 112 L.Ed.2d
+1057 (1991); United States v. Gonzalez-Sanchez,
+825 F.2d at 579; United States v. Wood, 780 F.2d at
+931; United States v. Patrick, 823 F.Supp. 583
+(N.D.III.1993). See also United States v. Hon, 17
+F.3d 21, 24-26 (2d Cir.1994) (upholding Government's refusal to file 5Kl letter for cooperator who
+delayed his testimony, thereby breaching his obligation to "fully cooperate").
+As found above, from the beginning of his proffer
+sessions in April 1993 through his final meeting on
+February 14, 1994, Hoffenberg lied to the Government about his involvement in the operation of
+DCC, about Lowy's "independence" as president of
+the company, and failed to disclose his involvement
+in Stratford.
+According to Hoffenberg, because the Government
+did not focus his attention on DCC until meetings
+in late January 1994, his failure to describe accurately his role at DCC was not a breach. Before he
+repren utation, Hoffenberg misled the Government
+Hoffenberg argues that whether
+not he
+"controlled" DCC is a legal question, not a factua
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+one, and therefore his assertion cannot be a lie or a
+breach of the Agreement. However, Hoffenberg
+misled the Government about specific facts relevant
+to his role at DCC. Each misleading statement,
+omission, and lie was itself a breach, apart from his
+general assertion that he did not "control" DCC.
+Page 16
+is no excuse for Hoffenberg's failure to provide the
+information, and correct the prior misleading statements he had already made. See United States v.
+Wood, 780 F.2d at 930 (defendant's failure to disclose information about a drug deal in Jacksonville,
+although only questioned about drug dealing in
+Tampa, was a material breach of the obligation to
+truthfully disclose all information about drug dealing).
+When confronted by Nardello on December 21
+993, Hoffenberg acknowledged that he had hed to
+the Government about even contemplating participation in Stratford. Although this
+the Government, in its discretion, did not end the
+Agreement based on that lie alone. What followed,
+and what the Government later learned, was that
+Hoffenberg misled the Government about his interest and participation in Stratford, the cash payments to Stratford, and, of course, that he had violated his promise to Nardello pursuant to the Agreement not to get involved in Stratford.
+that he cured this
+(5) Hoffenberg argues, howev lies. Although the
+"opportunity to cure" doctrine applies comfortably
+to contracts for the delivery of goods, it does not
+apply to cooperation agreements. As the Second
+Circuit has stated, "[c]omparing a criminal defendant to a merchant in the marketplace is an inappropriate analogy that we have rejected." Innes v.
+Dalsheim, 864 F.2d 974, 978 (2d Cir.1988), cert.
+denied, 493 U.S. 809, 110 S.Ct. 50, 107 L.Ed.2d 19
+(1989). See United States v. Khan, 920 F.2d 1100,
+1105 (2d Cir.1990) ("We recognize, of course, that
+criminal sentencing proceedings are not the same as
+civil contract disputes."), cert. denied, 499 U.S.
+969, I|| S.Ct, 1606, 113 L.Ed.2d 669 (1991).
+While the differences between contracts in the civil
+"meticulous standards [which must be] ... met by
+the prosecutors …..." U.S. v. Mozer, 828 F.Supp.
+208, 215-216 (S.D.N.Y.1993) (citations omitted),
+the differences apply to the defendants as well. The
+very purpose of a cooperation agreement is to obtain full and truthful information from a cooperator
+on each and every topic about which the Government inquires. While the Government gave Hoffenberg opportunities to be truthful, it was not incumbent on the Government to continue to extend to
+Hoffenberg such an opportunity. *1278 When the
+Government determined in February that Hoffenberg had not been truthful, as required in the
+Agreement, it was within its right to declare the
+breach.
+[6] Although Hoffenberg could not " cure" the fact
+that he lied to and misled the Government in violation of the Agreement, he was given ample opportunity to confront the allegations and provide an innocent explanation. Such an opportunity is all that
+is required. In United States v. Crawford, 20 F.3d at
+936, for example, a defendant told the Government
+one version of a fraud, implicating a co-defendant,
+and told others that he was solely responsible. It
+was sufficient that he was asked for names of
+people who could corroborate the version of events
+he had given.
+Hoffenberg was given numerous opportunities to
+show the Government that he had not breached the
+Agreement. Rather than terminate the Agreement
+once the Government had serious concerns, the
+Government met with Hoffenberg on January 27
+and February 14, 1994, to enable Hoffenberg to address the issues and to assert an innocent explanation for the allegations. With respect to Stratford,
+Hoffenberg admitted that he had lied to and misled
+the Government and intentionally violated the
+Agreement with Nardello.
+On the issue of cure, this case can be distinguished
+from that in United States v. Brechner, 93 Cr. 626,
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+Memorandum of Decision and Order, October 19,
+1995 (E.D.N.Y.). In Brechner, a defendant subjected to a similar truthfulness obligation was asked in
+Page 17
+lawyer apparently asked to speak to Brechner, and
+after doing that, Brechner admitted that he had received such payments. After "coming clean," the
+Government "advised Brechner that he was giving
+him a "fresh start' and expected him to answer
+questions concerning unreported cash truthfully..."
+The Court found that after this statement, the government asked another hours' worth of questions
+and that Brechner made full and truthful disclosures
+of the subject schemes. When five months later the
+Government refused to move for a downward departure, the Court found that this was done in bad
+faith.
+no such promises were made to Hof
+fenberg case rafter the February 1e session. The
+Government informed Hoffenberg three days later
+on February 17 that it was not going to move for a
+downward departure.
+The Government had
+promised that it would go forward with the 5K1
+term of the Agreement, nor is there any indication
+that it used these sessions to get additional information, thus behaving as thought the Agreement was
+in full force. In fact, there is no indication that the
+Government is attempting to use affirmatively any
+of the information gained in those sessions against
+Hoffenberg. The sessions confirmed suspected lies
+that he had told earlier and as a result the Government is choosing not to make a 5K1 motion on his
+behalf.
+The Agreement Allows the Government to Consider Truthfulness When it Determines Whether to
+Make a 5KJ Motion
+[7] When a cooperation agreement allows for a substantial assistance motion contingent upon the Government's evaluation of a defendant's cooperation,
+the Government has wide discretion in determining
+whether to make such a motion. United States v.
+Hon, 17 F.3d at 25; see United States v. Khan, 920
+F.2d at 1105 ("where a contract is conditioned on
+the satisfaction of the obligor, the condition is not
+met "if the obligor is honestly, even though unreasonably, dissatisfied' "); United States v. Knights,
+968 F.2d 1483, 1486 (2d Cir. 1992) (Government's
+pertormance in cooperation agreement is condi
+ioned on its satisfaction with the defendant's ef
+forts).
+[8] Where the Government declines to make a substantial assistance motion pursuant to a cooperation
+agreement, the district court may review the decision only to determine whether the Government
+based its decision on impermissible criteria, such as
+race or religion, or whether the Government acted
+in bad faith. United States v. Kaye, 65 F.3d 240,
+243 (2d Cir.1995); United States v. Hon, 17 F.3d at
+25; *1279United States v. Knights, 968 F.2d at
+1487; United States v. Agu, 949 F.2d 63, 67 (2d
+Cir. 1991), cert. denied, 504 U.S. 942, 112 S.Ct.
+2279, 119 L.Ed.2d 205 (1992); see United States v.
+Khan, 920 F.2d at 1104 ("the prosecutor's discretion is generally the sole determinant of whether the
+defendant's conduct warrants making the motion");
+United States v. Rexach, 896 F.2d 710, 714 (2d
+Cir.) (prosecutorial discretion limited only by subjective good faith standard), cert. denied, 498 U.S.
+969, 111 S.Ct. 433, 112 L.Ed.2d 417 (1990).
+[9][10] The Government may not refuse to make a
+substantial assistance motion by relying on facts
+which it knew at the time it entered into the agrecment. Such a decision would amount to fraudulently inducing a defendant's plea with a promise
+that the Government already knew it would not
+keep. See United States v. Knights, 968 F.2d at
+1488; United States v. Leonard, 50 F.3d at 1158.
+However, where as here, the Government enters into an agreement in good faith, believing the defendant's representations, and the Government subsequently learns that the defendant has lied and
+breached the terms of the agreement, the Government's dissatisfaction with the defendant's perform-
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+ance is justified.
+[11] When a defendant claims that the Government
+has acted in bad faith in refusing to move for downward departure, the Government may then rebut the
+allegation, explaining its reasons for refusing to so
+move. United States v. Knights, 968 F.2d at 1487.
+A defendant must then make some showing of bad
+faith to trigger a hearing on the issue. After a fullblown hearing in this case, Hoffenberg has failed to
+establish any bad faith on the part of the Government.
+[12] The clause of the Agreement regarding the
+SK1 states that:
+In addition, if it is determined by the Offices that
+Steven Hoffenberg has provided substantial assistance in an investigation
+or prosecution, and if
+Steven Hoffenberg has otherwise complied with the
+terms of this Agreement, the Offices will file a motion, pursuant to Section 5K1.1 of the Sentencing
+Guidelines, advising the sentencing judge of all relevant facts pertaining to that determination and requesting the Court to sentence Steven Hoffenberg
+in light of the
+forth in Section
+SKI.I(a)(1)-(5). (emphasis added).
+obligated to move for a departure if Hoffenberg provided substantial assistance and if he "otherwise complied with the terms
+of [the] Agreement." The Court of Appeals has
+stated that parties to a plea Agreement could establish terms of the Agreement which were other than
+standard and to which they would be bound. See
+United States v. Rexach, 896 F.2d 710, 714 (2d
+Cir. 1990) (*... a defendant might negotiate
+agreement which, by its terms, would define a different standard for evaluation. Should such a cooperation agreement specify
+.. La more stringent
+standard], then we would, of course, employ [that
+standard].") In this case the filing of the 5K1 motion was contingent on both substantial assistance
+and compliance with the terms of the Agreement.
+The parties were bound to the term as it was written. Hoffenberg did not otherwise comply with all
+Page 18
+the terms of the Agreement. The Agreement,
+quoted above, required truthfulness. Hoffenberg
+was not truthful.
+[13][14] Even if the Court were to consider the
+"substantial cooperation" clause in isolation of the
+rest of the conditions, there has not been a showing
+of bad faith.rNI It would not be enough for Hoffenberg to prove his substantial assistance, since "a
+claim that a defendant merely provided substantial
+assistance will not entitle a defendant to a remedy..." Wade v. U.S., 504 U.S. 181, 186, 112 S.Ct.
+1840, 1844, 118 L.Ed.2d 524 (1992). It is reasonable and appropriate for the Government to consider Hoffenberg's truthfulness in evaluating his assistance. It is significant that Hoffenberg repeatedly
+corrected and changed his story and helped suborn
+perjury. It was not bad faith to believe that the information Hoffenberg provided was not entirely
+useful. See, e.g., United States v. Knights, 968 F.2d
+1483, 1488 (2d Cir. 1992).
+FN1. In evaluating the Government's SKI
+motion, the Court is instructed by the
+Guidelines to consider the "truthfulness,
+completeness and reliability" of any inor testimony
+provided, See
+Guidelines § 5K1.1(a)(2).
+*1280 The Court of Appeals' admonition
+in
+Knights, is not relevant in this case. In Knights, the
+Court of Appeals reminded us that while the Government "has wide latitude in evaluating a defendant's cooperation, [t]hat latitude ... does not permit
+it to ignore a defendant's efforts at cooperation
+simply because the defendant is providing information that the government does not want to hear." Id.
+In this case it is the veracity of the cooperation and
+not the content of the cooperation that is at issue.
+The Agreement was vitiated only after the Government determined, after a thorough investigation,
+that Hoffenberg was lying about DCC, as well as
+about Stratford, that he encouraged the perjury of
+Hughes and Lowy, and only after Hoffenberg was
+given ample opportunity to provide an innocent ex-
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 6/8/2009
+
+
+
+planation. Hoffenberg cannot now claim that the
+Government acted in bad faith by accepting and believing his false portrayal of his role at DCC, and
+entering the Agreement in reliance on that.
+Because Nardello called Hoffenberg to testify in the
+grand jury on January 14, 1994, at a time when
+there were problems with Hoffenberg's cooperation
+and when the Government knew of his misrepresentations, Hoffenberg claims that Nardello improperly "sandbagged" Hoffenberg, and thus, acted in
+bad faith. As Nardello testified, it had been his intention for Hoffenberg to testify in the grand jury
+since the signing of the Agreement. In fact, in
+November 1993, Hoffenberg testified before the
+As of January 14, 1994, no decision had been made
+to terminate Hoffenberg's cooperation agreement.
+Indeed, the Government did not begin to seriously
+consider terminating the Agreement until January
+18, 1994, when Hoffenberg
+admitted that he had
+disregarded Nardello's
+specific
+instructions
+of
+December 22, 1993, regarding Stratford. As of the
+grand jury testimony on January 14, 1994, the only
+breach of which Nardello had personal knowledge
+was Hoffenberg's failure to mention Stratford when
+asked about businesses he might be considering entering into at the December 22, 1993 meeting.
+Hoffenberg places great emphasis on the fact that
+both Lowy and Hughes had already met with a
+Government investigator prior to January 14, 1994,
+and had made allegations that Hoffenberg suborned
+perjury. Nardello, however, did not meet with
+Lowy until January 24, 1994, and with Hughes until
+January 25, 1994. In large part what Nardello knew
+when is irrelevant to the determination of good
+faith on the issue of whether or not the Government
+must make the substantial assistance, 5K1 motion.
+The Government has not vitiated the other portions
+of the plea agreement. It has simply notified Hof
+fenberg that no 5K1 letter will be forthcoming.
+[15][16] In the end, it is proper for the Government
+to consider the truthfulness of a defendant in evalu-
+Page 19
+ating the degree of his cooperation. When a cooperator enters into an agreement with the government
+which includes a provision for a 5Kl motion, that
+defendant must be honest if he hopes to achieve the
+benefit of the bargain. The government may permit
+a defendant to cure his dishonesty, but it is not required to do so and certainly need not do so continuously. Even if the untruths are not central to the
+cooperation, if the lies are deemed material to the
+evaluation of the truthfulness, the Government, absent unconstitutional or bad faith motivation, is free
+not to move for the departure. Hoffenberg's repeated deceptions rendered him untrustworthy as a
+cooperator. The Government is justified in its actions. There has been no showing of bad faith.
+Conclusion
+For the reasons described above, Hoffenberg's motion for specific performance of the Agreement is
+denied.
+It is so ordered.
+S.D.N.Y.,1995.
+908 Sup. 12c3
+END OF DOCUMENT
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt.. 6/8/2009
+
+
+
+Westlaw Delivery Summary Report for ATKINSON,KAREN
+Your Search:
+non-prosecution agreement breached by defendant, do have to
+give time to cure breach
+Date/Time of Request:
+Client Identifier:
+Database:
+Citation Text:
+Lines:
+Documents:
+Images:
+Monday, June 8, 2009 14:56 Central
+ALLFEDS
+395
+!
+The material accompanying this summary is subject to copyright. Usage is governed by contract with Thomson Reuters,
+West and their affiliates.
+https://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt...
+6/8/2009
+
+
+• Case 9:08-cv-80119-KAM Document 146
+Entered on FLSD Docket 06/08/2009 Page 1 of 11
+JANE DOE NO. 2,
+Plaintiff
+Defendant
+JANE DOE NO. 3,
+Plaintiff
+!
+CASE NO: 08-CV-80232-MARRA/JOHNSON
+Defendant
+JANE DOE NO. 4,
+Plaintiff
+CASE NO: 08-CV-80380-MARRA/JOHNSON
+Defendant
+_'
+
+
+• Case 9:08-CV-80119-KAM Document 146
+Entered on FLSD Docket 06/08/2009 Page 2 of 11
+JANE DOE NO. 5,
+Plaintiff
+CASE NO: 08-CV-80381-MARRA/JOHNSON
+Defendant
+JANE DOE NO. 6.
+Plaintiff
+CASE NO: 08-CV-80994-MARRA/JOHNSON
+Defendant
+JANE DOE NO. 7,
+Plaintiff
+CASE NO: 08-CV-80993-MARRA/JOHNSON
+Defendant
+2
+
+
+Case 9:08-cv-80119-KAM Document 146
+Entered on FLSD Docket 06/08/2009 Page 3 of 11
+CASE NO: 08-CV-80811-MARRA/JOHNSON
+Plaintiff
+Defendant
+CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON
+Vs.
+JEFFREY EPSTEIN, et al.
+DOE II,
+CASE NO: 09-CV-80469-MARRA/JOHNSON
+Plaintiff
+JEFFREY EPSTEIN, et al.
+Defendants.
+3
+
+
+Case 9:08-Cv-80119-KAM Document 146
+Entered on FLSD Docket 06/08/2009 Page 4 of 11
+CASE NO: 08-CV-80119-MARRAIJOHNSON
+JANE DOE NO. 101,
+Plaintiff
+CASE NO: 09-CV-80591-MARRA/JOHNSON
+Defendant
+JANE DOE NO. 102,
+Plaintiff
+CASE NO: 09-CV-80656-MARRA/JOHNSON
+Defendant
+RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION TO STRIKE CASE
+FROM CURRENT TRIAL DOCKET
+COMES NOW plaintiff Jane Doe, by and through her undersigned counsel, to file
+this response in opposition to defendant Jeffrey Epstein's motion to strike her trial date
+from the current trial docket. Epstein argues that a few discovery disputes require
+striking the trial date. But these disputes can be resolved before the discovery deadline
+expires - particularly given that there are nearly four months remaining until the
+discovery cutoff. Moreover, Jane Doe will be gravely harmed by any delay in this matter
+because it will give Epstein the opportunity to finish hiding his assets.
+4
+
+
+• Case 9:08-Cv-80119-KAM Document 146 Entered on FLSD Docket 06/08/2009 Page 5 of 11
+Background
+Defendant Epstein has filed a boilerplate motion to strike Jane Doe's trial date -
+and numerous other consolidated cases involving similar allegations of his sexual abuse
+of minors - for an unspecified period of time, delaying what is currently set as a
+February 22, 2010, trial date until some later and unspecified date. On May 28, 2009,
+the court granted the motion to strike the trial date as to plaintiffs Jane Does 2-7 - who
+had agreed to the delay for their own reasons. The court set a new trial date of June 1,
+2010, for these cases. The court, however, reserved ruling on the motion to continue
+Jane Doe's case (and one other plaintiff,
+In recounting the procedural history of this case, Epstein does not disclose that in
+this particular case, he has been the one responsible for numerous delays. Indeed, a
+quick review of the docket sheet shows the following requests for extensions by
+defendant Epstein:
+DE 10 (defendant's motion for extension of time to respond to complaint)
+(10/1/08)
+DE21 (defendant's motion for extension of time to file motions to compel) (3/4/09)
+DE39 (defendant's motion extension of time to file reply as to response to
+opposition to motion to stay) (4/22/09)
+DE41 (defendant's motion for extension of time to file reply as to response in
+opposition to motion to compel tax records) (4/27/09)
+DE42 (defendant's motion for extension of time to file reply as to response in
+opposition to motion to compel on first interrogatories) (4/27/09)
+5
+
+
+'Case 9:08-cv-80119-KAM Document 146
+Entered on FLSD Docket 06/08/2009 Page 6 of 11
+DE44 (defendant's motion for extension of time to file response as to motion to
+strike reference to non-prosecution agreement) (4/29/09)
+DE52 (defendant's motion for extension to time to file response as to amended
+complaint) (5/05/09)
+DE60 (motion for extension of time to file response to plaintiff's first amended
+complaint) (5/18/09)
+It should be noted that Jane Doe, as a matter of civility, has not objected to a
+single one of these requests for an extension from defendant Epstein. In none of these
+conferences regarding these requests for extension did defense counsel indicate that
+he was concerned that the trial date might need to be continued because of any delay in
+this case.
+Jane Doe has yet to request a single extension of time for any reason.
+It may also be relevant to note that Epstein has "taken the Fifth" with regard to
+essentially all discovery that Jane Doe has propounded to him in this case.
+Epstein Has Failed to Provide any "Exceptional Circumstances"
+to Continue the Trial Date
+This court, of course, has discretion to continue the trial date. The rules of this
+court, however, make clear that "[a] continue of any trial... will be granted only on
+exceptional circumstances." Local Rule 7.6 (emphasis added). All defendant Epstein
+has shown is a few, run of the mill, discovery disputes - that have arisen months in
+advance of the discovery deadline. (The deadline in this case is October 1, 2009 -
+roughly four months away.) At the very least, any motion to continue is premature.
+6
+
+
+• Case 9:08-cv-80119-KAM
+Document 146 Entered on FLSD Docket 06/08/2009 Page 7 of 11
+Defendant Epstein has failed to provide any good reason for delaying trial in
+Jane Doe's case. Most of his pleading focuses on discovery disputes that have arisen
+with regard to Jane Does 2-7 or
+. These disputes have absolutely no bearing on
+whether Jane Doe's case can be ready for trial by February 22, 2010.
+In an effort to provide some sort of "good cause" for rescheduling the trial date,
+Epstein's defense counsel has provided an affidavit asserting generally that it will not be
+possible to complete discovery in a timely fashion in this case. That same affidavit,
+however, acknowledges that some of the discovery disputes that have arisen in other
+cases have not arisen in this case. In particular, the affidavit spends a great deal of
+time explaining how an objection to disclosing the true names of the plaintiffs in other
+cases has (allegedly) made it impossible for Epstein to serve subpoenas and thus
+obtain meaningful discovery about other plaintiffs. See Affidavit of Michael J. Pike at 4-
+5, Exhibit 1 to Epstein's Motion to Strike Cases from Current Trial Docket. The affidavit
+concedes, however, that this objection does not apply to Jane Doe's case. See id. at 5
+("As stated in the motion to strike, Brad Edwards [counsel for Jane Doe] has agreed to
+such a procedure relative to third party subpoenas.").
+In addition, Jane Doe will be gravely prejudiced if a delay of any sort is
+sanctioned in this case. As the court is well aware, this case involves serious
+allegations of sexual abuse of minor. Each passing day with the matter unresolved
+adds to the psychological stress that Jane Doe must bear. This is not the kind of case
+that where additional time should be allowed to pass. In general, "The compensation
+and remedy due a civil plaintiff should not be delayed." Gordon v. FDIC, 427 F.2d 578,
+7
+
+
+Document 146 Entered on FLSD Docket 06/08/2009 Page 8 of 11
+580 (D.C. Cir. 1970). Given the sexual abuse allegations at stake here, that general
+admonition applies with even greater force.
+Moreover, Jane Doe will be gravely prejudiced if Epstein is allowed to postpone
+trial in this matter. As explained at greater length in Jane Doe's soon to be filed
+Memorandum in Support of Motion for Injunction Restraining Fraudulent Transfer of
+Assets, good cause exists for believing defendant Epstein is currently moving his assets
+overseas in an attempt to defeat the satisfaction of any judgment that Jane Doe might
+obtain in this case. In addition, it is possible that by delaying the trial until June 2010,
+Epstein might be able to escape the supervision of the Florida courts entirely. Epstein
+is currently in jail and will serve a one-year term of community control (house arrest)
+following his release. Conveniently enough for Epstein, it appears that this term of
+community control will expire at around the time of his proposed new trial date.
+For all these reasons, the Court should deny the motion to strike Jane Doe's
+currently-established trial date.
+Dated: June 8, 2009.
+Respectfully Submitted,
+s/ Bradley J. Edwards
+Bradley J. Edwards
+ROTHSTEIN ROSENFELDT ADLER
+Hot at a Can, Sut 1850
+Telephone
+-acsimile
+8
+
+
+' Case 9:08-cv-80119-KAM
+Document 146 Entered on FLSD Docket 06/08/2009 Page 9 of 11
+E-mail:
+and
+Paul G. Cassell
+Pro Hac Vice
+332 S. 1400 E.
+Salt Lake City, UT 84112
+
+
+'Case 9:08-cv-80119-KAM
+Document 146
+Entered on FLSD Docket 06/08/2009(
+
+I HEREBY CERTIFY that on June 8, 2009, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF. I also certify that the foregoing
+document is being served this day on all parties on the attached Service List in the
+manner specified, either via transmission of Notices of Electronic Filing generated by
+CM/ECF or in some other authorized manner for those parties wo hare not authorized to
+receive electronically filed Notices of Electronic Filing.
+s/ Bradley J. Edwards
+Bradley J. Edwards
+10
+
+
+'Case 9:08-CV-80119-KAM Document 146
+Entered on FLSD Docket 06/08/2009 Page 11 of 11
+CASE NO: 08-CV-80119-MARRAJJOHNSON
+SERVICE LIST
+Jane Doe v. Jeffrey Epstein
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+Robert D. Critton, Esq.
+Isidro Manual Garcia
+lack Patrick HILL
+Katherine Warthen Ezell
+Michael James Pike
+Paul G. Cassell
+Richard Horace Willits
+Robert C. Josefsberg
+Adam D. Horowitz
+Stuart S. Mermelstein
+William I. Berner
+11
+
+
+Case 5:08-CV-80811-KAM Document 114
+
+Vs.
+JEFFREY EPSTEIN and
+Defendants.
+PLAINTIFF, :S, MOTION FOR PROTECTIVE ORDER REGARDING
+TREATMENT RECORDS FROM PARENT-CHILD CENTER, INC. AND DR. SERGE
+THYS AND INCORPORATED MEMORANDUM OF LAW
+., by and through her undersigned attorneys, hereby files her
+Motion For Protective Order Regarding Treatment Records From Parent-Child Center,
+Inc. and Dr. Serge Thys and Incorporated Memorandum of Law, and in support there of
+states as follows:
+1. This is an action to recover money damages against Defendant,
+JEFFREY EPSTEIN, for acts of sexual abuse and prostitution committed upon the thenminor, L
+Plaintiff has plead thirty separate counts against EPSTEIN for separate
+incidences of abuse committed by EPSTEIN against Plaintiff pursuant to 18 U.S.C.
+§2255. 18 U.S.C. §2255, entitled "Civil remedy for personal injuries", creates a private
+right of action for minor children who were the victims of certain enumerated sex
+offenses. 18 U.S.C. §2255 also creates a statutory floor for the amount of damages a
+
+
+
+A. Vs. Epstein, et al.
+victim can recover for a violation of same. Plaintiff has also alleged a single count of
+Sexual Battery against EPSTEIN.
+3.
+There presently exists between the Plaintiff and EPSTEIN a disagreement
+as to whether the statutory damage floor established in 18 U.S.C. §2255 is recoverable
+for each commission of an enumerated sex offenses listed in 18 U.S.C. §2255, or
+whether the statutory damage floor can only be enforced once, regardless of how many
+times a defendant perpetrates an enumerated sex offense against a minor victim.
+4. This disagreement between the parties is properly the subject of
+Defendant's Motion to Dismiss First Amended Complaint For Failure to State a Cause
+of Action, and Motion For More Definite Statement; Motion to Strike, and Supporting
+Memorandum of Law (D.E. 47) which is currently pending before this Court.
+In the event that the Court rules that Plaintiff can recover the statutory
+damage floor established in 18 U.S.C. §2255 for each proven incident of abuse
+committed by EPSTEIN upon her, Plaintiff intends to rely exclusively on the statutory
+damages, rather than those damages which are available at common law. (See D.E.
+113). If however, the Court rules that the statutory floor applies only one time,
+regardless of the number of times EPSTEIN committed an enumerated sexual offense
+against her, Plaintiff will be pursuing all damages available to her at both common law
+and by statute.
+6.
+Given Plaintiff's intent to rely exclusively on the statutory damages
+available to her under 18 U.S.C. §2255 as outline above, Plaintiff will not be presenting
+2
+
+
+Case 9:08-cv-80811-KAM Document 114 Entered on FLSD Docket 06/05/2009 Page 3 of 8
+L. Vs. Epstein, et al.
+any evidence of the extent of her physical, emotional, or pecuniary injuries, beyond
+evidence that she was the victim of sexual contact to which she was legally incapable of
+consenting by virtue of her age (including, pain and suffering, emotional distress,
+psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem,
+loss of dignity, invasion of her privacy, and loss of the capacity to enjoy life).
+Accordingly, any testimony and/or discovery regarding those types of damages would
+not be relevant to any material issue pending in this case.
+7. Presently pending before the Court is Defendant EPSTEIN's Motion to
+Compel Plaintiff C.M.A. to Respond to Defendant's First Request to Produce and
+Answer Defendant's First Set of Interrogatories, and to Overrule Objections, and For an
+Award of Defendant's Reasonable Expenses (D.E. 54). EPSTEIN is seeking from
+Plaintiff the production of certain treatment records of hers from the Parent-Child
+Center, Inc. and Dr. Serge Thys, a psychiatrist.
+8. Neither the treatment records from the Parent-Child Center, Inc. nor Dr.
+Serge Thys will have any relevance whatsoever in the event that Plaintiff pursues only
+those statutory damages available to her under 18 U.S.C. §2255. To the contrary, the
+production of these confidential and private treatment records would only serve to
+further humiliate, embarrass, and victimize
+Furthermore,
+'s treatment records from the Parent-Child Center,
+Inc. and Dr. Serge Thys are protected by the psychotherapist-patient privilege pursuant
+to the Supreme Court's decision in Jaffee |. Redmond, 518 U.S. 1, 116 S.Ct. 1923
+3
+
+
+
+(1996)("All agree that a psychotherapist privilege covers confidential communications
+made to licensed psychiatrists and psychologists. We have no hesitation in concluding
+in this case that the federal privilege should also extend to confidential communications
+made to licensed social workers in the course of psychotherapy.") Ordinarily, a plaintiff
+does not place her mental condition in controversy merely by requesting damages for
+mental anguish or "garden variety" emotional distress. In order to place a party's mental
+condition in controversy the party must allege a specific mental or psychiatric disorder
+or intend to offer expert testimony to support their claim of emotional distress. Turner v
+Imperial Stores, 161 F.R.D. 89 (S.D.Cal. 1995). The evidence sought is also protected
+under the substantive privacy rights recognized in Florida Statute $$90.503 and
+90.5035.
+10. Accordingly, Plaintiff respectfully moves for the entry of a protective order
+pursuant to Fed. R. Civ. Pro. 26(c) regarding Plaintiff's treatment records from the
+Parent-Child Center, Inc. and Dr. Serge Thys. More particularly, Plaintiff requests the
+entry of an order precluding the discovery of those records until such time as the Court
+rules on the issue regarding whether the statutory damage floor as contained in 18
+U.S.C. §2255 applies to each proven commission of an enumerated sexual offense by
+Should the Court rule that 18 U.S.C. §2255 provides a per
+EPSTEIN against
+incident damage floor, the treatment records would have absolutely no relevance
+whatsoever. In the event that the Court rules that the damage floor applies only once,
+the parties can then further brief the Court as to whether
+has placed her mental
+4
+
+
+
+condition "in controversy" such that it operates as a waiver of the psychotherapistpatient privilege.
+WHEREFORE, Plaintiff,
+.., respectfully requests that this Court enter a
+protective order preventing the discovery of Plaintiff's treatment records from the
+Parent-Child Center, Inc. and Dr. Serge Thys until such time as the Court decides
+whether the statutory damages pursuant to 18 U.S.C. §2255 are available to a victim of
+an enumerated sexual offense on a per incident basis.
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1
+Counsel for the movant conferred via telephone with counsel for the Defendant
+and counsel for the Defendant is not in agreement with Plaintiff's Motion For Protective
+Order Regarding Treatment Records From Parent-Child Center, Inc. and Dr. Serge
+Thys and Incorporated Memorandum of Law.
+s/ Jack P. Hill
+5
+
+
+
+I HEREBY CERTIFY that on the 5th day of June, 2009, I electronically filed the
+foregoing with the Clerk of the Court by using CM/ECF system, which will send a notice
+of electronic filing to all counsel of record on the attached service list.
+Is/Jack P. Hill
+Jack Scarola
+Jack P. Hill
+Florida Bar No.: l
+2139 Palm Beach Lakes Bouleva& Shipley, P.A.
+West Palm Beach Florida 33409
+Attorneys for Plaintiff
+
+
+Casé 9:08-cV-80811-KAM Document 114
+
+I LA. vs. Epstein, et al.
+COUNSEL LIST
+Richard H. Willits, Esquire
+Richard H. Willits, P.A.
+2290 10th Avenue North, Suite 404
+Lake Worth, El 33461,
+Robert Critton, Esquire
+Burman Critton Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach. EL 33414
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South
+West Palm Beach. F. 33401
+Bruce E. Reinhart, Esquire
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue
+Suite 1400
+West Palm Beach. EL
+33401
+7
+
+
+Case 9:08-CV-80811-KAM Document 114
+
+JEFFREY EPSTEIN and
+Defendants.
+ORDER ON PLAINTIFF, C.M.A'S MOTION FOR PROTECTIVE ORDER REGARDING
+TREATMENT RECORDS FROM PARENT-CHILD CENTER, INC. AND DR. SERGE
+THYS AND INCORPORATED MEMORANDUM OF LAW
+This matter came before the Court upon the Plaintiff's Motion For Protective
+Order Regarding Treatment Records From Parent-Child Center, Inc. and Dr. Serge
+Thys and Incorporated Memorandum of Law. Having considered the motion, it is
+hereby ORDERED and ADJUDGED that:
+Plaintiff's Motion for Protective Order is hereby GRANTED.
+DONE AND ORDERED this
+day of June, 2009.
+KENNETH A. MARRA
+United States District Judge
+Copies to all Counsel of Record
+
+
+Case 9:08-CV-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 1 of 15
+CASE NO.: 08-CV-80119-MARRA/JOHNSON
+JANE DOE NO. 2,
+JANE DOE NO. 3,
+JANE DOE NO. 4,
+JANE DOE NO. 5,
+CASE NO.: 08-CV-80232-MARRA/JOHNSON
+CASE NO.: 08-CV-80380-MARRA/JOHNSON
+
+
+Entered on FLSD Docket 06/08/2009 Page 2 of 15
+JANE DOE NO. 6,
+vs.
+CASE NO.: 08-CV-80994-MARRA/JOHNSON
+JANE DOE NO. 7,
+CASE NO.: 08- CV-80993-MARRA/JOHNSON
+/
+CASE NO.: 08- CV-80811 -MARRA/JOHNSON
+JEFFREY EPSTEIN, et al.,
+CASE NO.: 08- CV-80893-MARRA/JOHNSON
+DOE II,
+CASE NO.: 08-CV- 80469-MARRA/JOHNSON
+2
+
+
+
+JEFFREY EPSTEIN et al.,
+JANE DOE NO. 101,
+CASE NO.: 08- CV-80591-MARRA/JOHNSON
+/
+JANE DOE NO. 102,
+CASE NO.: 08- CV-80656-MARRA/JOHNSON
+/
+PLAINTIFFS JANE DOES 2-7'S RESPONSE TO DEFENDANT'S MOTION TO
+COMPEL AND/OR IDENTIFY PLAINTIFFS IN THE STYLE OF THIS CASE AND
+MOTION TO IDENTIFY JANE DOE IN THIRD-PARTY SUBPOENAS FOR
+PURPOSES OF DISCOVERY, OR ALTERNATIVELY, MOTION TO DISMISS
+"SUA SPONTE", WITH INCORPORATED MEMORANDUM OF LAW
+Plaintiffs, JANE DOES 2-7, hereby serve their Response to Defendant's Motion to
+Compel and/or Identify Plaintiffs in the Style of this Case and Motion to Identify Jane Doe in
+Third-Party Subpoenas for Purposes of Discovery, or Alternatively, Motion to Dismiss "Sua
+Sponte", With Incorporated Memorandum of Law, and state as follows:
+The lawsuits filed by JANE DOES 2-7 involve private, intimate facts pertaining
+to their own childhood sexual abuse and exploitation by Defendant Jeffrey Epstein.
+3
+
+
+Document 144 Entered on FLSD Docket 06/08/2009 Page 4 of 15
+2.
+Jane Does 2-7 filed their suits under a pseudonym' to prevent public disclosure of
+the private, highly sensitive and intimate facts pertaining to their sexual assaults, and the public
+association of their identities with Defendant Epstein and these assaults.
+Dr. Gilbert Kliman,? a well-known forensic psychiatrist with an expertise in the
+field of child trauma, has met with and evaluated each of Jane Does 2-7 and opined that public
+disclosure of their real names would create a substantial risk to them of further psychological
+harm. See Exhibit "A", Declaration of Gilbert Kliman, M.D.
+4. Dr. Kliman opines as follows:
+Releasing names of the plaintiffs to the public will reenact experiences of
+powerlessness and helplessness in the face of a boundary violation. Repetition and
+reenactment represent central features of Criterion B in the DSM-IV-TR diagnosis
+of posttraumatic stress disorder trauma. In effect, release of their identity and
+public intrusion into their personal life represents a reenactment of the shame of
+sexual traumatization. Repetition and reenactment are central pathologies that
+afflict sexual trauma survivors.
+Victims of sexual abuse often rely upon some form of dissociation, splitting or
+denial, as a defensive means to manage overwhelming affects associated with the
+sexual trauma. Each of the plaintiff girls has employed some variation of this
+defense, both during the massages and then subsequently following disclosure of
+the abuse. Primitive, maladaptive responses of this nature will become
+additionally reinforced as a result of public disclosure.
+Another aspect of the plaintiffs' experience, which is recognized by DSM-IV-TR,
+is that the trauma was associated with human design factors (such as cruel
+victims would reinforce the sense of design, pattern and policy of human
+intentions.
+It is my opinion, with a reasonably high degree of medical certainty that the
+defense motion to allow public disclosure of the plaintiffs' identity is clinically
+" Defendant and his counsel are aware of the real names of Jane Does 2-7.
+" A copy of the curriculum vitae of Dr. Gilbert Kliman is attached hereto as Exhibit "B".
+4
+
+
+Document 144 Entered on FLSD Docket 06/08/2009 Page 5 of 15
+releasing personal identities will foster an exacerbation and magnification of
+symptoms lending to increased risk of revictimization and retraumatization.
+See Exhibit "A", 11| 13-15, 21
+5.
+Given the private nature of the allegations in this lawsuit and the serious risk of
+harm to the mental health of Jane Does 2-7 if a public disclosure of their identities were required,
+Jane Does 2-7 should be permitted to continue using a pseudonym in this lawsuit.
+6. Notably, in one of the cases consolidated for purposes of discovery, Jane Doe v.
+Jeffrey Epstein, Case No. 08-80893, this Court recognized the harm likely to result from public
+disclosure of the victims' identities in these cases, and allowed the Plaintiff in that case to
+"proceed in this action under the pseudonym 'Jane Doe'", by Order dated October 6, 2008.
+7.
+Jeffrey Epstein sets forth no facts to support his bare contention that Jane Does 2-
+7 use of a pseudonym in these proceedings interferes with his "constitutional due process right."
+See Motion to Compel, p. 3. Defendant and his counsel know the identities of these Plaintiffs.
+Defendant also requests the Court's permission to use the real names of Jane Does
+2-7 in various third-party subpoenas for discovery purposes. Defendant does not identify any of
+the entities or persons to whom he intends to send subpoenas. An order granting the relief
+requested without limitations would essentially nullify Jane Does 2-7's right to proceed
+anonymously. Jane Does 2-7 therefore object to the issuance of third-party subpoenas, and
+submit that Defendant can obtain the discovery he seeks by alternative means that will preserve
+the confidentiality of the Jane Does 2-7's identities.
+If this Court
+were to permit third party subpoenas or records custodian
+depositions using the existing captions and identifying Jane Does 2-7 in the body of the
+5
+
+
+Case 9:08-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 6 of 15
+subpoena by their names, due to publicity surrounding the Defendant's crimes, then Jane Does 2-
+7 would effectively be revealed as abuse victims in these cases against Defendant Epstein. Any
+subpoenas or notices to third parties therefore should not disclose the type of action or the
+Defendant's identity. There are alternatives which would preserve Jane Does 2-7's anonymity
+and be more efficient and cost-effective at the same time. For instance, Defendant can obtain
+records from various non-party sources through Plaintiffs' counsel, who can certify that they
+have obtained the records through authorizations signed by Jane Does 2-7. Another means to
+obtain non-party records concerning Plaintiffs is the appointment of a special master, who would
+verify authenticity and completeness of the records.
+10. Finally, Jeffrey Epstein's request that this Court order a "sua sponte" dismissal is
+illogical. Sua sponte means "[w]ithout prompting or suggestion; on its own motion." Black's
+Law Dictionary 1437 (7th ed.1999). Thus, the definition of sua sponte does not fit these
+circumstances, because the Court is being prompted by Epstein's Motion. Velchez v. Carnival
+Corp., 331 F.3d 1207 (11th Cir. 2003). In any event, there is no basis or authority to support a
+dismissal of these cases.
+WHEREFORE, Plaintiffs Jane Does 2-7 respectfully request that (i) this Court deny
+Defendant's Motion to Compel and/or Identify Plaintiffs in the Style of this Case and Motion to
+Identify Jane Doe in Third-Party Subpoenas for Purposes of Discovery, or Alternatively, Motion
+to Dismiss "Sua Sponte", in its entirety; (ii) Plaintiffs Jane Does 2-7 be permitted to continue
+using their pseudonyms in this litigation; (iii) this Court order that records from non-parties
+relating to Jane Does 2-7, including medical and employment records, only be obtained through
+Plaintiffs' counsel by means of signed authorizations that do not include the caption or identify
+Epstein as the party seeking records, or alternatively, appoint a special master to obtain the
+6
+
+
+Entered on FLSD Docket 06/08/2009 Page 7 of 15
+records, who would verify authenticity and completeness of the records; and (iv) all other relief
+this Court deems just and appropriate.
+MEMORANDUM OF LAW
+I.
+PLAINTIFFS JANE DOES 2-7 SHOULD BE PERMITTED
+TO PROCEED ANONYMOUSLY IN THIS CASE DUE TO THE
+SENSITIVE, PRIVATE NATURE OF THE UNDERLYING FACTS
+AND THE RISK OF PSYCHOLOGICAL HARM TO THE PLAINTIFFS
+Federal courts permit a party to proceed under a pseudonym when special circumstances
+warrant anonymity. See, e.g., Roe v. Aware Woman Ctr. for Choice, Inc., 253 F.3d 678, 685-87
+(11th Cir.2001); Does 1 thru XXIII v. Advanced Textile Corp., 214 F.3d 1058, 1068-69 (9th
+Cir.2000); James v. Jacobson, 6 F.3d 233, 238-39 (4th Cir.1993); L
+v. New York Blood Center,
+213 F.R.D. 108, 110-12 (E.D.N.Y.2003); Javier v. Garcia-Botello, 211 F.R.D. 194, 196
+(W.D.N.Y.2002); Doe v. Smith, 105 F.Supp.2d 40, 43-44 (E.D.N.Y.1999); Doe v. United Servs.
+Life Ins. Co., 123 F.R.D. 437, 439 (S.D.N.Y.1988). Sexual assault victims are a paradigmatic
+example of those entitled to a grant of anonymity. See Doe No. 2 v. Kolko, 242 F.R.D. 193 (E.D.
+N.Y. 2006); Doe v. Blue Cross & Blue Shield United of Wisc., 112 F.3d 869, 872 (7th Cir.1997)
+("fictitious names are allowed when necessary to protect the privacy of ... rape victims, and other
+particularly vulnerable parties or witnesses"); see also Doe v. City of Chicago, 360 F.3d 667, 669
+(7th Cir. 2004).
+The decision whether to allow a plaintiff to proceed anonymously is within the court's
+discretion. See Aware Woman Ctr., 253 F.3d at 684; Javier, 211 F.R.D. at 195; L
+, 213 F.R.D.
+at 110. As set forth above, this Court exercised its direction in one of the consolidated cases,
+Jane Doe v. Jeffrey Epstein, Case No. 08-80893, to allow a plaintiff to proceed under the
+pseudonym "Jane Doe" in an Order dated October 6, 2008.
+7
+
+
+Case 9:08-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 8 of 15
+Courts will permit a party to proceed under a pseudonym where "the party's need for
+anonymity outweighs prejudice to the opposing party and the public's interest in knowing the
+party's identity." Does I Thru XXIII, 214 F.3d at 1068; see Javier, 211 F.R.D. at 195; EW, 213
+F.R.D. at 111; As set forth herein, the balancing test in this case weighs in favor of permitted
+plaintiff to continue to proceed anonymously:
+In undertaking this balance, courts have considered such facts as
+open access to proceedings without denying litigants access to the
+justice system.
+Doe v. Del Rio, 241 F.R.D. 154, 157 (S.D. N.Y. 2006)
+The public has a strong interest in protecting the identities of sexual assault victims so
+that other victims will not be deterred from reporting such crimes. See Doe v. Evans, 202 F.R.D.
+173, 176 (E.D.Pa.2001) (granting anonymity to sexual assault victim); Doe No. 2 v. Kolko, 242
+F.R.D. 193 (E.D. N.Y. 2006). That is particularly true in these consolidated cases where there
+are numerous victims with similar claims. Although these cases have gained considerable media
+attention, there appears to be little public interest in knowing the specific identity of each of the
+victims.
+With regard to the second factor, courts have granted anonymity to protect against
+disclosure of a wide range of issues involving matters of the utmost intimacy, including sexual
+8
+
+
+Case 9:08-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 9 of 15
+assault. See, e.g., Aware Woman Cir., 253 F.3d at 685 (abortion);
+213 F.R.D. at 111
+(infection with hepatitis B); Doe v. Evans, 202 F.R.D. 173, 176 (E.D.Pa.2001) (sexual assault
+victim); Smith, 105 F.Supp.2d at 42 (sexual assault victim); WGA v. Priority Pharmacy, Inc., 184
+F.R.D. 616, 617 (E.D.Mo.1999) (status as AIDS patient); Doe v. United Servs. Life Ins. Co., 123
+F.R.D. 437, 439 (S.D.N.Y.1988) (sexual orientation); see also Blue Cross, 112 F.3d at 872
+(recognizing rape victims as entitled to anonymity). It cannot be reasonably denied that a
+person's sexual history - especially during their childhood - is an intimate fact. When the
+childhood sexual history includes criminal sexual contact by an adult, the facts are even more
+intimate and personal. In the electronic age in which we live, these concerns are heightened. As
+federal courts have recognized in this context, it is now possible to "determine whether a given
+individual is a party to a lawsuit in federal court anywhere in the country by the simplest of
+computer searches, to access the docket sheet of any such case electronically, and ... that entire
+case files will be accessible over the Internet." Doe v. City of New York, 201 F.R.D. 100, 102
+(S.D.N.Y.2001) (denying anonymity where any injury was purely reputational and case did not
+involve private or intimate matter); see
+213 F.R.D. at 112-13.
+As Dr. Kliman explains in his Declaration, disclosure of Jane Does 2-7's identities will
+place these Plaintiffs "at-risk of having their personal lives scrutinized by friends, extended
+family, spouses, children, fellow students, employers and fellow employees, the media and
+general public. This type of exposure humiliates many victims and represents another betrayal of
+trust. Public exposure places the plaintiff's at further risk of stigmatization, shame and
+retraumatization." See Exhibit "A" at 9| 3. Dr. Kliman also finds it of no consequence that some
+of the plaintiffs are now legally adults in that "[dJue to traumatization the plaintiffs are arrested
+in their development, and even those who are now legally adult are arrested in part to adolescent
+9
+
+
+Case 9:08-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 10 of 15
+aspects of psychology." Id. at 94
+The policy of protecting victims of sexual misconduct from undue embarrassment and
+disclosure of their private affairs is firmly established in Fed.R.Evid. 412. The protections of
+Rule 412 are designed to "encourage victims of sexual misconduct to institute and participate in
+legal proceedings against alleged offenders." (Committee Notes to 1994 Amendment).
+Likewise, many states in this country, including Florida and New York, have similarly enacted
+laws to protect the anonymity of sexual assault victims. See Fla. Stat. §§794.024, 794.026
+(2008); N.Y. Civil Rights Law § 50-b (McK inney 2009). In 1994, the Florida Legislature passed
+The Crime Victims Protections Act. The legislative stated purpose for the Act was "to protect
+the identity of victims of sexual crimes." Fla. AGO, 2003-56, 2003 WL 22971082 (Dec. 15,
+2003). Under §794.024, Florida Statutes, court records that identify the name and/or address of a
+victim of a sexual crime are presumed to be confidential and exempt from public access. Id.
+Similarly, upon approving New York's rape shield law, then Governor Mario Cuomo stated,
+"sexual assault victims have unfortunately had to endure a terrible invasion of their physical
+privacy. They have a right to expect that this violation will not be compounded by a further
+invasion of their privacy." 1991 McKinney's Sessions Laws of N.Y., at 2211-2212 (quoted in
+Deborah S. v. Diorio, 153 Misc.2d 708, 583 N.Y.S.2d 872 (N.Y.City Civ.Ct.1992)); see also
+Coker |. Georgia, 433 U.S. 584, 597, 97 S.Cl. 2861, 53 L.Ed.2d 982 (1977) ("Short of homicide,
+[rape] is the ultimate violation of self").
+As to the fourth factor of risk injury, Dr. Kliman has evaluated Jane Does 2-7, and has
+concluded that the childhood sexual abuse at issue has caused features of post-traumatic stress
+disorder (PTSD), including shame, guilt, helplessness, and powerlessness. See Exhibit "A" at 19)
+4-7. Dr. Kliman further states,
+"it is more probable than not that releasing personal identities
+10
+
+
+Case 9:08-cv-80119-KAM Document 144 Entered on FLSD Docket 06/08/2009 Page 11 of 15
+will foster an exacerbation and magnification of symptoms lending to increased risk of
+revictimization and retraumatization." Id. at 9 21. Thus, this is not a case analogous to those
+cited by defendant in which the plaintiffs were merely at risk of "personal embarrassment."
+Instead, there is a genuine and immediate risk of psychological harm.
+None of the cases cited by Defendant where courts denied a plaintiff's request for
+anonymity involved victims of childhood sexual assault or evidence of emotional or
+psychological harm that would result from disclosure of the plaintiff's identity. See Doe v. Hartz,
+52 F.Supp.2d 1027 (N.D.Iowa 1999); Doe v. Shakur, 164 F.R.D. 359 (E.D.N.Y.1996); Doe v.
+Bell Atlantic Bus. Sys. Servs., 162 F.R.D. 418 (D.Mass.1995); Doe v. Univ. of Rhode Island, 28
+Fed.R.Serv.3d 366, 1993 WL 667341 (D.R.I. Dec. 28, 1993).
+As to the factor of prejudice, the Defendant does not identify how his ability to conduct
+discovery or impeach Jane Does 2-7's credibility has been or will be impaired if these Plaintiffs
+213 F.R.D. at 112, Smith, 105 F.Supp.2d
+are permitted to proceed under a pseudonym. See
+at 44-45. Other than the need to make redactions and take measures not to disclose these
+Plaintiffs' identities, Defendant will not be hampered or inconvenienced merely by Plaintiffs'
+anonymity in court papers. As set forth above, Defendant already knows their true identities. See
+Aware Woman Center, 253 F.3d at 687 (no prejudice where plaintiff offered to disclose her name
+to defendant);
+213 F.R.D. at 112; Smith, 105 F.Supp.2d at 44-45.
+II. DEFENDANT SHOULD NOT BE PERMITTED TO USE
+THE REAL NAMES OF JANE DOES 2-7 IN THIRD-PARTY
+SUBPEONAS EXCEPT FOR THOSE ISSUED TO PERSONS WHOM
+PLAINTIFFS HAVE ALREADY DISCLOSED THEIR SEXUAL ABUSE
+As for the use of Jane Does 2-7's real names in subpoenas issued to non-parties, a party
+may obtain discovery of any non-privileged matter that is relevant to a claim or defense of any
+party. Fed.R.Civ.P. 26(b)(I). However, a district court may limit discovery "for good cause
+11
+
+
+Entered on FLSD Docket 06/08/2009 Page 12 of 15
+shown" by making "any order which justice requires to protect a party or person from
+annoyance, embarrassment, oppression, or undue burden or expense," including that the
+discovery not be had or that it be had only by a method other than that selected by the party
+seeking discovery. Fed.R.Civ.P. 26(c). Jane Does 2-7 have articulated a specific and substantial
+harm from disclosure of their identities.
+If this Court were to permit Defendant to issue third-party subpoenas containing Jane
+Doe 2-7's real names, the identity of the Defendant, and/or facts pertaining to the nature of the
+case to whomever Defendant wants, it would be akin to requiring these Plaintiffs to use their real
+name in the pleadings.
+Instead, Jane Does 2-7 propose to voluntarily execute authorizations
+(which would not contain the case names or the identity of the Defendant) to allow Defendant to
+obtain education, employment, and medical records to be used for purposes of this litigation
+only.? Alternatively, Defendant can obtain the records through a special master, who would
+verify authenticity and completeness of the records. Either of these approaches would not only
+place Jane Does 2-7 at less risk of psychological harm, but would also be more cost-effective and
+efficient.
+CONCLUSION
+Based on the foregoing, Plaintiffs Jane Does 2-7 respectfully request that Defendant's
+Motion to Compel and/or Identify Plaintiffs in the Style of this Case and Motion to Identify Jane
+Doe in Third-Party Subpoenas for Purposes of Discovery, or Alternatively, Motion to Dismiss
+"Sua Sponte" be denied in its entirety, and that Plaintiffs Jane Does 2-7 be permitted to continue
+using their pseudonyms in this litigation. Additionally, to avoid public disclosure of the
+Plaintiff's identities in non-party records discovery, Plaintiffs Jane Does 2-7 request that such
+3 Defendant and Plaintiff have previously agreed that education records can be obtained in this
+12
+
+
+Entered on FLSD Docket 06/08/2009 Page 13 of 15
+discovery be obtained either through Plaintiffs' counsel by means of written authorizations, or by
+the appointment of a special master.
+Dated: June 8, 2009
+Respectfully submitted,
+By:
+s/ Adam D. Horowitz
+Stuart S. Mermelstein (FL Bar No.
+Adam D. Horowitz (FL Bar No.
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs Jane Doe Nos. 2-/
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+manner in lieu of subpoenas.
+13
+
+
+Entered on FLSD Docket 06/08/2009(
+
+I hereby certify that on June 8, 2009, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
+this day to all parties on the attached Service List in the manner specified, either via transmission
+of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for
+those parties who are not authorized to receive electronically Notices of Electronic Filing.
+/s/ Adam D. Horowitz.
+14
+
+
+
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+Robert D. Critton, Esq.
+Bradley James Edwards
+Isidro Manuel Garcia
+Jack Patrick Hill
+Katherine Warthen Ezell
+Michael James Pike
+Paul G. Cassell
+Richard Horace Willits
+Robert C. Josefsberg
+Is/ Adam D. Horowitz
+15
+
+
+Case 9:08-cv-80119-KAM Document 144-3 Entered on FLSD Docket 06/08/2009 Page 1 of 23
+professional publications include books and peer-reviewed medical journal articles on mass
+disasters, most recently concerning the Attack on America.
+anchorwoman, Linda Yee, concerning his Salvation Army project providing the Cornerstone
+form of psychoanalytic psychotherapy for homeless preschoolers and toddlers,, The Cornerstone
+project itself was viewed on the Channel I! Five O'Clock News. KGO TV interviewed Dr.
+Kliman concerning a forensic testimony, with a focus on a Stanford football player who had
+allegedly become a child molester. During the Lewinsky-Clinton matter, Kliman was
+interviewed by Channel 12/20 concerning psychoanalytic views of leaders having exceptional
+sexual access to partners and the risk of a position of power overcoming the judgments of such
+leaders. During 2001 following the World Trade Building terrorism, Dr. Kliman was
+interviewed by Channel II News and appeared on five occasions thereafter through 2003
+concerning the Afghanistan and Iraq wars. In May 2003, he was discussant with U.N. Secretary
+General Olaru Otonu, featured on Dhubai Business TV concerning the plight of children in war.
+In 2004, together with the International Psychoanalytic Association, Dr. Kliman helped organize,
+establish and supervise a therapeutic preschool project in Buenos Aires.
+"Cornerstone
+Argentina" is now in its second year of treating severely disturbed and impoverished
+preschoolers, with his continuing collaboration.
+Following the hurricane disasters of 2005 he collaborated with Mercy Corps and the Children's
+Psychological Health Center to produce a mental health resource. The result, "My Katrina and
+Rita Story", a guided activity resource of families who had to deal with the hurricanes. Mercy
+Corps is distributing copies to 20,000 families.
+In 2005, RE DISTURBED PRESCHOOLERS Dr. Kliman helped organize, establish and
+supervise a therapeutic project in Piedmont California, at the nonprofit Ann Martin Center.
+In 2007, RE HOMELESS CHILDREN: Dr. Kliman helped establish a Reflective Network
+Therapy service for homeless preschoolers in Seattle. He provided four days of training in that
+method for the Family Service Center of King County (located in Seattle), and created an
+organizational link between The Family Services Center and The Children's Psychological
+Health Center, Inc. of San Francisco in order to continue serving homeless children in Seattle.
+In 2008, Dr. Kliman activated the Reflective Network Therapy services for preschoolers in
+Seattle. He supervises there in person and by phone and video.
+In 2008, RE DISASTER SERVICES: Following the Sichuan Earthquake Disaster of May 12,
+2008, Dr. Kliman established a link between Children's Psychological Health Center, Inc.
+Mercy Corps, and The China America Psychoanalytic Alliance. He created mental health
+resources (see Publications) which were licensed for mass distribution in China by Mercy Corps.
+In 2008, Dr. Kliman helped found a new non-profit organization called Teach with Africa and is
+a member of its Board of Directors.
+2
+
+
+Case 9:08-CV-80119-KAM Document 144-3
+
+Foundation, The Dreyfus Foundation, The Seth Sprague Foundation, The Granick Foundation,
+The Harris Foundation, U.S. Trust, and The Scheuer Family Foundation.
+Most recent grants:
+1996-2002: Support from The Office of Education, Division of Special Education, San Mateo
+County, California.
+1996 The Windholz Foundation, San Francisco, for video documentation of an experimental
+project concerning treatment of disturbed and traumatized preschool patients in a public
+education special education division.
+1999 Morris Stulsaft Foundation for video-recording facility to document treatment in The
+Cornerstone Therapeutic School.
+1999-2001 The Cadence Corporation - for early childhood treatment services
+2000-2001 The Harris Foundation for Cornerstone Therapeutic School.
+2000 Funding and Recognition by the State of California: In 2001, The Department of
+Education, Division of Special Education, certified the Cornerstone Therapeutic School as a
+nonpublic special education school, allowing public entities to fund the school by contracts with
+Unified School Districts.
+2001 The San Francisco Day Care Corporation - for Cornerstone Therapeutic School.
+2001 The Sophie Murvis Foundation for Training of Teachers and Therapists in the Cornerstone
+Method.
+2002, 2003. The Five Bridges Foundation for development of The Cornerstone Therapeutic
+Preschool 2003.
+2005 The Sophie Murvis Foundation grant for Training of Teachers and Therapists in the
+Cornerstone Method.
+2005 Mercy Corps for creation of "My Personal Story about Hurricanes Katrina and Rita"
+2008 Mercy Corps for creation of "My Sichuan Earthquake Story"
+JANUSZ KORCZAK INTERNATIONAL LITERARY PRIZE:
+First place, International Literary Prize including an award of one thousand dollars, for "World's
+Best Book Concerning the Well-Being of Children"-Awarded to Gilbert Kliman, M.D. and
+Albert Rosenfeld, co-authors of Responsible Parenthood, published by Holt, Rinchart and
+Winston, New York, 1980
+PUBLISHED PAPERS AND BOOKS:
+4
+
+
+Case 9:08-CV-80119-KAM Document 144-3 Entered on FLSD Docket 06/08/2009 Page 5 of 23
+23. "Mourning, Memory, and Reconstruction: The Analysis of a Four-Year-Old
+Maternally Bereaved Girl at Age Sixteen Months" (With Thomas Lopez, Ph.D.), in
+The Psychoanalytic Study of the Child, Volume 34, The New York Times Press, New
+York, 1979.
+24. "Facilitation of Mourning During Childhood," in Gerber, I., Wiener, A., Kutscher, A.,
+et al., Perspectives on Bereavement, MSS Information Corporation, New York, 1979.
+25. "The Cornerstone Treatment of a Preschool Boy from an Extremely Impoverished
+Environment" (with Thomas Lopez, Ph.D.), The Psychoanalytic Study of the Child,
+Vol. 35, The New York Times Press, New York, 1980.
+26. Responsible Parenthood: The Child's Psyche Through the Six-Year Pregnancy, Holt,
+Rinchart, and Winston, New York, 1980.
+27. "Death: Some Implications in Child Development and Child Analysis," in Advances in
+Thanatology, Vol. 4, No. 2, Arno Press, New York, 1980.
+28. "Children in Foster Care: A Preventive Service and Research Program for a High Risk
+Population" (with M. Harris Schaeffer, Murray J. Friedman, and Bernard G.
+Pasquariella). The Journal of Preventive Psychiatry, Volume I: 1, 1981,
+29. Editorial(s). The Journal of Preventive Psychiatry. Volume I, 1981-1982, Volume II,
+1983-4, Volume III, 1985-7, Volume IV, in press.
+30. Preventive Mental Health Services for Children Entering Foster Family Care: An
+Assessment (with M. Harris Schaeffer, and M. Friedman). The Center for Preventive
+Psychiatry, White Plains, New York, 1982.
+31. "Summary
+of Two Psychoanalytically
+Preventive Treatments for Foster Children" with M. Harris Schaeffer, Ph.D. J. of
+Preventive Psychiatry, Vol. II, No. 1, 1983.
+32.
+"Three New Areas in Litigation on behalf of Children," in Child Psychiatry and the
+Law, Diane Schekty, Editor, Volume 2, Bruner/Mazel, New York, 1985.
+33. Preventive Psychiatry: Early Intervention and Situational Crisis Management, coeditor, with S.C. Klagsbrun, M.D., E.J. Clark, Ph.D., others. The Charles Press,
+Philadelphia, 1989.
+34. My Earthquake Story: A Guided Workbook for Children, Parents and Teachers, with
+Harriet Wolfe, M.D. and Edward Oklan, M.D. Psychological Trauma Center Press,
+Kentfield, CA. October, 1989.
+"Facilitation of Mourning During Childhood," chapter in Preventive Psychiatry: Early
+Intervention and Situational Crisis Management. (Eds) S. Klagsbrun, G. Kliman, E.
+Clark, A. Kutscher, R. DeBellis, C. Lambert. The Charles Press, Philadelphia, 1989.
+"Toward Preventive Intervention in Early Childhood Object Loss," chapter in
+Noshpitz, H. and Coddington, D. (Eds) Stressors and Clinical Techniques in Child
+Psychiatry. Charles Thomas, NY, 1990.
+37. "Brief Report: Loss of Parental Services—A Guide to Categorization." J. Preventive
+Psychiatry and Allied Disciplines 4:1, 1990. Human Sciences Press, NYC.
+Disciplines 4:1, 1990. Human Sciences Press, NYC.
+39.
+"The Rise of Adolf Hitler and Other Genocidal Leaders-Psychoanalytic and
+Historical Symposium (Summary)," J. Preventive Psychiatry and Allied Disciplines
+4:1,1990. Human Sciences Press, NYC.
+6
+
+
+Case 9:08-cv-80119-KAM Document 144-3
+
+57.
+"My Hurricane Story" A Guided Activity Workbook to help Children Cope. The
+Children's Psychological Health Center. Sept 21, 2008
+WORKS IN PROGRESS: available in Draft:
+IQ Rise among Preschoolers with Pervasive Developmental Disorders.
+Child Psychoanalytic Contributions to Civil Justice System, submitted by invitation, to
+Psychoanalytic Inquiry
+Books in Draft:
+1. Reflective Network Therapy: Early Childhood Psychotherapy in the Classroom
+2. A Unifying New Theory of Posttraumatic Stress Disorder
+PRESENTATIONS:
+01. "Specific Traumas: Selective Review of Literature," presented at the Ernst Kris Study
+Group, New York Psychoanalytic Institute, New York, 1965.
+02. "Psychoanalysis of a Four-Year-Old in a Preschool Group," presented at the American
+Psychoanalytic Association, Atlantic City, New Jersey, May, 1966
+03. "Covert Suicidal Impulses in Maternally Deprived Children" (with Harriet Lubin, M.S.W.),
+presented at the American Association of Psychiatric Services for Children, Boston,
+Massachusetts, November, 1969.
+04. Children's Reactions to National Events: The 1968 Federal Elections," presented at the
+American Orthopsychiatric Association, Washington, D.C., 1969.
+05. "Facilitation of Mourning During Childhood," presented at the Chicago Psychoanalytic
+Institute, May 1973.
+06. "Preventive Approaches to Preschool Psychiatric Disorders: Some Assessments," presented
+at the Academy of Child Psychiatry, Washington, D.C., October, 1973.
+07.
+"Biological Drive Derivative Cycles in Preschool Patients," presented at the New York
+Psychoanalytic Institute Research Seminar, 1974.
+08. "Children in National Disasters," presented at the International Association for Child
+Psychiatry, Philadelphia, Pennsylvania, 1974.
+09. "Childhood Mourning: Some Social Aspects," presented at Yeshiva University, New York,
+October, 1974.
+10. "The Center for Preventive Psychiatry's Interventions with Bereaved Children," presented
+at the second annual conference on "The Impact of Bereavement and Grief on the Family."
+Yeshiva University, October 15, 1975.
+11. "Death: Implication for Psychoanalytic Theory and Practice," presented at The Association
+for Psychoanalytic Medicine, New York, 1977.
+12. "A Psychoanalytic View of an Ancient Mass Disaster: The Mayan Exodus," The Center for
+Preventive Psychiatry, 1977.
+8
+
+
+Case 9:08-cv-80119-KAM Document 144-3 Entered on FLSD Docket 06/08/2009 Page 9 of 23
+33. Seminar on "New Areas in Forensic Psychiatry," at the Robert Cartwright law firm, San
+Francisco, 1986. VIDEOTAPE AVAILABLE
+34. "Children's Reactions to the Challenger Shuttle Disaster," on 20/20 (Television Broadcast),
+1986. VIDEOTAPE AVAILABLE
+35. The Fathering of Adolf Hitler," Grand Rounds, McAuley Neuropsychiatric Institute, St.
+Mary's Hospital, San Francisco, 1986.
+36. "Child Sexual Abuse: Psychoanalytic and Forensic Approaches," Children's Hospital, San
+Francisco, 1986. VIDEOTAPE AVAILABLE
+37. "Preventive Psychiatry for Children," Training Seminar at McAuley Neuropsychiatric
+38.
+Institute, St. Mary's Hospital, San Francisco, 1987. VIDEOTAPE AVAILABLE
+"Multi-Victim Child Sexual Abuse," San Francisco Psychoanalytic Institute Extension
+Division, October 1987. VIDEOTAPE AVAILABLE
+39. "Children in Foster Families: Advances in Preventive Psychiatry," Continuing Education
+Program for Psychiatrists, U.C. Davis, 1988.
+40. "The Mothering of Adolf Hitler," Grand Rounds. McAuley Neuropsychiatric Institute, St.
+Mary's Hospital, San Francisco, Dec. 1988.
+41. "Adolf Hitler's Mothering: A Child Psychoanalytic View," Westchester Psychoanalytic
+Society, New York Hospital, January, 1989.
+42. "The Personal Life History Book: Preventive Psychotherapy for Children in Chaos."
+Department of Child Psychiatry, Harlem Hospital, New York, NY, January, 1989.
+43. Chairman: Symposium April 20-21, 1989. The Rise of Adolf Hitler and Other Genocidal
+Leaders. Interdisciplinary Unit for Study of Mass Violence and Genocide. St. Mary's
+Hospital Department of Psychiatry, San Francisco.
+44.
+"The Mothering of Adolf Hitler," Symposium above. VIDEOTAPE AVAILABLE
+45.
+"The Fathering of Adolf Hitler," Symposium above. VIDEOTAPE AVAILABLE
+46. Public Media: Following the October 17th earthquake, Dr. Kliman and his Psychological
+Trauma Center associates appeared on KRON-TV, KFAS, KQED and public service radio
+network to offer advice and respond to call-in questions regarding earthquake stress and
+trauma. His Earthquake Story guided workbook (see above) was distributed as a public
+service by San Francisco Community Mental Health Services and the Oakland Bureau of
+Education to 11,000 teachers in Oakland and San Francisco.
+47. Marin Psychoanalytic Society: (April 1990) "Simultaneous child and couple therapy:
+emergence and interpretation of congruent unconscious themes."
+48. University of California College of Medicine, Department of Psychiatry, Irvine. (June
+1990) "Prevention of Psychopathology among Children: Systematic Projects with Foster
+Children."
+49. Preventive Interventions with Traumatized Children," Grand Rounds California Pacific
+Hospital Department of Psychiatry, October 20, 1992. VIDEOTAPE AVAILABLE.
+50. Altered Interpersonal Schemas After Life Threatening Childhood Trauma," Center for
+Study of Consciousness, UCSF, October 1992.
+51. Alterations of Pre-Traumatic Memory and Post Traumatic Schemas," Child Analysis
+Colloquium, San Francisco Psychoanalytic Institute, November 1992.
+52. Toward A New Theory of Post Traumatic Stress Disorder," Control Mastery Group, San
+Francisco Psychoanalytic Institute, December 1992.
+53. Severe Psychological Trauma in Very Young Children," Grand Rounds at the Menninger-
+San Mateo County Hospital Psychiatric Residency Program, March 23, 1993.
+54. Psychological Crises Among Preschoolers," Department of Health, City of San Francisco,
+April 1993.
+55. Child Analysis Colloquium," San Francisco Psychoanalytic Institute, May 1993.
+10
+
+
+Case 9:08-cv-80119-KAM Document 144-3 Entered on FLSD Docket 06/08/2009 Page 11 of 23
+79. "Operational Confirmation of a Psychoanalytic Hypothesis: Detecting and Interfering with
+The Repetition Compulsion," Cleveland Psychoanalytic Institute and Anni Katan Center for
+Child Development, October 28, 1995.
+80. The Personal Life History Book Method: Reducing Transfers Among Foster Family
+Homes," The Center for Preventive Psychiatry, White Plains, NY, October 30, 1995.
+81. "A New Theory of Posttraumatic Stress Disorder," Grand Rounds, Baylor University
+School of Medicine, Houston, November 8, 1995.
+82. "Raising IQ's in a Therapeutic Nursery: The Cornerstone Method. How it works as
+illustrated by video clips of the therapist and patients in the classroom," The Houston
+Psychoanalytic Institute and Stedman West Child Development Center, Houston, TX,
+November 8, 1995.
+83. "The Difficult Client: Accredited Continuing Legal Education seminar for California
+Attorneys." The Psychological Trauma Center, The Psychological Trauma Center, 1996.
+84. "Catastrophic injuries and psychological trauma: Accredited Continuing Legal Education
+seminar for California Attorneys." The Psychological Trauma Center, 1996.
+85. "Why Small Clients Get Large Awards: Proving and Disproving Psychological Injuries in
+Childhood. Accredited Continuing Legal Education seminar for California Attorneys."
+86. "A New Public Health Approach in Public Special Education: Presentation to The San
+Mateo Board of Education," San Mateo, CA. April 17, 1996.
+87. A new model for special education of preschoolers: The Cornerstone Method -- for synergy
+between early childhood education and psychotherapy. California State Dept. Education,
+Division of Special Education September 1996, Red Lion Hotel, Orange County Airport,
+88. "Synergy Between Special Education and Psychotherapy in the Classroom: Special
+Education Learning Program Administrators," San Mateo, CA. October 10, 1996.
+"The Role of Psychoanalyst as Forensic Expert in Catastrophic Psychological Trauma
+Cases." American Psychoanalytic Association, Winter Meeting, Waldorf Astoria, NY.
+December 1996
+Controlled Assessment of a Psychoanalytically Derived Psychotherapy." Americar
+rsychoanalytic Association, Winter Meeting, Waldorf Astoria, NY December 1996
+91. "Child Psychotherapy Course: Several preschool patients with different diagnosis, treated in
+a preschool therapeutic nursery, showing response to interpretations, with discussions of the
+role of teacher, parents and medications." San Francisco Psychoanalytic Institute, March 4,
+11, 18, 1997
+"Synergy between Psychotherapy and early childhood special education" SELPA
+Administrators, April 17, 1997
+"Analyst in the Nursery: The Cornerstone Method," San Francisco Psychoanalytic Institute,
+May 21, 1997
+"Psychological Trauma Among Preschoolers," San Francisco Psychoanalytic Institute, May
+15, 1997
+95. ACT for Mental Health, April 17, 1997
+96. "New Theory of Posttraumatic Stress Disorder," Fifth European Conference on Traumatic
+Stress, European Society for Traumatic Stress Studies, July 1, 1997.
+97. Education tasses. Caldo mite Siate Prederation/ Countle for Bin elonal Children tiall
+Annual Conference & Special Education Fall Conference, San Francisco, CA, October 21-
+24, 1998.
+98. Research and treatment with highly traumatized preschoolers. Wright Institute, Berkeley,
+Feb. 4, 2002.
+12
+
+
+Case 9:08-cv-80119-KAM Document 144-3 Entered on FLSD Docket 06/08/2009 Page 13 of 23
+110. Presentations of video-taped child treatment sessions: The Child Analysis Study Group of
+the San Francisco Psychoanalytic Institute, six occasions 2001-2002.
+111. New Theory and New Treatments of Children. Northern California Society of Mental
+Health Professionals. Feb 8, 2002.
+112. Treatment of Children in their Real Life Spaces. Ann Martin Center, Berkeley, CA
+February 2, 2002.
+113. Treatment of children in community school settings. Workshop on Community Child
+Psychiatry. American Academy of Child and Adolescent Psychiatry. October 2002.
+114. Treatment of preschoolers in real life space - The Cornerstone Method. A two day training
+workshop for the L.A. County Dept. of Mental Health. October 2002.
+115. The Cornerstone Method. The American Psychoanalytic Association, Workshop on Early
+Childhood. January 2003, New York.
+116. Treatment of Three Autistic Preschoolers: The American Psychoanalytic Association. June,
+2003. Boston.
+117. The Personal Life History Book: A Preventive Therapy for Foster Children. A day-long
+workshop at Counseling4Kids, Los Angeles, September 2003.
+118. A new method of treatment of autistic preschoolers. The Chinatown Child Development
+Center, San Francisco, December 4, 2003.
+119. Results of the Cornerstone Method: Pervasive Developmental Disorder with eight month to
+37 year followup. The M.I.N.D. Institute, U.C. Davis, December 19, 2003.
+120. Procedures for preventing and reducing psychopathology among foster children. Joint
+Committee of AACAP and Child Welfare League, November 2003, with Marilyn Benoit,
+M.D.
+121. The Role of Child Psychiatrists in Prevention of Child Abuse: Forensic Child Psychiatry as
+a Societal Influence. Mensa Society, January 2004.
+122. Psychoanalysis Confronts Autism. The L.A. and SoCal Psychoanalytic Institutes, February
+22, 2004.
+123. Child Psychiatric Testimony and the Leading Edge of Social Change. American College of
+Forensic Psychiatry, March 28, 2004
+124. The Cornerstone Method of Treating Autism, American Psychoanalytic Association,
+Boston, Mass., January 2005.
+125. An evidence based method for in-classroom treatment of disturbed preschoolers. Child
+Welfare League of America. New Orleans, May 2005.
+126. Two evidence-based methods for treating foster children. International Psychoanalytic
+Association, Rio de Janeiro, Brazil, July 2005.
+127. A novel evidence-based method for treatment of Asperger's Disorder. Lorman Educational
+Seminars, Redding, CA. November 18, 2005
+128. "Applications of The Cornerstone Method to Children with Autism Spectrum Disorders"
+American Psychoanalytic Association, New York, New York. January 18, 2006
+129. "Applying The Cornerstone Method in Public Schools" Philadelphia Board of Education
+April 28,06 DVD FORMAT AVAILABLE
+130. "Crises Intervention Techniques Within Schools: What you Need to Know When Large or
+131. saying do Dibe: Trikes in a outiny senAna Mening of The A,merican
+Annual Meeting, New York, NY, October 5-8, 2006.
+14
+
+
+Entered on FLSD Docket 06/08/2009 Page 15 of 23
+Member, Joint Committee on Foster Care: Academy of Child and Adolescent Psychiatry and the
+Child Welfare Association.
+PROFESSIONAL COMMENDATIONS:
+A letter of commendation regarding clinical work in the classroom within a public school
+system:
+December 3, 2001
+To Whom It May Concern:
+This is to report that the San Mateo County Office of Education, Special Education programs,
+has benefited from the services of The Children's Psychological Health Center, specifically its
+Cornerstone Therapeutic School Project.
+We have worked together for the past six years. Under the leadership of Gilbert Kliman, M.D.,
+the Center has trained members of our teaching and school psychology staff to carry out a
+mental health service on our premises. We now have a collaborative project in its sixth year for
+our special education preschool children with Pervasive Developmental Disorders (PDD) and
+for those with Serious Emotional Disorders (SED) which interfere with their education. As an
+alternative to sending children to a private nonpublic special education school for extremely
+intensive mental health services at significant cost, this project has created and provides just
+such intensive service within a public preschool special class program at 65 Tower Road, San
+Mateo.
+To my knowledge, among the 30 children served so far under the collaborative project, we are
+seeing cognitive, social and human gains which have decreased the gap between these children
+and their typically developing peers. Several families and children are thriving with less
+intensive special education service or returned to regular education class. Not only has the
+family and child suffering been reduced, the burden to taxpayers is also reduced. The children
+have been able to remain in the community, and some who were functioning as severely autistic
+and retarded now appear to be developing within a somewhat normal range. We are pleased
+with the quality of special education services our County provides for preschoolers with PDD or
+SED. We are also gratified with the research results provided by The Children's Psychological
+Health Center.
+We recommend the Cornerstone project to other school systems, so that they consider it an
+important opportunity should they be able to collaborate similarly with The Children's
+Psychological Health Center. At California's common cost of $15,000 to $40,000 or more a
+year, for a special education child who needs full time special education services and auxiliary
+intensive help, the savings for even one child's 12-year career of intensive services in special
+education can be substantial. The savings from one of the successes we have seen may equal the
+costs of the entire Cornerstone project with the 30 children helped so far.
+16
+
+
+Case 9:08-cv-80119-KAM Document 144-3 Entered on FLSD Docket 06/08/2009 Page 17 of 23
+to rescue himself. The foster father's partner was negligent, Dr. Kliman opined. The judge
+agreed and awarded the child compensation for psychological damages.
+Does vs. Archdiocese of Los Angeles. Dr. Kliman was the lead psychiatric witness. The case
+settled after six days of his deposition testimony.
+Does vs. Salesian Order Western Region. Dr. Kliman was the lead psychiatric witness. The case
+settled after nine days of his deposition testimony and two days of trial.
+Does v South Dakota School for the Deaf. Multiple boys were molested by an older student. The
+state school administration was allegedly negligent and major psychological damages were
+claimed. Dr. Kliman served as the principal plaintiffs' expert on administrative liability issues
+and psychological damages. The case settled with major compensation for the plaintiffs during
+the time of jury deliberations.
+CHILD PSYCHIATRIC EXPERT TESTIMONY:
+Dr. Kliman helped set legal precedents for the inclusion of psychiatric testimony in matters
+concerning wrongful death of a parent and loss of parental services, in both New York State and
+California. He has testified in over 275 cases including over 100 trials. A Federal Rule 26 list is
+available on request and on www.expertchildpsychiatry.com. His courtroom and deposition
+testimony experience includes cases of institutional negligence of children leading to
+psychological trauma, negligent foster care, loss of parental services due to wrongful deaths,
+psychological trauma as part of personal injury of adults and children, childhood molestation,
+sexual harassment, termination of parental rights, and disputed custody. Since 2000 about 30%
+of his forensic work has been requested by defense, about 70% by plaintiffs, with the defense
+tasks increasing markedly in recent years.
+Dr. Kliman's evaluations and testimony regarding 16 children negligently cared for and abused
+at The Kiwanis' OK Boys' Ranch, Olympia, WA, helped lead to settlements and awards,
+totalling $25,000,000. Responding to disclosures in that case, many improvements have occurred
+in the publicly funded and licensed institutional care of children throughout the State of
+Washington, according to newspaper accounts.
+Dr. Kliman's evaluations and opinions, together with that of The Children's Psychological
+Trauma Center team led by Robert Wynne MFCC, led to record-making $8,000,000 loss of
+parental and other services compensation for 17 bereaved subsistence-economy Alaskan Inupiat
+Native Americans (Smith vs. Ryan Airlines, Anchorage, 1997).
+Principal expert regarding institutional negligence and psychological damages in Does vs.
+Rudolph Kos and the Diocese of Dallas, Dallas 1997. The Catholic Church of Dallas was held
+liable for institutional negligence, testimony concerning the need for major psychiatric treatment
+planning was accepted by the jury, and $119,000,000--including punitive damages against the
+Church--was awarded to the 11 plaintiffs, by unanimous decision.
+18
+
+
+
+Archive of Videotaped
+Seminars and Events:
+- Gilbert Kliman, M.D., Medical Director
+THE CHILDREN'S PSYCHOLOGICAL TRAUMA CENTER
+(A division of the Children's Psychological Health Center, Inc.)
+Archive of Videotaped Seminars and Events:
+CONTINUING LEGAL EDUCATION TAPES:
+California MCLE credit is available to attorneys for study of these tapes. Unless otherwise
+indicated, Gilbert Kliman, M.D. was the sole or principal speaker. Contact Edith Lee at
+for MCLE credit fulfillment associated with study of these tapes.
+01. True and False Allegations of Sexual Molestations, 1987. 1.5 hrs.
+02. Loss of Parental Services, May 6" 1992 Elina Wayrynen and Gilbert Kliman, M.D.
+2.0 hrs.
+03. Abuse in Institutions, August 1" 1995, 2.0 hrs.
+04. Catastrophic Accidents with Lifetime Psychological Damage, December 5" 1995 2.5
+05.
+Evaluating Psychological Trauma in Catastrophic Accidents (Grosvenor Hotel, San
+Francisco) 1996, 2.5 hrs.
+06.
+Loss of Parental Services (Holiday Inn), January 9"* 1996, 2.5 hrs.
+07.
+Loss of Parental Services, May 12'" 1993 1.5 hrs.
+08.
+True and False Allegations of Sexual Abuse, June 7" 1993, 1.5 hrs.
+Catastrophic Psychological Traumas in Childhood, February 1994, 2.5 hrs.
+The Difficult Client, February 27" 1996, 2.5 hrs.
+The Difficult Client (at Wells Fargo), February 6' 1996, 2.5 hrs.
+12. Evaluating the Validity of Recovered Memories: Perspective of a Forensic Expert,
+February 29 1996, 1.0 hr.
+13. How Small Clients Get Large Awards, Psychological Trauma in carly childhood
+produces life time consequences in some cases. Defense and plaintiff considerations.
+14. Giving Powerful Voices to Children in Court: I, March 20#* 1998. Windle Turley, Esq.
+With Gilbert Kliman, M.D., 2.5 hrs.
+15. Giving Powerful Voices to Children in Court II, May 8" 1998, John Connelly, Jr. with
+Gilbert Kliman, M.D., 2.5 hrs.
+20
+
+
+Case 9:08-CV-80119-KAM Document 144-3
+Entered on FLSD Docket 06/08/2009 Page 21 of 23
+The Children's Psychological Health Center
+Archive of Videotaped Seminars and Events:
+- Gilbert Kliman, M.D., Medical Director
+CLINICAL AND SCIENTIFIC TAPES:
+STARRED (*) TAPES BELOW ARE A PRECIOUS ARCHIVE OF INFORMATION ABOUT
+PROBLEMS AND TREATMENT OF SEVERELY STRESSED CHILDREN. THEY ARE
+NOT FOR SALE OR COMMERCIAL DISTRIBUTION. THEY MAY BE STUDIED AT
+CPHC ON-SITE WITH ASSISTANCE OF OUR STAFF BY QUALIFIED RESEARCHERS,
+CLINICIANS, SPECIAL EDUCATION TEACHERS, ADMINISTRATORS OF NONPROFIT
+CLINICAL ORGANIZATIONS AND SCHOOLS FOR CHILDREN, SCIENTISTS AND
+STUDENTS OF RELEVANT DISCIPLINES BY APPOINTMENT AT CPTC
+HEADQUARTERS. CREDENTIALS, REFERENCES AND CONFIDENTIALITY
+AGREEMENT ARE REQUIRED COLLABORATIVE RESEARCH ARRANGEMENTS CAN
+BE CONTRACTED FOR WITH CONFIDENTIALITY AGREEMENTS AND LONG TERM
+USE OF THE TAPES.
+*1. Childhood Post Traumatic Stress Disorder (California Pacific Hospital Grand Rounds).
+1992
+*2.
+New Theory of Post Traumatic Stress Disorder, Gilbert Kliman, M.D. December 4"*
+1992, International Association of Child and Adolescent Psychiatry and Allied
+Disciplines, Fairmont Hotel, San Francisco.
+*3. Severe Psychological Trauma in very Young Children, March 23d 1993
+*4. Post Traumatic Stress Disorder: Child & Adult, September 27'h 1993
+5.
+Cost Effectiveness: Mental Health Services for Foster Children, September 28* 1993
+6.
+Preventive Child Psychiatry, Mc Auley St Mary's, October 16" 1993,
+New Theory of Post-Traumatic Stress Disorder, for Int. Association of Child and
+Adolescent Psychiatry, July 25"" 1994
+*8.
+Cornerstone Method Conference, Wells Fargo, January 30" 1996
+*9. Cornerstone Conference: Control - Mastery Group, San Francisco Psychoanalytic
+Institute. February 9'* 1996
+
+
+Casé 9:08-cv-80119-KAM
+Entered on FLSD Docket 06/08/2009 Page 23 of 23
+Francisco and Seattle, private therapeutic preschool in San Francisco, and Cornerstone
+Argentina
+24.
+Thirty four year follow-up of a Cornerstone Treated autistic child, now recovered.
+resented at The San Francisco Psychoanalytic Institute, Child Analysis Study Grou
+01. Permission for public viewing granted by the patient. Excerpts may be viewed c
+www.childrenspsychological.org or the entire video obtained from
+*25 Orientation of the Family Services Center of King County. Four days in December,
+2007, in Seattle. Six DVD's.
+Scientific and Educational Video Archives under Dr. Kliman's supervision:
+With parental permission, The Children's Psychological Health Center, under Dr. Kliman's
+leadership, is collecting unedited treatment documents of a special method of treatment in a real
+life space, called "The Cornerstone therapeutic preschool method." Now totaling over 200 video
+archive hours, eight different California therapists working with various educator teams have
+recorded their Cornerstone therapeutic preschool method work, Beginning in 1995, this archive
+started with Gilbert Kliman, M.D. working for a year as daily in-classroom therapist in a public
+special education school. He was assisted by Leanne Runyan and Gail Hernandez as the teachers
+at the San Mateo Early Childhood Education Center, a preschool special education facility of
+The County of San Mateo. A second team under his supervision included work at The San
+Francisco Unified School District (Vanessa Vigilante and Esther Kronenberg). Third and fourth
+teams were at The Salvation Army Gateway Shelter (Vanessa Vigilante as therapist and Lynda
+Byrd as teacher, Deanna Reardon as therapist and Lynda Byrd as teacher). A fourth was at The
+Cadence Cornerstone Site at Mt. Pleasant School, San Jose (Karita Hummer, therapist and Kathy
+Krall, teacher). Fifth team therapy was provided by Jane Christmas. The sixth team therapists
+was Dr. Miquela Diaz Hope, the seventh Molly Franklin, MFT. All have been extensively
+videotaped carrying out the method. An eighth team was assembled in late 2002, when Linda
+Hirshfeld Ph.D. joined as Fellow in Cornerstone Therapy. In 2001 Mike McDonald, Ed.D.
+became Special Education Director of Cornerstone School. All the treatments are have been
+under principal supervision of Dr. Kliman with additional supervision by Mali Mann, M.D.,
+Myrna Frankel, Ed.D., and Jan Bauerlen, M.D. Linda Hirshfeld, Ph.D. of the Ann Martin
+Center is conducting the archival work for her Cornerstone Services.
+A professional rescarcher/ training confidentiality agreement is required to study this archive.
+S: GK Private Forensic 7-13-041CVIPPA CVs\Gilbert Kliman CV ppa 06 02 0B.doc
+24
+
+
+06/05/2099 09:41 FAX
+RRA
+Rothstein Rosenfeldt Adler
+Attorneys at Law
+@001/011
+FACSIMILE COVER SHEET
+TO:
+FAX NUMBER:
+FROM:
+DATE:
+RE:
+MESSAGE:
+-
+, Esq.
+Bradley J. Edwards, Esq. and William J. Berger, Esq.
+June 4, 2009
+State of Florida v. Jeffrey Epstein
+Our File No. 09-22784
+as you probably know, the Palm Beach Post filed a
+separate Motion to unseal the NPA. We noticed that the Post
+did not notice you personally, so I have enclosed a courtesy
+copy of that Motion and Notice. I hope this finds you well.
+#OFPAGES L (including cover sheet)
+THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT
+IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL
+AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. IF THE READER OF THIS
+MESSAGE IS NOT THE INTENDED RECIPIENT, OR THE EMPLOYEE OR AGENT RESPONSIBLE
+FOR DELIVERING THE MESSAGE TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED
+THAT ANY DISSEMINATION, DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS
+STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE
+NOTIFY US IMMEDIATELY BY TELEPHONE AND RETURN THE ORIGINAL MESSAGE TO US AT
+THE ABOVE ADDRESS VIA THE U.S. POSTAL SERVICE. THANK YOU.
+Reply To: Las Olas City Centre • 401 East Las Olas Boulevard - Suite 1650 - Fort Lauderdale, Florida 33301 Telephone:
+FORT LAUDERDALE • BOCA RATON - TAMPA • TALLAHASSEE • NEW YORK CITY - LOS ANGELES
+www.rra-law.com
+• Fax:
+
+
+06/05/2009 09:41 FAX
+06-04-'09 15:18 FROM-THOMAS & LOCICERO
+
+&
+BRALOW
+Ø002/011
+T-997 P001/003 F-849
+To:
+From:
+Re:
+Co:
+400 N. Ashley DriveSuite 1100• Tampa, FL 33602
+(Phone)
+(Fax)
+Toll Free:
+facsimile transmittal
+R. Alexander Acosta, Esq.
+Judith Stevenson Arco, Esq.
+Michael McAuliffe, Esq.
+Jack Alan Goldberger, Esq.
+Bradley J. Edwards, Esq.
+William J. Berger, Esq.
+Deanna K. Shullman, Esq.
+State v. J. Epstein
+Marilyn Judicial Assistant to Judge
+Colbath
+Date:
+Pages: 6
+06/04/2009
+[Urgent •
+I For review L
+Please comment
+Please see attached Motion to Intervene and Petition for Access
+] Please reply O
+Please recycle ...
+CONFIDENTIALITY STATEMENT
+in enor, please notify as by telephone
+immediately. Thank you for your cooporation
+IRS Circuler 230 Disclosure. To the extent this correspondence contains federal tax advice, such advice was not intended to be used, and cannot
+be used by any taxpayer, for the purpose of (i avoiding penaitics under the Inemal Revenue Code or (i) promoting, marketing, or
+recommending to another party any transaction or matter addressed herein. If you would like us to prepare written tx edvice designed to provide
+penalty protection, please conccs us and we will be happy to discuss the matter with you in more detail
+
+
+
+06/05/2009 09:42 FAX
+06-04-' 09 15:19 FROM-THOMAS & LOCICEBO
+
+2003/011
+T-997 PØ02/003 F-849
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CRIMINAL DIVISION
+STATE OF FLORIDA
+JEFFREY EPSTE
+Case Nos.: 2006-CF9454-AXX &
+2008-9381CF-AXX
+NOTICE OF HEARING
+PLEASE TAKE NOTICE that Palm Beach Newspapers, Inc., d/b/a The Palm Beach Post
+will call up for hearing its Motion to Intervene and Petition for Access before the Honorable
+Jeffrey Colbath, Palm Beach County Courthouse, 205 N. Dixie Hwy., Room 11F, West Palm
+Beach on June 10, 2009 at 10:40 a.m. or as soon thereafter as counsel may be heard.
+Time reserved: 10 Minutes
+THOMAS, LOCICERO & BRALOW PL
+Jares B. Lake
+400 North Ashley Drive, Suite 1100
+P.O. Box 2602 (33601)
+Tampa, FL 33602
+Telephone:
+Facsimile
+Attomeys for The Palm Beach Post
+
+
+06/05/2009
+06-04-' 09 15:19 FROM-THOMAS & LOCICERO
+
+State v. Epstein
+Case No. 2006-CF9454 & 2008-9381CF
+Notice of Hearing on Palm Beach Post's Motion to Intervene
+@004/011
+T-997 P003/003 F-849
+WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
+via SU.S. Mail: &/Facsimile; Overnight Delivery to R. Alexander A costa, United States
+Attorney's Office - Southern District, 500 S. Australian Ave., Ste. 400, West Palm Beach, FL
+33401; Judith Stevenson Arco, Esq., State Attorney's Office - West Palm Beach, 401 North
+Dixie Highway, West Palm Beach, FL. 33401; William J. Berger, Esq., ROTHSTEIN
+ROSENFELDT ADLER, 401 East Las Olas Blvd., Ste. 1650, Fort Lauderdale, FL 33394;
+Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas Blvd., Ste.
+1650, Fort Lauderdale, FL 3394; Jack Alan Goldberger, Esq., Atterbury Goldberger, et al., 250
+S. Australian Ave., Ste. 1400, West Palm Beach, FL 33401 on this
+day of June,
+2009.
+B.
+tale
+Attorne
+cc:
+Judicial Assistant (Via Fax and U.S. Mail)
+Esquire Court Reporting
+2
+
+
+06/05/2009 09:42 FAX
+06-01-'09 15:35 FROM-THOMAS & LOCICERO
+
+400 N. Ashley Driveesuite 11000 Tampa. AL 33602
+813-984-3060 (Phone):
+Toll Free:
+facsimile transmittal
+To:
+From:
+Re:
+R. Alexander Acosta, Esq.
+Judith Stevenson Arco, Esq.
+Michael MeAnliffe, Esq.
+Jack Alan Goldberger, Esq.
+Bradley J. Edwards, Esq.
+William J. Berger, Esq.
+Deanna K. Shullman, Esq.
+State v. J. Epstein
+Date:
+Pages: 6
+06/01/2009
+@005/011
+T-989 P001/007 F-845
+[Urgent •
+| For review M. Please comment •
+Please see attached Motion to Intervene and Petition for Access
+_ Please reply O
+I Please recycle ..
+CONFIDENTIALITY STATEMENT
+immediately. Thank you for your cooperation
+IRS Circular 230 Disclosure. To the extent this correspondence contains federal tax advice, such advico was not intended to be uscd, and cannot
+tre used by any taxpayer, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (i) promoting, marketing, or
+recommending to another party any transaction or matter addressed herein. If you would like us to prepare written tax advice designed to provide
+penalty protection. please contact us and we will be happy to discuss the matter with you in more detail
+
+
+
+06/05/2009
+06-01- 09 15:35
+
+IHOMAS LOCICERO
+2006/011
+T-989 P002/007 F-845
+Tampa
+400 N. Ashley Dr., Ste. 1100, Tampa, FL. 39602
+P.O. Box 2602, Tampl 2 18912002
+ph. 819-984-3060 fa
+tall freeli
+Ft. Lauderdale
+101 N.E. Third Ave., Ste. 1500
+fax
+toll freak
+New York City
+220E. 42nd 94, 10th Floor
+fad
+www.uolawfitm.com
+Deanna K Shullman
+Direct Dial:
+Deanna.Shullman@tolawfirm.com
+Reply To Tampa
+June 1, 2009
+VIA FEDERAL EXPRESS OVERNIGHT MAIL
+The Honorable Jeffrey Colbath
+Fifteenth Judicial Circuit-Palm Beach
+Palm Beach County Courthouse
+Main Judicial Complex
+205 N. Dixie Highway, Room 11F
+West Palm Beach, FL 33401
+Re:
+Dear Judge Colbath:
+Enclosed is a courtesy copy of non-party Palm Beach Newspapers, Inc. d/b/a The Palm
+Beach Post's (the "Post"") Motion to Intervene and Petition for Access to certain court records in
+this case. It is our understanding that Bradley Edwards and William Berger of Rothstein
+Rosenfeldt Adier have filed a similar motion on behalf of a non-party known asl
+" and that
+• motion is set for hearing on June 10, 2009. The Post requests an opportunity to be heard
+on the issue of access to these records at that time.
+Thank you for your consideration in this matter. Please do not hesitate to contact me
+with any questions or comments.
+Sincerely,
+THOMAS, LOCICERO & BRALOW PL
+Deanna K. Shullman
+Deanna K. Shullman
+Cc:
+Counsel of Record
+
+
+
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CRIMINAL DIVISION
+@007/011
+T-989 P003/007 F-845
+STATE OF FLORIDA
+Case Nos: 2006-CF9454-AXX &
+2008-9381CF-AXX
+!
+PALM BEACH POST'S MOTION TO INTERVENE
+AND PETITION FOR ACCESS
+Palm Beach Newspapers, Inc., d/b/a The Palm Beach Post (the "Post") moves to
+intervene in this action for the limited purpose of seeking access to documents filed under seal.
+The documents relate directly to the Defendant's guilty plea and sentence. Thus, the sealed
+documents go to the heart of the disposition of this case. But in requesting that Judge Pucillo
+seal these documents, the parties failed to comply with Florida's strict procedural and substantive
+requirements for sealing judicial records. In addition, continued sealing of these documents is
+pointless, because these documents have been discussed repeatedly in open court records. For all
+of these reasons, the documents must be unsealed. As grounds for this Motion, the Post states:
+The Post is a daily newspaper that has covered this matter and related
+proceedings. In an effort to inform its readers concerning these matters, the Post relies upon
+(among other things) law enforcement records and judicial records.
+As a member of the news media, the Post has a right to intervene in criminal
+proceedings for the limited purpose of seeking access to proceedings and records. See Barron v.
+•Florida Ereedom Newspapers, Inc., 531 So. 2d 113, 118 (Fla. 1988) (news media have standing
+to challenge any closure order); Miami Herald Publ'g Co. v. Lewis, 426 So. 2d 1, 7 (Fla. 1982)
+(nows media must be given an opportunity to be heard on question of closure).
+
+
+06-01-' 09 15:36 FROM-THOMAS & LOCICERO
+
+01008/011
+T-989 P004/007 F-845
+The particular documents under seal in this case are a non-prosecution agreement
+that was docketed on July 2, 2008, and an addendum docketed on August 25, 2008. Together,
+these documents apparently restrict any federal prosecution of the Defendant for offenses related
+to the conduct to which he pleaded guilty in this case. Judge Pucillo accepted the agreement for
+filing during a bench conference on June 30, 2008. The agreement, Judge Pucillo found, was "a
+significant inducement in accepting this plea." Such agreements and related documents typically
+are public record. See Oregonian Publishing Co. v. United States District Court, 920 F.2d 1462,
+1465 (9th Cir. 1990) ("plea agreements have typically been open to the public"); United States v.
+Kooistra, 796 F.3d 1390, 1390-91 (1 1th Cir. 1986) (documents relating to defendant's change of
+plea and sentencing could be sealed only upon finding of a compelling interest that justified
+denial of public access).
+The Florida Constitution provides that judicial branch records generally must be
+open for public inspection. See Art. I, § 24(a), Fla. Const. Closure of such records is allowed
+only under narrow circumstances, such as to "prevent a serious and imminent threat to the fair,
+impartial and orderly administration of justice," or to protect a compelling governmental interest.
+See Fla. R. Jud. Admin. 2,420(c)(9)(A). Additionally, closure must be effective and no broader
+than necessary to accomplish the desired purpose, and is lawful only if no less restrictive
+measures will accomplish that purpose. See Fla. R. Jud. Admin. 2. 420(c)(9)(B) & (C); Lewis,
+426 So. 2d at 3.
+5.
+In this case, the non-prosecution agreement and, later, the addendum were sealed
+without any of the requisite findings. Rather, it appears from the record, the documents were
+sealed merely because the Defendant's counsel represented to Judge Pucillo that the nonprosecution agreement "is a confidential document." See Plea Conference Transcript page 38
+2
+
+
+06-01- 09 15:36
+
+2009/011
+T-989 P005/007 F-845
+1
+(June 30, 2008). Such a representation falls well short of demonstrating a compelling interest, a
+genuine necessity, narrow tailoring, and that no less restrictive measures will suffice.
+Consequently, the sealing was improper and ought to be set aside.
+6.
+In addition, at this time good cause exists for unsealing the documents because of
+their public significance. Since the Defendant pleaded guilty to soliciting a minor for
+prostitution, he has been named in at least 12 civil lawsuits that - like the charges in this case -
+allege he brought and paid teenage girls to come his home for sex and/or "massages." At least
+11 cases are pending. In another lawsuit, one of the Defendant's accusers has alleged that
+federal prosecutors failed to consult with her regarding the disposition of possible charges
+against the Defendant.? State prosecutors also have been criticized: The Palm Beach Police
+Chief has faulted the State Attorney's handing of these cases as "highly unusual" and called for
+the State Attorney's disqualification. Consequently, this case - and particularly the Defendant's
+agreements with prosecutors - are of considerable public interest and concern.
+7.
+The Defendant's non-prosecution agreement with federal prosecutors also was
+important to Judge Pucillo. As she noted in the June 2008 plea conference, "I would view [the
+non-prosecution agreement] as a significant inducement in accepting this plea." See Plen
+Conference Transcript page 39. Florida law recognizes a strong public right of access to
+documents a court considers in connection with sentencing. See Sarasota Herald Tribune, Div.
+' See, e.g. Doe v. Epstein, Case No. 08-80069 (S.D. Fla. 2008); Doe No, 2 v. Epstein,
+Case No. 08-80119 (S.D. Fla. 2008); Doe No. 3. v. Epstein, Case No. 08-80232 (S.D. Fla. 2008);
+Doe No. 4. v. Epstein, Case No. 08-80380 (S.D. Fla. 2008); Doe No. 5 v. Epstein, Case No. 08-
+80381 (S.D. Fla. 2008);
+• v. Epstein, Case No. 08-80811 (S.D. Fla. 2008); Doe v. Epstein,
+Case No. 08-80893 (S.D. Fla. 2008); Doe No. 7y. Epstein, Case No. 08-80993 (S.D. Fla. 2008);
+Doe No. 6 v. Epstein, Case No. 08-80994 (S.D. Fla. 2008); Doe II v. Epstein, Case No. 09-80469
+(S.D. Fla. 2009); Doe No. 101 v. Epstein, Case No. 09-80591 (S.D. Fla. 2009); Doe No. 102 v.
+Epstein, Case No. 09-80656 (S.D. Fla. 2009); Doe No. 8 v. Epstein, Case No. 09-80802 (S.D.
+Fla. 2009).
+' See In re: Jane Doe, Case No. 08-80736 (S.D. Fla. 2008).
+3
+
+
+08/05/2009 09:44 FAX
+06-01-'09 15:37 FROM-THOMAS & LOCICERO
+
+@010/011
+T-989 P006/007 F-845
+of the New York Times Co. v. Holtzendorl, 507 So. 2d 667, 668 (Fla. 2d DCA 1987) ("While a
+judge may impose whatever legal sentence he chooses, if such sentence is based on a tangible
+proceeding or document, it is within the public domain unless otherwise privileged."). In this
+case, no interest justifies continued sealing of these "significant" documents that Judge Pucillo
+considered in accepting the plea and sentencing the Defendant. The lack of any such
+compelling interest - as well as the parties' failure to comply with the standards for sealing
+documents initially - provide good cause for unsealing the documents at this time.
+8.
+Finally, continued closure of these documents is pointless, because many portions
+of the sealed documents already have been made public. For example, court papers quoting
+excerpts of the agreement have been made public in related federal proceedings? As the Florida
+Supreme Court has noted, "there would be little justification for closing a pretrial hearing in
+order to prevent only the disclosure of details which had already been publicized." Lewis, 426
+So. 2d at 8. Similarly, in this case, to the extent that information already has been made public,
+continued closure is pointless and, therefore, unconstitutional.
+9.
+The Post has no objection to the redaction of victims names (if any) that appear
+in the sealed documents. In addition, insofar as the Defendant or State Attorney seek continued
+closure, the Post requests that the Court inspect the documents in camera in order to assess
+whether, in fact, continued closure is proper.
+patein, See Ne posed is try pays, 208 ted patrol am 7,2009
+Motion for Stay, v
+4
+
+
+08/05/2009 09:44 FAX
+
+@ 011/011
+T-989 P007/007 F-845
+WHEREFORE, the Post respectfully requests that this Court unseal the non-prosecution
+agreement and addendum and grant the Post such other relief as the Court deems proper.
+Respectfully submitted,
+THOMAS, LOCICERO & BRALOW PL
+Racket toget for
+Jeanna K. Shullma
+Florida Bar No.:
+James B. Lake
+Florida Bar No.:
+101 N.E. Third Avenue, Suite 1500
+Fort Lauderdale, FL 33301
+Telephone:
+Facsimile:
+Attorneys for The Palm Beach Post
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
+via facsimile and U.S. Mail to: R. Alexander Acosta, United States Attorney's Office - Southem
+District, 500 S. Australian Ave., Ste. 400, West Palm Beach, FL 33401 (fax:
+Michael McAuliffe, Esq., and Judith Stevenson Arco, Esq. State Attomey's Office - West
+Palm Beach, 401 North Dixie Highway, West Palm Beach, FL 33401 (fax:
+0; Jack
+Alan Goldberger, Esq., Atterbury Goldberger, et al., 250 S. Australian Ave., Ste. 1400, West
+Palm Beach, FL 33401 (fax:
+); and Bradley J. Edwards, Esg. and William J.
+Berger, Esq., Rothstein Rosenfeldt Adler, 401 East Las Olas Blvd., Suite 1650, Fort Lauderdale,
+FL 33394 (fax:
+D on this Ist day of June, 2009.
+Recue agate
+5
+Fla Bar#t
+
+
+Case No:
+18 U.S.C. § 371
+18 U.S.C. § 1591(a)(1)
+18 U.S.C. § 1591(a)(2)
+18 U.S.C. § 2422(b)
+18 U.S.C. § 2423(e)
+18 U.S.C. § 2423(d)
+18 U.S.C. § 2423(b)
+UNITED STATES OF AMERICA
+and
+Defendants.
+INDICTMENT
+The Grand Jury charges that:
+BACKGROUND
+At all times relevant to this Indictment:
+1.
+Defendant JEFFREY EPSTEIN employed defendants
+, a/k/a *
+"and
+among other things, services as personal assistants.
+to perform,
+
+
+Defendants JEFFREY EPSTEIN and
+paid
+.,H.R., and
+A.F. to perform, among other things, recruiting services.
+Defendant JEFFREY EPSTEIN owned a property located at 358 El Brillo Way,
+Palm Beach, Florida, in the Southern District of Florida (hereinafter referred to as "358 El
+Brillo Way").
+4.
+Defendant JEFFREY EPSTEIN was the principal owner of JEGE, INC., a
+Delaware corporation. JEGE, INC.'s sole business activities related to the operation and
+ownership of a Boeing 727-31 aircraft bearing tail number N908JE.
+5.
+Defendant JEFFREY EPSTEIN served as president, sole director, and sole
+shareholder of JEGE, INC., and had the power to direct all of its operations.
+Defendant JEFFREY EPSTEIN was the principal owner of Hyperion Air, Inc.,
+a Delaware corporation. Hyperion Air, Inc.'s sole business activities related to the operation
+and ownership of a Gulfstream G-1159B aircraft bearing tail number N909JE.
+7.
+Defendant JEFFREY EPSTEIN served as president, sole director, and sole
+shareholder of Hyperion Air, Inc., and had the power to direct all of its operations.
+Pursuant to Florida Statutes Section 794.05, a "person 24 years of age or older
+who engages in sexual activity with a person 16 or 17 years of age commits a felony of the
+second degree." For purposes of "this section, 'sexual activity' means oral, anal, or vaginal
+penetration by, or union with, the sexual organ of another; however, sexual activity does not
+include an act done for a bona fide medical purpose." Florida Statutes Section 794.021 states
+2
+
+
+that "ignorance of the age [of the victim] is no defense," and that neither "misrepresentation
+of age by [the victim] nor a bona fide belief that such person is over the specified age [shall]
+be a defense."
+Pursuant to Florida Statutes Sections 800.04(5)(a) and 800.04(5)(c)(2), an adult
+"who intentionally touches in a lewd or lascivious manner the breasts, genitals, genital area,
+or buttocks, or the clothing covering them, of a person less than 16 years of age, or forces or
+entices a person under 16 years of age to so touch the perpetrator, commits lewd or lascivious
+molestation," which is a felony of the second degree if the victim is 12 years of age or older
+but less than 16 years of age.
+10.
+Pursuant to Florida Statutes Sections 800.04(6)(a) and 800.04(6)(b), an adult
+*who [i]ntentionally touches a person under 16 years of age in a lewd or lascivious manner
+or [s]olicits a person under 16 years of age to commit a lewd or lascivious act commits lewd
+or lascivious conduct," which is a felony of the second degree.
+11. Pursuant to Florida Statutes Sections 800.04(7)(a) and 800.04(7)(c), an adult
+"who: (1) [i]ntentionally masturbates; (2) [i]ntentionally exposes the genitals in a lewd or
+lascivious manner; or (3) [i]ntentionally commits any other sexual act that does not involve
+actual physical or sexual contact with the victim, including, but not limited to ... the
+simulation of any act involving sexual activity in the presence of a victim who is less than
+3
+
+
+16 years of age, commits lewd or lascivious exhibition," which is a felony of the second
+degree.
+12.
+Pursuant to Florida Statutes Section 800.04(2), "InJeither the victim's lack of
+chastity nor the victim's consent is a defense to the crimes proscribed by [Section 800.04]."
+13.
+Pursuant to Florida Statutes Section 800.04(3), "[t]he perpetrator's ignorance
+of the victim's age, the victim's misrepresentation of his or her age, or the perpetrator's bona
+fide belief of the victim's age cannot be raised as a defense in a prosecution under [Section
+800.04]."
+14. Pursuant to Florida Statutes Section 800.02, a "person who commits any
+unnatural and lascivious act with another person commits a misdemeanor of the second
+degree."
+15.
+Defendant JEFFREY EPSTEIN was over the age of 24 and did not have any
+medical license.
+16. During the period of her involvement with the Defendants, Jane Doe #4
+attended Wellington High School and
+in Palm Beach
+County.
+17.
+During the period of her involvement with the Defendants, Jane Doe #5
+attended Wellington High School in Palm Beach County.
+4
+
+
+18.
+During the period of their involvement with the Defendants, Jane Does # 6, 8,
+and 12 attended
+in Palm Beach County.
+19.
+During the period of her involvement with the Defendants, Jane Doe #7
+attended
+in Palm Beach County.
+20.
+During the periods of their involvement with the Defendants, Jane Does # 9,
+14, 15, 16, 17, 18, and 19 attended
+in Palm Beach County.
+21.
+During the period of her involvement with the Defendants, Jane Doe #10
+attended
+attended
+in Palm Beach County.
+22. During the period of her involvement with the Defendants, Jane Doe #11
+in Palm Beach County.
+23.
+During the period of her involvement with the Defendants, Jane Doe #13
+attended
+in Palm Beach County.
+COUNT 1
+(Conspiracy: 18 U.S.C. § 371)
+24. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
+25.
+From at least as early as 2001, the exact date being unknown to the Grand Jury,
+through in or around October 2005, in Palm Beach County, in the Southern District of
+Florida, and elsewhere, the Defendants,
+5
+
+
+EFFREY EPSTEIN,
+did knowingly and willfully combine, conspire, confederate, and agree with each other and
+with others known and unknown to commit an offense against the United States, that is, to
+use a facility or means of interstate or foreign commerce to knowingly persuade, induce, and
+entice individuals who had not attained the age of 18 years to engage in prostitution, in
+violation of Title 18, United States Code, Section 2422(b).
+Purpose and Object of the Conspiracy
+26.
+It was the purpose and object of the conspiracy to procure females under the
+age of 18 to travel to 358 El Brillo Way so that JEFFREY EPSTEIN could, in exchange for
+money, engage in lewd conduct with those minor females in order to satisfy JEFFREY
+EPSTEIN's prurient interests.
+Manner and Means
+27. The manner and means by which the Defendants and other participants sought
+to accomplish the purpose and object of the conspiracy included the following:
+(a)
+It was part of the conspiracy that Defendants
+a/k/a
+and other
+participants would contact minor females via the use of cellular and other telephones to
+6
+
+
+arrange appointments for minor females to travel to 358 El Brillo Way to allow Defendant
+JEFFREY EPSTEIN to engage in lewd conduct with them.
+(b)
+It was further a part of the conspiracy that Defendants JEFFREY
+EPSTEIN,
+a/k/a "1
+, and other participants would make payments to, or cause payments to be
+made to, minor females in exchange for engaging in lewd conduct.
+(c)
+It was further a part of the conspiracy that Defendants JEFFREY
+EPSTEIN,
+a/k/a"
+" and other
+participants would ask females to recruit other minor females to engage in lewd conduct with
+Defendant JEFFREY EPSTEIN.
+(d) It was further a part of the conspiracy that Defendants JEFFREY
+EPSTEIN,
+a/k/a"
+" and other
+participants would make payments to, or cause payments to be made to, the recruiters for
+bringing additional minor females to 358 El Brillo Way to engage in lewd conduct with
+Defendant JEFFREY EPSTEIN.
+(e) It was further a part of the conspiracy that Defendant JEFFREY
+EPSTEIN would pay minor females to engage in lewd conduct with Defendant
+to satisfy Defendant JEFFREY EPSTEIN's prurient interests.
+
+
+Overt Acts
+28.
+In furtherance of this conspiracy and to effect the objects thereof, there was
+committed, by at least one of the co-conspirators herein, at least one of the following overt
+acts, among others, in the Southern District of Florida, and elsewhere:
+Jane Does #1 and #2
+(1)
+In or around the beginning of 2001, Defendant JEFFREY EPSTEIN
+engaged in sexual activity with Jane Doe #1, who was then a seventeen-year-old girl,
+in the presence of Jane Doe #2, who was then a fourteen-year-old girl.
+(2) In oraround 2001, Defendant
+led Jane Doe #2 from the
+kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358
+El Brillo Way.
+(3)
+In or around 2001, Defendant JEFFREY EPSTEIN masturbated in the
+presence of Jane Doe #2, who was then a fourteen-year-old girl.
+(4)
+In or around 2001, Defendant JEFFREY EPSTEIN asked Jane Doe #2,
+who was then a fourteen-years-old girl, to pinch his nipples while he masturbated.
+(5)
+In or around 2001, Defendant JEFFREY EPSTEIN made a payment of
+$300 to Jane Doe #2.
+(6)
+In or around 2001, Defendant
+placed a telephone call
+to a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel
+to 358 El Brillo Way.
+8
+
+
+(7)
+In or around 2001, JEFFREY EPSTEIN engaged in sexual intercourse
+with an unidentified female in the presence of Jane Doe #2, who was then a fourteenyear-old girl.
+(8) In or around 2001, Defendant JEFFREY EPSTEIN paid $300 to Jane
+Doe #2, who was then a fourteen-year-old girl, for allowing an unidentified female
+to perform oral sex on Jane Doe #2 in EPSTEIN's presence.
+(9)
+On or about March 11, 2003, Defendant JEFFREY EPSTEIN reviewed
+a written telephone message prepared by one of his employees regarding a telephone
+call received from Jane Doe #2.
+(10) In or around 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #2
+if she had any younger friends who would be interested in engaging in similar sexual
+activities with him.
+(11) Inoraround 2003, Defendant
+took nude photographs
+of Jane Doe #2, who was then a sixteen-year-old girl.
+(12) In or around 2003, Defendant
+made a payment of
+$500 to Jane Doe #2 in exchange for posing for nude photographs.
+(13) In or around 2003, Defendant
+told Jane Doe #2 that
+Defendant JEFFREY EPSTEIN had asked
+to take nude photographs of Jane
+Doe #2.
+9
+
+
+(14) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the
+presence of Jane Doe #2, who was then a sixteen-year-old girl.
+(15)
+In or around 2003, Defendant JEFFREY EPSTEIN made a payment of
+$200 to Jane Doe #2, who was then a sixteen-year-old girl.
+(16) In oraround 2003, Defendant
+placed a telephone call
+to a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel
+to 358 El Brillo Way.
+(17) On or about April 23, 2004, Defendant
+telephone call to a telephone used by Jane Doe #2.
+(18) On or about May 2, 2004, Defendant
+telephone call to a telephone used by Jane Doe #2.
+Jane Doe #3
+(19) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the
+presence of Jane Doe #3, who was then a fifteen-year-old girl.
+(20) In or around 2003, Defendant JEFFREY EPSTEIN made a payment of
+$200 to Jane Doe #3.
+(21)
+On or about October 26, 2004, Defendant
+telephone call to a telephone used by Jane Doe #3.
+10
+
+
+(22) On or about October 30, 2004, Defendant
+telephone call to a telephone used by Jane Doe #3.
+(23)
+In or around 2004, Defendant JEFFREY EPSTEIN directed Jane Doe
+#3, who was then a sixteen- or seventeen-year-old girl, to straddle an adult female and
+to touch the adult female's breasts.
+(24)
+In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging
+device on the vagina of an adult female in the presence of Jane Doe #3, who was then
+a sixteen- or seventeen-year-old girl.
+(25) In or around 2004, Defendant JEFFREY EPSTEIN made a payment of
+$200 to Jane Doe #3.
+(26) In oraround 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe
+#3 to rub his nipples.
+(27) In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging
+device on the vagina of Jane Doe #3, who was then a sixteen- or seventeen-year-old
+girl.
+(28)
+In or around 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #3
+to recruit additional females to come to 358 El Brillo Way.
+11
+
+
+(29) On or about November 8, 2004, Defendant JEFFREY EPSTEIN
+reviewed a written telephone message prepared by one of his employees regarding a
+telephone call received from Jane Doe #3 that read: "I have a female for him."
+(30) On or about January 14, 2005, Defendant
+telephone call to a telephone used by Jane Doe #3.
+(31)
+On or about January 29, 2005, Defendant JEFFREY EPSTEIN reviewed
+a written telephone message prepared by one of his employees regarding a telephone
+call received from Jane Doe #3 that read: "I have a female for him."
+Jane Does #4, #5, and #6
+(32) In or around the first half of 2004, Defendant
+led
+Jane Doe #4 and Jane Doe #5 to Defendant JEFFREY EPSTEIN's bedroom at 358 EI
+Brillo Way.
+(33) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+learned that Jane Doe #4 was seventeen years old when he asked Jane Doe #4 about
+her age, and Jane Doe #4 responded with her true age.
+(34) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+masturbated in the presence of Jane Doe #4, who was then a seventeen-year-old-girl,
+and Jane Doe #5, who was then a seventeen-year-old girl.
+12
+
+
+(35) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+instructed Jane Doe #4, who was then a seventeen-year-old girl, to play with his
+nipples.
+(36) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+instructed Jane Doe #4, who was then a seventeen-year-old girl, to remove her
+clothing.
+(37) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+stroked the vagina of Jane Doe #4, who was then a seventeen-year-old girl.
+(38) In oraround the first half of 2004, Defendant JEFFREY EPSTEIN paid
+$200 to Jane Doe #4.
+(39) In or around the first half of 2004, Defendant JEFFREY EPSTEIN paid
+$200 to Jane Doe #5.
+(40) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+asked Jane Doe #6 what high school she attended.
+(41) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+instructed Jane Doe #4 to leave so that Jane Doe #6 could massage him alone.
+(42)
+In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+masturbated in the presence of Jane Doe #6, who was then a sixteen-year-old girl.
+13
+
+
+(43) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+digitally penetrated Jane Doe #6, who was then a sixteen-year-old girl.
+(44)
+In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+placed a large vibrating massager on the vagina of Jane Doe #6, who was then a
+sixteen-year-old girl.
+(45) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+caused a payment of $200 to be made to Jane Doe #6.
+Jane Does #7 and #8
+(46) In or around July 2004, Defendant JEFFREY EPSTEIN led
+., who
+was then a fifteen-year-old girl, and Jane Doe #7, who was then a sixteen-year-old
+girl, from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY
+EPSTEIN's bedroom.
+(47) On or about July 4, 2004, Defendant
+telephone call to a telephone used by Jane Doe #7.
+(48)
+On or about July 5, 2004, Defendant
+telephone call to a telephone used by
+(49)
+In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in
+the presence of Jane Doe #8, who was then a seventeen-year-old girl.
+
+
+(50) In or around July 2004, Defendant JEFFREY EPSTEIN stroked the
+vagina of Jane Doe #8, who was then a seventeen-year-old girl.
+(51) In
+or around July 2004, Defendant JEFFREY EPSTEIN paid
+approximately $200 to Jane Doe #8.
+(52)
+In or around July 2004, Defendant JEFFREY EPSTEIN paid $200 to
+for recruiting Jane Doe #8 to travel to 358 El Brillo Way.
+(53)
+In or around July 2004, Defendant
+told Jane Doe #8
+that Defendant JEFFREY EPSTEIN would pay Jane Doe #8 if she returned with a
+friend
+(54) On or about July 15, 2004, Defendant
+telephone call to a telephone used by Jane Doe #7.
+(55) On or about July 15, 2004, Defendant
+telephone call to a telephone used by Jane Doe #8.
+(56)
+On or about July 15, 2004, Defendant
+telephone call to a telephone used by
+(57) On or about July 16, 2004, Defendant
+more telephone calls to a telephone used by Jane Doe #7.
+(58)
+On or about July 16, 2004, Defendant
+telephone call to a telephone used by
+placed one or
+15
+
+
+(59)
+On or about July 17, 2004, Defendant JEFFREY EPSTEIN reviewed
+a written telephone message prepared by one of his employees regarding a telephone
+call received from
+that read: "Me & [Jane Doe #7] can come tomorrow any time
+or l
+] alone"
+(60)
+In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in
+the presence of Jane Doe #7, who was then a sixteen-year-old girl.
+(61)
+In or around July 2004, Defendant JEFFREY EPSTEIN instructed Jane
+Doe #7, who was then a sixteen-year-old girl, to rub his nipples.
+(62) In or around July 2004, Defendant JEFFREY EPSTEIN stroked the
+vagina of Jane Doe #7, who was then a sixteen-year-old girl.
+(63) In or around July 2004, Defendant JEFFREY EPSTEIN made a
+payment of $200 to Jane Doe #7.
+(64) In or around July 2004, Defendant JEFFREY EPSTEIN told Jane Doe
+#7 that if she reported to anyone what had occurred at Defendant JEFFREY
+EPSTEIN's home, bad things could happen to her.
+(65)
+On or about July 24, 2004, Defendant
+telephone call to a telephone used by Jane Doe #8.
+Jane Does #9 and #10
+(66)
+On or about July 15, 2004, Defendant
+telephone call to a telephone used by Jane Doe #9.
+16
+
+
+(67) On or about July 16, 2004, Defendant
+caused Jane
+Doe #9 to make a telephone call to a telephone used by Jane Doe #10.
+(68)
+On or about July 17, 2004, Defendant
+telephone call to a telephone used by Jane Doe #9.
+(69) On or about July 18, 2004, Defendant
+telephone call to a telephone used by Jane Doe #9.
+(70)
+On or about July 22, 2004, Defendant
+telephone call to a telephone used by Jane Doe #9.
+(71) In or around July 2004, Defendant JEFFREY EPSTEIN fondled the
+breasts of Jane Doe #9, who was then a seventeen-year-old girl.
+(72) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in
+the presence of Jane Doe #9, who was then a seventeen-year-old girl.
+(73) In or around July 2004, Defendant JEFFREY EPSTEIN made a
+payment of $200 to Jane Doe #9.
+(74)
+On or about July 22, 2004, Defendant
+telephone call to a telephone used by Jane Doe #10.
+(75) In or around the last half of 2004, Defendants JEFFREY EPSTEIN and
+engaged in oral sex and sexual intercourse in the presence
+of Jane Doe #9, who was then a seventeen-year-old girl.
+17
+
+
+(76) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
+forcibly inserted his penis into the vagina of Jane Doe #9, who was then a seventeenyear-old girl.
+(77)|
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN made
+a payment of $300 to Jane Doe #9.
+(78) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
+rubbed the vagina of Jane Doe #10, who was then a seventeen-year-old girl.
+(79) In oraround the last half of 2004, Defendant JEFFREY EPSTEIN made
+a payment of $200 to Jane Doe #10.
+(80) On or about November 28, 2004, Defendant JEFFREY EPSTEIN
+arranged for one of his employees to provide an envelope filled with cash to Jane Doe
+#9.
+(81) On orabout December 4, 2004, Defendant
+provided
+a written message to Defendant JEFFREY EPSTEIN regarding Jane Does #9 and 10,
+stating: "[Jane Doe #10] would like to work @ 4:00 pm if possible. [[Jane Doe #9]
+is scheduled for 5:00 today.] the movie is @ 7:30".
+(82) On or about December 29, 2004, Defendant
+a telephone call to a telephone used by Jane Doe #9.
+(83)
+On or about December 30, 2004, Defendants JEFFREY EPSTEIN and
+caused the purchase of Broadway tickets as an eighteenth birthday
+gift for Jane Doe #9.
+18
+
+
+(84) In oraround the last half of 2004 or January 2005, Defendant JEFFREY
+EPSTEIN masturbated in the presence of Jane Doe #10, who was then a seventeenyear-old girl.
+(85) In oraround the last half of 2004 or January 2005, Defendant JEFFREY
+EPSTEIN fondled the breasts of Jane Doe #10, who was then a seventeen-year-old
+girl.
+(86) On orabout January 14,2005, Defendant
+or more telephone calls to a telephone used by Jane Doe #10.
+placed one
+(87) On or about January 27, 2005, Defendant
+, a/k/a
+'" placed one or more telephone calls to a telephone used by Jane
+Doe #10.
+(88)
+On or about January 28, 2005, Defendant
+placed one
+or more telephone calls to a telephone used by Jane Doe #10.
+(89) On or about February 1, 2005, Defendant
+placed one or more telephone calls to a telephone used by Jane Doe #10.
+(90) In or around February 2005, Defendant JEFFREY EPSTEIN caused a
+payment of $200 to be made to Jane Doe #9 for recruiting Jane Doe #16 to travel to
+358 El Brillo Way.
+19
+
+
+Jane Doe #11
+(91) In or around the summer of 2004, Defendant
+led
+Jane Doe #11 and
+from the kitchen of 358 El Brillo Way upstairs to Defendant
+JEFFREY EPSTEIN's master bedroom suite.
+$200 to
+(92) In or around the summer of 2004, Defendant JEFFREY EPSTEIN paid
+for bringing Jane Doe #11 to 358 El Brillo Way.
+(93) In or around the summer of 2004, Defendant JEFFREY EPSTEIN
+masturbated in the presence of Jane Doe #11, who was then a fifteen- or sixteen-yearold girl.
+(94) In or around the summer of 2004, Defendant JEFFREY EPSTEIN
+instructed Jane Doe #11 to rub his chest and pinch his nipples while he masturbated.
+(95) In or around the summer of 2004, Defendant JEFFREY EPSTEIN
+instructed Jane Doe #11 to write her telephone number on a notepad in his master
+bedroom suite.
+(96) In or around the summer of 2004, Defendant JEFFREY EPSTEIN
+learned Jane Doe #11's true age when he asked Jane Doe #11 how old she was and
+she responded truthfully.
+(97)
+In or around the summer of 2004, Defendant JEFFREY EPSTEIN told
+Jane Doe #11 that he did not care how old she was and that he did not like girls older
+than eighteen.
+20
+
+
+(98) In or around the second half of 2004, Defendant JEFFREY EPSTEIN
+placed a vibrating massager on the vagina of Jane Doe #11, who was then a sixteenyear-old girl.
+(99)
+In or around the second half of 2004, Defendant JEFFREY EPSTEIN
+digitally penetrated the vagina of Jane Doe #11, who was then a sixteen-year-old girl.
+(100) On or about August 6, 2004, Defendant
+telephone call to a telephone used by Jane Doe #11.
+(101) On or about August 18, 2004, Defendant
+telephone call to a telephone used by Jane Doe #11.
+(102) On or about October 29, 2004, Defendant
+telephone call to a telephone used by Jane Doe #11.
+(103) On or about November 5, 2004, Defendant
+a telephone call to a telephone used by Jane Doe #11.
+(104) On or about February 14, 2005, Defendant JEFFREY EPSTEIN
+reviewed a written telephone message prepared by one of his employees regarding a
+telephone call received from Jane Doe #11 that read: "Please! Call her back".
+(105) On or about February 14, 2005, Defendant
+a telephone call to a telephone used by Jane Doe #11.
+(106) On or about February 21, 2005, Defendant
+a telephone call to a telephone used by Jane Doe #11.
+21
+
+
+(107) On or about March 29, 2005, Defendant
+telephone call to a telephone used by Jane Doe #11.
+(108) In or around the second half of 2005 or the first quarter of 2006,
+Defendant JEFFREY EPSTEIN offered to pay $400 to Jane Doe #11, who was then
+a sixteen-year-old girl, if she would engage in oral sex, or $500 or more if she would
+engage in sexual intercourse.
+(109) In or around the second half of 2005, Defendant JEFFREY EPSTEIN
+offered to pay $100 to Jane Doe #11 if she would bring other girls to 358 El Brillo
+Way.
+Jane Does #12 and #13
+(110) On or about August 2, 2004, Defendant JEFFREY EPSTEIN reviewed
+a written telephone message prepared by one of his employees regarding a telephone
+call received from
+and Jane Doe #12 that stated: "They are available all
+weekend and maybe [Jane Doe #13] too".
+(111) On or about August 21, 2004, Defendant |
+telephone call to a telephone used by Jane Doe #13.
+(112)
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN
+masturbated in the presence of Jane Doe #12, who was then a seventeen-year-old girl.
+(113) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
+digitally penetrated Jane Doe #12, who was then a seventeen-year-old girl.
+22
+
+
+(114) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
+attempted to place a massaging device on the vagina of Jane Doe #12, who was then
+a seventeen-year-old girl.
+(115) In oraround the last half of 2004, Defendant JEFFREY EPSTEIN made
+a payment of $200 to Jane Doe #12.
+(116) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked
+Jane Doe #12, who was then a seventeen-year-old girl, about her age.
+(117) In or around the last half of 2004, Defendant JEFFREY EPSTEIN told
+Jane Doe #12 that he would take her to Los Angeles when she turned eighteen.
+(118) In or around the last half of 2004, Defendants JEFFREY EPSTEIN and
+caused Jane Doe #12 to recruit Jane Doe #13 to travel to 358 El
+Brillo Way.
+(119) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
+masturbated in the presence of Jane Doe #13, who was then a seventeen-year-old girl.
+(120) In or around the end of 2004, Defendant JEFFREY EPSTEIN placed
+a massaging device on the vagina of Jane Doe #13, who was then a seventeen-yearold girl.
+(121) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made
+a payment of $200 to Jane Doe #13.
+(122) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
+digitally penetrated Jane Doe #13, who was then a seventeen-year-old girl.
+23
+
+
+(123) In oraround the last half of 2004, Defendant JEFFREY EPSTEIN asked
+Jane Doe #13, who was then a seventeen-year-old girl, about her age.
+(124) In or around the last half of 2004, Defendant JEFFREY EPSTEIN told
+Jane Doe #13 that he wanted to take her to Paris but he could not because Jane Doe
+#13 was not yet eighteen years old.
+(125) In oraround the last half of 2004, Defendant JEFFREY EPSTEIN asked
+Jane Doe #13 to bring her friends to his home, especially "girls who looked like [Jane
+Doe #13]."
+Jane Doe #14
+(126) In or around the last half of 2004, Defendant
+led
+Jane Doe #14 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY
+EPSTEIN's bedroom at 358 El Brillo Way.
+(127) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked
+Jane Doe #14 to provide her telephone number.
+(128) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
+instructed Jane Doe #14, who was then a seventeen-year-old girl, to pinch his nipples.
+(129) In
+or around the last half of 2004, Defendant JEFFREY EPSTEIN
+masturbated in the presence of Jane Doe #14, who was then a seventeen-year old girl.
+(130) In oraround the last half of 2004, Defendant JEFFREY EPSTEIN made
+a payment of $300 to Jane Doe #14.
+
+
+(131) In or around the end of 2004 and the beginning of 2005, Defendant
+JEFFREY EPSTEIN digitally penetrated Jane Doe #14, who was then a seventeenyear-old girl.
+(132) In or around the end of 2004 and the beginning of 2005, Defendant
+JEFFREY EPSTEIN asked Jane Doe #14, who was then a seventeen-year-old girl,
+whether she had any plans for her eighteenth birthday and acknowledged that she had
+not yet turned eighteen.
+(133) On or about December 23, 2004, Defendant JEFFREY EPSTEIN
+caused a Western Union wire transfer order to be sent to Jane Doe #14.
+(134) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+placed a massaging device on the vagina of Jane Doe #14, who was then a seventeenyear-old girl.
+(135) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+engaged in sexual intercourse with Jane Doe #14, who was then a seventeen-year-old
+girl.
+(136) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+performed oral sex on Jane Doe #14, who was then a seventeen-year-old girl.
+(137) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+made a payment of $600 to Jane Doe #14.
+(138) On or about January 8, 2005, Defendant
+telephone call to a telephone used by Jane Doe #14.
+25
+
+
+(139) On or about January 9, 2005, Defendant
+a/k/a
+'" placed a telephone call to a telephone used by Jane Doe #14.
+(140) On or about January 26, 2005, Defendant
+a/k/a
+" reviewed a written telephone message prepared by one of
+Defendant JEFFREY EPSTEIN's employees regarding a call received from Jane Doe
+#14 that read: "She is confirming for 5:30".
+(141) On or about January 26, 2005, Defendant
+a/k/a
+" placed a telephone call to a telephone used by Jane Doe #14.
+(142) On or about February 1, 2005, Defendant
+telephone call to a telephone used by Jane Doe #14.
+(143) On or about March 1, 2005, Defendant
+a/k/a
+'" placed a telephone call to a telephone used by Jane Doe #14.
+(144) On or about March 21, 2005, Defendant
+a/k/a
+'" placed a telephone call to a telephone used by Jane Doe #14.
+(145) On or about March 29, 2005, Defendant
+telephone call to a telephone used by Jane Doe #14.
+Jane Doe #15
+(146)
+On or about December 6, 2004, Defendant
+a telephone call to a telephone used by Jane Doe #15.
+(147)
+On or about December 14, 2004, Defendant
+a telephone call to a telephone used by Jane Doe #15.
+26
+
+
+(148) In or around the first half of 2005, Defendant
+led
+Jane Doe #15 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY
+EPSTEIN's bedroom at 358 El Brillo Way.
+(149) In or around the first half of 2005, Defendant JEFFREY EPSTEIN
+instructed Jane Doe #15, who was then a seventeen-year-old girl, to pinch his nipples
+while he masturbated.
+(150) In or around the first half of 2005, Defendant JEFFREY EPSTEIN
+fondled the breasts of Jane Doe #15.
+(151) In or around the first half of 2005, Defendant JEFFREY EPSTEIN
+made a payment of $200 to Jane Doe #15.
+(152) On or about January 7, 2005, Defendant
+a/k/a
+placed a telephone call to a telephone used by Jane Doe #15.
+(153) On or about February 4, 2005, Defendant
+telephone call to a telephone used by Jane Doe #15.
+(154) On or about February 10, 2005, Defendant
+a telephone call to a telephone used by Jane Doe #15.
+(155)
+On or about February 21, 2005, Defendant
+a telephone call to a telephone used by Jane Doe #15.
+(156)
+On or about February 24, 2005, Defendant
+a telephone call to a telephone used by Jane Doe #15.
+27
+
+
+(157) On or about March 17, 2005, Defendant |
+telephone call to a telephone used by Jane Doe #15.
+(158) On or about March 30, 2005, Defendant
+telephone call to a telephone used by Jane Doe #15.
+(159) On or about March 31, 2005, Defendant
+telephone call to a telephone used by Jane Doe #15.
+(160) On or about March 31, 2005, Defendant |
+a/k/a
+" placed a telephone call to a telephone used by Jane Doe #15.
+(161) On or about April 1, 2005, Defendant JEFFREY EPSTEIN reviewed
+a note prepared by one of his employees that read: "10:30 [Jane Doe #15]/[Jane Doe
+#10] on Fri around 2'Oclock".
+(162) In or around June 2005, Defendant JEFFREY EPSTEIN provided Jane
+Doe #15 with a gift of Victoria's Secret lingerie for her eighteenth birthday.
+Jane Does #16 & #17
+(163) In or around February 2005, Defendant JEFFREY EPSTEIN
+masturbated in the presence of Jane Doe #16, who was then a seventeen-year-old girl.
+(164) In or around the first quarter of 2005, Defendants JEFFREY EPSTEIN
+and
+caused Jane Doe #16 to place a telephone call to Jane Doe #17
+to ask her to travel to 358 El Brillo Way.
+28
+
+
+(165) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+caused a payment to be made to Jane Doe #16 for recruiting Jane Doe #17 to travel
+to 358 El Brillo Way.
+(166) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+masturbated in the presence of Jane Doe #17, who was then a sixteen-year-old girl.
+(167) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+instructed Jane Doe #17, who was then a sixteen-year-old girl, to remove all of her
+clothing.
+(168) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+placed a massaging device on the vagina of Jane Doe #17, who was then a sixteenyear-old girl.
+(169) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+made a payment of $200 to Jane Doe #17, who was then a sixteen-year-old girl.
+(170) In or around the first nine months of 2005, Defendant JEFFREY
+EPSTEIN placed a massaging device on the vagina of Jane Doe #16, who was then
+a seventeen-year-old girl.
+(171) In or around the first nine months of 2005, Defendant JEFFREY
+EPSTEIN asked Jane Doe #16, who was then a seventeen-year-old girl, how old she
+was, and she responded that she was seventeen years old.
+29
+
+
+(172) In or around the first nine months of 2005, Defendant JEFFREY
+EPSTEIN engaged in sexual activity with Defendant
+in the
+presence of Jane Doe #16, who was then a seventeen-year-old girl.
+(173) In or around the first nine months of 2005, Defendant JEFFREY
+EPSTEIN asked Jane Doe #16, who was then a seventeen-year-old girl, to touch the
+breast of Defendant
+(174) On or about April 11, 2005, Defendant
+a/k/a
+'" placed a telephone call to a telephone used by Jane Doe #16.
+(175) On or about April 11, 2005, Defendant
+(176) On or about April 11, 2005, Defendant
+left a
+message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #16] can work
+tomorrow at 4pm."
+(177) On or about May 19, 2005, Defendant
+(178) On or about June 30, 2005, Defendant
+(179) On or about July 2, 2005, Defendant
+(180) On or about July 22, 2005, Defendant
+30
+
+
+(181) On or about August 18, 2005, Defendant
+(182) On or about August 19, 2005, Defendant
+a/k/a
+" placed a telephone call to a telephone used by Jane Doe #16.
+(183) On or about August 21, 2005, Defendant
+placed a telephone call to a telephone used by Jane Doe #16.
+(184) On or about September 3, 2005, Defendant
+a/k/a
+" placed a telephone call to a telephone used by Jane Doe #16.
+(185) On or about September 18, 2005, Defendant
+a telephone call to a telephone used by Jane Doe #16.
+(186) On or about September 19, 2005, Defendant
+sent a
+text message to a telephone used by Jane Doe #16.
+(187) On or about September 29, 2005, Defendant
+a telephone call to a telephone used by Jane Doe #16.
+(188) On or about September 30, 2005, Defendant |
+a/k/a
+" placed a telephone call to a telephone used by Jane Doe #16.
+(189) On or about October 1, 2005, Defendant
+left a
+telephone message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #15]
+confirmed at 11 AM and [Jane Doe #16] - 4PM".
+(190) On or about October 2, 2005, Defendant
+31
+
+
+(191) On or about October 3, 2005, Defendant
+(192) On or about October 3, 2005, Defendant
+left a
+telephone message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #16] will
+be ½ hour late".
+(193) In or around the first week of October, 2005, Defendant JEFFREY
+EPSTEIN engaged in sexual intercourse with Jane Doe #16, who was then a
+seventeen-year-old girl.
+(194) In or around the first week of October, 2005, Defendant JEFFREY
+EPSTEIN made a payment of $350.00 to Jane Doe #16, who was then a seventeenyear-old girl.
+(195) In or around the first week of October, 2005, Defendant JEFFREY
+EPSTEIN provided a gift of Victoria's Secret lingerie to Jane Doe #16 for her
+eighteenth birthday.
+Jane Does #18 and #19
+(196) In or around the last half of 2003, Jane Doe #18 was approached by A.F.
+and was asked whether she would be willing to provide a massage to Defendant
+JEFFREY EPSTEIN in exchange for $200.
+(197) In or around the last half of 2003, Defendant JEFFREY EPSTEIN asked
+Jane Doe #18 to provide her telephone number.
+32
+
+
+(198) On or around August 27, 2003, Defendant
+a telephone call to a telephone used by Jane Doe #18.
+(199) In or around the last half of 2003, Defendant JEFFREY EPSTEIN
+masturbated in the presence of Jane Doe #18, who was then a seventeen-year-old-girl.
+(200) On oraround November 16, 2003, Defendant
+a telephone call to a telephone used by Jane Doe #18.
+(201) In or around the last half of 2003, Defendant JEFFREY EPSTEIN
+digitally penetrated Jane Doe #18, who was then a seventeen-year-old-girl.
+(202) In or around the last half of 2003, Defendant JEFFREY EPSTEIN asked
+Jane Doe #18 to recruit other females to travel to 358 El Brillo Way.
+(203) On or about March 5, 2004, Defendant JEFFREY EPSTEIN asked Jane
+Doe #19, who was then a seventeen-year-old girl, to leave when she refused to
+remove her shirt.
+(204) On or about March 5, 2004, Defendant JEFFREY EPSTEIN verbally
+reprimanded Jane Doe #18 for bringing Jane Doe #19 to 358 El Brillo Way when she
+was not willing to undress for him.
+The Defendants' Travel
+(205) On or about July 16, 2004, Defendants JEFFREY EPSTEIN,
+and
+traveled from Teterboro, New Jersey to
+Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air,
+Inc.
+
+
+(206) On or about August 6, 2004, Defendants JEFFREY EPSTEIN and
+traveled from the U.S. Virgin Islands to Palm Beach County,
+Florida aboard the Boeing 727 aircraft owned by JEGE, INC.
+(207) On or about August 19, 2004, Defendants JEFFREY EPSTEIN and
+traveled from Van Nuys, California to Palm Beach County,
+Florida aboard the Boeing 727 aircraft owned by JEGE, INC.
+(208) On or about October 29, 2004, Defendants JEFFREY EPSTEIN and
+traveled from Teterboro, New Jersey to Palm Beach
+County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.
+(209) On or about February 21, 2005, Defendants JEFFREY EPSTEIN,
+and
+traveled from the U.S. Virgin
+Islands to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by
+JEGE, INC.
+(210) On or about March 31, 2005, Defendant JEFFREY EPSTEIN traveled
+from New York, New York to Palm Beach County, Florida, aboard the Boeing 727
+aircraft owned by JEGE, INC.
+(211) On or about September 18, 2005, Defendants JEFFREY EPSTEIN,
+" traveled from
+, and
+, a/k/a"
+Westchester County, New York to Palm Beach County, Florida aboard the Gulfstream
+aircraft owned by Hyperion Air, Inc.
+34
+
+
+On or about September 29, 2005, Defendants JEFFREY EPSTEIN,
+, a/k/a"
+"and
+traveled
+from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream
+aircraft owned by Hyperion Air, Inc.
+All in violation of Title 18, United States Code, Section 371.
+COUNTS 2 THROUGH 11
+(Sex Trafficking: 18 U.S.C. § 1591(a)(1))
+29.
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
+30.
+On or about the dates enumerated as to each count listed below, the exact dates
+being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida,
+and elsewhere, the Defendants listed below did knowingly, in and affecting interstate and
+foreign commerce, recruit, entice, provide, and obtain by any means a person, that is, the
+person in each count listed below, knowing that the person had not attained the age of 18
+years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. §
+1591(c)(1):
+Count
+2
+Dates
+2001 - 2004
+Minor Involved
+Jane Doe #2
+Defendants
+3
+January 2004
+through
+July 2004
+Jane Doe #4
+
+
+Count
+4
+5
+6
+7
+8
+9
+Dates
+July 2004
+through
+December 29,
+2004
+July 2004
+through
+January 31, 2005
+Mid-2004
+through
+March 2005
+Mid-2004
+through
+April 22, 2005
+August 2004
+through
+May 27, 2005
+November 2004
+through
+March 2005
+December 2004
+through
+June 5, 2005
+February 2005
+through
+first week of
+October 2005
+Minor Involved
+Jane Doe #9
+Defendants
+Jane Doe #10
+Jane Doe #11
+Jane Doe #12
+Jane Doe #13
+Jane Doe #14
+Jane Doe #15
+Jane Doe #16
+a/k/a i
+a/k/a i
+a/k/a "
+All in violation of Title 18, United States Code, Sections 1591(a)(1) and 2.
+36
+
+
+COUNT 12
+(Sex Trafficking: 18 U.S.C. § 1591(a)(2))
+31.
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
+32.
+From at least as early as in or about 2001 through in or about October 2005,
+the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern
+District of Florida, and elsewhere, the defendants,
+-
+did knowingly benefit, financially or by receiving anything of value, from participation in a
+venture, as defined in 18 U.S.C. § 1591(c)(3), which had engaged in an act described in
+violation of 18 U.S.C. § 1591(a)(1), that is, the recruiting, enticing, providing, and obtaining
+by any means a person, in or affecting interstate commerce, knowing that the person or
+persons had not attained the age of 18 years and would be caused to engage in a commercial
+sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title 18, United States Code,
+Sections 1591(a)(2), 1591(b)(2), and 2.
+COUNT 13
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+33.
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
+37
+
+
+34.
+From in or around the spring of 2003 through on or about October 2, 2005, the
+exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District
+of Florida, and elsewhere, the defendants,
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice Jane Doe #3, who was a person who had not attained the age of
+18 years, to engage in prostitution and in a sexual activity for which a person can be charged
+with a criminal offense, that is violations of Florida Statutes Sections 800.04(5)(a),
+800.04(6)(a), and 800.04(7)(a); in violation of Title 18, United States Code, Sections 2422(b)
+and 2.
+COUNT 14
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+35.
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
+36.
+In or around July 2004, the exact dates being unknown to the Grand Jury, in
+Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants,
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice Jane Doe #7, who was a person who had not attained the age of
+38
+
+
+18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections
+COUNT 15
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+37. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
+38.
+From in or around July 2004 through in or around October 2004, the exact
+dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of
+Florida, and elsewhere, the defendants,
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice Jane Doe #8, who was a person who had not attained the age of
+18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections
+COUNT 16
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+39.
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
+40.
+From in or around July 2004 through on or around December 29, 2004, the
+exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District
+of Florida, and elsewhere, the defendants,
+39
+
+
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice Jane Doe #9, who was a person who had not attained the age of
+18 years, to engage in prostitution and in a sexual activity for which a person can be charged
+with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of
+Title 18, United States Code, Sections 2422(b) and 2.
+COUNT 17
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+41. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
+42. From in or around July 2004 through on or about January 31, 2005, the exact
+dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of
+Florida, and elsewhere, the defendants,
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice Jane Doe #10, who was a person who had not attained the age
+of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections
+40
+
+
+COUNT 18
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+43.
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
+44.
+From in or around the middle of 2004 through in or about March 2005, the
+exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District
+of Florida, and elsewhere, the defendants,
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice Jane Doe #11, who was a person who had not attained the age
+of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections
+COUNT 19
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+45. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
+46.
+From in or around the middle of 2004 through on or about April 22, 2005, the
+exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District
+of Florida, and elsewhere, the defendants,
+and
+41
+
+
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice Jane Doe #12, who was a person who had not attained the age
+of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections
+COUNT 20
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+47.
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
+48.
+From in or around August 2004 through on or about May 27, 2005, the exact
+dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of
+Florida, and elsewhere, the defendants,
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice Jane Doe #13, who was a person who had not attained the age
+of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections
+COUNT 21
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+49.
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
+42
+
+
+50. From in or around November 2004 through in or around March 2005, the exact
+dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of
+Florida, and elsewhere, the defendants,
+and
+1, a/k/a"
+"
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice Jane Doe #14, who was a person who had not attained the age
+of 18 years, to engage in prostitution and in a sexual activity for which a person can be
+charged with a criminal offense, that is a violation of Florida Statutes Section 794.05; in
+violation of Title 18, United States Code, Sections 2422(b) and 2.
+COUNT 22
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+51.
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
+52.
+From in or around December 2004 through on or about June 5, 2005, the exact
+dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of
+Florida, and elsewhere, the defendants,
+, and
+a/k/a i
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice Jane Doe #15, who was a person who had not attained the age
+43
+
+
+of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections
+COUNT 23
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+53.
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
+54.
+From in or around February 2005 through in or around the first week of
+October 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in
+the Southern District of Florida, and elsewhere, the defendants,
+a/k/a'
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce or entice Jane Doe #16, who was a person who had not attained the age of
+18 years, to engage in prostitution and in a sexual activity for which a person can be charged
+with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of
+Title 18, United States Code, Sections 2422(b) and 2.
+COUNT 24
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+55.
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
+44
+
+
+56.
+From in or around February 2005 through in or around April 2005, the exact
+dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of
+Florida, and elsewhere, the defendants,
+, a/k/a"
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice Jane Doe #17, who was a person who had not attained the age
+of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections
+COUNT 25
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+57.
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
+58.
+From in or around August 2003 through in or around February 2004, the exact
+dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of
+Florida, and elsewhere, the defendants,
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice Jane Doe #18, who was a person who had not attained the age
+45
+
+
+of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections
+59.
+COUNT 26
+(Conspiracy to Travel: 18 U.S.C. § 2423(e))
+Paragraphs 1 through 23 of this indictment are re-alleged and incorporated by
+reference as fully set for the herein.
+60.
+From at least as carly as 2001 through in or around October 2005, the exact
+dates being unknown to the Grand Jury, the Defendants,
+did knowingly and willfully conspire with each other and with others known and unknown
+to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as
+defined in 18 U.S.C. § 2423(f), with another person, in violation of Title 18, United States
+Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e).
+COUNT 27
+(Facilitation of Unlawful Travel of Another: 18 U.S.C. § 2423(d))
+61.
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
+62.
+From at least as early as in or about 2001 through in or around October 2005,
+the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern
+District of Florida, and elsewhere, the Defendant,
+46
+
+
+did, for the purpose of commercial advantage or private financial gain, arrange and facilitate
+the travel of a person, that is Defendant Jeffrey Epstein, knowing that such person was
+traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as
+defined in 18 U.S.C. § 2423(f); in violation of Title 18, United States Code, Section 2423(d).
+COUNTS 28 THROUGH 35
+(Travel to Engage in Illicit Sexual Conduct: 18 U.S.C. § 2423(b))
+63.
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
+64.
+On or about the dates enumerated as to each count listed below, from a place
+outside the Southern District of Florida to a place inside the Southern District of Florida, the
+Defendants listed below traveled in interstate commerce for the purpose of engaging in illicit
+sexual conduct as defined in 18 U.S.C. § 2423(f), with a person under 18 years of age, that
+is, the person(s) listed in each count below:
+Count
+28
+Date
+7/16/2004
+8/6/04
+30
+8/19/04
+Minor(s) Involved
+Jane Doe #7
+Jane Doe #8
+Jane Doe #9
+Jane Doe #10
+Jane Doe #9
+Jane Doe #11
+Jane Doe #9
+Jane Doe #10
+Jane Doe #11
+Defendants
+
+
+Count
+31
+Date
+10/29/04
+32
+2/21/05
+Minor(s) Involved
+Jane Doe #10
+Jane Doe #11
+Jane Doe #13
+Jane Doe #11
+Jane Doe #14
+Jane Doe #15
+Defendants
+3/31/2005
+34
+9/18/2005
+Jane Doe #11
+Jane Doe #14
+Jane Doe #15
+Jane Doe #16
+Jane Doe #16
+35
+9/29/05
+Jane Doe #16
+a/k/a"
+a/k/a i
+a/k/al
+a/k/a"
+All in violation of Title 18, United States Code, Sections 2423(b) and 2.
+FORFEITURE 1
+Upon conviction of the violation alleged in Count 1 of this indictment, the defendants,
+a/k/a"
+"and
+shall forfeit to the United States any property, real or personal,
+which constitutes or is derived from proceeds traceable to the violation.
+48
+
+
+Pursuant to Title 28, United States Code, Section 2461; Title 18, United States Code,
+Section 981(a)(1)(C); and Title 21, United States Code, Section 853.
+If the property described above as being subject to forfeiture, as a result of any act or
+omission of the defendants, JEFFREY EPSTEIN,
+a/k/a *
+" and
+cannot be located upon the exercise of due diligence;
+has been transferred or sold to, or deposited with a third person;
+has been placed beyond the jurisdiction of the Court;
+has been substantially diminished in value; or
+has been commingled with other property which cannot be subdivided without
+(1)
+(2)
+(3)
+(4)
+(5)
+difficulty;
+it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p),
+to seek forfeiture of any other property of the defendants up to the value of the above
+forfeitable property.
+All pursuant to Title/28, United States Code, Section 2461; Title 18, United States
+Code, Section 981(a)(1)(C); and Title 21, United States Code, Section 853.
+FORFEITURE 2
+Upon conviction of any of the violations alleged in Counts 13-35 of this indictment,
+the defendants, JEFFREY EPSTEIN, I
+, a/k/a"
+"and
+, shall forfeit to the United States any property, real
+or personal, constituting or traceable to gross profits or other proceeds obtained from such
+49
+
+
+offense; and any property, real or personal, used or intended to be used to commit or to
+promote the commission of such offense, including but not limited to the following:
+a.
+A parcel of land located at 358 El Brillo Way, Palm Beach, Florida
+33480, including all buildings, improvements, fixtures, attachments, and easements found
+therein or thereon, and more particularly described as:
+Being all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as
+recorded in Plat Book 9, Page 9, in the records of Palm Beach County, Florida
+and
+BEING that portion lying West of Lot 40, El Bravo Park, in Section 27,
+Township 43 South, Range 43 East, as recorded in Plat Book 9, Page 9, Public
+lecords of Palm Beach County. 1
+est sider fan Beach Court, Slavid ani unded on the sist be ea
+as shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981,
+and bounded on the East by the shoreline as shown on the plat of El Bravo
+Park, and bounded on the North and South by the Westerly extensions of the
+North and South lines respectively of Lot 40, containing 0.07 acres, more or
+less.
+Pursuant to Title 18, United States Code, Section 2253.
+If any of the forfeitable property described in the forfeiture section of this indictment,
+as a result of any act or omission of the defendants JEFFREY EPSTEIN,
+, a/k/a"
+" and
+(a)
+cannot be located upon the exercise of due diligence;
+(b) has been transferred or sold to, or deposited with, a third person;
+(C)
+has been placed beyond the jurisdiction of the Court;
+(d)
+has been substantially diminished in value; or
+50
+
+
+(e)
+has been commingled with other property which cannot be divided without
+difficulty;
+it is the intent of the United States, pursuant to Title 18, United States Code, Section 2253(o),
+to seek forfeiture of any other property of said defendant up to the value of the above
+forfeitable property.
+Pursuant to Title 18, United States Code, Section 2253.
+FORFEITURE 3
+Upon conviction of any of the violations alleged in Counts 2-12 of this indictment,
+the defendants, JEFFREY EPSTEIN,
+a/k/a"
+" and
+, shall forfeit to the United States any property, real
+or personal, that was used or intended to be used to commit or to facilitate the commission
+of such violation; and any property, real or personal, constituting or derived from any
+proceeds that such person obtained, directly or indirectly, as a result of such violation,
+including but not limited to the following:
+a.
+A parcel of land located at 358 El Brillo Way, Palm Beach, Florida
+33480, including all buildings, improvements, fixtures, attachments, and easements found
+therein or thereon, and more particularly described as:
+Being all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as
+recorded in Plat Book 9, Page 9, in the records of Palm Beach County, Florida -
+and
+BEING that portion lying West of Lot 40, El Bravo Park, in Section 27,
+Township 43 South, Range 43 East, as recorded in Plat Book 9, Page 9, Public
+Records of Palm Beach County, Florida, being bounded on the West by the
+51
+
+
+West side of an existing concrete seawall and the northerly extension thereof™
+as shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981,
+and bounded on the East by the shoreline as shown on the plat of El Bravo
+Park, and bounded on the North and South by the Westerly extensions of the
+North and South lines respectively of Lot 40, containing 0.07 acres, more or
+less.
+Pursuant to Title 18, United States Code, Section 1594(b).
+A TRUE BILL.
+FOREPERSON
+R. ALEXANDER ACOSTA-
+UNITED STATES ATTORNEY
+ASSISTANT UNITED STATES ATTORNEY
+52
+
+
+1
+2
+3
+4
+DATE(S)
+2001 - October 2005
+2001 - 2004
+January 2004 -
+July 2004
+July 2004 -
+December 29, 2004
+INDICTMENT SUMMARY
+DEFENDANT(S)
+VICTIM(S)
+Jane Does 1-19
+Jane Doe #2
+(Carolyn A.)
+NEPSTEN
+Jane Doe #4
+LEPSTEIN
+Jane Doe #9
+18 U.S.C. §§ 371 and 2
+Conspiracy to use a facility or means of interstate
+commerce to persuade, induce, or entice minors to
+engage in prostitution or any sexual activity for which
+any person can be charged with a criminal offense
+18 U.S.C. §§ 1591(a)(1) and 2
+Knowingly, in or affecting interstate or foreign
+commerce, recruiting, enticing, providing, and obtaining
+by any means a person, knowing that the person was a
+minor and would be caused to engage in a commercial
+sex act.
+18 U.S.C. §§ 1591(a)(1) and 2
+Knowingly, in or affecting interstate or foreign
+commerce, recruiting, enticing, providing, and obtaining
+by any means a person, knowing that the person was a
+minor and would be caused to engage in a commercial
+sex act.
+18 U.S.C. §§ 1591(a)(1) and 2
+Knowingly, in or affecting interstate or foreign
+commerce, recruiting, enticing, providing, and obtaining
+by any means a person, knowing that the person was a
+minor and would be caused to engage in a commercial
+sex act.
+
+
+
+5
+6
+7
+8
+DATE(S)
+July 2004 -
+January 31, 2005
+Mid-2004 -
+April 22, 2005
+Mid-2004 -
+April 22, 2005
+August 2004 -
+May 27, 2005
+DEFENDANT(S)
+VICTIM(S)
+Jane Doe #10
+Jane Doe #12
+WEPSTEIN
+Jane Doe #12
+YEPSTEIN
+Jane Doe #13
+
+18 U.S.C. §§ 1591(a)(1) and 2
+Knowingly, in or affecting interstate or foreign
+commerce, recruiting, enticing, providing, and obtaining
+by any means a person, knowing that the person was a
+minor and would be caused to engage in a commercial
+sex act.
+18 U.S.C. §§ 1591(a)(1) and 2
+Knowingly, in or affecting
+interstate or foreign
+commerce, recruiting, enticing, providing, and obtaining
+by any means a person, knowing that the person was a
+minor and would be caused to engage in a commercial
+sex act.
+18 U.S.C. §§ 1591(a)(1) and 2
+Knowingly, in
+or affecting interstate or foreign
+commerce, recruiting, enticing, providing, and obtaining
+by any means a person, knowing that the person was a
+minor and would be caused to engage in a commercial
+sex act.
+Knowingly, in or affecting interstate or foreign
+commerce, recruiting, enticing, providing, and obtaining
+by any means a person, knowing that the person was a
+minor and would be caused to engage in a commercial
+sex act.
+
+
+10
+11
+12
+DATE(S)
+November 2004 -
+March 2005
+December 2004 -
+June 5, 2005
+February 2005 -
+October 2005
+2001 - October 2005
+DEFENDANT(S)
+VICTIM(S)
+Jane Doe #14
+Jane Doe #15
+Jane Doe #16
+Jane Does 1-19
+
+18 U.S.C. §§ 1591(a)(1) and 2
+Knowingly, in or affecting interstate or foreign
+commerce, recruiting, enticing, providing, and obtaining
+by any means a person, knowing that the person was a
+minor and would be caused to engage in a commercial
+sex act.
+18 U.S.C. §§ 1591(a)(1) and 2
+Knowingly, in or affecting interstate or foreign
+commerce, recruiting, enticing, providing, and obtaining
+by any means a person, knowing that the person was a
+minor and would be caused to engage in a commercial
+18 U.S.C. $$ 1591(a)(1) and 2
+Knowingly, in or affecting interstate or foreign
+commerce, recruiting, enticing, providing, and obtaining
+by any means a person, knowing that the person was a
+minor and would be caused to engage in a commercial
+Benefitting, financially or by receiving any thing of
+value, from participation in a venture which had
+engaged in the recruiting, enticing, providing, or
+obtaining by any means a person, knowing that the
+pers vour er sons ed on attained the meril sears.
+
+
+13
+DATE(S)
+Spring 2003 -
+October 2, 2005
+DEFENDANTS)
+VICTIM(S)
+Jane Doe #3
+14
+July 2004
+Jane Doe #7
+15
+July 2004 to
+October 2004
+LPSTEIN
+Jane Doe #8
+July 2004 -
+December 29, 2004
+PEPSTEIN
+Jane Doe #9
+
+knowingly persuade, induce, or entice a person who had
+not attained the age of 18 years to engage in prostitution
+with a criminal offense
+knowingly persuade, induce, or entice a person who had
+not attained the age of 18 years to engage in prostitution
+with a criminal offense
+knowingly persuade, induce, or entice a person who had
+not attained the age of 18 years to engage in prostitution
+with a criminal offense
+
+
+18
+19
+20
+DATE(S)
+July 2004 -
+January 31, 2005
+Mid-2004 -
+March 2005
+Mid-2004 -
+April 22, 2005
+August 2004 -
+May 27, 2005
+DEFENDANT(S)
+VICTIM(S)
+Jane Doe #10
+Jane Doe #11
+Jane Doe #12
+Jane Doe #13
+
+sing a facility or means of interstate commerce to
+nowingly persuade, induce, or entice a person who ha‹
+not attained the age of 18 years to engage in prostitution
+with a criminal offense
+knowingly persuade, induce, or entice a person who had
+not attained the age of 18 years to engage in prostitution
+18 U.S.C. $$ 2422(b) and 2
+knowingly persuade, induce, or entice a person who had
+not attained the age of 18 years to engage in prostitution
+with a criminal offense
+knowingly persuade, induce, or entice a person who had
+ot attained the age of 18 years to engage in prostitutio
+r sexual activity for which any person can be charge
+
+
+22
+23
+24
+DATE(S)
+November 2004 -
+March 2005
+DEFENDANT(S)
+VICTIM(S)
+Jane Doe #14
+December 2004 -
+June 5, 2005
+REPSTEIN
+Jane Doe #15
+February 2005 -
+October 2005
+LEPSTEIN
+Jane Doe #16
+February 2005 -
+April 2005
+Jane Doe #17
+
+or entice a person who har
+not attained the age of 18 years to engage in prostitution
+with a criminal offense
+knowingly persuade, induce, or entice a person who had
+not attained the age of 18 years to engage in prostitution
+knowingly persuade, induce, or entice a person who had
+not attained the age of 18 years to engage in prostitution
+with a criminal offense
+
+
+25
+26
+27
+28
+29
+DATE(S)
+August 2003 -
+February 2004
+2001 - October 2005
+2001 - October 2005
+July 16, 2004
+August 6, 2004
+DEFENDANTS)
+VERSTEIN
+VICTIM(S)
+Jane Doe #18
+NEPSTEN
+Jane Does 1-19
+Jane Does 1-19
+TEPSTEN
+Jane Doe #7
+Jane Doe #8
+Jane Doe #9
+Jane Doe #10
+Jane Doe #9
+Jane Doe #11
+
+knowingly persuade, induce, or entice a person who had
+not attained the age of 18 years to engage in prostitution
+18 U.S.C. § 2423(e)
+Conspiracy to travel in interstate commerce for the
+purpose of engaging in illicit sexual conduct
+18 U.S.C. § 2423d)
+For the purpose of commercial advantage or private
+financial gain, arranging or facilitating the travel of a
+person knowing that the person was traveling in
+interstate commerce for the purpose of engaging in illicit
+sexual conduct
+18 U.S.C. $8 2423(b) and 2
+engaging in illicit sexual conduct with a minor
+18 U.S.C. §8 2423(b) and 2
+engaging in illicit sexual conduct with a minor
+
+
+30
+31
+32
+33
+34
+DATE(S)
+August 19, 2004
+October 29, 2004
+February 21, 2005
+March 31, 2005
+September 18, 2005
+DEFENDANT(S)
+NEPSTEIN
+LEPSTEIN
+TEPSTEIN
+VICTIMS)
+Jane Doe #9
+Jane Doe #10
+Jane Doe #11
+Jane Doe #10
+Jane Doe #11
+Jane Doe #13
+Jane Doe #11
+Jane Doe #14
+Jane Doe #15
+Jane Doe #11
+Jane Doe #14
+Jane Doe #15
+Jane Doe #16
+Jane Doe +16
+
+18 U.S.C. §§ 2423(b) and 2
+engaging in illicit sexual conduct with a minor
+18 U.S.C. $§ 2423(b) and 2
+engaging in illicit sexual conduct with a minor
+18 U.S.C. §§ 2423(b) and 2
+raveling in interstate commerce for the purpose of
+ngaging in illicit sexual conduct with a minor
+18 U.S.C. §§ 2423(b) and 2
+engaging in illicit sexual conduct with a minor
+18 U.S.C. $8 2423(b) and 2
+raveling in interstate commerce for the purpose o
+gaging in illicit sexual conduct with a minc
+
+
+35
+DATE(S)
+September 29, 2005
+DEFENDANT(S)
+VICTIM(S)
+Jane Doe #16
+18 U.S.C. $$ 2423(b) and 2
+engaging in illicit sexual conduct with a minor
+
+
+
+Case 9:08-CV-80119-KAM Document 147
+
+CASE NO.: 08-CV-80119-MARRA/JOHNSON
+JANE DOE NO. 2,
+JANE DOE NO. 3,
+CASE NO.: 08-CV-80232-MARRA/JOHNSON
+JANE DOE NO. 4,
+CASE NO.: 08-CV-80380-MARRA/JOHNSON
+JANE DOE NO. 5,
+
+
+
+JANE DOE NO. 6,
+CASE NO.: 08-CV-80994-MARRA/JOHNSON
+JANE DOE NO. 7,
+CASE NO.: 08-CV-80993-MARRA/JOHNSON
+CASE NO.: 08-CV-80811-MARRA/JOHNSON
+CASE NO.: 08-CV-80893-MARRA/JOHNSON
+
+
+
+DOE II,
+CASE NO.: 09-CV-80469-MARRA/JOHNSON
+JANE DOE NO. 101,
+CASE NO.: 09-CV-80591-MARRA/JOHNSON
+JANE DOE NO. 102,
+CASE NO.: 09-CV-80656-MARRA/JOHNSON
+PLAINTIFF'S RESPONSE TO DEFENDANT, JEFFREY EPSTEIN'S MOTION TO
+STRIKE CASES FROM CURRENT TRIAL DOCKET AND MOTION TO CONTINUE
+CASE AND/OR ALTERNATIVE MOTION TO MODIFY TRIAL AND SCHEDULING
+ORDER DEADLINES
+The Plaintiff,
+., by and through undersigned counsel, files this Response to
+Defendant, Jeffrey Epstein's Motion to Strike Cases From Current Trial Docket And
+Motion to Continue Case And/Or Alternative Motion to Modify Trial and Scheduling
+Order (D.E. 104), and further states as follows:
+
+
+Case 9:08-cv-80119-KAM Document 147 Entered on FLSD Docket 06/08/2009 Page 4 of 9
+Defendant EPSTEIN seeks to have this case (and others that are
+presently pending) stricken from the trial docket, or continued for at least an additional
+three months or have the existing pretrial deadlines extended. In light of Plaintiff's filing
+of her Conditional Notice of Intent to Exclusively Rely on Statutory Damages Provided
+by 18 U.S.C. §2255 (D.E. 113) on June 5, 2009, Plaintiff agrees to a modification of the
+pretrial schedule as outlined in Defendant EPSTEIN's Motion to Strike (D.E. 104); to wit,
+extending discovery for an additional three months from the currently set deadline of
+August 28, 2009, extending the current deadline of October 15, 2009 by two. months to
+file substantive pretrial motions, extending the current deadline of December 21, 2009
+by one month to mediate this matter, and extending the deadline of June 29, 2009 by
+one month to exchange expert witness reports.'
+2.
+EPSTEIN's requests to have this case stricken from the trial docket, or in
+the alternative, continued for three months, however, are not warranted under the
+circumstances and would unreasonably and unnecessarily delay the resolution of this
+case. The filing of the instant motion marks the third different way EPSTEIN has sought
+to delay the trial on this matter. First, it was Defendant's Motion for Stay (D.E. 33),
+which was denied by the Court on December 17, 2008. Next, it was Defendant's
+second Motion for Stay (D.E. 51), which is presently pending before the Court. Third,
+and unfortunately, probably not the last, is Defendant's latest attempt to delay the trial of
+this case.
+" With regards to the last requested modification of the pretrial order, EPSTEIN requests "an additional
+month to complete the remaining deadlines under each of the Court's Trial Orders." Given that each of
+the other deadlines not specifically listed above are to take place 15 days or less from the calendar call
+date of February 19, 2010 (which is 3 days from the trial date of February 22, 2010), the only logical
+deadline EPSTEIN could be referring to is the expert witness report exchange
+
+
+Case 9:08-cv-80119-KAM Document 147 Entered on FLSD Docket 06/08/2009 Page 5 of 9
+In order to justify his latest attempt to delay the trial of this case, EPSTEIN
+argues that Plaintiff's conduct has prevented him from "conducting any meaningful
+discovery, including the taking of
+'s supervisors, co-workers, acquaintances,
+friends, and other third parties."(D.E. 104, pg. 7). The sworn affidavit by counsel for
+Defendant, Michael Pike, Esq. repeats the same allegation ("As a result, the
+undersigned has not had an opportunity to depose any individuals that may have
+information about the allegations made by Plaintiffs."(D.E. 042-2, paragraph 4).
+4, Defendant's Motion and affidavit are simply not supported by the history of
+this case. First, this case was filed in state court on February 21, 2008. Defendant
+EPSTEIN was served with a summons and complaint on July 2, 2008. For reasons that
+are known only to himself and his counsel in this case, EPSTEIN waited a full six
+months before propounding any discovery of any kind upon Plaintiff. EPSTEIN filed his
+first set of interrogatories on January 16, 2009, and his first set of requests to produce
+on January 16, 2009. EPSTEIN's choice to wait a half a year before engaging in formal
+discovery is not the Plaintiff's fault, nor can he now be allowed to argue that the current
+trial setting is unworkable because of his failures.
+5.
+Second, Plaintiff provided answers to Defendant's first set of
+interrogatories on February 18, 2009 (Attached as Exhibit "1"). Plaintiff's answers to
+interrogatories identifies thirty six (36) people, other than herself and EPSTEIN, who
+have or may have knowledge regarding the subject matter of the instant law suit. This
+list of individuals includes Plaintiff's relatives, mental health providers, a former
+boyfriend, her friends, other victims of EPSTEIN, members of law enforcement who
+investigated EPSTEIN, and former employees and/or associates of EPSTEIN. Armed
+
+
+Case 9:08-cv-80119-KAM Document 147 Entered on FLSD Docket 06/08/2009 Page 6 of 9
+with the identities of these crucial fact witnesses for almost the last four (4) months,
+EPSTEIN had not set a single one of them for deposition as of the time he filed the
+instant motion.
+Defendant's claims that he has been absolutely prevented from
+engaging in any discovery as a result of Plaintiff's "delay tactics" are absolutely belied
+by the fact that he actually has much of the information he complains Plaintiff is
+concealing from him, but has chosen to do nothing with it over the last four months.
+6.
+Plaintiff also filed on February 2, 2009 her Initial Disclosure which likewise
+identified multiple individuals who had or may have knowledge regarding the subject
+matter of the instant suit (Attached as Exhibit "2"). Defendant failed to set any of those
+indentified individuals for deposition either.
+7.
+Once again, Defendant cannot bury his head in the sand by failing to take
+available discovery and then turn around and complain that he cannot get ready for trial
+scheduled in February of 2010.
+Third, EPSTEIN inappropriately characterizes Plaintiff's assertions of the
+protections afforded to her under the applicable rules of procedure and case law with
+respect to unreasonably invasive and irrelevant discovery propounded by EPSTEIN as
+an attempt to conceal evidence from EPSTEIN and delay the discovery of same.
+Defendant's allegations in this regard are flat out wrong. Plaintiff, just like EPSTEIN,
+has certain rights and privileges with respect to the scope of permissible discovery.
+Plaintiff has every right to avail herself of the protections available to her under the rules
+of discovery without fear of claims from EPSTEIN that she is concealing or delaying
+anything. Indeed, it is ironic that EPSTEIN takes issue with a litigant invoking the
+protections available to her with regards to inappropriate and unreasonable discovery
+
+
+
+when he himself has failed to respond to any discovery propounded to him by Plaintiff,
+but instead has invoked his 5' Amendment privilege.
+Fourth, in the event that the Court rules that Plaintiff can recover the
+statutory damage floor established in 18 U.S.C. §2255 for each proven incident of
+abuse committed by EPSTEIN upon her, the discovery which EPSTEIN presently seeks
+will not be relevant or material in any way given Plaintiff's Conditional Notice of Intent to
+Exclusively Rely on Statutory Damages Provided by 18 U.S.C. §2255.
+10.
+Defendant asserts as justification for continuing this case what can fairly
+be characterized as routine and ordinary discovery disputes. Nothing contained in
+either his motion or supporting affidavit rises to the level of "exceptional circumstances"
+required by Local Rule 7.6 to continue a trial setting. Any issues related to discovery
+can certainly be cured by extending the trial deadlines as proposed by EPSTEIN.
+Delaying the trial of this case is simply not necessary nor justified.
+
+
+Document 147
+
+WHEREFORE, in light of the foregoing, the Plaintiff respectfully requests this
+Court enter an order denying Defendant, Jeffrey Epstein's Motion to Strike Cases From
+Current Trial Docket And Motion to Continue Case And/Or Alternative Motion to Modify
+Trial and Scheduling Order.
+Respectfully submitted,
+Is/lack P. Hill
+JACK SCAROLA
+Florida Bar No.
+JACK P. HILL
+Florida Bar No.:
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Attorneys for Plaintiff
+I HEREBY CERTIFY that on June 8th, 2009, I electronically filed the foregoing
+document with the Clerk of Court using CM/ECF. I also certify that the foregoing
+document is being served this day on all counsel of record identified above via
+transmission of Notices of Electronic Filing generated by CM/ECF.
+Is/Jack P. Hill
+SACK P. HI
+JACK P. HILL
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Attorneys for Plaintif
+
+
+Case 9:08-CV-80119-KAM Document 147
+
+COUNSEL LIST
+Robert Critton, Esquire
+Burman Critton Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach. FL 33414
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S.
+West Palm Beach. FL. 33401
+Richard H. Willits, Esquire
+Richard H. Willits, P.A.
+2290 10th Avenue North
+Suite 404
+Lake Worth, FL 33461
+Bruce E. Reinhart, Esquire
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+
+
+Case 9:08-CV-80119-KAM Document 147-2
+
+#281849/c/w
+CASE NO.: 08-CV-80811-CIV-
+MARRA/JOHNSON
+Plaintiff(s),
+JEFFREY EPSTEIN and
+Defendant(s).
+NOTICE OF SERVING
+ANSWERS TO INTERROGATORIES
+COMES NOW the Plaintiff,
+•, by and through undersigned counsel, and hereby
+files this Notice with the Court that Answers to Interrogatories propounded by the Defendant,
+JEFFREY EPSTEIN, on January 16, 2009, have been furnished to the attorney for the
+I HEREBY CERTIFY that a true copy of the foregoing has been furnished by mail this
+18" day of February, 2009, to: See attached list of counsel.
+JACK SCAROLA
+Florida Bar No.
+JACK. P. HILL
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Attorney for Plaintits)
+PLAINTIFF'S
+
+
+
+
+ANSWERS TO INTERROGATORIES
+What is the name and address of all persons answering or assisting in answering
+these interrogatories, and, if applicable, the person's official position or
+relationship with the party to whom the interrogatories are directed?
+2.
+c/o her attorneys:
+Jack Scarola, Esq. and Jack P. Hill, Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+With the assistance of her counsel, Searcy Denney Scarola Barnhart &
+Shipley, P.A. and Richard Willits, P.A.
+List the names, business addresses, telephone and cell phone numbers, dates of
+employment, immediate supervisor (name and address) and rates of pay
+regarding all employers, including self-employment, for whom you have worked
+in the past 10 years; this includes listing all sources of income you have received.
+Answer this question by year, i.e. 1998-2009.
+Objection, Irrelevant, immaterial and not reasonably calculated to lead to
+discovery of admissible evidence.
+List all former names and when you were known by those names. State all
+by name, date of birth and the father's name and address. List the names and
+Nickname-
+2
+
+
+
+Thave never been married.
+Children:
+Parents:
+Siblings:
+3
+
+
+
+- vs. Epstein, et al.
+Have you ever been convicted of a crime, other than any juvenile adjudication,
+specific crime and the date and place of conviction.
+• ANSWER
+No
+Please provide the name, address, telephone number, place of employment and
+ob title of any person who has, claims to have or whom you believe may hav
+nowledge or information pertaining to any fact alleged in the pleadings (a
+defined in Federal Rule of Civil Procedure 7(a) filed in this action, or any fact
+underlying the subject matter of this action).
+c/o her attorneys:
+Jack Scarola, Esq. and Jack P. Hill, Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A
+2139 Palm Beach Lakes Boulevarc
+West Palm Beach. FL 33409
+Richard Willits, Esq.
+2.
+Subject matter: Plaintiff.
+Jeffrey Epstein
+clo his attorneys:
+Robert Critton, Esquire
+Burman Critton Luttier & Coleman LLP
+4
+
+
+
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33414
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South
+West Palm Beach, FL 33401
+Bruce E. Reinhart, Esquire
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+Defendant
+s mother,
+c/O
+s attorneys:
+Jack Scarola, Esq. and Jack P. Hill, Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+West Palm Beach FL 3 Boulevard
+Richard Willits, Esq.
+Richard H. Willits, P.A.
+2290 10th Avenue North, Suite 404
+Lake Worth, FL 33461
+I's involvement with Epstein.
+4.
+(Address unknown)
+5
+
+
+
+Jane Doe (Case No.: 1:93-cV-01109-KAM)
+clo her attorney:
+Theodore Leopold, Esquire
+alm Beach Gardens, FL 3341(
+Victim of Epstein.
+Jane Doe (Case No.: 502008CA020614)
+c/o her attorney:
+Isidro M. Garcia, Esquire
+The Law Office of Brad Edwards & Associates, LLC
+2028 Harrison Street, Suite 202
+Tellywood, FL 33020
+Victim of Epstein.
+Jane Doe #2 (Case No.: 9:08-CV-80119-KAM)
+c/o her attorney:
+8.
+Jeffrey M. Herman, Esquire
+ferman & Mermelstein, P.A
+18205 Biscayne Boulevard, Suite 2218
+Victim of Epstein.
+Jane Doe #3 (Case No.: 9:08-cV-80232-KAM)
+c/o her attorney:
+Jeffrey M. Herman, Esquire
+18206 Biscayne Bolivard, Suite 2218
+Miami, FL 33160
+6
+
+
+Case 9:08-CV-80119-KAM Document 147-2
+
+ase No.: 08-CV-80811-CIV-MARRA/JOHNSON
+Victim of Epstein.
+9.
+Jane Doe #5 (Case No.: 9:08-CV-80381-KAM)
+c/o her attorney:
+Jeffrey M. Herman, Esquire
+Herman & Mermelstein, P.A.
+18205 Biscayne Boulevard, Suite 2218
+Miami, FL 33160
+Victim of Epstein.
+10. Jane Doe #4 (Case No.: 9:08-cV-80380-KAM)
+c/o her attorney:
+Jeffrey M. Herman, Esquire
+Herman & Mermelstein, P.A.
+18205 Biscayne Boulevard, Suite 2218
+Miami, FL 33160
+Victim of Epstein.
+11. Jane Doe (Case No.: 9:08-cv-80804-KAM)
+c/o her attorney:
+12.
+Theodore Leopold, Esquire
+Leopold, Kuvin, P.A.
+2925 P.G.A. Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Victim of Epstein.
+Jane Doe #7 (Case No.: 9:08-cv-80993-KAM)
+c/o her attorney:
+Jeffrey M. Herman, Esquire
+Herman & Mermelstein, P.A.
+7
+
+
+Case 9:08-cV-80119-KAM
+
+.. vs. Epstein, et al.
+18205 Biscayne Boulevard, Suite 2218
+Miami. FI 33160
+Tel:I
+Subject matter: Victim of Epstein.
+13. |
+(Case No.: 502008CA025129XXXXMB AI
+c/o her attorneys:
+Jack Scarola, Esquire
+Jack P. Hill, Esquire
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL. 33409
+14.
+Victim of Epstein.
+Jose Alessi
+(Address unknown at this time)
+Jeffrey Epstein's Butler.
+15.
+Janusa Banasiack
+Palm Beach Police Department
+345 South County Road
+Pal: sh Fl 33480
+Investigator.
+16.
+Palm Beach County Prosecutors Office
+401 North Dixie Highway
+West Palm Beach. FL 33401
+Tel: L
+Prosecutor.
+17.
+Detective
+H1, lead investigator
+8
+
+
+
+_vs. Epstein, et al.
+Palm Beach Police Department
+345 South County Road
+Palm Beach, FL. 33480
+Investigator.
+18.
+19.
+Sgt.
+Palm Beach Police Department
+Subject matter: Investigator.
+Former boyfriend of a victim of Epstein.
+20.
+21.
+22.
+, supervisor
+Sanitation Bureau of the Town of Palm Beach
+3101 N.W. 16"* Terrace
+Pompano Beach, FL 33064
+Tel: (877) 46-WASTE
+The incident which is the subject matter
+of this lawsuit. Discovery is ongoing.
+Major
+Palm Beach County Sheriff's Office
+3228 Gun Club Road
+West Palm Beach, FL 33406
+9
+
+
+
+| vs. Epstein, et al.
+Case No.: 08-CV-80811-CTV-MARRA/JOHNSON
+Investigator.
+23.
+friend of
+(Address will be provided upon receipt)
+Victim and friend of
+24.
+Ghislane Maxwell c/o Ghislane Corp.
+3580 Brillo Way
+Palm Beach, FL 33480
+Associate of Epstein.
+25.
+Parent Child Center
+West Palm Beach, FL
+26.
+Detective
+Palm Beach Police Department
+345 South County Road
+Telm Beach. FL 33480
+Investigator.
+27.
+Chief Michael Reiter
+alm Beach Police Departmen
+45 South County Roa
+Tel: Beach, FL 33480
+Counselor at Parent Child Center.
+Investigator.
+28.
+(Address unknown at this time)
+Subject matter: Associate of Epstein who facilitated introductions
+with various victims.
+10
+
+
+
+C,M.A. vs, Epstein, et al.
+29.
+30.
+31.
+32.
+33.
+34.
+Alfredo Rodriguez
+(Address unknown at this time)
+Employee of Epstein.
+Detective
+Palm Beach Police Department
+345 South County Road
+Palm Beach, FL 33480
+Investigator
+Esquire
+First Assistant U.S. Attorney
+U.S. Dept. of Justice
+500 South Australian Avenue
+Suite 400
+West Palm Beach, FL 33401
+Federal prosecutor.
+Federal Bureau of Investigation
+505 South Flagler Drive, Suite 500
+West Palm Beach, FL 33401
+Investigator.
+Dr. Thys
+Address will be provided upon receipt
+West Palm Beach
+I's physician.
+Assistant U.S. Attorney
+U.S. Dept. of Justice
+500 South Australian Avenue
+11
+
+
+
+Suite 400
+West Palm Beach. FL 33401
+Subject matter: Federal prosecutor.
+35.
+(Address will be provided upon receipt
+Friend of
+mother.
+36.
+(Address will be provided upon receipt)
+Subject matter: Friend of
+'s mother
+37.
+(Address will be provided upon receipt)
+Potential victim and friend of
+38.
+(Address unknown at this time)
+Subject matter;
+Associate of Epstein who may have been involved
+in encounters between Epstein and
+Please state the specific nature and substance of the knowledge that you believe
+the person(s) identified in your response to interrogatory no. 5 may have.
+Please see answer to Interrogatory #5
+Were you suffering from physical infirmity, disability, disease, sickness, or
+Complain 8o, whate one ata or ten ray into coed in the
+
+
+
+School behavioral problems, received counseling prior to the incident.
+8.
+Did you consume any alcoholic beverages or take any drugs or medications
+vithin 12 hours before the time of each incidents) described in the complaint? I
+so, state the type and amount of alcoholic beverages, drugs, or medication whic
+were consumed, and when (dates) and where you consumed them.
+9.
+1. On one occasion I had taken "Morning Glory" and "Angel Trumpets". I
+do not recall the date.
+2. On another occasion I used cocaine powder. I do not recall the date.
+Describe each injury (physical, emotional, mental) for which you are claiming
+damages in this case, specifying the part of your body that was injured, the
+nature of the injury and as to any injuries you contend are permanent, the effects
+10.
+11.
+Please state each item of damage that you claim, and include in your answer: the
+ount to which the item of damages relates; the factual basis for each item o
+lamages; and an explanation of how you computed each item of damages
+including any mathematical formula used.
+I am claiming compensation for mental anguish, mental pain, psychic
+trauma, and loss of enjoyment of life. These damages will be evaluated by
+a jury who will provide their own methods of computation in an amount of
+at least the statutory minimum established by 18 U.S.C.A. § 2255.
+Discovery is ongoing.
+ist the names and business addresses of each physician (including psychiatris
+sychologist, chiropractor or medical provider) who has treated or examined you
+13
+
+
+Entered on FLSD Docket 06/08/2009 Page 14 of 20
+and each medical facility where you have received any treatment or examination
+for the injuries for which you seek damages in this case; and state as to each the
+date of treatment or examination and the injury or condition for which you were
+examined or treated.
+Dr. Serge Thys (Psychiatrist)
+2151 45* Street
+Date: I do not recall the date. I would defer
+to the Doctor's records.
+West Palm Beach, FL. 33407
+(Counselor/Therapist) Date: Since high school. Ongoing.
+Parent Child Center
+2001 W. Blue Heron Boulevard
+List the names and business addresses of all other physicians, medical facilities,
+state as to each the dates of examination or treatment and the condition or injury
+for which you were examined or treated.
+14
+
+
+
+13.
+• 14.
+State the name and address of every person known to you, your agents, or your
+attorneys, who has knowledge about, or possession, custody, or control of, any
+model, plat, map, drawing, motion picture, video tape, or photograph pertaining
+to any fact or issue involved in this controversy; and describe as to each, what
+item such person has, the name and address of the person who took or prepared
+it, and the date it was taken or prepared.
+The FBI has photos taken of me at Jeffrey Epstein's home by
+Jeffrey Epstein had a photo taken of me at his home by
+Please state if you (or parents or guardian on your behalf have ever been a
+party, either plaintiff or defendant, in a lawsuit other than the present matter, and,
+if so, state whether you were plaintiff or defendant, the nature of the action, and
+the date and court in which such suit was filed.
+No
+15.
+address of any individuals who were present in the home with Mr. Epstein and
+you.
+
+
+Case 9:08-cv-80119-KAM Document 147-2 Entered on FLSD Docket 06/08/2009
+
+From May or June of 2002 to August of 2003 | went to Mr. Epstein's home
+on average 2 times a week. There were weeks when I would go 4 times a
+week. All my visit dates were maintained by Jeffrey Epstein and his staff in
+a phone message book kept on a table by the phone in the kitchen.
+Discovery is ongoing.
+16.
+I was introduced to Jeffrey Epstein by my friend
+lugust of 2003.
+Cab, provided by Jeffrey Epstein,
+in 2002. I was to
+(Address will be provided upon receipt)
+17.
+State the amount of monies (or anything else of value, including gifts) you claim
+were given or paid to you by Mr. Epstein (or someone paid/gave you on his
+behalf and that person's name, address and phone number) by year from 2000-
+2006.
+$200-$300 for a massage session at an average of 2 sessions a week from
+May or June of 2002 to August 2003.
+$500 for a photo taken by
+at Jeffrey Epstein's house
+Paid for taxi cabs
+Concert tickets-Incubus, delivered by two girls at the concert
+Clothes and lingerie sent by FedEx
+Book-Massage for Dummies
+CD
+Flowers
+Express gift card
+16
+
+
+
+18.
+List separately the names, addresses and phone numbers of all males, excluding
+Mr. Epstein, with whom you have had sexual activity since age 10 (by year) up
+through your current age. Describe the nature of sexual activity, the date(s) and
+whether you received money or other consideration from the person.
+Objection. Relevance and overbroad.
+19.
+List separately the names, addresses and phone numbers of all males, excluding
+your clalms against Mr. Epstein, whom you have claimed (formally or informally)
+committed sexual assault or battery on you since age 10 (by year) up through
+your current age. Describe the nature of sexual assault or battery, the date(s)
+and whether you received money or other consideration from the person.
+None.
+20.
+State the names, addresses and phone numbers of all males, excluding your
+claims against Mr. Epstein, whom you have claimed (formally or intormally)
+committed lewd or lascivious conduct to you since age 10 (by year) up throug
+our current age. Describe the lewd or lascivious conduct, the date and whethe
+you received money or other consideration from the person.
+None
+21.
+21. State tenant Mr Epees
+State the names, addresses and phone numbers of all males, excluding your
+claims against Mr. Epstein, whom you have claimed (formally or informally)
+committed lewd or lascivious exhibition to you since age 10 (by year) up through
+your current age. Describe the lewd or lascivious exhibition, the date and
+whether you received money or other consideration from the person
+None
+22.
+List in detail all discussions/interviews which you had with any representative
+17
+
+
+Document 147-2 Entered on FLSD Docket 06/08/2009 Page 18 of 20
+from FBI, U.S. Attorneys' Office, State Attorneys' Office (Palm Beach County),
+Palm Beach Sheriff's Office and Palm Beach Police Department regarding your
+meetings with Mr. Epstein. Include dates, who was present, the details of what
+was discussed, whether a court reporter was present and whether a tapeo
+statement was taken or whether you provided a written statement.
+I was interviewed by the FBI and a State Attorney, they have my statement.
+23.
+State the names, addresses, ages, phone numbers and dates of all females
+whom you claim were brought by you to Mr. Epstein's home to give him a
+masain you are pid to rio a teach female e
+state the amount of mone
+Age: 22
+West Palm Beach, FL.
+I was paid $100.00
+24.
+Please list each time you were interviewed by any state or federal law
+enforcement agent or prosecutor, who was present, whether notes were taken,
+and what you recall saying to them.
+I do not recall who interviewed me. This information would be available in
+the FBI and Prosecutors office. They took notes and I was not provided
+with a copy of those notes.
+25. Please describe any statements made to you by any federal or state law
+enforcement agent or prosecutor regarding the availability of civil remedies
+against Mr. Epstein and regarding whether there would be any benefit from you
+oluntary cooperation with law enforcement
+None
+18
+
+
+
+Signature of Answering Party
+STATE OF Florida
+)
+COUNTY OF Palm Beach )
+by
+The foregoing instrument was acknowledged before me this 17_ day of February, 2009
+who is personally known to me or
+who has produced
+(type of identification) as identification and who did/did
+not take an oath.
+Notary Public
+State of Florida at Large
+My Commission expires:
+Commission No:
+alertee
+805 8012
+19
+
+
+
+COUNSEL LIST
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S.
+West Palm Beach, FL 33401
+Phone: 0
+Attorneys for Jeffrey Epstein
+Bruce B. Reinhart, Esquire
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+Attorneys for
+• Robert Critton
+Burman Critton Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL, 33414
+Attorneys for Jeffrey Epstein
+Richard H. Willits, Esquire
+Richard H. Willts, P.A.
+2290 10th Avenue North
+Suite 404
+Lake Worth, FL 33461
+Attorneys for Party
+20
+
+
+
+Plaintiffs),
+JEFFREY EPSTEIN and
+Defendants).
+PLAINTIFF'S INITIAL DISCLOSURE
+COMES NOW the Plaintiff,
+, by and through her undersigned attorneys,
+and hereby files her Initial Disclosure in compliance with the Joint Discovery
+Plan/Scheduling Report dated August 18, 2008, as follows:
+(A) Name and, if known, the address and telephone number of each
+individual likely to have discoverable information that the disclosing party may
+use to support its claim or defenses, unless solely for impeachment, identifying
+the subjects of the information:
+1.
+c/o her attorneys:
+Jack Scarola, Esq. and Jack P. Hill, Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+Richard Wilits, Esq.
+Richard H. Wilits, P.A.
+2290 10th Avenue North, Suite 404
+Lake Worth, FL 33461
+PLAINTIFF'S
+
+Z
+
+
+
+vs. Epstein, et
+ase No.: 08-CV-80811-CIV-MARRA/JOHNSON
+
+Plaintiff.
+Jeffrey Epstein
+c/o his attorneys:
+Robert Critton, Esquire
+Burman Critton Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33414
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South
+West Palm Beach, FL 33401
+Bruce E. Reinhart, Esquire
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+Defendant
+c/o
+'s attorneys:
+Jack Scarola, Esq. and Jack P. Hill, Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+Richard Willits, Esq.
+Richard H. Willits, P.A
+2290 10th Avenue North, Suite 404
+Lake Worth, FL 33461
+I's involvement with Epstein.
+
+
+
+6.
+7.
+(Address unknown)
+Subject matter: Defendant.
+Jane Doe (Case No.: 1:93-cv-01109-KAM)
+c/o her attorney:
+Theodore Leopold, Esquire
+Leopold, Kuvin, P.A.
+2925 P.G.A. Boulevard, Suite 200
+Palm Beach Gardens, FL. 33410
+Victim of Epstein.
+Jane Doe (Case No.: 502008CA020614)
+c/o her attorney:
+Isidro M. Garcia, Esquire
+The Law Office of Brad Edwards & Associates, LLC
+2028 Harrison Street, Suite 202
+Hollywood. El 33020
+Subject matter: Victim of Epstein.
+Jane Doe #2 (Case No.: 9:08-cv-80119-KAM)
+c/o her attornev:
+Jeffrey M. Herman, Esquire
+Herman & Mermelstein, P.A.
+18205 Biscayne Boulevard, Suite 2218
+Miaml. FI 33160
+Victim of Epstein.
+
+
+
+8.
+Jane Doe #3 (Case No.: 9:08-cV-80232-KAM)
+c/o her attorney:
+Jeffrey M. Herman, Esquire
+Herman & Mermelstein, P.A.
+18205 Biscayne Boulevard, Suite 2218
+10.
+11.
+Victim of Epstein.
+Jane Doe #5 (Case No.: 9:08-cV-80381-KAM)
+c/o her attorney:
+Jeffrey M. Herman, Esquire
+Herman & Mermelstein, P.A.
+18205 Biscayne Boulevard, Suite 2218
+Miami, FL 33160
+Victim of Epstein.
+Jane Doe #4 (Case No.: 9:08-cV-80380-KAM)
+c/o her attorney:
+Jeffrey M. Herman, Esquire
+Herman & Mermelstein, P.A.
+18205 Biscayne Boulevard, Suite 2218
+Miami, FL 33160
+Victim of Epstein.
+Jane Doe (Case No.: 9:08-CV-80804-KAM)
+c/o her attorney:
+Theodore Leopold, Esquire
+Leopold, Kuvin, P.A.
+2925 P.G.A. Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Victim of Epstein.
+
+
+Entered on FLSD Docket 06/08/2009 Page 5 of 12
+12.
+Jane Doe #7 (Case No.: 9:08-CV-80993-KAM)
+c/o her attorney:
+Jeffrey M. Herman, Esquire
+13.
+14.
+15.
+16.
+Subject matter: Victim of Epstein.
+(Case No.: 502008CA025129XXXXMB AI
+c/o her attorneys:
+Jack Scarola, Esquire
+Jack P. Hill, Esquire
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+Victim of Epstein.
+Jose Alessi
+(Address unknown at this time)
+Janusa Banasiack
+alm Beach Police Department
+345 South County Roac
+Tain Beach Fl 53480
+Investigator.
+Jeffrey Epstein's Butler.
+Palm Beach County Prosecutors Office
+401 North Dixie Highway
+West Palm Beach, FL 33401
+Prosecutor.
+
+
+
+›ase No.: 08-CV-80811-CIV-MARRA/JOHNSON
+age or a Disclosure
+17.
+Detective
+lead investigator
+Palm Beach Police Department
+345 South County Road
+Palm Beach. FL.33480
+Investigator.
+18.
+19.
+FL 33411-1228
+Former boyfriend of a victim of Epstein.
+Sgt.
+Palm Beach Police Department
+345 South County Road
+Palm Beach, FL 33480
+Investigator.
+20.
+21.
+22.
+Plaintiff's former boyfriend.
+, supervisor
+Sanitation Bureau of the Town of Palm Beach
+3101 N.W. 16" Terrace
+Pompano Beach, FL 33064
+Tel: (877) 46-WASTE
+The indent it is treble mater
+Major
+Palm Beach County Sheriff's Office
+3228 Gun Club Road
+West Palm Beach, FL 3340€
+Investigator.
+!
+
+
+Entered on FLSD Docket 06/08/2009|
+
+Case No.: 08-CV-B0811-CIV-MARRA/JOHNSON
+aintiff's Initial Disclosu
+age 7 of
+23.
+friend of
+(Address will be provided upon receipt)
+Victim and friend of
+24.
+Ghislane Maxwell c/o Ghislane Corp.
+3580 Brillo Way
+Palm Beach, FL 33480
+Associate of Epstein.
+25.-
+26.
+27.
+28.
+Parent Child Center
+West Palm Beach, FL
+Detective
+Palm Beach Police Department
+345 South County Road
+Palm Beach. FL 33480
+Investigator.
+Chief Michael Reiter
+Palm Beach Police Department
+345 South County Road
+Palm Beach Fl 33480
+Counselor at Parent Child Center.
+Investigator.
+29.
+(Address unknown at this time)
+various victims.
+Alfredo Rodriguez
+(Address unknown at this time)
+Employee of Epstein.
+Associate of Epstein who facilitated introductions with
+
+
+Entered on FLSD Docket 06/08/2009|
+
+
+30.
+31.
+32.
+33.
+34.
+35.
+Detective
+Palm Beach Police Department
+345 South County Roac
+Palm Beach, FL 33480
+Investigator
+Esquire
+First Assistant U.S. Attorney
+U.S. Dept. of Justice
+500 South Australian Avenue
+Suite 400
+West Palm Beach, FL 33401
+Federal prosecutor.
+Federal Bureau of Investigation
+505 South Flagler Drive, Suite 500
+West Palm Beach, FL 33401
+Investigator.
+Dr. Thys
+Address will be provided upon receipt
+West Palm Beach
+'s physician.
+Assistant U.S. Attorney
+U.S. Dept. of Justice
+500 South Australian Avenue
+Suite 400.
+West Palm Beach, FL 33401
+Federal prosecutor.
+(Address will be provided upon receipt)
+Friend of C.M.A's mother.
+
+
+Entered on FLSD Docket 06/08/2009 Page 9 of 12
+Page 9or i22al Disclosure
+36.
+(Address will be provided upon receipt)
+Friend of
+.'s mother
+37.
+(Address will be provided upon receipt)
+Potential victim and friend of
+38.
+(Address unknown at this time)
+Associate of Epstein who may have been involved in
+encounters between Epstein and
+(B) A copy of, or description by category and location of, all documents, data
+compilations, and tangible things that are in the possession, custody or control
+of the party and that the disclosing party may use to support its claim or
+defenses, unless solely for impeachment:
+¡Der
+Pite No
+Marked
+Objec. Marked
+Counsel tion
+in Evid
+3
+4
+5
+8
+7
+Description of Exhibit
+Visitation Log
+Any deposition in any other case involving
+molestation allegations against Jeffrey
+Epstein
+U.S. Department of Justice's complete file,
+records and evidence
+Federal Bureau of Investigation's complete
+file, records and evidence
+Palm Beach County Sheriff's Office's
+complete file, records and evidence
+Palm Beach County Prosecutor's
+complete file, records and evidence
+Palm Beach Police Department's complete
+file, records and evidence
+Palm Beach Police Department Probable
+Cause Affidavits
+!
+
+
+Entered on FLSD Docket 06/08/2009 Page 10 of 12
+
+(C) A computation of any category of damages claimed by the disclosing party,
+making available for inspection and copying as under Rule 34 the documents or
+other evidentiary material, not privileged or protected from disclosure, on which
+such computation is based, including materials bearing on the nature and extent
+of injuries suffered:
+All damages recoverable for personal injury under Florida law including the following:
+suffered bodily injury;
+pain and suffering;
+disability;
+disfigurement;
+mental anguish;
+loss of the capacity for the enjoyment of life; and
+Medical and nursing care and treatment.
+The economic damages have not yet been calculated. The noneconomic damages are
+for the jury's determination.
+Statutory damages pursuant to 18 USCA §2255.
+Punitive damages.
+(D) for inspection and copying as under Rule 34 any insurance agreement under
+which or a proment inchmay oranteen the national anyone
+reimburse for payment made to satisfy the judgment." Fed.R.Civ.P.26(a):
+Plaintiff is unaware of any applicable insurance policies. Discovery is ongoing.
+
+
+Entered on FLSD Docket 06/08/2009 Page 11 of 12
+. vs. Epstein, et al
+case No.: 08-CV-80811-CIV-MARRA/JOHNSON
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
+U.S. Mail to all counsel on the attached list, this 2nd day of February, 2009.
+All l be
+Searcy: Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Attorneys for Plaintiff
+
+
+
+1. vs. Epstein, et al.
+SERVICE LIST
+Richard H. Wilts, Esquire
+Richard H. Willits, P.A.
+2290 10th Avenue North, Suite 404
+Lake Worth, FI. 33461.
+Robert Critton, Esquire
+Burman Critton Luttier & Coleman LLP
+Ses Pain Eagler DiVe, Suite 400
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South
+West Palm Beach. FL 33401
+Bruce E. Reinhart, Esquire
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue
+Suite 1400
+West Palm Beach. Fl. 33401
+
+
+. Case 9:08-Cv-80119-KAM Document 141
+Entered on FLSD Docket 06/05/2009 Page 1 of 6
+CASE NO.: 08-cv-80119-MARRA/JOHNSON
+JANE DOE NO. 2,
+JANE DOE NO. 3,
+CASE NO.: 08-CV-80232-MARRA/JOHNSON
+Vs.
+CASE NO.: 08-CV-80380-MARRA/JOHNSON
+JANE DOE NO. 4,
+
+
+Case 9:08-cv-80119-KAM Document 141|
+Entered on FLSD Docket 06/05/2009 Page 2 of 6
+JANE DOE NO. 5,
+J
+CASE NO.: 08-80994-CIV-MARRA/JOHNSON
+JANE DOE NO. 6,
+J
+CASE NO.: 08-80993-CIV-MARRA/JOHNSON
+JANE DOE NO. 7,
+J
+CASE NO.: 08-80811-CIV-MARRA/JOHNSON
+
+
+Case 9:08-CV-80119-KAM Document 141 Entered on FLSD Docket 06/05/2009 Page 3 of 6
+JEFFREY EPSTEIN et al,
+Defendants.
+CASE NO.: 08-80893-CIV-MARRA/JOHNSON
+/
+DOE II,
+CASE NO.: 09-80469-CIV-MARRA-JOHNSON
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+CASE NO.: 09-80591-CIV-MARRA-JOHNSON
+JANE DOE NO. 102,
+CASE NO.: 09-80656-CIV-MARRA/JOHNSON
+NOTICE OF SUPPLEMENTAL AUTHORITY IN CONNECTION
+WITH DEFENDANT'S VARIOUS MOTIONS TO COMPEL
+AND REPLIES THERETO
+
+
+Document 141
+
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his
+undersigned attorneys, hereby gives notice of his intent to rely on the following case as
+supplemental authority in connection with the above referenced Motions to Compel and
+Replies thereto:
+Doe v. Evans, 202 F.R.D. 173, 176 (E.D. P.A. 2001) (denying protective
+order where alleged sexual assault victim did not demonstrate a serious specific injury
+and allowing Defendants to identify Plaintiff in discovery because holding otherwise
+would "chill defendants ability to conduct discovery").
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is
+being served this day on all counsel of record identified on the following Service List in
+the manner specified by CECE on this 5 day of _une, 2009
+ROBERT D. CRITTON. JR., ESQ.
+Florida Bar No.
+MICHAEL J. PIKE, ESQ.
+Florida Bar
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+
+
+Case 9:08-cv-80119-KAM Document 141 Entered on FLSD Docket 06/05/2009 Page 5 of 6
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/JOHNSON
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Miami, FL 33160
+Brad Edwards, Esq.
+Rothstein Rosenfeldt Adler
+401 East Las Olas Boulevard
+Suite 1650
+Fort Lauderdale, FL 33301
+Counsel for Plaintiff in Related Case No.
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119,
+08-80232, 08-80380, 08-80381, 08-80993,
+Paul G. Cassell, Esq.
+08-80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Salt Lake City, UT 84112
+Richard H. Willits, P.A.
+2290 10* Avenue North
+Suite 404
+Lake Worth, FL 33461
+Co-counsel for Plaintiff Jane Doe
+Isidro M. Garcia, Esq.
+Counsel for Plaintiff in Related Case No.
+Garcia Law Firm, P.A.
+08-80811
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+Jack Scarola, Esq.
+Jack P. Hill, Esq.
+Counsel for Plaintiff in Related Case No.
+Searcy Denney Scarola Barnhart & Shipley, 08-80469
+P.A.
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+Counsel for Plaintiff,
+Counsel for Plaintiffs in Related Cases
+
+
+Case 9:08-cv-80119-KAM Document 141
+Entered on FLSD Docket 06/05/2009 Page 6 of 6
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Ricci-Leopold, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+Counsel for Plaintiff in Related Case No.
+08-08804
+Nos. 09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+
+
+. Case 9:08-Cv-80119-KAM Document 141
+Entered on FLSD Docket 06/05/2009 Page 1 of 6
+CASE NO.: 08-cv-80119-MARRA/JOHNSON
+JANE DOE NO. 2,
+JANE DOE NO. 3,
+CASE NO.: 08-CV-80232-MARRA/JOHNSON
+Vs.
+CASE NO.: 08-CV-80380-MARRA/JOHNSON
+JANE DOE NO. 4,
+
+
+Case 9:08-cv-80119-KAM Document 141|
+Entered on FLSD Docket 06/05/2009 Page 2 of 6
+JANE DOE NO. 5,
+J
+CASE NO.: 08-80994-CIV-MARRA/JOHNSON
+JANE DOE NO. 6,
+J
+CASE NO.: 08-80993-CIV-MARRA/JOHNSON
+JANE DOE NO. 7,
+J
+CASE NO.: 08-80811-CIV-MARRA/JOHNSON
+
+
+Case 9:08-CV-80119-KAM Document 141 Entered on FLSD Docket 06/05/2009 Page 3 of 6
+JEFFREY EPSTEIN et al,
+Defendants.
+CASE NO.: 08-80893-CIV-MARRA/JOHNSON
+/
+DOE II,
+CASE NO.: 09-80469-CIV-MARRA-JOHNSON
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+CASE NO.: 09-80591-CIV-MARRA-JOHNSON
+JANE DOE NO. 102,
+CASE NO.: 09-80656-CIV-MARRA/JOHNSON
+NOTICE OF SUPPLEMENTAL AUTHORITY IN CONNECTION
+WITH DEFENDANT'S VARIOUS MOTIONS TO COMPEL
+AND REPLIES THERETO
+
+
+Document 141
+
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his
+undersigned attorneys, hereby gives notice of his intent to rely on the following case as
+supplemental authority in connection with the above referenced Motions to Compel and
+Replies thereto:
+Doe v. Evans, 202 F.R.D. 173, 176 (E.D. P.A. 2001) (denying protective
+order where alleged sexual assault victim did not demonstrate a serious specific injury
+and allowing Defendants to identify Plaintiff in discovery because holding otherwise
+would "chill defendants ability to conduct discovery").
+Certificate of Service /
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is
+being served this day on all counsel of record identified on the following Service List in
+the manner specified by CIECE on this 5 day of une, 2009
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No.
+MICHAEL J. PIKE, ESQ.
+Florida Bar tune
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+
+
+Case 9:08-cv-80119-KAM Document 141 Entered on FLSD Docket 06/05/2009 Page 5 of 6
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/JOHNSON
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Miami, FL 33160
+Brad Edwards, Esq.
+Rothstein Rosenfeldt Adler
+401 East Las Olas Boulevard
+Suite 1650
+Fort Lauderdale, FL 33301
+Counsel for Plaintiff in Related Case No.
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119,
+08-80232, 08-80380, 08-80381, 08-80993,
+Paul G. Cassell, Esq.
+08-80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Salt Lake City, UT 84112
+Richard H. Willits, P.A.
+2290 10* Avenue North
+Suite 404
+Lake Worth, FL 33461
+Co-counsel for Plaintiff Jane Doe
+Isidro M. Garcia, Esq.
+Counsel for Plaintiff in Related Case No.
+Garcia Law Firm, P.A.
+08-80811
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+Jack Scarola, Esq.
+Jack P. Hill, Esq.
+Counsel for Plaintiff in Related Case No.
+Searcy Denney Scarola Barnhart & Shipley, 08-80469
+P.A.
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+Counsel for Plaintiff,
+Counsel for Plaintijs in Related Cases
+
+
+Case 9:08-cv-80119-KAM Document 141
+Entered on FLSD Docket 06/05/2009 Page 6 of 6
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Ricci-Leopold, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+Counsel for Plaintiff in Related Case No.
+08-08804
+Nos. 09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/b1f47845ecf6380791d17503e4c42ea755d27d864649ecb28dea9f8fcbafaaa5.receipt.json b/vision-fixhub/ds9-unparsed-05/b1f47845ecf6380791d17503e4c42ea755d27d864649ecb28dea9f8fcbafaaa5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3cf6da944129777cfbf23e666d8e42d3ad836ace
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b1f47845ecf6380791d17503e4c42ea755d27d864649ecb28dea9f8fcbafaaa5.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -29476,
+  "dataset": "marble-joined",
+  "doc_id": "b1f47845ecf6380791d17503e4c42ea755d27d864649ecb28dea9f8fcbafaaa5",
+  "engine": "marble-apple-vision",
+  "event_count": 1038,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "3b9c18db068509ec70337fab2c7eb4f8f00142ec977a436b4aa5ed1d64543df4",
+  "output_sha256": "abbd64b97237a77fd70ac1bb4b03df8df4f6e9345988a923070a374f47ab4b77",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b1f91aeeb6ab509754689443d11bc79fe7bcbaa9b7dc38523794169771d2d4d7.md b/vision-fixhub/ds9-unparsed-05/b1f91aeeb6ab509754689443d11bc79fe7bcbaa9b7dc38523794169771d2d4d7.md
new file mode 100644
index 0000000000000000000000000000000000000000..6e8d5ff07277104831d9b9353ffed0d5a69a3e18
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b1f91aeeb6ab509754689443d11bc79fe7bcbaa9b7dc38523794169771d2d4d7.md
@@ -0,0 +1,116 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 S. Australian Ave, Ste 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+November 21, 2008
+DELIVERY BY ELECTRONIC MAIL
+Jay P. Lefkowitz, Esq.
+Kirkland & Ellis LLP
+Citigroup Center
+New York, New York 10022-4675
+Roy Black, Esq.
+Black Srebnick Kornspan & Stumpf P.A.
+Miami, FL 33131
+Jack A. Goldberger, Esq.
+Atterbury. Goldberger & Weiss. P.A.
+250 Australian Ave S
+West Palm Beach, FL 33401-5015
+Re: Jeffrey Epstein
+Dear Jay, Roy, and Jack:
+Yesterday I learned that Mr. Epstein applied for and was admitted to the Palm Beach
+County Sheriff's Office's work release program and that he has been on work release for the
+past few weeks. Forthe following reasons, the Office believes that Mr. Epstein's application
+to the work release program violates the Non-Prosecution Agreement. Accordingly, we ask
+that Mr. Epstein withdraw his application to participate in the program and complete his
+eighteen-month term of imprisonment in accordance with the Non-Prosecution Agreement.
+The Non-Prosecution Agreement provides that Epstein "shall be sentenced to
+consecutive terms of twelve (12) months and six (6) months in county jail for all charges,
+
+
+JAY P. LEFKOWITZ, ESQ.
+ROY BLACK, ESQ.
+JacK GolDBergeR, Esq.
+
+without any opportunity for withholding adjudication or sentencing, and probation or
+community control in lieu of imprisonment." I have more than a dozen e-mails between
+myself and Mr. Lefkowitz discussing the U.S. Attorney's insistence on eighteen months of
+incarceration. You will recall that at one meeting you raised the idea of Mr. Epstein hiring
+Sheriff's Deputies to guard him as equivalent to imprisonment. Mr. Acosta specifically
+rejected that suggestion. It is our understanding from the Sheriff's Office that Mr. Epstein
+is paying off-duty Sheriff's Deputies to guard him while he "works" at Mr. Goldberger's
+office each day.
+As you remember, shortly before Mr. Epstein's change of plea, Mr. Goldberger sent
+me a copy of the proposed plea agreement with the state. On June 27, 2008, I sent a letter
+containing the following language to Messrs. Black and Goldberger:
+The U.S. Attorney's Office hereby provides Notice that the proposed sentencing
+provision does not comply with the terms of the Non-Prosecution Agreement.
+The second sentencing paragraph of the proposed plea agreement reads:
+On 08CF009381AMB, the Defendant is sentenced to 18 months Community Control
+1 (one). As a special condition of this Community Control, the Defendant must
+serve the first 6 months in the Palm Beach County Detention Facility ...
+The Non-Prosecution Agreement specifically provides:
+Epstein shall be sentenced to consecutive terms of twelve (12) months and six (6)
+months in county jail for all charges, ... without probation or community control in
+lieu of imprisonment.
+Thus, the proposed plea agreement with the State Attorney's Office does not comply
+with the terms of the Non-Prosecution Agreement. To comply with the Agreement,
+Mr. Epstein must make a binding recommendation of eighteen months imprisonment,
+which means confinement twenty-four hours a day at the County Jail, and the judge
+must accept that recommendation. Community control must follow that term of
+incarceration.
+(Emphasis in original.)
+As I specified in that letter, the Non-Prosecution Agreement calls for "confinement
+
+
+JAY P. LEFKOWITZ, EsQ.
+JacK GolDBERgER, Esq.
+
+twenty-four hours a day." In response to that letter, Mr. Goldberger agreed that he would
+I also discussed the situation and he made clear that Mr. Epstein would not be asking for or
+receiving work release and would remain in jail "around the clock."
+In early August,
+and I raised the issue with Mr. Black when we heard
+that Mr. Epstein was considering applying for work release. On August 6, 2008, Ms.
+Atkinson and I had a conference call with Mr. Black wherein he again stated that Mr. Epstein
+would not apply for or receive work release and would spend his eighteen months
+incarcerated twenty-four hours a day at the Palm Beach County Stockade.
+In preparation for this letter, I obtained a certified copy of Mr. Epstein's state court
+file. On June 30, 2008, on the procurement of minors charge, Judge Pucillo entered the
+following sentence:
+The defendant is hereby committed to the custody of the Sheriff of Palm Beach
+County, Florida for a term of 6 mos. It is further ordered that the Defendant
+shall be allowed a total of 1 days [sic] as credit for time incarcerated prior to
+imposition of this sentence. It is further ordered that the composite term of all
+sentences imposed for the counts specified in the order shall run consecutive
+to the following: Specific sentences: 2006CF9454AXX.
+.. the following provisions apply to the sentence imposed: ... Followed b
+period of 12 mos on community control 1 under the supervision of th
+Department of Corrections ....
+As I learned today when I received the state court file, you neglected to inform our
+Office that, on July 21, 2008, Judge McSorley modified the judgment nunc pro tune to an
+"Order of Community Control I." This same language was the basis for the objection in my
+letter of June 26, 2008 and directly contradicts the language of the Non-Prosecution
+Agreement. I also note that, on the state plea agreement, Mr. Goldberger did not insert the
+word "imprisonment" as agreed prior to the change of plea, instead the words "jail sentence"
+are included.
+The Office's Agreement not to prosecute Mr. Epstein was based upon its
+
+
+JAY P. LEFKOWITZ., ESQ.
+JACK GOLDBERGER, EsQ.
+
+determination that eighteen months' incarceration (i.e., confinement twenty-four hours a day)
+was sufficient to satisfy the federal interest in Mr. Epstein's crimes. Accordingly, the U.S
+Attorney's Office hereby gives notice that Mr. Epstein has violated the Non-Prosecution
+Agreement by failing to remain incarcerated twenty-four hours a day for the eighteen month
+term of imprisonment.
+Sincerely,
+R. Alexander Acosta
+United States Attorney
+By:
+Assistant United States Attorney
+CC:
+1. Chief, Northern Division
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/b1f91aeeb6ab509754689443d11bc79fe7bcbaa9b7dc38523794169771d2d4d7.receipt.json b/vision-fixhub/ds9-unparsed-05/b1f91aeeb6ab509754689443d11bc79fe7bcbaa9b7dc38523794169771d2d4d7.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0c4d194f46b575fc6b2942eb81df2acc7af292e4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b1f91aeeb6ab509754689443d11bc79fe7bcbaa9b7dc38523794169771d2d4d7.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -168,
+  "dataset": "marble-joined",
+  "doc_id": "b1f91aeeb6ab509754689443d11bc79fe7bcbaa9b7dc38523794169771d2d4d7",
+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "1553052decfb80b97586789b3ad6adbbee652d47e8e89bc7030776139451f299",
+  "output_sha256": "c0f7b2889de5f403cac2ee0c1a3d019eab59052cf5790e4d2ab7943115888a6e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b27367d2e67e0424a3ac77492c69de1b68a15636be2e01eac4f1c11c34d21ac6.md b/vision-fixhub/ds9-unparsed-05/b27367d2e67e0424a3ac77492c69de1b68a15636be2e01eac4f1c11c34d21ac6.md
new file mode 100644
index 0000000000000000000000000000000000000000..0732c31ab22d3f34bb3b4181dab2c45314b949ca
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b27367d2e67e0424a3ac77492c69de1b68a15636be2e01eac4f1c11c34d21ac6.md
@@ -0,0 +1,73 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 E. Broward Boulevard, 7th Floor
+Ft. Lauderdale, FL 33394
+(954) 356-7255
+July 7, 2009
+DELIVERY BY ELECTRONIC MAIL
+Jay P. Lefkowitz, Esq.
+Kirkland & Ellis LLP
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4675
+Re:
+Jeffrey Epstein
+Dear Jay:
+Thank you for your letters of June 19th. From your letters, it appears that you have
+misconstrued the Office's past efforts at alleviating Mr. Epstein's unfounded fears of
+disparate treatment. You seem to have interpreted those efforts as either: (1) an
+acknowledgement of the validity of those fears, or (2) an acquiescence to the efforts of Mr.
+Epstein to avoid the full terms of the Non-Prosecution Agreement. So, for example, you
+write that, in an email to Mr. Acosta, you "confirmed that there were significant
+irregularities with the deferred prosecution agreement,"" and that "Mr. Acosta agreed to
+many of our objections and adopted several of our modifications ... [and] [t]his fact
+confirms both the good-faith nature of our objections and that neither Mr. Epstein nor his
+counsel could be considered to have violated the NPA by raising those objections in the first
+place." Neither your e-mails nor Mr. Acosta's consistent attempts to maintain a good
+working relationship with you act as modifications to the NPA or indications that the Office
+agreed or acquiesced to your positions.
+While your letter provides great detail regarding all of the objections that you raised'
+'In an effort to terminate the endless "battle of letters" that this case has become, I have
+elected not to detail each and every misstatement in your ten-page letter, but please do not mistake
+that for an agreement with those misstatements. One of those misstatements, however, begs for
+correction. You write: 'Indeed, due to a concern we had raised, your Office specifically modified
+the procedure to select an attorney representative and delegated that task to Judge Davis. Again, the
+
+
+JaY P. LEFKOWITZ, ESQ.
+JULY 7, 2009
+
+throughout the nine-month delay between the signing of the NPA and Mr. Epstein's
+commencement of performance, you neglect to mention that all of your objections were
+soundly rejected at each and every level of review, from West Palm Beach, to Miami, to the
+Child Exploitation and Obscenity Section, and, finally, to the highest levels of review at the
+Department of Justice. As Senior Associate Deputy Attorney General
+h stated:
+Even if we were to substitute our judgment for that of the U.S. Attorney, we
+believe that federal prosecution of this case is appropriate. Moreover, having
+reviewed your allegations of prosecutorial misconduct, and the facts
+underlying them, we see nothing in the conduct of the U.S. Attorney's Office
+that gives us any reason to alter our opinion.
+With regard to your proposal to engage in additional discussions regarding the scope
+of the NPA, we respectfully decline. A great deal of time and effort went into the negotiation
+and signing of the NPA, and the Agreement speaks for itself. Contrary to your assertion,
+both the government and the victims have suffered harm and prejudice due to the willful
+breaches of the NPA by Mr. Epstein. The Office will continue to evaluate its position and
+will proceed accordingly.
+Sincerely,
+Jeffrey H. Sloman
+Acting United States Attorney
+By:
+Assistant United States Attorney
+CC:
+1. Chief, Northern Division
+Jack Goldberger, Esq.
+Roy Black, Esq.
+fact that your Office accommodated our concerns validated their legitimacy..." As you have been
+told repeatedly, the decision to delegate that task to a Special Master was made independently and
+efore any of Mr. Epstein's attorneys voiced a concern about that process. Mr. Lefkowitz, you wen
+rovided with a list of potential attorney representatives and with information in writing regarding
+the alleged "conflict of interest," and you made the selection that you later claimed was problematic.
+Notwithstanding your agreement on the selection of the attorney-representative, our Office,
+independently, elected to ask an independent third party to make the final decision.
diff --git a/vision-fixhub/ds9-unparsed-05/b27367d2e67e0424a3ac77492c69de1b68a15636be2e01eac4f1c11c34d21ac6.receipt.json b/vision-fixhub/ds9-unparsed-05/b27367d2e67e0424a3ac77492c69de1b68a15636be2e01eac4f1c11c34d21ac6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..04c4602c711174e1ec6513d301c3719157fec7a9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b27367d2e67e0424a3ac77492c69de1b68a15636be2e01eac4f1c11c34d21ac6.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -35,
+  "dataset": "marble-joined",
+  "doc_id": "b27367d2e67e0424a3ac77492c69de1b68a15636be2e01eac4f1c11c34d21ac6",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "0f06d28fac386b7f15a81fa69a522b308ce966c6db898e04c2bf4c50cdfafde8",
+  "output_sha256": "e1fc9d72d6c2e7bbcedf14b8f7b09a2969a524eab162f2f77904a2c4250335b5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b2e53f0567a9816ff9fedf94564a5d000625f026c12613790ea2a7e3b42cbe51.md b/vision-fixhub/ds9-unparsed-05/b2e53f0567a9816ff9fedf94564a5d000625f026c12613790ea2a7e3b42cbe51.md
new file mode 100644
index 0000000000000000000000000000000000000000..8b460cc0eb2337d4fd0fcfbf3b3da9a158f17222
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b2e53f0567a9816ff9fedf94564a5d000625f026c12613790ea2a7e3b42cbe51.md
@@ -0,0 +1,5230 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.
+CIV-MARRA/JOHNSON
+JANE DOE,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN, et al.,
+Defendants.
+¿ Casaci
+VIDEOTAPED DEPOSITION OF
+TAKEN ON BEHALF OF THE PLAINTIFF
+DATE: April 13, 2010
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+N H
+3
+5
+8
+9
+10
+11
+12
+13
+14
+17
+18
+119
+20
+21
+22
+23
+24
+25
+2
+April 13, 2010
+INDEX
+WITNESS
+DIRECT CROSS REDIRECT RECROSS 3
+4
+BY MR. EDWARDS
+BY MR. HOROWITZ
+BY MR. LANGINO
+BY MS. EZELL
+5
+98
+65
+77
+81
+EXHIBITS
+PLAINTIFFS
+FOR IDENTIFICATION
+10
+PAGE
+/ Message dated August 21, 2005.
+45
+13
+20
+21
+22
+23
+24
+The videotaped deposition of
+in the above-entitled and numbered
+cause, was taken before me, TERRI BECKER, a
+Registered Professional Reporter and Notary
+Public for the State of Florida at Large, at 444
+West Railroad Avenue, in the City of West Palm
+Beach, Palm Beach County, in the State of
+Florida, beginning at the hour of 10:00 o'clock
+a.m., pursuant to the Notice in said cause for
+the taking of said deposition which is annexed to
+the court file herein, on behalf of the PLAINTIFF
+in the above-entitled action pending in the
+above-named court.
+The appearances at said time and place
+were as follows
+FARMER, JAFFE, WEISSING, EDWARDS,
+FISTOS & LEHRMAN, PL
+Attorneys for Plaintiffs Jane Does,
+L.N. and E.W.
+425 North Andrews Avenue
+Suite 2
+Fort Lauderdale, Florida 33301
+Tel: (954) 524-2820
+BY: BRADLEY J. EDWARDS, ESQ.
+MERMELSTEIN & HOROWITZ, P.A.
+Attomeys for Plaintiffs Jane Does,
+numbers 2 through 8
+18205 Biscayne Boulevard
+Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+BY: ADAM D. HOROWITZ, ESQ.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+17
+18
+20
+21
+22
+23
+24
+25
+4
+PPEARANCES (CONTINUED
+LEOPOLD-KUVIR
+Attorneys for Maintits
+25 PGA Boulevard, Suite 20
+alm Beach Garlens, Florida 3341
+Tel: (561) 515-1-406
+TY: ADAM J. LANGINO, ESQ
+PODHURST, ORSECK
+BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
+303 Bany a Brier, Suite pairing
+West Palm Beach, Florida 33401
+V: DAVID YAREMA, ES
+OBERT CRITTON, ES
+ATTERBURY, GOLDBERGER & WEISS
+Co-Counsel for Defendants
+One Clearlake Centre
+SVest Palm Beach, Florida 33401
+Tel: (561) 659-8300
+BY: JACK A. GOLDBERGER, ESQ.
+ALSO PRESENT:
+(U.S. Legal)
+5
+THEREUPON,
+being by Terri Becker first duly sworn to tell
+the whole truth, as hereinafter certified,
+testified as follows:
+DIRECT EXAMINATION
+BY MR. EDWARDS:
+Q Can you tell us your name.
+Q What is your date of birth?
+A February 21, 1985.
+Q What is your Social Security number?
+A Under advice of my counsel, I invoke my
+privileges under the Fifth and Sixth Amendments
+to the United States Constitution and
+respectfully decline to answer the question.
+Q Where were you born?
+A I'm sorry, though I would like to answer
+your question, 1 must invoke my Fifth and Sixth
+Amendment privileges and refuse to answer your
+questions.
+Q What is your current address?
+MR. GOLDBERGER: There is going to be a
+continued, obviously, you anticipate I'm
+sure, continued invocation of Fifth
+2 (Pages 2 to 5)
+
+
+1
+2
+3
+5
+6
+7
+9
+10
+11
+112
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+116
+17
+18
+19
+20
+21
+24
+25
+6
+8
+Amendment privileges. If it is okay with
+all counsel, to shorten things, l'll simply
+have the witness say "Fifth," if that
+satisfies everyone's interest.
+MR. EDWARDS: That is fine with me.
+MR. GOLDBERGER: Okay, with that Cathy?
+MS. EZELL: Yes.
+MR. HOROWITZ: Yes.
+Q I'Il reask the question, what's your
+current address?
+A Fifth.
+Q Are you currently living at 358 El
+Brillo Way with a man named Jeffrey Epstein?
+A The Fifth.
+Q Are you also familiar with an address in
+New York, 301 East 66th Street?
+A The Fifth.
+Q When Mr. Epstein was incarcerated in
+jail, you went to visit him on numerous
+occasions; is that correct?
+MR. YAREMA: Objection.
+A The Fifth.
+Q When you went to visit him you indicated
+to jail personnel your address was 301 East 66th
+Street, apartment 8-D in New York City, New York; 25
+is that correct?
+MR. YAREMA: Objection.
+A Fifth.
+Q Isn't it true when Mr. Epstein was in
+jail, you visited him on more than 50 occasions?
+MR. YAREMA: Form objection.
+Q True?
+A The Fifth.
+Q How long have you been in the United
+States, Ms.
+A The Fifth.
+Q Who brought you to the United States?
+MR. YAREMA: Form objection.
+A The Fifth.
+Q What is your current status in this
+country?
+A The Fifth.
+MR. YAREMA: Form objection.
+MR. GOLDBERGER: Let me take a half a
+second.
+(Witness and her counsel confer.)
+Q Are you a U.S. citizen?
+A The Fifth.
+Q What type of visa are you here on?
+MR. YAREMA: Form objection.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+7
+- N
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+18
+19
+20
+21
+22
+23
+24
+25
+A The Fifth.
+Q Do you know a lady by the name of
+A The Fifth.
+• Is this somebody who helped to falsify a
+visa for you?
+MR. YAREMA: Object to the form.
+A The Fifth.
+Q Do you knor
+A The Fifth.
+Q Were you ever a working model in the
+United States?
+A The Fifth.
+Q Can you tell us your parents' names?
+A The Fifth.
+Q How is it that you have supported
+yourself financially, since you have been in this
+country?
+MR. YAREMA: Object to the form.
+A The Fifth.
+Q Have you supported yourself financially?
+A The Fifth.
+Q What is the last grade you completed in
+school?
+A The Fifth, I take the Fifth Amendment.
+9
+Q Are you in school now?
+A The Fifth.
+Q Have you ever attended any school in the
+United States?
+A The Fifth.
+Q Have you ever been employed since
+residing in the United States?
+A The Fifth.
+Q Is Jeffrey Epstein your sole means of
+financial support today?
+MR. YAREMA: Object to the form.
+A The Fifth.
+Q Since coming to this country, hasn't
+Jeffrey Epstein always been your sole means of
+financial support?
+MR. YAREMA: Object to the form.
+A The Fifth.
+Q How much does Jeffrey Epstein pay you
+today?
+MR. YAREMA: Object to the form.
+A The Fifth.
+Q What does every Epstein pay you for?
+MR. YAREMA: Object to the form.
+A The Fifth.
+Q Does he pay you specifically to be his
+3 (Pages 6 to 9)
+
+
+1
+2
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+10
+12
+sex slave?
+MR. YAREMA: Object to the form.
+A The Fifth.
+Q Are you aware that the reports about you
+indicate that you were brought to the United
+States by Jeffrey Epstein when you were roughly
+13 or 14 years old to be his Yugoslavian lesbian
+sex slave?
+MR. YAREMA: Object to the form.
+A The Fifth.
+Q Is that true?
+MR. YAREMA: Object to the form.
+A The Fifth.
+Q Have you performed any services for
+Jeffrey Epstein aside from being his sex slave?
+MR. YAREMA: Object to the form.
+A The Fifth.
+Q What is your sexual orientation?
+MR. YAREMA: Object to the form.
+MR. GOLDBERGER: I'm going to instruct
+the witness not to answer that question. It
+serves no purpose other than to harass or
+intimidate her, so in addition to Fifth
+Amendment privileges, I'm objecting on
+privacy grounds.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+11
+A I take the Fifth.
+Q
+I represent a lady named, a young female
+names
+you know who that is, right?
+MR. YAREMA: Object to the form.
+A The Fifth.
+1
+2
+3
+4
+5
+Q Jeffrey Epstein made you have sex with
+I didn't he?
+MR: YAREMA: Object to the form.
+A The Filth.
+Q You did, in fact, engage in sexual
+activity with
+when she was only 16 years
+old; isn't that true?
+MR. YAREMA: Object to the form.
+A The Fifth.
+Q Back to my original question: And I'll
+ask you this way: Do you consider yourself
+heterosexual, bi-sexual, or can you answer tha
+question?
+MR. YAREMA: Object to the form.
+MR. GOLDBERGER: Same objection. Do not 20
+answer the question.
+A Fifth.
+Q How did you meet Jeffrey Epstein?
+A Fifth.
+Q When did you become one of Jeffrey
+7
+8
+9
+10
+11
+112
+13
+114
+15
+16
+17
+18
+19
+21
+22
+23
+24
+25
+Epstein's sex slaves?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q What does it mean to be Jeffrey
+Epstein's sex slave?
+MR. YAREMA: Object to the form.
+A Filth.
+Q Are you aware that Jeffrey Epstein reads
+books on how to be a proper master to his sex
+slave?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q What has Jeffrey Epstein done to train
+you to be his ses slave?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q What do your parents think about you
+being Jeffrey Epstein's sex slave?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q When did you first learn that Jeffrey
+Epstein had a sexual obsession for underage minor
+females?
+MR. YAREMA: Object to the form.
+A Fifth.
+13
+Q How many times has Jeffrey Epstein made
+you have sex with underage minor females?
+MR. YAREMA: Object to the fonn.
+A Fifth.
+Q Do you enjoy sex with underage minor
+females?
+MR. YAREMA: Object to the forn.
+A Fifth.
+Q What is the youngest child that Jeffrey
+Epstein has forced you to have sex with?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Does Jeffrey Epstein today still make
+you have sex with underage minor females?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q How many underage minor females has
+Jeffrey Epstein made you have sex with, since you
+were over the age of 18?
+MR. YAREMA: Object to the form.
+A The Fifth.
+Q Prior to turning 18, is it true that
+Jeffrey Epstein made you have sex with many other
+children in kid-type orgies?
+MR. YAREMA: Object to the form.
+4 (Pages 10 to 13)
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+I11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+14
+16
+A Fifth.
+Q Has Jeffrey Epstein also made you
+perform sexually on his friends?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you know David Copperfield?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Have you ever been made to perform
+sexually on David Copperfield?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you know Prince Andrew?
+A Fifth.
+Q Have you ever been made to perform
+sexually on Prince Andrew?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q When was the first time that you knew
+Jeffrey Epstein molested underage girls?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did Jeffrey Epstein molest you when you
+were underage?
+MR. YAREMA: Object to the form.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+15
+A Fifth.
+Q I'm assuming you understand why you're
+here today, correct?
+MR. YAREMA: Object to the form.
+A The Fifth.
+Q For allegations related to Jeffrey
+Epstein interacting sexually with numerous
+underage minor females; that's something you
+know, right?
+MR. YAREMA: Object to the formn.
+A The Fifth.
+Q That's something in addition to the
+civil lawsuits, there were criminal cases
+involving the same conduct, correct?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q You were a part of that criminal
+investigation, in fact, you were a co-conspirator
+of Jeffrey Epstein's; is that right?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q What crimes did you conspire to commit
+with Jeffrey Epstein against underage minor
+females?
+MR. YAREMA: Object to the form.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A Fifth.
+Q Have you read the nonprosecution
+agreement between the government and Jeffrey
+Epstein?
+A Fifth.
+Q Are you aware that inside that document
+you are labeled as a co-conspirator of his crimes
+against children?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Isn't it true that your role was to lure
+or procure underage minor females to Jeffrey
+Epstein for him to molest, correct?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q You also scheduled appointments for
+Jeffrey Epstein, so there would be designated
+times for Jeffrey Epstein to molest underage
+minor females, correct?
+MR. YAREMA: Object to the form.
+A The Fifth.
+Q As well, you participated in various sex
+nets with underage minor females, thus molesting
+them yourself; is that correct?
+MR. YAREMA: Object to the form.
+17
+A Fifth.
+Q Do you understand that Jeffrey Epstein's
+interaction with underage minor females is
+illegal? Do you understand that?
+MR. YAREMA: Object to the form.
+A The Fifth.
+Q Do you understand that the Lewd and
+Lascivious Molestation Statute in Florida
+indicates a person who intentionally touches in a
+lewd or lascivious manner, the breasts, genital
+area or buttocks, or the clothing covering them,
+of a person less than 16 years of age, or forces
+or entices a person under 16 years of age, to so
+touch the perpetrator, commits lewd or lascivious
+molestation? Are you aware of that statute?
+A Fifth.
+Q That is a statute that you know Jeffrey
+Epstein to have violated; is that true?
+MR. YAREMA: Object to the form.
+A The Fifth.
+Q That's a statute that you yourself have
+violated; is that true?
+MR. YAREMA: Object to the form.
+A The Fifth.
+Q You've observed Jeffrey Epstein violate
+5 (Pages 14 to 17)
+
+
+1
+2
+5
+6
+7
+9
+110
+11
+12
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+4
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+120
+21
+23
+24
+25
+18
+that statute on many underage minor females,
+1
+true?
+2
+MR. YAREMA: Object to the form.
+3
+A The Fifth.
+Q Have you ever discussed with Jeffrey
+5
+Epstein that the fact that he is a child
+6
+molester?
+MR. YAREMA: Object to the form.
+8
+A Fifth.
+9
+Q Have you asked Jeffrey Epstein why he
+has made you interact with underage minor females 11
+in a sexual manner?
+12
+MR. YAREMA: Object to the form.
+13
+A Fifth.
+14
+Q During the litigation of these civil
+15
+cases, has Jeffrey Epstein indicated to you an
+16
+intent to continue to molest children?
+117
+MR. YAREMA: Object to the form.
+118
+A Fifth.
+19
+Q Is it your intent to continue to commit
+20
+sex crimes against minors?
+21
+MR. YAREMA: Object to the form.
+22
+A Fifth.
+23
+Q In addition to your being named as a
+24
+co-conspirator of Jeffrey Epstein regarding his
+25
+19
+crimes against minors, there is also a person
+1
+name
+listed as a co-conspirator.
+2
+Do you know
+3
+A Fifth.
+4
+Q This is somebody who lives with you and
+5
+Jeffrey Epstein; is that true?
+6
+MR. YAREMA: Object to the form.
+7
+A Fifth.
+8
+Q And
+is somebody who you
+know to be Story Cowles's girlfriend; is that
+10
+true?
+•11
+MR. YAREMA: Object to the form.
+12
+A Fifth.
+13
+Q She's spoken with Story Cowles about
+14
+this case on numerous occasions; is that true?
+15
+MR. YAREMA: Object to the form.
+16
+A Fifth.
+117
+Q
+conversations with Story
+18
+Cowles and your observations of them, you believe 19
+would implicate you in a crime and that's why
+20
+you're able to take the Fifth as to that
+21
+question?
+MR. YAREMA: Object to the form.
+22
+23
+A Fifth.
+24
+Q Who is Lesley Groff, also listed as a
+25
+20
+co-conspirator in the non-prosecution agreement
+related to Jeffrey Epstein's crimes against
+minors?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you know
+A Fifth.
+• These are all people who also
+participated in Jeffrey Epstein's scheme to lure
+underage females to him for sex; is that true?
+MR. YAREMA: Object to the form.
+Q You and these other co-conspirators
+played various roles to make sure Jeffrey Epstein
+was able to engage in sexual contact or conduct,
+with underage minor females on an everyday basis;
+is that true?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Since the time you first met Jeffrey
+Epstein, has his appetite for underage minor
+females always been the same?
+MR. YAREMA: Object to the form.
+A Fifth.
+21
+Q By that I mean, have you observed
+Jeffrey Epstein to interact sexually with
+underage minor females literally on a daily
+basis?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Wasn't it one of your specific job
+duties to make sure that he had different
+underage minor females to molest on a daily
+basis?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q In addition to the improper sexual
+contact between Jeffrey Epstein and underage
+minor females at the West Palm Beach house, you
+have observed similar improper and illegal
+contact by Jeffrey Epstein in his New York
+mansion, as well, correct?
+MR. YAREMA: Object to the forn.
+A Fifth.
+Q In fact, he operates a very similar
+scheme up there, in that he schedules these
+appointments with underage minor females, under
+the guise that it is going to be a massage; is
+that correct?
+6 (Pages 18 to 21)
+
+
+1
+2
+3
+4
+6
+7
+8
+9
+10
+11
+12
+13
+14
+115
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+112
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+22
+MR. YAREMA: Object to the form?
+1
+A Fifth.
+2
+Q When he is in New York, he has contact
+3
+with underage minor females for the purposes of
+4
+sexually molesting them as well; is that
+5
+correct?
+6
+MR. YAREMA: Object to the form.
+7
+A Fifth.
+8
+Q When he is in his ranch in New Mexico,
+9
+similarly, Jeffrey Epstein is engaging in sex
+110
+with underage minor females from that local aren 11
+as well, and that's something you've observed?
+12
+MR. YAREMA: Object to the form.
+A Fifth.
+Q On his island, particularly, he has
+flown underage minor females to the island for
+underage kid-type orgies; is that true?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q You're shaking your head indicating, at
+least to me, indicating that you may not agree
+with what I'm saying, and I would love to give
+you the chance to explain it to us.
+MR. GOLDBERGER: 1 appreciate that, but
+don't --
+14
+15
+16
+17
+18
+119
+20
+21
+22
+23
+24
+25
+23
+MR. EDWARDS: Read too much into it?
+1
+MR. GOLDBERGER: Exactly. Don't go
+2
+there. Just ask the questions and we will
+3
+move right along.
+4
+MR. EDWARDS: 1 agree, Jack, I just know
+5
+if this is played for a jury, I don't want
+6
+the jury to interpret her shaking her head
+7
+as a "No," and then her pleading the Fifth.
+8
+MR. GOLDBERGER: 1 appreciate that.
+9
+Don't take anything as to any head movements
+10
+or any body movements at all. Just ask the
+11
+questions and we will let the video speak
+12
+for itself.
+13
+Q How many of these - you know what an
+14
+orgy is, don't you?
+15
+A Fifth.
+16
+Q And how many of these orgies, as I'm
+17
+calling them, where there are numerous underage
+18
+minors having sex with each other and with
+19
+Jeffrey Epstein, have you observed on Jeffrey
+20
+Epstein's island?
+21
+MR. YAREMA: Object to the form.
+22
+A Fifth.
+23
+Q Is part of your role as Jeffrey
+24
+Epstein's sex slave, to not tell the authorities
+25
+24
+when Jeffrey Epstein commits these crimes against
+children?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Is there any way for you to escape being
+his sex slave?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Have you ever wanted to cooperate with
+the authorities, so that you could escape being
+his sex slave?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you represent to others that you are
+his girlfriend or his sex slave, or some other
+designation?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Isn't it true that you recently
+represented to the Probation Officer that you
+were his live-in girlfriend?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q When Probation calls the house, are you
+told to tell Probation that he is in the swimming
+25
+pool or doing some other activity that would not
+allow him to come to the telephone?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Isn't it true you're under strict orders
+to tell Probation that?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Isn't it true you've heard Jeffrey
+Epstein tell you on numerous occasions, regarding
+the age of the girls that he wants to his house,
+for the purposes of sexually molesting, the
+phrase he uses is "the younger the better,"
+true?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q lasked you earlier about
+out of
+turn as a result of an objection related to your
+sexual orientation, but I'll talk specifically
+abou
+right now. You know who that is,
+right?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q That is somebody you observed Jeffrey
+Epstein to call for the purposes of getting her
+7 (Pages 22 to 25)
+
+
+2
+3
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+120
+121
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+26
+to his house to sexually molest; is that right?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q The first time she went to Jeffrey
+Epstein's house was in 2002 when she was only 14
+years old; is that true?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q In fact in 2002 you were only 18 years
+old or so yourself; is that right?
+A Fifth.
+Q And
+is somebody you observed at
+Jeffrey Epstein's house on more than 100
+occasions between 2002 and 2005, a time period
+between 14 and 17 years of age for her; is that
+right?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q And each time
+was summoned to
+Jeffrey Epstein's house, it was for the purposes
+of Jeffrey Epstein sexually molesting her,
+correct?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q If it was not Jeffrey Epstein personally
+1
+2
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+19
+20
+21
+22
+123
+24
+25
+27
+calling E.W., you observed
+to call
+1
+E.W. for the purposes of her coming over and
+2
+pleasing Jeffrey Epstein sexually, correct?
+3
+MR. YAREMA: Object to the form.
+4
+A Fifth.
+5
+Q And do you remember the instance where
+6
+Jeffrey Epstein instructed you to lay down naked
+7
+and engage in a threesome with
+- and Jeffrey
+8
+Epstein?
+9
+MR. YAREMA: Object to the form.
+10
+A Fifth.
+11
+Q Do you remember that that during that
+112
+threesome, Jeffrey Epstein demanded
+13
+straddle you and otherwise engage sexually with
+14
+you while Jeffrey Epstein was using vibrators
+15
+and/or dildos on you?
+16
+MR. YAREMA: Object to the form.
+17
+A Fifth.
+118
+Q In addition to your sexual interactions
+19
+with
+sn't it true that you have used
+20
+strap-on dildos and vibrators on other underage
+21
+minors at Jeffrey Epstein's direction?
+22
+MR. YAREMA: Object to the form.
+23
+A Fifth.
+24
+Q You have given oral sex to underage
+25
+28
+minor females?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q You have received oral sex from underage
+minor females?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q All of these sexual acts with minor
+females involving you happened in the presence of
+Jeffrey Epstein?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q During your interaction with underage
+minor females in a sexual manner, isn't it true
+that Jeffrey Epstein would participate in the
+sexual acts and the aet would be over upon
+Jeffrey Epstein ejaculating, correct?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did Jeffrey Epstein tell you, that when
+vas an underage minor female, he forced her
+to give him oral sex?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you remembe
+coming over, a
+29
+young girl, with braces on, and going up into
+Jeffrey Epstein's bedroom on numerous occasions
+to be sexually molested?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you know when it was that Jeffrey
+Epstein developed his plan or scheme to gain
+access to hundreds of underage minor females for
+the purposes of his sexual gratification?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Were you a part of the planning of that
+scheme of Jeffrey Epstein's to gain access to
+underage minor females?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you know Ghislaine Maxwell?
+A Fifth.
+Q Is that somebody who helped Jeffrey
+Epstein to devise the scheme to allow him access
+to various and a variety of underage minor
+females?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Isl
+somebody that was also
+8 (Pages 26 to 29)
+
+
+2
+3
+7
+8
+9
+10
+111
+12
+13
+14
+15
+16
+17
+/18
+19
+120
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+23
+24
+25
+30
+32
+involved in the planning of this scheme to gain
+1
+access to underage minor females?
+2
+MR. YAREMA: Object to the form.
+3
+A Fifth.
+4
+Q When is the first time that you observed
+5
+Jeffrey Epstein's method of enticing or inducing
+6
+underage minor females into sexual acts with him
+7
+inside his bedroom?
+8
+MR. YAREMA: Object to the form.
+9
+A Filth.
+110
+Q Isn't it true that after an underage
+11
+minor female was brought to Jeffrey Epstein's
+112
+house, typically
+13
+yourself would lead that underage minor female to 14
+Jeffrey Epstein's bedroom and leave them alone in 15
+the room; is that true?
+16
+MR. YAREMA: Object to the form.
+17
+A Fifth.
+18
+Q Then Jeffrey Epstein would appear either
+19
+naked or wearing a towel; is that true?
+20
+MR. YAREMA: Object to the form.
+21
+A Fifth.
+22
+Q This is his habit or method of
+23
+operation, every single time, and that's
+24
+something that he has told you about his sexual
+25
+31
+interaction with underage minors; is that true?
+1
+MR. YAREMA: Object to the form.
+2
+A Fifth.
+3
+Q And he would direct or demand or
+4
+instruct the underage minor female to remove her
+5
+clothing; is that true?
+6
+MR. YAREMA: Object to the form.
+7
+A Fifth.
+8
+Q Then he would perform one or more lewd
+9
+or lascivious or sexual acts on the underage
+10
+minor female. Is that true?
+11
+MR. YAREMA: Object to the form.
+112
+A Fifth.
+|13
+Q And you have observed Jeffrey Epstein
+14
+engage in sexual interaction with underage minor
+15
+females on hundreds and hundreds of occasions,
+16
+correct?
+17
+MR. YAREMA: Object to the form.
+18
+A Filth.
+19
+Q And you have observed Jeffrey Epstein
+20
+using vibrators and sexual toys on underage
+21
+minors, true?
+22
+MR. YAREMA: Object to the form.
+23
+A Fifth.
+24
+Q In fact, he has also used vibrators and
+25
+sex toys on you, correct?
+A Fifth.
+Q And he has instructed you to use sex
+toys and vibrators on other underage minor
+females, correct?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q You have observed Jeffrey Epstein
+digitally penetrate the vagina of underage minor
+females, including
+I correct?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q As part of his plan to avoid detection
+by law enforcement, you have observed Jeffrey
+Epstein to pay these underage minor females to be
+quiet, correct?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q And this is something that he has told
+you he does, for the purposes of grooming these
+underage minor females, and avoiding law
+enforcement detection, correct?
+MR. YAREMA: Object to the form.
+A. Filth.
+Q Jeffrey Epstein has talked to you about
+33
+the psychology of brainwashing or grooming
+underage minor females to perform for him
+sexually, hasn't he?
+MR. YAREMA: Object to the form.
+A Filth.
+Q And Sarah Kellen has also spoken with
+you about the methodology behind gaining access
+to and grooming underage minor females for sex?
+MR. YAREMA: Object to form.
+A Fifth.
+Q Isn't it true that Ghislaine Maxwell and
+yourself and
+had access to a master
+list of underage minor females names and phone
+numbers so that they could be called?
+MR. GOLDBERGER: Time out. Are you
+talking to me, counsel?
+MR. HOROWITZ: Nodding my head, back at
+you. You were nodding at me.
+MR. GOLDBERGER: I wasn't nodding at
+you. I'm not talking to you, I'm not
+communicating with you. I don't know what
+you think we are doing here. You said "It
+is truc," and I have no idea what you are
+talking about. Don't interrupt the
+deposition, okay?
+9 (Pages 30 to 33)
+
+
+3
+4
+5
+6
+7
+9
+10
+111
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+34
+MR. HOROWITZ: I think you interrupted.
+MR. GOLDBERGER: I didn't do a thing --
+MR. EDWARDS: I don't know what's
+happened here. It has deteriorated here for
+no reason whatsoever and has nothing to do
+with me or the witness.
+3
+4
+5
+6
+MR. GOLDBERGER: You're 100 percent
+correct.
+MR. EDWARDS: Can we go back to it.
+MR. GOLDBERGER: Absolutely.
+110
+MR. EDWARDS: Perfect.
+11
+The silent fight disrupted me. I lost
+12
+where I am now.
+13
+MR. GOLDBERGER: Sorry.
+114
+MR. EDWARDS: Can you read it back.
+15
+THE COURT REPORTER: Certainly.
+16
+(The record was read.)
+17
+MR. EDWARDS: I'll rephrase the
+18
+question.
+19
+Q Isn't it true that yourself, Ghislaine
+20
+Maxwell and
+had access to a master 21
+of list of underage minor females names and phone 22
+numbers so they could be called for the purpose 23
+of coming to Jeffrey Epstein's house to be
+24
+sexually molested?
+25
+35
+MR. YAREMA: Object to the form.
+A Fifth.
+Q How many underage minor females are on
+that master list?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Are there photographs of these underage
+minor females on that master list?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Is that master list saved on a computer
+system, as has been testified to in the past?
+MR. YAREMA: Object to the form.
+A Fifth.
+• Has Jeffrey Epstein talked to you about
+the success of his scheme to procure underage
+minor females?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q By that, I mean, the method where he
+molests an underage minor female, then offers
+them additional money if they will bring him
+ther underage minor females to molest; are yo
+amiliar with that system
+MR. YAREMA: Object to the forn.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+36
+A Fifth.
+Q In addition to that system, isn't it
+true that Jeffrey Epstein traffics underage minor
+females through a modeling agency?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Is a modeling agency that he is involved
+in with Jean Luc Brunel; you know who that is
+right?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Are you familiar with MC-2 or MC-Squared
+Modeling Agency?
+A Fifth.
+Q You know Jean Lue Brunel, right?
+MR. YAREMA: Object to the form.
+A Filth.
+Q Is Jean Lue Brunel somebody that you
+have been made to perform on sexually?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Jean Lue Brunel is somebody that you
+know to also be a child molester, true?
+MR. YAREMA: Object to the form.
+A Fifth.
+37
+Q This is somebody who for years the
+public has known of Jean Lue Brunel as a child
+molester, true?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q In fact, that is the only thing Jeffrey
+Epstein and Jean Lue Brunel have in common, is
+their obsession for underage minor females,
+correct?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q And the modeling agency is but one other
+mechanism used by Jeffrey Epstein to gain access
+to underage minor females for sex, true?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q I read you the statute earlier on Lewd
+and Lascivious Molestation, Chapter 800.04, and
+that's something that you have witnessed Jeffrey
+Epstein violate on hundreds of occasions,
+correct?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q And something that you have witnessed
+Jeffrey Epstein specifically violate, against
+10 (Pages 34 to 37)
+
+
+1
+2
+3
+4
+5
+6
+7
+9
+110
+11
+12
+13
+14
+15
+116
+17
+18
+19
+20
+21
+122
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+120
+21
+22
+23
+24
+25
+38
+40
+true?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Also a statute you have witnessed
+Jeffrey Epstein violate against then minor,
+1
+2
+4
+5
+MR. YAREMA: Object to the form.
+7
+A Fifth.
+Q In fac
+was somebody that Jeffrey
+Epstein liked or likes; isn't that true?
+MR. YAREMA: Object to the form.
+A Fifth.
+QI
+I was somebody Jeffrey Epstein met
+when she was only 13 years old and began sexually 14
+molesting her the first day that he met her,
+true?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q
+was one of his main girls, as he
+would call them; is that true?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q L.M. procured for him or brought for him
+to his house, over 50 girls between the ages of
+12 and 15 years old; is that true?
+9
+10
+11
+12
+13
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+39
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Each of these girls, aged 12 to 15, you
+observed come into the house, go into Jeffrey
+Epstein's bedroom and leave the house after being
+sexually molested, true?
+MR. YAREMA: Object to the form.
+A Fifth. (
+Q And in addition to
+being sexually
+molested herself, she was enticed or coerced into
+bringing her friends over, to also be sexually
+molested, true?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Has Jeffrey Epstein talked to you about
+an FBI statement that was given by
+A Fifth.
+Q He has also told you that that FBI
+statement that was favorable for him is
+completely false; isn't that true?
+MR. YAREMA: Object to the form.
+A Fifth. (
+Q Has he spoken to you about the fact that
+she is now telling the complete story and
+accurate account as to what happened at Jeffrey
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Epstein's house, and he is using all resources to
+try to intimidate and harass her; is that true?
+MR. YAREMA: Object to the form.
+A Filth.
+Q In fact, has he talked to you about his
+tactic of intimidating and harassing any victims
+that come forward against him, regarding the
+sexual abuse that they endured by him?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Would you agree that Jeffrey Epstein
+contributed to the delinquency of these various
+minors that he sexually abused?
+MR. YAREMA: Object to the form.
+A Fifth. (
+Q In addition to abusing them, he also
+encouraged them to return to him to receive more
+sexual abuse and encouraged them into a life of
+prostitution, true?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q How many underage minor females have you
+observed Jeffrey Epstein engage in sex acts with
+on any of his airplanes?
+MR. YAREMA: Object to the form.
+41
+A Filth.
+Q Have you engaged in sexual acts with any
+underage minor females on Jeffrey Epstein's
+airplanes?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q How many times has Jeffrey Epstein
+talked to you about the reasons why he sexually
+abuses minors?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Didn't he tell you that it is his intent
+to harm these minors in hopes of gaining
+psychological advantage over them?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Are you aware that Jeffrey Epstein pled
+guilty to two felonies related to his interaction
+with minors?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q And as a result he was incarcerated, and
+as we spoke about earlier, you visited him in
+jail on more than 50 occasions, correct?
+MR. YAREMA: Object to the form.
+11 (Pages 38 to 41)
+
+
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6 '
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+42
+44
+A Fifth.
+Q Aren't your observations with Jeffrey
+Epstein's interactions with
+wouldn't you
+agree he coerced her into a life of prostitution?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q And based on your observations of
+Jeffrey Epstein's interactions with
+wouldn't you agree that Jeffrey Epstein coerced
+her into a life of prostitution?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q And with respect to Jane Doe and
+and
+•wouldn't you agree that Jeffrey Epstein |14
+forced these girls to be a prostitute for him?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Would you agree that Jeffrey Epstein's
+actions against
+• and Jane Doe, were
+intentional, deliberate and reckless?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Would you agree that that intentional,
+deliberate and reckless conduct by Jeffrey
+Epstein against
+and Jane Doe was
+1
+2
+3
+4
+5
+6
+7
+8
+9
+110
+11
+12
+13
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+43
+likely to cause severe emotional distress?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q And isn't it a fact that Jeffrey Epstein
+has specifically told you that it is his intent
+to cause severe emotional distress, as it
+weakened his victims?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Has Jeffrey Epstein talked to you about
+your role in what he calls a criminal enterprise?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Has he talked to you about his
+ganization being a criminal enterprise, th
+ou need to help protec
+MR. YAREMA: Object to the form.
+A Fifth.
+Q What does Jeffrey Epstein do for a
+living?
+A Fifth.
+• Does he profit from international sex
+trafficking of children?
+MR. YAREMA: Object to the form.
+A Fifth.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Q Do you profit from sex trafficking of
+children?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you know Sergio Cordero?
+A Fifth.
+Q Do you know Mike Sanka?
+A Fifth.
+Q Would you consider Jeffrey Epstein's
+criminal enterprise that is designed to molest
+underage minor females, to be organized?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Is your role in that criminal
+arrangement to molest underage minor females, to
+help organize?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q As part of that organization, isn't it
+true that you, as well as various staff members,
+took meticulous messages regarding appointments
+and scheduling underage minor females to come
+over to be sexually molested?
+MR. YAREMA: Object to the form.
+A Fifth.
+45
+Q These were message pads that had a
+carbon copy that were positioned or stationed in
+several places around Jeffrey Epstein's home near
+the telephone; you're familiar with those,
+right?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Since I'm assuming that you are going to
+take the Fifth on each and every question related
+to any messages, I will show you only one, which
+will be marked, this one page, as Plaintiff's
+Exhibit 1. The date on the message that I will
+be showing you is 8/21, August 21, 2005.
+(Message dated August 21, 2005 was
+marked as Plaintiff's Exhibit number 1 for
+identification, as of this date.)
+MR. EDWARDS: Do you want to see it
+first?
+MR. GOLDBERGER: (Counsel examines
+document and hands it to the witness.)
+Q Would you look at the exhibit, please,
+if you can see it? I don't know if you can see
+it over your coffee.
+A I can see it.
+Q Okay. Do you recognize it?
+12 (Pages 42 to 45)
+
+
+1
+2
+3
+4
+6
+7
+8
+9
+110
+11
+12
+13
+114
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+3
+4
+5
+7
+9
+10
+111
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+16
+A Fifth.
+• That particular message indicates it is
+from You're the only "l
+' in the
+house; is that correct?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q This is a call from you indicating that
+cannot work today an
+will be
+here at 4:00 p.m.;" is that right?
+MR. YAREMA: Object to the form?
+A Fifth.
+Q Who is
+A Fifth.
+MR. YAREMA: Object to the form.
+Q That's an underage minor female that was
+scheduled to be molested at Jeffrey Epstein's
+house?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q You scheduled that act of molestation;
+is that right?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q And Britney will be at the house at 4:00
+p.m. Britney is another underage minor female;
+• N
+3
+4
+5
+10
+11
+12
+13
+14
+15
+16
+17
+19
+20
+21
+122
+23
+24
+25
+47
+is that correct?
+1
+MR. YAREMA: Object to the form.
+2
+A Fifth.
+3
+Q That's somebody else that you were
+4
+scheduling to come to his house at 4:00 p.m. for
+5
+Jeffrey Epstein to engage in sexual acts with
+6
+her, while she was an underage minor, true?
+7
+MR. YAREMA: Object to the form.
+8
+A Fifth.
+9
+Q Do you know Les Wexner?
+10
+A Fifth.
+11
+Q That's somebody that you know owns and 12
+operates the Victoria's Secret, the Limited?
+113
+MR. YAREMA: Object to the form.
+14
+A Is that a question?
+15
+Q Is that somebody that you know to own
+16
+Victoria's Secret or operate Victoria's Secret?
+17
+A Fifth.
+18
+Q Do you know if Jeffrey Epstein still
+19
+talks with Leslie Wexner?
+20
+MR. YAREMA: Object to the form.
+21
+A Fifth.
+Q Do you know Jane Doe
+22
+23
+A Fifth.
+24
+Q Are you aware of Jeffrey Epstein and
+25
+48
+Ghislaine Maxwell's sexual interaction with Jane
+when she was a minor?
+MR. YAREMA: Object to the form.
+Q This is one of many underage minor
+females that was trafficked basically around the
+globe to be sexually exploited and abused; is
+that correct?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Was that typical of Jeffrey Epstein and
+Ghislaine Maxwell to sexually abuse minors on
+Jeffrey Epstein's airplane?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q And also typical of Ghislaine Maxwell
+and Jeffrey Epstein to prostitute or pimp out
+underage minors to friends?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q By "friends," 1 am talking specifically
+about people of royalty, politicians,
+academicians, businessmen and other professional
+or personal acquaintances?
+MR. YAREMA: Object to the form.
+A Fifth.
+49
+Q Were you with Jeffrey Epstein on his
+birthday when one of his friends sent to him
+12 -- sorry, three 12-year olds for the purposes
+of Jeffrey Epstein sexually abusing them?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q How many occasions have you observed
+Jeffrey Epstein to receive as gifts from friends,
+underage minor females for the purposes of him
+sexually abusing them?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q These three 12-year olds were from
+France. Were they sent to him on his birthday by
+Jean Lue Brunel or by somebody else?
+MR. YAREMA: Object to form.
+A Fifth.
+Q Have you ever been made to engage in sex
+with 12-year olds?
+MR. YAREMA: Object to the forn.
+A Fifth.
+Q Is it true that Jeffrey Epstein makes
+you dress up as a 12-year old?
+MR. YAREMA: Object to the form.
+A Fifth.
+13 (Pages 46 to 49)
+
+
+1
+2
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+7
+8
+110
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+50
+52
+Q
+As part of being Jeffrey Epstein's sex
+slave, isn't it true that he asks you or requests
+of you to dress younger than 12 at times?
+1
+2
+3
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Have you seen naked photographs of the
+underage minor females with whom Jeffrey Epstein 7
+has engaged in sex acts?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Are there hidden cameras in any of
+Jeffrey Epstein's homes, that you know to have
+taken surreptitious videos or photographs of
+underage minors?
+MR. YAREMA: Object to the formn.
+A Fifth.
+Q Does Jeffrey Epstein still watch
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+pornography to this day?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Does Jeffrey Epstein watch homemade
+19
+20
+21
+pornographic videos of underage minors engaging 22
+in sex orgies on his island?
+MR. YAREMA: Object to the form.
+A Fifth.
+24
+25
+51
+Q Prior to the search warrant being
+executed, you are aware that at least three
+computers were taken at Jeffrey Epstein's
+direction, from Jeffrey Epstein's house, to avoid
+detection by law enforcement, correct?
+MR. YAREMA: Object to the form.
+A
+Correct.
+Q
+and some other person
+took those computers to avoid Jeffrey Epstein --
+to avoid the authorities obtaining the evidence
+contained on those computers, correct?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Who are the persons along with
+took the computers from Jeffrey
+Epstein's house prior to the execution of the
+search warrant?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Where are those computers today?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Were they taken by his investigator,
+Bill Riley?
+1
+MR. YAREMA: Object to the form.
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+114
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A Fifth.
+Q Do you know Bill Riley?
+A Fifth.
+Q Have you seen the flight logs from
+Jeffrey Epstein's private airplane flights?
+MR. YAREMA: Object to the forn.
+A Fifth.
+Q Are you aware that you're listed as a
+passenger on many flights, along with Jeffrey
+Epstein on his private airplane?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Certainly comes as no surprise to you,
+since you were on his airplane on numerous
+occasions, correct?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q On September 22, 2003, you were listed
+as being on a flight with
+1, Jeffrey
+Epstein,
+• My question
+is who ish
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you know
+A Fifth.
+53
+Q That's somebody that you're familiar
+with, because you have been to Jeffrey Epstein's
+house on many occasions with
+correet?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q In fact, do you remember there being a
+burglary of Jeffrey Epstein's house where he
+actually called the police to investigate the
+burglary?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q And during the police investigation
+inside Jeffrey Epstein's house, you were speaking
+with
+, both in person, at Jeffrey
+Epstein's house, correct?
+MR. YAREMA: Object to the form.
+A Correct.
+Q Is this another person that Jeffrey
+Epstein, when she was a minor, violated
+sexually?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you still speak with
+MR. YAREMA: Object to the form.
+14 (Pages 50 to 53)
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+B
+9
+10
+11
+112
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+54
+A Fifth.
+Q Do you know Bill Clinton?
+A Fifth.
+Q You have been on Jeffrey Epstein's
+airplane with Bill Clinton?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Isn't take true you have been on Jeffrey
+Epstein's airplane with Doug Band, Bill Clinton's
+righthand man?
+MR. YAREMA: Object to the form.
+A Filth.
+Q Have you witnessed improper sexual
+netivity between Jeffrey Epstein and minors,
+while he was in the presence of Bill Clinton?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q How many times have you ridden on the
+airplane with Jean Lue Brunel?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Each time that Jean Lue Brunel visits
+Jeffrey Epstein's house, does he bring underage
+minors to Jeffrey Epstein's house to engage in
+sex with?
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+111
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+55
+MR. YAREMA: Object to the form.
+1
+A Fifth.
+Q Do you know Glenn Dubin?
+3
+A Fifth.
+4
+Q Do you know
+?
+5
+A Fifth.
+6
+Q Is that somebody that was a sexual abuse
+7
+victim at one point in time of Jeffrey Epstein
+8
+and Jean Luc Brunel?
+9
+MR. YAREMA: Object to the form.
+10
+A Fifth.
+- 11
+Q Between 2002 and 2005 when
+was
+112
+abused by Jeffrey Epstein sexually, isn't it true
+13
+that Jeffrey Epstein took flights to Palm Beach
+14
+for the purposes of sexually abusing
+15
+MR. YAREMA: Object to the form.
+116
+A Fifth.
+17
+Q And between those same years of 2002 and
+18
+2005, isn't it true that Jeffrey Epstein took
+119
+airplane flights to Palm Beach from places
+20
+outside of the State, to engage in sexual acts
+21
+with
+7
+22
+MR. YAREMA: Object to the form.
+23
+A Fifth.
+24
+Q From 2003 through 2005, isn't it true
+25
+56
+Jeffrey Epstein specifically flew to Palm Beach
+for the purposes of engaging in sex nets with
+Jane Doe?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Generally, isn't it true Jeffrey Epstein
+would fly from place to place for the purpose of
+engaging in sexual activity with minors at his
+destination?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Isn't it true that he employed numerous
+people for the sole purpose of scheduling
+appointments with underage minor females at each
+destination he landed?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q What is Jeffrey Epstein's relationship
+with Sandy Berger?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you know what Jeffrey Epstein's
+relationship is with Alan Dershowitz?
+MR. YAREMA: Object to the form.
+A Fifth.
+57
+Q That's somebody who you know to have
+stayed at Jeffrey Epstein's house on many
+occasions, correct?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q And also somebody who you know to have
+been at the house when
+was in Jeffrey
+Epstein's bedroom getting sexually abused,
+correct?
+MR. YAREMA: Object to the form.
+A Fifth:
+Q Alan Dershowitz is also somebody that
+you also know to have been at the house when
+was being sexually abused in Jeffrey Epstein's
+bedroom, correct?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Generally, Alan Dershowitz is familiar
+with Jeffrey Epstein's habit of engaging in
+sexual acts with minors on a daily basis,
+correct?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q When Alan Dershowitz was in town,
+Jeffrey Epstein did not break his schedule for
+15 (Pages 54 to 57)
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+25
+58
+Alan Dershowitz, meaning he continued to sexually
+abuse minors despite Alan Dershowitz being a
+guest in the house?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Alan Dershowitz never engaged in any
+sexual activity with these underage minors; isn't
+that true?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Have you been made to have sex with
+Ghislaine Maxwell?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you know
+A Fifth.
+Q Similar to vou being Jeffrey Enstein's
+sex slave, is
+Ghislaine Maxwell's sex slave?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Ghislaine Maxwell is somebody who you
+know to be bi-sexual, true?
+MR. YAREMA: Object to the form.
+A Fifth.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+124
+25
+59
+Q You know that Ghislaine Maxwell engaged
+1
+in sexual acts with underage minor females, true?
+2
+MR. YAREMA: Object to the formn.
+3
+A Fifth.
+4
+Q This is yet another friend of Jeffrey
+5
+Epstein's that is into the act of molesting
+6
+underage minor females, right?
+7
+MR. YAREMA: Object to the forn.
+8
+A Fifth.
+9
+Q Now, you are the next participant in
+10
+that activity, meaning you have been groomed to
+- 11
+enjoy and appreciate the acts of sex with
+12
+underage minors, true?
+113
+MR. YAREMA: Object to the form.
+14
+A Fifth.
+15
+Q Has Jeffrey Epstein instructed you to
+16
+lie to his Probation Officer in any way?
+17
+MR. YAREMA: Object to the form.
+18
+A Fifth.
+19
+Q Mr. Visoski testified that you took a
+20
+helicopter flight within the last year with
+21
+Jeffrey Epstein to Miami. Do you remember that
+22
+flight?
+23
+MR. YAREMA: Object to the form.
+24
+A Fifth.
+25
+Q What was the purpose of that flight?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you sign a confidentiality agreement
+with Jeffrey Epstein?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q When is the last time that you observed
+Jeffrey Epstein have sex with a minor?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Since being on probation, has Jeffrey
+Epstein been able to, or has he flown to his
+island?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q To your knowledge, has Jeffrey Epstein
+flown to New York while on probation or community
+control?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Isn't it true that he has flown both to
+New York and to his island, and you have
+accompanied him on those trips, since he was on
+community control?
+61
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Isn't it also true that Jeffrey Epstein
+has indicated to you that he will always engage
+in sex acts with underage minor females?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q In fact, that's something that he has
+told you, that he believes he is entitled to do;
+isn't that right?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Isn't it true that Jeffrey Epstein
+believes and has told you that if he doesn't
+physically force the underage minor female into
+any act, then he is entitled to engage in sex
+with any underage minor female despite the age?
+MR. YAREMA: Object to the form.
+A Fifth.
+• What is the youngest female you have
+witnessed or observed Jeffrey Epstein to engage
+in sex with?
+MR. YAREMA: Object to the form.
+A Filth.
+Q Do you have a bank account at Chase Bank
+16 (Pages 58 to 61)
+
+
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+4
+5
+7
+10
+11
+12
+13
+11
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+in New York?
+A Fifth.
+Q And the money in that bank account under
+your name is money that was given to you by
+Jeffrey Epstein, correct?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q For the passed ten or so years, you have
+lived with Jeffrey Epstein under his control,
+right?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q You get to lead the life of a
+millionaire, and to lead that life, you were only
+required to be Jeffrey Epstein's sex slave and to
+bring Jeffrey Epstein other slaves?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Is this 301 East 66th Street apartment
+still an apartment that you frequent today?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q And you're familiar with the nine or ten
+apartments that Jeffrey Epstein owns or controls
+up there at 301 East 66th Street, aren't you?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q At any given time, there are between 8
+and 16 underage minors living in or staying at
+those apartments?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q On the various passenger lists on
+Jeffrey Epstein's airplane, where it will list,
+for instance, Jeffrey Epstein,
+going from Florida to St.
+homas, then generically, female, female; wou
+know who those female, females are
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Are those females listed generically
+ather than specifically because they ar
+inderage minor females engaging in sex with you 1
+or Jeffrey Epstein?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Is
+someone that you see on
+a regular basis at Jeffrey Epstein's house?
+MR. YAREMA: Object to the form.
+A Fifth.
+62
+1
+2
+3
+5
+7
+8
+9
+110
+11
+12
+13
+14
+15
+16
+17
+19
+21
+123
+24
+25
+63
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+117
+20
+21
+22
+23
+24
+25
+64
+Q That's somebody who these days refers to
+himself as Jeffrey Epstein's personal assistant,
+right?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q That's somebody who you know to work for
+or at the Florida Science Foundation, which is
+owned by Jeffrey Epstein, correct?
+MR. YAREMA: Object to the form.
+A Filth.
+Q It is also somebody that you know to
+have stayed at Jeffrey Epstein's house with
+I, correct?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q This is somebody that has been
+involved --
+is somebody who's been
+involved sexually with
+for at least
+a year, right?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q In fact, you know that they took a trip
+around the world together and during that trip
+they discussed Jeffrey Epstein and his
+interaction with underage minor females,
+65
+correct?
+MR. YAREMA: Object to the form.
+A Fifth.
+MR. EDWARDS: Done. I don't have
+anything else.
+MR. GOLDBERGER: Okay.
+MR. HOROWITZ: I do, why don't we take a
+short break.
+MR. GOLDBERGER: We are stopping at
+11:50.
+MR. HOROWITZ: What?
+MR. GOLDBERGER: 11:50.
+MR. HOROWITZ: I kind of remember that
+e-mail.
+THE VIDEOGRAPHER: Off the video record.
+(Pause in the proceedings.)
+THE VIDEOGRAPHER: We are back on the
+video record at 11:18 a.m.)
+(At this time Robert Critton joined the
+proceedings.)
+CROSS EXAMINATION
+BY MR. HOROWITZ:
+Q Ms.
+, between 2001 and 2006,
+did Jeffrey Epstein instruct you to place
+telephone calls to arrange for girls under the
+17 (Pages 62 to 65)
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+7
+8
+9
+110
+11
+12
+13
+114
+15
+16
+17
+18
+19
+20
+21
+22
+24
+25
+66
+68
+age of 18 to come to his home for his sexual
+gratification?
+MR. YAREMA: Object to the form.
+H N
+3
+A Fifth.
+Q Between 2001 and 2006 did you, in fact,
+place telephone calls to arrange for girls under
+the age of 18 to come to Jeffrey Epstein's home
+for his sexual gratification?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Are you personally aware that a girl
+named
+came to Jeffrey Epstein's Palm Beach 12
+home in late 2004?
+MR. YAREMA: Object to the form.
+A Fifth.
+• Did Jeffrey Epstein admit to you he
+sexually abused
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Isn't it true in late 2004 you made
+arrangements by telephone to bring
+Jeffrey Epstein's home?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did Jeffrey Epstein instruct you to
+5
+6
+7
+8
+9
+10
+11
+113
+111
+15
+16
+17
+18
+19
+20
+21
+22
+123
+24
+125
+67
+communicate by telephone to arrange fol
+1
+come to his home for his sexual gratification?
+2
+MR. YAREMA: Object to the form.
+3
+A Fifth.
+4
+Q Did Jeffrey Epstein inform you tha
+5
+would be giving him a massage that was sexual in
+6
+nature?
+7
+MR. YAREMA: Object to the form.
+8
+A Filth.
+9
+Q Did Jeffrey Epstein tell you it was his
+10
+intent during the course off
+Is visit to his
+111
+home to persuade, induce or entice her to engage
+|12
+in sexual activity?
+13
+MR. YAREMA: Object to the form.
+14
+A Fifth.
+15
+Q Did Jeffrey Epstein tell you that, in
+16
+fact, he succeeded in persuading, inducing or
+117
+enticing
+to engage in sexual activity with
+18
+him?
+19
+MR. YAREMA: Object to the form.
+20
+A Fifth.
+21
+Q Are you personally aware that a girl
+122
+named
+came to Jeffrey Epstein's Palm Beach 23
+home on multiple occasions in 20047
+24
+MR. YAREMA: Object to the form.
+25
+A Fifth.
+Q Did Jeffrey Epstein admit to you that he
+sexually abused
+in his Palm Beach home in
+2004?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you ever instruct a girl named
+to bring other underage girls to Jeffrey
+Epstein's home for Jeffrey Epstein's sexual
+pleasure?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q In 2004 did you communicate by telephone
+with y
+for the purpose of bringing
+To Jeffrey Epstein's home for sexual
+activity MR. YAREMA: Object to the form.
+A Fifth.
+Q Did Jeffrey Epstein instruct you to
+communicate with
+for the purpose of
+making arrangements for
+I to come to his home?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did Jeffrey Epstein tell you it was his
+intent during the course of
+• visit to his
+home to persuade, induce or entice her to engage
+69
+in sexual activity with him?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did Jeffrey Epstein admit to you that he
+had succeeded in, in fact, persuading, inducing
+or enticingl
+to engage in sexual activity
+with him?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Are you personally aware that a teenage
+girl named, came to Jeffrey Epstein's Palm
+Beach home on multiple occasions between 2003 and
+2005?
+MR. YAREMA: Object to the form.
+A Filth.
+Q Did Jeffrey Epstein admit to you that he
+sexually abused
+.?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Atany time prior to May of 2005, did
+Jeffrey Epstein instruct you to place telephone
+calls to for the purpose of arranging for
+her to come to his home and engage in sexual
+activity?
+MR. YAREMA: Object to the form.
+18 (Pages 66 to
+69)
+
+
+1
+2
+3
+6
+7
+10
+11
+12
+13
+114
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+72
+A Fifth.
+Q Did you, in fact, communicate by
+telephone with
+• for the purpose of arranging
+for her to come to his home for sexual activity?
+MR. YAREMA: Object to the form.
+A Filth.
+Q At any time prior to May of 2005, did
+you place a telephone call to
+wherein you arranged for
+• to come to Jeffrey
+Epstein's home for sexual activity?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Prior to May of 2005, did you ever
+observe I
+speaking with by
+telephone to arrange for
+• to come to Jeffrey
+Epstein's home?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did Jeffrey Epstein tell you that it was
+his intention to sexually abuse
+during the
+course of her visits to his home?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did Jeffrey Epstein tell you that he
+succeeded in engaging
+.. in sexual activity
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+24
+25
+71
+while she was still a minor, at his home?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Are you personally aware that a teenage
+girl named al
+I, came to Jeffrey Epstein's
+Palm Beach home in approximately 2001 or 2002?
+MR. YAREMA: Object to the form.
+A Fifth.
+@ Did Jeffrey Epstein admit to you that he
+sexually abuse
+at his home while she was
+still a child?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q In 2001 or 2002, did
+inform
+you that she received a telephone call in which
+she was referred to
+who would be willing to
+come to Jeffrey Epstein's home for sexual
+activity?
+MR. YAREMA: Object to the form.
+A Fifth.
+(Whereupon, at this point in the
+proceedings, Robert Critton left the
+deposition room.)
+Q Did Jeffrey Epstein instruct you to call
+1
+2
+3
+4
+5
+6
+7
+8
+g
+10
+11
+12
+13
+14
+15
+16
+117
+18
+119
+20
+21
+122
+23
+24
+to come to his home and give him a massage 25
+in either 2001 or 2002?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you, in fact, call
+to come to
+Jeffrey Epstein's home and give him a massage in
+a sexual nature in 2001 or 2002?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you either observe or overhear
+speaking with
+on the telephone to
+arrange forl
+• to come to Jeffrey Epstein's
+home for a massage of a sexual nature?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did Jeffrey Epstein tell you it was his
+intent during the course of
+visit to his
+home to persuade, induce or entice her to engage
+in sexual activity?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Didn't Jeffrey Epstein admit to you that
+he succeeded in persuading, inducing or enticing
+to engage in sexual activity with him at his
+home while she was still a minor?
+MR. YAREMA: Object to the form.
+73
+A Fifth.
+Q Are you personally aware that a girl
+named came to Jeffrey Epstein's home in
+approximately August 20047
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did Jeffrey Epstein admit to you that he
+had sexually abused
+• when she was only 13
+yenrs old?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q In 2004 did you participate in a
+telephone call wherein you arranged for. to
+come to Jeffrey Epstein's home for the purpose of
+giving him a massage that was to be sexual in
+nature?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did Jeffrey Epstein instruct you to
+communicate by telephone and make arrangements
+for . to come to his home for sexual activity
+while she was still a child?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did Jeffrey Epstein tell you it was his
+19 (Pages 70 to 73)
+
+
+2
+3
+4
+7
+9
+10
+11
+12
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+B
+9
+10
+111
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+74
+intention during the course of
+'s visit to
+his home to persuade, induce or entice her to
+engage in sexual activity with him?
+MR. YAREMA: Object to the form.
+A Fifth.
+1
+2
+3
+4
+5
+Q Did Jeffrey Epstein tell you that, in
+fact, he succeeded in persuading, inducing and
+7
+enticing l
+. to engage in sexual activity with
+8
+him while she was still a child at his home?
+9
+MR. YAREMA: Object to the form.
+110
+A Fifth.
+11
+Q Are you personally aware that a girl
+12
+named
+came to Jeffrey Epstein's home in Palm 13
+Beach on multiple occasions between 2003 and May 14
+of 2005?
+15
+MR. YAREMA: Object to the form.
+16
+A Fifth.
+17
+Q Did Jeffrey Epstein admit to you that he
+18
+sexually abused
+May of 2005?
+Lat his home between 203 and 20
+MR. YAREMA: Object to the form.
+21
+A Fifth.
+22
+Q Prior to May of 2005, did you receive a
+phone call from a girl named
+• herein 21
+she told you she was bringing
+to Jeffrey
+25
+75
+Epstein's home to give him a massage?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q At any time prior to 2005, did Jeffrey
+Epstein instruct you to communicate with
+I by telephone to make arrangements for F.P.
+to come to his home?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Prior to
+Is visits to Jeffrey
+Epstein's home, did Jeffrey Epstein tell you it
+was his intention to induce, entice and engage
+1. to engage in sexual activity with him?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q After
+visits to Jeffrey Epstein's
+home, did Jeffrey Epstein tell you that he
+succeeded in enticing, engaging and persuading
+to engage in sexual activity with him while
+she was still a child?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Are you personally aware that a teenage
+girl named
+came to Jeffrey Epstein's Palm
+Beach home in approximately 2001 or 2002?
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+76
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you participate in a telephone call
+wherein you arranged for
+to come to Jeffrey
+Epstein's home for a massage?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did Jeffrey Epstein instruct you to
+participate in a telephone call wherein you were
+to arrange fod
+come to his home for
+sexual activity?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did Jeffrey Epstein admit to you it was
+his intention during the course d
+risit
+to his home, to engage her in sexual activity
+while she was still a child?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did Jeffrey Epstein admit to you he had,
+in fact, persuaded, enticed and engaged in
+sexual activity at his home while she was still a
+child?
+MR. YAREMA: Object to the form.
+A Fifth.
+77
+MR. HOROWITZ: No other questions at
+this point.
+MR. LANGINO: I have less than ten
+minutes of questioning.
+MR. GOLDBERGER: Fine, that will bring
+us right to the break.
+CROSS EXAMINATION
+BY MR. LANGINO:
+I'm Adam Langino and I represen
+and
+Do you know an individual named
+A Fifth.
+Q Do you know an individual named
+A Fifth.
+Q Have you seen
+at the defendant's
+Palm Beach property?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Have you seen
+at the defendant's
+Palm Beach property?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Have you ever engaged in a sexual act
+with
+MR. YAREMA: Object to the form.
+20 (Pages 74 to 77)
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+119
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+24
+25
+78
+A Fifth.
+Q Have you ever engaged in a sexual act
+with
+1
+2
+3
+MR. YAREMA: Object to the form.
+4
+A Fifth.
+5
+Q Did you ever observe the defendant,
+6
+Jeffrey Epstein, witt
+7
+MR. YAREMA: Object to the form.
+8
+A Fifth.
+9
+Q Did you ever observe the defendant,
+10
+Jeffrey Epstein, witl
+11
+MR. YAREMA: Object to the form?
+12
+A Fifth.
+13
+Q Have you ever physically touched
+14
+MR. YAREMA: Object to the form.
+15
+A Fifth.
+16
+Q Have you ever physically touched
+17
+MR. YAREMA: Object to the form.
+18
+A Fifth.
+19
+Q Has the defendant ever made a statement
+20
+to you about
+21
+MR. YAREMA: Object to the form.
+22
+A Fifth.
+23
+Q Has the defendant ever made a statement
+24
+to you about
+25
+79
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Has
+ever made a statement
+to you about B.B.?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Has
+ever made a statement
+to you about C.L.?
+1
+2
+3
+4
+5
+6
+7
+8
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Have you ever communicated with
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Have you ever communicated with
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you know that
+at the time of sexual abuse?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you kno
+was a minor at
+the time of the sexual abuse?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you know il
+sexual activity
+10
+11
+12
+13
+14
+15
+16
+was a minor 17
+18
+19
+20
+21
+22
+23
+24
+25
+80
+with the defendant was consensual?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you know il
+sexual activity
+with the defendant was consensual?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q When you participated in sexual acts
+with each minor, how did you feel?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q In your heart, did you know it was
+wrong?
+MR. YAREMA: Object to the form, and in
+addition this is irrelevant and has already
+been addressed by Judge Hafele as an
+inappropriate question. That's my
+objection.
+A Fifth.
+O During this time period did you feel
+confused?
+MR. YAREMA: Object to the form.
+MR. GOLDBERGER: Same -
+MR. YAREMA: Same objection.
+A Fifth.
+81
+Q Are you currently in love with the
+defendant?
+MR. YAREMA: Object to the form, same
+objection. That question has no relevance
+to this... it is inappropriate per Judge
+Hafele's order.
+MR. GOLDBERGER: Also involves privacy
+rights of my client. I instruct her not to
+answer the question.
+A Fith.
+Q Have you ever been in love with Jeffrey
+Epstein?
+MR. GOLDBERGER: Same objection.
+MR. YAREMA: Same objections.
+A Fifth.
+MR. LANGINO: Thank you.
+CROSS EXAMINATION
+BY MS. EZELL:
+(Discussion off the record.)
+Q Good morning, Ms.
+I'm
+Katherine Ezell and I represent
+whose name is!
+which shall appear as
+"
+the deposition.
+Are you aware that in 2004 and 5, there
+was a sort of hidden staircase that would take
+21 (Pages 78 to 81)
+
+
+1
+2
+3
+4
+5
+6
+7
+10 00
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+3
+4
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+82
+one from the kitchen upstairs to the master
+bedroom and massage area?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you recall there being nude
+photographs on the staircase?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you know
+A Fifth.
+Q Did A.H. come to the house at 358 EI
+Brillo Way to provide a massage to Jeffrey
+Epstein?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did that massage become sexual in
+nature?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did
+become a regular visitor at
+Jeffrey Epstein's house?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you remember that she came maybe
+hundreds of times?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you recall that she was under the age
+of 18 at the time she was coming to Jeffrey
+Epstein's home?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Were you younger than
+at the time?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you remember occasions when you and
+Jeffrey Epstein were already in bed when
+arrived?
+MR. YAREMA: Object to the form.
+A Filth.
+Q Do you recall Jeffrey Epstein
+instructing
+to remove her clothes and join
+the two of you in bed?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you recall that you and Jeffrey
+Epstein bringing sex toys in bed for you and
+to use on each other?
+MR. YAREMA: Object to the form.
+A Fifth.
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+116
+17
+18
+19
+20
+21
+22
+23
+24
+25
+83
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+84
+Q Do you recall that Jeffrey Epstein would
+join in by performing oral sex on one or the
+other of you - you or
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you recall that also happening,
+meaning the oral sex, being performed on the
+massage table --
+MR. YAREMA: Objection.
+Q - to A.H.?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Were vau present one day when Jeffrey
+Epstein held
+down on the massage talle and
+while holding her inserted his penis into
+vagina?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you recall he stated that he wanted
+you to observe this?
+MR. YAREMA: Object to the form.
+A Filth.
+Q Do you recall th
+had rules,
+lines, that she had stated Jeffrey Epstein was
+not to cross, in their encounters?
+85
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you recall that
+• had forbidden
+any kind of vaginal penetration?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you recall tha
+refused to touch
+Jeffrey Epstein's penis?
+MR. YAREMA: Object to the form.
+A Fifth.
+O Do you recall that day when Jeffrey
+Epstein held
+on her stomach on the massage
+table and began pumping his penis into her
+vagina, that she screamed "No"?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you recall that upon her screaming,
+Epstein stopped and apologized?
+MR. YAREMA: Object to the forn.
+A Fifth.
+Q Do you recall that Jeffrey Epstein paid
+her $1,000 for that visit?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you engage in sex wit
+when she
+22 (Pages 82 to 85)
+
+
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+18
+19
+20
+21
+22
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+86
+was under 18?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did Jeffrey Epstein watch you and
+having sex while he masturbated?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Are you aware tha
+activities
+with Jeffrey Epstein escalated further and
+further as time went on?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you see Jeffrey Epstein use
+vibrators and strap-on - use vibrators on
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you and
+ngage in sex with
+strap-on penises?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q. Did you see Jeffrey Epstein perform oral 21
+sex ol
+numerous times?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did Jeffrey Epstein pa
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+|13
+14
+15
+16
+17
+18
+19
+20
+22
+23
+124
+25
+87
+additional $200 to perform oral sex on you?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you recall that each time a new toy
+or activity was introduced when
+there to
+1
+2
+3
+4
+5
+give massages, Jeffrey Epstein p
+additional money?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Would Jeffrey Epstein masturbate while
+watching you and
+I perform sexual acts?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you recall that Jeffrey Epstein
+provided A.H. with gifts of purses and
+8
+9
+10
+11
+12
+13
+14
+15
+bathingsuits?
+MR. YAREMA: Object to the form.
+A Fifth.
+18
+Q Do you recall that Jeffrey Epstein
+19
+provider
+with a blue 2000 Dodge Neon which 20
+had been rented for her?
+21
+MR. YAREMA: Object to the form.
+22
+A Fifth.
+23
+Q Do you recall that Jeffrey Epstein
+124
+ordered that roses be delivered to
+at the
+25
+88
+end of a play performance during her senior year?
+MR. YAREMA: Object to the form.
+A Fifth.
+THE VIDEOGRAPHER: Counsel, can we stop
+for one minute?
+MS. EZELL: Sure.
+THE VIDEOGRAPHER: Off the video record
+11:43 a.m.
+(Short pause.)
+(Whereupon at this point in time, Mr.
+Langino left the proceedings.)
+THE VIDEOGRAPHER: Back on the video
+record 1:43 a.m.
+CROSS EXAMINATION (CONTINUED)
+BY MS. EZELL:
+Q Were you present in October 2005 when
+the Palm Beach Police Department raided Jeffrey
+Epstein's home?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q You and others were aware that there
+would be a raid at that time; were you not?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Who informed you that there would be a
+89
+raid on the house?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you participate in the removal of
+nude photographs, sex toys, computer records from
+358 El Brillo Way prior to the raid?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you know who removed those objects at
+that time?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you remember that at times Jeffrey
+Epstein paid
+to just sleep in his bed in the
+nude?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you recall at times he paid her to
+just cuddle with him?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you ever drive
+to or from 358
+El Brillo Way?
+MR. YAREMA: Object to the form.
+A Fifth.
+23 (Pages 86 to 89)
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+112
+13
+14
+15
+16
+17
+118
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+7
+8
+9
+10
+12
+13
+14
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+90
+Q Did you ever know
+to drive
+A.H. to or from 358 El Brillo Way?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you remember the houseman at that
+time as being Alfredo Rodriguez?
+MR. YAREMA: Object to the form.
+A Fifth. (
+Q Do you remember Alfredo Rodriguez being
+instructed to drive A.H. to or from 358 El Brillo
+Way?
+MR. YAREMA: Object to the form.
+A Fifth. (
+Q Do you recall a time when Alfredo
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+Rodriguez discovered
+asleep upstairs naked? 15
+MR. YAREMA: Object to the form.
+A Fifth.
+17
+Q Were you aware Jeffrey Epstein
+18
+repeatedly asked
+.. to allow him to photograph
+19
+her in the nude?
+20
+MR. YAREMA: Object to the form.
+21
+A Fifth.
+22
+Q Did you allow Jeffrey Epstein to take
+23
+photographs, nude photographs of you?
+24
+MR. YAREMA: Object to the form.
+25
+91
+A Fifth.
+Q Do you recall a time when
+gave in
+and did allow Jeffrey Epstein to photograph her
+while nude?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you ever see any of those
+photographs taken by Jeffrey Epstein of
+in
+the nude?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you know whether those photographs
+were ever developed?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you know what kind of camera Jeffrey
+Epstein liked to use when taking photographs of
+women posing in the nude?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you ever hear here Jeffrey Epstein
+tell
+hat she needed to lose ten pounds?
+MR. YAREMA: Object to the form.
+A Fifth. (
+Q Did you ever hear here him tell her that
+1
+2
+4
+5
+6
+8
+10
+11
+12
+13
+14
+15
+16
+18
+19
+20
+21
+23
+24
+92
+he would pay her 1,000 or $1,500 if she would
+lose ten pounds?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you know
+to be a good student?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did it appear that you that
+vas
+smart?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you observe that
+was concerned
+about her grades?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you recall Jeffrey Epstein expressing
+interest in
+I college ambitions?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Have you known Jeffrey Epstein to brag
+about donations he's made to colleges like NYU,
+Columbia, Harvard and Wharton?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you know that
+wanted very much
+93
+to go to school in New York at NYU or at
+Columbia?
+MR. YAREMA: Object to the form.
+A Fifth.
+• Did you know that Jeffrey Epstein
+promised to help her get into one of those
+schools?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you know whether he did help?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you know whether he offered to pay
+some of her college expenses?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you ever observe Jeffrey Epstein
+working with
+• on her college applications?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you ever se
+just hanging out
+at Jeffrey Epstein's house studying while nude?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you know that Jeffrey Epstein gave
+24 (Pages 90 to 93)
+
+
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+119
+20
+21
+22
+23
+24
+25
+2
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+94
+96
+A.H. airline tickets and theater tickets in New
+York?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you and
+ever go shopping
+together?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you call
+once and ask her to go
+shopping with you for Jeffrey Epstein on his
+birthday?
+MR. YAREMA: Object to the form.
+… A Fifth.
+Q Did you and
+purchase adult sex toys
+to use for Jeffrey Epstein's birthday, as a show,
+for him?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Are you aware that Jeffrey Epstein told
+A.H. he would pay her to bring other young girls
+to give him massages?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you know that Jeffrey Epstein paid
+A.H. $200 for each girl that she brought to him,
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+19
+20
+21
+23
+24
+25
+95
+to give him a massage?
+MR. YAREMA: Object to the form.
+1
+2
+A Fifth.
+MR. GOLDBERGER: I guess we will have to
+take a break now, if that's all right with
+you.
+4
+5
+6
+MS. EZELL: Okay.
+THE VIDEOGRAPHER: 11:50 a.m., going off
+the video record.
+MR. GOLDBERGER: I will be done at 1:15
+so we can go until 1:30.
+(Pause in the proceedings.)
+THE VIDEOGRAPHER: We are back on the
+video record at 1:36 p.m.
+CROSS EXAMINATION (CONTINUED)
+8
+9
+10
+I1
+12
+13
+114
+15
+BY MS. EZELL:
+Q Ms.
+I did you ever have dinner 17
+at Jeffrey Epstein's house, with David
+18
+Copperfield as a guest, when A.H. was present?
+19
+MR. YAREMA: Object to the form.
+20
+A The Fifth.
+21
+Q Have you met David Copperfield?
+22
+A Fifth.
+23
+Q Have you ever been given tickets to go
+24
+see one of his shows?
+25
+A The Fifth.
+Q Do you know if typically girls who
+Epstein knew, were given tickets to go to the
+show, then invited back stage?
+MR. YAREMA: Object to the form.
+A Fifth.
+THE VIDEOGRAPHER: Can you speak up?
+THE WITNESS: (Adjusts microphone.)
+Q Did A.H. ever tell you that David
+Copperfield tried to feel her butt during dinner?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you ever hear Jeffrey Epstein
+telling any of the young women who came to give
+him massages, that he was a brain scientist?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you know
+A Fifth.
+Q And from now on I will use the initials
+Do you know tha
+- visited Jeffrey
+Epstein at 358 El Brillo Way some 15 to 20 times?
+MR. YAREMA: Object to the form?
+A Fifth.
+Q Did you ever interact witt
+while
+97
+she was there to give a massage?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you know that at the time she was
+visiting Mr. Epstein and providing massages, she
+was under the age of 18?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Do you recall being introduced to
+by Mr. Epstein?
+MR. YAREMA: Object to the fonn.
+A Fifth.
+Q Do you recall that Jeffrey Epstein
+structed you a
+o kiss and fondle each
+ther around the breasts and buttocks whi
+massaging him?
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did you ever see Mr. Epstein use a large
+vibrator/massager on
+MR. YAREMA: Object to the form.
+A Fifth.
+Q Did Jeffrey Epstein ever ask you to
+purchase a digital camera for him to giv
+MR. YAREMA: Object to the form.
+25 (Pages 94 to 97)
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+14
+15
+16
+18
+19
+20
+22
+23
+24
+25
+98
+100
+A Fifth.
+Q Did you know that Jeffrey Epstein gave
+A.D. a digital camera?
+MR. YAREMA: Object to the form.
+A Fifth.
+MS. EZELL: I don't have any other
+questions. Thank you.
+MR. GOLDBERGER: You still have your
+microphone on. You must have something on
+your mind, Brad.
+REDIRECT EXAMINATION
+BY MR. EDWARDS:
+Q Ms.
+, through the whole day
+you've taken the Fifth on just about every single
+question. Is there any reason why we should not
+presume that the answer to these questions would
+incriminate you?
+MR. YAREMA: Object to the form.
+A The Fifth.
+Q The reason that you have taken the Fifth
+is because the questions you have been asked
+would have been answered in the affirmative and
+you're afraid of prosecution for your
+involvement, true?
+MR. GOLDBERGER: Don't answer that
+1
+2
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+125
+99
+question. It interferes with the
+attorney/client relationship that I have
+with Ms.
+and any discussions she
+and I may have had would come under that
+privilege.
+You can try and dance around that, but
+I'm simply not going to allow her to answer
+that question. If you want to bring it up
+with the Judge, you can.
+MR. EDWARDS: Thanks, Jack.
+MR. GOLDBERGER: Okay.
+THE VIDEOGRAPHER: Off the video record
+at 1:41 p.m.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+THE COURT REPORTER: You're ordering
+this, Brad?
+15
+MR. EDWARDS: Yes. Copies?
+MS. EZELL: Yes.
+MR. YAREMA: Yes:
+THE COURT REPORTER: And Adam wanted i g
+is that right?
+MR. EDWARDS: Yes.
+(Time noted: 1:45 p.m.)
+THE STATE OF FLORIDA)
+COUNTY OF PALM BEACH)
+1, TERRI BECKER, a Registered
+Professional Reporter and Notary Public for the
+State of Florida at Large, do hereby certify that
+I reported the vidcotaped deposition of
+, the WITNESS, called by the PLAINTIFF
+in the above-entitled action; that the witness
+was duly sworn by me; that the foregoing pages,
+numbered from I to 104, inclusive, constitute a
+true record of the deposition by said witness.
+1 further certify that 1 am not attomey
+or counsel of any of the parties, nor a relative
+or employee of any attorney or counsel connected
+with the action, nor financially interested in
+the action.
+WITNESS MY HAND and official seal in the
+City of West Palm Beach, County of Palm Beach,
+State of Florida, this 19th day of April 2010.
+Seeker
+TERRI BECKER, Registered
+Professional Reporter and
+Notary Public, State of Florida
+at Large. My Commission expires
+March 13, 2011.
+101
+THE STATE OF FLORIDA)
+COUNTY OF PALM BEACH)
+The foregoing certificate was
+acknowledged before me this
+day of
+2010.
+Notary Public, State of Florida.
+My commission No.
+Expires March 13, 2011.
+26 (Pages 98 to 101)
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+102
+104
+1,
+I, do hereby
+certify that I have read the foregoing transcript
+of my deposition given on April 13, 2010; that
+together with the correction page attached hereto
+voting changes in form or substance, if any,
+s true and correct
+1
+2
+3
+I do hereby certify that the deposition
+of
+was submitted to the witness
+for reading and signing; that after she had
+stated to the undersigned Notary Public that she
+had read and examined her deposition, she signed
+the same in the presence of the undersigned
+authority on the
+_ day of
+2010.
+8
+9
+ERE
+15
+16
+17
+20
+21
+24
+25
+U.S. LEGAL SUPPORT
+Registered Professional Reporters
+444 West Railroad Avenue
+West Palmn Beach, Florida 33401
+(561)835-0220
+April 19, 2010
+ATTERBURY GOLDBERG, WEISS
+One Clearlake Centre, Suite 1400
+50 Australian Avenue Soul
+Nest Palm Beach, Florida 3346
+ATTENTION: JACK GOLDBERGER, ESQ.
+In Re: DOE I EPSTEIN
+Deposinice of
+Since counsel have agreed that you nur
+have the witness read and sign your copy of th
+witness' use in entering any changes to the
+deposition.
+Thank you for your prompt attention.
+CS. LEGAL SUPPORT
+TERRI BECKER, Registered
+Professional Reporter, Notary
+Public, State of Florida at
+Large. My commission expire
+March 13, 2011
+CC: Bradley Edwards, Esq
+Adam Horowitz, Esq.
+Katherine Ezell, Esq
+David Yareina, Esq.
+103
+ERRATA SHEET
+In Re: DOE L EPSTEIN
+DO NOT WRITE ON TRANSCRIPT
+ENTER CHANGES HERE:
+PAGE LINE CHANGE
+REASON
+THE STATE OF FLORIDA)
+COUNTY OF PALM BEACH
+I DO HEREBY CERTIFY THAT I
+ppeared before me and stated that she has rea
+er deposition; further, that this Errata Stree
+was signed in my presence on this.
+...day
+27 (Pages 102 to 104)
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
diff --git a/vision-fixhub/ds9-unparsed-05/b2e53f0567a9816ff9fedf94564a5d000625f026c12613790ea2a7e3b42cbe51.receipt.json b/vision-fixhub/ds9-unparsed-05/b2e53f0567a9816ff9fedf94564a5d000625f026c12613790ea2a7e3b42cbe51.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..267b7ad39b09874ec225e1ab8aeeedfaca154f11
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b2e53f0567a9816ff9fedf94564a5d000625f026c12613790ea2a7e3b42cbe51.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1375,
+  "dataset": "marble-joined",
+  "doc_id": "b2e53f0567a9816ff9fedf94564a5d000625f026c12613790ea2a7e3b42cbe51",
+  "engine": "marble-apple-vision",
+  "event_count": 39,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "627db61ffca16a298b4cbd98521b1be85f1ad164b91ca19804327f8b64e85f9b",
+  "output_sha256": "1ac8c85530e7f7f566e24b9500f24ff6803a73ecdee295c4e04965e020e7f817",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b325b83fbbf646e0e06ee80f99796b81cca7765d097048cba34126c8ed887ee7.md b/vision-fixhub/ds9-unparsed-05/b325b83fbbf646e0e06ee80f99796b81cca7765d097048cba34126c8ed887ee7.md
new file mode 100644
index 0000000000000000000000000000000000000000..6a64f6efbe953580379051077013c490f72a23f7
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b325b83fbbf646e0e06ee80f99796b81cca7765d097048cba34126c8ed887ee7.md
@@ -0,0 +1,126 @@
+OLY-61
+
+
+TO: Custodian of Records
+Broward Center for the Performing Arts
+201 SW Fifth Avenue
+Fort Lauderdale, FL
+Unwed States District Court
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-61
+SUBPOENA FOR:
+PERSON
+X
+DOCUMENTS OR OBJECTS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury ofthe United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+June 26, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+THE DOCUMENTS LISTED ON ATTACHMENT.
+ease poordinate you perine with this subpoena and entire tread and tige, and teation e!
+your appearance with Special Agend
+CLERK
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+STARES DATINGT
+(BY) DEPUTY CLERK
+DATE:
+June 13, 2007
+This subpoena is issued upon application
+*If not applicable, enter "none."
+Name, Address and Phone Number of Assistant ILS, Attorney
+500 So. Australian Avenue, Suite 400
+West Balm Roach FL, 33401-6235
+Tel:
+Fax:
+To be used in lieu of AOTIO
+FORM ORD-227
+JAN.86
+
+
+Custodian of Records
+Broward Center for the Performing Arts
+201 SW Fifth Avenue
+Fort Lauderdale, FL
+fax 954 462-3541
+ATTACHMENT TO GRAND JURY SUBPOENA
+FGJ 07-103 OLY-61
+A copy of a Playbill or program for any performances by David Copperfield
+at the Broward Center for the Performing Arts during the period of January 1, 2004
+through December 31, 2005.
+For the period of January 1, 2004 through December 31, 2005, all records and
+information, whether stored electronically or in hard copy, referring or relating to
+tickets/reservations made for or made by:
+(1) Jeffrey Esptein;
+(5) Lesley Groff;
+(6) Janusz Banasiak;
+(7) Alfredo Rodriguez;
+
+
+U.S. Departme
+if Justice
+United States Attorney
+Southern District of Florida
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401-6235
+(561) 820-8711
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Squthern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+authenticity. I-herefore, you may be able to avoid appearing personally at the grand
+jury/trial at the time and place specified by completely filling out the attached Certifienti
+and Inventory and immediately returning it with the records to Special Agent
+FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to June 26, 2007.
+Sincerely,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+BY:
+ASSISTANT UNITED STATES ATTORNEY
+
+
+CERTIFICATION OF BUSINESS RECORDS
+1, the undersigned,
+employed bylassociated with
+position of
+, declare that I am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+Date of execution:
+Place of execution:
+Signature:
+
+
+• APPENDIX A
+DOCUMENT INVENTORY
+The documents submitted are as follows:
+Signature of Records Custodian:
diff --git a/vision-fixhub/ds9-unparsed-05/b325b83fbbf646e0e06ee80f99796b81cca7765d097048cba34126c8ed887ee7.receipt.json b/vision-fixhub/ds9-unparsed-05/b325b83fbbf646e0e06ee80f99796b81cca7765d097048cba34126c8ed887ee7.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a22576e3f1e2627752e5a17a6064e640aa136042
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b325b83fbbf646e0e06ee80f99796b81cca7765d097048cba34126c8ed887ee7.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -72,
+  "dataset": "marble-joined",
+  "doc_id": "b325b83fbbf646e0e06ee80f99796b81cca7765d097048cba34126c8ed887ee7",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "0477030cc1e67877c077ff8c5cbc3d3168447fd804ce46cd27f257ac20af7059",
+  "output_sha256": "2e2bec0156dfae1f5e35824c01e1db361d77f52664aeaeb861c245fc6bd8409d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b33d962f145ef4651378776869c9afb4bb3a2bdecef2e63c480895dadb94d280.md b/vision-fixhub/ds9-unparsed-05/b33d962f145ef4651378776869c9afb4bb3a2bdecef2e63c480895dadb94d280.md
new file mode 100644
index 0000000000000000000000000000000000000000..faffbd0ae54441515986237167909d267b72f374
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b33d962f145ef4651378776869c9afb4bb3a2bdecef2e63c480895dadb94d280.md
@@ -0,0 +1,141 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+Miami, FL 33132-2111
+(305) 961-9299
+99 NE. 4 * Street
+Facsimile: (305) 530-6444
+November 30, 2007
+DELIVERY BY FACSIMILE
+Jay P. Lefkowitz, Esq
+Kirkland & Ellis LLP
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4675
+Re: Jeffrey Epstein
+Dear Jay:
+I write in response to your recent e-mails and letters regarding victim notification and other
+issues. Some of these issues also are addressed in the U.S. Attorney's letter to Mr. Starr, but in light of
+our discussions, I believe a separate response is needed
+In a recent e-mail, you write that you were surprised at the tone of my e-mail of November 27,
+2007. That tone was engendered by the continuing failures to abide by the terms of the Non-Prosecution
+Agreement, unfounded allegations of misconduct on the part of our office, attacks upon our investigation
+and the victims in the press, and the mounting evidence that you did not enter into our plea negotiations
+in good faith. This letter and U.S. Attorney Acosta's letter are the last opportunity for your client and his
+entire defense team to conform unwaveringly to all of the terms of the Non-Prosecution Agreement. As
+stated by the U.S. Attorney in his letter:
+Accordingly, please provide us with a definitive statement, signed by your client, of his
+intention to abide by each and every term of the Agreement by close of business on
+Tuesday, December 4, 2007. By that time, you must also provide us with the agreements)
+with the State Attorney's Office and a date and time certain for the plea and sentencing,
+which must occur no later than December 14, 2007. If we do not receive these items by
+that time, we will deem the agreement to be rescinded and will proceed with the
+prosecution. There must be closure in this matter.
+Before I address your continued allegations of some sort of misconduct on the part of the Office
+for trying to abide by both the letter of the Agreement and of the law, I need to address you and your
+client's failure to comply with the Agreement.
+Three weeks ago we spoke about the failure to set a timely plea and sentencing date. At that time,
+you assured me that a new prompt date would be set, and that the delay in scheduling the date was caused
+by the unavailability of Judge MeSorley. You promised that a date would be set promptly. On November
+15th, Rolando Garcia met with Barry Krisher on another matter, and was told by Mr. Krisher that he had
+just spoken with Jack Goldberger, and Mr. Epstein's plea and sentencing were set to occur on December
+14, 2007. Since that time, we have tried to confirm the date and time of the hearing, to include that
+information in the victim notification letters. You continue to refer to the plea and sentencing as though it
+will be in January; Mr. Krisher's office has not confirmed any date; and Mr. Goldberger told Marie
+that "there is no date."
+I have repeatedly told you that a delayed guilty plea and sentencing - now more than two months
+beyond the original deadline - is unacceptable to the Office. Contrary to your past assertions, the Non-
+Prosecution Agreement does not contemplate a staggered plea and sentencing. Instead, the Agreement
+contemplates a combined plea and sentencing followed by a later surrender date for Mr. Epstein to begin
+serving his jail sentence. As you will recall, the plea and sentencing hearing originally was to occur in
+early October 2007, but was delayed until October 26th to allow Mr. Goldberger to attend. It was
+delayed again until November to allow you to attend. You have provided no showing of how you and
+your client have used your best efforts to insure that the plea and sentencing occur in November. In fact,
+we recently learned that a plea conference had been scheduled with Judge MeSorley for November 20,
+
+
+2007, but was canceled at the request of the parties, not the judge. Judge MeSorley has not been away
+for any extended period, and there is no basis for your assertion that the judge is the cause of any past or
+future delay. Mr. Epstein currently has four Florida Bar members on his defense team, so attorney
+scheduling is not an adequate basis for delay.
+Three weeks ago I also asked you to provide our Office with the terms of the Plea Agreement with
+the State Attorney's Office. It is now more than two months since the signing of the Non-Prosecution
+Agreement and we have yet to see any formal agreement, or even a list of essential terms of such an
+agreement. The only conclusion that we can draw is that you are trying to avoid providing the Office
+with adequate time to review your agreement prior to the change of plea and sentencing to determine
+whether Mr. Epstein is complying with the terms of the Non-Prosecution Agreement.
+Your letters make reference to a failure by the United States to abide by the "spirit" of the
+Agreement, but recent correspondence shows that Mr. Epstein hopes to serve his sentence on "work
+release." This is plainly contrary to both the terms and spirit of the Agreement. The Agreement clearly
+indicates that Mr. Epstein is to be incarcerated, and during your joint meeting with representatives of our
+office and the State Attorney's Office, the parties specifically discussed that Mr. Epstein would serve his
+time in solitary confinement at the Palm Beach County Jail to obviate your safety concerns. In addition
+to the terms of the Agreement, the Florida Department of Corrections does not allow persons who are
+registered sex offenders to participate in "community release" (which includes "work release"). Since
+Mr. Epstein will have to register as a sex offender promptly after his guilty plea and sentencing, he will
+not be eligible for such a program. Thus, the U.S. Attorney's Office is simply putting you on notice that
+it intends to make certain that Mr. Epstein is "treated no better and no worse than anyone else" convicted
+of the same offense. If Mr. Epstein is somehow allowed to participate in a work release program despite
+the Department of Corrections' rules and practices, the Office intends to investigate the reasons why an
+exception was granted in Mr. Epstein's case.
+Next, let me address various accusations that you and Mr. Starr, amongst others, have raised. You
+have repeatedly alleged that attorneys in our office and agents of the FBI have leaked information to the
+press in an effort to affect possible civil litigation with Mr. Epstein. This is untrue. There has been no
+contact between any member of the press and any employee of our office or the FBI since you incorrectly
+accused investigators of telling "Vanity Fair" about Mr. Starr's employment by Mr. Epstein several
+months ago. As you have been told before, prior to that, the press had provided information to the FBI,
+but no comment was ever made about the ongoing investigation, it was simply referred to as an "open
+investigation." Your accusations on this point are ironic in light of the amount of information that Mr.
+Epstein's team has provided to the press, much of which is completely inaccurate and which is obviously
+intended to intimidate your client's victims. We intend to continue to refrain from commenting or
+providing information to the press. We would ask that your client and all of his representatives do the
+same.
+Mr. Starr's letter to Assistant Attorney General Alice Fisher contains several false statements and
+accusations. First, Mr. Epstein was never forced to enter into any agreement and all terms of the
+agreement were fully negotiated, including the terms regarding the payment of monetary damages to the
+victims under 18 U.S.C. § 2255. In fact, some of those terms were re-negotiated as part of the
+Addendum. Second, if Mr. Epstein's cadre of attorneys was concerned about a way to test the validity of'
+the victims" claims prior to placing the names of those victims on the list prepared by our office, that term
+could have been negotiated. In fact, at one of our early meetings, Roy Black raised that concern, and
+possible solutions were contemplated by our office prior to the negotiations. However, since none of Mr.
+Epstein's team of attorneys requested the inclusion of such a term, it was omitted from the Agreement.
+To the extent that you now object to the Agreement that you negotiated, this is akin to "buyer's
+remorse." However, you and Mr. Starr have, instead, made claims to the Justice Department that these
+thoroughly negotiated terms "leave[] wide open the opportunity for misconduct by federal investigators."
+You then misinterpret several statements that were included in correspondence - at your insistence - as
+proof that the designated victims have invalid claims. (
+Let me make clear that each of the listed
+individuals are persons whom the Office identified as victims as defined in Section 2255, that is, as
+persons "who, while a minor, was a victim of a violation of section ... 2422 or 2423 of this title." In
+other words, the Office is prepared to indict Mr. Epstein based upon what Mr. Starr refers to as Mr.
+Epstein's "interactions" with these individuals. This conclusion is based upon a thorough and proper
+
+
+investigation - one in which none of the victims was informed of any right to receive damages of any
+amount prior to the investigation of her claim. Each of the victims' claims was corroborated - again,
+prior to anyone being notified of a potential civil claim for damages. In fact, after the Agreement was
+signed, the FBI only had the opportunity to inform three victims of the resolution of the matter before
+you raised complaints and, in deference to your request, the Office asked that they defer further
+notifications. The Office agrees that it is not a party to, and will not take a role in, any civil litigation, but
+the Office can say, without hesitation, that each person on the list was a vietim of Mr. Epstein's criminal
+Mr. Starr's letter also suggests that the number of victims to whom Mr. Epstein is exposed by the
+Agreement is limitless. As you know, early drafts of the Agreement contained a numerical limit of 40
+victims. At your request, that number was removed. The Office repeatedly confirmed that the number
+would not exceed 40, after conducting additional investigation, it was reduced to 34, and we recently
+removed another name because, despite the fact that Mr. Epstein offensively touched the victim, in our
+opinion, the touching was not "sexual" enough to properly include her as a victim as defined in Section
+2255. Once the list is provided to you, if you have a good faith basis for asserting that a victim never met
+Mr. Epstein, we remain willing to listen and to modify if you convince us of your position.
+Mr. Starr also asserts that the Office has "improperly insisted that the chosen attorney
+representative should be able to litigate the claims of individuals, which violates the terms of the
+agreement and deeply infringes upon the spirit and nature of the Agreement." Again, this was a term
+that could have been discussed and negotiated prior to entering into the Agreement. At least five
+decides that there is a conflict is something to be addressed by him, but the Agreement speaks for itself.
+By:
+Sincerely,
+.. Alexander Acost
+nited States Attorne
+Jeffrey Sloman
+First Assistant United States Attorney
+cc: R. Alexander Acosta, U.S. Attorney
+AUSA A
diff --git a/vision-fixhub/ds9-unparsed-05/b33d962f145ef4651378776869c9afb4bb3a2bdecef2e63c480895dadb94d280.receipt.json b/vision-fixhub/ds9-unparsed-05/b33d962f145ef4651378776869c9afb4bb3a2bdecef2e63c480895dadb94d280.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b48b4ce64262454abc85406218138a98d8eeb3de
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b33d962f145ef4651378776869c9afb4bb3a2bdecef2e63c480895dadb94d280.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "b33d962f145ef4651378776869c9afb4bb3a2bdecef2e63c480895dadb94d280",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "f65f733924f54583bd64fb2218efe75055c5a9a3de62c4f54dd9c0c86cad664b",
+  "output_sha256": "ed2fa0529a86f0062213301ac339497cef7b3d5e9a798bf9a4f6ccdff4389a41",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b33df814175ee4dd83c67f27cb4314ceb5d6f260b5ac94e78275d4cf0e3b8937.md b/vision-fixhub/ds9-unparsed-05/b33df814175ee4dd83c67f27cb4314ceb5d6f260b5ac94e78275d4cf0e3b8937.md
new file mode 100644
index 0000000000000000000000000000000000000000..2c051e1e6434408cdbae693346887cd59547b5e6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b33df814175ee4dd83c67f27cb4314ceb5d6f260b5ac94e78275d4cf0e3b8937.md
@@ -0,0 +1,3924 @@
+Statements
+
+
+ZICHERMAN,IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .......
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .....••I//////•////////////II//I/I//.
+Your Messages
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD June 30, 2007
+THROUGH
+July 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2007
+3
+9
+CIO AMERICAN YACHT HARBOR
+6100 RED HOOK SUTE B-3
+QUAETERS #2
+ST THOMAS VI 00802-1348
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+78,153,540
+12,552,872
+$90,706,412
+77,359,175
+13,347,237
+here are no 'Stop Loss" orders or other pending bu
+r sell open orders on file for your accoun
+Market Value of Your Portfolio
+$12,552,872
+$3185235: $7407439
+Cash & Equivalent
+Equities
+578, 153.540
+= $81,581,379
+....
+....
+Current market value
+Last statement's market value
+Short market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859
+027
+SPC This statement shouid be retained por yous records. See reverse sides for try portant into.
+See reverse side for important information.
+08/01/07.07:19 001
+
+
+2 of 9
+027
+08/01/07 07:19 001|
+Bear, Steams Securities Corp
+One Metrotech Center North
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+3 org
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Funds Deposited
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Money Fund
+Dividends/Interest Charged
+Amount Debited
+Net Cash Activity
+Closing Balance.
+Same day tansfers of cash between acount types are not included in this
+section: such transfers, as well as details for all other transactions this period,
+appear in Transaction Detail.
+THIS PERIOD
+$-7,407,438.53
+1,289,086.17
+7,587,964.31
+5,124,265.26
+41,600.00
+10,457,933.00
+$24,500,848.74
+.....
+-125,700.00
+-16,934,242.93
+-33,467.28
+517,09341021
+7,407,438.53
+$0.00
+Cash Balance Summary
+Margin
+Net Cash Balance
+OFENING
+-7,407,438.53
+$-7,407,438.53
+CLOSING
+0.00
+$0.00
+027
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+Margin Int. Paid
+THIS PERIOD
+62,958.50
+0.00
+562.958.50
+-33,467.28
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+08/01/07 07:19 001|
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD June 30, 2007
+THROUGH
+July 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+June 29, 2007
+YEAR TO DATE
+834,823.38
+44.54
+...
+$834,867.92.
+-40,905.81
+12,552,872
+78,153,540
+$90,706,412
+Your Portfolio
+Allocation
+Cash & Equivalent -
+14%
+'Equities
+86%
+Unshaded portions denole debit balance and'or short
+
+
+4 of g
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD June 30, 2007
+THROUGH
+July 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2007
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST, 30 DAY AVG YIELD 5,2100%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+QUANTITY
+12,552,871.62
+PRICE
+1.0000
+MARKET
+VALUE
+12.552,872
+$12,552,872
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department. The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O= Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers use different ratings systems and have normalized them as follows: B = Buy; H = Hold; S = Sell (this may not always
+correspond directly to the underlying rating system used by each provider or BSC), The ratings information contained herein is for informational purposes only and is not intended
+to provide tax, legal, or investment advice. Bear Stearns is neither soliciting any action based on such information, nor endorsing any recommendation or opinion expressed by
+any independent, third-party research provider. The symbol indicates that continuing coverage of the subject company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost, Customers can access this research
+DESCRIPTION
+APPLE INC
+BSC RATING: STOCK O/SECTOR MW
+BOYAR'S ALTERNATIVE VIEWPOINT
+RATING: S
+BEAR STEARNS COMPANIES INC
+BOMBARDIER INC-CL B SUB-VTG
+CHOICEPOINT INC
+SYMBOL/CUSIP
+AAPL
+CASH
+QUANTITY
+220,000
+PRICE
+131.7600
+MARKET
+VALLE
+28,987,200
+ARMAL MOONE
+ESTIMATED
+YIELD (%)
+BSC
+BDRBF
+CPS
+CASH
+CASH
+....
+CASH
+130,000
+20,000
+....
+100,000
+121.2200
+6.0610
+-...
+38.7400
+15,758,600
+121,220
+3.874,000
+166,400
+1.0559
+027
+08101/07:07:19 001
+
+
+5 of g
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+COLGATE PALMOLIVE CO
+SCKINGHAM RESEARCH AN
+MATING:
+DEERFIELD TRIARC CAP CORP
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+CL
+DFR
+ESWW
+LEH
+WYNN
+CASH
+CASH
+CASH
+CASH
+MRGN
+QUANTITY
+56,200
+362,691
+100,000
+100,000
+160,000
+LEHMAN BROTHERS HOLDINGS INC
+WYNN RESORTS LTD
+BSC RATING: STOCK O/SECTOR MW
+WALL STREET STRATEGIES
+RATING: B
+Total Equities& Options
+TOTAL EQUITIES
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+027
+PRICE
+66.0000
+10.9700
+0.7500
+62.0000
+96.5600
+MARKET
+3,709,200
+3,978,720
+75,000
+6,200,000
+15,449,600
+$78,153,540
+$78,153,540
+ANNE MATER
+80,928
+609,321
+60,000
+$916,649
+$916,649
+$916,649
+$90,706,412
+08/01/07 07:19 001
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD June 30,2007
+THROUGH
+July 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29,2007
+ESTIMATED
+YIELD (S
+2.1818
+15.3145
+0.9677
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of g
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT TRADE
+DATE
+TRANSACTION
+07/13/07
+07/10/07
+BOUGHT
+DESCRIPTION
+BOMBARDIER INC-CL B SUB-VTG
+I IS 070710
+07/26/07
+- 07/23/07
+SOLD
+7/27/0
+07/24/07
+SOLD
+DEERFIELD TRIARC CAP CORP
+ANG PRICE SHOWN-DETAILS ON REQ
+UNSOLICITED
+TOTAL
+DEPOSITS AND WITHDRAWALS
+DATE
+07/13/07
+TRANSACTION
+FUNDS REC
+07/17/07
+FUNDS REC
+07/17/07
+FUNDS REC
+DESCRIPTION
+FNDS WIRED TO CITIBANK FROM
+CS LIC PRIME BROKER
+ENDS WIRED TO CITIBANK FROM
+EMORGAN CHASE BANK
+FNDS WIRED TO CITIBANK FROM
+MELLON RANK NA
+TOTAL
+027
+SYMBOLCUSIP
+BDRBF
+DFR
+DFR
+QUANTITY
+20,000
+17,500
+-82,500
+DEBIT AMOLNT
+1,695.26
+122,570.00
+5,000.000.00
+$5,124,265.26
+08/01/07.07:19 001
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD June 30,2007
+THROUGH
+July 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2007
+DEBIT AMOUNT
+125,700.00
+PRICE
+6.28500
+3.46190
+12.84270
+$-125,700.00
+... . . . . . . . . . : :
+234,529.64
+1.054,556.53
+$1,289,086.17
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+7 org
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+06/30/07
+TRANSACTION
+DESCRIPTION
+OPENINGBALANCE R
+07/02/07
+BOUGHT
+07/02/07
+DIVIDEND
+07/02/07
+REINVEST
+07/13/07
+BOUGHT
+Cinssansasssassassnıaaıaaıııaanani
+07/13/07
+BOUGHT
+07/13/07
+SOLD
+0747/07
+*''BOGHI
+07/18/07
+
+07/23/07
+07/26/07
+07/27/07
+BOUGHT
+"SOLD'
+SOLD
+BOUGHT,
+BOUGHT
+ISETENSN SHAN CENENI CLA")
+DREYFUS CASH MANAGEMENT-CLA
+METHIY DN SARES
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+DIVIDEND REINVEST
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+disasassnsssssssssssssıııııııııssnnsnssssssssssısssısıııssassnssnsssss sınsıınıııaas
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+REYFUS CASH MANAGEMENT-CL"
+INSTITUTIONAL SHARES
+"DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+''DREYFUS CASH MANAGEMENT-CLA"
+INSTITUTIONAL SHARES
+"DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+"DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+SYMBOUCUSIP
+DICXX
+bICX
+DICXX
+DICXX
+DICXX
+DICXX
+DICXX
+BICXX
+DICXX
+DICXX
+DICXX
+027
+QUANTITY
+3,185,234.50
+457,933
+21,358.50
+4,000,000
+6.001.695.26
+-125,700
+5,000,000
+122,570
+7.407,438.53
+33,467.28
+234.529.64
+1,096,156.53
+PRICE
+1.0000
+1.0000
+1.0000
+1.0000
+1.0000*
+1.0000
+1.0000**
+1.0000
+1.0000
+1.0000
+08/01/0707:19 001
+LEARED THAOUGH П
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD June 30, 2007
+THROUGH
+July 31, 2007
+ACCOUNT NUMBER
+TAPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2007
+DEBIT AMOUNT
+457,933.00
+21,358.50
+21,358.50
+4,000,000.00
+6,001,695.26
+125,700.00
+'5.000,000.00
+122,570.00
+7.407, 438.53
+33,467.28
+••III•
+234,529.64
+1,096,156.53
+1015
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+8 of 9
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MONDAY
+07/31/07
+TOTAL
+TRANSACTION
+DESCRIPTION
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+DESCRIPTION
+07/27/07
+BEAR STEARNS COMPANIES INC
+REC 07/17/07 PAY 07/27/07
+TOTAL
+INTEREST
+DATE
+07/23/07
+TOTAL
+DESCRIPTION
+INT DB
+06/21 - 07/20 @0F2.02779%
+BAL
+0 AVG
+MISCELLANEOUS
+07/02/07
+07/02/07
+07/13/07
+TRANSACTION
+JOURNAL
+JOURNAL
+JOURNAL
+DESCRIPTION
+FROM
+FROM LI
+FROM
+SYMBOUCUSIP
+BSC
+SYMBOUCUSIP
+SYMBOUCUSIP
+QUANTITY
+12,552,871.62
+PRICE
+QUANTITY
+130,000
+RATE (S)
+0.3200
+DEBIT AMOUNT
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD June 30, 2007
+THROUGH
+July 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29,2007
+DEBIT AMOUNT
+$-16,934,242.93
+$7.587,964.31
+41,600.00
+$41,600.00
+QUANTITY
+DEBIT AMOUNT
+027
+RATE (SI
+DEBIT AMOUNT
+33,467.28
+$-33,467.28
+CRECIT AMOUNT
+122,491.00
+335,442.00
+4,000,000.00
+08/01/07.07:19 001
+1---___...
+
+
+9 of g
+Transaction Detail (continued)
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+07/13/07
+07/18:07
+07/18/07
+07/23/07
+07/23/07
+TOTAL
+TRANSACTION
+OURNAL
+JOURNAL
+JOURNAL
+JOURNAL
+JOURNAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+FROM
+JOURNAL FROM TYPE 1 TO 2
+JOURNAL FROM TYPE 1 TO 2
+OURNAL FROM TYPE 1 TO 2
+JOURNAL FROM TYPE 1T02
+DEBIT AMOUNT
+7,407,438.53
+33,467.28
+$-7,440,905.81
+CRECIT AMOUNT
+6,000,000.00
+7,407,438.5
+33,467.28
+$17,898,838.81
+Your messages
+You are advised to promptly report any inaccuracy or discrepancy in your
+STOP
+****** Endof Statement******
+027
+08/01/07-07:19 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD June 30, 2007
+THROUGH
+July 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2007
+......
+.......
+........
+....... .
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD June 1,2007
+THROUGH
+June 29, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2007
+CIO AMERICAN YACHT HARBOR
+ST THOMAS VI 00802-1348
+Pursuant to your previously issued instructions, Bear Stearns Securities Corp, provides duplicate monthly statements and/or transaction confirmations to the
+third parties listed on the cover page of this statement, If you wish to modify or cease distribution to any of the recipients indicated, please contact your
+Investment Professional, This reminder notice will continue to be provided to you on your quarterly statements.
+Third Party
+J EPSTEIN & CO
+457 MADISON AVE 4TH FLOOR
+NEW YORK NY 10022
+027
+06/30/07-07:43 001
+4011
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ZICHERMAN,IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .......
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .....••.//////•///////////II//III//.
+Your Messages
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD June 1,2007
+THROUGH
+June 29, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2007
+3
+9
+#almonkelenon
+CIO AMERICAN YACHT HARBOR
+6100 RED HOOK SUTE B-3
+QUAETERS #2
+ST THOMAS VI 00802-1348
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET DEBIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+••••••••!!!!!!••••••
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+Market Value of Your Portfolio
+$3,185,235 : $-7,407,439
+$7,259,274
+81,581,379
+-7,407,439
+3,185,235
+$77,359,175
+92,012,420
+-14,653,245
+Cash & Equivalent
+Equities
+$81,581,379
+$84,753,146
+Current market value
+Last statement's market value
+Short market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of chacks or stocks, indicated as dollared to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+027
+SPC This statement shouid be retainel por out records." See reverse side for important intormation..
+
+
+2 of 9
+027
+06/30/07 07:43 001|
+Bear, Steams Securities Corp
+One Metrotech Center North
+
+
+3 or 9
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Funds Deposited
+Amount Credited
+Money Fund
+Funds Withdrawn
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERIOD
+$0.00
+5,190,917.09
+1,023,495.00
+$6,214,412.09
+-1,070,186.09
+-5,144,226.00
+-7,438.53
+-7,400,000.00
+$-13.621,850.62
+- 7,407,438.53
+$-7.407.438.53
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+Margin Int. Paid
+THIS PERIOD
+46,691.09
+0.00
+$46.691.09
+-7,438.53
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+SHOAT
+7,407,439
+$7,407,439
+Cash Balance Summary
+Margin
+Net Cash Balance
+OFENING
+CLOSING
+0.00
+-7,407,438.53
+60.00 $-7,407,438.5:
+027
+06/30/07 07:43 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD June 1,2007
+THROUGH
+June 29, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2007
+YEAR TO DATE
+771,864.88
+44.54
+...
+$771,909.42....
+-7,438.53
+LONG
+3,185,235
+81,581,379
+$84.766.614
+Your Portfolio
+Allocation
+Short Cash &Equivalent
+8%
+Cash & Equivalent
+3%
+'Equities
+89%
+Unshaded portions denole debi balance and'or short
+
+
+4 of g
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD June 1,2007
+THROUGH
+June 29, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2007
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+DREYFUS CASH MANAGEMENT-CLA
+NSTITUTIONAL SHARES
+ST, 30 DAY AVG YIELD 5,2200%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOL/CUSIP
+DICXX
+QUANTITY
+3,185,234.50
+1.0000
+MARKET
+VALUE
+-7,407,439
+3,185,235
+$-4,222,204
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department, The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O= Outperform; P = Peer Perform; U = Underperform, The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight, In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers use different ratings systems and have normalized them as follows: B = Buy; H = Hold; S = Sell (this may not always
+correspond directly to the underlying rating system used by each provider or BSC). The ratings information contained herein is for informational purposes only and is not intended
+to provide tax, legal, or investment advice, Bear Stearns is neither soliciting any action based on such information, nor endorsing any recommendation or opinion expressed by
+any independent, third-party research provider. The symbol indicates that continuing coverage of the subject company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost. Customers can access this research
+DESCRIPTION
+APPLE INC
+SC RATING: STOCK O/SECTOR M
+OYAR'S ALTERNATIVE VIEWPOIN
+RATING: S
+BEAR STEARNS COMPANIES ING
+SYMBOLCUSIP
+AAPL
+CASH
+QUANTITY
+220,000
+PRICE
+122.0400
+MARKET
+VALUE
+26,848,800
+ANNUAL NOME
+ESTIMATED
+YIELD (%)
+BSC
+CASH
+130,000
+140.0000
+18,200,000
+166.400
+0.9143
+027
+
+
+5 org
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+CHOICEPOINT INC
+COLGATE PALMOLIVE CO
+BSC RATING: STOCK O/SECTOR MW
+BUCKINGHAM RESEARCH RATING: B
+DEERFIELD TRIARC CAP CORP
+ENVIRONMENTAL SOLUTIONS
+WORLDWIDE INC
+LEHMAN BROTHERS HOLDINGS INC
+WYNN RESORTS LTD
+BSC RATING: STOCK O/SECTOR MV
+VALL STREET STRATEGIES
+RATING: B
+Total Equities & Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+CPS
+CL
+DFR
+ESWW
+WYNN
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CASH
+.........
+CASH
+CASH
+CASH
+CASH
+MAGN
+QUANTITY
+100,000
+56,200
+462,691
+100,000
+100,000
+160,000
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+027
+PRIN
+2.4500
+64.8500
+14.6300
+0.7800
+74.5200
+89.6490
+MARKET
+VALLE
+4,245,000
+3,644,570
+6,769,169
+78,000
+7,452,000
+14,343,840
+$81,581,379
+$81,581,379
+ANNEL NONE
+80,928
+777,321
+60,000
+$1,084,649
+$1,084,649
+$1,084,649
+$77,359,175
+06/30/07-07:43 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD June 1,2007
+THROUGH
+June 29, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2007
+ESTIMATED
+2.2205
+11.4833
+0.8052
+
+
+6 of 9
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TREE
+06/15/07
+06/15/07
+TOTAL
+TRANSACTION
+JOURNAL
+JOURNAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+WYNN RESORTS LTD
+JOURNAL FROM TYPE 1 TO 2
+КОНА РОЙ E 1 102
+SYMBOLCUSIP
+WYNN
+WYNN
+QUANTITY
+-160,000
+160,000
+DATE
+06/01/07
+06/06/07
+06/13/07
+06/18/07
+06/19/07
+06/27/07
+TRANSACTION
+FND WIRED
+FND WIRED
+FND WIRED
+FUNDS REC
+FND WIRED
+DESCRIPTION
+MDA#]
+INDS WIRED TO
+JEMORGUN CHASE BANK, NA
+MDA#MB447945FNDSWIRED TO
+EMOBCAN CHASE BANK. NA
+MDA#MB453372FNDS WIRED TO
+MEMORGAN CHASE BANK NA
+FNDS WIRED TO CITIBANK FROM
+CS LIC PRIME BROKER
+MDA#
+WENDS WIRED TO
+CITIBANK NE
+MDA#
+ENRAAN CHASE BANK NA
+DEBIT AMOLNT
+1,000,000.00
+1,000,000.00
+1,000,000.00
+1,023,495.00
+144,226.00
+1,000,000.00
+027
+PRICE
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD June 1,2007
+THROUGH
+June 29, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2007
+DEBIT AMOUNT
+aaaaaaaaaaaaaal
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+7 of g
+Transaction Detail (continued)
+DEPOSITS AND WITHDRAWALS (continued)
+
+TRANSACTION
+FND WIRED
+DESCRIPTION
+MDA#C|
+FNDS WIRED TO
+JEMORGAN CHASE BANK NA
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+06/01/07
+TRANSACTION
+DESCAIPTION
+OPENINGBALANCE
+06/01/07
+SOLD
+06/01/07
+DIVIDEND
+06/01/07
+REINVEST
+06/D6/07
+SOLD
+06/13/07
+SOLD
+06/18/01
+06/19/07
+06/27/07
+BOUGHT
+SOLD
+SOLD
+REYFUS CASH MANAGEMENT-CL
+INSTITUTIONAL SHARES
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+MONTHLY DIVIDEND
+DREYFUS CASH MANAGEMENT-CL A
+NSTITUTIONAL SHARE:
+DIVIDEND REINVEST
+STIONA SHAGEMENTCLA
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+DREYFUS CASH MANAGEMENT. CLA
+INSTITUTIONAL SHARES
+'DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+027
+DEBIT AMOUNT
+1,000,000.00
+$-5,144,226.00
+SYMBOUCUSIP
+DICXX"
+DICXX
+DICXX
+DICXX
+DICXX
+DICXX
+DICXX
+DICXX
+$1,023.495.00
+QUANTITY
+7,259,274.41
+-1,000,000
+46,691.09
+-1,000,000
+-1,000,000
+1,023,495
+144,226
+- 1,000,000
+063010707:43 001
+PRICE
+1.0000
+1.0000**
+1.0000
+1.0000
+1.0000
+1.0000
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD June 1,2007
+THROUGH
+June 29, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2007
+DEBIT AMOUNT
+46,691.09
+1,023,495.00
+1,000,000.00
+46,691.09
+1,000,000.00
+1,000,000.00
+144,226.00
+1,000,000.00
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+8 of 9
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MODAY
+06/28/07
+TRANSACTION
+SOLD
+DESCAIPTION
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+06/29/07
+TOTAL
+CLOSINGBALANCER
+INTEREST
+DATE
+DESCRIPTION
+06/21/07
+INT DB
+05/21 - 06/20 @06.03125%
+BAL 7400000 AVG 1432258
+SYMBOUCUSIP
+TOTAL
+MISCELLANEOUS
+DATE
+MO/DAY
+06/15/07
+TOTAL
+TRANSACTION
+JOURNAL
+DESCRIPTION
+TO
+SYMBOUCUSIP
+DICXX
+QUANTITY
+-1,000,000
+3,185,234.50
+PRICE
+1.0000
+QUANTITY
+RATE (%)
+DEBIT AMOUNT
+7,438.53
+$-7,438.53
+DEBIT AMOUNT
+7,400,000.00
+$-7,400,000.00
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD June 1,2007
+THROUGH
+June 29, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2007
+DEBIT AMOUNT
+1,000,000.00
+$-1,070,186.09
+$5,190,917.09
+
+
+9 or g
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your messages
+Confirmation: Unless we hear from you to the contrary, it is our understanding
+DeP You are advised to promptly report any inaccuracy or discrepancy in your
+account to your broker and Bear, Stearns Securities Corp, ('BSS") at the
+telephone numbers listed on the front of this statement, In order to protect
+broker and BSSC at the addresses which appear on the front of this
+statement,
+STOP
+****** End of Statement******
+027
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD June 1,2007
+THROUGH
+June 29, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+May 31, 2007
+SPECIAL NOTICE FOR MARGIN CUSTOMERS
+include, but are not limited to, loans of securities that you own in your margin
+account that continue over record dates for voting purposes and ex-dividend
+dates for dividend distributions. If you do not receive dividends directly from
+the issuing company, you may receive payments-in-lieu of dividends which
+could cause you to lose the benefit of the preferential tax treatment accorded
+In an effort to maximize execution quality, Bear Stearns may route your equity
+orders to its Smart Order Router (SOR), The SOR accepts limit and market
+orders and automates their routing across several sources of liquidity in an
+limit or may change the entered limit price in an attempt to obtain the bes
+rice. Although the Firm believes that the regular use of this technolog
+
+
+ZICHERMAN,IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .........
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .....••I//////•/////////////I//I/I//.
+Your Messages
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD May 1, 2007
+THROUGH
+May 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 30, 2007
+3
+6
+8
+#almonkelenon
+CIO AMERICAN YACHT HARBOR
+6100 RED HOOK SUTE B-3
+QUAETERS #2
+ST THOMAS VI 00802-1348
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+84,753,146
+7,259,274
+$92,012,420
+99,008,080
+-6,995,660
+or sel apen sers onese for your other ponding buy
+Market Value of Your Portfolio
+$7,259,274
+13 $17,756,525
+Cash & Equivalent
+Equities
+581.251,555
+$84,753,146
+....
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859
+027
+SPC This statement shouid be retainel por out records." See reverse side for important intormation..
+06/01/07:05:44 001
+
+
+027
+06/01/07 05:44 001|
+Bear, Steams Securities Corp
+One Metrotech Center North
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD May 1, 2007
+THROUGH
+May 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 30, 2007
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Funds Withdrawn
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+10,873,187.15
+229,562.22
+$11,102,749.37
+302,749.37
+-10,800,000.00
+$-11,102,749.37
+$0.00
+Income Summary
+THIS PERIOD
+Dividends
+302,749.37
+Credit Balance Int.
+0.00
+Total
+$302.749.37
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+YEAR TO DATE
+725,173.79
+44.54
+S725.218.33
+7,259,274
+84,753,146
+$92,012,420
+....
+Your Portfolio
+Allocation
+Cash & Equivalent ,
+7%
+'Equities
+93%
+Unshaded portions denole debt balance and'or short
+markot valuos. Tho alocation porcentago is derived
+from the absolute market value of your portfolio.
+027
+06/01/07-05:44 001
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD May 1, 2007
+THROUGH
+May 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 30, 2007
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST, 30 DAY AVG YIELD 5,1900%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+QUANTITY
+7,259,274.41
+FRICE
+1.0000
+MARKET
+VALUE
+7,259,274
+$7,259,274
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department. The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+ESPERATE
+where such research is available. The various providers use different ratings systems and have normalized them as follows: B = Buy; H = Hold; S = Sell (this may not always
+correspond directly to the underlying rating system used by each provider or BSC), The ratings information contained herein is for informational purposes only and is not intended
+to provide tax, legal, or investment advice. Bear Stears is neither soliciting any action based on such information, nor endorsing any recommendation or opinion expressed by
+any independent, third-party research provider. The symbol indicates that continuing coverage of the subject company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost, Customers can access this research
+DESCRIPTION
+SYMBCUCUSIP
+QUANTITY
+MARKET
+PRICE
+VALLE
+AHMAL MOONE
+ESTIMATED
+YIELD (%)
+APPLE INC
+AAPL
+CASH
+220,000
+121.5600
+26,743,200
+BSC RATING: STOCK O/SECTOR M
+BOYAR'S ALTERNATIVE VIEWPOINT
+RATING: S
+BEAR STEARNS COMPANIES INC
+CHOICEPOINT INC
+BSC
+CPS
+CASH
+CASH
+130,000
+100,000
+149.9600
+43.8600
+19,494,800
+4,386,000
+166,400
+0.8536
+027
+0601/07.05:44 001
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+COLGATE PALMOLIVE CO
+SCKINGHAM RESEARCH AN
+MATING:
+DEERFIELD TRIARC CAP CORP
+SYMBOLCUSIP
+CL
+DFR
+ESWW
+LEH
+WYNN
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+56,200
+462,691
+100,000
+100,000
+160,000
+LEHMAN BROTHERS HOLDINGS INC
+WYNN RESORTS LTD
+BSC RATING: STOCK O/SECTOR MW
+WALL STREET STRATEGIES
+RATING: B
+Total Equities& Options
+TOTAL EQUITIES
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+027
+PRICE
+66.9600
+16.2000
+0.8600
+73.3800
+96.5400
+MARKET
+3,763,152
+7,495,594
+86,000
+7,338,000
+15,446,400
+$84,753,146
+$84,753,146
+ESTIMATE
+NNUAL INCON
+80,928
+777,321
+60,000
+$1,084,649
+$1,084,649
+$1,084,649
+$92,012,420
+06/01/07 05:44 001
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD May 1, 2007
+THROUGH
+May 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 30,2007
+ESTIMATED
+YELD (5)
+2.1505
+10.3704
+0.8177
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of 8
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+05/09/07
+TRANSACTION
+FND WIRED
+05109/07
+ND WIRE
+05/21/07
+END WIRED
+05122/07
+FND WIRED
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MODAY
+05/01/07
+TRANSACTION
+05/01/07
+DIVIDEND
+05/01/07
+REINVEST
+05/09/07
+05/09/07
+SOLD
+SOLD
+DESCRIPTION
+MDA#M
+INDS WIRED TO
+ENOBGAN CHASE BANK NA
+MDA#M
+NEARN CHISE BANK NO
+MDORN NEASE BANK WIR
+FNDS WIRED TO
+MDA#C
+NDS WIRED TO
+EMOBCON CHASE BANK NA
+DESCAIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT-CLA
+USTITUTIONAL SHARE
+TONTHLY DIVIDEN
+DREYFUS CASH MANAGEMENT-CL A
+STITUTION
+SHARES
+VIDEND REINVE
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+027
+DEBIT AMOUNT
+1,000,000.00
+7,800,000.00
+1,000,000.00
+1,000,000.00
+$-10,800,000.00
+•......
+SYMBOUGUSIP
+DICXX
+DICXX
+DICXX
+DICXX
+QUANTITY
+17,756,525.04
+73,187.15
+1,000,000
+-7,800,000
+PRICE
+1.0000
+1.0000
+06/01/07:05:44 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD May 1, 2007
+THROUGH
+May 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 30, 2007
+DEBIT AMOUNT
+73,187.15
+73,187.15
+1,000,000.00
+7,800,000.00
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+7 of a
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MODAY
+TRANSACTION
+05/15/07
+BOUGHT
+05/21/07
+SOLD
+05/22/07
+"SOLD
+05/23/07
+BOUGHT
+05/30/07
+BOUGHT
+DESCAIPTION
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+NSTOL SHARESAGEMEN: CLU
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+REYFUS CASH MANAGEMENT-CL
+ISTITUTIONAL SHARI
+05/31/07
+TOTAL
+CLOSINGBALANCE
+DATE
+05/15/07
+05/23/07
+5/30/0
+TOTAL
+DESCRIPTION
+COLGATE PALMOLIVE CO
+REC 04/24/07 PAY 05/15/07
+LEHMAN BROTHERS HOLDINGS INO
+REC 05/15/07 PAY 05/23/07
+........
+DEERFIELD TRIARC CAP CORP
+REC 05/07/07 PAY 05/30/07
+SYMBOUCUSIP
+CL
+LEH
+SYMBOUCUSIP
+DICXX
+DICXX
+DICXX
+DICXX
+DICXX
+QUANTITY
+56,200
+100,000
+462,691
+027
+QUANTITY
+20,232
+-1,000,000
+-1,000,000
+15,000
+194,330.22
+7,259,274.41
+PRICE
+1.0000
+1.0000
+1.0000
+1.0000
+1.0000
+RATE (5)
+0.3600
+0.1500
+0.4200
+DEBIT AMOUNT
+06/01/07:05:44 001
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD May 1, 2007
+THROUGH
+May 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 30,2007
+DEBIT AMOUNT
+20,232.00
+1,000,000.00
+1,000,000.00
+15,000.00
+194,330.22
+$-302,749.37
+$10,873,187.15
+20,232.00
+15,000.00
+194,330.22
+$229,562.22
+
+
+8 of 8
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your messages
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD May 1, 2007
+THROUGH
+May 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 30, 2007
+You are advised to promptly report any inaccuracy or discrepancy in your
+STOP
+****** End of Statement******
+027
+06/01/07 05:44 001
+
+
+ZICHERMAN,IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .........
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .....••I//////•//////////III//III//
+Your Messages
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD March 31, 2007
+THROUGH
+April 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30, 2007
+3
+6
+8
+#almonkelenon
+CIO AMERICAN YACHT HARBOR
+6100 RED HOOK SUTE B-3
+QUAETERS #2
+ST THOMAS VI 00802-1348
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+81,251,555
+17,756,525
+$99,008,080
+91,955,222
+7,052,858
+or sel apen sers onese for your other ponding buy
+Market Value of Your Portfolio
+$17,756.525
+$15,275,886
+Cash & Equivalent
+Equities
+376.679336
+$81,251,555
+....
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of chacks or stocks, indicated as dalivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859
+027
+SPC This statement shouid be retainel por out records." See reverse side for important intormation..
+05/01/07.07:14 001
+4009
+
+
+027
+05/01/07 07:14 001|
+Bear, Steams Securities Corp
+One Metrotech Center North
+V00S
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Money Fund
+Miscellaneous
+Amount Debited.
+Net Cash Activity
+•....
+Closing Balance,
+THIS PERIOD
+$11.500.000.00
+100,846.63
+41,600.00
+2,425,000.00
+$2,567,446.63
+-14,024,042.68
+-43,403.95
+$-14.067.446.63
+-11,500,000.00
+$0.00
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+99,042.68
+0.00
+$99,042.68
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+OFENING
+Cash
+11,500,000.00
+Net Cash Balance
+$11,500,000.00
+CLOSING
+0.00
+.. . .
+$0.00
+027
+05/01/07 07:14 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD March 31, 2007
+THROUGH
+April 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30, 2007
+YEAR TO DATE
+422,424.42
+44.54
+...
+5422468.9
+17,756,525
+81,251,555
+$99,008,080
+Your Portfolio
+Allocation
+Cash &Equivalent
+18%
+Equities
+82%
+Unshaded portions denole debi balance and'or short
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD March 31, 2007
+THROUGH
+April 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30, 2007
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST, 30 DAY AVG YIELD 5,1600%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+QUANTITY
+17,756,525.04
+1.0000
+MARKET
+VALUE
+17,756,525
+$17,756,525
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department. The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers use different ratings systems and have normalized them as follows: B = Buy; H = Hold; S = Sell (this may not always
+correspond directly to the underlying rating system used by each provider or BSC), The ratings information contained herein is for informational purposes only and is not intended
+to provide tax, legal, or investment advice. Bear Stearns is neither soliciting any action based on such information, nor endorsing any recommendation or opinion expressed by
+any independent, third-party research provider. The symbol indicates that continuing coverage of the subject company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost, Customers can access this research
+DESCRIPTION
+APPLE INC
+BSC RATING: STOCK O/SECTOR M
+BOYAR'S ALTERNATIVE VIEWPOINT
+RATING: S
+BEAR STEARNS COMPANIES INC
+CHOICEPOINT INC
+SYMBCUCUSIP
+AAPL
+CASH
+QUANTITY
+220,000
+PRICE
+99.8000
+MARKET
+VALLE
+21,956,000
+AHMAL MOONE
+ESTIMATED
+YIELD (%)
+BSC
+CPS
+CASH
+CASH
+130,000
+100,000
+155.7000
+37.9700
+20,241,000
+3,797,000
+166,400
+0.8221
+027
+05/01/07.07:14 001
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+COLGATE PALMOLIVE CO
+SCKINGHAM RESEARCH AN
+MATING:
+DEERFIELD TRIARC CAP CORP
+SYMBOLCUSIP
+CL
+DFR
+ESWW
+LEH
+WYNN
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+56,200
+462,691
+100,000
+100,000
+160,000
+LEHMAN BROTHERS HOLDINGS INC
+WYNN RESORTS LTD
+BSC RATING: STOCK O/SECTOR MW
+WALL STREET STRATEGIES
+RATING: B
+Total Equities& Options
+TOTAL EQUITIES
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+027
+PRICE
+67.7400
+16.1900
+0.7800
+75.2800
+102.2100
+MARKET
+VALLE
+3,806,988
+7,490,967
+78,000
+7,528,000
+16,353,600
+$81,251,555
+$81,251,555
+ANNE NOTES
+80,928
+777,321
+60,000
+$1,084,649
+$1,084,649
+$1,084,649
+$99,008,080
+05/01/0707:14 001
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD March 31, 2007
+THROUGH
+April 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+March 30, 2007
+ESTIMATED
+YELD IN
+2.1258
+10.3768
+0.7970
+
+
+6 of a
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TREE
+04/24/07
+IRANSACTION
+EXCHANGE
+04/24/07
+TOTAL
+EXCHANGE
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+03/31/07
+TRANSACTION
+04/02/07
+04/02/07
+04/02/07
+BOUGHT
+BOUGHT
+DIVIDEND
+04/02/07
+REINVEST
+04/26/07
+04/27/07
+SOLD
+BOUGHT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+DEERFIELD TRIARC CAP CORP
+EXCHANGE
+EXCHANGED THIS CAP CORP
+EXCHANGE
+DESCAIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+REYFUS CASH MANAGEMENT-CL
+ISTITUTIONAL SHARI
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL
+SHARES
+MONTHLY DIVIDEND
+DREYFUS CASH MANAGEMENT-CLA
+NSTITUTIONAL SHARE
+DIVIDEND REINVES
+RESTINAL SHARE CEMENT-CLA
+"DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+027
+SYMBOL/CUSP
+DFA
+QUANTITY
+-462,691
+462,691
+SYMBOUCUSIP
+DICXX
+DICXX
+DICXX
+DICXX
+DICXX
+QUANTITY
+3,775,886.31
+2,425,000
+11,500,000
+57,442.68
+43,403.95
+41,600
+PRICE
+1.0000
+1.0000
+1.0000
+1.0000
+05101/07.07:14 001
+PRICE
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD March 31, 2007
+THROUGH
+April 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30, 2007
+DEBIT AMOUNT
+DEBIT AMOUNT
+2,425,000.00
+11,500,000.00
+57,442.68
+41,600.00
+CAEDIT AMOUNT
+57,442.68
+43,403.95
+4009
+
+
+7 of a
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MODAY
+04/30/07
+TOTAL
+TRANSACTION
+DESCRIPTION
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+DESCRIPTION
+04/27/07
+BEAR STEARNS COMPANIES INC
+REC 04/17/07 PAY 04/27/07
+TOTAL
+MISCELLANEOUS
+DATE
+MO/DAY
+04/02/07
+04/02/07
+04/02/07
+04/26/07
+TOTAL
+TRANSACTION
+JOURNAL
+JOURNAL
+JOUANAL
+JOURNAL"
+DESCRIPTION
+FROM 040-94084
+INT RVRSL 9/30/05
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUCUSIP
+QUANTITY
+17,756,525.04
+PRICE
+SYMBOUCUSIP
+BSC
+QUANTITY
+130,000
+RATE (S)
+0.3200
+DEBIT AMOUNT
+DEBIT AMOUNT
+43,403.95
+$-43,403.95
+CREEIT AMOUNT
+125,000.00
+.. ..
+300,000.00
+2000,000.00
+$2.425,000.00
+027
+05/01/07:07:14 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD March 31, 2007
+THROUGH
+April 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30,2007
+DEBIT AMOUNT
+$-14,024,042.68
+$100,846.63
+41,600.00
+$41,600.00
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your messages
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD March 31, 2007
+THROUGH
+April 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30, 2007
+You are advised to promptly report any inaccuracy or discrepancy in your
+STOP
+****** End of Statement******
+027
+05/01/07 07:14 001
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+EARED THROUGH
+OLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD March 1, 2007
+THROUGH
+March 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28,2007
+CIO AMERICAN YACHT HARBOR
+6100 RED HOOK SUTE B-3
+QUAETERS #2
+ST THOMAS VI 00802-1348
+Pursuant to your previously issued instructions, Bear Stearns Securities Corp, provides duplicate monthly statements and/or transaction confirmations to the
+third parties listed on the cover page of this statement, If you wish to modify or cease distribution to any of the recipients indicated, please contact your
+Investment Professional, This reminder notice will continue to be provided to you on your quarterly statements.
+Third Party
+J EPSTEIN & CO
+457 MADISON AVE 4TH FLOOR
+NEW YORK NY 10022
+027
+03/31/07 06:43 001
+WOOR
+
+
+ZICHERMAN,IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .........
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .....••I//////•//////////III//III//
+Your Messages
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD March 1, 2007
+THROUGH
+March 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+February 28,2007
+3
+6
+8
+#almonkelenon
+CIO AMERICAN YACHT HARBOR
+6100 RED HOOK SUTE B-3
+QUAETERS #2
+ST THOMAS VI 00802-1348
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+Market Value of Your Portfolio
+$15,275,886
+$21,645,828
+76,679,336
+11,500,000
+3,775,886
+$91.955, 222
+90,615,501
+1,339,721
+Cash & Equivalent
+Equities
+$76,679,336
+$68,969,673
+.....
+......
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+027
+SPC This statement shouid be retainel por out records." See reverse side for important intormation..
+
+
+2 of 10
+027
+03/31/07 06:43 001|
+Bear, Steams Securities Corp
+One Metrotech Center North
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+3 or 10
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Funds Deposited
+Amount Credited
+Securities Bought
+Money Fund
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERIOD
+$0.00
+18,054,458.05
+11,500,000.00
+$29,554,458.05
+-7,962,200.00
+-92,258.05
+-10,000,000.00
+S.18.054,458.05
+11,500,000.00
+$11,500,000.00
+Cash Balance Summary
+Cash
+Net Cash Balance
+OFENING
+0.00
+CLOGING
+11,500,000.00
+.. . .
+$0.00
+$11,500,000.00
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+92,258.05
+0.00
+$92,258.05
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+03/31/07 06:43 001
+YEAR TO DATE
+323,381.74
+44.54
+........ .
+$323.426.28
+15,275,886
+76,679,336
+$91,955,222
+.. . .
+VOOB
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD March 1,2007
+THROUGH
+March 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28,2007
+Your Portfolio
+Allocation
+Cash & Equivalent -
+17%
+-Equities
+83%
+Unshaded portions denole debi balance and'or short
+
+
+4 of 10
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD March 1, 2007
+THROUGH
+March 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+February 28,2007
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+DREYFUS CASH MANAGEMENT-CLA
+IT SODA SHARED 1700%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOL/CUSIP
+QUANTITY
+DICXX
+3,775,886.31
+1.0000
+MARKET
+VALUE
+11,500,000
+3,775,886
+$15,275,886
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department, The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O= Outperform; P = Peer Perform; U = Underperform, The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight, In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers use different ratings systems and have normalized them as follows: B = Buy; H = Hold; S = Sell (this may not always
+correspond directly to the underlying rating system used by each provider or BSC). The ratings information contained herein is for informational purposes only and is not intended
+to provide tax, legal, or investment advice, Bear Stearns is neither soliciting any action based on such information, nor endorsing any recommendation or opinion expressed by
+any independent, third-party research provider. The symbol indicates that continuing coverage of the subject company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost. Customers can access this research
+DESCRIPTION
+APPLE INC
+SC RATING: STOCK O/SECTOR M
+OYAR'S ALTERNATIVE VIEWPOIN
+RATING: S
+BEAR STEARNS COMPANIES ING
+SYMBOLCUSIP
+AAPL
+CASH
+QUANTITY
+220,000
+PRICE
+92.9100
+MARKET
+VALUE
+20,440,200
+AHMAL NOONE
+ESTIMATED
+YIELD (%)
+BSC
+CASH
+130,000
+150.3500
+19,545,500
+166.400
+0.8513
+027
+
+
+5 or 10
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+CHOICEPOINT INC
+.....
+COLGATE PALMOLIVE CO
+BSC RATING: STOCK O/SECTOR MM
+BUCKINGHAM RESEARCH RATING: B
+.. ..
+EERFIELD TRIARC CAP COR
+OCREDITED INVESTOR
+WORLDWIDE NIAL SOLUTIONS
+LEHMAN BROTHERS HOLDINGS INC
+RATING: B
+WYNN RESORTS LTD
+BSC RATING: STOCK O/SECTOR MW
+VALL STREET STRATEGIE
+TING: B
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+CPS
+CL
+ESWW
+LEH
+WYNN
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CASH
+.........
+CASH
+CASH
+....
+CASH
+CASH
+CASH
+QUANTITY
+100,000
+56,200
+462,691
+100,000
+100,000
+160,000
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+027
+PRICE
+37.4300
+66.7900
+14.9900
+0.7670
+70.0700
+94.8600
+MARKET
+VALLE
+3,743,000
+....
+3,753,598
+6,935,738
+76,700
+7,007,000
+15,177,600
+$76,679,336
+$76,679,336
+$307,328
+$91,955,222
+ESTIMATED
+ANNUAL INCOME
+80,928
+60,000
+$307,328
+$307,328
+03/31/07:06:43 001
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD March 1, 2007
+THROUGH
+March 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+February 28,2007
+ESTIMATED
+2.1560
+0.8563
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of 10
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEEMENT TATE
+TRANSACTION
+03/01/0702/26/07 BUGHT
+DESCRIPTION
+LEHMAN BROTHERS HOLDINGS INC
+UNSOLICITED
+TOTAL
+DEPOSITS AND WITHDRAWALS
+DATE
+03/30/07
+TRANSACTION
+FUNDS REC
+DESCRIPTION
+FNDS WIRED TO CITIBANK FROM
+CS LLC PRIME BROKER
+S077089196FF01
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MODAY
+03/01/07
+TRANSACTION
+DESCRIPTON
+OPENINGBALANCE
+03/01/07
+03/01/07
+SOLD
+DIVIDEND
+03/01/07
+REINVEST
+03/30/07
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+DREYFUS CASH MANAGEMENT-CL A
+IVIDEN
+DREYFUS CASH MANAGEMENT-CLA
+DIDEND RESENTES
+....
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL
+SHARES
+027
+SYMBOLCUSIP
+LEH
+QUANTITY
+100,000
+DEBIT AMOUNT
+SYMBOUGUSIP
+DICXX
+DICXX
+DICXX
+11,500,000.00
+$11,500,000.00
+QUANTITY
+21,645,828.26
+-7,962,200
+92,258.05
+10,000,000
+03/31/07.06:43 001
+PRICE
+1.0000
+1.0000
+PRICE
+79.56200
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD March 1, 2007
+THROUGH
+March 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28,2007
+DEBIT AMOUNT
+7,962,200.00
+$-7,962,200.00
+DEBIT AMOUNT
+7,962,200.00
+92,258.05
+92,258.05
+0,000,000.00
+VOOB
+
+
+7 of 10
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MODAY
+03/30/07
+TOTAL
+TRANSACTION
+MISCELLANEOUS
+DATE
+MO/DAY
+03/30/07
+TOTAL
+TRANSACTION
+JOURNAL
+DESCRIPTION
+CLOSINGBALANCE
+DESCRIPTION
+TO
+SYMBOUCUSIP
+QUANTITY
+3,775,886.31
+PRICE
+027
+03/31/07 06:43 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD March 1,2007
+THROUGH
+March 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28, 2007
+DEBIT AMOUNT
+$-92,258.05
+$18,054,458.05
+DEBIT AMOUNT
+10,000,000.00
+$-10,000,000.00
+VOOB
+
+
+8 of 10
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your messages
+Bear, Stearns Securities Corp. Net Capital and Net Capital Requirements:
+Le November 5.0lon on and 4,031,207, 4p Company not cantal.o%
+A complete copy of the Bear, Stearns Securities Corp, Statement of Financial
+Condition is available on the web site www.bearstearns.com, Alternatively, to
+request a free printed copy please call - toll free 1-866-299-9331,
+DeP You are advised to promptly report any inaccuracy or discrepancy in your
+account to your broker and Bear, Stearns Securities Corp, ('BSS") at the
+telephone numbers listed on the front of this statement, In order to protect
+broker and BSSC at the addresses which appear on the front of this
+statement,
+027
+18P
+lear, Steams Securities Com
+he Metratech Center Nort
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD March 1, 2007
+THROUGH
+March 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+February 28,2007
+SPECIAL NOTICE FOR MARGIN CUSTOMERS
+or in part, your ability to receive dividends directly from the issuing company
+d/or your right to exercise voting and other attendant rights of ownersh
+th respect to the loaned, sold or pledged securities. Such circumstanc
+include, but are not limited to, loans of securities that you own in your margin
+account that continue over record dates for voting purposes and ex-dividend
+dates for dividend distributions. If you do not receive dividends directly from
+the issuing company, you may receive payments-in-lieu of dividends which
+could cause you to lose the benefit of the preferential tax treatment accorded
+to dividends.
+NOTICE OF CHANGE PURSUANT TO TRUTH-IN-LENDING SEC RULE 10b-16
+hort-term market interest rates quoted by money center banks and t
+deral Reserve and the rate that BSSC is charged for borrowing mone
+
+
+9 of 10
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Effective no earlier than thirty (30) days from your receipt of this statement:
+1. The annual rate of interest charged to you on U.S. dollar-denominated
+redit will not exceed the specified percentage over the applicable rate, a
+ndicated in the following chart
+Debit Size Range
+Up to $499,999
+$500,000 - $999,999
+$1,000,000 - $2,499,999
+$2,500,000 - $4,999,999
+5,000,000 - $9,999,99:
+$10,000,000 and abov
+Index
+Margin Basis
+Margin Basis
+Margin Basis
+LIBOR
+LIBOR
+LIBOR
+Spread to Index
++ 3,000%
++ 2,000%
++ 1,500%
++ 3.000%
++ 2,250%
++ 1,750%
+Debits in currencies other than U,S, dollars will not be taken into account in
+computing the debit size for purposes of determining the applicable interest
+rate. The rate corresponding to the debit size range in which your U.S. dolla
+lenominated debit falls will apply to the entire amount of your U.S. dolla
+lenominated debit. The actual rate charged to you at any given time will b
+notified to you on request, and the amount charged to you will appear on your
+monthly statements.
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD March 1, 2007
+THROUGH
+March 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+February 28,2007
+2. Interest may be charged to your account at varying rates during the month
+to reflect any changes in such interest rates that have occurred during the
+month surel as alahanges in the applicable rate caused by a change in the
+3. The rate of interest charged to you on any credit extended to you in
+urrency other than U.S. dollars shall continue to be based on either (i)
+LIBOR, as such rate is compiled by the British Bankers Association and
+published on Bloomberg or Reuters, or (ii) any other rate quoted by Reuters
+that is applicable to the currency in which the obligation is denominated or, if a
+rate for such currency is not quoted by Reuters, the rate provided by Bear
+Stearns Securities' local bank, In either case, the annual rate of interest on
+such non-U,S, dollar denominated debit will continue to not exceed 5% above
+either a LIBOR, any rate quoted by Reuters or the rate provided by Bear
+Stearns Securities' local bank, and will appear on your monthly statements,
+The actual rate charged to you at any given time will be notified to you on
+request and the amount charged to you will appear on your monthly
+4, Unless otherwise agreed, the BSSC Fed Funds Rate will no longer be an
+available option for computing interest.
+03/31/07:06:43 001
+V00B
+
+
+10 of 10
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD March 1, 2007
+THROUGH
+March 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+February 28,2007
+If BSSC makes changes in any of the credit terms and conditions described
+herein or if a change is required by law, we will notify you of such change within
+reasonable period of time, unless such change results in the same or
+ligher rate to you, in which case we will provide vou at least 30 days' pric
+written notice, The annual rate of interest you are charged may fluctuate with
+changes in the BSSC Margin Basis Rate, a LIBOR, any of the rates quoted by
+Reuters or the rate provided by BSSC's local bank, The changes in rates
+resulting from this fluctuation will be made without prior notice to you (as
+contrasted with changes in the credit terms and conditions, notice of which will
+be provided as described above).
+The Truth-in-Lending disclosure previously provided to you shall continue to
+apply except as specifically noted above.
+STOP
+****** End of Statement******
+027
+03/31/07 06:43 001
+
+
+ZICHERMAN.IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .........
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity
+Trades Not Yet Settled
+.....
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD February 1, 2007
+THROUGH
+February 28, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31, 2007
+3
+6
+8
+#almondolonelold
+CIO AMERICAN YACHT HARBOR
+6100 RED HOOK SUTE B-3
+QUAETERS #2
+ST THOMAS VI 00802-1348
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+68,969,673
+21,645,828
+$90,615,501
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+97,195,040
+-6,579,539
+or sel apen sers onese for your other ponding buy
+Market Value of Your Portfolio
+$21.645,828
+$32,111,140
+Cash & Equivalent
+Equities
+S65,083,900
+$68,969,673
+......
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; Or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+027
+SP This suremen is four for ratanal purpose red de Set revere ase for portant itormation.
+03/01/07:05:17 001
+
+
+027
+03/01/07 05:17 001
+Bear, Steams Securities Corp
+One Metrotech Center North
+
+
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Securities Bought
+Money Fund
+Funds Withdrawn
+Amount Debited
+Net Cash Activity
+.. . .
+Closing Balance
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+.5194.330.22
+10,632,044.93
+18,028.54
+$10,650,073.47
+-8,654,880.00
+-189,523.69
+-2,000,000.00
+$-10.844.403.69
+-194,330.22
+..0
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+189,523.69
+44.54
+$189,568.23
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+OPENING
+194,330.22
+Net Cash Balance
+$194,330.22
+GLOSING
+0.00
+$0.00
+... .
+027
+03/01/07 05:17 001
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD February 1, 2007
+THROUGH
+February 28, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+January 31, 2007
+YEAR TO DATE
+231,123.69
+44.54
+___•...
+$231,168.23
+21,645,828
+68,969,673
+$90,615,501
+....
+Your Portfolio
+Allocation
+Cash & Equivalent,
+24%
+• Equities
+76%
+Unshaded portions denole debi balance and'or short
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD February 1, 2007
+THROUGH
+February 28, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31, 2007
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST. 30 DAY AVG YIELD 5.1700%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+QUANTITY
+21,645,828.26
+1.0000
+MARKET
+VALUE
+21,645,828
+$21,645,828
+ESTIMATED ESTIMATED
+ANNUAL INCOME
+YELD IS
+1,147,229 5.3000
+$1,147,229
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department. The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O= Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+ESPERATE
+where such research is available. The various providers use different ratings systems and have normalized them as follows: B = Buy; H = Hold; S = Sell (this may not always
+correspond directly to the underlying rating system used by each provider or BSC), The ratings information contained herein is for informational purposes only and is not intended
+to provide tax, legal, or investment advice. Bear Stearns is neither soliciting any action based on such information, nor endorsing any recommendation or opinion expressed by
+any independent, third-party research provider. The symbol indicates that continuing coverage of the subject company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost, Customers can access this research
+MARKET
+DESCRIPTION
+SYMBOUCUSIP
+QUANTITY
+PRICE
+VALUE
+ANNUAL NOTE
+ESTIMATED
+YIELD (%)
+APPLE INC
+AAPL
+CASH
+220,000
+84.6100
+18,614,200
+BSC RATING: STOCK O/SECTOR MW
+BOYAR'S ALTERNATIVE VIEWPOINT
+RATING: S
+BEAR STEARNS COMPANIES INC
+CHOICEPOINT INC
+BSC
+CPS
+CASH
+CASH
+aaaaaaaaa
+130,000
+100,000
+152.2400
+38.8800
+19,791,200
+3,888,000
+166,400
+0.8408
+027
+03/01/07.05:17 001
+
+
+5 or 8
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+COLGATE PALMOLIVE CO
+SYMBOLCUSIP
+CL
+ACRED WESTONE CORP
+ENVIRONMENTAL SOLUTIONS
+WORLDWIDE INC
+WYNN RESORTS LTD
+BSC RATING: STOCK O/SECTOR MW
+WALL STREET STRATEGIES
+RATING: B
+Total Equities& Options
+TOTAL EQUITIES
+WYNN
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+56,200
+462,691
+100,000
+160,000
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+027
+PRICE
+67.3600
+15.4000
+0.8200
+98.0200
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD February 1, 2007
+THROUGH
+February 28, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+January 31, 2007
+MARKET
+VALUE
+3,785,632
+7.125,441
+82,000
+15,683,200
+$68,969,673
+$68,969,673
+ESTIMATED
+ANNUAL INCOME
+71,936
+ESTIMATED
+YELD (S
+1.9002
+$238,336
+$238,336
+$1,385,565
+$90,615,501
+03/01/07 05:17 001
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of 8
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEEMENT TATE
+DATE
+TRANSACTION
+02/01/07 01/29/07 BOUGHT
+DESCRIPTION
+APPLE INC
+UNSOLICITED
+TOTAL
+DEPOSITS AND WITHDRAWALS
+DATE
+02/22/07
+ANSACTIO
+ND WIRE
+DESCRIPTION
+MDA#M|
+02/27/07"FND WIRED
+IENDS WIRED TO
+FD#_
+MDAR ENDS WIRED TO''
+MARN ARSE BANK NE
+TOTAL
+MONEY FUND ACTIVITY
+DADAY
+02/01/07
+TRANSACTION
+DESCRIPTION
+OPENINGBALANCE
+02/01/07
+SOLD
+INSTITUTIONAL SHARE CEMENT-CLA*
+SYMBOLCUSP
+AAPL
+QUANTITY
+100,000
+PRICE
+86.54880
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD February 1, 2007
+THROUGH
+February 28, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31,2007
+DEBIT AMOUNT
+8,654,880.00
+$-8,654,880.00
+DEBIT AMOUNT
+1,000,000.00
+1,000,000.00
+$-2,000,000.00
+SYMBOUCUSIP
+DICXX
+QUANTITY
+31,916,809.81
+-8,460,549.78
+PRICE
+1.0000
+DEBIT AMOUNT
+CAEDIT AMOUNT
+8,460,549.78
+027
+03/01/07:05:17 001
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+7 of a
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+TRANSACTION
+02/01/07
+DIVIDEND
+DESCAIPTION
+DREYFUS CASH MANAGEMENT-CL A
+0201/07
+REINVEST
+*DREYFUS CASH MANAGEMENT-CLA
+02/15/07 BOUGHT
+12/22/0
+02727/07
+SOLD
+SOLD
+STIONAL SHARESCEMENT-CL
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+BREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+02/28/07
+TOTAL
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+02/15/07
+TOTAL
+DESCRIPTION
+COLGATE PALMOLIVE CO
+REC 01/26/07 PAY 02/15/07
+SYMBOUGUSIP
+cL
+SYMBOUGUSIP
+DICXX
+XXOI
+DICXX
+DICXX
+DICXX
+QUANTITY
+56,200
+027
+QUANTITY
+171,539.69
+17,984
+999,955.46
+-1,000,000
+21,645,828.26
+PRICE
+1.0000
+1.0000
+1.0000
+RATE (5)
+0.3200
+DEBIT AMOUNT
+03/01/07:05:17 001
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD February 1, 2007
+THROUGH
+February 28, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31,2007
+DEBIT AMOUNT
+171,539.69
+171,539.69
+17,984.00
+999,955.46
+1,000,000.00
+$10,632,044.93
+$-189,523.69
+17,984.00
+$17,984.00
+VOOE
+
+
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+02/21/07
+INTEREST ON CREDIT BALANCE
+AT 041250% 0121 - 0220
+TOTAL
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUGUSIP
+Trades Executed Pending Settlement
+SATE MENT TRE
+03/01/07
+02/26/07
+TOTAL
+TRANSACTION
+BOUGHT
+DESCRIPTION
+LEHMAN BROTHERS HOLDINGS INC
+UNSOLICITED
+The stove trades do not appear in any other section of this statement.
+STOP
+****** Endof Statement******
+027
+QUANTITY
+RATE (%)
+DEBIT AMOUNT
+SYMBOLCUSP
+LEH
+QUANTITY
+100,000.00
+PRICE
+79.5620
+03/01/07 05:17 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD February 1, 2007
+THROUGH
+February 28, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31, 2007
+44.54
+$44.54
+DEBIT AMOUNT
+7,962,200.00
+$7,962,200.00
+CAEDIT AMOUNT
+$0.00
+
+
+ZICHERMAN.IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .........
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity
+Trades Not Yet Settled
+.....
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD December 30, 2006
+THROUGH
+January 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 29, 2006
+3
+4
+6
+8
+#almondolonelold
+CIO AMERICAN YACHT HARBOR
+6100 RED HOOK SUTE B-3
+QUAETERS #2
+ST THOMAS VI 00802-1348
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+65,083,900
+194,330
+31,916,810
+S97.195.040
+......
+••••••••••/•••••••
+88,154,315
+9,040,725
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$32,111,140
+$26,289,268
+Cash & Equivalent
+Equities
+$65.083,900
+S61,865,047
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+027
+SP The suren s four erratanal purposes rear die Set revere date for portant iformation.
+02/01/07:06:16 001
+
+
+027
+02/01/07 06:16 001
+Bear, Steams Securities Corp
+One Metrotech Center North
+
+
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Funds Deposited
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Money Fund
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Hosing Balanc
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+$0.00
+10,160,941.35
+15,000,000.00
+235,930.22
+425,000.00
+525.821.871.57
+-15,627,541.35
+-10,000,000.00
+$-25,627,541.35
+194,330.22
+$194,330.22
+Income Summary
+Dividends
+Total
+THIS PERIOD
+41,600.00
+$41.600.00
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Not Cast Balance
+OFENING
+0.00
+$0.00
+CLOSING
+194,330.22
+$194.330.22
+......
+027
+02/01/07 06:16 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD December 30, 2006
+THROUGH
+January 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 29, 2006
+YEAR TO DATE
+41,600.00
+... . .
+.....
+$41.600.00
+32,111,140
+65,083,900
+697,195,040
+Your Portfolio
+Allocation
+Cash & Equivalent!
+34%
+Equities
+66%
+Unshaded portions denole debi balance and'or short
+
+
+BEARR
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+EST, 30 DAY AVG VIELD 5.1600%
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+SYMBOL/CUSIP
+DICXX
+QUANTITY
+31,916,809.81
+1.0000
+DESCRIPTION
+APPLE INC
+BSC RATING: STOCK O/SECTOR MW
+BOYAR'S ALTERNATIVE VIEWPOINT
+BEAR STEARNS COMPANIES INC
+SYMBOL/CUSIP
+AAPL
+BSC
+CASH
+QUANTITY
+120,000
+CASH
+130,000
+027
+MARKET
+VALUE
+194,330
+31,916,810
+$32,111,140
+ESTIMATED ESTIMATED
+ANNUAL INCOME
+1,691,591
+$1,691,591
+5.3000
+PRICE
+85.7300
+MARKET
+VALUE
+10,287,600
+164.8500
+21,430,500
+166,400
+02/01/07:06:16 001
+Bear, Steams Securities Corp
+One Metratech Center North
+STATEMENT PERIOD December 30, 2006
+THROUGH
+January 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 29, 2006
+ELD 15
+0.7765
+
+
+5 or 8
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+CHOICEPOINT INC
+...•••.......
+COLGATE PALMOLIVE CO
+BSC RATING: STOCK O/SECTOR MW
+BUCKINGHAM RESEARCH RATING: E
+.. . .
+ERFIELD TRIARC CAP COF
+COREDITED INVESTOR
+ENVIRONMENTAL SOLUTIONS
+WORLDWIDE INC
+WYNN RESORTS LTD
+BSC RATING: STOCK O/SECTOR MW
+WALL STREET STRATEGIES
+Total Equities& Options
+TOTAL EQUITIES
+SIMBCLICUSIP
+CPS
+CL
+ESWW
+WINN
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+109T
+CASH
+.........
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+100,000
+56,200
+462,691
+100,000
+160,000
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUALINCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+027
+PRICE
+38.4900
+68.3000
+16.7000
+0.7300
+111.7400
+MARKET
+VALLE
+3,849,000
+3,838,460
+7,726,940
+73,000
+17,878,400
+$65,083,900
+$65,083,900
+ESTIMATE
+INNUAL INCOM
+71,936
+$238,336
+$238,336
+$1,929,927
+$97,195,040
+02/01/07 06:16 001
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD December 30,2006
+THROUGH
+January 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+December 29, 2006
+ESTIMATEC
+YIELD I%
+1.8741
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of a
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+01/04/07
+TRANSACTION
+FUNDS REC
+DESCRIPTION
+FNDS WIRED TO CITIBANK FROM
+IPMORGAN CHASE BANK
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+12/30/06
+TRANSACTION
+DESCRIPTION
+OPENINGBALANCE
+01/02/07
+REINVEST
+01/02/07
+DIVIDEND
+01/05/07
+BOUGHT
+BOUGHT
+01/26/07
+01/30/07
+BOUGHT
+SOLD
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+DIVIDEND REINVEST
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+AMT INCLUDED IN 2006 - 1099
+INSTITUIONAS SHANAGEMENT-CLA
+REYFUS CASH MANAGEMENT-CL
+INSTITUTIONAL SHARES
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+01/31/07
+TOTAL
+CLOSINGBALANCE
+DEBIT AMOUNT
+15,000,000.00
+$15,000,000.00
+QUANTITY
+26,289,268.46
+160,941.35
+SYMBOUCUSIP
+DICXX
+DICXX
+DICXX
+DICXX
+DICXX
+DICXX
+PRICE
+15,000,000
+425,000
+41,600
+10.000,000
+31,916,809.81
+1.0000
+1.0000
+1.0000
+1.0000*
+027
+02/01/07:06:16 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD December 30, 2006
+THROUGH
+January 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 29, 2006
+DEBIT AMOUNT
+160.941.35
+160,941.35
+15,000,000.00
+425,000.00
+41,600.00
+10,000,000.00
+$10,160,941.35
+$-15,627,541.35
+
+
+7 of a
+Transaction Detail (continued)
+DIVIDENDS
+DATE
+01/26/07
+0130/07
+DESCRIPTION
+BEAR STEARNS COMPANIES INC
+REC 01/16/07 PAY 01/26/07
+DEERFIELD TRIARC CAP CORF
+ASH DIVEN 4526
+62691 SH
+RAMOUNTINCLUDED ON 2006-1099
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUGUSIP
+BSC
+QUANTITY
+130,000
+RATE (S)
+0.3200
+DEBIT AMOUNT
+TOTAL
+MISCELLANEOUS
+01/10/07
+01/10/07
+01/30/07
+TOTAL
+TRANSACTION
+JOURNAL
+JOURNAL
+.. . .
+DURNA
+DESCRIPTION
+FROM |
+FROM L
+DEBIT AMOUNT
+0,000,000.00
+$-10,000,000.00
+CRECIT AMOUNT
+125,000.00
+300,000.00
+$425,000.00
+027
+02/01/07 06:16 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD December 30,2006
+THROUGH
+January 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 29, 2006
+41,600.00
+194,330.22
+$235.930.22
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Trades Executed Pending Settlement
+SEE MENT TE
+TRANSACTION
+02/01/07 01/29/07 BOUGHT
+DESCRIPTION
+APPLE INC
+UNSOLICITED
+UNIT PRICE 86.488800
+The above trades do not appear in any other section of this statement
+SYMBOLGUSP
+AAPL
+QUANTITY
+100,000.00
+PRICE
+86.5488
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD December 30, 2006
+THROUGH
+January 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+December 29, 2006
+DEBIT AMOUNT
+8,654,880.00
+$8,654,880.00
+$0.00
+STOP
+*****
+End of Statement******
+027
+02/01/07 06:16 001
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/b33df814175ee4dd83c67f27cb4314ceb5d6f260b5ac94e78275d4cf0e3b8937.receipt.json b/vision-fixhub/ds9-unparsed-05/b33df814175ee4dd83c67f27cb4314ceb5d6f260b5ac94e78275d4cf0e3b8937.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a628d9a8e9ef7bb158b051ca8a2ce45e5e78f02a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b33df814175ee4dd83c67f27cb4314ceb5d6f260b5ac94e78275d4cf0e3b8937.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -8246,
+  "dataset": "marble-joined",
+  "doc_id": "b33df814175ee4dd83c67f27cb4314ceb5d6f260b5ac94e78275d4cf0e3b8937",
+  "engine": "marble-apple-vision",
+  "event_count": 66,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "86a58a95bba37c5357c79b7d3667396cd80636e6a7160227a79e248656990b6e",
+  "output_sha256": "188a15a8e1f2b5a0453e234523c15ef4752c1fdad07d3ec030a085b51172909c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b402a3871d29649ec39035dffa15aba8dd063fb98f38357ee49c949132fae296.md b/vision-fixhub/ds9-unparsed-05/b402a3871d29649ec39035dffa15aba8dd063fb98f38357ee49c949132fae296.md
new file mode 100644
index 0000000000000000000000000000000000000000..1bf69461516deda8260f720fc5d8742408d77ebe
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b402a3871d29649ec39035dffa15aba8dd063fb98f38357ee49c949132fae296.md
@@ -0,0 +1,2927 @@
+MARTING. WEINBERG, P.C.
+ATTORNEY AT LAW
+20 PARK PLAZA, SUITE 1000
+BOSTON, MASSACHUSETTS 02116
+EMAIL ADDRESSES:
+FAX
+NIGHT EMERGENCY:
+July 22, 2011
+Assistant United States Attorney
+500 S. Australian Ave. Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epstein
+Dear Ms.
+Roy Black forwarded to me your letter to him dated July 21, 2011, from the District
+Attorney of the County of New York. We thank you for providing notice of the intended
+disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related
+list of witness/victims on the basis of the confidentiality provisions of paragraph 13. Absent an
+enforceable subpoena - which we would have the right to move to quash in the Court from which
+it was issued - there exists no right or duty to disclose the confidential Non-Prosecution
+Agreement or the non-public witness/victim list which was referenced in paragraph 7 of the
+NPA. Further, given that the witness/victim list was compiled based on the federal grand jury
+investigation, we object under Fed. R. Crim. P. 6(e) to its disclosure absent an appropriate court
+order.
+Very truly yours,
+Mate Is Wanky 1e
+Martin G. Weinberg
+cc: Roy Black
+
+
+07/22/2011
+15:55
+
+B SK S
+PAGE 02
+MARTIN G. WEINBERG, P.C.
+ATTORNEY AT LAW
+EMAII ADDRESSES:
+FAX
+NIGHT EMERGENCY:
+July 22,2011
+Assistant United States Attorney
+500 S. Australian Ave. Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epstein
+Dear Ms. Villafañia:
+Roy Black forwarded to me your letter to him dated July 21, 2011, from the District
+Attorney of the County of New York. We thank you for providing notice of the intended
+disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related
+list of witness/victims on the basis of the confidentiality provisions of paragraph 13. Absent an
+enforceable subpoena - which we would have the right to move to quash in the Court from which
+it was issued - there exists no right or duty to disclose the confidential Non-Prosecution
+Agreement or the non-public witness/victim list which was referenced in paragraph 7 of the
+NPA. Further, given that the witness/victim list was compiled based on the federal grand jury
+investigation, we object under Fed. R. Crim. P. 6(e) to its disclosure absent an appropriate court
+order.
+Very truly yours,
+Mate Is Wandy 12e
+Martin G. Weinberg
+ce: Roy Black
+
+
+07/22/2011 15:55
+
+BSK S
+PAGE 01
+BLACK
+SREBNICK
+KORNSPAN
+STUMPF
+TRIAL ATTORNEYS
+Email:
+Roy Black
+Howard M. Srebnick
+Scott A, Kornspan
+Larry A. Stumpf
+Maria Neyra
+Jackie Perczek
+Mark A.J. Shapiro
+Jared Lopez
+Varcos Beaton, Jr
+Jessica Fonseca-Nader
+Kathleen P. Phillips
+Jenifer 1. Goah Fox
+Joshua Shore
+FACSIMILE TRANSMITTAL SHEET
+FAX: 1
+TELEPHONE:
+TO:
+AUSA
+RE:
+JEFFREy Epstein - N.Y. DAé Request
+DATE:
+July 22, 2011
+SENDER:
+Jackie Perczek
+NO. OF PAGES (INCLUDING TRANSMITTAL SHEET): Two .
+MESSAGE:
+KiNDLY DELiVER ASAP.
+**IF YOU DO NOT RECEIVE
+PAGES, PLEASE CALL
+THIS PACSINÍS CONTAINS PRIVILIOED AND CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF THE
+INDIVIDUAL OR ENTITY NAMED ABOVE: IF THE RÉADER OF THIS FACINDE IS NOT THE INTENDED RECIPENT, OR THE
+EMPLOYER OR AbENT REBPONSIBLE FOR DELIVERIVG IT TO THD INTENDID RECILENT, YOU ARE HERENT MOTIFIED
+CHAT ANY DIBBEMINATION OR COPYING OF THIS FACSIMILE IS STRICTLY PROHIBITED, IT'YOU HAVE RECEIVED THIE
+ACBINIE IN ERROR, PLEASE IMMEDIATELY NOTIFY UADY TELEPHONE, AND RETURN THE ORIGINAL PACHIMLLE TO US
+AT THE ABOVE ADDRESS VIA THE V.SI POSTAL SERVICE.
+THANK YOU.
+201 S. Biscayne Boulevard, Suite 1300, Miami, Florida 33131 | (P) 305-371-6421 | (F) 305-358-2006 | www.royblack.com
+
+
+500 S. Australian Ave, Ste 400
+West Palm Beach, FL 33401
+Facsimile:
+July 27,2011
+DELIVERY BY FACSIMILE
+Martin G. Weinberg, Esq.
+20 Park Plaza, Suite 1000
+Boston, MA 02116
+Re:
+Jeffrey Epstein
+Dear Mr. Weinberg:
+Thank you for your letter of July 22, 2011. In order to review and address the objections that
+you raised in that letter, the Office deferred making its planned disclosure to the District Attorney
+of the County of New York of the Non-Prosecution Agreement ("Agreement") and the list of
+identified victims that was provided to Mr. Epstein pursuant to the Agreement. Nonetheless, after
+completing a full review of your objections, the Office still intends to proceed with the planned
+disclosures.
+The Agreement requires the Office only to provide Mr. Epstein with notice prior to a
+disclosure of the Agreement "Ti]f the United States receives a Freedom of Information Act request
+or any compulsory process"; the Agreement does not require Mr. Epstein's concurrence in any
+disclosure. Contrary to your suggestion, the Agreement (including paragraph 13) also does not make
+the Agreement itself "confidential." On the contrary, the Agreement expressly contemplates that
+disclosures of the Agreement may be made, and the Agreement further contemplates, contrary to
+your suggestion, that such disclosures of the Agreement may be made other than in response to
+"compulsory process." Here, moreover, the District Attorney of the County of New York, as a local
+law enforcement agency, has provided a legitimate request for disclosure of the requested
+information, as well as a promise to maintain the confidentiality of the information, particularly the
+names of the minor victims.
+Your objection pursuant to Federal Rule of Criminal Procedure 6(e) also does not impact the
+planned disclosures. The victim list itself is not grand jury material, and, thus, disclosure of that list
+to the District Attorney's Office will not violate Rule 6(e).
+If you wish to supply any additional authority (other than citation to Rule 6(e) and to
+paragraph 13 of the Agreement) for your claims that the Office cannot disclose the Agreement and
+
+
+MARTIN WEINBERG, ESQ.
+JULY 27, 2011
+
+the victim list to the District Attorney of the County of New York, we would be willing to consider
+those authorities before making any disclosure, provided that any such authorities are furnished to
+us before 5:00 p.m. on July 29, 2011. Otherwise, seeing no obstacle to the previously-planned
+disclosures, the Office will be disclosing copies of both the Non-Prosecution Agreement and the list
+of identified victims that was provided to Mr. Epstein to the District Attorney of the County of New
+York at 5:00 p.m. on July 29, 2011.
+Sincerely,
+Wifredo A. Ferrer
+By:
+Assistant United States Attorney
+cc:
+Chief, Northern Division
+, Assistant District Attorney, County of New York
+Roy Black, Esq.
+
+
+West Palm Beach, FL 33401-6235
+DATE: 7/27/2011
+TO:
+MARTIN WEINBERG
+ORGANIZATION:
+FAX#:
+SUBJECT: JEFFREY EPSTEIN
+FROM:
+(Fax)
+NUMBER OF PAGES, INCLUDING THIS PAGE: 3
+COMMENTS:
+Original document:
+To follow via regular mail
+
+
+Fax Number
+Fax Name
+Model Name
+: JUL- 27-2011 03:01PM WED
+: Phaser 3300MFP
+No. Name/Number
+246 M
+StartTime
+Time Mode
+07-27 03:00PM 00'31 EC
+Southera District of Florida
+0.S. Australian Ave., Suite 40
+'est Palen Beach, FL. 33401-62.
+DATE: 7/27/2011-
+TO.
+MARTIN WEINBERG
+ORGANIZATION
+FAX N:
+SUBJECT: JEFFREy EPSTEIN
+FROM:
+I (Fax)
+NUMBER OF PAGES, INCLUDING THIS PAGE: 3
+COMMENTS:
+Origmal document:
+To follow via regular mai
+To follow via Foderal Express
+Nothing to follow, FAX cignal
+Page Result
+003/003 O.K
+
+
+West Palm Beach, FL 33401-6235
+DATE: 7/27/2011
+To: Deborah Morse
+ORGANZATION. New York District Attorney's office
+SUBJECT: Jeftrey Epsteir
+FROM:
+(Fax)
+NUMBER OF PAGES, INCLUDING THIS PAGE: 3
+COMMENTS:
+Original document:
+To follow via regular mail
+
+
+..:.
+Fax Number
+Fax Name
+Model Name
+: SUI-27-2011 03:03PM WED
+: Phaser 3300MFP
+No. Name/Number
+247
+StartTime
+Time Mode
+07-27 03:01PM 00'57 BCM
+Page
+Result
+003/003 O.K
+Soutbera District of Fiorida
+PD S. Australian Ave, Suite 40
+est Palms Beach, FI. 33401-62:
+DATE: 7/27/2011
+10:
+Deborah Marse
+ORGANIZATION: New Yark District Attorneys office...
+FAX #:
+SUBJECT:
+Jeffrey Epattin
+FROM:
+лії (Гах)
+NUMBER OF PAGES, INCLUDING THIS PAGE: 3
+- - —
+COMMENTS:
+Original document:
+To follow via regutar mai
+-мл—
+To follow wa hand relivery
+* Nothin/to lolow, FAX = originat
+
+
+500 S. Australian Ave, Ste 400
+West Palm Beach, FL 33401
+Facsimile:
+July 21, 2011
+DELIVERY BY ELECTRONIC MAIL
+Roy Black, Esq.
+Black Srebnick Kornspan & Stumpf P.A.
+201 S. Biscayne Blvd, Suite 1300
+Miami, FL 33131
+Re:
+Jeffrey Epstein
+Dear Mr. Black:
+On July 17, 2011, the Office received a written request from the District Attorney of the
+County of New York for a copy of the signed Non-Prosecution Agreement and the list of identified
+victims that was provided to Mr. Epstein pursuant to the Non-Prosecution Agreement. Pursuant to
+the District Attorney's request, the U.S. Attorney's Office intends to disclose these items to
+, Assistant District Attorney, at 5:00 p.m. on Friday, July 22, 2011. Pursuant to the terms
+of the Non-Prosecution Agreement, the Office is hereby giving you notice of this intended
+disclosure.
+Sincerely,
+Wifredo A. Ferrer
+By:
+cc:
+Assistant United States Attorney
+Chief, Northern Division
+Assistant District Attorney, County of New York
+
+
+West Palm Beach, FL 33401-6235
+DATE: 7/21/2011
+TO:
+Deborah Morse
+ORGANIZATION: District AtaneysOffice Appeals Bureau
+SUBJECT:
+FROM:
+(Fax)
+NUMBER OF PAGES, INCLUDING THIS PAGE: 2
+COMMENTS:
+Original document:
+To follow via regular mail
+
+
+Fax Number
+Fax Name
+Model Name
+No. Name/Number
+211
+: JUL-21-20111 02: 0BPM THU
+Phaser 3300MFP
+StartTime
+Time Mode
+07-21 02:07PM 00'25 BCM
+Page Result
+002/002 O.K
+Shite sate Attores once
+Nest Palm Beach, I'L 33401-6235
+DATE: 7/21/2011
+o: Deborah Morse
+ORGANIZATION: District AttamaysOfice- Appeals Bureau
+FAX#:
+SUBJECT:
+FROM;
+(Fax)
+NUMBER OF PAGES, INCLUDING THIS PAGH
+COMMENTS:
+Original document:
+-
+To follow via regular nail
+To folow wis hane delivery
+_X.
+Nothing to tallow, FAX = original
+
+
+
+Fax:
+OUNTY OF NEW YOR
+ONE HOGAN PLACE
+Now York, N. Y. 10013
+Jul 17 2011 10:15pm P001/002
+CYRUS R. VANCE, JR.
+To:
+APPEALS BUREAU
+FAX DOCUMENT COVERSHEET
+FAX#
+July 17,2011
+AUSA Marie Villafaña
+Fax:
+From:
+Deborah Morse
+Tel #:
+# of Pages 2
+_ (includes cover sheet)
+URGENT
+ROUTINE
+Deliver Immediately
+Discuss with Appropriate Person(s)
+As Requested
+For Your Approval
+•
+Review and Comment
+Take Necessary Action
+For Your Information
+Reply Via FAX
+•
+File
+Reply Via Messenger
+Reply Directly
+0
+Progress Report
+Investigate
+Let's Discuss
+Prepare Reply for Signature
+Other Action To Be Taken/Additional Comments:
+My transit feet tom in dap pati ge
+transmittal sheet from !
+Agaria, I appreciate your cooperati -
+Deborah Morse
+
+
+212335928B
+Fax:
+OF THe
+COUNTY OF NEW YORK
+ONE HOGAN PLACE
+Now York, N. Y. 10013
+P
+Jul 17 2011 10:15pm P002/002
+CYRUS R. VANCE, JR.
+July 15, 2011
+THI, Esq.
+Assistant United States Attorney
+Office of the United States Attorney
+500 S. Australian Avenue
+Suite 400
+West Palm Beach, Florida 33401
+Dear Ms.
+As we have discussed, I am currently working on the appeal brought
+by defendant Jeffrey Epstein in
+which he challenges his risk-offender
+designation under New York State's Sexual Offender Registration Act.
+The non-prosecution agreement between defendant and your Office
+would be of assistance to us in fashioning our response on appeal. I would
+appreciate it if you would send us a copy of that agreement, including the list
+of victims.
+Please let me know if you need any further information in order to
+make this material available. I appreciate your assistance, and courtesy, in
+this matter.
+West. Man
+
+
+500 S. Australian Ave, Ste 400
+Wet aim Beach, FL. 3401
+Facsimile:
+July 21, 2011
+DELIVERY BY ELECTRONIC MAIL
+Roy Black, Esq.
+Black Srebnick Kornspan & Stumpf P.A.
+201 S. Biscayne Blvd, Suite 1300
+Miami, FL 33131
+Re:
+Jeffrey Epstein
+Dear Mr. Black:
+On July 17, 2011, the Office received a written request from the District Attorney of the
+County of New York for a copy of the signed Non-Prosecution Agreement and the list of identified
+victims that was provided to Mr. Epstein pursuant to the Non-Prosecution Agreement. Pursuant to
+the District Attorney's request, the U.S. Attorney's Office intends to disclose these items to
+1, Assistant District Attorney, at 5:00 p.m. on Friday, July 22, 2011. Pursuant to the terms
+of the Non-Prosecution Agreement, the Office is hereby giving you notice of this intended
+disclosure.
+Sincerely,
+Wifredo A. Ferrer
+By:
+CC:
+Assistant United States Attorney
+. Chief, Northern Division
+, Assistant District Attorney, County of New York
+
+
+COUNTY OF NEW YORK
+ONE HOGAN PLACE
+New York, N. Y. 10013
+CYRUS R. VANCE, JR.
+DeSTRICT ATTORNEY
+May 6, 2011
+Esq.
+Assistant United States Attorney
+Office of the United States Attorney
+500 S. Australian Avenue
+Suite 400
+West Palm Beach, Florida 33401
+Dear Ms.
+As I explained during our telephone conversation last week, I am
+currently working on an appeal brought by defendant Jeffrey Epstein.
+Defendant Epstein challenges the designation that he was given under New
+York State's Sexual Offender Registration Act... The underlying sexual
+misconduct at issue was the subject of an investigation and/or prosecution
+by your Office, as well as the Florida State's Attorney Office in Palm Beach
+County.
+I know that you handled the matter on behalf of your office when the
+case was presented to the federal grand jury. Those grand jury proceedings
+would be of assistance to us in fashioning our response on appeal, and 1
+would appreciate it if you would send us a transcript of those proceedings. If
+we furnish the minutes to the appellate court, we would do under seal for
+the purpose of an in camera review.
+Please let me know if you need any further information in order to
+make the materials available. I appreciate your assistance, and courtesy, in
+this matter.
+Delat. Mare
+
+
+COUNTY OF NEW YORK
+ONE HOGAN PLACE
+New York, N. Y. 10013
+CYRUS R. VANCE, JR.
+August 15, 2011
+Assistant United States Attorney
+Office of the United States Attorney
+500 S. Australian Avenue
+Suite 400
+West Palm Beach, Florida
+33401
+Dear Ms.
+Pursuant to our conversation, I have enclosed copies of the brief and
+appendix filed by defendant Jeffrey Epstein on appeal, as well as a copy of
+our brief in response.
+I look forward to hearing your opinion.
+Belunk. Mane
+
+
+New York County Clerk's Index No.
+Neto Hark Supreme Omurt
+APPELLATE DIVISION-FIRST DEPARTMENT
+PEOPLE OF THE STATE OF NEW YORK,
+-against—
+JEFFREY E. EPSTEIN,
+Respondent,
+Defendant-Appellant.
+APPENDIX
+CYRUS R. VANCE, JR.
+NEW YORK COUNTY DISTRICT
+ATTORNEY'S OFFICE
+One Hogan Place
+New York, New York 10013
+JAY P. LEFKOWITZ
+SANDRA LYNN MUSUMECI
+KIRKLAND & ELLIS LLP
+601 Lexington Avenue
+New York, New York 10022
+:
+Attorneys for Respondent
+Attorneys for Defendant-Appellant
+REPRODUCED ON RECYCLED PAPER
+
+
+TABLE OF CONTENTS
+PAGE
+Appellant's Pre-Argument Statement, dated February 9, 2011.............. A1
+Appellant's Notice of Appeal, dated February 9, 2011 ..................... A3
+Order Appealed From, dated January 18, 2011 with Notice of Entry........ A4
+Palm Beach Police Department - Probable Cause Affidavit of
+Det.
+- Defendant
+dated May 1, 2006
+. Аб
+Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein,
+dated July 23, 2006............
+A28
+2006 Grand Jury Indictment of Felony Solicitation of Prostitution -
+Jeffrey E. Epstein.
+A29
+Information for Procuring Person under 18 for Prostitution -
+Jeffrey E. Epstein, dated June 26, 2008
+A31
+Guilty Plea for Felony Solicitation of Prostitution and Procuring
+Person under 18 for Prostitution - Jeffrey E. Epstein,
+dated June 30,20........
+• ....
+A32
+Judgment for Procuring Person under 18 for Prostitution -
+Jeffrey E. Epstein, dated June 30, 2008
+........
+A33
+Sentence for Procuring Person under 18 for Prostitution -
+Jeffrey E. Epstein, dated June 30, 2008
+.... A34
+Community Control Standard Conditions, dated June 30, 2008.
+.. A35
+Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein,
+dated June 30, 2008............
+A47
+
+
+iii
+Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz Requesting a
+Continuance of the Hearing, dated September 9, 2010.
+Letter from Supreme Court to Sex Offender Registry Unit Enclosing
+Final Determinations, dated January 19, 2011
+Court Action Sheet - Jeffrey Epstein, No.
+PAGE
+A77
+A78
+A80
+Handwritten Notations on Court Jacket - Jeffrey Epstein,
+No.
+... . ..
+A81
+Transcript of SA Hearing, dated January 18,211...000./
+A82
+
+
+Al
+Appellant's Pre-Argument Statement, dated February 9, 2011
+[pp. A1-A2]
+SUPREME COURT FOR THE STATE OF NEW YORK
+COUNTY OF NEW YORK
+PEOPLE OF THE STATE OF NEW YORK,
+Plaintiff-Respondent,
+Index No.:
+-
+- against -
+PRE-ARGUMENT STATEMENT
+JEFFREY E. EPSTEIN,
+Defendant-Appellant.
+1. TITLE OF ACTION: As set forth in caption.
+2. FULL NAMES OF ORIGINAL PARTIES AND ANY CHANGE IN THE PARTIES:
+As set forth in caption. There has been no change in the parties.
+3. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR APPELLANT
+OR PETITIONER:
+Jay P. Lefkowitz, P.C.
+Sandra Lynn Musumeci
+KIRKLAND & ELLIS LLP
+601 Lexington Avenue
+New York, New York 10022-4611
+Telephone:
+Facsimile
+4. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR
+RESPONDENT:
+LEW ROY DISTRICT ATTORNEY'S OFFICE
+One Hogan Place
+New York, NY 10013
+Telephone:
+5. COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL
+IS TAKEN: New York Supreme Court (Criminal Term), New York County.
+6. THE NATURE AND OBJECT OF THE CAUSE OF ACTION OR SPECIAL
+PROCEEDING: Sex Offender Registration Act (SORA) hearing, pursuant to Article 6-C of the
+Correction Law.
+7. RESULT REACHED IN THE COURT OF ADMINISTRATIVE BODY BELOW:
+Supreme Court, New York County, adjudged appellant Jeffrey E. Epstein to be a Level 3 sexual
+offender, without additional designation.
+GROUNDS FOR SEEKING REVERSAL, ANNULMENT, OR MODIFICATION: The
+Court's designation of appellant Jeffrey E. Epstein as a Level 3 sexual offender was an abuse of
+
+
+A3
+Appellant's Notice of Appeal, dated February 9, 2011
+SUPREME COURT FOR THE STATE OF NEW YORK
+COUNTY OF NEW YORK
+THE PEOPLE OF THE STATE OF NEW
+YORK,
+Plaintiff,
+NOTICE OF APPEAL
+Index No.
+CRIMINAL TERM PART 66
+JUSTICE RUTH PICKHOLZ
+- against -
+JEFFREY E. EPSTEIN,
+Defendant.
+PLEASE TAKE NOTICE that the above named defendant, Jeffrey E. Epstein, hereby
+appeals to the Appellate Division of the New York Supreme Court in and for the First
+Department, from an order entered in the above entitled action in the office of the Clerk of New
+York County on the 18th day of January 2011, which order adjudged defendant Jeffrey E.
+Epstein to be a Level 3 sexual offender pursuant to Article 6-C of the Correction Law, and this
+appeal is taken from each and every part of that order as well as from the whole thereof.
+Dated: February 9, 2011
+To:
+Clerk, New York County
+Cyrus R. Vance, Jr
+NEW YORK DISTRICT ATTORNEY'S
+OFFICE
+One Hogan Place
+New York, NY 10013
+Telephone:
+Sandra Lynn Musumeci
+KIRKLAND & ELLIS LLP
+601 Lexington Avenue
+New York, New York 10022-4611
+lelepnone:
+Facsimile:
+Attorneys for Defendant
+Jefrey E. Eps
+FEB 0.9 2017
+SUPREME COURT
+NEW YORK COUNTY
+APPEALO FURRAU
+
+
+SUPREME GO FOR THE STATE OF NEW YORK
+THE PEOPLE OF THE STATE OF NEW
+YORK,
+Plaintiff,
+NOTICE OF ENTRY
+Index No.
+CRIMINAL TERM PART 66
+JUSTICE RUTH PICKHOLZ
+- against -
+JEFFREY E. EPSTEIN,
+Defendant.
+PLEASE TAKE NOTICE that the within is a copy of an order entered in this action on
+the 18th day of January 2011, in the office of the Clerk of the County of New York.
+Dated: February 9, 2011
+To:
+Clerk, New York County
+Cyrus R. Vance, Jr.
+NEW YORK DISTRICT ATTORNEY'S
+OFFICE
+One Hogan Place
+ew York, NY 10013
+"elephone
+Lefkowitz, P.C.
+Sandra Lynn Musumeci
+KIRKLAND & ELLIS LLP
+601 Lexington Avenue
+New York, New York 10022-4611
+Telephone:
+Facsimile:
+Attorneys for Defendant Jeffrey E. Epstein
+-
+FILED
+FEB 0.9 2011
+SUPREME COURT
+NEW YORK COUNTY
+APPEALO BUREAU
+
+
+A7
+Agency ORK# FLO 500600
+conversation ocourred betwen
+and
+whereas
+she should say she was eighteen. It was later confirmed by the
+on February 6, 2005. According to
+father,
+renorterly told
+that
+drove a pick up truck.
+that if Jeff asked her age,
+picked his daughter up
+described Epstein's house as a two-story pink house with a Cadillac Escalade parked in the
+driveway. She recalled that Jeff's house was on a dead end street. Upon arriving at the house
+stated that
+they walked up a driveway, past what appeared to be a small guard/security root. A male approaching them
+asking what they wanted.
+stated they were there to sec Epstein. The male allowed them to continue
+walking up to the house.
+stated the man told them that Epstein was not there but was expected back. He
+allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside.
+Shortlv thereafter, Epstein and his assistant, described as white female with blond hair and later identified as
+, entered the kitchen. Epstein introduced himself to
+described Epstein as being
+approximately forty-five years old, having a long face and bushy eyebrows, with graying hair.
+and Epstein left the kitchen leaving
+alone in the kitchen. They returned a short time later.
+spoke briefly in the kitchen.
+was instructed to follow
+recalled walking up a
+flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there.
+was a large bathroom to the right and a hot pink and green sofa in the room. There was a door on each side of
+recalled there being a mural of a naked woman in the room, as well as several photographs of
+naked women on a shelf.
+told the victim that Epstein would be up in a second.
+Epstein entered the room wearing only a towel and told
+to take off her clothes.
+stated Epstein
+was ster when he told her to take off her clothes.
+said she did not know what to do as she was the only one
+there in the room
+she took off her shirt leaving her bra on. Epstein had removed his towel and told the
+to
+take off everything.
+stated Epstein was nude when he took his towel off, placing it on the floor as he laid
+down on the table.
+stated she then removed her pants leaving her thong panties on. Epstein then instructed
+her to give him a massage pointing to a specific lotion for her to use. As
+began to give Epstein the massage,
+he told her to met on his back.
+stated she
+said Epstein was specific in his instruction to her on how to massage
+him, telling her to go clockwise or counter clockwise. Epstein then turned over and instructed
+to massage his
+chest
+was now standing on the ground and resumed massaging Epstein's chest area. stated Epstein
+as she massaged his chest and shoulder area. Epstein then turned to his side and
+started to rub his penis in an up and down motion. Epstein then pulled out a purple vibrator and began to
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det
+, who is personally known to me.
+State of Florida
+County of Palm Bench
+Signature/Artesing Officer
+Page 2of22
+
+
+A9
+Agency ORI# FLO 500600
+(Unknown last name) and
+(Unknown last name) picked
+up and she was taken to
+Epstein's house. Upon her arrival to the house she was introduced to Epstein in the kitchen of the house. She
+was also introduced to a white female known to her as
+. She was led upstairs to the main bedroom known
+to her as Jeff Epstein's bedroom.
+arranged the massage table and coveted the fable with a sheet. She
+brought out the massage oils and laid them next to the massage bed.
+then left the room and informed
+Jeff would be in, in a minute. Jeff entered the bedroom wearing only a towel. He removed the towel
+and laid nude on the massage table. He laid on the table onto his stomach and picked a massage oil for
+to rub on him. During the massage,
+stated "He tried to touch me and I stopped him." 1 asked how he
+tried to touch her.
+stated that Epstein
+and she felt uncomfortable.
+told
+Epstein, I'll massage you but I don't want to be touched.
+stated she performed the massage naked. At
+the conclusion of the massage, Epstein paid
+$200.
+After the massage Epstein stated to
+that he understood she was not comfortable, but he would
+pay her if she brought over some girls. He told her the younger the better.
+stated she once tried to bring
+a 23 year old female and Epstein stated that the female was too old.
+stated that in total she only
+remembers six girls that she brought to see Epstein, each time she was paid $200.
+stated she had
+brought the following girls:
+• 2
+L. (al6 year old female),
+(a 16 year old
+female) and."....
+said that at the time she brought these girls to Epstein's house they were alll 4
+through 16 years of age. I asked
+which one was the youngest.
+advised
+was the youngest as
+she was fourteen when the massage occurred.
+stated every girl she brought knew what to expect when
+they arrived. They were told they would provide a massage, possibly naked, and allow some touching. I asked
+her if
+was aware. She stated every girl she brought know what to expoct. She explained she knew that
+wanted to make money. She approached
+and explained about going to work for Jeff, agreed and
+arrangements were made to bring her to Epstein's house on a weekend.
+stated that she and
+(Later identified as ...
+-) picked up
+at her house.
+stated that at that time she was driving
+a red pickup truck. They traveled to Epstein's house and entered through the kitchen door. They tet with the
+house chef and Epstein's assistant
+was introduced to Epstein while they were in the kitchen area.
+Led | upstairs and Epstein went upstairs. When the massage was over
+returned to the kitchen area.
+stated she was paid $200.00 for bringing
+to Epstein's house.
+| stated told her she was
+paid $300.00 for the massage.
+number to avoid being contacted by
+stated that I was the last person she brought to Epstein's house. She had changed her cellular
+She continued stating that she had no direct contact with Epstein
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det
+, who is personally known to me.
+State of Florida
+County of Palm Beach
+signature Ary sing Officer
+Signature of Police Officer (F.S.S. I17.10)
+Page 4of 22
+
+
+Agency ORI# FLO 500600
+for Jeff. She was told she would have to provide a massage to Jeff. C-, i. stated upon her arrival to the house
+• she was brought to the kitchen area by
+. They tet with the house chef who was already in the kitchen
+area.
+. stated
+would wait for her in the kitchen. !
+• was introduced to
+, Jeff's
+assistant, who brought her upstairs to the master bedroom.
+prepared the room and tassage table for a
+massage. Epstein entered the room wearing only a towel and she provided a massage.
+*: stated she kept
+her clothes on during the massage. She advised sometime during the massage, Epstein
+pulled her close to him. I
+.. said she was uncomfortable by the incident involving Jeff. At the conclusion of
+the massage, she was paid $200.00 for the massage. I asked"..... If she has any formal training in massages to
+which she replied no. I asked her if
+received any monies for taking her to perform the massage.
+stated
+had received money for taking her there but was unsure in the amount. ?
+it stated she
+returned to Epstein's house on another occasion with
+and anothet girl
+• t stated
+she waited in the kitchen with
+, While...
+- was taken upstairs by
+i stated she only did the
+nassage once as she was uncomfortable with the whole experience.
+At the conclusion of the interview, the tape was stopped. I was informed that
+had attempted to
+reach
+- via cell phone. A voice mail message on October 4, 2005 at 10:59 am, revealed a female voice
+who identified herself as
+who requested:
+to call her baok reference the police questioning. -
+provided the incoming telephone number as
+stated she inadvertently told".-.
+about the police investigation because =.. had called her to tell her about how she just received a rental car
+from Jeff Epstein. ":
+... had called her to fell her that she was given a rental car, a 2005 Silver Nissan Sentra,
+to utilize to visit family and visit Epstin. 2.
+.. asked her what was going on at the house that the police would
+be asking questions.
+• then called Jeff and
+and asked what was going on
+reference the ongoing police investigation. According to
+has since then been trying to contact her
+to ask about the police questions. I instructed "
+not to contact
+and do not provide any more
+information to...
+as she would notify Jeff Epstein and
+what was transpiring
+On Ootober4, 2005, I made telephone contact with
+who had left several messages for me to contact
+her. During the message, she advised she was not completely truthful when we met in person but would like to
+speak with me to advise what had happened. She further advised she did not want to speak of this incident in
+front of her mother. At approximately 3:48 pm I made telephone contact with . During a taped recorded
+tatement | stated the following: approximately a year ago, when she was sixteen years of agc,
+M took her
+because they both attend Royal Pal Beach High School. The first
+drove to the house. They entered through the kitchen area where she was
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det
+_ who is personally. known to me.
+State of Florida
+County of Palm Beach
+Signature of Police Officer (F.S.S. 117.10)
+Signature A resting Officer
+Page of 22
+
+
+A13
+Agency ORI# FLO 500600
+table, straddling Epstein to massage his back. While doing this
+Epsteins.
+was instructed to return to the ground at which time Epstein turned to have his chest rubbed.
+was sure he was masturbating based on his hand movements going up and down on his penis area.
+i advised she
+. did
+not want to look at his penis area because she was incomfortable. Epstein removed a large white vibrator which
+was next to the massage table and turned it on. -.:
+... stated Epstein began
+Shortly thereafter, Epstein ejaculated and removed himself from the table. He
+walked over to where the shower was and opened the glass door. She waited as he was taking a shower in her
+direct view. When I asked .....' how old she was when this occurred, she stated she had just turned
+seventeen. At the conclusion of the shower, .
+: was paid either $350.00 or $400.00. She stated she
+wasn't sure, but knows it was close to $400.00.
+stated she never returned to provide a massage for
+Epstein.
+At approximately 2:10 pra, Det
+and I met with
+I tob
+, at her residence. As
+was only seventeen years of age, I had notified her mother, that she would be interviewed reference at ongoing
+investigation in Palm Beach. I assured her that her daughter was not a suspeot. I explained the possibility of her.
+being either a witness or victim.
+advised she wanted
+to cooperate and consented to the interview:
+During a sworn taped statement,
+stated the following: at the age of sixteen, during the month of
+September 2004, she was approached by
+for a chance to make money.
+was friends with
+associates of
+and knew the same people.
+had been previously told by her friends from Royal Palm
+Beach High School, what:
+did for Epstein.
+called a person known to
+as
+and
+scheduled the appointment.
+picked
+up and drove her to Palm Beach to a street called "Brillo Way".
+They drove to the end of the street and entered a large driveway. They entered the kitchen arca of the house and
+met with Epsteit.
+was introduced to Jeff Epstein.
+led
+upstairs to the main bedroom area and
+set up the room with a massage table and set out the oils.
+stated that while going up the stairs and into the
+bedroom she observed numerous photographs of naked young giris.
+dimmed the lights and turned on
+soft music.
+exited the room and Epstein entered the room wearing only a towel. Epstein picked oils and
+instructed her to rub his legs, under his buttocks, back and chest area. Epstein asked her to get comfortable.
+advised she did not remove her clothes. She was wearing tight jeans and a cropped tank top exposing her belly
+area: During the massage, Epstein removed his towel and laid on the massage table naked. As
+Epstein's chest arca, he attempted to reach down her pants to touch her buttocks arca however was unable to »
+. Epstein moaned as she
+The foregoing instrument was sworn to or affirried
+before me this 1" day of May, 2006 by
+Det
+, who is personally known to me.
+State of Florida
+County of Palm Beach
+Signature of Police Officer (F.S.S. 117.10)
+Signature Aresting Officer
+PageBof 22
+
+
+"A15
+Agency ORIN FLO 500609
+Epstein wanted to be rubbed on his back and recently he began turning over and have her rub his chest as he
+masturbated. He would try to touch
+as she
+* stated "Jeff would try to get away
+with more and more on each massage"
+stated Epstein would try to touch her more and on one occasion
+he attempted to usc a massager/vibrator on her.
+drove
+to the housc for the original massage. -
+left
+her cell phone number and every time Epstein Would come into town,
+would call her for an
+appointment to "work". Each time she went,
+would meet her at the kitchen door arca. She would bring
+her upstairs and prepare the massage table.
+advised Epstein would ask her questions about herself. Epstein
+knew she was a
+and would be attending
+1. Iasked:
+if Epstein knew het real
+age.
+i. stated Epstein did and didn't care. The most recent massage she provided was on October 1, 2005.
+During the massago, she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in
+, Florida. Epstein had told her she could borrow one of his vehicles but later stated he would rent her a
+car. She continued with the massage as Epstein
+and
+asked
+•if she was wearing undergarments to which she replied her thong underwear. Once he tried to touch
+i, she would pull away from him and he would stop.
+; was asked if he ever used a vibrator on her.
+- was awarc of the vibrator but advised she never would allow him to
+on her. She described
+the vibrator as the large white vibrator with a huge head on the tip of the vibrator. She stated he kept the vibrator
+in a closet near the massage table.
+. stated that on October 3, 2005, she was contacted by Epstein's assistan,
+who informed her
+that Jeff Epstein had rented her a new Nissan Sentra and she should come by the house to pick it up.
+informed
+she would have the car for a month. -
+• stated Epstein krew her car was not working properly
+and that she had missed appointments in the past because of her car being inoperable.
+:explained the car is
+currently parked next to the
+Gym field. I asked her if she ever took any one to the house.
+explained she took !
+; a friend of hers who attendod Royal Palm Beach High School, who has
+relocated to
+to attend college. I asked if she ever allowed another female in the room.
+i advised no
+one was brought into the room with her.
+At the conclusion of the interview, Det
+and I went to the gym area of
+and
+located the Silver Nissan Sentra bearing Florida tag l
+• The vehicle is registered to Dollar Rent a Car
+out of the Palm Beach International Airport. The vehicle was rented by Janusz Banasiack, later learned to be
+Epstein's houseman, and paid with Epstein's credit card.
+On September IT, 2005, w/f
+, dob 12/30/1986, was arrested by the Palm Beach Police Department
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det
+I, who is personally known to me.
+State of Florida
+County of Palm Bench
+Signatura/ Arresting Officer
+Signature of Police Officer (F.S.S. 117.10)
+Pagelor 22
+
+
+A17
+Agency ORI# FLO 500600 "
+during the female on female intercourse and provide oral sex to both
+the time
+was sixteen years of age.
+and
+This occurred during
+advised this continued to escalate during two years. The routine became familiar to
+• Epstein's
+assistant
+would telephone her every time Epstein was in the Town of Palm Beach and would place
+appointments for her to visit and work for Epstein. Each time something new was introduced, additional monies
+were produced and offered for to allow the acts to happen.
+consented to perform M these acts but was
+adamant that there was an understanding with Epstein that no vaginal penetration would occur with his penis.
+explained that Epstein's penis was deformed.
+I explained that his penis was oval shaped. |
+claimed when
+Epstein's penis was erect, it was thick toward the bottom but was thin and small toward the head portion. AH
+called Epstein's penis "egg-shaped."
+I stated Epstein would photograph
+and her naked and
+having sex and proudly display the photogtaphs within the home.
+stated during one visit to Epstein's house
+in which she provided a massage to Epstein, his female friend.
+was also present.
+provided the massage in which
+and her would
+for Epstein to
+enjoy. Towards the end of this massage, Epstein grabbed
+and turned her over onto her stomach on the
+massage table and
+stated Epstein began to
+became upset over this. She said her head was being held against the table
+I. She screamed "No!" and Epstein stopped. She told him that she did not want to have his
+penis inside of her. Epstein did not ejaculate inside of her and apologized for his actions and subsequently paid
+her a thousand dollars for that visit.
+stated she knows he still displays her photographs through out the house.
+On October 12, 2005, Det
+and I met with..
+dob
+i, who stated during
+a sworn taped statement, that nothing happened between her and Epstein.
+* . appeared nervous during the
+interview. I assured her that I have spoken with other people who advised differently.
+i stated on several
+occasions she provided a massage to Epstein. She stated she was brought to the Epstein house in March of
+2005.
+, a classmate at Royal Palm Beach Hieh School, approached her and asked her if shre
+wanted to "work".
+i made the arrangements with
+, Epstein's assistant.
+...., who has no formal
+training in providing massages, stated she provided a massage, fully clothed for $200.00. As I sensed hesitancy
+in her answers, I asked
+if she had been contacted by anyone from Epstein's organizations of his house.
+stated she was interviewed already by a private investigator for Epstein. He identified himself as "Paul".
+and inquired about the police investigation, and left his telepbone number
+for additional contact.
+'provided no additional information, as it appeared her responses were almost scripted.
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det
+I, who is personally known to me.
+State of Florida
+County of Palm Beach
+Signature Arresting Officer
+-
+. Signature of Police Officer (f.S.S. 117.10)
+Page 17r 22
+
+
+ALAJU LON
+A19Lu..
+Agency ORI# FLO 500600
+attending Royal Paim Beach High School.
+• would approach females who wished to work for Epstein.
+• stated she was offered to work for Epstein but declineů.
+- explained that "work" means give
+massages. She was asked about any formal training in providing massages which she said "nо."
+•said
+she accompanied
+and other females who were taken to Epstein's house to provide massages. !
+further stated she had been to the house approximately 4 or 5 times in the past year. She accompanied
+with
+, and.
+.. Each time the girls were taken
+over, they were previously told they would have to provide a massage, possibly naked. They were also told that
+should Epstein require them to do anything extra, and they were not comfortable just to tell him and he would
+stop.
+• stated
+_ received $200.00 for each girl she brought over to massage Jeffrey Epstein.
+When I asked which girl appeated to be the youngest, she replied,, who was really young, fifteen years old at
+the most.
+• further stated each time she went to the house, she gat in the kitchen and waited with
+until the massago was over. She further stated that the cook would make lunch or a snack for them as they
+waited. I asked her if there was anything that caught her attention within the home.
+-
+stated there were a
+lot of naked girls in photographs throughout the house.
+On November 8, 2005, at approximately 2:00pm, I met with
+:, dob
+I, at the
+Palm Beach Police Department. During a sworn taped statement,
+stated she had met Epstein.
+approximately two years ago when she was first approached by
+,, a classmate at Royal Palm Beach
+High School.
+approached her about working for Epstein and providing a massage to him for $200.00.
+bad made the arrangements however was unable to take her the day the arrangements were made.
+had
+take
+'also attended Royal Palm Beach High School and was familiar
+with Epstein. :
+recalled she was brought there and entered through the back kitchen door. She had met
+with an assistant
+and another assistant Adrianna.
+brought her upstairs as she observed several
+photographs of naked females throughout the house.
+stated Epstein came in the room, wearing only a
+towel, and laid on the table.
+stated he picked out the oils he wanted her to use and requested she
+remove her clothing to provide the massage.
+stated that on the first massage she provided she did not
+remove her clothing
+• stated she had returned several times after that. Each time she returned it was
+more than a massage. Epstein would walk into the master bedroom/bathroom area wearing only a towel. He
+would masturbate as she provided a massage.
+stated she was unsure if he climaxed as he masturbated
+under the towel. Additionally, she never looked below his waist. She claimed that Epstein would convince her to
+remove her clothes. She eventually removed her clothes and staved in ber thong panties. On occasion, Epstein
+would
+stated she had been to the house
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det
+, who is personally known to me.
+State of Florida
+County of Palm Beach
+Sigursue
+Signature of Police Officer (T.S.S. 117.10)
+Page/4of22
+
+
+A21
+Agency ORIN FLO S00600
+as
+itated
+• brought her into the house and she was introduced to !
+then
+brougit her upstairs into a master bathroom, located within the bedroom.
+stated she met. Epstein in the
+bathroom. He laid on the table and picked the massage oils. She provided the massage as he laid naked on the
+massage bed. She stated she rubbed his calves and back area Upon the end of the massage, Epstein removed
+himself from the massage table and paid her $300.00 for the massage.
+• said each subsequent time she
+went to the house, she was notified by !
+that Epstein was in town and would like her to "work".
+" stated she returned to the house and was again led upstairs by
+She provided the massage,
+clothed.
+• was asked if she ever removed her clothing to provide a massage.
+• stated it was not
+until the third time that she went that she removed her clothing.
+stated she was notified by
+that
+Epstein wanted het to come to work. She arrived at the house and was led upstairs by !
+She started
+•providing the massage when Epstein asked her to remove her clothing.
+• removed her pants, shirt and
+bra. She stayed in her thong panties and continued rubbing Epstein. Epstein turned over onto his back and she
+stated she knew he was masturbating himself as she providing the massage.
+stated she believed he climaxed based on his breathing. She did not want to vicw either the climax or
+the fact that he was masturbating.
+stated once the breathing relaxed he got up and told her to get
+dressed. She was paid $300.00 for her services.
+stated on the last time she went to provide a
+massage, she was notified by
+to come to the house and "work".
+stated she was now
+dating her current boyfriend and did not feel comfortable going. She recalled it was approximately January 2005.-
+She said she went, already thinking that this would be the last time. She went upstaits and went into the master
+bathroom. She met with Epstein, who was wearing only a towel, and laid onto the table.
+stated
+Epstein caught her looking at the clock on several occasions. Epstein asked her if she was in a hurry, --p-...
+stated her boyfriend was in the car waiting for her.
+further stated that Epstein got upset as he wasn't
+enjoying the massage. She told him that she didn't want to continue and she would not be back. Epstein told her
+to leave as she was ruining his massage.
+advised she had no formal training in providing any massages.
+stated although she had a falling out with Epstein, she still received a Christmas bonus from Epstein.
+stated she was wired money from Western Union for her Christmas bonus. Subpoena results from
+Western Union revealed money was sent from Jeffrey Epstein on December 23, 2004. - .
+received
+$200.00 from Epstein for her Christmas bonus.
+On November 15, 2005, Det.
+and I met with
+During a sworn taped
+statement,
+stated she met Jeffrey Epstein over a year ago. She was sixteen years of age and was
+approached by
+, a fellow Royal Palm Beach High School student, who informed her that she could
+make $200.00 providing a massage to Epstein. =...
+had informed her that she would have to provide this
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det
+, who is personally known to me.
+Signature of Police Officer (F.S.S: 117.10)
+State of Florida
+County of Palm Reach
+Signature/Arresting Officer
+Datc:
+Page|for 22
+
+
+A23
+Agency ORI FLO 500600
+During the course of the investigation a search warrant was executed at Jeffrey Epstein's home located at
+358 El Brillo-Way in Palm Beach. While in the home I observed the pink and green couch within the master
+bedroom area just as the girls previously mentioned. The stairway, which is located from the kitchen area to the
+master bedroom area, is lined with photos of naked young girls. Additionally, numerous photographs of naked
+young females, some of which appeared to be the girls I previously interviewed, were on display throughout the
+house. Also located in the house were various phone message books. The telephone message books have a
+duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn
+on the perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers
+were on the copy of the messages. I recoguized various numbers and names of girls that had already been
+interviowed. The body of the messages were time of the day that they called for confirmation of "work." Other
+names and telephone numbers were located in which the body of the messages were, "I have girls for him" or "I
+have 2 girls for him." These messages were taken by
+who signed the bottom of the messagcs.
+During the execution of the warrant, I located a Royal Palm Beach High School transcript for
+in Epstein's
+bedroom desk. This desk had stationary marked Jeffrey E Epstein. I located a wood colored armoire beside
+Epstein's bed that contained a bottle of "Joy Jelly," which is used to provide a warm massage. Several massage
+tables were located throughout the second floor of the residence, including a massage table found in Epstein's
+bedroom. On the first floor of the residence I found two covert cameras hidden within clocks. One was located
+in the garage and the other located in the library arca on a shelf behind Epstein's desk. A computer was located
+which was believed to contain the images from the covert cameras. The computer's hard drive was reviowed
+which showed several images of
+and other witnesses that have been interviewed.
+of these
+images appeared to come from the camera positioned behind Epstein's desk.
+On December 13, 2005, Det.
+and I met with
+dob
+During a swor taped
+statement,
+stated that when she was sixteen years old she was taken to Epstein's house to provide a massage
+for money.
+stated it was before Christmas last year (2004) when an associate,
+approached her and
+asked if she needed to make money for Christmas.
+made arrangements to take
+to the house and drove
+to the house to "work." They were encountered by a white female with long blond hair.
+was unable to
+remember the name of the white female with blond hair but knew she was Epstein's assistant. She was led
+upstairs by the white female who explained that there would be lotions out already and Epstein would choose the
+lotion he wanted her to use. She was led through a spiral staircase which led to. a master bedroom and
+bathroom. The massage table was already set up in the bathroom.
+described the bathroom as a large
+spacious bathroom with a steam room and shower beside it.
+was introduced to Epstein who was on the
+phone when she entered the room. Epstein was wearing a white towel and laid on his stomach so that
+may
+The foregoing instrument was sworn to or affirmed
+Deare me ils 1" day is personally kby
+who is personally known to me.
+State of Florida
+County of Palm Beach
+Signature/ArreSting Officer
+Signature of Police Officer (IS.S. 117.10)
+Page /89822
+
+
+A25
+Agency ORJ# FLO 500600
+to model lingerie for a wealthy Palm Beacher.
+was taken to Epstein's house located on Bl Brillo Way.
+introduced
+to Jeffrey Epstein. Epstein had his personal chef prepare dinner for
+and
+At the
+conclusion of dinner,
+and Epstein brought
+upstairs into a master bedroom area.
+observed a large
+massage table with a sheet on it. Epstein entered through a door and exited wearing only a towel.
+informed that they were going to provide a massage on Epstein.
+asked why were they doing this instead
+of modeling lingerie.
+explained to
+that this was his routine and to rub his calves and feet. Epstein had
+told
+to get comfortable.
+removed her pants and blouse.
+stated she stayed only in panties as she did
+not wear a bra that evening.
+stated while rubbing his calves and feet, Epstein tumed over onto his back.
+Epstein told to rub his chest and rub his nipples.
+stated that as she started
+Epstein
+began masturbating himself. Epstein t
+Enstein
+continued to masturbate himself as he
+Epstein ejaculated on his towel and paid $200.00
+for the massage. Epstein told
+happen.
+that if she told anyone what happened at his house that bad things could
+were brought home by Epstein's houseman and
+was afraid that Epstein knew where
+she lived.
+stated that several days later she received a telephone call from
+who coordinated for
+to return to "work."
+returned to the house and was brought to Epstein's bedroom area by
+who
+prepared the room for the massage. Epstein entered the room wearing only a towel. Epstein had
+remove her
+clothing and provide the massage naked.
+began rubbing his feet and calves and Epstein turned over onto his
+back. Epstein
+- Epstein began to masturbate himself with an upwards and
+downward motion on his penis. Epstein continued to
+and masturbate with the
+other hand. Once Epstein ejaculated onto the towel he was wearing, the massage was over. L
+was paid
+$200.00 for the massage. Epstein again told
+not to speak of what happened at his house or bad things would
+happen.
+wanted to notify authoritics however she was afraid of what would happen to either her or her
+family.
+During the course of the investigation, several subjects were identified as a potential witness/victim
+through information obtained during the trash pulls, physical surveillance and telephone message books retrieved
+from the search warrant. While conducting research on the subjects, I discovered that the females were age
+eighteen or older. Interviews were conducted on the consenting adults whose statements provided the same
+massage routine when they went to "work" for Epstein. The females would be notified by
+and
+made appointments for the females to "work" for Epstein. The females would come to Epstein's house and were
+led upstairs, through a stairwell from the kitchen area, by
+to Epstein's bedroom. Epstein would then
+enter the room wearing only a towel, and ask them to get comfortable. The females would then provide the
+massage naked as Epstein would either touch their vaginas with his fingers and/or utilize the massager/vibrator on
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det
+, who is personally known to me.
+State of Florida
+County of Palm Beach
+Signature of Police Officer (F.S.S. 117.10)
+Signature/ Arresting Officer
+Pagzoot 22
+
+
+A27 raur
+Agency ORIN FLO 500600
+bed. On one occasion Epstein ordered
+to go to the Dollar rent a car and rent a car for the same girl
+he brought the roses to,
+that she could drive her self to Epstein's house without incident.
+said the
+girl always needed rides to and from the house.
+produced a green folder which contained documents,
+and a note with Mr. Epstein's stationary with direction to deliver a bucket of roses to Royal Palm Beach High
+School after high school drama performance. Also in that same note was direction to rent a car for
+and
+direction to extend the rental contract.
+During the course of the investigation, subpoenas were obtained for cell phone and home phone records
+from several victims and witnesses along with the cell phone records of
+An analysis of these
+records was conducted which found numerous telephone calls were made between
+and the victims.
+These records indicate the dates the calls were made are consistent with the dates and times they
+victims/witnesses stated they were contacted. Speoifically, The phone records showed
+called
+during the exact times and dates when victim
+advised the incident occurred.
+also coordinated
+the encounters with
+ande.
+.. during the time frame the girls
+stated they occurred.
+Pursuant to a lawful subpoena I obtained Epstein's private plane records for 2005 from Jet Aviation.
+The plane records show arrival and departure of Epstein's plane at Palm Beach International aitport. These
+records were comnared to the cell phone records of
+This comparison found that the phone calls
+made to
+and the victims were made in the days just prior to their arrival or during the time Epsteiti
+was in Palm Beach.
+Jeffrey Epstein, who at the time of these inzidents was fifty one years of age, did have vaginal intercourse
+either with his penis or digitally with
+and-..., who were minors at the time this occurred, and
+who at the time of the incident was fifty two vears of age, did use a vibrator on the external vaginal area of
+fourteen year old minor. Therefore, as
+coordinated and aided in the recruitment of minors to
+frequent Epstein's house so that sexual services were provided to Epstein, scheduled the said minors to return to
+the work for Epstein, secured their appointments for the purpose of sexual activity and lewd and lascivious acts
+with four
+counts of Principal in the I" degree Unlawful Sexual Activity with a Minor, in violation of Florida State Statute
+794.05(1), a second degree felony and there is sufficient probable cause to charge her with Lewd and
+Lascivious Molestation, in violation of Florida State Statute 800:04 (5), a second degree felony.
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det
+, who is personally known to me.
+State of Florida
+County of Palm Beach
+Signature of Police Officer (F.S.S. 117.10)
+signature/Ar Gung Officer
+Pagezzof 22
+
+
+A29
+2006 Grand Jury Indictment of Felony Solicitation of Prostitution - Jeffrey E. Epstein
+[pp. A29-A30]
+TELLIN
+A TRUE BILL
+IN THE NAME OF AND BY THE AUTHORITY OF THE STATE OF FLORIDA
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
+CIRGUIT OF THE STATE OF FLORIDA
+For Palm Beach County, at the Spring Term thereof, in the year of our Lord Two
+Thousand and Six, to-wit: The Grand Jurors of the State of Florida, inquiring in and for
+the body of said County of Palm Beach, upon their oaths do present that JEFFREY E.
+EPSTEIN in the County of Palm Beach aforesaid, in the Circult and State aforesaid,
+COUNT ONE
+FELONY SOLICITATION OF PROSTITUTION
+on or about or between the 1st day of August in the year of our Lord Two Thousand and
+Four and October 31, 2005, did solicit, induce, entice, or procure another to commit
+prostitution lewdness, or assignation, contrary to Florida Statute 796.07(1) on three or
+more occasions between August 01, 2004 and October 31, 2005, contrary to Florida
+Statute 796.07(2)(f) and (4)(c), (3 DEG FEL)(LEVEL 1)
+against the form of the statute, to the evil example of all others, and against the peace
+and dignity of the State of Florida.
+I hereby certify that I have advised the Grand Jury returning this indictment as
+authorized and required by law.
+Post-it* Fax Note
+7671
+F Mr FONDA
+From
+aloshe licate
+coops.
+Co.
+SHO
+Pm 58-45-4/601 5l1- 655-7353
+pax 518-45-41,75* 54)-35
+ssistant State Attorney of th
+teenth Judicial Circuit of th
+of Florida, prosecuting for the said
+State
+
+
+A31
+Information for Procuring Person under 18 for Prostitution - Jeffrey E. Epstein,
+dated June 26, 2008
+IN THB CIRCUIT COURT OF THE FIFTBENTH JUDICIAL CIRCUIT
+• IN AND FOR PALM BEACH COUNTY, STATE OF FLORIDA
+CRIMINAL DIVISION 'W" (LB) 08 CF9381
+ARISES FROM BOOKING NO.:
+
+STATE OF FLORIDA
+VS.
+JEFFREY E EPSTEIN, W/M, 01/20/1953,
+08 JUN 26 PM 3:
+TI
+INFORMATION FOR:
+1)
+• PROCURING PERSON UNDER 18 FOR PROSTITUION
+In the Name and by Authority of the State of Florida:
+BARR YE. KRISCHER, Stato Atomy for the Fienth Judicin Creait, Palm Besch aly, Alorida, by and
+through his undersigned Assistant State Attorney, charges that JEFFREY E EPSTEIN on or about or between
+the 1" day of August in the year of our Lord Two Thousand and Four and October 9, 2005, did knowingly and
+unlawfully procure for prostitution, or caused to be prostituted,
+La person under the age of 18 years,
+contrary to Fiorida Statute 796.03. (2 DEG FEL)
+FL. BAR NO. 0776726
+Assistant State Attorney
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+Appared before me, LANNA BELOHLAVEK Assistant State Attorney for Palm Beach County,
+Florida, personally known to me, who, being first duly sworn, says that the allegations as set forth in the
+foregoing information are based upon facts that have been sworn to as true, and which, if true, would constitute
+the offense therein charged, that this prosecution is instituted in good faith, and certifies that testimony under
+Sworn to and subscribed to before mo thicke
+Tay of June, 2008.
+Damark Pina
+Lanaris pena
+MY COMMES* DO50/98 EXPRES
+NOTARY PUBLIC, State of Florida
+LB/đp
+August 2, 2010
+BOHEAD THE TROT TAN HELLACE, MC
+PCIC REFERENCE NUMBERS:
+1) FELONY SOLICITATION OF PROSTITUTION 3699
+
+
+A33
+84/26/2010 14:51
+Judgment for Procuring Person under 18 CORT CRIMINAL dated June 30, 2008.
+PAGE B6/20
+THE CRIMINAI. DIVISION OF THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT OF FIORIDA.
+IN AND FOR PALM BEACH COUNTY
+38 IF 4581-AMB
+OBTS NUMED 80F 938/AX
+STATE OF FLORIDA
+11
+COMMUNITY
+CONTROI
+VIOLATOR
+PROBATION
+VIOLATOR
+HAVEN SHIMMERHIS
+CFN 20080267252
+OR BK 22760 PG Ø565
+RECORDED 07/17/2008 @6:06:42
+Palm Beach County, Florida
+Sharon R. Bock, CLERK & COMPTROLLER
+Pg 6565; (1pg)
+Jettrey E. Ensteir
+DEFENDANT
+1 20 53
+DATE OF BIRTH
+M
+GENDER
+SOCALSELOR
+NUMBER
+JUDGMENT
+he ahove Defendant, being personally before this Court represented by
+Having been tried and found guilty of
+¡he following crime(s):
+J. Goldberger
+Having entered a plea of guilty fo
+the following crime(s):
+(attorney)
+Having enicred a plen of nolo
+contendere to the following
+crime(s):
+COUNT
+Procurigg Person Under
+for prosttutia.
+OFFENSE STATUTE NUMBER(S)
+DEGREE
+796.03
+2°F
+'X
+and no cause having been shown why the Defendant should not bo adjudicared guilty, IT IS ORDERED THAT the Defendant is herchy
+ADJUDICATED GUILTY of the ahove crime(s)..
+and having been conticicd or found guilty of. or having enlered a pica of nolo contendere ar guilty regardless nf adjudicaion, to alempts or
+offenses relating lo sexual battery (ch. 794), letd and lascivious conduct (ch. 300). of murder (s. 782.01), aggravated hatery (s. 784.045).
+burglary (s. 810.021, carjacking (s. 812.133). or home invasion robery (s. 613.135). or any mher offense spécified in tection 93.335, the
+defendant shall he required in submit blond specimens.
+SENTENCE
+STAYED
+and goral ause heing shawn: IT IS ORDERED THAT ADJUDICATION OF GUILT BE WITHHELPUN 3 0 2000
+I 1 The Cours herchy stays and withholds imposition of sentence as to coums) and plates the Defendant en
+() Probation ander | 1 Community Control under the supervision of the Dept, of Concurions condilions of probatinn
+set forth in separate order).
+SENTENCE
+DEFERRED
+¡ 1 The Court hereby defers imposition of sentence until _
+• The Defendane in Open Curt was advised of his right to appeal from the Judgment hy filing notice of appeal with the Clerk of Court within thirty days
+following the dare sentence is imposed or probation is ordered pursuant to this adjudication. The defendant was also advised of his righs to the assistance
+of counsel in taking said appeal at the expense of the State upon showing of indigency:
+DONE AND ORDERED in Open Court-at Palm Begch County, Florida. this
+3D ay nJune 300.
+Wehul Dole here
+CIRCUIT COURT MINCE
+
+
+A35
+Community Control Standard Conditions, dated June 30, 2008
+Ipp. A35-A46]
+PAGE 89/20
+04/26/2010
+
+FURTHER ORUERED THAT YOU SHALL COMPLY WITH THE FOLLOWING GONDITIONS OF SUPERVISION:
+1.
+COMMUNITY CONTROL S
+HONDARD CONDITIONS:
+You will remain confined to your residence except one balf hour before and after your approved employment,
+comtunity service work, or any other activities approved by your probation officer.
+You will maintain an bourly accounting of all your activities on a daily log which you will submit to your supervising
+officer upon request
+(c)
+The Department of Corrections, may at its discretion, places you on Blectronic Monitoring during the term of your
+Community Control. If placed, on Electronic Monitoring, you will wear & monitor at all times. You will maintain a -
+private phone line, bo financially responsible for any lost or damaged equipment and follow all rules and rogulations as
+instructed. Tho telepbone will be available within five working days of boing placed on Blectzonic Monitoring Program.
+While on electronie monitoring you will remain confined to your residence and are probibited from being outside the
+residential walls.
+(d)
+If while being monitored and the monitor is found to have been tampered with you shall be taken into custody
+immedistely, if the officer determines that your were not at your schedules place of work or school while allowed to be
+outside the resideoce tben in that event you shall be taken info custody immediately. If taken into custody, you shall be
+held without bond and shall, on the next working day, brought before a Judge presiding over his or her case for further
+disposition at the diacretion of the presiding indes.
+(e)
+If placed on Electronic Monitoring you will pay to the Stale of Florida, for the cost of Electronic Monitoring $1.00 per
+day, per F.S.948.09,
+Defendant will be residing. at 358 El Brillo Way,
+• Beach
+Flórida
+II.
+DRUG RENDER PROBARON STANDARD CONDITIONS
+- 33480
+(e) You will submit to and, unless otherwise waived, be financially responsible for drug testing, urinalysis at least on a
+monthly basis, and counseling if deeried appropriate by your supervising officer.
+(6) You will epter and successfully complete a hon-sosure or inpatient drug treatuent program if deemed appropriate by
+your offcer.
+(c) You will comply with any curfew restrictions, confinement approved residence or travel restrictions as instructed by
+your officer and approved by the Officer's Supervisor.
+•SEX OFFENAER 6T
+DARD CONDITIONS!
+you sball submit to a mandatory curfew from 10:00 PM to 6:00 AM
+(if the victum wes under the ago of 18 years) you shall not live within 1000 fect of a chool, day care center, park,
+playground, or other place where children regularly congregate.
+(c) you shall enter, setively participate in, and successfully complete e'sex offender treatment program with a therapist
+particularly trained to treat sex offender, at probationer's or community controlees experso.
+you shall not.have any contact with the victiin directly or indiroctly, including through a third person, unless approved
+by the victim, the tberapist and sentencing court.
+(if the victim was under the ago of 18 years) you shall not, until you successfully attend end complete the sex offender
+program, have any ubsupervised contact with a child under de age of 18 yents, arless authorized by the sentencing
+court, without an adult present who is responsible for the child's welfare and which adult bas been advised of the crime
+and is approved by the scatencing court
+if the victim was undor the age of 18 years) you shall not wolk for pay or as a volubleer in any school, day cire center.
+fark, playground, or other place where children regularly congregate.
+nice ethorir. Indicatin the name or spidest by the exual attender tamon progret, you shall yot wiew,
+Jown, or posses any obscens, pornographic or sexually stimulating visual or auditory material, including telephone.
+electronic media, computei programs or computer services that are relevant to your deviant bebavior pattern.
+You shall subtit two specimens of blood to the Florida Department of Law Buforcement to be registered wich the DNA
+Date Bank.
+'(i) You sball minke restiracion to the victim as ordered by this court pursuant to P.S. 775.089 for all necessary medical and
+related professional services relating to the physical, psycbiatrio and psycbological care of the victim.
+rosidenco, or yehicle.
+You sball submit to a warmless search by your probation officer or community control officer of your Eat d/
+9 Defendant to have contact with his abastar
+oficer at a minimum one time a weak. So
+6 Detendant to work @ Florida Science Foundation,
+1sn Australian Ame...
+
+
+A37
+
+PAGE 11/20
+948.101 Terms and conditions of community contral and arminal quarantine community
+control.-
+(1) The court shall determin the terms and conditions of community contral. Conditions
+specified in this subsaction do not require oral pronouncemant at the timo of sentencing and
+may ba corsidered standard conditions of community cantrol.
+(a) The court shall roquiro Intorva supervision and surveillance for an offondor placed into
+community cantrol, which may include but is not limicad to:
+1. Specified contact with the parole and probation officer.
+2. Confinomont to an apresd-upon rasdonce during hours away from employmont and publte
+sarvico activitios.
+3. Mandatory pubile sorvico.
+4. Supervision by the Departmart of Corructions by moans of an electronic monitoring device
+or System.
+5. The standard conditions of probation set forth in s. 948.03.
+(b] For an offonder placed on criminal quarantine community control, the court shell requiro:
+1. Bloctronic monitoring 24 hours per day.
+2. Confinemone to a designated rusdance during desigrated hours.
+(2) The onimuration of specific kinds of torms and conditions does not prevent the court from
+adding thorato any other torms or conditions that the court considers proper. However, the
+santancing court may only Impose a condition of supervision allowing an affonder corvicted of
+= 794.011, I. 800.01, s. 827.071, or s. 847.0145 to reside in anothar state if the ordor
+stipulatos thet it is contingont upon the approvel of the roceiving senta intorstato compact
+authority. The court may rescind of modify at any time the terms and conditions theratofore
+Imposed by it upon the offondor in community control. Homonor, If the court withholds
+adjudication of guilt or imposes a perlod of incencaration ms a condition of community control,
+the perlod may not excued 361 days, and incarceration shall be restricted to a county facility,
+a probation and restitution conter under the jurisdiction of the Departmont of Corrections, a
+probation program drut punishment phaso 1 securo residertial treatmant institution, or a
+community rendertiel facility owned of operated by any antity providing such services.
+(3) The court may place dofondant who is bring sentenced for criminal transmission of HIV in
+violation of s. 775.0077 on criminal quarantine community control. The Departmont of
+Corrections shall dovelop and administer a criminal quarantino community control program
+amphadzing intersiva supervision with 24-hour per-day electronic monitoring. Criminal
+quarantine community control status must include survelliance and may Include othor monsures
+normally assocated with community control, oxcopt that specific conditions nocessary to
+monitor this population may be ordered.
+
+
+A39
+04/26/2010
+
+PAGE 13/20
+(V) Saction 800.04(5)(d) where the court finds the use of forco or coorcion and unclothod
+gorritals.
+2. For
+qualifying offonses listed in sub-subparagraph (1)(m)1.d., the court shall make =
+writton Anding of the age of the offendor at the time of the offortse.
+For bach violation of a qualifying offonse listad in this subsoction, the court shall make a
+writton finding of the ago of the victim at the time of the offensa. For a violation of s.
+800.01(1), the court shal! additionally mako a writton finding indicating that tha offense did or
+did not Involve sexual activity and indicating that the offense did or did not involve force or
+coercion. For a violation of s. B00.04(5), tha court shall additionally make a written finding
+hat the offonsa did or did not involve unclothed gantals or gorital arge and that the offor
+Id or did not Involvo the use of forca coorcion
+(b) "Convictod moan that thare has boan a detormination of guilt as a result of a trial or Uner
+untry of a ploe of guilty or nolo contendere, rogardless of whether adjudication is withheld,
+and includes an adjudication of delinquency of a juvenile as specified in this section.
+Conviction of a similar offarea Includes, but Is not limitad to, a conction by a fodoral or
+military tribured, Including courts-martial conducted by the Armed Forces of the Unitad Statos,
+and includes a conviction or antry of a ples of guilty or nola contendare resulting in a sanction
+In any state of the Unitod States or other jurlsdiction. A sanction Includes, but is not I'mited
+to, a fino, probation, communty control, parola, conditional reluase, control rolease, or
+Incancoration in a state prison, fodoral prison, private correctional facility, or local datontion
+facility.
+(c) "Permanent residence" and "temporary residunce" have tha same meaning ascribed in s.
+725.21.
+(d) "Institution of highor aducation" means a carer contor, community collago, collage, stato
+university, or induponcert postsacondary institution.
+(0) "Chango in enrolimont or omployment status mears the commencument or termination of
+amullmet or omploymert or a change in location of onrallment or employment
+(1) "Electronic mall addross" furs the same mearny as provided in s. 068.602.
+(a) "Intant massage name" monrs an identifior that allows a person to communicate in real
+dina with anuthor parson using the internet.
+(2) A sexual offandor shall:
+(a) Roport In parson at the shoriff's office:
+1. In the courty in which the offundor ostablishes or maintains a pormanent or tomporary
+residonce within 49 hours after:
+a. Establishing permanant or comporary residonco in chis state; I
+b. Being rolosed from the custody, control, or supervision of the Orpartment of Corrections
+or from the custody of a private correctionni facility; of
+2. In the county where ho or the was convicted within 48 hours aftor boing convictod for o
+qualifying offonse for registration under this soction if the offondor is not in the custody or
+
+
+A41
+84/26/2010
+
+PAGE 15/20
+(b) Pay the costs ossassed by the Department of Higtway Safety and Motor Vehicles for issuing
+or renowing a driver's licarso or identification card as required by this section. The drivar's
+Icanse or idontification card fssued must bo in compliance with s. 322. 141(3).
+(c) Provide, upon roquest, any additional Information nacessary to confirm the identity of the
+saxual affancer, incluting a sot of fingerprints.
+(4)(a) Each timo a sexual offendor's driver's license or identification card is subject to ronowal,
+and, without regard to the status of the offender's driver's license or Identification card, within
+48 hours afler any change in the offendor's permanent or temporary residence or change in the
+offunder's name by reason of marriaga or othar logal process, the offonder shall roport in
+person to a driver's (case office, and shall be subjact to the requirements specified in
+subsaction (31. The Departmont of Highway Safoty and Motor Voticlos shall forward to the
+photographs and Information provided by saxuel offenders. Notwithstanding the
+restrictions set forth in x. 322.142, the Department of Miahway Safety and Motor Yohicles is
+authorized to reloase a roproduction of a color photograph or digitsi-imago Ifconse to tho
+Department of Law Enforcoment for purposes of public notification of saxual offenders as
+provided in this saction and is. 943.043 and 944.606.
+(b) A saxual offendor who vacates a permanunt residence and falls to establish or maintain
+anothor permanent or temporary residence shall, within 45 hours aftar vacating the permanent
+roddanca, report in person to the shariffs office of the county in which he or she is locatad.
+The sexual offendet shall specify the date upon which he or the intends to or did vacate such
+of the registration information
+requirad unstor paragraph (2)(b). The saxual offondor must provide an address for the residence
+or athar (oention that he or sho is or will be occupying during the time in which ho or she fails
+to establish or meintein e permanent or temporary residonce.
+(c) A sexual offender who romains at a permanant residence aftor reporting his or her intent
+to vacate such residence shall, within 18 hours after the date upon which the offander
+Incicated he or she would or did vacate such residence, roport In persan in the agency to which
+ho or she reported pursuant to paragraph (b) for the purpose of reporting his or her address at
+such residance. Whon the shoriff rocatves the roport, the shoriff shall promptly convey the
+infotmation to the dapartmont. An offender who makes a roport as required under paragraph
+(b) but falls to make a roport as recured uncer this pargraph commits a folony of the second
+daçroa, prarishablo as provtad in s. 775.061, s. 775.063, or s. 775.084.
+(d) A sexual offander must register ary oluctronic mail address of Instant messaga name with
+the departmont prior to using such aloctronic mail address or Instant message nama on or aftor
+Octobor 1, 2007. The dopartmant shall establish an online systom through which sexual
+offordors may securely accoss and update doctronic mall address and instant massaga
+name information.
+15) This section does not apply to a sexual offonder who is also a sexual prodator, as definod in
+s. I25.21. A sexua protator mint rapister 89 required undor s. 775.21.
+(6) County and local law enforcomont aponclos, in conjunction with the departmont, shall
+verify che addresses uf saxual offunders who are not under the caro, custody, control, or
+supervision of the Dapartmont of Corrections in a mannar that is concistent with the provisions
+of the Faderal Adam Waish Child Protection and Safety Act of 2006 and arry other fodoral
+standards applicable to such verification or requirad to be mot as a condition for the rocript of
+federal funds by the stata. Local law enforcomont agoncies shall report to the departmont orry
+failure by a sexual affendor to comply with registration requiremonts.
+
+
+A43
+04/26/2010 14:51
+
+PAGE 17/20
+Justice, the porsonnal of those departments, or any Individual or entity acting at the request
+or upon the direction of any of those departments in compiling or providing information, or if
+Information is Incomplete or incorract bocause a saxual affenter fails to roport or falsely
+roports fils or har currart place of permanent tamporary residence.
+(11) Excopt as provided ins. 943.04354, a saxual offunder must maintain rogistration with the
+dupartmont for the duration of his or her lifo, unless the saxusl offendor has rocolved a full
+pardon or hes had a conviction set aside in a postcorviction proceading for arty offerse that
+meets the criteria for classifying the porson as a sexital offorder for purposes of rogistration.
+Homevor, a saxual offarcar:
+(m)1. Who has been lawfully reloased from confinement, supervision, or sanction, whicherr is
+Inter, for at lose 25 yoers and hus not boar arrested far any felory or misdomoanor offerso
+since reloass, provided that the sarual offondor's requirement to rogister was not based upon
+an adult conviction:
+8. For a violation of x. 787.01 or s 787.02;
+b. For a violations of s. 794.011, asclueling s. 794.011(10);
+c. for a violation of s. 800.04(4)(b) whore the court finds the offerse Involved a victim under
+12 yours of ayte or sexual actlvity by tha use of force of coarcion;
+d. For a violation of s, 800.01(5) (b);
+o. For a violation of s. 800. 04(5)c.2. whare the court finds tha affonse involvod unclothed
+germitals or gorital area;
+f. For arty attompt of corspiracy to commit arry such offursa; or
+y. Por a vlolation of similar law of anothor Jurisdiction,
+mary pettion the crimined divison of the crault court of the circult in which the saxial
+offendor reudes for the purpose of removing tha requiroment for registration as a sexuni
+offender.
+2. The court may grant or derry rollat if the offonder demonstrates to the court that he or she
+has not been arrested for any crime since rolonsa; the roquested relief complies with the
+provisions of the fadoral Adam Walsh Child Protaction and Safaty Act of 2006 and arry other
+fadoral stanlands applicable to the removal of rogistration roguirements for a soxual offender
+or required to be met as a condition for the receipe of federal funds by the state; and the court
+is othorwise satisfied that tha affondor is not a current or potontial thrant to pubife safoty. Tho
+state attorney in the circuit in which the patition is filed must be given notice of the petition
+at least 3 wooks bafore the hoaring on the mattor, Tha state attornoy may prasant avidence in
+opposition to the roquested rallof or may othorwise demonstrate the rossoms wiry the patition
+should be darled, If the court dontes the petiton, the court may sat a future date at which the
+saxual offondar may again petition the court for relief, subjact to the standards for rollof
+provided in this subsaction.
+3. The dopertment shall remave an offonder from clasdfication as a sexual offondor for
+purposas of registration If the offandor providas to the dapartment a cortifiod copy of the
+court's written findings or order that indicates that the offendor is no langer required to
+comply with the roquirements for rogistration as a saxual offendor.
+
+
+
+A45
+PAGE 19/20
+1. Saction 794.011, oxcluding s. 794.011(10);
+3. Sectfon 800.04(4)(b) whore the court Finds the offonse invalved a victim under 12 years of
+age or sexuel activity by the use of force or coercion;
+4. Saction 800,04(5) (b);
+5. Saction B00.04(5)(c)1. wharo the court finds molestation imolving unclothod garitals or
+gorrital aran;
+t. Saction 800.04(5)c.Z. whore the court finds molestation involving inclathed gonitals or
+7. Section 800,04(5K(d) where the court finds the use of force or coarcion and unclothed
+paritals or purrital ares;
+8. Ary attompt of consprecy to commit such offense; or
+9. A violatiot of = similar low of another jurisdiction,
+must ruregister euch your durfng the month of the sexuel offender's birthday and ovary third
+morth thereafter.
+(c) The shoriffs office may detormine the appropriate times and days for roporting by the
+saxual effortor, which shall be comistent with the roporting roquirements of this subsection.
+Rarogistration shall include any changes to the following information:
+1. Name; social socurity numbor; ago; race; sax; date of birth; height; weight; hair and oys
+color, address of any permanent residence and address of any current tomporary residonce,
+within the state or out of state, Including a rural route address and a post office bax; arry
+- doctronic mail address and arry instant message namo required to be provided pursuant to
+paragraph (4)(d); date and place of arry amployment; vahicle make, model, color, and licuse
+tag numbor; Angorprints; and photograph. A post office bax shall not be pravidod in liou of a
+physical residential address.
+2. If the saxual offonder is anrolled, umployed, or carrying on a vacation at an institution of
+Mator education in this state, the saxual offonder shall also provide to tha department tha
+name, address, and county of such institution, Including each campus attended, and the sexual
+afforder's enrollmont or amploymant status.
+3. It the saxual offender's place of reddenca is a motor vehicle, trailor, mobile homo, or
+manufactured homo, es defined in chapter 320, the sexual offender shall also provide the
+vaticle (dontification number; the liconso tag number; the rogistration number; and a
+description, Including color schame, of the motor vehicle, trafler, mobile homo, or
+manufactured home. If the saxual offondor's place of residenco is a vassal, lfvo-abond vosser,
+or forsationt, is defined in chapter 327, the saxual offonder shall also provide the hufl
+identification number; the manufacturer's serial numbar; the namo of the vassol, live-aboard
+vassol, or houseboat; the registration numbor; and a description, Including color schema, of
+the vassal, liva-aboard versal or houseboat.
+4. Any saxual offondor who fails to roport in parson as roquired at the shariff's office, or whe
+falls to respond to any addross vorífication corrospondence from the department within 3
+weas of the date of the correspondance or who fails to roport alectronic mail addressas or
+
+
+A47
+Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein, dated June 30, 2008
+
+NAME:
+EPSTEIN, JEFFREY
+JACKET#: 0338617
+ALIASNAMES:
+OVER B NAMES: L
+EPSTE: JEFFREY - EPSTEIN, JEFFREY EDWARD-
+Monday, June 3D, 2008
+PALM BEACH SHERIFFS OFFICE
+11:33:10 AM
+BOOKING CARD
+INCARCERATION DATE/TIME 06/30/2008 11:12
+BKG.LOC:
+MOBILE BOOKING
+PRISONER TYPE: LOCAL CHARGES
+BKG. ID#: 8548
+DOB: 01/20/1953
+RAS:
+W/M
+HEIGHT: 6 110 in
+WEIGHT: 200
+HAIR COLOR: GRY
+EYE COLOR: BLU
+PAGE
+04/20
+#. 2008039316
+ADDRESS: 258 EL BRILLO WY
+10#:
+SID #:
+ALIEN#.
+FBI #: 787075K6
+CITY: PALM BEACH
+ROUGH TOO!
+AFIS:
+U.S. MARSHALF.
+OBTS #:
+STATE: FL ZIP: 334B0
+NCIC:
+DOC N
+INCIDENT #:
+CITIZEN
+COUNTRY: USA
+ARREST ADDRESS:205 N DIXIE HWY (MAIN CT HOUSE)
+CITY: WPB
+ARREST DATE:
+06/30/2008
+ARREST TIME: 10:15
+BKG, DATE:
+06/30/200฿
+BKG. TIME:
+11:12
+WARRANTICASEN:
+COURT GIVISION:
+ARREST OFFICER: D/S DELPLATO
+ARREST AGENCY: 01 - PBSO
+TRANS, OFFICER: DYS MCINTOSH
+TRANS, AGENCY: D1 - PBSO
+STATE: FL
+ZIP:
+CURRENT BOND:
+$0.00
+CASE TYPE: RECOMMIT-FELONY
+NOTE:
+STATUTE:
+9999.0004 (NN)
+CT:
+DESCRIPTION:
+-RE-GOMMIT
+CASE FLAG: NO BOND
+PROCURE PERSON UNDER AGE OF 18 FOR PROSTITUTION // CASE: 2008CF009361AXCX.W
+32 ₴
+VOFEE YEE: CUR BONO
+58.00
+30,00
+HOLDS:
+HOLD DATE/TIME:
+HOLD BY:
+HOLD DEPT:
+HOLD REM.DATE/TIME: HOLD REM. BY:
+HOLD REM, DEPT:
+ALERT DESCRIPTION;
+ALERT NARRATIVE:
+DNA NOT ON FILE/FELONY CONVICTION
+SVER J ALERTS;
+KEEP SEPARATE FROM:
+NONE
+WER 6 NAMES:
+ASSIGNED HOUSING:
+ICIC INTAKE:
+'ALMS REL:
+IED. CLEAR REL:
+ELEASE DATETIME:
+OURT DATE/TIME:
+CLERK 3
+NTA DATE/TIME:
+NCIC RELEASE:
+F.P. ENTERED:
+PHOTO ID:
+CLASSIFICATION:
+RELEASE MOVE:
+RELEASE INFORMATION:
+COURT LOCATION:
+WARRANTS L!
+STAtE ATTY i!
+NTA LOC:
+F.P. CLEAR:
+MEDCLEARIN: DE JUL: 1 2008
+CENTRALACDS !!
+CLASS | i
+
+
+A49
+Letter from Florida Department of Corrections Regarding Termination of Supervision,
+dated July 21, 2010
+FLORIDA
+DEPARTMENT of
+CORRECTIONS
+SATE OTTONS
+An Equal Oppartuniy Emiplayer
+2601 Bleir Stone Rond Tallahessec, FL 32399-2500
+Date: 121/2010
+FILED
+2070.902211AM1D::29
+RE:
+Jovemor
+CHARLIE CRIS
+SANES R. MEDONOUGH.
+http://www.dc.state.fl.us
+TERMINATION OF SUPERVISION
+DC# W15755
+DOCKET/UC NO(S) 502008CF009381AXXX
+Mr. Epstein
+358 B Brillio Way
+Palm Beach, EL 33480
+Dear Mr. Epstein
+You are hereby notified that you häve completed your term(s) of supervision, as referenced above, and are no
+longer under the supervision of the Department of Corrections.
+If you were adjudicated guilty of a felony offense, your name will be submitted to the Florida Parole Commission
+for consideration for restoration of the civil rights that you lost as a result of your felony conviction (right to vote,
+right to hold publio office, and the right to serve on a jury). If your rights are restored, a certificate of restoration of
+civil rights will be mailed by the Office of Executive Clemency to your last mailing address of record usually within
+one year following the termination of supervision. If your rights are not restored through this initial referral, you
+will be notified by the Florida Parole Commission and furnished an additional application for submission for
+restoration of civil rights with a hearing. If you have any questions about your civil rights, you may contact the
+Office of Executive Clemency for further information by calling (850) 488-2952 or by writing to that office at
+Florida Parole Commission, 2601 Blair Stone Road, Building C, Tallahasses, Floride 32399-2450. Information and
+application forms may be accessed through the following web sits: www.state.fl.us/fpc/exclem,html
+After eight (8) years from termination of your supervision, you may apply to rogain your right to own firearms.
+Applications can be obtained from the Office of Executive Clemency or be accessed by the website noted abovo.
+If adjudication was withheld, you did not lose your civil rights, however, the Florida Department of Law
+atend to you bes
+wishes for a very successful future.
+Sincerely,
+Candice Elkins
+If you were on supervision for a sexual offense, attached is a copy of the Notice of Responsibilities, whic
+outlines your continued responsibilities in ecordance with Florida Statutes
+Typine ten, red as cae often, stereone copy of a are it on rature..
+Original: Offender
+Copy:
+Offender File
+Florida Parole Commission (if applicable)
+Clerk of Court (if required)
+(Revised 03/03)
+
+
+A51
+Letter from Jack A. Goldberger to NYS Sex Offender Registry Regarding Florida Registration Level
+applicable to Jeffrey E. Epstein, dated August 12, 2010
+LIpp. A51-A521|
+ATTERBURY GOLDBERGER
+WEISS,
+*JOSEPH R.ATTERBURY
+'JACK A. GOLDBERGER
+"JASON S. WEISS
+Board Certified Criminal Trial Attorne
+Member of New Jersey & Florida Bar
+August 12, 2010
+New York State Division of Criminal Justice Services
+Sex Offender Registry
+4 Tower Place
+Albany, N.Y. 12203
+RE: Jeffrey E. Epstein
+To Whom It May Concern:
+The undersigned represented Jeffrey E. Epstein in the investigation that lead to his entry
+• of a guilty plea on June 30, 2008 to a felony charge in the State of Florida that required
+sex offender registration. The purpose of this letter is to clarify the level of registration that
+was applicable to Mr. Epstein's case
+Under Florida's registration scheme there are two levels of registration available based on
+a risk assessment. Florida characterizes these fwo levels as sexual predator and sexual
+offender. The sexual predator designation is obviously the more serious classification.
+Mr. Epstein, based on the offense on which his guilty plea was entered, was classified as
+a sexual offender, Florida's lowest level of sexual registration. In fact, within the sexual
+offender designation there are two sub-levels of reporting requirements. One classification
+requires reporting to the local Sheriff's Office twice a year and one requires reporting four
+times a year. In Mr. Epstein's case he is required to report at the lowest level, two times
+per year. Accordingly, under the Florida registration scheme, Mr. Epstein's registration
+requirements are at the lowest level for a person for whom registration is required.
+During the incarcerative portion of Mr. Epstein's sentence, he was allowed to participate
+in the Sheriff's Office work release program, an option that would not have been available
+to him had he been at a higher registration level. Additionally, while Mr. Epstein was in
+probationary status, he was allowed to travel on a limited basis for business purposes.
+This would not have been available to him had he been classified as a sexual predator.
+One Clearlake Centre, Suite 1400 250 Australian Avenue South West Palm Beach. FL 33401
+• p 561.659.8300 1 56l.835.869| www.agwpa.com
+
+
+A53
+Letter from Martin G. Weinberg to NYS Board of Examiners of Sex Offenders Regarding
+Risk Level and Designation Determination for Jeffrey Epstein, dated August 16, 2010
+MARTIN G. WEINBERG, P.C.
+ATTORNEY AT LAW
+I PARK PLAZA, SUITE 100
+OSTON, MASSACHUSETTS 0211
+=
+NIGHT EMERGENCY:
+August 16, 2010
+EMAIL. ADDRESSES:
+New York State
+Board of Examiners of Sex Offenders
+4 Tower Place
+Albany, New York 12203-3764
+Re:
+Jetirey Epstein
+NYSID #
+Dear Sir or Madam:
+This letter and the accompanying materials are submitted to the Board pursuant to its notice
+of August 2, 2010, concerning the risk level and designation determination to be made with respect
+to Jeffrey Epstein. Their purpose is to demonstrate to the Board that, based upon Mr. Epstein's
+history and personal characteristics, the circumstances of the offense which triggered the registration
+requirement, his acceptance of responsibility, his successful completion of his sentence and
+subsequent supervision, and the extraordinary unlikelihood of his ever again reoffending, the
+appropriate risk level designation is level 1.
+Overview
+Mr. Epstein, who is presently 58 years old, is a successful and respected financial advisor
+who also founded and heads a philanthropic organization, the C.O.U.Q. Foundation, Inc. which
+funds medical, educational, and advanced scientific research. The offense which led to the
+requirement that he register as a sex offender in Florida, which in turn triggered this state's reporting .
+requirement, ended almost five years ago and involved an exchange of money and consensual
+conduct with a young woman who, for all but a few months of the prostitution offense charged, was
+over the age of 17. Notably, as addressed in greater detail, infra, the conduct which occurred after
+. reached the age of 17 would not even have been a misdemeanor under the cognate New York
+statute at the time the offense was committed.
+Mr. Epstein pled guilty to that offense in the Circuit Court for Palm Beach County, Florida,
+and has fully and sincerely accepted responsibility for his conduct. There have been no subsequent
+incidents of criminal misconduct of any description.
+
+
+A55
+Epstein poses no threat to either himself or the general community, and he requires no
+additional intervention or treatment for his no-risk/low-risk status to be maintained into the
+future.
+Letter of Stephen R. Alexander, Psy. D., submitted herewith as Ex. B.'
+All of these circumstances - Mr. Epstein's low-risk classification in Florida, the state
+where the offense was committed, the low-risk assessment inherent in the decisions of Florida
+authorities responsible for the protection of the community, who knew him first-hand, to admit
+him to work release during his period of incarceration and to permit him to travel outside of
+Florida during his period of community control supervision, Dr.
+well-supported
+judgment that Mr. Epstein presents little or no risk of reoffense, the fact that the offense ended
+almost five years ago, and there has been no subsequent criminal misconduct of any kind, and the
+fact that Mr. Epstein is a mature, responsible, professional adult who uses neither alcohol nor
+drugs all support the conclusion that the supervision which accompanies a level 1 designation
+will more than suffice to serve the purposes of SORA. That conclusion is supported by the
+calculation of Mr. Epstein's risk assessment guidelines score.
+The Conduct Underlying the Offense Triggering the Florida Registration Requirement
+Would For the Most Part Not Even Have Been a Registerable Offense in New York Had
+the Conduct Occurred in New York
+The offense which required Mr. Epstein to register as a sex offender in the state of Florida
+was a violation of Fla. Stat. §796.03, which criminalizes procuring a person under the age of 18 (the
+age of consent in Florida) for prostitution, specifically, here, one "_
+" The nearest New York
+cognate among the registerable offenses listed in N.Y. Correction Law §168-a is N.Y. Penal Law
+§230.04 (patronizing a prostitute). The information to which Mr. Epstein pled guilty charged that
+the offense occurred between August 1, 2004, and October 9, 2005, see Information, Ex. C, that
+latter date being the day before
+I's 18th birthday: Thus, for almost all of the duration of the
+charged offense,
+was over the age of 17, and the wholly consensual conduct in exchange for
+money which occurred between the two would not even have been a registerable offense in New
+York. See §168-a(2)(a)(i)(§230.04 a registerable offense only if"person patronized" is in fact under
+17 years old). Indeed, at the time of the offense at issue, the conduct which occurred after
+turned 17 years of age would not even have been a crime under that statute if the conduct had taken
+place in New York. Mr. Epstein's offense ranks among the least serious of those which trigger the
+requirement of SORA registration. The single Florida offense which required registration involved
+' Dr.
+CV is included in Ex. B.
+2 In 2007, §230.04 was amended to extend its coverage to prostitution offenses involving individuals
+of any age, not just those under the age of 17, as the statute was written when Mr. Epstein's offense
+was committed in 2004-05. Under §230.04 as written in 2004-05, the offense, to the extent that
+was in the last three months of her 16th year, would only have been a misdemeanor had it been
+committed in New York.
+3
+
+
+A57
+substantial time he has spent with Mr. Epstein, Dr. Alexander is able to state unequivocally that Mr.
+Epstein has learned his lesson, that he presents no threat to the community, and that there is
+negligible risk that he will ever reoffend. Accordingly, Mr. Epstein should be scored at zero for the
+Post-Offense Behavior factors (factors 12-13).
+Release Environment
+Factor 14 contemplates that the risk level assessment will be made, as required under New
+York law, prior to the offender's release from incarceration. Here, as the preceding section shows,
+Mr. Epstein was released from jail more than a year ago and was subject to close supervision for a
+period of one year afterwards. During the same time, he continued to meet with Dr. Alexander. The
+score for factor 14 should, accordingly, be zero.
+Mr. Epstein maintains a vacation residence in Manhattan, which he owns, as well as
+residences in Florida and the Virgin Islands. Mr. Epstein's interactions in connection with both his
+employment and philanthropic work are with adult business professionals, scientists, and educators.
+There is nothing in either Mr. Epstein's living or employment situations which could even remotely
+be considered "inappropriate." The score on factor 15 too should be zero.
+Overrides
+None of the listed factors are of any relevance or applicability to Mr. Epstein's risk level
+designation.
+Conclusion
+Based on all the relevant factors, Mr. Epstein should be classified as a level 1 sex offender.
+Even should the Board somehow conclude that Mr. Epstein's risk assessment guidelines score
+exceeds 70, the circumstances addressed in this letter differentiate this case so markedly from the
+norm of level 2 sex offenders that the Board should recommend a level 1 classification, as it is
+empowered to do under the Sex Offender Guidelines. The ultimate issue is the risk that the offender
+will reoffend, and the information provided to the Board with this letter persuasively demonstrates
+that such a risk is virtually nonexistent in this case.
+y truly your
+Kahn Keek
+Weinberg 4.
+5
+
+
+
+
+
+
+
+
+
+
+A67
+Letter from Supreme Court attaching Notification, Recommendation and Notice of Right to Appeal,
+dated August 26, 2010
+Supreme Gourt
+State of Net ach
+TO:
+PART 66
+FROM: CORRESPONDENCE UNIT
+SUBJECT: SEX OFFENDER RISK ASSESSMENT
+RE: Jeffrey Epstein
+SCID. #
+Please refer to the attached:
+1) Notification to sex offender, defense attorney and D.A.'s office of the
+scheduled risk assessment;
+2.) Recommendation from Board of Examiners
+3.) Notice of Right to Appeal and Appeal Application.
+Please be advised that the above named defendant. his assigned counsel, Sex Crimes Unit of the D.A.'s
+office, City and State Correctional Facilities have been notified of the sex offender risk level assessment
+hearing which has been scheduled in your part.
+Upon completion of the risk assessment, you must endorse the calendar and worksheet and forward the
+COURT FILE AND ASSESSMENT DOCUMENTS to this office.
+BE FURTHER ADVISED_THAT THE DIVISION OF PAROLE MAY HOLD THE
+DEFENDANT UNTIL A RISK LEVEL HAS BEEN ASSIGNED.
+A REQUEST FOR 18B ASSIGNMENT HAS BEEN MADE. ONCE YOU
+ARE NOTIFIED THAT ANATTORNEY HAS BEEN ASSIGNED PLEASE
+SEND THE ATTACHED NOTIFICATION LETTER AND BOARD OF
+EXAMINER'S PACKAGE TO HIM/HER
+
+
+A69
+Order Sheet for Jeffrey Epstein, dated August 26, 2010
+Ipp. A69-A70]
+ORDER SHEET
+Date August 26.2010
+Part
+Correspondence Unit
+Court
+County
+Supreme Court. Criminal Term
+New York
+The People of the State of New York.
+VS.
+Jeffrey lipstein
+Defendane
+Highest Charge (Penal law)
+I lomicide
+Feions
+Dricker Ind.#
+Violates
+Special Procceding
+Sex Offender Hearing
+Being satisfied after a review of the fancial status of the defendant named, that he is financially unable de chain
+cransel, and upon his request for the appointment of counsel, it is,
+Ordered that the following memher of the Bar be and hereby is appointed to represent such defendan in all
+matters pertaining to this action:
+. Idjourned Date
+Sept. 15. 2010
+Valjourned Parr
+Ruth Pickholz.
+Paroled
+Bailed
+9 as 71" Street, New York, N.V.
+66
+Defendant's Status:
+Defendant's Veldress:
+Comment:
+Prior Morny:
+Clerk's Name:
+Incarcerared
+52
+Mary A. Price, CCS
+Telephone #
+646-386-3860
+:
+
+
+A71
+Letter from Supreme Court to Counsel Informing of SORA Level Determination Hearing
+(with attachments), dated August 26, 2010
+[pp. A71-A76]
+- "
+-
+Виргете Onurt
+of the
+State of Nein Work
+August 26.2010
+Defense Atlorney
+18B To Be Assigned
+Ms. Inn-Young Park
+NYC District Attorneys Office
+1 Hogan Place. Room 831
+New York. N.Y. 10013
+Re: Jeffrey Epstein
+SCID #
+Dear Sir/Madam:
+The above named defendant is scheduled for a Sex Offender Risk Level Determination helore the Hon.
+Ruth Pickholz in part 66 on September 15, 2010 at 9:30 a.m. The defendant has been notified under
+separate cover of this hearing and forwarded a copy of' the Board of Examiners recommendation.
+advised of his/her right to appear, advised of the name and address of the attorney assigned to
+represent him or that one is being assigned. risk level guidelines. and of his right to waive his
+appearance.
+Enclosed please find a copy of the Brard of lixaminers recommendation.
+..
+Very truly yours.
+Mary A. Price. CC'S
+Supreme Court - Criminal Term
+New York County
+enc.
+
+
+1. (Cont'd)
+urrent Previous Allempi
+- —
+Current Previous Attempt
+230.04 - Patronizing a prostitute 3rd degrec (victim <|7 years old)
+230.05 - Patronizing a prostitute 2nd degree
+230.06 - Patronizing a prostitute 1st degree
+230.30 (2) - Promoting prostitution 2nd degrec
+230.32 - Promoting prostitution 1st degree
+235.22 - Disseminating indecent material to minors 1st degree
+conse of for comic or are pite as to centime sere i sira
+485.05 of the penal law or as a crime of terrorism defined in section 490.25
+of such law:
+130.52 - Forcible touching (victim<18 years old)
+130.55 - Sexual abuse 3rd degree (victim<18 years old)
+Conviction/Attempt to commit any provision of 130.52 or 130.55 of the
+penal law regardless of age of victim and the offender has previously been
+convicted of: (i) a sex offense listed in Correction Law Section 168-a (2), or
+(il) a sexually violent offense listed in Correction Law Section 168-a (3), or
+(illy any of the provisions of section 130.52 or 130.55 of the penal law or an
+attempt thereof.
+A conviction of (i) an offense in any other jurisdiction which includes all of the
+essential elements of any such crime provided for in Correction Law Section
+168-a (2) (a), or (ii) a felony in any other jurisdiction for which the offender is
+required to register as a sex offender in the jurisdiction in which the conviction
+occurred, or (iii) any of the provisions of 18 U.S.C. 2251, 18 U.S.C. 2251A, 18
+U.S.C. 2252, 18 U.S.C. 2252A, or 18 U.S.C. 2260 provided the elements of
+such crime of conviction are substantially the same as those which are part of
+such offense as of March 11, 2002.
+130.35 - Rape Is degree
+130.50 - Sodomy 1st degree/Criminal Sexual Act Isi degree
+130. 65 - Sexual Abuse Ist degree
+130.66 - Aggravated sexual abuse 3rd degre
+130.67- Aggravated sexual abuse 2nd degree
+130.70 - Aggravated sexual abuse 1st degree
+130.75 - Course of sexual conduct against a child Ist degree
+130.80 - Course of sexual conduct against a child 2nd degree
+130.53 - Persistent sexual abuse
+130.65-a - Aggrav zied sexual abuse 4th degree
+130.90 - Facilitating a sex offense with a controlled substance
+a conviction of or a conviction for an attempt to commit any
+provisions of a sexually violent offense as set forth in Correction
+Lăw Section 168-a (3) committed or attempted as a hate crime
+defined in section 485.05 of the penal law or as a crime of
+terrorism defined in section 490.25 of such law:
+a conviction of an offense in any other jurisdiction which includes
+all of the essential elements of any such felony provided for
+above or conviction of a felony in any other jurisdiction for which
+the offender is required to register as a sex offender in the
+jurisdiction which the conviction occurred.
+250.50 - Unlawful surveillance Ist degree
+Sexual Predator - a sex offender who has been convicted of a sexually violent offense defined in Correction Law Section 168-a (3) and who suffers from a mental abnormality or
+personality disorder that makes him or her likely to engage in predatory sexually violent offenses.
+None of the above.
+FTA00181273
+
+A75
+RE:
+DATE:
+JEFFREY E EPSTEIN
+NYSID #: OS1909
+8/23/2010
+CASE SUMMARY
+This assessment is based upon a review of the inmate's file which may include but is not limited to the
+pre-sentence investigation. prior criminal history and post-offense behavior.
+Jeffrey Epstein is a 57-ycar-old sex offender who pled guilty in the state of Florida on 6/30/2008 to two felony
+senterted es. Paring in Perfollower by 13 moshi of Cand uniy Solicitation of Prosition. He was
+Il would appear he was convicted in London England of Unlawful Possession of an Offensive Weapon, a Sword
+Stick, and was sentenced to a Conditional Discharge on 1/4/1973.
+Regarding the instant offense, Epstein was approximately 51 years of'age on or about the year 2005 when he
+sexually assaulted numerous females between the approximate ages of 14 and 17. Most of the victims were
+recruited by one of Epstein's female employees from a local high school in the Palm Beach Florida area. Some of
+the female participants were age 18 or older. The contact included
+The available police reports from the Palm Beach Police Department include conversations
+with numerous female victims who in most cases, did not know Epstein when they were victimized. Most of the
+females were embarrassed to speak with police regarding what had happened to them while they were at Epstein's
+home. Swor statements were taken from at least five victims and seventeen witnesses concerning massages and
+unlawful sexual activity that took place at the residence of Jeffiey Epstein. Most of the victims were paid at least
+$200.00 each time they performed a massage.
+The victims were told they would be giving Epstein a massage and they were escorted to his bedroom. Most
+victims noted numerous pictures of naked young females, (some of the photos depicted females who would be
+eventually interviewed by police), on display throughout the home. The offender would enter the room only
+wearing a lowel. In most cases he would remove the towel and ask the victim to remove her clothing. In some
+cases he would masturbate into a towel while receiving a massage. In other cases he would touch
+of the victim with his hands or
+One 14 year old described how Epstein touched her
+and thereafter. when contacted by law enforcement, she had to identify the offender
+through the use of'a photo array. Another 16-year-old victim described giving Epstein massages for two years
+and at times, he
+and caressed her butt cheeks as she gave him a massage. Another
+16-year-old described going to the offender's home at least 100 times. He would touch
+insert his
+fingers into her vagina and sometimes
+on her while masturbating. He would also pay this
+underage victim
+female friend while he watched. Occasionally, he would join both girls and
+This
+- car-old victim described for police how one time, Epstein turned her over on
+the massage lable and
+his actions.
+When she screamed, "NO," he stopped and subsequently apologized for
+* The offenders conduct while on Community Control will be considered satisfactory and he does not have a
+history of subslance abuse. Based upon his plea of guilty. Epstein will be credited with accepting responsibility
+. - for his actions. He will be scored for sexual and deviate sexual intercourse, forcible compulsion, numerous
+victims and their ages. a continued course of sexual misconduct. a prior misdemeanor conviction in England
+absent specific information. for his stranger relationship to most victims and for establishing a relationship with
+these underage girls for the purpose of victimization.
+The Board acknowledges correspondence reccived from the offender's attorney.
+
+
+A77
+Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing,
+09/07/2010 09:55 FAX
+dated September 9, 2010
+@002/002
+. "
+KIRKLAND & ELLIS LLP
+AND AIFILIATED FARTNERSHIPS
+Not oN, Now AN 10022
+Jay P. Lefkowitz, P.C.
+To Call Writer Direcily:
+lerkawitz@kirkland.com
+Facsimile:
+www.kirkland.com
+September 7, 2010
+BY FACSIMILE
+/
+The Honorable Ruth Pickholz
+New York County Supreme Court
+Part 66
+111 Centre Street
+New York, NY 10013
+Re: SCID No.
+Dear Justice Pickholz:
+I am writing regarding the hearing for Mr. Jeffrey Epstein in the above-referenced matter,
+which is currently scheduled for 9:30:a.m. on Wednesday, September 15, 2010.
+We respectfully request a continuance of the hearing. Kirkland & Ellis was only recently
+retained by Mr. Epstein to represent him in this matter and due to the holidays this week and
+because the matter arises out of Florida, we will need some time in order to collect information
+to prepare for the hearing.
+We are available on or after October 4, 2010 for a hearing on this matter if that would be
+acceptable to the Court. We are available to discuss at the Court's convenience.
+Respectfully submitted,
+Lefkowitz, P.C.
+Chicago
+Hong Kong
+Los Angeles
+Munich
+Palo Allo
+San Francisco
+Shanghai
+Washington, D.C.
+
+
+A 79
+(TO
+FROM:
+ERE
+STATE OF NEW YORK
+BOARD OF EXAMINERS OF SEX OFFENDERS
+24N14 TOWER PLACEV
+'ALBANY, NEW YORK 12203-3764
+NEW YORK COUNT SUPREME COURT
+BOARD EXAMINER-STEPHEN D WEBER
+JEFFREY. E EPSTEIN
+REPORTED ADDRESS
+SDW
+9 EAST 71ST STREET
+NEW YORK, NY 10021
+DATE 8/19/20110
+ANYSIDHOR BOARD IDE OS1E09
+ASUPERVISING OFFICER:
+SUPERVISING AGENCY:
+NONE; OFFENDER IS UNSUPERVISED
+The above referenced individual has committed an offense in another Jurisdiction, and has established residence Ne
+York State at the address Indicated it has been determined thát, the offender is required to register and be hekatsessed
+as a sex offender in New York State
+The NYS Board of Examiners of Sex Offenders is recommending a risk level and desighation for the offerder a indica
+on the attached risk assessment instrument, cáse summary and desighation form Pursuant tö Correction Law Seatlony
+168-K(2) the County or Supreme Court in the county of residence of the offender shall determing the offender sisk levell
+and desighation The Court must determine whether, the offender meets: the definitior, of sexually: Vibleht Offehdel
+predicate sex 'öffender or sexual predatot as set forth in Correction Law Section 168-a(7)
+Please noie, pursuant to Chapel Be of the Law of da as of oatober 2006, Cornel ah Law Sadle coar
+and 168-n have been amended, lo provide that the Court shall conduct the, risk level and designation hearing Mine tex
+offender, having been given nolice including the date, time, and place of the proceeding tails to appear, without suricient
+excuse. Please note that until the court determines the offender's risk lovel, no community notification can ocea
+A copy of the order setting forth the fisk level and designatjon determinations, and the findings and conclusions of law ch
+Which such determinations are based, shall be submitted to the Division of Criminal Justice Services, Sex Offender
+egiry Unit by the Court In addition, please complete and attach this form Indicating the offenders isk lavalrend
+designation to the Court's order. Please distribute the remaining copies as indicated beldw
+81E:2300624
+nformation below is to be completed by Sentencing Court
+FINAL RISK LEVEL DETERMINATION I (circle one)
+:2
+DESIGNATION: Please check any that apply pursuant to Article 6-C of the NYS Correction LaW
+Sexually Violent Offender,
+¡Sexual Predator 1
+Predicate Sex Offende a kad No such designation
+Judge's Name (please print):
+Judge's signature:
+Date signed:
+R0р нскна2
+17220)
+WHITE COPY:
+Sax Offender Registry Unit
+- DCUS, 4 Tower Pl, Albany; NY 12203
+'YELLOW COPY: Court
+PINK COPY V Offender
+
+
+
+VCrI
+JeFFReY-EPSTeiN
+(50M)
+PT6G
+9-15-10 sily 10/5.
+-10/5 1ly 11-9
+11-29
+"19
+1-1-2000
+- 24 2010
+18.2011
+SELD
+ritten Notations and
+A81
+
+2
+3
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A83
+SORA HEARING
+page 2"
+COURT CLERK: This is number two on the calendar,
+matter of Jeffrey Epstein.
+Your appearances please.
+MS. GAFFNEY: .
+for the People.
+Good afternoon, Your Honor.
+MR. LEFKOWITZ: Jay Lefkowitz and Sandra Musumeci
+for Mr. Epstein.
+THE COURT: Mr. Epstein is not here.
+MR. LEFKOWITZ: That's correct.
+THE COURT: Are you waiving his appearance?
+MR. LEKWOWITZ: Yes.
+MS. GAFFNEY: Your Honor, this case is on for a
+SORA hearing this afternoon.
+The People did receive the board's recommendation
+of a Level Three. However, we received the underlying
+information from them and also had some contact with
+Florida, and we don't believe that we can rely on the entire
+probable cause affidavit.
+I don't know if the board sent that to you as
+well.
+THE COURT: I don't know why you cannot rely on
+it.
+MS. GAFFNEY: Because in Florida of all of the
+victims in that probable cause affidavit, they actually only
+went forward on one case. There was only an indictment for
+Senior Court Reporier
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A85
+SORA HEARING
+page 4
+year old, he was an adult obviously, he was a Marine, a 17
+year old came up to him and one thing lead to another and he:
+had sex with her and the People would not agree to a
+downward modification on that.
+So I am a little overwhelmed here because I see --
+I mean I read everything here, I am just a little
+overwhelmed that the People are making this application.
+I could cite many many, I have done many SORAs
+much less troubling than this one where the People would
+never make a downward argument like this.
+MS. GAFFNEY: I agree with Your Honor, it is
+incredibly unusual for us to make a downward argument. But
+the problem is the one thing that we have from the board is
+it seems to be in contradiction to their own guidelines
+which if something was not indicted, you are not supposed to
+rely on it.
+THE COURT: They obviously took that into
+consideration.
+MS. GAFFNEY: And I tried to reach -- I reached
+the authorities in Florida to try to see if they had all the
+interview notes or other things that we can then
+subsequently rely on that might be considered clear and
+convincing evidence, if they had interviewed these women on
+their own, and they never did. No one was cooperative and
+they did not go forward on any of the cases and none of them
+
+
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+• 13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A87
+SORA HEARING
+page 61
+Even though the first prosecutor left, presumably the
+prosecutor's office has the file.
+THE COURT: I would still call the prosecutor.
+MS. GAFFNEY: Anything from these women they would
+have forwarded it to us.
+THE COURT: I don't know that, I think you have to
+speak to the prosecutor.
+But be that as it may, I hear your argument.
+Anything else?
+MS. GAFFNEY: I mean that is why I don't think we
+can, I don't think we are entitled to rely on this because
+they did not go forward.
+THE COURT: The board made a recommendation.
+MS. GAFNEY: Correct.
+MS. MUSUMECI: May I speak, Your Honor?
+THE COURT: Yes.
+MS. MUSUMECI: Good afternoon.
+I would like to bring a few additional points to
+Your Honor's attention that don't come across in the board
+recommendation.
+The first is that Mr. Epstein is not a resident of
+New York, unlike most of these out of state, he has not
+changed his address and moved to New York, he maintains a
+vacation home in New York. His primary residence is the
+U.S. Virgin Islands.
+
+
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A89
+SORA HEARING
+page 8
+more than seven days or at least he has not since he has
+been registered. He has no intention to ever be here for
+longer than a period of ten days.
+Like I said, he does notify the authorities when
+he is here. He fully understands the reason for voluntary
+registration, he wants to be compliant with the Federal SORA
+law which requires wherever you own a property to register.
+To require Mr. Epstein to register as a Level
+Three offender in New York would actually require him to
+come to New York more than he does normally, it would
+require him to come every 90 days and renew his
+registration.
+He is very diligent in registering with New York
+authorities.
+All of the other jurisdictions that have
+considered his case have determined that he either not
+register at all or register at the Towest level, and he has
+been more than compliant with all of those requirements.
+Your Honor, we would join in the prosecutor's
+application.
+THE COURT: I am sure you would.
+MS. MUSUMECI: By way of background, we have been
+in contact with the prosecutor's office on this matter since
+I believe certainly since Mr. Epstein got his notification,
+which I believe was in August. We have met with the
+
+
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19°฿
+20
+21
+22
+23
+24
+25
+A91
+SORA HEARING
+page. 10
+Mr. Epstein plead to two charges, one was an
+indictment which is an offense that is not registrable, it
+is a Florida indictment for --
+THE COURT: Then why does he have to register
+here?
+MS. MUSUMECI: It was a second offense that he :
+plead to --
+THE COURT: That is registrable.
+MS. MUSUMECI: That is registrable.
+That offense was by information and that is the
+only registrable offense, that is what the DA's office is
+considering in doing their scoring.
+The indictment which was the only case that the
+prosecutor even prosecuted through grand jury is not even a
+registrable offense.
+THE COURT: He plead guilty to a registrable
+offense.
+MS. MUSUMECI: Yes.
+THE COURT: What did he plead guilty to?
+MS. GAFFNEY: He plead guilty to the procuring a
+person under 18 for prostitution.
+THE COURT: Procuring a person under 18 for
+prostitution.
+MS. GAFFNEY: Right.
+THE COURT: How old was she?
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A93
+SORA HEARING
+page 12
+consensual intercourse with him and 17 is not registrable or
+criminal under New York Taw.
+And the prostitution aspect of having intercourse
+with a 17 year old is not registrable conduct.
+THE COURT: Why does he have to register here?
+MS. GAFFNEY: Because it is a register able
+offense in Florida, New York State board of examiners --
+THE COURT: Recognizes it.
+MS. GAFFNEY: Recognizes it, yes.
+THE COURT: I have had many cases like that where
+it was not registrable here but it was in the state where
+the person came from and New York recognized that.
+MS. MUSUMECI: Your Honor, we are not saying that
+he should not register. Mr. Epstein has already registered
+and recognizes his duty to register.
+THE COURT: I am glad of that, very glad of that.
+I am sorry he may have to come here every 90 days.
+He can give up his New York home if he does not
+want to come every 90 days.
+Anything else?
+I rely on the board.
+MS. MUSUMECI: Your Honor, we would reserve our
+right to appeal Your Honor's ruling.
+THE COURT: Of course, do so:
+MS. GAFFNEY: For the record, Your Honor, he is
+
diff --git a/vision-fixhub/ds9-unparsed-05/b402a3871d29649ec39035dffa15aba8dd063fb98f38357ee49c949132fae296.receipt.json b/vision-fixhub/ds9-unparsed-05/b402a3871d29649ec39035dffa15aba8dd063fb98f38357ee49c949132fae296.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c47a9b59ae3df3e7139b866d1b93b0d852ca70d4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b402a3871d29649ec39035dffa15aba8dd063fb98f38357ee49c949132fae296.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -3696,
+  "dataset": "marble-joined",
+  "doc_id": "b402a3871d29649ec39035dffa15aba8dd063fb98f38357ee49c949132fae296",
+  "engine": "marble-apple-vision",
+  "event_count": 80,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "d8b7b18336fbcd570e9b3c50b2177cba00ecb65134a47e3f82188b9c93683b9a",
+  "output_sha256": "514c75d84e303a351b8d638670ee0491e9bbfd915705faa74ab3f1bffb7dc2aa",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b437cd513b57151f3c5cc2b936072ce5978f652c663af1d36a074a7323863c05.md b/vision-fixhub/ds9-unparsed-05/b437cd513b57151f3c5cc2b936072ce5978f652c663af1d36a074a7323863c05.md
new file mode 100644
index 0000000000000000000000000000000000000000..72bed1120eedcae26a6986055ce57511764a4954
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b437cd513b57151f3c5cc2b936072ce5978f652c663af1d36a074a7323863c05.md
@@ -0,0 +1,12 @@
+From:
+Sent:
+To:
+Cc:
+Subject:
+(USAFLS)
+Roy BLACK [RBLACK@royblack.com]
+Thursday, January 21, 2010 2:59 PM
+[USAFLS)
+Yesterday's Letter
+I: On second thought my letter yesterday went too far in one respect. So that there is no misunderstanding of
+this clarifies our concern in this one area. Thanks Roy
diff --git a/vision-fixhub/ds9-unparsed-05/b437cd513b57151f3c5cc2b936072ce5978f652c663af1d36a074a7323863c05.receipt.json b/vision-fixhub/ds9-unparsed-05/b437cd513b57151f3c5cc2b936072ce5978f652c663af1d36a074a7323863c05.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d5381c0ada18aa86ebeeebf26b7daf94bfbd9629
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b437cd513b57151f3c5cc2b936072ce5978f652c663af1d36a074a7323863c05.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "b437cd513b57151f3c5cc2b936072ce5978f652c663af1d36a074a7323863c05",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "da7bf5808262cceabd0c632d4e3ac4013777158ce43edf0cdfa22fd462427133",
+  "output_sha256": "34861343dbce68c48cc7484d533106f424038428f05cc98d22757b48f0a8be63",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b45fbe02a6df91d326cd3df4e7e465bcbc253c8fc1733780c3be724a8fe5219f.md b/vision-fixhub/ds9-unparsed-05/b45fbe02a6df91d326cd3df4e7e465bcbc253c8fc1733780c3be724a8fe5219f.md
new file mode 100644
index 0000000000000000000000000000000000000000..0f71d21000db6fe80d3d3239082158b11fa39b40
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b45fbe02a6df91d326cd3df4e7e465bcbc253c8fc1733780c3be724a8fe5219f.md
@@ -0,0 +1,9903 @@
+Statements
+
+
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary.............................
+Your Portfolio Holdings
+Transaction Detail
+Your Messages .......•••......••I.........
+Bear, Stears & Co. Inc.
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 28, 2003
+3
+4
+13
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+18,601,283
+215,777
+380,860
+NET EQUITY THIS PERIOD
+$19,197,920
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+15,882,704
+3,315,216
+There are no "Stop Loss' orders or other pending buy
+or sell open orders on file for your account
+Cash & Equivalent
+Fixed
+Income
+Market Value of Your Portfolio
+$380,860
+$280,444
+Current market value
+Last statement's market value
+$18.601.283
+$15,453,004
+Important Message
+If any information regarding
+2003interest, dividends,
+miscellaneous income,
+gross proceeds or original
+issue discount is required
+to be reported to the IRS for
+this account, a
+Consolidated Form 1095
+will be mailed to you by
+DeMarch 15,2004. a 10425
+SP The suremen s four ratanal purger red de Set revere die for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+01/01/04:12:17 001|
+
+
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERIOD
+$280,444.12
+...
+34,476,423.63
+769,840.35
+114,939.00
+.......
+$35.361.202.98
+....
+-35,167,056.55
+-93,680.63
+-50.00
+$-35,260.787.18
+.. . .
+100,415.80
+5380,859.92
+Income Summary
+Govt. Agency Int.
+Corp. Bond Int.
+Credit Balance Int.
+Reverse Repurchase Int.
+Total
+Bond Purchase Int.
+Margin Int. Paid
+Repurchase Int. Exp.
+THIS PERIOD
+529,120.88
+240,687.70
+31.77
+4,127.88
+5773.968.23
+-93,603.74
+-76.89
+Portfolio Composition
+Cast/Cash Equivalent
+Fixed Income
+Total
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+280,444.12
+$280,444.12
+CLOSING
+380,859.92
+$380,859.92
+027
+YEAR TO DATE
+9,461,836.30
+1,403,354.75
+1,111.16
+26,483.48
+.....
+$10.892.785.69
+-143,760.56
+-76.89
+-24,344.52
+380,860
+18,601,283
+... ..
+$18.982,143
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 28, 2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+2%
+- Fixed Income
+98%
+Unshaded portions denole debe balance andor short
+from the absolute marker value of your portiolo
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+FEDERAL HOME LOAN MTG CORP
+SERIES 2526 CLASS SI
+DATED DATE 10/01/02
+DUE 02/15/2032 5937%
+FEDERAL NATIONAL MTG ASSN
+STRIP MG SERIES 322 CL PO
+DATED DATE 03/01/02
+DUE 03/01/2032
+FACTOR -11.00000000
+FEDERAL HOME LOAN MG CORP
+SERIES 2471 CLASS YT
+DATED DATE 06/07/02
+DUE 03/15/2032 1 000%
+EDERAL HOME LOAN MIG COR
+SERIES 2488 CLASS S
+DATED DATE 07/08/02
+BOOK ENTRY ONLY.
+FACTOR 152033 12973
+SIMBCLCUSIP
+PRICE
+SYMEOLCUSP
+MRGN
+10,456,946
+MAGN
+1,971,241
+MAGN
+36,766,242
+MAGN
+18,505,970
+MARKET
+VALUE
+380,860
+$380,860
+PRICE
+10.4905
+3.6400
+11.2865
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 28, 2003
+STIMATE
+ANUAL INCON
+MARKET VALUE
+1,096,983
+CURREN
+YIELD IS
+0179:99
+1,678,327
+1,338,278
+27,127
+2
+16,340
+ESTIMATED
+ANNUAL INCOM
+Z4E19
+20
+367,662
+8ZLt 1Z
+2,088,679
+56,235
+1,265,253
+60.5767
+
+Your Portfolio Holdings (continued)
+Government & Agency Obligations (continued)
+PEDERAL HOME LOAN MIG CORP
+SIMBOLCUSP
+SERIES 2483 CL SL
+DATED DATE 07/02/02
+FACTO 2 5887%
+FEDL HOME LOAN MTG
+SERIES 223 CLASS PO
+DATED DATE 12/01/02
+VE 12/01/202
+ACTOR =
+FEDERAL NATIONAL MTG ASSN
+SERIES 2003-49 CLASS SW
+DATED DATE 04/30/03
+Total Government& Agency Obligations
+Corporate Bonds
+FANNIE MAE CMO/SERIES 2003-13
+SATED DATE 025103
+PACT 202 1259%
+Total CorporateBands
+TOTAL FIXED INCOME
+SMMBOLCUSP
+Bear, Steams & Co. Inc.
+MAGN
+MRGN
+21,350,313
+3,249,317
+MRGN
+18,701,667
+MAGN
+37,118,425
+PRICE
+10.6137
+79.9844
+11.2571
+PRICE
+14.6255
+027
+MARKET VALLE
+2,266,065
+2,598,946
+2,105,258
+$13,172,536
+55,389
+18,259
+$173,352
+MARKET VALUE
+5,428,747
+$5,428,747
+$18,601,283
+CORUE
+NTERES
+42,425
+$42,425
+$215,777
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 28, 2003
+ESTIMATED
+ANNUAL INCOME
+1,246,218
+CURRENT
+YIELD IN
+54.9948
+.....
+1,095,544
+$4,585,069
+52.0385
+2,545,582
+$2,545,582
+.130,651
+46.8908
+
+
+Bear, Steams & Co. Inc.
+Your Portfolio Holdings (continued)
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearnsand Co. Inc. outstanding as of date of statement
+PUACHASE'
+AEPURCHASE
+PRICING
+PURCHASE PRICEY
+ACCAUED REPO
+START DATE
+DATE
+RATE
+YOU PROVIDED
+(MARGIN)
+10/23/03 OPEN
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASETRANSACTIONS
+"As of statement date
+$215,777
+.130,651
+$18,982,143
+(FACE AMOUNT
+51,655,000
+CUSP
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 29,2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 28, 2003
+SERIES 2530 CLASS SE
+
+
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEEMENT TATE
+DATE
+TRANSACTION
+12/04/03 12/01/03
+SOLD
+12/05/03
+12/05/03
+12/05/03
+12/05/03
+12/09/03
+1215/03
+12245/03
+12/15/03
+JOURNAL"
+ESCRIPTION
+ANNIE MAE CMO/SERIES 2002-82
+K-VO FLTR
+013102512081.06.9318
+BS
+EDERAL NATIONAL MIG ASSI
+TRIP MG SERIES 322 CL PO
+PRINCIPAL REDUCT 12-25-03
+PRINCIPAL REDUCTN 12-15-03
+FANNIE MAE MOISERIES 2002-82
+FANNIE MAE CMOVSERIES 2002-82
+HAO DUE 1025131
+FANNIE MAE MOISERIES 2002-82
+K-VO FLT
+1931 DUE 10/25/3
+..............
+EDERAL HOME LOAN MG COF
+SERIES 2471 CLASS YT
+1,000 DUE 03/15/32
+PRINCIPAL REDUCTN 12-15-03
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+1,000 DUE 03/15/32
+PRINCIPAL REDUCTN 12-15-03
+SERIES 2483 CL SL
+.837 DUE 03/15/3
+RINCIPAL REDUCTN 12-15-0:
+SYMBOLCUSIP
+027
+- 14,242,198
+PRICE
+11.43750
+ACCR. INT.
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+November 28, 2003
+1,628,951.45
+24,679.06
+-69,948
+59,396
+-1
+1,460,000
+*302
+-848,004
+
+
+INVESTMENT ACTIVITY (continued)
+SETTLEMENT TRADE
+12/15/03
+TRANSACTION
+12/15/03
+1215/03
+2/180
+12/18/03
+SERIES 2488 CLASS SQ
+.837 DUE 03/15/32
+RINCIPAL REDUCTN 12-15-03
+FEDERAL HOME LOAN MTG CORP
+SERIES 2526 CLASS SI
+6,837 DUE 02/15/32
+RINCIPAL REDUCTN 12-15-03
+FEDL HOME LOAN MTG
+SERIES 223 CLASS PO
+UE 12/01/3
+RINCIPAL PAYMENT 12-15-0
+... ..
+FANNIE MAE CMO/SERIES 2003-1:
+S ROR-VO FLTA
+TUE 0302512033 06.881:
+12/26/03
+i2226/03
+1226/03
+TOTAL
+PRINCIPAL PAYMENT 12-25-03
+FANNIE MAE MOISERIES 2003-13
+S ROR-VO FLTR
+.881 DUE 03/25/33
+RINCIPAL REDUCTN 12-25-0:
+*FEDERAL NATIONAL MIG ASSN
+SERIES 2003-49 CLASS SW
+5.881 DUE 01/25/33
+PRINCIPAL REDUCTN 12-25-03
+SYMBOL/GUSP
+027
+-735,030
+-370,995
+PRICE
+37,669,355
+ACCR. INT.
+14.50000
+-550,930
+-277,580
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+November 28, 2003
+59,396.20
+5,462,056.55
+93,603.74
+69,948.10
+$-5,555,660.29
+$1,782.974.81
+
+
+DATE
+12/01/03
+AVG BAL
+124,272RT
+021 OFFICE INTEREST 1103
+1215/03
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+DEREST 220MENT 12-19-03
+12/15/03
+SERIES 2483 CL SL
+DUE 03/15/2032
+TEREST PAYMENT 12895-03
+.........
+12/15/03
+FEDERAL HOME LOAN MTG CORP
+HE 03S1 12032
+PAYMENT
+1215/03
+FEDERAL HOME LOAN MG CORP
+Bear, Stears & Co. Inc.
+SYMBOL/CUSIP
+12/15/03
+FEDERAL HOME LOAN MG CORP
+i215/03
+SERIES 2526 CLASS SI
+INTEREST PAYMENT 12-15.-03
+12/26/03
+-ANNIE ME MOSERIES 2003-13
+S ROR-I/O FLTR
+DUE 03/25/2033
+INTEREST PAYMENT 12-25-03
+i226/03
+FEDERAL NATIONAL MG ASSN
+SERIES 2003-49 CLASS SW
+DUE 01/25/2033
+INTEREST PATENT 12-25-03
+RATE (%)
+1.0000
+5.8370
+5.8370
+5.8810
+027
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 28, 2003
+31.77
+31,855.45
+108,771.75
+110,315.08
+18,373.41
+113,730.20
+53.056.91
+16,008.64
+93,018.08
+
+
+10 of 13
+INTEREST (continued)
+DATE
+12/31/03
+AVG BAL 23,718RT 3.765
+021 OFFICE INTEREST 1203
+TOTAL
+SETLEMENT
+12/04/03
+TRADE
+DATE
+TRANSACTION
+12/09/1
+1209/03
+"JOURNAL
+1209
+12/09/03
+12/091
+Bear, Stears & Co. Inc.
+8.625 D1
+8 625 D1
+DP CL
+8 625 011
+8 625 01
+8 625 DI
+23149
+M9517A9
+DUE 12/31/2010 3 625
+ITM.PR
+SYMBOL/CUSIP
+RATE (%)
+027
+76.89
+$-76.89
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 28, 2003
+$745,161.29
+1,800,000.00
+3,989,000.00
+'3.989, 000.00
+3.989,000.00
+4.208,000.00
+:177.3
+
+
+11 of 13
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+SETTLEMENT
+1210
+TRADE
+DATE
+TRANSACTION
+3 625 Mlizpst7g
+12/10/03
+12101
+2/10/0:
+
+2/171
+2/17/0:
+2/171
+ї2171
+8 625 01
+a0s149
+8 625 01
+
+aaaaaaaaaaaaaaaa
+8 625 DI
+W3143
+VE 122312019
+TM-P
+8.625 DI
+23148
+8 625 DI
+(231149
+8 625 Cl
+03149
+฿ 625 0l
+W3149
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 28, 2003
+4.208.000.00
+4.208.000.00
+18.0
+1,800,000.00
+4,240,000.00
+4.240,000.00
+027
+--..
+1.208,000.00
+4,240,000.00
+4.240,000.00
+
+
+Bear, Steams & Co. Inc.
+12 or 13
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+SETTLEMENT
+TRADE
+12/17/03
+DATE
+TRANSACTION
+1217
+12171
+1219/03
+12/19/1
+1219L
+8 625 Dl
+DUE 12/31/2019 8625
+EITM-PR
+DUE 121312019 8625
+EITM-PR
+8 625 DI
+2314g
+....
+8.625 01
+... ..
+DP C
+LE 12/31/2019 362
+TOTAL
+MISCELLANEOUS
+DATE
+MODAY
+12/08/03
+TRANSACTION
+FITG FITM
+SYMBOUGUSIP
+[ 040,000.00
+980,000.00
+$-29,705,000.00
+CRECIT AMOUNT
+114,939.00
+027
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 28, 2003
+54050
+837.40
+M. 040,000.00
+340.59
+$32,718,127.88
+
+
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 28, 2003
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+12/11/03
+TOTAL
+TRANSACTION
+NOV. 03 SPEC CLEARING FEES
+50.00
+$-50.00
+CRECIT AMOUNT
+$114,939.00
+Your messages
+18 Excess SIPC Account Protection Update
+Bear, Stearns Securities Corp. ('BSS"), a member of the Securities Investor
+Protection Corporation ("SIP"), provides account protection for the net equity
+of a customer's funds and securities positions, SIPC provides $500,000 of
+primary net equity protection, including $100,000 for claims for cash ("SIPC
+Coverage"), Visit www,sipc,org for more information about SIPC Coverage,
+BSSC provides the additional protection ("Excess SIPC") through a commercial
+insurer, Effective February 16, 2004, the commercial insurer for Excess SIPC
+will change to Customer Asset Protection Company (CAPCO"), a licensed New
+York insurance company. Account protection applies when a SIPC member
+firm fails financially and is unable to meet its obligations to its securities
+customers, but does not apply to losses from the rise or fall in the market
+value of investments or to SIPC ineligible assets such as options, futures,
+foreign exchange transactions, or any investment contracts that are not
+registered as securities,
+STOP
+****** End of Statement******
+027
+
+
+Bear, Stears & Co. Inc.
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary .............................
+Your Portfolio Holdings
+.. . .
+Transaction Detail
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31,2003
+3
+4
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+15,453.004
+149.256
+280,444
+NET EQUITY THIS PERIOD
+$15.882,704
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+16,731,773
+-849,069
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account
+Market Value of Your Portfolio
+$280,444
+$450,076
+Cash & Equivalent
+Fixed
+Income
+- 3 516500.4
+$16,075,464
+Current market value
+Last statement's market value
+SIP The wireman is foul ratanal pur ye rearde Set rente dae for portant iformation.
+11/29/03:08:43 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+11/29 03:08:43 001
+
+
+3 or 12
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERIOD
+...
+5450,076.34
+101,312,656.87
+637,878.91
+204,699.00
+S102,155,234.78
+....
+-102,136,500.00
+-188,367.00
+5-102 324,867.00
+-169,632.22
+....
+280.444.14
+Income Summary
+Govt. Agency Int.
+Corp. Bond Int.
+Credit Balance Int.
+Reverse Repurchase Int.
+Total....
+Bond Purchase Int.
+Repurchase Int. Exp.
+THIS PERIOD
+YEAR TO DATE
+552,396.94
+8,932,715.42
+85,430.29
+1,162,667.05
+51.68
+1,079.39
+2,398.77
+22,355.60
+... .
+$640.277.68
+.510.118.817.46
+-50,156.82
+-24,344.52
+Portfolio Composition
+Cash/Cash Equivalent
+Fixed Income
+Total
+280,444
+15,453,004
+...$15.733.448
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+450,076.34
+$450,076.34
+CLOSING
+280,444.12
+....
+$280,444.12
+027
+11/29/03:08:43 001
+LEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31,2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+1%
+- Fixed Income
+99%
+Unshaded portions denote debit balance and or shart
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+SERIES 2526 CLASS S
+ATED DATE 10/01/02
+PA 0 52032
+20202 52180%
+FEDERAL NATIONAL MTG ASSN
+STRIP MTG SERIES 322 CL PO
+DATED DATE 03/01/02
+DUE 03/01/2032
+FACTOR 110000000%
+FEDERAL HOME LOAN MG CORP
+SERIES 2471 CLASS YT
+DATED DATE 06/07/02
+DUE 03/15/2032 1,000%
+FACTOR - 38226545
+FEDERAL HOME LOAN MG CORP
+SERIES 2488 CLASS SQ
+DATED DATE 07/08/02
+E 03/15/2032.88
+CTOR - 384820
+Bear, Steams & Co. Inc.
+SIMBCLCUSIP
+PRICE
+280,444
+$280,444
+SYMBOLCUSP
+MRGN
+10,827,941
+PRICE
+10.5177
+MAGN
+2,041,189
+83.3750
+MAGN
+38,226,544
+3.6983
+MAGN
+19,241,000
+11.3871
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31,2003
+STIMATE
+ANUAL INCON
+MARKET VALUE
+1,138,856
+166'ZZ
+1.701,841
+1.413,715
+2
+13,800
+ESTIMATED
+ANNUAL INCOME
+636,683
+20
+382,265
+CURREN
+YIELD IS
+9906'99
+46002Z
+2,190,993
+47,800
+1,323,781
+60.4192
+11/2903:08:43 001
+
+Your Portfolio Holdings (continued)
+Government & Agency Obligations (continued)
+SERIES 2483 CL SL
+BOOK ENTRY ON 2102
+FACTOR 23322
+FEDL HOME LOAN MTG
+SERIES 223 CLASS PO
+DATED DATE 12/01/02
+OOK ENTRY ONLY
+DUE 12/01/2032
+-ACTOR - .6617427!
+FEDERAL NATIONAL MTG ASSN
+RIES 2003-49 CLASS 9
+TED DATE 04/301
+FACTOR 790821881%
+Total Government& Agency Obligations
+SIMBOLCUSP
+Corporate Bonds
+FANNIE MAE CMO/SERIES 2002-82
+SK-I/O FLTR
+BOOK ENTRY ON 2102
+FACTOR 587921%
+Total CorporateBands
+TOTAL FIXED INCOME
+SIMBOLCUSP
+Bear, Steams & Co. Inc.
+MAGN
+MRGN
+22,198,317
+3,308,713
+MRGN
+18,979,247
+MAGN
+14,242,197
+PRICE
+10.6633
+77.5781
+10.6794
+MARKET VALLE
+2.367.071
+2,566,838
+2,026,866
+ACCRUED
+NTERES
+47,134
+9,302
+$13,406,180
+$141,029
+PRICE
+14.3715
+MARKET VALLE
+2,046,824
+8,227
+$2,046,824
+$8,227
+$15,453,004
+$149,256
+027
+11/2903;08:43 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31, 2003
+ESTIMATED
+ANNUAL INCOME
+1,305,261
+CURRENT
+YIELD (S)
+55.1425
+......
+1,116,170
+.....
+55.0688
+$4,764,180
+ANNUAL MONE
+987,127
+$987,127
+$5,751,307
+URREN
+48.2273
+
+
+Bear, Steams & Co. Inc.
+Your Portfolio Holdings (continued)
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearnsand Co. Inc. outstanding as of date of statement
+PUACHASE'
+AEPURCHASE
+PRICING
+PURCHASE PRICEY
+ACCAUED REPO
+START DATE
+DATE
+RATE
+YOU PROVIDED
+(MARGIN)
+10/23/03 OPEN
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASETRANSACTIONS
+"As of statement date
+$149,256
+$5,751,307
+$15,733,448
+(FACE AMOUNT
+-51,655,000
+CUSP
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31,2003
+SERIES 2530 CLASS SE
+11/29/03;08:43 001
+
+
+Transaction Detail
+INVESTMENT ACTIVITY
+BELEMENT TATE
+11/07/03
+11/07/03
+11/13/03
+10/16/03
+11/13/03
+10/07/03
+11/13/03
+10/16/03
+11/13/03
+10/07/03
+11717/03
+TRANSACTION
+CANCEL SELL
+SOLD
+CANCEL BUY
+Bear, Steams & Co. Inc.
+FEDERAL NATIONAL MG ASSN
+MAR A REUT 12503
+FEDL HOME LOAN MG I
+SERIES 223 CLASS PO
+PRINCIPAL REDUCTN 11-15-03
+TO OL PRETOUS SEL
+SETT 11/03
+DUE 1100112033 05,500%
+REF T
+SETT, 11/03
+THE 1110712023.05,500%
+REF #1
+FNMA-30YR(FNMAJGTD
+SETT. 11/03
+DUE 110112023. 05,500%
+BS
+BS
+BS
+BS
+............••••..
+SERIES 217I COME CORD
+1.000 DUE 03/15/32
+RINCIPAL REDUCTN 11-15-03
+SYMBOL/GUSP
+027
+-100,887
+-61,871
+40,000,000
+PRICE
+100.12500
+40,000,000
+40,000,000
+40,000,000
+100.59375
+100.12500
+100.59375
+-1,910,000
+11/2903:08:43 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31, 2003
+40,050,000.00
+40,237,500.00
+40,050,000.00
+40,237,500.00
+
+
+INVESTMENT ACTIVITY (continued)
+SEEMENT TRIE
+11/17/03
+TRANSACTION
+11/17/03
+1117/03
+1417/03
+RINCIPA
+1717/03
+
+11/25/03
+1/25/0
+Bear, Stears & Co. Inc.
+FEDERAL HOME LOAN MG CORP
+SERIES 2471 CLASS YT
+1,000 DUE 03/15/32
+PRINCIPAL REDUCTN 11-15-03
+SERIES 2483 CL SL
+5,880 DUE 03/15/32
+RINCIPAL REDUCTN 11-15-03
+FEDERAL HOME LOAN MTG CORP
+SERIES 2483 CL SL
+,880 DUE 03/15/3
+RINCIPAL REDUCTN 11-15-0
+... . .
+DERAL HOME LOAN MTG CO
+DANCIPAL REDUN 1-1503
+FEDERAL HOME LOAN MTG CORP
+SERIES 2526 CLASS SI
+,880 DUE 02/15/3
+RINCIPAL REDUCTN 11-15-0
+FEDL HOME LOAN MTG
+SERIES 223 CLASS PO
+DUE 12/01/32
+PRINCIPAL PAYMENT 11-15-03
+FEDERAL NATIONAL MG ASSN
+STRIP MTG SERIES 322 CL PO
+1.001 DUE 03/01/32
+PRINCIPAL PAYMENT 11-25-03
+FANNE ME MOISERES 2002-82
+MAN PA NEVER 12503
+SYMBOL/GUSP
+027
+-818
+- 1,109,000
+-620
+-961,794
+527,288
+PRICE
+550,926
+11/29/03:08:43 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31, 2003
+61,871.10
+100,887.00
+
+
+9 of 12
+INVESTMENT ACTIVITY (continued)
+SATEMENT TREE
+11/25/03
+TRANSACTION
+TOTAL
+DATE
+11/03/03
+1/17/0:
+AVG BAL 216,567R
+'FEDERAL HOME LOAN MG CORP
+SERIES 2471 CLASS YT
+DUE 03/15/2032
+INTEREST PENT 11-15-03
+i1/17/03
+''FEDERAL HOME LOAN MG CORP
+SERIES 2483 CL SL
+DUE 03/15/2032
+INTEREST PAYMENT 11-19-03
+i1/17/03
+DUE 03/15/2032
+11/17/03
+SERES 2530 CLAN MIE COFFE
+DUE 02/15/2032
+1.280
+NT R/D 10-03 PLD 11-15-03
+REPO P&1
+1/17/03
+'FEDERAL HOME LOAN MIG CORP
+SERIES 2530 CLASS,
+DUE 02/15/2032
+REPO P &1
+Bear, Stears & Co. Inc.
+FEDERAL NATIONAL MIG ASSN
+SERIES 2003-49 CLASS SW
+,881 DUE 01/25/3
+RINCIPAL REDUCTN 11-25-0
+SYMBOL/CUSIP
+SYMBOL/CUSP
+RATE (%)
+1.0000
+5.8800
+027
+-354,146
+PRICE
+11/29/03:08:43 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31,2003
+$-80,287,500.00
+$80,450,258.10
+51.68
+... . .
+33,447.80
+114,208.89
+115,829.36
+19.268.14
+19268.51
+
+
+10 or 12
+INTEREST (continued)
+DATE
+11/17/03
+11/25/03
+1/25/03
+FEDERAL HOME LOAN MG CORP
+AVERT FRIEND 17503
+FANNIE ME MOISERIES 2002-82
+SK-I/O FLTR
+INTEREST PAINENT 1-25-03
+FEDERAL NATIONAL MIG ASSN
+SERIES 2003-49 CLASS SW
+DUE 01/25/2033
+INTEREST EN 11-25-03
+TOTAL
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS
+with Bear, Stearns& Co.Inc.
+SETTLEMENT
+DATE
+11/057
+TRADE
+DATE
+TRANSACTION
+8.605 01
+11/05/03
+8 625 D1
+11/05
+8 625 01
+50231/49
+...............................
+8625 0l:
+
+RATE (%)
+5.8800
+5.8810
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31,2003
+55,640.62
+85,430.29
+14,733.63
+$637,878.91
+3.000,000.00
+3,000,000.00
+3.000,000.00
+11/2903;08:43 001
+
+
+Bear, Stears & Co. Inc.
+11 of 12
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+SETLEMENT
+11/05/
+TRADE
+DATE
+TRANSACTION
+DUE 12/31/2019 8.625
+EITM-PR
+SYMBOUGUSIP
+1/18
+11/18/03
+11/18
+14718/03
+178L
+8,625 DI
+a03149
+8 625 01
+
+23148
+......
+8 625 D
+........
+BIE 12312019
+8.625
+EITM-PR
+11/20/"
+8 605 DI
+
+1/20/
+8 625 Cl
+฿ 625 0l
+28149
+3,450,000.00
+*3.980,000.0
+3.980,000.00
+027
+11/2903;08:43 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31, 2003
+913.33
+3.450,000.00
+3.450,000.00
+1,262.12
+3,980,000.00
+3,980,000.00
+
+
+Bear, Stears & Co. Inc.
+12 of 12
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+BETLEMENT
+TRADE
+DATE
+TRANSACTION
+11/20/03
+11/201
+DUE 121312019 8625
+TOTAL
+MISCELLANEOUS
+MATTAY
+11/05/03
+i1/12/03
+TRANSACTION
+11/7/03 JOURNAL
+11/24/03
+TOTAL
+FITG FITM
+FNMA-3OYR(FNMA)GTD
+SETT. 11/03
+MES NET 111200333
+FIG FITM
+"OCT O3 SPEC CLEARING FEES
+STOP
+****** End of Statement******
+220
+3,989,000.00
+$-21,849,000.00
+CRECIT AMOUNT
+204,699.00
+$204,699.00
+11/29/03:08:43 001
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31, 2003
+223.32
+$20,862,398.77
+17.00
+187,500.00
+850.00
+$-188,367.00
+
+
+Bear, Stears & Co. Inc.
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary.............................
+Your Portfolio Holdings
+Transaction Detail .....
+Trades Not Yet Settled
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2003
+3
+4
+14
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+16,075,464
+206.233
+450,076
+16.731.773
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+13,670,819
+3,060,954
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Cash & Equivalent —
+Fixed
+Income
+Market Value of Your Portfolio
+$450,076
+$992
+Current market value
+Last statement's market value
+$16,075,464
+$13,466,661
+SP The suremen is four for ratanal purger red de Set revere date for portant iformation.
+
+
+2 of 14
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or 14
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Miscellaneous
+Amount Debited.
+Net Cash Activity
+Closing Balance.
+Bear, Stears & Co. Inc.
+THIS PERIOD
+- $992.05
+158,614,157.53
+679,297.41
+1,214,062.50
+$160.507.517.44
+-159,821,725.15
+-236,708.00
+5-160.058.433.15
+449,084.29
+....
+5450,076.34
+Income Summary
+Govt. Agency Int.
+Corp. Bond Int.
+Credit Balance Int.
+Reverse Repurchase Int.
+Total
+Bond Purchase Int.
+Repurchase Int. Exp.
+THIS PERIOD
+589,443.56
+89,757.59
+96.26
+1,538.03
+5680,835.44
+YEAR TO DATE
+8,380,318.48
+1,077,236.76
+1,027.71
+19,956.83
+..........
+59.478,539.78
+-50,156.82
+-24,344.52
+Portfolio Composition
+Cash/Cash Equivalent
+Fixed Income
+Total
+450,076
+16,075,464
+_ 516,525,540
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+992.05
+$992.05
+CLOSING
+450,076.34
+$450,076.34
+027
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30, 2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+2%
+- Fixed Income
+98%
+Unshaded portions denote debit balance and or shart
+
+
+4 of 14
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+SERIES 2526 CLASS S
+DATED DATE 10/01/02
+DUE 02/15/2032 5,880%
+-ACTOR
+
+STRIP MTG SERIES 322 CL PO
+DATED DATE 03/01/02
+DUE 03/01/2032
+FACTOR 110000000
+FEDERAL HOME LOAN MG CORP
+SERIES 2471 CLASS YT
+DATED DATE 06/07/02
+DUE 03/15/2032 1,000%
+FACTOR - 40137363
+SERIES 2488 CLASS SO
+DATED DATE 07/08/02
+BOOK ENTRY ONLY.
+Bear, Steams & Co. Inc.
+SIMBCLCUSIP
+PRICE
+SYMBOLCUSP
+MRGN
+11,355,229
+MAGN
+2,142,076
+MAGN
+40,137,362
+MAGN
+20,202,794
+MARKET
+VALUE
+450,076
+$450,076
+PRICE
+10.4109
+1602:18
+3.6956
+11.2818
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2003
+STIMAT
+INJAL INCON
+MARKET VALLE
+1,182,184
+29,675
+
+1,483,335
+2
+17,840
+ESTIMATED
+ANNUAL INCOME
+667,687
+21
+401,374
+CURREN
+YIELD IS
+
+
+2,279,235
+61,775
+1,389,952
+60.9833
+
+5 or 14
+Your Portfolio Holdings (continued)
+Government & Agency Obligations (continued)
+REDEAL HOME LOAN MIG CORP
+SYMBOLCUSP
+SERIES 2483 CL SL
+BOOK ENTRY ONE 202
+FEDL HOME LOAN MTG
+SERIES 223 CLASS PO
+DATED DATE 12/01/02
+UE 12/01/203
+ACTOR - .6741169
+FEDERAL NATIONAL MTG ASSN
+SERIES 2003-49 CLASS SW
+DATED DATE 04/30/03
+FACTOR 95391680%
+Total Government& Agency Obligations
+Corporate Bonds
+FANNIE MAE CMO/SERIES 2002-82
+SYMBOLCUSP
+FACTOR 39121980%
+Total CorporateBonds
+TOTAL FIXED INCOME
+Bear, Steams & Co. Inc.
+MAGN
+MRGN
+QUANTIT
+23,307,937
+3,370,584
+MRGN
+19,333,393
+MAGN
+14,793,123
+PRICE
+78.3359
+10.9805
+14.2260
+027
+MARKET VALLE
+2,459.263
+2,640,379
+ICCRUEL
+TERES
+60,909
+2,122,905
+$13,970,996
+18,947
+$189,148
+MARKET VALUE
+2,104,468
+$2,104,468
+$16,075,464
+17,085
+$17,085
+$206,233
+LEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2003
+ESTIMATED
+ANNUAL INCOME
+1,370,507
+CURREN
+YIELD IS
+55.7284
+... ..
+1,136,804
+$4,966,345
+•......
+53.5495
+1,025,163
+$1,025,163
+$5,991,508
+48.7136
+VaTe
+
+
+I or 1a
+Bear, Stears & Co. Inc.
+Your Portfolio Holdings (continued)
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearnsand Co. Inc. outstanding as of date of statement
+PUACHASE'
+AEPURCHASE
+PRICING
+PURCHASE PRICEY
+ACCAUED REPO
+START DATE
+DATE
+RATE
+YOU PROVIDED
+(MARGIN)
+10/23/03 OPEN
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASETRANSACTIONS
+"As of statement date
+$206,233
+$5,991,508
+$16,525,540
+(FACE AMOUNT
+-51,655,000
+CUSP
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2003
+SERIES 2530 CLASS SE
+
+
+1 or 1a
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTEMENT TREE
+10/07103
+TRANSACTION
+1015/03
+09/30/03
+10775/03
+09/05/03
+CANCEL SELL"
+09/05/03
+09/04/03
+10/07/03
+CANCEL SELL
+CANCEL SELL
+CANCEL SELL
+FEDERAL NATIONAL MG ASSN
+FEDL HOME LOAN MG LI
+SERIES 223 CLASS PO
+DUE 12/01/2032
+* O 82068 INH ANO
+EIT, 10/0:
+TE nm12033 05.500g
+REFE
+AS CAL PREVIOUS SELL
+FNMA-30YR(FNMA) GTD
+SETT. 10/03
+nUE in 0112022,05.500%
+REF #
+15 CA. PREVIOUS SELL
+BS
+BS
+IT.10/L
+E 0012033_05.500
+* L PREVIOUS SEL
+FNMA-30YR(FNMA) GTD
+ETT. 10/0
+TE inm 12033,05,500
+BS
+BS
+SYMBOL/GUSP
+027
+- 169,307
+3,370,584
+PRICE
+.. . .
+2.3125
+10,000,000
+10,000,000
+99.53125
+99.5312:
+15,000,000
+98.96875
+40,000,000
+100.94922
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2003
+_._---...
+2,774,412.65
+9.953,125.00
+9,953,125.00
+14,845,312.50
+40,379,687.50
+
+
+8 of 14
+INVESTMENT ACTIVITY (continued)
+SETTLEMENT TRADE
+DATE
+TRANSACTION
+09/03/03
+10/15/03 09/05/03 SOLD
+
+09/05/03
+'SOLD
+09/04/03
+SOLD
+10/07/03
+SOLD
+09/03/03
+CANCEL BUY
+FNMA-30YR(FNMA) GTD
+ETT. 10/03
+tE 1n00112083 05,500
+REF #1
+SET: 01082023, 05,500%
+BS
+BS
+SETT, 10/03
+DUE 1N01/2033.05,500%
+REF#
+BS
+FNMA-30YR(FNMA) GTD
+ELT, 10/0
+IF 00172038_05.500
+REF #1
+BS
+FMA 30YR(FMA) GTD
+SETT, 10/0:
+E3nm12033 05,500%
+REF #1
+BS
+ENMA 30YR(FNMA) GTD
+SETT. 10/0
+HE I001/2033 05,500
+REFE
+BS
+AS OF USTUSTUS
+TO CXL PREVIOUS BUY
+EDERAL HOME LOAN MTG COR
+SERIES 2471 CLASS YT
+1.000 DUE 03/15/32
+PRINCIPAL REDUCTN 10-15-03
+SYMBOL/GUSP
+027
+65,000,000
+0,000,00
+- 10.000,000
+-15,000,000
+-40,000,000
+-65.000,000
+PRICE
+98.40625
+9.531:
+99.53125
+98.96875
+100.94922
+•98-40625
+3,174,000
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2003
+63,964,062.50
+*9,953, 125.00
+9.953,125.0
+14,845,312.50
+40,379,687.50
+63,964,062.50
+
+
+9 of 14
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+TRANSACTION
+Bear, Stears & Co. Inc.
+10124/03
+
+10/27/03
+SERIES 2471 CLASS YT
+1,000 DUE 03/15/32
+PRINCIPAL REDUCTN 10-15-03
+SERIES 2483 CL SL
+5,880 DUE 03/15/32
+RINCIPAL REDUCTN 10-15-03
+............
+FEDERAL HOME LOAN MTG CORP
+SERIES 2483 CL SL
+,880 DUE 03/15/3
+RINCIPAL REDUCTN 10-15-0
+•••••••••••••••••••••••••••••••••
+DERAL HOME LOAN MTG CO
+DANCIPAL REDUN 10. 1503
+FEDERAL HOME LOAN MTG CORP
+REPA RUNS 10 1503
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2526 CLASS SI
+5,880 DUE 02/15/32
+PRINCIPAL REDUCTN 10-15-03
+SERIES 2530 CLASS SE
+.280 DUE 02/15/32
+ADJUST POSITION
+"FEDERAL NATIONAL MIG ASSN
+TRIP MTG SERIES 322 CL PO
+1.001 DUE 03/01/32
+-RINCIPAL PAYMENT 10-25-03
+FANNIE MAE CMO/SERIES 2002-82
+RECAL RUN 102503
+SYMBOLCUSIP
+027
+-971
+-1,843,000
+-719
+598,004
+94
+-804,857
+PRICE
+-749,315
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+September 30,2003
+169,307.00
+
+
+10 of 14
+INVESTMENT ACTIVITY (continued)
+SATEMENT TREE
+10/27/03
+TRANSACTION
+TOTAL
+DATE
+10/01/03
+AVG BAL
+992 RT
+021 OFFICE INTEREST 0903
+10/02/03
+10/02/03 AVG BAL 379,748RT L
+021 OFFICE INTEREST 0903
+"FEDERAL HOME LOAN MIG CORP
+ERIES 2471 CLASS Y
+TEREST PAYMENT 10-19-0
+i0/15/03
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2483 CL SL
+DUE 03/15/2032
+INTEREST PAYMENT 10-15-03
+EDERAL HOME LOAN MG CORI
+MERE PRIEST 09. 03
+i015/03
+DERAL HOME LOAN MTG CO
+DUE 02/15/2032
+NETO P 89-03-2800
+Bear, Stears & Co. Inc.
+FEDERAL NATIONAL MIG ASSN
+SERIES 2003-49 CLASS SW
+,880 DUE 01/25/3
+RINCIPAL REDUCTN 10-25-0
+SYMBOL/CUSP
+RATE (%)
+1.0000
+5.8800
+027
+-498,148
+PRICE
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2003
+CRECIT AMOUNT
+$-141.869.725.15
+$139,264,619.50
+72:96
+...
+36,093.61
+123.243.11
+124,991.77
+148,356.10
+{9996L00V||
+
+11 of 14
+INTEREST (continued)
+DATE
+10/27/03
+i0127/03
+FEDERAL HOME LOAN MG CORP
+AVERT PRIES 80403
+FANNIE ME MOISERIES 2002-82
+SK-I/O FLTR
+INTEREST PENT 1025.03
+FEDERAL NATIONAL MG ASSN
+SERIES 2003-49 CLASS SW
+JUE 01/25/203:
+TEREST PANT 10-03
+TOTAL
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS
+with Bear, Stearns& Co.Inc.
+SETTLEMENT
+DATE
+10/02/03
+TRADE
+DATE
+TRANSACTION
+8.605 01
+1002l
+8 625 01
+10/02
+DUE 12/31/2040 9.625
+EITM_PR
+...............................
+8 635 П1l
+
+RATE (%)
+5.8800
+5.8800
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2003
+59,584.42
+... ..
+89,757.59
+97,174.55
+$679,297.41
+4,396,000.00
+4,396.000.00
+50.3
+
+
+12 of 14
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+SETLEMENT
+10/06
+TRADE
+DATE
+TRANSACTION
+8 625 Dl
+10/15/
+10/15/
+1016L
+0/16/0
+0/16/
+10/16/03
+DUE 12/31/2019 8625
+EITM-PR
+8 625 01l
+
+
+VE 12312019
+TM-F
+8.625 DI
+23148
+8 605 01
+(231149
+8 625 Cl
+03149
+฿ 625 0l
+W3149
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2003
+4,396,000.00
+323.5g
+4,296,000.00
+698.10
+1,520,000000
+1.520,000.00
+027
+'1,520,000.00
+1,520,000.00
+3.220,000.00
+
+
+13 of 14
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+SETLEMENT
+TRADE
+DATE
+TRANSACTION
+10/16/
+DUE 12/31/2019 8625
+EITM-PR
+10/20/03
+8.625 D1
+a0s149
+10/20/
+8.625 01
+50731/49
+10/20
+10123/03
+10/23/03
+DUE 12/312019 8 625
+EITM-PR
+.............
+DERAL HOME LOAN MIG CO
+ME 2530 LAS SE
+REPO AGREEMENT A1
+HE ONE MIG CORP
+TERM REPO AGHEEMENT
+0/23/D
+TOTAL
+'3,000,000.00
+-22,790,161
+26,471,971
+-3,681,809
+$-17,952,000.00
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2003
+31.67
+3.220.000.00
+34.3
+$19,349,538.03
+
+
+14 of 14
+MISCELLANEOUS
+DATE
+MO/DAY
+10/06/03
+10/10/03
+10-14/03
+TRANSACTION
+URNA
+10/20/03
+10/21/03
+TOTAL
+FITG TO FITM
+FITG FITM
+"SEP 03 SPEC CLEARING FEES
+FA-30YR(FNMA) GTD
+SETT. 10/03
+FIT FITM
+FIG FITM
+Trades Executed Pending Settlement
+TRANSACTION
+11/13/03
+10/07/03
+11/13/03
+10/16/03
+"SOLD
+TOTAL
+FNMA-30YR(FNMA)GTD
+SETT, 11/03
+DIE 1100102033_05.500%
+HEF #L
+NMA-30VR(FNMAJGTD
+SETT, 11/03
+DUE L9102033.05.500%
+REF TA
+The above trades do not appear in any ather section of this statement.
+BS
+BS
+1,338.00
+69,463.00
+1,050.00
+38.459.00
+126,398.00
+$-236,708.00
+CRECIT AMOUNT
+1,214,062.50
+$1,214,062.50
+SYMBOL/CUSIP
+40,000,000.00
+40,000,000.00
+PRICE
+100.5937
+100.1250
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2003
+40,237,500.00
+40,050,000.00
+$40,050,000.00
+$40,237,500.00
+
+
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summar..............................
+Your Portfolio Holdings
+Transaction Detail .....
+Trades Not Yet Settled
+Bear, Stears & Co. Inc.
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 29, 2003
+4
+13
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+13.466.661
+203,166
+992
+NET EQUITY THIS PERIOD
+$13.670.819
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+13,836,583
+-165,764
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account
+Cash & Equivalent
+Fixed
+Income
+Market Value of Your Portfolio
+$992
+$244
+Current market value
+Last statement's market value
+Important Message
+$13.466,661
+$13,626,053
+statement. Effective this
+month, your account
+statement reflects all
+day of the month.
+SIP The suremen s four or ratanal furyce rear die Set revere date for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+Securities Bought
+Miscellaneous
+Amount Debited.
+Net Cash Activity
+Closing Balance
+THIS PERIOD
+- 3224.46
+176,098,821.93
+762,801.16
+$176,861,623.09
+•........
+- 175,152,227.06
+-1,708,648.44
+........ 176,860.875.50
+747.59
+$992.05
+Income Summary
+Govt. Agency Int.
+Corp. Bond Int.
+Credit Balance Int.
+Reverse Repurchase Int.
+Total
+Bond Purchase Int.
+Repurchase Int. Exp.
+THIS PERIOD
+663,909.77
+98,763.24
+128.15
+2,357.87
+5765,159.03
+Portfolio Composition
+Cash/Cash Equivalent
+Fixed Income
+Total
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+244.46
+$244.46
+CLOSING
+992.05
+992.01
+027
+YEAR TO DATE
+[ 790,874.92
+987,479.17
+931.45
+18,418.80
+--...
+58.797.704.34
+-50,156.82
+-24,344.52
+992
+13,466,661
+.$13.467,653
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 29,2003
+Your Portfolio
+Allocation
+Fixed Income-
+100%
+Unshaded portions denole debi balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+SERIES 2526 CLASS SI
+DATED DATE 10/01/02
+DUE 02/15/2032
+5,880%
+FACTOR - .47247166
+FEDERAL NATIONAL MTG ASSN
+STRIP MTG SERIES 322 CL PO
+DATED DATE 03/01/02
+DUE 03/01/2032
+FACTOR 110000000
+FEDERAL HOME LOAN MG CORP
+SERIES 2471 CLASS YT
+DATED DATE 06/07/02
+DUE 03/15/2032 1,000%
+FACTOR - .43312334
+FEDERAL HOME LOAN MTG CORI
+SERIES 2488 CLASS SO
+DATED DATE 07/08/02
+BOOK ENTRY ONLY.
+JE 03/15/2032.88
+CTOR - 436017
+SIMBCLCUSIP
+PRICE
+SYMEOLCUSP
+MRGN
+MAGN
+12,160,086
+2,311,383
+MAGN
+MAGN
+43,312,333
+21,800,888
+MARKE
+/ALUE
+992
+$992
+PRICE
+9.7796
+87.5781
+3.2974
+10.1749
+027
+ESTIMATE
+NUAL INCON
+URREN
+ELD I
+
+MARKET VALUE
+NTERE
+29,793
+992-202
+2
+1,428,182
+18,050
+2,218,219
+62,495
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 29, 2003
+ESTIMATE
+NNUAL INCOM
+715,013
+23
+433,123
+CURREN
+YIELD IS
+60.1252
+1,499,901
+30.3269
+67.6174
+vaTa
+
+
+Your Portfolio Holdings (continued)
+Government & Agency Obligations (continued)
+FEDERAL HOME LOAN MTG CORP
+SERIES 2483 CL SL
+DATED DATE 07/02/02
+436015,880%
+SYMBOLCUSP
+FACTOR 2085890%
+Total Government& Agency Obligations
+Corporate Bonds
+FANNIE MAE CMO/SERIES 2002-82
+SYMBOLCUSP
+Bear, Steams & Co. Inc.
+MAGN
+25,151,656
+MRGN
+19,831,541
+ACCE
+MAGN
+15,542,438
+TOTAL FIXED INCOME
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+99886
+PRICE
+MARKET VALLE
+ACCRUED
+NTERES
+61,619
+10.4766
+2,077,667
+16,225
+$11,411,577
+$188,184
+CORUE
+14,982
+$14,982
+$203,166
+PRICE
+13.2224
+MARKET VALUE
+2,055,084
+$2,055,084
+$13,466,661
+$203,166
+•.373,700
+$13,467,653
+027
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 29, 2003
+ESTIMATED
+ANNUAL INCOME
+1,478,917
+CURRENT
+YIELD INI
+59.7775
+1,168,078
+$5,295,055
+ESTIMATE
+NNUAL INCOM
+1,078,645
+$1,078,645
+П.373,700
+.....
+56.2207
+SURREN
+(ELD 15
+52.4867
+
+
+Transaction Detail
+INVESTMENT ACTIVITY
+SATE EMENT TATE
+DATE
+TRANSACTION
+09/15/03
+08/04/03
+CANCEL SELL
+09/15/03
+06/17/03
+09/15/03
+09/15/03
+08/04/03
+06/17/03
+SOLD
+CANCEL BUY
+09/15/03
+07/28/03 BOUGHT
+09/15/03
+07/28/03
+FNMA-30YR(FNMA)GTD
+SEE 08032022,05,000%
+TO CXL PREVIOUS SELL
+FNMA-30YR(FNMA)GTD
+SET 02032032,05,000%
+REF #
+NMA-30YR(FNMA)GTD
+SET: 0903203,05.000%
+REF T
+FNMA-30YR(FNMA)GTD
+SETT 09/03
+0ÜE 09/012033 05,000%
+"FNMA 3OYR GTO
+SET: 09093023,05,500%
+NMA 30YR GTD
+ETT. 09/0
+DUE 0901/2023 05,500%
+REF #1
+BS
+BS
+BS
+BS
+BS
+BS
+SYMBOL/GUSP
+027
+10,000,000
+PRICE
+94.98438
+10,000,000
+0,000,000
+10,000,000
+101.46875
+94.98438
+101.46875
+10,000,000
+100.10938
+10,000,000
+100.10938
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 29,2003
+9,498,437.50
+10,146,875.00
+9.498,437.50
+10,146,875.00
+10,010,937.50
+10,010,938.00
+
+
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TRIE
+DATE
+TRANSACTION
+09/15/03
+07/07/03
+09/15/03 07/29/03 BOUGHT
+09/15/03
+09/03/03
+CANCEL SELL
+09/15/03
+07/28/03
+CANCEL BUY
+Bear, Stears & Co. Inc.
+09/15/03
+' 07/28/03
+*'''CANCEL BUY
+09/15/03
+07/07/03
+CANCEL BUY
+FNMA 3OYR GTD
+SETT, 09/03
+DUE hGin112033 05,500%
+REF #1
+... ..
+NMA 30YR GTO
+SET 00032023,05,500%
+REF #1
+FNMA 30YR GTD
+SETT. 09/03
+nUE nan 12032,05.500%
+AS OF USTUSTU
+TO CXL PREVIOUS SELL
+FNMA SOYA GTD
+SETT, 09/03
+DUE nsi0112033 12033,05,500%
+HOOL REHOUS BUN
+ST 090302 05,500%
+EFFi
+S OF 0712810:
+TO CXL PREVIOUS BUY
+SET 91003022,05,500%
+BS
+BS
+BS
+BS
+BS
+BS
+SYMBOL/GUSP
+027
+20,000,000
+35,000,000
+65,000,000
+PRICE
+102.25000
+99.48438
+98.80078
+- 10,000,000
+100.10938
+-10,000,000
+100.10938
+20,000,000
+102.25000
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD August 30,2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 29, 2003
+20,450,000.00
+34.819.531.25
+64,220,507.81
+10,010,937.50
+10,010,938.00
+20,450,000.00
+
+
+INVESTMENT ACTIVITY (continued)
+SETLEMENT TATE
+DATE
+TRANSACTION
+09/15/03
+07/29/03
+CANCEL BUY
+09/15/03
+09/15/03
+....
+09/15/03
+09/15/03
+9/15/0
+9/15/0
+09/15/03
+09/03/03
+SOLD
+PAINCIPAL
+FNMA 3OYR GTD
+ETT, 09/0:
+TEh9n12033 05,500g
+BS
+TO CXL PREVIOUS BU
+"ENMA SOYA GTD
+SET 09012022,05,500%
+REF #H
+BS
+SERIES 2471 CLASS YT
+1.000 DUE 03/15/32
+PRINCIPAL REDUCTN 09-15-03
+.. . ..
+FEDERAL HOME LOAN MIG CORF
+SERIES 2471 CLASS YT
+.000 DUE 03/15/3
+RINCIPAL REDUCTN 09-15-0:
+SERIES 2483 CL SL
+880 DUE 03/15/
+INCIPAL REDUCTN 09-15-
+SERIES 2483 CL S
+5,880 DUE 03/15/32
+PRINCIPAL REDUCTN 09-15-03
+"FEDERAL HOME LOAN MIG CORP
+RIES 2488 CLASS
+880 DUE 03/15/:
+RINCIPAL REDUCTN 09-15-03
+FEDERAL HELD I MIC CORR
+,880 DUE 03/15/32
+INCIPAL REDUCTN 09-15-03
+SYMBOL/GUSP
+027
+35,000,000
+PRICE
+99.48438
+-65,000,000
+# 205,000
+-487
+3,603,000
+553
+3,123,000
+479
+98.80078
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 29, 2003
+34,819,531.25
+64.220,507.81
+
+
+INVESTMENT ACTIVITY (continued)
+SETTLEMENT TRADE
+09/15/03
+TRANSACTION
+09/15/03
+09/25/03
+09/25/03
+09/25/03
+09/25/03
+09/25/03
+TOTAL
+SERIES 2526 CLASS SI
+PRINCIPAL REDUCTN 09-15-03
+FEDERAL HOME LOAN MG CORP
+SERIES 2526 CLASS SI
+6,880 DUE 02/15/32
+RINCIPAL REDUCTN 09-15-03
+EDERAL NATIONAL MIG ASS
+STRIP MG SERIES 322 CL PO
+1.001 DUE 03/01/32
+PO 80 0000-25-03
+FANNIE MAE CMO/SERIES 2002-82
+MANG A MEET 09 2503
+INNIE MAE CMOVSERIES 2002-
+K-VO FLTR
+INCIPAL DEN 09-250:
+5,880 DUE 01/25/33
+PRINCIPAL REDUCTN 09-25-03
+FEDERAL NATIONAL MTG ASSN
+SERIES 2003-49 CLASS SW
+5.880 DUE 01/25/33
+PRINCIPAL REDUCTN 09-25-03
+SYMBOL/CUSIP
+027
+-1,601,000
+-287
+PRICE
+-1,534,000
+778
+-1,090,000
+510
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD August 30,2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+August 29, 2003
+307, 237.00
+$-159,157,227.06
+$159,464,464.06
+
+
+10 of 13
+DATE
+09/02/03
+AVG BAL 488.921RT
+021 OFFICE INTEREST 0803
+09/15/03
+"FEDERAL HOME LOAN MIG CORP
+HERE RAINS SOS
+09/15/03
+FEDERAL HOME LOAN MG CORP
+SERIES 2483 CL SL
+DUE 03/15/2032
+TEREST PAYMENT 88-15-03
+09/15/03
+.........
+FEDERAL HOME LOAN MTG CORP
+SERIES 2488 CLASS SO
+NTEREST PAYMENT 09.15.0
+09/15/03
+FEDERAL HOME LOAN MG CORP
+Bear, Stears & Co. Inc.
+SYMBOUGUSIP
+09/15/03
+SERIES 2526 CLASS S
+INTEREST PAYMENT 09.-150:
+0925/03
+..........
+SA NO FATE MOISERIES 2002-82
+INTEREST PAYMENT 08.25-03
+09125/03
+... . .
+:DERAL NATIONAL MTG ASS
+SERIES 2003-49 CLASS SW
+DUE 01/25/2033
+5,880
+INTEREST PAYMENT 09-25-03
+TOTAL
+RATE (%)
+1.0000
+5.8800
+5.8800
+.880
+027
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 29, 2003
+128.15
+41,264.85
+141,140.15
+......
+9969189L
+----67,545.40
+....
+3,763.
+... . .
+02.692.
+$762,801.16
+
+
+11 of 13
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS
+with Bear, Stearns & Co. Inc.
+SETTLEMENT
+TRADE
+DATE
+TRANSACTION
+09/057
+8 625 0l
+09/05/03
+8,625 DI
+a0s149
+09/11/03
+09/12/03
+DUE 12/31/2019 8 625
+EITM-PR
+...............
+FEDERAL NATIONAL MG ASSN
+TRIP MTG SERIES 322 CL PI
+1.001_ DUE 03/01R
+TERM REPO AGREEMENT
+8.625 0lz
+0912L
+FITM-PR|
+8 625 D1l
+09/1211
+9/29/
+BUT 123220 2625
+....
+8 625 Dl
+2,311,383
+027
+--..
+5,033,000.00
+3,283,000.00
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 29,2003
+5.033.000.00
+685.05
+5,033,000.00
+327.7
+3.283,000.00
+
+
+Bear, Steams & Co. Inc.
+12 or 13
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+TRADE
+DATE
+09/29/03
+TRANSACTION
+8 625 Dls
+09/29
+8 625 01
+a0s149
+09/29/03
+8 625 D1
+S0/31/49
+09/29
+UE 12/312019 9 62
+MM-P
+TOTAL
+MISCELLANEOUS
+DATE
+MODAY
+09/12/03
+TRANSACTION
+19/12/0
+OURNA
+09/15/03
+TOTAL
+JOURNALI
+FNMA-30YR(FNMA)GTD
+SETT. 09/00
+MBS NET 0901203
+FRMA 30YR GTD
+SETT. 09/03
+MBS NET 0012033
+"AUG 03 SPEC CLEARING FEES
+648,437.50
+1,059,960.94
+250.00
+$-1,708,648.44
+027
+3,283,000.00
+4.396,000.00
+$-15,995,000.00
+CRECIT AMOUNT
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 29, 2003
+3.283,000.00
+1,045.09
+$16,634,357.87
+
+
+Trades Executed Pending Settlement
+SALEMENT DRES
+TRANSACTION
+09/30/03
+10/15/03 09/03/03
+*'BOUGHT
+0/15/0
+09/04/03
+SOLD
+09/05/03
+"SOLD**
+09/05/03
+SOLD
+09/05/03
+CANCEL SELL
+TOTAL
+FEDL HOME LOAN MIG
+SERIES 223 CLASS PO
+DiE: 1201120221
+REF #
+BS
+FNMA 30YR(FNMA) GTD
+T, 10/0
+iE 10101/2033 05.500
+HEF#
+BS
+FNMA-30YR(FNMA) GTD
+SETT, 10/O
+JIE 1010102033_05,500
+REF #1
+BS
+•....//.............
+NMA-30YR(FNMA) G1
+SET: 003202,05.500%
+BS
+SETT, 10/03
+DIE 1010172033,05,500%
+HEF #1
+FNMA-30YR(FNMA) GTD
+SETT, 10/03
+DiE 1010112023 05,500%
+LEFT
+IS OF USTUSTUS
+BS
+BS
+The above trades do not appear in any ather section of this statement.
+SYMBOLCUSIP
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD August 30,2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+August 29, 2003
+2,872,070.30
+63.964,062.50
+3,489,227.00
+65,000,000.00
+15,000,000.00
+10,000,000.00
+PRICE
+82.3125
+98.4062
+98.9687
+# 99.5312*•
+4,845,312.5
+9,953,125.00
+-10,000,000.00
+- 10,000,000.00
+99.5312
+99.5312
+9,953, 125.00
+9,953,125.00
+$76.789,257.80
+$34,751,562.50
+027
+vaTa
+
+
+Bear, Stears & Co. Inc.
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary .............................
+Your Portfolio Holdings
+Transaction Detail .....
+Trades Not Yet Settled
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 25, 2003
+4
+13
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+13,626.053
+210.286
+244
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+$13,836,583
+••••••••••••
+19,252,646
+-5,416,063
+ere are no "Stop Loss" orders or other pending bu
+r sell open orders on file for your accoun
+Market Value of Your Portfolio
+$244
+$531,555
+Cash & Equivalent
+Fixed
+Income
+$13,626.053
+$18,500,041
+Current market value
+Last statement's market value
+Important Message
+Bear Stearns is pleased to
+announce our conversion to
+a calendar month-end
+statement. Effective
+September 2003,your
+account statement will
+reflect all activity and
+account valuation up to and
+including the last business
+day of the month.
+SIP The suremen s four or ratanal furycer rear die Set revere date for portant formation.
+
+
+2 of 14
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+08/30/03:13:15 001
+
+
+3 or 14
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERICO
+5531,555.12
+37,638,376.55
+887,353.09
+529,666.62
+.......
+$39,055,396.26
+•••
+-36,628,000.00
+-2,958,706.92
+6 39.586.706.92
+-531,310.66
+.............
+$244.46
+Income Summary
+Govt. Agency Int.
+Corp. Bond Int.
+Credit Balance Int.
+Reverse Repurchase Int.
+Total
+Bond Purchase Int.
+Repurchase Int. Exp.
+THIS PERIOD
+774,898.10
+112,413.41
+41.58
+3,376.55
+5890.729.64
+YEAR TO DATE
+1. 126,965.15
+888,715.93
+803.30
+16,060.93
+........
+$8.032.545.31
+-50,156.82
+-24,344.52
+Portfolio Composition
+Cash/Cash Equivalent
+Fixed Income
+Total
+244
+13,626,053
+... 13.626.297
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+531,555.12
+$531,555.12
+CLOSING
+244.46
+......
+$244.46
+027
+09/30/03:13:15 001
+EARED THROUGH
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 25, 2003
+Your Portfolio
+Allocation
+Fixed Income-
+100%
+Unshaded portions denole debi balance and'or short
+
+
+4 of 14
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+FEDERAL HOME LOAN MG CORP
+RIES 2526 CLASS
+TED DATE 10/01/0
+LE 02/15/2032
+ACTOR
+253465990%
+FEDERAL HOME LOAN MG CORP
+SERIES 2471 CLASS VT
+DATED DATE 06/07/02
+FACTOR 152095176290%
+SERIES 2488 CLASS SQ
+DATED DATE 07/08/02
+EDERAL HOME LOAN MTG COR
+ERIES 2483 CL SI
+DATED DATE 07/02/02
+UE 03/15/2032 5,890
+ACTOR - .4984873
+Bear, Steams & Co. Inc.
+SIMBCLCUSIP
+PRICE
+SYMBOLCUSP
+MRGN
+13,761,373
+MAGN
+49,517,820
+MAGN
+24,924,367
+MAGN
+28,755,209
+WAKE
+/ALUE
+244
+$244
+PRICE
+10.2416
+11.2050
+04945
+10.4299
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 25, 2003
+ESTIMATE
+NUAL INCON
+MARKET VALLE
+1,409,390
+31,523
+ESTIMATE
+INNUAL INCOM
+810,545
+57.5103
+2,792,769
+2,999,138
+19,260
+66,780
+65,864
+495,178
+1.717,289
+1,693,682
+26.5467
+61.4905
+56.4723
+09:3003;13:15 001
+
+5 or 14
+Your Portfolio Holdings (continued)
+Government & Agency Obligations (continued)
+ESCRIPTION
+EDERAL NATIONAL MG ASSN
+SYMBOLCUSP
+PAT 09290%
+Total Government& Agency Obligations
+Corporate Bonds
+SA SERIES 2002-82
+BOOK ENTRY ON0202
+SYMEOLCUSIP
+Total CorporateBands
+TOTAL FIXED INCOME
+Bear, Steams & Co. Inc.
+MRGN
+20,922,051
+MRGN
+17,077,216
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+10.5008
+MARKET VALLE
+2,196,815
+13,692
+$11,263,424 $197,119
+PRICE
+13.8350
+MARKET VALUE
+2,362,629
+ACCRUED
+13,167
+$2,362,629
+$13,626,053
+$13,167
+$210,286
+$210,286
+П.134,162
+$13,626,297
+120
+08/30/03:13:15001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 25, 2003
+ESTIMATED
+ANNUAL INCOME
+1,232,309
+CURRENT
+YIELD IS
+56.0953
+$5,949,003
+ESTIMATED
+ANNUAL INCOME
+1,185,159
+CURRENT
+YIELD IN
+50.1627
+$1,185,159
+L. 134,162
+
+
+I or 1a
+Transaction Detail
+INVESTMENT ACTIVITY
+SETLEMENT TREE
+08/07/03
+TRANSACTION
+08/15/03
+0815/03
+......
+08/15/03
+....
+08/15/03
+08/15/03
+08/15/03
+....
+08/15/03
+PRINCIPA
+08/15/03
+Bear, Steams & Co. Inc.
+ERIES 2530 CLASS SI
+.293 DUE 02/15/3
+*FEDERAL HOME LOAN MTG CORP
+SERIES 2471 CLASS YT
+,000 DUE 03/15/3
+RINCIPAL REDUCTN 08-15-0
+FEDERAL HOME LOAN MIG CORF
+SERIES 2471 CLASS YT
+1,000 DUE 03/15/32
+PRINCIPAL REDUCTN 08-15-03
+.. . ..
+FEDERAL HOME LOAN MTG CORP
+SERIES 2483 CL SL
+5.890 DUE 03/15/32
+PRINCIPAL REDUCTN 08-15-03
+'EDERAL HOME LOAN MIG COR
+SERIES 2483 CL SL
+5,890 DUE 03/15/3
+PRINCIPAL REDUCTN 08-15-0:
+ERIES 2488 CLASS SO
+.890 DUE 03/15/32
+PRINCIPAL REDUCTN 08-15-03
+FEDERAL HOME LOAN MTG CORF
+SERIES 2488 CLASS SQ
+.890 DUE 03/15/32
+RINCIPAL REDUCTN 08-15-0:
+.....
+SEN A RUN 0 1503
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2526 CLASS SI
+5,890 DUE 02/15/32
+PRINCIPAL REDUCTN 08-15-03
+SYMBOLGUSIP
+220
+PRICE
+8.957,000
+.....
+-892
+-5,201,000
+-886
+4,508,000
+878
+-2,496,000
+-782
+093003;13:15 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 25, 2003
+
+
+I or 1e
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+08/25/03
+TRANSACTION
+08/25/03
+08/25/03
+0B/25103
+TOTAL
+DATE
+07/28/03
+0815/03
+146,204RT
+021 OFFICE INTEREST 0703
+08/15/03
+UE 03/15/203
+TEREST PAYMENT 08-15-0:
+*FEDERAL HOME LOAN NIG CORP
+SERIES 2483 CL SL
+INTEREST PAYMENT 08-19-03
+Bear, Stears & Co. Inc.
+FANNIE MAE CMO/SERIES 2002-82
+MAN PA RECT O8 2503
+....
+ANNIE MAE CMO/SERIES 20028
+SK-VO FLTR
+PANGA PAL DIE 08 25-03
+SEES 202 19 4A5 SASS
+900 DUE 01/25/3
+RINCIPAL REDUCTN 08-25-0
+"FEDERAL NATIONAL MIG ASSN
+SERIES 2003-49 CLASS SW
+5.900 DUE 01/25/33
+PRINCIPAL REDUCTN 08-25-03
+SYMBOLCUSIP
+RATE (%)
+1.0000
+5.8900
+027
+-2,1,000
+-292
+-1,801,000
+-520
+PRICE
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 25, 2003
+CAEDIT AMOUNT
+41.58
+48,729.76
+166,761.03
+
+
+Bear, Stears & Co. Ine.
+8 of 14
+INTEREST (continued)
+DATE
+08/15/03
+08/15/03
+ö818/03
+••••***•••
+08/25/03
+08/25/03
+FEDERAL HOME LOAN MG CORP
+AVERS RNA 8180S
+FEDERAL HOME LOAN MTG CORP
+SERIES 2526 CLASS SI
+I SENT 08: 19-03
+FEDERAL HOME LOAN MG CORP
+SUE 021520 CLASS SE90
+UE 02/15/203
+- 15 REPO PYN
+*FANNIE MAE COISERIES 2002-82
+SK-I/O FLTR
+DUE 10/25/2031
+NTEREST PAYMENT 08-25-03
+"FEDERAL NATIONAL MTG ASSN
+SERIES 2003-49 CLASS SW
+DUE 01/25/2033
+5,900
+NTEREST PAYMENT 08-25-03
+TOTAL
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS
+with Bear, Stearns& Co.Inc
+SETTLEMENT
+DATE
+07/29/03
+TRADE
+DATE
+TRANSACTION
+8 625 011
+P)3149
+1625 C=
+32314:
+RATE (%)
+5.8900
+5.9000
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 25, 2003
+169,072.41
+79,842.71
+198,767.97
+112,413.41
+111.724.22
+$887,353.09
+4,185,000.00
+
+
+9 or 14
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+BELEMENT
+07/29/
+TRADE
+DATE
+TRANSACTION
+DUE 12/31/2019 8.625
+SYMBOUGUSIP
+07/30/03
+8,625 DI
+a03149
+
+07/30"
+07731/03
+07/31
+8 625 01
+*PS149
+DUE 12312019 8625
+EITM-PR
+.....
+8 625 D
+........
+8.625 D
+03145
+37/317
+
+HE 121312010 8629
+"FEDERAL HOME LOAN NIG CORP
+SERIES 2530 CLASS SE
+1,293 DUE 02115/3
+FITMARGN
+REPO AGREEMENT
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT July 25, 2003
+1,256.66
+4,185.000.00
+84.86
+3.880.000.00
+84.07
+37,901,958
+027
+•...
+3.880,000.00
+3.000.000.00
+
+
+10 of 14
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+BELEMENT
+08/08
+TRADE
+DATE
+TRANSACTION
+8 625 0l
+08/08/03
+08/087
+0828L
+08/28/03
+08/28/1
+08/28/03
+8 625 01
+a0s149
+8 625 01l
+
+
+UF12342019
+TM-P
+8.625 D1
+2310E
+8 605 D1
+0231/49
+8 625 Cl
+03149
+• 625 ПЛ
+W3149
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 25, 2003
+3,000,000.00
+3.000.000.00
+464.17
+3.765,000.00
+3.765.000000
+027
+.. . .
+.000,000.00
+*3,765,000.00
+3,765,000.00
+5,000,000.00
+
+
+Bear, Steams & Co. Inc.
+11 of 14
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+BELEMENT
+08/287
+TRADE
+DATE
+TRANSACTION
+DUE 12/31/2040 8 625
+EITM-PR
+08/29
+8,625 DI
+a03149
+08/29/03
+8.625 01l
+50731/49
+08/29/
+....
+08/29/03
+0829L
+
+......
+8 625 D
+23145
+ADP CD"
+DUE 12/312019 8 625
+EITM_PR
+TOTAL
+MISCELLANEOUS
+DATE
+MODAY
+TAMNSACTION
+07/29/03
+07/30/03
+JOURNAL™
+07/31/03 JOURNAL
+FITM TO FITG
+FIT TO FITG
+FIM TO FITG
+SYMBOUGUSIP
+•''5,000,000.00
+5.033.000.00
+$-36,628,000.00
+531,596.00
+1,856,257.00
+305,085.00
+CRECIT AMOUNT
+027
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 25,2003
+1,390.96
+,000,000.00
+5,000,000.00
+95.83
+$37.638,376.55
+
+
+12 of 14
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+08/01/03
+08/11/03
+0818/03
+TRANSACTION
+OURNA
+0819/03
+08/19/03
+0B/21103
+08/27/03
+FITM TO FITG
+ITG TO FITI
+SERIES 2471 CLASS YT
+1,000 DUE 03/15/32
+P&I TRNFR
+JULY O3 SPEC CLEARING FEES
+... ..
+FEDERAL HOME LOAN MIG CORI
+SERIES 2471 CLASS Y
+.000 DUE 03/15/3
+81 TANF
+"FEDERAL HOME LOAN MG CORP
+SERIES 2471 CLASS Y
+1.000 DUE 03/15/32
+P&I TRNFR
+ADJ, DUPE
+... . .
+FEDERAL NATIONAL MG ASSN
+250,000.00
+1,150.00
+14,618.92
+TOTAL
+$-2,958,706.92
+027
+CRECIT AMOUNT
+134,451.00
+1.309.46
+1,309.46
+380,596.70
+$529,666.62
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 25, 2003
+
+
+13 of 14
+Trades Executed Pending Settlement
+SETLEMENT TREE
+TRANSACTION
+09/15/03 06/17/03
+09/15/03 08/04/03
+SOLD
+9/15/03
+07/07/03
+09/15/03
+07/28/03
+09/15/03
+07/28/03
+09/15/03
+07/29/03
+FNMA-30YR(FNMAIGTD
+ETT,09/0:
+= PGN0112022.05.000%
+REF #1
+FNMA 30YR(FNMAGTD
+SEE 03072023,05,000%
+REF #1
+FNMA 30YR GTD
+SETT, 09/03
+DIE 09M01/2033_05,500%
+REF #
+SET: 0803022.05,500%
+REF #
+"ENMA 3OYA GID"
+ETT, 09/0:
+HE 09M11/2038 05,500
+AS OF O72Er03T
+FNMA 30YR GTD
+SETT, 09/03
+DIE 09M 112023 05.500%
+HEF #F
+BS
+BS
+BS
+BS
+BS
+BS
+SYMBOL/CUSIF
+10,000,000.00
+PRICE
+101.4687
+10,000,000.00
+20,000,000.00
+94.9843
+102.2500
+10,000,000.00
+100.1093
+10,000,000.00
+100.1093
+35,000,000.00
+99.4843
+027
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 25, 2003
+10,146,875.00
+9,498,437.50
+20,450,000.00
+10,010,938.00
+10.010,937.50
+34,819.531.25
+
+
+14 of 14
+Bear, Stears & Co. Inc.
+Trades Executed Pending Settlement
+(continued)
+SETLEMENT TREE
+09/15/03
+07/28/03
+TRANSACTION
+CANCEL BUY
+FNMA 3OYR GID
+ETT, 09/03
+NE hal112033_05.500
+BS
+TOTAL
+The above trades do not appear in any other section of this statemere.
+STOP
+****** End of Statement******
+SYMBOL/CUSIP
+10.000,000.00
+PRICE
+100.1093
+027
+08/30/03:13:15 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 25, 2003
+10,010,938.00
+$85,438,281.75
+$19,509,375.50
+
+
+Bear, Steams & Co. Inc.
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary....
+Your Portfolio Holdings
+Transaction Detail .....
+.......
+Trades Not Yet Settled
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 27, 2003
+4
+12
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+18,500,041
+221,050
+531,555
+S19,252,646
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+20,131,089
+-878,443
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$531,555
+$83,953
+Cash & Equivalent
+Fixed
+Income
+$18,500,041
+• $19,744,476
+Current market value
+Last statement's market value
+SIP The suremen s four or ratanal furyce rear die Set revere date for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+07/26/03:10:09 001
+
+
+3 or 12
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Funds Withdrawn
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+Bear, Steams & Co. Inc.
+THIS PERICO
+83,953.25
+....•...
+57,559,955.57
+958,046.83
+10,330.47
+$58,528,
+-57,908,750.00
+-77,381.00
+-94,600.00
+$-58,080,731.00
+447,601.87
+$531,555.12
+Income Summary
+Govt. Agency Int.
+Corp. Bond Int.
+Credit Balance Int.
+Reverse Repurchase Int.
+Total
+Bond Purchase Int.
+Repurchase Int. Exp.
+THIS PERIOD
+834,952.46
+122,918.54
+175.83
+2,119.97
+960,166.8
+YEAR TO DATE
+[ 352,067.05
+776,302.52
+761.72
+12,684.38
+... .
+.:141.815.67
+-50,156.82
+-24,344.52
+Portfolio Composition
+Cash/Cash Equivalent
+Fixed Income
+Total
+531,555
+18,500,041
+.. 519,031,596
+Cash Balance Summary
+Margin
+Net Cash Balance
+OFENING
+83,953.25
+$83,953.25
+CLOSING
+531,555.12
+.....
+$531,555.12
+027
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 27, 2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+2%
+- Fixed Income
+98%
+Unshaded portions denote debit balance and or shart
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SIMBCLCUSIP
+FIXED INCOME
+Government & Agency Obligations
+FEDERAL HOME LOAN MG CORP
+RIES 2530 CLASS
+TED DATE 10/11/0
+FACTOR S 6369303%
+SERIES 2526 CLASS SI
+DATED DATE 10/01/02
+DUE 02/15/2032
+AT 2069303%
+SERIES 2471 CLASS YT
+DATED DATE 06/07/02
+DUE 03/15/2032
+FACTOR 52584757030%
+DERAL HOME LOAN MTG COL
+RIES 2488 CLASS :
+DATED DATE 07/08/02
+FACTOR 52588661993%
+SIMEOLCUSP
+Bear, Steams & Co. Inc.
+PRICE
+MRGN
+MRGN
+37,901,953
+16,258,155
+MAGN
+MAGN
+58,475,712
+29,433,245
+MARKET
+VALUE
+531,555
+$531,555
+9189'6
+PRICE
+9.5702
+3.7118
+10.1225
+027
+STIMATE
+ANUAL INCON
+MARKET VALUE
+3,669,527
+892'99
+1,555,931
+26,612
+2,170,484
+16,240
+2,979,394
+56,355
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 27,2003
+ESTIMATE
+INNUAL INCOM
+2,385,170
+CURREN
+64.9994
+958,093
+584,757
+2,028,834
+8925 19
+26.9413
+68.0955
+88996
+
+Your Portfolio Holdings (continued)
+Government & Agency Obligations (continued)
+SERIES 2483 CL SL
+BOOK ENTRY ONE 202
+FACTOR 2533
+SYMBOLCUSP
+PACT 39335-35%
+Total Government& Agency Obligations
+Corporate Bonds
+FANNIE MAE CMO/SERIES 2002-82
+SYMBOLCUSP
+Bear, Steams & Co. Inc.
+MAGN
+DUANTIT
+33,957,095
+MRGN
+22.723,571
+ACCT
+MAGN
+19,409,508
+TOTAL FIXED INCOME
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+PRICE
+9.6934
+10.0781
+MARKET VALLE
+3.291.586
+NOCRUEL
+NTERES
+55,585
+2,290,110
+$15,957,032
+$221,050
+PRICE
+13.1019
+MARKET VALUE
+2,543,009
+$2,543,009
+$18,500,041
+$221,050
+$10,674,984
+$19,031,596
+027
+$221,050
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOO June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 27,2003
+ESTIMATED
+ANNUAL INCOME
+2.001,092
+CURRENT
+YIELD IN
+60.7942
+1,355,461
+$9,313,407
+ESTIMATE
+NNUAL INCOM
+1,361,577
+$1,361,577
+$10,674,984
+59.1876
+CURRENT
+YIELD I%
+53.5420
+
+
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TREE
+07/08/03
+TRANSACTION
+07/14/03 07/07/03
+"CANCEL SELL
+
+07/14/03
+07/4403
+0775/03
+07/5/03
+06/05/03
+07/07/03
+06/05/03
+SOLD
+CANCEL BUY
+FEDERAL NATIONAL MG ASSN
+MAR A RECT 2503
+SETT.07/03
+SUE 07/01/2033 05,500%
+TO CAL PREVIOUS SEL
+MA: 30YR(ENMA)GTD
+SETT.07/03
+DUE NZ01/2033.05,500%
+REF#
+FNMA-30YR(FNMA)GTD
+SETT.07/03
+DUE 07/01/2033 05,500%
+REF #1
+BS
+BS
+BS
+SETT. 07/03
+TUE 071012202305,500%
+REF E
+BS
+S OF DEVOSTUR
+O CXL PREVIOUS BU
+BEREAL HOLE LON MIC CORP
+1.000 DUE 03/15/32
+PRINCIPAL REDUCTN 07-15-03
+.. . . .
+DERAL HOME LOAN MIG CO
+RIES 2471 CLASS
+1.000 DUE 03/15/32
+PRINCIPAL REDUCTN 07-15-03
+SYMBOL/GUSP
+027
+-289,086
+20,000,000
+PRICE
+02.9375
+20,000,000
+-20,000,000
+03.40625
+102.93750
+-20,000,000
+103.40625
+-5,365,000
+-251
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 27, 2003
+20,587,500.00
+20.681,250.00
+20,587,500.00
+20,681,250.00
+
+
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+07/15/03
+TRANSACTION
+Bear, Stears & Co. Inc.
+SERIES 2483 CL SL
+5,893 DUE 03/15/32
+PRINCIPAL REDUCTN 07-15-03
+SERIES 2483 CL SL
+5,893 DUE 03/15/32
+RINCIPAL REDUCTN 07-15-03
+07/15/03
+07715/03
+07/5/03
+0745/03
+07/5/03
+07/15/03
+07715/03
+07/25/03
+,893 DUE 03/15/3
+RINCIPAL REDUCTN 07-15-0
+........ .
+EDERAL HOME LOAN MTG COR
+BANE PAL REDUCEN 07.1503
+FEDERAL HOME LOAN MTG CORP
+RECAL REDUCT 07.1503
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2530 CLASS SE
+1.293 DUE 02/15/32
+INCIPAL REDUCTN 07-15-03
+.. . .
+EDERAL HOME LOAN MIG COF
+SERIES 2526 CLASS SI
+5,893 DUE 02/15/32
+PRINCIPAL REDUCTN 07-15-03
+"FEDERAL HOMELAN MIG CORP
+SERIES 2526 CLASS SI
+5,893 DUE 02/15/32
+PRINCIPAL REDUCTN 07-15-03
+FEDERAL NATIONAL MTG ASSN
+STRIP MTG SERIES 322 CL PO
+_001 DUE 03/01/32
+ADJUST POSITION
+SYMBOL/GUSP
+027
+-3,665,000
+PRICE
+440
+-3,177,000
+-121
+3,772,000
+370
+-1,618,000
+-169
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 27, 2003
+
+
+INVESTMENT ACTIVITY (continued)
+SETTLEMENT TRADE
+07/25/03
+TRANSACTION
+07/25/03
+FEDERAL NATIONAL MG ASSN
+MR A AMENT 12503
+FANNIE MAE CMO/SERIES 2002-82
+REAT AREN O7 2503
+07/25/03
+07/25/03
+07/25/03
+EDERAL NATIONAL MG ASSA
+SERIES 2003-49 CLASS SW
+5,965 DUE 01/25/33
+PRINCIPAL REDUCTN 07-25-03
+FEDERAL NATIONAL MG ASSN
+SERIES 2003-49 CLASS SW
+5.965 DUE 01/25/33
+PRINCIPAL REDUCTN 07-25-03
+TOTAL
+DEPOSITS AND WITHDRAWALS
+DATE
+07/02/03
+TRANSACTION
+FND WIRED
+WIRED TO
+GTESTNATIOMAL BANKI
+TOTAL
+SYMBOLCUSP
+77,381.00
+$-77,381.00
+027
+PRICE
+-1,617,000
+-183
+-1,124,000
+371
+07/26/03:10:09 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+June 27,2003
+289,085.60
+$-41,268,750.00
+$41,557,835.60
+
+
+9 of 12
+Bear, Stears & Co. Inc.
+DATE
+06/30/03
+AVG BAL 447,172RT
+021 OFFICE INTEREST 0603
+0715/03
+"FEDERAL HOME LOAN MIG CORP
+ERIES 2471 CLASS Y
+TEREST PAYMENT 07-19.0
+07/15/03
+SERIES 2483 CL SL
+DUE 03/15/2032
+TEREST PAYMENT 31-95-03
+.........
+07/15/03
+FEDERAL HOME LOAN MTG CORP
+SERIES 2488 CLASS
+INTEREST PANE
+32004A35 029303
+07/15/03
+*FEDERAL HOME LOAN MG CORP
+NE 0ZT5/203
+A 0213200485 203
+07/15/03
+"FEDERAL HOME LOAN MIG CORP
+SYMBOUGUSIP
+07/25/03
+07/25/03
+TOTAL
+FANNIE MAE CMO/SERIES 2002-82
+SK-I/O FLTR
+DUE 10/25/2031
+INTEREST PAYMENT 01015-
+-25-03
+... . .
+FEDERAL NATIONAL MTG ASSN
+SERIES 2003-49 CLASS SW
+UE 01/25/203
+RATE (%)
+1.0000
+5.8930
+5.8930
+5.9650
+027
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIO June 28,2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 27, 2003
+175.83
+45,891.34
+182,469.29
+185,335.58
+86,700.17
+122,918.54
+118,544.14
+$958.046.83
+
+
+Bear, Steams & Co. Inc.
+New York. New York 10179
+10 of 12
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS
+with Bear, Stearns & Co. Inc.
+SALEMENT UN
+TRADE
+DATE
+TRANSACTION
+07/11/03
+FEDERAL NATIONAL MIG ASSN
+REPO AGREEMEN AT
+07/11/03
+1625 DIn
+37/117
+8 625 Пl
+17/117
+ADP CI
+DUE 12/31/2040
+625
+07/18
+07718/03
+"ADP CO
+8.625 DIl:
+8 625 D1l
+0778Ш
+8 625 DI
+*098143
+37/18/03
+8 625 0l
+28149
+-599,843
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 27, 2003
+5,300,000.00
+5,400,000.00
+1,429.50
+5,300,000.00
+5,300,000.00
+5,300,000.00
+T.040,000.00
+027
+
+
+Bear, Steams & Co. Inc.
+11 of 12
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+SETTLEMENT
+07/18
+TRADE
+DATE
+TRANSACTION
+DUE 12/31/2019 8625
+07/24/03
+07/24/03
+07/24/03
+EDERAL NATIONAL MIG ASSA
+TRIP MTG SERIES 322 CL PO
+TEAM REPO AGREEMENT
+FEDERAL NATIONAL MIG ASSN
+STRIP MTG SERIES 322 CL PO
+1.001 DUE 03101R
+REPO AGREEMENT
+FEDERAL HOME LOAN MG CORP
+SERIES 2471 CLASS YT
+1,000 DUE 03/1532
+TERM REPO AGREEMENT
+TOTAL
+MISCELLANEOUS
+07/11/03
+TRANSACTION
+07/14/03
+07/16/03
+JOURNAL*
+FNMA-30YR(FNMA)GTD
+SETT,07/03
+MBS NET 070710093
+JUNE O3 SPEC CLEARING FEES
+FEDERAL HOME LOAN MG CORP
+SYMBOUGUSIP
+599,843
+-2,999,217
+8.771,356
+$-16,640,000.00
+93,750.00
+850.00
+CRECIT AMOUNT
+8,098.47
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 27, 2003
+690.47
+$16,002,119.97
+
+
+12 or 12
+MISCELLANEOUS (continued)
+DATE
+MODAY
+07/21/03
+TOTAL
+TRANSACTION
+FITG TO FITM
+Bear, Steams & Co. Inc.
+New York. New York 10179
+Trades Executed Pending Settlement
+SETLEMENT
+TRADE
+DATE
+TRANSACTION
+09/15/03
+06/17/03
+09/15/03
+07/07/03
+"BOUGHT
+TOTAL
+DESCAIPTION
+FNMA-30YR(FNMA)GTD
+SETT, 09/03
+5 haM 12023 05.0009
+REF #1
+FNMA SOYA GTO
+SETT, 09/03
+D/S NaM 112033.05.500%
+REF TA
+The above trades do not appear in any other section of this statement.
+BS
+BS
+STOP
+****** End of Statement******
+$-94,600.00
+$10,330.47
+SYMBOL/CUSIP
+10,000,000.00
+PRICE
+101.4687
+20,000,000.00
+102.2500
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 27, 2003
+10,146,875.00
+20,450,000.00
+$30,596,875.00
+
+
+Bear, Steams & Co. Inc.
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary....
+Your Portfolio Holdings
+Transaction Detail .....
+.............
+Trades Not Yet Settled
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 30, 2003
+4
+13
+Hollandlold
+FINANCIAL TRUST CO INC
+CIO JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+19,744,476
+302,660
+83,953
+NET EQUITY THIS PERIOD
+$20,131,089
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+24,422,603
+-4,291,514
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$83,953
+$128,074
+Cash & Equivalent -
+Fixed
+Income
+$19.744.476
+$23,876.335
+Current market value
+Last statement's market value
+SP The suremen s four or ratanal furyce rear die Set revere date for portant iformation.
+06/28/03;11:38 001
+4909
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+06/28/03:11:39 001|
+1909
+
+
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance.
+Bear, Steams & Co. Inc.
+THIS PERIOD
+128,074.4
+.....
+82,874,936.25
+995,092.35
+494,356.75
+....
+$84,364,385.35
+-84,399,062.25
+-9,444.25
+584,408,506.50
+-44,121.15
+.. . ..
+583,953.25
+Income Summary
+Govt. Agency Int.
+Corp. Bond Int.
+Credit Balance Int.
+Reverse Repurchase Int.
+Total
+Bond Purchase Int.
+Repurchase Int. Exp.
+THIS PERIOD
+872,169.36
+122,709.53
+213.46
+1,320.35
+$996.412.70
+YEAR TO DATE
+5,517,114.59
+653,383.98
+585.89
+10,564.41
+.. . .
+.. 181,648.87
+-50,156.82
+-24,344.52
+Portfolio Composition
+Cash/Cash Equivalent
+Fixed Income
+Total
+83,953
+19,744,476
+..59.828.429
+Cash Balance Summary
+Margin
+Net Cash Balance
+OFENING
+128,074.40
+$128,074.40
+CLOSING
+83,953.25
+.......
+$83,953.25
+....
+120
+06/28/03;11:39 001
+EARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 30, 2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+<1%
+- Fixed Income
+99%
+Unshaded portions denote debit balance and or shart
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+FEDERAL HOME LOAN MG CORP
+RIES 2530 CLASS
+TED DATE 10/11/0
+UE 02/15/2032220%
+FEDERAL HOME LOAD
+SERIES 2526 CLASS SI
+DATED DATE 10/01/02
+DUE 02/15/2032
+FACTOR 52694552120%
+FEDERAL NATIONAL MG ASSN
+STRIP MTG SERIES 322 CL PO
+DATED DATE 03/01/02
+DUE 03/01/2032
+FACTOR 11100000001%
+DERAL HOME LOAN MIG CO
+RIES 2471 CLASS
+DATED DATE 06/07/02
+E 03/15/2032 1.000
+CTOR - .647877
+SIMBCLCUSIP
+PRICE
+SWMEOLCUSP
+MRGN
+MAGN
+41,674,323
+17,876,324
+-
+MAGN
+MAGN
+3,288,302
+55,069,607
+MARKET
+VALUE
+83,953
+$83,953
+ESt08
+PRICE
+8.1907
+92.7109
+2.6940
+027
+ESTIMATE
+NUAL INCON
+MARKET VALUE
+3,352,813
+ACCRUE
+NTERES
+86,406
+3,048,616
+1,483,592
+34,681
+2
+18,351
+06/28/03;11:39 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 30, 2003
+ESTIMATE
+NNUAL INCOM
+2,592,143
+URREN
+MELD I:
+77.3125
+71.0560
+1,040,402
+33
+550,696
+37.1191
+
+
+Your Portfolio Holdings (continued)
+Government & Agency Obligations (continued)
+SERIES 2488 CLASS SO
+DATED DATE 07/08/02
+BOOK ENTRY ONLY.
+FACTOR 263220320%
+FEDERAL HOME LOAN MTG CORP
+JATED DATE 07/02/02
+DUE 03/15/2032 5.820%
+ACTOR - .65220732
+.. . . .
+FEDERAL NATIONAL MTG ASSN
+ERIES 2003-49 CLASS SV
+ATED DATE 04/30/0:
+PACT 2015,95%
+Total Government& Agency Obligations
+SIMBOLCUSP
+Corporate Bonds
+FANNIE MAE CMO/SERIES 2002-82
+SK-I/O FLTR
+BOOK ENTRY ON02102
+SMMBOLCUSP
+Total CorporateBonds
+TOTAL FIXED INCOME
+Bear, Steams & Co. Inc.
+MAGN
+MRGN
+MRGN
+32,610,366
+37,622,535
+23.847,942
+MAGN
+21,026,691
+PRICE
+8.2122
+9.9844
+MARKET VALUE
+2,598,645
+3,089,646
+2,381,068
+$17,418,581
+ACCRUED
+NTERES
+74,135
+72,988
+11.902
+$294,465
+PRICE
+11.0616
+MARKET VALUE
+2,325,895
+$2,325,895
+$19,744,476
+CORUE
+NTERES
+8,195
+$8,195
+$302,660
+027
+06/28/03;11:39 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 30,2003
+ESTIMATED
+ANNUAL INCOME
+2.224,027
+CURRENT
+YIELD (%)
+85.5841
+2,189,632
+.......
+70.8700
+1,422,530
+... . .
+59.7434
+$10,019,463
+URREN
+HELD (5
+63.4174
+1,475,022
+$1,475,022
+$11,494,485
+
+
+Bear, Steams & Co. Inc.
+Your Portfolio Holdings (continued)
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+BATEMENT CATE
+DATE
+06/09/03
+TRANSACTION
+06/09/03
+6/12/0
+06/10/03
+SOLD
+06/12/03
+''05/07/03 BOUGHT
+FEDERAL NATIONAL MTG ASSN
+TRIP MG SERIES 322 CL PO
+INCIPAL REDUCTN 06-25-03
+PRINCIPAL REDUCTN 06-25-03
+FEDERAL NATIONAL MIG ASSN
+STRIPS SERIES 326 CLASS 1 PO
+DUE 070112032 00.001%
+REF #L
+BS
+INMA 30YR(FNMAJGTD
+SET 06020205.50%
+REF #1
+BS
+$302,660
+$11,494,485
+$19,828,429
+SYMBOLCUSP
+-240,643
+-245,158
+-3.561,835
+95.14063
+20,000,000
+•102.71875
+027
+06/28/03;11:39 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 30, 2003
+3.388,752.75
+20,543,750.00
+
+
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TREE
+DATE
+TRANSACTION
+06/12/03
+06/05/03
+CANCEL SELL
+06/12/03
+06/05/03
+CANCEL SELL
+06/12/03
+05/07/03
+CANCEL BUY
+06/12/03
+06/05/03
+06/12/03
+06/05/03
+06/13/03
+"SOLD
+SOLD
+FNMA-30YR(FNMA)GTD
+SEE 06032022,05,500%
+TO CXL PREVIOUS SELL
+FNMA-30YR(FNMA)GTD
+SET 06042032,05,500%
+ENMA- 30YRIENMAJGTD
+SETT.06/03
+DUE 06m01/2033 05,500%
+AS OF 05707103
+TO CXL PREVIOUS BUY
+......
+NMA-30YR(FNMA)GT
+SETT. 06/03
+7ü= nSm12083 05,500%
+BS
+BS
+BS
+BS
+.. . . .
+FNMA-30YR(FNMA)GTD
+SETT.06/03
+DUE 06001/2033 05,500%
+AS OF DErSTUST
+BS
+FEDERAL NATIONAL MG ASSN
+LOUS RESTORES CLASS 1 PO
+SYMBOL/GUSP
+027
+20,000,000
+PRICE
+103.73828
+20,000,000
+103.73828
+-20,000,000
+102.71875
+*20,000,000
+-20,000,000
+-1
+103.73828
+103.73828
+06/28/03;11:39 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 30, 2003
+20,747,656.00
+20,747,656.25
+20,543,750.00
+20,747,656.00
+20,747,656.25
+
+
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+06/16/03
+TRANSACTION
+06/16/03
+06/16/03
+06/16/03
+6/16/
+06/16/03
+06/16/03
+06/16/03
+06/16/03
+SERIES 2471 CLASS YT
+1,000 DUE 03/15/32
+PRINCIPAL REDUCTN 06-15-03
+FEDERAL HOME LOAN MG CORP
+SERIES 2471 CLASS YT
+,000 DUE 03/15/32
+RINCIPAL REDUCTN 06-15-03
+............
+EDERAL HOME LOAN MIG CORF
+SERIES 2483 CL SI
+,820 DUE 03/15/3
+RINCIPAL REDUCTN 06-15-0
+..... .
+FEDERAL HOME LOAN MTG CORP
+SERIES 2483 CL SL
+5.820 DUE 03/15/32
+RINCIPAL REDUCTN 06-15-03
+FEDERAL HOME LOAN MTG CORP
+REPA RUN 06 1503
+SERIES 2488 CLASS SQ
+1.820 DUE 03/15/32
+RINCIPAL REDUCTN 06-15-03
+SERIES 2530 CLASS SE
+1.090 DUE 02/15/32
+PRINCIPAL REDUCTN 06-15-03
+"FEDERAL HOMELAN MIG CORP
+SERIES 2530 CLASS SE
+1.090 DUE 02/15/32
+RINCIPAL REDUCTN 06-15-03
+SERIES 2526 CLASS SI
+5.820 DUE 02/15/32
+PRINCIPAL REDUCTN 06-15-03
+SYMBOL/GUSP
+027
+-4,391,000
+PRICE
+-293
+-3,000,000
+.....
+,600,0
+374
+3,149,000
+-158
+-1,350,000
+06/2803;11:39 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 30,2003
+V908
+
+
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+06/16/03
+TRANSACTION
+06/25/03
+06/25/03
+06/25/03
+PRINCIPA
+06/25/03
+TOTAL
+DATE
+06/02/03
+AVG BAL 391,997RT
+021 OFFICE INTEREST 0503
+06/16/03
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+DUE 03/15/2032
+NTEREST PAYMENT 06-15-03
+FEDERAL HOME LOAN MG CORP
+SERIES 2526 CLASS SI
+5,820 DUE 02/15/32
+PRINCIPAL REDUCTN 06-15-03
+FEDERAL NATIONAL MTG ASSN
+STRIP MTG SERIES 322 CL PO
+.001 DUE 03/01/32
+RINCIPAL PAYMENT 06-25-03
+FEDERAL NATIONAL MIG ASSN
+STRIPS SERIES 326 CLASS 1 PO
+001 DUE 07/01/3
+NCIPAL PAYMENT 06-25-1
+FANNIE MAE MOISERIES 2002-82
+MAN A MEET O6 2503
+FEDERAL NATIONAL MG ASSN
+SERIES 2003-49 CLASS SW
+5,680 DUE 01/25/33
+PRINCIPAL REDUCTN 06-25-03
+SYMBOU/CUSIP
+SYMBOL/GUSP
+RATE (%)
+1.0000
+027
+-940
+PRICE
+853,165
+458,817
+06/28/03;11:39 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 30, 2003
+240,642.60
+245,158.30
+$-62,039,062.25
+213.46
+49,550.75
+$65.913,615.90
+vace
+
+
+Bear, Stears & Co. Inc.
+10 or 13
+INTEREST (continued)
+DATE
+06/16/03
+FEDERAL HOME LOAN MG CORP
+SERIES 2483 CL SL
+TEREST ENT 06-10.03
+06/16/03
+SERIES 2488 CLASS SO
+INTEREST PAINENT O-15-03
+0616/03
+EREST PANES 8 1503
+06/16/03
+FEDERAL HOME LOAN MTG COF
+SERIES 2526 CLASS SI
+DUE 02/15/2032
+INTEREST PAYMENT 06-25-03
+06/25/03
+*FANNIE MAE CMOISERIES 2002-82
+SK-VO FLIR
+DUE 10/25/2031
+INTEREST PAYMENT 06: 23-03
+06/25/03
+*FEDERAL NATIONAL MIG ASSN
+SERIES 2003-49 CLASS SW
+DUE 01/25/2033
+5,680
+INTEREST PAYMENT 06-25-03
+TOTAL
+SYMBOUGUSIP
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS
+with Bear, Stearns& Co.Inc.
+SATLE MENT
+06/13/03
+TRADE
+DATE
+TRANSACTION
+DESCRPTION
+SYMBOUGUSIP
+RATE (%)
+5.8200
+6.8200
+6.0900
+5.8200
+6.7300
+5.6800
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 30, 2003
+192,618.75
+----...
+96,299.86
+227,479.19
+91,168.80
+122,709.53
+115,051.99
+$995,092.35
+3,720,000.00
+06/28/03;11:39 001
+
+
+11 of 13
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+BELEMENT
+06/230
+TRADE
+DATE
+TRANSACTION
+06/23/03
+8 625 01
+a0s149
+06/231
+06/23/03
+8.625 01
+1=sJST4S
+
+06/23
+1E12312019
+IM-P
+о6IZ7
+8.625 DI
+23148
+06/27/03
+8 605 D1
+0231/49
+06/271
+8625 Cl
+03149
+06/27/03
+• 625 ПЛ
+W3149
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 30,2003
+3.720,000.00
+3.720.000.00
+928.97
+4,760,000.00
+4,760,000.00
+027
+'3,720,000.00
+4,760,000.00
+4,760,000.00
+5,400,000.00
+06/28/03;11:39 001
+
+
+Bear, Stears & Co. Inc.
+12 of 13
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+TRADE
+DATE
+06/27/|
+TRANSACTION
+DUE 12/31/2049 8 625
+EITM-PB
+TOTAL
+MISCELLANEOUS
+MATSAY
+06/11/03
+...............
+06/12/03
+TRANSACTION
+.......
+OURNA
+06/17/03
+MAY 03 SPEC CLEARING FEES
+FNMA-30YR(FNMA)GTD
+SETT.06/03
+5.500 DUE 06/01/33
+MBS NET 06/12/03
+....
+DERAL HOME LOAN MIG CO
+SERIES 2471 CLASS YT
+PEI TANER 03/15/32
+06/17/03
+06/19/03
+Sassin
+6/24/0
+TOTAL
+FEDERAL HOME LOAN MIG CORE
+SERIES 2471 CLASS Y
+.000 DUE 03/15/3
+&I TRNF
+ADJ,
+700.00
+8,744.25
+$-9,444.25
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 30,2003
+391.38
+$-22,360,000.00
+$16.961,320.35
+203,906.25
+8,74425
+8,744.25
+272,962.00
+$494,356.75
+06/2803;11:39 001
+V908
+
+
+Trades Executed Pending Settlement
+SEE MENT TRE
+TRANSACTION
+07/14/03 06/05/03
+09/15/03 06/17/03
+TOTAL
+FNMA-30YR(FNMA)GTD
+ETT,07/03
+IT= 0770112032.05,500%
+REF #1
+SEE 03092033 05,000%
+HE 1
+The above trades do not appear in arry other section of this statement
+BS
+BS
+STOP)
+****** End of Statement******
+SYMBOLCUSIF
+20,000,000.00
+PRICE
+103.4062
+10,000,000.00
+101.4687
+027
+06/28/03:11:38 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 30, 2003
+20,681,250.00
+.......
+10,146,875.00
+$30,828,125.00
+7909
+
+
+Bear, Stears & Co. Inc.
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary .............................
+Your Portfolio Holdings
+Transaction Detail ....
+Trades Not Yet Settled
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 25,2003
+3
+4
+15
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+23,876.335
+418,194
+128,074
+NET EQUITY THIS PERIOD
+฿24,422,603
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+21,444,251
+2,978,353
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account
+Market Value of Your Portfolio
+$128.074
+$97,944
+Cash & Equivalent
+Fixed
+Income
+• $23,876,335
+$21,153,305
+Current market value
+Last statement's market value
+SIP The suremen s four ratanal purger red de Set revere dise for portant iformation.
+
+
+2 of 15
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 of 15
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance,
+THIS PERIOD
+597.943.B9
+93,187,950.43
+987,495.06
+2,270,988.66
+596,446434.15
+.......
+-96,034,964.30
+-19,175.34
+-362,164.00
+5-96.416.303-64
+30,130.51
+$128,074.40
+Income Summary
+Govt. Agency Int.
+Corp. Bond Int.
+Credit Balance Int.
+Reverse Repurchase Int.
+Total
+Bond Purchase Int.
+Repurchase Int. Exp.
+THIS PERIOD
+858,912.79
+128.482.02
+100.25
+5,131.07
+$992.626.13
+-19,175.34
+-10,991.93
+Portfolio Composition
+Cash/Cash Equivalent
+Fixed Income
+Total
+YEAR TO DATE
+4,644,945.23
+530,674.45
+372.43
+9,244.06
+.....
+$5,185,236.17
+-50,156.82
+-24,344.52
+128,074
+23,876,335
+...$24.004.409
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+97,943.89
+$97,943.89
+CLOSING
+128,074.40
+....
+$128,074.40
+....
+120
+CLEARED THRESH SONARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 25, 2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+<1%
+- Fixed Income
+99%
+Unshaded portions denote debit balance andor shar
+from the absolute marker value of your portiolo.
+
+
+4 of 15
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+FEDERAL HOME LOAN MTG CORP
+SERIES 2530 CLASS SE
+DATED DATE 10/11/02
+DUE 02/15/2032 1.090%
+
+SERIES 2526 CLASS SI
+DATED DATE 10/01/02
+DUE 02/15/2032 5690%
+FACTOR - 74705810
+FEDERAL NATIONAL MIG ASSN
+STRIP MTG SERIES 322 CL PO
+DATED DATE 03/01/02
+DUE 03/01/2032
+FACTOR
+- 95851030%
+FEDERAL HOME LOAN MG CORP
+SERIES 2471 CLASS YT
+DATED DATE 06/07/02
+DUE 03/15/2032 1,000%
+
+SIMBCLCUSIP
+PRICE
+MARKET
+VALUE
+128,074
+$128,074
+SWMBOLCUSP
+MAGN
+MRGN
+MAGN
+MAGN
+44,823,481
+19,227,164
+3.528,945
+006'09t*69
+PAICE
+93.7734
+2.4527
+027
+ESTIMATE
+NUAL INCON
+MARKET VALUE
+3,382,158
+113,742
+1,490,873
+45,583
+3,309,213
+1,458,403
+3
+24,777
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 25,2003
+ESTIMATE
+INNUAL INCOM
+2,729,750
+URREN
+HELD I
+80.7103
+1,094,026
+609+69
+35
+ILL 01
+....
+8LL96L00V|]
+
+5 or 15
+Your Portfolio Holdings (continued)
+Bear, Steams & Co. Inc.
+Government & Agency Obligations (continued)
+SIMBOLCUSP
+MAGN
+35,210,740
+40,622,583
+FACTOR 904254690%
+-EDERAL NATIONAL MG ASSN
+STRIPS SERIES 326 CLASS 1 PO
+TED DATE 07/01/
+OK ENTRY ON
+DUE 07/01/2032
+981608001%
+FEDERAL NATIONAL MG ASSN
+SERIES 2003-49 CLASS SH
+NTEREST FROM DATE 05/25/0:
+DATED DATE 04/30/03
+IRST COUPON 06/25/200
+OOK ENTRY ONL
+DUE 01/25/2033 5,680%
+FACTOR - 1.00000000
+Total Government& Agency Obligations
+MRGN
+MAGN
+3.806,994
+MRGN
+24,306,759
+PRICE
+93.4609
+11.0313
+027
+MARKET VALLE
+2,589,920
+OCRUEI
+NTERES
+98,150
+3,160,349
+3.558,052
+96,310
+2,681,339
+19,176
+$21,630,307
+$397,744
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 25, 2003
+ESTIMATED
+ANNUAL INCOME
+2,355,599
+CURRENT
+YELD IN
+90.9526
+2,311,425
+73.1383
+1,380,624
+51.4901
+$10,466,106
+
+
+1 or 15
+Your Portfolio Holdings (continued)
+Corporate Bonds
+FANNIE MAE CMO/SERIES 2002-82
+SK-I/D FLTR
+JATED DATE 10/02/02
+SYABOLCUSP
+TOTAL FIXED INCOME
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stears & Co. Ine.
+MAGN
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TRE
+TRANSACTION
+05/12/03
+05/07/03
+SOLD
+FEDERAL NATIONAL MG ASS
+SERIES 2003-16 CLASS JS
+DUE 03/25/2018. 10.050%
+REF #1
+BS
+21,879,856
+PRICE
+10.2653
+MARKET VALUE
+2,246,028
+20459
+$2,246,028
+$20,450
+$23,876,335
+$418,194
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 25,2003
+ESTIMATED
+ANNUAL INCOME
+1,472,514
+CURRENT
+YIELD (S)
+65.5608
+$1,472,514
+$11,938,620
+$418,194
+$11,938,620
+$24,004,409
+SYMBOLCUSIP
+L 139,069
+PRICE
+101.06250
+ACCR. INT.
+CREDIT ANKUNT
+L.214,922.36
+33,880.83
+027
+
+
+1 or 15
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+DATE
+TRANSACTION
+05/14/03
+04/29/03
+Bear, Stears & Co. Inc.
+05/14/03*03/24/03"BOUGHT
+05/14/03
+05/07/03
+"CANCEL"SELL
+05/14/03
+203124/03
+''CANCEL BUY
+05/14/03
+/05/07703
+''''SOLD
+05/14/03
+05/15/03
+JOURNAL"
+FEDERAL NATIONAL MIG ASSN
+STRIPS SERIES 326 CLASS 1 PO
+DUE 0701/2082 00.001%
+REF #1
+AS OF O28005 MONTHS TAROR
+:ETT,05/03
+JE 05(01/2033 05,500
+REF #I
+BS
+SETT 05/03
+DUE 05/01/2033 05,500%
+REF #
+AS OF 05107703
+TO CXL PREVIOUS SELL
+FNMA-30YR(FNMAjGTD
+SETT.05/03
+DUE 05/01/2033 05,500%
+REF #1
+AS OF 03/24/03
+TO CXL PREVIOUS BUY
+BS
+BS
+SETT.05/03
+DUE 050112033. 05.500%
+REF #L
+BS
+FEDERAL NATIONAL MIG ASS
+SERIES 2003-16 CLASS JS
+10,050 DUE 03/25/18
+"FEBERAL" HOME TOAN MIE CORP
+SERIES 2471 CLASS YT
+1,000 DUE 03/15/3
+'RINCIPAL REDUCTN 05-15-0:
+SYMBOLGUSP
+027
+3.806,994
+PRICE
+89.00000
+20,000,000*
+100.93750"
+20,000,000*
+103.10156
+-20,000,000
+100.93750
+20,000,000
+103.10156
+2,238,000
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 25,2003
+3,388,224.66
+20,187,500.00
+20,620,312.50
+20,187,500.00
+20,620,312.50
+
+
+8 of 15
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+05/15/03
+TRANSACTION
+05/15/03
+05/15/03
+PRINCİPAL
+05/15/03
+PRINCİPAL
+05/15/03
+05/15/03
+ö5/15/03
+05/27/03
+"PRINCİPAL"
+Bear, Steams & Co. Inc.
+SERIES 2471 CLASS YT
+FEDERAL HOME LOAN MIG CORF
+ERIES 2483 CLIS
+5,690 DUE 03/15/32
+PRINCIPAL REDUCTN 05-15-03
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2483 CL SL
+.690 DUE 03/15/3
+RINCIPAL REDUCTN 05-15-0
+MERA ROUT O5 1508
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2530 CLASS SE
+1.090 DUE 02/15/32
+•RINCIPAL REDUCTN 05-15-03
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2526 CLASS SI
+5,690 DUE 02/15/32
+PRINCIPAL REDUCTN 05-15-03
+SERIES 2526 CLASS SI
+5.690 DUE 02/15/3
+RINCIPAL REDUCTN 05-15-03
+FEDERAL NATIONAL MIG ASSN
+STRIP MTG SERIES 322 CL PO
+1.001 DUE 03/01/32
+REPOP 801-08.0005-25-03
+REPO P & I
+SYMBOLGUSP
+027
+-952
+3,711,000
+PRICE
+454
+3,918,000
+-180
+-1,680,000
+715
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+April 25, 2003
+282,084.50
+
+
+9 of 15
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+05/27/03
+TRANSACTION
+05/27/03
+05/30/03
+0429(03
+TOTAL
+
+AVG BAL
+021 OFFICE INTEREST 0AU3
+05/15/03 FEDERAL HOME LOAN MIG CORP
+05/15/03
+FEDERAL HOME LOAN MG CORF
+05/15/03
+HEREST PANNENT
+AMENT 83-95-03
+Bear, Steams & Co. Inc.
+-ANNIE MAE CMO/SERIES 2002-82
+SK-VO FLTR
+PRINCIPAL DUCT 0525-03
+FANNIE MAE CMOSERIES 2002-82
+SK-30 DUE 10/25/31
+PRINCIPAL REDUCTN 05-25-03
+... . .
+FEDERAL NATIONAL MIG ASSN
+SERIES 2003-49 CLASS SW
+DUE 01/25/2033 05.680%
+REF #
+BS
+AS OF 04/29/03
+RATE (S)
+1.0000
+0000
+5.690
+027
+-1,029,000
+270
+24,306,759
+ACCR. INT.
+PRICE
+11.06250
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+April 25, 2003
+2.688.935.21
+19,175.34
+$-46.904,147.71
+$48,338,700.19
+100.25
+22,267.38
+*31,810.54
+210,217.22
+
+
+Bear, Steams & Co. Inc.
+10 or 15
+INTEREST (continued)
+DATE
+05/15/03
+05/15/03
+"FEDERAL HOME LOAN MIG CORP
+SERE AMAN 05903
+05/15/03
+'FEDERAL" HOME LÖAN MIG CORP
+RE R81312 CLAN S698.03
+05/27/03
+FANNIE MAE CMO/SERIES 2002-82
+RHEAR ARMENT 05738.03
+TOTAL
+EPURCHASE AND REVERSE REPURCHASE TRANSACTION
+ith Bear, Stearns& Co.In
+SALEMENT
+05/13/|
+THANSACTION
+DESCRIPTICN
+FITMAPR CR
+3.625 DUE 1231/49
+05/13/03
+"JOURNAL
+05/31
+ITM-PF
+5525 bUs 28143
+5.6900
+027
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+April 25, 2003
+214,234.68
+247,363.95
+99,138.19
+.....
+128,482.02
+$953,614.23
+1950,000.00
+1,950,000.00
+1,950,000.00
+
+
+Bear, Steams & Co. Inc.
+11 of 15
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+SATE EMENT
+TRADE
+DATE
+TRANSACTION
+05/13/03
+FINAR O
+86250N1231/49
+'''ADP CO
+JUE 12/31/2049
+8,625
+FIM-PRI
+
+1.001 QUE 07/01/32
+05/19/03
+
+ö5/19/03
+"JOURNAL
+FITM
+HOO QUE 0701321
+AP OPEN
+STRIPS SERIES 12 LASS ROSEN
+1001 QUE 0701172
+AP TERMI
+STARS ERE 12E NAS 1R55
+DUE 07/01/2032
+FITM
+1.001
+A2
+AP TERN
+AP TERN
+8.625 ПUEКP23149
+3.806.994
+3,806,394
+3,806,994
+027
+9,290,000.00
+'''*3,158,000.00***
+684.23
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 26, 2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 25,2003
+• 1,256.67
+'3.758,08080
+'2.120,000.00
+9.290,000.00
+
+
+12 or 15
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+SETLEMENT
+TRADE
+DATE
+05/23/03
+TRANSACTION
+FINAR O
+8.625 DU5T23149
+8.625 DUE 12/31149
+
+8.625 DUE 23149
+ö5/237
+DUE 12/31/2049
+EITM-PR
+8.625
+05/28/03
+05/28/03
+1.001 DUE 03/01/32
+FITM
+AP TERM
+LAd.
+AP TERM
+SERIES A GURE LOAN MIG CORP
+1,000 DUE 03/15/32
+LA2
+05/28/03
+"JOURNAL
+STARS SERES 426 VAS TRESSI
+L.001 DUE 07/01/32
+FITM
+TA2
+AP TERM
+-
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD April 26, 2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 25,2003
+9,290,000.00
+2,348.31
+3,528,945
+*34.977,000
+3.806.994
+027
+9,290,000.00
+''7: 188,880.80
+*.'*3.078.000.00
+2,120,000.00
+
+
+Bear, Steams & Co. Inc.
+13 of 15
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+SETLEMENT
+TRACE
+05/28/03
+TRANSACTION
+SERIESPERAE CRME JOAN MIG CORP
+L 690 QUE 03/15/32
+LA4
+05/28/03
+05/28/03
+RP TERM
+ADP Ci
+8.625 DUEK23149
+APP CE
+8.625 DUE 23149
+STRIP INTO SEE SEE ARE ASSEN
+DUE 03/01/2032
+FITM
+AP TERM
+AP TERM
+ö5/28/03
+"INTEAEST"
+FITM
+AP TERM
+AP TERM
+ö5/28/03
+05/287
+DUE 03/15/2032
+FITM
+AP TERM
+AP TERN
+'''DP CB
+DUE 12/312049
+$ 625
+35,210,740
+3,133,000.00
+'*3,190,000.00
+"4.968.69
+'**832.10
+4,508.91
+027
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York: 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+April 25, 2003
+T7.100,000.00
+1,369.00
+
+
+14 of 15
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+SETLEMENT
+TRADE
+DATE
+05/29/03
+TRANSACTION
+05/29|
+JOURNAL"
+FINAR O
+8625 DIESTS
+'''ADP Ch
+-ITM-PR
+8.625 DUE 1231149
+ö529
+INTEAEST"
+UE 12/31/2049 8.62
+ö5/30
+"JOURNAL
+05/30/
+8625 DUE 123149
+....••....
+DuE 128392049
+8625
+TOTAL
+MISCELLANEOUS
+PAIDAY
+05/09/03
+05/14/03
+TAANSACTION
+JOUANAL
+0577803* 8UANAL**
+APA 03 SPEC CLEARING FEES
+SETT, 05/03
+500 DUE 05/01/3
+BS NET 05/14/0
+''PEBERAL HOME LOAN MIG COAR'
+SERIES 2471 CLASS YT
+1,000 DUE 03/15/3:
+P&I TANFR
+50.00
+027
+2,830,000.00
+$-49,149,991.93
+432,812.50
+0•9,543.16
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 26, 2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 25,2003
+3.190,000.00
+82:41
+*2.830,000.00
+74.6
+$44,883,131.07
+
+
+15 of 15
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+05/27/03
+......
+05/29/03
+TOTAL
+RANSACTIO
+SURNA
+FIG TO FITM
+....
+FIT TO FITG
+Trades Executed Pending Settlement
+SETLEMENT TREE
+DATE
+TRANSACTION
+06/12/03 05/07/03
+TOTAL
+FNMA-30YR(FNMA)GTD
+SETT.06/03
+DUE 06/01/2033 05,500%
+REF #
+The above trades do not appear in arry other section of this statemene
+BS
+STOP
+****** End of Statement******
+362,114.00
+$-362,164.00
+,828,633.00
+$2.270,988.66
+SYMBOLICUSIP
+20,000,000.00
+PRICE
+102.7187
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 25,2003
+20,543,750.00
+$20,543,750.00
+
+
+Bear, Steams & Co. Inc.
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary .............................
+Your Portfolio Holdings
+Transaction Detail ....
+Trades Not Yet Settled
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 29, 2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28, 2003
+4
+13
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+21,153,305
+193.002
+97,944
+$21,444,251
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+24,650,030
+-3,205,779
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account
+Market Value of Your Portfolio
+$97,944
+$273.282
+Cash & Equivalent
+Fixed
+Income
+$21,153,305
+$24,075,942
+Current market value
+Last statement's market value
+SP The suremen s foul ratanal purger red de Set revere die for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+04/26/03:11:49 001
+
+
+Bear, Steams & Co. Inc.
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Funds Withdrawn
+Miscellaneous
+Amount Debited.
+Net Cash Activity
+Closing Balance
+THIS PERICO
+5273,282.28
+48,556,911.46
+1,070,933.50
+145,913.71
+$49,773,758.67
+... .
+-49,850,352.59
+-77,852.00
+-20,892.47
+5-49.949.097.06
+-175,338.39
+$97.943.89
+Income Summary
+Govt. Agency Int.
+Corp. Bond Int.
+Credit Balance Int.
+Reverse Repurchase Int.
+Total
+Bond Purchase Int.
+Repurchase Int. Exp.
+THIS PERIOD
+938,633.16
+132,220.68
+79.66
+521.67
+$1.071.455.17.
+-13,352.59
+Portfolio Composition
+Cash/Cash Equivalent
+Fixed Income
+Total
+YEAR TO DATE
+3,786,032.44
+402,192.43
+272.18
+4,112.99
+... .
+$4,192,610.04
+-30,981.48
+-13,352.59
+97,944
+21,153,305
+..... 21.251.249
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+273,282.28
+$273,282.28
+CLOSING
+97,943.89
+... ..
+$97,943.89
+....
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 29, 2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28, 2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+<1%
+- Fixed Income
+99%
+Unshaded portions denote debit balance andor short
+from the absolute marker value of your portiolo.
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+FEDERAL NATIONAL MG ASS
+SERIES 2003-16 CLASS JS
+DATED DATE 01/06/03
+DUE 03/25/2018 10,050%
+FACTOR
+, 96506519
+FEDERAL HOME LOAN MG CORP
+ERIES 2530 CLASS S
+ATED DATE 10/11/0
+FACTOR = 2812361000%
+SERIES 2526 CLASS SI
+DATED DATE 10/01/02
+FACTOR 52812361690%
+FACTOR
+SERIES 2471 CLASS VT
+DATED DATE 06/07/02
+DUE 03/15/2032 1,000%
+FACTOR —
+.76345290
+SIMBCLCUSIP
+PRICE
+SWMBOLCUSP
+MAGN
+I 139,070
+MAGN
+48,741,661
+MAGN
+MAGN
+20,907,879
+97,944
+$97,944
+PAICE
+98.7400
+9.1479
+9.1154
+2.7564
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 29,2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28, 2003
+STIMATE
+NUAL INCON
+MARKET VALUE
+1.049,118
+ESTIMATED
+ANNUAL INCOM
+717,477
+10.1783
+4,458,847
+82,458
+2,968,367
+249 99
+....
+1,905,832
+33,046
+1,189,658
+62.4220
+96996L
+1423
+267,209
+
+
+Your Portfolio Holdings (continued)
+Bear, Stears & Co. Inc.
+Government & Agency Obligations (continued)
+SHMBOLCUSIP
+MAGN
+44,334,037
+Total Government& Agency Obligations
+Corporate Bonds
+FANNIE MAE CMO/SERIES 2002-82
+SK-NO FLIR
+JATED DATE 10/02/02
+OOK ENTRY ONLY
+DUE 10/25/2031 1,730%
+FACTOR - .91636507
+Total CorporateBonds
+TOTAL FIXED INCOME
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+SYMBOLCUSP
+MAGN
+22,909,126
+PRICE
+9.2039
+MARKET VALUE
+4,080,481
+ACCRUED
+70.075
+$18,230,814
+$193,002
+PRICE
+12.7569
+MARKET VALUE
+2,922,491
+AGER ST
+$2,922,491
+$21,153,305
+$193,002
+$9,207,102
+$21,251,249
+$193,002
+027
+04/26/03:11:48 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 29,2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2003
+ESTIMATED
+ANNUAL INCOME
+2,522,607
+CURRENT
+YIELD IN
+61.8213
+.665,318
+ESTIMATED
+ANNUAL INCOME
+1,541,784
+CURREN
+YELD 1:
+52.7558
+$1,541,784
+$9,207,102
+
+
+Repurchase and Reverse Repurchase Transactions
+with Bear,Stearnsand Co. Inc. outstanding as of date of statement
+PLACHASE
+AEFURCHASE
+START DATE
+DATE
+PRIATE PURCHASE REALI
+ACCRUED REPO
+YOU PROVIDED
+(MARGIN)
+04/07/03 OPEN
+YOU SOLD
+(REPO)
+04/21/03 05/21/03
+1.570
+•...•
+YOU SOLD
+(REPO)
+04/25/03 05/21/03
+1.570
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASE TRANSACTIONS
+4s of statement don
+-3,078,000
+-939
+-3,133,000
+-409
+$ 211,000
+$-1,348
+Transaction Detail
+INVESTMENT ACTIVITY
+SETLEMENT TREE
+TRANSACTION
+04/14/03 01/27/03
+BOUGhT
+04/14/03 02/04/03BOUGHT
+FNMA-30YR(FNMA) GTD
+SETT,04/03
+DUE 24101/2033 05.500%
+REF #1
+PNMA 30YR(FNMA)GTD"
+SETT 04/03
+DUE 04101/2033 05.500%
+REF #1
+BS
+BS
+(FACE AMOUNT)
+-50,000,000
+-5,000,000
+-50,000,000
+CUSP
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 29, 2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2003
+SERIES 2471 CLASS YT 1.0000 03/15/32
+.. .
+FNMA-SMBS PRINCIPAL ONLY
+SERIES 322 CLASS PO
+03/01/32
+SERIES 2488 CLASS SO
+03/15/32
+...........
+SYMBOLCUSIP
+10,000,000
+10,000,000
+PRICE
+100.60938
+100.93750
+10,060,937.50
+10,093,750.00
+027
+
+
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+04/14/03
+
+TRANSACTION
+CANCEL SELL
+Bear, Stears & Co. Inc.
+04/14/03*01/27/03 CANCEL BUY
+04/14/03
+02/04/03
+CANCEL BUY
+04/14/03
+04/15/03
+04715/03
+04/15/03
+03/24/03
+SOLD
+FNMA-30YR(FNMA) GTD
+SETT, 04/03
+DUE 0410112033 05.500%
+REF #
+AS OF 03/24/03
+TO CXL PREVIOUS SELI
+FNMA-30YR(FNMA) GTD
+SET: 401203 05,500%
+REF #L
+AS OF 01/27/03
+TO CXL PREVIOUS BU
+*#NMA 30YA(FNMA) GT0
+SETT.04/03
+DUE 041011208305,500%
+BS
+BS
+BS
+SETT, 04/03
+DUE 04/01/2033 05.500%
+REF #L
+BS
+"FEDERAL HOME LOAN MTG CORP
+SERIES 2471 CLASS YT
+.000 DUE 03/15/3
+RINCIPAL REDUCTN 04-15-0:
+*FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+1,000 DUE 03/15/3
+PRINCIPAL REDUCTN 04-15-03
+FEDERAL" HÖME TOAN MIC CORP
+SERIES 2483 CL SL
+5.720 DUE 03/15/3
+'RINCIPAL REDUCTN 04-15-0:
+SYMBOLGUSF
+027
+20,000,000
+PRICE
+101.35156
+10,000,000
+*100.60938"
+10,000,000
+100.93750
+20,000,000
+1,548,000
+-610
+2.569,000
+101.35156
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD March 29,2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2003
+20,270,312.50
+10,060,937.50
+10,093,750.00
+20,270,312.50
+
+
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+04/15/03
+TRANSACTION
+0415/03
+04715/03
+04/15/03
+PRINCİPAL
+04/15/03
+04/25/03
+Bear, Steams & Co. Inc.
+
+
+PAINCIPAL
+SERIES 2483 CL SL
+SERIES 2530 CLASS SE
+|.120 DUE 02/15/32
+PRINCIPAL REDUCTN 04-15-03
+ME A RUN 0-1503
+SERIES 2526 CLASS SI
+5.720 DUE 02/15/3
+PRINCIPAL REDUCTN 04-15-03
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2526 CLASS SI
+5.720 DUE 02/15/32
+PRINCIPAL REDUCTN 04-15-03
+FEDERAL NATIONAL MIG ASSN
+TRIP MTG SERIES 322 CL PI
+.001 DUE 03/01/3:
+REPO P80 1.0004-25-03
+FANNIE MAE CMOVSERIES 2002-82
+RORA ROT O4 2503
+FEBERAL NAMONAL'MIG ASS
+SERIES 2003-16 CLASS JS
+10.050 DUE 03/25/18
+PRINCIPAL REDUCTN 04-25-03
+SYMBOLGUSIF
+027
+-379
+2,857,000
+650
+225,000
+797
+PRICE
+614,196
+188,473
+04/26/03;11:48 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 29,2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+March 28, 2003
+231,916.95
+
+
+INVESTMENT ACTIVITY (continued)
+SATEMENT TREE
+04/25/03
+TRANSACTION
+TOTAL
+DEPOSITS AND WITHDRAWALS
+DATE
+04/03/03
+TRANSACTION
+FND WIRED
+TOTAL
+DATE
+03/31/03
+AVG BAL
+241,588RT
+021 OFFICE INTEREST 0303
+64/15/03"REBERAL HOME LOAN MIG CORP
+ERIES 2471 CLASS
+04/15/03
+04/15/03
+1,000
+SERE PARENT 1.78.03
+Bear, Stears & Co. Inc.
+FEDERAL NATIONAL MG ASS
+SERIES 2003-16 CLASS JS
+0,050 DUE 03/25/18
+RINCIPAL PAYMENT 04-25-0:
+[WIRED TO
+SYMBOLCUSIP
+DEBIT AMOLNT
+77,852.00
+$-77,852.00
+RATE (SL
+1:0000
+1.0000
+5.7200
+027
+PRICE
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 29,2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2003
+188,472.84
+$-40,425,000.00
+$40,845.389.79
+79.66
+23,557.88
+*33.654.12
+223.572.95
+
+
+Bear, Steams & Co. Inc.
+10 or 13
+INTEREST (continued)
+DATE
+04/15/03
+SYMBOL/GUSIP
+04/15/03
+"FEDERAL HOME LOAN MIG CORP
+SERE AMAN 2803
+04/15/03
+'"FEDERAL" HOME LOAN MIG CORP
+SERIES 2526 CLASS SI
+RHE R2315/292eNT 84778-03
+ö4/25/03
+FANNIE MAE CMOVSERIES 2002-82
+04/25/03
+FEDERAL NATIONAL MG ASS
+TOTAL
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS
+with Bear, Stearns& Co.Inc.
+SATLEMENT
+04/07/03
+TRADE
+DATE
+TAANSACTION
+"JOURNAL
+SERIES ZAFT CURSE LOAN MIG CORP
+FilMO QUE 034532
+AP OPEN
+AP OPEN
+FIA PR T
+52 buar28149
+SYMBOL/CUSIP
+5.7200
+10.0500
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD March 29, 2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28, 2003
+227,667.02
+263,156.51
+105.503.85
+132,220.68
+61,520.83
+$1,070,933.50
+-40,384,945
+*750,000.00
+027
+
+
+Bear, Stears & Co. Inc.
+11 of 13
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+BETLEMENT
+TRADE
+DATE
+04/17/03
+TRANSACTION
+FINAR O
+8.625 DIz423149
+ö4/17||
+5.625 DUE 2231/49
+
+'JOURNAL'
+ö4/172|
+8.625 DUE P731/49
+'''BPC***
+DUE 12/31/2049
+8.625
+FIM-PR
+
+
+04/21/03
+L.001 DUE 03/01/32
+FITM
+LAZ
+AP TERM
+AP TERM
+STRIP INTO SEATS 92 MAG ASSI
+1.001 DUE 03/01/32
+FITM
+AL
+AP OPEN
+AP OPEN
+DUE 03/01/2032
+FITM
+AP TERM
+AP TERM
+-
+*3.811.029
+3.811,029
+027
+750,000.00
+''1:950,000.00
+•''*3.032,000.00
+4,307.97
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 29, 2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28, 2003
+750,000.00
+521:67
+*3.078,000.00
+
+
+Bear, Steams & Co. Inc.
+12 or 13
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+SETLEMENT
+TRACE
+04/25/03
+TRANSACTION
+SERIESPERAE CHRME JOAN MIG CORP
+1.690 QUE 03/15/32
+AP OPENI
+04/25/03
+AP TERM
+AP TERM
+... . .
+......
+DUE 03/15/2032
+FITM
+AP TERM
+AP TERM
+SYMBOUGUSIP
+-38,427,745
+38.427,745
+'''3,680,000.00
+.....
+04/25/03
+TOTAL
+MISCELLANEOUS
+DATE
+MO/DAY
+04/10/03
+04/14/03
+TRANSACTION
+04/16/03
+JOUANAL
+9,044.62
+$-9,425,352.59
+MAR 03 SPEC CLEARING FEES
+"FNMA-30YR(FNMAjGTD
+SETT,04/03
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+1,000 DUE 03/15/32
+INT 021-92128 TO
+700.00
+CRECIT AMOUNT
+195,625.00
+20,192.47
+027
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 29, 2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT March 28,2003
+3,133,000.00
+•.711,521.67
+
+
+MISCELLANEOUS (continued)
+DATE
+MODAY
+04/21/03
+TRANSACTION
+04/21/03
+TOTAL
+SERIES 2471 CLASS YT
+Trades Executed Pending Settlement
+TRANSACTION
+05/14/03
+03/24/03
+TOTAL
+FNMA-30YR(FNMA)GTD
+SETT,05/03
+DUE 05/01/2033 05,500%
+REF #
+The above trades do nat appear in any other section of this statemart.
+BS
+20,192.47
+CRECIT AMOUNT
+10,096.24
+$-20,892.47
+$145,913.71
+SYMBOLCUSIF
+20,000,000.00
+PRICE
+100.9375
+LZO
+04/26/03;11:48 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 29,2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28, 2003
+20,187,500.00
+$20,187,500.00
+
+
+Bear, Stears & Co. Inc.
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary .............................
+Your Portfolio Holdings
+Transaction Detail ....
+Trades Not Yet Settled
+LEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28, 2003
+3
+11
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+24.075.942
+300,806
+273.282
+$24,650,030
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+23,891,200
+758,830
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account
+Market Value of Your Portfolio
+$273.282
+$385,776
+Cash & Equivalent
+Fixed
+Income
+$24.075.942
+$23,198,123
+Current market value
+Last statement's market value
+SIP The suremen s four ratanal purger red de Set revere dise for portant iformation.
+03/29/03:10:54 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+03/29/03;10:54 001
+
+
+3 of12
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance.
+Bear, Stears & Co. Inc.
+THIS PERIOD
+3385.775.82
+5,010,034.50
+1,096,802.98
+205,279.34
+...
+7.312, 116.82
+.....
+Д.270,120.19
+-154,490.17
+54424,610.36
+-112,493.54
+.. . .
+6273.282.28
+Income Summary
+Govt. Agency Int.
+Corp. Bond Int.
+Credit Balance Int.
+Reverse Repurchase Int.
+Total
+Bond Purchase Int.
+THIS PERIOD
+962,655.39
+134,082.87
+64.72
+77.08
+1.096,880.06
+Portfolio Composition
+Cast/Cash Equivalent
+Fixed Income
+Total
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+385,775.82
+$385,775.82
+CLOSING
+273,282.28
+$273,282.28
+1.••...
+027
+YEAR TO DATE
+2,847,399.28
+269,971.75
+192.52
+3,591.32
+.....
+53.121,154.87
+-30,981.48
+273,282
+24.075,942
+......
+$24,349,224
+03/29/03;10:54 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28,2003
+Your Portfolio
+Allocation
+Cash & Equivalent —
+1%
+- Fixed Income
+99%
+Unshaded portions denote debit balance and or shart
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+FEDERAL NATIONAL MTG ASS
+SERIES 2003-16 CLASS JS
+DATED DATE 01/06/03
+DUE 03/25/2018 10.075%
+FACTOR. 99054310
+FEDERAL HOME LOAN MG CORP
+SERIES 2530 CLASS SE
+DATED DATE 10/11/02
+DUE 02/15/2032 |.1209
+FACTOR - ,85998860
+SERIES 2526 CLASS SI
+DATED DATE 10/01/02
+DUE 02/15/2032 5.720%
+FACTOR
+
+SERIES 2471 CLASS VT
+DATED DATE 06/07/02
+DUE 03/15/2032 1.000%
+
+SIMBCLCUSIP
+PRICE
+SHMEOLCUSP
+MAGN
+1 327,543
+MAGN
+51.599,311
+MAGN
+MAGN
+22,133,676
+80654,40
+MARKET
+VALUE
+273,282
+$273,282
+PAICE
+97.6300
+10.3259
+9.2919
+2.7988
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 1, 2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28, 2003
+STIMAT
+INUAL INCOR
+MARKET VALLE
+I153,880
+1. 153
+NUAL INCOM
+738,250
+10.3196
+5,328,097
+114,036
+3,157,878
+59.2684
+2,056,646
+45,719
+1,266,046
+61.5588
+1,921,493
+35.7297
+....
+09/2903:10:54 001
+
+Your Portfolio Holdings (continued)
+Bear, Stears & Co. Inc.
+Government & Agency Obligations (continued)
+SYMBOLCUSP
+MAGN
+46,903,416
+Total Government& Agency Obligations
+Corporate Bonds
+FANNIE MAE CMO/SERIES 2002-82
+SK-NO FLIR
+ATED DATE 10/02/02
+OOK ENTRY ONLY
+DUE 10/25/2031 1.745%
+FACTOR - 94093290
+Total CorporateBonds
+TOTAL FIXED INCOME
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+SYMBOLCUSP
+MAGN
+23,523,322
+PRICE
+9.3921
+MARKET VALLE
+4.405,222
+$20,865,338
+96,882
+$287,584
+PRICE
+13.6486
+MARKET VALUE
+3,210,604
+ACCRUE
+NTERES
+13,222
+$3,210,604
+$24,075,942
+$300,806
+$10,118,241
+$24,349,224
+$13,222
+$300,806
+120
+03/29/03:10:54001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28,2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28, 2003
+ANNUAL INCOME
+2,682,875
+CURRENT
+YIELD (S)
+60.9022
+$8,531,593
+ESTIMATED
+ANNUAL INCOME
+1,586,648
+CURRENT
+YIELD IS
+49.4190
+$1,586,648
+$10,118,241
+
+
+Bear, Stears & Co. Inc.
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearnsand Co. Inc. outstanding as of date of statement
+PLACHASE
+REPUACHASE
+PRICING
+PURCHASE PAICE
+ACCAUED REPO
+START DATE
+DATE
+RATE
+INTEREST*
+YOU SOLD
+(REPO)
+02/28/03 05/07/03
+1.580
+YOU SOLD
+(REPO)
+03/19/03 04/21/03
+1.550
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASE TRANSACTIONS
+As of statement dete
+-3,680,000
+-5,006
+-3,032,000
+-1,566
+$-| 712,000
+$1.572
+Transaction Detail
+INVESTMENT ACTIVITY
+SEEMENT TATE
+03/12/03
+03/17/03
+03/1703
+TRANSACTION
+"PRINCIPAL"
+"PRİNCIPAL"
+SERIES 2526 CLASS SI
+5,660 DUE 02/15/32
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+1,000 DUE 03/15/32
+PRINCIPAL REDUCTN 03-15-03
+SERIES 2471 CLASS YT
+,000 DUE 03/15/3
+RINCIPAL REDUCTN 03-15-0
+(FACE AMOUNT)
+-50,000,000
+-5,000,000
+CUSP
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28,2003
+SERIES 2488 CLASS SO
+...... . .
+FNMA-SMBS PRINCIPAL ONLY
+SERIES 322 CLASS PO
+03/15/32
+..............•.
+03/01/32
+SYMBOLGUSIP
+2,852,000
+339
+PRICE
+027
+03/29103;10:54 001
+
+
+1 0112
+INVESTMENT ACTIVITY (continued)
+SEEN TREE
+03/17/03
+TRANSACTION
+03/1703
+03717/03
+03/17/03
+03/19/03
+03/17/03 BOUGHT
+03/25/03
+03/25/03
+
+TOTAL
+"PRINCIPAL"
+SERIES 2483 CL SL
+PRINCIPAL REDUCTN 03-1503
+PRINCIPAL REDUCTN 03-15-03
+SERIES 2530 CLASS SE
+PAINCIPAL REDUCTN 03-15.03
+SERIES 2530 CLASS SE
+L.120 DUE 02/15/32
+PRINCIPAL REDUCTN 03-15-03
+"FEDERAL NATIONAL MIG ASSN
+TRIP MTG SERIES 322 CL P
+WE 03/01/2032 00.001
+REF #1
+FANNIE MAE CMO/SERIES 2002-82
+SK-VO FLTR
+MATCIPAL REDUCIN 03-2503
+"FEDERAL NATIONAL MIG ASS
+SERIES 2003-16 CLASS JS
+10,000 DUE 03/25/18
+PRINCIPAL REDUCTN 03-25-03
+FEDERAL NATIONAL MIG ASS
+SERIES 2003-16 CLASS JS
+10,000 DUE 03/25/18
+PRINCIPAL PAYMENT 03-25-03
+027
+-2,366,000
+236
+2,422,000
+836
+*4.042,946
+PRICE
+*''89.34375
+442,336
+69,957
+03/29103;10:54 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 1, 2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+February 28, 2003
+3,612,120.19
+$-3,612,120.19
+69,957.42
+$69,957.42
+
+
+
+G BAL 136.265RT
+21 OFFICE INTEREST 020
+03/17/03 "FEDERAL HOME LOAN MIG CORP"
+63/17/05 "PEDERAL HOME LOAN MIG CORP"
+SERE ARENT 877803
+03/17/03
+"FEDERAL HOME LOAN MIG CORP
+REPO P 81
+03717/03
+**FEDERAL HOME LOAN MG CORP
+RARE RACES 17803
+03/17/03
+'"FEDERAL HOME LOAN MIG CORP
+0991
+032503 PANNIE MAE CMOSERIES 200282
+K-VO FLIR
+DuE 101252031 1722-03
+0325/03
+FEDERAL NATIONAL MTG ASS
+ERIES 2003-16 CLASS ,
+HERER ARENT 18:99°0
+TOTAL
+ear, Stears & Co. Inc
+83 Madison AvenL
+SYMBOUGUSIP
+RATE (%)
+1.0000
+* 5.7200
+6.7200
+* 6.1200
+5.7200
+
+10.0000
+027
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28,2003
+64.72
+*49,492.72
+232,388.52
+237,017.33
+272,811.87
+109,299.12
+• 134.082.87
+61,645.83
+$1,096,802.98
+03/29103;10:54 001
+
+
+Bear, Stears & Co. Inc.
+9 of 12
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS
+with Bear, Stearns & Co. Inc.
+SATEMENT
+TRADE
+DATE
+TRANSACTION
+03/07/03
+SERIES BE ARME JOAN MIG CORP
+5.660 QUE 0245/32
+FITM
+AP OPEN T
+03/17/03
+SERIES 2526 CLASS SOAN MIG CORP
+5.720 QUE 02151322
+RP TERM
+AP TERN
+03/18/03
+"JOURNAL
+E2D0193149
+03/19/03
+STRIP MTO SERE 922 CLAG ASSN
+FiT QUE 0301/32
+FiTM
+AP OPEN
+AP OPEN
+03/20/03
+ö3/201
+"JOURNAL
+....
+TAPR CI
+03/27703
+"JOURNAL
+UE 12/31/2049
+EITM-PR
+8625
+
+SYMBOUGUSIP
+-23,172,958
+22,133,676
+4,042,946
+027
+'1,150,000.00
+''758.000.00"
+'''750.000.00
+03/29103;10:54 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 1, 2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28, 2003
+3,032,000.00
+1,150,000.00
+57.50
+
+
+Bear, Steams & Co. Inc.
+10 or 12
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+SATEMENT
+03/21/
+TRACE
+TRANSACTION
+ö321||
+FINAR O
+8.625 005123149
+'''ADP CO"''''
+JUE 12/31/2049
+8,625
+
+0328/03
+OURNA
+1,000 DUE 03/15/32
+FITMARGN
+A4
+AP TERM
+AP TERM
+SERIES EAT GIRE LOAN NIG CORP
+1,000 DUE 03/15/32
+FITMARGN
+LA1
+AP OPEN
+AP OPEN
+TOTAL
+MISCELLANEOUS
+DATE
+MO/DAY
+TRANSACTION
+03/12/03
+03920***
+JOURNAL"
+03/17/03
+03/18/05
+JOURNAL"
+FEB 03 SPEC CLEARING FEES
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+PAi TANFE 03/15/32
+'24,230,967
+12,115,483
+$-2,658,000.00
+400.00
+*''112,066.00
+"20,813:00
+CRECIT AMOUNT
+''22,211.17
+027
+03/29103;10:54 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28, 2003
+758,000.00
+- 1958
+$4,940,077.08
+
+
+11 of 12
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+03/18/03
+TRANSACTION
+03/19/03
+-JOURNAL
+03/20103
+TOTAL
+SERIES 2471 CLASS YT
+RECLASS P003 15/32
+DERAL HOME LOAN MIG COI
+RIES 2471 CLASS
+,000 DUE 03/15/3
+&I TANF
+FIG TO FITM
+Trades Executed Pending Settlement
+SETTE MENT TRE
+04/14/03
+01/27/03
+TRANSACTION
+04/14/03
+02/04/03
+4/14/0
+03/24/03
+SOLD
+FNMA-30YR(FNMA) GTD
+SETT,04.03
+DUE 04/01/2033 05,500%
+REF #
+NMA-30YR(FNMA) GT
+SETT,04.03
+DUE 04/01/2033 05,500%
+REF #
+.. . . .
+FNMA-30YR/FNMA) GTD
+SETT 04.03
+DUE 04/01/2033 05,500%
+REF #
+BS
+BS
+BS
+- 21,211.17
+$-154,490.17
+CRECIT AMOUNT
+21,211.17
+162,857.00
+$205,279.34
+SYMBOLGUSIP
+10,000,000.00
+10,000,000.00
+-20,000,000.00
+PRICE
+100.6093
+100.9375
+101.3515
+027
+03/29103;10:54 001
+LEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28, 2003
+10,060,937.50
+10,093,750.00
+20,270,312.50
+
+
+12 or 12
+Bear, Stears & Co. Inc.
+Trades Executed Pending Settlement
+(continued)
+SETTEMENT TRIE
+TRANSACTION
+05/14/03 03/24/03 BOUGHT
+FNMA-30YR(FNMA)GTD
+SETT,05/03
+DUE 05/01/2033 05,500%
+REF #
+TOTAL
+The above trades do not appear in any other section of this statement
+BS
+STOP
+****** End of Statement******
+SYMBOL/CUSIP
+20,000,000.00
+PRICE
+100.9375
+027
+03/29/03;10:54 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28,2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28, 2003
+20,187,500.00
+$40,342,187.50
+$20,270,312.50
+
+
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stears & Co. Inc.
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...........................
+Your Portfolio Holdings
+Transaction Detail ....
+Trades Not Yet Settled
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD February 1,2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31, 2003
+3
+11
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+23,198,123
+307,301
+385,776
+$23,891,200
+•••••••••
+22,986,053
+905,147
+ere are no "Stop Loss" orders or other pending bu
+sell open orders on file for your accoun
+Market Value of Your Portfolio
+$385.776
+$517
+Cash & Equivalent
+Fixed
+Income
+$23,198.123
+I $22,463,638
+Current market value
+Last statement's market value
+SP This satement stori for ratanal for our red de. pot revere did ora dotan itormation.
+
+
+2 of 11
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or 11
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance,
+Bear, Steams & Co. Inc.
+THIS PERIOD
+516.7
+.......
+35,413,423.41
+1,065,782.92
+169,239.08
+586648-45-41
+-36,253,953.00
+-8,333.33
+-900.00
+5.36.263. 18.33
+385,259.08
+5385.775.82
+Income Summary
+Govt. Agency Int.
+Corp. Bond Int.
+Credit Balance Int.
+Reverse Repurchase Int.
+Total
+Bond Purchase Int.
+THIS PERIOD
+929,766.24
+135,888.88
+127.80
+2,187.59
+$1.067.970.51
+-8,333.33
+Portfolio Composition
+Cash/Cash Equivalent
+Fixed Income
+Total
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+516.74
+$516.74
+CLOSING
+385,775.82
+... ....
+฿385,775.82
+.......
+027
+YEAR TO DATE
+1,884,743.89
+135,888.88
+127.80
+3,514.24
+.. . .
+$2.024,274.81
+-30,981.48
+385,776
+23,198,123
+.. . .
+$23,583,899
+.............
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD February 1, 2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31, 2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+1%
+- Fixed Income
+99%
+Unshaded portions denote debit balance and or shart
+
+
+4 of 11
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+FEDERAL HOME LOAN MG CORP
+SERIES 2530 CLASS SE
+DATED DATE 10/11/02
+DUE 02/15/2032 |.060%
+FACTOR...
+FEDERAL HOME LOAN MTG CORP
+DATE DA 0021
+UE 02/15/2032 5,660
+
+FEDERAL HOME LOAN MG CORP
+FACTOR OR152032
+842160%
+FEDERAL HOME LOAN MG CORP
+SERIES 2483 CL SL
+DATED DATE 07/02/02
+DUE 03/15/2032 5,660%
+
+SIMBCLCUSIP
+PRICE
+SWMBOLCUSP
+MAGN
+MAGN
+54,022,147
+23,172,960
+MAGN
+MAGN
+59,391,262
+
+MARKET
+VALUE
+385,776
+$385,776
+MINE ACTED
+PRICE
+9.3962
+MARKET VALLE
+5,076,007
+118,218
+8.5799
+1,988,216
+47,364
+2.8431
+8.5352
+1,688,559
+21,448
+4,205,264
+002'00L
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD February 1,2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31, 2003
+ANNUAL INCOME
+3,273,742
+64.4944
+1,311,590
+2896'99
+593,913
+35.1728
+
+
+...
+{9L96V
+
+5 of 11
+Your Portfolio Holdings (continued)
+Bear, Stears & Co. Inc.
+Government & Agency Obligations (continued)
+SYMBOLCUSP
+FEDERAL NATIONAL MTG ASS
+MAGN
+QUANTIT
+397,500
+DUE 02/25/2033 10,000%
+Total Government& Agency Obligations
+Corporate Bonds
+FANNIE MAE CMO/SERIES 2002-82
+SK-I/O FLTR
+DATED DATE 10/02/02
+Total CorporateBonds
+TOTAL FIXED INCOME
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+SIMEGLCUSP
+ACCE
+MRGN
+23,965,658
+PRICE
+98.5347
+MARKET VALLE
+[.289,104
+OCRUEL
+NTERES
+1.164
+$20.247,150$293,894
+PRICE
+12.3133
+MARKET VALLE
+2,950,973
+13,407
+$2,950,973
+$23,198,123
+$307,301
+$10,316,472
+$23,583,899
+$13,407
+$307,301
+027
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD February 1, 2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31,2003
+ESTIMATED
+ANNUAL INCOME
+739,750
+CURRENT
+YIELD (S)
+10.1487
+$8,707,657
+ANNER NONE
+1,608,815
+URREN
+IELD IS
+54.5181
+$1.608.815
+$10,316,472
+
+
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stears & Co. Inc.
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearnsand Co. Inc. outstanding as of date of statement
+PUACHASE/
+AEPURCHASE
+START DATE
+DATE
+PRICING
+PURCHASE PAICE
+ACCAUED REPO
+RATE
+YOU SOLD
+(REPO)
+02/28/03 05/07/03
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASE TRANSACTIONS
+-As of statement date
+1.580
+-3.680.000
+-484
+$3,680,000
+$484
+(FACE AMOUNT)
+-50,000,000
+CUSP
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD February 1, 2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31,2003
+SERIES 248B CLASS SO
+03/15/32
+Transaction Detail
+INVESTMENT ACTIVITY
+SETLEMENT TRADE
+DATE
+DATE
+02/13/03
+01/08/03
+TRANSACTION
+
+' '02/04/03"CANCEL SELL
+FNMA-30YR(FNMA) GTD
+SET 0201203305,500%
+REF #L
+:ETT.02/03
+VE 02101/2033 05.500
+REF #
+AS OF 02/04/03
+TO CXL PREVIOUS SELL
+SYMBOL/CUSP
+10,000,000
+PRICE
+101.43750
+10,143,750.00
+BS
+BS
+10,000,000
+
+10,176,953.00
+027
+
+
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+DATE
+TRANSACTION
+02/13/03
+01/08/03
+CANCEL BUY
+OFFICE SERVICING YOUR ACOOUNT
+Bear, Steams & Co. Inc.
+02/13/03 02/04/03 SOLD
+ö2/18/03
+ö2/18/03
+02218/03
+ö2/18/03
+02/18/03
+
+PAINCIPAL
+FNMA-30YR(FNMA) GTD
+SETT, 02/03
+PUE 0201/2033.05.500%
+REF #
+BS
+AS OF 01/08/03
+TO CXL PREVIOUS BUY
+#NMA-30YR(FNMA) GTD
+SETT.02/03
+DUE 0201/2033 05,500%
+REF #I
+BS
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+1,000 DUE 03/15/32
+PRINCIPAL REDUCTN 02-15-0:
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+1.000 DUE 03/15/32
+PRINCIPAL REDUCTN 02-15-0:
+SERIES 2483 CL SL
+5.660 DUE 03/15/3:
+RINCIPAL REDUCTN 02-15-0
+SERIES 2483 CL SL
+5,660 DUE 03/15/32
+PRINCIPAL REDUCTN 02-15-0:
+SERIES 2488 CLASS SO
+.660 DUE 03/15/32
+PRINCIPAL REDUCTN 02-15-0:
+"FEBERAL HOME'LOAN MIG CORP
+SYMBOLGUSF
+027
+-10,000,000
+PRICE
+101.43750
+10,000,000
+• 101.76953
+1,931,000
+398
+1.02,000
+*245
+1,388,000
+790
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD February 1, 2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31, 2003
+10,143,750.00
+10,176,953.00
+
+
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+02/18/03
+TRANSACTION
+02/18/03
+02/18/03
+02/25/03
+02/28/03
+'''22203703
+*''*BOUGHT
+OFFICE SERVICING YOUR ACOUNT
+Bear, Steams & Co. Inc.
+02/28/03
+02/27703
+SOLD
+02/28/03
+TOTAL
+02/27/03
+SOLD
+SERIES 2530 CLASS SE
+PAINIPAL REDUCTN 02-15-03
+SERIES 2530 CLASS SE
+1.030 DUE 02/15/32
+PRINCIPAL REDUCTN 02-15-03
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2526 CLASS SI
+660 DUE 02/15/
+INCIPAL REDUCTN 02-15-
+FANNIE MAE CMOSERIES 2002-82
+K-VO FLTR
+1.697 DUE 10/25/3
+PRINCIPAL REDUCTN 02-25-03
+"FEDERAL NATIONAL MIG ASS
+SEES 2021 48 5)
+REF#
+BS
+AS OF 02703103
+"FEDERAL NATIONAL MIG ASS
+SERIES 2003-16 CLASS JS
+DUE 02/25/203310.000%
+REF #
+BS
+... .
+FEDERAL NATIONAL MTG ASS
+SERIES 2003-16 CLASS JS
+PUE 022512033,10.000%
+REF #1
+BS
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD February 1, 2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+January 31, 2003
+-1,991,000
+819
+854,394
+381,733
+10,000,000
+ACCR. INT.
+1,177,500
+-1,425,000
+PRICE
+* 96.31250
+9.631,250.00
+8,333.33
+
+ACCR. INT.
+96.31250
+ACCR. INT.
+$-29,960,286.33
+1,134,079.69
+981.25
+1,372,453.13
+1,187.50
+$22,829,404.57
+
+
+9 of 11
+
+O2T OFFICE INTEREST O10ST
+ö2/18/03 FEDERAL HÖME LOAN MIG CORP
+SEE REST ANS 129503
+ö2/18/03TTPEDERAL HOME LOAN MIG CORP"
+SERE RACENT 02 98903
+02/18/03
+''FEDERAL HÖME LÖAN MTG CORP
+02/18/03
+ERE ARENT
+BRENT 026500:
+"FEDERAL HOME LOAN MIG CORP
+HERE PANANT E15003
+02/18/03"PEDERAL HOME LOAN MIG CORP
+625% REPE GLASS C
+TEREST PAYMENT 02-15-0
+02/25/03
+FANNIE MAE MOISERIES 2002-82
+RENE RENT 058303
+TOTAL
+SYMBOUGUSIP
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS
+with Bear, Stearns& Co. Inc.
+SALE MENT
+02/20/03
+TRADE
+DATE
+TRANSACTION
+RATE (%)
+1.0000
+• 5.6600
+SYMBOUGUSIP
+027
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD February 1, 2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31, 2003
+127.80
+51,102.22
+238,675.58
+281,470.21
+12.728.33
+135,888.88
+$1.063.614.17
+2,602,000.00
+
+
+Bear, Stears & Co. Inc.
+10 of 11
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+SATE EMENT
+02/20/
+TRADE
+DATE
+TRANSACTION
+1.625 D1023749
+-ITM-PR
+8.625 DUE 1213149
+02720/83
+
+INTEAEST
+DUE 12/31/2049
+8625
+02/28/03
+"JOURNAL
+ö2/287
+"JOURNAL
+02/28
+FITM
+AP OPEN
+AP OPEN
+5825 DUS2I3149
+......
+DUE 12/312049
+8.625
+TOTAL
+-
+:42,705,825
+027
+''''3,780,000.00"
+$1,302,000.00
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD February 1, 2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31,2003
+2,602,000.00
+2,602,000.00
+1,478.81
+3.680,000.00
+3.700,000.00
+768.78
+$12,586,187.59
+
+
+Bear, Stears & Co. Inc.
+11 of 11
+MISCELLANEOUS
+DATE
+MO/DAY
+02/13/03
+02/13/03
+RANSACTIO
+SURNA
+JOUANAL
+JAN 03 CLEARING FEES
+02/19/03
+"JOURNAL"
+02/21/03
+TOTAL
+SETT.02/03
+.500 DUE 02/01/33
+ABS NET 02/13/03
+1,00 DUE 03/15682
+....
+FIG TO FITM
+Trades Executed Pending Settlement
+SETTLEMENT TRADE
+DATE
+DATE
+TRANSACTION
+04/14/03
+01/27/03
+FNMA-30YR(FNMA) GTD
+SETT,04/03
+DUE 04/01/2033 05.500%
+04/14/03 02/04/03 BOUGHT
+SETT,04/03
+DUE 04/01/2033 05,500%
+REF #
+BS
+TOTAL
+The above trades do not appear in arry other section of this statement.
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD February 1,2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31, 2003
+900.00
+$-900.00
+CRECIT AMOUNT
+33,203.13
+21,900.95
+114,135.00
+$169.239.08
+SYMBOLICUSIP
+10,000,000.00
+PRICE
+100.6093
+10,060,937.50
+10,000,000.00
+1100937510093,750
+10,093,750.00
+$20,154,687.50
+027
+
+
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stears & Co. Inc.
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary...........................
+Your Portfolio Holdings
+Transaction Detail ....
+Trades Not Yet Settled
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2002
+3
+11
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+22,463,638
+521,898
+517
+$22,986,053
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+14,249,549
+8,736,503
+ere are no "Stop Loss" orders or other pending bu
+sell open orders on file for your accoun
+Market Value of Your Portfolio
+$517
+$24,520
+Cash & Equivalent
+Fixed
+Income
+$22,463,638
+$13,715,716
+Current market value
+Last statement's market value
+SP This satement stori for atanal for our red de, pot revere did a a dortant itomation.
+
+
+2 of 11
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or 11
+Bear, Steams & Co. Inc.
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Funds Withdrawn
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited.
+Net Cash Activity
+Closing Balance
+THIS PERICO
+$24.52047
+25,988,373.53
+954,977.65
+14,376,739.01
+541,320,090.19
+.....
+-25,965,207.77
+-366,738.00
+-22,648.15
+-14,989,500.00
+$ 41.344.093.92
+-24,003.73
+...
+$516.74
+Income Summary
+Govt. Agency Int.
+Reverse Repurchase Int.
+Total
+•......
+Bond Purchase Int.
+THIS PERIOD
+954,977.65
+1,326.65
+956,304.3(
+.. . ..
+-22,648.15
+Portfolio Composition
+Cash/Cash Equivalent
+Fixed Income
+Totall
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+24,520.47
+$24,520.47
+CLOSING
+516.74
+$516.74
+............•
+027
+YEAR TO DATE
+954,977.65
+1,326.65
+... . .
+$956,304.30
+.........
+-22,648.15
+517
+22,463,638
+... .
+522,164.155
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2002
+Your Portfolio
+Allocation
+Fixed Income-
+100%
+Unshaded portions denote debe balance andor short
+
+
+4 of 11
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+FEDERAL HOME LOAN MTG CORP
+SERIES 2530 CLASS SE
+DATED DATE 10/11/02
+DUE 02/15/2032 .030%
+FACTOR
+.93356610
+DATE DA 0021
+FEDERAL HOME LOAN MG CORP
+FACTOR - 287603800%
+
+DATED DATE 07/08/02
+DUE 03/15/2032 1.630
+
+SIMBCLCUSIP
+PRICE
+SWMBOLCUSP
+MAGN
+MAGN
+56,013,966
+24,027,354
+MAGN
+MAGN
+61,322,660
+44.094,615
+MARKET
+VALUE
+517
+$517
+PAICE
+10.0663
+9.1396
+2.7360
+11.6523
+027
+ESTIMATE
+NUAL INCON
+MARKET VALLE
+5,638,552
+150,120
+2,196,011
+60,122
+1,677,757
+27,251
+
+129,935
+02101/03;15:12 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2002
+ESTIMATEl
+NUAL INCOM
+3,377,642
+59.9026
+1,352,740
+3669 19
+613,227
+2,923,473
+36.5504
+.....
+6868'99
+t9496
+
+5 of 11
+Your Portfolio Holdings (continued)
+Bear, Stears & Co. Inc.
+Government & Agency Obligations (continued)
+SHMBOLCUSIP
+MRGN
+50,871,897
+Total Government& Agency Obligations
+Corporate Bonds
+FANNIE MAE CMO/SERIES 2002-82
+SK-IND FLIR
+DATED DATE 10/02/02
+DUE 10/25/2031 | 697%
+FACTOR - 97389566
+Total CorporateBonds
+TOTAL FIXED INCOME
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+SYMBOLCUSP
+MAGN
+24,347,391
+PRICE
+9.1370
+MARKET VALUE
+4,648,141
+127,293
+$19,298,477
+$494,721
+0000 EL
+PRICE
+MARKET VALUE
+3,165,161
+$3,165,161
+$22.463,638
+CORUE
+NTERES
+27,177
+$27,177
+$521,898
+$521,898
+$12,761,715
+$22,464,155
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2002
+ESTIMATED
+ANNUAL INCOME
+2.864,088
+CURRENT
+YIELD (S)
+61.6179
+$11,131,170
+ESTIMATED
+ANNUAL INCOME
+1,630,545
+CURRENT
+YIELD IN
+51.5154
+$1,630,545
+$12,761,715
+
+
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT TRADE
+DATE
+TRANSACTION
+01/14/03
+12/04/02
+01714709 01708703 CANCEL SEL
+
+12/04/02
+"CANCEL BUY
+01/14/03
+•'01/08/03
+'SOLD
+01715/03
+
+01715/03
+PRINCIPAL"
+FNMA- 30YR(FNMA) GTD
+SETT,01/03
+RUE 01/01/2033.05.500%
+REF #1
+BS
+SETT.01/03
+DUE 01101/2033 05.500%
+REF #1
+BS
+AS OF 01/08/03
+TO CXL PREVIOUS SELL
+*FNMA-30YR(FNMA)GTD
+SET: 01012039 05.500%
+REF #
+BS
+AS OF 12704/02
+TO CXL PREVIOUS BUY
+FNMA-30YR(FNMA) GTD
+SETT.01/03
+DUE 0101/2033 05,500%
+REF#L
+BS
+FEDERAL HOME LOAN MTG CORP
+PROPA ROUTE O.108
+"FEBERAL" HOME LOAN MIC CORP
+SERIES 2471 CLASS YT
+1,000 DUE 03/15/32
+PRINCIPAL REDUCTN 01-15-03
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2483 CL SL
+5,580 DUE 03/15/32
+PRINCIPAL REDUCTN 01-15-03
+SYMBOLGUSF
+027
+PRICE
+100.09375
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 1, 2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2002
+10,009,375.00
+10,000,000
+000,000
+*101.88672***
+10,188,671.88
+-70,000,000
+00.0937
+10,009,375.00
+-10,000,000
+2,344,000
+468
+1,944,000
+
+10, 188,671.88
+
+
+1 or 11
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+01/15/03
+TRANSACTION
+01715/03
+PRINCIPAL"
+01715/03
+01715/03
+PRINCİPAL
+01715/03
+01715/03
+PRINCIPAL"
+01/30/03
+01/27/03
+OFFICE SERVICING YOUR ACOUNT
+Bear, Steams & Co. Inc.
+SERIES 2483 CL SL
+PRINCIPAL REDUCTN 01-15-03
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2488 CLASS SO
+PRING PAL REDUCTIN 01-15.03
+SERIES 2530 CLASS SE
+5,980 DUE 02/15/32
+PRINCIPAL REDUCTN 01-15-03
+SERIES 2530 CLASS SE
+5,980 DUE 02/15/32
+PRINCIPAL REDUCTN 01-15-03
+SERIES 2526 CLASS SI
+5,580 DUE 02/15/32
+PRINCIPAL REDUCTN 01-15-03
+SAND AAE CMOSERES 200282
+DUE 10/25/2031 06,697%
+REF #
+BS
+AS OF 01/27/03
+TOTAL
+SYMBOLGUSIF
+027
+-917
+1,685,000
+810
+• 2,068,000
+:44
+887,093
+24,347,391
+ACCR. INT.
+PRICE
+13.00000
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+December 31, 2002
+3,165,160.89
+22,648.15
+$-23,385,855.92
+$20,198,046.88
+
+
+DEPOSITS AND WITHDRAWALS
+
+RANSACTION
+ND WIREI
+01/02/03
+• ND WIRED
+TOTAL
+DATE
+01/15/03
+FEDERAL HOME LOAN MG CORP
+HERE 1%2 GLEN 01-9903
+ö1715/03
+"FEDERAL HOME LOAN MIG CORP
+ERIES 2483 CL S
+VE 93 1512972N 5.5800
+01715/03
+'*#"BERAL" HOME LOAN MIC COAF
+S 2488 CLASS 9
+HEREST ARMENT 015800
+ö1/15/03
+'''FEDERAL HOME LOAN MIG CORP
+HERE GLEN 0F95-03
+01/15/03
+"FEDERAL HOME LOAN MG CORP
+REFEREST PANES OF 15-03
+TOTAL
+Bear, Steams & Co. Inc.
+WIRED TO
+WIRED TO
+SYMBOL/CUSIP
+84,854.00
+281.884.00
+$-366,738.00
+RATE (S)
+1.0000
+5.5800
+5.9800
+5.5800
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2002
+53,055.94
+245,598.18
+251,029.33
+289,442.02
+115,852.18
+$954,977.65
+VB40
+
+
+Bear, Steams & Co. Inc.
+9 of 11
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS
+with Bear, Stearns & Co. Inc.
+SETTLEMENT
+TRADE
+DATE
+01/30/03
+TRANSACTION
+8.625D1523149
+-ITM-PR
+8.625 DUE 1213149
+UE 12/3172049
+8,625
+01301
+TOTAL
+MISCELLANEOUS
+DATE
+MOVDAY
+E0/Z0/L0
+RECEIVED
+E0VZ0/L0
+DELIVERED
+DELIVERED
+01706/03
+IÖUANAL
+DUE 12/31/2049
+3,625 DUE 123149 8.625
+FITM-PRI
+"ADP CD"
+DUE 12/31/2049
+8.625 DUE 22131/49 8.625
+DUE 12/31/2049
+8,625
+8.625 DUE 12/31/49
+EITM-PR
+"HE 18 FAM
+4,000,000.00
+027
+2,602,000.00
+$-2,602,000.00
+1.913.94
+4,557,000.00
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2002
+5,789,000.00
+1328.65
+$5,790,326.65
+
+
+10 of 11
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+01/14/03
+RANSACTIO
+OURNA
+01715/03 JOURNAL"
+ö7/18/03'JOUANAL"
+01717/03
+ö171703**
+01721:03
+JOUANAL"
+RECEIVED
+Bear, Steams & Co. Inc.
+
+RECEIVED
+EOLIZILO
+"DELIVERED
+01/21703
+01721/03
+DELIVERED
+DELIVERED
+FNMA-30YR(FNMA) GTD
+SETT 01/03
+DEC 02 CLEARING FEES
+FEDERAL HOME LOAN MIG CORF
+1,00 0 1689 T
+PåI TANFR
+*PREM AVO 1/16
+"PREM INT 4/0 1716*
+"ADP CD"
+DUE 12/31/2049
+8.625
+8.625 DUE 12/31/49
+"ADP CD*
+DUE 12/31/2049
+8.625
+8,625 DUE 12/31/49
+FITM-PRI
+DUE 12/31/2049
+8.525 DUE 1213149 8,625
+FITM-PR J
+"ABP CD"
+DUE 12/31/2049
+B.21 DU: 1218/49 8,625
+''BP CD"
+DUE 12/31/2049
+8,625
+8,625 DUE 12/31/49
+179,296.88
+500.00
+600,000.00
+.600,000.00
+'5,789,000.00
+22,738.26
+- 14471
+559.67
+4,600,000.00
+- 4,600,000.00
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2002
+
+
+11 of 11
+MISCELLANEOUS (continued)
+DATE
+MODAY
+01/22/03
+TOTAL
+TRANSACTION
+FIG TO FITM
+Trades Executed Pending Settlement
+SETLEMENT TRADE
+02/13/03 01/08/03
+TRANSACTION
+0414/03
+01/27/03
+TOTAL
+FNMA-30YR(FNMA) GTD
+SETT,02/03
+DUE 02/01/2033 05.500%
+REF #
+FNMA-30YR(FNMA) GTD
+SETT,04.03
+DUE 04/01/2033 05,500%
+REF #
+The above trades do not appear in any other section of this statemene
+BS
+BS
+STOP
+****** End of Statement******
+$-14,989,500.00
+CRECIT AMOUNT
+413,789.00
+$14,376,739.01
+SYMBOLICUSIP
+10,000,000.00
+PRICE
+101.4375
+10,000,000.00
+100.6093
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2002
+DEBIT AMUNT
+10,143,750.00
+10,060,937.50
+$20,204,687.50
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/b45fbe02a6df91d326cd3df4e7e465bcbc253c8fc1733780c3be724a8fe5219f.receipt.json b/vision-fixhub/ds9-unparsed-05/b45fbe02a6df91d326cd3df4e7e465bcbc253c8fc1733780c3be724a8fe5219f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..952e695480626568bcf5efae4c4a0e4b8c852d22
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b45fbe02a6df91d326cd3df4e7e465bcbc253c8fc1733780c3be724a8fe5219f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -38007,
+  "dataset": "marble-joined",
+  "doc_id": "b45fbe02a6df91d326cd3df4e7e465bcbc253c8fc1733780c3be724a8fe5219f",
+  "engine": "marble-apple-vision",
+  "event_count": 206,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "e9d937464b4a5eabb2f74fcc477a685359ccf190e59dd714bc0266fe205ec03c",
+  "output_sha256": "13fec4ff82b85ebdabfd7746b22331adf9a0c0f8d90e41d854286a01b8a34531",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b46d1a7033a69609a502c9444a1ce6355cd2dd0b193e12ec3c221145c4486c77.md b/vision-fixhub/ds9-unparsed-05/b46d1a7033a69609a502c9444a1ce6355cd2dd0b193e12ec3c221145c4486c77.md
new file mode 100644
index 0000000000000000000000000000000000000000..66a301a9a9cf19c19e09dab72f2f12e0b17eb5ce
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b46d1a7033a69609a502c9444a1ce6355cd2dd0b193e12ec3c221145c4486c77.md
@@ -0,0 +1,5447 @@
+Statements
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summary .....................
+Your Portfolio Holdings ............................
+Transaction Detail ...............................
+Fund Activity ........•••••...••••.•..................
+Your Messages
+....
+LEARED THROUGH IT
+Bear, Steams Securities Corp
+One Metrutech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 1, 2004
+THROUGH
+December 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30,2004
+3
+8
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+4,559,197
+NET EQUITY THIS PERIOD
+9
+434,776
+$4,993,982
+NET EQUITY LAST STATEMENT
+4,748,242
+CHANGE SINCE LAST STATEMENT
+245,740
+*This portfolio indudes one or more urpriced securies that are not
+reflected in the Total Value of Securities and the Net Equity This Period.
+There are no 'Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$434,785
+5416,505
+Cash & Equivalent
+Equities
+$4,559,197
+# 54,331,737
+Current market value
+Last statement's market value
+Important Message
+If any information
+regarding 2004 interest,
+dividends, miscellaneous
+income, gross proceeds or
+original issue discount is
+required to be reported to
+the IRS for this account, a
+Consolidated For 1099
+will be mailed to you by
+nuary 31,2005 or
+)42Sby March 15,200
+Flease report any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+so Client Servicos at 800-634-1428; or write to Cient Servicos at Bear, Stoams Securitios
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal purger rear die Set revere date for portant iformation.
+
+
+2 of 8
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklynı, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+01/01/05;09:18 001
+
+
+3 ora
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance,
+OFFICE SERACING YOUR ACCOUNT
+ear, Steams & Co. Ind
+83 Madison Avenu
+New York New York 10179
+THIS PERICO
+$3.540.00
+592.82
+17,687.41
+$18,280.23
+-21,811.11
+$-21,811.11
+......
+-3,530.88
+$9.12
+Income Summary
+Dividends
+Credit Balance Int
+Total
+...
+THIS PERIOD
+18,271.11
+9.12
+$18,280.23
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+YEAR TO DATE
+105,627.30
+852.52
+........
+$106,479.82
+..........................
+434,785
+4,559,197
+54.993.982 I
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+3,540.00
+$3,540.00
+CLOSING
+9.12
+$9.12
+027
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 1, 2004
+THROUGH
+December 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30,2004
+Your Portfolio
+Allocation
+Cash d Equivalent,
+Equities
+92%
+Unshaded portions denole debe balance andor short
+market values.
+The allocation percentage is derived
+
+
+4 of a
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York New York 10179
+LEARED THROUGH I
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 1, 2004
+THROUGH
+December 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30,2004
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+EST. 30 DAY AVG YIELD 2.0100%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOL/CUSIP
+QUANTITY
+ANNUES INCOND
+CURREN
+IELD I:
+DICXX
+434,776.19
+1.0000
+9
+434,776
+7,391
+1.7000
+$434,785
+$7,391
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the Firm's Equity Research Department, The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market Underweight, In cases where a BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers have normalized their ratings systems as follows: B = Buy; H = Hold; 5 = Sell, The ratings information contained herein
+is for informational purposes only and is not intended to provide tax, legal or investment advice. Bear Steams is neither soliciting any action based on such information, nor
+endorsing any recommendation or opinion expressed by any independent, third-party research provider. The symbol indicates that continuing coverage of the subject
+company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost. Customers can access this research
+at www.bearstearns,com or can call (800) 517-2327 to request that a copy of this research be sent to them,
+DESCRIPTION
+CANHORN CHEMICAL CORP
+FELCOR LODGING TRUST INC
+SYMBOUCUSIP
+CNCPF
+FCH
+CASH
+CASH
+QUANTITY
+19
+2,000
+PRICE
+Unpriced
+14.6500
+.......
+VALUE
+ANNUAL INCOME
+YIELD (%)
+29,300
+...........
+027
+
+
+5 or8
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+GLENBOROUGH REALTY TRUST INC
+SERENT ITEMS, LECTOR MA
+RATING: 5
+GLIMCHER REALTY TRUST-SBI
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+JOHNSON& JOHNSON
+TING:
+KRAMONT REALTY TRUST
+.....
+WTS LUCENT TECHNOLOGIES INC
+EXP 12/10/2007
+PAN PACIFIC RETAIL PROPERTIES
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+SIRIUS SATELLITE RADIO INC
+Total Equities& Options
+TOTAL EQUITIES
+SYMBCUCUSIP
+GLB
+GRT
+HRP
+HPT
+JNJ
+KRT
+LUTHW
+PNP
+PEI
+RPT
+SIRI
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York New York 10179
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+2,000
+2,000
+10,000
+2,000
+57,800
+2,000
+235
+436
+1,794
+12,000
+1,000
+PRICE
+21.2800
+27.7100
+......
+12.8300
+46.0000
+63.4200
+23.4000
+.........
+1.5800
+62.7000
+•..**..*..
+42.8000
+32.2500
+7.6500
+MARKET
+42,560
+55,420
+128,300
+......
+92,000
+3,665,676
+.......
+46,800
+.................
+371
+27,337
+76,783
+387,000
+7,650
+$4.559,197
+$4,559,197
+027
+ANNE MATER
+2,800
+3,846
+8,400
+5,760
+65,892
+2,600
+946
+3,875
+20,160
+$114,279
+$114,279
+CURRENT
+YIELD IS
+6.5789
+6.9397
+6.5472
+6.2609
+1.7975
+5.5556
+3.4605
+5.0467
+5.2093
+........
+CLEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 1, 2004
+THROUGH
+December 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+November 30, 2004
+...........
+
+
+6 of a
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGS ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+12/10/04
+TRANSACTON
+JOURNAL
+DESCRIPTION
+WTS LUCENT TECHNOLOGIES INC
+EXP 12/10/2007
+DUE 12/10/07
+CLASS ACTION SETTLEMENT
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+12/01/04
+TRANSACTION
+DESCRIPTION
+OPENINGBALANCE
+12/01/04
+BOUGHT
+12/01/04
+DIVIDEND
+STIONAL SHAEACEMENTCLA
+REYFUS CASH MANAGEMENT-CL
+INSTITUTIONAL SHARES
+MONTHLY DIVIDEND
+LEARED THROUGH IT
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 1, 2004
+THROUGH
+December 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30, 2004
+$121,670
+$4,993,982
+SYMBOLICUSIP
+LUTHW
+QUANTITY
+235
+PRICE
+DEBIT AMOUNT
+CREDIT AMOUNT
+SYM BOUCUSIP
+DICXX
+DICXX
+QUANTITY
+412,965.08
+3,540
+027
+PRICE
+1.0000
+DEBIT AMOUNT
+3,540.00
+CREDIT AMOUNT
+592.82
+......... ••• / B • / / / E
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York New York 10179
+7 of a
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+TRANSACTION
+12/01/04
+REINVEST
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CL A
+12/21/04 BOUGHT
+12/31/04
+TOTAL
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+... ..
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+12/07/04
+.....I
+12/15/04
+DESCRIPTION
+OHNSON & JOHNSO
+:C 11/16/04 PAY 12/07,
+PAN PACIFIC RETAIL PROPERTES
+REC 11/26/04 PAY 12/15/04
+12/5/04
+* PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+REC 12/01/04 PAY 12/15/04
+SYMBOUCUSIP
+JNJ
+PNP
+TOTAL
+SYM BOUCUSIP
+DICXX
+DICXX
+QUANTITY
+57,800
+436
+QUANTITY
+592.82
+17,678.29
+434,776.19
+RATE (SI
+0.2850
+0.5425
+027
+PRICE
+1.0000
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securitles Corp.
+One Metratech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 1, 2004
+THROUGH
+December 31,2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+November 30, 2004
+DEBIT AMOUNT
+592.82
+CREDIT AMOUNT
+17.678.29
+$-21,811.11
+$592.82
+DEBIT AMOUNT
+CREDIT AMCUNT
+16,473.00
+236.53
+968.76
+$17,678.29
+
+
+8 of a
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+12/21/04
+INTEREST ON CREDIT BALANCE
+ATOL 73809 11/21 - 12/20
+TOTAL
+SYMBOUCUSIP
+QUANTITY
+Your messages
+UP Florida residents who own, manage, or control stocks, bonds, money market or
+mutual funds having a value of $250,000 or more for individuals or $500,000
+or married couples filing jointly must pay a tax on these items, calle
+ntangible Tax", by June 30 to avoid increased penalties. For Tax Returns ar
+information, call the Department of Revenue at 1-800-352-3671.
+STOP
+****** End of Statement******
+RATE 1%
+DEBIT AMOUNT
+LEARED THROUGH I
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 1, 2004
+THROUGH
+December 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30,2004
+CREDIT AMOUNT
+9.12
+39.12
+As part of the National Association of Securities Dealer's (NASD) Investor
+Education Program, you may obtain information on the NASD's Public
+Disclosure Program by contacting the NASD at telephone number (800)
+289-9999 or via the internet address which is www.nasdr.com, In addition, a
+brochure explaining the Public Disclosure Program is available from the NASD
+upon request,
+027
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summary .....................
+Your Portfolio Holdings ............................
+Transaction Detail .................................
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD October 30,2004
+THROUGH
+November 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 29,2004
+3
+4
+6
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+4,331,737
+3,540
+412,965
+54,748,242
+NET EQUITY LAST STATEMENT
+4,564,327
+CHANGE SINCE LAST STATEMENT
+183,915
+*This portfolio indudes one or more unpriced securies that are not
+relected in the Total Value of Securties and the Net Equity This Period
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+5416,505
+5412,417
+Cash & Equivalent
+Equities
+5.15.910
+$4,331,737
+Current market value
+Last statement's market value
+Flease report any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+do Client Services at 800-634-1428; or write to Cient Servicos at Bear, Stoama Securitios
+Corp.. One Metrolech Center North, Brooklyn, N.Y. 11201-3669.
+SIP The suremen is four ratanal purger red de Set revere date for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklynı, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 of7
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+..LL...
+Money Fund
+Amount Debitad
+Net Cash Activity
+Closing Balance
+ear, Steams & Co. Ind
+83 Madison Avenu
+New York. New York 10179
+THIS PERIOD
+$653.29
+548.28
+3,540.00
+$4.088.28
+-1,201.57
+$.1,201.57
+2,886.71
+38.50.00
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+4,088.28
+0.00
+$4,088.28
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+YEAR TO DATE
+87,356.19
+843.40
+......
+$88,199.59
+..**.*.•...***.....
+416,505
+4,331,737
+34748242..
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+653.29
+$653.29
+CLOSING
+3,540.00
+$3,540.00
+027
+12/01/04;14:42 001
+LEARED THROUGH I
+Bear, Steams Secunities Corp
+One Metrutech Center North
+Brooklym, New Yonk 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOO October 30,2004
+THROUGH
+November 30, 2004
+ACCOUNT NUMBER
+TAPAYER NUMBER On File
+LAST STATEMENT
+October 29,2004
+Your Portfolio
+Allocation
+Cash & Equivalent,
+Equities
+92%
+Unshaded portons denate debit balance andor shart
+market values. The alocation percentage is derived
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York New York 10179
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD October 30,2004
+THROUGH
+November 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 29,2004
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+EST. 30 DAY AVG YIELD 1,8400%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOL/CUSIP
+DICXX
+QUANTITY
+412,965.08
+1.0000
+3,540
+412,965
+$416,505
+WWAS INCOM
+NCOME
+CURREN
+FELD IS
+6,607
+1.5999
+$6,607
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the Firm's Equity Research Department, The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market Underweight. In cases where a BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers have normalized their ratings systems as follows: B = Buy; H = Hold; 5 = Sell, The ratings information contained herein
+is for informational purposes only and is not intended to provide tax, legal or investment advice. Bear Steams is neither soliciting any action based on such information, nor
+endorsing any recommendation or opinion expressed by any independent, third-party research provider. The symbol indicates that continuing coverage of the subject
+company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost. Customers can access this research
+at www.bearstearns,com or can call (800) 517-2327 to request that a copy of this research be sent to them,
+DESCRIPTION
+CANHORN CHEMICAL CORP
+FELCOR LODGING TRUST INC
+SYMBOUCUSIP
+CNCPF
+FCH
+CASH
+CASH
+QUANTITY
+19
+2,000
+PRICE
+Unpriced
+12.9400
+.......
+VALUE
+ANNUAL INCOME
+YIELD (%)
+25,880
+027
+
+
+5 or 7
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+GLENBOROUGH REALTY TRUST INC
+SERENT SYSTEMS, LECTOR MA
+RATING: H
+GLIMCHER REALTY TRUST-SBI
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+JOHNSON & JOHNSON
+SYMBOUCUSIP
+GLB
+GRT
+HRP
+HPT
+JNJ
+KRAMONT REALTY TRUST
+MAN PACIFIC RETAIL PROPERTES
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+... .
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+SIRIUS SATELLITE RADIO INC
+BSC RATING: STOCK O/SECTOR MW
+ATLANTIS RESEARCH RATING: B
+Total Equities& Options
+TOTAL EQUITIES
+KRT
+PNP
+PEI
+RPT
+SIRI
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York New York 10179
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+2,000
+2,000
+10,000
+2,000
+57,800
+2,000
+436
+1,794
+12,000
+1,000
+PRICE
+21.8400
+26.9500
+12.0900
+44.9400
+60.3200
+20.1200
+.................
+59.3000
+40.7500
+30.4300
+6.6400
+MARKET
+43,680
+53,900
+..............
+120,900
+89,880
+3,486,496
+40,240
+HI HOL HARI DOI
+25,855
+73,106
+365,160
+6,640
+$4,331,737
+$4,331,737
+027
+ANNE MATER
+2,800
+3,846
+8,400
+5,760
+65,892
+2,600
+...•. •
+946*
+3,875
+20,160
+$114,279
+$114,279
+CURRENT
+6.403
+7.1354
+6.9479
+6.4085
+1.8899
+6.4612
+......
+3.6589
+5.3005
+5.5209
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securitles Corp.
+One Metratech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD October 30, 2004
+THROUGH
+November 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+October 29,2004
+.. ..
+
+
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGS ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+MONEY FUND ACTIVITY
+TRANSACTION
+10/30/04
+11/01/04
+11/01/04
+DIVIDEND
+REINVEST
+11/02/04
+BOUGHT"
+11/30/04
+TOTAL
+DESCRIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT. CLA
+MONTHLY DAD ARE S
+•DREYFUS CASH MANAGEMENT-CLA
+INDEND RESISTES
+•DREYFUS CASH MANAGEMENT. CLA
+INSTITUTIONAL SHARES
+CLOSINGBALANCE
+SYM BOUCUSIP
+X010
+*DICXX
+DiCXX
+$120,886
+$4,748,242
+QUANTITY
+411,763.51
+548.28
+653.29
+412,965.08
+027
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD October 30,2004
+THROUGH
+November 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 29,2004
+PRICE
+DEBIT AMOUNT
+1.0000
+548.28
+653.29
+$-1,201.57
+CREDIT AMOUNT
+548.28
+..............................
+$548.28
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+DIVIDENDS
+DATE
+11/19/04
+DESCRIPTION
+HOSPITALITY PROPERTIES TRUST
+SEC 10/2/04 PAY 11/19/04
+i1/22/04
+HRPT PROPERTIES TR-SBI
+REC 10/22/04 PAY 11/22/04
+TOTAL
+SYMBOUCUSIP
+HPT
+STOP
+****** End of Statement******
+QUANTITY
+2,000
+10,000
+RATE (SI
+0.7200
+0.2100
+027
+DEBIT AMOUNT
+LEARED THROUGH I
+Bear, Steams Securitles Corp.
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD October 30,2004
+THROUGH
+November 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 29,2001
+CREDIT AMOUNT
+1,440.00
+2,100.00
+$3,540.00
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary .....................
+Your Portfolio Holdings ............................
+Transaction Detail .................................
+LEARED THROUGH IT
+Bear, Steams Securities Corp
+One Metrutech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD October 1,2004
+THROUGH
+October 29, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30, 2004
+3
+4
+6
+Hollandlol
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+4,151,910
+653
+411,764
+$4,564,327
+NET EQUITY LAST STATEMENT
+4,426,431
+CHANGE SINCE LAST STATEMENT
+137,897
+*This portfolio indudes one or more unpriced securies that are not
+relected in the Total Value of Securties and the Net Equity This Period
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+412,41
+404,61
+Cash & Equivalent
+Equities
+1 540215182
+$4,151,910
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+do Client Services at 800-634-1428; or write to Cient Servicos at Bear, Stoama Securitios
+Corp.. One Metrolech Center North, Brooklyn, N.Y. 11201-3669.
+SP The suremen is four ratanal purger red die Set revere dae for portant iformation.
+10/30/04:11:50001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklynı, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+10/30/04;11:50 001
+
+
+3 or 7
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance
+OFFICE SERACING YOUR ACCOUNT
+ear, Steams & Co. Ind
+83 Madison Avenu
+New York New York 10179
+THIS PERICO
+$115.78
+449.24
+7,354.89
+57,804.13
+-7,266.62
+5-7,266.62
+......
+537.51
+$653.29
+Income Summary
+Dividends
+Credit Balance Int
+Total
+THIS PERIOD
+7,800.84
+3.29
+57,804.13
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+YEAR TO DATE
+83,267.91
+843.40
+.. . .
+$84,111.31
+412,417
+4,151,910
+_ 54.564.32......
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+115.78
+$115.78
+CLOSING
+653.29
+$653.29
+027
+10/30/04;11:50 001
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD October 1,2004
+THROUGH
+October 29, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+September 30,2004
+Your Portfolio
+Allocation
+Cash & Equivalent.
+Equities
+91%
+Unshaded portions denote debit balance and or shart
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York New York 10179
+LEARED THROUGH IT
+Bear, Steams Securities Comp
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD October 1,2004
+THROUGH
+October 29, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2004
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+DREYFUS CASH MANAGEMENT-CL A
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOL/CUSIP
+DICXX
+QUANTITY
+411,763.51
+PRICE
+1.0000
+653
+411,764
+$412,417
+ESTIMATE
+NNUAL INCOM
+5,765
+$5.765
+CURREN
+VELD I:
+1.4001
+EQUITIES
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the Firm's Equity Research Department, The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market Underweight. In cases where a BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers have normalized their ratings systems as follows: B = Buy; H = Hold; 5 = Sell. The ratings information contained herein
+is for informational purposes only and is not intended to provide tax, legal or investment advice, Bear Steams is neither soliciting any action based on such information, nor
+endorsing any recommendation or opinion expressed by any independent, third-party research provider, The symbol indicates that continuing coverage of the subject
+company is temporarily not available due to legal reasons,
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost. Customers can access this research
+at www.bearstearns,com or can call (800) 517-2327 to request that a copy of this research be sent to them,
+DESCRIPTION
+SYMBOUCUSIP
+ACCE
+QUANTITY
+PRICE
+VALUE
+ANNUAL INCOME
+YIELD (%)
+CANHORN CHEMICAL CORP
+CNCPF
+CASH
+19
+Unpriced
+FELCOR LODGING TRUST INC
+BSC RATING: STOCK USECTOR MW
+FCH
+CASH
+2,000
+11.6200
+23,240
+GREEN STREET ADVISORS, INC.
+RATING: S
+027
+10/30/04:11:50 001
+
+
+5 or 7
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+GLENBOROUGH REALTY TRUST INC
+SERENT SYSTEMS, LECTOR MA
+RATING: H
+GLIMCHER REALTY TRUST-SBI
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+JOHNSON& JOHNSON
+SYMBOUCUSIP
+GLB
+GRT
+HRP
+HPT
+JNJ
+KRAMONT REALTY TRUST
+MAN PACIFIC RETAIL PROPERTES
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+... .
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+KRT
+PNP
+PEI
+RPT
+SIRIUS SATELLITE RADIO INC
+BSC RATING: STOCK O/SECTOR MW
+ATLANTIS RESEARCH RATING: H
+Total Equities& Options
+TOTAL EQUITIES
+SIRI
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York New York 10179
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+2,000
+2,000
+10.000
+2,000
+57,800
+2,000
+436
+1,794
+12,000
+1,000
+PRICE
+21.0000
+25.8200
+......
+11.1900
+42.8500
+58.3800
+18.8600
+...........
+56.6500
+40.5500
+.......
+27.0000
+3.9000
+MARKET
+VALUE
+42,000
+51,640
+.........
+111,900
+........
+85,700
+3,374,364
+37,720
+24,699
+72,747
+324,000
+3,900
+$4,151,910
+$4,151,910
+027
+2,800
+3,846
+8,400
+5,760
+65,892
+2,600
+...•. •
+946*
+3,875
+20,160
+$114,279
+$114,279
+CURRENT
+YIELD 196)
+6.6667
+7.4477
+7.5067
+6.7211
+1.9527
+6.8929
+........
+3.8301
+5.3267
+6.2222
+10/30/04:11:50 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD October 1, 2004
+THROUGH
+October 29, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+September 30, 2004
+.............
+
+
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGS ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+MONEY FUND ACTIVITY
+TRANSACTION
+10/01/04
+10/01/04
+10/01/04
+DIVIDEND
+REINVEST
+1ö/20/04
+"BOUGHT
+10/29/04
+TOTAL
+DESCRIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT. CLA
+MONTHLY DAD SNARES
+•DREYFUS CASH MANAGEMENT-CLA
+INDEND RESENTES
+"DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+CLOSINGBALANCE
+SYM BOUCUSIP
+X010
+*DICXX
+DiCXX
+$120,044
+$4,564,327
+QUANTITY
+404,496.89
+••I•
+449.24
+6,817.38
+411,763.51
+027
+LEARED THROUGH IT
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD October 1,2004
+THROUGH
+October 29, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30, 2004
+PRICE
+DEBIT AMOUNT
+CREDIT AMOUNT
+449.24
+..................................................-
+1.0000
+449.24
+6,817.38
+$-7,266.62
+$449.24
+10/30/04:11:50 001
+
+
+Transaction Detail (continued)
+DIVIDENDS
+DATE
+10/01/04
+DESCRIPTION
+RAMCO GERSHENSON PROPERTIES
+TEC 0920,04 PAY 10/021141
+10/15/04
+GLENBOROUGH REALTY TRUST INC
+REC 10/01/04 PAY 10/15/04
+10/15/04
+"GLIMCHER REALTY TRUST-SE
+EC 09/30/04 PAY 10/15/0
+10/22/04
+KRAM ONT REALTY TRUST
+REC 09/24/04 PAY 10/22/04
+TOTAL
+INTEREST
+DATE
+10/21/04
+DESCRIPTION
+INTEREST ON CREDIT BALANCE
+ATO1.12500% 09/21 - 10/20
+TOTAL
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+SYM BOUGUSIP
+RPT
+KRT
+SYM BOUCUSIP
+STOP
+****** End of Statement******
+QUANTITY
+12,000
+2,000
+2,000
+2,000฿
+QUANTITY
+RATE (S)
+0.4200
+0.3500
+0.4808
+0.3250
+RATE (%)
+027
+DEBIT AMOUNT
+..............I
+DEBIT AMOUNT
+10/30/04;11:50 001
+CLEARED THROUGH IT
+Bear, Steams Secuntles Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD October 1,2004
+THROUGH
+October 29, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+September 30,2004
+CREDIT AMOUNT
+5,040.00
+700.00
+961.60
+650.00
+$7,351.60
+CREDIT AMOUNT
+3.29
+$3.29
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summary .....................
+Your Portfolio Holdings ............................
+Transaction Detail .................................
+Fund Activity ........•••••...••••.•..................
+Your Messages
+....
+LEARED THROUGH IT
+Bear, Steams Securities Corp
+One Metrutech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 1, 2004
+THROUGH
+September 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31,2004
+3
+8
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+4,021,818
+116
+404,497
+54,426,431
+NET EQUITY LAST STATEMENT
+4,507,195
+CHANGE SINCE LAST STATEMENT
+-80,764
+*This portfolio indudes one or more unpriced securies that are not
+relected in the Total Value of Securties and the Net Equity This Period
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+5404,613
+$386,819
+Cash & Equivalent
+Equities
+1. $4.021,8.
+#m $4.120.31
+Current market value
+Last statement's market value
+Please report any difference or non-receipt of chocks or stocks, indicaled as delivered to you.
+1o Client Services at 800-634-1428; or write to Cient Services at Bear, Stoams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen is four ratanal furyce red die Set revere date for portant iformation.
+
+
+2 of 9
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklynı, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or 9
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Money Fund
+amount Debite!
+Net Cash Activity
+Closing Balance.
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+$386,818.60
+17,794.07
+$17,794.07
+-404,496.89
+404,496.8
+-386,702.82
+$115.78
+Income Summary
+Dividends
+Credit Balance Int
+Total
+....
+THIS PERIOD
+17,678.29
+115.78
+$17,794.07
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+YEAR TO DATE
+75,467.07
+840.11
+........
+$76,307.18
+.. . .
+404,613
+4,021,818
+_ 54.26.43L ..
+Cash Balance Summary
+Cash
+OPENING
+386,818.60
+Net Cash Balance
+.. . ..
+$386,818.60
+CLOSING
+115.78
+...
+$115.78
+.....
+027
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp
+One Metrutech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 1, 2004
+THROUGH
+September 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31,2004
+Your Portfolio
+Allocation
+Cash & Equivalent.
+Equities
+91%
+Unshaded portions denote debit balance and'or short
+from the absolute market value of your portlolo.
+
+
+4 of g
+ear, Steams & Co. Inc
+83 Madison Avenu
+New York New York 10179
+LEARED THROUGH IT
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 1, 2004
+THROUGH
+September 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31, 2004
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+EST. 30 DAY AVG YIELD 1,5500%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOL/CUSIP
+DICXX
+QUANTITY
+404,496.89
+PRICE
+1.0000
+116
+404,497
+$404,613
+ESTIMATE
+(NUAL INCON
+CURREN
+VELD I:
+5,258
+1.2999
+$5,258
+EQUITIES
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the Firm's Equity Research Department, The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market Underweight. In cases where a BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers have normalized their ratings systems as follows: B = Buy; H = Hold; 5 = Sell. The ratings information contained herein
+is for informational purposes only and is not intended to provide tax, legal or investment advice, Bear Steams is neither soliciting any action based on such information, nor
+endorsing any recommendation or opinion expressed by any independent, third-party research provider, The symbol indicates that continuing coverage of the subject
+company is temporarily not available due to legal reasons,
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost. Customers can access this research
+at www.bearstearns,com or can call (800) 517-2327 to request that a copy of this research be sent to them,
+DESCRIPTION
+SYMBOUCUSIP
+ACCE
+QUANTITY
+PRICE
+VALUE
+ANNUAL INCOME
+YIELD (%)
+CANHORN CHEMICAL CORP
+CNCPF
+CASH
+19
+Unpriced
+FELCOR LODGING TRUST INC
+BSC RATING: STOCK USECTOR MW
+FCH
+CASH
+2,000
+11.3100
+22,620
+GREEN STREET ADVISORS, INC.
+RATING: S
+027
+
+
+5 or g
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+GLENBOROUGH REALTY TRUST INC
+SERENT SYSTEMS, LECTOR MA
+RATING: H
+GLIMCHER REALTY TRUST-SBI
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+JOHNSON& JOHNSON
+SYMBCUCUSIP
+GLB
+GRT
+HRP
+HPT
+JNJ
+KRAMONT REALTY TRUST
+MAN PACIFIC RETAIL PROPERTES
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+... .
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+KRT
+PNP
+PEI
+RPT
+SIRIUS SATELLITE RADIO INC
+BSC RATING: STOCK O/SECTOR MW
+ATLANTIS RESEARCH RATING: H
+Total Equities& Options
+TOTAL EQUITIES
+SIRI
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York New York 10179
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+2,000
+2,000
+10.000
+2,000
+57,800
+2,000
+........
+436
+1,794
+12,000
+1,000
+PRICE
+20.7700
+24.3000
+10.9900
+42.4900
+56.3300
+18.6000
+I DO NOR NORTH.
+54.1000
+38.6600
+27.0800
+3.2000
+MARKET
+VALUE
+41,540
+48,600
+109,900
+84,980
+3,255,874
+37,200
+23,588
+69.356
+324,960
+3,200
+$4,021,818
+$4,021,818
+027
+ANNE MATER
+2,800
+3,846
+8,400
+5,760
+65,892
+2,600
+946
+3,875
+20,160
+$114,279
+$114,279
+CURRENT
+YIELD IS)
+6.7405
+7.9136
+7.6433
+6.7781
+2.0238
+6.9892
+.. nor nor
+4.0105
+5.5871
+6.2038
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securitles Corp.
+One Metratech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 1, 2004
+THROUGH
+September 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+August 31, 2004
+..IHI..
+...............
+
+
+6 of g
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+MONEY FUND ACTIVITY
+TRANSACTION
+09/01/04
+09/02/04
+BOUGHT
+09/15/04
+BOUGHT
+09/30/04
+TOTAL
+DESCRIPTION
+OPENINGBALANCE
+INSTITONA SHALACEMENTCLA
+STONE SHALCEMEVFICLA
+.......-............
+CLOSINGBALANCE
+SYM BOUCUSIP
+*DICXX
+DICXX
+$119,537
+$4,426,431
+QUANTITY
+0.00
+186,818.60
+17,678.29
+404,496.89
+027
+LEARED THROUGH IT
+Bear, Steams Securities Corp
+One Metrutech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 1, 2004
+THROUGH
+September 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31, 2004
+PRICE
+1.0000*
+1.0000
+DEBIT AMOUNT
+86,818.64
+17.678.29
+$-404,496.89
+CREDIT AMOUNT
+
+
+7 of g
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+DIVIDENDS
+DATE
+DESCRIPTION
+09/07/04
+LEE 0807104 PAY 09/07104
+09/15/04
+"PAN PACIFIC RETAIL PROPERTIES
+09/15/04
+REC 08/27104 PAY 09/15/04
+• GYLVANIA REAL ESTATE
+TOTAL
+INTEREST
+DATE
+09/21/04
+DESCRIPTION
+INTEREST ON CREDIT BALANCE
+A 00. 57500% 08/21 - 09/20
+TOTAL
+SYMBOUCUSIP
+JNJ
+PNP
+SYMBOUCUSIP
+QUANTITY
+57,800
+436
+1,794
+QUANTITY
+RATE (S)
+0.2850
+0.5425
+0.5400
+RATE (%)
+027
+DEBIT AMOUNT
+.......
+CLEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 1, 2004
+THROUGH
+September 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31, 2004
+CREDIT AMOUNT
+16,473.00
+236.53
+968.76
+$17,678.29
+DEBIT AMOUNT
+CREDIT AMOUNT
+115.78
+$115.78
+
+
+8 of 9
+ear, Steams & Co. Ir
+83 Madison Avenu
+New York New York 10179
+Your messages
+Bear, Stearns Securities Corp. Net Capital and Net Capital Requirements:
+a mamatey 536 billon and 53,6 bitton was aps netial 6, 8% and 6,59
+of aggregate debit items and exceeded the minimum regulatory net capita
+525 bion an 325 milon, al respectivelyd 51.1 bilin by approximately
+A complete copy of the Bear, Steams Securities Corp, Statement of Financial
+Condition is available on the web site www.bearsteams.com. Alternatively, to
+request a free printed copy please call - toll free 1-866-299-9331.
+Bear, Steams Securities Comp
+One Metrutech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 1, 2004
+THROUGH
+September 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+August 31,2004
+Le Securities and other assets in your account are the firm's collateral for any
+margin loan made to you. If the securities and other assets in your account
+decline in value, so does the value of the collateral supporting your loan, and
+as a result, the firm can take action, such as issue a margin call and/or sell
+securities or other assets in any of your accounts held with the member, in
+order to maintain the required equity in the account. It is important that you
+fully understand the risks involved in trading securities on margin, These risks
+include the following:
+* You can lose more funds than you deposit in the margin account.
+* The firm can force the sale of securities or other assets in your accounts).
+* The firm can sell your securities or other assets without contacting you.
+* You are not entitled to choose which securities or other assets in your
+accounts) are liquidated or sold to meet a margin call.
+" The firm can increase its house" maintenance margin requirements at any
+ime and is not required to provide you advance written notice
+* You are not entitled to an extension of time on a margin call.
+027
+
+
+9 of 9
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+This statement is provided to explain Bear, Steams & Co. Inc.'s ('BSC")
+payment for order flow practices.
+BSC routes a majority of orders for customer securities transactions to the
+primary market for such securities
+receives no cash payment or other consideration for such order routing othe
+than favorable executions or executions of limit orders at no additional charge.
+STOP
+****** End of Statement******
+Bear, Steams Securitles Corp.
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 1, 2004
+THROUGH
+September 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+August 31, 2004
+Pursuant to SEC Rule 11Ac1-6, please note the following:
+Bear, Steams & Co. Inc. will post its quarterly routing statistics at the following
+web link: http://www.bearsteams.com. Click on Individual Investor, Click on
+Equities, Click on Order Routing Practices.
+Customers of Bear, Stears & Co. Inc, may request information on any order
+executed within the prior six months from the time of the request. Specifically
+you may request the identity of the venue to which the identified orders were
+routed for execution, whether the order was directed by you to that venue, and
+the time of the executions, if any, that resulted from such orders.
+027
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summ..............................
+Your Portfolio Holdings ............................
+Transaction Detail
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD July 31,2004
+THROUGH
+August 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 30, 2004
+4
+Hollandlold
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+NET CREDIT BALANCE
+4,120,376
+386,819
+NET EQUITY THIS PERIOD
+$4,507,195
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+4,288,232
+218,963
+This portfolio includes one or more unpriced securties that are not
+elected in the Total Value of Securtes and the Net Equity This Period
+Market Value of Your Portfolio
+$386,819
+$383,017
+Cash & Equivalent
+Equities
+53.005.215
+$4,120,376
+......
+Current market value
+Last statement's market value
+Or el are or ers one or our acher pending bay
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP This suremen s four or ratanal furyce red de Set revere date for portant iformation.
+027
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklynı, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or 8
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York New York 10179
+THIS PERIOD
+$383,016.57
+3,802.03
+$3,802.03
+3,802.03
+386,818.60
+Income Summary
+Dividends
+Credit Balance Int
+Total
+THIS PERIOD
+3,540.00
+262.03
+$3,802.03
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+OPENING
+383,016.57
+Net Cash Balance
+$383,016.57
+CLOSING
+386,818.60
+$386,818.60
+027
+YEAR TO DATE
+57,788.78
+724.33
+........
+$58,513.11
+.......
+386,819
+4,120,376
+4,507,19
+1100188818880888881..1......I....
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD July 31,2004
+THROUGH
+August 31,2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT July 30,2004
+Your Portfolio
+Allocation
+Cash d Equivalent,
+Equities
+92%
+Unshaded portions denole debe balance andor short
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+LEARED THROUGH IT
+Bear, Steams Securtles Corp.
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD July 31,2004
+THROUGH
+August 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 30, 2004
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+QUANTITY
+PRICE
+MARKET
+386,819
+$386,819
+ESTIMATED
+ANNUAL INCOME
+CURRENT
+(IELD IS
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the Firm's Equity Research Department, The first rating represents the stock's total retum
+relative to the other stocks covered by that Analyst, The key for the stock rating values is as follows: O= Outperform; P = Peer Perform; U = Underperform, The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market Underweight. In cases where a BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers have normalized their ratings systems as follows: B = Buy; H = Hold; 5 = Sell, The ratings information contained herein
+is for informational purposes only and is not intended to provide tax, legal or investment advice, Bear Steams is neither soliciting any action based on such information, nor
+endorsing any recommendation or opinion expressed by any independent, third-party research provider, The symbol indicates that continuing coverage of the subject
+company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stears at no cost, Customers can access this research
+at www.bearstears.com or can call (800) 517-2327 to request that a copy of this research be sent to them.
+MARKET
+VALUE
+ESTIMATED
+ANNUAL INCOME
+CURRENT
+YEID IS
+DESCRIPTION
+CANHORN CHEMICAL CORP
+FELCOR LODGING TRUST INC
+BSC RATING: STOCK U/SECTOR MW
+GREEN STREET ADVISORS, INC.
+RATING: S
+GLENBOROUGH REALTY TRUST INC
+SAGENT STEMS, LECTOR MA
+RATING: H
+5YM BOUCUSIP
+CNCPF
+FCH
+CASH
+... ...
+CASH
+QUANTITY
+19
+2,000
+PRICE
+Unpriced
+11.7100
+...I...I.
+23,420
+GLB
+CASH
+2,000
+20.4800
+40,960
+2,800
+6.8359
+027
+09/01/04:08:31 001
+
+
+5 or8
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+GLIMCHER REALTY TRUST-SBI
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+JOHNSON& JOHNSON
+SYMBOLCUSIP
+GRT
+HRP
+HPT
+CASH
+CASH
+*••••.•••..
+CASH
+INJ
+CASH
+KRAMONT REALTY TRUST
+PAN PACIFIC RETAIL PROPERTIES
+INC
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+...........
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+KRT
+PNP
+CASH
+CASH
+PEI
+CASH
+RPT
+CASH
+SIRIUS SATELLITE RADIO INC
+SIRI
+CASH
+Total Equities& Options
+TOTAL EQUITIES
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+QUANTITY
+2,000
+10.000
+2,000
+57,800
+2,000
+436
+1,794
+12,000
+1,000
+PRICE
+25.3400
+.......
+10.7800
+41.9500
+58.1000
+18.4800
+•........ .
+53.3900
+38.2600
+27.0200
+..........
+2.3200
+MARKET
+VALUE
+50,680
+...........
+107,800
+....
+83,900
+3,358,180
+36,960
+.....
+23,278
+68,638
+324,240
+2,320
+$4,120,376
+$4,120,376
+$114,279
+-
+$4,507,195
+027
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Conp.
+One Metrutech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOO July 31,2004
+THROUGH
+August 31,2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+July 30, 2004
+ANHUS MAOEE
+CURRENT
+YIELD 1%)
+3,846
+7.5888
+........
+.......
+8,400
+7.7922
+............ . .
+5,760
+6.8653
+65,892
+1.9621
+2,600
+946
+3,875
+20,160
+$114,279
+$114,279
+7.0346
+4.0639
+5.6456
+6.2176
+.......
+..I..
+nasraaIs daI aasI aaRI aa
+
+
+6 of B
+Transaction Detail
+DIVIDENDS
+DATE
+08/20/04
+DESCRIPTION
+HOSPITALITY PROPERTIES TRUST
+SEC 07/22/04 PAY 08/20104
+08/25/04
+HRPT PROPERTIES TR-SBI
+TOTAL
+REC 07/23/04 PAY 08/25/04
+INTEREST
+DATE
+08/23/04
+DESCRIPTION
+INTEREST ON CREDIT BALANCE
+AT 0.73486950/21 - 08/20
+TOTAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUCUSIP
+HPT
+SYM BOUCUSIP
+STOP
+****** End of Statement******
+QUANTITY
+2,000
+10,000
+QUANTITY
+RATE (S)
+0.7200
+0.2100
+RATE 1%
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+LEARED THROUGH I
+Bear, Steams Securtles Corp.
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD July 31,2004
+THROUGH
+August 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 30, 2004
+CREDIT AMOUNT
+1,440.00
+2,100.00
+$3,540.00
+CREDIT AMCUNT
+262.03
+$262.03
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summ..............................
+Your Portfolio Holdings ...........................
+Transaction Detail
+LEARED THROUGH IT
+Bear, Steams Securities Corp
+One Metrutech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD July 1, 2004
+THROUGH
+July 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 30, 2004
+4
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+3,905,215
+383,017
+$4,288,232
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+4,294,063
+-5,832
+"This portfolio indudes one or more unpriced securties that are not
+relected in the Total Value of Securties and the Net Equity This Period
+or sel apen ries one or your acher pending buy
+Market Value of Your Portfolio
+$383,017
+$375,451
+Cash & Equivalent
+Equities
+$3,905,215
+- 53010.612
+......
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four or ratanal furyce rela die Set revere date for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklynı, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or 8
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York New York 10179
+THIS PERIOD
+$375,451.48
+7,565.09
+$7,565.09
+7,565.09
+.$383.016.57
+Income Summary
+THIS PERIOD
+Dividends
+7,351.60
+Credit Balance Int
+213.49
+Total
+7.565.0
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+YEAR TO DATE
+54,248.78
+462.30
+........
+$54,711.08
+.. ...
+383,017
+3,905,215
+.. 34,288,232 ..
+Cash Balance Summary
+Cash
+OPENING
+375,451.48
+Net Cash Balance
+$375,451.48
+CLOSING
+383,016.57
+$383,016.57
+027
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD July 1, 2004
+THROUGH
+July 30,2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+June 30,2004
+Your Portfolio
+Allocation
+Cash d Equivalent,
+Equities
+92%
+Unshaded portions denote debit balance and or shart
+market values.
+The alocation percentage is derived
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD July 1, 2004
+THROUGH
+July 30,2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 30,2004
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+QUANTITY
+PRICE
+MARKER
+383,017
+$383,017
+ESTIMATED
+ANNUAL INCOME
+CURRENT
+(IELD IS
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the Firm's Equity Research Department, The first rating represents the stock's total retum
+relative to the other stocks covered by that Analyst, The key for the stock rating values is as follows: O= Outperform; P = Peer Perform; U = Underperform, The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market Underweight. In cases where a BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers have normalized their ratings systems as follows: B = Buy; H = Hold; 5 = Sell, The ratings information contained herein
+is for informational purposes only and is not intended to provide tax, legal or investment advice, Bear Steams is neither soliciting any action based on such information, nor
+endorsing any recommendation or opinion expressed by any independent, third-party research provider, The symbol indicates that continuing coverage of the subject
+company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stears at no cost, Customers can access this research
+at www.bearstearns.com or can call (800) 517-2327 to request that a copy of this research be sent to them.
+MARKET
+VALUE
+ESTIMATED
+ANNUAL INCOME
+CURRENT
+YIELD 15
+DESCRIPTION
+CANHORN CHEMICAL CORP
+FELCOR LODGING TRUST INC
+BSC RATING: STOCK U/SECTOR MW
+GREEN STREET ADVISORS, INC.
+RATING: S
+GLENBOROUGH REALTY TRUST INC
+SAGENT STEMS, LECTOR MA
+RATING: H
+5YM BOUCUSIP
+CNCPF
+FCH
+CASH
+CASH
+QUANTITY
+19
+2,000
+PRICE
+Unpriced
+11.4000
+22,800
+GLB
+CASH
+2,000
+....
+18.2800
+36,560
+2,800
+7.6586
+027
+07/31/04:08:41 001
+
+
+5 or 8
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+GLIMCHER REALTY TRUST-SBI
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+JOHNSON& JOHNSON
+SYMBOLICUSIP
+GRT
+HRP
+HPT
+CASH
+CASH
+CASH
+INJ
+CASH
+KRAMONT REALTY TRUST
+PAN PACIFIC RETAIL PROPERTIES
+INC
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+.........
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+KRT
+PNP
+CASH
+CASH
+PEI
+CASH
+RPT
+CASH
+SIRIUS SATELLITE RADIO INC
+SIRI
+CASH
+Total Equities& Options
+TOTAL EQUITIES
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+QUANTITY
+2,000
+10,000
+2,000
+57,800
+2,000
+436
+1,794
+12,000
+1,000
+PRICE
+21.6600
+10.0700
+39.8800
+55.2700
+15.9000
+......
+50.6000
+34.8700
+25.7100
+.........
+2.5300
+MARKET
+VALUE
+43,320
+........
+100,700
+............
+79,760
+3,194,606
+31,800
+....
+22,062
+62,557
+308,520
+2,530
+$3.905,215
+$3.905,215
+$114,279
+$4,288,232
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Secuntles Corp.
+One Metratech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD July 1,2004
+THROUGH
+July 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+June 30, 2004
+ANUS HARD
+CURRENT
+YIELD 1S
+3,846
+8.8781
+.......
+8,400
+..........•...
+8.3416
+... ...
+5,760
+7.2217
+65.892
+2.0626
+2,600
+946
+3,875
+20,160
+8.1761
+4.2879
+6.1944
+6.5344
+$114,279
+$114,279
+
+
+Transaction Detail
+DIVIDENDS
+DATE
+07/01/04
+DESCRIPTION
+RAM CO GERSHENSON PROPERTIES
+TEC 0620104 PAY 07/0104
+07/15/04
+GLENBOROUGH REALTY TRUST INC
+REC 07/01/04 PAY 07/15/04
+0775104'
+'GLIMCHER REALTY TRUSTSE
+EC 06/30/04 PAY 07/15/04
+07/22/04
+KRAM ONT REALTY TRUST
+REC 06/25/04 PAY 07/22/04
+TOTAL
+INTEREST
+DATE
+07/21/04
+DESCRIPTION
+INTEREST ON CREDIT BALANCE
+Af 0.67573% 06/21 - 07/20
+TOTAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+SYM BOUGUSIP
+RPT
+KRT
+SYM BOUCUSIP
+STOP
+****** End of Statement******
+QUANTITY
+12,000
+2,000
+2,000
+2,000฿
+QUANTITY
+RATE (S)
+0.4200
+0.3500
+0.4808
+0.3250
+RATE (%)
+027
+DEBIT AMOUNT
+..............I
+DEBIT AMOUNT
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD July 1, 2004
+THROUGH
+July 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+June 30, 2004
+CREDIT AMOUNT
+5,040.00
+700.00
+961.60
+650.00
+$7,351.60
+CREDIT AMOUNT
+213.49
+$213.49
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearsteams.com
+What's In This Statement
+Financial Summary .....................
+Your Portfolio Holdings
+Transaction Detail ...............................
+Your Messages
+..........
+LEARED THROUGH IT
+Bear, Steams Securities Con
+he Metrutech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD May 29, 2004
+THROUGH
+June 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 28, 2004
+3
+4
+7
+Hollandlol
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+NET CREDIT BALANCE
+3,918,612
+375,451
+NET EQUITY THIS PERIOD
+$4,294,063
+....
+NET EQUITY LAST STATEMENT
+4,280,455
+CHANGE SINCE LAST STATEMENT
+13,609
+"This portfolio indudes one or more unpriced securties that are not
+relected in the Total Value of Securites and the Net Equity This Period
+Market Value of Your Portfolio
+$375,451
+$108,113
+Cash & Equivalent
+Equities
+1$3.918,612
+$4,172,342
+Current market value
+Last statement's market value
+Important Message
+Confirmation: Unless we
+ear from you to th
+ontrary, it is ou
+understanding that any free
+redit balances in your
+account are bein
+maintained to facilitate
+ur intention to inve
+ich amounts through u
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four ratanal purpose rear die Set revere date for portant iformation.
+
+
+2 of 8
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklynı, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 ora
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York New York 10179
+THIS PERICD
+$108,112.58
+249,597.25
+17,741.65
+$267,338.90
+......
+267,338.90
+. 3373.451.48
+Income Summary
+Dividends
+Credit Balance Int
+THIS PERIOD
+17,678.29
+63.36
+$17.741.65
+....
+..........
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+OPENING
+Cash
+Net Cash Balance
+108,112.58
+5108112.58
+CLOSING
+375,451.48
+....
+375.451.48
+027
+YEAR TO DATE
+46,897.18
+248.81
+.....I.I
+47,145.9
+375,451
+3,918,612
+$4,294,063
+.....
+LEARED THROUGH I
+Bear, Steams Securities Con
+One Metrutech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD May 29,2004
+THROUGH
+June 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+May 28, 2004
+Your Portfolio
+Allocation
+Cash & Equivalent —
+8%
+Equities
+92%
+Unshaded portions denote debe balance andor short
+market values.
+The alocation percentage is derived
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+CANHORN CHEMICAL CORP
+..... . . . . .
+FELCOR LODGING TRUST INC
+GLENBOROUGH REALTY TRUST INC
+GLIMCHER REALTY TRUST-SBI
+HRPT PROPERTIES TR-SBI
+SOSPITALITY PROPERTES TRUST
+JOHNSON& JOHNSON
+KRAMONT REALTY TRUST
+PAN PACIFIC RETAIL PROPERTIES
+INC
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+... ..
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+QUANTITY
+PRICE
+SYMBOLICUSIP
+CNCPF
+FCH
+GLB
+GRT
+HRP
+HPT
+JNJ
+KRT
+PNP
+PEI
+RPT
+ACCE
+CASH
+CASH
+CASH
+......
+CASH
+CASH
+CASH
+CASH
+........
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+19
+2,000
+2,000
+.. . .
+2,000
+10,000
+....
+2,000
+....
+57,800
+2,000
+...........
+436
+1,794
+12,000
+MARKET
+VALUE
+375,451
+$375,451
+PRICE
+Unpriced
+......
+12.1000
+18.3500
+.. . .
+22.1200
+10.0100
+42.3000
+55.7000
+.......
+16.0000
+.. . .
+50.5200
+34.2500
+24.2300
+MARKET
+VALUE
+24,200
+36,700
+.. . .
+44,240
+100,100
+84,600
+3,219,460
+.. . .
+32,000
+... .
+22.027
+61,445
+290,760
+120
+LEARED THROUGH IT
+Bear, Steams Securities Corp
+One Metrutech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD May 29, 2004
+THROUGH
+June 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 28, 2004
+URREN
+ELD I
+INUAL INCON
+2,800
+..............
+3,846
+8,000
+5,760
+65,892
+2,600
+... .
+946
+3,875
+20,160
+JURREN
+YIELD IS
+7.6294
+.............
+8.6935
+........
+7.9920
+6.8085
+ga давлая:
+2.0467
+.......
+8.1250
+...........
+4.2947
+6.3065
+.....
+6.9336
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York New York 10179
+5 org
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+SIRIUS SATELLITE RADIO INC
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOUCUSIP
+SIRI
+CASH
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SEEMENT TAR
+TRANSACTION
+06/17/04
+06/14/04
+SOLD
+TOTAL
+DESCRIPTION
+TOO INC
+UNSOLICITED
+DIVIDENDS
+DATE
+06/08/04
+.......
+DESCRIPTION
+JOHNSON& JOHNSON
+REC 05/18/04 PAY 06/0801.
+........
+SYM BOUCUSIP
+JNJ
+QUANTITY
+1,000
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD May 29, 2004
+THROUGH
+June 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 28, 2004
+PRICE
+3.0800
+MARKE
+VALUE
+3,080
+$3.918,612
+$3,918,612
+$113,879
+$4,294,063
+CURREN
+YIELD IS
+$113,879
+$113,879
+SYMBOLCUSIP
+TOO
+QUANTITY
+- 15,600
+PRICE
+16.06020
+DEBIT AMOUNT
+CREDIT AMOUNT
+249,597.25
+$249.597.25
+QUANTITY
+57,800
+RATE (S)
+0.2850
+027
+DEBIT AMOUNT
+CREDIT AMOUNT
+16,473.00
+......
+
+
+ear, Steams & Co. Inc
+83 Madison Avenu
+New York New York 10179
+Transaction Detail (continued)
+DIVIDENDS (continued)
+DATE
+06/15/04
+DESCRIPTION
+PAN PACIFIC RETAIL PROPERTES
+INC 05/28/04 PAY 06/15/104
+06/15/04 PENNSYLVANIA REAL ESTATE
+NVESTMENT TRUST-SBI
+REC 06/01/04 PAY 06/15/04
+TOTAL
+INTEREST
+SYMBOUCUSIP
+PNP
+PEI
+DATE
+06/21/04
+TOTAL
+DESCRIPTION
+INTEREST ON CREDIT BALANCE
+ATC0.200003 05/21 - 06/20
+SYMBOUCUSIP
+QUANTITY
+436
+RATE (S)
+0.5425
+1,794
+1.540
+QUANTITY
+RATE 1S
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+07/01/04;13:31 001
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD May 29, 2004
+THROUGH
+June 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+May 28, 2004
+CREDIT AMOUNT
+236.53
+968.76
+$17.678.29
+CREDIT AMOUNT
+63.36
+$63.36
+
+
+7 of a
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+Your messages
+Notice Regarding a Change in The Statement of Interest Charges
+And Manking To Tre-Mark-Lending" Rule 10 (b)-76 Regarding Short Sales
+fective no earlier than thirty (30) days from your receipt of this statement, v
+ill compute interest regarding your short sales and marking-to-the market
+follows:
+The credit that appears on your statement due to short sales (including short
+sales against the box) is offset by a debit of like amount because Bear Stears
+Securities has to borrow the same security in order to deliver it to the buying
+broker and has to provide its lender additional collateral of up to 105% of the
+settled short market value of the borrowed securities to secure such loan. This
+means that the debit balance on which interest is computed will be the
+difference between (i) up to 105% of the settled short market value of such
+short sales (across all currencies), which shall be calculated daily, and (ii) the
+proceeds of such short sales.
+18P
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD May 29, 2004
+THROUGH
+June 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+May 28, 2004
+Any short positions in your account will be kept "marked-to-the market". This
+means that periodically the balance maintained in the short account will be
+adjusted to equal the market value of the short securities, Securities that are
+priced below five dollars per share may be valued at five dollars per share for
+short marking-to-the market purposes. If a security has been sold short (or
+sold short against the box) and has appreciated in market price over the
+selling price, interest will be charged on the amount of appreciation; if it
+depreciates in market price, interest will be correspondingly reduced by the
+drop in value. The appreciation or depreciation of securities sold short will be
+Please note that the other sections of the "Truth-in-Lendino" disclosure
+previously provided to you remain unchanged.
+027
+
+
+8 of 8
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+Pursuant to the terms of the equity research settlement that was entered into
+by Bear Stearns and other major investment banks, we will soon make
+available to our customers, independent third-party research ("Independent
+Research"), at no cost, on the common stock of certain companies covered by
+the Firm's Equity Research Department (Covered Company"). Customers will
+be able to access this research at www.bearstearns.com or can call (800)
+517-2327 to request that a copy of this research be sent to them.
+Further, Bear Steams will notify certain of our customers, at the time of each
+solicited order to buy or sell the common stock of a Covered Company, of the
+availability of Independent Research, and will provide, on the confirmations
+and statements that are generated for these customers, the rating(s) on such
+Covered Company(s) by the Firm's Equity Research Department, as well as the
+corresponding rating(s) by the applicable Independent Research provider(s),
+where available. These notice provisions become effective in the near future
+and, to the extent applicable, will be included in your next monthly statement,
+Please note, Bear Steams is not responsible or liable for (i) decisions relating
+to the procurement of Independent Research, (ii) Independent Research or its
+content, (il) customer transactions, to the extent based on Independent
+3222-
+STOP
+****** End of Statement******
+Bear, Steams Securitles Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD May 29, 2004
+THROUGH
+June 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+May 28, 2004
+Please be advised of the following changes regarding account service fees:
+Beginning September 1, 2004, accounts will be subject to a $20.00
+processing fee for each outgoing wire transfer and for each check issued by
+Bear Steams at the request of a customer. You may wish to speak to your
+Account Executive to inquire about the availability of check writing privileges for
+Beginning January 1, 2005, accounts will be subject to an annual account
+charge of $75,00 applicable for households that maintain less than $100,000
+in net equity in related accounts or that generated less than $500 in
+brokerage commissions and/or fees paid to Bear Stears in those accounts in
+the prior calendar year,
+027
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearsteams.com
+What's In This Statement
+Financial Summar..............................
+Your Portfolio Holdings
+....
+Transaction Detail
+LEARED THROUGH IT
+Bear, Steams Securities Con
+he Metrutech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD May 1, 2004
+THROUGH
+May 28, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 30,2004
+Hollandlold
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITES THIS PERIOD*
+NET CREDIT BALANCE
+4,172,342
+108,113
+NET EQUITY THIS PERIOD
+$4,280,455
+.....
+NET EQUITY LAST STATEMENT
+4,170,996
+CHANGE SINCE LAST STATEMENT
+109,459
+"This portfolio indudes one or more unpriced securtles that are not
+relected in the Total Value of Securities and the Net Equity This Period
+Market Value of Your Portfolio
+$108,113
+$104,629
+Cash & Equivalent -
+Equities
+1 55066-367
+$4,172,342
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634 1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four ratanal purger red die Set revere date for portant iformation.
+
+
+2 of 5
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklynı, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+1831
+
+
+3 or 5
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+ear, Steams & Co. Ind
+83 Madison Avenu
+New York New York 10179
+THIS PERICO
+$104,629.07
+3,483.51
+....
+$3,483.51
+3,483.51
+$108,112.58
+Income Summary
+Dividends
+Credit Balance Int
+THIS PERIOD
+3,440.00
+43.51
+$3,483.51
+.....
+.. . .
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+.....
+YEAR TO DATE
+29,218.89
+185.45
+.............
+$29.404.34
+108,113
+4,172,342
+.34.280,455
+Cash Balance Summary
+OPENING
+Cash
+104,629.07
+Net Cash Balance
+$104,629.07
+CLOSING
+108,112.58
+$108,112.58
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRUPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBCUCUSIP
+QUANTITY
+PRICE
+MARKET
+VALUE
+108,113
+$108,113
+ANNUAL INCOME
+WAS NOME CURRENT
+027
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD May 1, 2004
+THROUGH
+May 28, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+April 30, 2004
+Your Portfolio
+Allocation
+Cash & Equivalent -
+2%
+Equities
+98%
+Inshaded portions denote debit balance andor sho
+arket values. The allocation percentage is derive
+from the absolute marker value of your portiolo
+
+
+4 of 5
+Your Portfolio Holdings (continued)
+EQUITIES
+Equities & Options
+DESCRIPTION
+CANHORN CHEMICAL CORP
+............
+FELCOR LODGING TRUST INC
+GLENBOROUGH REALTY TRUST INC
+GLIMCHER REALTY TRUST-SBI
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+SBI
+JOHNSON& JOHNSON
+KRAMONT REALTY TRUST
+PAN PACIFIC RETAIL PROPERTIES
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+....
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+....
+SIRIUS SATELLITE RADIO INC
+SYMBCUCUSIP
+CNCPF
+FCH
+GLB
+GRT
+HRP
+HPT
+JNJ
+KRT
+PNP
+PEI
+RPT
+SIRI
+TOO INC
+TOO
+Total Equities& Options
+TOTAL EQUITIES
+ear, Steams & Co. In
+83 Madison Avenu
+New York, New York 10179
+CASH
+......
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH™
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+19
+2,000
+2,000
+2,000
+10,000
+2,000
+57,800
+2,000
+436
+1,794
+12,000
+1,000
+15,600
+PRICE
+Unpriced
+10.6400
+-...
+19.0100
+22.3300
+9.8500
+40.9300
+55.7100
+16.1200
+46.0000
+33.3000
+24.2000
+3.0000
+16.8300
+MARKET
+VALUE
+21,280
+38,020
+44,660
+98,500
+81,860
+3.220,038
+32,240
+20,056
+59,740
+290,400
+3,000
+262,548
+$4,172,342
+$4,172,342
+027
+CLEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD May 1, 2004
+THROUGH
+May 28, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+April 30,2004
+ANNUAL INCOME
+CURRENT
+YIELD (%)
+...
+2,800
+7.3645
+.....
+3,846
+8.6117
+......
+8,000
+8.1218
+5,760
+7.0364
+65,892
+2,600
+946
+2.0463
+8.0645
+............
+4.7168
+3,875
+6.4864
+20,160
+6.9421
+$113,879
+$113,879
+
+
+5 or5
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+$113,879
+$4,280,455
+Transaction Detail
+DIVIDENDS
+DATE
+DESCRIPTION
+05/20/04
+HOSPITALITY PROPERTIES TRUST
+SEC 05/04/04 PAY 05/20104
+05/24/04 HRPT PROPERTIES TR-SBI
+REC 04/23/04 PAY 05/24/04
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+05/21/04
+INTEREST ON GREDIT BALANCE
+A0004/21-05/20
+TOTAL
+SYMBOUCUSIP
+HPT
+HRP
+QUANTITY
+2,000
+RATE (S)
+0.7200
+10,000 0.2000
+SYMBOUCUSIP
+QUANTITY
+RATE 15)
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+LEARED THROUGH IT
+Bear, Steams Securities Con
+he Metrutech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD May 1, 2004
+THROUGH
+May 28, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 30,2004
+CREDIT AMUNT
+1,440.00
+2,000.00
+$3.440.00
+CREDIT AMCUNT
+43.51
+$43.51
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearsteams.com
+What's In This Statement
+Financial Summar..............................
+Your Portfolio Holdings
+....
+Transaction Detail
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 1,2004
+THROUGH
+April 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 31,2004
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITES THIS PERIOD*
+4,066,367
+NET CREDIT BALANCE
+104,629
+NET EQUITY THIS PERIOD
+$4,170,996
+.....
+NET EQUITY LAST STATEMENT
+4,151,089
+CHANGE SINCE LAST STATEMENT
+19,907
+"This portfolio indudes one or more unpriced securties that are not
+relected in the Total Value of Secures and the Net Equity This Period
+Market Value of Your Portfolio
+$104,629
+$97,235
+Cash & Equivalent -
+Equities
+$4.066,367
+- 54005367
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The surene s four or ratanal furyce rear die Set revere date for portant iformation.
+027
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklynı, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+ear, Steams & Co. Ind
+83 Madison Avenu
+New York New York 10179
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+Cash Balance Summary
+OPENING
+Cash
+97,235.43
+Net Cash Balance
+$97,235.43
+THIS PERICO
+97,235.4.
+7,393.64
+57,393.64
+7,393.64
+8204.629.07
+CLOSING
+104,629.07
+$104,629.07
+Income Summary
+Dividends
+Credit Balance Int
+.......
+THIS PERIOD
+7,351.60
+42.04
+....
+57,393.64
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+........
+YEAR TO DATE
+25,778.89
+141.94
+.......
+$25,920.83
+104,629
+4,066,367
+S4.170.996
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRUPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBCUCUSIP
+QUANTITY
+PRICE
+MARKET
+VALUE
+104.629
+$104,629
+ESTIMATED CURRENT
+ANNUAL INCOME
+YIELD (%)
+027
+05/01/04;13:17 001
+LEARED THROUGH I
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 1,2004
+THROUGH
+April 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 31,2004
+Your Portfolio
+Allocation
+Cash & Equivalent -
+2%
+Equities
+98%
+Unshaded portions denote debit balance andor shar
+narket values. The allocation percentage is derived
+from the absolute marker value of your portiolo
+
+
+Your Portfolio Holdings (continued)
+EQUITIES
+Equities & Options
+DESCRIPTION
+CANHORN CHEMICAL CORP
+............
+FELCOR LODGING TRUST INC
+GLENBOROUGH REALTY TRUST INC
+GLIMCHER REALTY TRUST-SBI
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+SBI
+JOHNSON& JOHNSON
+KRAMONT REALTY TRUST
+PAN PACIFIC RETAIL PROPERTIES
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+....
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+......
+SIRIUS SATELLITE RADIO INC
+SYMBCUCUSIP
+CNCPF
+FCH
+GLB
+GRT
+HRP
+HPT
+JNJ
+KRT
+PNP
+PEI
+RPT
+SIRI
+TOO INC
+TOO
+Total Equities& Options
+TOTAL EQUITIES
+ear, Steams & Co. In
+83 Madison Avenu
+New York, New York 10179
+CASH
+......
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH™
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+19
+2,000
+2,000
+2,000
+10,000
+2,000
+57,800
+2,000
+436
+1,794
+12,000
+1,000
+15,600
+PRICE
+Unpriced
+10.0000
+... .
+18.7900
+21.1500
+9.5500
+39.0800
+54.0300
+15.8100
+43.9300
+32.3500
+23.6800
+3.3000
+17.5400
+MARKUS
+20,000
+37,580
+42,300
+95,500
+78,160
+3.122,934
+33,620
+19,153
+58,036
+284,160
+3,300
+273,624
+$4,066,367
+$4,066,367
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Secuntles Corp.
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 1, 2004
+THROUGH
+April 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 31,2004
+ANNUAL I COME
+URREN
+IELD IS
+.....
+...
+2,800
+7.4508
+.....
+3,846
+9.0922
+8,000
+8.3770
+5,760
+7.3695
+65,892
+21099
+2,600
+8.2226
+946
+4.9392
+3,875
+7,896
+6.6769
+2.7787
+$101,615
+$101,615
+05/01/04;13:17 001
+
+
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+DIVIDENDS
+DATE
+04/15/04
+04/15/04
+04/20104
+04/22/04
+TOTAL
+DESCRIPTION
+SLENBOROUGH REALTY TRUST IN
+EC 04/01/04 PAY 04/15
+GLIMCHER REALTY TRUST-SBI
+SEC 03/31/04 PAY 04/15/04
+RAMCO GERSHENSON PROPERTES
+REC 033104 PAY 04/20104
+KE 032504 PAY 04204
+SYMBOUCUSIP
+GLB
+GRT
+*RPT
+KRT
+QUANTITY
+2,000
+2,000
+12,000
+2,000
+$101,615
+$4,170,996
+RATE (S)
+0.3500
+0.4808
+0.4200
+027
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrutech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 1,2004
+THROUGH
+April 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 31,2004
+DEBIT AMOUNT
+CREDIT AMOUNT
+700.00
+961.60
+5,040.00
+650.00
+$7,351.60
+05/01/04;13:17 001
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+04/21/04
+INTEREST ON CREDIT BALANCE
+A 00 50000% 03121 - 04/20
+TOTAL
+SYMBOUCUSIP
+QUANTITY
+RATE 1%
+STOP
+****** End of Statement******
+027
+DEBIT AMOUNT
+LEARED THROUGH I
+Bear, Steams Securitles Corp.
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 1, 2004
+THROUGH
+April 30,2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 31,2004
+CREDIT AMOUNT
+42.04
+$42.04
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearsteams.com
+What's In This Statement
+Financial Summary .....................
+Your Portfolio Holdings
+Transaction Detail .................................
+Your Messages
+..........
+LEARED THROUGH IT
+Bear, Steams Securities Corp
+One Metrutech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD February 28,2004
+THROUGH
+March 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 27,2004
+6
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+NET CREDIT BALANCE
+4,053,854
+97,235
+NET EQUITY THIS PERIOD
+$4,151,089
+.. . ..
+NET EQUITY LAST STATEMENT
+4,275,042
+CHANGE SINCE LAST STATEMENT
+-123,952
+"This portfolio indudes one or more unpriced securtles that are not
+relected in the Total Value of Securites and the Net Equity This Period
+Market Value of Your Portfolio
+97,23
+82,123
+Cash & Equivalent -
+Equities
+$4,053,89
+#m $4.192.91
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four ratanal purger red die Set revere dae for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklynı, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+04/01/04;12:55 001
+
+
+3 or 7
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+Cash Balance Summary
+OPENING
+Cash
+82,122.74
+Net Cash Balance
+$82,122.74
+ear, Steams & Co. Ind
+83 Madison Avenu
+New York New York 10179
+THIS PERICO
+$82,122.74
+15,112.69
+$15,112.69
+15,112.69
+397-235.43
+Income Summary
+THIS PERIOD
+Dividends
+15,077.29
+Credit Balance Int
+35.40
+Total 315.12.69
+......
+$15.112.69
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+........ . .
+YEAR TO DATE
+18,427.29
+99.90
+.........
+$18,527.19
+97,235
+4,053,854
+34.151.069
+CLOSING
+97,235.43
+$97,235.43
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRUPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBCUCUSIP
+QUANTITY
+PRICE
+MARKET
+VALUE
+97,235
+$97,235
+ANNUAL INCOME
+WAS NOME CURENA
+027
+04/01/04;12:55 001
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD February 28,2004
+THROUGH
+March 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+February 27,2004
+Your Portfolio
+Allocation
+Cash & Equivalent -
+2%
+Equities
+98%
+nshaded portions denote debit balance andor she
+arket values. The allocation percentage is derive
+from the absolute market value of your portfolis.
+
+
+Your Portfolio Holdings (continued)
+EQUITIES
+Equities & Options
+DESCRIPTION
+CANHORN CHEMICAL CORP
+............
+FELCOR LODGING TRUST INC
+GLENBOROUGH REALTY TRUST INC
+GLIMCHER REALTY TRUST-SBI
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+SBI
+JOHNSON& JOHNSON
+KRAMONT REALTY TRUST
+PAN PACIFIC RETAIL PROPERTIES
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+....
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+....
+SIRIUS SATELLITE RADIO INC
+SYMBCUCUSIP
+CNCPF
+FCH
+GLB
+GRT
+HRP
+HPT
+JNJ
+KRT
+PNP
+PEI
+RPT
+SIRI
+TOO INC
+TOO
+Total Equities& Options
+TOTAL EQUITIES
+ear, Steams & Co. In
+83 Madison Avenu
+New York, New York 10179
+CASH
+......
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH™
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+19
+2,000
+2,000
+2,000
+10,000
+2,000
+57,800
+2,000
+436
+1,794
+12,000
+1,000
+15,600
+PRICE
+Unpriced
+10.4200
+... .
+22.3500
+27.1000
+11.3000
+46.4000
+50.7200
+18.9000
+52.1000
+37.6600
+28.2000
+3.4000
+20.9500
+MARKE
+20,840
+44,700
+54,200
+113,000
+92,800
+2,931,616
+37,800
+22,716
+67,562
+338,400
+3,400
+326,820
+$4,053,854
+$4,053,854
+027
+LEARED THROUGH IT
+Bear, Steams Secuntles Corp.
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD February 28,2004
+THROUGH
+March 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 27,2004
+ANNUAL COME
+CURREN
+YIELD IS
+.....•........
+2,800
+6.2640
+......
+3,846
+7.0959
+8,000
+7.0796
+5,760
+6.2069
+55,488
+2,600
+946
+1.8927
+.........
+6.8783
+..... ...
+4.1645
+3,875
+7,896
+5.7355
+23333
+$91,211
+$91,211
+
+
+5 or7
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGS ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+DIVIDENDS
+DATE
+DESCRIPTION
+03/09/04
+C 02/17/04 PAY 03/09/
+03/15/04
+PAN PACIFIC RETAIL PROPERTIES
+INC 0227104 PAY 03/15104
+03/5/04
+* PENNSYLVANIA REAL ESTATE
+NVESTMENT TRUST-SE
+REC 03/01/04 PAY 03/15/0
+TOTAL
+SYMBOUCUSIP
+JNJ
+PNP
+LEARED THROUGH IT
+Bear, Steams Secuntles Con
+he Metrutech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD February 28,2004
+THROUGH
+March 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 27,2004
+$91,211
+$4,151,089
+QUANTITY
+RATE (S)
+57,800
+0.2400
+436
+0.5425
+*1,794 0.5400
+1,794
+DEBIT AMOUNT
+CREDIT AMOUNT
+13,872.00
+236.53
+.....
+968.76
+$15,077.29
+027
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+03/22/04
+INTEREST ON CREDIT BALANCE
+AFCO. 50008 02121 - 03720
+TOTAL
+SYMBOUCUSIP
+QUANTITY
+Your messages
+Excess SIPC Account Protection Update
+Effective February 16, 2004, the commercial insurer through which Bear,
+Stearns Securities Corp, obtains excess SIPC protection changed to Customer
+Asset Protection Company (CAPCO"), a New York licensed insurance
+company. CAPCO has an At financial strength rating from Standard and
+RATE 1%
+DEBIT AMOUNT
+EARED THROUGH 1
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD February 28,2004
+THROUGH
+March 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 27,2004
+CREDIT AMOUNT
+35.40
+$35.40
+Bear, Stears Securities Corp, Net Capital and Net Capital Requirements:
+At November 30, 2003 and January 31, 2004, the Company's net capital of
+approximately $3,3 billion and $3,2 billion was approximately 7% and 7% of
+aggregate debit items and exceeded the minimum regulatory net capital
+requirement of approximately $930,3 million and $967,8 million by
+approximately $2.4 billion and $2,2 billion, all respectively.
+Contin s aval of te on tear seats wies terms an entert finely ca
+request a free printed copy please call - toll free 1-866-299-9331.
+027
+04/01/04;12:55 001
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+1 The Firm believes it is of the utmost importance that clients who purchase or
+hold mutual funds fully understand the intricacies of the pricing structures and
+ules which govern these investments, Recently, a joint Industry/NASD Tas
+orce collaborated to create a Disclosure Statement to address these issue
+We are providing this Disclosure Statement to you for the purpose of
+reinforcing these concepts and to initiate the opportunity for further discussion
+of these issues to the extent you have questions. You are encouraged to
+contact your financial professional with any questions you have regarding your
+investments. Additionally, you may review this information online at the
+following NASD web site
+http://www.nasdr.com/breakpoints_statement.asp
+STOP
+****** End of Statement******
+027
+04/01/04;12:55 001
+LEARED THROUGH IT
+Bear, Steams Securities Con
+he Metrutech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD February 28,2004
+THROUGH
+March 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 27,2004
+V929
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearsteams.com
+What's In This Statement
+Financial Summary .....................
+Your Portfolio Holdings
+Transaction Detail .................................
+Your Messages
+..........
+LEARED THROUGH IT
+Bear, Steams Securities Corp
+One Metrutech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 31, 2004
+THROUGH
+February 27,2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+January 30, 2004
+6
+Hollandlol
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+NET CREDIT BALANCE
+4,192,919
+82,123
+NET EQUITY THIS PERIOD
+$4,275,042
+.. . . .
+NET EQUITY LAST STATEMENT
+4,167,113
+CHANGE SINCE LAST STATEMENT
+107,929
+"This portfolio indudes one or more unpriced securtles that are not
+relected in the Total Value of Securites and the Net Equity This Period
+Market Value of Your Portfolio
+S82,123
+$80,089
+Cash & Equivalent -
+Equities
+ПТ 55089,0222
+$4,192,919
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four ratanal purposes red die Set revere date for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklynı, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+ear, Steams & Co. Ind
+83 Madison Avenu
+New York New York 10179
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+Cash Balance Summary
+OPENING
+Cash
+80,088.52
+Net Cash Balance
+$80,088.52
+THIS PERICO
+$80,088.52
+2,034.22
+$2,034.22
+2,034.22
+582.12.-74
+Income Summary
+THIS PERIOD
+Dividends
+2,000.00
+Credit Balance Int
+34.22
+To 203422-
+$2,034.22
+..........
+... . .
+.............
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+................
+YEAR TO DATE
+3,350.00
+64.50
+3.414.5
+82,123
+4,192,919
+54275,042
+CLOSING
+82,122.74
+$82,122.74
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRUPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBCUCUSIP
+QUANTITY
+PRICE
+MARKET
+VALUE
+82,123
+$82,123
+ANNUAL INCOME
+027
+CLEARED THROUGH IT:
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 31, 2004
+THROUGH
+February 27,2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+January 30,2004
+Your Portfolio
+Allocation
+Cash & Equivalent -
+1%
+• Equities
+99%
+Unshaded portions denote debit balance andor shar
+
+
+Your Portfolio Holdings (continued)
+EQUITIES
+Equities & Options
+DESCRIPTION
+CANHORN CHEMICAL CORP
+............
+FELCOR LODGING TRUST INC
+GLENBOROUGH REALTY TRUST INC
+GLIMCHER REALTY TRUST-SBI
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+SBI
+JOHNSON& JOHNSON
+KRAMONT REALTY TRUST
+PAN PACIFIC RETAIL PROPERTIES
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+...
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+....
+SIRIUS SATELLITE RADIO INC
+SYMBCUCUSIP
+CNCPF
+FCH
+GLB
+GRT
+HRP
+HPT
+JNJ
+KRT
+PNP
+PEI
+RPT
+SIRI
+TOO INC
+TOO
+Total Equities& Options
+TOTAL EQUITIES
+ear, Steams & Co. In
+83 Madison Avenu
+New York, New York 10179
+CASH
+......
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH™
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+19
+2,000
+.. . .
+2,000
+2,000
+10,000
+2,000
+57,800
+2,000
+436
+1,794
+12,000
+1,000
+15,600
+PRICE
+Unpriced
+10.7400
+....
+21.0000
+25.7700
+11.0800
+43.5000
+53.9100
+19.6700
+49.5000
+36.4500
+27.9700
+2.9400
+19.1800
+MARKE
+21,480
+42,000
+51,540
+110,800
+87,000
+3.115,998
+33,340
+21,582
+65,391
+335,640
+2,940
+299,208
+$4,192,919
+$4,192,919
+027
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp
+One Metratech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 31, 2004
+THROUGH
+February 27,2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+January 30,2004
+2,800
+3,846
+........•••.
+8,000
+5,760
+55,488
+2,600
+946
+3,875
+1,896
+$91,211
+$91,211
+CURRENT
+YIELD (%)
+6.6667
+...........
+7.4622
+......
+7.2202
+6.6207
+1.7807
+.... ...
+6.6090
+...........
+4.3833
+5.9259
+2.3525
+
+
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+DIVIDENDS
+DATE
+DESCRIPTION
+02/23/04
+HRPT PROPERTIES TR-SBI
+TOTAL
+REC 01/21/04 PAY 02/23/04
+INTEREST
+DATE
+02/23/04
+DESCRIPTION
+INTEREST ON CBEDIT BALANCE
+AT00.50000% 01/21 - 02/20
+TOTAL
+SYMBOUCUSIP
+HRP
+SYMBOUCUSIP
+QUANTITY
+10,000
+QUANTITY
+$91,211
+$4,275,042
+RATE (S)
+0.2000
+RATE ISI
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+CLEARED THROUGH IT:
+Bear, Steams Securities Corp
+One Metrutech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 31,2004
+THROUGH
+February 27,2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+January 30,2004
+CREDIT AMOUNT
+2,000.00
+$2,000.00
+CREDIT AMCUNT
+34.22
+$34.22
+
+
+ear, Steams & Co. In
+83 Madison Avenu
+New York New York 10179
+Your messages
+CLEARED THROUGH IT:
+HOLLY OWNED SUBSIDIAR'
+Bear, Steams Securities Corp
+One Metrutech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 31, 2004
+THROUGH
+February 27,2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+January 30,2004
+STOP
+****** End of Statement******
+027
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearsteams.com
+What's In This Statement
+Financial Summary ........................
+Your Portfolio Holdings
+Transaction Detail .................................
+Your Messages
+..........
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Secuntles Corp.
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 1, 2004
+THROUGH
+January 30,2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2003
+6
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITES THIS PERIOD*
+NET CREDIT BALANCE
+4,087,024
+80,089
+NET EQUITY THIS PERIOD
+$4,167,113
+.. . . .
+NET EQUITY LAST STATEMENT
+4,074,108
+CHANGE SINCE LAST STATEMENT
+93,005
+"This portfolio indudes one or more unpriced securties that are not
+relected in the Total Value of Securites and the Net Equity This Period
+Market Value of Your Portfolio
+$80,089
+$69,695
+Cash & Equivalent -
+Equities
+I 55.000.103
+54,087,024
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four ratanal purger red de Set revere date for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklynı, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+01/31/04;09:43 001
+
+
+ear, Steams & Co. Ind
+83 Madison Avenu
+New York New York 10179
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+Cash Balance Summary
+OPENING
+Cash
+69,694.64
+Net Cash Balance
+$69,694.64
+THIS PERICO
+369.694.64
+10,393.88
+$10,393.88
+10,393.88
+580.088.52
+Income Summary
+THIS PERIOD
+Dividends
+1,350.00
+Credit Balance Int
+30.28
+........
+$1,380.28
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+.........
+YEAR TO DATE
+1,350.00
+30.28
+$2,380.28
+80,089
+4,087,024
+54.67.11
+CLOSING
+80,088.52
+....•...
+$80,088.52
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRUPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBCUCUSIP
+QUANTITY
+PRICE
+MARKET
+VALUE
+80.089
+$80,089
+ANNUAL INCOME
+WAS NOME CUREN
+027
+01/31/04;09:43 001
+LEARED THROUGH I
+Bear, Steams Securitles Corp.
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 1, 2004
+THROUGH
+January 30,2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+1%
+• Equities
+99%
+Unshaded portions denote debit balance andor shar
+
+
+Your Portfolio Holdings (continued)
+EQUITIES
+Equities & Options
+DESCRIPTION
+CANHORN CHEMICAL CORP
+............
+FELCOR LODGING TRUST INC
+GLENBOROUGH REALTY TRUST INC
+GLIMCHER REALTY TRUSTSBI
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+SBI
+JOHNSON& JOHNSON
+KRAMONT REALTY TRUST
+PAN PACIFIC RETAIL PROPERTIES
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+...
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+....
+SIRIUS SATELLITE RADIO INC
+SYMBCUCUSIP
+CNCPF
+FCH
+GLB
+GRT
+HRP
+HPT
+JNJ
+KRT
+PNP
+PEI
+RPT
+SIRI
+TOO INC
+TOO
+Total Equities& Options
+TOTAL EQUITIES
+ear, Steams & Co. In
+83 Madison Avenu
+New York, New York 10179
+CASH
+......
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH™
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+19
+2,000
+2,000
+2,000
+10,000
+2,000
+57,800
+2,000
+436
+1,794
+12,000
+1,000
+15,600
+PRICE
+Unpriced
+11.7500
+-...
+19.4100
+...
+25.1900
+10.6000
+41.8500
+53.4200
+18.6000
+51.1100
+37.3600
+27.4200
+2.7200
+15.3000
+MARKE
+23,500
+....
+38,820
+50,380
+106,000
+83,700
+3,087,676
+33.200
+22,284
+67.024
+329,040
+2,720
+238,680
+$4.087.024
+$4,087,024
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securitles Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 1, 2004
+THROUGH
+January 30,2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31,2003
+ANNUAL INCOME
+CURRENT
+YIELD (%)
+....
+.....
+2,800
+7.2128
+..........
+3,846
+7.6340
+........•••.
+8,000
+7.5472
+5,760
+6.8817
+55,488
+2,600
+8890
+3,875
+7,896
+1.7971
+.......
+6.9892
+..........
+3.9894
+5.7815
+23997
+$91,154
+$91,154
+
+
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+DIVIDENDS
+DATE
+01/15/04
+01/15/04
+DESCRIPTION
+SLENBOROUGH REALTY TRUST INC
+EC 01/01/04 PAY 01/15
+GLIMCHER REALTY TRUST-SBI
+CAMP CLUB ON 205.1099
+
+RAMCO GERSHENSON PROPERTIES
+LE 12010312010500
+AMOUNT INCLUDED ON 2003-1099
+01/22/04
+RE 02020 A 1450.
+SYMBOUCUSIP
+GLB
+GRT
+'RPT
+KRT
+QUANTITY
+2,000
+2,000
+$91,154
+$4,167,113
+RATE (S)
+0.3500
+0.3250
+027
+DEBIT AMOUNT
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Secuntles Corp.
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 1, 2004
+THROUGH
+January 30,2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2003
+CREDIT AMCUNT
+700.00
+961.60
+6,612.00
+650.00
+
+
+Transaction Detail (continued)
+DIVIDENDS (continued)
+DATE
+DESCRIPTION
+01/30/04
+HOSPITALITY PROPERTIES TRUST
+SASH DIV ON 2000 SHS
+REC 12/31/03 PAY 01/30/04
+AMOUNT INCLUDED ON 2003-1099
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+01/21/04
+INTEREST ON CREDIT BALANCE
+AT 00130008012/21 - 02/20
+TOTAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUCUSIP
+HPT
+SYM BOUCUSIP
+Your messages
+QUANTITY
+QUANTITY
+RATE (5]
+DEBIT AMOUNT
+EARED THROUGH 1
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securitles Corp.
+One Metrotech Center North
+Brooklym, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 1, 2004
+THROUGH
+January 30,2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2003
+CREDIT AMOUNT
+1,440.00
+$10,363.60
+RATE 15)
+DEBIT AMOUNT
+CREDIT AMOUNT
+30.28
+$30.28
+The interest, if any, charged to your account during December 2003 was
+computed on the net debit balance through December 30. The interest, if any,
+charged to your account during January 2004 is computed from December 31,
+027
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/b46d1a7033a69609a502c9444a1ce6355cd2dd0b193e12ec3c221145c4486c77.receipt.json b/vision-fixhub/ds9-unparsed-05/b46d1a7033a69609a502c9444a1ce6355cd2dd0b193e12ec3c221145c4486c77.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..270eb08468daf61c807eab41d3d18fb2b143ac63
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b46d1a7033a69609a502c9444a1ce6355cd2dd0b193e12ec3c221145c4486c77.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -7624,
+  "dataset": "marble-joined",
+  "doc_id": "b46d1a7033a69609a502c9444a1ce6355cd2dd0b193e12ec3c221145c4486c77",
+  "engine": "marble-apple-vision",
+  "event_count": 84,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "640ba9904108b6e5f05187a69185c92fa9f31c1353a26786684ecfeadca9ed1e",
+  "output_sha256": "d240357171493e1e926d55b95af04c3fc5e556cea5935d8b21b758efdf360f8a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b502c0bb29c5b2920ea94fad2c19fac2e8393e814d0f991afbe253e013d2927b.md b/vision-fixhub/ds9-unparsed-05/b502c0bb29c5b2920ea94fad2c19fac2e8393e814d0f991afbe253e013d2927b.md
new file mode 100644
index 0000000000000000000000000000000000000000..851ecd2230b5628e546fdf470bede14ce81e40bf
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b502c0bb29c5b2920ea94fad2c19fac2e8393e814d0f991afbe253e013d2927b.md
@@ -0,0 +1,119 @@
+12/7/07 Sanches to!
+
+
+04:53pm
+Fron-Fowler-White Burnett
+
+LAW OFFICES
+FOWLER WHITE BURNETT
+ESPIRITO SANTO PLAZA
+1395 BRICKELL AVENUE, 14TII FLOOR
+MIAMI, FLORIDA 33131-3302
+T-966 P.001/004 F-876
+FAX TRANSMITTAL
+DATE: December 7, 2007
+Name
+Alex Acosta
+NUMBER OF PAGES: 3
+(Excluding transmittal page)
+305-530-641
+..........305-530-6444
+FROM: Lilly Ann Sanchez
+FAX NUMBER: (305) 789-9201
+MATTER NO: 71200
+REMARKS: please see attached.
+TEI.EPHONE NUMBER: (305) 789-9200
+Original documents will • will not • follow by mail.
+TIME OF TRANSMITTAL:
+a.m./p.m. TRANSMITTED BY:
+Photocopy should he laken of this transmision if it is to be ratained since Jacsimile puper has limired storage life.
+THE INFORMATION CONTAINED IN THIS FACSIMILE MESSAGE IS ATTORNEY PRIVILEGED AND CONFIDENTIAL
+INFORMATION INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF
+IS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATIO
+STRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED TH
+COMMUNICATION IN ERROR, PLEASE IMMEDIATELY NOTIFY US BY TELEPHONE (IF LONG DISTANCE, PLEASE CALI
+COLLECT) AND RETURN THE ORIGINAL MESSAGE TO US AT THE ABOVE ADDRESS VIA THE U.S. POSTAL SERVICE
+PLEASE NOTIFY US IMMEDIATELY BY CALLING (305) 789-9200, IF THERE IS ANY PROBLEM.
+
+
+04:54pm
+From-Fowler-White Burnett
+FOWLERWHITE
+ATTORNEYS AT LAW
+BURNETT
+MIAMI • FORT LAUDERDALE • WESTPALM BEACH • ST. PETERSBURG
+30578BB201
+T-B6B
+P. 002/004 F-976
+www.ronuer-write,.com
+LILLY ANN SANCHEZ
+DIRECT Phone No.: (305) 783-9279
+DIRECT FACSIMILE No.: (308) 728-7670
+LasNcHEx@rOW_EM-WHITE.COF
+December 7, 2007
+First Assistant United States Attorney
+United States Attorney's Office
+Southem District of Florida
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epstein
+Dear Jeft:
+Pursuant to your letter dated December 6, 2007, attached is a signed
+October 30, 20 let or tremenigned by ray died lette in pared
+(see attached).
+Moreover, pursuant to the terms of the Agreement, please note that the plea
+and sentencing hearing have been scheduled for January 4, 2008 at 8:30 a.m. before
+contents therein, Please call me at your earliest convenience.
+Sincerely,
+Lilly Anu Sanchez
+cc. Alex A. Acosta
+Judge Kenneth Star
+Limb] W47|300LE710743-alamen.LA8(12707-15-51)
+FOWLER WHITE BURNETT P.A.
+
+
+04:55pm
+From-Fowler-White Burnett
+
+T-B66
+P.003/004 F-#76
+Affirmation
+I, Jetfrey B. Epstein do hereby re-affirm the Non-Proscoution Agreement and Addendur 1o
+same dared October 30, 2007,
+phila
+Date
+
+
+Dec-07-0704:56pm
+Fron-Fowler-White Burnett
+
+T-866 P.004/004 F-076
+IN THE CIRCUIT COURT OF THE FIFTEENTH
+JUDICIAL CIRCUT, IN AND FOR PALM BEACH
+COUNTY, FLORIDA
+CASE NO.: 2006CF009454AXX
+STATE OF FLORDA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+NOTICE OF HEARING
+PLEASE TAKE NOTICE that the undersigned has called up for hearing the following:
+JUDGE:
+Sandra MeSorley
+DATE:
+January 4, 2008°
+TIME:
+8:30 am.
+PLACE:
+Room ITF, Palm Beach County Courthouse
+MATTER:
+Plea Conference
+I HEREBY CBRTIFY tbat a copy of the foregoing has been furnished by mail to Lanna
+Belohlavek, Esquire, State Attorney's Office, 401 North Dixie Highway, West Palm Bench, Florida
+33401 this 7* day of December, 2007,
+ATTERBURY, GOLDBERGER & WEISS, P.A
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, Florida 33401
+GOLDBERGBR, BSQUIRE
+ce: The Honorable Sandra MeSorley
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/b502c0bb29c5b2920ea94fad2c19fac2e8393e814d0f991afbe253e013d2927b.receipt.json b/vision-fixhub/ds9-unparsed-05/b502c0bb29c5b2920ea94fad2c19fac2e8393e814d0f991afbe253e013d2927b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9d81cfe56e0bf27a5c9ff632913b40a6c0d298be
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b502c0bb29c5b2920ea94fad2c19fac2e8393e814d0f991afbe253e013d2927b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -121,
+  "dataset": "marble-joined",
+  "doc_id": "b502c0bb29c5b2920ea94fad2c19fac2e8393e814d0f991afbe253e013d2927b",
+  "engine": "marble-apple-vision",
+  "event_count": 9,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "8a1230e7bc7ea881ce73c9c08bef45eb1a3502859bc9fda8e569c1fa592515f4",
+  "output_sha256": "41ce9bf2d416ec9db442e6d5a70b22ca34d3a3673c9ba2fe01e77a2ebc6683ea",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b54da70a1a7411b287ffffca99ff5257e3a2c9848721679a21864408d77ee546.md b/vision-fixhub/ds9-unparsed-05/b54da70a1a7411b287ffffca99ff5257e3a2c9848721679a21864408d77ee546.md
new file mode 100644
index 0000000000000000000000000000000000000000..2c53cd6581a6272469baf54a8686becdfc17c4d2
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b54da70a1a7411b287ffffca99ff5257e3a2c9848721679a21864408d77ee546.md
@@ -0,0 +1,308 @@
+KEN LANNING
+Background
+Hebephilia- interest in adolescent gurls
+Preferential sex offender
+Psychopath - felt like doing it and you did it
+-his own moral code, refuses hop to follow
+any other rules
+What is achild?
+Inexperienced, naive, sexually naive girls
+Control + manup manipulate
+-having money
+a payung them adds to control
+Groomung and seductio
+- gain cooperation & child victim
+- identity certain girls who are appealing
+radey and exaluate the ger!
+-hare are of your girls recruit more
+- attention, affection, kindnes
+- Key to rooming children is giving gifts, pujing
+
+
+How much is pay?
+sate y: Gervasio Torres, J.
+Defense attorney
+Victims tend not to disclose anything that is nod
+consistent with common belles about child
+molestations
+- victim is innocent who is forced or
+braineashed by the stranger-predat
+Gradually, over time they will disclose the full
+heids to develop confidence in the untiewer
+They are confronted with doing something that
+you were not supposed to do
+you lie, deny, minimize
+Reason that this is a crime is not ble children
+an a desiged mena hange
+- Shad pingager is about doing deans,
+compiant child victims- not forced
+- they deny, then minimize quality and quantity
+they will spin the story in the best light tor them
+Totality of evidence
+Lying way be evidence that the children actually
+were motested
+- story evdves as they become more confortable
+
+
+Emphase TE's active role in the
+mampulations
+- girls weren't perfect, but It took
+advantage of them
+Using an expert withess to educate the jury
+that childsen can't consent
+
+
+Kenneth V. Lanning
+CAC Consultants
+4121 Plank Road #115
+Fredericksburg, VA 22407
+Credentials to Testify as an Expert
+Concerning Sexual Victimization of Children
+1. My name is Kenneth V. Lanning. I am over the age of twenty-one (21) years and the facts
+stated are within my personal knowledge and are all true and correct.
+2. I am currently a private consultant in the area of crimes against children.
+3. My formal education is as follows:
+• B.B.A. (Accounting) Manhattan College, Bronx, New York (1962-1966).
+• Completed class work for Masters Degree (Criminal Justice) from Sam Houston State
+University, Huntsville, Texas (1975-1978).
+• M.S. (Administration of Justice) California Lutheran College, Thousand Oaks, California
+(1980).
+• No academic institution teaches what I come to know about the behavioral dynamics of
+the sexual victimization of children.
+4. Before retiring in 2000, I was a Special Agent with the Federal Bureau of Investigation (FBI)
+for more than 30 years. From 1970-1980, I was assigned to the St. Louis, San Antonio, and Los
+Angeles Field Offices where I worked a wide variety of investigative matters. During this time
+frame, however, few sexual victimization of children cases involved violations of Federal law
+under the jurisdiction of the FBI. Therefore, little of my work during this time involved
+investigating such cases.
+5. In 1973, I received specialized training from the FBI and was designated a field "sex crimes"
+police instructor. From 1973-1980, as a collateral responsibility I conducted training for local,
+state, and federal law enforcement in the area of sex crimes. To expand my knowledge in this
+area, I enrolled in graduate school, read books and articles, and interacted with law enforcement
+investigators who conducted such investigations.
+6. I received my first formal, specialized FBI training in the area of sexual exploitation of
+children in 1979. The term sexual exploitation of children is generally used to refer to those
+cases in which a non-family member victimizes the child.
+7. In 1981, after obtaining my Masters Degree, I was assigned to the FBI Behavioral Science
+Unit and the National Center for the Analysis of Violent Crime (FBI BSU/NCAVC) at the FBI
+Academy in Quantico, Virginia. The objective of this Unit was the practical application of
+knowledge of the behavioral sciences to the investigative process. I was assigned there for the
+next 20 years (1981-2000) and focused primarily on the sexual victimization of children. My
+
+
+duties included analyzing and understanding how sex offenders commit their crimes and how
+their child victims respond.
+8. I have attended and participated in every major training program I am aware of concerning
+sexual victimization of children inside and outside the FBI.
+9. While in the FBI BSU/NCAVC, my work involved conducting training, research, and case
+consultation concerning the behavioral and criminal aspects of deviant sexual behavior. Each of
+these components of my work complemented and supplemented the other. My expertise,
+conclusions, and observations concerning offender and victim behavior are therefore based on
+the totality of what I have learned from being simultaneously involved in training, research, and
+case consultation in the same area for over 25 years.
+10. Some significant aspects of the training component of my work include:
+• "One learns most when teaching others"
+• I was an adjunct instructor with the University of Virginia, University of Pennsylvania,
+National College of District Attorneys, and National Judicial College
+• I provided instruction to law enforcement officers from all over the United States and
+foreign countries attending the FBI National Academy in courses accredited by the
+University of Virginia such as Applied Criminology, Criminal Profiling and Crime
+Analysis, Interpersonal Violence and Sexual Victimization of Children.
+• I provided instruction to over 50,000 law enforcement officers, prosecutors, social
+workers, mental health and medical personnel, judges, and other professionals at training
+schools, seminars, and conferences conducted all over the United States and in foreign
+countries on various aspects of the Sexual Victimization of Children (e.g., Deviant
+Criminal Sexuality, Sexual Homicide, Abducted Children, Behavioral Analysis, Sexual
+Exploitation of Children, Ritualistic Crime, Evaluation of Sex Offenders, Compliant
+Child Victims, Child Pornography, Computer Exploitation, and Child Sex Rings).
+11. Some significant aspects of the research component of my work include:
+• I conducted research on "Use of Children in Pornography" funded by National Center on
+Child Abuse and Neglect, U.S. Department of Health and Human Services.
+• I was appointed a Senior Fellow Investigator by the University of Pennsylvania for a
+research project on the Linkages of Sexual Exploitation and Juvenile Delinquency
+Violence funded by Office of Juvenile Justice and Delinquency Prevention, U.S.
+Department of Justice (1984).
+• The results of this research and additional information were published in 1984 in a book
+itled, Child Pornography and Sex Rings and I was a contributing author to this book
+• I was assigned to the Advisory Staff of the U.S. Attorney General's Commission ot
+Pornography, U.S. Department of Justice (1986).
+• I was the Project Manager for the Serial Child Molester and Abductor Research Project
+funded by the Office of Juvenile Justice and Delinquency Prevention, U.S. Department of
+Justice. This project included interviewing dozens of offenders convicted of such crimes.
+2
+
+
+• I accumulated hundreds of case studies involving the sexual victimization of children.
+• As an FBI Agent, when doing this research, I had access to detailed law enforcement and
+other records (i.e., investigative reports, interviews of offenders and victims, crime scene
+photographs, laboratory reports, medical reports, computer records, child pornography,
+child erotica, collateral evidence, background information, pre-sentence evaluations,
+prison records, etc.) that are not normally available to mental health professionals and
+academic researchers.
+• I have authored more than 30 articles, monographs, and book chapters (published in
+"peer" reviewed publications) setting forth what I had learned about analyzing the
+criminal aspects of deviant sexual behavior and understanding how sex offenders and
+their child victims behave.
+• I received the Jefferson Award for Research on "Ritualistic Abuse of Children" from the
+University of Virginia, Charlottesville, Virginia (1990).
+• Since August 2001, I have served on the Research Advisory Board of the FBI National
+Center for the Analysis of Violent Crime (NCAVC) that evaluates and monitors research
+on the sexual victimization of children.
+12. Some significant aspects of the case consultation component of my work include:
+• My job in the FBI BSU/NCAVC was not to investigate cases, but to consult on cases.
+For the past 25 years, I have consulted on thousands of specific cases from all over the
+United States and from many foreign countries and have been able to document broad
+patterns of behavior in sexual victimization of children cases.
+• I have analyzed thousands of cases and provided:
+• investigative, prosecutive, and sentencing guidance;
+• expert opinions, advice, and direction; and
+• behavioral analysis
+• I have provided this analysis to state and local police officers, FBI Agents, federal
+investigators, prosecutors, mental health and medical professionals, social workers,
+organizations providing access to children, defense attorneys, and civil attorneys.
+• My case consultations included requests for assistance in
+• the investigation and/or prosecution of criminal cases,
+• the filing of civil litigation, and
+• the development of procedures to protect children
+, I have consulted on cases and situations involving child pornography, child sexual abuse
+ncest, child sexual exploitation, child sex rings, compliant child victims, child
+prostitution, Internet crimes against children, nuisance sex offenses, ritualistic abuse of
+children, child abduction, sexual assault, rape, and sexual homicide.
+pornography, child erotica, collateral evidence, etc.) that are not normally available to
+mental health professionals and academic researchers.
+• My analysis and conclusions in these cases were based on objectively evaluating in
+totality the most detailed and reliable information available.
+3
+
+
+13. Some significant indicators of the acceptance and recognition of my knowledge and expertise
+in the area of sexual victimization of children include:
+• I was invited to be a member of the Advisory Board for the Out of Home Abuse Research
+Project of the American Bar Association.
+• I was invited to be a member of the Advisory Board for the Program to Increase
+Understanding of Child Sexual Exploitation of the American Bar Association.
+• I was invited to be a participant to a child pornography conference sponsored by the
+American Medical Association.
+• I was invited to be a participant to a Planning Meeting on Child Pornography and Child
+Abuse sponsored by the National Academy of Sciences National Research Council.
+• I was a member of the editorial review board of Child Maltreatment, the Journal of the
+American Professional Society of Children (APSAC).
+• I was asked to and have peer reviewed articles for the International Journal of Child
+Abuse and Neglect, the Journal of Interpersonal Violence, Child Maltreatment, Sexual
+Abuse, the FBI Law Enforcement Bulletin, and The Police Chief.
+• The National Center for Missing & Exploited Children (NCMEC) has distributed more
+than 205,000 copies of the 4 editions of my monograph Child Molesters: A Behavioral
+Analysis.
+• I was the guest co-editor for the Special Issue of The APSAC Advisor Vol 14, No 2
+(Spring 2002) on the topic of "The Compliant Child Victim."
+• My observations and analysis concerning compliant child victims were published in The
+APSAC Advisor, Vol 14, No 2 (Spring 2002) and as a chapter in Viewing Child
+Pornography on the Internet, Russell House Publishing, Dorset, United Kingdom (2005).
+• My observations and analysis concerning compliant child victims were presented at the
+Forensic Symposium sponsored by the Institute of Law, Psychiatry, and Public Policy,
+University of Virginia, Charlottesville, VA (2003) and at the Psychological and Legal
+Issues of Internet Abuse Images Conference, Department of Applied Psychology,
+University College, Cork, Ireland (2004).
+• Professionals would not be utilizing my knowledge and expertise for so long if it had no
+validity.
+• My work and findings concerning the sexual victimization of children have been cited
+and referenced in numerous publications and legal documents (e.g., affidavits for search
+warrants, legal briefs, court decisions).
+• I have been invited to present my findings before organizations such as:
+• Academy of Criminal Justice Sciences,
+• American Academy of Forensic Sciences,
+• Institute of Law, Psychiatry, and Public Policy,
+Department of Psychiatric Medicine - Western State Hospital,
+Department of Psychology, University of Alabama,
+• Johns Hopkins University,
+• St Luke Institute for Sexual Disorders,
+• Walter Reed Army Medical Center,
+• Lee Institute of Forensic Science & University of New Haven,
+4
+
+
+• University of Virginia,
+• University of Southern California,
+National Council of Juvenile and Family Court Judges,
+National Judicial College,
+Flaschner Judicial Institute,
+Bronx County Special Grand Jury,
+Solicitor General of Canada,
+Department of Defense Polygraph Institute,
+• National Association of Counsel for Children,
+• Association for Treatment of Sex Abusers (ATSA),
+• American Orthopsychiatric Association,
+• American Academy of Psychiatry and the Law,
+• American Psychological Association,
+• American Academy of Child and Adolescent Psychiatry,
+• Benjamin N. Cardozo School of Law,
+• The Association of the Bar of the City of New York,
+• American Bar Association,
+• Tyndale University College and Seminary
+• Over the years, I have been contacted by hundreds of adult survivors of child sexual
+victimization who have described to me how their victimization fit the behavior
+dynamics I had discussed in my presentations or publications.
+• I was given the Outstanding Professional Award (1996) from the American Professional
+Society on the Abuse of Children (APSAC)
+• I am an invited member of the Advisory Board of the Association for the Treatment of
+Sexual Abusers (ATSA).
+• The dedication of The APSAC Handbook on Child Maltreatment (2nd edition) (2002)
+Sage reads: "This book is dedicated to Kenneth . Lanning. Ken, you are one of the
+pioneers. You led the way. You opened our eyes. You taught us. You were always one
+step ahead. You're the coolest FBI agent we know. You've done more than we can
+count to protect kids. Thanks"
+• I have been interviewed concerning the nature and scope of the sexual victimization of
+children, by the CBS, NBC, ABC, Fox Networks, MSNBC, PBS, CNN, ESPN, Frontline,
+National Public Radio, Associated Press, Time Magazine, Newsweek, Reader's Digest,
+Life, Parade Magazine, Sports Illustrated, Ladies' Home Journal, People Magazine, Los
+Angeles Times, Washington Post, New York Times, Psychiatric News, National Law
+Journal, APBnews.com, Legal Times and dozens of local TV stations and newspapers.
+14. I have testified 7 times before both the United States Senate and United States House of
+Representatives on various topics related to the sexual exploitation of children. Including:
+• On 4/11/84, I testified before the U.S. Senate Subcommittee on Juvenile Justice on
+"Preventing the Abuse of Children in Child Care Facilities: Pedophile Characteristics."
+• On 8/8/84, I testified before the U.S. Senate Subcommittee on Juvenile Justice on
+"Pedophile Collectors"
+• On 6/1185, I testified before the U.S. Senate Subcommittee Security and Terrorism on
+"Use of Computers by Pedophiles"
+5
+
+
+• On 10/31/85, I testified before the U.S. House of Representatives Select Committee on
+Children, Youth and Families on "Child Victims of Exploitation"
+15. I have also been qualified to provide trial testimony, in both criminal and civil trials, about
+my behavioral typology of sex offenders and the behavioral dynamics of the sexual exploitation
+of children, including the following cases in which I provided the testimony and my qualification
+was affirmed on subsequent appeal:
+• United States versus Mervyn Harold Cross, #84-192-CR-T-17 (A) Middle District of
+Florida - 3/11/86 Affirmed - 928 F. 2d 1030 (11" Cir 1990)
+• United States versus Richard Romero, #96-CR-167 Northern District of Illinois - 6/17-
+18/97 & 10/6/97 Affirmed - 189 F. 3d 576 (7" Cir 1999)
+• State of Texas versus Rudolph Edward Kos, #F-97 32232 Dallas, Texas - 3/30/98,
+Affirmed 15 S. W. 3d 633
+• United States v. Kenneth Long, #99-182, District of Columbia - 11/10/99 & 12/99,
+Affirmed - 328 F.3d 655 (D.C. Cir. 2003)
+• United States v. Scott Hayward, #02-63 Western District of Pennsylvania - 7/29/02,
+Affirmed - 2004 WL 405936 (3" Cir. 2004)
+• United States versus Ronald Forrest, Criminal Case # AW-03-0458, United States
+District Court, District of Maryland- 5/13/04 Affirmed - 429 F. 3d 73, U.S. Court of
+Appeals, Fourth Circuit, 11/14/05
+• State of Connecticut v. John Sorabella III, Docket # HHB-CR00-188041 & 88042
+Superior Court - New Britain Judicial District, New Britain, Connecticut - 12/10/02
+Affirmed - - 277 Conn.155, Connecticut Supreme Court, 2/7/06
+16. As the above clearly indicates, the knowledge and expertise concerning the behavioral
+aspects of the sexual victimization of children that I have developed for over 25 years through
+the totality of training, research, and case consultations and disseminated through presentations
+and publications:
+• Is based on observations and analysis of well-documented patterns of behavior.
+• Has been continually tested in the real world for more than 25 years by fact-finding
+professionals who have utilized this insight.
+• Has withstood peer review and publication.
+• Although there may be no known rate of error because of the limits of human subject
+research and the social sciences, this insight has been objectively applied to many cases
+resulting in the indication of false or inaccurate allegations and innocent subjects.
+• Has standards of practical application based on law enforcement investigative and
+judicial/appellate standards.
+• Has been generally accepted by the relevant community of investigators and other
+objective fact finders.
+6
diff --git a/vision-fixhub/ds9-unparsed-05/b54da70a1a7411b287ffffca99ff5257e3a2c9848721679a21864408d77ee546.receipt.json b/vision-fixhub/ds9-unparsed-05/b54da70a1a7411b287ffffca99ff5257e3a2c9848721679a21864408d77ee546.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3412e83f0ad300251f1eba21617496967ca0528a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b54da70a1a7411b287ffffca99ff5257e3a2c9848721679a21864408d77ee546.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -108,
+  "dataset": "marble-joined",
+  "doc_id": "b54da70a1a7411b287ffffca99ff5257e3a2c9848721679a21864408d77ee546",
+  "engine": "marble-apple-vision",
+  "event_count": 9,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "a1bb77d04ebaebff6306120d6bd4b4230b311a8cc5efb32ac692ab305688ea22",
+  "output_sha256": "6dda7798db7e59451655d31a75605a8bf9f354e3281bb04454ba0ab61ca911f1",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b616a5aae070e12955a5d887e23c3283255814ce770581025d752d28d5a3b4ff.md b/vision-fixhub/ds9-unparsed-05/b616a5aae070e12955a5d887e23c3283255814ce770581025d752d28d5a3b4ff.md
new file mode 100644
index 0000000000000000000000000000000000000000..38ff52fe2aab3fcf21cc9143adbc3a0d1be5a9e7
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b616a5aae070e12955a5d887e23c3283255814ce770581025d752d28d5a3b4ff.md
@@ -0,0 +1,18292 @@
+Case 9:09-CV-80656-KAM Document 21 Entered on FLSD Docket 05/29/2009 Page 1 of 17
+CASE NO.
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Case 9:09-cv-80656-KAM Document 21 Entered on FLSD Docket 05/29/2009 Page 2 of 17
+CASE NO.
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.
+Plainuit,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+Plaintiff,
+CASE NO.
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+/
+CASE NO.
+Paull,
+VS.
+JEFFREY EPSTEIN et al,
+Defendants.
+-2-
+
+
+Case 9:09-CV-80656-KAM Document 21 Entered on FLSD Docket 05/29/2009 Page 3 of 17
+DOE II,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN et al,
+Defendants.
+CASE NO.
+CASE NO.
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+/
+CASE NO.
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+UNITED STATES' RESPONSE TO COURT'S ORDER
+REQUESTING POSITION ON DEFENDANT'S MOTION TO STAY [DE 99]
+Comes now the United States, by and through the undersigned Assistant United States
+Attorney, and files this response to the Court's Order requesting the position of the United
+States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons
+set forth below, it is the United States' position that a stay of the proceedings is not necessary
+and was not contemplated by the Non-Prosecution Agreement between the United States and
+Defendant Jeffrey Epstein.
+-3-
+
+
+Case 9:09-cv-80656-KAM Document 21 Entered on FLSD Docket 05/29/2009 Page 4 of 17
+ISSUE PRESENTED
+The United States is not a party to these lawsuits and, accordingly, is not fully aware
+of the scope of the proceedings, the range of arguments presented by counsel, and any
+correspondence or oral communications between the parties in these civil suits. Based on
+the information presented by the Court and a review of Defendant Jeffrey Epstein's Motion
+to Stay and/or Continue Action for Time Certain Based on Parallel Civil and Criminal
+Proceedings with Incorporated Memorandum of Law (Court File No. 08-CV-80811-
+MARRA/JOHNSON DE 51-1), and responses thereto filed by various plaintiffs in their suits,
+the undersigned understands that the Court has requested the position of the United States
+on the following issue:
+Are there "special circumstances" that require the imposition of a stay of the
+civil proceedings in the "interests of justice" until the "expiration" of the Non-
+Prosecution Agreement ["NPA"] between the United States and Epstein?
+By filing this response, the United States does not make itself a party to this litigation
+and takes no position with respect to the outcome of any of the civil suits; nor does the
+United States take any position regarding Defendant Epstein's performance of his obligations
+pursuant to the NPA. The United States also declines to comment on Defendant Epstein's
+representations regarding past allegations of violations of the NPA by Epstein. The United
+States files this response solely as amicus curiae at the Court's request and does not waive
+any procedural or statutory bars to suit.
+-4-
+
+
+Case 9:09-CV-80656-KAM Document 21 Entered on FLSD Docket 05/29/2009 Page 5 of 17
+STANDARD FOR IMPOSING A DISCRETIONARY STAY
+A.
+The Defendant Must Show that the Assertion of His Fifth
+Amendment Privilege Against Self-Incrimination Would
+Automatically Result in the Entry of Summary Judgment Against
+Him.
+"The decision whether or not to stay civil litigation in deference to parallel criminal
+proceedings is discretionary.... A movant must carry a heavy burden to succeed in such an
+endeavor." Microfinancial, Inc. |. Premier Holidays Internat'l, Inc., 385 F.3d 72, 77 (Ist
+Cir. 2004) (citations omitted). When a defendant facing possible criminal liability invokes
+his Fifth Amendment right against compelled self-incrimination in connection with civil
+litigation, a court can stay discovery or the entire civil case. Diaz |. Jenne, 2007 WL 624286
+*1 (S.D. Fl. Feb. 23, 2007) (Cooke, J.). "However, 'the Constitution does not require a stay
+of civil proceedings pending the outcome of related criminal proceedings. Forcing an
+individual to risk non-criminal disadvantage by remaining silent for fear of self incrimination
+in a parallel criminal proceeding does not rise to the level of an unconstitutional
+infringement."' Id. (quoting Shell Oil Co. |. Altina Assocs., Inc., 866 F. Supp. 536, 540
+(M.D. Fl. 1994)).
+As this Court has previously explained:
+The law regarding stays of civil actions is well-settled in the Eleventh Circuit.
+In United States . Lot 5, Fox Grove, Alachua County, Fla, 23 F.3d 359, 363-
+65 (11th Cir. 1994) ("Lot 5"), the Court articulated the following principles of
+law with respect to a stay of a civil action pending resolution of a related
+criminal action:
+[A] blanket assertion of the privilege is an inadequate basis for
+the issuance of a stay.
+Rather, a court must stay a civil
+-5-
+
+
+Case 9:09-cV-80656-KAM Document 21 Entered on FLSD Docket 05/29/2009 Page 6 of 17
+proceeding pending resolution of a related criminal prosecution
+only when "special circumstances" so require in the "interests
+of justice." The court may deny a stay so long as the privilege's
+invocation does not compel an adverse judgment against the
+claimant.
+Pervis |. State Farm Fire & Casualty Co., 901 F.2d 944 (11th Cir. 1990).
+Under this standard, Movants must show that invocation of the privilege in the
+instant matter will result in certain loss by automatic summary judgment.
+United States |. Two Parcels of Real Property, 92 F.3d 1123, 1129 (11th Cir.
+1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment,
+and not "merely the loss of the defendant's most 'effective defense."'
+Securities & Exchange Comm. |. Incendy, 936 F. Supp. at 955 (S.D. FI. 1996);
+Shell Oil Co., 866 F. Supp. at 540-41.
+Court-Appointed Receiver of Lancer Mgt. Group LLC |. Lauer, 2009 WL 800144 (S.D. FI.
+Mar. 25, 2009) (Marra, J.).
+Thus, before reaching the relative benefit and prejudice to each of the parties caused
+by staying the cases, the Court must determine whether, if defendant Epstein were to invoke
+his Fifth Amendment right against self-incrimination' and the Court were to allow an adverse
+inference to be drawn therefrom, an adverse judgment against Epstein would be
+automatically compelled. The United States respectfully submits that it would not.
+'It appears from a brief review of some of Epstein's discovery responses that Epstein has
+made a blanket assertion of the privilege. For example, Epstein has asserted his Fifth Amendment
+privilege in response to a plaintiff's request to produce the NPA and the United States' list of
+identified victims although these documents were provided to Epstein by the United States
+-6-
+
+
+Case 9:09-CV-80656-KAM Document 21 Entered on FLSD Docket 05/29/2009 Page 7 of 17
+From a review of the Complaints filed by the plaintiffs in these cases, it appears that
+some have filed claims based upon Title 18, United States Code, Section 2255, some have
+filed claims based upon common law torts, and some have filed a combination of the two.
+Under general principles of tort law, a plaintiff is required to prove: (1) that the defendant
+committed a bad act; (2) that the plaintiff suffered damages; and (3) that the damages were
+caused by the defendant's bad act. To succeed on a claim under 18 U.S.C. § 2255, a plaintiff
+must show: (1) that the plaintiff is a person who, while a minor, was a victim of an
+enumerated offense committed by the defendant; (2) that the person suffered personal injury
+as a result of that violation; and (3) the amount of damages she sustained.
+Epstein's assertion of his Fifth Amendment privilege could result in the drawing of
+a negative inference only as to the first element under both of these claims. Therefore, to
+succeed on summary judgment (or at trial), the plaintiffs would still have to prove that they
+suffered personal injury/damages as a result of the defendant's bad act. Cf. In re Financial
+Federated Title & Trust, Inc., 252 B.R. 834, 838 (S.D. Fl. Bank. Ct. 2000) (Stay not
+warranted in bankruptcy proceeding where criminal indictment was pending because
+negative inference related only to defendant's receipt of allegedly fraudulent transfers, but
+"Trustee must still carry the burden of proving all of the elements of his complaint for
+fraudulent transfers ... includ[ing] fraudulent intent, insolvency, and financial condition at
+the time of the transfers to the Defendants.").
+While Epstein may believe that his arguments and proof as to the first element are his
+"most effective defense," that alone is insufficient to warrant the imposition of a stay of the
+-7-
+
+
+Case 9:09-cv-80656-KAM Document 21 Entered on FLSD Docket 05/29/2009 Page 8 of 17
+litigation. There are two other items for the Court to consider in deciding this issue. First,
+pursuant to the terms of the NPA, as to those victims identified by the United States, Epstein
+has already made a concession that they are victims of an enumerated offense committed by
+Epstein. Thus, this inference is drawn not due to his invocation of the right against selfincrimination but due to his entry into a contractual agreement with the United States for
+which the identified victims are third-party beneficiaries.? Second, in Lot 5, the Eleventh
+Circuit pointed out the wealth of evidence other than the defendant's testimony that could
+be used to defeat a liability claim. See Lot 5, 23 F.3d at 364 ("Thus, Claimant's assertion that
+only her own testimony could vindicate her is groundless; other participants to the illegal acts
+that gave rise to the forfeiture were available to testify at trial. Claimant's failure to indicate
+with precision why she did not use other parties' testimony to substantiate her defense was
+fatal."). For example, Epstein could mount a defense using effective cross-examination,
+telephone records, travel records, documents within the possession of the plaintiffs or third
+parties, and/or the testimony of third parties to rebut the plaintiffs' proof.
+"The United States notes that it is not aware of the identities of all of the plaintiffs in the civil
+suits. To the extent that any are not "identified vietims" under the NPA, this contractual provision
+would not apply.
+-8-
+
+
+Case 9:09-cv-80656-KAM Document 21 Entered on FLSD Docket 05/29/2009 Page 9 of 17
+B.
+Additional Factors to Consider in Balancing the Prejudice to the
+Parties
+If the Court is persuaded that the negative inference drawn from Epstein's assertion
+of his Fifth Amendment privilege would result in an automatic grant of summary judgment
+in favor of the plaintiffs, then the Court must engage in a balancing of equities in determining
+whether there are "special circumstances" warranting the imposition of a stay "'to prevent
+a party from suffering substantial and irreparable prejudice."" Securites and Exchange
+Comm'n| Incendy, 936 F. Supp. 952, 956 (S.D. Fl. 1996) (quoting S.E.C. | First Financial
+Group of Texas, Inc., 659 F.2d 660, 668 (5th Cir. 1981) (add'l citations omitted).
+Examples of "special circumstances" provided by the Supreme Court in
+[United States |. Kordel] are: (1) if the Government brought the civil action
+solely to obtain evidence for its criminal prosecution, (2) if the Government
+failed to advise the defendant in the civil proceeding that it contemplates his
+criminal prosecution; (3) if the defendant is without counsel or reasonably
+fears prejudice from adverse pretrial publicity or other unfair injury; or (4) any
+other special circumstances indicating unconstitutionality or even impropriety.
+Incendy at 956 (citing United States |. Kordel, 397 U.S. 1, 11 (1970)). See also Securities
+and Exchange Comm'n | Wright, 261 Fed. Appx. 259, 263 (11th Cir. 2008) (*[NJo 'special
+circumstances' existed in this case warranting a stay, as there is no record evidence
+suggesting the Government had brought the civil case solely to obtain evidence for the
+criminal prosecution or that the criminal case against [defendant] was unconstitutional or
+inappropriately instituted.").
+No "special circumstances" exist here. First, unlike Wright and Incendy, the United
+States Government is not a party to the civil litigation. Each suit is brought on behalf of an
+-9-
+
+
+Case 9:09-CV-80656-KAM Document 21 Entered on FLSD Docket 05/29/2009 Page 10 of 17
+individual plaintiff represented by private counsel. Some of those plaintiffs are adverse to
+the United States and have filed suit against the Government based upon its handling of the
+criminal case against Epstein. (See In rul
+Marra.) There has been no allegation, and certainly no showing, that the civil litigation is
+a ruse to obtain discovery on behalf of the criminal investigation.
+As some of the plaintiffs have mentioned, one purpose of the NPA was to place the
+identified victims in the same position where they would have been if Epstein had been
+convicted after trial of an offense enumerated in 18 U.S.C. § 2255. (See, e.g.. Court File No.
+08-CV-80119 DE 49-2.) If Epstein had proceeded to trial and been convicted, those victims
+would have been entitled to restitution and to file suit pursuant to 18 U.S.C. § 2255, and
+would have been entitled to the same sorts of discovery that they now seek. None of the
+plaintiffs has contacted the United States about passing on materials gathered through
+discovery to any criminal investigators or about seeking discovery that would be relevant
+only to the criminal proceedings, rather than to their individual cases. If Epstein has
+legitimate concerns that the civil discovery process is being abused in some way, he can ask
+the Court for a protective order limiting the scope of discovery or its distribution.
+Furthermore, if at some time in the future, Epstein were the subject of a criminal indictment
+and he alleged that the evidence to be used against him was gathered improperly, he could
+file a motion to suppress or to dismiss the indictment in that criminal action. See, e.g., United
+States, ex. rel. Westrick |. Second Chance, 2007 WL 1020808 *4 (D.D.C. Mar. 31, 2007)
+(Defendant in civil False Claims Act suit moved to stay civil action pending criminal
+- 10-
+
+
+Case 9:09-cv-80656-KAM Document 21 Entered on FLSD Docket 05/29/2009 Page 11 of 17
+investigation where no indietment had been returned. The district court denied the motion,
+noting that while "allowing civil discovery to proceed may afford the government [who was
+the real party in interest in the civil case] the opportunity to gain evidence that it may not be
+entitled to under the more restrictive criminal discovery rules, if and when discovery
+becomes necessary, protective orders and other remedial measures may be taken.") (citations
+omitted).
+By entering into the NPA, with its explicit discussion of 18 U.S.C. § 2255, Epstein
+acknowledged that the United States was trying to protect the victims' rights to restitution
+and that civil claims would likely follow. Epstein did not bargain for a stay of those
+proceedings. Instead, both parties received benefits and gave consideration for the bargain
+that was struck - while Epstein is faced with answering discovery requests that he would not
+face during criminal proceedings, he also is entitled to the identification of and extensive
+discovery from the victims, which he would not have received in the criminal case. Based
+upon a review of the discovery requests he has promulgated thus far, it appears that Epstein
+is taking full advantage of this benefit and if a criminal case were ever filed, he would, no
+doubt, seek to use that information in his defense.?
+"With respect to the other "special circumstances" mentioned in Incendy, the government
+obviously advised Epstein of the potential for criminal charges, and that knowledge led to the
+negotiation of the NPA. Epstein also has a number of attorneys listed on the Service List for the
+civil cases and has retained a similarly large number of attorneys to handle the criminal investigation
+and negotiation of the NPA. Epstein alleges a fear of adverse publicity, but as the plaintiffs have
+pointed out, during the course of the state and federal criminal investigations, Epstein's personal
+publicist distributed stories to the press impugning the credibility of the victims and other witnesses
+and averring that the victims' allegations of abuse were made solely to extract money from the
+defendant. In the context of some of the civil suits currently pending, Epstein has asked the Court
+-11-
+
+
+Case 9:09-CV-80656-KAM Document 21 Entered on FLSD Docket 05/29/2009 Page 12 of 17
+Unlike Wright and Incendy, Epstein also has not been criminally indicted. In some
+districts, this alone is virtually dispositive. See, e.g., Sterling Nat'l Bank |. A-1 Hotels
+Internat'l, 175 F. Supp. 2d 573, 576-77 (S.D.N.Y. 2001) ("district courts in this Circuit
+"generally grant the extraordinary remedy of a stay only after the defendant seeking a stay
+has been indicted. '"' (quoting Citibank, N.A. |. Hakim, 1993 WL 481335 * 1 (S.D.N.Y. Nov.
+18, 1993) (add'I citations omitted). As one court explained:
+the consensus that a party seeking a stay bears a heavier burden when he has
+not yet been indicted derives logically from the balancing test set out by the
+courts of appeals that have considered the question. When a defendant has
+been indicted, his situation is particularly dangerous, and takes a certain
+priority, for the risk to his liberty, the importance of safeguarding his
+constitutional rights, and even the strain on his resources and attention that
+makes defending satellite civil litigation particularly difficult, all weigh in
+favor of his interest. Moreover, if the potential prejudice to the defendant is
+particularly high post-indictment, the prejudice to the plaintiff of staying
+proceedings is somewhat reduced, since the criminal litigation has reached a
+crisis that will lead to a reasonably speedy resolution. Furthermore, at that
+stage in the criminal proceeding, the contours of the indictment will provide
+the Court with a reasonable basis for determining the extent of the threat to the
+defendant's Fifth Amendment rights, and the likely extent and timing of the
+criminal litigation.
+Pre-indictment, these factors must be balanced significantly differently.
+Though many of the same risks to the civil defendant are present, the dangers
+are at least somewhat more remote, and it is inherently unclear to the Court
+just how much the unindicted defendant really has to fear. Conversely, the
+delay imposed on the plaintiff is potentially indefinite. There is no telling how
+complicated the government's investigation may be, whether the allegations
+of the particular civil plaintiff are merely the tip of an iceberg that will result
+in a lengthy and open-ended investigation, what priority the government
+assigns to the investigation, whether it will result in charges that will have to
+to unseal the victims' names so that he may make use similar press efforts to impugn their
+credibility.
+-12-
+
+
+Case 9:09-cv-80656-KAM Document 21 Entered on FLSD Docket 05/29/2009 Page 13 of 17
+be litigated, or how time-consuming the resulting criminal case will be. Under
+these circumstances, the likelihood that a civil party can make the necessary
+showing to obtain the "extraordinary" remedy of a stay is inevitably much
+reduced
+Sterling Nat'l Bank, 175 F. Supp. 2d at 577 (internal citations omitted).
+The First Circuit has noted that the decision whether to grant a stay "is highly nuanced
+... [and] involves competing interests. Balancing these interests is a situation-specific task,
+and an inquiring court must take a careful look at the idiosyncratic circumstances of the case
+before it." Microfinancial, supra, 385 F.3d at 78. Epstein's case is more idiosyncratic than
+most.
+As the Court aptly noted in its Order denying Epstein's first motion to stay the civil
+proceedings, Epstein has not been indicted and there are no criminal proceedings pending
+against him.* The resurrection of criminal proceedings against Epstein lies entirely within
+Epstein's own hands, by performing or not performing under the terms of the NPA. This tips
+the balance of equities even further in favor of the plaintiffs. Epstein makes allegations that
+the U.S. Attorney's Office has unfettered discretion in determining breaches of the NPA, but
+this is no different than in any contractual setting. If one party believes that there has been
+a breach, it may seek the remedy set forth in the contract. If the other party believes that
+'Epstein points to provisions requiring him to maintain certain evidence "inviolate" as proof
+that the grand jury investigation is still active. These provisions are meant only to insure that easily
+destroyed evidence identified through the investigation, such as computer equipment, that is still in
+Epstein's control, will still be available to investigators if Epstein does, in fact, breach the NPA.
+Epstein is well aware that litigation concerning those matters have been removed from the Court's
+docket, at the insistence of the United States, because it fully halted its investigation in accordance
+with the terms of the NPA.
+- 13-
+
+
+Case 9:09-cv-80656-KAM Document 21 Entered on FLSD Docket 05/29/2009 Page 14 of 17
+there has been no breach, it has a remedy at law or equity. In this situation, Epstein would
+be entitled to seek dismissal of the indictment. See United States |. Beeks, 167 Fed. Appx
+777 (11th Cir. 2006); United States |. Diaz, 138 Fed. Appx. 965 (9th Cir. 2005); United
+States |. Davis, 393 F.3d 540 (5th Cir. 2004):
+Epstein argues that because he is seeking a finite period of delay - until the time that
+he asserts that the NPA "expires" - and that, thereafter, he will promptly provide full and
+complete responses to all discovery, the harm to the plaintiffs is de minimis. With all respect,
+this overlooks a number of obvious issues. First, if a stay is imposed until Epstein's
+proposed "expiration date," it affords Epstein one of two incentives: (a) to delay any intended
+breach until a time when he believes that the United States has no remedy and then to breach
+the agreement with impunity (i.e, to use the NPA as a shield and a sword); or (b) to delay the
+civil litigation as long as possible (until shortly before the "expiration" of the NPA), and
+then, after criminal charges have been filed, to seek a mandatory stay of the civil cases until
+the criminal case is resolved. Thus, contrary to the assertions of Epstein, the delay is not
+limited but, instead, is "potentially indefinite," as Sterling Bank warns. If the U.S. Attorney's
+Office were to proceed criminally, the litigation would likely be very lengthy, and would
+result in an even greater delay to the plaintiffs.
+"The United States also notes that this finite termination to Epstein's exposure to potential
+criminal consequences is illusory. The NPA addresses only certain victims identified during the
+course of the government's investigation. To the extent that any of the plaintiffs who have already
+filed suit against Epstein do not fall within that group, the NPA does not address potential charges
+based upon crimes committed against them. The NPA also does not bind any other state or federal
+prosecutor from pursuing charges for criminal acts committed within their jurisdiction(s). The
+federal statute of limitations for offenses against children is ten years or the life of the child,
+-14-
+
+
+Case 9:09-cv-80656-KAM Document 21 Entered on FLSD Docket 05/29/2009 Page 15 of 17
+The factors to consider include: "(i) the interests of the civil plaintiff in proceeding
+expeditiously with the civil litigation, including the avoidance of any prejudice to the
+plaintiff should a delay transpire; (ii) the hardship to the defendant, including the burden
+placed upon him should the cases go forward in tandem; (iii) the convenience of both the
+civil and criminal courts; (iv) the interests of third parties; ... ( the public interest:] ...
+(vi) the good faith of the litigants (or the absence of it) and (vii) the status of the cases."
+Microfinancial, 385 F.3d at 78 (citations omitted).
+In considering those factors, the United States respectfully recommends to the Court
+that all of the factors weigh against a stay. In making its decision, the Court should consider
+that, unlike all of the cases cited herein, Epstein seeks to stay not one suit involving a single
+plaintiff, but more than a dozen suits filed by individual plaintiffs. Each of those plaintiffs,
+in turn, impliedly asserts that she is a "crime victim" with the "right to full and timely
+restitution" and the "right to proceedings free from unreasonable delay." 18 U.S.C. §
+3771(a)(6) & (7). As noted above, one of the purposes of the NPA was to provide these
+rights to victims identified in the Government's investigation. Thus, this factor weighs more
+heavily for the plaintiffs than in the average civil dispute as it embodies both the plaintiffs'
+and the public's interests. The victims who were identified in the government investigation,
+by and large, were without financial assets and had significant counseling needs that could
+whichever is longer: 18 U.S.C. § 3283. Thus, for Epstein (or any other person accused of sexually
+busing children) to "wait out" any chance of criminal liability, the court would have to stay civi
+itigation until all of the plaintiffs have died
+- 15-
+
+
+Case 9:09-CV-80656-KAM Document 21 Entered on FLSD Docket 05/29/2009 Page 16 of 17
+be remedied through obtaining restitution from Epstein. In addition to those needs, they have
+legitimate concerns about memories fading, witnesses becoming unavailable, and dissipation
+of Epstein's assets while the matter is stayed. On the other hand, while the potential harm
+to the defendant normally weighs in the defendant's favor, in this case, Epstein has
+significant control over whether the criminal investigation remains in abeyance and whether
+criminal charges are ever filed.
+CONCLUSION
+In accordance with the Court's Order, the United States hereby submits that it is not
+aware of any "special circumstances" that warrant staying all of the civil cases pending the
+"expiration" of the NPA.
+Respectfully submitted,
+UNITED STATES ATTORNEY
+By:
+500 East Broward Boulevard, 7th Floor
+Ft. Lauderdale, FL 33394
+Telephone:
+Facsimile: 9
+-16-
+
+
+Case 9:09-Cv-80656-KAM Document 21 Entered on FLSD Docket 05/29/2009 Page 17 of 17
+HEREBY CERTIFY that on May 28, 2009, I electronically filed the foregoin
+ocument with the Clerk of the Court using CM/ECF. According to the Court's website, counse
+for all parties are able to receive notice via the CM/ECF system.
+- 17-
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+January 24, 2007
+DELIVERY BY HAND
+James L. Eisenberg, Esq.
+250 S Australian Ave, Ste 704
+West Palm Beach, FL 33401-5007
+Re: Federal Grand Jury Subpoena
+Dear Jim:
+A new grand jury has been empaneled and I have enclosed a new subpoena for
+As I mentioned earlier, Ms.
+¡ is not a target of this investigation and the United
+States seeks her testimony solely as a victim/witness. During our last conversation regarding
+Ms.
+i, you indicated that she was unwilling to speak with us pursuant to a Kastigar
+letter and that she also was unwilling to speak with the grand jury and intends to invoke the
+Fifth Amendment if questioned. Please confer with her to confirm whether this remains her
+position. If it is, please advise in writing. Even if Ms.
+ris inclined to invoke her Fifth
+Amendment rights, she must still appear pursuant to the subpoena so that I may ask her
+questions that would not require the invocation of the Fifth Amendment. If she still invokes,
+I intend to move to compel her answers. If you or your client is unavailable on February 6,
+2007, please let me know of another Tuesday when you are available.
+I also am concerned about a potential conflict of interest in your representation of Ms.
+In case of future litigation regarding this issue, please provide me with information
+regarding who is paying (directly or indirectly) for your services on behalf of Ms.
+I, the
+scope of your representation, and whether you are taking direction on this matter from
+anyone other than Ms.
+If any formal or informal joint defense agreements exist,
+whether in writing or otherwise, please provide a copy of such agreements. If the agreement
+is purely oral, please provide a written summary of its terms.
+PENGAD 800-631-6385
+
+1
+
+
+JAMES EISENBERG, EsQ.
+JANUARY 24, 2007
+I look forward to your response.
+Inited States
+By:
+
+
+SUBPOENA TO TESTIFY
+SUBPOENA FOR:
+X PERSON
+X
+DOCUMENTS OR OBJECTISI
+YOUARE HEREBY COMMANDED to appear and testify before the
+Court at the place, date and time specified below.
+of the United States District
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+DATE AND TIME:
+February 6, 200
+1:00pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+ANY AND ALL NOTES, LETTERS, CARDS, GIETS, PAYMENTS, AND PHOTOGRAPHS YOU HAVE RECEIVED
+FROM JEFFREY EPSTEIN,
+ANANDATI PHOTOGRAPHS, WHETHER PRINTED OR DIĞITAL, OF JEPFREY EPSTEIN,
+ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS; OR TELEPHONE
+MESSAGES THAT YOU HAVE SENT TO AND/OR RECEIVED FROM JEFFREY EPSTEIN,
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+January 23, 2007
+This subpoena is issued upon application
+of the United States of America
+*If not applicable, enter "none."
+DON DESTIKET OR T
+Name, Address and Phone Number of Assistant U.S. Attorney
+, Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+Tel:
+Fax:
+To be used in linu of A0110
+JAN.8G
+
+
+Florida Bar Board Certified Criminal Trial Lawyer
+National Board Of Trial Advocacy Certified Criminal Trial Advocate
+KAI LI ALOE FOUTS
+One Clearlake Centre, Suite 704, 250 Australian Avenue South, West Palm Beach, FL 33401
+February 1, 2007
+Fax:
+Asst. U.S. Attorney
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+Re:
+Grand Jury Subpoena for
+Dear
+I received your letter dated January 24, 2007 with regard to
+. I must admit I forced
+myself to wait several days to respond in order to "cool off" and not say anything I would regret
+later. Now that time has passed; allow me to respond appropriately.
+1. If you want to force Ms.
+a single mother, to come to the grand jury room to
+personally invoke her Fifth Amendment rights, she will be there. That does remain her position.
+My only request is that you provide a babysitter service for her child. I will be there, but I am not
+paid to babysit and Ms.
+should not have to pay someone. It is this type of attitude, that your
+office refuses to accept the fact that it is Ms.
+decision not to cooperate with the government
+that upsets her. Your office fails to recognize that merely coming to court is a problem for a single
+mother like Ms.
+and, under these circumstances, appears to be a waste of time at best and, in
+her mind, personal harassment.
+2. Rest assured that there is no conflict of interest in my representation of Ms.
+In this
+case I have always been asked and always will exercise independent judgment to follow my client's
+independent will. The remainder of your questions as to this matter are really none of the
+Government's business.
+3. I will share with you that one of the reasons for our firm position that Ms.
+will
+invoke her Fifth Amendment right and choose not to voluntarily cooperate with the Government is
+our concern that the Government is not exercising independent judgment in this case.
+The history of this case has been in the newspapers. The case is being prosecuted in State court.
+Despite the state court prosecution, the Town of Palm Beach Police Chief went on what can only be
+
+2
+
+
+1, Asst. U.S. Attorney
+February 1, 2007
+Page Two
+described as a public rampage in the newspaper when the case was not prosecuted to his liking that
+reminded me of a small child having a public temper tantrum. In my thirty years of experience, I
+have never seen a law enforcement officer like this publicly make what appeared to be a political
+case in the newspaper for a prosecution and publicly criticize anyone who got in his way, including
+the elected State Attorney. This resulted in a federal investigation on a topic no one remembers the
+Federal Government ever being interested in prosecuting before. Although I am certain that you
+personally have not had your decision-making process compromised, the appearance that your office
+is being influenced by the Town of Palm Beach Police Chief's agenda is very real. Under these
+circumstances don't see how any lawyer could advise any client to voluntarily cooperate. Of
+special concern is that the Town of Palm Beach Police have promoted prosecuting at least one of the
+girls who allegedly gave massages.
+One final thought. My client and my fear that Ms.
+could be prosecuted is enhanced by the
+demand for the personal appearance made in your letter. Your initial Kastiger letter fell far short
+of granting the functional equivalent of DOJ immunity. Several months ago I was given the distinct
+impression through our conversations that you were going to obtain DOJ immunity for Ms.
+Now the government is changing course for no apparent reason. This leads to speculation that the
+only reason for the turnabout is that prosecution in either state or federal court is being considered
+by someone.
+None of the above is directed at you personally. I want to repeat that you have always treated us with
+respect. Maybe your office should advise the Town Police Chief to act in a similar fashion.
+JAMES
+
+
+500 South Australian Ave, Suite 400
+West Palm Beach, Florida 33401
+Facsimile
+FACSIMILE COVER SHEET
+DATE:
+TO: JIM EISENBERG, ESQ.
+FAX NO.
+PHONE NO.
+February 5, 2007
+# OF PAGES:
+RE:
+FROM:
+A.
+VILLAFAÑA, ASSISTANT U.S. ATTORNEY
+PHONE NO.
+COMMENTS: Hi Tim- These pertably say the
+sane thing, but they shird a little
+different.
+for chares, please let me
+if you have any noggstions
+arcate yat for ice today. '
+Regards,
+PENGAD 800-631-8080
+
+3
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Pacsimile:
+February 5, 2007
+DELIVERY BY HAND
+Ms.
+c/o James L. Eisenberg, Esq.
+250 S Australian Ave, Ste 704
+West Palm Beach, FL 33401-5007
+Re:
+Grand Jury Testimony of |
+Dear Ms.
+This letter confirms the understanding between yourself and the United States Attorney's
+Office for the Southern District of Florida.
+You have represented that you will truthfully answer questions of the federal government in
+its investigation of the procurement of prostitutes, amongst others. You will supply complete and
+truthful information to the attorneys and law enforcement officers of the federal government and to
+any Federal Grand Jury which may conduct an investigation, as well as in any other proceeding
+related to or growing out of this investigation. The obligation of truthful disclosure includes your
+obligation to provide the attorneys and law enforcement officers of the federal government with any
+documents, records or other tangible evidence within your custody or control relating to the matters
+about which you are questioned. You will neither attempt to protect any person or entity through
+false information or omission, nor falsely implicate any person or entity.
+No statements provided by you on this date in this matter pursuant to this agreement will be
+offered into evidence in any criminal case against you, except during a prosecution for perjury and/or
+giving a false statement. However, if it is determined that you have materially violated any provision
+of this agreement, all statements made by you shall be admissible in evidence against you in any
+proceeding.
+The federal government remains free to use information derived from the grand jury
+testimony directly or indirectly for the purpose of obtaining leads to other evidence, which may be
+used against you. You expressly waive any right to claim that such evidence should not be
+introduced because it was obtained as a result of the grand jury testimony. Furthermore, the federal
+government may use statements made in the grand jury testimony and all evidence derived directly
+or indirectly therefrom for the purpose of cross-examination, if you testify at any trial or if you
+
+
+Ms.
+FEBRUARY 5, 2007
+suborn testimony that contradicts your prior statements and testimony.
+No additional promises, agreements and conditions have been entered into other than those
+set forth in this letter and none will be entered into unless in writing and signed by all parties.
+By:
+I have read this agreement and discussed it with my attorney, and I hereby acknowledge that it
+fully sets forth my agreement with the office of the United States Attorney for the Southern District of
+Florida. I state that there have been no additional promises, agreements or representations made to me
+by any officials of the United States in connection with this matter.
+Dated: February
+→ 2007
+West Palm Beach, Florida
+James L. Eisenberg, Esq.
+Attorney for
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+February 5, 2007
+DELIVERY BY HAND
+James L. Eisenberg, Esq.
+250 S Australian Ave, Ste 704
+West Palm Beach, FL 33401-5007
+Re:
+Dear Mr. Eisenberg:
+I am writing to clarify the ground rules for the interview with your client,
+("your client"), to occur February 2007.
+As I mentioned earlier, Ms.
+is not a target or subject of this investigation, but
+instead is being interviewed solely as a victim/witness. However, to address your concern
+about criminal exposure, if your client complies with every provision of this agreement, then
+the United States Attorney's Office for the Southern District of Florida ("this Office") will
+treat all statements made by your client during the interview as statements made pursuant to
+Rule 11(f) of the Federal Rules of Criminal Procedure. This is not a grant of immunity,
+which can be given only with approval of the Justice Department, but protects your client
+from having the statements made by her during the interview from being used against her
+directly. To guard against any misunderstandings concerning the interview of your client,
+this letter sets forth the terms of this agreement.
+Your client agrees to be fully interviewed, that is, to provide information concerning
+your client's knowledge of, and participation in criminal activity, including but not limited
+to the procurement of prostitutes. The protection of this letter applies to an interview that
+Will be conducted by this Office, Special Agents of the Federal Bureau of Investigation, and
+any other federal law enforcement agency this Office may require. Under this agreement,
+no information disclosed by your client during the interview will be offered in evidence
+against her in any criminal or civil proceeding, provided that your client complies with this
+agreement and that the information your client furnishes is truthful, complete, and accurate.
+It, however, your client gives materially false, incomplete, or misleading information,
+
+
+JaMeS L. EISENBERG, ESQ.
+RE:
+then this Office may use such information in any matter or proceeding and your client is
+subject to prosecution for perjury, obstruction of justice, and making false statements to
+government agencies. Any such prosecution may be based upon information provided by
+your client during the course of the interview, and such information, including your client's
+statements, will be admissible against your client in any grand jury or other proceeding.
+The government also may use statements made by your client in the interview and all
+evidence derived directly or indirectly therefrom for the purpose of impeachment or
+cross-examination if she testifies at any trial or hearing, and/or in any rebuttal case against
+your client in a criminal trial in which she is a defendant or a witness. These provisions are
+necessary to ensure that your client does not make or offer any false representation or
+statement in any proceeding or to a government agency or commit perjury during any
+testimony.
+Your client further agrees that attorneys for the United States may be present at the
+interview, and agrees not to seek disqualification of any such government attorney from any
+proceeding or trial because of their participation at the interview.
+The entire agreement between the United States and your client is set forth in this
+letter. No additional promises, agreements, or conditions have been entered into and none
+will be entered into unless in writing and signed by all parties.
+If the foregoing accurately reflects the understanding and agreement between this
+Office and your client, it is requested that you and your client execute this letter as provided
+below.
+• By:
+I have received this letter from my attorney, James L. Eisenberg, Esquire, have read
+it and discussed it with my attorney, and I hereby acknowledge that it fully sets forth my
+understanding and agreement with the Office of the United States Attorney for the Southern
+
+
+JAMES L. EISENBERG, EsQ.
+RE: L
+PAGE 3
+District of Florida. I state that there have been no additional promises or representations
+made to me by any official of the United States Government or by my attorney in connection
+with this matter.
+Dated:
+James L. Eisenberg, Esquire
+
+
+Authorization for Reimbursement
+of Unusual Expenses of Fact Witnesses
+Request for Unusual Expense(s) of Fact Witness
+(For United States Attorney's Office Use Only)
+1. Case Name
+2. Court Docket Number
+Operaton LeaVer
+4. Location of Court Proceeding
+5. Contact Person
+West PalmBeach
+7. Witness Name & Address, Phone #, SSN
+Control #
+• Raauostina ALSA
+6. Contact Person Number
+8. Vendor Name & Address, Phone #, TIN/SSN
+9. Payment to be made to:
+10. Receipt/Invoice is:
+11. Type of Unusual Expense:
+Medically Necessary Item
+(Attached Supporting Statement)
+A Dependent Care
+• Excess Lodging/Per Diem
+• Travel & Transportation
+• Pretrial Conference Waiver
+• Other
+13. Start Date of Service (MO/DA/YR)
+2/6/07
+16. Justification:
+12. Explanation:
+The witness has a small child and
+would not had no one who could
+watch the child while she
+testified.
+14. End Date of Service (MO/DA/YR)
+2/6/07
+15. Amount
+17. I hereby certify that the expenses and services listed on this document are appropriate and are within the Federal laws
+and regulations. I fully understand that I can be held personally liable or be subject to disciplinary action for improperly using
+government funds or services that exceed delegated authority or that violate Federal laws or regulations.
+Signature of Requesting AUSA
+18. Name & Title of Approving Official
+Date
+19. Date (MO/DA/YR)
+20. Signature of Approving Official
+
+4
+UFWE Form
+
+
+Florida Bar Board Certified Criminal Trial Lawyer
+National Board Of Trial Advocacy Certified Criminal Trial Advocate
+KAI LI ALOE FOUTS
+One Clearlake Centre, Suite 704, 250 Australian Avenue South, West Palm Beach, FL 33401
+February 12, 2007
+Fax:
+Asst. U.S. Attorney
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+Re:
+Grand Jury Subpoena for
+Dear
+As always, it was a pleasure speaking to you the other day. Pursuant to our telephone conference
+I am writing this letter to proffer my concerns for
+should she testify without immunity
+before a federal grand jury. Therefore, allow me to reiterate that Ms.
+will refuse to voluntarily
+cooperate with the federal government. She has a good faith basis for her position under the Fifth
+Amendment to the United States Constitution.
+We, of course, do not live or work in a vacuum. We have read many inflammatory remarks the
+Town of Palm Beach Police Chief has made to the media about the state court's handling of the
+Jeffrey Epstein investigation. The police chief's remarks frighten both myself and my client. I am
+aware that the town police have prepared documents to charge at least one of Mr. Epstein's lady
+friends in state court. If they can push to have one lady charged I remain unconvinced that they do
+not have the ability or political clout to push to have other ladies such as Ms.
+charged.
+The proffered facts that raise my concerns are being provided via this proffer letter. Pursuant to our
+telephone conference agreement, this letter and its contents cannot be used against Mr.
+Ms.
+is not at all certain of dates. She does remember meeting Mr. Epstein about three years
+ago. She is not certain of her age, it could have been when she was sixteen. A girlfriend asked her
+if she wanted a job giving massages. Ms.
+agreed because she had knowledge of massages
+through her mother, who was a masseuse.
+Ms.
+went to Mr. Epstein's house via taxi. Ms.
+girlfriend instructed Ms.
+that,
+if asked, she had to tell Mr. Epstein that she
+•was eighteen years old. The friend was
+nineteen years old and
+_looked old for her age, so passing for eighteen was not a problem. At
+
+5
+
+
+the home Ms.
+met Mr. Epstein and later gave him a massage. The friend had told Ms.
+to give the message topless. Mr. Epstein told
+that if she were at all uncomfortable being
+topless, not to do it and it was not a requirement of employment as a masseuse. Ms.
+I never
+touched Mr. Epstein in a sexual way and Mr. Epstein never touched Ms.
+at all. At one point,
+Mr. Epstein did ask Ms.
+her age. Ms.
+insisted that she was eighteen years old
+Ms.
+continued to see Mr. Epstein over time and massages were given in a similar fashion.
+She was later asked if her friends wanted to work in a similar way and she asked some girls who did
+give Mr. Epstein massages. Ms.
+was never asked to bring girls of any age to Mr. Epstein's
+home. When she did have her friends come over, she instructed all of them that if asked, they insist
+that they were eighteen years old. She is not certain at all of any of these girls' real ages.
+In summary, our concern is that if the government believes that Mr. Epstein committed some federal
+offense, then Ms.
+could he considered a co-conspirator. We believe no crime was committed.
+The Fifth Amendment was not intended to protect the guilty, however. It was enacted to protect
+citizens who fear prosecution notwithstanding their innocence. Our fear of any prosecution,
+especially
+in lightof the Town police chief's public remarks, is clearly in good faith.
+
+
+NORTHERN (WEST PALM BEACH) DIVISION
+FGJ 07-103(WPB)
+3.0.
+IN RE:
+GRAND JURY PROCEEDINGS
+2007 APR 16 PM 2:15
+FILED BY...
+SEALED ORDER
+On Application of the United States Attorney for the Southern District of Florida, and it
+appearing to the satisfaction of the Court:
+1.
+That
+has been called to testify and to provide other information before
+the United States District Court for the Southern District of Florida, including a Grand Jury
+impanelled therein; and
+That in the judgment of the said United States Attorney,
+has refused
+to testify and provide other information on the basis of her privilege against self-incrimination; and
+3.
+information from
+That in the judgment of the said United States Attorney, the testimony and other
+may be necessary to the public interest; and
+4.
+That the aforesaid Application has been made with the approval of the Assistant
+Attorney General in charge of the Criminal Division of the Department of Justice or a duly
+designated Acting Assistant Attorney General, pursuant to the authority vested in him by Title 18,
+United States Code, Section 6003, and Title 28, Code of Federal Regulations, Sections 0.175 and
+0.132(e).
+that
+NOW, THEREFORE, it is ordered pursuant to Title 18, United States Code, Section 6002,
+give testimony and provide other information which she refuses to give or to
+I VERNMENT
+
+6
+
+
+provide on the basis of her privilege against self-incrimination, as to all matters about which she may
+be interrogated before said United States District Court, including a Grand Jury impaneled therein,
+as well as any subsequent proceeding or trial.
+However, no testimony or other information compelled under this Order (or any information
+directly or indirectly derived from such testimony or other information) may be used against
+in any criminal case, except a prosecution for perjury, giving a false statement, or otherwise
+failing to comply with this Order.
+IT IS FURTHER ORDERED the this Order shall be SEALED in accordance with Fed.
+R. Crim. P. 6(e)(б), except that a copy of this Order shall be provided to counsel for the United
+States, who may disclose the existence of the Order to members of the Grand Jury, to the witness,
+to counsel for the witness, and to law enforcement officers engaged in the investigation pending
+before the Grand Jury. Those persons may review the Order, but may not retain a copy of the Order,
+nor may they disclose the existence of the Order to any others.
+DONE and ORDERED this 16
+day of April, 2007, at West Palm Beach, Florida.
+DONALD M. MIDDLEBROOKS
+UNITED STATES DISTRICT JUDGE
+CC:
+AUSA
+2
+
+
+500 S. Australian Ave, Ste 400
+West Palm Beach, FL 33401
+December 13, 2007
+DELIVERY BY ELECTRONIC MAIL
+Jay P. Lefkowitz, Esq.
+Kirkland & Ellis LLP
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4675
+Re: Jeffrey Epstein
+Dear Jay:
+I am writing not to respond to your asserted "policy concerns" regarding Mr. Epstein's Non-
+Prosecution Agreement, which will be addressed by the United States Attorney, but the time has
+come for me to respond to the ever-increasing attacks on my role in the investigation and
+negotiations.
+It is an understatement to say that I am surprised by your allegations regarding my role
+because I thought that we had worked very well together in resolving this dispute. I also am
+surprised because I feel that I bent over backwards to keep in mind the effect that the agreement
+would have on Mr. Epstein and to make sure that you (and he) understood the repercussions of the
+agreement. For example, I brought to your attention that one potential plea could result in no gain
+time for your client; I corrected one of your calculations of the Sentencing Guidelines that would
+have resulted in Mr. Epstein spending far more time in prison than you projected; I contacted the
+Bureau of Prisons to see whether Mr. Epstein would be eligible for the prison camp that you desired;
+and I told you my suspicions about the source of the press "leak" and suggested ways to avoid the
+press. Importantly, I continued to work with you in a professional manner even after I learned that
+you had been proceeding in bad faith for several weeks - thinking that I had incorrectly concluded
+that solicitation of minors to engage in prostitution was a registrable offense and that you would
+"fool" our Office into letting Mr. Epstein plead to a non-registrable offense. Even now, when it is
+clear that neither you nor your client ever intended to abide by the terms of the agreement that he
+signed, I have never alleged misconduct on your part.
+The first allegation that you raise is that I "assiduously" hid from you the fact that Bert
+Ocariz is a friend of my boyfriend and that I have a "longstanding relationship" with Mr. Ocariz.
+
+7
+
+
+
+I informed you that I selected Mr. Ocariz because he was a friend and classmate of two people
+whom I respected, and that I had never met or spoken with Mr. Ocariz prior to contacting him about
+this case. All of those facts are true. I still have never met Mr. Ocariz, and, at the time that he and
+I spoke about this case, he did not know about my relationship with his friend. You suggest that I
+should have explicitly informed you that one of the referrals came from my "boyfriend" rather than
+simply a "friend," which is the term I used, but it is not my nature to discuss my personal
+relationships with opposing counsel. Your attacks on me and on the victims establish why I wanted
+to find someone whom I could trust with safeguarding the victims' best interests in the face of
+intense pressure from an unlimited number of highly skilled and well paid attorneys. Mr. Ocariz
+was that person.
+One of your letters suggests a business relationship between Mr. Ocariz and my boyfriend.
+This is patently untrue and neither my boyfriend nor I would have received any financial benefit
+from Mr. Ocariz's appointment. Furthermore, after Mr. Ocariz learned more about Mr. Epstein's
+actions (as described below), he expressed a willingness to handle the case pro bono, with no
+financial benefit even to himself. Furthermore, you were given several other options to choose from,
+including the Podhurst firm, which was later selected by Judge Davis. You rejected those other
+options.
+You also allege that I improperly disclosed information about the case to Mr. Ocariz. I
+provided Mr. Ocariz with a bare bones summary of the agreement's terms related to his appointment
+to help him decide whether the case was something he and his firm would be willing to undertake.
+I did not provide Mr. Ocariz with facts related to the investigation because they were confidential
+and instead recommended that he "Google" Mr. Epstein's name for background information. When
+Mr. Ocariz asked for additional information to assist his firm in addressing conflicts issues, I
+forwarded those questions to you, and you raised objections for the first time. I did not share any
+further information about Mr. Epstein or the case. Since Mr. Ocariz had been told that you
+concurred in his selection, out of professional courtesy, I informed Mr. Ocariz of the Office's
+decision to use a Special Master to make the selection and told him that the Office had made contact
+with Judge Davis. We have had no further contact since then and I have never had contact with
+Judge Davis. I understand from you that Mr. Ocariz contacted Judge Davis. You criticize his
+decision to do so, yet you feel that you and your co-counsel were entitled to contact Judge Davis to
+try to "lobby" him to select someone to your liking, despite the fact that the Non-Prosecution
+Agreement vested the Office with the exclusive right to select the attorney representative.
+Another reason for my surprise about your allegations regarding misconduct related to the
+Section 2255 litigation is your earlier desire to have me perform the role of "facilitator" to convince
+the victims that the lawyer representative was selected by the Office to represent their interests alone
+and that the out-of-court settlement of their claims was in their best interests. You now state that
+doing the same things that you had asked me to do earlier is improper meddling in civil litigation.
+Much of your letter reiterates the challenges to Detective Recarey's investigation that have
+
+
+
+already been submitted to the Office on several occasions and you suggest that I have kept that
+information from those who reviewed the proposed indictment package. Contrary to your
+suggestion, those submissions were attached to and incorporated in the proposed indictment
+package, so your suggestion that I tried to hide something from the reviewers is false. I also take
+issue with the duplicity of stating that we must accept as true those parts of the Recarey reports and
+witness statements that you like and we must accept as false those parts that you do not like. You
+and your co-counsel also impressed upon me from the beginning the need to undertake an
+independent investigation. It seems inappropriate now to complain because our independent
+investigation uncovered facts that are unfavorable to your client.
+You complain that I "forced" your client and the State Attorney's Office to proceed on
+charges that they do not believe in, yet you do not want our Office to inform the State Attorney's
+Office of facts that support the additional charge nor do you want any of the victims of that charge
+to contact Ms.
+or the Court. Ms.
+Is opinion may change if she knows the full
+scope of your client's actions. You and I spent several weeks trying to identify and put together a
+plea to federal charges that your client was willing to accept. Yet your letter now accuses me of
+"manufacturing" charges of obstruction of justice, making obscene phone calls, and violating child
+privacy laws. When Mr.
+told you that those charges would "embarrass the Office," he meant
+that the Office was unwilling to bend the facts to satisfy Mr. Epstein's desired prison sentence - a
+statement with which I agree.
+I hope that you understand how your accusations that I imposed "ultimatums" and "forced"
+you and your client to agree to unconscionable contract terms cannot square with the true facts of
+this case. As explained in letters from Messrs.
+Jan
+the indictment was postponed
+for more than five months to allow you and Mr. Epstein's other attorneys to make presentations to
+the Office to convince the Office not to prosecute. Those presentations were unsuccessful. As you
+mention in your letter, I -a simple line AUSA - handled the primary negotiations for the Office, and
+conducted those negotiations with you, Ms. Sanchez, Mr. Lewis, and a host of other highly skilled
+and experienced practitioners. As you put it, your group has a "combined 250 years experience" to
+my fourteen. The agreement itself was signed by Mr. Epstein, Ms. Sanchez, and Mr. Lefcourt,
+whose experience speaks for itself. You and I spent hours negotiating the terms, including when to
+use "a" versus "the" and other minutiae. When you and I could not reach agreement, you repeatedly
+went over my head, involving Messrs.
+In the negotiations at
+various times. In any and all plea negotiations the defendant understands that his options are to
+plead or to continue with the investigation and proceed to trial. Those were the same options that
+were proposed to Mr. Epstein, and they are not "persecution or intimidation tactics." Mr. Epstein
+chose to sign the agreement with the advice of a multitude of extremely noteworthy counsel.
+You also make much of the fact that the names of the victims were not released to Mr.
+Epstein prior to signing the Agreement. You never asked for such a term. During an earlier
+meeting, where Mr. Black was present, he raised the concern that you now voice. Mr. Black and
+I did not have a chance to discuss the issue, but I had already conceived of a way to resolve that
+
+
+
+issue if it were raised during negotiations. As I stated, it was not, leading me to believe that it was
+not a matter of concern to the defense. Since the signing of the Non-Prosecution Agreement, the
+agents and I have vetted the list of victims more than once. In one instance, we decided to remove
+a name because, although the minor victim was touched inappropriately by Mr. Epstein, we decided
+that the link to a payment was insufficient to call it "prostitution." I have always remained open to
+a challenge to the list, so your suggestion that Mr. Epstein was forced to write a blank check is
+simply unfounded.
+Your last set of allegations relates to the investigation of the matter. For instance, you claim
+that some of the victims were informed of their right to collect damages prior to a thorough
+investigation of their allegations against Mr. Epstein. This also is false. None of the victims was
+informed of the right to sue under Section 2255 prior to the investigation of the claims. Three
+victims were notified shortly after the signing of the Non-Prosecution Agreement of the general
+terms of that Agreement.
+You raised objections to any victim notification, and no further
+notifications were done. Throughout this process you have seen that I have prepared this case as
+though it would proceed to trial. Notifying the witnesses of the possibility of damages claims prior
+to concluding the matter by plea or trial would only undermine my case. If my reassurances are
+insufficient, the fact that not a single victim has threatened to sue Mr. Epstein should assure you of
+the integrity of the investigation.'
+"There are numerous other unfounded allegations in your letter about document demands,
+the money laundering investigation, contacting potential witnesses, speaking with the press, and the
+like. For the most part, these allegations have been raised and disproven earlier and need not be
+readdressed. However, with respect to the subpoena served upon the private investigator, contrary
+to your assertion, and as your co-counsel has already been told, I did consult with the Justice
+Department prior to issuing the subpoena and I was told that because I was not subpoenaing an
+attorney's office or an office physically located within an attorney's office, and because the business
+did private investigation work for individuals (rather than working exclusively for Mr. Black), I
+could issue a grand jury subpoena in the normal course, which is what I did. I also did not
+"threaten" the State Attorney's Office with a grand jury subpoena, as the correspondence with their
+grand jury coordinator makes perfectly clear.
+With regard to your allegation of my filing the Palm Beach Police Department's probable
+cause affidavit "with the court knowing that the public could access it," I do not know to what you
+are referring. All documents related to the grand jury investigation have been filed under seal, and
+the Palm Beach Police Department's probable cause affidavit has never been filed with the Court.
+If, in fact, you are referring to the Ex Parte Declaration of Joseph Recarey that was filed in response
+to the motion to quash the grand jury subpoena, it was filed both under seal and ex parte, so no one
+should have access to it except the Court and myself. Those documents are still in the Court file
+only because you have violated one of the terms of the Agreement by failing to "withdraw
+[Epstein's] pending motion to intervene and to quash certain grand jury subpoenas."
+
+
+JAY P. LEFKOWITZ., ESQ.
+
+With respect to Ms.
+_ I contacted her attorney - who was paid for by Mr. Epstein and
+was directed by counsel for Mr. Epstein to demand immunity - and asked only whether he still
+represented Ms.
+_and if he wanted me to send the victim notification letter to him. He asked
+what the letter would say and I told him that the letter would be forthcoming in about a week and
+that I could not provide him with the terms. With respect to Ms.
+status as a victim, you
+again want us to accept as true only facts that are beneficial to your client and to reject as false
+anything detrimental to him. Ms. |
+made a number of statements that are contradicted by
+documentary evidence and a review of her recorded statement shows her lack of credibility with
+respect to a number of statements. Based upon all of the evidence collected, Ms.
+is classified
+as a victim as defined by statute. Of course, that does not mean that Ms.
+a victim or that she would seek damages from Mr. Epstein. I believe that a number of the identified
+victims will not seek damages, but that does not negate their legal status as victims.
+I hope that you now understand that your accusations against myself and the agents are
+unfounded. In the future, I recommend that you address your accusations to me so that I can correct
+any misunderstandings before you make false allegations to others in the Department. I hope that
+we can move forward with a professional resolution of this matter, whether that be by your client's
+By:
+You also accuse me of "broaden[ing] the scope of the investigation without any foundation
+for doing so by adding charges of money laundering and violations of a money transmitting business
+to the investigation." Again, I consulted with the Justice Department's Money Laundering Section
+about my analysis before expanding that scope. The duty attorney agreed with my analysis.
+
+
+Case 9:08-cv-80736-KAM Document 304-1 Entered on FLSD Docket 01/30/2015 Page 1 of 3
+CASE NO. 08-80736-CIV-MARRA
+Petitioners,
+VS.
+UNITED STATES OF AMERICA,
+Respondent.
+DECLARATION OF FBI SPECIAL AGENT
+declares as follows:
+1. 1 am a Special Agent, Federal Bureau of Investigation (FBI), currently assigned as a
+Section Chief at FBI Headquarters, Washington, D.C. I was appointed a Special Agent in May
+1999. Upon graduation from the FBI Academy at Quantico, Virginia, in September 1999, I was
+assigned to the Detroit Field Office. I was subsequently transferred to the FBI Miami Field
+Office in May 2006.
+2. In 2006, I was assigned to work on an investigation of Jeffrey Epstein, who was
+accused of sexually abusing many young girls under the age of 18. In the course of our
+investigation, the FBI identified many potential victims of sexual abuse by Epstein. We obtained
+names by speaking to other victims, who frequently knew of friends who had also been paid
+money by Epstein to provide sexual services to him.
+3. One of the victims identified was
+In January - February 2007, 1
+used various computer indices to try and locate Ms.
+By using these indices and other
+means, I found two international phone numbers which I believed were being used by Ms.
+Case T
+
+8
+
+
+Case 9:08-cv-80736-KAM Document 304-1 Entered on FLSD Docket 01/30/2015 Page 2 of 3
+4. Sometime during January - February 2007, I called the one of the numbers, in an
+attempt to speak to Ms.
+Also in my office was FBI Special Agent
+the Icad agent for the investigation of Jeffrey Epstein. I was not using a
+speakerphone when I spoke with Ms.
+I asked S/A
+to be present because
+she, as the lead agent, was thoroughly versed in the details of the entire investigation, and I might
+need her assistance to respond to a question posed by Ms.
+that I was unable to answer.
+5. When I dialed the number, a young woman answered the phone. I told her my name,
+identified myself as a Special Agent with the FBI, and asked if she was
+She
+said yes. I used a technique which I employ when speaking to people on the phone, who might
+question whether I am truly an FBI agent. I provided her with the phone number of the FBI
+Field Office in Miami, Florida, and told her she could hang up and verify the number. She
+could then call me back at the number, and her call would be routed to me. Ms.
+said that
+would not be necessary.
+6. I told Ms.
+about our investigation of Jeffrey Epstein, and the allegations that
+Epstein had sexually abused many underage young girls. I told her we believed she might be a
+victim of sexual abuse by Epstein.
+7. Ms.
+answered basic questions, telling me that she did know Jeffrey Epstein.
+She quickly became uncomfortable, telling me she moved away to distance herself from this
+situation, and expressing her desire to "let this be in my past." She asked that I not bother her
+with this again.
+8. I thanked Ms.
+and told her 1 appreciated her time. I provided my name and
+encouraged her to call the FBI Miami Field Office, if she had any questions or needed assistance.
+2
+Case No. 08-80736 CM-MABID
+
+
+Case 9:08-CV-80736-KAM Document 304-1 Entered on FLSD Docket 01/30/2015 Page 3 of 3
+The entire phone conversation only last several minutes.
+9. I did not hear from Ms.
+again. In mid-March 2007, I reported for my new
+assignment at FBI Headquarters in Washington, D.C.
+10. I declare under penalty of perjury that the foregoing is true and correct.
+Executed on January 26, 2015.
+Section Chief
+Washington, D.C.
+3
+Govt Exhibit D
+
+
+
+Je
+sor & Associates
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIBCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CASE NO, 2006 C/09454AXX
+STATE OF FLORIDA,
+-·B-
+JERTREY EPSTEIN,
+Defendant -
+DEPOSITION OF
+Medneaday, February 20, 2008
+2:00 p.m. - 4:30 p.n.
+Pain Beach County Courthoare
+205 North Dixie Highway
+Weat Palm Beach, Florida 33401
+copy
+Reported By:
+Judith E. Consor, FPR
+Notary Public, State of Plorida
+Consor & Associates Raporting and Transcription
+Phone -
+• Fax
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+฿
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ansor & Associates
+Dependog and Batsovipine, M
+Page 2
+ВЕРБАНИВО!
+bobalf of the stater
+11. ESQ-
+ANSISTANT STATE ATTORNEY
+401 North Dixie Highway
+Best Palm Beach, Florida 33401
+On behalf of the Defendant:
+MICHAEL. R. TEIN, ESQ.
+KNIHRYN A. METERS, E30-
+LENIS TEIN, PL
+3059 GRAND AVENUE, SUITE 349
+COCONUT GROVE, EL. 33133
+On behalf of the Defendant:
+JACK A. GOLDBERGER, ESQ.
+AFTERBURY, GOLDRERGER & WEISS
+250 AUSTRALIAS AVENUE S00TH
+SUITE 1400
+WEST PALM BEAN, FLORIDA 33401
+ALSO PRESENT:
+ON BEHALF OF THE WITNESS:
+THEODORE J. IDOPOLD, ESQ.
+KEITH J. BRETT, DIRECTOR GE HULTIMIDIA DEVISION,
+LEGAL-EXE
+- Fax. MB.682.1771
+1655 Pain Beach Lakes Bivd, Suite 500 - West Palm Beach, FL 33401
+isor & Associates
+INDEX
+HE LOO
+DIRECT EXAMINATION
+BY MR.
+TEIN:
+NOEXHIBIIS
+MARKED
+Page
+CERTIFIED QUESTIONS..
+Line
+22
+111
+112
+Page 3
+10
+11
+12
+13
+14
+15
+17
+18
+19
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Ph.|
+1655 Palm Beach Lakes Bld., Suite 500-
+Vest. Palm Beach, FL 33401
+Page 4
+Deposition taken before Judith F. Consor,
+Court Reporter and Notary Public in and for the State of
+Florida at Large. in the above cause.
+Thereapon,
+having been first duly sworn or affirmed, was examined
+and testified as follows:
+THE MITNESS:
+I do.
+DIRECT EXAMINATION
+BY NR. TEIN:
+Good afternoon.
+Please tell mn your tull
+And can you please spell it.
+Thank you-
+May I call you
+0.
+I'a going to ask you a few
+questlens,
+several questions today.
+It at any tine you
+want to take a break, you just let me know, Okay?
+A.
+Okay.
+0-
+It you at any time don't understand one of
+1= fax.
+1655 Pain: Beach Lakes Bivd., Suite 500 - West
+PENGAD 800-631-6984
+
+9
+
+
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Entered on FLSD Docket 06/30/2008 Page 3 of 35
+Reposing and Tonamigon, to
+Page 3
+my questions, will you just please let no know?
+Yes.
+0.
+And iE at any time you're not feeling well
+or sonathing Aske that, you'll tell un, right?
+A.
+Yes.
+Do you feel okay today?
+A.
+Yes-
+Iike that, right?
+A.
+No.
+Bot taking any alcohol or drugs or anything
+So you feel ready to hame your deposition
+takenT
+A.
+Yes.
+what is your address?
+A.
+I's curzently Jiving at my aunt's house and
+I don't know It off the top of my head.
+Where La it?
+In Jopiter.
+Who is your aunt?
+A.
+who else is living there?
+my unca.
+Anyone else living there?
+ND.
+The contesps motion that yeur nother flled
+I - Fax.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 6
+against your father regarding your fifty million-dollar
+lawsuit against Jeffrey Epstein says that you live with
+your aunt and uncle and have been living there: da that
+A.
+Yes.
+0-
+aunt and uncle?
+A-
+Q-
+How Jeng have you been living with your
+Since my father kicked an out.
+That was Thankagiving of this past year?
+793, 311.
+Okay. Didn't your firefighter boyfelend
+got an apartment for the two of you?
+No, sir.
+He has an aparteent, but by
+himselt.
+0.
+to live in?
+A.
+Did he çat an apartment for the two of you
+No, міг-
+Are you planning to nove In with him?
+Haybe one day in the future-
+Do you save a plan to some is with him
+0.
+presently?
+No.
+Have you been to the apartment that you and
+have discussed moving in together?
+I have been to the apartment.
+1.682.0905 - Fax.
+1655 Palm Beach Lakes Bivd., Suite 500 -
+West Palm Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+morT Associates
+Марата н Turrin
+Page 7
+9.
+Where is that?
+Palm Beach Laxes.
+Have you spent the night ever there?
+No, sir-
+Do you know the address there?
+I do not.
+Isn't your slater
+planning on living
+with you and
+you know that this court case 1a a
+criminal prosecution, correct?
+A.
+Correct.
+0. And you know that it's a crinisal
+pessecution againat a man sho has no erininal background.
+Do you know that?
+I do now.
+you agree that court is a very serious
+matter?
+Yea.
+And you're here with your lawyer
+Me. leopold, right?
+A.
+Yes.
+0.
+And you know that Hi. Leopold recently
+tiled a lausult in federal court againat Jeffrey Epatein,
+seeking fifty sillien dollars.
+I - Fax.
+1655 Palm Beach Lakes Bvd., Suite 500 - West Palm Beach, FL 33401
+10
+11
+12
+13
+14
+15
+15
+17
+18
+19
+20
+21
+22
+23
+24
+25
+sor Associates
+Reparing and Tue
+Page 8
+HR. LEOPOLD: Let me Just object.
+let an instrect you.
+Anything that
+you have learted through conversations between you
+and ne are protected. So If you know any of chat
+intornation autaide of those discussions, you may
+азамег. Bue If the only way you know It is
+through our discussions, do cot answer that
+qutation-
+BY MR. TEIN:
+0.
+you know that ME. Leopold recently
+Ellad a Javsult in federal court on your behalf against
+Jeffrey Epstein seeking fifty million dollars?
+MA. LEOPOLD Sane objection.
+If you know the ansuer to that outside of
+our discussions, you way anaver. If it in the
+only way that you know the ansuer la through our
+discuasions, do not ansver that question.
+MR. LEOPOLD: Actormy/client privilege.
+TEEN:
+You can ansuer the questióa unless -
+MA. LEOPOLD: Sane objeetion.
+MA. TEIN: Let no finish.
+NR. TEIN: No. Let ne finish.
+1655 Palm Beach Lakes Bivd., Suite 500-
+sim Beach, FL 33401
+
+
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Sagariag and Tussaigime, Ini
+Entered on FLSD Docket 06/30/2008 Page 4 of 35
+ansor & Associates
+Kapering and Transpise, les
+Page 9
+HR. IEOPOLD: Levis, ue're not going to de
+that.
+MR. TRIN: My hane 1s not Lawis-
+I'= going to finish my queation. Okayz
+MR. LOPOLD: Do not answer until you hear
+tron ne. i
+BY HA. TEIH:
+Other than conversations thas you have had
+with Mr. Leopold -- I'm not aaking about that -- are you
+ware that Mr. Leopold has filed a lavault in federal
+court seeking fifty million dollars from Jeffrey Epacein
+on your behalt?
+MR. LEOPOLD: Sane objection.
+Anything that you learn through
+conversations between you and no, do not ansunr.
+Those are protected. If you know through any
+other reals of knowledge, you may answer.
+THE WISHESSI NO.
+BY ME. TEIN:
+You hara no Idas thas Mr. Leopold filed a
+tirty million-dollar lawsult on your behalf against
+Saffrey Epstein?
+MR. LEOPOLD: Same objection.
+Do not answee that question If it's through
+discassions that you and I had.
+Outside of that,
+Page 10
+you nay answer. So do not anover that question 1E
+that is the only basis by which you underatand
+that answer-
+THE WITNESS: No.
+HT. TEA
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+You didn't know that?
+MR. LEOPOLD: Don't anauer that question.
+Again, 1E's attorney/client privilege. Any
+infersation you've learned through conversations
+between you and I are protectad. If you keen it
+through any other realm, you say anaver.
+MA. TEIN: Are you going to say that tor
+every question in the deposition, Mr. leopold?
+Ma. L20P0101 When you ask improper
+questions like that without the peoper --
+MR. TEIN: You're going to stop your
+apeaking objections right now, Okay?
+MR. IROPOLD: Without the proper --
+MR. TEIN: Yeu need to stop your speaking
+abjections.
+22
+23
+24
+25
+Let's continue.
+HA. LEOPOLD: Counsel, you Just asked me a
+question and I'a going to state it on the
+record --
+MR. TEIN:
+Tou need to stop your speaking
+U
+PhL.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+Ph. :
+- Fax. 11
+1655 Pain Beach Lakes Bivd, Suite 500 - West Palm Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Sisor tArsociates
+Page 11
+objections. Check your roles.
+MR. IROPOLD: Excuse me. Foc the record,
+Counsel asted ne a question. I'1l state che
+ansver on the record. He asted no the question de
+I going to be answering that way throughout the
+deposition,
+So long as there's inproper
+foundation and predicate asked by the attornay. 1
+will protect my ellent and i nake the record where
+appropriate. If counsel wishes to ask an
+appropriate worded queation with the proper
+foundacion and predicate, I will certainly allow
+the client to answer the question.
+MA. GOLDBERGER: Why don't ysu just state
+atterney/client privilege and juat be done with
+ItT
+NB. LEOPOLD: I want the record to be
+clear.
+Ma. SEIN: You vant to vaste time is what
+you want to do.
+Tou weze sapposed to be here this morning
+and you totally broke the deal, the agceezent that
+you had with us 1f your hearing goe cancelled.
+Sut let's move en and maybe you'll stop
+obstructing this deposition.
+MR. LOPOLD: I think the record is very
+I - Fax.
+1655 Palm Beach Lakes Bivd, Suite 500 - West Paim Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+міну ної Тинатрію, і
+Page 12
+elear where vt stand thus far-
+Is there a recording taken of thin
+deposition?
+THE COORT REPORTER: Tes.
+HI. LEOPOLD: Just make sure that's
+presetved.
+ST-MR.
+Go to Exhibit 20-03 - vall, before you do
+are you aware that & lavyar naned Jeffrey
+Hernan filed • Javsuit on your behalf, you or no?
+KA. EROPOLD: Objestion.
+Any coversations that you and I have had
+regarding, that, If that is the only way by which
+you understand how to anaves that question, do not
+ansver. It's attorney/ellent privilege, as well
+as any conversations you say have had with the
+attorney fron Kland. That 1s also attorney/client
+privilege. And I'm assuming "
+MR, TEIN: You're actually wrong about the
+attorney/client privilege.
+MR. LEOPOLD: 1'm assusing Counsel is not.
+asking you to divulge attorney/ellent t-
+MA. TRIM: OF COUTRE NOt-
+are you avace that Jeffrey Barsan,
+ILL 682.0905 - Fax.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+
+
+- Case 9:08-cv-80119-KAM Document 15-2
+
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+U
+25
+ensor & Associates
+ansor & Associates
+Page 13
+an attorney, Illed a fifty million-dollar laurale on your
+behalf against jeffrey Epstein, yes or not
+MA. LEOPOLD: Sase objection.
+NR. TETN: Ne've heard the objectlen 10
+times already.
+HR. LROPOLD: Counsel, excuse me.
+MR. TEIN: Just say attorney/ellent
+privilege. Stop interrupting dy questions.
+MR. LEOPOLD: 1'm enticied to make an
+objection for the record, which I'n doing. and
+I'll sake the same objection.
+And It it calls for
+attorney/ellent pelvilege, any conversations you
+and I have had, do not ansuer the question.
+And I think that is might be appropriate.
+for the record, to ask questions via
+an opposed to
+would be sore apprepriate for this deposition.
+BY HA. TEIN:
+0.
+Go abead.
+Please ansver yes or no.
+Thank you.
+In tact, you know chae Kr. Herman held a
+press conference after he filed the Esfty-ail1100-00218E
+lausadt on your behalf, don't you?
+After it happaned
+1655 Palm Beach Lakes Bivd., Sulte 500 - West Palm Beach, FL 33401
+9
+10
+11
+12
+13
+14
+15
+16
+17
+10
+19
+20
+21
+22
+23
+24
+25
+Pago 14
+You know that he had a press conference,
+don't you, yes or no?
+Yes.
+0. Is fact, let's go to Exhibit 20-01.
+MR. GOLDBERGER: Look behind you. You"ll
+see it.
+Have you aver seth that picture before?
+A.
+Yes-
+Is that a picture of your father, your
+stopesther and Mr. Herman at the press conference
+sagaeding youe lansult?
+A.
+Yes.
+Now you know that this in a very serious
+natter, don't you?
+MA. LEOPOLD: Aaked and answered.
+Objection.
+MR. GOLDBERGER: A11 right. You can
+object. You're representing a witness here,
+Mr. Leopold. You can object on privilege grousts.
+You cannot make leçal objectlons. You have no
+standing to do a0.
+HM. LEOPOLD: I'a going to nake then and
+then +-
+COLDERRORA: We're --
+- Far
+1655 Palm Beach Laies Blvd., Suite 500 - West Palm Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Варкіна мі Turipas,
+Page 15
+HA. LEOPOLD: Me're going to leave or ue"re
+going to cake a break, because his demeanor do not
+appropriate.
+There's no reason to here this kind
+at deneance. If you want to dave this kind of
+demeanor with he "-
+Mn. TEIN: You are obatructing this
+depositionwhy don't you quys go
+cutside and just talk about --
+MR. 1EDPOLD: She -- her job is very
+difficult and she's not going to be able to take
+us both talking at the same time
+KA. GOLDBENGER: Off the record.
+MA. LEOPOLD: We're not going off the
+record, Jack. Me're not, Jack.
+Her Job is very
+difficult. I'm poing to make the record-
+I don't think it is appropriate, especially
+in the anall confines of this roos, to be very
+aggressive with this young lady.
+NB. TEEN: That's not happening. Stop,
+stop actually -
+MR. LEOPOLD: If you're going to interrupt
+se, va'ra going to cancel this deponition -
+MR. TEEN: Stop sistepresenting-
+THAT UTTERe
+I seed one at a cine,
+1 - Fax
+1655 Palm Beach Lakes Blvd, Suite 500 - West Palm Beach, FL. 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Ensor & Associates
+Reposing and Tur
+Page 16
+MR. LEOPOLD: 1 think we're going to take a
+break. Perhapa you sight want to talk to your
+co-counsel --
+MR. TEIN: I don't need to talk to him.
+MA. LEOPOLD:
+But un're going to tate a
+MR. TEIN: Me're not taking a break unless
+the witness seeds a break-
+Tou're obatructing this deposition, Ted.
+Ma. LEOPOLD: Cone en,
+You all want to continue in this
+densor ..
+MN. TEIN: Tou're obstructing the
+deposition.
+Stop saking speeches. We're Bot
+discuaming this with you. The questions are to
+your client. Oo take your five-ainute break.
+MR. LEOPOLD: Fine.
+Ke need to make sure
+the record's elear and clean.
+And I want to make sure, as I've already
+anbad you -- I know that you"re one of the beat in
+Down - that this wedlo «- this moda to be
+preserved, Okay?
+ISR. TEIN: Go take your five-ainute break,
+Mr. Leopold, now.
+1655 Palm Beach Lakes Bivd, Suite 500 - West Palm Beach, FL. 33401
+
+
+annie and Tae
+)
+Page 17
+Tou vare supposed co be here at nine
+it's now after tuo. Take your break and come
+back.
+HM. LEOPOD:
+Okay.
+If the demeator keeps
+up, we will not be here beyond those five minutes.
+NR. TEEN: Take your beeak and come back.
+HA. LEOPOLDI
+Okay.
+So I suggest that you
+NR. TEIM: I suggest that you take your
+10
+11
+12
+13
+14
+break.
+MR. GOLDBENGER: Let them take that
+Ilve-minute break.
+MA. LEOPOLD: But I would suggest that you
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+take deep breaths.
+tabe a breas.
+MR. TEIN: Suggeat whatever you want, Go
+(Thereupon, • recass was taken.)
+BT MR. TEIN:
+2.
+you agree that giving ceacimony
+today at your depsaition in something very sarlous, don't
+you7
+A.
+Yes-
+Yes-
+And you respect the court, don't you?
+Let me show you Exhibit 31-091. Can you
+1655 Palm Beach Li
+.682.0905.- Fax.
+is Bivd, Sulte 500
+ach, FL 33401
+
+10
+11
+12
+19
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 10
+read that out loud, please.
+Okay. What do you want?
+will you read that out loud, please.
+A.
+Oh.
+Q-
+Thank you.
+A.
+lol hah my baddd.. 1a1 yah i got some
+stupid court shit on the 20th.. bullshit... and damn you
+still have court shit with him? like after so long wou
+im sorey... well yah well we will detinitely harta sake
+plans for sure. .because i adas a tona times a million and
+no no no i love yna...o and p.s. i love at default plo
+niggas. Huah xo.
+Did you send that message last week to a
+Erland of yours on Hypace?
+I woulds'E know. Thece's no dates and I've
+deleted thas HySpace, s0 -
+0.
+A.
+We're going to talk wbout that in a second.
+Okay.
+0.
+A.
+0.
+Did you pend that message last week -
+Right.
+Let se finiah ay question.
+Did you send that nessage last week to a
+felend of yoars on Ryspace?
+I wouldn't know the date, bet obvioualy.
+it's to a friend.
+1655 Palm Beach Lake
+Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 19
+Did you send that message to a friend of
+yours on MySpace?
+Sure, yes.
+9-
+A.
+Here you referring to this deposition?
+Yes.
+That's not anywere in there.
+What word did you use in there?
+MR. LEOPOLD: Where are you referring to,
+Courani? There's 20 plus vords in there.
+MR. TEIM: Con't make a speaking objestion.
+THE MITNESS! Are you referring to
+anything -
+MR. LEOPOLD: No.
+Don"t == don't ..
+let hin ask you the question.
+BY MR. TEIN:
+0.
+What question were you eaking.
+MR. LED/OLD: She doesn't ask questiona.
+You ask the questions. What la the question
+pending?
+BY NA. THIM:
+what Is the last vocd on there in
+the taxt of your message before the cloning?
+A.
+Nigged.
+Don't you find that tern oftensive?
+- Fax.
+1655 Paim Beach Lakes Bivd., Sulte 500 - West Palm Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 20
+A.
+No.
+MR. LEOPOLD: Can you spell it for the
+record, please.
+THE WITNESS: 3-1-g-9--
+MR. TEIN: No, no, so. tou are not going
+to be asking questiona.
+MB. LEOPOLD: I'm not asking questions.
+I'm asking for the record the word to be spelled,
+because we don't have a video here today.
+MR. TEIN: These exhibits are part of the
+record. You -
+MR. LEOPOLD: Well, it's not marked as an
+NA. TEIN: Stop interrupting me,
+Mr. Leopold. I bare marked and identified as an
+exhibit and you will get it.
+HR. LEOPOLD: There has been no
+Identification of this docusent in the incond.
+MR. TEIN: Mr. Leopold, stop interrupting
+this deposition.
+MR. IDOPOLD: What is the exhibit number
+marked for Identification?
+MR. TEIN: 31-001-
+MA. LEOPOLD: Do we have copies? Is it on
+the record anywhere?
+10905 - Fax.
+1655 Pain Beach Lakes Elvd., Suite 500 - West Palm Beach, FL 33401
+- -
+
+
+
+10
+11
+12
+13
+14
+15
+16
+17
+IB
+19
+20
+21
+22
+23
+24
+25
+Page 21
+Let an ast you,
+did you in fact
+write your friend this nessage about this duposition?
+Yes-
+So you wrote your friend that this
+deposition is stupid court a-h-i-t, correct?
+A.
+Tea.
+0.
+Because you chink this deposition in stupid
+court a-h-1-t, don"t yoa?
+A.
+No.
+0-
+You wrote that to your friend, didn't you?
+Yes.
+You think that court in stupid, don't you?
+A-
+In sose cases.
+And you think that court 1a bull s-it-l-t,
+don"t you?
+A.
+No.
+And you think this deposition is bull
+g-h-1-t, don't you?
+A.
+No.
+0.
+You wrote that to your friand, didn't you?
+MR. LEDFOLD: objection. Asked and
+anavered.
+MA. TEIR:. That's not an objection.
+BY MR. TEEN:
+1655 Palm Beach Lakes Evd,, Suite 500 - West Falm Besch, FL 33401
+opening Tremorigin, las
+...
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 22
+0-
+Yoo wrote that to your friend, didn't you?
+MA. LEOPOLD: Cbjection. Asked and
+ansuered, for the fourth tist.
+HR. TEEN: Yeu are inproperly objecting.
+Mr. Leopold. You have no growls to object.
+And
+that's not an objection.
+NX. LEOPOLD: It to an objection.
+HA. TEIN: Then terminate the depoastion it
+you think de's been asked and answered.
+MA. IBOPOLD: Counsel, I as sot precluded
+tron junt saking an objection to the form of the
+question. As the courta well know, and if you
+practice bese in lest Palm Beach, sany of the
+judges require you to set che objection with
+apolficity. And I will do that. And if you
+don't want ne to, you can make the record. But I/
+will do that.
+ня. TEIN: Here's what we'll do, Ted.
+cas - I will allow you to reserve an objection to
+form for every single one of my qastions.
+Otherwise, all you're doing is obstrecting.
+Ma. LEOPOLD:
+I won't do that-
+MA. TEIM: Of course: because you want to
+obstruet.
+LEOPOLDI
+All right.
+1655 Palm Beach Lak
+Suite 500
+cach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+sing and Transition, lea
+Page 23
+BY HA. TEIN:
+you think that giving testimong
+today, under oath, is bull a-h-i-t, don't you?
+A.
+No.
+And you wrote that to your fadend on
+Hyspace last weak, didn't you?
+MA. LEOPOLD: objection. Asked and
+answered.
+THE WITNESS:
+BY MR.
+0.
+A.
+you didn't write this exhibit?
+I Mrote that, but I didn't write what you
+Sandal
+You wrote in this e0l015905 0
+stupid court a-h-L-t on the 20th. Bull s-h-j-t." Didn't
+you vrite that?
+Yes.
+0. Referring to this deposition, didn't you?
+Referring to the court. I was later
+Infomed that It was a deposition.
+I'm going to ask you some questions now
+about what happened when you went to Jeft Epstein'a hopse
+three years ago.
+Okay?
+When the pollee intervieved you one nooth
+1655 Palm Beach Lakes Elvd, Suite 500 - West Palm Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ensor & Associates
+Page 24
+after you
+want to Epstein's house, you awore on your.
+nother'» grave chat you and Epstein did not engage in sex
+of any kind?
+Tes.
+Didn't you tell that to the polloe?
+And 1 will continue.
+I have never
+had sex with him.
+9.
+Eld what happened upstairs at Jett
+Epstein's house take you completely by surprise.
+Yes.
+Row the civil complaint that you Elled
+againat Hr. Epstein for Eitty zillion dollars alleged
+that you were tatally shocked by what happened when you
+got there.
+A.
+Tea.
+Here you totally shocked by what happened
+when you qut to Ipacein's house?
+A.
+You didn't expect 1t at all, did you?
+You had absolutely no Idea why your friend
+as taking you to Epstein's boass,
+right?
+I was Inforzed it was 4 massage.
+" All you thought that it was going to be was
+a massage, corEect?
+- Fax
+1655 Palm Beach Lakes Bivd, Suke 500 - Wesk Palm Beach, Fl. 33401
+
+
+J
+Case 9:08-cv-80119-KAM Document 15-2 , Entered on FLSD Docket 06/30/2008
+
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 25
+Yes-
+0.
+Before you got Lo Epstein's nouse
+never said anything to you on the telephose about sexual
+activity with Epstein, did she?
+Ho.
+And before you got to Epstein's house
+never sent ysu a massage over the Internet about
+sexonl activity with Epatoln, did she?
+NO-
+Did
+ever try to convince you to
+engage in any sexual activ!ty with Ipatein?
+A.
+Did
+every try to convince
+you to engage in any sexual activity with Epstein?
+A.
+I don't keow
+Do you have a frland
+Okay. Before you Hant so Epstein'a heuse
+did anyone call or e-pail you to induce you to engage in
+sexual activity with Epsteint
+A.
+No.
+0.
+So you'se sure that before you got to
+Epstein'a house no one tried to persuade you to engage in
+sexual activity with Jeftrey Ipatein?
+582.0905 - Fax.
+1655 Palm Beach Lakes Blvd, Suite 500 - West Palm Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Ensor & Associates
+Rapiering sad Tasuripian, les.
+Page 26
+Tou're sure that .. let ne ask the question
+You're sure that before you got to
+spatein's house no ana triad to persuade you to engage In
+sexual activity with Epstein for nosey. Are you?
+MA. LEOPOLD: Objection. Asked and
+asswered.
+THE WITNESS: No. And I've alceady
+anguered that a bazillion times.
+BY NA. TEIN:
+Sa'a douching you now. So I'm poing to ask
+the qoeatien -
+HA. LEOPOLD: Counsel, I've made an
+objection for the record.
+MR. TEIN: Stop speaking-
+HR. IEOPOLD: 1'm not going to stop
+speaking. Tou can't interropt ne when I'a saking
+the record.
+In. TEIN:
+You're coaching the witness.
+ME. 1EOPOLD: Counsel --
+MI. TEIN: Stop coaching the witness.
+DY HA. TEIN:
+let ne aak you --
+MR. LEOPOLD: If you continue to =-
+Stop interrupting my questions.
+Ph. 58
+-- Fax.
+1655 Palm Beach Lakes Bivd, Suite 500 - West Palm Beach, FL 33401
+10
+11
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+sor Associates
+Page 27
+MR. GEOPOLD:
+If you do it one nora time.
+no're leaving.
+0.
+I'a going to sake the record.
+You cassot interrupt se vhen I'm making che
+record.
+cut of profesalosal condict, you cannot
+do that.
+I's entitled to make the record.
+1 made
+an objection, asied and answered.
+Tour demeanor
+is inappropriate.
+Tou te willing and you are able
+and you're responsible to ask a question In a
+professional manner, and ask the question and once
+you get the ansver, to elther follow up on it or
+move of, but not continously broubeat and ask the
+sana questios over and over because you don't like
+MR. TEIN: Calm down, sir.
+NS. LeOPOLD: Trust no, I'm very caln here.
+When I's not calm, yoa"11 knew it. I'a very calm.
+So please continue on.
+But I will not
+allon you to cortinue to harass her in the
+desaanor that you're dolng. Ask has a question
+and move D.
+MA, TEIM: Are you done?
+HA. LEOPOLD:
+Thank you.
+I am.
+1655 Palm Beach Lakes Bld, Sulte 5CD - West Palm Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+U
+ánsor & Associates
+Page 28
+HA. TEIN: Stop misrepcesesting the record
+and calm down. I'a going to ask ay question.
+stop is.
+0.
+HA. LBOPOLD: I think the record is very
+cheat.
+Ma. GOLDBERGER: Let ne just elarity
+something.
+When you object to the form of a
+questlon, you're not inatructing the witness not
+to ensue: the question, are you?
+HR. LEOPOLD: No. And I'm not making that
+objection:
+only on attorsey/clint privilege.
+IX. TEIN: WIId you stop speaking now so I
+can ask ny question? Are you done?
+Okay-
+I'a going to ask ay questics.
+BY HE. TETH:
+Laten,
+HA. LBOFOLD:
+HOLd CO.
+stop.
+I've been dolng this fer 20 plus yoars and
+have net d l0c of attorneys, bat I've never bad an
+experience like this whace I've «-
+MR. TEIN: Stop your speechot.
+MR. LEOPOLD: If you continue to do this.
+whether it's with se or with my elient, I will not
+11 - Fax
+1655 Palm Besch Lakes Bivd.; Suite 500 - West Palm Beach, FL 33401
+
+
+ning a Transplan, les
+
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 29
+put up with le and I don't need to pus up with it
+and it's not appropriate. And I'm sure
+Mr. Goldberger knows all this, because I know that
+he waldn't do this. So 1 will not put up with
+it. And I think it's highly inappropriate to do
+this with thia child sitting here, the uny you're
+acting, primarily tovards se, and I will not put
+up with it.
+MR. TEIN: Mill you please stop your speech
+so I can ask questions?
+MR. LEOPOLD: So long as you act
+professionally, I will do so. But it you continue
+to do it this way, I will leare.
+MR. TEIN: Suit yourself.
+are you sare that before you got to
+Ipatela's house no one tried to persuade you co engage in
+serial activity with Ipatein for noray?
+MR. LEOPOLD: Maked and ansvered.
+objection-
+на. 181М:
+Did you get her anaver?
+THE COURT REPORTER:" lo, I did not.
+THE WITNESS: I'm ance.
+BY HI. TEIN:
+Let me ask you a teu questions about your
+- Fax.
+1655 Palm Beach Lakes Bivd, Suite 500 - West Paim Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ansor & Associates
+Sopening and Tourigine, Ser.
+Paçe 30
+contact with Jeffrey Spatein. Okay?
+(itness nods heat up and doen.)
+Jeff never e-mailed you, did he?
+A-
+No.
+Jeft never tast sensaged you, did be?
+No.
+Jeff never chatted in a chat coca with you,
+did het
+A.
+No.
+9.
+Before you got to Epstein's hoame you bad
+never spokes to Jaft, had you?
+A.
+No.
+And before you got to Epatein's house you
+bad cever net deft?
+A.
+Correct-
+Before you got to Epatein's house you had
+never told Jeff that you were under 19, right?
+A.
+No.
+0.
+Beloce you got to Epatein'a house had you
+ever told Jeffrey that you wece wader 187
+A.
+No.
+I never spoke to the man before that.
+0.
+And you anly went to Jeff Epatein's house
+that one fine three years spo, correct?
+0.
+You never want there again, correct?
+2.0905 - Fax
+1655 Palm Beach Lakes Bivd, Suite 500 - West. Palm Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+puning and Tractor, ber
+Page 31
+A-
+All right. Let se ask you two final areas
+of questioning about this and ve'll move onto something
+eise.
+Okay?
+Uh-huh. Tes.
+I'm sorry-
+Befose you got to [patein'» did anyone
+associated with Epstein ever call yoo on the phone and
+try to persuade, induce, entice or concce you to engage
+in any sexual activity?
+A..
+No.
+0.
+Before you pot to Epstein's did anybody
+associated with Spatein ever contact you on the Internet
+and try to persuade, induce, entice or coerce you to
+engage in any seveal activity?
+A.
+No.
+uho told you that when you got to
+Jell Epatein'a house you should lie to Jeff about your
+#g*7
+or vas it the othet girl in
+the car who you rode over with to Epstein'a house?
+Who was the other girl ie the car with you
+that day?
+A.
+1 Bonestly don't know.
+1655 Palm Besch Lakes Ulrd., Suite 500 - West Palm Beach, FL. 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Ensor & Associates
+Page 32
+Had you ever seen her before?
+A.
+No.
+sir-
+0-
+Tou told the police that when you rode over
+co Epstein's you had no idea who she was, righe?
+Coreect.
+You told the polioe that you didn't know
+her name, but she was llie really dark, kind of like a
+Spanish girl?
+Tes-
+Those were your words, right?
+Tea.
+you nou know who she la?
+No, sirso it was
+0.
+who told you to lie about
+your age to Jeff [patein?
+A.
+Yes,
+віг-
+9.
+And
+sold you that if you weren't 18,
+Epatein wouldn't let you into his house, Ilght?
+A-
+That's -- yes, yes.
+All right. Let's talk for a minate about
+when you first net Jett. Okay?
+A-
+0.
+Sure.
+When you flest net Jeff he teled to find
+out hau old you were, right?
+Касила те?
+- Fax
+1655 Palm Beach Lakes Bivd., Suite 500 - West Palm Beach, FL 33401
+
+
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 33
+When you firat sue Jett he Erled to find
+out how old you were, right?
+A.
+Hot when we first Introduced each other:
+whan ve get upatairs, thee, yes-
+During the russage Jelf asked you how old
+you were, correct?
+A.
+Tes, yes.
+Now hadn't you already told Ject's
+assistant, the one who walked you upstairs, that you went
+to cullege and had just mored down here from Ohio?
+A.
+I never spoke to the lady.
+0.
+Do you want to rethink that answer?
+NR. LEOPOLD: In that a queation?
+BY MN. TEIN:
+Q-
+Eo you want to ruthink that answer?
+No.
+I didn't mally speak with her that
+much.
+Do you want to try to refresh your sEnory
+on that?
+MR. JEOPOLD: Do you have sorething to
+refresh her senory with?
+MR. TBIN:
+Do you want to stop making
+speaking objections?
+HA. LEOPOLD: No. But to refresh acneone's
+memory, you show them a document.
+• Fax.
+1655 Palm Beach Lakes Bvd, Suite 500 - West Path Beach, FL 33401
+Entered on FLSD Docket 06/30/2008 Page 10 of 35
+16
+11
+12
+13
+14
+15
+16
+17
+1B
+19
+20
+21
+22
+23
+24
+25
+Testing and Trasurinton, Ins.
+Page 34
+MM. TEIM: I know low to do thia.
+MR. LEDPOLD: Then show her a document-
+MA. TEIN: Stop speaking.
+MR. LEOPOLD: I'a not going to stop
+speaking. J'a going to continue to mate che
+recoed.
+MR. TEIN: You're obatructing. Pisase
+stop.
+I'a not chatructiog. But le
+you want to refresh her recollection, you need to
+show her something.
+That's not a proper question. I object to
+the foundation and the predicate of that question.
+MR. TEEN: Are you done?
+MN. LEOPOLD: I an heM. Thank you.
+BT MR. TEEN:
+Do you want to try to tefresh your tenory
+as to whether you had any conversacion with the wonan who
+walked you upstaira in Epstein's house in which you teld
+her that you went to college ad had jant moved dows fron
+HA. LEOPOLD: Objectien, Object to the
+toce of the queation. Lack of foundation and
+predicate.
+BY MR. 7EIN:
+Ph. :
+1655 Palm Beach Late
+- Fax.
+ne 500
+each, FL 33401
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page
+35
+Yoo can assuer the question.
+A.
+Sure.
+Is there anything that would refresh your
+menory that in fact you told Is. Epstein's assistant,
+the
+one who walked you upatairs, that you went to college and
+you had just moved down here fron Ohio?
+A.
+I don't ceranbes saying that, but 1f you --
+I don't reseaber saying that myself, s0 -
+Q.
+That would be a 15e,
+Eight?
+A.
+No. I really don't reseaber.
+so you told Jalf that you were 19 years
+old, correct?
+Yes-
+Q-
+Do you renenber Detective
+the Folion Papactment, Palm Beach Follce Department?
+Yes.
+0.
+Do you renesber you spoke to bert
+Yes.
+Do you renenber that you told Detective
+Pagan that when you lied about your age to Jeff you said
+It really tast because you didn't want to make it sound
+like you wace lying?
+I don't remarber the Hords exactly, but 1
+do resenber telling hez I told him I was 18.
+And do you remember telling Detective Pagan
+1655 Palm Beach La
+sulte 500
+West Palm Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Ensor & Associates
+Reparing und Torturian, is.
+Page 36
+that when you lled to Ipstein about your age that you
+said le really fast so Epstein wouldn't coalize you were
+lying:
+A.
+No, I don't remember saying those words
+eactly to bar. I renomber telling her that I told
+Epstein 1 vas 18.
+0.
+Does it sound right to you that you told
+Detective Pagan that you said your age really fast to
+Epsteis --
+Objection. Asked and
+MS.
+answered.
+BY MR. TEEN:
+- ao he wouldn't think that you were
+lying!
+MR. LEOPOLD: Objection. Raked and
+answered, lock of foundation, mischaracterization
+of her earlier testingny. She's already snavered
+that question.
+BY HR. TEIN:
+0.
+You can anaver it.
+MR. LEOPOLD: Sane objection. It's been
+asked and anauered.
+You can ansaer. J'r+ nade the objection.
+THE WITNESS: I forget the gaescion, now.
+1655 Palm Beach La
+» Suite 500
+each, FL 33401
+
+
+Entered on FLSD Docket 06/30/2008 Page 11 of 35
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+opening and Tussaépia, ba.
+Page 37
+BY NR. TEIN:
+Get no put it again.
+Does It sound right to you that you told
+Ithat when you lied about your age to
+Jetfray Epsteis, you said it really fast because you
+didn't want to sake It sound like you were lying?
+Ma. LEOPOLD: Objection. Lack of
+foundation, asked and anavered.
+THE MITNESS: 1 could have posaibly said
+that, yes.
+BY MR. TRIM:
+Q-
+A.
+You didn't want Mr. Epatein to know that
+you vace lying about your age, right?
+COTTAGE
+0.
+Tou didn't uant Mr. Epatein to know that
+you were not 18 yet, rightt
+CorreCt.
+You Mansed Mr. Epatein co believe that you
+really were 18, Fight?
+A.
+Correct.
+Do you extenber when Mr. Ipatein asked
+where you want to school?
+A-
+Yes.
+And you told Mr. Epstein you went to
+Wellington, right?
+1655 Paim Beach Lakes Bvd, Suite 500
+- West Palm Beach, FL 33401
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ansor & Associates
+Separing and Tarrigion. B
+Page 30
+Was that the trath?
+A-
+No.
+In fact, you want co Royal Pale, right?
+A.
+0.
+Yes.
+So you liad to Mr. Epatele again, correct?
+Yes.
+9.
+Is Nellington the college that you told
+Jell's assistant that you were attending?
+I don't renesber having that conversation
+with her, so I wouldn't know if that's whas I sadd.
+That was a lie, chough, vasn"t it?
+MR. LEOPOLD: Objection to the torn of the
+question, lack of toandation. You're making an
+assumption. She just answered you she cao't tell
+you that.
+MA. TEIN: Speaking objection. Jad you
+well knaw that, Mr. Leopold.
+She can't answer that
+question.
+The way you pheased that question,
+you're purposaly making her not he honess in her
+testimony.
+She can't anaver a question like that.
+She doesn'E renenber. So then you say, "So you
+were lying." That's improper and you know that.
+That's not a proper question.
+And any attorney
+1655 Palm Beach La
+5ute 500
+1771
+Palm Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+U
+sor & Associates
+Page 39
+that would do that to a witnesses or to a person
+that's aitting in this chair is not aoting
+professionally.
+You can't ask a queation 1ike
+that.
+You can do it, but it's not proper. And
+I'a sure you weren't trained that way, certainly
+not ethically.
+B8- 7317:
+WIll you stop?
+MA. LEOPOLD:
+I'm not going to stop,
+because the way you're asking that question 1a
+improper and you know it.
+MR. TSIN: You're losing your 0001.
+BE HA• TEED:
+HA. LEOPOLDI
+Trust ne. I'n very caln.
+When I Jase my coal, you'll knew it.
+HA. TEIN: I do knot it.
+ВУ На. ТЕТМ:
+0-
+Ma.
+Mr. patein never asked you
+to do anything other than nassage his, corrent?
+A.
+Incorrect, becauso he asked no to take off
+sy bra, so that voold be two things he's asked ne to do.
+other than asking you to take your bra off,
+ME. Epatein never asked you to do anything with him otber
+than massage, correct?
+HR. LEOPOLD:
+objection.
+Foundation,
+1655 Palm Beach Lakes Bive.,
+682.1771
+lest: Palm Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+dupering and Tany, ler.
+Page 40
+predICate:
+THE FITNESSI COFFECE.
+BY MA. TEAMS
+Tou told the police, in your worda, that
+you did not whack hin off, right?
+A.
+What does that sean?
+Whack, 11ke whacking off?
+Your term, what does thas sean?
+Hasturbating.
+Ne. Epatein never tried at any time to grab
+your hand, did he?
+A.
+No-
+Mr. Epstein sever tried to put your hand
+anyubare, did be?
+No.
+At so tine did you touch Me. Epatein's
+penis, did you?
+No.
+And he did not touch you, correct?
+Incorrect.
+"At no time did
+Q.
+tolt, you told the police,
+he touch ne." Nure you lying to the police then?
+No. We11, I waan't being tully truthtal,
+bat I wasn't lying.
+11.682.1771
+1655 Pair Beach Lakes Divd., Sulte 500 - West Palm Beach, FL 33401
+
+
+Entered on FLSD Docket 06/30/2008 Page 12 of 35
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Supering and Touripie, fas
+Page 43
+You told the police twice when you spoke to
+that "at ho tine did he touch ne. " Didn't
+you say that to the police?
+And you're aaying that that was not fully
+0-
+cruthful, Is that what you're saying now?
+Correct.
+And you're saying if you'te not fully
+truthtal, that's not a lie. Correct?
+You took that out of context like ceally
+bad. I didn't neas like that.
+Touching ay legs and -
+he naver kept his hands to himself the entire tize.
+That's what I'm trying to say.
+0.
+You told the police, "At no tises did ha
+touch se."
+You agree with that, correct?
+No, I don't agree with that, because he did
+touch pe.
+Old you tell the police that he did not
+touch you, yus ot no?
+It's a possibility, but I do not ramester.
+Okay.
+And you did not have any type af sex
+with Jeff.
+A.
+No.
+And you did not have any type of oral ser
+with Jeff, correct?
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+U
+ánsor & Assgciates
+Page 42
+A.
+0.
+No sype of intercouree with Jeff, correct?
+COLLEC
+All right. Let'* talk about vhat happened
+after the massage was over.
+A.
+okay.
+After the massage, you told Epstein that
+you wanted to bring your twin sister back so she could
+wake some money, correct!
+A.
+Incorrect.
+0.
+Tour twin slater is
+Correct.
+And you love
+#ighe?
+very much, don't you?
+A.
+Yes.
+And when you left the louse you were Joking
+with the other girls, weren't you?
+A.
+Incorrect.
+0.
+Well, when
+land the other girl in the
+car that day made their statesents to the police they
+told the police that you were joking afterwards. Are jos
+saying that they were lying to the police about that?
+A.
+NO,
+But a question or - questiona fron
+Ilke aho asked se questions, but it wasn'e
+joking.
+She was kind of Ilke in a happy way, Aska, "oh,
+what did you do?
+What did you dot Like those kind of
+682.0905 - Fax.
+682.1771
+1655 Palm Beach Lakes Bvd, Sulte 500.-.West Palm. Beach, FL 33401
+• Fax.
+1655 Palm Beach Cakes BId., Sulbe 500-West Palm Beach, FL 33401.
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ansor & Associates
+Page 43
+things, but it wasn't joking about it at all.
+You joked about 15, didn't you?
+No-
+You said to
+that if you did this
+every veekend you'd be rich,
+didn't you?
+A.
+Q.
+No.
+That's what
+eld ne-
+You didn't tell that to
+MR. LEOPOLD: Objection.
+Asked and
+ansuered.
+THE VITRESS: No.
+After you left Epsteln's house you took she
+and the other
+money and you went shopping with
+girl 1e the car, corcect?
+A.
+Incorrect. I didn't spend any of the
+A.
+0-
+didn't you?
+You want to Marshall's, didn't you?
+I went along, yes, but I didn't --
+You vest shopping with them at Marshall's,
+MR. LEOPOLD:
+object lon.
+THE WITHESS:
+I quess you could say that.
+HA. LEOPOLD:
+Objection. Lack of predicate
+and foundation. Mischaracterization of earlier
+testimony.
+- Fax.
+1655 Palmi Beach Cakes Bird, Suite 500 - West Faim Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ánsor & Associates
+Page 44
+BY ME. TEEN:
+0.
+And
+bought a parse, right?
+Yes.
+And you were with her the whale tine at
+Haeshall's, correct?
+h.
+Tes.
+llow tell ze about when the federal
+prosecutors told you about getting reimbursed.
+A.
+I have no ides what you're talking about.
+Tell ne about when the federal prosecutors
+spoke to you about getting money you feel you're entitled
+to from Me. Epatein.
+I don't know what yog're talking about.
+9-
+so you knew who
+A.
+No, sir.
+0.
+Bid you ever seet with any federal
+prosecutora?
+A.
+I think -- yeah. I chink they were -- I
+think they wace 1ika FRI.
+Oh-buh. Did you meet with federal
+prosecutora?
+They case to ay house one tine, yes.
+When did they come to your house?
+very Jong a90.
+Has it this year, 20067
+Ph. 561.682.0905 - Fax.
+11771
+1655 Paim Beach Lakes 8vd., Suite 500 = West: Palm Beach,-FL 33401.
+
+
+Entered on FLSD Docket 06/30/2008 Page 13 of 35
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+10
+11
+12
+13
+14
+15
+16
+17
+10
+19
+20
+21
+22
+23
+24
+25
+U
+i....
+Ensor & Associates
+Supering and tapedgies, lat
+Page 45
+It was not this year, no.
+9. Han it 20077
+A.
+I'd have to say at least too years ago at a
+year ago, yauh. So 1t would be 2007, 2006/ but it was a
+while ago.
+How many federal prosecutors or til agents
+came to your house?
+A.
+I'a ceying to remember. I want to say four
+people cans.
+Did they give you their businesa carde?
+If they did, I don't reseaber, and they
+weren't toward ne. Maybe my parents have them.
+I don't
+клон.
+Q-
+Did thay give you their call phone numbers?
+No.
+Did you ever speak to then on their call
+Shonest
+9-
+parents.
+0.
+parent" s7
+No, sir.
+Did thay spaak to your parenta?
+That's nonething you'd have to ask my
+Do you know whether they spoke to your
+No. SIE. 1
+You have no idea?
+1655 Palm Beach Lakes Bivd, Suite 500-West Palm Beach, FL. 37401
+Page 47
+fashion, you ray answer.
+THE WITNESS: Ckay-
+I wouldn't know.
+TEIN:
+You don't know?
+No.
+NR. LEOPOLD: Objection.
+Foundation.
+Attorney/client privilege.
+BY HA. TBIH:
+157
+And you say you don't know who Jeff Sloman
+3.
+No, siE.
+Does it refresh your recollection that he'a
+the mumber two prosecutor at the U.S. Attornay'a Office?
+No.
+Q-
+That he's
+boss?
+A.
+Does it refresh your nenory that he's the
+ex-partner of Jeff Henan, the firat lavyur who soed
+you - sued Mr. Epatein on yeur behalf for fifty million
+dallars?
+A.
+No, sir. I don't know who le 1s.
+Without telling me any coversations that
+you've had with your lawyers, hot is it that you selected
+He. Herman as your lawyer tras the 81,000 menbers of the
+662.1771
+5655 Palm Beach Lake
+Suite 500
+- West Palm Besch, EL 33401.._
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Ensor & Associates
+Page 46
+No. sir.
+NO. BROFOLD: Objection. Asked and
+BY NA. TKIN:
+So it I say the rome to you Bl
+Villafona, you don't know who that is7
+A.
+No, SiE-
+How nany women and how many sen one to
+your hoste?
+A.
+I vant to say two ladies and too guys.
+CONG CO
+Did someone Tuned
+your hoose?
+I don't know names, sir.
+587
+No, sir-
+Do you know who Jeffrey Hernan $a7
+Yes.
+9.
+That's the lawyer who fiest aued Epstein on
+your behalf, righe?
+A.
+Yes.
+0. Has He. Merman advanced your tamily any
+попкут
+NS. LEOPOLD: Any conversatlons that yeu"re
+had with Mr. Herman regarding that issue, yog ace
+not to disclose. If you've learsed in some other
+m-beach, EL_33401
+1555 Palm Beach LEX
+wing and spin,
+Pagn 48
+•Florida Bart
+A.
+9.
+A.
+I did not select him.
+who did?
+My fathes.
+Did you ever meet Mr. Herman?
+Once.
+Don't - don't tell me what you discussed
+with him. Where did you meet his?
+A.
+I was shopping in my -- he showed up at ay
+friend's house.
+Whose house?
+A-
+My Erland
+Is that
+from the Quarterdeck
+Tavernt
+A.
+Yes.
+And did you have a westing with him at
+housel
+Yes.
+1 goess you could say that.
+And who alse was there?
+My Aunt
+And what was that meeting about?
+HR. 10/010:
+objection. That calls for
+attorney/elient privilege.
+BY HA. TEIH:
+What discusalone did you have with
+1655 Palm Beechi Cakes Li
+I suke 500
+-west Pam, Beach, FL 33401
+
+
+Entered on FLSD Docket 06/30/2008. Page 14 of 35
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Resent ael Temple, tol
+Page 49
+Mr. Herman in the presence of
+A.
+0-
+What diacussions did you have in the
+presence of her aunt?
+or ny aunt?
+HA. GOLDBERGER:
+It's the witness's sunt.
+BY HA. TEIN:
+oh, of your aunt.
+The only one that we've ever discussed or
+avat had.
+Q.
+And 30 you were in a conversation with
+Me. Herman and your amt?
+A-
+yes, siz.
+Aul you discussed privileged natters during
+that conversation?
+Ill. LEOPOLD: Object to the form.. I think
+you might have to educate her on that question.
+ву На. ТЕІНЕ
+You discussed the lavault?
+tell you about any
+Did
+converaatlons that she had with Me. Bernan?
+A-
+As far as I'a concerned, she's never spoten
+or she's never had a conversation.
+She only opened the
+door and then left.
+She's the one who answered the door.
+0905 - Fax.
+1655 Palm Beach Lakes
+: Dvd:, Suite 500 - West Falm Beach, EL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ánsor & Associates
+Page 50
+Why did the nesting take place at
+ouse?
+I apest the night that night at her house.
+9.
+And whee was this?
+A.
+a while ago.
+Now long ago?
+A montle and a half ago.
+I'm guessing-
+A month and a half ago?
+Oh-huh.
+So was it before of after Mr. Herman filed
+the fifty-million-dollar lawsuit against Epstein?
+Alter.
+Did you meet with an 731 agent naned
+a woman?
+I don't kaoh.
+9.
+Did
+Ipeak to you about
+getting relabursed fron lc. Epatein?
+A.
+I've never had a discussion with anyone
+about getting reisbursed Icon Me. Epstein.
+lave you not with an agent nased
+A.
+A.
+0.
+Not to ay knowledge.
+How about an agent nose
+No, sir.
+How about an agent named Junior Ost12?
+each. EL 33401
+1655 Palm Beach Lak
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Дарослу іні Танкунни, Н
+Page 51
+No.
+9.
+And we've learned that nany of the girls,
+gone of how are as old as 23, were told by the
+government that they would get money at the end of tha
+criminal prosecution.
+Does that sound faniliar to you?
+No, sir.
+Other than Me. Leopold here -. I'm not
+asking about Me. Herman either -
+A-
+Ch-heh.
+9-
+- did anyone ever discuss with you that
+you could get reinbaraement for your danages?
+No, siE-
+Did you de any nester -
+MR. LEOPOLD:
+Are you referring to a
+crininal natter or a civil matter?
+0.
+Did you or any menber "
+Excuse Ha. Let me object to
+the forn of the question.
+ST MR. TEIN:
+9-
+bld you or any momber of your fantly erec
+get a vietin notification letter fron anyone?
+I no Jonger live at that residence and 1
+wouldn't know.
+0.
+So your teacimony ta that you have never
+~1655 Palm Beach Lakes Bivd.,Suite, 500 - West Palm Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+" +*
+Page 52
+rectored a victin notification letter, correct?
+rect.
+0.
+and yoer teatinony da that you don't know
+If your parenta have aver received a victia notification
+letter,
+correct?
+Correct.
+Have you given any evidence to prosecutors
+or lav enforcesent In this case?
+A.
+9-
+A.
+What do you mean by evidence?
+Hel1. Anything that you can touch or feel.
+No.
+HA. MOPCLD: Objection to the torn of the
+question.
+BY ME, TEIN:
+So you haven't çiven anything physical --
+A.
+No.
+- any iton te any prosecutor, police
+officer or law enforcemeat agent, correct?
+A.
+My cell phone Cour years ago or three years
+- ago, but that's it-
+You gave your cell phone to whom?
+Did she Keep it7
+A.
+Ask her.
+0-
+tou gave it to her and than you dide't get
+.682.0905 - FaX. 561.582.1771
+1655 Palm Beach Lakes Bivd, Suite 500 - West Falm Beach, FL. 33401
+
+
+C
+Entered on FLSD Docket 06/30/2008 Page 15 of 35
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 53
+it back at the end of the senting?
+They -- yeah.
+No. They have It. I'a
+guessing. I don't have it-
+How such soney are you hoping to get out of
+HI. Epstein?
+MR. LEOPOLD: dojection to the form of the
+question. Attorney/client privilege.
+BT MR. TEIN:
+0-
+How such noney are you hoping to get, you,
+yourself, hoping to get out of Epatein?
+MR. LBOPOLD: Sane. Sane objection,
+attorney/client privilege.
+Don't anaver the questian.
+BT HR. TEIN:
+I'm not asking about what your lawyer told
+you-
+MR. IROPOLD: I'm Instructing her not to
+anawer the question, because any of those
+conversations involve her counsel-
+ME. TEIN: Certify that.
+MR. LEOPOLD: Please.
+•CERTIFIED QUESTION
+0.
+Мон,
+deposition, didn't
+yogy
+you lied to get out of thia
+- Fax
+1655 Palm Beach Lakes BID, sche 500
+beach, FL. 33401
+ensor Associates
+olgand Таннірім,
+Page 55
+..CERTIFIED QUESTION.
+BY MA. TEIN:
+You asked your co-workers --
+MR. GEOPOLD: It's vague and inbiquous.
+BY NR. TEEN:
+Q-
+You asked your co-workers at the
+Quarterdeck Tavern to lie Iot you, didn't you?
+A.
+No.
+I inforned ny boas about what was
+going on and he told se that he would help in any way
+that he can.
+Okay. Tau got your friend
+to l1e
+by aultehing nane tags with you, correot?
+A.
+Incorrect. Ie vas a coincidence that same
+sight ahe was not wearing her nase tags she was wearing
+sino. But I was also not wearing «- I was wearing ny
+nase tag. Everyone switches nane tago. It just so
+happens it was a colncidence that same right the people
+cane with the papers.
+HA. TEIN: Will you put up chibit 18-0017
+Hit. GOLDBERGER: And mark 18-001 for
+Identification purposes to tris deposition.
+HR. LEOPOLD: Hone of then have bean marked
+yet. Can ve mark them and put than as attachment
+to the depositlons? Because I think you've shoun
+three photos now.
+And this is the only one that
+1655 Palm Be
+Beach, VL30401
+U
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+lupering and Trapon, Joe.
+Page 54
+No, sir.
+Tou didn't want to conu to court today and
+tell the story that you had told to the police under
+cath, did you?
+MR. LEOPOLD: Objeat to the fora of the
+question. Lack of foundation, predicate.
+THE WITNESS: No. I have no problem coming
+here and talking to yoa.
+BY MR. TEIN:
+0.
+And te avoid getting served with a lawfal
+subpoina, you lied about your nabe, didn't you?
+0.
+And in fact, just lying yourself wass't
+enbuph, was 1E7
+MX. LEOPOLD: Objection to the forn of the
+goration.
+Don't anaver St.
+It's not a questies.
+doject to the torn of the question. Lack
+of foundation.
+HA. TEIN: Are you instructing her not to
+answerT
+MA. LEOPOLD: I am.
+MR. SEEN: Certify It.
+HA. LEOPOLD: Please.
+1655 Palm Beach Lak
+beach, 7L 33401
+ánsor & Associates
+Page 56
+has been sacked for identification yet.
+BT NA. TRIN:
+SOPOLD: lold on just a second. Just
+so the record is clear --
+MR. TEIN: I'm not speaking to you.
+IN LEOPOLD: Okay.
+Then don't speak to me
+then.
+But I'll speak to Mr. Goldberger, perhaps.
+But at least for the record, can ve put on
+the record what the previous two photographs were
+marked for identification?
+МН наникі на ні маке aure Chac CnE
+record is clear at the and of the deposition so
+that there's no anbiquity.
+MR. LEOPOLD: Thank you.
+I've pus a photograph parked 18-00L
+4p on the botany
+Do you sen that?
+Yup.
+who is that in the phote?
+on the left and ne on the right.
+Eight?
+your friend at the
+Dearterdeck Tavern, tight?
+- 03
+1655 Palm Beach Likes Biva, Suite 500 - West Palm Beach, 7L'33401
+
+
+Entered on FLSD Docket 06/30/2008 Page 16 of 35
+10
+11
+12
+13
+14
+15
+15
+17
+18
+19
+20
+21
+22
+23
+24
+25
+sparing and Tensigties, Is.
+Page 57
+your friend, who you say the day
+Ches Ene process
+• servers went to serve you with a
+subpoena for this deposition, just happered -- Just by
+coincidence, was wearing your name cag?
+A.
+Yes, sir.
+And just by coincidence, you were wearing
+her name seg, correcet
+A.
+Yes.
+Your testimony under oath is that's Just a
+coincidence, right?
+Total honesty-
+0.
+It juat happens to be the day that you were
+guing to be secred with a subpoena, correct?
+That wasn't the firat day that --
+Just ansuer the
+question.
+It calls for a yes or no.
+THE WITNESS:
+Tos.
+BY NO. TEIN:
+You sald that wasn't the firat day you were
+poing to be -- yos thought you were being served with a
+subpoene, correct?
+A.
+Correct.
+You knew before the day that you switched
+nase tags with
+bat the process servees were
+1655 PElm Beach L3
+Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 58
+Josting far you, dich't you?
+A.
+No. I kneu .
+Ha. LEOPOLD: Just anamer it, It calls for.
+a yes or no.
+BY MI. TEIN:
+Now you can explain the answer that your
+pounaal stopped you tron explaining.
+Okay.
+I vork at quarterdect and people
+were telling su that people were looking for so. So yes,
+1 uas avare that people were searching for se.
+But I bad
+no idea who they were or what chale Intentions were. But
+I thought they were juat people I didn't want to talk to.
+So I junt didn't want to talk to then. And erery time
+thay'd cose to work I wass't there. And so happens the
+night that they cane in ne and my friend switched name
+tags.
+No big deal.
+0.
+That's a lie, Isn't iet
+MH, LEOPOLD:
+objection.
+Don't ansuer that
+question.
+That 'a harassment and I will not alle
+it. He could ask the questions and we'll allow a
+jury to sake that deteraination, but not counael.
+I will not allow her to ansver that
+MA. TKIN: Certify it.
+1655 Palm Beach La
+Suite 500
+1682,1771
+est Palm Beach, FL 33401
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ansor & Associates
+Page 59
+MR. LEOPOLD:
+I'll cectly it.
+•..CERTIFIED QUESTION
+She's anavered that quastion.
+She's explained it five
+class already. The fact that Counsel doesn't like the
+ansuer, that's a ditterent query-
+Na. TEIN:
+stop naking speaking objections.
+MR. LEOPOLD: I'm not.
+I'm not going to
+put up with it, because it's in appropriate, Jack,
+and you know it. I will not allow Counsel to
+berate a witness, whether it's in a crininal case
+or a civil cate, whether ay ellest or =-
+HA. TEIN: Calm down.
+HR. LEOPOLD: Excuse me.
+No, I'a not going to allow it. That is not
+MR. GOLDBERGER: Okay.
+MA. LEOPOLD: If he wants to say that she's
+lying after asking it tive times and her
+axplainieg in great detail, he can do that.
+But
+I'm not going to alieu her to ansver, nor be
+harassed by him. It'a inproper.
+KA. GOLDBENUER: Okay. But your seaponse
+that Counsel doesn't 15ke the question -- or
+doesn't Jike the ansuer -- just let ne finish.
+MR. LEOPOLD: Absolutely. I wasn't going
+Ph
+TESS Palm beach Lakes Bid,
+Suibe 500 -
+West Palm Beach, FC 33901
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Ensor & Associates
+Page 60
+to interrupt you.
+MR. GOLDDERGER: Just requices us to say we
+I5ke the ansver to that question.
+And it's not
+you and I or you and Me. Tein who ace testifying
+here. It's the witness.
+MR. LEOPOLD:
+Fine.
+But after the sixth
+Line of asking the sane question and than coning
+back and painting a finger at her and saying.
+"You're a 15ar* --
+'MA. TEIN: That didn't happen-
+MR. LEOPOLD: Tbat's Else. But I'm not
+going to allow her to ansver that question,
+because she'a anavered that sane question and has
+explained it.
+low Coonael alght be sitting Chace rubbing
+Bin head with a aigraine. That's his problen,
+But it he can't ank a question appropriately in a
+professional manner, ve will leave. I will not
+allow her to be berated like that.
+HM. GOLDBERGER: Aotually, we're very happy
+wich the anauer.
+MR. IEOPOLD: That's great.
+MR. GOLDBERGER: Do you want us to get into
+that!
+HA. TRIN: Tod --
+I - Fax.
+1655 Palm Beach Lakes Blvd., Sutie 500 - West Fam Beach, FC 33401
+
+
+Case 9:08-cv-80119-KAM Document 15-2 . Entered on FLSD Docket 06/30/2008 Page 17 of 35
+10
+11
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ánsor & Associates
+Amering and Tanapk, Is. -
+Page 61
+KA. LEOPOLD: Thin la really big stuff that
+you'se going through. But that's fine; Just ask
+your question and sove on.
+But do it one tine.
+It you don't understand it, I'll let you tollow
+up, but I'm not going to allow you to sak the same
+question time and again and then call her a liar.
+Just ask the question, get the anauer and nore to
+the neat subject matter.
+NR. TEEN: Ted, I'a sitting right across
+the table trum you.
+MR. LEOPOLD: Tes, sir.
+HA. SRIM: Please be quiet. Don't yell.
+MR. IROPOLD: I vill not be quiet.
+MA. TEIN: Stop yelling.
+MA. LEOPOLD: tawla, when I'a yelling
+you"11 know It. I Mill not --
+HA. TETH: My namn is not Lewis.
+NR. LEOPOLD: I thought your flest nose was
+Iewis, ME. Tein-
+MR. TEIH: You vatched ne for three days at
+the avidettiary hearing where you sat in the back
+of the courtroon.
+You should know who 1 an.
+NA. LEOPOLD: Mell, thac's the lapression
+you sust have sade in the courtroom.
+I vill not be quiet.
+T655 Pam Beach Lat
+hate 500*
+al Beh, FL 33401*
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ansor & Associates
+Separag and Junwipina, In.
+Page 62
+MA. SEIN: That's obnoxicus. Stop being
+obnoxious. It's atupid. Let's go ahoad with the
+questiona.
+MR. LEOPOGD: I will make the record.
+MR. TEIN: let's get on with the questions.
+MA. LEOPOLD: Do yor need a break?
+(Thereupon, • recess was takes-)
+HY ND. TEIN:
+Okayafter you told your manager
+at che Quarterdeck Savern everything that was going an
+and he told you be would help you any way he could, he
+hid you in the kitchen from the process servers, correctr
+A.
+Incorrect.
+Isn't it true that lying to avoid aurvice
+do a seaningiess lie to you,
+A.
+Incorrect.
+What Ià your susager's nase?
+A.
+I have three. Would you like to know
+Who's the one who lied for you?
+9.
+And what did
+do to lle for you?
+Said I wasn't there.
+And who did ho tell waan't there?
+Ask him.
+Ph
+1655 Palm Beach Lat
+west Pam Be50, FC33901
+10
+11
+12
+13
+14
+15
+16
+17
+10
+19
+20
+21
+22
+23
+24
+25
+Raportag and Teneripilin.
+Page
+Where were you when
+told this
+acneone that you were not at the Quarterdeck Tavern?
+A.
+Eating nechos.
+At the Quarterdeck Tavern?
+Yes.
+0-
+what did you do so that
+would lie to
+the process servers for y047
+A.
+Nothing.
+0.
+You Just got him to lie for you, didn'e
+you?
+A.
+wasn't there.
+No. I had no influance on him saying 3
+He took that upon himself?
+Ian't it Eroe that Mr. Epatein's process
+servers had to ask the police to get you put of the
+restaurant so that they could serve you?
+MR. IZOPOLD: Objection. Lack of
+BY MR.
+TEIN:
+You can anare: the question-
+NR. LEOPOLE:
+It you know. Don't guess.
+THE WITNESS: No. Can you repeat the
+question?
+HE. TEIN:
+Don't coach.
+HH. LEOPOLD; Don't queas.
+- Fax.
+1655 Palm Beach Lakes Blvd., Sate 500 - WER Palm Beach, FC 33401
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ansor & Associates
+Page 64
+MR. TEIN:
+That's a coaching.
+HA. LEOPOLD: No.
+That's an instruction to
+H. TEIN: No. You don't do that.
+THE WITNESS: Can you reprat the question?
+NR. LEOPOGD: Let ne just stace for the
+ERODEd --
+BY HR, TEIN:
+Once the police -- ian't it true that
+Mr. Epstein's process secrecs had to ask the polloe to
+get you out of the restaurant so that they could serve
+you?
+A. Incorrect. My boss called the police.
+0.
+And once the police shoved up, to stop you
+tron lying te aroid service, you nade up another lie that
+the process servers had harassed you. Isn't that
+correct?
+Incorrect.
+9-
+You lie all the time, don't you?
+MR. LEOPOLD: objection.
+THE WITNESS: Incorrect.
+BT HA.
+You hare a Hypace page, don't y9u7
+No longer do I have a MySpace page. I
+deleted it.
+1655 Palm Beach Lakes Bivd, Suite 500
+1771
+1 Palm Beach; FL-33401
+
+
+U
+Entered on FLSD Docket 06/30/2008 Page 18 of 35
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Papering sad Traine, Ine
+Page 65
+When did you delete your Hyspace page?
+A.
+A couple days age.
+Who told you to take your Myspace page dove
+* couple of daya ago?
+Nobody. I'm sick and tired of Hy$pace.
+0-
+You all of a sudden got sick and tired of
+MySpace and just a few days before this deposition you
+decided to delete your MySpace page, correct?
+A.
+Correct.
+0-
+In that your testinony wader oath?
+Did you take your Myspace page doun because
+you thought the governnent might subpoena 1t7
+A.
+Incorrect.
+0.
+Hadn't your Myspace page been up for orer
+three sonths before you took it down?
+A.
+Correct. Rut I also had made tons of
+Myspaces over the last years. I just get tired of them
+and delete them because - drana «. and sake nts ones.
+Ne're going to talk about that-
+So you deleted your Myspace pago after you
+vere already under subpoena for thie deposition, correct?
+Correct.
+What about the Hydpace page didn't you want
+us to see,
+-1655-Palm Beach Lakes T
+avd., Suite 500 - West-Palm Beach, FL: 33401-
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ansor & Associates
+Page 66
+A-
+Nothing-
+Well, ve're going to cone back to Myspace
+in a second.
+You do that.
+' going to ask you some questiona
+about why you die about your aço so often, okay?
+MR. LEOPOLD: Objection to the torn.
+Argunentacire.
+BY MR. TEIN:
+0.
+You lie aboue your age all the time, don't
+youT
+MR. LEOPOLD: Objection, argunentative.
+THE MITRESS: Incorrect.
+BY MR. TEIN:
+0.
+You lie about your age to pet body
+piercinga, don't yout
+A.
+Incorrect.
+0.
+You have body plereings, den't you?
+A.
+Yes.
+0.
+Tou have four body piereinga, isn't that
+right?
+A.
+Five.
+Other than the piercings on your tars
+I'm not talking about that --
+Oh, then no: just one.
+1655 Palm Beach Lakes vd., suite 500-West Pam Seach, FL-33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ansor & Associates
+Page 67
+0-
+And where is the one body plercing?
+Belly.
+When did you get that?
+Tor ay birthday, with my stepnother and my
+0-
+And when was that?
+When 1наз 14-
+0.
+Oicay.
+So you had that body piereing when
+you set Ipatait, correct?
+A.
+It might have been, or saybe that -- yeah,
+either my 14th blethday or ay 15th.
+I honestly don't
+LATELLI
+How you've lied about your age to get into
+bars by using driver's licenses that aren't yours,
+Correct?
+Are you swearing under oath that you've
+never done that?
+A-
+Yes, I avnar under oath.
+And you've lled about your age to buy beer,
+Correct?
+A.
+Incortect.
+You're swearing under oath that you've
+never lied to stores about your age?
+I'ne never lied to a store about ny age or
+- 1655 Palms Beach Lakes
+- Fax.
+d; Sulte 500 - West Palm Beach, FL-33401-
+10
+11
+12
+13
+14
+15
+15
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Ragoning and Tenurigo, Sne
+Page 68
+anything.
+0.
+don't you?
+You try to look much older than you are.
+Incorzect.
+And you've lied about your age en your
+Myspace pages, don't you?
+A.
+0.
+Incorrect.
+All right. Let'a look at Exhibst 26-01
+one-
+26-0017
+MR. THIN:
+Yes.
+BY MR. TEIN:
+On this page you lled to everyone that you
+ware 18, didn"t yeu?
+Correct.
+Let's go to Exhibit 33.
+That's 33-0017
+Coerect.
+BY MR. TEIN:
+On this page you lied to everyone that you
+Here 19, didn't you?
+h.
+Incorrect.
+MA. LEOPOLD: Just ansver the question.
+THE KIMESS: Oh, Incorrect.
+BY MR. TEIN:
+- Fax.
+•- 1655 Palm Beach Lakes Bvd, Suke 500 - West Palm Beach-Fl: 33401-
+
+
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Lipoing and Tusspina, leo.
+Page 69
+Now you can taplain your anandr.
+I know that I have seen all of these and I
+Can you go downt
+MA. LEOPOLD: Jest for the record, you're
+pointing to the photo.
+THE WITNESS: I'm pointing to --
+TEIN:
+You're polating to the one where it says
+your age 5s 187
+SOCCEEL.
+That's yours, Fight?
+Correct.
+That's wine fron e couple yoars
+A.
+ago that I have cot been on, because I don't use that-
+Please leup going down, please. And I think that'a it,
+because there's co cne -- Just that ena is mine.
+0.
+So the one you pointed to wbare it says
+your age is 19, that's yours, correct?
+A.
+Correct.
+0.
+And when you wrote 18 as your age on your
+Myspace page, that was a lie, wasn't 1t7
+A.
+Correct.
+Did you lie about your Myspace page back
+then becauso you coulds't post on Hypace unless you were
+107
+0905 - Pax
+- 1655 Palm Beach Lakes Bivd., Suite 500
+West Palm Beach, FL-33401
+Entered on FLSD Docket 06/30/2008 Page 19 of 35
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 70
+Correct. There was a rule many years ago
+that you had to be 16 to have a Myspace.
+So you lied about your age so you could
+post on HySpace, right?
+TES.
+0.
+Let's go back to the top one on this page.
+11-01-
+Are you testifying now under cath that thia
+'Myspace pago where the headline says, "Twins do have nore
+fun, " and the location is given as Lox, abbreviation tor
+Loxatatcheo, and the age is 15, and it says
+'is it your teatimony that you did not post
+CorreCt
+Now Let's go back to the one that you were
+pointing to before on this paçe,
+where it gaya your age
+is 18 and you lied about your age to post Myspace, okay?
+A.
+Uh-huh, yes.
+All right. Shy did you finsily put your
+true age on your Myapace profile four days before you
+were scheduled to testify before the Geand Jury?
+I don't know what you'se talking about.
+MR. LEOPOLD: If you don't understand, ask
+him to ask the question again.
+HA. TEIN:
+Don't coach.
+- Fax
+-1655 Palm Beach Lakes Bld, Suite 500 - West-Palm Beach,-FL-33401—-
+G
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+U
+Page 71
+THE WITNESS: I don't know which Myspace
+90 E0 588E9 a0o0E-
+BY HR. TEIN:
+The Myspace page that you're just pointing
+to, where it says you were 18.
+A.
+0.
+A.
+Tea.
+And you vere lying about your ago, right?
+Uh-huh.
+why did you finally post your trae age on
+your Myspace protile -
+Oh --
+- four days before you were schedulad te
+testify before the Grand Jury?
+A.
+I honestly don't koow which Myspace,
+because I've had like a barillion Myspaces, and in that
+year, I had two, that one and another one, and that ane's
+been deleted. So I don't know which dew you're referring
+to.
+You renesber that you changed your age on
+your Myspace pago from 16 to your troe age just four, daye
+befose you went and testified in the Grand Jury?
+30.
+0-
+A.
+Yoo don't remember that.
+0-
+Do you renasber Datective Recacey?
+Did you
+- Fax.
+1682.1771
+-1655-Palm Beach Lakes Bivd.; Suite 500 - West-Palm Besch,-FL-33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ensor & Associates
+dagering and Tasse, 10
+Page 77
+eTer meet a Cutective Racatey?
+I don't know the names.
+How nany different detectives have you met
+with on this case from Paim Beach?
+A.
+Probably a good six or seven, maybe.
+Bld one of the detactives tall you before
+you testified in the Grand Jury that you should take your
+MySpace age and put your trot age?
+A.
+No.
+Didn't Detective
+have to come to
+your house to pick you up to get you to testify in front
+of the Grand Jury?
+A-
+Fossibly, raybe bacause I didn't have a
+ride: I van only 14 or 15 at the time.
+Your non didn't drive you?
+A.
+Q.
+No.
+Stepace didn't drive you?
+I think ay dad.
+Ch, my dad, my dad drove
+Be.
+0.
+A.
+Your dad drove you?
+Yes, sir.
+So your testimony is Detective
+not drive you, correct?
+sE. LEOPOLD: Objection.
+lasked and
+ansuered.
+did
+Ph
+1655 Palm Beach Lakes Bld,, Sute 500 - West Palm Beach, FL 93401-
+
+
+Case 9:08-cv-80119-KAM Document 15-2 Entered on FLSD Docket 06/30/2008 Page 20 of 35
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+nor& Associates
+Page 73
+THE WITNESS: No. I'm pretty sure my dad
+drove ra, because he was there with ae.
+HY MA. TEEN:
+Did any detective tell you to change your
+aqa on your Hyspace page, to put your true age?
+No, sir.
+Now you also lied on your Myspace page
+about your incone, dide't you?
+A-
+Tos.
+And you lied, saying that you made a
+quarter million dollars a year and higber, correct?
+As a jeta, yes.
+That was • Lie, Haan't It?
+A.
+Yes.
+And you also lied on your MySpace page.
+saying that you were sarried, didn't you?
+A.
+Possibly. And that might have been an
+error on ay part.
+Now you elao lie to the police, don't you?
+No.
+Well, you lied to the police in your
+cape-recorded statazent that you game to Detective
+Michelle Pagan three yeara ago, didn't you?
+A.
+0.
+To my knowledge, no, I did not.
+Mell, you lied to the police when you
+Ph. :
+_1655 Palm Beach Lakes Blud
+Fax.
+Palm Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 74
+accused Mr. Epstein of attenting to wurder your facher,
+didn't you?
+A.
+0.
+So.
+I never heard a statement anying that
+ME. Epstein tried to murder ny father.
+Tou nade that statement, didn't you?
+MR. LBOPOLD: Do you have a statement to
+show her?
+That's been asked and ansuered.
+MA. TEIN: I'm aDELy. I didn't hear the
+witness' ansuer, Mr. Leopold.
+BY HR.
+TEIN:
+you told the polies, didn't you,
+that Mr. Epstain alson: killed your father, didn's you?
+9.
+Three yeara ago, before Mr. Epstein even
+knew about thin investigation, you told the police that
+Epstein had "already come to my dad's house and did
+something to my dad's tires and ay dad almost died. I
+didn't want my dad to get hurt, because deff already
+alrost killed hin."
+Bide't you say that?
+A.
+Not to my knowledge or recollection. I
+have never said anything like that.
+That would have been a complete lie,
+woeldn't it have been?
+Yeah.
+L- Fax.
+- 1655 Palm Beach Lakes Bhd., Suite 500 - West Pair Beach, Fl 3340L
+10
+11
+12
+13
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+leg and Transcripico, Is.
+Page 75
+Because HI. Epatein never cane to your
+dad's house, correct?
+A.
+Correct.
+0-
+And no one who worked for Mr. Epstein ever
+did something to your dad's tires, did they?
+MR. LEOPOLD:
+Objection. Lack of
+toundation, predicate.
+Don't guess.
+BY MR. TEIN:
+0-
+It's not true that Mr. Epstein alnost
+killed your father, is ie?
+MR. LEOPOLD: Objection. Asked and
+anawered, Jack of foundation, predicate.
+BY MR. TEIN:
+You can answer.
+lo.
+Now you told the police that you didn'e
+know who was in the car with you and
+on the day
+you went to Epstein'a house, didn't you?
+A.
+Yes.
+0. And that was a lie, wasn't 1t?
+It's the truth.
+0.
+You told the police that there was someone
+in the cor next to you and you specifically said you
+didn't know her nane, right?
+Ph.-
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Ensor & Associates
+Ragoning and Smas
+Page 76
+Correct. I do not know her name.
+You said, "1 don't know her nase, but she
+was dark 11ke a Spaniah girl. " Those wese your words,
+right?
+A.
+Yes.
+#navered.
+BY MR. TEIN:
+MR. MOPOLD: objection. Asked and
+Who was in the car that day with you and
+Again, I do not know.
+Ie Mas your pood friend
+wasn't 1t7
+A.
+No. I don't know a
+0.
+You lied to the police about who was in the
+car with you and
+didn't you?
+A. Incorrect.
+0.
+Let se ask you some questions about who you
+may have apoken to about thia case. All r1ght?
+A.
+Go ahead.
+0. Did you speak to your twin sister
+A.
+Blot in detail, but of course she kneus;
+she's fantly. And yes.
+What's her e-mail?
+A.
+I don't think she has an e-mail.
+Ph. 561.682.0905 - Fax. 561.682.1771
+1655 Paini Beach Cakes Blvd., Suite 500- West Palm Beach, FL 33401™*
+
+
+Smsor de Associates
+Irperipa iod Traniu
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Entered on FLSD Docket 06/30/2008 Page 21 of 35
+ansor & Associates
+Laporiing end Tresnirlpie, 3ed
+Page 77
+0.
+- What is her phone numbert
+oh, gosh. I dan't know off the top of my
+head.
+Q.
+And what is her hose addresa?
+A.
+She lives with ay mon.
+In Georgia?
+A.
+Yes, sir-
+0.
+What about
+boytriend
+Bid you
+spaak to him about [patein's
+A-
+That's ay non's beytriend.
+NY SESCOE
+doean't have a boyfriend. Hy som'a husband'a naae ia
+so naybe you get then confused.
+0.
+Do you know his phone nurber?
+No.
+Q.
+Whero does he ilvet
+A.
+With ay sos.
+Q.
+In the aane house with her?
+A.
+Yes. They" ce married.
+So nat boyfelend, basband?
+A.
+Yeah, huaband.
+Have you spoken to
+about
+what bappened in Nr. Spatein'a house?
+A.
+Not in detail, but be koows che basics,
+yes.
+Hhat is his e-mail?
+1 e Fanc 3
+-1655 Paim Beach Lakes Blvd., Sute 500 - West Palm Beach, FL-33401--
+Begoning and Tersolpden, loc
+Page 79
+what apartment nusber is 1c?
+I couldn'E tell you.
+0-
+Whan was the last tims you want there?
+A.
+Just visiced this past veokend. That's the
+tirat and last tine I went there-
+0.
+How abeut
+Have you spoken
+to hin about your case?
+A.
+No. He no longer speak.
+What's his phose number? Actually. we
+already bare his phone momber and e-mail.
+How about
+Have you ever
+spoken to ber about your case?
+A-
+I don't know an
+2.
+Have you ever net
+ln. But just to let you know,
+I don't
+really know nsaen. If you have pictures of there faces I
+could tell you.
+Q-
+All right. Iet so sce if I can refresh
+your menory.
+A-
+Okay-
+0.
+Does it cefresh your senory that
+1s the other girl who nade allegatiens about Epstein,
+bat
+retused to show to the Grand Jury when ahe had to testily
+about then under oath?
+No, sir. I have no knovledge of any other
+- Fax.
+* 1655 Palm Beach Lakes-Bld;, Sulte 500 - West Palm Beach, FL-33401-.--
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 78
+Q.
+A.
+0-
+I don't knou.
+What is bis phone number?
+How Is that relevant?
+What 15 his phone murberr
+9.
+What is his hone address?
+I don't know.
+Where doed he live?
+A-
+0-
+A.
+0-
+In Palm Beach Lakes sonevtere.
+Ever bees to his house?
+Yes.
+You don't know what his address 1s?
+HR. LEOPOLD: 'Objection. Asked and
+anauered. She just said she doesn't know.
+MR. TRIN: Don't coach.
+MR. LEOPOLD: Objection. Asked and
+ansuered.
+BY MR. TEIN:
+Q.
+A.
+A-
+You can ansuer the quescion.
+I don't knou the exact address.
+What street is it on?
+It'a an apartnent conplax: its sot a
+steeet.
+Q-
+What's the naze of the apartnent conplex?
+A.
+Sonething Cove.
+L682.0905 - Fax. I
+'1655-Palm Beach takes Blvd., Sute:500--West-Palm-Deach, FL-33401--
+ánsor & Assocíates
+-Raporag eed-Tanoipoiar, Iss
+Page 80
+girla in this whole sitastian. We're not alloved to know
+each other.
+Q.
+A.
+I didn't get the last four vord».
+Ne'ee not allowad to know aach other.
+And what about
+• Havo you
+of net ber?
+A.
+No, sir.
+Let's see it I can refresh your meacry on
+her. She's the other person represented by your lawyer
+Mr. Slecman, who is suing fpatein tor fifty nillion
+dollars.
+A.
+0.
+A-
+1 have no knowledge ef her.
+Naver set her?
+Never net her.
+A-
+I des't know who that in either.
+A peraon named
+who knous
+Is that
+I don't know, sir.
+Do you renenber making a statenent to
+Detective Pagan thac's in the police ceporta?
+No, sir.
+0.
+Have you read the polien ceports in thin
+caset
+A.
+Yes.
+III.682.0905 - Fax.
+-**1655 Palm Beach Lakes Blvd., Sube 500 - West Palm Beach, Fl: 33401--
+
+
+ansor & Associates
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 81
+They're on the Internet, right?
+Yes, I think.
+0-
+Were you surprised when the police reporta
+were released on the Internet containing your statements
+that you had sade to the police?
+A.
+Tea.
+You didn't want to see that happen, right?
+A-
+No.
+So ya're saying you don't know a
+MR. LEOPOLD: Objection. Asked and
+ansuered.
+BY MR. TEIN:
+0.
+Does it refresh your nemory that he was
+sonebody who had gone to jail for drugs and car theft?
+A.
+No. air.
+Someone who knows
+A-
+No.
+0-
+You don't know if he wet with Detective
+Recarey?
+A.
+A-
+No. air.
+How about
+Yes, I reserber-
+I know who that 1s.
+Did you ever speak to
+happened at Me. Epstein's house?
+about what
+1655 Palm BeschLakes Bivd., Solbe 500~-West Palm Beach, FL-33401-
+Reposing and Transition, Ma
+Did you speak to
+Page 83
+about this
+case?
+A.
+No, sir.
+Have you spoken to
+bout this
+8a6P "
+A.
+No. I don't know who
+Did your parenta apeak to
+A.
+Ask my parents.
+Lat's see if I can refresh your senory as
+to who he is. Okay?
+Uh-huh.
+He'a the Vanity Fair reporter who sade a
+[inanelal arrangesent with your father.
+I am aware of that. And again, I was not
+aware like that my dad did it until after it was done.
+And I don't know the details about that.
+I Just know
+what you know about that, Ilke that they talked.
+0.
+Tell ne what you know about the financial
+arrangenent that
+the Vanity Fair reportar,
+made with your father-
+A.
+I don't know about the details at all.
+0.. How much money did
+give to
+your father?
+I don't even know he gave noney to ny dad.
+0.
+'1655 Palm Beach Lakes Bivd., Suite 500 - West Palm Beach,-FL 33401-—--
+
+ansor & Associates
+Reporting and Tummigro, be.
+----
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page B2
+A.
+Be knows what happened four years ago.
+Ite
+doesn't know this is still going on today.
+What's his address? I'm sorry. I have his
+address.
+A.
+I don't know.
+How sbout
+You know who that ia?
+A.
+I know who that is, yes.
+0-
+He'a the one you stayed out drinking all
+night one night last year when your dad reported you
+adasing?
+A.
+No, sir.
+0.
+Renenber the baseball gaze you vere
+supposed to go to?
+A.
+No, sir.
+bid you speak to
+about this
+case?
+A.
+0.
+No, BiT-
+How about
+That's ny siacer's ex-boyfriend.
+He's the one with the saved-off shotgun
+with the obliterated serial nurber?
+Ask him. I would not know that
+infernation.
+- Fax. 9
+-1655 Falm Beach-Lakes-Old;, Sulte 500--West Palm Beach,-FL-33401~
+Ensor & Associates
+Page 84
+I didn't even know he gave zoney to my dad.
+What do you know about the deal that
+has with your father?
+A.
+I only know they spoke on the telaphone
+once. - I don't know anything else.
+0.
+When was that?
+This uns a while ago, a year or two -. or a
+year ago. I honestly don't know.
+0-
+Did
+the Vanity Fair
+reporter, offer any money to your father?
+A.
+I don't know.
+Bid
+the Vanity Fair
+reporter, give you any nooey?
+A.
+No, sir.
+0-
+Did he offer you any money?
+A. ' Ho, sir. Never spoke to him.
+0.
+What reporters have you apokes to?
+Zero.
+What about your fanily seabers? What
+reporters have they spoken to?
+л.
+The whole Palm Beach County, obviously, as
+you can see in that newspaper.
+0.
+Tell no -- Jet's go through each ane that
+you reseaber. Other than the Vanity Fair reporter,
+what other reporters have any member of your
+--1655 Palm Beach takes Bvd., Suite 500 - West-Palm Beach, FL-33401-
+!
+
+
+15or & Associates
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Entered on FLSD Docket 06/30/2008 Page 23 of 35
+pening as Transcrigtim, las.
+Page 85
+tanily apoken to?
+A.
+I don't know. And I know my ron has spoken
+to zero. Hy sister spoke to tero.
+My father and
+stepnother, I wouldn't know. You'd have to ask then. I
+don't contact then.
+Vell, I Just want to know -. I don't want
+you to -- I want to know what's in your mind. All right?
+IN. LEOPOLD: She Juat told you. She Just
+answered
+MR. TEIN: Be quiet.
+BY MR. TETN:
+What I want to know 1s what you know from
+your personal knowledge.
+Ny queation to you is: What
+knowledge do you have about fanily members of yours
+speaking to reporters?
+MR. LEOPOLD:
+Objectian. Asked and
+answered.
+And if you can't talk professionally, we're
+going to leare.
+MR. TEIN: Do what you want to do.
+MR. LEOPOLD: Are you going to continan to
+talk this way?
+MR. TRIN:
+I'm not going to ansver any
+queation that you ask no, Mr. Seopold.
+HR. AROPOLD:
+Okay.
+•Fax.
+'T655 Palm Beach Lakes Boy sure 500~
+3 Pambeach, FL-33401--
+sane Tusk
+Page 87
+MR. TEIN: Stop engaging ne.
+Make your
+speech and then ve"ll ask the questions.
+HR. LEDFOLD: Hell, you won't let me finish
+naking the abjection, so it's difficult to do
+that. But if you wast to follow with as
+appropriate question, feel free to do that.
+But
+we're nos going to harass the witness.
+MR. TEI: I disagree with averything
+you've said.
+Let's ask the goestions.
+Okay?
+MR. IOPOLD: Ask an appropciate question.
+MR. TBIN: Are you going to stop talking?
+MR. LEOPOLD: I'a going to make - protect
+ay client and make appropriate objectlons. But
+there's not a question peeding eight nou.
+BY MA. TEEN:
+apokan to any reporters?
+A.
+No.
+MR. IE0POLD: Objectien. Asked and
+answered.
+BE MR. TEIN:
+Has
+been given money by any
+reporters?
+A.
+No.
+Has your non spoken to any reporters?
+MR. LEOPOLD: objection./
+Asked and
+- Fax.
+-1655-Palm Beach-Lakes Bivd., Suite 500--West ram-Beach,-FL-33401-
+9
+10
+11
+12
+13
+14
+15
+15
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+4
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 86
+MR. TEIN: But you are alsrepresenting the
+record and you are grandatanding for your ellent
+and It's wrang. So be qulet. And you know how to
+nake an objection. Make 1E. ocherwise stop
+talking-
+BY MR. TEIN:
+MR TEIN: If you vast to leave the
+deposition,
+leave. Bat you'll be back here.
+MA. LEOPOLD: Incuse me. If I could juat
+make the record, instead of interrupting ner
+please. That's what ve do professionally.
+There's a recorder here. I's certainly not being
+obatrucelonist.
+I'm going to nake the record.
+But we're going to act with sone senblance of
+professionalisn, hopefully, by all partles in the
+coon. That goes to an, that goes to your
+co-counsel sitting behind you and next to you, the
+court reporter and everyone else in the coom.
+Everyose is entitled to that.
+You've asked a question. She answered the
+question fully and she's not going to be barassed
+because you don't 15ke the ansues. If you want to
+follow up --
+Fax.
+-1655 Palm Beach LE
+682.1771
+st Palm Beach, FL. 33401..-
+ansor & Associates
+wait and Transplan, Tea.
+Page 8B
+anavered.
+THE MITNESS: No.
+BY MA. TEIN:
+Q. Has your som'a husband
+apoken to any
+reportern?
+A.
+No.
+Has your nos's husband
+zeceived any
+noney from reporters?
+No.
+Q-
+Are you sure you don't know
+MR. LEOPOLD: Objection.
+Asked and
+answered.
+THE WITNESS: I'm positive.
+BY MR. TEIN:
+I'll try again to refresh your zanory.
+A.
+Okay.
+0.
+Doss it refresh your maozy that abe had
+been arrested for drugs and was cooperating with
+Detective Recarey againat Spatein to get herself a better
+deal?
+A.
+No. I den't know who she is.
+Have you apoken to anyose else who's been
+at Epatein's house?
+A.
+No.
+Without telling ne what was said - I don't
+- Fax.
+-=-1659 Palm Beach L8l
+Kes BINd., sute-500
+cim deach, FL 33401--
+
+
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Masonia and fratiant, Jas
+Entered on FLSD Docket 06/30/2008 Page 24 of 35
+ansor & Associates
+Reportag and Treasonipine, Ins
+Page 89
+• want to know about any converastions with any lawyers,
+Uh-hah.
+0.
+-- did you or your parents apeak to any
+other law firme beaides Nr. Herman and Mr. Leopold's Law
+NO.-
+0.
+Now without telling ne about anything that
+was said, what -- did cne juat come to mind?
+A.
+No.
+I was thinking about something else.
+0.
+What wete you thinking about?
+Does farily coast bacter?
+Okay. Mithout telling me what was said,
+who prepared you for today's deposition?
+A.
+What do you mean prepared?
+0.
+Did you talk about this depostion, about
+what woald happen, with anybody?
+*.
+Yes.
+Don't tell ne what was said.
+A.
+0.
+Okay-
+I'm not asking that. I don't want to know
+that.
+A.
+2-
+A.
+okay.
+Mho prepared you for coday's deposition?
+ME. Leopold.
+- Fax.
+1655 Palm sach Lakes Old, Suite 500--West Falm-Beach,-FL-33401-
+2
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 90
+Q.
+Anyhody elae?
+A.
+No.
+When did you neet with Me. Leopold to
+prapare for today'a deposition?
+A.
+This sorning.
+And how long did that meeting last?
+0.
+A.
+Until it started.
+g.
+Now you told ne that you previously had
+read the police reporta in this case?
+A.
+Yes.
+0.
+to the police?
+A.
+Have you read your statement that you gave
+0.
+Yes, sir.
+And in what forn was that atatement?
+A.
+9.
+What do you sean?
+Mas it in the torn at a police report or a
+transcript?
+A.
+What's the difference?
+A transcript has questions and anavers on
+it: A police report is just typed out narrative.
+A-
+Oh, it'a a police report.
+And when did you read the police report?
+A.
+A few days ago. I overread it a few daya
+ago-
+0.
+Had you read it before that?
+'1655 Palm Beach Lakes Bivd., Suite 500-
+rest Palm Beach,-FL-33401——
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Bandag and Touris,
+Page 91
+A.
+No.
+know what was said.
+Now you told ne -- again, I don't want to
+A.
+Uh-huh.
+Tou tald ne that you not with Mr. Leopold
+this morning to prepare for your deposition, righe?
+Yea.
+A.
+0.
+When did you set up that nesting with
+Mr. Leopold to take place this morning?
+A.
+Gee, like, like tive days ago, four days
+Q-
+So you're avare that Mr. Leopold told us
+that he could not start the deposition thia morning
+because he had a court appeacance, correct?
+MR.
+LEOPOLD:
+Don't anaver that question.
+Call» for attorney/client communications.
+BY MR. TEIN:
+9.
+Have you seen the letter that Me. Leopold
+wrote to us stating that he -- an e-mail that Mr. Leopold
+wrote to Mr. Goldberger stating that he could not be here
+this morning because be had a court appearance? Did you
+see that e-mail?
+MH• 2000
+You can anaver that question.
+THE WITNESS:
+- Fax.
+1655 Paim Beach Lakes Bld, Suite 500--West Palm Besch,-FL-33401-..
+-.-
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ansor & Associates
+Repering sad Teasi
+Page 92
+BY IS. TEIN:
+0-
+Have you listened to your tape-recorded
+ataterent to the police?
+A.
+Yes.
+A-
+Where did you listen to that?
+In. I think, this building.
+I don't know.
+It was here.
+A.
+When did you liaten to that statement?
+This morning.
+And who was present when you listened to
+that statenent?
+A.
+Me. Leopold -- and I torget your sane.
+Ns.
+HR. COLDBERGER:
+THE WITNESS:
+Ma-
+BY MR. TEIN:
+0.
+And you hadh't listened to your statement
+before that, correct?
+A.
+No, sir.
+0.
+Have you net with lawyera repsesenting
+anyone aise saing Epatein?
+A.
+No, sir.
+How many times have you spoken to officers
+with the Palm Beach Police Departnent?
+A.
+More than I like can count. It'a been
+ongoing for four years, so qulte a few timen.
+- Fax.
+1655 Palm Beach- Lakes-Bivd., Sulte 500 - West-Palm Beach, FL-33401 ---
+
+
+Entered on FLSD Docket 06/30/2008 Page 25 of 35
+Nepening and Tiencipian, Ja
+ansor & Associates
+Raging and Tarsalyce, Me
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 93
+When was the last tize you apoke with
+officers of the Palm beach Police Department?
+A while ago. I'd say = year ago.
+A year ago?
+A.
+Q.
+A.
+Yeah.
+Muybe a year and a halt.
+Do you resenber Detective Recarey?
+No.
+Do you reseaber
+Detective
+Pagan?
+Yes-
+How many times have you spoken to Deteçtive
+A.
+She was the only one I spoke to about this
+until for sose reason she wasn't on the case anynore.
+When was that?
+The fleat neeting I ever had was with her
+and then I think 11ke I net with her like 10 tines or 12
+tlnes or sopething like that, and than I didn't get --
+another investigator questioned me after that.
+0-
+And who was that?
+I don't renesbes.
+And what type of questions did they ask
+you?
+The sane.
+The sase questions all over again?
+1655 Palm Beatif Lakes Bivü., Suite 500 - West Pain Besch, FL 3340T
+Kapening and Trate
+Page 95
+A.
+I'd have to say like a year and a halt ago.
+a year ago.
+It was a long time ago.
+(Discussion held off the record.]
+NR. TEIN:
+Tell se the last ansver, please.
+(Thereupon, a portion of the reoped vas read
+by the reporter.)
+BY MR. TEIN:
+And who was present when the FBI spoke to
+you at your father's house?
+My atepnother was there, but ahe wasn't
+around.
+She made berself Iike do other things.
+And how many FBI agents were there?
+I think four.
+0-
+A.
+A.
+And you don't resember any of their nanes?
+No, sir.
+And were there any lawyers there?
+Mos that I know of.
+And none of than gave you their cell phone
+numbers?
+And the last time you spoke to the FBI was
+a year and a halt ago?
+A.
+It was a while ago.
+Ma. LEOPOLD: objection.. Raked and
+answered.
+- Fax.
+1655 Palm Beachr Lakes Blvd., Sulte 500v-West Pain Beach, FL 33401-
+10
+11
+12
+13
+14
+15
+16
+17
+10
+19
+20
+21
+22
+23
+24
+25
+3
+9
+10
+11
+12
+'13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 94
+Basically-
+How many taped statewents have you given to
+the police?
+h.
+One that I know of.
+Just the one with
+A.
+Yes,
+How about to the FBI? Did you give any
+statesents to then?
+A.
+No. Nell, actually, I don't really
+rentaber if that was taped or not, to be honese with you.
+I had one meeting with them at my house and don't know if
+it was taped.
+Tou were intervieved at
+house?
+л.
+No.
+That was by the Lawyer.
+Oh, by the lawyer?
+A.
+Uh-huh.
+0. - Share did the converaation that you had
+with the FBI take place?
+A.
+At ny father's residence.
+Which is where?
+A.
+in Locabatchee.
+On where?
+A.
+in Loxahatchee.
+0.
+And when did that take place?
+- Fax
+1655 Palm Beach takes Bivol, Suite 500-West Palm beach, FL 33401
+ansor & Associates
+Page 96
+BY HA. TEIN:
+And the last time you spoke to the Enderal
+prosecutor's office was whea?
+A.
+I don't know.
+Q.
+Did any of the FBI agents tell you that
+had apoken with He. Leopold!
+A.
+No.
+0.
+Did any of the fil agents tell you that
+Villafona had spoken with Mr. Herman?
+A.
+No.
+Did any FBI agents tell you that
+spoke with Mr. Kernan.
+No.
+Did any FBI agents tell you that Jett
+spoke with Mr. Leopold?
+A.
+Bo.
+Do you know whether any of the federal
+prosecutors alloved Mr. Hernan to review a draft
+indictsent?
+A-
+I wouldn't know.
+Do you know if any of the federal
+prosecatara diacussed a draft indictrent with Mr, Herman?.
+A.
+I wouldn't know.
+9.
+Have you ever e-salled with any FBI agent
+or any federal prosecutor?
+1655 Palm Beach Cakes 9ld;, Solter 500 - West Palm Beach, FL 33401—
+
+
+Case 9:08-cv-80119-KAM Document 15-2 Entered on FLSD Docket 06/30/2008
+
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+onsor & Associates
+Ragoning and Tenuiplan, Iss.
+Page 97
+A.
+No.
+Have you ever tent nessaged with any FBI
+agent or any federal prosecutor?
+A.
+No.
+0.
+A.
+Mas the FBI told you about ether testimony?
+No.
+0.
+Has the FBI told you about what other girls
+have said?
+A-
+No.
+Have federal prosecutors told you what.
+other giris have said?
+A.
+No.
+Do you have any way of getting in touch
+with the 5B1 if you vanted to get in touch with then?
+A.
+No.
+0. How about your parestor Do thay know hew
+to get in touch with the FBI?
+A.
+I don't know.
+0.
+And by your parents, I'm referring to both
+sets, okay?
+Oh. Hell, I'm referring to only my dad,
+because ay son coally doasn't care to know any of this
+stuff.
+0.
+So the answer would be the sane for your
+now and
+.0905 - Fax.
+1655 Path Beach Cakes Bivd, Sülte 500 - West Palm Beach, FL'33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ánsor & Associates
+Page 98
+A.
+Teah.
+Deariz about thia case?.
+Have you spoken to a lawyer named burt
+0.
+No.
+Do you know who Bart Ocariz 1s7
+Iet's see if I can zefresh your nasory.
+Does it refresh your manory that he's a good friend of
+boyfriend?
+I don't know who
+the lead federal
+prosecutor that's on the federal part of this case.
+Okay?
+A.
+No.
+So does it refresh your mesocy that Ocarie
+boyfriend?
+is the good friend of
+A.
+Not at all.
+0.
+Does It refresh your senory that
+tried to get Epstein to pay for Ocaria to represent you
+in the federal case?
+A.
+No.
+0.
+with your father?
+A.
+No.
+Do you know if Detective Recazey has spoken
+Q.
+Do you know if Detective Recarey has spoken
+to your stepnother?
+- Fax.
+-1655 Palms Beach Lakes Bivd., Suite-500-
+est Palm Beach, F. 33401--
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24 •
+25
+Repoing and Transpolas, Jee.
+Page 99
+No.
+0. How about with
+A.
+Yes, I would know: and no, she did not.
+Let's put up - let ne ask you some
+questions about the photo that you had pasted on your
+Myspace page before you erased it last week. Okay?
+A.
+Okay-
+HA. TEIN: Do you mind if ve close the door
+a second, please.
+MR. LEOPOLD: Exhibit maber, please.
+MR. TEIN: Put up 25-005.
+Hold on a second.
+NA.
+LEOPOLD: Don't say anything.
+talking to her counsel.
+MA. TEIN:
+Put up 25-006.
+MR. IROPOLD: In that 005 right there?
+MR. TEIN:
+Yes.
+BY MR. TEIN:
+0.
+Who took chia photo of you in a warehosse,
+simulating being gang-raped by a bunch of --
+MR. LEOPOLD:
+objection. Mischaracterizes
+the photograph, and lack of foundation and
+predicate.
+Fully explain if you need to.
+THE WIINESS: I will.
+1,1771
+1655-Palm Beach Lakes Bivd., Suite 500--West Palm-Beach-FL-33401-
+1
+2
+3
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ensor & Associates
+Page 100
+firat off, this is not a warehouse. This
+is in
+
+Second of all, I'a not being gang-raped.
+Everyone has their clothing on.
+Thirdly, If you'd look at all the other
+pictures in that albun, I's deinking -- what'o
+when you're sick you drink 1t7
+You can't ask questions of your counsel.
+A-
+ALl right. I'a drinking like Sprite.
+not drinking any kind of alcobol, If you would look at ny
+other pictures in that albus.
+You guys picked the possibly worst piotures
+out at there to present.
+And it was juat a goofy
+All of these kids like to be goofy. And that'a
+what we were doing.
+0.
+who's the nan on the left of the picture
+holding his -- holding a beer bottle as if it were a
+pania towards your mouth?
+Q.
+Who's the nan behind you, right up towards
+your backside, with you beat over?
+A-
+That one?
+The right side, kissing with his mouth.
+That's
+-1655 Palm Beach Lakes Bivd.; Suite 500--West-Palm Beach, FL-33401-
+
+
+@
+Saponing and Transgine, Int
+
+Вилта: вла прави2
+Page 101
+0.
+Ho's the one grabbing towarda the groin
+area of
+A.
+Yes.
+And there's three other nen in the photo.
+What are their names?
+The one on the left with the hatt
+A.
+That's
+(phonet ie).
+Sailing?
+A.
+Yes.
+Who's the one kissing --
+10
+MR. LEOPOLD: Don't interrupt. Let her
+11-
+finish the cecord. She's testifying.
+12
+NR. TEIN: I know you don't like thla
+13
+picture, my friend.
+14
+MR. LEOPOLD: The picture is fine.
+15
+16
+BY MA. TEIN:
+0.
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Who's the one with the hat?
+MR. LEOPOLD: No.
+Hold en. Stop.
+You have to let the witneas finish her
+She was In the process of explaining and
+you cut hee off.
+Please finish what you'were saying and then
+Couneal can ask you whatever he wishes after chat-
+THE WITNESS: Okay. This guy -
+HA. LEOPOLD: Jost make it no the record 1a
+clear who you're referring to.
+• Fax.
+1655. Palm Beach Lakes 3vd, Sute 500.- west Pam Leach,_EL 33401.
+Rapering as Tananda, /ng
+Page
+103
+to hin at all.
+What's his last nase?
+A.
+0-
+A.
+Q.
+And have you spoken to
+about this
+A.
+No, sir.
+Hae you spoken to
+Not in detall,
+but yes.
+about this case?
+10
+11
+12
+13
+14
+15
+16
+17
+19
+19
+20
+21
+22
+23
+24
+25
+Ace we referring to
+THE WITNESS:. Yes.
+Okay.
+0.
+Have you spoken to
+about this case?
+A.
+Do you have a friend naned
+A.
+I do not have a friend name
+9.
+From freshman year?
+A.
+No.
+Q.
+How about
+A.
+No.
+0.
+Have you spoken to
+about this case?
+- Fax.
+_1655. Palm Beach Lakes Bivd., suite 500 = West Palm Beach, FL 33401
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+9.
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 102
+THE HITNESS: -- on the far left 1s
+BY MR. TEIN:
+of
+He's the one whose bead in nest the groin
+right?
+And in the middle Chere's a man smiling.
+Who's that?
+A.
+0.
+That's
+And who's the one in the red hat, kiasing?
+That's
+phonetic) -
+Let ne atop you for a second.
+Are you
+done?
+A.
+Yes, I'm done.
+0.
+Who is
+My sister's friend. Mell, ahe's a mutual
+friend, but more ny aister's.
+0.
+What Is her last name?
+A.
+2.
+Q.
+A-
+Q-
+- 1655 Palm Beach. Le
+Spell that.
+I don't know how to --
+Have you spoken to her about this case?
+No.
+Who's
+My sister's frlend.
+I don't really speak
+Fax.
+be 500
+ash. f 3340)L
+ensor & Associates
+Repring and Transe
+Page 104
+No.
+0.
+A.
+What's her last name?
+I don't know how to spell it.
+Is she the person whose house you went to
+on lew Year's this yoat?
+A.
+No. I wass't at her hoase on few Year's.
+Where vere you when you took the picture of
+"Can you say blazed, " that's on your website?
+A.
+I wouldn't know or -- wait.
+We vere at a
+birthday party for some girl's 16ch birthday.
+Were you drinking at that party?
+No. Thare was no alcohol or anything
+what does "blase" nean to you?
+A.
+It's like -- it just means like nessed up.
+But we weren't, If you look at the picture.
+Messed up Ilke drunk, right?
+A.
+Sure.
+Who's
+A.
+A girl I knew, like fron like two yeara
+ago.
+0.
+She's the one you were sapposed to be
+staying with when you went drinking with
+A.
+No.
+9.
+Last name?
+-1655 Palm Beach La
+Ite 500
+Beach, FL 33401.
+
+
+Saponing and Transpion, Ine.
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Entered on FLSD Docket 06/30/2008 Page 28 of 35
+lansor & Associates
+Page 105
+A.
+A.
+0.
+A-
+Where does she live?
+I don't know. In Royal Palm.
+A.
+0.
+Uh-bah.
+I's guessing.
+Do you know ber phone number?
+No, I do not.
+Let's look at 25-010.
+See. I'a drinking --
+I'm not asking you about what you're
+drinking.
+Who are the men in this photo who are
+pretending to gang up on you and stab you with knives?
+Who ace they?
+Q.
+Are
+these firenent
+A.
+Are those?
+said the
+two stabbing with knives.
+That's why I said that. I
+don't know. That's
+Are these fleesen?
+A.
+No. They're all on =- except
+they're all on full rights for football.
+Go to 025-015.
+MR. LEOPOLD: 025 dash?
+MR. TEIN: 015.
+- Fax
+1655.Palm.Beach, Lakes Bic., Sute 500 -
+Beach, FL 33401.
+Repenting and Tocrip, Jen
+Page 107
+A.
+Actually, thia is an old Myspace I never
+finished and I never like did anything. I Just kind of
+nade it and lett it.
+So the ansver is yes, you postod thia on
+HySpace?
+A.
+0.
+Yup-
+0o to 25-014. Who took this photo of you
+simulating sex with a vosan?
+HR. LEOPOLD:
+Object to the forn of the
+question. Argumentative.
+THE WITHESS: First off, she's piereing my
+helly button or replereing It, and I'a pretty sure
+it was just like we put up a carera somentece and
+pue a timer on it. He didn't have anybody take
+St.
+BY MR. 3E1N:
+You posted chat on your Myspace page?
+Go to 25-013. In that a photo of you?
+Yep.
+Who's in the photo with you?
+A.
+A.
+Хер-
+0.
+In thin you coning out of the shower?
+- Fasc
+1655. Palm,Beach Lakes Bld, Suite 500 - West Pam Beach, FL.33801
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 10€
+THE WITNESS: Gosh, that's so long ago.
+BY MR. TRIN:
+Who took the photo of you licking the
+A.
+My atepnother.
+Whose idea -- that was your stepnother's
+Idea?
+A.
+It was in Boca di Seppo, whare she works
+currently, and that was before she worked there. And we
+juat thought It would be funny.
+MA. TEIN: 19-007, Can you enlarge that?
+BY MA. TEIN:
+Who took this photo of you simulating you
+having sex with a man?
+л.
+we're not simulating having sex, and
+it'a --ah, and the person who took It was,
+I'm pretty
+but I know him as
+I don't know hia
+last nase.
+0.
+with a man?
+A.
+having sex,
+0.
+Go to 15-006, please.
+Who took this phato of you sinulating sex
+The sane person. And we're not simalating
+Tein.
+Did you post that on the Internet?
+- Fax
+1655.Balm Beach Lakes.., suite 500-West 14m beach, EL 33401..
+ansor & Associates
+Page 108
+A-
+0-
+0.
+A-
+Yes.
+Ara you clothed in this ploture?
+Yeah.
+I have a halter dress on.
+where is that picture taken?
+In
+house.
+Did you post that on the internet?
+Yes-
+All righs.
+MR. TEIN: You can take that dova.
+BY MR. TEIN:
+Now your boyfiland is
+correct?
+A.
+Teah.
+You lie about your age in order to conceal
+something about your relationship with
+isn't that correct?
+A-
+No.
+22 years old, isn't he?
+A.
+0.
+is a firefighter with the Paln
+A.
+Beach Fire Department, right?
+tup.
+Does the Palm Beach Fire Department know
+that your boyfedend is dating an underage giel?
+Actually, mister, it's legal.
+Fax.
+1555.Falm Beach Lakes, wd., suite 500 - W80m Beach, FL 3340]...
+
+
+
+önsor & Associates
+ánsor & Associates
+Repecing and Тилирк, Ise
+Rajering snd Tiasscipfag, doc
+3
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 109
+Wel1 =-
+HR. LEOPOLD: Juat anaver the question,
+THE HITNESS: Yes.
+BY HR. TEIN:
+Dld they know two weeks ago that you vara
+dating an underage qirl (aic)?
+A.
+Yes.
+I met everybody in there.
+0.
+Did they kpow your age?
+A.
+Yes.
+Q-
+Did you lde about your age so that the fice
+department woulde't Chink that
+is connitting a
+crine by having a sexual relatlonship with an ondecage
+gir17
+MS.
+Objection. Aasunen facta
+not in evidence.
+BY MR. TEIN:
+You can anauer the question.
+A.
+No.
+Doas the Pain Resch Polico Departsent Inow
+that
+In having a serual relationahlp with an
+underage qirl?
+MR. LBOPCLD: Don't guess. Anaver If you
+know.
+THE WITHESS:
+Can you repeat the queation?
+FaX.
+1655.Palm. Beach. Lakes.Blvd.; Sute 500 - West Palm Beach, FL.33401
+ns0r & Arsociates
+Repuniag and Te
+Page 111
+THE WITHESS: Never -. what did you say?
+BY MR. TEIN:
+0.
+You Lied when you went to the crack houst
+in Georgia, didn't you?
+LEDFOLD:
+Objection.
+Argunentative.
+Lack of foundation, lack of predicete.
+BY MR. TEIN:
+0-
+A-
+You can ansver the qaestion.
+I have never been to a crack house.
+Who don't you lie to?
+MR. LDOPOLD: Objection, Argumentative.
+Don't ansuer the question.
+MR. IEIN: Certify It.
+...CERTIFIED QUESTION.
+BY MR- TEIN:
+0.
+You don't lie to
+da you?
+MR. LEOPOLD: Objectlon.
+Asked and
+anaueted.
+Don'E ansuer the queation.
+BY NR. TEIN:
+0. - No. You can anaver that question.
+MR. LEOROLD! No. I Jase cold has not to.
+You've asked that queation about five "-
+KA. TEIN: No, I haves't.
+HR. LEOPOLD: Don't anever tha question.
+- Fax.
+1655 Palm. Beach. Lakes. Bhvd., Suite 500 - West Palm Beach, FL 33401
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 110
+DY NR. TKIN:
+0.
+Doss the Pals Beach Police Department know
+that
+a nesber of the Paln Beach Pice Department,
+ia having a sexual relationship with an underage girl?
+I's gueasing no.
+Q-
+You lie about your twin siste:
+don 't
+you?
+BY HR.
+TEIN!
+Q.
+Q.
+habit, eight?
+MR. LEOPOLD:
+objection. Argumentacive.
+Don't you?
+No.
+I have never lied tor ot to
+You lie about the fact that she has a drug
+No. I would never accuse ny sister of
+having a deug habit.
+Q-
+Do you try to conceni the fact that she has
+a deug habit?
+MR. IBOPOLD: objectlon, Argurentative.
+BY MR.
+TEIN:
+0.
+You can ansver the question.
+A-
+No.
+My sister does not have e drag bablt-
+0-
+You Iled when you went to the crack house
+in Gesrgia, didn't you?
+HR.. LEOPOLD: Objection. Argunentative.
+Lack of toandetion, lack of predicate.
+_1655 Palm_Beach Lakes Bivd., Sute 500 - West Palm Beach _FL 33401
+ánsor & Associates
+SPiPEan anE T1
+o, Ips.
+Page 112
+MR. TEIM: 1'11 certify it.
+-CERTIPIED QUESTION..
+HR. IEOPOLD: Tor che record, you have to
+atop isterrupting ne because she can't take doun
+hoth of us talking at the sane time.
+BY MR. TEIN:
+0.
+0.
+0-
+Tou tell
+the truth, don't you?
+Excuse ne?
+You tell
+the trath, don'e you?
+When
+I tell
+the truth.
+Hho 's
+drug dealer?
+My sister dona net have a drug dealer. She
+lives in Georgia with my sother.
+Okay-
+Who is the drug dealer who dropped
+you and
+otE at 5ies Ill.. in 2006, after being out
+all night, the two of you, using drugs at Pala beach
+Country Estates where your father called the police?
+A.
+Q.
+He's the drug dealer?
+A.
+He 1s a
+drag dealer.
+Do you runtaber
+was arrested by the
+Pala Deach Police Deportment and taken to the Juvenil*
+Assessment Center Chat morning?
+A.
+I do renenber chat.
+How betore you sassaged Epatein, you were
+- Fax.
+_1655 Falm Beach Lakes Blvd, Sulte 500 - West Paln Beach, FL 33401
+
+
+aparly an Tramcrgrina, teo.
+
+3
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ánsor & Associates
+Raporag and Thanerigaion, Ine
+Page 113
+involuntarily adnitted into a juvenile educational
+tacilicy; lan'E that right?
+A.
+Did you say involuntarily?
+Yes.
+No. I was willing to go. I -- duly sald
+sure.
+0.
+And you went there because you were lylng
+so auch, no one could contrel you: ian't that corract?
+A.
+That's very incorrect.
+9.
+Now you lie to your parenta all the tine,
+dan't you?
+A.
+Incorrect-
+MA. LEOPOLD: Objection. Argumentative.
+BY MR. TEIN:
+Q.
+Sorry?
+A. Incorrect.
+The day you went to Epstein's house you
+Iled to your father about where yeu weze going/ isn't
+that correct?
+A.
+Carrect.
+0.
+You adnitted to the polise that you told
+your father that you were going shopping, didn't you?
+A.
+Yes.
+0-
+And that was a lie, vasn't it?
+A.
+Yes.
+1655 Paim Beach Lakes Blvd., Sute 500 - West Pelm Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 11
+0-
+And isn't It true that jour fathes has
+aocused you of lying?
+All the tine.
+Didn't your tather thraw you out of the
+house Thanksgiving of this past year beceuse you were
+lying so much to hin?
+Yes, he did klek ne out. No, that'a not
+the reasons why.
+0.
+out of the haune, too?
+A.
+Dida't your father throw your sister
+Tes-
+And he theew her out of the house the weok
+after Thankagivings, right?
+A.
+I dan't know the date, but aure.
+Sounda sbout right?
+A.
+Sure.
+0-
+And the reason he threv her out of the
+house was because she was lying, Coot
+MN. LEOROLD: Objection. Lack of
+foundation. Calls for speculation.
+BY KA. TEIN:
+Q.
+Whan your counsel coaches you, you say it'a
+correct, right?
+I've sever been coached.
+MR. IBOPOLD: Objection-
+Ph
+- Fax
+-1655 Palin Beach Lakes-Bivd., Suite 500 - West Palm Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+nsor Associates
+BARRARA BIS TIL
+Page 115
+BY MR. TEIN:
+Okay. When your counsel that It was there
+was lack of toundation, you agree with your counsel,
+right?
+A.
+I vas Iske saying, "Yeah, Jet'a sove on, "
+because there uns no point to asking that question.
+0-
+Tour father threw
+because she was iying, correct?
+LEDPOLD:
+Objectlon. Lack of
+out of the house
+foundacion.
+Hold on,
+Let se just nske the
+objection-
+Lack of foundation, predicate, calla for
+apeculat.ion.
+BY HR.
+0.
+Anaver-
+A.
+A.
+I'n not ay sister.
+I don't know.
+I want to know what you know enly-
+I don"t know.
+You don't know. That'» your answer?
+Yea-
+Q.
+Now your parenta filed the poliçe report
+regarding Hr. Epatein, righs?
+A.
+Yen.
+g.
+Hou your parenta are also lying, sren't
+- Fax.
+1655 Palm Beach Lakes Bivd., Sulte 500.- West.Palm Beach, E-.33901.
+- . .
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ansor & Associates
+Saging a Тазыгрін, Ано.
+Page 116
+they?
+703 -
+MR. IBOPOLD: Juat so the secord in clear,
+the fathes -- because the mother was up north.
+HR. TEIN: Dos'E testily, Counsel-
+HR. LEOPOLD: So the record is clear, just
+the father. The sother Has --
+HU. TEIN: Counsel, don'E coach and
+testity, please. That's absolately inproper-
+MR. LEOPOLD: You Juat asked the wrong
+question-
+KR. TEIN: You can't coach ber that way and
+you well know It.
+MR: GEOPOLD: For the record, it's the
+father. He'a rensrried, I thint on his third
+marriage.
+NR, TEIN: You cannot -- It's absolutely,
+totally agalnat the rules and you know it.
+MR. LEOFOLD: The satural sother lives in
+Georgia.
+MR. TEIN: You need to belave yourself,
+lawyer.
+MR. LEOFOLD: The natural nother lives in
+Georgia. The father is bare Jecally.
+MR. TEIN: Stop coaching. Stop talking.
+I - Fax,
+-1655 Palm Beach Lakes Bivd., Sulte 500 - West Palm Beact, FL 33401...
+
+
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Entered on FLSD Docket 06/30/2008 Page 31 of 35
+Ragoning and Trancrigion, M
+Page 117
+Tou object. You know the tales. You just
+lectured w about the rules, Counsel. 5o why
+don't you play by the rules? Or only when they
+Cit you? Why don't you grandstand a little noce
+now-
+Give us a five-minute apeech, Me. Leopold.
+MA. LEOPOLD: Are you finished, for the
+record?
+HA. TEIN: I'= not talking to you.
+Do what
+you want.
+MR. LEOPOLD: Don't say anything yet.
+BY HR. TEIN:
+your pacents -
+MR. LEOPOLD: Hold It. Don't say anything
+yet.
+Let no --
+HY MR. TEEN:
+0-
+Your parenta, who filed the police report
+are alao liars.
+MR. LEOPOLD: Don't anaves the question.
+We're not going to araver untll I make the record.
+I vant to put on the record, now that Counsel
+apposes to be finished with his connents for the
+record, that the previous question was
+inappropriate, was intentionally sinleading.
+Now you can ask the question.
+BY NR. TEIN:
+,Ph.
+-1655 Palm Beach Lakes Bld., Sute. 500 - West Palm,Beach, FL.33:401...
+10
+11
+12
+13
+14
+15
+16
+17
+16
+19
+20
+21
+22
+23
+24
+25
+Page 118
+0.
+Your parenta, who filed the police report
+In this case, are also proven liara, aren't they?
+MR. LEOPOLD: Sane objection.
+BT HA. TEIN:
+0-
+Aren't your parents llars?
+MR. LEOPOLD: Calla for apeculation. Lack
+of predicate.
+MR. TEIN: Stop coaching. You know what
+that is, Leopold.
+HR. LEOPOLD: Calls for speculation. Lack
+of foundation.
+THE WITNESS: When you say parenta, my son
+la not, but sure, yeah, ay dad has bean to jail
+for lying.
+BY MR. TEIN:
+0.
+Your dad weat to federal prison for two
+years for lying, =ight?
+A.
+Correct.
+0.
+Did he tell you it vas for a financial
+fraud?
+A.
+Yes.
+For stealing money from some financial
+institution?
+A.
+Q.
+Correct.
+And do you think your father in trying to
+-1655-Palm Beach Lakes
+• Fax
+Suite 500.- West.Palm.Beach, FL 33401,
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Bering and Tannipin, Ja,
+Page 119
+steal your lawsuit soney away froa. you?
+Don't look so your lawyer for the answer.
+MR. LEOPOLD: Yoa can answer if you know
+the answer to it. I have no idea.
+THE WITNESS: Yeah.
+BY MR. TEIN:
+And your father filed a lawsuit, the fiest
+lawsuit for titty million dollars açainst Mr. Epatein
+without consalting you, correct?
+A.
+Correct.
+And your father had a lawyer file the first
+Jawsuit on your behalt for fifty million dollars against
+ME. Epstein without your knowledge, correce?
+A.
+COrreCt.
+0.
+And you don't trust your father, do yout
+A.
+Carac.
+9.
+And you believe he's trying to manipulate
+you tor his oun gain, don't you?
+A.
+Sort of.
+0.
+Wel1, you know that your mother filed a
+statesent, an affidavit, saying that you don't trust you=
+father and that you belleve he's trying to manipulate you
+for his own gain; isn't that correct?
+A.
+Correct.
+0.
+You agree with that statement, don't you?
+- Fax,
+1655 Palm Besch Lakes Bivd., Suite 500 - West. Palm Beach, FL. 33401
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+insor Apsociates
+Page 120
+Uh-huh. Tes.
+0.
+A.
+Do you trust your stepnother?
+My stepmother, no.
+Toa think abe's aleo trying to steal your
+Epstein lawsuit money away from you, don't you?
+A.
+I would like to clarity something. You
+keep saying ay Epstein lawsuit money. I don't have any
+noneyand it's just a lawsuit at the moment. So I Just
+don't trust her.
+0-
+Olay. You think that your stepmother is
+trying to take advantage of this lawsuit to try to get
+money fron Me. Epstein that belongs to you, right?
+A-
+Did your atepnother tell you why she was
+arrested?
+A.
+No.
+ever been arrested?
+No.
+Did your stepmother tell you that she's
+Did she tall you she was arrested for
+fraud?
+A.
+Never.
+Hawthorne Aviation?
+Mo.
+Did ahe cell you that ahe was fired from
+1- Fax.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401.
+
+
+Entered on FLSD Docket 06/30/2008 Page 32 of 35
+loposing and Transcripelen, Ies
+ansor & Associates
+Repandag and Tes
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+10
+11
+12
+13
+14
+15
+15
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 121
+Did she tell you that abo was fired fron
+Hauthorne Aviation for stealingt
+A-
+No.
+HA. TEIN: Let's take a break.
+(Thereupon, a recess vas taken.]
+BY HR. TEIN:
+before you net Jeffrey Epstein, had
+you ever had sexual intercoures?
+Yes, yeah-
+0.
+How many times?
+Just a tow.
+Twice.
+With how many different men?
+A.
+Two.
+How old vete they?
+being one year older than ne.
+and then the other person was two yoars older than me.
+0-
+What was his name?
+low old were you when you first had sexual
+Intercourse?
+A.
+14.
+How many -- before you net Epstein, haw
+many different men had you had any type of sexual
+actlvity with?
+Juat those two.
+Fax.
+582.1771
+'1655 Palm Beach Lakes Bid., Sure 500-
+west Palm. Beach, EL.33401.
+Page 123
+Laser color copied so that we have a copy, and I'n
+assuning he'll get 4 copy to the court reporter,
+too, to attach, actually a certified copy to the
+depoaltion.
+MR. GOLDBERGER:
+Done.
+MA. LEOPOLD: That's if you agree to chas.
+If not, then I want to pull each one out and put
+exhibit labels on then, which ve should do before
+we leave.
+MR. COLOSENGER: We're not going to do
+either. I'll have copies sent to the court
+reporter and she can attach then to the
+deposition.
+MR. IEOPOLD: So you're not going to agree
+to what we talked about daring the break than.
+MR. GOLDBERGER: I'a not quite sure bat
+your asking an to do. Tet ne finish.
+Ma. LBOPOLD: Okay. Sure. That's Line.
+MR. GOLDBERGER: Okay. If you want me to
+go over to Ma. M
+Il office and make copies
+and then I'1l give those to the court reporter,
+- tine. A11 I'm saying Is that I would avoid that
+process. I would send copies to the court
+raporter. Bat If it will nake you happier --
+MR.
+LEOPOLD:
+I'm not?
+1655 Palm Beach Lakes Evo.
+Beach, FL 33401
+Q
+Page 122
+0.
+than those two?
+Are you saying you never kiased a man other
+3
+1
+6
+MA. LEOPOLD: Objection to the form of the
+question.
+THE WITNESS: Yes, I had kissed people
+before.
+BY MX. TEIN:
+Before you net Epstein, had you ever had
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+oral sek?
+A.
+No.
+Q.
+for roseching of value?
+A.
+Ever in your life, have you exchanged sex
+MR. TEIN: We're done.
+THE WITNESS: Oh, okay.
+MR. ISOPOLD: Ne'll read.
+NS. lll I don't have way
+questions. Thank you.
+MR. LEOPOLD: Before ve ço off the record,
+It's my understanding -- Mr. Goldberger can
+correct the recoed -- but we have stipulated that
+color coples of the docurents chat were Identified
+tor Identification certainly will be attached to
+the deposition and counsel will be taking the
+photographs across street ao that they can be
+Fax.
+1655-Palm Beach Lakur
+sure 500
+ach, FL33401-.
+g ні Taserini, Jea
+Page 124
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR. GOLDBERGER:
+Let ne finiah.
+MR. IBOPOLD: I'n not interrupting nom-
+MR. GOLDBERGER:
+Pat It it will make you
+happies it I go over to Ns.
+In office
+and make a copy of those photos that vese part of
+this deposition and then I'll give thea to the
+court reporter, I'll be happy to do it.
+MA. LEOPOLD: I trust you Inplleltly.
+hovever you with to do it. Hoverer, the
+docusants, betore they leave this room, need to
+have an exhiblt sticky on then with the
+appropriate **
+MA. GOLDBERGER: Hant to go get some? fe
+don't have any.
+MR. LEOPOLD: I wil1 do that. Excuse me.
+Let se finish the record, please. You can't do
+that to the court reporter. She's going to stroke
+out.
+You can't do that. You have to let no -
+MA. TEIN: Finish your sestence, Ted. - Tou
+are the most Long-winded lawyer I've ever seen in
+ay lite. Finish your sentence.
+MI. LEOPOLD: Jack, tell him not to raise
+his voice, please.
+MD. TETH:
+Finish your sentence. Is there
+going to he a perlod at the end of the sentence or
+-1655 Palm Beach L
+each, FL 33401
+
+
+ánsor & Associates
+legaiing an Tres pilme, I0
+Page 125
+in it just going to be cosna after conna after
+coma7
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Go shead, lawyer-
+MM. LEOPOLD: All right. The exhibica, I
+can't prevent you trom taking them, but I will
+object and I will be bringing It to the court for
+sanationa. You cannot take the exhibits out of
+the coom without than being nacked. I want then
+macked, because you carnot Identify in the record
+what was ased.
+And with all due respect to
+Mr. Goldberger, I do sot -- the way this
+deposltion is going, I do not vant to tely on
+Caunael fron Mianl to nark the appropriate
+exhibite. I will not do that. I cascot prevant
+you fron taking then. Bat if you do, I vill be
+bringing the matter to the court with appropriate
+sanctions, because that is improper.
+That is
+imprope=. Wien you use soasching in a deposition,
+they are to be narked.
+And you hare refused to do
+that throughost for what aves reason.
+KX. TEIM: You'ze wrong- Fisiah your
+sentence because you're talking about sonething
+you have no ides.
+Every single. coe Is narked, Ted. Every
+single one ia already marked. But you wast to
+- 1655 Palm Beach Lakes Blvd, Zuite 500 - West Palm Beach, FL 33401
+ánsor & Associates
+Rapsning eni Toserljalcs, Je
+Page 127
+finish. Tou behave-
+MR. IEOPOLD: Don't point your finger at
+ne.
+MR. TEIN: Listen. Be quiet and I von't
+have a need to point it at you.
+MR. LEOPOLD: Don': point your tinger at -
+MR. TEIN: Me. Leopold *-
+NR. LEOPOLD: Don't podnt your finger at
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+se.
+MR. TEIN: Me. Leopold, let ne tinish-
+Hi. IBOPOLD: Don'E Ialse your voice
+aither.
+MR. TEIN: Mr. Leopold -.
+LEDPOLDI Jack, do you want to take
+care of thia?
+MR. IEIN: tet ne finish sy sentence. The
+axhibita are narked. Ke are walking out of here.
+You are soneone who aiarepresents the •
+record. It is abaolately atrocious what you do-
+That is not how a Lawyer ahould behare. Thia
+deposition ia over. You will get your exhibita,
+Mr. Leopold.
+MR. GOLOBERGER: I inderstand what you're
+saying, Hichani, and I understand Ted'a position.
+Juat so there'» -- ve'te going to have lots
+- Fax
+-1655 Palm. Beach Lakes Blyd., Sute_500 -
+Beach, FL 33401 :
+Entered on FLSD Docket 06/30/2008 Page 33 of 35
+ánsor & Associates
+Hainai w Tos imm
+:
+10
+5
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 125
+gegue about avezything. Ever single one js
+aiready sarked. Tan't that ailly, Ted?
+MR. GOLDBERGER: Thirty years of doing this
+and 1 have never had an argusent over this.
+HR. TEIN: Tou've sade -. Ted, you are
+obatructionint, you are a liar. You have lled and
+misrepcesented things, for the receed. You are
+grandstanding.
+MN. IBOBOLD: You need to back up.
+HR. TRIN: No, no. I'n goirg to finish-
+HR. LEOPOLD: You can finish, but don't
+MR. TEIN: No one is hovering over you.
+Stop trying to neke a lying record.
+Let ne say sonething else.
+Den't you dare threaten se with sanccions,
+after you lied in a letter to my co-counsel about
+the tact -- be qulet. De quiet and lec eo finiah.
+You liad in a letter to ay co-counsel,
+He. Leopold, in which you said =. it vas a
+complete and utter lle -- that you were
+unavallable chis morning because you bad a
+hearing. That was a 1ie. I have paver seen »
+lavyer deign to do sonething like that.
+So you will get the ex -- be gulet. Let =e
+-1655.Palm Beach La
+Re 500.-
+west Pamn Beach, FL 33401
+ansor & Associates
+SARMTAT BR TERNRIORON
+Page 128
+of issuer ia thio case. Se'ze going to have lota
+of reasons to disagree.
+I'a going to take it over sow and I'm going
+to Hake coples and I'm going to give then to
+Ms. Consor. If you want to go Eind some exhibit
+Jabels and put scon exhiblt labels on 1E, be ny
+guest. Dut Chat's what I'n offaring to do.
+THE MITNESS: Let ne say tuo things,
+because I as happy to alwaya disagree, and with
+you, I hare no preblen: we cosid always do 1t
+profesaionally. I have not probles.
+I vant co say two things so the cecord ls
+very clear.
+Since tor whaterer ceason I have not been
+able to leok as eshibits, because they have boen
+refused to have been shoun to ne --
+HR. TEIN: That's a lle.
+NR. 1B0EOLD: - Jack, If you represent
+that the docunonta bave the appropriate exhibat
+minbers er sowe identifying markings, 23, 30.000,
+whatever they nay be, then yoa can take them, sake
+copies, send nt a copy, nake sure thn court
+reporter geca a copy and then send me a bill for
+my copies, that'a fine. I didn't knaw that they
+are narked that way becaus I haven't been able to
+.0905 - Fax.
+1655 Palm. Beach Laxes
+Bivd, Sulte 500 - We
+deach, FL 33401.
+
+
+
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 129
+look at them-
+M3. GOLDBERGER: They are barcoded, and the
+number that we've sade reference to in the
+depositlon coincides with the barcoding.
+MR. IZOPOLD: That's fine. Eight by eleven
+color laser copies arn fine.
+MS. BELOHLAVEN: The State Attorneya Office
+is not going to chaege anybody for color copies 1
+print out.
+MA. LEDPDLD: That's fine. He's going to
+take then back to his afflee.
+Secandly -- and I will be more than happy
+to do it, because it sounds like you all know more
+about it chan I -- bet I'm happy to get affidavita
+tron ME. Pincus, Judge Stern, erecybody olae about
+what happened with this hearing today, because I
+know very Iletle about it.
+But ay representationa
+ace what they are-
+MR. GOLOBERGER: They stay -
+MR. LEOPOLD: Let ne İsat finish Ioc the
+My representations or consents about what
+happened, representatlon about this bearing this
+morning, 1 know very liecle about it. I --
+MR. GOLDBERGER!
+I'll take your word on
+1655, Palm Beach Lakes, Bled a:
+- West Palm Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 130
+that.
+MA. LEOFOLD: No, no, no. I Just put it on
+the record. I Will get an affidavit - 1'=
+assuming It sounda like you need it —- from Mr.
+Pincus.
+I have no cise about what happened and
+why it was canceled. All I was told when I was
+out of town yesterday was that the hearing this
+morning was cancellad.
+MA. GOLDBERGER:
+I'll take your word for
+it.
+eN. 1BOPOLD: If you want an affidavit.
+I'll get le doc you-
+MR. GOLDBERGER: It's a personal issue for
+ne because I had to disrupt a vacation and if is
+vas done Just because it wasn't convenient for
+you, then I'm offended by that. But if you're
+telling me that it was planned and it didn't
+happen, I'll take your word for it.
+MA. LEOPOLD: I am nore than happy to get
+you an aftidarit, because I don't know the reason
+why it was canceled other than the fact that 1'=
+assuming #ince my deposition was taken for four
+hours on Honday for preparation for the hearing
+today, for whatever reason it vas canceled, I am
+told It is being re-noticed. Why it wan canceled,
+1655 Palm. Beach_Lal
+0905 - Fax.
+Suite 500
+each, FL. 33401
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+sing and Tre
+Page 131
+I have no idea, but it your co-counsel wishes an
+affidavit to that effect feon Mr. Pincus, I'a nore
+than happy to get it. Bat I don't know the reason
+why it was canceled.
+MA. TEIN: I don't need it. But what I do .
+cake issue with is regardless of why it vas
+canceled, you owed us the courtesy of saying, Top
+know what? We can start earlier this morning.
+HR. LEOPOLDI
+I ove you nothing.
+MR. TEIN: I don't care. Don't interrupt
+because of you.
+Because Jack canceled his vacation plans
+MR. QOLOBERGERI That'a all right, that's
+all right.
+HR. TEEN: And you're selfiah. And this
+deposition is over. Good-by Mr. Leopold.
+MR. GOLDBERGER: You can go off the record.
+ansor & Associates
+Reponing and Teamrigi, Nee
+Page 132
+CENTIFICATE
+The State of Florida,
+County of Pain Beach-
+I hereby certify that I have read the
+toregoing deposition by ne given, end that the statementa
+contained herein are trun and correct to the beat of my
+knowledge and bellef, with the exception of any
+corrections or rotationa sade on the errata sheet, it one
+was executed.
+pated this _day of
+2008.
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+C
+• Fax.
+1655 Palm.Beach Lakes Bivd., Suite 500 - WeSt
+Beach, FL 33401
+1655 Palm Beach Late
+ach, Fl. 33401
+
+
+
+10
+11
+12
+13
+14
+15
+16
+17
+1B
+19
+20
+21
+22
+23
+24
+25
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ansor & Associates
+Перипіяд амі Трірім, 1н;
+Paye 133
+RATE: February 25, 2008
+office of ta StatE
+401 M. Dixie. Highway
+West Palm Beach, Florida 33401
+IN BE:
+STATE OF TLORIDA 1
+JEFFREY EPSTEIN
+CASE NO.:
+2006 CF09454AXX
+Pleaso take notice that on Wednesday, the
+20ch of February, 200B, you gave your deposition in the
+above-referred matter.
+At that time, you did not walve
+signature.
+It 1a now necessary that you sign your
+deposition.
+Please call our office at the below-listed
+number to schedule an appointment between the hours of
+9:00
+and 4:30 p.z., Honday through Friday.
+It you do not read and sign the deposition
+within a reasonable time, the original, voich has already
+been forwarded to the ordering attorney, say be filed
+with the Cleck of the Court.
+It you wish to waive your
+signature,
+sign yout nabe in the blank at the bottun of
+this letter and return it to us.
+Very truly yours,
+Jodith F. Consor, FPR
+Consor 4 Associates Reporting and Transcription
+1655 Pals Beach Lakes Boulevard, Suite 500
+West Falm Beach, Florida 33401
+I do hereby waive my signature:
+oc via transcript:
+JACK A-
+GOLDBERGER, ESO.
+ESO-
+MICHAEL R. TEIN,
+ESQ.
+THEODORE J. LEOPOLD, ES0.
+t5le copy
+Ph
+1655. Balm Beach Lakes Bivd., Suite 500 - West Palm Beach, FL 33401
+Repening and Therapise, Me.
+Page 135
+THE STATE OF FLORIDA, !
+COUNTY OF PAIN BEACH.
+I, the undersigned authority, certify that
+peraonally appeared before su on the 20th
+of Fabruary, 2008 and was duly aween-
+wITNEsS my hand and offiedal seal thie 25 day
+of Eebruary, 2008.
+Jodith F. Consor, FPR
+Notary Public - State of Florida
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 134
+SHEET
+IN RE:
+STATE-|
+-JEFFREY EPSTEIN
+DEPOSITION DE:
+200฿
+TAKEN: February 20th,
+PAGE
+DO NOT HHITE ON TRANSCRIIT - ENTER CHANGES HERE
+LINE 1
+CHANGE
+Please forward the original siqoed errata shoot to this
+office so that copies nay be distributed to all parties.
+Under pensity of perjury, I declare that I have read my
+deposition and that it la true and correct subjeot to any
+changes in fore or subatance entered here.
+DATE:
+SIGNATURE OF DEPONENT:
+Ph
+- Fax,
+1655. Palm Beach Lakes Had Suite 500
+* Beach, F. 33401
+ansor & Associates
+Rapping sed Tonerigion, Ime.
+Page 136
+CERTIFICATE
+The state of Florida, 1
+County Of Pala Beach.
+I,
+Judith f. Consor, Court Reporter and Notary
+Public in and for the State of Tlorida at large, do
+hereby certify that I was wuthorized to and did
+stanographically report the deposition of
+that a review of che transcript was requested;
+and Cle
+the foregoing pages, numbered from 1 to 131, Inclusive,
+ace a true and correct transcription of ny stenographic
+notes of said deposition.
+I further certify that said deposition was
+taken at the time and place hereinabove set forth and
+that the taking of said deposition was commenced and
+completed as hereinabove set out.
+I further certify that I an not an attorney or
+counsel of any of the partles, nor an I a relative or
+employee of any attorney or counsel of party connected
+with the action, nor an I financially interested in tha
+action.
+The foregoing certification of this transcript
+does not apply to any reproduction of thn aame by any
+means unless under the direct control asd/or direction of
+the certifying reporter-
+INTED this 25 day of February,
+Judith F. Consor, Court Repoi
+Florida Professional Reporter
+1655 Palm Beach Lak
+- Fax.
+Suite 500 -
+Palm Beach, FL 33401
+1655 Pair Beach Lak
+- Fax
+te 500-
+est Palm Beach, FL 33401
+
+
+Case 9:08-cv-80119-KAM Document 180
+Entered on FLSD Docket 06/24/2009 Page 1 of 51
+1
+WEST PALM BEACH DIVISION
+CASE NO. 08-80119-CIV-MARRA
+WEST PALM BEACH, FLORIDA
+1
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+JANE DOE, et al.,
+Plaintiffs,
+JUNE 12, 2009
+vS.
+JEFFREY EPSTEIN,
+Defendant.
+TRANSCRIPT OF MOTION HEARING
+BEFORE THE HONORABLE KENNETH A. MARRA,
+UNITED STATES DISTRICT JUDGE
+APPEARANCES:
+FOR THE PLAINTIFFS:
+ADAM D. HOROWITZ, ESQ.
+Mermelstein & Horowitz
+18205 Biscayne Boulevard
+Miami, FL 33160
+For Jane Doe
+305.931.2200
+BRADLEY J. EDWARDS, ESQ.
+Rothstein Rosenfeldt Adler
+401 East Las Olas Boulevard
+Fort Lauderdale, FL 33301
+954.522.3456
+ISIDRO M.
+ESQ.
+Elkins Boehringer
+224 Datura Avenue
+West Palm Beach,
+FL 33401
+Jane DOE II
+RICHARD H. WILLITS, ESQ.
+2290 10th Avenue North
+Lake Worth, FL 33461
+For C.M.A.
+TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTIOI
+
+10
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009
+
+2
+1
+2
+3
+ROBERT C. JOSEFSBERG, ESQ.
+Podhurst Orseck Josefsberg
+25 West Flagler Street
+Miami, FL 33130
+For
+305.358.2800
+(Via telephone)
+KATHERINE W. EZELL, ESQ.
+Podhurst Orseck Josefsberg
+25 West Flagler Street
+Miami, FL 33130
+For
+305.358.2800
+ROBERT D. CRITTON, JR., ESQ.
+MICHAEL BURMAN, ESQ.
+Burman Critton, etc.
+515 North Flagler Street
+West Palm Beach, FL 33401
+6
+7
+8
+FOR THE DEFENDANT:
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+REPORTED BY:
+22
+23
+24
+25
+JACK A. GOLDBERGER, ESQ.
+Atterbury Goldberger Weiss
+250 Australian Avenue South
+West Palm Beach, FL 33401
+1, ESQ.
+Assistant U.S. Attorney
+500 East Broward Boulevard
+Fort Lauderdale, FL 33394
+FoI U.S.A.
+MARTIN G. WEINBERG, ESQ.
+20 Park Plaza
+Boston MA 02116
+(Via telephone)
+JAY LEFKOWITZ, ESQ.
+(Via telephone)
+617.227.3700
+LARRY HERR, RPR-RMR-FCRR-AE
+Official United States Court Reporter
+Federally Certified Realtime Reporter
+400 North Miami Avenue, Room 8N09
+Miami, FL 33128
+305.523.5290
+
+
+Case 9:08-cv-80119-KAM Document 180
+Entered on FLSD Docket 06/24/2009 Page 3 of 51
+THE COURT: We are here in the various Doe vs. Epstein
+3
+1
+2
+3
+4
+5
+cases.
+May I have counsel state their appearances?
+MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs
+THE COURT: Good morning.
+MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane
+7
+8
+Doe.
+9
+THE COURT: Good morning.
+10
+11
+MR.
+: Good morning, Your Honor. Sid
+foI
+12
+THE COURT: Good morning.
+13
+MR. WILLITS: Good morning, Your Honor. Richard
+14 Willits, here on behalf of the plaintiff C.M.A..
+15
+THE COURT: Good morning.
+16
+MS. EZELL: Good morning, Your Honor. I'm Katherine
+17| Ezell from Podhurst Orseck, here with Amy Adderly and Susan
+18| Bennett, and I believe my partner, Bob Josefsberg, is going to
+19
+appear by telephone.
+20
+THE COURT: Mr. Josefsberg, are you there?
+21
+MR. JOSEFSBERG: I am, Your Honor.
+22
+THE COURT: Good morning.
+23
+MR. JOSEFSBERG: Good morning.
+24
+THE COURT: All right. Do we have all the plaintiffs
+25
+stated their appearances?
+Okay.
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 4 of 51
+4
+1
+Defense?
+2
+MR. CRITTON: Your Honor, Robert Critton on behalf of
+3 Mr. Epstein, and my partner,
+Michael Burman.
+4
+THE COURT: Good morning.
+5
+MR. GOLDBERGER: Good morning, Your Honor. Jack
+6
+Goldberger on behalf of Mr. Epstein.
+7
+THE COURT: I see we have some representatives from
+the United States Attorney's Office here.
+MS.
+Good morning, Your Honor. Ann
+for the U.S. Attorney's office.
+THE COURT: Good morning.
+Who else do we have on the phone?
+MR. CRITTON: Your Honor, we have two members of the
+defense team are on the phone, also.
+THE COURT: Who do we have on the phone?
+MR. WEINBERG:
+Martin Weinberg. Good morning, Your
+9
+10
+11
+12
+13
+14
+15
+16
+17 Honor.
+18
+19
+Honor.
+20
+21
+22
+23
+24
+25
+MR. LEFKOWITZ: Jay Lefkowitz. Good morning, Your
+THE COURT: Good morning.
+I scheduled this hearing for very limited issues
+which, as you all know, there's been a motion by Mr. Epstein to
+stay the civil proceedings against him. The one issue I have
+concern about is Mr. Epstein's contention or assertion that by
+defending against the allegations in the civil proceedings, he
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 5 of 51
+1
+may expose himself to an allegation by the United States in the
+2
+non-prosecution agreement that he's violated that agreement and
+3
+therefore would subject himself to potential federal charges.
+4
+I had asked for some briefing on this. I asked the
+5
+United States to present its position to me. And I received
+6
+the Government's written response, which I frankly didn't find
+7
+very helpful. And I still am not sure I understand what the
+8
+Government's position is on it.
+9
+So first let me hear from Mr. Epstein's attorneys as
+10
+to what do you believe the concern is. I don't believe the
+11
+non-prosecution agreement has ever been filed in this Court; am
+12| I correct?
+13
+MR. CRITTON: To my knowledge, Your Honor, it has not.
+14
+THE COURT: So I don't believe I've ever seen the
+15
+entire agreement. I've seen portions of it.
+16
+MR. EDWARDS: Your Honor, I believe that it was filed
+17
+under
+vs. United States of America, case under
+18 seal in your court.
+19
+THE COURT: Okay.
+20
+MR. EDWARDS: In a separate case.
+21
+THE COURT: In that case, okay. Was it actually filed
+22 in that case?
+23
+MR. EDWARDS: I filed it under seal.
+24
+THE COURT: In any event, what's Mr. Epstein's concern
+25
+about if you defend the civil actions, you're going to expose
+5
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 6 of 51
+6
+1 yourself to a claim for a breach by the United States of the
+2
+non-prosecution agreement?
+MR. CRITTON: Robert Critton.
+4
+Your Honor, our position on this case is, I'd say is
+5
+somewhat different. When this issue originally came before the
+6
+Court, as you are aware prior to my firm's involvement in the
+7 case, there was a motion filed on behalf of Mr. Epstein seeking
+8 a stay. And I think it was in
+and then
+9
+subsequently
+because all of those cases
+10
+were filed on or about the same time.
+11
+And at that time the Court looked at the issue and it
+12
+was based upon a statutory provision at that time. And the
+13
+Court said I don't find that it's applicable, or for whatever
+14
+reason I think the Court said I don't consider that to be a
+15
+pending proceeding or a proceeding at that particular time.
+16
+In that same order, which was in
+17
+believe it's -- not I believe, I know it's docket entry 33, the
+18
+Court also went on to talk about at that particular point in
+19
+time dealt with the issue of the discretionary stay.
+20
+And the Court said at that time, I'm paraphrasing, but
+21
+the Court also does not believe a discretionary stay is
+22
+warranted. And what the Court went on to say is that if
+23
+defendant does not breach the agreement, then he should have no
+24
+concerns regarding his Fifth Amendment right against
+25
+self-incrimination.
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 7 of 51
+7
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+The fact that the U.S. Attorney or other law
+enforcement officials may object to some discovery in these
+civil cases is not in and of itself a reason to stay the civil
+litigation, so that any such issue shall be resolved as they
+arise in the course of the litigation.
+And I would respectfully submit to the Court that the
+position that the Government has taken in its most recent
+filings changes the playing field dramatically. Because what
+the Government in essence has said as distinct from the U.S.
+saying is, well, we object to some discovery, or we may object
+to some discovery in the civil cases.
+What they have,
+in essence, said is if you take some
+action, Mr. Epstein, that we believe unilaterally, and this is
+on pages 13 and 14 of their pleading or of their response memo
+to the Court's inquiry, they say if Mr. Epstein breaches the
+agreement. They said it's basically like a contract, and if
+one side breaches, the other side can sue.
+In this instance what the Government will do is if we
+believe that Mr. Epstein has breached the agreement, we '11
+20 indict him. We will indict him. And his remedy under that
+21
+circumstance, which is an incredible and catastrophic catch 22
+22
+is, we'll indict him and then he can move to dismiss. That's a
+23
+great option.
+24
+In this particular instance my mandate in defending --
+25
+and that's a dramatic change in the Government's position,
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 8 of 51
+8
+1
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+because the Government is not saying, and the Court was pretty
+specific in what you asked the Government for in its response
+is, in essence, and it's the same question in a more limited
+fashion you're posing today is whether Mr. Epstein's defense of
+the civil action violates the NPA agreement, the
+non-prosecution agreement, between the U.S. and Mr. Epstein.
+And the Government refuses to answer that question.
+They won't come out and say, yes, it will, or no, it won't.
+What they're doing is they want to sit on the sideline, and as
+their papers suggest is, they want us to lay in wait and that
+if, in fact, they believe he violates a provision of the NPA as
+it relates to the defense of this case or these multitude of
+cases, then they can come in and indict him -- no notice, no
+opportunity to cure.
+We don't think that's what the NPA says, but that's
+certainly what their papers say. We'll indict him, no notice,
+no opportunity to cure. We will indict him, and his remedy
+under that circumstance is that he can move to dismiss the
+indictment.
+Well, that's great except Mr. Epstein, his mandate to
+me and I know his mandate to his criminal lawyers, is: Make
+certain I don't do anything, in particular in these civil cases
+that would in any way suggest that I am in willful violation of
+the NPA.
+Now, in the Court's prior ruling in the docket entry
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 9 of 51
+9
+1
+33, certainly some aspects of the NPA are within Mr. Epstein's
+2
+control. There's no question about that. But aspects that
+3
+relate to the defense of these cases, either in terms of the
+4
+civil lawyers who are defending these, I think there's 12 or 13
+5
+pending cases in front of you, there's another four cases in
+6
+the state court, is the risk is substantial, it's real, and it
+7
+presents a chilling effect for the civil lawyers in moving
+8
+forward to determine whether or not we're taking some action
+9
+that in some way may be a violation of the NPA.
+10
+And the Government's, again, refusal or non-position
+11
+with regard to past acts
+that have been taken in the civil case
+12
+with regard to the defense
+or future acts that we may take with
+13
+regard to these contested litigation casts an extraordinary
+14
+cloud of doubt and uncertainty and fear that the defense of
+15
+these cases could jeopardize Mr. Epstein and put him in the
+16
+irreparable position of violating the NPA and then subsequently
+17 being indicted.
+18
+In this particular instance, again, Mr. Epstein has no
+19
+intention of willfully violating the NPA, but it's of great
+20
+concern to him. And I'd say with the position that the
+21
+Government has taken, no notice, no cure period, no opportunity
+22
+to discuss. Again, we think that's not what the NPA provides,
+23
+it's not what the deal was between the two contracting parties,
+24
+the United States and Mr. Epstein. But that's clearly what
+25
+their papers say under the circumstances, and it would create
+
+
+Case 9:08-cV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 10 of 51
+10
+1
+this irreparable harm to Mr. Epstein under the circumstances.
+2
+In essence, we're left with a catch 22 in defending
+3
+the civil cases.
+We have a mandate to take no action, to take
+4
+any action which may be deemed to be a violation of the NPA,
+5
+either in the past or in the future, which would in any way
+6
+risk Mr. Epstein being indicted by the United States.
+7
+He has the clear risk of an indictment based upon the
+8
+papers that the Government filed. It's real, it's not remote,
+9
+and it's not speculative. It chills the action of the defense
+10
+in this instance of both Mr. Epstein and his attorneys in
+11
+trying to defend these cases and decide under the circumstances
+12
+can we do this, can we take this position with regard to
+13
+depositions, can we take this legal position with regard to
+14
+motions to dismiss, with regard to responses, with regard to
+15
+replies?
+16
+And we send out paper discovery. Is this in some way
+17
+if we contact someone who may be an associate of these
+18
+individuals as part of our investigation, is that potentially
+19
+in any way a violation of the NPA? Again, we don't think so.
+20
+And, obviously, again, my direction has been from my
+21
+client: Don't take any action that would result in me being
+22
+indicted under the NPA.
+Well, that's great. But, generally,
+23
+civil lawyers or civil lawyers in defending a personal injury
+24
+case or a tort case, which is exactly what these are, and from
+25
+a practical standpoint, we use various tools to do discovery.
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 11 of 51 11
+They're standard. They're specific. They're very temporary.
+2
+Very typical.
+3
+But in this instance, as the Court knows, things are
+4 not typical with regard to this case in any way, shape or form.
+5 We can't even serve subpoenaes, there's objections and there's
+6
+-- we can't even serve objections to third parties so we can
+7 obtain documents unless we have to filter it through the
+plaintiffs' attorneys. They won't allow us to use their
+9
+clients' names, even in a subpoena that would never be filed in
+10
+the court.
+11
+How do we do a deposition of a third party? We wanted
+12
+to take the deposition of
+Well, who is she? Well,
+13
+we can't tell you that. Well, who's the defendant? Well, we
+14
+can't tell you that because nobody wants anybody to know
+15
+anything about the case. They want to present it strictly
+16
+through rose-colored glasses.
+17
+And in this particular instance, we simply can't
+18
+defend this case or take certain action with the spector
+19
+hanging over us that, in fact, the Government may deem it to be
+20
+a violation of the NPA, because very clearly in their response
+21
+papers, they don't say. They say we don't take the position,
+22
+and then they take a substantial position is we think there's
+23
+not all that substantial factors that would entitle him to a
+24
+stay.
+25
+Except for the one major issue which the Court posed
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 12 of 51 12
+1
+in the question is, is can he defend these cases?
+That's what
+2
+I really want to know. Can he defend these
+cases and, in
+3
+essence, what he has done in the past or what his defense team
+4
+has done in the past and what they're going to do in the
+5
+future, can you give him, Epstein, assurances that the
+6
+Government under this situation, whatever he does, based on
+advice of counsel, that that cannot be a willful violation of
+8
+the NPA, which they can -- they, the U.S. -- can then turn
+9
+around and say that's a violation of the agreement and,
+10
+therefore, we're going to go proceed to indict you under the
+11
+circumstances.
+12
+Our position is, Your Honor, is that the U.S. has now
+13
+cavalierly suggested that, as they did in picking up on the
+14
+court's docket entry or prior order, is, look, compliance with
+15
+the NPA is solely up to Mr. Epstein. In this type of balance
+16
+of equities, it doesn't speak in favor of a stay.
+17
+Well, that's great. And maybe that was the position
+18
+back in '08, on August 5th of '08, when the issue came up in
+19
+front of the Court with regard to the initial stay.
+20
+But the Government's papers under these, circumstances
+21
+suggested a very different set of circumstances. Their own
+22
+unilateral, which is the issue that we argued in the motion for
+23
+stay, is that the Government's position is that we can
+24
+unilaterally indict this man if we think he's breached the NPA.
+25
+We don't think that's right, but we have no buffer
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 13 of 51 13
+1 between us and the Government.
+They'll say, and as the Court
+2
+3
+4
+5
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+knows, the Government has
+substantial power. The Government
+does
+what it wants.
+Most of the time hopefully they're right.
+Sometimes they make mistakes.
+But in this particular instance, my client has rights.
+We think that there's notice provisions, we think there's cure
+provisions under the NPA. That's not what their paper says
+under the circumstances.
+And what we'd like to know from the Government, and
+maybe the answer is basically what the Court asks is, let the
+Government come forward today and say, based on the knowledge
+that we have, or as of today's date, June 12th, 2009, we, the
+Government, agree that there is no set of circumstances, not
+that we're not aware of, but as of today's date, there is
+nothing that exists that would be a violation of the NPA.
+THE COURT: Well, that's way beyond what I'm
+interested in. I don't know what Mr. Epstein may have done
+outside the context of defending this case that may constitute
+a violation. And if he has done something outside the context
+of defending this case that's a violation, I don't care.
+That's between the United States and Mr. Epstein.
+I'm only concerned about whether anything he does in
+defending these civil actions is going to be a violation of the
+non-prosecution agreement. If he has done something else, it's
+none of my business,
+and I don't care, and I'm not going to
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 14 of 51 14
+even ask the Government to give you an assurance that he hasn't
+2
+done anything that might have violated the agreement up till
+3
+today. I'm only interested in defending these civil actions.
+4
+MR. CRITTON: Then I would respectfully submit to the
+5 Court that the Government be asked in that limited context, are
+6 they as of today, whether there were or not, but as of today is
+7 there anything that has been done or will you take the
+8 position, the United States, that any position that Mr. Epstein
+9
+has taken with regard to defending these civil cases is in any
+10 way a violation of the NPA?
+11
+THE COURT: Well, I'm not sure what they're going to
+12 say, but that might -- that cures the problem up to this point.
+13
+But then we have to deal with what's going to happen from here
+14
+on in. And that's another issue that we have to deal with.
+15
+So I understand your position.
+16
+But has anyone suggested to you on behalf of the
+17
+United States that there is something that you've done in
+18
+defending this case that they believe may or could be construed
+19
+as a violation of the non-prosecution agreement? Has anyone
+20
+pointed to anything that you've done? For example, the fact
+21
+that you've wanted to take their -- I don't know if you've
+22
+noticed depositions or not in this case, but if you've sent
+23
+notice of taking deposition, if you sent requests for
+24
+production of documents, if you sent interrogatories, if you
+25
+issued third party subpoenas?
+Is anything you've done thus far
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009
+Page 15 of 51 15
+1
+in the context of this case been brought to your attention as a
+potential violation?
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR. CRITTON: I have received no notification nor am I
+aware that we've received any notification of any action that
+we have taken today. As I suggested to the Court, I don't know
+when they've done or not. And in their papers they suggested,
+well, we don't know everything that's gone on in the civil
+litigation.
+But from a practical standpoint, it was a number of
+comments that were made in their papers is, we can indict, we
+can see if there's a breach.
+Judge, I may have some --
+THE COURT: Before you go on.
+MR. CRITTON: I'm sorry.
+THE COURT: You've focused a great deal on the
+Government's response to my inquiry as supporting your position
+that you're in jeopardy. But you've made the suggestion, even
+before this brief was filed, that defending the case was going
+to potentially result in an assertion or allegation that you
+breached the non-prosecution agreement.
+So what was it that caused you to make that initial
+assertion? Because that's what caught my attention, was not -
+this brief that the Government has filed was in response to
+something that you filed initially in your most recent motion
+for a stay which raised the issue.
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 16 of 51 16
+So what was it that gave you some concern to even
+raise the issue that defending this case is going to constitute
+a breach?
+1
+2
+3
+4
+5
+6
+MR. CRITTON: Because there are other instances where
+counsel other than myself, not in the civil aspects, where
+allegations have been made and letters have been sent by the
+United States suggesting that there's been a violation of the
+8
+NPA. And under those circumstances, some notification was
+9 provided.
+10
+THE COURT: Did it have anything to do with defending
+11
+the civil actions?
+12
+MR. CRITTON: It did not.
+13
+THE COURT: So then why was that issue raised by you
+14| in the first instance?
+15
+MR. CRITTON: Because of the prospect that the
+16
+defendant could take, that the U.S. would take the position
+17 under the circumstances that a position that we took with
+18 regard to the contested litigation may well impact, that the
+19
+Government may have a very different view of what the
+20 interpretation of the agreement is.
+21
+And as an example is a number of the parties, and I
+22
+know the Court doesn't want to get into a discussion, the issue
+23
+is, is under 2255 is that from the defendant's perspective the
+24
+deal that was cut on that, it was a very specific deal. It
+25
+dealt with both consensual and contested litigation. It dealt
+
+
+Case 9:08-cV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 17 of 51
+1
+with a secret list of individuals who we had no idea who was on
+2
+the list, and a commitment that he would under certain
+3
+circumstances be required to pay a minimum amount of damages,
+4
+which our position is under 2255 based upon the statute that
+5
+was in effect at the time, a $50,000 as to anyone who wanted --
+6
+who came forward who was on the list and met certain criteria.
+7
+The position that now has been asserted by a number of
+8
+the plaintiffs under the circumstances, and it's been pled, and
+9
+actually a number of the complainants is, is Epstein agreed,
+10
+and they cite to a letter that was sent by Ms.
+from
+11
+the Government, that says he has to plead guilty or he can't
+12
+contest liability. That may be true under very, very limited
+13
+or specific circumstances.
+14
+But what the plaintiffs have done in a number of the
+15
+cases, and these are pending motions, is they've said is, well,
+16
+we think C.M.A. cases is a good example, they've pled 30
+17
+separate counts of 2255 alleged violations. And they're saying
+18
+under the circumstances is, therefore, we have 2255 violations,
+19
+there's 30 of them, so 30 times 150, or should be, or whether
+20
+it's 150, that's the amount of money that we want, so maybe $15
+21
+million, or whatever the number is.
+22
+Some of the other plaintiffs' lawyers have been even
+23
+more creative. They've said is, well, we'll agree that it's
+24
+only one cause of action but that each number of violations;
+25
+that is, if 20 alleged incidents occurred, that we would
+17
+
+
+Case 9:08-Cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 18 of 51 18
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+consider to be, or that we will argue are violations, then we
+can take 20 times the 50, or the 150, depending on which
+statute is applicable.
+So the Government under that set of circumstance could
+say, and, again, this is one of the reasons that we raised it,
+they could say, look, our deal with you was that you couldn't
+contest liability, that you were waiving liability, or your
+ability to contest an enumerated offense under 2255.
+Again, part of the deal was as to an enumerated
+offense. Okay. Well, what's that mean? What did he plead to?
+Well, he really didn't plead to anything, which is another
+issue associated with the 2255. But if the Government comes
+in
+and says, no, wait a minute, our position was, is that you're
+stuck with 2255 and the language within the NPA. And,
+therefore, whether it's an offense or whether it's multiple
+offenses or violations or each one represents an individual
+cause of action, if the Government takes the position that's
+adverse to what we think the clear reading of the agreement was
+under those circumstances, they could claim a violation.
+And as a result -- and that's one of the reasons we
+put -- that was the most glaring one to us, so we raised that
+issue. And then when the Government's response came with
+regard to, is we can just proceed to indict if we think that
+there's been a breach of the agreement.
+That puts us at substantial risk and chills our
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 19 of 51 19
+1
+ability to move forward. Thank you, Your Honor.
+2
+THE COURT: Thank you. Who wants to be heard from the
+3
+plaintiffs first?
+4
+Is there any plaintiff's attorney who is contending
+that the defense of these civil actions by Mr. Epstein is going
+6
+to constitute a breach of the non-prosecution agreement?
+7
+MR. JOSEFSBERG: Your Honor, this is Bob Josefsberg.
+8 May I speak?
+9
+THE COURT: Yes, sir.
+10
+MR. JOSEFSBERG: We're not quite confident that any
+11
+breaches of any agreement, which were third-party
+12
+beneficiaries, should be resolved by you. We're not saying it
+13
+shouldn't. But we have not raised any breach of agreement. We
+14
+think that is between the United States and Mr. Epstein.
+15
+What I find incredulous and disingenuous is that
+16
+Mr. Epstein is saying that he wants a stay because he may be
+17
+forced into taking actions in the defense of this case that
+18
+would violate the agreement.
+19
+And let me make our position clear on that. If he
+20
+wants to move to take depositions, interrogatories, production,
+21
+and they are according to your rulings appropriate, not
+22
+invasive of the privacy of someone, and they are relevant, then
+23
+I don't know how those could in any way be violations of the
+24
+agreement.
+25
+What I find hypocritical is that there are two parts
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 20 of 51 20
+1
+to the agreement that I am a beneficiary of. One of them is
+2
+that he has agreed that on any action brought in the 2255, he
+3
+will admit to liability.
+4
+And I received on May 26 a motion to dismiss, which
+5
+we're prepared to respond to and disagree with, but totally
+6
+contesting liability, saying that the
+statute doesn't apply
+7
+because the girls are no longer minors and saying, and this is
+8
+the great one, saying that the predicate of the conviction
+9
+under 2255 has not been satisfied.
+10
+Now, the understanding that I have is the agreement
+11 between the Government and Mr. Epstein was that the Government
+12
+desired to see these victims made whole, and wanted them to be
+13
+in the same position as if Mr. Epstein had been prosecuted and
+14| pled or convicted. And they would be able to have the
+15
+predicate of that criminal conviction, which just as a matter
+16
+of liability would just be introduced as proof that he's done
+17 this.
+18
+They, under the agreement, are supposed to admit to
+19
+liability on limited something that's under 2255. He has
+201
+filed, but since there is no conviction, there can be no civil
+21 suit under 2255, with which we disagree. But it is totally in
+22
+opposite of the NPA.
+23
+The second part is there are many young ladies, and
+24
+this perhaps he can use this to his great advantage, who are
+25
+humiliated about this entire situation. Some of them won't
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009
+Page 21 of 51 21
+1
+come forward.
+2
+We were appointed by Judge Davis as a Special Master
+to represent these young ladies. And some of them don't even
+4 want to file suit. They don't even want to be known as
+5
+They don't want any of the risks for these motions
+6
+that are pending.
+7
+And part of the agreement was that if we represented
+them and they settle, MI. Epstein would pay our fees. And he
+9
+has written us as of yesterday that he is under no obligation
+10
+to pay our fees on settling cases.
+11
+Now, those two matters, I believe, may be breaches.
+12
+But I am not asking this Court at this time to do anything
+13
+about them. Nor am I telling the Government, I'm not running
+14
+to the Government and saying indict him because I want you to
+15
+pressure him to do what he agreed to.
+16
+I'm a third-party beneficiary for that agreement, and
+17
+I may move to enforce certain parts of it. But as far as the
+18
+issue of staying the litigation, that is the exact opposite of
+19
+the intent and the letter of the NPA. The purpose of the NPA
+20
+was so that these 34 young ladies, these victims who have been
+21
+severely traumatized, may move on with their lives.
+22
+And to stay this action would be the exact opposite of
+23
+the purpose of that agreement and would be horrible
+24 psychologically for all of my clients.
+25
+THE COURT: Mr. Josefsberg, I understand your
+
+
+Document 180 Entered on FLSD Docket 06/24/2009 Page 22 of 51 22
+position. And I don't want to argue the merits of whether a
+2
+stay should or should not be granted.
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+I'm just trying
+to understand what the ground rules
+are going to be if I grant a stay or if I deny a stay. And
+I've already denied a stay once. I have to decide this current
+motion, and I just want to know what is going to happen if I
+deny the stay in terms of Mr. Epstein's exposure under the
+non-prosecution agreement. That's my concern.
+So if you're telling me that you're not going to urge
+the United States, on behalf of any of your clients, to take
+the position that he's breached the agreement because he's
+taking depositions, because he's pursuing discovery, because
+he's conducting investigations that anyone in any other type of
+civil litigation might conduct with respect to plaintiffs that
+are pursuing claims against a defendant, that those typical
+types of actions, in your judgment, are not breaches of the
+agreement and that he can go forward and defend the case as any
+other defendant could defend, and you're not going to run to
+the United States and say, hey, he's breaching the agreement by
+taking depositions and he's breaching the agreement by issuing
+subpoenas to third parties in order to gather information
+necessary to defend, then I don't have a problem. But if he's
+going to be accused of breaching the agreement because he sends
+out a notice of deposition of one of your clients, how is he
+supposed to defend the case?
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 23 of 51
+23
+1
+MR. JOSEFSBERG: Your
+Honor, you're totally correct.
+2
+He can depose my client. That's not a problem. But the
+3
+problem is that these are not typical clients and this is not a
+4
+typical case. He has written in his pleadings that he wants to
+5
+publish the names of these girls in the newspapers so that
+6
+other people may come forward to discuss their sexual
+7
+activities with these different plaintiffs. That's not your
+8
+typical case. But are rulings that you'll make in this case,
+9
+and they're not part of the NPA.
+10
+As far as my going to the Government is concerned, I
+11
+find it very uncomfortable for me to use the Government to try
+12
+to pursue my financial interest in litigation. And I know that
+13
+Mr. Epstein and his counsel will make much ado about it. So I
+14
+am not going to be running there.
+15
+However, if they start taking depositions regarding
+16
+liability, I will consider that to be a breach because they're
+17
+supposed to have admitted liability.
+18
+THE COURT: But, again, I don't have the agreement and
+19
+I don't remember reading the agreement. But what I'm being
+20
+told is the part of the agreement that admits liability is only
+21
+as to a 2255 claim, and there are numerous other personal
+22 injury tort claims other than 2255 claims.
+23
+And there's a limit of damages on the 2255 claim, as I
+24
+understand it, but I presume that all the plaintiffs are going
+25
+to seek more than the limited or capped amount of damages in
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 24 of 51 24
+the non-prosecution agreement as to the other claims.
+2
+And so why aren't they entitled to defend and limit
+3
+the amount of damages that your client is seeking on the
+4
+non-2255 tort claims?
+5
+MR. JOSEFSBERG: Your Honor, you are correct. On
+6
+non-2255 tort claims, they are permitted to do the defense,
+7
+whatever is appropriate.
+8
+My cases are pure 2255 on which liability under the
+9
+agreement is supposed to be admitted. Now, as to the amount of
+10
+damages, there are legal issues that will be before you and
+11 under the C.M.A. cases that are getting before you, as to
+12 whether it is 50 or 150. That has nothing to do with the NPA.
+13
+There are legal issues that are before you as to
+14 whether it is per statute, per count or per incident or per
+15
+plaintiff. Those have nothing to do with the NPA. There is no
+16
+amount in NPA. Those will be resolved.
+17
+Anyone who has brought a case that is outside of 2255,
+18 the defense is permitted to contest liability under the NPA.
+19| That's no violation.
+20
+Under the NPA if someone brought a case under just
+21 2255, Mr. Epstein, if he is to keep his word, cannot contest
+22 liability. And there would no need to stay this. Because it
+23
+is a self-fulfilling agreement. He can contest liability. And
+24 as far as the amount of damages, anyone that wants to go over
+25
+the statutory minimums, of course, he can contest that in any
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 25 of 51 25
+1
+way that is proper under the Rules of Evidence and your
+rulings. The NºA has no limitation on his contesting damages
+3
+above the minimum statutory amount.
+4
+The only thing that he has done is in his actions of
+5
+refusing to pay for settling defendants, and in his saying that
+6
+he has no liability under 2255, those appear to be contrary to
+7 what's in the NPA.
+8
+But I'm not in any position right now to claim a
+9
+breach, and I don't know whether I'd be claiming a breach or
+10
+enforcing it in front of you, suing him for fees, asking you to
+11 have him admit liability, or complaining to the Government.
+12 And that's why I'm not that helpful in this situation because I
+13
+think it's the Government's role.
+14
+But I do not waive the right to be a third-party
+15
+beneficiary because pursuant to my appointment, which was
+16
+agreed to by Mr. Epstein, I and my clients have certain rights,
+17
+and we want to enforce them.
+18
+But his defending this lawsuit will not in any way be
+19
+a violation. His getting this lawsuit stayed would be a
+20
+violation of the spirit of taking care of these girls, and
+21 there would be other issues. Like if there is a stay, Your
+22 Honor, would he be posting a bond?
+23
+THE COURT: We don't need to talk about those issues.
+24
+That's not my concern.
+25
+MR. JOSEFSBERG: I agree, Your Honor, we don't.
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 26 of 51 26
+1
+THE COURT: That's not my concern. So, again, I just
+2
+want to make sure that if the cases go forward and if
+3
+Mr. Epstein defends the case
+as someone ordinarily would defend
+4
+a case that's being prosecuted against him or her, that that in
+5
+and of itself is not going to cause him to be subject to
+6
+criminal prosecution.
+7
+MR. JOSEFSBERG: I agree, Your Honor.
+8
+THE COURT: Any other plaintiff's counsel want to
+9
+chime in?
+10
+MR. WILLITS: Richard Willits on behalf of C.M.A..
+I
+11]
+would join, to weigh in on what Mr. Josefsberg said.
+12
+MR. JOSEFSBERG: Your Honor, I could not hear.
+13
+THE COURT: We'll get him to a microphone.
+14
+Mr. Willits is speaking.
+15
+MR. WILLITS: On behalf of my client, C.M.A., we join
+16
+in what Mr. Josefsberg said, and we also want to point out
+17
+something to the Court.
+18
+First, we want to make a representation to the Court,
+19
+we have no intention of complaining to the U.S. Attorney's
+20
+Office, never had that intention, don't have that intention in
+21
+the future, but, of course, subject to what occurs in the
+22
+future.
+23
+I want to point out to the Court that Mr. Epstein went
+24
+into this situation with his eyes wide open, represented by
+25
+counsel, knowing that civil suits had to be coming. If he
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 27 of 51 27
+1
+didn't know it, his lawyers knew it.
+2
+He appears to be having second thoughts now about he
+3
+could have negotiated this way or he could have negotiated that
+4
+5
+way with the U.S. Attorney's Office. And they want to impose
+their second thoughts on the innocent plaintiffs. We don't
+6
+think that's fair. We think it's in the nature of invited
+7
+error, if there was any error whatsoever.
+8
+Thank you.
+9
+THE COURT: You agree he should be able to take the
+10
+ordinary steps that a defendant in a civil action can take and
+11
+not be concerned about having to be prosecuted?
+12
+MR. WILLITS: Of course. And we say the same thing
+13
+Mr. Josefsberg said. It's all subject to your rulings and the
+14
+direction of this Court as to what is proper and what is not
+15
+proper. And we're prepared to abide by the rulings of this
+16
+Court, and we have no intention of running to the State's
+17
+Attorney.
+18
+THE COURT: The U.S. Attorney?
+19
+20
+MR. WILLITS: I'm sorry. The U.S. Attorney.
+THE COURT: Mr.
+21
+MR.
+Thank you, Your Honor.
+22
+If I may briefly, I think perhaps defense counsel
+23
+forgot about this, but on pages 17 and 19 of my memorandum of
+24 law in opposition to the motion to dismiss, I did make
+25
+reference to the non-prosecution agreement, and I did say that
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 28 of 51 28
+1
+the contesting of the jurisdiction of this Court was a
+2
+potential breach of the non-prosecution agreement.
+3
+So my client happens to have, and they have filed with
+4
+the Court a copy of her state court complaint, given the fact
+5
+that the non-prosecution agreement limits the non-contesting of
+6
+jurisdiction to claims exclusively brought under the federal
+7
+statute.
+8
+I'm going to go ahead and withdraw those contentions
+9
+on pages 17 and 19 of my memo of law because it doesn't apply
+10
+to my case. So to the extent that I raised this issue with
+11
+defense counsel and the Court, I'm going to withdraw that
+12 aspect of it.
+13
+THE COURT: Can you file something in writing on that
+14| point with the Court?
+15
+MR.
+: Yes.
+16
+THE COURT: What do you say about this issue that
+17
+we're here on today?
+18
+MR.
+: I think that the problem that I have with
+19
+it is that this non-prosecution agreement is being used by
+20
+defense counsel for the exact opposite purpose that it was
+21 intended. My perception of this thing, and I wasn't around, is
+22
+that Mr. Epstein essentially bought his way out of a criminal
+23
+prosecution, which is wonderful for the victims in a way, and
+24 wonderful for him, too.
+25
+Now he's trying to use the non-prosecution agreement
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 29 of 51 29
+as a shield against the plaintiffs that he was supposed to make
+2 restitution for.
+3
+And, certainly, he can take my client's depo. He's
+4 done extensive discovery in the state court case -- very
+5
+intrusive, I might add. And we don't care, because we can win
+6
+this case with the prosecution agreement or without the
+7 prosecution agreement. We are ready to go forward.
+8
+THE COURT: You're not going to assert to the United
+9
+States Government that what he's doing in defending the case is
+10 a violation for which he should be further prosecuted?
+11
+MR.
+: Absolutely not.
+12
+THE COURT: Anyone else for the plaintiffs?
+13
+MR. HOROWITZ: Judge, Adam Horowitz, counsel for
+14
+plaintiffs
+15
+I just wanted to address a point that I think you've
+16
+articulated it. I just want to make sure it's crystal clear,
+17
+which is that we can't paint a broad brush for all of the
+18|
+cases.
+19
+The provision relating to Mr. Epstein being unable to
+20
+contest liability pertains only to those plaintiffs who have
+21
+chosen as their sole remedy the federal statute. My clients,
+22
+have elected to bring additional causes
+23
+of action, and it's for that reason we were silent when you
+24
+said does anyone here find Mr. Epstein to be in breach of the
+25
+non-prosecution agreement. That provision, as we understand
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 30 of 51 30
+1
+2
+it, it doesn't relate to our clients.
+THE COURT: Okay. But, again, you're in agreement
+with everyone else so far that's spoken on behalf of a
+plaintiff that defending the case in the normal course of
+conducting discovery and filing motions would not be a breach?
+MR. HOROWITZ: Subject to your rulings, of course,
+5
+6
+7
+yes.
+8
+THE COURT: Thank you.
+9
+Anyone else have anything to say from the plaintiffs?
+10
+Ms.
+if you would be so kind as to maybe
+11 help us out. I appreciate the fact that you're here, and I
+12
+know you're not a party to these cases and under no obligation
+13
+to respond to my inquiries. But as I indicated, it would be
+14 helpful for me to understand the Government's position.
+15
+MS.
+Thank you, Your Honor. And we, of
+16
+course, are always happy to try to help the Court as much as
+17|
+possible. But we are not a party to any of these lawsuits, and
+18 in some ways we are at a disadvantage because we don't have
+19
+access. My access is limited to what's on Pacer. So I don't
+20
+really know what positions Mr. Epstein may have taken either in
+21
+correspondence or in discovery responses that aren't filed in
+22
+the case file.
+23
+But your first order was really just what do you think
+24
+about a stay, and then the second order related to this hearing
+25
+and asked a much more specific question, which is whether we
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 31 of 51 31
+1
+believe that Mr. Epstein's defense was a breach of the
+2
+agreement.
+3
+And I've tried to review as many of the pleadings as
+4 possible. As you know, they're extremely voluminous. And I
+haven't been through all of them. But we do believe that there
+has been a breach in the filing that Mr. Josefsberg referred
+7
+to, and contrary to Mr. Critton, we do understand that we have
+8
+an obligation to provide notice, and we are providing notice to
+9
+Mr. Epstein today.
+10
+The pleading that we found to be in breach -- the
+11
+non-prosecution agreement, sought to do one thing, which was to
+12
+place the victims in the same position they would have been if
+13
+Mr. Epstein had been convicted of the federal offenses for
+14
+which he was investigated.
+15
+And that if he had been federally prosecuted and
+16
+convicted, the victims would have been entitled to restitution,
+17
+regardless of how long ago the crimes were committed,
+18 regardless of how old they were at the time, and how old they
+19
+are today, or at the time of the conviction.
+20
+And it also would have made them eligible for damages
+21
+under 2255.
+22
+And so our idea was, our hope was that we could set up
+23
+a system that would allow these victims to get that restitution
+24 without having to go through what civil litigation will expose
+25
+them to.
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 32 of 51 32
+1
+You have a number of girls who were very hesitant
+2
+about even speaking to authorities about this because of the
+3
+trauma that they have suffered and about the embarrassment that
+4
+they were afraid would be brought upon themselves and upon
+5
+their families.
+6
+So we did through the non-prosecution agreement tried
+7
+to protect their rights while also protecting their privacy.
+So, pursuant to the non-prosecution agreement -- on the other
+9
+hand, we weren't trying to hand them a jackpot or a key to a
+10 bank. It was solely to sort of put them in that same position.
+11
+So we developed this language that said if -- that
+12
+provided for an attorney to represent them. Most of the
+13
+victims, as you know from the pleadings, come from not wealthy
+14
+circumstances, may not have known any attorneys who would be in
+15
+a position to help them.
+16
+So we went through the Special Master procedure that
+171
+resulted in the appointment of Mr. Josefsberg, and the goal was
+18
+that they would be able to try to negotiate with Mr. Epstein
+19
+for a fair amount of restitution/damages. And if Mr. Epstein
+20
+took the position, which apparently he has, which is that the
+21
+$50,000 or $150, 000 floor under 2255 also would be a cap. That
+22
+if they were to proceed to file suit in Federal Court to get
+23
+fair damages under 2255, Mr. Epstein would admit liability, but
+24
+he, of course, could fight the damages portion, which means
+25
+that, of course, he would be entitled to depositions; of
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 33 of 51 33
+1
+course, he would be entitled to take discovery, and we don't
+2
+believe that any of that violates the non-prosecution
+3
+agreement.
+4
+The issue with the pleading that he filed, the motion
+5
+to dismiss the case, I believe it's
+represented
+6
+by Mr. Josefsberg, is that that is a case that was filed
+7
+exclusively under 18 U.S.C., Section 2255. She met that
+8
+requirement. Mr. Epstein is moving to dismiss it, not on the
+9
+basis of damages, he is saying that he cannot be held liable
+10
+under 2255 because he was not convicted of an offense.
+11
+The reason why he was not convicted of an offense is
+12
+because he entered into the non-prosecution agreement. So that
+13
+we do believe is a breach.
+14
+The issue really that was raised in the motion to stay
+15
+and that I addressed in our response to the motion to stay is
+16
+that Mr. Epstein's -- Mr. Epstein wants to stay the litigation
+17
+in order to leave, in order to
+sort of attack the cases of the
+18 victims whether they are fully within the non-prosecution or
+19
+not, non-prosecution agreement or not, and leave the Government
+20
+without a remedy if he does, in fact, breach those terms. And
+21
+that is why we opposed the stay.
+22
+THE COURT: I'm not sure what you mean by that last
+23
+statement.
+24
+MS.
+Well, because this issue related to
+25
+the motion to dismiss on Mr. Josefsberg's client came up after
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 34 of 51 34
+1 we had filed that response. And what we said in the response
+2 to the motion to stay is that the reason why he wants to stay
+3 the litigation is so that the non-prosecution agreement
+4 terminates based on a period of time, as he puts it. And then
+afterwards he would be able to come in here and make all of
+6
+these arguments that clearly violate the non-prosecution
+7
+agreement but we would be without remedy.
+8
+THE COURT: But you're not taking the position that
+9
+other than possibly doing something in litigation which is a
+10
+violation of an express provision of the non-prosecution
+11
+agreement, any other discovery, motion practice, investigations
+12
+that someone would ordinarily do in the course of defending a
+13
+civil case would constitute a violation of the agreement?
+14
+MS.
+: No, Your Honor. I mean, civil
+15
+litigation is civil litigation, and being able to take
+16
+discovery is part of what civil litigation is about. And while
+17
+there may be, for example, if someone were to try to subpoena
+18 the Government, we would obviously resist under statutory
+19
+reasons, all that sort of stuff. But, no, Mr. Epstein is
+20
+entitled to take the deposition of a plaintiff and to subpoena
+21
+records, etc.
+22
+THE COURT: And even if he seeks discovery from a
+23
+Government agency, you have the right to resist it under the
+24
+rules of procedure but that would not constitute a violation,
+25
+again unless there's a provision in the prosecution agreement
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 35 of 51 35
+that says I can't do this?
+2
+MS.
+Correct.
+3
+THE COURT: That's your position?
+4
+MS.
+Yes.
+5
+THE COURT: Thank you.
+6
+MS.
+Thank you, Your Honor.
+7
+THE COURT: Mr. Critton, did you want to add anything?
+8
+MR. CRITTON: Yes, sir. Just a few responses to some
+9
+of the issues that have been raised.
+10
+The most glaring, at least from our perspective, is
+11 both Mr. Josefsberg's comments that he believes that there's a
+12
+violation of the NPA as well as Ms.
+with regard to
+13
+14
+Mr. Josefsberg, while he was the attorney rep who was
+15 selected by Judge Davis to represent a number of individuals,
+16
+alleged victims that may have been on the list, he represents
+17 many of them. And the type of response that was filed in
+18 would probably be very similar to what we will file if he
+19
+files -- and he filed
+well. But if he files
+20
+and
+or whatever number he files, we may well take that
+21
+same legal position in our motions and in our response or in
+22
+reply.
+23
+And what we've been, in essence, told today is we
+24
+consider that to be a violation of the NPA under the
+25
+circumstances.
+
+
+Document 180 Entered on FLSD Docket 06/24/2009 Page 36 of 51 36
+1
+is a perfect example that he filed is, we have
+2
+e-mails going back and forth between the Government and my
+3
+clients' attorneys at the time that suggested that 102 probably
+4 doesn't even fit within the statute of limitations.
+5
+So under Mr. Josefsberg's argument is as well, we've
+6
+only brought a 2255 claim. We don't care whether she's within
+7
+or is outside the statute of limitations. Because she was on
+the list and under the circumstances, he has to admit
+9
+liability, which we contest is under that set of circumstances
+10
+you're stuck with it. You can fight damages if you can, but
+11
+she's a real person and you can't raise statute of limitations.
+12
+The other point that kind of strikes out is there's
+13
+probably a difference. And I'm happy to provide a copy of the
+' 14
+NPA or a redacted portion of the NPA which deals with the civil
+15
+issues, which are paragraphs
+7, 8, 9 and 10, and the entire
+16
+addenda in camera for the Court to look at, if plaintiff's
+17
+counsel and the Government, I guess, really, because they're
+18 not a party, is if they have no objection because they all have
+19
+access based on a prior court order to the non-prosecution
+20
+agreement.
+21
+So I'm happy to provide that to the Court today and
+22
+show it to counsel so that the Court can review that.
+23
+But our position with regard to the 2255 claims is
+24
+that -- there were two types of claims that could be filed, one
+25
+was consensual litigation, the second was contested litigation.
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 37 of 51 37
+1 And under the consensual, in essence, which Mr. Epstein did, is
+2 he's offered $50, 000 of the statutory minimum for that time
+3 period to all of those individuals.
+4
+THE COURT: Can I interrupt you a second?
+5
+MR. CRITTON: Yes, sir.
+6
+THE COURT: I'm not here, and I don't believe it's my
+7
+role to decide whether or not there is or is not a breach of
+the agreement. I'm just trying to understand what the
+9
+Government's position is regarding your defending these cases.
+10
+Now, I'm just saying this as an example. If, for
+11 example, in the non-prosecution agreement there was a provision
+12
+that said explicitly: Jeffrey Epstein shall not move to
+13
+dismiss any claim brought under 2255 by any victim no matter
+14 how long ago the allegations or the acts took place, period.
+15
+If that was in the agreement and you filed a motion to
+16
+dismiss by someone who brought a claim, it might sound like it
+17
+might be a violation.
+18
+MR. CRITTON: I agree.
+19
+THE COURT: So you would know that when you filed your
+20
+motion because it was right there for you to read.
+21
+And so to stay the case because I want to do something
+22
+that the contract expressly prohibits me from doing, so stay
+23
+the case until the agreement expires so then I can do something
+24
+that the agreement said I couldn't do so you won't be in fear
+25
+of prosecuting, I'm not sure that that is what I'm concerned
+
+
+Document 180 Entered on FLSD Docket 06/24/2009 Page 38 of 51 38
+1
+about.
+2
+3
+I'm concerned about discovery, investigation, motion
+practice, that's not prohibited by a provision of the
+agreement. If there's something that's prohibited by the
+5
+agreement that you, knowing what the agreement says, go ahead
+6
+and do, anyway, I guess that's a risk you're going to have to
+7
+take. If there's a legitimate dispute about it, I guess some
+arbiter is going to decide whether it's a breach or not.
+9
+But, again, that's something you and Mr. Burman,
+10
+Mr. Goldberger, and you are all very good lawyers, and he's got
+11
+a whole list of lawyers representing him, and you've got the
+12
+agreement and you're going to make legal decisions on how to
+13
+proceed, and you're going to have to go and make your own
+14
+decisions.
+15
+I'm concerned about things that aren't in the
+16 agreement, that aren't covered, that you're going to be accused
+17| of violating because, again, you take depositions, you send out
+18| subpoenas, you file motions that are not prohibited by the
+19
+agreement. And that's what I'm concerned about.
+20
+MR. CRITTON: And I understand that, Your Honor.
+21
+But at the same time, it's as if the lawyers and the
+22
+clients, based upon our interpretation of the agreement, and,
+23
+believe me, we would not have filed 101, the motion to dismiss,
+24
+but for believing that there was a good faith basis to do that
+25
+under the circumstances.
+
+
+Case 9:08-cV-80119-KAM
+Document 180 Entered on FLSD Docket 06/24/2009 Page 39 of 51 39
+1
+And now, in essence, we're being accused not only by
+2
+-- not accused, but it's been suggested that there's a breach
+3
+of the NPA, not only by Mr. Josefsberg on behalf of, but as
+well Ms.
+on behalf of the United States.
+5
+That's the perfect example. They're basically saying
+6
+we think you violated.
+We may send you notice under the
+7
+circumstances. So does that mean that onl
+we have to back
+8 off of it because we think in good faith that it's a motion and
+9
+is that something that this Court ultimately will rule?
+10
+THE COURT: I don't know that I'm the one who is going
+11 to make that decision. Again, that's not the kind of thing
+12
+that I was concerned about. I was more concerned about the
+13
+normal, ordinary course of conducting and defending a case that
+14|
+would not otherwise expressly be covered under the agreement,
+15
+that you're going to then have someone say, ah, he's sent a
+16
+notice of deposition, he's harassing the plaintiffs. I don't
+17
+know if there's a no contact provision in the agreement or no
+18 harassment type of provision in the agreement. Ah, this is a
+19
+breach because you sent discovery, or he's issuing subpoenas to
+20
+third parties trying to find out about these victims'
+21
+backgrounds, he's breaching the agreement.
+22
+Those are the kind of things that I was worried about.
+23
+MR. CRITTON: The concern that we have is as part of
+24
+doing this general civil litigation, it's not just the
+25
+discovery process. And I understand the issues that the Court
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 40 of 51 40
+1
+has raised.
+2
+But part of it is that often cases are disposed of
+3
+either on a summary basis or certainly legal issues that come
+4
+before the Court during the course of the case, just like in a
+5
+criminal case. That's clearly part of the, I'd say the defense
+6
+of the case under the circumstances; and if, in fact, an
+7
+individual can't legally bring a cause of action for certain
+reasons, such as has been suggested inl
+and may be
+9
+suggested in
+when that pleading is filed, that certainly is
+10
+a position that puts my client at risk.
+11
+As another example that I use with C.M.A., that they
+12
+filed this 30-count complaint. Now, they have the state court
+13
+claims as well. But they, in essence, have said they filed
+14
+another pleading with the Court that says depending on what the
+15
+Court rules, in essence, on whether we can file multiple claims
+16
+or one cause of action with multiple violations, we may dump
+17
+the state court claims and, therefore, we'll just ride along on
+18 that. That's a very different --
+19
+Mr. Epstein would never have entered into, nor would
+20
+his attorneys have allowed him to enter into that agreement
+21
+under those circumstances where he had this unlimited
+22
+liability. That clearly was never envisioned by any of the
+23
+defendants -- by the defendant or any of his lawyers under the
+24
+circumstances.
+25
+And if that's claimed to be a violation, either by the
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 41 of 51 41
+1
+attorneys; i.e., he's not recapitulating on liability under the
+2
+2255, and that's all we have now. That's our exclusive remedy.
+3
+And the Government says, yeah, that's right, that's a
+violation of the NPA. It again chills us from moving forward,
+5
+filing the necessary motion papers and taking legal positions
+6
+that may put my client at risk for violating the NPA and then
+7
+creating the irreparable harm of, after having been in jail,
+8 after having pled guilty to the state court counts, after
+9
+registering on release as a sex offender, he's complied and
+10
+done everything, taken extraordinary efforts to comply with the
+11
+NPA, puts him at substantial risk. And that's what our worry
+12
+is moving forward.
+13
+MR. JOSEFSBERG: Your Honor, may I be heard. May I
+14
+make three comments? It will take less than a minute.
+15
+THE COURT: Yes, sir.
+16
+MR. JOSEFSBERG: Mr. Critton refers to the alleged
+17
+victims. I want you to know that our position is that pursuant
+18 to the NPA they're not alleged victims. They are actual, real
+19
+victims, admitted victims.
+20
+Secondly, he argues about the statute of limitations
+21
+on 102. I know that you don't want to hear about that, and I'm
+22
+not going to comment about it. But please don't take our lack
+23
+of argument about this as being we agree with anything.
+24
+Last and most important, we totally agree with
+25
+Mr. Critton in his suggestion that he hand you a copy of the
+
+
+Case 9:08-Cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 42 of 51 42
+1
+NPA. I think that many of the questions you asked will be
+2
+answered when you read the NPA, and I think it's very unfair of
+3
+everyone who is sitting in front of you who have the NPA to be
+4
+discussing with you whether it's being breached, whether there
+5
+should be a stay when you're not that familiar with it.
+6
+If we would give you a copy of it, I think it would be
+7
+much more helpful in making your ruling.
+8
+THE COURT: Maybe Judge Colvat will resolve this issue
+9
+for me.
+10
+MR. JOSEFSBERG: Even if he doesn't, Your Honor, I
+11
+believe we are allowed to show it to you.
+12
+THE COURT: I'll tell you what: I'll wait for Judge
+13
+Colvat to rule, and then if he rules that it should remain
+14 sealed, then I'll consider whether or not I want to have it
+15฿
+submitted to me in camera.
+16
+Anything else, Mr. Josefsberg?
+17
+MR. JOSEFSBERG: No. I thank you on behalf of myself
+18 and the other counsel on the phone for permitting us to appear
+19 by phone.
+20
+THE COURT: All right. Anyone else have anything they
+21
+want to add?
+22
+MR. EDWARDS: Brad Edwards on behalf of
+23
+I only had one issue here, and when I read your motion
+24
+that you wanted to hear on the narrow issue of just defense in
+25
+the civil actions filed against him violates the
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 43 of 51 43
+1
+non-prosecution agreement, I was expecting that we were going
+2
+to hear something from the Government similar to the affidavit
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+that was filed by MI. Epstein's attorneys wherein he indicates
+as of the day of this affidavit attached to the motion to stay,
+the U.S. Attorney's Office has
+taken the position that Epstein
+has breached the non-prosecution agreement and it names
+specifically investigation by Epstein of this plaintiff and
+other plaintiffs, Epstein's contesting damages in this action.
+Epstein, or his legal representatives, making statements
+to the
+press. And we didn't hear any of those things.
+So that's what I was expecting that the U.S.
+Attorney's Office was going to expound on and say, yes, we've
+made some communications to Epstein. He's violating.
+What we're hearing right now, today, just so that I'm
+clear, and I think the Court is clear now, is that the
+non-prosecution agreement is what it is. There have been no
+violations, but for maybe what Mr. Josefsberg brought up.
+But there are very few restrictions on Mr. Epstein.
+He went into this eyes wide open. And whether or not I agree
+with the agreement, how it came to be in the first place, is
+neither here nor there.
+But there have been no violations or breaches up to
+this point. And his affidavit that was filed, I'm just
+troubled by where it even came from. I mean, it's making
+specific allegations that the U.S. Attorney's Office is
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 44 of 51 44
+1
+2
+threatening a breach, and this is part of the motion to stay,
+which we're all battling here.
+3
+So I just wanted to indicate to the Court or remind
+4
+7
+the Court that there have been specific allegations made, the
+United States Attorney's Office is making these allegations of
+breach, which we haven't heard any of the evidence of.
+Thank you.
+8
+THE COURT: All right.
+9
+Ms.
+, did you want to respond to that
+10
+suggestion that there were other allegations of breach besides
+11 the one that you've just mentioned today?
+12
+13
+14
+15
+16
+17
+MS.
+: No, Your Honor.
+THE COURT: Thank you. I appreciate your giving me
+the information, which I think has been very helpful today, and
+I'll try and get an order out as soon as possible.
+[Court adjourned at 11:10 |
+1.].
+CERTIEICATE
+18
+I hereby certify that the foregoing is an accurate
+19
+transcription of proceedings in the above-entitled matter.
+20
+s/larry Herr
+21
+DATE
+22
+23
+LARRY HERR, RPR-CM-RMR-FCRSC
+Official United States Court Reporter
+400 N. Miami Avenue
+Miami, FL 33128
+24
+25
+email:
+Quality Assurance by Proximity Linguibase Technologies
+
+
+JAMES I, EISENBERG
+- Florida Bar Board Certified Criminal Trial Lawyer
+National Board Of Trial Advoency Certified Criminal Trial Advocate
+KAILI ALOE FOUTS
+One Cleurlake Centre, Suite 704, 250 Australian Avenue South, West Palm Beach, F1. 33401 l
+September 21, 2006
+1, Asst. U.S. Attorney
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL, 33401
+Re:
+Subpoena for T
+Deat
+Please allow me to confitm my latest e-mail to you, I did receive your e-mail of last week with
+attachments and passed them on to my client. At this time, I can only say that my client does not
+want to do either of your suggestions. She does not want to give a statement under the immunity
+letter you proyided with its Kastigar exception and she does not want to testity!
+and yill not on 5" Amendment grounds. With this client, I am sorry, but I must have a formal grant
+of immunity before she will say anything.
+JAMES I
+SENDERG
+JLEIgw
+co:
+Ms.
+
+A
+Case No. 08-80736-CV-MARRA
+P-000146
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+January 24, 2007
+DELIVERY BY HAND
+James L. Eisenberg, Esq.
+250 S Australian Ave, Ste 704
+West Palm Beach, FL 33401-5007
+Re: Federal Grand Jury Subpoena
+Dear Jim:
+A new grand jury has been empaneled and I have enclosed a new subpoena for
+As I mentioned earlier, Ms.
+is not a target of this investigation and the United
+States seeks her testimony solely as a victim/witness. During our last conversation regarding
+Ms.
+1, you indicated that she was unwilling to speak with us pursuant to a Kastigar
+letter and that she also was unwilling to speak with the grand jury and intends to invoke the
+Fifth Amendment if questioned. Please confer with her to confirm whether this remains her
+position. If it is, please advise in writing. Even if Ms.
+is inclined to invoke her Fifth
+Amendment rights, she must still appear pursuant to the subpoena so that I may ask her
+questions that would not require the invocation of the Fifth Amendment. If she still invokes,
+I intend to move to compel her answers. If you or your client is unavailable on February 6,
+2007, please let me know of another Tuesday when you are available.
+Ialso am concerned about a potential conflict of interest in your representation of Ms.
+In case of future litigation regarding this issue, please provide me with information
+regarding who is paying (directly or indirectly) for your services on behalf of Ms.
+_ the
+scope of your representation, and Whether you are taking direction on this matter from
+anyone other than Ms.
+anythe other hag or therwis, please provide or infra doing dements rece age exist,
+is purely oral, please provide a written summary of its terms.
+
+1
+
+
+JAMES EISENBERG, ESQ.
+• JANUARY 24, 2007
+I look forward to your response.
+United States
+By:
+
+
+SUBPOENA TO TESTIFY
+SUBPOENA FOR:
+X PERSON
+DOCUMENTS OR OBJECTS]
+YOU ARE HEREBY COMMANDED to appear and testify before the
+Court at the place, date and time Specified below.
+of the United States District
+PLACE:
+ROOM:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+DATE AND TIME:
+February 6, 2007
+1:00pm*
+YOU ARE ALSO COMMANDED to bring with you the following document (s) or objects):
+ANY AND ALL NOTES, LETTERS CARDS, GETS, PAYMENTS, AND PHOTOGRAPHS YOU HAVE RECEIVED
+FROM JEFFREY EPSTEIN,
+ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIĞITAL, OF JERFREY BPSTBIN,
+ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS; OR TELEPHONE
+MESSAGES THAT YOU HAVE SENT TO AND/OR RECEIVED FROM JEFFREY EPSTEIN,
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+GATES DISTANCE
+(BY) DEPUTY CLERK
+DATE:
+January 23, 2007
+This subpoena is issued upon application
+of the United States of America
+*IF not applicable, enter "one"
+Jame, Address and Phone Number of Assistant U.S. Attorne
+Assistant U.S. Attorne
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+Tel:
+x3047
+Fax:
+To be wed in lieu of 40110
+JAN.86
+
+
+Morida Bar Board Certified Criminal Trial Lawye
+lational Board Of Trial Advocacy Certified Criminal Trial Advocat
+KAI LI ALOE FOUTS
+One Clearlake Centre, Suite 704, 250 Australian Avenue South, West Palm Beach, FL 33401 |
+February 1, 2007
+1, Asst. U.S. Attorney
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+Fax:
+Re:
+Grand Jury Subpoena for
+Dear
+I received your letter dated January 24, 2007 with regard to
+• I must admit I forced
+myself to wait several days to respond in order to "cool off" and not say anything I would regret
+later. Now that time has passed; allow me to respond appropriately.
+1. If you want to force Ms:
+a single mother, to come to the grand jury room to
+personally invoke her Fifth Amendment rights, she will be there: That does remain her position.
+My only request is that you provide a babysitter service for her child. I will be there, but I am not
+paid to babysit and Ms.
+should not have to pay someone. It is this type of attitude, that your
+office refuses to accept the fact that it is Ms.
+decision not to cooperate with the government
+that upsets her. Your office fails to recognize that merely coming to court is a problem for a single
+mother like Ms.
+and, under these circumstances, appears to be a waste of time at best and, in
+her mind, personal harassment.
+2. Rest assured that there is no conflict of interest in my representation of Ms.
+In this
+case I have always been asked and always will exercise independent judgment to follow my client's
+independent will. The remainder of your questions as to this matter are really none of the
+Government's business.
+3. I will share with you that one of the reasons for our firm position that Ms.
+will
+ivoke her Fifth Amendment right and choose not to voluntarily cooperate with the Government
+ur concern that the Government is not exercising independent judgment in this cas
+The history of this case has been in the hewspapers. The case is being prosecuted in State court.
+Despite the state couit prosecution, the Town of Palm Beach Police Chief went on what can only be
+
+2
+
+
+Asst. U.S. Attorney
+February 1, 2007
+Page Two
+described as a public rampage in the newspaper when the case was not prosecuted to his liking that
+reminded me of a small child having a public temper tantrum. In my thirty years of experience, I
+have never seen a law enforcement officer like this publicly make what appeared to be a political
+case in the newspaper for a prosecution and publicly criticize anyone who got in his way, including
+the elected State Attorney. This resulted in a federal investigation on a topic no one remembers the
+Federal Government ever being interested in prosecuting before. Although I am certain that you
+personally have not had your decision-making process compromised, the appearance that your office
+is being influenced by the Town of Palm Beach Police Chief's agenda is very real. Under these
+circumstances!! don't see how any lawyer could advise any client to voluntarily cooperate. Of
+special concern is that the Town of Palm Beach Police have promoted prosecuting at least one of the
+girls who allegedly gave massages.
+One final thought. My client and my fear that Ms.
+could be prosecuted is enhanced by the
+demand for the personal appearance made in your letter. Your initial Kastiger letter fell far short
+of granting the functional equivalent of DOJ immunity. Several months ago I was given the distinct
+impression through our conversations that you were going to obtain DOJ immunity for Ms.
+Now the government is changing course for no apparent reason. This leads to speculation that the
+only reason for the turnabout is that prosecution in either state or federal court is being considered
+by someone.
+None of the above is directed at you personally. I want to repeat that you have always treated us with
+respect. Maybe four office should advise the Town Police Chief to act in a similar fashion.
+Sincere
+JAMES
+
+
+500 South Australian Ave, Suite 400-
+West Palm Beach, Florida 33401
+Facsimile
+FACSIMILE COVER SHEET
+TO: JIM EISENBERG, ESQ.
+DATE:
+FAX NO.
+# OF PAGES:
+February 5, 2007
+6
+PHONE NO.
+RE:
+FROM:
+ASSISTANT U.S. ATTORNEY
+PHONE NO.
+COMENTS: Hi Tim-These pedably say the
+for changes, please let me
+ppreciatel
+hark your patience today. "
+Regards,
+
+3
+
+
+V.S. Department of Justice
+Southern District of Florida.
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+February 5, 2007
+DELIVERY BY HAND
+Ms.
+c/o James L. Eisenberg, Esq.
+250 S Australian Ave, Ste 704
+West Palm Beach, FL 33401-5007
+Re: Grand Jury Testimony of _
+Dear Ms.
+This letter confirms the understanding between yourself and the United States Attorney's
+Office for the Southern District of Florida.
+You have represented that you will truthfully answer questions of the federal government in
+its investigation of the procurement of prostitutes, amongst others. You will supply complete and
+truthful information to the attorneys and law enforcement officers of the federal government and to
+any Federal Grand Jury which may conduct an investigation, as well as in any other proceeding
+related to or growing out of this investigation. The obligation of truthful disclosure includes your
+obligation to provide the attorneys and law enforcement officers of the federal government with any
+documents, records or other tangible evidence within your custody or control relating to the matters
+about which you are questioned. You will neither attempt to protect any person or entity through
+false information or omission, nor falsely implicate any person or entity.
+No statements provided by you on this date in this matter pursuant to this agreement will be
+offered into evidence in any criminal case against you, except during a prosecution for perjury and/or
+giving a false statement. However, if it is determined that you have materially violated any provision
+of this agreement, all statements made by you shall be admissible in evidence against you in any
+proceeding.
+The federal government remains free to use information derived from the grand jury
+testimony directly or indirectly for the purpose of obtaining leads to other evidence, which may be
+used against you. You expressly waive any right to claim that such evidence should not be
+introduced because it was obtained as a result of the grand jury testimony. Furthermore, the federal
+government may use statements made in the grand jury testimony and all evidence derived directly
+or indirectly therefrom for the purpose of cross-examination, if you testify at any trial or if you
+
+
+Ms. |
+FEBRUARY 5, 2007
+suborn testimony that contradicts your prior statements and testimony.
+No additional promises, agreements and conditions have been entered into other than those
+set forth in this letter and none will be entered into unless in writing and signed by all parties.
+By:
+I have read this agreement and discussed it with my attorney, and I hereby acknowledge that it
+fully sets forth my agreement with the office of the United States Attorney for the Southern District of
+Florida. I state that there have been no additional promises, agreements or representations made to me
+by any officials of the United States in connection with this matter.
+Dated: February
+_ 2007
+West Palm Beach, Florida
+James L. Eisenberg, Esq.
+Attorney for
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+February 5, 2007
+DELIVERY BY HAND
+James I. Eisenberg, Esq.
+250 S Australian Ave, Ste 704
+West Palm Beach, FL 33401-5007
+Re:
+Dear Mr. Eisenberg:
+I am writing to clarify the ground rules for the interview with your client,
+("your client"), to occur February _
+- 2007.
+As I mentioned earlier, Ms.
+¿is not a target or subject of this investigation, but
+instead is being interviewed solely as a victim/witness. However, to address your concern
+about criminal exposure, if your client complies with every provision of this agreement, then
+the United States Attorney's Office for the Southern District of Florida ("this Office") will
+treat all statements made by your client during the interview as statements made pursuant to
+Rule 11(f) of the Federal Rules of Criminal Procedure. This is not a grant of immunity,
+which can be given only with approval of the Justice Department, but protects your client
+from having the statements made by her during the interview from being used against her
+directly. To guard against any misunderstandings concerning the interview of your client,
+this letter sets forth the terms of this agreement.
+Your client agrees to be fully interviewed, that is, to provide information concerning
+your client's knowledge of, and participation in criminal activity, including but not limited
+to the procurement of prostitutes. The protection of this letter applies to an interview that
+will be conducted by this Office, Special Agents of the Federal Bureau of Investigation, and
+any other federal law enforcement agency this Office may require. Under this agreement,
+no information disclosed by your client during the interview will be offered in evidence
+against her in any criminal or civil proceeding, provided that your client complies with this
+agreement and that the information your client furnishes is truthful, complete, and accurate.
+If, however, your client gives materially false, incomplete, or misleading information,
+
+
+JAMES L., EISENBERG, ESQ.
+RE:
+then this Office may use such information in any matter or proceeding and your client is
+subject to prosecution for perjury, obstruction of justice, and making false statements to
+government agencies. Any such prosecution may be based upon information provided by
+your client during the course of the interview, and such information, including your client's
+statements, will be admissible against your client in any grand jury or other proceeding.
+The government also may use statements made by your client in the interview and all
+evidence derived directly or indirectly therefrom for the purpose of impeachment or
+cross-examination if she testifies at any trial or hearing, and/or in any rebuttal case against
+your client in a criminal trial in which she is a defendant or a witness. These provisions are
+necessary to ensure that your client does not make or offer any false representation or
+statement in any proceeding or to a government agency or commit perjury during any
+testimony.
+Your client further agrees that attorneys for the United States may be present at the
+interview, and agrees not to seek disqualification of any such government attorney from any
+proceeding or trial because of their participation at the interview.
+The entire agreement between the United States and your client is set forth in this
+letter. No additional promises, agreements, or conditions have been entered into and none
+will be entered into unless in writing and signed by all parties.
+If the foregoing accurately reflects the understanding and agreement between this
+Office and your client, it is requested that you and your client execute this letter as provided
+below.
+• By:
+I have received this letter from my attorney, James L. Eisenberg, Esquire, have read
+it and discussed it with my attorney, and I hereby acknowledge that it fully sets forth my
+understanding and agreement with the Office of the United States Attorney for the Southern
+
+
+JAMES L. EISENBERG, EsQ.
+RE: _
+PAGE 3
+District of Florida. I state that there have been no additional promises or representations
+made to me by any official of the United States Government or by my attorney in connection
+with this matter.
+Dated:
+James L. Eisenberg, Esquire
+
+
+U.S. Department of Justice'
+Authorization for Reimbursement
+of Unusual Expenses of Fact, Witnesses
+Request for Unusual Expense(s) of Fact Witness
+(For United States Attorney's Office Use Only)
+1. Case Name
+2. Court Docket Number
+Operation Leashlar
+4. Location of Court Proceeding
+5. Contact Person
+West PalmBeach
+7. Witness Name & Address, Phone #, SSN
+Control#
+3. Requesting AUSA
+6. Contact Person Number
+|8. Vendor Name & Address, Phone #, TIN/SSN
+9. Payment to be made to:
+10. Receipt/Invoice is:
+11. Type of Unusual Expense:
+• Medically Necessary Item
+(Attached Supporting Statement)
+Dependent Care
+• Excess Lodging/Per Diem
+• Travel & Transportation
+• Pretrial Conference Waiver
+• Other
+13. Start Date of Service, (MO/DA/YR)
+2/6/07
+16. Justification:
+12. Explanation:
+The witness has a small child and
+would not had no one who could
+watch the child while she
+testified.
+14. End Date of Service (MO/DA/YR)
+2/6/07
+15. Amount
+17. I hereby certify that the expenses and services listed on this document are appropriate and are within the Federal laws
+and regulations. I fully understand that I can be held personally liable or be subject to disciplinary action for improperly using
+government funds or services that exceed delegated authority or that violate Federal laws or regulations.
+Signature of Requesting AUSA
+18. Name & Title of Approving Official
+-
+Date
+19. Date (MO/DA/YR)
+20. Signature of Approving Official
+
+4
+UFWE Form
+
+
+Florida Bar Board Certified Criminal Trial Lawyer
+National Board OfTrial Advocacy Certified Criminal Trial Advocate
+KAI LI ALOE FOUTS
+One Clearlake Centre, Suite 704, 250 Australian Avenue South, West Palm Beach, FL. 33401
+February 12, 2007
+Asst. U.S. Attorney
+500 South Australian Avenue, Suite 400
+West Palm Beach, FL 33401
+Re:
+Grand Jury Subpoena for
+FaX: S
+Dear.
+As always, it was a pleasure speaking to you the other day. Pursuant to our telephone conference
+I am writing this letter to proffer my concerns for |
+should she testify without immunity
+before a federal grand jury: Therefore, allow me to reiterate that Ms: Miller will refuse to voluntarily
+cooperate with the federal government. She has a good faith basis for her position under the Fifth
+Amendment to the United States Constitution.
+We, of course, do not live or work in a vacuum. We have read many inflammatory remarks the
+Town of Palm Beach Police Chief has made to the media about the state court's handling of the
+Jeffrey Epstein investigation. The police chief's remarks frighten both myself and my client. I am
+aware that the town police have prepared documents to charge at least one of Mr. Epstein's lady
+friends in state court. If they can push to have one lady charged I remain unconvinced that they do
+not have the ability or political clout to push to have other ladies such as Ms.
+charged.
+The proffered facts that raise my concerns are being provided via this proffer letter. Pursuant to our
+telephone conference agreement, this letter and its contents cannot be used against Mr.
+Ms.
+is not at all certain of dates. She does remember meeting Mr. Epstein about three years
+ago. She is not certain of her age, it could have been when she was sixteen. A girlfriend asked her
+if she wanted a job giving massages. Ms.
+agreed because she had knowledge of massages
+through her mother, who was a masseuse.
+Ms:*
+went to Mr. Epstein's house via taxi: Ms:
+girlfriend instructed Ms.
+that,
+if asked, she had to tell Mr. Epstein that she
+- was eighteen years old. The friend was
+nineteen years old and
+looked old for her age, so passing for eighteen was not a problem. At
+
+5
+
+
+the home Ms. I
+met Mr. Epstein and later gave him a massage. The friend had told Ms. 1
+to give the message topless. Mr. Epstein told 1
+that if she were at all uncomfortable being
+topless, not to do it and it was not a requirement of employment as a masseuse. Ms.
+never
+touched Mr. Epstein in a sexual way and Mr. Epstein never touched Ms.
+at all. At one point,
+Mr. Epstein did ask Ms.
+her age. Ms.
+insisted that she was eighteen years old.
+Ms.
+continued to see Mr. Epstein over time and massages were given in a similar fashion.
+She was later asked if her friends wanted to work in a similar way and she asked some girls who did
+give Mr. Epstein massages. Ms.
+was never asked to bring girls of any age to Mr. Epstein's
+home. When she did have her friends come over, she instructed all of them that if asked, they insist
+that they were eighteen years old. She is not certain at all of any of these girls' real ages.
+In summary, our concern is that if the government believes that Mr. Epstein committed some federal
+w.., offense, then Ms.1
+could be considered a co-conspirator. We believe no crime was committed.
+The Fifth Amendment was not intended to protect the guilty, however. It was enacted to protect
+citizens who fear prosecution notwithstanding their innocence. Our fear of any prosecution,
+especially
+i light,
+of the Town police chief's public remarks, is clearly in good faith.
+
+
+:
+NORTHERN (WEST PALM BEACH) DIVISION
+FGJ 07-103(WPB)
+30.
+COPi
+IN RE:
+GRAND JURY PROCEEDINGS
+2007 APR 16 PM 2: 15
+FILED BY-
+0.5.
+SEALED ORDER
+On Application of the United States Attorney for the Southern District of Florida, and it
+appearing to the satisfaction of the Court:
+That
+has been called to testify and to provide other information before
+the United States District Court for the Southern District of Florida, including a Grand Jury
+impanelled therein; and
+2.
+That in the judgment of the said United States Attorney,
+has refused
+to testify and provide other information on the basis of her privilege against self-incrimination; and
+That in the judgment of the said United States Attorney, the testimony and other
+information from
+may be necessary to the public interest; and
+4.
+That the aforesaid Application has been made with the approval of the Assistant
+Attorney General in charge of the Criminal Division of the Department of Justice or a duly
+designated Acting Assistant Attorney General, pursuant to the authority vested in him by Title 18,
+United States Code, Section 6003, and Title 28, Code of Federal Regulations, Sections 0.175 and
+0.132(e).
+that
+NOW, THEREFORE, it is ordered pursuant to Title 18, United States Code, Section 6002,
+give testimony and provide other information which she refuses to give or to
+
+6
+
+
+provide on the basis of her privilege against self-incrimination, as to all matters about which she may
+be interrogated before said United States District Court, including a Grand Jury impaneled therein,
+as well as any subsequent proceeding or trial.
+However, no testimony or other information compelled under this Order (or any information
+directly or indirectly derived from such testimony or other information) may be used against
+in any criminal case, except a prosecution for perjury, giving a false statement, or otherwise
+failing to comply with this Order.
+IT IS FURTHER ORDERED the this Order shall be SEALED in accordance with Fed.
+R. Crim. P. 6(e)(б), except that a copy of this Order shall be provided to counsel for the United
+States, who may disclose the existence of the Order to members of the Grand Jury, to the witness,
+to counsel for the witness, and to law enforcement officers engaged in the investigation pending
+before the Grand Jury. Those persons may review the Order, but may not retain a copy of the Order,
+nor may they disclose the existence of the Order to any others.
+DONE and ORDERED this 16
+day of April, 2007, at West Palm Beach, Florida.
+DONALD M. MIDDLEBROOKS
+UNITED STATES DISTRICT JUDGE
+AUSA
+2
+
+
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-13/2
+SUBPOENA FOR:
+x PERSON
+X
+DOCUMENTS OR OBJECTIS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Grand Jury Room
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+DATE AND TIME:
+February 6, 2007
+1:00pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+ANY AND ALL NOTES, LETTERS, CARDS, GIFTS, PAYMENTS, AND PHOTOGRAPHS YOU HAVE RECEIVED
+FROM JEFFREY EPSTEIN,
+ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIĞITAL, OF JEFFREY EPSTEIN
+AND/OR
+ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS: OR TELEPHONE
+MESSAGES THAT YOU HAVE SENT TO AND/OR RECEIVED FROM JEFFREY EPSTEIN,
+AND/OR
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+January 23, 2007
+This subpoena is issued upon application
+of the United States of America
+*If not applicable, enter "none."
+SO CHESTINET OR T
+Name, Address and Phone Number of Assistant U.S. Attorney
+1, Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL. 33401-6235
+Tel:
+Fax:
+To be used in liou of ADIO
+JAN.86
+
+
+Respondent's Exhibit
+ase No. 08-80736-CIV-MARR
+CASE NO. 08-80736-CIV-MARRA
+JANE DOE #1 AND JANE DOE #2,
+Petitioners,
+VS.
+UNITED STATES,
+Respondent.
+DECLARATION OF
+E.
+declares as follows:
+1. 1 am a Special Agent in the Federal Bureau of Investigation (FBI) and have been so
+employed since 1997. I am currently assigned to the West Palm Beach office of the FBI Miami
+Field Division.
+2. In 2006, I was assigned as the case agent in an investigation into allegations that
+Jeffrey Epstein had engaged in unlawful sexual contact with girls under the age of 18. The case
+was called Operation Leap Year. FBI Special Agent
+and I conducted most of the
+investigation, and worked with the U.S. Attorney's Office, on Operation Leap Year.
+3. Over the course of the investigation, the FBI obtained hundreds of documents through
+the use of grand jury subpoenas, public records, and law enforcement databases. FBI agents
+conducted interviews with females believed to have been sexually abused by Mr. Epstein and
+underage at the time of the assault, as well as other individuals who might have relevant
+information. The interviews are memorialized and prepared by the interviewing FBI agent. The
+interview reports of the young women interviewed contain highly personal and intimate details,
+
+
+Respondent's Exhibit A
+which would cause embarrassment to the young women if disclosed to third parties. For those
+interviewed who did not reveal any intimate details, many will be displeased if their cooperation
+with the FBI is made public. In my experience, individuals are reluctant to cooperate with law
+enforcement for fear of being singled out, harassed, embarrassed, or subjected to retaliation if
+their cooperation is disclosed to third parties.
+4. The case file on Operation Leap Year also contains FBI agents' analysis of
+information obtained during the course of the investigation. These written analyses of the
+evidence reveal potential theories of criminal liability based on the evidence uncovered in the
+case. Information contained within FBI investigative files can also reveal sensitive FBI
+investigative and operational methods, procedures and techniques. While it is publically known
+that the FBI conducts investigations into the type of criminal wrongdoing committed by Jeffrey
+Epstein, disclosing the precise details of the sensitive methods, procedures and techniques
+employed during an investigation might compromise their future effective use. It is critical that
+the FBI's investigative tools remain confidential to both retain an element of surprise and to
+prevent countermeasures to such tools from being employed by targets and suspects.
+5. During the course of Operation Leap Year, I interviewed and heard the personal
+account of sexual abuse committed by Mr. Epstein on the young women. They suffered
+emotionally, and some were referred by the FBI to mental health professionals because of the
+psychologically harmed caused by Mr. Epstein. In at least one instance, mental health
+professionals were involved to help prevent one young woman from physically harming herself.
+6. The disclosure of personal information, contained in the FBI investigative file, to
+third parties would not merely cause further embarrassment but could result in additional
+psychological trauma, disruption of family relationships, disruption of professional careers and
+2
+
+
+Respondent's Exhibit A
+possible public release of personal information.
+7. Operation Leap Year remains an open case.
+8. I declare under penalty of perjury that the foregoing is true and correct.
+EXECUTED on September 3, 2013.
+West Palm Beach, Florida
+3
+
+
+Suite 500
+505 South Flagler Drive
+West Palm Beach, FL 33401
+Phone:
+Fax:
+January 10, 2008
+James Elsenberg
+One Clearlake Center Ste 704 Australian South
+West Palm Beach, FL 33401
+Re:
+Dear James Elsenberg:
+You have requested to recelve notifications fo
+This case is currentiy under Investigation. This can be a lengthy process and we request your
+continued patience while we conduct a thorough investigation.
+As a crime victim, you have the following rights under 18 United States Code 5 3771: (1) The right to
+be reasonably protected from the accused; (2) The right to roasonable, accurate, and timely notice of any
+public court proceeding, or any parole proceeding, Involving the crime or of any release or escape of the
+accused; (3) The right not to be excluded from any such public court proceeding, unless the court, after •
+receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if
+the victim heard other testimony at that proceeding; (4) The right to be reasonably heard at any public
+proceeding in the district court involving release, plea, sentencing, or any parole proceeding; (5) The
+reasonable right to confer with the attorney for the Government in the case; (5) The right to full and timely
+restitution as provided in law; (7) The right to proceedings free from unreasonable delay: (8) The right to be
+treated with fairess and with respect for the victim's dignity and privacy.
+We will make our best efforts to ensure you are accorded the rights described. Most of these rights
+pertain to events occurring after the arrest or indictment of an individual for the crime, and it will become the
+responsibility of the prosecuting United States Attorney's Office to ensure you are accorded those rights. You
+may also seek the advice of a private attorney with respect to these rights.
+The Victim Notification System (VNS) is designed to provide you with direct Information regarding the
+case as it proceeds through the criminal justice. system. You may obtain current information about this matter
+on the Internet at WWW.Notify. USDOJ.GOV or from the VNS Call Center at 1-866-DOJ-4YOU (1-866-365-
+4968) (TDD/TTY: 1-866-228-4619) (International: 1-502-213-2767). In addition, you may use the Call
+Center or Interet to update your contact information and/or change your decision about participation in the
+notification program. If you update your information to include a current emall address, VNS will send
+information to that address. You will need the following Victim Identification Number (VIN) 1941741' and
+Personal Identification Number (PIN) '7760' anytime you contact the Call Center and the first time you log on to
+VNS on the Intemet. In addition, the first time you access the VNS Internet site, you will be prompted to enter
+your last name (or business name) as currently contained in VNS. The name you should enter is Eisenberg.
+
+NO. 08-80736-CV-MARR/
+
+
+
+If you have additional questions which involve this matter, please contact the office listed above. When
+you call, please provide the file number located at the top of this letter. Please remember, your participation
+in the notification part of this program is voluntary. In order to continue to receive notifications, it is your
+
+
+
+Sulte 500
+505 South Flagler Drive
+West Palm Beach, FL 33401
+Phone:
+Fax:
+NO. 08-80736-CV-MARRA
+
+May 30, 2008
+Re:
+Dear S
+Your name was referred to the FBl's Victim Assistance Program as being a possible victim of a federal
+crime. We appreciate your assistance and cooperation while we are investigating this case. We would like to
+make you aware of the victim services that may be available to you and to answer any questions you may have
+regarding the criminal justice process throughout the investigation. Our program is part of the FBl's effort to
+ensure the victims are treated with respect and are provided information about their rights under federal law.
+These rights include notification of the status of the case. The enclosed brochures provide information about
+the FBI's Victim Assistance Program, resources and instructions for accessing the Victim Notification System
+(VNS). VNS is designed to provide you with information regarding the status of your case.
+This case Is currently under Investigation. This can be a lengthy process and we request your
+continued patience while we conduct a thorough investigation.
+As a crime victim, you have the following rights under 18 United States Code § 3771: (1) The right to
+be reasonably protected from the accused; (2) The right to reasonable, accurate, and timely notice of any
+public court proceeding, or any parole proceeding, involving the crime or of any release or escape of the
+accused; (3) The right not to be excluded from any such public court proceeding, unless the court, after
+receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if
+the victim heard other testimony at that proceeding: (4) The right to be reasonably heard at any public
+proceeding in the district court involving release, plea, sentencing, or any parole proceeding; (5) The
+reasonable right to confer with the attorney for the Govemment in the case; (6) The right to full and timely
+restitution as provided in law; (7) The right to proceedings free from unreasonable delay; (8) The right to be
+treated with fairness and with respect for the victim's dignity and privacy.
+We will make our best efforts to ensure you are accorded the rights described. Most of these rights
+pertain to events occurring after the arrest or indictment of an individual for the crime, and it will become the
+responsibility of the prosecuting United States Attorney's Office to ensure you are accorded those rights. You
+may also seek the advice of a private attorney with respect to these rights.
+The Victim Notification System (VNS) Is designed to provide you with direct information regarding the
+case as it proceeds through the criminal justice system. You may obtain current information about this matter
+on the Internet at WWW.Notify. USDOJ.GOV or from the VNS Call Center at 1-866-DOJ-4YOU (1-866-365-
+4968) (TDD/TTY: 1-866-228-4619) (International: 1-502-213-2767). In addition, you may use the Call
+Center or Internet to update your contact information and/or change your decision about participation in the
+notification program. if you update your information to include a current email address, VNS will send
+information to that address. You will need the following Victim Identification Number (VIN) 2074381' and
+Personal Identification Number (PIN) '1816' anytime you contact the Call Center and the first time you log on to
+VNS on the Internet. In addition, the first time you access the VNS Internet site, you will be prompted to enter
+your last name (or business name) as currently contained in VNS. The name you should enter is R
+
+
+U
+if you have additional questions which involve this matter, please contact the office listed above. When
+you call, please provide the file number located at the top of this letter. Please remember, your participation
+the notification part of this program is voluntary. In order to continue to receive notifications, it is yo
+sponsibility to keep your contact information curre
+TOTAL P.07
+
+
+Souhern District of Florida
+500 South Ausiralian Ave, Suite: 400
+West Palm Beach, FL 33401
+June 7, 2007
+DELIVERY BY HAND
+Re:
+Crime Victims" and Witnesses' Rights
+Dear Miss
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense,
+you have a number of rights. Those rights are:
+(1) The right to be reasonably protected from the accused.
+(2)
+The right to reasonable, accurate, and timely notice of any public court proceeding
+involving the crime or of any release or escape of the accused.
+(3)
+The right not to be excluded from any public court proceeding, unless the court
+determines that your testimony may be materially altered if you are present for other
+portions of a proceeding.
+(4)
+The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, or sentencing-
+(5)
+(6)
+(7)
+(8)
+The reasonable right to confer with the attorney for the United States in the case.
+The right to full and timely restitution as provided in law.
+The right to proceedings free from unreasonable delay.
+The right to be treated with fairess and with respect for the victim's dignity and
+pnvacy.
+Members of the U.S. Department of Justice and other federal investigative agencies,
+ncluding the Federal Bureau of Investigation, must use their best efforts to make sure that thes
+gits are protected. It you have any concerns in this regard, please feel free to contact me at
+, or Special Agent
+from the Federal Bureau of Investigation at
+You also can contact the Justice Department's Office for Victims of Crime in
+Washington, D.C. at
+That Office has a website at www.ovc.gov.
+You can seek the advice of an attorney with respect to the rights listed above and, if you
+believe that the rights set forth above are being violated, you have the right to petition the Court for
+
+
+JUNE 7, 2007
+In addition to these rights, you are entitled to counseling and medical services, and protection
+from intimidation and harassment. If the Court determines that you are a victim, you also may be
+entitled to restitution from the perpetrator. A list of counseling and medical service providers can
+be provided to you, if you so desire. If you or your family is subjected to any intimidation or
+harassment, please contact Special Agent L
+Jor myself immediately. It is possible that
+someone working on behalf of the targets of the investigation may contact you. Such contact does
+not violatibe law." However, if you are contacted, you have the choice of speaking to that person
+or refusing to"do so. If you refuse and feel that you are being threatened or harassed, then please
+'contact Special Agent
+or myself.
+You also are entitled to notification of upcoming case events. At thistime, your case is unde
+nivestigation$ If anyone is charged in connection with the investigation, you will be notifice
+R. Alexander Acosta
+1
+By:
+Assistant United States Attomey
+Cc:
+, F.B.I.
+!!
+
+
+U.S. Department of.Justice
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+August 11, 2006
+DELIVERY BY HAND
+Miss
+Re: Crime Victims' and Witnesses' Rights
+Dear
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense,
+you have a number of rights. Those rights are:
+(1)
+(2)
+The right to be reasonably protected from the accused.
+The right to reasonable, accurate, and timely notice of any public court proceeding
+involving the crime or of any release or escape of the accused.
+(3)
+The right not to be excluded from any public court proceeding, unless the court
+determines that your testimony may be materially altered if you are present for other
+portions of a proceeding.
+(4)
+The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, or sentencing.
+(5)
+(6)
+(7)
+(8)
+The reasonable right to confer with the attorney for the United States in the case.
+The right to full and timely restitution as provided in law.
+The right to proceedings free from unreasonable delay.
+The right to be treated with fairness and with respect for the victim's dignity and
+privacy:
+Members of the U.S. Department of Justice and other federal investigative agencies,
+including the Federal Bureau of Investigation, must use their best efforts to make sure that these
+rights are protected. If you have any concerns in this regard, please feel free to contact me at
+, or Special Agent
+from the Federal Bureau of Investigation at
+You also can contact the Justice Department's Office for Victims of Crime in
+Washington, D.C. at 202-307-5983. That Office has a website at www.ovc.gov.
+You can seek the advice of an attorney with respect to the rights listed above and, if you
+believe that the rights set forth above are being violated, you have the right to petition the Court for
+
+
+MISS TEA
+AUGUST 11, 2006
+In addition to these rights, you are entitled to counseling and medical services, and i
+from intimidation and harassment. If the Court determines that you are a victim, you ..!: •
+entitled to restitution from the perpetrator. A list of counseling and medical service pr:
+be provided to you, if you so desire. If you or your family is subjecled to any intr:
+harassment, please contact Special Agent
+lor myself immediately. It is pr
+someone working on behalf of the targets of the investigation may contact you. Such cir':
+not violate the law. However, if you are contacted, you have the choice of speaking to ih :
+or refusing to do so. If you refuse and feel that you are being threatened or harassed, licontact Special Agent
+I or myself.
+You also are entitled to notification of upcoming case events. At this time, your es :
+investigation. If anyone is charged in connection with the investigation, you will be m
+R. Alexander Acosta
+United States Attomey
+By:
+F.B.L.
+!!
+". "
+
+
+w1 000 0201
+r.ucr0l
+Federal Bureau of Investigatlor
+FBI - West Palm Beact
+Suite 500
+505 South Flagler Drive
+West Palm Beach, FL 33401
+Phone:
+Fax:
+January 10, 2008
+Re: Case Number:d
+Dear
+This case is currently under investigation. This can be a lengthy process and we request your
+continued patience while we conduct a thorough investigation.
+As a crime victim, you have the following rights under 18 United States Code g 3771: (1) The right to
+be reasonably protected from the accused: (2) The right to reasonable, accurate, and timely notice of any
+public court proceeding, or any parole proceeding, Involving the crime or of any release or escape of the
+accused; (3) The right not to be excluded from any such public court proceeding, unless the court, after
+receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if
+the victim heard other testimony at that proceeding; (4) The right to be reasonably heard at any public
+proceeding in the district court involving release, plea, sentencing, or any parole proceeding; (5) The
+reasonable right to confer with the attorney for the Government In the case; (6) The right to full and timely
+restitution as provided In law; (7) The right to proceedings free from unreasonable delay: (B) The right to be
+treated with faimess and with respect for the victim's dignity and privacy.
+We will make our best efforts to ensure you are accorded the rights descrbed. Most of these rights
+pertain to events occurring after the arrest or indictment of an Individual for the crime, and it will become the
+responsibility of the prosecuting United States Attorey's Office to ensure you are accorded those rights. You
+may also seek the advice of a private attomey with respect to these rights.
+The Victim Notification System (VNS) is designed to provide you with direct information regarding the
+case as it proceeds through the criminal justice system. You may obtain current information about this matter
+on the Internet at WWW.Notify. USDOJ.GOV or from the VNS Call Center at 1-866-DOJ-4YOU (1-866-365-
+4968) (TDD/TTY: 1-866-228-4619) (International: 1-502-213-2767). In addition, you may use the Call
+Center or Internet to update your contact information and/or change your decision about participation in the
+notification program. If you update your Information to include a current email address, VNS will senc
+information to that address. You will need the following Victim Identification Number (VIN) '1941737 and
+Personal Identification Number (PIN) '5502' anytime you contact the Call Center and the first time you log on to
+VNS on the Internet. In addition, the first time you access the VNS Internet site, you will be prompted to enter
+vour last name (or business name) as currently contained in VNS. The name you should enter is Wl
+
+
+If you have additional questions which involve this matter, please contact the office listed above. When
+you cal, please provide the file number located at the top of this letter. Please remember, your participation
+in the notification part of this program is voluntary. In order to continue to receive notifications, it is your
+
+
+Suite 500
+05 South Flagler Dri
+lest Palm Beach, FL 334
+Phone
+Fax: (5
+January 10, 200B
+James Elsenberg
+Ono Clearlake Center Ste 704 Austrellan South
+West Palm Beach, FL. 33401
+Re: M
+Dear James Elsenberg:
+You have requested to recelve notifications for
+This case is currently under Investigation. This can be a lengthy process and we request your
+continued patience while we conduct a thorough investigation.
+As a crime victim, you have the following rights under 18 United States Code § 3771: (1) The right to
+be reasonably protected from the accused: (2) The right to reasonable, accurate, and timely notice of any
+public court proceeding, or any parole proceeding, Involving the crime or of any release or escape of the
+accused; (3) The right not to be excluded from any such public court proceeding, unless the court, after •
+receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if
+the victim heard other testimony at that proceeding; (4) The right to be reasonably heard at any public
+proceeding in the district court involving release, plea, sentencing, or any parole proceeding; (5) The
+reasonable right to confer with the attorney for the Government in the case; (5) The right to full and timely
+restitution as provided in law; (7) The right to proceedings free from unreasonable delay: (8) The right to be
+treated with faimess and with respect for the victim's dignity and privacy.
+We will make our best efforts to ensure you are accorded the rights described. Most of these rights
+pertain to events occurring after the arrest or Indictment of an individual for the crime, and it will become the
+responsibility of the prosecuting United States Attorney's Office to ensure you are accorded those rights. You
+may also seek the advice of a private attorney with respect to these rights.
+The Victim Notification System (VNS) is designed to provide you with direct information regarding the
+case as it proceeds through the criminal justice system.
+You may obtain current information about this matter
+on the internet at WWW.Notlfy.USDOJ.GOV or from the VNS Call Center at 1-866-DOJ-4YOU (1-866-365-
+4968) (TDD/TTY: 1-866-228-4618) (International: 1-502-213-2767). In addition, you may use the Call
+Center or Internet to update your contact information and/or change your decision about participation in the
+notification program. If you update your information to Include a current emall address, VS will send
+information to that address. You will need the following Victim Identification Number (VIN) 1941741' and
+Personal Identification Number (PIN) 7760' anytime you contact the Call Center and the first time you log on to
+VNS on the Internet. In addition, the first time you access the VNS Internet site, you will be prompted to enter
+your last name (or business name) as currently contained in VNS. The name you should enter is Eisenberg.
+
+
+r.03/0
+If you have additional questions which involve this matter, please contact the office listed above. When
+you call, please provide the fle number located at the top of this letter. Please remember, your participation
+in the nottfication part of this program is voluntary. In order to continue to receive notifications, it is you
+responsibillty to keep your contact Information current.
+
+
+SUV
+-EXHIBIT
+500 South Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Facsimile.
+June 7, 2007
+DELIVERY BY HAND
+Mis
+Re:
+Crime Victims" and Witnesses" Rights
+Dear
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense,
+you have a number of rights. Those nights are:
+(1)
+(2)
+(3)
+(4)
+(5)
+(6)
+(7)
+(8)
+The right to be reasonably protected from the accused.
+The right to reasonable, accurate, and timely notice of any public court proceeding
+involving the crime or of any release or escape of the accused
+The right not to be excluded from any public court proceeding, unless the court
+determines that your testimony may be materially altered if you are present for other
+portions of a proceeding.
+The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, or sentencing.
+The reasonable right to confer with the attorney for the United States in the case.
+The right to full and timely restitution as provided in law.
+The righi to proceedings free from unreasonable delay.
+The right to be treated with fairess and with respect for the victim's dignity and
+privacy.
+Members of te U.S. Department of Justice and other federal investigative agencies,
+including the Federal Bureau of Investigation, must use their best efforts to make sure that these
+ights are protected. If you have any concerns in this regard, please feel free to contact me at
+- or Special Agent
+from the Federal Bureau of Investigation at
+You also can contact the Justice Department's Office for Victims of Crime in
+Washington, D.C. at 202-307-5983. That Office has a website at www.ovc.gov.
+You can seek the advice of an attorey with respect to the rights listed above and, if you
+believe that the rights set forth above are being violated, you have the right to petition the Court for
+
+
+Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 9 of 21
+MISS CEN
+JUNE 7, 2007
+In addition to these rights, you are entitled to counseling and medical services, and protection
+from intimidation and harassment. If the Court determines that you are a victim, you also may be
+entitled to restitution from the perpetrator. A list of counseling and medical service providers can
+be provided to you, if you so desire. If you or your family is subjected to any intimidation or
+harassment, please contact Special Agent R
+nor myself immediately. It is possible that
+someone working on behalf of the targets of the investigation may contact you. Such contact does
+not violasthe law" However, if you are contacted, you have the choice of speaking to that person
+or refusing to"do so. If you refuse and feel that you are being threatened or harassed, then please
+contact Special Agent
+or myself.
+You also are entitled to notification of upcoming case events. At this time, your case is under
+investigation! If anyone is charged in connection with the investigation, you will be notified.
+R. Alexander Acosta
+By:
+Assistant United States Attomey
+F.B.I.
+
+
+Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008;
+НЕХНІВП
+NO: 55-60736-CY.MAR
+500 South Australian Avc., Suite 400
+West Palm Beach, FL 33401
+August 11, 2006
+DELIVERY BY HAND
+Miss
+Re:
+Crime Victims' and Witnesses' Rights
+Dear Miss
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense,
+you have a number of rights. Those nghts are:
+(1)
+(2)
+The right to be reasonably protected from the accused.
+The night to reasonable, accurate, and timely notice of any public court proceeding
+involving the crime or of any release or escape of the accused.
+(3)
+The right not to be excluded from any public court proceding, unless the court
+determines that your testimony may be materially altered if you are present for other
+portions of a proceeding.
+(4)
+The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, or sentencing.
+(5)
+(6)
+(7)
+(8)
+The reasonable right to confer with the attorney for the United States in the case.
+The right to full and timely restitution as provided in law.
+The right to proceedings free from unreasonable delay.
+The right to be treated with fairness and with respect for the victim's dignity and
+privacy.
+Members of the U.S. Department of Justice and other federal investigative agencies,
+including the Federal Bureau of Investigation, must use their best efforts to make sure that these
+rights are protected. If you have any concerns in this regard, please feel free to contact me at !
+or Spocial Agent 1
+from the Federal Burcau of Investigation at
+You also can contact the Justice Department's Office for Victims of Crime in
+Washington, D.C. at 202-307-5983. That Office has a website at www.ovc.gov.
+You can seek the advice of an attorney with respect to the rights listed above and, if you
+believe that the rights set forth above are being violated, you have the right to petition the Court for
+
+
+Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 11 of 21
+MISS
+AUGUST 11, 2006
+In addition to these rights, you are entitled to counseling and medical services, and pa :
+from intimidation and harassment. If the Court determines that you are a victim, you ....
+entitled to restitution from the perpetrator. A list of counseling and medical service pro:
+be provided to-you, if you so desire. If you or your family is subjected to any inter
+harassment, please contact Special Agent _
+for myself immediately. It is pere
+someone working on behalf of the targets of the investigation may contact you. Such ain:"
+not violate the law. However, if you are contacted, you have the choice of speaking to iir:
+Corespeci do so. you refuse an fe that you are being tireatened or harase, li.
+You also are entitled to notification of upcoming case events. At this time, your es
+nvestigation. If anyone is charged in connection with the investigation, you will be no
+R. Alexander Acosta
+By:
+F.B.I.
+*..
+
+
+Case 9:08-cv-80736-KAM Document Document Entered on FLSD Docket Docket Page 12-05:21
+Suite 500
+505 South Flagler Drive
+West Palm Beach, FL 33401
+Phone
+Fax: (4
+January 10, 2008
+Re: Case Number:
+Dear
+This case is currently under Investigation. This can be a lengthy process and we request your
+continued patience while we conduct a thorough investigation.
+As a crime victim. you have the following rights under 18 United States Code § 3771: (1) The right to
+be reasonably protected from the accused: (2) The right to reasonable, accurate, and timely notice of any
+pubile court proceeding, or any parole proceeding, Involving the crime or of any release or escape of the
+accused; (3) The right not to be excluded from any such public court proceeding, unless the court, after
+receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if
+the victim heard other testimony at that proceeding; (4) The right to be reasonably heard at any public
+proceeding in the district court involving release, plea, sentencing, or any parole proceeding: (5) The
+reasonable right to confer with the attorey for the Government In the case; (6) The right to full and timely
+restitution as provided in law; (7) The right to proceedings free from unreasoneble delay; (B) The right to be
+treated with faimess and with respect for the victim's dignity and privacy.
+We will make our best efforts to ensure you are accorded the rights deserbed. Most of these rights
+portain to events occurring after the arrest or indictment of an Individual for the crime, and it will become the
+responsibility of the prosecuting United States Attorney's Office to ensure you are accorded those rights. You
+may also seek the advice of a private attomey with respect to these rights.
+The Victim Notification System (VNS) is designed to provide you with direct information regarding the
+case as it proceeds through the criminal justice system. You may obtain current information about this matier
+on the Internet at WWW.Notify. USDOJ.GOV or from the VNS Call Center at 1-866-DOJ-4YOU (1-866-365-
+4968) (TDD/TTY: 1-866-228-4619) (International: 1-502-213-2767). In addition, you may use the Call
+Center or Internet to updale your contact information and/or change your decision about participation in the
+notification program. If you update your Information to include a current email address, VNS will send
+information to that address. You will need the following Victim Identification Number (VIN) '1941737' and"
+Personal Identification Number (PIN) '5502' anytime you contact the Call Center and the first time you log on to
+VNS on the Internet. In addition, the first time you access the VNS Interet site, you will be prompted to enter
+your last name (or business name) as currently contained in VNS. The name you should enter is
+EXHIBE:
+NO. 08-80736-CVMARR
+
+-NO.:
+
+
+Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 13'0f21
+If you have additional questions which Involve this matter, please contact the office listed above. When
+you call, please provide the file number located at the top of this letter. Please remember, your participation
+in the notification part of this program is voluntary. In order to continue to receive notifications, it is your
+
+
+Case 9:08-cv-80736-KAM .Document 14 Entered on FLSD Docket 07/45/2008>Page740P21
+FBI - West Paim Beach
+Suite 500
+505 South Flagler Drive
+West Palm Beach Fl 33401
+Phone
+Fax:
+January 10, 2008
+James Elsenberg
+One Clearake Center Ste 704 Australian South
+West Palm Beach, Fl. 33401
+Re:
+Dear James Elsanberg:
+You have requested to recelve notifications for
+This case is currently under Investigation. This can be a lengthy process and we request your
+continued patience while we conduct a thorough investigation.
+As a crime victim, you have the following rights under 18 United States Code § 3771: (1) The right to
+be reasonably protected from the accused: (2) The right to reasonable, accurate, and timely notice of any
+public court proceeding, or any parole proceeding, Involving the crime or of any release or escape of the
+accused; (3) The right not to be excluded from any such public court proceeding, unless the court, after -
+receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if
+the victim heard other testimony at that proceeding; (4) The right to be reasonably heard at any public
+proceeding in the district court involving release, plea, sentencing, or any parole proceeding; (5) The
+reasonable right to confer with the attorney for the Government in the case; (5) The right to full and timely
+restitution as provided in law; (7) The right to proceedings free from unreasonable delay: (8) The right to be
+treated with faimess and with respect for the victim's dignity and privacy.
+We will make our best efforts to ensure you are accorded the rights described. Most of these rights
+pertain to events occurring after the arrest or Indictment of an individual for the crime, and it will become the
+responsibility of the prosecuting United States Attorney's Office to ensure you are accorded those rights. You
+may also seek the advice of a private attorey with respect to these rights.
+The Victim Notification System (VNS) is designed to provide you with direct information regarding the
+case as it proceeds through the criminal justice system. You may obtain current information about this matter
+on the Internet at WWW.Nalify. USDOJ.GOV or from the VNS Call Center at 1-886-DOJ-4YOU (1-866-365-
+4968) (TDD/TTY: 1-866-228-4619) (Interational: 1-502-213-2767). In addition, you may use the Call
+Center or Interet to update your contact information and/or change your decision about participation in the
+notification program. If you update your information to Include a current emall address, VNS will send
+information to that address. You will need the following Victim Identification Number (VIN) '1941741' and
+Personal Identification Number (PIN) '7760' anytime you contact the Call Center and the first time you log on to
+VNS on the Interet. In addition, the first time you access the VNS Internet site, you will be prompted to enter
+your last name (or business name) as currently contained in VNS. The name you should enter is Eisenberg.
+NO: 08-80736-CY-MARRA
+
+
+
+Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/46/2008 Page 150121
+If you have additional questions which involve this matter, please contact the office listed above. When
+you call, please provide the file number located at the top of this letter. Please remember, your participation
+in the notification part of this program is voluntary. In order to continue to receive nolifications, it is your
+responsibility to keep your contact Information current.
+
+
+Case 9:08-cv-80736-KAM . Document 14
+Entered on FLSD Docket 07/15/200% sager 8012
+
+Suite 500
+505 South Flagler Drive
+West Palm Beach. Fl 33401
+Phone:
+Fax:
+NO. D8-#0736-CMMARR
+
+May 30, 2008
+Re:
+Dee
+Your name was referred to the FBl's Victim Assistance Program as being a possible victim of a federal
+crime. We appreciate your assistance and cooperation while we are Investigating this case. We would like to
+make you aware of the victim services that may be available to you and to answer any questions you may have
+regarding the criminal justice process throughout the investigation. Our program is part of the FBl's effort to
+ensure the victims are treated with respect and are provided information about their rights under federal law.
+These rights include notification of the status of the case. The enciosed brochures provide information about
+the FBI's Victim Assistance Program, resources and instructions for accessing the Victim Notification System
+(VNS). VNS is designed to provide you with information regarding the status of your case.
+This case Is currently under Investigation. This can be a lengthy process and we request your
+continued patience whlle we conduct a thorough investigation.
+As a crime victim, you have the foliowing rights under 18 United States Code 5 3771: (1) The right lo
+be reasonably protected from the accused; (2) The right to reasonable, accurate, and timely notice of any
+public court proceeding, or any parole proceeding, involving the crime or of any release or escape of the
+accused: (3) The right not to be excluded from any such public court proceeding, unless the court, after
+receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if
+the victim heard other testimony at that proceeding; (4) The right to be reasonably heard at any public
+proceeding in the district court involving release, plea, sentencing, or any parole proceeding; (5] The
+reasonable right to confer with the attorney for the Government in the case; (6) The right to full and timely
+restitution as provided in law; (7) The right to proceedings free from unreasonable delay: (8) The right to be
+treated with fairess and with respect for the victim's dignity and privacy.
+We will make our best efforts to ensure you are accorded the rights described. Most of these rights
+pertain to events occurring after the arrest or indictment of an individual for the crime, and it will become the
+responsibility of the prosecuting United States Attorney's Office to ensure you are accorded those rights. You
+may also seek the advice of a private attorney with respect to these rights.
+The Victim Notification System (VNS) Is designed to provide you with direct information regarding the
+case as it proceeds through the criminal justice system. You may obtain current information about this matter
+on the Internet at WWW.Notify. USDOJ.GOV or from the VNS Call Center at 1-866-DOJ-4YOU (1-866-365-
+4968) (TDD/TTY: 1-866-228-4619) (Interational: 1-502-213-2767). In addition, you may use the Call
+Center or Internet to update your contact information and/or change your decision about participation in the
+notification program. if you update your information to include a current email address, VNS will send
+nformation to that address. You will need the following Victim Identification Number (VIN) 2074381' and
+Personal Identification Number (PIN) "1816' anytime you contact the Call Center and the first time you log on to
+VNS on the Internet. In addition, the first time you access the VNS Internet site, you will be prompter to enter
+your last name (or business name) as currently contained in VNS. The name you should enter is
+
+
+Cage-9:08-CV-80736-KAM Document 14, Entered on FLSD Docket 07/45/2008> Page 7P'oF21
+If you have addtional questions which involve this matter, please contact the office listed above. When
+you call, please provide the file number located at the top of this letter. Please remember, your participation
+in the notification part of this program is voluntary. In order to continue to receive notifications, it is your
+TOTAL P.07
+
+
+Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 18 of 21
+
+NO.08-80736-CV-MARRA
+
+6
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33407
+July 9, 2008
+VIA FACSIMILE
+Brad Edwards, Esq.
+The Law Offices of Brad Edwards & Associates, LLC
+2028 Harrison Street, Suite 202
+Hollywood, Florida 33020.
+Re:
+Jeffrey Epstein
+IDENTIFIED VICTIM
+¿ NOTIFICATION OF
+Dear Mr. Edwards:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following notice to your client,
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+
+
+Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 19 of 21
+NOTIFICATION OF IDENTIFIED VICTIM CERNS VENO
+JULY 9, 2008
+
+had been tried federally and convicted of an enumerated offense. For purposes
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that your client,
+is an individual whom the United States was prepared to name as a victim of an enumerated
+offense.
+Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401, |
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; howevêr, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an
+enumerated offense, please provide notice of that denial to the undersigned.
+Please thank your client for all of her assistance during the course of this examination
+and express the heartfelt regards of myself and Special Agents
+for
+the health and well-being of Ms.
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+Jack Goldberger, Esq.
+
+
+Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 20 of 21
+
+NO.08-80736-CV-MARRA
+
+7
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+July 9, 2008
+VIA FACSIMILE
+Brad Edwards, Esq.
+The Law Offices of Brad Edwards & Associates, LLC
+2028 Harrison Street, Suite 202
+Hollywood, Florida 33020.
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+NOTIFICATION OF
+Dear Mr. Edwards:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following notice to your client,
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nas. 2006-cf-009454AXXXMB and 2008-cfollowed by an additional six months
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+
+
+Case 9:08-cv-80736-KAM Document 14 Entered on FLSD Docket 07/15/2008 Page 21 of 21
+NOTIFICATION OF IDENTIFIED VICTIM SEEN
+JULY 9, 2008
+
+had been tried federally and convicted of an enumerated offense. For purposes
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that your client,
+s an individual whom the United States was prepared to name as a victim of an
+enumerated offense.
+Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401, L
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an
+enumerated offense, please provide notice of that denial to the undersigned.
+Please thank your client for all of her assistance during the course of this examination
+and express the heartfelt regards of myself and Special Agents
+for
+the health and well-being of Ms.
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+Jack Goldberger, Esq.
+
+
+GOVERNMENT SUMMARY JUDGMENT EXHIBITS
+: United States
+
+Personal email
+DE 361-15
+Item
+E-mail from Jim Eisenberg to
+October 24, 2006
+OEO approval of 18 U.S.C. § 6001 Immunity for
+April 24, 2007
+Interview Transcript
+écember 21, 2007 letter from Lefkowitz to
+August 11, 2006 victim letter to
+August 11, 2006 victim letter to
+Epstein appeal letters to CEOS
+• May 15, 2008 letter from Oosterbaan to Lefkowtiz
+* June 23, 2008 letter from John Roth to Lefkowitz
+January 2008 FBI victim letters
+• November 28, 2007 letter, Ken Starr to Alice Fisher
+December 11, 2007 letter, Lefkowitz to
+Attorney General Guidelines (2005), Victim and Witness
+Assistance
+November 27, 2007 email,
+• December 26, 2007 letter, Lefkowitz to A
+to Lefkowitz
+Complaint
+r. Epstein (CW)
+Complaint
+1. Epstein (TM)
+S/A
+Declaration
+10110/07 Leftowitz lt
+
+
+CASE NO. 08-80736-CIV-MARRA
+Petitioners,
+VS.
+UNITED STATES,
+Respondent.
+/
+SECOND DECLARATION OF E.
+I, E.
+declare as follows:
+1.
+I am a Special Agent in the Federal Bureau of Investigation (FBI) and have been
+so employed since 1997. I am currently assigned to the West Palm Beach office of the FBI Miami
+Field Division.
+2.
+In 2006, I was assigned as the case agent on the investigation of Jeffrey Epstein,
+which was referred to as Operation Leap Year.
+As part of that investigation, I attempted to interview
+was walking to her vehicle, and she refused to speak with me.
+at her residence.
+4.
+I returned to my vehicle to get a grand jury subpoena for
+and handed
+it to her.
+threw the grand jury subpoena onto the ground. I then verbally instructed
+her that it was a court order and she was expected to appear at the grand jury at the location, date,
+and time that appeared on the subpoena.
+got into the vehicle and drove away without
+speaking to me.
+
+
+later obtained counsel and appeared for a videotaped interview on
+April 24, 2007. During the videotaped interview
+expressed her opinion that Jeffrey
+Epstein should not be prosecuted. She said, "I hope Jeffrey, nothing happens to Jeffrey because
+he's an awesome man and it would really be a shame. It's a shame that he has to go through this
+because he's an awesome guy and he didn't do nothing wrong, nothing."
+6.
+Other than these events, neither I nor any other FBI agent had any contact with
+during the course of the investigation.
+never contacted me or my co-case
+agents asking for information about the investigation or asking to confer with anyone from the
+government about the resolution of the matter.
+On August 7, 2007, my co-case agent and I interviewer
+as part of the
+investigation of Jeffrey Epstein. At no time during that interview did
+sk to confer
+with anyone from the government about any potential criminal charging decisions or about any
+potential resolution of the matter. An FBI report was prepared. Between the time of the interview
+and the signing of the Non-Prosecution Agreement in September 2007,
+never
+contacted me or my co-case agent asking for information about the investigation or asking to
+confer with anyone from the government about any potential criminal charging decisions or about
+the resolution of the matter.
+In October 2007, my co-case agent and I met with
+at a Publix grocery
+store in Palm Beach Gardens. We were meeting with
+to advise her of the main terms
+of the Non-Prosecution Agreement. Among other information I provided, I told
+that
+an agreement had been reached, Mr. Epstein was going to plead guilty to two state charges, and
+there would not be a federal prosecution.
+2
+
+
+After my co-case agent and I met with
+land two other victims, I became
+concerned about what would happen if Jeffrey Epstein failed to perform his obligations under the
+Non-Prosecution Agreement. If Mr. Epstein breached or failed to perform those obligations, then
+the government would need to be ready to proceed with a prosecution. I was concerned that if the
+victims were informed of the Non-Prosecution Agreement, which included an option for victims
+to seek monetary damages in a civil matter, then Epstein's counsel would use the notifications to
+impeach me and the victims if a prosecution were to proceed in the future. Accordingly, after
+conferring with the U.S. Attorney's Office, a decision was made that no further notifications would
+be made at that time.
+10.
+After the Non-Prosecution Agreement was signed, in the last quarter of 2007 and
+continuing through 2008, the investigative team felt that there was a possibility that Epstein would
+breach or fail to perform the terms of the Agreement. Accordingly, the investigation continued in
+case the prosecution of Epstein would later proceed. The continuing investigation included
+additional witness interviews, service of grand jury subpoenas, and testimony before the grand
+jury.
+11.
+On January 31, 2008, as part of the continuing investigation of Jeffrey Epstein, I
+participated in an interview of
+with
+from the U.S. Attorney's Office
+and
+from the Justice Department.
+was re-interviewed in case Epstein
+breached or failed to perform under the Non-Prosecution Agreement.
+12.
+Throughout the investigation, we interviewed many victims that fell within the
+scope of Mr. Epstein's criminal activity. A majority of the victims expressed concern about the
+possible disclosure of their identities to the public. A number of the victims raised concerns about
+having to testify and/or their parents finding out about their involvement with Mr. Epstein.
+3
+
+
+Additionally, for some victims, learning of the Epstein investigation and possible exposure of their
+identities caused them emotional distress. Overall, many of the victims were troubled about the
+existence of the investigation. They displayed feelings of embarrassment and humiliation and
+were reluctant to talk to investigators. Some victims who were identified through the investigation
+refused even to speak to us.
+Our concerns about the victims' well-being and getting to the truth
+were always at the forefront of our handling of the investigation.
+During interviews conducted from 2006 to 2008, no victims expressed a strong
+opinion that Epstein be prosecuted. As noted above,
+expressed her opinion that
+nothing should happen to Epstein.
+I declare under penalty of perjury that the foregoing is true and correct.
+EXECUTED on May
+, 2017.
+E.
+West Palm Beach, Florida
+4
+
+
+Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 1 of 6
+MOTION FOR FINDING OF VIOLATIONS OF THE
+CRIME VICTIMS RIGHTS ACT
+AND REOUEST FOR A HEARING ON APPROPRIATI
+REMEDIES
+CASE NO: 08-80736-Civ-Marra/Johnson
+•
+
+
+
+Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 2 of 6
+FD-302 (Rev. 10-6-95)
+- 1-
+FEDERAL BUREAU OF INVESTIGATION
+Date of transcription 08/14/2007
+interviewed in West Palm Beach,
+investigation involving the sexual
+interviewing agent and here been are in ree dent vene
+the following information:
+In 2003 or 2004 was introduced to JEFFREY EPSTEIN
+for the purpose of providing him with personal massages. WI
+was
+approached at a party by a female she believed was named CHARLISE.
+she described the female as having brown hair and taller.
+The
+female was later identified as
+• told
+We and Wi
+that they could make money by
+providing massages to EPSTEIN.
+told won that she could
+provide the massages with her clothes on or off.
+WE who was
+fifteen years old,
+believed that she was close to turning sixteen
+when she first met EPSTEIN.
+*e first contact
+with EPSTEIN, she told him that she had just turned eignteen.
+and w
+• traveled to EPSTEIN's residence in Palm
+Beach by taxi
+was pregnant at the time.
+Once at the
+residence,
+took WI
+upstairs.
+EPSTEIN entered the room
+wearing only a robe.
+Once EPSTEIN had removed the robe,
+both
+and W
+• provided EPSTBIN With a massage.
+Both,
+and w
+• had removed their clothing and remained only in their
+underwear. EPSTEIN asked C
+to leave.
+Once alone with wan
+EPSTEIN began to masturbate.
+was uncomfortable.
+After
+EPSTEIN climaxed the massage was
+over. Wu believed that.
+had mentioned EPSTEIN might masturbate during the massage but she
+was still very surprised when he masturbated.
+EPSTEIN paid Wi
+$200.00.
+EPSTEIN did not touch Weduring that massage.
+departed EPSTEIN's residence with two men that worked for EPSTEIN.
+They drove WIto a Shell Gas Station located near Okeechobee
+Boulevard and the Florida Turnpike.
+Prior to departing the residence,
+provided her
+telephone number to one of EPSTEIN's assistants,
+(PHONETIC) •
+We described her as a very pretty Hispanic female in
+early twenties, with long brown hair. and approximately 5'5" to
+5'6" tall.
+•stated that |
+another of EPSTEIN's
+assistants, or EPSTEIN would usually contact her.
+•would
+telephone and ask if she was
+available or if she had any other
+Investigation on
+08/07/2007
+West Palm Beach, Florida
+File # 31E-MM-108062
+SA E
+by
+SA
+Date dictated
+08/07/2007
+This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency:
+it and its contents are not to be distributed outside your agency.
+
+
+Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 3 of 6
+FD-302в (Rev. 10-6-95)
+Continuation of FD-302 of
+. On 08/07/2007. Page
+2
+telephoned her they would inform her of when they would no coming
+back to town and if she might have anyone new.
+W
+traveled to the EPSTEIN's residence during 2003 and
+2004 over
+twenty five times.
+•believed that she provided
+EPSTEIN with approximately 10-15 massages.
+EPSTEIN initially
+started out touching Wh
+s breasts but gradually the massages
+became more sexual. EPSTEIN would instruct W on how and what to
+do during the massages. He would request WE to rub his chest and
+nipples.
+WI
+stated that on approximately two occasions, EPSTEIN
+asked that W
+remove her underwear and provide the massage nude.
+WI
+•complied.
+stated that EPSTEIN would make her feel that
+she had the option to do what she wanted.
+During one massage,
+stated that she had been giving
+BPSTEIN a massage for approximately 30-40 minutes when instead of
+EPSTEIN turning over to masturbate, EPSTEIN brought another female
+into the massage area.
+described the female as a beautiful
+blonde girl, a
+"Cameron Diaz" type, 19 years of age,
+bright blue
+eyes, and speaking with an accent.
+EPSTEIN had War straddle the
+female on the massage table.
+EPSTEIN wanted W to touch the
+females breast.
+According to We EPSTEIN "pleasured" the female
+while WI
+stated she
+could hear what she believed to be a vibrator.
+EPSTEIN it was all about pleasuring the female.
+climaxed, EPSTEIN patted Wi
+Don the shoulder and she removed
+herself from the table.
+'he temale got up from the table and went
+into the spa/sauna. EPSTEIN commented to Wil
+minutes the female
+would realize what had just happened to her.
+received $200.00.
+advised the interviewing agents that EPSTEIN ha
+used a back massager on her vagina.
+EPSTEIN asked her first if he
+could use the massager on her.
+Westated that she had held her
+breath when EPSTEIN
+used the back massager on her
+WE stated
+that at no time during any of the massages had EPSTEIN caused her
+to climax.
+During another massage, WE
+was seventeen, EPSTEIN placed his hand on w
+•believed by this time she
+• vagina, touchin
+
+
+Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 4 of 6
+, FD-302a (Rev. 10-6-95)
+Continuation of FD-302 of
+. on 08/07/2007, Page
+3
+clitoris.
+W
+was uncomfortable and told him to stop.
+EPSTEIN complied.
+•stated that the incident freaked her out.
+W stated that EPSTEIN was upset because she was upset.
+Wastated that she did not deal
+with EPSTEIN anymore after that incident.
+EPSTEIN gave both Wil
+• and Meach a book entitled
+"Massage for Dummies".
+They received the books on the same visit.
+EPSTEIN also commented how strong
+hands were when it came to
+her providing his massages.
+On another occasion, WE
+mentioned to EPSTEIN that she
+was looking at a car, a Toyota Corolla.
+EPSTEIN provided We
+•with
+$600.00 - $700.00.
+•stated that EPSTEIN gave her the money
+after the incident with the other female.
+According to W
+• EPSTEIN would ask her to bring him
+other girls.
+• who started dancing at strip clubs when she was
+b, brought girls from the club as well as from other sources.
+stated she brought girls from fifteen years or age to twentyfive years of age.
+• stated that EPSTEIN would get frustrated
+with
+„her if she did not have new females for him.
+On one instance,
+EPSTEIN hung up on her because she could not provide him with
+anyone new.
+•stated that EPSTEIN's preference was short,
+little, white girls.
+Wastated that EPSTEIN was upset when
+of the
+other girls brought a black girl. WED stated that EPSTEIN
+did not want black girls or girls with tatoos.
+WI
+stated that one of the girls she stayed with on
+occasion,
+• also started providing EPSTEIN with
+massages.
+A telephone number for
+said that her family resides in i
+Plorida, possibi
+Dalso stayed with
+- during this sar
+time period.
+However, C
+never
+went to EPSTEIN's house or
+provided him with massages.
+I has a Yacht Club address.
+Another girl that Wa
+•had taken to EPSTEIN's residence
+was L
+• Last Name Unknown (LNU) •
+According to we EPSTEIN
+liked
+• LNU a lot.
+• said that she was never a favorite of
+EPSTEIN. EPSTEIN offered Wi
+$300.00 to bring I
+• LNU.
+LNU was a couple years younger than W
+Wi believed that she
+was either 16 or 17 when she first went to EPSTEIN's residence.
+wetsaid that LL
+INU went 2-3 times but that she did not want
+any part of it after that.
+WaN believes she could identify Le
+LNU if she saw her photograph.
+• also stated that Li
+• LNU at
+
+
+Case 9:08-Cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 5 of 6
+FD-3028 (Rev. 10-6-95)
+31B-MM-108062
+, On 08/07/2007. Page
+Continuation of FD-302 of
+4
+one time attended
+• HIGH SCHOOL. WiNDalso
+Detended that they dad met treen roof friends while
+attending l
+mentioned another girl by the name of cl
+EPSTEIN distinguished the two "d
+• by referring to
+• worked at an ice cream
+shop.
+•stated that she did not like Il
+• and that L
+was a storyteller and a bad liar.
+we stated that I
+really wanted to go to EPSTEIN's residence but she went anyway.
+said that she had not taken a good look at EPSTEIN's
+penis.
+hide his penis.
+explained that it seemed like he would always try and
+• stated that EPSTEIN never asked her for sex.
+started dancing when she was sixteen at
+The owner,
+let her dance.
+•has also
+• located
+in Boynton
+worked at
+Beach, Florida.
+used illegal drugs during the years she provided
+EPSTEIN with massages.
+W. said that EPSTEIN tried to provide her
+with advice regarding controlled substances.
+stated that she met with EPSTEIN's attorneys,
+a unidentified female (UF), at
+the ALE HOUSE RESTAURANT.
+met with them after she contacted
+who confirmed that
+they were really working for EPSTEIN.
+stated that|
+also
+talked of her twin boys and stated that she was living in
+Manhattan. W
+→ found out that and the UF are employed by
+They asked a lot of questions.
+specifically asked about LE
+and a GIN LNU.
+They
+reiterated
+her dislike for Li
+spoken to MI
+told wo
+•that she had met with investigators and that they had
+videoed her.
+confirmed her association to the following telephone
+numbers:
+Old cellular number - (
+Possibly an old
+cellular numbe
+"s telephone number
+
+
+Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 6 of 6
+FD-3028 (Rev. 10-6-95)
+Continuation of FD-302 of
+,On _08/07/2007_
+_. Page -
+"'...
+- 42
+..".
+.".
+
+
+• Case 9:08-cv-80736-KAM Document 48-8 Entered on FLSD Docket 03/21/2011 Page 1 of 3
+I MOTION FOR FINDING OF VIOLATIONS OF THE
+CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE
+REMEDIES
+CASE NO:
+
+
+
+Case 9:08-cv-80736-KAM Document 48-8
+Entered on FLSD Docket 03/21/2011 Page 2 of 3
+, FD-302 (Rev. 10-6-95)
+- 1 -
+FEDERAL BUREAU OF INVESTIGATION
+Date of transcription
+02/08/2008
+On Thursday, January 31, 2008, C
+-met with
+Assistant United States Attorney |
+ATTORNEY'S OFFICE (USAO) and Attorney
+MYESHA RI
+UNITED STATES
+STATES DEPARTMENT OF JUSTICE (DOJ), CRIMINAL DIVISION.
+at the meeting were Special Agents B.
+FEDERAL BUREAU OF INVESTIGATION!
+arranged
+pursuant to a federal investigation regarding the sexual
+exploitation of minors. During the course of the meeting, we
+provided the following additional or clarifying information not
+previously documented in earlier FD-302s:
+JEFFREY EPSTEIN and his assistants, SARAH and
+(identified as
+and
+would
+contact word to set up appointments for EPSTEIN'S massages.
+According to WO
+• would call and say that EPSTEIN was on
+a flight and inquire about scheduling work for l
+Life was not going well for W
+during the time she was
+providing EPSTEIN with massages.
+We was buying and taking drugs,
+1.e. Xanax, Lorcets, and Percosets.
+wen said that she stayed on
+•explained that she wanted to feel numb.
+• stopped
+attending school
+at age fifteen. Her parents were addicted to
+crack and cocaine. Prior to her parent's drug use,.
+• was in the
+band, a cheerleader, and a straight "A" student.
+played the
+trumpet for the school band.
+When her parent's drug habits got
+bad, things went downhill, they lost everything.
+became a dancer the day before her sixteenth
+birthday at
+She worked there for six months,
+up 'until the employer found out she was underage.
+Later,
+worked for l
+which
+she did for 6 months.
+stopped
+seeing EPSTEIN during that time.
+or thirty different girls.
+We said all
+ten of them were underage.
+EPSTEIN were dancers.
+of the girls she brought to him.
+- Bone chat sprained that Sparin ail
+not care for some of the dancers, the older females, and the
+females with tattoos.
+Investigation on
+01/31/2008
+File # 31E-MM-108062
+SA B. ||/
+by
+SA
+West Palm Beach, Florida
+Date dictated 01/31/2008
+This document contains neither recommendations nor conclusions of the FBI. It is the property of the FB) and is loaned to your agency;
+in and its contents are not to be distributed outside your agency.
+
+
+Case 9:08-cv-80736-KAM Document 48-8 Entered on FLSD Docket 03/21/2011 Page 3 of 3
+FD-3020 (Rev. 10-6-95)
+Continuation of FD-302 of
+, On 01/31/2008, Page.
+said that during the massages EPSTEIN would push
+quath spare never asked ng he okay, he wouia Just see to
+far one would let him go.
+recalled seeing sculptures of naked women and lot
+f pictures of kids in the library
+5:
+stated that everybody thought Epstein was a
+neurologist.
+S
+also
+stated that
+twin. boys.
+2-
+:
+.:.
+....ї
+
+
+- Case 9:08-CV-80736-KAM Document |]
+Entered on FLSD Docket 07/19/2013 Page 1 of 2
+Case No. 08-80736-Civ-Marra/Matthewman
+Petitioners,
+UNITED STATES OF AMERICA,
+Respondent.
+UNITED STATES' NOTICE OF FILING PRIVILEGE LOG
+Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United
+States of America, by and through the undersigned Assistant United States Attorney, hereby gives
+notice of its filing of its Privilege Log, which is attached hereto.
+The documents referenced in the Privilege Log are being delivered today to the Chambers
+of U.S. District Judge Kenneth A. Marra for ex parte in camera review, pursuant to the Court's
+Omnibus Order.
+By:
+Respectfully submitted,
+UNITED STATES ATTORNEY
+s/A.
+Villafaña
+Florida Bar No. 0018255
+500 South Australian Ave, Suite 400
+Weis Palm Beach. FL. 3401
+
+
+Entered on FLSD Docket 07/19/2013 Page 2 of 2
+I HEREBY CERTIFY that on July 19, 2013, I electronically filed the foregoing document
+with the Clerk of the Court using CM/ECF. According to the Court's website, counsel for all parties
+are able to receive notice via the CM/ECF system.
+SERVICE LIST
+United States,
+Case No. 08-80736-CIV-MARRA/MATTHEWMAN
+United States District Court, Southern District of Florida
+Brad Edwards, Esq.,
+Farmer Jaffe Weissing Edwards Fistos Lehrman
+425 N Andrews Ave Ste 2
+Fort Lauderdale, FL 33301-3268
+brad@pathtojustice.com
+954-524-2820
+Fax: 954-524-2822
+Paul G. Cassell
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, Utah 84112
+(801) 585-5202
+Fax: (801) 585-6833
+E-mail: casselp@law.utah.edu
+Attorneys for
+2
+
+
+• Case 9:08-CV-80736-KAM Document
+-1 Entered on FLSD Docket 07/19/2013 Page 1 of 23
+PRIVILEGE LOG
+Description
+P-000001
+thru
+P-000039
+P-000040
+thru
+P-000549
+P-000550
+thru
+P-000621
+File folder entitled "Ritz Compact Flash SW"
+containing copies of a sealed search warrant
+application, warrant, and supporting documents
+P-000622
+thru
+P-000693
+File folder entitled "PNY Technologies Compact
+Flash SW" containing copies of a sealed search
+warrant application, warrant, and supporting
+documents
+P-000694
+thru
+P-000781
+P-000782
+thru
+P-000803
+P-000804
+thru
+P-000854
+File folder entitled "JE Corporations" containing
+attorney research on Epstein-owned corporations
+and prior litigation
+File folder entitled "Capital One"
+containing subpoena and correspondence
+File folder entitled "DTG Operations/Dollar
+Rent-a-Car" containing subpoena and responsive
+Contains documents subject
+to investigative privilege
+Also contains documents
+subject to privacy rights of
+rictims who are not parties t
+this litigation
+Contains information subject
+to investigative privilege
+Also contains information
+subject to privacy rights of
+victims who are not parties te
+this litigation
+Contains information subject
+to investigative privilege
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+Contains information subject
+to investigative privilege
+information subject to
+investigative privilege
+
+
+
+Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 2 of 23
+P-000855
+thru
+P-000937
+P-000938
+thru
+P-000947
+P-000948
+thru
+P-000982
+File folder entic riptiMorgan Chase®
+containing subpoena, correspondence, and
+responsive documents
+File folder entitled "Washington Mutual"
+containing subpoena, correspondence, and
+responsive documents
+File folder entitled "Computer Search &"
+containing legal research on computer search and
+handwritten notes on indictment preparation
+P-000983
+thru
+P-001007
+File folder entitled "Attorney Notes from
+Document Review" containing typed and
+handwritten attorney
+) notes, target
+letters, correspondence re grand jury subpoena
+P-001008
+thru
+P-001056
+File folder entitled "Notes from Fed Ex Records"
+containing handwritten and typed attorney
+) notes and screen shots of FedEx
+subpoena response electronic file
+Contains documents and
+information subject to
+investigative privilege
+Contains documents and
+information subject to
+investigative privilege
+Attorney-Client
+Contains information subject
+to investigative privilege.
+Also contains information
+vicine to piracy paris to
+this litigation
+Contains information subject
+to investigative privilege.
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+this litigation
+Contains information subject
+to investigative privilege.
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+Contains information subject
+to investigative privilege
+P-001057
+thru
+P-001959
+P-001960
+Thru
+P-002089
+ile folder entitled "Colonial Bank Records
+ontaining records received in response to gran
+jury subpoena
+File folder entitled "OLY Grand Jury Log Vol 2:
+OLY-51 THROUGH" containing subpoenas
+lumbered OLY-51 through OLY-81 with related
+
+
+
+, Case 9:08-CV-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 3 of 23
+P-002090
+Thru
+P-002169
+P-002170
+Thru
+P-002246
+P-002247
+Thru
+P-002265
+P-002266
+Thru
+P-002386
+Description
+File folder entitled "Epstein Corporate Records:
+OLY-51, OLY-52, OLY-53, OLY-54" containing
+subpoenas, records received in response to
+subpoenas, and related correspondence
+File folder entitled "Colonial Bank" containing
+subpoenas, correspondence related to subpoenas,
+records received in response to subpoenas
+File folder entitled "JEGE & Hyperion from
+Goldberger OL Y-46 & OLY-47" containing
+documents received in response to subpoenas
+Indictment preparation binder containing:
+Grand jury subpoena log, evidence/activity
+summary chart, witness/victim names and contact
+list, attorney (
+) handwritten notes, 302s,
+portions of state investigative file, attorney
+) typed notes, of individuals listed as
+"Additional victims"
+P-002387
+Thru
+P-002769
+jrand jury subpoena log, evidence/activit
+summary chart, witness/victim names and contac
+P-002770
+Thru
+P-003211
+persons identified as
+Past Employees, Misc. Witnesses
+itness/victim list with identifying informatio
+exual activity summary, telephone call summa
+chart, attorney (
+Contains information and
+documents subject to
+investigative privilege
+Contains information and
+documents subject to
+investigative privilege
+Contains information and
+documents subject to
+investigative privilege. Also
+contains information and
+documents subject to privacy
+rights of victims who are not
+Contains information and
+documents subject to
+investigative privilege. Also
+contains information and
+documents subject to privacy
+rights of victims who are not
+Contains information and
+documents subject to
+investigative privilege. Also
+analysis charts, victim/witness photographs,
+DAVID records, NCICs, and related materials for
+persons identified as
+8
+
+
+
+Case 9:08-cV-80736-KAM Document
+1 Entered on FLSD Docket 07/19/2013 Page 4 of 23
+P-003212
+Thru
+P-003545
+Description
+Indictment preparation binder containing metaanalysis charts of telephone/flight/grand jury
+information for a number of victim/witnesses,
+and
+P-003546
+Thru
+P-003552
+FBI Reports of March 2008 interviews of
+additional witness/victim located in New York
+Contains information and
+documents subject to
+investigative privilege. Also
+contains information and
+documents subject to privacy
+rights of victims who are not
+Contains information and
+documents subject to
+investigative privilege. Also
+P-003553
+Thru
+P-003555B
+P-003556
+Thru
+P-003562
+P-003563
+Thru
+P-003629
+P-003630
+Thru
+P-003633
+P-003634
+Thru
+P-003646
+Printout of filenames from Federal Express
+subpoena response with Attorney notations
+Document entitled "Identified Numbers" with
+accompanying handwritten attorney list compiled
+from grand jury materials and attorney analysis of
+records
+Folder entitled "Flight Manifests" containing
+manifests received pursuant to grand jury
+subpoena
+File folder entitled "Recent Attorney Notes"
+containing handwritten attorney (
+D notes
+regarding document review and case strategy
+File folder bearing victim name containing FBI
+interview report from May 2008, telephone
+activity report with attorney
+handwritten notes, related grand jury material
+Contains information subject
+to investigative privilege
+Contains information and
+documents subject to
+investigative privilege
+Attorney-client privilege
+Also contains information anc
+documents subject to privacy
+rights of victims who are not
+
+
+
+. Case 9:08-CV-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 5 of 23
+P-003647
+Thru
+P-003651
+Description
+File folder entitled "Summary of Sexual Activity"
+containing chart bearing handwritten title "Sexual
+Activity - Summary" with meta-analysis of
+P-003652
+Thru
+P-003663
+P-003664
+Thru
+P-003678
+P-003679
+Thru
+P-003680
+P-003681
+Thru
+P-003687
+P-003688
+Thru
+P-003693
+P-003694
+Thru
+P-003711
+File folder entitled "Victim Civil Suits"
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+Not privileged.
+Produced to counsel for
+File folder entitled "Research re JE Websites"
+containing attorney research
+File folder entitled "
+containing attorney (
+(N.Y. AUSA)"
+) handwritten notes
+File folder entitled "Dr. Anna Salter" containing
+attorney (
+D memo to expert witness and
+handwritten attorney notes
+File folder entitled "ID G[] Interview" containing
+attorney handwritten notes of interview, and
+attorney handwritten notes regarding potential
+File folder entitled "Research re Travel fol
+Prostitution" containing attorney (
+presentation, chart entitled "Brought to Epstein's
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+P-003712
+information
+Empty file folder bearing name of victim/witness
+
+
+
+Entered on FLSD Docket 07/19/2013 Page 6 of 23
+P-003713
+Thru
+P-003746
+P-003747
+Thru
+P-003751
+P-003752
+Thru
+P-004295
+P-004296
+Thru
+P-004350
+Description
+File folder entitled "T[] M[" containing grand
+jury subpoenas, motion and order to compel
+testimony, and correspondence regarding same
+File folder entitled"
+" containing
+subpoena and correspondence regarding same
+File folder entitled "PBPD Investigative File"
+obtained via subpoena
+Documents under seal
+pursuant to court order
+File folder bearing name of victim/witness
+containing meta-analysis chart showing telephone
+calls, travel, and grand jury materials relevant to
+possible charges
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+P-004351
+Thru
+P-004381
+P-004382
+Thru
+P-004478
+P-004479
+Thru
+P-004551
+P-004552
+Thru
+P-004555
+File folder entitled "
+Documents
+53909-004" containing attorney research related
+to bias issue
+File Folder entitled "FEDEX" containing
+documents obtained via subpoena
+File Folder entitled "State of Delaware Records"
+containing documents obtained in preparation for
+indictment
+File folder entitled "Jet Blue Records" containing
+documents obtained via subpoena
+Also contains information and
+P-004556
+Thru
+P-004560
+File folder entitled "FL EMPLOYMENT
+RECORDS" containing FDLE records on targets
+and witnesses obtained at attorney request
+nvestigative privileg
+Vork produ
+
+
+
+. Case 9:08-CV-80736-KAM Document
+1 Entered on FLSD Docket 07/19/2013 Page 7 of 23
+P-004561
+Thru
+P-004565
+P-004566
+Thru
+P-004716
+Description
+Filed folder entitled "JANUSZ BANASIAK"
+containing attorney (
+) handwritten notes
+of interview
+File folder entitled "JANUSZ BANASIAK
+RECORDS 23-0001 THROUGH 23-" containing
+documents obtained via subpoena
+Also contains information anc
+locuments subject to privac
+rights of victims who are not
+P-004717
+Thru
+P-004722
+P-004723
+Thru
+P-004725
+P-004726
+Thru
+P-004819
+P-004820
+Thru
+P-004959
+P-004960
+Thru
+P-005059
+File folder entitled "IGOR ZINOVIEV"
+containing attorney research regarding witness
+File folder entitled "BEAR STEARNS
+RESEARCH" containing attorney research
+regarding potential witness and subpoena
+recipient
+File folder entitled "LAWSUITS INVOLVING
+EPSTEIN CORP'S" containing attorney research
+regarding Epstein's past personal and business
+Filed folder entitled "SEC RECORDS"
+containing attorney research regarding Epstein
+File folder entitled "Message Pads" containing
+selected items from evidence obtained via
+subpoena
+P-005060
+Thru
+P-005081
+File folder bearing name of victim/witness
+notes regarding witness reports and case
+preparation
+File folder entitled "New York Trip" containing
+attorney notes re witness interview
+P-005082
+Thru
+P-005083
+
+
+
+Case 9:08-CV-80736-KAM Document |
+Entered on FLSD Docket 07/19/2013 Page 8 of 23
+P-005108
+Thru
+P-005193
+P-005194
+Thru
+P-005300
+Description
+P-005084 thru P-005107 are non responsive
+P-005301
+Thru
+P-005331
+P-005332
+Thru
+P-005341
+P-005342
+Thru
+P-005387
+P-005388
+Thru
+P-005442
+File folder entitled "JUAN ALESSI
+STATEMENT" containing transcript obtained via
+subpoena
+File folder entitled "KEN LANNING" containing
+attorney research on select expert, including
+attorney handwritten notes
+File folder entitled "Info re Planes" containing
+correspondence regarding subpoenas and
+documents received in response to subpoenas
+File folder entitled "Police Reports & PC
+Affidavit" containing portions of police reports
+with attorney notes, related phone records, a list
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+parties to this litigatior
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+P-005443
+Thru
+P-005496
+P-005497
+Thru
+P-005556
+File folde entervied" Gi Transel pranscript of
+File folder entitled "Bear Stearns Subpoena
+Resp." containing material received in response
+to subpoena
+
+
+
+Entered on FLSD Docket 07/19/2013 Page 9 of 23
+P-005557
+Thru
+P-005576
+P-005578
+Thru
+P-005583
+P-005584
+Thru
+P-005606
+Description
+U.S. Attorney's Office Criminal Case File Jacket
+containing file opening documents, exper
+witness payment documents
+U.S. Attorney's Office Asset Forfeiture Case File
+Jacket containing file opening and file closing
+documents
+File folder entitled "6001 Immunity Request"
+containing internal memoranda seeking witness
+immunity and correspondence with counsel for
+witness regarding same
+Box #2
+P-005607
+Thru
+P-005914
+File folder entitled "MASTER PHONE
+ECORDS" containing meta-analysis of a
+hone, travel, and grand jury data for al
+victim/witnesses for indictment preparation
+Box #2
+P-005915
+Thru
+P-005977
+File folder bearing name of victim/witness
+phone, travel. and
+graininy data ratated is ohat vicine traves, fo
+Box #2
+P-005978
+Thru
+P-006050
+File folder bearing name of victim/witness
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+Box #2
+P-006051
+Thru
+P-006065
+File folder bearing name of victim/witness
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+Work product and
+deliberative process (as to
+nternal memoranda
+avestigative privileg
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+Work produet
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+
+
+
+Case 9:08-CV-80736-KAM Document |
+Box #2
+P-006066
+Thru
+P-006220
+•1
+Entered on FLSD Docket 07/19/2013 Page 10 of
+23
+Description
+File folder entitled •
+• containin
+neta-analysis of all phone, travel, and grand jur
+data related to that victim/witness for indictment
+preparation
+Box #2
+P-006221
+Thru
+P-006222
+File folder entitled
+containing
+meta-analysis of all phone, travel, and grand jury
+data related to that victim/witness for indictment
+preparation
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+Box #2
+P-006223
+Thru
+P-006522
+File folder entitled "CORRECTED PHONE
+RECORDS 5/31/07" containing meta-analysis of
+all phone, travel, and grand jury data related to all
+victims/witnesses for indictment preparation
+Box #2
+P-006523
+Thru
+P-006802
+File folder entitled "Victim Name] Phone
+Records" containing telephone records received
+in response to subpoena
+Box #2
+P-006803
+Thru
+P-006860
+Box #2
+P-006861
+Thru
+P-007785
+File folder entitled "Lists of Identified Phone
+Numbers" containing charts of information culled
+from grand jury materials, interviews, and other
+investigation, with attorney handwritten notes,
+and information to issue follow-up grand jury
+File folder entitled "EPSTEIN/
+notes and highlighting
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+Also contains information and
+Highs of victims who prene
+
+
+
+. Case 9:08-CV-80736-KAM Document
+•1
+Entered on FLSD Docket 07/19/2013 Page 11 of
+Box #2
+P-007786
+Thru
+P-008120
+Description
+Folder entitled "OLY GRAND JURY LOG:
+OLY-01 THROUGH OLY-50" containing
+subpoenas, correspondence regarding same, 6(e)
+letters, attorney handwritten notes regarding
+records received in response to subpoenas
+Handwritten flight logs received in response to
+subpoena
+Box #2
+P-008121
+Thru
+P-008139
+Box #2
+P-008140
+Thru
+P-008298
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+package dated 2/19/2008
+idekazing int mation, vitograjs, jind
+summary of activity
+File folder entitled "FINAL AGREEMENTS"
+Box #2
+P-008299
+Thru
+P-008363
+Box #2
+P-008364
+Thru
+P-008382
+Box #2
+P-008383
+Thru
+P-008516
+Circuit
+File folder entitled "
+Immunity Request"
+containing internal memoranda, Justice
+Department documentation, and subpoen
+regarding immunity request
+File folder containing March 18, 2008 grand jury
+presentation materials, including "Operation Leap
+Year Revised Indictment Summary Chart (by
+victim)," grand jury materials, draft indictments,
+victim reference list, grand jury subpoena log
+Also contains information and
+locuments subject to privac
+ights of victims who are no
+
+
+
+1 Entered on FLSD Docket 07/19/2013 Page 12, of
+Box #2
+P-008517
+Thru
+P-008535
+Box #2
+P-008536
+Thru
+P-008542
+Box #2
+P-008543
+Thru
+P-008549
+Box #2
+P-008550
+Thru
+P-008615
+Description
+6/25/2007 Letter from Gerald Lefcourt to Jeffrey
+[pursuant to Court's Order, not being withheld as
+privileged - will be produced to opposing counsel
+upon lift of stay by 11" Circuit]
+Handwritten attorney notes to prepare for
+Handwritten attorney notes regarding May 8,
+2007 grand jury presentation
+File folder entitled "Most Recent Indictment &
+Good Cases" containing draft indictment and
+legal research
+Box #2
+P-008616
+Thru
+P-008686
+Box #2
+P-008687
+Thru
+P-008776
+File folder entitled "FBI Summary Charts"
+containing chart prepared at direction of AUSA,
+containing victim names, identifying information,
+summary of activity, and other information
+relevant to indictment
+File folder entitled "[Victim name
+containing phone records and meta-analysis of all
+phone, travel, and grand jury data related to that
+victim/witness for indictment preparation
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Box #2
+P-008777
+Thru
+P-008808
+File folder entitled "[Victim name
+nd meta-ama vs
+Fantaining arader, aten notes and nata related
+that victim/witness for indictment preparation
+who are not parties to this suit
+
+
+
+• Case 9:08-Cv-80736-KAM Document/
+Entered on FLSD Docket 07/19/2013 Page 13 of
+Box #2
+P-008809
+Thru
+P-008847
+Box #2
+P-008848
+Thru
+P-008862
+Box #2
+P-008863
+Thru
+P-008890
+Box #2
+P-008891
+Thru
+P-009103
+Box #2
+P-009104
+Thru
+P-009111
+Box #2
+P-009112
+Thru
+P-009113
+Box #2
+P-009114
+Thru
+P-009115
+Box #2
+P-009116
+Thru
+P-009125
+Description
+File folder entitled "[Victim name)
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+indictment preparation
+File folder entitled "[Victim name]
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+indictment preparation
+File folder entitled "[Victim name]/,
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+indictment preparation
+File folder entitled "Certified Copy of State Case"
+containing certified copy of Epstein state criminal
+cases and change of plea transcript [not being
+withheld as privileged - copy provided to
+File folder entitled "Meeting Timeline"
+I typed notes summarizing
+meetings with opposing counsel prepared at
+request of R.
+with handwritten
+correction and typed guideline estimate
+11/26/2008 Email from Roy Black to A. I
+and
+re Jeffrey Epstein
+(work release)
+[pursuant to Court's Order, not being withheld as
+privileged - will be produced to opposing counsel
+upon lift of stay by 11" Circuit]
+7/3/2008 Email from
+to Col.
+M. Gauger at PBSO re Epstein work release with
+attachment [not being withheld as privileged -
+produced to opposing counsel]
+12/6/2007 Letter from
+to Jay P.
+Lefkowitz re Jeffrey Epstein (victim notification)
+[pursuant to Court's Order, not being withheld as
+privileged - will be produced to opposing counsel
+upon lift of stay by 11" Circuit])
+Contains information subject
+to privacy rights of victim:
+ho are not parties to this sui
+
+
+
+Case 9:08-cv-80736-KAM Document 212-1
+Entered on FLSD Docket 07/19/2013 Page 14.of
+Box #2
+P-009126
+Thru
+P-009134
+Box #2
+P-009135
+Thru
+P-009141
+Box #2
+P-009141A
+Thru
+P-009141C
+Box #2
+P-009142
+Thru
+P-009152
+Description
+File folder entitled "[Victim name
+ontaining meta-analysis of all phone, travel, an
+rand jury data related to that victim/witness fo
+indictment preparation
+File folder entitled "[Victim name
+containing meta-analysis of all phone,
+travel, and grand jury data related to that
+victim/witness for indictment preparation
+File folder entitled "[Victim name]/
+containing meta-analysis of all phone,
+travel, and grand jury data related to that
+victim/witness for indictment preparation
+File folder entitled "1
+containing meta-analysis of all phone, travel, and
+grand jury data related to that individual for
+indictment preparation
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Contains information subject
+o privacy rights of victim:
+who are not parties to this sui
+Box #2
+P-009153
+Thru
+P-009156
+Box #2
+P-009157
+Thru
+P-009208
+Box #2
+P-009209
+Thru
+P-009213
+File folder entitled "
+containing meta-analysis of all phone, travel, and
+grand jury data related to that individual for
+indictment preparation
+File folder entitled "[Victim name]
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+indictment preparation
+File folder entitled "[Victim name
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+indictment preparation
+
+
+
+Case 9:08-Cv-80736-KAM Document|
+. Entered on FLSD Docket 07/19/2013 Page 15 of
+Box #2
+P-009214
+Thru
+P-009271
+Box #2
+P-009272
+Thru
+P-009354
+Box #2
+P-009355
+Thru
+P-009403
+Box #2
+P-009404
+Thru
+P-009536
+Box #2
+P-009537
+Thru
+P-009574
+Box #2
+P-009575
+Thru
+P-009603
+Box #2
+P-009604
+Thru
+P-009711
+Box #2
+P-009712
+Thru
+P-009819
+Box #2
+P-009820
+Thru
+P-009965
+Box #2
+P-009966
+Thru
+P-010096
+Description
+File folder entitled "[Victim name]
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+indictment preparation
+File folder entitled "Purpose of Travel Cases"
+containing attorney research and handwritten
+notes
+File folder entitled "Interstate Commerce Cases"
+containing attorney research and handwritten
+notes
+File folder entitled "Attorney Conflict Research"
+containing attorney research and handwritten
+notes
+File folder entitled "Mann Act/Travel to Have
+Sex w/Minor" containing attorney research and
+handwritten notes
+File folder entitled "Travel Act" containing
+attorney research and handwritten notes
+File folder entitled "Florida
+Prostitution/Lewdness Statutes" containing
+attorney research and handwritten notes
+Booklet entitled "Attorney General Guidelines for
+Victim and Witness Assistance" [not being
+withheld as privileged - produced to opposing
+counsel]
+File folder entitled "Corporate Liability Rsrch"
+containing attorney research and handwritten
+notes
+File folder entitled "Research re Knowledge of
+age Unnecessary" containing attorney researcl
+nd handwritten notes and copy of grand jur
+subpoena
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+
+
+
+-1 Entered on FLSD Docket 07/19/2013 Page 16 of
+Box #2
+P-010097
+Thru
+P-010276
+Box #2
+P-010277
+Thru
+P-010394
+Box #2
+P-010395
+Thru
+P-010488
+Box #2
+P-010489
+Thru
+P-010509
+Box #2
+P-010510
+Thru
+P-010525
+Box #2
+P-010526
+Thru
+P-010641
+Description
+File folder entitled "Money Laundering"
+containing attorney research and handwritten
+notes
+File folder entitled "1960 & Aiding/Abetting"
+containing attorney research and handwritten
+notes
+File folder entitled "18 USC § 2255 Cases"
+containing attorney research and handwritten
+notes
+File folder entitled "Research re Overt Acts &
+Witness Testimony" containing attorney research
+and handwritten notes
+File folder entitled "Extradition" containing
+attorney research and handwritten notes
+File folder entitled "Rsrch re Crime Victims
+Rights" containing attorney research, handwritten
+notes, draft victim notification letter, and draft
+correspondence to Jay Lefkowitz
+(Also contains a November 28, 2007 letter from
+Kenneth Starr to Alice S. Fisher; and a November
+29, 2007 letter from Jay Lefkowitz to R.
+Alexander Acosta (P-010528 thru P-010530 and
+-010556 thru P-010559). Pursuant to the
+Court's Order, these will be produced to opposing
+counsel upon lift of stay by 11" Circuit)
+Box #2
+P-010642
+Thru
+P-01650
+Box #2
+P-010651
+Thru
+P-010659
+Box #2
+P-010660
+Thru
+P-010757
+with subpoena
+File folder entitled "Research re GJ Transcript"
+
+
+
+Case 9:08-Cv-80736-KAM Document
+1 Entered on FLSD Docket 07/19/2013 Page 17 of
+Box #2
+P-010758
+Thru
+P-010793
+Box #2
+P-010794
+Thru
+P-010829
+Box #2
+P-010830
+Thru
+P-010853
+Box #2
+P-010854
+Thru
+P-010876
+Box #2
+P-010877
+Thru
+P-010920
+Box #2
+P-010921
+Thru
+P-011049
+Box #2
+P-011050
+Thru
+P-011212
+Box #2
+P-011213
+Thru
+P-011237
+Box #2
+P-011238
+Thru
+P-011319
+Box #2
+P-011320
+Thru
+P-011361
+Box #2
+P-011362
+Thru
+P-011374
+Description
+File folder entitled "Original Proposed Ind."
+containing draft indictment
+File folder entitled "Epstein" containing sample
+indictments and attorney research re potential
+charges with attorney notes
+File folder entitled "1591 & Money Laundering"
+containing attorney research and handwritten
+notes
+File folder entitled "18 USC 2425 containing
+attorney research and handwritten notes
+File folder entitled "Knowledge of Age"
+containing attorney research and handwritten
+notes
+File folder entitled "2423(b) Constitutionality and
+Purpose of Travel" containing attorney research
+and handwritten notes
+File folder entitled "Mistake not a
+Defense" containing attorney research and
+handwritten notes
+File folder entitled "Research re "Pandering'"
+containing attorney research and handwritten
+notes
+File folder entitled "Research re Grand Jury
+Instructions" containing attorney research and
+handwritten notes
+File folder entitled "Telephone = Facility of
+Commerce" containing attorney research and
+handwritten notes
+File folder entitled "Def of Prostitution"
+containing attorney research and handwritten
+
+
+
+Case 9:08-CV-80736-KAM Document|
+-1 Entered on FLSD Docket 07/19/2013 Page 18.of
+Box #2
+P-011375
+Thru
+P-011456
+Box #2
+P-011457
+Thru
+P-011626
+Box #3
+P-011627
+Thru
+P-011662
+Box #3
+P-011663
+Thru
+P-011698 and
+P-012189 thru
+P-012361
+(gap was
+scanning error)
+Box #3
+P-011699
+Thru
+P-011777
+Box #3
+P-011778
+Thru
+P-011788
+Box #3
+P-011789
+Thru
+P-011879
+Box #3
+P-011880
+Thru
+P-011922
+Descriptio
+ile folder entitled "Relevant Florida Statutes
+containing attorney research and handwritten
+notes
+File folder entitled "Unit of Prosecution
+Research" containing attorney research and
+handwritten notes
+File folder entitled "Attorney Notes" containing
+attorney handwritten and typed notes
+File folder entitled "Drafts" containing draft
+indictments with attorney handwritten notes, draft
+internal memoranda, relevant witness interview
+reports and grand jury material and attorney
+handwritten notes
+Contains information subject
+to privacy rights of victims
+who are not parties to this
+File folder entitled "6/9/09 Signed Indictment"
+containing signed indictment package dated
+6/9/2009 with corrections
+File folder entitled "6/12/09 Victim Notif. Log"
+containing chart with victim contact information
+and attorney notes regarding dates and type of
+contacts
+File folder entitled "Breach Memo" containing
+memorandum analyzing breach of Non-
+Prosecution Agreement with attachments
+File folder entitled "Overt Act Lists" containing
+landwritten notes cross-checking all overt act
+lleged in draft indictment by victim and type
+overt act summary charts for indictment
+preparation
+Attorney-client privilege
+
+
+
+1 Entered on FLSD Docket 07/19/2013 Page 19 of
+Box #3
+P-011923
+Thru
+P-011966
+Description
+Folder entitled "Responses to Arguments from JE
+Counsel" containing:
+7/13/2007 letter from Lilly Ann Sanchez
+with handwritten
+attorney (
+notes;
+• 6/25/2007 letter from Gerald Lefcourt to
+Jeffrey Sloman,
+Menchal,
+and
+handwritten attorney (
+with
+I notes:
+• 6/25/2007 email from
+and
+entitled "Thoughts on Lefcourt's letter"
+Handwritten and typed attorney (
+D) notes
+regarding main themes raised by Epstein counsel
+Composition book entitled "Operation Leap
+Year" containing attorney handwritten notes
+Box #3
+P-011967
+Thru
+P-012016
+Contains information subject
+to privacy rights of victims
+who are not parties to this
+litigation
+Box #3
+P-012017
+Thru
+P-012055
+Box #3
+P-012056
+Thru
+P-012088
+Box #3
+P-012089
+Thru
+P-012129
+Box #3
+P-012130
+Thru
+P-012150
+Box #3
+P-012151
+Thru
+P-012167
+Motion of Jeffrey Epstein to Intervene and to
+Quash Grand Jury Subpoenas and Incorporated
+Memorandum of Law
+Affidavit of Roy Black, Esq. in Support of
+Motion of Jeffrey Epstein to Intervene and to
+Quash Grand Jury Subpoenas
+United States' Response to Motion of Jeffrey
+Epstein to Intervene and to Quash Grand Jury
+Subpoenas and Cross-Motion to Compel
+Declaration of Joseph Recarey
+Ex Parte Declaration Number One in Support of
+United States' Response to Motion to Quash
+Subpoenas
+
+
+
+41 Entered on FLSD Docket 07/19/2013 Page 20 of
+Box #3
+P-012168
+Thru
+P-012170
+Box #3
+P-012171
+Thru
+P-012173
+Box #3
+P-012174
+Thru
+P-012176
+Box #3
+P-012177
+Thru
+P-012178
+Box #3
+P-012179
+Thru
+P-012188
+Description
+Ex Parte Declaration Number Two in Support of
+United States' Response to Motion to Quash
+Supplement to Ex Parte Declaration Number One
+in Support of United States' Response to Motion
+to Quash Subpoenas
+Draft of September 2009 letter from
+Prosecuton Age Back reading ren of rey
+Undated handwritten attorney (
+notes
+regarding negotiations and allegations
+File Folder entitled "FBI G.J. Log" containing
+copy of FBI grand jury subpoena log with
+Box #3
+P-012362
+Thru
+P-012451
+File folder entitled "Key Documents" containing
+correspondence between AUSA and case agent
+regarding indictment prep questions, victim
+identification information, corrections to draft
+indictment, indictment preparation timeline, ker
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+this litigation
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+this litigation
+Attorney-Client privilege
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+Box #3
+P-012451
+Thru
+P-012452
+File folder entitled "Victim List" containing list
+of victims with dates of birth and age information
+this litigation
+
+
+
+Case 9:08-CV-80736-KAM Document|
+1 Entered on FLSD Docket 07/19/2013 Page 21 of
+23
+Box #3
+P-012453
+Thru
+P-012623
+Description
+Complete indictment package marked "Originals
+12/12/07"
+Work-product
+Also contains documents
+Box #3
+P-012624
+Thru
+P-012653
+Box #3
+P-012654
+Thru
+P-012864
+Box #3
+P-012865
+Thru
+P-013226
+Folder entitled "(Victims) Additional 302's"
+containing reports of interviews conducted in
+June 2007, October 2007, and March 2008.
+3-ring binder entitled "Child Molesters:
+A
+Behavioral Analysis" with attorney
+handwritten notes
+witness/victim list with identifying information
+exual activity summary, telephone call summar
+chart, attorney (
+Also contains documents
+subject to investigative
+privilege
+Also contains documents
+subject to privacy rights of
+victims who are not parties to
+this litigation
+Privacy Act
+Box #3
+P-013227
+Box #3
+P-013226
+Thru
+P-013230
+Box #3
+P-013231
+Thru
+P-013239
+persons identified as.
+14
+April 23, 2008 Memo from
+Office of Professional Responsibility re Self
+Reporting, Corrected Version of the previously
+submitted April 21, 2008 Letter to OPR
+April 21, 2008 Letter from
+Office of Professional Responsibility re Self
+April 22, 2008 Letter from A.
+Report of lection octie of lity so Solf.
+Privacy Act
+Privacy Act
+
+
+
+71 Entered on FLSD Docket 07/19/2013 Page 22 of
+Box #3
+P-013240
+Thru
+P-013247
+Box #3
+P-013248
+Thru
+P-013251
+Description
+Privacy Act
+Box #3
+P-013252
+Thru
+P-013253
+Box #3
+P-013254
+Thru
+P-013257
+Box #3
+P-013258
+Thru
+P-013259
+Box #3
+P-013260
+Thru
+P-013262
+Emails between
+Assistant
+General Counsel, Executive Office for United
+States Attorneys. and
+1, First
+Assistant U.S. Attorney, Southern District of
+Florida, regarding Formal Notice of Office-wide
+Recusal of Southern District of Florida dated
+Assistant
+General Counsel, Executive Office for United
+Assistant U.S. Attorney,
+Southern District of
+Florida, regarding Recusal matter, dated July 28,
+August 3, and August 24, 2011
+Emails between
+Assistant
+General Counsel, Executive Office for United
+States Attorneys, and
+, First
+Issistant U.S. Attorney,
+Aria, regarding Formal Sole or Die vid
+Recusal of Southern District of Florida dated
+August 24 and August 29, 2011
+Emails between
+Assistant
+General Counsel, Executive Office for United
+States Attorneys, and |
+• First R
+Assistant U.S. Attorney, Southern District of
+Florida, regarding Formal Notice of Office-wide
+Recusal of Southern District of Florida dated July
+28 and August 3, 2011
+Email from
+Assistant General
+Counsel, Executive
+Office
+for United States
+Attorneys, to
+(U.S. Attorney,
+SDFL), Robert O'Neill (U.S. Attorney, MDFL).
+. (FAUSA, SDFL), and
+(FAUSA, MDFL) regarding Formal
+Notice of Office-wide Recusal of Southern
+District of Florida dated August 24, 2011. CC's
+(ODAG), I
+(USAEO),
+(USAEO),
+(USAEO),
+(USAEO)
+
+
+
+Case 9:08-CV-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 23 of
+Box #3
+P-013263
+Thru
+P-013271
+Box #3
+P-013272
+Thru
+P-013278
+Description
+Emails between
+General Counsel, Executive Office for United
+States Attorneys, and
+, First
+Assistant U.S. Attorney, Southern District of
+Florida, regarding recusal of Southern District of
+Florida, dated July 29,
+, 2011, with attached
+memorandum from
+summarizing
+Jeffrey
+Epstein Investigation
+Emails between
+Executive Office
+for United States Attorneys, and
+Southern District of Florida, seeking advice
+regarding office-wide recusal, dated December 16
+2010, with attached letter from
+dated December 10,
+2010
+
+
+
+
+
+Case 9:08-CV-80736-KAM Document 216 Entered on FLSD Docket 07/27/2013 Page 1 of 2
+Case No. 08-80736-Civ-Marra/Matthewman
+Petitioners,
+UNITED STATES OF AMERICA,
+Respondent.
+UNITED STATES' NOTICE OF FILING SUPPLEMENTAL PRIVILEGE LOG
+Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United
+States of America, by and through the undersigned Assistant United States Attorney, hereby gives
+notice of its filing of its Privilege Log, which is attached hereto.
+The documents referenced in the Privilege Log are being delivered today to the Chambers
+of U.S. District Judge Kenneth A. Marra for ex parte in camera review, pursuant to the Court's
+Omnibus Order.
+Respectfully submitted,
+UNITED STATES ATTORNEY
+By:
+Florida Bar No.
+500 South Australian Ave, Suite 400
+vest Palm Beach, FL 3340
+'elenhon
+
+
+Case 9:08-cV-80736-KAM Document 216 Entered on FLSD Docket 07/27/2013 Page 2 of 2
+I HEREBY CERTIFY that on July 26, 2013, I electronically filed the foregoing document
+with the Clerk of the Court using CM/ECF. According to the Court's website, counsel for all parties
+are able to receive notice via the CM/ECF system.
+SERVICE LIST
+United States,
+Case No. 08-80736-CIV-MARRA/MATTHEWMAN
+United States District Court, Southern District of Florida
+Brad Edwards, Esq.
+Farmer Jaffe Weissing Edwards Fistos Lehrman
+425 N Andrews Ave Ste 2
+Fort Lauderdale, FL 33301-3268
+brad @pathtojustice.com
+954-524-2820
+Fax: 954-524-2822
+Paul G. Cassell
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, Utah 84112
+(801) 585-5202
+Fax: (801) 585-6833
+E-mail: casselp@law.utah.edu
+Attorneys for Jane Doe # 1 and Jane Doe # 2
+2
+
+
+Case 9:08-CV-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 1 of 14
+P-013279
+Thru
+P-013280
+P-013281
+SUPPLEMENTAL PRIVILEGE LOG
+Description
+8/15/08 Emails between A. Acosta and
+proposed correspondence to Jay Lefkowitz
+Handwritten note re Epstein investigation
+re
+P-013282
+Thru
+P-013283
+P-013284
+P-013285
+Thru
+P-013289
+P-013290
+Thru
+P-013292
+7/9/08 Email from
+to A.
+Acosta,
+and FBI re
+proposed response to Goldberger letter re victim
+notification
+7/10/08 Emails between |
+and FBI re proposed
+response to
+Goldberger's letter re victim
+notification
+File folder entitled "8/5/08 AMCV e-mail re
+correct agrmt" containing 8/5/08 email from A
+Acosta,
+re "Jeffrey Epstein
+Agreement"
+discussing 6/24/08 email from
+to R. Black and J. Goldberger
+concerning the binding nature of the Agreement
+File folder entitled "8/14/08 E-mail from Lefk to
+AMCV"
+containing (undated) emails from A.
+1, A.
+Acosta,
+re draft response to
+3/14/08 email from J. Lefkowitz regarding "the
+December 2007 proposal"
+Also contains information
+subject to privacy rights of
+victims who are not
+arties to this litigatior
+
+
+
+Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 2 of 14
+P-013293
+Thru
+P-013299
+P-013300
+Thru
+P-0133303
+P-013304
+Thru
+P-013325
+P-013326
+Thru
+P-013329
+P-013330
+Thru
+P-013333
+P-013334
+Thru
+P-013337
+Description
+File folder entitled "8/15/08 AMCV e-mail re
+Agrmt" containing 8/15/08 e-mails from A.
+10 A. A costlow up on Afreement and
+from A. Acosta to Ann |
+of Special Master with attached 8/15/08 emails
+from
+to A. Acosta,
+re Agreement;
+8/15/08 email from J. Lefkowitz to
+1. R. Black, M. Weinberg re
+Agreement; 8/14/08 emails from
+to J. Lefkowitz,
+, R. Black
+re interpretation of Agreement:
+email from J.
+Lefkowitz to
+re
+questions re Agreement; email from
+to J. Lefkowitz,
+re
+production of Agreement to victims
+File folder entitled *8/18/08 Lefkowitz Ltr to
+AMCV" containing
+handwritten draft notes for proposed letter to J.
+Lefkowitz; 5/22/07 e-mail from
+to M.
+re
+meeting with G. Lefcourt with attached email
+from G. Lefcourt re solicitation for meetings
+File folder entitled "6/25/07 Lefcourt to Sloman
+&
+containing
+6/25/07
+letter (with
+handwritten notes by
+1 from G.
+Lefcourt to
+_ M.
+addressing
+reasons for not
+rosecuting Epstein; handwritten outline b
+if possible response to lette:
+File folder entitled *9/17/07
+Lefkowitz containing 9/17/07 e-mail from
+and from
+to A.
+concerning status
+File folder entitled "11/8/07 Lefkowitz to
+containing 11/8/07 letter from J.
+Lefkowitz re issues arising during pendency of
+matter with attorney handwritten notes
+File folder entitled 11/13/07
+Lefkowitz (was this sent?)".
+containing draft
+11/13/07 letter from |
+responding to J.
+Lefkowitz's letter
+
+
+
+Cașe 9:08-CV-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 3 of 14
+P-013338
+Thru
+
+P-013342
+Thru
+P-013350
+P-13351
+Thru
+P-013361
+P-013362
+Thru
+P-013366
+P-013367
+Thru
+P-013372
+P-013373
+Thru
+P-013503
+P-013504
+Thru
+P-013507
+P-013508
+Thru
+P-013514
+Description
+File folder entitled
+"12/6/07
+Sloman
+Lefkowitz" containing 12/5/07 faxed letter w/
+cover sheet from K. Starr and J. Lefkowitz to A.
+Acosta
+File folder entitled "12/05/07 Starr to Acosta"
+containing drafts of 11/30/07 letters from A.
+Acosta to K. Starr and from
+to J.
+Lefkowitz re performance and victim notification
+with handwritten notes and edits by A.
+File folder entitled "12/21/07 Lefkowitz
+Acosta" containing handwritten notes by [
+12/21/07 letter from J
+Lefkowitz to A. Acosta re performance of NPA
+and appeal to
+handwritten notes
+File folder labeled "12/26/07 Lefkowitz to
+Acosta" containing 2 copies of draft letter from
+A. Acosta to J. Lefkowitz (with 12/28/07 fax
+header)
+File folder labeled "Draft Itr from
+Lefkowitz re termination" containing draft letter
+dated "April, 2008" from
+to J.
+Lefkowitz concerning the compliance with the
+Agreement
+File folder labeled "6/3/08 Sloman Submission to
+the DAG" containing 6/3/08 letter from |
+Office of the DAG. ce'd to
+re
+Jeffrey Epstein, detailing events concerning the
+Agreement and thereafter and with relevant
+File folder labeled "Mtg w/ Ken Starr, RAA, JS.
+Drew" containing handwritten notes by A.
+File folder labeled "Internal Corr." containing
+11/28/07 e-mails from
+re responding to 11/28/07 e-mail from
+J. Lefkowitz to
+regarding victim
+notification with attachments
+[Not considered
+privileged. Will be
+produced to opposing
+counsel upon lifting of
+stay]
+
+
+
+Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 4 of 14
+P-013515
+Thru
+P-013525
+P-013526
+Thru
+P-013527
+P-013528
+Thru
+P-013530
+P-013532
+Thru
+P-013537
+P-013531
+P-013538
+Thru
+P-013553
+P-013554
+Thru
+Description
+Draft 11/30/07 letter from AL
+and A.
+to K. Starr
+re
+items to address in letter
+5/23/07 e-mail from A.
+re draft proposed internal e-mail about
+handling of case
+and
+attached
+correspondence between
+and G.
+Typed note addressed to "Dear David" re
+response to grand jury subpoena
+File folder labeled "Notes Re Post-Agreement
+Communications" containing handwritten notes
+by A.
+File
+folder
+labeled
+Negotiations" containing:
+•
+11/28/07 e-mail from
+"E-mails
+Re
+Plea
+to A.
+re
+non-prosecution
+agreement,
+attached correspondence:
+• 9/19/07 e-mail from A.
+with
+negotiating
+strategy,
+correspondence;
+• 9/18/07 e-mail from A.
+A.
+Acosta,
+with
+re
+attached
+re
+negotiating
+strategy;
+• 9/17/07 e-mail from A. L
+A. Acosta re negotiation;
+• 9/17/07 e-mail from A. I
+A. Acosta,
+re negotiations:
+• 9/17/07 e-mail from A.
+
+
+
+Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 5 of 14
+Description
+re negotiation
+strategy;
+• 9/14/07 e-mail from A.
+A. Acosta.
+re proposed
+plea agreement and Information;
+9/14/07 e-mail from A.
+A.
+Acosta.
+re plea negotiations;
+9/13/07 e-mail from A
+re
+•
+•
+indictment package;
+9/13/07 e-mail from A
+re trust agreement with
+attached correspondence
+9/13/07 e-mail from A.
+re trust agreement;
+9/13/07 e-mail from A
+re conference call
+•
+•
+with J. Lefkowitz;
+9/13/07 e-mail from A.
+re plea negotiations
+with
+attached comes from ence.
+re charging
+strategy
+with
+attached correspondence;
+9/13/07 e-mail from A.
+re
+•
+indictment package;
+9/13/07 e-mail from A.
+A.
+Acosta,
+9/11/07 e-mail from A.
+re plea negotiations;
+•
+re revised Agreement with
+attached correspondence;
+9/11/07 e-mail from A.
+re non-prosecution agreement
+edits with attached correspondence:
+9/11/07 e-mail from A.
+re status of negotiations
+with attached correspondence;
+
+
+
+Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 6 of 14
+P-013609
+Thru
+P-013615
+Description
+| 9/10/07 e-mail from
+ne negotiations: 9/10007 e-mail
+from
+re state grand jury proceedings:
+•
+2/17/07 e-mail from A. Acosta to
+re draft Agreement
+with attached correspondence:
+• 9/14/07 e-mail from
+A. Acosta,
+, re finalizing
+documents;
+• 9/14/07 e-mail from |
+re
+charging
+strategy
+with
+attached correspondence;
+9/13/07 e-mail from
+to A.
+re setting up trust fund;
+•
+9/13/07 e-mail from
+re final negotiations with
+attached correspondence:
+9/11/07 e-mail from
+Ito/
+re
+scheduling
+a
+meeting
+regarding finalizing the agreement with
+attached correspondence
+•
+9/11/07 e-mail from
+to l
+re
+non-prosecution
+with
+attached
+agreement
+edits
+correspondence;
+9/11/07 e-mail from
+•
+Te
+non-prosecution
+agreement
+edits
+with
+attached
+correspondence;
+• 9/11/07 e-mail from |
+Ito
+I re negotiations with
+attached correspondence:
+9/17/07 e-mail from A.
+re negotiation
+strategy
+File folder entitled "D Target Letter" containing
+copy of signed letter and contact info for counsel
+for target
+
+
+
+Case 9:08-CV-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 7 of 14
+P-013616
+Thru
+P-013621
+Description
+File folder entitled "Atty Notes re Revised
+Indictment" containing handwritten notes by A.
+P-013622
+Thru
+P-013643
+P-013644
+Thru
+P-013653
+File folder entitled "Research Re Possible
+Misdemeanors" containing attorney research
+ttorney-Client Privileg
+Deliberative Proces
+Also contains information
+subject to privacy rights of
+victims who are not
+P-013654
+Thru
+P-013745
+P-0013747
+Thru
+P-013810
+File folder entitled "Notes Re Plea Negotiations"
+containing
+: 9/17/07
+e-mail from
+A
+re status
+update: undated and typed handwritten notes by
+A.
+re items to be completed on
+case, strength
+of case,
+victim interviews,
+summary of evidence, guidelines calculations
+File folder entitled "Plea Agreement Drafts"
+conta hang ever notes blea seements some
+with handwritten notes by A.
+copies of draft non-prosecution agreement some
+with handwritten notes by A.
+copy of a draft Information
+File folder entitled "Draft
+Non-Prosecution
+notes by
+Also contains information
+subject to privacy rights of
+victims who are not
+P-013811
+Thru
+P-013833
+P-013834
+Through
+P-013835
+Compite drat normation pf keformations, and
+Two pages of filed document, D.E. 62, page 2 of
+stand page 6 of 54, containing handwritten
+
+
+
+Case 9:08-CV-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 8 of 14
+P-013836
+Thru
+P-013837
+P-013838
+Thru
+P-013841
+P-013842
+P-013843
+Thru
+P-013844
+P-013845
+Thru
+P-013846
+P-013847
+Thru
+P-013849
+P-013850
+P-013851
+Thru
+P-013853
+P-013854
+P-013855
+P-013856
+Thru
+P-013857
+Palm Beach Daily News Article, "Attorneys want
+Jeffrey Epstein Agreement Thrown Out," with
+attorney's notes written on margin
+Letter from
+December 10, 2010, Subject:
+Investigation of Jeffrey Epstein Prosecution, with
+underlines. written notes, and comments by DOJ
+attorney
+Email from
+(OPR), February 25, 2011, 4:31 p.m., Re:
+Request for OPR Investigation - Jeffrey Epstein
+Non-Prosecution Agreement
+E-mail,
+and
+19,2007, 4:33 p.m., RE: Plea Agreement
+September
+E-mail,
+September 19, 2007, 4:21 p.m., RE: Epstein,
+with internal U.S. Attorney's Office e-mails
+attached
+E-mail,
+and
+September
+18, 2007, 11:43
+., RE:
+Draft Agreements?,
+with e-mail from Jay Lefkowitz (September 18,
+2007, 11:09
+) attached
+E-mail,
+and
+September 18, 2007, 9:31
+RE: Epstein Negotiations
+E-mail,
+and
+September 17, 2007, 10:35
+RE:
+Epstein [providing
+update re plea
+negotiations]
+September 13, 2007, 8:10 p.m., RE: Epstein,
+13, 2007, 7:54 p.m.), attached
+E-mail,
+September 10, 2007, 524 pand
+RE: FBI
+Septil ber 6, 2007.547 p.m. RE: Epstein, with
+e-mail from
+(September 6, 2007,
+5:35 p.m.), attached
+atty-client privilege
+
+
+
+Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 9 of 14
+P-013858
+P-013859
+Through
+P-013860
+P-013861
+Thru
+P-013865
+P-013866
+P-013867
+Thru
+P-013868
+P-013869
+P-013870
+Thru
+P-013871
+Description
+Email,
+September 6, 2007, 9:29
+., Re: Meeting on
+Friday
+Email, Gerald Lefcourt to
+- Lilly
+Ann Sanchez, Roy Black, re: Jeffrey Epstein
+[Not considered
+privileged. Will be
+produced to opposing
+counsel upon lifting of
+stay]
+atty-client privilege
+P-013872
+P-013873
+E-mail,
+to Matthew
+July 13, 2007, 3:14 p.m., RE: Epstein, with e-
+mail from
+(July 5, 2007, 3:30 p.m.),
+(July 4, 2007, 5:16 p.m.),
+and Sloman to
+(July 3, 2007, 1:47
+p.m.), attached
+E-mail,
+. Matthew
+and
+July 3,2007, 6:26
+.. RE: Epstein
+E-mail,
+to Matthew
+June 21, 2007, 3:24 p.m., RE:
+Meeting Next
+Week, with e-mails from
+(June 21, 2007, 2:58 p.m.), and
+(June 21, 2007, 1:37 p.m.), attached
+E-mail.
+to Matthew
+and
+June 18, 2007, 5:04 p.m., RE: Epstein
+E-mail,
+1 May
+24, 2007, 9:25
+.. FW: Jeffrey Epstein, with e-
+mail from Gerald Lefcourt to
+(May 23, 2007, 5:00 p.m.),
+Gerald Lefcourt (May 22, 2007. 6:32 p.m.), and
+Gerald Lefcourt to
+I, and Lilly Ann Sanchez (May 22, 2007,
+2:05 p.m.), attached
+E-mail.
+to Matthew
+and
+, May 22, 2007, 3:11
+Jeffrey Epstein, with e-mail from
+and Lilly Ann
+2007, 10:52
+e-mail from
+(May 14, 2007, 10:38
+, May 14,
+, RE: Operation Leap Year, with
+and
+), attached
+
+
+
+Case 9:08-CV-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 10 of
+P-013874
+Through
+P-013875
+P-013876
+Thru
+P-013877
+P-013878
+Thru
+P-013879
+P-013880
+Thru
+P-013882
+P-013883
+P-013884
+Thru
+P-013886
+P-013887
+P-013888
+Description
+Inadvertently marked as privileged, will be
+produced
+E-mail,
+and
+, September 19, 2007, 4:33 p.m., RE:
+Draft Plea
+Agreement, with
+e-mail from
+Lefkowitz to
+(September 19, 2007, 3:44
+p.m.), and Lefkowitz to
+(September 19,
+2007, 3:35 p.m.) attached
+E-mail,
+September 19, 2007,
+4:21 p.m.,
+RE:
+Epstein
+and
+with e-mails from
+(September 19
+2007, 4:13 p.m.),
+and
+(September 19,
+and
+2007, 4:05 p.m.), and
+(September 19, 2007, 3:50
+p.m.),
+(September 19 2007,
+2:36 p.m.),
+(September 19,
+2007,
+2:33 p.m.), and |
+and
+(September 19, 2007, 2:31 p.m.), attached
+E-mail
+and
+September 18, 2007,
+11:43
+RE:
+Draft Agreements?, with e-mails from
+and
+(September 18
+2007,
+11:18
+.),
+Lefkowitz
+(September 18, 2007, 11:09
+-), and
+to Lefkowitz (September 18
+2007, 9:14
+ande Lefkowitz to
+(September
+2007, 8:59
+., attached
+E-mail,
+to Acosta,
+and McMillan, September 18, 2007,
+9:31
+RE: Epstein Negotiations
+E-mail,
+and
+September 17, 2007 10:35
+1., RE: Epstein,
+with e-mail from
+(September 17, 2007,
+10:26
+b), attached
+E-mail,
+September 13, 2007, 8:10 p.m., RE: Epstein,
+with e-mail from
+(September
+13, 2007, 7:54 p.m.), attached
+E-mail,
+and
+September 10, 2007, 5:24 p.m.,
+RE: FBI
+
+
+
+Case 9:08-CV-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 11 of
+P-013889
+Thru
+P-013890
+P-013891
+P-013892
+Through
+P-013893
+P-013894
+Thru
+P-013898
+Description
+E-mail,
+September 6, 2007, 5:47 p.m., RE: Epstein, with
+e-mail from
+(September 6, 2007,
+5:35 p.m.), attached
+Email,
+September 6, 2007, 9:29
+., Re:
+Meeting on
+Friday
+Email, Gerald Lefcourt to
+1. Lilly
+Ann Sanchez, Roy Black, re: Jeffrey Epstein
+[Not considered
+privileged. Will be
+produced to opposing
+counsel upon lifting of
+atty-client privilege
+P-013899
+P-013900
+Thru
+P-013901
+P-013902
+P-013903
+Thru
+P-013904
+P-013905
+E-mail,
+to Matthew
+July 13, 2007, 3:14 p.m., RE: Epstein, with e-
+mail from
+(July 5, 2007, 3:30 p.m.),
+(July 4, 2007, 5:16 p.m.),
+and Sloman to
+(July 3, 2007, 1:47
+p.m.), attached
+E-mail,
+. Matthew
+and
+, July 3, 2007, 6:26
+,, RE: Epstein
+E-mail,
+to Matthew
+June 21, 2007, 3:24 p.m., RE:
+Meeting Next
+Week, with e-mails from
+(June 21, 2007, 2:58 p.m.), and
+(June 21, 2007, 1:37 p.m.), attached
+E-mail,
+to Matthew
+and
+June 18, 2007, 5:04 p.m., RE: Epstein
+E-mail,
+1 May
+24, 2007, 9:25
+.. FW: Jeffrey Epstein, with e-
+mail from Gerald Lefcourt to
+(May 23, 2007, 5:00 p.m.),
+Gerald Lefcourt (May 22, 2007, 6:32 p.m.), and
+, and Lilly Ann Sanchez (May 22, 2007,
+E-mail,
+to Matthew
+and
+, May 22, 2007, 3:11
+p.m., FW: Jeffrey Epstein, with e-mail from
+Lefcourt to
+I and Lilly Ann
+Sanchez (May 22, 2007, 2:05 p.m.), attached
+
+
+
+Case 9:08-CV-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 12 of
+P-013906
+P-013907
+Through
+P-013908
+P-013909
+Thru
+P-013911
+P-013912
+Thru
+P-013914
+P-013915
+Thru
+P-013918
+Description
+E-mail
+and
+- May 14,
+.,RE: Operation Leap Year, with
+and
+(May 14, 2007, 10:38
+l), attached
+Inadvertently marked as privileged, will be
+P-013919
+Thru
+P-013921
+P-013922
+Thru
+P-013924
+P-013925
+Thru
+P-013927
+P-013928
+Thru
+P-013930
+P-013931
+Thru
+P-013933
+Memorandum,
+U.S. Department of Justice, Office.
+Professional Responsibility (OPR), to
+Acting Associate Counsel, OPR,
+undated, Subiect: Recommendation
+Memorandum,
+Assistant Counsel,
+OPR, to
+Acting Associate
+Counsel, OPR, Subject: Recommendation, with
+handwritten note dated 5/4/11
+Memorandum,
+, Assistant Counsel,
+OPR, to
+Acting Associate
+Counsel, OPR, Subject: Recommendation, with
+two post-it notes attached with handwritten
+attorney notations, and handwritten notations
+underlines, and circled text throughout the body
+of the two page memorandum
+Draft letter, marked "Confidential", from |
+Counsel, Office of Professional
+Responsibility to
+United
+States
+Attorney, with handwritten corrections,
+strikethroughs, and added text
+Draft Letter, marked "Confidential"
+from
+with
+handwritten corrections
+Draft Letter, from
+to Professor
+Paul G. Cassell, with handwritten correction
+Draft Letter, from
+to Professor
+Paul G. Cassell, with handwritten corrections
+Draft Letter, from
+to Professor
+Paul G. Cassell, with handwritten corrections,
+circled text, strikethroughs, and additional text
+Privilege; atty workproduct
+Privilege, atty workproduct
+Privilege; atty workproduct
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+
+
+
+Case 9:08-CV-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 13 of
+P-013934
+Thru
+P-013936
+P-013937
+Thru
+P-013939
+P-013940
+Thru
+P-013942
+P-013943
+P-013944
+P-013945
+P-013946
+P-013947
+P-013948
+Thru
+P-013951
+Description
+Draft Letter, marked "Confidential," from
+with handwritten
+corrections
+Draft Letter,
+to Professor Paul
+G. Cassell, with handwritten corrections
+Draft Letter, marked "Confidential: To Be
+Opened by Addressee Only,"
+with handwritten corrections
+E-mail,
+, May 5,
+2011, 11:19
+., RE: Re-write of Epstein letters
+for your review, with e-mail from
+(May 5, 2011, 11:08
+), and
+May 5, 2011, 11:10
+and
+), attached
+E-mail,
+11:17
+your
+1),
+(May 5, 2011, 10:41
+to l
+May 5, 2011,
+RE: Re-write of Epstein letters for
+review, with e-mail from
+(May
+11:08
+and
+5, 2011,
+(May 5, 2011, 11:01
+.).
+(May 5, 2011, 10:41),
+attached
+E-mail,
+May 4, 2011, 5:01
+p.m., RE: draft letters in Epstein matter, with e-
+mail from
+(May 4, 2011,
+4:57 p.m.), attached
+E-mail,
+• May 4,
+2011, 4:08 p.m., RE: FYI on the Florida matter
+E-mail,
+May 3, 2011,
+12:23 p.m., RE: OPR Inquiry
+request for
+information, with post-it note attached with
+handwritten attorney notes
+between
+with
+and
+E-mail.
+and
+_ May 3, 2011, 12:30 p.m., FW: OPR
+Inquiry - request for information, with attached
+e-mails. Handwritten attorney notes on margin
+
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+Privilege
+Privilege
+Law Enforcement
+investigatory record, atty
+work product; deliberative
+process privilege
+atty work product; law
+enforcement investigatiory
+record
+
+
+Case 9:08-Cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 14 of
+P-013952
+Thru
+P-013953
+P-013954
+Thru
+P-013955
+P-013956
+Thru
+P-013846
+Description
+E-mail,
+16, 2011, 10:52
+., RE: Referral of Cassell
+Request for Investigation, with e-mail from
+and
+(March 15, 2011, 7:21 p.m.), attached
+E-mail,
+OPR,
+December 16, 2010, 10:59
+FW: OPR
+Referral - Allegation of Misconduct - U.S.
+Attorney's_ Office, S.D.Fla., with e-mail from
+(December 16, 2010,
+10:22
+), attached.
+Handwritten attornev
+notations.
+Fourteen (14) pages of handwritten attorney notes
+on case, telephone interviews with DOJ attorneys
+atty work-product; attylient privilege
+atty work-product, attyclient privilege
+
+
+
+Çase 9:08-CV-80736-KAM Document 329 Entered on FLSD Docket 06/23/2015 Page 1 of 2
+Case No. 08-80736-Civ-Marra/Matthewman
+Petitioners,
+UNITED STATES OF AMERICA,
+Respondent.
+UNITED STATES' NOTICE OF FILING SECOND SUPPLEMENTAL PRIVILEGE LOG
+Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United
+States of America, by and through the undersigned Assistant United States Attorney, hereby gives
+notice of its filing of its Second Supplemental Privilege Log. The index has been marked with
+Bates Numbers P-013970' thru P-014923.
+The documents referenced in the Second Supplemental Privilege Log will be delivered
+today to the Chambers of U.S. District Judge Kenneth A. Marra for ex parte in camera review,
+pursuant to the Court's Omnibus Order.
+Respectfully submitted,
+WIFREDO A. FERRER
+UNITED STATES ATTORNEY
+By:
+Florida Bar NoW
+500 South Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Telephone:
+thru P-013969 [14 pages].
+1
+
+
+Case 9:08-cv-80736-KAM Document 329 Entered on FLSD Docket 06/23/2015 Page 2 of 2
+I HEREBY CERTIFY that on June 23, 2015, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF. According to the Court's website,
+counsel for all parties are able to receive notice via the CM/ECF system.
+SERVICE LIST
+United States,
+Case No. 08-80736-CIV-MARRA/MATTHEWMAN
+United States District Court, Southern District of Florida
+Brad Edwards, Esq.,
+Farmer Jaffe Weissing Edwards Fistos Lehrman
+425 N Andrews Ave Ste 2
+Fort Lauderdale. FL 33301-3268
+Paul G. Cassell
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, Utah 84112
+2
+
+
+Case 9:08-Cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 1 of 18
+P-013970
+thru
+P-013971
+P-013972
+JANE DOE I. UNITED STATES
+COURT FILE NO. 08-80736-CV-MARRA
+SECOND SUPPLEMENTAL PRIVILEGE LOG - BOX #4
+Description
+11/29/2006-12/1/2006 emails between
+and prison
+employee regarding attempted contact with potential witness
+5/18/2007 email from
+informing him
+of intent to subpoena Roy Black's private investigator and steps taken to
+obtain DOJ authorization
+5/18/2007 emails between
+and expert witness regarding
+securing pre-indictment consultation contract
+5/21/2007 email from
+(CEOS) re
+2423(b) charging question
+Privacy Act
+P-013973
+thru
+P-013976
+P-013977
+thru
+P-013979
+P-013980
+P-013981
+P-013982
+P-013983
+thru
+P-013984
+5/21/2007 email from
+regarding guidance on grand jury presentation
+5/22/2007 email from Andy
+and
+(cc:
+D re letter received from Gerald Lefcourt discussing
+a meeting to discuss Epstein investigation
+5/23/2007 email from
+re extradition
+research
+5/23/2007 emails between
+and
+regarding decision to meet with counsel for Epstein
+Investigative rivilege
+
+
+Case 9:08-Cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 2 of 18
+P-013985
+thru
+P-013989
+P-013990
+thru
+P-013991
+P-013992
+thru
+P-013994
+P-013995
+thru
+P-014010
+P-014011
+thru
+P-014025
+P-014026
+thru
+P-014027
+P-014028
+thru
+P-014030
+P-014031
+thru
+P-014032
+Description
+6/14/2007-6/21/2007 emails between
+. and
+regarding addendum to
+Pros Memo, grand jury presentation and changes to indictment, and
+meeting with counsel for Epstein
+6/26/2007 email from
+5
+and
+addressing arguments regarding interstate nexus for
+2422(b) charges
+7/3/2007-7/4/2007 emails between
+and
+regarding extension of time to respond to subpoenas requested by Lilly
+Ann Sanchez and possible resolution of case
+6/12/2007-7/6/2007 series of emails between
+and
+AUSAs
+and
+re an earlier unrelated
+investigation of Epstein
+7/3/2007-7/13/2007 email chain between
+regarding disagreement on
+and
+plea negotiations and
+written request for meeting between USAO management and victims
+7/16/2007 email from |
+5
+regarding correspondence from Roy Black and Motion to Quash
+7/18/2007 emails from
+and
+regarding Motion to Quash grand jury subpoena and
+supporting affidavit filed by Roy Black
+7/19/2007 email chain between
+, S/A
+and S/A
+service of target letters
+regarding potential
+Privacy Act
+
+
+Case 9:08-CV-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 3 of 18
+P-014033
+P-014034
+P-014035
+P-014036
+P-014037
+P-014038
+thru
+P-014041
+P-014042
+P-014043
+thru
+P-014044
+P-014045
+thru
+P-014046
+Description
+7/19/2007 email from
+and
+regarding planned service of target letters
+7/26/2007 email from |
+and
+regarding proposed changes to the indictment
+7/31/2007 email from
+g
+and
+summarizing proposed plea terms as per
+recommendation
+7/31/2007-8/2/2007 email chain between
+, and
+regarding plea negotiations
+8/2/2007 email drom
+and
+with draft response to Epstein counsel regarding
+agreement
+8/2/2007 emails between
+, Andy
+1, and
+regarding letter received from Lilly Ann Sanchez
+8/3/2007 Email from |
+regarding draft response to
+Correspondence from Epstein counsel and ardined tate espanise steps if
+agreement cannot be reached.
+Emails dated 8/6/2007 from
+and
+regarding
+correspondence prior to his departure.
+8/7/2007 email chain between
+, and
+Alex Acosta regarding meeting to discuss Epstein matter
+İnvestigative Privilege
+
+
+
+Case 9:08-CV-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 4 of 18
+P-014047
+P-014048
+P-014049
+thru
+P-014050
+P-014051
+P-014052
+P-014053
+P-014054
+P-014055
+P-014056
+P-014057
+P-014058
+Description
+8/7/2007 email from |
+to Andy
+regarding deadline
+set for Epstein plea and Epstein's plan to demand a meeting with CEOS.
+8/7/2007 email from
+regarding
+Epstein meeting
+8/7/2007 email chain from
+1, and Alex Acosta regarding Epstein meeting
+8/8/2007 emails between
+and
+(CEOS) regarding case staffing and plea negotiations
+8/8/2007 email chain between
+, Alex Acosta,
+regarding
+, and
+"The meeting on Epstein"
+8/8/2007 email from
+regarding
+plea negotiations, guideline calculations, and assistance in preparing
+case for trial
+8/8/2007 email from
+to Alex Acosta,
+and
+regarding planning
+meeting with Epstein counsel and service of target letters
+8/10/2007 Electronic correspondence from
+to expert
+witness regarding topics for expert testimony
+8/10/2007 email from
+regarding
+target letters and staying motion to compel production of computers
+8/30/2007 email from
+, and
+coverage of meeting with Ken Starr
+regarding press
+9/4/2007-9/6/2007 emails between
+and
+regarding planned participation of FBI ASAIC at 9/7/2007 meeting with
+Epstein defense team
+
+Deliberativedrocess
+
+Case 9:08-CV-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 5 of 18
+P-014059
+thru
+P-014061
+P-014062
+thru
+P-014068
+P-014069
+P-014070
+thru
+P-014074
+P-014075
+thru
+P-014089
+P-014090
+thru
+P-014102
+P-014103
+thru
+P-014107
+P-014108
+thru
+P-014134
+Description
+9/6/2007 emails between
+› and
+regarding status of plea
+negotiations, draft agreements, and need to confer with victims
+9/10/2007-9/14/2007 emails between
+, and Alex
+Acosta regarding final plea negotiations, finalizing details with State
+Attorney's Office and final revisions to indictment package
+9/10/2007 email from
+and
+regarding Acosta inquiry about FBI investigation into State
+grand jury proceeding
+9/11/2007 emails between
+, and
+regarding changes
+to the draft indictment and status of plea negotiations
+9/10/2007-9/11/2007 emails between
+, Alex Acosta, and
+9/13/2007 emails from
+Agreement
+5
+, Alex Acosta,
+regarding plea to
+federal charges recommending 18 USC 403 or 1512(d), or 47 USC
+223(a)(1)(B); response that Epstein was only willing to plead to assault
+on the plane; and rejection of facts supporting assault on the plane
+charge
+9/13/2007-9/14/2007 emails regarding
+research
+regarding victim trust fund set up in Alaska child exploitation case
+9/17/2007-9/19/2007 emails between
+1, and
+regarding negotiations of a federal plea and a non-prosecution
+agreement
+
+
+Case 9:08-CV-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 6 of 18
+P-014135
+thru
+P-014149
+P-014150
+thru
+P-014156
+P-014157
+thru
+P-014160
+P-014161
+P-014162
+thru
+P-014170
+P-014171
+thru
+P-014174
+P-014175
+thru
+P-014203
+P-014204
+thru
+P-014205
+P-014206
+thru
+P-014216
+P-014217
+thru
+P-014238
+Description
+9/19/2007-9/20/2007 emails between
+regarding plea negotiations with counsel for
+Epstein
+9/20/2007 emails between
+and
+regarding plea agreement to federal charges and factual proffer
+9/21/2007 emails between
+and
+and
+regarding revisions to the
+non-prosecution agreement
+9/21/2007 email from
+to Alex Acosta,
+, and
+regarding review of Epstein
+indictment package
+9/24/2007 series of emails between
+1, Alex Acosta, and
+regarding plea negotiations and revisions to nonprosecution agreement
+9/23/2007-9/24/2007 series of emails between Alex Acosta,
+and
+regarding
+proposed revisions to non-prosecution agreement
+9/20/2007-9/24/2007 emails between Alex Acosta,
+, and
+regarding revisions to the non-prosecution agreement
+9/24/2007 emails between
+and
+regarding notifying Palm Beach Police Chief and victims about
+agreement
+9/24/2007-9/25/2007 emails between
+regarding Lefkowitz email about
+keeping agreemen from becoming public in confidentiality provision
+in agreement
+10/5/2007-10/16/2007 emails between
+and Alex Acosta re selection of Special Master and negotiation of
+revision/addendum to Non-Prosecution Agreement
+Work Production
+
+
+Case 9:08-Cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 7 of 18
+P-014239
+thru
+P-014242
+P-014243
+thru
+P-014251
+P-014252
+thru
+P-014275
+P-014276
+Description
+10/18/2007 emails between
+and
+regarding
+Epstein's request to delay his change of plea
+10/19/2007 emails between
+and
+regarding
+Special Master's Selection of Attorney Representative
+and
+Agreement and drafting of correspondence regarding scope of Special
+Master's duties and selection criteria
+10/31/2007 email from
+regarding attempts to interview additional witnesses/victims
+P-014277
+thru
+P-014282
+P-014283
+thru
+P-014284
+P-014285
+thru
+P-014298
+P-014299
+thru
+P-014307
+11/2/2007-11/5/2007 emails between
+and
+regarding drafting 11/5/2007 letter from Sloman to Lefkowitz
+11/5/2007-11/7/2007 emails from
+inquiring about status of matter and contact by Epstein investigators
+with victims
+11/8/2007-11/14/2007 emails between
+regarding response to objections
+raised by Epstein counsel and efforts to chan respere to ily blen
+11/14/2007-11/19/2007 emails between
+1, and
+regarding communications with State Attorney's Office and
+Sheriff's Office in an attempt to insure that Epstein was ineligible for
+work release
+
+
+
+Case 9:08-CV-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 8 of 18
+P-014308
+thru
+P-014310
+P-014311
+thru
+P-014329
+Description
+11/19/2007 emails between
+, and
+about efforts by Epstein's counsel to change date for change of'
+plea
+11/19/2007-11/28/2007 emails between
+and
+regarding drafting victim
+notification letter of upcoming plea
+P-014330
+thru
+P-014337
+P-014338
+thru
+P-014354
+P-014355
+thru
+P-014361
+P-014362
+thru
+P-014402
+P-014403
+thru
+P-014414
+P-014415
+thru
+P-014420
+11/28/2007 correspondence between
+1, and
+regarding Lefkowitz 11/27/2007
+email discussing presentation to DAAG
+11/29/2007-12/1/2007 emails between
+regarding draft
+response to Jay Lefkowitz and victim notification letters
+12/3/2007 emails between
+Villafaña, Alex Acosta, and
+correspondence from Jay Lekowitz and Ken Starr
+12/3/2007-12/5/2007 correspondence between
+about dating and sending the 124/2007 Acosta leter
+to Ken Starr
+12/6/2007 emails between
+regarding correspondence from Ken Starr, request for a
+meeting from Epstein counsel, and need to notify victims of upcoming
+plea
+12/6/2007-12/7/2007 emails between
+1, and
+regarding draft victim
+notification letter
+Attorney -Cieni Privilege
+
+
+Case 9:08-CV-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 9 of 18
+P-014421
+thru
+P-014428
+P-014429
+thru
+P-014439
+P-014440
+P-014441
+P-014442
+P-014443
+P-014444
+P-014445
+thru
+P-014447
+P-014448
+thru
+P-014454
+Description
+12/6/2007-12/7/2007 emails between
+regarding request from State
+Attorney's Office for draft plea proffer
+12/9/2007-12/12/2007 emails between
+and
+regarding drafting response to personal attacks and
+12/11/2007 email from 1
+upcoming meeting with Ken Starr
+and
+regarding,call with lawyer for Jane Doe #2 (T.M.)
+12/12/2007 emails between
+and
+regarding planning indictment review
+12/14/2007 email from
+5
+and
+regarding state cases mentioned by Epstein's
+counsel
+Villafaña tol
+, and
+with draft letters to State
+Attorney's Office and victims
+12/17/2007 email from
+inquiring about
+case status and informing Sloman regarding agent concern about victim
+notifications
+and
+summarizing research into other cases where individuals were charged
+with violating 2422(b) based upon the use of a telephone
+and
+regarding drafting response to concerns raised during December
+14, 2007 meeting between Epstein counsel,
+the FBI SAIC, and
+Deliberaive Process
+
+
+Case 9:08-CV-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 10 of
+P-014455
+thru
+P-014456
+and
+Description
+g
+regarding challenge to state charge raised by
+Epstein counsel during 12/14/2007 meeting
+P-014457
+thru
+P-014464
+12/20/2007 emails between
+and
+regarding
+P-014465
+thru
+P-014485
+P-014486
+P-014487
+P-014488
+thru
+P-014499
+P-014500
+P-014501
+thru
+P-014506
+12/18/2007-12/21/2007 emails between
+and other
+AUSAs regarding other instances of charging 2422(b) based on the use
+of a telephone as a "facility of interstate commerce"
+12/21/2007 email from
+with thoughts on
+recent correspondence from Jay Lefkowitz raising concerns about
+interpretation of the Nonprosecution Agreement
+12/27/2007 email from
+non-prosecution agreement
+12/27/2007 emails between
+, and
+regarding Jay
+Lefkowitz letter of 12/26/2007
+1/2/2008 email from
+land
+regarding telephone conversation with State Attorney's Office about
+delay in Epstein state plea.
+1/2/2008 emails between
+. and
+regarding requests from
+for information
+related to the handling of the investigation by the State Attorney's Office
+
+
+Case 9:08-CV-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 11 of
+P-014507
+thru
+P-014508
+P-014509
+thru
+P-014519
+P-014520
+P-014521
+thru
+P-014522
+P-014523
+P-014524
+thru
+P-014550
+P-014551
+P-014552
+Description
+5
+and
+regarding renewed plea negotiations for federal plea agreement
+1/3/2008 emails hetween
+, and
+_ gardiz admitted that he hover intered to hate steih plead shere
+telephone conference with Jay Lefkowitz where
+to an offense that required sex offender registration.
+1/3/2008 email from
+and
+regarding renewed plea negotiations and press coverage of'
+Epstein matter.
+1/7/2008 email from
+P
+, and
+regarding proposed
+additional investigative steps in Epstein case.
+1/9/2008 email from
+regarding informing Jay Lefkowitz that a CEOS
+attorney would join the SDFL team regarding the Epstein case and
+would review the prosecution and defense materials.
+1/9/2008-1/14/2008 emails between
+I and
+, and
+regarding
+assigning a CEOS attorney to the investigation, meeting with the CEOS
+attorney and victims in Florida, the results of the meetings and planned
+additional meetings, and revisions to the indictment in light of the
+meetings.
+1/17/2008 email from
+regarding
+updated summary charts for indictment preparation, meetings with
+victims, and victim notification letters from FBI
+1/23/2008 email from
+and
+regarding FBI involvement in meeting in DC
+
+Attorney client privilege
+Privacy Act
+Attorney-client privilege
+Attorney-client privilege
+
+
+Case 9:08-CV-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 12 of
+P-014553
+thru
+P-014556
+Description
+1/25/2008 emails between I
+regarding press coverage of case and strategic decisions regarding
+revisions to initial indictment
+P-014557
+1/25/2008 email from 1
+regarding research for purposes of issuing grand fand
+subpoenas.
+P-014558
+P-014559
+thru
+P-014562
+1/29/2008 email from
+Or erin status of meeting in DC and concerns regarding delay.
+1/28/2008-1/29/2008 emails between
+and
+regarding scheduling victim interviews on 1/31/2008-2/1/2008
+P-014563
+thru
+P-014565
+1/30/2008 emails between
+regarding Lefkowitz email about lawsuit filed against Epstein
+by one of the victims identified during the state investigation.
+Attorney-client privilege
+Also contains information subiect to
+
+
+
+Case 9:08-CV-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 13 of
+P-014566
+thru
+P-014568
+Description
+1/31/2008 emails between
+and
+regarding interviews with victims.
+P-014569
+thru
+P-014573
+1/31/2008-2/1/2008 emails between
+1, and Alan Santiago
+regarding results of additional victim-witness interviews and requesting
+intervention with CEOS to move review process along
+P-014574
+thru
+P-014583
+P-014584
+thru
+P-014622
+2/20/2008-2/21/2008 emails between
+Sigal Mandelker.
+and
+regarding
+status of CEOS plans to meet with counsel for Epstein and status of
+indictment review
+2/12/2008-2/22/2008 emails between
+. and
+analyzing facts
+gathered from grand jury investigation and discussing strategy for
+drafting revised indictment
+P-014623
+thru
+P-014627
+P-014628
+2/25/2008 emails between
+and Caroline Heck
+regarding ethical issue about whether or not to present proposed revised
+indictment to new grand jury
+2/25/2008 email from
+, and
+of consultation with Caroline Heck
+regarding result
+about grand jury question
+
+Attorney-client privilege
+parties to this litigation Investigative
+Albaco nains of victims on suite not
+
+
+Case 9:08-CV-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 14 of
+P-014629
+P-014630
+thru
+P-014631
+P-014632
+thru
+P-014646
+P-014647
+thru
+P-014649
+P-014650
+thru
+P-014653
+Description
+2/26/2008 email from
+I to
+regarding
+CEOS review and draft indictment package
+2/26/2008 email from
+5
+regarding
+2/25/2008 correspondence to Jay Lefkowitz further extending
+the plea deadline for Epstein
+2/21/2008-2/27/2008 emails between
+, and
+regarding notifying
+DOJ's Civil Rights Division regarding the status of the case and the
+planned indictment, and the draft written notification
+2/28/2008 emails between
+regarding
+related investigation, potential investigatory leads, and CEOS review
+2/21/2008-2/28/2008 emails between
+1, and
+regarding review of evidence received
+pursuant to subpoenas and planned interviews of additional potential
+victim-witnesses
+P-014654
+thru
+P-014655
+P-014656
+thru
+P-014665
+2/29/2008 emails between
+and
+regarding continuing investigation and status of
+CEOS review
+3/4/2008-3/5/2008 emails between
+and
+regarding search warrant and victim contact with attorneys
+nestigative Pilege
+Attorney-client privilege
+Attorney-client privilege
+
+
+
+Case 9:08-Cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2115 Page 15 of
+P-014666
+thru
+P-014693
+P-014694
+thru
+P-014706
+P-014707
+thru
+P-014711
+P-014712
+thru
+P-014716
+P-014717
+thru
+P-014721
+3/5/2008-3/6/2008 emails between
+regarding meeting in DC, additional
+information to prepare for meeting, and new information from ongoing
+investigation
+3/10/2008-3/12/2008 emails between
+, E.J. Yera, and
+about Epstein attempts to contact victims and finding
+counsel for victims
+3/12/2008 emails between
+1, and
+regarding CEOS meeting with Epstein counsel
+3/14/2008 emails between
+1, and
+regarding complete
+12208-3Me71 packen fo between
+final review
+and E.J. Yera regarding search warrant application and
+execution of search warrant
+P-014722
+thru
+P-014727
+3/14/2008-3/17/2008 emails between
+and
+regarding corrections
+to indictment package and proposed grand jury presentation
+Attorney-client privilege
+Attorney client privilege
+
+
+
+case 9:08-CV-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 16 of
+P-014728
+thru
+P-014742
+P-014743
+thru
+P-014780
+P-014781
+thru
+P-014800
+P-014801
+thru
+P-014810
+P-014811
+thru
+P-014829
+P-014830
+thru
+P-014837
+Description
+3/14/2008-3/19/2008 emails between
+• and
+about Epstein attempts to contact victims
+and finding counsel for victims
+3/19/2008-3/21/2008 emails between
+(CEOS),
+CEOS),
+and
+about meeting between Esptein counsel and CEOS and follow-up
+questions
+3/19/2008-3/27/2008 emails between
++ and
+regarding waiting for DC's decision regarding Epstein's challenges to
+NPA: status of ongoing investigation; problems with Epstein's counsel
+contacting victims in the guise of deposing them for the state criminal
+action; and securing pro bono counsel for those victims to represent
+them in connection with the depositions
+3/28/2008 emails between
+1 and
+regarding status of DC
+review of case and preparing for grand jury presentation
+3/31/2008 emails between
+regarding status of ongoing investigation,
+planned presentation to grand jury, continued delay in awaiting decision
+from Washington, DC, and problems with victims being harassed
+• Alex Acosta,
+regarding efforts by Jay Lefkowitz and Ken Starr to speak
+with Alex Acosta and instructions to direct question to
+Attorney-client privilege
+Delegative Privilege
+
+
+
+Case 9:08-CV-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 17 of
+P-014838
+thru
+P-014843
+P-014844
+thru
+P-014851
+P-014852
+thru
+P-014864
+P-014865
+Description
+4/4/2008-4/7/2008 emails between
+and
+regarding status of CEOS review
+of Epstein matter
+4/10/2008-4/18/2008 emails between
+about continued
+delay in presenting case to grand jury due to failure to receive decision
+from DC, status of grand jury presentation and ongoing investigation
+4/11/2008-4/23/2008 emails between
+1. and
+regarding self-reporting to OPR false allegations of ethics
+4/29/2008 email from
+violations
+, on
+re grand jury presentation
+P-014866
+thru
+P-014883
+P-014884
+thru
+P-014886
+P-014887
+thru
+P-014894
+4/21/2008-5/1/2008 emails between
+and
+about continued delay in presenting case to grand jury due to failure to
+investigation, staffing of case for purposes of trial, and meeting to
+prepare for grand jury presentation
+5/2/2008 emails between
+and
+regarding
+developments in Epstein investigation and impact on grand jury
+presentation
+4/29/2008-5/2/2008 emails between
+and
+regarding contact by Epstein counsel and victims and draft letter to
+counsel for Epstein
+Privacy Act
+
+
+
+Case 9:08-CV-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 18 of
+P-014895
+thru
+P-014900
+P-014901
+thru
+P-014906
+P-014907
+thru
+P-014911
+P-014912
+thru
+P-014919
+P-014920
+thru
+P-014923
+Description
+5/7/2008-5/9/2008 emails between
+, and
+regarding awaiting
+approval from DC and status of ongoing investigation
+5/15/2008-5/16/2008 emails between
+, and
+regarding receiving final approval from DC
+5/19/2008-5/22/2008 emails between
+and
+regarding preparation for grand jury
+presentation; communication with
+regarding plea
+negotiations; and status of ongoing investigation
+5/23/2008-5/27/2008 emails between
+(FBI), and Jason
+Richards (FBI) re status of investigation, indictment review, grand jury
+preparation, and Epstein's attempt to revisit plea negotiations
+8/15/2008 email from
+containing draft
+implemenation of the PA. Rolaced verion produce a posing
+counsel)
+
+
+Case 9:08-cv-80736-KAM Document 338 Entered on FLSD Docket 08/03/2015 Page 1 of 2
+Case No. 08-80736-Civ-Marra/Matthewman
+Petitioners,
+UNITED STATES OF AMERICA,
+Respondent.
+UNITED STATES' NOTICE OF FILING THIRD SUPPLEMENTAL PRIVILEGE LOG
+Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United
+States of America, by and through the undersigned Assistant United States Attorney, hereby gives
+notice of its filing of its Third Supplemental Privilege Log. The index has been marked with
+Bates Numbers P-014924 thru P-015267.
+The documents referenced in the Third Supplemental Privilege Log will be delivered
+tomorrow to the Chambers of U.S. District Judge Kenneth A. Marra for ex parte in camera review,
+pursuant to the Court's Omnibus Order.
+Respectfully submitted,
+UNITED STATES ATTORNEY
+By:
+Florida Bar No. 0018255
+00 South Australian Ave, Suite 40
+/est Palm Beach. FL 3340
+Telephone:
+1
+
+
+Case 9:08-CV-80736-KAM Document 338 Entered on FLSD Docket 08/03/2015 Page 2 of 2
+I HEREBY CERTIFY that on August 3, 2015, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF.
+According to the Court's website,
+counsel for all parties are able to receive notice via the CM/ECF system.
+SERVICE LIST
+Case No. 08-80736-CIV-MARRA/MATTHEWMAN
+United States District Court, Southern District of Florida
+Brad Edwards, Esq.,
+Farmer Jaffe Weissing Edwards Fistos Lehrman
+425 N Andrews Ave Ste 2
+Fort Lauderdale, FL 33301-3268
+Paul G. Cassell
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, Utah 84112
+Attorneys for Jane Doe # 1 and Jane Doe #2
+2
+
+
+Case 9:08-cv-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 1 of 7
+P-014924
+P-014925
+thru
+P-014927
+P-014928
+P-014929
+thru
+P-014933
+P-014934
+thru
+P-014935
+P-014936
+thru
+P-014940
+JANE DOE I. UNITED STATES
+COURT FILE NO. 08-80736-CV-MARRA
+THIRD SUPPLEMENTAL PRIVILEGE LOG - BOX #5
+Description
+5/27/2008 emails between
+and
+regarding
+report of new state plea deal for J. Epstein
+5/27/2008 emails between
+, and I
+and plans do review and revise pdated indictment pack. patein
+5/23/2008-5/27/2008 emails between
+and
+regarding plans to meet to prepare for indictment
+presentation, service of grand jury subpoenas, interviews of additional
+witnesses, and plea negotiation issue
+5/27/2008-5/28/2008 emails between
+regarding request for legal analysis of
+statute of limitations issues under state and federal law
+5/27/2008-5/28/2008 emails between
+. and
+regarding report of new state plea
+deal for J. Epstein
+5/29/2008-5/30/2008 emails between
+regarding
+planned fanny to entire sas or grand jay restinsible grant
+Deterative Processe
+
+
+
+Case 9:08-CV-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 2 of 7
+P-014941
+thru
+P-014954
+P-014955
+thru
+P-014971
+P-014972
+thru
+P-014975
+P-014976
+P-014977
+thru
+P-014978
+P-014979
+thru
+P-014980
+P-014981
+Description
+6/2/2008 draft letter to Deputy Attorney General
+regarding
+reasons to approve continued prosecution of J. Epstein
+(NB: The Court has already determined that final version of this letter
+is protected by Work Product/Deliberative Process/Attornev-Client
+Privileges)
+6/3/2008 draft letter to Deputy Attorney General
+regarding
+reasons to approve continued prosecution of J. Epstein
+(NB: The Court has already determined that final version of this letter
+is protected by Work Product/Deliberative Process/Attorney-Client
+Privileges)
+6/6/2008 emails between
+and E.
+regarding victim/witness subpoenaed to the grand jury and need for
+additional grand jury subpoenas
+6/18/2008 emails between
+, and
+regarding telephone conference
+with R. Black about allowing J. Epstein to accept state plea to 60 days'
+imprisonment.
+6/19/2008 email forwarding 6/19/2008 email from
+NB: Asserting privilege only for
+email. Attorney
+Edwards presumably has copy of his email to
+6/23/2008 emails between
+(USAO staff) regarding scheduling of grand jury time for indictment
+presentation and witness testimony
+(Information regarding unrelated grand jury case redacted)
+6/23/2008 emails between
+regarding grand jury subpoena to
+victim/witness, revisions to indictment, planned grand jury presentation,
+and plans to supersede indictment
+
+
+
+Case 9:08-CV-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 3 of 7
+P-014982
+thru
+P-014990
+P-014991
+thru
+P-015004
+P-015005
+thru
+P-015006
+P-015007
+P-015008
+thru
+P-015024
+P-015025
+thru
+P-015028
+Description
+6/25/2008 emails between
+and
+regarding draft of notification of victim list for
+J. Epstein counsel with attached drafts
+NB: Final list, with victim names redacted, has been produced to
+counsel for Petitioners)
+6/23/2008-6/26/2008 emails between
+and counsel for
+grand jury witness/victim regarding immunity and travel for grand jury
+6/28/2008 emails between
+appearance
+,, and
+change to state plea agreement
+7/3/2008 emails between
+, and
+regarding telephone conf. with
+and regarding meeting with
+Sheriff's Office about work release program
+7/8/2008 emails between
+(Attorney Advisory, Victim
+Witness Staff, EOUSA), and
+regarding filing of
+Petitioners' suit, with attached Draft of
+Declaration and initial
+Petition (DE1)
+(NB: Privilege is not being asserted for second attachment (DE1).
+Attachment was prepared by petitioners and is not being produced
+because it is within their custody and control.)
+7/8/2008 email from
+and
+regarding victim notification letter provided to counsel for J.
+Epstein on 11/28/2007 with attachment
+P-015029
+thru
+P-015034
+7/7/2008-7/8/2008 emails between
+and
+regarding
+background of J. Epstein investigation, negotiations, and victim
+notifications, and forwarding earlier emails related to Lee questions
+
+
+Case 9:08-CV-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 4 of 7
+P-015035
+thru
+P-015062
+P-015063
+thru
+P-015069
+P-015070
+thru
+P-015071
+P-015072
+thru
+P-015074
+P-015075
+thru
+P-015081
+P-015082
+thru
+P-015084
+P-015085
+thru
+P-015090
+Description
+7/8/2008-7/9/2008 emails between
+A. Acosta,
+and
+regarding response to Jane Doe suit, procedure for filing, and internal
+office policies
+7/11/2008-7/14/2008 emails between
+and
+re outcome of hearing in
+Jane Doe . U.S. suit and contact from counsel for J. Epstein
+7/14/2008-7/15/2008 emails between
+, and T. Smith regarding FBI victim
+provide
+7/17/2008 email from
+with attached draft of letter to M. Tein
+regarding misrepresentations in flings on behalf of J. Epstein in civil
+suits
+7/18/2008-7/21/2008 emails between
+regarding
+preparation of victim notification letters, victim contact list, filing of
+victim notification letter in a civil proceeding, and contact by L
+with one victim opining that sentence imposed was insufficient
+7/21/2008 emails between
+, and
+regarding ongoing
+victim notification process and Epstein filings in state court litigation
+related to federal grand jury investigation
+7/22/2008 emails between
+A. Acosta.
+regarding
+7/21/2008 letter from M. Tein announcing plan to stay the civil suits
+against J. Epstein and notification that B. Reinhart is counsel of record
+for S.
+in civil suits
+(NB: Tein letter is being produced to petitioners' counsel concurrently
+with production of this privilege log
+
+
+Case 9:08-CV-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 5 of 7
+P-015091
+thru
+P-015092
+P-015093
+thru
+P-015097
+P-015098
+P-015099
+P-015100
+thru
+P-015116
+P-015117
+thru
+P-015135
+Description
+7/22/2008 emails between
+and E.
+regarding ongoing victim notification process
+7/22/2008 emails between
+and
+regarding correspondence
+from J. Epstein counsel with attached draft response
+(NB: A final version of the letter has been produced.)
+and
+regarding
+correspondence with counsel for J. Epstein and notice of breach
+7/25/2008 emails between
+and
+extension of grand jury to allow for continued presentation of J. Epstein
+case
+8/2/2008 email from
+, and
+summarizing status of Jane Doe
+United States
+litigation and requesting views on making certain disclosures to counsel
+for petitioners with attached pleading filed by petitioners (DE19)
+(NB: Privilege is not being asserted for attachment. Attachment was
+prepared by petitioners and is not being produced because it is within
+their custody and control.)
+8/5/2008 email from |
+and
+regarding analysis of Jeffrey Epstein agreement, with
+attached 6/24/2008 email from
+to R. Black and J.
+Goldberger and attached Epstein agreement.
+(NB: Privilege is not being asserted for the two attachments. The
+6/24/2008 email will be produced to petitioners' counsel
+contemporaneously with the filing of this log, and the Agreement has
+previously been produced to petitioners pursuant to an earlier Court
+order.)
+
+
+Case 9:08-CV-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 6 of 7
+P-015136
+thru
+P-015172
+P-015173
+thru
+P-015186
+P-015187
+thru
+P-015194
+P-015195
+thru
+P-015198
+P-015199
+thru
+P-015206
+P-015207
+thru
+P-015213
+P-015214
+thru
+P-015226
+Description
+8/13/2008-8/15/2008 emails between
+, and
+regarding scope of Epstein
+agreement and correspondence and telephone conference with J.
+Lefkowitz
+(NB: Emails to and from J. Lefkowitz and R. Black have been
+produced to Petitioners' counsel)
+8/25/2008 emails between
+and
+regarding letter received from J.
+Lefkowitz
+(NB: Lefkowitz letter has been produced to Petitioners' counsel)
+8/20/2008-8/26/2008 emails between
+and
+re draft response to J. Leikowitz
+and draft amended victim notification letter
+Petitioners' counsel)
+9/2/2008 emails between
+, and
+regarding revised victim notification
+9/17/2008 emails between
+, and
+regarding efforts by Palm
+Beach Daily News to unseal NonProsecution Agreement that had been
+filed in state court
+(NB: Emails from Counsel for Daily News and from State Attorney's
+9/17/2008 email from
+g
+regarding attached letters from J.
+counsel)
+9/29/2008 correspondence to Florida Bar Ethics Counsel regarding
+victim notification letters and allegation of ethics violation for
+distribution of letters with attached proposed victim notification letters
+
+Relevance
+Florida Bar Privacy Rules
+
+
+Case 9:08-CV-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 7 of 7
+P-015227
+thru
+P-015233
+P-015234
+thru
+P-015238
+P-015239
+thru
+P-015263
+P-015264
+thru
+P-015267
+Description
+10/18/2008-10/20/2008 emails between
+regarding correspondence with
+discussing changes to understanding of portions of Non-Prosecution
+agreement and victim notifications
+11/4/2008 correspondence from Florida Bar Ethics Counsel regarding
+Florida Ethics Rules involved in distributing victim notification letters.
+11/26/2008 emails between
+and
+regarding email from R. Black about work release
+(NB: Email from R. Black has been produced to Petitioners' counsel)
+12/4/2008 emails between E.
+and
+regarding attempts to send victim notification letters overseas via Legal
+Attaches and unrelated Epstein financial issue
+Relevance
+Florida Bar Privacy Rules
+
+
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 1 of 57
+Case No. 9:08-cv-80736-KAM
+Petitioners,
+UNITED STATES,
+Respondent.
+JANE DOE 1 AND JANE DOE 2'S CONSOLIDATED STATEMENT OF UNDISPUTED
+MATERIAL FACTS AND MOTION FOR PARTIAL SUMMARY JUDGMENT WITH
+INCORPORATED MEMORANDUM OF LAW
+(also referred to as "the victims"), by and through
+undersigned counsel, pursuant to Fed. R. Civ. P. 56 and Local Rule 56.1, move for summary
+judgment on the issue of the United States Government's violation of their rights under the
+Crime Victims' Rights Act (CVRA), where no genuine issue of material fact exists.' In support,
+they state:
+INTRODUCTION
+In 2004, Congress enacted the CVRA because it found that in case after case "victims,
+and their families, were ignored, cast aside, and treated as non-participants in a critical event in
+their lives. They were kept in the dark by prosecutors too busy to care enough ... and by a court
+system that simply did not have place for them." 150 CoNG. REC. 7296 (2004) (statement of
+' The Court previously granted the victims leave to file a 60-page motion for partial summary judgment. DE 327.
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 2 of 57
+Sen. Feinstein). In passing the CVRA, Congress mandated a series of rights for crime victims.
+Sadly, several years later, when the Government began handling this case, it did precisely what
+Congress thought it had forbidden. The Government deliberately kept crime victims "in the
+dark" so that it could enter into a plea arrangement designed to prevent the victims from raising
+any objection. In doing so, the Government refused to afford victims the rights they had been
+promised by Congress-particularly "the right to reasonable, accurate, and timely notice of any
+public court proceeding," "the reasonable right to confer with the attorney for the Government in
+the case," and "the right to be treated with fairness and with respect for the victim's dignity and
+privacy."
+The undisputed evidence begins in 2005, when the Palm Beach Police Department
+("PBPD") had identified numerous girls as victims of Jeffrey Epstein's sexual crimes. In 2006,
+the PBPD turned the case over to federal authorities for further investigation. As early as March
+15, 2007 and throughout the rest of the investigation, the United States Attorney's Office for the
+Southern District of Florida ("the Office") specifically identified several dozen girls whom it
+classified as "victims" under the CVRA. Once that identification was made, the Government
+was obligated to afford these victims certain rights under the CVRA—a fact of which the
+Government itself was well aware. Indeed, the Government provided notification to the girls
+that they were classified as "victims" under the CVRA.
+But what the Government did not tell the victims lies at the heart of the case. It is
+undisputed that the Government did not tell the victims that, by May 2007, the Office had
+= 18 U.S.C. § 3771(a)(2), (4)-(5), (8); RFP MIA 000001-000006 (Exhibit 1).
+3 000966-000967 (Exhibit 2); 000589-000591 (Exhibit 3); US_Atty_Cor_00135 (Exhibit 4); RFP MIA 000222
+(Exhibit 5).
+2
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 3 of 57
+prepared an 82-page prosecution memorandum and a 53-page indictment against Epstein and his
+co-conspirators.* At that time, rather than confer with the victims about how to proceed, the
+Government began conferring
+, about this issue exclusively with Epstein's counsel. Epstein's
+counsel contended that, despite abundant connection to interstate commerce, Epstein's sex
+trafficking was purely of local concern. By August 2007, federal prosecutors had disproven or
+rejected these defense arguments and notified the defense that all of the identified victims
+retained federal rights.
+For example, during August 2007,
+and other similarly situated victims,
+provided details to federal agents of the abuse that they endured at the hands of Epstein and his
+co-conspirators. In September 2007, without conferring with any of the victims, the Government
+and Epstein shifted gears and began working together to concoct a criminal charge for Epstein to
+plea to other than his sexual abuse of minors. As alternative charges, they discussed charging
+Epstein with: (1) various misdemeanors, (2) assaulting his co-conspirators and girlfriend, (3)
+using private investigators to chase and harass victims' families, (4) obstructions of grand jury
+subpoenas, or (5) his obstruction of the federal investigation when he instructed another coconspirator to lie to federal agents. Ultimately, however, none of those would work. Assistant
+U.S. Attorney ("AUSA")
+(the "line prosecutor"") informed Epstein's counsel that
+she was getting pushback for creating a charge using one of the main co-conspirators as the
+4 RFP WPB 000286 (Exhibit 6).
+S US_Atty_Cor_00030-00032 (Exhibit 7); RFP MIA 000129 (Exhibit 8); RFP MIA 000133 (Exhibit 9); RFP MIA
+000095 (Exhibit 10); RFP MIA 000075-000076 (Exhibit 11); RFP WPB 000220 (Exhibit 12); RFP MIA 000077-
+000087 (Exhibit 13); RFP MIA 000088 (Exhibit 14); RFP WPB 000235-000244 (Exhibit 15); RFP WPB 000107-
+000112 (Exhibit 16); RFP WPB 002188 (Exhibit 17); RFP WPB 000266-000277 (Exhibit 18); RFP MIA 000113
+(Exhibit 19); RFP MIA 000151-000160 (Exhibit 20); RFP MIA 000098-000105 (Exhibit 21).
+3
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 4 of 57
+victim. Consequently, the Government and Epstein searched for another crime for Epstein to
+plead to, which could accompany a federal non-prosecution agreement (NPA). Incredibly, the
+offense to which Epstein and the Government ultimately agreed, labeled the minor victims
+"prostitutes."
+The undisputed evidence clearly shows that by September 21, 2007, the line prosecutor
+had informed Palm Beach State Attorney
+that a federal resolution had been
+reached by way of a NPA, yet the victims remained uninformed.? On September 24, 2007, the
+NPA was signed, preventing prosecution of all federal crimes committed by Epstein and his coconspirators against the victims. After the signing of the NPA, the Government and Epstein's
+attorneys worked together to choose a lawyer to be paid by Epstein to represent Epstein's victims
+for the purpose of settling civil restitution claims. This too was all being done without the
+victims having any knowledge whatsoever. The correspondence between the Government and a
+candidate for that representative position as well as between the Government and Epstein's
+counsel reflects that the Government still had not yet disclosed the NPA to the victims, and was
+following the guidance of Epstein's counsel in making decisions with respect to the timing and
+substance of any communication to the victims.®
+For the next nine months, from the time the NPA was signed through the date of
+Epstein's state court plea in June of 2008, the Office doing Epstein's bidding-assiduously
+concealed the NPA's existence from the victims. While this indulgent deal was incredible in its
+own right, even more extraordinary was how the victims were treated during the process. Rather
+• Exhibit 15.
+- RFP WPB 002125 (Exhibit 22).
+" See eg., US_Alty_Cor _00166 (Exhibit 23).
+4
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 5 of 57
+than confer with the victims about the fact that resolution by NPA was ever being considered
+or even tell them that it was already a signed dealthe Office and Epstein inserted a
+"confidentiality" provision into the agreement barring its disclosure to anyone, including the
+victims. There is no dispute that the Government did not inform the victims of the NPA or of the
+possibility of any such type of resolution. Consequently, there is no dispute that the Government
+did not afford the victims any rights before the signing of the NPA.
+In October 2007, after the NPA was signed, federal agents spoke with three of the more
+than 30 identified victims, including
+The Government does not dispute that this
+contact only occurred after the signing of the NPA. Even more important, it is not disputed that
+this contact was: 1) made by the Federal Bureau of Investigation ("FBI") and not a "prosecutor
+for the Government," 2) that the FBI did not inform the victims of the NPA and certainly did not
+confer with the victims about the details of the NPA, and 3) that this contact only occurred with
+three of the more than 30 victims. Lastly, while the content of that conversation is contested, any
+stretched argument that the conversation satisfied CVRA requirements for
+are belied
+by the timing of the conversation as well as the uncontested documentary evidence of the
+communications with the victims (including with
+that followed that conversation.
+Subsequent to the FBI's contact with three of Epstein's victims, the Government
+informed Epstein's attorneys that victim notification letters needed to be sent to all the victims
+pursuant to the CVRA. Rather than comply with this acknowledged requirement, Epstein's
+counsel convinced the Government that (contrary to standard Government practice) Epstein
+• RFP MIA 000464-000468 (Exhibit 24).
+5
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 6 of 57
+should be permitted to provide input into any message being delivered, and ultimately that the
+victims should not be told anything "until after Epstein pleas."10
+In January 2008, FBI agents again met with
+and gathered additional details
+about Epstein's abuse as well as the direct sexual abuse by one of his co-conspirators,
+who participated in the abuse of other victims as well. The Government then sent
+a victim notification letter to Jane Doe 1 informing her of her rights under the CVRA, that "this
+will be a long investigation," and to "be patient."'|
+was sent a similar letter on June
+7, 2008.!? Other victims were also sent these letters communicating that the Epstein case was an
+on-going active criminal investigation—-not that the Government had already immunized Epstein
+for all federal crimes committed against each of the victims, through a NPA. These misleading
+letters were sent almost up until the date of Epstein's state court plea in late June 2008.!3
+On June 30, 2008, Epstein pled guilty to state court charges. It is uncontested that the
+victims were not reasonably and accurately informed about that hearing-specifically, they were
+never told the hearing was part of a process that would extinguish any possibility of Epstein
+being prosecuted for the crimes he had committed against them in Florida. Even after the plea,
+the Government once again conferred with Epstein's attorneys to decide what to tell the victims.
+As the Court is aware, this CVRA action was filed in July 2008 at a time when the
+victims mistakenly believed that the federal case remained open, and wanted to ensure that their
+rights under the CVRA were afforded before any possible federal disposition. At the emergency
+10 RFP WPB 001978-001979 (Exhibit 25).
+" Declaration o
+12 000978-000989 (Exhibit 28).
+I [DE 48] Exhibit I (Exhibit 29).
+(Exhibit 27).
+6
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 7 of 57
+hearing on the Petition for Enforcement of Crime Victims' Rights Act,
+vere in the courtroom to learn for the first time that the federal case had been resolved.
+The undisputed facts show that for nine months, the Government and Epstein conspired
+to conceal the NPA from the victims to prevent them from voicing any objection, and to avoid
+the firestorm of controversy that would have arisen if it had become known that the Government
+was immunizing a politically-connected billionaire and all of his co-conspirators from
+prosecution of hundreds of federal sex crimes against minor girls. Such facts demonstrate clear
+violations of the CVRA's requirements that the Government afford victims the reasonable right
+to confer, the right to be treated with fairness, and the right to reasonable and accurate notice
+about court hearings. No genuine issue of material fact or law can exist on these points. The
+Court should accordingly grant summary judgment for the victims on the issue of the CVRA
+violations and then, in subsequent proceedings, turn to the issue of the proper remedy for those
+violations.
+STATEMENT OF UNDISPUTED MATERIAL FACTS
+Pursuant to Local Rule 56.1, the victims submit this statement of undisputed material
+facts in support of their motion for partial summary judgment:!4
+14 In an effort to streamline their case and bring it to a more rapid resolution, in this summary judgment motion the
+victims present only some of the evidence that they are prepared to produce at any evidentiary hearing in this matter.
+For instance, the victims have concentrated on the emails and other documents establishing violations of their rights,
+largely avoiding issues of the Government's "motive" for the violations and other related issues. Because of the
+possibility that the Court may not grant summary judgment on this narrower approach, the victims are continuing to
+pursue discovery with regard to motive and several other important issues that would come into play at a broader
+evidentiary hearing. See, e.g., [DE 344] (victims' motion for deposition of government witnesses). The victims
+reserve the right to supplement this motion if additional discovery is received through these discovery efforts and to
+present these broader issues at any evidentiary hearing or remedy phase of these proceedings.
+7
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 8 of 57
+EPSTEIN'S CRIMES
+1. Between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor
+girls, including
+at his mansion in Palm Beach, Florida, located in the
+Southern District of Florida, and elsewhere in the United States and overseas.'
+2. Because Epstein and his co-conspirators knowingly traveled in interstate and
+international commerce to sexually abuse
+and other similarly situated
+victims, they committed violations of not only Florida law (see, e,g., Fla. Stat. §§ 794.05, 796.04,
+796.045, 39.201 & 777.04), but also federal law, including repeated violations of 18 U.S.C. §§
+1591, 2421, 2422, 2423, & 371) "
+EPSTEIN'S VICTIMS
+3. In addition to personally abusing his victims, Epstein also directed other persons to
+sexually abuse the girls. For example,
+sexually abused
+and other
+victims at the direction of Epstein.!?
+IS See, e.g., Exhibit 26; Exhibit 27;
+Epstein Complaint (Exhibit 30): Resnonse to Request for
+Admission #1 (Exhibit 31) (admitting federal investigation); FBI 302 of Interview with
+on August 14,
+2007 (Exhibit 32); FBI 302 of Interview with
+on January 31, 2008 (Exhibit 33); Palm Beach Police
+memo and 52-page prepared indictment); [DE 304] Declaration of FBI Special Agent |
+thane and 52-page prepared freial vy, or okat abuse by of 58 peti apie ofte sat of 2 natal.
+Jeffrey Epstein (Exhibit 36); RFP WPB 000550-000554 (Exhibit 37) (listing 31 victims the that U.S. Attorney's
+Office was prepared to name as a victim of an enumerated federal offense); Sora Hearing Transcript (Exhibit 38);
+RFP MIA 000361-000365 (Exhibit 39) (Chief of Child Exploitation Section of the Justice Department concluding
+after review of the facts that U.S. Attorney's would not abuse its discretion in prosecuting; noting "multiple
+mutually-corroborating witnesses;" the Epstein case "consistent in principle with other federal prosecutions
+nationwide").
+10 See note 14, supra.
+1 See Exhibit 32; Exhibit 33; Exhibit 34.
+8
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 9 of 57
+THE INVESTIGATION OF EPSTEIN'S CRIMES
+4. In 2005, the Town of Palm Beach Police Department received a complaint from the
+parents of a 14-year-old girl about her sexual abuse by Jeffrey Epstein. The PBPD then capably
+conducted a thorough investigation and ultimately identified approximately 20 girls between the
+ages of 14 and 17 who were sexually abused by Epstein.'
+5. In 2006, at the request of the PBPD, the FBI opened a federal investigation into
+allegations that Epstein and his personal assistants had used facilities of interstate commerce to
+induce girls between the ages of 14 and 17 to engage in illegal sexual activities.
+6. The FBI ultimately determined that both
+ere victims of
+sexual abuse by Epstein while they were minors.
+for example, provided detailed
+information about her abuse—-and the abuse o
+to the FBI on August 7, 2007.19
+7. On about August 11, 2006,
+received a standard CVRA victim notification
+letter. The notification promised that the Justice Department would make its "best efforts" to
+protect
+s rights, including "It]he reasonable right to confer with the attorney for the
+Government in the case" and "to be reasonably heard at any public proceeding in the district
+court involving ….. plea." The notification further explained that "[a]t this time, your case is
+under investigation." 20 That notification meant that
+ad been identified as a victim
+of a federal offense and as someone protected by the CVRA.
+18 Exhibit 34; see also RFP WPB 001940-001941 (Exhibit 40) (later description of investigation by the U.S.
+Attorney's Office).
+19 Exhibit 26; Exhibit 27; Exhibit 32.
+20 August 11, 2006 Victim Notification Letter tol
+(Exhibit 41).
+9
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 10 of 57
+8. More generally, the FBI established that Epstein used paid employees to repeatedly
+find and bring minor girls to him. Epstein worked in concert with others to obtain minor girls
+not only for his own sexual gratification, but also for the sexual gratification of others.?'
+EPSTEIN'S FEDERAL PLEA NEGOTIATIONS
+9. From January 5, 2007 through September 2007, plea discussions took place between
+the U.S. Attorney's Office for the Southern District of Florida and Jeffrey Epstein, who was
+represented by numerous attorneys.?
+10. On February 1, 2007, the Epstein defense team sent a 24-page letter to the Office
+going over what they intended to present during a meeting at the Office the same day. The letter
+falsely stated: "Epstein did not know or believe any women were under 18 years of age." It also
+contained other deceptive factual and legal arguments about Epstein's culpability.23
+11. By March 15, 2007, the Office was sending letters to victims informing them of their
+rights pursuant to the CVRA.24
+12. By May 2007, the Office had drafted an 82-page prosecution memorandum and 53-
+page indictment outlining numerous federal sexual offenses committed by Epstein.?5
+13. On about June 7, 2007, FBI agents hand delivered to
+a standard CVRA
+victim notification letter. The notification promised that the Justice Department would make its
+"best efforts" to proted
+rights, including "[t]he reasonable right to confer with the
+attorney for the United States in the case" and "to be reasonably heard at any public proceeding
+"' See note 14, supra.
+22 RFP WPB 001744 (Exhibit 42).
+23 RFP WPB 000730-000754 (Exhibit 43) (asserting Epstein thought the girls were 18 or older).
+24 Exhibit 1.
+25 US_Atty_Cor. 00004 (Exhibit 44); Exhibit 6.
+10
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 11 of 57
+in the district court involving [a]...plea." The notification further stated that, "[a]t this time, your
+case is under investigation."26
+14. The notification described in the previous paragraph meant that
+had been
+identified as a victim of a federal offense and as someone protected by the CVRA.
+relied on these representations and believed that the Government would protect these rights and
+keep her informed about the progress of her case.?7
+15. On July 6, 2007, Epstein's lawyers sent a 23-page letter lodging numerous, technical
+legal arguments to persuade the Office that no federal crimes had been committed by Epstein,
+and that consequently there were no federal crime victims. The letter also falsely claimed that
+"Mr. Epstein never targeted minors," and urged the Government against a federal prosecution on
+the basis that Epstein was an upstanding citizen who had made tremendous philanthropic and
+personal contributions that warranted a declination to prosecute.?8
+16. On August 2, 2007, another attorney for Epstein sent a similar letter expressing the
+same sentiments.?9
+17. However, by August 3, 2007, the Government had disproven or rejected Epstein's
+various arguments against federal charges, as AUSA
+sent a letter to Epstein's
+counsel stating, "[w]e would reiterate that the agreement to Section 2255 liability applies to all of
+the minor girls identified during the federal investigation, not just the 12 that form the basis of an
+25 June 7, 2007 Victim Notification Letter to
+(Exhibit 45).
+27 Exhibit 26.
+28 MIA CEOS_00077-00099 (Exhibit 46); RFP MIA 000189 (Exhibit 47).
+29 RFP MIA 000053-000055 (Exhibit 48).
+11
+•
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 12 of 57
+initial planned charging instrument."30 This was a clear indication from the federal prosecutors
+that all of the minor girls identified through the investigation were classified as victims with
+federal rights pursuant to the CVRA.
+18. By September 10, 2007, multiple drafts of the NPA had been exchanged between
+Epstein's counsel and the U.S. Attorney's Office; however, no one from the Office and no
+Government representative had notified a single victim about the existence of the plea
+negotiations, much less conferred with them about their views on those negotiations.?!
+19. On September 12, 2007, while attempting to create alternative charges against Epstein,
+the U.S. Attorney's Office expressed concern about "the effect of taking the position that Mr.
+Epstein's house is in the special maritime and territorial jurisdiction of the United States"
+because the Government had "no evidence of any assaults occurring either on Mr. Epstein's
+plane or offshore from his residence. *32
+20. On September 13, 2007, the line prosecutor emailed Epstein's counsel indicating that
+in an effort to come up with a solution to the September 12 concern, she had been "spending
+some quality time with Title 18 looking for misdemeanors." The line prosecutor further
+indicated, "I know that someone mentioned there being activity on an airplane, I just want to
+make sure that there is factual basis for the plea that the agents can confirm." Epstein's counsel
+responded, "[a]lready thinking about the same statutes."33
+30 RFP WPB 001479-001480 (Exhibit 49); Exhibit 48 (earlier correspondence attached for reference).
+31 RFP MIA 000058-000063 (Exhibit 50).
+32 Exhibit 12; RFP MIA 000072-000073 (Exhibit 51).
+33 Exhibit 11 (emphasis added).
+12
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 13 of 57
+21. On September 14, 2007, after having spoken on the telephone about the subject matter
+of the September 13 emails, Epstein's counsel and the line prosecutor exchanged emails
+including a proposed plea agreement for Epstein to plea to assaulting one of his coconspirators.4
+22. On September 15, 2007, the line prosecutor sent an email to the Epstein defense team
+raising concerns about a resolution that would not involve one of Epstein's minor victims and
+stating:
+I have gotten some negative reaction to the assault charge with [a co-conspirator]
+as the victim, since she is considered one of the main perpetrators of the offenses
+that we planned to change in the indictment. Can you talk to Mr. Epstein about a
+young woman named
+|? We have hearsay evidence that she traveled on
+Mr. Epstein's airplane when she was under 18, in around the 2000 or 2001 time
+frame. "5
+23. On September 16, 2007, the line prosecutor corresponded with Epstein's counsel
+about having Epstein plead to obstruction of justice for pressuring one of his co-conspirators to
+prevent her from turning over evidence or complying with a previously-served grand jury
+subpoena.36
+24. In the same correspondence, the Office discussed with defense counsel how they could
+contrive to establish jurisdiction away from the location where the crimes actually occurred
+and away from where the victims actually lived
+-so as to avoid the public finding out about
+anything: "On an 'avoid the press' note, I believe that Mr. Epstein's airplane was in Miami on
+the day of the [co-conspirator] telephone call. If he was in Miami-Dade County at the time, then
+3* Exhibit 13.
+35 Exhibit 15; RFP WPB 000066-000074 (Exhibit 52).
+3 RFP WPB 000124-000126 (Exhibit 53).
+13
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 14 of 57
+I can file the charge in the District Court in Miami, which will hopefully cut the press coverage
+significantly." They also discussed having Epstein plea to a second charge of assaulting a
+different co-conspirator.7
+25. On September 16, 2007, the line prosecutor wrote to Epstein's counsel indicating that
+the Office did not like the factual basis for the proposed charges as the Office was "not
+investigating Mr. Epstein abusing his girlfriend. "38
+26. The correspondence further discussed a possible plea disposition that would make it
+hard for a judge to see what was happening:
+Andy [i.e., AUSA Andrew Laurie] recommended that some of the timing issues
+be addressed only in the state agreement, so that it isn't obvious to the judge that
+we are trying to create federal jurisdiction for prison purposes.
+I will include our standard language regarding resolving all criminal liability and I
+will mention 'co-conspirators,' but I would prefer not to highlight for the judge all
+of the other crimes and all of the other persons that we could charge. Also, we do
+not have the power to bind Immigration... there is no plan to try to proceed on
+any immigration charges against either Ms. [co-conspirator] or Ms. [coconspirator]."
+27. In the same email, the line prosecutor wrote to defense counsel about a meeting
+outside the U.S. Attorney's Office: "Maybe we can set a time to meet. If you want to meet off
+campus' somewhere, that is fine."40
+28. On about September 16, 2007, Epstein's counsel provided a proposed NPA to the
+Government that extended immunity from federal prosecution not only for Epstein, but also to
+37 US_Atty_Cor. at 29 (Exhibit 54); RFP WPB 000122 (Exhibit 55); RFP WPB 000125-000126 (Exhibit 56); RFP
+MIA 000281 (Exhibit 57).
+35 Exhibit 7.
+39 Id.
+40 Exhibit 7; US_Atty_Cor. 00196 (Exhibit 58) (indicating that at least one additional meeting was held off campus
+between the Government and counsel for Epstein).
+14
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 15 of 57
+certain co-conspirators: "Epstein's fulfilling the terms and conditions of the Agreement also
+precludes the initiation of any and all criminal charges which might otherwise in the future be
+brought against
+Lesley Groff, and
+or any
+employee of N.E.S. for any criminal charge that arises out of the ongoing federal investigation as
+described above."41
+29. On September 17, 2007, the line prosecutor wrote to defense counsel Jay Lefkowitz:
+"Please send [a document] to my home e-mail address - [redacted] and give me a call on my cell
+[redacted] so I can be ready for some discussions tomorrow."2 In discovery in this case, the
+U.S. Attorney's Office has not produced any emails sent to or from any home e-mail addresses
+of its prosecutors.
+30. On September 17, 2007, defense counsel Jay Lefkowitz responded: "[DJo you have
+another obstruction proffer I can review that you have drafted? Also, if we go that route, would
+you intend to make the deferred prosecution agreement public?*3
+31. On September 18, 2007, the Office responded: "A non-prosecution agreement would
+not be made public or filed with the Court, but it would remain part of our case file. It probably
+would be subject to a FOIA request, but it is not something that we would distribute without
+compulsory process."*4
+32. On September 20, 2007, the U.S. Attorney's Office wrote: "On the issue about 18
+USC 2255 [a civil restitution provision], we seem to be miles apart. Your most recent version
+4' Exhibit 16.
++2 RFP WPB 001709 (Exhibit 59).
+* Exhibit 17.
+* Exhibit 10.
+15
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 16 of 57
+not only had me binding the girls to a trust fund administered by the state court, but also
+promising that they will give up their 2255 rights.... In the context of a non-prosecution
+agreement, the office may be more willing to be specific about not pursuing charges against
+others. "45
+33. On September 21, 2007, state prosecutor
+wrote the line prosecutor
+about the proposed deal and added: "Glad we could get this worked out for reasons I won't put in
+writing. After this is resolved I would love to buy you a cup at Starbucks and have a
+conversation."46 Such statement is further evidence of the fact that Epstein's counsel, the U.S.
+Attorney's Office, and the State of Florida were conferring daily in an effort to resolve the case
+in a way that would compensate the victims through restitution, yet no one made any effort to
+notify the victims of the true status of the case.
+34. On September 21, 2007, the line prosecutor emailed Epstein's counsel stating, "I think
+that the attached addresses the concerns about having an unlimited number of claimed victims,
+without me trying to bind girls whom I do not represent."47 Despite knowledge that such
+agreement would be binding on the victims, the Office never attempted to notify or confer with
+the victims about the existence of the NPA.
+35. On September 23, 2007, the U.S. Attorney's Office sent an email to Lefkowitz stating:
+"It is factually accurate that the list we are going to give you are persons we have identified as
+victims. If we did not think they were victims, they would have no right to bring suit.*8
+45 RFP MIA 000173 (Exhibit 60).
+45 Exhibit 21.
+47 US_Atty_Cor_0081-0087 (Exhibit 61) (emphasis added).
+43 Exhibit 4.
+16
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 17 of 57
+36. On September 24, 2007, the line prosecutor sent an e-mail to a prospective
+representative for the Epstein victims named Humberto "Bert" Ocariz, entitled "Conflict Check"
+confirming the girls" status as victims, stating: "Please keep this confidential because these are
+minor victims. This is a preliminary list."9 Later on September 24, 2007, the line prosecutor
+sent an email to Lefkowitz stating, "I have compiled a list of 34 confirmed minors."50
+37. As correspondence continued on September 24, 2007, and the NPA was being
+executed, Lefkowitz sent an email to line prosecutor
+whatever you can to keep this [i.e., the NPA] from becoming public."|
+stating: "
+- Please do
+SIGNING THE SECRET NON-PROSECUTION AGREEMENT
+38. On September 24, 2007, Epstein and the U.S. Attorney's Office formally reached an
+agreement whereby the United States would defer federal prosecution in favor of prosecution by
+the State of Florida. Epstein and the Office accordingly entered into a NPA reflecting such
+agreement. Most significantly, the NPA gave Epstein a promise that he would not be prosecuted
+in the Southern District of Florida for a series of federal felony offenses involving his sexual
+abuse of more than 30 known minor girls and countless other unknown minors. The NPA
+instead allowed Epstein to plead guilty to state felony offenses for solicitation of prostitution and
+procurement of minors for prostitution.
+39. The NPA also set up a procedure whereby a victim of Epstein's sexual abuse could
+obtain an attorney to proceed with a civil settlement with Epstein, provided that the victim
+49 Exhibit 2.
+so Exhibit 4.
+S' Exhibit 57.
+52 Executed Non-Prosecution Agreement (Exhibit 62).
+17
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 18 of 57
+agreed to limit damages sought from Epstein." Such provision was devised by Epstein's
+counsel and the Office without the knowledge or consent of the victims, and without any
+opportunity for them to reasonably confer on the provision.
+40. Among other provisions, the NPA expanded immunity to any "potential coconspirator" of Epstein's: "In consideration of Epstein's agreement to plead guilty and to provide
+compensation in the manner described above, if Epstein successfully fulfills all of the terms and
+conditions of this agreement, the United States also agrees that it will not institute any criminal
+charges against any potential co-conspirators of Epstein, including but not limited to
+Lesley Grott, or
+3954
+41. The NPA also provided that it was confidential: "The parties anticipate that this
+agreement will not be made part of any public record. If the United States receives a Freedom of
+Information Act request or any compulsory process commanding the disclosure of the
+agreement, it will provide notice to Epstein before making that disclosure."55
+LACK OF VICTIM NOTIFICATION BEFORE THE NPA WAS SIGNED
+42. From the time the FBI began investigating Epstein until September 24, 2007—when
+the NPA was concluded—-the U.S. Attorney's Office never conferred with the victims about a
+NPA. 56
+43. From the time the FBI began investigating Epstein until September 24, 2007—when
+the NPA was concluded-the U.S. Attorney's Office never even told the victims that such an
+" Exhibit 62.
+s* Id. at 5.
+55 Id.
+56 See Tr. of July 11, 2008 Hearing (Exhibit 63) at 9-12; [DE 14] at 4 (Exhibit 64).
+18
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 19 of 57
+agreement was under consideration.?
+FAILURE TO NOTIFY OTHER SIMILARLY-SITUATED VICTIMS
+ABOUT THE NPA
+44. Many, if not all, other similarly-situated victims received standard CVRA victim
+notification letters substantively identical to those sent to
+and the
+Government reasonably expected them to rely on those representations.S8
+45. The U.S. Attorney's Office did not consult or confer with any of the victims about the
+NPA before it was signed. 59
+46. The U.S. Attorney's Office did not tell any of the victims about the NPA before it was
+signed.®
+47. Because none of the victims knew about the NPA or any other possible resolution of
+the case, they could not have conferred with prosecutors about the NPA before it was signed."!
+48. Epstein's counsel was aware that the Office was deliberately keeping the NPA secret
+from the victims and, indeed, had sought assurances to that effect. 2
+NEGOTIATIONS ABOUT CONCEALING THE NPA FROM THE VICTIMS
+49. After the NPA was signed, Epstein's counsel and the Office began negotiations about
+whether the victims would be told about the NPA."3
+57 See Exhibit 63 at 9-12; Exhibit 64 at 4; [DE 225-1] at 51 (Exhibit 65).
+59 Id.
+61 Exhibit 26; Exhibit 27.
+62 Exhibit 63 at 9; US _ Atty_Cor. 0153 (Exhibit 66) (emphases added); RFP MIA 000489-000491 (Exhibit 67).
+6 Exhibit 66 (emphases added).
+19
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 20 of 57
+50. It was a deviation from the Government's standard practice to negotiate with defense
+counsel about the extent of crime victim notifications.64
+51. To pressure the Office to agree to positions they wanted, Epstein's counsel began "a
+year-long assault on the prosecution and the prosecutors." This assault was more aggressive than
+any U.S. Attorney Alex Acosta, or any of his prosecutors, had ever seen in their extensive
+experience."
+52. On about September 24, 2007, the U.S. Attorney's Office sent an e-mail to Lefkowitz,
+stating that the Government and Epstein's counsel would negotiate privately about what
+information would be disclosed to the victims about the agreement:
+Thank you, Jay. I have forwarded your message only to [United States Attorney]
+contains identifying information about the girls.
+issue, just about what crimes Mr. Epstein is pleading guilty to and the amount of
+time that has been agreed to. Rolando also is telling Chief Reiter not to disclose
+the outcome to anyone."6
+53. On September 25, 2007, the line prosecutor sent an e-mail to Lefkowitz stating: "And
+can we have a conference call to discuss what I may disclose to ... the girls regarding the
+agreement.*7
+64 Exhibit 65 at 50.
+iS 001795-001797 (Exhibit 68); see, e.g., Exhibit 24.
+65 Exhibit 66 (emphases added).
+67 US_Atty_Cor, at 156 (Exhibit 69).
+20
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 21 of 57
+54. On September 25, 2007, the line prosecutor sent an email to Lefkowitz, (1) expressing
+what she called "bias" against plaintiffs" attorneys, (2) trying to set up an arrangement whereby
+Epstein's victims would not be represented by various private attorneys, and (3) arguing instead
+for an attorney in Miami who could help keep things concealed: "They [Ted Babbitt, Stuart
+Grossman, Chris Searcy, Jake Lytal] are all very good personal injury lawyers, but I have
+concerns about whether there would be an inherent tension because they may feel that THEY
+might make more money (and get a lot more press coverage) if they proceed outside the Terms
+of the plea agreement. (Sorry - I just have a bias against plaintiffs' attorneys.) One nice thing
+about Bert is that he is in Miami where there has been almost no coverage of this case."68
+55. On September 26, 2007, the line prosecutor sent an e-mail to Lefkowitz in which she
+stated: "Hi Jay - Can you give me a call at |
+[xxx-xxxx] this morning? 1 am meeting with the
+agents and want to give them their marching orders regarding what they can tell the girls. "69
+56. On September 27, 2007, the attorney appointed by the Office to represent the
+victims—-without the knowledge of the victims emailed the Office asking questions about the
+assignment, including whether he could see a copy the indictment or plea agreement "so that we
+understand exactly what Epstein concedes to in the civil case."*70
+57. On September 27, 2007, upon inquiry from the Office, Lefkowitz responded by stating
+that the attorney representative "certainly I] should not get a copy of any indictment.*!
+68 RFP WPB 000384 (Exhibit 70).
+69 Exhibit 26; US
+_Atty_Cor. at 359 (Exhibit 71).
+° 000574-000575 (Exhibit 72).
+71 RFP WPB 001687 (Exhibit 73).
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 22 of 57
+58. On September 27, 2007, the line prosecutor informed Epstein's counsel of concerns
+raised by the attorney representative for the girls selected by the Government and paid for by
+Epstein. Specifically, "[t]he concern is, if all 40 girls decide they want to sue, they don't want to
+be in a situation where Mr. Epstein says this is getting too expensive, we won't pay anymore
+attorneys' fees."72
+59. On September 27, 2007, the line prosecutor sent an email to state prosecutors
+and
+"Can you let me know when Mr. Epstein is going to enter his
+guilty plea and what judge that will be in front of? I know the agents and 1 would really like to
+be there, 'incognito."" The fact that they intended to be at the plea proceeding "incognito" is
+evidence that they did not intend to notify the victims of the proceeding.?
+60. On October 3, 2007, the U.S. Attorney's Office sent a proposed letter that would have
+gone to a special master for selecting an attorney representative for the victims under NPA's
+compensation procedure. The letter described the facts of the Epstein case as follows: "Mr.
+Epstein, through his assistants, would recruit underage females to travel to his home in Palm
+Beach to engage in lewd conduct in exchange for money. Based upon the investigation, the
+United States has identified 40 young women who can be characterized as victims pursuant to 18
+U.S.C. § 2255. Some of those women went to Mr. Epstein's home only once, some went there
+as many as 100 times or more. Some of the women's conduct was limited to performing a
+72 Exhibit 23.
+* RFP WPB 002046 (Exhibit 74).
+22
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 23 of 57
+topless or nude massage while Mr. Epstein masturbated himself. For other women, the conduct
+escalated to full sexual intercourse."74
+61. On October 10, 2007, Lefkowitz sent a letter to U.S. Attorney Acosta stating, in
+pertinent part: "Neither federal agents nor anyone from your Office should contact the identified
+individuals to inform them of the resolution of the case, including appointment of the attorney
+representative and the settlement process. Not only would that violate the confidentiality of the
+agreement, but Mr. Epstein also will have no control over what is communicated to the identified
+individuals at this most critical stage. We believe it is essential that we participate in crafting
+mutually acceptable communication to the identified individuals." The letter further proposed
+that the attorney representative for the victims be instructed that "[t]he details regarding the
+United States's investigation of this matter and its resolution with Mr. Epstein is confidential.
+You may not make public statements regarding this matter."?5
+62. On October 18, 2007, the U.S. Attorney met with Lefkowitz in person for breakfast.
+Meanwhile, the victims had still not been notified of the NPA.7
+63. On October 23, 2007, Lefkowitz sent a letter to U.S. Attorney Acosta, which stated: "l
+also want to thank you for the commitment you made to me during our October 12 meeting in
+which you... assured me that your Office would not ... contact any of the identified
+individuals, potential witnesses, or potential civil claimants and their respective counsel in this
+matter. "77
+*4 RFP WPB 000411-000412 (Exhibit 75).
+15 RFP MIA 000015-000016 (Exhibit 76).
+76 RFP WPB 002020-002021 (Exhibit 77).
+" Exhibit 67 (emphasis added).
+23
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 24 of 57
+64. On October 24, 2007, AUSA
+sent a letter to Jay Lefkowitz, proposing an
+Addendum to the NPA clarifying the procedures for the third-party representative for the victims
+under the NPA's compensation procedures."
+65. On October 25, 2007, AUSA |
+sent a letter to Ret. Judge Davis about
+selecting an attorney to represent the victims under the NPA's compensation procedure.?
+LACK OF VICTIM NOTIFICATION AFTER THE NPA WAS SIGNED
+66. After the NPA was signed, the Office regarded the agreement as having "an express
+confidentiality provision."0
+67. By entering into the confidentiality provision, the Office put itself in a position that
+conferring with the crime victims-including
+and other similarlysituated victims-about the co-conspirator immunity provision and the NPA's non-prosecution
+provisions would have violated the confidentiality provision of the agreement.'
+68. The confidentiality provision was a contractual prohibition, binding on the U.S.
+Attorney's Office, against disclosing the terms of the NPA.82
+69. Epstein was well aware of this failure to notify the victims and, indeed, arranged for
+this failure to notify the victims.*3
+70. On about October 26 or 27, 2007, after the initial plea agreement was signed, FBI
+agents contacted
+Special Agents E.
+and
+met in
+78 US_Atty_Cor. 00220-00226 (Exhibit 78).
+* 000551-000554 (Exhibit 79).
+80 Exhibit 64 at 4.
+81 Exhibit 62.
+82 Id.
+B3 Id.; Exhibit 63 at 4-6, 18-19, 22-23, 28-29; Exhibit 64 at 4-5; Exhibit 69.
+24
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 25 of 57
+person witl
+During this litigation, the Special Agents have said that they explained
+that Epstein would plead guilty to state charges involving another victim, he would be required
+to register as a sex offender for life, and he had made certain concessions related to the payment
+of damages. 84
+71. During this meeting, the Special Agents did not explain that an agreement had already
+been signed that precluded any prosecution of Epstein for federal charges for crimes committed
+against Jane Doe 1 or the many other victims cooperating with the federal investigation.®S
+72. The Special Agents also did not explain that an agreement had already been signed
+that precluded any prosecution of Epstein's co-conspirators, including
+who had
+personally sexually abuse
+the direction of Epstein. Because the plea arrangement
+had already been reached with Epstein, the agents made no attempt to secure
+view
+on the proposed resolution of the case or to confer with her about it. 86
+73.
+did not get the opportunity to meet or confer with the attorney for the
+Government in the case about any potential federal deal that related to her or the crimes Epstein
+committed against her.87
+74. The agents could not have revealed the immunity features of the NPA without
+violating its terms, which required that the Government "provide notice to Epstein before making
+... disclosure" of the NPA.88
+84 Exhibit 26.
+85 Exhibit 62; Exhibit 26; Exhibit 63 at 4-6, 18-19, 22-23.
+86 Id.
+87 Id.
+88 Id.
+25
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 26 of 57
+75.
+understanding of the Special Agent's explanation was that only the state
+portion of the Epstein investigation was being resolved, and that the federal investigation in
+which she was participating would continue. This understanding is consistent with the future
+communication she received."
+76. In addition to
+FBI agents talked to only two other victims out of the 34
+identified victims about the "general terms" of the NPA, including the provision providing a
+federal civil remedy to the victims.?
+77. After these meetings with three victims, Epstein's defense team complained. At that
+point, the U.S. Attorney's Office decided not to make any notifications about the NPA to any
+victim."
+78. Other than the three victims mentioned above, the United States did not inform any of
+the victims of anything about the status of the case or any plea discussions with Epstein,
+including even the existence of the NPA.!2
+79. On about November 27, 2007, AUSA
+sent an e-mail to Lefkowitz, (with a
+cc to U.S. Attorney Acosta) stating that the Office had a statutory obligation to notify the victims
+about Epstein's plea to state charges that was part of the NPA:
+The United States has a statutory obligation (Justice for All Act of 2004) to notify
+the victims of the anticipated upcoming events and their rights associated with the
+agreement entered into by the United States and Mr. Epstein in a timely fashion.
+Tomorrow will make one full week since you were formally notified of the
+selection. I must insist that the vetting process come to an end. Therefore, unless
+you provide me with a good faith objection to Judge Davis's selection [as special
+89 Exhibit 26; Exhibit 63 at 4-6, 18-19, 22-23, 28-29; [DE 58] (Exhibit 80) at 11.
+50 RFP MIA 000408 (Exhibit 81); Exhibit 64 at 4.
+91 Exhibit 64 at 5.
+92 Exhibit 62; Exhibit 65 at 57; Exhibit 64 at 4-5.
+26
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 27 of 57
+master for selecting legal counsel for victims pursuing claims against Epstein] by
+COB tomorrow, November 28, 2007, I will authorize the notification of the
+victims. Should you give me the go-head on [victim representative] ... selection
+›y COB tomorrow, I will simultaneously send you a draft of the letter. I intend to
+notify the victims by letter after COB Thursday, November 29th 9
+80. On November 28, 2007, the Government sent an email to Lefkowitz attaching a letter
+dated November 29, 2007 (the apparent date upon which it was intended to be mailed) and
+explained that "I am writing to inform you that the federal investigation of Jeffrey Epstein has
+been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement
+containing the following terms." The proposed letter then spelled out a number of the provisions
+in the NPA, including that because Epstein's plea to state charges was "part of the resolution of
+the federal investigation," the victims were "entitled to be present and to make a statement under
+oath at the state sentencing. "94
+81. On November 28, 2007, Lefkowitz sent an email to U.S. Attorney Acosta (with a copy
+to AUSA Sloman) objecting to victim notifications:
+We do, however, strongly and emphatically object to your sending a letter to the
+alleged victims. Finally, we disagree with your view that you are required to
+notify the alleged victims pursuant to the Justice for All Act of 2004....
+Furthermore, if a letter is to be sent to these individuals, we believe we should
+have a right to review and make objections to that submission prior to it being
+sent to any alleged victims... (It it should happen only after Mr. Epstein has
+entered his plea."
+82. The Government complied with such direction and failed to inform the victims of the
+NPA until after Epstein entered his plea. On November 29, 2007, Lefkowitz sent a letter to U.S.
+Attorney Acosta
+objecting to the proposed victim notification letter, stating that it is
+US_Atty_Cor. at 00255-00262 (Exhibit 82) (emphasis rearranged)
+* RFP WPB 000429 (Exhibit 83); RFP MIA 000011-000014 (Exhibit 84)
+95 Exhibit 26 (emphasis added).
+27
+
+
+Case 9:08-cV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 28 of 57
+inappropriate for any letter to be sent to the victims before Epstein entered his plea or had been
+sentenced. Lefkowitz also told the Government that the victims should not be invited to the state
+sentencing, that they should not be encouraged to contact law enforcement officials, and that
+encouraging the attorney representative to do anything other than get paid by Epstein to settle the
+cases was to encourage an ethical conflict.?
+83. On about November 30, 2007, U.S. Attorney Acosta sent a letter to one of Epstein's
+defense attorneys, Ken Starr, stating: "I am directing our prosecutors not to issue victim
+notification letters until this Friday at 5 p.m., to provide you with time to review these options
+with your client." The letter also explained that the line prosecutor had informed Acosta "that
+the victims were not told of the availability of Section 2255 relief during the investigation phase
+of this matter" despite the fact that the "[r]ule of law ... now requires this District to consider
+the victims' rights under this statute in negotiating this Agreement.*97
+84. Because of concerns from Epstein's attorneys, the U.S. Attorney's Office never sent
+the proposed victim notification letters discussed in previous paragraphs to the victims or
+anything discussing any of the NPA provisions.*
+85. On December 5, 2007, Starr sent a letter to U.S. Attorney Acosta (with copy to AUSA
+Sloman) asking about issuance of victim notification letters and stating: "While we believe that it
+is wholly inappropriate for your Office to send this letter under any circumstances, it is certainly
+inappropriate to issue this letter without affording us the right to review it. "99
+* RFP MIA 000007-000010 (Exhibit 85).
+97 RFP MIA 000501-507 (Exhibit 86).
+98 Exhibit 26; RFP MIA 000025-000037 (Exhibit 87).
+9 Exhibit 76.
+28
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 29 of 57
+86. On about December 6, 2007, Sloman sent a letter to Lefkowitz again recognizing the
+rights of the victims, and also recognizing that the victims had not yet been afforded any rights,
+despite the fact that the NPA was signed months earlier. The letter stated:
+[Ejach of the listed individuals are persons whom the Office identified as victims.
+LThe Oflice is prepared to indict Mr. Epstein based upon Mr. Epstein's
+"interactions' with these individuals. This conclusion is based upon a thorough
+and proper investigation - one in which none of the victims was informed of any
+right to receive damages of any amount prior to the investigation of her claim.
+[T]he Office can say, without hesitation, that the evidence demonstrates that each
+person on the list was a victim of Mr. Epstein's criminal behavior.
+Finally, let me address your objections to the draft Victim Notification Letter.
+You write that you don't understand the basis for the Office's belief that it is
+appropriate to notify the victims. Pursuant to the 'Justice for All Act of 2004,
+crime victims are entitled to: "The right to reasonable, accurate, and timely notice
+of any public court proceeding ... involving the crime' and the right not to be
+excluded from any such public court proceeding....' 18 U.S.C. § 3771(a)(2) &
+(3). Section 3771 also commands that 'employees of the Department of Justice..
+• engaged in the detection, investigation, or prosecution of crime shall make their
+best efforts to see that crime victims are notified of, and accorded, the rights
+described in subsection (a).' 18 U.S.C. § 3771(c)(1)....
+With respect to notification of the other information that we propose to disclose,
+the statute requires that we provide a victim with the earliest possible notice of:
+the status of the investigation, the filing of charges against a suspected offender,
+and the acceptance of a plea. 42 U.S.C. 10607(c)(3). Just as in 18 U.S.C. 3771,
+these sections are not limited to proceedings in a federal district court. Our Non-
+Prosecution Agreement resolves the federal investigation by allowing Mr. Epstein
+› plead to a state offense. Ine victms identfied through the federal investigatio
+hould be appropriately informed, and our Non-Prosecution Agreement does n
+require the U.S. Attorney's Office to forego its legal obligations.
+[The Office believes that it has proof beyond a reasonable doubt that each listed
+ndividual was a victim of Mr. Epstein's criminal conduct while the victim was
+minor. The law requires us to treat all victims "with fairness and with respect fo
+the victim's dignity and privacy." 18 U.S.C. 3771(a)(8). 1°*
+100 US_Atty_Cor. 190-193 (Exhibit 88) (emphasis added).
+29
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 30 of 57
+The letter included a footnote stating: "Unlike the State's investigation, the federal investigation
+shows criminal conduct by Mr. Epstein at least as early as 2001, so all of the victims were
+minors at the time of the offense."l01
+87. On December 7, 2007, defense attorney Lilly Ann Sanchez sent a letter to AUSA
+Sloman, requesting "that the Office hold off on sending any victim notification letters." The
+Government complied. '2
+88. While discussing with defense counsel changes in the October 2007 Addendum and in
+a December 19, 2007 letter from the U.S. Attorney to Attorney Lilly Ann Sanchez, the U.S.
+Attorney's Office did not confer with any of the victims about these modifications to the NPA.
+89. On December 13, 2007, the line prosecutor sent a letter to Lefkowitz confirming that
+the Government had earlier stopped making victim notifications because of objections from
+Epstein's criminal defense counsel: "You raised objections to any victim notification, and no
+further notifications were done."103 The December 13, 2007 letter reveals it would have been
+possible to confer with victims about the NPA. The U.S. Attorney's Office was able to confer
+constantly with Epstein's counsel about the parameters of the NPA, but intentionally declined to
+confer with Epstein's victims about the Agreement. '4
+90. On December 19, 2007, U.S. Attorney Acosta sent a letter to Lilly Ann Sanchez
+stating, "I understand that the defense objects to the victims being given notice of time and place
+of Mr. Epstein's state court sentencing hearing. We intend to provide victims with notice of the
+101 RFP WPB 000620 (Exhibit 89).
+102 RFP WPB 001557 (Exhibit 90).
+103 Exhibit 24; Exhibit 69; RFP MIA 00469 (Exhibit 91).
+104 Id.
+30
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 31 of 57
+federal resolution, as required by law. We will defer to the discretion of the State Attorney
+regarding whether he wishes to provide victims with notices of the state proceedings. S
+91. In about early January 2008, as the result of pressure from Epstein's attorneys, Acosta
+agreed with Epstein's attorneys "that there were significant irregularities with the deferred
+prosecution agreement" and "called a time-out." At that time, Acosta asked the Child
+Exploitation and Obscenity Section of the Justice Department's Criminal Division, located in
+Washington, D.C., to look at the case. '06
+CONCEALING THE NPA WHILE EPSTEIN SOUGHT REVIEW
+92. Following the entry of the "time out," any requirement that Epstein carry out his
+obligations under the NPA was delayed while he sought higher level review within the Justice
+Department. During this review, the victims were not told about the existence of the NPA. 1°7
+93. On January 10, 2008,
+received victim notification letters
+from the FBI advising them that "[t]his case is currently under investigation. This can be a
+lengthy process and we request your continued patience while we conduct a thorough
+investigation." 08
+94. The January 10, 2008, notification letter did not disclose that the federal cases in the
+Southern District of Florida involving
+were the subject of the NPA
+105
+US_Atty_Cor. 00272-00273 (Exhibit 92); RFP MIA 000038-000040 (Exhibit 93); RFP MIA 00041-00047
+(Exhibit 94); RFP MIA 000048-000052 (Exhibit 95).
+106 Exhibit 91 (email from Lefkowitz to Acosta, dated February 29, 2008, and noting that it had been nearly two
+months since the "time out" agreement).
+107 Exhibit 26; Exhibit 27; RFP WPB 001616-001623 (Exhibit 96); Exhibit 63 at 4-5, 18-19, 22-29.
+10B January 10, 2008 Victim Notification Letter to
+(Exhibit 97) (emphasis added); January 10, 2008
+Victim Notification Letter to
+(Exhibit 98).
+31
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 32 of 57
+entered into by Epstein and the U.S. Attorney's Office discussed previously, or that there had
+been any potentially binding resolution. 09
+95. On about January 10, 2008, other victims similarly-situated to
+received letters identical in substance to those described in the immediately preceding
+paragraphs.'°
+96. In early 2008,
+believed that criminal prosecution of
+Epstein was extremely important. They also desired to be consulted by the FBI or other
+representatives of the Federal Government about the prosecution of Epstein. In light of the
+letters that they had received around January 10, 2008, they reasonably believed, as was
+obviously intended by the letters, that a federal criminal investigation of Epstein was on-going
+including investigation into Epstein's crimes against them. They also reasonably believed that
+they would be contacted by and have an opportunity to confer with federal prosecutors before the
+Federal Government reached any final resolution of that investigation.'"'
+97. On January 31, 2008,
+met with FBI Agents and AUSA's from the U.S.
+Attorney's Office. She provided additional details of Epstein's sexual abuse of her. The
+AUSA's did not disclose to
+at this meeting that they had already negotiated a NPA
+with Epstein. 2
+98. On March 19, 2008, the line prosecutor sent a lengthy email to a prospective pro bono
+attorney for one of Epstein's victims who had been subpoenaed to appear at a deposition. The
+109 Id
+11° Exhibit 63 at 4-5, 18-19, 22-29.
+''' Exhibit 63 at 4-6, 18-19, 22-23, 28-29; Exhibit 26; Exhibit 27.
+112 Exhibit 33.
+32
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 33 of 57
+email listed the attorneys representing Epstein, the targets of the investigation, and recounted in
+detail the investigation that had been conducted to that point. The email did not reveal the fact
+that Epstein had signed the NPA in September 2007.''3
+99. On May 30, 2008
+(another client of the undersigned), who was recognized
+as an Epstein victim by the U.S. Attorney's Office, received a letter from the FBI advising her
+that "It]his case is currently under investigation. This can be a lengthy process and we request
+your continued patience while we conduct a thorough investigation."II4 The statement in the
+notification letter was misleading. The letter did not disclose the NPA already entered into by
+Epstein and the Office, and instead implied that the Office was still investigating Epstein and had
+not decided how to proceed with the case, neither of which was accurate.''5
+100. The May 30, 2008, victim letter to
+also acknowledged the victims' rights
+under the CVRA at the same time as the Office was not disclosing the NPA's existence t
+and the other victims. '6
+101. In mid-June 2008, Mr. Edwards contacted the line AUSA handling the case to inform
+her that he represented
+Mr. Edwards asked to meet to provide
+information about the federal crimes committed by Epstein against these victims, hoping to
+secure a significant federal indictment against Epstein, consistent with his clients' desires. The
+line prosecutor and Mr. Edwards discussed the possibility of federal charges being filed in the
+113 Exhibit 40.
+114 Exhibit 29.
+1'5 Id.
+116 Exhibit 28; Exhibit 62.
+33
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 34 of 57
+future. Mr. Edwards was lead to believe federal charges could still be filed, with no mention
+whatsoever of the existence of the NPA or any other possible resolution to the case. ''?
+102. At the end of the call, the line prosecutor asked Mr. Edwards to send any information
+that he wanted considered by the Office in determining whether to file federal charges. Because
+of the confidentiality provision that existed in the plea agreement, the line prosecutor did not
+inform Mr. Edwards that months earlier, in September 2007, the Office had reached an
+agreement not to file federal charges. The line prosecutor also did not inform Mr. Edwards that
+resolution of the criminal matter was imminent. '8
+103. On June 19, 2008, Mr. Edwards sent an email to the line prosecutor requesting to
+meet in person to confer with the Government regarding the status of his clients' case.'!
+104. Because the line prosecutor did not tell Mr. Edwards about the NPA, Mr. Edwards
+was not able to confer with the prosecutor about the NPA on behalf of his clients. Mr. Edwards,
+however, made it perfectly clear that his clients wanted to confer with the prosecutor before any
+resolution was reached. Epstein was aware of this continued concealment of the NPA from the
+victims and, indeed, sought this concealment. '20
+105. On June 23, 2008, the line prosecutor sent an email to Lefkowitz stating that the
+Deputy Attorney General had completed his review of the Epstein matter and "determined that
+federal prosecution of Mr. Epstein's case [wa]s appropriate. Accordingly, Mr. Epstein ha[d] until
+11? Exhibit 63 at 4-6, 18-19, 22-23, 28-29; Exhibit 64 at 5-6.
+118 Id.; US_Atty_Cor. 0321 (Exhibit 99).
+119 RFP WPB 001894 (Exhibit 100).
+120 Exhibit 63 at 4-6, 18-19, 22-23, 28-29; Exhibit 64 at 5-6; Exhibit 99.
+34
+
+
+Case 9:08-cV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 35 of 57
+the close of business on Monday, June 30, 2008, to comply with the terms and conditions of the
+agreement between the United States and Mr. Epstein."121
+EPSTEIN'S ENTRY OF HIS GUILTY PLEA
+106. On and before June 30, 2008, the Government and Epstein's attorneys corresponded
+extensively (often multiple times on any given day) regarding Epstein's entry of his guilty plea.
+Throughout the course of these communications, the Government and Epstein operated on the
+agreement that the victims would not be told about the NPA, much less about the fact that
+Epstein's plea was a triggering event for the federal case being resolved.!?
+107. On about June 27, 2008, the U.S. Attorney's Office called Mr. Edwards to provide
+notice to his clients regarding the impending Monday morning hearing. The notice, however,
+was only that Epstein was pleading guilty to state solicitation of prostitution charges involving
+other victims—not Mr. Edwards' clients nor any of the federally-identified victims. The U.S.
+Attorney's Office did not tell Mr. Edwards that the guilty pleas in state court would bring an end
+to the possibility of federal prosecution pursuant to the plea agreement.?3
+108. In fact, the U.S. Attorney's Office did not disclose to Edwards the fact that the guilty
+pleas in state court had any bearing on the cases of
+As a result,
+Hid not attend the plea hearing.!24
+121 Exhibit 40.
+122 Exhibit 26; Exhibit 27; Exhibit 62; Exhibit 63 at 4-6, 18-19, 22-23; Exhibit 99; RFP WPB 000512-000513
+12 Exhibit 26, Exhibi 27, Exe 62, 22 Es at 4-0,18. 97, 2-123; Exhibi 9; Exhibit 101; Declaration of Brad
+Edwards (Exhibit 102).
+35
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 36 of 57
+109. Had they known that the plea agreement in state court made it impossible to prosecute
+Epstein federally for his crimes against them, they would have objected to this resolution and
+would have certainly attended the hearing.'?s
+110. On or before June 30, 2008, the Office prepared a draft victim notification to be sent
+to the victims—a letter that it intended to show to both Epstein and Jack Goldberger, as reflected
+by a place for the initials of both Epstein and Goldberger on the document. The notification was
+designed to inform the victims of the provisions of deferral of federal prosecution in favor of
+state charges. The notification letter began by describing Epstein's guilty plea in the past tense:
+"On June 30, 2008, Jeffrey Epstein ... entered a plea of guilty to violations of Florida statutes
+forbidding the solicitation of minors to engage in prostitution and felony solicitation of
+prostitution." Later, a substantively identical letter was prepared for Epstein's and Guy Lewis'
+review. '26
+I11. On June 30, 2008, the Office sent an e-mail to Goldberger reflecting continuing
+efforts to keep the NPA secret: "Jack: The FBI has received several calls regarding the Non-
+Prosecution Agreement. I do not know whether the title of the document was disclosed when the
+Agreement was filed under seal, but the FBI and our office are declining comment if asked. *127
+112. On June 30, 2008, Epstein plead guilty to state law solicitation of prostitution charges.
+Because the Federal Government failed to notify the victims about the NPA or its arrangements
+with Epstein, neither
+nor any of the identified victims in the
+125 Exhibit 26; Exhibit 27; Exhibit 63 at 4-6, 18-19, 22-23; Exhibit 99; Exhibit 101; Exhibit 102.
+126 US_Atty_Cor. 00323 (Exhibit 103); RFP WPB 000515-000520 (Exhibit 104).
+127 Exhibit 99.
+36
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 37 of 57
+federal case were aware of the ramifications of the state proceeding (either in person or through
+counsel). 28
+113. Immediately following the June 30, 2008 hearing, the line prosecutor told one of the
+victims' attorneys that Epstein had "plead guilty today in state court."29
+114. On June 30, 2008, based on what she had been told by the Government,
+thought that the Office was still investigating and pursuing her case. She did not receive notice
+that Epstein's state guilty plea affected her rights in any way. If she had been told that the state
+plea had some connection to blocking the prosecution of her case, she would have attended and
+tried to object to the judge to prevent that plea from going forward. '30
+115. On June 30, 2008, based on what she and her attorneys had been told by the
+Government.
+hought that the Government was still investigating her case. If she had
+been told that the state plea had some connection to blocking the prosecution of her case, she
+would have tried to confer with the prosecutors about it and tried to get charges filed. She
+wanted to be treated fairly in the process.!3!
+116. From September 24, 2007, the date that the NPA was signed, through at least the state
+court plea on June 30, 2008
+—a period of more than nine months—-the Office did not notify any
+of Epstein's victims about the existence of the NPA. 132
+128 Exhibit 26; Exhibit 27; Exhibit 63 at 4-6, 18-19, 22-23; Exhibit 64 at 6; 000001-000002 (Exhibit 105).
+129 RFP WPB 001861 (Exhibit 106).
+130 Exhibit 26; Exhibit 63 at 4-6, 18-19, 22-23.
+131 Exhibit 27; Exhibit 63 at 4-6, 18-19, 22-23; Exhibit 105.
+132 Exhibit 62; Exhibit 63 at 4-6, 18-19, 22-23, 28-29; Exhibit 64 at 4; US_Atty_Cor. 00267-00271 (Exhibit 107).
+37
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 38 of 57
+117. On July 1, 2008, the day following Epstein's plea, the line prosecutor emailed the
+Assistant State Attorney a copy of the NPA for "filing with the Court under seal" demonstrating
+that the agreement continued to be withheld from the victims. '33
+118. On July 3, 2008, as specifically directed by the U.S. Attorney's Office, Mr. Edwards
+sent a letter to the Office communicating the wishes off
+that federal charges be filed against Epstein: "We urge the Attorney General and our United
+States Attorney to consider the fundamental import of the vigorous enforcement of our Federal
+laws. We urge you to move forward with the traditional indictments and criminal prosecution
+commensurate with the crimes Mr. Epstein has committed, and we further urge you to take the
+steps necessary to protect our children from this very dangerous sexual predator."134
+119. When Mr. Edwards wrote his July 3, 2008 letter, he was still unaware that a NPA had
+been reached with Epstein and that there was any federal resolution of the case—-facts that the
+Office continued to conceal, at the request of Epstein, not only from Edwards but also as his
+clients and other victims. '33
+120. On July 7, 2008, the line prosecutor again conferred with Epstein's counsel seeking
+permission to begin distributing the notification letters to the victims, acknowledging her failure
+to include one victim who was still a minor in 2008.136
+121. Mr. Edwards first saw a reference to the NPA on or after July 9, 2008, when the
+Government filed its responsive pleading to |
+emergency petition. That pleading was
+133 RFP WPB 001857 (Exhibit 108).
+134 Exhibit 105.
+135 Exhibit 63 at 4-6, 18-19, 22-23, 28-29; Exhibit 99; RFP WPB 001855 (Exhibit 109); [DE 48] (Exhibit 110) at
+18-19.
+136 RFP WPB 001854 (Exhibit 111).
+38
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 39 of 57
+the first public mention of the NPA and the first disclosure to Mr. Edwards-and thus to
+-of the possible existence of a NPA. '37
+122. Mr. Edwards detrimentally relied on the misleading representations made by the
+Office that the case was still under investigation when he was writing his July 3, 2008 letter. He
+would not have wasted his time undertaking a pointless exercise had he known that the U.S.
+Attorney's Office had previously negotiated a NPA, and he would have informed his clients
+about the agreement. '38
+A MOTIVE TO CONCEAL THE NPA FROM THE VICTIMS
+123. The U.S. Attorney's Office-pushed by Epstein—wanted the NPA kept from public
+view because of the strong objection it would have faced from victims of Epstein's abuse, and
+because of the public criticism that would have resulted from allowing a politically-connected
+billionaire who had sexually abused more than 30 minor girls to escape from federal prosecution
+with only a county court jail sentence. 39
+124. When deciding whether to notify the victims before Epstein entered his guilty plea,
+the Office was aware that a state court judge would have to review the plea and determine
+whether it was in the public interest, and accordingly chose not to "highlight" certain potentially
+objectionable features. 140
+137 Exhibit 62; Exhibit 63 at 4-6, 18-19, 22-23, 28-29; Exhibit 99; Exhibit 110 at 18-19.
+138 See Exhibit 28; Exhibit 102; Exhibit 105.
+13º Exhibit 26; Exhibit 27; Exhibit 62; Exhibit 63 at 4-6, 18-19, 22-23; Exhibit 99; Exhibit 101; Exhibit 102; Exhibit
+57 (urging Government to try and keep agreement from becoming public); Exhibit 7 (explaining Goverment's
+desire not to "highlight" possible charges or defendants being immunized).
+39
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 40 of 57
+125 Concealing the NPA from the victims prevented them from using their right to confer
+with the Government about why the NPA was not desirable or appearing at Epstein's plea and
+sentencing hearing to raise their concerns with the Court. 41
+THE VICTIMS' UNSUCCESSFUL ATTEMPTS TO ENFORCE THEIR RIGHTS
+126. On July 7, 2008,
+under the CVRA. At the time
+filed an emergency petition for enforcement of her rights
+was not aware of the NPA, so she sought a court order
+directing the Government to confer with her before reaching any such agreement. Epstein
+quickly became aware of this petition. 42
+127. On July 8, 2008, the line prosecutor sent a letter to Epstein's counsel stating that
+victims would be informed about the civil compensation provision of the NPA the next day:
+In accordance with the terms of the Non-Prosecution Agreement, on June 30,
+2008, the United States Attorney's Office provided you with a list of thirty-one
+individuals "whom it was prepared to name in an Indictment as victims of an
+enumerated offense by Mr. Epstein."
+... In deference to your vacation, we
+allowed you a week to provide us with any objections or requested modifications
+of the list and/or the Notification language. Yesterday, I contacted you via
+telephone and e-mail, but received no response. Accordingly, the United States
+hereby notifies you that it will distribute the victim notifications tomorrow, July 9,*
+2008, to each of the thirty-two identified victims, either directly or via their
+counsel. '43
+128. On July 9, 2008, Jack Goldberger sent a letter to the line prosecutor raising concerns
+about the notifications, and suggesting modifications to the notification letter. Epstein's counsel
+also objected to the victim notification letters containing certain information about the NPA. 144
+141 18 U.S.C. § 3771; Exhibit 26; see also Exhibit 62.
+142 [DE 1] (Exhibit 112) at 1-2.
+143 Exhibit 101.
+11 RFP WPB 000524-000525 (Exhibit 113).
+40
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 41 of 57
+129. Later on July 9, 2008, the line prosecutor sent a response back to Goldberger,
+explaining how she intended to keep the victims from having access to the terms of the NPA:
+Without such an express Acknowledgment by Mr. Epstein that the notice contains
+the substance of that Agreement, I believe that the victims will have justification
+to petition for the entire agreement, which is contrary to the confidentiality claus
+that the parties have signed. '45
+130. On July 9, 2008, the U.S. Attorney's Office sent victim notification letters to
+via their attorney, Mr. Edwards, and to other identified victims of Epstein.
+That notification contained a written explanation of some of the civil compensation provisions of
+the NPA. The notification did not provide the full terms of the NPA. For example, the
+notification did not disclose the NPA or the immunity for "other potential co-conspirators" of
+Epstein. 45
+131. On July 10, 2008, Epstein's counsel continued to protest victim notification as
+evidenced by Goldberger's email to the line prosecutor stating, "we respectfully request a
+reasonable opportunity to review and comment on a draft of the modified notification letter you
+intend to mail before you send it."147
+132. On July I1, 2008, the Court held a hearing on
+petition and, with the
+stipulation of the Government, added
+as a petitioner because she was a recognized
+crime "victim." The Court unsealed a declaration that the line prosecutor had filed in response to
+the petition, and because the declaration contained one paragraph of the NPA, that paragraph
+145 RFP WPB 000526-000527 (Exhibit 114).
+Hº 000777-000779 (Exhibit 115); 000774-000776 (Exhibit 116).
+147 RFP WPB 000535-000537 (Exhibit 117).
+41
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 42 of 57
+became unsealed. The line prosecutor sent an email to Goldberger informing him of the
+unsealing of that one paragraph. 148
+133. During the July 11, 2008 hearing, the Government conceded that the NPA had been
+concluded months before the victims were notified about it. !49
+134. Throughout July 2008, Epstein's attorneys and the Government continued to
+correspond about issues such as subpoenas related to his computers and returning of his
+property. '50
+135. On August 7, 2008, the line prosecutor emailed one of Epstein's defense attorneys,
+Roy Black, notice of the motion to disclose the NPA to the victims and assured him that the
+Government intended "to oppose the motion based upon the confidentiality provision."!51
+136. On August 10, 2008,
+¡led a motion seeking release of the
+NPA. '52
+137. Immediately after the motion was filed, the Office coordinated with another Epstein
+attorney about how to best object to the motion.!53
+138. On August 11, 2008, Roy Black wrote back to the line prosecutor, thanking the
+Government for "agreeing to oppose any disclosure of the 9/24/07 agreement."I54
+145 RFP WPB 001845 (Exhibit 118).
+149 See Exhibit 63 at 12 ("... the agreement was consummated by the parties in December of 2007."); see also
+
+150 RFP WPB 000470-000471 (Exhibit 119); RFP WPB 000481-000489 (Exhibit 120); RFP WPB 000547 (Exhibit
+121).
+151 [DE 19] (Exhibit 122); RFP WPB 001825 (Exhibit 123).
+152 Exhibit 122.
+153 RFP WPB 001820-001838 (Exhibit 124).
+154 RFP WPB 001819 (Exhibit 125).
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 43 of 57
+139. Between August 11 and 14, 2008, the line prosecutor attempted to obtain a copy of
+the NPA that Epstein's counsel had filed in state court.!s After receiving a copy, on August 14,
+2008, the line prosecutor wrote to Lefkowitz: "I can no longer argue that the Court shouldn't
+force us to produce the agreement because we have already provided the victims with the
+relevant portion when I now understand from you that I have NOT provided them with the
+relevant portion."156
+140. Further communications ensued between the line prosecutor and Epstein's counsel
+about what exactly was contained in the NPA—specifically, whether a December modification
+to the agreement was part of the NPA. The notification to the victims about the civil restitution
+provisions had quoted from the December language. 'ST
+141. On August 14, 2008, the line prosecutor emailed Epstein's counsel stating that the
+court has "ordered us to make the Agreement available to the plaintiffs. "158
+142. On August 15, 2008, the line prosecutor sent a letter to Epstein's counsel confirming
+that recent correspondence was intended "solely to determine what Mr. Epstein considered to be
+the terms of the Non-Prosecution Agreement" so that the Government would know exactly what
+needed to be produced to the victims in this CVRA case. '59
+143. On August 18, 2008, Lefkowitz wrote the line prosecutor that Epstein objected to
+disclosure of the terms of the NPA, but that Epstein would "cooperate with the government to
+reach an agreement as to substance of the notification to be sent to the government's list of
+155 RFP WPB 001809-001818 (Exhibit 126).
+156 RFP WPB 001804 (Exhibit 127).
+157 RFP WPB 001805-001808 (Exhibit 128).
+158 RFP WPB 001798 (Exhibit 129).
+159 Exhibit 68; RFP WPB 000575-000576 (Exhibit 130).
+43
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 44 of 57
+individuals. Based on the Agreement, the information contained in the notification should be
+limited to (1) the language provided in the Agreement dealing with civil restitution (paragraphs
+7-10) and (2) the contact information of the selected attorney representative. We object to the
+inclusion of additional information about the investigation of Mr. Epstein, the terms of the
+Agreement other than paragraphs 7-10 and the identity of other identified individuals." 160
+144. On August 21, 2008, the Government sent a letter to Epstein's counsel stating that,
+"[cJopies of the victim notifications will continue to be provided to counsel for Mr. Epstein."
+The letter further requested substantive objections to the draft notification letters, which were
+being re-sent "[bjecause I previously provided the victims with incorrect information —albeit
+with the approval of Mr. Epstein's counsel—it is imperative that I correct the error promptly. *161
+145. On August 26, 2008, the Government sent another letter to Epstein's counsel stating,
+"Mr. Goldberger and Mr. Tein explicitly approved the language in my earlier victim notification
+letter, even though they apparently were taking the position that the December 19, 2007 letter
+was not part of the Agreement, so that misinformation was provided to the victims with the
+approval of Mr. Epstein's attorneys."|62
+146.
+were not informed of the contents of the NPA until
+August 28, 2008, when the line prosecutor provided a copy to Mr. Edwards, 163
+147. On September 2, 2008, nearly a year after the NPA was signed, the line prosecutor
+sent an email to Epstein's counsel stating, "I will start sending out the victim notifications today.
+160 RFP WPB 000581-000583 (Exhibit 131).
+I51 RFP WPB 000587-000588 (Exhibit 132).
+162 RFP WPB 000603-000604 (Exhibit 133) (emphasis in original).
+163 RFP WPB 001776 (Exhibit 134).
+44
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 45 of 57
+In accordance with your request, I have changed the language regarding the victims' right to
+receive a copy of the Agreement."64
+148. On September 2 and 3, 2008, the U.S. Attorney's Office sent to
+nd other
+identified victims amended notification letters correcting the earlier inaccurate information about
+the civil compensation provisions contained in the earlier notifications. 165
+149. The victim notification letters that the victims received were confusing. They did not
+directly state that Epstein's crimes against them were not going to be prosecuted, but instead said
+that "the United States has agreed to defer federal prosecution in favor of this state prosecution."
+The letter did not inform the victims of how this applied to them. 166
+150. The victim notification letters also state that there was "litigation between the United
+States and two other victims regarding the disclosure of the entire agreement between the United
+States and Mr. Epstein." The letters did not explain that the remedy being sought in the litigation
+was not just to get "disclosure" of the agreement, but instead to uphold the rights of Epstein's
+victims. 167
+151. On September 16, 2008, the Palm Beach Daily News wrote the State Attorney's
+Office that it had "recently discovered" the NPA and wanted to know what was in it. The State
+Attorney's Office wrote the line prosecutor inquiring how to respond. 168
+152. On September 16, 2008, attorney Jeffrey Herman, who represented several Epstein
+victims, wrote to the line prosecutor to strenuously object to the restitution procedures
+164 RFP WPB 001775 (Exhibit 135).
+165 September 3, 2008 Victim Notification Letter tol
+i ld.; Exhibit 26; Exhibit 27.
+167 Id.
+168 002343-002344 (Exhibit 137).
+Exhibit 136); Exhibit 2; Exhibit 94 at 2-3.
+45
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 46 of 57
+established in the NPA after learning that another attorney established through the NPA would
+be making unsolicited contacts to the victims. Mr. Herman explained that the notification letters
+were "misleading" because they referred generally to a waiver of "any other claim for damages"
+without informing them that this waiver might include a valuable punitive damages claim against
+an alleged billionaire. 169
+153. On September 17, 2008, the line prosecutor sent an email to State Attorney
+explaining that the NPA "contain[ed] a confidentiality provision that require[ed] us to
+inform Mr. Epstein's counsel before making any disclosure."|70
+154. On September 18, 2008, attorney Katherine Ezell representing some of Epstein's
+victims emailed the line prosecutor, asking whether the NPA was "blessed" by Judge Marra.
+The line prosecutor emailed back: "As far as I know, Judge Marra has not ever seen the
+agreement or these notification letters.... I don't know if the sentencing judge ever reviewed it.
+The letters were reviewed by my office and Jay Lefkowitz and Roy Black before they went
+out. *171
+155. In 2010,
+net with the new U.S. Attorney, Wilfredo Ferrer. She explained
+to him how the NPA had been concealed from her. Nothing ever came of the meeting, and Mr.
+Ferrer has continued to fight efforts byl
+and other victims to have the court declare
+that their rights were violated while the NPA was drafted and implemented.'?2
+169 Jd.
+170 RFP WPB 001773 (Exhibit 138).
+171 RFP WPB 001763 (Exhibit 139).
+172 Exhibit 26; Tr. Nov. 23, 2015 (Exhibit 140) at 3-5 (U.S. Attorney's Office argues that the victims are "complicit"
+in their own sexual abuse and therefore cannot receive any remedy under the CVRA).
+46
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 47 of 57
+156. At all times material to this statement of facts, it would have been practical and
+feasible for the federal government to inform
+Ms.
+and all other similarly-situated victims of the details of the proposed NPA with Epstein,
+including in particular the fact that the agreement barred any federal criminal prosecution of
+crimes that Epstein committed against them.'
+157. At no time while it negotiated and executed the NPA did the Government notify the
+victims that Epstein's guilty plea would prevent his prosecutions for crimes against them. Nor
+did the Government ever allow the identified victims to "confer with the prosecutor on the case,"
+18 U.S.C. § 3771(a)(5), or "treat them with fairness, respect and dignity" by making them aware
+of the NPA, § 3771(a)(8). In fact, to the contrary, the Government went to great lengths to
+conceal the fact that there was a federal resolution at all and mislead the victims into believing
+that the federal case was proceeding so that the NPA could be secretly put in place before the
+victims knew what was going on.!?
+MOTION FOR SUMMARY JUDGMENT AND
+INCORPORATED MEMORANDUM OF LAW
+In light of the foregoing undisputed material facts, summary judgment for the victims on
+the issue of whether their CVRA rights were violated is appropriate. The Court is well aware of
+the applicable summary judgment standard, which requires that there be no disputed issues that
+are genuine or material for the moving party to be entitled to judgment as a matter of law. See,
+e.g., Joseph |. Napolitano, 839 F. Supp. 2d 1324, 1333 (S.D. Fla. 2012). The undisputed facts
+173 See Exhibit 88.
+174 Exhibit 26; Exhibit 27; Exhibit 62; Exhibit 63 at 4-6, 18-19, 22-23; Exhibit 99; Exhibit 101; Exhibit 102; Exhibit
+57; Exhibit 7.
+47
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 48 of 57
+here plainly establish that the Government-with the knowledge of, and at the urging of
+Epstein—violated the CVRA rights of'
+and other similarly-situated
+victims, by deliberately concealing from them the NPA barring the prosecution of Jeffrey
+Epstein and his co-conspirators for the federal offenses they committed against them. In
+particular, the Government violated the victims' right to confer with prosecutors, right to
+accurate notice of court hearings, and right to be treated with fairness. 18 U.S.C. § 3771(a)(5),
+(2), & (8).
+A. The Government Violated the Victims' Right to Confer.
+There can be no real debate that the Government violated the victims' right to confer.
+Indeed, it is worth recalling that in earlier proceedings, the victims filed a similar (although less
+detailed) motion for summary judgment. DE 48. The Government responded not by claiming
+that it had in fact conferred with the victims, but rather by advancing the legal argument that the
+CVRA does not extend any rights to victims before the filing of an indictment. DE 62. This
+argument was flatly contradicted by the Government's own earlier decision to provide
+notification to victims after the NPA was signed - and even during the investigation treating
+them as victims. See, e.g., 11 10-16, 34-35, 69-73, 91-94, 98, 125, supra. In any event, this
+Court has now firmly rejected the Government's contrived legal position. DE 99 (the court has
+determined "that as a matter of law the CVRA can apply before formal charges are filed")!?5
+175 Not only has this Court rejected the Government's position, but Congress and the President have specifically
+decided to end any debate and to codify this Court's ruling into federal law. See 18 U.S.C. § 3771(a)(9) (victims
+have the "right to be informed in a timely manner of any plea bargain or deferred prosecution agreement") (added as
+part of Pub. L. 114-22, Title I, § 113(a), (c)(1) (May 29, 2015)). This codification builds on the fact that Senator
+Kyl, the Senate co-sponsor of the CVRA, took to the Senate floor to directly express his approval of this Court's
+ruling. 157 Cong. Rec. S7060-01 (statement of Senator Kyl) (Nov. 2, 2011) (applauding this Court's decision and
+48
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 49 of 57
+The Government's inability to demonstrate that it afforded victims their right to confer is
+unsurprising. Under the CVRA, identified crime victims are granted "the reasonable right to
+confer with the attorney for the Government in the case." 18 U.S.C. § 3771(a)(5). In some
+cases, there might be a debate about how much conferring is "reasonable" for the prosecutor to
+undertake. But here, no such debate is possible for the simple reason that the Government
+simply concealed that it was planning to enter into an agreement blocking the federal prosecution
+of Epstein from more than 30 of Epstein's identified victims. See, e.g., 11 17, 32-33, 38, 41, 44-
+46, 66, 71-72, 87-88, 95, 102, 113, 123, supra.
+Whatever other rights the CVRA extends to crime victims, it surely extends the simple
+right to know when the Government is entering into a deal with a sex offender blocking his
+prosecution for crimes committed against them. See, e.g., 1 155, supra. Here, the Government
+violated the victims right to confer during at least three separate time periods: (1) on and before
+September 24, 2007, when the Government was negotiating and signing the NPA; (2) in and
+around January 2008, when it sent letters telling the victims not about the previously signed
+NPA, but rather counseling "patience" while the Government finished its "investigation;" and (3)
+in and around June 30, 2008, when the Government didn't tell the victims that the state plea
+would effectively extinguish their rights to ever see Epstein prosecuted. See 919 17, 32-33, 38,
+41, 44-46, 66, 71-72, 87-88, 95, 102, 113, 123, supra.
+noting its "careful] review" of the issues).
+49
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 50 of 57
+Simply put, the NPA barred prosecution of the federal sexual offenses that Epstein had
+committed against Jane Doe 1, Jane Doe 2, and other similarly-situated victims. Under the
+CVRA, the victims were entitled to confer about this disposition and attempt to persuade
+prosecutors to reach a different result. Recognizing a right to confer about such dispositions is
+"not an infringement ... on the government's independent prosecutorial discretion; instead, it is
+only a requirement that the government confer in some reasonable way with the victims before
+ultimately exercising its broad discretion." In re Dean, 527 F.3d 391, 395 (5"' Cir. 2008)
+(internal citations omitted) (emphasis added).
+The victims fully understand that if they had conferred with the Government, the
+prosecutors could possibly have ultimately reached the same kind of agreement. But there is
+good reason to believe that if the prosecutors had exposed their dealings to scrutiny by
+and the other victims, they would not have reached such a sweetheart plea deal.
+See 11 121-23, supra. For example, despite the fact that this case has been in litigation for more
+than seven years spanning several hundred pleadings, the Government does not write even a
+single sentence explaining why it entered into an NPA with a sex offender who had committed
+hundreds of federal sex offenses against young girls. Perhaps there is some reason for this
+extraordinary leniency. But if so, the Government has yet to offer it. In any event, regardless of
+the ultimate consequences of conferring, Congress promised to all crime victims—-including
+and other similarly-situated victims-that they would be able to confer with
+prosecutors before a disposition was reached in their case. 18 U.S.C. § 3771(a)(5). The victims
+never received that congressionally-mandated opportunity.
+50
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 51 of 57
+In sum, the Government repeatedly violated the victims' CVRA right to confer - and
+did so at the specific request of Jeffrey Epstein. Summary judgment is thus appropriate on this
+basis.
+B.
+The Government Violated the Victims' Right to Be Treated With Fairness.
+The Government also violated the victims' "right to be treated with fairness and with
+respect for the victim's dignity and privacy." 18 U.S.C. § 3771(a)(8). Entirely apart from
+whether the victims had any right to confer with prosecutors, at a bare minimum they had a right
+to be treated fairly and not be deceived by the Government. Yet here the Government repeatedly
+and deliberately misled the victims about what was happening in their case, concealing from
+them the NPA's negotiation and all of the terms it ultimately contained. As with the violation of
+the right to confer, these violations occurred at multiple points in the process, including the time
+before the NPA was signed, after the NPA was signed, and when Epstein was entering his State
+court guilty plea.
+A clear-cut example of the Government's violating the victims right to be treated fairly is
+its remarkable decision in 2008, well after the NPA had been signed, to send the victims (and, in
+some cases, their attorneys) deceptive information that the case "is currently under investigation"
+and that "It]his can be a lengthy process and we request your continued patience while we
+conduct a thorough investigation." See 11 91-103, supra. When the Government finally did
+inform the victims about what had happened, the notifications were not only incomplete and
+inaccurate, but they also arrived too late for the victims to do anything about the deal.
+Specifically, it was too late to confer with the prosecutor or attend the sentencing hearing. See 11l
+124-48, supra. Most important, the notifications did not inform the victims that a NPA had been
+51
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 52 of 57
+signed with Epstein, preventing federal prosecution in the Southern District of Florida (and thus,
+as a practical matter, any prosecution for most of the victims) for the crimes he and his coconspirators had committed against them. The notification letters also described this litigation as
+"the disclosure" of the NPA, rather than its true purpose of vindicating the victims' rights and
+securing for the victims a right to confer about prosecuting Epstein free from the backdrop of the
+NPA. See 191 145-48, supra.
+The foregoing facts provide numerous other examples of the victims not being treated
+fairly. These examples include, but are not limited to:
+• Secretly discussing with Epstein's defense counsel contrived charges to avoid making
+victim notifications (19 17-22, supra);
+• Secretly discussing with Epstein's defense counsel arranging a guilty plea in a
+jurisdiction located some distance from the victims to make it hard for them to find out
+what was happening (1 23, supra);
+• Secretly reaching a resolution of the case that would make it hard for a judge to see what
+was going on (1| 25, supra);
+• Not telling the victims the NPA was under consideration (f9 41-47, supra);
+• Deviating from standard policy by negotiating with defense counsel about the extent and
+substance of crime victim notifications (1 49, supra);
+• Negotiating with defense counsel about concealing the agreement (19 48-58, supra);
+• Working to have agents attend Epstein's sentencing hearing "incognito" without telling
+the victims what was happening (1 58, supra);
+• Making a commitment to Epstein not to contact victims about the NPA (1 62, supra);
+• Entering into a NPA with a confidentiality provision that precluded compliance with
+CVRA victim notification obligations (19 65-69, supra);
+52
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 53 of 57
+• Sending FBI agents to meet with three victims, while precluding the agents from being
+able to discuss the NPA (11 69-73, supra);
+• Agreeing with defense counsel to stop victim notifications required under the CVRA (11
+76-77, supra);
+• Agreeing to notify victims only after Epstein had entered his plea (111 80-81);
+• Sending deceptive letters about the case still being "under investigation" (111 91-94, 98);
+• Concealing the NPA from attorneys for the victims (111 100-02, 116-17);
+• Failing to provide reasonable notice of Epstein's sentencing hearing to the victims (11
+105-10); and
+• Agreeing with Epstein to oppose the release of the NPA to the victims after his plea (11)
+134-36).
+The Government took all of these actions, it should be noted, with the knowledge of - and,
+indeed, at the insistence of - Epstein, the criminal who had sexually abused the victims. See 1 1,
+supra.
+The overarching point on many of these actions is that victims of crime are not treated
+fairly if prosecutors are deceiving them about what is going on with regard to prosecuting their
+abusers. Whatever else "fairness" might mean, it has to at least mean that the Government keep
+the victims properly informed and otherwise try to insure that their interests are respected in the
+criminal justice process.
+See 150 CONG. REC. 7303 (Apr. 22, 2004) (statement of Sen. Kyl
+describing right to fairness in broad terms). The foregoing facts amply demonstrate numerous
+situations wherein the Government deliberately kept the victims in the dark about what was
+happening.
+Accordingly, the Government violated their right to fairness too and summary
+judgment is warranted on this independent basis as well.
+53
+
+
+Case 9:08-cV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 54 of 57
+C.
+The Government Violated the Victims' Right to Reasonable and Accurate
+Notice.
+The Government also violated the victims? "right to reasonable, accurate and timely
+notice of any public court proceedings... involving the crime." 18 U.S.C. § 3771(a)(2) (emphasis
+added). The Government may claim that it complied with this right by giving the victims notice
+of the state court proceeding in which Epstein pled guilty to sex offenses involving other girls
+less than one business day before the hearing.!? But the Government violated the victims' right
+to "reasonable" and "accurate" notice about this hearing. The Government concealed from
+and all the other victims, that the NPA and the federal investigation were
+implicated in this hearing and thus their right to see Epstein prosecuted was about to be
+permanently extinguished. As a result of this concealment, they missed their only chance to
+speak to the Court about the crimes committed against them and to see with their own eyes
+Epstein being sent to jail. Indeed, even afterwards, the Government continued to hide what was
+happening with regard to the NPA. See 11l 124-148, supra.
+Importantly, one of the motives for this concealment was to avoid scrutiny by the
+victims —and the public—-of what the Government was doing. See 11 121-23, supra.
+ad other similarly-situated victims of serious federal sex offenses did not attend
+Epstein's plea hearing and sentencing for the obvious reason that they thought it had nothing to
+do with them—-which is precisely what the Government and Epstein were trying to accomplish
+76 The Government also seems to argue that the CVRA did not apply to this hearing because it was held in state
+ourt. But the hearing was one "involving the crime" committed against the victims, 18 U.S.C. § 3771(a)(2)
+Epstein had constructed te PA, the state ple riger the apricoly of tie eat A - ane tus the ra.
+54
+
+
+Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 55 of 57
+together. Whatever else might be said about one of the most extraordinarily lenient plea
+arrangements in American history, the Government simply failed to discharge its duty to
+Epstein's victims to provide "reasonable" and "accurate" notice about court hearings connected
+with their abuse. Summary judgment should therefore also be granted on this basis.
+CONCLUSION
+Under the Crime Victims' Rights Act, once the Government had identified the victims of
+Epstein's sexual offenses, it had statutory obligations to them that it was legally required to
+respect. Despite those responsibilities to the victims, the Government chose instead to side with
+the man who had victimized them. Rather than properly inform the victims what was happening,
+the Government engaged in months of undisclosed plea negotiations with Epstein. Once the
+negotiations had produced a plea arrangement that was sufficiently lenient to be acceptable to
+Epstein, rather than tell the victims what had been agreed, the Government conspired with
+Epstein to conceal that agreement. The undisputed facts clearly show that, for months, the
+Government deceived the victims about the existence of this arrangement-deception that was
+necessary to permit the agreement to be consummated before the victims could object.
+Perhaps before Congress enacted the CVRA, such outrageous behavior could escape a
+judicial response. But Congress has now spoken. The Government has an obligation to confer
+with crime victims, to treat them fairly, and to provide them reasonable and accurate notice of
+judicial proceedings relevant to their victimization. To the contrary, the undisputed facts in this
+case show that the Government did not make any effort to extend to any of Epstein's dozens of
+victims any of the rights which Congress promised them. This Court is accordingly now
+55
+
+
+Case 9:08-CV-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 56 of 57
+obligated to take all necessary steps to "ensure" that the victims' rights are protected. 18 U.S.C.
+§ 3771(b).
+This is not a close case. This is a summary judgment case. For all the foregoing reasons,
+the Court should find the Government violated the rights of
+and other
+similarly situated victims under the Crime Victims' Rights Act. If the Court grants their motion,
+the victims would then ask the Court to set an appropriate schedule for briefing and a hearing on
+the issue of the remedy for the violations of their rights.
+DATED: February 10, 2016
+Respectfully Submitted,
+Is/ Bradley 9. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+And
+Paul G. Cassell
+So. Hainey College of Law at the
+University of Utah
+*This daytime business address is provided for identification and correspondence purposes only and is not
+intended to imply institutional endorsement by the University of Utah.
+56
+
+
+Case 9:08-Cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 57 of 57
+I certify that the foregoing document was served on February 10, 2016, on the following
+using the Court's CM/ECF system:
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Fax:
+E-mail
+3-mail:
+Attorneys for the Government
+Roy Eric Black
+Jacqueline Perczek
+Black Srebnick Kornspan & Stumpf
+201 S Biscayne Boulevard
+Suite 1300
+Miami, FL 33131
+305-371-6421
+Fax: 358-2006
+Email: pleading@royblack.com
+Attorneys for Jeffrey Epstein
+Is/ Bradley f. Edewards
+
diff --git a/vision-fixhub/ds9-unparsed-05/b616a5aae070e12955a5d887e23c3283255814ce770581025d752d28d5a3b4ff.receipt.json b/vision-fixhub/ds9-unparsed-05/b616a5aae070e12955a5d887e23c3283255814ce770581025d752d28d5a3b4ff.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f4ac47bd84dbdd89e074b3c445dcf7e0acd24e58
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b616a5aae070e12955a5d887e23c3283255814ce770581025d752d28d5a3b4ff.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36739,
+  "dataset": "marble-joined",
+  "doc_id": "b616a5aae070e12955a5d887e23c3283255814ce770581025d752d28d5a3b4ff",
+  "engine": "marble-apple-vision",
+  "event_count": 437,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "af889c72a5f74bb9039710689aee28eac7c058ce98e2bfd6cd71fc68216234c1",
+  "output_sha256": "8e6758dd7f23afdf7aa6935a82bfb37eefb677aa592d819d4924ebfc12ada00a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b635b1fdd8d21d6b573a6f0e1a5f0526382299a8923d635e31d31899ed72be77.md b/vision-fixhub/ds9-unparsed-05/b635b1fdd8d21d6b573a6f0e1a5f0526382299a8923d635e31d31899ed72be77.md
new file mode 100644
index 0000000000000000000000000000000000000000..6be5243aae2f123d0e21e6ef0d27b986f9f59e5f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b635b1fdd8d21d6b573a6f0e1a5f0526382299a8923d635e31d31899ed72be77.md
@@ -0,0 +1,462 @@
+Memorandum
+Subject
+Operation Leap Year: Notification of Breach
+USAO No. 2006R01181
+Date
+June 9, 2009
+To
+From
+Jeffrey H. Sloman
+Acting United States Attorney
+AUSA, Ft Lauderdale
+First Assistant U.S. Attorney
+Deputy Chief, Criminal Division, West Palm Beach
+Chief
+Chief, Criminal Section I, Northern Division, WPB
+INTRODUCTION
+This memorandum seeks approval to serve the attached letter providing notice of a breach
+of the Non-Prosecution Agreement on attorneys for Jeffrey Epstein. On Friday, June 12, 2009,
+Judge Marra will be presiding over a hearing on Jeffrey Epstein's motions to stay all of the civil
+lawsuits filed against him by victims identified through our investigation. In his Order setting the
+matter for a hearing, Judge Marra stated:
+This hearing shall be limited to the issue of whether Defendant Epstein's defense of
+the civil actions filed against him violates the non-prosecution agreement between
+Epstein and the United States. The United States' position in this matter would be
+very helpful to the Court and, accordingly, the Court requests that the United States
+appear at the hearing.
+Based upon a review of pleadings filed by Epstein in connection with the civil suits, Epstein
+has taken positions directly in contravention of the Non-Prosecution Agreement between Epstein
+
+
+
+and the United States. Accordingly, I recommend that we provide Epstein's counsel with Notice
+of the Breach at the hearing on June 12th, and proceed to indictment promptly thereafter.
+BACKGROUND
+In the summer of 2006, the FBI approached the U.S. Attorney's Office about an investigation
+of Jeffrey Epstein ("Epstein") into allegations of enticing minors to engage in prostitution. The
+Town of Palm Beach Police Department ("PBPD"*) had approached the FBI after it became
+convinced that Epstein's attorneys had placed undue pressure on the Palm Beach County State
+Attorney's Office ("SAO"), causing them to forego prosecution of Epstein. When the SAO
+presented the case to a state grand jury rather than proceeding by information, and when the state
+grand jury returned an indictment charging only solicitation of adult prostitution, PBPD asked the
+FBI to begin a federal investigation. FBI, in turn, approached the USAO about possible federal
+prosecution.
+The federal grand jury investigation began in the summer of 2006, and the first grand jury
+subpoenas were issued in August 2006. Towards the end of 2006, Epstein's attorneys began making
+contact with the U.S. Attorney's Office to seek resolution of the case. A meeting in West Palm
+Beach was held with Epstein's attorneys in February 2007. After that meeting, the investigation
+continued, and an indictment package was prepared in May 2007 with the intent to present to the
+grand jury in mid-May. At the requests of Epstein's counsel, the indictment was delayed to allow
+Epstein's attorneys to meet with additional members of the U.S. Attorney's Office. A meeting was
+held on June 26, 2007, when Epstein's attorneys presented their arguments why federal prosecution
+was inappropriate.
+On July 31, 2007, another meeting occurred between Epstein's attorneys and the U.S.
+
+2
+
+
+Attorney's Office. At that meeting, the United States presented a list of terms of a possible nonprosecution agreement. One of those terms was:
+Epstein agrees that, if any of the victims identified in the federal investigation file
+suit pursuant to 18 U.S.C. $ 2255, Epstein will not contest the jurisdiction of the U.S.
+District Court for the Southern District of Florida over his person and the subject
+matter. Epstein will not contest that identified victims are persons who, while
+minors, were victims of violations of Title 18, United States Code, Section(s) 2422
+and/or 2423.
+At that time, Epstein's attorneys advised that an agreement involving jail time would not be
+acceptable.
+On August 31, 2007, the FBI agents and I met with
+Chief of the Child
+Exploitation and Obscenity Section, to discuss the evidence and theory of the prosecution. He had
+previously been provided with a copy of the prosecution memo related to the indictment. On
+September 7, 2007, Epstein's attorneys met with the U.S. Attorney,
+Jeff Sloman,
+and I. Ken Starr presented federalism arguments, urging deferral to state
+prosecution. When those arguments failed, Epstein's attorneys stated that he wanted to engage in
+plea negotiations. Epstein's attorneys wavered back and forth between a Non-Prosecution
+Agreement, involving pleading to state charges, or a plea to federal charges. Finally, on September
+24, 2007, the Non-Prosecution Agreement was signed.' The Agreement contains the following
+provisions:
+'An amended indictment package had been prepared and was scheduled for presentation to
+the grand jury on September 25, 2007. Judge Marra also had scheduled a hearing on Epstein's
+motion to quash grand jury subpoenas for the computer equipment removed from Epstein's home
+by Roy Black's investigator when they learned of the state investigation. This was postponed to
+allow plea negotiations and eventually was withdrawn pursuant to the terms of the Non-Prosecution
+Agreement.
+
+3
+ATToRNEY Work PRoDUcT
+
+
+8.
+If any of the individuals referred to in paragraph (7).' supra, elects to file suit
+pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the
+United States District Court for the Southern District of Florida over his
+person and/or the subject matter, and Epstein waives his right to contest
+liability and also waives his right to contest damages up to an amount as
+agreed to between the identified individual and Epstein, so long as the
+identified individual elects to proceed exclusively under 18 U.S.C. § 2255,
+and agrees to waive any other claim for damages, whether pursuant to state,
+federal, or common law. Notwithstanding this waiver, as to those individuals
+whose names appear on the list provided by the United States, Epstein's
+signature on this agreement, his waivers and failures to contest liability and
+such damages in any suit are not to be construed as an admission of any
+criminal or civil liability.
+10.
+Except as to those individuals who elect to proceed exclusively under 18
+U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's
+signature on this agreement, nor its terms, nor any resulting waivers or
+settlements by Epstein are to be construed as admissions or evidence of civil
+or criminal liability or a waiver of any jurisdiction or other defense as to any
+person, whether or not her name appears on the list provided by the United
+States.
+The Agreement also called upon Epstein to use his "best efforts" to enter a guilty plea and
+be sentenced not later than October 26, 2007. (I 11) Citing conflicts with attorney schedules,
+Epstein's attorneys asked the USAO to extend the deadline for his plea and sentencing. After a
+series of delays, Epstein's attorneys sought review by members of the Justice Department. When
+it appeared that the Non-Prosecution Agreement would be undone, the indictment package was
+prepared again, and was reviewed in anticipation of presentation to the grand jury.
+On June 23, 2008, Senior Associate Deputy Attorney General John Roth denied the various
+appeals of Epstein's attorneys and wrote, "Even if we were to substitute our judgment for that of the
+U.S. Attorney, we believe that federal prosecution of this case is appropriate. Moreover, having
+"The "individuals referred to in paragraph (7)" are "individuals whom [the United States] has
+identified as victims, as defined in 18 U.S.C. § 2255."
+
+4
+ATTORNEY Work PRODUCT
+
+
+reviewed your allegations of prosecutorial misconduct, and the facts underlying them, we see
+nothing in the conduct of the U.S. Attorney's Office that gives us any reason to alter our opinion."
+After several more skirmishes regarding the wording of the plea agreement with the State
+Attorney's Office, Epstein entered his guilty plea and was sentenced on June 30, 2008. In
+accordance with the terms of the Non-Prosecution Agreement, later that day, Special Agent
+and I met with Attorneys Jack Goldberger and Michael Tein and provided them with
+a written list of the 32 identified victims.
+Since the entry of the plea and sentencing, a number of concerns have been raised with
+Epstein's attorneys, including: (1) their objections to our efforts to notify victims of the resolution
+of the case; (2) their refusal to abide by and pay for the victims' representative, Bob Josefsberg, who
+had been selected by Judge Michael Davis, acting pro bono as a Special Master; (3) their
+representations to the Court about the continued pendency of the motion related to the subpoena for
+the computer equipment removed by a private investigator; (4) inappropriate contact between people
+working for Epstein and the identified victims; and (5) Epstein's application for and participation
+in the work release program. Some written notifications of potential breaches have been provided
+to Epstein's counsel. Those have all been resolved without a determination of breach by the U.S.
+Attorney's Office and a resultant indictment.
+THE CIVIL SUITS AGAINST EPSTEIN
+Not surprisingly, since the entry of the guilty plea, a number of victims have filed suit against
+Epstein. In federal court, fourteen suits have been filed against Epstein. All of those cases have
+been assigned to Judge Marra who also was assigned the lawsuit filed against the United States by
+two of Epstein's victims. In the Victims' Rights suit, Judge Marra ordered the United States to make
+
+5
+
+
+the Non-Prosecution Agreement available to each of the victims and/or her attorney, so long as they
+agreed to be bound by a Protective Order. Each victim (or her attorney) was provided with notice
+of the Court's ruling, and several executed the Protective Order and were provided with copies of
+the Non-Prosecution Agreement.
+From the beginning, Epstein has "vigorously defended" the suits, and has filed several
+motions to dismiss.
+In all of the early suits, the plaintiffs raised only common law tort claims or a
+combination of common law claims and a claim under 18 U.S.C. § 2255. A number of plaintiffs"
+attorneys have argued that Epstein's defenses violate the NPA. Reviewing the language of the NPA
+and resolving any ambiguities in favor of Epstein, those defenses do not breach the NPA. However,
+some of the later plaintiffs, especially those represented by Bob Josefsberg, filed claims exclusively
+under 18 U.S.C. § 2255. Epstein has filed answers and Motions to Dismiss those Complaints as
+well, asserting defenses to liability, including that there can be no liability because Epstein was not
+convicted of an offense enumerated in 18 U.S.C. § 2255. By doing so, Epstein has breached the
+NPA.
+The following is a brief synopsis of the suits filed in federal court.?
+2.
+Doe v. Epstein, 08-CV-80804-KAM: This suit was filed in state court, but was
+removed to federal court on July 18, 2008 by Epstein. The suit was filed by
+... the first victim identified in PBPD's investigation. Plaintiff filed motion to
+remand to state court, which was granted by Judge Marra.
+Jane Doe #2 v. Epstein, 08-CV-80119-KAM: Complaint filed on February 6, 2008,
+alleging: sexual assault (Count I), and intentional infliction of emotional distress
+(Count II). Epstein moved to stay the litigation, which was denied by Judge Marra.
+Epstein moved to dismiss Count I, claiming that there was no civil cause of action
+"As mentioned above, the NPA provides protection only to victims who proceed exclusively
+pursuant to 18 U.S.C. § 2255. By definition, the lawsuits filed in state court do not contain claims
+for relief under section 2255. Accordingly, this memo will not address those lawsuits.
+
+6
+
+
+for "sexual assault." Plaintiff filed an Amended Complaint asserting: sexual assault
+and battery (Count I), intentional infliction of emotional distress (Count II), and
+"coercion and enticement to sexual activity in violation of 18 U.S.C. § 2422 (Count
+III). Epstein again moved to dismiss, claiming that there was no civil cause of action
+for "sexual assault and battery," and arguing that the plaintiff had not made sufficient
+factual allegations to support a claim under 18 U.S.C. § 2422. Plaintiff then filed a
+Second Amended Complaint raising the same claims, but providing additional
+factual allegations. Epstein filed an Answer, in which he cited his Fifth Amendment
+privilege from self-incrimination as the response to the allegations in the Second
+Amended Complaint. Epstein also raised the following affirmative defenses:
+As to all counts, Plaintiff consented to and was a willing
+participant in the acts alleged.
+As to all counts alleged, Plaintiff consented to and
+patrice ed in conde
+participated in conduct similar and/or identical to the acts
+alleged with other persons which were the sole or
+contributing cause of Plaintiff's alleged damages.
+As to all counts, Defendant reasonably believed that the
+Plaintiff had attained the age of 18 years old at the time of the
+alleged acts.
+Plaintiff's claims are barred by the applicable statute of
+limitations.
+Epstein then filed another Motion to Stay all of the civil litigation. Judge Marra
+ordered theUnited States to file a written response, and the matter is set for hearing
+on Friday, June 12, 2009. Today, Epstein filed an Amended Answer, raising a
+umber of additional affirmative defenses, including that the claims are barred by tl
+atute of limitations and that the pre-2006 version of 18 U.S.C. $ 2255 applic
+which only creates a cause of action for a person who is still a "minor," as opposed
+Jane Doe #3 v. Epstein, 08-CV-80232-KAM: This suit was filed by the same
+lawyers as in the Jane Doe #2 suit, and the procedural history is identical.
+4.
+Jane Doe #4 v. Epstein, 08-CV-80380-KAM: This suit was filed by the same
+lawyers as in the Jane Doe #2 suit, and the procedural history is identical.
+Jane Doe #5 v. Epstein, 08-CV-80381-KAM: This suit was filed by the same
+lawyers as in the Jane Doe #2 suit, and the procedural history is identical.
+6.
+Jane Doe #6 v. Epstein, 08-CV-80994-KAM: This suit was filed by the same
+
+7
+
+
+7.
+8.
+9.
+10.
+lawyers as in the Jane Doe #2 suit, and the procedural history is identical.
+Jane Doe #7 v. Epstein, 08-CV-80993-KAM: This suit was filed by the same
+lawyers as in the Jane Doe #2 suit, and the procedural history is identical.
+v. Epstein, 08-CV-80811-KAM: This suit was filed in state court and
+removed to federal court. Plaintiff sued Epstein and
+(Epstein's
+assistant).
+is represented by Bruce Reinhart.
+initial Complaint
+alleged sexual abuse and intentional infliction of emotional distress.
+later filed
+a First Amended Complaint, which alleged 30 separate claims pursuant to 18 U.S.C.
+§ 2255. Epstein filed a motion to dismiss, arguing that a victim can raise only one
+claim under section 2255, not a separate claim for each occurrence. A few days ago,
+filed a document entitled "Conditional Notice of Intent to Exclusively Rely on
+Statutory Damages provided by 18 U.S.C. § 2255." In that document,
+that, if the statutory floor applies to each of her 30 claims under § 2255, then she will
+forego her civil claims. If, however, the Court decides that the statutory floor can
+apply to each victim only once, then she wants to be able to pursue both her statutory
+and common law claims.
+Doe v. Epstein, 08-CV-80893-KAM: This suit was filed by one of the victims who
+brought the victim's rights suit against the United States. She is represented by Brad
+Edwards. The Complaint raises the following claims: sexual exploitation, sexual
+abuse and/or sexual assault of a minor (Count I), "Cause of Action pursuant to 18
+U.S.C. § 2255" (Count II), intentional infliction of emotional distress (Count III,
+and "Civil Remedy for Criminal Practices" (Count IV). Plaintiff also filed a separate
+"Civil RICO Statement." Epstein filed a motion to dismiss or for a more definite
+statement, which was granted in part by Judge Marra. Plaintiff filed an Amended
+Complaint in April, adding a claim for damages under a Florida statute providing
+compensation for crime victims. Epstein has filed several motions to extend the time
+to file his Answer pending the outcome of his motion to stay all the civil litigation.
+Epstein must file his Answer to this Amended Complaint by June 12th, the date of
+the hearing on the Motion to Stay.
+Doe II v. Epstein, 09-CV-80469-KAM: This Complaint is based exclusively on 18
+U.S.C. § 2255. Plaintiff alleges that she was a victim of a violation of 18 U.S.C. §
+2422(b), and that Epstein "has made an agreement with the United States Attorney's
+Office to not contest liability for claims brought exclusively pursuant to 18 U.S.C.
+§ 2255, in exchange for avoiding federal prosecution under 18 U.S.C. § 2422(b),
+which provides a sentence of 10 years for each violation of the law." On May 6,
+2009, Epstein filed a motion to dismiss, alleging that the case should be dismissed
+because the plaintiff had already filed a state court suit for common law claims
+arising from the same activity. Epstein also argued that the version of 18 U.S.C. S
+2255 that was in effect at the time of the sexual encounters applies (with its $50,000
+
+8
+
+
+minimum rather than the $150,000 minimum).*
+11.
+Doe No. 101 v. Epstein, 09-CV-80591-KAM: This was the first suit filed by
+firm. On May 1, 2009, Plaintiff filed an Amended Complaint alleging
+six claims under 18 U.S.C. § 2255 — a separate count for each predicate offense that
+Epstein committed. Thus, Count 1 alleges that defendant Epstein "used a facility or
+means of interstate and/or foreign commerce to knowingly persuade, induce, entice,
+or coerce Jane Doe No. 101, when she was under the age of 18 years, to engage in
+prostitution and/or sexual activity for which any person can be charged with a
+criminal offense ... in violation of 18 U.S.C. § 2422(b)." The other counts charge
+that Epstein violated § 2423(b) (travel with intent to engage in illicit sexual conduct);
+§ 2251 (production of child pornography); §2252(a)(1) (transportation of child
+pornography); § 2252A(a)(1) (distribution of child pornography); and § 2252A(g)
+(engaging in a child exploitation enterprise).
+12.
+13.
+Doe No. 102 v. Epstein, 09-CV-80656-KAM: This suit also was filed by
+Josefsberg's firm. On May 1, 2009, Plaintiff filed suit alleging the same claims
+raised by Doe No. 101. Epstein has not yet filed his answer to that Complaint.
+Doe No. 8 v. Epstein, 09-CV-80802-KAM: This is the most recently filed suit. It
+vas filed on May 28, 2009. This suit was filed by the same lawyers as in the Jan
+Doe #2 suit, and the procedural history is identical
+THE PLEADING THAT VIOLATED THE NON-PROSECUTION AGREEMENT
+Epstein's Non-Prosecution Agreement speaks of waiving challenges to liability and damages
+and one could certainly argue that the liability waiver applies to any 2255 claim filed by one of the
+listed victims.
+However, construing any ambiguity in favor of Epstein, the most conservative
+reading of the NPA requires him to waive challenges to liability in those cases where the plaintiff
+proceeds exclusively under 18 U.S.C. § 2255. Jane Doe #101 has stated all claims pursuant to 18
+U.S.C. § 2255 and is not seeking any common law, state, or other federal statutory remedies. In
+response to those claims, Epstein has made the following arguments in his Motion to Dismiss the
+'Although not raised in the Motion to Dismiss Jane Doe I's Complaint, Epstein has argued
+in another suit that, under the pre-2006 law, only persons who are still "minors" can file suit under
+18 U.S.C. § 2255. In the 2006 version of the law, the language was changed to allow suit by any
+person who, "while a minor," was a victim of a violation.
+
+9
+
+
+First Amended Complaint or, in the Alternative, for a More Definite Statement (which is attached
+hereto):
+A.
+The applicable version of § 2255 only permits "minor" to sue: ... Yet the
+FAC [First Amended Complaint] affirmatively admits that Plaintiff is over the age
+of 18... Plaintiff is bound by that admission, and the FAC must be dismissed with
+prejudice....
+B.
+Nor is Plaintiff the "victim of a violation" of a predicate criminal statute
+within the meaning of § 2255. 18 U.S.C. § 2255(a). In our system of justice, those
+accused of "violating" a criminal statute are innocent until proven guilty beyond a
+reasonable doubt in criminal court. With due respect to the courts that have
+concluded otherwise, it defies common sense to think that Congress intended to
+invert that fundamental legal norm, and the legislative history of $ 2255 expressly
+confirms that Congress intended to condition § 2255 actions on an antecedent
+criminal conviction. The FAC therefore must be dismissed because it does not-and
+cannot-allege that Defendant has been convicted of a predicate criminal offense.
+C.
+Even if the applicable version of § 2255 were construed to allow adults to sue
+in the absence of a predicate conviction, the FAC...-even taken as true-would not
+establish a legally "plausible" claim that Plaintiff is a victim of any predicate
+criminal offense giving rise to a § 2255 cause of action.
+(Epstein's Mot'n at 2-3.)
+The motion expands each of these arguments. With respect to his argument that only
+"minors" can sue for damages under 18 U.S.C. § 2255, Epstein asserts that the 2006 amendment to
+§ 2255 was not meant to apply retroactively and cannot apply retroactively because it would violate
+the Ex Post Facto Clause.'
+'The pre-2006 statute reads: "Any minor who is a victim of [certain federal crimes] and who
+utters personal injury as a result of such violation may sue in any appropriate United States Distric
+Court and shall recover the actual damages such minor sustains and the cost of the suit, includin
+a reasonable attorney's fee. any minor as described in the preceding sentence shall be deemed to
+have sustained damages of no less than $50,000 in value."
+In 2006, the statute was revised to state: "Any person who, while a minor, was a victim of
+[certain federal crimes] and who suffers personal injury as a result of such violation, regardless of
+whether the injury occurred while such person was a minor, may sue in any appropriate United
+
+10
+
+
+As to his second argument, Epstein reiterates that the "FAC still would fail as a matter of law
+because it does not (and cannot consistent with Rule 11) allege that Defendant is guilty of *a
+violation' of a predicate statute.... As set forth below, the plain text of the statute and its legislative
+history demonstrate that § 2255 is conditioned on a prior federal conviction. Because Defendant has
+never been convicted of a predicate federal offense, the FAC must be dismissed." (Epstein's Mot'n
+at 14-15.) He explains:
+Given the presumption of innocence that animates our system of criminal justice,
+Congress's reference to "a victim of a violation" of a criminal statute can only be
+interpreted to require proof that the defendant has been convicted of a predicate
+federal offense against the plaintiff. After all, an individual accused of "violating"
+a criminal statute is deemed innocent until proven guilty beyond a reasonable doubt.
+It would turn that principle upside down if plaintiffs could sue in the absence of an
+antecedent criminal conviction.
+(Id. at 15.) Epstein notes that the only district courts to have addressed § 2255 have held that an
+"antecedent conviction" is not required, but argues that those cases were wrongly decided. In her
+Complaint, Jane Doe #101 asserted that Epstein had been convicted of state law crimes and, taking
+language directly from Alex Acosta's letter to Lilly Ann Sanchez, wrote that Epstein "is in the same
+position as if he had been tried and convicted of the sexual offenses committed against Plaintiff and,
+as such, must admit liability unto Plaintiff." (Id. at 20.) Epstein quotes from the state plea colloquy
+and the state charging instrument to show that the state charges do not relate to Jane Doe #101.
+Further, he writes, "even if Defendant's state-law pleas did involve state-law offenses against
+Plaintiff-which they did not-$ 2255 only authorizes suit based on predicate convictions under
+certain federal statutes..." (Id. at 21 (emphasis added).)
+States District Court and shall recover the actual damages such person sustains and the cost of the
+suit, including a reasonable attorney's fee. Any person as described in the preceding sentence shall
+be deemed to have sustained damages of no less than $150,000 in value."
+
+
+
+Epstein then addresses each of Jane Doe #101's claims. Taking his arguments directly from
+the various "position papers" that Epstein submitted to our office to urge declination, he argues:
+(1)
+Epstein could not have violated 18 U.S.C. § 2422(b) because he did not use a facility
+of interstate commerce to persuade Jane Doe #101 to engage in sexual activity - the persuasion
+always occurred in person.
+(2)
+Epstein could not have violated 18 U.S.C. § 2423(b) because the "dominant motive"
+for Epstein's interstate travel was not to engage in unlawful sexual activity. 'Instead, as the FAC
+makes clear, Defendant is a successful businessman who maintains homes and properties around the
+world. Even if the FAC's fanciful allegations regarding Defendant's conduct while at those homes
+were true, the FAC does not remotely allege that his dominant motive for travel was to engage in
+illicit sexual acts ..." (Id. at 28 (emphasis in original).)
+(3) Plaintiff failed to adequately plead violations of 18 U.S.C. § 2251, 2252(a)(1) and
+2252A(a)(1) because she does not allege that Epstein intended to transmit or actually did transmit
+images of child pornography in interstate commerce, and alleged only that Epstein "may have taken
+lewd photographs of Plaintiff ..."
+(4)
+Epstein could not have violated 18 U.S.C. § 2252A(g) because the statute was not
+enacted until 2006, and Jane Doe #101 alleges that her interactions with Epstein occurred in 2003.
+RECOMMENDATION
+As explained above, the Non-Prosecution Agreement provides, in relevant part, that "If any
+of the individuals referred to in paragraph (7),° supra, elects to file suit pursuant to 18 U.S.C. $ 2255,
+"The "individuals referred to in paragraph (7)" are "individuals whom [the United States] has
+identified as victims, as defined in 18 U.S.C. § 2255."
+
+12
+
+
+Epstein will not contest the jurisdiction of the United States District Court for the Southern District
+of Florida over his person and/or the subject matter, and Epstein waives his right to contest liability
+and also waives his right to contest damages up to an amount as agreed to between the identified
+individual and Epstein, so long as the identified individual elects to proceed exclusively under 18
+U.S.C. § 2255, and agrees to waive any other claim for damages, whether pursuant to state, federal,
+or common law." The United States has performed its obligations under the NPA, and Jane Doe
+#101 has proceeded exclusively under 18 U.S.C. § 2255, yet Epstein is contesting liability.
+Moreover, Epstein is not simply contesting whether Jane Doe #101 is owed damages because of the
+particular circumstances of his interactions with Jane Doe #101, he is asserting that he can never be
+forced to pay damages pursuant to 18 U.S.C. § 2255 because-in reliance on the NPA-the United
+States never prosecuted and convicted him of a predicate offense. The protection of the victims"
+rights to restitution was one of the most important aspects of the NPA and the failure of that key
+piece of consideration cannot be tolerated. This is especially true when one considers that Epstein
+has served virtually no jail time, in contravention of the NPA and representations made to our Office
+by Epstein's attorneys. The importance of this consideration is reiterated later in the NPA: 'In
+consideration of Epstein's agreement to plead guilty and to provide compensation in the manner
+described above, if Epstein successfully fulfills all of the terms and conditions of this agreement,
+the United States also agrees that it will not institute any criminal charges against any potential coconspirators of Epstein." (NPA at p.5.) The Agreement continues: "By signing this agreement,
+Epstein asserts and certifies that each of these terms is material to this agreement and is supported
+by independent consideration and that a breach of any one of these conditions allows the United
+States to elect to terminate the agreement and to investigate and prosecute Epstein and any other
+
+13
+ATToRNEY Work PRoDucT
+
+
+individual or entity for any and all federal offenses." (NPA at p.6.)
+Accordingly, I recommend that the Office declare that Epstein has breached the NPA and
+proceed promptly to indictment.
+NOTICE REQUIREMENTS OF THE NPA
+Pursuant to the NPA, the U.S. Attorney's Office is required to provide prompt notice of a
+breach:
+If the United States Attorney should determine, based on reliable evidence, that,
+during the period of the Agreement, Epstein willfully violated any of the conditions
+of this Agreement, then the United States Attorney may, within ninety (90) days
+following the expiration of the term of home confinement discussed below, provide
+Epstein with timely notice specifying the condition(s) of the Agreement that he has
+violated, and shall initiate its prosecution on any offense within sixty (60) days' of
+giving notice of this violation. Any notice provided to Epstein pursuant to this
+paragraph shall be provided within 60 days of the United States learning of facts
+which may provide a basis for a determination of a breach of the Agreement.
+(NPA at p.2.)
+The pleading that is the subject of the breach was filed with the Court on May 26, 2009.
+Thus, we must provide notice of the breach not later than Saturday, July 25, 2009. The Office also
+must indict within 60 days of giving notice. In light of Judge Marra's directive that the Office
+address the issue of breach at the hearing on Friday, June 12, 2009, I recommend that we provide
+that Notice at the hearing.
+
+14
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/b635b1fdd8d21d6b573a6f0e1a5f0526382299a8923d635e31d31899ed72be77.receipt.json b/vision-fixhub/ds9-unparsed-05/b635b1fdd8d21d6b573a6f0e1a5f0526382299a8923d635e31d31899ed72be77.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b25cd4dad9d02b3fc186c80a763233c084d92f7b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b635b1fdd8d21d6b573a6f0e1a5f0526382299a8923d635e31d31899ed72be77.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -793,
+  "dataset": "marble-joined",
+  "doc_id": "b635b1fdd8d21d6b573a6f0e1a5f0526382299a8923d635e31d31899ed72be77",
+  "engine": "marble-apple-vision",
+  "event_count": 31,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.privileged-attorney-work-product\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "e29a87425038ba30a3e019b8fb9941595eb3a62602497a7af372453aab6477ef",
+  "output_sha256": "736e8334fe08daeffd5ffa29807b6c58270e2bb2784be4c86dbe97b29f74b501",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b645552b195c7b71f3ca4b8a40b93560a6b87bc11fb78ca35f11af7248b9f75a.md b/vision-fixhub/ds9-unparsed-05/b645552b195c7b71f3ca4b8a40b93560a6b87bc11fb78ca35f11af7248b9f75a.md
new file mode 100644
index 0000000000000000000000000000000000000000..e952ec1cf02c8f1c0400101823d1ef6a23f9a278
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b645552b195c7b71f3ca4b8a40b93560a6b87bc11fb78ca35f11af7248b9f75a.md
@@ -0,0 +1,114 @@
+OLY-54
+
+
+TO:
+United States District iourt
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-54
+SUBPOENA FOR:
+| PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+June 12, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+See attachments for the production of required documents.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+vour annenrance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+May 31, 2007
+This subpoena is issued upon application
+of the United States of America
+.S. Attorney
+*If not applicable, enter "none."
+500 So. Australian Avenue, Suite 400
+West Palm Beach. ET. 33401-6235
+Tel
+Fax
+To be used in licu of AO110
+FORM ORD-227
+JAN.86
+
+
+... :
+ATTACHMENT TO SUBPOENA
+1.
+2.
+3.
+4.
+5.
+6.
+
+
+U.S. Departn tof Justice
+United States Attorney
+Southern District of Florida
+00 S. Australian Ave, Suite 40
+Yest Palm Beach, FL 33401-623
+(561) 820-8711
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+authenticity. Theretore, you may be able to avoid appearing personally at the granc
+jury/trial at the time and place specified by completely filling out the attached Certificatior
+and Inventory and immediately returning it with the records to Special Agent I
+FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to June 12, 2007.
+Sincerely,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+BY:
+ASSISTANT UNITED STATES ATTORNEY
+
+
+→ ...
+CERTIFICATION OF BUSINESS RECORDS
+I, the undersigned,
+employed bylassociated with
+position of
+_ declare that l am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+Date of execution:
+Place of execution:
+Signature:
+
+
+APPENDIX A
+DOCUMENT INVENTORY
+The documents submitted are as follows:
+Signature of Records Custodian:
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/b645552b195c7b71f3ca4b8a40b93560a6b87bc11fb78ca35f11af7248b9f75a.receipt.json b/vision-fixhub/ds9-unparsed-05/b645552b195c7b71f3ca4b8a40b93560a6b87bc11fb78ca35f11af7248b9f75a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..25c8220baf2146a6e487f0bc5beeaa0d2d2490f3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b645552b195c7b71f3ca4b8a40b93560a6b87bc11fb78ca35f11af7248b9f75a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -79,
+  "dataset": "marble-joined",
+  "doc_id": "b645552b195c7b71f3ca4b8a40b93560a6b87bc11fb78ca35f11af7248b9f75a",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "a80f32931237a81aca4140204fa71267aae06784918fbe35eec8be50507bc951",
+  "output_sha256": "d2938dc64980815a787d28a511df848fb3720b15b68831ccd0cf6ee2fb3d7c92",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b7017567a06b86fa54e3e05dcf4a82dd1ea1529e3e626698d30e1a5724a06e62.md b/vision-fixhub/ds9-unparsed-05/b7017567a06b86fa54e3e05dcf4a82dd1ea1529e3e626698d30e1a5724a06e62.md
new file mode 100644
index 0000000000000000000000000000000000000000..69ea97955b91def3b4d10e03240e771b98ded5c7
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b7017567a06b86fa54e3e05dcf4a82dd1ea1529e3e626698d30e1a5724a06e62.md
@@ -0,0 +1,4033 @@
+Statements
+
+
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary .............................
+Your Portfolio Holdings
+Transaction Detail
+Your Messages ......................
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+2
+3
+4
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+••••••••••••••
+Securities Bought
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERIOD
+$0.18
+39,793,750.00
+58,606.56
+39,852,356.56
+-39,736,535.03
+-115,821.22
+6. 39.852.356.25
+0.31
+$0.45
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+0.18
+$0.18
+Income Summary
+U.S. Govt. Bond Int.
+Credit Balance Int.
+Reverse Repurchase Int.
+Total
+Bond Purchase Int.
+Margin Int. Paid
+Repurchase Int. Exp.
+THIS PERIOD
+58,606.56
+0.00
+0.00
+$58,606.56
+0.00
+0.00
+-36,535.03
+CLOSING
+0.49
+$0.49
+YEAR TO DATE
+2,153,257.88
+225.80
+32,666.67
+52.186.150.35
+-532,378.76
+-111.71
+-255,320.39
+01/01/04;12:17 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 28, 2003
+Important Message
+any information regardir
+D03interest, dividenc
+niscellaneous income
+gross proceeds or original
+1o be reported to the is tor
+By Macy 21,004,a 10425
+
+
+2 of5
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SIMBCLCUSIP
+QUANTITY
+PRICE
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearnsand Co. Inc. outstanding as of date of statement
+URCHASE
+REPURCHASE
+PRICING
+PURCHASE PRICE
+ACCRUED REPO
+TART DAT
+DATE
+RATE
+PRINCIPAL
+INTEREST*
+YOU SOLD
+(REPO)
+11/14/03
+OPEN
+0.750
+YOU SOLD
+(REPO)
+12/05/03 OPEN
+0.800
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASE TRANSACTIONS
+-As of statoment diño
+-9,987,500
+-19,900,000
+$0
+$-29,887,500
+-6,441
+-14,250
+$0
+$-20,691
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 28, 2003
+MARKET
+VALUE
+ESTIMATED
+ANIVUAL INCOME
+URREN
+ELD I:
+QUANTITY
+(FACE AMOUNT)
+-10,000,000
+CUSP
+DESCRIPTION
+USTR
+USTR
+3.1250 10/15/08
+1.6250 09/30/05
+-20,000,000
+027
+01/01/04;12:17 001
+
+
+3 or 5
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEEMENT TATE
+DATE
+TRANSACTION
+12/05/03 12/04/03
+SOLD
+TOTAL
+SETILEMENT
+DATE
+12/05/03
+TRADE
+DATE
+TRANSACTION
+JOURNAL
+1205/03
+JOURNAL
+12205/03
+INTEREST
+TOTAL
+MISCELLANEOUS
+DATE
+MO/DAY
+12/05/03
+TAANSACTION
+RECEIVED
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRPTION
+UNITED STATES TREASURY NOTE
+DUE 0903012005_01.625% MS 31
+HELD 1 SZKE TO MATUBIT
+GVER REF #
+DESCRIPTION
+UNITED STATES TREASURY NOTE
+FITG
+625 DUE C3
+EPO AGREEMEN
+UNITED STATES TREASURY NOTE
+TERN REPO AGREEMENT
+"UNITED STATES TREASURY NOTE
+D090/205
+1.625
+REPO INTEREST
+DESCRIPTION
+FITG
+FINANCING NEP PA OFF BIEF
+SYMBOLCUSIF
+QUANTITY
+-20,000,000
+PRICE
+99.46875
+ACCR. INT.
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 28,2003
+DEBIT AMOUNT
+19,893,750.00
+58,606.56
+$19.952.356.56
+SYMBOUGUSIP
+QUANTITY
+-20,000,000
+0,000,00
+DEBIT AMOUNT
+39,700,000.00
+_ 36,535.03
+$-39,736,535.03
+19,900,000.00
+$19,900,000.00
+DEBIT AMOUNT
+882.22
+CRECIT AMOUNT
+027
+01/01/04;12:17 001
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 28, 2003
+Transaction Detail (continued)
+MISCELLANEOUS (continued)
+DATE
+MODAY
+12/08/03
+TOTAL
+TRANSACTION
+IOURNAL
+DESCRIPTION
+FITG FITM
+DEBIT AMOUNT
+114,939.00
+$-115,821.22
+CRECIT AMOUNT
+Your messages
+18 Excess SIPC Account Protection Update
+Bear, Stearns Securities Corp. ('BSS"), a member of the Securities Investor
+Protection Corporation ("SIP"), provides account protection for the net equity
+of a customer's funds and securities positions, SIPC provides $500,000 of
+primary net equity protection, including $100,000 for claims for cash ("SIPC
+Coverage"), Visit www,sipc,org for more information about SIPC Coverage,
+BSSC provides the additional protection ("Excess SIPC") through a commercial
+insurer, Effective February 16, 2004, the commercial insurer for Excess SIPC
+will change to Customer Asset Protection Company (CAPCO"), a licensed New
+York insurance company. Account protection applies when a SIPC member
+firm fails financially and is unable to meet its obligations to its securities
+customers, but does not apply to losses from the rise or fall in the market
+value of investments or to SIPC ineligible assets such as options, futures,
+foreign exchange transactions, or any investment contracts that are not
+registered as securities,
+STOP
+****** End of Statement******
+027
+01/01/04:12:17 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+01/01/04:12:17 001
+
+
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary .............................
+Your Portfolio Holdings
+Transaction Detail
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+1
+2
+3
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERIOD
+$-0.51
+19,935,937.50
+25,614.75
+181.59
+..........
+$19,961.733.84
+- 19,757,016.74
+-17.41
+-204,699.00
+S 19.961.733.15
+0.69
+$0.18
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+-0.51
+$-0.51
+Income Summary
+THIS PERIOD
+U.S. Govt. Bond Int.
+25,614.75
+Credit Balance Int.
+0.00
+Reverse Repurchase Int.
+0.00
+Total
+$25,614.75
+Bond Purchase Int.
+0.00
+Margin Int. Paid
+-17.41
+Repurchase Int. Exp.
+-7,016.74
+CLOSING
+0.18
+$0.18
+YEAR TO DATE
+2,094,651.32
+225.80
+32,666.67
+52.127.543.79
+-532,378.76
+-111.71
+-218,785.36
+11/29103:08:43 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 31,2003
+
+
+2 of5
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SIMBCLCUSIP
+QUANTITY
+PRICE
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearnsand Co. Inc. outstanding as of date of statement
+URCHASE
+REPURCHASE
+PRICING
+PURCHASE PRICE
+ACCRUED REPO
+TART DAT
+DATE
+RATE
+PAINCIPAL
+INTEREST*
+YOU SOLD
+(REPO)
+10/17/03
+OPEN
+0.930
+YOU SOLD
+(REPO)
+11/14/03 OPEN
+1.030
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASE TRANSACTIONS
+-As of statoment diño
+-39,700,000
+9,987,500
+$0
+$49,687,500
+-33,943
+-1,925
+$0
+$-35,868
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 31, 2003
+MARKET
+VALUE
+ESTIMATED
+ANIVUAL INCOME
+URREN
+ELD I:
+QUANTITY
+(FACE AMOUNT)
+-40,000,000
+CUSP
+DESCRIPTION
+USTR
+USTR
+1.6250 09/30/05
+3.1250 10/15/08
+-10,000,000
+027
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+3 or 5
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEEMENT TATE
+TRANSACTION
+11/14/03 11/13/03
+SOLD
+DESCRIPTION
+UNITED STATES TREASURY NOTE
+DUE 1001512008 03,125% AO 15
+ELD 31238A TO MATUBI
+VER REF
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+11/03/03
+AVG BAL
+5,422RT 3.852
+021 OFFICE INTEREST 1003
+TOTAL
+SYMBOUCUSIP
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS
+with Bear, Stearns& Co.Inc.
+SETLEMENT
+11/14/03
+TRANSACTION
+JOURNAL
+1114/03
+JOURNAL
+DESCRIPTION
+UNITED STATES TREASURY NOTE
+FITG
+3,125 DUE
+REPO AGREEMENT E
+UNITED STATES TREASURY NOTE
+FITG
+3,125 DUE 10115705
+TERM REPO AGREEMENT
+SYMBOLCUSIP
+QUANTITY
+-10,000,000
+PRICE
+99.48438
+ACCR. INT.
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 31, 2003
+DEBIT AMOUNT
+9,948,437.50
+25,614.75
+$9.974,052.25
+QUANTITY
+RATE (%)
+DEBIT AMOUNT
+17.41
+$-17.41
+SYMBOL/CUSIP
+QUANTITY
+-10,000,000
+20,000,000
+DEBIT AMOUNT
+19,750,000.00
+9,987,500.00
+027
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+TRADE
+DATE
+11/14/03
+TRANSACTION
+INTEREST
+DESCRIPTION
+UNITED STATES TREASURY NOTE
+DUE 1041512008
+3,125
+TOTAL
+MISCELLANEOUS
+11/05/03
+
+TRANSACTION
+JOURNAL
+ELIVERI
+
+TOTAL
+JOURNAL"
+DESCRIPTION
+FITG FITM
+FITG
+FOOL
+COUPON 3,125
+INANCING NET PAIROFF DIF
+FING FIM"
+SYMBOUCUSIP
+DEBIT AMOUNT
+204,699.00
+$-204,699.00
+STOP
+****** End of Statement******
+027
+QUANTITY
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 31, 2003
+DEBIT AMOUNT
+7,016.74
+$-19,757,016.74
+$9.987,500.00
+17.00
+164.59
+$181.59
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+11/29 03:08:43 001
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary .............................
+Your Portfolio Holdings
+. . . .
+Transaction Detail
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 30,2003
+3
+4
+5
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET DEBIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+- 1
+$-1
+657
+-658
+There are no "Stop Loss' orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent -
+-$-1
+$657
+Last statement's market value
+Short market value
+This summary is for informational purposes only. It is not intended as a tax documen
+Ce tatement should be retained for our records. See revere side for important information
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Miscellaneous
+Amount Credited
+Securities Bought
+Funds Withdrawn
+Dividends/Interest Charged
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERIOD
+657.0
+... ..
+59,450,000.00
+235,658.00
+$59,685,658.00
+-59,581,250.00
+-71,459.00
+-33,606.56
+$-59.686.315.56
+-657.56
+5051
+Income Summary
+U.S. Govt. Bond Int.
+Credit Balance Int.
+Reverse Repurchase Int.
+Total
+Bond Purchase Int.
+Margin Int. Paid
+Repurchase Int. Exp.
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+THIS PERIOD
+0.00
+0.00
+0.00
+$0.00
+-33,606.56
+0.00
+0.00
+SHORT
+1
+$1
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+657.05
+$657.05
+CLOSING
+-0.51
+$-0.51
+....
+027
+YEAR TO DATE
+2,069,036.57
+225.80
+32,666.67
+52,101.929.04
+-532,378.76
+-94.30
+-211,768.62
+LONG
+...
+....
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 30,2003
+Your Portfolio
+Allocation
+Short Cash & Equivalent
+100%
+Unshaded portions denote debe balance andor short
+from the absolute market value of your portolio.
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SIMBOUCUSIP
+QUANTITY
+PRICE
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearnsand Co. Inc. outstanding as of date of statement
+URCHASE
+REPURCHASE
+TART DATE
+DATE
+PRICANE PURCHASE NCAL
+ACCRUED REPO
+PRINCIPAL
+INTEREST
+YOU SOLD
+(REPO)
+10/17/03 OPEN
+0.650
+-39,700,000
+-7,862
+YOU SOLD
+(REPO)
+10/17/03 OPEN
+0.200
+- 19,750,000
+-5,535
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+$0
+$0
+TOTAL REPURCHASE TRANSACTIONS
+$-59,450,000
+$-13,397
+is of statement da
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 30,2003
+MAKE
+ALU
+-1
+$-1
+ESTIMATED
+ANNUAL INCOME
+JAREN
+ELD I
+$-1
+QUANTITY
+(FACE AMOUNT)
+-40,000,000
+-20,000,000
+CUSP
+DESCRIPTION
+USTR
+USTR
+1.6250 09/30/05
+3.1250 10/15/08
+027
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+5 or 8
+Transaction Detail
+INVESTMENT ACTIVITY
+SATE EMENT TATE
+DATE
+TRANSACTION
+TD/17/03
+10/16/03
+BOUGHT
+DESCRUPTION
+UNITED STATES 0. 125: A 15
+OVER REF TREATO MATURITY
+10/17/03 10/16/03 BOUGHT
+SVER REF #
+TOTAL
+DEPOSITS AND WITHDRAWALS
+DATE
+10/03/03
+TRANSACTION
+FND WIRED
+DESCRIPTION
+MDA#
+IFNDS WIRED TO
+SLEET NATIONAL BANK
+19
+TOTAL
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS
+with Bear, Stearns& Co.Inc.
+SALEMENT
+10/17/03
+TRADE
+DATE
+TRANSACTION
+JOURNAL
+DESCRIPTION
+UNITED STATES TREASURY NOTE
+FITG
+REPO AGREEMENT
+SYMBOLCUSIP
+QUANTITY
+20,000,000
+ACCR. INT.
+40,000,000
+ACCR. INT.
+PRICE
+98.87500
+....
+39.5156
+DEBIT AMOLNT
+71,459.00
+$-71,459.00
+SYMBOUCUSIP
+QUANTITY
+-20,000,000
+DEBIT AMOUNT
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+September 30,2003
+DEBIT AMOUNT
+19,775,000.00
+3,415.30
+39,806.250.00
+30,191.26
+$-59,614,856.56
+19,750,000.00
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of 8
+Transaction Detail (continued)
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+SETLEMENT
+TRADE
+DATE
+TD/17/03
+TRANSACTION
+JOURNAL
+DESCRIPTION
+UNITED STATES TREASURY NOTE
+FITG
+TOTAL
+MISCELLANEOUS
+MATTAY
+10/06/03
+10/10/03
+10/20/03
+1021/03
+TOTAL
+TRANSACTION
+JOURNAL
+URNA
+IOURNAL
+JOURNAL
+DESCRIPTION
+FITG TO FITM
+-ITG FITM
+FITG FITM
+FITG FITM
+SYMBOUCUSIP
+QUANTITY
+-40,000,000
+DEBIT AMOUNT
+STOP
+****** End of Statement******
+027
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 30,2003
+39,700,000.00
+$59,450,000.00
+DEBIT AMOUNT
+CRECIT AMOUNT
+1,338.00
+69,463.00
+38,459.00
+126,398.00
+$235,658.00
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary.............................
+Your Portfolio Holdings
+Transaction Detail
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 29, 2003
+3
+3
+4
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+657
+$657
+751
+-94
+Cash & Equivalent
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$657
+# $751
+Current market value
+Last statement's market value
+Important Message
+Bear Stearns is pleased to
+announce our conversion to
+a calendar month-end
+statement. Effective this
+month, your account
+statement reflects all
+activity and account
+valuation up to and
+including the last business
+day of the month.
+SPC This suremenis foul be ratanal purposes records Se reverse dide a ra portant information.
+10/01/03;10:54 001
+
+
+2 of 4
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+10/01/03;10:54 001
+
+
+3 or a
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest Charged
+Amount Debited
+Net Cash Activity
+Closing Balance
+Cash Balance Summary
+Margin
+••••••••••••••••••••••
+Net Cash Balance
+OPENING
+751.35
+$751.35
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERIOD
+$751.35
+-94.30
+$ 94.30
+-94.30
+$657.05
+CLOSING
+657.05
+357.
+Income Summary
+THIS PERIOD
+U.S. Govt. Bond Int.
+0.00
+Credit Balance Int.
+0.00
+Reverse Repurchase Int.
+0.00
+Total
+$0.00
+Bond Purchase Int.
+0.00
+Margin Int. Paid
+-94.30
+Repurchase Int. Exp.
+0.00
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+YEAR TO DATE
+2,069,036.57
+225.80
+32,666.67
+52.101.929.04
+-498,772.20
+-94.30
+-211,768.62
+657
+$65
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+QUANTITY
+FRICE
+MARKET
+VALUE
+657
+$657
+ESTIMATED
+ANNUAL INCOME
+CURRE
+ELD I
+027
+10/01/03:10:54001
+LEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 29, 2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debit balance andor short
+
+
+4 of 4
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+INTEREST
+DATE
+DESCRIPTION
+09/02/03
+AVG BAL 34,583RT 2.887
+021 OFFICE INTEREST 0803
+TOTAL
+SYMBOUCUSIP
+STOP
+****** End of Statement******
+QUANTITY
+$657
+RATE (%)
+027
+DEBIT AMOUNT
+94.30
+$-94.30
+10/01/03;10:54 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 29, 2003
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary.........................
+Your Portfolio Holdings
+... .
+Transaction Detail
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29,2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+Juty 25, 2003
+3
+4
+4
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+751
+$751
+1
+751
+There are no "Stop Loss' orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent -
+| $1
+$751
+Current market value
+Last statement's market value
+Important Message
+Bear Stearns is pleased to
+announce our conversion to
+a calendar month-end
+statement. Effective
+September 2003,your
+account statement will
+reflect all activity and
+account valuation up to and
+including the last business
+day of the month.
+This summary is for informational purposes only. It is not intended as a tax documen
+TPC This statement should be retained for your recards. See reverse side for important information
+09/30103;13:15 001
+
+
+2 of 7
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+08/30/03:13:15 001
+
+
+3 or 7
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERICO
+$0.80
+*...
+85,869,531.25
+388.417.32
+2,942,938.00
+$89,200,886.57
+.......
+-89,065,558.14
+-134,577.88
+5 89.200.136.02
+750.55
+•....
+$751.35
+Income Summary
+U.S. Govt. Bond Int.
+Credit Balance Int.
+Reverse Repurchase Int.
+Total
+Bond Purchase Int.
+Repurchase Int. Exp.
+THIS PERIOD
+388,417.12
+0.20
+0.00
+$388.417.32
+0.00
+-40,558.14
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+0.80
+$0.80
+CLOSING
+751.35
+......
+$751.35
+027
+YEAR TO DATE
+2,069,036.57
+225.80
+32,666.67
+52.101.929.04
+-498,772.20
+-211,768.62
+751
+... $751
+08/30/03:13:15001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 25, 2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+4 of 7
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SIMBOUCUSIP
+QUANTITY
+Transaction Detail
+INVESTMENT ACTIVITY
+SETILEMENT TRADE
+DATE
+DATE
+07/28/03
+07/25/03
+TRANSACTION
+SOLD
+07729/03
+07/28/03
+SOLD
+DESCRIPTION
+UNITED STATES TREASURY NOTE
+DUE 0501512013_03,625% MN 15
+OVER REAVERSO MATURITY
+ONE 2003 02,625% MAN T5
+YIELD
+3.0В0ЖТО MATUBIT
+VER AFE #
+PRICE
+MAKE
+ALU
+751
+$751
+SYMBOL/CUSIP
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 25, 2003
+ESTIMATED
+ANNUAL INCOME
+URRE
+ELD I
+$751
+QUANTIT
+-10,000,000
+-10,000,000
+PRICE
+95.98438
+ACCR. INT.
+97.98438
+ACCR. INT.
+DEBIT AMCUNT
+9,598,437.50
+72,894.02
+9,798,437.50
+53,498.64
+027
+09/30103;13:15 001
+V912
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+5 of 7
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+DATE
+TRANSACTION
+07/30/03 07/29/03
+SOLD
+UNITED STATES TREASURY NOTE
+DUE 05015/2013 03.625% MN 15
+HELD 4,328B TO MATUBIT
+VER REF #
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+07/28/03
+AVG BAL
+1,522RT 0.215
+021 OFFICE INTEREST 0703
+TOTAL
+SYMBOUCUSIP
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS
+with Bear, Stearns& Co.Inc.
+SALEMENT
+07/28/03
+TRADE
+DATE
+TRANSACTION
+JOURNAL
+DESCRIPTION
+UNITED STATES TREASURY NOTE
+FITG
+07728/03
+JOURNAL
+07/28/03
+INTEREST
+UNITED STATES TREASURY NOTE
+FITG
+3,625 DUE 05/15/15
+TERM REPO AGREEMENT
+............
+VITED STATES TREASURY NO
+DUE 05/15/2012
+3.625
+FITG
+REPO INTEREST
+SYMBOL/CUSP
+QUANTITY
+-35,000,000
+PRICE
+94.42188
+ACCR. INT.
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 25,2003
+DEBIT AMOUNT
+33,047,656.25
+262,024.46
+$52.832.948.37
+QUANTITY
+RATE (%)
+DEBIT AMOUNT
+0.20
+$0.20
+SYMBOUCUSIP
+QUANTITY
+-35,000,000
+45,000,000
+027
+DEBIT AMOUNT
+45,450,000.00
+32,105.38
+09:3003;13:15 001
+33,425,000.00
+V912
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of 7
+Transaction Detail (continued)
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+BELEMENT
+TRADE
+DATE
+TRANSACTION
+07/29/03
+JOURNAL
+07/29/03
+INTEREST
+07/30/03
+JOURNAL
+07/30/03
+NTERES
+DESCRIPTION
+UNITED STATES TREASURY NOTE
+FITG
+TEAM REPO AGREEMENT
+DUE STATE TREASURY NOTE
+REPO INTEREST
+UNITED STATES TREASURY NOTE
+SER REPO AGREEMENT
+........
+UNITED STATES TREASURY NOTE
+DUE 05415/2013
+3.625
+FITG
+REPO INTEREST
+TOTAL
+MISCELLANEOUS
+07/29/03
+TRANSACTION
+RECEIVED
+07/29/03
+27/30/03
+07/31/03
+08/01/03
+JOURNAL
+JOURNAL
+JOURNAL
+DESCRIPTION
+FRANCING NET PA OF DIFF
+FITM TO FITG
+FITM TO FITG
+"FITM TO FITG
+FITM TO FITG
+SYMBOUCUSIP
+QUANTITY
+10,000,000
+35,000,000
+DEBIT AMOUNT
+10,150,000.00
+8,151.01
+'33.425,000.00
+301.75
+$-89,065,558.14
+DEBIT AMOUNT
+126.88
+CRECIT AMOUNT
+531,596.00
+1,856,257.00
+305,085.00
+•••••••••/••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••/
+250,000.00
+027
+09/30103;13:15 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 25,2003
+$33,425,000.00
+
+
+7 of 7
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 25, 2003
+Transaction Detail (continued)
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+08/11/03
+TOTAL
+TRANSACTION
+JOURNAL
+DESCRIPTION
+FITG TO FITM
+DEBIT AMOUNT
+134,451.00
+$-134,577.88
+CRECIT AMOUNT
+$2,942,938.00
+STOP
+****** End of Statement******
+027
+08/30/03:13:15 001
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary....
+Your Portfolio Holdings
+Transaction Detail ......
+............
+Trades Not Yet Settled
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 27, 2003
+3
+3
+5
+Hollandlold
+FINANCIAL TRUST CO INC
+CIO JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+1
+....
+2,221
+-2,220
+There are no "Stop Loss' orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent — $1
+$2.221
+Current market value
+Last statement's market value
+This summary is for informational purposes only. It Is not intended as a tax documen
+Ce tatement should be retained for our records. See revere side for important information
+07/26/03:10:09001
+V811
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+07/26/03:10:09 001
+V911
+
+
+3 of 5
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Miscellaneous
+Amount Debited.
+Net Cash Activity
+Closing Balance
+THIS PERIOD
+2,221.21
+... ..
+11.60
+$11.60
+-2,232.00
+
+-2,220.40
+50.30
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+2,221.20
+$2.221.20
+CLOSING
+0.80
+$0.80
+..... .
+Income Summary
+U.S. Govt. Bond Int.
+Credit Balance Int.
+Reverse Repurchase Int.
+Total
+Bond Purchase Int.
+Repurchase Int. Exp.
+THIS PERICO
+0.00
+11.60
+0.00
+$11.60
+0.00
+0.00
+YEAR TO DATE
+1,680,619.45
+225.60
+32,666.67
+51.713.511.72
+-498,772.20
+-171,210.48
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+QUANTITY
+PRICE
+STIMATE
+INUAL INCON
+1
+$1
+027
+07/26/03:10:09 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 27, 2003
+V811
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PRICED PORTFOLIOHOLDINGS
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearnsand Co. Inc. outstanding as of date of statement
+URCHASE
+START DATE
+DEPURCHASE
+PRICING
+PURCHASE PRICES
+ACCRUED REPO
+RATE
+PRINCIPAL
+INTEREST
+05/28/03
+OPEN
+0.200
+-45,450,000
+-32,105
+YOU SOLD
+(REPO)
+YOU SOLD
+(REPO)
+06/20/03 OPEN
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASETRANSACTIONS
+'As of statement date
+0.750
+-10,150,000
+$0
+$-55,600,000
+8.066
+$0
+$-40,171
+$1
+QUANTITY
+(FACE AMOUNT)
+45,000,000
+CUSP
+-10,000,000
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 27, 2003
+DESCRIPTION
+USTR
+USTR
+3.6250 05/15/13
+2.6250 05/15/08
+07/26/03:10:09 001
+V911
+
+
+5 or 5
+Transaction Detail
+INTEREST
+DATE
+DESCRIPTION
+06/30/03
+AVG BAL 30,056RT 0.496
+021 OFFICE INTEREST 0603
+TOTAL
+MISCELLANEOUS
+JATE
+MO/DAY
+07/21/03
+TOTAL
+TRANSACTION
+JOURNAL
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUGUSIP
+DESCRIPTION
+FITG TO FITM
+Trades Executed Pending Settlement
+ELEMENT THE
+DATE
+07/28/03
+07/25/03
+TRANSACTION
+SOLD
+TOTAL
+DESCRPTION
+UNITED STATES TREASURY NOTE
+DIE 0511503013.03.625% MN 15
+VELD CANO MATUBITY
+GVER REF #
+The atrove trades do not appear in arry other section of this statemere.
+QUANTITY
+RATE (%)
+DEBIT AMOUNT
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 27, 2003
+11.60
+$11.60
+DEBIT AMOUNT
+2,232.00
+$-2,232.00
+SYMBOLICUSIP
+QUANTITY
+-10,000,000.00
+PRICE
+95.9843
+DEBIT AMOUNT
+$0.00
+9,671,331.52
+$9.671,331.52
+07/26/03;10:09 001
+4911
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary.....
+Your Portfolio Holdings
+Transaction Detail
+...... ..
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 30, 2003
+3
+4
+5
+Hollandlold
+FINANCIAL TRUST CO INC
+CIO JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+2,221
+$2,221
+- 1
+2,222
+Cash & Equivalent —
+There are no "Stop Loss' orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$-1
+$2.221
+Current market value
+Last statement's market value
+• Short market value
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+4909
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+06/28/03:11:39 001|
+4909
+
+
+3 ore
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+Securities Bought
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance,
+THIS PERICO
+5091
+20,506,250.00
+103,619.09
+$20,609,869.09
+-20,309,005.63
+-25,679.35
+-272,962.00
+$ 20.607,646.98
+2,222.11
+$2.221.20
+Income Summary
+U.S. Govt. Bond Int.
+Credit Balance Int.
+Reverse Repurchase Int.
+Total.
+Bond Purchase Int.
+Repurchase Int. Exp.
+THIS PERIOD
+103,591.16
+27.93
+0.00
+$103,619.09
+-25,679.35
+-23,068.13
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+Cash Balance Summary
+Margin
+Net Cash Balance
+OFENING
+-0.91
+$-0.91
+CLOSING
+2,221.20
+$2,221.20
+027
+YEAR TO DATE
+1,680,619.45
+214.00
+32,666.67
+$1,713,500.12
+-498,772.20
+-171,210.48
+2,221
+$2.221
+LEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 30,2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+V908
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SIMBOUCUSIP
+QUANTITY
+PRICE
+YOUR PRICEDPORTFOLIOHOLDINGS
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearnsand Co. Inc. outstanding as of date of statement
+URCHASE
+REPURCHASE
+TART DATE
+DATE
+PRANE PURCHASE COPAL
+ACCRUED REPO
+PRINCIPAL
+INTEREST
+YOU SOLD
+(REPO)
+05/28/03
+OPEN
+0.200
+-45,450,000
+-25,035
+YOU SOLD
+(REPO)
+06/20/03 OPEN
+0.940
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASE TRANSACTIONS
+As of slatement das
+-10,150,000
+$0
+$-55,600,000
+-3,030
+$0
+$-28,065
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 30,2003
+WAKE
+VALU
+2,221
+$2,221
+ESTIMATED
+ANNUAL INCOME
+$2,221
+QUANTITY
+(FACE AMOUNT)
+-45,000,000
+-10,000,000
+CUSP
+DESCRIPTION
+USTR
+USTR
+3.6250 05/15/13
+2.6250 05/15/08
+027
+4909
+
+
+5 or 8
+Transaction Detail
+INVESTMENT ACTIVITY
+SATE EMENT TATE
+DATE
+06/20/03 06/19/03
+TRANSACTION
+SOLD
+06/20/03 06/19/03 BOUGHT
+TOTAL
+INTEREST
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRUPTION
+UNEED STATES 0,00% FA 15
+EVER REP HERO MATUETY
+JELD 242765310 MATIBIT
+VER REF # |
+DATE
+06/02/03
+TOTAL
+DESCRIPTION
+AVG BAL
+60,963RT 0.550
+021 OFFICE INTEREST 0503
+SYMBOL/CUISIP
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS
+with Bear, Stearns& Co.Inc.
+SALEMENT
+TRADE
+DATE
+06/20/03
+TRANSACTION
+JOURNAL
+DESCRIPTION
+UNITED STATES TREASURY NOTE
+FITG
+3,000 DUSTRA
+RP TERM
+TERM REPO AGHEEMENT
+SYMBOLCUSIP
+QUANTITY
+-10,000,000
+10,000,000
+ACCR. INT.
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 31, 2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 30, 2003
+PRICE
+103.56250
+ACCR. INT.
+DEBIT AMOUNT
+10,356,250.00
+103,591.16
+101.60938
+10,160,937.50
+25,679.35
+$-10,186,616.85
+$10,459,841.16
+QUANTITY
+RATE (S)
+DEBIT AMOUNT
+27.93
+$27.93
+SYMBOUGUSIP
+QUANTITY
+10,000,000
+DEBIT AMOUNT
+10,125,000.00
+027
+06/28/03:11:38 001
+V90e
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of 8
+Transaction Detail (continued)
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+BELEMENT
+TRADE
+DATE
+06/20/03
+TRANSACTION
+JOURNAL
+06/20/03
+INTEREST
+DESCRIPTION
+UNITED STATES TREASURY NOTE
+FITG
+IP OPEN
+REPO AGREEMENT
+UNITED STATES TREASURY NOTE
+PIE 0215/2008
+3.000
+AP TERM
+REPO INTEREST
+TOTAL
+MISCELLANEOUS
+DATE
+MODAY
+06/24/03
+TOTAL
+TRANSACTION
+JOURNAL
+DESCRIPTION
+FITG TO FITM
+SYMBOUGUSIP
+QUANTITY
+-10,000,000
+DEBIT AMOUNT
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 30,2003
+10,150,000.00
+- 23,068.13
+... . ..
+$-10,148,068.13
+$10,150,000.00
+DEBIT AMOUNT
+272,962.00
+$-272,962.00
+STOP
+****** End of Statement******
+027
+V908
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary .............................
+Your Portfolio Holdings
+.. . .
+Transaction Detail
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 25,2003
+3
+4
+5
+Hollandiml
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET DEBIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+- 1
+$-1
+....
+11
+-12
+There are no "Stop Loss' orders or other pending buy
+or sell open orders on file for your account.
+Cash & Equivalent
+Market Value of Your Portfolio
+$-1
+Last statement's market value
+Short market value
+$11
+This summary is for informational purposes only. It is not intended as a tax documen
+PC This statement should be retained ter our red le See reense did a important information
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+$11.02
+.. . .
+117,550,000.00
+359,668.51
+362,114.00
+$118,271,782.51
+-116,406,221.90
+-36,939.54
+-1,828,633.00
+5 118.271.794.44
+-11.93
+$-0.91
+Income Summary
+U.S. Govt. Bond Int.
+Credit Balance Int.
+Reverse Repurchase Int.
+Total
+Bond Purchase Int.
+Repurchase Int. Exp.
+THIS PERIOD
+359,668.51
+0.00
+0.00
+$359,668.51
+-36,939.54
+-46,126.50
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+SHORT
+1
+51.
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+11.02
+$11.02
+CLOSING
+0.91
+......
+$-0.9
+027
+YEAR TO DATE
+1,577,028.29
+186.07
+32,666.67
+1.609.881.03
+-473,092.85
+-148,142.35
+LONG
+-......
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 25,2003
+Your Portfolio
+Allocation
+Short Cash & Equivalent
+100%
+Unshaded portions denote debe balance andor short
+from the absolute market value of your portolio.
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+QUANTITY
+PRICE
+YOUR PRICEDPORTFOLIOHOLDINGS
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearnsand Co.Inc. outstanding as of date of statement
+JACHASE
+AEFUACHASE
+TART DAT
+DATE
+PRICING
+PURCHASE PRICE
+ACCAUED REPO
+RATE
+PRINCIPAL
+INTEREST
+YOU SOLD
+(REPO)
+03/14/03
+OPEN
+0.950
+YOU SOLD
+(REPO)
+05/28/03 OPEN
+1.200
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASE TRANSACTIONS
+"As of statement date
+-10,125,000
+45,450,000
+$0
+$-55,575,000
+- 17,502
+-7,448
+$0
+$-24,950
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 25,2003
+MAKE
+ALU
+-1
+$-1
+ESTIMATED
+ANNUAL INCOME
+JAREN
+ELD I
+$-1
+QUANTITY
+(FACE AMOUNT)
+-10,000,000
+CUSP
+DESCRIPTION
+USTR
+USTR
+3.0000 02/15/08
+3.6250 05/15/13
+-45,000,000
+027
+
+
+5 ore
+Transaction Detail
+INVESTMENT ACTIVITY
+SATE EMENT TATE
+DATE
+TRANSAGTION
+05/22/03
+05/21/03
+SOLD
+ö5/22/63*""65/21703*•"BOUGHT
+05/28/03
+05/13/03
+BOUGHT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+JNITED STATES TREASURY NOTE
+UE 02/15/2013 03_875% FA 19
+YIELD 3.359 4T0 MATURITY
+GVER REF # I
+'UNITED STATES TREASUAY NOTE'
+DUE 05/15/2013 03.625% MN 15
+HELD 3,373 70 MATURIT
+OVER REF #
+UNITED STATES TREASURY NOTE
+DUE 05/15/2013 03,625% MN 15
+YIELD 3.411 TO MATURITY
+GVER REF #
+AS OF 05/13/03
+TOTAL
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS
+with Bear, Stearns& Co.Inc.
+SETILEMENT
+DATE
+05/22/03
+TRADE
+DATE
+TRANSACTION
+JOURNAL
+05/22/03
+JOURNAL
+DESCRIPTION
+FITG UNITED STATE TREASURY NOTE
+3,875 DUE0215HВ
+AP TERM
+TERM REPO AGHEEMENT
+UNITED STATES TREASURY NOTE
+AP OPEN
+REPO AGREEMENT
+SYMBOLGUSP
+QUANTITY
+-35,000,000
+"35,000,000*
+ACCR. INT.
+10,000,000
+ACCR. INT.
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 25,2003
+PRICE
+104.25000
+ACCR. INT.
+DEBIT AMOUNT
+36,487,500.00
+359,668.51
+'102.72259****
+35,742,907.90
+24,133.83
+101.79688
+10,179,687.50
+12,805.71
+$45,959.534.94
+$36,847,168.51
+SYMBOL/GUSIP
+QUANTITY
+35,000,000
+35,000,000
+DEBIT AMOUNT
+34,825,000.00
+35,612,500.00
+027
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of 8
+Transaction Detail (continued)
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+SETLEMENT
+05/22/03
+TRADE
+DATE
+TRANSACTION
+INTEREST
+DESCRIPTION
+SYMBOUGUSIP
+DUE GHER STATES TREASURY NOTE
+REPO INTEREST
+65/28/89**
+05/28/03
+"JOURNAL
+05/28/03
+INTEREST
+3,625 DUE 034513)
+AP TERM
+TERM REPO AGREEMENT
+FIG NEGATE FREASURY NOTE
+3,625 DUE0545H5
+AP OPEN
+REPO AGREEMENT
+DUE STE SIES, TEASURY NOTE
+AP TERM
+REPO INTEREST
+TOTAL
+MISCELLANEOUS
+DATE
+MODAY
+TRANSACTION
+05/27/03
+JOURNAL
+0529/03 JOURNAL
+TOTAL
+DESCRIPTION
+FITG TO FITM
+DEBIT AMOUNT
+1,828,633.00
+........
+$-1.828,633.00
+QUANTITY
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 25,2003
+DEBIT AMOUNT
+39,004.00
+**•''35612,500.00•••••••••••••••••
+# 35,000,800
+45,000,000
+5,450,000.0
+7,122.50
+$-70,483,626.50
+$81,062,500.00
+CRECIT AMOUNT
+362,114.00
+$362,114.00
+027
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary .............................
+Your Portfolio Holdings
+. . . .
+Transaction Detail
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 29, 2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 28,2003
+3
+3
+5
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+11
+$11
+......
+1
+10
+There are no "Stop Loss' orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent -
+$11
+$1
+Current market value
+Last statement's market value
+This summary is for informational purposes only. It Is not intended as a tax documen
+PC This statement should be retained for poser records. See reverse side for important information
+04/26/03:11:48001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 of 5
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERIOD
+$0.80
+....
+10.22
+$10.22
+10.22
+501.02
+Income Summary
+U.S. Govt. Bond Int.
+Credit Balance Int.
+Reverse Repurchase Int.
+Total
+Bond Purchase Int.
+Repurchase Int. Exp.
+THIS PERIOD
+0.00
+10.22
+0.00
+$10.22
+0.00
+0.00
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+0.80
+$0.80
+CLOSING
+11.02
+$11.02
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+QUANTITY
+PRICE
+11
+$11
+027
+YEAR TO DATE
+1,217,359.78
+186.07
+32,666.67
+$1.250.
+-436,153.31
+-102,015.85
+11
+_SII
+04/26/03:11:48001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 29, 2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 28,2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+from the absolute market value of your portfolio.
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PRICEDPORTFOLIOHOLDINGS
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearnsand Co. Inc. outstanding as of date of statement
+URCHASE
+REPURCHASE
+TART DATE
+DATE
+PRATE PURCHASE NEPAL
+PRINCIPAL
+ACCRUED REFC
+INTEREST
+YOU SOLD
+(REPO)
+03/14/03
+OPEN
+0.700
+-10,125,000
+YOU SOLD
+(REPO)
+03/19/03 OPEN
+0.600
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASE TRANSACTIONS
+-As of statement done
+-34,825,000
+$0
+$44,950,000
+-11,266
+-24,880
+$0
+$-36,146
+$11
+QUANTITY
+(FACE AMOUNT)
+-10,000,000
+CUSP
+-35,000,000
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 29,2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 28, 2003
+DESCRIPTION
+USTR
+USTR
+3.0000 02/15/08
+3.8750 02/15/13
+
+
+Transaction Detail
+INTEREST
+DATE
+DESCRIPTION
+03/31/03
+AVG BAL 27,103RT 0.566
+021 OFFICE INTEREST 0303
+TOTAL
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUGUSIP
+QUANTITY
+RATE (%)
+STOP
+*** End of Statement*****
+027
+DEBIT AMOUNT
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 29,2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 28,2003
+10.22
+$10.22
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary............................
+Your Portfolio Holdings
+. . . .
+Transaction Detail
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+February 28, 2003
+3
+3
+5
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+1
+48,708
+-48,708
+There are no "Stop Loss' orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent Sla
+$48,708
+Current market value
+Last statement's market value
+This summary is for informational purposes only. It Is not intended as a tax documen
+PC This statement should be retained for poser records. See reverse side for important information
+
+
+2 of 7
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or 7
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance,
+THIS PERIOD
+$48,708.36
+.. . .
+110,277,979.17
+479,612.15
+132,879.00
+S110,890470.32
+.....
+-110,578,841.60
+-197,479.28
+-162,857.00
+5110999.177. 88
+-48,707.56
+*....
+.$0.80
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+48,708.36
+$48,708.36
+CLOSING
+0.80
+......
+$0.80
+Income Summary
+THIS PERIOD
+U.S. Govt. Bond Int.
+479,558.01
+Credit Balance Int.
+54.14
+Reverse Repurchase Int.
+32,666.67
+Total
+512,278.8
+Bond Purchase Int.
+- 197,479.28
+Repurchase Int. Exp.
+-32,747.85
+YEAR TO DATE
+1,217,359.78
+175.85
+32,666.67
+$1.250.202.30
+-436,153.31
+- 102,015.85
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+QUANTITY
+FRICE
+MARKET
+VALUE
+1
+$1
+ESTIMATED
+ANNUAL INCOME
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+February 28, 2003
+
+
+4 of 7
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PRICEDPORTFOLIOHOLDINGS
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearnsand Co. Inc. outstanding as of date of statement
+URCHASE!
+REPURCHASE
+TART DATE
+DATE
+PRATE PURCHASE NEPAL
+PRINCIPAL
+ACCRUED REPO
+INTEREST
+YOU SOLD
+(REPO)
+03/14/03
+OPEN
+0.950
+-10,125,000
+YOU SOLD
+(REPO)
+03/19/03 OPEN
+0.900
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASE TRANSACTIONS
+-is of statement dans
+-34,825,000
+$0
+$44,950,000
+-3,974
+-6,287
+$0
+$-10,261
+$1
+QUANTITY
+(FACE AMOUNT)
+-10,000,000
+CUSP
+-35,000,000
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+February 28, 2003
+DESCRIPTION
+USTR
+USTR
+3.0000 02/15/08
+3.8750 02/15/13
+03/29/03:10:54001
+
+
+5 of 7
+Transaction Detail
+INVESTMENT ACTIVITY
+SATE EMENT TATE
+DATE
+TRANSACTION
+03/13/03
+03/12/03
+BOUGHT
+63/13/03*****
+''DELIVERED"
+03/14/03
+03/13/03
+BOUGHT
+03/19/03
+03/18/03
+SOLD
+.. . .
+03/19/03
+03/18/03
+BOUGHT
+TOTAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+UNITED STATES TREASURY NOTE
+DUE 01/31/2005 01.625% JJ 31
+PECIAL INSTRUCTION
+VER 76% TO MATURIT
+1,625
+RS TERM
+TERM RESALE AGREEMENT
+UNITED STATES TREASURY NOTE
+DUE 02/15/2008 03.000% FA 15
+YIELD 27305370 MATUBITY
+GVER REF #
+"UNITED STATES TREASURY NOTE
+DUE 11152012 01.000% MN 15
+YIELD 3.89453T0 MATURITY
+GVER REF #
+0:02820130575 A 154
+YIELD 3.893E3T0 MATUBITY
+GVER REF #
+SYMBOLGUSIF
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+February 28,2003
+DEBIT AMOUNT
+30,138,281.25
+55,214.09
+QUANTITY
+30,000,000
+ACCR. INT.
+:30,000,0Öö
+PRICE
+100.46094
+.........••*..
+30,000,000.00
+0,000,000
+ACCR. INT.
+:35,000,000
+35,000,000
+ACCR. INT.
+101.23438
+100.84375"
+ACCR. INT.
+99.81250
+10,123,437.50
+22,375.69
+35,295,312.50
+479,558.01
+34,934,375.00
+119,889.50
+$-75,393,573.03
+$65.774,870.51
+03/29103;10:54 001
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of 7
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+03/03/03
+AVG BAL 120,072RT 0.580
+021 OFFICE INTEREST 0203
+TOTAL
+SYMBOUCUSIP
+SEASE TRANSACTIONS
+SETILEMENT
+DATE
+03/13/03
+TRADE
+DATE
+TRANSACTION
+INTEREST
+03714/03
+JOURNAL
+DESCRIPTION
+DUE DIET STATES TREASURY NOTE
+FITG
+AS TERM
+RESALE INTEREST
+FIND STARE TREASURY NOTE
+3,000 DUE 021508
+RP OPEN
+REPO AGREEMENT
+03/19/03
+"JOURNAL
+03/19/03
+JOURNAL
+0319/03
+INTEREST
+4,000 DUESTSEIR
+AP TERM
+TERM REPO AGREEMENT
+NEE REASURY NOTE
+3.875 DUE NOISER
+AP OPEN
+REPO AGREEMENT
+DUE INTER STATES RESURY NOTE
+AP TERM
+REPO INTEREST
+TOTAL
+QUANTITY
+SYMBOUCUSIP
+RATE (%)
+DEBIT AMOUNT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28,2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+February 28, 2003
+54.14
+$54.14
+QUANTITY
+10.000,000
+35.000,000
+-35,000,000
+DEBIT AMOUNT
+32,666.67
+10,125,000.00
+''35,350,000.00
+34.825,000.00
+32,747.85
+$-35,382,747.85
+$44.982.666.67
+027
+03/29103;10:54 001
+
+
+7 of 7
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD March 1, 2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+February 28, 2003
+Transaction Detail (continued)
+MISCELLANEOUS
+DATE
+MO/DAY
+03/14/03
+03/17/03
+03/20/03
+TRANSACTIO
+OURNAL
+JÖUANAL"
+JOURNAL
+DESCRIPTION
+FITM TO FITG
+"FIT TO FITG
+"FIG TO FITNI
+DEBIT AMOUNT
+162,857.00
+$-162,857.00
+112.066.00
+20,813.00
+$132,879.00
+STOP
+****** End of Statement******
+027
+
+
+OFFICE SERVICING YOUR ACOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summar...........................
+Your Portfolio Holdings
+Transaction Detail
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD February 1,2003
+THROUGH
+February 28,2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+January 31,2003
+3
+4
+5
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+48,708
+$48,708
+220,616
+-171,908
+Cash & Equivalent
+There are no "Stop Loss' orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$48.708
+Current market value
+Last statement's market value
+$220.616
+This summary is for informational purposes only. It is not intended as a tax documen
+PC see aatement should be retained for vour records. See reverte side for important information
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or 5
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance,
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+5220.616.16
+29,936,718.75
+5,508.45
+
+-30,114,135.00
+#-30,114,135.00
+-171,907.80
+548.708.36
+Income Summary
+U.S. Govt. Bond Int.
+Credit Balance Int.
+Bond Purchase Int.
+Repurchase Int. Exp.
+THIS PERIOD
+5,386.74
+121.71
+55,508.45
+0.00
+0.00
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+220,616.16
+$220,616.16
+CLOSING
+48,708.36
+$48,708.36
+027
+YEAR TO DATE
+737,801.77
+121.71
+.....
+$737,923.48
+... . .
+-238,674.03
+-69,268.00
+48,708
+$48,708
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD February 1, 2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+January 31,2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLICUSIP
+QUANTITY
+PRICE
+YOUR PRICEDPORTFOLIOHOLDINGS
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearnsand Co. Inc. outstanding as of date of statement
+JACHASE
+AEPUACHASE
+TART DAT
+DATE
+PRICING
+PURCHASE PRICE
+ACCAUED REPO
+RATE
+PRINCIPAL
+INTEREST
+YOU SOLD
+(REPO)
+01/23/03
+OPEN
+0.700
+-35,350,000
+YOU BOUGHT
+(REVERSE)
+02/04/03 OPEN
+1.150
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASE TRANSACTIONS
+"As of statement date
+30,000,000
+$30,000,000
+$-35,350,000
+- 16,005
+23,700
+$23,700
+$-16,005
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD February 1, 2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+January 31,2003
+MARKET
+VALUE
+48,708
+$48,708
+ESTIMATE
+NUAL INCON
+$48,708
+QUANTITY
+(FACE AMOUNT)
+-35,000,000
+CUSP
+30,000,000
+DESCRIPTION
+USTR
+USTR
+4.0000 11/15/12
+1.6250 01/31/05
+027
+VE41
+
+
+5 ors
+Transaction Detail
+INVESTMENT ACTIVITY
+SATE EMENT TATE
+DATE
+02/04/03
+02/03/03
+TRANSAGTION
+SOLD
+02/04/03
+RECEIVED
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+02/03/03
+AVG BAL
+AZI DICE INTEREST 010561
+TOTAL
+MISCELLANEOUS
+DATE
+MODAY
+02/21/03
+TOTAL
+TRANSACTION
+JOURNAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+UNITED STATES TREASURY NOTE
+1.525 0 015 roS
+1.625
+RESALE AGREEMENT
+SYMBOL/CUISIP
+DESCRIPTION
+FITG TO FITM
+SYMBOLGUSIF
+QUANTITY
+RATE (%)
+DEBIT AMOUNT
+114,135.00
+$-114,135.00
+027
+QUANTITY
+-30,000,000
+30,000,000
+DEBIT AMOUNT
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD February 1, 2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+January 31,2003
+PRICE
+99.78906
+ACCR. INT.
+DEBIT AMOUNT
+29,936,718.75
+5,386.74
+30,000,000.00
+$-30,000,000.00
+$29,942,105.49
+121.71
+$121.71
+VE41
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summar...........................
+Your Portfolio Holdings
+Transaction Detail
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+December 31, 2002
+3
+4
+5
+Hollandlol
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+220,616
+$220,616
+220,616
+There are no "Stop Loss' orders or other pending buy
+or sell open orders on file for your account.
+Cash & Equivalent -
+Market Value of Your Portfolio
+$0
+S220.616
+Current market value
+Last statement's market value
+This summary is for informational purposes only. It Is not intended as a tax documen
+Ce tatement should be retained for our records. See revere side for important information
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERIOD
+50.15
+121,617,968.75
+732,415.03
+4,463.41
+S122,354,847.19
+.....
+- 121,481,768.00
+-238,674.03
+-413,789.15
+$ 122.134.231.18
+220,616.01
+$220.616.16
+Income Summary
+U.S. Govt. Bond Int.
+Total.
+Bond Purchase Int.
+Repurchase Int. Exp.
+THIS PERIOD
+732,415.03
+3732415.03
+-238,674.03
+69,268.00
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+0.15
+$0.15
+CLOSING
+220,616.16
+....
+220,616.16
+027
+YEAR TO DATE
+732,415.03
+... .
+$732.415.03
+-238,674.03
+-69,268.00
+220,616
+$220,616
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 1, 2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+December 31, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+QUANTITY
+PRICE
+YOUR PRICEDPORTFOLIOHOLDINGS
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearnsand Co.Inc. outstanding as of date of statement
+PRIATE PURCHASE NGON
+ACCAUED REPO
+PRINCIPAL
+INTEREST*
+YOU SOLD
+(REPO)
+01/23/03 OPEN
+0.850
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASE TRANSACTIONS
+Is of statement date
+-35,350,000
+$0
+$-35,350,000
+-5.106
+$0
+$-5,106
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 1, 2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+December 31, 2002
+MARKET
+VALUE
+220,616
+$220,616
+ANUAL INCONS
+$220,616
+QUANTITY
+(FACE AMOUNT)
+-35,000,000
+CUSP
+DESCRIPTION
+USTR
+4.0000 11/15/12
+027
+VE40
+
+
+5 or 8
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT TRADE
+DATE
+01/08/03
+01/07/03
+TRANSAGTION
+SOLD
+ö1768703 81767703"BÖ0GAT
+01/23/03
+01/22/03
+SOLD
+TOTAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+UNITED STATES TREASURY NOTE
+DUE 08/15/2012 04,375% FA 15
+YIELD 4.046 TO MATURITY
+GVER REF #
+'UNITED STATES TREASUAY NOTE™
+DUE 11/15/2012 04.000% MN 15
+YIELD 4,0585:70 MATURITY
+GVER REF #
+YIELD 3.924% TO MATURITY
+GVER REF # G0225466 A3
+AS OF 01/22/03
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS
+with Bear, Stearns& Co.Inc.
+SETILEMENT
+DATE
+TRADE
+DATE
+01/08/03
+TRANSACTION
+JOURNAL
+01708/03
+"JOURNAL
+DESCRIPTION
+FIG UNITED STATES TREASURY NOTE
+4,375 DUE 0B7512
+AP TERM
+TERM REPO AGHEEMENT
+FIND TAE REASURY NOTE
+4,000 DUSTMEN
+RP OPEN |
+REPO AGREEMENT
+SYMBOLGUSP
+QUANTITY
+40,000,000
+40,000,000*
+ACCR. INT.
+-5,000,000
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+December 31, 2002
+PRICE
+102.59375
+ACCR. INT.
+DEBIT AMOUNT
+41,037,500.00
+694,293.48
+₫9.53125"9.812,500.00ª
+238,674.03
+100.60938
+ACCR. INT.
+$-40,051,174.03
+5,030,468.75
+38,121.55
+$46,800,383.78
+SYMBOL/GUSIP
+UANTI
+40,000,000
+40,000,000
+41-0.00
+40,200,000.00
+027
+VE40
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of 8
+Transaction Detail (continued)
+REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS (continued)
+SETTLEMENT
+TRADE
+DATE
+01/08/03
+TRANSACTION
+INTEREST
+DESCRIPTION
+DUE ONER SITES TREASURY NOTE
+AP TERM
+REPO INTEREST
+01723783*
+''JOURNAL
+ö1/23/03
+JOURNAL
+01/23/03
+INTEREST
+4,000 DUE 1115/12
+REPO AGREEMENT
+FINE STATE REASURY NOTE
+4,000 DUE THEN
+AP TERM |
+TERM REPO AGREEMENT
+DUE NESTEST SUAY NOTE
+AP TERM]
+REPO INTEREST
+TOTAL
+MISCELLANEOUS
+DATE
+MO/DAY
+TRANSACTION
+01/06/03
+JOURNAL
+01708/03 DELIVERED
+01/22/03
+01/2803
+TOTAL
+JOURNAL"
+JOURNAL
+DESCRIPTION
+FITG TO FITM
+"FiG
+COUPON 4,3750
+FINANCING NET PARORE DIFF
+FIG REBATE 2002
+SYMBOUGUSIP
+QUANTITY
+'35,000,000"
+40,000,000
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 1, 2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+December 31, 2002
+DEBIT AMOUNT
+65,918.00
+''•••••••••*35.350,000.00
+0,200,000.
+3,350.00
+$-81,669,268.00
+$75,550,000.00
+DEBIT AMOUNT
+0.15
+...... 413,789.00
+$-413,789.15
+027
+CRECIT AMOUNT
+517:50
+3,945.91
+$4,463.41
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/b7017567a06b86fa54e3e05dcf4a82dd1ea1529e3e626698d30e1a5724a06e62.receipt.json b/vision-fixhub/ds9-unparsed-05/b7017567a06b86fa54e3e05dcf4a82dd1ea1529e3e626698d30e1a5724a06e62.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9a48e89134a45a41581e5d06bb17cc711dfcc90c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b7017567a06b86fa54e3e05dcf4a82dd1ea1529e3e626698d30e1a5724a06e62.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -6960,
+  "dataset": "marble-joined",
+  "doc_id": "b7017567a06b86fa54e3e05dcf4a82dd1ea1529e3e626698d30e1a5724a06e62",
+  "engine": "marble-apple-vision",
+  "event_count": 73,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "162f4547e04548de614e584a1511404059149905d57fe20cc4b464972349fb7c",
+  "output_sha256": "44f73625f3d2e2ab7639e3bab5e7cbde23586483404788971707a6964af393ea",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b70d6ee027a095060d640555620d25b09bbeaa78c4f1df7976688349e1e9a7d2.md b/vision-fixhub/ds9-unparsed-05/b70d6ee027a095060d640555620d25b09bbeaa78c4f1df7976688349e1e9a7d2.md
new file mode 100644
index 0000000000000000000000000000000000000000..1c8934eeeadd0ee66c11c5996f6a8cfe76a5ff73
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b70d6ee027a095060d640555620d25b09bbeaa78c4f1df7976688349e1e9a7d2.md
@@ -0,0 +1,62 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+West Palm Beach, FL 33401
+500 S. Australian Ave, Ste 400
+Facsimile:
+September 18, 2009
+DELIVERY BY ELECTRONIC MAIL
+Roy Black, Esq.
+Black Srebnick Kornspan & Stumpf P.A.
+201 S. Biscayne Blvd, Suite 1300
+Miami, FL 33131
+Re: Jeffrey Epstein
+Dear Roy:
+I write in response to your letter to Mr. Sloman regarding the transfer of supervision of
+Mr. Epstein's community control to the Virgin Islands. I requested from Mr. Goldberger a copy
+of the documentation that Mr. Epstein submitted in support of his request and a copy of the
+interstate compact that you had mentioned. I have not received these documents. Rather than
+wait any longer, I am advising you of our Office's preliminary concerns. The Office may have
+additional concerns upon receipt of the requested items.
+The Non-Prosecution Agreement called for Mr. Epstein to serve eighteen months in
+county jail followed by twelve months of community control. Mr. Epstein's eighteen-month jail
+term was reduced to slightly more than twelve months based upon Mr. Epstein's "work release"
+of more than twelve hours per day, seven days per week. Mr. Epstein has been on community
+control for less than two months and he is already asking that he be allowed to transfer his
+supervision. The request comes on the heels of an instance where Mr. Epstein was found by the
+Palm Beach Police Department walking on the beach. I understand that he told the police that he
+was "walking to work," despite the fact that his "office" was more than eight miles away, and the
+beach where he was found was not en route from his residence to his workplace.
+Throughout the negotiation of the NPA, representations were repeatedly made by you and
+your colleagues that Mr. Epstein would serve his complete sentence, including community
+control, in Palm Beach County. During his change of plea and sentencing, Mr. Epstein told the
+Court that he intended to remain in Palm Beach County during his period of community control -
+a fact that was important to Judge Pucillo in making her decision whether or not to accept the
+plea agreement. Mr. Epstein's presence in Palm Beach County was important to the Court, our
+Office, and, presumably, the State Attorney's Office, because it allowed all of these entities to
+monitor Mr. Epstein's performance of his obligations. Relocating to the Virgin Islands, where
+Mr. Epstein lives on a private island without any independent law enforcement presence, would
+eliminate that ability.
+The Office's ability to determine whether Mr. Epstein has breached the NPA and to file
+charges against him when/if he breaches that Agreement was a key piece of consideration for the
+decision to enter that Agreement. Another key piece was the ability of victims to pursue claims
+against Mr. Epstein under 18 U.S.C. § 2255.
+Your September 1, 2009 letter to Mr. Sloman, in essence, asked whether it would be the
+Office's position that Mr. Epstein's move to his private island would violate the terms of the
+NPA. For the reasons stated above, even upon our preliminary review, it is the position of the
+Office that the transfer of community control would frustrate the purpose of the agreement and
+thereby violate its terms. No final decision has been made, of course, because Mr. Epstein has
+
+
+not yet moved. However, if Mr. Epstein elects to go forward with the transfer of community
+control with the knowledge of the Office's objection, that will be considered, along with all of the
+previous violations by Mr. Epstein, as set forth in my letters of June 15 and July 7, 2009, in
+determining the Office's final course of action.
+I look forward to receiving the materials requested from Mr. Goldberger.
+Sincerely,
+Jeffrey H. Sloman
+Acting United States Attorney
+By:
+Assistant United States Attorney
+cc:
+Chief, Northern Division
diff --git a/vision-fixhub/ds9-unparsed-05/b70d6ee027a095060d640555620d25b09bbeaa78c4f1df7976688349e1e9a7d2.receipt.json b/vision-fixhub/ds9-unparsed-05/b70d6ee027a095060d640555620d25b09bbeaa78c4f1df7976688349e1e9a7d2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..cc23da5a19b518420c7330a57a8f920b1d8b524e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b70d6ee027a095060d640555620d25b09bbeaa78c4f1df7976688349e1e9a7d2.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "b70d6ee027a095060d640555620d25b09bbeaa78c4f1df7976688349e1e9a7d2",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "4bb4a961316252e1d2cefae065a5572ca64c81fbc7a7e3af35e1227c19846070",
+  "output_sha256": "10cd9e732e008887e6c8e078bbda0cd2321fc21d477434a2d5d7518d1c6158e2",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b7234ed18c1c3068f9d079c9418d09a5d528267cdd0e192db307eaee93c669a7.md b/vision-fixhub/ds9-unparsed-05/b7234ed18c1c3068f9d079c9418d09a5d528267cdd0e192db307eaee93c669a7.md
new file mode 100644
index 0000000000000000000000000000000000000000..11adf52b82f89da0b4bdb8215e952d0350ad1a71
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b7234ed18c1c3068f9d079c9418d09a5d528267cdd0e192db307eaee93c669a7.md
@@ -0,0 +1,7876 @@
+FOR PUBLICATION
+UNITED STATES COURT OF APPEALS
+FOR THE NINTH CIRCUIT
+IN RE: STAKE CENTER LOCATING,
+INC., Crime Victim.
+No. 13-73267
+D.C. No.
+2:13-Cr-00089-
+JCM-GWF-1
+STAKE CENTER LOCATING, INC.,
+Petitioner,
+OPINION
+V.
+FOR THE DISTRICT OF NEVADA, LAS
+VEGAS,
+Respondent,
+DEBORAH A. DIFRANCESCO,
+Defendant-Real Party in Interest,
+UNITED STATES OF AMERICA,
+Plaintiff-Real Party in Interest.
+Petition for Writ of Mandamus to the
+United States District Court
+for the District of Nevada
+James C. Mahan, District Judge, Presiding
+
+
+2
+Submitted September 20, 2013*
+Filed September 26, 2013
+Per Curiam Opinion
+SUMMARY**
+Criminal Law
+A motions panel issued a per curiam opinion denying a
+crime victim's petition for a writ of mandamus seeking
+reversal of the district court's denial of the victim's motion
+for forfeiture under the Crime Victims' Rights Act.
+The panel explained that the Crime Victims' Rights Act
+and the Mandatory Victim Restitution Act give victims a
+right to restitution, not a right to criminal forfeiture. The
+panel also explained that the Crime Victims' Rights Act
+expressly does not impair the government's broad discretion
+to seek forfeiture of assets implicated in an offender's wire
+fraud.
+*The panel unanimously concludes this case is suitable for decision
+without oral argument. See Fed. R. App. P. 34(a)(2).
+** This summary constitutes no part of the opinion of the court. It has
+been prepared by court staff for the convenience of the reader.
+
+
+COUNSEL
+3
+Kenneth P. Childs, Stake Center Locating, Inc., Salt Lake
+City, Utah, for Petitioner.
+Elizabeth Olson White, Appellate Chief and Assistant United
+States Attorney, District of Nevada, Reno, Nevada, for
+Plaintiff-Real Party in Interest.
+Mark B. Bailus, Bailus Cook & Kelesis, Ltd., Las Vegas,
+Nevada, for Defendant-Real Party in Interest.
+OPINION
+PER CURIAM:
+Petitioner Stake Center Locating, Inc. ("Stake Center")
+petitions for a writ of mandamus reversing the district court's
+denial of its motion for forfeiture under 18 U.S.C. § 3771, the
+Crime Victims' Rights Act ("CVRA")!
+In the underlying criminal action, Deborah DiFrancesco,
+a former employee of Stake Center, was charged with crimes
+stemming from her embezzlement of funds from Stake Center
+and other victims, and pleaded guilty to one count of tax
+vasion and three counts of wire fraud. Pursuant to her plea
+agreement, DiFrancesco agreed to make restitution to Stake
+' Stake Center previously petitioned this court for mandamus, and we
+denied this petition as premature. See Stake Ctr. Locating, Inc. v. U.S.
+
+
+4
+Center in the amount of $763,846. Stake Center moved the
+district court to compel the government to institute criminal
+forfeiture proceedings and to obtain property allegedly
+traceable to DiFrancesco's crimes and thus subject to
+forfeiture from third parties. The district court denied this
+motion.
+We have jurisdiction under 18 U.S.C. § 3771(d)(3). In
+eviewing a CVRA mandamus petition, we need not balanc
+he usual factors under Bauman v. United States Distric
+Court, 557 F.2d 650, 654-55 (9th Cir. 1977), but rather "must
+issue the writ whenever we find that the district court's order
+reflects an abuse of discretion or legal error." Kenna v. U.S.
+Dist. Court, 435 F.3d 1011, 1017 (9th Cir. 2006).
+Here, the district court did not abuse its discretion or
+commit a legal error in denying Stake Center's motion for
+forfeiture.
+First, the CVRA and Mandatory Victim
+Restitution Act ("MVRA") give victims a right to restitution,
+not a right to criminal forfeiture. The CVRA provides that a
+crime victim has the "right to full and timely restitution as
+provided in law." 18 U.S.C. § 3771(a)(6). The Mandatory
+Victim Restitution Act ("MVRA") requires that a "defendant
+make restitution to the victim" of certain offenses. 18 U.S.C.
+§ 3663A(a)(1). Criminal forfeiture is not, as petitioner
+contends, a type of restitution; "[c]riminal forfeiture is ...
+separate from restitution, which serves an entirely different
+purpose." United States v. Newman, 659 F.3d 1235, 1241
+(9th Cir. 2011). Among other differences between restitution
+and forfeiture, only the criminal defendant is subject to
+restitution, not third parties. See 18 U.S.C. § 3663A(a)(1),
+(b)(1) (requiring that "defendant make restitution" and
+"defendant" return property).
+
+
+5
+Nor did the district court err in declining to order the U.S.
+Attorneys'
+Office to commence criminal forfeiture
+proceedings against the Internal Revenue Service and other
+non-parties alleged to possess assets implicated in
+DiFrancesco's criminal activities. Contrary to Stake Center's
+argument, forfeiture is mandatory for wire fraud only if the
+government exercises its discretion to seek such forfeiture.
+See 28 U.S.C. § 2461(c); Fed. R. Crim. P. 32.2(a); United
+States v. Liquidators of European Fed. Credit Bank, 630 F.3d
+1139, 1144 (9th Cir. 2011) (describing procedure for
+forfeiture). "[T]he Government retains broad discretion as to
+whom to prosecute." Wayte v. United States, 470 U.S. 598,
+607 (1985) (quotation omitted). The CVRA expressly does
+not impair that broad discretion. See 18 U.S.C. § 3771(d)(6)
+("Nothing in this chapter shall be construed to impair the
+prosecutorial discretion of the Attorney General or any officer
+under his direction.")?
+Accordingly, Stake Center's petition for writ of
+mandamus is denied.
+DENIED.
+2 Because we decide this issue on these grounds, we do not reach the
+other arguments advanced by the government why forfeiture proceedings
+cannot be commenced in this case.
+
+
+
+
+Case 9:08-CV-80736-KAM Document 224 Entered on FLSD Docket 08/16/2013 Page 1 of 3
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOE #1 and JANE DOE #2
+V.
+UNITED STATES
+JANE DOE #1 AND JANE DOE #2'S NOTICE OF FILING OF OBJECTIONS TO
+PRIVLEGE LOG
+COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and
+through undersigned counsel, to give notice of their filing of objections to the Government's two
+privilege logs (DE 212 and DE 216). The objections are attached hereto. The victims are filing
+these objections concurrently with a motion to compel production of the materials at issue.
+DATED: August 16, 2013
+Respectfully Submitted,
+Is/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Elorida 33301
+Telephona
+Facsimile
+Florida Bar No: 542075
+and
+Paul G. Cassell
+Pro Hac Vice
+1
+
+
+Case 9:08-CV-80736-KAM Document 224 Entered on FLSD Docket 08/16/2013 Page 2 of 3
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone:
+Facsimile:
+E-Mail:|
+2
+
+
+Case 9:08-CV-80736-KAM Document 224 Entered on FLSD Docket 08/16/2013 Page 3 of 3
+I certify that the foregoing document was served on August 16, 2013, on the following
+using the Court's CM/ECF system:
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Fax
+Attorneys for the Government
+Roy Black, Esq.
+Jackie Perczek, Esq.
+Black, Srebnick, Kornspan & Stumpf, P.A.
+201 South Biscayne Boulevard, Suite 1300
+Miami, FL 33131
+Jay P. Lefkowitz
+Kirkland & Ellis, LLP
+601 Lexington Avenue
+New York, NY 10022
+Email:
+Martin G. Weinberg, P.C.
+Boston, Ma02Suie 1000
+Is/ Bradley J. Edwards
+3
+
+
+Case 9:08-cv-80736-KAM Document 224-1
+Entered on FLSD Docket 08/16/2013
+
+
+PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 2 of 70
+PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS
+Key to Objections (linking to Victims' Motion to Compel Production of Doements that Are Not Privileged)
+Objection
+Abbreviation
+General Objections --
+Inadequate Privilege Log
+Inadequate Log
+Failure to Prove Factual Underpinnings of Privilege Claim
+No Factual Underpinnings
+Waiver of Confidentiality
+Waiver
+Government's Fiduciary Duty to Crime Victims Bars Privilege
+Fiduciary Duty
+Communications Facilitating Crime-Fraud-Misconduct Not Covered
+Factual Materials Not Covered
+Factual Materials
+Documents Not Prepared in Anticipation of CVRA Litigation
+Not in Anticipation of Litigation
+Attorney Client Objections -
+Ordinary Governmental Communications Not Covered
+Ordinary Government Communication
+Attorney-Client Relationship Not Established
+No Attorney-Client Relationship
+Deliberative Process Objections -
+Privilege Not Properly Invoked
+Final Decision Exempted from Privilege
+Qualified Privilege Overridden By the Victims' Need for the Documents
+Investigative Privilege -
+Privilege Not Properly Invoked
+Qualified Privilege Overridden By the Victims' Need for the Documents
+Work Product Doctrine
+No Work Product Doctrine in the Context of a Claim Against Public Prosecutors
+Qualified Privilege Overridden By the Victims' Need for the Documents
+Work Production Privilege Does No Apply When the Attorney's Conduct is at Issue
+Court-Authorized Disclosure Not Covered Under Rule 6(e)(3)(E)
+The Court Has Inherent Power to Release Grand Jury Materials
+Victims Have Properly Petitioned for the Release of Grand Jury
+The CVRA Gives the Court Authority to Release Grand Jury Materials
+Improper Invocation
+Final Decision
+Overriding Need
+Improper Invocation
+Overriding Need
+Claims Against Public Prosecutor
+Overriding Need
+Court Authorized Under 6(e)(3)(E)
+Court Inherent Power to Release
+Proper Victim's Petition
+CVRA-authorized release
+
+
+
+Liase 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 3 of 70
+Grand Jury Materials Can Be Severed from Other Materials
+The Privacy Rights of Other Victims
+No Assertion of Privacy Rights by o her Vie Concerns
+The Privacy Act Does Not Apply to Court-Compelled Disclosures for Discovery
+Description
+File folder entitled "CORR RE GJ
+6(e)
+P-000001
+SUBPOENAS" containing correspondence
+thru
+related to various grand jury subpoenas and
+P-000039
+attorney (
+D handwritten notes
+P-000040
+thru
+P-000549
+Operation Leap Year Grand Jury Log
+containing subpoenas OLY-01 through
+relaxed 1, coremont of same dorescench
+produced in response to some subpoenas;
+and attorney
+Material Severable
+Redaction
+No Assertion by Victims
+Court-Compelled Disclosure
+Litigation; Claims Against Public Prosecutor;
+Overriding Need; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+release; Material Severable; Overriding Need
+Anticipation of Litigation;
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+| 6(e)(3)(E); Court Inherent Power to Release;
+Assertion by Victims; Overriding Need
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 4 of 70
+P-000550
+thru
+P-000621
+File folder entitled Ritz Compact Flash
+SW" containing copies of a sealed search
+warrant application,
+warrant,
+supporting documents
+P-000622
+thru
+P-000693
+File folder entitled PNY Technologies
+Compact Flash SW" containing copies of a
+sealed search warrant application, warrant,
+File folder entitled "JE Corporations"
+Cond corporation and pior tigatore in -
+File folder entitled "Capital One"
+containing subpoena and correspondence
+Contains information
+Fiduciary Duty; Factual Materials; Not in
+subject to investigative
+Anticipation
+of Litigation;
+privilege
+Invocation;
+Overriding
+Also contains information
+Materials; Court Authorized Under 6(e)(3)(E);
+subject to privacy rights of
+| Court Inherent Power to Release; Proper
+victims who are not
+parties to this litigation
+Material Severable; Redaction; No Assertion
+by Victims
+Contains information
+Fiduciary Duty; Factual Materials; Not in
+subject to investigative
+Anticipation
+of Litigation;
+privilege
+Invocation;
+Overriding
+Subc to privacy mati or
+Materials; Court Authorized Under 6(e)(3)(E);
+Court Inherent Power to Release; Proper
+victims who are not
+parties to this litigation
+Contains information
+subject to investigative
+privilege
+P-000694
+thru
+P-000781
+P-000782
+thru
+P-000803
+| Inadequate Log; No Factual Underpinnings;
+Attorney Conduct at Issue; Overriding Need
+Fiduciary Duty; Factual Materials; Court
+Authorized Under 6(e)(3)(E); Court Inherent
+Power to Release; Proper Victim's Petition;
+CVRA-authorized release; Material Severable
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 5 of 70
+P-000804
+thru
+P-000854
+Description
+folder
+entitled
+"DTG
+Operations/Dollar Rent-a-Car" containing
+subpoena and responsive documents
+P-000855
+thru
+P-000937
+File folder entitled "JP Morgan Chase"
+containing subpoena, correspondence, and
+responsive documents
+6(e)
+Contains documents and
+information subject to
+investigative privilege
+Also contains documents
+and information subject to
+privacy rights of victims
+who are not parties to this
+litigation
+6(e)
+Contains documents and
+information subject to
+investigative privilege
+P-000938
+thru
+P-000947
+File folder entitled "Washington Mutual"
+containing subpoena, correspondence, and
+responsive documents
+6(e)
+Contains documents and
+information subject to
+investigative privilege
+P-000948
+thru
+P-000982
+File folder entitled "Computer Search &"
+containing legal research on computer
+search and handwritten notes on indictment
+Attorney-Client
+Contains information
+subject to investigative
+privilege. Also contains
+information subject to
+privacy rights of victims
+who are not parties to this
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+of Litigation;
+Improper
+Invocation; Overriding
+Need;
+Factual
+Materials; Court Authorized Under 6(e)(3)(E);
+Court Inherent Power to Release; Proper
+Material Severable; Redaction; No Assertion
+by Victims
+Need; Factual Materials; Court Authorized
+Under 6(c)(3)(E); Court Inherent Power to
+Fiduciary Duty; Not in Anticipation
+Need; Factual Materials; Court Authorized
+Fiduciary Duty; Factual Materials; Not in
+Anticipation of Litigation; Ordinary
+Government Communication; No Attorney-
+Client Relationship; Improper Invocation;
+Overriding Need; Claims Against Public
+Prosecutor; Attorney Conduct at Issue;
+Redaction; No Assertion by Victims
+
+
+
+Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 6 of 70
+P-000983
+thru
+P-001007
+Description
+File folder entitled "Attorney Notes from
+handwint exter" containine ped and,
+handwritten attorney
+I notes,
+target letters, correspondence re grand jury
+subpoena
+P-001008
+thru
+P-001056
+File folder entitled "Notes from Fed Ex
+Record containing hand aid en rend shoed
+attorney (
+of FedEx subpoena response electronic file
+P-001057
+thru
+P-001959
+File folder entitled "Colonial Bank
+Records" containing records received in
+response to grand jury subpoena
+Work product
+6(e)
+Contains information
+subject to investigative
+privilege. Also contains
+information subject to
+privacy rights of victims
+who are not parties to this
+litigation
+6(e)
+Contains information
+subject to investigative
+privilege. Also contains
+information subject to
+privacy rights of victims
+who are not parties to this
+litigation
+6(e)
+Contains information
+subject to investigative
+privilege
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+Litigation;
+Improper
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+Fadeday Duty; Facuat Materies Not is
+Anticipation
+of Litigation;
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(c)(3)(E); Court Inherent Power to Release;
+Need; Factual Materials; Court Authorized
+| authorized release; Material Severable
+
+
+
+P-001960
+P-002089
+P-002090
+P-002169
+P-002170
+P-002246
+P-002247
+P-002265
+yucument 224-1 Entered on FLSD Docket 08/16/2013 Page 7 of 70
+Description
+File folder entitled "OLY Grand Jury Log
+Vol 2: OLY-51 THROUGH" containing
+subpoenas numbered OLY-51 through
+OLY-81 with related correspondence
+6(e)
+Contains information
+subject to investigative
+privilege. Also contains
+information subject to
+privacy rights of victims
+who are not parties to this
+litigation
+6(c)
+Contains information and
+documents subject to
+investigative privilege
+File folder entitled "Epstein Corporate
+Records: OLY-51, OLY-52, OLY-53,
+OLY-54" containing subpoenas, records
+received in response to subpoenas, and
+related correspondence
+File folder entitled "Colonial Bank"
+response to subpoenas
+6(e)
+Contains information and
+documents subject to
+investigative privilege
+File folder entitled "JEGE & Hyperion
+from Goldberger OLY-46 & OLY-47"
+containing documents received in response
+to subpoenas
+Contains information and
+documents subject to
+investigative privilege
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+Litigation;
+Improper
+Invocation; Overriding
+Materials; Court Authorized Under 6(e)(3)(E);
+Court Inherent Power to Release; Proper
+Material Severable; Redaction; No Assertion
+by Victims
+Fiduciary Duty; Not in Anticipation
+Need; Factual Materials; Court Authorized
+Inadequate Log: No Factual Underpinnings;
+Need; Factual Materials; Court Authorized
+Need; Factual Materials; Court Authorized
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 8 of 70
+P-002266
+P-002386
+P-002387
+P-002769
+Description
+Indictment preparation binder containing:
+Grand jury subpoena log, evidence/activity
+summary chart, witness/victim names and
+contact list,
+attorney
+handwritten notes, 302s, portions of state
+investigative file,
+attorney
+typed notes, of individuals
+listed as
+"Additional victims"
+Indictment preparation binder containing:
+Grand jury subpoena log, evidence/activity
+summary chart, witness/victim names and
+list,
+handwritten notes, 302s, portions of state
+typed notes, relevant pieces of grand jury
+materials, telephone records/flight records
+analysis
+charts,
+photographs, DAVID records, NCICs, and
+related materials for persons identified as
+Jane Does #15, 16, 17, 18, 19, Past
+Employees, Misc. Witnesses
+Work product
+6(e)
+Contains information and
+documents subject to
+investigative privilege.
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+litigation
+Work product
+6(e)
+Contains information and
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+litigation
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+of Litigation;
+Improper
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+release; Material Severable
+Anticipation of Litigation;
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+
+
+
+wast y.Vo-CV-BU/3b-KAM Document 224-1 Entered on FL Docket 08/10/2013 Page 901
+P-002770
+P-003211
+P-003212
+P-003545
+Description
+Indictment preparation binder containing:
+witness/victim
+list
+with identifying
+information, sexual activity summary,
+telephone call summary chart, attorney
+handwritten
+notes,
+302s,
+portions of state investigative file, attorney
+typed notes, relevant pieces of
+grand
+jury
+materials,
+telephone
+records/flight records analysis charts,
+victim/witness
+photographs,
+DAVID
+records, NCICs, and related materials for
+persons identified as Jane Does #1, 2, 3, 4,
+Indictment preparation binder containing
+meta-analysis
+charts
+of
+telephone/flight/grand jury information for
+number of
+victim/witneace
+and
+Work product
+Contains information and
+documents subject to
+investigative privilege.
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+litigation
+Fiduciary Duty; Factual Materials; Not in
+Anticipation of Litigation;
+. Improper
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Redaction; No Assertion by Victims
+Work product
+Fiduciary Duty; Factual Materials; Not in
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 10 of
+P-003546
+P-003552
+Description
+FBI Reports of March 2008 interviews of
+additional witness/victim located in New
+York
+Printout of filenames from Federal Express
+subpoena response with Attorney notations
+Work product
+6(e)
+Contains information and
+documents subject to
+investigative privilege.
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+litigation
+Work product
+6(e)
+P-003553
+P-003555B
+P-003556
+P-003562
+Work product
+6(e)
+Contains information
+subject to investigative
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+of Litigation;
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+Fiduciary Duty; Not in Anticipation
+Litigation; Claims Against Public Prosecutor;
+Overriding Need; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+release; Material Severable
+Attorney Conduct at Issue; Factual Materials;
+Court Authorized Under 6(e)(3)(E); Court
+
+
+
+Lase 9:00-CV-80736-KAM Document 224-1
+Entered on FLSD Docket 08/16/2013 Page 11 of
+P-003563
+P-003629
+Description
+"Flight
+Manifests"
+Fontaining manifest received usual o
+grand jury subpoena
+6(e)
+Concim into subion and
+investigative privilege
+P-003630
+P-003633
+File folder entitled "Recent Attorney
+Notes" containing handwritten attorney
+notes regarding document
+review and case strategy
+Work product
+6(e)
+Investigative privilege
+Deliberative process
+P-003634
+P-003646
+File folder bearing victim name containing
+FBI interview report from May 2008,
+telephone activity report with attorney
+handwritten notes, related
+grand jury material
+Work product
+Attorney-client privilege
+Investigative privilege
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+litigation
+Need; Factual Materials; Court Authorized
+Fiduciary Duty; Not in Anticipation
+Attorney Conduct at Issue; Factual Materials;
+Court Authorized Under 6(e)(3)(E); Court
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+Litigation; Ordinary
+Government Communication; No Attorney-
+Client Relationship; Improper Invocation;
+Overriding Need; Claims Against Public
+Prosecutor; Attorney Conduct at Issue; Factual
+Materials; Court Authorized Under 6(e)(3)(E);
+Court Inherent Power to Release; Proper
+Material Severable; Redaction; No Assertion
+by Victims
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 12 of
+P-003647
+P-003651
+Description
+File folder entitled "Summary of Sexual
+Activity"
+containing chart
+bearing
+handwritten title "Sexual Activity -
+Summary
+meta-analysis
+information, sorted by name of each
+victim/witness,
+including name
+identifying
+information
+victim/witness
+Work product
+Investigative privilege
+Deliberative process
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+litigation
+Fiduciary Duty; Factual Materials; Not in
+Anticipation of Litigation;
+Improper
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+P-003652
+P-003663
+P-003664
+P-003678
+P-003679
+P-003680
+P-003681
+P-003687
+File folder entitled "Victim Civil Suits"
+Not privileged.
+Produced to counsel for
+Petitioners
+Work product
+File folder entitled "Research re JE
+Websites" containing attorney research
+File folder entitled "Serene Cano N.Y
+AUSA)" containing attorney
+handwritten notes
+File folder entitled
+"Dr. Anna Salter"
+containing attorney
+expert witness and handwritten attorney
+Work product
+Work product
+Investigative privilege
+Litigation; Claims Against Public Prosecutor;
+[Inadequate Log; No Factual Underpinnings;
+Litigation; Claims Against Public Prosecutor;
+
+
+
+os00--KAM Document 224-1
+Entered on FLSD Docket 08/16/2013 Page 13 of
+P-003688
+P-003693
+P-003694
+P-003711
+P-003712
+Description
+File folder entitled "I[] G[] Interview"
+containing attorney handwritten notes of
+interview, and attorney handwritten notes
+regarding potential charges
+File folder entitled Research re Travel for
+Prostitution"
+containing
+attorney
+handwritten notes regarding
+handwritten notes, Message Pad metaanalysis chart, summary of evidence
+related to one victim/witness, and relevant
+grand jury information
+Empty file folder bearing name of
+victim/witness
+P-003713
+P-003746
+P-003747
+P-003751
+grand jury subpoenas, motion and order to
+compel testimony, and correspondence
+File folder entitled
+regains subpoena and correspondence
+Work product
+Investigative privilege
+Fiduciary Duty; Factual Materials; Not in
+Also contains information
+Anticipation
+Litigation;
+subject to privacy rights of
+Invocation; Overriding Need; Claims Against
+victims who are not
+Public Prosecutor; Attorney Conduct at Issue;
+parties to this litigation
+Redaction; No Assertion by Victims
+Work product
+Fiduciary Duty; Factual Materials; Not in
+Investigative privilege
+Anticipation
+Improper
+Also contains information
+Invocation; Overriding Need; Claims Against
+and documents subject to
+Public Prosecutor; Attorney Conduct at Issue;
+privacy rights of victims
+Factual Materials; Court Authorized Under
+who are not parties to this
+6(e)(3)(E); Court Inherent Power to Release;
+litigation
+Investigative privilege
+Also contains information
+subject to privacy rights of
+victim who is not a party
+6(e)
+Documents under seal
+pursuant to court order
+Inadequaye Duty; actual Materials, Cousi
+Authorized Under 6(e)(3)(E); Court Inherent
+6(e)
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 14 of
+P-003752
+P-004295
+Description
+File folder entitled "PBPD Investigative
+File" obtained via subpoena
+P-004296
+P-004350
+File folder bearing name of victim/witness
+contine amit, all, and rathoving
+materials relevant to possible charges
+6(e)
+Investigative privilege
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+litigation
+Work product
+6(e)
+Investigative privilege
+who are not parties to this
+P-004351
+P-004381
+P-004382
+P-004478
+File folder entitled "Daniel Gonzalez
+Documents
+53909-004"
+containing
+attorney research related to bias issue
+File Folder entitled "FEDEX" containing
+documents obtained via subpoena
+Work product
+6(e)
+Investigative privilege
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+Litigation;
+Invocation;
+Overriding
+Materials; Court Authorized Under 6(e)(3)(E);
+Court Inherent Power to Release; Proper
+Material Severable; Redaction; No Assertion
+by Victims
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+of Litigation;
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+Litigation; Claims Against Public Prosecutor;
+Need; Factual Materials; Court Authorized
+
+
+
+Case .00-CV-00/36-KAM Document 224-1
+Entered on FLSD Docket 08/16/2013 Page 15 of
+P-004479
+P-004551
+Description
+File Folder entitled "State of Delaware
+6(e)
+Investigative privilege
+Work product
+P-004552
+P-004555
+File folder entitled "Jet Blue Records"
+containing
+documents
+obtained
+via
+subpoena
+6(e)
+Work product
+Investigative privilege
+Also contains information
+and documents subject to
+privacy rights of victims
+who are nig parties to this
+Investigative privilege
+Work product
+P-004556
+P-004560
+P-004561
+P-004565
+File folder entitled "FL EMPLOYMENT
+RECORDS" containing FDLE records on
+targets and witnesses obtained at attorney
+Filed folder
+entitled
+"JANUSZ
+BANASIAK"
+I hand itemainies of intervenes
+attorney
+Work product
+Investigative privilege
+Inadequate Log No Factual Underpinnings;
+Need; Claims Against Public
+Prosecutor;
+Attorney Conduct at Issue; Factual Materials;
+Court Authorized Under 6(e)(3)(E); Court
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+Litigation;
+Improper
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 16 of
+P-004566
+P-004716
+Description
+File folder entitled "JANUSZ BANASIAK
+RECORDS 23-0001 THROUGH 23-"
+containing
+documents
+subpoena
+obtained
+Work product
+Investigative privilege
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+litigation
+Work product
+Investigative privilege
+P-004717
+P-004722
+P-004723
+P-004725
+P-004726
+P-004819
+P-004820
+P-004959
+File folder entitled "IGOR ZINOVIEV"
+containing attorney research regarding
+witness
+File folder entitled "BEAR STEARNS
+reparing prential wines andy research
+File folder
+entitled
+"LAWSUITS
+INVOLVING
+EPSTEIN
+CORP'S"
+containing attorney research regarding
+Epstein's past personal and business
+litigative practices
+Filed folder entitled "SEC RECORDS"
+containing attorney research regarding
+Epstein financial relationships
+Investigative privilege
+Investigative privilege
+Investigative privilege
+Fiduciary Duty; Factual Materials; Not in
+Anticipation of Litigation;
+Improper
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 17 of
+P-004960
+P-005059
+Description
+File folder entitled "Message Pads"
+containing selected items from evidence
+obtained via subpoena
+P-005060
+P-005081
+File folder bearing name of victim/witness
+containing correspondence with counsel
+for victim/witness, attorney witness outline
+with attorney handwritten notes, attorney
+reports and case preparation ding
+witness
+P-005082
+P-005083
+File folder entitled "New York Trip"
+containing attorney notes re witness
+Fiduciary Duty; Factual Materials; Not in
+Investigative privilege
+Anticipation
+Litigation;
+Also contains information
+Invocation; Overriding Need; Claims Against
+and documents subject to
+Public Prosecutor; Attorney Conduct at Issue;
+privacy rights of victims
+Factual Materials; Court Authorized Under
+who are not parties to this
+6(e)(3)(E); Court Inherent Power to Release;
+Investigative privilege
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+of Litigation;
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+Work product
+Investigative privilege
+P-005084
+thru P-005107
+responsive documents and have been
+removed
+
+
+
+
+P-005108
+P-005193
+Box #I
+P-005194
+• P-005300
+P-005301
+P-005331
+P-005332
+P-005341
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2023 Page 18 of
+Description
+File folder entitled "ANNA SALTER"
+containing attorney research on select
+expert, use of experts at trials in child
+exploitation cases, and additional research
+materials on offenders and victims
+File folder entitled "Extra Copies"
+containing meta-analysis chart and 302's of
+victim/witnesses used in
+preparing
+indictment package
+File folder entitled "JUAN
+ALESSI
+Strained via subpoenantaining
+transcript
+File folder entitled "KEN LANNING"
+containing attorney research on select
+expert, including attorney handwritten
+notes
+Work product
+Investigative privilege
+Work product
+6(e)
+Investigative privilege
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+litigation
+6(e)
+Investigative privilege
+Work product
+Investigative privilege
+Inadequate Log; Fiduciary Duty; Factual
+Materials; Not in Anticipation of Litigation;
+Improper Invocation; Overriding Need; Claims
+Against Public Prosecutor; Attorney Conduct
+at Issue
+Fiduciary Duty; Factual Materials; Not in
+Anticipation of Litigation;
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+adequate Loty Not in cain of
+Need; Factual Materials; Court Authorized
+
+
+
+P-005342
+P-005387
+P-005388
+P-005442
+P-005443
+P-005496
+Case 9:08-Cv-80736-KAM Document 221-1 Entered on FLSD Docket 08/16/2013 Page 19 of
+Description
+File folder entitled "Info re Planes"
+regarding
+contains and documents received in
+response to subpoenas
+File folder entitled "Police Reports & PC
+Affidavit" containing portions of police
+reports with attorney notes, related phone
+records, a list entitled "Victims" with
+identifying information and attorney
+handwritten notes, photographs
+DAVID information, and additional
+attormey research regarding Epstein sexual
+Transcript of eried l Transcripmel
+Investigative privilege
+Work product
+Investigative privilege
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+litigation
+6(e)
+Investigative privilege
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+P-005497
+P-005556
+File folder entitled "Bear Stearns Subpoena
+Resp." containing material received in
+6(e)
+Investigative privilege
+Fiduciary
+Invocation;
+Overriding Need; Factual Materials; Court
+Authorized Under 6(e)(3)(E); Court Inherent
+Power to Release; Proper Victim's Petition;
+CVRA-authorized release; Material Severable
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+Litigation;
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+Litigation;
+Invocation; Overriding
+Materials; Court Authorized Under 6(e)(3)(E);
+Court Inherent Power to Release; Proper
+Material Severable; Redaction; No Assertion
+by Victims
+Need; Factual Materials; Court Authorized
+Release; Proper
+Victim's Petition; CVRA-
+
+
+
+Entered on FLSD Docket 08/16/2013 Page 20 of
+P-005557
+P-005576
+P-005578
+P-005583
+P-005584
+P-005606
+U.S. Attorney's Office Criminal Case File
+Jacket containing file opening documents,
+expert witness payment documents
+U.S. Attorney's Office Asset Forfeiture
+Case File Jacket containing file opening
+and file closing documents
+File folder entitled 6001 Immunity
+Request" containing internal memoranda
+seeking witness
+immunity
+correspondence with counsel for witness
+regarding same
+Work product
+Deliberative process
+Work product
+Deliberative process
+P-005607
+P-005914
+all phone, travel, and grand jury data for all
+victim/witnesses for indictment preparation
+Work product and
+deliberative process (as to
+Investigative privilege
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+litigation
+Work product
+Investigative privilege
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+litigation
+Attorney Conduct at Issue; Factual Materials;
+Court Authorized Under 6(e)(3)(E); Court
+Severable; Redaction; No Assertion by
+Fiduciary Duty; Factual Materials; Not in
+of Litigation; Improper
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 21 of
+P-005915
+P-005977
+Description
+File folder bearing name of victim/witness
+containing meta-analysis of all phone,
+travel, and grand jury data related to that
+victim/witness for indictment preparation
+P-005978
+P-006050
+File folder bearing name of victim/witness
+canal, and grand juay diat relatl to that
+victim/witness for indictment preparation
+P-006051
+P-006065
+victim, with ess for indic data preparati ot
+Work product
+Fiduciary Duty; Factual Materials; Not in
+Investigative privilege
+Anticipation
+Litigation;
+Improper
+Also contains information | Invocation; Overriding Need; Claims Against
+and documents subject to
+Public Prosecutor; Attorney Conduct at Issue;
+privacy rights of victims
+Factual Materials; Court Authorized Under
+who are not parties to this
+6(e)(3)(E); Court Inherent Power to Release;
+Work product
+Investigative privilege
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+of Litigation;
+Improper
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+Work product
+Investigative privilege
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+litigation
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+of Litigation;
+Improper
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+
+
+
+P-006066
+P-006220
+P-006221
+P-006222
+P-006223
+P-006522
+Case 9:03 CV 30736-KAM Document 224-1 Entered on FLSD Docket 08/1/2023 Page 22 of
+Description
+File folder entitled "JANE DOE #4"
+fontai, and mand anal did are all phone,
+victim/witness for indictment preparation
+File folder entitled ""JANE DOE #12"
+containing meta-analysis of all phone,
+travel, and grand jury data related to that
+victim/witness for indictment preparation
+File folder entitled "CORRECTED
+PHONE RECORDS 5/31/07" containing
+meta-analysis of all phone, travel, and
+grand jury data
+related
+to all
+victims/witnesses
+indictment
+preparation
+Work product
+6(e)
+Investigative privilege
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+litigation
+Work product
+6(e)
+Investigative privilege
+and documents subjection
+privacy rights of victims
+who are not parties to this
+litigation
+Fiduciary Duty; Factual Materials; Not in
+Anticipation of Litigation;
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(c)(3)(E); Court Inherent Power to Release;
+Fiduciary Duty; Factual Materials; Not in
+Anticipation of Litigation; |
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Work product
+Investigative privilege
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+litigation
+| Inadequate Log; No Factual Underpinnings;
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+of Litigation;
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+
+
+
+Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 23 of
+P-006523
+P-006802
+Description
+File folder entitled "[Victim Name] Phone
+received response to subpone records
+Work product
+Investigative privilege
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+P-006803
+P-006860
+File folder entitled "Lists of Identified
+Phone Numbers" containing charts of
+information culled from grand jury
+materials,
+interviews,
+and
+other
+investigation, with attorney handwritten
+Boxes and information to issue follow-up
+Work product
+Investigative privilege
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+P-006861
+P-007785
+File folder entitled "EPSTEIN/
+CELL PHONE RECORDS" containing
+documents received via subpoena with
+attorney
+handwritten
+notes
+and
+highlighting
+Work product
+Investigative privilege
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+litigation
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+Litigation;
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+Fiduciary Duty; Factual Materials; Not in
+Anticipation of Litigation;
+Improper
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+of Litigation;
+Improper
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)E): Court Inherent Power to Release;
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 24 of
+P-007786
+P-008120
+Description
+Folder entitled "OLY GRAND JURY
+containing subpoenas, correspondence
+regarding same, 6(e) letters, attorney
+handwritten notes regarding
+records
+received in response to subpoenas
+P-008121
+P-008139
+Handwritten flight logs
+received
+in
+response to subpoena
+P-008140
+P-008298
+Grand jury presentation folder containing
+attorney handwritten notes, typed outline
+with additional handwritten
+complete indictment package dated
+2/19/2008, victim list with identifying
+information, photographs, and summary of
+Work product
+6(e)
+Investigative privilege
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+litigation
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+of Litigation;
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+6(e)
+Investigative privilege
+Fiduciary Duty; Not in Anticipation
+Need; Factual Materials; Court Authorized
+Rehan Prese Materia Seria VRA.
+Work product
+6(e)
+Fiduciary Duty; Factual Materials; Not in
+Investigative privilege
+Anticipation
+of Litigation;
+Improper
+Also contains information
+Invocation; Overriding Need; Claims Against
+and documents subject to
+Public Prosecutor; Attorney Conduct at Issue;
+privacy rights of victims
+Factual Materials; Court Authorized Under
+who are not parties to this
+6(e)(3)(E); Court Inherent Power to Release;
+litigation
+
+
+
+Case 9:08Cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 25 of
+P-008299
+P-008363
+Description
+folder
+entitled
+"FINAL
+AGREEMENTS" containing subfolder
+entitled "Agrts Filed in State Court" (P-
+008300-P-008327 [not being withheld as
+privileged - have been produced to
+counsel]); signed
+Prosecution Agreement, Addendum, and
+operative portion of 12/19/2007 Sanchez-
+Acosta letter (P-008328-P-008343 [not
+being withheld as privileged - have been
+produced to opposing counsel]); subfolder
+entitled "12/19/07 Acosta-Sanchez Ltr"
+order, no being oped a privil epo
+lift of stay by 11" Circuit)
+P-008364
+P-008382
+Investigative privilege
+Fidelay Duty Not in Antipation ste
+Attorney Conduct at Issue; Factual Materials;
+Court Authorized Under 6(e)(3)(E); Court
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 26 of
+P-008383
+P-008516
+Description
+File folder containing March 18, 2008
+Summary Chart (by victim)," grand jury
+materials, draft
+indictments,
+victim
+reference list, grand jury subpoena log
+Work product
+6(e)
+Investigative privilege
+Deliberative process
+Also contains information
+and documents subject to
+privacy rights of victims
+who are not parties to this
+litigation
+Fiduciary Duty; Factual Materials; Not in
+Anticipation of Litigation;
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+P-008517
+P-008535
+P-008536
+P-008542
+P-008543
+P-008549
+6/25/2007 Letter from Gerald Lefcourt to
+_and Andrew
+[pursuant to Court's Order, not being
+withheld as privileged - will be produced
+10 opposing counsel upon lift of stay by
+Handwritten attorney notes to prepare for
+interview of Jane Doe #2
+5.2007 grand try pe ones regarding May
+Work product
+Investigative Privilege
+Fiduciary Duty; Factual Materials; Not in
+Contains information
+Anticipation
+of Litigation;
+Improper
+subject to privacy rights of
+Invocation; Overriding Need; Claims Against
+victims who are not
+Public Prosecutor; Attorney Conduct at Issue;
+parties to this suit
+Redaction; No Assertion by Victims
+Work product
+Fiduciary Duty; Factual Materials; Not in
+Investigative privilege
+Anticipation of
+Litigation;
+Improper
+Contains information
+Invocation; Overriding Need; Claims Against
+subject to privacy rights of
+| Public Prosecutor; Attorney Conduct at Issue;
+victims who are not
+Factual Materials; Court Authorized Under
+parties to this suit
+6(e)(3)(E); Court Inherent Power to Release;
+[Assertion by Victims
+
+
+
+Entered on FLSD Docket 08/16/2013 Page 27 of
+P-008550
+P-008615
+Description
+File folder
+entitled "Most
+Recent
+Indictment & Good Cases" containing draft
+indictment and legal research
+P-008616
+P-008686
+File folder entitled "FBI Summary Charts"
+containing chart prepared at direction of
+AUSA, containing
+victim names,
+identifying information, summary of
+indictmend other information relevant to
+P-008687
+P-008776
+File folder entitled "[Victim name]/Jane
+Doe #4" containing phone records and
+meta-analysis of all phone, travel, and
+grand jury data related to
+that
+victim/witness for indictment preparation
+Work product
+Fiduciary Duty; Factual Materials; Not in
+Investigative privilege
+Anticipation
+Deliberative process
+Invocation; Overriding Need; Claims Against
+Contains information
+Public Prosecutor; Attorney Conduct at Issue;
+subject to privacy rights of
+Factual Materials; Court Authorized Under
+victims who are not
+6(e)(3)(E); Court Inherent Power to Release;
+parties to this suit
+Work product
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+of Litigation;
+Investigative privilege
+Government Communication; No Attorney-
+Contains information
+Client Relationship; Improper Invocation;
+subject to privacy rights of | Overriding Need; Claims Against Public
+victims who are not
+Prosecutor; Attorney Conduct at Issue; Factual
+parties to this suit
+Materials; Court Authorized Under 6(e)(3)(E);
+Court Inherent Power to Release; Proper
+Material Severable ; Redaction; No Assertion
+by Victims
+Work product
+6(e)
+Investigative privilege
+Contains information and
+documents subject to
+privacy rights of victims
+who are not parties to this
+suit
+Fiduciary Duty; Factual Materials; Not in
+Anticipation of Litigation;
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 28 of
+P-008777
+P-008808
+Description
+File folder entitled "[Victim name]/Jane
+Doe #5" containing handwritten notes and
+meta-analysis of all phone, travel, and
+grand jury data
+related to that
+victim/witness for indictment preparation
+P-008809
+P-008847
+File folder entitled [Victim name]/Jane
+Doe #6" containing meta-analysis of all
+phone, travel, and grand jury data related to
+that victim/witness
+for
+indictment
+P-008848
+P-008862
+Doe f7 comic Viaim as of all
+phone, travel, and grand jury data related to
+for
+indictment
+preparation
+Work product
+6(e)
+Fiduciary Duty; Factual Materials; Not in
+Investigative privilege
+Anticipation
+of Litigation;
+Contains information
+Invocation; Overriding Need; Claims Against
+subject to privacy rights of
+Public Prosecutor; Attorney Conduct at Issue;
+victims who are not
+Factual Materials; Court Authorized Under
+parties to this suit
+6(e)(3)(E); Court Inherent Power to Release;
+Work product
+6(e)
+Fiduciary Duty; Factual Materials; Not in
+Investigative privilege
+Anticipation
+Litigation;
+Contains information
+Invocation; Overriding Need; Claims Against
+subject to privacy rights of
+Public Prosecutor; Attorney Conduct at Issue;
+victims who are not
+Factual Materials; Court Authorized Under
+parties to this suit
+6(e)(3)(E); Court Inherent Power to Release;
+Work product
+6(c)
+Fiduciary Duty; Factual Materials; Not in
+Investigative privilege
+Anticipation of Litigation;
+Improper
+Contains information
+Invocation; Overriding Need; Claims Against
+subject to privacy rights of
+Public Prosecutor; Attorney Conduct at Issue;
+victims who are not
+Factual Materials; Court Authorized Under
+parties to this suit
+6(e)(3)(E); Court Inherent Power to Release;
+| Assertion by Victims
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 29 of
+P-008863
+P-008890
+Description
+File folder entitled "[Victim name]/Jane
+Doe #8" containing meta-analysis of all
+phone, travel, and grand jury data related to
+that victim/witness
+indictment
+preparation
+P-008891
+P-009103
+P-009104
+P-009111
+P-009112
+P-009113
+File folder entitled "Certified Copy of State
+Case" containing certified copy of Epstein
+state criminal cases and change of plea
+transcript [not being withheld as privileged
+- copy provided to opposing counsel]
+File folder entitled "Meeting Timeline"
+typed notes
+Alexander Acosta, with handwritten
+correction and typed guideline estimate
+1126/2008 Email from Roy Black to
+re
+Jeffrey Epstein (work release)
+[pursuant to Court's Order, not being
+withheld as privileged - will be produced
+10 opirsing counsel upon lift of stay by
+Work product
+6(e)
+Fiduciary Duty; Factual Materials; Not in
+Investigative privilege
+Anticipation of
+Litigation;
+Improper
+Contains information
+Invocation; Overriding Need; Claims Against
+subject to privacy rights of
+Public Prosecutor; Attorney Conduct at Issue;
+victims who are not
+Factual Materials; Court Authorized Under
+parties to this suit
+6(e)(3)(E); Court Inherent Power to Release;
+Work product
+Deliberative process
+En Anticipatio origin inproper
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 30 of
+P-009114
+P-009115
+P-009116
+P-009125
+P-009126
+P-009134
+Description
+7/3/2008 Email from
+Col. M. Gauger at PBSO re Epstein work
+release with attachment
+[not being
+withheld as privileged - produced to
+opposing counsel]
+12/6/2007 Letter from
+Jay P. Lefkowitz re Jeffrey Epstein (victim
+notification) [pursuant to Court's Order,
+not being withheld as privileged - will be
+produced to opposing counsel upon lift of
+File folder entitled "[Victim name]/Jane
+Phong , and grandary nada ris at all
+preparation
+P-009135
+P-009141
+File folder entitled "[Victim name]/Jane
+Doe #13" containing meta-analysis of all
+phone, travel, and grand jury data related to
+that victim/witness
+indictment
+preparation
+Work product
+Fiduciary Duty; Factual Materials; Not in
+Consis nervie
+of Litigation; Improper
+Invocation; Overriding Need; Claims Against
+subject to privacy rights of
+Public Prosecutor; Attorney Conduct at Issue;
+victims who are not
+Factual Materials; Court Authorized Under
+parties to this suit
+6(c)(3)(E); Court Inherent Power to Release;
+Work product
+Fiduciary Duty; Factual Materials; Not in
+Investigative privilege
+Anticipation
+of Litigation;
+Improper
+Contains information
+Invocation; Overriding Need; Claims Against
+subject to privacy rights of
+Public Prosecutor; Attorney Conduct at Issue;
+victims who are not
+Factual Materials; Court Authorized Under
+parties to this suit
+6(e)(3)(E); Court Inherent Power to Release;
+| Assertion by Victims
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 31 of
+P-009141A
+P-009141C
+Description
+File folder entitled "[Victim name/Jane
+Doe #12" containing meta-analysis of all
+phone, travel, and grand jury data related to
+that victim/witness
+indictment
+preparation
+P-009142
+P-009152
+File folder entitled
+containing
+meta-analysis of all
+that individual for indicemen prepaid to
+P-009153
+P-009156
+File folder entitled
+conti and mend jury data related to that
+individual for indictment preparation
+Work product
+Fiduciary Duty; Factual Materials; Not in
+Investigative privilege
+Anticipation
+Litigation;
+Contains information
+Invocation; Overriding Need; Claims Against
+subject to privacy rights of | Public Prosecutor; Attorney Conduct at Issue;
+victims who are not
+Factual Materials; Court Authorized Under
+parties to this suit
+6(e)(3)(E); Court Inherent Power to Release;
+Work product
+Fiduciary Duty; Factual Materials; Not in
+Investigative privilege
+Anticipation
+of Litigation;
+Contains information
+Invocation; Overriding Need; Claims Against
+subject to privacy rights of
+Public Prosecutor; Attorney Conduct at Issue;
+victims who are not
+Factual Materials; Court Authorized Under
+parties to this suit
+6(e)(3)(E); Court Inherent Power to Release;
+Work product
+Fiduciary Duty; Factual Materials; Not in
+Investigative privilege
+Anticipation
+of Litigation;
+Improper
+Contains information
+Invocation; Overriding Need; Claims Against
+subject to privacy rights of
+Public Prosecutor; Attorney Conduct at Issue;
+victims who are not
+Factual Materials; Court Authorized Under
+parties to this suit
+6(e)(3)(E); Court Inherent Power to Release;
+
+
+
+Entered on FLSD Docket 08/16/2013 Page 32 of
+Bates Range Descriptier entited "Victim name//Jane
+P-009157
+Doe #1" containing meta-analysis of all
+phone, travel, and grand jury data related to
+P-009208
+that victim/witness
+for
+indictment
+preparation
+P-009209
+P-009213
+File folder entitled "[Victim name]/Jane
+Doe #2" containing meta-analysis of all
+phone, travel, and grand jury data related to
+that victim/witness
+indictment
+preparation
+P-009214
+P-009271
+File folder entitled "[Victim name]/Jane
+Doe #3" containing meta-analysis of all
+phone, travel, and grand jury data related to
+preparationim/ witness
+indictment
+Work product
+6(e)
+Fiduciary Duty; Factual Materials; Not in
+Investigative privilege
+Anticipation
+of Litigation;
+Contains information
+Invocation; Overriding Need; Claims Against
+subject to privacy rights of
+Public Prosecutor; Attorney Conduct at Issue;
+victims who are not
+Factual Materials; Court Authorized Under
+parties to this suit
+6(e)(3)(E); Court Inherent Power to Release;
+Work product
+6(e)
+Investigative privilege
+Contains information
+subject to privacy rights of
+victims who are not
+parties to this suit
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+Litigation;
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Work product
+6(e)
+Fiduciary Duty; Factual Materials; Not in
+Investigative privilege
+Anticipation
+of Litigation;
+Contains information
+Invocation; Overriding Need; Claims Against
+subject to privacy rights of | Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+parties to this suit
+6(e)(3)(E); Court Inherent Power to Release;
+
+
+
+Case 9:08-cv-80736-KAM Document 224-1
+Entered on FLSD Docket 08/16/2013 Page 33 of
+P-009272
+P-009354
+P-009355
+P-009403
+P-009404
+P-009536
+P-009537
+P-009574
+P-009575
+P-009603
+P-009604
+P-009711
+P-009712
+P-009819
+P-009820
+P-009965
+File folder entitled "Purpose of Travel
+Cases" containing attorney research and
+handwritten notes
+File folder entitled "Interstate Commerce
+Cases" containing attorney research and
+handwritten notes
+File folder entitled "Attorney Conflict
+Research" containing attorney research and
+handwritten notes
+File folder entitled "Mann Act/Travel to
+Have Sex w/Minor" containing attorney
+research and handwritten notes
+File folder entitled "Travel Act" containing
+attorney research and handwritten notes
+File
+folder
+entitled
+"Florida
+Prostitution/Lewdness Statutes" containing
+attorney research and handwritten notes
+Booklet entitled "Attorney
+General
+Guidelines for Victim and Witness
+Assistance" [not being withheld as
+privileged - produced to opposing counsel]
+File folder entitled "Corporate Liability
+Rsrch" containing attorney research and
+handwritten notes
+Work product
+Work product
+Work product
+Work product
+Fiduciary Duty; Not in
+Anticipation of
+Litigation; Claims Against Public Prosecutor;
+Fiduciary Duty; Not in
+Anticipation
+of
+Litigation; Claims Against Public Prosecutor;
+Fiduciary Duty; Not in Anticipation
+of
+Litigation; Claims Against Public Prosecutor;
+Fiduciary Duty; Not in Anticipation
+Litigation; Claims Against Public Prosecutor;
+
+
+
+Entered on FLSD Docket 08/16/2013 Page 34 of
+P-009966
+P-010096
+Description
+File folder
+entitled
+"Research
+Knowledge
+of Age Unnecessary"
+containing
+attorney
+research
+and
+handwritten notes and copy of grand jury
+subpoena
+6(e)
+P-010097
+P-010276
+P-010277
+P-010394
+P-010395
+P-010488
+P-010489
+P-010509
+P-010510
+P-010525
+File folder entitled "Money Laundering""
+containing
+attorney
+handwritten notes
+research
+File
+folder
+entitled
+"1960
+Aiding/Abetting" containing
+attorney
+research and handwritten notes
+File folder entitled "18 USC § 2255 Cases"
+research
+and
+handwritten notes
+File folder entitled "Research re Overt Acts
+& Witness Testimony" containing attorney
+research and handwritten notes
+File folder
+entitled
+"Extradition"
+Candiriten notto
+attorney
+research
+and
+Fiduciary Duty; Not
+in Anticipation of
+Litigation; Claims Against Public Prosecutor;
+Overriding Need; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+release; Material Severable
+Fiduciary Duty; Not in Anticipation
+Litigation; Claims Against Public Prosecutor;
+Litigation; Claims Against Public Prosecutor;
+Litigation; Claims Against Public Prosecutor;
+Litigation; Claims Against Public Prosecutor;
+Figion, Can Against Public Prosecutor
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 35 of
+P-010526
+P-010641
+P-010642
+P-010651
+P-010659
+Description
+File folder entitled "Rsrch re Crime
+Victims Rights" containing
+research, handwritten notes, draft victim
+letter,
+correspondence to Jay Lefkowitz
+(Also contains a November 28, 2007 letter
+from Kenneth Starr to Alice S. Fisher; and
+a November 29, 2007 letter from Jay
+Lefkowitz to R. Alexander Acosta (P-
+010528 thru P-010530 and P-010556 thru
+P-010559). Pursuant to the Court's Order,
+these will be produced to opposing counsel
+upon lift of stay by 11" Circuit)
+File folder entitled "Immunity" containing
+attorney research on granting immunity to
+witnesses
+File folder entitled "Research re G.J.
+Crime-Fraud-Misconduct; Factual Materials;
+Not in Anticipation of Litigation; Improper
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue
+6(e)
+Deliberative process
+Litigation; Claims Against Public Prosecutor;
+Attorney Conduct at Issue; Factual Materials;
+Court Authorized Under 6(e)(3)(E); Court
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 36 of
+P-010660
+P-010757
+Description
+File folder entitled "Research re GJ
+Transcript" containing grand jury
+subpoena, 6(e) letters, attorney research
+and correspondence related to subpoena
+6(e)
+P-010758
+P-010793
+File folder entitled "Original Proposed
+Ind." containing draft indictment
+6(e)
+Deliberative process
+P-010794
+P-010829
+P-010830
+P-010853
+P-010854
+P-010876
+File folder entitled "1591 & Money
+Laundering" containing attorney research
+and handwritten notes
+File folder entitled "18 USC 2425"
+containing
+attorney
+research
+handwritten notes
+Litigation; Claims Against Public Prosecutor;
+Overriding Need; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+Proper Victim's Petition;
+CVRA-authorized
+release; Material Severable
+Fiduciary Duty; Not in Anticipation
+Attorney Conduct at Issue; Factual Materials;
+Court Authorized Under 6(e)(3)(E); Court
+| Petition; CVRA-authorized release; Material
+Litigation; Claims Against Public Prosecutor;
+Litigation; Claims Against Public Prosecutor;
+Litigation; Claims Against Public Prosecutor;
+
+
+
+P-010877
+P-010920
+P-010921
+P-011049
+P-011050
+P-011212
+P-011213
+P-011237
+P-011238
+P-011319
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 37 of
+Description
+File folder entitled "Knowledge of Age"
+containing
+attorney
+research
+handwritten notes
+folder
+entitled
+2423(b)
+Constitutionality and Purpose of Travel"
+containing
+attorney
+handwritten notes
+research
+File folder entitled Mistake not a
+Defense containing attorney research and
+handwritten notes
+File
+folder entitled "Research re
+"Pandering'" containing attorney research
+and handwritten notes
+File folder entitled "Research re Grand
+Jury Instructions" containing attorney
+research and handwritten notes
+6(e)
+P-011320
+P-011361
+P-011362
+P-011374
+File folder entitled "Telephone = Facility
+of Commerce" containing
+attorney
+research and handwritten notes
+File folder entitled "Def of Prostitution"
+containing
+attorney
+research
+and
+handwritten notes
+Fiduciary Duty; Not in
+Anticipation
+Litigation; Claims Against Public Prosecutor;
+Fiduciary Duty; Not in
+Anticipation
+Litigation; Claims Against Public Prosecutor;
+Fiduciary Duty; Not in
+Anticipation
+of
+Litigation; Claims Against Public Prosecutor;
+Fiduciary Duty; Not in Anticipation
+Litigation; Claims Against Public Prosecutor;
+Fiduciary Duty; Not in Anticipation
+Litigation; Claims Against Public Prosecutor;
+Overriding Need; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+Proper Victim's Petition;
+CVRA-authorized
+release; Material Severable
+Fiduciary Duty; Not in
+Anticipation of
+Litigation; Claims Against Public Prosecutor;
+Fiduciary Duty; Not in Anticipation
+Litigation; Claims Against Public Prosecutor;
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 38 of
+P-011375
+P-011456
+P-011457
+P-011626
+P-011627
+P-011662
+P-011663
+P-011698 and
+P-012189 thru
+P-012361
+(gap was
+scanning
+error)
+P-011699
+P-011777
+Description
+File folder entitled "Relevant Florida
+Statutes" containing attorney research and
+handwritten notes
+File folder entitled Unit of Prosecution
+Research" containing attorney research and
+handwritten notes
+File folder entitled "Attorney Notes"
+containing attorney handwritten and typed
+File folder entitled "Drafts" containing
+draft indictments with attorney handwritten
+notes, draft internal memoranda, relevant
+witness interview reports and grand jury
+material and attorney handwritten notes
+File folder entitled "6/9/09 Signed
+Indictment" containing signed indictment
+package dated 6/9/2009 with corrections
+Litigation; Claims Against Public Prosecutor;
+Fiduciary Duty; Not in Anticipation
+Litigation; Claims Against Public Prosecutor;
+Litigation; Claims Against Public Prosecutor;
+6(e)
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+of Litigation;
+Investigative Privilege
+Invocation; Overriding Need; Claims Against
+Contains information
+Public Prosecutor; Attorney Conduct at Issue;
+subject to privacy rights of | Factual Materials; Court Authorized Under
+victims who are not
+6(e)(3)(E); Court Inherent Power to Release;
+6(e)
+Work product
+Deliberative process
+Attorney Conduct at Issue; Factual Materials;
+Court Authorized Under 6(e)(3)(E); Court
+
+
+
+Case 9:08-CV-80736 KAM Document 224-1 Entered on FLSD Docket 08/26/2013 Page 39 of
+Work product
+P-011778
+P-011788
+P-011789
+P-011879
+P-011880
+P-011922
+Description
+File folder entitled 6/12/09 Victim Notif.
+Log" containing chart with victim contact
+information and attorney notes regarding
+dates and type of contacts
+File folder entitled "Breach Memo"
+containing memorandum analyzing breach
+of Non-Prosecution
+Agreement
+with
+attachments
+File folder entitled "Overt Act Lists"
+handwritten notes
+crosschecking all overt acts alleged in draft
+indictment by victim and typed overt act
+summary charts for indictment preparation
+Work product
+Deliberative process
+Work product
+Attorney-client privilege
+Deliberative process
+6(e)
+Factual Materials; Not in Anticipation of
+Litigation; Claims Against Public Prosecutor;
+Fiduciary Duty; Not in Anticipation
+Attorney Conduct at Issue; Factual Materials
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+of Litigation;
+Government Communication; No Attorney-
+Client Relationship; Improper Invocation;
+Overriding Need; Claims Against Public
+Protect Cour ey Conted ties e
+Court Inherent Power to Release; Proper
+Material Severable
+
+
+
+P-011923
+P-011966
+P-011967
+P-012016
+Case 9:08Cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2023 Page 40 of
+Description
+Folder entitled Responses to Arguments
+from JE Counsel" containing:
+7/13/2007 letter from Lilly Ann
+Sanchez to Andrew
+with
+handwritten
+attorney
+notes;
+• 6/25/2007
+letter from
+Gerald
+Lefcourt to
+Menchal,
+Andrew
+and
+with handwritten
+attorney (
+notes;
+6/25/2007
+email from
+Andrew
+and
+entifled Thoughts on
+Letcourt's letter"
+Handwritten and typed attorney (
+notes regarding main themes raised by
+Epstein counsel
+Composition book entitled "Operation
+Leap Year"
+containing attorney
+handwritten notes regarding investigation
+and case strategy
+Work product
+Deliberative process
+6(e)
+Crime-Fraud-Misconduct;
+Crime-Fraud-
+Misconduct; Not in Anticipation of Litigation;
+Ordinary Government Communication; No
+Attorney-Client Relationship; Improper
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Factual Materials; Court Authorized Under
+6(e)(3)(E); Court Inherent Power to Release;
+release; Material Severable
+Work product
+Investigative privilege
+Fiduciary Duty; Factual Materials; Not in
+Contains information
+Invocation; Overriding Need; Claims Against
+subject to privacy rights of
+Public Prosecutor; Attorney Conduct at Issue;
+victims who are not
+Factual Materials; Court Authorized Under
+parties to this litigation
+6(e)(3)(E); Court Inherent Power to Release;
+| release; Material Severable; Redaction; No
+
+
+
+case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/26/2013 Page 41 of
+P-012017
+P-012055
+P-012056
+P-012088
+P-012089
+P-012129
+P-012130
+P-012150
+P-012151
+P-012167
+Motion of Jeffrey Epstein to Intervene and
+to Quash Grand Jury Subpoenas and
+Incorporated Memorandum of Law
+Affidavit of Roy Black, Esq. in Support of
+Motion of Jeffrey Epstein to Intervene and
+to Quash Grand Jury Subpoenas
+United States' Response to Motion of
+Jeffrey Epstein to Intervene and to Quash
+Grand Jury Subpoenas and Cross-Motion
+to Compel
+Declaration of Joseph Recarey
+6(e)
+6(e)
+6(e)
+Ex Parte Declaration Number One in
+Support of United States' Response to
+Motion to Quash Subpoenas
+Investigative Privilege
+Also contains information
+subject to privacy rights of
+victims who are not
+parties to this litigation
+Fiduciary Duty; Factual Materials; Court
+Authorized Under 6(e)(3)(E); Court Inherent
+Power to Release; Proper Victim's Petition;
+CVRA-authorized release; Material Severable
+Fiduciary Duty; Factual
+Materials; Court
+Authorized Under 6(e)(3)(E); Court Inherent
+Power to Release; Proper Victim's Petition;
+CVRA-authorized release; Material Severable
+Fiduciary Duty; Factual Materials; Court
+Authorized Under 6(e)(3)(E); Court Inherent
+Power to Release; Proper Victim's Petition;
+CVRA-authorized release; Material Severable
+Fiduciary Duty
+Fiduciary Duty; Factual Materials; Not in
+Anticipation of Litigation; Improper
+Invocation; Overriding Need; Factual
+Materials; Court Authorized Under 6(e)(3)(E);
+Court Inherent Power to Release; Proper
+Material Severable; Redaction; No Assertion
+by Victims
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 42 of
+P-012168
+P-012170
+Description
+Ex Parte Declaration Number Two in
+Support of United States' Response to
+Motion to Quash Subpoenas
+P-012171
+P-012173
+Supplement to Ex Parte Declaration
+Number One in Support of United States'
+Response to Motion to Quash Subpoenas
+P-012174
+P-012176
+Draft of September 2009 letter from
+to Roy Black regarding breach of
+Non Prosecution
+Agreement
+handwritten attorney (
+with
+notes
+P-012177
+P-012178
+Undated handwritten attorney (
+alepatio negarding
+negotiations
+and
+6(e)
+Investigative Privilege
+Need; Factual Materials; Court Authorized
+6(e)
+Investigative Privilege
+Fiduciary Duty; Factual Materials; Not in
+Also contains information
+Anticipation
+of Litigation;
+subject to privacy rights of
+Invocation;
+Overriding
+victims who are not
+Materials; Court Authorized Under 6(e)(3)(E);
+parties to this litigation
+Court Inherent Power to Release; Proper
+Material Severable; Redaction; No Assertion
+Litigation;
+Ordinary
+Government
+Communication;
+Attorney-Client
+Relationship; Improper Invocation; Overriding
+Ordinary
+Communication;
+Attorney-Client
+Relationship; Improper Invocation; Overriding
+| Attorney Conduct at Issue
+
+
+
+Entered on FLSD Docket 08/16/2013 Page 43 of
+P-012179
+P-012188
+Description
+File Folder entitled "FBI G.J. Log"
+containing copy of FBI grand
+subpoena log with attorney
+handwritten notes
+P-012362
+P-012451
+File folder entitled "Key Documents"
+containing correspondence between AUSA
+and case agent regarding indictment prep
+victim
+identification
+information,
+corrections
+draft
+indictment,
+indictment
+preparation
+timeline, key grand jury material
+P-012451
+P-012452
+File folder entitled "Victim List"
+containing list of victims with dates of
+birth and age information
+6(e)
+Fiduciary Duty; Factual Materials; Not in
+Investigative Privilege
+Anticipation
+Litigation;
+Improper
+Also contains information
+Invocation; Overriding Need; Claims Against
+subject to privacy rights of Public Prosecutor; Attorney Conduct at Issue;
+victims who are not
+Factual Materials; Court Authorized Under
+parties to this litigation
+6(e)(3)(E); Court Inherent Power to Release;
+Fiduciary Duty; Factual Materials; Not in
+Attorney-Client privilege
+Anticipation
+of Litigation;
+Investigative Privilege
+Government Communication; No Attorney-
+Also contains information
+Client Relationship; Improper Invocation;
+subject to privacy rights of
+Overriding Need; Claims Against Public
+victims who are not
+Prosecutor; Attorney Conduct at Issue; Factual
+parties to this litigation
+Materials; Court Authorized Under 6(e)(3)(E);
+Court Inherent Power to Release; Proper
+Material Severable; Redaction; No Assertion
+by Victims
+Investigative Privilege
+Fiduciary Duty; Factual Materials; Not in
+Also contains information
+Anticipation of Litigation;
+Improper
+subject to privacy rights of
+Invocation; Overriding Need; Claims Against
+victims who are not
+Public Prosecutor; Attorney Conduct at Issue;
+parties to this litigation
+Redaction; No Assertion by Victims
+
+
+
+P-012453
+P-012623
+P-012624
+P-012653
+P-012654
+P-012864
+P-012865
+P-013226
+Case 9:08 Cv-80736-KAM Document 221-1 Entered on FLSD Docket 08/16/2023 Page 41 of
+Description
+COnginal 1z120ment
+package marked
+Work-product
+Deliberative process
+Fiduciary Duty; Factual Materials; Not in
+6(e)
+Anticipation
+Also contains documents
+of Litigation;
+Invocation; Overriding
+subject to investigative
+Materials; Court Authorized Under 6(e)(3)(E);
+privilege
+Court Inherent Power to Release; Proper
+Also contains documents
+subject to privacy rights of
+Material Severable; Redaction; No Assertion
+victims who are not
+by Victims
+parties to this litigation
+3028 Contain reports or interies
+Investigative Privilege
+Also contains documents
+Fiduciary Duty; Factual Materials; Not in
+conducted in June 2007, October 2007, and
+subject to privacy rights of
+Anticipation
+of Litigation;
+Improper
+March 2008.
+victims who are not
+Invocation; Overriding Need; Redaction; No
+parties to this litigation
+3-ring binder entitled "Child Molesters: A
+Work-product
+Behavioral
+Analysis with
+attorney
+Fiduciary Duty; Overriding Need
+handwritten notes
+Indictment preparation binder containing:
+witness/victim
+with
+identifying
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+of Litigation; Improper
+Also contains documents
+Invocation; Overriding Need; Claims Against
+handwritten notes,
+subject to investigative
+Public Prosecutor; Attorney Conduct at Issue;
+portions of state investigative file, attorney
+privilege
+Factual Materials; Court Authorized Under
+o typed notes, relevant pieces of
+Also contains documents
+6(e)(3)(E); Court Inherent Power to Release;
+grand
+materials,
+telephone
+subject to privacy rights of
+records/flight records analysis charts,
+victims who are not
+victim/witness
+photographs, DAVID
+parties to this litigation
+records, NCICs, and related materials for
+persons identified as Jane Does #9, 10, 11,
+12, 13,14
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 45 of
+P-013227
+P-013226
+P-013230
+P-013231
+P-013239
+P-013240
+P-013247
+P-013248
+P-013251
+Description
+April 23, 2008 Memo from
+to Office of Professional Responsibility re
+Self Reporting, Corrected Version of the
+previously submitted April 21, 2008 Letter
+to OPR
+April 21, 2008 Letter from
+to Office of Professional Responsibility re
+Self Reporting
+April 22, 2008 Letter from
+to Office of Professional
+Responsibility re Self-Report of Allegation
+of Conflict of Interest
+April 21, 2008 Letter from
+to Office of Professional Responsibility re
+Self Reporting with attachments
+Privacy Act
+Privacy Act
+Privacy Act
+Privacy Act
+Factual Materials;
+Court
+Compelled
+Disclosure; Waiver
+Fiduciary Duty; Court Compelled Disclosure;
+Factual Materials; Waiver
+Factual Materials; Fiduciary
+Duty; Court
+Compelled Disclosure; Waiver
+Fiduciary Duty; Court Compelled Disclosure;
+Factual Materials; Waiver
+Ordinary Government Communication; No
+Attorney-Client Relationship; Waiver
+P-013252
+P-013253
+Ordinary Government Communication; No
+Attorney-Client Relationship; Waiver
+
+
+P-013260
+P-013262
+Attorney-Client Relationship; Waiver
+Formal Notice of Office-wide Recusal of
+Southern District of Florida dated August
+24, 2011. CC's David Margolis (ODAG),
+Jay Macklin (USAEO), Thomas Anderson
+(USAEO), Michelle Tapken (USAEO),
+James Read (USAEO)
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 46 of
+P-013254
+P-013257
+Description
+Emails between Richard Sudder, Assistant
+General Counsel, Executive Office for
+United States Attorneys, and Benjamin
+Greenberg, First Assistant U.S. Attorney,
+Southern District of Florida, regarding
+Formal Notice of Office-wide Recusal of
+Southern District of Florida dated August
+24 and August 29, 2011
+Emails between Richard Sudder, Assistant
+Attorney-Client Relationship; Waiver
+P-013258
+P-013259
+Ordinary Government Communication; No
+Attorney-Client Relationship; Waiver
+
+
+
+Case 9:08-cV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 47 of
+P-013263
+P-013271
+P-013272
+P-013278
+P-013279
+P-013280
+Description
+Emails between Richard Sudder, Assistant
+General Counsel, Executive Office for
+United States Attorneys, and Benjamin
+Greenberg, First Assistant U.S. Attorney,
+Southern District of Florida, regarding
+recusal of Southern District of Florida,
+dated July 29,
+with attached
+Benarand Urerberg summarizing Jeffrey
+Epstein Investigation
+Emails between Peter Mason, Executive
+Office, for, United States Attorneys, and
+1, Southern District of Florida,
+seeking advice regarding office-wide
+recusal, dated December 16 and 17, 2010,
+with attached latter from Paul Cassell to
+dated December 10,
+2010
+3/1S/08 Emails between A Acosta and
+and
+re proposed
+correspondence to Jay Lefkowitz
+Not in Anticipation of Litigation; Ordinary
+Government Communication; No Attorney-
+Client Relationship; Improper Invocation;
+Overriding Need; Claims Against Public
+Prosecutor; Attorney Conduct at Issue; Waiver
+Ordinary Government Communication; No
+Attorney-Client
+Relationship;
+Factual
+Materials; Waiver
+Handwritten note re Epstein investigation
+Investigative privilege
+Also contains information
+subject to privacy rights of
+victims who are not
+
+Crime-Fraud-Misconduct; Not in Anticipation
+of Litigation; Ordinary Government
+Communication;
+Attorney-Client
+Relationship; Claims
+Against
+Prosecutor; Overriding
+Need; Attorney
+Conduct at Issue; Waiver
+Fiduciary Duty; Factual Materials; Not in
+Anticipation
+of Litigation;
+Ordinary
+Government Communication; No Attorney-
+Client Relationship; Improper Invocation;
+Overriding Need; Claims Against Public
+
+
+P-013281
+Case 9:08-Cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 48 of
+Description
+parties to this litigation
+Prosecutor; Attorney Conduct at
+Redaction; No Assertion by Victims
+Issue;
+P-013282
+P-013283
+7/9/08 Email from
+A. Acosta, Li
+to
+and
+FBI re proposed response to Goldberger
+letter re victim notification
+Work product
+P-013284
+7/10/08 Emails between
+and
+and FBI
+re proposed response to Goldberger's
+letter e victim notification
+P-013285
+P-013289
+File folder entitled 8/5/08 AMCV e-
+mail romes arm" containine s/508
+email from
+to A.
+Acosta. IL
+re "Jeffrey Epstein Agreement"
+discussing 6/24/08 email from
+to R. Black and J. Goldberger
+concerning the binding nature of the
+Agreement
+Crime-Fraud-Misconduct;
+Crime-Fraud-
+Misconduct; Crime-Fraud-Misconduct; Factual
+Materials; Not in Anticipation of Litigation;
+Ordinary Government Communication; No
+Attorney-Client
+Relationship;
+Improper
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Waiver
+Crime-Fraud-Misconduct; Factual Materials;
+Not in Anticipation of Litigation; Ordinary
+Government Communication; No Attorney-
+Client Relationship; Improper Invocation;
+Overriding Need; Claims Against Public
+Prosecutor; Attorney Conduct at Issue; Waiver
+| No Factual Underpinnings; Fiduciary Duty;
+Crime-Fraud-Misconduct;
+Crime-Fraud-
+Misconduct; Not in Anticipation of Litigation;
+Ordinary Government Communication; No
+Attorney-Client Relationship; Improper
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue
+
+
+Entered on FLSD Docket 08/16/2013 Page 49 of
+P-013290
+P-013292
+P-013293
+P-013299
+P-013300
+Description
+File folder entitled "8/14/08 E-mail from
+Lefk to AMCV"
+containing. (undated)
+emails from
+to
+A.
+Acosta,
+re draft response to
+8/14/08
+from J. Lefkowitz
+regarding the December 2007 proposit
+File folder entitled 8/15/08 AMCV e-
+mail re Agrmt"
+8/15/08 e-
+mails from
+to
+Acosta.
+follow
+up
+Agreement and
+from A. Acosta to
+on issue of Special
+Master with attached 8/15/08 emails from
+re Agreement; 8/15/08 email from
+Lefkowitz to
+R. Black, M. Weinberg,
+Agreement:
+8/14/08 emails from
+to J. Lefkowitz,
+R. Black re interpretation of
+Apreement: email from i, Jetkowitz to
+questions re Agreement; email from
+to J. Lefkowitz,
+re production of Agreement to
+victims
+File folder entitled "8/18/08 Lefkowitz tr
+AMCV" containing
+handwritten draft notes for
+Fiduciary Duty; Crime-Fraud-Misconduct; Not
+in Anticipation of Litigation; Ordinary
+Government Communication; No Attorney-
+Client Relationship; Claims Against Public
+Prosecutor; Overriding
+Need;
+Attorney
+Conduct at Issue
+Factual Materials; Not in Anticipation of
+Litigation;
+Ordinary
+Government
+Communication;
+Attorney-Client
+Relationship; Improper Invocation; Overriding
+Attorney Conduct at Issue; Waiver
+in Anticipation Crimi Frong OMinonduet; Not
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 50 of
+P-0133303
+Description
+proposed letter to J. Lefkowitz: 5/22/07 c-
+mail from
+to M.
+re meeting
+with G. Lefcourt with attached email from
+G. Lefcourt re solicitation for meetings
+P-013304
+P-013325
+File folder entitled "6/25/07 Lefcourt to
+containing 6/25/07 letter
+(with handwritten notes by
+from G. Lefcourt to
+addressing reasons for not
+prosecuting Epstein: handwritten outline
+by
+of possible
+response to letter
+T File folder entitled "9/17/07
+P-013326
+Lefkowitz containing 9/17/07 e-mail from
+to R. Garcia,
+P-013329
+and from R. Garcia to
+concerning status of plea negotiations
+P-013330
+P-013333
+File folder entitled "11/8/07 Lefkowitz
+' containing 11/8/07 letter from
+J. Lefkowitz re issues arising during
+pendency of matter
+with
+attorney
+handwritten notes
+P-013334
+File folder entitled "11/13/07
+Lefkowitz (was this sent?)" containing
+draft 11/13/07 letter from
+Government Communication; No Attorney-
+Client Relationship; Claims Against Public
+Prosecutor; Overriding Need; Attorney
+Conduct at Issue; Waiver
+Fiduciary Duty; Crime-Fraud-Misconduct; Not
+in Anticipation of Litigation; Ordinary
+Government Communication; No Attorney-
+Client Relationship
+Prosecutor; Overriding Need; Attorney
+Conduct at Issue
+Litigation; Ordinary Government
+Communication; No Attorney-Client
+Relationship; Claims Against Public
+Prosecutor; Overriding Need; Attorney
+Conduct at Issue
+Litigation; Ordinary Government
+
+
+
+P-013337
+Case 9:08-CV-80736 KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 51 of
+Description
+responding to J. Lefkowitz's letter
+Communication; No Attorney-Client
+Relationship; Claims Against Public
+Prosecutor; Overriding Need; Attorney
+Conduct at Issue
+P-013338
+
+P-013342
+P-013350
+P-13351
+P-013361
+P-013362
+P-013366
+File folder entitled "12/6/07
+to
+Lefkowitz" containing 12/5/07 faxed letter
+w/ cover sheet from K. Starr and J.
+Lefkowitz to A. Acosta
+File folder entitled "12/05/07 Starr to
+Acosta" containing drafts of 11/30/07
+Acosta to K. Starr and
+to J. Lefkowitz re
+performance and victim notification with
+handwritten notes and edits by
+File folder entitled "12/21/07 Lefkowitz
+Acosta containing handwriten notes by
+12/21/07
+letter
+from J. Lefkowitz to A. Acosta re
+performance of NPA and appeal to
+Washington with attorney handwritten
+notes
+File folder labeled "12/26/07 Lefkowitz
+to Acosta" containing 2 copies of draft
+letter from A. Acosta to J. Lefkowitz
+(with 12/28/07 fax header)
+[Not considered
+privileged. Will be
+produced to opposing
+counsel upon lifting of
+Attomey-Stient Privilege
+folder labeled "Draft Itr from
+Factual Materials; Not in Anticipation of
+Litigation;
+Ordinary
+Communication;
+Relationship; Improper Invocation; Overriding
+Fiduciary Duty; Crime-Fraud-Misconduct; Not
+Anticipation of Litigation; Ordinary
+Government Communication; No Attorney-
+Client Relationship; Claims Against Public
+Prosecutor;
+Overriding
+Need;
+Factual
+Materials; Attorney Conduct at Issue
+Fiduciary Duty; Crime-Fraud-Misconduct; Not
+in Anticipation of Litigation; Ordinary
+Government Communication; No Attorney-
+Client Relationship; Improper Invocation;
+Overriding Need; Claims Against Public
+Prosecutor; Attorney Conduct at Issue
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 52 of
+P-013367
+P-013372
+P-013373
+P-013503
+P-013504
+P-013507
+Description
+to Lefkowitz re termination"
+containing draft letter dated "April,
+2008" from
+to J. Lefkowitz
+concerning
+the compliance with the
+Agreement
+File folder labeled "6/3/08
+Submission to the DAG" containing
+6/3/08 letter from
+to Mark
+Filip. Office of the DAG, ce'd to
+re jeffrey Epstein, detailing events
+concerning the Agreement and thereafter
+and with relevant attachments
+File folder labeled "Mtg w/ Ken Starr,
+RAA, JS. Drew" containing handwritten
+notes by.
+P-013508
+P-013514
+P-013515
+File folder labeled "Internal Corr."
+containing 11/28/07 e-mails from
+re
+responding to 11/28/07 e-mail from J.
+Lefkowitz to !
+regarding victim
+notification with attachments
+Draft 11/30/07 letter from A. Acosta to
+K. Starr co'd to !
+re compliance with Agreement
+Fiduciary Duty; Not in Anticipation
+of
+Litigation;
+Ordinary
+Government
+Communication;
+No
+Attorney-Client
+Relationship;
+Claims
+Against
+Public
+Prosecutor;
+Overriding
+Need;
+Attorney
+Conduct at Issue
+Investigative privilege
+Litigation;
+Ordinary
+Communication;
+No
+Government
+Attorney-Client
+Relationship; Improper Invocation; Overriding
+Vaividing Need; Atomey Conduct at Issue;
+Litigation;
+Ordinary
+Government
+Communication;
+Attorney-Client
+Proscenship ering
+Against
+Public
+Need; Attorney
+Conduct at Issue: Waiver
+[Factual Materials; Not in Anticipation of
+-Litigation;
+Ordinary
+Government
+Communication;
+Relationship; Claims
+Attorney-Client
+Against
+Public
+Prosecutor; Overriding
+Need; Attorney
+Conduct at Issue; Factual Materials; Waiver
+Fiduciary Duty; Crime-Fraud-Misconduct; Not
+Anticipation of Litigation; Ordinary
+
+
+
+P-013525
+P-013526
+P-013527
+P-013528
+P-013530
+P-013532
+P-013537
+P-013531
+case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 53 of
+Description
+and internal emails from
+Acosta, and
+re items to
+address in letter
+5/23/07 comail from
+tol
+re draft proposed internal
+e-mail about handling of case and
+attached email correspondence between
+Andrew
+; and G. Lefcourt
+Handwritten notes by
+dated 9/21 re telephone conference with
+possible victim representative, conflict
+hanks of potenis and ime rised list of
+Calmito, mai conting contactine
+for potential victim representative, draft
+Non Prosecution Agreement dated
+9/10/074:17 pm
+Typed note addressed to "Dear David" re
+response to grand jury subpoena
+Government Communication; No Attorney-
+Client Relationship; Improper Invocation;
+Overriding Need; Claims Against Public
+Prosecutor; Attorney Conduct at Issue;
+Waiver; Factual Materials
+Fiduciary Duty; Not in Anticipation
+of
+Litigation;
+Ordinary
+Government
+Communication;
+Attorney-Client
+Relationship; Improper Invocation; Overriding
+Attorney Conduct at Issue; Factual Materials
+Fiduciary Duty; Factual Materials; Not in
+Anticipation of Litigation; Claims Against
+Public Prosecutor; Overriding Need; Attorney
+6(e)
+Investigative privilege
+P-013538
+File folder labeled "Notes Re Post-
+Agreement Communications" containing
+Need; Factual Materials; Court Authorized
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 54 of
+P-013553
+Description
+handwritten notes by
+Privileges) Asserted
+P-013554
+File folder labeled "E-mails Re Plea
+Negotiations" containing:
+• 11/28/07 c-mail from
+A. Oosterbaan,
+R. Garcia re non-prosecution
+agreement,
+with
+attached
+correspondence;
+• 9/19/07 e-mail from
+to l
+R. Garcia,
+re negotiating strategy, with
+attached correspondence;
+9/18/07
+_e-mail from
+Jo A. Acosta,
+•
+9717/07
+_e-mail from
+to A. Acosta re negotiation;
+•
+9/17/07
+e-mail from
+to R. Garcia, A. Acosta,
+J. McMillan re
+negotiations;
+9/17/07
+e-mail from
+I to R. Garcia,
+negotiation strategy;
+9/14/07
+e-mail from
+to
+Carproposed plaagreement and
+Information
+Investigative Privilege
+Attorney Conduct at Issue; Factual Materials
+Crime-Fraud-Misconduct; Not in Anticipation
+of Litigation; Ordinary Government
+Communication;
+Attorney-Client
+Relationship; Improper Invocation; Overriding
+Attorney Conduct at Issue; Waiver; Final
+Decision
+
+
+
+Case 9:08-cv-80736-KAM Document 224-1, Entered on FLSD Docket 08/16/2013 Page 55 of
+Description
+9/14/07
+e-mail
+from
+Acosta,
+R Garcia,
+McMillan, S. Ball re plea negotiation
+9/13/07
+e-mail
+from
+I to J.
+S. Ball, J.
+McMillan re indictment package:
+9/13/07
+e-mail from
+to A. Oosterbaan re trust
+agreement
+with
+attached
+correspondence
+• 9/13/07
+e-mail
+from
+to A. Oosterbaan
+2
+trust
+agreement
+9/13/07 e-mail from
+Villafaña to R. Garcia,
+conference call with J. Lefkowitz:
+9/13/07
+e-mail
+to
+from
+negotiations
+with
+correspondence;
+• 9/13/07
+e-mail
+to
+from
+re plea
+attached
+strategy
+correspondence;
+• 9/13/07
+e-mail
+with
+re charging
+attached
+from
+S. Ball, J.
+McMillan re indictment package:
+• 9/13/07 e-mail from
+to A. Acosta.
+Garcia,
+negotiations;
+re plea
+
+
+
+Case 9:08-Cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 56 of
+Description
+9/11/07
+e-mail
+Lefcourt
+correspondence;
+• 9/11/07 e-mail
+from
+re meeting w/
+with
+attached
+from
+re revised
+attached
+Agreement
+with
+correspondence;
+• 9/11/07 e-mail
+to i
+from
+prosecution agreement
+re
+nonedits
+with
+attached correspondence;
+9/11/07 e-mail from
+o A. Oosterbaan re status of
+negotiations
+with
+attached
+correspondence;
+9/10/07
+_e-mail
+to l
+e-mail
+from
+are negotiations;
+9/10/07
+from
+J. McMillan re
+state grand jury proceedings;
+9/17/07 e-mail from A. Acosta to
+R. Garcia,
+. McMillan re draft
+Agreement
+with
+attached
+correspondence;
+• 9/14/07 e-mail from .
+to
+A. Acosta, R. Garcia,
+S. Ball, re
+finalizing documents;
+9/14/07 e-mail from
+to .
+re charging strategy
+
+
+P-013616
+File folder entitled "Atty Notes re
+Revised
+Indictment"
+containing
+
+
+case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 57 of
+P-013609
+P-013615
+Description
+with attached correspondence;
+• 2/13/07 e-mail from A. Oosterbaan to
+re setting up trust
+fund;
+• 9/13/07 e-mail from
+re final negotiations
+• 9/11/07 e-mail from
+with attached correspondencci to
+re scheduling a
+meeting
+regarding
+finalizing the
+agreement
+with
+attached
+correspondence;
+• 9/11/07 e-mail from
+to A.
+Marie Villafaña re non-prosecution agree
+•
+9/11/07 e-mail from
+to A.
+Marie Villafaña re non-prosecution agree!
+• 9/11/07 e-mail from A. Oosterbaan to
+with attached corresponden
+re negotiations
+- 97/012 c-mail from re
+to R. Garcia
+negotiation strategy
+File folder entitled "D Target Letter"
+containing copy of signed letter and
+contact info for counsel for target
+6(e)
+Investigative Privilege
+Inadegate Luty: Not in Anticipaion of
+Need Factual Mater is Cour Outhorized
+
+S-0130443
+P-013653
+P-013654
+P-013745
+P-0013747
+Negotiations ended * 9% 7 Ple
+to J. Richards, N.
+re status update; undated and
+vard handwriten notes by
+re items to be completed on
+case, strength of case, victim interviews,
+summary
+guidelines
+calculations
+File folder entitled "Plea Agreement
+Drafts" containing several draft plea
+seems come with advis or dracs
+; copies of draft
+non-prosecution agreement some with
+handwritten notes byl
+copy of a draft Information
+File folder
+entitled
+Prosecution
+Agreements"
+"Draft
+Noncontaining
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 58 of
+P-013621
+Description
+handwritten notes by
+P-013622
+P-013643
+File folder entitled "Research Re Possible
+Misdemeanors"
+containing
+attorney
+research
+Anticipation of Litigation; Ordinary
+Investigative Privilege
+Government Communication; No Attorney-
+Also contains information
+Client Relationship; Improper Invocation;
+subject to privacy rights of
+Overriding Need; Claims Against Public
+victims who are not
+Prosecutor; Attorney Conduct at Issue
+parties to this litigation
+Work product
+Lidation, Cats Against Public Prosecutor
+Fiduciary Duty; Factual Materials; Not in
+of Litigation; Ordinary
+Investigative privilege
+Government Communication; No Attorney-
+Also contains information
+Client Relationship; Improper Invocation;
+subject to privacy rights of
+Overriding Need; Claims Against Public
+victims who are not
+Prosecutor; Attorney Conduct at Issue; Waiver
+parties to this litigation
+Litigation;
+Ordinary
+Government
+Attorney-Client
+Relationship; Improper Invocation; Overriding
+| Fiduciary Duty; Not in Anticipation
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 59 of
+P-013810
+P-013811
+P-013833
+Description
+several draft non- prosecution agreements
+some with handwritten notes by
+plea sheet State Circuit Court;
+copies of draft Information; draft plea
+proffer; draft motion and order to seal;
+draft penalty sheet; draft plea agreement
+File folder entitled "Information Packet
+Drafts" containing several drafts of
+Informations,
+and
+complete draft
+Information packet
+
+Through P-
+
+P-013836
+P-013837
+P-013838
+P-013841
+P-013842
+Two pages of filed document, D.E. 62,
+page 2 of 54 and page 6 of 54,
+containing handwritten attorney notes
+Palm Beach Daily News Article,
+"Attorneys
+want Jeffrey
+Epstein
+Agreement
+Thrown Out,"
+with
+attorney's notes written on margin
+Letter from Paul Cassell to
+December 10, 2010, Subject:
+Request for Investigation of Jeffrey Epstein
+Prosecution, with underlines, written notes,
+and comments by DOJ attorney
+Email from Dexterr Lee to
+Re: request for
+Investigation - Jeffrey sepstein Non-
+Prosecution Agreement
+Atty work-product
+Atty work-product
+Atty work-product
+Atty work-product
+Atty-client privilege
+Litigation;
+Ordinary
+Government
+Communication;
+No
+Attorney-Client
+Relationship; Improper Invocation; Overriding
+Attorney Conduct at Issue; Factual Materials
+Litigation;
+Communication;
+Ordina Attorneyrient
+Relationship; Improper Invocation; Overriding
+Fiduciary Duty; Claims Against Public
+Prosecutor; Overriding Need; Attorney
+Conduct at Issue
+Fiduciary Duty; Claims Against Public
+Prosecutor; Overriding
+Need; Attorney
+Conduct at Issue
+Fiduciary Duty; Claims Against Public
+Prosecutor; Overriding Need; Attorney
+Conduct at Issue
+Factual Materials; Ordinary Government
+Communication;
+Attorney-Client
+Relationship; Claims Against
+Public
+Prosecutor; Overriding
+Need;
+Attorney
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 60 of
+P-013843
+P-013844
+P-013845
+P-013846
+P-013847
+P-013849
+P-013850
+P-013851
+P-013853
+P-013854
+Description
+E-mail.
+to Andrew
+and
+September 19, 2007, 4:33 p.m., RE: Plea
+Agreement
+E-mail, Andrew
+to
+September rit9 i2oal t2s. Atomey's
+Office e-mails attached
+E-mail,
+to Andrew
+and
+September 18, 2007, 11:43 a.m., RE: Draft
+with e-mail from Jay
+greme September 18, 2007, 11:09
+a.m.) attached
+E-mail,
+to Alex Acosta,
+Andrew
+McMillan,
+September 13, 2007, 9:31 a.m. lan:
+Epstein Negotiations
+E-mail,
+to
+and Andrew
+September
+17, 2007, 10:35 a.m., RE: Epstein
+[providing update re plea negotiations]
+E-mail,
+to Andrew
+Oosterbaan, September 13, 2007, 8:10
+p.m., RE: Epstein, with e-mail from
+Andrew Oosterbaan (September 13, 2007,
+7:54 p.m.), attached
+to Jeff
+Atty work-product
+atty-client privilege
+Atty work-product
+Atty work-product
+Conduct at Issue
+Fiduciary Duty; Ordinary Government
+Communication;
+No
+Attorney-Client
+Relationship; Waiver; Claims Against Public
+Prosecutor; Overriding Need;
+Attorney
+Conduct at Issue
+Fiduciary Duty; Claims Against Public
+Prosecutor; Overriding Need;
+Attorney
+Conduct at Issue
+Fiduciary Duty; Claims Against Public
+Prosecutor; Overriding
+Need; Attorney
+Conduct at Issue Waiver
+Atty work-product
+Atty work-product
+Atty work-product
+Misconduct; Waiver; Claims Against Public
+Prosecutor; Overriding Need;
+Attorney
+Conduct at Issue
+Fiduciary Duty; Claims Against Public
+Prosecutor; Overriding
+Need; Attorney
+Conduct at Issue
+Claims Against Public Prosecutor; Overriding
+Need; Attorney Conduct at Issue
+| Inadequate Log; No Factual Underpinnings;
+Atty work-product
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 61 of
+P-013855
+Description
+and Andrew
+September 10,
+2007, 5:24 p.m., RE: FBI
+Atty-client privilege
+P-013856
+P-013857
+P-013858
+Suppl. Box
+P-013859
+P-013860
+P-013861
+P-013865
+P-013866
+P-013867
+E-mail,
+to Jeff
+September 6, 2007, 5:47 p.m.. RE: Epstein,
+with e-mail from Jeff
+(September
+6, 2007, 5:35 p.m.), attached
+Email,
+to Jeff
+September 6, 2007, 9:29 a.m., Re: Meeting
+on Friday
+Email.
+Gerald Lefcourt to
+Lilly Ann Sanchez, Roy
+Black, re: Jeffrey Epstein
+E-mail.
+Epstein, with c- mail from
+2007, 3:30 p.m.),
+(IN 4 2007, 5:16 p.m.), and
+g
+(July 3, 2007, 1:47
+p.m.), attached
+E-mail.
+to Jeff
+Andrew
+and Shawn Ball, July 3,
+2007, 6:26 a.m., RE: Epstein
+E-mail.
+to
+June 21, 2007, 3:24 p.m., RE:
+Meeting Next Week, with e-mails from
+Atty work-product
+Atty-client privilege
+atty work-product
+[Not considered
+privileged. Will be
+produced to opposing
+counsel upon lifting of
+stay]
+Atty work-product
+atty-client privilege
+Need; Attorney
+Conduct
+Issue
+Communication;
+No
+Attorney-Client
+Relationship
+Ordinary Government Communication; No
+Attorney-Client Relationship; Claims Against
+Public Prosecutor; Overriding Need; Attorney
+Conduct at Issue
+Claims Against Public Prosecutor; Overriding
+Need; Attorney Conduct at Issue
+Atty work-product
+Atty work-product
+Ordinary Government Communication; No
+Attorney-Client Relationship; Waiver; Claims
+Against Public Prosecutor; Overriding Need;
+Crime-Fraud-Misconduct;
+Waiver; Claims
+Against Public Prosecutor; Overriding Need;
+Waiver; Claims Against Public Prosecutor;
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 62 of
+P-013868
+P-013869
+P-013870
+P-013871
+P-013872
+P-013873
+Suppl. Box
+3P-
+
+Description
+p.m.), and
+2007, 1:37 p.m.), attached
+E-mail,
+JeffE
+(June 21, 2007, 2:58
+(June 21,
+to
+Andrew
+and
+June 18, 2007, 5:04 p.m.,
+RE: Epstein
+E-mail,
+Andrew
+May 24, 2007, 9:25 a.m., FWa
+Jeffrey Epstein, with e-mail from Gerald
+Lefcourt to Andrew
+May 23,
+2007, 5:00 p.m.), Andrew
+Gerald Lefcourt (May 22, 2007, 6:32
+p.m.), and Gerald Lefcourt to Andrew
+and Lilly Ann
+Sanchez
+May 22, 2007, 2:05 p.m.),
+attached
+E-mail,
+Andrew
+to
+Jeff
+and
+May 22, 2007, 3:11 p.m., FW:
+Jeffrey Epstein,
+with
+e-mail
+from
+Lefcourt to !
+and Lilly
+Ann Sanchez (May 22, 2007, 2:05 p.m.),
+attached
+E-mail
+May
+14, 200%,
+and
+10:52 a.m.,
+RE:
+Operation Leap Year, with e-mail from
+and
+(May
+14, 2007, 10:38 a.m.), attached
+Treproteety marked as privileged, will
+Atty work-product
+Atty work-product
+Waiver; Claims Against Public Prosecutor;
+Prosecutor; Overriding
+Need; Attorney
+Conduct at Issue
+Atty work-product
+Waiver; Claims Against Public Prosecutor;
+Atty work-product
+| Inadequate Log; No Factual Underpinnings;
+Fider Claims A Gains Public Prosecutor:
+
+
+
+P-013875
+P-013876
+P-013877
+P-013878
+P-013879
+P-013880
+P-013882
+Lase 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 63 of
+Description
+E-maill
+Garcia,
+and
+, September 19, 2007, 4:33 p.m.,
+RE: Draft Plea Agreement. with e-mail
+from Lefkowitz to
+(September
+19. 2007, 3:44 p.m.), and Lefkowitz to
+(September 19, 2007, 3:35 p.m.)
+attached
+E-mail,
+, September 19,
+2007,421 p.m
+, RE: Enstein, with e-mails
+from
+to
+and Garcia
+(Sentember
+2007,
+4:13 p.m.),
+to
+and Garcia (Sentember
+12. 2007,
+4:05 p.m.), and
+and Garcia
+ptember
+7s0a, mie 19 2007, 236 p.m.,1
+(Sentember
+p.m.), and |
+to
+and aris
+(September 19.2007.2:31 p.m.), attached
+to
+Garcia,
+and
+September 18, 2007, 11:43
+a.m., RE: Draft Agreements?, with e-mails
+Garcia and
+(September 18, 2007, 11:18a.m.),
+Atty work-product
+Atty work-product
+Atty work-product
+Fiduciary Duty; Waiver; Claims Against
+Public Prosecutor; Overriding Need; Attorney
+Conduct at Issue
+Fiduciary Duty; Claims Against Public
+Prosecutor; Overriding Need; Attorney
+Conduct at Issue
+Waiver; Claims Against Public Prosecutor;
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 64 of
+P-013883
+P-013884
+P-013886
+P-013887
+P-013888
+P-013889
+P-013890
+P-013891
+Suppl. Box
+Description
+E-mail,
+to Acosta,
+McMillan,
+September 18, 2007, 93 mi
+Epstein Negotiations
+E-mail,
+to Garcia and
+September 17, 2007 10:35 a.m., RE:
+Epstein,
+with
+(September
+e-mail
+from
+Garcia
+17, 2007, 10:26 a.m.),
+attached
+E-mail,
+to Andrew
+Oosterbaan, September 13, 2007, 8:10
+p.m., RE: Epstein, with e-mail from
+Andrew Oosterbaan (September 13, 2007,
+7:54 p.m.). attached
+E-mail, |
+to Jeff
+and Andrew
+September 10,
+2007, 5:24 p.m., RE: FBI
+E-mail,
+to Jeff
+September 6, 2007, 5:47 p.m. RE: Epstein,
+with e-mail from Jeff
+(September
+6, 2007, 5:35 p.m.), attached
+Email,
+to Jeff
+September 6, 2007, 9:29 a.m., Re: Meeting
+on Friday
+Email.
+Gerald
+Lefcourt to
+Lilly
+Ann Sanchez, Roy
+Atty work-product
+Atty work-product
+Atty work-product
+Atty work-product
+Atty-client privilege
+Atty work-product
+Atty-client privilege
+atty work-product
+Crime-Fraud-Misconduct;
+Waiver; Claims
+Against Public Prosecutor; Overriding Need;
+Fiduciary Duty; Waiver; Claims Against
+Public Prosecutor; Overriding Need; Attorney
+Conduct at Issue
+Pidlic Prosecutor Weriding Necd, Atomist
+Conduct at Issue
+Attorney-Client
+Relationship; Waiver; Claims Against Public
+Prosecutor; Overriding Need; Attorney
+Conduct at Issue
+Communicatiouty: Ordinary Arentent
+Attorney-Client
+Relationship;
+Claims
+Prosecutor;
+Against
+Public
+Overriding
+Need; Attorney
+Conduct at Issue
+Fiduciary Duty; Claims Against Public
+Prosecutor; Overriding Need;
+Attorney
+Conduct at Issue
+[Not considered
+privileged. Will be
+
+
+Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 65 of
+P-013893
+P-013894
+P-013898
+produced to opposing
+counsel upon lifting of
+stay]
+Atty work-product
+atty-client privilege
+P-013899
+P-013900
+P-013901
+P-013902
+P-013903
+P-013904
+E-mail.
+to
+July 13, 2007, 3:14 p.m., RE:
+Epstein, with e-mail from
+(July
+2007, 3:30 p.m.),
+to
+(July 4. 2007, 5:16 p.m.), and
+(July 3, 2007, 1:47
+p.m.), attached
+E-mail.
+to Jeff
+Andrew
+and
+, July 3,
+2007, 6:26 a.m., RE: Epstein
+E-mail.
+to
+June 21, 2007, 3:24 p.m., RE:
+Meeting Next Week, with e-mails from
+p.m.), and
+2007, 1:37 p.m.), attached
+10 21 200 28
+E-mail,
+to
+Jeff
+Andrew
+and
+RE: Epstein
+June 18, 2007, 5:04 p.m.,
+E-mail.
+Andrew
+5
+May 24, 2007, 9:25 a.m., FW:
+Jeffrey Epstein, with e-mail from Gerald
+Lefcourt to Andrew
+May 23,
+2007, 5:00 p.m.), Andrew
+Gerald Lefcourt (May 22, 2007, 6:32
+p.m.), and Gerald Lefcourt to Andrew
+and Lilly Ann
+Atty work-product
+Atty work-product
+Atty work-product
+Atty work-product
+Ordinary Government Communication; No
+Attorney-Client Relationship; Claims Against
+Public Prosecutor; Overriding Need; Attorney
+Conduct at Issue
+Waiver; Claims Against Public Prosecutor;
+Cad, Armiey Condie Prosecuter Overiding
+Waiver; Claims Against Public Prosecutor;
+Fiduciary Duty; Waiver; Claims Against
+Public Prosecutor; Overriding Need; Attorney
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 66 of
+P-013905
+Description
+Sanchez (May 22, 2007, 2:05 p.m.),
+E-mail.
+Andrew
+Jeff
+and
+May 22, 2007, 3:11 p.m., FW:
+Jeffrey Epstein.
+with
+e-mail from
+Lefcourt to
+Atty work-product
+Claims Against Public Prosecutor; Overriding
+Need; Attorney Conduct at Issue
+P-013906
+Atty work-product
+May 14,
+2007,
+10:52
+Macion Leano ear i email tom
+and
+(May
+14, 2007, 10:38 a.m.), attached
+Inadvertently marked as privileged, will
+be produced
+Public Proscior Overing ied, Attormey
+Conduct at Issue
+Suppl. Box
+3 P.
+
+P-013908
+P-013909
+P-013911
+P-013912
+P-013914
+Memorandum,
+Assistant
+Counsel, U.S. Department of Justice,
+Office of Professional Responsibility
+(OPR), to
+Associate Counsel,
+OPR,
+Acting
+undated,
+Subject: Recommendation
+Memorandum, [
+Assistant
+Counsel, OPR, to
+Acting Associate Counsel, OPR, Subject:
+Recommendation, with handwritten note
+Memorandum,
+Assistant
+Privilege; atty workproduct
+Privilege, atty workproduct
+Factual Materials; Improper Invocation; Final
+Decision; Waiver; Claims Against Public
+Prosecutor; Overriding Need; Attorney
+| Fiduciary Duty; Crime-Fraud-Misconduct;
+Factual Materials; Improper Invocation;
+Waiver; Final Decision; Claims Against Public
+Need;
+Attorney
+
+
+
+P-013915
+P-013918
+P-013919
+P-013921
+P-013922
+P-013924
+P-013925
+P-013927
+P-013928
+P-013930
+P-013931
+P-013933
+Case 9:08-Cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/26/2013 Page 67 of
+Description
+Counsel, OPR, to
+Acting Associate Counsel, OPR, Subject:
+Recommendation, with two post-it notes
+attached with handwritten attorney
+notations, and handwritten notations,
+underlines, and circled text throughout
+the body of the two page memorandum
+Draft letter, marked "Confidential", from
+Counsel, Office of
+Professional Responsibility to
+United States Attorney, with
+handwritten corrections, strikethroughs,
+and added text
+Draft Letter. marked "Confidential". from
+to
+with handwritten corrections
+Draft Letter, from
+Professor Paul G.
+handwritten correction
+Cassell,
+with
+Draft Letter, from
+Professor Paul
+Cassell,
+handwritten corrections
+to
+with
+Draft Letter, from
+to
+Pandesire cuttions, cield text,
+Privilege; atty workproduct
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+
+Factual Materials; Improper Invocation;
+Waiver; Final Decision; Claims Against Public
+Prosecutor; Overriding Need;
+Attorney
+Conduct at Issue
+Fiduciary Duty; Not in Anticipation
+Attorney Conduct at Issue; Waiver; Final
+Decision
+Fiduciary Duty; Not in Anticipation
+Fiduciary Duty; Not in Anticipation
+Inadequate Log; No Factual Underpinnings:
+
+
+Entered on FLSD Docket 08/16/2013 Page 68 of
+Suppi. Box 3
+P-013934
+P-013936
+P-013937
+P-013939
+P-013940
+P-013942
+P-013943
+Suppi. Box 3
+P-013944
+Description
+strikethroughs, and additional text
+Draft Letter.
+marked
+"Confidential"
+from
+. with handwritten corrections
+Draft Letter, L
+Professor Paul
+Cassell,
+handwritten corrections
+to
+with
+Draft Letter, marked "Confidential: To Be
+Opened by Address Deli
+with
+handwritten corrections
+E-mail.
+1, May 5, 2011, 11:19 a.m., RE:
+Rewrite of Epsteir netters for Your
+reviey with e-mail from
+May 5.2011, 11:08
+a.m.), and
+May
+5. 2011. 11:10 a.m.), and
+(May 5, 2011, 10:41 a.m.),
+attached
+E-mail,
+2011,
+to
+May 5,
+11:17 a.m., RE:
+Re-write of Enstein letti
+Your review, with e-mail from
+May 5, 2011,
+11:08
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+Privilege
+Attorney Work Product
+Attorney Conduct at Issue; Waiver
+Privilege
+Attorney Work Product
+Privilege
+Improper Invocation; Overriding Need; Final
+Decision; Waiver
+
+
+case 9:08-Cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 69 of
+P-013945
+P-013946
+Description
+to
+May 5. 2011,
+11:01 a.m.), and
+(May 5, 2011, 10:41), attached
+E-mail,
+5
+May 4,
+2011, 5:01 p.m., RE: draft letters in Epstein
+matter. with e-mail from
+(May 4, 2011, 4:57 p.m.),
+attached
+E-mail,
+May 4, 2011, 4:08 p.m., RE: FYI on the
+Florida matter
+SP-01 39473 2o ai, Paul Casell ol
+May 3,
+2011,12:23 p.m., RE: OPR Inquiry -
+request for information, with post-it note
+attached with handwritten attorney notes
+on telephone call between
+and
+with |
+and
+P-013948
+P-013951
+P-013952
+P-013953
+E-mail,
+and
+May 3, 2011, 12:30 p.m., FW:
+OPR Inquiry - request for information,
+with
+attached e-mails.
+attorney notes on margin
+E-mail,
+March 16, 2011, 10:52 a.m., RE: Referral
+of Cassell Request for Investigation, with
+e-mail from Paul Cassell to
+(March 15, 2011, 7:21
+p.m.), attached
+E-mail,
+to Neil Hurley, OPR,
+Privilege
+Improper Invocation; Overriding Need
+Law Enforcement
+investigatory record, atty
+work product; deliberative
+process privilege
+atty work product; law
+enforcement
+investigatiory
+record
+Not in Anticipation of Litigation; Improper
+Invocation; Overriding Need; Claims Against
+Public Prosecutor; Attorney Conduct at Issue;
+Final Decision; Waiver
+Crime-Fraud-Misconduct; Factual Materials;
+Not in Anticipation of Litigation; Improper
+rubie Prosecutor, Armed Condiet at suet
+| Factual Materials; Final Decision
+atty work-product
+atty work-product; attyclient privilege
+Crime-Fraud-Misconduct; Factual Materials;
+Claims Against Public Prosecutor; Overriding
+Need; Attorney Conduct at Issue
+Ordinary Government Communication; No
+Attorney-Client Relationship; Claims Against
+Public Prosecutor; Overriding Need; Attorney
+Conduct at Issue
+atty work-product, atty-
+
+
+
+Case 9:08-CV-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 70 of
+P-013954
+P-013955
+P-013956
+P-013846
+Description
+December 16, 2010, 10:59 a.m., FW: OPR
+Referral - Allegation of Misconduct -
+mail Aomey's Office, SDFla, with e-
+(December
+16, 2010, 10:22 a.m.),
+attached. Handwritten attorney notations.
+Fourteen (14) pages of handwritten
+attorney notes on case, telephone
+interviews with DOJ attorneys
+client privilege
+atty work-product
+Factual Materials; Ordinary Government
+Communication;
+No
+Attorney-Client
+Relationship; Waiver; Claims Against Public
+Prosecutor; Overriding
+Need;
+Attorney
+Fiduciary Duty; Material Severable; Crime-
+Fraud-Misconduct; Factual Materials; Claims
+Atome Conduct At stutor, Overriding Need;
+
+
+
+P:090i
+
+Case 9:08-CV-80736-KAM Document 225 Entered on FLSD Docket 08/16/2013 Page 5 of 10
+not to provide legal advice or assistance to the police officers but rather to provide the city with
+information relating to alleged indiscretion within the department).
+Attorney-Client Relationship Not Established. Any attorney-client privilege has not
+been properly invoked because the Government has not provided factual material identifying
+who is the attorney, who is the client, and how the communications were confidential. See Bogle
+v. McClure, 332 F.3d 1347, 1358 (11th Cir. 2003).
+B. Deliberative Process Privilege
+Privilege Not Properly Invoked - Any deliberative process privilege has not been
+properly asserted, because it must be asserted by the head of the department having control over
+the requested information who must explain why revealing the information would compromise
+deliberative processes. See Landry v. F.D.I.C., 204 F.3d 1125, 1135 (D.C. Cir. 2000).
+Final Decision Exempted from Privilege - Any deliberative process privilege would
+only cover only the processes by which a decision was made, not the final decision itself. See,
+e.g., NLRB v. Sears Roebuck & Co., 421 U.S. 132, 151-52 (1975).
+Qualified Privilege Overridden By the Victims' Need for the Documents - Any
+deliberative process privilege would be a qualified privilege, which would be overridden by the
+victims' compelling need to obtain the materials here. See, e.g., Newport Pac., Inc. v. County of
+San Diego, 200 F.R.D. 628, 638-41 (S.D. Cal. 2001) (in action charging county Board of
+Supervisors with violating Federal Fair Housing Act, the interest in free expression by policy
+makers during the deliberative process leading up to those actions was outweighed by the
+litigant's interest in obtaining information concerning those deliberations).
+C. Investigative Privilege
+4
+
+
+Case 9:08-cv-80736-KAM Document 225 Entered on FLSD Docket 08/16/2013 Page 6 of 10
+Privilege Not Properly Invoked - Any investigative privilege has not been properly
+asserted, because it must be asserted by the head of the department having control over the
+requested information who must explain why revealing the information would compromise
+deliberative processes. See Landry v. F.D.I.C., 204 F.3d 1125, 1135 (D.C. Cir. 2000).
+Qualified Privilege Overridden By the Victims' Need for the Documents - Any
+investigative privilege would be a qualified privilege, in which the public interest in
+nondisclosure must be balanced against the need of a particular litigant for access to the
+privileged information.
+Tuite v. Henry, 98 F.3d 1411, 1418 (D.C. Cir. 1996). The balancing is
+ordinarily made by considering the ten factors identified in Frankenhauser v. Rizzo, 59 F.R.D.
+339, 344 (E.D. Pa. 1973). Those ten factors decisively tip in favor of the victims receiving
+access to the information.
+D. Work Product Doctrine.
+No Work Product Doetrine in the Context of a Claim Against Public Prosecutors -
+The work product doctrine does not apply to claims advanced by crime victims that federal
+prosecutors have violated their public responsibilities under the Crime Victims' Rights Act. See
+U.S. v. Arthur Young & Co., 465 U.S. 805, 817 (1984) (refusing to extend work product privilege
+to public accountants, because they have a public responsibility transcending any employment
+relationship with the client"); In re Grand Jury Subpoena, 112 F.3d at 919-21 ("the strong public
+interest in honest government and in exposing wrongdoing by public officials would be illserved by recognition of
+a governmental attorney-client privilege applicable in criminal
+proceedings inquiring into the actions of public officials.").
+5
+
+
+Case 9:08-CV-80736-KAM Document 225 Entered on FLSD Docket 08/16/2013 Page 7 of 10
+Qualified Privilege Overridden By the Vietims' Need for the Documents - The work
+product doctrine is a qualified privilege that can be overcome where a litigant shows it has a
+substantial need for the materials and that it has exhausted other means of obtaining the relevant
+information it seeks. In re Grand Jury Subpoena Dated July 6, 2005, 510 F.3d 180, 185-86 (2d
+Cir. 2007). The victims here can make this showing.
+Work Production Privilege Does Not Apply When the Attorney's Conduct is at
+Issue - If the attorney's conduct is a central issue in the case, the work-production protection
+does not apply. See, e.g., In re John Doe, 662 F.2d 1073, 1080 (4th Cir. 1981); Charlotte Motor
+Speedway, Inc. v. International Ins. Co., 125 F.R.D. 127, 130 (M.D.N.C. 1989).
+E. Rule 6(e) - Grand Jury Secrecy
+Court-Authorized Disclosure Not Covered Under Rule 6(e)(3)(E) - The Court can
+authorize disclosure of grand jury materials pursuant to Fed. R. Crim. P. 6(e)(3)(E). It has
+already authorized disclosure of grand jury materials here, and the Government has no
+independent "privilege" to interpose against court-ordered disclosure of grand jury materials.
+The Court Has Inherent Power to Release Grand Jury Materials - The Court has
+"inherent power beyond the literal wording of Rule 6(e)(3) to disclose grand jury material" and
+has properly exercised that power here. United States v. Aisenberg, 358 F.3d 1327, 1347 (11th
+Cir. 2004).
+Victims Have Properly Petitioned for the Release of Grand Jury Materials - A
+litigant can petition for release of grand jury materials. Fed. R. Crim. P. 6(e)(3)(F). The Court
+has properly granted the victims petition for release of the materials. They have also
+concurrently-filed such a petition.
+6
+
+
+Case 9:08-CV-80736-KAM Document 225 Entered on FLSD Docket 08/16/2013 Page 8 of 10
+The CVRA Gives the Court Authority to Release Grand Jury Materials - The Court
+is obligated to enforce crime victims' rights. 18 U.S.C. § 3771(b)(I) (the court "shall ensure"
+that crime victims receive their rights). This obligation carries with it authority to release
+necessary materials to protect victims' rights, including grand jury materials.
+Grand Jury Materials Can Be Severed from Other Materials - The Government can
+redact grand jury information from the requested materials, and produce the remaining materials.
+See, e.g., In re Grand Jury Investigation, 445 F.3d 266, 280 (3rd Cir. 2006).
+E. The Privacy Rights of Other Victims
+Government Redaction Can Resolve Privacy Concerns. The Government cannot
+withhold materials in this case because of the privacy rights of other victims when it has the
+simple option of simply redacting the names and identifying information of these other victims
+before producing the materials. The Government has already followed this procedure elsewhere
+and should do so here. See, e.g., Bates 000966-67 (materials about victim "B.B.").
+No Assertion of Privacy Rights by Other Victims. Several of the victims cited by the
+Government are represented by undersigned counsel and do not wish to interpose privacy rights
+here. Nor has the Government established that they can assert the privacy rights of other victims.
+G. The Privacy Act
+The Privacy Act Does Not Apply in the Context of Court-Compelled Disclosures for
+Discovery. See 5 U.S.C. § 552a(b)(11).
+CONCLUSION
+Because the Government's assertions of privilege are not well-founded, the Court should
+provide all of the documents the Government submitted for in camera inspection to the victims.
+7
+
+
+Case 9:08-CV-80736-KAM Document 225 Entered on FLSD Docket 08/16/2013 Page 9 of 10
+DATED: August 16, 2013
+Respectfully Submitted,
+Is/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+and
+Paul G. Cassell
+S.J. Quinney College of Law at the
+University of Utah
+Salt Lake City. UT 8411
+E-Mail:|
+8
+
+
+Case 9:08-CV-80736-KAM Document 225 Entered on FLSD Docket 08/16/2013 Page 10 of 10
+I certify that the foregoing document was served on August 16, 2013, on the following
+using the Court's CM/ECF system:
+Assistant U.S. Attorneys
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Attorneys for the Government
+Jackie Perczek, Esq.
+Black, Srebnick, Kornspan & Stumpf, P.A.
+201 South Biscayne Boulevard
+Miami, EL 33131
+(305) 358-2006
+Jay P. Lefkowitz
+Kirkland & Ellis, LLP
+Martin G. Weinberg, P.C.
+20 Park Plaza
+Suite 1000
+Boston, MA 02116
+Email: owlmgw@att.net
+(617) 227-3700
+/s/ Bradley J. Edwards
+9
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 1 of 64
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOE No. 1 and JANE DOE No. 2
+V.
+UNITED STATES
+AFFIDAVIT OF BRADLEY J. EDWARDS, ESQ. REGARDING NEED FOR
+PRODUCTION OF DOCUMENTS
+1. I, Bradley J. Edwards, Esq., do hereby declare that I am a member in good standing of the Bar
+of the State of Florida. Along with co-counsel, I represent Jane Doe No. 1 and Jane Doe No. 2
+(as referred to as "the victims") in the above-listed action to enforce their rights under the Crime
+Victims Rights Act (CVRA). I also represented them (and several other victims) in civil suits
+against Jeffrey Epstein for sexually abusing them. I am also familiar with the criminal justice
+system, having served as state prosecutor in the Broward County State Attorney's Office.
+2. This affidavit covers factual issues regarding the Government's assertions of privilege to
+more than 13,000 pages of documents it has produced for in camera inspection in this case. This
+affidavit provides factual information demonstrating that the Government's assertions of
+privilege are not well founded. It further demonstrates that the victims have a compelling and
+substantial need for the information requested and have no other way of obtaining the
+information.
+Background Regarding Unsuccessful Efforts to Reach Stipulated Facts with the
+Government
+3. On July 7, 2008, I filed a petition to enforce the CVRA rights of Jane Doe No. 1 and Jane Doe
+No. 2 with regard to sex offenses committed against them by Jeffrey Epstein while they were
+minors. The course of the proceedings since then is well-known to the Court. For purposes of
+this affidavit regarding privileges, it is enough to briefly recount the efforts of the victims to
+reach a stipulated set of facts with the Government - efforts that the Government has blocked.
+4. The Court first held a hearing on victims' petition on July 11, 2008. The Court discussed a
+need to "hav[e] a complete record, and this is going to be an issue that's ... going to go to the
+Eleventh Circuit, [so it] may be better to have a complete record as to what your position is and
+the government's is as to what actions were taken." Tr. at 25-26. The Court concluded the
+hearing with the following instructions: "So I'll let both of you confer about whether there is a
+need for any additional evidence to be presented." Tr. at 32.
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 2 of 64
+5. The victims and the U.S. Attorney's Office then attempted to reach a stipulated set of facts
+underlying the case. The U.S. Attorney's Office offered a very abbreviated set of proposed facts,
+and the victims responded with a detailed set of proposed facts. Rather than respond to the
+victims' specific facts, however, the U.S. Attorney's Office suddenly reversed course. On July
+29, 2008, it filed a Notice to Court Regarding Absence of Need for Evidentiary Hearing (DE 17).
+The U.S. Attorney's Office took the following position: "After consideration, the Government
+believes that an evidentiary hearing is not necessary" (DE 17 at 1). The Office asserted that the
+Court need only take judicial notice of the fact that no indictment had been filed against Epstein
+to resolve the case.
+6. On August 1, 2008, the victims filed a response to the Government's "Notice," giving a
+proposed statement of facts surrounding the case. DE 19 at 5. The victims' response also
+requested that the Court direct the Government to confer with the victims regarding the
+undisputed facts of the case, and produce the non-prosecution agreement and other information
+about the case. Id. at 14. On August 14, 2008, the Court held a hearing on the case regarding
+the confidentiality of the non-prosecution agreement. The Court ultimately ordered production
+of the agreement to the victims.
+7. After the U.S. Attorney's Office made the non-prosecution agreement available to the
+victims, the victims reviewed it and pursued further discussions with the U.S. Attorney's Office.
+Ultimately, however, the U.S. Attorney's Office declined to reach a stipulated set of facts with
+the victims and declined to provide further information about the case.
+8. With negotiations at an impasse, the victims attempted to learn the facts of the case in other
+ways. In approximately May 2009, counsel for the victims propounded discovery requests in
+both state and federal civil cases against Epstein, seeking to obtain correspondence between
+Epstein and prosecutors regarding his plea agreement - information that the U.S. Attorney's
+Office was unwilling to provide to the victims and information that was highly relevant both to
+the victims' civil suit and their CVRA enforcement action. Epstein refused to produce that
+information, and (as the Court is aware) extended litigation to obtain the materials followed. The
+Court rejected all of Epstein's objections to producing the materials.
+9. On June 30, 2010, counsel for Epstein sent to counsel for the victims approximately 358
+pages of e-mail correspondence between criminal defense counsel and the U.S. Attorney's Office
+regarding the plea agreement that had been negotiated between them. See DE48-Attachment
+1/Exhibit A. These e-mails began to disclose for the first time the extreme steps that had been
+taken by the U.S. Attorney's Office to avoid prosecuting Epstein and to avoid having the victims
+in the case learn about the non-prosecution agreement that had been reached between Epstein
+nd the Government. While the Court ordered that all of the correspondence be turned over t
+ne victims, Epstein chose to disobey that order and instead only produced the correspondenc
+authored by the Government and redacted all correspondence authored by him or his attorneys.
+10. In mid-July 2010, Jane Doe No. 1 and Jane Doe No. 2 settled their civil lawsuits against
+Epstein. Then, armed with the new information, they turned to moving forward in the CVRA
+case. On September 13, 2010, the victims informed the Court that they were preparing new
+filings in the case.
+11. On October 12, 2010, the Court entered an order directing the victims to provide a status
+report on the case by October 27, 2010. That same day, counsel for the victims again contacted
+2
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 3 of 64
+the U.S. Attorney's Office about the possibility of reaching a stipulated set of facts in the case.
+That same day, the U.S. Attorney's Office responded: "We don't have any problem with
+agreeing that a factual assertion is correct if we agree that is what occurred" (DE 41 at 2).
+12. On October 23, 2010, the victims e-mailed to the U.S. Attorney's Office a detailed proposed
+statement of facts, with many of the facts now documented by the correspondence between the
+U.S. Attorney's Office and Epstein's counsel. The victims requested that the U.S. Attorney's
+Office identify which facts it would agree to. In a letter to the U.S. Attorney's Office, the victims
+stated:
+If you believe that any of the facts they propose are incorrect, Jane Doe No. 1 and
+Jane Doe No. 2 would reiterate their long-standing request that you work with us
+to arrive at a mutually-agreed statement of facts. As you know, in the summer of
+2008 Jane Doe No. 1 and Jane Doe No. 2 were working with you on a stipulation
+of facts when you reversed course and took that position that no recitation of the
+facts was necessary (see doc. No. 19 at 2).... I hope that your e-mail means that
+you will at least look at our facts and propose any modifications that you deem
+appropriate. Having that evidence quickly available to the Court could well help
+move this case to a conclusion.
+That same day, the U.S. Attorney's Office agreed to forward the proposed statement of facts to
+the appropriate Assistant U.S. Attorney for review (DE 41 at 2-3).
+13.
+On October 26, 2010, rather than stipulate to undisputed facts, the U.S. Attorney's Office
+contacted the victims' attorneys and asked them to delay the filing of their motion for a twoweek period of time so that negotiations could be held between the Office and the victims in an
+attempt to narrow the range of disputes in the case and to hopefully reach a settlement resolution
+without the need for further litigation. Negotiations between the victims and the U.S. Attorney's
+Office then followed over the next two days. However, at 6:11 p.m. on October 27, 2010 - the
+date on which the victims'
+pleading was due - the U.S. Attorney's Office informed the victims
+that it did not believe that it had time to review the victims' proposed statement of facts and
+advise which were accurate and which were inaccurate. The Office further advised the victims
+that it believed that the victims did not have a right to confer with their Office under the CVRA
+in this case because in its view the case is "civil" litigation rather than "criminal" litigation (doc.
+No. 41 at 3).'
+14. As a result, purely as an accommodation to the U.S. Attorney's Office, on October 27, 2010,
+the victims filed a report with the Court in which they agreed to delay filing their motion and
+accompanying facts for up to two-weeks to see if negotiations can resolve (or narrow) the
+disputes with the U.S. Attorney's Office (DE 41 at 4). Discussions with the U.S. Attorney's
+Office dragged on, including a personal meeting between Jane Doe No. 1 and the U.S. Attorney
+in December 2010.
+' In seeming contradiction to this position, on March 17, 2011, the U.S. Attorney's Office
+informed the victims that it would not be making any initial disclosures to the victims as required
+for civil cases by Fed. R. Civ. P. 26(a)(I). The U.S. Attorney's Office did not explain why they
+believe that this rule of civil procedure is inapplicable if they think this case is properly viewed
+as a "civil" case.
+3
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 4 of 64
+15. After further discussions failed to produce any agreement or other visible progress, the
+victims informed the U.S. Attorney's Office that they would file their "summary judgment"
+motion with the Court on March 18, 2011 and requested further cooperation from the Office on
+the facts.
+16. Ultimately, after months of discussion, the U.S. Attorney's Office informed counsel for the
+victims that - contrary to promises made earlier to stipulate to undisputed facts - no such
+stipulation would be forthcoming. Instead, on March 15, 2011, the U.S. Attorney for the
+Southern District of Florida,
+1 sent a letter to the victims declining to reach any
+agreement on the facts:
+Because, as a matter of law, the CVRA is inapplicable to this matter in which no
+federal criminal charges were ever filed, your requests for the government's
+agreement on a set of proposed stipulated facts is unnecessary and premature.
+That is, because whether the rights in 18 U.S.C. § 3771(a) attach prior to the filing
+of a charge in a federal court is a matter of statutory interpretation, resolution of
+that question is not dependent upon the existence of any certain set of facts, other
+than whether a charging document was ever filed against Jeffrey Epstein in the
+United States District Court for the Southern District of Florida.
+And while this
+Office remains willing to cooperate, cooperation does not mean agreeing to facts
+that are not relevant to the resolution of the legal dispute at issue ....
+Letter from
+to Paul G. Cassell (March 15, 2011).
+17. Accordingly, unable to work with the Government to reach a resolution of the facts, on
+March 21, 2011, the victims filed a Motion for Summary Judgment, alleging 53 undisputed facts
+along with some evidentiary support for each of the facts. DE 48.
+The victims also filed a
+motion to have their facts accepted because of the Government's failure to contest their facts.
+DE 49. The victims also filed a motion to have the Court direct the Government to not withhold
+relevant evidence. DE 50.
+18. Following
+a hearing on the motions, on September 26, 2011, the Court rejected the
+Government's argument that the CVRA was inapplicable in this case because the Government
+had never filed charges against Epstein. DE 99. The Court, however, rejected the victims'
+argument that it should accept their facts because of the Government's failure to contest the
+facts. DE 99 at 11. Instead, the Court directed that discovery could proceed in the form of
+requests for admission and document production requests. Id. at 11. The Court reserved ruling
+on the victims' motion that the Government should be directed not to withhold evidence.
+19. In light of the Court's order, on October 3, 2011, the victims filed requests for production
+with the Government. The requests included 25 specific requests, each of which linked very
+directly to the facts that the victims were attempting to prove in this case.
+20. On November 7, 2011, the day when the Government's responses were due, rather than
+produce even a single page of discovery, the Government filed a motion to dismiss the victims'
+petitions. DE 119. On that same day, the Government filed a motion to stay discovery. DE 121.
+The victims filed a response, arguing that the Government's motion was a stall tactic. DE 129.
+The victims also filed a motion to compel production of all of their discovery requests. DE 130.
+The Government filed a reply, arguing that it was not stalling. Indeed, the Government told the
+Court that "the United States has agreed to provide some information to [the victims] even
+4
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 5 of 64
+during the pendency of the stay [of discovery] and is undertaking a search for that information."
+DE 140 at 4. Contrary to that representation, however, over the next seventeen months, the
+Government did not produce any information to the victims, despite the victims reminding the
+Government of that statement made to the court.
+21. Ultimately, after some additional motions and rulings, on June 19, 2013, the Court denied
+the Government's motion to dismiss and lifted any stay of discovery. DE 189. That same day,
+the Court entered an order granting the victims' motion to compel and directing the Government
+to produce (I) all correspondence between it and Epstein; (2) all communications between the
+Government and outside entities; and (3) every other document requested by the victims. DE
+190 at 2. With respect to the third item, the Court allowed the Government to assert privilege by
+producing the items in question for in camera inspection and filing a contemporaneous privilege
+log. Id. The Court required that the privilege log must "clearly identifyl] each document[] by
+author(s), addressee(s), recipients), date, and general subject matter ...." DE 190 at 2.
+22. On July 19 and July 27, 2013, the Government made its production. With regard to item (1)
+- correspondence with Epstein, the Government withheld the correspondence pending a ruling
+from the Eleventh Circuit on Epstein's motion to stay production of these materials. With regard
+to the other items, the Government produced 14,825 pages of documents to the Court for in
+camera inspection, but turned over only 1,357 pages to the victims. Thus, the Government
+asserted privilege to more than 90% of the documents in question. The documents that the
+Government produced were almost worthless to the victims, as they included such things that the
+victims' own letters to the Government (Bates 0001-04), court pleadings filed by the victims
+themselves or other victims, by Epstein, or by news media organizations (e.g., Bates 00142-88,
+00229-31, 281-311, 00668-69), public court rulings on Epstein related matters (e.g., Bates 0008-
+10, 0012-14. 0036-86, 00190-228), public newspaper articles (e.g., Bates 0011, 0030, 0032-33),
+and similar materials already available to the victims.
+pages of notices sent to the various other victims in this case - notices that were substantively
+indistinguishable from the notices the victims themselves in this case had already received.
+Almost without exception, the documents the Government produced do not go to the disputed
+issues in this case.
+23. The Government made one last production of materials in this case on August 6, 2013. This
+involved roughly 1,500 pages of documents that were largely meaningless in the context of the
+contested issues in the case. They included public documents in the case such the crime victims'
+own pleadings, see, e.g., Bates 000671-000711 (copy of the victims' redacted summary
+judgment motion). Curiously, while the Government has produced these documents that would
+likely fall into an "irrelevant" category of documents, they have simultaneously refused
+production of hundreds of other documents that are responsive to our requests on the basis of
+24. The victims have tried to obtain information on all relevant subjects through requests for
+admission. The Government, however, has refused to admit many of the victims' central
+allegations in this case. A copy of the victims' requests for admissions and the Government's
+responses is attached to this affidavit so that the Court can see that the victims have diligently
+tried to pursue this avenue for developing the facts in this case.
+5
+
+
+Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 6 of 64
+25. The victims have also tried to obtain information on subjects related to their suit by
+voluntary requests for interview with persons who are no longer employed by the Justice
+Department. For example, I have sent letters to both Bruce Reinhart and Alex Acosta, who both
+have information about the Epstein case, requesting an opportunity to discuss the case with them.
+Both of them have ignored my letters.
+The Need for the Materials Requested by the Victim
+6. The documents that the victims requested that the Government produce to them on Octobe
+3,2011, are all highly relevant to their CVRA enforcement action. We would not have requested
+them otherwise. The victims also have no other means of obtaining the requested material. This
+section of the affidavit explains why the materials are needed by the victims. For the
+convenience of the Court, the affidavit will proceed on a section-by-section basis concerning the
+need for the materials. Also for the convenience of the Court, a copy of the October 3, 2011,
+request for production is attached to this Affidavit. Also attached is the victims' supplemental
+discovery request of June 24, 2013. As the Court will note from reviewing the requests for
+production, most of the requests specifically recount the allegations that the requested documents
+would support, in an effort to eliminate any dispute from the Government that the documents
+were not relevant to the case. Many of the requests for production link directly to specific
+paragraphs in the victims' previously-filed summary judgment motion. Accordingly, the victims
+have a very specific need for these documents to support the allegations in the summary
+judgment motion found at DE 48 at 3-23.
+27. The Court has previously concluded that the victims' proof of their claims is, at this point in
+the case, inadequate. Instead, the Court has ruled: "Whether the evidentiary proofs will entitle
+[the victims] to that relief [of setting aside the non-prosecution agreement] is a question properly
+reserved for determination upon a fully developed evidentiary record." DE 189 at 11-12. The
+Court has further indicated that it will be considering an "estoppel" argument raised by the
+Government as a defense in this case. DE 189 at 12 n.6. The Court has noted that this argument
+"implicates a fact-sensitive equitable defense which must be considered in the historical factual
+context of the entire interface between Epstein, the relevant prosecutorial authorities and the
+federal offense victims - including an assessment of the allegation of a deliberate conspiracy
+between Epstein and federal prosecutors to keep the victims in the dark on the pendency of
+negotiations between Epstein and federal authorities until well after the fact and presentation of
+the non-prosecution agreement to them as a fait accompli." DE 189 at 12 n.6 (emphasis added).
+The victims have a compelling need for information about the Government's actions to show
+Request for Production ("RFP") No. I requests information regarding the Epsteit
+investigation. These documents are needed to support the victims' allegations that the
+Government had a viable criminal case for many federal sex offenses that it could have pursued
+against Epstein. See, e.g., DE. 48 at 3-7.
+29. RFP No. 2 requests information regarding crime victim notifications in this case. Theso
+documents are needed to support the victims' allegations that their rights under the CVRA, their
+6
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 7 of 64
+right to notice and to confer with the Government, were violated in this case. In particular, these
+documents are needed to demonstrate that the victims were not properly notified about the nonprosecution agreement (NPA) entered into by the Government and Jeffrey Epstein and that the
+Government did not confer with the victims about the agreement. See, e.g., DE 48 at 11-17.
+30. RFP No. 3 requests information about the NPA, including in particular its confidentiality
+provision.
+These documents are needed to demonstrate that the confidentiality provision
+precluded disclosing the agreement to Jane Doe No. 1 and Jane Doe No. 2, as well as to other
+victims. See, e.g., DE 48 at 10-17. These documents are further needed to demonstrate that
+Jeffrey Epstein specifically orchestrated the secrecy of the agreement, thereby deliberately
+causing the Government's CVRA violation in this case. See, e.g., DE 48 at 13.
+31. RFP No. 4 requests documents relating to negotiations between the Government and Jeffrey
+Epstein concerning the court and/or location in which Jeffrey Epstein would enter any guilty plea
+(including in particular any negotiations concerning concluding the plea in Miami or another
+location outside of West Palm Beach). These documents are relevant to the victims allegations
+that the Government was interested in finding a place to conclude any plea agreement that would
+effectively keep Epstein's victims (most of whom resided in or about West Palm Beach) from
+learning what was happening through the press. See, e.g., DE 48 at 7-8.
+32. RFP No. 5 requests documents pertaining to negotiations between the Government and
+Jeffrey Epstein regarding any legal representation of the victims in civil cases against Epstein.
+These documents are needed to prove the victims'
+allegation that part of the plea negotiations
+with Epstein involved Epstein's efforts to make sure that the victims would be represented in
+civil cases against Epstein by someone who was not an experienced personal injury lawyer or by
+someone familiar to Epstein or his legal team. See, e.g., DE 48 at 9.
+33. RFP No. 6 requests documents concerning the Government's and/or Epstein awareness or
+discussion of possible public criticism and/or victim objections to the non-prosecution agreement
+that they negotiated.
+The documents are needed to prove the victims' allegations that the
+Government wanted the non-prosecution agreement with Epstein concealed from public view
+because of the intense public criticism that would have resulted had the agreement been
+disclosed and/or the possibility that victims would have objected in court and convinced the
+judge not to accept the agreement. See, e.g., DE 48 at 7-8, 11. They are also relevant to bias and
+motive by the authors or subjects of other documents in this case.
+34. RFP No. 7 requests documents regarding the Government's awareness of its potential
+CVRA obligations in this case and regarding any discussions between the Government and
+Epstein concerning these CVRA obligations in this case. These documents are needed to prove
+the victims' allegations that the Government was aware that it potentially had obligations under
+the CVRA to notify the victims about the non-prosecution agreement and any related state court
+plea agreement. See, e.g., DE 48 at 12-13.
+35. RFP No. 8 requests documents regarding Epstein's lobbying efforts to persuade the
+Government to give him a more favorable plea arrangement and/or non-prosecution agreement,
+including efforts on his behalf by former President Bill Clinton, Prince Andrew, and Harvard
+Law Professor Alan Dershowitz. These materials are needed to prove the victims allegation
+that, after Epstein signed the non-prosecution agreement, his performance was delayed while he
+used his significant social and political connections to lobby the Justice Department to obtain a
+7
+
+
+Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 8 of 64
+more favorable plea deal. See, e.g., DE 48 at 16-18. These materials also are needed to establish
+the course of the proceedings in this case, which is necessary in light of the Government's letters
+to the victims (discussed in the next paragraph) concerning the status of the case.
+36. RFP No. 9 requests documents regarding the letters sent to the victims by the FBI on
+January 10, 2008, Jane Doe No. 1 and Jane Doe No. 2 advising them that "this case is currently
+under investigation." These documents are needed to show that these letters were inaccurate or,
+at the very least, highly misleading, because they conveyed the impression that no plea
+arrangement (for example, a non-prosecution agreement) had been negotiated between Epstein
+and the Government. See, e.g., DE 48 at 16. These documents are also needed to respond to the
+Government's "estoppel" defense, as noted in the Court's order DE 189 at 12 n.6.
+37. RFP No. 10 requests documents regarding the victims' allegations that the FBI was led to
+believe that their investigation of Epstein was going to produce a federal criminal prosecution
+and that the FBI was also misled by the U.S. Attorney's office about the status of the case. The
+Government has argued that these documents are not relevant to the case, because the only issue
+is whether the Government misled the victims. But the Government fails to recognize that the
+victims received information about the case through the FBI. These documents are therefore
+needed to demonstrate that the victims received inaccurate information about the status of the
+case - inaccurate information caused by the U.S. Attorney's Office's negotiations with Epstein.
+If the FBI agents were not accurately informed about the progress of the cases, then they could
+not have accurately informed the victims about the progress of the case - a central point in the
+victims' argument.
+Moreover, these documents would show a common scheme or plan -
+something made admissible in a trial by operation of Fed. R. Evid. 404(b). Of course, if the U.S.
+Attorney's Office was misleading the FBI about the NPA, it would have been part of the same
+scheme or plan to mislead the victims as well. The documents are also needed to support specific
+allegations in the victims' summary judgment motion. See, e.g., DE 48 at 16-17.
+38. RFP No. 11 requests documents regarding various meetings that the Government (including
+FBI agents) had with the victims. These documents are needed to prove that during those
+meetings the Government did not disclose to the victims (or to their attorneys) that a nonprosecution agreement had been negotiated with Epstein, and even signed with Epstein, that
+related to their cases, allegations that the victims have advanced in their summary judgment
+motion. See, e.g., DE 48 at 16-18.
+39. RFP No. 12 requests all documents connected with a request from the U.S. Attorney's
+Office to me (Bradley J. Edwards) to write a letter concerning the need for filing federal charges
+against Epstein and follow-up to that letter. These documents are needed to show that this
+request was made to me without disclosing the existence of the non-prosecution agreement.
+Thus, just as Jane Doe No. 1 and Jane Doe No. 2 were deceived about the NPA, I was deceived
+as well. See, e.g., DE 48 at 18-19. It is also needed to contradict the Government's apparent
+position that it disclosed the "existence' of the NPA to me and to the victims. See, e. g., Gov't
+Answers to RFA 1 13(d) ("The government admits that, when Epstein was pleading guilty to the
+state charges discussed in the non-prosecution agreement, the USAO and Epstein's defense
+attorneys sought to keep the document memorializing the non-prosecution agreement
+confidential, but denies that they sought at that time to keep the existence of the non-prosecution
+agreement confidential.").
+8
+
+
+Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 9 of 64
+40. RFP No. 13 requests documents regarding how, on or about June 27, 2008, the Government
+learned that Epstein would be entering his plea to state charges on or about June 30, 2008. The
+documents are needed to describe the course of proceedings in this case and to prove both the
+Government's and Epstein's awareness that he would be entering a guilty plea (and thus
+blocking prosecution of other crimes) without the victims' full knowledge of what was
+happening. See, e.g., DE 48 at 19-20.
+RFP No. 14 requests documents relating to the Government and Epstein working together
+to keep the existence of the non-prosecution agreement secret, including declining comment
+about the existence of such an agreement when asked about it when his guilty plea in state court
+became public knowledge. These documents are needed to prove the victims" allegations that
+the Government concealed the NPA from them, see, e.g., DE 48 at 14-18,and to contradict what
+appears to be the Government's position, namely that the victims were aware of the NPA shortly
+after it was negotiated, see, e.g., Gov't Answers to RFA 1 13(b) (claiming that "the USAO had
+communicated with Jane Doe #1 about the non-prosecution agreement prior to Epstein's June 30,
+2008 guilty plea.").
+These documents are also necessary to contradict the Government's
+apparent claim that the NPA did not bar discussions with crime victims.
+See, e.g., Gov't
+Answers to RFA 9| 13(d) (Government denying request that it admit that "Epstein's defense
+attorneys had negotiated for a confidentiality provision in the non-prosecution agreement that
+barred conferring with victims about the agreement").
+42. RFP No. 15 requests documents pertaining to the feasibility of notifying the victims about
+the NPA, along with information concerning how the victims came to receive a "corrected"
+notification letter on about September 3, 2008 - months after Epstein had pled guilty. These
+documents are needed to demonstrate that the Government had no valid reason for failing to
+provide notice to the victims.
+It is also needed to demonstrate why the victims at first received
+inaccurate information about the NPA, as well as Jeffrey Epstein's involvement in that
+inaccurate notice.
+See, e.g., DE 48 at 15-16.
+43. RFP No. 16 requests documents regarding Bruce Reinhart, a senior prosecutor who was
+present in the U.S. Attorney's Office during the time that the Office negotiated the NPA with
+Epstein, blocking his prosecution for federal crimes in the Southern District of Florida. In RFP
+No. 16, the victims have sought documents showing that Reinhart learned confidential, nonpublic information about Epstein matter.
+The Court will recall that Reinhart has filed a sworn
+affidavit with this Court, in which he flatly declared that while he was a prosecutor in the Office:
+"I never learned any confidential, non-public information about the Epstein matter." DE 79-1 at
+3 (9| 12). When Reinhart made that statement, it seemed improbable to me, because Reinhart was
+in close contact with other prosecutors in the Office and would seem likely that he would have
+discussed the high-profile Epstein case with them. Additionally, I learned through public record
+that while still a prosecutor at the Office Mr. Reinhart established his criminal defense office at
+the exact address (and exact Suite number) as Jeffrey Epstein's personal business address.
+However, I did not have any direct way of contradicting Reinhart's sworn statement. Since then,
+however, in answering the victims' Requests for Admissions, the Government has admitted that
+it possesses information that Reinhart learned confidential, non-public information about the
+Epstein case and that he discussed the Epstein case with other prosecutors. Gov't Answers to
+RFA's 1 15(a) & (b). Of course, this means that the Government has documents that Reinhart
+9
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 10 of
+filed a false affidavit with this Court. This gives rise to the reasonable inference that, if Reinhart
+was willing to provide false information about this subject, he may have additional information
+about the case that is being concealed as well.
+44. Materials about Reinhart are also needed to support the victims' summary judgment motion.
+See, e.g., DE 48 at 22-23 (raising allegations about Reinhart).
+45. Reinhart's affidavit with the Court also states: "Because I did not have any, I did not share
+non-public confidential information about the Epstein investigation with any of Epstein's
+attorneys." DE 79-1 at 4 (f 17). Because the Government has information demonstrating that
+the first part of this statement is false, it may well be that the second part of the statement is false
+as well. Given that Mr. Reinhart established a business address identical to Epstein's business
+address, at a time while he was still working at the US Attorney's Office, and that Mr. Reinhart
+ultimately represented several of Epstein's co-conspirators, jet pilots, and staff, during the civil
+litigation, any involvement Mr. Reinhart had with the Epstein case while working at the Office is
+highly relevant.
+46. The Government has further admitted that it possesses documents reflecting contacts
+between Bruce Reinhart and persons/entities affiliated with Jeffrey Epstein before Reinhart left
+his job at the U.S. Attorney's Office. Gov't Answers to RFA's 9| 16. As stated above, Reinhart
+left the U.S. Attorney's Office to start a private firm that was located in the same address as
+Epstein's personal business where he was daily. This would appear to be a violation of the
+Florida rules of ethics for attorneys.
+47. Information about Reinhart's connections to Epstein is critical to the victims' allegations in
+this case. If Reinhart was helping Epstein gain insight into the prosecutions efforts, that would
+provide a motive for Reinhart (and other prosecutors) not to properly notify the victims and not
+to confer with them.
+Also, if Epstein was improperly receiving information about the
+prosecution efforts against him (or lack thereof), that could be highly relevant to the remedies
+stage of this case, in which the victims will ask (among other things) to have the NPA agreement
+invalidated. Epstein has already indicated that he will raise a double jeopardy argument against
+that effort. However, double jeopardy considerations do not apply in situations where the
+defendant was not truly in jeopardy of prosecution. In addition, the Court may wish to consider,
+in crafting a remedy, Epstein's culpability for the violations of the NPA. Evidence that Epstein
+was improperly obtaining information about the prosecution efforts against him would be highly
+relevant to that culpability assessment. It is also relevant to the estoppel defense that the
+Government (and perhaps Epstein as well) intend to raise.
+48. Evidence concerning Reinhart's connections, including improper connections, to Epstein is
+also relevant to bias and motive in this case. It would show, for example, the Reinhart had a
+reason to encourage others in the U.S. Attorney's Office to give Epstein a more lenient deal than
+the one he was entitled to.
+49. RFP No. 16 requested information not only about improper connections between Epstein
+and Reinhart, but more broadly about such connections with any other prosecutors. Of course, if
+the Government possesses such information, it would be highly relevant to the victims'
+allegations for the reasons just discussed. In its answers to the victims' Requests for Admission,
+he Government admits that it has information about a personal or business relationship betwee
+effrev Epstein and another prosecutor involved in the Epstein cast
+10
+
+
+Case 9:08-cV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 11 of
+to Requests for Admission at 1 20. The Government should be required to disclose all of those
+documents so that the victims can determine whether there was anything improper about those
+relationships. In my experience, it is highly unusual for federal prosecutors to work on a case
+prosecuting someone (such as Jeffrey Epstein) and then, shortly thereafter, leave the employment
+of the federal government and enter into a business relationship with the person who was being
+prosecuted.
+50. RFP No. 17 asks for documents concerning an investigation into the Epstein prosecution
+undertaken by the Justice Department's Office of Professional Responsibility (OPR) in
+Washington, D.C. The investigation was undertaken at the request of the victims, who asked the
+Justice Department to determine whether "improper influences" were brought to bear during the
+negotiations involving the possible prosecution (and ultimately the non-prosecution) of Jeffrey
+Epstein. It is apparent from the privilege logs that the Government has produced that OPR
+generated a great deal of correspondence (at least 46 pages) regarding this request. See Bates P-
+013909 to P-013955. Of course, improper influences being brought to bear on the Epstein
+prosecution would support the victims'
+allegations that they were not being properly notified.
+Moreover, OPR may well have investigated the specific allegations that are at issue in this case -
+or directed others to undertake such an investigation. Here again, this information would be
+critical to supporting the victims' case.
+In fact, because OPR has presumably investigated many
+of the precise actions and actors, about which the victims complain in this litigation, and have
+already gathered many of the documents needed, the production of the OPR case file could
+probably short-cut this litigation and discovery process.
+51. There is no other way to obtain this information from OPR. On May 6, 2011, nearly half a
+year after the victims' request of December 10, 2010, for an investigation, OPR sent a letter to
+my co-counsel, Professor Paul Cassell, in which it stated that it "regret[ted] it could not be of
+assistance" in providing information about the allegations.
+52. RFP No. 18 asks for information about why the U.S. Attorney's Office for the Southern
+District of Florida was "conflicted out" of handling various issues related to the Epstein case.
+This information is needed to show why the victims did not receive proper notifications about
+the NPA that the Office negotiated with Epstein. It appears that the conflict of interest that has
+been recognized may have to do with the Office's treatment of the victims. Moreover, in its
+production of documents, and in follow-up correspondence, the U.S. Attorney's Office for the
+Southern District of Florida has indicated that there are no responsive documents being held by
+the U.S. Attorney's Office in the other district that is handling conflict matters. (It appears that
+this other office is the Middle District of Florida.) This appears to be improbable, because the
+conflict matters would presumably generate many documents covered by the victims' discovery
+requests, including the OPR investigative file. Accordingly, the conflict matter is highly relevant
+to determining whether the U.S. Attorney's Office has provided complete production to the
+victims. A conflict of interest would also be highly relevant to the motivations of the
+Government attorneys throughout the handling of the Epstein case.
+53. RFP No. 19 asks for information supporting allegations made in March 2011, by former
+U.S. Attorney Alexander Acosta. He sent a three-page letter to the news media in which he
+claimed that when Government attorneys began investigating Epstein, Epstein launched "a
+yearlong assault on the prosecution and the prosecutors." This information is needed to explain
+11
+
+
+Case 9:08-cV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 12 of
+why the U.S. Attorney's Office would have withheld notifications from the victims about the
+NPA. If the prosecutors were being assaulted, as Acosta has said they were, then they would
+have reason to disregard their obligations to crime victims. In addition, this would show
+improper behavior by Epstein, which would be relevant at the remedies stage of this case in
+determining the scope of any remedy. These allegations would also bear strongly on motive and
+bias.
+54. RFP No. 20 requests documents between the Government and state and local prosecutors
+and police agencies (including The Palm Beach Police Department) regarding the nonprosecution agreement. Because this involves information outside of the Department, it is the
+victims understanding that the Government has already turned over all of this information to
+them, as the Court has directed. See DE 190 at 2 (requiring production of information with
+persons or entities outside the federal government). For the sake of completeness, however, it is
+worth noting that this information is needed to demonstrate that the victims were not properly
+informed that Epstein's plea to state charges would trigger the NPA and preclude prosecution for
+crimes committed against them.
+Government was concealing the existence of the NPA from them and that this was done at
+Epstein's behest. The Court has specifically noted that the victims have a need for information
+that will allow them to argue to the Court in support of their "allegation of a deliberate
+conspiracy between Epstein and federal prosecutors to keep the victims in the dark on the
+pendency of negotiations between Epstein and federal authorities until well after the fact and
+presentation of the non-prosecution agreement to them as a fait accompli." DE 189 at 12 n.6.
+56. RFP No. 22 requests information about any considerations that Epstein provided, or offered
+to provide, to any individual within the Government. Here again, the victims understand that this
+information is being provided to them. It is again worth noting, however, that this information is
+highly relevant to explaining why the U.S. Attorney's Office would not have properly notified
+the victims about what was happening in their case, an allegation that is at the center of the
+victims' summary judgment motion.
+See, e.g., DE 48 at 11 (noting allegation that Epstein
+pushed the U.S. Attorney's Office to keep the NPA secret from public view to avoid public
+57. RFP No. 23 asks for documents that will assist Jane Doe No. 1 and Jane Doe No. 2 in
+protecting their rights under the CVRA. This request links to the Government's obligations
+under the CVRA to use its "best efforts" to protect victims' rights. 18 U.S.C. § 3771(c)(1).
+The direct connection between this request and the victims' case is self-explanatory.
+58. RFP No. 24 request correspondence related to the Epstein prosecution that the Government
+had with entities outside the federal government. Here again, it is my understanding that these
+materials have already been ordered produced. See DE 190 at 2 (requiring production of
+information with persons or entities outside the federal government). For the sake of
+completeness, this information is again relevant to showing the course of the Epstein
+12
+
+
+Case 9:08-cV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 13 of
+investigation and why the victims were not properly notified about event during that
+investigation.
+59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil
+Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules
+apply, they then receive all materials to which they are entitled.
+60. In June 2013, the victims sent a supplemental request for production, asking the Government
+to provide any information concerning any investigation that the Department undertook
+concerning the treatment of the victims during the investigation in this case, including any FBI,
+grand jury, OPR or other investigation in the Southern District of Florida, Middle District of
+Florida, or elsewhere. Here again, this information is critically needed, as it would go directly to
+proving the victims' allegations that their rights were violated during the investigation of
+Epstein. This information would also go directly to defeating the Government's "estoppel"
+argument. This information would also show motive and bias.
+Inadequate Privilege Log
+61. The Government has produced a privilege log that violates the Court's order in this case. I
+have been greatly hampered in responding to the Government's assertions of privilege because
+of that inadequate log.
+Indeed, in many cases, it is impossible to determine whether the
+Government's assertions of privilege are even plausible because of the inadequacy of the log.
+62. The Court has directed the Government to produce a privilege log that "clearly identiffies]
+each document[] [as to which privilege is asserted] by author(s), addressee(s), recipients), date,
+and general subject matter....
+" DE 190 at 2. Many of the entries in the privilege log fail to
+meet this requirement.
+63. A good illustration of the inadequacies of the privilege log comes from the very first entry in
+the log, covering Box No. 1 (P-000001 through P-000039), some 39 pages of documents. DE
+212-1. Yet the only description of these 39 pages is: "File folder entitled 'CORR RE GJ
+SUBPOENAS' containing correspondence related to various grand jury subpoenas and attorney
+) handwritten notes."
+64. Another good illustration of the inadequacies of the privilege log is provided on page 20 of
+the first privilege log, with regard to Box No. 3 (P-012362 through P-012451). The Government
+asserts privilege here regarding 90 pages of documents. Yet the only description of these 90
+pages is: "File folder entitled 'Key Documents' containing correspondence between AUSA and
+case agent regarding indictment prep questions, victim identification information, corrections to
+draft indictment, indictment preparation timeline, key grand jury materials."
+65. There are many other illustrations of the inadequacies of the privilege log which the Court
+will see when it examines it.
+I have also filed contemporaneously a response to the
+government's privilege log, which identifies many situations of an inadequate privilege log, as
+well as other responses that are needed to respond to the Government's privilege log.
+66. The Government has never contacted me or co-counsel about any burdens associated with
+producing a privilege log that complied with the Court's directives. At all times relevant to this
+case, I would have been willing to work with Government counsel to minimize any excessive
+burden from producing an adequate privilege log. The requests for production that I sent to the
+Government specifically invited discussion to avoid any excessive burden.
+Failure to Prove Factual Underpinnings of Privilege Claim
+13
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 14 of
+67. Many of the Government's privilege assertions require factual premises - such as the
+existence of an attorney-client relationship and the rendition of legal services within that
+relationship. Yet the Government has not provided the factual underpinnings for any of its
+privilege assertions.
+68. An illustration of this problem is found on page 1 of the supplemental privilege log (DE
+216il) beth read to plemental ox No 2 01328) The entre perposed responso
+1. and FBI re proposed response to
+Goldberger's letter re victim notification." The log then indicates that the Government is
+asserting attorney-client privilege, work product privilege, and deliberative process privilege.
+The Government, however, does not provide any document for any of the factual underpinnings
+of any of these claims. For example, with regard to the attorney-client claim, the Government
+does not explain who the attorney is and who the client is. With regard to the work product
+claim, the Government does not explain what litigation this document contemplated. And with
+regard to deliberative process, the Government does not explain what deliberative process was
+involved.
+69. There are many other illustrations of the Government's failure to prove the factual
+underpinnings of privilege assertions, which the Court will see when it examines the privilege
+log and the victims responsive log.
+Waiver of Confidentiality
+70. Some of the privileges that the Government has asserted have been waived. Of course, a
+requirement of a privilege is that confidentiality be maintained. Some of the materials have been
+circulated outside of any confidential circle, thereby waiving privilege.
+71. An illustration of waiver found on page 1 of the supplemental privilege log (DE 216-1), with
+regard to supplemental box No. 3 (P-013282 to 83).
+he entry here reads: *7/08/08 email from
+to A. Acosta,
+, and FBI re proposed response to
+Goldberger's letter re victim notification." The log then indicates that the Government is
+asserting attorney-client privilege regarding these emails. But the emails were not internal to the
+U.S. Attorney's Office, but were also sent to the "FBI." (This is another illustration of the
+inadequacies of the privilege log, because who in the FBI the materials were sent to is not
+disclosed.) But the FBI is a law enforcement investigative agency, not an agency that provides
+legal advice. Accordingly, any attorney-client privilege would be waived by dissemination of
+this e-mail outside the U.S. Attorney's Office.
+72. Another illustration of waiver is found on page 3 of the supplemental privilege log (DE 216-
+1), with regard to supplemental box No. 3 (P-013504 to P-013507). The entry here reads: "File
+folder labeled 'Mtg w/ Ken Starr, RAA, JS, Drew' containing handwritten notes by
+" Kenn Starr, of course, is a defense attorney who represented defendant Epstein.
+Recording information provided by a defense attorney is not part of any governmental attorneyclient privilege.
+73. Another illustration of waiver is found on page 7 of the supplemental privilege log (DE
+216-1), with regard to supplemental box No. 3 (P-013644 through P-013653). The entry ho
+"File folder entitled "Notes Re Plea Negotiations" containing 9/17/07 c-mail from L
+re status update; undated and typed handwritten
+re items to be completed on case, strength of case, victim interviews,
+14
+
+
+Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 15 of
+summary of evidence, guidelines calculations." The Government is asserting attorney-client
+privilege regarding this e-mail. I understand the reference to
+to be
+references to FBI agents - not attorneys in the U.S. Attorney's Office. Accordingly, the
+attorney-client privilege would not extend to this e-mail.
+The Government's Fiduciary Duty to Crime Vietims Bars Any Privilege
+74. I am familiar with the caselaw recited in our pleadings regarding a "fiduciary exception"
+(also known as the "Garner exception" in some settings) to privileges. In this case, the
+Government had a fiduciary obligation to protect the CVRA rights of Jane Doe No. 1 and Jane
+Doe No. 2.
+Specifically, because they were recognized "victims" under the CVRA, the
+Government had obligations to provide them rights under the CVRA, including the right to
+confer, the right to notice, and the right to be treated with fairness. Because of this fiduciary
+duty, an exception applies to many of the Government privilege claims regarding interactions
+with the victims.
+75. The fiduciary duty of the Government to the victims in this case is clear. In 2007, the FBI
+determined that both Jane Doe No. 1 and Jane Doe No. 2 were victims of sexual assaults by
+Epstein while they were minors beginning when they were approximately fourteen years of age
+and approximately thirteen years of age respectively. These sexual assaults involved
+means of interstate commerce (i.e., a telephone) and travel in interstate commerce. Both Jane
+Does were initially identified through the Palm Beach Police Department's investigation of
+Epstein.
+76. Confirming the fact that the Government had identified Jane Doe No. 1 as a victim in this
+case, on about June 7, 2007, FBI agents hand-delivered to Jane Doe No. 1 a standard CVRA
+victim notification letter. The notification promises that the Justice Department would make its
+"best efforts" to protect Jane Doe No. I's rights, including "[t]he reasonable right to confer with
+the attorney for the United States in the case" and "to be reasonably heard at any public
+proceeding in the district court involving .. plea ...." The notification further explained that
+"[at this time, your case is under investigation."
+77. Similarly, on about August 11, 2007, FBI agents hand-delivered to Jane Doe No. 2 a standard
+CVRA victim notification letter. The notification promises that the Justice Department would
+make its "best efforts" to protect Jane Doe No. I's rights, including "It]he reasonable right to
+confer with the attorney for the United States in the case" and "to be reasonably heard at any
+public proceeding in the district court involving ... plea ...." The notification further explained
+that "[alt this time, your case is under investigation."
+78. Early in the investigation, the FBI agents and the Assistant U.S. Attorney had several
+meetings with Jane Doe No. 1. Jane Doe No. 2 was represented by counsel that was paid for by
+Epstein and, accordingly, all contact was made through that attorney. These meetings occurred
+because the FBI had obligations to protect the victims' rights under the CVRA.
+79. In October 2007, shortly after the initial non-prosecution agreement was signed between
+Epstein and the U.S. Attorney's Office for the Southern District of Florida, Jane Doe No. 1 was
+contacted to he advised regarding the investigation. On October 26, 2007, Special Agents
+met in person with Jane Doe No. I because she was
+recognized as a "victim' of Epstein's crime.
+15
+
+
+Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 16 of
+80. In all of these dealings between the Government and the victims, as well as other dealings of
+a similar nature, the Government had a fiduciary obligation to protect the interests of the victims
+under the Crime Victims Rights Act. Accordingly, the Government is precluded from raising
+any privilege claim to which a fiduciary exception applies or, at the very least, any privilege
+assertion would be outweighed by the victims' compelling need for the material.
+81. An illustration of a situation where the fiduciary duty exception applies is found on page 1 of
+the supplemental privilege log (DE 216-1), with regard to supplemental box No. 3 (P-013282 to
+83). The entry here reads: "7/08/08 email from
+a to A. Acosta,
+1, and FBI re proposed response to Goldberger's letter re victim notification.
+responding to defense attorney Goldberger's letter about victim notification, the U.S. Attorney's
+Office had a statutory duty under the CVRA to protect the victims' interests. Accordingly, the
+Office cannot assert privilege when questions about whether it fulfilled its obligations to the
+victims have arisen in this case or, at the very least, any privilege assertion would be outweighed
+by the victims' compelling need for the materials.
+82. Another illustration of a situation where the fiduciary duty exception applies is found on
+page 16 of the first privilege log (DE 212-1), with regard to Box #2 P-010526 to P-010641. The
+entry reads: "File folder entitled 'Rsrch re Crime Victims Rights' containing attorney research,
+handwritten notes, draft victim notification letter, and draft correspondence to Jay Lefkowitz."
+Here again, the materials at issue go to the heart of this case - what kind of notifications were
+made to the victims and how did the defense attorneys shape and limit those notifications.
+Moreover, in evaluating victims' rights issues and determining what kind of letter to send, the
+Government was fulfilling legal duties that it owed to the victims. Accordingly, the Office
+cannot now assert privilege when questions about whether it fulfilled its obligations to the
+victims have arisen in this case.
+Communications Facilitating Crime-Fraud-Misconduct Not Covered
+83. I am familiar with the cases cited in our brief regarding an exception to various privileges
+when the communications concern crime, fraud, or government misconduct. Many of the
+important documents about the treatment of the victims to which the Government is asserting
+privilege would fall within that exception.
+84. With regard to fraud and government misconduct, a number of the documents in the
+Government's privilege log concern concealment from the victims of the existence of a nonprosecution agreement between the Government and Epstein. I have reviewed a copy of the nonprosecution agreement signed on about September 24, 2007, by Epstein and his attorneys and a
+representative of the U.S. Attorney's Office. The text of that agreement bars disclosure of the
+agreement to the victims.
+85. On about January 10, 2008, my clients Jane Doe No. 1 and Jane Doe No. 2 received letters
+from the FBI advising them that "[t]his case is currently under investigation. This can be a
+lengthy process and we request your continued patience while we conduct a thorough
+investigation." The statement in the notification letter was deceptive, because it did not reveal
+that the case had previously been resolved by the non-prosecution agreement entered into by
+Epstein and the U.S. Attorney's Office discussed previously. Moreover, the FBI did not notify
+Jane Doe No. 1 or Jane Doe No. 2 that a plea agreement had been reached previously, and that
+part of the agreement was a non-prosecution agreement with the U.S. Attorney's Office for the
+16
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 17 of
+Southern District of Florida and that the Non-Prosecution Agreement would resolve the federal
+case completely. (Whether the FBI itself had been properly informed of the non-prosecution
+agreement is also unclear. We are not alleging misconduct by the FBI, but rather that the FBI
+was not properly informed about the case or, in any event, was acting at the direction of the U.S.
+Attorney's Office.)
+86. In about April 2008, Jane Doe No. 1 contacted the FBI because Epstein's counsel was
+attemptine to take her deposition and private investigators were harassing her. Assistant U.S.
+Attorney
+• secured pro bono counsel to represent Jane Doe No. 1 and several
+ther identified victims in connection with the criminal investigation. Pro bono counsel was able
+to assist Jane Doe No. 1 in avoiding the improper deposition. AUSA
+a secured pro bono
+counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in
+Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms.
+Garvin was not advised that a non-prosecution agreement had been reached in this matter.
+87. On May 30, 2008, another one of my clients who was recognized as an Epstein victim by the
+U.S. Attorney's Office, received letters from the FBI advising her that "[t]his case is currently
+under investigation. This can be a lengthy process and we request your continued patience while
+we conduct a thorough investigation." The statement in the notification letter was deceptive
+because it did not reveal that the case had been resolved by the non-prosecution agreement
+entered into by Epstein and the U.S. Attornev's Office in September 2007.
+88. In mid-June 2008, I contacted AUSA
+to inform her that I represented Jane Doe No.
+1 and, later, Jane Doe No. 2. I asked to meet to provide information about the federal crimes
+committed by Epstein, hoping to secure a significant federal indictment against Epstein. AUSA
+and I discussed the possibility of federal charges being filed. At the end of the call,
+asked me to send any information that I wanted considered by the U.S.
+Attorney's Office in determining whether to file federal charges. I was not informed that
+previously, in September 2007, the U.S. Attorney's Office had reached an agreement not to file
+federal charges. I was also not informed that any resolution of the criminal matter was imminent
+at that time. Presumably the reason the U.S. Attorney's Office withheld this information from
+me was because of the confidentiality provision that existed in the non-prosecution agreement.
+At this point it is clear that AUSA
+was restricted in what she was being permitted to
+89. On July 3, 2008, I sent to AUSA
+a letter. In the letter, I indicated my client's
+desire that federal charges be filed against defendant Epstein. In particular, I wrote on behalf of
+my clients: "We urge the Attorney General and our United States Attorney to consider the
+fundamental import of the vigorous enforcement of our Federal laws. We urge you to move
+forward with the traditional indictments and criminal prosecution commensurate with the crimes
+Mr. Epstein has committed, and we further urge you to take the steps necessary to protect our
+children from this very dangerous sexual predator." When I wrote this letter, I was still unaware
+that a non-prosecution agreement had been reached with Epstein - a fact that continued to be
+concealed from me (and the victims) by the U.S. Attorney's Office. I only learned of this fact
+90. As alleged in the preceding paragraphs, and elsewhere in this affidavit and in this case,
+deliberate concealment from crime victims and their legal counsel of the existence of a signed
+17
+
+
+Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 18 of
+non-prosecution agreement would be a fraud and government misconduct. Documents relating
+to that fraud and misconduct would then fall outside of many of the privileges being asserted.
+91. An illustration of a document to which the crime-fraud-misconduct exception applies on this
+basis is found on page 3 of the supplemental privilege log (DE 216-1), with regard to Suppl. Box
+#3 P-013342 to P-013350. The entry reads: "File folder entitled '12/05/07 Starr to Acosta'
+containing drafts of 11/30/07 letters from A. Acosta to K. Starr and from |
+to I
+crime victims. And given the dates of the communications, in all likelihood they would be
+related to the deceptive notifications that the Government made to the victims a few weeks later.
+92. Another illustration of a document to which the crime-fraud-misconduct exception applies is
+found on page 1 of the supplemental privilege log (DE 216-1), with regard to Suppl. Box #3 P.
+015282 to P-013283, The entry reads: "7/9/08 Email from
+to A. Acosta,
+and FBI re proposed response to Goldberger letter re victim notification."
+These communications would presumably reflect efforts by the government prosecutors and
+Epstein's defense attorneys (e.g., Goldberger) to keep the non-prosecution agreement secret.
+93. Another illustration of where the crime-fraud-misconduct exception would apply is to
+information that the Government possesses that Bruce Reinhart learned private, non-public
+information about the Epstein case. This would show (at the very least) misconduct by Bruce
+Reinhart in later representing Epstein-related entities. Because the Government's (inadequate)
+privilege log does not reveal which entries relate to Reinhart, it is not possible to point the Court
+to the specific documents that demonstrate this misconduct. These documents, however, are
+covered by the crime-fraud-misconduct exception.
+94. Another illustration of where the crime-fraud-misconduct exception could potentially apply
+is with regard to information that the Government possesses that
+personal or business relationship with defendant Jeffrey Epstein. Gov't Answers to RFA's 120.
+This could potentially show misconduct by
+,, and also potentially a motive to violate the
+victims' rights as explained previously. The Government's privilege log has numerous entries
+showing that Menchal was substantially and personally involved in making decisions related to
+the Epstein prosecution. See, e.g., page 19 of the first privilege log (DE 212-1), with regard to
+Box #3 P-011923 to P-011966. The victims have information suggesting that immediately after
+leaving his employment with the U.S. Attorney's Office,
+was associated with Epsteincontrolled entities or had some business relationship with him.
+The documents that the
+Government possesses showing a personal or business relationship between one of its
+prosecutors and the man he was charged with prosecuting should be produced.
+95. The Government has admitted that its internal affairs component - the Office of Professional
+Responsibility - has collected information about possible improper behavior during the
+investigation of the Epstein matter, Gov't Answers to RFA 122 (government admits that "The
+Justice Department's Office of Professional Responsibility and/or other Government entities
+have collected information about ... other government attorney's [apart from Bruce Reinhart's]
+possible improper behavior in the Epstein matter"). The fact that the Government's own
+investigating agencies have collected such information demonstrates that there is a prima facie
+18
+
+
+Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 19 of
+case of improper behavior, which is enough to trigger the crime-fraud-misconduct exception to
+various privileges.
+Factual Materials Not Privileged
+96. As noted in the accompanying legal memorandum, factual materials are generally not
+covered by the privileges at issue in this case. Many of the materials to which the Government is
+asserting privilege are factual materials.
+Assertions of Attorney-Client Privilege
+97. The Government has asserted attorney client privilege regarding many documents. Yet with
+regard to most of these assertions, it is impossible to determine who is the attorney, who is the
+client, whether professional legal services are being rendered, and whether the communications
+were confidential to those involved in the delivery of legal services. Accordingly, it is very
+difficult for me to respond to many of the assertions of attorney client privilege and, in any
+event, the Government has failed to carry its burden of showing that the privilege applies.
+98. An illustration of documents at to which attorney-client privilege appears to have been
+improperly asserted or inadequately described is found at page 7 of the first privilege log (DE
+216-1), with regard to Suppl. Box #3 P-013811 to P-013833. The entry for these twenty-two
+pages of documents reads: "File folder entitled Information Packet Drafts' containing several
+drafts of Informations,
+and complete draft Information packet." It is impossible from this
+description to see how the attorney-client privilege applies to these documents. I could provide
+many other illustrations of the problem.
+99. The Government's attorney-client privilege claim directly covers situations where it was in a
+fiduciary relationship with the victims and therefore is limited in now asserting privilege. For
+example, page 3 of the supplemental privilege log (DE 216-1) contains an entry concerning
+Suppl. Box #3 P-013342 through P-013350, which involves "File folder entitled ' 12/05/07 Starr
+to Acosta' containing drafts of 11/30/07 letters from A. Acost to K. Starr and from /
+I. Lefkowitz re performance and victim notification with handwritten notes and edits by
+" This information goes very directly to the issues involved in this case, as it
+goes directly to "victim notification."
+Yet the Government has asserted
+an attorney-client
+privilege to prevent the victims from learning what is in these documents. The fiduciary
+exception to the attorney-client privilege applies in this situation, and limits the government's
+ability to invoke a privilege. This also appears to be shared communications between the
+Government and Epstein's attorneys, and it is unclear how the attorney-client privilege could
+ethically apply to such documents.
+100. As one example of why the victims have established a compelling need for the materials
+described in the preceding paragraph (and other materials like them) is the fact that the Court has
+indicated that it will be considering an "estoppel" argument raised by the Government as a
+defense in this case. DE 189 at 12 n.6. The Court has noted that this argument "implicates a
+fact-sensitive equitable defense which must be considered in the historical factual context of the
+entire interface between Epstein, the relevant prosecutorial authorities and the federal offense
+victims - including an assessment of the allegation of a deliberate conspiracy between Epstein
+and federal prosecutors to keep the victims in the dark on the pendency of negotiations between
+Epstein and federal authorities until well after the fact and presentation of the non-prosecution
+agreement to them as a fait accompli." DE 189 at 12 n.6 (emphasis added). The materials to
+19
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 20 of
+which the Government is asserting attorney-client privilege go directly to that "interface"
+between the victims, the Government, and Epstein. The victims have a compelling need for this
+information and the fiduciary exception to the attorney-client privilege applies to permit the
+Court to provide these documents to the victims.
+101. The Government has not explained any harm that would come from releasing the
+documents covered by attorney client privilege to the victims. If the Government raises any such
+harm, I respectfully request an opportunity to provide additional information on that alleged
+harm.
+102. Some of the correspondence that is being withheld by the Government under the
+deliberative process privilege concerns an investigation that the Justice Department's Office of
+Professional Responsibility (OPR) opened with regard to the Epstein case. This investigation
+was undertaken at the request of the victims in this case. On December 10, 2010, co-counsel,
+Professor Paul Cassell of the University of Utah College of Law, and I met with the U.S.
+Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in
+Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr.
+Ferrer, asking him to personally investigate what happened during the Epstein prosecution and
+how the victims were treated during that investigation. Based on the privilege log that has been
+provided, as well as subsequent correspondence sent to Professor Cassell, that request for
+investigation was turned over to OPR in Washington, D.C.
+103. The ultimate outcome of the OPR investigation is unclear. What is clear is that many
+documents are being withheld about that investigation - documents that would go to the central
+issues in this case. Approximately three whole pages of the privilege log - pages 12 through 14
+of the supplemental privilege log (DE 216-1) - relate to the OPR investigation of how the
+Epstein case was handled and how the victims were treated.
+104. A deliberative process privilege claim can only be asserted with regard to the process of
+reaching a decision, not the ultimate decision itself. The Government here has apparently
+asserted a deliberative process claim over not only the OPR process, but also over the OPR
+decision. It is not clear which document embodies the final OPR decision (or, given the
+inadequacies of the Government's privilege log, whether that final decision has been produced).
+Given the limited descriptions of the documents that have been provided, it appears that the OPR
+decision may be reflected in a document found on page 13 of the supplemental privilege log (DE
+216-1), with regard to Suppl. Box #3 P-013940 to P-013942. The description there reads: "Draf
+Letter, marked 'Confidential: To Be Opened by Addressee Only,'
+with handwritten corrections." No date is provided regarding this letter. Nor is there
+any indication as to whether the letter was or was not circulated to other persons. It is also
+noteworthy that this letter is described as a "draft" letter. Nowhere in the privilege log is the
+final version of the letter indicated, raising questions about what was "draft" and what was
+"final." If this is the final embodiment of OPR's conclusions, then this letter would not be
+protected by a "deliberative process" privilege, because the deliberations would have come to an
+end. (It is also worth noting that because OPR is an agency that investigates misconduct by
+federal prosecutors, it would not be providing attorney-client advice to prosecutors and its
+20
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 21 of
+documents would not be attorney-client privileged with regard to, for example, the U.S.
+Attorney's Office for the Southern District of Florida.)
+105. The fact that OPR has investigated many of the exact claims raised by Jane Does 1 and 2,
+conclusion likely means that production of the OPR file to the victims in this case could
+significantly shortcut this discovery process and the litigation. Additionally, if OPR "needed"
+the documents to investigate and make findings regarding the victims' claims, then logically the
+victims share that "need" and have no other means through which to obtain the documents. The
+Government has not explained any harm that would come from releasing the documents covered
+by deliberative process privilege to the victims. If the Government raises any such harm, I
+respectfully request an opportunity to provide additional information on that alleged harm.
+Investigative Privilege
+106. The investigative privilege is a qualified privilege, which balances the need of particular
+litigate for access to information against any public interest in non-disclosure. That balancing
+process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59
+F.R.D. 339, 344 (E.D.Pa. 1973), specifically:
+(1) the extent to which disclosure will thwart governmental processes by
+discouraging citizens from giving the government information; (2) the impact
+upon persons who have given information of having their identities disclosed; (3)
+the degree to which governmental
+self-evaluation and consequent program
+improvement will be chilled by disclosure; (4) whether the information sought is
+factual data or evaluative summary; (5) whether the party secking the discovery is
+an actual or potential defendant in any criminal proceeding either pending or
+reasonably likely to follow from the incident in question; (6) whether the police
+investigation has been completed; (7) whether any intradepartmental disciplinary
+proceedings have arisen or may arise from the investigation; (8) whether the
+plaintiff's suit is non-frivolous and brought in good faith; (9) whether the
+information sought is available through other discovery or from other sources;
+and (10) the importance of the information sought to the plaintiff's case.
+On the facts of this case, these factors weigh in favor of disclosing the information the victims
+have requested.
+107. With regard to factor (1) (the extent to which disclosure will thwart governmental
+processes by discouraging citizens from giving the government information), I represented four
+victims of Epstein's sex offenses in Federal Court - Jane Doe No. 1, Jane Doe No. 2, and a
+victim I will refer to as "S.R." and "M.J.", and other victims of Jeffrey Epstein's abuse as well.
+If further information is disclosed about this case, that will not discourage them from providing
+information, but rather will encourage them. I have also talked personally to attorneys for a
+number of other victims in this case. I have been told that many of these other victims hope that
+Jane Doe No. 1 and Jane Doe No. 2 are successful in their case.
+108. With regard to factor (2) (the impact upon persons who have given information of having
+their identities disclosed), Jane Doe No. 1 and Jane Doe No. 2 are not asking for information that
+would identify any particular victim. Accordingly, there will be no effect on other victims.
+Additionally, I am aware of the true names of many of Epstein's victims and that information has
+21
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 22 of
+not been disseminated to the public where those individual victims did not wish for their
+identities to be disseminated.
+109. With regard to factor (3) (the degree to which governmental self-evaluation and consequent
+program improvement will be chilled by disclosure), this is a lawsuit to force the compliance by
+the Government with its CVRA obligations. Accordingly, the Government's "program" of
+providing victims' rights will be directly improved if the victims are able to enforce their rights
+in this lawsuit.
+110. With regard to factor (4) (whether the information sought is factual data or evaluative
+summary, many of the items that the victims seeks are factual summaries. An example of this is
+found at page 18 of the first privilege log (DE 212-1), with regard to Box #3 P-011778 to P-
+011788. The entry reads: "File folder entitled "6/12/09 Victim Notif. Log' containing chart with
+victim contact information and attorney notes regarding dates and type of contacts." This would
+include, for example, dates of contacts with Jane Doe No. 1 and Jane Doe No. 2, which would be
+purely factual information.
+111. With regard to factor (5) (whether the party seeking the discovery is an actual or potential
+defendant in any criminal proceeding either pending or reasonably likely to follow from the
+incident in question), Jane Doe No. 1 and Jane Doe No. 2 are plainly victims of a crime, not
+criminal defendants. Indeed, as the Court is aware, it is the criminal defendant (Jeffrey Epstein)
+who has undertaken several "limited" intervention efforts to try and block disclosure of
+information to the victims.
+112.
+With regard to factor (6) (whether the police investigation has been completed), the
+investigation of Epstein was completed years ago and the Government has not produced in its
+privilege log any information indicating recent investigative activity.
+With regard to factor (7) (whether any intradepartmental disciplinary proceedings have
+arisen or may arise from the investigation), it appears than OPR investigation has arisen as a
+direct result of the victims' efforts in this case. However, it does not appear that release of any
+information to the victims would hamper any disciplinary proceedings. Indeed, to the extent that
+the victims are able to obtain information about this case and find information about misconduct,
+then they can provide that information to Government and other disciplinary entities as
+appropriate.
+114. With regard to factor (8) (whether the plaintiff's suit is non-frivolous and brought in good
+faith), it should be clear at this juncture of a five-year long case that the victims have a
+substantial claim that is brought in good faith.
+115.
+With regard to factor (9) (whether the information sought is available through other
+discovery or from other sources), as recounted throughout this affidavit, the victims have no
+other way to obtain the information at issue in this privilege debate, as it involves information
+internal to the Justice Department.
+116. With regard to factor (10) (the importance of the information sought to the plaintiff's case),
+the information that the victims are seeking is highly important to their case. Indeed, without
+adequate proof, the Court has indicated that it may have to deny the victims' petition. DE 99 at
+11. Throughout this affidavit, I have provided numerous examples and explanations of why the
+victims need the information that they are requesting. The documents to which the Government
+22
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 23 of
+s asserting investigative privilege, for example, bear directly on the Government's allege
+estoppel defense, which the victims need a complete evidentiary record to disput
+Work-Product Doctrine
+117. A work product claim can be defeated by a showing of substantial need and undue hardship
+to obtain the materials in other ways. In this affidavit, I have tried to articulate the specific and
+compelling need for all of the materials that victims are seeking. I will not repeat all of those
+assertions here, but simply note that I stand ready to provide any additional information that the
+Court may require to determine the compelling need that the victims have for the materials they
+have requested as well as the undue hardship (if not actual impossibility) of obtaining the
+materials in other ways. Any balancing of considerations tips decisively in the victims favor.
+118. As one example, the victims have a compelling need for the materials that OPR collected as
+part of its investigation. Because Justice Department attorneys are generally required to talk to
+OPR investigators, OPR was apparently able to investigate the claims of misconduct related to
+the Epstein case by getting statements from the attorney's involved. These interviews appear to
+be recorded in materials found at page 14 of the supplemental privilege log (DE 216-1), with
+regard to Suppl. Box #3 P-013956 to P-013846 [sic - apparently should be P-013970, a total of
+14 pages].
+Judging from the entry, these notes would be factual statements from Justice
+Department prosecutors about how the Epstein case was handled and whether any misconduct
+occurred during the handling of the case. Those are central issues in this case. There is no other
+way for the victims to obtain information about these subjects, because the Justice Department
+has declined to provide information on this subject.
+previous paratims ha of this blinda i sul reviel ed is the mates, the dr meeting in the
+requests numbers 1 through 25 and supplemental request number 1.
+As another example of why the victims have established a compelling need for the
+materials is the fact that the Court has indicated that it will be considering an "estoppe!"
+argument raised by the Government as a defense in this case. DE 189 at 12 n.6. The Court has
+noted that this argument "implicates a fact-sensitive equitable defense which must be considered
+in the historical factual context of the entire interface between Epstein, the relevant prosecutorial
+authorities and the federal offense victims - including an assessment of the allegation of a
+deliberate conspiracy between Epstein and federal prosecutors to keep the victims in the dark on
+the pendency of negotiations between Epstein and federal authorities until well after the fact and
+presentation of the non-prosecution agreement to them as a fait accompli." DE 189 at 12 n.6
+(emphasis added). The materials to which the Government is asserting work product protection
+go directly to that "interface" between the victims, the Government, and Epstein. The victims
+have no other way of showing what that interface is. The Government will not be harmed if the
+materials are provided to the victims.
+Grand Jury Information
+121. The victims' legal pleading has explained why the Government has not properly asserted
+any grand jury secrecy to the documents at issue. In addition, many of the Government's grand
+jury privilege assertions appear to broadly cover both grand jury and non-grand jury information.
+Even if the Court allows the Government to assert some form of grand jury privilege, it should
+require the Government to sever grand jury materials from non-grand jury materials.
+23
+
+
+Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 24 of
+122. An illustration of this problem comes from page 12 of the first privilege log (DE 212-1),
+with regard to Box #2 P-008616 to P-008686.
+The entry reads: "File folder entitled 'FBI
+Summary Charts' containing chart prepared at direction of AUSA, containing victims names,
+identifying information, summary of activity, and other information relevant to indictment."
+This does not appear to be a document that was ever presented to the grand jury or that directly
+discloses grand jury proceedings. Moreover, to the extent that it involves some kind of limited
+disclosure of grand jury proceedings, that limited disclosure could be redacted and the other
+information provided to the victims.
+123. It does not appear that any of the alleged grand jury materials that the Government is
+asserting privilege involve on-going grand jury issues. Moreover, it does not appear that
+disclosing any of the materials would "tip off" a potential target to a Government investigation.
+Of course, Jeffrey Epstein (and his associates) are well aware of the Government's investigation
+into their crimes against young girls for sexual purposes.
+124. The Government has not explained any harm that would come from releasing the
+cuments to the victims. If the Government raises any such harm, I respectfully request
+portunity to provide additional information on that alleged harn
+Privacy Rights of Other Victims
+125. Jane Doe No. 1 and Jane Doe No. 2 do not seek confidential or identifying information
+about any other victims. To clarify that fact, on July 31, 2013, I sent a letter to the Government
+stating, in part, that "to avoid any interference with any privacy rights of victims who are not
+parties to this litigation, Jane Doe #1 and Jane Doe #2 are not seeking any identifying
+information about other victims. In any of the documents that Jane Doe #1 and Jane Doe #2 have
+requested the Government produce, the Government should not produce the names of other
+victims or other identifying information (e.g., address or telephone number) but should instead
+redact that information."
+*****
+I declare under penalty of perjury, pursuant to 28 U.S.C. § 1746, that the foregoing is
+true and correct to the best of my knowledge and belief.
+Executed this 16th day of August, 2013.
+/s/ Bradley J. Edwards
+BRADLEY J. EDWARDS, ESQ.
+Attachments:
+1. October 3, 2011, request for production;
+2. June 24, 2013, supplemental request for production; and
+3. Victims' Requests for Admissions and Government Answers
+24
+
+
+Document 225-1 Entered on FLSD Docket 08/16/2013 Page 25 of
+
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 26 of
+SINTED TRIST OF TODA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs
+v.
+UNITED STATES,
+Defendants
+JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR PRODUCTION
+TO THE GOVERNMENT REGARDING INFORMATION RELEVANT TO THEIR
+PENDING ACTION CONCERN THE CRIME VICTIMS RIGHTS ACT
+COME NOW Jane Doe #1 and Jane Doe #2 ("the victims"), by and through undersigned
+counsel, and request the defendant United States (hereinafter "the Government") to produce the
+original or best copy of the items listed herein below for inspection and/or copying, pursuant to
+the Court's Order (DE #99) directing discovery in this case.
+BACKGROUND
+As the Government will recall, the victims have asked the Government to stipulate to
+undisputed facts in this case. The Government has declined. Accordingly, the victims filed their
+Motion for Finding of Violations of the Crime Victims' Rights Act and Request for a Hearing on
+Appropriate Remedies (DE 48) (the victims' "summary judgment motion") along with a Motion
+to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts
+(DE 49).
+On September 26, 2011, the Court denied the victims' motion to have their facts accepted
+(DE 99 at 11). At the same time, however, the Court has ordered discovery to develop the
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 27 of
+factual record concerning the summary judgment motion (DE 99 at 11). The Court reserved
+ruling on the victims' motion for an order directing the Government not to suppress relevant
+evidence (DE 99 at 11).
+On September 28, 2011, the victims requested that the Government voluntarily provide
+documents concerning this case. The Government declined to provide even a single document.
+Accordingly, the victims now seek the following information relevant to their pending summary
+judgment motion.
+DISCOVERY REQUESTED
+The numbered discovery requests below should all be construed in light of the definitions of
+terms provided at the end of the requests.
+1. In the victims' currently-pending summary judgment motion, the victims contend that the
+Government conducted an extensive criminal investigation into Jeffrey Epstein's sexual
+exploitation of young girls, including Jane Doe #1 and Jane Doe #2 between 2001 and 2008.
+The victims also contend that the FBI and other federal agencies established that Epstein
+operated a large criminal enterprise that used paid employees and underlings to repeatedly find
+and bring minor girls to him. In deferring ruling on the victims' summary judgment motion, the
+Court noted that the victims had alleged that the FBI and the U.S. Attorney's Office's
+"investigation developed a strong case for a federal prosecution against Epstein based on
+'overwhelming' evidence." DE 99 at 2. The Court, however, also noted that this was an
+allegation that needed "further factual development." DE 99 at 2 n.2. Please provide all
+documents, correspondence, and other information that supports these victims' allegations,
+including:
+(a) the FBI case file on the Epstein case;
+(b) all documents, correspondence, witness statements, FBI 302s, and other
+similar information, that the Government collected as part of its case against
+and/or investigation of Epstein, including any information provided to Epstein
+or receive from Epstein as part of "discovery" or exchange of information
+concerning the case;
+(c) all documents, correspondence, witness statements, and other similar
+information that the Government received from any federal, state, local, or
+other law enforcement agency regarding sex offenses committed against
+children by Jeffiey Epstein;
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 28 of
+offenses that the Government developed in this case and any similar successor
+or predecessor document; and
+(e) Any other prosecution memorandum regarding Jeffrey Epstein (and any
+documents attached to that memorandum) and all draft federal indictments
+that were prepared regarding Epstein. Please also provide all documents,
+correspondence, and other information regarding these prosecution
+memoranda and the draft federal indictments.
+2. Throughout their pending summary judgment motion, the victims contend that they
+received only limited notifications from the Government (and, in particular, the U.S. Attorney's
+Office acting through FBI agents) about the plea negotiations that occurred with Jeffrey Epstein
+and the non-prosecution agreement that was ultimately reached. Please provide all documents,
+correspondence and other information regarding victim notifications in this case, including (but
+not limited to):
+a) All crime victims notifications (and draft notifications) sent to Jane Doe #1 and
+Jane Doe #2 and the other identified victims of Epstein's offenses;
+b) All correspondence, documents, and other information regarding negotiations
+between the Government and Epstein's defense attorneys concerning the extent
+and nature of notifications to be made to Epstein's victims;
+c) All correspondence, documents, and other information regarding discussions
+between the Government, the FBI, the Palm Beach Police Department, the Palm
+Beach County State Attorney's Office,
+and Epstein's defense attorneys
+concerning the extent and nature of notifications to be made to Epstein's victims;
+d) All correspondence, documents, and other information regarding "marching
+orders" that were given to FBI agents regarding the information that they could
+provide to the victims about the negotiations and the non-prosecution agreement;
+e) All correspondence, documents, and other information regarding information that
+could be given to attorneys for the victims about the non-prosecution agreement,
+including information about what could be told to Brad Edwards (counsel for Jane
+Doe #1 and Jane Doe #2) about the non-prosecution agreement;
+f) All correspondence, documents, and other information regarding Epstein's
+awareness that his victims (including Jane Doe #1 and Jane Doe #2) would not be
+notified of the non-prosecution agreement (and its ultimate presentation in court)
+or given a chance to confer regarding the plea negotiations he was conducting
+with the Government.
+3. The victims allege in their pending summary judgment motion that the Government
+egotiated a non-prosecution agreement with Epstein and that among the subjects covered in tha
+on-prosecution agreement was a confidentiality provision that precluded disclosing th
+agreement to them and to other victims. Please provide all draft plea agreements (both state and
+federal) and non-prosecution agreements prepared either by attorneys for the Government or by
+torneys for Epstein, as well as any correspondence, documents or other information pertaini
+these agreements and to any confidentiality provision in these agreements. Please indica
+that date on which each of these proposed agreements was drafted and by whom.
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 29 of
+4. The victims allege in their pending summary judgment motion that the Government was
+interested in finding a place to conclude any plea agreement that would effectively keep
+Epstein's victims (most of whom resided in or about West Palm Beach) from learning what was
+happening through the press.
+Please provide all correspondence, documents, and other
+information pertaining to negotiations between the Government and Jeffrey Epstein concerning
+the court and/or location in which Jeffrey Epstein would enter any guilty plea (including in
+particular any negotiations concerning concluding the plea in Miami or other location outside of
+West Palm Beach).
+5. The victims allege in their pending summary judgment motion that part of the plea
+negotiations with Epstein involved Epstein's efforts to make sure that the victims would be
+represented in civil cases against Epstein by someone who was not an experienced personal
+injury lawyer. Please provide all correspondence, documents, and other information pertaining
+to negotiations between the Government and Jeffrey Epstein regarding any legal representation
+of the victims in civil cases against Epstein, including any negotiations about what kinds of
+representation should be provided in a plea agreement or non-prosecution agreement.
+6. The victims allege in their pending summary judgment that the Government wanted the
+non-prosecution agreement with Epstein concealed from public view because of the intense
+public criticism that would have resulted had the agreement been disclosed and/or the possibility
+Please provide all correspondence, documents,
+and other information concerning the
+Government's and/or Epstein awareness or discussion of this possible public criticism and/or
+victim objections.
+7. The victims allege in their pending summary judgment motion that the Government was
+aware that it potentially had obligations under the CVRA to notify the victims about the nonprosecution agreement and any related state court plea agreement. Please provide all
+correspondence, documents, and other information regarding the Government's awareness of its
+potential CVRA obligations in this case and regarding any discussions between the Government
+and Epstein concerning these CVRA obligations in this case. This should include any objections
+raised by Epstein to any notification of the victims (including Jane Doe #1 and Jane Doe #2) and
+any Government response to these objections. This should also include any correspondence and
+information about whether the CVRA applied to the victims.
+8. The victims allege in their pending summary judgment motion that, after Epstein signed
+the non-prosecution agreement, his performance was delayed while he used his significant social
+and political connections to lobby the Justice Department to obtain a more favorable plea deal
+(including lobbying components of the Justice Department in Washington, D.C., including the
+Child Exploitation Obscenity Section). Please provide all correspondence, documents, and other
+information regarding Epstein's lobbying efforts to persuade the Government to give him a more
+favorable plea arrangement and/or non-prosecution agreement, including efforts by former
+President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York),
+Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy
+Black on his behalf.
+
+
+Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 30 of
+9. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI
+dvising them that "this case is currently under investigation." Please provide all documents
+correspondence, and other information relating to those representations being made by the FBI t
+Jane Doe #1 and Jane Doe #2, including all information about whether the FBI was aware of the
+non-prosecution agreement at that time and about whether Epstein was aware of the notifications
+being made to the victims.
+10. In their pending summary judgment motion, the victims have alleged that the FBI was led
+to believe that their investigation of Epstein was going to produce a federal criminal prosecution
+and that the FBI was also misled by the U.S. Attorney's office about the status of the case.
+Please provide all documents, correspondence, and other information relating to these
+allegations, including:
+a) All documents, correspondence, and other information relating to discussions
+between the U.S. Attorney's Office and the FBI concerning the status of the
+investigation and the plea discussions with Epstein, as well as what kind of
+charges would appropriately be filed against Epstein;
+b) All documents, correspondence, and other information relating to the U.S.
+Attorney's Office's representations to the FBI and any other state or local law
+enforcement agency about how this case was being handled; and
+c) All documents, correspondence, and other information relating to whether the FBI
+would support the position of the U.S. Attorney's Office that it has not violated
+the rights of Epstein's victims in this case.
+11. In their pending summary judgment motion, the victims have alleged that they had
+various meetings with Government prosecutors and/or agents (including FBI agents). Related to
+these meetings, they also allege that in mid-June 2008, their attorney (Bradley J. Edwards)
+discussed with an AUSA involved in the case the need for filing federal charges and that the
+AUSA asked the attorney to send a letter about why such charges should be filed without
+disclosing the existence of a previously-signed non-prosecution agreement. The victims further
+allege that on about July 3, 2008, their attorney sent a letter urging the filing of federal charges
+against Epstein. Please provide all documents, correspondence, and other information regarding
+these meetings with the victims and their legal counsel, including meetings with the victims on
+October 26, 2007, and January 31, 2008, and the contact with their legal counsel in mid-June
+2008. Please also provide all documents, correspondence, and other information related to
+contacts between the Government and the National Crime Victim's Law Institute (NCVLI)
+concerning possible legal representation or other assistance to the victims by NCVLI.
+12. In their pending summary judgment motion, the victims allege that in mid-June 2008,
+their attorney (Bradley J. Edwards) discussed with an AUSA involved in the case the need for
+flanges deral herie nd that disclosing the ed then attorney to end a letter agency such
+victims further allege that on about July 3, 2008, their attorney sent a letter urging the filing of
+federal charges against Epstein. Please provide all documents, correspondence, and other
+intormation regarding these contacts, including e-mails and correspondence generated as a resul
+of the attorney's inquiry and any action that was taken in response to the letter that he sent.
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 31 of
+13. In their pending summary judgment motion, the victims allege that on or about June 27,
+2008, the Government learned that Epstein would be entering his plea to state charges on about
+June 30, 2008. Please provide all documents, correspondence, and information regarding:
+a) How the Government Office learned that the plea was going to be entered;
+b) How the Government notified victims about the entry of the guilty plea; and
+c) The contents of the notifications given to the victims about the entry of the guilty,
+including whether the victims were informed about the non-prosecution
+agreement and about whether the entry of this plea would preclude prosecution of
+crimes Epstein had committed against them.
+14. In their pending summary judgment motion, the victims have alleged that the
+Government and Epstein worked together to keep the existence of the non-prosecution
+agreement secret, including declining comment about the existence of such an agreement when
+asked about it when his guilty plea in state court became public knowledge. Please provide all
+documents, correspondence, and information about the Government's and Epstein's efforts to
+the existence of the
+non-prosecution agreement secret, including all e-mails and
+correspondence about "declining comment" or similar devices to keep the non-prosecution
+agreement secret.
+15. In their pending summary judgment motion, the victims allege that at all materials times,
+it would have been practical and feasible for the Government to have kept the victims informed
+about the discussions concerning the non-prosecution agreement. The victims further allege that
+on about July 9, 2008, the U.S. Attorney's Office provided notice to Jane Doe #1 of some of the
+terms of the agreement between it and Jeffrey Epstein. The victims also received a "corrected"
+notification letter on about September 3, 2008. Please provide all documents, correspondence,
+and other information about these notifications, including:
+a) any information about whether these notifications should or should not include
+some mention of the non-prosecution agreement;
+b) any information about the contents of these notifications;
+any communications between the Government and Epstein's counsel regarding
+what the notifications should contain, including any communication on or about
+July 9, 2008, objecting to parts of the draft;
+d) Any communications between the Government and Epstein's counsel about
+which parts of the non-prosecution agreement were operative (including whether
+Part 3 was operative;
+e) Any communications between the Government and Epstein's counsel regarding
+the September 3, 2008, corrected notification letter; and
+f) any documents, correspondence, and other information regarding the practicality
+and feasibility of providing notice to the victims of the existence of the
+agreement, which shall include any correspondence related to meeting with the
+victims or notifying them in any way of the non-prosecution agreement.
+16. In their pending summary judgment motion, the victims allege that one of the senior
+prosecutors in the U.S. Attorney's Office joined Epstein's payroll shortly after important
+decisions were made limiting Epstein's criminal liability - and improperly represented people
+close to Epstein. In light of this fact, the peculiar nature of the non-prosecution agreement
+
+
+Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 32 of
+reached in this case, and other information in the possession of the victims, it is also possible that
+other improper relationships exist between Government agents and Epstein. Please provide any
+documents, correspondence, and other information regarding the possibility of any improper
+relationship, including:
+a) Attorney Bruce Reinhart's involvement in and/or awareness of any aspect of the
+Government's criminal investigation and/or possible prosecution/non-prosecution
+of Epstein;
+b) Attorney Bruce Reinhart's involvement in and/or awareness of the Government's
+interest in any witness, subject, or target of the Enstein investigation, including
+Ghislaine Maxwell,
+Larry Mornson, carry Visoki, David Rogers, William
+Hammond, and Robert Roxburgh;
+c) All documents, correspondence, and other information reflecting telephone calls
+(including telephone logs and telephone billing statements) made by or received
+by Reinhart from Jeffrey Epstein, the Florida Science Foundation, Jack
+Goldberger, Alan Dersowitz, Roy Black, Ken Starr, Lillian Sanchez, and any
+other person involved with the criminal defense of Jeffrey Epstein, including
+telephone calls to and from Jack Goldberger and the Florida Science Foundation;
+d) All documents, correspondence, and other information (including, for example, e-
+mails) that were sent to copied to, or sent by Reinhart in which the word
+"Epstein,"
+" "Morrison," "Visoki," "Rogers," "Hammond,"
+Roxburgh,"
+" "Florida Science Foundation," "Starr," "Black,"
+"Goldberger," "Jeffrey," "Australian," «
+"Sanchez," "358 El Brillo Way"
+appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger,
+or the Jeffrey Epstein investigation or prosecution;
+e) All documents, correspondence, and other information (including for example e-
+mails) of a similar nature that indicate that any other Government prosecutor has
+represented (or discussed representing) a person or entity related to Jeffrey
+Epstein or has received business or funds from a person or entity related to Jeffrey
+f) All documents, correspondence, and other information that indicate or suggest
+that any Government prosecutor or investigator (including state and local
+prosecutor or investigator) has had any form of business, social, personal, or other
+relationship with Jeffrey Epstein or a person or entity related to Jeffrey Epstein;
+g) All documents, correspondence, and other information that indicate or suggest
+that any Government prosecutor or investigator (including state and local
+prosecutor or investigator) would receive anything of value, directly or indirectly
+from Jeffrey Epstein or a person or entity related to Jeffrey Epstein (including any
+charitable contributions to be made by Epstein to any entity).
+17. In December 2010, the victims sent a letter to the U.S. Attorney's Office for the Southern
+District of Florida, requesting that the Office investigate whether "improper influences" were
+brought to bear during the negotiations involving the possible prosecution (and ultimately the
+non-prosecution) of Jeffrey Epstein. That letter led to a reference of the matter to the Office of
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 33 of
+Professional Responsibility (OPR) in the Justice Department in Washington, D.C., which began
+some kind of an inquiry/investigation. Please provide:
+a) All documents, correspondence, and other information collected by the Office of
+Professional Responsibility (OPR) and any other component of the Justice
+Department (including the FBI) in response to the victims' letter;
+b) All documents, correspondence, witness statements, and other information
+collected as part of OPR's inquiry/investigation;
+c) All documents, correspondence, witness statements and other information
+collected as part of any criminal inquiry/investigation that was initiated as a result
+of that letter, including any inquiry/investigation into criminal conflict of interest
+violations (such as 18 U.S.C. § 205 and § 207)
+d) All documents, correspondence, witness statements, and other information
+collected by any federal investigative agency that was triggered by OPR's
+inquiry/investigation, including any FBI inquiry/investigation regarding any
+improper influences or criminal or ethical violations that may have been
+committed by government attorneys during the handling of the Epstein
+investigation and/or prosecution;
+e) Any documents, correspondence, and other information regarding the accuracy or
+inaccuracy of Bruce Reinhart's sworn statements (found in DE 79-1 at p. 31) that
+he "did not participate in any way in the Office's investigation of Epstein;" that he
+"was not involved in any of the Office's decisionmaking with regard to the
+Epstein matter;" and that he "never learned any confidential, non-public
+information about the Epstein matter,"
+f) Any documents, correspondence,
+or other
+information regarding the
+circumstances that lead OPR to send a letter to the victims on May 6, 2011,
+indicating that they would not provide any further assistance to the victims in
+connection with their allegations that improper influences were brought to bear on
+the Epstein case;
+g) Any document, correspondence, e-mail, memoranda, or other information
+prepared by OPR, the FBI, or other Justice Department Component as a result of
+or following up on the victims' December 2010 letter concerning the Epstein
+case; and
+h) Any documents, correspondence, or other information that OPR has collected or
+obtained regarding the Epstein investigation and/or prosecution.
+18. At a couple points during the prosecution of this action, including in approximately
+December 2010 and most recently after the August 2011 hearing, the Justice Department in
+Washington, D.C., discussed or determined that the U.S. Attorney's Office for the Southern
+District of Florida (USAO SDFL) was "conflicted out", or may be conflicted out, of handling
+various issues related to the Epstein case because it suffered from a conflict of interest. The
+Justice Department accordingly sent various issues related to the Epstein case (and, on
+information and belief, issues related to Jane Doe #1 and Jane Doe #2) to the Department of
+Justice and to a United States Attorney's Office in another District. Please provide all
+documents, correspondence, and other information regarding the potential conflicts of interest
+that the Justice Department discussed or determined existed for the USAO SDFL, as well as any
+referral that was made to Main Justice or to any other District, including any documents that
+
+
+Case 9:08-cV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 34 of
+were transmitted to any other District regarding the conflict and regarding what was to be
+investigated.
+19. In March 2011, former U.S. Attorney Alexander Acosta sent a three-page letter to the
+news media in which he claimed that when Government attorneys began investigating Epstein,
+Epstein launched "a yearlong assault on the prosecution and the prosecutors." Shortly thereafter,
+Jeffrey Epstein's defense attorney Roy Black sent a responsive letter to Alexander Acost's letter
+to the news media in which he claimed that he did not pry into the personal lives of prosecutors
+but merely pointed out misconduct and over-reaching by certain people involved in the Epstein
+investigation. Please provide all documents, correspondence and other information that supports
+or contradicts Acosta's allegations in his letter, including any information that the Justice
+Department received from Epstein attacking the prosecutors and investigators working on the
+case. Please also provides all documents, correspondence, information about misconduct and
+over-reaching that was provided by Black and that the Government found that supported or
+contradicted such allegations.
+20. In their pending summary judgment motion, the victims have alleged that Epstein's guilty
+plea to state charges was intended to be the consummation of a non-prosecution agreement that
+barred prosecution of federal offenses committed against them. They have further alleged that
+Epstein entered such a guilty plea on or about June 30, 2008. Please provide all documents,
+correspondence, and other information between the Government and state and local prosecutors
+and police agencies (including The Palm Beach Police Department and Palm Beach State
+Attorney's Office) regarding the Epstein investigation and ultimate Epstein plea.
+21. In their pending summary judgment motion, the victims have alleged that correspondence
+in the possession of the Government will support their claims. Please provide all documents,
+correspondence, and other information between Government attorneys/officials (including both
+federal and state prosecutors) and attorneys for Jeffrey Epstein (or non-attorney acting on
+Epstein's behalf) relating to (1) negotiations involving the possible prosecution (and ultimately
+the non-prosecution) by federal or state agencies for sex offenses, including sex offenses
+committed against Jane Doe #1 and Jane Doe H2, (2) Epstein's entry of state guilty pleas for
+related sex offenses; (3) a non-prosecution agreement entered into between Epstein and the
+Government that barred his prosecution for offenses committed against Jane Doe #1 and Jane
+Doe #2; (4) the fulfillment of Epstein's and/or the Government's obligations under the nonprosecution agreement and/or the state guilty pleas Epstein entered; (5) any work release or other
+conditional release of Epstein from confinement; (6) any designation of Epstein as a sex offender
+or restrictions on him contacting victims of his offenses (including Jane Doe #1 and Jane Doe
+#2); and (7) any termination of supervision or parole of Epstein. This information should include
+unredacted e-mails, letters, and correspondence of any type between government prosecutors
+working on the case includina but not limited to federal prosecutors Alexander Acosta, Jeffrey
+, and Bruce Reinhart
+and state prosecutors Dahua Weiss, Lana Belolovek, and others involved in the Epstein
+investigation) and defense attorneys representing Epstein (including, but not limited to, Roy
+Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy
+Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein
+(including, but not limited to former President Bill Clinton and Andrew Albert Christian Edward
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 35 of
+(a/k/a Prince Andrew, Duke of York). This should also include letters of recommendation or
+similar communications submitted to any Government official vouching for or providing support
+for Jeffrey Epstein.
+22. As you know, throughout their pending summary judgment motion, the victims have
+alleged that they were not properly notified of plea negotiations with Jeffrey Epstein and were
+denied their right to confer by the Government and that instead the Government gave Epstein
+generous concessions through the plea negotiations. Please provide any documents,
+correspondence and other information that reflects or discusses any consideration of any type
+that Epstein had previously provided or offered to provide to the Government (or any individual
+within the Government, in either his official or private capacity or any person previously
+employed by the Government and involved in the Epstein investigation or prosecution. The
+documents, correspondence, and other information should include any information discussing:
+(a) Any donation or offer to donate, directly or indirectly, either funds, services,
+or any other valuable consideration to any person or entity;
+(b) Any offer to assist, directly or indirectly, any person to obtain employment,
+business opportunities, business clients, real estate, office properties;
+(c) Any offer to assist the Government or law enforcement agencies in the
+investigation or prosecution of any federal or state criminal offense;
+(d) Any consideration that Epstein had provided to Government or law
+enforcement agencies in the past; and
+(e) Any other consideration of any type that Epstein offered to provide or had
+provided in the past that could provide a basis for the Government extending
+Epstein a more generous or lenient plea bargain or non-prosecution agreement
+than would be received by any other similarly situated child abuse suspect.
+23. The Crime Victims' Rights Act, 18 U.S.C. § 3771(c)(I), requires the Government to use
+its "best efforts" to protect the rights of crime victims.
+Please provide all documents,
+correspondence, and other information that will assist Jane Doe #1 and Jane Doe #2 in protecting
+their rights under the CVRA, including all documents, correspondence, and other information
+that the Government previously identified as being helpful to the victims but refused to provide
+based on its legal interpretation (now rejected by the Court) that the CVRA did not apply to this
+case because no indictment was filed.
+24. In the course of its investigation of Epstein and negotiations with Epstein, the
+Government (i.c., federal investigators and prosecutors) shared documents, correspondence, and
+information with other persons outside the federal government, including state and local
+prosecuting and law enforcement agencies, prosecuting and law enforcement agencies in other
+countries, Epstein's legal counsel, legal counsel for crime victims, and other entities. Please
+provide all documents, correspondence, and other information that the Government shared with
+any entity or person outside the federal government, including all correspondence (including e-
+mails) with those entities or persons.
+25. After the victims had made extensive efforts to try and reach a stipulated set of facts in
+this case, in March 2011 the Government refused to negotiate about such facts. Accordingly, at
+that time the victims filed various motions to obtain evidence in this case and, at the same time,
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 36 of
+the victims voluntarily made all initial disclosures on their part that are required by Federal Rule
+of Civil Procedure 26(a)(1). Please provide all initial disclosures required by the Federal Rules
+of Civil Procedure, including all disclosures required by Rule 26(a)(1).
+DEFINITIONS
+For the purpose of construing the foregoing discvery requests, the following terms are
+defined:
+The term "documents" means and includes, without limitation, all writings of any kind,
+including the originals and all non-identical copies or drafts, whether different from the original
+by reason of any notation made on such copy or draft or otherwise including, without limitation,
+correspondence, memoranda, notes, diaries, statistics, letters, e-mails, electronic computer files,
+telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries,
+pamphlets, books, prospectuses, interoffice communications, offers, notations of any sort of
+conversation, telephone calls, meetings or other communications, bulletins, printed matter,
+computer print-outs, teletypes, facsimiles, invoices, work sheets and all drafts, alterations,
+modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records
+or representations of any kind including, without limitation, photographs, charts, graphs,
+microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or
+electric records or representations of any kind including, without limitation, tapes, cassettes and
+dise recordings, and writings and printed material of every kind.
+means any tangible object that conveys intormation o
+nemorializes information that was conveyed in tangible or oral form including, but not limited
+to, writings, letters, memoranda, reports, notes, e-mails, telephone logs, telephone billing
+information, telephone recordings, and interoffice communications.
+The term "Epstein's victims" means any person that the Government identified as a
+possible victim of a sex offense committed by Jeffrey Epstein, including Jane Doe #1, Jane Doe
+#2, all victims identified in attachment to the non-prosecution agreement entered into by Epstein,
+and another person that the Government investigated as a possible victim of Epstein's sex
+offenses.
+The term "Government" means the federal government, including all employees of and
+components of the United States Department of Justice (such as, the Office of the Attorney
+General, the Office of the Deputy Attorney General, the Criminal Divisions, the Office of
+Professional Responsibility, the Child Exploitation and Obscenity Section, the U.S. Attorney's
+Offices for the Southern District and Middle District of Florida, and the Federal Bureau of
+Investigation) and other federal government agencies with law enforcement responsibilities
+related to the Epstein case (such as the Internal Revenue Service). This request for production
+seeks all documents, correspondence, and other information held by all of these entities,
+including all employees of and components of the Justice Department that worked on or were in
+any way involved the Epstein investigation and/or that possess information relevant to the
+victims' claims.
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 37 of
+The term "including" means containing within the request, but not limiting the request.
+The term "witness statement" means any document or other recording in any form
+(including oral form) reflecting, recording, or otherwise memorializing a statement made or
+information conveyed by a potential witness, including for example FBI 302's. The term
+includes information collected by any law enforcement, prosecuting or government agency
+including all federal, state, and local law enforcement agencies located in Washington, D.C., o
+NO GRAND JURY TRANSCRIPTS SOUGHT
+If any of the foregoing requests cover grand jury transcripts, do not provide the grand
+jury transcript. If any of the foregoing requests include documents that quote directly from a
+grand jury transcript, please redact that particular quotation.
+PRIVILEGE LOG
+document, general subject matter of the document, date of the document, and author and
+addressee of the document or correspondence.
+REDUCING UNDUE BURDEN
+If you believe that complying with any of the foregoing requests would be unduly
+burdensome, please contact victims counsel - Bradley J. Edwards - to discuss ways to reduce
+any such burden.
+DATED: October 3, 2011
+Respectfully Submitted,
+s/ Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Elorida 33301
+Telephone
+Facsimile
+Florida Bar No.: 542075
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 38 of
+and
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utal
+332 S. 1400 E
+Salt Lake City. UT 84112
+Telephone:
+Facsimile:
+E-Mail:
+E-Mail Transmission:
+The foregoing document was served on October 3, 2011, on the following via US Mail and
+Assistant U.S. Attorneys
+300 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Fax:
+Attorneys for the Government
+Roy Black, Esq.
+Jackie Perczek, Esq.
+Black, Srebnick, Kornspan & Stumpf, P.A.
+201 South Biscayne Boulevard
+Suite 1300
+Miami. EL, 33131
+Attorneys for Proposed Intervenors Roy Black et al.
+Respectfully Submitted,
+S/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+
+
+Document 225-1 Entered on FLSD Docket 08/16/2013 Page 39 of
+
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 40 of
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs
+UNITED STATES,
+Defendants
+JANE DOE #1 AND JANE DOE #2'S SUPPLEMENTAL REQUEST
+FOR PRODUCTION TO THE GOVERNMENT REGARDING NEW INFORMATION
+CONCERNING INVESTIGATION OF HANDLING OF EPSTEIN NON-
+PROSECUTION AGREEMENT
+COME NOW Jane Doe #1 and Jane Doe #2 ("the victims), by and through undersigned
+counsel, and request the defendant United States (hereinafter "the Government") to produce the
+original or best copy of the items listed herein below for inspection and/or copying, pursuant to
+the Court's Order (DE 99) directing discovery in this case, the Court's Order denying the
+Government's motion to dismiss and lifting stay of discovery (DE 189), and the Court's
+Omnibus Order (DE 190):
+BACKGROUND
+As the Government will recall, the victims have repeatedly asked the Government to
+stipulate to undisputed facts in this case. The Government has declined. Accordingly, the
+victims filed their Motion for Finding of Violations of the Crime Victims' Rights Act and
+Request for a Hearing on Appropriate Remedies (DE 48) (the victims' "summary judgment
+motion") along with a Motion to Have Their Facts Accepted Because of the Government's
+Failure to Contest Any of the Facts (DE 49).
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 41 of
+On September 26, 2011, the Court denied the victims' motion to have their facts accepted
+(DE 99 at 11).
+At the same time, however, the Court has ordered discovery to develop the
+factual record concerning the summary judgment motion (DE 99 at 11). The Court reserved
+ruling
+on the victims' motion for an order directing the Government not to suppress relevant
+evidence (DE 99 at 11).
+On September 28, 2011, the victims requested that the Government voluntarily provide
+documents concerning this case. The Government declined to provide even a single document.
+On October 3, 2011, the victims sent requests for production of documents relevant to
+this case.
+On November 8, 2011, the same day that the production of this discovery was due, rather
+than produce a single item of discovery or stipulate to a single fact, the Government filed a
+motion to dismiss the victims' case. The Government also filed an accompanying motion for a
+stay in this case.
+On November 8, 2011, the Government filed an ex parte, sealed motion to stay further
+discovery in this case. (DE 121). On November 9, 2011, the Court granted an ex parte, sealed
+order to stay. (DE 123).
+On December 5, 2011, the victims filed a response to Government's motion to stay. The
+victims strenuously objected to the Government's approach, alleging specifically that "delay
+appears to be the Government's motivation for filing the motion to dismiss." DE 129 at 2. The
+victims went on to recount the fact that the Government had waited three years to file a motion to
+dismiss, concluding that "as a practical matter, the Government's motion has had the desired
+effect of delay: While its motion remains pending, the victims have been effectively denied any
+ability to obtain discovery from the Government." DE 129 at 2-3. The victims also filed a
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 42 of
+protection motion to compel (DE 130) asking that the Court direct the Government to produce
+the requested materials.
+On January 24, 2012, the Government filed a reply in support of its motion to stay. DE
+140. In that reply, the Government represented that it would voluntarily be providing
+information to the victims: "[T]he United States has agreed to provide some information to [the
+victims] even during the pendency of the stay and is undertaking a search for that
+information." DE 140 at 4. Contrary to that representation, however, over the next seventeen
+months, the Government did not provide any information to the victims.
+A year after the Government's motion to dismiss, on December 6, 2012, the victims filed
+a Motion for a Prompt Ruling Denying the Government's Motion for a Stay (DE 179). The
+motion explained that it had been more than a year since the Government had filed its motion for
+a stay and that the Government's refusal to produce any information continues to effective block
+the victims from learning what happened during the Government's plea negotiations with the
+man who sexually abused them. The Government filed a response in opposition to that motion
+(DE 182).
+On February 25, 2013, counsel for the victims sent a request to the Government that, in
+view of that fact that its requested stay had never been granted, it should begin fulfilling its
+court-ordered discovery obligations:
+The victims believe that in view of fact that it has been more than fifteen
+months since the Government filed its motion for a stay of discovery and yet the
+Court has not granted that motion, the Court's discovery order is in effect and
+controlling. Accordingly, the victims respectfully request that by March 8, 2013,
+the Government produce all of the materials which is covered by the victims'
+discovery requests. If the Government has not produced those materials by
+March 8, 2013, the victims may be forced to seck the intervention of the Court to
+order the Government to follow its obligations.
+If you would like to discuss this further, please feel free to set up a time
+where we can talk to you over the phone about all this. We are happy to work
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 43 of
+with you to try and minimize any unnecessary burden from your discovery
+obligations.
+E-mail from Paul G. Cassell & Bradley J. Edwards to
+et al., Counsel for the
+Government (February 25, 2013).
+The Government ignored the e-mail and did not respond in any way.
+Accordingly, in view of the Government recalcitrance and refusal to even discuss its
+discovery obligations, on March 14, 2013, the victims filed a motion to compel production of
+discovery materials. The Government did not respond to this motion.
+On June 1, 2013, the Court denied the Government's motion to dismiss. DE 189. That
+denial also lifted stay of discovery proceedings. DE 189 at 14 ("The stay of discovery pending
+ruling on the Government's motion to dismiss entered on November 8, 2011 [DE# 123] is also
+lifted."). The Court also entered an Omnibus Order (DE 190) that, among other things, granted
+the victim motion to compel (DE 130).
+SUPPLEMENTAL DISCOVERY REQUEST
+The victims now request one specific item of supplemental discovery relating to information
+that, in large measure, has come into existence since they filed the first request for production of
+documents on October 3, 2011:
+Jane Doe #1 and Jane Doe #2 have asked the Government to investigate their allegations that
+the U.S. Attorney's Office for the Southern District of Florida entered into a non-prosecution
+agreement with Jeffrey Epstein for sexual offenses committed against them and other victims
+based on considerations apart from the merits of the criminal case and also that violations of
+up to and surrounding the entry of the non-prosecution agreement. Please provide any
+information that the Government has developed concerning or relating to those allegations
+and the handling of the negotiations and consummation of the non-prosecution agreement,
+including any information developed by the Justice Department's Office of Professional
+Responsibility (OPR), the Federal Bureau of Investigation or other federal investigative
+entity, and any grand jury investigating these (or releated) allegations, including any grand
+jury meeting in the Southern District of Florida, the Middle District of Florida, the District of
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 44 of
+New Jersey, and/or the District of Columbia. For this one discovery request only, please
+include all relevant grand jury transcripts and evidence collected by the grand jury.
+DEFINITIONS
+For the purpose of construing the foregoing discovery requests, the following terms are
+defined:
+The term "documents" means and includes, without limitation, all writings of any kind,
+including the originals and all non-identical copies or drafts, whether different from the original
+by reason of any notation made on such copy or draft or otherwise including, without limitation,
+correspondence, memoranda, notes, diaries, statistics, letters, e-mails, electronic computer files,
+elegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries
+amphlets, books, prospectuses, interoffice communications, offers, notations of any sort o
+conversation, telephone calls, meetings or other communications, bulletins, printed matter,
+computer print-outs, teletypes, facsimiles, invoices, work sheets and all drafts, alterations,
+modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records
+or representations of any kind including, without limitation, photographs, charts, graphs,
+disc recordings, and writings and printed material of every kind.
+The term "correspondence" means any tangible object that conveys information or
+memorializes information that was conveyed in tangible or oral form including, but not limited
+to, writings, letters, memoranda, reports, notes, e-mails, telephone logs, telephone billing
+information, telephone recordings, and interoffice communications.
+The term "Epstein's victims" means any person that the Government identified as a
+possible victim of a sex offense committed by Jeffrey Epstein, including Jane Doe #1, Jane Doe
+#2, all victims identified in attachment to the non-prosecution agreement entered into by Epstein,
+and another person that the Government investigated as a possible victim of Epstein's sex
+The term "Government" means the federal government, including all employees of and
+The term "including" means containing within the request, but not limiting the request.
+
+
+Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 45 of
+The term "witness statement" means any document or other recording in any form
+(including oral form) reflecting, recording, or otherwise memorializing a statement made or
+information conveyed by a potential witness, including for example FBI 302's. The term
+includes information collected by any law enforcement, prosecuting or government agency,
+including all federal, state, and local law enforcement agencies located in Washington, D.C., or
+Florida.
+PRIVILEGE LOG
+If you believe that any document, correspondence, or other information requested in this
+request is subject to a privilege and if you intend to assert that privilege, please provide a
+"privilege log" consistent with Local Rule 26.1(g), including a description a document that is
+consistent with Local Rule 26.1(g)(3)(B). Your privilege log should include the type o
+Iorse the a subit matter ponte document, date of the document, and author an
+REDUCING UNDUE BURDEN
+ny such burder
+DATED: June 24, 2013
+Respectfully Submitted,
+s/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Elorida 33301
+Telephonel
+Floria Sa No 532075
+and
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 46 of
+Salt Lake City, UT 84110
+Telephones
+Facsimile:
+E-Mail:
+
+
+Document 225-1 Entered on FLSD Docket 08/16/2013 Page 47 of
+
+
+
+Case 9:03-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 48 of
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs
+UNITED STATES,
+Defendants
+JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR ADMISSIONS
+TO THE GOVERNMENT REGARDING QUESTIONS RELEVANT TO THEIR
+PENDING ACTION CONCERNING THE CRIME VICTIMS RIGHTS ACT
+COME NOW Jane Doe #1 and Jane Doe #2 ("the victims"), by and through undersigned
+counsel, and request the defendant United States (hereinafter "the Government") to admit or
+deny the following facts:
+BACKGROUND
+As the Government will recall, the victims have asked the Government to stipulate to
+undisputed facts in this case. The Government has declined. Accordingly, the victims filed their
+Motion for Finding of Violations of the Crime Victims' Rights Act and Request for a Hearing on
+Appropriate Remedies (DE 48) (the victims' "summary judgment motion") along with a Motion
+to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts
+(DE 49).
+On September 26, 2011, the Court denied the victims' motion to have their facts accepted
+(DE 99 at 11). At the same time, however, the Court has ordered discovery to develop the
+factual record concerning the summary judgment motion (DE 99 at 11). The Court reserved
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 49 of
+ruling on the victims' motion for an order directing the Government not to suppress relevant
+evidence (DE 99 at 11). The Court allowed the victims to propound requests for admission to
+the Government.
+DISCOVERY REQUESTED
+The numbered requests for admissions below should all be construed in light of the
+definitions of terms provided at the end of the requests. Where the request for admission has
+separate, lettered sub-parts, please admit or deny each separate sub-part:
+1. The FBI and the U.S. Attorney's Office for the Southern District of Florida's
+investigation into Jeffrey Epstein developed a case for a federal prosecution against
+Epstein for many federal sex offenses.
+1. The government admits that the FBI and the U.S. Attorney's Office for
+the Southern District of Florida ("USAO") conducted an investigation
+into Jeffrey Epstein ("Epstein") and developed evidence and
+information in contemplation of a potential federal prosecution against
+Epstein for many federal sex offenses. Except as otherwise admitted
+above, the government denies Request No. 1.
+* The government's response is confined to Request No. 1 through Request No.
+26 in the "Discovery Requested" section of the Request for Admissions and does not
+intend to respond to assertions in any other section of the Request for Admissions
+(including the "Background" section), none of which appear to separately state any
+matter calling for an admission. Nonetheless, the government denies the assertion that
+the government has declined the request of Jane Doe #1 and Jane Doe #2 to stipulate to
+undisputed facts in this case.
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 50 of
+2. Regarding notifications provided to victims of Jeffrey Epstein's sexual abuse:
+(a)
+The U.S. Attorney's Office negotiated with Jeffrey Epstein's defense attorneys
+concerning the notifications to be provided to victims of Epstein's abuse;
+2. (a) The government admits that, after Epstein's attorneys learned of
+(b)
+It is not standard practice for the U.S. Attorney's Office to negotiate with defense
+attorneys about the extent of notifications provided to crime victims;
+(b) Admitted.
+(c) As a result of those negotiations or requests received from Epstein, the U.S.
+Attorney's Office stopped making notifications to some crime victims;
+victims. With regard to Jane Doe H2, the government further admits that, as a
+government denies Request No. 2(c).
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 51 of
+(d)
+The language used in the notifications to Jane Doe #1 and Jane Doe #2 were
+affected by the negotiations with Epstein's defense lawyers;
+(d) The government admits that, after the USAO received objections to victim
+notifications from Epstein's counsel and reevaluated its victim notification
+obligations, the USAO altered the language that was ultimately contained in
+the July 9, 2008 notification letter to Jane Doe #1 in care of Bradley Edwards.
+Except as otherwise admitted above, the government denies Request No. 2(d).
+At least in part as a result of the negotiations, Jane Doe #1 and Jane Doe #2 were
+not told that the U.S. Attorney's Office had entered into a non-prosecution
+agreement with Epstein until after the agreement was executed.
+(e) The government admits that, at least in part as a result of objections lodged
+by Epstein's lawyers to victim notifications, the USAO reevaluated its
+obligations to provide notifications to vietims, and Jane Doe #1 was thus not
+told that the USAO had entered into a non-prosecution agreement with Epstein
+until after the agreement was signed. The government further admits that Jane
+Doe #2 was not told that the USAO had entered into a non-prosecution
+agreement with Epstein until after the agreement was signed, but denies that
+the USAO did not inform Jane Doe #2 as a result of any negotiations involving
+Epstein or any objections lodged by Epstein's lawyers; the USAO did not
+consider Jane Doe #2 a victim after she informed the USAO and the FBI that
+she was not a victim of any offense committed by Epstein, and, as a result, the
+USAO did not consider informing Jane Doe #2 about the non-prosecution
+agreement. Except as otherwise admitted above, the government denies
+Request No. 2(e).
+that non-prosecution agreement barring prosecution of certain sex offenses.
+3. Denied.
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 52 of
+4. During its negotiations with Jeffrey Epstein's defense attorneys, the U.S. Attorney's
+Office was aware that publicly disclosing the non-prosecution agreement with Jeffrey
+Epstein would likely have led to public criticism of the agreement.
+4. Denied.
+5. During negotiations with Jeffrey Epstein regarding the non-prosecution agreement, it was
+the position of at least one experienced attorney within the U.S. Attorney's Office that the
+Crime Victims' Rights Act required notifications to the victims in this case.
+5. The government admits that, during the negotiations with Jeffrey Epstein
+regarding the non-prosecution agreement, at least one experienced attorney within
+the USAO subscribed to the position that the CVRA required notifications to the
+victims in this case and that position was communicated to Epstein's counsel. To the
+extent that Request No. 5 seeks admissions regarding the positions held by attorneys
+within the USAO that were not communicated to non-government personnel
+regarding whether or not the CVRA ultimately required notifications to the victims
+in this case, the government objects to Request No. 5 as violative of the deliberative
+process privilege.
+6. The Justice Department possesses documents, correspondence or other information
+reflecting contacts with the Department between May 2007 and September 2008 on
+behalf of Jeffrey Epstein by:
+(a) President Bill Clinton; Denied.
+(b) Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York); Denied.
+(c) Harvard Law Professor Alan Dershowitz; Admitted
+(d) Ken Starr; Admitted.
+(e) Lillian Sanchez;
+Admitted to the extent that the reference to "Lillian Sanchez" was
+meant to refer to Lilly Ann Sanchez.
+(f) Jay Lefkowitz; Admitted and
+(g) Roy Black. Admitted
+
+
+Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 53 of
+7. On about January 10, 2008, when Jane Doe #1 and Jane Doe #2 were sent letters advising
+them that "this case is currently under investigation," the U.S. Attorney's Office had
+already entered into a non-prosecution agreement with Jeffrey Epstein.
+The government admits that, on about January 10, 2008, when Jane
+Doe #1 and Jane Doe #2 were sent letters advising them that "this case
+is currently under investigation," the U.S. Attorney's Office had
+already signed a non-prosecution agreement with Jeffrey Epstein, but
+that, on that date, the non-prosecution agreement nonetheless
+remained in a state of some flux and was subject to being set aside as
+Epstein was challenging the propriety of the non-prosecution
+agreement and seeking further review from the Department of
+8. In September 2007 when the U.S. Attorney's entered into the non-prosecution agreement
+with Epstein, it did not inform FBI agents of the details of the disposition of the case in
+the way that it ordinarily informed them of dispositions of other cases.
+UNITED STATES RESPONSE: Denied
+9. With regard to the non-prosecution agreement between Epstein and the Government:
+(a)
+Epstein insisted on, and the U.S. Attorney's Office agreed to, a provision in the
+non-prosecution agreement that made the agreement secret;
+any public record. If the United States receives a Freedom of Information Act
+equest or any compulsory process commanding the disclosure of th
+seem so ievil a mide above the goverament denic Reque o ta)
+(b)
+In particular, the agreement stated: "The parties anticipate that this agreement will
+not be made part of any public record;"
+UNITED STATES RESPONSE: Admitted
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 54 of
+(d)
+(e)
+By entering into such a confidentiality agreement, the U.S. Attorney's Office put
+itself in a position that conferring with the crime victims (including Jane Doe #1
+and Jane Doe #2) about the non-prosecution agreement would violate certain
+UNITED STATES RESPONSE: Denied
+Even notifying the victims about the agreement would have violated the
+confidentiality provision; and
+UNITED STATES RESPONSE: Denied
+From September 24, 2007 through June 2008, the U.S Attorney's Office did not
+notify Jane Doe #1 and Jane Doe #2 of the existence of the non-prosecution
+agreement.
+(e) The government admits that, during the period from September 24, 2007
+through June 2008, the USAO did not notify Jane Doe #2 of the existence of
+non-prosecution agreement during the period from September 24, 2007
+denies Request No. 9(e).
+10. With regard to contact between the Government and the victims:
+(a) On about October 26, 2007, FBI agents met with Jane Doe #1;
+10. (a) Admitted. Because Request No. 10 appears directed solely to the communica
+tions between FBI agents and Jane Doe #1 during their meeting on or about Octobe
+26, 2007, the government responses to Requests No. 10(b) through 10(g) address
+only that meeting.
+The agents explained that Epstein would plead guilty to state charges involving
+nother victim, he would be required to register as a sex offender, and he ha
+nade certain concessions related to the payment of damages to the victim
+including Jane Doe #1;
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 55 of
+(b) The government admits that, on or about October 26, 2007, FBI agents
+explained to Jane Doe #1 that Epstein would plead guilty to state charges for
+procuring minors to engage in prostitution; that Epstein would be required to
+register as a sex offender; that Jane Doe #1 would be entitled to seek damages
+from Epstein; and that, if she desired, Jane Doe #1 would be entitled to use the
+services of an attorney at no expense to her in seeking those damages from
+Epstein. The government denies that the FBI agents explained that the state
+charges "involv|ed] another victim."
+(c)
+During this meeting, the agents did not explain that an agreement had already
+been signed that precluded any prosecution of Epstein for federal crimes
+committed against Jane Doe #1;
+(c) The government denies that the FBI agents did not explain to Jane Doe #1 that
+an agreement had already been signed; denies that the FBI agents did not explain to
+Jane Doe #l that the agreement resolved the investigation of the federal case
+involving Jane Doe #1; and denies that the FBI agents did not explain to Jane Doe
+#1 other terms of that agreement Except as otherwise admitted above, the
+government denies Request No. 10(c).
+(d)
+The agents could not have revealed this part of the non-prosecution agreement
+without violating the terms of the non-prosecution agreement;
+UNITED STATES RESPONSE: Denied
+(e)
+The agents themselves had not been informed of the existence of the provision in
+the non-prosecution agreement barring Epstein's prosecution for various federal
+crimes or sex offenses at that time;
+UNITED STATES RESPONSE: Denied
+(f)
+(g)
+UNITED STATES RESPONSE: Denied
+The agents never explained that the non-prosecution agreement would ultimately
+bring to an end the federal investigation in the case.
+UNITED STATES RESPONSE: Denied
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 56 of
+64
+11. On about November 29, 2007, the U.S. Attorney's Office sent a draft of a crime victim
+notification letter to Jay Lefkowitz, defense counsel for Jeffrey Epstein. The notification
+etter would have explained: "I am writing to inform you that the federal investigation of
+effrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office hav
+reached an agreement containing the following terms ...." Because of concerns from
+Epstein's attorneys, the U.S. Attorney's Office never sent the proposed victim
+notification letter to the victims.
+11. The government admits that, on or about November 28, 2007,
+Letkowitz, counsel for Jeffrey Epstein, and that the draft notification letter
+stated, in part: "I am writing to inform you that the federal investigation of
+Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney's
+Office have reached an agreement containing the following terms ...." The
+government further admits that, in part as a result of objections lodged by
+Epstein's lawyers, the USAO reevaluated its obligations to provide notifications
+to victims, and, as a result of that reevaluation and other considerations and
+developments, the USAO never sent victims the draft notification letter that was
+sent to Jay Lefkowitz on or about November 28, 2007. Except as otherwise
+admitted above, the government denies Request No. 11.
+12. On July 3, 2008, when Bradley J. Edwards was working on a letter to the U.S. Attorney's
+Office concerning the need to federally prosecute Epstein for sex offenses committed
+against Jane Doe #1 and Jane Doe #2, the U.S. Attorney's Office had already entered into
+a binding non-prosecution agreement with Jeffrey Epstein.
+12. The government admits that, prior to July 3, 2008, the USAO had already
+entered a binding non-prosecution agreement with Jeffrey Epstein. The
+government is without knowledge of precisely when "Bradley J. Edwards was
+government denies Request No. 12.
+13. When Jeffrey Epstein pled guilty to state charges on June 30, 2008,
+(a)
+Jane Doe #1 and Jane Doe #2 had not been informed by the U.S. Attorney's
+Vitice of the existence of the non-prosecution agreement.
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 57 of
+13. (a) The government admits that, when Epstein pled guilty to state charges on
+June 30, 2008, Jane Doe #2 had not been informed by the USAO of the
+existence of the non-prosecution agreement. The government further admits
+that time of the existence of the non-prosecution agreement. Except as
+otherwise admitted above, the government denies Request No. 13(a).
+(b)
+The U.S. Attorney's Office had not conferred with either Jane Doe #1 or Jane Doe
+#2 about the non-prosecution agreement;
+(b) The government denies that, by the time of Epstein's June 30, 2008 guilty plea,
+an attorney for the government working at the USAO had not already
+conferred with Jane Doe #1 and Jane Doe #2 about their opinions regarding
+how the federal investigation and potential prosecution of Epstein should
+proceed. The government admits that the USAO had not conferred with Jane
+Doe #2 about the non-prosecution agreement prior to Epstein's June 30, 2008
+guilty plea. The government further admits that, although the USAO had
+communicated with Jane Doe #1 about the non-prosecution agreement through
+FBI agents prior to Epstein's June 30, 2008 guilty plea, no employee of the
+USAO had personally conferred with Jane Doe #1 about the non-prosecution
+agreement prior to Epstein's guilty plea. Except as otherwise admitted above,
+the government denies Request No. 13(b).
+(c) Epstein's defense attorneys were aware that the U.S. Attorney's Office had not
+conferred with Jane Doe #1 and Jane Doe #2 about the agreement; and
+(c) Although the government was aware that Jane Doe #2 had been represented
+by counsel paid for by Epstein, the government is unaware of the extent of
+Epstein's defense attorneys' awareness of the USAO's communications with
+Jane Doe #1 and Jane Doe #2 about the agreement, as described in the responses
+to Requests No. 13(a) and 13(b), and therefore can neither deny nor admit
+Request No. 13(c). Except as otherwise admitted above and in the responses to
+Requests No. 13(a) and 13(b), the government denies Request No. 13(c).
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 58 of
+64
+Epstein's defense attorneys had negotiated for a confidentiality provision in the
+non-prosecution agreement that barred conferring with victims about the
+agreement.
+(d) The government admits that Epstein's attorneys negotiated with the USAO
+for a provision in the non-prosecution agreement that ultimately provided as
+follows: "The parties anticipate that this agreement will not be made part of any
+public record. If the United States receives a Freedom of Information Act
+equest or any compulsory process commanding the disclosure of the agreement
+t will provide notice to Epstein before making that disclosure." Except a
+otherwise admitted above, the government denies Request No. 13(d).
+4. When Epstein was pleading guilty to the state charges discussed in the non-prosecutio
+greement, both the U.S. Attorney's Office and Epstein's defense attorneys were workin
+to keep the existence of the non-prosecution agreement confidential.
+14. The government admits that, when Epstein was pleading guilty to the state
+charges discussed in the non-prosecution agreement, the USAO and Epstein's
+defense attorneys sought to keep the document memorializing the nonprosecution agreement confidential, but denies that they sought at that time to
+keep the existence of the non-prosecution agreement confidential. Except as
+otherwise admitted above, the government denies Request No. 14.
+15. Defense attorney Bruce E. Reinhart:
+(a) learned confidential, non-public information about the Epstein matter;
+(b)
+discussed the Epstein matter with an attorney working on the case for the U.S.
+Attorney's Office; and
+(b) The government admits that, while Bruce E. Reinhart was an Assistant
+U.S. Attorney, he discussed the Epstein matter with another Assistant U.S.
+Attorney working on the Epstein matter.
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 59 of
+(c)
+was involved in decision-making with regard to the Epstein matter.
+UNITED STATES RESPONSE: Denied
+16. The Government possesses information (including telephone logs and emails) reflecting
+contacts between Bruce E. Reinhart and persons/entities affiliated with Jeffrey Epstein
+(including Jeffrey Epstein, the Florida Science Foundation, Jack Goldberger, Harvard
+Law Professor Alan Dershowitz, Roy Black, Ken Starr, Lily Ann Sanchez) before
+Reinhart left the employment of the U.S. Attorney's Office.
+UNITED STATES RESPONSE: Admitted.
+7. The Government possesses information (including telephone logs or emails) reflectin
+ontacts between Bruce E. Reinhart and persons working at or for the Department o
+Justice or United States Attorney's Office that related to Jeffrey Epstein or the
+investigation into Jeffrey Epstein and other potential co-conspirators of Jeffrey Epstein.
+UNITED STATES RESPONSE: Admitted.
+18. The government possesses, or has knowledge or information (including telephone logs or
+photographs or emails) reflecting improper communication or influence made or
+attempted with the Government, on Jeffrey Epstein's behalf by:
+(a)
+Guy Lewis
+UNITED STATES RESPONSE: Denied.
+(b) LilyAnn Sanchez
+UNITED STATES RESPONSE: Denied.
+19. The government possesses, or has knowledge or information (including telephone logs,
+photographs, emails or statements) of other credible sources) about a personal or
+business relationship between Jeffrey Epstein and U.S. Attorneys and/or Assistant US
+Attorneys.
+19. To the extent that Request No. 19 is directed to the business or personal
+relationships of the 93 U.S. Attorneys and over 5,400 Assistant U.S. Attorneys
+serving across this country, or the countless individuals who have formerly
+served as U.S. Attorneys and Assistant U.S. Attorneys throughout this nation,
+the government objects to Request No. 19 as overly broad and burdensome and
+not calculated to lead to or involve information relevant to the instant matter.
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 60 of
+64
+The government denies possessing or having any knowledge or information
+about a personal or business relationship between Jeffrey Epstein and either the
+U.S. Attorney or any Assistant U.S. Attorney serving in the Southern District of
+Florida. Except as otherwise admitted above, the government denies Request No.
+20. The government possesses, or has knowledge or information (including telephone logs,
+photographs, emails or statement(s) of other credible sources) about a personal of
+business relationship between Jeffrey Epstein and
+UNITED STATES RESPONSE: Admitted.
+21. The government possesses, or has knowledge or information (including telephone logs,
+photographs, emails or statements) of other credible sources) about a personal or
+business relationship between Jeffrey Epstein and Alex Acosta.
+UNITED STATES RESPONSE: Denied
+22. The Justice Department's Office of Professional Responsibility and/or other Government
+entities have collected information about:
+(a)
+Bruce Reinhart's possible involvement in the Epstein matter;
+UNITED STATES RESPONSE: Admitted
+(b)
+Other government attorney's possible improper behavior in the Epstein matter;
+and
+UNITED STATES RESPONSE: Admitted
+(c) A conflict of interest regarding the U.S. Attorney's Office for the Southern
+District of Florida handling issues relating to the Epstein matter.
+UNITED STATES RESPONSE: Admitted
+
+
+Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 61 of
+64
+23. The non-prosecution agreement signed by the U.S. Attorney's Office and Jeffrey Epstein
+currently blocks the U.S. Attorney's Office from prosecuting sex offenses committed by
+Epstein against Jane Doe #1 and Jane Doe #2 in the Southern District of Florida.
+23. The government admits that the non-prosecution agreement signed by the
+USAO and Jeffrey Epstein currently blocks the USAO from prosecuting sex
+offenses committed by Epstein against Jane Doe #1 and Jane Doe #2 in the
+Southern District of Florida from in or around 2001 through in or around
+September 2007, provided that those offenses are set out on pages 1 and 2 of the
+non-prosecution agreement, were the subject of the joint investigation by the
+FBI and the USAO, or arose from the federal grand jury investigation. Except as
+otherwise admitted above, the government denies Request No. 23.
+24. The Justice Department possesses information that Epstein, himself or through his
+attorney's or acquaintances, has provided or offered to provide to the federal government
+(or an individual within the Government, in his official or private capacity) valuable
+consideration.
+24. Admitted; Jeffrey Epstein provided valuable consideration to the federal
+government through the non-prosecution agreement he entered with the USAO.
+25. The Justice Department's Office of Professional Responsibility's investigation/inquiry
+into alleged misconduct relating to the negotiation and consummation of the Epstein nonprosecution agreement has relevance to issues pending in this case.
+UNITED STATES RESPONSE: Denied
+26. The government objects to Request No. 26 because it seeks information
+protected from disclosure by the law enforcement investigative privilege.
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 62 of
+DEFINITIONS
+For the purpose of construing the foregoing discovery requests, the following terms are
+or representations of any kind including, without limitation, photographs, charts, graphs,
+microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or
+electric records or representations of any kind including, without limitation, tapes, cassettes and
+dise recordings, and writings and printed material of every kind.
+The term "correspondence" means any tangible object that conveys information or
+memorializes information that was conveyed in tangible or oral form including, but not limited
+to, writings, letters, memoranda, reports, notes, e-mails, telephone logs, telephone billing
+information, telephone recordings, and interoffice communications.
+The term "Epstein's victims" means any person that the Government identified as a
+possible victim of a sex offense committed by Jeffrey Epstein, including Jane Doe #1, Jane Doe
+#2, all victims identified in attachment to the non-prosecution agreement entered into by Epstein,
+and another person that the Government investigated as a possible victim of Epstein's sex
+The term "Government" means the federal government, including all employees of and
+components of the United States Department of Justice (such as, the Office of the Attorney
+General, the Office of the Deputy Attorney General, the Criminal Divisions, the Office of
+Professional Responsibility, the Child Exploitation and Obscenity Section, the U.S. Attorney's
+Offices for the Southern District and Middle District of Florida, and the Federal Bureau of
+victims' claims.
+The term "including" means containing within the request, but not limiting the request.
+
+
+Case 9:08-CV-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 63 of
+The term "U.S. Attorney's Office" means the U.S. Attorney's Office for the Southern
+District of Florida and includes all branch offices within the Southern District of Florida.
+PRIVILEGE LOG
+If you believe that any request for admission is subject to a privilege and if you intend to
+for the privilege.
+DATED: December 1,2011
+Respectfully Submitted,
+s/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Elorida 33301
+Telephone
+Facsimile
+Florida Bar No.: 542075
+and
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City. UT 8411
+Telephone:
+Facsimile:
+E-Mail: cassellp@law.utah.edu
+The foregoing document was served on December 1, 2011, on the following persons via US Mail
+and electronic mail to:
+Dexter A
+
+
+Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 64 of
+Assistant U.S. Attorneys
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Fax:
+Attorneys for the Government
+
+
+Case 9:08-CV-80736-KAM Document 225 Entered on FLSD Docket 08/16/2013 Page 1 of 10
+JNITED STATES DISTRICT COUR
+OUTHERN DISTRICT OF FLORID/
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOE #1 and JANE DOE #2
+V.
+UNITED STATES
+JANE DOE #1 AND JANE DOE #2'S MOTION TO COMPEL PRODUCTION OF
+DOCUMENTS THAT ARE NOT PRIVILEGED
+
+
+Case 9:08-CV-80736-KAM Document 225 Entered on FLSD Docket 08/16/2013 Page 2 of 10
+COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and
+through undersigned counsel, to move this Court to turn over to them numerous documents that
+to which the Government has asserted various privileges. All of the Government's assertions of
+privilege are not well founded, for the reasons described in this pleading, and the Court should
+provide all of the documents to the victims.' The factual support for the arguments found in this
+memorandum is contained, inter alia, in the attached affidavit of Bradley J. Edwards, Esq. The
+victims have also concurrently filed itemized objections to the Government's privilege log.
+1. General Responses to All Assertions of Privilege.
+Inadequate Privilege Log - The great bulk of the Government's privilege assertions do
+not comply with the Court's requirement that the privilege log must "clearly identifyl] each
+document[] by author(s), addressee(s), recipients), date, and general subject matter ..." DE
+190 at 2. As a result of the Government's failures, it is impossible to even begin to determine
+which of the Government's assertions of privilege are valid.
+Failure to Prove Factual Underpinnings of Privilege Claim - Most of the
+Government's privilege assertions rest on factual underpinnings (e.g., an attorney-client
+relationship is at issue, a deliberative process is at issue) that have not been proven by any
+materials in the record. Accordingly, these assertions of privilege are inadequate. See Bogle v.
+McClure, 332 F.3d 347, 1358 (11th Cir: 2003); Brown v. City of Margate, 842 F.Supp. 515, 520
+' Should the Court allow the Government to assert privilege with regard to any of the
+mation of privilege to but hold pre ud a ge thems a fom de in the die be a
+ssertion of privile
+victims that would have been supported by the withheld information. See, e.g., Attorney General
+of the U.S. v. Irish People, Inc., 684 F.2d 928, 951 (D.C. Cir. 1982).
+1
+
+
+Case 9:08-CV-80736-KAM Document 225 Entered on FLSD Docket 08/16/2013 Page 3 of 10
+(S.D. Fla. 1993) (government failed to prove attorney-client relationship), aff'd, 56 F.3d 1390
+(11th Cir. 1995).
+Waiver of Confidentiality - Some of the Government's assertions of privilege fail
+because it is clear that any confidentiality was waived by the presence of persons outside the
+confidential relationship.
+For example, some of the assertions of attorney-client privilege
+involve documents and correspondence sent to person outside of any attorney-client relationship.
+Government's Fiduciary Duty to Crime Vietims Bars Privilege - The Government
+cannot invoke privilege in the context of a Crime Victims' Rights Act petition because it owes a
+fiduciary duty to the crime victims to use "best efforts," 18 U.S.C. § 3771(c)(1), to protect their
+rights. See Solis v. Food Employers Labor Relations Ass'n, 644 F.3d 221, 226-27 (4th Cir. 2011)
+(noting that the attorney-client privilege does not apply "in the context of fiduciary relationships"
+and that "[t]his principle has been applied to fiduciary relationships beyond the traditional trust
+context"); see also In re Grand Jury Subpoena Duces Tecum, 112 F.3d 910, 919-21 (8th Cir.
+1997) (government attorneys have duty to report wrongdoing).
+Communications Facilitating Crime-Fraud-Misconduct Not Covered - Any privilege
+would be subject to a crime-fraud-misconduct exception. See In re Sealed Case, 754 F.2d 395,
+399 (D.C. Cir. 1985) (applying exception to attorney-client privilege); Cox v. Administrator U.S.
+Steel & Carnie, 17 F.3d 1386, 1422 (11th Cir. 1994) (applying exception to work product claim).
+Such an exception applies to the facts of this case.
+Factual Materials Not Covered - Any privilege would only cover materials reflecting
+the confidential relationship, not factual materials. See, e.g., EPA v. Mink, 410 U.S. 73, 87-88
+(1973) ("memoranda consisting only of compiled factual material ... and severable from its
+2
+
+
+Case 9:08-CV-80736-KAM Document 225 Entered on FLSD Docket 08/16/2013 Page 4 of 10
+context would generally be available for discovery by private parties in litigation with the
+Government."). Many of the materials at issue are factual materials.
+Documents Not Prepared in Anticipation of CVRA Litigation - The work product
+doctrine (as well as the investigative privilege) only applies to documents prepared by an
+attorney in anticipation of litigation, not to documents prepared in the ordinary course of
+business, pursuant to regulatory requirement, or for other non-litigation purposes. Solis v. Food
+Employers Labor Relations Ass'n, 644 F.3d 221, 231 (4th Cir. 2011). Many of the documents at
+issue here were not prepared in anticipation of litigation, and certainly not litigation about the
+Crime Victims' Rights Act. See, e.g., Southern Union Co. v. Southwest Gas Corp., 205 F.R.D.
+542, 549 (D. Ariz. 2002) (documents not protected by work product because not prepared in
+connection with case at hand).
+II. Specific Responses to Specific Assertions of Privilege.
+A. Attorney-Client Privilege.
+Ordinary Governmental Communications Not Covered - A general attorney-client
+privilege does not exist for ordinary governmental communications. See In re Grand Jury
+Subpoena Duces Tecum, 112 F.3d 910, 916-21 (8th Cir. 1997).
+Only communications concerning
+legal services covered - Any attorney-client
+privilege would be limited to communications made for purposes of facilitating the rendition of
+legal services to the Government client. See, e.g., Diamond v. City of Mobile, 86 F.R.D. 324 (D.
+Ala. 1978) (attorney-client privilege did not bar disclosure of statements made to the city
+attorney while conducting the internal investigation where the purpose of the investigation was
+3
+
+
+Case 9:08-CV-80736-KAM Document 226 Entered on FLSD Docket 08/16/2013 Page 1 of 18
+SOUTHERN DISTRICT OCT CORRE
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOE #1 and JANE DOE #2
+UNITED STATES
+JANE DOE #1 AND JANE DOE #2'S RENEWED MOTION
+FOR AN ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE
+NOT TO WITHHOLD RELEVANT EVIDENCE
+COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and
+through undersigned counsel, to renew their Motion for an Order Directing the U.S. Attorney's
+Office Not to Withhold Relevant Evidence (DE 50). The Court has previously reserved ruling on
+this motion. DE 99 at 11. In light of the Governments' recent decision to assert that thousands
+of pages of documents are privileged - and to produce a privilege log in a manner and format
+that makes it impossible to understand what kinds of documents have been produced, or even
+whether the Government has responded to each request at all - the Court should now grant the
+motion. By granting the motion, the Court would simplify and expedite these proceedings and
+largely or entirely avoid the need for a document-by-document review of the Government's
+privilege assertions and the victims' responses to them.
+BACKGROUND
+As the Court is aware from the victims' previous filing of this motion (see DE 50 at 1-3),
+in discussions with the U.S. Attorney's Office about this case, counsel for Jane Doe #1 and Jane
+1
+
+
+Case 9:08-CV-80736-KAM Document 226 Entered on FLSD Docket 08/16/2013 Page 2 of 18
+Doe #2 inquired about whether the Office would voluntarily provide to the victims information
+in its possession that was material and favorable to the victims' case. Victims' counsel pointed
+out that, if they were criminal defense attorneys representing criminals, the Office would
+promptly turn over all information in its possession that was helpful to these criminals under
+Brady v. Maryland, 373 U.S. 83 (1963), and related decisions. Victims' counsel asked the
+Office to extend to the victims the same assistance that it would provide to criminal defendants -
+i.e., to voluntarily provide to the victims information in its possession that was favorable to the
+victims' CVRA case.
+In response, victims' counsel were informed by the Office that it could - and would -
+withhold from the victims such information, apparently on the theory that the CVRA does not
+apply to this case or on the theory that victims lack due process rights under the CVRA.
+Accordingly, on March 21, 2011, the victims filed a motion asking the Court to enter an order
+directing the Government to produce information in its possession favorable to them. DE 50.
+The Government filed a response in opposition. DE 59. The victims filed a reply. DE 76. After
+a hearing on this and related motions, on September 26, 2011, the Court agreed to allow factual
+development through discovery by the victims. DE 99 at 11. The Court allowed the victims to
+file requests for admission and for production of documents (and potentially other discovery
+requests as well). Id. The Court then noted: "Because the Court will allow this limited factual
+development, it is unnecessary to decide here whether the CVRA or the Federal Rules of Civil
+Procedure provide discovery rights in this context. The Court therefore reserves ruling on [the
+victims'] motion [for an order directing the Government not to withhold relevant evidence]." Id.
+
+
+Case 9:08-cv-80736-KAM Document 226 Entered on FLSD Docket 08/16/2013 Page 3 of 18
+On October 3, 2011, the victims filed requests for production with the Government. On
+November 7, 2011, rather than produce even a single page of discovery, the Government filed a
+motion to dismiss the victims' petition. DE 119. On that same day, the Government filed a
+motion to stay discovery. DE 121. The victims filed a response, arguing that the Government's
+motion was a stall tactic. DE 129. The victims also filed a motion to compel production of all of
+their discovery requests. DE 130. The Government filed a reply, arguing that it was not stalling.
+Indeed, the Government told the Court that "the United States has agreed to provide some
+information to [the victims] even during the pendency of the stay [of discovery] and is
+undertaking a search for that information." DE 140 at 4. Contrary to that representation,
+however, over the next seventeen months, the Government did not produce any information to
+the victims.
+Ultimately, after some additional motions and rulings, on June 19, 2013, the Court denied
+the Government's motion to dismiss and lifted any stay of discovery. DE 189. That same day,
+the Court entered an order granting the victims' motion to compel and directing the Government
+to produce (1) all correspondence between it and Epstein; (2) all communications between the
+Government and outside entities; and (3) every other document requested by the victims. DE
+190 at 2. With respect to the third item, the Court allowed the Government to assert privilege by
+producing the items in question for in camera inspection and filing a contemporaneous privilege
+log. Id. The Court required that the privilege log must "clearly identify] each document|] by
+author(s), addressee(s), recipients), date, and general subject matter
+..."
+DE 190 at 2
+(emphasis added).
+3
+
+
+Case 9:08-CV-80736-KAM Document 226 Entered on FLSD Docket 08/16/2013 Page 4 of 18
+On July 19 and July 27, 2013, the Government made its production in this case. With
+regard to item (1) - correspondence with Epstein, the Government withheld the correspondence
+pending a ruling from the Eleventh Circuit on Epstein's motion to stay production of these
+materials. With regard to the other items, the Government produced 14,825 pages of documents
+to the Court for in camera inspection, but turned over only 1,357 pages to the victims. Thus, the
+Government asserted privilege to more than 90% of the documents in question. The documents
+that the Government produced were almost worthless to the victims, as they included such things
+that the victims' own letters to the Government (Bates 0001-04), court pleadings filed by the
+victims themselves or other victims, by Epstein, or by news media organizations (e.g., Bates
+00142-88, 00229-31, 281-311, 00668-69), public court rulings on Epstein related matters (e.g.,
+Bates 0008-10, 0012-14. 0036-86, 00190-228), public newspaper articles (e.g., Bates 0011,
+0030, 0032-33), and similar materials already available to the victims. It also included roughly
+four hundred pages of notices sent to the various other victims in this case - notices that were
+substantively indistinguishable from the notices the victims themselves had already received.
+Almost without exception, the documents the Government produced do not go to the disputed
+issues in this case.
+On the other hand, the Government asserted privilege on 13,468 pages of materials.
+While many of these pages also do not appear to go to the disputed issues in this case, buried
+among the documents appear to be some highly pertinent materials. The Government has
+asserted privilege, for example, with regard to its internal discussions about notifications to
+crime victims. The Government has also asserted privilege with regard to an investigation by the
+Office of Professional Responsibility (OPR) regarding the handling of the Epstein case and the
+4
+
+
+Case 9:08-CV-80736-KAM Document 226 Entered on FLSD Docket 08/16/2013 Page 5 of 18
+treatment of the victims. It is, however, difficult to say for certain which documents are
+important, because rather than comply with the Court's privilege log requirement, the
+Government provided only a truncated log that did not fully describe the documents at issue,
+much less "clearly" identify the subject matter of the documents and the parties who received
+them.' The Government has also failed to identify which documents it is producing go to which
+document production requests.
+DISCUSSION
+The victims have previously explained at length why the Court should enter an order
+directing the Government not to withhold relevant documents. DE 50; see also DE 59 (Gor't
+Response); DE 76 (victim's reply). The Court reserved ruling on that motion for an uncertain
+amount of time. The victims will not repeat their previously-advanced arguments here, but
+simply incorporate them by reference and respectfully suggest that now would be a propitious
+point in this case for the Court to take up the motion again - and to grant the motion. Doing so
+would save the Court and the victims considerable amount of time by narrowing (or even
+eliminating entirely) the number of privilege issues that would need to be resolved.
+In addition, the victims wish to advance three new arguments in support of their motion
+for such an order based on new developments in this case since they filed their motion. First and
+most important, the Government's response to the Court's discovery order is so fundamentally
+inadequate that the Court should simply not allow further litigation but provide the documents to
+the victims by granting their motion. Second, the Court should also grant the victims' motion
+" Further factual information that may be relevant to this motion is found in the
+contemporaneously-filed Affidavit of Bradley J. Edwards, attached to Jane Doe #1 and Jane Doe
+#2's Motion to Compel Production of Documents That Are Not Privileged.
+5
+
+
+Case 9:08-CV-80736-KAM Document 226 Entered on FLSD Docket 08/16/2013 Page 6 of 18
+because the Government's fiduciary obligations to the victims to use its "best efforts" to protect
+their rights conflict with its privilege assertions. Specifically, assertion of any privilege is
+inconsistent with the fiduciary duties that flow from that statutory "best efforts" requirement.
+Third, the Government's recent admissions and privilege log make clear that significant "Brady"
+material exists. Accordingly, the Court should no longer reserve ruling on the victims' motion
+but instead should simply order these highly relevant materials to be produced now, just as it
+would order the Government to produce highly relevant materials to criminal defendants.
+I.
+THE COURT SHOULD SIMPLY PRODUCE THE DOCUMENTS TO
+THE VICTIMS BECAUSE OF THE GROSS INADEQUACIES OF THE
+GOVERNMENT'S PRIVILEGE ASSERTIONS.
+The Government has grossly violated the Court's order to provide an appropriate
+privilege log in connection with the disputed documents. In light of that stark failure, the Court
+should simply grant the victims'
+pending motion regarding suppression of evidence and produce
+the disputed documents to them.
+As the Court is well aware, it has denied repeated efforts by the Government to block the
+victims from receiving relevant information about this case. In its most recent order (DE 190),
+the Court directed the Government to either produce "all other responsive documents in response
+to all outstanding requests for production of document" to the victims or "file and serve, in the
+public portion of the court file, a privilege log clearly identifying each document] [withheld] by
+author(s), addressee(s), recipients), date, and general subject matter
+...." DE 190 at 2
+(emphasis added). Government then made its production. But rather than provide helpful
+information to the victims, the Government instead has provided information that was essentially
+irrelevant to the disputed issues. See Affidavit of Bradley J. Edwards at 5.
+16
+
+
+Case 9:08-CV-80736-KAM Document 226 Entered on FLSD Docket 08/16/2013 Page 7 of 18
+More important with regard to this motion, the Government has not begun to comply in a
+meaningful way with a discovery process that would permit the victims to obtain information
+relevant to their claims. Of course, the purpose of a privilege log "is to provide a party whose
+discovery is constrained by a claim of privilege ... with information to sufficient to evaluate
+such a claim and to resist if it seems unjustified." Tuite v. Henry, 98 F.3d 1411, 1416 (D.C. Cir.
+1996). Reinforcing that command, this Court required the Government's privilege log to
+"clearly" indicate what materials were covered. The Government has not begun to provide the
+victims with sufficient information to resist claims of privilege.
+One of the most basic problems with the Government's action is that it is not identified
+which of the "privileged" documents apply to which of the victims' document production
+requests,
+Instead, the Government has simply taken more than 13,000 pages of documents,
+Bates stamped them in no particular order (or at least no order that the victims can discern), and
+then asserted that they are all privileged for various reasons. The resulting "log" is wholly
+inadequate for multiple reasons, the most basic of which is that it does not signal to the victims
+which produced documents respond to which requests. To gather the documents to respond to
+the Requests for Production (RFPs), presumably the Government had to perform query searches
+in electronic databases or actual searches in paper files. Each search would have then produced
+certain documents. But rather than disclose documents on a search-by-search basis, the
+Government has simply taken the all documents it gathered, apparently dropped them on the
+2 The victims' First and Second Requests for Production are included as attachments to
+the Affidavit of Bradley J. Edwards, which is (in turn) an attachment to the victims'
+contemporaneously-filed Motion to Compel Production of Documents That Are Not Privileged.
+See, e.g., Jane Doe #1 and Jane Doe #2's First RFP, 1 16(d) (requesting emails and
+other documents in which certain particular words appear).
+
+
+Case 9:08-cv-80736-KAM Document 226 Entered on FLSD Docket 08/16/2013 Page 8 of 18
+floor into a random pile, and then provided a "log" of documents in no order whatsoever - and
+without indicating which documents are being produced in answer to each question. The
+resulting mishmash of thousands of documents places the victims in the impossible position of
+trying to determine what the documents mean without any context whatsoever.
+Compounding this problem and creating a critical additional problem, this lump and
+dump technique makes it impossible to verify that the Government has actually performed each
+of the searches required to make each of the responses. Indeed, it would be entirely possible that
+the Government could have failed to search for, or to produce, any documents whatsoever on
+certain requests and the victims would have no way to know one way or the other.
+Perhaps in theory these problems might be mitigated if the Government had produced (as
+the Court required) a privilege log "clearly" describing the subject matters and other particulars
+of the documents produced. But as the Court can confirm with just a casual glance at the
+privilege log, many of the documents have been described generically or not at all, leaving the
+victims to wonder what many of the documents really are.
+The upshot of the "lump and dump" approach is that the victims cannot even begin to
+understand what has been produced with regard to their particular discovery requests. As an
+illustration, consider the victims' request for production of documents about former prosecutor
+Bruce Reinhart's knowledge of information about the Epstein prosecution immediate before he
+left to become employed by Epstein. See Jane Doe #1 and Jane Doe #2's First Request for
+Production, 1 15 (seeking this information); 1| 21 (requesting information collected by OPR on
+this subject). The victims know that the Government has information responsive to this request,
+because in answering the victims' First Request for Admissions, the Government admitted that it
+8
+
+
+Case 9:08-CV-80736-KAM Document 226 Entered on FLSD Docket 08/16/2013 Page 9 of 18
+possessed information reflecting contacts between Reinhart and persons working at the Justice
+Department that related to the Epstein investigation. See Government's Answers to Jane Doe #1
+and Jane Doe #2's First Request for Admissions (RFA's), 99 15-17." It further admitted that
+OPR collected information about Reinhart's possibly improper behavior. See Gov't's Answers
+to RFA's, 1 22(a). Yet there is no way to tell which documents (among the more than 13,000
+pages of documents) are responsive to RFP 15 because the Government has not indicated which
+of its documents apply to which RFP. Nor has the Government given the victims sufficient
+information to make this determination on their own. Indeed, the Government's privilege log
+does not even contain the word "Reinhart" anywhere in it. So it is simply impossible to tell
+which documents apply to the Reinhart issue.
+As another illustration, consider the victims' request for information about former
+prosecutor
+personal/business relationship with Jeffrey Epstein. See, e.g.,
+Victims' First RFP's at 9 16(f). Here again, the victims know that the Government possesses
+such information, because it admitted to having such information in answer to the victims'
+request for admissions - information collected by its own internal affairs unit, OPR. See Gov't's
+Answers to RFA's, 1| 20. Yet once again, it is impossible for the victims to even tell which
+documents (if any) the Government has turned over to the Court that pertain to this issue,
+because the Government has not explained which documents apply to this request and none of
+4
+The victims' Request for Admissions and the Government's answers thereto are
+included as an attachment to the Affidavit of Bradley J. Edwards, which is (in turn) an
+attachment to the victims' contemporancously-filed Motion to Compel Production of Documents
+That Are Not Privileged.
+
+
+Case 9:08-CV-80736-KAM Document 226 Entered on FLSD Docket 08/16/2013 Page 10 of 18
+the privilege log entries provide any description that indicates they cover documents regarding
+such a personal or business relationship.
+As yet another illustration, consider the victims' request for information about the OPR
+investigation into the possible mishandling of the Epstein prosecution and victim notifications.
+Here again, the victims have very specifically requested such information. See Victims' First
+RFP's at 1| 17. The Government has admitted that OPR collected information about possible
+improper behavior by prosecutors in the Epstein matter. Gov't's Answers to RFA's, 9|22. Yet
+it is simply impossible to tell where the information that the Government collected appears
+among thousands of pages of documents it has produced.
+As a fourth and final illustration, the victims requested information about why the U.S.
+Attorney's Office for the Southern District of Florida (USAO-SDFL) was "conflicted out" of
+considering issues relating to the Epstein matter, as well as any information that developed about
+that conflict after the Epstein matter was referred to another district (e.g., the Middle District of
+Florida). See Victims' First RFP's at 9 18; Victims' Second FRP's at 9| 1. The victims know
+that the USAO-SDFL was in fact conflicted out of some decisions, so presumably the USAO-
+MDFL evaluated something as a result.
+Yet apart from a few preliminary emails within the
+5
+is, of course, revealed in the privilege log at several points as on the e-mails
+chains involved in the plea bargain discussions surrounding the Epstein prosecution. But none of
+relationship. Motions, the rivit ma lo of the are remog ely ries d not personal or business
+is not even possible to look for materials that might follow the date on which
+U.S. Attorney's Office.
+& The Court will notice that some pages in the Government's privilege log do deal with
+the OPR investigation. See Gov't Supp. Privilege Log at 12-14. But so far as the victims can
+discern, the documents covered there are simply e-mails about the OPR investigation, rather than
+the underlying substantive information collected during the OPR (or OPR-triggered)
+investigation.
+10
+
+
+Case 9:08-cV-80736-KAM Document 226 Entered on FLSD Docket 08/16/2013 Page 11 of 18
+Justice Department regarding whether the recusal should occur, see Gov't First Privilege Log at
+pp. 22-23, nothing in the privilege log indicates that the Government has produced even a single
+document in response to the request for information about what happened as a result of the
+recusal. Indeed, so far as the victims can tell, the Government may even be staking out the
+remarkable position that there is not even one single document in the Middle District of Florida
+that is responsive to the victims' requests, because (so far as the victims can tell) nothing has
+been provided from the Middle District of Florida.
+These are but four clear and illustrative examples, which the victims could multiply
+dozens of times. The victims respectfully ask the Court to require the Government, in its
+response to this motion, to indicate where (if anywhere) in the privilege log documents
+pertaining to these four issues appear, so that the Court can then judge for itself whether the
+victims have been given sufficient information to respond to the Government's claims of
+privilege.
+Again, our point in this pleading is not to try and debate the Government on its privilege
+assertions. The more basic point in this pleading is that the victims cannot even begin to fairly
+challenge many of the Government's assertions because they do not know which (if any) of the
+documents at issue pertain to their discovery requests. The Government's privilege assertions
+are simply broken beyond repair. In view of this gross failure by the Government, the Court
+should simply provide the documents it has received to the victims by granting the victims'
+Motion for an Order to the Government not to Withhold Relevant Evidence. At an absolute
+minimum, to solve the problem that the Government has not indicated which documents apply to
+11
+
+
+Case 9:08-CV-80736-KAM Document 226 Entered on FLSD Docket 08/16/2013 Page 12 of 18
+which requests, the Government should be required to provide a listing of documents on a
+request-by-request basis.
+Il.
+THE COURT SHOULD ORDER THE GOVERNMENT TO PRODUCE THE
+REQUESTED DOCUMENTS BECAUSE THE CVRA'S BEST EFFORTS
+REQUIREMENT CREATES A FIDUCIARY EXCEPTION TO ALL
+PRIVILEGES.
+In their 2011 motion, the victims explained that the CVRA obligates government
+prosecutors to "make their best efforts to see that crime victims are... accorded/] their rights"
+under the CVRA. DE 50 at 3-5 (citing 18 U.S.C. § 3771(c)(1)); see also DE 76 at 2-6. In light
+of the Government's recent assertion of privilege, the Government's failure is now even more
+apparent. The Government's invocation of a privilege to block disclosure of documents is
+simply inconsistent with the Government's statutorily-mandated best efforts obligation.
+Controlling circuit precedent supports the conclusion that the Government fiduciary duty
+bars an assertion of privilege, even in the context of the well-established and absolute attorneyclient privilege. In Garner v. Wolfinbarger, 430 F.2d 1093 (5th Cir. 1970), the Court of Appeals
+with jurisdiction over this Court? held that an attorney-client privilege can give way when "the
+client asserting the privilege is an entity which in the performance of its functions acts wholly or
+partly in the interests of others, and those others... seek access to the subject matter of the
+communications." Id. at 1101 (emphasis added). In Garner, the Court refused to allow the
+management of a corporation to invoke attorney-client privilege in the context of a shareholder
+derivative action, noting that beneficiaries of its actions with the stockholders. Id. Since that
+' See Knight v. Thompson, --F.3d--, 2013 WL 3843803 at *5 n.5 (lIth Cir. 2013)
+(citing Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en banc) (11th Circuit
+adopts as binding precedent all decisions of the former Fifth Circuit handed down prior to the
+close of business on September 30, 1981)).
+12
+
+
+Case 9:08-cv-80736-KAM Document 226 Entered on FLSD Docket 08/16/2013 Page 13 of 18
+ruling, many courts (including this Court) have applied the "Garner doctrine" or "fiduciary
+exception doctrine" in settings outside the shareholder derivative context. See, e.g., Solis v. Food
+Employers Labor Relations Ass'n, 644 F.3d 221, 227-28 (4th Cir. 2011) (applying Garner
+principles to bar assertions of privilege to communications by ERISA fiduciary and plan
+attorneys in suit concerning alleged mismanagement of plan assets); Maltby v. Absolut Spirits
+Co., Inc., 2009 WL 800142 at *4 (S.D. Fla. 2009) ("Defendant maintains that this Court should
+not apply the fiduciary exception here because the Eleventh Circuit has never applied the
+fiduciary exception in the context of an ERISA case. Defendant provides no legal or factual
+explanation of why this Court should not apply this doctrine, however."); Nellis v. Air Line Pilots
+Ass'n, 144 F.R.D. 68, 71 (E.D. Va. 1992) (holding that the Garner doctrine applies because
+unions owe a fiduciary duty to their members). The "Garner doctrine" or "fiduciary exception"
+has also been applied to bar the federal government from asserting privilege against those whose
+interests it must protect, such as Indian tribes. See, e.g., Osage Nation and/or Tribe of Indians of
+Oklahoma v. United States, 66 Fed. Cl. 244 (2005); Cobell v. Norton, 212 F.R.D. 24 (D.D.C.
+2002). For instance, in Osage Nation, the Government argued against application of the
+fiduciary exception in the context of a case alleging mismanagement of Indian trust funds,
+contending that the federal agencies are "often charged with protecting competing interests,
+including some potentially adverse to a Tribe's interest." Id. at 247. The district court rejected
+these arguments, finding the claim "that the government's sovereign interests somehow negate or
+offset its obligations as trustee to be unpersuasive." Id. at 248.
+The situation here is parallel to situations such as a union being challenged by its
+members or the Government is being challenged an Indiana tribe. In this case, of course, a U.S.
+13
+
+
+Case 9:08-CV-80736-KAM Document 226 Entered on FLSD Docket 08/16/2013 Page 14 of 18
+Attorney's Office is being challenged by recognized crime victims, who are arguing that the
+Office violated its statutory obligation to act in their "best interests." Accordingly, under
+Garner, an attorney-client privilege is not appropriate, provided the victims to show "good
+cause" why the privilege should not be invoked. Id. at 1104. Here, there is ample good cause.
+See generally Affidavit of Bradley J. Edwards, Esq. (filed concurrently with this motion as an
+attachment to the Victims' Motion to Compel Production of Documents that Are Not Privileged)
+(explaining why good cause exists for production of documents requested). As a result, the Court
+should not allow the Government to invoke privilege but should instead simply grant the victims'
+motion for an order not allowing the Government to withhold relevant evidence and turn the
+disputed materials over to the victims.
+THE VICTIMS HAVE A DUE PROCESS RIGHT UNDER THEIR CVRA
+"RIGHT TO BE TREATED WITH FAIRNESS."
+In their 2011 motion, the victims also argued that they were entitled to receive favorable
+evidence in the Government's possession for the same reason that criminal defendants receive
+such information: fundamental considerations of fairness require that the Government not
+deliberately withhold relevant information contrary to its position in court. DE 50 at pp. 5-9
+(citing Brady v. Maryland, 373 U.S. 83, 87 (1963), and arguing that they are entitled to "Brady"
+information contradicting the Government's position no less than criminal defendants). In light
+of the Government's recently-filed privilege log, the need for the Court to grant the victims'
+motion has become even more apparent.
+The Government's privilege log indicates that it is withholding significant information
+that is critical to the victims' arguments.
+For example, the Government is withholding
+14
+
+
+Case 9:08-CV-80736-KAM Document 226 Entered on FLSD Docket 08/16/2013 Page 15 of 18
+information about its discussions concerning how to notify crime victims. See, e.g., page 16 of
+first privilege log (DE 212-1) regarding Box #2 P-010526 to P-010641. And the Government is
+withholding information about its own internal investigation into the potential wrongdoing in this
+case. See, e.g., page 13 of supplemental privilege log (DE 216-1) regarding Suppl. Box 3 P-
+013940 to P-013942.
+As we understand the Government's position on this issue, it does not contend that it does
+not have important evidence for the victims' case. Nor does the Government argue that it would
+be difficult to identify that material. Instead, the Government's argument has been that Brady
+obligations are confined to criminal cases against criminal defendants. DE 59 at 5-6.
+But the case law is not so narrow as the Government believes. The victims have recently
+identified several cases in which courts have applied Brady outside of the criminal context. In
+Demjanjuk v. Petrovsky, 10 F.3d 338 (6th Cir. 1993), the Sixth Circuit applied Brady in the
+context of a denaturalization and extradition case. In United States v. Edwards, 777 F.Supp.2d
+985 (E.D.N.C. 2011), the district court applied Brady to civil commitment proceedings for sexual
+offenders. And in EEOC v. Los Alamos Constructors, Inc., 382 F.Supp. 1373, 1374 (D.N.M.
+1974), the district court applied Brady to an employment discrimination action.
+The issue of Brady obligations in a CVRA action appears to be one of first impression.
+Thus, more important than case law is the fact that the victims here can rely on specific statute -
+the CVRA - that gives them a right to be "treated with fairness." 18 U.S.C. § 3771(a)(8). Being
+treated with fairness means (at a minimum) treated someone with due process. As one of the
+CVRA's co-sponsors (Senator Kyl) explained, "The broad rights articulated in this section [§
+3771(a)(8)] are meant to be rights themselves and are not intended to just be aspirational. One of
+15
+
+
+Case 9:08-CV-80736-KAM Document 226 Entered on FLSD Docket 08/16/2013 Page 16 of 18
+these rights is the right to be treated with fairness. Of course, fairness includes the notion of due
+process. Too often victims of crime experience a secondary victimization at the hands of the
+criminal justice system.
+This provision is intended to direct Government agencies and
+employees, whether they are in executive or judiciary branches, to treat victims of crime with the
+respect they deserve." 150 Cong. Rec. S4269 (Apr. 22, 2004) (emphasis added).
+In the context of this particular case, it is simply inconsistent with the "due process"
+requirements of the CVRA to allow the Government to withhold documents that will help the
+victims prove their case. The Court should accordingly enter an order, paralleling its "Standing
+Discovery Order" in criminal cases, directing the Government to provide favorable evidence to
+the victims. See Local Rule 88.10. The Standing Discovery Order typically provides: "The
+government shall reveal to the defendant(s) and permit inspection and copying of all information
+and material known to the government which may be favorable to the defendant on the issues of
+guilty or punishment within the scope of Brady v. Maryland, 373 U.S. 83 (1963), and United
+States v. Agurs, 427 U.S. 97 (1976)." The Court should adopt that language to the case at hand
+here.
+Interesting, the Standing Discovery Order - and associated local rule 88.10(O) - contains
+a broad, commonsense provision which the Government has plainly violated in this case. The
+Order provides: "The parties shall make every possible effort in good faith to stipulate to all facts
+or points of law the truth or existence of which is not contested and the carly resolution of which
+will expedite the trial." For more than five years, the victims have been trying to get the
+Government to stipulate to undisputed facts, precisely as the Court's rules envision. The
+Government, however, has refused to do so. Accordingly, the Court should enter an order
+16
+
+
+Case 9:08-CV-80736-KAM Document 226 Entered on FLSD Docket 08/16/2013 Page 17 of 18
+requiring the Government to produce evidence which it well knows is relevant and material to
+the victims' case. And because the Court has in its possession thousands of pages of documents
+that fit that description, the Court should simply turn that information over to the victims.
+CONCLUSION
+The Court should enter an order directing the Government not to withhold material
+evidence in this case and should provide to the victims the materials it has received for in camera
+review.
+In addition, to solve the problem that the Government has not indicated which
+documents apply to which requests, the Government should be required to provide such a
+responsive document.
+DATED: August 16, 2013
+Respeetfully Submitted,
+Is/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale. Florida 33301
+Telephone
+Facsimile
+and
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City. UT 84112
+Telephone:
+Facsimile:
+E-Mail:
+17
+
+
+Case 9:08-CV-80736-KAM Document 226 Entered on FLSD Docket 08/16/2013 Page 18 of 18
+I certify that the foregoing document was served on August 16, 2013, on the following
+using the Court's CM/ECF system:
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Fax:
+Attorneys for the Government
+Day Fletore, Esq.
+Jay P. Lefkowitz
+Kirkland & Ellis, LLP
+601 Lexington Avenue
+New York, NY 10022.
+Martin G. Weinberg, P.C.
+20 Park Plaza, Suite 1000
+Boston, MA 02116
+Email: owlmgw@att.net
+Is/ Bradley J. Edwards
+18
+
+
+Case 9:08-CV-80736-KAM Document 230 Entered on FLSD Docket 09/03/2013 Page 1 of 12
+CASE NO. 08-80736-CIV-MARRA
+JANE DOE #1 AND JANE DOE #2,
+Petitioners,
+Vs.
+UNITED STATES,
+Respondent.
+RESPONDENT'S OPPOSITION TO PETITIONERS' RENEWED MOTION FOR
+AN ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE NOT TO
+WITHHOLD RELEVANT EVIDENCE
+Respondent, by and through its undersigned counsel, files its Opposition to Petitioners"
+Renewed Motion for an Order Directing the U.S. Attorney's Office Not to Withhold Relevant
+Evidence, and states:
+I.
+INTRODUCTION
+In its Omnibus Order of June 18, 2013, this Court directed that petitioners should have
+thirty days after service of the government's privilege log to file a motion to compel contesting
+any asserted privilege claim. D.E. 190 at 2. Any such motion to compel was limited to seven
+pages. Id.
+Within fifteen days, the government was permitted to file its response, which was
+also limited to seven pages. D.E. 190 at 3.
+Petitioners' response to the government's filing of its privilege log has been the filing of
+the following: (1) the government's privilege log with its objections annotated (D.E. 224-1); (2)
+a motion to compel production of documents that are not privileged, numbering eight pages D.E.
+225; (3) a twenty-four page, single-spaced affidavit of petitioners' counsel, addressing the
+
+
+Case 9:08-CV-80736-KAM Document 230 Entered on FLSD Docket 09/03/2013 Page 2 of 12
+various privileges asserted by the government, D.E. 225-1; and (4) a renewed motion for an
+order directing the U.S. Attorney's Office not to withhold relevant evidence, numbering
+seventeen pages, D.E. 226. The renewed motion also challenges the government's assertions of
+privilege.
+I.
+THE GOVERNMENT HAS PROPERLY INVOKED APPLICABLE
+PRIVILEGES
+Petitioners argue that this Court should summarily dismiss the privileges invoked by the
+government because of the "gross inadequacies" in the privilege assertions. D.E. 226 at 6-7.
+Their argument is baseless because the privilege log does clearly indicate what documents for
+which a privilege is being claimed. Further, the Court also has the actual document for in
+camera review to determine if the privilege is valid.
+Petitioners go so far as to complain that the government has not identified in the privilege
+log which documents respond to which requests. Id. at 7. They do not explain how the validity
+of a privilege is contingent upon which request for production the document is responsive to. In
+request for production no. 18, petitioners requested documents "regarding potential conflicts of
+interest that the Justice Department discussed or determined existed for the USAO SDFL ...."
+The government's privilege log clearly references e-mails between Assistant General Counsel
+Richard Sudder, Executive Office for United States Attorneys, and First Assistant U.S. Attorney
+Benjamin Greenberg, "regarding Formal Notice of Office-wide Recusal of Southern District of
+Florida, dated August 24 and August 29, 2011." D.E. 212-1 at 22. Further, the privilege log
+detailed emails between Peter Mason, Executive Office for United States Attorneys, and
+Assistant U.S. Attorney
+"seeking advice regarding office-wide recusal, dated
+December 16 and 17, 2010, with attached letter from Paul Cassell to
+dated
+December 10, 2010." D.E. 212-1 at 23.
+2
+
+
+Case 9:08-CV-80736-KAM Document 230 Entered on FLSD Docket 09/03/2013 Page 3 of 12
+The subjects of the e-mails, office-wide recusal and "seeking advice regarding officewide recusal," were stated in the privilege log. The attorney-client privilege was invoked for
+these documents, along with the deliberative process and work product privileges for a subset of
+these documents. Since petitioners requested these documents, they should be able to discern
+what document request they pertain to. Moreover, the purpose of the e-mails, seeking advice
+regarding office-wide recusal, was stated in the privilege log. This is sufficient factual detail to
+permit petitioners and the Court to determine whether the attorney-client privilege applies.
+Petitioners' claim that the government has failed to produce relevant documents is based
+on fallacious assumptions. They use as an example of a failure to produce documents the request
+for documents regarding former Assistant U.S. Attorney Bruce Reinhart. D.E. 226 at 8-9. "The
+victims know that the Government has information responsive to this request, because in
+answering the victims' First Request for Admissions, the Government admitted that it possessed
+information reflecting contacts between Reinhart and persons working at the Justice Department
+that related to the Epstein investigation." Id. Continuing, petitioners state, "It further admitted
+that OPR collected information about Reinhart's possibly improper behavior," They then argue
+that "there is no way to tell which documents (among the more than 13,000 pages of documents)
+are responsive to RFP 15 because the Government has not indicated which of its documents
+apply to which RFP."' Id, at 9.
+The fallacy in petitioners' reasoning is the assumption that the basis for the government's
+response to the request for admission was a document, rather than personal observation. If it was
+based on the latter, there would be no document to produce. Petitioners make the same
+fallacious assumption in the case of former Assistant U.S. Attorney
+9-10. The admission in Request for Admission No. 20 need not have been based upon a
+D.E. 226 at
+' The RFP which seeks documents pertaining to Reinhart is actually number 16, rather than 15.
+3
+
+
+Case 9:08-cV-80736-KAM Document 230 Entered on FLSD Docket 09/03/2013 Page 4 of 12
+document.
+Petitioners admit that the government has included documents from the Office of
+Professional Responsibility (OPR) in its privilege logs. D.E. 226 at 10 n.6. The government has
+properly invoked the attorney-client, work product, and deliberative process privileges for many
+of the OPR documents. D.E. 216-1 at 12-14. In Sandra T.E. v. South Berwyn School District
+100, 600 F.3d 612 (7" Cir. 2010), the Seventh Circuit reversed a district court's finding that the
+attorney-client and work product privileges did not apply to notes of witness interviews, and
+memoranda prepared from those interviews, by a law firm retained by a school district. A
+teacher in the school district was charged with sexually molesting numerous students over
+several years. Id. at 615. A civil lawsuit was filed against the school district and the principal.
+The school district hired Sidley Austin LIP to conduct an internal investigation and provide
+legal advice to the school board. Sidley Austin was not the school district's litigation counsel in
+the civil lawsuit. Attorneys from Sidley Austin interviewed current and former school district
+employees, as well as third-party witnesses. The attorneys took handwritten notes and later
+drafted memos summarizing the interviews. Id.
+During discovery in the civil litigation, the plaintiffs sought documents in Sidley Austin's
+possession regarding its investigation. The law firm invoked the attorney-client and work
+product privileges as to its notes and internal memoranda relating to the employee witness
+interviews, as well as other legal memoranda. The district court rejected the privilege claims,
+finding that Sidley Austin had been hired to provide investigative services, not legal services. Id.
+The appellate court found, based on the engagement letter between Sidley Austin and the
+school district, that the law firm had been hired to "investigate the response of the school
+administration to allegations of sexual abuse of students," and "provide legal services in
+4
+
+
+Case 9:08-cv-80736-KAM Document 230 Entered on FLSD Docket 09/03/2013 Page 5 of 12
+connection with the specific representation." Id. at 619. The Seventh Circuit found this letter
+brought the case squarely within Upjohn Co. v. United States, 449 U.S. 383 (1981), "which
+explained that factual investigations performed by attorneys as attorneys fall comfortably within
+the protection of the attorney-client privilege." 600 F.3d at 619(emphasis in original). Despite
+the fact that Sidley Austin was not the school district's litigation counsel, the appellate court
+found that Sidley's investigation of the factual circumstances surrounding the abuse was an
+integral part of the package of legal services for which it was hired and a necessary prerequisite
+to the provision of legal advice about how the school district should respond, Id. at 620. The
+Court also found the witness interview notes and memoranda were entitled to protection under
+the work product privilege because they were prepared "with an eye toward" the pending
+litigation. Id, at 622
+In this case, OPR is charged with the responsibility of investigating allegations of
+misconduct committed by DOJ attorneys. 28 C.F.R. § 0.39a(a)(1). The counsel heading OPR
+reports to the Attorney General. 28 C.F.R. § 0.39a. One of OPR's functions is to "[rjeceive,
+review, investigate and refer for appropriate action." § 0.39a(a)(2). In discharging this function,
+OPR attorneys interviewed DOJ attorneys regarding the allegations of misconduct lodged by
+petitioners' counsel, took notes, and prepared memoranda, just like the law firm retained by the
+South Berwyn School District. The documents generated by these investigative actions are
+covered by the work product privilege because notes and memoranda prepared by OPR attorneys
+are created with an eye toward potential litigation. Under § 0.39a(a)(3), OPR Counsel shall,
+"[r'leport to the responsible Department official the results of inquiries and investigations arising
+under paragraphs (a)(I) and (2) of this section, and, when appropriate, make recommendations
+for disciplinary and other corrective action."
+5
+
+
+Case 9:08-CV-80736-KAM Document 230 Entered on FLSD Docket 09/03/2013 Page 6 of 12
+In their fourth example, petitioners claim they "know that the USAO-SDFL was in fact
+conflicted out of some decisions, so presumably the USAO-MDFL evaluated something as a
+result." D.E. 226 at 10-11. They contend that, other than a few preliminary emails within the
+DOJ regarding whether the recusal should occur, "nothing in the privilege log indicates that the
+Government has produced even a single document in response to the request for information
+about what happened as a result of the recusal."
+Petitioners appear to believe that, because the USAO-SDFL was recused from the
+Epstein case, the USAO-MDFL "evaluated something as a result." In U.S. v. Weyhrauch, 544
+F.3d 969 (9" Cir. 2008), the Ninth Circuit noted that, "the General Counsel's Office of the
+EOUSA coordinates office-wide recusals, obtains necessary approvals and helps arrange the
+transfer of responsibility to another office ...." Id. at 973-74. Office-wide recusals are
+frequently based upon a finding that a reasonable person could question the impartiality of a
+particular U.S. Attorney's Office, such as when the Office is prosecuting a crime where the
+victim is an employee in that U.S. Attorney's Office, or a defendant is a close family member of
+a U.S. Attorney's Office employee. Petitioners seem to believe that the recusal of the USAO-
+SDFL was based on a finding that misconduct had occurred in the Epstein case, which is
+incorrect. Further, the transfer of responsibility to the USAO-MDFL was not a charter for it to
+investigate the USAO-SDFL. Instead, the USAO-MDFL assumed responsibility for the Epstein
+case, and exercises its own independent judgment and discretion in deciding what action to take,
+if any.
+Il.
+THE FIDUCIARY EXCEPTION TO THE ATTORNEY-CLIENT PRIVILEGE
+DOES NOT APPLY IN THIS CASE
+Petitioners argue that government should be ordered to produce the requested documents
+because there is a fiduciary exception to all privilege. This wholesale attempt to overcome the
+6
+
+
+Case 9:08-cv-80736-KAM Document 230 Entered on FLSD Docket 09/03/2013 Page 7 of 12
+government's claims of privilege should be rejected because it lacks any legal basis.
+The premise of petitioners' argument is that the CVRA provides that government
+prosecutors are to "make their best efforts to see that crime victims are accorded their rights." 18
+U.S.C. § 3771(c)(1). They provide no legal authority for the contention that the CVRA creates a
+fiduciary obligation between the government and crime victims. Instead, petitioners attempt to
+engraft such a duty from other cases, involving duties owed by a corporation to its shareholders,
+Garner v. Wolfinbarger, 430 F.2d 1093 (5' Cir. 1970), and the relationship between the federal
+government and Indian tribes. None of those cases are apposite.
+In United States v. Jicarilla Apache Nation, 131 S.Ct. 2313 (2011), the Supreme Court
+reversed the Court of Federal Claims' finding that the government was required to produce
+documents in litigation involving the Jicarilla Apache Nation. The Tribe had instituted a breach
+of trust action against the United States, claiming the government had mismanaged funds held in
+trust for the Tribe. The Tribe sought various documents in discovery, which included materials
+for which the government claimed were protected by the attorney-client privilege. The Court of
+Federal Claims applied the fiduciary exception to the attorney-client privilege, applied in the
+context of common law trust, and found the documents were not privileged. 131 S.Ct. at 2319.
+The Supreme Court reversed, finding the government is not a private trustee, and the trust
+defined between the government and the Tribe was governed by statutes, rather than the common
+law. Id. at 2323. Further, the United States did not obtain legal advice as a "mere
+representative" of the Tribe, nor was the Tribe the "real client" for whom that advice was
+intended. Id. at 2326. Assuming any fiduciary relationship exists between the government and
+a crime victim, such relationship would be based on the CVRA, not the common law. Further,
+the government would be managing any trust relationship as a sovereign function, pursuant to
+7
+
+
+Case 9:08-cv-80736-KAM Document 230 Entered on FLSD Docket 09/03/2013 Page 8 of 12
+the plenary authority of Congress, not as a private trustee.
+In Jicarilla, the Supreme Court distinguished Garner:
+benefit from its administration. Courts apply the fiduciary
+exception on the ground that "management does not manage for
+implementation of federal Indian policy. For that reason, when the
+Government seeks legal advice related to the administration of
+tribal trusts, it established an attorney-client relationship related to
+its sovereign interest in the execution of federal law. In other
+words, the Government seeks legal advice in a "personal" rather
+than a fiduciary capacity. See Riggs, 355 A.2d at 711.
+131 S.Ct. at 2327-28. In this case, the government had its own independent interest in the
+exercise and implementation of its sovereign authority to prosecute an individual for violating
+federal law. Therefore, the fiduciary exception does not apply.?
+II. PETITIONERS HAVE NO DUE PROCESS RIGHTS UNDER THE CVRA
+Petitioners argue that they have a due process right to documents in the government's
+possession. D.E. 226 at 14-17. The basis for a due process right, according to petitioners, is the
+CVRA's provision that crime victims have a right "to be treated with fairness." 18 U.S.C. §
+3771(a)(8).
+In making this due process argument, petitioners dispense with any analysis of whether
+the CVRA creates any protected liberty or property interest, sufficient to trigger the due process
+clause. "The necessary first step in evaluating any procedural due process claim is determining
+" The two cases cited by petitioners in support of a fiduciary exception due to the government's relationship with
+Indian tribes, Osage Nation and/or Tribe of Indians of Oklahoma v. United States, 66 Fed. Cl. 244 (2005), and
+Cobell v. Norton, 212 F.R.D. 24 (D.D.C. 2002), are of dubious vitality in light of Jicarilla Apache Nation.
+8
+
+
+Case 9:08-cv-80736-KAM Document 230 Entered on FLSD Docket 09/03/2013 Page 9 of 12
+whether a constitutionally protected interest has been implicated." Tefel v. Reno, 180 F.3d 1286,
+1299 (11" Cir. 1999), citing Economic Dev. Corp. v. Stierheim, 782 F.2d 952, 954-55 (11" Cir.
+1986)(*in assessing a claim based on an alleged denial of procedural due process a court must
+first decide whether the complaining party has been deprived of a constitutionally protected
+liberty or property interest. Absent such a deprivation, there can be no denial of due process.").
+There is no life, liberty, or property interest implicated in the CVRA, and courts are
+hesitant to find that a substantive due process right has been created. See Collins v. City of
+Harker Heights, Texas, 503 U.S. 115, 125 (1992)("As a general matter, the Court has always
+been reluctant to expand the concept of substantive due process because guideposts for
+responsible decisionmaking in this uncharted area are scarce and open ended. (citation omitted).
+The doctrine of judicial self-restraint requires us to exercise the utmost care whenever we are
+asked to break new ground in this field."). Without a protected life, liberty, or property interest,
+petitioners cannot invoke the due process clause as a basis for compelling the government to
+disclose documents to them.
+Petitioners' reliance upon Brady v. Maryland, 373 U.S. 83 (1963), is similarly unavailing.
+Petitioners are not charged with any crime, nor are they in the position of having their liberty
+deprived at the hands of the government, such as the case with a defendant charged with
+committing a crime. Petitioners rely upon three cases, which they claim demonstrate the
+application of Brady outside the criminal context. D.E. 226 at 15. In Demjanjuk v. Petrovsky,
+10 F.3d 338 (6 Cir. 1993), the Sixth Circuit observed:
+misrepresentation at the time he sought admission to the United
+9
+
+
+Case 9:08-CV-80736-KAM Document 230 Entered on FLSD Docket 09/03/2013 Page 10 of 12
+States and subsequently when he applied for citizenship, it would
+have been only a civil action.
+Id. at 353. Demjanjuk has no application to this case since the government does not seek to
+deprive petitioners of their United States citizenship, or anything else. The Sixth Circuit found
+Brady should apply because of two factors. First, the government was seeking to denaturalize
+Demjanjuk. Second, it was seeking to do so on the ground that Demjanjuk engaged in criminal
+activities.
+The appellate court's specific focus on the government's reliance upon Demjanjuk's
+participation in criminal activities, demonstrates that was the legal basis for its finding that Brady
+applied. Their reference to the denaturalization case being "only a civil action," if the
+government had relied solely upon Demjanjuk's misrepresentations, suggests that seeking to
+denaturalize, without an allegation of criminal activity, would not be a sufficient basis for
+applying Brady.
+Similarly, in U.S. v. Edwards, 777 F.Supp.2d 985 (E.D.N.C. 2011), the government was
+seeking to civilly commit Edwards for being a "sexually dangerous person" under 18 U.S.C. §
+4248(a). The district court found that Edwards had a liberty interest in avoiding detention and
+civil commitment. Id. at 990. Consequently, the due process clause was implicated because the
+government was seeking to deprive Edwards of a liberty interest in avoiding detention. In this
+case, the government does not seek to deprive petitioners of anything.
+The third case cited by petitioners is EEOC v. Los Alamos Constructors, Inc., 382
+F.Supp. 1373 (D.N.M. 1974). The district court's analysis of the due process issue is contained
+in one sentence in the following footnote: "Brady v. Maryland (1963) 373 U.S. 83, 83 S.Ct.
+1194, 10 L.Ed.2d 215, orders that exculpatory information must be furnished a defendant in a
+criminal case. A defendant in a civil case brought by the government should be afforded no less
+due process of law." Id. at 1383 n.5. This is no authority for petitioner's due process argument
+10
+
+
+Case 9:08-cv-80736-KAM Document 230 Entered on FLSD Docket 09/03/2013 Page 11 of 12
+since there is no analysis of whether a protected life, liberty, or property interest is implicated by
+the government's actions.
+Moreover, by its own terms, this district court decision is
+inapplicable because petitioners are not defendants in a civil case brought by the government.
+CONCLUSION
+Petitioners' renewed motion should be denied. The privilege log provided by the
+government adequately describes the documents for which privileges are being asserted.
+Further, there is no fiduciary exception to the attorney-client privilege invoked by the
+government, nor is there any due process right to documents provided in the CVRA.
+DATED: September 3, 2013
+Respectfully submitted,
+WILFREDO A. FERRER
+UNITED STATES ATTORNEY
+By: _s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorne!
+Fla. Bar No. 0936693
+99 N.E. 4th Street, Suite 300
+Miami, Florida 33132
+Fax:
+ATTORNEY FOR RESPONDENT
+I HEREBY CERTIFY that on September 3, 2013, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF.
+s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+SERVICE LIST
+
+
+Case 9:08-CV-80736-KAM Document 230 Entered on FLSD Docket 09/03/2013 Page 12 of 12
+Jane Does 1 and 2 v. United States,
+Case No. 08-80736-CIV-MARRA/JOHNSON
+United States District Court, Southern District of Florida
+Bradley J. Edwards, Esq.,
+Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+Fax:
+Paul G. Cassell
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City. Utah 84112
+Fax_
+Attorneys for Jane Doe # 1 and Jane Doe #2
+Roy Black
+Jackie Perczek
+Black, Srebnick, Kornspan & Stumpf, P.A.
+201 South Biscayne Boulevard
+Suite 1300
+Miami, Florida 33131
+(305) 371-6421
+Fax: (305) 358-2006
+Attorneys for Intervenors
+12
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/b7234ed18c1c3068f9d079c9418d09a5d528267cdd0e192db307eaee93c669a7.receipt.json b/vision-fixhub/ds9-unparsed-05/b7234ed18c1c3068f9d079c9418d09a5d528267cdd0e192db307eaee93c669a7.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2b8c49450a7a35d4f71a0d15328a80b17aeea5a4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b7234ed18c1c3068f9d079c9418d09a5d528267cdd0e192db307eaee93c669a7.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -40058,
+  "dataset": "marble-joined",
+  "doc_id": "b7234ed18c1c3068f9d079c9418d09a5d528267cdd0e192db307eaee93c669a7",
+  "engine": "marble-apple-vision",
+  "event_count": 285,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "a4c10c416c7b1dae2e7be168251663bd1a6f5e00e12adfa0bb900c6f454c3a9b",
+  "output_sha256": "8162f5272052f6ccdd15936790195894ce626891f574330d3d8093644d5b7669",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b72b3c223ce2150ee4ec96abce59b31ec82e01dedccee4285202d81f0dd19799.md b/vision-fixhub/ds9-unparsed-05/b72b3c223ce2150ee4ec96abce59b31ec82e01dedccee4285202d81f0dd19799.md
new file mode 100644
index 0000000000000000000000000000000000000000..2215e4c6c20b8f2d052b48f173db53b45069449c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b72b3c223ce2150ee4ec96abce59b31ec82e01dedccee4285202d81f0dd19799.md
@@ -0,0 +1,177 @@
+OLY-67
+
+
+TO: Custodian of Records
+Live Nation Theatrical/Broadway
+Across America
+500 E. Broward Boulevard
+Fort Lauderdale, FL
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-67
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOUARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+July 10, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or object(s):
+THE DOCUMENTS LISTED ON ATTACHMENT.
+*Please coordinate your compliance with this suhnnons nud confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+DATE:
+(BY) DEPUTY CLERK
+June 27, 2007
+This subpoena is issued upon application
+of the United Statos of America
+I not applicable, cuter "none.
+Name, Address and Phone Number of Assistant IJ.S. Attorney
+300 50. Australian Avenue, Suite 400
+Wes
+Tel:
+Fax:
+To be used in lieu of A0110
+FORM ORD-227
+JAN.86
+
+
+ATTACHMENT TO GRAND JURY SUBPOENA OLY-67
+ADDRESSED TO CUSTODIAN OF RECORDS,
+LIVE NATION THEATRICAL/BROADWAY ACROSS AMERICA
+Request No.
+1
+Documents/Information Requested
+A copy of a Playbill or Program for any performances of David Copperfield at
+the Broward Center for the Performing Arts during the period of January 1,
+2004, through December 31, 2005
+(a) Jeffrey Epstein;
+(f) Lesley Groff;
+(g) Janusz Banasiak (or Banasiar);
+(h) Alfredo Rodriguez;
+
+
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500S. Australian Ave., Suite 400
+West Palm Beach, FL 33401-6235
+(561) 820-8711
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow
+an opportunity for any challenges to their
+authenticity. Therefore, you may be able to avoid appearing personally at the grand
+jury/trial at the time and place specified by completely filling out the attached Certification
+and Inventory and immediately returning it with the records to Special Agent
+, FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to July 10, 2007.
+Sincerely,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+BY:
+ASSISTANT UNITED STATES ATTORNEY
+
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+IN RE FEDERAL GRAND JURY SUBPOENA
+OLY-67 ADDRESSED TO
+LIVE NATION THEATRICAL/BROADWAY
+ACROSS AMERICA
+CERTIFICATION REGARDING DOMESTIC RECORDS
+OF REGULARLY CONDUCTED ACTIVITY
+I, the undersigned,
+› declare that I am employed by
+Live Nation Theatrical/Broadway Across America, in the position of
+→ and, by reason of my position, am authorized and qualified
+to make this declaration.
+1.
+Through my employment with Live Nation Theatrical/Broadway Across America,
+I am familiar with the business records it maintains.
+2.
+2.
+I certify that the records attached to this certification:
+(a)
+were made at or near the time of the occurrence of the matters set forth
+therein, by or from information transmitted by, a person with knowledge of
+those matters;
+(b)
+were kept in the course of regularly conducted business activity; and
+(c)
+were made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A
+(Document Inventory).
+
+
+
+3.
+I further certify that the documents attached hereto are responsive to the Grand Jury
+Subpoena served upon Live Nation Theatrical/Broadway Across America.
+Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing
+information is true and correct.
+Executed this
+day of
+_ 2007.
+Place of execution:
+Signature
+
+
+
+APPENDIX A
+DOCUMENT INVENTORY
+The documents submitted are as follows:
+Signature of Records Custodian:
+
+
+LIVE nATIOn
+Mary Mcintyre
+Litigation Paralegal
+July 10, 2007
+Via U.S. Mail and Facsimile
+Assistant United States Attorney
+500 S. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+Re:
+Live Nation / Broadway Across America
+Subpoena To Testify Before Grand Jury
+FGJ 07-103(WPB)-Tues./No. OLY-67
+Dear
+On July 2, 2007 Live Nation received the above-referenced subpoena seeking production
+of a playbill or program for certain David Copperfield performances and individual customer
+records for twelve persons for shows in 2004 - 2005. Live Nation has searched its files, and no
+records responsive to the subpoena were found.
+On July 5, 2007 I called and left a voicemail for
+at the investigation desk
+and also left a voicemail on
+Is direct line notifying them that Live
+Nation does not have any records responsive to the subpoena.
+If Live Nation can be of further assistance, please feel free to contact me.
+Sincerely,
+LIVE NATION.
+Mary Mantyre™
+Litigation Paralegal
+cc:
+Live Nation, Inc. | 9348 Civic Center Drive | Beverly Hills | California 90210
+Tel.: 310.975.6846 / Fax: 310.867.7190
diff --git a/vision-fixhub/ds9-unparsed-05/b72b3c223ce2150ee4ec96abce59b31ec82e01dedccee4285202d81f0dd19799.receipt.json b/vision-fixhub/ds9-unparsed-05/b72b3c223ce2150ee4ec96abce59b31ec82e01dedccee4285202d81f0dd19799.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..347eb51821c227f157d48759795f500c75da45d5
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b72b3c223ce2150ee4ec96abce59b31ec82e01dedccee4285202d81f0dd19799.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -118,
+  "dataset": "marble-joined",
+  "doc_id": "b72b3c223ce2150ee4ec96abce59b31ec82e01dedccee4285202d81f0dd19799",
+  "engine": "marble-apple-vision",
+  "event_count": 10,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "92028ed2908f2522e0e7765f414146bb4229ad341b3a6c95cb239aa58144553d",
+  "output_sha256": "60bb1016e834f606221657f0c708a07c0fb83a00c577dfca1e12ac4f6826342c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b77971ccee5131ce1aa47ff3e613d6b0e4f2e56f2172a2c0cebd35a07ec4910e.md b/vision-fixhub/ds9-unparsed-05/b77971ccee5131ce1aa47ff3e613d6b0e4f2e56f2172a2c0cebd35a07ec4910e.md
new file mode 100644
index 0000000000000000000000000000000000000000..3d9bb08f1bf97b3c9494fea736807d8a521c2350
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b77971ccee5131ce1aa47ff3e613d6b0e4f2e56f2172a2c0cebd35a07ec4910e.md
@@ -0,0 +1,43446 @@
+USAM 9-6.000 RELEASE AND DETENTION PENDING JUDICIAL PROCEEDINGS
+
+US Attorneys > USAM > Title 9
+prev | next | Criminal Resource Manual
+9-6.000
+RELEASE AND DETENTION
+PENDING JUDICIAL PROCEEDINGS -
+18 U.S.C. S$ 3141 ET SEQ.
+9-6.100 Introduction
+9-6.200 Pretrial Disclosure of Witness Identity
+9-6.100 Introduction
+The release and detention of defendants pending judicial proceedings is governed by the Due
+Process Clause of the Fifth Amendment, the Excessive Bail Clause of the Eighth Amendment, and the
+Bail Reform Act of 1984. The Bail Reform Act of 1984 provides procedures to detain a dangerous
+offender, as well as an offender who is likely to flee pending trial or appeal. See United States v.
+Salerno, 481 U.S. 739 (1987).
+For a discussion of the provisions of the Bail Reform Act of 1984 (18 U.S.C §§ 3141 et seq.) and
+related case law see the Criminal Resource Manual at 26.
+9-6.200 Pretrial Disclosure of Witness Identity
+Insuring the safety and cooperativeness of prospective witnesses, and safeguarding the judicial
+process from undue influence, are among the highest priorities of federal prosecutors. See the Victim
+and Witness Protection Act of 1982, P.L. 97-291, § 2, 96 Stat. 1248-9. The Attorney General Guidelines
+for Victim Witness Assistance 2000 provide that prosecutors should keep in mind that the names,
+addresses, and phone numbers of victims and witnesses are private and should reveal such information
+to the defense only pursuant to Federal Rule of Procedure 16, any local rules, customs or court orders, or
+special prosecutorial need.
+Therefore, it is the Department's position that pretrial disclosure of a witness' identity or statement
+should not be made if there is, in the judgment of the prosecutor, any reason to believe that such
+disclosure would endanger the safety of the witness or any other person, or lead to efforts to obstruct
+justice. Factors relevant to the possibility of witness intimidation or obstruction of justice include, but
+are not limited to, the types of charges pending against the defendant, any record or information about
+the propensity of the defendant or the defendant's confederates to engage in witness intimidation or
+obstruction of justice, and any threats directed by the defendant or others against the witness. In
+addition, pretrial disclosure of a witness' identity or statements should not ordinarily be made against the
+known wishes of any witness.
+However, pretrial disclosure of the identity or statements of a government witness may often
+http://www.usdoj.gov/usao/eousa/foia_reading_room/usam/title9/6mcrm.htm
+
+
+USAM 9-6.000 RELEASE AND DETENTION PENDING JUDICIAL PROCEEDINGS Page 2 of 2
+promote the prompt and just resolution of the case. Such disclosure may enhance the prospects that the
+defendant will plead guilty or lead to the initiation of plea negotiations; in the event the defendant goes
+to trial, such disclosure may expedite the conduct of the trial by eliminating the need for a continuance.
+Accordingly, with respect to prosecutions in federal court, a prosecutor should give careful
+consideration, as to each prospective witness, whether absent any indication of potential adverse
+consequences of the kind mentioned above reason exists to disclose such witness' identity prior to trial.
+It should be borne in mind that a decision by the prosecutor to disclose pretrial the identity of potential
+government witnesses may be conditioned upon the defendant's making reciprocal disclosure as to the
+identity of the potential defense witnesses. Similarly, when appropriate in light of the facts and
+circumstances of the case, a prosecutor may determine to disclose only the identity, but not the current
+address or whereabouts of a witness.
+Prosecutors should be aware that they have the option of applying for a protective order if
+discovery of the private information may create a risk of harm to the victim or witness and the
+prosecutor may seek a temporary restraining order under 18 U.S.C. § 1514 prohibiting harassment of a
+victim or witness.
+In sum, whether or not to disclose the identity of a witness prior to trial is committed to the
+discretion of the federal prosecutor, and that discretion should be exercised on a case-by-case, and
+witness-by-witness basis. Considerations of witness safety and willingness to cooperate, and the
+integrity of the judicial process are paramount.
+November 2000
+USAM Chapter 9-6
+http://www.usdoj.gov/usao/eousa/foia_reading_room/usam/title9/6mcrm.htm
+
+
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+USABook Online > Criminal Procedure > Sixth Circuit Desk Book > Chapter 7
+next | help | download
+Chapter 7
+Bail and Detention Issues
+I.
+The Bail Reform Act of 1984
+II.
+Release or Detention Pending Trial
+II.A.
+Generally
+II.B.
+Release on Personal Recognizance or Unsecured Appearance Bond
+II.C.
+Release on Conditions
+II.C.1. Generally
+II.C.2. Release on Secured Appearance Bond
+II.C.3. Release on Bail Bond with a Solvent Surety
+II.D. The Defendant's Failure to Appear
+II.E. Temporary Detention for Revocation of Conditional Release or Deportation
+II.F. Detention
+II.F.1. Generally
+II.F.2. Risk of Flight
+II.F.3. Dangerousness
+II.G. The Detention Hearing
+II.G.1. Hearing Procedures
+II.G.2. Criteria for Pretrial Release or Detention
+II.G.3. Content of Release or Detention Order
+II.G.4. Reopening the Detention Hearing
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+I.H. Review of Release/Detention Order by District Judge, Court of Appeals
+III. Release or Detention Pending Imposition or Execution of Sentence
+IV. Release or Detention Pending Appeal
+V.
+Release or Detention of Arrestees Other than Ordinary Defendants
+V.A. Probationers and Supervised Releasees
+V.B. Material Witnesses
+V.C. Aliens
+VI. Additional Resources
+I. The Bail Reform Act
+of 1984
+All things relating to bail in fede ral prosecutions are governed by the
+Bail Reform Act of 1984 (Act or 1984 Act) . In Reno v. Koray, 515 U.S. 50
+(1995), the Supreme Court explained:
+The Bail Reform Act of 1984 pr ovides a federal court with two
+choices when dealing with a crimina 1 defendant who has been "charged with
+an offense" and is awaiting trial,
+18 U.S.C. 5 3142(a), or who "has
+been found guilty of an offense and
+is awaiting imposition or
+execution of sentence," 18 U.S.C. § 3143(a) (1) (1988 ed., Supp. V) .
+The court may either (1) "release" the defendant on bail or (2) order him
+"detained" without bail. A court m ay "release" a defendant subject to a
+variety of restrictive conditions, including residence in a community
+treatment center. See 55 3142 (c) (1) (B) (i), (x), and
+(xiv). If, however, the court "fin de that no condition or combination of
+conditions will reasonably assure t he appearance of the person as required
+and the safety of any other person and the community," § 3142(e), the
+court "shall order the detention of the person," ibid., by issuing
+a "detention order" "direct [ing) th at the person be committed to the
+custody of the Attorney General for confinement in a corrections
+facility," § 3142(i) (2). Thus, under the language of t he Bail Reform
+Act of 1984, a defendant suffers "d etention" only when committed [by the
+district court] to the custody of t he Attorney General; a defendant
+admitted to bail on restrictive con ditions, as respondent was, is
+"released."
+515 U.S. at 57 (citations omitted); see also 18 U.S.C § 3141(a) ("A
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+judicial officer [i.e., federal magistrat e judge or district judge]
+bèfore whom an arrested person is brought shall order that such person be
+released or detained, pending [further] judicial proceedings, under this
+[Act].").
+The 1984 Act completely superseded the Bail Reform Act of 1966 and funda -
+mentally changed the law.
+"It transforme d preexisting practice in very |
+significant ways, providing among other t hings for the pretrial detention of
+persons charged with certain serious felo nies on the ground of dangerousness
+a ground theretofore not cognizable."
+United States v. Tortora, 922 F.2d
+B80, 884 (Ist Cir. 1990). | FN1] As a technical matter, the 1984 Act ad ded
+sections 3062 and 3141-3150 to Title 18 of the U.S. Code, and it repealed then
+existing sections 3043 and 3141-3151. The 1984 Act also amended 18 U.S.C •
+55 3041, 3042, 3154, 3156, 3731, 3772, and 4 282; 28 U.S.C. § 636;
+Fed. R. Crim. P. 5, 15, 40, 46, and 54; a nd Fed. R. App. P. 9.
+II. Release or Detention Pending Trial
+A. Generally
+A person arrested for a federal off ense must be brought "without
+unnecessary delay before the nearest avai lable federal magistrate judge" for his
+initial appearance.
+Fed. R. Crim. P. 5(a ), 9(c)(1). At this proceeding, the
+magistrate judge "shall," among other thi ngs, "detain or conditionally release
+the defendant as provided by statute or i n these rules." Fed. R. Crim. P. 5(c).
+Rule 46, captioned "Release from Custody, " provides that "[elligibility for
+release prior to trial shall be in accord ance with 18 U.S.C. §S 3142
+and 3144." Fed. R. Crim. P. 46(a). Sect ions 3142 and 3144 are a part of the
+Bail Reform Act of 1984 (1984 Act).
+Under the 1984 Act, the magistrate judge "shall" order that a "person
+charged with an offense" be
+(1)
+released on personal recogniza nce or upon execution of an unsecured
+appearance bond, under subsect ion (b) of this section;
+released on a condition or com bination of conditions under
+subsection (c) of this section ;
+temporarily detained to permit revocation of conditional release,
+deportation, or exclusion unde I subsection (d) of this section; or
+(4) detained under subsection (e) of this section.
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+18 U.s.C. § 3142 (a).
+In figuring out which option to pic k, the magistrate judge relies
+--
+at
+the U.S. Pretria 1 Services Agency.
+See 18 U.S.C. S5 3152-3154 (establishing Pretrial Services
+Agency in every judicial district and pre scribing duties); E.D. Mich. Local Crim.
+R. 5.1(b), 10.1(b). This recommendation is the result of a Pretrial Services
+Officer's (1) interview of the defendant, (2) receipt of information from the
+government and defense counsel, and (3)
+i ndependent (though brief and necessarily
+necessarily
+cursory) investigation of the defendant's residential, familial, and employment
+situations. The recommendation is usuall y made in writing (in a report rarely
+longer than 4 pages with a radioactive o range cover sheet), but it is not
+uncommon for the recommendation to be mad e orally in open court because there was
+insufficient time for the Pretrial Servic es Officer to prepare a written report.
+These recommendations typically carry som e weight with the magistrate judges, but
+are not controlling. Remember that the P retrial Services Officer will usually
+not know anything about the specifics of
+the offense or the dangerousness of the
+defendant unless those facts are made pla in in the charging document or you
+provide this information to the officer.
+Thus, in any case in which the
+government is seeking detention or restri ctive conditions of release, the AUSA
+should contact the Pretrial Services Offi cer early in the process to make sure
+that she has all of the available informa tion about both the crimes alleged and
+history of violence, jumping bail. and
+drug or alcohol
+abuse, (3) employment sit uation and history.
+(4) assets, (5)
+domestic situation and recent residential history, and (6) anything else that is
+relevant.
+B. Release on Personal Recognizance or an Unsecured Appearance Bond
+"Release on personal recognizance," 18 U.S.C. § 3142(b) (caption).
+means release on the following conditions : (1) that the defendant promise to
+appear at all subsequent judicial proceed ings [FN2] and (2) that he "not commit
+a Federal, State, or local crime," id.
+"Release on
+means release on the following conditions : (1) that the defendant promise to
+appear at all subsequent judicial proceed ings; (2) that he not commit another
+crime, id.; and (3) that he execute "an unsecured appearance bond in an
+amount specified by the court," id. A bond is a promise, see
+lack's Law Dictionary _
+. (Bryan A. Garn er ed., 7th ed. 1999), and an unsecured
+appearance bond is "[a] bond that holds a defendant liable for a breach of the
+bond's conditions (such as failure to app ear in court), but that is not secured
+http://10.173.2.12/usao/cousa/ole/usabook/desk/07desk.htm
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+by a deposit of or lien on property, " id. at 170.
+Thus, if ordered
+released on an unsecured bond, the defend ant need not put up any money. His
+signing an unsecured appearance bond in t he amount of, say, $10,000, simply means
+that he agrees to forfeit $10,000 to the court if he fails to appear for a
+our it he tally to spear for ay mean
+judicial proceeding.
+C. Release on Conditions
+1. General ly
+If the court believes that release on personal recognizance or an unsecured
+appearance bond is inadequate to the task , it may order the defendant's release
+on certain additional conditions.
+See 18 U.S.C. § 3142 (c) (1) (B) .
+"Release on conditions," id. § 3142(c) (caption), means release on
+the following conditions: (1) that he pro mise to appear at all subsequent
+judicial proceedings; (2) that he not com mit another crime; and (3) that he be
+"subject to the least restrictive further condition, or combination of
+conditions, that such judicial officer de termines will reasonably assure the
+of the person as required and| /or] the safety of any other person and
+the conmunityl.]" 18 U.S.C. § 3142(c).
+Section 3142(c) (1) (B) lists the
+additional conditions of pretrial release that the court may impose, including
+a catch-all for "any other condition that is reas onably necessary to assure the
+appearance of the person as required and to assure the safety of any other person
+and the community."
+§ 3142 (c) (1) (B) (xiv). Some of the more
+commonly used conditions require that def endants report as directed to their
+Pretrial Services Officers,
+stay within a specific geographical area (e.g., the
+State of Michigan, metropolitan Detroit ( specifying certain counties), surrender
+their passports, reside in specific house s or apartments, be electronically
+tethered to their houses ("home detention "), remain in the "custody" of a third
+party (e.g., uncle Sam, granny), seek or maintain employment, or submit to drug
+testing and treatment.
+With respect to financial condition s of release, the court may decide that
+an unsecured appearance bond is not enoug h to "reasonably assure the appearance
+of the person as required and[/or] the sa fety of any other person and the
+communityl.]" and that the defendant shou ld also have to make a firmer financial
+commitment to the court. The COURT may o rder either one of two additional
+financial conditions: first, the court ma y order the defendant to execute a
+secured appearance bond and put up some P roperty as the security; second, the
+court may order the defendant to execute a bail bond with a solvent surety.
+If the defendant violates any condi tion of his pretrial release, he could
+be "subject to a revocation of release, a n order of detention, and a prosecution
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+for contempt of court. " U.S.C. U.S.C. $ 3148(a).
+2. Release on Secured Appearance Bond
+A secured appearance bond, see 18 U.S.C. § 3142 (c) (1) (B) (xi),
+is an unsecured appearance bond
+that requ ires security in the form of personal
+or real property that is specified by the court.
+If the collateral for a secured
+appearance bond is cash, often referred t o as a "cash bond," the defendant must
+deposit the "cash" with the clerk's offic e. In this district,
+"cash" may take
+the form of "cash, [a] money order, or la | cashier's check made payable to
+'Clerk, United States District Court.'" E .D. Local Crim. R. 46.1(b) (1). A "VISA
+or MasterCard credit card is [also] accep table for a cash bond." Id.
+If the collateral for a secured app earance bond is property other than
+cash, the magistrate judge must obtain th e prior approval of a district judge.
+See E.D. Local Crim. R. 46.1(b) (2) ("Unless approved in writing by a
+District Judge, property [other than cash ] shall not be accepted as collateral
+for a bond."). A defendant seeking relea se on an appearance bond secured by non -
+cash property "shall provide the court wi th proof of ownership and the value of
+the property along with information regar ding existing encumbrances as the
+judicial office may require."
+18 U.S.C. § 3142 (c) (1) (B) (xi).
+ordinarily opposes the use of non -cash property to collateralize an appeara nce
+bond. [FN3]|
+To prevent property constituting or derived from criminal proceeds from
+serving as collateral for an appearance b ond, the 1984 Act provides:
+In considering the conditions of re lease described in subsection
+(c) (1) (B) (xi) or (c) (1) (B) (xii) of this section, the judicial officer may
+upon his own motion, or shall upon the motion of the Government, conduct
+an inquiry into the source of the p roperty to be designated for potential
+forfeiture or offered as collateral to secure a bond, and shall decline to
+accept the designation, or the use as collateral, of property that,
+because of its source, will not rea sonably assure the appearance of the
+person as required.
+18 U.S.C. § 3142(g). This section codifies the rule of United States v.
+Nebbia, 357 F.2d 303 (2d Cir. 1966), in which t he Second Circuit held that
+a district court has the authority to in quire into the source of a large cash
+bond (a $100,000 cashier's check). The Nebbia court noted that "the mere
+deposit of cash bail is not sufficient to deprive the court of the right to
+inquire into other factors which might be ar on the question of the adequacy of
+the bail.. "
+Id. at 304.
+Of course, cash and non-cash property
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+representing or derived from criminal pro ceeds are not likely to assure the
+appearance of the defendant, who will oft en be all too happy to abandon such
+property as the cost of doing business.
+Thus, if indicated, the AUSA should request the court to examine whether
+the proposed collateral for an appearance bond is derived from criminal proceeds.
+Depending on the evidence produced at the hearing, called a "Nebbia
+ало а нер росе».
+hearing," the court could refuse to accep t the defendant's proposed collateral
+or the proposed surety. And whatever the
+court's decision turns out to be, if the
+AUSA believes that the collateral is "dir ty," she should consult with the Asset
+Forfeiture Unit of this office's Civil Di vision to assess the likelihood that the
+collateral (whether cash or non -cash property) could be subject to crimin al or
+civil forfeiture under 18 U.S.C. S5 981, 982 or 21 U.S.C. 55
+853, 881-
+3. Release on Bail Bond wit h a Solvent Surety
+A "bail bond with solvent sureties, " 18 U.S.C. § 3142 (c) (1) (B) (xii),
+is the other harsher financial alternativ e to an unsecured appearance bond. A
+bail bond with a solvent surety, also cal led a "surety bond," is basically a
+three-party agreement involving, naturally, a t hird party, the surety. FN4] The
+defendant "execute[s] a bail bond with [a l solvent suret[yl," and the solvent
+surety "execute [s] an agreement [with the court] to forfeit [to the court]
+such
+amount as is reasonably necessary to assu re appearance of the person as
+required." Id. [FN5] Thus, if the court sets a surety bond in the amount
+of $100,000, and if the defendant thereaf ter fails
+to appear at a judicial
+proceeding, the surety must pay the court $100,000.
+Most sureties are corporations esta blished to engage in the business of
+bailing people out. Corporate sureties,
+like most service providers, charge
+their customers a fee.
+Defendants in thi s district may use only those corporate
+sureties that have been approved by the d istrict court.
+For the court to approve of the use of a non-corporate surety, it must be
+satisfied of the surety's solvency. Rule 46 provides in relevant part:
+(d) Justification of Sureties.
+Every surety, except a corporate
+surety which is approved as provide d by law, shall justify by affidavit
+and may be required to describe in the affidavit the property by which the
+surety proposes to justify and the encumbrances thereon, the number and
+amount of other bonds and undertaki ngs for bail entered into by the surety
+and remaining undischarged and all the other liabilities of the surety. No
+bond shall be approved unless the s urety thereon appears to be qualified.
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+Fed. R. Crim. P. 46(d). Similarly, the 1 984 Act directs that a surety
+shall provide the court with inform ation regarding the value of the assets
+and liabilities of the surety if ot her than an approved surety and the
+nature and extent of encumbrances a gainst the surety's property; such
+surety shall have a net worth which shall have sufficient unencumbered
+value to pay the amount of the bail bond;
+18 U.S.C. $ 3142 (c) (1) (B) (xii).
+In United States v. Nebbia, 357 F.2d 303 (2d Cir. 1966), the Second
+Circuit observed that a district court ma y reject a surety "'[ilf the court lacks
+confidence in the surety's purpose or abi lity to secure the appearance of a
+e out lacks
+bailed defendant.'" Id. at 304. Thus, if indicated, the AUSA sh ould
+request the court to examine whether the defendant's proposed surety is
+sufficiently reliable and solvent. Depen ding on the evidence produced at the
+Nebbia hearing, the court could reject the prop osed surety.
+D. The Defendant's Failure to Appear
+If the court releases the defendant pending trial on an unsecured
+appearance bond, a secured appearance bon d, or a surety bond, and the defendant
+thereafter fails to appear for a judicial proceeding, the government should move
+for and "the district court shall declare a forfeiture of the bail." Fed.
+R. Crim. P. 46(e) (e)(1); see also 18 U.S.C. § 3146(d) ("judicial officer
+may .
+• declare any property designate d [as bail] to be forfeited
+to the United States"). To be useful, th e declaration of forfeiture must be
+followed by the entry of a civil judgment in favor of the government. But if the
+defendant surrenders himself or is arrest ed and dragged in by his suretyl[ FN6]]
+before entry of the judgment, "[t]he cour t may direct that [the] forfeiture be
+set aside in whole or in part, upon such
+conditions as the court may impose."
+Fed. R. Crim. P. 46 (e) (2). If the defend ant does not reappear, "the court shall
+on motion [of the government] enter a jud gment of default and execution may issue
+thereon." Fed. R. Crim. P. 46 (e) (3) .
+under A judgment for the government is en forced by the Financial litigation Unit
+under the Federal Debt Collection Procedu res Act of 1990.
+See
+28 U.S.C.
+$ 3201-3206 (relating to government's "postjudgm ent remedies"). If the
+defendant reappears "[alfter entry of such judgment, the court may remit it in
+whole or in part." Fed. R. Crim. P. 46(e ) (4).
+"When the condition of the bond
+has been satisfied or the forfeiture ther eof has been set aside or remitted, the
+court shall exonerate the obligors and re lease any bail. A surety may be
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+exonerated by a deposit of cash in the am ount of the bond or by a timely
+surrender of the defendant into custody." Fed. R. Crim. P. 46(f) .
+The defendant's failure to appear h as serious nonfinancial consequences as
+well. Once the defendant is apprehended,
+he could be made "subject to a
+separate offense of bondjumping. See id. § 3146.
+E. Temporary Detention for Revocation of Conditional Release or Deportation
+Temporary detention is a limited pe riod of detention -- no more than 10
+business days -- that can be ordered only in certain limit ed circumstances.
+Temporary detention "shall" be ordered if
+* the defendant is on release pending trial in another criminal case (state
+or federal) that involves a felony; on release pending imposition or
+execution of sentence or pending ap peal in another criminal case; on
+probation or released on parole in another criminal case, and
+* "the person may flee or pose a dang er to any other person or the
+community." 18 U.S.C. 55 3142 (d) (1) (A), (2).
+Temporary detention "shall" also be order ed if
+* the defendant is neither a U.S. cit izen nor a permanent resident alien
+(i.e. someone with a "green card"), and
+* "the person may flee or pose a dang er to any other person or the
+community." 18 U.S.C. 55 3142 (d) (1) (B), (2).
+During the period of temporary detention, the AUSA must
+notify the appropriate court, proba tion or parole official, or State or
+local law enforcement official, or the appropriate official of the
+Immigration and Naturalization Serv ice. If the official fails or declines
+to take such person into custody du ring that period, such person shall be
+treated in accordance with the othe r provisions of this section,
+notwithstanding the applicability o f other provisions of law governing
+release pending trial or deportatio n or exclusion proceedings.
+18 U.S.C. § 3142(d). "Such person shall be treated i n accordance with the
+other provisions of this section" simply means that the magistrate judge must
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+order that the defendant be released (wit h or without conditions) or detained
+pending further judicial proceeding based
+on the criteria applicable to ordinary
+defendants.
+F. Detention
+1.
+General ly
+Although there is a general presump tion in favor of pretrial release, the
+1984 Act provides that the magistrate jud ge "shall" order that the defendant be
+detained pending trial
+[ilf, after a hearing pursuant to t he provisions of [section 3142(f)], the
+[magistrate judge]
+finds that no condition or combination of conditions
+will reasonably assure the appearan ce of the person as required and the
+safety of any other person and the community.
+18 U.S.C. § 3142(e). Thus, a defendant may be detain ed because he
+represents an unacceptable risk of flight or an unacceptable danger to
+specific individuals or to the community at large. The AUSA should make clear
+to the court which basis for detention th e government is relying on, or that it
+is relying on both.
+2. Risk of Fl ight
+The 1984 Act authorizes the court t o order pretrial detention if there is
+"a serious risk that the [defendant] will flee."
+'he government must establish risk of fli ght by a preponderance of the evidence
+ee, e.g.. United States | Mercedes ,
+* 111 g0
+18 U.S.C. $ 3142(£) (2) (A) .
+2001) ("The government retains the ultima te burden of persuasion by the lesser
+¡tandard of a preponderance|
+: the eviden ce that the defendant presents a risk
+£ flight."); United States •| Gebro, 948 F.2d 1118, 1121 (9th Cir. 1991)
+(per curiam) ("On a motion for pretrial detention, the government bears the
+burden of showing by a preponderance of t he evidence that the defendant poses a
+F.2d 34, 37 (6th Cir. 1985) ("Nor has the |
+government distinguished between flight
+and dangerousness, although as we read se ction 3142(f), the clear and convincing
+standard applies only to the latter.").
+The 1984 Act creates a rebuttable p resumption in favor of detention based
+on risk of flight
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+• if the judicial officer finds that there is probable cause to believe that
+the person committed an offense for
+which a maximum term of imprisonment
+of ten years or more is prescribed in the Controlled Substances Act (21
+U.S.C. 801 et seg.), the Controlled Substances Import and Export Act (21
+401 et oeg.), the Controle
+U.S.C. 951 et seg.), the Maritime D rug Law Enforcement Act (46 U.S.C. App.
+cantoned y
+1901 et seq.), or an offense under
+section 924 (c) [using or carrying
+firearm in relation to crime of vio lence or drug trafficking crimel,
+956 (a) [conspiracy to kill, kidnap,
+etc. in a foreign countryl, or 2332b
+[terrorism across international bou ndaries] of title 18 of the United
+States Code.
+18 U.S.C. § 3142(e) .
+The principal risk-of-flight considerations are whether the def endant (1)
+has substantial ties to the local communi ty (employment, spouse, children,
+ownership of business, real estate, or ot her nonportable assets, etc.); (2) has
+failed to appear in court in another crim inal case; (3) has a genuine incentive
+to flee (high likelihood of conviction, e xposure to long prison term, likelihood
+of bad collateral consequences in other c riminal cases, fear of retribution from
+victims, etc.), and (4) has a mental dise ase or defect (too drunk, drug -addled,
+paranoid, schizoid, etc. to control own b ehavior). See 18 U.S.C. S
+3142 (g) .
+3. Dangerous ness
+The 1984 Act authorizes the court to order pretrial detention on the basis
+of dangerousness if (1) the defendant is
+charged with a "crime of violence," [ FN7]
+a capital offense, or a drug offense carr ying a maximum term of imprisonment of
+10 years or more, and (2) "no condition or combination of
+conditions or [pretrial release] will rea sonably assure . . . the safety of any
+other person and the community." 18 U.S. C. S5 3142(e), (f). The
+the safety of any
+government must establish the defendant's dangerousness "by clear and convincing
+see also, e.g.. United States
+I dance. 762 F.23134, 37 see d1r. 199) United sea the government.
+distinguished between flight and dangerou sness, although as we read section
+3142(f), the clear and convincing standar d applies only to the latter.")..
+The 1984 Act also authorizes the co urt to order pretrial detention in
+any case if there is "a serious risk that su ch person will obstruct or
+attempt to obstruct justice, or threaten, injure, or intimidate, or attempt to
+threaten, injure, or intimidate, a prospe ctive witness or juror." 18 U.S.C.
+$ 3142 (f) (2) (B).
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+The Act creates a rebuttable presum ption in favor of detention based
+on dangerousness in two situations. The first is when the judicial officer
+finds that there is probable cause to bel ieve that the person committed
+the charged offense and the charged offense is an offense for which a
+maximum term of imprisonment of ten years or more is prescribed in the
+Controlled Substances Act (21 U.S.C. 801 et seg.), the Controlled
+Substances Import and Export Act (2 1 U.S.C. 951 et seg.), the Maritime
+Drug Law Enforcement Act (46 U.S.C. App. 1901 et seq.), or an offense
+under section 924 (c) [using or carr ying firearm in relation to crime
+of violence or drug trafficking cri mel, 956(a) [conspiracy to kill,
+kidnap, etc. in a foreign countryl, or 2332b [terrorism across
+international boundaries] of title
+18 of the United States Code.
+18 U.S.C. § 3142(e) .
+The second situation giving rise to a rebuttable presumption of
+dangerousness, also described in Section 3142(e), is
+when it is determined that a person charged with a seriously dangerous
+offense has in the past been convic ted of committing another serious crime
+vor . Sun an a to try ok pre-erial criminality sa. aber
+of 10 years or more). Such a histo ry of pre-trial criminality is, absent
+mitigating information, a rational basis for concluding that a defendant
+poses a significant threat to commu nity safety and that he cannot be
+trusted to conform to the requireme nts of the law while on release.
+S. Rep. No. 98-225, at 4 (1984), reprinted in 1984 U.S.C.C.A.N. 3182,
+See 18 U.S.C. § 3142(e).
+This rebuttable presumption does not
+arise, however, if the period beginning w ith the date of defendant's prior
+conviction or the date of his release fro m imprisonment for that conviction,
+whichever is later, and the date of the detention hearing exceeds five years.
+Id. S 3142 (e) (3) .
+G. The Detention Hearing
+Before issuing an order of pretrial detention, the magistrate judge must
+conduct a detention hearing. See 18 U.S.C. 55 3142(e), (f) .
+1. Hearing Proc edures
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+The 1984 Act requires that the dete ntion hearing be held "immediately upon
+the person's first appearance before the judicial officer," id. §
+3142(f), but it also entitles the governm ent to a continuance of the hearing for
+at least one but no more than three busin ess days, and entitles the defendant to
+a continuance of at least one but no more than five business days, id.
+$ 3142 (f) (2). "[Flor good cause," the magistrate judge may grant either
+party a longer continuance. Id. "During [thel continuance, [the
+defendant] shall be detained .
+."
+Id. [FN8] However, once the
+detention hearing begins, the defendant " may be detained pending
+completion of the hearing." Id.
+In practice, the magistrate judges in our district usually grant
+continuances to the government only if th e AUSA makes a factual proffer
+establishing a basis for detention author ized by the 1984 Act, and the
+continuances that are granted are usually for only one or two days. If the
+government fails to make an adequate prof fer, the magistrate judge may well start
+the detention hearing immediately and rel ease the defendant pending completion
+of the hearing.
+"The rules concerning admissibility of evidence in criminal trials do not
+apply to the presentation and considerati on of information at (a detention]
+hearing."
+18 U.S.C.
+§ 3142 (f) .
+Thus, hearsay is admissible.
+also Fed. R. Evid. 1101(d) (3) (FRE do not app ly to "proceedings with respect
+to release on bail or otherwise").
+With respect to due process, the 19 84 Act provides:
+22E2
+At the hearing, such person has the right to be represented by counsel,
+and, if financially unable to obtai n adequate representation, to have
+counsel appointed. The person shal 1 be afforded an opportunity to
+- examine witnesses who appear at
+the hearing, and to present informa tion by proffer or otherwise.
+18 U.S.C. § 3142 (£).
+The government's presentation of ev idence typically consists of the
+testimony of the case agent (who is the g overnment's sole or principal witness).
+and/or a proffer of evidence made by the AUSA. The evidence will also
+automatically include the report of the P retrial Services Officer.
+The Jencks Act, now codified at Fed. R. Crim. P. 26.2, applies to detention
+hearings. See Fed. R. Crim. P. 26.2(g) (3), 46(i). This means that each
+party must disclose to the other party th e prior statements of its witnesses, if
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+any. Although a witness's prior statemen ts are not required to be
+disclosed until after the witness testifi es on direct examination,
+Fed. R. Crim. P. 26.2(a), the magistrate judge will likely be irritated if the
+government fails to disclose witness stat ements before the hearing begins.
+Criteria for Pretrial Rel ease or Detention
+The Act sets forth the criteria by which the court (usually the magistrate
+judge) must decide the question of pretri al release or detention.
+3142(g) provides that the court
+shall .. take into account t he available information concerning
+--
+(1) The nature and circumstances of the o ffense charged, including
+whether the offense is a crime of V iolence or involves a narcotic drug;
+(2) the weight of the evidence aga inst the person;
+(3) the history and characteristic s of the person, including --
+ties employment, ananda resca, length of residence in the
+re sources, length of residence in the
+community, community ties, pas t conduct, history relating to drug or
+alcohol abuse, criminal histor y, and record concerning appearance at
+court proceedings; and
+(B) whether, at the time of th e current offense or arrest, the
+person was on probation, on pa role, or on other release pending
+trial, sentencing, appeal, or completion of sentence for an offense
+under Federal, State, or local law; and
+(4) the nature and seriousness of the danger to any person or the com -
+munity that would be posed by the person' s release.
+18 U.S.C. § 3142(g) .
+3. Content of Release or Detention Order
+If at the conclusion of the hearing the court orders that the defendant be
+released pending trial, the order "shall
+include a written statement
+that sets forth all the conditions to whi ch the release is subject, in a manner
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+sufficiently clear and specific to serve as a guide for the person's conduct."
+18- U.S.C. § 3142(h) (1).
+If, instead, the court orders that the defendant be detained pending trial,
+the order "shall
+include writte n findings of fact and a written
+statement of the reasons for the detentio n."
+Id. $ 3142 (i) (1);
+see also Fed. R. App. P. 9(a) (1) ("The district c ourt must state in
+writing, or orally on the record, the rea sons for an order regarding the release
+or detention of a defendant in a criminal
+case.").
+4. Reopening the Detention Hearing
+A detention
+hearing may be reopened before or a fter a determination by the judicial
+officer, at any time before trial i f the judicial officer finds that
+information exists that was not kno wn to the movant at the time of the
+hearing and that has a material bea ring on the issue whether there are
+conditions of release that will rea sonably assure the appearance of such
+person as required and the safety o f any other person and the community.
+18 U.S.C. § 3142(£).
+"The judicial officer may at an y time amend the order
+[of release on conditions] to impose addi tional or different conditions."
+Id. 5 3142 (c) (3) .
+H. Review of Release/Detention Order by District Judge, Court of Appeals
+Detention hearings in this district are invariably conducted by magistrate
+judges.
+See Fed. R. Crim. P. 5(c) (at in itial appearance, "magistrate judge . . .
+shall detain or conditionally release the defendant"); 28 U.S.C. §
+636 (a) (2) (conferring on magistrate judge s "power to . .
+• issue orders
+pursuant to section 3142 of title 18 conc erning release or detention of
+persons pending trial"). A magistrate ju dge's order of pretrial release or
+detention must be reviewed by a district judge if eithe r party moves
+for such review. See 18 U.S.C. S5 3145(a), (b). If the
+magistrate judge enters an order of relea se, "(1) the attorney for the
+Government may file
+a motion for revocation of the order or
+amendment of the conditions of release; a nd (2) the [defendant] may file . . .
+a motion for amendment of the conditions of release." 18 U.S.C.
+S 3145(a). If the magistrate judge enters an order of detention, "the
+[defendant] may file a motion for revocat ion or amendment of the order" Id.
+$ 3145(b). A motion filed by the governmen t or the defendant "shall be
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+determined promptly." Id.
+If the AUSA believes that a magistr ate judge's order of pretrial release
+should be reviewed by a district judge, s he should contact the court clerk of the
+appropriate district judge immediately to schedule the review hearing.
+charging instrument is a complaint, the reviewer is the presiding district judge-
+See E.D. Mich. Local Crim. R. 57.2, Local R. 77.2(a). If the charging
+instrument is an indictment,
+the reviewer is the district judge to whom the case
+was assigned, or if that judge is unavail able, the presiding district judge,
+see E.D. Mich. Local R. 77.2(b).
+The fact that under the 1984 Act th e government has the right to
+have a magistrate judge's order of releas e reviewed by a district judge,
+see 18 U.S.C. § 3145(a), implies that the magistrate judg e's order
+of release should be stayed pending revie w of the order by a district judge. |
+In
+United States v. Huckabay, 707 F. Supp. 35 (E.D. Pa. 1989), the ma gistrate
+judge ordered pretrial release but detain ed the defendant pending review by a
+district judge, explaining that "'an appe al of the magistrate's release order
+after a motion for detention has been fil ed at the initial appearance, by
+statutory implication, authorizes the jud icial officer [i.e., the magistrate
+judge] to stay the release order to allow
+the court having original jurisdiction
+[i.e., the district judge] to pass upon t he detention issue.'"
+Id. at 36.
+The district judge agreed, observing that
+"[r]equiring release pending review by
+the district court could frustrate the ve ry purpose of review."
+Id. at
+37. If the magistrate judge refuses to s tay her order of release, the AUSA
+should request a stay from the district j udge.
+The AUSA should make sure that the district judge has a copy of the audio
+"shall be determined promptly" by the dis trict judge. 18 U.S.C. § 3145(a) .
+Some district judges will conduct the hea ring on the same day; others will wait
+for another day or two.
+The AUSA should order an expedited transcript of the
+hearing before the magistrate judge (afte r obtaining the approval of the Criminal
+Chief). Some judges will not conduct the ir review until a transcript is
+available.
+The district judge's review of a ma gistrate judge's decision is de
+novo. [FN9] The district judge, therefore, may rel y entirely on the record
+that was before the magistrate judge, or he may expand the record by conducting
+a limited or full-blown hearing. The AUSA should be prepar ed to present live
+witnesses at such a hearing. At the conc lusion of his review, the district judge
+will enter an order of pretrial detention or release, and he "must state in
+http://10.173.2.12/usao/cousa/ole/usabook/desk/07desk.htm
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+writing, or orally on the record, the rea sons for [that] order." Fed. R. App.
+P.'9 (a) (1); see also 18 U.S.C. § 3142 (i) (1).
+If the district judge issues an or der of pretrial release, the government
+may appeal the order to the U.S. Court of Appeals for the Sixth Circuit.
+See 18 U.S.C. S 3145(c); Fed. R. App. P. 9(a) .
+The AUSA should
+contact her supervisor and the Appellate Chief immediately to discuss this
+option. A government appeal of an order of release, like its appeal of any other
+order or judgment of the district court,
+must be approved by the Appellate Chief,
+the United States Attorney, and the Solic itor General of the United States. "The
+appeal should be determined promptly." 1 8 U.S.C. § 3145(c); see also
+Fed. R. App. P. 9(a) (2) .
+III. Release or Detention Pending Imposi tion or Execution of Sentence
+Once a defendant has been convicted , the 1984 Act tilts the playing field
+toward detention. It provides:
+The judicial officer shall order th at [a convicted defendant]
+... be
+detained, unless the judicial offic er finds by clear and convincing
+evidence that the person is not lik ely to flee or pose a danger to the
+safety of any other person or the c ommunity if released under section
+3142 (b) or (c). If the judicial off icer makes such a finding, such
+judicial officer shall order the re lease of the person in accordance with
+section 3142 (b) or (c).
+18 U.S.C. § 3143(a) (1). In practice, the government,
+at least in this
+district, often permits a convicted defen dant to remain free pending the
+imposition of sentence or the execution o f sentence following its
+imposition. [FN10] This generally occurs in cases where a
+defendant on pretrial
+release pleads guilty, or where a defenda nt on pretrial release is convicted at
+trial and the AUSA is not really concerne d about the risk of flight or danger to
+others posed by the defendant. Of course , the AUSA should insist that the court
+comply with Section 3143(a) when circumst ances indicate that detention pending
+sentencing or service of sentence would b e prudent.
+If a defendant is convicted of a sp ecified serious offense, the presumption
+of detention is even stronger.
+The speci fied offenses are "crime[s] of
+violence," capital offenses, and drug off enses carrying a maximum term of
+imprisonment of 10 years or more. 18 U.S .C. § 3143(a) (2). Such a defendant
+"shall"
+be detained unless --
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+(A) (i)
+the judicial officer finds ther
+e is a substantial likelihood
+that a motion for acquit tal or
+new trial will be granted; or
+(ii)
+an attorney for the Government has recommended that no
+sentence of imprisonment
+be imposed on the person; and
+(B) the judicial officer finds by clear and convincing evidence that the
+person is not likely to flee o r pose a danger to any other person or
+the community.
+18 U.S.C. § 3143 (a) (2) .
+IV. Release or Detention Pending Appeal
+The 1984 Act sets forth a presumpti on of detention when a defendant who has
+been sentenced to a term of imprisonment
+files an appeal.
+See 18 U.S.C.
+5 3143 (b)./
+Ordinarily, the presumption is
+rebuttable, and the burden is on
+the defendant to establish by clear and convincing evidence that he should be
+released pending appeal. See id. § 3143 (b) (1) (defendant must show |
+that he is not likely to flee or pose a d anger to any other person or the
+community, and that the appeal will likel y result in the reversal of his
+conviction or the vacation of his prison term). If, however, the defendant has
+been convicted of and sentenced for a "c rime of violence," a capital offense,
+or a drug offense carrying a maximum term of imprisonment of 10 years or more,
+the presumption of detention is irrebutta ble. See id. § 3143 (b) (2) .
+V. Release or Detention of Arrestees Oth er than Ordinary Defendants
+A. Probationers and Supervised Releasees
+A defendant arrested for a violatio n of probation or supervised release
+"may be released pursuant to Rule 46(c) p ending the revocation hearing." Fed.
+R. Crim. P. 32.1 (a) (1).
+Rule 46(c) says that release or detention "shall be in
+accordance with 18 U.S.C. 5 3143." Fed. R. Crim. P. 46(c).
+governs the release or detention of convi cted defendants awaiting the imposition
+is deten 3103 of cod.
+Section 3143 (a)
+or execution of sentence.
+See supra pp. 17-18.
+B. Material Witnesses
+A provision of the 1984 Act deals w ith material witnesses, see 18
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+U.S.C. $ 3144, who are individuals whose presence at trial "may become
+impracticable to secure .
+• • by subpoena
+•" Many material witnesses are aliens
+whose whereabouts at the time of trial wi 1l be a foreign country or unknown.
+Basically, a material witness may be arre sted on a material witness complaint and
+warrant issued by the court, and then det ained until his testimony can be secured
+by deposition.
+See id.; Fed. R. Crim. P. 15(a); see also,
+e.g., Torres-Ruiz v. United States District Court , 120 F.3d 933, 934 -
+36 (9th Cir. 1997) (per curiam).
+C. Aliens
+Aliens may be subject to "temporary detention" for up to 10 days to allow
+for the notification of INS and the defen dant's transfer to INS for
+administrative deportation proceedings.
+See 18 U.S.C. ss
+3142 (d) (1) (B), (2); supra p. 9.
+VI. Additional Resources
+* Annual Review of Criminal Procedure (Part II: Preliminary
+Proceedings (Bail) , Georgetown Law Journal.
+* 27 Moore's Federal Practice ch . 646 (3d ed., looseleaf service
+updated annually) .
+3A Charles Alan Wright, Federa 1 Practice and Procedure 55
+761-778 (2d ed. Supp. 2001).
+* David Marshall Nissman, Proving Federal Crimes ch. 17 (2001).
+* 3 Wayne R. LaFave et al., Crim inal Procedure ch. 12 (2d ed. 1999) .
+FN 1. Still, under the 1966 Act district cour ts effectively ordered pretrial
+detention based on dangerousness by order ing pretrial release with bail set
+in an amount clearly beyond the defendant 's means (e.g., $ 500,000), a
+practice specifically prohibited by the 1 984 Act. See 18 U.S.C.
+$ 3142 (c) (2) ("The judicial officer may not impose a financial
+condition that results in the pretrial de tention of the person.").
+FN 2. "personal recognizance. The release of a defendant in a
+will appear for a scheduled matter or whe n told to appear." Black's Law
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+Dictionary 1278 (Bryan A. Garner ed., 7th ed. 1999). "release on
+recognizance.
+The pretrial release of an arrested per son who promises,
+usu. in writing but without supplying a s urety or posting bond, to appear
+for trial at a later date.
+Also termed release on own
+recognizance." Id. at 1292.
+FN 3. If real property
+is offered as collater al, the AUSA must be satisfied
+based on a review of deeds, mortgages, li ens, and appraisals that the owner
+(whether the defendant or someone else) h as sufficient equity in the
+property to back the amount of the bond.
+The office's Asset Forfeiture Unit
+can assist the AUSA in making this inquir y. The AUSA should also thoroughly
+examine or cross-examine anyone with an ownership interest in the property
+about several matters, including her will ingness to lose her interest in the
+property if the defendant fails to appear ; her knowledge of the defendant's
+criminal activity; her involvement with t he defendant in criminal activity,
+if any, and her own criminal record and a ctivity, if any; and her knowledge
+of the existence of assets owned by the defendant from which she might
+expect repayment in the event of forfeitu re of collateral. Such questioning
+may lead to surprising and helpful inform ation, especially when defense
+counsel fails to thoroughly prepare the witness.
+In the rare case where the real pro perty in question is sufficiently
+valuable and "clean" to serve as collater al, the AUSA should simply agree with
+defense counsel to jointly seek the appro val of the presiding district judge if
+the charges are contained in a complaint, or the approval of the district judge
+to whom the case was assigned if the char ges are contained in an indictment.
+FN 4. "surety (shuur[-p]-tee). 1. A person who is primarily liab le for the
+payment of another's debt or the performa nce of another's obligation. . . ."
+Black's Law Dictionary 1278 (Bryan A. Gar ner ed., 7th ed. 1999). A surety
+can be an individual or a corporation. In this context, a surety is often
+referred to as a "bail bondsman," and the formal legal term is "bailer."
+See id. at 136. Another term used is "bail bond ing agency."
+See E.D. Local Crim. R. 46.1(b) (3) ("Court personnel shall not
+recommend specific bail bonding agencies. ").
+FN 5. "bail bond. A bond given to a court by a criminal defendant's
+future; a bond given to obtain a prisoner 's release and to secure the |
+prisoner's appearance to answer legal pro cess.
+* The effect of the release
+on bail bond is to transfer custody of th e prisoner from the officers of the
+law to the custody of the surety on the bail bond, whose undertaking is to
+redeliver the defendant to legal custody at the time and place appointed in
+the bond."
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+Black's Law Dictionary 169 (Bryan A. Garn er ed., 7th ed. 1999) .
+FN 6. The 1984 Act empowers sureties to arres t a fugitive defendant.
+See 18 U.S.C. 5 3149 ("A person charged with an offense,
+who is
+released upon the execution of an appeara nce bond with a surety, may be
+arrested by the surety, and if so arreste d, shall be delivered promptly to a
+United States marshal and brought before a judicial officer.").
+FN 7. "Crime of violence" is defined at 18 U. S.C. 5 3156(a) (4). The
+circuits are split as to whether the crim e of being a felon in possession of
+a firearm, id. § 922(g) (1), is a "crime of violence" under the
+1984 Act.
+Compare United States v. Dillard, 214 F.3d 88 (2d
+Cir. 2000) (FIP "crime of violence") with United States v.
+Lane, 252 F.3d 905 (7th Cir. 2001)
+(FIP not " crime of violence"), and
+United States v. Singleton, 182 F.3d 7 (D.C. Cir. 1999) (same). The
+Sixth Circuit has not yet addressed the i ssue in a published opinion.
+FN 8. This brief detention is often referred to as "temporary detention,"
+which is a term of art in the 1984 Act,
+see 18 U.S.C. § 3142 (d)
+(caption), that actually refers to an ent irely different kind of detention.
+See id. (providing for detention of up to 10 day s of either a
+defendant who is on release in connection
+with another criminal case or a
+defendant who is an alien, and who "may f lee or pose a danger to any other
+person or the community").
+FN 9. Although "[t]he Sixth Circuit has not a ddressed this question,"
+United States v. Yamini, 91 F. Supp. 2d 1125, 1127 (S.D. Ohio 20 00),
+the great weight of authority holds that the district judge's standard of
+review of a magistrate judge's order of p retrial release or detention is de
+novo.. See United States v. Leon, 766 F.2d 77, 80 (2d Cir.
+, 1394 (3d Cir.1985);
+199 ted Stated sta tea V, 8015 P. 2d 1435; 1436(42 947.199; 1925)d
+States v. Fortna, 769 F.2d 243, 251 (5th Cir. 1985);
+United States v.
+Maull, 773 F.2d 1479, 1481-82 (8th Cir. 1985) (en banc); United
+States V. Hurtado, 779 F.2d 1467, 1481 (11th Cir.1985). I n
+Yamini, a Sixth Circuit district judge canvasse d the case law and
+concluded:
+The district court . .
+should not defer to the magistrate judge's
+ultimate conclusion, even if "the whole process [in the district court] .
+• does not] start from scratch, a s if the proceedings before the
+magistrate had never occurred." Ra ther, "It]he point is that the district
+court is to make its own 'de novo' determination of facts, whether
+
+
+Sixth Circuit Criminal Desk Book Chapter 7. Bail and Detention
+
+different from or an adoption of th e findings of the magistrate." Thus,
+while the district courts are not r equired to engage in a plenary
+procedure pursuant to § 3145(b), the circuit courts that have
+addressed the standard of review ag ree that some independent review is
+required.
+91 F. Supp. 2d at 1128 (citations omitted , brackets in original).
+FN 10. The imposition of sentence occurs at th e sentencing hearing. The
+execution of sentence, by contrast, "comm ences on the date the defendant is
+received in custody awaiting transportati on to, or arrives voluntarily to
+commence service of sentence at, the offi cial detention [read penal or
+correctionall facility at which the sente nce is to be served." 18 U.S.C.
+
+
+Chapter 17
+17.01 General provisions
+17.02 Bail Reform Act
+17.03 Categories
+17.04 Personal recognizance
+17.05 Conditional release
+17.06 Eligibility for release - factors
+17.07 Temporary detention orders
+17.08 Detention
+17.09 Bail application following detention
+17.10 Breach of condition of bond
+17.11 Defendant's appeal of detention order
+17.12 Miscellaneous sections
+17.01 General provisions
+The Eighth Amendment to the United States Constitution
+provides that "[e]xcessive bail shall not be required ..." U.S. CONST.
+AMEND. VIII. The United States Supreme Court has interpreted this
+amendment to prohibit the imposition of excessive bail without creating
+a right to bail in criminal cases. See United States v. Salerno, 481 U.S. 739,
+754-55 (1987)("Eighth Amendment does not grant absolute right to
+bail"). The subject of bail and detention also implicates the Fourteenth
+Amendment's Due Process Clause, and requires that laws imposing
+pretrial detention "servea compelling governmental interest", Salerno, 481
+U.S. at 752, and "the Due Process Clause of the Fifth Amendment".
+The principal source of this chapter is the Criminal Resource
+Manual of the United States Attorney's Manual § 26.
+17.02
+Bail Reform Act
+In federal criminal proceedings, release and detention
+determinations are governed by the Bail Reform Act of 1984. 18 U.S.C
+§$ 3141-3156 (1990). These sections contain specific guidelines that
+Be detained or mase playing federal criminal procedtendant should
+543
+
+
+Title 18, United States Code, Section 3141(a) gives "judicial
+officers" authority to make determinations regarding bail in all stages of
+a criminal case, up to and including the trial stage. The term "judicial
+officers" is defined in Title 18, United States Code, Section 3156, along
+with other terms relevant to the matter of bail in criminal cases. Once a
+defendant has been convicted of the federal charges, Title 18, United
+States Code, Section 3141 (b) vests authority with district judges and the
+appellate courts to make bail determinations pending the imposition or
+execution of sentence, or pending appeal of the same.
+Title 18, United States Code, Sections 3152 through 3154
+pertain to the administration and the supervision authority of pretrial
+services officers in the federal criminal system. Section 3154 specifically
+empowers pretrial services officers with the authority to collect
+information from defendants and other sources relative to the matter of
+bail. Pretrial services officers are authorized to make recommendations
+as to whether a defendant should be detained or released, including
+specific recommendations regarding conditions of release. 18 U.S.C. §
+3154(1). Pretrial services officers are also authorized to establish facilities
+for and conduct the supervision of defendants released under the
+provisions of Section 3142.
+17.03
+Categories
+Title 18, United States Code, Section 3 142 defines the categories
+of "release and detention" a defendant may be subject to and contains the
+rules under which the court and parties must proceed relating to bail
+matters. In that regard, Section 3142(a) states "that upon the appearance
+before a judicial officer of a person charged with an offense, the judicial
+officer shall make a determination regarding bail status of the defendant,
+and shall enter an order designating a defendant's custodial status" under
+one of four categories:
+(1)
+released on personal recognizance or upon execution of
+an unsecured appearance bond (following the provisions
+(2)
+of Section 3142(b));
+released on a condition or combination of conditions as
+(3)
+defined by Section 3142(c);
+temporarily detained to permit revocation of conditional
+release, deportation, or exclusion under Section 3142(d);
+or
+detained pursuant to the provisions of Section 3142(e).
+544
+
+
+17.04
+Personal recognizance
+Title 18, United States Code, Section 3142(b) requires a judicial
+officer to order the pretrial release of a defendant on "personal
+recognizance" or upon the defendant's execution of an "unsecured
+appearance bond" in an amount specified by the court. A Section
+3142(b) release order must be conditioned on a defendant's agreement to
+"not commit a Federal, State, or local crime during the period of release."
+If, however, the judicial officer determines that the release of a defendant
+on "personal recognizance" or "unsecured appearance bond" would not
+"reasonably assure" the defendant's appearance at court proceedings, or
+will "endanger the safety of any other person or the community", then
+there is no obligation to order release. 18 U.S.C. §$ 3142(b) and
+3142(c). In this event, the judicial officer must follow the provisions of
+Title 18, United States Code, Section 3142(c).
+17.05 Conditional release
+Once a judicial officer has made the determination that a
+defendant does not qualify for release under Section 3142(b), then the
+judicial officer must follow Section 3142(c). When structuring the
+release of a defendant under Section 3142(c), the judicial officer must
+order that the defendant "not commit a Federal, State, or Local crime
+during the period of release. 18 U.S.C. § 3142(c)(1)(A). In addition, the
+judicial officer must impose the least restrictive condition or combination
+of conditions necessary to "reasonably assure" the defendant's appearance
+as required and to "reasonably assure" the safety of any person and the
+community". 18 U.S.C. § 3142(c)(1)(B). An illustrative list of
+conditions is set forth in § 3142(c)(1 )(B)(i)-(xiv) which gives the judicial
+officer authority to impose conditions not specifically enumerated so long
+as the same serve the purposes set out in $ 3142(c)(1)(B). It is important
+to note that "Section 3142 speaks only of conditions that will
+"reasonably" assure appearance, not guarantee it". United States v. Xulum,
+84 F.3d 441, 443 (D.C. Cir. 1996)(per curiam). A judicial officer is not
+conditions of release. 18 U.S.C. § 3142(c)(3).
+545
+
+
+17.06
+Eligibility for release - factors
+When making a determination regarding the eligibility of a
+defendant for pretrial release (whether personal recognizance, unsecured
+appearance bond, or release on conditions), the judicial officer must
+consider the factors listed in Section 3142(g), including: |
+(1)
+the nature and circumstances of the offense (in particular
+whether it is an offense which is violent or nonviolent in
+nature, or involves narcotics);
+(2)
+(3)
+the weight of the evidence against the person;
+the history and characteristics of the person --
+character - including physical and mental
+condition), family ties, employment, financal
+resources, length of time in the community,
+community ties, past conduct history relating to
+drug or alcohol abuse, criminal history, record of
+court appearances; and
+(B)
+whether, at the time of the current offense or
+arrest, the person wason probation, on parole, or
+on other release pending trial, sentencing, appeal,
+or completion of sentence for an offense under
+Federal, State, or local law; and
+(4)
+the nature and seriousness of the danger to any person or
+to the community that would be posed by the person's
+release.
+18 U.S.C. $ 3142(g)
+In addition to considering evidence of the factors set forth above,
+the court may upon its own motion, or upon the motion of the
+government attorney, conduct an inquiry into the source of any property
+to be designated for potential forfeiture or offered as collateral to secure
+any bond. 18 U.S.C. § 3142(g)(4). If the court determines that any such
+collateral or property, because of its source, will not reasonably assure the
+coleral or property as security for a bond til berationed. 8 US.C.
+$ 3142(g)(4).
+17.07
+Temporary detention orders
+Title 18, United States Code, Section 3142(d) requires a judicial
+officer to enter an order of temporary detention in cases where a factual
+determination is made that:
+546
+
+
+(1)
+the defendant:
+(A)
+is,
+and was at the time the offense was
+committed, on
+(i) release pending trial for a felony under Federal,
+State, or local law;
+(ii) release pending imposition or execution of
+sentence, appeal of sentence or conviction, or
+completion of sentence, for any offense under
+Federal, State, or local law; or
+(iii) probation or parole for any offense under
+Federal, State, or local law; OR
+(B) is not a citizen of the United States or lawfully
+admitted for permanent residence, as defined in
+section 101(a)(20) of the Immigration and
+Nationality Act (8 U.S.C. 1101(a) (2); and
+(2)
+the defendant may flee or pose a danger to any other
+person or the community.
+18 U.S.C. § 3142(d)
+The formula for calculating the 10 day temporary detention
+period is set forth in Section 3142(d). At the time the 10 day order is
+entered, the judicial officer must direct the attorney for the government
+to notify the appropriate "authorities" of the defendant's status. In the
+event that the "notified authority" declines to take the defendant into
+custody, then the judicial officer must make an independent
+determination regarding bail under the provisions of Sections 3142(b),
+3142(c), and 3142(e)(if the government moves for detention).
+17.08
+Detention
+The Bail Reform Act requires the pretrial detention of a defendant
+only if a judicial officer determines that no conditions or combination of
+conditions exist which will "reasonably assure the appearance of the
+person", United States v. Xulam, 84 F.3d 441, 442 (D.C. Cir. 1996)(per
+curiam), and "the safety of any other person and the community:" United
+States v. Rodriguez, 897 F. Supp. 1461, 1463 (S.D. Fla. 1995); 18 U.S.C.
+§ 3142(c).
+Cases Which Qualify For Detention Hearings: Section
+3142(f) defines specific situations under which a judicial officer may hold
+a detention hearing. Those situations are as follows:
+(1)
+Ch. 17
+547
+
+
+an offense for which the maximum term of imprisonment
+is 10 or more years as prescribed by the Controlled
+Substances Act; or (d) any felony if the person has been
+convicted of two or more offenses described in
+paragraphs (a) through (c) or comparable state offenses.
+(2)
+Upon the motion of the government attorney or on the
+court's own motion, in a case that involves: (a) a serious
+risk of flight; or (b) a serious risk that the defendant will
+obstruct justice or threaten a witness.
+18 U.S.C. § 3142(f)
+Section 3142(f) "does not authorize a detention hearing in the
+absence of one of the six situations set forth above." United States v.
+Butler, 165 F.R.D. 68, 71 (N.D. Ohio 1996). Thus, the government may
+not request a detention hearing only on the allegations of danger to the
+community or another person.
+The "government is required to
+demonstrate that there are grounds for a hearing under the specific
+provisions of either 3142(D(1) or (f)(2)." Butler, 165 F.R.D. at 71.
+"When there existsone or more grounds for holding a hearing under those
+provisions, the government may proceed on the theory of risk of flight
+and/or danger to the community or any other person." Id. Section
+3142(f) may fairly be interpreted as authorizing pretrial detention "only
+upon proof of a likelihood of flight, a threatened obstruction of justice or
+a danger of recidivism in one or more of the crimes actually specified by
+the bail statute." Butler, 165 F.R.D. at 71 (quoting United States v. Himler,
+797 F.2d 156, 160 (3d Cir. 1986) and citing United States v. Bynd, 969
+F.2d 106 (5th Cir. 1992); United States v. Ploof, 851 F.2d 7 (Ist Cir.
+When the court has determined that a detention hearing is
+warranted, it may consider evidence relating to a defendant's danger to
+the community. Detention considerations are then guided by the factors
+set forth in 18 U.S.C. § 3142(g), and the specific consideration of "the
+nature and seriousness of the danger to any person or the community that
+would be posed by the person's release." Butler, 165 F.R.D. at 71; 18
+U.S.C. § 3142(g)(4). Accordingly, the government must first prove one
+or more of the grounds listed in 3142(f)(1) or (2) as a prerequisite to the
+court considering the factor of danger to the community whether there
+exist appropriate conditions of release in the case. In the Butler decision,
+the court evaluated the government's motion to detain a defendant
+charged with firearms offenses. In reaching a decision in favor of pretrial
+detention, the Butler court stated:
+there is danger inherent to the community in the unlawful
+possession of firearms, both a rifle and a pipe bomb. This is
+particularly true where the possessor has a lengthy criminal
+548
+
+
+history, has not been deterred from the commission of crime by
+prior convictions and appears to be involved in ongoing drug
+offenses.
+Timing Of Detention Hearing: Title 18, United States Code,
+Section 3142(f)(2) contains specific guidelines regarding the timing of
+detention hearings. Ideally, the hearing is supposed to take place
+immediately upon the defendant's first appearance before the judicial
+officer. However, given the fact that a defendant may lack representation
+at this initial appearance, the detention hearing is not likely to go forward
+unless the court has made other arrangements for the defendant to be
+represented by counsel. Section 3142(f)(2) also permits a 3 day delay of
+the detention hearing upon the motion of the government attorney. A
+defendant may request a continuance of up to 5 days under this section,
+for good cause shown. Between the time the detention motion is filed
+and the actual detention hearing (up through the court's ruling on the
+motion for detention), the defendant will remain in the custody of the
+United States Marshal's Office. 18 U.S.C. § 3142(f)(2). A hearing may
+be reopened before or after the court's ruling on a detention motion, at
+any time before trial if the judicial officer makes a factual finding that
+information exists that was not previously known at the time of the
+hearing and that the information is material on the issue of whether there
+are conditions of release that will reasonably assure the appearance of the
+defendant and the safety of any other person and the community.
+Detention Hearings May Proceed By Way of Proffer; Rules
+of Evidence Do Not Apply: "Detention hearings are an informal
+proceeding, and the evidence presented is not governed by the Federal
+Rules of Evidence." United States v. Duncan, 897 F. Supp. 688, 690
+(N.D.N.Y. 1988); 18 U.S.C. § 3142(f)(2). The government may proceed
+in a detention hearing by way of proffer. United States v. Miller, 39 Fed.
+Appx. 278, 278-78 (6th Cir. 2002); United States v. Smith, 79 F.3d 1208,
+1209-10 (DC Cir. 1996); United States v. Gaviria, 828 F.2d 667, 669
+(11th Cir. 1987); United States v. Martir, 782 F.2d 1141, 1145 (2d Cir.
+1986); United States v. Winsor, 785 F.2d 755, 756 (9th Cir. 1986); United
+States v. Acevedo-Ramos, 755 F.2d 203, 206-07 (Ist Cir. 1985). The
+rationale for permitting detention hearings to proceed by way of proffer
+is that such hearings are "neither a discovery device for the defense nor a
+trial on the merits." Smith, 79 F.3d at 1210. "The process that is due is
+only that which is required by and proportionate to the purpose of the
+proceeding." Id. "That purpose includes neither a reprise of all the
+evidence presented before the grand jury, United States v. Suppa, 799 F.2d
+115, 119 (3d Cir. 1986), nor the right to confront non-testifying
+government witnesses, United States v. Accetturo, 783 F.2d 382, 388-89
+549
+
+
+(3d Cir. 1986)." Smith, 79 F.3d at 1210 also citing United States v.
+Hurtado, 779 F.2d 1467, 1479 (11th Cir. 1985)( purpose of pretrial
+1992). "A right to require the government to produce its witnesses
+against [a defendant] would complicate the hearing to a degree out of
+proportion to the liberty interest at stake - viz. the interest in remaining
+free until trial, for what is by statute a period of limited duration." Smith,
+79 F.3d at 1210; see also Speedy Trial Act, 18 U.S.C. § 3161, et seq.
+Application of the Rebuttable Presumption: Title 18, United
+States Code, Section 3142(e) contains three categories of criminal
+offenses that give rise to a rebuttable presumption that "no condition or
+combination of conditions" will (1) "reasonably assure" the safety of any
+other person and the community if the defendant is released; or (2)
+"reasonably assure" the appearance of the defendant as required and
+"reasonably assure" the safety of any other person and the community if
+the defendant is released. These three categories are:
+(e)
+... a judicial officer finds that:
+(1)
+the person has been convicted of a Federal offense that is
+described in subsection (f)(1) of this section, or of a State
+or local offense that would have been an offense
+described in subsection (f)(1) of this section if a
+circumstance giving rise to Federal jurisdiction had
+existed;
+(2)
+the offense described in paragraph one of this subsection
+was committed while the person was on release pending
+trial for a Federal, State, or local offense; and
+(3)
+a period of not more than five years has elapsed since the
+date of conviction, or the release of the person from
+imprisonment, for the offense described in paragraph (1)
+of this subsection, whichever is later.
+18 U.S.C. § 3142(e) (1)-(3).
+Subject to rebuttal by the person, it shall be presumed that no
+condition or combination of conditions will reasonably assure the
+appearance of the person as required and the safety of the community if
+the judicial officer finds that there is probable cause to believe that the
+person committed an offense for which a maximum term of imprisonment
+of ten years or more is prescribed in the Controlled Substances Act (21
+U.S.C. 801 et seq.), the Controlled Substances Import and Export Act
+(21 U.S.C. 951 et seq.), the Maritime Drug Law Enforcment Act (46
+U.S.C. App. 1901 et seq), an offense under section 924(c), 956(a), or
+2332b of this title, or an offense involving a minor victim under section
+550
+
+
+1201, 1591, 2241, 2242, 2244(a)(1), 2245, 2251, 2251A, 2252(a)(1),
+2252(a)(2), 2252(a) (3),
+2252A(a)(I), 2252A(a)(2), 2252A(a) (3),
+2252A(a)(4), 2260, 2421, 2422, 2423, or 2425 of this title.
+18 U.S.C. § 3142(e).
+The rebuttable presumption relating only to the safety of any
+other person and the community pertains to those cases meeting the
+criteria of Section 3142(e)(1)(3). It is important to note, that all 3 of
+these conditions must be met forthe proper application of the rebuttable
+presumption of "danger to the community."
+The rebuttable presumption relating to both "risk of flight" and
+"danger to the community" pertains to those cases where the judicial
+officer finds there is probable cause to believe that the defendant
+committed: (1) a drug offense (as defined under Title 21) when the
+maximum term of imprisonment is 10 years or more; or (2) an offense
+under Title 18, United States Code, Section 924(c). 18 U.S.C. §
+3142(e).
+The indictment alone is sufficient to raise the rebuttable
+presumption that nocondition (or combination of conditions) will ensure
+the defendant's reappearance for trial and that no conditions of release
+will ensure the safety of the community. See, e.g., Smith, 79 F.3d at
+1210-1211 citing United States v. Dillon, 938 F.2d 1412 (Ist Cir. 1991);
+Suppa, 799 F.2d at 119; United States | Dominguez, 783 F.2d 702, 706 n.7
+(7th Cir. 1986); Hurtado, 779 F.2d at 1477-79; United States . Contreras,
+776 F.2d 51 (2d Cir. 1985): United States _ Hazime, 762 F.2d 34, 37 (6th
+Cir. 1985); United States
+1 Mosuro, 648 F. Supp. 316, 318 (D.D.C.
+1986); see also United States _ Tedder, 903 F. Supp. 344, 345 (N.D.N.Y.
+1995).
+Burden of Proof At Detention Hearing: In a pretrial detention
+hearing, the government's burden is to establish by clear and convincing
+evidence that no conditions of release will reasonably assure the safety of
+the community. Rodriguez, 897 F. Supp. at 1463 citing United States |
+Orta, 760 F.2d 887 (8th Cir. 1985); see also United States v. Arena, 894 F.
+Supp. 580, 585-86 (N.D.N.Y. 1995) citing United States | Chimurenga,
+760 F.2d 400, 405 (2d Cir. 1985). "The issue in such a hearing is
+whether releasing a defendant would pose a danger to the community
+hat would not exist were [the defendant] detained." Rodriguez, 897 F
+Supp. at 1463 citing United States | Phillips, 732 F. Supp. 255, 267 (D
+F.2d 887 (8th Cir. 1985). The standard is different when the issue is
+whether any conditions of release will reasonably assure the defendant's
+attendance at trial (risk of flight); the government need only prove that
+551
+
+
+here are no such conditions by a "preponderance of the evidence." Se
+United States | Tedder, 903 F. Supp. 344, 345 (N.D.N.Y. 1995 )citin
+United States v. Martir, 782 F.2d 1141, 1146 (2d Cir. 1986); 18 U.S.C.
+§ 3142(c). It is not necessary that the government prove both flight risk
+and danger to the community to warrant detention. See United States
+Flores, 856 F. Supp. 1400, 1401 (E.D. Cal. 1994).
+Requirements For The Contents Of Release and Detention
+Orders: Title 18, United States Code, Section 3142(h) lists the
+requirements for the contents of a "release order." Title 18, United States
+Code, Section 3142(g) lists the requirements for the contents of a
+"detention order," including the requirement of "written findings of fact
+and a written statement of the reasons for detention."
+17.09
+Bail application following
+detention
+When a defendant moves for release on bail following pretrial
+detention, the court must consider three factors: "(1) the length of the
+pretrial detention; (2) the extent to which the prosecution is responsible
+for the delay of the trial; and (3) the strength of the evidence upon which
+the pretrial detention was based." United States | Millan, 4 F.3d 1038
+1043 (2d Cir. 1993); United States | O'Neill, 52 F. Supp. 2d 954, 960
+(E.D. Wis. 1999)(to get to first base on this issue, the defendant must
+show that either the prosecution or the court has unnecessarily delayed
+in bringing the case to trial-maybe the prosecutor is stalling because he
+realizes his case is so weak that pretrial detention is the only punishment
+in fact he can impose on the defendant).
+Regarding the length of pretrial detention, there is no doubt that
+the longer the pretrial detention the more likely the denial of due process.
+Typically, this f
+Imita Statis fact veals Claudio, m.2d F2 334, (2d Cir.
+1986) ("detention that has lasted for fourteen months and, without
+of due process").
+044 (pretrial detention period of 30-31 months a factor in defendant
+avor but not dispositive); see also United States | Melendez-Carrion, 82
+F.2d 56 (2d Cir. 1987)(pretrial detention period of 19 months did not
+violate defendant's due process rights).
+Regarding the reason or "responsibility" for delay factor, the court
+will consider information relating to pretrial events such as motions for
+552
+
+
+continuance, discovery disputes, complexity of the case, plea discussions,
+and other matters relating to the progress (or lack thereof) of the case.
+Regarding the reasons for the pretrial detention, the court will
+examine the findings from the detention hearing.
+17.10
+Breach of condition of bond
+Title 18, United States Code, Sections 3146 through 3148
+describe the penalties a defendant may be subject to for: (1) failure to
+appear at any proceeding as required (Section 3146); (2) committing an
+offense while on pretrial release (Section 3147); and (3) violating any
+condition of pretrial release (which includes the sanction of bond
+revocation) (Section 3148). In addition, Title 18, United States Code,
+Section 3149 empowers a su rety with arrest authority over offenders, and
+requires that the surety promptly deliver the offender to the custody of
+the United States Marshal for proceedings under Section 3148. In this
+instance, judicial officers are also bound by Federal Rule of Criminal
+Procedure 46.
+Federal Rule of Criminal Procedure 46(e) provides that "It]he
+court must declare the bail forfeited if a condition of the bond is
+breached." FED. R. CRIM. P. 46(f)(1). This language is broad, and
+reaches any condition of release. See United States | Gigante, 166 F.R.D.
+'[T]here is no conflict between Rule 46(f) and the Bail Reform Act; the
+Rule and the Act are complementary and form a unified system dealing
+with pretrial release." Gigante, 166 F.R.D. at 6 quoting Vaccaro, 51 F.3d
+at 192.
+17.11
+Defendant's appeal of detention
+order
+When a defendant seeks review of a magistrate judge's order of
+detention, the district court is bound to review the matter de novo, and
+is drakendeeple conclus the Set United heapurpose of ar, 897 F.
+Supp. 688, 689-90 (N.D.N.Y. 1995) citing United States 1. Leon, 766 F.2d
+Ch. 17
+553
+
+
+17.80 Cia. r ) Sric als ed Sia, 53 24 2,338 480cir
+1985). 18 U.S.C. § 3145 (a)-(c).
+17.12
+Miscellaneous sections
+554
+
+
+
+USABook > Crimes > Narcotics > Federal Narcotics Prosecutions > Chapter 26
+prev | next | help | download
+Chapter 26
+Barry Wiegand
+District of District of Columbia
+26.1
+Introduction
+26.2
+Detention for serious drug crimes
+26.3
+First appearance
+26.4
+Standard of proof
+26.5
+Detention hearing
+26.6
+Rebuttable presumptions
+26.7
+Temporary detention
+26.8
+Other bases for denying bail
+26.9
+Nebbia hearings
+26.10 Resources
+26.11 Acknowledgments
+26.1 Introduction
+Whether a defendant is detained without bail pending trial often profoundly affects
+the course of a drug prosecution. For example, pretrial detention or release influences
+whether a defendant decides to co-operate with the government, as well as the calculation
+of whether to plead guilty or go to trial. Moreover, Congress has paid special attention to
+serious drug offenders in the law of pretrial detention, placing much stricter limitations on
+
+
+
+their right to bail, and presuming that most should be detained pending trial.
+Federal law of pretrial detention, release, and bail is set forth in the Bail Reform Act of
+1984, as amended, 18 U.S.C. §§ 3141-3156. The most important provisions, which govern
+when a defendant may be held without bail pending trial, are set forth in § 3142(e)
+(detention), § 3142(f) (detention hearing), and § 3142(g) (factors to be considered in
+determining whether there are conditions of release that will reasonably assure the
+appearance of the defendant and the safety of the community).
+26.2 Detention for serious drug crimes
+westlaw query 18 +S 3142(F) (1)(C)
+Nearly all defendants charged with serious drug crimes may be detained pending trial
+under 18 U.S.C. § 3142(f)(1)(C), which permits the government to move for the pretrial
+detention of any defendant charged with a federal drug crime for which the maximum
+penalty is more than ten years in prison. In practice, this means that any defendant is
+subject to pretrial detention if charged with the manufacture, distribution, or possession
+with intent to distribute of heroin, cocaine powder, crack cocaine base, methamphetamine,
+phencyclidine, or any other drug classified as a Schedule I or Schedule Il controlled
+substance, as these crimes all have maximum penalties of 20 years in prison under
+21 U.S.C. § 841(b)(1)(C) and § 960(b)(3). Defendants conspiring or attempting to commit
+these offenses are punishable to the same extent under 21 U.S.C. § 846 and § 963, and
+similarly may be held without bail pending trial under § 3142(f).
+• Maximum penalty. Section 3142(f) (1)(C) specifically refers to violations of "the
+Controlled Substances Act (21 U.S.C. § 801 et seq.), the Controlled Substances
+Import and Export Act (21 U.S.C. § 951 et seq.), or the Maritime Drug Law
+Enforcement Act (46 U.S.C. App. § 1901 et seq.)." Under this section, it is the
+maximum penalty that must be ten years or more, not whether the charged offense
+has a mandatory-minimum penalty of ten years or more.
+• Marijuana. Defendants charged with distribution or possession with intent to
+
+
+
+distribute marijuana are not subject to pretrial detention unless the amount involved
+is greater than 50 kilograms, see 21 U.S.C. § 841(b)(1)(D) (less than 50 kilograms of
+marijuana subject to sentence of not more than five years), or the defendant is
+charged with a "schoolhouse," "playground," or "public housing" offense, in violation
+of 21 U.S.C. § 860, under which such violations are subject to twice the maximum
+punishment authorized under § 841(b).
+• PCP. Most statute books list phencyclidine (PCP) under Schedule III of the Controlled
+Substances Act, where it originally was classified. However, PCP has been reclassified
+as a Schedule Il drug, subject to maximum penalties of 20 years in prison under 21
+U.S.C. § 841(b)(1)(C) and § 960(b)(3), so that almost any felony federal offense
+involving PCP would be a "detainable" crime. See 43 Fed. Reg. 3359-60 (January 23,
+1978) (Final rule transferring phencyclidine to Schedule II from Schedule III, effective
+February 24, 1978).
+26.3 First appearance
+A motion for pretrial detention is to be made at a defendant's first appearance, which
+normally is presentment on a complaint in a case founded upon an arrest on probable
+cause, or an arraignment on a grand jury original indictment. Although the statute
+contemplates an immediate hearing on the detention motion, see 18 U.S.C. § 3142(f), in
+common practice, the government is accorded up to three working days after the first
+appearance for the hearing to be held under the continuance provision of § 3142(f).
+During this period, the defendant must be held without bond. The "shall" language of the
+§ 3142(f) indicates that the court must grant a motion for a hearing on the motion for
+pretrial detention, and lacks discretion to deny it outright.
+Normally, when a defendant is arrested in a district other than where the prosecution
+will occur, the first appearance is deemed to take place when the defendant first appears
+in the prosecuting district. However, this question is not free from doubt. See United
+States - Melendez-Carrion, 790 F.2d 984, 990 (2d Cir. 1986) (detention hearing may be
+held in first appearance in charging district where defendant is arrested in another
+district); United States | Dominguez, 783 F.2d 702, 704 (7th Cir. 1986) (government was
+
+
+
+not required to request detention in district where defendants were arrested and initially
+appeared, but could do so when defendants first appeared in charging district; "first
+Cr. Unred States roSeS, 62 3.3d 1233, 1235-38 (9th Cir. 1995) (while defendant was
+"initial appearance").
+entitled to detention hearing before magistrate in arresting district, only district court in
+charging district had authority to review the order).
+Practice note. At "removal" proceedings, pursuant to Fed. R. Crim. P. Rule 40,
+r any other similar hearing tollowing an arrest outside the prosecuting distric
+le prosecutor should make clear on the record that detention will be sought an
+take any other necessary steps to ensure that the defense has no colorable basis
+later to claim that there was a failure to meet the "first appearance" provision of
+§ 3142(f). See generally United States ; Valenzuela-Verdigo, 815 F.2d 1011,
+1013-16 (Sth Cir. 1987) (detention hearing, although not held until 18 days after
+arrest, was not untimely where prosecutor in arresting district had requested
+pretrial detention and hearing date was set but subsequently delayed with
+apparent agreement of parties due to transfer of prisoner to charging district and
+schedule of defendant's counsel). However, failure to comply with the "first
+defendante" er the detention hearing See baited States modetaining the ,
+495 U.S. 711, 716- 17 (1990) ("Neither the timing requirements nor any other
+part of the Act can be read to require, or even suggest, that a timing error must
+810 F.2d 1008, 1009-10 (11th Cir. 1987)
+(where defendant was temporarily detained under § 3142(d), hearing could be
+held at any time within the 10-day temporary detention period).
+26.4 Standard of proof
+westlaw query 18 +S 3142(E) /P SAFETY OR APPEARANCE
+The judge deciding a pretrial detention motion must order a defendant held without
+bail if it is shown that no condition or combination of conditions of release will reasonably
+
+
+
+assure either the defendant's appearance in court or the safety of the community or any
+individual. 18 U.S.C. § 3142(e). In other words, the key detention issue is whether a
+defendant's release poses such a danger to the community—or any specific person, such
+as a witness—or such a risk of flight, that he should be held in jail pending trial.
+• Safety. Section 3142(f) provides that the government must prove "by clear and
+convincing evidence" that no conditions of release will assure the safety of the
+community or any individual.
+• Appearance. Circuit Courts of Appeals have held the government must prove by a
+Cir. 1996); United States | Kirk, 992 F.2d 1218 (6th Cir.1993)(unpublished order):
+United States | Dillon, 938 F.2d 1412, 1416 (1st Cir. 1991): United States v.
+1990); United States . King, 849 F.2d 485,
+(8th Cir. 1985); United States - Motamedi, 767 F.2d 1403, 1406 (9th Cir. 1985).
+26.5 Detention hearing
+westlaw query 18 +S 3142(F) /P 26.2 OR JENCKS
+At a detention hearing, "the rules concerning the admissibility of evidence in criminal
+trials do not apply to the presentation and consideration of information at the hearing."
+18 U.S.C. § 3142(f). However, the Jencks Act, 18 U.S.C. § 3500, does apply at pretrial
+detention hearings. See Fed. R. Crim. P. Rule 46(j) (Rule 26.2 generally applies to a
+detention hearing under § 3142) and Rule 26.2 (production of witnesses' statements).
+Thus, if a defendant is being prosecuted upon a criminal complaint following an arrest on
+probable cause, the court commonly will schedule a consolidated preliminary and detention
+hearing at which the prosecution must make available "Jencks" statements. If a
+
+
+
+defendant's detention hearing follows an indictment, the government may proceed solely
+Practice notes.
+1. In some instances, when proceeding by proffer, it may be tactically adroit to bring to
+the nearing a government witness, such as the supervising case agent, and make
+that witness available to the court or defense counsel if either wishes to obtain
+additional evidence or information. A witness thus being called by the court or
+defense counsel is not subject to the requirements of the Jencks Act. See Fed. R.
+Crim. P. Rule 26.2 (a).
+2. In hearings at which the government will proffer evidence derived from intercepted
+communications, for example, from court-authorized "wiretaps," there is a
+requirement under "Title III, "18 U.S.C. § 2510-2522, more particularly § 2518(9), for
+ten-days' notice to the defendant. This can conflict with the three-day continuance
+limit under 9 3142(f), which defense counsel may try to employ to preclude the
+proffer of evidence based upon wiretaps. Section 2518(9) itself provides for a waiver
+by the court of the ten-day period upon finding that it is not possible to furnish the
+information ten days before the hearing and that the delay will not be prejudicial. If
+the defendant insists on ten-days notice, this could constitute "good cause" to extend
+states Sale det, 794 .20 64, 90(2d tr, Istatute's three day limit. See United
+26.6 Rebuttable presumptions
+
+
+
+westlaw query 18 +S 3142(E)
+The most important section of the Bail Reform Act in drug prosecutions, after
+18 U.S.C. § 3142(f)(1)(C), is 18 U.S.C. § 3142(e). This section provides for a rebuttable
+presumption that no condition or combination of conditions of release will reasonably
+assure the safety of the community where there is a showing of probable cause that:
+(1) the defendant has committed a drug crime for which pretrial detention is
+authorized; that is, a violation of the Controlled Substances Act with a maximum
+term in prison of ten or more years, as well as crimes under the other two
+federal drug laws referred to in § 3142(f)(1)(C);
+(1) the defendant has committed a violation of 18 U.S.C. § 924(c): using or
+carrying a firearm during and in relation to, or possessing a firearm in
+furtherance of, a drug-trafficking crime; and
+(1) the defendant is a "released" or "recidivist" offender subject to a
+presumption applying to defendants who have recently committed detainable
+crimes while on pretrial release.
+As noted above, an indictment itself constitutes a finding of probable cause.
+A second rebuttable presumption attaches to defendants accused of crimes
+identified in (1) and (2) above, that no condition or combination of conditions
+will reasonably assure the appearance of the person as required. § 3142(e).
+Note. Although probable cause to believe that a defendant has
+committed an 18 U.S.C. § 924(C) crime gives rise to the presumptions,
+it is not obvious that a § 924(c) offense alone allows a § 3142(f)
+motion for pretrial detention. Given that committing a § 924(c)
+offense raises presumptions favoring detention, it would be a statutory
+anomaly if the charge did not authorize pre-trial detention under
+§ 3142(f). Since a § 924(C) crime is not itself a violation of the
+Controlled Substances Act, if it is "detainable," it either must be (A) as
+a crime of violence under § 3142(f)(1)(A), or (B) as a crime with a
+
+
+
+: maximum sentence of life imprisonment under § 3142(f) (1)(B). For
+purposes of bail, crimes of violence are defined in § 3156(a)(4), and it
+appears that § 924(c) would only qualify under § 3156(a)(4)(B), as a
+felony that, "by its nature, involves a substantial risk that physical
+force against the person or property of another may be used in the
+course of committing the offense." Similarly, § 924(c)'s penalty
+provisions generally speak of mandatory minimum sentences, rather
+than explicitly authorizing a maximum sentence of life imprisonment.
+Nevertheless, § 924(c)(1)(C)(ii) does prescribe life imprisonment for a
+defendant convicted of the offense under certain circumstances.
+Moreover, Amendment 642 to the U.S. Sentencing Commission
+Guidelines Manual, which took effect November 1, 2002, reflects a
+decision to treat a § 924(c) offense as a "life crime" for purposes of the
+career offender sentencing enhancement. See Amendments to the
+Guidelines Manual, Supplement to Appendix C, 277-78 (November 1,
+2002) (Amendment 642, "Reason for Amendment"). See also United
+States 1 Woodruff, 296 F.3d 1041, 1049 (11th Cir. 2002). In the great
+bulk of situations, this is only of academic concern, but the anomaly
+can arise when a defendant is charged with a crime involving less than
+50 kilograms of marijuana and a § 924(c) offense. As the marijuana
+charge is not a detainable offense (because the maximum penalty is
+five years in prison), a pretrial detention motion can only be made if
+the § 924(c) offense is an independent basis for pretrial detention. This
+also arises when the underlying drug-trafficking crime involves
+Schedule III, IV, or controlled substances (which are not subject to a
+maximum punishment of imprisonment for ten years or more).
+26.7 Temporary detention
+westlaw query 18 +S 3142(D)(1)(A)
+Another key provision of the Bail Reform Act is 18 U.S.C. § 3142(d), which authorizes
+periods of temporary detention of up to ten working days where the defendant commits an
+
+
+
+offense while on some form of judicial supervision, such as parole, probation, release
+pending sentencing, or pretrial release in a felony case. See § 3142(d)(1)(A)(i)-(iii). Most
+foreign nationals who do not have a "green card," that is, who are not lawfully admitted for
+permanent residence, are also subject to a ten-day hold. See § 3142(d)(B). The purpose
+or the temporary detention is to give supervising authorities-parole board
+officer, trial judge, or the Bureau of Immigration and Customs Enforcement (formerly
+INS)—a chance to issue a warrant for the defendant. See § 3142(d). A motion for a tenday hold imposes a duty on the government to notify the supervising authority of the
+defendant's new charge. See § 3142(d).
+Practice notes.
+• When the government seeks both a detention hearing after a three-day continuance,
+§ 3142(f), and also temporary detention, § 3142(d), the court may effectively
+combine the two matters and set a consolidated hearing within the ten-day period,
+but later than the three days permitted for a strictly pretrial detention hearing. Or the
+court may construe the time limits more narrowly and require a detention hearing in
+three days, even though the defendant will nevertheless remain jailed after the three
+days elapse pursuant to the ten-day hold. Under either view, however, ten-day holds
+do not "tack,
+" and a defendant who satisfies more than one ground for temporary
+detention under § 3142(d) may only be detained for a total of ten days.
+• Section 3142(d) requires two findings for temporary detention: (a) that the defendant
+is on some form of release or not a lawful U.S. resident, and (b) that the defendant
+may be a danger to the community or a risk of flight. As a result, some judges may
+conclude that they have discretion to deny a motion for temporary detention, even
+when it is clearly established that a defendant is on parole, probation, or pretrial
+release for a felony. Although this question may arise in non-drug cases, it should not
+be an issue in narcotics prosecutions because of the rebuttable presumptions that the
+defendant is a danger and risk of flight.
+• Section 3142(d)(1)(A)(i) authorizes temporary detention only for defendants released
+before trial in felony cases, not misdemeanors, but under § 3142(d)(1)(A)(ii), any
+defendant facing sentence or released pending appeal may be held for up to ten days.
+
+
+
+26.8 Other bases for denying bail
+Even though a serious narcotics charge itself is sufficient for pretrial detention,
+employing one or more of the other five bases for denying bail can bolster the
+government's case for detention. Consequently, sound litigating tactics suggest moving for
+pretrial detention on every applicable ground available under § 3142(f):
+1. Where there is a serious risk that a defendant might try to obstruct justice, § 3142(f)
+(2)(B), for example, by attempting to influence, intimidate, or harm a witness or
+juror. This is a valuable additional ground upon which to seek pretrial detention, and
+is often available in drug cases-it focuses the Court's attention on a threat to a
+specific, live person, rather than on the more generalized notion of community safety;
+2. Where a defendant is also charged with a crime of violence, § 3142(f) (1)(A)), as
+often is the case in RICO and CCE prosecutions based upon narcotics conspiracies;
+3. Where a defendant is a serious risk of flight, § 3142(f)(2)(A), there is no drawback to
+specifically seeking detention on this ground, in addition to relying on the
+presumption that drug defendants are a risk of flight;
+4. Where a defendant is also charged with an offense for which the maximum sentence
+is life imprisonment or death, § 3142(f)(1)(B); and
+5. Where the "recidivist" provision of § 3142(f)(1)(D) authorizes pretrial detention if a
+defendant has previously committed two or more "detainable offenses"; that is,
+crimes which themselves would have permitted a pretrial detention motion under
+§ 3142(f)(1). As fairly few defendants have extensive federal criminal records, this
+provision also incorporates state and local convictions that would have been
+detainable had they been subject to federal jurisdiction. 18 U.S.C. § 3142(f)(1)(D).
+As a result, a defendant with two or more serious state drug felonies or crimes of
+violence (or one of each) is subject to pretrial detention independent of the maximum
+sentence of the current federal felony narcotics charge.
+
+
+rage 11 01 12
+Practice note. When litigating a pretrial detention motion, the legislative history of
+the 1984 Bail Reform Act is a fertile source of authority. For example, it confirms the
+argument that the law reflects a congressional intent to detain defendants who
+co. 98-225 at 307 00 0) trial red in 05 4 0 5. iN 082 dens get see.
+language is:
+The Committee also notes, with respect to the factor of community ties,
+that it is aware of the growing evidence that the presence of this factor
+does not necessarily reflect a likelihood of appearance, and has no
+correlation with the question of the safety of the community.... [T]he
+Committee wishes to make it clear that it does not intend that a court
+conclude that there is no risk of flight on the basis of community ties
+alone ....
+Id., 1984 U.S.C.C.A.N. at 3207.
+Under current law, consideration of a defendant's criminal history is
+confined to his record of convictions. While a prior arrest should not be
+accorded the weight of a prior conviction, the Committee believes that it
+would be inappropriate to require the judge in the context of this kind of
+hearing to ignore a lengthy record of prior arrests, particularly if there were
+convictions for similar crimes. ... In any event, independent information
+concerning past criminal activities certainly can, and should, be considered
+by a court.
+Id. at 3206 n. 76 (citations omitted).
+26.9 Nebbia hearings
+If a monetary or property bond is set, the prosecution may request the court to order
+that-before the release of the defendant—a Nebbia hearing be held to determine whether
+the collateral for the court (or the collateral provided the bail bondsman) is tainted. See
+
+
+Page 12 01 12
+18 U.S.C. § 3142(g)(4); United States - Nebbia, 357 F.2d 303 (2d Cir. 1966). See also
+United States - Patel, 1995 WL 557379 (N.D. III. 1995) (unpublished memorandum
+opinion and order) (notwithstanding the tax returns and testimony tendered by the
+defense, the defense failed to convincingly establish that the properties offered as security
+for the bond "were purchased solely with legitimate funds"). Nebbia-type hearings are
+particularly important when someone other than the defendant is posting the collateral, as
+they present an opportunity for the judge to establish on the record that the sureties are
+hare undertaking, such as potential loss of their
+1097, Sea tried Sales Hammond, 304 supe 20 157, 168-67 ED ME. Cr.
+2002) (sufficiency of the security offered).
+26.10 Resources
+The main treatise on federal detention and bail law is: Hon. John L. Weinberg, Federal
+Bail and Detention Handbook (2003), which is updated regularly. Another source collecting
+decisions on detention cases is: Propriety of denial of pretrial bail under Bail Reform Act,
+75 A.L.R. Fed. 806. Links to relevant internal DOJ monographs and memoranda appear on
+the USABook Bail and Release topic page at
+http://10.173.2.12/usao/eousa/ole/tables/subject/bail.htm.
+26.11 Acknowledgments
+This Chapter was adapted and updated from material originally written by then Senior
+Trial Attorney Robert Lipman, NDDS, for the 1999 edition of Federal Narcotics
+Prosecutions.
+
+
+SOUTHERN DISTRICT OF FLORIDA
+Case No. _
+UNITED STATES OF AMERICA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Notice of Appeal From Magistrate's
+Order Denying Pre-Trial Detention
+Comes now the United States of America, by and through its undersigned Assistant United
+States Attorney, and files this Notice of Appeal from the Order of United States Magistrate Judge
+- U.S. District Court for the
+District of
+, entered
+, 2008, which denied the United States' request for pre-trial detention as to defendant
+on April
+Jeffrey Epstein.
+United States Magistrate Judge
+set a S
+cash bond, with the
+following conditions:
+- The United States gave notice
+of its intent to appeal the bond order and asked the Magistrate Judge to stay execution of the bond
+pending the Court's determination of this appeal. The Magistrate Judge granted the motion and the
+defendant remains in custody.
+Pursuant to 18 U.S.C. § 3145(a), if "a person is ordered released by a magistrate judge, or
+by a person other than a judge of a court having original jurisdiction over the offense ... the attorney
+for the Government may file, with the court having original jurisdiction over the offense, a motion
+
+
+for revocation of the order or amendment of the conditions of release." Accordingly, the United
+States hereby files this emergency motion with the District Judge assigned to the case for immediate
+revocation of the Magistrate Judge's Order.
+THE CHARGES IN THE INDICTMENT
+On April
+› 2008, a Grand Jury sitting in the Southern District of Florida returned a
+twenty-nine-count indictment charging defendant Jeffrey Epstein' with one count of conspiracy to
+use a means of interstate commerce to persuade, induce, or entice nineteen minors to engage in
+prostitution, in violation of 18 U.S.C. § 371; eight counts of knowingly, in and affecting commerce,
+recruiting, enticing, and obtaining eight minors to engage in commercial sex acts, in violation of 18
+U.S.C. §1591(a)(1); twelve substantive counts of using a means of interstate commerce to persuade,
+induce, or entice twelve minors to engage in prostitution or other criminal sexual activity, in
+violation of 18 U.S.C. § 2422(b); one count of conspiracy to travel in interstate commerce for the
+purpose of engaging in illicit sexual conduct, in violation of 18 U.S.C. § 2423(e); and four counts
+of traveling in interstate commerce for the purpose of engaging in illicit sexual conduct with a person
+under 18 years of age, in violation of 18 U.S.C. § 2423(b).
+ere all
+minors at the time of their involvement with defendant Epstein
+vas a resident of New
+York; the remaining Jane Does were all residents of Palm Beach County, Florida, at the time of their
+involvement with defendant Epstein.
+Count 1 carries a statutory maximum sentence of five years' imprisonment. Counts 2
+through 10 each carry a statutory maximum sentence of forty years' imprisonment. Counts 11
+through 23 each carry a statutory mandatory minimum sentence of five years' imprisonment up to
+'Epstein is named as a defendant in twenty-seven counts.
+2
+
+
+a maximum of thirty years' imprisonment. Counts 24 and 26 through 29 each carry a maximum of
+thirty years' imprisonment.
+THE FACTS OF THE OFFENSE
+The investigation of Jeffrey Epstein initially was undertaken by the City of Palm Beach
+Police Department in response to a complaint received from the parents of a 14-year-old girl,
+from Royal Palm Beach. When
+- and another girl began arguing at school because the other girl
+accused
+of being a prostitute, one of the school principals intervened. The principal searched
+'s purse and found $300 cash. The principal asked
+. where the money came from.
+initially claimed that she earned the money working at "Chik-Fil-A," which no one believed.
+then claimed that she made the money selling drugs; no one believed that either.
+finally
+admitted that she had been paid $300 to give a massage to a man on Palm Beach Island.
+parents approached the Palm Beach Police Department ("PBPD") about pressing charges.
+PBPD began investigating the recipient of the massage, Jeffrey Epstein, and two of his
+assistants,
+. PBPD identified approximately 27 girls who went
+to Epstein's house to perform "sexual massages" (not including one licensed massage therapist) or
+who recruited girls to do the same. The girls' ages ranged from 14 years' old to 23 years' old. Some
+girls saw Epstein only once and some saw him dozens of times. The "sexual massages" performed
+also varied. Some girls were fully clothed while they massaged Epstein; some wore only their
+underwear; and some were fully nude. During all of these massages, Epstein masturbated himself
+and he would touch the girl performing the massage, usually fondling their breasts and touching their
+currently is not one of the Jane Does referenced in the indictment.
+IN These are the statutory maximums and minimum
+in effect at the time of the charged achvity. Many of thes
+statutes nov carry significantly stiffer penalties.
+
+
+vaginas - either over their clothing or on their bare skin. Epstein often used a vibrator to masturbate
+the girls and digitally penetrated a number of them. For the girls who saw him more often, Epstein
+graduated to oral sex and vaginal sex. Epstein sometimes brought his assistant/girlfriend,
+, into the sexual activity.
+On October 18, 2005, PBPD obtained a search warrant with the assistance of the Palm Beach
+County State Attorney's Office ("PBSAO"). By this time, PBSAO had already been contacted by
+Epstein's cadre of lawyers. When PBPD arrived at Epstein's home two days later (10/20/05) to
+execute the search warrant, they found several items conspicuously missing. For example, computer
+monitors and keyboards were found, but the CPUs were gone. Similarly, surveillance cameras were
+found, but they were disconnected and the videotapes were gone. Nonetheless, the search did
+recover some evidence of value, including message pads showing messages from many girls over
+a two-year span. The messages show girls returning phone calls to confirm appointments to "work."
+Messages were taken by
+The search also
+recovered numerous photos of Epstein sitting with naked girls whose ages are undetermined.
+Photographs taken inside the home show that the girls' descriptions of the layout of the home
+and master bedroom/bathroom area are accurate. PBPD also found massage tables and oils, the high
+school transcript of one of the girls, and sex toys.
+In sum, the PBPD investigation showed that girls from a local high school would be
+contacted by one of Epstein's assistants to make an appointment to "work." Up to three
+4
+
+
+appointments each day would be made. The girls would travel to Epstein's home in Palm Beach
+where they would meet Epstein's chef and Epstein's assistant-usually
+-in the kitchen. The
+assistant normally would escort the girls upstairs to the master bedroom/bathroom area and set up
+the massage table and massage oils. The assistant would leave and Epstein would enter the room
+wearing a robe or a towel. He would remove the clothing and lie face down and nude on the
+massage table. Epstein would then instruct the girl on what to do and would ask her to remove her
+clothing. After some time, Epstein would turn over, so that he was lying face up. Epstein would
+masturbate himself and fondle the girl performing the massage. When Epstein climaxed, the
+massage was over. The girl was instructed to get dressed and to go downstairs to the kitchen while
+Epstein showered. Epstein would pay the girl-usually $200-and if it was a "new" girl, would ask
+for the girl's phone number to contact her in the future. Girls were encouraged to find other girls to
+bring with them. If a girl brought another girl to perform a "massage," each girl would receive $200.
+The PBPD investigation consists primarily of sworn taped statements from the girls. When
+PBPD began having problems with PBSAO, they approached the FBI. The investigation was
+formally presented to FBI and to me after PBSAO "presented" the case to a state grand jury and that
+grand jury returned an indictment charging Epstein with three counts of solicitation of prostitution.
+The State of Florida has since dismissed its charges after the United States initiated
+prosecution.
+ARGUMENT
+The defendant was arrested in the Northern District of Texas and, today, had a bond hearing.
+The United States sought to have the defendant detained pending trial based upon the presumption
+5
+
+
+of detention as well as the defendant's risk of flight and danger to the community.
+This is a case where detention is presumed, both as to risk of flight and as a danger to the
+community. The law regarding this presumption is as follows:
+Where the Court finds probable cause to believe that the defendant committed one
+of the offenses listed in 18 U.S.C. § 3142(e), [which includes the violations of 18
+USC 2242 and 2243 as charged by the grand jury]?
+a statutory rebuttable presumption arises that no condition or combination of
+conditions will reasonably assure the appearance of the person as required and the
+adult's sexual gratification or for the production of child pornography is also a
+legitimate government objective. One of the fundamental duties of government is
+public safety, including protecting children from sexual predators. ... Once it is
+determined that the presumption applies, the defendant bears a limited burden of
+production to rebut that presumption by coming forward with evidence he does not
+pose a danger to the community or a risk of flight. Once a defendant has met his
+burden of production relating to these two factors, the presumption favoring detention
+does not disappear entirely, but remains a factor to be considered among those
+weighed by the district court.
+United States . Abad, 350 F.3d 793, 797 (8th Cir. 2003) (internal citations omitted).
+In determining how much weight to accord the presumption after the defendant has come
+forward to meet his burden of production, the Second Circuit explains:
+A judicial officer conducting a detention hearing should, even after a defendant has
+come forward with rebuttal evidence, continue to give the presumption of flight some
+weight by keeping in mind that Congress has found that these offenders [who fall
+within the presumption] pose special risks of flight, and that "a strong probability
+arises" that no form of conditional release will be adequate to secure their appearance.
+The judge of magistrate thus should consider those legislative findings among the
+other factors to be weighed in deciding whether a defendant should be detained.
+United States | Martir, 782 F.2d 1141, 1144 (2d Cir. 1986) (internal citations omitted) (discussing
+"A grand jury indictment provides the probable cause required by the statute to trigger the
+presumption. United States . Hurtado, 779 F.2d 1467 (11th Cir. 1985); United States
+Quartermaine, 913 F.2d 910 (11th Cir. 1990).
+6
+
+
+narcotics defendants).
+In United States | Sciacca, one of the district judges in the Southern District of Florida
+summarized the Eleventh Circuit's approach to the analysis of the presumption as follows. Once it
+is determined that the statutory presumption applies based upon the crime charged, then
+"the defendant carries the burden of production to come forward with evidence to
+rebut the presumption." United State v. Quartermaine, 913 F.2d 910, 916 (11th Cir.
+1990). Although the statutory presumption places a burden of production on a
+defendant, the burden of persuasion concerning the dangerousness [or risk of flight]
+emains on the government. United States |. King, 849 F.2d 485, 488 (11th Cit
+988). ... The kind of evidence which a defendant must produce to satisfy his burder
+of production must "suggest that he ... [is] either not dangerous or not likely to flee
+if turned loose on bail." United States . Hurtado, 779 F.2d 1467, 1479 (11th Cir.
+1985). If the defendant produces such evidence, the presumption does not disappear
+but "remains in the case as an evidentiary finding militating against release, to be
+weigh[ed] along with other evidence relative to factors listed in section 3142 (g).
+United States . King, 849 F.2d 485, 488 (11th Cir. 1988).
+Sciacca, (unpublished opinion), Court File No. 03-80164-Cr-Hurley, at pp. 4-5 (S.D. Fl. Feb. 25,
+2004).
+Here, the defendant's blatant disregard of the order of the Florida court regarding his contact
+with the victim shows his continued dangerousness. In addition, there is evidence that he is having
+"romantic" chats with other minors, including one located in Texas.
+Furthermore, in considering a defendant's risk of flight, the Court must consider the
+defendant's ties to the community where the prosecution occurs, not merely his ties to the United
+States at large or the district in which he is arrested. See, e.g., United States . Adipietro, 773 F.
+Supp. 1270 (W.D. Mo. 1991). The only tie that the defendant has to the Southern District of Florida
+is the victim in this case. He is not employed here, does not live here, and does not attend school
+here. The defendant's lack of ties to the Southern District of Florida and the amount of time that he
+7
+
+
+will be facing on federal charges also are evidence of an incentive to flee. Count 1 of the indictment
+carries a five year mandatory minimum sentence, up to a maximum of 30 years, and Count 2 carries
+a maximum of 30 years. Both also carry a recommended supervised release term of life.
+The United States Magistrate Judge in the Northern District of Texas considered these factors
+and determined that a $12,000 cash bond was sufficient to secure the safety of the community in the
+Southern District of Florida and to secure the defendant's appearance at trial.
+For the foregoing reasons, the United States respectfully requests that the Court revoke the
+order of the Magistrate Judge and order the defendant detained pending his intial appearance in the
+Southern District of Florida.
+Respectfully submitted,
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+500 Australian Avenue, Suite 400
+L
+CERTIFICATE OF SERVICE
+I hereby certify that a true and correct copy of the foregoing was served by facsimile this 21st
+day of April, 2006, to Heidi Perlett, Esq. Counsel for Defendant.
+8
+
+
+ASSISTANT UNITED STATES ATTORNEY
+9
+
+
+Memorandum
+Subject
+Third Supplement to Prosecution Memorandum:
+Operation Leap Year: United States |. Jeffrey Epstein, et al.
+Date
+2/19/08
+Chief, Criminal Division
+Deputy Chief, Criminal Division
+Chief, Northern Region
+cc:
+INTRODUCTION
+This third supplement summarizes the changes to the indictment and prosecution
+memo since the first presentation in May 2007. The most significant changes are the
+exclusion of some victims and the inclusion of newly discovered victims. The order of the
+indictment also has been changed.
+For the reasons set forth below, a number of girls who were originally considered for
+the indictment are being excluded at this time. Some may be re-added, but, for strategic
+reasons, I believe that this indictment should focus on victims who are unknown to Epstein's
+counsel. Of the nineteen victims listed in this indictment, eleven were not part of the State
+investigation. Only one of the girls who testified in the state grand jury is included in our list.
+We believe that approximately eight of these girls are unknown to the defense.
+I. VICTIMS DELETED FROM THIS INDICTMENT
+A.
+Persons Recruited by
+• and l
+Myesha Braden and I have discussed the possibility of removing
+and her
+recruits entirely from the indictment because of the amount of press coverage that
+has
+received over her statement to police that she was "like Heidi Fleiss."
+has been very
+inwilling to speak to us and, even after assurances that she would be treated as a victim, sh
+insisted on full immunity before she would meet. Excluding
+also removes much of
+the ammunition about
+and alleged misrepresentations of
+
+
+statements t
+also was the person who instructed the girls to say they were
+18. The evidence related to girls outside her group about knowledge of age is stronger and
+will weaken their defense that Epstein had a rule that all of the girls had to be over 18.
+By removing |
+and treating her as an unindicted co-conspirator, we also make it
+easier to introduce discussions between
+and the other defendants and
+statements to others under the co-conspirator exception to the hearsay rule.
+Applying this approach would result in the potential removal of seven victims (
+plus six others). I have removed six for the following reasons:
+First, I have removed
+was 14 years' old when she was brought to
+Epstein's home by
+., one of the Epstein's main recruiters. At
+instruction,
+lied to Epstein about her age-telling him that she was an eighteen-year-old senior at
+Wellington High School. In her statements to the Palm Beach Police Department and the
+state grand jury,
+admitted that Epstein masturbated in her presence and placed a
+massager/vibrator on her vagina. In
+statement to
+immediately after leaving
+Epstein's home, and in her statement to the FBI and
+admitted that
+Epstein digitally penetrated her. Epstein's criminal activity came to light when
+stepmother learned of a fight between
+and a friend at school over $300 cash found in
+purse.
+cooperated with the Palm Beach Police and made recorded telephone
+calls with
+to set up a second "massage" with Epstein. Handwritten notes were found
+in Epstein's trash confirming this second meeting.
+Despite all of this corroborating evidence,
+is not being included (for now, at
+least) because her father, and stepmother have filed a civil suit against Epstein seeking 'in
+excess of 50 million dollars."
+father is represented by Jeff Herman.
+father
+also has been in frequent contact with the journalist at "Vanity Fair" magazine, and, as
+mentioned in the original pros memo, he has a prior federal fraud conviction. After the suit
+was filed,
+mother filed a motion to intervene and to stay the proceedings until
+turns 18. In her affidavit,
+-mother avers that
+and her father have been estranged
+for several months, and that
+neither knew nor approved of the filing of the lawsuit. If
+mother is correct, we may decide to add
+- into a superseding indictment, but for
+now the safer course is to exclude allegations related to her.'
+' We are monitoring the status of the litigation and intend to subpoena transcripts of relevant
+depositions. There also is a possibility that Epstein's attorneys have violated federal law by
+distributing to the press identifying information about a child sex abuse victim and by harassing that
+2
+
+
+were brought by
+and their appointments were made
+between
+performed one massage and
+performed two.
+For both girls, Epstein masturbated and tried to touch them but they refused. With
+1. Epstein became upset that she wouldn't engage in more sexual activity and he told
+not to bring her back. Because of the highly probative nature of this testimony related to
+Epstein's intent (i.e., no sex/no money), I believe that
+s testimony will be admitted
+under Rule 404(b).
+has been identified as the plaintiff in the second civil lawsuit filed against
+Epstein by Jeff Herman. She was 16 years old when she first went to Epstein's home and
+was recruited by
+., one of
+friends.
+• only went to Epstein's
+home once, never told Epstein her age, and was never contacted directly by any of the
+defendants.
+contribution to the indictment is outweighed by the presence of the
+civil suit, so she has been removed.
+is another girl whom
+recruited.
+was 16 when she first went to
+Epstein's home. She has admitted to providing massages and that Epstein touched her breast
+and attempted to touch her vagina.
+denies any additional sexual activity.
+recruited one other girl,
+., when
+was 17.
+lives in Venezuela and has
+not responded to efforts to contact her. The concern with
+is that she will never
+completely admit to the sexual activity that occurred. Phone records show that
+spoke
+with
+more than 60 times. Yet
+insists that she
+never provided massages fully nude and Epstein never digitally penetrated her, touched her
+vagina, or used the massager/vibrator on her. From all of the evidence, it is highly unlikely
+that Epstein would have allowed
+to return so frequently without increasing the level
+of sexual activity. As one of the other girls reported,
+reputation at school was that
+she "was a virgin the day she graduated." I believe that it will be too difficult for her to give
+up that persona and admit to everything that happened.
+will still remain as a witness, because she can corroborate many of the
+statements made by
+drove
+to Epstein's home and she knew
+hat Epstein gave a vibrator to
+and that Epstein offered to take
+ind to his island.
+knew of other gifts given to
+including
+Secret
+lingerie, birthday flowers, and a rental car.
+victim. A motion may be filed before Judge Marra on the issue of inappropriate contact with and
+harassment of
+3
+
+
+The one
+currently attending
+related to
+will be late because of
+with
+recruit whom I have kept in the indictment is
+She is
+on a l
+scholarship. The documentary evidence
+is strong - numerous message pads, including one saying that
+¡ practice, car rental records, 156 calls with
+, Z calls
+13 calls to Epstein's house, and 20 calls to Epstein's Palm Beach
+property manager. Epstein also gave
+a vibrator and lingerie for her 18th birthday.
+B.
+Although I never intended to use
+,. as a witness, I did refer to her as one of
+the Jane Does in the indictment in connection with a massage that she gave together with
+L.
+can testify as an eyewitness.) In light of the outcry from Epstein's
+attorneys that
+does not consider herself a victim, I have used her initials instead.
+Il.
+VICTIMS ADDED TO THIS INDICTMENT
+A.
+traveled to Epstein's home together while they were students at
+Wellington High School. Both had heard at the school that you could get money for
+massaging Epstein. When they arrived at Epstein's home, they were met by |
+who
+took them on a tour of the house before leading them to Epstein's bedroom. Both sat on the
+couch until Epstein arrived. He arrived shortly thereafter and took a shower. Before he
+stepped into the shower, Epstein told the girls to get undressed.
+removed her
+top and pants;
+only removed her top.
+After the girls massaged his back and legs, Epstein turned over and began
+masturbating. Epstein tried to reach down
+pants, and she backed away.
+Epstein then instructed
+to play with his nipples while he masturbated. After he
+ejaculated, Epstein told the girls to get dressed. He paid each girl $200.
+Afterwards,
+attempted to contact
+multiple times to set up
+appointments, but she refused
+returned, and on her second visit she massaged
+Epstein alone while wearing only her panties. When he began masturbating, Epstein placed
+on the massage table, pushed her underwear to one side, and stroked her vagina.
+He also fondled her breasts.
+received another S200. At some point during her
+visits, Epstein asked
+how old she was, and she told him her true age (17).
+4
+
+
+On one occasion in the Spring of
+junior year, whe
+as 16 vears old, she and
+went to Epstein's
+house together. Epstein asked
+what hich school she wentto and
+answered Palm Beach Central High School.
+took
+upstairs and told
+her to remove her clothing. Both girls were wearing only their panties when Epstein entered
+Epstein laid down and both girls began massaging him. Epstein then asked
+leave. After she left, Epstein began masturbating and grabbing
+ouching her
+all over. When
+pulled away, Epstein would grab her and pull her closer.
+Epstein both digitally penetrated
+and placed the vibrator/massager on her
+vagina.
+was paid $200, but cannot remember who handed the money to her.
+explained that
+never returned, but
+went a few more times.
+would always call to set up the appointments.
+re all referenced in the overt acts section of the indictment.
+The only telephone contact initiated by Epstein's group that resulted in sexual conduct was
+between
+enticement counts. Also, because J
+substantive sex trafficking charge related to
+is the subject of one of the substantive
+told Epstein her true age, I have added a
+B.
+was recruited by
+in approximately July 2004, wher
+was 17.
+told
+that she knew a "filthy rich guy" who would pay girls $200
+to $300 for giving a massage.
+took
+¡ to Epstein's home in a taxi. Epstein
+took a shower before starting the massage and instructed
+o remove her shirt.
+Epstein began masturbating and rubbed
+§ vagina over her panties before pushing
+the underwear aside to stroke her vagina. Epstein told
+'this is normal,
+nothing's wrong." Epstein paid
+$200 to $300. During the ride home,
+told
+that she had been paid and said, "if you bring someone, you'll get $200."
+called about a week later inviting
+to return and telling her that
+Epstein would pay if she brought a friend.
+called
+eight or nine times.
+finally told
+that she moved out of state to stop her from calling.
+i phone records,
+called
+Four times in one day when
+According to
+Epstein was in town.
+is referenced in the overt acts section of the indictment and in one of the
+5
+
+
+substantive counts of travel in interstate commerce to engage in illicit sexual activity.
+C.
+is the first fully-identified New York high school girl. She only
+provided one massage, but became a recruiter for Epstein.
+I first went to
+Epstein's home towards the end of her junior year, when she was seventeen years old. After
+that first massage, Epstein told
+that he would pay her to bring more girls.
+implicates two other Epstein assistants - Lesley Groff and
+We had anticipated that Groff would be a witness, not a target. When the agents went
+to Groff's house to interview her, she went upstairs, claiming she needed to change her
+baby's diaper. While upstairs, she called Epstein, causing Epstein to re-route his flight to
+take
+back to his island. (They were scheduled to fly to New Jersey,
+where the agents had planned to serve
+with target letters.) After this
+meeting with Groff, Epstein's team began negotiating in earnest to end this investigation.
+FBI New York agents are interviewing several girls identified by
+At
+this time, we do not have Lesley Groff's phone records, so we do not have sufficient
+evidence to charge her. She is referred to by her initials in the indictment, and we will
+hopefully be ready to charge her when we supersede the indictment.
+is referenced in the overt acts but is not part of any substantive counts.
+D.
+was recruited by her brother's friend,
+(referred to in
+sent as
+also was the former boyfriend
+recruited several girls to Epstein's home, including
+attended Royal Palm Beach High School with
+knew that
+and the other gins were going to Epsein 5 house, but they ard not know
+about
+told
+that she would receive $200 for providing a massage and
+that she should tell Epstein that she was 18, if he asked. (Epstein never asked.)
+drove
+Lo Epstein's house. L
+describes a similar pattern of activity
+as that faced by the other victims, with Epstein pushing for more clothes to be removed and
+more sexual activity with each visit. On her second-to-last visit, Epstein walked
+6
+
+
+over to a couch, forcibly pushed her panties aside, and digitally penetrated her, without
+her consent.
+is still traumatized by this event. She reports that she went
+through a period of using drugs, but now she is clean and is studying to be a nurse.
+is only about five feet tall and looks barely eighteen now. She is very concerned about
+her family finding out about what happened to her, but she is strongly committed to Epstein's
+prosecution.
+What seems most devastating to
+is that she returned to Epstein's house
+after the forcible digital penetration and brought her friend,
+massaged Epstein's back and legs. When he turned over, Epstein asked J
+remove her shirt. She refused and he became upset and ended the massage. Epstein then
+sent for
+and reprimanded her for not telling
+that she would have
+to perform the massage topless.
+When
+left, they called the Royal Palm Beach Police
+Department, who referred them to the Palm Beach Police.
+spoke
+with someone there and reported what happened. After much searching, the Palm Beach
+Police Department was able to locate a report of this call. The report contains Epstein's
+name and address and the names of both girls and describes Epstein as paying $200 for a
+massage. The girls complained that Epstein insisted that they take off their tops and pants,
+even though he knew that they were 17. The date of the report is March 5, 2004, less than
+two weeks after
+eighteenth birthday, and when
+ras seventeen
+years old. [NB: The police report describes a pattern of activity, including dates when Jane
+was seventeen years old.] Neither
+ever returned to Epstein's
+home.
+Although we have not yet obtained
+telephone records, we were able
+to identify her telephone number, and there are twenty telephone calls that appear on
+- phone records. All of those calls were outgoing (meaning
+called
+The telephone calls range in date from August 27, 2003 through March 3, 2004. The
+phone number is the same one that
+provided to the Palm Beach Police
+Department when she made the report against Epstein.
+never again called.
+made the report to the Palm Beach Police Department.
+Both
+appear in the overt acts portion of the
+Indictment. In addition, a count of use of the telephone to entice
+o engage in
+prostitution has been added. There was no direct telephone contact between
+so a substantive count has not been added related to her.
+7
+
+
+III. OTHER CHANGES TO INDICTMENT
+The overt acts are now organized by victim, or if a group of victims are related, then
+by group, followed by a separate listing of Epstein's travel to Palm Beach. This should make
+the indictment much easier to follow. I also have selected telephone calls that are more
+closely linked to the dates of the sexual activity rather than focusing exclusively on calls near
+flights. The number of overt acts has not significantly decreased for the following reason.
+First, as an initial filing, the included overt acts provide a complete picture of Epstein's
+behavior. The Grand Jury's determination that there is probable cause to believe that all of
+the acts were committed should help persuade the Magistrate Judge and the District Judge
+that Epstein is a danger to the community and that the evidence against Epstein is strong.
+Second, there are cases that suggest that, when a certain number of overt acts are charged in
+a conspiracy count, but the Government seeks to introduce a large number of uncharged overt
+acts, those uncharged acts can serve as a variance from/amendment to the Indictment. One
+of those cases was argued by Gerald Lefcourt - one of Epstein's attorneys. For those
+reasons, I have kept most of the overt acts from the original indictment (excluding those
+related to the Jane Does who have been dropped from the indictment) and have added acts
+related to the new Jane Does. I still plan to supersede the indictment with information about
+additional Jane Does from New York or elsewhere and with potential money laundering
+counts and computer-related counts when those phases of the investigation are completed.
+At the time I supersede, the overt acts can be reduced.
+The counts have been reorganized based upon discussions with Myesha Braden from
+the Child Exploitation Section. She believes that our strongest counts are the child sex
+trafficking violations (18 U.S.C. § 1591). I have moved those counts forward in the
+indictment.
+
+
+
+D.C.Mi.1i8arco
+..1985.
+United States District Court, N.D. Illinois,
+Eastern Division
+UNITED STATES of America, Plaintiff,
+Joseph DiVARCO, et al., Defendants.
+No. 84 CR 507.
+Feb. 6, 1985.
+After conviction by jury on all counts in
+which each defendant was named in indictment, Government moved for detention of
+each of them pursuant to Bail Reform Act,
+claiming each of them was likely to pose
+danger to safety of other persons or community if released. Defendants moved for
+release from detention, launching number
+of constitutional
+attacks on statute.
+The
+District Court, Shadur, J., held that: (1)
+Bail Reform Act did
+not violate Eighth
+Amendment's
+bail; (2) Act did Iscription on
+excessive
+not violate due process on
+ground it was vague or lacked
+standards;
+(3) Act did not violate equal protection; (4)
+detention pending sentencing did not violate defendants' right to counsel; and (5) application of law to defendants did not constitute ex post facto violation.
+Motions for release on bail denied
+West Headnotes
+[1] Bail 49 €m52
+49 Bail
+1911 In Criminal Prosecutions
+49k50 Amount of Bail
+49k52 k. Excessive Bail. Most
+Crov Con or Bail Reform Act which im-
+[2] Bail 49 €- 39
+49 Bail
+491l In Criminal Prosecutions
+49k39 k. Nature and Scope of Remedy. Most Cited Cases
+Although statute requiring that presentence
+convicted defendant establish by clear and
+convincing evidence that he is not likely to
+pose danger to safety of other persons or
+community if released under Bail Reform
+Act did not specify procedures to be followed, it was not invalid on ground it was
+vague or lacked standards, where requirement of judicial officer's finding by clear
+and convincing evidence necessarily connoted hearing, and clear implication of statute was that neighboring provisions dealing
+with hearings for presentence detention
+and specitying tactors to be considered in
+such hearıngs, includıng satety or danger
+of others and community applied to presentence defendant as well. 18 U.S.C.A. §9
+3142(b, c, f, g), 3143(a).
+[3] Statutes 361 €-47
+361 Statutes
+3611 Enactment, Requisites, and Validity in GenkaS Validiy and Suficiency of
+361k47 k. Certainty and Definiteni or en er d go te ein ore
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+precise content by giving examples or by
+establishing laundry list
+[4] Constitutional Law 92 €-889
+92 Constitutional Law
+92VI
+Enforcement of Constitutional
+Provisions
+92VI(A) Persons Entitled to Raise
+Constitutional Questions; Standing
+92VI(A)I0 Due Process
+92k888 Criminal Law
+92k889 k. In General. Most
+Cited Cases
+(Formerly 92k42.1(3))
+Detendants challenging provision of Bal
+Leform Act requiring that presentence con
+victed defendant establish by clear and
+convincing evidence that he is not likely to
+pose danger to safety of other persons or
+community if released on bail
+could not
+challenge
+of statute
+ground that term "danger
+on
+constitutionality lacked meaning
+as to them, where defendants were tied by
+and mony tornar realton natin
+potential for retaliation against
+witnesses.
+18 U.S.C.A. §§ 3142(b, c),
+3143(a).
+[5] Bail 49 €- 49(4)
+49 Bail
+491l In Criminal Prosecutions
+49K49 Proceedings to Admit to Bail
+49k49(3) Evidence
+49K49(4)
+K.
+Presumptions
+and Burden of Proof. Most Cited Cases
+Bail 49 €- 49(5)
+49 Bail
+4911 In Criminal Prosecutions
+49k49 Proceedings to Admit to Bail
+49k49(5) k. Hearing and Determination. Most Cited Cases
+Court assured both adequate notice of al-
+[6] Bail 49 €m 49(3.1)
+49 Bail
+4911 In Criminal Prosecutions
+49k49 Proceedings to Admit to Bail
+49k49(3) Evidence
+49k49(3.1) k. In General.
+Most Cited Cases
+(Formerly 49K49(3))
+Rules of evidence do not limit conduct of
+bail hearings, even those resulting in detention; thus, hearsay may be considered,
+with judge applying his or her experience
+as fact finder to decide extent to which it is
+to be credited or discredited because of insuficient reliability.
+[7] Constitutional Law 92 €m4653
+92 Constitutional Law
+92XXVII Due Process
+92XXVII(H) Criminal Law
+92XXVII(H)5 Evidence and Witnesses
+92K4653 K. Presumptions, In
+ferences, and Burden of Proof. Most Citec
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619... 4/10/2008
+
+
+
+[8] Constitutional Law 92 €~3797
+92 Constitutional Law
+92XXVI Equal Protection
+92XXVI(F) Criminal Law
+92k3797 k. Bail. Most Cited Cases
+(Formerly 92k250.2(1))
+Bail 49 €-42
+49 Bail
+4911 In Criminal Prosecutions
+49k41 Right to Release on Bail
+49k42 k. In General. Most Cited
+(Formerly 92k250.2(1))
+Where occasion for court's present determination was not offense leading to conviction but postconviction threat to satety
+and class defined by
+Congress as en cosited date dants d by
+represented such societal threat bore
+direct imaginable nexus to remedy of depending sentencing, Ball Retorm
+Act's failure to distinguish between those
+victed but not yet sentenced unless he esraised no
+equal protection
+J.S.C.A. Const.Amend. 5; 18 U.S.C.A. s
+3143.
+[9] Bail 49 €m 39
+49 Bail
+49I1 In Criminal Prosecutions
+49k39 k. Nature and Scope of Remedy. Most Cited Cases
+Court may structure conditions of presen-
+Amendment right to
+counsel.
+• U.S.C.A.
+Const.Amend. 6; 18 U.S.C.A. §§ 3142(b,
+c), 3143(a).
+[10] Constitutional Law 92 €~2790
+92 Constitutional Law
+92XXIII Ex Post Facto Prohibitions
+92XXIII(A) Constitutional Prohibitions in General
+92k2790 k. Punishment in General. Most Cited Cases
+(Formerly 92k203)
+Absent "punishment," there is no ex post
+facto problem. U.S.C.A. Const. Art. 1, § 9,
+cl. 3.
+[11] Constitutional Law 92 € 2810
+92 Constitutional Law
+92XXIII Ex Post Facto Prohibitions
+92XXIII(B)
+Particular
+Issues
+Applications
+92k2809 Criminal Proceedings
+92k2810
+. In
+General. Most
+Cited Cases
+(Formerly 92k199)
+Bail 49 €m 42
+49 Bail
+4911 In Criminal Prosecutions
+19k41 Right to Release on Bail
+49k42° k. In General. Most Cited
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+Page 4
+beyond reasonable doubt that defendants
+had committed crimes, application of statute to them did not constitute impermissible ex post facto law. U.S.C.A. Const. Art.
+1, 8 9, cl. 3; 18 U.S.C.A. § 3143
+*1031 Judith Dobkin, John Scully, Sp. At-
+tys., U.S. Dept. of Justice, Chicago, III., for
+plaintiff
+Elliot Samuels.
+P. Lynch, Chicago,
+III., Joseph M. Larala, Wheaton, III., for
+defendants.
+MEMORANDUM OPINION AND OR-
+DER
+SHADUR, District Judge.
+On January 9,
+1985 each of Joseph Di-
+Varco ("DiVarco") and Ronald Ignotto
+("Ignoffo") was convicted by a jury on all
+counts in which he was named in the indictment in this case. On January 10 the
+government moved for the detention of
+each of them pursuant to the Bail Reform
+Act of 1984
+"Act"),
+18 U.S.C. §
+3143(a) ("Section 3143(a)),NI claiming
+each of them (though not any of their four
+convicted codefendants) was likely to pose
+a danger to the safety of other persons or
+the community if released pursuant to Sections 3142(b) or (c).
+FNI. All other citations to Title 18
+(as amended by the Act) will also
+simply take the form "Section-."
+Citations to the Act's internal numbering will take the form "Act §-."
+had not shown by clear and convincing
+evidence that he was not likely to pose
+such a danger. Accordingly Ignoffo was
+ordered detained in accordance with Section
+3143(a)."2 DiVarco's hearing was
+not concluded because his doctors recommended
+he be hospitalized.fs However,
+testimony
+sassination of Ken Eto, a witness in the trial of this case), this Court ordered DiVarco
+committed to the custody of the Attorney
+General for confinement at Bethany Methodist Hospital pending imposition of sentence (subject, of course, to a possibly different resolution if the Hearing were completed before that time). ENa
+FN2. Exhibit 1 to this memorandum
+opinion and order is this Court's order of detention as to Ignoffo.
+FN3. At that time DiVarco's doctors
+considered him an imminent pneu-
+Hearing as to Ignoffo, this Court found he
+of a pacemaker, which has since
+been done. DiVarco is now recuperfrom that operation
+should be capable of discharge from
+the hospital shortly, though a later
+hearing on that subject has disclosed further complications in his
+physical condition.
+FN4. Exhibit 2 to this memorandum
+pinion and order is this Court's o
+er of detention as to DiVarco
+Both DiVarco and Ignoffo have now
+ing anuber of constitional attack aunch-
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+Section 3143(a). For the reasons stated in
+this memorandum opinion and order, their
+motions are denied.
+Page 5
+Changed Standards Under the Act
+Two of this Court's colleagues have recently dealt with the constitutionality of
+of the Act: Judge Har
+i United Statesos Hazzard, 598 f. Hap
+person or to the community. If such a risk
+of flight or danger is believed to exist ...
+the person may be ordered detained
+Pre-Act law also imposed the burden of establishing the absence of such danger on
+the convicted defendant-at least one who
+has already been sentenced. Although early
+case law under 18 U.S.C. § 3148 had
+treated its language as continuing to create
+1985) (detention after sentencing and
+pending appeal, based on the likelihood of
+reversal
+on appeal). Though the constitutional considerations in those situations are
+obviously related to the considerations applicable to the present question, the distinc
+ions among the
+several
+situations make
+neither of the earlier analyses controlling
+here.
+Here we deal with already-convicted but
+not-yet-sentenced defendants, as to each of
+whom the decision of detention or release
+is based on whether he "is not likely to ...
+posson orange coo munis it leased ofter
+tion 3143(a)). Just
+such a likelihood of
+danger was an established basis for denybail under former law,
+18 U.S.C. §
+3148 (repealed by Act § 203(a)):
+A person ... Who has been convicted of ar
+offense and is either awaiting sentence or
+sentence review under section 3576 of this
+title or has filed an appeal or a petition for
+a writ of certiorari, shall be treated in accordance with the provisions of section
+3146
+[establishing
+conditions of release]
+unless the court or judge has reason to believe that no one or more conditions of release will reasonably assure that the person
+will not flee or pose a danger to any other
+to that Rule):
+to allocate to the defendant the burden of
+establishing that he will not flee and that h
+oses no danger to any other person or to
+the community. The burden is placed upon
+the defendant in the view that the fact of
+his conviction justifies retention in custody
+in situations where doubt exists as to
+whether he can be safely released pending
+disposition of his appeal.
+See discussion in Provenzano, 605 F.2d at
+93-95.
+Thus the allocation of proof as to the dangerous post -sentence detendant is clear
+But this Court has not located any case,
+either under prior law or under the Act
+dealing with the burden-of-proof question
+in the post-conviction pre -sentence situation such as DiVarco's or Ignoffo's. It
+would surely seem, however, that Congress
+might reasonably have viewed the single
+fact of conviction (as opposed to the precise timing of a detention decision-whether pre-sentence or post-sentence) as determinative, so as to equate the burden of
+roof in any post-conviction situation t
+hat defined in Rule 9(c) (see the later dis
+cussion of this subject). In any event, the
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-...
+
+
+
+Act has now changed the burden on the
+convicted defendant (both pre-sentence and
+post-sentence) to one of "clear and convincing evidence." FNS
+FN5. Thus the shift from old 18
+U.S.C. § 3148 and Rule 9(c) to Section 3143(a) involves two changes:
+1. from "the judge has reason to
+believe that no ... conditions of release will reasonably assure that
+the person will not
+• pose :
+danger....
+" to "the judicial officer
+finds
+... that the person is not
+likely to .. pose a danger...."; and
+2. from "the burden of establishing...
+rests with the defendant" to
+"the judicial officer finds by clear
+and convincing evidence....
+It is always difficult to convert the
+semantics
+such differently
+stated standards into a
+quantified
+comparison. Here the
+"reason
+believe" test in the first pairing
+might
+arguably
+be
+viewed
+harder for a
+defendant to
+overcome than
+its "finds not likely"
+counterpart.
+Conversely
+and convincing" is plainly a more
+difficult burden for the defendant
+than a mere preponderance.
+Thus
+factors
+might be perceived as pointing in different 'dir-
+Page 6
+Constitutional Considerations FNs
+FN6. All the detention provisions
+of the Act have been drawn from
+the corresponding provisions of th
+District
+Columbia
+(Sections 23-1321
+Code
+to
+23-1327),
+where they have been in effect since
+enactment of
+the
+District
+of
+Columbia Court Reform and Criminal Procedure Act of 1970. Section
+3143(a)
+counter-part
+8 23-1325(b). In United
+Staleso* Edwards, 430 A.2a 1321
+(D.C.1981) (en banc) the District of
+Columbia Court of Appeals dealt
+with the constitutionality of various
+of those provisions in an extended
+opinion (with some dissents on different issues).
+1. Eighth Amendment
+At the outset it should be made clear the
+"right to bail" here-at least in terms of a literal constitutional right-is plainly a misnomer. What the Eighth Amendment says
+on the subject is simply this:
+Excessive bail shall not be required.... In
+Carison 1 Landon, 342 U.S. 524, 72 S.Ct.
+525, 96.
+L.Ed. 547 (1952) the Supreme
+Court rejected (albeit in dictum) the notion
+that because excessive bail cannot be set,
+the outright denial of bail must a fortiori be
+foreclosed. Instead the Eighth Amendment
+was there taken to mean that if an individual is found entitled to bail at all, the right
+created by that determination cannot be
+subverted by an unreasonably high bail setting (id. at 545, 72 S.Ct. at 536):
+BET E
+provide that bail shall not be excessive in
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+those cases where it is proper to grant bail.
+When this clause was carried over into our
+Bill of Rights, nothing was said that indicated any different concept. The Eighth
+Amendment has not prevented Congress
+from defining the classes of cases in which
+bail shall be allowed in this country.
+There is room for debate on that score in
+he pre-conviction context, fueled in par
+›y a dictum in Stack . Boyle, 342 U.S
+1. 72 S.Ct. 1, 3, 96 L.Ed. 1 (1951) (decide
+he same term as Carlson ) (emphasis it
+original):
+From the passage of the Judiciary Act of
+1789, 1 Stat. 73, 91, to the present Federal
+46(a)(1), federal law has unequivocally
+provided that a person arrested for a noncapital offense shall be admitted to bail.
+traditional
+right to freedom before
+conviction permits the unhampered preparation of a defense, and serves to prevent
+viction. See Hudson ament prior to con-
+Parker, 156 U.S
+218.51. Unless this right 10 bail before trial
+is preserved, the presumption of innocenturies of
+struggle, would lose its meaning.
+this area,
+For an extended discussion of tesswards
+see United
+States
+430 A.2d 1321, 1325-31 (D.
+banc).
+But even the Stack dictum addresses the
+Tendant. As for the patst category of of.
+fender Justice Douglas,
+civil liberties, spoke to the issue i
+pacity as Circuit Justice in Carbe i United
+States, 82 S.Ct. 662, 666, 7 L.Ed.2d 769
+Page 7
+It, for example, the satety of the com
+munity would be jeopardized, it would be
+irresponsible judicial action to grant bail.
+Accord, Harris | United States, 404 U.S
+1235-36,
+Justice); and see Russell |
+United States,
+402 F.2d 185, 187 (D.C.Cir.1968):
+Appellants will remain in custody not be
+cause they lack the means to make bail, bu
+for the reason that their release would
+present danger to the community.
+But see Sellers _ United States, 89 S.Ct.
+36, 38, 21 L.Ed.2d 64 (1968) (Black, J.,
+Circuit Justice) (questioning whether a defendant's dangerousness can ever justify
+denial of bail).
+!!] This Court therefore rejects, as to convicted defendants DiVarco and Ignoffo, the
+unconstitutionality of Section 3143(a) on
+Eighth Amendment
+grounds.FN7
+If
+fendants are to find relief, it must be elsewhere in the Constitution.
+FN7. There are cases that express
+Some debt on 8 Fee, 948.
+Roth,
+F.2d
+1158-62 (8th Cir.1981). But they do
+so on the theory that a wholly arbit
+rary denial of bail is the functiona
+equivalent of "excessive bail," thus
+2. Due Process Clause
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+Both DiVarco and Ignoffo advance a potpourri of challenges to the procedure under
+the Act. None is persuasive, and none calls
+for more than brief discussion. FNs
+FN8. True enough, just last year the
+Supreme Court
+Martin,
+467 U.S. 253,
+5. 2 3 04 5. 0.
+2403, 2410, 81 L.Ed.2d 207 (1984):
+In Bell Wolfisin, 441 U.S. (520],
+at 534
+18714m. 15(60 LiEd.28 447
+[60 L.Ed.2d
+447
+(1979) ], we left open the question
+whether any governmental objectve other than ensuring a detainee's presence at trial may constitutionally justify pretrial detention.
+But Schall itself upheld in due
+process terms (at least as to juvenles) a system of pretrial detention predicated on
+*the combined
+in protecting
+community and the juvenile himself from the consequences of future criminal conduct....
+the detained person has already
+been tried and found guilty of another crime (as have
+DiVarco and
+Ignoffo), the powerful consideraconce whichr endergirds all our
+concerns about pretrial detention,
+viewed as punishment, see Stack,
+342 U.S. at 4, 72 S.Ct. at 3) loses
+its force. It would be a mistake to
+Page 8
+*1035 2|3|4||||| Though they call
+and lack of staradards, DiVarco and ignoss
+attack Section 3143 in both procedural and
+substantive due process terms. It is true the
+statute does not specifically prescribe the
+procedures to be followed. But its requirement of a judicial officer's "find[ing] by
+clear and convincing evidence" necessarily
+connotes a hearing, and the clear implication of the statute is that the neighboring
+provisions of Sections 3142(f), (dealing
+safety or danger to other persons and the
+community) apply to Section 3143(a) as
+well. eve This Court in fact conducted just
+such a hearing. In that light the DiVarco-Ig-
+noffo arguments evanesce:
+FN9. Among other things, Section
+3143(a) says a finding of no danger
+results in a release order under Section 3142(b) or (c). Section 3142(f)
+provides for the
+"detention
+hearing" to see which if any conditions
+under
+one
+of
+those
+very
+sections-Section 3142(c)-should apply. Section 3142(g) speaks of the
+factors to be considered at such a
+hearing. That statutory structure of
+course creates a common-sense link
+between the
+Section 3143(a) requirement of a minding, on the one
+hand, and the Section 3142(f) hear
+ing
+procedures and the Section
+3142(g) factors, on the other.
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+tential danger to other persons or the community: That triggers the need for a judicial
+determination of the issue, and hence a
+hearing•
+2. By its very nature, such "danger" can
+take a number of forms. Nothing requires
+Congress to substitute the particular for the
+generic-to give the term more precise content by giving examples or by establishing
+a laundry list. Certainly DiVarco and Ig-
+assassinations aed with their prential for
+retaliation against witnesses here), cannot
+claim the concept of danger to others or the
+community is devoid of content in their
+cases. That would follow a fortiori from
+such cases as Provenzano, 605 F.2d at
+constitutes a
+"sufficient showing" of the likelihood of
+such danger, that is no different from any
+other factual determination courts are regularly called upon to make.
+3. By imposing the burden of going forward at the Hearing on the government and
+by according to each defendant and his
+counsel as much time as they found necessary to deal with the government's charges,
+this Court assured both adequate notice of
+the allegations against the defendants and
+ample opportunity for a meaningtul defense. Edwards, 430 A.2d at 1339-41.
+4. Even in full-blown criminal trials, the
+Sixth Amendment's Confrontation Clause
+poses the only constitutional objection to
+hearsay evidence. And it has always been
+Page 9
+provision of Fed.R.Evid. 803(24) _and
+804(b)(5) (which some thoughtful academicians and courts have suggested ought to
+upplant entirely the particularızed excep
+ions to the hearsay rule) permit essentially
+that result even in the more formal environment of a trial. On this issue generally, see
+Edwards, 430 A.2d at 1337-38.
+5. Burden of proof allocations do not necessarily implicate due process require-
+Be but of pro a as a the post
+conviction, post-sentencing situation) of
+negating his or her likely danger to other
+persons or the community where that was
+placed in issue. And so long as the issue is
+one of likelihood of danger, it appears rational for Congress to
+have cquated the
+convicted felon before sentencing with the
+same convicted felon after sentencing for
+rationality of the congressional decision
+that the burden of proof in the two situations should be exactly the same. Once
+that determination is made, the use of a
+"clear and convincing" rather than a preponderance test does not appear to cross
+the borderline into a due process no-man's
+land. ENO
+FN10. Candor compels the disclosure that this Court has found no
+case law (nor have the parties cited
+any) on this subject.
+3. Equal Protection Clause
+is to be credited or discredited because of
+insufficient reliability. In fact the catchall
+those convicted of misdemeanors and those
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+convicted of felonies, and between those
+convicted of nonviolent and those convicto problems. Devas pists related issues in a different way: Section 3143's presumption against all convicted defendantsregardless
+of their
+offenses
+rounds-bears no rational relationship tc
+egitimate governmental interests of protecting
+the community (including other
+persons).
+[8] Ot course the distinctions between ofenders made by Ignoffo cut against rathe
+han for him, except the comparison baser
+on the nonviolent nature of the offenses of
+which he has been convicted. That fact-that
+he is on the wrong side of two of the three
+comparisons-creates standing questions as
+to his ability to raise such other claims. But
+even apart from that,
+what both Ignoffo
+and DiVarco gloss over is that the occasion
+for this Court's present determination is not
+the offense leading to the conviction but
+the post-conviction threat to safety posed
+by the detendant.
+That
+the
+class
+Congress has defined-all convicted defendants who represent such a societal threatand that class bears the most direct imaginable nexus to
+the remedy: detention
+pending sentencing. There can
+be no quarrel with the rationality of that classification
+for Equal Protection Clause purposes. NIz
+FN11. This distinction is touched
+on more fully in the ex post facto
+discussion later in this opinion.
+Page 10
+danger to other persons or to the
+community).
+4. Effective Assistance of Counsel
+[9] DiVarco says detention pending sentencing effectively negates his right to ap-
+Both those arguments are essentially Sixth
+presentence detention so as to preserve
+those rights to a defendant.
+But not that to of titan
+5. Ex Post Facto Clause
+Up to this point DiVarco and Ignoffo have
+truck out on all the grounds they asser
+That leaves for consideration only the e
+post facto question-a question that (given
+Judge Getzendanner's opinion invalidating
+a related provision of the Act on that score)
+bears careful scrutiny.
+Because this Court is not called upon to decide the same issues as Judge Getzendanner or Judge Hart, and because orderly jurisprudence
+dictates the non-decision
+constitutional questions until they must be
+resolved in the crucible a t
+versy (see Ashwander
+297 U.S.
+56 S.Ct. 466, 482-83, 80
+L.Ed. 688 (1936) (Brandeis, J., concurring)), nothing in this opinion should be
+construed as either subscribing to or diseither Cirrincione or Hazzard
+But as both the extended analysis in Czaincione and the shorter treatment in Hazzard
+reflect, the key to ex post facto vulnerability vel non in this case is whether, in the
+words of the most recent Supreme Court
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-...
+
+
+
+Graham, 450 US. 2h, s0, 50 Scl. 96d.
+965, 67 L.Ed.2d 17 (1981), a defendant's
+Paunishment has been increased by the new
+The presence or absence of an affirmative,
+enforceable right is not relevant, however,
+to the ex post facto prohibition, which forbids the imposition of punishment more
+severe than the punishment assigned by
+aw when the act to be punished occurrec
+Critical to relief under the Ex Post Fact
+Clause is not an individual's right to less
+punishment, but the lack of fair notice and
+governmental restraint when the legislature
+punishment beyond what was
+prescribed
+when the crime was consummated. FNI3
+FN13. Other facets of Ex Post Facto
+Clause coverage, such as its prohibition of (1) retrospective changes in
+fenses available when the crime was
+committed, are plainly not in issue
+It is true Weaver, id. at 29, 101 S.Ct. at 964
+also speaks in terms of the challenged law
+"disadvantag[ing] the offender affected by
+it." But that characterization alone is oversimplistic, for the Supreme Court itself has
+consistently
+taught
+"disadvantage" is vulnerable under the
+Clause, and the core inquiry remains the
+eat Braise 363
+tive increase in punishment. As De
+U.S. 144,
+160, 80
+S.Ct.
+146, 1155, 4 L.Ed.2d 1109 (1960)
+put it:
+"he mark of an ex post facto law is the im
+unishment for past acts. The question it
+Page 11
+each case where unpleasant consequences
+are brought to bear upon an individual for
+prior conduct, is whether the legislative
+aim was to punish that individual for pas
+activity, or whether the restriction of the
+individual comes about as a relevant incident to a regulation of a present situation....
+Just last Term the Supreme Court held pretrial detention to protect society from the
+potential consequences of predictable crin
+inal acts was not punishment. Schall
+Martın,
+104 S.Ct. at 2412-13 (1984).FN1
+*1038 Though that decision was renderer
+in the context of juveniles (with their special right and disabilities), the same punishment
+non-punishment analysis. was
+ane years carlic in Bell Taolisha, nee
+Wolfish, 44]
+U.S. 520, 535, 537, 538, 99 S.Ct. 1861,
+1871, 1873, 1874, 60 L.Ed.2d 447 (1979)
+(citations omitted):
+FN14. Schall and a number of the
+other cases discussed in the text disfacto) purposes.
+seems
+"punishment" logical reason. the
+concept should be
+given any different content in construing the two constitutional provisions, this Court has felt free to
+draw on the due process cases in
+this Ex Post Facto Clause discussion.
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-... 4/10/2008
+
+
+
+cordance with due process of law.
+Not every disability imposed during pretrial detention amounts to "punishment" in
+he constitutional sense. however. Once the
+Jovernment has exercised its conceded authority to detain a person pending, trial, it
+obviously is entitled to employ devices that
+are calculated to effectuate this detention.
+Traditionally, this has meant confinement
+in a facility which, no matter how modern
+or how antiquated, results in restricting the
+movement of a detainee in a manner in
+which he would not be restricted if he
+simply were free to walk the streets
+pending trial. Whether it be called a jail, a
+prison, or a custodial center, the purpose of
+the facility is to detain. Loss of freedom of
+and privacy are inherent incidents
+of confinement in such a facility. And the
+fact that such detention interferes with the
+detainee's understandable desire to live as
+comfortably as possible and with as little
+restraint as possible during confinement
+does not convert the conditions or restrictions of detention into "punishment."
+This Court has recognized a distinction
+between punitive measures that may not
+constitutionally be imposed prior to a determination of guilt and regulatory restraints that may.
+A court must decide whether the disability
+is imposed for the purpose of punishmen
+or whether it is but an incident of som
+Page 12
+ternative purpose assigned [to it]."
+What is at work under Section 3143 is not
+punishment for past conduct but the protection of society generally, and its individual members particularly, from reasonably predictable future conduct. Schall, 104
+S.Ct. at 2417-18 (citations omitted) said:
+Our cases indicate, however, that from a
+legal point of view there is nothing inherently unattainable about a prediction of future criminal conduct. Such a judgment
+forms an important element in many decisions, and we have specifically rejected
+the contention, based on the same sort of
+sociological data relied upon by appellees
+and the district court, "that it is impossible
+to predict future behavior *1039 and that
+the question is so vague as to be meaningless.
+That calls into play the concept our Court
+of Appeals applied to the Ex Post Facto
+_1390-91 (7th
+(quoting United States | Karnes, 437 F.2d
+284, 289-90 (9th Cir.), cert.
+denied, 402
+U.S. 1008, 91 S.Ct. 2189, 29 L.Ed.2d 430
+(1971)):
+It is well established "that where Congress
+has rationally concluded that persons who
+have demonstrated a tendency in the past to
+engage in conduct that Congress has the
+power to proscribe, Congress may restrict
+such future activities without violating the
+Ex Post Facto prohibition."
+turn on "whether an alternative purpose to
+which [the restriction] may rationally be
+connected is assignable for it, and whether
+it appears excessive in relation to the al
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+- 602 F.Supp. 1029
+other than "punishment." Absent punishment there is no ex post facto problem.
+Hound beyond a reasonable doubt alt Di
+Varco and Ignoffo have committed crimes.
+Surely society cannot be less entitled to
+protect itself and its members against what
+this Court has found the likelihood of real
+dangers-dangers that would be posed by
+the continued enlargement of convicted detendants
+Ignoffo
+pending their sentencingnd
+DiVarco
+FN1S
+FN15. This does not of course im-
+Plarco. Because the statase places
+Because
+the statute places
+the burden on him, and because the
+evidence during
+the Hearing to this
+point demonstrates a real probabil-
+a danger to the
+safety of othorin his release pending
+completion of the Hearing would be
+improper.
+Conclusion
+Section 3143 is not vulnerable to constitutional onslaught, either on its face or as ap-
+DiVarco
+and gnoffo."NIs Both
+Pheid motions for release on bail pending
+sentencing are denied.
+FN10. After this opinion was completed (and indeed signed and ready
+for issuance), this Court learned of
+the very recent decisions by three
+Courts
+of Appeal reaching a result
+opposite to that of Judge Getzendanner's Cirrincione opinion in
+the post-appeal situation
+Section
+3143(b).
+United States
+Powell and other
+consolidated cases (8th Cir.) (order
+follow);
+United
+Sates opinick, 00. 84-2630 (ited)
+Page 13
+Cir.) (same). In addition, on Januar
+26 our own Court
+of
+Appeal:
+entered an
+unpublished
+order
+(non-citeable and
+non-precedential
+under Circuit Rule 35) affirming
+Judge Kanne's decision rejecting |
+HCR
+83-36-33 (N.D.Ind
+Jan. 9, 1985). In accordance with
+he Ashwander principles reterrec
+to carlier in the text, this Court of
+course continues
+express
+opinion on the substantive issue
+cases.
+-to determine how if at all that opinion may be
+useful here. As to that:
+1. Miller, at 21 gives very short
+shrift to the ex post facto issue,
+simply declaring the "availability
+vel non of bail pending appeal, albeit extremely important to the individual involved, is a procedural
+issue rather than a type of punishment to which the Ex Post Facto
+Clauses apply."
+2. None of the other constitutional
+Issues raised by DiVarco, or Ig
+noffo here was discussed in
+Suffice it to say that (not surprisingly, given the Court of Appeals
+ruling) nothing it
+points to
+a different result in this case. Nor
+does it appear any more likely that
+Footpote would do soes cited in this
+
+*1040 Exhibit 2
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+0 Sup 1029
+UNITED STATES OF AMERICA,
+Plaintiff,
+Page 14
+1. DiVarco shall be allowed monitored visits trom
+his immediate family (his wife,
+their children and their children's spouses).
+All such visits are to be prearranged
+through the United States Marshal's :
+JOSEPH DiVARCO, et al., Defendants.
+NO. 84 CR 507
+DETENTION ORDER
+3. United States Probation Officer Rhoda
+Di Varco by are aranged appointed access 1o
+4. DiVarco shall be provided telephone access to his immediate family (see Paragraph 1) if such access can be secured
+through the United States Marshal's Service. Such access shall not include a direct
+on all counts in the indictment in
+which he was named in this case. On January 10 the government moved for Di-
+Varco's detention pursuant to 18 U.S.C. §
+3143(a). This Court
+immediately commenced a detention hearing (see 18 U.S.C
+§ [3142] (f), found that the government
+had presented credible evidence that established prima tacie though this Court has
+not at this time definitively found) that Di-
+Varco was likely to pose a danger to the
+safety of other persons or the community if
+released pursuant to 18 U.S.C. §9 3142(b)
+or (C) and that DiVarco had not yet established by clear and convincing
+evidence
+that he was not likely to pose such danger,
+and therefore ordered DiVarco detained
+completion of the hearing
+completion of the hearing was not feasible
+, in part because DiVarco's
+counsel advised that DiVarco's doctors had
+directed his hospitalization to avoid the
+possibility of his contracting pneumonia.
+In accordance with 18 U.S.C. § 3143(a)
+his Court hereby orders that DiVarco be
+committed to the custody of the Attorney
+General for confinement at Bethany Methodist Hospital pending imposition of sentence, upon the following conditions:
+5. No access shall be provided the United
+States Marshal's Service to DiVarco's medical records, nor shall any Marshal discuss
+DiVarco's medical condition with hospital
+personnel.
+/s/ Milton I. Shadur
+Milton I. Shadur
+United States District Judge
+Date: January 11, 1985
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-... 4/10/2008
+
+
+
+J.S. _ Rourke
+.C. Va., 1985
+United States District Court,E.D.
+Nortfolk Division.
+UNITED STATES of America, Plaintiff,
+John ROURKE, et al., Defendants.
+Crim. No. 84-94-N.
+June 21, 1985.
+On defendant's motion for bail pending appeal, the District Court, Doumar, J., held
+that: (1) defendant was not entitled to bail
+pending appeal; (2) Bail Reform Act of
+1984 is not an ex post facto law; and (3) no
+manifest injustice resulted in ordering defendant to begin serving his sentence
+pending appeal.
+Motion denied.
+West Headnotes
+[1] Bail 49 €-44(1)
+49 Bail
+4911 In Criminal Prosecutions
+49k41 Right to Release on Bail
+49k44 Pending Appeal or Other
+Proceeding for Review
+49K44(]) K. In General; Conditions. Most Cited Cases
+edy. Most Cited Cases
+Constitutional Law 92 €~2810
+92 Constitutional Law
+2XXIII Ex Post Facto Prohibition
+2XXIII(B) Particular Issues an
+Applications
+92k2809 Criminal Proceedings
+92k2810 k. In General. Mos
+Cited Cases
+(Formerly 92k199
+ail Reform Act of 1984 [18 U.S.C.A. ‹
+3onst AnolaS excost facto law. V.S.C.A.
+[3] Bail 49 €m 44(1)
+4911 In Criminal Prosecutions
+49k41 Right to Release on Bail
+49k44 Pending Appeal or Other
+Proceeding for Review
+49k44(1) k. In General; Conditions. Most Cited Cases
+No manifest injustice resulted in ordering
+defendant, who had been admitted to bail
+before effective date of Bail Reform Act of
+1984 |18 U.S.C.A. § 3143), to begin
+serving his sentence pending appeal, under
+rationale that even under Bail Reform Act
+of 1966 release on bail was modifiable and
+never a vested right, or under interpretation
+12] Bail 49 €m 39
+49 Bail
+49I1 In Criminal Prosecutions
+49k39 k. Nature and Scope of Rem-
+John Rourke.
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+MEMORANDUM ORDER
+DOUMAR, District Judge.
+On March 14, 1985, the defendant, John
+Rourke, was convicted of 21 U.S.C. § 963
+to import cocaine and 21
+dict of guilty and an evidentiary hearing,
+the Court ordered that Rourke, an accomplished pilot and the aviation consultant to
+Room Act of 194 The Cour pose.
+clines to modify that judgment for the reasons which follow.
+Following the preparation of a pre-sentence
+report, the Court sentenced Rourke on May
+3, 1985 to concurrent imprisonment terms
+of fourteen (14) years on both counts.
+Rourke now moves for bail pending appeal
+under 18 U.S.C. § 3143(b) as he remains
+incarcerated under the sentence imposed on
+May 3,
+1985. Rourke argues that (1) the
+Bail Reform Act of 1984 15 an ex post jacio
+law as applied to him and (2) that the statute does not apply retroactively to a defendant like Rourke admitted to bail prior
+to the Act's passage.
+detained, unless the judicial officer finds
+by clear and convincing evidence that the
+person is not likely to flee or pose a danger
+to the safety of any person or the comsions of section 3142(b) or (c).
+(b)
+RELEASE
+DETENTION
+PENDING APPEAL BY THE DEFEND-
+ment, and who has filed an appeal or a petition for a writ of certiorari, be detained,
+unless the judicial officer finds-
+(1) by clear and convincing evidence that
+the person is not likely to flee or pose a
+danger to the safety of any other person o
+the community if released pursuant to section 3142(b) or (c); and
+(2) that the appeal is not for purpose of
+delay and raises a substantial question of
+law or fact likely to result in reversal or an
+order for a new trial.
+If the judicial officer makes such findings,
+he shall order the release of the person in
+accordance with the provisions of section
+3142(b) ог (с).
+18 U.S.C. § 3143. This new Act created
+I.
+Laying aside constitutional analysis and
+questions of retroactivity, the
+relevant
+subsections of the Bail Reform Act of 1984
+read as follows:
+3143. Release or detention of a defenc
+it pending sentence or appea
+RELEASE
+DETENTION
+PENDING SENTENCE.- The Endical ON
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+at trial and at a post-verdict evidentiary
+hearing led the Court to find that clear and
+convincing evidence of Mr. Rourke's return
+for sentencing was wholly lacking. Actually, much evidence to the contrary was revealed. Rourke himself is a pilot who has
+States at edin/ and his family cottinues to
+own an aviation business. He was in poor
+financial condition. Rourke testified that he
+had received communications and threats
+of an undisclosed nature, from other fugitive co-defendants involved in the smuggling, venture. These continuing_ communications particularly troubled the Court.
+Coat Rourke's appeal of his postive led
+pre-sentence detention was
+"premature
+enced. United States of America Son
+Rourke, No. 85-5101 (4th Cir. April 17,
+1985).
+Following his sentencing on May 3, 1985,
+Rourke renewed his motion in this Court
+for bail pending appeal to allow his release
+Cruit acted. That motion is in the routh
+under 18 U.S.C. § 3143(b) (Release or De-
+tention Pending Appeal), whereas prior to
+*862 sentencing the relevant subsection
+was
+3143(a)
+(Release or Detention
+Pending Sentencing).
+Subsection (a) requires the Court to detain
+10o mo he derant serial beton is
+[1] There have been numerous recent circuit courts of appeal decisions interpreting
+F.2d 1200 (Sth Cir.1985) (one
+United States ed Say, 7 Faza 2279 754
+Cir. 1985);
+Giancola, 754
+7.13 Fiza
+• and United
+pret this subsection in a new and important
+way, these cases are irrelevant to the instant determination. Here, the Court stands
+pat on its findings at the post-conviction,
+presentence hearing
+• that there was no
+showing by clear and convincing evidence
+that the defendant was not likely to lee.
+The operative language of subsection
+3143(a) is identical to the language of subsection 3143(b)(1) regarding risk of flight
+Hence, the Court need not further evaluate
+subsection 3143(b)(2) as Rourke desires,
+because he must meet the burdens of both
+subsections, not just one or the other.
+II.
+[2] Rourke claims that the Bail Reform Act
+of 1984 1s an ex post jacto law under Article I, sec. 9 of the Constitution. Until Oc-
+rese and is other been con sected of an
+detained unless the Court finds that both §
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+visions of section 3146 [18 USCS § 3146]
+unless the court or judge has reason to believe that no one or more conditions of release will reasonably assure that the person
+will not flee or pose a danger to any other
+person or to the community. If such a risk
+of flight or danger is believed to exist, or if
+it appears that an appeal is frivolous or
+taken for delay, the person may be ordered
+detained....
+18 U.S.C. § 3148 (repealed). As the Sev-
+(ra ching th the said or bal
+pending appeal is not an ex post facto law.
+'Even though it may work to the disadvantida, 432 U.S. 282,
+97 S.Ct.
+53 L.Ed.2d
+United States ex rel Massarella elroa
+688,
+(extending the statute of limitations); Dunn
+V. Maggio, 712 F.2d 998, 1001-02 (5th
+Cir. 1983) (per curiam) (repealing pardon
+statute). It appears that the recent circuit
+decisions construing the Bail Reform Act
+›f 1984 are in acco
+1200,
+• United States
+* Crabtree 754 Fee
+1201-02
+Inited States Pi air 1985) (one judge)
+753 F.2d 19, 21
+(3rd Cir. 1985).
+The Court follows these
+cases and rejects the ex post facto claim.
+Page 4
+cision would result in manifest injustice or
+II.
+F.2d 1358,
+Cir. 1983). The Court here addresses the
+Congressional intent and the issue of
+"manifest injustice".
+Rourke was admitted to bail in the amount
+Twenty-Five
+Thousand Dollars
+($25,000.00) in the Northern District of
+Oklahoma on July 30, 1984. The Bail Re-
+form Act of 1966 was then in effect. He
+was free on bail at the effective date of the
+Bail Reform Act of 1984, yet the government made no attempt to seek his detention under the new statute's standards.
+However, after the jury returned a guilty
+verdict at his third trial, the government
+moved for his immediate detention. Under
+the new Act, 18 U.S.C. § 3143(b), the
+Court ordered Rourke's detention for the
+many reasons revealed in the transcript of
+the post-verdict detention hearing held on
+March 14, 1985.
+This Court reads 18 U.S.C. § 3143(b) as
+speaking in terms of conviction as the triggering event, 1.e.,
+"a person ... found guilty
+... and sentenced to a term of imprisonment
+.. Who has filed an appeal ... [IS] detained,
+unless....
+" Rourke's conviction occurred on
+May 3, 1985. Uaon sentencingine Cour
+May 3, 1985. Upon sentencing,
+The defendant in United States | Zannino,
+761 F.2d 52 (Ist Cir.1985), was admitted
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+' 611 F.Supp. 860
+to bail before the Act's effective date.
+However, after its effective date, and before trial, the government moved for his
+detention under the "dangerous" defendant
+provisions of the new Act. Seels U.S.C. s
+3143(a). The district Court affirmed the
+U.S. Magistrate, who refused to revoke bail
+under the Bail Reform Act of 1984, and the
+First Circuit reversed
+[3] The First Circuit in Zannino noted that
+even under the prior Bail Reform Act of
+1966, bail terms were "subject to review
+when changed circumstances require that
+the release
+be reappraised."
+Zannino,
+supra, at 55. The Court cited 18 U.S.C. S
+3146(e), repealed by18 U.S.C. § 3142(c),
+which reads in part:
+A judicial officer ordering the release of a
+person on any condition specified in this
+section may at any time amend his order to
+impose additional or different conditions of
+release.
+1. Although kourke is a sentenced an
+onvicted defendant unlike Zannino. whi
+a pre-trial defendant, Rourke was
+equally subject to the repealed subsection
+above by virtue of repealed § 3148, which
+states that those "awaiting ... sentence review ... shall be treated in accordance with
+the provisions of section 3146 unless there
+exists] a risk of flight or danger is believed
+to exist, or if it appears that an appeal is
+frivolous or taken
+for delay....
+" The Zan-
+Thus the release on bail allowed under the
+1966 Act was not an absolute grant; de-
+Fendants were given notice that a change in
+conditions or terms could bring about the
+throne not not ingrediton that com.
+What has actually occurred with the pas-
+Page 5
+sage of the pretrial detention provision
+nay be considered a statutorily mandates
+change in those conditions.... We hold that
+defendants released under the 1966 Bail
+Act must show their continued eligibility
+for bail by meeting the newly imposed con
+litions if this issue is affirmatively raise
+by the Government.
+Zannino, supra, at 55-56. It is plain that
+even under the prior Bail Reform Act of
+1966 release on bail was modifiable and
+never a vested right; hence, Rourke would
+not profit from its applicability.
+*864 Under the rationale of Zannino, or
+under an interpretation that the Bail Re
+form Act of 1984 is a prospective law ef
+fectuating a procedural change which fully
+applied to Rourke upon his sentencing, the
+Court holds that no manifest injustice results in ordering Rourke to begin serving his
+sentence pending appeal. There is no indication of any kind in the legislative history
+of the Bail Reform Act of 1984 that Congress intended it to apply to certain classes
+of defendants and not to others, nor of the
+Act's retroactivity or prospectivity. Furthermore, since the Act had an obvious impact
+pretrial detainees
+and postconviction defendants, any limitation on its
+applicability would have been expressed by
+Congress. See generally Zannino, supra, at
+The Court recognizes that in United States
+Mitchell,
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-... 4/10/2008
+
+
+
+' 611 F.Supp. 860
+challenge and a "retroactivity" attack on
+the Bail Reform Act of 1984, by pre-trial
+detainees alleged to have committed crimes
+rior to the Act's passage. In another case
+he First Circuit Court of Appeals rejecte
+the "retroactivity" argument with respect
+to one charged before the new Act was efeee Velied States Soangiuor, -55 F. 2d 959.
+973-74 (1st Cir.1985).
+wa apited 1o Romic: that the Ac 18 tm
+Page 6
+IT IS SO ORDERED
+.C.Va.,198
+S.I. Rourk
+.Supp. 860
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+U.S. V. GAVIRIA
+667
+Cite as 828 F.2d 667 (11th Cir. 1987)
+sarial role has long been well established.
+United States District Court for the South-
+We agree with the district court that petiern Distriet of Florida, No. 87-803-CR-
+tioner's present claim is merely a variation
+LCN, Lenore Carrero Nesbitt, J., affirmed,
+of law that was well established at the time
+and defendants took further appeal. The
+of the 1983 proceedings.
+The ends of jus-
+Court of Appeals, Hatchett, Circuit Judge,
+tice can provide no exception in this case to
+held that: (1) Government could proceed at
+the application of the abuse of the writ
+pretrial detention hearing by way of profdoctrine. The trial attorney could not prefer of evidence; (2) defendants' right to call
+vent Ritter from testifying.
+Ritter's testiadverse witnesses was conditional; and (3)
+mony—which admitted all of the relevant
+defendants were not entitled to de novo
+facts, evidenced no remorse, affirmatively
+hearing before district court.
+sought the death penalty, and threatened
+Affirmed.
+harm to the jurors should they fail to return a death sentence-would have undermined any defense which the attorney 1. Criminal Law e-1158(1)
+might have presented. Under these circumstances, we are confident that the
+"ends of justice" concept does not warrant
+an exception to the abuse doctrine.
+dard of review in considering appeals under
+Bail Reform Act, but purely factual findings of distriet court remain subject to
+clearly erroneous review standard. 18 U.S.
+III. Conclusion
+Although we GRANT the petition to proceed in forma pauperis, since both claims
+raised by petitioner are barred by the
+abuse of the writ doctrine, and since this
+issue would not be debatable among jurists
+of reason, we conclude the petitioner's application for a certificate of probable cause
+should be DENIED.
+Accordingly, petitioner's emergency motion for a stay of execution is DENIED.
+C.A. § 3141 et seq.
+2. Bail e-49(3)
+At pretrial detention hearing, Government as well as defense may proceed by
+proffering evidence, subject to discretion of
+judicial officer presiding at detention hearing. 18 U.S.C.A. § 1341 et seq.
+3. Bail e=42, 49(5)
+Defendant in pretrial detention hearing
+has only conditional right to call adverse
+witnesses; judicial officer presiding at detention hearing is vested with discretion
+UMBER SYSTEM
+whether to allow defense counsel to call
+adverse witness with or without initial
+proffer of expected benefit of witness' testimony. 18 U.S.C.A. § 1841 et seg.
+UNITED STATES of America,
+Plaintiff-Appellee,
+4. Ball 49(5)
+Narcotics defendants were not entitled
+to de novo hearing to fully review magis-
+Jorge Enrique GAVIRIA and Jose Elkin
+trate's pretrial detention order which was
+Echeverry, Defendants-Appellants.
+based on proffers of evidence, where order
+No. 87-5517.
+ras affirmed after reviewing Gover
+ent's and defendants' memoranda of la
+United States Court of Appeals,
+Eleventh Circuit.
+Sept. 3, 1987.
+Narcotics defendants appealed magis
+rate's order of pretrial detention. The
+Milton Hirsch, Miami, Fla., for Gaviria.
+Samuel J. Rabin, Jr., Miami, Fla., for
+Echeverry.
+
+
+668
+828 FEDERAL REPORTER, 2d SERIES
+Leon B. Kellner, U.S. Atty., Miami, Fla.,
+ment to proceed by proffering evidence at
+for plaintiff-appellee.
+the pretrial detention hearing; (2) defense
+Appeal from the United States District
+counsel were not permitted to call as a
+Court for the Southern District of Florida.
+witness the government's case agent, who
+was present at the detention hearing; and
+Before RONEY, Chief Judge, FAY
+(3) Gaviria and Echeverry were interviewed
+and HATCHETT, Cireuit Judges.
+by immigration agents while in custody
+without notice to their defense counsel.
+HATCHETT, Circuit Judge:
+The district court, without a de novo
+hearing, affirmed the magistrate's order of
+pretrial detention noting that the government had met its burden under the Bail
+suant to 18 U.S.C. § 3142(e). We affirm.'
+Reform Act.
+Gaviria and Echeverry urge this court to
+FACTS
+reverse the district court's order affirming
+On April 30, 1987, Jorge Enrique Gaviria
+their pretrial detention. They allege that
+and Jose Elkin Echeverry were arrested
+(1) the magistrate erred in allowing the
+and charged with several Title 21 narcotics
+government to proceed by proffer; (2) deoffenses.
+The government requested temfense counsel were erroneously prevented
+porary detention of Gaviria and Echeverry
+from calling the government's case agent
+pursuant to 18 U.S.C. § 3142(d) after deteras a witness; and (3) the district court
+mining that they were in the United States
+erred in failing to conduct a de novo review
+illegally.
+of the pretrial detention proceedings."
+On May 6, 1987, a United States Magistrate conducted a pretrial detention hearing
+pursuant to 18 U.S.C. § 3142(L) and ordered
+pretrial detention of Gaviria and Echeverry.* The magistrate based the pretrial detention order on risk of flight and dangers
+posed to the community as authorized by
+18 U.S.C. § 3142(e). Gaviria and Echeverry requested a review of the magistrate's
+order and a de novo hearing before the
+district court, alleging that (1) the magistrate erroneously permitted the govern-
+DISCUSSION
+[1] We note that this circuit has
+adopted the plenary standard of review in
+considering appeals under the Bail Reform
+Act.
+• United States u. Hurtado, 779 F.2d
+1467, 1470-73 (I1th Cir.1985).
+Nevertheless, the purely factual findings of the district court remain subject to the clearly
+erroneous standard. Hurtado, 779 F.2d at
+1472.
+1. This matter came to the court as a "Motion for
+Bail Pending Trial." We noted that 18 U.S.C.
+§ 3145 provides for an appeal from a pretrial
+detention order. Under our rules and operating
+procedures, a single judge may determine a mo
+tion for bail pending appeal, but a panel must
+determine an appeal pursuant to 18 U.S.C
+2. Title 18 U.S.C. § 3142(f) provides, in pertinent
+part, that:
+The judicial officer shall hold a hearing to
+determine whether any condition or combination of conditions set forth in subsection (c
+of this section will reasonably assure the ap
+pearance of the person as required and the
+safety of any other person and the community....
+At the hearing, the person has the right to
+e represented by counsel and, if financiall
+nable to obtain adequate representation, t
+have counsel appointed. The person shall be
+afforded an opportunity to testify, to present
+witnesses, to cross-examine witnesses who appear at the hearing, and to present information by proffer or otherwise.
+The facts the judicial officer uses to support
+a finding pursuant to subsection (e) that no
+condition or combination of conditions will
+reasonably assure the safety of any other person
+
+
+I.
+Gaviria and Echeverry contend that the
+magistrate committed error by allowing the
+government to proceed by proffer at the
+pretrial detention hearing and by improperly precluding defense counsel from calling
+as a witness the government's case agent
+who was present at the detention hearing.
+The district court, citing a decision of the
+Third Circuit, United States v. Delker, 757
+F.2d 1390 (3d Cir.1985), stated that "the
+magistrate did not err in allowing the
+government to proceed by proffer during
+the pretrial detention hearing. Nor did the
+magistrate err in the defendants' request
+to call the case agent as a witness on their
+clients' behalf under section 3142(g)(2) of
+the Bail Reform Act." We agree.
+Although this circuit has not expressly
+addressed the issue of whether the government at a pretrial detention hearing may
+proceed solely by proffer, the court in
+Delker stated that
+the "procedural requirements for the pretrial detention hearing set forth in section 3142(f) are based on those of the
+District of Columbia statute which were
+held to meet constitutional due process
+requirements in United States v.
+wards,' 430 A.2d 1321 (D.C.App.1981) (en
+bane), cert. denied, 455 U.S. 1022, 102
+S.Ct. 1721, 72 L.Ed.2d 141 (1982). S.Rep.
+No. 225, 98th Cong. at lst Seas. at 22
+(1983), reprinted in 1984 U.S. Code
+Cong. & Adm.News at 25 (Supp. 9A).
+Delker, 757 F.2d at 1895. In Edwards, the
+District of Columbia Court of Appeals held
+that "the information presented to the judicial officer by either the government or
+the defense may be by proffer....",
+Ed-
+wards, 430 A.2d at 1834. In Edwards, the
+court continued by stating that
+The legislative history of the statute
+confirms Congress' intent that the information upon which the judicial officer
+makes his findings need not be sworn
+testimony, and that the hearing is not
+designed to afford defendants a discovery device. Thus, in providing that
+the finding of substantial probability is
+to be based upon information presented
+'by proffer or otherwise,' the House re.
+U.S. v. GAVIRIA
+Cite as 828 F.Zd 667 (lith Cir. 1987)
+port anticipates 'that, as is the present
+practice under the Bail Reform Act, ...
+the use of sworn testimony will be the
+exception and not the rule... [BJail
+hearings under the Bail Reform Act,
+which frequently result in detention of
+the accused, proceed primarily by way of
+proffers. They are not formal trials requiring striet adherence to technical
+rules of evidence. If the court is dissatisfied with the nature of the proffer, it
+can always, within its discretion, insist
+on direct testimony. But discretion
+should be left to the court without imposing on it the burden of limiting admissibility to that it would permit a jury to
+Edwards, 430 A.2d at 1334 (citation omitted) (original emphasis). Additionally, the
+United States Supreme Court recently held,
+in United States u. Salerno and Cafaro,
+— U.S. —, 107 S.Ct. 2095, 95 L.Ed.2d
+697(1987), that under the Bail Reform Act
+of 1984, "Congress hoped to 'give the
+courts adequate authority to make release
+decisions that give appropriate recognition
+to the danger a person may pose to others
+if released.'" Salerno, 107 S.Ct. at 2098
+(citing S.Rep. No. 98-225 at 3).
+[2] In light of the legislative history
+and the relevant case law relating to the
+Bail Reform Act of 1984, we reject Gaviria's and Echeverry's contention that the
+magistrate erred in allowing the government to proceed at the pretrial detention
+hearing by way of proffer. We hold that
+the government as well as the defense may
+proceed by proffering evidence subject to
+the discretion of the judicial officer presiding at the detention hearing.
+[3] Gaviria and Echeverry also allege
+error because the magistrate refused defense counsels' request to call the government case agent, who was present at the
+hearing, as a witness. We note that 18
+U.S.C. § 3142(f) specifically provides that a
+defendant may testify, present witnesses,
+and cross-examine witnesses who appear at
+the detention hearing. The court in Ed-
+wards held, however, that:
+The legislative history does not discuss
+the scope of cross-examination permitted
+
+
+670
+828 FEDERAL REPORTER, 2d SERIES
+of witnesses who are called by the a written statement of the reasons for the
+government. Section 1322(c)(4) gives the
+detention. Hurtado, 779 F.2d at 1480-81.
+accused the right 'to present witnesses in
+We find that the distriet court's order in
+his own behalf, but the House report
+this case complies with the requirements
+states that the accused has only a condiunder Hurtado, and we affirm the district
+tional right to call adverse witnesses:
+court's denial of Gaviria's and Echeverry's
+He may not, of course, call witnesses
+request for a de novo hearing because the
+who ordinarily would be expected to tesdistrict court properly afforded de novo
+tify for the government at trial, unless
+review of the magistrate's detention order.
+he can proffer to the court in reasonable detail how he expects their testimony to negate substantial probability.
+Edwards, 430 A.2d at 1834 (original emphasis).
+We agree that the defendant in a
+pretrial detention hearing has only a condi-
+III.
+Gaviria and Echeverry also contend that
+the pretrial detention statute was unconstitutionally applied in this case. This claim
+is not persuasive. For the above-stated
+tional right to call adverse witnesses. We,
+however, do not adopt the procedural
+guideline under Edwards requiring the defendant to initially proffer to the court in
+detail how an adverse witness's testimony
+is expected to negate substantial probability as a prerequisite to calling such witness.
+The legislative history compels a finding
+and procedurally correct.
+Accordingly, we affirm the decision of
+the district court.
+AFFIRMED
+that the judicial officer presiding at the
+detention hearing is vested with the discretion whether to allow defense counsel to
+call an adverse witness with or without an
+initial proffer of the expected benefit of the
+witness's testimony.
+Moreover, as the
+court in Edwards noted, "[t]he related trial
+right of compulsory process, as provided by
+the sixth amendment, guarantees that the
+defendant may compel the attendance of
+witnesses in his favor." Edwards, 430
+A.2d at 1838 (emphasis added).
+David W. TROEDEL,
+Petitioner-Appellee,
+Cross-Appellant,
+11.
+(4] Gaviria and Echeverry next contend
+that the distriet court erred in failing to
+conduct a de novo hearing to fully review
+the magistrate's detention order which was
+based merely on proffers of evidence. The
+distriet court's order, however, expressly
+states that it affirmed the magistrate's order after reviewing "the Government's and
+Defendants' Memorandum of Law and the
+Richard DUGGER, Secretary, Florida
+Respondent pet no, Cried pelle.
+No. 86-5860.
+United States Court of Appeals,
+Eleventh Circuit.
+Sept. 4, 1987.
+Richard E. Doran, Asst. Atty. Gen.,
+transcript of the proceedings before the
+Magistrate, in accordance with U.S. v. Hurtado, 779 F.2d 1467 (11th Cir.1985)." In
+Hurtado, we held that de novo review requires the court to exercise independent
+considerion of tackercie in bede it EVan dave, Tatal Bee, slat tiere Hi
+and to include written findings of fact and
+Malone, Sp. Appointed Asst. Representa-
+
+
+
+49 Bail
+4911 In Criminal Prosecutions
+49k49 Proceedings to Admit to Bail
+49k49(3) Evidence
+49k49(3.1)
+United States Court of Appeals, First Circult.
+UNITED STATES of America, Appellee,
+Gennaro J. ANGIULO, Defendant, Appel-
+No. 84-1745.
+Heard Jan. 10, 1985.
+Decided Feb. 25, 1985.
+An accused sought release from pretrial
+detention. The United States District Court
+for the District of Massachusetts, David S
+Nelson, J
+Nel, ordered that abused remain in cust
+tody. Accused appealed on ground that the
+Bail Reform Act did not apply to one like
+him whom Government had charged before
+Act took effect. The Court of
+Appeals,
+Breyer, Circuit Judge, held that standard:
+of the Bail Reform Act were applicable to
+one who was incarcerated and seeking release when Act became law.
+Affirmed.
+[3] Bail 49 €m49(3.1)
+49 Bail
+4911 In Criminal Prosecutions
+49k49 Proceedings to Admit to Bail
+49k49(3) Evidence
+49k49(3.1)
+In General.
+Most Cited Cases
+(Formerly 49k49(3))
+Materials under seal offered legally sufficient basis for district court to conclude under the Bail Reform Act that no condition
+or combination of conditions imposed on
+release of accused would reasonably assure
+safety of any other person and the community. 18 U.S.C.A. §§ 3141 et seq.,
+3142(e).
+*969 James L. Sultan, Boston, Mass., with
+whom Joseph T
+• Travaline,
+Burlington,
+Mass., was on brief, for defendant, appel-
+West Headnotes
+[1] Bail 49 €~39
+49 Bail
+49II In Criminal Prosecutions
+49k39 k. Nature and Scope of Remedy. Most Cited Cases
+Standards of the Bail Reform Act were applicable to one who was incarcerated and
+seeking release when Act became law. 18
+U.S.C.A. § 3141 et seq.
+[2] Bail 49 €m49(3.1)
+Before BREYER, ALDRICH and TOR-
+RUELLA, Circuit Judges.
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-... 4/10/2008
+
+
+
+BREYER, Circuit Judge.
+The district court, applying the Bail Re-
+form Act of 1984, found that the release of
+Gennaro Anguilo from pretrial detention
+would put at risk the "safety" of the community, and it ordered that he remain in
+custody. Anguilo appeals, on the ground
+that the new Bail Reform Act does not apply to one like him whom the government
+lad charged before the new Act took effect. Since we do not agree with this claim,
+since Anguilo makes no significant constitutional challenge to the new statute on this
+appeal, and since we find that the district
+court's order has sufficient evidentiary support, we affirm the district court's decision.
+"prepared to order" that appellant be released under conditions
+*tantamount to
+house arrest"; and, it asked the government
+to suggest appropriate safeguards. In response, the government noted that the new
+Bail Reform Act had just become law (on
+October 12, 1984); it asked the court to
+continue appellants detention under the
+new Acts
+"dangerousness" provisions. On
+October 19, the court ordered appellant's
+continued detention. Subsequently, in a
+memorandum of October 23, the court
+wrote that its
+stated intention in its prior decision to release the defendant on bail is withdrawn,
+endant be detained pending trial as dequired by the Bail Reform Act of 1984 is
+allowed
+Anguilo appeals from the district court's
+decision.
+I
+The basic procedural facts are the following. On September 19, 1983, a grand jury
+charged appellant with several serious fed
+eral crimes. On September 20, the government brought appellant before a magistrate,
+who ordered him held without bail lest he
+flee the jurisdiction-a decision that the district court affirmed. In early January, 1984,
+this court upheld the lawfulness of appellant's pretrial confinement,
+finding
+the
+evidence of risk of flight sufficient to make
+this a "rare case of extreme and unusual
+circumstances that
+guilo, No. 83-1965 (Ist fir. Jan. S,-
+quoting United States
+Abrahams, 575
+F.2d 3, 8 (Ist Cir.), cert
+*970 denied, 439
+U.S. 821, 99 S.Ct. 85, 58 L.Ed.2d 112
+(1978).
+During 1984 appellant first asked the magistrate and then twice asked the district
+court to reconsider his circumstances. See
+Bail Reform Act of 1966, 18 U.S.C. former
+993146(d)_ and 3147(a). On October s
+984. the district court wrote that it wa
+II
+[1] The basic legal issue in this case is
+whether the standards of the new Bail Re-
+form Act, 18 U.S.C. § 314let seq., apply to
+one who, like appellant, was incarcerated
+(and seeking release) on October 12, 1984,
+when the new Act became law. The Act itself does not say. It speaks of an "effective
+date" of "October 12, 1984," but it is silent
+as to whether, or to what extent, it applies
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-... 4/10/2008
+
+
+
+First, courts often turn to various "canons"
+of construction to interpret statutes that are
+silent or ambiguous. See generally, e.g., C.
+Sands, Statutes and Statutory Construction
+(4th ed. 1984); R. Dickerson, The Interpretation and
+Application
+of Statutes
+(1975). One such canon, relevant here, interprets new statutes and other new law to
+reflect an intent to apply to cases in the
+process of being decided at the time the
+new law takes effect. This canon, or prinis reflected in Chief Justice Marshall's well known statement that,
+if subsequent to the judgment and before
+the decision of the appellate court, a law
+intervenes and positively changes the rule
+which governs, the law must be obeyed....
+application of prior law. In this respect
+there is an important difference between
+persons in custody on October 12 and those
+free on bail. The latter might claim that
+hey have relied upon continued freedom ir
+making plans for their trial defense, or ir
+making
+other important plans; and the
+threat of incarceration might disrupt those
+plans. The former, however, could not have
+reasonably relied
+*971 upon the freedom
+promised them under prior law, for they
+were committed to custody under that law.
+At best theirs was a hope for freedom that
+changing circumstances might, or might
+not, have let them realize.
+Without a showing of likely significant and
+justified reliance those in custody fall outside both Bradley 's exception and the
+actie of other canons that disfavor "retro-
+e.g. United States i|
+Security Industrial
+Bank, 459 U.S. 70, 7.
+Ba L. Ed.2d 235 (1982); Greene 1° United
+States, 376 U.S. 149, 160, 84 S.Ct. 615,
+principle is
+Court's holding that a new law applies to a
+case in progress unless applying it "would
+result in manifest injustice or there is statutory direction or legi lative history to the
+contrary." Bradley
+Richmond
+School
+Board, 416 U.S. 696,
+711, 94 S.Ct. 2006,
+2016, 40 L.Ed.2d 476 (1974); New England Power Co.
+• United States, 693 F.2c
+239, 244 (Ist Cir.1982). The case before us
+is one that was pending on October 12. The
+district court had not reached a final decision about appellant's application for release. Since nothing in the new Bail Re-
+form Act or its legislative history says that
+seek to protect the interests of those who
+have See 2nColsareds, Colands, Sature she deal status
+Construction
+1973). An inability to find such likely reliance by those incarcerated indicates that
+application of the new law is not unjust.
+and that Congress therefore likely intended
+the new law to apply, at least to pending
+proceedings involving incarcerated per-
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+their legal advisors often refer to well established interpretive principles when preparing statutory language. A court decision
+consistent with such a principle is more
+likely than its opposite to reflect what congressional staffs,
+advisors,
+witnesses,
+interest groups, and legislators
+themselves
+believe will occur despite a legislative history that is silent. (In fact, silence may reflect an absence of controversy, not congressional indifference to the result.) At the
+same time consistent judicial adherence to
+interpretive principles eases the task of
+dratting legislation by pointing to likely tuture interpretive results without requiring
+statutory language on every
+point. These
+practical institutional
+considerations
+as
+well as legal theory recommend adherence
+to Bradley's interpretive rule here.
+Second, a consideration of the new Act's
+purposes
+suggests that legislators,
+with those purposes in mind, would likely
+favor the Act's applieation to those in custody. Cf. Mayburg
+Secretary of Health
+and Human Services,
+740 F.2d 100, 104-07
+(Ist Cir.1984). The Act has at least two objectives. On the one hand, it seeks to bail
+vent the "arbitrary use of high money
+as a way to assure a defendant's incarceration." S.Rep.
+No.
+225,
+98th Cong.,
+1st
+Sess. 9-10 (1983) U.S.Code Cong. & Ad-
+min.News 1984 pp. 1, 11, 12 ("It has been
+suggested that pretrial detention under"
+the former Bail Act "is often the result of
+intentional imposition of excessively strinzent release conditions, and in partıcular
+high money bonds"). See Hearings before
+the Subcommittee on the Constitution of
+he Senate Comm. on the Judiciary
+Page 4
+person." 18 U.S.C. § 3142(c). (See Ap-
+pendix, infra, for text of relevant portions
+of the Act.) On the other hand, the new Act
+broadens the courts' authority to detain
+them, after a hearing, to keep in custody
+not only defendants who pose à serious risk
+of flight, but also
+those who seriously
+threaten the "safety" of others or of "the
+community." 18 Ü.S.C. § 3142(e).
+• Thus
+the statute seeks to assure release of the defendant who is "safe but poor" while allowing detention of a dangerous defendant
+financially capable of posting a bond.
+Given these purposes, it is difficult to see
+why Congress would not want the new law
+to apply to those incarcerated at the time it
+was enacted. To apply the new Act's specific language to the
+"safe but poor" defendant furthers Congress's statutory objective, benefits the defendant, and deprives the government of nothing to which
+it was entitled under the old law, cj. tormer
+*972 18 U.S.C. § 3146(a), or the new. To
+apply it (in what must be an unusual situation) to a "dangerous" person previously
+held as a "flight risk" also furthers Congress's statutory objectives
+by keeping
+those persons in custody. Although application of the new statute works to the disadvantage of any such defendant who otherwise would be released, nothing in the new
+Act or its history suggests congressional
+solicitude for this category of defendant.
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+to a judicial proceeding already in progress.
+n sum, principles of statutory constructior
+resting upon fairness and consideration of
+the statute's purposes both suggest that
+Congress intended the statute to apply in
+cases like the one before us.
+We next consider four arguments to the
+contrary. First, Anguilo points to § 3142(f
+of the new Act. That section says that th
+magistrate or judge will decide whether to
+detain or to release a defendant after a
+"detention hearing" which
+shall be held immediately upon the person's first appearance before the judicial
+officer unless that person or the attorney
+for the government seeks a continuance
+[for a maximum of five days and two
+days respectively].
+Anguilo points out that this detention
+hearing
+"immediately" in the case of a person first
+detained betore the provision became law
+(October 12, 1984). He concludes from this
+fact that the new law was not meant to apply to such a person.
+This conclusion, however, rests too much
+upon too little. The object of § 3142(f)'s
+quoted language is to guarantee a speedy
+ball determination, to prevent the magistrate or judge from ordering the defendant
+temporarily
+detained
+(see18
+3012i aid the sonde the key deter
+tion" hearing at some much later time.
+Page 5
+carceration.
+We concede that the way in which S
+3142(c) is to be applied seems slightly conusing because of
+an odd procedural omis-
+1966 Act, which provided for magistrate or
+district court reconsideration of
+tion order. As far as we can tell, § 3142(t)
+›t the new Act governs the magistrate's (o
+judge's) initial decision whether to detai
+or to release a defendant on conditions.
+The mat serate of judge at a ye all vs
+"amend"
+a release order. But, the Act
+nowhere says how one detained can seck a
+new determination in light of changed circumstances. (Section 3145, at first blush,
+may seem to provide for such review; but
+in fact it does not, for it governs only what
+are in essence appeals, trom magistrate t
+• from district court to
+court of appeals). After reviewing the le-
+gıslatıve history, we have concluded that
+for procedural omission was inadvertent,
+ongress nowhere expresses any inten
+to deny a person in custody the right to ask
+for reconsideration. In the absence of an
+express statutory reconsideration provision,
+the magistrate and district court nonetheless possess inherent power to reconsider
+previous detention orders-an
+power to modify (or revoke) previous bail
+orders that the 1966 Act's statutory provisions "merely embodied." C. Wright, Fedthe entire Act no longer applies. Nor does
+it forbid application of the Act's standards
+at other hearings, say those at which a magistrate reconsiders previously ordered in-
+Jackson, J.); Fernandez
+United States,
+81 S.Ct. 642, 644, 5 L.Ea.2d 683 (1961)
+Circuit
+("District courts have authority as an incident*973 of their inherent powers ... to re-
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619. 4/10/2008
+
+
+
+voke bail"); United States | Black, 543
+F.2d 35,
+37 (7th Cir.1976) T"[T]he same
+statute which explicitly empowers the district court to impose conditions upon release pending appeal,
+I, implicitly empowers
+the court to make such adjustments in those
+Page 6
+procedural perspective as such a reconsideration by the district court of its prior detention order. Regardless, this procedural
+problem does not help appellant, for the
+question remains what standards Congress
+intended a magistrate or court to apply at a
+reconsideration hearing. And for the reasons previously stated, we believe that Congress wanted (or would have wanted) the
+new Act's standards applied to one then being held in custody.
+Second, the parties point to three recent
+ment notes that in united sa. Payde
+598 F.Supp. 1388 (S.D.N.Y.1984), the district court upheld application of the new
+law to a defendant arraigned before October 12. Appellant notes that in two other
+cases the courts denied
+. application of the
+new Act to persons arraigned before its enacting. In the first of these, however, the
+Eleventh Circuit refused per curiam to apply the new law to persons whose "release
+was ordered by the district court before the
+ew law became effective.
+" United States
+. Fernandez-Toledo, 749 F.2d 703 (11th
+Cir.1985) (per curiam). The court ruled the
+In United States | Mitchell, 600 F.Supp.
+164 (D.Cal.1985),
+California district
+court held the new Act inapplicable in circumstances much like this one. The Callfornia court,
+however, based its decision
+upon the reliance interests of those released on bail before October 12. The court
+did not distinguish between the class of released persons and the class of persons in
+custody. It seems to us, however, that tho
+fact of custody (and the consequent smal
+likelihood of significant reliance) makes an
+important
+meaningful
+difference.
+Moreover, the "in custody/at liberty". distinction is simple are easy to administer
+Cj. United States | Mitchell, supra, a
+168-169. Thus, we believe we can best eftectuate likely congressional intent by applying the new Acts standards to those de
+tained at the time of its enactment
+appellant claims that the district
+court is applying new law "retroactively,"
+and he invokes a series of cases that, he
+says,
+See United
+(1982); Greene United States, 376 U.S.
+149, 160, 84 S.Ct. 615, 621, 11 L.Ed.2d
+576 (1964); United States Heth, 7 U.S
+Madison a Bulk Food Carriers, Inc. 489
+F.2d 104T, 1042-43 (1st Cir.1974). "Retro
+activity. however, is a relative, not an ab
+solute, notion. The law before us is not retroactive in the sense of punishing or reof this opinion.
+consider a confidi ve therefore do hi
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+swer the applicability question. Rather, one
+must look
+beneath the word to the functional considerations that it embodies. And,
+doing so, for reasons stated at pp. 970-971,
+leads us to conclude that the new Act applies here.
+Fourth, appellant argues that his case ought
+to be considered like that of a person released, not a person in custody, for, he
+says, the district court had ordered him reeased before October 12. As a practica
+natter, however, appellant had not been re
+leased. As a formal matter, the court had
+made no final decision to release him.
+Rather, the new Act became law and was
+*974 brought to the attention of the district
+court while it was in the midst of deciding
+what to do with appellant's motion for release. The court had not ordered appellant's
+release. On October 9, the court said it was
+"prepared" to do so; it later characterized
+its decision as "tentative";
+; and it spoke in
+its October 23 memorandum of its previous
+"intention." On January 9, 1985, the court
+characterized its decision as one made in
+response to an ongoing motion for modification. United States
+Zannino, Cr. No.
+83-235-N, slip op. at 5 n. 1 (D.Mass. Jan.
+9, 1985). Moreover, a release order by the
+district court would have been appealable
+under $ 3145, and therefore not "
+Thus, both formal
+and practical considerations require us to
+treat this case as one involving the application of the new Bail Act's standards to one
+presently in custody. And for the reasons
+stated, the Act's new standards apply.
+Page 7
+to "the safety of any other person and the
+community." 18 U.S.C. § 3142(f). He first
+claims that the district court could not rely
+on the evidence obtained by electronic surveillance, the legality of which he challenges. We previously wrote, however, ir
+(ist Cir 1984) a case in which both defendant and the government were parties,
+that the provisions of federal law
+"allow
+the disclosure of [information obtained
+through electronic surveillance, at least
+court conducting ... bail hearings.
+until a court has decided that the materia
+was not obtained legally. Otherwise, the
+challenge of a defendant to lawfully obtained materials might prove sufficient to
+keep highly relevant information from the
+judicial officer or to delay the initial bai.
+hearing, contrary to the
+quirement of § 3142(f).
+[3] Appellant also argues that the materials
+on which the district court relled (including
+those obtained from
+electronic surveil
+lance) are stale or irrelevant or conclusory
+and, in any event, even when taken together are insufficient for the district court's
+conclusion. Those materials are under seal.
+We have examined them, and we conclude
+that they offer a legally sufficient basis for
+the district court to conclude that "no condition or combination of
+conditions
+[imposed on release will reasonably assure
+... the satety of any other person and the
+community.
+* 18 U.S.C. § 3142(e)
+III
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+the risks appellant poses to others in the
+community are precisely the same whether
+or not he is detained. In any event, we are
+inwilling to assume it meant this in the ab
+a showing in the record that the
+court focused directly on the issue that appellant's counsel now raises.
+Again we note that appellant does not now
+challenge the basic constitutionality of the
+new Act's "dangerousness"
+the basis our resolution of the issues he
+has presented to us on this appeal, we believe the district court's decision is legally
+correct, and that decision is
+Affirmed.
+Page 8
+APPENDIX
+18 U.S.C. §§ 3142, 3145
+"§ 3142 . Release or detention of a defendant pending trial
+"(4) detained pursuant to the provisions
+of subsection (e).
+*(b) Release on Personal Recognizance or
+Unsecured Appearance Bond.-The judicial
+officer shall order the pretrial release of the
+person on his personal recognizance, or
+upon execution of an unsecured appearance
+bond in an amount specified by the court,
+subject to the condition that the person not
+commit a Federal, State, or local crime during the period of his release, unless the judicial officer determines that such release
+will not reasonably assure the appearance
+of the person as required or will endanger
+the safety of any other person or the community.
+"(c) Release on Conditions.-If the judicial
+officer determines that the release described in subsection (b) will not reasonably assure the appearance of the person as
+required or will endanger the safety of any
+other person or the community, he shall order the pretrial release of the person-
+"(1) subject to the condition that the
+person not commit a Federal, State, or
+local crime during the period of release,
+"(2) subject to the least restrictive further condítion, or combination of conditions, that he determines will reasonably
+assure the appearance of the person as required and the safety of any other person
+and the community, which may include
+the condition that the person-
+"(1) released on his personal recognirovisions of subsection (b)
+"(2) released on a condition or combintion of conditions pursuant to the provi
+ions of subsection (c)
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-... 4/10/2008
+
+
+
+pose a danger to the safety of any other
+person or the community:
+Page 9
+and post with the court such indicia of
+ownership of the property or such per
+centage of the money as the judicial of
+ficer may specify;
+"(L) execute a bail bond with solvent
+sureties in such amount as is reasonably
+necessary to assure the appearance of
+the person as required;
+"(C) maintain or commence an educational program;
+on his personal
+"his personal associations, strice of
+abode, or travel;
+"(E) avoid all contact with an alleged
+victim of the crime and with a potential
+witness who may testify concerning the
+offense;
+"(F) report on a regular basis to a designated law enforcement agency, pretrial services agency, or other agency;
+"(G) comply with a specified curfew;
+"(H) refrain from possessing a firearm, destructive device, or other dangerous weapon;
+"(I) refrain from excessive use of alohol, or any use of a narcotic drug o
+ther controlled substance, as detine
+in section 102 of the Controlled Substances Act (21 U.S.C. 802), without a
+prescription by a licensed medical pracpsychiatric
+sychiatric Treatment bine mini aleatincluding
+lent for drug or alcohol dependency
+id remain in a specified institution i
+required for that purpose;
+*976 "(N) satisfy any other condition
+that is reasonably necessary to assure
+the appearance of the person as re
+quired and to assure the safety of any
+other person and the community.
+The judicial officer may not impose a financial condition that results in the pretrial
+letention of the person. The judicial of
+icer may at any time amend his order t
+impose additional or different conditions of
+release.
+"(d) Temporary Detention To Permit Re-
+vocation of Conditional Release, Deportation, or Exclusion.-If the judicial officer
+determines that-
+"(1) the person-
+"(A) is, and was at the time the offense was committed, onunder Federal, State, or local lawa felony
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619. 4/10/2008
+
+
+
+"(iii) probation or parole for any offense under Federal, State, or local law;
+"(B) is not a citizen of the United
+States or lawfully admitted for permanent residence, as defined in section
+101(a)(20) of the Immigration and Na-
+tionality Act (8 U.S.C. 1101(a)(20)); and
+"(2) the person may flee or pose a
+danger to any other person or the comhe shall order the detention of the person,
+for a period of not more than ten days, excluding Saturdays, Sundays, and holidays,
+and direct the attorney for the Government
+to nouty the appropriate court, probation or
+. or State or local law enforcement official, or the appropriate official of the Immigration and
+Naturalization
+Service. If the official fails or declines to
+take the person into custody during that
+period, the person shall be treated in accordance with the other provisions of this
+section, notwithstanding, the applicability
+of other provisions of law governing release pending trial or deportation or exclusion proceedings. If temporary detention is
+sought under paragraph (1)(B), the person
+has the burden of proving to the court that
+he is a citizen of the United States or is
+lawfully admitted for permanent residence.
+Page 10
+bination of conditions will reasonably assure the safety of any other person and th
+community if the judge finds that
+"(1) the person has been convicted of a
+Federal offense that is described in sub
+section (f)(l), or of a State or local offense that would have been an offense
+described in section (f)(1) if a circumstance giving rise to Federal Jurisdiction
+had existed
+"(2) the offense described in paragraph
+1) was committed while the person wa
+n release pending trial for a Federa
+State, or local offense; and
+"(3) a period of not more than five
+years has elapsed since the date of conviction, or the release of the person from
+imprisonment, for the offense described
+in paragraph (1), whichever is later.
+Subject to rebuttal by the person, it shall be
+presumed that no condition or
+combination of conditions will reasonably assure
+the appearance of the person as required
+and the safety of the community if the judicial officer
+finds that there is probable
+cause to believe that the person committed
+an offense for which a maximum term of
+imprisonment of ten years or more is prescribed in the Controlled Substances Act
+(21 U.S.C. 801 et seq)., the Controlled
+Substances Import and
+Export Act (21
+U.S.C. 951 et seq.), section 1 of the Act of
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+other person and the community in a case-
+"(1) upon motion of the attorney for the
+Government, that involves-
+"(A) a crime of violence;
+"(B) an offense for which the maximum sentence is life imprisonment or
+death;
+"(C) an offense for which a maximum
+term of imprisonment of ten years or
+more is prescribed in the Controlled
+Substances Act (21 U.S.C. 801 et seq.),
+the Controlled Substances Import and
+Export Act (21 U.S.C. 951 et seq.), or
+section 1 of the Act of September 15,
+1980 (21 U.S.C. 955a); or
+"(D) any felony committed after the
+person had been convicted of two or
+more prior offenses described in subparagraphs (A) through (C), or two or
+more State or local offenses that would
+have been offenses described in subparagraphs (A) through (C) if a circumstance
+giving rise to Federal jurisdicion had existed: or
+"(2) Upon motion of the attorney for
+the Government or upon the judicial officer's own motion, that involves-
+"(A) a serious risk that the person
+will flee;
+"(B) a serious risk that the person will
+Page 11
+continuance. Except for good cause, a continuance on motion of the person may not
+exceed five days, and continance on motion of the attorney for the Government
+may not exceed three days. During a coninuance,
+ney for the Government or on his own motion, may order that, while in custody
+person who appears to be a narcotics addict
+receive a medical examination to determine
+whether he is an addict. At the hearing, the
+person has the right to be represented by
+counsel, and, if he is financially unable to
+obtain adequate representation, to have
+counsel appointed for him.
+The person
+shall be afforded an opportunity to testify,
+to present witnesses on his own behalf, to
+cross-examine witnesses who appear at the
+hearing, and to present information by
+proffer or otherwise. The rules concerning
+admissibility of evidence in criminal trials
+do not apply to the presentation and consideration
+of information at the hearing
+The facts the judicial officer uses to support a finding pursuant to subsection (e)
+that no condition or combination of conditions will reasonably assure the safety of
+any other person and the community shall
+be supported by clear and convincing evidence. The person may be detained pending
+completion of the hearing
+"(g) Factors To Be Considered.-The judicial officer shall, in determining whether
+ccount the available information concern
+ing-
+a prospective witness or juror.
+The hearing shall be held immediately
+apon the person's first appearance before
+he judicial officer unless that person, or
+the attorney for the Government, seeks a
+"(1) the nature and circumstances of the
+ffense charged, including whether th
+ffense is a crime of violence or involve
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+a narcotic drug;
+"(2) the weight of the evidence against
+the person;
+"(3) the history and characteristics of
+the person, including-
+"(A) his character, physical and menfinancial resources, lengs, on residence
+financial resources, length
+Page 12
+*978 "(B) whether, at the time of the
+current offense or arrest, he was on probation, or parole, or on other release
+pending, trial,
+sentencing, appeal.
+• ог
+completion of sentence for an offense
+under Federal, State, or local law; and
+"(4) the nature and seriousness of the
+danger to any person or the community
+that would be posed by the person's release. In considering the conditions of release described in subsection (c)(2)(K) or
+(C)(2)(L), the judicial officer may upon
+his own motion, or shall upon the motion
+of the Government, conduct
+an inquiry
+into the source of the property to be designated for potential forfeiture or offered
+as collateral to secure a bond, and shall
+decline to accept the designation, or the
+sets forth all the conditions to which the
+grace the pron one are a :.
+"(2) advise the person of-
+"(A) the penalties for violating a conlition of release, including the penaltie
+or committing an offense whil
+"(B) the consequences of violating a
+mediate istance a warant or the
+person's arrest; and
+"(C) the provisions of sections 1503
+of this title (relating to intimidation of
+witnesses, Jurors.
+and officers of the
+court), 1510 (relating to obstruction o
+criminal
+investigations),
+(tampering with a witness, victim, or an
+informant),
+1513
+(retaliating
+against a witness, victim, or an inform-
+"(i) Contents of Detention Order.-In a
+detention order issued pursuant to the
+provisions of subsection (e), the judicial
+officer shall-
+"(1) include written findings of fact
+and a written statement of the reasons
+for the detention;
+"(1) include a written statement that
+"(3) direct that the person be affordec
+relation ve op his counsel, a private con-
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-...
+
+
+
+"(4) direct that, on order of a court of
+the United States or on request of an atin charge of the corrections facility on
+which the person is confined deliver the
+person to a United States marshal for
+the purpose of an appearance in connection with a court proceeding.
+The judicial officer may, by subsequent orler, permit the temporary release of the
+person, in the custody of a United States
+marshal or another appropriate person, to
+the extent that the judicial officer determines such release to be necessary for preparation of the person's defense or for another compelling reason.
+() Presumption of Innocence.-Nothing !!
+his section shall be construed as modify
+ing or limiting the presumption of inno-
+"§ 3145. Review and appeal of a release
+or detention order
+"(a) Review of a Release Order.-If a person
+is ordered released by a magistrate, or by a
+original irisdiction der the offense ang
+other than a Federal appellate court-
+"(1) the attorney for the Government
+may file with the court having original
+jurisdiction over the offense, a motion for
+revocation of the order or amendment of
+the conditions of release, and
+Rame on engin tor man men of
+the conditions of release.
+The motion shall be determined promptly.
+"(b) Review of a Detention Order.-If a person is ordered detained by a magistrate, or
+Page 13
+by a person other than a judge of a court
+having original jurisdiction over the oftense and other than a Federal appellate
+court, the person may file, with the cour
+naving original jurisdiction over the of
+fense, a motion for revocation or amendment of the order. The motion shall be determined promptly.
+"(c) Appeal From a Release or Detention
+Order.-An appeal from a release or detention order, or from a decision denying revocation or amendment of such an order, is
+The apa shal be determined prompily.!!e.
+C.S. Mass. 1985.
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-... 4/10/2008
+
+
+
+C.. (75), 1985.
+United States Court of Appeals,First Cir-
+UNITED STATES of America, Plaintiff,
+Appellant,
+Ilario M.A. ZANNINO, Defendant, Ap-
+ellee
+1o. 85-1070
+Argued March 8, 1985.
+Decided May 3, 1985.
+United States appealed from an order of the
+United States District Court for the District
+of Massachusetts,
+David S. Nelson,
+denying its motion to revoke bail of defendant and to detain him pursuant to the
+Bail Reform Act. The Court of Appeals,
+lorruella, Circuit Judge, held that provisions of Bail Reform Act on pretrial detention and bail revocation were applicable to
+a defendant released on bail before effective date of Act where defendant's expectation of remaining free on bail was both
+minimal, in view of emphatic statement of
+magistrate, upon both granting motion for
+bail under earlier law and denying Government's motion for revocation of bail, that
+he found defendant to be a danger to community and that he would detain detendant
+it he had a legal mechanism by which to do
+so, and outweighed by public interest in
+protection from demonstrably dangerous
+Reversed.
+Breyer, Circuit Judge, dissented and filed
+West Headnotes
+Bail 49 € 39
+49I1 In Criminal Prosecutions
+to community and that he would detain defendant if he had a legal mechanism by
+which to do so, and outweighed by public
+interest in protection from demonstrably
+dangerous
+defendants. 18 U.S.C.A. §9
+3142(e), 3148(b).
+*53 Diane M. Kottmyer, Boston, _Mass.,
+with whom Ernest S. Dinisco and Jane E
+Serene, Sp. Attys., William F. Weld, U.S.
+Atty.,
+Jeremiah I. O'Sullivan,
+Boston, Mass., were on brief for
+plaintift, appellant
+Joseph J. Balliro,
+Boston, Mass.,
+whom James L. Sultan, Boston, Mass., was
+on brief for defendant, appellee.
+Before BREYER and TORRUELLA, Circuit Judges, and SELYA,™* District Judge.
+FN* Of the District of Rhode Is-
+land, sitting by designation.
+TORRUELLA, Circuit Judge.
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+Massachusetts of its motion to revoke the
+bui no de deni Recom or ar ai, pecifically
+U.S.C. s
+3142(e)
+3148(b).FN1
+FNI. Section 18 U.S.C. § 3142(e)
+provides:
+DETENTION.-Il, after a hearing
+ursuant to the provisions of sub
+section (t), the
+judicial officel
+inds that no condition or combin
+ably assure the appearance of the
+person as required and
+. the safety
+of any other person and the comhe shall order the detention of the person prior to trial. I
+a case described in (Đ(1), a rebuttable
+presumption
+arises that no
+condition or combination of conditions will reasonably assure the
+safety of any other person and the
+community if the judge finds that-
+*(1) the person has been
+convicted of a Federal offense that is
+described in subsection (f)(1), or
+of a State or local offense
+that
+would
+have been
+an offense described
+in subsection (f)(1) if a
+circumstance
+ziving rise to Federal jurisdiction had existed;
+offense, described in paragraph
+(1), whichever is later. Subject to
+rebuttal by the person, it shall be
+presumed that no condition or
+combination of conditions will
+reasonably assure the appearance
+of the person as required and the
+atety of the community if the ju
+officer finds that there is
+probable cause to believe that the
+person committed an offense for
+which a maximum term of imprisonment of ten years or more is
+prescribed in the Controlled Substances Act (21 U.S.C. 801 et
+seq.), the Controlled Substances
+Import and Export Act (21 U.S.C
+951 et seq.), section 1 of the Ac
+of September 15, 1980 (21 U.S.C.
+955a), or an offense under section
+924(c) of title 18 of the United
+States Code."
+Section
+18 U.S.C. § 3148(b)
+provides:
+(b) REVOCATION
+LEASE.-The attorney for the
+Government may initiate a proceeding for revocation of an order
+of release by filing a motion with
+the district court. A judicial officer may issue a warrant for the
+arrest of a person charged with vioftene, an federi, Satc, o ocd
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+' 761 F.2d 52
+before the judicial officer who
+ordered the release and whose or
+der is alleged to have been violated.
+The
+judicial officer shall
+enter an order of revocation and
+detention if, after a hearing, the
+"(1) finds that there is-
+"(A) probable cause to believe
+Federal,
+Federal, Perate, has local crime
+State,
+or local
+while on release; or
+"(B)
+clear and convincing
+evidand other condition as release.
+"(2) finds that-
+"(A) based on the factors set forth
+in section
+3142(g)
+there
+is no
+ondition or combination of conditions of release that will assure
+that the person will not flee or
+pose a danger to the safety of any
+other person or the community; or
+"(B) the person is unlikely to
+abide by any condition or combination of conditions of release.
+leveral probal ace so bee
+person
+committed
+Federal,
+State, or local felony, a rebuttable
+any other person or the comand that the person will
+abide by such conditions, he shall
+in
+the provisions of section
+3142 and may amend the conditions of release accordingly."
+*54 On September 19, 1983, a federal
+ore the magistrate on September 20, 198.
+Lannino was ordered held without bail o
+the grounds that no conditions of pretrial
+release would reasonably assure his appearance at trial. Eventually,
+however,
+terms for release on bail were set. In his order dated December 23, 1983, the magistrate expressly found that Zannino posed a
+serious and substantial threat to the safety
+of the community and that, were it not for
+the fact that he had no authority to detain
+the defendant under the 1966 Bail Reform
+Act on those grounds, he would unhesitatingly order Zannino held without bail
+pending trial. Zannino was, therefore, released on bail in early January, 1984.
+Shortly after the passage of the Bail Re-
+form Act of 1984 in October of that year,
+the Government filed a motion to revoke
+bail as to Zannino and to hold a detention
+hearing, alleging, as
+, grounds thereof, the
+previous findings of the magistrate concerning dangerousness to the community
+the rate one find to here
+or pose danger to the sat y
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+der the 1984 Act was grounds for revocation of bail. 18 U.S.C. § 3148(b) (1984).
+The magistrate denied the motion, finding
+that the 1984 Act did not apply to pending
+cases in which the defendant was already
+released on ball. In his order, however, he
+once again reiterated his conclusion that no
+condition or combination
+of conditions
+could reasonably assure the safety of any
+other person" or the community in the absence of Lannino's pretrial detention. The
+magistrate's denial
+was thereafter affirmed
+by the district court and the government
+#pealed. Thus, the specific issue before us
+whether Sections
+3142(e),
+which
+provides for the pretrial detention,
+3148(b), which provides for bail
+tion, apply to a defendant released on bail
+prior to the effective date of the 1984 enactments. F2
+FN2. Inasmuch as the constitutionality of a retrospective application
+of the 1984 Act is not now being
+challenged,
+the case must turn on
+the intent of Congress.
+The Supreme Court has held that the federal courts must apply the law in effect at the
+time it renders its decision, unless doing so
+would result in manifest injustice *55 or
+where there is clear statutory direction or
+egislative history to the contrary. Bradley
+Richmond School Board, 416 U.S. 696
+(1974) See United States " Gennaro J.
+(1974). See United States
+Gennaro J.
+Page 4
+That the decision releasing Zannino was
+not unalterable and, even as originally issued, was subject to revision at any time
+prior to trial, is particularly evidenced by
+the text of the section of the pre-1984 Act
+under which he was released:
+A judicial officer ordering the release of a
+person on any condition specified in this
+section may at any time amend his order to
+impose additional or different conditions of
+Provided that, if imposition of
+such additional or different conditions results in the detention of the person as a result of his inability to meet such conditions
+or in the release of the person on a condition requiring him to return to custody,
+subsection (d) [requiring review] shall apply.
+(Emphasis in original). Bail Reform Act of
+1966, 18 U.S.C. §
+3146(e), repealed by
+Bail Reform Act of 1984, 18 U.S.C. §
+3142(c). Thus the decision regarding the
+terms of bail may be considered to have
+subject to post-bail
+been an open matter before the 1984 Act
+release review, even
+was passed on October 12th.
+We thus look to the situation created by the
+passage of the
+to ascertain
+whether an individual in Zannino's position
+in effect receive a privilege vis-
+a-vis all defendants charged after October
+12th, notwithstanding the pendency of all
+their proceedings. Since nothing in the new
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+' 761 F.2d 52
+a stronger argument to support his contention that the pretrial detention provisions
+did not apply to his case. Id. By positing
+this hypothetical, we were not creating
+hard and fast rule.
+Closer examination.
+within the context of an actual case and
+controversy, does not support this exception to the retroactivity of the new Act.
+Section 3146(e) of the 1966 Act clearly
+states that conditions of the release can be
+changed, and that the inability to meet such
+conditions could require the
+return to custody. Thus the release on bail allowed unler the 1966 Act was not an absolute grant;
+defendants were given notice that a change
+in conditions or terms could bring about
+the revocation of the release. That statute,
+furthermore, created no
+expectation that
+conditions would not change.
+What has actually occurred with the passage of the pretrial detention provision
+may be considered a statutorily mandated
+change in those conditions. That is, under
+Section 3142(e) of the 1984 Act, for a defendant to be eligible for pretrial bail, he
+must be able in certain instances to rebut
+the presumption that no condition or combination of conditions will reasonably assure the safety of "any other person and the
+community:" 18 U.S.C. § 3142(e). We hold
+that defendants released under the 1966
+Bail Act must show their continued eligibility for bail by meeting the newly imposed
+conditions if
+this issue is affirmatively
+raised by the Government.
+Page 5
+could detain Zannino existed, he would
+have done so. This clearly constituted noice*56 to appellee that a change of condi
+tion, such as
+las occurred by the passage o
+for dangerousness, would call for reevalation of his release.
+Under the manifest injustice standard of
+Bradley, supra,
+the disappointment of
+private expectations that results from the
+implementation of a new rule must be balanced against public interest in the enforcement of that rule. New England Power Co.,
+Home of Williamstown,
+548 F.2d 1077, 1080 (1st Cir.1977). Im-
+portant public policy
+considerations dictated the enactment of a pretrial detention
+mechanism whereby the community could
+be safeguarded from the "alarming probof crimes committed
+"by demonstrably dangerous defendants"
+pretrial release. See Report of the Committee on the Judiciary, United States Senate
+on S.1762, S.Kep. No. 225, 98th Cong., Is
+Admin.News 1984,
+Admin.News 1984, P. 3182, 3184,
+pp. 3182,
+3187-3189. Logic and common sense, as
+well as the new Act's legislative history,
+dictate application of the new conditions to
+all dangerous defendants, including those
+previously released because of the lack of
+Judicial power to prevent such a result.
+Pic hid ga canim by which the
+BENE
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619. 4/10/2008
+
+
+
+such defendants."
+priate decisions regardin® is strong
+the release of
+, talk,
+couched in a sense of legislative urgency.
+It is inconceivable to us that, in the face of
+such concerns, the Congress meant for the
+courts to temporize in the application of the
+pretrial release provisions of
+the 1984 Act
+by interdicting the use of such detention
+powers in any suitable case, whether or not
+he accused had previously been release
+under the more relaxed criteria of the 1966
+Act. The legislative
+histor
+fairly read,
+epresents a člear statutory directive favor.
+ng applicability of the new pretrial releas
+scheme across the board. Indeed, the basi
+purposes of the new Act, as we delineated
+them in Angiulo, at 971-972, lead to the
+same conclusion.
+The statistics cited by our dissenting brother are similarly unconvincing.
+The smallness of the potentially affected group is
+transmutable: it can be used just as powerfully to argue for, as against, the applicability of the 1984 Act. Neither this contention nor its corollary-ease in judicial administration-therefore cuts much ice. Even
+a single dangerous defendant left free to
+wreak havoc under circumstances where
+pretrial
+detention is constitutionally permissible and
+legally appropriate is one
+nenace too many; and, if the price of pro
+tecting the public is more work for already
+overtaxed judges, it is a small price to pay
+for the wellbeing of the community.
+Page 6
+New England Power Co. standards, Sections 3142(e) and 3148(b) apply retroactively to Lannino, and that the government
+is entitled to a hearing before the magistrate on the merits of the issues raised by
+its motion to revoke.
+We recognize that other courts have
+States a fernander-Toledo, 749 f:2d 703,
+705 (11th Cir.1985), and we do not lightly
+reate a split among the circuits. Ye
+mindful of
+the nature of the rights involved, the impact of the change in law
+upon those rights, the will of the Congress,
+and the substantial public interest which
+we perceive to be at stake, we must respectfully disagree with the rationale of the
+Eleventh
+Circuit.
+The
+Fernández-Toledo*57, panel, without indepth analysis of either the provisions of
+the 1966 Act or the legislative history of
+the 1984 Act, held under circumstances
+comparable to those at bar that the defendant's "rights to bail had already vested, "id.,
+and therefore declined to give the new law
+retrospective effect in such a situation. We
+are not of a similar mind. To be "vested," a
+thing must be "fixed; ... settled; absolute
+..; not contingent." H. Black, Black's Law
+Dictionary at 1401 (5th Ed.1979). The cession of bail partakes of none of these characteristics; it is a privilege extended,
+even the 1966 Act evidenced, on a contingent, nonabsolute basis, entirely subject to
+the dynamics of change, consistent with
+applicable law and fundamental fairness.
+• was, in these circumstances, unjustifie
+e conclude that under the Bradlev ar
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619 4/10/2008
+
+
+
+The decision of the district court is reversed.
+BREYER, Circuit Judge (dissenting).
+The issue in this case is whether the provision of the new Bail Act that provides for
+detention of "dangerous" persons,
+U.S.C. 8. 3142(1), applies to a person
+already released on bail the day the new
+Act was passed (October 12, 1984). This
+court has previously suggested (though it
+did not expressly hold) that Congress did
+not intend this provision of the Act to ap-
+" to those
+persons. United lates actively, 1551rzd
+969, 970 (1st Cir. 1985). I believe the suggestion is correct for the following reasons.
+First, it is "manifestly unfair" to apply the
+new detention provision to those released
+Bradle befRichmond Schools Board, See
+soard. 410
+U.S. 696, 711, 94 S.Ct. 2006, 2016, 40
+L.Ed.2d
+(1974).
+Magistrates
+judges specifically gave those defendants
+their provisional freedom. The defendants
+in all likelihood relied on the fact that (in
+the absence of misbehavior) they would remain free to prepare their trial defense, to
+witnesses,
+to consult with their
+attorneys. Trials, for most members of this
+class, must be imminent. Application of the
+new standard to members of this class
+threatens to intertere severely with ongoin
+defense preparations, not
+only because 1
+may place a defendant behind bars just before trial, but also because even appearance
+pung hot have and mei gal a
+Page 7
+terterence with a settled expectation. That
+means "unfairness." See Myers | Hawkins
+362 So.2d 926, 933 n. 25 (Fla. 1978) ("
+'One of the fundamental considerations of
+fairness recognized in every legal system Is
+that settled expectations honestly arrived at
+with respect to substantial interests ought
+Sut to and stated onguing 2 S41.0s
+Sutherland Statutory
+at 261 (4th ed. 1973)).
+Second, not to apply the detention provi
+sion of the new Act to previously release
+detendants does not intertere significantly
+with Congress's objective: giving judges a
+way to deal with "dangerous" defendants
+The number of persons already free on bail
+(as of October 12) is rapidly diminishing
+The Director of the Administrative Office
+of the United States Courts reports that approximately 18,000 indictments or charges
+are pending at any one time. The average
+length of time between charge and trial is
+4.4 months. Thus even if all federal defendants facing charges on October 12
+were on release (with an average time of
+2.2 months remaining before trial), by now
+(April 1985) there must be only a handful
+of pre-October 12 defendants whose trials
+have not yet begun. Can one say that, in
+terms of Congressional purpose, it is of
+critical importance to apply the new Act to
+this small (and diminishing) class of persons,*58 when Congress itself considered
+adoption of this "dangerous person"
+No. 225, 98th Cong.,
+(1983), reprinted in1984 U.S.Code Cong
+& Ad.News 3182, 3189 & n. 19 (Supp. 9A)
+Thistion have he th that ve Act does this
+ply to this class of persons. United State.
+Fernandez-Toledo. 749 F.2d 703. 70
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+*761 F.2d 52
+(11th Cir.1985) (per curiam) (holding that
+"*vested"
+and that on would be manifestly unjust to
+Pply the new Act to them Suppen
+: United States
+Mitchell,
+N.D.Cal.1985) ("Congress apparently did
+not contemplate that
+individuals released
+pursuant to [the old Act] would be subject
+United States in Payden, 759F20 202(20
+759 F.2d 202 (2d
+Cir. 1985) (reversing district court decision
+ordering detention, under provisions of the
+new Bail Act, of defendant whose release
+had been ordered pursuant to provisions of
+the old Bail Act). Even were I less convinced of the correctness of Anguilo, I
+would hesitate to create a split in the circuits over this particular legal issue.
+Fourth, there is additional support in the
+language of the new Bail Act itself. The
+new Act does not contain a provision that
+allows the government to recall a detendant solely for the purpose of applying the
+new, stricter standard of release. The new
+Act (like the old) does provide
+for reconsideration and modification of release consees 3142(C) (allowing imposition
+of "additional or different conditions of release"), but this provision does not author-
+"modification" that changes a release
+order into an unconditional detention orbut only if the government can show that
+the defendant has violated his release conditions. Of course, there is substantial authority for the proposition that courts have
+"inherent power" to revoke bail when
+necessary to insure the defendant's appearance or to protect the integrity of the judicial process.
+States, 82 S.Ct. 662, 667-69, 7 L.Ed.2d 769
+(Douglas,
+Justice)
+(1962); Fernandez
+aero United
+Page 8
+States, 81 S.Ct. 642, 5 L.Ed.2d 683 (1961)
+(Harlan, Circuit Judge) (protection of wit-
+490 (D.C.Cir.1969)
+United States Anguilo, srora, at 972. Bul
+there is no authority extending that "inherpower to instances of defendant
+"dangerousness."
+Finally, the legislative history of the new
+songre mi concentriu or pening
+crimes and for treating accused persons
+fairly. See,
+e.g.. S.Rep.,
+(noting "the importance of the interests of
+the defendant which are implicated in a
+pretrial detention hearing"
+and the "due
+process" considerations in establishing the
+procedural requirements of the new Act).
+The arguments advanced in favor of applying the new provision (in a sense) retro
+actively to those previously released ar
+unconvincing. The government says that, if
+the new Act does not apply in its entirety to
+hese defendants, then no law applies to
+Bail Reform Ael as of Ocd ber 12, 1984
+Trason or ener, a cow pro Win in a me
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619... 4/10/2008
+
+
+
+erns that circumstance or person, whether
+or not the new law "expressly" repeals the
+old law as of a certain date. Thus,
+ample, Congress has
+repealed the Youth
+Corrections Act as of October 12, 1984,
+see*59Pub.L.
+No.
+98-473,
+Title
+HI,
+218(a)(8), 98 Stat. 1837, 2027 (1984), but.
+is the Department of Justice has recog
+lized. it mav be unconstitutional under the
+Page 9
+fendants who
+committed crimes prior to
+that date. See U.S. Dept. of Justice, Handbook on the Comprehensive Crime Control
+Act of 1984 and Other Criminal Statutes
+Enacted by the Soth Congress 32 (1984).
+As to those persons, the Department says
+See also
+Romero, 596
+A similar approach in this case is in accord with well
+established
+precedent.
+e.g.,
+United States
+les Payden, supra holding
+that defendant's
+should be determined under provisions of old Bail Act,
+even after its repeal, where bail application
+Uhthorn,
+F.Supp.
+(E.D.Ark.1964), aff'd,366
+_F.2d 211 (8th
+1r.1966), cert. denied,385 U.S. 1026
+.Ct. 753, 17 L.Ed.2d 674 (1967); State
+McMillin, 150 Colo. 23, 370 P.2d 435
+(1962) (en banc); In
+Opinion of the
+Justices,
+Mamat 271 Wis. 176, 72
+Mamat,
+fact rely upon guarantees of continued
+freedom. It does not make sense here,
+however, to apply an "unfairness" test on a
+case-by-case basis. The very act of doing
+so creates untair burdens, for it injects a
+new, and potentially unresolvable, issue into each bail revocation proceeding. Rather,
+to prevent serious unfairness the Act must
+not apply to the class of persons already released on bail on October 12, avoiding unfairness by creating a bright, judicially administrable line.
+Further, the government argues that not to
+apply the new provision
+• retroactively
+leaves it without a remedy against one
+(allegedly like the defendant here) who
+commits a crime while free on bail. This is
+not so. For one thing the government could
+indict the person for that crime (whether it
+was committed before or after October 12,
+1984), at which point the government
+seek his detention under the new
+law. For another thing, the new Bail Act allows the magistrate to attach a new condition to a defendant's pre-October 12 bail
+order-the condition that he not commit new
+crimes while on release. To attach this condition to the bail of one previously released
+does not seem unfair. Indeed, the old Act
+provides magistrates and
+Judges with the
+express authority to modify release condi
+tions. See18 U.S.C. §
+3146(e) (repealed
+October 12, 1984). In this case, the magistrate attached a condition on October 31,
+1984, that Zannino not commit any crimes
+while on release. Thus, Zannino's release
+The government also argues that it is not
+nfair to apply the new provision to thi
+articular defendant because he did not i
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+* 761 F.2d 52
+, the majority points to a provision
+in the former 1966 law that allows a magistrate to impose "additional or different conditions of release" upon a person free on
+bail. Bail Reform Act of 1966, 18 U.S.C. §
+3184, 1 Used by Bail The matory
+the existence of this provision
+makes it more fair to apply the new law
+retroactively to those already free on bail.
+! disagree,
+because a new
+condition seems to me very different from an unconditional detention or-
+Page 10
+For the foregoing reasons, I believe Condetention provision of the new Bail Ar
+provision of the new Bail Act
+to apply to those already free on bail on
+October 12.
+And, I would affirm the judgment of the
+district court.
+,.A. L (Mass.), 198:
+J.S. _ Zannin
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+P
+C.A. 10,1950k
+),1985.
+United States Court of Appeals, Tenth Circuit.
+UNITED STATES of America, Plaintiff-
+Appellee,
+V.
+irant C. AFFLECK, Defendant-Appellant
+JNITED STATES of America, Plaintiff
+Appellee,
+v.
+Frank KOWALIK, Jr., Defendant-Appellant.
+Nos. 85-1009, 84-2600.
+May 24, 1985.
+Defendants challenged denial by. the
+United States District Court for the District
+of Utah, David K. Winder, J., and the
+United States District Court for the District
+of Colorado, Zita L. Weinshienk, J., of motions for bail pending appeal. After panel
+denied motions for release pending appeal,
+ehearing
+en bane was granted, with the
+Court of
+Appeals, Holloway, Chief Judge,
+holding that: (1) Bail Reform Act section
+setting forth standards governing release of
+defendants on bail pending appeal applied
+to defendants even though they were convicted before effective date of the Act; (2)
+application of the new standards to defendants convicted before effective date of the
+Act did not disadvantage them in any way
+prohibited by the ex post facto clause; (3)
+two-step analysis for determining whether
+to grant bail pending appeal would be adopted, though with stricter interpretation of
+what constitutes "substantial"
+question of
+law or fact than that applied by the Third
+Circuit; and (4) need for a clear record a
+listrict court hearing warranted partial re
+mand.
+Cases partially remanded.
+McKay, Circuit Judge, dissented and filed
+opinion, in which Seymour, Circuit Judge
+joined, also filing a separate dissenting
+West Headnotes
+[1] Bail 49 € 44(1)
+49 Bail
+49Il In Criminal Prosecutions
+49k41 Right to Release on Bail
+49k44 Pending Appeal or Other
+Proceeding for Review
+49k44(1) k. In General; Conditions. Most Cited Cases
+There is no constitutional right to bail
+pending appeal.
+12] Bail 49 € 39
+49Il In Criminal Prosecutions
+49k39 k. Nature and Scope of Remedy. Most Cited Cases
+Section of Bail Reform Act [18 U.S.C.A. §
+3143(b)] setting forth standards governing
+release of defendants on bail pending appeal, became fully effective on October 12,
+1984 and applied to defendants seeking
+ail pending appeal after that date, eve
+hough they were convicted before th
+13] Bail 49 € 39
+49 Bail
+49II In Criminal Prosecutions
+49k39 k. Nature and Scope of Remedy. Most Cited Cases
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+Constitutional Law 92 €~2810
+92 Constitutional Law
+92XXIII Ex Post Facto Prohibitions
+92XXIII(B) Particular Issues and
+Applications
+92k2809 Criminal Proceedings
+92k2810 k. In General. Most
+Cited Cases
+(Formerly 92k203)
+Application of new Bail Reform Act [18
+U.S.C.A. § 3143(b)] standards governing
+release of defendants on bail pending appeal to defendants convicted before effective date of the Act did not disadvantage defendants in any way prohibited by the ex
+post facto clause, though the sentences and
+the district court orders denying bail
+appeal were entered
+after that
+date; the Act introduced significant procedural change,
+. disadvantageous to defend-
+, but it did not change the quantum of
+U.S.C.A. Const. Art. I, $ 9, Cl. 5.
+the crimes.
+[4] Bail 49 Cm 44(4)
+49 Bail
+4911 In Criminal Prosecutions
+49k41 Right to Release on Bail
+49k44 Pending Appeal or Other
+Proceeding for Review
+49k44(3) Grounds for Grant or
+Denial
+49k44(4) k. Substantiality
+of Grounds for Review; Delay. Most Cited
+Cases
+State-step analysor determined in tried
+in reversal or order for new trial of all
+inquiry
+whether appeal
+'substantial"
+question of law or fact, and,
+secondly, whether resolution of that quesion in favor of defendant is likely to result
+15] Bail 49 em44(4)
+4911 In Criminal Prosecutions
+49k41 Right to Release on Bail
+49k44 Pending Appeal or Other
+Proceeding for Review
+49k44(3) Grounds for Grant or
+Denial
+49k44(4) k. Substantiality
+of Grounds for Review; Delay. Most Cited
+Cases
+For purposes of determining whether de-
+U.S.C.A
+3143(b)] has raised a substantial question
+of law or fact, a "substantial" question is
+one of more substance than would be necessary to a finding that it was not frivolous; it is a close question or one that very
+well could be decided the other way, but
+whether it has been treated by controlling
+precedent is not determinatíve;
+whether
+particular question is "substantial" must be
+determined on case-by-case basis.
+[6] Criminal Law 110 €-1181.5(3.1)
+110 Criminal Law
+110XXIV Review
+110XXIV(U)
+Determination
+Disposition of CaiS Remand in General:
+Vacation
+Determination or 18.Soasideraten of Particular Matters
+110k1181.5(3.1) k. In General. Most Cited Cases
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+(Formerly 110k1181.5(3))
+Need for a clear record at hearing in the
+district court in order to resolve question
+whether defendants were entitled to bail
+Usog appeal under Bail Reform Act [18
+l. 8 3143(b)] standards warrantec
+partial remand for such hearings and reconsideration of denials of motions for bail
+hereing appeal under standards adopted
+*945 A. Brent Carruth,_Carruth & Goodwin, Van Nuys, Cal. (Eric A. Goodwin,
+Carruth & Goodwin, Van Nuys, Cal., with
+him on the briefs), for defendant-appellant
+Affleck.
+rent D. Ward, U.S. Atty., Salt Lake City
+Utah (David Schwendiman, Sp.
+Asst. U.S
+Atty, Salt Lake City, Utah, with him on
+the brief), for plaintiff-appellee U.S. in No.
+85-1009.
+Albert M. Pearson, University of Georgia
+School of Law,
+Athens, Ga., and Scott
+_ Athens,
+Ga. (Cecil Hartman,
+Denver, Colo., with them on the brief), for
+defendant-appellant, Kowalik.
+Thomas M.
+. O'Rourke, Asst.
+Denver,
+Colo. (Robert N
+AUST
+Atty. with him on the briet), T
+appellee U.S. in No. 84-2600.
+Michael L. Bender, Bender & Treece, and
+Jay P.K. Kenney, Denver, Colo., were on
+the brief in 84-2600 for amicus curiae Nat.
+Ass'n of Criminal Defense Lawyers.
+Before HOLLOWAY,
+Chief Judge,
+SETH, BARRETT, DOYLE, McKAY, LO-
+GAN, and SEYMOUR, Circuit Judges 'N*.
+FN* Senior Circuit Judges Seth and
+Doyle,
+Doich initially muled on defendants
+mo panic in in he in an al
+termination upon their election and
+HOLLOWAY, Chief JudgeS. C. 840(0)
+Chief Judge
+OPINION ON REHEARING EN BANC
+Act of
+1984, Title II of Pub.L. No. 98-473, 98
+Stat. 1976, approved October 12, 1984.
+appeal.
+I
+Facts
+A. Affleck
+FN1. 15 U.S.C. § 78j; 17 C.F.R. §
+240-10b-5.
+FN2. 18 U.S.C. $§ 152, 2.
+FN3. 18 U.S.C. § 2314.
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+765 F.2d 944. 53 USL W 2628
+On November 16, Affleck was sentenced to
+ten years' imprisonment and five years'
+probation. On November 19, Affleck filed
+a notice of appeal. On November 20 the
+district court, in response to Affleck's ex
+stayed execution of the sen-
+Page 4
+mediate threat of fleeing during appeal and
+no immediate danger to society during that
+period." VIII R. 1438-39.
+On November 21, the Government filed a
+motion in the district court to reconsider its
+order staying execution of Affleck's sentence and ordering his release pending appeal, or in the alternative, to hold an exped
+Ited hearing and to make the findings to
+support such an order as required by 18
+U.S.C. § 3143(b), as amended
+by the new
+Act. Section 203(a) of the Act changed the
+standards governing release of convicted
+defendants on bail pending appeal.
+Under former 18 U.S.C. §§ 3146 and 3148,
+convicted defendants were entitled to release on ball pending appeal unless no one
+or more conditions of release would reasonably assure that they would not flee or
+pose a danger to any other person or to the
+community, or unless their appeal was
+frivolous or taken
+tor purpose of delay.
+The burden was on the Government under
+the former law to show that the appeal was
+frivolous and was taken for purpose of
+delay; the defendant bore the burden of
+showing he would not flee and was not a
+danger to any person or the community.
+See also former Fed.R.App.P. 9(c). The
+Act changed the criteria for release on bail
+ending appeal and placed the burden o
+he convicted defendant to prove that h
+all the new criteria. Current 18
+U.S.C. § 3143(b) provides as follows:
+Release or Detention Pending Appeal by
+the Detendant.-The judicial officer shall
+order that a person who has been found
+guilty of an offense and sentenced to a
+term of imprisonment, and who has filed
+an appeal or a petition for a writ of certiorarí, be detained, unless the judicial officer finds-
+(1) by clear and convincing evidence
+that the person is not likely to flee or
+pose a danger to the safety of any other
+person or the community if released
+pursuant to section 3142(b) or (c); and
+(2) that the appeal is not for purpose
+of delay and raises a substantial question of law or fact likely to result in reversal or an order for a new trial.
+Act § 203(a), 98 Stat. 1981-82 (emphasis
+added);
+alsoFed.R.App.P.
+9(c), as
+amended by Act § 210, 98 Stat. 1987.
+Affleck principally argued below that h
+was entitled to bail pending appeal because
+the former law entitled him to that relief,
+and that application to him of the new Act
+would violate the ex post facto clause.
+After a hearing,
+district court on
+December 11 vacated its earlier order. The
+cleat held colA fleck had established by
+clear and convincing evidence under
+3143(b)(1) that he was not likely to flee o
+pose a danger to the safety of any othe
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+new criteria of § 3143(b) to deny Affleck
+Page 5
+effect when the offenses were committed
+and when the guilty verdicts were returned.
+Id. at 1491-95.
+likely to result in reversal or an order for a
+new trial under § 3143(b)(2). and denied
+B. Kowalik
+Defendant Frank Kowalik,
+victed in the
+District of Colorado on
+September 19, 1984 after a jury trial of two
+*947 counts of willfully failing to file federal income tax returns in
+violation of
+I.R.C. § 7203. On November 14 the district
+court sentenced Kowalik to one year of imprisonment and
+_a $10,000 fine on each
+count. The district court on that date also
+ordered Kowalk's release pending appeal
+upon filing of a $20,000 bond. The court
+found that Kowalik did not pose a danger
+to the community and was not likely to
+flee. I R. 123.
+Also on November 14 Kowalik filed a notice of appeal and sought release on the appeal bond,
+but the magistrate concluded
+that release was inappropriate absent findings by the district court under § 3143(b).
+Kowalik principally argued that he was entitled to bail
+pending appeal under the
+former law. He also
+contended that he
+raised substantial questions likely to result
+in reversal or an order for a new trial under
+the new Act. He argued that the trial court
+erred in its instructions because they did
+not properly treat his defenses of not willfully and knowingly intending a violation
+of the tax law, and that the instructions did
+not properly cover the effect of evidence
+from his character witnesses. After a hearing on November 15, the district court vacated its earlier order permitting Kowalik
+to be released on bail pending appeal. The
+C. Proceedings in this court
+Both Affleck and Kowalik challenge the
+district courts' denial of their motions for
+release pending appeal.
+A panel of this
+court denied the
+motions
+for release
+pending appeal. On its own
+motion
+this court, by order of a majority of its active circuit judges on February 1, 1985,
+granted rehearing en banc of of the court's
+earlier orders denying the motions for release pending appeal.rns We
+expedited
+these cases for argument at our March term
+of court and asked counsel to brief and argue the effect of the new § 3143(b) standards in these cases. We now address various issues
+concerning the application to
+these defendants of the new § 3143(b) cr
+teria for release pending appea
+FN4. Kowalik's petition for a stay
+pending appeal was denied by order
+of a panel of this court on December 4, 1984. Affleck's motion for reing en banc.
+II
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+Effective Date and the Ex Post Facto
+Clause
+Page 6
+A. Effective date
+Affleck asserts that Congress did not inend the Bail Reform Act to apply to thos
+convicted of crimes before
+1984. He relies on cases holding that other
+provisions of the Bail Reform Act do not
+shat ae ee unie Sated or tei odore
+Toledo, 749 F.2d 703 (11th Cir.1985) (§
+9 3142, Which provides tor pretrial detention). But see United States _ Anguilo, 75.
+F.2d
+969,
+970-74
+(Ist
+Cir.1985)
+(application of pretrial detention provisions of new Act to a defendant incarcerated and seeking release
+Aed ck diso cites Grease United State),
+376 U.S. 149, 84 S.Ct. 615, |1 L.Ed.2d 576
+and argues that criminal statutes
+like § 3143(b)
+should not be given retrospective operation where to do so would
+interfere with antecedent rights. See also
+Fernandez-Toledo,
+at 705
+(defendant released on bail prior to effective date of the Act had a vested, antecedent
+right to bail).
+cesin ke Atace, ongu adok bore de.
+tober 12, who seeks bail pending appeal
+after that date. There is no constitutional
+right to bail
+ending appeal. See
+Inited States Provenzano
+. 602 F.Supp.
+230, 232 (E.D
+230 Came ronD a New York 383 Fisu ex
+182, 183 (E.D.N.Y.1974) Fs In these circumstances, we hold that § 3143(b), in the
+absence of a showing of congressional in•
+became fully effective
+on October 12 when the President approved the Act. Section 3143(b) theretore
+applies to Affleck even though he was convicted before the effer ve date of the Act.
+See United States
+Cirrincione,
+(N.D.Ind.1985);
+United States
+(N.D.III.1984); Unitea
+States Kowal, 596 F.Supp.
+Cavloie , ee ao taie sae n
+Gavrilovic,
+551 F.2d 1099, 1103
+Cir. 1977); United States | Clizer, 464 F.2d
+121, 123 n. 2 (9th Cir.), cert. deniea, 409
+U.S. 1080, 93 S.Ct. 679, 34 L.Ed.2d 669
+(1972).
+FN6. The legislative history of the
+Bail Reform Act notes that "there is
+clearly no constitutional right to
+bail once a person has been con-
+Sess.
+cobai S co o e ANews
+reprinted
+3182, 3209 (footnote omitted).
+B. The ex post facto clause
+[3] Affleck and Kowalik both argue that
+application to them of the
+3143(b)(2) standards
+governing
+inge" bail
+The Constitution provides that no "ex post
+facto [l]aw shall be passed." U.S. Const.
+cl. 3.e7 The ex post facto
+clauses forbid the enactment by co gaess
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+prescribed; or changes the rules of evidence by which less or different testimony is
+than was then re-
+18 L.Ed. 356 (1867);
+see also Weaver Graham, 450 U.S. 24.
+28, 101 S.Ct. 960, 963, 67 L.Ed.2d 17
+(1981). FNS
+FN7. The Constitution also prohibits the states from passing ex post
+facto laws. U.S. Const. art. I, § 10.
+cl. 1 ("No State shall ... pass any ...
+ex post facto |Jaw....").
+FN8. The Court_ has emphasized
+that "[t]he mark of an ex post facto
+law is the imposition of what can
+Page 7
+the punishment[.] nor change the ingredients of the offen[c]e or the ultimate facts
+28 L.Ed. 262 (1884) (brackets added to
+CO 50 20, 20 , 42 324
+(1977) (Even though it may work to the
+. Ohio, 269 U.S. 167,
+169-70,
+68-69,
+L.Bd. 216 (1925) (A)ny statute
+which punishes as a crime an act
+previously committed, which was
+innocent when done; which makes
+burdensome
+the punishment
+for a crime, after its commission, or
+which deprives one charged with
+crime of any defense available according to law at the time when the
+Wainwright,
+70 L.Ed. 216 (1925) (ex post facto clause
+not intended to "limit the legislative control of remedies and modes of procedur
+which do not affect matters of substance")
+The Court has held that "two critical elenents must be present for a *949 crimina
+or penal law to be ex post facto: it must be
+retrospective, that is, it must apply to
+events occurring before its enactment, and
+it must disadvantage the oftender attecte
+›y it." Weaver Graham, 450 U.S. at 29
+101 S.Ct. at 964 (footnotes omitted). FP
+FN9. See also Paschal
+Wainwright,
+1175-76
+Mulcrone,
+673 F.2d
+1169,
+(10th
+Cir. 1982); see generally J. Nowak,
+R. Rotunda &
+Constitu
+tional Law 477-78 (2d ed. 1983): 1
+Tribe American Constitutional Law
+477-84 (1978).
+The Court has stated that "no ex post facto
+violation occurs if the change effected is
+merely procedural, and does
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+bail pending appeal, one seriously disadvantageous to him in that respect, but the
+statute does not change the "quantum of
+punishment attached to the crime
+bert, 432 U.S. at 294, 97 S.Ct. at 2298. We
+agree with other cases, which have similarly held that § 3143(b) does not violate
+e ex post tacto clause. see United States
+Powell
+761
+F.2d 1227,
+1234
+(8th
+ir.1985) (en banc) (footnote omitted)
+(Admission to bail pending appeal is, tor
+Ex
+Post
+Facto
+Clause
+purposes,
+procedural'. It does not increase the pun
+shment for a crime already committed. but
+simply regulates the time at which imprisonment for that crime wil begin after conviction"); United States
+• Molt, 758 F.2d
+1198, 1200-01 (7th Cir.1985) ("We think
+the change in the standard for bail pending
+appeal is not an ex post facto law.... [T]he
+presumption is against construing a procedural change as an ex post facto law, and
+must carry the day in the absence of a
+stronger showing than made in this case
+that the change works an increase in
+ishment... The change in the balance of advantages against the defendant is too slight
+to brini tacth cause tin thied Si ds T
+753 F.2d 19, 21 (3d Cir.1985) (
+The availability vel non of bail pending
+appeal, albeit extremely important to the
+individual involved, is a procedural issue
+rather than a type of punishment to which
+the Ex Post Facto Clauses apply."); United
+States | Crabtree, 754 F.2d 1200,
+(5th Cir.1985), (opinion of Chief Judge
+Clark as a single circuit judge) ("[ (Section
+3143(a)(1) ] is merely procedural and does
+increasc the substante not an gece not
+Chiattello,
+Page 8
+ing the release of a defendant on appeal
+following a conviction is a matter of procedure and does not beari
+F.Supp. 453, 468 (S.D.N.Y.1984) (on motion to revoke bail) (*[Defendant's] entitlement to bail, and the cheesurby which that
+. constitute
+"modes of procedure' falling outside the ex
+post facto rule, notwithstanding the fact
+that
+increased
+restrictions
+upon
+bail
+pending appeal may undoubtedly "work to
+the disadvantage' of defendants.")
+n reaching this conclusion, we are mindtu
+f the Supreme Court's decision in Kring 1
+Missouri, 107 U.S. 221, 2 S.Ct. 443,
+L.Ed. 506 (1883). In Kring, the Court held
+that an ex post facto violation had occurred
+where the Missouri courts had imposed a
+death penalty by a second
+sentence in a
+murder case. A tormer plea of guilty to i
+second degree murder charge had resulter
+in a twenty-five year sentence; the defendant appealed and the judgment was reversed. Under Missouri law in force when
+the homicide was committed, the first sentence constituted an acquittal of first degree murder. Before retrial, the state law
+was changed so that this effect of an acquittal of first degree murder no longer operated. The defendant refused to withdraw
+his plea of guilty to second degree murder
+or to reenter a not guilty plea to the first
+degree murder charge.
+The trial court
+ordered a general not guilty plea entered to
+the first degree murder charge. The retrial,
+BARA
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+But it cannot be sustained without destroying the value of the constitutional
+provision, that a law, however it may invade or modify the rights of a party
+charged with crime, is not an ex post
+facto law, if it comes within either of
+these comprehensive branches of the law
+as Pleadings, Practice, and
+Can the law with regard to bail, to into the inal Jury
+l be changed to the disadvantage of th
+prisoner by state legislation after the of
+fence was committed, and such legislation not held to be ex post facto legislation, because it relates to procedure, as it
+does according to [Bishop on Criminal
+Procedure ]?
+And can any substantial right which the
+law gave the
+defendant at the time to
+which his guilt relates be taken away
+from him by ex post facto legislation, because, in the use or a modern phrase, it 1s
+called a law of procedure? We think i
+Page 9
+Id. at 232, 2 S.Ct. at 452 (emphasis added).
+We believe that Kring and its dictum respecting bail must be read in light of later
+Supreme Court opinions on the ex post
+facto clause. In Beazell, for example, the
+Court stated that "e]xpressions are to be
+found in earlier judicial opinions to the ef-
+The Court conceded that there "may be
+procedural changes which operate to deny
+to the accused a defense available at the
+time of the commission of his offense, or
+which otherwise affect him in such a harsh
+and arbitrary manner as to fall within the
+constitutional prohibition." Id. The Court
+noted that "Glust what alterations of procedure will be held to be of sufficient moment to transgress the constitutional prohibition cannot be embraced within a fornula or stated in a general proposition. The
+distinction is one of degree. But the constitutional provision was intended to secure
+substantial rights against arbitrary and op
+pressive legislation.
+'269 U.S. at 171,
+S.Ct. at 69.
+In Kring, the Court explained that the effect of the change in state law, which was
+denied application there as ex post facto,
+was that formerly conclusive evidence of
+innocence of the higher grade of murder
+could not be received at all, or was given
+no weight, and that the law on punishment
+was changed from a bar against the death
+penalty in such circumstances to a new law
+permitting such punishment. 107 U.S. at
+228, 2 S.Ct. at 449. Although we are bound
+y that holding in Kring, we must view th
+statements concerning bail and procedura
+changes in Kring in light of the ex post
+facto standards applied by the Court in subsequent cases.
+We are particularly persuaded by the Court's more recent focus in
+ex post jacto cases on the elements of the
+offense,
+the conditions and quantum of
+punishment, and the quantity and degree of
+S.Ct. at 966-967; Dobbert, 432 U.S. at 295,
+97 S.Ct. at 2299. In light of these standurds, we conclude that there is no ex pos
+grang anger as now premind l
+We are unpersuaded by the reasoning in
+Cirrincione, 600 F.Supj
+436 (N.D.III.T985). There the distric
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-...
+
+
+
+court held that § 3143(b)(2) violates the ex
+post facto clause. The court reasoned that a
+sentence which begins immediately is more
+severe than a sentence which commences
+after
+unsuccessful
+appeal.
+1443-46. The court said that "[w]hile the
+Supreme Court has not always been clear
+on the underlying rationales for the ex post
+jacto clause, certainly one rationale is that
+an individual who acts in reliance upon the
+known criminal penalties for his acts must
+be punished in accordance with that reliance." Id. at 1444.
+*951 Although we agree that the ex post
+facto clauses protect an individual who acts
+in reliance on the known criminal penalties
+for his conduct, we cannot accept the Cirrincione court's view that § 3143(b)(2) affects the punishment imposed for such conduct. A convicted defendant may wish to
+postpone serving his sentence until his apis decided,
+certainly, the
+pending appeal are "more onerous
+Send oe apet ac mor ngring, hai
+those under the former law. However, §
+3143(b)(2) does not in any way alter the
+"quantum of punishment"
+imposed on
+criminal defendants, or the elements and
+required proof of the offense, which are the
+main focus of the Supreme Court's more
+recent decisions. Dobbert illustrates the
+fact that significant changes, even
+procedure for imposition of the death penalty, do not necessarily violate the ex post
+facto clause.
+ur conclusion is also supported by stat
+ourt decisions which have upheld change
+sen pte ie tun sup emu colm nas noud
+that a state statute denying bail pending appeal by a habitual criminal was not ex pos
+facto as applied to a defendant who com
+Page 10
+mitted the offense and was convicted belore the ettecti
+date of the statute. State
+ex rel. Dorton | Circuit Court of Elkhar
+County, 274 Ind. 373, 412 N.E.2d 72
+(1980) Fo The court explained that the
+superseding
+statute did "not make an act
+críminal which was legal before the statute
+nor [did] it "provide a greater punishment
+the coor mission rd, atbed at thing opt
+Id. at 74 (quoting Hopt
+[ Utah, 110 U.S. 574, 579, 4 S.Ci. 202,
+04, 28 L.Ed. 262 (1884)).
+FN10. The court explained that
+"It)he necessity to protect society
+against further criminal acts by a
+convicted, but unpunished, person
+[by denying bail pending appeal]
+outweighs society's interest in protecting persons who may have a reversible conviction." 412 N.E.2d at
+Moreover, the Oklahoma Court of Criminal
+Appeals has held that a state statute prohibiting bail pending appeal if a defendant was
+convicted
+of rape or forcible sodomy,
+among other things, was not ex post jacio
+as applied to a defendant who committed
+the oltense belore the ellective date of th
+statute. Spitznas
+State, 648 P.2d 127
+(Okla Crim.App.1982). The court
+concluded that the statute was procedural and
+did not inflict greater punishment than the
+law imposed at the time the offense was
+committed. Id. at 1275-76.
+454 A.2d
+. 1308 (D.C.App.1982),
+• denied,460
+1087,
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+1781.
+76 L.Ed.2d 351 (1983). The court
+emphasized that the statute did not "impose
+formerly legal conduct a crime, makel
+formerly
+1314.FNI
+FNI1. But see Greene | State, 238
+(Fla. 1970)
+(application of ball statute to deny
+bail pending appeal from conviction
+on second
+acto clauses where bail statute be-
+Page 11
+fective date of the Act, but the sentences
+and the order by the district court denying
+bail pending appeal were entered after that
+*952 I||
+Interpretation of 18 U.S.C. § 3143(b)(2)
+(Fla.Dist. Ct.App.1982) (per curiam)
+(ex post facto clause prohibited application
+pending appeal
+of drug trafficking
+conviction to defendant who committed offense before
+of statute; f. Parker | State, 667
+at time of offense
+under state
+passed after date of offense but beconviction which eliminated
+bail for persons convicted of certain
+felonies did not apply to defendant);
+Ellis State, 544
+S.W.2d 908,
+(Tenn.Crim.App. 1976)
+denying bail
+pending appeal to defendants convicted of possession of
+controlled substances with intent to
+sell had "ex post facto overtones"
+when applied
+to defendants who
+were arrested after effective date of
+statute).
+We therefore hold that the § 3143(b)(2)
+the appeal "raises a substantial question of
+law or fact likely to result in reversal or an
+order for a new trial." The parties in both
+the Affleck and Kowalik cases contend that
+we should interpret this requirement in
+light of the two-step analysis announced by
+he Third Circuit in United States | Miller
+ment, however, argues that a stricter interpretation than that of Miller should be ap-
+"substantial question of law or fact.
+determine what constitutes
+In Miller, the Third Circuit held that the
+language quoted above requires the court
+to make two determinations in order to
+grant bail pending appeal. First, the court
+must decide that the appeal raises
+a
+"substantial", question of
+law or
+fact.
+Second,
+"if that substantial question is determined tavorably to detendant on appeal,
+that decision is likely to result in reversal
+or an order for a new trial of all counts on
+which imprisonment has been imposed."
+Id. at 24.
+• This approach has been.
+followed
+in other cases. See United States
+• Powell
+(en banc; United States
+761 F20 1227, 1230-1234 8th Cir. 1985)
+Handy, 761
+am); United State l
+Cir.1985) (per curi-
+898: 900-90 ares
+Giancola, 754 F.2d
+900-901
+Cir. 1985); see also
+United States
+Polin,
+Nos.
+85-5009,
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-...
+
+
+
+85-5010, slip, op. at 2 (4th Cir. March 4;
+1985) (opinion
+of Murnaghan,
+Circuit
+Judge, as a single circuit judge). We adopt
+the Miller two-step analysis for determining whether to grant bail pending appeal
+under § 3143(b), but we apply a somewhat
+stricter interpretation of what constitutes a
+"substantial"
+we believe the statute and its purpose require.
+What constitutes a "substantial" question
+under the first prong of this test must be
+Conder Former S3148, bal pending appeal
+would be
+denied
+"frivolous." The new Act was intended to
+reverse the presumption in favor of bail
+pending appeal under the former law and to
+make
+standards for
+granting
+bail
+more
+stringent.
+SeeS.Rep.No. 225, 98th Cong., 1st Sess.
+26-27, reprinted in 1984 U.S.Code Cong. &
+Ad.News 3182.
+[S] Accordingly, we agree with the Eleventh Circuit that "a 'substantial question' is
+one of more substance than would be necessary to a finding that it was not frivolous. It is a 'close' question or one that very
+well could be decided the other way." Gi-
+ancola,
+_754 F.2d at 901. In Miller, the
+Third Circuit said that a "substantial" question under § 3143(b)(2)is one which 1s
+either novel, which has not been decided
+by controlling precedent, or which is fairly
+doubtful." Miller,
+753 F.2d at 23.FN12 We
+agree with the Eleventh Circuit, however,
+that a question "which has not been de-
+'ided by controlling precedent" may not be
+• 3143(b)(2). For exmay be
+without merit that it has not been found ne
+cessary for it to have been resolved....
+ilarly, there might be no precedent in this
+Page 12
+circuit, but there may also be no real reason
+to believe that this circuit would depart
+from unanimous resolution of the issue by
+other circuits."
+Giancola,
+754 F.2d at
+questions under
+3143(b)(2). Therefore, whether a particular
+question is "substantial" must be determ
+ined on a case-by-case basis, under the
+general guidelines we adopt as quoted
+above. See Giancola, 754 F.2d at 901.
+FN12. See also Handy, 761 F.2d at
+1281 ("substantial" question is one
+that is "fairly debatable").
+FNI3. Of course, a "substantial"
+question must be one which can be
+properly
+raised on appeal. See Gi-
+anola, 754 F.2d at 901 n. 4
+The second prong of the Miller test poses
+less of a definitional problem. Under this
+second prong, bail pending appeal is *953
+appropriate
+assuming
+that the
+"substantial question is determined favorably to defendant on appeal, that decision
+is likely to result in reversal or an order for
+a new trial of all counts on which imprisonment has been imposed." Miller, 753
+F.2d at 24. The Third Circuit further explained that this language
+must be read as going to the significance
+of the substantial issue to the ultimate
+lisposition of the appeal. A question ol
+law or fact may be substantial but may
+nonetheless, in the circumstances of a
+particular case,
+be considered harmless,
+to have no prejudicial effect, or to have
+›een insufficiently preserved. A cour
+may find that reversal or a new trial is
+"likely" only if it concludes that the
+question is so integral to the merits of the
+conviction on which defendant is to be
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-...
+
+
+
+mprisoned that a contrary appellate hold
+ng is likely to require reversal of the
+Id. at 23.FN14
+Page 13
+on the probability of ultimate outcome.
+Miller, 753 F.2d at 23; see also
+Polin,
+slip op. at 2 n 2; Handy
+761 F.2d at 1280; Giancola, 75
+ons:
+In the first place, such a reading
+would render language
+in the statsurplusage
+question that is likely to be bee
+must by
+definition
+"substantial". In the second place,
+we are unwilling
+to attribute to
+Congress the cynicism that would
+underlie the provision were it to
+as requiring the district
+court to determine the likelihood
+of its own error. A district judge
+who, on reflection, concludes that
+s/he erred may rectify that error
+when ruling on post-trial motions.
+not knowingly leave
+substantial errors uncorrected, or
+deliberately
+misconstrue
+able precedent.
+have been capricious of Congress
+to have conditioned bail only on
+the willingness of a trial judge to
+certify his or her own error.
+FN15 that the appeal is not for purpose of
+delay, and:
+•N15. We note that
+, unlike §
+3143(b)(1), § 3143(b)(2) does no
+require that the showing be made by
+"clear and convincing evidence.
+We therefore conclude that a deendant must only prove the
+143(b)(2) criteria under the ordin
+ary preponderance of the evidence
+standard
+[1.] that the appeal raises a substantial
+question of law or fact; and
+[2.] that if that substantial question is determined favorably to detendant on ap
+peal, that decision is likely to result in reversal or an order for a new trial of all
+counts on which imprisonment has been
+imposed.
+Id. at 24.
+IV
+Disposition
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+[6] In Affleck, both the defendant and the
+Jovernment agree that we should remanc
+the case to the district court to reconsider
+Page 14
+ant did not meet his burden of
+showing
+that his appeal raised a
+"substantial" question. Polin, slip
+op. at 3-4.
+In Handy, the Ninth Circuit adopted the Miller standard and disagreed with the district court's
+ion of law or fact, which we have re
+solved. In Kowalik, however, both the de
+fendant and the Government apparently
+agree that a remand is not appropriate.
+Kowalik argues that we should grant him
+bail pending appeal under the test he espouses, while the Government argues that
+we should deny bail under the standard it
+proposes.
+We conclude that the proper disposition is
+to remand both cases for the district court
+to make findings and conclusions under the
+standard for determining bail on appeal
+which we adopt today. The Third and Eleventh Circuits made this disposition in
+*954Miller and Giancola. Miller, 753 F.2d
+at 24; Giancola, 754
+F.2d at 901 & n.
+S.FN16 This disposition comports with
+Fed.R.App.P. 9(b). Rule 9(b) requires that
+applications for bail pending appeal be
+made
+"in the first instance in the district
+court." Id. The rule
+also requires the district court to "state in writing the reasons"
+if the court denies release pending appeal
+or imposes conditions on release.
+ld. The
+rule contemplates that the district court is
+in a better position to evaluate, in the first
+court to make written findings and conclusions.
+had met his burden of proving that
+his appeal raised a "substantial ot
+'fairly debatable' question of the
+type that calls into question the
+validity of the judgment." Handy,
+761 F.2d at 1283. The Ninth Circuit remanded to the district court
+for imposition of the appropriate
+conditions of release.
+These proceedings obviously present ditticulties for the parties, as well as for the trial and appellate courts. We are convinced
+that those difficulties will be lessened if a
+clear record at a hearing is made in the trial
+court. As noted, the detendant bears the
+burden of making the showings outlined
+above on the facts and the law, and he must
+present sufficient portions of the record to
+support the questions he raises. If this is
+not done, as to evidentiary matters we must
+give considerable deferénce to the
+trial
+court's determination on the substantiality
+of questions of fact. We can, like the trial
+court, independently consider questions of
+law.
+FETI
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-... 4/10/2008
+
+
+
+tion of the principal appeals in these cases.
+The mandates for the partial remands shall
+issue forthwith.
+MckAY, Circuit Judge, dissenting:
+Since our country's inception, liberty has
+held a preeminent place in our pantheon of
+ralues. Our founding fathers took care to
+preserve it through a wealth of carefully
+crafted constitutional safeguards. Among
+them are the eighth amendment's proscription of excessive bail, the due process
+clause, and the ex post facto clause. In my
+view, the court has trivialized each of these
+safeguards in sustaining the constitutionality of the bail pending appeal provisions of
+the Bail Reform Act of 1984, and in approving the application of these provisions
+to defendants
+who
+were convicted of
+crimes committed before the Act's passage.
+I believe that this is, in large measure, a
+consequence of the court's preoccupation
+with attempting to ameliorate the harsh effects of these provisions. Had the court
+held fast to the actual intent of Congress,
+the constitutional infirmity of the statute
+would have been readily apparent.
+When the standard for release of a conerson pending appea
+under 18
+U.S.C. § 3143 was first considered by tria
+courts and by a panel of this court, they all
+concluded that Congress did indeed mean
+what it said-bail should be denied unless
+the trial court finds:
+Page 15
+gress intended to eliminate bail pending
+appeal in all but the most extraordinary
+cases. Subsequently, the Third Circuit fabricated from rules of judicial construction
+cuits quick!
+tell in line. nited States circlian duickl
+United States
+Murnaghan, C.J., as a single circuit judge).
+In this case the majority, adopting the reasoning of both the Third and Eleventh Circuits, rewrites the statutory provision to
+read that bail may be granted by the trial
+court if:
+1. the appeal raises a substantial question
+of law or fact; and
+2. if that substantial question is determined favorably to the defendant on appeal, the decision is likely to result in reversal or an order for a new trial on all
+counts for which imprisonment has been
+imposed.
+Thus, under the majority's attempted emas-
+18 U.S.C. § 3143(b).
+hese early decisions took the statute t
+lean that for all practical purposes Con
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-...
+
+
+
+Ikely prove to be no amelioration at all. !
+ım fullv satisfied that the result will be essentially the same as it would were the statute interpreted literally-the denial of bail to
+he overwhelming majority of persons who
+previously would have received bail
+pending appeal. Such exceptions as may
+exist under the newly established standards
+will be at best quixotic. FNI
+FNI. By my calculation, sixty-three
+percent of direct appeals handled by
+this court in the most recent reporting period involved persons
+were free on bail pending appeal.
+The new
+standards will
+only
+eliminate bail in the overwhelming
+majority of those cases, but | am
+satisfied
+that
+it will be accident
+rather than design if even a substantial majority of those cases that we
+reverse coincide with the cases in
+which bail pending appeal is granted.
+More important, in sorting through the theoretical niceties of supposedly ameliorative
+standards the courts have lost sight of the
+fact that the statute both as written by Congress and as rewritten by them allows for
+the punishment of a substantial class of individuals who have not yet been tinally adjudicated guilty. I am convinced that denying bail under the test set forth in the panel's opinion is contrary to the Constitution
+of the United States.
+CONSTITUTIONAL RIGHTS ON AP-
+PEAL
+Page 16
+BEYE
+appeal as a matter of right,
+ısed in deciding appeals must compor
+with the demands ol the Due Process an
+Equal Protection clauses of the Constitution." 469 U.S. at --.., 105 S.Ct. at 834. In
+holding that a defendant has a due process
+right to effective assistance of counsel on
+appeal, the Court stated that 'in establishing a system of appeal as of right, the state
+had implicitly determined that it was unwilling to curtail drastically a defendant's
+liberty unless a second judicial decisionmaker, the appellate court, was convinced
+in accord with
+law." 469 U.S. at -.., 105 S.Ct. at 840
+The state was thus found to have "made the
+appeal the final step in the adjudication of
+guilt or innocence of the individual." FN
+ld. *956 Accordingly, in a system where :
+defendant has an appeal as of right, his
+guilt or innocence is not finally determined
+until the conclusion of his appeal. Under
+this rationale, all rights that apply to protect a defendant at the trial stage also apply
+at the appellate level, provided the appeal
+is a matter of right.
+FN2. Justice Rehnquist, writing
+dissent, vehemently objected to this
+characterization
+as
+*inconsistent
+with the general view of state anne
+late review expressed ... in
+102443 s4pra, ar 610-11 L, 94 S.0l
+Mogir 4t a Dss. Co0, 94 Set.
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+As the Supreme Court has stated,
+"[p]resent federal law has made an appeal
+from a district court's judgment of conviction in a criminal case what is, in effect, a
+matter of right."
+Coppedge v.
+United
+States, 369 U.S. 438,
+441,82 S.Ct. 917,
+Pea cut fare bacon, made i ap.
+peal "the final step in the adjudication of
+guilt or innocence
+and, under Evitts,
+full panoply of constitutional rights applies
+until the conclusion of the appeal
+Page 17
+ally been allowed in all capital
+cases, but this exception falls within
+most defendants facing a possible
+death penalty would likely flee re-
+THE EIGHTH AMENDMENT
+The traditional purpose of bail has been to
+ensure the presence of the detendant at trial. Higher bail than that amount reasonably
+calculated
+"excessive"
+the eighth
+amendment. Stack Boyle, 342 U.S. I, 5,
+72 S.Ct. 1, 3, 96 L.Ed. I (1951). It remains
+an open question, however, whether the
+eighth amendment provides a right to bail
+in cases where the defendant
+not likely
+to flee. Compare Escandar
+441 F.Supp. 53, 58 (S.D.Fla. 1977) (finding
+that likelihood of flight is the only constial of bail) with United States
+all of bail) with United States on Edwards,
+430
+A.2d 1321
+(D.C.App.1981)
+denied, 455 U.S. 1022, 102
+S.Ct. 1721, 7.
+L.Ed.2d 141 (1982) (upholding the denial
+of bail for the purpose of protecting the
+ficiently high.")
+- would resolve the question leit open in
+Wolfish by finding that prevention of flight
+is the only constitutionally permissible justification for the denial of bail. In my view,
+to say that the eighth amendment does not
+prevent Congress from defining classes of
+cases in which bail shall not be allowed but
+only provides that ball Shall not be excessive in those cases where it is allowed *is a
+classic case of the cart pulling the horse
+since the Congress could abrogate the right
+to ball altogether,
+making
+amendment absolutely
+meaningless."
+wards, 430 A.2d at 1365
+Mack, J., dis
+senting). See also Carlson | Landon, 34.
+U.S. 524, 556, 72 S.Ct. 525, 542, 96 L.Ed
+547 (1951) (Black, J., dissenting): Regardless of whether the English provision that
+provided the basis for the eighth amendnarrowly structured,
+the Bill of Rights "was written and adopted
+to guarantee Americans greater freedom
+than had been enjoyed by their ancestors
+542, 96 L.Ed. 547reh. denied,343 U.S. 988,
+72 S.Ct. 1069, 96 L.Ed. 1375 (1952)). See
+also Foote,
+The Coming Constitutional
+Crisis in Bail, 113 U.Pa.L.Rev. 959, 1125
+FN3. The denial of bail has historic-
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+FN4. See Duker, The Right to Bail:
+Historical
+Alb.L.Rev.
+58-66
+Inquiry (1977)
+(finding that the English provision
+did not limit Parliament's ability to
+define offenses as nonbailable).
+Although there have been hints to the contrary in recent Supreme Court opinions, see
+at 545-46, 72 S.Ct
+(1984), it would be a travesty if we glibly
+abandoned the
+oservations of the suprem
+Court in Stack Boyle, 342 U.S. 1, 4, 7.
+S.Ct. 1, 3, 96 L.Ed. 1 (1951):
+From the passage of the Judiciary Act of
+1789, 1 Stat. 73, 91, to the present Federal Rules of Criminal Procedure,
+Rule
+46(a)(1), federal law has unequivocally
+provided that a person arrested for a noncapital offense shall be admitted to bail.
+This traditional right to freedom before
+conviction permits the unhampered preparation of a defense, and serves to prerent the infliction of punirment prior to
+conviction. See Hudson
+Parker, 156
+U.S. 277,
+285, 15 S.Ct.
+450,
+453,
+39
+L.Ed. 424 (1895). Unless this right to bail
+before trial is preserved, the presumption of innocence, secured only after centuries of struggle, would lose its mean- ing.
+Thus, in my view, the Bail Reform Act violates the eighth amendment by allowing
+the denial of bail on grounds unrelated to
+the defendant's likelihood of flight.
+Even if Congress is free to define nonbail-
+Page 18
+at the very least obligates judges passing
+upon the right to bail to deny such relie
+nly for the strongest of reasons." Seller:
+United States,
+... U.S. ...., 89 S.Ct. 36,
+Circuit Justice 1978); Harris
+L.Ed.2d 25
+(1971) Douglas,
+Justice 1971). At a minimum, the eighth
+amendment
+prohibit
+unreasonable
+denial of bail. Carlson, 342 U.S. at 569, 72
+states may reasonably legislate as to the
+right to bail for certain offenses provided
+the power is exercised rationally, reasonably, and without discrimination.") Surely
+we cannot condone the position that bail
+may be denied for the primary purpose of
+punishing a detendant prior to the tinal determination of his guilt, as defined in Evitts.
+The government has a compelling interest
+in safeguarding the integrity of the judicial
+system. Denial of bail on the ground that
+the defendant is likely to flee furthers this
+interest by ensuring the defendant's presence at trial. Certainly, from the perspective of the individual denied bail on this
+ground, the bars are just as cold and the
+cell is just as bleak as if he were being punished. Whatever penal aspects are attendant
+This justification is, however, inapplicable
+in the cases before us, since the district
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-... 4/10/2008
+
+
+
+Page 19
+court found on a sufficient record that bail
+would ensure the presence of the defendto the co thaunity heguiring immediate isol
+ation. Thus, the only possible purpose for
+detaining them before the guilt determination is complete,
+as defined by Evitts,
+unitive. While this conclusion is not diffi
+cult to divine from the face of the statute,
+Congress has made our analytic task even
+easier by explicitly stating the intent of the
+tatutory provisions governing bail pending
+appeal to be punitive. The legislative his
+tory accompanying the Act indicates that
+Congress believed swifter punishment is a
+greater
+deterrent
+criminal
+conduct:
+"release of a criminal defendant into the
+community after conviction may undermine the deterrent effect of the criminal
+law, especially in those situations where
+the appeal of the conviction may
+drag on
+for many months or even years." Senate
+Report No. 98-225 at 26, 98th Cong., 2d
+(1984), U.S.Code
+min.News 1984,
+No. 98-147 at 562 3209; Senate Report
+2, 98th Cong., 1st Sess.
+(1983); Senate Report No. 97-317 at 15-56,
+97th Cong., 2d Sess. (1982). As the court
+noted in its memorandum*958 opinion and
+order in United States
+Cirrincione, 600
+F.Supp. 1436, 1443 (N.D.III.1985):
+By viewing the restrictions on release
+pending appeal to be a deterrent to crime,
+Congress must have concluded that a sentence that commences immediately upon
+conviction is somehow more severe than
+substantial likelihood that persons will
+retrial will not necessarily result in convic-
+N5. Annual Report of the Directo
+of the Administrative Office of th
+United States Courts, Table B-l, p.
+228 (1984).
+Denial of bail for the primary purpose of
+and therefore a violation or the cle
+amendment. Accordingly, I can only conclude that, because under the statute as
+written by Congress and as rewritten by
+our court and others the denial of postthe stion is inconstation under act.
+under the
+eighth amendment. In addition, the punitive nature of the statute leads me to conclude that the statute also violates the due
+process clause and the ex post facto clause.
+THE DUE PROCESS CLAUSE
+The liberty protected by the fifth amend-
+-includes freedom from punishment.
+Bell | Wolfish, 441 U.S. 520, 535 n. 17, 99
+S.Ct. 1861, 1871, n. 17, 60 L.Ed.2d 447
+(1978). Thus, under the due process clause,
+a person may not be punished prior to an
+adjudication of guilt in accordance with
+535, 99 S.Ct. at 1871. Since a defendant is
+Indeed, in the approximately ten percent of
+all criminal cases in which the appellate
+courts reverse convictions rns there is a
+The Supreme Court "has recognized a distinction between punitive
+measures that
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-...
+
+
+
+may not constitutionally be imposed prior
+19, 15 ct in Thus in mung)
+537, 99 S.Ct. at
+the denial of bail,
+"the court must decide
+whether the disability is imposed for the
+purpose of punishment or whether it is but
+1S9. As ease, the legine story
+makes clear that the statutory restrictions
+on bail pending appeal were
+the purpose of punishment." Wolfish, 441
+U.S. at 538, 99 S.Ct. at 1873. The statute
+thus violates the due process clause by imposing punishment prior to a final adjudication of guilt
+The infirmity of the new statute has another dimension under the due process clause
+as well-one which stems from the critically
+overburdened state of our docket. In my
+view, the risk of erroneous deprivation of
+liberty under the new provisions will be
+gre substance or ere legal sues raised in
+the petitions for bail pending appeal will
+receive only slight consideration.
+While I have been unable to make a precise
+calculation, such figures as are available
+suggest that approximately sixty-three percent of all direct criminal appeals to this
+circuit involve persons who
+have been
+granted bail pending appeal. Because of the
+Bail Reform Act, we have pending a large
+number of petitions to this court to grant
+bail pending appeal after denial by the trial
+It is quite possible that we would
+have little difficulty continuing to work in
+to our calendar an examination of cases
+Page 20
+Appellate Procedure seriously,
+*959 just added a mini-appeal in a large
+percentage of direct criminal appeals to our
+unmanageable
+docket.
+majority admits that "[i]n the final analysis, we cannot define blanket categories for
+what will constitute
+"substantial'
+questions
+under § 3143(b)(2)." Op. at p. 952. The
+court's self-injunction that such issues must
+be determined on a "case-by-case basis" is
+the administrative equivalent of handing a
+rock to a drowning man. Even in the cases
+in which we ultimately determine that the
+question is not "substantial," the effort required to give conscientious judicial scrutiny to the determination of that issue will
+be substantial.
+Notwithstanding the fact that the trial court
+makes the initial determination, the substantiality of an issue of law is one that this
+court must determine and no presumption
+can properly be given to the trial court's
+predetermination of that issue. Once a
+question is found to be substantial, the
+court must also make a determination tantamount to a harmless error determination.
+At this point the mini-appeal is no longer a
+mini-appeal. We have a duty to find harmlessness only in light of the entire record
+One need say no more in order to suggest
+the damage we have done to our dockets,
+and the risk that in our overburdened state
+the bail decisions will not be adequately reviewed. In addition, the process impinges
+on the fundamental fairness of the review
+of the merits of each criminal appeal, for
+1-14
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+
+of the human mind.
+EX POST FACTO
+The ex post facto clause was adopted, in
+part, to protect an individual's right to fair
+notice ene beyond over was
+what was prescribed
+crime was
+consummated."
+Weaver Graham, Graham, U,S. U,S.24, 30, 101
+S.Ct. 960,
+, 965, 67 L.Ed.2d 17 (1981). In
+Weaver the Court noted that two elements
+must be present for a criminal law to be
+Celd ex before it enactent into a c
+its enactment into law, and
+it must function to the disadvantage of the
+offender affected by it. The Supreme Court
+however, that a
+has ly parcel ral change in the lay is i
+ex post facto, even if a defendant is disag
+vantaged thereby.
+See, e.g..
+Florida, 432 U.S. 282, 97 S.Ct. 2290, 5:
+L.Ed.2d 344 (1977), reh. denied,434 U.S.
+882, 98 s.Ct. 246, 54 L.Ed.2d 166 (1977);
+U.S. 574, 4 S.Ct. 202, 28 L.Ed. 262 (1884).
+however, the Court has
+noted that a procedural change may so atfect substantial rights as to fall within th
+Page 21
+The mark of an ex post facto law is the
+imposition of What can tairly be designated as punishment for past acts. The
+question in each case where unpleasant
+consequences are brought to bear upon an
+individual for prior conduct, is whether
+the legislative aim was to punish that individual for past activity, or whether the
+restriction comes about as a relevant incident to a regulation of a present situation....
+As the court found in Cirrincione, "the
+post-conviction bail restrictions are not un-
+(1898). I
+need not
+linger long over the
+tons between those procedural changes
+that do affect substantial rights and those
+*960 impose on defendants what Congress
+viewed as the harsher punishment of a sentence that must be served immediately
+rather than after the conclusion of the appeal. Indeed, for those defendants whose
+convictions are reversed and who
+thereafter reconvicted, the statute imposes
+the punishment of imprisonment on those
+who would not otherwise be forced to bear
+it. To fall into the "procedure" versus
+"substance" trap
+is intolerable under the
+circumstances and trivializes the seriousness of incarceration. Because the proviare principally and
+fundamentally
+penal, they are irreconcilable with the notion that a person may be punished only to
+the extent that the law allowed at the time
+he committed the crime.
+PRE-TRIAL DETENTION
+80 S.Ct.
+1154,
+L.Ed.2d 1109, ren. denied, 364 U.S. 856, 84
+S.Ct. 30, 5 L.Ed.2d 80 (1960):
+he trivialization of premature incarceration
+if convicted persons prior to appeal a
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+merely procedural will result in the same
+trivialization of premature incarceration of
+accused persons prior to trial. I hold with
+lustice Jackson who, sitting as a circun
+justice, said:
+It is difficult to reconcile with traditional
+american law the jailing of persons by
+he courts because of anticipated but as
+yet uncommitted crimes.
+to protect society from predicted but unconsummated offenses is so unprecedented in this country and so fraught with
+danger of excesses that I am loath to resort to it, even as a discretionary judicial
+technique....
+Williams | United States, 184 F.2d 280,
+282-83 (2đ Cir.1950). Professor Tribe has
+noted that this approach bears a striking
+similarity to the exchange in Lewis Carroll's Through the Looking Glass:
+The Queen observes that the King's Messenger is "in prison now, being punished;
+and the trial doesn't even begin till next
+Wednesday;
+of course the crime
+comes last of all." Perplexed, Alice asks,
+"Suppose he never commits the crime?"
+"That will be all the better, wouldn't it?"
+the Queen replies.
+Tribe, An Ounce of Detention: Preventive
+Justice in. 571. 34 (5 0) g Mied il 56-
+wards, 430 A.2d at 1368 (Mack, J., dissenting)).
+What one thinks of the role of the eighth
+amendment and the due process clause in
+restraining unjustified detention prior to
+trial or pending appeal undoubtedly deends on one's experience. From our priv
+eged position it would be quite normal fo
+us to assume that the spectre of unjustified
+detention looms only in such countries as
+Poland or South Africa. Perhaps we would
+Page 22
+214, 65 S.Ct. 193, 89 L.Ed. 194 (1944)
+'eh. denied,324 U.S. 885, 65 S.Ct. 674, 8º
+cial and economic disparity in the execution of accused persons).
+Crime is indeed one of the most serious of
+the problems that threaten our society, and
+the goal of enhancing the security of our
+citizenry is an important one. We should
+not seek to achieve it through the circumvention
+of
+constitutional
+however. To fall
+into
+sardards,
+versus "substance" trap is intolerable when
+human liberty hangs in the balance. To
+punish an individual before he has been finally adjudicated guilty or to retroactively
+enhance the punishment tor a crime Is
+verversion oi our svstem or lustice. In tne
+end it will not bring either credit or *961
+enhanced effectiveness to the criminal
+justice system.
+I would grant both petitions to admit to bail
+Righ is the soe conce ain thal mad of
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-. 4/10/2008
+
+
+
+given to a bail decision pending appeal. I
+believe that circumstances could justity a
+denial of bail where the defendant has been
+convicted of a violent crime and has otherwise indicated that he is a danger to the
+community. Nonetheless, I fear that the
+language of the statute is sufficiently vague
+to encompass far more situations than I
+would consider constitutional. That is not
+the case here, however, and the proper contours of "likely to ... pose a danger to the
+safety of any
+other person or
+the community,"18 U.S.C. § 3143(b)(1), must be
+left to the appropriate cases.
+Second, it is unfortunate that Congress has
+chosen to limit bail pending appeal as a reaction to the sad state of the circuit court
+dockets. In 1979, there were 1194 appeals
+filed in the Tenth Circuit; in 1984, there
+were 1922. Administrative Office of the
+United States Courts, Federal Court Management Statistics 11 (1984). The average
+time it is currently taking this circuit to
+handle a criminal appeal from the date of
+the notice to oral argument is 368 days.
+In a bail opinion in 1956, Justice Frankfurter addressed the growing length of time
+of criminal appeals:
+"Nothing has disturbed me more during
+my years on the Court than the time span,
+in so many cases that come here, between
+the date of an indictment and the final appellate disposition of a conviction. Such
+untoward delays seem to me inimical to
+the fair and effective administration of
+criminal
+whatever why we in this country cannot
+be as expeditious in dealing with criminal
+appeals as is true of England. Applications for appeals are heard in the English
+Court of Criminal Appeal within eight
+weeks of conviction; in murder cases appeals "are generally before the Court not
+Page 23
+later than three weeks after the conviction.'"
+Ward United States, Fa2d 2
+76
+163, 1066, 1 L.Ed.2d 25 (1956).
+When Justice Frankfurter expressed these
+concerns, the case before him had been
+pending on appeal for tour months and he
+expected that it would not be heard on the
+merits for another two months. Given this
+time frame, which he viewed as far too
+•The Government should, I believe,, be
+me he responsity or sting tel
+sound reasons for postponing such a
+hearing. I am not able to understand why
+it should not become the settled practice
+for the Government to move, after an aphealing of the appeal on the stongra tie
+minutes at the earliest possible moment
+that a Court of Appeals can accommodate
+its calendar to the disposition of business
+that has first call, namely, a criminal appeal. This is especially desirable in a case
+where bail has been denied."
+Id. 76 S.Ct. at 1067.
+I agree with Justice Frankfurter. I believe
+that Congress should have addressed its
+concern for the length of the appeal process
+by enacting some form of speedy appeals
+act rather than limiting bail. Judge McKay
+correctly envisions that the circuits soon
+presented. For this reason, I urge this court
+to expedite all criminal appeals where bail
+has been denied, to deny extensions of time
+to court reporters and brief writers, and to
+hear oral argument on the merits within 90
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-..
+
+
+
+65 F.2d 944. 53 USLW 262
+Cite as: 765 F.2d 944
+Page 24
+ult in reversal, it can immediately order
+that bail be set pending the final decision
+on appeal. In this manner, the court can
+ameliorate the deprivation of liberty inrolved where bail has been denied to a defendant whose conviction is thereafter
+overturned on appeal.
+..A.L0,198.
+. Affleck
+765 F.2d 944, 53 USLW 2628
+https://web2.westlaw.com/print/printstream.aspx?utid=%7bFEDF5709-3AEA-4F74-8619-.. 4/10/2008
+
+
+SOUTHERN DISTRICT OF FLORIDA
+Case No:
+D
+18 U.S.C. § 371
+18 U.S.C. § 1591(a)(1)
+18 U.S.C. § 1591(a)(2)
+18 U.S.C. § 2422(b)
+18 U.S.C. § 2423(e)
+18 U.S.C. § 2423(d)
+18 U.S.C. § 2423(b)
+UNITED STATES OF AMERICA
+VS.
+R
+JEFFREY EPSTEIN,
+, a/k/a "
+Defendants.
+A
+INDICTMENT
+The Grand Jury charges that:
+BACKGROUND
+At all times relevant to this Indictment:
+1. Defendant JEFFREY EPSTEIN employed defendants
+a/k/a"
+" and
+among other things, services as personal assistants.
+to perform,
+1 06 25
+
+
+2.
+Defendant JEFFREY EPSTEIN employed
+to perform, among other
+things, services as a personal assistant.
+3.
+Defendants JEFFREY EPSTEIN and
+•. to perform, among other things, recruiting services.
+paid
+• and
+Defendant JEFFREY EPSTEIN owned a property located at 358 El Brillo Way,
+Palm Beach, Florida, in the Southern District of Florida (hereinafter referred to as "358 El
+Brillo Way").
+Defendant JEFFREY EPSTEIN owned a property located at 9 East 71st Street,
+New York, New York (hereinafter referred to as "the New York residence").
+Defendant JEFFREY EPSTEIN was the principal owner of JEGE, INC., a
+Delaware corporation. JEGE, INC.'s sole business activities related to the operation and
+ownership of a Boeing 727-31 aircraft bearing tail number N908JE.
+7.
+Defendant JEFFREY EPSTEIN served as president, sole director, and sole
+shareholder of JEGE, INC., and had the power to direct all of its operations.
+Defendant JEFFREY EPSTEIN was the principal owner of Hyperion Air, Inc.,
+a Delaware corporation. Hyperion Air, Inc.'s sole business activities related to the operation
+and ownership of a Gulfstream G-1159B airctaft bearing tail number N909JE.
+9.
+Defendant JEFFREY EPSTEIN served as president, sole director, and sole
+shareholder of Hyperion Air, Inc., and had the power to direct all of its operations.
+2
+
+
+10.
+Pursuant to Florida Statutes Section 794.05, a "person 24 years of age or older
+who engages in sexual activity with a person 16 or 17 years of age commits a felony of the
+second degree." For purposes of "this section, 'sexual activity' means oral, anal, or vaginal
+penetration by, or union with, the sexual organ of another; however, sexual activity does not
+include an act done for a bona fide medical purpose." Florida Statutes Section 794.021 states
+that "ignorance of the age [of the victim] is no defense," and that neither "misrepresentation
+of age by [the victim] nor a bona fide belief that such person is over the specified age [shall]
+be a defense."
+R
+11.
+Pursuant to Florida Statutes Sections 800.04(5)(a) and 800.04(5)(c)(2), an adult
+"who intentionally touches in a lewd or lascivious manner the breasts, genitals, genital area,
+or buttocks, or the clothing covering them, of a person less than 16 years of age, or forces or
+entices a person under 16 years of age to so touch the perpetrator, commits lewd or lascivious
+molestation," which is a felony of the second degree if the victim is 12 years of age or older
+but less than 16 years of age.
+12.
+Pursuant to Florida Statutes Sections 800.04(6)(a) and 800.04(6)(b), an adult
+'"who ilntentionally touches a person under 16 years of age in a lewd or lascivious manner
+or [s]olicits a person under 16 years of age to commit a lewd or lascivious act commits lewd
+or lascivious conduct," which is a felony of the second degree.
+3
+
+
+13.
+Pursuant to Florida Statutes Sections 800.04(7)(a) and 800.04(7)(c), an adult
+"who: (1) [i]ntentionally masturbates; (2) [i]ntentionally exposes the genitals in a lewd or
+lascivious manner; or (3) [i]ntentionally commits any other sexual act that does not involve
+actual physical or sexual contact with the victim, including, but not limited to ... the
+simulation of any act involving sexual activity in the presence of a victim who is less than
+16 years of age, commits lewd or lascivious exhibition," which is a felony of the second
+degree.
+14.
+Pursuant to Florida Statutes Section 800.04(2), "[n]either the victim's lack of
+chastity nor the victim's consent is a defense to the crimes proscribed by [Section 800.04]."
+15. Pursuant to Florida Statutes Section 800.04(3), "[t]he perpetrator's ignorance
+of the victim's age, the victim's misrepresentation of his or her age, or the perpetrator's bona
+fide belief of the victim's age cannot/be raised as a defense in a prosecution under [Section
+800.041"
+16. Pursuant to Florida Statutes Section 800.02, a "person who commits any
+unnatural and lascivious act with another person commits a misdemeanor of the second
+degree."
+17.
+Defendant JEFFREY EPSTEIN was over the age of 24 and did not have any
+medical license.
+4
+
+
+18.
+During the period of her involvement with the Defendants,
+attended Wellington High School and Palm Beach Central High School in Palm Beach
+County.
+19. During the period of her involvement with the Defendants,
+attended Wellington High School in Palm Beach County.
+20. During the period of their involvement with the Defendants, .
+and 12 attended Palm Beach Central High School in Palm Beach County.
+21. During the period of her involvement with the Defendants,
+attended William T. Dwyer High School in Palm Beach County.
+22. During the periods of their involvement with the Defendants,
+14, 15, 16, 17, 18, and 19 attended
+in
+23. During the period of Her involvement with the Defendants,
+attended 1
+24. During the period of her involvement with the Defendants,
+attended the
+25.
+F
+During the period of her involvement with the Defendants,
+attended
+5
+
+
+COUNT 1
+(Conspiracy: 18 U.S.C. § 371)
+26. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by
+reference as though fully set forth herein.
+From at least as early as 2001, the exact date being unknown to the Grand Jury,
+through in or around October 2005, in Palm Beach County, in the Southern District of
+Florida, and elsewhere, the Defendants,
+JEFFREY EPSTEIN,
+1, a/k/a "
+did knowingly and willfully combine, conspire, confederate and agree with each other and
+with others known and unknown to commit an offense against the United States, that is, to
+use a facility or means of interstate of foreign commerce to knowingly persuade, induce, and
+entice individuals who had not attained the age of 18 years to engage in prostitution, in
+violation of Title 18, United States Code, Section 2422(b).
+28.
+Purpose and Object of the Conspiracy
+It was the purpose and object of the conspiracy to procure females under the
+age of 18 to travel to 358 El Brillo Way and the New York residence so that JEFFREY
+EPSTEIN could, in exchange for money, engage in lewd conduct with those minor females
+in order to satisfy JEFFREY EPSTEIN's prurient interests.
+6
+
+
+Manner and Means
+29.
+The manner and means by which the Defendants and other participants sought
+to accomplish the purpose and object of the conspiracy included the following:
+It was part of the conspiracy that Defendants
+a/k/a "
+and other
+participants would contact minor females via the use of cellular and other telephones to
+arrange appointments for minor females to travel to 358 El Brillo Way and the New York
+residence to allow Defendant JEFFREY EPSTEIN to engage in lewd conduct with them.
+(b)
+It was further a part of the conspiracy that Defendants JEFFREY
+EPSTEIN,
+, and
+_,alk/a"l
+, and other participants would make payments to, or cause payments to be
+made to, minor females in exchange for engaging in lewd conduct.
+(c)
+It was further a part of the conspiracy that Defendants JEFFREY
+EPSTEIN,
+a/k/a"
+" and other
+participants would ask females to recruit other minor females to engage in lewd conduct with
+Defendant JEFFREY EPSTEIN.
+(d)
+EPSTEIN,
+It was further a part of the conspiracy that Defendants JEFFREY
+a/k/a"
+' and other
+participants would make payments to, or cause payments to be made to, the recruiters for
+
+
+bringing additional minor females to 358 El Brillo Way and the New York residence to
+engage in lewd conduct with Defendant JEFFREY EPSTEIN.
+(e)
+It was further a part of the conspiracy that Defendant JEFFREY
+EPSTEIN would pay minor females to engage in lewd conduct with Defendant
+to satisfy Defendant JEFFREY EPSTEIN's prurient interests.
+Overt Acts
+30.
+In furtherance of this conspiracy and to effect the objects thereof, there was
+committed by at least one of the co-conspirators herein, at least one of the following overt
+acts, among others, in the Southern District of Florida, and elsewhere:
+(1) In or around the beginning of 2001, Defendant JEFFREY EPSTEIN
+engaged in sexual activity with,
+who was then a seventeen-year-old girl,
+in the presence of
+who was then a fourteen-year-old girl.
+(2) In or around 2001, Defendant
+led
+From the
+kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358
+El Brillo Way.
+(3)
+In or around 2001, Defendant JEFFREY EPSTEIN masturbated in the
+presence of
+who was then a fourteen-year-old girl.
+(4)
+In or around 2001, Defendant JEFFREY EPSTEIN asked
+who was then fourteen years' old, to pinch his nipples while he masturbated.
+8
+
+
+(5)
+In or around 2001, Defendant JEFFREY EPSTEIN made a payment of
+$300 to
+(6)
+In or around 2001, Defendant
+placed a telephone call
+to a telephone used by
+to make an appointment for
+to travel
+to 358 El Brillo Way.
+(7)
+In or around 2001, JEFFREY EPSTEIN engaged in sexual intercourse
+with an unidentified female in the presence of
+who was then a fourteenyear-old girl. R
+(8)
+In or around 2001, Defendant JEFFREY EPSTEIN paid $300 to Jane
+who was then a fourteen-year-old girl, for allowing an unidentified female
+to perform oral sex on
+in EPSTEIN's presence.
+(9)
+On or about March 11, 2003, an employee of Defendant JEFFREY
+EPSTEIN prepared a written telephone message for Defendant JEFFREY EPSTEIN's
+review regarding a telephone call received from
+(10) In or around 2003, Defendant JEFFREY EPSTEIN asked
+if she had any younger friends who would be interested in engaging in similar
+activities with him.
+(11) In oraround 2003, Defendant
+took nude photographs
+of
+9
+
+
+(12) In or around 2003, Defendant
+$500 to
+in exchange for posing for nude photographs.
+(13) In or around 2003, Defendant
+Defendant JEFFREY EPSTEIN had asked
+made a payment of
+told
+that
+to take nude photographs of
+(14) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the
+presence of
+(15) In or around 2003, Defendant JEFFREY EPSTEIN made a payment of
+$200 to
+(16) In or around 2003, Defendant
+placed a telephone call
+to a telephone used by
+to make an appointment for
+to travel
+to 358 El Brillo Way.
+A
+(17) On or about April 23, 2004, Defendant
+(18) On or about May 2, 2004, Defendant
+telephone cal to a telephone used by a a
+(19) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the
+presence o
+who was then a fifteen-year-old girl.
+10
+
+
+(20) In or around 2003, Defendant JEFFREY EPSTEIN made a payment of
+$200 to
+(21) On or about October 26, 2004, Defendant
+telephone call to a telephone used byl
+(22) On rabour October 30,204, Defendant a
+(23) In or around 2004, Defendant JEFFREY EPSTEIN directed
+• who was thena sixteen- or seventeen-year-old girl, to straddle an adult female and
+to touch the adult female's breasts.
+(24) In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging
+device on the vagina of an adult female in the presence of
+who was then
+a sixteen- or seventeen-year-old girl.
+(25)
+In or around 2004, Defendant JEFFREY EPSTEIN made a payment of
+$200 to
+(26)
+In or around 2004, Defendant JEFFREY EPSTEIN instructer
+to rub his nipples.
+F
+(27) In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging
+device on the vagina of .
+who was then a sixteen- or seventeen-year-old
+girl.
+11
+
+
+(28) In or around 2004, Defendant JEFFREY EPSTEIN asked
+to recruit additional females to come to 358 El Brillo Way.
+(29) On or about November 8, 2004, one of Defendant JEFFREY
+EPSTEIN's employees prepared a written telephone message for Defendant
+JEFFREY EPSTEIN's review regarding a telephone call received from
+that read: "I have a female for him."
+(30) On or about January 14, 2005, Defendant
+(31) On or about January 29, 2005, one of Defendant JEFFREY EPSTEIN's
+employees prepared a written telephone message for Defendant JEFFREY
+EPSTEIN's review regarding a telephone call received from
+that read:
+"I have a female for him."
+A
+(32) In or around the first half of 2004, Defendant
+led
+to Defendant JEFFREY EPSTEIN's bedroom at 358 El
+Brillo Way.
+asked
+(33) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+responded with her true age.
+
+
+(34) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+masturbated in the presence of
+who was then a seventeen-year-old-girl,
+and.
+D
+(35) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+instructed
+who was then a seventeen-year-old girl, to play with his
+nipples.
+(36) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+instructed
+who was then a seventeen-year-old girl, to remove her
+clothing.
+(37) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+stroked the vagina of
+ho was then a seventeen-year-old girl.
+(38) In or around the first half of 2004, Defendant JEFFREY EPSTEIN paid
+$200 to
+(39) In oraround the first half of 2004, Defendant JEFFREY EPSTEIN paid
+$200 to
+asked
+instructed
+(40) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+what high school she attended.
+(41)
+In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+could massage him alone.
+13
+
+
+(42) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+masturbated in the presence of!
+(43) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+digitally penetrated
+(44) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+placed a large vibrating massager on the vagina of'
+who was then a
+sixteen-year-old girl.
+(45)
+In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+caused a payment of $200 to be paid tol
+(46) In or around July 2004, Defendant JEFFREY EPSTEIN led |
+., who
+was then a fifteen-year-old girl, and
+who was then a sixteen-years-old
+girl, from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY
+EPSTEIN's bedroom at 358 El Brillo Way.
+(47) On or about July 4, 2004, Defendant
+more telephone calls to a telephone used by
+made one or
+(48)
+On or about July 5, 2004, Defendant
+14
+
+
+(49)
+In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in
+the presence of
+(50) In or around July 2004, Defendant JEFFREY EPSTEIN stroked the
+vagina of l
+(51) In or around July 2004, Defendant JEFFREY EPSTEIN paid
+approximately $200 tol
+(52) In or around July 2004, Defendant JEFFREY EPSTEIN paid $200 to
+. for recruiting
+to travel to 358 El Brillo Way.
+(53)
+In or around July 2004, Defendant
+told
+that Defendant JEFFREY EPSTEIN would pay
+f she returned with a
+friend.
+(54)
+On or about July 5, 2004, Defendant
+more telephone calls to a telephone used by
+placed one or
+(55)
+On or about July 15, 2004, Defendant
+telephone call to a telephone used by |
+(56) On or about July 15, 2004, Defendant
+(57)
+On or about July 16, 2004, Defendant
+placed one or
+more telephone calls to a telephone used byl
+15
+
+
+(58) On or about July 16, 2004, Defendant
+(59) On or about July 17, 2004, one of Defendant JEFFREY EPSTEIN's
+employees prepared a written telephone message for Defendant JEFFREY
+EPSTEIN's review regarding a telephone call received from
+. that read: "Me&
+can come tomorrow any time or [
+•] alone".
+(60) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in
+the presence of
+(61)
+In or around July 2004, Defendant JEFFREY EPSTEIN instructed
+who was then a sixteen-year-old girl, to rub his nipples.
+(62) In or around July 2004, Defendant JEFFREY EPSTEIN stroked the
+vagina of
+(63) In or around July 2004, Defendant JEFFREY EPSTEIN made a
+payment of $200 to
+(64) In or around July 2004, Defendant JEFFREY EPSTEIN told sane.
+hat if she reported to anyone what had occurred at Defendant JEFFREY
+EPSTEIN's home, bad things could happen to her.
+(65) On or about July 24, 2004, Defendant
+placed totelephone call to a telephone used by
+16
+
+
+(66) On or about July 15, 2004, Defendant
+I placed one or
+more telephone calls to a telephone used by
+D (67) On or about July 16, 2004, Defendant
+o make one or more telephone calls to a telephone used byl
+caused
+(68) On or about July 17, 2004, Defendant
+telephone call to a telephone used byl
+(69)
+On or about July 18, 2004, Defendant
+(70) On or about July 22, 2004, Defendant
+(71) In or around July 2004, Defendant JEFFREY EPSTEIN fondled the
+breasts of
+(72) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in
+the presence of
+(73) In or around July 2004, Defendant JEFFREY EPSTEIN made a
+payment of $200 to
+(74) On or about July 22, 2004, Defendant
+telephone call to a telephone used byl
+17
+
+
+(75) In oraround the last half of 2004, Defendants JEFFREY EPSTEIN and
+engaged in oral sex and sexual intercourse in the presence
+of
+D
+(76)
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN
+forcibly inserted his penis into the vagina of
+who was then a seventeenyear-old girl.
+(77) In oraround the last half of 2004, Defendant JEFFREY EPSTEIN made
+a payment of $300 to
+(78) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
+rubbed the vagina of
+(79) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made
+a payment of $200 to
+(80) On or about November 28, 2004, Defendant JEFFREY EPSTEIN
+arranged for one of his employees to provide an envelope filled with cash to
+(81) On orabout December 4, 2004, Defendant
+a written message to Defendant JEFFREY EPSTEIN regardingl
+stating:
+would like to work @ 4:00 pm if possible.
+is scheduled for 5:00 today.] the movie is @ 7:30".
+(82) On or about December 29, 2004, Defendant
+a telephone call to a telephone used by
+18
+provided
+placed
+
+
+(83) On or about December 30, 2004, Defendants JEFFREY EPSTEIN and
+caused the purchase of Broadway tickets as an eighteenth birthday
+gift for
+D (84)
+EPSTEIN masturbated in the presence of
+In or around the last half of 2004 or January 2005, Defendant JEFFREY
+who was then a seventeenyear-old girl.
+(85) In oraround the last half of 2004 or January 2005, Defendant JEFFREY
+EPSTEIN fondled the breasts of
+who was then a seventeen-year-old
+girl.
+(86) On orabout January 14, 2005, Defendant SARAH KELLEN placed one
+or more telephone calls to a telephone used by
+(87) On or about January 27, 2005, Defendant
+=
+" placed one or more telephone calls to a telephone used by
+(88) On orabout January 28, 2005, Defendant
+placed one
+or more telephone calls to a telephone used byl
+(89)
+On or about February 1, 2005, Defendant
+placed one or more telephone calls to a telephone used by
+(90) In or around February 2005, Defendant JEFFREY EPSTEIN caused a
+payment of $200 to be made to
+for recruitingr
+o travel to
+358 El Brillo Way.
+19
+
+
+(91) In or around 2004, Defendant JEFFREY EPSTEIN told
+that he would pay her to find and bring him more girls.
+D In or around around Defendant JEFFREY EPSTEIN paid paid 10 10l
+for recruiting a minor female to travel to his New York home.
+(93) In oraround 2004, Defendant JEFFREY EPSTEIN asked
+when she would be getting more girls.
+(94)
+On or about April 5, 2005, one of Defendant JEFFREY EPSTEIN's
+employees prepared a written message for Defendant JEFFREY EPSTEIN's review
+regarding a telephone call received from
+that read: "Re does she have
+any new friends you can meet - I was away over the weekend so I have not spoken
+to anyone new. But, [unidentified Jane Doe] will be around later today and I know
+she really wants to work. The others should be back around Thursday. Let me know
+about [unidentified Jane Doe]."
+(95) On or about June 22, 2005, Defendant
+(96)
+On or about August 2, 2004, an employee of Defendant JEFFREY
+EPSTEIN prepared a written telephone message for Defendant JEFFREY EPSTEIN's
+review regarding a telephone call received from. and
+"They are available all weekend and maybe
+20
+that stated:
+too".
+
+
+(97) On or about August 21, 2004, Defendant
+(98)
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN
+masturbated in the presence of
+(99) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
+digitally penetrated
+(100) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
+attempted to place a massaging device on the vagina of
+who was then
+a seventeen-year-old girl.
+(101) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made
+a payment of $200 to
+(102) In oraround the last half of 2004, Defendant JEFFREY EPSTEIN asked
+who was then a seventeen-year-old girl, about her age.
+(103) In or around the last half of 2004, Defendant JEFFREY EPSTEIN told
+that he would take her to Los Angeles when she turned eighteen.
+(104) In or around the last half of 2004, Defendants JEFFREY EPSTEIN and
+caused
+to travel to 358 El
+Brillo Way.
+(105) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
+masturbated in the presence o1
+
+
+(106) In or around the end of 2004, Defendant JEFFREY EPSTEIN placed
+a massaging device on the vagina of
+who was then a seventeen-yearold girl.
+D
+(107) In oraround the last half of 2004, Defendant JEFFREY EPSTEIN made
+a payment of $200 to
+(108) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
+digitally penetrated
+(109) Inor around the last half of 2004, Defendant JEFFREY EPSTEIN asked
+ho was then a seventeen-year-old girl, about her age.
+(110) In or around the last half of 2004, Defendant JEFFREY EPSTEIN told
+nat he wanted to take her to Paris but he could not because
+as not yet eighteen years old.
+(111) In oraround the last half of 2004, Defendant JEFFREY EPSTEIN asked
+to bring her friends to his home, especially "girls who looked like|
+(112) In or around the last half of 2004, Defendant
+led
+from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY
+EPSTEIN's bedroom at 358 El Brillo Way.
+(113) In oraround the last half of 2004, Defendant JEFFREY EPSTEIN asked
+p provide her telephone number.
+22
+
+
+(114) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
+instructed
+who was then a seventeen-year-old girl, to pinch his nipples.
+(115) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
+masturbated in the presence of
+who was then a seventeen-year old girl.
+(116) In oraround the last half of 2004, Defendant JEFFREY EPSTEIN made
+a payment of $300 td
+(117) In or around the end of 2004 and the beginning of 2005, Defendant
+JEFFREY EPSTEIN digitally penetrated
+who was then a seventeenyear-old girl.
+(118) In or around the end of 2004 and the beginning of 2005, Defendant
+JEFFREY EPSTEIN asked
+who was then a seventeen-year-old girl,
+whether she had any plans for her eighteenth birthday and acknowledged that she had
+not yet turned eighteen.
+(119) On or about December 23, 2004, Defendant JEFFREY EPSTEIN
+caused a Western Union wire transfer order to be sent to
+(120) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+placed a massaging device on the vagina of
+ho was then a seventeenyear-old girl.
+(121) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+engaged in sexual intercourse with
+who was then a seventeen-year-old
+girl.
+23
+
+
+(122) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+performed oral sex on
+(123) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+made a payment of $600 to
+(124). On or about January 8, 2005, Defendant
+(125) On or about January 9, 2005, Defendant
+'" placed a telephone call to a telephone used byl
+(126) On or about January 26, 2005, one of Defendant JEFFREY EPSTEIN's
+employees prepared a written telephone message for Defendant
+review regarding a call received from
+that read: "She is confirming for
+5:30".
+(127) On or about January 26, 2005, Defendant
+" placed a telephone call to a telephone used by
+(128) On or about February 1, 2005, Defendant
+(129) On or about March 1, 2005, Defendant
+" placed a telephone call to a telephone used by
+(130) On or about March 21, 2005, Defendant
+" placed a telephone calls to a telephone used by
+24
+
+
+(131) On or about March 29, 2005, Defendant
+D
+(132) On or about December 6, 2004, Defendant
+placed
+a telephone call to a telephone used by
+(133) On or about December 14, 2004, Defendant
+placed
+a telephone call to a telephone used by .
+(134) In or around the first half of 2005, Defendant
+led
+from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY
+EPSTEIN's bedroom at 358 El Brillo Way.
+(135) In or around the first half of 2005, Defendant JEFFREY EPSTEIN
+instructed
+L who yras then a seventen-year-old girl, to pinch his nipples
+while he masturbated.
+(136) In or around the first half of 2005, Defendant JEFFREY EPSTEIN
+fondled the breasts of
+(137) In or around the first half of 2005, Defendant JEFFREY EPSTEIN
+made a payment of $200 to
+(138) On or about January 7, 2005, Defendant
+" placed a telephone call to a telephone used by
+#15.
+25
+
+
+(139) On or about February 4, 2005, Defendant
+(140) On or about February 10, 2005, Defendant
+placed
+a telephone call to a telephone used byl
+(141) On or about February 21, 2005, Defendant ]
+placed
+a telephone call to a telephone used b
+(142) On or about February 24, 2005, Defendant
+placed
+a telephone call to a telephone used by l
+(143) On or about March 17, 2005, Defendant
+(144) On or about March 30, 2005, Defendant
+(145) On or about March 31, 2005, Defendant
+(146) On or about March 31, 2005, Defendant
+" placed a telephone call to a telephone used b
+(147) On or about April 1, 2005, one of Defendant JEFFREY EPSTEIN's
+employees prepared a note for Defendant JEFFREY EPSTEIN's review that read:
+"10:30
+on Fri around 2'Oclock".
+(148) In or around June 2005, Defendant JEFFREY EPSTEIN provided
+with a gift of
+Secret lingerie for her eighteenth birthday.
+26
+
+
+(149) In or around February 2005, Defendant JEFFREY EPSTEIN
+masturbated in the presence of
+D
+(150) In or around the first quarter of 2005, Defendants JEFFREY EPSTEIN
+caused
+Ito place a telephone call tell
+to ask her to travel to 358 El Brillo Way.
+(151) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+caused a payment to be made to
+o travel
+to 358 El Brillo Way.
+(152) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+masturbated in the presence o
+• who was then a sixteen-year-old girl.
+instructed
+(153) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+who was then a sixteen-year-old girl, to remove all of her
+clothing.
+(154) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+placed a massaging device on the vagina of.
+who was then a sixteenyear-old girl.
+made a payment of $200
+(155) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+27
+
+
+(156) In or around the first nine months of 2005, Defendant JEFFREY
+EPSTEIN placed a massaging device on the vagina of|
+ho was then
+a seventeen-year-old girl.
+(157) In or around the first nine months of 2005, Defendant JEFFREY
+EPSTEIN asked
+who was then a seventeen-year-old girl, how old she
+was, and she responded that she was seventeen years old.
+(158) In or around the first nine months of 2005, Defendant JEFFREY
+EPSTEIN engaged in sexual activity with Defendant
+in the
+presence of
+(159) In or around the first nine months of 2005, Defendant JEFFREY
+EPSTEIN asked
+who was then a seventeen-year-old girl, to touch the
+breast of Defendant
+MARCINKOVA.
+(160) On or about April 11, 2005, Defendant
+" placed a telephone call to a telephone used by
+(161) On or about April 11, 2005, Defendant
+telephone call to a telephone used byl
+(162) On or about April 11, 2005, Defendant
+left a
+message for Defendant JEFFREY EPSTEIN stating:
+can work
+tomorrow at 4pm."
+(163) On or about May 19, 2005, Defendant
+telephone call to a telephone used by,
+28
+
+
+(164) On or about June 30, 2005, Defendant
+telephone call to a telephone used byl
+(165) On or about July 2, 2005, Defendant
+telephone call to a telephone used byl
+(166) On or about July 22, 2005, Defendant
+(167) On or about August 18, 2005, Defendant
+telephone call to a telephone used byl
+(168) On or about August 19, 2005, Defendant
+" placed a telephone call to a telephone used by
+(169) On or about August 21, 2005, Defendant
+placed a telephone call to a telephone used by
+(170) On or about September 3, 2005, Defendant
+" placed a telephone call to a telephone used by l
+(171) On or about September 18, 2005, Defendant
+a telephone call to a telephone used by
+(172)
+On or about September 19, 2005, Defendant
+text message to a telephone used byl
+(173)
+On or about September 29, 2005, Defendant
+a telephone call to a telephone used by
+, a/k/a
+placed
+sent a
+placed
+29
+
+
+(174) On or about September 30, 2005, Defendant,
+'" placed a telephone call to a telephone used by ,
+, a/k/a
+(175) On or about October 1, 2005, Defendant
+left a
+telephone message for Defendant JEFFREY EPSTEIN stating:
+confirmed at 11 AM and
+- 4PM".
+(176) On or about October 2, 2005, Defendant
+telephone call to a telephone used byl
+(177) On or about October 3, 2005, Defendant
+telephone call to a telephone used b
+(178) On or about October 3, 2005, Defendant
+left a
+telephone message for Defendant JEFFREY EPSTEIN stating: "'
+will
+be ½ hour late".
+A
+(179) In or around the first week of October, 2005, Defendant JEFFREY
+EPSTEIN engaged in sexual intercourse with
+who was then a
+seventeen-year-old girl.
+(180) In or around the first week of October, 2005, Defendant JEFFREY
+EPSTEIN made a payment of $350.00 to
+who was then a seventeenyear-old girl.
+(181) In or around the first week of October, 2005, Defendant JEFFREY
+EPSTEIN provided a gift of Victoria's Secret lingerie to
+for her
+eighteenth birthday.
+30
+
+
+(182) In or around the last half of 2003]
+was approachedby
+and was asked whether she would be willing to provide a massage to Defendant
+JEFFREY EPSTEIN in exchange for $200.
+(183) In oraround the last half of 2003, Defendant JEFFREY EPSTEIN asked
+Jane Doe #18 to provide her telephone number.
+(184) On or around August 27, 2003, Defendant
+a telephone call to a telephone used by
+placed
+(185) In or around the last half of 2003, Defendant JEFFREY EPSTEIN
+masturbated in the presence o
+who was then a seventeen-year-old-girl.
+(186) On oraround November 16, 2003, Defendant
+placed
+a telephone call to a telephone used by
+(187) In or around the last half of 2003, Defendant JEFFREY EPSTEIN
+digitally penetrated
+who was then a seventeen-year-old-girl.
+(188) In oraround the last half of 2003, Defendant JEFFREY EPSTEIN asked
+to recruit other females to travel to 358 El Brillo Way.
+(189) On orabout March 5, 2004, Defendant JEFFREY EPSTEIN asked
+who was then a seventeen-year-old girl, to leave when she refused to
+remove her shirt.
+31
+
+
+(190) On or about March 5, 2004, Defendant JEFFREY EPSTEIN verbally
+to 358 El Brillo Way when she
+reprimanded.
+was not willing to undress for him.
+D
+The Defendants' Travel
+(191) On or about March 11, 2004, Defendants JEFFREY EPSTEIN,
+pand
+traveled from Teterboro, New Jersey, to
+Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air,
+Inc.
+(192) On or about May 1, 2004, Defendants JEFFREY EPSTEIN,
+, and
+traveled from New York, New York to Palm
+Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC.
+(193) On or about May 14, 2004, Defendants JEFFREY EPSTEIN,
+traveled from Canada to Palm Beach
+County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC.
+(194) On or about June 11, 2004, Defendants JEFFREY EPSTEIN and
+traveled from Chicago, Illinois to Palm Beach County, Florida
+aboard the Gulfstream aircraft owned by Hyperion Air, Inc.
+(195) On or about June 20, 2004, Defendants JEFFREY EPSTEIN and
+traveled from the U.S. Virgin Islands to Palm Beach
+County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC.
+32
+
+
+(196) On or about July 4, 2004, Defendants JEFFREY EPSTEIN,
+traveled from Aspen, Colorado to Palm
+Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.
+(197) On or about July 16, 2004, Defendants JEFFREY EPSTEIN,
+, and
+traveled from Teterboro, New Jersey to
+Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air,
+Inc.
+(198) On or about July 22, 2004, Defendants JEFFREY EPSTEIN,
+, and
+traveled from the U.S. Virgin Islands to
+Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC.
+(199) On or about August 19, 2004, Defendants JEFFREY EPSTEIN and
+traveled from Van Nuys, California to Palm Beach County,
+Florida aboard the Boeing 727 aircraft owned by JEGE, INC.
+(200) On or about August 25, 2004, Defendants JEFFREY EPSTEIN,
+, and
+traveled from Ecuador to Palm
+Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC.
+(201) On or about October 2, 2004, Defendants JEFFREY EPSTEIN, L
+traveled from the U.S. Virgin Islands to
+Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC.
+33
+
+
+(202) On or about October 29, 2004, Defendants JEFFREY EPSTEIN and
+traveled from Teterboro, New Jersey to Palm Beach
+County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.
+(203) On or about November 10, 2004, Defendants JEFFREY EPSTEIN and
+traveled from Teterboro, New Jersey to Palm Beach County,
+Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.
+(204) On or about November 18, 2004, Defendants JEFFREY EPSTEIN,
+a/k/a"
+" and i
+traveled from Teterboro, New Jersey to Palm Beach County, Florida
+aboard the Gulfstream aircraft owned by Hyperion Air, Inc.
+(205) On or about December 3, 2004, Defendants JEFFREY EPSTEIN,
+, and
+, а/k/a")
+" traveled from
+New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft
+owned by JEGE, INC.
+(206) On or about December 13, 2004, Defendant JEFFREY EPSTEIN
+traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the
+Gulfstream aircraft owned by Hyperion Air, Inc.
+(207) On or about December 17, 2004, Defendants JEFFREY EPSTEIN and
+traveled from Teterboro, New Jersey to Palm Beach
+County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.
+
+
+(208) On or about January 1, 2005, Defendants JEFFREY EPSTEIN,
+1, and
+traveled from Anguilla, British West Indies
+to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion
+Air
+Inc.
+(209) On or about January 6, 2005, Defendant JEFFREY EPSTEIN traveled
+from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream
+aircraft owned by Hyperion Air, Inc.
+(210) On or about January 14, 2005, Defendants JEFFREY EPSTEIN,
+a/k/a "
+" and
+traveled from the U.S. Virgin Islands to Palm Beach County,
+Florida, aboard the Boeing 727 aircraft owned by JEGE, INC.
+(211) On or about January 19, 2005, Defendants JEFFREY EPSTEIN,
+a/k/a "
+"and
+traveled from New York, New York to Palm Beach County, Florida
+aboard the Boeing 727 aircraft owned by JEGE, INC.
+On or about February 3, 2005, Defendants JEFFREY EPSTEIN,
+, and
+traveled from Columbus, Ohio, to
+Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC.
+(213) On or about February 10, 2005, Defendants JEFFREY EPSTEIN,
+a/k/a "l
+"and
+35
+
+
+traveled from New York, New York to Palm Beach County, Florida,
+aboard the Boeing 727 aircraft owned by JEGE, INC.
+(214) On or about February 21, 2005, Defendants JEFFREY EPSTEIN,
+traveled from the U.S. Virgin
+Islands to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by
+JEGE, INC.
+(215) On or about February 24, 2005, Defendants JEFFREY EPSTEIN,
+, and
+traveled from Teterboro, New
+Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by
+Hyperion Air, Inc.
+(216) On or about March 4, 2005, Defendants JEFFREY EPSTEIN,
+, a/k/a"
+"and
+i traveled
+from New York, New York to Palm Beach County, Florida aboard the Boeing 727
+aircraft owned by JEGE, INC.
+(217) On or about March 18, 2005, Defendant JEFFREY EPSTEIN traveled
+from New York, New York to Palm Beach County, Florida aboard the Boeing 727
+aircraft owned by JEGE, INC.
+(218) On or about March 31, 2005, Defendant JEFFREY EPSTEIN traveled
+from New York, New York to Palm Beach County, Florida, aboard the Boeing 727
+aircraft owned by JEGE, INC.
+36
+
+
+(219) On or about May 19, 2005, Defendants JEFFREY EPSTEIN,
+traveled from
+Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft
+owned by Hyperion Air, Inc.
+(220) On or about June 30, 2005, Defendants JEFFREY EPSTEIN and
+traveled from Teterboro, New Jersey to Palm Beach County,
+Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.
+(221) On or about July 22, 2005, Defendants JEFFREY EPSTEIN and
+traveled from Teterboro, New Jersey to Palm Beach County,
+Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.
+(222) On or about August 18, 2005, Defendants JEFFREY EPSTEIN,
+, a/k/a '1
+"and
+traveled
+from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream
+aircraft owned by Hyperion Air, Inc.
+(223) On or about September 3, 2005, Defendants JEFFREY EPSTEIN and
+, a/k/a"
+" traveled from the U.S. Virgin Islands
+to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion
+Air, Inc.
+(224) On or about September 18, 2005, Defendants JEFFREY EPSTEIN,
+, and
+, ak/a"
+' traveled from
+37
+
+
+Westchester County, New York to Palm Beach County, Florida aboard the Gulfstream
+aircraft owned by Hyperion Air, Inc.
+(225) On or about September 29, 2005, Defendants JEFFREY EPSTEIN,
+p, a/k/a"1
+"and
+traveled
+from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream
+aircraft owned by Hyperion Air, Inc.
+All in violation of Title 18, United States Code, Section 371.
+COUNTS 2 THROUGH 10
+Psex Trafficking: 18 U.S.C. § 1591(a)(1))
+31.
+Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by
+reference as though fully set forth herein.
+32. On orabout the dates enumerated as to each count listed below, the exact dates
+being unknown to the Grand Jury, in/Palm Beach County, in the Southern District of Florida,
+and elsewhere, the Defendants listed below did knowingly, in and affecting interstate and
+foreign commerce, recruit, entice, provide, and obtain by any means a person, that is, the
+person in each count listed below, knowing that the person had not attained the age of 18
+years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. §
+1591(c)(1):
+Count
+2
+Date(s)
+2001 - 2004
+Minor Involved
+Defendants)
+JEFFREY EPSTEIN
+38
+
+
+Count
+3
+4.
+D
+5
+7
+8
+10
+Date(s)
+January 2004
+through
+July 2004
+July 2004
+through
+December 29,
+2004
+July 2004
+hroug
+anuary 31. 200
+Mid-2004
+through
+April 22, 2005
+August 2004
+through
+May 27,2005
+November 2004
+through
+March 2005
+December 2004
+through
+June 5, 2005
+February 2005
+through
+first week of
+October 2005
+Minor Involved
+Defendants)
+JEFFREY EPSTEIN
+JEFFREY EPSTEIN
+JEFFREY EPSTEIN
+JEFFREY EPSTEIN
+JEFFREY EPSTEIN
+JEFFREY EPSTEIN
+JEFFREY EPSTEIN
+JEFFREY EPSTEIN
+a/k/a"
+a/k/a"
+All in violation of Title 18, United States Code, Sections 1591(a)(1) and 2.
+39
+
+
+COUNT 11
+(Sex Trafficking: 18 U.S.C. § 1591(a)(2))
+33.
+Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by
+reference as though fully set forth herein.
+34.
+From at least as early as in or about 2001 through in or about October 2005,
+the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern
+District of Florida, and elsewhere, the defendants,
+did knowingly benefit, financially or by receiving anything of value, from participation in a
+venture, as defined in 18 U.S.C. § 1591(c)(3), which had engaged in an act described in
+violation of 18 U.S.C. § 1591(a)(1), that is, the recruiting, enticing, providing, and obtaining
+by any means a person, in or affecting interstate commerce, knowing that the person or
+persons had not attained the age of 18 years and would be caused to engage in a commercial
+sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title 18, United States Code,
+Sections 1591(a)(2), 1591(b)(2), and 2.
+COUNT 12
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+35.
+Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by
+reference as though fully set forth herein.
+40
+
+
+36. From in or around the spring of 2003 through on or about October 2, 2005, the
+exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District
+of Florida, and elsewhere, the defendants,
+D
+JEFFREY EPSTEIN
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice
+who was a person who had not attained the age of
+18 years, to engage in prostitution and in a sexual activity for which a person can be charged
+with a criminal offense, that is violations of Florida Statutes Sections 800.04(5)(a),
+800.04(6)(a), and 800.04(7)(a); in violation of Title 18, United States Code, Sections 2422(b)
+and 2.
+/ COUNT 13
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+37. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by
+reference as though fully set forth herein.
+-From in or around January 2004 through in or around July 2004, the exact dates
+being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida,
+and elsewhere, the defendants,
+JEFFREY EPSTEIN
+41
+
+
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice
+no was a person who had not attained the age of
+18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections
+2422(b) and 2.
+COUNT 14
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+39.
+Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by
+reference as though fully set forth herein.
+From
+thrag in or arowned October 2004,
+40.
+In or around July 2004, the exact dates being unknown to the Grand Jury, in
+Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants,
+JEFFREY EPSTEIN
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice
+ho was a person who had not attained the age of
+18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections
+2422(b) and 2.
+COUNT 1S
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+41.
+Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by
+reference as though fully set forth herein.
+42
+
+
+42. From in or around July 2004 through on or around December 29, 2004, the
+exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District
+of Florida, and elsewhere, the defendants,
+D
+JEFFREY EPSTEIN
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice
+who was a person who had not attained the age of
+18 years, to engage in prostitution and in a sexual activity for which a person can be charged
+with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of
+Title 18, United States Code, Sections 2422(b) and 2.
+COUNT 16
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+43. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by
+reference as though fully set forth herein.
+44.
+From in or around July 2004 through on or about January 31, 2005, the exact
+dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of
+Florida, and elsewhere, the defendants,
+F
+JEFFREY EPSTEIN
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice
+who was a person who had not attained the age
+43
+
+
+of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections
+2422(b) and 2.
+COUNT 17
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by
+reference as though fully set forth herein.
+46. From in or around the middle of 2004 through on or about April 22, 2005, the
+exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District
+of Florida, and elsewhere, the defendants,
+JEFFREY EPSTEIN
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice
+who was a person who had not attained the age
+of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections
+2422(b) and 2.
+COUNT 18
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+47.
+Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by
+reference as though fully set forth herein.
+48.
+From in or around August 2004 through on or about May 27, 2005, the exact
+dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of
+Florida, and elsewhere, the defendants,
+44
+
+
+JEFFREY EPSTEIN
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entic
+who was a person who had not attained the age
+of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections
+2422(b) and 2.
+COUNT 19
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+49. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by
+reference as though fully set forth herein.
+50. From in or around November 2004 through in or around March 2005, the exact
+dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of
+Florida, and elsewhere, the defendants,
+JEFFREY EPSTEIN,
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice
+who was a person who had not attained the age
+of 18 years, to engage in prostitution and in a sexual activity for which a person can be
+charged with a criminal offense, that is a violation of Florida Statutes Section 794.05; in
+violation of Title 18, United States Code, Sections 2422(b) and 2.
+45
+
+
+COUNT 20
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+51. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by
+reference as though fully set forth herein.
+From in or around December 2004 through on or about June 5, 2005, the exact
+dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of
+Florida, and elsewhere, the defendants,
+R
+JEFFREY EPSTEIN,
+, and
+_, a/k/a"
+"
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+who was a person who had not attained the age
+persuade, induce and entice
+of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections
+2422(b) and 2.
+COUNT 21
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+53. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by
+reference as though fully set forth herein.
+F
+54.
+From in or around February 2005 through in or around the first week of
+October 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in
+the Southern District of Florida, and elsewhere, the defendants,
+46
+
+
+JEFFREY EPSTEIN,
+-a/k/a *
+an
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce or entice
+who was a person who had not attained the age of
+18 years, to engage in prostitution and in a sexual activity for which a person can be charged
+with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of
+Title 18, United States Code, Sections 2422(b) and 2.
+R
+COUNT 22
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+55. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by
+reference as though fully set forth herein.
+56.
+From in or around February 2005 through in or around April 2005, the exact
+dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of
+Florida, and elsewhere, the defendants,
+JEFFREY EPSTEIN,
+Land.
+a/k/a"
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice
+who was a person who had not attained the age
+of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections
+2422(b) and 2.
+
+
+COUNT 23
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+57.
+Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by
+reference as though fully set forth herein.
+From in or around August 2003 through in or around February 2004, the exact
+dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of
+Florida, and elsewhere, the defendants,
+JEFFREY EPSTEIN,
+R
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly
+persuade, induce and entice
+who was a person who had not attained the age
+of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections
+2422(b) and 2.
+A
+COUNT 24
+(Conspiracy to Travel: 18 U.S.C. § 2423(e))
+59. Paragraphs 1 through 25 of this indictment are re-alleged and incorporated by
+reference as fully set for the herein.
+60.
+From at least as early as 2001 through in or around October 2005, the exact
+dates being unknown to the Grand Jury, the Defendants,
+EFFREY EPSTEIN,
+48
+
+
+did knowingly and willfully conspire with each other and with others known and unknown
+to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as
+defined in 18 U.S.C. § 2423(f), with another person, in violation of Title 18, United States
+Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e).
+COUNT 25
+(Facilitation of Unlawful Travel of Another: 18 U.S.C. § 2423(d))
+61. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by
+reference as though fully set forth herein.
+62. From atleast as early as in or about 2001 through in or around October 2005,
+the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern
+District of Florida, and elsewhere, the Defendant,
+did, for the purpose of commercial advantage or private financial gain, arrange and facilitate
+the travel of a person, that is Defendant Jeffrey Epstein, knowing that such person was
+traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as
+defined in 18 U.S.C. § 2423(f); in violation of Title 18, United States Code, Section 2423(d).
+COUNTS 26 THROUGH 29
+(Travel to Engage in Illicit Sexual Conduct: 18 U.S.C. § 2423(b))
+63. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by
+reference as though fully set forth herein.
+64.
+On or about the dates enumerated as to each count listed below, from a place
+outside the Southern District of Florida to a place inside the Southern District of Florida, the
+49
+
+
+Defendants) listed below traveled in interstate commerce for the purpose of engaging in
+illicit sexual conduct as defined in 18 U.S.C. § 2423(f), with a person under 18 years of age,
+that is, the person(s) listed in each count below:
+Count
+26
+Date(s)
+7/16/2004
+Minor(s) Involved
+Defendants)
+JEFFREY EPSTEIN
+28
+3/31/2005
+R
+9/18/2005
+JEFFREY EPSTEIN
+a/k/a"
+JEFFREY EPSTEIN
+29
+9/29/05
+A
+a/k/a*
+a/k/a*
+JEFFREY EPSTEIN
+All in violation of Title 18, United States Code, Sections 2423(b) and 2.
+FORFEITURE 1
+Upon conviction of the violation alleged in Count 1 of this indictment, the defendants,
+JEFFREY EPSTEIN,
+, a/k/a"
+," and
+, shall forfeit to the United States any property, real or personal,
+which constitutes or is derived from proceeds traceable to the violation.
+50
+
+
+Pursuant to Title 28, United States Code, Section 2461; Title 18, United States Code,
+Section 981(a)(1)(C); and Title 21, United States Code, Section 853.
+If the property described above as being subject to forfeiture, as a result of any act or
+omission of the defendants, JEFFREY EPSTEIN,
+a/k/a"
+(1)
+cannot be located upon the exercise of due diligence;
+(2) has been transferred or sold to, or deposited with a third person;
+(3) has been placed beyond the jurisdiction of the Court;
+(4)
+has been substantially diminished in value; or
+(5)
+has been commingled with other property which cannot be subdivided without
+difficulty;
+it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p),
+to seek forfeiture of any other property of the defendants up to the value of the above
+forfeitable property.
+All pursuant to Title 28 United States Code, Section 2461; Title 18, United States
+Code, Section 981(a)(1)(C); and Title 21 United States Code, Section 853.
+FORFEITURE 2
+Upon conviction of any of the violations alleged in Counts 12-29 of this indictment,
+the defendants, JEFFREY EPSTEIN,
+"and
+y, a/k/a"
+, shall forfeit to the United States any property, real
+or personal, constituting or traceable to gross profits or other proceeds obtained from such
+51
+
+
+offense; and any property, real or personal, used or intended to be used to commit or to
+promote the commission of such offense, including but not limited to the following:
+a.
+A parcel of land located at 358 El Brillo Way, Palm Beach, Florida
+33480, including all buildings, improvements, fixtures, attachments, and easements found
+therein or thereon, and more particularly described as:
+Being all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as
+recorded in Plat Book 9, Page 9, in the records of Palm Beach County, Florida
+BEING that portion lying West of Lot 40, El Bravo Park, in Section 27,
+Township 43 South, Range 43 East, as recorded in Plat Book 9, Page 9, Public
+Records of Palm Beach County, Florida, being bounded on the West by the
+West side of an existing concrete seawall and the northerly extension thereof
+as shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981,
+and bounded on the East by the shoreline as shown on the plat of El Bravo
+Park, and bounded on the North and South by the Westerly extensions of the
+North and South lines respectively of Lot 40, containing 0.07 acres, more or
+less.
+Pursuant to Title 18, United States Code, Section 2253.
+If any of the forfeitable property described in the forfeiture section of this indictment,
+as a result of any act or omission of the defendants JEFFREY EPSTEIN,
+a/k/a *
+" and
+(a)
+cannot be located upon the exercise of due diligence;
+(b)
+has been transferred or sold to, or deposited with, a third person;
+(c)
+has been placed beyond the jurisdiction of the Court;
+(d)
+has been substantially diminished in value; or
+52
+
+
+:
+(e)
+has been commingled with other property which cannot be divided without
+difficulty;
+it is the intent of the United States, pursuant to Title 18, United States Code, Section 2253(o),
+to seek forfeiture of any other property of said defendant up to the value of the above
+forfeitable property.
+Pursuant to Title 18, United States Code, Section 2253.
+FORFEITURE 3
+Upon conviction of any of the violations alleged in Counts 2-11 of this indictment,
+the defendants, JEFFREY EPSTEIN,
+%, a/k/a"/
+" and
+1, shall forfeit to the United States any property, real
+or personal, that was used or intended to be used to commit or to facilitate the commission
+of such violation; and any property, real or personal, constituting or derived from any
+proceeds that such person obtained, directly or indirectly, as a result of such violation,
+including but not limited to the following:
+a.
+A parcel of land located at 358 El Brillo Way, Palm Beach, Florida
+33480, including all buildings, improvements, fixtures, attachments, and easements found
+therein or thereon, and more particularly described as:
+Being all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as
+recorded in Plat Book 9, Page 9, in the records of Palm Beach County, Florida
+BEING that portion lying West of Lot 40, El Bravo Park, in Section 27,
+Township 43 South, Range 43 East, as recorded in Plat Book 9, Page 9, Public
+Records of Palm Beach County, Florida, being bounded on the West by the
+53
+
+
+West side of an existing concrete seawall and the northerly extension thereof
+as shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981,
+and bounded on the East by the shoreline as shown on the plat of El Bravo
+Park, and bounded on the North and South by the Westerly extensions of the
+North and South lines respectively of Lot 40, containing 0.07 acres, more or
+less.
+Pursuant to Title 18, United States Code, Section 1594(b).
+A TRUE BILL.
+FOREPERSON
+R
+UNITED STATES ATTORNEY
+ASSISTANT UNITED STATES ATTORNEY
+F
+54
+
+
+U.S.
+HARVEY
+1441
+Cite as B69 Fia 1439 (11th Clr. 1989)
+§ 7201,' and one count of filing a false letter from the United States Attorney for
+income tax return in April of 1981, a violathe Southern District of Alabama acknowltion of 26 U.S.C. § 7206(1).* The governedging that Harvey had reached an agreement alleges that Harvey kept millions of
+ment with the government in 1980.
+dollars derived from his lucrative drug
+The government denied that Harvey had
+dealings in a bank account in the Cayman
+Islands.
+been granted any immunity other than a
+In his individual income tax re
+simple agreement not to prosecute him for
+turn for the year 1980, however, Harvey
+certain charges pending in Alabama.
+Be-
+denied that he had any proprietary interest
+cause it disputed the very existence of a
+in, or authority over, any bank account
+grant of immunity, the government objectoutside the United States. Harvey also
+ed to the holding of a Kastigar hearing as
+failed to report the interest income he allegedly earned on his Cayman Islands account on his individual income tax returns
+for the years 1978 to 1982.
+Harvey
+filed a motion in the district
+court on June 2, 1986 in which he alleged
+that the government had informally grant.
+ed him use immunity in return for his coop
+eration in a drug investigation in 1980.
+Harvey sought a pretrial hearing to require
+the government to prove that the evidence
+it proposed to use at trial was derived from
+a legitimate source independent of the immunized testimony, as Kastigar o. United
+States,
+406
+U.S. 441, 92 S.Ct. 1653, 82
+L.Ed.2d
+(1972), required. The immunity agreement was never reduced to writing. but Harvey was able to point to a
+' Tie 26 U.S.C. § 7201 provides in part as fol.
+Any person who willfully attempts in any
+manner to evade or defeat any tax imposed by
+this title or the payment thereof shall, in addition to other penalties provided by law, be
+guilty of a felony and, upon conviction thereof, shall be fined
+than 5 years, or both, together with the costs
+of prosecution.
+The fine for a violation of section 7201 committed before September 3, 1982 is an amount not
+more than $10,000.
+For violations committed
+after t pendaty norman 110000. Tax
+tential penalty to not more than $100,000.
+Equity and Fiscal Responsibility Act of 1982
+Pub.L. No. 97-248, § 329, 96 Stat. 324, 617-18
+(1982).
+2. Title 26 U.S.C. § 7206(1) provides in part:
+Any person who-
+(1) DECLARATION UNDER PENALTIES
+OF PERJURY.-Willfully makes and
+scribes any return statement, or other doc
+ten declare on that in made ender ne
+Faced with this disputed claim of an unwritten grant of immunity, the magistrate
+did not hold a traditional Kastigar hearing.
+as Harvey had requested.
+Instead, she
+held a series of "pre Kastigar" hearings in
+order to determine (1) whether Harvey had
+been granted immunity in 1980, (2) if so,
+what kind of immunity the government had
+granted, and (3) what information Harvey
+had revealed to the government.
+The "pre-Kastigar" hearings revealed
+that in June of 1980 a grand jury sitting in
+the Southern District of Alabama had indicted Harvey and several others for the
+attempted importation of a large quantity
+of quaalude tablets.
+The government's
+case against Harvey was indefensible
+shall be guilty of a felony and, upon conviction thereof, shall be fined not more than
+$100,000 ($500,000 in the case of a corpora
+tion) or imprisoned not more than 3 years, or
+both, together with the costs of prosecution.
+As for violations of section 7201, the fine for a
+violation of section 7206(1) is an amount not
+more than $10,000 for violations committed before September 3, 1982, $100,000 if committed
+after that date.
+Tax Equity and Fiscal Responsibility Act of 1982, Pub.L. No. 97-248, § 329, 96
+Stat. 324, 617-18 (1982).
+3. Harvey answered "no" to the following ques
+tion: "At any time during the tax year, did you
+have an interest in or a signature or other
+authority over a financial account in a foreig
+country (such as a bank account, or other finan
+See U.S. Individual Income Tax
+Return 1980 (Form 1040), Schedule B, Part III
+(Foreign Accounts and Foreign
+Trusts).
+form TD-F 90-22.1 (requiring each person subject to U.S. jurisdiction to report any interest in
+a bank account in a foreign country.
+alties of perjury, and which he does not
+to be true and correct as to every
+material matter; or
+680 F. 20-13
+
+
+1442
+"slam dunk" to use the evocative words of
+had granted Harvey both transactional immunity and use immunity for any information he had revealed to the DEA officials in
+cooperate with the government.
+Although the United States Attorney in
+the Southern District of Alabama did not
+need any of the testimony Harvey offered,
+his counterpart in the Southern District of
+Florida did. Thus, Harvey was able to
+reach a three-sided agreement with the
+government. Although there was some
+dispute at the "pre-Kastigar" hearings
+about the specific terms of the actual bargain struck between Harvey and the
+government, the witnesses agreed that the
+United States Attorney for the Southern
+District of Alabama offered to dismiss the
+indictment pending in that district in return
+for Harvey's cooperation with an investigation that the United States Attorney for
+the Southern District of Florida was conducting.
+The United States Attorney for
+the Southern District of Florida sent several Drug Enforcement Administration
+("DEA") agents to Alabama where they
+interviewed Harvey. Apparently Harvey
+met his side of the bargain, and the United
+States Attorney dismissed the indictment
+against Harvey in the Alabama quaalude
+case.
+The testimony differed sharply as to any
+further elements of the agreement. After
+weighing all the evidence, the magistrate
+found that in addition to agreeing to drop
+the Alabama indictment, the government
+4. Under the net worth method the government
+establishes the taxpayer's total assets and liabilities at the beginning of the year and compares
+them with the taxpayer's assets and liabilities at
+If the excess of assets over
+liabilities increases during the year the increase
+is taxable unless the taxpayer can show that the
+represents nontaxable income.
+eg. Holland v. Umited States, 348 U.S. 121, 75
+S.Ct. 127, 99 LEd. 150 (1954) (approving net
+worth method of reconstructing taxable income
+under predecessor of current Internal Revenue
+1980.
+Because the DEA agents who interviewed Harvey had failed to keep any
+records whatsoever of their conversations
+with Harvey, the daunting task of reconstructing what Harvey disclosed to the
+DEA agents in 1980 now faced the magistrate. The magistrate found that Harvey
+had told the agents about all of the drug
+deals in which he had been involved before
+and at the time of his arrest in 1980, and
+had also "divulged ... his financial dealings with respect to his illegal drug deals."
+This information included the identification
+of the funds in the Cayman Islands bank.
+Having thus determined what had hap
+pened in 1980, the magistrate turned to the
+1985 tax evasion indietment. Stephen Snyder, the Justice Department's Criminal Tax
+Division attorney responsible for the investigation of the government's case and its
+presentation to the grand jury appeared at
+the "pre-Kastigar" hearings.
+Snyder testified that the government had used the net
+worth method of proving to the grand jury
+that Harvey had substantially underreported his income in the prior years.* In addition, the government also introduced documents obtained from the Bank of Nova
+Scotia in the Cayman Islands showing pay.
+ment of interest
+to Harvey during the
+years in question. Snyder further testidence from the Cayman Islands under the
+agreement only when it does so as part of an
+investigation for narcotics violations.
+the government was investigating him solely for
+tax evasion, Harvey argues that it could not
+invoke the provisions of the agreement (even
+though the corpus of the money was derived
+from narcotics activity). The district court dismissed the indictment against Harvey before
+addressing this question; therefore, because this
+question is not now before us, we do not ad.
+dress it, nor do we address Harvey's standing to
+5. In a separate motion before the district court
+Harvey sought to have the court exclude these
+documents which the government had obtained
+Activities." The gravamen of Harvey's argu
+ment is that the United States may obtain evi-
+o the government of the Cayman Islands as i
+tad to in order to obtain documentary evideno
+under the terms of the agreement—that Harvey
+was involved in narcotics activity. Because we
+conclude that the government is entitled to
+
+
+U.S. HARVEY
+1443
+Cite as 869 F:
+. 1439 (11th Clr. 1989)
+fied that he told the grand jury that the
+For the purposes of this appeal the
+probable source of Harvey's income was
+government does not dispute the factual
+his drug-related activities.
+findings of the magistrate and distriet
+The magistrate did not allow the governcourt that Harvey received transactional
+ment to show that it had derived the eviand use immunity in 1980 and that he told
+dence it presented to the grand jury—or
+the DEA agents about his financial dealthat it intended to introduce at trial-from
+ings, including the existence of the funds in
+legitimate independent sources. The hearthe Cayman Islands. The government,
+ing transcript, currently under seal, reveals
+however, vigorously disagrees with the leconclusively that Snyder began to testify
+gal conclusion that such a grant of immuniabout the trail that led to Harvey's Cayman
+ty given in 1980 bars Harvey's prosecution
+Islands bank account, but upon the objecfor failure to report the existence of a
+tion of Harvey's counsel, the magistrate
+foreign bank account or the interest earned
+stopped Snyder from testifying further.
+in that account in years after that grant o
+The magistrate considered such informammunity.
+tion irrelevant to the "pre-Kastigar " hear
+ing; instead, the magistrate reasoned that
+II. INFORMAL GRANTS OF
+whether the government derived the infor-
+IMMUNITY
+mation leading to the indietment from independent sources was properly a matter
+We note at the outset that this appeal
+only for a true Kastigar hearing.
+would not be necessary had the United
+States Attorneys for the Southern Districts
+With the findings of fact set out, the
+magistrate then made a "Finding of Law"
+of Alabama and Florida reduced their
+in which she concluded that the information
+agreement with Harvey to writing. The
+concerning Harvey's drug activities and re
+magistrate and district court have been put
+lated financial dealings formed the basis
+through the arduous task of reconstructing
+for the tax indictment and was "inextricathe
+terms of the agreement with the
+bly tied" to the information that Harvey
+government, a task made still more diffi
+had revealed to the DEA agents in 1980.
+cult by the astonishing failure of the DEA
+Even though she had refused the governagents who interviewed Harvey to keep
+ment the opportunity to demonstrate that
+any written records of those interviews.
+the evidence against Harvey came from a
+Informal grants of immunity are by their
+source independent of the immunized testivery nature less certain than formal
+mony, the magistrate concluded that the
+grants, and thus are much more likely to
+evidence presented to the grand jury was
+create confusion for the government and
+"tainted." The magistrate further concludfor the courts in the future. As long as
+ed that the indictment violated the grant of
+prosecutors continue the practice of unwritimmunity extended to Harvey and recomten grants of immunity, they open the door
+mended that the district court dismiss the
+for subsequent litigation such as this, and
+indictment.
+for adverse decisions as well.
+The district court reviewed the record de
+[1] Due process requires the governnovo and agreed with the magistrate's fac
+ment to adhere to the terms of any plea
+tual finding that the government had ex- bargain or immunity agreement it makes
+tended both use and transactional immuni-
+See Mabry v. Johnson, 467 U.S. 504, 104
+ty to the appellee. The district court dis-
+S.Ct. 2548, 81 L.Ed.2d 437 (1984) (plea
+missed the indictment with prejudice.
+agreement); Santobello v. New York, 404
+ove that it derived the evidence against Har
+he date of the immunity agreement), or a
+from sources independent of the immunize
+ther legal action, such as forfeiture, that mig
+estimony, we need not address this.
+arise from violations that allegedly took place
+before the immunity agreement. Harvey got a
+fresh start in 1980, including his Cayman Is
+lands money.
+allegedly committed before September of 1980
+
+
+1444
+U.S. 257, 92 S.Ct. 495, 30 L.Ed.2d 427 States v. Quatermain, 613 F.2d 88, 41 (8d
+(1971) (plea agreement); In re Arnett, 804 Cir.), cert. denied, 446 U.S. 954, 100 S.Ct.
+F.2d 1200 (11th Cir.1986) (ples agreement); 2923, 64 L.Ed.2d 812 (1980). We will exam-
+Rowe t. Griffin, 676 F.2d 524 (11th Cir.
+ine each in turn.
+1982) (immunity); United States t. Weiss,
+599 F.2d 730, 737 (5th Cir.1979) (immunity)
+(Tuttle, J.) ('"To protect the voluntariness of
+a waiver of fifth amendment rights, where
+a plea, confession, or admission is based on
+a promise of a plea bargain or immunity,
+the government must keep its promise.").
+See also Plaster v. United States, 789 F.2d
+289 (4th Cir.1986) (immunity); Johnson t.
+Lumpkin, 769 F.2d 630 (9th Cir.1985) (plea
+agreement); United States v. Carter, 454
+F.2d 426, 427 (4th Cir.1972) (in bane) (immunity) ("if the promise was made to defendant as alleged and the defendant relied
+upon it in incriminating himself, the
+government should be held to abide by its
+terms"").
+This is true because by entering
+into a plea agreement the defendant for-
+III. USE IMMUNITY
+The first issue we address is the effect
+the 1980 grant of use immunity has on the
+current prosecution for tax evasion. This
+question is essentially evidentiary in nature. As we discuss below, the government may not use, either directly or derivatively, any testimony Harvey gave under
+the 1980 grant of use immunity against
+him in a subsequent related prosecution.
+We discuss in a separate section the an
+alytically distinct question of whether the
+government may ever prosecute Harvey
+for tax evasion.
+Resolution of that question depends on the scope of the 1980 grant
+of transactional immunity Harvey regoes his important constitutional right to a
+jury trial, or by testifying under a grant of
+immunity he forgoes his fifth amendment
+privilege. In either case courts will enforce the agreement when the defendant or
+witness has fulfilled his side of the bargain.
+[2] Although federal law no longer provides for formal, statutory grants of transactional immunity, a prosecutor may, as in
+this case, informally grant transactional
+immunity to a witness in return for his
+cooperation in a criminal case.
+Similarly,
+although 18 U.S.C. 99 6002-6003 provide
+for court-supervised grants of use immunity, prosecutors may extend such immunity
+informally as well. Harvey did not receive
+a formal (statutory) grant of transactional
+or use immunity, yet because due process
+requires us to
+enforce the government's
+agreement with Harvey, we apply the same
+rules and method of analysis to an informal
+grant of use or transactional immunity as
+we would to a formal grant." E.g., United
+7. As a part of the Organized Crime Control Act
+of 1970 Congress added the current scheme for
+statutory grants of use immunity, currently co-
+18 U.S.C. 55 6001-6005, and repealed
+other immunity statutes, including
+transactional immunity provisions, that had
+been scattered throughout the United States
+[3-5] Use immunity prohibits the use of
+compelled testimony, or any evidence de
+rived directly or indirectly from that testimony, against the witness in a criminal
+prosecution. See generally Kastigar v.
+United States, 406 U.S. 441, 92 S.Ct. 1653,
+32 L.Ed.2d
+(1972). In contrast to transactional immunity, use immunity does not
+prohibit the government from prosecuting
+the witness for crimes about which he testified, provided the government proves that
+it has other evidence to support the prosecution that "is derived from a legitimate
+source wholly independent of the compelled
+testimony." Id., 406 U.S. at 460, 92 S.Ct.
+at 1665.
+Pursuant to Title 18 U.S.C
+§§ 6002-6003, a district court may formally
+grant use immunity to a witness who refuses to testify on the basis of his fifth amendment privilege, or, as here, a prosecutor
+may informally grant use immunity to a
+witness in return for his cooperation in a
+criminal case. When a defendant has dem-
+522(190. No. 91-452, 59 201-260, 84 Star.
+8. We note that the government has not alleged
+that Harvey in some way failed to meet his end
+of the bargain. Therefore, our task is simply to
+enforce the agreement with Harvey.
+
+
+U.8. v. HARVEY
+1445
+Cite ne 369 FId 1439 (11th Cir. 1989)
+onstrated that he testified under a grant of
+IY. TRANSACTIONAL IMMUNITY
+use immunity, the burden shifta to the
+prosecution which then has "the affirmative duty to prove that the evidence it pro-
+16) The more difficult issue in this apposes to use is derived from a legitimate
+peal is whether the transactional immunity
+source wholly independent" of the testimo-
+Harvey received in 1980 prohibits the
+ny given under the grant of immunity. See
+government from prosecuting him for tax
+Braswell v. United States, — U.S. -
+violations committed after that grant of
+108 S.Ct. 2284, 2295, 101 L.Ed.2d 98 (1988);
+immunity.
+We conclude that it does not.
+Kastigar, 406 U.S. at 460, 92 S.Ct. at 1665.
+[7) Transactional immunity "accorda
+See also Murphy . Waterfront Comm'n,
+full immunity from prosecution for the of
+378 U.S. 52, 79 . 18, 84 S.Ct. 1594, 1609 n.
+fense to which the compelled testimony re-
+18, 12 L.Ed.2d 678 (1964).
+lates."
+Kastigar v. United States, 406
+The government contends that it derived
+U.S. 441, 458, 92 S.Ct. 1653, 1661, 82 L.Ed.
+the evidence it used to secure Harvey's
+2d 212 (1972)." The purpose of a grant of
+indictment by the grand jury and the evitransactiona. (or use) immunity is to pre
+clude a witnesa's reliance on his fifth
+dence it intended to use at trial, from an
+independent source.
+amendment privilege against compelled
+essence, the
+self-incrimination: the government may
+government claims that while investigating
+compel a witness to testify by granting him
+someone else the Criminal Tax Division of
+immunity, provided that the scope of the
+the Justice Department came upon a trail
+immunity is at least as great as that of the
+of evidence that led to Harvey's bank ac
+fifth amendment privilege that the witness
+count in the Cayman Islands.
+must forego.
+See Kastigar v. United
+As we noted above, the record reveals
+States, 406 U.S. at 449, 92 S.Ct. at 1659;
+that the magistrate did
+not permit the
+Counselman i. Hitchcock, 142 U.S. 547,
+government to show the independed
+564, 586-87, 12 S.Ct. 195, 198, 206, 35 L.Ed.
+sources of its evidence against Harve
+1110 (1892). As such, in deciding the scope
+The magistrate recommended that the il
+of a grant of immunity the Supreme Court
+dictment be dismissed after having contraditionally has referred to the scope of
+ducted only the "pre-Kastigar" hearing.
+the fifth amendment privilege itself.
+Similarly, the distriet court dismissed the
+For example, in Heike v. United States,
+indictment in part because it believed that
+227 U.S. 131, 38 S.Ct. 226, 57 L.Ed. 450
+all of the government's evidence was given
+(1913) (Holmes, J.), the Court refused to
+under the 1980 grant of immunity.
+Yet
+construe broadly a transactional immunity
+such a conclusion was premature without
+statute that provided that "no person shall
+giving the government the opportunity to
+be prosecuted or be subjected to any penalmeet its burden under Kastigar of proving
+ty or forfeiture for or on account of any
+the independent source of its evidence.
+transaction, matter, or thing concerning
+For the same reason, any conclusion that
+which he may testify or produce evidence,
+tainted evidence sufficient to justify disdocumentary or otherwise, in any proceedmissing the indietment was presented to
+ing, suit, or prosecution under [the interstate commerce and anti-trust acts]."
+the grand jury was also premature because Heike, 227 U.S. at 141, 33 S.Ct. at 227
+the government may have been able to
+demonstrate that the evidence was not
+(quoting Act of February 25, 1905, ch. 755,
+32 Stat. 904). The Court saw "no reason
+tainted at all.
+for supposing that the act offered a gratui-
+Transactional immunity statutes typically pr
+rided that "no person shall be prosecuted o
+20-23
+gar v. United States, 406 U.S. 441, 451, 92 S.CL.
+1653, 1660, 32 LEd.2d
+(1972) (quoting from
+Compulsory Testimony Act of 1893, which
+served as a model for numerous federal immunity statutes).
+
+
+1446
+ty to crime." Id. at 142, 39 S.Ct. at 228.
+before us now. The magistrate found as a
+Instead, the Court reasoned that a grant of
+fact, and the district court affirmed her
+immunity "should be construed, so far as
+finding, that the government extended use
+its words fairly allow the construction, as
+and transactional immunity to Harvey in
+coterminous with what otherwise would
+return for his cooperation, i.e., his testimohave been the privilege of the person conny. Absent any factual finding to the conerned."
+Shapd" United States, 335 U.S. 1, 19,
+trary, we believe it proper to conclude that
+this grant of immunity was fully as broad
+68 S.Ct. 1375, 1385, 92 L.Ed. 1787 (1948)
+as the fifth amendment privilege that Har-
+(following rule of construction of Heike).
+vey gave up when he disclosed his illegal
+More recently, in Kastigar, the Court upactivities to the DEA agents. By the same
+held the constitutionality of 18 U.S.C.
+token, we believe that-absent any con-
+§ 6002 on the ground that use immunity
+trary factual finding—we should not con-
+"is coextensive with the scope of the priviclude that the scope of the immunity Har
+lege against self-incrimination, and therevey received was any greater than that of
+fore is sufficient to compel testimony over
+the fifth amendment privilege he gave up.!°
+a claim of the privilege." 406 U.S. at 453,
+Thus, Harvey received transactional and
+92 S.Ct at 1661.
+use immunity for any testimony as to
+The Court noted in Kastigar that transwhich he could have invoked his fifth
+actional immunity is broader than the fifth
+amendment privilege in September of 1980.
+amendment privilege because it provides
+With this in mind, we turn now to the
+for full immunity from future prosecution,
+issue of when may a witness invoke his
+while the fifth amendment privilege "has
+fifth amendment privilege with respect to a
+never been construed to mean that one who
+crime he has not yet committed.
+invokes it cannot subsequently be prosecuted." Id.
+Yet the Court has never indicated that transactional immunity is in any
+other respect broader than the fifth amendment privilege. Thus, transactional immunity and use immunity are coterminous
+with the fifth amendment privilege in ail
+respects other than their effect on the
+government in the future. A grant of use
+immunity prohibits the government from
+using evidence disclosed either directly or
+derivatively, while a grant of transactional
+immunity prohibits the government from
+prosecuting the witness at any time with
+respect to the incriminating matters the
+witness disclosed.
+Although Kastigar and Heike were cases
+in which the witness refused to testify, and
+thus the Court had to look to the scope of
+the fifth amendment privilege in order to
+determine whether the proffered immunity
+sufficed to displace that privilege, we believe the same principles apply to the case
+10. We note that neither the magistrate nor the
+district court found that the plea agreement
+included anything other than the dismissal of
+B.
+[8] In general, the privilege against
+self-incrimination only prohibits compelled
+testimony that might incriminate a witness
+for crimes he had already committed, or
+was in the process of committing, at the
+time the testimony was given. See Counselman, 142 U.S. at 562, 12 S.Ct. at 198
+(purpose of privilege is "to insure that a
+person should not be compelled, when acting as a witness in any investigation, to
+give testimony which might tend to show
+that he himself had committed a crime")
+(emphasis added); United States u. Quatermain, 613 F.2d 88, 42 (3d Cir.), cert.
+denied, 446 U.S. 954, 100 S.Ct. 2923, 64
+L.Ed.2d 812 (1980).
+Twenty years ago,
+however, the Supreme Court rejected a rig
+id chronological test under the fifth amendment privilege, focusing instead on the substantiality of the risk the witness faced.
+involved anything more. Thus, we are working
+solely with the familiar categories of transac
+tional and use immunity, and do not face any
+the Alabama indictment and the grant of use
+and transactional immunity. Nor does Harvey
+suggest during this appeal that his agreement
+
+
+U.S. L HARVEY
+1447
+Cite as 369 FE
+| 1439 (11ch Cir. 1989)
+In Marchetti i. United States, 890 U.S.
+the general rule that the fifth amendment
+39, 88 S.Ct. 697, 19 L.Ed.2d 889 (1968) the
+privilege applies only to past and present
+Supreme Court held that the fifth amendcriminal acts, the exception is a very narment privilege was not entirely inapplicable
+row one.
+to prospective acts. The petitioner in Mar-
+In United States v. Freed, 401 U.S. 601,
+chetti was convicted of violating provisions
+91 S.Ct. 1112, 28 L.Ed.2d 356 (1971), the
+of a statute that required professional
+Court emphasized the narrowness of the
+gamblers to register annually with the In-
+ternal Revenue Service and pay an occupafifth amendment privilege's application to
+future conduct. In Freed, the Court reject-
+The Court, overruling a prior
+ed the argument that a registration recase that had upheld the very same statute,
+quirement of the National Firearms Act
+United States . Kahriger, 345 U.S. 22, 73
+violated the fifth amendment because the
+S.Ct. 510, 97 L.Ed. 754(1963), held that the
+information disclosed could be used in conpetitioner's assertion of his fifth amendnection with offenses that the transferee of
+ment privilege in refusing to comply with
+the firearm might commit in the future. In
+the statute provided a complete defense to
+so doing, the Court stated:
+his prosecution for failing to register and
+Appellee's argument assumes the exist
+pay the occupational tax."
+ence of a periphery of the Self-Incrimi-
+Marchetti explicitly rejected the notion
+nation Clause which protects a person
+that the fifth amendment privilege offere
+against incrimination not only against
+protection only as to past and present acts.
+past or present transgressions but which
+390 U.S. at 53, 88 S.Ct. at 705.
+supplies insulation for a career of crime
+the Court emphasized that "[t]he central
+about to be launched. We cannot give
+standard for the privilege's application has
+the Self-Incrimination Clause such an exbeen whether the claimant is confronted by
+pansive interpretation.
+substantial and 'real,' and not merely trila. at 606-07, 91 S.Ct. at 1117. Thus, Marfling or imaginary, hazards of incriminachetti and Freed teach that the focus of
+tion." Id., 88 S.Ct at 705. Relying on this
+inquiry under the fifth amendment is
+standard, the Court held that the hazards
+whether the witness faces a substantial
+of incrimination created by the registration
+risk of incrimination.
+When the witness
+and occupational tax provisions as to fuhas not yet committed the crime, or is not
+ture acts were not "trifling or imaginary"
+in the process of committing it, his risk of
+because prospective registrants could reaincrimination is generally so speculative as
+sonably expect that compliance with these
+to remove him from the aegis of the fifth
+provisions "may serve as decisive evidence
+amendment privilege.
+that they have in fact subsequently violat-
+Lower court opinions
+also make clear
+ed state gambling prohibitions." Id, 88
+that the fifth amendment privilege rarely
+will apply to future conduct. For example,
+Although application of this standard
+in United States v. Quatermain, 613 F.2d
+proved favorable to the petitioner in Mar-
+38, 42-43 (8d Cir.), cert. denied, 446 U.S.
+chetti, the Court stressed that this would
+954, 100 S.Ct. 2923, 64 L.Ed.2d 812 (1980),
+not usually be the case, as prospective acta
+the court noted that Marchetti did not sup
+"will doubtless ordinarily involve only specport the defendant's argument that the
+ulative and insubstantial risks of incriminafifth amendment privilege applies to a wittion." Id. at 54, 88 S.Ct. at 705. Thus,
+ness who refuses to testify because he
+although Marchetti created an exception to
+asserts that his testimony somehow may be
+11. Marchetti also overruled Lewis v. United
+sion which would-be gamblers must make at the
+States, 348 U.S. 419, 75 S.Ct. 415, 99 LEd. 475
+threshold. They may have to give up gambling.
+(1955), which had held that the wagering tax
+but there is no constitutional right to gamble.
+provisions did not violate the fifth amendment
+privilege because they were not compulsory.
+According to the Lewis Court, "It]he only com
+pulsion under the Act is that requiring the deci.
+
+
+1448
+used to incriminate him in a prosecution for 1980 did not apply to these crimes, because
+a different type of criminal act that he may
+they did not occur until April of 1981, well
+commit in the future.
+Accordingly, the
+after immunity was granted.
+court held that the defendant's testimony
+According to his testimony at the preunder an informal grant of use immunity
+Kastigar hearing, Harvey had revealed to
+about his involvement in a drug ring did
+the DEA agents that he had deposited mil
+not prevent the government from indieting
+lions of dollars, earned through illegal drug
+him for subsequently manufacturing a gun
+transactions, into his accounts at the Nova
+silencer, even though the district
+Scotia Bank in the Cayman Islands. He
+found that the defendant's immunized testialso told the agents how he set up corporamony had helped lead to the indictment on
+tions in the Cayman Islands to launder
+the gun charge. See also United States
+drug money. In September of 1980, the
+Gallo, 859 F.2d 1078, 1088 (2d Cir.1988)
+defendant could not have had "substantial
+(Van Graafeiland, J., coneurring) ("Licensand real" fears that this information would
+ing and taxing statutes aside, the only hazincriminate him for evasion of taxes on
+ards of incrimination that are likely to be
+interest income that either was not yet
+considered substantial and real are those
+which relate to existing or past misdeed or
+required to be reported or had not yet been
+a continuing course of criminal activity.").
+earned, or for filing a false income tax
+return that was not due for months to
+come." Harvey could not have asserted
+his fifth amendment privilege with respect
+When we apply these principles to the
+to these matters, therefore they are outside
+case at hand, we see that the information
+the scope of the immunity he received in
+Harvey revealed to the DEA agents in September of 1980 could not have created substantial and real hazards that it would incriminate him for tax crimes he later allegedly committed in April of 1981, 1982 and
+Counts three through five of the
+indietment charged Harvey with evasion of
+income taxes for the years 1980, 1981, and
+1982, offenses that could not have occurred
+until April of 1981, 1982, and 1983, when
+Harvey filed his tax returns for the preceding years.' Furthermore, the crime of
+willfully filing a false tax return for income
+earned in 1980, as charged in count six of
+the indictment, could not have occurred
+until April of 1981 when Harvey filed the
+allegedly fraudulent return."
+though the crimes charged in counts three
+and six of the indictment related to Harvey's 1980 taxes, the immunity granted in
+2. See Sansone | United States, 380 U.S. 34.
+151, 85 S.Ct. 100
+, 1010, 13 L.Ed.2d 882 (1965)
+(violation of 26 U.S.C. § 7201 does not occur
+atil the defendant commits an affirmative a
+instituting an evasion or attempted evasion
+Put another way, each failure to report
+income and each failure to disclose the
+Cayman Islands account was a separate
+transaction, in the eyes of the law separathe transactions
+Harvey received immunity. Harvey had a
+right by contract to receive the interest
+income on his money, a right he presumably could have enforced in a Cayman Is-
+lands court. Similarly, each year Harvey's
+failure to report the interest on the foreign
+account was a separate transaction.
+duty to report the existence of the foreign
+bank account in April of 1981, was a separate transaction, unrelated to what had
+gone before.
+The mere fact that Harvey
+failed to disclose funds the existence of
+which he had disclosed under a grant of
+14. Even if Harvey was certain that he intended
+conceal the existence of the Cayman Islands
+and the interest earned there from his
+uture tax returns, that would not suffice t
+make the threat of future prosecution "real and
+the tax).
+13. See United States w. Bishop,
+412 U.S. 346
+357-58, 93 S.Ct. 2008, 2016, 36 L.Ed.2d 94]
+ture tax violations. The law will not deem his
+risk of incrimination substantial because the
+law expects him to be honest in the future.
+
+
+U.S. | HARVE)
+1449
+ite as 869 F3
+1439 (11th Cir. 1989)
+immunity does not alter the independent understanding it is possible to apply the
+duty Harvey had to report his income accu- correct analysis to the case at hand.
+rately.
+We must reject Harvey's argument that
+the 1980 grant of transactional immunity
+somehow shielded the Cayman Islands
+funds themselves from the reach of the tax
+laws." There is no such thing as in rem
+immunity. Harvey became immune from
+prosecution for those transactions about
+which he testified, but the money he disclosed did not somehow partake of this
+immunity. The grant of transactional immunity the government extended to Harvey in 1980 does not prohibit prosecution
+for tax violations he allegedly committed in
+the years following that grant of immunity.
+CONCLUSION
+For the reasons we have stated above,
+we REVERSE the decision of the district
+court and REMAND for proceedings consistent with this opinion.
+CLARK, Circuit Judge, dissenting:
+The majority has written a well reasoned
+opinion on the scope of formal statutory
+immunity. Insofar as the court holds that
+under a formal grant of immunity, an individual is shielded from prosecution only to
+the extent of his Fifth Amendment privilege, I believe it correctly states the law.
+Unfortunately, this case does not involve
+formal statutory immunity. Instead, this
+case involves an agreement between the
+defendant and the prosecutor in which the
+prosecutor agreed not to prosecute the defendant in return for his cooperation. Not
+only does the majority fail to recognize the
+fundamental difference between the two
+forms of immunity, it assumes that the
+same rules apply to formal and informal
+immunity. Since the same principles do
+not apply, I dissent. To understand why
+the analysis of the majority is erroneous, it
+is necessary to understand the various
+forms of "immunity" Only with that
+15. Whether Harvey himself reasonably believed
+this is a matter for the jury, which under 26
+U.S.C. 55 7201 and 7206(1) must find that he
+wilfully violated the reporting requirements of
+In two key sections, the majority states
+that the same rules apply to formal and
+informal immunity. Supra at 1444, 1446.
+Specifically the majority holds that the
+scope of any grant of immunity is defined
+by the Fifth Amendment. Before explaining this error, it is necessary to understand
+the difference between transactional and
+use immunity as well as the difference
+between formal and informal immunity.
+Transactional immunity "accords full immunity from prosecution for the offense to
+which the compelled testimony relates,"
+Kastigar v. United States, 406 U.S. 441,
+453, 92 S.Ct. 1653, 1661, 32 L.Ed.2d 212
+(1972). Use immunity, on the other hand,
+is more limited; it protects the individual
+from prosecution through the use of the
+immunized testimony or evidence derived
+from that testimony. Therefore, while
+transactional immunity prohibits any future prosecution, use immunity only limits
+the government's manner of proof in a
+subsequent prosecution.
+This distinction is
+significant in this case because the magistrate found that the government granted
+Harvey "transactional immunity" or full
+immunity from prosecution. As the majority correctly states, the issue in this case is
+the scope of that "transactional immunity."
+The majority holds that the scope is coextensive with the Fifth Amendment privilege. To understand why the majority is
+incorrect, it is necessary to understand the
+distinction between formal and informal immunity. Because the two forms of immunity come from different sources, the scope
+of each type of immunity differs.
+Formal or statutory immunity is set out
+in 18 U.S.C. § 6001 et seg. Immunity is
+granted by a court upon the U.S. Attorney's request when a witness refuses to
+testify before a grand jury or at trial based
+so ta code reape nones of a vented.
+
+
+1450
+on his Fifth Amendment privilege against States v. Carter, 454 F.2d 426, 428 (4th
+self-incrimination.
+statute authorizes the granting of
+"use" and derivative use immunity.
+U.S.C. § 6002. Several points are noteworthy. First, a United States Attorney does
+not have the power to grant formal immunity. Instead, he must first subpoena a
+witness and if the witness invokes the Fifth
+Amendment privilege, the prosecutor must
+obtain approval by the Attorney General or
+Deputy Attorney General and then request
+the court to order the witness to testify.
+18 U.S.C. § 6003.1 Second, the statute only
+authorizes use immunity, not transactional
+immunity. Third, since formal immunity is
+granted to overcome a witness' invocation
+of the Fifth Amendment, the Supreme
+Court has held that the scope of the immunity granted must be as broad as the privilege. Kastigar, 406 U.S. at 450, 92 S.Ct. at
+Due to the cumbersome requirements of
+obtaining properly authorized statutory immunity, U.S. Attorneys often make informal agreements with individuals in return
+for their cooperation. See United States v.
+Quatermain, 613 F.2d 38, 45 (3d Cir.) (Al-
+disert, J., dissenting), cert. denied, 446 U.S.
+954, 100 S.Ct. 2923, 64 L. Ed.2d 812 (1980).
+The agreements are perfectly analogous to
+plea agreements: an individual with valuable information bargains with the prosecutor with respect to pending charges in re
+turn for that individual's cooperation. A
+usual condition of cooperation is that the
+individual not be subject to prosecution for
+any of the information he provides. See id.
+A prosecutor's power to grant informal
+immunity derives from his inherent discretion over prosecuting cases; just as a prosecutor has the discretion to plea bargain,
+he has the discretion to grant an individual
+immunity from prosecution.
+We have held
+that "due process requires the prosecutor's
+promise to be fulfilled." Rowe u. Griffin,
+676 F.2d 524, 528 (11th Cir.1982); see also
+This practice has been dubbed "informal
+immunity," "hip pocket immunity," see
+Quatermain, 618 F.2d at 45, or "equitable
+immunity." Rowe, 676 F.2d at 526. Additionally, since the prosecutor often agrees
+not to prosecute at all, these agreements
+are sometimes carelessly labeled "transactional immunity." See Rowe, 676 F.2d at
+526 (since prosecutor promised Rowe there
+would be no subsequent prosecution, court
+stated he was offered "transactional immunity"). All these terms are unfortunate
+mianomers because they lead to confusion
+with formal statutory immunity. Such confusion ignores the fact that the two types
+of immunity derive from totally different
+sources and that the source of the immunity determines the scope of a specific grant
+of immunity. For example, 18 U.S.C.
+§ 6002 only authorizes use immunity.
+More importantly, because statutory immunity is granted to avoid reliance on the
+Fifth Amendment privilege, the scope of
+immunity must be coextensive with the
+Fifth Amendment privilege.
+Amendment only protects an individual
+against divulging information about future
+conduct if he faced a substantial risk of
+incrimination as to those events at the time.
+See United States v. Freed, 401 U.S. 601,
+603, 91 S.Ct. 1112, 1115, 28 L.Ed.2d 356
+(1971) (firearm registration requirement did
+not violate Fifth Amendment); Marchetti
+. United States, 390 U.S. 39, 53, 88 S.Ct.
+697, 705, 19 L.Ed.2d 889 (1968) (tax registration requirements violated fifth amendment because registrants could expect provisions to serve as evidence of violation of
+gambling laws). It therefore follows that
+under a formal grant of immunity, a witness is only immunized with respect to
+conduct if he faced a substantial risk of
+incrimination as to those events when he
+Plaster v. United States, 789 F.2d 289, 293
+(4th Cir.1986); United States v. Fountain,
+In cases of informal immunity, however,
+776 F.2d 878, 882 (10th Cir.1985); United
+the scope of the immunity is not limited by
+1. Immunity is only available when the testimotestify on the basis of the privilege. 18 U.S.C.
+ny is necessary to the public interest and the
+individual has refused or is likely to refuse to
+
+
+U.S. v. HARVEY
+Clie as 869 FId 1439 (11th Cir. 1989)
+1451
+the Fifth Amendment. As Judge Fay has
+conclusion is United States v. Quaterpointed out,
+main, 613 F.2d 38 (8d Cir.1984). Unfortuunder the self-incrimination clause of the
+nately, in Quatermain, the court specificalfifth amendment, evidence of guilt inly held that the informant was granted
+duced by a government promise of immu-
+"the minimum immunity required by the
+nity is 'coerced' evidence and may not be
+Constitution"-that is, use immunity, Id.
+used against the accused.
+• For purpoes
+at 38 (emphasis added). Therefore, the faet
+of compelling testimony which otherwise
+that the agreement provides use immunity
+would be privileged by the fifth amendmade the Fifth Amendment case law relement, all that is constitutionally required
+vant, not the fact that it was an informal
+is a grant of use immunity. However, in
+grant of immunity.
+order to secure testimony, evidence or
+Rowe provides the appropriate analysis
+other cooperation from a potential
+to apply in cases of informal immunity. In
+criminal defendant, a prosecutor may
+Rowe, the court considered a prosecutor's
+see fit to promise complete immunity
+agreement not to prosecute a Ku Klux
+from prosecution.
+Klan informant in return for the informa-
+Rowe, 676 F.2d at 527 (emphasis added).
+tion he provided the state concerning a
+Rowe holds that the government must ofmurder during the Selma to Montgomery
+fer at least use immunity when an individu-
+Civil Rights March. 676 F.2d at 525.*
+The
+al is induced to cooperate, but that there is
+court held that such an agreement must be
+no limit to what the defendant can demand
+enforced when the defendant proves that
+in return for his cooperation. See Quateran agreement was made, that he performed
+main, 618 F.2d at 45 (Aldisert, J., dissenthis side and that the prosecution was diing) ("[T]he United States Attorney is at
+rectly related to the assistance the defenliberty to impose conditions that usually
+dant had given. The court specifically
+relate to testifying or providing certain inanalogized to the case law on plea agreeformation. For his part the
+... informant
+menta and held that "as a matter of fair
+often imposes conditions of his own, usualconduct, the government [must] honor such
+ly relating to agreements not to prosecute
+an agreement[J" Id. at 52T.
+but often covering other matters as
+It follows then that the case law concernwell[.]"). If the potential informant deing the interpretation of plea agreements is
+mands too much, the government may derelevant to the interpretation of this type
+cide that the information is not worth the
+of an agreement made by the prosecutor.
+price or the government can always sub-
+See id. at 528 (this contractual analysis
+poena the potential informant to testify
+applies equally well to promises of immunibefore a grand jury or at the trial thereby
+ty from prosecution). This court inter
+ensuring that the informant is only granted
+prets a plea agreement consistently with
+use immunity. This discussion illustrates
+what the defendant reasonably understood
+that the scope of an informal grant of
+when he entered the plea. In re Arnett,
+immunity depends on the bargain struck.
+804 F.2d 1200, 1201-02 (11th Cir.1986).
+The majority therefore is incorrect to
+The court first determines whether the
+assume the same principles apply to deterwritten agreement is ambiguous on its
+mining the scope of formal and informal
+face. If the agreement is unambiguous
+immunity. In determining that the Fifth
+and there is no allegation of government
+Amendment defines the scope of a grant of
+overreaching, the court will enforce the
+informal immunity, the majority ignores
+agreement according to its plain words.
+the cited quotation from Rowe. The only
+United States . (Michael) Harvey, 791
+case the majority cites as support for its
+F.2d 294, 300 (4th Cir.1986). If the agree
+2. In 1965, the state Attorney General agreed not
+the state attempted to prosecute him for murto prosecute Rowe in return for his testimony a
+der. Rowe brought suit under 42 U.S.C. § 1983
+he grand jury and at trial. After new informa
+to enjoin the state prosecution. 676 F.2d at
+tion arose that Rowe might have lied about
+525-26.
+whether he actually fired any of the fatal shots,
+
+
+1452
+ment is ambiguous, the ambiguity "should
+lands." Supra at 1446 n. 10. Indeed as I
+be resolved in favor of the criminal defenread the majority opinion, its holding that
+dant." Rowe, 676 F.2d at 526 n. 4 (ambi-
+Harvey's immunity is only as broad as the
+guity over whether Attorney General's
+fifth amendment is explicitly dependent on
+promise bound future Attorney General
+this factual finding. See supra at 1446
+was resolved in favor of the defendant);
+("By the same token, we believe that-absee In re Arnett, 804 F.2d at 1203 (governsent any contrary factual finding-we
+ment breached the agreement when it
+should not conclude that the scope of the
+sought forfeiture of defendant's farm since
+immunity Harvey received was any greater
+written agreement ambiguous as to wheththan that of the fifth amendment privilege
+er government would seek forfeiture of
+he gave up.") (Emphasis added). I find this
+property and government could not satisfy
+statement incomprehensible since the only
+heavy burden of proving defendant under-
+"species of immunity" the prosecutor was
+stood government reserved right to seek
+authorized to grant was an agreement not to
+property forfeiture): United States u. (Mi-
+prosecute. Additionally, the magistrate's
+chael) Harvey, 791 F.2d at 301 (imprecision
+use of the terms "transactional" and "use"
+in terms of written agreement construed
+immunity should not be given such great
+against the government).
+weight since the term "transactional" immunity has been used by this court to describe
+an agreement not to prosecute. See Rowe,
+676 F.2d at 526; Quatermain, 613 F.2d at
+In this case, Harvey was not granted
+44 (Aldisert, J., dissenting) (although the
+formal statutory immunity. He was never
+district court phrased its discussion in
+called to testify and never invoked his Fifth
+Amendment privilege.
+terms of transactional and use immunity,
+If he had been
+analyzing it as an agreement not to prosegranted statutory immunity, a diseussion
+cute leads to same result). Furthermore, it
+of the scope of Harvey's Fifth Amendment
+is clear from the magistrate's opinion that
+privilege would be relevant. Instead, Haralthough she used the terms "transactionvey bargained with the government. In
+al" and "use" immunity, she understood
+return for the information he provided, the
+the critical distinction between formal and
+government agreed to drop the charges
+informal immunity.
+In rejecting
+against him in Mobile and agreed not to
+government's argument that it had no powprosecute him for any crimes related to the
+er to grant "transactional" immunity, the
+information he gave.
+magistrate held
+that Harvey entered an agreement with the
+what the government confuses with regovernment and that he performed his side.
+spect to immunity is the court's power
+The crux of this case, therefore, depends
+under 18 U.S.C. 6001 et seq. to force an
+on an interpretation of the agreement not
+unwilling defendant to testify versus the
+government's virtually unbridled discre-
+The magistrate reconstructed the agreetion to plea bargain with any defendant
+ment and found that Harvey had been
+as to terms offered by the government.
+granted both "transactional" and "use" im-
+With respect to § 6001 immunity,
+munity for the information he provided.
+court can compel a defendant to testify,
+The magistrate also determined that Harbut can only grant him use and not
+vey had told the government about the
+transactional immunity. On the other
+Cayman Islands funds. The majority aphand, the executive branch can grant
+parently takes comfort from this finding.
+transactional immunity in the form of a
+stating "we are working solely with the
+bargain and does not need the blessing
+familiar categories of transactional and use
+immunity, and do not face any different Record, Vol. 3, Tab 72 at 22, Indeed, the
+'species' of immunity-e.g., an express
+magistrate applied the principles applicable
+agreement not to prosecute for future tax to plea agreements to what she described
+violations with respect to the Cayman Is- "transactiona]" immunity, Therefore, de-
+
+
+U.S. | HARVEY
+1453
+Ite as 869 F5A
+| 1439 (11th Clr. 1989)
+spite the majority's wishful thinking, we
+given use immunity but that he did not
+are dealing with an agreement not to proseknow whether or not he was given transaccute.
+tional immunity. Finally, the prosecutor
+In this case, the government never wrote
+most intimately involved with the agreedown the terms of the agreement.
+Addiment, Patrick Sullivan, an Assistant U.S.
+tionally, there is no record of the informa-
+Attorney in the Southern District of Flortion Harvey provided.
+Clearly the written
+ida had no recollection of any involvement
+terms of the agreement would be the startwith Jerry Lee Harvey.* He could not
+ing place for determining the scope of imremember speaking to the Mobile U.S. At-
+munity Harvey was granted.
+Due to the
+torney's office or having any negotiations
+government's gross negligence, however,
+with Harvey.
+we are forced to reconstruct the terms of
+The court must interpret an agreement
+the agreement." In order to do so, the
+court must look to the testimony of those
+consistently with the defendant's reasonable interpretation of the agreement. In
+involved in negotiating the agreement to
+this case, the government has failed to
+determine what Harvey believed the agreement provided and whether Harvey's exoffer any evidence to disbelieve Harvey's
+view of the agreement. Instead, the
+pectations were reasonable.
+government argues that it was unreason-
+Jerry Harvey testified that the governable for Harvey to believe that the agreement "agreed nothing I ever give [sic]
+ment would shield him from prosecution
+them would be used against me, nor would
+for future tax violations relating to the
+any U.S. Attorney's Office seek to prose-
+Cayman Islands funds. I do not agree. It
+cute me for anything; that I was just getis not at all clear that a lay citizen would
+ting a clean walk, and I should stay on the
+Government's
+side
+help
+them."
+understand that a government's agreement
+Record Vol. 3, Tab 72 at 14.
+Harvey's
+not to prosecute for anything related to the
+attorney,
+Tom Haas, testified that "the
+Cayman Islands funds would not preclude
+understanding I had with I he gos
+ent]
+prosecution for failure to declare interest
+was that nothing that Jerr
+Harv
+from those funds. In addition, since we
+them, or any agent on
+the
+i to
+Govermment
+have no record of the agreement we have
+would ever at
+any time be used against
+no way of knowing what the government
+Jerry
+Harvey."
+Id.
+at
+15.
+This
+officials represented to Harvey as the
+testimony supports Harvey's argument
+terms of the agreement. In the absence of
+that he believed he was immune from any
+some evidence that Harvey knew the
+prosecution related to the information he
+agreement would not cover these crimes," I
+gave. Significantly, no testimony by either
+cannot accept the government's position.
+of the prosecutors involved in the negotia-
+See (Michael) Harvey, 791 F.2d at 300 (due
+tions rebutted Harvey's broad interpretaprocess requires holding government to a
+tion of the agreement. In response to a
+greater degree of responsibility for ambiquestion by the court, the U.S. Attorney
+guity in plea agreement than defendant).
+for the Southern District of Alabama, Wil-
+Furthermore, to the extent that the governliam Kimbrough, testified that Harvey was
+ment's argument is based on the belief the
+3. I emphasize this point because the majority
+Mr. Sullivan was unable to recall having used
+suggests, supra at 1442-1443, that the only prob-
+Harvey as a witness in a case in which he was
+lem is that ihere is no record of the information
+the trial prosecutor some three to five years
+provided by
+While that omission is
+before the agreement.
+Important, it Is equally problematic (and ultimately decisive in my mind) that there is no
+record of the terms of the agreement.
+4. This is despite the fact that a letter from Mr.
+Sullivan was introduced in which ise asked a
+state prosecutor to consider the fact that Harvey
+had cooperated with both the U.S. Attorney and
+the Drug Enforcement Agency. Additionally,
+5. I emphasize the narrowness of such a holding.
+The terms of the agreement, i/ preserved, might
+have contradicted Harvey's interpretation.
+Even if the agreement was ambiguous, a transcript or even notes of the negotiations might
+have shown that Harvey's position is unreasonable.
+
+
+1454
+government had no authority to enter the
+of which is that U.S. Attorneys are responagreement as Harvey perceived it because
+sible persons who do not conduct themit granted immunity for future crimes, it is
+selves as apprehended by the majority. I
+not persuasive.
+have tried to make clear that the holding is
+that Harvey would know that the governlimited to the facts of this case. In this
+ment did not have the power to enter the
+case, it was not unreasonable for Harvey to
+agreement as he perceived it. Second, that
+believe that the agreement covered the fuargument ignores the possibility that the
+ture tax consequences from the informagovernment may have lead Harvey to betion he provided. Indeed, I have attached
+lieve (or at least contributed to his misunas an appendix excerpts from the testimoderstanding) that the agreement offered
+ny before the magistrate which show that
+such immunity. Finally, this court has nevthe government may have interpreted the
+er refused to enforce a plea agreement just
+agreement to cover even more than this. I
+because the government made a bad deal.
+have also made clear that once Harvey was
+I would therefore hold that the governput on notice by the government that he
+ment agreed that it would not prosecute
+was required to include income from the
+Cayman Island bank accounts on his in-
+Harvey with respect to the Cayman Islands
+funds and that Harvey believed that he
+come tax returns, he no longer could consider himself immune from prosecution for
+would not be prosecuted for failing to report the interest on the Cayman Islands
+failure to report the income. Due process
+funds.
+This does not mean that Harvey
+of law in the context of this case requires
+was immunized from declaring the interest.
+that Harvey be provided advance notice of
+the government's interpretation of the
+Quite the contrary, 1 believe that Harvey
+agreement, especially if the government's
+was required to pay taxes on the interest
+interpretation changed.
+and that the government may collect those
+back taxes. It may not, however, crimi-
+The majority contorts this simple case
+mally prosecute Harvey for failing to reconcerning an agreement not to prosecute
+port his interest. I also do not believe that
+into a use or transactional immunity case
+the agreement forever insulates Harvey
+and then relies on irrelevant Fifth Amendfrom criminal prosecution for failing to rement case authority.
+Here the same
+port his taxes.
+Because the government
+government that promised Harvey in a
+failed to provide any evidence to disbelieve
+bona fide agreement that it would not seek
+Harvey's view of the agreement, it is apto jail him based on information furnished
+parent that the indictment entered against
+in 1980 now seeks to breach that agreement. It must be remembered that the
+Harvey on November 25, 1985 for the first
+district court found:
+time put Harvey on notice that his under-
+"that tainted evidence, evidence for which the defendant
+standing of the agreement conflicted with
+received both use and transactional immuthe government's view. After that point, it
+nity, was presented before the grand jury
+became unreasonable for Harvey to believe
+the agreement provided such broad immuwhich returned the [tax evasion] indietment
+against him."
+nity.
+The majority fears that if the govern-
+III
+ment is required to abide by its contract, a
+pandora's box will be opened where federal
+In conclusion I wish to emphasize that prosecutors will immunize criminals from
+this case presents unique facts and con- being prosecuted for future crimes. That
+cerns which fortunately are of infrequent is obviously unreal. As I have explained,
+occurrence. The concern of the majority is
+this case is an aberration. U.S. Attorneys
+that my view provides carte blanche au- seldom make oral agreements like this.
+thority to U.S. Attorneys to enter into plea We can have confidence that U.S. Attoragreements that will insulate criminals neys will not abuse the informal method of
+from liability for future criminal conduct.
+granting immunity and presumably such
+That concern has many answers, the chief
+agreements will be reduced to writing.
+
+
+Cite as 869 F.2
+U.S. HARVEY
+1439 (11th Cir. 1989)
+1455
+Harvey's due process righta not to be
+I know that he was skeptical. I know
+prosecuted pursuant to the government's
+he didn't trust anybody, and I had to
+agreement are violated by the majority's
+literally force him to comply. I said, "l
+reversal of the district court's dismissal of
+know these people, U.S. Attorney, and
+the tainted indictment.
+Assistant U.S. Attorney." I said, "]
+would stake my life on their honor and
+APPENDIX
+veracity."
+The following are excerpts from the
+magistrate's report. (Record, Vol. 8, Tab
+Tom Haas (Harvey's attorney] and
+William Kimbrough, who was at the time
+of the agreement the U.S. Attorney in
+the Southern Distriet of Alabama, testified the deal negotiated with Harvey was
+that Harvey would not be prosecuted for
+anything about which he told the Government nor would anything he said be used
+against him.
+Q. by Leonard Sands
+A. by Tom Haas
+Q. What was the bargain that was ultimately struck with the two of them?
+A. Once it had been understood that he
+might be able to supply these things, the
+understanding I had with Ruddy and Billy was that nothing that Jerry Harvey
+said to them,
+or
+Government would ever at any time be
+used against Jerry Harvey.
+Q. And what does that mean,
+"would
+ever be used against Jerry Harvey?
+A. That he wouldn't be prosecuted on
+the basis of what they found out from
+him.
+Q. What instructions or advice did you
+give Jerry Harvey prior to his attending
+this meeting at the Sheraton?
+A. Well, I told him just what I just said,
+and I remember that Jerry was very
+skeptical about that. He didn't seem to
+trust anybody, and maybe he didn't trust
+me either. Really, he didn't know me;
+anything about me. I was a small town
+lawyer in a small town to him, and I
+don't recall who had referred him to me.
+I usually try to find that out, perticularly
+in drug cases, because I don't want to
+get in a situation where I am getting
+paid by somebody else.
+Mr. Sands asked Mr. Kimbrough:
+Q. In return for Harvey's furnishing
+information, what was he to receive?
+A. I was to dismiss the indictment
+against him.
+Q. Do you know whether or not any—
+A. And I would not prosecute him for
+anything he said; and I would not use
+anything he said as a means of going
+beyond this agreement to try to stir up
+trouble for Harvey.
+Q. At that time as United States Attorney, you were speaking for yourself, and
+Southern Distriet of Florida?
+A. I can't say that. It was certainly my
+understanding
+somebody had
+touched base with South Florida who
+wanted the information, and I assumed,
+and I continued to assume that nobody
+would have
+I certainly would not have asked Mr.
+Harvey to make a total disclosure had I
+thought that in doing so, I, you know,
+turned him loose to prosecution in some
+other district. I have no personal knowledge of that.
+That is all I am saying.
+That is not the way we operated, I assure you. We tried to treat everybody
+as human beings, although we tried to
+put some of them in the penitentiary.
+•
+THE COURT: I need to interrupt you,
+Mr. Sands. Mr. Kimbrough, you made
+the statement that you would not have
+prosecuted him for anything he told you
+about
+Now, there are all different kinds of
+immunities, and we have been discussing
+that. We have been discussing transactional immunity versus use immunity.
+If in telling you about all drug-related
+murders about which he had knowledge,
+Mr. Harvey told you that he killed some-
+
+
+1456
+APPENDIX-Continued
+defendant Harvey also divulged to the
+Drug Enforcement Administration his fibody in Mobile, Alabama, pursuant to
+this agreement, and this letter, and your
+nancial dealings with respect to his ilunderstanding of this, could you proselegal drug deals.
+cute him for that murder?
+HATCHETT, Circuit Judge,
+THE WITNESS: I don't know. I probdissenting.
+ably rouldn't have.
+I join Judge Clark's dissent. The agree
+THE COURT: Could you use his statement in this case covers the subject funds.
+ment or facts that he gave you in the
+I hasten to add that nothing is gained by
+statement in building of the murder
+encouraging the government to enter into
+informal agreements, the terms of which
+THE WITNESS: No, because it would
+are determined through evidentiary hearbe derived from the statement he gave.
+ings in the district court and fact-finding in
+the in bane court, after the accused has
+Q. by Leonard Sands
+completed performance.
+A. by Jerry Lee Harvey
+Q. As a result of those conversations,
+was it your understanding you had an
+agreement with the U.S. Attorney's Of-
+fice in the Southern District of Alabama?
+A. I knew I did. Mr. Kimbrough, and
+Mr. Favre told me, and Tom Haas told
+me.
+Q. What did they tell you your deal
+was? What were you supposed to do?
+Roy LOHR and Larry Randolph,
+Plaintiffs-Appellees,
+A. I was supposed to tell them everything I knew about drug trafficking, people involved, how it took place, what happened to the funds, how you would register airplanes fictitiously.
+Anything I
+STATE OF FLORIDA DEPARTMENT
+OF CORRECTIONS, et al.,
+Defendants,
+knew from 1975, and everything I had
+done from
+75 up to the present time.
+Q. And what was the Government's obligation to you in return for your cooperation?
+A. They agreed nothing I ever give
+them would be used against me, nor
+would any U.S. Attorney's office seek to
+prosecute me for anything;
+that I was
+just getting a clean walk, and I should
+stay on the Government's side and help
+them.
+Ken Ault, Defendant-Appellant.
+No. 87-5122
+Non-Argument Calendar.
+United States Court of Appeals,
+Eleventh Circuit.
+April 14, 1989
+Keith C. Tischler, Parker, Skelding, Costigan, MeVoy & Labasky, Tallahassee, Fla,
+for defendant-appellant.
+Evan I. Fetterman and Salvatore Scibet
+The best that can be said as a summary of the evidence or statement made by
+ta, Fetterman & Associates, North Palr
+Beach, Fla., for plaintiffs-appellees
+Harvey to the Drug Enforcement Agents
+at that meeting is that Harvey told them
+Appeal from the United States Distric
+all about his drug dealings in which he
+Court for the Southern District of Florida
+had been involved prior to his arrest in
+June of 1980, and including the arrest of
+1980. This Court specifically finds from
+Before HILL, VANCE and CLARK,
+the facts adduced at the hearing that the
+Circuit Judges.
+
+
+
+43A C.J.S. Injunctions $ 281
+Corpus Juris Secundum
+Database updated December 2007
+Injunctions
+By John Bourdeau, J.D., Nicole D. Fox, J.D., John R. Kennel, J.D., of the National Legal Research Group, Charles
+J. Nagy, J.D., Thomas Muskus, J.D., Eric C. Surette, J.D.
+IV. Subjects of Protection and Relief
+H. Criminal Acts, Conspiracies, Prosecutions, and Judgments
+2. Criminal Proceedings, Prosecutions, and Judgments
+Topic Summary References Correlation Table
+§ 281. When injunctive relief available
+West's Key Number Digest
+West's Key Number Digest, Injunction - 105(1)
+There are circumstances under which the courts properly make exceptions to the general rule that equity will
+not interfere with criminal process by entertaining actions for injunction in advance of criminal prosecutions.
+An injunction to restrain a criminal prosecution may issue where a statute authorizes such relief,[FN1] and
+apart from statute, there are circumstances under which courts properly make exceptions to the general rule that
+equity will not interfere with criminal processes by entertaining actions for injunction in advance of criminal
+prosecutions.[FN2] More specifically, an injunction to restrain a criminal prosecution lies where it is shown that
+the prosecution is for the sole purpose of unlawfully taking property, destroying the business of the plaintiff, [FN3]
+or will result in irreparable injury to the plaintiff, [FN4] and the plaintiff has no adequate remedy at law.[FN5]
+Furthermore, there must be a grave danger of impending or imminent injury to the person or property rights; a mere
+So long as the court has jurisdiction and the case is not moot,[FN7] the grant or denial of an injunction is a
+matter for the trial court in the exercise of its sound discretion according to the circumstances and exigencies of
+each particular case.[FN8] It is dependent on the establishment of a clear legal right to the relief sought.(FN9]
+Special circumstances making injunctive relief appropriate may involve prosecution in bad faith[FN10] and
+the use of criminal statutes to suppress and chill constitutionally protected rights.[FN11] In a proper case, unlawful
+ordinarily, one who has not been indicted, arrested, or even threatened with prosecution has no standing to bring a
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=.. 12/27/2007
+
+
+
+43A C.J.S. Injunctions $ 281
+suit for injunction. [FN16]
+Suit relating to same matters pending in equity.
+subject matter of the two proceedings must be identical.(FN20]
+[FN1] Neb.—Webber |. City of Scottsbluff, 141 Neb. 363, 3 N.W.2d 635 (1942).
+[FN2] Ga. —Sarrio | Gwinnett County, 273 Ga. 404, 542 S.E.2d 485 (2001).
+[FN3] Ark.—Billy/Dot, Inc. | Fields, 322 Ark. 272, 908 S.W.2d 335 (1995).
+Ga.—Sarrio |. Gwinnett County, 273 Ga. 404, 542 S.E.2d 485 (2001).
+[FN4] U.S.—Scolaro |. District of Columbia Bd. of Elections and Ethics, 946 F. Supp. 80 (D.D.C. 1996).
+Ga.—Sarrio |. Gwinnett County, 273 Ga. 404, 542 S.E.2d 485 (2001).
+[ENS] U.S.—Metro Medical Supply, Inc. | Shalala, 959 F. Supp. 799 (M.D. Tenn. 1996).
+Ga.—Sarrio |. Gwinnett County, 273 Ga. 404, 542 S.E.2d 485 (2001).
+[FN6] U.S.—Gersten |. Rundle, 833 F. Supp. 906 (S.D. Fla. 1993), affd, 56 F.3d 1389 (11th Cir. 1995).
+Ga.—Sarrio |. Gwinnett County, 273 Ga. 404, 542 S.E.2d 485 (2001).
+[FN7] Ark.—Dickey | Signal Peak Enterprises, 340 Ark. 276, 9 S. W.3d 517 (2000).
+Tenn.—Storey |. Nichols, 49 S.W.3d 288 (Tenn. Ct. App. 2000).
+[FN8] Wyo.—Nation . Giant Drug Co., 396 P.2d 431 (Wyo. 1964).
+[FN9] N.Y.—Weiss | Beckmann, 197 Misc. 414, 96 N.Y.S.2d 66 (Sup 1950).
+[FN10] U.S.—In re Scott, 166 B.R. 779 (D. Mass. 1994).
+La.—Board of Com'rs of Orleans Levee Dist. | Connick, 654 So. 2d 1073 (La. 1995).
+A.L.R. Library
+Proceedings for injunction or restraining order as basis of malicious prosecution action, 70 A.L.R. 3d 536.
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=... 12/27/2007
+
+
+
+43A C.J.S. Injunctions § 281
+[FN 1 1] U.S.—Metro Medical Supply, Inc. | Shalala, 959 F. Supp. 799 (M.D. Tenn. 1996).
+[FN12] U.S.—U.S. | Hasiwar, 299 F. Supp. 1053 (S.D. N.Y. 1969).
+[FN13] N.Y.—Simonson || Cahn, 33 A.D.2d 790, 307 N.Y.S.2d 581 (2d Dep't 1969), order aff'd, 27
+N.Y.2d 1, 313 N.Y.S.2d 97
+261 N.E.2d 246 (1970).
+[FN14] U.S.—Younger |. Harris, 401 U.S. 37, 91 S. Ct. 746, 27 L. Ed. 2d 669 (1971).
+[FN15] U.S.—New Am. Library of World Literature | Allen, 114 F. Supp. 823, 52 Ohio Op. 289, 67 Ohio
+L. Abs. 143 (N.D. Ohio 1953).
+[FN16] U.S.—Alga, Inc. . Crosland, 327 F. Supp. 1264 (M.D. Ala. 1971), order affd, 459 F.2d 1038 (5th
+Cir. 1972).
+[FN17] U.S.— Packard |], Banton, 264 U.S. 140, 44 S. Ct. 257, 68 L. Ed. 596 (1924).
+[FN18] Fla.—Gulf Theatres | State ex rel. Ferguson, 133 Fla. 634, 182 So. 842 (1938).
+[FN19] U.S.— Harkrader , Wadley, 172 U.S. 148, 19 S. Ct. 119, 43 L. Ed. 399 (1898).
+[FN20] Fla.—Coleman | Greene, 136 Fla. 276, 186 So. 541 (1939).
+[FN21] Pa.—Pennsylvania Soc. for Prevention of Cruelty to Animals | Bravo Enterprises, Inc., 428 Pa.
+350, 237 A.2d 342 (1968).
+[FN22] Ala.—Quinnelly | City of Prichard, 292 Ala. 178, 291 So. 2d 295 (1974).
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_topdmt=..
+
+
+177
+Count Three is ripe for federal adjudica- of conduct leading up to the enactment of
+SHEELE
+Ordinance and the SDP challenge to appellees' obstructive course of conduct prior to
+the enactment of the Ordinance are ripe
+for review. The complaint states a facial
+SDP claim upon which relief can be grant-
+(заминан
+ed as to the Ordinance, and a SDP claim
+as to appellees' obstructive course of conduct, and the order of the Distriet Court
+dismissing those claims on this ground will
+be reversed. The complaint fails to state
+STOLT-NIELSEN, S.A.; Stolt-Nielsen
+Transportation Group Ltd.;
+Richard B. Wingfield
+an EPC claim, and the order of the District Court dismissing on this ground will
+To the extent that the Dis-
+UNITED STATES of America
+triet Court dismissed the SDP, EPC, Takings and Tortious Interference claims
+No. 05-1480.
+(Counts One through Four) against the
+individual defendants on the ground of ab-
+United States Court of Appeals,
+solute legislative immunity, the order of
+Third Circuit.
+the District Court will be vacated, and we
+Argued Sept. 30, 2005.
+will remand for findings consistent with
+this opinion. To the extent the District
+Filed March 23, 2006.
+Court accorded the individual defendants
+As Amended May 16, 2006.
+legislative immunity as to appellants' SDP
+Background: Company and officer, faced
+claim attacking defendants' pre-Ordinance
+with possible criminal charges for antitrust
+conduct under Blanche Road, the order of
+violations, brought action to enforce terms
+the District Court will be reversed. The
+of immunity agreement under United
+order of the District Court granting sum-
+States Department of Justice's (DOJ's)
+mary judgment on Counts Four and Seven
+corporate leniency program. The United
+will be affirmed as to all appellees, except
+States District Court for the Eastern Dis-
+Stern, with respect to whom the order will
+be reversed. The District Court's dismisstrict of Pennsylvania, Timothy J. Savage,
+al of Count Five on statute of limitations
+J., 352 F.Supp.2d 553, enjoined prosecugrounds will be affirmed," and the order tion, and government appealed.
+dismissing Count Six will be vacated. The
+Holding: The Court of Appeals, Ambro,
+cross-appeal will be dismissed.
+Circuit Judge, held that, on issue of first
+In sum, the following claims survive: a
+impression in circuit, district court lacked
+substantive due process facial challenge to authority to enjoin executive branch from
+the Ordinance; a substantive due process
+filing indictment.
+challenge to appellees' obstructive course Reversed and remanded.
+5. Appellants have not argued that the dismissal on Count Five should be reversed.
+
+
+178
+1. Federal Courts C-754.1, 814.1
+District court's grant or denial of permanent injunction is reviewed for abuse of
+discretion, while its underlying legal conclusions are reviewed without deference.
+law that is as complete, practical and efficient as that which equity could afford.
+2. Federal Courts 6-776
+R. Hewitt Pate, Assistant Attorney Gen-
+District court's determination of eral, Scott D. Hammond, Makan Delrahim,
+whether potential criminal defendant's co-
+Deputy Assistant Attorneys General, John
+een breached is legal conclusion, ne
+P. Fonte, John J. Powers, III, (Argued),
+United States Department of Justice, Antitrust Division, Washington, D.C., Robert
+E. Connolly, Antonia R. Hill, Wendy B.
+3. Injunction e-105(1)
+Although court generally lacks jurisdietion to enjoin criminal prosecution, exception exists when necessary to avoid
+chilling effect on First Amendment or similar constitutional rights. U.S.C.A. Const.
+Norman, Kimberly Justice, Richard S.
+Rosenberg, U.S. Department of Justice,
+Philadelphia, PA, for Appellant.
+Ian M. Comisky, Matthew D. Lee, Blank
+Rome LLP, Philadelphia, PA, George J.
+Terwillinger III, John M. Gidley, Christopher M. Curran, (Argued), Lucius B. Lau,
+4. Criminal Law 6=42.5(3), 273.1(2)
+White & Case LLP, Washington, D.C., for
+Government must adhere strictly to
+Appellee Stolt-Nielsen S.A. and Stoltterms of agreements made with defen-
+Nielsen Transportation Group Ltd.
+dants, including plea, cooperation, and im-
+Roberta D. Liebenberg, Allen D. Black,
+munity agreements, to extent they require (Argued), Gerard A. Dever, Fine, Kaplan
+defendants to sacrifice constitutional
+& Black, Philadelphia, PA, James A. Backrights.
+strom, Jr., Philadelphia, PA, for Appellee
+5. Injunction 6105(1)
+Richard B. Wingfield.
+District court lacked authority to enjoin indictment of corporation and officer
+Before ALITO * and AMBRO, Cireuit
+Judges and RESTANI,** Judge.
+for antitrust violations, despite claim that
+indictment would violate terms of immuni-
+AMBRO, Cireuit Judge.
+ty agreement entered into as part of government's corporate lenieney program;
+This case raises a significant constituthough agreement may have been defense
+tional question of first impression in this
+to conviction, it was not defense to indiet-
+Circuit: whether federal courts have authority, consistent with the separation of
+powers, to enjoin the executive branch
+6. Equity e-46
+from filing an indietment. Although feder-
+Suit in equity does not lie where there al courts have this authority in narrow
+is plain, adequate and complete remedy at circumstances, we conclude that this is not
+United States Court of International Trade,
+sitting by designation.
+2006. This opinion is filed by a quorum of
+the panel. 28 U.S.C. § 46(d).
+
+
+179
+Cite as 442 F.3d 177 (3rd Cir.
+such a case and therefore reverse the Dis- and the Government informed him that an
+trict Court's judgment to the contrary. investigation had already begun.
+Specifically, Nannes inquired about possible protection for Stolt-Nielsen and its
+A. Background
+officers under the Antitrust Division's Cor-
+Appellee Stolt-Nielsen, S.A., through its porate Leniency Policy. Under this Polisubsidiary Stolt-Nielsen Transportation cy, the Government agrees "not [to]
+Group Ltd. (collectively "Stolt-Nielsen" or chargle] a firm criminally for the activity
+the "Company"), is a leading supplier of being reported" if (in the case of an appliparcel tanker shipping services. In March cant who comes forward after an investiga-
+2002, Stolt-Nielsen's general counsel, Paul tion has begun) seven conditions are met:
+O'Brien, resigned. According to a com- (1) the applicant is the first to report the
+plaint O'Brien filed against Stolt-Nielsen illegal activity; (2) the Government does
+in Connecticut Superior Court in Novemnot, at the time the applicant comes forber 2002, and a subsequent article in The
+ward, have enough information to sustain a
+Wall Street Journal, O'Brien advised his
+conviction; (3) the applicant, "upon its dissuperiors of illegal collusive trading praccovery of the illegal activity being reporttices between Stolt-Nielsen and two of its
+ed, took prompt and effective action to
+competitors, and resigned after the Com- terminate its part in the activity"; (4) the
+pany failed to take action to resolve the
+applicant's report is made "with candor
+problem. On receiving O'Brien's Novemand completeness and provides full, conber 2002 complaint, Stolt-Nielsen hired
+tinuing and complete cooperation" with the
+John Nannes, a former Deputy Assistant
+Government's investigation; (5) the appli-
+Attorney General in the Antitrust Division
+cant confesses to illegal anticompetitive
+at the U.S. Department of Justice, to conconduct as a corporation and not merely
+duet an internal investigation of possible
+through individual confessions by corpoantitrust violations by the Company and
+rate officers; (6) the applicant makes restiadvise it regarding any criminal liability.
+tution where possible; and (7) the Govern-
+On November 22, 2002, Nannes met
+ment determines that granting leniency to
+with the chairman of Stolt-Nielsen's tankthe applicant would "not be unfair to other division, Samuel Cooperman. Cooperers." The officers and directors of the
+informed Nannes that O'Brien
+corporation who assist with the investiga-
+*rais(ed] some antitrust concerns" in early
+tion are considered for immunity from
+2002, and that in response Stolt-Nielsen
+prosecution on the same basis as if they
+revised its antitrust compliance policy and had come forward individually.
+disseminated it to its employees and competitors.
+Cooperman also told Nannes
+B. The Conditional Leniency Agreethat he believed an internal investigation
+ment
+would demonstrate that the Company was
+The Government informed Nannes that
+in violation of federal antitrust laws and Stolt-Nielsen would not be eligible for amasked Nannes about the possibility of le- nesty under the Corporate Leniency Poliniency from the Department of Justice. cy if O'Brien's departure was involuntary
+With Cooperman's permission, Nannes and due to his exposure of the Company's
+spoke with an Antitrust Division official antitrust violations. Nannes assured the
+later that day to inquire about amnesty if Government that O'Brien left voluntarily
+Stolt-Nielsen were to admit its violations, and detailed the changes to the Company's
+
+
+180
+antitrust policy that were implemented in
+response to O'Brien's concerns. During
+the ensuing investigation, Nannes learned
+that between 1998 and 2001 a Stolt-Nielmer director, officer, or employee of
+[Stolt-Nielsen] to the Antitrust Division
+pursuant to this Agreement, may be
+used against Stolt-Nielsen in any such
+sen executive, Andrew Pickering, exchanged customer allocation lists with two
+of Stolt-Nielsen's competitors, presumably
+he Agreement also provided that tr
+for the purpose of apportioning customers
+Government would not prosecute office
+and directors of the Company who "admit
+among the companies and restraining competition. In January 2003, Pickering's their knowledge of, or participation in, and
+successor, appellee Richard Wingfield, fully and truthfully cooperate with the An-
+provided Nannes with four such lists, titrust Division in its investigation of the
+which confirmed that Stolt-Nielsen had in. anticompetitive activity being reported."
+deed engaged in illegal anticompetitive be-
+Specifically, that cooperation entailed: (1)
+havior. Nannes promptly turned these
+producing all documents and records relists over to the Government, which enquested by the Government; (2) being
+tered into a Conditional Leniency Agreeavailable for Government interviews; (3)
+ment (the "Agreement") with Stolt-Niel-
+"responding fully and truthfully to all insen on January 15, 2008.
+quiries of the [Government] ... without
+Under the terms of the Agreement, the
+falsely implicating any person or intention-
+Government agreed "not to bring any
+ally withholding any information"; (4) volcriminal prosecution against [Stolt-Nieluntarily providing any information or masen] for any act or offense it may have
+terials not requested by the Government
+committed prior to the date of this
+that were nonetheless relevant to the in-
+[Agreement] in connection with the antivestigation; and (5) testifying under oath
+competitive activity being reported." This
+when asked by the Government. It conpromise was, of course, subject to Stoltcluded with a standard integration clause:
+Nielsen's strict compliance with the afore-
+"This letter constitutes the entire agreementioned conditions, "[s]ubject to verifiment between the [parties], and supercation [by the Government] and subject to
+sedes all prior understandings, if any,
+[Stolt-Nielsen's] full, continuing and comwhether oral or written, relating to the
+plete cooperation." The Agreement fursubject matter herein."
+ther stated:
+Using the information provided by
+If the Antitrust Division at any time
+Stolt-Nielsen and its executives (including
+determines that [Stolt-Nielsen] has vio-
+Wingfield), the Government secured guilty
+lated this Agreement, [it] shall be pleas from Stolt-Nielsen's co-conspirators,
+void.... Should the Antitrust Division
+resulting in prison sentences for individual
+revoke the conditional acceptance of executives at those companies and fines
+may thereafter initiate a criminal prosecution against [Stolt-Nielsen], without
+limitation. Should such a prosecution be
+initiated, any documentary or other in-
+In the weeks following execution of the
+formation provided by [Stolt-Nielsen), Agreement, the Government's investigaas well as any statements or other infor- tion revealed that Stolt-Nielsen's particmation provided by any current or for- ipation in the conspiracy persisted for
+
+
+181
+several months after O'Brien raised his D. District Court Proceedings
+concerns to Cooperman in early 2002 Shortly before the Government revoked
+The Government concluded that Stolt- Stolt-Nielsen's conditional leniency, the
+tinueen, collude unlavily artiu lar, coti Company and Wingfield filed complaints in
+tinued to collude unlawfully with competi.
+tors until November 2002. Based on this
+the United States District Court for the
+information, the Government informed Eastern District of Pennsylvania seeking
+enforcement of the Agreement and an in-
+Nannes on April 8, 2003 that it was suspending Stolt-Nielsen's obligations under Junetion preventing the Government from
+the Agreement and considering withdrawfiling indietments against them. The Goving the grant of conditional leniency en- ernment agreed to postpone its indietments of both parties pending the District
+tirely because the Company did not take
+"prompt and effective action to terminate
+Court's consideration of the complaints.
+its part in the anticompetitive activity be-
+The District Court bifurcated the proing reported upon discovery of the activiceedings into two phases. In Phase
+ty," as required by the Agreement. One
+the Court considered whether
+of Wingfield's subordinates, Bjorn Jansen,
+Stolt-Nielsen's alleged conduct between
+then admitted that the anticompetitive
+March and November 2002 violated the
+agreement between Stolt-Nielsen and its
+terms of the Agreement.
+If so, Phase
+competitors was still in place in the fall of
+Two would determine whether the con-
+2002, despite having told Nannes that
+duet actually occurred. During the
+such conduct ceased in March 2002 once
+Phase One proceedings, the District
+the Company learned of O'Brien's allega-
+Court consolidated consideration of Stolttions and issued its new antitrust policy.
+Nielsen's and Wingfield's requests for
+In June 2003, the Government concluded
+preliminary injunctions with the trial on
+that Wingfield had not fulfilled his oblithe merits, and heard testimony from
+Nannes and James Griffin, a Deputy As-
+gations under the Agreement because he
+sistant Attorney General in the Antitrust
+never informed the Government that his
+Division at the Department of Justice.
+unlawful communications with Stolt-Nielsen's competitors did not cease in March
+In January 2005, the District
+2002 when Stolt-Nielsen issued its new
+granted judgment in favor of Stolt-Nielsen
+antitrust policy. On June 24, 2003, the
+and Wingfield and permanently enjoined
+Government charged Wingfield by criminal
+the Government from indicting either of
+complaint with violating the Sherman Act,
+them for violations of the Sherman Act.
+15 U.S.C. § 1. The Government withdrew
+See Stolt-Nielsen S.A. v. United States,
+its grant of conditional leniency to Stolt-
+352 F.Supp.2d 553 (E.D.Pa.2005). The
+Nielsen on March 2, 2004, and announced
+Court concluded that the Government
+that it intended to indiet the Company and
+could not unilaterally rescind the Agree-
+Wingfield for violations of the Sherman
+ment without a judicial determination that
+Stolt-Nielsen and Wingfield breached it,
+be instituted by a complaint, this only perits issuance of a warrant for the arrest o
+e offender, and he cannot be tried unles
+an indictment or information, as the case
+may require, is brought against him.").
+1999) ("Although a criminal proceeding may
+
+
+182
+an issue appropriate for consideration before indictment "because if an indictment
+nated itself when it delivered the evidence DOJ used to accomplish its goals.
+were later determined to have been Id
+wrongfully secured, it would be too late to
+prevent the irreparable consequences."
+Id. at 560. The Court further found that
+the Agreement did not specify a discovery
+On appeal, the Government contends
+date and instead granted amnesty for activity before January 15, 2003, the date on
+which it was signed. Indeed, it found that
+branch from filing an indictment. Second,
+*the date when [Stolt-Nielsen] ended its
+it asserts that the District Court erred ir
+participation [in the conspiracy] was never
+holding that Stolt-Nielsen's and Wing
+clearly established," id. at 562 n. 10, and
+therefore, in light of the Agreement's integration clause, "DOJ, especially because it
+drafted the agreement, cannot depend
+upon a tacit understanding of what it contends was meant [to be the discovery date]
+ber 2002 did not violate the terms of the
+Agreement. For the reasons that follow,
+the District Court's judgment is reversed
+and the case remanded to that Court so
+that it may dismiss the appellees' combut was not memorialized in the integrated
+agreement." Id. at 562. The Court con-
+The agreement immunizes [Stolt-
+Nielsen] from prosecution for activity
+We review a Distriet Court's
+prior to January 15, 2003. Now DOJ
+grant or denial of a permanent injunction
+contends the activity had to have
+for abuse of discretion, United States u
+stopped at an earlier unspecified date
+Bell, 414 F.3d 474, 478 (3d Cir.2005), but
+that is not set forth in the agreement.
+exercise plenary review over the District
+Had it wanted to fix the date sometime
+underlying legal conclusions.
+before January 15, 2003, it could have
+Freethought Socy of Greater Phila, u.
+replaced the words "to the date of this
+Chester County, 334 F.3d 247, 255-56 (3d
+letter" with the earlier date it now con-
+Cir.2003). A District Court's determinatends the parties contemplated.
+tion whether a cooperation agreement has
+been breached is a legal conclusion. Unit-
+... [The Government's) goals [in con- ed States v. Baird, 218 F.3d 221, 229 (3d
+cluding the Agreement with Stolt-Niel- Cir.2000). All findings of fact are resen] were to pursue (Stolt-Nielsen's] co- viewed for clear error. See Bell, 414 F.3d
+conspirators and break up the conspira- at 478 (reviewing findings of fact related to
+cy. It got what it had bargained for in a permanent injunction for clear error);
+the agreement....
+Now that it has Baird, 218 F.3d at 229 (reviewing findings
+received the benefit of the bargain, DOJ of fact related to a cooperation agreement
+cannot prosecute the party that incrimi- for clear error).
+2. The District Court had jurisdiction over this
+case under 28 U.S.C. § 1331, as it is a civil
+action arising under the laws of the United
+States. Our jurisdiction arises under 28
+.S.C. § 1291, since the Government filed
+nely notice of appeal from a final decisi
+of the District Court.
+
+
+183
+III.
+the case different. The chilling effect
+[3] The Supreme Court has observed
+upon the exercise of First Amendment
+that the executive branch "has exclusive
+rights may derive from the fact of the
+authority and absolute discretion to decide
+prosecution, unaffected by the prospects
+whether to prosecute a case," United
+of its success or failure.
+States v. Nixon, 418 U.S. 683, 693, 94 S.Ct.
+Dombrowski, 380 U.S. at 486-87, 85 S.Ct.
+3090, 41 L.Ed.2d 1039 (1974), and the Gov-
+1116, 14 L.Ed.2d 22 (1965); see also Ashernment therefore argues that courts lack
+croft v. ACLU, 542 U.S. 656, 670-71, 124
+jurisdiction to enjoin a criminal prosecu-
+S.Ct. 2783, 159 L.Ed.2d 690 (2004) (upholdtion. See United States v. Cox, 342 F.2d
+ing preliminary injunction against criminal
+167, 171 (5th Cir.1965) (en banc) ("It folenforcement of the Child Online Protection
+lows, as an incident of the constitutional
+Act because, inter alia, "[where a proseseparation of powers, that the courts are
+cution is a likely possibility, yet only an
+not to interfere with the free exercise of
+affirmative defense is available, speakers
+the discretionary powers of the attorneys
+may self-censor rather than risk the perils
+of the United States in their control over
+criminal prosecutions.").
+[4] It is also well established that the
+Government must adhere strictly to the
+There is an exception to this general
+terms of agreements made with defenrule, however, in order to avoid a chilling
+dants—including plea, cooperation, and imeffect on constitutional rights.
+See Dommunity agreements—to the extent the
+browski v. Pfister, 380 U.S. 479, 486-87, 85
+agreements require defendants to sacrifice
+S.Ct. 1116, 14 L.Ed.2d 22 (1965) (recognizconstitutional rights.
+See, e.g., Santobello
+ing that the threat of criminal prosecution
+u New York, 404 U.S. 257, 262, 92 S.Ct.
+creates the potential for a serious chill
+495, 30 L.Ed.2d 427 (1971); United States
+upon First Amendment rights); Hynes v.
+Grimes Packing Co., 337 U.S. 86, 98-99, 69
+v. Hodge, 412 F.3d 479, 485 (3d Cir.2005)
+("The government must adhere strictly to
+S.Ct. 968, 98 L.Ed. 1281 (1949) (recognizing that the threat of prosecution
+may
+the terms of the bargains it strikes with
+defendants. Because defendants entering
+deny fishermen the right to earn a livelipleas forfeit a number of constitutional
+hood; Truax t. Raich, 239 U.S. 33, 38-39,
+rights, courts are compelled to scrutinize
+36 S.Ct. 7, 60 L.Ed. 131 (1915) (recognizing
+closely the promise made by the governthat the threat of prosecution may lead to
+ment in order to determine whether it has
+an unconstitutional denial of the right to
+been performed." (citation and internal
+earn a livelihood and to continue employquotation marks omitted)).
+ment). The Supreme Court has typically
+Therefore, although the Government is
+applied the exception in the First Amendcertainly correct that there is no freement context, and in such cases has recogranging jurisdiction on the part of courts
+nized,
+to enjoin criminal prosecutions, that aual criminal prosecution under a stat- thority does exist in limited situation
+te regulating expression usually in- where the mere threat of prosecutio
+volves imponderables and contingencies would inhibit the exercise of constitutional
+that themselves may inhibit the full ex- freedoms. Federal courts also have jurisercise of First Amendment free- dietion to consider, and hold the Governdoms... The assumption that defense ment to, the terms of agreements it makes
+of a criminal prosecution will generally with defendants. The question thus beassure ample vindication of constitution- comes whether, even when there is no risk
+al rights is unfounded in such cases....
+of a chilling effect on constitutional rights,
+[Wle have not thought that the improba- the existence of an immunity agreement
+bility of successful prosecution makes provides federal courts with authority to
+
+
+enjoin a federal criminal prosecution in criminally prosecute a defendant, like the
+order to avoid the filing of an indictment.
+agreement at issue in this case, have like-
+The District Court relied on a Seventh
+wise been construed to protect the defen-
+Circuit case, United States v. Meyer, 157
+dant against conviction rather than indict-
+F.3d 1067 (7th Cir.1998), as authority for
+ment and trial. See, e.g., Heike v. United
+conducting a pre-indietment review of the
+States, 217 U.S. 423, 431, 30 S.Ct. 539, 54
+Agreement before us. See Stolt-Nielsen,
+L.Ed. 821 (1910) (construing the Sherman
+352 F.Supp.2d at 560-61. In Meyer, the
+Act's immunity provision, which protected
+Seventh Circuit stated, in dicta, that "the
+a testifying witness from being "prosecutpreferred procedure, absent exigent cired," see Act of Feb. 25, 1903, ch. 755, $ 1,
+cumstances, would be for the government
+32 Stat. 854, 904 (repealed 1970), "not ...
+to seek relief from its obligations under
+to secure to a person making such a plea
+the immunity agreement prior to indietimmunity from prosecution, but to provide
+ment. Since the government is required
+him with a shield against successful proseto obtain a judicial determination of a decution, available to him as a defense");
+fendant's breach prior to trial, it is but a
+de minimis inconvenience for the govern-
+United States v. Bailey, 34 F.3d 683, 690-
+91 (8th Cir.1994) (holding that an agreement to secure that determination prement "not to prosecute" protected the deindictment."
+157 F.3d at 1077.
+fendant from "the inherent risk of convic-
+We have no quarrel with the Seventh
+tion and punishment as a result of the
+Circuit's observation that, in many circumstances, a pre-indictment determination of
+trial, not the trial itself'); United States v.
+Bird, 709 F.2d 388, 392 (5th Cir.1983)
+the parties' obligations under an immunity
+("While the agreement is phrased in terms
+agreement might be useful. We point out,
+of nonprosecution, its essence is a promise
+however, that no federal court (including
+the Seventh Circuit) has held that a preof immunity. [The defendant's] immunity
+indictment determination is constitutionalfrom punishment will not be lost simply
+because she is forced to stand trial.").
+ly required. Indeed, notwithstanding its
+dicta regarding the *preferred procedure."
+This distinetion is grounded in the unthe Meyer Court held the defendant was
+derstanding that simply being indicted and
+constitutionally "entitled to a judicial deforced to stand trial is not generally an
+termination of his breach before being deinjury for constitutional purposes but is
+prived of his interest in the enforcement of
+rather "one of the painful obligations of
+an immunity agreement," and that this
+citizenship." Cobbledick v. United States,
+"interest" was in not being convicted, rath-
+309 U.S. 323, 325, 60 S.Ct. 540, 84 L.Ed.
+er than not being indicted.
+783 (1940); see Deaver . Seymour, 822
+77.3 As the Court noted, "a post-indict-
+F.2d 66, 69 (D.C.Cir.1987) ("Although it is
+ment evidentiary hearing on the defensurely true that an innocent person may
+dant's alleged breach was sufficient to satsuffer great harm to his reputation and
+isfy due process." Id. at 1076 (citing property by being erroneously accused of a
+United States v. Verrusio, 803 F.2d 885,
+crime, all citizens must submit to a crimi-
+889 (7th Cir.1986)).
+nal prosecution brought in good faith so
+[5] Other immunity agreements that that larger societal interests may be prehave promised not to charge or otherwise served.").* As the District of Columbia
+3. In keeping with the case law discussed below, the Seventh Circuit reached this conclusion despite the fact that the immunity agreement before it stated that the Government
+would not "charge" the defendant. Meyer,
+157 F.3d at 1077.
+4. We do not address in this opinion those
+circumstances in which equity might serve to
+enjoin an ultra vires prosecution brought in
+bad faith. The Supreme Court has only approved federal injunctions against state criminal proceedings on that basis. See Younger v.
+Harris, 401 U.S. 37, 55, 91 S.Ct. 746, 27
+L.Ed.2d 669 (1971) (noting that, although
+"the possible unconstitutionality of a statute
+'on its face' does not in itself justify an injunc-
+
+
+185
+Circuit noted in Deaver, in the absence of the Government's authority to proceed
+a chilling effect on constitutional rights, with a prosecution, for example, the Su-
+the adversary system "afford[s] defen- preme Court has allowed those appeals
+dants, after indictment, a federal forum in only in very limited circumstances. For
+which to assert their defenses-including example, the Double Jeopardy Clause, see
+those based on the Constitution. Because U.S. Const. amend. "INJor shall any
+these defendants are already guaranteed
+person be subject for the same offense to
+access to a federal court, it is not surpris- be twice put in jeopardy of life or limb
+ing that subjects of federal investigation …..."), protects interests that are "wholly
+have never gained injunetive relief against
+unrelated to the propriety of any subsefederal prosecutors." 822 F.2d at 69-70.*
+quent conviction," in that it provides a
+Although this interpretation of agree- "guarantee against being twice put to trial
+ments "not to prosecute" may seem counfor the same offense." Almey u. United
+terintuitive, it comports with the federal
+States, 431 U.S. 651, 661, 97 S.Ct. 2034, 52
+courts' general reluctance to recognize a
+L.Ed.2d 651 (1977) (emphasis added). Be-
+right not to be indieted or tried in the
+cause the prohibition against double jeopabsence of an express constitutional (or
+ardy affords a defendant the right to
+perhaps statutory) command. In the con-
+"contest ] the very authority of the Govtext of interlocutory appeals challenging
+ernment to hale him into court to face
+tion against [a state's] good-faith attempts to
+enforce it."
+"showing of bad faith [or]
+harassment" might "justify federal intervention"); see also Howard W. Brill, Equity and
+the Criminal Law, 2000 Ark. L. Notes 1, 3-4
+(noting that state courts have sometimes used
+injunctions to prevent bad-faith prosecutions,
+such as those brought solely to "harass and to
+retaliate for the exercise
+of constitutional
+rights,
+" or where the prosecutor charges conduct that is not illegal).
+As our precedent
+makes clear, however, in the absence of
+state
+prosecution,
+federal-state abstention
+doctrine is irrelevant and Younger does not
+apply. Pic-A-State Pa., Inc. | Reno, 76 F.3d
+1294, 1300 (3d Cir.1996).
+Moreover, even if
+the principles of Younger or the willingness of
+certain state courts to entertain injunctions
+against bad-faith or illegal prosecutions could
+be applied to a federal prosecution, we perceive no bad faith on the part of the Government in this case; rather, the parties are
+engaged merely in a good-faith dispute over
+the meaning of the Agreement.
+properly be considered in deciding upon a
+permanent (as opposed to preliminary) injunction-which is a matter of some tension
+in our case law, compare Chao v. Rothennel,
+327 F.3d 223, 228 (3d Cir.2003) (stating that
+a permanent injunction may be granted
+"where the moving party has demonstrated
+that: (1) the exercise of jurisdiction is appropriate; (2) the moving party has actually succeeded on the merits of its claim; and (3) the
+'balance of equities' favors granting injunctive
+relief"), and ACLU of N.J. | Black Horse Pike
+Reg'1 Bd. of Educ., 84 F.3d 1471, 1477 nn. 2-3
+(3d Cir. 1996) (en banc ) (noting that a preliminary injunction requires consideration of, inter alia, irreparable injury, while a permanent
+injunction merely requires consideration of
+5. We note that the District Court's finding
+that Stolt-Nielsen and Wingfield would be
+irreparably harmed by an indictment does not
+bring this case within the ambit of the cases
+in which injunctions against indictment and
+trial have been approved. Even assuming
+that irreparable harm is a factor that may
+(stating that a court may grant a permanent
+injunction if it finds, inter alia, that "the moving party will be irreparably injured by the
+denial of injunctive relief" (citing Black Horse
+Pike, 84 F.3d at 1477 nn. 2-3))—we note that,
+as stated above, other courts have not accepted the argument that the unpleasantness of an
+indictment brought in good faith constitutes
+an injury that may be remedied by a preindictment injunction, and neither have we.
+
+
+186
+trial on the charge against him," it neces- the provision of a new trial free of prejudisitates an exception to the "firm congres- cial error normally are adequate means of
+sional policy against interlocutory or vindicating the constitutional rights of the
+'piecemeal' appeals." Id. at 656, 659, 97 accused"); Parr v. United States, 351 U.S.
+S.Ct. 2034. Likewise, the Speech and De- 513, 519, 76 S.Ct. 912, 100 L.Ed. 1377
+bate Clause, see U.S. Const. art. I, § 6, cl. (1956) (holding that the mere fact a defen-
+1 ("[Flor any speech or debate in either dant would have to "hazard a trial" in one
+House, [members of Congress] shall not venue before challenging the District
+be questioned in any other Place."), has Court's order transferring his case from a
+been construed "to protect Congressmen different venue did not warrant an internot only from the consequences of litiga- locutory appeal); of United States v.
+tion's results but also from the burden of P.H.E., Inc., 965 F.2d 848, 855 (10th Cir.
+defending themselves," thus allowing in-
+1992) (noting that, in comparing the vindicterlocutory appeals from denials of claims
+tive prosecution claim in Hollywood Motor
+of immunity under that Clause. Helstoski
+Car to a vindictive prosecution claim based
+v. Meanor, 442 U.S. 500, 508, 99 S.Ct.
+on the defendants' dissemination of consti-
+2445, 61 L.Ed.2d 30 (1979) (internal quotatutionally protected speech,
+"[t]he wrong
+tion marks omitted).
+alleged is similar, but the right sought to
+Our case is not an interlocutory appeal,
+be vindicated is not" because the "procebut the Supreme Court's cases in that field
+dural rule [at issue in Hollywood Motor
+are instructive because they reinforce the
+Car ] raises concerns distinet from and less
+narrowness of a defendant's ability to chalpressing than the courts' obligation to prolenge the Government's decision to pursue
+tect the First Amendment right not to be
+a prosecution. Just as the authority to
+subjected to a pretextual prosecution").
+enjoin criminal enforcement of a law regu-
+Indeed, when a district court rejects prior
+lating speech is grounded in the overriding
+to trial a defendant's contention that an
+need to avoid a chilling effect on the exerimmunity agreement bars his conviction,
+cise of core constitutional rights, so too
+the defendant may not avail himself of an
+does the right not to be prosecuted recoginterlocutory appeal challenging that decinized in Abney and Helstoski stem from
+sion; rather, "the availability of dismissal
+express textual commands in the Constituafter final judgment will adequately protect and secure for the defendant the bention that prohibit any interference with the
+rights against double jeopardy or of memefit of his bargain under the nonprosecubers of Congress to speak freely in legislation agreement if he is entitled to it."
+Bailey, 34 F.3d at 691; see Bird, 709 F.2d
+at 392 (same).
+In other contexts, however, courts have
+refused to allow interlocutory appeals to Here, Stolt-Nielsen and Wingfield may
+stop prosecutions. See, e.g., United States interpose the Agreement (as a defense to
+v. Hollywood Motor Car Co., 458 U.S. 263, conviction) in a pre-trial motion. See, e.g.,
+268, 102 S.Ct. 3081, 73 L.Ed.2d 754 (1982) Meyer, 157 F.3d at 1077 ("In accordance
+(per curiam) (holding that a vindictive with due process, [the defendant] was entiprosecution claim may not be raised in an tled to a judicial determination that he had
+interlocutory appeal to stop an ongoing breached the agreement before being subprosecution, but rather may only be raised jected to the risk of conviction. The disafter the defendant has been convicted, trict court's pretrial [but post-indictment]
+because "reversal of the conviction and ...
+evidentiary hearing satisfied this require-
+
+
+STOLT-NIELSEN, S.A. _ U.S.
+187
+ment.")." But their contention that the cases in which the very act of filing an
+immunity they purportedly received under indietment may chill constitutional rights,
+the Agreement precludes an indietment in this case does not implicate that concern.
+the first place is belied by precedent, and Instead, we are guided by other cases
+we see no compelling reason to reach a from the Supreme Court and Courts of
+Appeals that lead us to conclude that non-
+*
+*
+*
+prosecution agreements may not form the
+[6] "[A] suit in equity does not lie
+basis for enjoining indictments before they
+where there is a plain, adequate and complete remedy at law ... [that is] as complete, practical and efficient as that which
+equity could afford." Terrace v. Thompson, 263 U.S. 197, 214, 44 S.Ct. 15, 68
+L.Ed. 255 (1923). Here, Stolt-Nielsen and
+Wingfield have a practical and efficient—
+and indeed complete-legal remedy available to them, że., access to a federal forum
+In this context, we conclude that the
+District Court lacked authority to employ
+the extraordinary remedy of enjoining the
+Government's indictments of Stolt-Nielsen
+and Wingfield. The judgment is therefore
+reversed and the case remanded with the
+instruction that the District Court dismiss
+their complaints with prejudice.?
+post-indietment in which they may assert
+the Agreement as a defense. Separationof-power concerns thus counsel against using the extraordinary remedy of enjoining
+the Government from filing the indietments. Although courts have carved out a
+narrow exception to this rule in those
+indictment claims that immunity agreements
+barred conviction, and as such were not concerned with the timing of the claims in the
+district court. In any event, it is not in the
+interest of defendants or the Government,
+once an indictment has been issued, to proceed with a trial before determining whether
+an immunity agreement bars conviction. We
+therefore agree with the Seventh Circuit that
+a pre-trial hearing is appropriate in these
+circumstances. We note, however, that this
+timing is not essential, and a defendant may
+raise an immunity agreement as a defense
+during the trial.
+7. Because we conclude that the District Court
+lacked the power to enjoin the filing of indictments in this case, we do not consider, at this
+stage, the Government's alternative argument
+that the District Court inappropriately concluded that Stolt-Nielsen's and Wingfield's
+actions between March and November 2002
+did not violate the terms of the Agreement.
+As stated, the District Court's lack of authority compels us to reverse the judgment and
+remand to that Court so that it may dismiss
+the complaints. Because the judgment is reversed, it lacks preclusive effect.
+See, e.g..
+loseph A. ex rel. Wolfe || Ingram, 275 F.3d
+1253, 1266 (10th Cir.2002) ("A judgment that
+has been vacated, reversed, or set aside on
+appeal is thereby deprived of all conclusive
+effect, both as res judicata and as collateral
+estoppel." (internal quotation marks omitted)). Therefore, if the appellees assert the
+Agreement as a defense after they are indicted, the District Court must consider the
+Agreement anew and determine the date on
+which Stolt-Nielsen discovered its anticompetitive conduct, the Company's and Wingfield's subsequent actions, and whether, in
+light of those actions, Stolt-Nielsen complied
+with its obligation under the Agreement to
+take "prompt and effective action to termi-
+
+
+188
+1. Federal Courts 6-817
+Earle B. GREGORY; Ken Blinko; Bet-
+District court's class certification decity C. Coley; Vicki Grainger; Ethel E. sion is reviewed for abuse of discretion.
+Graves; Becky Halsall; John S. Hal- Fed.Rules Civ.Proc.Rule 28, 28 U.S.C.A.
+sall, III; Jerry F. MeDaniel; Veronica
+T. MeDaniel; Laverne MeKenzie;
+Marianne MeKenzie; Nathan J. Neely;
+Zevie H. Neely; Sulina Prather; Ka- burden of proving entitlement to same.
+thryn Roddey; Gina Tibbs; John A. Fed.Rules Civ.Proc.Rule 23, 28 U.S.C.A.
+Tibbs; John C. Tibbs; Brenda D.
+Watts; Gerald D. Watts; C. Ann
+Williams; Henry M. Williams, Ir;
+Class certification of noteholders secu-
+Wesley L. Williams, Jr.; Grant |
+rities fraud claims against now-bankrupt
+Tom Moore; Anna Nunnery; Charles
+issuer's principal lender was abuse of dis-
+Shope; Penelope Shope; Kathy An-
+cretion, absent showing that class action
+nette Wood; Sam Jones Wood; Ruth
+was superior method for fair and efficient
+, Plaintiffs-Appellees,
+adjudication of controversy; same claims
+were already pending against lender in
+bankruptey adversary proceeding.
+Rules Civ.Proc.Rule 23(b)(3), 28 U.S.C.A.
+FINOVA CAPITAL CORPORATION,
+Defendant-Appellant.
+No. 05-2118.
+United States Court of Appeals,
+Fourth Circuit.
+ARGUED: Daniel P. Shapiro, Goldberg.
+Kohn, Bell, Black, Rosenbloom & Moritz,
+Ltd, Chicago, Illinois, for Appellant. Gil-
+Argued Feb. 2, 2006.
+bert Scott Bagnell, Bagnell & Eason,
+Decided March 14, 2006.
+L.L.C., Columbia, South Carolina, for Ap-
+pellees. ON BRIEF: Elizabeth Van Dor-
+Background: Noteholders filed class action securities fraud suit against nowen Gray, Allen J. Barnes, Sowell, Gray,
+bankrupt issuer's principal lender. The
+Stepp & Laffitte, P.L.L.C., Columbia,
+South Carolina; Steven A. Levy, Andrew
+United States District Court for the Dis- R. Cardonick, Goldberg, Kohn, Bell, Black,
+trict of South Carolina, Gi. Anderson, Rosenbloom & Moritz, Ltd, Chicago, IlI-
+Jr., J., certified class, and lender appealed.
+Holding: The Court of Appeals, Luttig, Randall Hood, MeGowan, Hood, Felder &
+Circuit Judge, held that class action was Johnson, Rock Hill, South Carolina;
+not superior method for fair and efficient Randall M. Eason, Bagnell & Eason,
+adjudication of controversy.
+L.L.C., Lancaster, South Carolina, for Ap-
+Reversed.
+pellees.
+King, Circuit Judge, concurred in part,
+Before WIDENER, LUTTIG, and
+dissented in part, and filed opinion.
+KING, Circuit Judges.
+nate its part in the anticompetitive activity
+being reported upon discovery of the activity."
+
+
+
+Not Reported in F.Supp.2d, 2007 WL 1113646 (M.D.Pa.)
+(Cite as: 2007 WL 1113646 (M.D.Pa.))
+Only the Westlaw citation is currently available.
+United States District Court,
+M.D. Pennsylvania.
+Michael Curtis REYNOLDS, Petitioner
+John GURGANUS, Prosecutor, Respondent.
+Civil No. 4:CV-07-675.
+April 12, 2007.
+Michael Curtis Reynolds, Scranton, PA, pro se.
+Hamburg, PA, forrespondes. Attorey's Office,
+MEMORANDUM
+JAMES F. McCLURE, JR., United States District
+Judge.
+Background
+*1 Michael Curtis Reynolds ("Petitioner"), an
+inmate presently confined in the Lackawanna
+County Prison, Scranton, Pennsylvania initiated this
+pro se petition for a writ of habeas corpus pursuant
+to 28 U.S.C. § 2241. Reynolds' petition is
+accompanied by an in forma pauperis application.
+For the reasons set forth below, Reynolds' petition
+will be dismissed as meritless.
+testimony was presented before the grand jury. As
+criminal charges and ease.
+seeks reversal of his federa
+Discussion
+Rule 4 ("Preliminary Consideration by the Judge")
+i the Rules Governing Section 2254 Cases in tl
+nited States District Courts, 28 U.S.C. foll. § 22:
+(1977) (applicable to § 2241 petitions under Rule
+copus pets see dism Pator 2241m 491
+corpus petition.. See, e.g., Patton
+F.Supp. 156, 158-59 (M.D.Pa. 1979). A judge may
+enter summary dismissal "li]f it plainly appears
+from the face of the petition and any exhibits
+annexed to it that the petitioner is not entitled to
+relief in the district court." Dismissal under Rule 4
+is appropriate "when the petition is frivolous, or
+obviously
+lacking in merit, or where
+iself say files fan erie 2 in Mis 49, 424
+F.2d 134, 141 (6th Cir.), cert. denied, 400 U.S. 906,
+*1 S.Ct. 147, 27 L.Ed.2d 143 (1970). Accord Love
+- Butler, 952 F.2d 10, 15 (1 st Cir.1991).
+Named as sole Respondent is Assistant United
+States Attorney John Gurganus of the Middle
+District of Pennsylvania. This is the latest in a series
+of civil rights complaints and habeas corpus
+petitions filed by Reynolds which challenge the
+gality of his ongoing federal criminal prosecutio
+n this district. See United States | Reynolds, Cast
+No. 3:05-CR-493. AUSA Gurganus is the
+prosecuting attorney. In his petition, Reynolds
+reasserts his previous claims that there has been a
+violation of his speedy trial rights and perjured
+As repeatedly noted by this Court, Reynolds has
+not yet been convicted or even tried of the federal
+criminal offenses underlying this action. [FN1] The
+Court of appeals for the Third circuit has observed
+that, "simply being indicted and forced to stand
+trial is not generally an injury for constitutional
+purposes but is rather
+one of the painfu
+obligations of citizenship." Stolt-Nielsen, $ .A.
+United States, 442 F.3d 177, 184 (3d Cir.2006)
+(internal citation omitted). More importantly, in
+Stolt-Nielsen, the Court of Appeals indicated that a
+habeas corpus petition should not be entertained
+where the applicant has an available forum in which
+federal criminal charges.
+See side at 185; Deas Y Seymour, 822 F.2d 66,
+69-70 (D.C.Cir.1987). Clearly, the Petitioner has an
+available and adequate remedy at law. Specifically,
+he may assert his present claims as well as any
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGo... 12/27/2007
+
+
+
+Not Reported in F.Supp.2d, 2007 WL 1113646 (M.D.Pa.)
+(Cite as: 2007 WL 1113646 (M.D.Pa.))
+ditional defenses/arguments before the judg
+esiding over his ongoing federal crimin
+proceedings.
+FN1. Petitioner's federal criminal trial is
+presently scheduled for May 29, 2007.
+*2 Furthermore, even if convicted of the pending
+federal criminal charges, the appropriate avenue for
+Reynolds to pursue his present arguments would be
+via a direct appeal, and if not successful therein, to
+then seek collateral relief under 28 U.S.C. § 2255.
+As Petitioner has been previously told, it is simply
+not appropriate for this Court to entertain his claims
+of speedy trial violation and perjured grand jury
+testimony via a pre-trial federal habeas corpus
+petition. If Reynolds wishes to pursue his present
+arguments, he must do so in his ongoing federal
+prosecution, or thereafter before the Court of
+Appeals. The petition for writ of habeas corpus will
+be denied. An appropriate Judgment will enter.
+ORDER
+In accordance
+with
+accompanying
+Memorandum, IT IS HEREBY ORDERED
+THAT:
+1. Petitioner is granted leave to proceed in forma
+pauperis for the sole purpose of the filing of this
+action.
+2. Reynolds' habeas corpus petition is DENIED.
+3. The Clerk of Court is directed to close the case.
+4. Based on the Court's determination herein, ther
+is no basis for the issuance of a Certificate of
+Appealability.
+Not Reported in F.Supp.2d, 2007 WL 1113646
+(M.D.Pa.)
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGo... 12/27/2007
+
+
+
+173 Fed.Appx. 840
+173 Fed.Appx. 840, 2006 WL 592928 (C.A.D.C.)
+(Cite as: 173 Fed.Appx. 840)
+H
+Miranda |. Gonzales
+C.A.D.C.,2006.
+This case was not selected for publication in the
+Federal Reporter. Please use FIND to look at the
+applicable circuit court rule before citing this
+opinion. District of Columbia Circuit Rule 28(c).
+(FIND CTADC Rule 28.)
+United States Court of Appeals,District of
+Columbia Circuit.
+Manuel A. MIRANDA, Appellant
+V.
+Alberto GONZALES, et al. Appellees.
+No. 05-5066.
+Feb. 16, 2006.
+Rehearing En Banc Denied May 11, 2006.
+Background: Plaintiff filed complaint for
+injunctive and declaratory relief, seeking prevention
+of any criminal investigation related to past conduct
+as Senate aide and to immunize him from future
+prosecution. United States District Court for
+District of Columbia dismissed complaint, and
+plaintiff appealed.
+Holdings: The Court of Appeals held that:
+(1) plaintiff was not entitled to injunetive relief, and
+(2) denial of request for declaratory judgment was
+not abuse of discretion.
+212k105(1) k. In General. Most Cited
+Cases
+Plaintiff was not entitled to injunctive relief to
+revent criminal investigation related to pas
+conduct as Senate aide and to immunize him fron
+future prosecution; if indicted, plaintiff could
+protect his rights under First Amendment and raise
+defense under Speech and Debate Clause of federal
+criminal procedure rules. U.S.C.A. Const.Amend. 1
+; Fed.Rules Cr.Proc.Rule 12(b), 18 U.S.C.A.
+[2] Declaratory Judgment 118A €-84
+118A Declaratory Judgment
+118AIl Subjects of Declaratory Relief
+118AII(A) Rights in General
+118Ak84 k. Criminal Laws. Most Cited
+Cases
+Denial of request for declaratory relief with respect
+to complaint to prevent criminal investigation into
+plaintiff's past conduct as Senate aide and to
+immunize plaintiff from future prosecution was not
+abuse of discretion, absent showing of special
+circumstances,
+given considerations of
+practicality
+judicial administration.
+U.S.C.A. § 2201(a); Fed.Rules Civ.Proc.Rule 57,
+28 U.S.C.A.
+*841 Appeal from the United States District Court
+for the District of Columbia.
+Arthur Duncan McKey, Hanson & Molloy, Adam
+Affirmed.
+West Headnoter
+[1] Injunction
+€-105(1)
+Before:
+and ROGERS, Circuit
+Judges, SILBERMAN, Senior Circuit Judge.
+Injunction
+21211 Subjects of Protection and Relief
+JUDGMENT
+212I1(H) Matters Relating to Criminal Acts
+PER CURIAM.
+212k105 Criminal Prosecutions
+**1 This case was considered on the record from
+https://web2.westlaw.com/print/printstream.aspx?prf=HTMLE&destination=atp&sv=Ful... 12/27/2007
+
+
+
+173 Fed.Appx. 840
+173 Fed.Appx. 840, 2006 WL 592928 (C.A.D.C.)
+(Cite as: 173 Fed.Appx. 840)
+the United States District Court for the District of
+Columbia and on the briefs by counsel. For the
+reasons set forth below it is
+ORDERED that the judgment from which this
+appeal has been taken be affirmed. Miranda
+appeals the district court's dismissal of his
+complaint to enjoin any criminal investigation
+related to his past conduct as a Senate aide and to
+immunize him from future prosecution. It is
+well-settled, however, that a court will not act to
+restrain a criminal prosecution if the moving party
+has an adequate remedy at law and will not suffer
+ireparable injury if denied equitable relief. See
+Reing Posegn H2 15 400 65. 3C, 9 10
+746, 27 L.Ed.2d 669 (1971)). The district court
+correctly held that, if indicted, Miranda can protect
+his rights under the First Amendment and Speech or
+Debate Clause pursuant to Rule 12(b) of the Federal
+Rules of Criminal Procedure. F.R.Crim. P. 12(b)
+(2005) (upon indietment, defendant may raise by
+motion defense based on "defects in the institution
+of the prosecution*). See also Deaver, 822 F.2d at
+70 ("existence of Rule 12(b)[ (3) ] suggests that
+appellant's constitutional challenge is not to be
+raised in a preindictment civil injunctive action").
+[1] Miranda argues that without injunctive relief his
+First Amendment right will be "chilled" and that the
+a special circumstance that
+injunctive relief under
+Dombrowski | Pfister, 380 U.S. 479, 85 S.Ct.
+1116, 14 L.Ed.2d 22 (1965). As the district court
+pointed out, however, injunctive relief is not
+demonstrate that his "First Amendment interests
+[are] either threatened or in fact being impaired at
+ne time relief [is] sought." Joint Appendix 61
+quoting Wagner Taylor, 836 F.2d 566, 576 n. 7
+(D.C.Cir.1987))
+in original). But
+Miranda himself alleges only that any infringement
+of his First Amendment right occurred while he was
+employed by the Senate. See Compl. 19 26-27,
+Joint Appendix 12-13 (alleging Senate Sergeant at
+ation chilled his
+speech righ D)o Ckmpare Steresti t thompilen tis
+U.S. 452, 461, 94 S.Ct. 1209, 39 L.Ed.2d 505
+[2] Miranda's argument that he is entitled to
+declaratory relief under the Declaratory Judgment
+Act, 28 U.S.C. § 2201, is likewise unavailing.
+While it is true, as Miranda states, that an adequate
+remedy at law does not preclude declaratory relief if
+relief is
+otherwise appropriate,
+Fed.R.Civ.P. 57, the decision whether to grant that
+elief is squarely within the district cour
+liscretion. See28 U.S.C. § 2201(a); Wilton
+52 5 5 12 25 0 2 25 2 20654)
+(1987). The district court failed to separately set
+out its basis for denying declaratory relief; instead
+it relied on general principles addressed to the
+inappropriateness of granting equitable relief here.
+This is not reversible error. See, e.g.. Deaver, 822
+F.2d at 71 (complaint sought both injunctive and
+declaratory relief; in dismissing complaint court
+did not explicitly state
+grounds for denying
+declaratory relief as it did for denying injunctive
+relief but stated "[p]rospective defendants cannot,
+by bringing. ancillary
+equitable proceedings,
+circumvent federal criminal procedure"). The
+district court did not abuse its discretion in denying
+declaratory relief in the absence of special
+circumstances and given its "considerations of
+practicality and wise judicial administration." See
+Wilton, 515 U.S. at 288, 115 S.Ct. 2137.
+**2 Pursuant to D.C. Circuit Rule 36, this
+disposition will not be published. The Clerk is
+directed to withhold issuance of the mandate herein
+until seven days after resolution of any timely
+petition for rehearing or rehearing en banc. See
+Fed. R.App. P. 41(b); D.C.Cir. R. 41.
+https://web2.westlaw.com/print/printstream.aspx?prf=HTMLE&destination=atp&sv=Ful... 12/27/2007
+
+
+577
+dismiss the complaint for lack of subject that were allegedly proceeds of mail and wire
+matter jurisdietion.
+fraud scheme involving companies' sales of
+memberships in various "who's who" registries. The Court of Appeals, Milton Pollack,
+Senior District Judge, sitting by designation,
+held that: (1) remand was required for consideration of new evidence to determine exact nature of bargain between companies and
+members and thus whether salesmen's repre-
+In re the SEIZURE OF ALL FUNDS IN
+sentations to members were material, and (2)
+ACCOUNTS IN the NAMES REGISTRY district court lacked authority to enjoin gov-
+PUBLISHING, INC., Sterling Who's
+ernment from mailing additional question-
+Who, Inc., Who's Who of Retailers, Inc.,
+naires to members to obtain further evidence
+William's Who's Who, Ine., Who's Who
+of probable cause.
+Executive Club, Bruce Gordon, Who's
+Vacated and remanded.
+Who Worldwide Registry, Inc., Publishing Ventures, Inc, including but not
+limited to Marine Midland Bank Ac- 1. Searches and Seizures 6-83
+count Nos. 018-78090-3, 018-78047-4,
+In order to seize property under civil
+018-78044-0, 018-78055-5, 018-78153-5,
+forfeiture statute, government must demon-
+018-78173-0, Sterling National Bank &
+strate that there was probable cause to be-
+Trust Company of New York Account
+lieve that property is subject to forfeiture.
+Nos.
+035-79716-07, 031-43410-01, 031-
+18 U.S.C.A. $ 981.
+43402-01, Republic National Bank for
+Savings Account No. 2601001775, and All
+2. Searches and Seizures 8-83
+Funds Traceable Thereto.
+Whether probable cause exists must be
+determined on basis of totality of cireum-
+Bruce GORDON, Who's Who Worldwide
+stances and, in context of civil forfeiture pro-
+Registry, Ine., Sterling Who's Who, Ine.,
+ceedings, such circumstances are not limited
+Registry Publishing, Inc., William's
+to evidence presented to magistrate who is-
+Who's Who, Inc., Who's Who Executive
+sued warrant. 18 U.S.C.A. § 981.
+Club, Publishing Ventures, Inc., Who's
+Who of Retailers, Inc., Petitioners-Ap- 3. Forfeitures e-5
+pellees,
+Findings supporting district court's de-
+V.
+UNITED STATES of America,
+Respondent-Appellant.
+No. 474, Docket 95-6119.
+United States Court of Appeals,
+Second Circuit.
+termination as to probable cause to believe
+that property is subject to forfeiture are
+reviewed for clear error, but determination
+itself is conclusion of law reviewed de novo.
+18 U.S.C.A. § 981.
+4. Postal Service e=35(5)
+Essential element of mail fraud is intent
+Argued Aug. 31, 1995.
+Decided Oct. 17, 1995.
+to defraud; in order to establish that defendant acted with intent to defraud, government must show that some actual harm or
+injury was contemplated by schemer. 18
+Government appealed from order en-
+U.S.C.A. § 1341.
+tered in the United States District Court for
+the Eastern District of New York, Arthur D.
+5. Postal Service €-35(11.1)
+Spatt, .., 887 F.Supp. 435, vacating ex parte
+In order for sales tactics to rise to level
+seizure warrant authorizing seizure of funds
+of mail fraud, misrepresentations must be
+belonging to companies and their founder material to bargain that customer is induced
+
+
+578
+to enter into with company. 18 U.S.C.A. neys, Brooklyn, NY, of counsel for Respon-
+§ 1841.
+dent-Appellant.
+6. Forfeitures •-5
+Vivian Shevitz, Mount Kisco, New York
+Determination that probable cause did
+(Gerald L. Shargel, Jane Simkin Smith, Carnot exist to believe that companies and their
+ol E. Gette, New York City, of counsel) for
+founder had committed mail or wire fraud in
+Petitioners-Appellees.
+connection with sales of memberships in companies' "who's who" registries, and thus that
+companies' funds were not subject to seizure,
+Before MINER and CALABRESI, Circuit
+Judges, and POLLACK, Senior Distriet
+had to be remanded for reconsideration of
+nature of bargain between companies and
+members in light of members' responses to
+government questionnaires, and thus whether salesmen's representations could be considered material misrepresentations; while
+district court concluded that bargain between
+companies and members entailed purchase of
+membership in registry and companies making available other services or products, new
+evidence showed that members had bargained to join exelusive registries that would
+provide opportunities for networking among
+prominent group of individuals, and thus registries more exclusive in nature than ones
+whose members were merely culled from
+mailing lists. 18 U.S.C.A. 65 981, 1341, 1343.
+7. Constitutional Law @-73
+Injunetion 105(1)
+In context of government's investigation
+MILTON POLLACK, Senior Distriet
+Judge:
+The government appeals from an order
+entered in the United States District Court
+for the Eastern District of New York (Spatt,
+J.) vacating an ex parte seizure warrant that
+authorized the seizure of funds belonging to
+petitioners-appellees Bruce Gordon and several companies under Gordon's control, and
+releasing funds seized pursuant to the warrant. The distriet court determined that the
+government failed to establish probable
+cause to believe that petitioners had committed mail or wire fraud in violation of 18
+U.S.C. 95 1841 and 1343.
+For the reasons that follow, we vacate the
+order and remand for further findings and
+reconsideration in light of new evidence.
+of alleged mail and wire fraud scheme, and
+effort to seize funds as proceeds of those
+schemes, district court lacked authority to
+enjoin government from mailing additional
+questionnaires
+to purported
+vietims of
+scheme to obtain further evidence of probable cause; as incident to separation of powers, court may not interfere with free exercise of discretionary powers of attorneys of
+United States in their control over criminal
+prosecutions.
+BACKGROUND
+Petitioner Bruce Gordon founded and owns
+a controlling interest in the companies involved in this case, including: Who's Who
+Worldwide Registry, Inc, Sterling Who's
+Who, Ine., Who's Who Executive Club, Who's
+Who Worldwide Communications, Tribute
+Magazine, Registry Publishing, Inc., Publishing Ventures, Inc., Who's Who of Retailers,
+and William's Who's Who (collectively, the
+"Companies"). The oldest of the Companies,
+Barbara Underwood, Assistant United
+Who's Who Worldwide Registry, Ine., was
+States Attorney, Brooklyn, NY (Zachary W.
+incorporated in 1989.!
+Carter, United States Attorney for the East- Gordon formed the Companies in order to
+em District of New York, Deborah B. solicit individuals to purchase memberships
+Zwany, Arthur P. Hui, Sarah J. Lam, Gary in the registries published by the Companies.
+R. Brown, Assistant United States Attor- The Companies' salespersons contacted po-
+States District CourtEor the Souther District of ' Who's Coopin America published by Re
+ates District Court for the Southern District
+New York, sitting by designation.
+Elsevier, Inc., and first published in 1899.
+
+
+579
+tential customers either by telephone or by furtherance of a scheme to defraud, and
+sending solicitation letters through the mail. therefore constitutes a violation of the mail
+The salespersons explained to potential customers that, upon becoming a member, they
+would receive a registry containing biograph-
+On March 22, 1995, based on the aliegaical data and addresses of all members, a
+tions in the Complaint, United States Magispersonalized plaque,
+and a camera-ready
+trate Judge Azrack signed arrest warrants
+logo. In addition, customers were told that,
+for Gordon and twenty-nine of the Compaas members, they could purchase a CD-
+nies' salespersons. The following day, the
+ROM version of the registry, a subscription
+government obtained an ex parte warrant of
+to Tribute, a magazine containing profiles of
+seizure, pursuant to Fed.R.Crim.P. 41, authoother members, a credit card, and discounted
+rizing the seizure of funds deposited in certelephone and travel services. The salespertain of the Companies bank accounts.
+sons also stressed that membership was ex-
+Thereafter, on March 30, 1995, the governclusive and prestigious, and that membership
+ment seized over $511,000 of the Companies'
+would provide valuable networking opportufunds, allegedly the proceeds of the scheme
+nities. As a result of their sales efforts, the
+to defraud. As part of its investigation, the
+Companies had acquired more than 60,000
+government also began contacting and sendmembers by the end of 1994.
+ing questionnaires to those who purchased
+In July of 1994, based on complaints reregistry memberships.
+garding the Companies' business practices
+On April 10, 1995, the district court issued
+received from the New York State Depart-
+a temporary restraining order ("TRO") enment of Law, the New York State Consumer
+joining the government from sending addi-
+Protection Board and the Better Business
+tional questionnaires to members of the
+Bureau, the United States Postal Inspection
+Companies" registries. On April 19 and 20,
+Service commenced
+investigation into
+the distriet court held a probable cause hear-
+Gordon and the Companies.
+The investigaing pursuant to United States . All Assets of
+tion culminated in a complaint and affidavit
+Statewide Auto Parts, /nc, 971 F.2d 896, 905
+(the "Complaint"), sworn to by Postal Inspee-
+(2d Cir.1992) and United States v. Monsanto,
+tor Martin T. Biegelman. In the Complaint,
+921 F.2d 1186, 1203 (2d Cir.1991).
+Biegelman alleges that the Companies' business operations constitute a "telemarketing
+On May 30, 1995, the district court vacated
+boiler room" operation using "high pressure
+the seizure warrant, finding that the governtelephone sales pitches that misrepresent the
+ment had failed to establish that there was
+identity of the Company and the nature of its
+probable cause to believe that the Companies
+products in order to defraud customers into
+had committed mail or wire fraud. Relying
+purchasing one
+primarily on United States t. Regent Office
+Who' directories and other products." Bie
+Supply Co., 421 F.2d 1174 (2d Cir.1970), the
+gelman contends that the Companies' salescourt determined that the representations
+persons made fraudulent representations remade by the Companies' salespersons were
+garding the nomination and selection process
+not part of a scheme to defraud. The court
+for membership in the registries,
+found that some of the representations were
+tige of the registries, free placement in the not false, such as the Companies' statements
+registries, the identity of other members of that their registries were "selective" and "inthe registries, the usefulness of the registries valuable tools for networking among memas a networking tool, and the intention of the bers." Other representations were found by
+Companies to hold seminars and conferences. the court to be false or misleading but not
+Since 1989, according to Biegelman, Gordon material, such as the Companies' statements
+and the Companies have defrauded their eus- that they did not acquire new members by
+tomers of more than $22 million dollars. The solicitation for their directories and that "the
+Complaint concludes with the allegation that majority of new candidates who are nominathe Companies' use of the mail and tele- ed are not accepted for inclusion." The dis
+phones to conduct the solicitations was in trict court concluded that the Companies'
+
+
+580
+representations did "not constitute a scheme
+and the seized property. The government
+or artifice to defraud, either singly or in the
+is not required to link a bank account to a
+aggregate." In addition to vacating the seiparticular illegal transaction, but it must
+zure warrant, the district court vacated the
+have probable cause to connect the account
+TRO against the government.
+to criminal activity.
+The government then moved for a stay of
+Id. at 1126 (citations omitted).
+the release of the seized funds. On June 7,
+[2,3] Whether probable cause exists
+1995, the district court granted a temporary
+must be determined on the basis of the totalistay pending application to this court for a
+ty of the circumstances. United States u.
+further stay. On the same day, the govern-
+Ceballos, 812 F.2d 42, 50 (2d Cir.1987). In
+ment filed a Notice of Appeal of the district
+the context of civil forfeiture proceedings,
+court's May 30 Order. On June 9, the court
+these circumstances are not limited to evireleased $220,000 of the seized funds. On
+dence presented to the magistrate who is-
+June 26, 1995, we denied the government's
+sued the warrant. United States u 4499
+motion for a stay, pending appeal to this
+South Livonia Rd, 889 F.2d 1258, 1268 (2d
+court, of the partial release of seized funds
+Cir.1989) ("Once a forfeiture proceeding is
+granted by the district court.
+brought, if further evidence is legally ob-
+Funds in Accounts in Names Registry Pubtained to justify [a finding of probable cause].
+lishing, Inc, 58 F.3d 855 (2d Cir.1995).
+there is no persuasive reason to bar its
+Since the district court's May 30, 1995
+use."). The findings supporting a district
+vacatur of the TRO, the government has
+court's determination as to probable cause
+redesigned its questionnaire in order to genare reviewed for clear error, but the determierate from the registry members information
+nation itself is a conclusion of law reviewed
+regarding the materiality of the misrepresende novo. United States v. Holder, 990 F.2d
+The government now has mailed
+1327, 1328 (D.C.Cir.1993).
+over 49,000 questionnaires to the members,
+and has received approximately 7000 re-
+[4] The mail fraud statute, 18 U.S.C.
+§ 1341, provides, in relevant part, that a
+sponses. The government has moved in this
+court for permission to supplement the recperson is guilty of mail fraud if,
+ord fith the responses to these questionhaving devised or intending to devise any
+naires or, in the alternative, for remand to
+scheme or artifice to defraud, or for oballow the district court to consider whether
+taining money or property by means of
+its order should be modified in light of these
+false or fraudulent pretenses, representations, or promises ... for the purpose of
+executing such scheme or artifice or at-
+DISCUSSION
+tempting so to do, [the person] places in
+any post office or authorized depository for
+1. Probable Cause
+mail matter, any matter or thing whatever
+[I] In order to seize property under 18
+to be sent or delivered by the Postal Ser-
+U.S.C. § 981, the government must demonstrate that there was probable cause to be-
+An essential element of mail fraud, and the
+lieve that the property is subject to forfeielement that is in dispute here, is intent to
+ture. Marine Midland Bank, N.A. v. Unitdefraud. See United States v. D'Amato, 39
+ed States, 11 F.3d 1119, 1124 (2d Cir.1993).
+F.3d 1249, 1256-57 (2d Cir.1994). In order
+In the context of the seizure of bank accounts
+to establish that the defendant acted with an
+allegedly forfeitable under § 981,
+intent to defraud, the government "must
+(p]robable cause is established if the govshow that some actual harm or injury was
+ernment can show that it has reasonable
+contemplated by the schemer." Id. at 1257
+grounds, more than mere suspicion, to be-
+(internal quotations omitted).
+lieve that the property is subject to forfei-
+[5] In United States u. Regent Office
+ture. The government must be able to Supply Co, 421 F.2d 1174 (2d Cir.1970), we
+show a nexus between the illegal conduct stated that an intent to defraud could be
+
+
+581
+found in sales tactics that misrepresent the
+of equal value. It may be impossible to
+usefulness of an item. Id. at 1180. We
+measure his loss by the gross seales available to a court, but he has suffered a
+cases sustaining convictions for mail fraud
+wrong; he has lost his chance to bargain
+have involved sales tactics and representawith the facts before him.
+tions which have tended to mislead the
+purchaser, or prospective purchaser, as to
+Id. at 749. In Regent, we noted that the
+the quality or effectiveness of the thing
+"formulation of law stated in the Rowe decibeing sold, or to mislead him with regard
+sion" affirmed the proposition "that a wrong
+to the advantages of the bargain which
+has been suffered when a man is deprived of
+should accrue to him. Thus claims or
+his chance to bargain 'with the facts before
+statements in advertising may go beyond
+him' where the absent facts are facts materimere puffing and enter the realm of fraud
+al to the bargain he is induced thereby to
+where the product must inherently fail to
+enter."
+421 F.2d at 1182 (emphasis added).
+do what is claimed for it. And promotion
+[6] In the present case, the government
+of an inherently useful item may also be
+fraud when the scheme of promotion is
+contends that the Companies' misrepresentabased on claims of additional benefits to
+tions likewise were material to the bargain
+between the members and the Companies.
+accrue to the customer, if the benefits as
+The government argues that networking and
+represented are not realistically attainable
+by the customer.
+the financial opportunities that networking
+might generate were the principal purposes
+1d. (internal quotations omitted). Accordingfor which the members had joined the Comly, in order for sales tactics to rise to the
+level of mail fraud, misrepresentations must
+panies registries.
+According to the government, the value of the networking, and hence
+be material to the bargain that the customer
+the value of the membership, largely was
+is indueed to enter into with the company.
+dependent on the selection criteria and pro-
+See id. at 1182.
+cesses used to choose the members. Since
+In Regent, we held that the particular misthe Companies misrepresented these criteria
+representations made by the salespersons
+and processes, the government argues, the
+were not material to the nature of the barfalse claims were material to the nature of
+gain between the companies and the customthe bargain between the members and the
+ers. Id In that case, customers bargained
+Companies, and therefore constituted mail
+for office stationery, and, although misreprefraud.
+sentations were made by the stationery companies in order to gain the attention of the
+The district court, however, found that the
+customers, the customers received the prodmisrepresentations of the Companies did not
+ucts for which they had bargained. Id at
+rise to the level of mail fraud. The court
+1180. Accordingly, such false claims were
+stated that the bargain between the Companot material to the bargain between the cusnies and the members entailed both 1) the
+tomers and the companies.
+purchase of "membership in a registry that
+We affirmed the conviction for mail fraud
+the member will be listed in," and 2) the
+in United States v. Rowe, 56 F.2d 747 (2d
+Companies" making available other services
+Cir.), cert. denied, 286 U.S. 554, 52 S.Ct. 579,
+or products that either accompany the pur-
+76 L.Ed. 1289 (1932), involving a scheme to
+chase free of charge" or are available to the
+sell worthleas land. Although the victims of
+members for a cost. In evaluating whether
+the scheme did not prove that they had
+the Companies' sales tacties were material to
+suffered any loss, this court held that the this bargain, the court examined separately
+defendants had committed mail fraud beeach of the nineteen misrepresentations allegedly made by the Companies. The court
+[a] man is none the less cheated out of his concluded that the misrepresentations did
+"not constitute a scheme or artifice to deit by fraud, because he gets a quid pro quo fraud, either singly or in the aggregate."
+
+
+582
+In making this determination, the district whether any misrepresentations were matecourt largely relied on our description of
+rial to the bargain.
+fraudulent sales tacties in Regent, and found
+that the sales tactics used by the Companies
+did not amount to mail fraud. Although the
+2. The Injunction
+court determined that some of the Compa-
+[7) The injunetion ordered by the district
+nies' representations were "false or deceivcourt enjoined the government from mailing
+ing," it found that these representations were
+additional questionnaires to obtain further
+"not material to the bargain struck between
+evidence of probable cause. This injunction
+the membership purchaser and the Compawas improper. In United States u Burzynny." The court stated that the representaski Cancer Research Inst., 819 F.2d 1301 (5th
+tions were "not directed at the quality, ade-
+Cir.1987), cert. denied, 484 U.S. 1066, 108
+quaey or price of the goods,' nor [did] they
+S.Ct. 1026, 98 L.Ed.2d 990 (1988), the Fifth
+concern facts 'essential in deciding whether
+Circuit held that "[a]s an incident to the
+to enter the bargain.'" Furthermore, the
+separation of powers founded in the Consticourt found that the members "received extution, the courts are not to interfere with
+actly what [they] paid for when they purthe free exercise of the discretionary powers
+chased a membership," and that there was
+of the attorneys of the United States in their
+not a "discrepaney between benefits reasoncontrol over criminal prosecutions."
+819
+ably anticipated because of the misleading
+F 2d at 1312 (internal quotation omitted); see
+statements and the actual benefits which the
+also LaRouche v. Webster, 566 F.Supp. 415,
+defendant delivered, or intended to deliver."
+417 (S.D.N.Y.1988) (holding that the separa-
+Accordingly, the court determined that the
+tion of powers prevents courts from interfergovernment had not shown that it had probaing in federal criminal investigations except
+ble cause to believe that the Companies had
+in the "rarest of circumstances"). We agree.
+committed mail or wire fraud.
+In the present case, the injunction especially
+resulted in improper interference because,
+Although the
+court concluded that the
+according to our decision in 4492 South Livo-
+Companies' misrepresentations were not mania Ra, 889 F.2d at 1258, the government
+terial to the bargain between the Companies
+may use post-seizure evidence at a probable
+and the members, we think that the court did
+cause hearing.
+not fully evaluate the true nature of the
+bargain. The members had bargained with
+On remand, the district court should allow
+the Companies to join exclusive registries
+the government to continue collecting questhat would provide opportunities for nettionnaires. We note that, after the vacatur
+working among a prominent group of individof the injunction, the government redesigned
+uals.
+Although
+the members did obtain
+its questionnaires in order to generate from
+membership in
+the registry members information regarding
+had bargained to join registries of a more
+the materiality of the misrepresentations.
+exclusive nature than ones whose members
+The district court, on remand, should considmerely were culled from mailing lists. As a
+er the responses to these questionnaires,
+result, this may be a different situation than
+along with the evidence previously introthat presented in Regent, where the consumduced, and reconsider whether the Compaers received the products for which they had
+bargained. In the present case, membership
+Barpain beiven the Companies and the
+in the registries may not have provided the
+members. The totality of the circumstances
+members with the full networking capability
+should inform the district court's determinathat they expected to receive from the Comtion of probable cause.
+panies. On remand, the distriet court should
+re-examine, with the benefit of the information provided by the new questionnaires, the
+nature of the bargain and the inducements
+that impelled the members to join and
+CONCLUSION
+For the foregoing reasons, we vacate the
+order of the district court and remand for
+
+
+U.S. | NELSON
+583
+Cite as 68 F.3d 583 (2nd Cir. 1995)
+further findings and reconsideration in accor- justice to grant transfer. 18 U.S.C.A.
+dance with the foregoing.
+§ 5082.
+2. Infants e-68.7(3)
+Burden is on government to establish
+that transfer of juvenile to adult status is
+warranted, as there is presumption in favor
+of juvenile adjudication. 18 U.S.C.A. § 5032.
+3. Infants e-68.7(2)
+In determining whether transfer of juve-
+UNITED STATES of America, Appellant, nile to adult status would be in interest of
+justice, district court must consider, and
+make findings in record regarding, statutory
+Lemrick NELSON, Jr., Defendant-
+Appellee.
+No. 421, Docket 95-1271.
+United States Court of Appeals,
+Second Circuit.
+factors of juvenile's age and social background, nature of offense alleged, nature and
+extent of any prior delinquency record, present psychological maturity and intellectual
+development, juvenile's response to past
+treatment efforts nature of those efforts, and
+available programs designed to treat juve-
+Argued Aug. 29, 1995.
+Decided Oct. 17, 1995.
+nile's behavior problems; factors need not be
+accorded equal weight by district court, and
+it may balance factors in any way that seems
+appropriate. 18 U.S.C.A. § 5032.
+The United States District Court for the
+Eastern District of New York, David G.
+Trager, J., denied government's motion to
+transfer juvenile for adult prosecution. Government appealed. The Court of Appeals,
+Miner, Circuit Judge, held that: (1) juvenile's
+age at time of transfer proceeding should
+have been considered; (2) distriet court
+should have assumed juvenile committed offense charged in information and not examined strength of government's evidence; (3)
+juvenile's conviction as adult for actions after
+alleged offense should have been considered;
+(4) "glimmer of hope" test for rehabilitation
+was explicitly rejected; and (5) finding regarding availability of programs designed to
+treat juvenile's behavioral problems was in-
+4. Infants e=68.7(2), 68.8
+Decision of district court concerning
+transfer of juvenile to adult status is discretionary and will not be disturbed except upon
+finding of abuse of discretion and court abuses its discretion when it fails to make required factual findings or where findings it
+makes are clearly erroneous; district court's
+interpretation of each statutory factor presents question of law, and Court of Appeals
+reviews interpretation de novo. 18 U.S.C.A.
+5. Infants e=68.7(3), 68.8
+District court erred in refusing to consider juvenile's age at time of transfer proceeding where juvenile was 20; unless government intentionally delayed filing of juve-
+Vacated and remanded.
+nile charges, there was every reason to give
+weight to age at time of transfer motion. 18
+U.S.C.A. § 5032.
+Juvenile alleged to have committed act 6. Infants e=68.7(2)
+after 15th birthday which, if committed by
+In evaluating statutory factor concerning
+adult, would be felony that is crime of viotransfer of juvenile to adult status, while
+lence may be proceeded against as adult court correctly focused on juvenile's age of
+where district court, after transfer motion by
+time of offense, but statutory factor specifies
+Attorney General, finds it is in interest of only "age" and current age was significant
+
+
+372
+945 FEDERAL REPORTER, 2d SERIES
+723, 79 L.Ed.2d 184 (1984) (listing alterna- hausted in state court the federal due pro
+tive methods of exhausting federal consticess claim he now presents to this Court.
+tutional issues in state court without spe-
+AFFIRMED.
+cifically referring to them in constitutional
+terms). Instead, they need only present
+the substance of a federal constitutional
+claim to the state courts in order to exhaust the issue and preserve it for review
+in a federal habeas corpus proceeding. Pi-
+card v. Connor, 404 U.S. 270, 278, 92 S.Ct.
+509, 513, 30 L.Ed.2d 438 (1971). When a
+federal habeas petitioner presents what
+Saul KENT, William Faloon, the Lif
+amounts to "a mere variation in the same
+claim rather than a different legal theo-
+Extension Foundation, Plaintiff
+гу...." Wilks u. Israel, 627 F.2d 32, 38
+Appellants,
+(7th Cir.1980), cert. denied, 449 U.S. 1086,
+V.
+101 S.Ct. 874, 66 L.Ed.2d 811 (1981), he has
+James BENSON, Commissioner, Food
+presented the state courts with the substance of his claims and thus has properly
+and Drug Administration, U.S. Depart
+ment of Health and Human Services
+exhausted them.
+In Hutchins v. Wain-
+Dexter Lehtinen, U.S. Attorney for the
+wright, 715 F.2d 512 (11th Cir.1983), cert.
+Southern District of Florida, Defendenied, 465 U.S. 1071, 104 S.Ct. 1427, 79
+dants-Appellees.
+L.Ed.2d 751 (1984), we concluded that a
+petitioner who had challenged the admis-
+No. 90-5710.
+sion of certain out-of-court statements on
+state hearsay grounds had adequately
+United States Court of Appeals,
+Eleventh Circuit.
+presented and preserved a federal constitutional claim concerning the violation of his
+Oct. 22, 1991.
+Sixth Amendment right to confront the witnesses against him.
+[11] To the extent that defendant's con-
+Targets of federal grand jury investigation involving inquiry about whether
+stitutional claim is based on the failure of
+the Florida court to follow Florida law,
+they and their companies had participated
+in criminal offenses involving distribution
+petitioner presented both the state and federal courts with the identical claim, namely
+of preseription drugs without prescription
+that he had been convicted despite the prosand distribution of unapproved new drugs
+ecution's failure to demonstrate each elesued to enjoin grand jury proceeding and
+ment of the offense. In both forums, the
+for advisory opinion from Food and Drug
+only question is whether all of the elements
+Administration (FDA) with respect to
+of sexual battery under Florida law have
+whether their activities were illegal. The
+been demonstrated in this case. Cf. Lani-
+United States District Court for the Southgan v. Maloney, 853 F.2d 40, 44-46 (1st
+ern District of Florida, No. 90-1603-CIV-
+Cir. 1988), cert. denied, 488 U.S. 1007, 109
+CCA, C. Clyde Atkins, J., dismissed com-
+S.Ct. 788, 102 L. Ed.2d 780 (1989) (objection
+plaint. Plaintiffs appealed. The Court of
+to reasonable doubt instruction in state
+Appeals held that: (1) targets of grand
+court sufficient to exhaust constitutional
+jury investigation were not entitled to enclaim premised on same issue); Hawkins v.
+join grand jury proceeding or obtain adviso
+West, 706 F.2d 437, 439 (2d Cir.1983)
+ry opinion from FDA with respect to
+(same). As a result, we conclude that by
+whether their activities were illegal, and (2)
+contending that the trial court misapplied
+appeal from dismissal of complaint was
+Florida law and allowed the jury to convict
+frivolous justifying imposition of economic
+without the necessary showing of criminal
+intent, petitioner adequately raised and ex-
+
+
+1. Grand Jury $33
+Injunction 105(1)
+Targets of federal grand jury investigation involving inquiry about whether
+they and their companies had participated
+in criminal offenses involving distribution
+of prescription drugs without prescription
+and distribution of unapproved new drugs
+were not entitled to enjoin grand jury proceedings or to secure advisory opinion from
+Food and Drug Administration with respect
+to whether their activities were illegal.
+Federal Food, Drug, and Cosmetic Act,
+§ 305, 21 U.S.C.A. § 335.
+2. Federal Civil Procedure *=2840
+Appeal from district court's denial of
+suit to enjoin grand jury proceedings involving plaintiffs and seeking advisory
+opinion from Food and Drug Administration with respect to whether plaintiffs' ae-
+Michael Pasano, Zuckerman, Spaeder,
+Taylor & Evans, Humberto J. Pena, Guy A.
+Rasco, Miami, Fla., for plaintiffs-appellants.
+North Miami Beach, Fla, for Willam Fa.
+for William Fa
+ioon.
+Dexter W. Lehtinen, U.S. Atty., Miami,
+Fla., Barbara K. Bisno, Asst. U.S. Atty.,
+Deborah S. Smolover, U.S. Dept. of Justice,
+Jacqueline H. Eagle, Office of Consumer
+Litigation, U.S. Dept of Justice, Washington, D.C., for defendants-appellees.
+Appeal from the United States District
+Court for the Southern District of Florida.
+Before KRAVITCH and EDMONDSON,
+Cireuit Judges, and CLARK, Senior Circuit
+Judge.
+PER CURIAM:
+This is a frivolous appeal from the district court's denial of plaintiffs' suit to enjoin the United States Attorney from conducting a grand jury proceeding involving
+the plaintiffs. On or about April 9, 1990,
+appellants were advised by letter that they
+KENT BENSON
+Cite as 945 F.2c
+373
+372 (11ch Cir. 1991)
+were targets of a federal grand jury investigation.
+The investigation involved an inquiry about whether plaintiffs and their
+companies had participated in criminal of
+fenses involving the distribution of pre
+scription drugs without a prescription and
+the distribution of unapproved new drugs.
+[1] The opening paragraph of appel
+lant's complaint describes their cause of
+This is an action in the nature of mandamus and pursuant to Title 5, United
+States Code, Section 702, to compel
+James Benson, the acting Commissioner
+of Food and Drug Administration, to follow his own statute, rules and regulations and to give the Plaintiffs appropriate notice and an opportunity to present
+information and views to show cause
+why criminal prosecution against them
+should not be recommended to the United States Attorney for the Southern District of Florida. This action also seeks to
+compel the United States Attorney for
+the Southern District of Florida to refrain from pursuing a federal criminal
+grand jury investigation of Plaintiffs and
+attempting to secure Plaintiffs' indictment until such time as James Benson,
+the acting Commissioner of Food and
+Drugs, has complied with the requirements of the Food and Drug Act and
+accompanying regulations. This Court
+has jurisdietion pursuant to Title 28,
+United States Code, Sections 1346 and
+Record Excerpts at 2-1.
+The relevant statute is Title 21 U.S.C.
+§ 335, and provides:
+Before any violation of this chapter is
+reported by the Secretary to any United
+States attorney for institution of a crimiplated proceeding.
+The distriet court dismissed the com
+plaint, holding that the court lacked the
+
+
+374
+945 FEDERAL REPORTER, 2d SERIES
+tration with respect to whether their activi- (IRS) seeking tax refunds on grounds that
+ties were illegal. The court was obviously
+IRS inconsistently administered charitable
+correct in dismissing the complaint. Withdeductions for quid pro quo payments to
+out getting into a lengthy history of the
+religious organizations. The United States
+statute, suffice it to say that it was enacted
+Distriet Court for the Southern District of
+on June 30, 1906. The law has been twice
+Florida, No. 90-8271-CIV-JLK, James Lawinterpreted by the United States Supreme
+rence King, J., granted a motion to dismiss.
+Court to deny the relief sought by appellants here. First, in United States v. Mor-
+Church member appealed. The Court of
+gan, 222 U.S. 274, 32 S.Ct. 81, 56 L.Ed. 198
+Appeals, Dubina, Circuit Judge, held that
+(1911), the Court closed its opinion with the
+following sentence:
+There is nothing in the nature of the
+offense under the pure food law, or in
+- not the pure nature of the file condie grated.
+church member's allegation of administrative inconsistency stated claim upon which
+Vacated and remanded.
+the language of the statute, which indicates that Congress intended to grant
+violators of this act a conditional immunity from prosecution, or to confer upon
+them a privilege not given every other
+person charged with a crime.
+The Supreme Court confirmed this holding
+in United States t. Dotterweich, 320 U.S.
+277, 64 S.Ct. 134, 88 L.Ed. 48 (1943).
+[2] Appellants cite no authority to supnone. The arguments being without arguable merit, economic sanctions are in order,
+including reasonable attorneys fees and
+double costs. Upon receipt of the mandate,
+the district court, after hearing, should determine the amount. See Hopson u. Fischbeck, 758 F.2d 579 (11th Cir.1985).
+AFFIRMED.
+1. Federal Courts • 794
+Court of Appeals must accept plaintiff's allegations as true when reviewing
+dismissal of complaint for failure to state
+claim. Fed.Rules Civ.Proc.Rule 12(b)(6), 28
+U.S.C.A.
+2. Federal Civil Procedure $1772
+District court may dismiss complaint
+for failure to state claim only if it is clear
+that no relief could be granted under any
+set of facts that could be proved consistent
+with allegations. Fed.Rules Civ.Proe.Rule
+12(b)(6), 28 U.S.C.A.
+3. Constitutional Law 84.5(7)
+Allegations by member of Church of
+Scientology that Internal Revenue Service
+(IRS) inconsistently administered charitable
+deductions for quid pro quo payments to
+religious organizations on federal income
+I. POWELL, Plaintire
+Appellant,
+tax returns stated cause of action for discrimination among religions prohibited by
+establishment clause of First Amendment.
+26 U.S.C.A. § 170; Fed.Rules Civ.Proc.
+UNITED STATES of America,
+Defendant-Appellee.
+No. 90-6034.
+United States Court of Appeals,
+Eleventh Circuit.
+Oct. 22, 1991.
+Rule 12(b)(6), 28 U.S.C.A.; U.S.C.A. Const.
+Amend. 1.
+4. Constitutional Law e-84(1)
+Establishment clause of First Amendment prohibits denominational preferences,
+including those created by discriminatory
+or selective application of facially neutral
+Member of Church of Scientology filed statute; Government may not discriminate
+complaint against Internal Revenue Service
+among religions by applying or enforcing
+
+
+
+AMJUR INJUNCTION § 180
+42 Am. Jur. 2d Injunctions § 180
+American Jurisprudence, Second Edition
+Database updated November 2007
+b. Types of Laws
+Topic Summary; Correlation Table; References
+§ 180. Criminal or penal statutes--Grand jury proceedings
+A grand jury cannot be enjoined from conducting lawful investigations and deliberations.[FN35] Thus, targets
+of a federal grand jury investigation involving an inquiry about whether they and their companies had participated
+in criminal offenses involving the distribution of prescription drugs without a prescription and distribution of
+unapproved new drugs were not entitled to enjoin grand jury proceedings or to secure an advisory opinion from
+Food and Drug Administration with respect to whether their activities were illegal. [FN36] The target of a federal
+grand jury investigation had an adequate remedy at law for any irregularity in the investigative process and was not
+entitled to injunctive relief to prevent the grand jury from returning an allegedly tainted indictment.[FN37]
+[FN35] Ex parte Jones County Grand Jury, First Judicial Dist., 705 So. 2d 1308 (Miss. 1997).
+[FN36] Kent |. Benson, 945 F.2d 372 (11th Cir. 1991).
+(FN37] Blalock . U.S., 844 F.2d 1546 (11th Cir. 1988), reh'g denied, 856 F.2d 200 (11th Cir. 1988) an
+(distinguished by,
+Nestin . McDaniel, 760 F. Supp. 1563 (M.D. Ga. 1991)) and (disagreed with on other ground
+by, Finn |. Schiller, 72 F.3d 1182 (4th Cir. 1996)).
+© 2007 Thomson/West
+AMJUR INJUNCTION § 180
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGo... 12/27/2007
+
+
+curring:
+I write separately to emphasize what I
+believe is most salient in the majority's
+careful exposition of 28 U.S.C. §9 2680(a)
+and (h): these sections of the FTCA must
+be harmonized. In achieving harmony, a
+task made no simpler by Congress's draftsmanship and the sketchy legislative history
+of the law enforcement proviso, it is not
+necessary to conclude with the majority
+U.S. BURZYNSKI CANCER RESCE. ICH INSTITUTE
+1301
+Cite as 819 F.2d 1301 (5th Clr. 1987)
+EDITH H. JONES, Circuit Judge, coninterference with their vital functions. See
+Harlow v. Fitzgerald, 457 U.S. 800, 806,
+102 S.Ct. 2727, 2782, 73 L.Ed.2d 396 (1982).
+The discretionary function exception to the
+Federal Tort Claims Act should perform a
+similar role as the courts continue to interpret the law enforcement proviso.
+The
+panel's use of the Elliott v. Perez pleading
+standard in cases involving 95 2680(a) and
+(h) is a step in the direction of creating the
+necessary harmony.
+that "even Bivens and Collinsville would
+not pass muster" if the law enforcement
+proviso, § 2680(h), is subject to the discre-
+6 KEY MOMBIE TIEN
+tionary function exception, § 2680(a). As
+the majority elsewhere observe, this court
+has held that violations of agency regulations do not fall within the discretionary
+function exception so as to immunize the
+federal government from
+tort liability.
+See, e.g., Collins v. United States,
+788
+UNITED STATES of America, Plaintiff-
+Counter Defendant-Appellee,
+F.2d 1225 (5th Cir.1986).
+What I believe
+sensitivity in this task of statutory construction is preserving prosecutorial and
+discretionary law
+Compare Smith v. United States, 375 F.2d
+243 (5th Cir.), cert. denied, 889 U.S. 841, 88
+S.Ct. 76, 19 L.Ed.2d 106 (1967) (decisions on
+when, where and against whom to prosecute are discretionary under § 2680(a));
+Gray t. Bell, 712 F.2d 490, 505 (D.C.Cir.
+BURZYNSKI CANCER RESEARCH IN.
+STITUTE, et al., Defendants-Counter
+Plaintiffs-Appellants
+Janice Kuharzyk, and Other Patients of
+Dr. Stanislaw R. Burzynski, et al., In-
+tervenors-Counter
+Plaintiffs-Appellants.
+1983) ("Although the concepts of 'discretion' in official immunity law and under the
+FTCA are not of identical scope, they are
+similar and may have a common origin")
+In law enforcement, while the opportunities
+No. 86-2183.
+United States Court of Appeals,
+Fifth Circuit.
+June 25, 1987.
+for government abuse abound, the incentive for oppressive use of FTCA lawsuits is
+powerful and pervasive.
+What better way
+Action was brought against physician
+to "get even" with one's accuser than to
+and research center seeking to enjoin them
+file suit against the government on account
+from violating Federal Food Drug. and
+of his investigatory conduct? Such law-
+Cosmetie Act by interstate distribution of
+suits are hardly less deleterious to consciproduct used in cancer chemotherapy, antientious law enforcement than are actions
+neoplastons, on ground that they were
+seeking to impose personal liability, be- "new drugs" within meaning of Act, and
+cause they equally threaten careers and
+were being distributed without prior apreputations, divert official time and re. proval by Food and Drug Administration.
+sources, and imperil impartial decisionmak-
+Government also sought to enjoin manufacing. The doctrines of absolute prosecutori- turer in distribution of antineoplastons on
+al and qualified official immunity from per- ground that drugs were adulterated within
+sonal liability are essential to shield the law
+meaning of Act. Physician's patients were
+enforcement community from unwarranted permitted to intervene. After execution of
+
+
+1302
+criminal search warrant, physician filed 3. United States 127(2)
+counterclaim seeking damages, injunctive
+Failure of physician and patients, asrelief, and contempt orders against Governserting claim under Federal Tort Claims
+ment and certain FDA employees.
+Act in connection with seizure of patient-
+United States District Court for the Southtreatment records during fraud and drug
+ern District of Texas, Gabrielle K. Me-
+investigation pursuant to criminal search
+Donald, J., dismissed counterelaims, and
+warrant, to file administrative claim for
+appeal was taken. The Court of Appeals,
+relief required that claim be dismissed, in
+Alvin B. Rubin, Cireuit Judge, held that:
+that administrative review was jurisdiction-
+(1) claims under Federal Tort Claims Act
+al prerequisite under Act; it would not
+required, as jurisdictional prerequisite, adhave been appropriate merely to stay suit
+ministrative review; (2) employees involved
+until claim could be filed once issue was
+in obtaining criminal search warrant were
+raised. 28 U.S.C.A. §5 1346, 2671 et seq.
+entitled to immunity from common law and
+4. Federal Civil Procedure •2533
+constitutional tort claims; (3) physician and
+Affirmative defense may be raised on
+patients were not entitled to return of
+seized patient records; (4) physician and
+motion for summary judgment only if that
+patients were not entitled to injunction
+motion is first pleading responsive to subagainst use of records; (5) physician and
+stantive allegations.
+Fed.Rules Civ.Proc.
+patients were entitled to develop faets to
+Rule 8(c), 28 U.S.C.A.
+support their claim to injunctive relief with
+5. Federal Civil Procedure @ 1823, 2532
+respect to Government's allegedly provid-
+None of Government's initial filings
+was responsive "initial pleading," such as
+would preclude, due to waiver, raising afment complied with obligations under perfirmative immunity defenses on part of inmanent injunction and, thus, it and its emdividual government employees in motion
+ployees were not in contempt.
+to dismiss or for summary judgment. Fed.
+Affirmed in part, reversed in part, and
+Rules Civ.Proc.Rule 8(c), 28 U.S.C.A.
+remanded.
+6. United States €-50.5(3)
+Federal employees are absolutely immune from common-law tort suits for dam-
+1. Federal Civil Procedure 1957
+ages arising out of performance of either
+Distriet court did not, in electing not to
+mandatory or discretionary acts that are
+restate, in its dismissal order, legal analywithin outer perimeter of their line of
+sis it had already set forth in denial of
+duties; immunity extends even to allegedly
+preliminary motions for a temporary remalicious acts.
+straining order, return of property, and
+7. United States $-50.10(3)
+contempt, conduct trial on merits, much
+Activities of federal employees with
+less impermissibly consolidate trial with
+respect to application for and execution of
+hearing on preliminary motions.
+criminal search warrant, pursuant to which
+2. Federal Civil Procedure 1836
+physician's patient-treatment records were
+Order denying preliminary motion for
+seized, were within scope of their duties
+and, therefore, employees were absolutely
+a temporary restraining order, return of
+immune from suit for common-law torts
+property, and contempt, and order dismissallegedly committed in connection with
+ing action, taken together, adequately
+presented full review of actions taken by
+district court and its reasons therefor; district court elected not to restate in its dismissal order legal analysis it had already
+set forth in its denial of preliminary mo-
+8. United States -50.10(3)
+Federal employees involved in obtaining and executing warrant for search of
+business premises occupied by physician
+were entitled to qualified immunity shield-
+
+
+U.S. v. BURZYNSKI CANCER RESEARCH INSTITUTE
+Cite as 819 F2d 1301 (5th Cir. 1987)
+ing them from liability for their acts with 13. Injunction -105(1)
+respect to constitutional tort claims of phy-
+Allegations of unlawful seizure of pasician and patients; employees followed estient-treatment records could not form cogtablished constitutional procedures and vionizable basis for claiming that Government
+lated no norms of clearly established law.
+had of would interfere impermissibly with
+U.S.C.A. Const.Amends. 4, 5, 8.
+physician's treatment of patient's solely
+9. Searches and Seizures 26, 150
+within State of Texas, such as would entitle
+Witnesses -212
+physician and patient's to injunctive relief
+Patients had no legitimate expectation
+against interference; there was simply no
+of privacy in records maintained by physigeniune issue of such threat raised.
+cian that could be asserted against criminal
+search warrant and, thus, no standing to
+seek return of records; under Texas law,
+seizure pursuant to search warrant issued
+as part of criminal investigation was exempt from physician-patient privilege.
+Vernon's Ann.Texas Civ.St. art. 4495b
+§ 5.08(b) (Repealed); Fed.Rules Cr.Proe.
+Rule 41(e), 18 U.S.C.A.
+10. Searches and Seizures $-150
+Physician and patients alleged no basis
+on which it could be found that seizure of
+patient-treatment records pursuant to crim-
+14. Administrative Law and Procedure
+6-232
+Drugs and Narcoties •23
+Physician failed to make good-faith effort to obtain investigational new drug status for antineoplastons from FDA and to
+exhaust administrative remedies with respect to application, and, therefore, he
+could not be entitled to injunctive relief
+against government's interfering with his
+treatment of patients with antineoplastons
+by refusing to grant IND status to drug.
+inal search warrant was unlawful, such as
+would entitle them to obtain return of
+records. Fed.Rules Cr.Proe.Rule 41(e), 18
+U.S.C.A.
+11. Injunction $-105(1)
+District court could not enjoin Government in its use of patient-treatment records
+seized, pursuant to criminal search war-
+15. Drugs and Narcotics -10
+allure to allege facts establishin
+nat investigational new drug status wa
+improperly withheld from antineoplastons
+precluded patients' indirect challenge to
+FDA action, based on allegations that their
+constitutional right to
+travel freely between states was being infringed.
+rant, from physician's business, absent allegation of any improper use of seized
+12. Injunction @ 105(1)
+overnment would not be enjoined
+communicating
+with physician's
+present and former patients and their insurance carriers, in connection with seizure
+16. Drugs and Narcoties •-23
+Patients had no claim for injunctive
+relief against Government's interference
+with interstate distribution of antineoplastons based on asserted constitutional right
+to obtain medical treatment that was encompassed by the right to privacy.
+of patient-treatment records pursuant to
+criminal search warrant, in that such in-
+17. Injunction • 105(1)
+junction would interfere with free exercise
+Physician and patients were entitled to
+of discretionary powers of attorneys of the
+develop facts that could entitle them to
+United States in their control over criminal
+injunctive relief with respect to claim that
+prosecutions; injunction would have imped- Government provided insurance company's
+ed or totally frustrated Government's abili- with false and misleading information, givty to pursue its investigation of, among en finding that at least two statements by
+other things, interstate distribution of anti- government employee in response to in
+neoplastons, fraudulent over-billing and
+quiries about physician and his treatment
+double-billing of insurance companies, and
+were nearly inappropriate, exceeded his
+false statements to Government.
+duties and responsibilities as officer of
+
+
+1304
+Charges stillige dience big tiserting iny grinda or finding thatch serare of
+any grounds for finding that the seizure of
+the records was unconstitutional. We
+18. Injunction 6-223
+therefore affirm its dismissal of all coun
+FDA advised physician of its position
+terclaims regarding the seizure or continwith respect to manufacturing practices of
+ued government retention of documents
+research institute and, thus, was in complifrom the doctor's offices. Because, howance with terms of permanent injunction;
+ever, in the absence of an opportunity to
+accordingly, Government and employees
+conduct discovery regarding their contencould not be in civil contempt.
+tion that the government had provided insurance companies with false and mislead-
+Christian P. Di Ferrante, John I. Johning information, the doctor and his patients
+son, Calvin, Dylewski, Gibbs, Maddox, Rushave not had a chance to develop facts that
+sell & Verner, Houston, Tex., for Burzinski
+may entitle them to injunctive relief on that
+Cancer Research Institute.
+score, we remand that counterclaim for
+further proceedings.
+Margaret A. Harris, Stuart M. Nelkin,
+Nelkin & Nelkin, Houston, Tex., for Juanice Kuharzyk, etc., et al.
+Gerald C. Kell, Atty., U.S. Dept, of Jus-
+In 1988, the United States sued Dr. Stantice, Office of Consumer Lit., Washington,
+islaw R. Burzynski and the Burzynski Can-
+D.C., Linda M. Cipriani, Asst. U.S. Atty.,
+cer Research Institute (together referred to
+Henry K. Oncken, U.S. Atty., Frank A
+as Dr. Burzynski) in this civil action seek-
+Conforti, James R. Gough, Asst. U.S. At-
+ing to enjoin them from violating the Fedtys., Houston, Tex., for the U.S.
+eral Food, Drug,
+and Cosmetic Act by
+interstate distribution of a produet used in
+Appeals from the United States District
+cancer chemotherapy, antineoplastons, on
+Court for the Southern District of Texas.
+the ground that the antineoplastons were
+"new drugs" within the meaning of the
+Before RUBIN, RANDALL, and
+Act,' and were being distributed without
+JOHNSON, Circuit Judges.
+prior approval by the Food and Drug Ad-
+ministration. Dr. Burzynski manufactures
+ALVIN B. RUBIN, Cireuit Judge:
+the natural type of antineoplastons from
+Armed with a search warrant,
+urine, and synthetie forms, called antinegovernment seized a doctor's patient-treatplastons 10, from various chemicals. The
+ment records during an investigation to
+government also sought to enjoin the mandetermine whether the doctor had violated
+ufacture and distribution of antineoplacriminal fraud statutes and a criminal statstons on the ground that the drugs were
+ute forbidding the interstate shipment of
+adulterated within the meaning of the Act?
+drugs that had not been approved by the
+because Dr. Burzynski's manufacturing
+Food and Drug Administration. The doemethods, facilities, and controls did not
+tor and some of the patients, as intercomply with the FDA's current good manuvenors, sought to have the records refacturing practice regulations. A number
+turned and to obtain damages and other of Dr. Burzynski's patients were allowed to
+relief by filing a counterclaim in a previous- intervene. After a two-day hearing, the
+ly pending civil action filed by the govern- district court issued an injunction granting
+ment to enjoin interstate distribution of the most of the relief sought by the governdrug. The distriet court properly held that ment. It also directed Dr. Burzynski to
+the doctor and his patients have failed to bring his research and manufacturing facilestablish any basis entitling them to a hear- ity into compliance with FDA's current
+1. 21 U.S.C. § 301, et seq. (1982).
+2. 21 U.S.C. § 321(p).
+
+
+Cite as 819 F.2d 1301 (5ch Cir. 1987)
+good-manufacturing procedures, ordering
+ter to make copies. On the advice of his
+the FDA in turn to act promptly on their
+employees, Dr. Burzynski himself "decided
+submission for approval. The order, howto give away filing cabinets along with the
+ever, expressly allowed Dr. Burzynski to
+records" in order to protect the records.
+continue manufacturing and prescribing
+Since the execution of the search warrant,
+the drug in Texas.
+The court expressly
+Dr. Burzynski has been allowed to install a
+retained continuing jurisdiction to enforce
+copying machine in the PDA offices in
+or modify its order.
+Houston where the seized patient treat-
+Two years later, in July 1985, as part of
+ment records are being held and has made
+a criminal investigation based on a referral
+copies of those treatment records that he
+from the FDA to the Department of Justice, the government applied for and obtained a warrant to search an office complex that, as the warrant stated, housed the
+administrative offices of Dr. Burzynski and
+the Burzynski Research Institute, Incory
+rated, a separate legal entity from Burzy
+ski Cancer Research Institute, which had
+been a defendant in the civil action.
+application for the warrant was supported
+by the affidavit of FDA Compliance Offi
+cer, Kenneth P. Ewing. Ewing stated that
+the application was based on FDA inspections and investigations of Dr. Burzynski
+and the Institute, information supplied by
+insurance companies that had
+supplied by the surviving spouse of one of
+Dr. Burzynski's patients, and information
+supplied by confidential informants.
+In terms set forth in full in the footnote,'
+the warrant authorized a search for and
+seizure of records and other property that
+reflected distribution of antineoplastons
+outside the State of Texas and other
+records that would show the antineoplastons had been and were being distributed
+in interstate commerce in violation of Title
+21, United States Code 881(d), the court
+injunction, and Title 18, United States
+Code, Sections 286, 287, 371, 401, 1001,
+1341, and 1505.
+During the search Dr.
+Burzynski's employees were allowed to
+take records to a commercial copying cen-
+(a) distribution of antineoplasions outside the
+State of Texas;
+(b) the true addresses of persons to whom anti.
+neoplastons have been and are being distribut-
+After the warrant had been executed,
+Dr. Burzynski and the Burzynski Research
+Institute, Ine. filed a counterclaim in this
+civil action seeking damages, injunctive relief, and contempt orders against the
+government and certain FDA employees,
+including the FDA Compliance Officer Ew-
+ing, Sharyn Miller, an investigator who had
+assisted Ewing in executing the warrant,
+and other unknown agents of the FDA and
+the United States. Certain named patients
+of Dr. Burzynski were given leave to file
+their own counterclaim as intervenors and
+sought a temporary restraining order commanding return of the records and other
+emergency relief.
+During a twelve-day hearing on the motion for a temporary restraining order and
+contempt ruling, Dr. Burzynski testified
+that he had continued to treat patients in
+Texas. Based on what some of them told
+him, he suspected that antineoplastons
+were supplied from the Institute to patients
+in other states, but he testified that he did
+not believe it would be possible to detect
+such shipments with certainty unless every
+one of the Institute's employees had "a spy
+on his back." After the hearing was completed, the district court denied all of the
+The government then responded to the
+counterclaims by moving for their dismis-
+(c) patient treatment, patient accounts, and patient billings: and
+(d) insurance claims and receipt of insurance
+payments that show that antineoplastons have
+been and are being distributed in interstate
+commerce in violation of Title 21 United States
+Code, Section 331(d) and the injunction of this
+Court and that evidence violations of Title 18,
+nited States Code, Sections 286, 287, 371, 40
+001, 1341, and 150
+
+
+1306
+sal for failure to state a claim for which
+[2] The patients also attack the dismisrelief could be granted or, in the alternasal order as being "pithy to the point of
+tive, for summary judgment. In a brief
+being incomplete" and ask this court to
+order, which referred to the evidence ad
+vacate it and remand the case for further
+duced in the earlier hearing on the motion
+consideration. In support of that request,
+for a temporary restraining order, the
+they rely on Myers v. Gulf Oil Corporacourt dismissed the counterclaims.
+tion," in which we held that a district
+court's explanation that the defendant
+should be granted summary judgment "be-
+[1] Dr. Burzynski and the patients concause the Plaintiff has failed to state a
+tend that the district court impermissibly
+claim on which relief can be granted" was
+consolidated the hearing on the motions for
+insufficient to explain that court's reason-
+TRO, return of property, and contempt (the
+The patients' argument focuses on
+preliminary motions) with trial on the merthe length of the district court's dismissal
+its of their counterclaims. The simple fact
+order rather than on its content. Taken
+is that no such consolidation occurred.
+together, the two orders adequately
+the close of the hearing on the preliminary
+present for our review both the actions
+motions, the district court orally denied
+taken by the district court and its reasons.
+those motions. Thereafter, the court entered a nine-page order setting forth its
+III. Claims for Monetary Relief
+findings with respect to the preliminary
+Dr. Burzynski and the patients seek monmotions and its legal basis for denying
+etary damages from the United States
+those motions. Subsequent to the hearing
+on the preliminary motions, the govern-
+FDA, FDA employees Ewing and
+ment filed its motion to dismiss for failure
+(both individually and in their official capacities), and unknown agents of the Unitto state a claim or, alternatively, for sumed States and the FDA. We discuss these
+mary judgment on all of the counterclaims.
+claims separately.
+In an order separate from the order denying the preliminary motions, the district
+court dismissed the counterclaims.
+A. Claims Against the Government
+The district court did state in the later
+[3] Neither the United States, its agenorder that, because the issues raised in the
+cies, nor its officials acting in their official
+counterclaims "raise legal questions which
+capacities, may be sued without the United
+were decided against the Defendants and
+States' specific consent.® The Federal Tort
+Intervenors [Dr.
+Burzynski and the pa-
+Claims Act ' permits certain elaims to be
+tients] in the hearing of October 28, 1985"
+asserted against the United States, as sov-
+(the hearing on the preliminary motions), it
+ereign, and its agents but exacts the filing
+would not repeat its discussion of those
+of an administrative claim for relief as a
+issues. In other words, the district court
+jurisdictional prerequisite to suit. No such
+simply elected not to restate in its dismissal
+claim has been filed. Therefore, the disorder legal analysis it had already set forth
+trict court properly dismissed the damage
+in its denial of the preliminary motions. In
+claims against the United States, the FDA,
+deciding, based on that legal analysis, to
+dismiss the counterclaims, the district court capacities. Because the requirement of addid not conduct a trial on the merits, much ministrative review is a jurisdictional requiless impermissibly consolidate trial with
+site, it would not have been appropriat
+the hearing on the preliminary motions.
+merely to stay the suit until a claim could
+5. 731 F.2d 281, 283 (5th Cir.1984).
+1969), cert. denied, 397 U.S. 941, 90 S.CL. 953, 25
+L.Ed.2d 121 (1970).
+6. United States v. Sherwood, 312 U.S. 584, 586,
+61 S.Ct. 767, 769, 85 L.Ed. 1058 (1941); Zapata
+w. Smith, 437 F.2d 1024, 1025 (5th Cir.1971);
+7. 28 U.S.C. § 2671, et seq. (1982).
+Carter v. Seamans, 411 F.2d 767, 770 (5th Cir.
+
+
+U.S. - BURZYNSKI CANCER SECH IRCH INSTITUTE
+1307
+Cite as 819 Fad 1301 (5th Cir. 1987)
+be filed, as Burzynski sought, once the to allege his affirmative defense in any
+issue was raised."
+"responsive pleading."" The decision,
+therefore, did not address the issue wheth-
+B. Claims Against Individual
+Government Employees
+In seeking monetary damages against
+the government employees as individuals,
+Dr. Burzynski and the patients asserted
+both common law tort claims and claims
+under the Constitution. All of the damages claims asserted against individual
+government employees related to and arose
+out of the application for and execution of
+the criminal search warrant for Dr. Burzynski's business premises, and all are
+barred by immunity doctrines.
+er prior pleadings that are unresponsive to
+the substance of the allegations should preclude the possibility of raising affirmative
+defenses in a subsequent responsive pleading. Because no other panel of this court
+has had occasion to apply the rule that
+Funding Systems sets forth, the proper
+interpretation of the rule remains undecided, and we adopt what we believe to be the
+most principled interpretation of the standard:
+An affirmative defense may be
+raised on a motion for summary judgment
+only if that motion is the first pleading
+responsive to the substance of the allega-
+1. Waiver of Immunity Defenses
+[4] Dr. Burzynski and the patients contend that the government cannot rely on
+immunity defenses
+for the
+individuals
+named as defendants because such affirmative defenses may not be raised by means
+of a motion to dismiss or for summary
+judgment.
+whether the affirmative defenses listed in
+Fed.R.Civ.P. 8(c) must be asserted in the
+defendant's answer or may be raised for
+the first time in a motion to dismiss or
+other dispositive motion.° In
+Systems Leasing Corp. v. Pugh, a panel of
+this court stated that a defendant may
+raise an affirmative defense by a motion
+for summary judgment only when that motion "is the initial pleading tendered by
+[the] defendant." "0
+quoted above
+pleading will defeat the defendant's right
+to raise an affirmative defense in a summary judgment motion, in the context of the
+decision as a whole it becomes apparent
+that the Funding Systems opinion was referring only to pleadings responsive to the
+substantive issues charged.
+The Funding
+Systems decision itself specifically noted
+that the defendant in that case had failed
+8. Gregor
+Cir. 1981) V. Mitchell, 634 F.2d 199, 203-04 (Sth
+9. See C. Wright and A.
+Federal Practice
+328=29 (1969). Com-
+745 (3d
+tions.
+[5] Although in this case the government filed a brief memorandum in opposition to Dr. Burzynski's original counterclaim and several preliminary motions before filing its motion to dismiss or for
+summary judgment, none of those filings is
+a responsive "initial pleading" within the
+meaning
+of Funding
+Systems.
+The
+government's initial memorandum is not a
+"pleading" and did not purport to respond
+to the substantive charges of the counterclaim. It presented only a legal analysis of
+the procedural posture of the case, raising
+issues about whether the counterclaim was
+filed in accordance with the Federal Rules
+of Civil Procedure and about the propriety
+of using civil counterclaims as a means of
+hampering criminal investigations.
+Similarly, the government's ensuing motionswhich are "pleadings" within the meaning
+of the Rules--were not responsive to the
+substance of the counterclaims, but sought
+only to preserve counter-defendants' rights
+pending preparation of an answer or dislair Prairie Oil Co., 35 F.Supp. 296 (E.D.Okl:
+940), aff'd, 120 F.2d 746 (10th Cir.1941)
+10. 530 F.2d 91, 96 (5th Cir.1976).
+11. Id.
+130 F.2d 631 (3d Cir.1942) with Eber
+
+
+1308
+2. Common Law Tort Claims
+sued a new investigation of Dr. Burzynski
+[6] Federal employees are absolutely
+to determine if Dr. Burzynski had violated
+immune from common law tort suits for
+the Act and other federal criminal statutes
+damages arising out of the performance of
+by failing to adhere to the requirements of
+either mandatory or discretionary acts that
+the permanent injunction entered by the
+are, as the Supreme Court stated in BarrI
+district court in May 1983. That investiga-
+Matteo, "within the outer perimeter of the
+tion included the application for and execu-
+[employees'] line of duty." 12 This immunition of the criminal search warrant.
+ty extends even to allegedly malicious
+The activities of Ewing.
+, and the
+acts. 13
+other federal employees with respect to the
+[7] It is difficult to sort out the comsearch warrant were clearly within the
+mon law claims of Dr. Burzynski and the
+scope of their duties. Therefore, they are
+patients from their constitutional elaims.
+absolutely immune from suit for the com-
+Reading the counterclaims as broadly as
+mon law torts allegedly committed in conpossible, however, it appears that, with renection with the search warrant, and disspect to the application for and execution
+missal of the damage claims based on those
+of the search warrant, Dr. Burzynski asalleged torts was proper.
+serted common law claims for abuse of
+process and for some type of tortious inter.
+ference with his relationship with his pa-
+Ewing's duties as a compliance officer
+with FDA included reviewing investigative
+ered by FDA to determine whether there
+were apparent violations of the FDC Act or
+other laws, making recommendations for
+appropriate civil or criminal legal action,
+conducting investigations, and collecting of
+information and samples. FDA compliance
+officers and investigators also are
+required, in conjunction with a United States
+Marshal, to execute criminal search warrants.
+Moreover, Ewing was the person
+within FDA chiefly responsible for the investigation of Dr. Burzynski.
+3. Constitutional Tort Claims
+[8] In Bivens v. Six Unknown Named
+Agents of Federal Bureau of Narcotics,"
+the Supreme Court held that federal officers who, acting under color of their federal authority, but without a warrant, entered and searched the plaintiff's apartment and arrested him, could be personally
+sued for monetary damages for deprivation
+of the plaintiff's rights under the fourth
+The holding of Bivens was
+extended to deprivations of fifth amendment due process rights in Butz t. Economou," to violations of the right to equal
+protection as embodied in the fifth amendment in Davis v. Passman," and to the
+eighth amendment's prohibition against
+cruel and unusual punishment in Carison
+Acting upon information gathered in the
+course of previous FDA investigations of
+Shortly after its recognition of a right of
+Dr. Burzynaki and others, and upon inforaction for constitutional torts under Bi-
+mation supplied to him by named individuvens, the Supreme Court began to develop
+als and confidential informants, swing,
+the defense of qualified immunity to pro
+and other federal employees pur tect federal employees against liability for
+12. Barr v. Matteo, 360 U.S. 564, 575, 79 S.Ct.
+1335, 1341, 3 L.Ed.2d 1434 (1959).
+Accord Ev
+1. 439 V.S. 478, 98 SC. 2694, 57 LEd.2d 395
+ans v. Wright, 582 F.2d 20, 21 (5th Cir.1978).
+13. Barr, 360 U.S. at 575, 79 S.Cr. 1341; Norton
+MeShane, 332 F.2d 855, 858 (5th Cir.1964), c
+16. 442. VS. 228, 99 SCI. 2264, 60 L.Ed.2d 846
+denied, 380 U.S. 981, 85 S.Cz. 1345, 14 L.Ed.2d
+274 (1965).
+1(19846 U.S. 14, 100 SC. 1468, 64 LEd.zd 15
+14. 403 U.S. 388, 91 S.Ct. 1999, 29 L.Ed.2d 619
+(1971)
+
+
+1309
+Cite as 819 F.2d 1301 (5ch Cir. 1987)
+and the burden of defending themselves
+Seabrook, Tezas," "[a] judge's determinaagainst, alleged violations of constitutional
+tion of probable cause breaks the chain of
+rights. As first formulated in Butz v. Ecocausation and insulates the initiating party
+nomou, qualified immunity had both an
+from liability." " Dr. Burzynski counters
+objective and subjective element: the federby correctly pointing out that the Supreme
+al official was entitled to immunity if there
+Court rejected the rationale underlying
+were reasonable grounds to believe that
+that broadly-stated rule in Malley .
+the challenged conduct did not violate a
+constitutional right (the objective element)
+and the official undertook the challenged
+conduct in a good-faith belief that the conduct was valid (the subjective element).
+On further consideration, however,
+Court in Harlow v. Fitzgerald stated,
+"[t]he subjective element of the good-faith
+defense frequently has proved incompatible
+with our admonition in Butz that insubstantial claims should not proceed to trial." " Therefore, the Court eliminated the
+subjective element of the qualified immuni-
+Government officials performing discretionary functions,
+shielded from liability for civil damages
+whenever their conduct does not violate
+clearly established statutory or constitutional rights of which a reasonable person
+would have known."
+Reading Dr. Burzynski's counterclaim
+most broadly, it appears to allege that Ew-
+ing violated the fourth amendment by obtaining the criminal search warrant for Dr.
+Burzynski's business premises
+plish purposes outside the proper scope of
+a search warrant," ie.,
+"for the apparent
+ulterior purpose of foreing [Dr. Burzynski]
+out of business." The government contends, however, that the warrant was issued by an independent judicial officer, the
+United States Magistrate, and that under
+this court's decision in Jureczki u. City of
+18. 438 U.S. at 495-98, 507, 98 S.Ct. at 2905-07,
+In Malley, the Court held that an officer
+may not rely on the judgment of a judicial
+officer in finding that probable cause exists
+if "a reasonably well-trained officer would
+have known that his affidavit failed to establish probable cause and that he should
+not have applied for the warrant." 24 This
+holding, however, does not signal a retreat
+from the principle that, to give rise to
+liability, the actions of á publie official
+must be objectively unreasonable in the
+light of clearly established law.
+therefore, remains "irrelevant in obtaining
+a warrant where probable cause exists." "
+Dr. Burzynski's counterclaim alleges no
+misstatements or omissions in Ewing's affidavit that would have obviated probable
+cause if corrected. Indeed, Dr. Burzynski
+in effect supported its correctness by testifying that, based on the affidavit as well as
+his own independent suspicions, he suspected that antineoplastons were being transported out of Texas, that the Institute has
+been obliged to refund hundreds of insur
+ance overpayments resulting from insurance companies being billed for services
+already paid for by patients, and that on at
+least one occasion an insurance claim was
+submitted for an office visit when the patient did not actually come to the Institute.
+Dr. Burzynski's counterclaim does contain an allegation that the search warrant
+21 760 2 6 68 5 26105) car. demised.
+20. 457 U.S. at 817-18, 102 S.Ct. at 2737-38. See
+also David v. Scherer, 468 U.S. 183, 104 S.Ct.
+3072,130 472 0. 5: 517, 13 . 12. 105 ice all x 234720271 (1985: 106S.C. 1092, 1098.99, 89
+Forsyth, 472 U.S. 511, 535 a. 12, 105 S.C1. 2806,
+2820 n. 12, 86 L.Ed.2d 411 (1985); Saldana v.
+Garza, 684 F.2d 1159, 1163 (5th Cir.1982), cert. 24. Id. (footnote omitted).
+denied, 460 U.S. 1012, 103 S.Ct. 1253, 75 L.Ed.2d
+25. Jureczki, 760 F.2d at 668.
+
+
+1310
+"was not supported by affidavits and evi- to obtain medical treatment. Again, these
+dence
+sufficient to establish probable
+claims could survive the government decause." Based on no more than this unsupfenses of qualified immunity only if Dr.
+ported charge, and despite the admonition
+Burzynski and the patients demonstrated a
+of the Supreme Court in Franks v. Delareasonable basis to believe that the execuware " that to mandate an evidentiary
+tion of the search warrant violated "clearly
+hearing such a charge must also assert
+established law." * They simply failed to
+deliberate falsehood or reckless disregard
+do so. Aceording to the counter-claimants'
+for truth and must be accompanied by an
+own witnesses, the documents seized were
+offer of proof, the district court allowed a
+only those described in the warrant. Since
+lengthy cross-examination of Ewing rethe seizure of these specific documents was
+garding his affidavit. Nonetheless, the disthus authorized, the seizure was in accord
+trict court found no basis even to proceed
+with, rather than in contravention of, clearwith a hearing on the validity of the search
+ly established law.
+warrant, much less to justify a finding that
+the warrant was not validly supported. In
+The patients also assert that seizure of
+this circuit, once a government employee
+their treatment records, which belonged to
+has asserted qualified immunity and estab-
+Dr. Burzynski or the Institute and were in
+lished that the allegedly tortious acts were
+the possession of the Institute, invaded
+undertaken within the scope of his discretheir right to privacy.
+That they have a
+tionary authority, the burden shifts to the
+privacy interest in such documents " does
+party seeking damages to show that qualinot establish the immunity of the doefied immunity does not bar recovery.* Dr.
+uments from seizure. The patients do not
+Burzynski has failed to suggest any factual
+cite a single case in which seizure of docbasis upon which a trier of fact could find
+uments authorized by a warrant has been
+that probable cause was lacking or that
+found to be an unconstitutional invasion of
+agent Ewing's action in seeking the search
+privacy. The absence of such citations is
+warrant was
+objectively
+unreasonable.
+not surprising since a warrant issued upon
+Therefore, the individual defendants were
+"[p]rior review by a neutral and detached
+entitled to have those charges against them
+magistrate is the time-tested means of efdismissed.
+fectuating Fourth Amendment rights." 30
+In addition, both Dr. Burzynski and the
+In any event, seizure of the patients' treatpatients asserted constitutional claims with
+menu records pursuant to a warrant did not
+respect to the government employees' exeviolate clearly established law so as to subcution of the warrant. Both Dr. Burzynski
+ject the government agents to individual
+and the patients challenged the warrant as
+wotaton and the patents a te
+amendment violation.
+Additionally, the paconstitutional rights to privacy, to life, and
+26. 438 U.S. 154, 171-72, 98 S.Ct. 2674, 2684, 57
+L.Ed.2d 667 (1978).
+The patients also assert that seizure of
+their treatment records deprived them of
+their right to life and to medical treatment.
+This claim was unsupported by factual allegations creating any basis to believe that
+the treatment of patients would be substantially. hindered.
+All of the parties
+agree that the records are available for
+8. Harlow • Firgerald, 457 U.S. at 818, 10
+Ct. at 273
+2°Cret ye Search Warrant, 810 F:20 67, 71 (3d)
+1107, 1121 (5th Cir.1981)).
+
+
+1311
+Cite as 819 Fld 1301 (5th Cir. 1987)
+copying. As the distriet court determined
+Both the patients and Dr. Burzynski acbelow, the patients have shown no basis to
+knowledged that the medical records were
+believe that "an opportunity would not be
+seized from Dr. Burzynski's business premmade available to [Dr. Burzynski] to secure
+On appeal, the patients state that
+a copy of those documents in sufficient
+their "property interest [is] in the informatime to treat his patients effectively...."
+tion contained in their medical treatment
+In sum, the federal employees involved
+records." Thus, the patients' own allegations demonstrate that they were not "entitled to lawful possession of the property"
+which was seized and, therefore, that they
+did not have standing to seek return of the
+dures. They violated no norms of clearly
+seized records.
+established law. As federal agents per-
+Since the medical records were seized
+forming discretionary functions within the
+from Dr. Burzynski's business premises,
+scope of their duties, they were entitled to
+the patients would have had standing to
+qualified immunity shielding them from liability for their acts. The district court's
+challenge the search and seizure only if
+dismissal of the constitutional claims
+had a "legitimate expectation of priva-
+• [those] premises," a business belongagainst the federal employees was thereing to others" Even if the seized medical
+fore proper.
+records had been the property of the pa-
+IV. Injunetive Relief
+tients, "It]he fact that [their] property became the 'target' of the search is irrele-
+The counterclaims requested injunetions
+vant." 32
+requiring return of the records seized pursuant to the search warrant, prohibiting
+[9] The patients attempt to ground
+use of the seized records by the governtheir asserted privacy interest in their
+ment, prohibiting government contact with
+medical records on a physician-patient privi.
+patients and their insurance carriers, prolege as codified in Texas state law, Tex.
+hibiting the government from interfering
+Rev.Civ.Stat.Ann. art. 4495b § 5.08(b) (Verwith Dr. Burzynski's treatment of the panon Supp.1985).
+tients with antineoplastons, and prohibiting
+records, however, took place pursuant to a
+the government from disseminating allegsearch warrant as part of a criminal invesedly false or misleading information retigation, and was therefore exempt from
+garding antineoplastons.
+the Texas shield. In the context of federal
+A. Return of the Seized Records
+criminal proceedings, no physician-patient
+privilege exists." Therefore, the patients
+Fed.R.Crim. Proc. 41(e) provides the avehad no legitimate expectation of privacy in
+nue by which a person may obtain return
+the records maintained by Dr. Burzynski
+of property seized by the government.
+that could be asserted against the search
+cause neither Dr. Burzynski nor the pawarrant and no standing to seek the return
+tients stated any basis for a finding that
+of the records.
+the records were illegally seized and the
+patients did not even allege a basis for
+[10] Even if the patients had alleged
+finding that were entitled to lawful possescircumstances sufficient to afford them
+sion of the records, the district court was standing to seek return of the medical
+required to dismiss the injunctive claims records, they alleged no basis on which the
+for return of the records, whether under
+district court could have found the seizure
+Rule 41(e) or its general equity jurisdiction.
+of the records unlawful. The patients ar-
+31. Dickens v. Lewis, 750 F.2d 1251, 1254 (5th
+33. United States v. Meagher, 531 F.2d 752, 753
+(5th Cir.), cert. denied, 429 U.S. 853, 97 S.CT.
+32. Id. (citing Rakas v. Minois, 439 U.S. 128, 99
+146, 50 L-Ed.2d 128 (1976); United States v.
+S.Ct. 421, 426-27, 58 L.Ed.2d 387 (1978)).
+Mancuso, 444 F.2d 691, 694-95 (5th Cir.1971).
+
+
+1312
+gue that their sole challenge to the warrant
+seized records constituted evidence of
+authorizing the seizure was to the face of
+crimes or suggested avenues of investigathe warrant, not the supporting affidavit.
+Yet the only specifie deficiency alleged by
+the patients was that the warrant authorized the seizure of virtually all medical
+records at the Institute while the supporting affidavit stated that patients' true
+home addresses were recorded only on patient billing and insurance récords. The
+patients' argument rests on the premise
+that the only purpose of the warrant was
+to "ascertain evidence of interstate shipment of antineoplastons." The warrant
+was sought, however, to authorize the seizure of evidence of numerous criminal offenses in addition to interstate distribution
+of antineoplastons. Since the seized medical records were relevant to all of those
+possible violations the warrant was facially
+valid, and the patients stated no basis for
+the district court to find seizure of the
+medical records unlawful, a prerequisite to
+mandating their return."
+Unlike the patients, Dr. Burzynski did
+attack the affidavit supporting the war-
+However, he neither alleged nor
+proved a single fact on which the district
+court could have found the affidavit deficient and the resulting warrant and seizure
+unlawful.
+As an incident to the separation of powers founded in the Constitution, "the courts
+are not to interfere with the free exercise
+of the discretionary powers of the attorneys of the United States in their control
+over criminal prosecutions."" Furthermore, to the extent that an injunction
+against providing the seized documents to
+"any other person or entity" would prohibit
+presenting the documents to a grand jury,
+such an injunction would improperly interfere with the mission of the grand jury
+which "must be free to pursue its investigations unhindered by external influence or
+supervision... "3
+"The Fifth Amendment guarantees that no civilian may be
+brought to trial for an infamous crime 'unless on a presentment or indietment of a
+Grand Jury. This constitutional guarantee
+presupposes an investigative body 'acting
+independently of either prosecuting attorney or judge....
+Since neither Dr. Burzynaki nor the patients alleged even one arguably improper
+use of the seized records, the distriet court
+had no proper choice but to dismiss the
+requests to enjoin use of the seized records
+by the government.
+B. Use of the Seized Records
+[11] Both the patients and Dr. Burzyn-
+C. Communications with Patients or
+ski seek to enjoin the government from
+Insurance Companies
+providing the records seized pursuant to
+[12] Similarly, the requests of Dr. Burthe search warrant to any other agents or
+zynski and the patients that the governagencies of the United States Government
+ment be enjoined from communicating with
+or to any commercial entity or to any other
+Dr. Burzynski's present and former paentity or person. While not alleging any
+tients and their insurance carriers, would,
+basis to believe that the government had
+if granted, have impeded or totally frusmade improper use of the seized records or
+trated the government's ability to pursue
+was likely to do so, Dr. Burzynski and the
+its investigation of, among other things,
+patients sought an injunction that, if grant interstate distribution of antineoplastons,
+ed, would have totally prevented the fraudulent over-billing and double-billing of
+insurance companies, and false statements
+to the government. Such an injunction
+34. Fed.R.Crim.P. 41(e).
+6. United States v. Dionisio, 410 U.S. 1, 17, S
+Cr. 764, 773, 35 L.Ed.zd 67 (1973
+35. United States v. Cox, 342 F.2d 167, 171 (5th
+Cir.) (en banc), cert. denied, 381 U.S. 935, 85
+S.Ct. 1767 (1965).
+37. Id. at 16, 93 S.Ct. at 772 (quoting Stirone v.
+United States, 361 U.S. 212, 218, 80 S.Ct. 270,
+273, 4 L.Ed.2d 252 (1960)).
+
+
+U.S. | BURZYNSKI CANCER RESEARCH INSTITUTE
+1313
+Cite as 819 F2d 1301 (5th Cir. 1987)
+would obviously have interfered with "the that "Dr. Burzynski's patients will be irrepfree exercise of the discretionary powers of
+arably harmed if this Court [the district
+the attorneys of the United States in their
+court] fails to require the FDA to grant
+control over criminal prosecutions." 38
+IND status to the Antineoplaston A10 compound ... in that many patients who could
+D. Alleged Interference with Treatment
+be helped by the use of antineoplastons will
+of Patients and Dissemination of
+be denied their Constitutional right of ac-
+False Information
+cess to Dr. Burzynski's treatment....
+Dr. Burzynski and the patients
+The district court, therefore, construed his
+asked the distriet court to enjoin the
+counterclaim correctly.
+government from interfering with Dr. Bur-
+Dr. Burzynski's own testimony demonzynski's treatment of the patients with anstrates that the FDA notified him in Februtineoplastons, both intrastate and interary 1984 that it found deficiencies in his
+IND application and required additional
+[13] The interference alleged included
+data. He candidly admits that he has neithe seizure of patient records pursuant to
+ther provided the data requested nor exthe search warrant, the refusal of the FDA
+plained to the FDA his reasons for considto grant investigational new drug status
+ering that data unnecessary. Thus, he has
+(IND) to the form of antineoplastons Dr.
+failed to make a good faith effort to obtain
+Burzynski is currently using, and the disan IND or to exhaust his administrative
+semination of false or misleading informa-
+His claim for injunctive relief
+tion about Dr. Burzynski and his treatment
+with respect to his IND was, therefore,
+to insurance companies and current or proproperly dismissed.*
+Many of these claims
+[15] The patients indirectly challenge
+are patently groundless. Just as the alle-
+FDA's action with respect to the IND,
+gations of unlawful seizure of patient
+alleging that their "constitutional right to
+records cannot support injunctive relief retravel freely between the states ... is bequiring return of the seized records, they
+ing infringed by the Government and its
+cannot form a cognizable basis for claiming
+agents through their continued refusal to
+that the government has or would interfere
+allow the interstate distribution and shipimpermissibly with Dr. Burzynski's treatment of antineoplastons."
+ment of patients solely within the State of
+Burzynski and his patients have failed to
+Texas. There simply has been no genuine
+allege facts suggesting that IND status
+issue of such a threat raised.
+was improperly withheld, this claim was
+[14] Similarly, neither Dr. Burzynski
+also dismissed properly. Moreover, to the
+nor his patients have alleged facts suggestextent that the patients' counterclaim can
+ing that the FDA has acted improperly by
+be construed as a challenge to the authoridenying antineoplaston A10 IND status.
+ty of the FDA to bar interstate distribution
+Although, in his brief before this court, Dr.
+of unapproved drugs, the claim is friv-
+Burzynski contends that he has never argued that he is entitled to IND status for
+[16] The patients' separate claim for inhis new drug but only that the FDA has
+junctive relief against interference with intreated his application differently than othterstate distribution of antineoplastons
+er IND applications, the language of his
+based on the asserted "constitutional right
+counterclaims belies that assertion. In his
+to obtain medical treatment that is encomcountercomplaint, Dr. Burzynski asserted
+passed by their right to privacy," was also
+38. United States Cox, 342 F.2d at 171.
+40. See United States v. Lebman, 464 F.2d 68,
+73-74 (5th Cir.), cert. denied, 409 U.S. 950. 93
+39. See Rutherford - American Medical Associa
+ion, 379 F.2d 641|(7th Cir.1967), cert. denie
+S.Ct. 271, 34 L.Ed.2d 220 (1972).
+389 U.S. 1043, 89 S.Ct. 787, 19 L.Ed.2d 835
+819F.2d-30
+
+
+1314
+unsupportable. The patients asserted that parties, therefore, should not have been
+they should be free to obtain antineopladismissed until Dr. Burzynski and his pastons interstate because of "the unavailatients had an opportunity to discover the
+bility of any other treatment that would be
+scope of the problem and to provide evieffective in treating their cancer." Similar
+dence that an injunction is necessary.
+claims were raised and rejected in United
+Of course, nothing in this opinion should
+be construed as suggesting that the FDA
+As in the present case, the plaintiffs in
+acted improperly by expressing its position
+Rutherford were cancer patients, alleged
+with regard to the status of antineoplato be terminally ill, desiring treatment with
+stons, ie., that they are drugs that may not
+an unapproved drug, and arguing that the
+lawfully be introduced into interstate comrestrictions on interstate distribution of
+merce because they are not approved by
+new drugs imposed by the Act should not
+the FDA or the subject of an acceptable
+be allowed to interfere with their access to
+IND. Such information is not false, mis-
+The Supreme Court rejected the
+leading, or inaccurate.
+patients' claims. The Court agreed with
+The FDA also cannot be required to com-
+FDA that the new drug approval provisions
+municate what the patients view as "favorof the Food, Drug, and Cosmetic Act speable" information. According to Dr. Burcifically applied to the situation presented.
+zynski and some of his patients, relevant
+[17] In one respect, however, the fact
+"favorable information" is that antineoplathat Dr. Burzynski and his patients were
+ston therapy has proved beneficial to some
+denied any opportunity for discovery has
+cancer patients. The views of Dr. Burzynunfairly prejudiced their opportunity to alski and his patients, however, do not constilege facts in support of counterclaims that
+tute "favorable" information on which
+may entitle them to relief. The distriet
+FDA may properly rely. "[W]hen the subcourt found that at least two statements
+ject of investigation is the existence of
+made by Ewing in
+response to inquiries
+cancer, the personal testimony of the lay
+about Dr. Burzynski and his
+sufferer is entitled to no weight....** 42
+were "near to inappropriate," exceeded
+Furthermore, as the Supreme Court found
+"his duties and responsibilities as an officer
+in Weinberger u. Hynson, Westcott and
+of the FDA," and misled his audience by
+Dunning, Inc.,*:
+asserting, as established fact, charges still
+[FDA's] strict and demanding standards,
+subject to investigation. The district court
+barring anecdotal evidence indicating that
+also noted that, by showing that such statedoctors "believe" in the efficacy of a
+ments were made to at least one insurance
+drug, are amply justified by the legislacompany, Dr. Burzynski and his patients
+demonstrated that *the above conduct has
+tive history [of the Food, Drug, and Coshad an impact on their ability to treat pametic Act]. The hearings underlying the
+1962 Act show a marked concern that
+tients because over fifty percent of [the
+impressions or beliefs of physicians, no
+Institute's] income is derived from insurmatter how fervently held, are treacherance payments." Whether additional exous.
+amples of such questionable conduct exist
+and, if so, in numbers justifying injunctive
+relief can only be discerned through dis-
+The Civil Contempt Claim Against
+covery. The claim seeking an injunction to
+the Government and its Employees
+stop the government from disseminating
+[18] The same conduct by the governfalse or misleading information to outside
+ment and its employees alleged as the basis
+41. 442 U.S. 544, 99 S.Ct. 2470, 61 L.Ed.2d 68
+43. 412 U.S. 609, 619, 93 S.Ct. 2469, 2478, 37
+(1979).
+L.Ed.2d 207 (1973) (footnote omitted).
+42. United States v. Hossey Cancer Clinic, 198
+F.2d 273, 280 (5th Cir.1952), cert. denied, 346
+U.S. 897, 74 S.Ct. 220, 98 L.Ed. 398 (1953).
+
+
+OWENS & KRITIKOS, INC. | C.I.R.
+1315
+Cite as 819 F.2d 1315 (5th Cir. 198:
+for the damages and injunctive claims of
+hastily with the mission of FDA or to dis
+Dr. Burzynski and the patients formed the
+ract us from our duty to uphold the law.
+basis of their requests to hold the government and its employees in civil contempt.
+Dr. Burzynski and the patients apparently
+do not appeal from the dismissal of their
+civil contempt claims. Their briefs to this
+further proceedings consistent with this
+court assign no error to the dismissal of
+those claims. But, even if they do appeal
+this ruling, the requests for a finding of
+civil contempt were also without foundation, and the district court's dismissal of
+those claims was proper.
+The permanent injunction, of which the
+government and its employees were alleged
+to be in contempt, imposed no restrictions
+or obligations on the government or its
+employees, except that FDA was directed
+to review, evaluate, and appraise the manufacturing practices of the Burzynski Re-
+OWENSBY & KRITIKOS, INC., Petro-
+Marine Engineering, Ine. & Subsidiar
+ies, John W. Owensby & Dolores G
+Owensby, Theodore A. Kritikos & Be Jo
+Kritikos, Petitioners,
+search Institute and promptly advise Dr.
+Burzynski of any violations of current good
+manufacturing practices.
+neither Dr. Burzynski nor the patients raised
+that issue in their counterclaims as a basis
+for a contempt citation or any other relief,
+the issue was raised at the hearing on Dr.
+Burzynski's motion for a temporary restraining order. However, as the record
+shows, FDA has advised Dr. Burzynski of
+COMMISSIONER OF INTERNAL
+REVENUE, Respondent.
+No. 86-4073.
+United States Court of Appeals,
+Fifth Circuit.
+June 26, 1987.
+its position with respect to his manufacturing practices, and so is in compliance with
+its obligations under the permanent injunetion.
+The patients who appear in this suit are
+in a critical plight. They seek any treatment that offers them the slightest hope,
+for they think it better to exhaust any
+possibility than to resign themselves to a
+fate that seems otherwise certain.
+FDA has been assigned the duty of protecting such desperate persons from deception,
+abuse, and exploitation and of assuring
+that the treatment they are given is safe
+Two shareholder employees of three
+closely held corporations disputed determination of Commissioner of Internal Reve
+nue that amounts paid to the individuals
+exceeded reasonable compensation for services. The United States Tax Court found
+that amounts paid as compensation for two
+taxable years were in part unreasonable
+Taxpayers appealed. The Court of Ap
+peals, Wisdom, Circuit Judge, held that
+finding that compensation paid to individuals in part constituted a dividend, rather
+than compensation for services rendered,
+and effective. It cannot perform these
+tasks if those professing to offer new cures
+Affirmed.
+refuse to work with the system and obey
+the law, whether their motives be noble or
+ill. This court, therefore, must not allow
+1. Internal Revenue 6-3321, 3323
+sympathy for the plight of persons suffer-
+A corporation may deduct compensa
+ing from cancer to cause us to interfere
+tion paid to employees only to the extent i
+
+
+791
+either a clear probability or well-founded backgrounds sued for damages and declarfear of persecution.
+The applications for
+atory injunction relief arising from a prewithholding of deportation and political
+liminary investigation into possible violaasylum were properly denied.
+tions of the Voting Rights Act. The Unit-
+DENIED.
+ed States District Court for the Northern
+Distriet of California, Spencer Williams and
+Stanley A. Weigel, JJ., dismissed injunction
+claims and granted summary judgment in
+favor of the United States Attorney and
+county officials. Appeal was taken.
+The
+Court of Appeals, Wallace, Circuit Judge,
+Jose J. OLAGUES, on Behalf of himself
+and all others similarly situated,
+Plaintiffs-Appellants,
+held that: (1) the citizen did not have standing to challenge the investigation, but the
+organizations did; (2) there were no extraordinary circumstances to warrant injunctive relief; (3) the organizations were
+Joseph P. RUSSONIELLO, individually
+not entitled to a declaratory judgment; (4)
+and in his capacity as United States
+there was not basis for an injunction
+Attorney for the Northern District of
+against county officials which would, in
+California, et al., Defendants-Appellees.
+effect, enjoin the United States Attorney
+Jose J. OLAGUES, on Behalf of himself
+from pursuing his investigation; and (5)
+and all others similarly situated; Histhere was no implied private action under
+panic Coalition for Human Rights, Chi- the Voting Rights Act for damages.
+nese for Affirmative Action, and San
+Francisco Lation Voter Registration
+Project, Plaintiffs-Appel-
+Nelson, Circuit Judge, concurred in
+part and dissented in part with opinion.
+Joseph P. RUSSONIELLO, individually
+1. Federal Courts e-12
+and in his capacity as United States
+Attorney for the Northern Ca; O'Mal-
+Claims for equitable relief become
+ley, William A., individually and in his
+moot when challenged activity ceases if
+capacity as District Attorney for Consubsequent events show that activities
+tra Costa County; Underwood, Lon, incould not reasonably be expected to recur,
+dividually and in his capacity as regisunless there is possibility of continuing.
+trar of voters for Contra Costa County;
+present adverse effects.
+Smith, Arlo, individually and in his capacity as District Attorney for San
+2. Federal Courts •-12
+Francisco County, et al, Defendants-
+Voluntary cessation of challenged ac-
+Appellees.
+tivity by government official is insufficient
+to render case moot if legality of chal-
+Nos. 82-4427, 83-2581,
+lenged practices is still in dispute because
+United Staint Gire of Appeals,
+official is free to return to his old ways.
+Argued and Submitted Sept. 12, 1984.
+Decided Sept. 3, 1985.
+voting fish to of Anitain promoting
+3. Federal Courts •-12
+Case or controversy for purposes of
+Article III may remain live following cessation of challenged activity if actions are
+capable of repetition and of evading review. U.S.C.A. Const. Art. 3, § 1 et seq.
+
+
+792
+4. Federal Courts • 13.20
+Action challenging investigation by
+United States Attorney as to whether reg
+istered voters were American citizens was
+not rendered moot by Attorney's termination of investigation where Attorney terminated investigation solely because it
+failed to produce evidence supported any
+further investigative activities, Attorney
+argued vigorously that his actions were
+lawful and there was no showing that investigation conducted in same
+manner
+against same groups would not recur.
+U.S.C.A. Const. Art. 3, § 1 et seq.
+5. Injunction 114(2)
+9. Injunction e=110
+District court had jurisdiction over
+complaint seeking to enjoin preliminary investigation of United States Attorney into
+whether registered voters were citizens.
+10. Administrative Law and Procedure
+District court has no power to monitor
+executive investigations before case or controversy arises.
+11. Injunetion e-105(1)
+There were no extraordinary circumstances to justify injunetive relief against
+investigation by United States Attorney
+into citizenship status of recently registered, foreign-born voters.
+to enjoin prosecutorial activities concerning
+whether noncitizens were registered to
+12. Constitutional Law &-213.1(1)
+vote where possibility that voter registra-
+Language-based classification is not
+tion records would again be scrutinized was
+equivalent of national origin classification
+entirely speculative and no official action
+and does not denote suspect class requiring
+was taken other than verifying citizenship
+U.S.C.A. Const.
+status of voters.
+13. Constitutional Law •=82(8)
+6. Injunction @=114(2)
+Although voting is considered funda-
+Organizations which conducted voter
+mental right, no "burden" was placed on
+registration drive among ethnic groups had
+anyone's right to vote by United States
+standing to challenge investigation into
+Attorney's preliminary investigation into
+whether registered voters
+were citizens
+citizenship status of recently registered
+where they alleged that their voter regisforeign-born voters so as to require heighttration and education efforts had been hinened scrutiny. U.S.C.A. Const.Amend. 14.
+dered as direct result of challenged investigation, organizations asserted that both
+14. Constitutional Law e=82(8)
+they and their members were threatened
+United States Attorney's investigation
+with possible prosecution, interests orgainto citizenship status of recently reg
+nization sought to protect were "germane"
+istered foreign-born voters and circumto their purposes and relief sought did not
+stances surrounding their registration did
+require participation of individual members
+not violate First Amendment rights of orin suit. U.S.C.A. Const. Art. 3, § 1 et seg.
+ganizations which conducted registration
+drives among ethnie groups. U.S.C.A.
+1. Injunction *-126
+Const.Amend. 1.
+Although case may not be moot, plain-
+15. Constitutional Law e=213.1(2)
+tiff still has burden of showing that eguitable relief is necessary and mere possi
+When no "suspect class" is involved
+bility of future injury is insufficient to enand no fundamental right is burdened, rajoin official conduct.
+tional-basis test is used to determine legitimacy of classification. U.S.C.A. Const.
+8. Federal Courts •-814
+Amend. 14.
+There must be strong showing of 16. Elections *~324
+abuse of discretion to overturn denial of
+Voter fraud investigation limited to reinjunctive relief against official conduct. cently registered foreign-born voters seek-
+
+
+793
+ing bilingual ballots was reasonably limited tigation into citizenship status of those votin both its scope and its use of classificaers where there was no intent to intimidate
+tions. U.S.C.A. Const.Amend. 14.
+voters.
+17. Injunction $-138.78
+23. Elections 12(9)
+Organizations which conducted voter
+There is no implied private right of
+registration drives among ethnic groups
+action for violations of Voting Rights Act.
+were not entitled to preliminary injunction
+42 U.S.C.A. § 1971(b); Voting Rights Act
+against United States Attorney's investiga
+of 1965, 55 11(b), 203, as amended, 42 U.S.
+tion into possible voter fraud resulting
+C.A. §5 1973 (b), 1978aa-la.
+from registration of noneitizens.
+24. Civil Rights e-13.8(3, 6)
+18. Declaratory Judgment 6=5
+United States Attorney and county of
+Decision whether to grant declaratory
+ficials who participated in investigation of
+relief is within sound discretion of district
+recently registered foreign-born voters
+court. 28 U.S.C.A. §5 2201, 2202.
+who requested bilingual ballots, for purposes of determining whether voter fraud
+19. Deelaratory Judgment @4
+occurred, were entitled to at least qualified,
+Declaratory relief may be appropriate
+good-faith immunity from liability under
+even when injunetive relief is not. 28 U.S.
+civil rights statute. 42 U.S.C.A. § 1983.
+C.A. §5 2201, 2202.
+20. Declaratory Judgment $-84
+Organizations which conducted voter
+registration drives among ethnic groups
+were not entitled to declaratory judgment
+against investigation of citizenship status
+of recently registered foreign-born voters
+seeking bilingual ballots where organizations
+were not generally hindered from
+pursuing their lawful voter registration activities at time of imminent criminal prosecation.
+28 U.S.C.A. §§ 2201, 2202.
+Joaquin G. Avila, Ronald T. Vera, Alan
+L. Schlosser, American Civil Liberties Un-
+ion, San Francisco, Cal., and Kathleen A.
+Pool, California Rural Legal Assistance,
+Marysville, Cal., for plaintiffs-appellants.
+William T. MeGivern, and John D. O'Con-
+Tarkington, Carey, O'Connor &
+O'Neili, San Francisco, Cal., for defendants-appellees.
+Appeal from the United States Distriet
+Court for the Northern District of Califor-
+21. Injunction 105(1)
+Where county officials
+names of recently registered foreign-born
+Before WALLACE, ALARCON, and
+voters who requested bilingual ballots at
+NELSON, Cireuit Judges.
+specific request of United States Attorney,
+who was investigating possible voter fraud,
+WALLACE, Circuit Judge:
+there was no basis for injunction against
+county officials which would, in effect, en-
+Olagues, a citizen, and certain organizations promoting the voting rights of Amerijoin United States Attorney from pursuing
+cans with Hispanic or Chinese ethnie backhis investigation.
+grounds in the San Francisco Bay area (the
+22. Elections 12(4)
+organizations) sued for damages and de-
+There was no violation of Voting
+claratory and injunctive relief arising from
+Rights Act [42 U.S.C.A. § 1971(b); Voting
+a preliminary investigation by the United
+, Rights Act of 1965, 4§ 11(b), 203, as
+States Attorney and various state officials
+amended, 42 U.S.C.A. §§ 1973i(b), 1978aa- into possible violations of the Voting
+la] in county officials' conduct of forward Rights Act of 1965, 42 U.S.C. $ 1973(e), (d)
+ing names of recently registered foreign- (the Act), which prohibits the illegal regisborn voters who requested bilingual ballots tration of voters or conspiracies to illegally
+to United States Attorney as part of inves- register voters. Olagues and the organiza-
+
+
+794
+tions claim violations of their rights under
+were not citizens be interviewed thereafter.
+the Act and the first, fifth, fourteenth, and
+Russoniello stated that he did not intend to
+fifteenth amendments to the Constitution.
+prosecute any improperly registered vot-
+The district court dismissed the injunctive
+ers, but that he would consider prosecuting
+elaims on the ground that it lacked jurisdieindividuals who deliberately conspired to
+tion to enjoin an investigation by the Unitregister unqualified voters if evidence of
+ed States Attorney. The district court also
+such impropriety surfaced.
+granted summary judgment in favor of the
+The local officials responded by forward
+United States Attorney and the state offiing the names of 168 persons, one of whom
+cials on the remaining claims.
+We have
+was Olagues, from the publie voting lists
+jurisdiction pursuant to 28 U.S.C. § 1291,
+which were subsequently checked by the
+INS. At Russoniello's request, local officials then conducted voluntary interviews
+with some of the 113 individuals whom the
+INS could not positively identify as citizens
+to determine their eitizenship and, if the
+individuals proved not to be United States
+citizens,
+the circumstances surrounding
+their registration. No further investigation occurred.
+I
+In March and April of 1982, United
+States Attorney Russoniello received information from the Santa Clara County district
+attorney indicating that a substantial number of foreign-born individuals who had
+recently registered to vote were not United
+The information was contained in a study of recent voter regis-
+II
+trants whose primary language was not
+Because the investigation has terminat-
+English. Many of the noncitizen
+regised, we first must determine whether there
+trants apparently believed or were told that
+remains a live controversy for purposes of
+they were entitled to vote on the basis of
+granting equitable relief.
+There is no
+marriages to United States citizens or a
+question that a controversy remains with
+long period of residence in the
+United
+respect to damages.
+States. Russoniello also was informed that
+the Spanish translation of the voter regis-
+[1] We begin this analysis with the rectration form erroneously stated that regisognition that "[p]ast exposure to illegal
+trants "should be" a United States citizen,
+conduct does not in itself show a present
+rather than stating one "must be" a citizen.
+case or controversy" for equitable relief
+Russoniello then sent a letter on April
+O'Shea v. Littleton, 414 U.S. 488, 495, 94
+19, 1982, to law enforcement officers and
+S.Ct. 669, 675, 38 L.Ed.2d 674 (1974)
+voter registrars in nine local counties with-
+(O'Shea). Claims for equitable relief therein his jurisdiction requesting their cooperafore become moot when the challenged ac
+tion in obtaining a sampling of names from
+tivity ceases if subsequent events
+show
+voter registration lists in order to deterthat the activities "could not reasonably be
+mine whether the improper registration
+expected to recur," Chinese for Affirmaproblem noticed in Santa Clara County was
+tive Action v. Leguennec, 580 F.2d 1006,
+more widespread. The letter requested the
+1009 (9th Cir. 1978), cert. denied, 439 U.S.
+forwarding of 25 names, randomly select-
+1129, 99 S.Ct. 1047, 59 L.Ed.2d 90 (1979),
+ed, of recently registered, foreign-born votunless there is a possibility of "continuing
+ers who requested bilingual ballots. The
+present adverse effects." O'Shea, 414 U.S.
+letter indicated that upon receipt of the
+at 496, 94 8.Ct. 676.
+sampling, the names would be forwarded
+[2,3] There is a heavy burden, howto the Immigration and Naturalization Ser ever, on the defendant to show that there is
+vice (INS) to determine each individual's no reasonable expectation of repetition.
+citizenship status. He recommended that United States u. W.T. Grant Co., 345 U.S.
+those individuals who the INS indicated 629, 633, 73 S.Ct. 894, 897, 97 L.Ed. 1303
+
+
+OLAGUES - RUSSONIELLO
+(1953) (W.T. Grant). Voluntary cessation
+tions correctly observe that election offiof the challenged activity by the official is
+cials in San Francisco, Santa Clara, Alameinsufficient to render a case moot if "the
+da and Monterey counties will continue to
+legality of the challenged practices" is still
+provide the same bilingual ballot materials
+in dispute because "[t]he defendant is free
+as previously required by section 203(b) of
+to return to his old ways." Id. at 682, 78
+the Voting Rights Act, 42 U.S.C. $ 1913aa-
+S.Ct. at 897.
+See Allee u. Medrano, 416
+1a(b). Thus, Russoniello will continue to
+U.S. 802, 810-11, 94 S.Ct. 2191, 2197-98, 40
+have the means available to conduct an
+L.Ed.2d 566 (1974); Walling . Helmerich
+investigation similar to the one challenged
+& Payne, Inc., 323 U.S. 37, 43, 65 S.CL. 11,
+here. It is immaterial that the tools useful
+29 (1944);
+for discriminatory purposes are furnished
+County of Los Angeles, 674 F.2d 1288,
+by the state rather than by the federal
+1291 (9th Cir.1982) (claim is moot if subsegovernment; what matters is whether fedquent "events have completely and irrevoeral officials may utilize them.
+cably eradicated the effects of the alleged
+niello is certainly empowered to inviolation"'). Moreover, a case or controverelection fraud; it would not be
+sy for purposes of article III may also
+unreasonable to believe that a similar inremain live following cessation of the chalvestigation might arise at some point in the
+lenged activity if the actions are capable (1)
+future. Thus, the same issues are capable
+of repetition and (2) of evading review.
+of repetition. At the same time, these in-
+See, eg., Super Tire Engineering Co. t
+vestigations, such as the one in the present
+McCorkle, 416 U.S. 115, 122, 94 S.Ct. 1694,
+case, may be of very short duration, mak-
+1698, 40 L.Ed.2d 1 (1974).
+Finally, the
+ing them effectively capable of evading
+existence of "a publie interest in having the
+by an appellate court.
+legality of the practices settled •• mil
+braska Press Association u. Stuart, 427
+against a mootness
+W.T. Grant, 345 U.S. at 632, 73 S.Ct. at 897
+U.S. 539, 546-47, 96 S.Ct. 2791, 2796-97, 49
+L.Ed.2d 688 (1976).
+(emphasis added).
+Other factors also suggest a live contro-
+[4] Applying this framework to the
+versy. The organizations argue that their
+several factors
+organizational efforts have been handipointing toward the continuing existence of
+capped as a result of the fear engendered
+a case or controversy for purposes of evalby this investigation.
+They contend that
+uating plaintiffs' equitable claims. First,
+unless the legality of the investigation is
+the United States Attorney did not volundetermined, they may continue to suffer
+tarily cease the challenged activity because
+despite the termihe felt that the investigation was improper.
+nation of the initial investigation. Further-
+Rather, Russoniello terminated the investimore, there is a significant publie interest
+gation solely because it failed to produce
+in addressing both the appropriateness of
+evidence supporting any further investigapermitting a challenge to a federal investi-
+Russoniello has at all times
+raises separation-of-powers
+continued to argue vigorously that his acconcerns, and the appropriateness of the
+tions were lawful.
+investigatory methods employed,
+Second, there has been no showing that
+raises voting rights and first amendment
+an investigation conducted in the same
+manner against the same groups would not
+This case is distinguishable from O'Shea
+reeur. Although Russoniello and the state
+and City of Los Angeles . Lyons, 461 U.S.
+officials point out that the Director of the
+95, 108 S.Ct. 1660, LEd.2d LEd.2d 675(1983)
+Census now has determined that these
+(Lyons). In O'Shea, the plaintitis chalcounties no longer must provide bilingual
+lenged certain arrest and bail procedures
+ballot materials, see 49 Fed.Reg. 25,887-88 employed by state law enforcement and
+(June 25, 1984), Olagues and the organiza- judicial officials. In order to be subject to
+
+
+796
+these alleged unlawful procedures, however, one would first have had to violate
+some law and then have been arrested.
+414 U.S. at 496, 94 S.Ct. at 676. The
+Supreme Court found that plaintiffs failed
+to show any case or controversy because it
+presumed that plaintiffs would obey the
+law, and therefore they never would become subject to any unlawful procedures in
+Id. at 497, 94 S.Ct. at 676.
+Unlike the situation before us, the O'Shea
+plaintiffs did not claim any constitutional
+right to act as they had prior to their
+arrest. See id. at 498, 94 S.Ct. at 677. In
+Lyons, the plaintiff challenged the use of
+chokeholds by Los Angeles police on arrestees. The Court again held that there was
+no case or controversy for equitable relief
+because whether Lyons would again be ar
+rested and subjected to a chokehold a seeond time was purely speculative. See 461
+U.S. at 105-06, 108 S.Ct. at 1667.
+Here, Olagues and the organizations
+claim that the actions of the officials have
+interfered with their constitutionally protected first amendment activities in registering voters. Unlike O'Shea and Lyons,
+neither Olagues nor the organizations had
+to break any law in order to be subjected to
+alleged unlawful conduct by the officials.
+Certainly the legality of the investigation
+at issue remains in dispute; both
+sides
+continue forcefully to advocate their positions. Russoniello has never seriously attempted to make any showing that the
+challenged investigative techniques will
+never be employed again; rather, he vigorously defends his investigative tacties.
+Thus, he fails to meet his "heavy burden"
+of showing mootness.
+W.T. Grant, 345
+U.S. at 683, 73 S.Ct. at 897.
+We recently summarized the law relating
+to standing required by article III of the
+Constitution:
+Standing is a threshold question in every case before a federal court. Before
+the judicial process may be invoked, a
+plaintiff must "show that the facts alleged present the court with a 'ease or
+controversy' in the constitutional sense
+and that (he] is a proper plaintiff to raise
+the issues sought to be litigated." A
+party seeking to invoke the court's authority must demonstrate "such a personal stake in the outcome of the controversy as to assure that concrete adverseness which sharpens the presentation of
+the issues upon which the court so largely depends...."
+The question of whether the plaintiff
+has standing involves both constitutional
+and prudential limitations. The constitutional limitations of article III involve
+three separate but interrelated components: first, a "distinct and palpable"
+injury to the plaintiff, be it "threatened
+or actual"; second, a
+"fairly traceable
+causal connection" between that injury
+and the challenged conduct of the defendant; and third, a "gubstantial likelihood" that the relief requested will redress or prevent the injury.
+McMichael | County of Napa, 709 F.2d
+1268, 1269-70 (9th Cir.1983) (citations omit-
+[5] Olagues
+standing under the Act if he is an "aggrieved person," broadly defined as one who has
+suffered an injury.
+Board of Elections, 393 U.S. 544, 554-57,
+89 S.Ct. 817, 825-2T, 22 L.Ed.2d 1 (1969)
+(Allen). He has alleged an injury: his
+request for a bilingual ballot triggered an
+III
+investigation of his records by the FBI and
+the INS and an interview by the local Dis-
+We next examine the standing of Olatrict Attorney. Juxtaposed against the
+gues, a foreign-born citizen who requested
+holding in Allen, however, is the general
+bilingual election materials, and the orgabar against the invocation of federal equity
+nizations, which claim that the challenged jurisdiction in criminal prosecutions when
+investigatory activities will "effectively
+the plaintiff is not being prosecuted or
+deny their right to participate in the electhreatened with prosecution. See Linda
+toral process."
+R.S. v. Richard D., 410 U.S. 614, 617-19,
+
+
+797
+) F.2d 791 (1985)
+93 S.Ct 1146, 1148-49, 36 L.Ed.2d 536 13-14, 92 S.Ct. 2318, 2325-26, 33 L.Ed.2d
+(1973);
+Younger v. Harris, 401 U.S. 37,
+154 (1972). We need not pass on the "stig-
+50-54, 91 S.Ct. 746, 753-55, 27 L.Ed.2d 669
+ma". claim as a basis for standing. The
+(1971) (Younger). In order to harmonize
+only time it could have arisen was after
+these conflicting strains of precedent arispublic diselosure that the investigation was
+ing in this particular factual circumstance,
+taking place, which apparently was self-inwe find it necessary to focus on the nature
+duced by the filing of this lawsuit. In the
+of the relief sought by Olagues.
+absence of standing to pursue equitable
+Here, Olagues is not seeking any affirmrelief, Olagues' individual claim for relief is
+ative injunctive relief in order to permit
+therefore relegated to one for damages
+him to vote, such as demanding that he be
+only for any direct injuries which might
+listed as an eligible voter. Rather, he
+have occurred as a result of the investigaenjoin prosecutorial activities
+tion directed at others. See Lyons, 461
+which are focused on persons other than
+U.S. at 111, 103 S.Ct. at 1670 (damage
+himself. Moreover, it does not appear that
+remedy is adequate when there is no show-
+Olagues has demonstrated that he would
+ing of future injury).
+suffer irreparable harm without equitable
+relief. Unlike the organizations,
+[6] The organizations' standing relege that their current voter registration
+quires more extensive analysis. Chinese
+efforts are being hindered by the fear that
+for Affirmative Action is a voluntary memthey may possibly be subject to a similar
+bership group that seeks to protect the
+investigation in the future, the possibility
+rights of Chinese-Americans. It monitors
+that Olagues's voter registration records
+compliance with bilingual election requirewill be scrutinized again is entirely speculaments and encourages Asian-Americans to
+Olagues thus
+faces the barrier of
+register and to vote. The Hispanie Coali-
+Lyons, which emphasizes that the irreparation for Human Rights is an association of
+ble harm showing is "a requirement that
+Hispanie organizations and persons of Mexcannot be met where there is no showing of
+ican descent, with a goal of securing the
+any real or immediate threat that the plaincivil rights of Hispanies. It encourages
+tiff will be wronged again." 461 U.S. at
+them to register and to vote, and advises
+111, 103 S.Ct. at 1670.
+them on the availability of bilingual elec-
+Under these circumstances, we conclude
+The San Francise Latino
+that Olagues has failed to overcome the
+Voter Registration Education Project is a
+prudential limitations on standing that are
+coalition of Hispanic groups that was conparticularly important when evaluating
+ducting a voter education and registration
+claims for equitable relief regarding a crimdrive at the time of the investigation. The
+The injuries he alleges
+organizations allege that the investigation
+are insufficient to warzant such an intruhas hindered their efforts to encourage citi-
+Since he is a citizen, it cannot
+zens of Hispanic and Chinese ethnie backbe seriously contended that Olagues has
+grounds to participate in the electoral probeen or will be denied his right to vote as a
+cess and that it was aimed at investigating
+result of an examination of publie records.
+how they registered voters, thus intimidat-
+No official action has been taken against
+ing them in such activities.
+They also fear
+him, other than verifying his citizenship
+disclosure of their organizational memberstatus along with those individuals who
+They claim direct injury both to
+were initially identified as improperly regthemselves and to their members.
+istered. The principal claim of present injury is that the investigation has had a
+An associational plaintiff has standing to
+"chilling effect" on and "stigmatized" him.
+seek redress of direct injury to the orga-
+However, mere "allegations of a subjective
+nization itself. See Simon 1. Eastern
+"chill'" do not suffice to present a justicia-
+Kentucky Welfare Rights Organization,
+ble claim. Laird . Tatum, 408 U.S. 1,
+426 U.S. 26, 27, 40, 96 S.Ct. 1917, 1919,
+
+
+48 L.Ed.2d 450 (1976) (Simon);
+tions of the Voting Rights Act.
+Warth v. Seldin, 422 U.S. 490, 511, 95 S.Ct.
+Russoniello's letter as evidence that such
+2197, 2211, 45 L. Ed.2d 343 (1975) (Warth);
+prosecution was possible. They further as-
+NAACP v. Button, 371 U.S. 415, 428, 83
+sert that they are undoubtedly the targets
+S.Ct. 328, 335, 9 L. Ed.2d 405 (1963). Under
+of Russoniello's investigation and may be
+certain circumstances, an association may
+charged with improperly influencing inelialso be entitled to seek redress of injury to
+gible persons to register.
+its members. See, e.g., Hunt v. Washington State Apple Advertising Commis-
+A preliminary issue is whether the invession, 432 U.S. 333, 342, 97 S.CL 2434, 2440,
+tigation may be fairly characterized as hav-
+58 L.Ed.2d 388 (1977) (Hunt); Simon, 426
+ing been "targeted" at these organizations
+U.S. at 40, 96 S.Ct. at 1925;
+The investigation
+U.S. at 511, 95 .Ct. at 2211; Sierra Club
+sought to determine whether there existed
+v. Morton, 405 U.S. 727, 739, 92 S.Ct. 1361,
+any unlawful conspiracies to register ineli-
+1368, 31 L.Ed.2d 636 (1972) (Sierra Club).
+gible foreign-born voters.
+In Hunt, the Supreme Court established a
+sample of voters employed focused solely
+three-part test to determine whether an
+on foreign-born registrants who sought biassociation has standing: (1) either the
+lingual ballots.
+Russoniello's letter indigroup or its members must have suffered
+cates that groups targeting citizens of Chisome direct, cognizable injury; (2) the innese and Hispanic ethnie backgrounds were
+terests the group seeks to protect must be
+the source of his concern.
+"germane to the organization's purpose";
+stated that he did not challenge their right
+and (3) the claim or relief sought must not
+to conduct registration drives, he did not
+require the participation of the individual
+disavow future prosecutions against permembers in the suit. 482 U.S. at 348, 97
+sons conspiring to register noncitizens.
+S.Ct. at 2441. A mere "abstract concern,"
+When any voter whose name was chosen at
+Simon, 426 U.S. at 40, 96 S.Ct. at 1925, or
+random initially appeared to be unqualified,
+"special interest" in a publie issue, Sierra
+he sought follow-up questioning to deter-
+Club, 405 U.S. at 739, 92 S.Ct. at 1368,
+mine who registered the voter and what
+however, is legally insufficient to confer
+representations had been made as to the
+qualifications necessary to vote. It is not
+The organizations claim standing on two
+difficult to conclude from this fact that the
+First, they assert a direct injury:
+investigation was sufficiently "targeted" at
+their voter registration and educational ef.
+the organizations and their members for
+forts have been hindered as the direet repurposes of our analysis. Their principal
+sult of the challenged investigation, in viaactivities were directed specifically at reg
+lation of their first amendment and associaistering and counseling voters who would
+tional rights. They claim that the investifall within the classification on which the
+gation has discouraged members from parinvestigation was based.
+That they were
+ticipating in their associational activities
+not specifically named as targets does not
+and that it will lead to disclosure of organizational membership, thus undermining
+We now analyze these organizations'
+their voter education and registration efstanding under Hunt's three-part test.
+Because the investigation involved The first hurdle is whether the groups or
+questioning of voter registrants as to who their members may have suffered any dihad assisted them in registering, they con- rect, cognizable injury. We conclude that
+tend, it inherently delved into their associathe organizations' allegations raise suffitional activities and membership in violation of their constitutional rights.
+cient claims of potential direct injury to
+both themselves and their members. The
+Second, the organizations assert that
+Supreme Court has recognized previously
+both they and their members are threat
+that a group may have standing even if it
+ened with possible prosecution for viola- is only derivatively injured as the result of
+
+
+799
+the prosecution or threat of prosecution of the mere possibility of future injury is inits members. See Allee o. Medrano, 416
+sufficient to enjoin official conduct. More-
+U.S. 802, 829-30 & n. 6, 94 S.Ct. 2191, 2207
+over, there must be "a strong showing of
+& n. 6, 40 L.Ed.2d 566 (1974) (Burger, J.,
+abuse" of discretion to overturn a denial of
+concurring in part and dissenting in part).
+such relief. Id. We also keep in mind the
+In the case before us,
+the organizations"
+Supreme Court's admonition that any invoter education and registration efforts are
+junction regarding government functions is
+unquestionably protected from unwarrantgenerally only permitted in "extraordinary
+ed interference by prosecutorial officials;
+circumstances," Rizzo v. Goode, 423 U.S.
+whether the investigation actually involved
+362, 379, 96 S.Ct. 598, 608, 46 L.Ed.2d 561
+any unwarranted intrusions into their asso-
+(1976), as officials should be given the
+ciational activities solely affects the merits
+"widest latitude" possible while performing
+of their claim, not their standing. Moretheir official duties. Id. at 378, 96 S.Ct. at
+over, unlike Olagues, members who partici-
+607.
+pated in the organizations' counseling ac-
+[9] The organizations seek to enjoin a
+tivities and voter registration drives are
+preliminary investigation of a United
+potential targets of future prosecutions.
+States Attorney. The district court dis-
+Thus, the bar to invocation of federal equimissed the organizations' complaint on the
+ty jurisdiction faced by a plaintiff who is
+grounds that "as a matter of law," it
+not being prosecuted or threatened with
+lacked "jurisdiction to enjoin or otherwise
+prosecution is not applicable. See Linda
+control" such an investigation. We review
+R.S. t. Richard D., 410 U.S. 614, 93 S.Ct.
+the legal question of jurisdiction de novo.
+1146, 35 L.Ed.2d 536 (1973); Younger 1.
+E.g., United States #. Oregon, 718 F.2d
+Harris, 401 U.S. 37, 91 S.Ct. 746, 27
+299, 303 & n. 5 (9th Cir.1983). The district
+L.Ed.2d 669 (1971).
+court erred in its ruling that it lacked juris-
+The next inquiry is whether the interests
+diction. See, e.g, Jett ». Castaneda,
+578
+the organizations seek to protect are "ger-
+F.2d 842, 845 (9th Cir.1978) (Jett).
+mane" to the purposes of the organiza-
+[10]
+We have recognized, however, that
+tions. Hunt, 482 U.S. at 343, 97 S.Ct. at
+as a general proposition, a district court
+2441.
+We conclude that they are. The
+has no "power to monitor executive investiorganizations' activities are centered on
+gations before a case or controversy
+voter education and registration. Such acarises." Jett, 578 F.2d at 845.
+tivities are directly related to the individual
+United States v. Coz, 342 F.2d 167, 171
+(5th Cir.) (en banc) ("courts are not to inter.
+fere with the free exercise of the discreranted prosecutorial intrusions.
+Finally, the relief sought by the organizations does not require the participation
+of individual members in the suit. The
+principal claims are for injunctive and declaratory relief; such equitable relief is
+particularly suited for group representation. See Warth, 422 U.S. at 515, 95 S.Ct.
+at 2218. Thus, we conclude that the organizations have standing.
+tionary powers of the attorneys of the
+United States in their control over criminal
+prosecutions"), cert. denied, 381 U.S. 935,
+85 S.Ct. 1767, 14 L.Ed.2d 700 (1965).
+emphasized that intrusions into the investigative process of a United States Attorney
+present "difficult problems of separation of
+circumstances would we entertain an action
+to enjoin a prosecutor's investigatory activ-
+IV
+ities. See id. ("prosecutor may be subject
+[7, 8] Although a case may not be moot,
+to a suit to enjoin egregiously illegal con-
+a plaintiff still has the burden of showing
+duet"'). See also United States v. Chanen,
+that equitable relief is necessary, see W.T.
+549 F.2d 1806, 1813 (9th Cir.) ("a court may
+Grant, 345 U.S. at 638, 78 S.Ct. at 897, and
+not exercise its 'supervisory power' in a
+
+
+800
+way which encroaches on the prerogatives
+riam), the district court enjoined the enof [a prosecutor] unless there is a clear
+forcement of a subpoena requiring the disbasis in fact and law for doing so," because
+closure of contributions to a political party.
+of separation of powers constraints), cert
+Such disclosure of what was then condenied,
+434 U.S. 825, 98 S.Ct. 72, 54
+sidered confidential data would have result-
+L. Ed.2d 83 (1977) (Chanen).
+ed in immediate, irreparable harm to the
+[11] The organizations alleged that the
+plaintiffs' clear first amendment interests.
+United States Attorney lacked a reasonable
+As a result, the court placed a minimal
+basis for initiating the investigations.
+The
+burden on the prosecutor to show that the
+district court should therefore have detersubpoena was rationally related to a legitmined whether any extraordinary
+circumimate investigation, 288 F.Supp. at. 256, a
+stances were present. Because we may
+burden that he failed to meet.
+affirm the district court's ruling on any
+Courts have rejected attempts to interbasis fairly presented by the record, howfere with an investigation by a United
+ever, see Keniston v.
+• 717 F.2d
+States Attorney in two similar instances.
+1295, 1300 n. 3 (9th Cir.1988), we consider
+In LaRouche, contributors and organizawhether there were extraordinary circumtions supporting a Congressman sued for
+stances, Jett, 578 F.2d at 845, present reinjunctive and declaratory relief in regard
+quiring injunetive relief. We conclude that
+no extraordinary circumstances are
+to an investigation into his campaign.
+investigation was triggered by a series of
+rested in the record, as indicated in our
+discussion in Part
+Because we hold that
+newspaper stories indicating potentially itinjunctive relief would not be appropriate,
+legal campaign financing activities.
+tiffs argued that the investigation was in
+we need not determine whether, as Olagues
+and the organizations claim, an action for
+bad faith with the intention of both chilling
+such relief may lie against federal officials
+the plaintiffs' exercise of their first amendunder the Act itself.
+ment rights of association and discouragfuture contributions. The United
+Other courts have been equally reluctant
+States Attorney's activities had been limitto intrude into the sphere of prosecutorial
+ed to questioning various contributors.
+authority. See Reporters Committee for
+ter noting the "almost insurmountable bur-
+Freedom of the Press . American Teleden" plaintiffs faced, the distriet court emphone & Telegraph, 593 F.2d 1030, 1065
+phasized that: "The decision to investigate,
+(D.C.Cir.1978) ("Only the most extraordilike the decision to prosecute, is one which
+nary circumstances warrant anticipatory
+the Constitution places in the executive
+judicial involvement in criminal investigabranch. The constitutional separation of
+tions."), cert, denied, 440 U.S. 949, 99 S.Ct.
+powers prevents the courts from interfer-
+1431, 59 L.Ed.2d 639 (1979) (Reporters
+Committee); LaRouche v. Webster, 566
+ing with the exercise of prosecutorial discretion except under the rarest of cireum-
+F.Supp. 415, 417 (S.D.N.Y.1983) ("party
+566 F.Supp. at 417. That court
+seeking to enjoin a criminal investigation
+limited its review to a determination of
+bears an almost insurmountable burden")
+(LaRouche); accord In re Grand Jury of
+believe that criminal activity may have takthe Southern District of Alabama, 508
+en place." Id. at 418. Beyond that, the
+F.Supp. 1210, 1214 (S.D.Ala.1980); In re
+court held that it was not its funetion to
+Grand Jury Subpoena to Central States,
+examine the "wisdom" or "motives" behind
+225 F.Supp. 923, 925 (N.D.III.1964).
+the decision to investigate. Id. In denying
+Only one court has actually found the all of plaintiffs' claims for relief, the court
+presence of sufficiently extraordinary cirfound that the mere "possibility of crimi-
+In Pollard v. Roberts, 283 nal activity" as alleged in the newspaper
+F.Supp. 248 (E.D.Ark.), af/d, 393 U.S. 14, articles was "sufficient to justify a criminal
+89 S.Ct. 47, 21 L.Ed.2d 14 (1968) (per eu- investigation." Id. Because the plaintiff
+
+
+OLAGUES
+RUSSONIELLO
+801
+made no showing of future investigatory
+No court has yet held that a languagemisconduet, an injunction with respect to
+based classification is the equivalent of one
+future investigations was also denied. Id.
+based on race or national origin requiring
+at 419.
+As to the fear that first amendheightened scrutiny as a "suspect class."
+ment rights were being chilled, the court
+Indeed,
+those courts which have faced this
+emphasized that the "compelling governissue have held that language-based classimental interest in investigating possible"
+fications are not the equivalent of national
+crime overrode such interests and that "the
+origin classifications. See Soberal-Perez u.
+mere asking of material questions does not
+Heckler, 717 F.2d 36, 41 (2d Cir.1983), cert.
+constitute a First Amendment violation."
+denied,
+, — U.S. —, 104 S.Ct. 1713, 80
+Id. at 418. See also Jones v. Unknown
+L.Ed.2d 186 (1984); Frontera v. Sindell,
+Agents of the Federal Election Commis-
+522 F.2d 1215, 1219-20 (6th Cir. 1975); see
+sion, 613 F.2d 864, 877-78 (D.C.Cir.1979)
+also Garcia v. Gloor, 618 F.2d 264, 268
+(reasonable questioning by Commission
+(5th Cir 1980) ("Neither [Title VII] nor comagents about campaign contributions does
+mon understanding equates national origin
+not chill first amendment rights), cert. dewith the language one chooses to speak."),
+nied, 444 U.S. 1074, 100 S.Ct. 1019, 62
+cert. denied, 449 U.S. 1113, 101 S.Ct. 923,
+L.Ed.2d 755 (1980).
+66 L.Ed.2d 842 (1981). We agree with
+Reporters Committee
+involved two
+these courts and hold that a languagenewspapers which sought injunctive and
+based classification is not the equivalent of
+declaratory relief from a telephone compa-
+a national origin classification, and does
+ny poliey of providing toll call records to
+not denote a suspect class.
+law enforcement officials, claiming first
+Unlike race, place of birth, or sex,
+and fourth
+amendment violations.
+The
+language is not one of those "immutable charcourt held that the first amendment providacteristics] determined solely by the accied no additional "shield" respecting privacy
+dent of birth" which typically are the basis
+interests beyond the fourth amendment's
+for finding a suspect class.
+Frontiero v
+protection in the context of a good faith
+Richardson, 411 U.S. 67T, 686, 93 S.Ct.
+criminal investigation.
+593 F.2d at 1054-
+1764, 1770, 36 L.Ed.2d 583 (1973).
+Al-
+55, 1058.
+The court emphasized the "parthough our first choice of language may be
+tieularly heavy burden"
+on plaintiffs deinitially determined to some extent "by the
+manding
+equitable relief in
+such circumstances dietated by separation of powers
+concerns, id. at 1065, and that mere speculation as to irreparable harm would
+suffice. Id. at 1067.
+In order to meet the
+burden, plaintiffs would have to establish
+"a clear and imminent threat of future
+[prosecutorial] misconduct."
+Id. at 1071.
+thereafter to choose another should we decide to undertake the initiative.
+bilingualism or multilingualism is hardly an
+extreme rarity today, as
+Olagues's own
+bilingualism exemplifies. Moreover, even
+if a significant percentage of those speaking a particular language can be shown to
+be of one "discrete and insular" racial or
+ethnie minority, United States v. Carolene
+Plaintiffs urge that the preliminary in-
+Products Co.,
+304 U.S. 144, 152 n. 4, 58
+vestigation in this case should be reviewed
+S.Ct. 778, 783 n. 4, 82 L.Ed. 1234 (1938), not
+by this court with "heightened scrutiny"
+all persons speaking that language would
+because it focused on a "guspect class" and
+be so situated. The court would thus face
+because a fundamental right is burdened.
+the problem of blurred lines defining those
+persons entitled to heightened protection
+[12] Initially, the organizations argue
+from use of the challenged classification,
+that a classification based on an individu- with the possibility of overbroad protectior
+al's choice of language is a form of discrim- leading to the striking down of otherwise
+ination based on race or national origin. rationally based official action. The orga-
+
+
+802
+nizations' request therefore urges us "to
+ble criminal activity"). Investigative activiextend its most exacting scrutiny to review
+ty inherently "affects or 'implicates' First
+[government action] that allegedly discrimi-
+Amendment activity." Reporters Commitnates against a large, diverse, and amortee, 593 F.2d at 1059 (emphasis omitted).
+phous class, unified only by the common
+The review of public records cannot involve
+factor" of language. San Antonio School
+any violation of first amendment rights.
+District v. Rodriguez, 411 U.S. 1, 28, 93
+Moreover, the follow-up questioning of po-
+S.Ct. 1278, 1293, 36 L.Ed.2d 16 (1973). We
+tential witnesses also is lawful. See, e.g.,
+agree that within a society "of multitudi-
+Jones i. Unknown Agents of the Federal
+nous origins, customs, tongues, beliefs, and
+Election Commission, 613 F.2d 864, 877-
+cultures, ... [it would hardly take extraor-
+78 (D.C.Cir. 1979) (upholding questioning of
+dinary ingenuity for a lawyer to find 'insucampaign contributors regarding
+lar and discrete' minorities at every turn in
+contributions), cert. denied, 444 U.S. 1074,
+the road." Sugarman v. Dougall, 418
+100 S.Ct. 1019, 62 L. Ed.2d 755 (1980); LaR-
+U.S. 634, 657, 98 S.Ct. 2842, 2865, 37
+ouche, 566 F.Supp. at 418 ("As long as
+L.Ed.2d 853 (1973) (Rehnquist, J., dissentreasonable cause to investigate exists, the
+ing). We therefore decline to equate one's
+mere asking of material questions does not
+choice of language with one's race or naconstitute a First Amendment violation.").
+tional origin, classification on the basis of
+which would require exacting serutiny.
+[15, 16) When no "suspect class" is involved and no fundamental right is bur-
+Heightened scrutiny is also approdened, a rational basis test is used to deterpriate if a fundamental right is burdened,
+mine the legitimacy of the classification.
+and voting is considered a
+fundamental
+See Massachusetts Board of Retirement v.
+right.
+E.g., Dunn v. Blumstein, 405 U.S.
+Murgia, 427 U.S. 307, 811-12,
+96 S.Ct.
+330, 336, 92 S.Ct. 995, 999, 31 L.Ed.2d 274
+2562, 2565-66, 49 L.Ed.2d 520 (1976) (per
+(1972).
+It is difficult to see how any "burcuriam). Here, the scope of the investigaden" was placed on anyone's right to vote,
+tion was limited to recently-registered forhowever,
+since no
+individual citizen was
+eign-born voters seeking bilingual ballots.
+denied his right to vote.
+Russoniello's pre-
+The impetus for the investigation was a
+liminary inquiry was aimed at ferreting out
+study indicating problems with persons
+potential voting fraud, in order to enhance
+whose primary language was other than
+the right to vote of those who qualified.
+English, in part because of mistranslations
+Individual citizens who were initially identiin the Spanish language applications. The
+fied as not qualified thereafter were only
+initial review was randomly based among
+the subject of narrowly confined, noneerthis group in order to readily obtain some
+cive follow-up interviews probing potentialindication of the scope of any impropriety.
+ly unlawful activities of others.
+When no significant level of impropriety
+construe this as a "burden," it is a burden
+was noticed, the investigation was termithat all citizens must be asked to bear
+nated. Thus, it appears to have been reawhen they are potential witnesses to unsonably limited in both its scope and its use
+lawful conduct.
+of classifications.
+[14]
+The organizations'
+first amend-
+We realize that the separation of powers
+ment claims are equally lacking in subdoctrine does not require us to ignore any
+stance. Whatever incidental burden (if
+any) on their associational rights which
+and all activities by executive officials regardless of whether their actions constitute
+may have occurred must give way to the
+clear violations of individual rights. At the
+overnment's need to ensure the sanctits
+same time, however, even the organizations
+if the polls
+recognize that a United States Attorney is
+F.Supp. at 418 ("associational rights ...
+entitled, indeed required, to conduct an in-
+[often] must give way to compelling govvestigation into allegations of voting fraud.
+ernmental interests in investigating possi-
+They only quarrel with the scope and man-
+
+
+ner of the investigation subsequently unconduet is unlawful and should be correct-
+But ours is not the role of a ed. Nevertheless, there remains the con-
+"super prosecutor" empowered to monitor
+cern that an award of declaratory relief in
+all prosecutorial activities on a day-to-day
+favor of the organizations could later probasis, absent compelling, extraordinary cirvide grounds for seeking injunctive relief
+cumstances. Chanen, 549 F.2d at 1312-13.
+against the same officials should the orga-
+We only hold that on the facts of
+nizations believe they are again the targets
+this case, no such extraordinary circumof a similar investigation, see Samuels u.
+stances exist warranting intrusion into the
+Mackell, 401 U.S. 66, 72, 91 S.Ct. 764, 767,
+actions of the executive branch.
+27 L.Ed.2d 688 (1971) (Samuels), even
+not to say that the organizations' charges
+though the investigative techniques may
+are not serious; we reach this conclusion
+Therefore, if declaratory
+only after careful scrutiny of the record
+relief based on a lesser showing leads to an
+before us. We are compelled, however, to
+injunction, the distinetion between the two
+refrain from injecting ourselves into the
+types of relief would be lost, despite the
+midst of what essentially was only an emstrong policy disfavoring such disruptive
+bryo of an investigation. A narrowly forelief which we previously outlined.
+cused preliminary inquiry using public
+Steffel, 415 U.S. at 481-82 & n. 3, 94 S.Ct.
+records was undertaken in order for the
+at 1226-27 & n. 3 (Rehnquist, J., concur-
+Attorney to determine
+ring) (expressing concern over potential use
+whether a problem even existed.
+of declaratory relief as a bootstrap).
+the ability to make such a narrow inquiry,
+in the face of a study indicating potentially
+Thus, the Supreme Court has recsignificant voter registration problems, the
+ognized that "ordinarily a declaratory judg-
+United States Attorney would be deprived
+ment will result in precisely the same interof the information he needs to perform his
+ference with and
+disruption of" law enduties. The organizations would have us
+forcement activities as an injunetion, Sameither forbid any preliminary investigation,
+wels, 401 U.S. at 72, 91 S.Ct. at 767, and
+or mandate one of significantly broader
+therefore * *the practical effect of [injunc
+scope. But matters such as the scope of a
+tive and declaratory] relief will be virtually
+preliminary investigation are delegated to
+identical.'"' Doran u. Salem Inn, Inc, 422
+discretion of the executive
+922, 981, 95 S.Ct. 2561, 2567, 45
+L.Ed.2d 648 (1975), quoting Samuels, 401
+U.S. at 73, 91 S.Ct at 768. Notwithstanding the difference in effect between injune-
+[18] The organizations also sought deelaratory relief.
+The district court disthis claim without elaborating its
+reasons. The decision whether to grant
+declaratory relief is within the sound discretion of the district court. See, e.g., Doe
+•. Gallinot, 657 F.2d 1017, 1024-25 (9th
+tive and declaratory relief, we conclude
+that the same general equitable principles
+should apply here in determining whether
+to grant declaratory relief as to the lawfulness of Russoniello's investigation.
+Samuels, 401 U.S. at 73, 91 S.Ct. at 76B.
+The central purpose of the Declaratory
+Judgment Act, 28 U.S.C. §5 2201-2202, is
+[19] Declaratory relief may be appropriate even when injunctive relief is not. See
+Steffel u. Thompson, 415 U.S. 452, 469, 94
+S.Ct. 1209, 1220, 39 L.Ed.2d 505 (1974)
+(Steffel). There is a considerable differ.
+ence between ordering a government official to conduct his activities in a certain
+manner, and simply pronouncing that his
+to provide parties with a declaration of
+their rights prior to incurring actual injury.
+In the typical case requesting declaratory
+relief with respect to law enforcement officials, a declaration of rights is sought with
+respect to a party's ongoing or intended
+conduct in light of existing crimina. statutes. The party desires a deelaration that
+
+
+804
+his conduct is lawful, and therefore may
+not be interfered with by state or federal
+officials. See Steffel, 415 U.S. at 478, 94
+S.Ct. at 1225 (Rehnquist, J., concurring).
+Declaratory relief thus provides an "alternative to pursuit of the arguably illegal
+activity:" Id. at 480, 94 S.Ct. at 1226.
+Here, however, there is no claim seeking a
+declaration that the organizations' voter
+registration activities are lawful. Rather,
+they seek a declaration that the government's activities are unlawful. Thus, the
+organizations are not seeking any alternative to being forced to continue arguably
+lawful conduct with the fear of imminent
+criminal prosecution. E.g., Doran o. Sa-
+lem Inn, Inc., 422 U.S. 922, 95 S.Ct. 2561,
+45 L.Ed.2d 648 (1975).
+In these circumstances, we hold that the
+district court's denial of declaratory relief
+was not an abuse of discretion.
+nizations were not generally hindered from
+pursuing their lawful voter registration acat the risk of imminent criminal
+prosecution, unlike the restaurant owners
+in Doran. Declaratory relief in this action
+would raise the same concerns regarding
+interference with the activities of prosecuting officials that we pointed
+discussion of injunetive relief.
+should inform the judgment of federal
+courts when asked to oversee state law
+enforcement authorities." Laons, 461 U.S.
+at 112, 103 S.Ct. at 1670. Here, the actions
+of the county officials of which the organizations complain were all performed at
+the specific request of the United States
+Attorney. Enjoining the county officials"
+activities would thus, to some effect, enjoin
+the United States Attorney from pursuing
+his investigation. Because we find no basis for interfering with the United States
+Attorney's investigation, we find no basis
+for equitable relief concerning the means
+he has to conduct it. Cf. Gravel v. United
+States, 408 U.S. 606, 621, 92 S.Ct. 2614,
+2625, 33 L.Ed.2d 583 (1972) (committee
+counsel gathering information for congressman is entitled to invoke congression-
+[21) The separation of powers concerns
+with regard to equitable relief against a
+United States Attorney are absent when
+examining the appropriateness of equitable
+relief against the county officials.
+similar considerations of restraint in ordering such relief arise out of principles of
+comity and federalism, as emphasized in
+Lyons, O'Shea, and Younger.
+tion of the need for a proper balance between state and federal authority counsels
+restraint in the issuance of injunctions
+against state officers engaged in the ad-
+[22] Even absent these concerns, the
+organizations' claims under the
+Rights Act against these officials do not
+appear to have merit. Assuming that the
+search of voting records intimidated bilingual voters, such intimidation would satisfy
+only one part of a two-pronged test for
+violations of 42 U.S.C. §5 1971(b) and
+1973i(b): the voters and organizations were
+intimidated, but the officials did not intend
+See United States .
+McLeod, 385 F.2d 734, 740-41 (5th Cir.
+1967). As we diseuss in Part IX, the officials acted in good faith. Although a declaratory judgment for violation of 42
+U.S.C. § 1978aa-la could not be denied on
+the basis of intent, see Chinese for Affirmative Action, 580 F.2d at 1008-09 (good
+faith is no defense to equitable relief regarding bilingual ballot provisions), there
+has been no violation of this section, which
+concerns solely the provision of bilingual
+ballots. There has been no allegation that
+bilingual ballots have not been provided in
+accordance with that section.
+ministration of the States' criminal
+laws...." Lyons, 461 U.S. at 112, 103
+S.Ct. at 1670, citing O'Shea, 414 U.S.
+499, 94 S.Ct. at 877, and Younger, 401 IS.
+[23] The organizations" First Amended
+Complaint seeks "statutory damages" unat 46, 91 S.Ct. at 751, "[N]ormal principles
+der the Voting Rights Act. Pursuant to
+of equity, comity, and federalism...
+Allen w. State Board of Elections, 398 U.S.
+
+
+544, 555, 89 S.Ct. 817, 826, 22 L.Ed.2d 1
+(1969), private litigants are held to have an
+[24] There is also an issue of whether
+action against state officials for declaratothe organizations' complaint can be read
+ry and injunctive relief under section 5 of
+fairly to inelude a request for damages
+the Act, 42 U.S.C. § 1973c.
+based on constitutional claims or statutory
+The Act, however, does not specify any
+claims such as section 1988, 42 U.S.C.
+statutory damage remedies.
+§ 1983. We agree with the distriet court,
+been cited nor have we found one in which
+however, that the officials involved in this
+damages were recovered. In determining
+action would be entitled to immunity from
+whether to construe an implied cause of
+such damage claims.
+action, the principal focus must be on congressional intent. Merrill Lynch, Pierce,
+Under Imbler v. Pachtman, 424 U.S.
+Fenner & Smith, Ine. v. Curran, 456 U.S.
+109, 96 S.Ct. 984, 47 L.Ed.2d 128 (1976),
+358, 377, 102 S.Ct. 1825, 1838, 72 L.Ed.2d
+state prosecutors are absolutely immune
+182 (1982). The Act itself limits the recovfrom damage suits with respect to their
+ery of any fine for criminal sanctions to
+quasi-judicial activities. Federal prosecu-
+See 42 U.S.C. § 1973aa-8. The
+tors receive the same protection. Butz v.
+legislative history nowhere suggests any
+Economou, 438 U.S. 478, 516-17, 98 S.Ct.
+action for damages, but instead observes
+2894, 2915-16, 57 L.Ed.2d 895 (1978). Oththat a private litigant is entitled to "the
+er executive officials are entitled to qualisame remedy" as the Attorney General, as
+fied immunity, see, e.g., Scheuer v. Rhodes,
+well as attorneys' fees as in 42 U.S.C.
+416 U.S. 282, 247-49, 94 S.Ct. 1683, 1691-
+55 1981-1988.
+S.Rep. No. 295, 94th Cong.,
+92, 40 L.Ed.2d 90 (1974) (state executive
+Ist Sess. 39-48, reprinted in 1975 U.S.
+officials), as are prosecutorial activities
+Code Cong. & Ad.News 774, 806-10. That
+that are merely administrative or investigahistory points out that "[t]he sole consetive. Jacobson v. Rose, 592 F.2d 515, 524
+of the provision for a private
+(9th Cir.1978), cert. denied, 442 U.S. 930,
+cause of action under the Act "is to broaden the scope of eguitable relief which may
+99 S.Ct. 2861, 61 L.Ed.2d 298 (1979).
+be requested" to include the "special reme-
+We have previously employed Imbler's
+specified in the Act. Id. at 49, refunctional approach for determining the deprinted in 1975 U.S.Code Cong. & Ad.
+gree of immunity for prosecutorial activity.
+News at 816 (emphasis added).
+See Ybarra t. Reno Thunderbird Mobile
+Moreover, Supreme Court precedent sug-
+Home Village, 723 F.2d 675, 678 (9th Cir.
+gests that private plaintiffs are limited to
+1984). Quasi-judicial activities are not limdamage actions under 42 U.S.C. § 1983.
+ited to post-indietment matters, but also
+See Smith v. Allwright, 321 U.S. 649, 64
+include "[investigative funetions carried
+S.Ct. 757, 88 L.Ed.2d 987 (1944), In Smith,
+out pursuant to the preparation of a proseplaintiffs were awarded damages for violacutor's case."
+Freeman on Behalf of the
+tion of their voting rights under 8 U.S.C.
+Sanctuary . Hittle, 708 F.2d 442, 443 (9th
+§ 81 (now echoed in 42 U.S.C. § 1973), in a
+Cir.1983) (per curiam). See also Atkins v.
+suit under 8 U.S.C. § 43 (now codified at 42
+Lanning, 556 F.2d 485, 488-89 (10th Cir.
+U.S.C. § 1983). Equitable relief suffices to
+1977) (per curiam).
+fulfill the purpose of the statute, which is
+The district court held that the actions in
+to ensure the right to register and vote at
+the polls. See, e.g., Webber v. White, 422 question were investigatory rather than
+F.Supp. 416, 426 (N.D.Tex.1976) ("the most prosecutorial in nature. The limited invesrelief that a federal district court can grant tigative activities undertaken by Russonielto a private litigant under the Allen inter- lo, however, may be encompassed within
+pretation of 42 U.S.C. § 1978c" is declarathose activities essential to the initiation of
+tory and injunctive relief). We decline to a prosecution. His decision to request a
+imply any action for damages.
+sampling of voting records can hardly be
+
+
+described as a purely administrative act.
+Russoniello's actions were limited to con-
+The Third Circuit has highlighted this asdueting a preliminary investigation of popect of a prosecutor's duties:
+tential voting fraud by examining and
+We recognize that the decision of the
+cross-checking publie records. The limited
+Attorney General, or a prosecuting attorscope of the investigation was reasonably
+ney, to initiate a prosecution is not made
+related to his need to secure a preliminary
+in a vacuum. On occasion, the securing
+indication of the scope of potential illegaliof additional information may be neces-
+No further activities were undersary before an informed decision can be
+taken or contemplated. These actions also
+made. To grant a prosecuting attorney
+violated no individual's "clearly estababsolute immunity over his decision to
+lished" rights; indeed, it was Russoniello's
+initiate a prosecution while subjecting
+duty to perform this investigation under
+him to liability for securing the informathe Voting Rights Act.
+tion necessary to make that decision
+would only foster uninformed decision-
+The organizations' claims rest entirely on
+making and the potential for needless
+their contention that an investigation using
+a language-based classification to define its
+We believe the right to make
+scope is subject to strict scrutiny as invidthe decision without being subject to suit
+ious discrimination on the basis of national
+must include some limited right to gather
+necessary information.
+origin. This contention is further dependent upon a finding that the illegality of
+Forsyth v. Kleindienst, 599 F.2d 1203,
+using such a classification was "clearly es-
+1215 (3d Cir.1979), cert, denied, 453 U.S.
+tablished." See Capoeman v. Reed, 754
+913, 101 S.Ct. 8147, 69 L. Ed.2d 997 (1981).
+F.2d 1512, 1514 (9th Cir.1985) (establishing
+We need not determine whether the disframework for determining whether a right
+trict court erred in denying absolute immunity, because we agree that all those sued
+was clearly established for purposes of
+qualified immunity). We already have conare entitled at least to qualified, good faith
+cluded that such a classification does not
+immunity. The controlling standard is "the
+call for strict scrutiny. But even if it did,
+objective reasonableness of an official's
+the illegality of such a classification was
+conduct, as measured by reference to clearnot "clearly established." The district
+ly established law." Harlow v. Fitzgerald,
+court's order finding qualified immunity
+457 U.S. 800, 818, 102 S.Ct. 2727, 2788, 73
+for all federal and state officials sued is
+L.Ed.2d 396 (1982). Moreover, summary
+therefore affirmed.
+judgment is encouraged as an appropriate
+"avoid excessive disruption of
+government." Id.
+Under this objective standard, all the of-
+NELSON, Circuit Judge, concurring and
+dissenting;
+I agree that the controversy is not moot
+(section II), that the organizations have
+mation in the publie record to the United
+standing (section III), and that the defend-
+States Attorney at his request, with some
+ants are entitled to good faith immunity
+later, voluntary interviews of those voters
+from damages under 42 U.S.C. § 1983 (secwhose citizenship the INS was unable to
+tion IX). I dissent from the holdings that
+ascertain. Such actions do not violate any
+Olagues lacks standing (part of section III,
+"clearly established" rights.
+Examining
+that "extraordinary circumstances" are re
+information in the public record violates no
+quired to enjoin an investigation that inone's rights.
+The Northern District Di-
+fringes upon First Amendment rights (secrector of the INS, David Ichert, similarly
+tion IV), that heightened scrutiny is not
+did no more than provide information to
+warranted for the equal protection claim
+Russoniello that was available to anyone on
+(section. that declaratory and injunetive
+request.
+relief should be judged under the same
+
+
+)LAGUES • RUSSONIELLO
+807
+*ite as 77
+F2d 791 (1985)
+standards (section VI), and that the plainconcrete. He has a personal stake in the
+tiffs have no. elaims under the Voting
+controversy and the relief requested would
+Rights Act (sections VII and VIII). I
+prevent the injury from recurring.
+Morewould remand on the injunction and one
+over, the majority's suggestion that any
+Voting Rights Act claim, and reverse the
+stigma attributable to the government's acdenial of a declaratory judgment which protion was Olagues' own fault, because all
+vides that the investigation violated
+the
+publicity coneerning the investigation re-
+Equal Protection Clause. For clarity
+sulted from the filing of this lawsuit, has
+brevity, I will limit my comments on this
+neither legal support nor a factual basis in
+complex case to these issues.
+Standing should not be denied to Ola-
+The majority accords standing to the orgues. Neither rationale employed by the
+majority is convincing. The prudential
+analysis speaks of "equitable relief"
+then considers solely the request for an
+injunction, ignoring the declaratory relief
+The majority concedes that Olagues has alleged an injury, but then categorizes the harm as "subjective" and therefore nonjusticiable under Laird t.
+408 U.S. 1, 92 S.Ct. 2318, 38 L.Ed.za 154
+(1972). Yet Laird recognizes
+the complainant is subject to the challenged
+exercise of government power,
+the government improperly imposed an affirmative obligation likely to have a deterrent effect on the exercise of his rights,
+Lamont v. Postmaster General, 381 U.S
+301, 308, 85 S.Ct. 1493, 1497, 14 L.Ed.2d
+398 (1965), the requirements of standing
+Laird, 408 U.S. at 11-18, 92 S.Ct.
+at 2824-25 (citing Lamont).
+Olagues satisfies the reguisites of standing under the very case upon which the
+majority relies. See McMichael u. County
+of Napa, 709 F.2d 1268, 1269-70 (9th Cir.
+The burden which Olagues alleges
+upon his exercise of the franchise-that his
+request for a bilingual ballot triggered an
+investigation of him by the INS, the FBI,
+and the United States Attorney, and an
+interview with the local District Attorney
+at which he was to prove his citizenship-is
+1. See Rizzo v. Goode, 423 1S. 362, 379, 96 S.Ct.
+sues in junction of municipal police seri
+Castaneda, 578 F.2d 842, 845 (9th Cir.1978) (n
+Immediate controversy on discovery until prose
+cution had commenced); United States v. Chan
+en, 549 F.2d 1305, 1313 (9th Cir.) (prosecutor's
+choice of evidence to present to grand jury)
+ert. denied, 434 U.S. 825, 98 S.C1. 72, 54 L.Ed.2d
+threatened their members. The identical
+threat is posed to the group of voters to
+which Olagues belongs-Hispanic citizens
+who request bilingual ballots. This language minority group is explicitly protected against voting discrimination.
+U.S.C. § 1973b(fX2). The injury to Olagues
+as a member of this group is another
+ground for his standing under the Equal
+See United Jewish Or-
+ganizations of Williamsburgh, Ine. v. Wilson, 510 F.2d 512, 522 (2d Cir.1975).
+The majority misstates the standard for
+injunctive relief in this context. Instead of
+the "extraordinary circumstances" threshold, drawn from federalism and criminal
+cases,' this investigation should have been
+enjoined if it lacked a reasonable basis or
+was initiated in bad faith.
+See Branzburg
+v. Hayes, 408 U.S. 665, 699-701, 707-08, 92
+2669-2670,
+L.Ed.2d 626 (1972); Reporters Committee
+for Freedom of the Press . American
+Telephone &
+593 F.2d 1030,
+1064 (D.C.Cir.1978), cert. denied, 440
+949, 99 S.Ct. 1431, 59 L.Ed.2d 639 (1919);
+288 F.Supp. 248, 256-
+58 (E.D.Ark.), affa, 393 U.S. 14, 89
+47, 21 L.Ed.2d 14 (1968) (per curiam).
+The First Amendment protects citizens
+from investigations which do not meet this
+171 (5th Cir.) (en bane) (United States Attorney
+arrested for contempt for refusing to sign a
+grand jury indictment), cert. denied, 381 U.S
+935, 85 S.Ct. 1767, 14 L.Ed.2d 700 (1965); In re
+Grand Jury of the Southern District of Alabama,
+508 F.Supp. 1210, 1214 (S.D.Ala.1980) (prosecutorial vindictiveness); In re Grand Jury Subpoema to Central States, 225 F.Supp. 923, 925 (N.D
+III.1964) (motion to quash grand jury subpoe
+83 (1977); United States v. Cox. 342 F.2d 167,
+
+
+808
+"reasonable basis" standard. Pollard, 283 ed when warranted, even if an injunction
+F.Supp. at 258; Reporters Committee, 593 under the same circumstances would be
+F.2d at 1064. See also Branzburg v.
+denied. Steffel, 415 U.S. at 471-72, 94
+Hayes, 408 U.S. 665, 699-01,
+S.Ct. 2646, 2665-66, 2669-70, 33 L.Ed.2d 626
+This case warrants the award of a declar-
+The organizations alleged that the Unitatory judgment under the Constitution.
+The investigation fails before the scrutiny
+ed States Attorney lacked a reasonable barequired for a classification which burdens
+sis for initiating the investigations.
+the voting rights of a suspect class.
+district court should have made a finding
+on this issue. See La Rouche v. Webster,
+The majority recognizes that the investi-
+566 F.Supp. 415, 418 (S.D.N.Y.1983); Polgation targeted "recently registered, forlard, 283 F.Supp. at 258. The relief sought
+eign-born voters who requested bilingual
+by the organizations was not anticipatory,
+ballots," at — but then analyzes the
+since the investigation presented a current
+class as if it were defined solely by lancase or controversy. Cf. Jett v. Castaneguage ability. The classification was of
+da, 578 F.2d 842, 845 (9th Cir. 1978) (no case
+those who requested bilingual ballots, not
+or controversy); Reporters Committee,
+just of individuals who speak more than
+593 F.2d at 1065. The denial of the prelimione language, and it included two other
+nary injunction should be affirmed, therefactors-foreign birth and recent registrafore, only if the organizations failed to
+tion to vote. The class should be analyzed
+show that the investigation was not reasonas defined by these three characteristics.
+able or initiated in bad faith. The question
+Foreign birth is "an immutable characshould be remanded.
+teristic determined solely by an accident of
+Contrary to the majority's view, declarabirth," Frontiero o. Richardson, 411 U.S.
+tory relief raises different concerns than an
+67T, 686, 93 S.Ct. 1764, 1770, 36 L.Ed.2d
+injunction.
+To quote one case cited by the
+583 (1973), and is similar to a national
+majority,
+"critical distinetions make declarorigin classification. Together with the reatory relief appropriate where injunctive
+quirement of recent registration, the target
+relief would not be." Steffel v. Thompson,
+class appears composed of immigrants who
+415 U.S. 452, 481, 94 S.Ct. 1209, 1226, 39
+have recently obtained United States citi-
+L.Ed.2d 505 (1974) (Rehnquist, J., concurzenship but prefer Spanish or Chinese-lanring). The majority echoes the mistake of
+guage ballots. Like the class of Hispanies
+the panel which was reversed in Steffel for
+in Hernandez v. Texas, 347 U.S. 475, 74
+holding that a failure to demonstrate irrep-
+S.Ct. 667, 98 L.Ed. 866 (1954), these characarable injury precluded the granting of deteristies taken together define a suspect
+claratory relief. Id. at 471-72, 94 S.Ct. at
+class. The investigation by the FBI and
+1221-22. It reasons that where injunctive
+INS, together with the interviews requiring
+relief is inappropriate,
+declaratory relief
+proof of citizenship, amount to "different
+should also be denied, because "an award
+treatment" of these citizens. Such addiof declaratory relief in favor of the orgational requirements imposed on voters
+nizations could later provide grounds for
+"solely because of their ancestry are by
+seeking injunctive relief against the same
+their very nature odious to a free people."
+officials should the organizations believe
+Hirabayashi o. United States, 320 U.S. 81,
+they are again the targets of a similar
+100, 63 S.Ct. 1375, 1385, 87 L.Ed. 1774
+investigation." This concern is misplaced, (1943).
+because an injunction should issue if the
+The fundamental right to vote was burgovernment so flouts a judgment declaring dened by this investigation. The majority
+certain action unconstitutional. Declarato- finds otherwise, perhaps because it equates
+ry relief is a separate remedy to be award "burden" with outright denial of the right
+
+
+to vote. Precedent does not define "bur examine the interests asserted in support
+den" so narrowly, however. See, e.g., Har. of the classification. Id. The classification
+per u Virginia Board of Blections, 385
+must be necessary to serve a compelling
+U.S. 663, 666-67, 86 S.Ct. 1079, 1081, 15
+interest, and it must employ the least dras-
+L. Ed.2d 169 (1966) (poll tax constitutes burtie means to achieve that end. Id. at 184-
+den). Nor is "denial" of the right to vote
+85, 99 S.Ct. at 990. This investigation canthe only behavior prohibited under the Votnot withstand such scrutiny. It was not
+ing Rights Act. See 42 U.S.C. § 1973 ("no
+narrowly tailored to catch those wrongly
+voting qualification or prerequisite to votregistered, because it targeted recently
+ing, or standard, practice, or procedure ...
+registered citizens, who are required by
+to deny or abridge ..."); 42 U.S.C.
+law to be literate in English. It assumed
+(intimidate, threaten, or
+that individuals who speak Spanish or Chinese are likely not to be citizens, though
+the statistical predominance of Spanish-
+The opinion states that "it is difficult to
+and Chinese-speaking citizens is the very
+see how any 'burden' was placed," but I do
+reason why provision of bilingual ballots
+not share this difficulty. An investigation
+by the FBI and INS and a summons to the
+was required under federal law. The investigation was unconstitutional under the
+distriet attorney to prove one's citizenship.
+Equal Protection Clause, and a declaratory
+as I noted above concerning the injury to
+Olagues, constitutes a burden on the exerjudgment should be granted.
+cise of the right to vote in this case.
+Relief may also be required under the
+impact of the investigation on the class
+Voting Rights Act. I would remand the
+went beyond any ordinary inconvenience
+issue of potential violation of 42 U.S.C.
+caused to witnesses. These individuals are
+§ 1973aa-la. See Lequennec, 580 F 2d at
+not fluent in English, are new to this coun-
+1008-09. Good faith is not a defense under
+try, and through their recent acquisition of
+this provision, which does not require incitizenship have experienced the INS bureaucracy, which misrepresented the citizenship status of more than half of those
+investigated. When a citizen's request for
+a bilingual ballot-which is specifically
+made available by Congress to eliminate
+voting discrimination against those more
+comfortable in another language, Chinese
+for Affirmative Action v. Lequennec, 580
+F.2d 1006, 1006 (9th Cir.1978), cerl. denied,
+439 U.S. 1129, 99 S.Ct. 1047, 59 L.Ed.2d 90
+Finally, even absent its legal infirmities,
+this investigation violated the spirit behind
+the Voting Rights Act, which charges the
+Attorney General with eradicating discrimination against language minority voters
+and discrimination based upon national origin. Instead, this U.S. Attorney's efforts
+engendered such discrimination. I cannot
+join the majority's wholesale affirmance of
+the district court's judgment.
+(1979)—triggers such consequences, a burden has been imposed. The Voting Rights
+Act forbids intimidation of voters, and in
+my view this investigation intimidated
+those foreign-born, recently registered voters who requested bilingual ballots.
+Having examined the character of the
+classification in question and the impor
+tance of the individual interests at stake,
+Illinois State Board of Elections t. So-
+cialist Workers Party, 440 U.S. 173, 183,
+99 S.Ct. 988, 989, 59 L.Ed.2d 280 (1979), we
+
+
+PENTHOUSE INTERN, LTD. | MAULIFFE
+925
+Cite as 702 F.3d 835 (198
+R.B., 429 7 2d 697 (10th Cir.1970), and more
+prosecuting or threatening to prosecute, uncently by the Fourth Circuit, Air Transit der Georgia obecenity statute, any person
+| N.L.R.B, 679 F2d 1101 (4th Cir.1982),
+exhibiting the film. The United States Disthe Board sought to impose the same infestriet Court for the Northern District of
+tation on the Eleventh Circuit. The effort
+Georgia at Atlanta, Richard C. Freeman, J.,
+is to no avail.
+denied permanent injunction but granted
+declaratory relief in favor of the plaintiff.
+[24] We hold that the daily lessees are
+On appeal by the county prosecutor, the
+independent contractors and not employees
+Court of Appeals, Tjoflat, Circuit Judge,
+of the Company and the contrary finding of
+held that: (1) injunctive relief was properly
+the Board is unsupp
+evidence. N.L.R.B.
+denied where reasonable prosecutor could
+F.2d at 1228. The red
+believe there was probable cause that those
+and does not support
+"two fairly conflicting views," N.L.R.B. v.
+who would be involved in exhibition of the
+film would violate the Georgia obecenity
+United Insurance Co., 390 U.S. at 260, 88
+statute as constitutionally applied, but (2)
+S.Ct. at 992, but only one: the daily lessees
+are independent contractors. A fortiori the
+district court erred in proceeding to determination of the obecenity vel non of the
+annual lessees, over whom the Company
+film where such issue could not be resolved
+concededly exercises even less control and
+as matter of federal constitutional law.
+who have a greater investment and entrepreneurial interest in the taxicabs than the
+Affirmed in part; reversed in part and
+daily lessees also are independent contracremanded.
+tors.* Accordingly, the enforcement of the
+Lynne, District Judge, sitting by desigorder of the Board is DENIED.
+nation, dissented and filed opinion.
+SKET NUMBER SISTE
+1. Injunction 105(1)
+Where prosecutor threatened to enforce valid criminal statute against behavior that fell within ambit of statute, in that
+reasonable prosecutor could have believed
+there was probable cause that those who
+would be involved in exhibition of film
+would violate Georgia obecenity statute as
+constitutionally applied, such prosecutorial
+threat under such circumstances gave rise
+to no cause of action for injunction. O.C.
+G.A. § 16-12-80; U.S.C.A. Const.Amend. 1.
+2. Constitutional Law *-90.1(8)
+PENTHOUSE INTERNATIONAL, LTD,
+Plaintiff-Appellee,
+V.
+Hinson MeAULIFFE, Individually and as
+Solicitor General for the County of Fulton, State of Georgia, Defendant-Appel-
+No. 81-7426.
+Vited Stare Cock of Apeak,
+April 11, 1983.
+Opinion on Granting of Rehearing En
+Bane June 30, 1983.
+wner of rights to film brought suit t
+njoin county prosecutor in Georgia fron
+I. Having reached this result it is unnecessary
+for us to reach the Issue of whether the annual
+lessees are supervisors because, as independent
+contractors, they do not qualify as employees
+SC. ContAmend. 2.A. $ 16-12-80;
+3. Criminal Law e=31
+t is fundamental that some innocen
+ersons may be charged with violatin
+and they tore tuder not or not told no
+U.S.C. § 152(3).
+
+
+926
+702 FEDERAL REPORTER, 2A SERIES
+criminal statutes, and, absent prosecutorial
+misconduct, no constitutional claim exists to
+relieve burden on those innocent persons of
+defending valid criminal prosecutions.
+4. Distriet and Proeecuting Attorneys +8
+Prosecutor was well within his discretion in threatening to prosecute persons associsted with showing of film, in that reasonable prosecutor could have believed
+there was probable cause that those involved in exhibition of such film would be
+violating Georgia obecenity statute as constitutionally applied. O.C.G.A. § 16-12-80;
+U.S.C.A. Const.Amend. 1.
+5. Courts *=508(T)
+Though county prosecutor threatened
+to enforce valid criminal statute against
+behavior falling within ambit of statute, in
+sense that reasonable prosecutor could have
+believed there was probable cause that
+those who would be involved in exhibition
+of film would violate Georgia obscenity
+statute as constitutionally applied, owner of
+righta to film was not entitled to ruling
+from federal district court that film was
+not obecene unless it was proved that film
+was not obscene as matter of federal constitutional law regardleas of factual context in
+which movie was shown. O.C.G.A. 55 16-
+12-80, 16-12-80(b); U.S.C.A. Const.Amend.
+George Weaver, Atlanta, Ga., for defendant-appellant.
+• Honorable Seybourn H. Lynne, U.S. District
+Judge for the Northern District of Alabama,
+sitting by designation.
+1. Jurisdiction was predicated on 28 U.S.C
+§ 1343(3) (1976 & Supp. IV 1980), through
+which 42 U.S.C. § 1983 (1976) is implemented.
+2. Penthouse makes no attack on the facial
+lidity of the Georgia obscenity statute. Inder
+such an attack would be frivolous because that
+statute explicitly incorporates the constitutional standards enunciated in Miller v. California,
+413 U.S. 15, 83 S.Ct. 2607, 37 L.Ed.2d 419
+(1973). Ga.Code 5 16-12-80 (1980).
+3. We recognize that Penthouse neger cross-ap
+pealed the district court's denial of Injunctive
+relief. Therefore, we discuss such denial at the
+Coup or the cera be see oria.
+Before TJOFLAT and HENDERSON,
+Circuit Judges, and LYNNE*, District
+Judge.
+TJOFLAT, Circuit Judge:
+'enthouse brought this suit to enjoin the
+olicitor General of Fulton County, Geor
+gia, Hinson McAuliffe, from prosecuting or
+threatening to prosecute under the Georgia
+obscenity statute,
+Ga.Code § 16-12-80
+(1980), any person who exhibited the movie
+"Caligula," the rights to which Penthouse
+owns.' Penthouse also sought a declaration
+that "Caligula" is not obscene within the
+meaning of that obscenity statute as constitutionally applied.* After a trial before the
+district court and an advisory jury, the
+court declared "Caligula" not obacene under
+state or federal law. The court denied
+Penthouse's prayer for a permanent injunction because it assumed that a declaratory
+judgment would have the same practical
+effect as an injunction of restraining prosecution or threats thereof.
+McAuliffe appeals from the district court's entry of declaratory relief in favor of Penthouse.
+We affirm the district court's denial of
+the injunction, although our reasoning differs from that of the district court.* We
+risk of pontificating obiter dictum. We belleve
+our discussion is necessary, however, for two
+reasons. First, our discussion of the district
+court's grant of declaratory relief would not be
+complete without a discussion of its denial of
+injunetive rellef. Although the two prayers for
+relief are separate, they are closely related. A
+typical complaint, such as the one Penthouse
+brings, would contain both prayers. Neither
+should be considered in a vacuum; profitable
+comparison results from a discussion of both.
+Second, the district court denied injunctive re
+lief solely because it thought declaratory relief
+would be sufficient. We now reverse the district court's grant of declaratory relief. Our
+reasons for agreeing with the district court that
+It should not
+e granted injunctive relief are
+
+
+PENTHOUSE INTERN, LTD.
+L MCAULIFFE
+Cite as 703 F.3d 925 (1963
+927
+reverse the district court's grant of Pent-
+[1] The focus of Penthouse's suit for an
+house's prayer for declaratory relief and
+injunction is on McAuliffe's conduct.
+remand this claim because the court erred
+McAuliffe threatened to enforce a valid
+in proceeding to a determination of the
+criminal statute against behavior that falls
+obecenity vel non of "Caligula."
+within the ambit of the statute, in the sense
+that a reasonable prosecutor could have be-
+The essence of Penthouse's complaint is
+lieved there was probable cause that those
+that McAuliffe is infringing on Penthouse's
+who would be involved in the exhibition of
+first amendment rights by threatening to
+"Caligula" would violate the Georgia obprosecute persons involved in the showing
+scenity statute as constitutionally applied.
+of "Caligula."* Penthouse alleges that it
+Prosecutorial threata in such circumstances
+cannot obtain an exhibitor in Fulton County
+give rise to no cause of action for an injunebecause of McAuliffe's threats of prosecution.* To sustain a cause of action for an
+tion. To remedy this infringement, Pentinjunction, Penthouse would have to show
+house seeks two remedies: an injunction
+some sort of "bad-faith" conduct on MeAu-
+against prosecution or threats thereof, and
+liffe's part. We do not mean subjective
+a declaration that "Caligula" is not obscene.
+bad-faith conduct; rather, if Penthouse
+Careful analysis reveals that these two remcould show that no probable cause ressonedies are in fact based on separate causes of
+ably could have existed to believe that those
+action.
+who would be involved in the exhibition of
+so different from that of the lower court that
+Record, vol. 1, at 8-9. Penthouse's complaint
+we belleve we are compelled to state them.
+also alleges that the plaintiffs in the Southern
+District of New York lawsuit, including McAu-
+4. Penthouse's complaint describes the threats
+liffe, sought to compel the defendants therein
+as follows:
+to initiate some type of action to prevent the
+Defendant McAuliffe's Conduct
+exhibition or distribution of "Caligula" in the
+16.
+United States. Id. at 9.
+Defendant McAuliffe has publicly announced that he considers Caligula to be ob-
+5. We have no reason to question the district
+scene by commencing a lawsult in United
+court's findings that McAuliffe has threatened
+States District Court for the Southern Disto prosecute and that Penthouse cannot obtain
+trict of New York in the name and style:
+an exhibitor in Fulton County.
+Morality In Media, Inc.,
+individually;
+Morton A. Hill, S.J., for himself and all others
+similiarly (sic] situated; and Hinson McAu-
+liffe, in his official capacity as Sollcitor General of Fulton County, Georgia, himself and
+all others similarly (sic] situated
+One Mo-
+tion Picture Film Entitled "Caligua," a res;
+Edward R. Korman, in his official capacity as
+United States Attorney for the Eastern Dis
+trict of New York; and Benjamin R. Civiletti,
+in his official capacity as Attorney General of
+the United States, Civil Action No. 80-0640
+(hereinafter the "Southern District of New
+York Lawsuit"), Defendant McAuliffe, allegedly in his capacity as Solicitor General of
+Fulton County, Georgia, and as part of the
+Southern District of New York Lawsuit,
+caused to be issued by the Clerk of said
+court, a warrant for the seizure of Caligula
+17.
+In the Southern District of New York Lawsult initiated by Defendant McAuliffe and
+others, Defendant McAuliffe alleged under
+oath that Caligula is obscene; and Defendant
+McAuliffe alleged that if Caligula is exhibited
+In Fulton County, Georgla, Defendant McAu-
+liffe will commit public funds and resources
+6. Indeed, the Supreme Court has, In dicta, addressed a similar, if not identical, situation.
+Bantam Books, Inc. v. Sullivan, 372 U.S. 58, 83
+S.Ct. 631, 9 L.Ed.2d 584 (1963). After holding
+an act creating a censorship commission unconstitutional, the Court stated:
+[Wle do not mean to suggest that private
+consultation between law enforcement officers and distributors prior to the institution
+of a judicial proceeding can never be constitutionally permissible. We do not hold that
+law enforcement officers must renounce all
+Informal contacts with persons suspected of
+violating valid laws prohibiting obscenity.
+Where such consultation is genuinely undertaken with the purpose of aiding the distributor to comply with such laws and avold prosecution under them, it need not retard the full
+enjoyment of First Amendment freedoms.
+Id. at 71-72, 83 S.Ct. at 640. Thus, the Su-
+preme Court has at least intimated that there
+may be no constitutional problem arising from
+hreats of enforcement of a valid obscenity
+tatute against conduct that falls within the
+reach of the statute.
+to institute prosecutions under Georgia law.
+
+
+928
+702 FEDERAL REPORTER, 2d SERIES
+"Caligula" would be violating the Georgia under the first amendment is not stated.
+obscenity statute as constitutionally ap- Therefore, we affirm the district court's
+plied, because "Caligula" is so clearly not
+obscene, the requisite objective bad faith
+27EEE
+would be shown.
+[5] Penthouse's second claim seeks a de-
+[2,3] We base this reasoning on several
+premises.
+claratory judgment that "Caligula" is not
+Our initial and most basie
+obscene under the Georgia obscenity statute
+premise is that obecenity is not protecter
+as constitutionally applied. We hold that
+under the first amendment. See Miller
+Penthouse is entitled to this relief only if it
+California, 418 U.S. 15, 23, 93 S.Ct. 2607,
+can prove that "Caligula" is not obscene as
+2614, 37 L.Ed.2d 419 (1973). Thus, states
+a matter of federal constitutional law. If
+such as Georgia are free to enact statutes
+factual issues are present, Penthouse's
+making the exhibition of obscene matter
+claim must be denied because the claim
+criminal. See Ga.Code § 16-12-80 (1980).
+would be nothing more than a request that
+Our second premise is that states may en-
+a federal court determine whether prospecforce their valid criminal statutes within
+constitutional limits. They may also charge
+tive, possibly illegal conduet is in fact illegal
+under a valid state criminal statute. To
+certain public officials, such as MeAuliffe,
+allow such a claim would be to countenance
+with the responsibility of enforcing such
+the bypass of the entire state criminal juslaws. Our third premise is that it is fundatice system so a federal court could determental that some innocent persons may be
+mine the "guilt or innocence," under a valid
+charged with violating criminal statutes,
+state criminal statute, of one who proposes
+and that absent prosecutorial misconduet,
+to exhibit "Caligula." Notions of comity
+no constitutional claim exists to relieve the
+and federalism preclude us from recognizburden on those innocent persons of defending such a cause of action, especially in an
+ing valid criminal prosecutions.
+We believe
+area in which local community standards
+the validity of these three premises is beare so crucial. See Miller
+California, 418
+yond question. We believe also that these
+U.S. 15, 30-34, 96 S.Ct. 2507, 2618-20, 37
+premises lead inescapably to the conclusion
+L.Ed.2d 419 (1978). In contrast, if Pentthat law enforcement officials must be alhouse can prove that "Caligula" is not oblowed the discretion in good faith to do all
+scene as a matter of federal constitutional
+that is reasonably necessary to their funelaw, notions of comity and federalism would
+tion of enforcing valid laws, and that the
+not interfere with a federal court's grant of
+first amendment contemplates no other result.
+declaratory relief.
+In granting relief, the
+federal court would not be invading the
+[4] We hold that McAuliffe was well
+province of the state factfinder; rather, it
+within his discretion in threatening to proswould be determining a question of federal
+cute persons associated with the showin
+constitutional law as a matter of law.
+of "Caligula." Having viewed "Caligula,
+Furthermore, if Penthouse cannot prove
+it is clear to us that a reasonable prosecutor
+that "Caligula" is not obscene as a matter
+could have believed there was probable
+of law, its claim must fail because it would
+cause that those who would be involved in
+not prove a present case or controversy.
+the exhibition of "Caligula" in Fulton Coun-
+The allegedly protected conduct would be
+ty, Georgia, would be violating the Georgia
+the prospective exhibition of a movie under
+obscenity statute as constitutionally applied. Regardless of the obscenity vel non
+of the movie, it cannot be contended that
+the movie is so clearly not obscene that
+McAuliffe was acting in "bad faith" in
+threatening to prosecute. Without such a
+showing, we hold a claim for an injunction
+no problem of the requisite case or controversy would exist because the complaint
+would be that the facts involving the exhibition of the film, e.g., where and when the
+movie is shown, are irrelevant. The com-
+
+
+PENTHOUSE INTERN, LTD. MCAULIPPE
+Cite as 702 F.2d 925 (190
+929
+plaint would be that regardless of the facwhether the showing would have serious
+the movie is not obscene as a matter of law.
+Thus, there is nothing to prevent a federal
+court from recognizing such a cause of aetion.
+We believe the above analysis is consist-
+Only if these questions can be resolved as a
+matter of federal constitutional law ' does
+this case parallel Steffel. If not, the dis
+uret court
+• must not attempt to resolve
+(1974). In Steffel the Supreme Court held
+that a valid claim for declaratory relief was
+stated when the complaint alleged threats
+of prosecution under a facially valid criminal trespass statute against conduct arguably protected under the first amendment
+A cognizable claim was stated because a
+federal court could determine as a matter
+of law whether such threats violated the
+plaintiff's constitutional rights. No factual
+issues needed resolution; a pure question of
+law was presented.
+Because such a ques
+tion was presented, no prohibitive problems
+of federalism or case or controversy arose
+Steffel would have been a much different
+case had it been disputed whether the plaintiffs would make a
+"knowing" entry upon
+the defendant's land within the meaning o
+the state trespass statute.
+Problems of federalism and case or controversy would have
+then arisen.
+The same problems arose in
+this case when the district court determined
+the obecenity vel non of "Caligula"
+Coetical actual mies tinder loving bygo.
+thetical factual issues under the
+obscenity
+statute:
+whether the
+future
+showing of "Caligula" would predominantly
+appeal to the prurient interest of the loca
+community; whether the showing would be
+patently offensive to that community; and
+7. Because these questions must be resolved as
+a matter of law, a jury has no role in these
+determinations.
+8. We hold only that the district court cannot
+decide the question of the obscenity of "Caligula" as a matter of state law. We remand the
+case for the court to decide the question as a
+matter of federal constitutional law, just as a
+federal appellate court would if it was revies
+ing a state jury determination. See Jenkins
+Georgia, 418 U.S. 153, 161, 94 S.Ct. 2750, 2755
+41 L.Ed.2d 642 (1974) (We hold that the fllm
+could not, as a matter of constitutional law, be
+found to depict sexual conduct in a patently
+offensive way, and that it is therefore not outside the protection of the First and Fourteenth
+Amendments because it is obscene.").
+Thus,
+the dissent mischaracterizes our holding as one
+FFIRMED in part; REVERSED :
+art and REMANDE
+LYNNE, District Judge, dissenting:
+se or one on tree doors deniao
+injunction are inappropriate.
+Penthouse
+did not contest that ruling by a cross-appeal.
+The superficial parallelism of the
+remedies of injunctive and declaratory relief would not seem to justify consideration
+of standards applicable to the former to
+illuminate the only issue before us, the
+grant of the latter.
+I believe the court's opinion is contrary to
+the precise holding of Steffel:
+We therefore hold that, regardless of
+whether injunctive relief may be appropriate,
+federal declaratory relief is not
+precluded when no state prosecution is
+pending and a federal plaintiff demonstrates a genuine threat of enforcement
+of a disputed state criminal statute,
+whether an attack is made on the constitutionality of the statute on its face or as
+applied.
+415 U.S. 452, 475, 94 S.Ct. 1299,
+1223-24, 89 L. Exd.2d 506 (1978).
+of abstention.
+We are not refusing to intervene
+to protect federal rights; we are refusing only
+to decide state law questions. We see no prohibition on deciding whether "Caligula" is protected as a matter of federal constitutional law
+without deciding any state law questions. The
+dissent also fails to recognize the separate nature of the state and federal questions. For
+example, the Georgia obscenity statute must
+give at least as much protection to "Caligula"
+as does the first amendment, but the statute
+may extend greater protection consistent with
+federal law. Furthermore, state law may vary
+depending on who applies it, L.e., a federal
+judge or a state jury. The state should be free
+to interpret its own law so long as that interpretation is consistent with federal constitutional law.
+
+
+930
+702 FEDERAL REPORTER, 2d SERIES
+It is conceded that Penthouse demontrial judge applied these standards in his
+strated a genuine threat of enforcement of
+own fact findings.
+the Georgia statute. Clearly there is a dispute as to
+whether
+this statute may be
+Finally, I cannot agree with the implica
+applied to "Caligula" McAuliffe believes
+tion of the Court's opinion that the distric
+"Caligula" is obscene; Penthouse does not.
+court was powerless to resolve the question
+hus there is a case or controversy withi
+of whether Caligula is obscene under the
+Georgia statute in order to reach the queshe meaning of Article III of the Constitu
+tion as to whether it is protected by the
+ion and the Federal Declaratory Judgment
+First Amendment; that it is "more appro-
+Act,
+28 U.S.C. Sec. 2201.
+Septum. Inci
+Keller, 614 F.2d 456 (5th Cir.1980).
+priately left to state factfinders."
+Septum, Inc. squarely holds that under
+Synthesizing the averments of the comthe circumstances of this case abstention is
+plaint, the consolidated pre-trial order, the
+trial transcript, and the May 15, 1981 order
+inappropriate.
+Presumably state factfinders would be confined to a criminal proceed
+of the court, it is at once apparent that the
+ing. The fallacy of this approach is demongravamen of the claim asserted by Pentstrated by the reasoning of Steffel:
+house is that "Caligula" is protected by the
+First Amendment as applied to the States
+[While a pending state prosecution pro
+vides the federal plaintiff with a concrete
+through the Fourteenth Amendment. Concededly obscene material is not protected.
+opportunity to vindicate his constitutional
+Miller established a three-prong contermirights, a refusal on the part of the federal
+nous test to determine obscenity vel non
+courta to intervene when no state prosewhich Georgia incorporated in its statute.
+cution is pending may place the hapless
+plaintiff between the Scylla of intention-
+If "the average person, applying contemally flouting state law and the Charybdis
+porary community standards would [not]
+of foregoing what he believes to be confind that ["Caligula"), taken as a whole,
+stitutionally protected activity in order to
+appeals to the prurient interest," the First
+avoid becoming enmeshed in a criminal
+Amendment insulates it from the application of the Georgia statute. Appeal to the
+interest is a question of fact.
+It would be anomalous to suggest that it
+is possible to adjudicate the question of
+whether material is obscene
+under the
+Georgia statute without resolving at the
+same time whether such material is protected by the First Amendment within the Miller definition of obscenity since out of the
+facts the law arises.
+Both the advisory jury
+and the court found as a fact that, applying
+contemporary community standards,
+Caligula does not appeal to the prurient interest.
+A careful review of the Court's instruetiona to the jury reveals that its definition
+was in accord with
+of the prurient interes United States, 354
+the teaching of Roth
+U.S. 476, 77 S.Ct 1504, 1 L.Ed.2d 1498
+(1957).
+The Court properly charged the
+jury that the burden of proof with respect
+of beyond a reasonabl
+toubt. Mckinney Alabama, 424 U.S. 66.
+684, 96 S.Ct. 1185, 1197, 47 L.Ed.2d 887
+(1976) (Brennan, J., concurring in the judgment). It is reasonable to assume that the
+415 U.S. at 462, 94 S.Ct. at 1217.
+I respectfully dissent.
+ON PETITION FOR REHEARING AND
+PETITION FOR REHEARING
+EN BANC
+Before GODBOLD, Chief Judge, and RO
+NEL, TOPLAT, HILL, FAY
+VANCE,
+KRAVITCH, JOHNSON, HENDERSON,
+HATCHETT, ANDERSON and CLARK,
+Cireuit Judges.
+BY THE COURT:
+A member of this Court in active service
+having requested a poll on the application
+for rehearing en bane and a majority of the
+judges in active service having voted in
+favor of granting a rehearing en bane,
+IT IS ORDERED that the case shall be
+reheard by this Court en bane with oral
+argument on a date hereafter to be fixed.
+The Clerk will specify a briefing schedule
+for the filing of en bane briefs.
+
+
+MAJURI T. UNITED STATES
+469
+Cite as 431 F.2d 402 (1970)
+es from a case of smuggling in that the use of drugs as part of religious
+United States,
+5th Cir. 1969, practice is not constitutionally privileged.
+417 F.2d 698.
+We find no reversible error and th
+tion here.
+Leary, Marchetti and Grosso judgment is affirmed
+State had declared illegal, and which
+therefore would subject the individuals
+to prosecution under state laws.
+In the
+present case, however, if the appellants
+nad declared and invoiced the heroin and
+marihuana at the International border
+they would not, at that point, have been
+vulnerable to prosecution, either Federal or State, because they would have
+complied with the Federal law and would
+never have reached the United States
+vith the drugs in their possession. Se
+Rule . United States, 5th Cir. 1966, 362
+[3] Secondly, appellants
+they could not
+ported and concealed the marihuana and
+heroin beyond the primary border checkpoint because they only proceeded beyond that point, where they had failed
+to declare the contraband, to the
+ondary checkpoint at the direction of the
+customs authorities.
+controlled by our decision in Walden
+United States, supra, where we held the
+when a defendant enters custom's primary inspection station and fails to declare and invoice marihuana at the first
+opportunity, he is in violation of the law.
+[4] Finally, it is argued that the district court should have permitted
+jury to pass on appellants'
+that they are sincere followers of the
+Moslem or Islamic religion, which sanetions the use of heroin and marihuana.
+Appellants claim that failure to admit
+this evidence violates their first amendment right to freedom of religion.
+851, 859-862, reversed on other grounds,
+395 U.S. 6, 89 S.Ct. 1532, 23 L.Ed.2d
+57 (1969), where we cited numerous authorities in support of the proposition
+Charles MAJURI and Joseph Caruano
+UNITED STATES of America, John N.
+Mitchell, Attorney General of the U.S.,
+Frederick B. Lacey, United States Att'y
+for the District of New Jersey, and
+John Doe, any Federal Law Enforcement Officer
+Joseph Caruano, Appellant In No. 18903
+Charles Majuri, Appellant in No. 18904.
+United States Court of Appeals,
+Argued June 23, 1970.
+Decided Aug. 17, 1970.
+Certiorari Denied Dec. T, 1970.
+See 91 S.Ct. 245.
+Action for preliminary and permanent injunction restraining the United
+States, the Attorney General and other
+federal law enforcement officers from
+proceeding with prosecutions against
+plaintiffs based on federal statutes prohibiting use of extortionate means to
+collect or to attempt to collect extensions
+The United States District
+Court for the District of New Jersey,
+Leonard I. Garth, J., dismissed motions
+for convening of three-judge district
+court and for preliminary injunction and
+dismissed the complaint. The plaintifts
+appealed.
+The Court of Appeals, Gibbons, Circuit Judge, held that where
+only allegation advanced by plaintiffs in
+support of injunction against pending
+federal criminal prosecution for using
+extortionate means to collect or attempting to collect extensions of credit was
+inconvenience of the trial and preference
+for civil remedy before three-judge dis.
+
+
+470
+431 PEDERAL REPORTER, 2d SERIES
+trict court instead of single-judge court,
+judge panels. U.S.C.A.Const. Amend. 1;
+complaint failed to state claim for in-
+28 U.S.C.A. S8 2281, 2282, 2284.
+junctive relief and did not warrant convening of three-judge court.
+6. Courts e101
+Single-judge district court may ad-
+Affirmed.
+judicate claim for declaratory relief if
+the court has subject matter jurisdic.
+1. Courts 385(1)
+tion. 28 U.S.C.A. IS 2201, 2202.
+Where district court enters appeala-
+7. Courts 101
+ble order, review of its refusal to con-
+Where single-judge district court's
+vene a three-judge district court lies in
+jurisdiction of remaining claim for dethe Court of Appeals. 28 U.S.C.A. §
+claratory relief after denial of application for convening of three-judge dis-
+2. Courts 101
+In determining substantiality of
+claimed constitutional
+question
+which request for three-judge district
+court is based, the district court makes a
+judicial decision and district court must
+look beyond prayer for relief to the substantive allegations of the complaint. 28
+U.S.C.A. § 2284.
+3. Injunetion 105(1)
+While activities protected by First
+Amendment are common bases for injunctive relief against actual or threattrict court was based on statute granting district court original jurisdiction of
+all civil actions wherein matter in controversy exceeds the sum of $10,000 and
+arises under Constitution, laws, or trea
+ties of the United States, but complaint
+did not allege the requisite jurisdietional amount, single-judge court properly
+dismissed plaintiff's claim for declaration that Congress was without power to
+prohibit intrastate loan sharking.
+18
+U.S.C.A. 55 891, 892, 894; 28 U.S.C.A.
+88 1331, 2201, 2202.
+are not the sine qua non for injunctions
+against criminal prosecutions, U.S.C.A.
+Const. Amend. 1; 28 U.S.C.A. 88 2281,
+2282, 2284.
+4. Courts 6-101
+Where only allegation advanced by
+plaintiffs in
+injunction
+against pending federal criminal prosecution for using extortionate means to
+collect or attempting to collect extensions of credit was inconvenience of the
+trial and preference for civil remedy before three-judge district court instead of
+single-judge court, complaint failed to
+state claim for injunctive relief and did
+not warrant convening of three-judge
+court. 18 U.S.C.A. §5 891, 892, 894; 28
+U.S.C.A. §§ 2282, 2284.
+5. Courts -101
+District court should judiciously and
+cautiously screen applications for three-
+Filindo B. Masino, Berk, Masino &
+Moonblatt, Philadelphia, Pa., for appellants.
+Frederick P. Hafetz, Justice Dept.,
+Newark, N. J., for appellees.
+Before WINTER* ALDISERT and
+GIBBONS, Circuit Judges.
+OPINION OF THE COURT
+GIBBONS, Circuit Judge.
+On December 16, 1969 a Federal
+Grand Jury sitting at Newark, New Jersey, handed up a seven count indictment
+(Crim. No. 545-69) against appellants,
+Majuri and Caruano, along with others
+not parties to this action. Three counts
+of that indictment charged appellants
+with conspiracy to make, the making of,
+and the collection of extortionate extension of credit, in violation of
+U.S.C.
+65891, 892, and 894 (Supp. 1970).
+That criminal case was routinely as
+signed to the Honorable Leonard I.
+• Cireuit Judge of the Court of Appeals for the Fourth Circuit, sitting by deaignation.
+
+
+MAJURI V. UNITED STATES
+471
+Cite as 431 F.2d 469 (1870)
+Garth for pretrial motions, and he didergo grave personal inconvenience
+rected a time schedule for the orderly
+and anxiety in the preparation of a
+filing, briefing and argument of such
+defense to these charges.
+motions. In the criminal case the de-
+4. Unless the Defendants are enfendants have filed a motion to dismiss
+joined and restricted from committing
+so much of the indictment as charges
+the threatened acts, the Plaintiffs will
+them with violations of 18 U.S.C. §§ 891,
+suffer great and irreparable damage
+892, and 894, on the ground that those
+in that they believe, upon the advice
+sections of Title 18 were enacted by
+of counsel, that Sections 891, 892 and
+Congress without constitutional authori-
+894 of Title 18, U.S.C. are unconstituty and in violation of the Ninth and
+tional and repugnant to the 9th and
+Tenth Amendments to the United States
+10th Amendments
+to
+the United
+Constitution. Their contention is that
+States Constitution
+*.
+Congress is without power to prohibit
+Appendix at 24-25.
+intrastate loansharking.
+Defendants in this civil action are de-
+Appellants' motion to dismiss the
+scribed in the complaint as
+"the soverloansharking counts of the indictment is
+eign, and Law Enforcement Officials
+still pending and undecided in the dis- charged with the Prosecution of these
+trict court, solely because of the pen- matters." The prayer for relief seeks a
+dency of the civil action in which this preliminary and a permanent injunetion
+appeal arises. On March 30, 1970, aprestraining the defendants from propellants filed a complaint alleging the
+ceeding with "any prosecution based on
+fact of indietment Crim. No. 545-69,
+the provisions of Sections 891, 892, and
+and:
+894
+*
+*."
+Plaintiffs alleged that Sections
+With the complaint and affidavits, ap-
+891, 892, and 894 of Title 18, United
+pellants filed a motion pursuant to 28
+States Code, are repugnant to the 9th
+U.S.C. § 2284 (1964) for the convening
+and 10th Amendments to the United
+of a three-judge district court and a mo-
+States Constitution, in that they are
+tion for a preliminary injunction. The
+vague, speculative, and do not charge
+civil action was also assigned to Judge
+an offense cognizable under the Unit-
+Garth. Both motions were heard by him
+ed States Constitution.
+on April 13, 1970.
+No answering plead-
+5. Plaintiffs allege that unless the
+ings were filed but the United States At-
+defendants are restrained from entorney appeared and filed an extensive
+forcement of these provisions, the
+memorandum raising legal issues as to
+plaintiffs will suffer severe and irrepthe sufficiency of the complaint in sevarable harm, as more fully set forth in
+eral particulars.
+the affidavits attached hereto.
+The government contended (1) that
+Appendix at 19.
+the claim of unconstitutionality is so insubstantial as to be frivolous, and (2)
+that the complaint and affidavits show
+no basis for equitable relief. On May 7,
+are free on substantial
+trial. They also allege:
+1970 the district court filed a memorandum and order disposing of these congreat sums of money, as well as to un-
+2213
+. United States v. Peres, 428 F.2d 107:
+2 Cir.. May 1, 1970): United States v
+De Lutro. 309 F.Supp.
+F.2d 584 (7 Cir. 1970):
+Baited States 1 Carefo, 310 F.Supp. 351
+
+
+472
+431 FEDERAL REPORTER, 2d SERIES
+leas, that the constitutional issue was at
+Appellants contend that having found
+least sufficiently substantial to be bethe federal constitutional question to be
+yond the province of a single judge. On
+at least not frivolous, the district court
+the second issue, however, it held that
+should have made no further inquiry,
+the complaint failed to allege facts suffibut should thereupon have entertained
+cient to invoke traditional equitable juthe request for a three judge court as a
+risdietion, Therefore, it denied injunematter of form. Principal reliance for
+tive relief, denied appellants' motion to
+convene a three-judge court, and dismissed the complaint.
+position is upon the language Idle-
+Bon Voyage Liquor Corp.
+sten, supra 370 U.S. at 715, 82 S.Ct. at
+Appellants filed notices of appeal and
+on May 19, 1970, applied to a panel of
+this court for injunctive relief pending
+appeal and for a stay of the judgment of
+the district court. The panel ordered an
+accelerated briefing schedule
+ferred those motions to the panel which
+would hear argument on the merits.
+[1] Although it was not always so,
+it is now clear that, at least in cases
+where, as here, the district court enters
+an appealable order, review of a refusal
+thieven in Lue oil im in
+90 S.Ct. 2018, 26
+684(1970);
+Mengelkoch
+S9 S.Ct, 60, 21 L.Ed.2d 215
+(1968) ;
+vaca, 391 U.S. 352, 88 S.Ct. 1509, 20 L
+Ed.2d 636 (1968); Schackman
+ergh, 387 U.S. 427, 87 S.Ct. 1622, 18 I
+385 U. 1967); Buchanan Rhodes
+87 S.Ct. 33, 17 [.Ed.2d 3
+Idlewild Bon Voyage Liquor
+Corp. v. Epstein, 370 U.S. 713, 82 S.Ct.
+1294, 8 L.Ed.2d 794 (1962). Since in
+this case we affirm that
+not now decide whether or not
+there is jurisdiction in the court of appeals to grant preliminary injunctive relief pending appeal, or equivalent preliminary relief within the federal judicial
+system by way of mandamus pending appeal, or mandamus relief in the absence
+of an appealable order.3
+= 10, 81 8.C. 5, 76 1, a 1a5 (2). S
+10, 51 8.
+Darte Metropolitan Water Co.,
+230 U.8.
+8, 81, S.Ct. 600, 55 L.Ed. 575 (1911)
+Iller Smith, 238 F.Supp. 927 (E.
+When an application for a statutory
+three-judge court is addressed to a
+district court, the court's inquiry is
+appropriately limited to determining
+whether the constitutional question
+raised is substantial, whether the complaint at least formally alleges a basis
+for equitable relief, and whether the
+case presented otherwise comes within
+the requirements of the three-judge
+statute. (Italics added)
+Appellants emphasize that their prayer
+for relief asks for an injunction, that
+the complaint contains the words "irreparable injury" and that this is all the
+Supreme Court intended to require by
+the language "at least formally alleges a
+basis for equitable relief."
+[2] We do not agree.
+that in determining the substantiality of
+the claimed constitutional question the
+distriet court makes a judicial decision.
+Schneider v. Rusk, 372 U.S. 224, 83 S.Ct.
+621, 9 L.Ed.2d 695 (1963); Ex parte
+Eat 162 21985): Huma exaco
+Ed. 152 (1933); Fiumara
+Inc., 240 F.Supp. 325,
+326 (E.D.Pa.
+1965); Miller
+Smith, supra note 2
+Its function is
+analagous to that of a
+court reviewing a complaint for legal
+sufficiency under Rules 12(b)(1) or
+3. Seo Gunni
+University Committee,
+012(5 Ta 1009) Choose 10a voren, 402
+E.2d 890, 892 (1 Cir. 1965
+), cert. denied
+861, 21 LEd.2
+Commission, 311
+F.Supp.
+1970).
+
+
+MAJURI - UNITED STATES
+473
+Cite as 481 F.2d 469 (1870)
+Supreme Court the intention, in the
+lege that they should be free to continue
+same sentence of Idlewild Bon Voyage
+intrastate loansharking. They say, only,
+Liquor Corp. v. Epstein, supra 370 U.S.
+that it is inconvenient and expensive to
+at 715, 82 S.Ct. at 1294, to distinguish beraise their constitutional contentions by
+tween the distriet court's role in deterappropriate pretrial and trial motions in
+mining substantiality of a constitutional
+the criminal case, though they have in
+question and ita role in determining the
+fact done so. They do not even explain
+existence of a ground for equitable rehow it will be any less expensive to try
+lief. Both decisions are judicial rather
+the constitutional issues in this civil
+than ministerial. Both require that the
+case than in the criminal case.
+district court look beyond the prayer for
+relief to the substantive allegations of
+the complaint.
+Appellants suggest, however, that the
+decision as to substantiality of the federal constitutional question is "jurisdie-
+App.D.C. 387, 354 F.2d 519 (1965),
+stressed in its memorandum the absence
+tional", at least in non-diversity cases,
+of any alleged infringement of first
+whereas a decision that the complaint
+fails to state a claim for equitable relief
+amendment rights. While activities prois a decision "on the merits" and hence
+tected by the first amendment are a
+common basis
+injunctive relief
+one which by virtue of 28 U.S.C. § 2284
+against actual or threatened
+a single judge may not make. But it
+prosecution, they are not the only activiseems to us that a decision that a
+ties worthy of such protection in approclaimed question of constitutional law is
+See, e.g., Hynes
+insubstantial is èven more clearly on the
+merits, and such decision is now a firm-
+v. Grimes Packing Co., 337 U.S. 86, 98,
+93 L.Ed. 1231 (1949):
+established duty of a single district
+Frink Dairy Co., 274 U.S. 49D,
+court judge. A finding of insubstantial-
+451, 47 fi.Ct. 681, 71 L.Ed. 1146 (1927):
+ity of the constitutional question is,
+Society of Sisters, 268 U.S.
+moreover, one involving a more sophisticated judgment than that required to de-
+P0, 635, 45 S.Ct. 671, 69 L.Bd. 1070
+termine whether or not a complaint
+man, 266 U.S. 497, 500, 40 g.ot. 141, 6r.
+man, 266 U.S. 497, 500, 45 S.Ct.
+states a cause of action for injunctive
+L.Ed 402 (1925); Terrace | Thompson
+relief. Over recent history far greater
+263 U.S. 197, 214, 44 S.Ct.
+growth and change has taken place, and
+255 (1923); Truax - Raich, 239 U.S
+undoubtedly will continue to take place,
+33, 37, 36 S.Ct. T, 60 L.Ed. 131 (1915).
+in federal constitutional law than in the
+We do not, by affirming, therefore, suglaw of equitable remedies.
+gest agreement with a possible interpre-
+We agree, therefore, that it was the
+tation of the district court opinion, that
+district court judge's duty to examine
+first amendment rights are a sine qua
+the complaint for substantive allegations
+injunctions against criminal
+which would support a claim for injuneprosecutions.
+tive relief, and not to look merely at the
+prayer for relief and the conclusive alle-
+But, where, as here, the only algation of irreparable injury.
+legation advanced in support of an injunction against a pending federal crim-
+Appellants are not faced with the
+inal prosecution is the inconvenience of
+choice of committing a violation of the
+that trial and the preference for a civil
+criminal statute in order to test their
+remedy before three judges instead of
+constitutional contentions. There is no
+one, the complaint fails to state a claim
+allegation that the pendency of the crimfor injunctive relief, and does not fall
+inal charge inhibits them from engaging
+within the province of 28 U.S.C. §$ 2282
+in protected activities. They do not al- and 2284.
+
+
+474
+431 FEDERAL REPORTER, 2d SERIES
+[5]
+What is here approved is a judicious screening by the district courts of
+applications for three-judge
+panels.
+That screening should be done cautiously, of course, because of the procedural
+court will be in all respects affirmed.
+All motions made in this court and not
+heretofore disposed of will be denied.
+and jurisdictional morass into which litigants may be led by these troublesome
+three-judge court statutes. 28 U.S.C. §5
+2281, 2282, and 2284. But the role of
+the single district judge should be more
+than a conditioned reflex to such an application, especially now that the Su-
+preme Court has provided for judicial review in the circuit courts of appeals at
+least when an appealable order has been
+entered.* In most if not all cases, refusal
+UNITED STATES of America,
+Plaintitt-Appellee,
+to convene a three-judge court will be
+accompanied by the denial of a preliminary injunetion and hence will be appealable. 28 U.S.C. § 1292 (1964).
+[6, 7] One other problem
+remains.
+The district court not only denied appellants' motions to convene a three-judge
+court and to grant a preliminary injuneriffin Thomas WILLIAMS, Jr
+efendant-Appellan
+No. 28219
+Summary Calendar.*
+United States Court of Appeals,
+Fifth Circuit.
+Oct. 2, 1970.
+tion, but also dismissed the complaint.
+On another record the latter step might
+well be questionable, since it would dispose, without hearing,
+claim for declaratory relief. See Note,
+The Federal Anti-Injunction Statute and
+Declaratory Judgments in Constitutional
+Litigation, 83 Harv.L.Rev. 1870 (1970).
+Such relief, assuming subject matter jurisdiction, would be available from a single judge.
+But the Declaratory Judgment Act, 28 U.S.C. 4§ 2201-02 (1964),
+is limited in operation to those cases
+Courts e=104
+Criminal Law @=1182
+On factors delineated in Nationa
+Labor Relations Board | Amalgamatec
+Clothing Workers of America, AFL
+CIO, Local 990, 5th Cir., 1970, 430 F.2d
+966, under U.S.Ct. of App. 5th Cir.,
+Rules 18 and 21, 28 U.S.C.A., case was
+waced opinionary calendar and decided
+which would be otherwise within the jurisdiction of the federal courts. Jurisdiction in this case depends upon 28 U.
+S.C. § 1381 (1964), and there is no alle-
+Appeal from the United States District Court for the Northern District of
+gation in the complaint or affidavits of
+the requisite jurisdictional amount. The
+Georgia at Atlanta; Newell Edenfield,
+District Judge.
+situation might be different if the suit
+challenged a state statute and jurisdie- Atlanta, Ga., for appellant
+S. 496, 513, 59 S.Ct. 964, 83 L.Ed. 1423 for appellee.
+4. See cases cited at 472 supra.
+* Rule 18, 5th Cir.; See Isbell Enterprises,
+Ine. Y. Citizens Casalty Co. of New York
+et al, 5th Cir., 1970, 431 F.24 409, Part
+
+
+WALLACE OTTY OF PAGEDALE
+allowance during the four year protecqualified to perform." 13 Thus, Sheppard's obtaining a job as spike puller on
+Southern did not offer or advise Sheppard of other railroad employment upon
+his release following the change in
+A&EC ownership. Soon after his discharge, Sheppard learned from an independent source of an open job as spike
+puller with an A&EC labor gang out of
+Morehead City. He had worked out of
+New Bern while a diesel mechanic's help-
+Southern admits that Sheppard
+sought and obtained the open position on
+his own initiative. Sheppard's new emloyment required different skills that
+is old job and paid him a lower ag
+his own initiative, as the district court
+thought, is analogous to a dismissed railroad worker unsuccessfully attempting
+work other than railroad employment.
+Such a situation is within the scope and
+purpose of the dismissal benefits accorded under the Act.
+Whether the second dismissal was for
+cause in the sense that Sheppard could
+not do the work or for cause in the sense
+of insubordination, we think the district
+court rightly adjudged that he lost his
+sult of the acquisition of the A&EC by
+Southern is, of course, er
+Sheppard was discharged from the
+titled to reduce the compensation owin
+new position as spike puller after only a
+to Sheppard by the amount of his tempoweek because of his intemperate prorary earnings—whether as a spike puller
+test " when asked to assist in lifting a
+with the A&EC or in other employment
+half-ton motor car from the tracks.
+10,869, Reversed.
+[4] We believe the district court was
+10,870, Affirmed.
+correct in treating
+Sheppard's employ-
+10,873, Affirmed.
+ment as a spike puller "in a manner as
+if [he]
+had found work with
+an employer totally unrelated to railroading." 1ª It was, therefore, unnecessary to determine whether Sheppard's
+second dismissal was for good cause.
+[5] We interpret
+Conditions interan that an oployee is
+Richard WALLACH, Appellant,
+not "retained" in a position—-and thus
+displaced as opposed to
+dismissed—un-
+CITY OF PAGEDALE et al., Appellees.
+less retained at the instance of the rail-
+No. 18580.
+road. We think that displacement con-
+United States Court of Appeals
+ditions should not be substituted for
+Eighth Circult.
+except where an
+May 9, 1967.
+employee receives an offer from the railroad to continue in or return to a new
+position for which he is qualified. Shep-
+Civil rights action seeking redress
+pard's second discharge may or may not for the deprivation of rights and conhave resulted from his inability to perspiracy to interfere with civil rights.
+form the new work he attempted. Such
+The United States District Court for the
+inability could well account for insub- Eastern District of Missouri, Roy W.
+ordination and intemperance of lan-
+Harper, C. J., dismissed the action, 41
+guage. We need not decide—-because he F.R.D. 547, and appeal was taken. The
+was not notified by the carrier of a posi-
+Court of Appeals, Van Oosterhout, Cirtion "the duties of which he [was] * •
+cuit Judge, held that civil rights action
+HI. He said: "Wait a God damn minute."
+13. Oklaboma Conditions f 5, supra.
+12. Sheppard Southern Ry. Co., 258 F.
+Supp. 217, 222(1906).
+
+
+672
+376 FEDERAL REPORTER, 2d SERIES
+was properly dismissed for lack of ju-
+Richard Wallach, Wellston, Mo., made
+argument pro se and filed brief pro se.
+Paul J. Boll, St. Louis, Mo., for appellee and filed typewritten brief.
+Before VAN OOSTERHOUT, MAT-
+THES and LAY, Cireuit Judges.
+See also 264 F.Supp. 271.
+VAN OOSTERHOUT, Circuit Judge.
+The trial court dismissed this action
+commenced by plaintiff Wallach which
+asserted juriediction in the federal court
+under 28 U.S.C.A. § 1331 (federal ques-
+• Injunction 8=105(1
+To person is immune from prosec
+tion in good faith for his alleged criminal acts, and imminence of prosecution
+even though alleged to be in violation of
+constitutional guarantees is not ground
+for equity relief since lawfulness or constitutionality of statute or ordinance on
+which prosecution is based may be determined as readily in criminal case as in
+tion) and 28 U.S.C.A. § 1343 (violation
+of civil rights.) Diversity jurisdiction is
+not asserted and does not exist. The
+asic grievances asserted here are th
+ame as those urged in Wallach • Cit:
+of Pagedale, 8 Cir., 359 F.2d 57, and are
+asserted damages flowing from alleged
+violation by defendants of plaintiff's constitutional rights.
+Defendants moved for dismissal of the
+action on the following grounds:
+"(a) That
+the
+claim
+asserted
+Where threatened criminal prosecution is by state officers for alleged violations of state law, the state courts are
+final arbiters of meaning and application
+of state law, subject only to review by
+United States Supreme Court on federal
+grounds appropriately asserted.
+4. Constitutional Law 230(3)
+Conferring of discretionary power
+upon administrative board to grant or
+withhold permission to carry on trade or
+business properly subject to regulation
+under police power does not violate
+Fourteenth Amendment. U.S.C.A.Const.
+Amend. 14.
+5. Courts -260.2
+Federal courts have only that jurisdiction which Congress, acting within
+the limits of the Constitution, confers
+upon them.
+6. Federal Civil Procedure 1742
+Civil rights action was properly dismissed for lack of jurisdiction where
+plaintiff did not, by his pleadings or in
+any other manner, meet the burden resting upon him to establish federal jurisdiction. 28 U.S.C.A. §§ 1331, 1343.
+gainst the detendante 1s not a clain
+pon thieh relief can be granted; an
+"(b) That this Court has no jurisdiction over the subject matter of the
+claim presented between the plaintiffs
+and the defendants.
+"(e) That the petition of plaintiff
+fails to comply with Rule 8, Federal
+Rules of Civil Procedure in that the
+averments therein are not simple, concise or direct, in respect to jurisdietion, facts or relief and is so vague,
+ambiguous, rambling and full of irrelevant averments that these defendants cannot be reasonably required to
+frame a responsive pleading thereto."
+The motion to dismiss was sustained.
+The case was dismissed without prejudice for want of jurisdiction. Plaintiff
+has appealed from such dismissal.
+The trial court cited our former opinion in Wallach | City of Pagedale, supra.
+We there stated:
+"There is no doubt that the complaint does not comply with Rule 8
+(a) as it does not contain 'a short and
+plain statement of the claim showing
+that the pleader is entitled to relief.'
+
+
+WALLACH V. CITY OF PAGEDALE
+673
+The complaint is confusing, ambiguous, redundant, vague, and, in some
+respects, unintelligible. It is also
+highly argumentative." 359 F.2d 57,
+We went on to state that the pleadings,
+even if given a liberal interpretation, do
+not state a cause of action against the
+defendants within the jurisdiction of the
+federal court, setting forth the basis for
+such conclusion and supporting authorities. The complaint now before us is
+much more extensive than the former
+complaint but in our view it is in greater violation of Rule 8 than the complaint
+previously considered.
+Plaintiff in his present voluminous,
+repetitious, confusing and argumentative
+complaint asserts that he acquired real
+estate in an unincorporated area in St.
+Louis County which was zoned as heavy
+industrial property upon which he was
+permitted to and did establish a junk
+yard and automobile wrecking yard in
+conformity with the St. Louis County
+zoning ordinance adopted in 1946. It is
+then asserted that plaintiff's property
+was maliciously and illegally annexed to
+the city of Pagedale but no substantial
+legal grounds are asserted to support the
+claim of invalid annexation.
+next asserts in a highly inflammatory
+manner that numerous zoning and licensing ordinances were passed by the city
+of Pagedale both before and after the
+annexation in violation of numerous
+rights guaranteed plaintiff by the Con-
+Some of such ordinances are
+cited by number and excerpts of part of
+the ordinances are set out.
+As shown by the complaint, Ordinance
+No. 88 passed by the city before the annexation provides for the zoning of the
+city but specifically carries a provision
+reading:
+"The lawful use of land, buildings
+and structures existing at the time of
+the adoption of this ordinance may be
+continued, although such use does not
+conform to the provisions thereof, but
+if such non-conforming use is discontinued, any use in the future of such
+premises shall be in conformity with
+the provisions of this ordinance."
+It would appear from the complaint that
+Ordinance No. 88 was amended in 1954
+to zone the annexed property, including
+plaintiff's property, with the provisions
+of Ordinance No. 88 made applicable to
+the annexed property.
+Thus, on their face the ordinances
+pleaded with respect to zoning appear to
+protect the rights of nonconforming
+users and the basis of the asserted invalidity of such ordinances does not reasonably appear in the complaint.
+It would seem from the complaint and
+statements in oral argument that there
+is a question whether the prior junk yard
+operation was the plaintiff's own or by a
+corporation in which he was interested
+and there is also some intimation that the
+prior use of the property may have been
+Plaintiff's principal claims of wrongs
+committed by the defendants appear to
+be: (1) His arrest and conviction in the
+Pagedale police court for operating a
+junk yard without a license; (2) the
+city's refusal to permit plaintiff to use
+his premises for its highest and best use
+—a junk yard—-thereby depriving plaintiff of income needed to pay mortgage indebtedness and the refusal of the city to
+grant a license to a prospective purchaser
+which resulted in plaintiff's inability to
+make an advantageous sale of such property, and his loss of the property through
+mortgage foreclosure for a sum considerably under its fair value.
+prays for declaratory judgment and for
+such further relief as may be just.
+It would appear that the claimed grievances arise primarily out of the licensing
+requirements of the city ordinances.
+[1-3] With respect to the propriety
+of federal courts interfering with state
+criminal prosecutions, the rule is stated
+in Douglas v. City of Jeannette, 319 U.S.
+157, 163-164, 63 S.Ct. 877, 881, 87 L.Ed.
+1324, as follows:
+"Congress, by its legislation, has
+adopted the policy, with certain well
+defined statutory exceptions, of leav-
+
+
+674
+376 FEDERAL REPORTER, 2d SERIES
+ing generally to the state courts the stitutional rights. Plaintiff quotes part
+trial of criminal cases arising under
+of Ordinance No. 23 relating to licensing
+state laws, subject to review by this
+of junk dealers and license fees and then
+Court of any
+volved. * • Lederal questions inasserts that his business does not fall
+within any of the categories listed in the
+"It is a familiar rule that courts of
+Later plaintiff refers to
+equity do not ordinarily restrain crim-
+Ordinance No. 227 relating to regulating,
+inal prosecutions. No person is imlicensing and license fees for automobile
+mune from prosecution in good faith
+lots, and No. 228 with reapect to licensing
+for his alleged criminal acts. Its imand license fees for salvage yards, both
+enacted in 1959. Neither of such ordiminence, even though alleged to be in
+nances are set out in whole or pertinent
+violation of constitutional guarantees,
+is not a ground for equity relief since
+part. No ascertainable attack is made
+the lawfulness or constitutionality of
+on the validity of such ordinances but
+the statute or ordinance on which the
+rather the claim is made that the plainprosecution is based may be detertiff's business does not fit the classificamined as readily in the criminal case
+tions covered by the ordinances.
+would appear that the questions raised
+as in a suit for an insunction.
+primarily relate to the interpretation of
+& Farnum Mfg. Co.
+• [City of] Los
+Angeles, 189 U.S. 207 [23 S.Ct. 498,
+the ordinances and that such questions
+47 L.Ed. 778] ; Fenner v. Boykin, 271
+are questions of state law.
+U.S. 240 [46 S.Ct, 492, 70 L.Ed. 927].
+Plaintiff does not state what attempt,
+Where the threatened prosecution is
+if any, he made to comply with the liby state officers for alleged violations
+censing ordinances nor make any clearof a state law, the state courts are the
+cut allegation that he made any proper
+final arbiters of its meaning and apapplication for a license, and if so, that
+plication, subject only to review by this
+any basis exists for a determination that
+Court on federal grounds appropriatethe city abused its discretion in withly asserted. Hence the arrest by the
+holding a license.
+federal courts of the processes of the
+[4] In Mosher | Beirne, 8 Cir., 357
+criminal law within the states, and the
+F.2d 638, 640-641, we sustained the disdetermination of questions of criminal
+missal of plaintiff's action based on 28
+liability under state law by a federal
+U.S.C.A. § 1343, wherein plaintiff claimcourt of equity, are to be supported
+ed a city improperly refused him a lionly on a showing of danger of ircense to operate a publie dance. We
+reparable injury 'both great and immediate.'"
+See Outdoor American Corp. | City of
+Philadelphia, 3 Cir., 333 F.2d 963, 965.
+No extraordinary circumstances are
+dur pren on the sh word
+stated. On oral argument, it developed
+that plaintiff appealed from his convic
+tion and that such appeal is still pending.
+• license was denied to him to operat
+is junk yard in violation of his con
+'"The rights and necessity for restrictions in municipal zoning ordinances have long been sustained. Village of Euclid, Ohio - Ambler Realty
+Co., 272 U.S. 365, 47 S.Ct. 114, 71
+I.Ed. 303 [54 A.L.R. 1016] (1926).
+It has also been recognized that the
+conferring of discretionary power upon administrative boards to grant or
+withhold permission to carry on a
+trade or business which is the proper
+subject of regulation within the police
+power of the state is not violative of
+Ambe set, peple the tae of enth
+
+
+UNITED STATES | OUSTER CHANNEL WING CORPORATION
+675
+Cite an 376 5.3d 675 (1987)
+York ex rel. Lieberman | Van De
+Carr, 199 U.S. 552, 26 S.Ct. 144, 50
+L.Ed. 305 (1905); and that ordinances validly prohibiting the opera
+tion of certain businesses without first
+obtaining municipal permission do not
+deprive one of his property without
+due process of law nor deny one the
+equal protection of the law, Fischer v.
+City of St. Louis, 194 U.S. 361, 24
+.Ct. 673, 48 LEd, 1018 (1904)."
+In Garfinkle | Superior Court of Nev
+UNITED STATES of America,
+Appellee,
+1
+CUSTER CHANNEL WING CORPORA
+TION and Willard R. Custer,
+Appellants.
+No. 10399.
+United States Court of Appeals
+Fourth Cireult.
+Argued Feb. 8, 1967.
+Decided April 3, 1967.
+Jersey, 3 Cir., 278 F.2d 674, the court
+in affirming the dismissal of an actior
+based on violation of federal constitutional rights concluded, "His stated fundamental facts, irrespective of their
+fantastic nature, certainly do not show
+clearly and distinetly that this suit is
+based on a federal question." What was
+said there is fully applicable here.
+[5] Federal courts have only that jurisdiction which Congress, acting within the limits of the Constitution, confers
+"The party invoking the district
+court's original jurisdiction has the
+duty of affirmatively alleging jurisdiction; and,
+properly controverted, the burden of
+establishing jurisdiction. Lack of federal jurisdiction may be raised by motion or in the responsive pleading.
+And 'whenever it appears by suggestion of the parties or otherwise that
+the court lacks jurisdiction of the subject matter, the court shall dismiss
+the action.'" 1 Moore's Federal Prac-
+Criminal contempt proceeding initiated by government for violation of injunction prohibiting use of interstate
+commerce and mails to promote sales of
+unregistered securities.
+The United
+States District Court for the Distriet of
+Maryland, at Baltimore, Harrison L.
+Winter, J., 247 F.Supp. 481, entered judgment of conviction, and appeals were
+taken. The Court of Appeals, Sobeloff,
+Circuit Judge, held, inter alia, that where
+defendants had already breached securities law proscribing sale of unregistered
+securities to purchasers without acceas to
+pertinent financial information and had
+been enjoined not to do so again, but
+knowingly repeated selfsame forbidden
+acts, to be adjudged in criminal contempt,
+it was enough to show that they intentionally committed acts constituting violation with full knowledge of all relevant
+circumstances, and proof of evil purpose or bad motive, that is, proof of a
+specific intent to violate the injunction,
+Civil Procedure No. 8(a) (1).
+1. Licenses 6-18½ (47)
+Sale of securities was public offer-
+[6] Defendants have by motion ating, and not exempt from registration as
+tacked the jurisdiction of the federal
+a private offering, where none of purcourt to hear this case. Plaintiff has not
+chasers had access to kind of informaby his pleadings or in any other manner
+tion that would have become available to
+met the burden resting upon him to esthem through a registration statement,
+tablish federal jurisdiction.
+although purchasers may have been
+The judgment dismissing the petition
+sophisticated investors. Securities Act
+without prejudice for the lack of jurisof 1933, Schedule A, 16 U.S.C.A. § 77aa,
+diction is affirmed.
+Schedule A; Securities Act of 1938, §5
+
+
+APPEAL OF KITZER
+677
+Cite as 309 F.2d 677 (1968)
+inal judgment, it is not unlikely that ap- denial of request for order suppressing
+pellees would have attempted to prepare evidence consisting of testimony althemselves with evidence relating to the legedly "tainted" on theory that such
+disputed amount. That the appellant's testimony to Grand Jury in Illinois was
+representation in its pre-trial memoran- wrongfully transmitted to Grand Jury in
+dum evidenced its understanding of its Minnesota was properly denied without
+burden is confirmed by the fact that it hearing, absent allegations which had not
+did indeed undertake to offer proof in been concluded by Minnesota court's dethe presentation of its case in chief. It nial of petitioner's motion to dismiss
+is essential to the orderly disposition of Minnesota indictment.
+litigation that parties, as well as courts,
+be able to rely on procedural courses
+which have been clearly defined and established in properly conducted pre-trial
+[9] The entire record supports the
+District Court's conclusion that the burden of proof in this case rested upon
+appellant. It had agreed to meet it, and
+it did not do so. The judgment is
+Affirmed.
+In the Matter of the Testimony of Phillip
+Kitzer, Sr., Before the United States
+Grand Jury-65 GJ 2072.
+Appeal of Phillip KITZER, Sr.
+No. 15650.
+United States Court of Appeals
+Seventh Circuit.
+Nov. 18, 1966.
+1. Injunction 105(1)
+Mandamus C-61
+District court was without jurisdiction to control discretionary actions of
+Attorney General and could not, on theory
+that testimony before Grand Jury in
+Illinois was wrongfully transmitted to
+Grand Jury in Minnesota, grant relief
+by way of an order directing Attorney
+General to move Minnesota District
+Court to dismiss indictment or an order
+restraining further proceedings in prosecution of Minnesota indictment.
+U.S.
+C.A.Const. Amend. 5; Fed.Rules Crim.
+Proc. rule 6(e), 18 U.S.C.A.
+2. Criminal Law 6-394.6(5)
+Denial of request for order suppressing evidence consisting of testimony allegedly "tainted" on theory that such
+testimony to Grand Jury in Illinois was
+wrongfully transmitted to Grand Jury
+in Minnesota, was properly denied without hearing, absent allegations which had
+not been concluded by Minnesota court's
+denial of petitioner's motion to dismiss
+Minnesota indictment.
+U.S.C.A.Const.
+mend. 5; Fed.Rules Crim.Proc. rule
+(e), 41(e), 18 U.S.C..
+Petition seeking relief for allegedly
+wrongful transmission of testimony,
+given to Grand Jury in Illinois, to Grand
+Doris A. Coonrod, Chicago, IIl., for
+Jury in Minnesota. The United States
+District Court for the Northern District
+of Illinois, Eastern Division, William J.
+Campbell, Chief Judge, entered judgment dismissing the petition without a
+hearing, and petitioner appealed. The
+KNOCH,
+Court of Appeals held, inter alia, that
+SWYCERT, Circuit Judges.
+KILEY and
+
+
+678
+369 FEDERAL REPORTER, 2d SERIES
+PER CURIAM.
+[2] The request for an order sup-
+Petitioner Phillip Kitzer, Sr., contends
+pressing the "tainted" evidence pursuant
+to Fed.R.Crim.P. 41(e) contained no allethat he was denied due process in violagations which had not been concluded by
+tion of the Fifth Amendment of the Conthe Minnesota court's denial of petitionstitution because the district court denied
+er's motion to dismiss the Minnesota
+him a hearing before entering judgment
+indictment. No authority has been cited
+dismissing his sworn petition. We have
+to support Kitzer's claim to a hearing
+considered the briefs and the record in
+on his 41(e) motion when a previous mothe light of the oral arguments made in
+tion on the same grounds was denied.
+this court, and we affirm the judgment.
+We see no merit in this contention and
+The substance of the petition is that hold that the district court did not err in
+Kitzer gave certain testimony to the
+denying the 41(e) motion without a hear-
+Affirmed.
+t the Assistant United States Attorne
+hat he would not be named in any indict
+ment based upon that testimony; that
+notwithstanding the promise, the testihority of a court order to a Grand Jur
+1 Minnesota in violation of Fed.I
+ern District of Illinois authorizing trans
+mission of that testimony to the Minne
+nowledge of the broken promise to
+witzer and without knowledge that the
+Roy MUNDRY and Charlotte Mundry,
+GREAT AMERICAN INSURANCE COME.
+No. 105, Docket 30364.
+Unitad Staton Coreut Appeals
+Argued Oct. 27, 1966.
+Decided Dec. 14, 1966.
+Minnesota Grand Jury
+United States Attorney.
+The relief prayed was an order directing the Attorney General of the United
+States to move the Minnesota District
+Court to dismiss the indietment or, alternatively, for an order restraining further proceedings in the prosecution of
+the Minnesota indictment or an order
+suppressing as evidence in that prosecution the disclosures made by petitioner to
+the Grand Jury in the Northern District
+of Illinois.
+[1] We think it is clear that the district court was without jurisdiction to
+control discretionary actions of the At-
+orney General or to grant the relief re
+quested with respect to him. Goldberg i
+• Hoffman, 225 F.2d 463 (7th Cir. 1955).
+Appeal from judgment of United
+States District Court for the District of
+Connecticut, 248 F.Supp. 817, Robert C.
+Zampano, J., holding that the appellant
+had waived, and was estopped from asserting, its contractual right to disclaim
+its liability under automobile insurance
+policy. The Court of Appeals, Irving R.
+Kaufman, Circuit Judge, held that where,
+Kaufman, Circuit Judge, held that where
+insurer's disclaimer of liability on automobile liability policy because of noncooperation of insureds was conceded to
+be timely, plaintiff injured parties were
+free to discontinue their suit if they
+thought defendant insureds were judg-
+
+
+32
+351 FEDERAL REPORTER, 24 SERIES
+prosecution and trial on the earlier
+charge of "uttering a forged instrument." He was subsequently found guilty by a jury in the Circuit Court of the
+City of St. Louis.
+On December 20, 1963, under a writ
+of habeas corpus, appellant was again
+brought before the United States Distriet Court and, pursuant to the verdiet
+of guilty returned against him on No-
+vember 5, 1963, the court sentenced him
+to two and one-half years imprisonment.
+He was then returned to the custody
+of the State of Missouri and, on February 3, 1964, pursuant to the guilty verdiet in the Circuit Court of the City of
+St. Louis on the charge of "uttering a
+forged instrument", appellant was sentenced to eight years imprisonment to the
+Missouri State Department of Correc-
+He was also sentenced to a concurrent term of eight years • imprisonment on his plea of guilty to the earlier
+charge of "first degree robbery". Appellant is now in the process of serving
+these terms at the Missouri State Pen-
+Dr. Andrew C. IVY, Plaintiff-Appellant,
+Nicholas KATZENBACH, Attorney Genazal of the United States, and Edward
+Hanrahan, United States Attorney
+for the Northern District of Illinois, De-
+fendants-Appellees.
+No. 15094.
+United States Court of Appeals
+Seventh Circuit.
+Sept. 22, 1965.
+Certiorari Denied Dec. 13, 1965.
+Physician, who had promoted drug
+used in treatment of cancer, and who had
+been charged with certain offenses by indietment because of his promotion of
+drug, brought suit against the Attorney
+General and the United States Attorney
+for the Northern District of Illinois to
+enjoin them from proceeding against him
+in the criminal case and for appointment
+of impartial medical commission to make
+a court supervised clinical test of the
+efficacy of the drug in the treatment of
+cancer. The United States District Court
+[1] A § 2255 motion is not available
+to attack a mented to shive a lion I
+263 F.2d 395 (10 Cir.
+870 (sC. 005), In Seats 0 24)
+States, 358 U.S. 415, 79 S.Ct. 451, 3
+L.Ed.2d 407 (1959), the Supreme Court
+stated that:
+"Section 2255 is available
+only to attack a sentence under which a
+prisoner is in custody." Id. at 418, 79
+for the Northern District of Illinois,
+Eastern Division, Bernard M. Decker, J.,
+entered judgment adverse to the physician, and the physician appealed. The
+United States Court of Appeals, Castle,
+Circuit Judge, held that trial of the criminal case prior to an impartial clinical
+test of the efficacy of the drug in the
+treatment of cancer would not violate the
+5th and 6th Amendment rights to a fair
+trial and due process of law on ground
+that resolution of the efficacy issue involved matter beyond the intelligence
+[2] Appellant's § 2255 motion is preand comprehension of the jury.
+He is presently serving, in the
+Judgment affirmed.
+*entouri State Penitentiary, the concur 1. Constitutional Law e-268
+rent eight year sentences imposed by the
+Federal Civil Procedure >1951
+Circuit Court of the City of St. Louis. Injunction 105(1)
+He will not begin to serve the two and
+Prosecution of physician, who had
+one-half year sentence imposed by the promoted drug used in treatment of can-
+Federal District Court, which he attacks
+cer, prior to impartial clinical test of effiin this § 2255 proceeding, until he has
+cacy of drug would not violate physician's
+finished service of the State terms.
+5th and 6th Amendment rights to fair
+trial and due process of law, and physi-
+The order appealed from is affirmed.
+cian was not entitled to injunction to en-
+
+
+IVY | KATZENBAOR
+33
+Cite as 351 F.2d 32 (1905)
+join Attorney General and United States
+The prosecution sought to be restrained
+Attorney from proceeding against him in
+involves an indictment charging Dr. Ivy,
+criminal case and appointment of impartogether with three individual and one
+tial medical commission to make court
+corporate co-defendants, with conspiracy
+supervised clinical test of efficacy of
+in violation of 18 U.S.C.A. § 371. Dr. Ivy
+drug. 18 U.S.C.A. §§ 871, 1001, 1841;
+is named in additional substantive counts,
+Federal Food, Drug, and Cosmetic Act, §
+alleged to be overt acts in furtherance of
+1 et seq, 21 U.S.C.A. § 301 et segthe conspiracy, which charge violations of
+18 U.S.C.A. § 1001 (filing false informa-
+2. Injunction §-105(1)
+tion with agencies of the government),
+Mere complexity of factual issues to
+violations of 18 U.S.C.A. § 1341 (use of
+be determined by jury in criminal case is
+the mails in furtherance of a scheme to
+not constitutional basis for precluding
+defraud), and violations of the Federal
+trial of criminal case by injunction.
+Food, Drug, and Cosmetic Act (21 U.S.
+C.A. § 301 et seq.).
+Plaintiff's complaint alleges in sub-
+Melvin L. Klafter, Leonard R. Hartenfeld, Chicago, Ill, for appellant.
+Edward 1. Hanrahan, U. S. Atty., John
+Peter Lulinski, Thomas W. James, Asst.
+U. S. Attys., Chicago, Ill., William W.
+Goodrich, Asst. Gen. Counsel, Joanne S.
+Sisk. Atty, Dept. of Health, Education,
+and Welfare, Washington, D. C., for apstance that plaintiff is a medical scientist
+of outstanding reputation who has been
+engaged, since approximately 1950, in experimental studies on the drug Krebiozen; his study and the reports of physicians submitted to him have demonstrated
+to his satisfaction that Krebiozen has
+produced favorable results as an anticancer agent and is useful in alleviating
+the pain usually present in terminal
+Before CASTLE, KILEY, and SWY-
+GERT, Circuit Judges,
+cases: plaintiff, as scientific adviser to
+the Krebiozen Research Foundation, has
+never received any remuneration for his
+CASTLE, Circuit Judge.
+advice, and has never submitted any applications to the United States with the
+The plaintiff-appellant, Dr. Andrew C.
+object of becoming a sponsor or manu-
+Ivy, brought suit in the District Court
+facturer of the drug; he has a mandate
+agairist Nicholas Katzenbach, Attorney
+from the Illinois legislature to conduet
+General of the United States, and Edward
+research and investigation on Krebiozen;
+Hanrahan, United States Attorney for
+the gist of the indictment against him is
+the Northern District of Illinois, the defendants-appellees,
+that Krebiozen is a fake cancer drug: the
+indictment is based upon reports of the
+them from proceeding against him in a
+National Cancer Institute and the Food
+pending criminal cause and for the apand Drug Administration which are erpointment of an impartial medical comroneous; the only way to prove whether
+mission to make a court supervised clini-
+Krebiozen is an effective treatment for
+cal test of the efficacy of the drug Krecancer is by clinical test which no Federal
+biozen in the treatment of cancer. Plaintiff's complaint was filed subsequent to
+agency has undertaken; the Secretary of
+Health, Education, and Welfare by perthe return of the indictment, but prior
+to the commencement of the eriminal
+sisting in the view that Krebiozen is a
+trial.* Defendants' motion to dismiss
+fake, by refusing to acknowledge that
+on the ground that the complaint does
+there is a difference of opinion about the
+not state a claim on which relief can be
+drug's merits, and by refusing to conduct
+granted was allowed and the action was
+a clinical test, has caused the disseminadismissed. Plaintiff appealed.
+tion of adverse publicity and is acting
+I. At the time of the preparation of this opinion the criminal trial was still in progress.
+351 F.2d-3
+
+
+351 FEDERAL REPORTER, 24 SERIES
+arbitrarily and far beyond the exercise of
+edent for the making of such imputation
+administrative prerogative.
+is wholly inapposite.
+through his agents, discouraged physicians from prescribing Krebiozen by im-
+[1] We are unpersuaded by the plainplied threats of reprisal by medical astiff's contention that a trial prior to an
+sociations or the government, and has
+impartial clinical test of the efficacy of
+attempted to discourage patients from
+Krebiozen in the treatment of cancer
+using the drug;
+this conduct of the
+would violate his 5th and 6th Amendment
+Secretary has caused Ivy to lose prestige
+rights to a "fair trial" and "due process
+as a professional man, and his rights to
+of law" for the reason that resolution of
+practice medicine,
+to conduct research,
+the efficacy issue presented by some of
+and to teach and advocate ideas have been
+the counts of the indictment involves matinfringed; plaintiff has a legal and moral
+ter beyond the intelligence and compreright to use any drug he regards as safe
+hension of a jury and the complaint thus
+in treating cancer patients and is compresents a basis for the injunctive relief
+pelled to continue to use Krebiozen, which
+sought. In this connection the memorancan only result in a multiplicity of civil
+dum opinion filed by the distriet judge
+and criminal actions; only a court of
+discerningly and aptly points out:
+equity, and not a jury, can intelligently
+"Plaintiff's constitutional rights to a
+determine whether Krebiozen is a fake
+fair trial will be protected by the
+cancer drug and this determination can
+court in the criminal trial. Juries
+only be made after a court supervised
+are called every day to determine
+clinical test; and that to require plaintiff
+problems which are not within the
+to defend himself in the criminal trial
+scope of their prior knowledge and
+without a prior clinieal test of the drug
+experience; in these cases, the exwill deprive him of que process of law.
+pert witness is used to bridge the gap
+The complaint asserts that the acts comthe known and the unplained of violate rights guaranteed to the
+known. Expert witnesses in crimiplaintiff by the 1st, 5th and 6th Amendnal trials are commonplace;
+ments to the Constitution of the United
+mere fact that the issues of a case
+may be complex or confusing to a
+jury does not mean that they must
+The complaint does not challenge the
+constitutional validity of any of the statutes the indictment charges the plaintiff
+with violating nor is any allegation made
+that either of the defendants sought to be
+restrained is acting other than within the
+discretionary scope of his duties concerning enforcement of the lawg. Apart from
+the question of the sufficiency of any of
+the factual allegations made with respect
+to the actions and conduct of the Secretary of Health, Education, and Welfare
+to present an issue involving the infringement of any constitutional right of the
+plaintiff, we perceive no basis either from
+the averments of the complaint or the applicable law for imputing to the defendants the alleged conduct of the Secretary.
+And, plaintiff's reliance upon Philadelphia Co Sa. 890. 22a controline prec
+•Ed. 570 as a controlling precremain so—the prosecution must
+clarify the facts in order to present its charges properly.
+complexity of the subject matter of a
+lawsuit cannot be raised to a constitutional issue in advance of its presentation in that lawsuit."
+[2] Mere complexity of factual issues
+to be determined by the jury in a criminal
+case is not a constitutional basis for precluding the trial.
+We agree with the District Court that,
+contrary to the contentions of the plain
+tiff, the allegations of the complaint d
+not present one of those rare instances
+and Ex parte Young, 209 U.S. 123, 28 S
+Ct. 441, 52 L.Ed. 714, require that cquit,
+
+
+I. L. R. B. LO. L. FRANK, INO.
+35
+Cite as 351 F.24 35 (1985)
+should intervene to restrain a pending
+Labor Relations 389
+the rationate of Douglas City of Cant
+Employer's general manager's request that employees caucus and inform
+nette, 319 U.S. 157, 63 S.Ct. 877, 87 L. Ed.
+him of result was reasonable method
+1824, is applicable here, and in the lanof verifying one employee's statement.
+guage of Dombrowski (880 U.S. p. 485,
+that employees had changed their minds
+85 S.Ct. p. 1120) there are "no special
+about union representation; and, in concircumstances to warrant cutting short
+text, manager's statement to assembled
+the normal adjudication of constitutional
+employees with regard to scheduled indefenses in the course of a criminal
+crease in wages and his designation of
+prosecution."
+supervisor desired by employees were, if
+The judgment order appealed from is
+technical violations, so de minimis in naaffirmed.
+ture as to afford no reasonable basis for
+board's conclusion that they resulted in
+Affirmed.
+dissipation of union's majority.
+Na-
+tional Labor Relations Act, § 8(a) (1, 5)
+as amended 29 U.S.C.A. § 158(a) (1, 5).
+NATIONAL LABOR RELATIONS
+BOARD, Petitioner,
+C. L. FRANK, INC., Respondent.
+No. 15054.
+United States Court of Appeals
+Seventh Circuit.
+Sept. 27, 1965.
+Marcel Mallet-Prevost,
+Asst. Gen.
+Counsel, Gary Green, Atty., N. L. R. B.,
+Arnold Ordman, Gen. Counsel, Dominick
+L. Manoli, Associate Gen. Counsel, Leo
+N. McGuire, Atty,, N. I. R. B., Washington, D. C., for petitioner.
+D. Bailey Merrill, William E. Statham,
+Evansville, Ind., for respondent C. L:
+Frank, Inc., Merrill, Schroeder & Johnson, McCray, Clark, Statham & McCray,
+Evansville, Ind., of counsel.
+Before SCHNACKENBERG, CASTLE
+and KILEY, Circuit Judges.
+Proceedings on petition for enforcement of an order of the National Labor
+Relations Board. The Court of Appeals,
+CASTLE, Cireuit Judge.
+Castle, Circuit Judge, held that employ-
+This case is before the Court upon the
+er's general manager's request that empetition of the National Labor Relations.
+ployees caucus and inform him of result
+Board for enforcement of the Board's
+was reasonable method of verifying one
+order issued against C. L. Frank, Inc.,
+employee's statement that employees had
+respondent. The order is based on the
+changed their minds about union repre-
+Board's findings and conclusions that the
+sentation; and, in context, manager's
+Company violated Section 8(a) (5) and!
+statement to assembled employees with
+(1) of the National Labor Relations Act
+regard to scheduled increase in wages
+by refusal to bargain with the Union
+and his designation of supervisor deand that such refusal was not based on
+sired by employees were, if technical vioany good faith doubt that the Union
+lations, so de minimis in nature as to
+represented a majority of the employees:
+afford no reasonable basis for board's
+involved; and that the Company vioconclusion that they resulted in dissipalated Section 8(a) (1) of the Act by
+tion of union's majority.
+directing employees to conduct a poll with:
+Order accordingly.
+respect to the authorization of the Union:
+I. Chunuffeurs, Teamsters and Helpers Local
+Union 215, a/w International Brotlerhood of Teamsters, Clauffeurs, Warehousemen and Helpers of Amerien
+
+
+165
+Cite n$ 252 F.2d 165 (19C0)
+occasion it split up a team working on
+tion for return of books and records.
+one job to send one member of the team
+The Court of Appeals, Friendly, Cireuit
+to another job, a practice as to which
+Judge, held that where judge signed an
+there is no evidence whatever in the case
+ex parte order requiring United States
+Moreover, in the latter case it
+attorney to show cause why taxpayer
+was found that in the event extra work
+should not be entitled to return of recturned up in the course of a job the apords or papers voluntarily turned over to
+plicator was not allowed to contract to
+agents of Internal Revenue Service and
+do it for the householder on his own acstaying United States attorney and all
+count, as in the case at bar, but was reother agents and representatives from
+quired to ask the taxpayer-plaintiff for
+submitting any evidence or information
+instructions as to how to proceed. These
+to grand jury pending determination of
+facts, and others we might mention, difapplication for order to suppress, and
+ferentiate the Security Roofing case from
+subsequently court signed order, second
+order was not final and was not appeal-
+The case at bar is consistent with the
+Metropolitan Roofing, Jagolinzer and
+American Homes cases cited above and
+not inconsistent with Security Roofing.
+A judgment will be entered affirming
+the judgment of the District Court.
+able as an interlocutory order refusing to
+dissolve or modify injunction.
+Appeal dismissed for want of appellate jurisdiction.
+Moore, Cireuit Judge, dissented.
+1. Courts C=405(3.11)
+In a civil action a restraining order
+qua restraining order is not appealable,
+whereas a preliminary injunetion is. 26
+U.S.C.A. (I.R.C.1939) § 6531.
+2. Courts e=405(3.11)
+Label put on order by trial court is
+not decisive whether order constitutes a
+Luther F. GRANT and Sirrka | Grant,
+Petitioners-Appellees,
+restraining order or preliminary injunetion within rule that restraining order
+qua restraining order is not appealable
+UNITED STATES of America,
+Defendant Appellant.
+No. 344, Docket 26183.
+whereas a preliminary injunction is, but
+rather the courts look to such factors as
+furation of order, whether it was issued
+after notice and hearing, and type o!
+United States Court of Appeals
+Second Circuit.
+Argued May 12, 1960.
+Decided July 28, 1960.
+showing made in obtaining order.
+3. Courts C=405(12.1, 12.12)
+Where court signed ex parte order
+requiring United States attorney to show
+cause why records taxpayer had made
+available to agents of internal revenue
+Appeal by United States from order service should not be suppressed and
+of the Distriet Court for the Northern staying United States attorney and all
+District of New York, James T. Foley, other agents and representatives from
+J., 186 F.Supp. 418, refusing to dissolve submitting any evidence or information
+order staying United States attorney to grand jury pending determination of
+and all other agents and representatives application,
+and subsequently court
+of the United States from submitting
+signed order refusing to dissolve stay
+evidence relating to taxpayers to a grand
+and reserving decision as to vacation
+jury pending determination of applica- of original order to show cause until
+
+
+166
+hearing, second order was not final and
+Kenneth P. Ray, Asst. U. S. Atty..
+was not appealable as an interlocutory Syracuse, N. Y. (Theodore F. Bowes,
+order refusing to dissolve or modify in- U.S. Atty., Northern Dist. of New York,
+junctions. 28 U.S.C.A. §5 1291, 1292(a)
+Syracuse, New York, on the brief), for
+(1): Fed.Rules Civ.Proc. rule 65(b). 28
+4. Injunction C-105(1)
+District judges do not have unlimited discretion to stay government or
+its agents from presenting evidence to
+grand jury pending a hearing on motion
+to suppress evidence and evidentiary
+hearing should not be set as a matter of
+course but only when petition alleges
+facts which if proved would require
+Fed.Rules Crim. Proc.
+rule 41(e), 18 U.S.C.A.
+5. Searches and Seizures C-7(28)
+Taxpayers do not make a showing
+of violation of constitutional guarantees
+by alleging only that they turned over
+their books and records voluntarily to
+Treasury agents|
+for examination
+such books and records were found to
+contain evidence leading government to
+6. Criminal Law C-391.6(5)
+In those cases where an evidentiary
+hearing is required on application for
+order to suppress evidence, court should
+proceed in an
+expeditous manner
+sonant with summary character of rem-
+Fed.Rules Crim.Proc. rule 41(e),
+Possible expiration of a period of
+limitations is highly relevant to the exercise of court's discretion in staying gorernment or its agents from presenting
+evidence to grand jury pending hearing
+on motion to supress such evidence.
+Fed.Rules Crim.Proc. rule 41(e), 18 U.S.
+Abuses of discretion by trial court
+in ordering a hearing on motion to suppress evidence or in the scope or duration of a stay pending such hearing can
+be corrected by Courts of Appeals
+through issuance of mandamus
+tules Crim.Proc. rule 41(e), 18 U.S.C.A
+Joseph W. Burns, New York City
+(John P. Cuddahy and Austin, Burns,
+Appell & Smith, New York City, and
+George Bond, Jr., N. Earle Evans, Jr.
+and Bond, Schoeneck & King. Syracuse,
+New York, on the brief), for appellees.
+Before CLARK,
+MOORE and
+FRIENDLY, Circuit Judges.
+FRIENDLY, Circuit Judge.
+Luther F. Grant and his wife Sirrka
+Grant are physicians practicing in
+Liberty, New York. Luther applied on
+their joint behalf to the Distriet Court
+for the Northern District of New York,
+pursuant to Fed.R.Crim. Proc. 41(e), 18
+U.S.C., for an order suppressing as evidence records and papers that he had
+made arailable to agents of the Internal
+Revenue Service.
+He alleged that the
+records had been obtained in violation of
+the Fourth and Fifth Amendments and
+that the United States attorney was
+about to present to a grand jury information relating to petitioners' tax liability derived from them.
+Upon this application, Judge Foley.
+sitting in Albany, signed an ex parte
+order dated February 26, 1960, requiring
+the United States attorney to show cause
+on the judge's next scheduled motion day
+at Albany, March 21, 1960, why petitioners should not be granted the relief
+The order stayed the United
+States attorney and all other agents and
+representatives of the United States
+"from submitting any evidence or information to a Grand Jury or from taking
+any other or further proceedings in relation to the above captioned petitioners
+pending the determination of this appli-
+* * *". At the same time
+the judge signed an order, also ex parte,
+granting petitioners leave under Fed.R.
+Civ.Proc. 26(a), 28 U.S.C., to serve notice of the taking of depositions of four
+revenue agents prior to the expiration
+
+
+GRANT | UNITED STATES
+167
+Cite as 282 F.24 105 (1000)
+of 20 days after the commencement of
+under 28 U.S.C. § 1291. However, the
+the action on the ground "that their order of February 26 contained language
+testimony is desired for use at the hear- of restraint, and we must consider
+ing of petitioners' motion to suppress illewhether the order of March 8 is an intergal evidence *
+*and that it is
+locutory order "refusing to dissolve or
+essential that their testimony be taken
+modify injunctions" and therefore apprior to such hearing." Pursuant to
+pealable within 28 U.S.C. § 1292(a) (1).
+such leave petitioners served notice that
+the depositions would be taken on March
+[1,2] If appealability were governed
+8, 1960 and a subpoena commanding a
+by 28 U.S.C. § 1292(a)(1), we would be
+special agent to bring copies of the manrequired to determine whether the Febuals and instruction to revenue agents
+ruary 26 order was a temporary restrainand special agents, "all documents,
+ing order or a preliminary injunction.
+papers, books, records, memoranda, re-
+For "In a civil action a restraining order
+ports, diaries and objects maintained or
+qua restraining order is non-appealable,"
+obtained" by two agents, and "copies or
+7 Moore, Federal Practice, f 65.07,
+extracts of books and papers made
+1049 (2d ed. 1955): Schainmann |
+them as a result of examinations or in-
+Brainard, 9 Cir., 1925, 8 F.2d 11, where
+vestigations" relating to the tax affairs
+as a preliminary injunction is.
+of the petitioners.
+"the label put on the order by the
+trial court is not decisive; instead the
+When Judge Foley arrived in Syracuse
+courts look to such factors as the duraon March 1,
+1960, to commence a trial
+tion of the order, whether it was issued
+term, an assistant United States attorafter notice and hearing,
+and the type
+ney asked him to vacate the order of Febof showing made in obtaining the order."
+ruary 26. The judge declined to do this
+3 Barron & Holtzoff, Federal Practice
+but signed an order, supported by affiand Procedure, § 1440, at 509 (Wright
+davits of the United States attorney and
+ed. 1958).
+The authors aptly add, "Ap-
+two revenue agents, requiring the petiplication of these tests is not easy to
+tioners to show cause on March 7 "why
+Fed.R.Civ.Proc. 65(b)
+an order should not be made dissolving
+vides that any temporary restraining
+the injunetion and vacating the order to
+order granted without notice
+show cause granted by this Court on the
+pire by its terms within such time after
+26th day of February 1960." Petitioners
+entry, not to exceed 10 days, as the court
+submitted answering affidavits on the
+fixes, unless within the time so fixed the
+return day.
+After considering the afforder, for good enuse shown, is extended
+davits and hearing counsel, Judge Foley,
+for a like period
+on March 8, 1960, made a Memorandum-
+Greene, 3 Cir., 1947, 160 F.2d 512, held
+Decision and Order, 186 F.Supp. 418, rethat an order originally issued on De-
+fusing to dissolve
+the stay (although
+modifying it to permit the institution
+cember 2, 1946, extended on December 20
+of a complaint before a United States
+without objection until January 14, 1947,
+Commissioner under 6531 of the Interand thereafter continued from time to
+nal Revenue Code of 1954, 26 U.S.C. §
+time until February 3, during which
+time a long evidentiary hearing was held,
+6531, to toll the statute of limitations)
+and reserving decision as to vacating
+had ceased to be a temporary restrainthe original order to show cause until
+ing order and had become a preliminary
+injunction subject to appeal under what
+the hearing. From this the United
+States appeals.
+is now 28 U.S.C. § 1292(a)(1). On the
+other hand, Connell || Dulien Steel Prod-
+We meet at the outset the question, not
+ucts, Inc., 5 Cir., 1957, 240 F.2d 414, 415,
+discussed by the parties, whether the orcertiorari denied, 1958, 356 U.S. 968, 78
+der is appealable. Manifestly the order
+S.Ct. 1008, 2 L.Ed.2d 1074, held that an
+was not final; hence it is not appealable
+order labelled a "temporary restraining
+
+
+order" did not cease to be one because it property and to suppress for use as evirestrained pending decision on a motion
+dence anything so obtained" on various
+for a preliminary injunction which was
+grounds therein specified. It directs that
+scheduled to be heard 28 days thence, see
+"The judge shall receive evidence on any
+71 Harv.L.Rev. 550 (195S).
+issue of fact necessary to the decision of
+Third Circuit has decided similarly with
+the motion." The rule embodies a pracrespect to a stay that was to remain in
+tice which long antedated it but whose
+effect until the application for the temjurisdictional character, at least in those
+porary injunction was heard, when the
+cases where the motion precedes the crimappeal was taken prior to the expirainal proceeding to which the evidence
+ruck Ass'n Port of Philadelphi
+has been little discussed. We
+have said that such a motion "was in
+Marine Terminal Ass'n, 1960, 276 F.2d
+effect a complaint initiating a civil ac-
+Here the minimum period of retion," Lapides v. United States, 2 Cir..
+straint was 24 days, only four more than
+1954, 215 F.2d 253, 254: Russo v. United
+the 20 permitted by Rule 65(b), a period
+States, 2 Cir., 241 F.2d 285, 287, certiothat might have been accepted by consent
+rari denied, 1057, 355 U.S. 816, 78 S.Ct.
+under the express terms of the rule or
+18, 2 L.Ed.2d 33, and so it is in the sense
+would undoubtedly have been shortened
+with which the Court was there mainly
+had the court been requested to do so:
+concerned, namely, its independence from
+the order was issued without notice and
+the later criminal proceeding and the conhearing: and the judge had not made the
+sequent appealability of a final order
+preliminary determination of the rights
+therein under 28 U.S.C. § 1291. Howof the parties required for issuance of a
+the jurisdictional grants in 28
+temporary injunction.
+On the other
+U.S.C. §S 1331-1358 will be searched in
+hand, as demonstrated by the order pervain for any rubrie under which such a
+mitting petitioners to take depositions,
+motion falls, in the absence of any allethe hearing scheduled for March 21 was
+of jurisdictional amount that
+evidently intended to be the final hearing.
+would bring it under § 1331, see Censo that the stay may be said to have
+tracchio v. Garrity, 1 Cir., 1952, 198 F.2d
+performed the traditional office of an
+385, certiorari denied, 1952, 34-1
+injunction pendente lite, "to preserve the
+U.S. 866, 73 S.Ct. 108, 97 L.Ed. 672.
+status quo pending final determination
+The classical exposition of the nature of
+of the action after a full hearing."
+such a motion is Judge
+Hourh's state-
+Moore, Federal Practice, 1 65.04, at 1625
+ment in United States Maresca, D.C.
+S.D.N.Y.1920, 26G F. 713, 717:
+The difficulty in resolving these conflicting considerations suggests that we
+may not be asking the right question and
+that we ought examine a more basic one,
+namely, whether 28 U.S.C. § 1292(a) (1)
+applies at all to preliminary stays in
+summary proceedings to suppress illegally
+obtained evidence. This in turn requires
+analysis of the nature of a motion to that
+end nade before any criminal proceeding
+is pending.
+Fed.R.Crim.Proc. 41(e) provides that
+"A person aggrieved by an unlawful
+search and seizure may more the district
+court for the district in which the property was seized for the return of the
+'Whenever an officer of the court
+has in his possession or under his
+control books or papers, or (by parity
+of reasoning) any other articles in
+which the court has official interest,
+and of which any person (whether
+party to a pending litigation or not)
+has been unlawfully deprived, that
+person may petition the court for
+restitution. This I take to be an elementary principle, depending upon
+the inherent disciplinary power of
+any court of record.
+"Attorneys are officers of the
+urt, and the United States attorne
+es not by taking office escape fro
+
+
+169
+Cite ns 282 F.2d 105 (1000)
+this species of professional disciand papers claimed to have been unlawpline.
+Thus power to entertain this
+fully taken until the court can determine
+motion depends on the fact that the
+his right to use them, is an order "grant
+party proceeded against is an attoring, continuing, modifying, refusing or
+ney, not that he is an official known
+dissolving injunctions, or refusing to disas the United States attorney.
+It
+solve or modify injunctions" within 28
+is further true that the right to move
+U.S.C. § 1292(a) (1), even if the stay
+does not at all depend on the existruns beyond the 20-day period permitted
+ence of this indictment; it might be
+for temporary restraining orders by
+made, were no prosecution pending."
+Fed.R.Civ.Proc. 65(b) and we should as-
+See also Go-Bart Importing Co. v. United
+sume that the Rule is fully applicabie.'
+States, 1931, 282 U.S. 344, 355, 51 S.Ct.
+Section 1292(a) (1) stems from § 7 of
+153, 75 L.Ed. 374; Foley v. United States,
+the Evarts Act, c. 517, 26 Stat. 828,
+5 Cir., 64 F.2d 1, 3, certiorari denied,
+providing, by way of exception to the re-
+1933, 289 U.S. 762, 53 S.Ct. 796, 77 L.Ed.
+quirement of finality, "That where, upon
+a hearing in equity in a district court
+or in an existing circuit court, an injune-
+When motions under Rule 41(e) or the
+tion shall be granted or continued by an
+practice preceding it are independent of
+interlocutory order or decree, in a cause
+a criminal proceeding, the courts enterin which an appeal from a final decree
+the return of papers, Perimens Chitca
+tain appeals from final orders.
+may be taken under the provisions of
+this act to the circuit court of appeals,
+States, 1918, 247 U.S. T, 38
+62 L.Ed. 950; Essgee Co. | United
+an appeal may be taken from such interlocutory order or decree granting or con-
+States, 1923, 262 U.S. 151, 43
+tinuing such injunction to the circuit
+67 L.Ed. 917; Go-Bart Co. | United
+court of appeals"; orders denying such
+States, supra, or granting such return
+injunctions were first added in 1895, e.
+• McDowell, 1921, 256 U.S. 465,
+14, 65 L.Ed. 1048. In contrast.
+peared in the Judicial Code of 1911, §
+when the motion is made afte
+States, either its denial, Cogen f United
+129, 36 Stat. 1134, continued to be prefaced by the words "Where upon a hear-
+States, 1929, 278 U.S. 221, 49 S.Ct. 11
+ing in equity in a district court," and
+73 L.Ed. 275, nor its grant, Carroll
+the omission of the words "in equity" in
+United States, 1037, 354 U.S. 397,
+the Act of February 13, 1925, 43 Stat.
+S.Ct. 1332, 1 L.E-.2d 1442, is appealable.
+We have found 1.o case sustaining appellimitations of chenan to rema thatlate jurisdietion from any order in such
+a proceeding save a final one.
+burg American Line, 1935, 294 U.S. 454,
+457, In. 3, 55 S.Ct. 475, 471, 79 LE
+We do not think an order, made in the
+989; see Baltimore Contractors, Inc.
+exercise of "the inherent disciplinary
+Bodinger, 1955, 348 U.S. 176, 180, fn. 6,
+power" of the court, directing one of its
+75 S.Ct. 249, 99 L.Ed. 233. Whatever
+own officers to refrain from using books
+might be the case when a person seeking
+Rubber Co. v. N.L.R.B., G Cir., 1941, 122
+F.24 450, 451, 136 A.L.R. 8S3.
+
+
+the return of property alleged to have
+been illegally seized proceeds by a pleary action under an appropriate jurisnctional statute, see Goodman • Lan
+8 Cir., 1931, 48 F.2d 32; cf. Eastus 1-
+Bradshaw, 5 Cir., 94 F.2d 788, certiorari
+denied, 1938, 304 U.S. 576, 58 S.Ct. 1045,
+82 LEd. 1539, such language is hardly
+apt to describe a preliminary step in a
+special proceeding where, in the course
+of exercising its "disciplinary powers"
+"summarily to determine" what one of
+its own officers should do, Go-Bart Co.
+United States, supra, 282 U.S. at page
+355, 51 S.Ct. at page 157 the court instruets him, ex parte, not to take action
+pending the determination that might
+impair the court's ability
+to grant full
+Such a proceeding normally
+would not have the three
+stages-temporary restraining order,
+injunction, and final decree
+tie of "a hearing in equity"; the first
+evidentiary hearing would usually be the
+last and the proceeding would generally
+be determined before an appeal from an
+interlocutory order could be heard.
+The Baltimore Contractors case itself
+teaches that not every request for an
+order containing words of restraint is
+one for an injunction within $ 1292(a)
+_ Phillips, 2 Cir.,
+264 F.2d 515, 516,
+359 U.S. 1002, 79 S.Ct. 1139, 3
+L.Ed.2d 1030, where we said, also dealing with officers of the court, that "the
+prayers for injunctive relief add nothing
+to the orders denying the motions and
+render neither of them automatically apealable under 28 U.S.C. § 1292(a)(1).
+nd United States • Rosenwasser,
+Cir., 1944, 145 F.2d 1015, 156 ALR
+1200, held that an order suppressing evidence and restraining the United States
+from using copies of the seized records
+or information derived therefrom in any
+proceeding of any kind, which was not
+appealable as final because it was sought
+only after the information had been filed,
+could not be appealed as an interlocutory
+order granting an injunction although
+literally it assuredly was.
+[3-8] Our holding that the order
+here sought to be reviewed is not appealable does not mean that district judges
+have unlimited discretion to stay the
+government or its agents from presenting evidence to a grand jury pending a
+hearing on a motion to suppress. Fed.R.
+Crim.Proc. 41(e) requires that evidence
+be taken on "any issue of fact necessary
+to the decision of the motion." It follows
+that evidentiary hearings should not be
+set as a matter of course, but only when
+the petition alleges facts which if proved
+would require the grant of relief.
+find it somewhat hard to see how the petition here met this test, since the constitutional guarantees are not violated
+when taxpayers' books and records, voluntarily turned over to Treasury agents
+for examination, are found to contain
+evidence leading the government to assert criminal liability, Russo
+States, supra; United States | Sclafani,
+2 Cir., 265 F.2d 408, certiorari denied
+1959, 360 U.S. 918, 79 S.Ct. 1436, 3 L.Ed.
+2d 1534: Centracchio || Garrity, supra;
+the fact that one of the agents was a
+special agent (whose presence, petitioners allege, shows an intent to develop
+facts leading to criminal prosecution)
+has been held irrelevant, Turner | United States, 4 Cir., 222 F.2d 926, 930, certiorari denied 1955, 350 U.S. 831, 76
+S.Ct. 65, 100 L.Ed. 742; and the only
+affirmative misrepresentation alleged as
+to the nature of the investigation postdated the voluntary delivery of the rec-
+In those cases where an evidentiary hearing
+required, the court
+should proceed in an expeditious manner
+consonant with the summary character
+of the remedy and with a recognition
+that "It is no less important to safeguard
+against undue interruption the inquiry
+instituted by a grand jury than to protect from delay the progress of the trial
+after an indictment has been found."
+Cobbledick 1 United States, 1940, 309
+U.S. 323, 321, 60 S.Ct. 540, 542, 84 L.Ed.
+783. The possible expiration of a period of limitations is, of course, highly
+relevant to the exercise of the court's
+discretion. Abuses of discretion in or-
+
+
+171
+dering a hearing or in the scope or dura- without
+The order
+tion of a stay can be corrected by courts
+sought "to initiate this special proceedof appeals through the issuance of maning." It was issued er parte on Febru-
+6 Moore, Federal Practice, f
+ary 26, 1960 and enjoined the govern-
+54.10 [4], at 87 (2d ed. 1955).
+ment from submitting any evidence (resuch relief, see Zamore I Goldblatt, 2
+gardless of any relationship whatsoever
+to the material sought to be suppressed)
+Cir., 1953, 201 F.2d 738, the stay was to
+pending the determination of the applicacontinue only until the next motion day
+tion. Since the return date was March
+of the court in Albany, and the issue
+21, 1960, the minimum period of injunewould doubtless have been settled long
+tion was 24 days, The date of entry of
+ago if the government had complied with
+an order after decision could have exthe order to show cause instead of taking
+tended this period substantially.
+this appeal.
+Simultaneously a motion was made.
+The appeal is dismissed for lack of apalso without notice for an order pursuant
+pellate jurisdiction.
+to Rule 26(a) of the Federal Rules of
+Civil Procedure, for leave to serve notice
+MOORE, Circuit Judge (dissenting).
+of taking depositions of various govern-
+This appeal tests the regularity of the
+ment agents prior to the expiration of
+proceedings instituted by the taxpayers
+20 days after the commencement of "this
+(referred to as "the taxpayer") to en-
+The affidavit supporting this
+join the United States Attorney from
+ex parte "civil procedure" motion recites
+submitting to a Grand Jury any evidence
+that "this action" is the order to show
+of any crime whatsoever, or taking any
+cause under the "criminal procedure"
+other proceedings, against them.
+rule. Again without notice this motion
+injunction thus has the effect of enjoining pro tanto the Grand Jury in its time-
+On March 4, 1960, the court issued a
+honored function of investigating crime.
+further order to show cause
+The reason asserted in the petition suporder should not be made dissolving the
+porting this drastie request is in subinjunction" and vacating the first order
+stance, that, although "petitioner, either
+of February 26th. On March 8th the
+personally or through employees in his
+court concluded that a hearing should be
+office, did make available to
+held and reserved decision on the motion
+ternal Revenue] agents all of his books,
+to dissolve the injunction until the hearrecords and papers and those of his wife,
+ing had been held. From the order of
+including among others, daily log books,
+March 8th the government appeals.
+check books,
+books, cancelled checks, stock records,
+In summary, an order to show cause.
+books and papers," that he did not do so
+at best a motion under section 41(e) of
+"for purposes of any criminal investigathe criminal rules—containing a "without notice" injunction of 24 days or more
+The taxpayer sought a return of these
+simultaneously with its issuance is metapapers and an injunetion against their
+morphosized into a civil "action" on the
+use (and leads therefrom) by an order
+basis of which another "without notice"
+to show cause pursuant to Rule 41(e) of
+order for leave to take depositions under
+the Federal Rules of Criminal Procedure.
+section 26(a) of the civil rules is issued.
+This Rule permits a person "aggrieved
+Under what authority of law is this
+by an unlawful search and seizure" to
+baffling procedure conducted? Certainly
+move the district court for the return of
+some legal justification must be found
+the property and its suppression as evibefore approving the steps here taken.
+dence. Of the grounds specified in the
+Despite the fact that no jurisdictional
+Rule the only one possibly applicable is
+sanction is given in any of the grants
+that "the property was illegally seized
+specified in 28 U.S.C.A. §9 1331-1358, as
+
+
+172
+pointed out in Centracchio | Garrity, 1 is restricted and by the words "shall ex-
+Cir., 1952, 198 F.2d 382, at page 385:
+pire" the order became self-terminating
+"it has long been accepted that
+in 10 days, i. e., March 7th. No good
+where evidence, obtained by an uncause for the permissive extension was
+constitutional search and seizure in
+shown nor was any extension granted.
+violation of the Fourth Amendment,
+Therefore even if the injunction had had
+is in the hands of a United States
+any effect under the guise of a temattornes, a federal district court
+porary restraining order between Febmay entertain and grant relief on a
+ruary 26th and March 7th it could conpetition, filed even prior to any intinue thereafter only as a preliminary
+dictment, seeking a return of the
+injunction. The order of March 8th of
+papers or property unconstitutionalnecessity had to be an order "refusing
+ly seized and the suppression of the
+to dissolve" an injunction. The fact that
+same as evidence. (Citing cases)"
+the court's memorandum-decision-order
+This court in Lapides | United States,
+did not use the words "granted" or "de-
+2 Cir., 1954, 215 F.2d 253, at page 254,
+nied" is not determinative. The indescribed a somewhat similar proceeding
+junction was continued by the order
+and hence must be regarded as a refusal
+to dissolve it.
+"Appellant's "motion' was in effect a complaint initiating a civil
+action seeking suppression
+dence said to have been illegally obtained and to restrain the United
+States Attorney from presenting
+such evidence to the grand jury.
+The suit thus began before any
+criminal proceedings by the government against appellant had been instituted, and his appeal was therefore not from an interlocutory order
+entered in the course of a criminal
+Accordingly, the order denying his motion was a final and appealable order."
+If the order to show cause be tantamount to a civil action (and apparently
+the taxpayer would so regard it by seeking to avail himself of the civil deposition rules), then the other civil rules are
+equally applicable. Federal Rules of Civil Procedure 65(b) specifically provides
+that every temporary restraining order
+"shall expire by its terms within such
+time after entry, not to exceed 10 days,
+as the court fixes, unless within the time
+so fixed the order, for good cause shown,
+is extended for a like period or unless the
+party against whom the order is directed
+consents that it may be extended for a
+longer period."
+The language of this Rule is significant. The restraining power of the court
+The entire purpose of the temporary
+restraining order rule would be frustrated if it were allowed to be disregarded
+Ten days was the maximum
+period during which the enjoined party
+was to be restrained without opportunity
+for appellate review.
+Over the years
+courts have become more and more reluctant to enjoin without notice: rules
+and statutes express this policy. The
+right of appeal from a preliminary injunction is a purposeful exception to the
+general rule requiring finality. Since
+"preliminary" by
+"final," the presently imposed restraint
+must be preliminary because the order to
+be entered after any hearing will be final.
+Although I agree that an appeal cannot
+be taken from a temporary restraining
+order this limitation applies only to this
+type of order as authorized by law. The
+very "label" argument advanced by the
+majority cannot create an order which
+had no legal being after March 7th merely by calling it a temporary restraining
+The trial court states that his powers
+of restraint are supported by precedent,
+citing In re Fried, 2 Cir., 161 F.2d 453,
+. A.L.R.2d 996: Application of Bodki
+.C., 165 F.Supp. 25 and Lapideg d
+United States, 2 Cir., 1954, 215 F.2d 253
+
+
+GRANT v. UNITED STATES
+Cite as 282 F.20 165 (1000)
+Upon the appeals by the taxpayers and taxpayer alleges that some time after he
+the government in Bodkin after a stipu- had voluntarily made available his books
+lation by the taxpayers "to grant the he was "shocked" when he was advised
+government all the relief to which it
+that as a result of the investigation crimcould be entitled on a successful appeal" inal proceedings might be instituted.
+the appeal was dismissed as moot. Howthat he had thought, as the agents had
+ever, the district court's judgment was
+represented, that a "routine" examinavacated and the complaint dismissed.
+tion only was being made and that the
+This court specifically referred to our
+agents had never "implied or said that
+disapproval of Bodkin in United
+States Sclafani, 2 Cir., 1959, 265 F.2d
+there was the remotest possibility that
+either fraud or criminal proceedings
+Examining the Bodkin case, a situwere under consideration."
+ation most comparable to the present
+In Selafani it was held that under
+case appears, i. e., a motion to suppress
+quite similar circumstances "the failure
+restrain under Federal Rule of
+to disclose the changing course of the in-
+Criminal Procedure 41(e), depositions
+vestigation is not fraudulent or deceitunder Federal Rule of Civil Procedure
+ful" (265 F.2d 408, 414) and that:
+The same grounds, in substance,
+"A routine' tax investigation
+were advanced, namely, that the original
+voluntary surrender of their books by
+openly commenced as such is devoid
+of stealth or deceit because the
+the taxpayers for tax audit became involuntary when subsequently facts were
+ordinary taxpayer surely knows that
+there is inherent in it a warning
+thereby disclosed indicating criminal liathat the government's agents will
+The hearing must have been in
+pursue evidence of
+the nature of a full-scale trial because
+without regard to the shadowy line
+over 1,000 pages of
+testimony were
+between avoidance and evasion, mis-
+Bodkin,* expressly disapproved,
+does not furnish a precedent as to procetake and willful omission.
+Lapides, as here, was a pre-indictdefendant was aware
+ment order to show cause. As this court
+that, if a "routine audit" revealed
+on review said,
+"Nothing in said order
+of criminal liability, the
+suggested that the hearing thus set was
+agent would not ignore it merely beto be a preliminary hearing only" (215
+cause he was primarily concerned
+F.2d 253, 256). Nor was any question
+there raised as to the nature of the injunctive provisions.
+As to the substantive law, whether the
+papers on which the order to show cause
+was granted be regarded as a Rule 41(e)
+motion or as a complaint in a civil action
+or even as a unique hybrid, they must
+possess legal sufficiency. Giving to the
+taxpayer's affidavit the most liberal construction as a complaint and at the same
+time regarding the same papers as an application for a preliminary injunction
+pending trial and final judgment of the
+issues there tendered, it fails to meet
+the legal requirements for suppression.
+Stripped of its conclusory assertions, the
+statement that the purpose of an investigation is a "routine audit" is
+not the equivalent of a promise that
+only civil liability will be considered
+regardless of what the examination
+reveals. Nor would any accountant
+or businessman so understand it.'
+United States • Wolrich, D.C.S.D
+N.Y.1954, 119
+F.Supp. 538, 540
+(Dimock, J.).
+"Moreover it is unrealistic to suggest that the government could or
+should keep a taxpayer advised as to
+the direction in which its necessarily fluctuating investigations lead.
+The burden on the government
+"Sco United Statea T. Selafani, 2 Cir.,
+265 F.21 408, which expressly disap
+1058, 103 F.Supp. 25." 2 Cir., 200 #.
+21 50.
+proves Matter of Bodkin, D.C.E.D.N.Y.
+
+
+would be impossible to discharge in
+fact, and would serve no useful pur-
+Che same principle was stated in Russo
+_ United States, 2 Cir., 1957, 241 F.2d
+285 (Clark, then Chief Judge. Iumbard
+and Waterman, C. JJ.). The Fourth
+Circuit rejected a taxpayer's contention
+which the court stated as follows:
+"The contention seems to be that
+revenue agents who secure the consent of a taxpayer to an examination
+of his books with intent to obtain
+evidence and use it in a criminal
+prosceution, are guilty of deceit unless they divulge their purpose, and
+that the obtaining of information in
+such a manner violates the Fourth
+Amendment and its introduction in
+evidence violates the Fifth Amend
+ment: and even if the examination
+is begun solely to ascertain the civil
+liability of the taxpayer and
+dence of crime is unearthed, the taxpayer must be warned and given an
+opportunity to withdraw his consent, or all information subsequently obtained is inadmissible in
+prosecution."
+926, 93 States, 4 Cir. 1065. 22 F. ei
+And in Centracchio | Garrity, 1 Cir.,
+1952, 108 F.2d 382, at page 387, the
+"On the face of the petition in the
+present case.
+and certainly on
+evidence offered by petitioner at the
+hearing before the district court, it
+is clear that the evidence in question did not come into the possession
+of the government officials in violation of petitioner's rights under the
+Fourth Amendment. He voluntarily turned over the evidence, and
+made the disclosures, to the agents
+of the Internal Revenue Bureau, for
+the purpose of a determination of his
+income tax liabilities."
+In conclusion I cannot reconcile the
+result reached by the majority with the
+language of the opinion. If, as they say.
+"Our holding that the order here sought
+to be reviewed is not appealable does not
+mean that district judges have unlimited
+discretion to stay the government or its
+agents from presenting evidence to a
+grand jury pending a hearing on a motion to supress," how can the discretion
+be limited except by appeal?
+that a judge disregards the 10 days'
+temporary restraining order limitation
+and grants 90 days. The restrained
+party has no other recourse than to move
+A refusal to vacate continues
+the injunction. If this order is not nppealable, the discretion remains "unlimited." Add to this situation the ingredient that the supporting papers do not
+support as a matter of law.
+relief against an improper injunction be
+secured except by appeal? It is all very
+well to say what difference does it make
+whether matters are called motions or
+actions, preliminary, temporary, civil or
+criminal but far more is at stake than
+mere words.
+Just as on the sea experience has proven that a maximum of safety for all is obtained by the formulation
+of definite rules of navigation and adherence thereto, so is it equally important that the procedures specified in
+legal rules be followed.
+The opinion of
+Judge Biggs of the Third Circuit (a circuit which has rather taken the lead in
+strict limitation upon,
+appealability) is
+most apposite.
+Sims | Greene, 3 Cir.
+1947, 160 F.2d 512.
+court had disregarded the time provisions of Rule 65(b).
+He said at page
+"It is settled that no temporary
+restraining order may be continued
+beyond twenty days unless the party
+against whom the order is directed
+consents that it may be extended for
+a longer period."
+Denying the motion to dismiss the ap
+peal and reversing the order, the court
+concluded at page 517:
+order now opinion the restraining
+Court must be treated as a temporary injunction, issued without the
+consent of the defendant, in the face
+
+
+LIZZA AND SONS, INC. - D'ONFRO
+175
+Cite as 282 F.2d 175
+of his motion to dissolve it, and conpolice and other enforcing officers is
+trary to the provisions of Rule 52
+indeed a major interest in a free
+(a).
+It is clear that an appeal
+society; but so is the effective prosies from
+temporary injunction.
+ecution of crime, an interest which
+Deckert Independence
+Shares
+at times seems to be forgotten."
+bar therefore may not be dismissed
+and the order restraining the defendant must be reversed."
+cision of the Fifth
+Circuit in Connell Dullen Steel Produets, 5 Cir., 1957, 240 F.2d 414 (temponotice strai from sims as reace t
+notice) differs from Sims
+believe that the Third Circuit's interpretation better follows the words and in-
+Following the type of relief granted
+in Sims Greene, I would hold that the
+order of March 8th is an order refusing
+to dissolve an injunction and hence ap-
+On the appeal I would vacate
+the stay order of February 26th as extended in effect by the order of March
+8th. I concur with the majority in their
+views with respect to the lack of sufficiency of the petition because the law is
+clear that upon the facts therein alleged
+the taxpayer is not entitled to an order
+of suppression. In connection with the
+pre-indietment preliminary attacks upon
+evidence, which are apparently becoming increasingly popular,
+it might be
+well to remember the words of a distinguished jurist (L. Hand, C. J.) in In re
+Fried, 2 Cir., 1947, 161 F.2d 453, 465:
+"It would be an intolerable burden
+upon the prosecution of crime, if it
+were possible to test in advance the
+competency of evidence which an
+accused, to say nothing of a prospective accused, might be able to show
+was likely to be used against him.
+Hon and toe sy the
+LIZZA AND SONS, INC., Plaintift,
+Appellant,
+Daniel A. D'ONFRO et al., Defendants,
+Appellees.
+No. 5571.
+United States Court of Appeals
+First Circuit.
+Aug. 18, 1960.
+Action by general contractor against
+contractor and surety for breach of alleged subcontract.
+The United States
+District Court for the District of Massachusetts, 186 F.Supp. 428, Charles Ed-
+ward Wyzanski, Jr., J., dismissed the
+complaint, and general contractor appeal-
+The Court of Appeals, Hartigan,
+Circuit Judge, held that where, after
+tract and delivered it to general contractor, who made deletions, without con
+Judgment affirmed.
+031, is not to the contrary. There the
+
+
+384
+272 FEDERAL REPORTER, 24 SERTES
+Under I.R.C.1939, § 272(a) (1), (f),
+ly mailing circulars in violation of the
+and (k), 26 U.S.C.A. § 272(a) (1), (f, k),
+Obscene Mail Statute, and who had been
+the first notice of deficiency was clearly
+arrested on the indictments at their resisufficient; and since timely filing is made
+dences in the Southern District of Calijurisdictional, the Tax Court correctly
+fornia where proceedings for their removal were instituted before the United
+States Commissioner, brought suits in
+equity in the United States District
+Court for the Southern District of California against the United States Comnot hold to the con-
+Crary, While pple C. T. B., 7 Cir., 180
+aimed a dir, 2 :2. 1, 0т. 065,
+point, since in each of these cases the
+firat letter had been sent to the wrong address.
+firmed.
+missioner and the United States Marshal
+to enjoin their removal. The United
+States District Court for the Southern
+District of California entered orders dismissing the suits on the merits and ordered removal of accused, and aceused
+appealed from the orders and made a
+The decision of the Tax Court is afmotion in the Court of Appeals for a
+stay of removal pending disposition of
+the appeals.
+The Court of Appeals held
+that stay would be denied, on ground that
+courts of equity do not ordinarily restrain criminal prosecution.
+Stay denied and appeal dismissed.
+Injunction 4-105(1)
+Where accused was indicted in
+United States District Court for the
+Harold R. STEINEB, Appellant,
+V.
+Theodore HOCKE, United States Commis
+soner for the Southern District of Call.
+fornia, Central Division, and Robert W.
+Ware, United States Marshal for the
+Southern District of Californis, Appel-
+Eastern District of Michigan for allegedly mailing circulars in violation of Ob-
+scene Mail Statute and were arrested on
+such indictmente at their residences in
+Southern District of California
+proceedings for removal of accused were
+instituted before United States Commissioner, and thereupon accused filed suits
+James B, FREW, Appellant,
+in equity against United States Commissioner and United States Marshal in
+Theodore HOCKE, United States Commis-
+United States District Court in Southern
+sloner for the Southern District of Call-
+•District of California to enjoin removal
+fornia, Central Division, and Robert W.
+of accused, on
+ground that circulars
+Ware, United States Marshal for the
+were identical with circulars which had
+Southern District of California, Appelpreviously been adjudged properly mail-
+Misc. Nos. 885, 896,
+United States Court of Appeals
+Los Angeles postmaster, and the District
+Court dismissed suits on merits and or
+Ninth Circult.
+Nov. 5, 1959.
+Accuzed, who had been indicted in asping, cort or alread sonia d
+the United States District Court for the stay on ground that courts of equity do
+
+
+ons. 18 U.S.C.A. 88 1461. 1462: U.S
+.A.Const. Amend. 1
+Brock, Fleishman & Rikoft, Hollywood, Cal., for appellanta.
+Laughlin E. Waters, U. S. Atty., Richard A. Lavine, Jordan A. Dreifus, Asst.
+U. 8. Attys., Los Angeles, Cal., for appellees.
+Before POPE, HAMLEY and KO-
+BLSCH, Cireuit Judges,
+PER CURIAM.
+The appellants have each been indicted
+in the United States District Court for
+the Eastern District of Michigan for allegedly mailing circulars in violation of
+the "Obscene Mail Statute", 18 U.S.C.A.
+§5 1461 and 1462 as amended August 28,
+1958. They were arrested upon these indictments at their residences in the
+Southern District of California where
+proceedings for their removal were instituted before the United States Commissioner, Thereupon each of them filed
+a suit in equity in the District Court for
+the District last mentioned against the
+Commissioner and the United States
+Marshal of said District, seeking to enjoin their removal. The grounds stated
+for the injunction sought were that the
+circulars they were charged with having
+caused to be delivered by mail in the
+Michigan district were the identical circulars which had theretofore been adjudged properly mailable, and whose
+mailing was held protected by the First
+Amendment in certain actions previously brought by one Toberoff against the
+Los Angeles postmaster.* Appellants alleged in such suits in equity, that the
+STEINER y. HOCKE
+385
+Cite sa 272 V 2d 384
+now pending had been sought only to
+harass the appellants, that the District
+Court in Michigan was without juriadietion to try appellants, that the Government is estopped by the rule of res judicata, and of estoppel by judgment to
+prosecute appellants for mailing the eirculars, and hence the removal should be
+enjoined and prevented.
+The court below dismissed these suits
+on the merits, on the ground that appellants had an adequate remedy at law.
+Thereafter
+the court below,
+acting
+through another judge, ordered the removal.
+These appeals were taken and
+now appellants move us to order a stay
+of the removal pending disposition of
+the appeals from the orders dismissing
+the equity suits.
+Appellees, in response, show that appellants have given bail bonds on removal calling for their appearance in the
+Michigan District to answer the indictmenta there. By that procedure, appellees say, appellants are now under obligation to respond in the Michigan district, and no officer in the State of California has any further function to perform in connection with their removal.
+Appellees move to dismiss the appeal as
+(1) moot, and (2) frivolous.
+We deny the stay upon grounds analogous to those discussed in Beal . Miasouri Pacifie R. Co., 812 U.S. 45, 61
+S.Ct. 418, 420, 85 L.Ed. 577, namely, that
+"courts of equity do not ordinarily restrain criminal prosecutions."
+While
+that case dealt with an attempted restraint of state prosecutions, we think
+the quoted rule is equally applicable to
+restraints of federal prosecutions. While
+great inconvenience will result from apjudgments in the former actions had
+finally adjudieated that the circulars were
+yet, as in the case cited, there is no showproperly mailable, that the indictments
+I Appellants alleged in their respective
+complainta that after these judgmente
+had been made, they bad purchased the
+buainess of the concerns which had been
+operating them at the time the postmaater had attempted to stop the mailing
+of the circulars out of which those actiona arose. We do not reach the quertion whether these appellanta were la
+sufficient privity with the original parties
+so as to permit application of the rules
+of res judicata or of collateral estoppel.
+Nor do we come to the queation as to
+whether the judgments against the postmaster bound the United States. For
+the purpose of this order we assume that
+these questiona may be answered in the affirmatire
+
+
+386
+272 FEDERAL BEPORTER, 2d SERIES
+bet fon te more tened. no erid no person treure did be ine complaint with
+cution is threatened. We find no reason
+here wh
+appellante should be permitted
+Affirmed.
+to depal from the ordinary rule that
+equity will not intervene in criminal
+prosecutions.
+Since & removal order is, under the
+scheme of the rules and the statutes, not
+appealable, we think it would frustrate
+that scheme if a defendant could, as at-
+Civil Rights 6-13
+Complaint for alleged loas of constitutional civil rights of plaintiff while in
+custody of city poliee and for alleged
+illegal transportation of his person into
+anther state was insufficient.
+tempted here, frame an issue in equity
+designed to force an adjudication in hia
+home district of a defense that will be
+fully available to him at the place of the
+indietment. The 1958 amendment of the
+statute suggests a further reason why
+the Congressional purpose to permit
+prosecutions at the place of receipt of the
+circulars should not be frustrated by the
+Congressional and Administrative News,
+85 Cong, Second Session, 1958, Vol. 2,
+Fred T. Stockwell, Toledo, Ohio, on
+brief in pro. per. for appellant.
+William D. Driscoll and Ben Neidlinger, Toledo, Ohio (Louis R. Young, Director of Law, by William D. Driscoll, Toledo, Ohio, on the brief), for appellees.
+Before McALISTER, Chief Judge
+and MARTIN and CECIL, Circuit
+Judges.
+p. 4012.
+The stay is denied and the appeal is
+dismissed.
+PER CURIAM.
+This case came on to be heard on this
+first day of December, 1959, the appellant having been duly notified of the
+setting.
+The appeal has been heard and considered upon the brief and reply brief
+of appellant, Frank T. Stockwell, and
+upon the brief and oral argument of the
+appellee, appellant having made no appearance at the hearing in person or by
+Frod T. STOCKWELI, Appellant,
+Harry FRIBERG ot al, Appellees.
+No. 13857.
+Jnited States Court of Appeal
+ixth Circuit
+Dec. 14, 1959.
+attorney.
+The action of appellant was to recover
+damages for the alleged loss of his "constitutional rights while in the custody of
+the Toledo, Ohio, Police, and for the illegal procedures involved which brought
+about the illegal transportation
+person into the State of Michigan." He
+prayed an award of damages in the
+amount of Five Millien Dollars ($5,000,-
+Action for alleged loss of constitu-
+000) and that the amount awarded by the
+tional civil rights of plaintiff while in
+jury be tripled and declared tax free.
+custody of city police and for alleged ille-
+We find no merit whatever in appelgal transportation of his person into anlant's contention that bis constitutional
+other state. The United States District
+civil rights have been violated; and, for
+Court for the Northern District of Ohio,
+the reasons stated in the opinion of Unit-
+Kloeb, J., rendered judgment dismissing ed States Distriet Judge Kloeb, we affirm
+complnint with prejudice, and plaintiff his order dismissing the complaint with
+appealed. The Court of Appeals, beld prejudice.
+
+
+8G0
+187 FEDERAL BEPORTER, 2d BERIES
+ACKERMAN, Atty. Gen. INTERNATION- 1945, §5 11120, 11570-11584, National La
+AL LONGSHOREMEN'S & WARE
+bor Relations Act, 29 U.S.C.A. § 151 et seq.:
+HOUSEMEN'S UNION et al.
+Labor Management Relations Act of 1947,
+BEVINS. County Atty, et al. • INTERNA
+29 U.S.C.A. § 141 et seq., 8 U.S.C.A. 99 41,
+TIONAL LONGSHOREMEN'
+& WARE-
+43, 44, 46, 47, 49(a); U.S.C.A.Const.
+HOUSEMEN'S UNION et al. (two cases).
+Amends. 1, 5, 6, 14, 19.
+ACKERMAN, Atty. Gen. at al. ¿ INTERNA. 2. Courts e=262.7(24)
+TIONAL LONGSHOREMEN'S & WARE.
+Alleged activity of pickets in force-
+HOUSEMEN'S UNION et al.
+fully preventing nonstriking workers from
+Nos. 12300, 12301.
+entering plant, beating of nonstrikers, and
+acts of force preventing supervisory em-
+United States Court of Appeals,
+ployees from unloading employer's product
+Ninth Circult.
+upon barges, involved conduct, policing of
+Feb. 28, 1051.
+which was left wholly to territory of
+Rebearing Denled May 25, 1951.
+Hawaii in which alleged acts occurred.
+Two actions by International Longshore-
+Rev.Laws Hawaii 1945, 55 11120, 11570-
+men's & Warehousemen's Union, a voluntary
+nincorporated association and labor union,
+and others, agalnst Walter D. Ackerman, Jr., 3. Courts e-262.6(1)
+individually and as Attorney General of tbe
+Mere proof of bad faith of prosecutors
+Territory of Hawali, and others, and agalnst
+is not sufficient to warrant enjoining crim-
+E. R. Bevins, Individually and as County At-
+inal proceeding.
+torney for the County of Maul, and others, to
+enjoin the prosecution of four criminal pro-
+4. Courts *=262.6(2), 262.7(3)
+ceedings pending in the Circuit Cort of the
+In suit to enjoin prosecutions under
+Territory of Hawall, one for riot and conspl-
+Hawaiian unlawful assembly and riot act
+recy and three for rot.
+The United States
+and conspiracy statute against members of
+District Court for the Territory of Hawail,
+union for alleged acts of violence during
+John Biggs, Jr., Circult Judge, and Delbert
+E. Metzger and George B, Harris, District
+strike, constitutionality of statutes could
+Judges, entered final decrees granting permabe determined as readily in criminal cases
+nent Injunetions, and Walter D. Ackerman,
+as in suit for injunction. Rev.Laws Ha-
+Jr., and E. R. Bevins, individually, and othwaii, 1945, S$ 11120, 11570-11584.
+ers, appealed. The Court of Appeals, Pope,
+Circult
+Judge,
+held that Injunctiong
+5. Courts @406.3(8)
+ground of exceptional circumstances and It-
+In suit to enjoin prosecutions under
+reparable injury were improper.
+Hawaiian unlawful assembly and riot act
+Judgments reversed with directions.
+and conspiracy statute against members of
+union for alleged acts of violence during
+I. Courts e-262.7(24)
+strike, trial court's finding to effect that
+In suit to
+enjoin prosecutions unde
+prosecutions were not begun in good faith
+was clearly
+Rev.Laws Ha-
+wail 1945, §§ 11120, 11570-11584.
+strike, alleged efforts of pickets to prevent 6. In]unction 6109
+In suit to enjoin prosecutions under
+beatings by pickets and assaults which al- Hawaiian unlawful assembly and riot act
+legedly prevented loading of products on and conspiracy statute against members of
+barges had no relation to any rights grant- union for alleged acts of violence during
+ed by the Labor Management Relations strike, facts that no one had been prose-
+Act, or Civil Rights Act or to constitu- cuted under first statute except in connectional rights to free speech, press, assembly tion with labor dispute, that there were
+and peaceful picketing so as to justify mass arrests, that excessive bail was reinjunctive relief on ground that prosecu- quired, that police did not contemplate
+tions interfered with collective bargaining complaints until directed by prosecuting
+or legitimate activity. Rev.Laws Hawaii officers, and that statutes with heavy pen-
+
+
+AOKERMAN - INTEBNATIONAL LONGSHOREMEN'S & W. UNION 861
+Cite as 187 F.2d 560
+alties were invoked for minor infractions, 12. Courts -262.6(1)
+among other things, did not establish lack
+Injunction * 105(1)
+of good faith on part of prosecutors. Rev,
+Equity will stay its hand with respect
+Laws Hawaii 1945, 95 11120, 11570-11584.
+to criminal proceedings, always when they
+are pending, and ordinarily when they are
+7. Courts 8-262.6(4)
+threatened, and rule is applied both by
+In suit to enjoin prosecutions under state courts and by federal court when
+Hawaiian unlawful assembly and riot act asked to enjoin criminal proceedings in
+and conspiracy statute against members of federal court.
+union for alleged acts of violence during
+strike, where constitutionality of statutes
+13. injunction 105(1)
+could be tested in criminal proceedings and
+Rule that equity will stay its hand with
+there was no evidence to support finding
+respect to criminal proceedings, always
+that criminal prosecutions were not in good
+when they are pending, and ordinarily when
+faith, plaintiffs were not entitled to have
+they are threatened, is a principle expressprosecutions enjoined on grounds of exing sound policy that processes of criminal
+ceptional circumstances and irreparable
+law should be permitted to reach orderly
+injury. Rev.Laws Hawaii 1945, $5 11120,
+conclusion in criminal courts where they
+11570-11584.
+belong.
+14. Courts e-262.6(1)
+8. Courts 8=262.6(4)
+Ordinarily, federal court should not
+In suit to enjoin pending prosecutions interfere with state officers charged with
+under Hawaiian unlawful assembly and
+riot act and conspiracy statute against un- laws.
+duty of prosecuting offenders against state
+ion members for alleged acts of violence
+during strike, where complaint contained 15. Courts -262.4(5), 432
+no allegations to support injunction against
+Where equitable interference with
+future criminal proceedings but merely state and territorial acts is sought in fedalleged that enforcement would deprive eral courts, judicial consideration of acts
+plaintiffs of their liberty and property of importance primarily to people of state
+without due process of law, that they would or territory should as a matter of disbe prohibited from exercising rights of free cretion be left by federal courts to courts
+speech, press and assemblage, and that of the legislating authority unless excepunion could not function, no injunction tional
+circumstances command different
+should have been granted. Rev.Laws Ha- course.
+waii 1945, 99 11120, 11570-11584.
+9. Courts §=508(I)
+Federal court cannot interfere in case
+where proceedings are already pending 'in
+state court.
+Walter D. Ackerman, Jr., Atty, Gen.
+Territory of Hawaii, J. Garner Anthony,
+Special Deputy Atty. Gen., Rhoda. Lewis,
+Asst. Atty. Gen.,
+Richard K. Sharpless,
+Deputy Atty. Honolulu, T. H., for ap-
+It is not function of federal court of
+Bouslog & Symonds and Harriet Bousequity to exercise supervisory control over log, all of Honolulu, T. H., for appellees.
+action of territorial court.
+I. Injunction @- 105(1)
+cule that equity jurisdiction doesi not
+xtend to enjoining pending crimina
+prosecutions has no exceptions, and extraordinary circumstances will not create jurisdiction.
+Stephenson and J. Donovan Flint, all of
+Honolulu, T. H., for Bar Association of
+Hawaii, as amicus curiac.
+Before DENMAN, Chief Judge,
+, ORR
+and POPE, Circuit Judges.
+
+
+862
+187 FEDERAL REPORTER, 2d SERIES
+POPE, Circuit Judge.
+In consequence of this incident some 75
+These are appeals from judgments in
+men have been indicted, charged with riot
+two actions brought by the International
+and conspiracy under the Territorial un-
+Longshoremen's & Warehousemen's Un-
+lawful assembly and riot act, Chap. 277
+ion (ILWU), a labor union, and by certain
+Rev.Law of Hawaii, 1945, 59 11570-11584,
+individual members of that union, to enand the Territorial conspiracy
+join the prosecution of four criminal pro-
+Rev.Laws of Hawaii, 1945, § 11120 Brature,
+ceedings pending in the circuit court of
+The other three criminal proceedings
+the Territory of Hawaii, one for riot and
+grew out of incidents later occurring in
+conspiracy, and three for riot. The court
+connection with the pineapple workers
+below entered final decrees granting per- strike, on the Island of Lanai, also in the
+manent injunctions as prayed, against the County of Maui. On July 14, 1947, as
+Attorney General of the Territory, the several supervisory employees of the Ha-
+waiian Pineapple Company, not members
+torney of the County of Maui, and in one
+of the union, were about to load upon a
+case the County Chief of Police.
+barge some pineapples picked before the
+The criminal charges grew out of certain
+strike and then in bins upon the wharf,
+disorders which occurred during separate
+about 300 union pickets led by union "picket
+strikes by sugarworkers, and pineapple
+policemen" ran toward the men on the
+wharf, yelling "at the tops of their voices",
+caught and beat one of the men, chased
+the sugarworkers strike, some three to four
+and "punched at" another, forcing him
+hundred members of that group were in a
+and another man to jump into the water
+picket line, four columns deep, before the
+to escape, broke open the bins and threw
+entrance to the sugar mill of Maui Agripineapples at the barge and tug and at the
+cultural Company at Paia, on the Island of
+men in the water.
+Maui.
+Five workmen employed in the mill
+Two complaints, charging riot, were filed
+appeared for the purpose of crossing the
+against persons accused of participating in
+picket line and going to work. The same
+this incident. In one case eleven defendmen had attempted to pass through to
+ants, and in the other, 36 defendants, were
+work the previous day, but had been pre- committed after waiving preliminary exvented because the pickets stood shoulder
+amination, to await the action of the grand
+to shoulder.
+On the 16th a number of
+police were on hand.! As the mill whistle
+blew the five men, escorted by the police,
+On the day following the incident at
+started toward the mill entrance. Two
+the wharf, 20 to 25 persons headed by
+hundred of the pickets converged on the
+"union police" with arm bands, went to the
+five men and pushed them back.
+Upon a
+rooms of two non-striking truck drivers
+second attempt to pass the five workmen and
+employed by the Hawaiian Pineapple Comthe police were pushed back 10 or 12 feet
+pany on the Island of Lanai, and adminisfarther. This ended the attempts to enter
+tered "a severe beating" to both of them.
+the mill. There is no finding that any blows
+A complaint, charging riot, was
+filed
+were struck.
+against five persons charged with par-
+I. The opinion of the distriet court states
+that at this time "After certain prelim-
+Inary conversations between members of
+the ILWU, Kealoha, Joseph Kaholokula,
+and others, respecting the eatry of the
+five workmen to the mill it was stated by
+Kaholokula that if the five men tried to
+ross the picket line, "police or no police,
+here would be violence and bloodshed."
+82 F.Supp. 65, 79.
+Kabolokula, 37 Ilaw. G25. The second
+indietment followed.
+
+
+ACKERMAN Y. INTERNATIONAL LONGSHOBEMEN'B & W. UNION
+863
+Cite as 187 .2d 800
+ticipating in this affair, They also were serious difficulties, and in this connection
+committed awaiting action by the grand quoted from the opinion of Chief Justice
+jury. The prosecution of these defendants
+Stone in Douglas v. City of Jeannette, 319
+and of the other defendants similarly
+U.S. 157, 163, 63 S.Ct. 877, 881, 87 L.Ed.
+bound over, has proceeded no further by
+1324, as follows: "It is a familiar rule
+reason of the injunctions issued by the
+that courts of equity do not ordinarily
+court below.
+restrain criminal prosecutions. No person
+The individual plaintiffs in these actions
+is immune from prosecution in good faith
+are the defendants in the four criminal
+for his alleged criminal acts. Its improceedings mentioned, plus two officials
+minence, even though alleged to be in
+of the union who purport to sue on behalf
+violation of constitutional guaranties, is
+of themselves and all other members of the
+not a ground for equity relief since the
+union in the Territory.
+lawfulness or constitutionality of the stat-
+Judgment in No. 12301 was based upon
+ute or ordinance on which the prosecution
+a complaint seeking to enjoin further
+is based may be determined as readily in
+prosecution of the proceeding in which the
+indictment was returned. The complaint in
+No. 12300 sought similar relief in respect prosecution is by state officers for alleged
+to the three proceedings in which commitments had been made. Both complaints
+Fill
+the criminal case as in a suit for an injunction. * • * Where the threatened
+violations of a state law, the state courts
+are the final arbiters of: its meaning and
+allege that in furtherance of the objectives
+application, subject only to review by this
+of the strikes, which were to obtain better
+Court on federal grounds appropriately
+wages, hours, and conditions of employasserted. Hence the arrest by the federal
+ment, the individual plaintiffs engaged in
+courts of the processes of the criminal law
+"lawful, peaceful and constitutionally prowithin the states, and the determination
+tected activities of speech, press and asof questions of criminal liability under state
+semblage and of peaceful picketing." The law by a federal court of equity, are to be
+unlawful assembly and riot statute and the
+supported only on a showing of danger
+conspiracy
+statute are attacked as un- of irreparable injury 'both great and imconstitutional in that they are alleged to mediate.'"
+deprive plaintiffs of their rights of free
+But the trial court held that the facts of
+speech, press and assemblage and will this case were such as to take it outside
+subject them to criminal prosecutions if
+of the ordinary rule that courts of equity
+they exercise their constitutional rights. will not enjoin criminal prosecutions; that
+It is alleged that the grand jury which it involved exceptional circumstances which
+found the indictment was chosen and compermit injunctive relief, and that there
+posed in an unconstitutional manner. Pray- has been a disclosure of the irreparable
+crea for of the in praiting men honey to bogres and in or diate entioned, that prosecution of the criminal pra.
+proceedings be enjoined, and that the stat-
+The court found two such special circumutes be held unconstitutional.
+stances. First, it said, "All collective bar-
+The trial court recognized that
+the gaining in the Territory of Hawaii in our
+prayer for an injunction restraining the
+opinion is substantially affected by the two
+prosecution of criminal proceedings posed
+statutes! as well as by the prosecutions
+heard before the decision
+• a Stainback 1. No Hock ore tok Po, 33
+U.S. 368, 60 S.Ct. 606, 93 LEd. 741, by
+three judges who, although of the opinno application, they were in any event a
+Jistrict court "sitting in bank". Sines
+the decision and all rulings were unanimous, the direumatance of three judges
+artleipating we consider of no aignit
+ance here. The extended opinion of th
+court in reported in 82 F.Supp. 65.
+4. [l. e., the unlawful assembly and riot act
+and the
+conspiracy statute, both of
+which the court held unconstitutional.]
+
+
+864
+187 FEDERAL REPORTER, 2d BERIES
+conducted or about to be carried on there-
+[1,2] Here there is no showing of any
+under.
+Approximately
+thousand
+attempted collective bargaining, or other
+members of the ILWU and the union itlegitimate union activity with which any
+self necessarily feel the impact of the statact here charged to the defendants could
+utes as does each employer in the sugar possibly interfere.
+The evidence shows, on
+and pineapple industries.
+All labor rethe contrary, that the activities in which
+lations in the Islands are clouded by them.
+the plaintiffs were engaged at the time of
+On the records presently before us we
+the occurrence out of which the criminal
+think it is fair to state that equable or
+prosecutions arose had nothing to do with
+amicable relations betwery employers and
+any right granted by the Labor Manageemployees in the Territos
+of Hawaii are
+ment Relations Act, 1947,g the Civil Rights
+impossible while the statutes stand. The
+Act,® or Amendments I,
+VI, XIV and
+repercussions which arise from the en-
+XIX to the Constitution, upon which plainforcement of these statutes of the Territory
+tiffs' rights are alleged to be founded. The
+are such as to cause great and irreparable
+activities and conduct of the plaintiffs
+harm and damage to all labor relations in
+here, (characterized by the trial court as
+the "illegal conduct of the strikers") in-
+This portion of the opinion of the court
+volved the sort of conduct "policing of
+[which] is left wholly to the States. * *
+No one questions the State's power to
+L.Ed. 873. The trial court's opinion quoted
+police coercion by those metiaods." Interfrom that case what was there said of the
+natjonal Union, U. A. W.
+Wisconsin
+requirement of proof of irreparable in-
+Employment Relations Board, 36 U.S. 245,
+jury which is clear and imminent" as fol-
+253, 69 S.Ct. 516, 93 L.Ed. 651.
+lows: "That is a strict test. But we think
+Perhaps implicit in the triai court's
+appellants satisfy it. We reach that confinding that labor relations and collective
+clusion on the basis of the allegations
+bargaining were adversely affected, is the
+concerning the disruption of the collective
+court's apparent view that the very exbargaining processes and the injury to the
+istence of an unconstitutional act upon the
+unions and to the employers alike, if the
+statute books operated as a psychological
+closed-shop agreement is outlawed.
+obstacle to labor activities and negotiations.
+we have said, it is averred that there are
+Such an argument, if sound, would lead
+about 500 contracts with Florida employers
+to the result that an injunction might issue
+containing closed-shop agreements
+in any case where
+an unconstitutional
+82 F.Supp. 65, 109.
+statute might constitute a mental hazard
+We are unable to perceive any resem-
+Thus the statute attacked in Douglas
+blance between the facts here and those
+City of Jeannette, supra, was unquestion
+in A. F. I. y. Watson,
+bly unconst ational, for the court so he
+it appeared that the plaintiff labor unions
+• Murdock - Pennsylvania, 319 U.S. 10
+were engaged in negotiating closed shop
+63 S.Ct. 870, 87 LEd. 1292, yet the bill in
+agreements, as they asserted they had the
+the Jeannette case was held to be without
+right to do by virtue of the National Labor
+Relations Act, 29 U.S.C.A. § 151 et seg.
+equity.
+No doubt the invalid ordinance
+there was as much of a psychological
+and that the proceedings which the At- hazard to the Jehovah's Witnesses, as the
+torney General of Florida proposed to in- statutes here attacked could be to union
+stitute against them, pursuant to the newly labor.
+00 contracts, and many thousands of emthe rimini roat che prosecution d in h
+ployees.
+5. 20 U.S.C.A. § 141 et seq.
+6. 8 U.S.C.A. 18 41, 43, 44, 40, 47, 43(a);
+28 U.S.C.A. $ 1343.
+
+
+AOKERMAN | INTERNAYIONAL LONGSHOBEMEN'S & W. UNION
+865
+Cite as 187 F.2d 800
+proceedings was not in good faith. The warrant
+enjoining the criminal proceed.
+trial court did not undertake to cite any case ings.?
+in which proof of bad faith in a criminal. The trial court has failed to note what
+prosecution was held to establish reason
+appears to us to be the probable reason for
+for departure from the ordinary rule that
+the use of the words "prosecution in good
+a court of equity will not entertain a suit faith" in the sentence quoted from the
+to enjoin criminal prosecutions. The court Jeannette case. Appellants have called our
+evolved its conclusion that want of good
+attention to the fact that the statement:
+faith was a sufficient reason for issuing
+"No citizen * • • is immune from
+such an injunction from the phraseology
+prosecution, in good faith, for his alleged
+ised in Douglas - City of Jeannette, supra
+criminal acts", was first used in decisions
+hat "courts of
+equity do. not ordinarily following Hague v. C. I. O., 1939, 307 U.S.
+restrain criminal prosecutions. No person
+496, 59 S.Ct. 954, 83 LEd. 1423. Such
+is immune from prosecution in good faith
+decisions, thus referring to "prosecution
+for his alleged criminal acts." (Emphasis
+in good faith", are Beal v. Missouri-Pacific
+The court reasoned that in in-
+R. Corp., 312 U.S. 45, 49, 61 S.Ct. 418, 85
+serting the words "in good faith" in the
+LEd. 577; Watson v. Buck, 313 U.S. 38
+woted language, the court was at least 61 S.Ct. 962, 85 L.Ed. 4416, and Douglas
+implying that only prosecutions in good City of Jeannette, supra.
+faith are immune from equity injunctions,
+and hence if bad faith be shown the crimi-
+[4] We think a more likely explanation
+nal prosecution may be enjoined. We think
+of the use of this phrase is that the Su-
+this purely textual analysis of the quoted
+preme Court had in mind such cases as
+language is not warranted, for to say that
+Hague v. C. I. O., supra, in which it apone is not immune from prosecution in
+peared that plaintiffs seeking to hold peacegood faith does not imply that one is imful meetings and to distribute literature
+mune from prosecution in bad faith, and
+were threatened with arrest under the void
+may enforce that immunity by injunction.
+Jersey City ordinance, and their associates
+The trial court recognized that "the motive
+had been arrested and carried out of the
+of the prosecutor is of course not relevant
+city, all in line with a deliberate policy of
+to the ordinary criminal proceeding"
+excluding and removing plaintiffs' agents
+from Jersey City, Indeed, the Jeannette
+We cannot bring ourselves to believe
+case, supra, 319 U.S. at page 164, 63 S.Ct.
+that a defendant in a criminal case, who
+at page 881, made specifie reference to this
+would not be permitted to plead or prove
+aspect of the Hague case in distinguishing
+as a defense to the charge, that the proseit. Another type of case is that represented
+cutor's motives were bad, could nevertheby Ex parte Young, 209 U.S. 123, 28 S.Ct.
+less by alleging such bad faith and the
+441, 52 L.Ed. 714, where the applicant for
+invalidity of the criminal statute, move
+injunction was confronted with threatened
+into a court of equity and have those issues
+prosecution under a statute imposing such
+tried there.
+No case has been called to
+large penalties he dare not test its validity
+our attention which has applied the trial
+by violation inviting prosecution.
+cause of the special facts which were
+court's theory that proof of bad faith in present in Hague v. C. I. O. and Ex parte
+the criminal prosecution is sufficient to
+Young, the applicants for injunction had
+On the contrary, compare Kentucky
+owers, 201 U.8. 1, 28 8.Ct. 387, 50 I
+rolved the knowing use of perjured testi-
+Ed, 633. A claim of denial of constitumony, and a deliberate euppression of eridence, and bence was itself • denial of
+tonal rights and of official bed faith, opdue process, the petitioner for federal
+pression and misconduct in the prosecocourt action (habeas corpos), was redate Crate bones nodes
+remedy in the
+state courts.
+294
+U.8. 103, 65 8.Ct. 340,
+TP LeEd. 791,
+faith charged against the prosecuter in-
+187 F.8d-65
+lecord, Er parte Hawk, 821 U.S, 114.
+116, 04 8.Ot. 448, 88 L.Ed. 572
+
+
+866
+187 FEDERAL REPORTER, 2d SERIES
+no reasonable opportunity to test their was too vigorous, or that the police officers
+rights in the criminal cases.
+For this rather than the prosecuting attorney, should
+reason the threatened prosecutions there
+have selected the statute under which comsort not is and at an in outs
+plaint would be filed, or that the methods
+used in securing evidence were poor. In
+City of Jeannette, that "the lawfulness
+our opinion these circumstances are inconstitutionality of the statute or ordinance
+sufficient to establish want of good faith.
+on which the prosecution is based may be
+We must therefore disagree with the condetermined as readily in the criminal case. clusion of the trial court that the facts
+as in a suit for an injunction." Such, we
+here present extraordinary circumstances
+to take this case out of the ordinary rule
+think, is the case here.
+that a court of equity will not enjoin a
+[5-7] Furthermore, we think want of
+criminal prosecution.
+good faith was not proven, and the court's
+But there is a further reason why, in
+finding in that respect clearly erroneous.
+The principal ground of bad faith is said
+our opinion, these cases cannot, in any
+to be that "no one has been prosecuted under the unlawful assembly and riot act except in connection with labor disputes". 739, this court said: "In support of the
+But unless riots did occur at places and un- decree appellee argues broadly that a court
+der circumstances not involving labor disof equity may enjoin a criminal prosecution
+putes which called for complaints which
+under a void statute where such prosecution amounts to a wrongful invasion of
+the prosecutor refused or neglected to file,
+the quoted statement has no significance. It a property right, [citing cases]. However,
+is not claimed, and there was no allegation
+the present suit is not within the principle
+or proof that there were any such unproseannounced in these,
+authorities.
+The remainder of the
+was sought in those cases was relief against
+circumstances listed by the court's opinthreatened, not pending, prosecutions; and
+ion as evidence of bad faith, it seems to
+in them the court proceeded upon the view
+us, are no more than expressions of the
+that one is not compelled to test the contrial court's opinion that the prosecution
+stitutionality of an act by first incurring
+8. The trial court'a enumeration of the
+facta thought to show bed faith was as
+follows: "In thia connection the following facts among othere in the instant
+cases are pertinent: (1) (a), the mass
+arresta, and the very broad, indeed, the
+too broad feld, from which the police
+drew the defendants in the various erim-
+Inal procedinge after both the Pais and
+the Kaumalapnu Harbor incidents, demonstrated by the faet that the names of sixteen persons were stricken out of one of
+the complainte and that of ninety-tree
+arresta made on the Island of Osbu on
+July 18, 1047 only one person, ris. Sibolboro, was subjected to prosecution, all
+ther complainta being selle prossed
+b) the naming of persons ás defendant
+in criminal proceedings from photographe
+taken by the police both prior and sub-
+BABE
+fact that Aaristant Chief of Police Frei-
+Pala or Kaumalapan Incidenta and did not
+contemplate the swearing out of a complaint against any of the plaintits under
+that statute until directed to do so by
+the prosecuting officers of Maui County:
+(3) the repeated selection of the unlawful
+assembly and riot act with its beavy penalties as the vebicle for the prosecution
+of comparatively miner infractions of the
+criminal laws; (4) the haste with which
+the prosecuting officers of Maal County
+procured the second indictment of Kaho-
+Jokala and others when the first indictment was held avalid by the Supreme
+Court of Hawaii: (5) the fact, for we
+have found it to be a fact, that no one
+has been prosecuted under the unlawtul
+assembly and riot act except in conneetion with labor diaputes at any time during the life of the Territory: and (6)
+the fact that the maximum penalty under
+the unlawful assembly and riot act was
+increased from five years' imprisosment
+to tweaty years imprisonment in 1929,
+following the Filipino workers' atrike in
+tas did not read the unlawful assembly
+and riot act to the strikers doring the
+
+
+ACKERMAN Y. INTERNATIONAL LONGBHOBEMEN'S & W. UNION 867
+drastic penalties attached to its violation, nied The court made no fnding that fubut may, under extraordinary circumstanc- ture prosecutions were threatened.
+es, appeal to equity for relief against the
+invasion of his property rights through the
+(9] The rule stated in the Babcock case
+was that declared in Ex parte Young, 209
+0.5. 123, 162, 28 S.Ct. 441, 455, 52 L.Ed.
+52 L.Ed. 714; Fenner
+714, as follows:
+"But the Federal court
+1 Tempon 120 5 07, i ser s
+cannot, of course, interfere in a case where
+the proceedings were already pending in a
+LEd. 255]. Here, no threat of the instate court." The same rule was followed
+stitution of other criminal proceedings
+and applied in Cline
+• Frink Dairy Co.,
+under the act is alleged in the bill or found
+274 U.S. 445, 452-453, 47 S.Ct. 681, 71 L
+to have been made. The relief sought is
+against the further prosecution of the
+[10] The distinction stated in the Babpending case."
+cock case, between pending and threatened
+[8] The injunctions here issued reprosecutions, is founded upon certain fundlated solely to prosecutions then pending."
+amental characteristics of equity, juris-
+There is no injunction against any threat- in Douglas
+diction. The first to be noted is that stated
+City of Jeannette, supra, 319
+tained no allegations to support an injunc-
+The complaints con- U.S, at page 165, 63 S.Ct. at page 882: "In
+tion against future or threatened criminal
+any event, an injunction looks to the fuproceedings.
+The only allegation of future
+ture." In the case before us all that is
+damage was that the criminal statutes "will
+drawn in question are past acts. There
+deprive plaintiffs of their liberty and propis no proof or finding that for exercising
+erty without due process of law, in that
+lawful rights plaintiffs are threatened with
+plaintiffs will be prohibited from exercisfuture prosecutions under the statutes they
+ing their rights of free speech, press and
+assail. Thus, for the court below to assume
+assemblage in violation of the Fifth and
+to enjoin prosceution of the four pending
+Fourteenth Amendments to the Constituproceedings is to assume to exercise a
+supervisory control over the action of the
+tion of the United States," and that the Territorial court.. Such is not the function
+union could not function "so long as the of a court of equity.
+members of the said ILWU are subject
+* * * to prosecution under statutes con-
+The second circumstance basic to this
+taining unconstitutional limitations." This
+distinction was pointed out in the quoted
+falls far short of an allegation that these
+portion of the : Babcock opinion which
+plaintiffs were threatened with prosecution
+states that where the prosecution is threatunder the statutes on account of peaceful
+"one is not compelled
+to test the constitutionality of an act by
+picketing, publicizing, bargaining, or ex- first incurring drastic penalties attached to
+ercising other constitutional rights and its violation, but may, under extraordinary
+This defect in the complaints
+circumstances, appeal to equity
+was called to the attention of the court and
+etc. Ex parte Young, which dealt with a
+of the plaintiffs by motions which pointed
+out the failure to complain of threatened
+statute having drastic penalties, is a classic
+example of such a situation. Here, on the
+future action, but the motions were decontrary, in the four pending actions, the
+9. The injunetion In No. 12301 was "from
+to dismiss, and for summary judgmenta
+proceeding with the prosecutios com
+"The complaint falls to show
+meneed in October, 1940." That in No.
+that said plaintitle are threatened with
+more than one criminal proceeding, or
+that anything at all is involved otber
+than prosecution of an alleged violation
+ment of the suits
+of the criminal laws of the Territory of
+10. Motions for more defnite statement,
+Hawall, with respect to matters which
+have already occurred."
+
+
+868
+187 FEDERAL REPORTER, 2d BEBIES
+plaintiffs have at hand full opportunity to
+avoiding whenever possible conflict betest their rights by defending in those
+tween the two judicial sy
+This
+proceedings. As this court said in Alesna
+licy was stated in Fenner • Boykin, 271
+v. Rice, 9 Cit., 172 F2d 176, 177, "Had
+T.S. 240, 243, 46 S.Ct. 492, 793, 70 L.Ec
+the prosecution of the information pro-
+927: "Ordinarily, there should be no interceeded, the jury might have acquitted the
+ference with such officers; primarily, they
+defendants, appellants, and the constituare charged with the duty of prosecuting
+tional and other questions avoided. In any
+offenders against the laws of the state,
+event, the appellants had a speedy and
+and must decide when and how this is to
+sufficient remedy at law by appeal to the
+The accused should first set up
+Hawaiian Supreme Court, where the apand rely upon his defense in the state
+pellants' arguments of the two contentions
+courts, even though this involves a chalmay have prevailed. Losing, there is the
+lenge of the validity of some statute, unappeal here. In both appellate courts the
+less it plainly appears that this course
+practice gives primacy of consideration to
+would not afford adequate protection. The
+criminal appeals."
+Judicial Code provides ample opportunity
+(11)
+The rule that equity jurisdiction
+for ultimate review here in respect of feddoes not extend to enjoining pending crimeral questions.
+An intolerable condition
+inal prosecutions, has no exceptions. No
+would arise, if, whenever about to be
+extraordinary circumstances will serve to
+charged with violating a state law, one
+were permitted freely to contest its validity
+create such jurisdiction.
+by an original proceeding in some federal
+[12, 13] That equity will stay its hand
+court.".
+in respect to criminal proceedings, always
+when they are pending.
+and ordinarily
+[15] That this policy applies to pro
+posals to enjoin proceedings in the courts
+when they are threatened, is a rule of wide
+of Hawaii as well as to similar injunctions
+and general application
+under our legal
+system. It is a rule of the state courts in
+directed painst state courts, we stated in
+Alesna
+Rice, supra:
+"The Jeannette
+respect to criminal proceedings in the same
+case concerned the enjoining of state proseor other state courts.
+Milton Dairy Co.
+cutions. We think the criminal laws of the
+Great Northern Ry. Co., 124 Minn. 23
+Territory of Hawaii are entitled to the
+144 N.W. 764, 49 L.R.A.,N.S., 951; State
+same protection.
+Section 86(c) of the
+ex rel. Kenamore
+1 Wood, 155 Mo. 425,
+56 S.W. 474, 48 L.R.
+Federal courts
+Hawaiian Organic Act, 48 U.S.C. § 642,
+48 U.S.C.A. § 642, provides that the United
+apply the same rule when asked to enjoin
+States District Court for the District of
+Criminal proceedings in the federal courts.
+Hawaii 'shall have the jurisdiction
+of
+Argonaut Mining Co. McPike, 9 Cir.,
+district courts of the United States,
+78 F.Zd 584; Whitehead v. Cheves, 5 Cir., • * * This court has recognized that
+67 F.2d 316, 317, certiorari denied 290 U.S.
+the Organic Act places the courts of the
+04, 54 S.Ct. 371, 78 L.Ed. 605; Campbel
+Territory, of Hawaii in a relatively similar
+_ Medalie, 2 Cir., 71 FZd 6/1, certiorar
+position to the federal judicial system as
+denied 293 U.S. 592, 55 S.Ct. 108, 79 L.Ed.
+See Wilder's S. S.
+686. It is a principle expressing a sound
+policy that the processes of the criminal
+affirmed 183 U.S. 545, 22 S.Ct. 225, 46 I
+law should be permitted to reach an orderly
+Ed. 321, and Yeung - Territory of Hawai
+conclusion in the criminal courts where 9 Cir., 132 F2d 374, 378." And since our
+they belong.
+decision in that case, the Supreme Court
+[14] But when the demand for an in- stated the reason for assimilating the
+, 69 S.Ct. 606,
+of policy against any such action are 614, 93 L.Ed. 741, as follows:
+"Entirely
+multiplied because
+of the necessity of aside from the question of the propriety
+
+
+BROOKS HE BI TATANTA BOO
+869
+of an injunction in any court, territorial felent to prevent award of summars judglike state courts are the natural sources for ment against plaintier.
+the interpretation and application of the Attirmed.
+acts of their legislatures and equally of the
+See, also, 81 F.Supp. 101.
+propriety of interference by injunction. I. Federal evil procedure e2491
+We think that where equitable interference
+with state and territorial acts is sought in
+In action against railroad for alleged
+federal courts, judicial consideration of
+misdelivery of household goods transported
+under straight bill of lading issued by deacts of importance primarily to the people fendant and in which plaintiff was named
+of a state or territory should, as a matter of
+discretion, be left by the federal courts to
+as consignor and consignec, allegation in
+the courts of the legislating authority unaffidavit submitted in opposition to defendless exceptional circumstances command
+ant's motion for summary judgment, that
+a different course."
+plaintiff's contract with defendant called
+for shipment of goods to specified place
+Appellants argue that the district court in foreign country rather than to place
+was prohibited from granting the injunc- in United States to which defendant detions by § 2283 of Title 28, relating to in- livered the goods, do not pose a genuine
+n a State issue of material fact and was insufficient
+court. As we said in Alesna Rice, sue to prevent award of summary judgment
+pra, we find it unnecessary to consider this 2 Carriers e=84
+question here.
+If plaintiff's contract with railroad
+The rules expressed
+supra, and in Alesna
+Babcock Noh, for shipment of goods by railroad called
+Rice, supta, required the district cour
+: to deny the infor delivery at specified place in foreign
+junctions prayed for.
+The judgments are
+country, but plaintiff authorized plaintiff's
+agent to take delivery of goods in United
+reversed with directions to dismiss the
+suits.
+States, defendant was justified in delivering
+goods to plaintiff's agent in United States
+and could not be held liable for misdelivery
+of goods.
+BROOKS v. PENNSYLVANIA R. CO.
+No. 199, Docket 21917.
+United States Court of Appeals
+Second Circult.
+Reverend John R. Brooks, pro se.
+Bleakley,
+Platt, Gilchrist
+& Walker,
+New York City, Dennis P. Donovan and
+Robert L. Conkling, New York City, of
+counsel, for appellee.
+Before SWAN, CHASE and FRANK,
+Circuit Judges.
+PER CURIAM.
+Decided March 28, 1951.
+Plaintiff appeals from a summary judg-
+John R. Brooks brought an actlon against ment which dismissed his complaint in an
+the Pennsylvanla Rallroad Company for mis action against the Pennsylvania Railroad
+dellvery of goods shipped on a straight bill Company for alleged misdelivery of houseof lading lesued by defendant.
+The Unlted hold goods transported under a straight
+States District Court for the Boothern Die bill of lading in which plaintift was named
+trict of New York, entered a summary judgment which dismissed the complaint and the
+as both consignor and consignee. Defendplaintiff appealed. The Court of Appeals,
+ant moved for summary judgment on the
+Per Curiam, beld that allegatlon in plain. grounds that (1) the uncontradicted evitit's affidavit submitted in opposition to mo- dence showed that proper delivery had been
+tion for summary judgment did not pose a made; and that (2) the action was barred
+genuine issue of material fact and was Insuf. by res judicata. The lower court held that
+
+
+644
+181 FEDERAL REPORTER, 2d SERIES
+The exhibited letter plainly threatens
+sentence and to viet in me aiate fis injury eshie ed esse plain Cobrates.
+lease. from prison.
+San Francisco, California, and
+There were nine counts in the indictevinces the manifest intent to extort money
+ment, all charging appellant's violation of from the addressee.
+section 338a, subdivision (a), of Title 18
+he order of the district court denyil
+nited States Code [1948 Revised Crim• the motion of appellant is affirme
+inal Code, 18 U.S.C.A. § 876], in wilfully
+with intent to extort money, threatening to
+injure, and knowingly and with intent to
+extort money depositing in the United
+States Post Office letters containing threats
+to injure the person of the addressee.
+On motion of the United States Attorney,
+all counts of the indictment except the ninth
+count were dismissed. The defendant was
+CITY OF MIAMI | SUTTON ot al.
+found guilty on that count and was sen-
+No. 13113.
+tenced to fifteen years imprisonment. The
+United States Court of Appeals
+only material issue before us is whether
+Fitth Circult.
+the single count upon which the conviction
+April 25, 1050.
+rested states an offense.
+It is clear that it
+does.
+Even without inclusion of the first
+Durward B. Sutton and Sarnh R. Sutton.
+numbered paragraph of the ninth count, the
+dolng business ns the Sutton Jeweles Comoffense condemned is plainly charged, in
+pany brought suit against the City of Minni
+that averment is made that the defendant
+to
+enjoin enforcement of eity ordinance
+"did, on or about the 3rd day of May, 1948,
+which would have effect of preventing plaintiffs from holding proposed jewelry auctions
+in the City of Canton,
+County of Stark,
+between the hours of six in the evening and
+State and Northern
+eight in the morning, on ground that ord!-
+and there knowingly and with intent to exnance, as applicable to them, violated protort noney from Joe Cohen deposit and
+visions of the federal constitution, and for
+cause to be deposited in a Post Office of
+a declaratory decree.
+The United States
+the United States, to-wit,
+the Post Office
+Distriet Court for the Southern Distriet of
+at Canton, Ohio, to be sent and delivered
+Florida, John W. Holland, J., rendered a
+by the
+Post Office establishment of the
+Judgment for the plaintiffs, and the defend-
+United States, a letter and communication
+ants appealed.
+The Court of Appeals, Russell, Circult Judge, held that plaintiffs were
+postmarked
+Ohio, May 3, 1948,
+not entitled to Injunctive relief.
+addressed to the said Joe Cohen and con-
+Judginent reversed with directions to distaining a threat to injure the person of
+the said addressee,
+and communication was then and there
+I. Declaratory Judgment *128
+enclosed in a sealed envelope, postage pre-
+Injunction e=85(2)
+paid, a true copy of which envelope is
+Those operating a jewelry store were
+marked Exhibit "Q", attached hereto, and
+not entitled to a declaratory judgment or
+by reference made a part hereof; that a
+to injunction from federal district court
+true copy of said letter and communication enjoining city from enforcing ordinance
+is marked Exhibit "R", attached hereto, which would have effect of preventing
+and by reference made a part hereof; that them from holding proposed jewelry aucsaid letter and communication was duly tions at their establishd place of business
+carried by the United States mail for de- between the hours of six in the evening
+livery into the City and County of San and eight in the morning, on ground that
+Francisco, Southern Division of the North- ordinance, as applicable to them, violated
+ern District of California, according to provisions of the federal Constitution be
+the direction thereon."
+cause they would be subject to multiple
+
+
+645
+Cite as 181 F.
+fines and imprisonments under the ordi- tional circumstances and upon clear shownance and would allegedly suffer damage ing that an injunction is necessary to pre-
+Amends. 4, 14.
+9. Courts $=508(7)
+2. Injunction &=105(l)
+In the exercise of the sound discretion
+Equity courts do not ordinarily restrain
+which guides the determination of federal
+criminal prosecutions.
+equity courts, scrupulous regard must be
+had for the rightful independence of state
+3. Criminal faw &-31
+Immunity from prosecution in good
+governments, and a remedy infringing that
+independence which might otherwise be
+faith for his alleged criminal acts is not
+given should be withheld if sought on slight
+accorded to any citizen or member of the
+or inconsequential grounds.
+community.
+10. Declaratory Judgment $-387
+4. Injunetion 105(1)
+Injunction 105(2)
+The imminence of a criminal prosecu-
+The restrictions on the propriety of the
+tion, even though alleged to be unauthorized
+grant by a federal court of an injunction
+and hence unlawful, is not alone ground for to restrain institution of prosecutions for
+relief in equity which exerts its extraordi- violations of state or municipal penal laws
+nary powers only to prevent irreparable inare in no wise relaxed because application
+jury to the plaintiff who seeks its aid.
+for an injunction may be presented along
+5. Courts 508(7)
+with a request for a declaratory decree.
+The imminence of a criminal prosecu- 11. Declaratory Judgment 8-128
+tion, even though alleged to be unauthorized
+Where issuance of an injunction was
+and hence unlawful, is not alone ground for the only means by which a declaration of
+relief in a federal equity court particularly
+rights as to the constitutionality of city
+where the only threatened action is the
+ordinance as applied to plaintiffs could
+prosecution in the state courts by state offi- effectively be enforced or bring about a
+cers of an alleged violation of state law termination of the controversy, the legal
+with the resulting final and authoritative impossibility of obtaining such injunctive
+determination of the disputed question
+relief rendered a declaration advisory only
+whether the act complained of is lawful-or
+and therefore futile to effectuate a settleunlawful,
+ment of the controversy.
+6. Courts $-508(7)
+The federal courts are without jurisdiction to try alleged criminal violation of
+John D. Marsh, Asst. City Atty., J. W.
+Watson, Jr., City Atty, Miami, Fla., for
+7. Courts 489(2)
+The state courts are the final arbiters
+George C. McCaughan, Miami, Fla., and
+of the meaning and appropriate application
+Arthur A. Kimmel, Miami Beach, Fla., for
+of state statutes, subject only to review by
+appellees.
+the United States Supreme Court if such
+Morris Berick, Herbert S. Shapiro an
+construction or application is appropriately Richard E. Gerstein, Miami Beach, Fla.
+challenged on constitutional grounds.
+for amicus curiae.
+3. Courts e-508(7)
+Before HUTCHESON, Chief Judge, and
+Interference with the process of the WALLER and RUSSELL, Circuit Judges
+criminal law in state courts, in whose control they are lodged by the constitution, and RUSSELL, Circuit Judge.
+the determination of questions of criminal
+The City of Miami, appellant here, and
+
+
+616
+181 FEDERAL REPORTER, 2d SERIES
+City's Ordinance No. 3535 against Dur- ishing of detailed reports of operations by
+ward B. Sutton and Sarah B. Sutton, doing permittees; and subjects violators to a fine
+this appeal the City contends that the Court
+2553
+of not exceeding $500.00 or imprisonment
+not to exceed 60 days, or both." The comerred in exercising jurisdiction, in granting
+plaint specifically concedes that fraud is
+the injunction, and in denying the appellikely to occur at auction sales of diamonds,
+lant's motion to dismiss. Under the facts jewelry and other like articles conducted
+of this case and the law properly apafter nightfall and by artificial light durplicable thereto, we sustain the contention
+ing the excitement of competitive bidding.
+that the Court erred in overruling the mowhen the high bid is final without opportion to dismiss, and in granting an injunc- tunity for daylight inspection and examination.
+tion.
+Indeed the selection and proposed
+The complaint of the appellees, seeking
+adoption of "appellees' detailed method" is
+a declaratory decree and injunctive relief,
+said to be prompted by the desire to elimioutlined what was denominated a "unique nate the possibility of fraud or deception.
+method of doing business and electing
+Appellees set forth as the controversy besales" of jewelry and other related mertween the partics their contention that the
+chandise, which while it concededly has provisions of the ordinance, and particularsome of the features of a "publie auction" ly specified sections thereof, are not applisale is "materially different from such auc- cable to their proposed method of doing
+tion sales in important respects," these
+business, but if so, are violative of the
+claimed differences in law and fact being
+provisions of Amendment 4 and Amendfully stated.* It is alleged that the appellees
+ment 14 of the Constitution of the United
+had prepared for inaugurating the proposed
+States, whereas the City contends and asmethod of sales by acquiring a substantial
+serts that the ordinance is applicable to apstock of articles, the disposal of which was
+pellee's detailed method of doing business,
+prevented by the threat of a series of vexaand the ordinance and all of its provision
+tious arrests, any one of which would iris constitutional. The officials of defendant
+reparably damage the good reputation of
+have "threatened to arrest the plaintiffs and
+the complainants which they had enjoyed * • * all of their employees and charge
+in the community since 1925; and that the each of them with a violation of the provithreatened and intended enforcement of
+sions of such ordinance if and when they
+the ordinance had injuriously restricted
+should
+conduct their
+business
+them in their business and resulted in a
+within the corporate limits of said defenddiminution of their profits.
+ant municipality between the hours of six
+A copy of Ordinance No. 3535 of the
+in the evening of any day and eight in the
+City of Miami, attached as an exhibit to
+morning of the following day, and if and
+the complaint, provides stringent regulawhen the plaintiffs employ in the conduct
+tions governing the sale and offer to sell
+of their business the methods detailed hereof jewelry, watches and diamonds at pubinabove.
+***" The appellees prayed
+lic auction" and requires the securing of a
+that the Court decree the provisions of the
+permit to conduct such auction; the furnordinance and the specific provisions re-
+I. It is stated in the briefs that this
+proposed plan would in operation aud
+egal effect be the same as th
+Polind apheld in Zacnick City o
+Tollywood, D.C., 85 F.Supp. i
+he contentions now urged were approve
+by the trial Court in the present case
+and the enforcement of an ordinance
+dentical with Miami's #8535 enjoined
+* is apparent that the plan of sale
+proposed to be adopted by the complainants in in substantial accord with
+the discussion and rulings of the Court
+there made.
+2. A similar ordinance has been upheld by
+the Florida Courts. The opinion in
+Zaconick v. City of Hollywood, supra,
+ens Bey 1060, 1a 459, 15
+Stone), 97 Fia. 138, 121
+So. 585, 560, held "a municipal ordinance
+certain classes of merchandise."
+
+
+CITY OF MIAMI Y. BUTTON
+647
+Cite as 181 F.2d 644
+ferred to as not applicable to the plaintiffs tive relief; that the complainants had a
+and their proposed method of conduct of complete and adequate remedy at law in the
+their business; or if the Court holds the courts of the State of Florida; that there
+provisions of such ordinance applicable to
+was no such showing of irreparable injury
+the plaintiffs and such methods, it declare
+as would warrant the issuance of an inand decree such ordinance unconstitutional junction; and that the ordinance was valid
+and enjoin and restrain the municipality
+and constitutional. On the same day the
+and its officers from enforcing or attempt-
+Court, after a hearing, granted an injuncing to enforce the ordinance during the
+tion upon terms and provisions as in the
+pendency of the cause or until the further
+order set forth? On January 16th, upon a
+order of the Court, and that upon the final further hearing, the motion to dismiss the
+hearing the injunction be made permanent.
+complaint was ordered denied and the de-
+Eight days after the filing of the com- fendant granted twenty days within which
+plaint the municipality responded with a
+motion to dismiss on the grounds: that no
+[1] The temporary injunction issued in
+federal question was involved; that there this case had factual support only in the alwas no matter stated warranting injunc- legations of the complaint. There was in
+3. "It is Ordered and Decreed herein as
+follows:
+"J. That on the plaintills" compliance
+with the provisions of the paragraph
+hereof numbered 2, and the subject to
+the provisions of the paragraph hereof
+numbered 3, the defendant municipality,
+and each of its officers, agenta, servanta
+and employes be, and they hereby are,
+enjoined and restrained until the further
+order of the Court, from enforcing or attempting to enforeo against the plaintiffs
+any of the provisiona of that certain ordinance of the defendant municipality. towit:
+Ordinance #3335,
+dated
+April 7,
+1948.
+-#2.
+That the plnintiffs be,
+and they
+hereby are, required to file herein a good
+and sufficient bond in the penal sum of
+$1000.00 with good and sufficient surety
+or sureties.
+payable
+to
+the
+and conditioned that the plaintiff will pay,
+or cause to be paid, to the defendant, it
+and in the erent the plaintiffs' application
+for this injunetive order shall be later
+held to baro been wrongful, all costs,
+damages and expenses (including reasonable attorney's fces) which the defendaut shall pay or incur and
+which shall
+result from,
+or be ocensioned by, stel
+wrongful application; and the injunctive
+provisions of the paragraph bereof ammbered 1, shall not become or be effective
+unless and until the plaintiffs have filed,
+and the Clerk of this Court shall have
+approved suel bonds.
+character of which are set forth in their
+hereby are, furtber required (a) to inforra and advise all prospective or potential purchasers, prior to offering
+any
+article for sale, of the conditione or provisions subject to which any proposal to
+buy such article is to be accepted by the
+plaintiffs;
+(b) to prominently display.
+at all times, in their place of business a
+notice or bulletin in and by which progpective or potential purchasers shall be
+effectively and adequately Informed and
+advised of the plaintiffs' methods of do-
+Ing baainess (as outlined and detailed
+in their complaint); and (e) to furnish
+and deliver
+to each prospective or potential purchaser, whose conditional or
+provisional
+proposal to buy any article,
+offered for sale by the plaintills shali
+have been accepted by him, a written or
+printed memorandum in and by which
+the plaintifie shall legally and effectively
+bind themselves contractually to refund
+to him or her the full amount of the
+purchase price of such article conditionally and provisionally paid to or deposited
+with the
+plaintiffs by
+such prospective
+or potential purchaser if and in the event
+he or she, at any time within thirty days
+after the submission of such conditional
+or provisional proposal, with or without
+the araignment of any reason or excuse
+for doing so, shall redeliver such article,
+in the samue condition it was in at the
+time of the delivery to such prospective
+or potential porchaser, to the plaintiffs
+and request such refund; and the applicability and effectivenese of the injunctive provisions of the paragraph
+hereof number 1, are dependent and conditioned on striet complianee by the plaintiffe with the provisions of this paragraph."
+
+
+181 FEDERAL REPORTER, 24 SERIES
+opposition the defendant's motion to dis- the law "where a man's fate depends on his
+While for the purposes of the motion
+estimating rightly, that is, as the jury subto dismiss, the factual allegations of the
+sequently estimates it, some matter of decomplaint may be taken as true, this is
+gree. If his judgment is wrong, not only
+nevertheless not the preferable foundation
+may he incur a fine or a short imprisonfor the issuance of an injunction against
+may incur the penalty of
+the institution of a prosecution for violadeath; Nash • . United States, 229 U.S
+tion of a municipal ordinance. Regardless
+373, 377, 33 S.C
+t. 780, 781, 57 L.Ed. 1232
+of this, however, the facts which may be
+The complaint presents no ground authorconsidered as thus established are insuffi- izing the issuance of an injunction to precient to authorize the issuance of an injunevent multiple prosecutions.
+tion. The complaint fails to show "the im-
+[2-9] The law applicable to the
+minence and immediacy of proposed ention here is elearly stated in Beal tis
+forcement, the nature of the threats actualsouri Pacific R. Corp. 312 U.S. 45, 6
+ly made, and the exceptional and irrepara-
+418, 420, 85 L.Ed. 577, as follows:
+ble injury which [the complainant] would
+sustain if those threats were carried out."
+"It is a familiar rule that courts of equity
+Watson | Buck, 313 U.S. 387, 61 S.Ct. 962
+do not ordinarily restrain criminal prosecu-
+966, 85 LEd. 1416. Particularly here there
+In re Sawyer, 124 U.S. 200, 211, 8
+is and can be no showing of irreparable in-
+S.Cr. 482, 488, 31 L.Ed. 402; Davis & Far
+jury, for there is not even a claim of innum Mfg. Co. - City of Los Angeles, 18
+jury to complainants' established and going
+U.S. 207, 23 S.
+Ct. 498. 47 L..Ed. 778; Hy-
+business, but merely a claim that the hazgrade Provision Co. | Sherman, 266 U.S.
+ards posed by the contemplated enforcement
+497, 500, 45 S.Ct. 141, 69 L.Ed. 402.
+of the ordinance prevents complainants
+citizen or member of the community is imfrom embarking upon a new enterprise,
+mune from prosecution, in good faith, for
+from trying out, it may be said, their prohis alleged criminal acts, The imminence
+posed unique method of merchandising
+of such a prosecution even though alleged
+The only loss which the complainants could
+to be unauthorized and hence unlawful is
+sustain is speculative, dependent upon what,
+not alone ground for relief in equity which
+if any, profits they might make if they are
+exerts its extraordinary powers only to
+permitted to begin and carry on the conduct
+revent irrepaid Terrace Thompson
+of their sales in the manner which they aswho seeks its aid.
+sert is legal. They are not disturbed in any
+25 Packara Baton, 26 US. 680,15
+feature of their business dealings which
+they allege they have conducted since 1925.
+44 S.Ct. 257, 258, 68 LEd. 596; Tyson &
+Since there is no danger to their already
+Bro. Un U.S 718 4e 47 S.C1. 428 27,71
+established business, but merely apprehenton, 273 U.S. 418, 428, 47 S.Ct. 426-
+sion of punishment for, and prospective loss
+L.Ed. 718, 58 A.L.R. 1236; Cline Frink
+of profits in being prevented from, carrying
+Dairy Co., 274 U.S. 445, 452, 47 S.tt. 681,
+on their proposed new method of sale, the
+question of apprehended multiple prosecutions could only arise upon continued and only threatened action is the prosecution in
+persistent engagement in the new business the state courts by state officers of an alin disregard of the adjudications by the leged violation of state law, with the resultmunicipal or state courts in which the ques- ing final and authoritative determination of
+tion of the legality of the proposed business the disputed question whether the act comshould properly be made.
+hey are ronfronted with the necessity of rader of adey, 172 os. ma, iS.. t
+Cuties operation al within the repa gog, 20 in or 080,
+tions of the ordinance, but the situation is 79 L.Ed. 1322. The federal courts arc
+no different from numerous instances in without jurisdiction to try alleged criminal
+
+
+CITY OF MIAMI Y. BUTTON
+619
+Cite as 181 F.2d 644
+violations of state
+statutes.
+The state ly determination of what practice or means
+courts are the final arbiters of their mean- of operation would result in a violation of
+ing and appropriate application, subject the ordinance was in effect removed from
+only to review by this Court if such con- the jurisdiction and control of the municistruction or application is appropriately pal or state courts, and opportunity for
+the Court of the matter of noncompliance
+"Hence interference with the processes
+with the Court's order by a request for
+of the criminal law in state courts, in whose
+of the restraining order.
+control they are lodged by the Constitution,
+Thereby jurisdiction of the violation of the
+and the determination of questions of crimiordinance was, for all practical purposes,
+nal liability under state law by federal
+removed from the municipal or state courts
+courts of equity can be justified only in
+to the federal court, but with the appellees
+most exceptional circumstances, and upon
+left immune from any penalty for violaclear showing that an injunction is necestion of the City Ordinance; and in case of
+any violation of the restrictions of the decree, only subject to the loss of the protec-
+Frink Dairy Co., supra;
+tion the decree provided when and if the
+Spielman Motor Sales Co. i
+. Dodge, supra.
+city might secure a dissolution of the inwhich guides the determination of courts
+[10] The restrictions upon the propriety
+of equity, scrupulous regard must be had
+of the grant by a federal court of an injunefor the rightful independence of state gov- tion to restrain the institution of prosecuernments and a remedy infringing that in- tions for violations of state or municipal
+dependence which might otherwise be given penal laws are in nowise relaxed because
+should be withheld if sought on slight or
+the application for an injunction may be
+inconsequential grounds. Di Giovanniv.
+presented to the Court along with a re-
+Camden Fire Insurance Ass'n, 296 U.S. 64,
+quest for a declaratory decree.
+73, 56 S.Ct. 1, 5, 80 L,Ed
+47, and cases cited." Sec also, Watson Buck, supra.
+"[11] Since the issuance of an injunetion is the only means by which any declara-
+These principles are even more applica- tion of rights could effectively be enforced
+ble here where there is no substantial con- or bring about a termination of the controtention that the City Ordinance, when ap- versy, the legal impossibility of obtaining
+plied to the subject matter which it purports
+such injunctive relief renders a declaration
+to encompass,
+is unconstitutional as such,
+advisory only' and therefore futile to effecbecomes so. when
+tuate a settlement of the controversy. The
+the complainants in the conduct of their
+opinion and decree of the federal court
+proposed business.
+Nevertheless, under
+would not be res adjudicate in any subsethese circumstances, appellees were granted
+quent criminal proceeding in the municipal
+by the issuance of the injunction, in effect,
+or state court, and the matter of the accep-
+a determination
+tance of the
+federal court's declaration
+method presented to the Court as a proposed would be at last left solely to the volunplan of operation in the future was not
+tary determination of the municipal authorwithin the terms of the ordinance, and
+herefore that the municipality would no
+e refore tha to be mum splay male of Thy granted try complain out tan
+the conduct of the complainants' business heen dismissed. The judgments are re
+(which of course could be determinable versed with directions to dismiss it.
+only after it had been begun). Consequent-
+
+
+
+(Cite as: 137 F.2d 71)
+SPENCE I COLE
+C.A.4 1943.
+Circuit Court of Appeals, Fourth Circuit.
+SPENCE, Chief of Police,
+COLE et al.
+No. 5082.
+106k508(7)
+k.
+Criminal
+Proceedings. Most Cited Cases
+That enforcement of ordinance against plaintiffs
+would constitute a violation of their constitutional
+rights did not entitle plaintiffs to an injunction
+where there was no showing of such irreparable
+injury as would warrant a court of equity in
+restraining criminal prosecutions and there was no
+reason to think that state courts would not protect
+constitutional rights of plaintiffs upon such
+July 14, 1943.
+5. Courts 508(7) The arrest by federal courts of the
+processes of the criminal law within the states, and
+the determination of questions of criminal liability
+under state law by federal court of equity, are to be
+supported only on a showing of danger of
+irreparable injury both great and immediate.
+[2] Injunction 212 €- 105(1)
+212 Injunction
+21211 Subjects of Protection and Relief
+212I1(H) Matters Relating to Criminal Acts
+212k105 Criminal Prosecutions
+Appeal from the District Court of the United States
+Cases
+212k105(1) k. In General. Most Cited
+for the Eastern District of North Carolina,
+Courts of equity do not ordinarily restrain criminal
+Elizabeth City; Isaac M. Meekins, Judge.
+prosecutions.
+Action by Andrew E. Cole, A. K. Smith and Everett
+13] Injunction
+9105(2)
+B. Costner against Walter W. Spence, Chief of
+Police of Elizabeth City, N.C., to enjoin the
+212 Injunction
+defendant from arresting or interfering with
+212I1 Subjects of Protection and Relief
+plaintiffs in preaching the gospel or in distributing
+212II(H) Matters Relating to Criminal Acts
+booklets, tracts and pamphlets used by them for the
+212k105 Criminal Prosecutions
+purpose of stimulating private Bible study. From a
+212k105(2) k. Invalidity of Statute or
+judgment for plaintiffs, the defendant appeals.
+Ordinance. Most Cited Cases
+Reversed.
+West Headnotes
+[1] Courts 106 €- 508(7)
+Ton a in though ind
+No person is immune from prosecution in good
+prosecution though alleged to be in violation of
+constitutional guaranties is not a ground for equity
+relief, since lawfulness or constitutionality of a
+106 Courts
+statute or ordinance on which the prosecution is
+06VII Concurrent and Conflicting Jurisdictio
+based may be determined as readily in the criminal
+06VII(B) State Courts and United State
+case as in a suit for an injunction.
+Courts
+106k508 Injunction by United States
+14] Courts 106 C-508(7)
+Court Against Proceedings in State Court
+106k508(2)
+Restraining
+Particular
+106 Courts
+Proceedings
+106VII Concurrent and Conflicting Jurisdiction
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=...
+
+
+
+(Cite as: 137 F.2d 71)
+106VII(B) State Courts and United States
+Courts
+106k508 Injunction by United States
+Court Against Proceedings in State Court
+106k508(2)
+Restraining Particular
+Proceedings
+106k508(7) k. Criminal
+Proceedings. Most Cited Cases
+for alleged violation of a state law, the state courts
+are yet final arbiters of is paring code or cried,
+States on federal grounds appropriately asserted.
+15] Courts 106 €-508(7)
+106 Courts
+106VII Concurrent and Conflicting Jurisdiction
+106VII(B) State Courts and United States
+Courts
+106k508 Injunction by United States
+Court Against Proceedings in State Court
+106k508(2)
+Restraining Particular
+Proceedings
+106k508(7)
+Proceedings. Most Cited Cases
+k. Criminal
+118AI(A) Rights in General
+118Ak84 k. Criminal Laws. Most Cited
+federal court of equity, are to be supported only on
+a showing of danger of irreparable injury both great
+and immediate.
+[6] Declaratory Judgment 118A €-5.1
+118A Declaratory Judgment
+118AI Nature and Grounds in General
+118AI(A) In General
+118Ak5 Discretion of Court
+118Ak5.1 k. In General. Most Cited
+Cases
+(Formerly 118Ak5, 13k6)
+The granting of a declaratory judgment is a matter
+resting in the sound discretion of the court.
+17| Declaratory Judgment 118A €-84
+118A Declaratory Judgment
+118AIl Subjects of Declaratory Relief
+*72 John H. Hall, of Elizabeth City, N.C. (J. W
+Jennette, of Elizabeth City, N.C., on the brief), fo
+appellant.
+Hayden C. Covington, of Brooklyn, N.Y., for
+appellees.
+Before PARKER, SOPER, and NORTHCOTT,
+Circuit Judges.
+PER CURIAM.
+This is an appeal from a decree enjoining the Chief
+of Police of Elizabeth City, N.C., from arresting or
+interfering with plaintiffs in preaching the Gospel or
+in distributing booklets, tracts and pamphlets used
+by them for the purpose of stimulating private Bible
+study. Plaintiffs are members of the sect known as
+Jehovah's Witnesses. They were threatened with
+prosecution by defendant for violating an ordinance
+of Elizabeth City which declared it to be a nuisance
+solicitors, peddlers,
+hawkers,
+merchants or transient vendors of merchandise to go
+in or upon private residences or premises, without
+the request or invitation of the owners or occupants,
+for the purpose of soliciting orders for goods, wares
+and merchandise or peddling, hawking or disposing
+of same. The evidence showed that plaintiffs had
+been going from house to house in the city
+distributing the pamphlets of their sect and seeking
+to collect a small sum of money therefor. The
+judge below held that their activities did not
+constitute a violation of the ordinance, but that
+defendant was attempting to enforce it against them
+in such way as to violate their constitutional rights.
+The injunction granted did not enjoin the
+prosecution of criminal cases already pending in
+which plaintiffs were being prosecuted for violation
+of the ordinance, but restrained future prosecutions.
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=... 12/27/2007
+
+
+
+(Cite as: 137 F.2d 71)
+[1][2][3][4][5] We may assure that the enforcement
+of the ordinance against plaintiffs under the
+circumstances here disclosed would constitute
+violation of their constitutional rights. Murdock I
+Commonwealth of Pennsylvania, 63 S.Ct. 870, 87
+L.Ed. .... But it does not follow that plaintiffs are
+entitled to the injunction granted them below.
+There was no showing of such irreparable injury as
+would warrant a court of equity in restraining
+criminal prosecutions; and there is no reason to
+think that the state courts would not protect the
+constitutional rights of plaintiffs upon such
+prosecutions being instituted.*73 The case is
+clearly one for the application of the rulenlaid do or
+by the Supreme Court
+Douglas
+Jeannette, 63 S.Ct. 877, 881, 87 L.Ed.
+follows: It is a familiar rule that courts of equity do
+not ordinarily restrain criminal prosecutions. No
+person is immune from prosecution in good faith for
+his
+alleged criminal
+acts.
+Its
+imminence,
+even
+though alleged to be in violation of constitutional
+guaranties, is not a ground for equity relief since the
+lawfulness
+constitutionality
+determined rich thin the crion is based may be
+rights. The granting of a declaratory judgment,
+however, is a matter resting in the sound discretic
+of the court (Aetna Casualty & Surety Co.
+Quarles, 4 Cir., 92 F.2d 321); and it is clear that the
+discretion ought not be exercised in a case of this
+character where its only effect would be to decide
+matters, as pointed out in the quotation above,
+which could be better decided in the criminal courts
+of the state. This is particularly true in view of the
+fact that criminal actions are pending against
+plaintiffs in the state courts involving the identical
+questions as to which plaintiffs ask a declaratory
+judgment. See Borchard Declaratory Judgments 2d
+ed. pp. 312, 653, 1022; Aetna Casualty & Surety
+Co. IL Quarles, supra.
+The decree appealed from will accordingly be
+reversed.
+Reversed.
+C.A.4 1943.
+137 F24 C0le
+L.Ed. 778;Fenner | Boykin, 271 U.S. 240, 46 S.Ct.
+492,
+70 L.Ed.
+927.
+Where
+the
+threatened
+prosecution is by state officers for alleged violations
+of a state law, the state courts are the final arbiters
+of its meaning and application, subject only to
+review
+this
+Court
+on
+federal
+grounds
+appropriately asserted.
+Hence the arrest by the
+federal courts of the processes of the criminal law
+within the states, and the determination of questions
+of criminal liability under state law by a federal
+court of equity, are to be supported only on a
+Miller, 317 U.S. 599, 63 S.Ct. 258, 87 L.Ed....."
+5][7] We are asked to hold that plaintifis a
+titled to a declaratory judgment establishing the
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=...
+
+
+
+JACOB HOFFMAN BREWING CO. I
+M'ELLIGOTT
+C.A.2 1919.
+Circuit Court of Appeals, Second Circuit
+IACOB HOFFMAN BREWING CO.
+McELLIGOTT, Deputy Internal Revenue Collector
+tal. CLAUSEN-FLANAGAN BREWERY I
+SAME. RUPPERT I SAME.
+June 28, 1919.
+Rogers and Hough, Circuit Judges, dissenting in
+part.
+Three suits, by the Jacob Hoffman Brewing
+Company, by the Clausen-Flanagan Brewery, and
+by Jacob Ruppert, a corporation, respectively,
+against Richard J. McElligott, Acting and Deputy
+Collector of Internal Revenue, and Francis G.
+Caffey, United States Attorney for the Southern
+District of New York. From orders granting
+license or sell revenue stamps to concerns which it
+deputy collector may be enjoined from reverting to
+the original practice of the department.
+Injunction 212 €-105(1)
+212 Injunction
+212I1 Subjects of Protection and Relief
+212II(H) Matters Relating to Criminal Acts
+212k105 Criminal Prosecutions
+212k105(1) k. In General. Most Cited
+A federal district attorney cannot be enjoined from
+instituting
+criminal proceedings
+War-Time Prohibition Act of November 21, 1918,
+40 Stat. 1046, against concerns manufacturing and
+selling nonintoxicating beer, upon the ground that
+the attorney had transcended his authority by
+invoking the act against nonintoxicating liquors.
+Intoxicating Liquors 223 C-134
+detendants appeal. Affirmed as modified.
+West Headnotes
+Indictment and Information 210 €-28
+223 Intoxicating Liquors
+223VI Offenses
+23k133 Liquors Prohibite
+210 Indictment and Information
+210I1I Formal Requisites of Indictment
+210k27 Commencement
+210k28 k. In General. Most Cited Cases
+A criminal suit in the federal courts must be brought
+in the name of the United States and by the United
+States attorney.
+3k134 k. Description and Propertie
+Most Cited Cases
+The War-Time Prohibition Act of November 21,
+1918, 40 Stat. 1046, preventing the manufacture
+and sale of beer, wine and other intoxicating
+iquors, etc., refers only to beer and wine which i
+n fact intoxicating
+Injunction 212 €-75
+United States 393 € 125(3)
+212 Injunction
+393 United States
+212I1 Subjects of Protection and Relief
+393IX Actions
+212I|(E) Public Officers and Entitie:
+393k125 Liability and Consent of United
+212k75 k. State or National Boards anc
+States to Be Sued
+Officers. Most Cited Cases
+393k125(3)k. Necessity of Waiver or
+Where the Internal Revenue Department refused to
+Consent. Most Cited Cases
+
+
+
+United States can only be sued by own consent.
+United States 393 € 125(28.1)
+393 United States
+393IX Actions
+393k125 Liability and Consent of United
+States to Be Sued
+393k125(28)
+Particular Departments,
+Officers, or Agencies, Suits Against
+393k125(28.1) k. In General. Most
+Cited Cases
+(Formerly 393k125(28))
+A suit to enjoin a United States attorney from
+instituting criminal proceedings under a federal
+statute is a suit against the United States, which
+threatened with irreparable damage, and the statute
+transcending his authority under a valid statute.
+*525 Francis G. Caffey, U.S. Atty., of New York
+City (William C. Fitts. Vincent H. Rothwell, and
+Comelius J. Smyth, all of New York City, of
+counsel), for appellants.
+Root, Clark, Buckner & Howland, of New York
+City (Elihu Root and William D. Guthrie, both of
+New York City, of counsel), for appellee Jacob
+Hoffman Brewing Co.
+Guggenheimer, Untermyer & Marshall, of New
+York City (Elihu Root and William D. Guthrie,
+both of New York City, of counsel), for appellee
+Clausen-Flanagan Brewery.
+*526 Fitch & Grant, of New York City (Elihu Root
+and William D. Guthrie, both of New York City, of
+counsel), for appellee Jacob Ruppert.
+Before WARD, ROGERS, and HOUGH, Circuit
+Judges.
+WARD, Circuit Judge.
+These three cases involve the same question, and in
+each the appeal is from an order of the District
+Court of the United States for the Southern District
+of New York restraining, pending final hearing, the
+defendant McElligott, Acting and Deputy Collector
+of Internal Revenue of the Third District of New
+York, from refusing to issue licenses to the
+complainants as brewers of beer, or to issue revenue
+stamps in respect to their beer, provided they pay or
+duly tender the taxes required by law, and
+restraining the defendant Caffey, United States
+Attorney for the Southern District of New York,
+from arresting or prosecuting the complainants,
+their officers, agents, servants, etc., or from
+enforcing forfeiture of their property for failure to
+affix revenue stamps to their barrels of beer when
+such failure is due to the refusal of the defendant
+McElligott to issue the same, and from enforcing
+the pains and penalties of the act of November 21,
+1918, c. 212, 40 Stat. 1046, by arresting or
+prosecuting the complainants, their officers, agents,
+The complainants are brewers of beer made from
+malt with an alcoholic content not exceeding 2.75
+per cent. by weight, and the rights of the parties in
+connection with the orders appealed from depend
+upon the act of Congress of November 21, 1918,
+the relevant portions of which are:
+*That after June 30, 1919, until the conclusion of
+the present war and thereafter until the termination
+of demobilization,
+the date of which shall be
+determined and proclaimed by the President of the
+United States, for the purpose of conserving the
+man power of the nation, and to increase efficiency
+in the production of arms, munitions, ships, food,
+and clothing for the army and navy, it shall be
+unlawful to sell for beverage purposes any distilled
+spirits, and during said time no distilled spirits held
+in bond shall be removed therefrom for beverage
+purposes except for export. After May 1, 1919,
+until the conclusion of the present war and
+thereafter until the termination of demobilization,
+the
+date of which shall be determined and
+proclaimed by the President of the United States, no
+grains, cereals, fruit, or other food product shall be
+used in the manufacture or production of beer,
+wine, or other intoxicating malt or vinous liquor for
+beverage purposes. After June 30, 1919, until the
+conclusion of the present war and thereafter until
+the termination of demobilization, the date of which
+shall be determined and proclaimed by the
+President of the United States, no beer, wine, or
+other intoxicating malt or vinous liquor shall be
+sold for beverage purposes except for export. The
+Commissioner of Internal Revenue is hereby
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=.. 12/27/2007
+
+
+
+authorized and directed to prescribe rules and
+act shall cease to operate, for other than beverage
+jurisdiction Geard i chi, its. 3, beyond is.
+2, 60 L.Ed. 114), or to deal with any attack upon or
+ice with the complainants' property (United
+States _ Lee, 106 U.S. 196, 1 Sup.Ct. 240, 27
+L.Ed. 171), or of confiscation of it, as in the Rate
+It is perfectly well settled that the United States
+may not be sued, except upon its own consent
+Such consent it has given by various statutes whic
+this act no distilled, malt, vinous, or other
+intoxicating liquors shall be imported into the
+United States during the continuance of the present
+war and period of demobilization: Provided, that
+this provision against importation shall not apply to
+shipments en route to the United States at the time
+of the passage of this act.
+*527 'Any person who violates any of the
+foregoing
+provisions
+shall be punished by
+imprisonment not exceeding one year, or by fine not
+exceeding $1,000, or by both such imprisonment
+and fine.
+***c
+Originally the Internal Revenue Department took
+the position that after May 1, 1919, it would not
+license brewers who manufactured beer with an
+alcoholic content equaling or exceeding one-half of
+1 per cent. by volume, nor sell the revenue stamps
+to be affixed to barrels of such beer; but afterwards,
+by advice of the Attorney-General, this position was
+abandoned, and the department consented to license
+brewers and to sell them revenue stamps, even if
+their beer did contain an alcoholic content equaling
+or exceeding one-half of 1 per cent. by volume.
+Accordingly the complainants are not now subject
+to any forfeiture or penalty under the internal
+revenue acts if they pay the taxes required by law.
+The only risk they are exposed to if they continue to
+brew beer of an alcoholic content not exceeding
+2.75 per cent. by weight is that of imprisonment for
+not more than one year, or a fine not exceeding
+$1,000, or both, if such manufacture be found to be
+a violation of the act of November 21, 1918.
+Nevertheless the injunction against the acting
+deputy collector, defendant, can do no harm, and, in
+view of the position originally taken by the Internal
+Revenue Department, it may go against him.
+In this case we have not to inquire whether an
+It is an attribute of every sovereign, recognized by
+all sovereigns. A criminal suit in the federal courts
+must be brought in the name of the United States,
+and can only be brought by the United States
+attorney. Confiscation Cases, 7 Wall 454, 457, 19
+L.Ed. 196. A suit in equity to enjoin the United
+proceedings under a statute of the United States is
+manifestly a suit against the United States. In such
+a case the United States is sued as effectively as if it
+were a defendant by name. There is, however, a
+well-recognized exception
+to the rule,
+property rights are invaded, and the statute
+question is unconstitutional, it is void, is to be
+treated as nonexistent, and so no defense to the
+United States attorney. When instituting criminal
+proceedings under it he is to be regarded not as
+representing the United States in his official
+capacity, but as acting individually. So if, under a
+valid statute, he threatens to proceed in a manner
+injurious to complainant's property rights, and not
+authorized by the statute,
+he transcends his
+authority, does not represent the United States, is
+not protected by the statute, and may be enjoined.
+Irreparable injury alone is not enough. Both these
+conditions must exist. Obviously *528 in such
+cases the constitutionality of the statute, or the
+question whether the United States attorney has
+transcended his authority, must be determined by
+the court before it can determine whether the
+particular suit is or is not against the United States.
+Mr. Justice Peckham said in Ex parte Young, 209
+U.S. 123, 159, 28 Sup.Ct. 441, 453 (52 L.Ed. 714,
+13 L.R.A.(N.S.) 932, 14 Ann.Cas. 764):
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=...
+
+
+
+Page 4
+*It is also argued that the only proceeding which the
+Attorney General could take to enforce the statute,
+so far as his office is concerned, was one by
+mandamus, which would be commenced by the
+state in its sovereign and governmental character,
+and that the right to bring such action is a necessary
+a sovereign government. It is
+contended that the complainants do not complain
+and they care nothing about any action which Mr.
+Young might take or bring as an ordinary
+individual, but that he was complained of as an
+officer to whose discretion is confided the use of the
+name of the state of Minnesota so far as litigation is
+concerned, and that when or how he shall use it is a
+matter resting in his discretion, and cannot be
+controlled by any court.
+"The answer to all this is the same as made in every
+case where an official claims to be acting under the
+authority of the state. The act to be enforced is
+alleged to be unconstitutional, and, if it be so, the
+the name of the state
+unconstitutional act to the injury of complainants is
+a proceeding without the authority of and one which
+affect the state in its sovereign or
+governmental capacity. It is simply an illegal act
+upon the part of a state official in attempting by the
+use of the name of the state to enforce a legislative
+enactment which is void because unconstitutional.
+If the act which the state Attorney General seeks to
+enforce be a violation of the federal Constitution,
+in proceeding under such enactment
+comes into conflict with the superior authority of
+that Constitution, and he is in that case stripped of
+or representative character, and is
+subjected in his person to the consequences of his
+individual conduct. The state has no power to
+impart to him any immunity from responsibility to
+the supreme authority of the United States. See In
+re Ayers, supra (123 U.S.)p. 507 (8 Sup.Ct. 164, 31
+L.Ed. 216). It would be an injury to complainant to
+harass it with a multiplicity of suits or litigation
+generally in an endeavor to enforce penalties under
+an unconstitutional enactment, and to prevent it
+ought to be within the jurisdiction of a court of
+equity. If the question of unconstitutionality with
+reference, at least, to the federal Constitution, be
+first raised in a federal court, that court, as we think
+is shown by the authorities cited hereafter, has the
+right to decide it, to the exclusion of all other courts.
+The act of November 21, 1918, is a war measure,
+constitutional as such, and by its express terms is to
+continue in force until a time which has not yet been
+reached, i.e., the conclusion of the present war and
+thereafter until the termination of demobilization,
+the date of which shall be determined and
+proclaimed by the President of the United States.
+Until such time it is the duty of the United States
+attorney, defendant, under section 771, United
+States Revised Statutes (Comp. St. Sec. 1296), to
+prosecute all delinquents for crimes and offenses
+The sole ground upon which the United States
+attorney, defendant in this case, is charged with
+transcending his authority is that he erroneously
+construes
+the
+statute
+in connection with the
+complainant's product, viz. as prohibiting the use of
+food products in the manufacture of any beer for
+beverage purposes after May 1, 1919, and the sale
+of such beer after June 30, 1919; whereas, the act,
+properly construed, prohibits only the manufacture
+and sale of such beer as is intoxicating, which the
+complainants' beer, containing not more than 2.75
+per cent. of alcohol by weight, is not.
+*529 Although we concur in the construction of the
+statute by the court below, and assume that the
+United States
+attorney
+will institute criminal
+proceedings, we do not think the court had power to
+stay him by injunction from doing so. The proper
+place for determining
+whether such criminal
+proceedings are maintainable is not in a court of
+equity, but upon an indictment tried in a criminal
+court before a jury. For any error then committed
+there will be an adequate remedy by writ of error.
+We recognize the importance of the interests at
+stake; that the complainants and others in like case,
+if not content to manufacture beer containing an
+alcoholic content not equaling or exceeding
+one-half of 1 per cent. by volume, must choose
+between discontinuing their business or carrying it
+on at the risk of punishment under the act of
+November 21, 1918, if they continue after May 1,
+1919, to manufacture, and after June 30, 1919, to
+sell, beer containing not more than 2.75 per cent. of
+
+
+
+alcohol by weight. The question, however, is not
+one of convenience or of discretion, but of the
+power of the court; and we think such an extension
+of judicial power, to meet what seems to be a hard
+case, to the domain of the executive department and
+of the courts of common law, would be an injury to
+our system of jurisprudence still more serious.
+This precise question was decided in accordance
+Page 5
+value and prevent its sale, yet a court of equity
+could not usurp the right of trial which both the
+state and the accused have in a common-law court
+before a jury. Every citizen must submit to such
+accusations,
+if lawfully made, looking to the
+vindication of an acquittal and such remedies as the
+law affords for the recovery of damages. It is often
+a great hardship to be wrongfully accused of crime,
+but it is one of the hardships which may result in the
+Day, who as Justice Day wrote the opinion in the
+Hammer Case, 247 U.S. 251, 38 Sup.Ct. 529, 62
+L.Ed. 1101, Ann. Cas. 1918E, 724, greatly relied
+upon by the complainants, and to be presently
+considered, said:
+*We are now dealing with an officer of a state
+proceeding under a valid law of the state, and
+whose error lies in wrongfully construing the statute
+right of trial by jury, by substituting a court of
+equity to inquire into the commission of offenses
+where it would have no jurisdiction to punish the
+parties if found guilty. It would be the extension of
+equity jurisdiction to cases where prosecutions in
+state courts by the state officers are sought to be
+enjoined, with a view to determining whether they
+shall be allowed to proceed under valid statutes in
+the courts of law. We think this an enlargement of
+the jurisdiction opposed to reason and authority. It
+is claimed, however, that conceding that a court of
+equity cannot enjoin the prosecution of criminal
+offenses, as a general thing, the rule is different
+when property rights are involved; and we are cited
+to cases holding that equity has jurisdiction to
+enjoin acts likely to be destructive of property
+rights, although the acts complained of constitute
+infractions of the criminal law. This is quite a
+different proposition from enjoining criminal
+proceedings alleged to be indirectly destructive of
+property rights. Many criminal prosecutions may
+affect the property of the person accused. A
+property may be greatly injured by the wrongful and
+unfounded charge that it is used for immoral
+purposes. Such prosecution may destroy its rental
+District Judge Grubb in Central Consumers Co. |
+238 Fed. 616, arrived at the same
+conclusion. It is said
+inconsistent with the decision in Ex parte Young,
+supra. In that case the defendant Young, Attorney
+General of Minnesota, had been enjoined by the
+Circuit Court of the United States from enforcing an
+act of the state of Minnesota fixing the charges for
+freight transportation at rates found to be
+confiscatory. After this order was entered in the
+Attorney General, in
+defiance of it, applied to a state court for a writ of
+mandamus compelling
+the railroad company to
+comply with certain provisions of the state act. For
+this he was adjudged by the Circuit Court to be in
+contempt, and put in custody of the United States
+marshal. Thereupon he applied to the Supreme
+Court for leave to file a petition for writs of habeas
+corpus and certiorari, which the court denied. The
+act was held to be unconstitutional because, among
+other reasons, it had been found by the lower court
+to be confiscatory of the railroad company's
+property. The general rule that courts of equity
+have no jurisdiction to enjoin criminal proceedings
+was fully recognized, but the injunction was
+sustained because of certain exceptions to the
+general rule within which that case fell. Mr. Justice
+Peckham said, at page 161 of 209 U.S., at page 454
+of 28 Sup. Ct. (52 L.Ed. 714, 13 L.R.A.(N.S.) 932,
+14 Ann.Cas. 764):
+'It is further objected (and the objection really
+forms part of the contention that the state cannot be
+sued) that a court of equity has no jurisdiction to
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=...
+
+
+
+enjoin criminal proceedings, by indictment or
+otherwise, under the state law. This, as a general
+rule, is true. But there are exceptions. When such
+indictment or proceeding is brought to enforce an
+alleged unconstitutional statute, which is the
+subject-matter of inquiry in a suit already pending
+in a federal court, the latter court, having first
+obtained jurisdiction over the subject-matter, has
+the right, in both civil and criminal cases, to hold
+and maintain such jurisdiction, to the exclusion of
+47 L.Ed. 584). But the federal court cannot, of
+ourse, interfere in a case where the proceeding
+vere already pending in a state court. Taylor
+Wall. 366, 370 (21 L.Ed. 287);
+Harkrader"|| Wadley, 172 U.S. 148 (19 Sup.Ci.
+119, 43 L.Ed. 399).
+*Where one commences a criminal proceeding who
+is already party to a suit then pending in a court of
+equity, if the criminal proceedings are brought to
+enforce the same right that is in issue before that
+court,
+the
+may enon such criminal
+proceedings.
+etc., Co. Los Angeles, 189
+U.S. 207,
+Sup.Ct. 498, 47 L.Ed.
+778). In
+Debbins | Los Angeles, 195 U.S. 223-241 (25
+Sup.Ct. 18,
+49 L.Ed. 169), it is remarked by Mr.
+Justice Day, in delivering the opinion of the court,
+that 'it is well settled that where property rights will
+be destroyed, unlawful interference by criminal
+proceedings under a void law or ordinance may be
+cached and controlled by a court of equity. Smyt!
+• Ames (169 U.S. 466, 18 Sup.Ct. 418, 42 L.Ed
+819), supra, distinctly enjoined the proceedings in
+indictment to compel obedience to the rate act.
+*These cases show that a court of equity is not
+always precluded from granting an injunction to
+stay proceedings in criminal cases, and we have no
+doubt the principle applies in a case such as the
+present. In re Sawyer, 124 U.S. 200, 211 (8 Sup.Ct.
+482, 31 L.Ed. 402), is not to the contrary. That
+case holds that in general a court of equity has no
+jurisdiction of a bill to stay criminal proceedings,
+but it expressly states an exception, 'unless they are
+instituted by a party to the suit already pending
+before it and to try the same right that *531 is in
+issue there.' Various authorities are cited to sustain
+Page 6
+the exception. The criminal proceedings here that
+could be commenced by the state authorities would
+be under the statutes relating to passenger or freight
+rates, and their validity is the very question
+involved in the suit in the United States Circuit
+Court. The right to restrain proceedings by
+mandamus is based upon the same foundation and
+governed by the same principles.'
+The case under consideration does not fall,
+withir
+any of these exceptions. See, also,
+_ Los
+Angeles, 189 U.S. 207, 23 Sup.Ct. 498, 47 L.Ed.
+Only two cases are referred to in which United
+States attorneys have been enjoined, and the
+omplainants rely upon them as showing that thi
+uestion of jurisdiction was disregarded. Wilson
+New, 243 U.S. 332, 37 Sup.Ct. 298, 61 L.Ed. 755,
+..R.A. 1947E, 938, Ann. Cas. 1918A, 1024, and
+Tammer Dagenhard, 247 U.S. 251, 38 Sup.Ct
+529, 62 L.Ed. 1101, Ann. Cas. 1918E, 724. In
+them, as in the case under consideration, only
+injunctive relief was prayed for. The moment that
+relief was granted or denied the suit was at an end.
+The only difference is that, the decree in the two
+cases cited being final, an appeal lay directly to the
+Supreme Court (section 238, Judicial Code, Act
+March 3, 1911, c. 231, 36 Stat. 1157 (Comp. St.
+Sec. 1215)), whereas in this case, the order being
+interlocutory, appeal lay only to the Circuit Court of
+Appeals (section 129, Judicial Code (Comp. St.
+Sec. 1121)). It is said that because the Supreme
+Court disposed of the two cases cited it actually
+exercised the jurisdiction which the complainants
+deny the court in this suit has. Jurisdiction as a
+federal court is plain in all three cases, but this does
+not prove that a suit against the United States can be
+maintained either by consent of the parties or of the
+court or by oversight of either or both. The right to
+maintain the suits, i.e., to give the injunctive relief
+prayed for, could not be determined until the court
+ad ascertained whether they fell within the genera
+ule or within the exception. In Wilson - New th
+moment the court found the act constitutional, from
+proceeding under which the United States attorney
+had been enjoined, the suit was necessarily found to
+be one against the United States, and the injunction
+improper, without any reference to the property
+
+
+
+rights involved. So in Hammer | Dagenhard, the
+moment the
+statute was
+found to
+be
+unconstitutional, and the complainant's right to
+employment directly invaded by its enforcement,
+the suit was necessarily found not to be against the
+United States, and the injunction was proper within
+the well-established exception. The decisions in
+these cases do not impair the general rule as to suits
+against the United States, or extend the exception to
+that rule. The whole attention of the court was
+irected to the vital question of constitutionality
+nd the fact that it did not restate well-establishes
+law does not convince us that it intended to depart
+therefrom.
+We are sure that the United States attorney will
+co-operate with
+the complainants to have the
+question involved determined as speedily, and in
+the meantime with as little interference with their
+business, as possible.
+Because the suit, so far as the defendant Caffey,
+United States attorney, is concerned, is against the
+Page 7
+accordingly been issued restraining the United
+States attorney and the acting and deputy collector
+of internal revenue of the Third district of New
+York from enforcing, pending final hearing, certain
+acts of Congress. It seems to me that the rulings
+made are contrary to the powers of a court of
+equity, and are due to a misapprehension of certain
+decisions of the Supreme Court of the United States.
+The court of chancery was founded on the
+inefficiency of the ordinary tribunals to do complete
+justice in civil matters. Almost at the same time
+and for a like reason the court of star chamber was
+established, and both had their origin in the royal
+prerogative. The star chamber grew out of the
+failure of the ordinary tribunals to do complete
+justice in criminal matters and other offenses of an
+extraordinary and
+dangerous character, and
+its
+jurisdiction was confined to cases partaking of a
+criminal
+character.
+Essays
+Anglo-american Legal History, vol. 2, pp. 251, 252.
+We accordingly find it laid down with unanimity
+by the text-writers that criminal proceedings are not
+enjoined in equity.
+In Pomeroy's Equity Jurisprudence (sec. 1361, p.
+396, note) that distinguished authority states that
+criminal proceedings will never be enjoined'; citing
+to proceed is constitutional, and in so proceeding he
+will not transcend his authority under the act, the
+order of the court below is modified by striking out
+the injunction pendente lite against him, and as so
+modified is affirmed.
+ROGERS, Circuit Judge (dissenting
+in part) I
+concur in the foregoing opinion in so far as it holds
+that the injunction cannot issue to restrain the
+United States attorney from instituting criminal
+prosecutions under the acts of Congress approved
+August 10, 1917, c. 53, 40 Stat. 276 (Comp. St.
+1918, Secs. 3115 1/8e to 3115 1/8r), and November
+21, 1918. The importance of this case to the
+government and to the complainants, and the
+fundamental principle which is involved and which
+goes to the jurisdiction of the equity courts, makes
+it my duty to state the reasons upon which my
+conclusion is based.
+The learned District Judge has rendered an opinion
+in which he has denied a motion to dismiss the bill
+of complainant, and a preliminary injunction has
+34 Ark. 375;Phillips |
+This accords with the general principle that when a
+cause belongs to the jurisdiction of the law courts
+equity will
+interfere to restrain the
+prosecution of the action nor to stay proceedings on
+the judgment or execution upon mere legal grounds.
+In Bispham's Equity (8th Ed., Sec. 424) it is laid
+down that "proceedings in criminal courts will not
+be interfered with by injunction unless the
+proceedings are commenced by a person who is
+also plaintiff in equity relative to the same matter.'
+The author notes no other exception.
+exception to which he refers comes under the right
+of *533 the equity court to control the conduct of
+parties who seek its aid in furtherance of their civil
+rights. The defendant in the bill and in the criminal
+proceeding must be the same person, and the
+question raised and the object sought in the two
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=... 12/27/2007
+
+
+
+259 F. 525. 170 C.C.A. 487
+Page 8
+proceedings must be identical.
+In Maitland's Equity (page 261) that distinguished
+legal scholar says:
+'A civil court, again, must not prohibit a man from
+instituting criminal proceedings."
+In Story's Equity Jurisprudence (section 893) the
+law is stated as follows:
+"There are, however, cases in which courts of
+equity will not exercise any jurisdiction by way of
+injunction to stay proceedings at law. In the first
+place, they will not interfere to stay proceedings in
+any criminal matters or in any cases not strictly of a
+civil nature. As, for instance, they will not grant an
+injunction to stay proceedings on a mandamus, or
+an indictment, or an information, or a writ of
+prohibition. But this restriction applies only to
+cases where the parties, seeking redress by such
+proceedings, are not the plaintiffs in equity; for, if
+they are, the court possesses power to restrain them
+cases the injunction is merely incidental to the
+ordinary power of the court to impose terms upon
+parties who seek its aid in furtherance of their rights.
+In Eden on Injunctions, 66, it is said:
+'It is an established rule that an injunction, or any
+order in the nature of an injunction,
+will not be
+granted to restrain proceedings in a criminal matter.*
+n Kerr on Injunctions (4th Ed.p. 7), the leading
+English authority on the subject, it is said:
+"The court will not interfere by injunction in
+matters merely criminal or immoral, which do not
+affect any right to property. But if an act which is
+criminal touches also the enjoyment of property, the
+court has jurisdiction, but its interference is founded
+solely on the ground of injury to property.*
+In High on Injunctions (section 68, 4th Ed.) it is
+laid down that-
+"since courts of equity deal only with civil and
+property rights, they will not interfere by injunction
+with criminal proceedings, having no jurisdiction or
+power to afford relief in such cases. Jurisdictior
+over such actions is conferred upon courts
+And the exceptions he refers to do not include a
+case like the present. He goes on to say:
+"So equity will not interfere by injunction to
+restrain municipal officers from the prosecution of
+suits for the violation of city ordinances, such
+proceedings being of a quasi-criminal nature, since
+equity will not interfere with the execution of the
+criminal law, whether pertaining to the state at large
+or to municipalities which are agents in the
+administration of civil governments.*
+In Spelling on Injunctions (2d Ed., vol. 2, Sec. 24)
+it is said:
+*Equity has no jurisdiction to interpose for the
+prevention of crime,
+or to enforce moral
+obligations, nor will it interfere for the prevention
+of illegal acts, merely because they are illegal. Nor
+have the courts of equity jurisdiction*534 to
+prevent by injunction the institution of bona fide
+prosecutions for criminal offenses, whether the
+same be violations of state statutes or municipal
+ordinances.'
+Lord Chief Justice Holt, of the Queen's Bench, said
+in the case of Holderstaffe - Saunders, 6 Mod. 16
+(1703), when counsel suggested that an injunction
+be sought in chancery, that-
+'Surely chancery will not grant an injunction in a
+criminal matter under examination in this court; and
+that, if they did, this court would break it, and
+protect any that would proceed in contempt of it.*
+1 1742, in the Mayor and Corporation of York, •
+tkins, 302, the plaintiffs claimed the sole right o
+fishing in the River House; the defendants claimed
+the same right, and a bill and cross-bill were
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=.. 12/27/2007
+
+
+
+brought to establish their several rights. While
+these suits were pending the plaintiffs caused the
+agents of the defendant to be indicted at the York
+sessions, where they themselves were judges, for a
+breach of the peace, in fishing in their liberty. An
+application for an injunction was made to the Lord
+Chancellor (Hardwicke).
+"This court,' said the chancellor, 'has not originally
+and strictly any restraining power over criminal
+prosecutions. * * * If actions of trespass had been
+brought vi et armis this court would have stopped
+them; but though I cannot grant an injunction, yet I
+may certainly make an order upon the prosecutors
+to prevent the proceeding on the indictment. * * *
+Where parties submit their right to the court, they
+have certainly a jurisdiction and may interpose.*
+In 1751, in Montague | Dudman, 2 Ves., Sr., 396,
+Lord Chancellor Hardwicke said:
+"This court has no jurisdiction to stay proceedings
+on a mandamus, nor to an indictment, nor to any
+information, nor to a writ of prohibition, that I know
+of.'
+In 1827, in Macaulay | Shackell, 1 Bligh's New R.
+96, 127, Lord Eldon declared that 'a court of equity
+has no criminal jurisdiction.*
+In 1876, in Kerr | Corporation of Preston, supra,
+involved
+an attempt to
+restrain certain
+criminal proceedings, Jessel, M.R., said:
+*Why ought a court of equity to interfere with the
+ordinary proceedings of a criminal court? I am not
+ware that any such power exists. The point cam
+fore me in Saul i. Browne, L.R. 10 Ch. 64, where
+I declined to interfere with criminal proceedings or
+• follow Lord Hardwicke's doubtful decision ir
+Mayor of York Pilkington, 2 Atk. 302. My
+decision was appealed from, and the Lords Justices
+thought it a right decision. With the exception of
+that case before Lord Hardwicke, there is no
+Page 9
+In Wharton's Criminal Procedure (10th Ed., vol. 3,
+p. 2134) it is said:
+Court of equity has no jurisdiction to stay or enjoi
+iminal proceedings.
+In 16 Am. & Eng. Encyc. of Law, p. 363, it is laid
+down:
+general rule it will not.*
+nterference, actual or threatened, with property o
+ghts of a pecuniary nature; but when there is suc
+interference, and there is no adequate remedy *535
+at law, the fact that the act may be criminal will not
+divest the jurisdiction of equity to prevent it.*
+I may stop here to say that an illustration of what is
+meant by the passage quoted may be found in In re
+Debs, 158 U.S. 564, 15 Sup.Ct. 900, 39 L.Ed. 1092.
+In that case, decided in 1894, Mr. Justice Brewer,
+speaking for the court, said:
+'A chancellor has no criminal jurisdiction.
+Something more than the threatened commission of
+an offense against the laws of the land is necessary
+to call into exercise the injunctive powers of the
+court. There must be some interferences, actual or
+threatened, with property or rights of a pecuniary
+nature; but when such interferences appear the
+jurisdiction of a court of equity arises, and is not
+destroyed by the fact that they are accompanied by
+or are themselves violations of the criminal law.*
+The court sustained the right to punish Debs for his
+violation of the injunction, the injunction having
+been issued for the protection of property. The acts
+which Debs committed in violating the injunction
+the court said might or might not have been
+violations of the criminal law. 'If they were, that
+matter is for inquiry in other proceedings."
+In citing the English decisions above referred to !
+am mindful that the Supreme Court has more than
+once declared that the equity jurisdiction of the
+courts of the United States is the same in nature and
+extent as the equity jurisdiction of England, fron
+which it is derived. Dodge | Woolsey, 18 How
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=... 12/27/2007
+
+
+
+Page 10
+31, 347, 15 L.Ed. 401;Fenn || Holt
+6 LEd 19mpson Railroad
+Companies, 6 Wall. 134, 18 L.Ed. 765;Van Nord
+| Morton, 99 U.S. 378. 380. 25 L.Ed. 453:Root |
+Railroad Co., 105 U.S. 189, 26 L.Ed. 975.
+There are many decisions in the courts of this
+country in which the general rule has been applied
+that in general the equity courts are without
+jurisdiction to restrain criminal proceedings. In
+Attorney General |. Utica Ins. Co., 2 Johns.Ch. 371,
+Chancellor Kent said:
+'If a charge be of a criminal nature, or an offense
+against the public, and does
+enjoyment of property, it ought not to be brought
+within the direct jurisdiction of this court, which
+was intended to deal only in matters of civil right,
+resting on equity, or where the remedy at law was
+not sufficiently adequate.'
+The citations might be extended indefinitely, but
+enough has been said to show that the statements of
+the text-writers are abundantly sustained by the
+decisions of the courts as to what is the general rule
+as to the right to an injunction to restrain criminal
+proceedings.
+I come now to inquire under what circumstances the
+Supreme Court has recognized a right to restrain
+criminal proceedings by injunction.
+The question was before the court in 1887 in In re
+Sawyer, 124 U.S. 200, 8 Sup.Ct. 482, 31 L.Ed. 402.
+I shall not go into the facts that were before the
+court in that case, except to say that a bill was filed
+praying an injunction to restrain the mayor and
+council of a city from removing a city officer for
+malfeasance in office. The lower court granted the
+injunction, and committed the defendants for
+contempt in disregarding it. The Supreme Court
+held the injunction *536 absolutely void, and that
+the order committing defendants for contempt was
+also void, and that defendants were entitled to their
+discharge on habeas corpus. In the opinion, written
+by Mr. Justice Gray, it is said in referring to the
+jurisdiction of equity:
+*It has no jurisdiction over the prosecution, the
+punishment, or the pardon of crimes or
+misdemeanors, or over the appointment and
+removal of public officers. To assume such a
+jurisdiction, or to sustain a bill in equity to restrain
+or relieve against proceedings for the punishment of
+offenses, or for the removal of public officers, is to
+invade the domain of the courts of common law, or
+of the executive and administrative department of
+the government.'
+And it is also said:
+'From long before the Declaration of Independence
+it has been settled in England that a bill to stay
+criminal proceedings is not within the jurisdiction
+of the court of chancery, whether those proceedings
+are by indictment or by summary process.*
+Again it is said:
+"The modern decisions in England, by eminent
+equity judges, concur in holding that a court of
+chancery has
+no power to restrain criminal
+proceedings, unless they are instituted by a party to
+a suit already pending before it, and to try the same
+right that is in issue there."
+In 1898, in Fitts | McGhee, 172 U.S. 516, 19
+Sup.Ct. 269, 43 L.Ed. 535, the subject was before
+the court again, a suit having been brought to
+Governor of Alabama, the Attorney
+General of the state, and the solicitor of the
+Eleventh judicial circuit of the state, from instituting
+or prosecuting
+any indictment or
+criminal
+proceeding against any one for violating the
+provisions of an act of the Legislature of Alabama,
+prescribing certain maximum rates of toll. The
+court below, the cause having been discontinued as
+against the governor, whose term of office had
+expired, issued a temporary injunction on the
+ground that the act was unconstitutional and void,
+as being in violation of the Constitution of the
+United States. The court, in an opinion written by
+Mr. Justice Harlan, referred approvingly to what
+was held in Re Sawyer, supra. And in referring to
+the fact that the toll-gatherers in the plaintiff's
+service had been indicted in a state court for
+violating the provisions of the act, the court said:
+1&prft=...
+
+
+
+*Let them appear to the indictment and defend
+themselves upon the ground that the state statute is
+repugnant to the Constitution of the United States.
+The state court is competent to determine the
+question thus raised, and is under a duty to enforce
+the mandates of the supreme law of the land. ***
+That the defendants may be frequently indicted
+constitutes no reason why a federal court of equity
+should assume to interfere with the ordinary course
+of criminal procedure in a state court.'
+The next case I will refer to is that of Ex parte
+Young, 209 U.S. 123, 28 Sup.Ct. 441, 52 L.Ed.
+. 13 L.R.A.(N.S.) 932, 14 Ann.Cas. 764,
+decided in 1908. This was an application for leave
+to file a petition for writs of habeas corpus and
+certiorari in behalf of the Attorney General of the
+state of Minnesota. The lower court had restrained
+the Attorney General from taking any steps to put in
+force the orders of the
+railroad commission of the
+by the
+Legislature of the state fixing rates, and which
+to criminal
+proceedings
+violated the provisions of the acts and the orders of
+the commission. It was claimed that the acts were
+confiscatory.
+Attorney General had violated the injunction, was
+proceeded against for contempt, and was in the
+custody of
+Supreme Court held the acts unconstitutional. So
+that the court had before it (1) an unconstitutional
+act, (2) which act was the subject of inquiry in a suit
+already pending in a federal court, and (3) the
+intention of the state's Attorney
+• General to enforce
+it. And it was held that under these circumstances
+the injunction was properly issued. But the case of
+Sawyer, supra, was neither overruled nor
+doubted. In the opinion, written by Justice
+Peckham, the court, referring to the rule that a court
+of equity has no jurisdiction to enjoin criminal
+proceedings, by indictment or otherwise, said:
+'But there are exceptions. When such indictment
+or proceeding is brought to enforce an alleged
+unconstitutional statute, which is the subject-matter
+of inquiry in a suit already pending in a federal
+court, the latter court, having first obtained
+jurisdiction over the subject-matter, has the right, in
+both civil and criminal cases, to hold and maintain
+Page 11
+such jurisdiction, to the exclusion of all other
+courts, until its duty is fully performed.*
+The court also pointed out that an injunction might
+issue to prevent unlawful interference by criminal
+proceedings under a void law or ordinance, where
+otherwise property rights would be destroyed. The
+case is considered consistent with In re Sawyer,
+supra, which the court expressly declared 'is not to
+the contrary.
+I concur with what is said in the opinion of the court
+that the case now under consideration does not fall
+within the exceptions stated in Ex parte Young.
+No cases have come under my notice in which the
+Supreme Court has added to the exceptions stated in
+the case last cited.
+In 1916 the court decided Wilson | New, 243 U.S.
+332, 37 Sup.Ct. 298, 61 L.Ed. 755, L.R.A. 1917E,
+938, Ann. Cas. 1918A, 1024. The suit was brought
+to restrain the officers of certain labor unions and a
+United States District Attorney from establishing an
+eight-hour day for interstate and foreign commerce.
+The act provided that any person violating
+should, upon conviction, be fined not less than $100
+and not more than $1,000, or imprisoned not to
+exceed one year, or both. The court held the act
+constitutional, and reversed the court below, which
+had granted an injunction. The case turned upon
+the constitutionality of the act, and there is no
+decision of the question as to the power of a court
+of equity to enjoin criminal proceedings, and no
+reason for supposing that the court intended it to be
+understood that the jurisdiction of equity in such
+cases was to be extended beyond the limits stated in
+Ex parte Young.
+In 1918 Hammer || Dagenhart, 247 U.S. 251, 38
+Sup.Ct. 529,6 L.Ed. 1101, Ann. Cas. 1918E, 724,
+was decided. The court below had enjoined the
+enforcement of an act of Congress intended to
+prevent interstate commerce in the products of child
+labor. The act provided for a criminal prosecution
+of those violating its provisions. *538 The only
+question discussed in the opinion was that of the
+constitutionality of the statute, and, as the court held
+that unconstitutional, it affirmed the lower court,
+
+
+
+which enjoined its enforcement. The case added
+Page 12
+extent denied his official or representative character.
+by criminal proceedings under a void law, and
+therefore within the exceptions stated in Justice
+Peckham's opinion in the Young Case.
+n Truax - Raich, 239 U.S. 33, 36 Sup.Ct. 7, 6(
+»Ed. 131, L.R.A. 1916D, 545, Ann. Cas. 1917B
+283, the act was unconstitutional and the Attorney
+General was restrained.
+In Philadelphia Co. | Stimson, 223 U.S. 605, 32
+Sup.Ct.
+56 L.Ed. 570, the statute being
+constitutional, the bill to enjoin enforcement was
+dismissed.
+Does the fact that the prosecuting officer
+misconstrues a constitutional statute justify a court
+of equity in issuing an injunction to restrain him? I
+am not aware that the Supreme Court has so held.
+In the absence of such a ruling I think the doctrine
+announced by the Circuit Court of Appeals in the
+Sixth Circuit
+should be followed. It was there said
+in Arbuckle - Blackburn, 113 Fed. 623,51 C.C.A.
+129,65 L.R.A. 864, that the jurisdiction of courts of
+equity had never been carried to that extent in
+authoritative decisions.
+'On the contrary,'
+said
+Judge Day (afterwards Justice Day of the Supreme
+Court),
+'the Supreme Court, in more than one
+instance, has denied such jurisdiction.' And he
+adds: *We think this an
+enlargement of the
+jurisdiction opposed to reason and authority.' This
+opinion was concurred in by Judge Lurton, who
+also later became a member of the Supreme Court
+of the United States.
+I concur also in the objection that to enjoin the
+United States attorney from proceeding under a
+160, 170, 19 Sup.Ct. 119, 127 (43 L.Ed. 399): 'In
+proceeding by indictment to enforce a criminal
+statute the state can only act by officers or
+attorneys, and to enjoin the latter is to enjoin the
+state.' If the law officer of the government
+attempts to enforce an unconstitutional law, he is in
+that attempt not representing the state, and is to that
+deputy collector of internal revenue. The bill is
+against McElligott, describing him as acting and
+deputy collector of internal revenue, and the
+runs against "the
+McElligott.' It is not necessary to inquire what the
+effect would be in case McElligott *539 should
+cease to hold the office he now fills, and whether
+the words acting and deputy collector of internal
+revenue * are anything more than a descriptio
+personae, identifying the person intended to be
+bound, and not effective as against another who
+might succeed to the office upon his death or
+Municipal
+Corporations, vol. 4 (5th Ed.) Sec. 1536.
+The injunction restrains McElligott, his agents,
+servants, subordinates, and employes,
+aped until the father and de of this dirt, are,
+refusing to issue to said complainant, its
+officers, servants, and employes, or any of them,
+revenue stamps in respect of such beer or malt
+liquor, provided the taxes payable thereon by law
+are duly tendered or paid to him or them, and from
+at any time hereafter refusing to license and to
+permit said complainant duly to qualify as a brewer
+of said beer or malt liquor, if otherwise duly
+qualified, even though the beer or malt liquor
+manufactured, produced, and sold by it, or intended
+so to be, contain more than one-half of one per cent.
+of alcohol by volume, so long as it shall contain,
+when disposed of for consumption, not to exceed
+two and three-quarters per cent. (2 3/4 p.c.) of
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=... 12/27/2007
+
+
+
+alcohol by weight."
+The injunction also restrains him from-
+"seizing, attempting or causing to be seized, or
+otherwise interfering with the property, business,
+and affairs of said complainant for or on account of
+any such violations of the provisions of said act of
+Congress of November 21, 1918, or said
+proclamation of the President, or said regulations,
+upon the ground or claim that beer or malt liquor
+containing not to exceed two and three-quarters per
+cent. (2 3/4 p.c.) of alcohol by weight is as matter of
+fact intoxicating, and that the manufacture,
+production, and sale of such beer or malt liquor is
+prohibited by the act of Congress of November 21,
+1918, or by the
+proclamation of the President
+heretofore issued under and by virtue of said act of
+Congress of August 10, 1917, or by the regulations
+of the Commissioner of Internal Revenue.'
+McElligott is
+subject to
+Commissioner of Internal Revenue. That official
+in an affidavit states
+that he is acting, and will
+continue to act, in the matters herein involved, 'in
+conformity
+with the advice of the Department of
+Justice. ' He states:
+*That heretofore,
+that he could not
+properly sell stamps for tax payments on beer
+illegally manufactured, and that his so doing might
+be construed as an act on the part of the government
+sanctioning an illegal act, he instructed the collector
+of internal revenue for the Third district of New
+York, and the collectors of internal revenue at
+Philadelphia, Pa., Syracuse, N.Y., and Newark,
+N.J., to refuse to sell such stamps when the beer had
+been manufactured subsequent to December 1,
+1918. But being now advised by the Department of
+Justice that if such beer is actually manufactured the
+manufacturer is liable for the tax whether the
+manufacture be lawful or unlawful, although in the
+latter event such manufacturer will be subject to
+prosecution for a violation of the acts above
+mentioned, he has canceled said instructions, and
+directed said collectors to sell the stamps in order
+that the tax in question may be paid. And this
+course he intends to pursue unless it shall be
+decided by the courts that the same is improper.
+Page 13
+*That this affiant, acting under advice from the
+Department of Justice, has instructed the collector
+of internal revenue for the Third district of New
+York, N.Y., and the collectors of internal revenue at
+Philadelphia, Pa., Syracuse, N.Y., and Newark,
+N.J., not to take the seizures of beer or seizures of
+any property of brewers because of violations of the
+provisions of the Food Control Act of August 10,
+1917, or regulations issued thereunder,
+violations of the act of November 21, 1918. That
+this affiant is advised and believes*540 that the
+powers of seizures of beer or of the property of
+brewers be exercised by collectors of internal
+revenues only for violations or evasions of statutes
+relating to the payment and collection of taxes upon
+the manufacture and sale of beer, and that such
+powers of seizure do not exist because of violations
+of the Food Control Act of August 10, 1917, or the
+act of November 21, 1918, or regulations issued by
+the Commissioner of Internal Revenue with the
+approval of the Secretary of the Treasury under
+either of the two above-named acts."
+He also states in an affidavit:
+"That deponent is advised and believes, and, unless
+otherwise directed by the court, will act and require
+collectors of internal revenue to act upon the
+assumption
+the sole penalties for such
+violations of section 15 of the Food Control Act of
+August 10, 1917, or of the rules and regulations
+made pursuant thereto, or of the act of November
+21, 1918, are fines and imprisonments prescribed
+by those acts; that the penalties of seizures and
+forfeitures of property prescribed by the Internal
+Revenue Laws do not accrue because of such
+violations, but accrue only because of failures to
+comply with the Internal Revenue Laws themselves,
+which govern the payment and collection of taxes.'
+It appears that acting under instructions from the
+Commissioner of Internal Revenue, issued on April
+11th, and revoked on or about April 21st,
+McElligott refused to sell internal revenue stamps to
+the brewers. In relation to that matter MeElligott
+states in his affidavit:
+'After the revocation of such instructions I never
+required such affidavit, and never refused or
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=...
+
+
+
+Page 14
+threatened to refuse to sell internal revenue stamps
+to be placed on beer or barrels of beer, and have
+been at all times and still am ready and willing to
+sell the brewers all such stamps as they may wish to
+purchase.*
+He also states:
+"Affiant further says that while he held the office of
+collector of internal revenue of the Third district of
+New York, as aforesaid, he never did at any time
+make any threat or threats with respect to or in any
+manner or form as alleged in paragraph Xl of the
+bill of complaint, or in any way or manner with
+respect to the matters or things therein alleged."
+In view of these affidavits, I find no justification for
+the issuance of an injunction against McElligott.
+The intention to do the prohibited acts is not shown
+to exist, but is expressly shown not to exist.
+All 37, it was held that where the defendan, 65
+answer and in open court, disclaimed any intention
+of doing the acts sought to be enjoined, a
+preliminary injunction should be denied, but that
+the bill would be retained, with leave to the plaintiff
+to apply for an
+injunction
+if the defendant
+disregarded his avowed intention.
+Under the circumstances existing in this case, and in
+view of the fact that the defendant McElligott is a
+responsible official of the
+government, who
+disclaims any intention of doing the acts he is
+alleged to intend to commit, I am of the opinion that
+the bill should be dismissed as to him, as well as to
+the United States attorney, but for a different
+reason. As I understand, the law courts do not
+grant injunctions to allay fears and apprehensions
+without evidence that there are sufficient reasons
+for the fears and apprehensions which are alleged to
+be entertained. It must be made to appear to the
+court that the acts *541 against which protection is
+asked are not only threatened, but will in all
+probability be committed to the injury of the
+complainant, who must show reasonable ground for
+apprehending that it will otherwise be done. 16
+Am. & Eng.Encyc. 361. It is well to remember that
+there is no power the exercise of which is, in the
+opinion of the Supreme Court, more delicate that
+he issuing of an injunction. It is the strong arm of
+quity, which ought n
+In view of the conclusion reached that the bill
+of Congress approved November 21, 1918. The
+statute provides:
+'After May 1, 1919, until the conclusion of the
+present war, and thereafter, until the termination of
+demobilization, the date of which shall be
+determined and proclaimed by the President of the
+United States, no grains, cereals, fruit, or other food
+product shall be used in the manufacture or
+production of beer, wine, or other intoxicating malt
+or vinous liquor for beverage purposes. After June
+30, 1919, until the conclusion of the present war,
+and thereafter until termination of demobilization,
+the date of which shall be determined
+proclaimed by the President of the United States, no
+beer, wine, or other
+intoxicating malt or vinous
+liquor shall be sold for beverage purposes except
+for export.'
+As, however, it is desired that the judges express
+their opinion as to the meaning of the words,
+beer, wine or other intoxicating malt or vinous
+liquor,' I state my opinion. It is that the rule of
+construction known as ejusdem generis applies.
+Where general words follow the enumeration of a
+particular class of things, the general words will be
+construed as applicable to things of the same class
+as that enumerated. The paramount duty of a court
+is to see that no effect shall be given to any law
+which violates the Constitution. After that the next
+duty is to see that effect is given to the legislative
+intent. I am unable to see any escape from the
+conclusion that Congress in enacting the law had in
+mind intoxicating liquors. In that conclusion I
+agree with my Associates.
+Whether beer containing not more than 2.75 per
+cent. of alcohol is intoxicating is not a question of
+law, but one of fact, and will be determined at the
+
+
+
+final hearing upon the merits.
+Contain no de Cign of hat per ento of eration
+nakes liquor intoxicating. In a number of th
+¡tates the statutes prohibit the use of all 'alcoholic
+liquors for beverage purposes. In a large number
+the standard of an intoxicating beverage is fixed at
+one-half of 1 per cent. And for nearly 20 years the
+Bureau of Internal Revenue has treated beer
+ontaining one-half of 1 per cent. or more o
+Icohol as a malt liquor, and the brewers of the
+country have acquiesced in this definition of beer.
+And it is not unlikely that the present Congress, in
+enacting a Prohibition Enforcement Bill, will
+undertake to define what is intoxicating liquor, and
+if it does may undertake to fix the standard at
+one-half of 1 per cent. in accordance with the rule
+established for so many years in the Bureau of
+Internal Revenue. But, in the absence of some
+definitive legislation, the meaning of the term
+intoxicating liquors' is clearly *542 left as a
+question of fact, and not of law, and the courts
+cannot undertake to say, as matter of law, that
+liquor which contains 2.75 per cent. of alcohol by
+weight is not intoxicating. And neither the opinion
+of my Associates, nor the opinion of the district
+judge, contains anything to the contrary. In the
+opinion of the district judge he expressly declared *
+that the question whether beer having 2.75 per cent.
+of alcohol is intoxicating' was not before him for
+decision.
+I summarize my conclusions as follows:
+1. The acts of Congress herein involved are
+constitutional.
+2. They relate to liquors which are intoxicating.
+3. Whether liquor which contains 2.75 per cent. of
+alcohol in weight is intoxicating is a question of
+fact, which will be determined as such when the
+case reaches final hearing, the majority of the court
+having decided that the bill should not be dismissed
+except as against the United States attorney.
+4. That the bill should have been dismissed not only
+as against the United States attorney, but also
+Page 15
+against the acting and deputy collector of internal
+revenue.
+52737
+HOUGH, Circuit Judge (dissenting in part).
+In the result reached by Judge WARD i concur, and
+with the opinion I agree, except in so far as it bases
+the modification of injunction order on a lack of
+power to stay the United States attorney from
+instituting any and every criminal proceeding under
+any constitutional statute.
+The matter is one of degree, not of kind or power.
+A prosecuting officers threatened act may be so
+preposterously
+unconstitutional) as to justify the intervention of
+Injunction is always against human action, and no
+logical difference, either as to wrong or remedy, can
+• pointed out between unconstitutional huma
+ction and similar action without color of la
+therefor.
+The wrong here complained of, however, was and is
+that of the Internal Revenue Department of the
+Treasury. Under laws in force long before 1918,
+every brewer (practically) brewed on sufferance of
+the commissioner. As July 1, 1919, approached
+that official threatened to refuse the licenses and
+stamps, without which brewing is absolutely illicit,
+and subjects the brewer to confiscatory proceedings
+and penalties of extreme severity. The plain intent
+was to enforce a strained construction of the act of
+November 21, 1918, by preventing brewers from
+complying with pre-existing and unrepealed law.
+So far as I can now see, the injunction against the
+collector stops that plan, and I regard the relief
+obtained below against the United States attorney as
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=... 12/27/2007
+
+
+
+259 F. S25, 170 C.C.A. 487
+in effect preventing that official from asking at the
+hands of a grand jury indictments for offenses
+created only by the act of November 21st itself.
+*543 Such possible indictments would not involve
+preliminary seizure of plant and tools, and they
+should be left to their course at common law, except
+under circumstances of extreme necessity, not here
+shown. This dissent, then, is limited to the reason
+assigned for a result to which I agree.
+C.A.2 1919.
+2591.525, 170 CCA Co. Meligott
+Page 16
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=...
+
+
+
+-- F.3d----
+..- F.3d ---, 2007 WL 4510264 (C.A.10 (Utah))
+sufficiently analogous guideline, [to sentence the
+defendant according to] the provisions of 18 U.S.C.
+§ 3553. "U.S.S.G. § 2X5.1. Accordingly, under our
+case law, the district court first had to determine
+hether any guideline was sutticiently analogous
+• used in sentencing Mr. Rakes. United States I
+Nichols, 169 F.3d 1255, 1270 (10th Cir.1999).
+more than one sufficiently analogous guideline
+could be found, the court then had to assess which
+qualified as the most analogous, and employ it in
+sentencing Mr. Rakes. Id. at 1271. Put another way,
+the court first had to ask what analogous provisions
+were within the ballpark; it then had to ask which
+represented the best fit. On appeal, we review the
+district court's determinations on these scores de
+novo to the extent they rest on legal bases, and for
+clear error to the extent they
+factual
+findings. Id. at 1270-71;United States l Fortier,
+180 F.3d 1217, 1225 (10th Cir.1999). Because the
+parties' dispute in this case
+involves only an
+interpretation of the Guidelines, our de novo
+standard applies.
+Page 7
+impede various officers or employees of the United
+force or threat of force, see26 U.S.C. § 7212(a).
+B
+that 2A6.1 is the most analogous provision. Mr.
+Rakes disagrees, submitting that 2A2.4 is the apter
+section. The dispute is hardly
+inconsequential:
+under 2A6.1, with the appropriate adjustments for
+Mr. Rakes's criminal history
+and offense
+characteristics, his advisory Guidelines sentencing
+range is 63 to 78 months; under 2A2.4 with similar
+adjustments, his sentencing range is only 37 to 46
+months.
+In approaching the resolution of this dispute, we
+pause to acknowledge an antecedent complication.
+Our sister circuits have adopted
+approaches to the question of what information a
+should look
+when deciding
+Guidelines section is the most analogous. See
+Nichols, 169 F.3d at 1271. Some courts restrict
+their analysis to the facts alleged in the indictment
+A
+On the first question posed by our test, we discern
+no material disagreement between the parties. We
+generally compare the elements of the defendant's
+crime to the elements of federal offenses already
+covered by specific Guidelines sections to ascertain
+which plausible analogies exist for sentencing. Id. at
+1270.Here,
+the parties seem to agree that two
+candidates emerge from this process-Sections 2A6.1
+and 2A2.4. The offense of which the jury convicted
+Mr. Rakes requires (1) two or more persons to
+conspire (2) to prevent any person from discharging
+the duties of their office under the United States (3)
+by force, intimidation, or threat. See18 U.S.C. § 372
+• Guideline 2A6.1 applies to threatening or
+harassing communications, and the majority of the
+offenses covered by that section capture the threat
+and intimidation aspect of 18 U.S.C. § 372,
+requiring a threat of harm against a person, and
+some require that the person be a particular officer
+of the United States. See18 U.S.C. §§ 32(c), 871,
+876, 877, 878(a), 879, 2332b(a)(2); 47 U.S.C. §
+223(a)(1)(C)-(E); 49 U.S.C. § 46507. Meanwhile,
+guideline 2A2.4 applies to efforts to obstruct or
+338-39 (5th Cir.1996); United States | Terry, 86
+F.3d 353,
+357-78 (4th Cir.1996).
+beyond such documents to examine the defendant's
+proven relevant conduct. Nichols, 169 F.3d at 1271;
+seeU.S.S.G. § 1B1.3; United States | Osborne, 16.
+: 3d 434, 438 (8th Cir.1999): United States
+rdo, 149 F.3d 36, 45 (Ist Cir.1998); Unitea
+States Clay, 117 F.3d 317, 319-20 (6th Cir. 1997)
+. The parties in this case do not advocate for either
+approach and because we conclude that the district
+court chose the appropriate guideline using either
+methodology, we decline to enter this inter-circuit
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=.. 12/31/2007
+
+
+
+--- F.3d----
+..- F.3d --.., 2007 WL 4510264 (C.A.10 (Utah))
+Looking solely to the face of Count II of the
+ndictment, it charged Mr. Rakes with a conspirac
+o threaten and intimidate a federal prosecutor
+alleged that he conspired to write a letter with
+threatening language, listing the street on which the
+victim lived; and contended that he or a
+co-conspirator sent the letter to the victim through
+the mail. Guideline 2A6.1 appears most analogous
+to the offense conduct charged in Count Il because,
+as the district court noted, it better captures the
+element of a letter seeking to threaten or intimidate
+a public official. The majority of the 2A6.1 listed
+offenses concern threats of harm. SeeU.S.S.G. §
+2A6.1. By contrast, most (though admittedly not all)
+of the offenses listed as predicates for guideline
+2A2.4 do not involve threats or intimidation and the
+concomitant complexities
+premeditation such
+actions imply, but instead concern simple assaults
+against officers of the United States. SeeU.S.S.G. §
+2A2.4. Accordingly, when compared against the
+indictment itself, 2A6.1 appears the most analogous
+An examination of all the circumstances of the case
+confirms rather than alters this conclusion. The case
+actually proven at trial against Mr. Rakes centered
+threatening
+letter-focusing on his
+involvement in writing the letter, addressing it, and
+conveying its threat to the
+victim prosecutor.
+Although the evidence showed that Mr. Rakes
+sought to impede the prosecution of members of the
+Soldiers of Aryan Culture, it also demonstrated that
+he intended to accomplish this goal by means (at
+least in the first instance) of a premeditated and
+comparatively complex scheme
+of intimidation
+rather than by an act of simple assault.
+C
+Page 8
+of the victim is covered by both provisions and no
+reason to distinguish between them. Confirming the
+point, the district court applied the official victim
+enhancement to Mr. Rakes's sentence, making his
+sentence under guideline 2A6.1 track the elements
+of 18 U.S.C. § 372 almost exactly.
+Mr. Rakes next argues that guideline 2A2.4 is most
+analogous because its title, "Obstructing or
+impeding officers," employs an almost identical
+formulation as the title language of 18 U.S.C. § 372
+, "Conspiracy to impede or injure officer. But
+whether we adopt the face of the indictment test or
+the competing proven conduct test, in neither
+circumstance is the question as facile as matching
+titles of statutes and guidelines. Both require more
+analysis from us than that. Neither can titles of
+statutory or Guidelines provisions limit the plair
+neaning of the provisions themselves. See Griffin |
+160 F.3d 591, 594 n. 4 (10th
+Cir. 1998) ("[T]he title to a statutory provision is not
+part of the law itself."); 2A Sutherland Statutory
+Construction § 47:3 (7th ed.) (stating the statutory
+title "does not constitute part of the statute and is
+not controlling regarding its construction or
+interpretation").
+Looking beyond titles,
+Mr. Rakes suggests that
+guideline 2A2.4 is the most analogous because one
+of the statutes (though only one of the at least 30
+statutes) covered by the guideline, 26 U.S.C. § 7212
+, proscribes threatening conduct similar to that of 18
+U.S.C. § 372. Section 7212, part of the Interna
+Revenue Code, proscribes using force or threats of
+force,
+including
+threatening
+letters
+communications, to intimidate or impede internal
+revenue officers or the administration of the internal
+revenue laws. 26 U.S.C. § 7212.
+Although we concede that the offense conduct in §
+*8 Mr. Rakes objects that, like 18 U.S.C. § 372,
+7212 is similar to the § 372 offense conduct in this
+guideline 2A2.4 incorporates the fact that the victim
+case to the extent both center on communicating
+was a governmental officer, while guideline 2A6.1
+threats to federal officers, Mr. Rakes's argument
+is not necessarily so limited. And this is surely true.
+fails to take account of the fact that § 7212 actually
+But while 2A6.1 does not incorporate the official
+consists of two parts with two different applicable
+status of the victim into the base offense level, the
+guidelines. The first part, intimidating or impeding
+Guidelines enhancement for an official victim,
+a tax administration officer of the United States,
+Section 3A1.2, expressly applies to 2A6.1 and not
+uses guideline 2A2.4,
+but the
+second part,
+2A2.4. SeeU.S. S.G. § 2A2.4 n. 2. Thus, the status
+obstructing or impeding the due administration of
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=.. 12/31/2007
+
+
+
+--- F.3d --.., 2007 WL 4510264 (C.A.10 (Utah))
+the internal revenue laws, employs guideline 2J1.2,
+Page 9
+***
+The district court's judgment is Affirmed.
+And, in fact, guideline 2J1.2 imposes sentences
+more akin to those found in 2A6.i, the provision
+employed by the district court in this case. For
+example, given Mr. Rakes's offense conduct and
+criminal history, his 2A6.l advisory sentencing
+range would be 63-78 months; with the same
+offense characteristics and criminal history, his
+sentencing range under 2J1.2 would be 70-87
+months (as opposed to 37-46 months under 2A2.4).
+The indictment in this case not only charged Mr.
+Rakes with conspiring to threaten the prosecutor but
+also with conspiring
+to impede and thwart the
+prosecution of members of the Soldiers of Aryan
+Culture, that is, impede the due administration of
+the law. Thus, even if § 7212 were similar to the
+offense in this case, Mr. Rakes's conduct would
+likely implicate, and be more analogous to, the
+more severe guideline, not 2A2.4, as he urges.
+*9 Finally, Mr. Rakes contends that it was improper
+sentence him
+communications, when the court granted him an
+acquittal on mailing a threatening communication,
+18 U.S.C. § 876, which falls squarely within
+guideline
+rejected precisely this argument in Nichols. There,
+the jury in the Oklahoma City bombing trial
+acquitted Terry Nichols on counts of first and
+second degree
+murder, but the district court
+affirmed Mr. Nichols's sentence under the first
+degree murder guideline, finding that it was the
+most analogous, and his acquittal of murder did not
+affect our "most analogous guideline"
+inquiry. See
+d. at 1270-76:see also United States | Sarracino
+131 F.3d 943, 950 (10th Cir .1997) (finding no
+merit in the argument that acquittal of first degree
+murder should preclude use of the first degree
+murder offense level at sentencing). Mr. Rakes
+offers us no reason why Nichols does not control
+the outcome of his case on this point.
+FN2. The government requested that its
+supplemental record, including the victim
+impact letter, the threat letter and
+envelope, and the first presentence report,
+be sealed-a motion that we provisionally
+granted on May 7, 2007, pending this
+panel's final decision. Today, we confirm
+our prior ruling and grant the government's
+(unopposed) motion.
+FN3.See also3 Charles Alan Wright et al.,
+Federal Practice & Procedure § 524 (3d
+ed.) (reporting that Rule 32 was amended
+to respond to "the concern that the vitally
+important sentencing decision
+will be
+made on the basis of erroneous information
+"); United States | Hamad, 495 F.3d 241,
+243 (6th Cir.2007) (holding that, because "
+escalation of a sentence based on
+undisclosed evidence raises serious due
+process concerns, "Rule 32 requires a
+sentencing court *either to
+sufficient details about the evidence to
+the defendant a reasonable
+opportunity to respond or ... to refrain
+"ring on the evidence"); United
+Baldrich, 471 F.3d 1110, 1113
+(9th Cir.2006) (pointing out Rule 32's
+concern with ex parte communications that
+may result in the district court considering
+undisclosed or improper facts).
+C.A.10 (Utah),2007.
+U.S. I. Rakes
+--- F.3d -.., 2007 WL 4510264 (C.A.10 (Utah))
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=... 12/31/2007
+
+
+
+-. F.3d----
+F.3d ----, 2007 WL 4510264 (C.A.10 (Utah
+'ite as: --- F.3d =•
+Page 10
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=
+_top&mt=...
+
+
+
+507 F.3d 1213, 07 Cal. Daily Op. Serv. 13,202, 2007 Daily Journal D.A.R. 17,149
+U.S. |. Garcia
+C.A.9 (Wash.),2007.
+United States Court of Appeals, Ninth Circuit.
+UNITED STATES of America, Plaintiff-Appellee,
+V.
+Adrian GARCIA, Defendant-Appellant.
+United States of America, Plaintiff-Appellee,
+V.
+Ivan Torres, Defendant-Appellant.
+United States of America, Plaintiff-Appellee,
+V.
+Miguel Plascencia-Alvarado, also known as Esteban
+Garcia-Morales also known as Angel Caloca,
+Defendant-Appellant.
+Nos. 05-30356, 05-30391, 05-30415.
+Argued and Submitted July 25, 2006.
+Submission Withdrawn Oct. 31, 2006.
+Resubmitted Nov. 1, 2007.
+Filed Nov. 19, 2007.
+Background: Defendants pled guilty in the United
+States District Court for the Western District of
+Washington, Marsha J. Pechman, J., to drug
+conspiracy. Defendants appealed.
+Holdings: The Court of Appeals, Fisher, Circuit
+Judge, held that:
+(1) it lacked jurisdiction to review sentence
+imposed within range stipulated to in defendant's
+plea agreement;
+(2) drug testing supervised release condition did not
+impermissibly delegate authority to set maximum
+number of non-treatment drug tests to probation
+officer; and
+(3) district court could impose financial disclosure
+requirement to supervised release.
+Affirmed.
+West Headnotes
+[1] Criminal Law 110 €- 1026.10(4)
+110 Criminal Law
+110XXIV Review
+110XXIV(D) Right of Review
+110k1025 Right of Defendant to Review
+110k1026.10 Waiver or Loss of Right
+110k1026.10(2) Plea of Guilty or
+Nolo Contendere
+110k1026.10(4) k. Issues
+Considered. Most Cited Cases
+Court of Appeals lacked jurisdiction to review
+sentence imposed within range stipulated to in
+defendant's plea agreement, which was well within
+statutory maximum, since sentence was not imposed
+in violation
+of law and
+not contingent on
+Guidelines. 18 U.S.C.A. § 3742(a)(1); Fed.Rules
+Cr.Proc.Rule 11(e)(1)(C), 18 U.S.C.A.
+[2] Criminal Law 110 €- 1023(11)
+110 Criminal Law
+110XXIV Review
+110XXIV(C) Decisions Reviewable
+110k1021 Decisions Reviewable
+110k1023 Appealable Judgments and
+Orders
+110k1023(11) k. Requisites and
+Sufficiency of Judgment or Sentence. Most Cited
+Cases
+Appellate courts are granted limited jurisdiction to
+review a defendant's challenge to a district court's
+sentence. 18 U.S.C.A. § 3742(a).
+[3] Criminal Law 110 €~1147
+110 Criminal Law
+110XXIV Review
+10XXIV(N) Discretion of Lower Cour
+10k1147 k. In General. Most Cited Case:
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prf=HTMLE&fn=
+_top&mt=...
+
+
+
+507 F.3d 1213, 07 Cal. Daily Op. Serv. 13,202, 2007 Daily Journal D.A.R. 17,149
+The Court of Appeals generally defers to the
+district
+court in
+imposing supervised release
+conditions and reviews them for an abuse of
+discretion.
+[4] Criminal Law 110 €-1042
+110 Criminal Law
+110XXIV Review
+110XXIV(E) Presentation and Reservation in
+Lower Court of Grounds of Review
+110XXIV(E)| In General
+110k1042 k. Sentence or Judgment.
+Most Cited Cases
+Where defendant did not object to the conditions of
+his supervised release before the sentencing court,
+the Court of Appeals reviews for plain error.
+[5] Sentencing and Punishment 350H €-1977(2)
+350H Sentencing and Punishment
+350HIX Probation and Related Dispositions
+350HIX(G) Conditions of Probation
+350Hk1964 Particular Terms and
+Conditions
+350Hk1977 Rehabilitation and Therapy
+350Hk1977(2) k. Validity. Most
+Cited Cases
+Supervised release condition that defendant submit
+to one drug test within 15 days of release from
+imprisonment and at least two periodic drug tests
+thereafter did not impermissibly delegate authority
+to set maximum number of non-treatment drug tests
+to probation officer, where government conceded
+that probation office could conduct only the
+minimum three tests allowed for in order.
+[6] Sentencing and Punishment 350H €- 1983(2)
+350H Sentencing and Punishment
+350HIX Probation and Related Dispositions
+350HIX(G) Conditions of Probation
+350Hk1964
+Particular
+Terms
+Conditions
+350Hk1983 Other Particular Conditions
+350Hk1983(2) k. Validity. Most
+Cited Cases
+District court
+could impose financial disclosur
+equirement to supervised release for defendar
+who pled guilty to drug trafficking; defendant was
+involved in large scale drug conspiracy as drug
+supplier, defendant had history of drug abuse, if
+defendant received or spent significant funds in
+suspicious way probation office would have reason
+to believe that defendant reengaged with drug
+trafficking, and financial disclosure requirement
+reflected appreciation of nature of defendant's
+crimes and served to protect public from further
+crimes. 18 U.S.C.A. § 3553(a)(1), (a)(2)(C).
+17] Sentencing and Punishment 350H €- 1983(1)
+350H Sentencing and Punishment
+350HIX Probation and Related Dispositions
+350HIX(G) Conditions of Probation
+350Hk1964 Particular Terms and
+Conditions
+350Hk1983 Other Particular Conditions
+350Hk1983(1) k. In General. Most
+Cited Cases
+A district court may impose a financial disclosure
+condition to supervised release even without
+ordering restitution, so long as the condition is
+reasonably related to the statutory sentencing
+factors, involves no greater deprivation of liberty
+than is reasonably necessary, and is consistent with
+pertinent policy statements of the Sentencing
+Commission. 18 U.S.C.A. § 3553(a).
+*1215 Mary Anne Royle, Vancouver, WA, for
+defendant-appellant Adrian Garcia.
+Nancy
+L.
+Talner,
+Seattle,
+WA,
+for
+defendant-appellant Miguel Plascencia-Alvarado.
+Jeffrey E. Ellis, Law Offices of Ellis, Holmes &
+Witchley,
+PLLC,
+Seattle,
+WA,
+for
+defendant-appellant Ivan Torres.
+John L. Lulejian (argued), Assistant United States
+Attorney, and James M. Lord, Assistant United
+States
+Attorney,
+Seattle,
+WA,
+plaintiff-appellee.
+Appeal from the United States District Court for the
+Western District of
+Washington; Marsha
+Pechman, District Judge, Presiding. D.C. Nos.
+CR-04-00301-016-MJP.
+CR-04-00301-003-MJP,
+CR-04-00301-007-MJP
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=...
+
+
+
+507 F.3d 1213, 07 Cal. Daily Op. Serv. 13,202, 2007 Daily Journal D.A.R. 17,149
+Before:
+J. CLIFFORD WALLACE,
+KIM
+MCLANE WARDLAW and RAYMOND C.
+FISHER, Circuit Judges.
+FISHER, Circuit Judge:
+This appeal requires us to consider several
+allegations of sentencing error. Initially, we must
+decide whether we have jurisdiction to review a
+sentence that is imposed in accordance with a plea
+agreement under
+Federal Rule of Criminal
+Procedure 11(c)(1)(C) and that is not contingent
+upon the advisory Sentencing Guidelines. We also
+must determine whether a district court commits
+plain error by failing to explicitly set the maximum
+number of non-treatment related drug tests to which
+the defendant will be exposed as a condition of
+supervised release. Finally, we must evaluate
+whether a district court commits plain error by
+imposing a financial disclosure condition on a
+defendant who has been convicted of a drug
+trafficking offense and has a history of drug use.
+We hold that we do not have jurisdiction to review
+a sentence within the range agreed to in a Rule 11(c
+X1)(C) plea agreement, and that the district court
+did not commit plain error by imposing either
+condition.
+than five grams of
+methamphetamine and less than 50 grams of a
+mixture containing methamphetamine in violation
+of 21 U.S.C. §§ 846 and 841(b)(1)(C), as well as
+witness tampering in violation of 18 U.S.C. §
+1513(b)(2). In accordance with their respective
+plea agreements, Garcia was sentenced to 48
+months imprisonment and Plascencia-Alvarado was
+sentenced to 60 months imprisonment. Torres was
+sentenced to 66 months imprisonment, also
+pursuant to his plea agreement, and is subject to
+various supervised release conditions. Garcia and
+Plascencia-Alvarado appeal their sentences, and
+Torres appeals the district court's imposition of
+certain supervised release conditions.
+I. Background
+Because the issues on appeal are exclusively related
+to sentencing, we need not recount detailed facts of
+the underlying criminal offenses to which the
+defendants pled guilty. Rather, we explain only
+those facts relevant to our resolution of the
+defendants' allegations of sentencing error.
+FN1. Rule 11(c)(1)(C) provides in part:
+An attorney for the government and the
+defendant's attorney ... may discuss and
+reach a plea agreement.... If the defendant
+pleads guilty or nolo contendere to either a
+charged offense or a lesser or related
+offense, the plea agreement may specify
+that an attorney for the government will ...
+agree that a specific sentence or sentencing
+range is the appropriate disposition of the
+case, or that a particular provision of the
+Sentencing Guidelines,
+or policy
+statement, or sentencing factor does or
+does not apply (such a recommendation or
+request binds the court once the court
+accepts the plea agreement).
+A. Garcia and Plascencia-Alvarado
+Adrian
+Garcia,
+Miguel
+Plascencia-Alvarado were all involved in a
+large-scale drug trafficking conspiracy in the
+Western District of Washington. After being
+charged with various crimes, all three entered into
+Rule
+11 written plea
+agreements.
+See
+Fed.R.Crim.P. 11(e)(I)(C) FN1 Garcia pled guilty
+to conspiracy to distribute less than 500 grams of
+*1216 cocaine in violation of 21 U.S.C. §§ 846 and
+841(b)(1)(C); Plascencia-Alvarado pled guilty to
+conspiracy to distribute methamphetamine and
+cocaine in violation of 21 U.S.C. §§ 846 and
+841(b)(1)(C); and Torres pled guilty to conspiracy
+Garcia's and Plascencia-Alvarado's plea agreements
+are nearly identical in all material respects. In both
+plea agreements, the defendants accepted that the
+maximum statutory penalty for their offenses is 20
+years imprisonment, waived their right to a trial and
+agreed that the district court "will consider the
+factors set forth in Title 18, United States Code,
+Section 3553(a), including the sentencing range
+calculated
+under the United States Sentencing
+Guidelines" but "is not bound by any
+recommendation regarding the sentence to be
+imposed, or by any calculation or estimation of the
+Sentencing Guidelines range offered by the parties,
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=.. 12/31/2007
+
+
+
+507 F.3d 1213, 07 Cal. Daily Op. Serv. 13,202, 2007 Daily Journal D.A.R. 17,149
+Page 4
+or by the United States Probation Department."
+Most importantly, Garcia agreed that "the
+appropriate sentence of imprisonment to be
+imposed by the Court at the time of sentencing
+should be within the range of twenty-four (24) to
+forty-eight (48) months," and Plascencia-Alvarado
+agreed that the appropriate sentence in his case was
+"fifty-four (54) to ninety (90) months." In light of
+these stipulated sentencing ranges, the parties
+acknowledged that "the Court retains full discretion
+to impose a sentence within the range agreed to
+above." (Emphasis added.)
+At sentencing, the district court accepted Garcia's
+the advisory
+guidelines range.FN2 In so doing, the court, over
+Garcia's objection, attributed to him "the amount of
+cocaine that the Garcia arm of this organization was
+responsible for," which was nearly five kilograms.
+The district court also granted Garcia a three-point
+reduction for acceptance of responsibility, and
+adjusted downward
+criminal history
+After rejecting
+Garcia's request for a two-point reduction for his
+minor role in the offense, the district court arrived
+at a guidelines recommended range of 97 to 121
+months. However, because the district court had
+accepted the plea agreement, Garcia was ultimately
+sentenced to 48 months
+imprisonment.EN3 Garcia
+*1217 appeals this sentence, arguing that the
+district court erred in calculating the guidelines
+range because it applied the wrong burden of proof
+with respect to the drug quantity atributed to
+Garcia. Had the district court applied the correct
+evidentiary standard, Garcia argues, it would have
+arrived at a lower guidelines calculation and he
+would have received a 24-month sentence.
+consistent with others who were" involved
+in similar offenses arising out of the
+conspiracy, reflected
+Garcia's cooperation with the governmen
+and served to deter others from criminal
+conduct.
+Plascencia-Alvarado's plea
+Plascencia-Alarado she district greeme ace pied
+calculated his advisory guidelines range to be 108
+agreement stipulation) because of various equities
+in his favor, including his
+relationship with his young daughter. He further
+claimed that other similarly situated defendants
+received comparable sentences. The district court
+Plascencia-Alvarado to 60 months imprisonment
+(still at the lower end of his plea agreement's
+stipulated range).FN4 Plascencia-Alvarado appeals
+this sentence as unreasonable in light of the 18
+U.S.C. § 3553(a) factors.
+FN4. The district court judge explained
+that
+Plascencia-Alvarado's
+sentence
+reflected his role in the conspiracy, was
+comparable to that imposed upon others
+charged
+with
+similar
+conduct
+accounted for his contrition and lack of
+prior drug trafficking offenses.
+B. Torres
+FN2. During sentencing, the district court
+acknowledged
+guidelines
+calculation
+"appear[ed]
+academic
+because (the court was] going to accept the
+11(c)(1)(C) plea agreement."
+Ens of theisyipulate d eratee ahe hei higt
+court explained that the sentence was
+lower than the guidelines range, was
+Torres' plea agreement stipulated to a fixed
+sentence of 66 months and acknowledged "that the
+Court retains full discretion with regard to the
+imposition of a term of supervised release, the
+conditions of supervised release, fines, forfeiture or
+restitution." At sentencing,
+the district court
+accepted the Rule 11 plea agreement and sentenced
+Torres to the agreed upon term. The district court
+also imposed several conditions of supervised
+release, including that Torres (1)shall submit to
+one drug test within 15 days of release from
+imprisonment and at least two periodic drug tests
+thereafter, as determined by the court;" (2) "shall
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=.. 12/31/2007
+
+
+
+507 F.3d 1213, 07 Cal. Daily Op. Serv. 13,202, 2007 Daily Journal D.A.R. 17,149
+submit to mandatory drug testing pursuant to 18
+U.S.C. § 3563(a)(5) and 18 U.S.C. § 3583(d)"
+(drug testing condition); and (3) "shall provide his
+probation officer with access to any requested
+financial information, including authorization to
+conduct credit checks and obtain copies of
+defendant's Federal Income Tax Returns" (financial
+disclosure condition). Although Torres did not
+object to these conditions at sentencing, he now
+argues that the district court erred in imposing them.
+II. Analysis
+A. Garcia and Plascencia-AlvaradoFN5
+Page 5
+courts limited jurisdiction to review a defendant's
+• to a district court's sentence. See United
+tates Barron-Rivera, 922 F.2d 549. 553 (9tł
+Cir.1991).
+To entertain either Garcia's or
+Plascencia-Alvarado's claim of sentencing error, we
+must find that some provision of § 3742(a) applies,
+thus establishing our jurisdiction. Specifically, the
+statute provides in relevant part:
+(a) Appeal by a defendant. A defendant may file a
+notice of appeal in the district court for review of an
+otherwise final sentence if the sentence-
+(1) was imposed in violation of law;
+(2) was imposed as a result of an incorrect
+application of the sentencing guidelines; or
+(3) is greater than the sentence specified in the
+applicable guideline range to the extent that the
+sentence includes a greater fine or term of
+imprisonment, probation, or supervised release than
+the maximum established in the guideline range ..;
+(4) was imposed for an offense for which there is no
+sentencing guideline and is plainly unreasonable.
+18 U.S.C. § 3742(a). Garcia asserts that we may
+review his sentence for guidelines calculation error
+under either
+: 3742(a)(1) ог
+(2),
+whereas
+Plascencia-Alvarado relies only on § 3742(a)(1) to
+argue that we have jurisdiction to determine
+whether his sentence is unreasonable.FN7 We
+conclude that we are without jurisdiction to
+entertain either Garcia's or Plascencia-Alvarado's
+appeal.
+Because both Garcia's and
+Plascencia-Alvarado's challenges implicate
+the same dispositive issue, we address their
+claims jointly.
+11 As an initial matter, the government argues tha
+e lack jurisdiction to review these defendants
+sentences because they each received a sentence
+within the range stipulated to in their plea
+agreements. N6 That is, because the defendants
+received the benefit of their plea bargains, they may
+not now challenge the sentences.
+FN6.
+Neither
+Garcia
+Plascencia-Alvarado expressly waived the
+right to appeal the district court's sentence.
+Cf. United States | Joyce, 357 F.3d 921
+922-23 (9th Cir.2004) ("A defendant':
+waiver
+of his
+appellate
+enforceable if the language of the waiver
+encompasses his right to appeal on the
+прані от ве
+grounds raised, and if the waiver was
+cnowingly and voluntarily made. Plea
+agreements are contracts between a
+defendant and the government, and we
+generally construe ambiguous language in
+favor of the defendant."(internal citations
+omitted)).
+FN7. There was some discussion at oral
+argument regarding the applicability of 18
+U.S.C. § 3742(c), which provides that "
+[i]n the case of a plea agreement that
+includes a specific sentence under rule [11(
+c)(1)(C) ] of the Federal Rules of Criminal
+Procedure-(1) a defendant may not file a
+notice of appeal under paragraph (3) or (4)
+of [18 U.S.C. § 3742(a) ] unless the
+sentence imposed is greater than the
+sentence set forth in such agreement."
+Because
+neither
+Garcia
+nor
+Plascencia-Alvarado asserts that §
+3742(a)(3) or (4) applies, we need not
+explore whether § 3742(c), which by its
+*1218 [2] 18 U.S.C. § 3742(a) grants appellate
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=... 12/31/2007
+
+
+
+507 F.3d 1213, 07 Cal. Daily Op. Serv. 13,202, 2007 Daily Journal D.A.R. 17,149
+Page 6
+terms refers only to a plea agreement
+providing for a specific sentence, applies
+to cases such as this where the plea
+agreement provides for a specific
+sentencing range.
+Section 3742(a)(1) allows us to review a sentence "
+imposed in violation of law." We have held that
+where a defendant is given the minimum sentence
+permitted, by the statute of conviction, see Unitec
+itates
+Littlefield, 105 F.3d 527, 528 (9th
+Cir. 1997), or a sentence within the statutory
+maximum, see United States | Baramdyka, 95 F.3d
+illegal, and therefore does not violate the law. In
+this case, our jurisdiction is not established under §
+3742(a)(1)
+Plascencia-Alvarado received sentences well within
+the statutory maximums. Therefore their sentences
+were not "imposed in violation of law."
+More recently, we held that § 3742(a)(1) confers
+jurisdiction to review sentences imposed within the
+the defendant
+challenges the sentence as unreasonable under the §
+imposed cio violatione or laso Uniedses
+*imposed in violation of law.
+Plouffe, 445 F.3d 1126, 1130 (9th Cir.2006) (*A
+sentence that is within the Guidelines range ... may
+be unreasonable and thus imposed in violation of
+law pursuant to
+3742(a)(1)."). Garcia
+Plascencia-Alvarado invoke Plouffe to argue that
+jurisdiction properly lies because their sentences
+failed to satisfy § 3553(a) either because the
+guidelines range was improperly computed, seef
+3553(a)(4), or because the other factors were not
+inapplicable to the sentences in this case. Plouffe
+considered only appeals of sentences imposed *1219
+within and pursuant to the applicable advisory
+guidelines range. Plouffe, 445 F.3d at 1129-30. In
+reasoning that we have jurisdiction to review even
+within-guidelines sentences for reasonableness,
+Plouffe relied on United States | Booker, 543 U.S.
+220, 125 S.Ct. 738, 160 L.Ed.2d 621 (2005), which
+held that the reasonableness (and therefore legality)
+of a sentence must be evaluated in light of all of the
+Booker, 543 U.S. at 245-46, 125 S.Ct. 738).
+Unlike Plouffe, Garcia and Plascencia-Alvarado
+were not sentenced pursuant to the guidelines.
+Their sentences were within the range they agreed
+to in their Rule 11(e)(1)(C) plea agreements, and
+although each agreement contemplated that the
+district court would calculate the guidelines range,
+it did not condition the sentence on a properly
+calculated range. We have already held that such
+stipulated sentences need not comport with the
+[gluidelines."
+Cir.2005) ("We conclude that, where a defendant
+was sentenced after pleading guilty pursuant to a
+plea agreement that included a specific sentence
+stipulation that did not exceed the statutory
+maximum and was not contingent upon the
+Guidelines, remand is not required to comport with
+Booker and [United States | Ameline, 409 F.3d
+103(91t cresto) den 4a0 F.3d 393, 364 (ized)
+Cir.2005) ("A sentence imposed under a Rule 11(c)(
+1)(C) plea arises directly from the agreement itself,
+not from the Guidelines, even though the court can
+and should consult the Guidelines in deciding
+accept the plea.
+As Booker is
+concerned with
+Guidelines, it is inapplicable in this situation."
+(internal citation omitted)). Consequently, we hold
+that we do not have jurisdiction to review a
+sentence that was imposed pursuant to a Rule 11(c)(
+1)(C) plea agreement and was not contingent on the
+guidelines, where the defendant claims only that
+was some error in the district court's
+Booker ton Sec United States dl" siva, 413 F.30
+1283, 1284 (10th Cir.2005) ("Silva's only plausible
+argument [that the court has jurisdiction] is that his
+sentence was imposed in violation of law because it
+was given under a mandatory sentencing scheme.
+But this argument fails for the simple and obvious
+reason that Silva received the specific sentence he
+bargained for as part of his guilty plea."). We
+therefore dismiss Garcia and Plascencia-Alvarado's
+appeals of their sentences.
+§ 3553(a) factors, not
+calculation. Plouffe, 445 F.3d at 1130 (citing
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=.. 12/31/2007
+
+
+
+507 F.3d 1213, 07 Cal. Daily Op. Serv. 13,202, 2007 Daily Journal D.A.R. 17,149
+Page 7
+FN8. Because Garcia's Rule 11(c)(1(C)
+stipulated sentence was not conditioned by
+a requirement that it comport with the
+guidelines, and was not contingent upon
+them, his argument that we have
+jurisdiction under § 3742(a)(2) must also
+fail.
+FN9. As in Pacheco-Navarette, we do not
+iere address "whether or to what extent a
+olea agreement containing a stipulation o
+a particular Guideline range or a sentence
+otherwise based or contingent upon the
+Guidelines must comport with the
+Guidelines, as that situation is not before
+us." 432 F.3d at 971 n. 3. Furthermore,
+because we lack jurisdiction to review
+Garcia's
+Plascencia-Alvarado's
+sentences,
+septicabiliry or Rda no,
+address
+the
+United States, ..
+U.S. ...., 127 S.Ct. 245
+. 168 L.Ed.2d 203
+(2007), United States Carty, 453 F.3d
+1214 (9th Cir.2006),
+reh'g
+en
+| 1066 (9th Cir.2006), or
+granted, 462 F. Zavala, 443 F.3d 1165
+United States
+(9th Cir.2006), reh'g en banc granted,462
+F.3d 1066 (9th Cir.2006).
+B. Torres
+Torres challenges the district court's imposition of
+both the drug testing and financial disclosure
+conditions. As to drug testing, Torres argues that
+the district court erred in failing to specify the
+maximum number of non-treatment drug tests,
+thereby impermissibly
+delegating
+authority to Torres' probation officer.
+States | Stephens, 424 F.3d 876, 881 (9th Cir.2005)
+(holding that a probation officer may not decide
+the …. extent of the punishment imposed," because "
+[u]nder our constitutional system the right to ...
+impose the punishment provided by law is judicial"
+(alteration in original) (internal quotation marks and
+punctuation omitted)). Torres also argues that the
+district court abused its discretion in imposing the
+financial disclosure condition because it is not "
+reasonably related to the crime of conviction."
+Sentenceuch less plain error, in the district cour's
+1. Drug Testing Condition
+[5) The district court directed Torres to "submit to
+one drug test
+within 15 days of release from
+imprisonment and at least two periodic drug tests
+thereafter, as determined by the court" and to
+submit to mandatory drug testing pursuant to 18
+U.S.C. § 3563(a)(5) and 18 U.S.C. § 3583(d).* FN1O
+Although recitation of this
+boilerplate drug
+testing language established the minimum number
+of drug tests to which Torres would be subject, it
+does not appear to establish a maximum number of
+such tests. However, as we held in Stephens, "the
+[sentencing] courts
+[have] the responsibility
+stating the maximum number of [drug] tests to be
+performed or to set a range for the permissible
+number of tests." 424 F.3d at 883(concluding that "
+while the district court itself determined the
+minimum number of tests to which [the defendant]
+would be required to submit, the court erred when it
+state the
+number of
+non-treatment drug tests the probation officer could
+impose"). Unlike in Stephens, where the district
+court expressly delegated the authority to set a
+maximum number of non-treatment drug tests to the
+probation officer, id. at 878, in this case the district
+court made no such delegation. Nonetheless
+because the district court did not set a maximum
+Coute be understod as having this aubariy, hich
+FN10. 18 U.S.C. § 3563(a)(5) applies to
+drug testing conditions of probation
+whereas § 3583(d) applies to a conditior
+of supervised release. Both statutor
+sections provide that courts shall ordet
+[3][4] We generally defer to the district court in
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&in=_top&mt=.
+
+
+
+507 F.3d 1213, 07 Cal. Daily Op. Serv. 13,202, 2007 Daily Journal D.A.R. 17,149
+as an explicit condition of [probation or
+supervised release,] that the defendant
+refrain from any unlawful use of a
+controlled substance and submit to [a] drug
+test within 15 days of release on [probation
+or supervised release] and at least 2
+periodic
+drug
+tests thereafter (as
+determined by the court) for use of a
+In United States | Maciel-Vasquez, 458 F.3d
+994(9th Cir.2006), cert. denied... U.S. ...., 127
+S.Ct. 2097, 167 L.Ed.2d 817 (2007), the defendant
+challenged a drug testing condition of supervised
+"participate in
+outpatient substance abuse treatment and submit to
+instructed by the
+probation officer." Id. at 996(internal quotation
+omitted). We observed that this condition
+would be permissible if imposed
+incidental to a
+drug treatment program, but would be improper
+under Stephens
+it were to be understood as
+"the probation officer authority to require
+any treatment
+program." Id.
+we refused
+determine the
+purpose of the drug testing because the defendant
+did not object at sentencing and could not establish
+any plain error. Id. Unlike in Maciel-Vasquez, the
+government here
+Probation
+Office may conduct only the minimum three tests
+allowed for in the order." Indeed,
+it is clear that
+district courts that seek to impose more than the
+explicitly do so at sentencing. See United States 1
+Lewandowski, 372 F.3d 470, 471 (Ist Cir.2004)
+(per curiam). Given the government's concession,
+we construe the district court's supervised release
+as implicitly limiting the maximum
+number of drug tests to three. Torres must submit
+to at least and at most "one drug test within 15 days
+of release from imprisonment and ... two periodic
+drug tests thereafter." Should the probation office
+believe more drug tests are necessary, it would have
+to request a modification from the district court.
+Any such modification would of course have to
+comply with Stephens. Thus construed, there is no
+error in the district court's drug testing condition.
+Page 8
+2. Financial Disclosure Condition
+[6][7] District courts are encouraged to impose a
+financial disclosure condition when they require a
+defendant to pay restitution. SeeU.S.S.G. §
+5D1.3(d)(3)(instructing that where "the court
+imposes an order of restitution, forfeiture, or notice
+to victims, or orders the defendant to pay a fine," it
+should also impose "a condition requiring the
+defendant to provide the probation officer access to
+any requested financial information"). However, a
+district court may impose such a condition even
+without ordering restitution, so long as the
+condition satisfies certain criteria.ENI' First, it
+must be "reasonably related to the factors set forth
+in 18 U.S.C. § 3553(a)." United States | Gallaher,
+275 F.3d 784, 793 (9th Cir.2001); see also Unitea
+States | Brown, 402 F.3d 133, 137 (2d Cir.2005) ("
+[T]he Guidelines recommend a financial disclosure
+special condition where the court imposes a fine or
+restitution. By its own terms, however, this policy
+statement does not preclude a court from requiring
+financial disclosure in other 'appropriate' situations.
+"(internal citation omitted)). Second, it must
+involve no greater deprivation of liberty than is
+reasonably necessary...."United States
+157 F.3d 1197, 1204 (9th Cir.1998). Finally, the
+condition "must be consistent with pertinent policy
+statements of the Sentencing Commission." Id.
+FN11.
+Moreover, contrary to Torres
+argument otherwise, the condition need not
+"be related to
+offense of conviction."
+United States
+Wise, 391 F.3d 1027,
+1031 (9th Cir.2004).
+The financial disclosure requirement imposed on
+Torres satisfies all three criteria, and the district
+court did not commit plain error by imposing the
+condition. Torres was involved in a large scale
+drug conspiracy as a drug supplier. Torres also has
+a history of drug abuse. Clearly, if Torres is
+receiving or
+spending
+significant funds in
+suspicious ways, the probation office would have
+reason to believe he has reengaged with drug
+trafficking or use and would so report to the district
+court. Requiring Torres to disclose financial
+information, at the very least, reflects appreciation
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=... 12/31/2007
+
+
+
+507 F.3d 1213, 07 Cal. Daily Op. Serv. 13,202, 2007 Daily Journal D.A.R. 17,149
+of "the nature and circumstances of the offense and
+[his] history and characteristics" and serves "to
+protect the publie from further crimes." 18 U.S.C. §
+$ 3553(a)(1), (a)(2)(C). And the probation office's
+monitoring is no greater than necessary to achieve
+We join our sister circuits in concluding that certain
+defendants who have been convicted of drug
+trafficking offenses may properly be required to
+disclose the details of their personal finances as a
+condition of *1222 supervised release. See Brown,
+402 F.3d at 137(affirming financial disclosure
+condition imposed on defendant convicted of drug
+trafficking in part because "given this particular
+defendant's personal characteristics and history, the
+disclosure requirement is an effective
+monitoring-and
+deterring-device"
+because "monitoring [the defendant's] finances will .
+. serve to protect the public from "further crimes
+Melender-Santana, 353 :. 3d 93, 107 (Ist Cir:200%)
+(affirming
+financial disclosure condition imposed
+on a similarly situated defendant because it is
+related to the characteristics of the defendant and
+deters future crimin
+grounds by U.S.
+(l conduct), overruled om other
+Padilla, 415 E.3d 211 (Ist
+Cir.2005) (en banc); United States| Behler, 187
+F.3d 772, 780 (8th Cir.1999) (affirming financial
+disclosure condition because
+"the district court
+understood that money and greed were at the heart
+of[the defendant's] drug distribution offenses and
+believed that monitoring [the defendant's] financial
+situation would aid in detecting any return to his
+former lifestyle of
+drug distribution"). Therefore
+the district court did not plainly err in imposing this
+condition.
+Page 9
+improper, nor is the financial disclosure condition.
+DISMISSED. Poren sellered i aluinl ane
+sentence (including the
+conditions of supervised release) is AFFIRMED.
+C.A.9 (Wash.),2007.
+S07 -.3a 1213, 07 Cal. Daily Op. Serv. 13,202,
+2007 Daily Journal D.A.R. 17,149
+III. Conclusion
+Garcia and Plascencia-Alvarado were sentenced to
+a term that was within the range they agreed to in
+their Rule 11(c)(1)(C) plea agreement, which was
+not contingent upon the guidelines. Consequently,
+we do not have jurisdiction under 18 U.S.C. §§
+3742(a)(1) or (a)(2) to review challenges to their
+entences. Torres' supervised release drug testing
+ondition, as construed by this court. is no
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=..
+
+
+
+Effective: July 27, 2006
+United States Code Annotated Currentness
+Title 42. The Public Health and Welfare
+Chapter 151. Child Protection and Safety
+| Subchapter I. Sex Offender Registration and Notificatic
+1 Part A. Sex Offender Registration and Notificatic
+→ § 16913. Registry requirements for sex offenders
+(a) In general
+A sex offender shall register, and keep the registration current, in each jurisdiction where the offender resides,
+here the offender is an employee, and where the offender is a student. For initial registration purposes only, a se
+ffender shall also register in the jurisdiction in which convicted if such jurisdiction is different from th
+jurisdiction of residence.
+(b) Initial registration
+The sex offender shall initially register--
+(1) before completing a sentence of imprisonment with respect to the offense giving rise to the registration
+requirement; or
+(2) not later than 3 business days after being sentenced for that offense, if the sex offender is not sentenced to
+a term of imprisonment.
+(c) Keeping the registration current
+A sex offender shall, not later than 3 business days after each change of name, residence, employment, or student
+status, appear in person in at least 1 jurisdiction involved pursuant to subsection (a) of this section and inform that
+jurisdiction of all changes in the information required for that offender in the sex offender registry. That
+jurisdiction shall immediately provide that information to all other jurisdictions in which the offender is required to
+register.
+(d) Initial registration of sex offenders unable to comply with subsection (b) of this section
+The Attorney General shall have the authority to specify the applicability of the requirements of this subchapter to
+sex offenders convicted before July 27, 2006 or its implementation in a particular jurisdiction, and to prescribe
+rules for the registration of any such sex offenders and for other categories of sex offenders who are unable to
+comply with subsection (b) of this section.
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&in=_top&mt=.. 12/31/2007
+
+
+
+(e) State penalty for failure to comply
+mach jurisdiction, ther ban a rehaly geoler ted i ye trio thal provide a criminal pray a dice e
+requirements of this subchapter
+CREDIT(S)
+(Pub.L. 109-248, Title I, § 113, July 27, 2006, 120 Stat. 593.)
+HISTORICAL AND STATUTORY NOTES
+Revision Notes and Legislative Reports
+2006 Acts. Statement by President, see 2006 U.S. Code Cong. and Adm. News, p. S35.
+References in Text
+This subchapter, referred to in subsecs. (d) and (e) originally read "this title", meaning Title I [§ 101 et seq.] of
+Pub.L. 109-248, July 27, 2006, 120 Stat. 590, known as the Sex Offender Registration and Notification Act, which
+enacted this subchapter; for complete classification, see Short Title note set out under 42 U.S.C.A. § 16901 and
+NOTES OF DECISIONS
+Commerce clause 7
+Constitutional delegation of authority 2
+Ex post facto 6
+Procedural due process 3
+Retroactive application 1
+Standing 5
+Substantive due process 4
+Venue 8
+1. Retroactive application
+Defendant was required to register as a sex offender, pursuant to the Sex Offender Registration and Notification
+Act (SORNA), regardless of whether the Attorney General had adopted required rule specifying the applicability of
+he Act to sex offenders convicted before its enactment; defendant was required to register or update his
+registration under the existing state law of his residence. U.S. | Hinen, W.D. Va.2007, 487 F.Supp.2d 747
+Mental Health E- 469(2)
+Sex Offender Registration and Notification Act's (SORNA) requirement that sex offenders register and update their
+registration did not apply to defendants at the time of their indictments where their convictions pre-dated SORNA
+and they were indicted after SORNA's effective date, but before the Attorney General exercised his authority under
+SORNA and issued an interim rule that made it clear that SORNA applied to sex offenders regardless of when they
+were convicted; the indictments occurred in the brief window during which SORNA's scope remained undefined as
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prfi=HTMLE&fn=_top&mt=.. 12/31/2007
+
+
+
+convicted offenders. U.S. app, M.D. Pa.2007, 487 Supp.2d 536. Statutes Em 278.2
+statute required the Attorney General to animate SORNA's provisions to previously
+2. Constitutional delegation of authority
+Provision of Sex Offender Registration and Notification Act (SORNA) which gave Attorney General authority to
+decide whether persons classified as sex offenders, who were unable to register, should be subject to the
+registration requirements, was not unconstitutional, in violation of the non-delegation doctrine, as applied to
+defendant, a previously-convicted sex offender; the delegation of authority to the Attorney General was not so
+road as to be violative of the non-delegation doctrine, and defendant was not a person who was unable to registe
+vithin the meaning of the provision. U.S. I. Hinen, W.D.Va.2007, 487 F.Supp.2d 747. Mental Health C- 433(2
+3. Procedural due process
+Sex Offender Registration and Notification Act (SORNA) did not violate the procedural due process rights of
+lefendant, a previously-convicted sex offender, by failing to give him actual notice that travel across state line
+subjected him to criminal penalties; defendant had sufficient notice that failing to register was illegal. U.S.
+Hinen, W.D.Va.2007, 487 F.Supp.2d 747. Mental Health Em 433(2)
+4. Substantive due process
+Sex Offender Registration and Notification Act (SORNA) did not, by subjecting to the Act's requirements persons
+who were not in fact convicted of an offense listed as a qualifying sex offense, or whose conviction was set aside,
+violate the substantive due process rights of defendant, a previously-convicted sex offender; defendant fell squarely
+within the category of persons required to register, and his conviction had not been set aside. U.S. | Hinen,
+W.D.Va.2007, 487 F.Supp.2d 747. Mental Health E 433(2)
+5. Standing
+Previously-convicted sex offender who could allege no injuries traceable to the Sex Offender Registration and
+Notification Acts (SORNA) alleged violations of procedural and substantive due process did not have standing to
+challenge the constitutionality of the Act on such grounds. U.S. | Hinen, W.D.Va.2007, 487 F.Supp.2d 747
+Constitutional Law €- 885
+6. Ex post facto
+Sex Offender Registration and Notification Act (SORNA), and the federal offense it created, of failing to register
+as a sex offender (FFR), did not violate the Ex Post Facto Clause by inflicting greater punishment on defendant, a
+previously-convicted sex offender, than was provided by law when he was convicted; Act's legislative history
+7. Commerce clause
+Sex Offender Registration and Notification Act (SORNA), and the federal offense it created, of failing to register
+8. Venue
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=..
+
+
+
+Page 4
+Failing to register as a sex offender, pursuant to the Sex Offender Registration and Notification Act (SORNA), was
+42 U.S.C.A. § 16913, 42 USCA § 16913
+Current through P.L. 110-133 approved 12-6-07
+Copr. (C) 2007 Thomson/West. No Claim to Orig. U.S. Govt. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=... 12/31/2007
+
+
+
+Effective: July 27, 2006
+United States Code Annotated Currentness
+Chapter 151. Child Protection and Safety
+• Subchapter I. Sex Offender Registration and Notificatio
+• Part A. Sex Offender Registration and Notificatio
++ § 16911. Relevant definitions, including Amie Zyla expansion of sex offender definition and
+expanded inclusion of child predators
+In this subchapter the following definitions apply:
+(1) Sex offender
+The term "sex offender" means an individual who was convicted of a sex offense.
+(2) Tier I sex offender
+The term "tier I sex offender" means a sex offender other than a tier Il or tier III sex offender.
+(3) Tier II sex offender
+The term "tier Il sex offender" means a sex offender other than a tier II! sex offender whose offense is
+punishable by imprisonment for more than 1 year and--
+(A) is comparable to or more severe than the following offenses, when committed against a minor, or at
+attempt or conspiracy to commit such an offense against a minor
+(i) sex trafficking (as described in section 1591 of Title 18);
+(i) coercion and enticement (as described in section 2422(b) of Title 18);
+(iii) transportation with intent to engage in criminal sexual activity (as described in section 2423(a))
+of Title 18;
+(iv) abusive sexual contact (as described in section 2244 of Title 18);
+(B) involves--
+(i) use of a minor in a sexual performance;
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H... 12/31/2007
+
+
+
+(ii) solicitation of a minor to practice prostitution; or
+(it) production or distribution of child pornography; or
+(C) occurs after the offender becomes a tier I sex offender.
+(4) Tier III sex offender
+The term "tier III sex offender" means a sex offender whose offense is punishable by imprisonment for more
+than 1 year and--
+(A) is comparable to or more severe than the following offenses, or an attempt or conspiracy to commit
+such an offense:
+(i) aggravated sexual abuse or sexual abuse (as described in sections 2241 and 2242 of Title 18); or
+(i) abusive sexual contact (as described in section 2244 of Title 18) against a minor who has not
+attained the age of 13 years;
+(B) involves kidnapping of a minor (unless committed by a parent or guardian); or
+(C) occurs after the offender becomes a tier Il sex offender.
+(5) Amie Zyla expansion of sex offense definition
+(A) Generally
+(A) Generally
+Except as limited by subparagraph (B) or (C), the term " sex offense" means--
+(i) a criminal offense that has an element involving a sexual act or sexual contact with another;
+(ii) a criminal offense that is a specified offense against a minor;
+(iii) a Federal offense (including an offense prosecuted under section 1152 or 1153 of Title 18) under
+section 1591, or chapter 109A, 110 (other than section 2257, 2257A, or 2258), or 117, of Title 18;
+(iv) a military offense specified by the Secretary of Defense under section 115(a)(8XC)(i) of Public Law
+105-119 (10 U.S.C. 951 note); or
+(1) an attempt or conspiracy to commit an offense described in clauses (i) through (iv).
+(B) Foreign convictions
+(B) Foreign convictions
+A foreign conviction is not a sex offense for the purposes of this subchapter if it was not obtained with
+sufficient safeguards for fundamental fairness and due process for the accused under guidelines or regulations
+established under section 16912 of this title.
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H... 12/31/2007
+
+
+
+(C) Offenses involving consensual sexual conduct
+(C) Offenses involving consensual sexual conduct
+(6) Criminal offense
+The term "criminal offense" means a State, local, tribal, foreign, or military offense (to the extent specified by
+the Secretary of Defense under section 115(a)(8)(C)(i) of Public Law 105-119 (10 U.S.C. 951 note)) or other
+criminal offense.
+(7) Expansion of definition of "specified offense against a minor" to include all offenses by child predators
+The term " specified offense against a minor" means an offense against a minor that involves any of the
+following:
+(A) An offense (unless committed by a parent or guardian) involving kidnapping.
+(B) An offense (unless committed by a parent or guardian) involving false imprisonment.
+(C) Solicitation to engage in sexual conduct.
+(D) Use in a sexual performance.
+(E) Solicitation to practice prostitution.
+(F) Video voyeurism as described in section 1801 of Title 18.
+(G) Possession, production, or distribution of child pornography.
+(H) Criminal sexual conduct involving a minor, or the use of the Internet to facilitate or attempt such
+conduct.
+(I) Any conduct that by its nature is a sex offense against a minor.
+(8) Convicted as including certain juvenile adjudications
+(9) Sex offender registry
+a jurisdiction.
+The term "sex offender registry" means a registry of sex offenders, and a notification program, maintained by
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H... 12/31/2007
+
+
+
+Page 4
+(10) Jurisdiction
+The term "jurisdiction" means any of the following:
+(A) A State.
+(B) The District of Columbia.
+(C) The Commonwealth of Puerto Rico.
+(D) Guam.
+(E) American Samoa.
+(F) The Northern Mariana Islands.
+(G) The United States Virgin Islands.
+(H) To the extent provided and subject to the requirements of section 16927 of this title, a federally
+recognized Indian tribe.
+(11) Student
+The ther p'side or piane a sediniday schol, tal or prated al seduct, and institution orchiding.
+(12) Employee
+compensated or not.
+The term "employee" includes an individual who is self-employed or works for any other entity, whether
+(13) Resides
+The term "resides" means, with respect to an individual, the location of the individual's home or other place
+where the individual habitually lives.
+(14) Minor
+The term "minor" means an individual who has not attained the age of 18 years.
+CREDIT(S)
+(Pub.L. 109-248, Title I, § 111, July 27, 2006, 120 Stat. 591.)
+HISTORICAL AND STATUTORY NOTES
+Revision Notes and Legislative Reports
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H... 12/31/2007
+
+
+
+Page 5
+2006 Acts. Statement by President, see 2006 U.S. Code Cong. and Adm. News, p. S35.
+References in Text
+This subchapter, referred to in text, originally read "this title", meaning Title I [§ 101 et seq.] of Pub.L. 109-248,
+July 27, 2006, 120 Stat. 590, known as the Sex Offender Registration and Notification Act, which enacted this
+subchapter; for complete classification, see Short Title note set out under 42 U.S.C.A. § 16901 and Tables.
+Chapter 109A of Title 18, referred to in par. (5)(A)(iii), is Sexual Abuse, 18 U.S.C.A. § 2241 et seq.
+Chapter 110 of Title 18, referred to in par. (5)(A)(iii), is Sexual Exploitation and Other Abuse of Children, 18
+U.S.C.A. § 2251 et seq.
+Chapter 117 of Title 18, referred to in par. (5)(A)(ii), is Transportation for Illegal Sexual Activity and Related
+Crimes, 18 U.S.C.A. § 2421 et seq.
+Section 115 of Public Law 105-119, referred to in par. (5)(A)(iv), (6), is cl. (i) of Pub.L. 105-119, Title 1, $
+115(a)(8)(C), Nov. 26, 1997, 111 Stat. 2466, which is set out as a note under 10 U.S.C.A. § 951.
+NOTES OF DECISIONS
+Generally !
+Commerce clause 6
+Ex post facto 2|
+Policy safety regulation 5
+Procedural due process 3
+Substantive due process 4
+1. Generally
+2. Ex post facto
+Congress did not violate ex post facto law clause of Constitution by passing Sex Offender Registration and
+Notification Act (SORNA), on grounds that registration requirements were additional punishment inflicted upon
+ce of public safety, rather thar
+oral and ex post facto reut of applied pose to pral prostis sur dera, a 200, 4a
+F.Supp.2d 1257. Mental Health C- 433(2)
+Sex Offender Registration and Notification Act (SORNA), and the federal offense it created, of failing to register
+as a sex offender (FFR), did not violate the Ex Post Facto Clause by inflicting greater punishment on defendant, a
+previously-convicted sex offender, than was provided by law when he was convicted; Act's legislative history
+indicated that Congress's concern was with public safety rather than with a desire to further punish sex offenders,
+and the registration requirements were not so punitive as to negate Congress's intent that they be nonpunitive. U.S.
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H... 12/31/2007
+
+
+
+| Hinen, W.D. Va.2007, 487 F.Supp.2d 747. Mental Health em 433(2)
+3. Procedural due process
+Page 6
+F.Supp.2d 1257. Mental Health Em 433(2)
+4. Substantive due process
+Substantive due process rights of convicted sex offenders was not violated by Sex Offender Registration and
+Notification Act (SORNA), requiring that they register and disclose their whereabouts following release. U.S. I
+Madera, M.D.Fla.2007, 474 F.Supp.2d 1257. Mental Health C- 433(2)
+5. Policy safety regulation
+There was rational public safety basis for regulation of interstate commerce, underlying Sex Offender Registration
+and Notification Act (SORNA) requirements that released offenders report address changes to authorities,
+precluding claim that SORNA violated Commerce Clause. U.S. - Madera, M.D.Fla.2007, 474 F.Supp.2d 1257.
+Mental Health E- 433(2)
+6. Commerce clause
+Sex Offender Registration and Notification Act (SORNA), and the federal offense it created, of failing to register
+as a sex offender (FFR), was a proper exercise of Congressional authority under the Commerce Clause; FFR had at
+cast a de minimis effect on interstate travel, since it regulated sex offenders who traveled across state lines. U.S
+. Hinen, W.D.Va.2007, 487 F.Supp.2d 747. Mental Health Em 433(2)
+42 U.S.C.A. § 16911, 42 USCA § 16911
+Current through P.L. 110-133 approved 12-6-07
+Copr. (C) 2007 Thomson/West. No Claim to Orig. U.S. Govt. Works.
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H... 12/31/2007
+
+
+
+Nestlaw.
+42 U.S.C.A. § 16914
+Effective: July 27, 2006
+United States Code Annotated Currentness
+Title 42. The Public Health and Welfare
+Chapter 151. Child Protection and Safety
+• Subchapter I. Sex Offender Registration and Notificatio
+| Part A. Sex Offender Registration and Notificatio
++ § 16914. Information required in registration
+(a) Provided by the offender
+The sex offender shall provide the following information to the appropriate official for inclusion in the sex
+offender registry:
+(1) The name of the sex offender (including any alias used by the individual).
+(2) The Social Security number of the sex offender.
+(3) The address of each residence at which the sex offender resides or will reside.
+(4) The name and address of any place where the sex offender is an employee or will be an employee.
+(5) The name and address of any place where the sex offender is a student or will be a student.
+(6) The license plate number and a description of any vehicle owned or operated by the sex offender.
+(7) Any other information required by the Attorney General.
+(b) Provided by the jurisdiction
+The jurisdiction in which the sex offender registers shall ensure that the following information is included in the
+registry for that sex offender:
+(1) A physical description of the sex offender.
+(2) The text of the provision of law defining the criminal offense for which the sex offender is registered.
+3) The criminal history of the sex offender, including the date of all arrests and convictions; the status of
+arole, probation, or supervised release; registration status; and the existence of any outstanding arres
+warrants for the sex offender.
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prfi=HTMLE&fn=_top&mt=... 12/31/2007
+
+
+
+42 U.S.C.A. § 16914
+(4) A current photograph of the sex offender.
+(5) A set of fingerprints and palm prints of the sex offender.
+(6) A DNA sample of the sex offender.
+(7) A photocopy of a valid driver's license or identification card issued to the sex offender by a jurisdiction.
+(8) Any other information required by the Attorney General.
+CREDIT(S)
+(Pub.L. 109-248, Title I, § 114, July 27, 2006, 120 Stat. 594.)
+HISTORICAL AND STATUTORY NOTES
+Revision Notes and Legislative Reports
+2006 Acts. Statement by President, see 2006 U.S. Code Cong. and Adm. News, p. S35.
+42 U.S.C.A. § 16914, 42 USCA § 16914
+Current through P.L. 110-133 approved 12-6-07
+Copr. (C) 2007 Thomson/West. No Claim to Orig. U.S. Govt. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prfi=HTMLE&fn=
+_top&mt=... 12/31/2007
+
+
+
+42 U.S.C.A. § 16915
+Effective: July 27, 2006
+United States Code Annotated Currentness
+→ § 16915. Duration of registration requirement
+(a) Full registration period
+A sex offender shall keep the registration current for the full registration period (excluding any time the sex
+offender is in custody or civilly committed) unless the offender is allowed a reduction under subsection (b) of this
+section. The full registration period is--
+(1) 15 years, if the offender is a tier I sex offender;
+(2) 25 years, if the offender is a tier Il sex offender; and
+(3) the life of the offender, if the offender is a tier Ill sex offender.
+(b) Reduced period for clean record
+(1) Clean record
+(1) Clean record
+The full registration period shall be reduced as described in paragraph (3) for a sex offender who maintains a clean
+record for the period described in paragraph (2) by--
+(A) not being convicted of any offense for which imprisonment for more than 1 year may be imposed;
+(B) not being convicted of any sex offense;
+(C) successfully completing any periods of supervised release, probation, and parole; and
+(D) successfully completing of an appropriate sex offender treatment program certified by a jurisdiction or by
+the Attorney General.
+(2) Period
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft-HTMLE&fn=_top&mt=... 12/31/2007
+
+
+
+42 U.S.C.A. § 16915
+(2) Period
+In the case of--
+(A) a tier I sex offender, the period during which the clean record shall be maintained is 10 years; and
+(B) a tier III sex offender adjudicated delinquent for the offense which required registration in a sex registry
+under this subchapter, the period during which the clean record shall be maintained is 25 years.
+(3) Reduction
+(3) Reduction
+In the case of--
+(A) a tier I sex offender, the reduction is 5 years;
+(B) a tier III sex offender adjudicated delinquent, the reduction is from life to that period for which the clean
+record under paragraph (2) is maintained.
+CREDIT(S)
+(Pub.L. 109-248, Title I, § 115, July 27, 2006, 120 Stat. 595.)
+HISTORICAL AND STATUTORY NOTES
+Revision Notes and Legislative Reports
+2006 Acts. Statement by President, see 2006 U.S. Code Cong. and Adm. News, p. S35.
+References in Text
+This subchapter, referred to in subsec. (b)(2)(B) originally read "this title", meaning Title | [§ 101 et seq.] of
+Fracted this sul haper, 2o compose classification, set here Tile note Be out inder 42 U.S.C.A. 8 16901 and
+42 U.S.C.A. § 16915, 42 USCA § 16915
+Current through P.L. 110-133 approved 12-6-07
+Copr. (C) 2007 Thomson/West. No Claim to Orig. U.S. Govt. Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=.. 12/31/2007
+
+
+
+.. F.3d -..., 2007 WL 4510264 (C.A.10 (Utah))
+(Cite as: -- F.3d ---)
+asking whether, viewing it in the light most
+U.S. L. Rakes
+C.A.10 (Utah),2007.
+Only the Westlaw citation is currently available.
+United States Court of Appeals, Tenth Circuit.
+UNITED STATES of America, Plaintiff-Appellee,
+Joe RAKES, Defendant-Appellant.
+No. 06-4208.
+Dec. 26, 2007.
+Background: Defendant was convicted in the
+United States District Court for the District of Utah
+of conspiring to impede or injure an officer, and
+was sentenced to 63 months' imprisonment, and he
+appealed.
+Holdings: The Court of Appeals, Gorsuch, Circuit
+Judge, held that:
+(1) evidence was sufficient to support conviction;
+(2) court did not violate rule of criminal procedure
+requiring court to provide the parties with any
+information on which it would rely in sentencing;
+(3) any violation of rule of criminal procedure
+governing pleas was harmless error; and
+(4) applicable sentencing guideline was guideline
+for threatening or harassing communications.
+Affirmed.
+[1] Criminal Law 110 €-0
+[2] Criminal Law 110 c-0
+110 Criminal Law
+The evidence of the existence of an agreement
+between defendant and another person to prevent
+the victim, a prosecutor, from discharging her duties
+by sending her a threatening letter was sufficient to
+support defendant's conviction for conspiring to
+impede or injure an officer; although coconspirator
+presented alternative and
+conflicting
+testimony
+about nature of her involvement
+in alleged
+conspiracy, including statements suggesting she was
+coerced by defendant, by voices in her head, or
+perhaps by someone else, one of the accounts she
+offered did involve admission of her knowing and
+voluntary participation in scheme with defendant,
+and friend of defendant, who read the letter at
+defendant's apartment, testified defendant told him
+that he and coconspirator had written letter. 18
+U.S.C.A. § 372.
+[3] Criminal Law 110 €-0
+In assessing challenges to the suficiency of the
+appens revi s the evidence piosenied de mo vor
+110 Criminal Law
+In prosecution for conspiring to impede or injure an
+officer, district court did not violate rule of criminal
+procedure requiring sentencing court to provide the
+parties with any information on which it would rely
+in sentencing by failing to disclose at hearing on
+parties' plea agreement that court had received a
+victim impact letter from the prosecutor who was
+the victim in the case; the court did not sentence
+defendant at the hearing on the plea agreement, and
+instead, concluded the hearing by advising the
+parties that it was rejecting the agreement's
+recommended sentence, and would not sentence
+defendant that day in accord with the agreement.
+Fed.Rules Cr.Proc. Rule 32(i)(1)(B), 18 U.S.C.A.
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=... 12/31/2007
+
+
+
+-- F.3d ----
+-.- F.3d •*.*, 2007 WL 4510264 (C.A.10 (Utah))
+(Cite as: --- F.3d =---)
+14] Criminal Law 110 C-0
+110 Criminal Law
+In prosecution for conspiring to impede or injure an
+officer, any violation of rule of criminal procedure
+governing pleas in district court's failure to disclose
+at hearing at which court rejected recommended
+sentence in parties' plea agreement that court had
+received victim impact letter from victim in the case
+was harmless error; after defendant learned of letter,
+he asked court to reconsider rejection of plea
+agreement, and court denied reconsideration, stating
+it would have rejected agreement regardless of letter
+for reasons set forth on record, including court's
+assessment that guidelines advisory sentence for
+crime to which defendant agreed to plead guilty was
+at least double the parties' agreed
+sentence, and
+neither party had offered persuasive reason for such
+a
+disparity. Fed.Rules Cr.Proc.Rule 11(h), 18
+U.S.C.A.
+[5] Senteneing and Punishment 350H C-0
+350H Sentencing and Punishment
+For
+purposes
+of
+defendant's
+sentencing
+for
+conspiring to impede or injure an officer, an offense
+for
+which no sentencing
+guidelines
+range
+was
+designated, most analogous
+guideline,
+and thus,
+applicable
+guideline, was guideline for threatening
+harassing
+communications, rather
+than for
+obstructing or
+impeding
+an
+officer; indictment
+charged conspiracy
+to threaten
+intimidate
+federal prosecutor by writing letter with threatening
+language, listing street on which victim lived, and
+mailing
+letter to victim, and although defendant
+sought to impede prosecution of members of white
+supremacy group, he intended to do so by means of
+premeditated and comparatively complex scheme of
+intimidation rather than by act of simple assault,
+and case proven at trial centered around threatening
+letter.
+§§ 2A2.4, 2A6.1(a)(1), 18 U.S.C.A.
+Appeal from the United States District Court for the
+District of Utah (D.C. No. 2:05-CR-131-TS).
+(Thomas E. Moss, United States Attorney, with him
+on
+the
+brief),
+Pocatello, Idaho,
+Plaintiff-Appellee.
+Before LUCERO, BALDOCK, and GORSUCH,
+Circuit Judges.
+GORSUCH, Circuit Judge.
+*1 Joe Rakes challenges his conviction and
+resulting sentence arising from an
+conspiracy to impede the investigation and
+prosecution of a white supremacy group, the
+Soldiers of Aryan Culture. Specifically, he argues
+that (1) the evidence presented at trial was
+insuficient to establish a conspiracy between him
+and another participant in the alleged scheme; (2)
+the district court improperly rejected his plea
+agreement based on an undisclosed victim impact
+letter; and (3) the district court applied the wrong
+provision of the United States Sentencing
+Guidelines ("Guidelines") in calculating
+• sentence. While none of these arguments is without
+force, we ultimately conclude that none merits
+reversal under our governing standards of review.
+A
+In March 2004, an Assistant United States Attorney
+for the District of Utah in Salt Lake City received a
+threatening letter stating,
+"You stupid bitch! It is
+because of you that my brothers are in jail for the
+Rico. I know you live on the [street name redacted].
+We will get you. til the casket drops."The letter
+apparently referred to an ongoing racketeering
+prosecution under the Racketeer Influenced and
+Corrupt Organization Act ("RICO") that the victim
+prosecutor was pursuing against members of the
+Soldiers of Aryan Culture. As a result of the letter,
+the prosecutor moved out of her home for a month,
+was assigned a United States Marshals detail to
+protect her for a time, and was eventually removed
+from the prosecution in question.
+Jeremy M. Delicino, Salt Lake City, Utah, for
+Defendant-Appellant.
+Jack B. Haycock, Assistant United States Attorney
+The Federal Bureau of Investigation's subsequent
+investigation of the letter led to a woman named
+April Dowding, a friend of two of the RICO
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=... 12/31/2007
+
+
+
+--- F.3d--., 2007 WL 4510264 (C.A.10 (Utah))
+(Cite as: -- F.3d ----)
+defendants who was known to refer to them as her
+brothers. Ms. Dowding identified Mr. Rakes as
+being involved in writing or mailing the threatening
+letter, as did other witnesses, including Laura Scott
+and Doug Errett.
+The government indicted Mr. Rakes in March 2005
+in the District of Utah on two counts: mailing a
+threatening communication, 18 U.S.C. § 876, and
+conspiring to impede or injure an officer, 18 U.S.C.
+§ 372. After initially pleading not guilty, Mr. Rakes
+agreed to enter a plea of guilty to the lesser offense
+misprision of a felony, 18 U.S.C. § 4, in exchange
+for an agreement from the government that the
+appropriate sentence was 9 months imprisonment,
+below the 18 to 24 months suggested by Section
+2X4.1 of
+the
+advisory
+Guidelines.
+See
+Fed.R.Crim.P. 11(c)(1)(C). The court conditionally
+accepted the change of plea, subject to its receipt of
+a presentence report and subsequent sentencing
+hearing.
+Prior to sentencing, the district court received a
+victim impact letter,
+see18 U.S.C. § 3771(a)(4),
+from the victim prosecutor but did not disclose the
+existence of the letter either to defense counsel or
+counsel for the government. At sentencing,
+the
+district court opened the proceeding by expressing
+doubt about the parties' recommended sentence of
+nine months, remarking that it would like them to
+explain how such a sentence would be justifiable
+even though
+it represented only half what the
+advisory Guidelines recommended
+as a minimum
+sentence.
+After argument,
+the district court,
+apparently
+seeing no
+convincing reason for a
+below-Guidelines sentence,
+reversed
+its prior
+conditional
+approval
+plea agreement,
+indicated its belief that a more substantial sentence
+was merited, and explained that it was concerned
+with
+• the very real victim impact presented by in
+se. This is a serious mater, ine impact on
+respected Assistant U.S. Attorney in her role as an
+Assistant U.S. Attorney is very real. Furthermore,
+the impact on her as an individual, on her family is
+R. Ill at 10-1l. With the plea agreement's
+recommended sentence rejected, the district court
+advised Mr. Rakes of his right to withdraw his
+guilty plea and proceed to trial, seeFed.R.Crim.P.
+11(c)(5), a right Mr. Rakes decided to exercise.
+properly punished.
+B
+At trial, Ms. Dowding, the government's primary
+witness, testified that the threatening letter was
+created in Mr. Rakes's apartment but otherwise
+offered contradictory factual scenarios concerning
+its genesis, stating variously that (1) Mr. Rakes
+threatened her into writing the letter; (2) she could
+have been threatened by someone else or the voices
+in her head; and (3) she wrote the letter willingly,
+with the help of Mr. Rakes or at his suggestion,
+because she was upset about the treatment of her
+brothers" in the white supremacy group who were
+charged in the RICO case and were in jail.
+Laura Scott was similarly equivocal in recalling her
+own involvement with the letter. She did testify,
+however, that she was a friend of Mr. Rakes and, at
+his direction and borrowing his car, went to the
+library to look up the address of the victim
+prosecutor. Ms. Scott brought the information back
+to Mr. Rakes at his apartment, where she saw Ms.
+Dowding was writing and had paper and envelopes.
+Doug Errett testified that he was also a friend of Mr.
+Rakes, having known him in prison where they were
+both members of the
+Fourth Reich, a white
+supremacist prison gang. Mr. Errett stated that in
+February 2004 he was at Mr. Rakes's residence with
+Mr. Rakes and Ms. Dowding, where he saw the
+letter in question. At that time Mr. Rakes told him
+he and Ms. Dowding had written the letter to the
+prosecutor on the Soldiers of Aryan Culture case.
+At the close of the government's case, Mr. Rakes
+moved for acquittal on both counts, see
+Fed.R.Crim.P. 29, which the district court granted
+as to Count I, mailing a threatening communication,
+but denied as to Count II, conspiring to impede or
+injure an officer. The jury thereafter found Mr.
+Rakes guilty of the surviving count, and the district
+court denied his renewed Rule 29 motion. Before
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=.. 12/31/2007
+
+
+
+... F.3d --•, 2007 WL 4510264 (C.A.10 (Utah))
+(Cite as: --- F.3d -.--)
+sentencing, Mr. Rakes filed a motion for disclosure
+of any victim impact statements pursuant to Rule 32
+of the Federal Rules of Criminal Procedure, which
+the district court granted, providing both parties the
+letter it had received from the victim prosecutor.
+Because the district court had not disclosed the
+letter at the plea agreement stage, Mr. Rakes moved
+he district court to reconsider the plea agreement
+and recuse itself so another judge could handle the
+inquiry. The district court denied the motion.
+*3 In preparing its presentence report, the probation
+office encountered a different sort of complication.
+Because Mr. Rakes's offense, conspiracy to impede
+or injure an officer, 18 U.S.C. § 372, does not have
+an assigned Senteneing Guidelines section, the
+probation office
+required
+analogize to
+another Guidelines section and ultimately chose to
+employ Section 2A6.1(a)(I),
+which covers certain
+crimes
+involving
+threatening
+harassing
+communications and has a base offense level of 12.
+Mr.
+objected,
+arguing
+that the
+analogous guideline was Section 2A2.4, relating to
+obstructing or impeding a law enforcement officer,
+with a base offense level of 10. The district court
+overruled Mr. Rakes's objection and, employing
+Section 2A6.1(a)(1), sentenced Mr. Rakes to 63
+months imprisonment.EN1
+II
+Page 4
+Cir.2004). While our standard of review is
+deferential to be sure, we will not uphold a
+conviction obtained by piling inference upon
+inference, and the evidence supporting a conviction
+must do more than raise-amere suspiz or d iait,
+United States
+1262-63 (10th Cir. 1998).
+Mr. Rakes argues that Ms. Dowding could not have
+been a willing coconspirator with him because she
+co-conspirator knowingly and voluntarily joined the
+conspiracy). This argument is, of course, addressed
+solely to whether a conspiracy existed between Mr.
+Rakes and Ms. Dowding and does not contemplate
+the possibility that, even without Ms. Dowding, the
+jury could have found a voluntary agreement
+between Mr. Rakes and Ms. Scott or perhaps Mr.
+Errett. Because in its briefing before us the
+government also pursues the theory that the
+conspiracy was primarily between Mr. Rakes and
+Ms. Dowding, and because we agree that suficient
+evidence of such a conspiracy was presented, we
+accept for our current purposes Mr. Rakes's premise
+that the conspiracy was only between Ms. Dowding
+[][2] On appeal, Mr. Rakes first contends that the
+government presented insufficient evidence at trial
+essential element of his crime-namely, the
+existence of an agreement between him and another
+person to prevent the victim from discharging her
+duties by the use of force, violence, or intimidation.
+In assessing such sufficiency challenges, we review
+the evidence presented de novo, asking whether,
+viewing it in the light most favorable to the
+government, as the prevailing party, any rational
+trier of fact could have found the essential elements
+of the crime beyond a reasonable doubt. In so
+doing, we do not weigh conflicting evidence or
+credibility, but ask only whether the government's
+evidence, credited as true, would establish the
+elements of the
+crime. United States
+Delgado-Uribe, 363 F.3d 1077, 1081 (10th
+Viewing the case in this light, we begin by readily
+acknowledging
+alternative and conflicting testimony about
+nature of her involvement in the alleged conspiracy,
+including statements suggesting she was coerced by
+Mr. Rakes, by voices in her head, or perhaps by
+someone else. But one of the accounts she offered
+did involve an admission of her knowing and
+voluntary participation in a scheme with Mr. Rakes.
+In our judicial system, the jury, as factfinder, was
+charged with the task of sifting the wheat from the
+chaff, discerning which (if any) of Ms. Dowding's
+accounts merited belief. See Young | Sirmons, 486
+F.3d 655, 666 (10th
+([lt is] the
+responsibility of the trier of fact fairly to resolve
+conflicts in the testimony, to weigh the evidence,
+to d ti are acas (gublin lachson oT)
+U.S. 307, 319, 99 S.Ct. 2781, 61
+(1979)). Of course, a jury is not free to credit
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=.. 12/31/2007
+
+
+
+.-- F.3d ----
+... F.3d -.., 2007 WL 4510264 (C.A.10 (Utah))
+estimony beyond the pale of reason, see Parker
+Scott, 394 F.3d 1302,
+1315 (10th Cir.2005
+(distinguishing inconsistent testimony from that
+which is "inherently implausible"), but we are not
+allowed to substitute our judgment for that of the
+jury when it comes to deciding which rationally
+plausible account of the facts to credit, see Young.
+486 F.3d at 666.
+*4 Though the question whether Ms. Dowding was
+worthy of belief in any of her accounts is not one
+that can be reflexively dismissed, neither can we say
+that no rational jury could have credited her
+testimony that she wrote the letter willingly, with
+the help of, or at the suggestion of, Mr. Rakes. It
+seems to us that the jury could have reasonably
+concluded that this particular version of events was
+more believable than Ms. Dowding's alternative
+explanations, and that her alternative explanations
+were calculated to minimize her own culpability and
+rationalize her willing involvement with Mr. Rakes.
+Bolstering the plausibility of such a conclusion is
+the fact that Ms. Dowding was not the sole source
+of evidence about the agreement between herself
+and Mr. Rakes. Mr. Errett, who read the threatening
+letter at Mr. Rakes's apartment, testified that Mr.
+Rakes told him that he and Ms. Dowding had
+written the letter. Ms. Scott likewise testified that,
+after she looked up the address of the victim at the
+library, she brought it back to Mr. Rakes at his
+apartment, where Ms. Dowding, under no apparent
+duress, was writing and had paper and envelopes.
+To the extent that the jury believed either or both of
+Page 5
+[3] Mr. Rakes next contends that the district court
+committed reversible error by failing to disclose the
+victim impact letter during the course of its hearing
+on the parties' plea agreement.EN2In aid of his
+argument, Mr. Rakes rests primarily on Rule 32 of
+the Federal Rules of Criminal Procedure, which
+requires a sentencing court to provide both parties
+with any information on which it will rely in
+sentencing and give them a reasonable opportunity
+to comment on the information. SeeFed.R.Crim.P.
+32(i)(1)(B). Under our case law, failing to disclose
+evidence on which the court relied in sentencing
+may result in a remand for resentencing. See United
+• Alvarado, 909 F.2d 1443, 1444-46 (10th
+Cir. 1990).
+and thus help
+plausible,
+Ms. Dowding's version of the events in
+which she and Mr. Rakes knowingly and voluntarily
+conspired.
+While this case surely required the jury to pick and
+choose among competing versions of events, with at
+least three witnesses testifying that Ms. Dowding
+and Mr. Rakes worked together on the threat letter
+we cannot say, as we must for Mr. Rakes to prevail,
+that no rational trier of fact could have found
+beyond a reasonable doubt that Ms. Dowding and
+Mr. Rakes entered into an agreement aimed at
+preventing the victim prosecutor from performing
+her job by means of force, violence, or intimidation.
+We agree with Mr. Rakes and the government that it
+would have been better for the district court to have
+provided the parties with copies of the vietim
+impact letter prior to its disposition of the plea
+agreement. Doing
+would have made more
+transparent the district court's concerns about
+whether the plea agreement's proposed sentence
+adequately accounted for the crime's impact on the
+victim prosecutor and would have allowed the
+parties to address those concerns more intelligently.
+But, by its plain terms, Rule 32(i)(1)(B) obligates
+the district court to provide the parties advance
+access to information on which it "will rely in
+sentencing." And the harm it seeks to safeguard
+against is sentencing based on evidence that the
+parties have not had reasonable notice
+of and
+opportunity to address. See United States Begay,
+117 Fed.Appx. 682, 683 (10th Cir.2004) (noting
+Rule 32 seeks "to ensure that sentencing is based on
+reliable facts found by the court itself after
+deliberation") FN3 Here, however, the court did not
+sentence Mr. Rakes. Instead, it concluded the
+hearing by advising the parties that it would not
+sentence Mr. Rakes that day in accord with their
+plea agreement. Had the court proceeded to issue
+something other than the parties' agreed sentence
+first affording
+meaningful
+opportunity to review and comment on the victim's
+letter, Rule 32(iX1XB) surely would have been
+implicated and we would have before us a very
+different case. As it is, however, we cannot say the
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=.
+
+
+
+-- F.3d --.
+... F.3d •..., 2007 WL 4510264 (C.A.10 (Utah))
+(Cite as: -- F.3d -=--)
+Page 6
+rule, by its plain terms, was violated, or that the
+harm it seeks to avoid was implicated. In fairness to
+the district court we must also note that, although
+the parties did not have the victim's letter, they were
+at least on notice of its existence and could have
+sought its production. The presentence report
+prepared for the plea hearing explicitly stated, under
+"Victim Impact," that "[the victim] is preparing a
+statement that will be submitted directly to the
+Court. "P.S.R. of Oct. 5, 2005 at 9 11.
+*5 [4] Beyond Rule 32, there remains in our view a
+distinct and even more germane question, A district
+court enjoys substantial discretion in deciding
+whether to accept or reject a plea agreement under
+Rule 11. SeeFed.R.Crim.P. 11(c)(3); United States
+Robertson, 45 F.3d 1423, 1438 (10th Cir. 1995);
+United States | Carrigan, 778 F.2d 1454, 1461-62
+(10th Cir. 1985). But that discretion is not without
+limit. See Robertson, 45 F.3d at 1438. While a
+defendant has no absolute right to have his plea
+agreement accepted, in our supervisory capacity we
+have placed some boundaries on the district court's
+discretion-requiring district courts, for example, to
+articulate reasons on the record if and when they
+decide to reject such agreements in order, among
+other things,
+*to insure
+district
+courts exercise
+sound judicial discretion. "Id. Though Mr. Rakes's
+brief primarily discusses
+Rule
+32.
+we
+also
+understand him to suggest that, even if Rule 32 is
+not implicated, a district
+court
+cannot exercise
+sound judicial discretion under Rule 11 in rejecting
+a plea agreement when it acts on
+the basis of
+undisclosed evidence, and this strikes us as a very
+different and more appropriately targeted question.
+The parties, however, have directed
+us to no
+authority on this issue and, at the end of the day, we
+After Mr. Rakes became aware of the victim impact
+letter, he asked the district court to reconsider its
+decision to reject the parties' plea agreement,
+arguing that the court's decision had improperly
+relied on undisclosed information. The district court
+denied
+reconsideration,
+citing, among other
+grounds, the fact that it "would have rejected the
+plea agreement regardless of the letter for the
+reasons set forth plainly on the record."Sealed
+Mem. Decision and Order, at 5. Those reasons
+included the district court's assessment that the
+Guidelines advisory sentence for the crime to which
+Mr. Rakes agreed to plead guilty was at least double
+that of the parties' agreed sentence and neither party
+had offered a persuasive reason for such a disparity
+under the facts and circumstances of this case.
+Before us on appeal, Mr. Rakes likewise offers us
+no reason to doubt the district court's assessment,
+making no attempt to show why such a disparity
+would have been warranted. Neither does he
+identify, nor did he state in his motion to reconsider,
+what information in the victim's letter was incorrect
+or what arguments addressing it he would have
+made to the district court. Without being given some
+reason to think that a sentencing court would have
+reached a different outcome in the disposition of the
+plea agreement had the letter been disclosed, we are
+compelled to conclude that, even taking the district
+court's failure to disclose the letter to be error, it
+was harmless error.
+IV
+of a plea agreement are violated, any such error is
+to be deemed "harmless error if it does not affect
+substantial rights. "Fed.R.Crim.P. 11(h); see also
+Fed.R.Crim.P.
+52(a)
+(Any
+error,
+defect,
+irregularity, or variance that does not affect
+substantial
+rights must be disregarded."). On
+balance, we think this mandate applies here.
+*6 [5] After trial, the district court sentenced Mr.
+Rakes on the sole surviving charge, 18 U.S.C. § 372
+, in accord with Section 2A6.1(a)(I), the guideline
+for threatening or harassing communications. Mr.
+Rakes argues that the most analogous guideline is
+instead Section 2A2.4, pertaining to obstructing or
+impeding an officer, and that his sentence was
+therefore in error.
+In approaching this dispute, we note at the outset
+that it is common ground between the parties that
+the Sentencing Guidelines Manual does not specify
+a sentencing range for Mr. Rakes's offense, and so
+the district court was obliged to
+, "apply the most
+analogous offense guideline [or,][i]f there is not a
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=
+_ top&mt=...
+
+
+1176
+476 FEDERAL REPORTER; 3d SERIES
+UNITED STATES of America,
+Plaintiff-Appellee,
+Justin EVANS, Defendant-Appellant.
+No. 06-10907.
+United States Court of Appeals,
+Eleventh Cireuit.
+cerning the court's subject matter jurisdiction.
+2. Criminal Law e=1139
+Whether a statute is unconstitutional
+as applied is a question of law subject to de
+novo review.
+3. Commerce 6-826
+Jan. 30, 2007.
+Background: Defendant was convicted in
+the United States District Court for the
+Southern District of Florida, No. 05-20444-
+satisfied interstate-commerce element of
+CR-PAS, Patricia A. Seitz, J., of enticing a
+minor to engage in a commercial sex act,
+Trafficking Vietims Protection Act (TVPA)
+and enticing a minor to engage in prostituprovision prohibiting the enticing of a mition, and he appealed.
+nor to engage in a commercial sex act;
+defendant's enticement of child to commit
+Holdings: The Court of Appeals, Bowman, Cireuit Judge, sitting by designation,
+prostitution had the capacity, when considheld that:
+ered in the aggregate with similar conduct
+by others, to frustrate Congress's broader
+(1) even though all of defendant's conduct
+regulation of interstate and foreign ecoinvolving child occurred solely within
+the state of Florida, defendant's conduet satisfied interstate-commerce ele- 4. Commerce •-82.6
+ment of Trafficking Victims Protection
+Act (TVPA) provision prohibiting the
+pins Prection 4. Commere -826
+nomic activity. 18 U.S.C.A. § 1591(a).
+Infants •-13
+enticing of a minor to engage in a
+Trafficking Vietims Protection Act
+commercial sex act, and
+(TVPA) provision prohibiting the enticing
+of a minor to engage in a commercial sex
+(2) defendant's use of telephones and celact does not require knowledge by a defenlular telephones, even without evidence
+dant that his actions are in or affecting
+that the calls he made were routed
+interstate commerce. 18 U.S.C.A.
+through an interstate system, was suf-
+§ 1591(a)(1).
+ficient to satisfy interstate-commerce
+element of statute prohibiting enticing 5. Commerce 67(2)
+a minor to engage in prostitution.
+Under Congress's Commerce Clause
+Affirmed.
+authority, Congress is empowered to regulate and protect the instrumentalities of
+1. Criminal Law 6-1139, 1149
+interstate commerce even though the
+A district court's denial of a motion to threat may come only from intrastate acdismiss an indietment is generally re- tivities. U.S.C.A. Const. Art. 1, § 8, cl. 3.
+viewed for abuse of discretion; however,
+when the motion to dismiss the indietment 6. Commerce e-59
+challenges the court's subject matter juris-
+Telephones and cellular telephones
+diction, appellate court reviews de novo are instrumentalities of interstate comthe district court's interpretation and ap- merce for purposes of Commerce Clause.
+plication of the statutory provisions con- U.S.C.A. Const. Art. 1, § 8, cl. 3.
+
+
+U.S. | EVANS
+Cite as 476 F.3d 1176 (11th Cir. 2007)
+1177
+7. Commerce 6-82.10
+I.
+Prostitution •15
+A federal grand jury indicted Evans and
+Defendant's use of telephones and cel- two co-defendants for their roles in operatlular telephones, even without evidence ing a child prostitution ring in Miamithat the calls he made were routed Dade County, Florida. Evans filed a mothrough an interstate system, was suffi- tion to dismiss the indietment, contending
+cient to satisfy interstate-commerce ele- that the evidence upon which the government of statute prohibiting enticing a mi-ment planned to rely would not satisfy the
+nor to engage in prostitution. 18 U.S.C.A.
+interstate-commerce element of the statutes under which he was charged. Thereafter, the parties agreed to proceed by
+way of a conditional guilty plea. Evans
+pleaded guilty to violating 18 U.S.C.
+Faith Mesnekoff and Richard C. Klugh,
+Jr., Fed. Pub. Defenders, Jacqueline Esther Shapiro, Asst. Fed. Pub. Def., Miami,
+FL, Kathleen M. Williams, Fed. Pub. Def.,
+West Palm Beach, FL, for Evans.
+Lisa T. Rubio, Dawn Bowen, Anne R.
+Schultz, Asst. U.S. Atty., Miami, FL, for
+U.S.
+§5 1591(a)(1) and 2422(b), but reserved his
+right to pursue his motion to dismiss the
+indictment. See Fed.R.Crim.P. 11(a)(2).
+The parties agreed to the following relevant faets, either in the Factual Proffer to
+Support the Guilty Plea or at the hearing
+on the motion to dismiss the indictment.
+From December 2004 until May 2005, a
+fourteen-year-old girl ("Jane Doe") worked
+Appeal from the United States Distriet
+Court for the Southern District of Florida.
+for Evans as a prostitute in Miami-Dade
+County. Evans arranged "dates" for Jane
+Before TJOFLAT, HULL and
+Doe at local hotels, and Jane Doe gave the
+BOWMAN, " Circuit Judges.
+money she earned on these dates to Ev-
+ans. To inform Jane Doe of dates that he
+BOWMAN, Circuit Judge:
+had arranged, Evans called Jane Doe on a
+Justin Evans appeals his convictions for
+cellular telephone that she had acquired
+enticing a minor to engage in a commercial
+from him. Evans also gave Jane Doe's
+sex act in violation of 18 U.S.C.
+cellular telephone number to customers
+§ 1591(a)(1), and enticing a minor to enand told Jane Doe to arrange dates when
+gage in prostitution in violation of 18
+customers called. During the dates, Ev-
+U.S.C. § 2422(b). Evans asserts that the
+ans called Jane Doe on the cellular teledistrict court erred in denying his motion phone to "check up on her." Governto dismiss the indictment. Specifically, ment's Sur-Reply to Motion to Dismiss at
+Evans challenges the constitutionality of 3. Evans supplied Jane Doe with condoms
+§ 1591(a)(1) and § 2422(b) as applied to for use on the dates. The condoms were
+his purely local actions and the sufficieney usually Lifestyle brand, which are manuof the stipulated facts to satisfy the juris- factured overseas, imported into Georgia,
+dictional interstate-commerce elements of and then distributed throughout the Unitthe offenses. After review and oral argu- ed States. In February 2005, Jane Doe
+ment, we affirm.
+was hospitalized for eleven days, during
+* Honorable Pasco M. Bowman II, United
+States Circuit Judge for the Eighth Circuit,
+sitting by designation.
+
+
+1178
+476 FEDERAL REPORTER, 3d SERIES
+which time she was diagnosed with AIDS.
+A few days after Jane Doe's release from
+[3] Count One of the indietment
+the hospital, Evans called her on a land- charged Evans with violating 18 U.S.C.
+line telephone and induced her to resume § 1591(a)(1), which imposes punishment on
+her work as a prostitute for him. Jane
+anyone who "knowingly in or affecting in-
+Doe worked for Evans until May 2005, terstate or foreign commerce, ... recruits,
+when she was again hospitalized for AIDS
+entices, harbors, transports, provides, or
+obtains by any means a person ... know-
+The district court determined that Ev- ing ... that the person has not attained
+ans's conduct satisfied the "in or affecting the age of 18 years and will be caused to
+interstate or foreign commerce" element of engage in a commercial sex act." 18
+$ 1591(a)(1) and the "using ... any facility U.S.C. $ 1591(a)(1) (emphasis added).
+or means of interstate or foreign commerce" element of § 2422(b). Accordingduct involving Jane Doe occurred solely
+ly, the distriet court denied Evans's motion
+within the state of Florida, it cannot supto dismiss the indictment. Evans appeals.
+ply the necessary factual predicate for the
+interstate-commerce
+element
+of
+§ 1591(a)(1). We disagree.
+Pursuant to authority conveyed by the
+[1,2] Generally, we review a distriet
+Commerce Clause of the United States
+court's denial of a motion to dismiss an
+Constitution, "Congress has the power to
+indictment for abuse of discretion.
+regulate activities that substantially affect
+United States v. Noriega, 117 F.3d 1206,
+interstate commerce." Gonzales v. Raich,
+1211 (11th Cir.1997), cert. denied, 523 U.S.
+545 U.S. 1, 17, 125 S.Ct. 2195, 162 L.Ed.2d
+1060, 118 S.Ct. 1389, 140 L.Ed.2d
+1 (2005). The Supreme Court has inter-
+(1998). When the motion to dismiss the
+preted this power broadly to include the
+indictment challenges the court's subject
+"power to regulate purely local activities
+matter jurisdietion, however,
+that are part of an economic 'class of acde novo the district court's interpretation
+tivities' that have a substantial effect on
+and application of the statutory provisions
+interstate commerce." Id. "[W]here
+concerning the court's subject matter ju-
+Congress has attempted to regulate (or
+risdiction." United States v. McPhee, 336
+eliminate) an interstate market, Raich
+F.3d 1269, 1271 (11th Cir.2003); see also
+grants Congress substantial leeway to reg-
+United States v. Drury, 396 F.8d 1303,
+ulate purely intrastate activity (whether
+1312 (11th Cir.) (applying a de novo stan- economic or not) that it deems to have the
+dard of review in determining whether the capability, in the aggregate, of frustrating
+evidence was sufficient to satisfy the inter- the broader regulation of interstate ecostate-commerce element of 18 U.S.C. nomie activity." United States v. Max-
+§ 1958(a)), cert. denied, — U.S. —, 126 well, 446 F.3d 1210, 1215 (11th Cir.), cert.
+S.Ct. 336, 163 L.Ed.2d 48 (2005). Whether denied, — U.S. —, 127 S.Ct. 705, 166
+a statute is unconstitutional as applied is L.Ed.2d 545 (2006). Thus, in Raich, the
+also a question of law subject to de novo Supreme Court upheld the application of
+review. United States v. Ballinger, 395 the federal Controlled Substances Act
+F.3d 1218, 1225 (11th Cir.) (en banc), cert. ("CSA") to the purely intrastate growth
+denied, — U.S. —, 126 S.Ct. 368, 163 and use of marijuana for medical pur-
+L.Ed.2d 77 (2005).
+poses. 545 U.S. at 9, 125 S.Ct. 2195. The
+
+
+U.S. | EVANS
+1179
+Cite as 476 F.3d 1176 (11th Cir. 2007)
+Court found that the CSA created a com- curring solely within Florida.
+prehensive framework for regulating con- 1591 was enacted as part of the Trafficking
+trolled substances and that Congress had Victims Protection Act of 2000 ("TVPA"),
+a rational basis to conclude that intrastate Pub.L. No. 106-886, 114 Stat. 1464 (codiconduct could substantially affect its abili- fied as amended in scattered titles of
+ty to regulate interstate commerce. Id. at
+U.S.C.). Like the CSA and the CPPA, the
+30, 32, 125 S.Ct. 2195.
+TVPA is part of a comprehensive regulato-
+Applying Raich, our Court recently re- ry scheme. The TVPA criminalizes and
+jected arguments that purely intrastate attempts to prevent slavery, involuntary
+conduct could not be prosecuted under the servitude, and human trafficking for comfederal Child Pornography Prevention Act mercial gain.' Congress recognized that
+of 1996 ("CPPA"). First, in Mazwell, we human trafficking, particularly of women
+held that 18 U.S.C. § 2252A(a)(5)(B) was and children in the sex industry, "is a
+not unconstitutional as applied to a defenmodern form of slavery, and it is the largdant's intrastate possession of child porest manifestation of slavery today." 22
+nography, even though no evidence indi-
+U.S.C. § 7101(b)(1); see also id at
+cated that the defendant's conduet was
+$ 7101(b)(2), (4), (9), (11). Congress found
+likely to impact interstate commerce. 446
+that trafficking of persons has an aggre-
+F.3d at 1217-19. We noted that the CPPA
+gate economic impact on interstate and
+is part of a comprehensive regulatory
+foreign commerce, id. § 7101(b)(12), and
+scheme criminalizing, inter alia,
+we cannot say that this finding is irrationduction, possession, and sale of child pornography and that Congress could rationally conclude that the cumulative effect of
+[4] Evans's enticement of Jane Doe to
+local possession of child
+commit prostitution, even though his acwould substantially affect the interstate
+tions occurred solely in Florida, had the
+commerce that Congress was seeking to
+capacity when considered in the aggregate
+Id. at 1217-19. Similarly, in
+with similar conduct by others, to frustrate
+United States v. Smith, we rejected the
+Congress's broader regulation of interstate
+argument that 18 U.S.C. § 2251(a) was
+and foreign economic activity. As noted
+unconstitutional as applied to the intraby the district court, "While [Evans's] acstate production of child pornography.
+tivities may be minor in the national and
+459 F.3d 1276, 1284-85 (11th Cir.2006),
+international market of trafficking children
+cert. denied, 75 U.S.L. W. 3352 (U.S. Jan. 8,
+for commercial sex acts, his acts contribute
+2007) (No. 06-7780).
+to the market that Congress'[s] compre-
+§ 2251(a), like § 2252A(a)(5)(B), is part of
+hensive scheme seeks to stop." Order of
+a comprehensive regulatory scheme that Nov. 23, 2005, at 10. Evans's use of hotels
+could be frustrated by purely intrastate that served interstate travelers and distriactivity considered in the aggregate. Id. bution of condoms that traveled in interstate commerce are further evidence that
+We have no difficulty concluding that Evans's conduct substantially affected in-
+Raich, Maxwell, and Smith foreclose Ev- terstate commerce. See United States o.
+ans's challenge to the constitutionality of Pipkins, 878 F.3d 1281, 1295 (11th Cir.
+§ 1591(a)(1) as applied to his activities oc- 2004) (holding that evidence that "pimps
+1. Section 1591 docs not criminalize all acts of
+prostitution (a vice traditionally governed by
+state regulation). Rather, its reach is limited
+to sex trafficking that involves children or is
+accomplished by force, fraud, or coercion.
+18 U.S.C. § 1591(a).
+
+
+1180
+476 FEDERAL REPORTER, 3d SERIES
+furnished their prostitutes with condoms prostitution." 18 U.S.C. § 2422(b) (emmanufactured out of state ... supports a phasis added). Evans argues that the
+finding that the activities of the enterprise government did not establish § 2422(b}s
+affected interstate commerce"), vacated on interstate-commerce element because, alother grounds, 544 U.S. 902, 125 S.Ct.
+though Evans admitted using both a cellu-
+1617, 161 L. Ed.2d 215, opinion reinstated,
+lar telephone and a land-line telephone to
+412 F.3d 1251 (11th Cir.), cert. denied, —
+entice Jane Doe to engage in prostitution,
+-, 126 S.Ct. 591, 163 L.Ed.2d 492
+no evidence was presented that his intra-
+(2005). Therefore, Evans's conduct suffistate calls were routed through interstate
+ciently satisfies the interstate-commerce
+channels. This argument is without merit.
+element of 18 U.S.C. § 1591(a) and his asapplied constitutional challenge fails.?
+[5-7] Under Congress's Commerce
+Clause authority, "Congress is empowered
+to regulate and protect the instrumentalities of interstate commerce ...
+even
+though the threat may come only from
+intrastate activities." United States u. Lo-
+pez, 514 U.S. 549, 558, 115 S.Ct. 1624, 131
+L.Ed.2d 626 (1995). Telephones and cellular telephones are instrumentalities of interstate commerce.
+See Pipkins, 378 F.3d
+at 1295; Ballinger, 395 F.3d at 1226. Ev-
+urged by Evans. Nor is there anything in the
+legislative history of § 1591 suggesting that
+Congress intended the statute to reach only
+those sex traffickers who knew they were acting in or affecting interstate or foreign commerce. The Supreme Court has directed that
+"the existence of the fact that confers federal
+jurisdiction need not be one in the mind of
+the actor at the time he perpetrates the act
+Count Four of the indictment charged
+Evans with violating 18 U.S.C. § 2422(b),
+which imposes punishment on anyone who,
+"using the mail or any facility or means
+of interstate or foreign commence, ...
+knowingly persuades, induces, entices, or
+coerces any individual who has not attained the age of 18 years, to engage in
+2. At oral argument, Evans's counsel asserted
+that the term "knowingly" modifies the inter-
+§ 1591(a) and that the government was therefore required to prove that Evans knew that
+his actions were in or affecting interstate or
+foreign commerce. This argument was not
+made to the district court or raised in Evans's
+brief on appeal, and we would ordinarily
+See Solantic, LIC v. City of
+Neptune Beach, 410 F.3d 1250, 1256 п. 6
+(11th Cir.2005) (holding that a statutory-interpretation argument raised for the first time at
+oral argument and not raised in the district
+United States Silvastri, 409 .3d 1311, 1332
+n. 18 (11th Cir.) ('Under the law of this
+Circuit, an issue not raised in a party's initial
+appellate brief is considered waived, and the
+party is prohibited from raising the issue later
+in the appeal."). cert. denied, — U.S.
+126 S.Ct. 772, 163 L.Ed.2d 598 (2005); see
+also Plea Agreement at 4 ("This reservation of
+the defendant's right to appeal is limited to
+arguments that are raised in district court.").
+Because this argument might be regarded as
+a challenge to our jurisdiction, however, we
+We are unaware of any court that has
+adopted the narrow reading of § 1591(a)
+S.Ct. 1255, 43 L.Ed.2d 541 (1975); see also
+Smith, 459 F.3d at 1287-89 (applying plain
+error standard of review and rejecting the
+argument that the term "knowingly" applies
+to the interstate-commerce element of 1
+U.S.C. 5 2252A(a)(SXB)); United States
+Darby, 37 F.3d 1059, 1067 (4th Cir.1994)
+("Numerous cases have held that criminal
+statutes based on the government's interest in
+regulating interstate commerce do not generally require that an offender have knowledge
+of the interstate nexus of his actions."), cert.
+denied, 514 U.S. 1097, 115 S.Ct. 1826, 131
+L.Ed.2d 747 (1995). Accordingly, we reject
+Evans's request to construe § 1591(a) as requiring knowledge by a defendant that his
+actions are in or affecting interstate com-
+
+
+U.S. HASSOUN
+Cite as 476 F.3d 1181 (11th Cir. 2007)
+ans's use of these instrumentalities of interstate commerce alone, even without evidence that the calls he made were routed
+through an interstate system, is sufficient
+to satisfy § 2422(b)'s interstate-commerce
+element. Accord United States v. Gilbert,
+181 F.3d 152, 158-59 (1st Cir.1999) (citing
+cases and ruling that the intrastate use of
+a telephone provides a sufficient basis for
+jurisdiction based on interstate commerce
+even absent evidence that the call is routed
+through an interstate system); United
+States v. Weathers, 169 F.3d 336, 341 (6th
+Cir.) ("It is well established that telephones, even when used intrastate, constitute instrumentalities of interstate commerce. Similarly, cellular telephones,
+even in the absence of evidence that they
+were used to make interstate calls, have
+been held to be instrumentalities of interstate commerce." (citations and emphasis
+omitted)), cert. denied, 528 U.S. 838, 120
+S.Ct. 101, 145 L.Ed.2d 85 (1999). Thus,
+the district court did not err in determining that § 2422(b) reached Evans's conduct and in denying Evans's motion to
+dismiss Count Four.
+1181
+UNITED STATES of America,
+Plaintiff-Appellant,
+Adham Amin HASSOUN, Kifah Wael
+Jayyousi, a.k.a. Abu Mohamed, Jose
+Padilla, a.k.a. Ibrahim, a.k.a. Abu Ab
+dullah Al Mujahir, a.k.a. Abu Abu Ab
+dullah the Puerto Rican, Defendants-
+Appellees.
+III.
+For the foregoing reasons, we affirm
+Evans's convictions.
+Affirmed.
+No. 06-15845.
+United States Court of Appeals,
+Eleventh Circuit.
+Jan. 30, 2007.
+Background: Five defendants were
+charged with various crimes arising from
+their alleged participation in a support cell
+with the aim of promoting violent jihad as
+espoused by a radical Islamic fundamentalist movement. Three of the defendants
+moved to dismiss, on double jeopardy
+grounds, first count of the indietment,
+which charged defendants with conspiracy
+to murder, kidnap, and maim outside the
+United States, as multiplicitous of counts
+two and three, which charged defendants
+with conspiracy to provide material support for the conspiracy alleged in the first
+count, and actual provision of such material support. The United States District
+Court for the Southern District of Florida,
+No. 04-60001-CR-MGC, 2006 WL 2415946,
+Marcia G. Cooke, J., granted motion, and
+enied Government's motion for reconsi
+ration. Government appealed.
+Holding: The Court of Appeals, Tjoflat,
+Cireuit Judge, held that counts were not
+multiplieitous and did not violate Double
+Reversed and remanded with instructions.
+1. Criminal Law 659(5)
+Pursuant to federal aiding and abetting statute, one who has been indicted as
+
+
+Page 1 of 3.
+104 Fed.Appx. 479, 2004 WL 1491625 (C.A.6 (Tenn.))
+(Cite as: 104 Fed.Appx. 479)
+U.S. I. Kisor
+C.A.6 (Tenn.),2004.
+This case was not selected for publication in the
+Federal Reporter.NOT RECOMMENDED FOR
+FULL--TEXT PUBLICATIONSixth Circuit Rule
+28(g) limits citation to specific situations. Please
+see Rule 28(g) before citing in a proceeding in a
+court in the Sixth Circuit. If cited, a copy must be
+served on other parties and the Court.Please use
+FIND to look at the applicable circuit court rule
+before citing this opinion. Sixth Circuit Rule 28(g).
+(FIND CTA6 Rule 28.)
+United States Court of Appeals,Sixth Circuit.
+UNITED STATES of America, Plaintiff-Appellee,
+V.
+William Ray KISOR, II, Defendant-Appellant.
+No. 02-5578.
+June 22, 2004.
+Background: Defendant was convicted in the
+United States District Court for the Western District
+of Tennessee of using facility or means of interstate
+commerce to knowingly persuade minor to engage
+in prohibited sexual acts, and he appealed.
+Holding: The Court of Appeals, Forester, Chief
+District Judge, held that district court did not abuse
+its discretion by refusing to ask defendant's
+proposed question during voir dire.
+Affirmed.
+West Headnotes
+Jury 230 €-131(8)
+230 Jury
+230V Competency of Jurors, Challenges, and
+Objections
+230k124 Challenges for Cause
+230k131 Examination of Juror
+230k131(8) k. Personal Opinions and
+Conscientious Scruples. Most Cited Cases
+District court did not abuse its discretion in
+prosecution for using facility or means of interstate
+commerce to knowingly persuade minor to engage
+in prohibited sexual acts in declining to ask
+potential jurors during voir dire whether they
+believed 16-year old girl could persuade adult male
+to engage in sexual activity, even if defendant's
+intended defense was that victim persuaded him to
+engage in sexual activity. 18 U.S.C.A. § 2422.
+*479 On Appeal from the United States District
+Court for the Western District of Tennessee.
+Richard Leigh Grinalds, Asst. U.S. Attorney, U.S.
+Attorney's
+Office,
+Jackson,
+Plaintiff-Appellee.
+Bruce I. Griffey, Office of Bruce Irwin Griffey,
+Memphis, TN, for Defendant-Appellant.
+Before: MOORE, and ROGERS, Circuit Judges;
+and FORESTER, District Judge. FNI
+FN1. The Honorable Karl S. Forester,
+Chief Judge of the United States District
+Court for the Eastern District of Kentucky,
+sitting by designation.
+OPINION
+FORESTER, District Judge.
+**1 The Defendant-Appellant, William Ray Kisor,
+II, stands convicted of using a facility or means of
+commerce-electronic mail,
+messages and
+telephone
+conversations to knowingly persuade, induce,
+entice, coerce and attempt to persuade, induce,
+entice, and coerce a minor to engage in prohibited
+sexual acts in violation of 18 U.S.C. § 2422(b).
+Kisor now appeals, arguing that the district court
+abused its discretion by refusing to ask one of
+Kisor's tendered questions to the jury during voir
+dire. For the following reasons, we AFFIRM.
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H.. 12/18/2007
+
+
+
+104 Fed.Appx. 479, 2004 WL 1491625 (C.A.6 (Tenn.))
+(Cite as: 104 Fed.Appx. 479)
+I. FACTUAL BACKGROUND AND
+PROCEDURAL HISTORY
+In October of 2000. Kisor, who was then
+thirty-two years old and lived in Wellston. Ohio.
+met a minor female, identified as J.F., who was then
+sixteen years old and lived in Paris. Tennessee, in
+an internet chat room. For several months, the *480
+two communicated with each other through
+electronic mail, instant messages, and long distance
+telephone conversations.
+communications involved graphic descriptionh ot
+sexual desires and sexual role playing. Kisor does
+not dispute the fact that he initiated some of these
+communications.
+On March 13, 2001, J.F.'s mother. Donna Gay
+Francisco, became suspicious when J.F.'s name
+appeared on her high school's daily absentee list.
+Francisco began looking
+for her
+daughter and
+eventually located her truck in front of a room at a
+local motel. Francisco knocked on the door of that
+room, and Kisor opened the door wearing only his
+boxer shorts. Francisco recognized the clothes on
+the motel room floor as belonging to J.F., and heard
+J.F. in the bathroom. In response to Francisco's
+questioning, Kisor admitted that he knew that J.F.
+was only sixteen years old and that he knew that it
+was illegal to cross state lines into the State of
+Tennessee to engage in sexual activity with a minor.
+Francisco called the police, and Kisor was arrested.
+A federal grand jury returned a two
+count
+indictment against Kisor, Count One charged Kisor
+with persuading, inducing, enticing, or coercing and
+attempting to persuade, induce, entice, or coerce
+minor to engage in sexual acts that constitute a
+prosecutable offense under Tennessee law FN2 in
+violation of 18 U.S.C. § 2422(b). FN3 Count Two
+sought forfeiture of any instruments used by Kisor
+in committing the offense in accordance with 18
+U.S.C. § 2253.
+when the victim is at least thirteen (13) but
+ess than eighteen (18) years of age and th
+lefendant is at least four (4) years old
+than the victim .. (c) Statutory rape is a
+FN3. This section was amended after Kisor
+was indicted.
+At trial in January of 2002, Kisor requested that the
+istrict court ask potential jurors the followin
+uestion during voir dire: "Whether they believe
+6 year old girl can persuade an adult male t
+ngage in sexual activity?" The district cou
+answer to the question would not be relevant. A
+jury was empaneled and Kisor was convicted on
+Count One. The jury also determined that specified
+items were subject to forfeiture under Count Two.
+Kisor timely filed the instant appeal, claiming that
+the district court abused its discretion by failing to
+ask Kisor's proposed question during voir dire.
+This is the sole issue on appeal.
+II. STANDARD OF REVIEW
+**2 This Court has articulated the following
+standard of review of district courts' conduct of voir
+dire:
+In reviewing the district court's voir dire in this
+case, we must determine whether the court abused
+the broad discretion vested in [it] by the rulings of
+the Supreme Court of the United Stater
+in [its]
+impaneling of [the] jury." United States |
+999 F.2d 1053,
+1071 (6th Cir.1993)
+Phibbs,
+(quoting
+United States | Blanton, 719 F.2d 815, 822 (6th
+Cir. 1983)), remaining mindful of the fact that a
+listrict court *retains great latitude in deciding what
+questions should be asked on voir dire.' Mu'Min
+Virginia, 500 U.S. 415, 424, 111 S.Ct. 1899, 114
+L.Ed.2d 493 (1991). We ascertain only whether
+the district court ensured that Middleton had a fair
+anel of impartial, "indifferent" jurors.
+FN2. Tennessee Code Annotated §
+-481/rvin Dowd, 366 U.S. 717, 722, 81 S.S.
+39-13-506 provides in pertinent part as
+1639, 6 L.Ed.2d 751 (1961). Only in the absence
+follows: "Statutory rape-(a) Statutory rape
+of a fair trial is reversal warranted. See id.
+is sexual penetration of a victim by the
+defendant or of the defendant by the victim
+United States | Middleton, 246 F.3d 825, 834-35
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prfl=H... 12/18/2007
+
+
+
+104 Fed.Appx. 479, 2004 WL 1491625 (C.A.6 (Tenn.))
+(Cite as: 104 Fed.Appx. 479)
+(6th Cir.2001).
+inducing, coercing or attempting to persuade,
+entice, induce, or coerce-are considered.
+III. ANALYSIS
+The district court did not abuse its discretion in
+declining to ask Kisor's proposed question during
+voir dire. "Judges need not use every question
+submitted by counsel; they need only use those to
+**3 Kisor has failed to explain why a juror who
+believed that J.F. could not have persuaded Kisor
+into engaging in sexual activity would be unable to
+follow the district court's instructions and decide the
+case on the evidence presented at trial. Even if a
+juror refused to believe that J.F. could have
+persuaded Kisor to engage in sexual activity, that
+juror could still conclude, on the basis of J.F!'s
+Fish, 928 F.2d 185,
+185 (6th Cir.1991).
+conduct, that Kisor did not violate 18 U.S.C. §
+challenge for cause is subject to the district court's
+2422(b) because J.F. needed no persuading,
+approval and must be supported ay a finding of
+enticing, inducing, or coercing to participate in
+actual or implied bias. Hughes
+sexual activity.
+The jury
+258 F.3d 453, 458 (6th Cir.2001). Kisor's proposed
+response that would have provided a basis for a
+hat would have provided a bad for a
+hallenge for cause because no possible answer to
+question during voir dire.
+he question would have shown actual or impliec
+bias.
+Kisor contends that the district court's refusal to ask
+his proposed
+discovering whether potential jurors were biased.
+He maintains that, because his intended defense was
+that J.F. persuaded him to engage in sexual activity,
+IV. CONCLUSION
+Accordingly, we AFFIRM the judgment of the
+district court.
+C.A.6 (Tenn.),2004.
+U.S. | Kisor
+potential jurors would be willing to find a sixteer
+104 Fed.Appx. 479, 2004 WL 1491625 (C.A.6
+year old girl capable of such persuasion. In raising
+(Tenn.))
+this claim, Kisor presupposes that there were two
+possible outcomes at trial. First, the jury could find
+that he persuaded J.F. to engage in sexual activity.
+Kisor does not dispute that, upon such a finding, the
+jury would be required to find him guilty of the
+Second, the jury could find that J.F.
+persuaded Kisor to engage in sexual activity. Kisor
+contends that, upon such a finding, the jury would
+be required to find him not guilty of the offense.
+Kisor's argument is based upon an incorrect framing
+of the relevant possibilities at trial. Under Kisor's
+construct, either he persuaded J.F. or J.F. persuaded
+him. This flawed construct ignores other
+possibilities, namely that Kisor and J.F. engaged in
+mutual persuasion or that neither Kisor nor J.F.
+needed any persuading. The reality of these
+additional possibilities becomes ever clearer once
+the rest of the statutory possibilities-enticing,
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H... 12/18/2007
+
+
+
+United States District Court,
+E.D. Virginia,
+Alexandria Division.
+UNITED STATES of America,
+1
+David A. KAYE, Defendant.
+No. 1:06cr205 (JCC).
+Sept. 6, 2006.
+Background: Trial was held on charges of
+coercion and enticement and of travel with intent to
+engage in illicit sexual conduct.
+Holding: The District Court, Cacheris, J., held
+that evidence, including that defendant believed he
+was going to engage in sexual activity with a
+13-year-old boy, established beyond a reasonable
+doubt all elements of the charged offenses.
+Ordered accordingly.
+West Headnotes
+[1] Infants C-13
+211k13 Most Cited Cases
+To convict for coercion and enticement, the
+Government must prove the following elements
+beyond a reasonable doubt: (1) use of a facility of
+interstate commerce; (2) to knowingly persuade,
+induce, entice, or coerce; (3) a person who is
+younger than eighteen; (4) to engage in an illegal
+sexual activity.
+18 U.S.C.A. § 2422(b).
+2| Commerce C-82.11
+13k82.10 Most Cited Case:
+that a defendant: (1) traveled in interstate
+i sexua conduct U.SC.A. US. 24210 gage in
+3] Criminal Law E-561(
+10k561(1) Most Cited Cas
+In determining the guilt or innocence of an
+aply the les prose beyond a reasonable doubto
+offense
+have been
+met by the Government,
+defendant will be found guilty.
+[4] Commerce €-82.10
+83k82.10 Most Cited Cases
+14] Infants €- 13
+211k13 Most Cited Cases
+14] Telecommunications C-1351
+372k1351 Most Cited Cases
+Evidence established beyond a reasonable doubt all
+elements of an attempt to violate the statute
+prohibiting the use of a facility of interstate
+commerce to coerce and entice minors to engage in
+sexual
+activity;
+defendant admitted that
+he
+communicated
+using email and Internet instant
+messaging, a chat log established that he persuaded,
+enticed, and induced his correspondent to engage in
+a sexual act, and evidence, including chat room logs
+and a videotape of the defendant when he was
+confronted at a location where he went to meet the
+15) Commerce C-82.10
+83k82.10 Most Cited Cases
+15) Infants e-13
+211k13 Most Cited Cases
+© 2007 Thomson West. No Claim to Orig. US Gov. Works.
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=... 12/18/2007
+
+
+
+15] Telecommunications C-1012
+372k1012 Most Cited Cases
+15] Telecommunications C-1350
+372k1350 Most Cited Cases
+Transmission of communication by means of the
+telephone or Internet constitutes the "use of a
+facility of interstate commerce," for purposes of the
+statute prohibiting the use of facility of interstate
+commerce to coerce and entice minors to engage in
+sexual activity. 18 U.S.C.A. § 2422(b).
+[6] Commerce €-82.10
+83k82.10 Most Cited Cases
+[6] Infants E-13
+211k13 Most Cited Cases
+[6] Telecommunications €-1350
+372k1350 Most Cited Cases
+Use of the Internet, particularly Internet chat rooms,
+necessarily involves interstate communications and
+therefore constitutes the "use of a facility of
+interstate commerce" for purposes of the statute
+prohibiting the use of a facility of interstate
+commerce to coerce and entice minors to engage in
+sexual activity. 18 U.S.C.A. § 2422(b).
+[7] Commerce €-82.10
+83k82.10 Most Cited Cases
+17] Infants C-13
+211k13 Most Cited Cases
+[7] Telecommunications €-1351
+372k1351 Most Cited Cases
+Evidence established beyond a reasonable doubt all
+elements of travel with intent to engage in illicit
+sexual conduct; defendant admitted that he traveled
+from Maryland to Virginia, and that he was
+traveling to engage in homosexual activity with a
+"young adult," and evidence, including Internet chat
+room logs and a videotape of the defendant when he
+was confronted at his destination, showed that he
+believed the individual he was to meet was a
+13-year-old boy. 18 U.S.C.A. § 2423.
+*776 Peter David Greenspun, Greenspun & Mann
+PC, Fairfax, VA, for Defendant.
+Edmund P. Power, United States Attorney'S Office,
+Alexandria, VA, for United States of America.
+MEMORANDUM OPINION
+CACHERIS, District Judge.
+The matter before this Court is whether Defendant,
+David A. Kaye, violated 18 U.S.C. § 2422(b) and
+18 U.S.C. § 2423(b) by using the Internet to
+persuade, induce, or entice an individual whom he
+individual. For the following reasons, this Court
+finds Defendant guilty on both counts.
+I. Findings of Fact
+The basic facts of this case are largely undisputed
+as between the Government and Defendant. In
+evaluating Defendant's guilt or innocence, the Court
+carefully considered those facts that it found proven
+beyond a reasonable doubt. The Court's findings of
+A. On August 7, 2005, at 3:50 AM, Defendant, a
+fifty-four-year-old male in Rockville, Maryland
+under the America Online ("AOL") screen name
+[FN1] "REDBD," initiated contact by instant
+message
+Rad1992," FN2] with screen name "MadC
+NI. "A screen name is an appellatio
+sed to identify oneself in a chat room o
+when sending instant messages to another
+computer user. Although it can be the
+iser's real name, it is mom often i
+pseudonym." United States
+Mitchell,
+353 F.3d 552, 554 n. 3 (7th Cir.2003).
+FN2. As its name describes, an "instant
+message" is a one-on-one communication
+whereby two parties are able to engage in
+real-time dialogue by typing messages to
+one another and sending/receiving the
+messages almost instantly.
+B. The screen name "MadC Rad1992" described
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=... 12/18/2007
+
+
+
+himself to "REDBD" as a thirteen-year-old boy
+named "Conrad" located in Herndon, Virginia. His
+internet "profile"
+stated that
+he was a
+thirteen-year-old *777 boy and his screen name
+contained the number "1992," which purports to be
+the year in which the individual was born.
+C. During all relevant times, the screen name
+"MadC Rad1992" was controlled in reality by a
+26-year-old male in Florida by the name of Sean
+O'Connor, a member of an organization called
+Perverted Justice. [FN3]
+FN3. Perverted Justice is an organization
+that is dedicated to exposing adults who
+use the Internet to seek sexual activity with
+children. The modus operandi of the
+organization is to have members pose as a
+young children in internet "chat rooms"
+and wait to be contacted by adults that
+engage them in a sexual dialogue. The
+organization
+often
+involves
+law
+enforcement and also may publish
+information about the adult, including the
+sexually explicit chat, on the Internet.
+herndon u?
+REDBD (4:06 AM): you cute?
+MadC Rad1992[04:06 AM): i have a pic[picture]
+REDBD [04:07 AM]: nah but for 54 im decent i
+only hali Je x pics and dont want to send them to
+you because you are so young
+REDBD [04:07 AM]: you are very cute man wha
+ti syour name
+REDBD [04:09 AM]: where do you live?
+D. In this "chat" conversation on August 7, 2005,
+REDBD [04:09 AM): you alone
+the following dialogue occurred between Defendant
+and MadC Rad1992: [FN4]
+FN4. Due to the informal nature of online
+"chatting," the conversations involve
+numerous typographical errors, symbols,
+shorthand, and abbreviations. For the sake
+of intelligibility of the conversation, this
+Court has not used "[sic]" to indicate ever
+error or mistake
+conversation.
+REDBD [3:50 AM]: hi
+REDBD [04:09 AM]: i would like to suck your
+dick
+MadC Rad1992[04:09 AM]: rlly? that would be
+way kewl
+REDBD [04:10 AM]: have you ever had
+omeone suck yor
+MadC Rad1992[04:10 AM]: no i really wan
+head [fellatio] tho[though]
+MadC Rad1992[04:10 AM]: i wanna kno what
+its like
+REDBD [04:10 AM]: you jo[masturbate] alot?
+MadC Rad1992 [04:04 AM]: yo
+REDBD [04:04 AM]: hey
+MadC Rad1992 [04:05 AM]: sorry u[you]
+REDBD [04:11 AM]: doy oucum(sic] a lot
+im(instant message] me carlier I was eating a
+REDBD [04:11 AM]: ever been naked whit a
+boy or girl
+MadC Rad1992 [04:05 AM): sup
+MadC Rad1992[04:12 AM): no:(
+EDBD [04:05 AM]: ok you are only 13
+[after MadC Rad 1992 describes that he would
+adC Rad1992[04:05 AM): yup 13 m[mal
+like to do "stuff"]...
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=...
+
+
+
+*778 REDBD [04:13 AM]: well i can help you
+out
+MadC Rad1992[04:13 AM]: sweet:)
+REDBD [04:13 AM]: you seem sweet
+[After discussing that his father would be out of
+town soon, but that he was not allowed to throw
+parties] ...
+REDBD [04:14 AM]: but we could still party
+REDBD [04:14 AM]: just you and me
+REDBD [04:21 AM]: maybe ill send you my pics
+REDBD [04:21 AM]: you have mail
+REDBD [04:24 AM]: you are sweet
+REDBD [04:24 AM]: you are not a cop are you
+[Defendant and "Conrad" discuss the death of
+Conrad's mother] ...
+REDBD [04:36 AM]: how long ago did your
+mom die?
+MadC Rad1992[04:47 AM): 6 yrs ago
+MadC Rad1992[04:47 AM]: when I[w]as 7
+REDBD [04:47 AM]: wow you were very young
+REDBD [04:51 AM]: soy ou [sic] in herndon
+REDBD [04:51 AM]: that far from me but you
+would be worth it
+REDBD [04:51 AM]: you have nice dick?
+MadC Rad1992[04:51 AM]: its ok
+MadC Rad 1992[04:51 AM): it s like 5"
+REDBD [04:51 AM]: cut?
+MadC Rad1992[04:51 AM]: yep
+REDBD [04:51 AM]: nice to sukc[sic] 5 ers
+MadC Rad1992[04:51 AM]: well tehn u'll like 2
+suck mine lol [laughing out loud]
+MadC Rad1992[04:52 AM]: I dont got a lot of
+hair like alot of dudes is that kewl?
+REDBD [04:52 AM]: sure
+Page 4
+REDBD [04:52 AM]: you me aroudn your dick
+or on your body
+MadC Rad1992[04:52 AM): both
+MadC Rad1992[04:52 AM): none on my body
+REDBD [04:53 AM): i love smooth men
+[Defendant and "Conrad" discuss the relationship
+of his father and his girlfriend] ...
+EDBD [04:56 AM]: ok
+REDBD (04:56 AM): you hard now again
+MadC Rad1992[04:56 AM]: uhm yeah it never
+rilly left lol
+MadC Rad1992[04:56 AM): ru?
+REDBD [04:57 AM): lol
+REDBD [04:57 AM]: oh yes honey
+E. During the August 7th interaction, Defendant
+spoke on the phone with a person who posed as the
+thirteen-year-old "Conrad." In reality, the voice on
+the phone was Alison Shea, a 24-year-old woman
+and also a member of Perverted Justice. Shea had
+been corresponding with O'Connor during his
+sexual dialogue with Defendant.
+F. Also during this conversation, Defendant and
+"Conrad" electronically exchanged pictures. Mr.
+O'Connor, posing as "Conrad," provided Defendant
+with a picture of a young male that he downloaded
+from an adoption website. In return, Defendant sent
+"Conrad" pornographic pictures of himself. These
+sexually explicit pictures were of Defendant posing
+nude and engaging in fellatio with another male.
+(Govt. Ex. 4-1 through 4-5).
+*779 G. On August 10, 2005, the following
+dialogue occurred in a chat conversation between
+Defendant and MadC Rad1992:
+MadC Rad1992(10:41 AM]: hello
+MadC Rad1992[10:41 AM]: :)
+MadC Rad1992[10:41 AM]: UGH! its early!!!
+REDBD [10:42 AM]: hey cutie
+MadC Rad1992[10:42 AM]: hi!!!!
+MadC Rad1992[10:42 AM]: i got ur email
+REDBD [10:42 AM]: :)
+REDBD [10:43 AM]: im at work now. is dad
+still at home?
+REDBD [10:43 AM]: i have to go
+MadC Rad1992[10:42 AM]: ru busy?
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=...
+
+
+
+MadC Rad1992[10:42 AM]: awww ok
+H. On August 16, 2005, the following dialogue
+occurred in a chat conversation between Defendant
+and MadC Rad1992:
+REDBD [04:39 PM): let me call you soon
+MadC Rad1992 [04:39 PM]: how have you been
+REDBD (04:39 PM): still in a meeting give me
+20 more minutes is dad home?
+MadC Rad1992[04:40 PM): ok
+REDBD [04:40 PM]: is dad home?
+MadC Rad1992 [04:40 PM]: no
+REDBD [04:40 PM]: is he away?
+MadC Rad1992 [04:41 PM]: he will be leaving
+tomorrow
+REDBD [04:41 PM]: for how long? you will be
+alone?
+MadC Rad1992 [04:41 PM]: for until Friday or
+Sat. and ya
+MadC Rad1992 [04:41 PM]: nol [no one] is
+avialable to stay with me
+REDBD [04:41 PM]: yummy
+REDBD [04:41 PM]: I can stay with you
+REDBD [04:41 PM]: lol
+REDBD [04:50 PM]: what is your scheudle
+tonite and where do yolive again?
+MadC Rad1992 [04:51 PM): Herndon man
+Page 5
+MadC Rad1992 [04:58 PM): 13
+REDBD [04:58 PM): thats rape
+MadC Rad1992 [04:59 PM]: dood I tell ya that
+before
+Mad Rad 59 0459 Michaker
+REDED 0459 PM: Is that you are s000 3000
+young
+REDBD [04:59 PM]: ive never been with a
+young man like you
+REDBD [04:59 PM]: but i would like to
+*780 MadC Rad1992 [04:59 PM]: i want 2 try
+stuff
+REDBD [05:00 PM]: i can let you try anything
+REDBD [05:00 PM]: waht do you want to try
+MadC Rad1992 [05:00 PM]: and i want u to
+suck me like in that pic u sent me
+REDBD [05:00 PM]: i can suck your dick
+REDBD [05:00 PM]: *you ever been sucked?
+MadC Rad1992 [05:00 PM]: no, never
+MadC Rad1992 [05:00 PM]: im stoked 2 try it
+REDBD [05:00 PM]: you cut?
+MadC Rad1992 [05:00 PM]: SOOO stoked
+MadC Rad1992 [05:00 PM]: ya
+REDBD [05:01 PM]: yummy conrad
+REDBD [04:51 PM): can i cum|sic] over?
+[Defendant and "Conrad" discuss when his father
+is coming home that evening-]
+REDBD [04:52 PM): what time does he cum[sic]
+MadC Rad1992 [OS:07 PM: u like sucking? or
+beng suckd?
+REDBD [05:07 PM]: you tell me what you want
+REDBD (05:07 PM]: I like sucking and being
+sucked
+REDBD [04:57 PM): stats again?
+REDBD [05:08 PM]: i like ot kiss
+MadC Rad1992 [04:58 PM]: 5'5" 120 Ibs
+MadC Rad1992 [05:08 PM): i wanna try that
+MadC Rad1992 [04:58
+PM]: what u doin
+REDBD [05:08 PM): and rub assholes
+tomorrow? cuz he leaves
+MadC Rad1992 [05:08 PM]: ohh@ and kiss!
+REDBD [04:57 PM): age?
+kiss alot
+MadC Rad1992 [04:58 PM]: u gotta work?
+MadC Rad1992 [05:08 PM]: ok,
+11&prft=... 12/18/2007
+
+
+
+REDBD [05:08 PM]: you just have to be very
+clean i your ass
+REDBD [05:08 PM]: no shit
+MadC Rad1992 [05:08 PM]: ohh
+MadC Rad1992 [05:08 PM): can u show me?
+REDBD [05:08 PM]: how to clean your asshole?
+MadC Rad1992 [05:08 PM]: well
+MadC Rad1992 [05:09 PM]: i think im clean but
+i wanna make sure im doin it rite u know?
+REDBD [05:09 PM]: ok ic an hlep you
+[Defendant and "Conrad" then discuss what time
+to meet and also arrange a quick phone call from
+Defendant to "Conrad."]
+occurred in as chat conversation belven Defendant
+and MadC Rad1992:
+REDBD [09:53 AM): So
+what the time my
+young sexy guy
+MadC Rad1992 [10:05 AM): what u want me to
+REDBD [10:05 AM]: lol
+REDBD [10:05 AM]: NOTHING.
+[Defendant and "Conrad" discuss what time to
+meet as well as where the meeting will take place.]
+REDBD [10:25 AM]: sure i love to kiss have
+you kissed many people?
+REDBD [10:25 AM]: boys or girls romantically
+MadC Rad1992 [10:25 AM]:just a girl but no
+tongue
+REDBD [10:26 AM]: tell me about that
+MadC Rad1992 [10:26 AM]: we were at a dance
+MadC Rad1992 [10:26 AM): and then after we
+kissd
+REDBD [10:26 AM]:did you slow dance with
+MadC Rad1992 [10:26 AM]: yeah
+REDBD [10:26 AM]: did you get hard when you
+danced next to here
+REDBD [10:25 AM): her
+MadC Rad1992 [10:26 AM]: yeah lol how did u
+know?
+Page 6
+REDBD [10:25 AM]: we all do that
+REDBD [11:36 AM): im leavning now
+(Govt.Ex. 1).
+J. On August 17, around 12:00 PM, Defendant
+K. Defendant arrived at the address provided by
+"Conrad" and entered the house through the garage.
+Unbeknownst to Defendant, the house was being
+used in a cooperative "sting" operation between
+NBC Dateline and Perverted Justice.
+L. Defendant was filmed by a hidden camera and
+as quickly approached by NBC Datelit
+respondent Chris Hansen, who began to questic
+Defendant.
+M. When asked by Hansen "what are you doing
+here?" Defendant replied, "Not something good ...
+this isn't good." Hansen referenced the chat log and
+confronted him
+about the appearance
+Defendant was "setting up a meeting with a
+13-year-old boy." (Govt.Ex.бa). Defendant made
+incriminating statements such as "You know I'm in
+trouble. I know I'm in trouble." Upon learning
+Hansen was from NBC Dateline and that he was
+being filmed, Defendant became upset and departed
+the house.
+N. Defendant soon thereafter attempted to delete
+his entire America Online account "REDBD" as
+well as erase the hard drive of his computer at work.
+II. Elements of 18 U.S.C. § 2422(b) and 2423(b)
+On May 18, 2006, a grand jury returned a
+two-count indictment charging Defendant with one
+count of coercion and enticement in violation of 18
+U.S.C. § 2422(b) and one count of travel with intent
+to engage in illicit sexual conduct in violation of 18
+U.S.C. § 2423(b). On August 21, 2006, Defendant
+waived his Sixth Amendment right to a jury trial
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prfl=... 12/18/2007
+
+
+
+and requested a bench trial.
+With respect to Count I, the statute 18 U.S.C. §
+2422(b)is commonly used as a tool in the Federal
+Government's attempts to prevent sexual abuse of
+children using the Internet. The statute's text
+provides:
+Whoever, using the mail or any facility or means
+of interstate or foreign commerce, or within the
+special maritime and territorial jurisdiction of the
+United States knowingly persuades, induces,
+entices, or coerces any individual who has not
+attained the age of 18 years, to engage in
+prostitution or any sexual activity for which any
+person can be charged with a criminal offense, or
+attempts to do so, shall be fined under this title
+and imprisoned not less than 5 years and not more
+18 U.S.C. § 2422(b) (2006) (emphasis added).
+The statute's primary focus is on adults using the
+Internet to seek out and persuade minors to meet for
+the purpose of engaging in
+sexual activity. The
+statute is often used in the context of sting
+operations that involve adults posing as minors in
+an Internet "chat session." Many defendants have
+challenged this use of the statute, claiming that an
+"actual minor" as a victim is required. However,
+every Court of Appeals to address this issue has
+uniformly upheld this use of the statute and that an
+"actual minor" is not required. [FN5]
+FN5. In fact, Defendant challenged this
+use of the statute in this case, but the Court
+denied his challenge and upheld the
+interpretation that the statute does not
+require an
+with precedent.
+"actual minor" in accordance
+See United
+States
+Page 7
+*782 [|] To convict under § 2422(b), the
+Government must prove the following elements
+beyond a reasonable doubt: (1) use of a facility of
+interstate commerce; (2) to knowingly persuade,
+induce, entice, or coerce; (3) a person who is
+rounger than eighteen; (4) to engag
+in an illegal
+exual activity. See United States | Helder, 45
+F.3d 751, 755 (8th Cir.2006); United States | Meek
+366 F.3d 705, 718 (9th Cir.2004); United States I
+Davis, 165 Fed.Appx. 586, 588 (10th Cir.2006);
+United States | Bolen, 136 Fed.Appx. 325, 329
+(11th Cir.2005).
+Defendant has been charged with criminal attempt
+under the statute since there was no actual minor
+involved and, as such, the offense was not
+completed. Consequently, the Government must
+also prove that Defendant: (1) acted with the kind
+of culpability required for a conviction of the
+underlying substantive
+offense; (2) engaged in
+conduct that constitutes a substantial step toway
+commission of the crime. See United States |
+Farner, 251 F.3d 510, 513 (5th Cir.2001); Helder,
+452 F.3d at 755.
+[2] With respect to Count II, the statute 18 U.S.C. §
+2423(b) is used by the
+federal government to
+prevent the sexual abuse of children in interstate
+commerce. The statute's relevant text provides:
+A person who travels in interstate commerce ...
+for the purpose of engaging in any illicit sexual
+conduct with another person shall be fined under
+this title or imprisoned not more than 30 years, or
+both.
+18 U.S.C. § 2423(b). From this text, to convict an
+individual under this statute, the Government must
+prove beyond a reasonable doubt that a defendant:
+(1) traveled in interstate commerce and (2) acted
+with the intent to engage in illicit sexual conduct.
+F.3d 945, 959-60 (10th Cir.2005); United
+States | Meek, 366 F.3d 705, 717-20 (9th
+Cir.2004); United States Roor, 296 F.3d
+sates dParner. 251 F.3d-200, 513 (sech)
+Cir.2001); United States
+S Bailey (szh
+F.3d 637, 639 (6th Cir.2000).
+Gamache, 156 F.3d 1, 8 (Ist Cir.1998); United
+States | Vang, 128 F.3d 1065, 1068 (7th Cir.1997).
+III. Application
+[3][4] In determining the guilt or innocence of an
+individual under a specific statute, the Court must
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.I1&prit=.. 12/18/2007
+
+
+
+apply the facts proven beyond a reasonable doubt to
+the elements of the offense. If all elements of the
+offense have been met by the Government,
+Defendant will be found guilty. This Court will
+first address Defendant's alleged violation of §
+2422(b) followed by Defendant's alleged violation
+of § 2423(b).
+A. Coercion and Enticement under § 2422(b)
+1. "Use of Facility of Interstate Commerce"
+[5][6] First, the Government must prove that
+Defendant used a facility of interstate commerce. A
+transmission of communication by means
+of the
+of
+interstate commerce.
+Use
+of the Internet,
+particularly
+necessarily
+involves interstate communications and therefore
+"use of
+facility of interstate
+commerce." United States | Hornaday, 392 F.3d
+(11th Cir.2004). At trial,
+Defendant
+admitted that he communicated with "Conrad"
+Internet
+messaging
+Therefore, Defendant used a facility of interstate
+commerce
+and this element of the offense is
+satisfied.
+2. "To Knowingly Persuade, Induce, Entice, or
+Coerce"
+Next, the Government must prove that Defendant
+knowingly attempted to
+persuade,
+*783 induce,
+entice, or coerce the victim. There is no definition
+for these terms included in the statute. Generally,
+courts have treated this element as self-explanatory
+while some have provided dictionary definitions
+and alternative language to juries such as
+"convinced, influenced or made the possibility more
+appealing" and
+"to stimulate the occurrence of."
+United States | Rashkovski, 301 F.3d 1133, 1137
+(9th Cir.2002); United States | Murrell, 368 F.3d
+1283, 1287 (11th Cir.2004). This Court rests on the
+plain meaning of the words in the statute in deciding
+whether the Government has satisfied this element.
+he chat log between Defendant and "Conrac
+with excerpts provided infra Section I provide
+Page 8
+more than sufficient evidence that Defendant
+persuaded, enticed, and induced the young boy to
+engage in a sexual act. From the outset of the
+elationship, Detendant repcatedly
+provided
+Conrad" with compliments of being "cute" an
+"sweet." These compliments were followed not by
+sexual innuendo, but by blatant, aggressive sexual
+advances on "Conrad" such as "I want to suck your
+dick" and "have you ever had someone suck you?"
+Defendant tells the child that he can let the child
+"try anything you want" and suggests other forms of
+oral and manual stimulation. Such aggressive,
+persuading advances by an adult on a
+thirteen-year-old-boy are clearly attempts to induce
+and entice the child to engage in sexual activity.
+Moreover,
+Defendant's attempts to persuade,
+induce, and entice do not end there. Defendant
+sends sexually explicit pictures to Conrad depicting
+himself posing nude and engaging in sexual acts.
+Defendant asked whether the young boy has "ever
+been naked with a boy or a girl" and offering "to
+help [Conrad] out." Defendant asks personal,
+sexual questions to the child about masturbating.
+ejaculating, and whether he has a "nice dick." This
+Court finds that the pictures and sexually suggestive
+advances on the child were direct attempts to
+persuade, induce, and entice the child to engage in
+sexual activity.
+Counsel for Defendant argues that these comments
+were not sincere, but instead were simply "talking
+dirty"
+over the Internet. This Court strongly
+disagrees, and finds that these comments were
+backed by substantiated sexual intent as evidenced
+Defendant
+consistently asked whether the child's father is
+home, scheduled a time to "cum[sic] over," and
+actually drove across state lines to "Conrad's"
+house. Defendant intended far more than "talking
+dirty." He intended sexual activity.
+Counsel for Defendant further argues that it was
+Defendant that was induced or enticed by the
+members of Perverted Justice posing as a
+thirteen-year-old boy. Upon carefully looking at the
+chat logs in evidence, some of the interaction made
+by "Conrad"/Perverted Justice could certainly be
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=.. 12/18/2007
+
+
+
+considered as inviting sexually explicit responses.
+(e.g. "no i really want head tho"). Furthermore, this
+Court recognizes that Perverted Justice is an
+organization dedicated to exposing child molesters
+and clearly had a motive to "deliver" Defendant
+since it was being featured on NBC Dateline,
+receiving $100,000 from NBC. However,
+Defendant's argument proves to be unpersuasive for
+three reasons:
+First, in almost any context, Defendant's language
+and actions in this case can only be regarded as an
+attempt to persuade, entice, and induce the other
+individual to engage in a sexual activity. Defendant
+stated "I want to suck your dick" before any inviting
+language had been received by Defendant and
+Defendant sent sexually explicit pictures soon
+thereafter. This aggressive behavior, without any
+invitation from
+"MadC Rad 1992", would be
+considered *784 an attempt to persuade, induce,
+and entice.
+Second, as discussed in the next section, Defendant
+believed that he was
+interacting
+thirteen-year-old boy.
+No degree of interest,
+curiosity,
+mutual
+thirteen-year-old is enough to find that Defendant's
+agressive language and actions are not an attempt
+to persuade, induce, and entice the individual to
+engage in sexual activity.
+Third, Defendant's chat conversations with
+"Conrad" and his testimony clearly demonstrate his
+disposition to engaging in sexual activity wit
+sons trom Internet conversations. includin
+thirteen-year-old males.
+Touret orat thie statements ande the pi teres nable
+Defendant to "Conrad" were an attempt to persuade,
+induce, and entice the individual under screen name
+"MadC Rad1992" to engage in sexual activity.
+3. "A person younger than eighteen years of age"
+Third, the Government must prove that Defendant
+believed that the individual he was persuading,
+inducing, and enticing was below eighteen years of
+Page 9
+age. As stated infra, the Government need not
+prove the existence of an "actual minor" but only
+that Defendant believed that "Conrad" was below
+eighteen years of age. Defendant argues that he
+believed he was meeting a young adult (of
+consenting age) for a homosexual encounter and
+that the picture and voice of the person purporting
+to be "Conrad" were that of an eighteen-year-old
+male. After evaluating the evidence, the Court is
+not persuaded by Defendant's arguments and finds
+that Defendant believed the individual he was
+inducing, enticing, and persuading was a
+thirteen-year-old male.
+First, the evidence shows that on August 7, 2005,
+Defendant was aware of "Conrad's" age
+before the initial contact. Without any reference to
+age by "Conrad," Defendant stated "ok y ou are
+only 13?" in the third instant message he ever sent
+to the screen name MadC Rad1992. This fact alone
+shows that Defendant either (1) previously viewed
+"Conrad's" online profile (which contained his age),
+discovered he was thirteen-years-old, and then
+initiated contact; or (2) viewed "Conrad's" screen
+name of MadC Rad1992,
+assumed this was a
+reference to the year in which the individual was
+born (thirteen years prior in 2005), and then
+Either scenario
+Defendant to have affirmative knowledge of the
+child's age even before the first contact.
+Defendant repeatedly acknowledged
+"Conrad" as "young" and as a thirteen-year-old boy
+in online conversations that
+August 7- 17, 2005: "I only ha[i le x pics and don't
+want to send them to you because you are so
+young", "for a 13 yr old you handle yourself very
+well", "you are only 13? thats rape", "you are 5000
+sooo young", and "ive never been with a young man
+like you/but would like to." This repeating,
+unambiguous acknowledgment of "Conrad's" age
+leads this Court to conclude that Defendant
+believed that he was persuading, inducing, and
+enticing an individual of thirteen years of age.
+Defendant's testimony that he believed he was
+going to meet a young adult for a homosexual
+encounter is not persuasive for two reasons. First,
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=... 12/18/2007
+
+
+
+* Dear stem did e vas
+neeting a young adult is not credible. Upon being
+confronted by the correspondent, Defendant's
+demeanor, body language, and facial reaction is one
+of complete *785 and utter shock. This is followed
+by Defendant stating "I know I'm in trouble" and
+when asked "what are you doing here" Defendant
+said "not something good." Defendant's behavior is
+not consistent with his testimony that he believed he
+was meeting a young adult, but instead,
+corroborates the extensive chat log portraying
+Defendant's
+belief
+that
+"Conrad"
+was
+a
+thirteen-year-old boy. Second, the Court did not
+find Defendant's testimony to be credible in its
+assessment of his veracity, demeanor, cadence,
+tenor, and inflection of his
+voice as well as the
+consistency of his answers on cross examination.
+Defendant proffered expert testimony at trial to
+picture and
+of the
+Perverted Justice purported to be "Conrad. With
+respect to the picture, an expert testified that the
+child depicted in the picture emailed to Defendant
+appears to have fully developed facial features, and
+accordingly, the child depicted in the picture could
+an
+eighteen-year-old
+male.
+On
+cross
+examination, the expert testified that he could not
+give the exact age of the child with any degree of
+certainty, but, as expected, could only offer a range
+within which the child's age is likely to fall. The
+expert concluded the child in the picture could be
+eighteen, but he could also be much younger.
+Defense counsel
+argues
+since
+picture
+depicts a person that could be an eighteen-year-old,
+it provides reasonable
+doubt with respect to
+Defendant's mental state that he believed he was
+enticing a minor for sex. This Court disagrees.
+Even if this Court agreed with
+the expert's
+testimony, the expert testified only that the age
+"could be" that of an eighteen-year-old. Never did
+the expert testify that the picture could not also
+reasonable depict a thirteen-year-old boy. This
+tentative, inconclusive testimony, received in light
+of the overwhelming evidence provided in the chat
+log that Defendant sought out a thirteen-year-old
+Page 10
+boy and confirmed his age several times, does not
+Create a sonal pout that and an eleved
+thirteen-year-old boy to engage in a sexual activity.
+Defendant's voice expert testified that the
+frequency of one's voice depends upon gender and
+For instance, the frequency of an adult
+female's voice is between 180 and 250 Hz, while an
+adult male's voice is between 100 and 150 Hz,
+consistent with the general understanding that a
+man's voice sounds lower in pitch than a female's.
+The expert analyzed a video-recording of a female
+from Perverted Justice speaking on the phone to
+Defendant (as "Conrad") and testified that the
+frequency of the woman's voice on the phone was
+184 to 190 Hz (at the lower end of the spectrum for
+a female). Finally, the expert testified that the
+frequency
+thirteen-and-a-half-year-old male is between that of
+an adult male and an adult female, centered around
+174 Hz. In fact, on cross examination, the expert
+admitted that the frequency of the voice on the
+phone overlaps with that of a thirteen-year-old
+Q[by Government]
+So if you assume [the voice on the phone is] a
+male instead of a female, that frequency is
+actually between the age of 12.2 and 13.5,
+A[by voice expert]
+That would be correct.
+(Trial Tr. of Aug. 22, 2006, 297). This testimony
+does not persuade the Court in the slightest that
+Defendant believed he was speaking to an adult
+male. Instead, this testimony is entirely consistent
+with the overwhelming evidence of Defendant's
+belief that he was speaking to a thirteen-year-old
+boy, since the actual person to whom he was
+speaking had a pitch of 184 Hz to 190 Hz, and the
+pitch of a thirteen-year-old boy's voice overlaps that
+range.
+*786 In sum, Defendant's personal testimony is not
+credible and his expert testimony is not persuasive.
+The extensive chat log and Defendant's behavior
+during his video-interrogation lead this Court to
+conclude beyond a reasonable doubt that Defendant
+
+
+
+believed he was "enticing, persuading, and
+inducing" an individual that was thirteen years of
+4. To engage in illegal sexual activity
+Fourth, the Government must prove that Defendant
+was enticing, persuading, or inducing the minor to
+engage in illegal sexual activity, or, as the statute
+reads: "any sexual activity for which any person
+can be charged with a criminal offense." 18 U.S.C.
+§ 2422(b).
+There is little question that Defendant intended to
+engage
+in sexual
+activity. He
+sent
+"Conrad"
+sexually explicit pictures and suggested numerous
+sexual
+activities
+in
+the
+chat
+conversation.
+Therefore, the inquiry becomes whether engaging in
+exual activity with a thirteen-year-old boy is an ac
+hat can be charged as a crime. United States
+Patten,
+397 F.3d 1100
+(8th Cir.2005). This
+state sexual offenses. See, eg.
+United
+States 1 Kay, 22x0 .3709, 13 (86 Cir 2001).
+The Government need not prove all the elements of
+the offense
+to establish a conviction under 18
+U.S.C. § 2422(b). Instead, the Government must
+prove that
+the
+sexual act intended by
+Defendant would constitute a criminal offense
+under the statute.
+The Government alleges that Defendant's intended
+conduct was in violation of the Code of Virginia, §
+18.2-370, taking indecent liberties with a child. This
+Virginia statute criminalizes sexual conduct with an
+individual under the age of fifteen. In this case, as
+stated several times, Defendant intended to engage
+in sexual activity with a thirteen-year-old boy. This
+conduct is clearly within the scope of the Virginia
+indecent liberties statute, and thus, chargeable as a
+criminal offense. Thus, the Government has
+satisfied this final element of the substantive offense
+under 18 U.S.C. § 2422(b).
+5. "Or attempts to do so"
+Defendant has been charged with criminal attempt
+under the statute since there was no actual minor
+involved and, as such, the offense was not
+Page 11
+completed. Consequently, the Government must
+also prove that Defendant: (1) acted with the kind
+of culpability required for a conviction of the
+underlying substantive offense; (2) engaged in
+onduct that constitutes a substantial step towar
+ommission of the crime. See United States 1
+Farner, 251 F.3d 510, 513 (5th Cir.2001); Helder,
+452 F.3d at 755.
+Whether Defendant had the requisite culpability for
+the underlying offense can be addressed by
+inquiring whether Defendant intended to complete
+the offense. If Defendant intended to complete the
+offense, then it logically follows that he had the
+requisite culpability. From the previous analysis in
+subparts 1-4, the evidence clearly shows that
+Defendant intended to: (1) use the Internet; (2) to
+knowingly persuade, induce, or entice; (3) an
+individual he believed was under the age of
+eighteen; (4) to engage in illegal sexual activity. In
+fact, the only element Defendant contests that he
+did not have knowledge of was that the individual
+was under eighteen, and that claim was not credible
+and contrary to the evidence before the Court.
+Therefore, this Court concludes that he intended to
+complete the offense and thus had the requisite
+culpability. [FNG]
+FN6. In United States
+Eleventh Circuit found that the defendant
+intended to
+complete
+the substantive
+offense by reviewing the online transcript
+("chat log") stating that: (1) Defendant
+wanted to feel [victim's]
+"little nipples";
+(2) Defendant had "never been with one
+your age," but would
+enjoy it, and (3)
+Defendant knew he could "get into a lot of
+trouble" for engaging in the activity he
+proposed. 296 F.3d 1222, 1228 (11th
+Cir.2002).
+*787 The final inquiry is whether Defendant's
+conduct constitutes a "substantial step" toward the
+commission of the crime. Id. This element is
+satisfied by actual, objective acts that, independent
+of Defendant's mental state, strongly corroborate
+In at 1zzide unequivocal evidence of his culpabilty.
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=... 12/18/2007
+
+
+
+In prosecutions under 2422(b) resulting from a
+sting operation, courts have deemed this element
+satisfied by the presence of several facts: (1) sexual
+dialog between Defendant and the "minor;" (2)
+repeated references to what would be performed
+upon meeting the minor; (3) the transmission of a
+sexually suggestive photograph; and (4) travel by
+Defendant to meet the minor. See, e.g.. Unitea
+States | Meek, 366 F.3d 705, 720 (9th Cir.2004);
+Root, 296 F.3d at 1229.
+The instant case contains all four of these
+circumstances, any of which would likely be
+sufficient by themselves to constitute a substantial
+step. Defendant engaged in extensive sexual dialog
+with the minor and referenced the sexual activities
+that
+would
+Additionally, he transmitted pornographic images of
+himself posing and performing sex acts. Finally, he
+drove an automobile from Rockville, Maryland to
+Herndon, Virginia, parked the car, walked into the
+house, and waited in the kitchen. From these facts,
+there is no question that Defendant's acts constitute
+a substantial step towards the commission of the
+crime and provide significant corroboration of his
+culpability.
+In
+summation,
+Government has satisfied all elements required for a
+conviction under 18 U.S.C. 2422(b). Specifically,
+the Government has proven beyond a reasonable
+doubt that (1) Defendant used a facility of interstate
+commerce, (the
+internet); (2) to
+attempt to
+knowingly persuade, induce, entice, or coerce; (3)
+a person Defendant believed to be less
+than
+Page 12
+offense and his actions constitute a substantial step
+sexual conduct. It is under this framework that the
+Court proceeds with its analysis of Count II.
+1. Travel in interstate commerce
+• "travel in interstate commerce simply means i
+love from one state to another. Defendant ha
+admitted that he traveled from Maryland to
+Virginia, therefore, this element is satisfied.
+2. Intent to engage in illicit sexual conduct
+Next, the Government must prove that Defendant
+had the intent to engage in illicit sexual conduct.
+The term "illicit sexual conduct" is defined in 18
+U.S.C. § 2423(f) as "a sexual act(as defined in
+section 2246) with a person under 18 years of age
+that would be in violation of Chapter 109A if the
+sexual act occurred in the *788 special maritime
+and territorial jurisdiction of the United States."
+[FN7] Put simply, the Government must prove that
+Defendant traveled with the intent to engage in
+sexual activity which, if it had occurred, could have
+been charged as an offense in a federal enclave.
+Section 2243(a)(within chapter 109A) criminalizes
+knowingly engaging in a sexual act with a person
+who "has not attained the age of 16 years." 18
+U.S.C. § 2243(a). Therefore, if Defendant intended
+to engage
+in
+a sexual
+activity
+with
+a
+thirteen-year-old boy, as the Government alleges in
+this case,
+such activity is squarely within the
+meaning of "illicit sexual conduct" in § 2423(b).
+[FN8]
+FN7. Section 2246 defines a "sexual act"
+as:
+(A) contact between the penis and the
+vulva or the penis and the anus, and for
+purposes of this subparagraph contact
+occurs upon
+U.S.C. § 2422(b).
+B. Travel with Intent to Engage in Ilicit Sexual
+Conduct under § 2423
+[7] Defendant has also been charged with travel
+with intent to engage in illicit sexual conduct under
+penis, the mouth and the vulva, or the
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=... 12/18/2007
+
+
+
+- 451 F.Supp.2d 775
+(C) the penetration, however slight, of the
+Page 13
+or arouse or gratify the sexual desire of
+any person; or
+(D) the intentional touching, not through
+the clothing, of the genitalia of another
+person who has not attained the age of 16
+years with an intent to abuse, humiliate
+harass, degrade, or arouse or gratify the
+sexual desire of any person;
+18 U.S.C. § 2246
+FN8. It is not required that Defendant
+engage in the intended illegal sex at the
+destination, but solely that he act with the
+intent. Hersh, 297 F.3d at 1246-47.
+This Court finds
+this element is satisfied since
+Defendant traveled with the intent to engage in
+sexual activity with a thirteen-year-old boy. First, it
+is unmistakable from the evidence that Defendant
+intended to engage in sexual activity at his
+destination. In fact, Defendant admitted so at trial
+when testifying that he was traveling to engage in
+homosexual
+nonetheless. In light of these admissions, there is
+little left for this Court to decide on the issue of
+whether Defendant intended to engage in sexual
+activity.
+Defendant replies "not something good" and "]
+know I'm in trouble."
+In sum, Defendant's repeated acknowledgment of
+"Conrad's" age and his incriminating statements it
+he confrontation with NBC lead this Court t
+conclude that Defendant clearly intended to meet a
+thirteen-year-old boy for sex. Since Defendant
+tended to engage in sexual activity with
+hirteen-year-old boy, and such sexual activity i
+considered "illicit sexual conduct" within the
+meaning of the statute, this Court concludes that this
+element of § 2423(b) is satisfied.
+Sined a teasingle doubt, that ete dan sailed
+across state lines and that such travel was with the
+intent to engage in illicit sexual conduct, this Court
+*789 finds Defendant guilty of violating 18 U.S.C. §
+IV. Conclusion
+For the foregoing reasons, this Court finds
+to engage in illicit sexual conduct in violation of 18
+U.S.C. § 2423(b) (Count II).
+he was enticing, inducing, and persuading an
+individual he believed was a thirteen-year-old boy.
+There is no evidence before the Court (nor does
+defense counsel argue) that Defendant's mental state
+as to "Conrad's" age changed between the time he
+was "inducing, enticing, and persuading" over the
+internet and the time he was traveling almost
+immediately thereafter. Defendant's mental state
+whilst traveling is confirmed by his statements to
+Virginia. Den asked spad are you doing here.
+https://web2.westlaw.com/print/printstream.aspx?vr=2.0&sv=Full&rs=WLW7.11&prft=...
+
+
+
+H
+U.S. | Fuller
+C.A.6 (Ohio),2003.
+This case was not selected for publication in the
+Federal Reporter.NOT RECOMMENDED FOR
+FULL-TEXT PUBLICATIONSixth Circuit Rule
+28(g) limits citation to specific situations. Please
+see Rule 28(g) before citing in a proceeding in a
+court in the Sixth Circuit. If cited, a copy must be
+served on other parties and the Court.Please use
+FIND to look at the applicable circuit court rule
+before citing this opinion. Sixth Circuit Rule 28(g).
+(FIND CTA6 Rule 28.)
+Jnited States Court of Appeals, Sixth Circuit
+UNITED STATES of America, Plaintiff-Appellee,
+James Stanley FULLER, Defendant-Appellant.
+No. 02-3303.
+Oct. 9, 2003.
+Defendant appealed his conviction, by a jury in the
+United States District Court for the Northern
+District of Ohio, John M. Manos, .., of attempting
+to entice a minor by computer or telephone to
+engage in criminal sexual activity, and related child
+pornography offenses. The Court of Appeals, Guy,
+Jr., J., held that: (1) electronic messages and e-mails
+were not illegally seized; (2) apartment lessee had
+authority to consent to warrantless search of room
+in which defendant was staying; (3) evidence was
+that production
+pornography images involved use of a minor
+sentence enhancements for use of material involving
+a prepubescent minor, for use of a computer in
+nvolved distribution, and on basis that offense
+nvolved sadistic or masochistic conduct, was no
+West Headnotes
+[1] Telecommunications 372 €-1439
+Affirmed.
+or Disclosure
+372k1435 Acts Constituting Interception
+Computer
+Communications. Most Cited Cases
+(Formerly 372k494.1)
+FBI's capture of instant messaging sessions and
+e-mails did not constitute an illegal warrantless
+seizure, where the communications were sent by
+defendant to an undercover FBI account.
+12] Searches and Seizures 349 €-125
+349 Searches and Seizures
+349II Warrants
+349k123 Form and Contents of Warrant;
+Signature
+349k125 k. Objects or Information
+Sought. Most Cited Cases
+Search warrant which identified defendant's
+computer and its files and records as items to be
+seized was sufficiently particularized, with respect
+to the scope of the search, to allow search for
+defendant's computer and the files and records
+stored on it.
+13] Searches and Seizures 349 €-174
+349 Searches and Seizures
+349V Waiver and Consent
+349k173 Persons Giving Consent
+349k174 k. Owners of Property; Hosts
+and Guests. Most Cited Cases
+Apartment lessee had authority to consent to
+arrantless search of spare bedroom in whi
+efendant was staying as an overnight gues
+14] Commerce 83 €-82.10
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H... 12/18/2007
+
+
+
+83 Commerce
+83II Application to Particular Subjects and
+Methods of Regulation
+83II(J) Offenses and Prosecutions
+83k82.5 Federal Offenses and Prosecutions
+83k82.10
+Offenses
+Activity Unlawful Under State Law. Most lied
+Cases
+Infants 211 €-13
+211 Infants
+211I1 Protection
+211k13 k. Protection of Health and Morals.
+Most Cited Cases
+Evidence was sufficient to support conviction for
+attempted enticement of
+a
+minor,
+even
+if
+government offered no proof that victim was in fact
+a minor, that any sexual activity occurred, or that
+the necessary
+nexus to
+interstate
+or
+foreign
+commerce existed; age of victim and fact of sexual
+activity were immaterial inasmuch as defendant was
+only charged with attempting to entice a minor, and
+interstate commerce connection was established by
+indisputable evidence that defendant used both the
+internet
+the
+telephone in committing the
+offense. 18 U.S.C.A. § 2422(b).
+[5) Obscenity 281 €-2.5
+281 Obscenity
+281k2 Power to Regulate; Statutory and Local
+Regulations
+281k2.5 k. Particular Regulations. Most Cited
+Cases
+Statute under which defendant was convicted, in his
+prosecution on three counts relating to interstate
+transportation or transmission of images of child
+16] Obscenity 281 €-17
+281 Obscenity
+281k14 Evidence
+281k17 k. Weight and Sufficiency. Most
+Evidence was sufficient to establish, in prosecution
+for three counts relating to interstate transportation
+or transmission of images of child pornography, that
+production of the visual images involved use of a
+minor engaged in sexually explicit conduct; severa
+experts indicated that the images appeared to be of
+real children, and there was no evidence that the
+images were computer-generated. 18 U.S.C.A. §
+2252(a)(1), (a)(4)(B).
+17] Sentencing and Punishment 350H €-995
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(H) Proceedings
+350HIV(H)3 Hearing
+350Hk992 Findings and Statement of
+Reasons
+350Hk995 k. Necessity. Most Cited
+Cases
+Imposition, in sentencing on three counts relating to
+interstate transportation or transmission of images
+of child pornography, of enhancement for use of
+material involving a prepubescent minor was not
+erroneous, even though trial court failed to make
+required factual findings; defendant failed to create
+any dispute of fact inasmuch as he offered no
+evidence to contradict medical testimony that 13 of
+the images were of minors at a developmental stage
+for which the average age was 10 years. 18
+U.S.C.A. § 2252(a)(1),
+(4)(B);
+Fed.Rules
+Cr.Proc.Rule 32(c)(1), 18 U.S.C.A.; U.S.S.G. §
+2G2.2(b)(1), 18 U.S.C.A.
+(8] Sentencing and Punishment 350H €-995
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(H) Proceedings
+350HIV(H)3 Hearing
+350Hk992 Findings and Statement of
+Reasons
+350Hk995 k. Necessity. Most Cited
+Cases
+Imposition, in sentencing on three counts relating to
+on chid pransporatior tangi for image se
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H... 12/18/2007
+
+
+
+77 Fed.Appx. 371, 2003 WL. 22331999 (C.A.6 (Ohio))
+computer in transmission of the material, was not
+erroneous even though trial court failed to make
+required factual findings; defendant failed to create
+any dispute of fact inasmuch as his conviction
+established that he transmitted child pornography by
+computer, and evidence at trial showed that he sent
+and downloaded child pornography. 18 U.S.C.A. §
+2252(a)(1),
+(a)(4)(B); Fed.Rules Cr.Proc.Rule
+32(c)(1), 18 U.S.C.A.; U.S.S.G. § 2G2.2(b)(5), 18
+U.S.C.A.
+[9] Sentencing and Punishment 350H €-995
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(H) Proceedings
+350HIV(H)3 Hearing
+350Hk992 Findings and Statement of
+Reasons
+350Hk995 k. Necessity. Most Cited
+Cases
+Imposition, in sentencing on three counts relating to
+interstate transportation or transmission of images
+of child pornography, of enhancement on basis that
+offense involved distribution, was not erroneous
+even though trial court failed to make required
+factual findings; defendant's objections failed to
+create any dispute of fact inasmuch as nothing
+contradicted evidence that he transmitted child
+pornography as part of his attempt to entice a minor
+into sexual
+activity. 18 U.S.C.A. § 2252(a)(1),
+(a)(4)(B),
+2422(b);
+Fed Rules
+Cr.Proc.Rule
+32(c)(1), 18 U.S.C.A.;
+§ 2G2.2(b)(2), 18
+U.S.C.A.
+[10] Sentencing and Punishment 350H C-995
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HI_ (H) Proceedings
+350HIV(H)3 Hearing
+350Hk992 Findings and Statement of
+Reasons
+350Hk995 k. Necessity. Most Cited
+Imposition, in sentencing on three counts relating to
+interstate transportation or transmission of images
+of child pornography, of enhancement on basis that
+offenses involved sadistic or masochistic conduct,
+ortraying sexual penetration of prepubescent gir
+at would likely be painful, and he did not raise
+U.S.C.A.
+§ 2252(a)(1), (a)(4)(B); Fed.Rules
+Cr.Proc.Rule 32(c)(I), 18 U.S.C.A.; U.S.S.G. §
+*373 On Appeal from the United States District
+Court for the Northern District of Ohio.
+Before GUY and DAUGHTREY, Circuit Judges;
+and LAWSON, District Judge. FN*
+FN* The Honorable David M. Lawson,
+United States District Judge for the Eastern
+District of Michigan, sitting by designation.
+GUY, Circuit Judge.
+**1 Defendant,
+James Stanley Fuller, appeals
+following his conviction by a jury on four counts:
+(1) attempting to entice a minor by computer or
+telephone to engage in criminal sexual activity (18
+U.S.C. § 2422(b)); (2) interstate transportation of
+photographic computer files from Georgia to Ohio
+depicting
+engaged in sexually explicit
+conduct (18 U.S.C. § 2252(a)(1)); (3) interstate
+transmission of photographic computer files by
+computer depicting minors engaged in sexually
+explicit conduct (18 U.S.C. § 2252(a)(1)); and (4)
+possession of photographic computer files that had
+been transported in interstate commerce depicting
+minors engaged in sexually explicit conduct (18
+U.S.C. § 2252(a)(4)(B)). Defendant, who chose to
+represent himself, was sentenced to a term of
+imprisonment of 135 months to be followed by a
+two-year term of supervised release.
+Through appointed counsel, defendant challenges
+his sentence on the grounds that the district court
+failed to make adequate factual findings and erred
+in its application of the guidelines. In addition,
+counsel contends (in an argument also made in
+defendant's pro se filings), that defendant's
+convictions on counts 2, 3, and 4 must be vacated
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prfl=H... 12/18/2007
+
+
+
+. 77 Fed.Appx. 371
+under Ashcroft | Free Speech Coalition, 535 U.S.
+234, 122 S.Ct. 1389, 152 L.Ed.2d 403 (2002),
+because the government failed to prove that the
+depictions in the computer files were of actual*374
+human beings. Although sometimes repetitive and
+undeveloped, defendant's pro se filings include
+Page 4
+o his convictions on what appear to be sutficienc
+of the evidence grounds. For the reasons discusse
+sentence.
+I.
+Defendant came to the attention of the FBI after two
+adult females, Margaret Dudas and Marjorie
+Vizurraga, reported his preoccupation with having
+sex with minors. Both women made contact with
+defendant over the Internet through the instant
+messaging (IM) service offered by AOL and
+communicated with him by e-mail and telephone
+before meeting him in person.
+Fuller used the screen name "Blueey0123" to
+communicate with Dudas through AOL. During one
+telephone conversation with Fuller, Dudas received
+an IM from someone using the screen name "
+K9Teacher" that forwarded a picture of a dog in a
+sexual position with a woman. Dudas later realized
+that she heard the AOL chimes on Fuller's end of
+the line each time "K9Teacher" communicated with
+her, but when she blocked messages from
+K9Teacher" the chiming stopped. Fuller met
+Dudas at her home and, after consensual sex,
+commented on a photograph of Dudas's 14-year-old
+Dugh and he fuller aked abrese be en
+having sex with them both, Dudas threw him out.
+Fuller communicated with Vizurraga through AOL
+using the screen names "Stan046" and "Blueey0123.
+" Fuller, who said he trained major league baseball
+layers around the country, stayed with Vizurrag
+1 Cleveland during their brief relationship. Sh
+testified that she ended their relationship after about
+a month because of his preoccupation with sex and
+is desi to hars, her parting a is gearala s mil
+abysitter FN
+FN1. Both Dudas and Vizurraga testified
+xplicitly about what Fuller had said abou
+exual acts he wanted them to perform o
+underage girls while he participated.
+Cross-examines enth of them.
+investigating
+investigat Sile lignian inaux bom
+Fuller.
+another FBI office that an earlier AOL account in
+Fuller's name had been terminated for having
+transferred child pornography. In answer to an
+administrative subpoena, AOL advised that Fuller
+had been a member of AOL since February 27,
+2000, and
+used screen
+names including
+Blueey0123," "April0435," and "K9Teacher01."
+With this information, Vigneaux connected to the
+Internet via AOL and, using the undercover screen
+name "Peaches14kwl," added "Blueey0123" to the
+account's IM "buddy list." On July 12, 2000,
+Vigneaux made contact with defendant and relayed
+that "Peaches" was almost 14 years old and lived
+with her mother. Fuller said he was 48 years old,
+and they exchanged photographs. Vigneaux sent
+Fuller a photograph of Special Agent Kelly Liberti,
+which had been taken when she was 14 years old
+and in which she was dressed as a cheerleader. As
+the session continued, Fuller asked "Peaches" to
+call him on the telephone and discussed, in sexually
+telephone
+conversations
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H... 12/18/2007
+
+
+
+77 Fed.Appx. 371, 2003 WL. 22331999 (C.A.6 (Ohio))
+between Fuller and Agent Liberti.
+During their next IM session on July 17, 2000,
+Fuller told "Peaches" that he was in Cleveland and
+was staying with a major league baseball player.
+He asked about meeting with her, offered to take
+digital pictures of her, and questioned her in explicit
+terms about her sexual activity and asked if she had
+sex with a 13-year-old girlfriend. Fuller again
+asked that she call him on his cellular telephone.
+Vigneaux arranged to have Agent Liberti call a few
+hours later, posing as "Peaches" and identifying
+herself as "Brianna." Fuller asked her age again
+and was told she was "almost 14." Fuller tried to
+arrange for them to meet that night, told her they
+could have privacy, promised that they would go
+slowly, and talked explicitly about sex.
+Fuller contacted "Peaches" by instant messaging on
+July 19, 2000, and suggested that they could meet
+while her mother was at work. He accused her of
+being a "talker and not a doer." At the end of the
+session, she agreed to call him 30 minutes later.
+Liberti called Fuller as agreed, telling him she could
+ride her bicycle to meet him the following afternoon
+after her mom left for work. Fuller asked about her
+mom's age, looks, and if she was dating anyone.
+He also asked in explicit terms about specific sex
+acts; including multiple partners, domination, sex
+with dogs, sex with other girls, and mother/daughter
+sex. When Liberti expressed interest, Fuller agreed
+to e-mail her some pictures of things they were
+talking about. They discussed arrangements for
+their meeting the next day, and Liberti agreed to
+call him as soon as her mother left for work. Fuller
+later sent "Peaches" an e-mail with two pictures of
+women having sex with dogs.
+**3 The next morning, July 20, Fuller and "Peaches
+" conversed by instant messaging about where and
+when they would meet and what they would each be
+wearing. Fuller e-mailed "Peaches" several more
+sexually explicit pictures; including one Fuller told
+her was of a 13-year-old girl FN3 Fuller said she
+could meet two Cleveland Indian baseball players
+after he picked her up, explaining that he would say
+she was the daughter of a friend, and told her that
+they then could go to the apartment where he was
+staying to be alone. About 30 minutes later, Liberti
+Page 5
+FN3. That file was named "13 year old
+getting fucked and licking mom.bmp."
+SEESE
+a blindfold, a cat-o-nine tails, and a prescription
+bottle containing Viagra. Agent Liberti located
+Russell Branyan, the baseball player with whom
+Fuller had been staying, and told him about the
+arrest. Branyan had known Fuller professionally
+for several years, but Fuller had never stayed with
+him before.
+Branyan testified that Fuller spent a lot of time
+using the computer in the spare *376 bedroom of
+the apartment. Although Branyan had asked Fuller
+to leave because he
+had continued to smoke
+cigarettes in the apartment, Fuller had not vacated
+before his arrest. Branyan offered to cooperate,
+gave them consent to search the apartment, and
+signed a consent-to-search form to that effect.
+When agents entered the apartment and looked in
+the spare bedroom, they saw a laptop computer that
+displayed the AOL sign-on screen for "Blueey0123"
+and nine "minimized" boxes showing partial file
+names. Although Branyan had given permission to
+remove Fuller's possessions, agents
+waited and
+obtained a search warrant before seizing defendant's
+Compaq Presario notebook computer.
+Barry Gummow, a computer forensic examiner, was
+lemon maximized exte one boxes so that
+photographs could be taken of the images, which
+included sexually explicit pictures involving both
+mother/daughter sex and sex with dogs. Grummow
+then shut down the computer and seized it for
+kamination. On the computer, Gummow foun
+vidence of child pornography downloaded throug
+AOL from the Internet; Internet history files
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H... 12/18/2007
+
+
+
+Page 6
+showing child pornography web sites visited by
+Fuller; and photographs of Fuller and other women,
+some taken with the digital camera seized at the
+time of his arrest. Among the pictures found on
+Fuller's computer were those that had been sent
+between Fuller and "Peaches."
+Using the Tanner Scale of Pubertal Development,
+Dr. Douglas Rogers, a pediatric endocrinologist at
+the Cleveland Clinic, testified that 21 pictures taken
+rom defendant's computer depicted minor female
+t or below Tanner Stage Four (for which th
+average age is 13), and that 13 of those pictures
+were of females at or below Tanner Stage One (for
+which the average age is 10). The government also
+offered the opinion of Douglas Rehman, an expert
+in computer forensics and
+concerning his examination of the images for
+evidence of alteration.
+**4 Arrested pursuant to a complaint and warrant
+on July 20, 2000, Fuller was detained without bond.
+After the indictment was filed on August 9, 2000,
+Fuller was arraigned and entered a plea of not
+guilty. Defendant's retained counsel withdrew, as
+did defendant's next two court-appointed attorneys.
+Defendant's third appointed counsel represented
+him before trial and then served as an advisor
+during trial because defendant had asserted his right
+to represent himself. That attorney was permitted
+to withdraw prior to sentencing, and new counsel
+served as defendant's advisor at sentencing and filed
+a brief on appeal. Timely notice of appeal was
+filed both by Fuller and by his appointed counsel.
+II.
+A. Denial of Motion to Suppress
+[1] Fuller
+suppress, we review the district court's factual
+indings for clear err
+• and the legal conclusions de
+ovo. United States | Atkin, 107 F.3d 1213, 121(
+(6th Cir. 1997). In his pro se filings, Fuller argues
+that the FBI illegally seized communications from
+AOL without a warrant in violation of 18 U.S.C. §
+2703. Because this argument was not mentioned in
+the district court's orders, it is not clear whether the
+issue was preserved for appeal. Even if it was,
+however,
+communications eported, plain the instan
+messaging sessions and e-mails, were sent by Fuller
+to the undercover FBI account and were not
+obtained through disclosure forced upon AOL.
+*377 [2] Fuller challenges the search and seizure of
+Attachment G to the warrant only identified items to
+be seized, but did not authorize the search for those
+We cannot accept this distinction
+meaningful and agree with the district court's
+implicit finding that the search warrant was
+sufficiently particularized with respect to the scope
+of the search to satisfy the Fourth Amendment and
+allow search for the computer and the files and
+records stored on it. Although Fuller challenged
+the warrant on other grounds, the district court
+observed in a footnote that defendant
+has not argued that the description "all personal
+computers/computing systems located therein" is
+unconstitutionally overbroad. The Court notes that
+the determination of the requisite particularity must
+be "flexible" and the description of items to be
+investigaon armile United States activiair, 2e4
+investigation permit." United States
+F.3d 690, 697 (6th Cir.2000) (citing United States
+| Ables, 167 F.3d 1021, 1033 (6th Cir.1999)).
+[3] Second, Fuller challenges the validity of
+Branyan's consent for the search of the apartment's
+spare bedroom. Specifically, Fuller argues that he
+was an overnight guest in Branyan's apartment and
+spent most of his time in the spare bedroom with the
+door closed. Consequently, Fuller claims, Branyan
+lacked authority to consent to a search of the spare
+bedroom that revealed the presence of the computer
+and led to the search warrant. There is support for
+defendant's contention that, as an overnight guest,
+he had an expectation of privacy that gives hi
+standing to challenge the search. Minnesota
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H... 12/18/2007
+
+
+
+Olson, 495 U.S. 91, 110 S.Ct. 1684, 109 L.Ed.2d
+5 (1990). Nonetheless. a warrantless search doe
+ot violate the Fourth Amendment if police have
+nsent to search from one who possesses comme
+thority over the premises with the abse
+Page 7
+S.Ct. 988, 39 L.Ed.2d 242 (1974)). The record
+supports the district court's finding that Branyan, as
+the lessee, had authority to consent to the search of
+the spare bedroom. FN4
+FN4. The district court observed that "the
+lessee's consent to the instant search of the
+spare bedroom provides an independent
+eason to deny the Detendan
+uppress. See United States | Hall, 97
+Clutter, 914 F.2d 775,
+ir. 1990), cert. denied,499 U.S. 947, 111
+S.Ct. 1413, 113 L.Ed.2d 466 (1991)
+(citing United States | Matlock, 415 U.S.
+, 169, 94 S.Ct. 988, 39 L.Ed.2d 242
+(1974)." Moreover,
+government could not show Branyan's
+consent was valid, a warrantless entry does
+not violate the Fourth Amendment when it
+is based on consent from a third party
+whom the agents reasonably believed
+(even if erroneously) to have common
+177, 110 S.Ct. 2793, 111 L.Ed.2d 148
+(1990)).
+B. Attempted Enticement of A Minor
+United States Code, for which *378 JAMES
+STANLEY FULLER, a.k.a. JAMES STANLEY,
+a.k.a. STAN FULLER, a.k.a. BLUEEY0123, a.k.a.
+K9TEACHERO1, can be charged with a criminal
+offense under Title 18, Section 2243, United States
+under Ohio Revised Code Sections
+2907.04(A), 2907.06(A)(4), and 2907.07(C), and
+under Code of Georgia Sections 16-6-2, 16-6-3, and
+16-6-4; all in violation of Title 18, United States
+Code, Section 2422(b).
+Fuller argues that the government offered no proof
+That the octim a in that a minas hat me ceual
+nexus to interstate or foreign commerce. FNS
+**5 Count 1 of the indictment charged that between
+July 12 and July 20, 2000, James Stanley Fuller,
+using facilities and means of interstate and foreign
+commerce, that is, computerized access to the
+Internet and telephones, did knowingly attempt to
+persuade, induce, entice, and coerce an individual
+who had not attained the age of 18 years, that is, a
+thirteen (13) year old girl, to engage in sexual
+activity, as defined in Title 18, Section 2246,
+N5. Fuller also argues that the indictmen
+vas jurisdictionally deficient because i
+refers to offenses for which he can be
+charged. On the contrary, the indictment
+clearly charges Fuller, in language that
+parallels the statute, with attempted
+enticement of a minor to engage in sexual
+activity for which he could be charged
+under state law. See18 U.S.C. § 2422(b).
+[4] First, Fuller asserts that both the minor age of
+the victim and a sexual act are elements of the
+charged offense. This claim is meritless. This
+statute, as amended in 1998 to add "or attempts to
+do so," criminalizes both the enticement and the
+attempted enticement,
+not the
+performance of the sexual activity, United States l
+Bailey, 228 F.3d 637, 639 (6th Cir.2000) (intent to
+commit the sexual act is not required to prove
+attempt to persuade a minor to engage in sexual
+activity), cert. denied,532 U.S. 1009, 121 S.Ct.
+1737, 149 L.Ed.2d 661 (2001).
+Further, as the district court found in denying
+Fuller's motion to dismiss count 1, a defendant may
+be charged with knowingly attempting to persuade,
+induce, entice, or coerce a minor to engage in
+sexual activity even though he is mistaken as to the
+true age of the person with whom he admittedly
+communicated. Several courts have specifically
+held that a defendant may be convicted of attempted
+persuasion or enticement of a minor even though
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H... 12/18/2007
+
+
+
+the defendant had been communicating with an
+United States Post, 296 Fd 1222 (ih
+296 F.3d 1222 (11th
+ir.2002), cert. denied,537 U.S. 1176, 123 S.
+006. 154 L.Ed.2d 921 (2003): United States
+arner, 251 F.3d 510 (5th Cir.2001); United States
+- Miller, 102 F.Supp.2d 946, 948 (N.D.III.2000). FN
+Page 8
+U.S.C. § 2422(b). While there was evidence that
+recipient, the interstate commerce connection was
+established in this case by indisputable evidence
+hat Fuller used both the Internet and the telephone
+acilities or means of interstate commerce, it
+committing the offense. FN7
+FN6. Although not fully developed, Fuller
+also seems to be arguing that there was
+insufficient evidence to support a finding
+hat he believed he was communicatins
+with a minor. Fuller specifically refers to
+evidence that, during their final telephone
+conversation on July 20, Liberti indicated
+she was "'almost 14," "14 going on 18," *
+going on 21," and then assented when
+Fuller responded:
+hear ... you're 21 as far as I'm concerned."
+FN7. Fuller also asserts that because
+counts 1 and 3 refer to interstate and
+foreign commerce, the government was
+required to prove both. We find no error
+in this regard.
+C. Counts 2, 3, and 4
+Seeking reversal of his convictions on counts 2, 3,
+and 4, Fuller argues-both through counsel and in his
+Fuller preserved
+such a challenge by
+moving
+for judgment of acquittal at the
+close of the proofs, we need only examine
+the transcripts of the IM sessions
+telephone calls to be more than satisfied
+that there
+was sufficient evidence
+from
+which a rational trier of fact could find
+Fuller believed he was communicating
+with a minor.
+535 U.S. 234, 122 S.Ct. 1389, 152 L.Ed.2d 403
+(2002), because the government failed to prove that
+the visual depictions were of "real" children as
+opposed to virtual, computer-generated images that
+"appeared to be" children.
+Decided several months after Fuller was sentenced,
+the Court in Free Speech Coalition struck down, as
+overbroad and unconstitutional, two provisions
+Finally,
+defendant
+seems
+to
+argue that the
+added by the Child Pornography Prevention Act of
+government failed to prove the interstate commerce
+1996 (CPPA). Those two provisions expanded the
+element of the offense because telephone calls to
+definition of child pornography to include: any
+internet service providers (ISP) made within the
+visual depiction, including (1) a computer generated
+caller's local calling area are
+"local calls" for
+image, that "is, or appears to be, of a minor
+reciprocal compensation arrangements under the
+engaging in sexually explicit conduct,"18 U.S.C. §
+cations Act of 1996. See Bell Atl.
+Tel. Cos. FCC, 206 F.3d 1 (D.C.Cir.2000)
+2256(8)(B) (emphasis added); and (2) any sexually
+explicit image that was "advertised, promoted,
+(vacating FCC ruling that such calls were not local
+presented, described, or distributed in such a
+because they extend beyond the ISP to out-of-state
+manner that conveys the impression " of depicting "
+web sites). The "local call" designation for
+a minor engaging in sexually explicit conduct,"18
+compensation purposes does not control this issue.
+U.S.C. § 2256(8)(D) (emphasis added). The Court
+held that by encompassing "virtual" child
+pornography that involved no real children these
+definitions violated the First Amendment because
+interstate or foreign commerce" to commit the
+they proscribed "a significant universe of speech
+offense of attempted persuasion or enticement. 18
+that is neither obscene under Miller nor child
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H. 12/18/2007
+
+
+
+pornography
+under Ferber." Free Speech
+Coatening Miles Calizia 223 SS. 15,51
+Ct. 2607, 37 L.Ed.2d 419 (1973), and New York
+Ferber, 458 U.S. 747. 102 S.Ct. 3348, 73
+C.Ed.2d 1113 (1982)).
+[5] To the extent that Fuller's claim can be
+understood to argue that his convictions could have
+been based on an unconstitutional definition of
+child pornography, we find no danger of this was
+presented here because Fuller's convictions were for
+violations of 18 U.S.C. § 2252(a)(1) and (a)(4)(B).
+These sections each require proof both that "the
+producing of such visual depiction involves the use
+of a minor engaged in sexually explicit conduct"
+and that "such visual depiction is of such conduct."
+18 U.S.C. § 2252(a)(1)(A) and (B)
+2252(a)(4)(B)(i)
+These elements
+correspond to the definition of child pornography
+that predated the CPPA amendments, now found in
+18 U.S.C. § 2256(8(A), which was not invalidated
+by the Court in
+Free Speech
+Speech Coalition,535 U.S. at 1397, 122 S.Ct. 1751;
+see also United States
+Kelly, 314 F.3d 908
+911-13 (7th Cir.), cert. denied,538 U.S. 1001, 123
+S.Ct. 1923, 155 L.Ed.2d 829 (2003). As a result,
+we find Fuller's convictions on counts 2, 3, and 4
+were not rendered unconstitutional
+Coalition. Accord United States
+MY Deaton, 328
+F.3d 454, 455 (8th Cir.2003) (upholding conviction
+under § 2252(a)(4)(B)). FN8
+Page 9
+substantial rights because there was no
+evidence that the depictions were anything
+other than of "actual" minors. See, e.g.,
+Kelly,
+314 F.3d at 911 (affirming
+conviction under § 2252A(a)(5)(B)
+been endant substantial night ere
+ritual claired that the images were of
+*380 **7 Next, without identifying this claim as a
+challenge to the sufficiency of the evidence.
+defendant nonetheless argues that the government's
+proofs were insufficient to support a finding that the
+visual depictions were produced using
+"actual"
+minors. In reviewing the sufficiency of the
+evidence, "the relevant question is whether, after
+viewing the evidence in the light most favorable to
+the prosecution, any rational trier of fact could have
+und the essential elements of the crime beyond
+easonable doubt." Jackson | Virginia, 443 U.
+307, 319, 99 S.Ct. 2781, 61 L.Ed.2d 560 (1979). FN9
+FN8. To the extent that defendant may rely
+on recent cases applying Free Speech
+Coalition to child pornography convictions
+under a related statute, 18 U.S.C. § 2252A,
+those cases must be distinguished because §
+2252A incorporates
+the
+statutory
+definition of child pornography, including
+those provisions struck down by the
+was instructed
+according Co. United hates abyssin, 32d
+F.3d
+522
+(4th
+Cir.2003) (reversing
+conviction under § 2252A(a)(5)(B) where
+issue was preserved). On plain
+error
+review, however, some courts have found
+the error did not affect the defendant's
+FN9. Because the government does not
+argue that our review is for plain error, we
+assume such a challenge to the sufficiency
+of the evidence was preserved by motion
+for judgment of acquittal at the close of the
+evidence. Neither party, however, has
+indicated whether that was in fact the case.
+[6] In particular, defendant argues that although Dr.
+testified concerning the developmental
+stages of the depicted minors, he conceded that he
+was not an expert in computers and could not
+determine whether the images were computerized or
+were of real minors. When asked if he could tell
+whether the pictures on defendant's computer were
+of actual people, Grummow testified that some of
+the pictures were of the defendant and other known
+persons and that the visual depictions of child
+pornography appeared to be" live human beings.
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H... 12/18/2007
+
+
+
+Finally, defendant relies on the statement by
+Rehman, the expert in computer forensics and child
+exploitation, that: "All of the images appear to
+have real children in them." When read in context,
+however, and in the absence of any evidence that
+the images were computer-generated or "virtual"
+child pornography, it is clear that there was
+sufficient evidence that actual minors were involved
+in the production of the images.
+Significantly, no contrary evidence was offered to
+suggest either that any of the visual depictions were
+computer generated, or that they were not produced
+using actual minors. Having not only heard the
+above testimony, but also having viewed the images
+in question, the jury was in a position to draw its
+own conclusions about whether they depicted actual
+children.
+Deaton,
+328 F.3d
+at 455 (jury's
+conclusion that real children were depicted may be
+upheld even when the only evidence offered
+167 s 3d tells a dice States is
+167
+F.3d
+449-50 (8th Cir.1999) (where
+defendant simply argues that images may or may
+not be of real children, the government is not
+required
+to negate as
+part of its
+proofs the
+unsupported speculation). ENIO
+FN10. Fuller's pro se pleadings also assert
+that the government failed
+burden of proving that he was personally
+involved in the production of the images.
+As the district court observed in denying
+one of defendant's motions to dismiss,
+Fuller was not charged with manufacture
+child pornography,
+proscribed by 18 U.S.C. § 2251, but rather
+with transportation and possession of child
+pornography
+in interstate
+commerce in violation of 18 U.S.C. § 2252
+, which does not require that the named
+defendant be involved in any way in the
+proded States the Trivel, depo. 89-580,
+1990 WL 170432,
+*2 (6th Cir. Nov.6,
+(unpublished
+disposition)
+(discussing differences between §5 2251
+and 2252 for double jeopardy purposes).
+Page 10
+*381 D. Sentencing
+Fuller, having decided to represent himself at
+sentencing, filed numerous objections to the
+probation department's calculation of the guideline
+range. Each of the objections was specifically
+identified and responded to in a written addendum
+to the presentence report. Due to certain objections
+information,
+the probation
+department reduced both the total offense level
+(from 36 to 34) and the criminal history category
+(from III to II). As an initial matter at the time of
+sentencing, the district judge took up and rejecte
+ecommended 2-level enhancemen
+obstruction of justice. Then, after making clear
+that he had carefully reviewed every one of the
+defendant's objections, the court indicated that no
+further argument was necessary with respect to the
+objections already made, overruled those objections
+without specific discussion, and accepted the
+probation department's calculation of the offense
+levels under United States Sentencing Guidelines
+Manual (USSG) §§ 2G2.1 and 2G2.2 (1998). EN11
+FN11. The 1998 edition of the United
+States Senteneing Guidelines Manual was
+applied in this case due to concerns about
+possible ex post facto problems that might
+arise from subsequent amendments to the
+relevant guideline provisions.
+**g Without challenging the guideline calculations
+themselves, defendant argues that the district court
+erred by applying enhancements for specific offense
+characteristics without making
+factual findings
+required by Fed.R.Crim.P. 32(c)(1). Despite the
+government's reliance on the context of the
+proceedings and the colloquy with the court at
+sentencing, the record is clear that the district court
+overruled
+defendant's
+objections
+to
+the
+enhancements without articulating the reasons for
+doing so. As we explain more fully below, we only
+affirm because we conclude that the denials asserted
+in the form of objections to the sentencing
+enhancements did not present a controverted or
+disputed matter for which findings were required.
+Even so, we cannot help but observe that this issue
+could easily have been avoided if the district court
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H... 12/18/2007
+
+
+
+had just addressed each of the enhancements in turn
+and stated the basis for finding that it should be
+applied in this case.
+At the time of sentencing, Rule 32(c)(1) (2001)
+stated that: "For each matter controverted, the court
+must make either a finding on the allegation or a
+determination that no finding is necessary because
+the controverted matter will not be taken into
+account in, or will not affect, sentencing." FNI2 "
+Because the purpose of the rule is to ensure that
+sentencing is based on reliable facts found by the
+court itself after deliberation, a court may not
+merely summarily adopt the factual findings in the
+presentence report or simply declare that the facts
+' a preponderance of the evidence."
+United States
+F.3d 528, 540 (6th Cir.2000)).
+This court has
+required "literal compliance" with this rule. United
+States | Tackett, 113 F.3d 603, 613 (6th Cir. 1997).
+Page 11
+FN12. This provision was
+replaced,
+December
+Fed.R.Crim.P.
+32(i)(3)
+clarifies that the sentencing court "may
+accept any undisputed portion of the
+presentence report as a finding of fact."
+*382 The requirement of literal compliance,
+however, assumes that the objections raise a matter
+which
+controverted. For example, in United
+States
+| Treadway, 328 F.3d 878, 885-86 (6th
+Cir.2003), petition for cert. filed,No. 02-11197, --.
+U.S.L.W.
+... (U.S. June 9, 2003), where the
+defendant had not objected, orally or in writing, to
+the drug quantity calculation, this court found "no
+reason to require a district court to make
+independent findings outside the PSR when the
+facts are undisputed." Id. at 886. Even an
+objection that represents a bare denial or "bare
+bones" assertion of a factual dispute will not give
+rise to a dispute within the meaning of Rule 32
+unless the defendant produces some evidence that
+calls the reliability or correctness of the alleged
+facts into question. United States | Lang. 333 F.3d
+(6th Cir.2003) (agreeing with United
+States Mustread, 42 F.3d 1097, 1102 (Te
+Cir. 1994)).
+Defendant claims error in the district court's
+overruling of his objections to the enhancements
+imposed
+for the following specific offense
+characteristics: (1) "the material involved a
+prepubescent minor or a minor under the age of
+twelve years" (2 levels); (2) "the offense involved
+distribution" (5 levels); (3) "the offense involved
+material that portrays sadistic or masochistic
+conduct or other depictions of violence" (4 levels);
+and (4) "a computer was used for the transmission
+of the material" (2 levels). USSG § 2G2.2(b)(1),
+(2), (3), and (5) (1998). The critical question is
+whether the objections placed any of these matters
+in controversy for purposes of Rule 32.
+1. Prepubescent Minor
+**9 [7] Fuller's objection to the first enhancement
+was that the government had failed to prove at trial
+that he had sent or received any visual depiction
+involving a prepubescent minor or a minor under
+the age
+of twelve years. As outlined above,
+however, Fuller offered no evidence at trial to
+dispute the testimony of Dr. Rogers that 21 images
+were of minors and that 13 of those images were of
+minors at a developmental stage for which the
+average age was 10 years. The only challenge to
+that testimony was
+the speculation, raised by
+cross-examination, that the images were not of "real
+" children. The fact that "real" children had been
+used was established by defendant's convictions on
+counts 2, 3, and 4. Thus, defendant's denial in this
+regard did not create a dispute as to any fact and the
+applicability of this specific offense characteristic
+cannot be said to have been reasonably controverted.
+2. Use of Computer
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H... 12/18/2007
+
+
+
+challenging the sufficiency of the evidence to
+support his convictions on counts 2, 3, and 4, but
+does not deny that "a computer was used for the
+transmission of the material" as is required for the
+enhancement under § 2G2.2(b)(5).
+[8] Because defendant's conviction on count 3
+required proof that he transmitted child
+pornography by computer, application of this
+enhancement for that offense cannot be contested.
+In addition, this court has recently adopted the
+Seventh Circuit's interpretation of this enhancement
+as applying equally to material that is either shipped
+by the defendant or received by the defendant as
+ong as a computer was used for the transmission of
+he *383 material. United States | Bovd. 312 F.3d
+213, 216 (6th Cir.2002) (following United States
+Richardson, 238 F.3d 837, 839 (7th Cir.2001)).
+The evidence at trial showed that child pornography
+was not only sent to Liberti, but was downloaded to
+defendant's computer from the Internet. Not only
+was this enhancement required by the convictions
+on counts 3 and 4, but defendant did not directly
+dispute the factual basis at sentencing.
+Page 12
+States | Laney, 189 F.3d 954 (9th Cir.1999)
+with a purpose of enticing another to have sex with
+him was sufficient to trigger the enhancement. 110
+F.3d at 263. In this case, nothing in the record
+pictions create a disputed question on the issue.
+3. Distribution
+Fuller objected
+to the enhancement under §
+2G2.2(b)(2), which applied if the offense involved
+distribution.
+The application
+define
+distribution" to include"any act related to
+distribution
+for pecuniary
+gain,
+including,
+production,
+transportation, and possession with
+intent to distribute." USSG § 2G2.2, comment.
+(n.1) (1998). Denying that he gave any
+visual
+depiction to anyone, defendant also objected on the
+grounds that there was no evidence of distribution
+for any pecuniary gain.
+[9] Although courts have differed on the issue, this
+court has followed the Fifth Circuit's lead and held
+that this enhancement encompasses distribution for
+distribution for
+F.3d 233, 237-38 (6th Cir.1998) (trading child
+ornography over the Internet was distribution for
+'alue") (following United States Canada, 11
+F.3d 260, 263 (5th Cir.1997)). But see United
+FN13. This guideline provision was
+substantially amended effective November
+1, 2000, to clarify that the enhancement
+applies to distribution for pecuniary gain;
+distribution for the receipt, or expectation
+of receipt, of a thing of value; distribution
+to a minor; distribution to a minor that
+was intended to persuade, induce, entice,
+coerce, or facilitate the travel of a minor to
+engage in prohibited sexual conduct; and
+distribution other than that specifically
+enumerated. USSG § 2G2.2(b)(2)(A)-(E)
+(2000).
+4. Sadistic or Masochistic Conduct
+**10 Finally, objecting to the 4-level enhancement
+under § 2G2.2(b)(3), Fuller stated generally that the
+government had not charged or proved an offense
+that involved depictions being sent or received by
+computer that portrayed "sadistic or masochistic
+conduct or other depictions of violence." This
+general denial does not create a factual dispute
+concerning the depictions, all
+of which were
+admitted into evidence and viewed by the district
+court, or present a controverted matter concerning
+the application of this enhancement.
+Although the guidelines themselves do not define
+what is meant by sadistic, masochistic, or violent
+depictions, courts must look to the common
+meaning
+of these
+terms
+to determine their
+application. See, e.g., United States | Parker, 267
+F.3d 839, 847 (8th Cir.2001), cert. denied, 535 U.S.
+1011, 122 S.Ct. 1592, 152 L.Ed.2d 509 (2002);
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H... 12/18/2007
+
+
+
+United States | Lyckman, 235 F.3d 234, 237-40
+(5th Cir.2000). The term "sadism," which is the
+most relevant to this case, is defined as the
+infliction of pain upon a love object as a means of
+obtaining sexual release." Lyckman, 235 F.3d at
+238 n. 19 (citation omitted). Construing*384 the
+terms "sadistic conduct" and "other depictions of
+violence" in the context of cases involving child
+pornography, courts have found the enhancement is
+warranted when the offense involves the depiction
+of a sexual act that is "likely to cause pain in one so
+young." Lyckman, 235 F.3d at 238-39.
+dislaviber vaginal thana fountation ma es
+displaying vaginal
+anal penetration
+prepubescent minor by either an adult male or a
+foreign object is likely to be painful and constitutes
+"sadistic conduct" that justifies the enhancement.
+See, e.g..
+312 F.3d at 1261-63; Parker, 267
+F.3d
+at
+847; Lyckman, 235 F.3d
+Canada,
+110 F.3d at
+264; United
+d' States 1
+States
+Caldwell, No. 97-5618, 1999 WL 238655, *9 (6th
+Cir. Apr.13, 1999) (unpublished disposition). One
+circuit has specifically held that the government
+need not present expert medical evidence to prove
+such acts would be painful to a young child.
+312 F.3d at 1262.
+[10] As the government aptly observes on appeal,
+the pictures found on defendant's computer included
+images of sexual penetration of prepubescent girls
+that present sufficient basis to find the material
+portrayed images of "sadistic conduct" justifying
+the 4-level enhancement.FNI4 Defendant's general
+objection did not dispute that pictures found or tal
+computer included images that portrayed
+penetration of prepubescent girls that would likely
+be painful. Nor did defendant present a legal
+controversy about the definition of sadistic conduct
+for purposes of the enhancement. As a result, the
+district court's failure to specify the reasons for
+applying the enhancement was not error. #NIS
+FN14. Government Exhibit 133 included
+two pictures entitled "Creempuff4u ...
+Page 13
+!!!! preteen gets it in the ass. bmp," "2
+year
+old getting fucked.bmp,"
+familyfun.jpg," and "preteen.21.bmp."
+FN15. As a result, we express no opinion
+with respect to the government's further
+contention on appeal that the enhancement
+under § 2G2.2(b)(3) may be based on
+images of bondage or bestiality that were
+not identified as child pornography.
+(Government Exhibits 128 to 132 were
+Bondage trapPed ave rips bop
+slave.2.bmp.") We note, however, that the
+decision relied on by the government to
+support this proposition rested on the
+interplay of the sentencing guidelines and a
+determination of relevant conduct where
+the convictions involved a common
+scheme to distribute both obscene material
+that depicted adults involved in
+sadomasochistic conduct and sexually
+explicit child pornography that did not
+Satise Schille 900 2d 960 ist
+Cir. 1992).
+AFFIRMED.
+C.A.6 (Ohio),2003.
+USFuller
+77 Fed.Appx. 371, 2003 WL 22331999 (C.A.6
+(Ohio))
+https://web2.westlaw.com/print/printstream.aspx?rs=WLW7.11&destination=atp&prft=H... 12/18/2007
+
+
+
+(Cite as: Not Reported in F.Supp.2d)
+H
+U.S. |. Patten
+D.N.D.,2003
+Only the Westlaw citation is currently available.
+United States District Court,D. North
+Dakota, Southeastern Division.
+UNITED STATES of America, Plaintiff,
+V.
+Casey Scott PATTEN, Defendant.
+Criminal File No. C3-03-44.
+July 28, 2003.
+Christopher J. Lancaster, Stefanson Plambeck Foss
+& Fisher, Moorhead, MN, for Detendant.
+MEMORANDUM OPINION AND ORDER
+DENYING MOTION TO DISMISS AND
+DENYING MOTION FOR A BILL OF
+PARTICULARS
+RALPH R. ERICKSON, District Judge.
+*1 Before the Court is Defendant's Motion to
+Dismiss and for Bill of Particulars (doc. # 13). The
+United States filed a brief in opposition (doc. # 14).
+Defendant filed a reply brief (doc. # 19). The
+United States then requested the leave of Court to
+file an additional brief relating to an issue of first
+impression (doc. # 20). The Court granted that
+request and accepted the United States' additional
+brief (doc. # 22) and allowed Defendant to file an
+additional brief (doc. # 24).
+Ndblondie2003 replied that she had dated older
+guys before.
+N1. In reality, ndblondie2003 was Wes
+argo Police Officer Al Schmid
+would allow a guy do to her. At the end of this
+conversation, Defendant asked her if she would
+want to "hook up sometime?" The two then agreed
+that they would talk on the phone first.
+Later that same day, Detendant talked
+to
+ndblondie2003 in the
+Yahoo chat room again.
+Defendant asked "Can you and I get drunk this
+week?"After discussing
+what kind of liquor
+nodblondie2003 liked, she stated "we could hook
+up this week."
+The next day, West Fargo Police Dispatcher Brandi
+Gunderson posed as ndblondie2003 and called
+Defendant. They arranged to meet in the parking lot
+of the West Fargo Sunmart store. Defendant stated
+that he would be driving a white Blazer with big
+headlights. When Defendant arrived in the Sunmart
+parking lot in the white Blazer, Officer Schmidt
+arrested him.
+STATEMENT OF FACTS
+On February 16, 2003, the detendant, Casey Patten
+ogged onto a Yahoo chat room using the screen
+name "got2run400." He had a conversation with
+someone using the screen name "ndblondie2003."
+At the start of the conversation, ndblondie2003
+identified herself as a sixteen-year-old female who
+lived in Fargo.FN Defendant told her that he was
+twenty-six and asked her if he was too old.
+ANALYSIS
+The grand jury indicted Defendant with luring a
+minor via the internet, in violation of 18 U.S.C. §
+2422(b). At the time of the instant offense, that
+statute read:
+Whoever, using the mail or any facility or means of
+interstate or foreign commerce, or within the special
+maritime and territorial jurisdiction of the United
+States knowingly persuades, induces, entices, or
+coerces any individual who has not attained the age
+of 18 years, to engage in prostitution or any sexual
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&in=_top&mt=.
+
+
+
+7 Not Reported in F.Supp.2d
+(Cite as: Not Reported in F.Supp.2d)
+activity for which any person can be charged with a
+criminal offense, or attempts to do so, shall be fined
+under this title and imprisoned not more than 15
+years, or both.
+18 U.S.C. § 2422(b)(1998). FN2
+FN2. The statute was amended in April
+2003
+to add a minimum mandatory
+sentence of five years and increase the
+maximum term of imprisonment to thirty
+years. 18 U.S.C. § 2422(b)(2003).
+I. Motion to Dismiss
+"Unless there is a stipulated
+immunity issues are implicated, a pretrial motion to
+dismiss an indictment is not a permissible vehicle
+for addressing the sufficiency of the government's
+evidence. "United States | DeLaurentis, 230 F.3d
+659, 660-61 (3d Cir.2000) (citing
+United States
+396 U.S. 77, 83 n. 7 (1969)). There is no
+corollary in criminal cases to a motion for summary
+judgment pursuant to Rule 56 of the Federal Rules
+of Civil Procedure. Id.
+at 661.The government is
+entitled to present all of its evidence at trial and
+then have its sufficiency tested by a motion for
+acquittal pursuant to Rule 29 of the Federal Rules
+of Criminal Procedure. Id.
+*2 Defendant argues that the government lacks any
+proof on three of the essential elements of this
+crime. First, Defendant
+argues that he never
+attempted to persuade, induce, entice, or coerce
+ndblondie2003 into engaging in sexual activity. The
+evidence submitted to the Court demonstrates that
+shortly after finding out that ndblondie2003 was a
+sixteen-year-old female living in Fargo, Defendant
+asked if he was too old for her and then engaged in
+a discussion with her about sex acts and what kinds
+of sexual things she would do with a man.
+Following that discussion, Defendant asked her if
+she would like to hook up. Whether this
+conversation or other portions of the conversations
+FN3 Defendant had with ndblondie2003 prove that
+he attempted to persuade, induce, entice, or coerce
+her into engaging in sexual activity is for a jury to
+decide.
+FN3. Defendant appears to argue that the
+government could not use the subject
+matter of the telephone conversation to
+prove the charge in the indictment since it
+is not the internet. Def.s Br. Supp. Mot
+Dismiss and for Bill of Particulars at 8
+However, the statute includes the use of "
+the mail or any facility or means of
+interstate or foreign commerce."18 U.S.C.
+(10th Cir.1974); United States 1 Giordano,
+No. 3:01CR216, 2002 WL 32082891
+(D.Conn. July 29, 2002).
+Second, Defendant argues that there is no evidence
+of a substantial step to prove attempt. Defendant did
+agree to meet with ndblondie2003 in the Sunmart
+parking lot in West Fargo, and he drove to that
+location. Whether this act, or any other evidence
+that the government intends to produce, constitutes
+a substantial step is for a jury to decide.
+Finally, Defendant argues that the government
+cannot prove that "any sexual activity for which [he
+could have been] charged with a criminal offense"
+was about to occur. See 18 U.S.C. § 2422(b).
+Defendant alleges that under Minnesota law, and
+the United States does not dispute this, it is not a
+crime for a sixteen-year-old to have consensual sex
+with someone who is eighteen or older. However,
+Defendant concedes that it is a crime in North
+Dakota.
+The United States argues that it does not have to
+prove that Defendant intended to have sex with
+ndblondie2003 in North Dakota in order to satisfy
+this final element of the statute. The phrase "any
+sexual act for which any person can be charged with
+description of the inter
+-emini. United Stales 2 Kerovich, 997 F. Supi
+246, 256 (D.Conn.1997). To satisfy this final
+element, the government must prove two items: 1)
+Defendant intended to engage in a sexual act with
+ndblondie2003 and 2) Defendant or ndblondie2003
+could have been charged with a criminal offense for
+that sexual act if it had occurred. See 18 U.S.C. S
+2422(b).
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&In=_top&mt=..
+
+
+
+• Not Reported in F.Supp.2d
+(Cite as: Not Reported in F.Supp.2d)
+The United States cites Kufrovich for the basic
+principle that the judge instructs the jury on the law;
+therefore the judge will instruct the jury on whether
+a sexual act violates the law. 997 F.Supp. at 256.
+However, when factual issues will determine which
+law applies, those factual issues must be determined
+first, see Blome Aerospatiale Helicopter Corp.,
+924 F.Supp. 805, 814 (D.Tex.1996), and the jury is
+the finder of fact. Assuming Defendant did intend to
+have sex with ndblondie2003, and did intend to
+have sex with her in Minnesota, then there is no "
+sexual act for which any person can be charged with
+a criminal offense" because a sixteen-year-old can
+have consensual sex with someone over the age of
+eighteen in Minnesota without either of them being
+charged with a criminal offense. The government
+will
+have to produce evidence that Defendant
+intended
+to
+engage in
+a
+sexual
+act
+with
+ndblondie2003 that he could be charged with if the
+sexual act had taken place in order to satisfy this
+final element. 18 U.S.C. § 2422(b).
+deci ebondie203 in Norl baod on or a jur e
+All of Defendant's arguments go to the sufficiency
+f the evidence. Since it is for a jury to decid
+hether the government has proved its case beyon
+a reasonable doubt, this case is not subject to
+dismissal. See DeLaurentis, 230 F.3d at 660-61
+(citing Knox, 396 U.S. at 83 n. 7) (stating that a
+motion to dismiss is not the appropriate method for
+addressing the sufficiency of the evidence against a
+criminal defendant).
+II. Motion for a Bill of Particulars
+Brockdorff. 992 F.Supp. 22 (D.C.1997) and United
+Pelton, 578 F.2d 701 (8th Cir.1978) for
+analogous support of its argument that it does not
+have to prove that Defendant intended to have sex
+with a sixteen-year-old in North Dakota. Both of
+these cases involve statutes that make the intended
+behavior itself a federal crime. See Pelton, 578 F.2d
+at 712 (stating that 18 U.S.C. § 2421 prohibits
+prostitution,
+prohibition is not "keyed to the legality or illegality
+of prostitution under the law of the state where the
+transportation ends"); Brockdorff, 992 F.Supp. at 23
+U.S.C. &
+sect; 2423(b)(1997))
+(making it ilegal for a person to travel in interstate
+commerce for the purpose of engaging in any sexual
+act with someone under eighteen years of age).
+Since 18 U.S.C. § 2422(b) does not make it illegal
+for a minor to have sex with an adult, the
+government has to rely on some other law that
+makes that sexual activity illegal.
+The decision to grant or deny a bill of particulars
+lies within the sound discretion of the trial court.
+Jnited States | Buffington, 578 E.2d 213, 214 (8t
+Cir. 1978) (citing United States | Long, 449 F.2
+288, 295 (8th Cir.1971)). A party must demonstrate
+good cause before a court will issue an order to
+compel or other order pertaining to discovery. See
+Fed.R.Crim.P. 16(d)(1) (stating that, for gooc
+cause, a court may grant appropriate relief on
+discovery
+matters).
+When
+the
+indictment
+substantially follows the words of the statute, a
+ourt does not abuse its discretion when it denies
+equest for a bill of particulars. Bunn • Unite
+States, 260 F.2d 313, 314 (8th Cir.1958).
+In this case, the indictment substantially follows the
+DECISION
+Defendant argues that the government has no proof
+Defendant's Motion to Dismiss is DENIED and
+that he was going to have sex with ndblondie2003
+Defendant's Motion for a Bill of Particulars is
+in North Dakota. The government will likely
+produce evidence at trial that ndblondie2003 told
+Defendant that she lived in North Dakota and that
+*4 IT IS SO ORDERED.
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=...
+
+
+
+/ Not Reported in F.Supp.2d
+ot Reported in F.Supp.2d, 2003 WL 22118983 (D.N.D
+Cite as: Not Reported in F.Supp.2c
+D.N.D.,2003.
+U.S. [ Patten
+Not Reported in F.Supp.2d, 2003 WL 22118983
+(D.N.D.)
+Page 4
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prfi=HTMLE&fn=_top&mt=..
+
+
+
+504 F.3d 737, 07 Cal. Daily Op. Serv. 11,330, 2007 Daily Journal D.A.R. 14,672
+H
+U.S. _. Sinerius
+C.A.9 (Mont.),2007.
+United States Court of Appeals,Ninth Circuit.
+UNITED STATES of America, Plaintiff-Appellee,
+V.
+Arthur Emil SINERIUS, Jr., Defendant-Appellant.
+No. 06-30327.
+Argued and Submitted March 9, 2007.
+Filed Sept. 20, 2007.
+Background: Defendant was convicted in the
+United States District Court for the District of'
+Montana, Charles C. Lovell, J., of receipt of child
+pornography and possession of child pornography,
+and he appealed his 180-month sentence.
+Holding: The Court of Appeals, O'Scannlain,
+Circuit Judge, held that defendant's prior conviction
+under Montana law for sexual assault constituted a
+conviction relating to sexual abuse, for purposes of
+increase of defendant's statutory mandatory minimum sentences.
+knowingly subjecting another person to sexual con-
+Affirmed.
+West Headnotes
+[1] Obscenity 281 €-18.1
+281 Obscenity
+281k18 Trial
+281k18.1 k. In General. Most Cited Cases
+Under categorical approach for determining the
+character of a prior conviction, defendant's prior
+conviction under Montana law for sexual assault
+constituted a conviction relating to sexual abuse,
+for purposes of increase of defendant's statutory
+mandatory minimum sentences to 15 years for receipt of child pornography and ten years for possession of child pornography; all conduct criminalized
+by Montana statute of conviction, which prohibited
+16-year-old offender and 13-year-old victim, categorically qualified as sexual abuse. 18 U.S.C.A. §
+2252A(b); MCA 45-5-502.
+[2] Obscenity 281 €-18.1
+281 Obscenity
+281k18 Trial
+281k18.1 k. In General. Most Cited Cases
+For purposes of determination of whether defendant's prior conviction under Montana law for sexual
+assault constituted a conviction relating to sexual
+abuse, for purposes of an increase of the defendant's statutory mandatory minimum sentences to 15
+years for receipt of child pornography and ten years
+for possession of child pornography, court of appeals was not required to define term "sexual abuse" by cross-reference to federal offense of sexual
+abuse, rather than by the ordinary, contemporary,
+and common meaning of the term. 18 U.S.C.A. §5
+2242, 2252A(b); MCA 45-5-502.
+*738 Michael Donahoe, Senior Litigator, Federal
+Defenders of Montana, argued the cause for the defendant-appellant, and filed briefs; Anthony R.
+Gallagher, Federal Defender, was on the briefs.
+Marcia Hurd, Assistant U.S. Attorney, Billings,
+MT, argued the cause for the plaintiff-appellee and
+filed a brief; William W. Mercer, U.S. Attorney,
+District of Montana, and Eric B. Wolf, Assistant
+U.S. Attorney, Billings, MT, were on the brief.
+Appeal from the United States District Court for the
+District of Montana; Charles C. Lovell, District
+Judge, Presiding. D.C. No. CR-05-00024-CCL
+Before: B.
+FLETCHER,
+DIARMUID F.
+O'SCANNLAIN, and A. WALLACE TASHIMA,
+Circuit Judges.
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov... 2/27/2008
+
+
+
+504 F.3d 737, 07 Cal. Daily Op. Serv. 11,330, 2007 Daily Journal D.A.R. 14,672
+O'SCANNLAIN, Circuit Judge:
+We are called upon to determine whether a federal defendant's prior conviction for "sexual assault" under Montana state law triggers an enhanced penalty under the sentencing provisions applicable to his federal crimes.
+In 2005, Arthur Emil Sinerius, Jr. was indicted
+by a federal grand jury for receipt of child pomography ("Count I") and possession of child pornography ("Count II"), in violation of 18 U.S.C. §§
+2252A(a)(2) and 2252A(a)(5)(B) respectively. Sinerius subsequently pled guilty to both counts, and
+also agreed to forfeiture of his computer pursuant to
+18 U.S.C. § 2253. The government agreed, pending
+the determinations of the presentence investigation
+report ("PSR"), to recommend a sentence at the low
+end of the advisory guideline range.
+The PSR determined that Sinerius's base offense level was 22 and then added two levels because the material involved a prepubescent minor
+or a minor under the age of 12, U.S.S.G. §
+2G2.2(b)(2); four levels because the offense involved material that portrays sadistic or masochistic
+conduct*739 or other depictions
+of violence,
+U.S.S.G. § 2G2.2(b)(4); two levels because the offense involved the use of a computer, U.S.S.G. §
+2G2.2(b)(б); and four levels because the offense involved between 300 and 600 images,
+U.S.S.G. S
+2G2.2(b)(7)(C). The PSR then subtracted two levels
+because Sinerius's conduct was limited to the receipt of child pornography and he did not traffic in
+such material, U.S.S.G. § 2G2.2(b)(1); and three
+levels for acceptance of responsibility, U.S.S.G. §
+3E1.1. Accordingly, based on Sinerius's total offense level of 29 and Criminal History Category of
+II, the PSR calculated an advisory Guidelines range
+of 97 to 121 months. However, the PSR also determined that Sinerius's' prior conviction for sexual
+assault, in violation of Mont.Code Ann. § 45-5-502
+(the "Montana sexual assault statute"), was a predicate offense "relating to aggravated sexual abuse,
+sexual abuse, or abusive sexual conduct involving a
+minor or ward," as defined by § 2252A(b). 18
+U.S.C. §§ 2252A(b)(1),(2). The PSR thus concluded that § 2252A(b) required enhanced mandatory minimum sentences of 15 years for Count I and
+10 years for Count II. 'NI
+FN1. Section 2252A(b)(1) sets forth the
+mandatory minimum sentence for Count
+(receipt of child pornography under
+2252A(a)(2)(B)), among other offenses.
+Section 2252(A)(b)(2) sets forth the mandatory minimum sentence for Count I|
+(possession of child pornography under §
+2252A(a)(5)(B)). Both provisions require
+an enhanced sentence when the defendant
+has been convicted of a state offense
+*relating to aggravated sexual abuse, sexual abuse, or abusive conduct involving a
+minor or ward." §§ 2252A(b)(1),(2). Be-
+the relevant text of both
+2252A(b)(1) and 2252A(b)(2) is identical,
+we treat the two provisions together for
+purposes of the issue raised by this appeal.
+At his change of plea hearing, Sinerius admitted to his prior conviction and indicated that he
+agreed with the government's summary of the facts,
+including that "Sinerius is a registered sexual offender, having been convicted in Montana
+state
+court in 1994 of sexually abusing a minor female
+child." FN2 Sinerius objected to the PSR, however,
+arguing that his prior Montana conviction did not
+categorically qualify as a predicate offense for enhancement purposes.
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov. 2/27/2008
+
+
+
+504 F.3d 737, 07 Cal. Daily Op. Serv. 11,330, 2007 Daily Journal D.A.R. 14,672
+due to her age." Subsequently, however,
+the Montana trial judge granted the state's
+motion in open court to amend the charge
+against Sinerius from "sexual intercourse
+without consent (felony)" to "sexual assault (felony)," in violation of Mont.Code
+Ann. § 45-5-502. The amendment was
+made by a handwritten interlineation on
+the information, striking out the former
+charge and replacing it with the latter. At
+Sinerius's federal sentencing hearing, the
+federal prosector,
+who, coincidentally,
+had also served as the state district attorney in the Montana court proceedings,
+stated that this amendment only changed
+the charged offense, not the underlying
+facts. No transcript of the state trial proceedings is available.
+After Sinerius pled guilty to "sexual assault
+(felony)," the Montana trial judge sentenced him to
+ten years imprisonment, all but 30 days suspended,
+placed him on probation for ten years, and ordered
+him to pay a fine, register as a sex offender, and undergo treatment.
+At the sentencing hearing, the district court
+ruled that Sinerius's Montana conviction was a predicate offense that required the enhanced mandatory minimum sentences provided by § 2252A(b)
+because it was an offense "relating to ... sexual abuse, or abusive sexual conduct involving a minor or
+ward." Reling
+on the prior conviction, the court
+sentenced Sinerius to *740 imprisonment of 180
+months for receipt of child pornography (under §
+2252A(b)(I)), and 120 months for possession of
+child pornography (under § 2252A(b)(2)), to run
+concurrently. The court also sentenced Sinerius to
+supervised release for a term of life, and ordered
+him to participate in treatment and to pay an assess-
+Sinerius appeals the sentence.
+II
+11 To determine whether Sinerius's convictio
+nder the Montana sexual assault statute meets th
+definition of a predicate sex offense under §
+252A(b), we rely on the familiar two-step test se
+orth in Taylor || United States, 495 U.S. 575, 11
+States 143, 105 L. Fd.2d 607 (1990). See United
+| Baron-Medina, 187 F.3d 1144, 1147 (9th
+Cir.1999) (employing Taylor's categorical approach
+(recognizing the parties' agreement that Taylor's
+categorical approach applies to a sentence enhancement under § 2252A(b)).
+First, we examine the definition of the predicate offense in the federal statute. See United States
+| Lopez-Solis, 447 F.3d 1201, 1206 (9th Cir.2006).
+Section 2252A(b) imposes an enhanced sentence on
+a defendant "if such person has a prior conviction
+... under the laws of any State relating to aggravated sexual abuse, sexual abuse, or abusive sexual
+conduct involving a minor or ward." 18 U.S.C. §
+2252A(b)(1),(2) (emphasis added). Thus, the relevant offenses under § 2252A(b) are those "relating to
+... aggravated sexual abuse, sexual abuse, or abusive sexual conduct involving a minor or ward." See
+Lopez-Solis, 447 F.3d at 1206.
+Next, we look to the Montana sexual assault
+statute and compare its elements to the definition of
+the terms "aggravated sexual abuse," "sexual abuse,"
+and "abusive sexual conduct involving a
+minor" under § 2252A(b). Lopez-Solis, 447 F.3d at
+1206. Under this categorical approach, Sinerius's
+Montana conviction will qualify as a predicate sex
+offense only if the full range of conduct covered by
+the Montana statute falls within the meaning of
+those terms. Id.
+A
+Section 2252A(b) requires an enhanced sentence if Sinerius's Montana conviction is as an offense "relating to" either "aggravated sexual ab-
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prf=HTMLE&mt=FederalGov. 2/27/2008
+
+
+
+504 F.3d 737, 07 Cal. Daily Op. Serv. 11,330, 2007 Daily Journal D.A.R. 14,672
+use," "sexual abuse," or "abusive sexual conduct
+involving a minor." We first consider whether Sinerius's conviction is an offense "relating to ... sexual abuse."
+Under the categorical approach, we follow our
+common practice in cases involving non-traditional
+offenses by defining the offense based on the
+"ordinary, contemporary, and common meaning of
+the statutory words." See Lopez-Solis, 447 F.3d at
+1206-07 (citation omitted) (defining "sexual abuse
+of a minor" for purposes of the predicate offense
+under U.S.S.G. § 2L1.2).
+We define the term "sexual abuse" by coupling
+the dictionary definition of "abuse" with the common understanding of "sexual." See id. at 1207;
+Baron-Medina, 187 F.3d at 1146. First, in the context of the Sentencing Guidelines, we have defined
+"abuse" to mean
+"misuse ... to use or treat so as to
+injure, hurt, or damage ... to commit
+decent assault on." Id. at 1207; United States| Pallares-
+Galan,
+359 F.3d 1088,
+1100
+(9th Cir.2004)
+(quoting Webster's Third New Int'l Dictionary 8 (3d
+ed.1981)). We have explained that this definition
+"encompass[es] behavior that is harmful emotionally and physically." Lopez-Solis, 447 F.3d at 1207.
+Second, we *741 have given the term "sexual" its
+ordinary
+commonsense
+meaning.
+See id.
+Equipped with this understanding of § 2252A(b)'s
+definition of a predicate offense, we next consider
+the Montana statute under which Sinerius was con-
+Page 4
+The Montana statute undeniably proscribes acts
+that are "sexual" in nature. Mont.Code Ann. §
+45-5-502. The statute prohibits knowingly subjecting "another person to any sexual contact without
+consent." Id. § 45-5-502(1). The relevant definitional provision describes "sexual contact" as "any
+touching of the sexual or other intimate parts of the
+person of another for the purpose of arousing or
+gratifying the sexual desire of either party." Id. §
+45-2-101(60). In addition, the range of conduct the
+Montana statute proscribes is "abusive" because it
+necessarily involves physical "contact without consent." Id. § 45-5-502(1) (emphasis added). The
+physical touching of another person's sexual or intimate parts, for the purposes of sexual arousal or
+gratification and without consent, amounts to an
+"indecent assault on" that person. Lopez-Solis, 447
+F.3d at 1207.
+Nevertheless,
+Sinerius maintains
+that the
+Montana statute is over-inclusive vis-a-vis the offenses described in § 2252A(b) and, as a consequence, that his conviction therefore cannot categorically qualify as a predicate offense.
+Under the categorical approach, even the least
+egregious conduct proscribed by the Montana statabe soi s e ity as 1206075 atelatin lo cosexial
+439 F.3d 1046, 1052 & n. 3 (9th Cir.2006). If such
+conduct does not qualify, the Montana statute is
+over-inclusive on its face.
+The Montana statute provides that a victim les
+han 14 years old cannot consent to sexual contac
+if the offender's age exceeds his or her own by three
+or more years. Mont.Code Ann. § 45-5-502(5).
+Under the categorical approach, we look only
+to the fact of Sinerius's prior conviction and the elenents of the Montana offense to determine whethe
+i 2252A(b)'s definition of "sexual abuse" cover
+Montana sexual assault statute. Id. at 1206.
+1
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov... 2/27/2008
+
+
+
+504 F.3d 737, 07 Cal. Daily Op. Serv. 11,330, 2007 Daily Journal D.A.R. 14,672
+tent, even when it is "innocently and warmly received ... indisputably falls within the common,
+everyday meaning of the words "sexual' and
+'minor' " and that such "use of young children for
+the gratification of sexual desires constitutes an abuse." 187 F.3d at 1147 (emphasis added); see also
+gratification is corrupt, improper, and contrary to
+good order. It constitutes maltreatment, no matter
+its form."(citations omitted) (internal quotation
+marks omitted)).
+As a consequence, even the least egregious
+conduct proscribed by the Montana statute, consensual sexual contact by a 16-year-old on a
+13-year-old victim, categorically qualifies as
+"sexual abuse." Further,
+because the statute reconsistent with ou
+decisions in Lopez-Solis*742
+and United States| Baza-Martinez, 464 F.3d 1010
+(9th Cir.2006), holding that more expansive state
+statutes were not predicate offenses
+within the
+definition of the term "sexual abuse of a minor."
+In Lopez-Solis, we held that a conviction under
+a state statutory rape statute did not qualify as
+"sexual abuse of a minor" because the statute prohibited "consensual penetration of a victim just under 18 years of age by a 22-year-old perpetrator."
+447 F.3d at 1207. We concluded that this conduct
+did not categorically include the necessary physical
+or psychological
+required by the
+"abuse," indicating that "prior case law-as well as
+common sense-suggest that, while consensual underage sex may be harmful to a young teen, it may
+not be harmful.
+to an older one." Id. at 1208 (citing
+United States | Melton, 344 F.3d 1021, 1028-29
+(9th Cir.2003)) (suggesting that only in the presence of certain aggravating factors, such as incest.
+will a sexual encounter between a 17 year old and
+an adult necessarily create a "situation of
+1 ear oi and)
+[psychological] dominance and control"). Similurly, in Baza-Martinez, we concluded that a state
+statute prohibiting "indecent liberties with a child'
+Page 5
+did not qualify as "sexual abuse of a minor," because it prohibited a very broad range of conduct,
+including "mere words." 464 F.3d at 1016-17 ("AIl
+that is required is that at the time of the immoral,
+improper, or indecent liberty, the defendant must be
+in either the actual or constructive presence of the
+child."(internal quotation marks and citations omitted)).
+In contrast to the statutes at issue in Lopez-Solis and Baza-Martinez, the Montana sexual assault
+statute proscribes a narrower range of conduct, all
+of which necessarily involves "sexual abuse" under
+its ordinary and common meaning.
+2
+[2] Sinerius argues, however, that § 2252A(b)
+requires us to define the term "sexual abuse" by
+cross-reference to the federal offense of "sexual abuse" under 18 U.S.C. § 2242 rather than by the orand common meaning of that phrase.!
+Section 2242 proscribes a narrower range of conduct than the Montana sexual assault statute. Specifically, Sinerius argues that "sexual abuse" under
+§ 2242 requires skin-to-skin contact, whereas
+"sexual assault" under the Montana statute only requires "offensive touching of a intimate body part,"
+which could include touching through clothing.
+Mont.Code Ann. § 45-2-101. Consequently, Sinerius contends that his conviction under the Montana
+statute cannot qualify, categorically, as a predicate
+offense "relating to ... sexual abuse" under §
+2252A(b). We disagree.
+FN3. Sinerius offers an identical argument
+Creie to the ederal ore coor saee
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prfl=HTMLE&mt=FederalGov... 2/27/2008
+
+
+
+504 F.3d 737, 07 Cal. Daily Op. Serv. 11,330, 2007 Daily Journal D.A.R. 14,672
+§ 2243 and "abusive sexual contact" under
+18 U.S.C. § 2244. We decline to interpret
+these terms by cross-reference to the cited
+federal crimes for the same reasons we decline to interpret the term "sexual abuse"
+in such manner.
+We have never defined predicate sex offenses
+under § 2252A by cross reference to the federal
+rovisions Sinerius cites, nor has any other court o
+ppeals. See United States | Hubbard, 480 F.3(
+341, 348 (5th Cir.2007) (construing "aggravated
+sexual abuse, sexual abuse, [and] abusive sexual
+conduct involving a minor" under § 2252A(b)(1) as
+"generic offenses"); Rezin, 322 F.3d at 447-48
+(reaching the same conclusion in construing materially indistinguishable language in § 2252). Our
+declining to do so derive from *743
+well-established principles of statutory interpretation. First, the federal crime of "sexual abuse" under § 2242 is not a definitional provision applicable
+to § 2252A. Section 2252A is codified in title 18,
+chapter 110. The definitions applicable to chapter
+110 are located in 18 U.S.C. § 2256. Section 2242,
+on the other hand, is located in chapter 109A.
+While Congress did not provide a specific
+definition of "sexual abuse" in § 2256, we believe
+its decision not to do so reflects Congress's intent to
+define "sexual abuse" as a generic offense, understood by its ordinary and common meaning, see
+Lopez-Solis, 447 F.3d at 1206-07, rather than to import the elements of offenses delineated elsewhere
+in the U.S.Code. See Hubbard, 480 F.3d at 348.
+Our conclusion is strengthened by the plain
+language of § 2252A. That section specifically accounts for the federal crime of "sexual abuse" under § 2242 in a separate category of predicate offenses. Section 2252A(b) requires an enhanced sentence if the defendant "has a prior conviction under
+... chapter 109A ...or under the laws of any State relating to aggravated sexual abuse, sexual abuse, or
+abusive sexual conduct involving a minor or ward."
+18 U.S.C. § 2252A(b)(1),(2) (emphasis added).
+Thus, § 2252A(b) treats federal offenses located in
+Page 6
+chapter 109A (which includes sexual abuse under §
+2242) as a separate category of predicate offenses,
+independent from its treatment of state law convictions like the one at issue here.
+Further, § 2252A employs broader language
+when defining state convictions that qualify as a
+predicate sex offenses than it does when defining
+predicate federal offenses, such as those located in
+chapter 109A. An individual must be convicted of
+the specific federal offense listed to be subject to an
+enhanced sentence. However, such individual need
+only be convicted of a state offense "relating to...
+sexual abuse" to have the same penalty imposed. 18
+U.S.C. § 2252A(b)(1),(2) (emphasis added). The
+phrase "relating to," as defined by the Supreme
+Court, means "to stand in some relation to; to have
+earing or concern; to pertain; refer; to bring int
+ssociation with or connection with." Morales
+Trans World Airlines, 504 U.S. 374, 383, 112 S.Ct.
+2031, 119 L.Ed.2d 157 (1992) (quoting Black's
+Law Dictionary 1128 (5th ed.1979)) (construing
+"relating to" in a different statutory context). We
+lave construed "relating to" language broadly i
+he past, see Luu-Le | INS, 224 F.3d 911, 915-1
+(interpreting the phrase "relating to a controlled
+substance" in section 241(a)(2)(B)(i) of the Immigration and Nationality Act), and the Fifth, Eighth,
+and Tenth Circuits have done the same when interpreting this provision and the materially indistinguishable text of § 2252, see Hubbard, 480 F.3d at
+347 ("We must assume that Congress chose the
+words 'relating to' [in § 2252A(b)(1) ] for a purpose."); United States | Weis, 487 F.3d 1148, 1152
+(8th Cir.2007) (construing "relating to" broadly in §
+2252); United States | McCutchen, 419 F.3d 1122,
+1127 (10th Cir.2005) (same). In short, § 2252A
+does not simply mandate a sentencing enhancemen
+for individuals convicted of state offenses equival-
+Lance set tor any star atens tal anc ih ne
+relation, bears upon, or is associated with that gen-
+3
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prfl=HTMLE&mt=FederalGov.. 2/27/2008
+
+
+
+504 F.3d 737, 07 Cal. Daily Op. Serv. 11,330, 2007 Daily Journal D.A.R. 14,672
+Finally, experience indicates that when Congress intends to require a state offense to be congruent to a coresponding federal offense for sentencing enhancement purposes,
+it will draft such a
+requirement expressly. For example,
+*74418 U.S.C.
+§ 2241(c) requires a life sentence where the defendant "has previously been convicted of another Federal offense under this subsection, or of a State offense that would have been an offense under either
+such provision had the offense occurred in a federal prison." 18 U.S.C.
+§ 2241(c) (emphasis
+added).FN4 Similarly, 18 U.S.C. § 3559(e)(2)(B)
+defines a "State sex offense" for purposes of that
+subsection to mean "an offense under State law that
+is punishable by more than one year in prison and
+consists of conduct that would be a federal sex offense." 18 U.S.C. § 3559(e)(2)(B) (emphasis added).
+FN4. The phrase "either such provision"
+refers to
+18 U.S.C.
+§5 2241(c) and
+2243(a). United States | Etimani, 328 F.3d
+493, 503 (9th Cir.2003).
+Sinerius cites
+224(c) and
+3559(e)(2)(B) as evidence that his Montana conviction is not a predicate offense "relating to ... sexual
+abuse* under § 22-2A(b), relying on our decision
+Page 7
+quirement in § 2252A(b) manifested its intent that
+no such requirement exist. See Hubbard, 480 F.3d
+at 348 (concluding that the terms "aggravated sexual abuse," "sexual abuse," and "abusive conduct involving a minor" in § 2252A(b)(1) are "generic
+terms, describing generic offenses" without reference to federal offenses defined elsewhere in the
+Accordingly, we interpret § 2252A(b) in light
+of its plain text and reject Sinerius's argument that a
+state conviction "relating to ... sexual abuse" must
+meet the federal definition of sexual abuse under §
+2242 in order to qualify as a predicate offense for
+purposes of § 2252A. We therefore conclude that
+Sinerius's conviction under the Montana sexual assault statute categorically qualifies as a predicate
+offense triggering the sentencing enhancement under § 2252A(b).
+C
+Since we conclude that Sinerius's prior
+Montana conviction categorically qualifies
+as
+"sexual abuse" for purposes of § 2252A(b), we
+need not consider whether the conviction would
+also qualify as "aggravated sexual abuse"
+or
+"'abusive sexual conduct involving a minor" under
+the same provision, nor is it necessary that we examine Sinerius's conviction under the "modified"
+categorical approach.
+ences in the statutory language, however, Sinerius's
+reliance on Etimani is misplaced. In Etimani, we refused to qualify categorically a conviction under a
+state statute prohibiting
+"sexual contact" as a predicate offense under § 2241(c). The state statute
+defined *sexual contact" to include touching
+through
+clothing,
+while § 2241(c)
+required
+"skin-to-skin contact." Etimani, 328 F.3d at 503.
+But as discussed previously, § 2241(c) expressly requires that a state predicate offense include all the elements of a coresponding federal
+crime; § 2252A(b) imposes no such limitation. For
+that reason, Etimani not only fails to support Sinerius's interpretation, it provides reliable evidence that
+Congress's failure to include an equivalency re-
+III
+For the foregoing reasons, we agree with the
+Costicio und the Montana soar l asaul spaio
+qualifies as a predicate offense under §
+2252A(b)(1) & (2). Therefore, we conclude that the
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft-HTMLE&mt=FederalGov.. 2/27/2008
+
+
+
+504 F.3d 737, 07 Cal. Daily Op. Serv. 11,330, 2007 Daily Journal D.A.R. 14,672
+AFFIRMED.
+C.A.9 (Mont.),2007.
+SOS F:.3d 737, 07 Cal. Daily Op. Serv. 11,330, 2007
+Daily Journal D.A.R. 14,672
+Page 8
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov.. 2/27/2008
+
+
+
+H
+U.S. |. Johnson
+C.A.7 (Ind.),2007.
+UNiTED STA Co o Apical Saint Opelie,)
+V.
+Charles M. JOHNSON, Jr., Defendant-Appellant.
+No. 06-3968.
+Argued April 10, 2007.
+Decided July 30, 2007
+Background: Defendant was convicted, upon a
+conditional guilty plea, following denial of his motion to suppress, in the United States District Court
+for the Southern District of Indiana, John Daniel
+Tinder, J., of production of child pornography. De-
+fendant appealed.
+Holdings: The Court of Appeals, Ripple, Circuit Judge, held that:
+1) defendant voluntarily consented to search
+f his computer and living area
+to search de fendanen en aputs and prona actuse
+(3) imposition of did not violate defendant's
+Fifth or Sixth Amendment rights.
+Affirmed.
+ing on a motion to suppress de novo.
+[2] Criminal Law 110 €-1158(2)
+110 Criminal Law
+110XXIV Review
+110XXIV(O) Questions of Fact and Findings
+110k1158 In General
+110k1158(2) k.
+Findings on Preliminary Proceedings in Conduct o
+Trial in General. Most Cited Cases
+cause the voluntariness of a defendant's conse
+search is a factual determination, the Court
+Appeals reviews a district court's resolution of this
+question for clear error.
+[3] Searches and Seizures 349 €-171
+349 Searches and Seizures
+349V Waiver and Consent
+349k171 k. In General. Most Cited Cases
+The Fourth Amendment's prohibition against warrantless searches does not apply when the defendant
+consents voluntarily to the search. U.S.C.A.
+Const.Amend. 4.
+[4] Searches and Seizures 349 €-194
+349 Searches and Seizures
+349VI Judicial Review or Determination
+349k192 Presumptions and Burden of Proof
+349k194 k. Consent, and Validity Thereof. Most Cited Cases
+The government bears the burden of proving that
+consent to search was given freely and voluntarily.
+U.S.C.A. Const.Amend. 4.
+[5] Searches and Seizures 349 €-201
+West Headnotes
+[1] Criminal Law 110 €-1139
+110 Criminal Law
+110XXIV Review
+110XXIV(L) Scope of Review in General
+110k1139 k. Additional Proofs and Trial
+De Novo. Most Cited Cases
+The Court of Appeals reviews a district court's rul-
+Cited Cases
+search is a dacual asesnen ly conums d o e
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prfi=HTMLE&mt=FederalGov... 2/27/2008
+
+
+
+totality
+of
+Const.Amend. 4.
+the
+circumstances.
+U.S.C.A.
+16| Searches and Seizures 349 €-180
+349 Searches and Seizures
+349V Waiver and Consent
+349k179 Validity of Consent
+349k180 k. Voluntary Nature in General.
+Most Cited Cases
+Searches and Seizures 349 €-183
+349 Searches and Seizures
+349V Waiver and Consent
+349k179 Validity of Consent
+349k183 k. Knowledge of Rights; Warnings and Advice. Most Cited Cases
+Searches and Seizures 349 €-184
+349 Searches and Seizures
+349V Waiver and Consent
+349k179 Validity of Consent
+349k184 k. Custody, Restraint, or Detention Issues. Most Cited Cases
+Among the factors a court considers in determining
+whether consent to search was voluntarily given
+are: (1) the person's age, intelligence, and education, (2) whether he was advised of his constitutional rights, (3) how long he was detained before he
+gave his consent, (4) whether his consent was immediate, or was prompted by repeated requests by
+the authorities, (5) whether any physical coercion
+was used, and (6) whether the individual was in police custody when he gave his consent. U.S.C.A.
+Const.Amend. 4.
+17) Searches and Seizures 349 €-181
+349 Searches and Seizures
+349V Waiver and Consent
+349k179 Validity of Consent
+349k181 k. Particular Concrete Applications. Most Cited Cases
+Searches and Seizures 349 €-183
+349 Searches and Seizures
+349V Waiver and Consent
+349k179 Validity of Consent
+349k183 k. Knowledge of Rights; Warnings and Advice. Most Cited Cases
+Defendant voluntarily consented to a search of his
+computer and living area; although law enforcement agents requested more than once that defendant consent to search, and agents told him that they
+would need to secure the residence until a search
+warrant issued if he did not consent, defendant
+stated that he did not feel threatened or coerced and
+that he understood the consent form he signed, defendant was 48 years old, he was of at least average
+intelligence, and the interview with agents was
+calm and professional at all times. U.S.C.A.
+Const.Amend. 4.
+[8] Criminal Law 110 €-394.1(3)
+110 Criminal Law
+110XVII Evidence
+110XVII(1) Competency in General
+110k394 Evidence Wrongfully Obtained
+110k394.1 In General
+110k394.1(3) k. Effect of Illegal
+Conduct on Other Evidence. Most Cited Cases
+The doctrine of inevitable discovery provides that,
+when the government can establish by a preponderance of the evidence that the information obtained
+would have been discovered ultimately or inevitably by lawful means, the deterrence rationale of
+the exclusionary rule no longer applies and the
+evidence
+should
+be
+admitted. U.S.C.A.
+Const.Amend. 4.
+19] Obscenity 281 € 7.6
+281 Obscenity
+281k7.5 Pretrial Seizure, Suppression, or Cen-
+281k7.6 k. In General; Necessity for Ad-
+ersary Hearing. Most Cited Case
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov.. 2/27/2008
+
+
+
+minor victim that defendant had taken pornographic
+photographs of her, that defendant used a silver digital camera, and that he possessed a black computer, and during the course of his conversation
+with agents, defendant confirmed that he owned a
+silver digital camera and black computer, and that
+U.S.C.A. Const.Amend. 4.
+ive agents, camed in the same citer, a ni tha
+[10] Jury 230 €-34(7)
+230 Jury
+230I1 Right to Trial by Jury
+230k30 Denial or Infringement of Right
+230k34 Restriction or Invasion of Functions of Jury
+230k34(5) Sentencing Matters
+230k34(7) k. Particular Cases in
+General. Most Cited Cases
+Imposition of mandatory minimum life sentence for
+defendant convicted of production of child pornography, based on determination of the fact of a pri-
+US CA Co And 1, 0. 1
+U.S.C.A. §§ 2251(e), 3559(e).
+[11] Indictment and Information 210 €-113
+210 Indictment and Information
+210V Requisites and Sufficiency of Accusation
+210k113 k. Matter of Aggravation in General. Most Cited Cases
+Jury 230 €-34(6)
+230 Jury
+2301l Right to Trial by Jury
+230k30 Denial or Infringement of Right
+230k34 Restriction or Invasion of Functions of Jury
+230k34(5) Sentencing Matters
+230k34(6) k. In General. Most
+Cited Cases
+Sentencing and Punishment 350H €-322
+350H Sentencing and Punishment
+350HII Sentencing Proceedings in General
+350HII(F) Evidence
+350Hk322 k. Degree of Proof. Most Cited
+Cases
+For sentencing purposes, the fact of a prior conviction need not be found by a jury beyond a reasonable doubt, nor must it be alleged in the indictment.
+U.S.C.A. Const.Amends. 5, 6.
+37 Gayle Helart (argued), Office of the Unit
+ates Attorney, Indianapolis, IN, for Plaintiff-A
+pellee.
+William H. Dazey, Jr. (argued), Indiana Federal
+Community Defenders, Inc., Indianapolis, IN, for
+Defendant-Appellant.
+Before BAUER, POSNER and RIPPLE, Circuit
+Judges.
+*538 RIPPLE, Circuit Judge.
+Charles Johnson was charged in a two-count
+indictment with production of child pornography in
+violation of 18 U.S.C. § 2251(a) FNI and (e).FN2
+Mr. Johnson filed a motion to suppress certain evidence on the ground that his consent to the search
+was involuntary. He also claimed that his waiver of
+his Miranda rights was involuntary. The district
+court conducted an evidentiary hearing and denied
+Mr. Johnson's motion to suppress. Mr. Johnson
+pleaded guilty but preserved his right to appeal the
+denial of his motion to suppress. The district court
+accepted his plea. After a sentencing hearing, Mr.
+Johnson was sentenced to concurrent terms of life
+imprisonment. He timely filed this appeal. For the
+reasons set forth in the following opinion, we affirm the judgment of the district court.
+FN1. 18 U.S.C. § 2251(a) provides:
+(a) Any person who employs, uses, persuades,
+induces, entices, or coerces any minor to engage in,
+or who has a minor assist any other person to engage in, or who transports any minor in interstate or
+foreign commerce, or in any Territory or Posses
+ion of the United States, with the intent that suc
+minor engage in, any sexually explicit conduct for
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov... 2/27/2008
+
+
+
+the purpose of producing any visual depiction of
+such conduct, shall be punished as provided under
+subsection (e), if such person knows or has reason
+to know that such visual depiction will be transported in interstate or foreign commerce or mailed, if
+that visual depiction was produced using materials
+that have been mailed, shipped, or transported in interstate or foreign commerce by any means, including by computer, or if such visual depiction has actually been transported in interstate or foreign commerce or mailed.
+FN2. 18 U.S.C. § 2251(e) provides:
+(e) Any individual who violates, or attempts or
+conspires to violate, this section shall be fined under this title and imprisoned not less than 15 years
+nor more than 30 years, but if such person has one
+prior conviction under this chapter, section 1591,
+chapter 71, chapter 109A, or chapter 117, or under
+section 920 of title 10 (article 120 of the Uniform
+Code of Military Justice), or under the laws of any
+State relating to aggravated sexual abuse,
+sexual
+abuse, abusive sexual contact involving a minor or
+ward, or sex trafficking of children, or the production, possession, receipt, mailing, sale, distribution,
+shipment, or transportation of child pornography,
+such person shall be fined under this title and imprisoned for not less than 25 years nor more than 50
+years, but if such person has 2 or more prior convictions under this chapter, chapter 71, chapter
+109A, or chapter 117, or under section 920 of title
+10 (article 120 of the Uniform Code of Military
+Justice), or under the laws of any State relating to
+the sexual exploitation of children,
+such person
+shall be fined under this title and imprisoned not
+less than 35 years nor more than life. Any organization that violates, or attempts or conspires to violate, this section shall be fined under this title. Whoever, in the course of an offense under this section,
+engages in conduct that results in the death of a per
+not lesatan s0 years or for leath or imprisoned for
+Page 4
+BACKGROUNDR
+A.
+Law enforcement officials interviewed Jane
+Doe. She stated that a man she called "Charlie'" had
+been a live-in babysitter for her neighbors family.
+She stated that "Charlie" had taken nude photos of
+her since she was six or seven years old and *539
+that he had molested her and two of the children
+living with him at the time. She also stated that the
+photos had been taken with a silver digital camera
+and that she had seen him transfer the photos to a
+black Dell-brand computer.
+"Charlie" was identified as Mr. Johnson, and a
+warrant for his arrest issued on December 15, 2005.
+Law enforcement officials executed this arrest warrant the following day at a home in Cincinnati,
+Ohio. Mr. Johnson resided there as a live-in
+babysitter for the same family with whom he had
+lived in Indianapolis.
+The law enforcement officials who went to arrest Mr. Johnson included Agent Tim Rothrock and
+Sergeant Chris Hunt. The officers knocked on the
+door of the home, and the owner allowed them inside. The officers proceeded to the basement where
+the owner told them Mr. Johnson could be found.
+Sgt. Hunt had left his firearm in the car, and, although Agent Rothrock had his firearm in his hand,
+he carried it behind his back. The agents identified
+themselves to Mr. Johnson, who was in the basement with a toddler. The toddler was removed from
+the room. Agent Rothrock then put away his firearm and did not take it out again during the inter-
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov.. 2/27/2008
+
+
+
+view with Mr. Johnson F3 The law enforcement
+officers told Mr. Johnson his name had come up
+during an investigation and read him his Miranda
+rights. Mr. Johnson and the officers each signed a
+form indicating Mr. Johnson's waiver of his Miranda rights.
+FN3. Mr. Johnson later testified that he
+never saw the firearm.
+The two officers then proceeded to a small bedroom where they interviewed Mr. Johnson. The
+tone was conversational and, although there were
+other officers in the home, only Sgt. Hunt and
+Agent Rothrock remained in the room with Mr.
+Johnson. Mr. Johnson stated that he had lived with
+the children who had been depicted in the photographs and that he had a computer in his bedroom
+area. Agent Rothrock asked if Mr. Johnson would
+consent to a search of his bedroom area and his
+computer, and Mr. Johnson calmly replied that he
+would not. Agent Rothrock then asked Mr. Johnson
+if he would continue talking; Mr. Johnson replied
+that he would. Mr. Johnson then confirmed that he
+owned a black Dell computer and that he likewise
+owned a silver digital camera. At this point in the
+conversation, Agent Rothrock gave Mr. Johnson
+more information about the investigation including
+the fact that a victim had stated that he had taken
+photos of her and that he had used a specific digital
+camera and computer. Further, Agent Rothrock told
+Mr. Johnson that some of these photos had been
+found on the internet. He then told Mr. Johnson that
+he believed he had probable cause to obtain a
+search warrant which would allow him to search
+Mr. Johnson's computer and living area. He explained that the statement about the warrant was not
+meant as a threat and that a magistrate judge, and
+not he, would make the decision as to whether to issue a warrant. Agent Rothrock then told Mr. Johnson he would have to secure the residence until the
+lagistrate judge could be contacted, which woul
+volve limiting the residents' ability to enter and
+exit the house.
+The officers then left and Agent Rothrock con-
+Page 5
+tacted
+an Assistant United States Attorney
+("AUSA") in Indianapolis. He described the house
+and the property inside the house, including the
+computer and the camera, in which Mr. Johnson retained a privacy interest. He also discussed the
+factors that supported probable cause, at which
+point the AUSA agreed to start the process of obtaining a search warrant. Agent Rothrock then returned to the home, told Mr. Johnson that the process of *540 obtaining a warrant had been started
+and that the AUSA believed that probable cause existed. Agent Rothrock again asked Mr. Johnson if
+he would consent to a search. Sgt. Hunt recalled
+Agent Rothrock stating that Mr. Johnson's consent
+"could possibly save time for us." R.53 at 105-06.
+Mr. Johnson was read forms acknowledging his
+consent to the search of his computer and his living
+area, and he was reread his Miranda warnings. Mr.
+Johnson signed both forms. Mr. Johnson stated that
+the police might find child pornography on the
+computer. The officers continued to question Mr.
+Johnson about the child pornography on his computer. Mr. Johnson then acknowledged that he had
+taken the photos. He declined to answer any questions as to the identity of the children in the photos
+and was then asked if he wished to speak to an attorney regarding that particular question; he replied
+that he would.
+Mr. Johnson identified Jane Doe in one photograph in which she was fully clothed and stated that
+the photo had been taken in his Indianapolis bedroom. He declined to answer questions about
+whether he had any knowledge as to how the photo
+had become available on the internet and stated that
+he wished to speak to an attorney as to that question
+preston bearing . or din es coed halt a spid
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov... 2/27/2008
+
+
+
+not seen Agent Rothrock's weapon when he came
+down the stairs. He stated that the officers were not
+harsh or mean to him. He also said that he understood that he was suspected of a crime and that he
+had signed the Miranda waiver. He agreed that he
+never felt threatened or coerced into answering
+questions. He further stated that he was concerned
+for the other residents of the home because Agent
+Rothrock had mentioned his intent to secure the
+home until the search warrant was issued. He
+claimed that his consent to the search was involuntary because he perceived that hardship would befall other members of the household if he persisted
+in declining consent. When he invoked his right to
+counsel as to certain questions, he indicated that he
+did not believe he had to answer questions on those
+topics. He stated that he had read and understood
+the consent to search forms and the Miranda waiver
+at the time he signed it.
+Mr. Johnson's computer was found to contain
+approximately 3,700 images of child pornography
+and child erotica. The nine images of Jane Doe
+found by the NCMEC were on the computer, and
+the computer allowed file sharing.
+Page 6
+not an overly long *541 period of detention, (8)
+was not barraged with requests for consent, and (9)
+was not subject to a threatening atmosphere. The
+district court also found that Mr. Johnson selectively had waived his Miranda rights, only requesting counsel as to two specific questions which was
+an ambiguous assertion of his right to counsel as to
+all questions. Finally, the district court found that,
+even if his consent were not voluntary, the evidence
+would not be suppressed because it would be admissible under the inevitable discovery doctrine.
+At sentencing, the district court computed,
+without objection, the sentencing guidelines range.
+The applicable guidelines range of 188-235 months
+was trumped by 18 U.S.C. § 3559(e), + which requires mandatory life imprisonment for repeated
+sex offenses against children. Mr. Johnson qualified
+as a repeat sex offender against minors on the basis
+convictions in 1989 for second degree rape,
+second degree sodomy and sexual abuse offenses
+for victimizing two children under the age of
+twelve. Mr. Johnson preserved Fifth, Sixth and
+Eighth Amendment objections to the invocation of
+the recidivist statutes. The district court sentenced
+Mr. Johnson to concurrent terms of life imprison-
+B.
+The district court found that Mr. Johnson's consent to search his living area and computer was voluntary. The court did not believe that Agent Ro-
+throck's statements that he would secure the home
+while a search warrant was obtained had overborne
+Mr. Johnson's free will. The district court found
+this consent to be voluntary because Mr. Johnson
+(1) was approximately 48 years old, had two years
+of college and had his associate's degree, (2) had
+emonstrated computer savvy, (3) had gained an
+sed managerial experience in his employment, (4
+had declined consent earlier in the encounter and
+stated that he did not feel threatened, (5) had consented after he was told that the process of obtaining a warrant had commenced, (6) had been read
+his Miranda warnings a second time, (7) had consented after one hour and five minutes which was
+FN4. 18 U.S.C. § 3559(e) provides:
+(e) Mandatory life imprisonment for repeated
+sex offenses against children.-
+(1) In general.-A person who is convicted of a
+Federal sex offense in which a minor is the victim
+shall be sentenced to life imprisonment if the person has a prior sex conviction in which a minor was
+the victim, unless the sentence of death is imposed.
+II
+DISCUSSION
+A.
+[1][2] Mr. Johnson submits on appeal that his
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov... 2/27/2008
+
+
+
+consent to the search of his bedroom area and computer was involuntary and, therefore, that his motion to suppress evidence should have been
+granted. FN5 We review a district court's ruling on a
+motion to suppress de novo. However, we review
+he district court's factual findings for clear error.
+/nited States Lawshea, 461 F.3d 857. 859 (7th
+Cir.2006). Because the voluntariness of a defendant's consent to search is a factual determination,
+ve review a district court's resolution of this quesion for clear error. United States | Raiblev. 243
+F.3d 1069, 1076 (7th Cir.2001).
+FN5. Mr. Johnson does not appeal the district court's denial of his motion to suppress statements to law enforcement offi
+cials. He recognizes that he
+selectively
+his Miranda rights, see United
+States Amaro, 816 F.2d 284, 286 (7th
+Cir. 1987), and
+that suppression of his
+statements would have left the Government's case largely unchanged. See Appellant's Br. at 11.
+[3][4][5][6] The Fourth Amendment's prohibition against warrantless searches does
+not apply
+when the defendant consents voluntarily to the
+search. United States
+Sandoval-Vasquez, 435
+F.3d 739,
+744 (7th Cir.2006). The Government
+bears the burden of proving that consent freely and
+voluntarily was given. Id. Whether a defendant voluntarily consented to a search is a factual assessment which turns on
+the totality of the circumstances. Schneckloth | Bustamonte, 412 U.S. 218,
+227, 93 S.Ct. 2041, 36 L.Ed.2d 854 (1973). We
+must keep in mind that "a determination of voluntariness does not ride on the presence or absence of
+a single controlling factor." United States | LaG-
+rone, 43 F.3d 332, 334 (7th Cir.1994) (internal citations and quotation marks omitted). Rather, we
+must undertake a "careful scrutiny of all the surrounding circumstances." Id. (citing *542 Schneckloth, 412 U.S. at 226, 93 S.Ct. 2041). Among the
+factors we consider are: "(1) the person's age, intelligence, and education, (2) whether he was advised
+Page 7
+of his constitutional rights, (3) how long he was detained before he gave his consent, (4) whether his
+consent was immediate, or was prompted by repeated requests by the authorities, (5) whether any
+physical coercion was used, and (6) whether the individual was in police custody when he gave his
+consent." Sandoval-Vasquez, 435 F.3d at 744.
+[7] Mr. Johnson contends that his consent was
+given involuntarily because of two occurrences in
+the course of the police requests for consent: (1)
+Agent Rothrock requested more than once that Mr.
+Johnson consent to a search; (2) Agent Rothrock
+said that he would need to secure the residence until the warrant issued, thereby causing his free will
+to be overborne. Mr. Johnson was concerned that
+the other residents of the home would be unable
+freely to come and go. We shall examine each of
+these contentions.
+With respect to Mr. Johnson's first submission
+ur opinion in United States • LaGrone. 43 F.30
+332, 333 (7th Cir.1994), is helpful. In LaGrone, as
+in this case, the defendant was asked more than
+once whether he would consent to a search. We
+stated that "[w]hile it is true that the officers asked
+LaGrone more than once whether he would consent
+to the search, we do not believe this constitutes the
+sort of repetitive psychological harassment that
+should tip the balance in favor of LaGrone." Id. at
+334. Here, Agent Rothrock asked Mr. Johnson to
+consent on more than one occasion. However, Mr.
+Johnson himself stated that at no time did he feel
+threatened or coerced.
+With respect to the second submission, in
+United States | Santiago, 428 F.3d 699, 705 (7th
+lective custody. The district court, however, con
+cluded that no actual threat had been issued. Rather
+he district court determined that, when his hom
+address had been discovered and he realized that
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prf=HTMLE&mt=FederalGov.. 2/27/2008
+
+
+
+became "rightful[ly] concern(ed]" for his family.
+Id. The district court further found that this
+"rightful concern" did not amount to
+"psychological pressure." Id. In reaching this conclusion, the district court found it important that the
+authorities had behaved professionally, that the entire incident took only twenty minutes and that the
+encounter was "devoid of any badgering or harassment." Id. Looking to the totality of the circumstances considered by the district court, we concluded, in Santiago, that the district court's voluntariness finding was not clearly erroneous. Id. Similarly, we must conclude that Mr. Johnson's concern
+that he might inconvenience the other residents of
+the home was a "rightful concern," but not one that
+caused "psychological pressure."
+Mr. Johnson is 48 years of age and of at least
+average intelligence. He testified at the suppression
+hearing that he understood the consent form, that he
+never felt coerced or threatened and that he understood he was waiving his Fourth Amendment
+rights. The interview was calm and professional at
+all times. Considering the totality of the factors surrounding Mr. Johnson's consent, we certainly cannot say the district court clearly erred in finding
+that consent was voluntarily and freely given.
+Page 8
+Cir.2003) (internal citations and quotation marks
+omitted).
+[9] The facts of this case clearly demonstrate
+that probable cause existed for the search. See
+Illinois | Gates, 462 U.S. 213, 103 S.Ct. 2317, 76
+L.Ed.2d 527 (1983) (establishing a totality of the
+circumstances test by which to determine whether
+probable cause exists). The officers had acquired
+detailed information from Jane Doe that Mr. Johnson had taken the photos, that she was the child depicted in the photos and that Mr. Johnson had used
+a silver digital camera. She also mentioned that he
+possessed a black Dell computer. R.53 at 15-16. In-
+deed, based on this information, Agent Rothrock
+obtained a warrant for Mr. Johnson's arrest before
+his encounter with Mr. Johnson. Moreover, before
+Mr. Johnson consented to the search, he had a conversation with the officers. During the course of
+that conversation, he stated that he owned a black
+Dell computer and a silver digital camera. He confirmed that he previously had lived in Indianapolis.
+This information would more than suffice to establish probable cause upon which to issue a search
+warrant. Therefore, the deterrence rationale of the
+exclusionary rule would not apply, and the evidence would be admissible under the inevitable discovery doctrine.
+B.
+[8] Even if Mr. Johnson did not consent, the
+evidence would have been otherwise*543 admissible
+under the inevitable discovery doctrine. See
+Nix | Williams, 467 U.S. 431, 444, 104 S.Ct. 2501,
+81 L.Ed.2d 377 (1984). This doctrine provides that,
+when the Government can establish by a preponderance of the evidence that the information obtained
+would have been discovered ultimately or inevitably by lawful means, the deterrence rationale of
+the exclusionary rule no longer applies and the
+evidence should be admitted. Id "The prosecution
+C.
+[10] Mr. Johnson also submits that the district
+court violated his Fifth and Sixth Amendment
+rights by imposing the mandatory minimum life
+sentence, required by 18 U.S.C. § 3559(e) and 18
+U.S.C. § 2251(e), because the underlying fact of a
+prior conviction had not been charged in the indictment or proven beyond a reasonable doubt to a jury.
+[11] Mr. Johnson acknowledges that this court
+is without power to decide this issue in his favor.
+The governing law of the Supreme Court unequivocally states that the fact of a prior conviction
+need not be found by a jury beyond a reasonable
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov... 2/27/2008
+
+
+
+doubt, nor must it be alleged in the indictment. Al-
+mendarez-Torres | United States,
+523 U.S. 224,
+46-47, 118 S.Ct. 1219, 140 L.Ed.2d 350 (1998
+porendi New Jersey, 530 U.S. 466, 120 S.C
+2348, 147 L.Ed.2d 435 (2000), explicitly preserved
+Almendarez-Torres, see530 U.S. at 490, 120 S.Ct.
+2348 ("Other than the fact of a prior conviction,
+any fact that increases the penalty for a crime beyond the prescribed statutory maximum must be submitted to a jury, and proved beyond a reasonable
+doubt") (emphasis added), although left open the
+possibility that future cases might revisit its holding, see id. at 489-90, 120 S.Ct. 2348. Later cases,
+including Blakely | Washington, 542 U.S. 296, 124
+Ct. 2531, 159 L.Ed.2d 403 (2004), United State.
+Booker, 543 U.S. 220, 125 S.Ct. 738, 16(
+C.Ed.2d 621(2005), and Shepard | United States,
+544 U.S. 13, 125 S.Ct. 1254, 161 L.Ed.2d 205
+(2005), each have confirmed Almendarez-Torres'
+continuing vitality. See United States | Sachsen-
+491 F.3d 680, 683 (7th Cir.2007)
+(confirming that Almendarez-Torres remains the
+governing law but noting that *544 the defendant
+had preserved the argument for consideration by the
+Supreme Court). Therefore, we cannot accept Mr.
+Johnson's claim that the district court's failure to
+submit this issue to the jury constitutes reversible
+Page 9
+Conclusion
+For these reasons, the judgment of the district
+court is affirmed.
+AFFIRMED
+C.A.7 (Ind.),2007.
+J.S.. Johnsor
+195 F.3d 536
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prfl=HTMLE&mt=FederalGov... 2/27/2008
+
+
+
+U.s. I Leach
+C.A.8 (Mo.),2007.
+United States Court of Appeals, Eighth Circuit.
+UNITED STATES of America, Appellant,
+Tyler M. LEACH, Appellee.
+No. 06-1471.
+Submitted: Feb. 14, 2007.
+Filed: June 22, 2007.
+Background: Defendant was convicted in the
+United States District Court for the Western District of
+Missouri, Howard F. Sachs, Senior District Judge, of
+knowingly using a facility of interstate commerce to attempt to persuade, induce, and entice a minor to engage
+in illegal sexual activity, and the government appealed
+his 72-month sentence.
+Holdings: The Court of Appeals, Smith, Circuit
+Judge, held that:
+(1) government did not breach plea agreement by
+advocating at sentencing for application of sentencing
+guidelines offense level enhancement, and
+(2) offense level enhancement was warranted for
+having committed the offense subsequent to sustaining
+a sex offense conviction.
+Vacated and remanded.
+West Headnotes
+[1] Sentencing and Punishment 350H €-290
+350H Sentencing and Punishment
+350HII Sentencing Proceedings in General
+350HII(E) Presentence Report
+350Hk290 k.
+Successive, Supplemental and
+Updated Report. Most Cited Cases
+Sentencing and Punishment 350H C-299
+350H Sentencing and Punishment
+350HII Sentencing Proceedings in General
+350HII(E) Presentence Report
+350Hk299 k. Objections and Disposition
+Thereof. Most Cited Cases
+Government's failure to timely object to original presentence investigation report (PSR) prepared for defendant's sentencing for knowingly using facility of interstate commerce to attempt to persuade, induce, and entice a minor to engage in illegal sexual activity did not
+preclude government from advocating at sentencing for
+sentencing guidelines offense level enhancement that
+was not mentioned in original PSR; probation office
+amended PSR more than a month before the sentencing
+hearing to include the enhancement, giving defendant
+ample opportunity before sentencing to prepare sentencing memoranda on applicability of enhancement and to
+formulate an argument regarding the enhancement.
+Fed.Rules Cr.Proc.Rule 32(f), 18 U.S.C.A.
+[2] Criminal Law 110 €-273.1(2)
+110 Criminal Law
+110XV Pleas
+110k272 Plea of Guilty
+110k273.1 Voluntary Character
+110k273.1(2) k. Representations, Promises,
+or Coercion; Plea Bargaining. Most Cited Cases
+Government did not breach plea agreement pursuant to
+which defendant pleaded guilty to knowingly using facility of interstate commerce to attempt to persuade, induce, and entice a minor to engage in illegal sexual
+activity by advocating at sentencing for application of
+sentencing guidelines offense level enhancement under
+chapter 4 of guidelines for having committed offense
+subsequent to sustaining a sex offense conviction; although government stipulated in plea agreement that defendant's base offense level was 24, agreement only referred to base offense level under chapter 2 of
+guidelines, and did not address adjustments from
+chapter 4, and agreement stated that, as to unmentioned
+guidelines issues, parties were free to advocate their positions at sentencing. U.S.S.G. § 1B1.1 et seq., 18
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prf=HTMLE&mt=FederalGov... 2/27/2008
+
+
+
+|3] Criminal Law 110 € 1139
+110 Criminal Law
+110XXIV Review
+110XXIV(L) Scope of Review in General
+110k1139 k. Additional Proofs and Trial De
+Novo. Most Cited Cases
+Issues regarding the interpretation and enforcement of a
+plea agreement are reviewed de novo.
+14] Criminal Law 110 C-273.1(2)
+110 Criminal Law
+110XV Pleas
+110k272 Plea of Guilty
+110k273.1 Voluntary Character
+110k273.1(2) k. Representations, Promises,
+or Coercion; Plea Bargaining. Most Cited Cases
+Plea agreements are contractual in nature, and should be
+interpreted according to general contract principles.
+[5] Sentencing and Punishment 350H €-795
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(E) Prior or Subsequent Misconduct
+350Hk795 k. Order. Most Cited Cases
+In a case in which the defendant had pleaded guilty in
+Kansas state court to attempted aggravated criminal
+sodomy with a child under age 14, but had not yet been
+sentenced for that offense when he committed the federal offense of knowingly using a facility of interstate
+commerce to attempt to persuade, induce, and entice a
+SMITH, Circuit Judge.
+Tyler Leach pleaded guilty, pursuant to a plea
+agreement, to knowingly using a facility of interstate
+commerce to attempt to persuade, induce, and entice a
+minor to engage in illegal sexual activity, in violation of
+18 U.S.C. § 2422(b). In sentencing Leach, the district
+court declined to apply enhancements advocated by the
+government under U.S.S.G. § 4B1.5(a) or, alternatively,
+under § 4B1.5(b). Leach was sentenced to 72 months'
+imprisonment. The government appeals the district
+court's decision that neither enhancement applies. We
+reverse.
+*860 I. Background
+On February 22, 2005, Leach pleaded guilty in
+Kansas state court to attempted aggravated criminal
+sodomy with a child under the age of 14 years ("the
+Kansas offense*). The Kansas offense involved Leach
+receiving oral sex from a 13-year old girl that he had
+met in an internet chat-room. Leach's sentencing on that
+offense was set for March 15, 2005.
+On March 8, 2005, one week before his scheduled
+sentencing on the Kansas offense, Leach conversed in a
+chat-room with someone that he thought was a 14-year
+old girl named "Amber." However, "Amber" was actually an undercover FBI agent. Leach's conversations
+with "Amber" quickly became sexual. The next day,
+Leach again contacted "Amber" and made arrangements
+to travel from his residence in Lawrence, Kansas, to her
+residence in Kansas City, Missouri, to engage in sexual
+activity. On March 10, 2005, Leach arrived at the Kansas City, Missouri address provided by "Amber," and
+was arrested by federal agents. During a post-arrest interview, Leach admitted that he had arranged to have
+vaginal and oral sex with "Amber," whom he believed
+to be a 14-year old girl. Because of Leach's arrest, his
+sentencing on the Kansas offense did not occur as
+having committed the offense subsequent to sustaining
+a sex offense conviction. U.S.S.G. § 4B1.5(a), 18
+U.S.C.A.
+*859 Philip M. Koppe, Asst. U.S. Atty., argued, Kansas
+City, MO (Bradley J. Schlozman, U.S. Atty., Cynthia L.
+Phillips, Asst. U.S. Atty., on the brief), for appellant.
+Sephen City, Mos Aar. ond Conrad, fe Fed. Public
+Cansas City, MO (Raymond C. Conrad, Jr.,
+Defender, on the brief), for appellee.
+Before WOLLMAN, BYE, and SMITH, Circuit Judges.
+gaging in illegal sexual conduct, in violation of 18
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prfl=HTMLE&mt=FederalGov.. 2/27/2008
+
+
+
+U.S.C. § 2422(b) (Count One); traveling in interstate
+commerce for the purpose of engaging in illicit sexual
+conduct with another person, in violation of 18 U.S.C. §
+2423(b) (Count Two); and criminal forfeiture, pursuant
+to 18 U.S.C. § 2253 (Count Three). Leach entered into a
+plea agreement, pleading guilty to Count One in return
+for the government dropping the remaining counts. In
+the plea agreement, Leach acknowledged that he was
+subject to a 5-year minimum and a 60-year maximum
+sentence under 18 U.S.C. § 2426(a) because his federal
+offense occurred after [Leach] had a prior sex offense
+conviction."
+The parties stipulated in the plea agreement that:
+(1) "the applicable Guidelines section for the offense
+was U.S.S.G. § 2G1.3 (Travel to engage in prohibited
+sexual conduct with a minor);" (2) "the base level offense is 24 pursuant to U.S.S.G. § 2G1.3(a);" (3) Leach
+was subject to a two-level enhancement pursuant to
+U.S.S.G. § 2G2.2(b)(3)(A) because the offense involved
+the use of a computer; (4) Leach was entitled to a threelevel reduction
+for
+acceptance of responsibility; (5)
+"there [was] no agreement between the parties regarding the defendant's
+criminal history category;"
+(6)
+neither party would seek a departure from the applicable
+guidelines range; and (7) the court would determine the
+"applicable criminal history category after receipt of the
+presentence investigation report."
+Additionally, the plea agreement limited its scope
+to issues explicitly addressed therein and had no effect
+on any unmentioned Sentencing Guidelines issues. As
+to any unmentioned issues,
+"the parties were free to advocate their respective positions at the sentencing hearing." It is undisputed that the plea agreement was negotiated without any consideration of
+§ 4B1.5. In
+the government acknowledges
+"completely unaware" of the potential applicability of
+the enhancement when it negotiated and executed the
+plea agreement.
+The presentence investigation report (PSR ) wa
+repared on October 3, 2005, and revised, along with ar
+addendum, on November 3, 2005. The PSR concluded
+that Leach's Guidelines range was 60-63 *861 months
+FN1 based on an offense level of 23 and criminal his-
+tory category of II. Neither party objected to these calculations. Thereafter, on November 10, 2005, the probation office filed a second addendum to the PSR, stating
+that "the guidelines were inaccurately calculated" in the
+original PSR and suggesting that Leach was subject to
+an enhancement under Guidelines § 4B1.5(a) based on
+the existence of the Kansas offense for which he had
+already been adjudicated guilty but had not yet been
+sentenced. If the § 4B1.5(a) enhancement applied,
+Leach's offense level would have been 34 with a criminal history Category . making Leach's Guidelines range
+168-210 months' imprisonment. Leach timely objected
+to the § 4B1.5(a) enhancement.
+FN1. The Guidelines range would have been
+51-63 months, if not for the statutory minimum
+sentence of 60 months.
+Both parties filed briefs, prior to sentencing, on the
+applicability of the § 4B 1.5(a) enhancement. Leach
+contended that the enhancement did not apply because
+he had not yet been sentenced for the Kansas offense,
+and therefore had not yet sustained a prior sex offense
+conviction. Additionally, Leach urged the court to honor
+the parties' stipulations in the plea agreement and sentence him accordingly. The government, despite having
+not objected to the initial or first-amended PSR, which
+did not include the § 4B 1.5 enhancement-and admitting
+that it had previously been "completely unaware" of §
+4B1.5-adopted the position of the probation office and
+advocated for the application of § 4B 1.5(a).
+On December 20, 2005, the court held a hearing on
+the applicability of § 4B 1.5(a) and concluded that the
+enhancement did not apply because Leach had not yet
+been sentenced for the Kansas offense. The court determined that it was unclear whether the "conviction"
+requirement of § 4B 1.5(a) required the defendant to
+have been sentenced for the prior offense or merely
+have been adjudicated guilty by plea of guilty, nolo
+contendre, or a finding of guilt. Based on the failure of
+define the
+"conviction," recent legislative enactments regarding
+the term, and the rule of lenity, the court refused to apply the § 4B1.5(a) enhancement to Leach. FN2
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov... 2/27/2008
+
+
+
+FN2. After the court ruled that § 4B1.5(a) did
+not apply, Leach stated for the record that in
+the event the court's decision on the enhancement was overturned, his position was that the
+plea agreement prevented the government from
+advocating for the enhancement. At no time
+during the December 20, 2005, hearing did
+Page 4
+ment had no standing to advocate for the enhancements because it had failed to timely object to the original PSR which did not include
+either enhancement.
+The district court ultimately concluded that Leach's
+offense level was 23, his criminal history was a Category II and his advisory guideline range was 60-63
+months. The court then sentenced Leach to 72 months'
+imprisonment, a 9-month increase from the top of the
+calculated Guidelines range. The government appeals.
+vocating for enhancement.
+The government moved for reconsideration of the
+court's ruling on the § 4B1.5(a) enhancement, and the
+probation office filed a third addendum to the PSR, suggesting that if § 4B1.5(a) did not apply, then a five-level
+enhancement under § 4B1.5(b) should apply because
+the defendant had engaged "in a pattern of activity involving prohibited sexual conduct." If § 4B1.5(b) applied, Leach's total offense level would increase from
+23 to 28, causing his Guidelines range to increase from
+60-63 months to 87-108 months' imprisonment. Both
+parties filed sentencing briefs regarding the applicability of § 4B1.5(b).
+On January 13, 2006, the court conducted Leach's
+sentencing hearing and heard arguments on both the reconsideration of § 4B1.5(a) and the applicability of §
+4B1.5(b). After oral argument, the court denied the government's motion to reconsider its ruling on the §
+4B1.5(a) enhancement, concluding that the government
+had no standing to seek the enhancement*862 because it
+had failed to timely object to the original PSR.FN3
+Moreover, the court determined that the plea agreement
+prevented the government from advocating for the enhancement. Alternatively, the court denied the motion
+to reconsider for the same reasons given in its original
+decision-that it was unclear whether § 4B1.5(a)'s conviction requirement required a defendant to have been
+sentenced on the conviction or merely adjudicated
+guilty and that the rule of lenity favored Leach. Further,
+he court determined that § 4B1.5(b) was inapplicable
+because the government failed to prove two prior occasions that were distinct from the offense of conviction.
+FN3. Prior to the January 13, 2006 sentencing
+hearing, Leach had not argued that the govern-
+II. Discussion
+The government contends that the district court
+erred in not applying § 4B1.5(a), or alternatively, §
+4B1.5(b). Leach agrees with the district court's conclusion that neither enhancement should apply but alternatively asserts that the plea agreement and the government's failure to timely object to the original PSR prevent it from advocating for either enhancement.
+A. Untimely Objections to the PSR
+Federal Rule of Criminal Procedure 32(f) states that
+"[w]ithin 14 days after receiving the presentence report,
+the parties must state in writing any objections ... contained in or omitted from the report." *The reason for
+the fourteen-day filing requirement is 'so that the objections can be addressed and investigated prior to the sentencing hearing
+F.3d 1009, 1010 (8th Cir. 1995)) (emphasis deleted).
+[1] Here, the probation officer did not include the §
+4B1.5(a) enhancement in the initial or first-amended
+PSR, and the government did not object to the omission.
+However, when the probation office amended the PSR,
+through the second addendum, to include the § 4B1.5(a)
+enhancement, Leach was put on notice-more than a
+month before his initial sentencing hearing-that the enhancement could be at issue. This gave Leach ample opportunity before sentencing to prepare a sentencing
+memoranda on the applicability of § 4B1.5(a) and formulate an argument regarding the enhancement. Given
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov.. 2/27/2008
+
+
+
+these circumstances, any possible prejudice to Leach
+from the government's failure to object to the original
+and first-amended PSR was cured by the adequate opgiven to oppose the enhancement. See
+United States
+Soto-Beniguez, 356 F.3d 1, 52 (Ist
+Cir.2004) ("Any possible prejudice to [defendant] from
+the government's non-compliance [with Federal Rule of
+Criminal Procedure 32] was cured by the district court's
+two-week continuance to give defense counsel an adsquates opno i, uiited Seapen o yung vero end late
+457 (2d Cir.1998) ("The sentencing court may impose
+sentencing enhancements belatedly
+*863 suggested by
+the Government and not contained in the PSR, provided
+the defendant is afforded an adequate opportunity to respond to the Government's late submission and any revision of the PSR.") (internal citation omitted). We hold
+that the government's arguments for the enhancements
+were not foreclosed.
+Page 5
+B. The Plea Agreement
+[2] Leach argues that the govermment's advocacy
+for the § 4B1.5(a) enhancement breached the plea
+would have increased Leach's offense level to 34. Leach
+further contends that because the plea agreement stipulated to a two-level enhancement for use of a computer,
+pursuant to § 2G2.2(b)(3)(A), without any reference to
+§ 4B1.5 or any other enhancement, the agreement necessarily implied that no other enhancements would be
+applied.
+[3][4] Issues regarding the interpretation and enforcement of a plea agreement are reviewed de novo.
+United States | Martinez-Noriega, 418 F.3d 809, 81l
+(8th Cir.2005); United States | DeWitt, 366 F.3d 667,
+669 (8th Cir.2004). *Plea agreements are contractual in
+ture, and should be interpreted according to gener
+ntract principles. " DeWitt. 366 F.3d at 6
+ant stipulated to a base offense level and a specific drug
+quantity in a plea agreement. Id. at 668. After the plea
+agreement was accepted by the court at a change of plea
+hearing, the probation office prepared a PSR suggesting
+that DeWitt's relevant conduct made her accountable for
+additional drug amounts and recommended a higher
+base offense level. Id. at 668-69. At the sentencing
+hearing, the government, on its own initiative, sought to
+introduce evidence to establish the higher drug quantity
+set forth in the PSR, and DeWitt objected, claiming that
+the government had stipulated in the plea agreement to
+the base offense level and the drug quantity. Id. at 669.
+The district court allowed the evidence and subsequently found DeWitt accountable for the drug quantity recommended in the PSR and adopted the PSR's recommended base offense level. Id.
+On appeal, we reversed, holding that the government breached the plea agreement when it introduced
+evidence at sentencing to attribute a greater drug quantity to the defendant when it had previously stipulated to
+the total drug quantity in the plea agreement. Id. at
+670-72. Although the plea agreement entitled the government to offer evidence of uncharged relevant conduct, we ruled that such a general provision could not
+be read to override the specific provision to recommend
+only a certain drug quantity for Guidelines calculation
+purposes. Id. at 670. We noted that when stipulations in
+the plea agreement differ from recommendations in a
+PSR, there is no breach of the plea agreement if the
+court requests the parties to provide evidence or argument on the issue. Id. at 671. But, we ultimately concluded that "[w]here the government stipulates to a drug
+quantity and a base offense level, it may not then initiate an effort at the sentencing hearing to obtain a greater
+sentence, even if the government has come to believe
+that the stipulation was made in error." Id. at 671-72.
+Although there are certainly some similaritie
+between this case and DeWitt, we believe that the in
+stant case is controlled by our decision in Martinez-
+Noriega. In Martinez-Noriega, the plea agreement *86-
+stipulated that the defendant's base offense level wa
+20, pursuant to § 2D1.1. 418 F.3d at 810. The plea
+agreement in Martinez-Noriega, like the plea agreement
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov.. 2/27/2008
+
+
+
+here, made no agreement regarding the defendant's
+justment to his offense level under Chapter Four. Id. at
+• ia orte ort ht ape ram ie .
+810-11. Prior to the sentencing hearing, the probation
+office prepared a PSR, which recommended that Martinez-Noriega be assessed an offense level of 32, pursuant to the career offender guideline, § 4B1.1(b)(C), because he had two prior felony drug convictions. Id. at
+811. Martinez-Noriega objected, arguing that because
+his plea agreement stipulated that his base offense level
+was 20 and did not refer to § 4B1.1, the court was precluded from applying the career offender guideline. Id.
+The district court disagreed and sentenced Martinez-
+Noriega as a career offender. Id.
+On appeal, Martinez-Noreiga argued that application of the career offender enhancement would render
+his base-offense-level stipulation under § 2D1.1 meaningless. He contended the existence of the specific stipulation concerning the base offense level necessarily
+implied that his
+offense level
+would be computed
+without regard to § 4B1.1. Id."We reject[ed] Martinez-
+Noriega's argument because we [found] it inconsistent
+with the structure of the sentencing guidelines." Id. In
+reaching this conclusion, we explained:
+The "Application
+Instructions"
+use of the
+guidelines set forth nine sequential steps to be followed
+by the sentencing court in applying the provisions of the
+guidelines manual. The second step calls for the court to
+"[d]etermine the base offense level ... contained in the
+particular guideline in Chapter Two. "USSG § 1B1.1(b).
+The next three steps direct the court to apply adjustments from Chapter Three of the guidelines. The sixth
+step then states that the court should "[djetermine the
+defendant's criminal history category as specified in
+Part A of Chapter Four," and "[d)etermine from Part B
+of Chapter Four any other applicable adjustments."
+USSG § 1B1.1(f). These adjustments from Part B include the enhanced offense levels for career offenders
+pursuant to USSG § 4B1.1.
+Id. at 812. (emphasis in original).
+plate.. tater explain d dandant fumatine is entec
+Page 6
+to [a Chapter Four adjustment], the court will first compute the defendant's "base offense level" under Chapter
+Two of the guidelines." Id. Thus, by stipulating to a
+base offense level, "[the] defendant has solidified where
+he will start in Chapter Two of the guidelines, but he
+has not protected himself against adjustments in
+Chapter Four."Id. at 813. Accordingly, we held that the
+district court did not err in applying the career-offender
+Guideline to Martinez-Noriega because the agreement
+only resolved the defendant's base offense level under
+Chapter Two, but did not resolve any issues with respect to Chapter Four. Id.
+Like the agreement in Martinez-Noriega, Leach's
+plea agreement only stipulated to his base offense level
+under Chapter Two of the Guidelines. Although the
+parties were free to do so, they did not address possible
+adjustments "from Part B of Chapter Four," which includes the enhanced offense levels for repeat and dangerous sex offenders against
+U.S.S.G. § 4B1.5. Thus, in contrast to DeWitt, the government here did not advocate for anything inconsistent
+with the stipulations of the plea agreement; it advocated
+for something that was not resolved by the plea agreement. Paragraph *865 11 of Leach's plea agreement
+stated that "[t]he parties understand, acknowledge and
+agree that there are no agreements between the parties
+with respect to any Sentencing Guidelines issues other
+than those specifically listed" and that "[a]s to any other
+Guidelines issues, the parties are free to advocate their
+respective positions at sentencing." We conclude, therefore, that the government was free to advocate for the §
+4B1.5(a) enhancement because it was an issue that had
+not been agreed to or specifically listed in the agreement. Accordingly, we hold that the government did not
+breach the plea agreement.
+C. U.S.S.G. § 4B1.5(a)
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prfi=HTMLE&mt=FederalGov.. 2/27/2008
+
+
+
+(a) In any case in which the defendant's instant offense
+of conviction is a covered sex crime, § 4B1.1 (Career
+Offender) does not apply, and the defendant committed
+the instant offense of conviction subsequent to sustaining at least one sex offense conviction:
+(1) The offense level shall be the greater of:
+(A) the offense level determined under Chapters Two
+and Three; or
+(B) the offense level from the table below decreased by
+(i) Life.
+(ii) 25 years or more.
+(iii) 20 years or more, but
+less than 25 years.
+(iv) 15 years or more, but
+less than 20 years.
+($ 10 years or more, but less
+than 15 years.
+(vi) 5 years or more, but less
+than 10 years.
+(vii) More than 1 year, but
+less than 5 years.
+(2) The criminal history category shall be the greater of: (A) the criminal history category determined under Chapter Four, Part A (Criminal History); or (B)
+criminal history Category I
+U.S.S.G. § 4B1.5(a). FN4
+N4. The plea agreement stipulated that the ap
+icable Guidelines Manual was *the one tha
+took effect on November 5, 2004." Section
+4B1.5(a) remains unchanged in the current edition of the Guidelines Manual.
+Put simply, Leach would be subject to the §
+4B1.5(a) enhancement if: (1) his "instant offense of
+conviction is a covered sex crime;" (2) the career offender enhancement (§ 4B1.1) does not apply to him;
+and (3) he "committed the instant offense of conviction
+subsequent to sustaining at least one sex offense conviction." Id. Leach unquestionably meets the first two prerequisites of § 4B1.5(a). His "instant offense of conviction"-knowingly using a facility of interstate commerce
+to attempt to entice a minor to engage in sexual activity-
+Page 7
+she nument tom 8 l T Aordian to any episible
+Offense Statutory Maximum Offense Level
+37.
+34.
+32.
+29.
+24.
+17.
+12.
+qualifies as a "covered sex crime" as that term is
+defined in Application Note 2 to § 4B1.5.FNs More
+specifically, the offense *866 was perpetrated against a
+minor Fie and fell under 18 U.S.C. § 2422(b) which is
+under Chapter 117 of Title 18 of the United States Code
+nd thus constituting a "covered sex crime." See Unite
+tates • Blazek, 431 F.3d 1104, 1110 (8th Cir.2005
+(upholding the application of § 4B1.5(a) enhancement
+and ruling that a conviction for attempted enticement of'
+a minor under 18 U.S.C. § 2422(b) is a "covered sex
+crime" for purposes of the enhancement, even if the intended victim was an undercover officer and not an actual minor). Additionally, § 4B1.1, the career offender
+not have at least two prior felony convictions of either a
+rime of violence or a controlled substance offense
+FNS. Application Note 2 of § 4B1.5, entitled
+"Covered Sex Crime as Instant Offense of Con-
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov... 2/27/2008
+
+
+
+viction," states:
+For purposes of this guideline, the instant offense
+of conviction must be a covered sex crime, i.e.: (A) an
+offense, perpetrated against a minor, under (i) chapter
+109A of title 18, United States Code; (ii) chapter 110 of
+such title, not including trafficking in, receipt of, or
+possession of, child pornography, or a recordkeeping
+offense; (iii) chapter 117 of such title, not including
+transmitting information about a minor or filing a factual statement about an alien individual; or (B) an attempt
+or conspiracy to commit any offense described in subdivisions (A)(i) through (iii) of this note.
+FN6. Although Application Note 1 to § 4B1.5,
+defines "minor" as a person under the age of 18
+and defines "minor victim" to include
+"an undercover law enforcement officer who represented to the defendant that the officer was a
+minor," this court has specifically held that a
+conviction for attempted enticement of a minor
+under 18 U.S.C. § 2422(b)-Leach's instant offense of conviction-is a "covered
+sex crime"
+for purposes of § 4B1.5 even though the intended victim was
+in fact an undercover law enforcement officer. United States Blazek, 431
+F.3d 1104, 1110 (8th Cir.2005).
+It is undisputed that Leach committed the instant
+offense of conviction after he pleaded guilty to the Kansas offense-attempted
+However,
+sentencing on Leach's Kansas offense was
+pending when the district court sentenced him on the instant offense. Thus, no final judgment of conviction had
+been entered on the Kansas offense. Leach contends,
+therefore, that the Kansas offense cannot be counted as
+a prior "sex offense conviction"
+for purposes of §
+4B1.5(a) because the section does not define whether
+the term "conviction"
+requires the defendant to have
+been sentenced pursuant to the conviction (a final judgment of conviction) or whether a "conviction" only requires that the defendant was adjudicated guilty of the
+offense, whether by the court, jury, or accepted plea of
+guilty or nolo contendere. If the prior conviction under
+§ 4B1.5(a) only requires that the defendant have been
+found guilty of the offense, the enhancement would ap-
+Page 8
+ply to Leach. However, if the prior "conviction" requires that the defendant have been sentenced for the
+offense and a final judgment of conviction entered, then
+§ 4B1.5(a) would not apply to him.
+The district court ruled that the term "conviction"
+in § 4B1.5(a) was ambiguous. The court noted that the
+erm is not defined in § 4B1.5(a), relying on languag
+rom the Supreme Court's decision in Deal United
+States, 508 U.S. 129, 131-32, 113 S.Ct. 1993, 124
+L.Ed.2d 44 (1993) ("It is certainly correct that the word
+"conviction' can mean either the finding of guilt or the
+entry of a final judgment on that finding," which
+"includes both the adjudication of guilt and the sentence."). The district court considered that the context
+of § 4B1.5(a) did not clear up the ambiguity of the term
+"conviction," so it applied the rule of lenity and found
+the Kansas offense could not count as a prior sex conviction under the section.
+We disagree with the district court's interpretation
+and find that the context of § 4B1.5-much like the context of the statute at issue in Deal-makes "it unambiguous that "conviction' refers to the finding of guilt by a
+judge or jury that necessarily precedes the entry of a final judgment of conviction." See id. at 132, 113 S.Ct.
+1993. The first clause of § 4B1.5(a) speaks of "the instant offense of conviction," which is *867 the crime
+for which the defendant was now to be sentenced, and
+for which the enhancement would apply if the defendant
+has a previous sex offense conviction. See§ 4B1.5(a).
+The term "conviction" in § 4B1.5(a) therefore cannot
+mean a judgment of conviction. Clearly, the term conviction refers to a conviction without an entry of final
+judgment in the phrase "instant offense of conviction"
+because the sentencing was not yet complete. The term
+should be read to have the same meaning when used
+later in the same sentence unless otherwise stated or implied. F7 We do not read § 4B1.5(a) as requiring the
+formal entry of a judgment of conviction before a de
+fendant is considered convicted for the provision's enhancements to apply. Any other reading is at best
+strained. See Deal, 508 U.S. at 132, 113 S.Ct. 1993
+(finding that if "conviction" in § 924(c)(1) meant
+"judgment of conviction," then "the provision would be
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov... 2/27/2008
+
+
+
+incoherent, prescribing that a sentence which ha
+ready been imposed ... shall be 5 or 20 years longer
+than it was").
+FN7. Essentially, Leach argues for one definition of "conviction" the first time it appears in
+§ 4B1.5(a)-an adjudication of guilt-and a different definition for "conviction" the second
+time the term is used-a judgment of conviction
+requiring a sentence to be imposed. This result
+would go against one of the basic rules of statutory interpretation-that identical words used in
+different parts of the same act or statute are inon internat evenes mean 515 0. 235,
+250, 116 S.Ct. 647, 133 L.Ed.2d 611 (1996)
+("the normal rule of statutory construction [is]
+that identical words used in different parts of
+the same act are intended to have the same
+meaning.").
+Our reading of the term "conviction" in § 4B1.5(a)
+as only requiring an adjudication of guilt is confirmed
+by the "Background" section of § 4B1.5, which states:
+The guideline is intended to provide lengthy incarceration for offenders who commit sex offenses against
+minors and who present a continuing danger to the public. It applies to offenders whose instant offense of conviction is a sex offense committed against a minor victim. The relevant criminal provisions provide
+for increased statutory maximum penalties for repeat sex offenders and make those increased statutory maximum
+penalties available if the defendant previously was convicted of any of several federal and state sex offenses
+(see 18 U.S.C. 2247, 2426). In addition, section 632 of
+Public Law 102-141 and section 505 of Public Law
+105-314 directed the Commission to ensure lengthy incarceration for offenders who engage in a pattern of
+ctivity involving the sexual abuse or exploitation o
+inors. Section 401(i)X1)(A) of Public Law 108-21 dir
+ectly amended Application Note 4(b)(i), effective April
+U.S.S.G. § 4B1.5 cmt. Background (Emphasis added).
+Page 9
+As stated above, § 4B1.5"is intended to provide
+lengthy incarceration for offenders who commit sex offenses against minors and who present a continuing
+danger to the public," and to increase the maximum
+penalties for "repeat sex offenders." Requiring a "repeat
+sex offender," such as Leach, to have been sentenced
+for a prior sex offense against a minor, when he has
+already been adjudicated guilty of the offense does
+nothing to effectuate the stated intent of the enhance-
+(a) Maximum term of imprisonment.-The maximum
+term of imprisonment for a violation of this chapter
+after a prior sex offense conviction shall be twice the
+term of imprisonment otherwise provided by this
+chapter, unless section 3559(e) applies.
+*868 (1) the term "prior sex offense conviction"
+means a conviction for an offense-
+(A) under this chapter, chapter 109A, or chapter
+(B) under State law for an offense consisting of
+conduct that would have been an offense under a
+chapter referred to in paragraph (1) if the conduct had
+occurred within the special maritime and territorial jurisdiction of the United States;
+18 U.S.C. § 2426 (emphasis added).
+Although this section does not explicitly state
+whether a "conviction" requires sentencing to have occurred, subsection (a) of § 2426 doubles a defendant's
+maximum term of imprisonment if the defendant had a
+prior "sex offense conviction" against a minor. 18
+U.S.C. § 2426. In the plea agreement entered into in this
+case, Leach acknowledged, in the "Statutory Penalties"
+section of his plea agreement, that upon pleading guilty
+to Count One of the indictment, his maximum sentence
+was 60 years "pursuant to 18 U.S.C. § 2426(a) because
+said offense occurred after (Leach] had a prior sex offense conviction... " Plea Agreement 9| 5 (emphasis added). Because the phrase "sex offense conviction" in §
+4B1.5(a) is defined as "any offense described in 18
+U.S.C. 2426(b)(1)(A) or (B), if the offense was perpet-
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov... 2/27/2008
+
+
+
+rated against a minor" and Leach stipulated in his plea
+agreement that his maximum sentence would be
+doubled to 60 years under 18 U.S.C. § 2426(a) because
+the Kansas offense qualified as a prior "sex offense conviction" against a minor, Leach essentially stipulated in
+the plea agreement that the Kansas offense was a prior
+"sex offense conviction" under § 2426(b)(1)(A).
+Because we find that § 4B1.5(a) applies to Leach,
+we need not address the merits of the district court's decision regarding the inapplicability of § 4B1.5(b), as
+subsection (b) can only apply if subsection (a) is inapplicable. U.Ş.S.G. § 4B1.5(b).
+III. Conclusion
+Accordingly, we vacate Leach's sentence and remand the case for resentencing in accordance with this
+decision.
+C.A.8 (Mo.),2007.
+U.S. | Leach
+Page 10
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov... 2/27/2008
+
+
+
+Slip Copy, 2007 WL 3273402 (W.D.Ky.)
+(Cite as: Slip Copy)
+H
+U.S. L. Moore
+W.D.Ky.,2007.
+Only the Westlaw citation is currently available.
+United States District Court, W.D. Kentucky,
+at Louisiville.
+UNITED STATES of America, Plaintiff
+V.
+James Terry MOORE, Defendant.
+Criminal Action No. 3:06-CR-98-S.
+Nov. 5, 2007.
+Jo E. Lawless, U.S. Attorney Office, Louisville,
+KY, for Plaintiff.
+Patrick J. Bouldin, Western Kentucky Federal
+Community Defender, Inc., Louisville, KY, for De-
+fendant.
+MEMORANDUM OPINION
+CHARLES R. SIMPSON, III, United States District
+Judge.
+*1 This matter is before the court upon the motion of the defendant, James Terry Moore
+("Moore"), to reconsider this court's Memorandum
+Opinion and Order entered July 9, 2007, which concluded that Moore is subject to a mandatory life
+sentence pursuant to 18 U.S.C. § 3559(e). Moore
+contends that we should find the penalty provision
+of 18 U.S.C. § 2251(e) applicable in this case and
+impose the thirty-five year mandatory minimum
+sentence.
+In September 2006, after having been arrested
+for advertising and facilitating the distribution of
+child pornography on the Internet, Moore pled
+guilty to violations of 18 U.S.C. §§ 2251(d)(1)(A),
+(d)(2)(B),
+2252A(a)(2), (a)(5)(B), (b)(1), and
+(b)(2). At that time the court advised Moore that
+under 18 U.S.C. § 2251(e) he faced a mandatory
+minimum penalty of thirty-five years imprisonment
+and a maximum of life imprisonment. The United
+States now asserts that 18 U.S.C. § 3559(e) mandates that Moore receive a life sentence.
+In this court's Memorandum Opinion and Order
+entered July 9, 2007, we noted that Moore qualified
+for sentencing under both § 2251(e) and § 3559(e).
+We also noted that if irreconcilable sentencing provisions applicable to the same offense were enacted
+sumultaneously,
+*the last in order or arrangement
+controls. "See United States | Moore, Criminal Ac-
+ion No. 3:06-CR-98-S Memorandum Opinion (Jul
+, 2007) (citing United States, ex rel. Harris 1
+Daniels, 279 Fed. 844 (2nd Cir.1922)). Recognizing that both § 2251(e) and § 3559(e) were enacted
+simultaneously as part of the Prosecutorial Remedies and Tools Against the Exploitation4 of Children
+Today Act of 2003, Pub.L. 108-21, 117 Stat. 650,
+we held that since § 3559(e) was later in arrangement, both in Title 18 of the U.S.Code and in Pub.
+108-21, it prevails. Thus we concluded that Moore
+was subject to mandatory life imprisonment for his
+offenses under 18 U.S.C. § 2251. Moore now urges
+us to apply the rule of lenity and impose the thirtyfive year mandatory minimum sentence provided
+for in § 2251(e).
+The rule of lenity is a principle of statutory
+construction which applies not only to interpretations of the substantive scope of criminal statute
+but also to the penalties they impose. Bifulco
+United States, 447 U.S. 381, 387, 100 S.Ct. 2247,
+2252, 65 L.Ed .2d 205 (1980)."This policy of lenity
+means that the Court will not interpret a federal
+criminal statute so as to increase the penalty that it
+places on an individual when such an interpretation
+lenity is statutory ambiguity. Bifulco, 447 U.S. at
+387. The rule of lenity is generally inapplicable unless "after seizing everything from which aid can be
+court is still left with an ambiguity
+derped i United States, 500 Vis. 453, 463, ily
+S.Ct. 1919, 1926, 114 L.Ed.2d 524 (quoting United
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov... 2/27/2008
+
+
+
+Slip Copy, 2007 WL 3273402 (W.D.Ky.)
+(Cite as: Slip Copy)
+States Bass, 404 U.S. 336, 347, 92 S.Ct. 515,
+522, 30 L.Ed.2d 488 (1971)).
+*2 The rule of lenity is inapplicable to this
+case. Application of the rule is predicated on statutory ambiguity. This court is not faced with any
+ambiguity insofar as whether § 3559(e) is applicable to Moore based on his current criminal conduct and past criminal convictions. The plain language of § 3559(e) applies directly to Moore and
+mandates a life sentence. Simply because Moore's
+criminal conduct also places him within § 2551(e)
+does not give rise to any ambiguity as to whether
+Moore's conduct places him within the ambit of §
+3559(e). This court is not applying the mandatory
+life sentence of § 3559(e) based simply on a guess
+as to what Congress intended. Rather this court is
+applying the mandatory life sentence based on the
+fact that Moore's criminal conduct and past criminal convictions place him directly within § 3559(e),
+and § 3559(e) prevails over § 2551(e) because it is
+later in order of arrangement in the Prosecutorial
+Remedies and Tools Against the Exploitation of
+Children Today Act of 2003. Accordingly, we will
+deny Moore's motion for reconsideration.
+A separate order will be entered herein this
+date in accordance with this opinion.
+W.D.Ky.,2007.
+U.S. I. Moore
+Slip Copy, 2007 WL 3273402 (W.D.Ky.)
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov... 2/27/2008
+
+
+
+Slip Copy, 2007 WL 2025191 (W.D.Ky.)
+(Cite as: Slip Copy)
+H
+U.S. I. Moore
+W.D.Ky.,2007.
+Inly the Westlaw citation is currently availabl
+Inited States District Court, W.D. Kentucky
+at Louisiville.
+UNITED STATES of America, Plaintiff
+V.
+James Terry MOORE, Defendant.
+Criminal Action No. 3:06-CR-98-S.
+July 5, 2007.
+Jo E. Lawless, U.S. Attorney Office, Louisville,
+KY, for Plaintiff.
+Patrick J. Bouldin, Western Kentucky Federal
+Community Defender, Inc., Louisville, KY, for De-
+fendant.
+MEMORANDUM OPINION
+CHARLES R. SIMPSON III, United States District
+*1 This matter is before the court upon the
+parties' briefs regarding sentencing of the defendant, James Terry Moore ("Moore"). Moore, due to
+his prior sex convictions involving minors, faces
+statutory mandatory sentencing. At issue is whether
+the mandatory life sentence provided for in
+U.S.C. § 3559(e) or the thirty-five years to life
+range contemplated by 18 U.S.C. § 2251(e) should
+be applied to him.
+In September 2006, after having been arrested
+for advertising and facilitating the distribution of
+child pornography on the internet, Moore pled
+guilty to violations of 18 U.S.C. §§ 2251(d)(1)(A),
+(d)(2)(B), 2252A(a)(2), (a)(5)(B), (b)(1), and
+(b)(2). At that time the court advised Moore that
+under 18 U.S.C. § 2259(e) he faced a mandatory
+minimum penalty of thirty-five years imprisonment
+and a maximum of life imprisonment. Now, the
+United States asserts that 18 U.S.C. § 3559(e) mandates Moore receive a life sentence.
+In short, § 2251(e) and § 3559(e) conflict, as
+Moore qualifies for sentencing under both. When
+two statutes conflict and cannot be reconciled, "the
+general rule of statutory interpretation is that a subsequent statutory provision prevails over a preexisting and irreconcilably conflicting provision
+which is not expressly repealed " 73 Am. Jr.2d
+Statutes § 169 (2007). This rule, however, is inapplicable here given that § 2251(e), in its most current form, and § 3559(e) were enacted simultaneously as part of the Prosecutorial Remedies and
+Tools Against the Exploitations of Children Today
+Act of 2003, Pub.L. No. 108-21, 117 Stat.
+650. Thus, the more precise issue becomes: if Congress has simultaneously enacted irreconcilable
+sentencing provisions applicable to the same offense, which applies?
+United States, ex rel. Harris | Daniels, 279
+Fed. 844 (2nd Cir.1992), provides guidance on this
+issue. In Ex. rel. Harris, the Second Circuit was
+faced with a potential conflict between two sentencing provisions, one which permitted " *all sentences' of summary court-martial [to] be carried into effect upon the approval of the senior officer
+present …..", and another, which provided "that the
+Secretary of the Navy may set the proceedings of
+the court aside and remit or mitigate in whole or in
+part the sentence imposed.' " Id.
+at 849.Although
+the court ultimately decided that the "apparent conflict [was not] one in realityl ]," it first stated:
+In consideration of irreconcilable conflicting
+provisions, if both were enacted at the same time,
+the last in order or arrangement controls.
+Section 3559(e) is later in arrangement, both in
+Title 18 of the U.S.Code and Pub.L. No. 108-21.As
+© 2008 Thomson/West. No Claim to Orig. U.S. Govt, Works.
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prfl=HTMLE&mt=FederalGov... 2/27/2008
+
+
+
+Slip Copy, 2007 WL 2025191 (W.D.Ky.)
+(Cite as: Slip Copy)
+such, it prevails, subjecting Moore to mandatory
+life imprisonment. Moreover, an argument exists
+that § 2251(e) and § 3559(e) were not enacted simultaneously. This argument, if accepted, permits the
+court to apply the general rule of statutory construction calling for the later enacted provision to control. Section 2559(e) existed at the time at the time
+§ 3559(e) was enacted. Public Law No. 108-21
+merely amended§ 2259(e) by raising the mandatory
+minimum sentence from thirty to thirty-five years.
+On the other hand, Pub. Law No. 108-21 added an
+entirely new subsection to § 3559, subsection (e),
+which provides for mandatory life imprisonment for
+repeated sex offenses against minors.
+*2 Accordingly, the court concludes that pursuant to 18 U.S.C. § 3559(e) Moore is subject to a
+sentence of mandatory life imprisonment for his offenses under 18 U.S.C. $ 2251. It is so ordered.
+W.D.Ky,2007.
+U.S. Moore
+Slip Copy, 2007 WL 2025191 (W.D.Ky.)
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&mt=FederalGov.. 2/27/2008
+
+
+
+H
+U.S. I. Peck
+C.A.8 (lowa),2007.
+United States Court of Appeals, Eighth Circuit.
+UNITED STATES of America, Appellee,
+Nicholas PECK, Appellant.
+No. 06-4187.
+Submitted: June 12, 2006.
+Filed: Aug. 6, 2007.
+Rehearing and Rehearing En BancDenied Sept. 10,
+2007.
+Background: Defendant pled guilty in the
+United States District Court for the Northern District of lowa, Linda R. Reade, Chief Judge, to sexual exploitation of a child, possession of child pornography, and distribution of cocaine. Defendant appealed.
+Holdings: The Court of Appeals, Gruender,
+Circuit Judge, held that:
+(1) government did not breach its plea agreement by advocating for sentencing enhancements;
+(2) imposition of enhancements for pattern of
+activity and exploiting more than one minor was
+not impermissible double counting; and
+(3) sentence of 420 months' imprisonment was
+not unreasonable.
+Affirmed.
+110k273.1(2)
+romises, or Coercion; Plea Bargaining. Most Cite
+Cases
+overnment did not breach its plea agreement wi
+efendant, in which it agreed to file no addition
+criminal charges, by advocating for sentencing enhancements, where plea agreement expressly permitted government to provide all relevant information to probation office for use in preparing presentence report and the agreement did not contain any
+provision regarding the advisory gurdelines calcula-
+[2] Criminal Law 110 €-1030(1)
+110 Criminal Law
+110XXIV Review
+110XXIV(E) Presentation and Reservation in
+Lower Court of Grounds of Review
+110XXIV(E)1 In General
+110k1030 Necessity of Objections in
+General
+110k1030(1) k. In General. Most
+Cited Cases
+The Court of Appeals can correct an error not
+raised before the district court if there is error, that
+is plain, and that afects substantial rights.
+[3] Criminal Law 110 €-1030(1)
+110 Criminal Law
+110XXIV Review
+110XXIV(E) Presentation and Reservation in
+Lower Court of Grounds of Review
+110XXIV(E)1 In General
+110k1030 Necessity of Objections in
+General
+110k1030(1) k. In General. Most
+West Headnotes
+[1] Criminal Law 110 €-273.1(2)
+110 Criminal Law
+110XV Pleas
+110k272 Plea of Guilty
+110k273.1 Voluntary Character
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F...
+
+
+
+[4] Senteneing and Punishment 350H €-906
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(G) Dual or Duplicative Use
+350Hk903 Particular Cases and Problems
+350Hk906 k. Adjustments. Most Cited
+Cases
+Imposition of five-level enhancement for engaging
+in a pattern of activity involving prohibited sexual
+conduct, after imposition of three-level enhancement for exploiting more than one minor, for defendant convicted of sexual exploitation of a child
+and possession of child pornography was not impermissible double counting; separate adjustments
+for the number of minors exploited and for the fact
+that those minors were exploited on multiple occasions were not premised on the same conduct.
+U.S.S.G. §§ 2G2.1(d)(1), 4B1.5(b)(1), 18 U.S.C.A.
+[5] Criminal Law 110 €-1139
+110 Criminal Law
+110XXIV Review
+110XXIV(L) Scope of Review in General
+110k1139 k. Additional Proofs and Trial
+De Novo. Most Cited Cases
+The Court of Appeals reviews de novo whether the
+district court's application of the sentencing
+guidelines amounts to impermissible double counting.
+[6] Sentencing and Punishment 350H €-902
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(G) Dual or Duplicative Use
+350Hk902 k. Factor Taken Into Account
+by Guidelines in General. Most Cited Cases
+Double counting occurs when one part of the
+Guidelines is applied to increase a defendant's punishment on account of a kind of harm that has
+already been accounted for by application of another part of the Guidelines; such double counting is
+permissible where the Sentencing Commission intended the result and each statutory section con-
+Cerningonceptually separate notions related to sen-
+[7] Senteneing and Punishment 350H €-645
+350H Sentencing and Punishment
+350HIII Sentence on Conviction of Different
+Charges
+350HIII(D) Disposition
+350Hk645 k. Total Sentence Deemed Not
+Excessive. Most Cited Cases
+Sentence of 420 months' imprisonment imposed on
+defendant convicted of sexual exploitation of a
+child, possession of child pornography, and distribution of cocaine was not unreasonable, where
+" contezed
+court considered the statutory sentencing factors,
+sentence was within the guidelines range, death of
+one of the victims who defendant described as his
+"girlfriend" did not call for leniency, and court did
+consider the letters submitted on defendant's behalf.
+18 U.S.C.A. § 3553(a).
+[8] Criminal Law 110 €-1147
+110 Criminal Law
+110XXIV Review
+110XXIV(N) Discretion of Lower Court
+110k1147 k. In General. Most Cited Cases
+Sentencing and Punishment 350H €-651
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(A) In General
+350Hk651 k. Operation and Effect of
+Guidelines in General. Most Cited Cases
+The Court of Appeals reviews a sentence for reas-
+19) Criminal Law 110 €-1144.17
+'o xxil Review
+110XXIV(M) Presumptions
+110k1144 Facts or Proceedings Not
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F... 2/27/2008
+
+
+
+Shown by Record
+110k1144.17 k. Judgment, Sentence,
+and Punishment. Most Cited Cases
+Although a sentence within the applicable
+guidelines sentencing range is presumed reasonable, the presumption may be rebutted by reference
+to the statutory sentencing factors. 18 U.S.C.A. §
+3553(a).
+[10] Senteneing and Punishment 350H €-651
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(A) In General
+350Hk651 k. Operation and Effect of
+Guidelines in General. Most Cited Cases
+A defendant must show that the district court failed
+to consider a relevant factor that should have received significant weight, gave significant weight
+to an improper or irelevant factor, or considered
+only appropriate factors but nevertheless committed
+a clear error of judgment, in order for his sentence
+within the guidelines range to be considered unreasonable.
+[11] Sentencing and Punishment 350H €-373
+350H Sentencing and Punishment
+350HII Sentencing Proceedings in General
+350HII(G) Hearing
+350Hk369 Findings and Statement of
+Reasons
+350HK373 k. Sufliciency. Most Cited
+While the district court is not required to mechanically recite each of the statutory sentencing factors,
+it must be clear from the record that it actually considered them in determining the appropriate sentence. 18 U.S.C.A. § 3553(a).
+*886 Anne M. Laverty, argued, Cedar Rapids, IA,
+for appellant.
+Charles J. Williams, AUSA, argued, Sean R. Berry,
+AUSA, on the brief, Cedar Rapids, IÁ, for appellee.
+Before MELLOY, SMITH and GRUENDER, Circuit Judges.
+GRUENDER, Circuit Judge.
+Pursuant to two plea agreements, Nicholas
+Peck pled guilty to one count of sexual exploitation
+of a child, in violation of 18 U.S.C. § 2251(a), one
+count of possession of child pornography, in violation of 18 U.S.C. § 2252A(a), and one count of distribution of cocaine, in violation of 21 U.S.C. §
+841(a)(I). The district court PNI sentenced *887
+Peck to 420 months' imprisonment. Peck appeals
+his sentence, arguing that the Government breached
+one of the plea agreements, that the district court
+erred in applying two enhancements under the
+United States Sentencing Guidelines, and that his
+sentence is unreasonable. We affirm.
+FN1. The Honorable Linda R. Reade,
+Chief Judge, United States District Court
+for the Northern District of lowa.
+I. BACKGROUND
+S.L., a fifteen-year-old girl, reported to lowa
+law enforcement authorities that Peck, a twentyfour-year-old man, was involved in trafficking controlled substances from Illinois to Wisconsin and
+Iowa. S.L. also reported that Peck had a laptop
+computer containing pornographic images of her
+and another minor girl and that Peck had engaged
+in sex acts with her on six occasions in Iowa and on
+one occasion in Wisconsin. S.L. also informed the
+authorities he had given her cocaine.
+While driving in Iowa, Peck was pulled over
+and arrested on an outstanding warrant. During his
+post-arrest interview, Peck admitted that his computer contained pictures of S.L.'s genitalia and pictures of a male having sex with S.L. Peck falsely
+denied he was the male pictured having sex with
+S.L. and also falsely denied that he took the pornographic pictures. Peck admitted he also possessed
+pornographic pictures of J.C., another fifteenyear-old girl, with whom he admitted to having sex.
+During the search of Peck's vehicle, authorities
+seized the following items: a laptop computer, two
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prf=HTMLE&fn=_top&mt=F. 2/27/2008
+
+
+
+digital cameras, various electronic storage devices
+including compact dises, a hollowed out pen containing a white powdery residue, a digital scale
+with a white powdery residue, and a plastic baggie
+containing several pills. The compact dises revealed
+digital still and video images of Peck engaged in
+separate sexual acts with S.L., J.C., and another
+minor, K.V. At least one of the images depicted
+Peck having sexual intercourse with K.V., and several depicted Peck engaging in sexual acts with J.C.
+and displayed J.C.'s genitalia.
+Following his arrest and release, Peck twice
+sold cocaine to a confidential informant, again resulting in his arrest. In this post-arrest interview,
+Peck admitted that he took the pornographic images
+of S.L. found on his laptop computer and admitted
+that he knew S.L. was fifteen years old when the
+pictures were taken. He also admitted that he took
+nude pictures of
+knowing that she was either
+fourteen or fifteen years old.
+Peck was indicted in the Northern District of
+Iowa and charged with one count of sexual exploitation of' a child, in violation of 18 U.S.C. § 2251(a),
+and one count of possession of child pornography,
+in violation of 18 U.S.C. § 2252A(a). Peck pled
+guilty to these charges pursuant to a plea agreement
+("first plea agreement"). Peck was subsequently indicted
+in the Western District of Wisconsin and
+charged with one count of distribution of cocaine,
+in violation of 21 U.S.C. § 841(a)(1). The drug
+charge was transferred pursuant to Rule 20 of the
+Federal Rules of Criminal Procedure to the Northern District of lowa, where Peck pled guilty pursuant to a second plea agreement. The two cases were
+then consolidated for sentencing.
+Page 4
+formation now in [its] possession." Paragraph five
+of the plea agreement stated that, in imposing sentence:
+[T]he court will ... consider the kinds of sentence and the sentencing range established by the
+United States Sentencing Guidelines for the applicable category of offense(s) committed by defendant
+and will consider any pertinent policy statements
+issued as part of the *888 Guidelines. The court
+will consider relevant adjustments under the United
+States Sentencing Guidelines, which will include a
+review of such things as the defendant's role in the
+offense, his criminal history, his acceptance or lack
+of acceptance of responsibility and other considerations. The court may also consider other information including any information concerning the
+background, character, and conduct of the defendant.
+Paragraph seven provided: The defendant, his
+attorney and the United States may make whatever
+comment and evidentiary offer they deem appropriate at the time of the guilty plea, sentencing or any
+other proceeding related to this case, so long as the
+offer or comment does not violate any other provision of this agreement. The parties are also free to
+provide all relevant information to the probation office for use in preparing the presentence report.
+Finally, the first plea agreement contained no
+stipulation or recommendation whatsoever regarding the advisory sentencing guidelines, and it expressly noted that it "did not result in any express
+or implied promise or guarantee concerning the actual sentence to be imposed by the court."
+In accord with paragraph seven of the first plea
+agreement, the Government provided an offense
+conduct statement regarding the exploitation and
+pornography charges to the United States Probation
+Office and to Peck. In that statement, the Government stated its
+belief that Peck's advisory
+guidelines calculation should be enhanced three
+teeo puse inv o ed exploia on or the separase
+minors, and also enhanced five levels pursuant to
+U.S.S.G. § 4B1.5(b)(1), because Peck engaged in a
+pattern of activity involving prohibited sexual
+activity. The presentence investigation report subsequently prepared by the probation office accounted for this conduct and also recommended the en-
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft-HTMLE&fn=_top&mt=F...
+
+
+
+hancements.
+At sentencing, the district court applied the enhancements pursuant to § 2G2.1(d)(1) and §
+4B1.5(b)(1), giving Peck a total guideline offense
+level of 42. The district court calculated Peck's
+criminal history as a category III, which resulted in
+a final advisory sentencing guideline range of 360
+months to life in prison. The district court sentenced Peck to 240 months' imprisonment on the
+drug charge and 360 months' imprisonment on the
+sexual exploitation charge, to be served concurrently. The district court also sentenced Peck to 60
+months on the pornography charge, to run consecutively to the other sentence, for a final sentence of
+420 months' imprisonment. Peck filed a timely notice of appeal.
+Page 5
+II. DISCUSSION
+A. Plea Agreement
+[1][2]3] Peck argues
+that the Government
+breached paragraph three of the first plea agreement, but he concedes that our review of this issue
+is for plain error because he did not present this argument to the district court. We can correct an error
+not raised before the district court if there is "(1) errights" United Statesn Rice, 449 F.3d 887, 894
+Rice, 449 F.3d 887, 894
+(8th Cir.), cert. denied,--- U.S. ..., 127 S.Ct. 601,
+166 L.Ed.2d 446 (2006) (quotation omitted). "We
+will reverse under plain error review only if the error prejudices the party's substantial rights and
+vould result in a miscarrage of justice if lett un
+orrected." United States • McCourt, 468 F.3c
+1088, 1093 (8th Cir.2006), cert. denied,--- U.S. ....,
+127 S.Ct. 1866, 167 L.Ed.2d 356 (2007) (quotation
+omitted).
+*889 Paragraph three of the first plea agreement has not filed any new indictment or information officially charging him with additional crimes,
+arguing instead that the Government "effectively
+filed additional charges when it advocated, after the
+execution of the plea agreement, [for] sentencing
+enhancements"
+pursuant
+to
+U.S.S.G.
+2G2.1(d)(1) and 4B1.5(b)(1). We disagree.
+Peck cites no case, and our research has not revealed one, that supports the proposition that the
+Government's pursuit of sentencing enhancements
+reaches a promise not to file additional crimina
+harges. The case cited by Peck, United States 1
+Clark, 55 F.3d 9 (Ist Cir.1995), is inapposite. In
+Clark, the Government agreed not to oppose a
+three-level downward departure for acceptance of
+memorandum it submitted to the district court, the Government made its position clear that no reduction
+was warranted, adding that it could not present "a
+more vigorous argument" because of the plea
+agreement. Id. The First Circuit held that although
+the Government did not formally oppose the reduction, it effectively opposed it in the memorandum.
+Id. Clark has no bearing on the present scenario.
+Unlike formally opposing a downward departure,
+which may be done "effectively" by other informal
+means such as in a memorandum, there is no way to
+file criminal charges "effectively." They are cither
+filed or they are not. Here, the Government filed no
+additional charges, and Peck concedes as much.
+Peck also cites United States | Fowler, 445
+F.3d 1035 (8th Cir.2006), and United States 1
+DeWitt, 366 F.3d 667 (8th Cir.2004). In Fowler, we
+held that the Government breached a plea agreement by actively advocating
+for career-offender
+status where the plea agreement specifically stipulated to an offense level that did not account for
+such status. Fowler, 445 F.3d at 1037. Likewise, in
+that the drug quantity and corresponding base offense level should be higher. DeWitt, 366 F.3d at
+sion." Peck concedes-as he must-that the Govern-
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F... 2/27/2008
+
+
+
+670.
+In contrast to the plea agreements in Fowler
+and DeWitt, the plea agreement in this case does
+not contain any provision whatsoever regarding the
+advisory guidelines calculations. It does contain
+general language, not present in the plea agreements in Fowler and DeWitt, that expressly permits
+the Government to "provide all relevant information to the probation office for use in preparing the
+resentence report." Peck's case, therefare, is mor
+kin to our decision in United States Stobaug
+420 F.3d 796 (8th Cir.2005), cert. denied,546 U.S.
+1120, 126 S.Ct. 1093, 163 L.Ed.2d 908 (2006). In
+Stobaugh, the plea agreement specified certain
+guidelines calculations but also stated that the calculations
+"are only estimates and do not bind the
+parties." Id. at 801. The agreement also contained a
+provision stating "that information about "the entirety of the defendant's criminal activities' would
+be provided to the district court and would 'not [be]
+limited to the count to which the defendant pled
+guilty.' " Id. Noting that the plea agreement did not
+contain a more specific provision like that in
+DeWitt that conflicted with the Government's general authority under the plea agreement to present
+evidence of relevant conduct, we held that there
+was no breach. Id. at 800-01 (citing DeWitt ).
+*890 As in Stobaugh, Peck's plea agreement
+lacks a specific provision that conflicts with the
+general provision granting the Government express
+authority to "provide all relevant information to the
+probation office for use in preparing the presentence report." Absent a conflicting provision, Peck
+cannot successfully challenge the Government's decision to present to the probation office and to the
+paragraph seven of the first plea agreement. Therefore, because the Government did not file addition-
+Page 6
+injustice left uncorrected. See Rice, 449 F.3d at 894.
+B. Double Counting
+[4][5] The district court amalied sentencing enhancements pursuant to
+§5 2G2.1(d)(1)
+and 4B1.5(b)(1). Peck does not dispute that his
+conduct qualifies him for these enhancements.
+Rather, Peck contends that the five-level increase to
+his sentence pursuant to § 4B1.5(b)(1) impermissfails to survive our plain error review because
+without an identified error there is no substantial
+trict court's application of the sentencing guidelines
+amounts to impermissible double counting. United
+States | Kiel, 454 F.3d 819, 822 (8th Cir.2006).
+[6] "Double counting occurs when one part of
+the Guidelines is applied to increase a defendant's
+punishment on account of a kind of harm that has
+ready been ... accounted for by application of a
+ther part of the Guidelines." United States
+Jones, 440 F.3d 927, 929 (8th Cir.), cert. denied,--.
+U.S. -., 127 S.Ct. 130, 166 L.Ed.2d 95 (2006)
+(quotations omitted). Such double counting is permissible where "(1) the [Sentencing] Commission
+intended the result and (2) each statutory section
+contencin con United Sateara l
+notions related to
+sentencing." United States
+Hipenbecker, 115
+F.3d 581, 583 (8th Cir.1997).
+Section 2G2.1(d)(1) states: "If the offense involved the exploitation of more than one minor,
+Chapter Three, Part D (Multiple Counts) shall be
+applied as if the exploitation of each minor had
+been contained in a separate count of conviction."
+BEELE
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F... 2/27/2008
+
+
+
+Section 4B1.5(b)(1) states: "In any case in
+which the defendant's instant offense of conviction
+is a covered sex crime ... and the defendant engaged
+in a pattern of activity involving prohibited sexual
+conduct: (1) The offense level shall be 5 plus the
+offense level determined under Chapters Two and
+Three...." Peck does not dispute that his conviction
+for production of child pornography in violation of
+18 U.S.C. § 2251(a) constitutes a "covered sex
+crime" and is "prohibited sexual conduct." A
+"pattern of activity" for the purposes of §
+4B1.5(b)(1) occurs when the defendant engages in
+the prohibited sexual conduct with a minor on at
+least two separate occasions. U.S.S.G. § 4B1.5 ,
+cmt. n. 4(B)(i). Peck also does not dispute that he
+engaged in prohibited sexual conduct with minor
+children on at least two separate occasions, thus
+constituting a pattern of activity involving prohibited sexual conduct.
+*891 Peck contends that the district court's imposition of a five-level increase pursuant to §
+4B1.5(b)(1) for engaging in a "pattern of activity"
+after the imposition of a three-level, multiple-victim enhancement under § 2G2.1(d)(1) constitutes
+impermissible double counting because both enhancements are premised upon the same conductnamely, his sexual exploitation of each of the three
+minor children. Peck's characterization of the targeted harm is too broad.
+The application of § 2G2.1(d)(1) punished
+Peck for exploiting three different minors, while the
+§ 4B1.5(b)(1) enhancement punished him for exploiting those.
+minors on multiple occasions. See
+United States | Schmeilski, 408 F.3d 917, 920 (7th
+Cir.2005) (holding that the application of both §
+2G2.1(d)(1) and § 4B1.5(b)(1) does not constitute
+impermissible double counting). As such, the separate enhancements for the number of minors Peck
+exploited and for the fact that Peck exploited the
+minors on multiple occasions are not premised on
+the same harm. See id.(noting that for a defendant
+who had on only one occasion photographed three
+minor children engaging in sexually explicit con-
+Page 7
+duct, § 2G2.1(d)(1) would apply because more than
+one minor was exploited but § 4B1.5(b)(1) would
+not because prohibited sexual conduct did not occur
+on at least two separate occasions). Therefore, because § 2G2.1(d)(1) and § 4B1.5(b)(1) do not address the same kind of harm, the application of both
+in calculating Peck's sentence did not constitute
+double counting under these circumstances.
+C. Peck's Sentence
+7][8] "We review appellaris sentence for
+reasonableness." United States
+| Cadenas, 44.
+F.3d 1091, 1094 (8th Cir.2006). "In doing so we,
+like the district court, begin with the applicable
+guidelines
+sentencing
+range." Id. The Supreme
+Court recently held that "a court of appeals may apply a presumption of reasonableness to a district
+the Senteneing Guidelies" Ripoler nited States. -
+he Sentencing Guidelines.
+.. U.S. ...., 127 S.Ct. 2456, 2462, 168 L.Ed.2d 203
+(2007). Because the district court properly calculated the advisory sentencing guidelines range for
+Peck, and because it sentenced Peck within that
+range, Peck's sentence is cloaked in a presumption
+of reasonableness. See id.
+[9][10][11] However, this presumption may be
+rebutted by reference to
+the factors listed in
+18
+U.S.C. § 3553(a). Cadenas, 445 F.3d at 1094,see
+also United States | Harris, 493 F.3d 928, 932-33
+(8th Cir.2007). In other words, Peck must show that
+the "district court failed to consider a relevant
+factor that should have received significant weight,
+gave significant weight to an improper or irelevant
+factor, or considered only appropriate factors but
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F... 2/27/2008
+
+
+
+Peck concedes that the facts considered by the
+district court in reaching his sentence were
+"doubtless 'relevant' under 18 U.S.C. § 3553(a),"
+and he instead argues that "[g]iven the maximum
+sentence permitted by law on the most serious
+count, [sexual exploitation of a minor], is thirty
+years, it is reasonable to conclude that a sentence at
+the bottom of the 360 to life range might be appropriate." While this argument may explain why a
+different sentence would be reasonable, it fails to
+explain*892 why the within-guidelines-range senfeates l receind 446 read able, 13l0 ied
+Cir.2006) (noting that "there is a range of reasonableness available to the district court in any given
+case"). Further, to the extent that this argument suggests that the district court should have run his sentence on the possession of child pornography
+charge concurrently rather than consecutively, we
+find it to be without merit. The district court's decision to run Peck's sentences consecutively is authorized under the guidelines and is proper under
+this circuit's case law. SeeU.S.S.G. § SG1.2(d) ("If
+the sentence imposed on the count carrying the
+Page 8
+their 'consent' is of no significance.") (quotation
+omitted).
+Peck also contends that the district court did
+not consider facts in his background that call for leniency, such as the death of his girlfriend and let
+ters submitted to the district court on his behall
+First, the girl Peck claims was his "girlfriend" was
+actually one of the minor victims he sexually exploited. Her death, though tragic, does not call for
+leniency vis-a-vis Peck. Second, the record reveals
+that the district court did consider the letters submitted on Peck's behalf, and nothing in the record
+demonstrates that they were given inappropriate
+weight.
+Peck's arguments are without merit in that they
+fail to demonstrate that the district court's sentence
+was unreasonable. The district court made a clear
+record of the sentencing factors relevant under §
+3553(a), and our review of it shows that the district
+court considered them, weighed them properly and
+did not commit a clear error of judgment in arriving
+at Peck's sentence, which was within the range of
+choice dictated by the facts of the case. Accordingly, Peck's sentence was not unreasonable. See
+Harris, 493 F.3d at 932-33; Cadenas, 445 F.3d at
+1094.
+but only to the extent necessary to produce a combined sentence.
+binted Snites y hamas 4h34 otad p42, 546 (7
+Cir.2007).
+"apparently may have even thought of [Peck] as
+their boyfriend," there was no evidence to support
+the district court's conclusion that Peck "preyed
+upon" teenage girls for sexual relations. We reject
+Peck's argument and note that the district court's
+onclusion regarding Peck's conduct i
+supported
+United States Abad, 35(
+III. CONCLUSION
+For the foregoing reasons, we affirm Peck's
+sentence.
+C.A.8 (Iowa),2007.
+U.S. | Peck
+these cases, because of ignorance or deceit, do not
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prfl=HTMLE&fn=_top&mt=F... 2/27/2008
+
+
+
+Westlaw:
+H
+U.S. |. Denkler
+C.A.4 (N.C.),2007.
+This case was not selected for publication in the
+Federal Reporter.Not for Publication in West's Federal Reporter See Fed. Rule of Appellate Procedure
+32.1 generally governing citation of judicial decisions issued on or after Jan. 1, 2007. See also
+Fourth Circuit Rule 32.1 (Find CTA4 Rule 32.1)
+United States Court of Appeals, Fourth Circuit.
+UNITED STATES of America, Plaintiff-Appellee,
+Phillip Daniel DENKLER, ak/a George Austin,
+Defendant-Appellant.
+No. 06-4781.
+Submitted: March 7, 2007.
+Decided: July 10, 2007.
+Background: Defendant pled guilty in the
+United States District Court for the Eastern District
+of North Carolina, at Raleigh, James C. Dever, III,
+J., to interstate transportation of a minor with intent
+to engage in criminal sexual activity and interstate
+transportation of a stolen vehicle, for which he was
+sentenced to respective terms of 360 months and
+120 months. Defendant appealed.
+Holdings: The Court of Appeals held that:
+(1) victim's out-of-court statements to investigators had sufficient indicia of reliability to render
+them admissible for sentencing purposes, and
+(2) guidelines departure was reasonable in light
+of defendant's criminal history and likelihood of recidivism.
+Affirmed.
+West Headnotes
+[1] Sentencing and Punishment 350H €-967
+350H Sentencing and Punishment
+350HIV Senteneing Guidelines
+350HIV(H) Proceedings
+350HIV(H)2 Evidence
+350Hk967 k. Hearsay. Most Cited Cases
+Victim's out-of-court statements to investigators
+had suficient indicia of reliability to render them
+admissible for sentencing purposes, for determination of whether imposition of enhancement for using threats and force to engage in sex with victim
+was warranted, in prosecution for interstate transportation of a minor with intent to engage in criminal sexual activity; victim submitted willingly to a
+medical examination and to interviews by local and
+federal authorities, and acknowledged that she had
+engaged in text messaging with other men, and her
+statement to the agent was consistent with her previous statement to local police. 18 U.S.C.A. §
+2423(a); U.S.S.G. § 6A1.3(a), p.s. 18 U.S.C.A.
+[2] Sentencing and Punishment 350H €-841
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(F) Departures
+350HIV(F)2 Upward Departures
+350Hk841 k. Inadequacy of Criminal
+History Category. Most Cited Cases
+District court acted reasonably both with respect to
+its decision to impose departure sentence and with
+respect to the extent of the divergence from the
+range, upon finding that defendant's criminal history category substantially underrepresented his
+criminal history and the likelihood of recidivism,
+for sentencing on conviction for interstate trans-
+ELER
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F... 2/27/2008
+
+
+
+*337 Appeal from the United States District Court
+for the Eastern District of North Carolina, at
+Raleigh. James C. Dever, III, District Judge.
+(5:05-cr-00264-D).
+Tevon L. Donalae, Assistant ederal Pbie der
+fender, Raleigh, North Carolina, for Appellant.
+States Attorneys, Raleigh, North Carolina, for Ap-
+pellee.
+Before WILLIAMS, Chief Judge, and KING and
+SHEDD, Circuit Judges.
+Afirmed by unpublished PER CURIAM opinion.
+Unpublished opinions are not binding precedent in
+this circuit PER CURIAM:
+**1 Phillip Daniel Denkler pled guilty to interstate transportation of a minor with intent to engage
+in criminal sexual activity, 18 U.S.C.A. § 2423(a)
+(West Supp.2006) (Count One), and
+transportation of a stolen vehicle, 18 U.S.C. § 2312
+(2000) (Count Two). He received a sentence of 360
+months imprisonment on Count One and a concurrent sentence of 120 months on Count Two. Denkler appeals his sentence, arguing that (1) the district
+court erred in considering the victim's statement to
+a federal agent because it lacked sufficient indicia
+of reliability to support certain fact findings that affected the sentence, see U.S. Sentencing Guidelines
+Manual § 6A1.3(a), p.s. (2005); (2) the district
+court clearly erred in finding that the victim's ability to appraise or control the situation was substantially impaired after Denkler gave her vodka to
+drink, USSG § 2G1.3, comment. (n.5 (B)(D); and
+(3) the district court abused its discretion by depart-
+225E
+In August 2005, after serving an eight-month
+istodial sentence for taking indecent liberties wi
+thirteen-year-old girl, and then violating prob
+tion, Denkler began serving six months electronic
+house arrest in Rocky Mount, North Carolina.
+Within a few days, using the name "George," he
+had somehow come in contact by telephone with a
+twelve-year-old girl, who told Denkler she wanted
+to leave home. On August 25, 2005, driving a car
+he had stolen from a former roommate, and in possession of a credit card stolen from his mother,
+Denkler picked up the victim.
+On August 30, 2005, Denkler left the victim at
+a bus station in Des Moines after helping her call
+her grandparents from there. The victim told her
+grandparents that "George" had forced her to have
+intercourse multiple times. At a local hospital, the
+victim described the sexual contacts she had with
+Denkler to local authorities and a Federal Bureau of
+Investigation (FBI) agent, and identified him from a
+photographic line-up.
+She told investigators that
+Denkler had threatened to kill her if she did not
+have sex with him, and when she refused to perform oral sex on him, he choked her until she
+nearly passed out to make her comply. The victim
+said Denkler refused to let her call her grandparents
+during *338 the trip. She told the FBI agent that
+Denkler slapped her and pulled her hair and made
+her drink a glass of vodka. She also said Denkler
+told her that, if he went to jail because of her, he
+would kill her when he got out, and that he would
+kill her if she was pregnant with his child and had
+an abortion or gave up the child.
+The results of the medical examination were
+not made available to the investigators or, later, to
+the court, and investigators were not able to obtain
+independent evidence that Denkler used force or
+threats with the victim because she had showered
+and had been swimming since the last time she and
+enkler had intercourse, and the motel room whe
+e last intercourse occurred had been cleane
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F.. 2/27/2008
+
+
+
+they had drunk vodka together, after which the victim got "wild" and they had intercourse.
+After Denkler's guilty plea, the probation officer calculated the offense level for the sex offense
+under U.S. Sentencing Guidelines Manual § 2G1.3
+(2005) (Transportation of Minors to Engage in Prohibited Sexual Contact with a Minor). Denkler had
+9 criminal history points, which placed him in criminal history category IV. However, because he qualified for sentencing as a repeat and dangerous sex
+ffender against minors, seeUSSG § 481.5 , he wa
+laced in criminal history category . The recom
+mended advisory guideline range was 168-210
+months imprisonment.
+scribed in 18 U.S.C.A. § 2241(a) or (b) (West 2000
+& Supp.2006), to USSG 2A3.1 (Criminal Sexual
+Abuse). The court determined that the cross reference applied because it found as a fact that Denkler
+used force to engage in sexual conduct with the vietim, see§ 2G1.3, comment. (n.5(B)(i)(I)), and also
+forced her to drink vodka, which substantially impaired her ability to appraise or control her conduct,
+see id.(n.5 (B)(i)(IV)). The offense level calculated
+under § 2A3.1 produced a higher offense level than
+§ 2G1.3 or USSG § 4B1.5 (Repeat and Dangerous
+Sex Offender Against Minors); accordingly, the
+court applied it.
+At sentencing, after the FBI agent who interviewed the victim in the hospital in Des Moines
+testified, the district court found as a fact that Denkler had used force to engage in sexual conduct
+with the victim. The court consequently determined
+that § 2A3.1 applied and recalculated the guideline
+range as 262-327 months. The court then departed
+a concurrent 120-month sentence (the statutory
+laximum) on Count Iwo. Alternatively, the cou
+lated that, "even if category were the appropr:
+ate criminal history category, the court would sentence Denkler, pursuant to a variance, to the same
+sentence of 360 months for Count One and 120
+months for Count Two, to run concurrently," because his threats to kill the victim if he went to jail
+or if she became pregnant and aborted or gave up
+the child increased the seriousness of the offense
+and were not accounted for in the offense level.
+[1] On appeal, Denkler first challenges the district court's application of § 2A3.1*339 on the
+ground that the district court erred in relying on information that lacked sufficient indicia of reliability
+when it determined that he used threats and force to
+engage in sex with the victim. Policy statement §
+6A1.3(a) provides that, in resolving disputes about
+sentencing factors, the district court "may consider
+relevant information without regard to its admissibility under the rules of evidence applicable at trial,
+provided that the information has suficient indicia
+of reliability to support its probable accuracy."
+**3 Denkler first contends that allowing senencing courts to rely on hearsay violates the Sixt
+Amendment, citing Crawford Washington, 54
+U.S. 36, 124 S.Ct. 1354, 158 L.Ed.2d 177 (2004)
+(addressing right of confrontation at trial), but concedes that other circuits have held that Crawford
+United States Chau,
+, to sentencing hearings. See, e.g..
+426 F.3d 1318, 1323 (1lt)
+Cir.2005). Denkler principally argues that the district court should not have relied on the victim's
+statements to investigators, asserting that she
+wished to portray herself in a sympathetic light to
+her etanhpcansed thed to plece the blame for the
+sidering the factors set out in 18 U.S.C.A. §
+3553(a) (West 2000 & Supp.2006), the court imposed a sentence of 360 months on Count One and
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F.. 2/27/2008
+
+
+
+thong panties, black lace panties, and a sleeveless
+shirt with the phrase "no boundaries" on it. Denkler
+also argues that the court ignored the fact that the
+medical examination of the victim revealed no indication of forcible intercourse, bruises, or serious
+injuries. He points out that the medical examination
+form states that the victim answered "Yes," when
+asked whether she had "any consensual coitus in
+the previous 72 hours." With respect to this question, the FBI agent who interviewed the victim testified at sentencing that the doctor who filled out the
+form told her the question was meant to determine
+whether there had been recent sexual activity, not
+whether it had actually been consensual. The agent
+also testified that the victim was cooperative with
+her and with the hospital staff, and was "very honest and very credible."
+Even though authorities were unable to find
+evidence to substantiate the victim's statements, we
+conclude that her statements had sufficient indicia
+of reliability to support their probable accuracy.
+She submitted willingly to a medical examination
+and to interviews by local and federal authorities,
+and acknowledged that she had engaged in text
+messaging with other men. Her statement to the
+FBI agent was consistent with her previous statement to local police. Therefore, the district court
+did not err in relying on her statements.
+Denkler also contends that the district court
+clearly erred in finding that the victim's ability to
+appraise or control the situation was substantially
+impaired after she drank alcohol because the court
+lacked the information necessary to reach that conclusion. We need not decide this issue because the
+district court's finding that Denkler used force
+against the victim to engage in sex with her was
+supported by the victim's statement and that finding
+is sufficient to trigger the application of § 2A3.1.
+[2] Finally, Denkler maintains that the district
+court abused its discretion it
+, departing upward
+from criminal history category to category VI. In
+his view, the guideline sentence adequately accounted for his past criminal conduct and the court de-
+Page 4
+parted merely because it was dissatisfied with the
+length of the guideline sentence.*340 Denkler does
+not challenge the court's determination that a departure was also warranted based on the high likelihood of recidivism.
+**4 Following United States | Booker, 543
+U.S. 220, 125 S.Ct. 738, 160 L.Ed.2d 621 (2005),
+we review a sentence for reasonableness. United
+States | Hernandez-Villanueva, 473 F.3d 118, 123
+(4th Cir.2007). "When we review a sentence outside advisory sentencing range-whether as
+product of a departure or a variance-we consider
+whether the sentencing court acted reasonably both
+• Fom tie raget he tl a depane pil
+to § 4A1.3 is encouraged, provided that the criminal history category does not account adequately for
+his past criminal conduct or the likelihood that he
+will commit other crimes. United States
+Dixon,
+318 F.3d 585, 588 (4th Cir.2003).
+Here, the distict court decided that criminal
+history category
+substantially underrepresented
+Denkler's criminal history, even though the application of § 4B1.5 had already raised him from category IV to category . First, the court noted that
+Denkler was prosecuted in the juvenile court system in Kentucky for stealing his father's car. This
+finding is based solely on a statement to investigators by Denkler's estranged father that is contained
+in the presentence report. Although Denkler did not
+dispute it, no official record of the charge and its
+disposition was available. The court decided that
+the offense was similar to Count Two, transportation of a stolen vehicle, and that it could consider
+LEAH
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F... 2/27/2008
+
+
+
+Second, the district court considered the fact
+that Denkler had previously been charged with statutory rape (for which the court estimated he would
+have received a custodial sentence of at least 192
+months), was permitted to plead guilty to a lesser
+offense, served a short custodial sentence, violated
+his probation and then, after being placed on house
+arrest, absconded to engage in the criminal conduct
+that resulted in his current prosecution. The background commentary to § 4A1.3 suggests that a defendant who has a history of serious offenses for
+which he has received very lenient sentences may
+be in a category that underrepresents his criminal
+history. The court found that Denkler fit this de-
+Last, the court decided that category did not
+adequately represent the likelihood that Denkler
+would commit similar crimes in the future. The
+court noted that Denkler had been prosecuted for
+sexual intercourse with a thirteen-year-old girl and
+a twelve-year-old girl, and for assaulting another
+female. FNI The court found that Denkler's conduct
+showed that he had no respect for the law and had
+"a strong tendency to revert to grossly inappropriate behavior toward females, particularly young
+girls." The court decided that category VI best represented his criminal history and likelihood of recidivism.
+FN1. Denkler received one criminal history point for a sentence of 30 days custody and 36 months unsupervised probation after he was convicted in 2002 of misdemeanor assault on a female.
+**5 Denkler argues that category adequately
+addressed his criminal history because it took into
+minors, his custodial status when he committed the
+instant *341 offense, and the recency of the prior
+conviction, and he emphasizes that he was awarded
+criminal history points for all his serious adult sentences. Denkler maintains that the court erred in assuming that he would necessarily have been found
+guilty of statutory rape had he gone to trial instead
+Page 5
+of pleading guilty to the lesser offense, and would
+automatically have received a sentence of 192
+months imprisonment. He further maintains that his
+juvenile conviction for stealing his father's car was
+not counted because the sentence and the offense
+were not suficiently serious, and that the district
+court decided otherwise without adequate basis for
+doing so.
+After carefully considering Denkler's arguments, we conclude that the district court's decision
+to depart pursuant to § 4A1.3 was reasonable. Denkler had twice received lenient sentences in state
+court for offenses against females and, rather than
+comply with the conditions of probation, he initiated the instant offense. The district court based its
+decision to
+depart in part on the under-representation of Denkler's past criminal conduct and
+in part on the likelihood that he would commit future crimes. Taking the two factors together, the
+district court could reasonably conclude that an upward departure was warranted.
+We must also consider whether the extent of a
+departure is reasonable. Hernandez-Villanueva,
+473
+F.3d at 123. Here, the court departed upward by
+one category. The
+resulting guideline range was
+292-365 months, and the sentence of 360 months
+(the statutory maximum) was within the departure
+range. The court explained that it chose the maximum sentence in light of several factors set out in §
+3553(a), specifically, "the need to protect the public, to deter this defendant, to reflect the seriousness
+of the offense, and to provide just punishment."
+The court further stated that it imposed a sentence
+at the top of the guideline range because of Denkler's "history of violence and predatory behavior,
+and the court's views on his likelihood to commit
+similar crimes if released earlier."
+prisonment 327 months, or another term of impris-
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F... 2/27/2008
+
+
+
+onment that is less than 360 months, the court reasonably concluded that only the maximum sentence
+was adequate to protect potential victims and punish Denkler for the offenses he committed. We conclude that the length of the sentence was reason-able.
+We therefore affirm the sentence imposed by
+the district court. We dispense with oral argument
+because the facts and legal contentions are adequately presented in the materials before the court
+and argument would not aid the decisional process.
+**6 AFFIRMED.
+C.A.4 (N.C.),2007.
+U.S. |. Denkler
+232 Fed.Appx. 336,
+2007 WL 2012431 (C.A.4
+(N.C.))
+Page 6
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prf=HTMLE&fn=
+_topömt=F... 2/27/2008
+
+
+
+U.S. J. Carter
+C.A.8 (S.D.),2007.
+United States Court of Appeals, Eighth Circuit.
+UNITED STATES of America, Appellee,
+William T. CARTER, Appellant.
+No. 05-4414.
+Submitted: Sept. 26, 2006.
+Filed: June 18, 2007.
+Background: Defendant was convicted of
+sexual abuse of a minor and related crimes, and was
+sentenced to 360 months' imprisonment. The Court
+of Appeals, 410 F.3d 1017, affirmed convictions
+but remanded for resentencing. On remand, the
+United States District Court for the District of
+South Dakota, Charles B. Kormann, J., imposed a
+295-month sentence, and defendant appealed.
+Holdings: The Court of Appeals, Arnold, Circuit Judge, held that:
+(1) defendant forfeited his Ex Post Facto
+Clause argument, and
+suport ofenise lever emade edeni tor indirecti on
+of justice based on perjury.
+Affirmed.
+General
+92k2789 k. Penal Laws in General. Most
+Cited Cases
+Constitutional Law 92 €-2790
+92 Constitutional Law
+92XXIIII Ex Post Facto Prohibitions
+92XXIII(A) Constitutional Prohibitions in
+General
+92k2790 k. Punishment in General. Most
+Cited Cases
+The ex post facto clause is violated when a law defining a crime or increasing punishment for a crime
+is applied to events that occurred before its enactment, to the disadvantage of the offender. U.S.C.A.
+Const. Art. 1, § 9, cl. 3.
+[2] Criminal Law 110 €-1180
+110 Criminal Law
+110XXIV Review
+110XXIV(T) Subsequent Appeals
+110k1180 k. In General. Most Cited Cases
+In defendant's appeal of sentence that was imposed
+for sexual abuse of a minor and related crimes after
+court of appeals remanded his case to district court
+for resentencing, law of the case doctrine did not
+preclude defendant's claim that use of a single, less
+serious offense that occurred after effective date of
+new version of sentencing guidelines as ground for
+application of that version of guidelines in his sentencing for more serious offenses that occurred
+earlier violated Ex Post Facto Clause; although
+court of appeals in opinion remanding case had re-
+Bye, Circuit Judge, filed opinion concurring in part
+and concurring in the judgment.
+West Headnotes
+[1] Constitutional Law 92 €-2789
+92 Constitutional Law
+92XXIII Ex Post Facto Prohibitions
+92XXIII(A) Constitutional Prohibitions in
+[3] Criminal Law 110 €-1042
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F... 2/27/2008
+
+
+
+110 Criminal Law
+110XXIV Review
+110XXIV(E) Presentation and Reservation in
+Lower Court of Grounds of Review
+110XXIV(E)1 In General
+110k1042 k. Sentence or Judgment.
+Most Cited Cases
+Defendant forfeited his argument that district court,
+in resentencing him for sexual abuse of' a minor and
+related offenses, violated Ex Post Facto Clause by
+using a single, less serious offense that occurred
+after effective date of new version of sentencing
+guidelines as ground for application of that version
+of guidelines in his sentencing for more serious offenses that occurred earlier; defendant did not raise
+the issue at his original sentencing, on his appeal of
+that sentence, or at resentencing after remand from
+court of appeals. U.S.C.A. Const. Art. 1, § 9, cl. 3;
+U.S.S.G. § 1B1.11(b)(2), 18 U.S.C.A.
+(4] Senteneing and Punishment 350H €-996
+350H Sentencing and Punishment
+350HIV Sentencing Guidelines
+350HIV(H) Proceedings
+350HIV(H)3 Hearing
+350Hk992 Findings and Statement of
+Reasons
+350Hk996 k. Sufficiency. Most
+In sentencing defendant for sexual abuse of a minor
+and related offenses, district court made adequate
+findings to support application of
+sentencing
+guidelines offense level enhancement for obstruction of justice based on perjury; court stated during
+sentencing hearing that it found that defendant testified falsely as to all diferent sexual assaults, all of
+which was testimony on material matters, and added that the finding was based upon what the court
+saw and heard at trial, and court stated that the
+evidence in defendant's case was as strong as the
+court had seen in any case during nine years on the
+bench and that the court would have found defendant guilty in a bench trial. U.S.S.G. § 3C1.1, 18
+U.S.C.A.
+*642 Counsel who presented argument on behalf of
+the appellant was Jana M. Miner, AFPD, Pierre, SD.
+*643 Counsel who presented argument on behalf of
+the appellee was Mikal G. Hanson, AUSA, Pierre,
+SD.
+Before ARNOLD, BYE, and MELLOY, Circuit
+Judges.
+ARNOLD, Circuit Judge.
+William Carter was originally sentenced to 360
+months in prison after being convicted of sexual abuse of a minor and related crimes. We afirmed his
+remanded for resentencing. See
+United States" reCarter, 400 esed ont ser
+Cir.2005)(Carter | ). After a hearing, the district
+court "NI sentenced Mr. Carter to 295 months' imprisonment. Mr. Carter appeals, contending that the
+district court violated the ex post facto clause of the
+Constitution by imposing an enhancement under
+U.S.S.G. § 4B1.5(b)(1), and that it erred by imposing an obstruction-of-justice enhancement without
+making sufficient factual findings, seeU.S.S.G. §
+3C1.1. We affirm.
+FN1. The Honorable Charles B. Kornmann, United States District Judge for the
+District of South Dakota.
+I.
+[1] We review Mr. Carter's ex post facto claim
+de novo. See United States | Mashek, 406 F.3d
+1012, 1016 (8th Cir.2005). The ex post facto clause
+s violated when a law detining a crime c
+ng punishment for a crime. see Collins | Young
+blood.
+497 U.S. 37, 43,
+110 S.Ct. 2715, 111
+| Florida, 482 U.S. 423, 435-36, 107 S.Ct. 2446
+96 L.Ed.2d 351 (1987), the Supreme Court held
+shad fines chat subiected offenders to onge sene
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F.. 2/27/2008
+
+
+
+tences than they would have received at the time
+the crime was committed, violated the ex post facto
+clause applicable to the states, seeU.S. Const., art.
+I, § 10, cl. 1. And we have held that the ex post
+facto clause applicable to Congress is similarly vilated by retroactive application of a more onerou
+ederal sentencing guideline. United States Bel
+991 F.2d 1445, 1448 (8th Cir.1993); seeU.S. Const.
+art. I, § 9, cl. 3.
+Initially, we note that since the Supreme Court
+decided United States | Booker, 543 U.S. 220, 125
+S.Ct. 738, 160 L.Ed.2d 621(2005), at least one of
+our sister circuits has held that the ex post facto
+clause does not apply to the now-advisory
+guidelines. See United States || Demaree, 459 F.3d
+791, 794 (7th Cir.2006), petition for cert. filed,No.
+States U.s. Dec. I1, 2006); see also United
+Barton, 455 F.3d 649, 655 m. 4 (6th
+Cir.2006). But in a case decided after Booker, we
+"recognize[d] that 'retrospective application of the
+Guidelines implicates the ex post facto clause,' "
+though we took into account post-offense amendments to the guidelines when determining the overall reasonableness of the defendant's
+United States | Larrabee, 436 F.3d 890, 894 (8th
+Cir.2006) (quoting Bell, 991 F.2d at 1448). Given
+our decision in Larrabee, we will proceed to address Mr. Carter's ex post facto claim.
+The guidelines themselves refer to the ex post
+facto clause: under U.S.S.G. § 1B1.11(a) and
+(b)(1), courts are directed to apply the version of
+the guidelines in effect on the date of sentencing
+unless to do so would violate the ex post facto
+clause, in which case the guidelines in effect on the
+date of the crime should be used. The so called onebook rule requires*644 that the "Guidelines Manual
+in effect on a particular date be applied in its entirety." U.S.S.G. § 1B1.11(b)(2). And the
+guidelines specify that "[i]f the defendant is convicted of two offenses, the first committed before,
+and the second after, a revised edition of the
+Guidelines Manual became effective, the revised
+edition of the Guidelines Manual is to be applied to
+both offenses." U.S.S.G. § 1B1.11(b)(3).
+[2] In this appeal, Mr. Carter argues that in his
+case, by applying the one-book rule, seeU.S.S.G. §
+1B1.11(b)(2), and using the date when the last
+crime was committed to determine which edition of
+guidelines
+cf. U.S.S.G.
+1B1.11(b)(3), the district court violated the ex post
+facto clause. According to the defendant, the court
+violated the clause by sentencing him under a version of the guidelines that included U.S.S.G. §
+4B1.5(b)(1),
+an enhancement for repeat sexoffenders that went into effect on November 1,
+2001, seeU.S.S.G. app. C, amend. 615, thereby increasing his offense level and guideline sentencing
+range "for the three most serious pre-November,
+2001 grouped Counts." Mr. Carter argues that even
+if, as we held in Carter I, the evidence supported a
+finding that one of his crimes (Count II) occurred
+after November 1, 2001, he was unconstitutionally
+disadvantaged by the application of § 4B1.5(b)(1)
+to the three more serious crimes that occurred beore that date and could not be grouped with Coun
+I. Cf. United States • Ortland. 109 F.3d 539, 547
+(9th Cir. 1997):
+The government maintains that Mr. Carter's
+claim is precluded by the law-of the-case doctrine
+because of our ruling against him on an ex post
+facto claim in Carter I, 410 F.3d at 1026-27. In
+general, *the law-of-the-case doctrine posits that
+when a court decides upon a rule of law, that desigion enu stageti in toe seme tas sam trisues i1
+California, 460 U.S. 605, 618, 103 S.Ct. 1382,
+L.Ed.2d 318 (1983); see also United States |
+Barish, 69 F.3d 864, 866 (8th Cir.1995).
+At the first sentencing hearing, the district
+court carefully followed the provisions of § 1B1.11.
+The court first rejected the 2003 guidelines manual
+in effect at that time based on ex post facto concerns, see § 1B1.1(a), (b)(1), explaining that the
+then-current manual might produce a higher sentence because it included a new prohibition on
+downward departures for sexual crimes and elimin-
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F... 2/27/2008
+
+
+
+ated a multiple-victim requirement for an enhancement under § 4B1.5(b). Then the court referred to
+the one-book rule, see§ 1B1.11(b)(2), and the need
+to use the guidelines manual in effect when the last
+crime was committed, see§ 1B1.11(b)(3). Following these provisions, the district court applied the
+manual that "went into effect on November 1, 2001,
+in between the defendant's offenses of conviction"
+(though it mistakenly referred to it as the 2002,
+rather than the 2001, manual). The court found generally that "at least one" of Mr. Carter's crimes occurred after § 4B1.5(b)(1) went into effect
+(November 1, 2001), and it also relied on the indictment to determine that Count VII occurred after
+Page 4
+In his first appeal, Mr. Carter maintained in his
+brief that the district court erred by enhancing his
+sentence under § 4B1.5(b)(1)"where the prosecuevidence failed to prove that any
+charged offenses" occurred after that enhancement
+went into effect. He asserted that the "trial testimony did not prove an offense" after that date and
+also contended that the district court should have
+relied on the evidence, rather than the indictment,
+to determine when Count VII occurred. Significantly, Mr. Carter did not challenge the constitutionality of *645§ 1B1.11 (b)(2) or § 1B1.11 (b)(3) ог
+the district court's decision to calculate his sentence
+"one book"
+of sentencing
+guidelines, i.e., the one in effect when his last crime
+was committed. And though he now contends that
+the court should not have relied on the date of a
+lesser crime to increase his sentence for earlier
+more serious crimes that could not be grouped with
+in his first appeal he mentioned
+neither the relative seriousness of the crimes nor
+their groupability. We rejected Mr. Carter's previous ex post facto claim in Carter 1, 410 F.3d at
+1027, because evidence regarding Count II supported the district court's finding that at least one of the
+crimes occurred after November 1, 2001. We noted
+that the victim in Count II, who was a minor at the
+time of the crime, testified that Mr. Carter had
+sexual contact with her in December, 2001, and,
+when pressed on cross-examination, estimated the
+date as "around November 2, 2001." After remand,
+the district judge reiterated that at least one of Mr.
+Carter's crimes occurred after § 4B1.5 went into efect, basing his finding on the "trial testimony ..
+that
+the contact happened around November 2
+2001."
+[3] We agree with Mr. Carter's contention in
+his reply brief that the law-of-the case doctrine does
+not apply because we "did not issue a legal ruling"
+in Carter I addressing whether the ex post facto
+clause "prohibits using a single less serious, later
+offense to justify the retroactive application" of a
+guideline to increase the sentencing range "for
+carlier ungrouped more serious offenses." But we
+did not address the issue because Mr. Carter did not
+raise it, and we conclude that the issue has been
+forfeited.
+Mr. Carter asserts that he did not raise the argument earlier because at the first sentencing the
+district court specifically referred only to Count VII
+and did not mention Count II when deciding to apply the 2001 guidelines. We believe, however, that
+the argument is not dependent on the court mentioning Count II, but is a challenge to the district
+court's determination that the 2001 guidelines applied because at least one crime occurred after
+November 1, 2001. And Mr. Carter's rationale for
+not making his current ex post facto argument is
+particularly unpersuasive because Counts II and VII
+are virtually identical: they both charge Mr. Carter
+with abusive sexual contact with a minor in violation of 18 U.S.C. § 1153, on dates after November
+1, 2001, and neither crime was groupable with the
+earlier more serious offenses, seeU.S.S.G. § 3D1.2
+Caries of wieter the dietict cour velied re.
+Siono the uidlines to sapr determining which ver.-
+the ex pou ei thi apel did Met Ca ap rgio hat
+the 2001 guidelines even if one of his crimes took
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F... 2/27/2008
+
+
+
+place after November 1, 2001. This is not simply a
+case where the defendant appeals an issue that he or
+she dich nees, en ro d 1128, 1130 (8th Cir.2006).
+Here Mr. Carter did not raise this issue at his first
+sentencing, in his appeal from that sentence, or at
+resentencing. We do not permit piecemeal appeals,
+and we choose not to afford Mr. Carter an opportunity (unavailable to other defendants) to raise a
+new issue at this late date merely because his case
+was remanded on other grounds. See United States
+Palmer. 297 F.3d 760. 767 (8th Cir.2002):
+979 F.2d 136, 138 (8th
+Cir.1ed S: United State Fiallo-Jacome, 874 F.20
+1479, 1481-83 (11th Cir.1989). We conclude that
+Mr. Carter has forfeited his *646 current ex post
+facto claim, and thus we decline to address it on the
+merits.
+Page 5
+II.
+[4] Mr. Carter next argues that the district court
+failed to make adequate findings to support an obstruction-of-justice enhancement based on perjury,
+seeU.S.S.G. § 3C1.1. Since Mr. Carter objected to
+the enhancement, the court was required to "review
+the evidence and make independent findings neces-
+" United
+sare so rs buni an, 557 Cis. 87, u55, 11 sict.
+1111, 122 L.Ed.2d 445 (1993). Although it is
+preferable for the court "to address each element of
+the alleged perjury in a separate and clear finding."
+a finding
+"that encompasses all of the factual predicates for a finding of perjury" is suficient. Id.
+We conclude that there is no merit to Mr.
+Carter's contention that the district court did not
+make adequate findings here. The court stated during the sentencing hearing that it found "that Mr.
+Carter ... testified falsely as to all these different
+sexual assaults, all of which was testimony on material matters." The judge added that he was
+"making that finding based upon what I saw and
+heard at trial." At another point, the judge stated
+that the evidence in Mr. Carter's case was "as
+strong as [he'd] seen in any case" during nine years
+on the bench and that he would have found Mr.
+Carter guilty in a bench trial.
+In Dunnigan, the Court concluded that the district court's findings that "the defendant was untruthful at trial with respect to material matters"
+and that the defendant's "failure to give truthful
+testimony on material matters ...were [sic) designed
+to substantially affect the outcome of the case*
+were sufficient to support the enhancement. Id.
+(emphasis in Dunnigan). The district court undoubtedly made independent findings in Mr.
+Carter's case, and we believe that the court's statements are substantially similar to those that we
+lave previously concluded are sutticient. See, e.g.
+/nited States Kessler, 321 F.3d 699, 703 (8tl
+Cir.2003).
+inally, we note that Mr. Carter mistakenly re
+ied in his brief on United States Cabbell 3
+States Wilis. 940 F.2d 1136, T40 (leh)
+940 F.2d
+1136,
+Cir.1991), cert. denied,507 U.S. 971, 113 S.Ct.
+1411, 122 L.Ed.2d 782 (1993)), for the proposition
+that an obstruction-of-justice enhancement should
+not be imposed based upon a defendant's testimony
+" 'if a reasonable trier of fact could find the testimony true.' " This statement, first made in Willis,
+940 F.2d at 1140, was based directly on an application note to U.S.S.G. § 3C1.1 (n.l) (1990) that required a sentencing court to evaluate any suspect
+testimony or statements in the light most favorable
+to the defendant when determining whether he or
+she had committed penury.
+But
+the Sentencing
+Commission amended that application note in 1997
+"so that it no
+longer suggests
+the use of a
+heightened standard of proof, "U.S.S.G. app. C,
+amend. 566, and thus there was no longer a basis
+for our statement in Willis. Rather than viewing the
+evidence favorably to the defendant or to the verdict, the district court now makes independent findings based on a preponderance of the evidence, and
+we review those findings for clear error only. See
+United States | Guel-Contreras, 468 F.3d 517, 522
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prf=HTMLE&fn=_top&mt=F.. 2/27/2008
+
+
+
+(8th Cir.2006). Understandably, Mr. Carter does
+not contend here that the findings of the district
+court are clearly erroneous.
+Page 6
+III.
+For all of the above reasons, we affirm the
+judgment of the district court.
+*647 BYE, Circuit Judge, concurring in part and
+concurring in the judgment.
+I join in Part II of the majority's opinion and its
+judgment. I also agree with Part I to the extent the
+majority recognizes Carter cannot now assert his ex
+post facto challenge because he did not raise it at
+resentencing. I write separately because I disagree
+with the majority's view, expressed in Part I, that
+Carter could have raised the challenge at his first
+sentencing or in his appeal from that sentence.
+At Carter's resentencing, the district court applied the 2001 Guidelines,
+citing the
+conduct in
+Count VII (Resentencing Tr. at 34) and Count II
+(Resentencing Tr. at 39) as the basis for their apobjected,
+arguing
+Guidelines should be used but in doing so merely
+"restate[d]" the objection raised at the first sentencing-that the Count VII conduct occurred before the
+2001 Guidelines' November 1, 2001, effective date.
+Carter did not argue at resentencing, as he does in
+this appeal, that, regardless of when committed, the
+conduct in Count II could not be used to
+appl
+U.S.S.G. § 4B1.5(b)(/ ) to grouped Counts IV,
+and VI. Thus, Carter forfeited the
+ex post facto
+challenge he raises for the first time in this appeal
+and, as it is committed to our discretion, the majority appropriately declines to
+for pain prat. See Geed on If United States, 295
+F.2d 897, 902 (8th Cir.1961) ("The normal rule is
+that an appellate court should not consider questions which have not been properly raised in the trial court and upon which the trial court has had no
+opportunity to pass.").
+But I am not as convinced as my colleagues it
+is reasonable to hold Carter's failure to raise his ex
+post facto challenge at the first sentencing or in his
+first appeal against him. At his first sentencing, the
+district court applied the 2001 Guidelines because it
+determined the offense charged in Count VII occurred after their effective date. Believing the evidence showed the conduct charged in Count VII occurred in August or September of 2001, Carter appealed, arguing the district court violated the ex
+post facto clause of the Constitution by applying S
+4B1.5(b)(1), which was not in effect when he committed Count VII. We agreed with Carter "[t]he
+evidence relevant to Count VII that was offered at
+trial pertained to an incident that occurred in Al
+rust or September of [2001]." United States
+Carter, 410 F.3d 1017, 1025 (8th Cir.2005). Still,
+we affirmed the application of the 2001 Guidelines,
+finding, sua sponte, the conduct charged in Count I/
+might have occurred after November 1, 2001, stating, "[W]e cannot conclude that ... the district court
+clearly erred in determining that the defendant perpetrated at least one of his offenses after the effective date of § 4B1.5(b)(/)." Id. at 1027.
+The relevance of the timing of the conduct
+charged in Count II arose "out of the correction of
+the sentence" and was "made newly relevant by
+[our decision-whether by the reasoning or the result." United States | Lee, 358 F.3d 315, 326 (5th
+Cir.2004). In other words, the relevance of the timing of the conduct in Count II "became extant as a
+consequence of our mandate." Id. Since the district
+court only referenced Carter's Count VII conduct in
+applying the 2001 Guidelines at the first sentencing, it was not in Carter's interest to point out to
+the district court the Count Il conduct might be an
+alternative basis for applying the 2001 Guidelines
+but argue such an application would violate the ex
+post facto clause for the reasons stated in this
+the district court another*648 means to increase his
+sentence. See S.D. Rules of Prof 1 Conduct pre
+amble (As advocate, a lawyer zealously asserts the
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=.
+_top&mt=F...
+
+
+
+Page 7
+client's position under the rules of the adversary
+system."); Id. Rule 1.1 ("A lawyer shall provide
+competent representation to a client."). Even if she
+believed the conduct in Count II occurred after the
+effective date of the 2001 Guidelines (the opposite
+appears to be true), I do not think her candor obligation required her to hang her client. Nonetheless, I
+concur in the ultimate outcome of this case for the
+reasons given.
+C.A.8 (S.D.),2007.
+U.S. . Carter
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F... 2/27/2008
+
+
+
+H
+U.S. |. Blazek
+C.A.8 (lowa),2005.
+United States Court of Appeals, Eighth Circuit
+JNITED STATES of America, Plaintiff-Appellee
+V.
+Michael David BLAZEK, Defendant-Appellant.
+No. 05-1705.
+Submitted: Sept. 13, 2005.
+Filed: Dec. 21, 2005.
+Rehearing and Rehearing En Banc Denied Feb. 1,
+2006.FN*
+FN* Judge Colloton did not participate in
+the consideration or decision of this matter.
+Background: Defendant was convicted in the
+United States District Court for the Southern District of lowa, James E. Gritzner, J., attempted enticement of a minor for sex, travel in interstate
+commerce to engage in prohibited sex acts with a
+minor, and two child pornography offenses. De-
+fendant appealed.
+Holdings: The Court of Appeals, Loken, Chief
+Judge, held that:
+(1) evidence was sufficient to support conviction for attempted enticement of a minor for sex;
+(2) evidence was sufficient to support conviction for travel in interstate commerce to engage in
+prohibited sex acts with a minor;
+(3) prior conviction for abusive sexual contact
+with minor was admissible;
+(4) to support conviction for traveling in interslate commerce to engage in sexual act with minor
+between the ages of 12 and 16 years old, government was not required to prove that defendant knew
+specific age of the victim or that he knew that the
+requisite age difference existed between offender
+and victim; and
+(5) convictions for attempted enticement of a
+Afirmed.
+West Headnotes
+[1] Criminal Law 110 €-1144.13(3)
+110 Criminal Law
+110XXIV Review
+110XXIV(M) Presumptions
+110k1144
+Facts
+or Proceedings Not
+Shown by Record
+110k1144.13 Sufficiency of Evidence
+110k1144.13(2)
+Construction
+Evidence
+110k1144.13(3) k.
+. Construction
+in Favor of Government, State, or Prosecution.
+Most Cited Cases
+Criminal Law 110 €-1144.13(5)
+110 Criminal Law
+110XXIV Review
+110XXIV(M) Presumptions
+110k1144
+Facts or Proceedings Not
+Shown by Record
+110k1144.13 Sufficiency of Evidence
+Deductions from Evidence. Most Cited Caseces or
+Criminal Law 110 €-1144.13(6)
+110 Criminal Law
+110XXIV Review
+110XXIV(M) Presumptions
+110k1144 Facts or Proceedings Not
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prfl=HTMLE&fn=_top&mt=F... 2/27/2008
+
+
+
+Shown by Record
+110k1144.13 Sufticiency of Evidence
+110k1144.13(6) k. Evidence Considered; Conflicting Evidence. Most Cited Cases
+In reviewing the sufficiency of the evidence to support a conviction, an appellate court views the evidence in the light most favorable to the government,
+resolving evidentiary conflicts in favor of the government, and accepting all reasonable inferences
+drawn from the evidence that support the jury's verdict.
+[2] Infants 211 €-13
+211 Infants
+211II Protection
+211k13 k. Protection of Health and Morals.
+Most Cited Cases
+Evidence was sufficient to prove defendant intended to entice a minor to engage in illegal sexual
+activity, as required to support conviction for attempted enticement of a minor for sex; the evidence
+presented at trial showed that the defendant engaged in explicit sexual conversations over the internet with an undercover officer posing as a
+15-year-old male, and then arranged to meet the
+boy. 18 U.S.C.A. § 2422(b).
+[3] Criminal Law 110 €-1030(1)
+110 Criminal Law
+110XXIV Review
+110XXIV(E) Presentation and Reservation in
+Lower Court of Grounds of Review
+110XXIV(E)1 In General
+110k1030 Necessity of Objections in
+General
+110k1030(1) k. In General. Most
+Cited Cases
+1 "plain error" is one that is clear or obvious.
+Fed.Rules Cr.Proc.Rule 52(b), 18 U.S.C.A.
+14) Commerce 83 €-82.10
+83 Commerce
+83II Application to Particular Subjects and
+Methods of Regulation
+83I1(J) Offenses and Prosecutions
+83k82.5 Federal Offenses and Prosecutions
+Liy Unlawrl undea1S ak avemo celia Aai".
+Infants 211 €-13
+211 Infants
+211I1 Protection
+211k13 k. Protection of Health and Morals.
+travel in interstate commerce to engage in prohibited sex acts with a minor between the ages of 12
+and 16; undercover officer posing as minor in internet chat room told defendant about a month before
+their planned meeting that he was 15 years old and
+that he would be turning 16 a couple of months
+after the scheduled meeting, so that when defendant
+made the interstate trip for the meeting, he intended
+to meet a boy under the age of 16. 18 U.S.C.A. §5
+2243(a), 2423(b).
+[5] Commerce 83 €-82.10
+83 Commerce
+8311 Application to Particular Subjects and
+Methods of Regulation
+83Il(J) Offenses and Prosecutions
+83k82.5 Federal Offenses and Prosecutions
+83k82.10 k. Offenses Involving Activity Unlawful Under State Law. Most Cited Cases
+Infants 211 €-13
+211 Infants
+211II Protection
+211k13 k. Protection of Health and Morals.
+Most Cited Cases
+I violation of statute prohibiting travel in interstate
+commerce to engage in prohibited sex acts with a
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F... 2/27/2008
+
+
+
+minor between the ages of 12 and 16 turns not on
+the actual age of the intended victim, but on whether the defendant traveled in interstate commerce
+with the requisite criminal intent for the purpose of
+engaging in a sexual act with a minor between the
+ages of twelve and sixteen. 18 U.S.C.A. § 2423(b).
+[6] Criminal Law 110 €-369.2(5)
+110 Criminal Law
+110X VII Evidence
+110XVII(F) Other Offenses
+110k369 Other Offenses as Evidence of
+Offense Charged in General
+110k369.2 Evidence Relevant to Of-
+fense, Also Relating to Other Offenses in General
+110k369.2(3) Particular Offenses,
+Prosecutions for
+110k369.2(5) k. Sex Offenses;
+Offenses Relating to Children. Most Cited Cases
+Charged offense of traveling in interstate commerce
+to engage in sexual act with minor between the ages
+of 12 and 16 years old was "offense of sexual assault
+," and thus, defendant's prior conviction for
+abusive sexual contact with minor was admissible
+in prosecution for the charged offense, under federal rule of evidence providing for admission of prior
+sexual assault offenses in sexual assault prosecutions. 18 U.S.C.A. § 2423(b); Fed.Rules Evid.Rule
+413(a, d), 28 U.S.C.A.
+[7] Commerce 83 €-82.10
+83 Commerce
+83Il Application to Particular Subjects and
+Methods of Regulation
+83II(J) Offenses and Prosecutions
+83k82.5 Federal Offenses and Prosecutions
+83k82.10 k. Offenses Involving Activity Unlawful Under State Law. Most Cited Cases
+Infants 211 €-13
+211 Infants
+211II Protection
+211k13 k. Protection of Health and Morals.
+[8) Criminal Law 110 €-805(1)
+110 Criminal Law
+110XX Trial
+110XX(G) Instructions: Necessity, Requisites, and Sufficiency
+110k805 Form and Language in General
+110k805(1) k. In General. Most Cited
+Cases
+Criminal Law 110 €-822(1)
+110 Criminal Law
+110XX Trial
+110XX(G) Instructions: Necessity, Requisites, and Sufficiency
+110k822
+Construction and Effect of
+Charge as a Whole
+110k822(1) k. In General. Most Cited
+Cases
+In reviewing challenges to jury instructions, the
+Court of Appeals recognizes that the district court
+has wide discretion in formulating the instructions,
+and it will affirm if all of the jury instructions,
+when read as a whole, fairly and adequately contain
+the law applicable to the case.
+19) Sentencing and Punishment 350H €-780
+350HIV Sentencing Guidelines
+350HIV(E) Prior or Subsequent Misconduct
+350Hk780 k. Grade, Degree or Classification of Other Offense. Most Cited Cases
+Defendant's convictions for attempted enticement
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prfi=HTMLE&fn=_top&mt=F...
+
+
+
+of a minor for sex, and travel in interstate commerce to engage in prohibited sex acts with a minor
+were "covered sex crimes," within meaning of sentencing guideline providing for increased offense
+level and criminal history category when defendant
+committed covered sex crime, the career offender
+provision did not apply, and he committed at least
+Page 4
+U.S.S.G. § 4B1.5(a).
+*1106 B. John Burns, argued, Assistant Public De-
+fender, Des Moines, IA, for appellant.
+Richard Lee Richards, AUSA, argued, Des Moines,
+IA, for appellee.
+Before LOKEN, Chief Judge, WOLLMAN and
+BYE, Circuit Judges.
+LOKEN, Chief Judge.
+Michael Blazek appeals his conviction and sentence on charges of attempted enticement of a
+minor for sex, travel in interstate commerce to engage in prohibited sex acts with a minor, and two
+child pornography offenses. He argues that the
+evidence was insuficient to convict him of the enticement and travel offenses, the district court FNI
+erred in admitting a prior sexual assault conviction,
+a jury instruction was misleading, and the court
+erred in imposing a sentence enhancement under
+U.S.S.G. § 4B1.5 for repeated sexual offenses
+against minors. We affirm.
+FN1. The Honorable James E. Gritzner,
+United States District Judge for the Southern District of Iowa.
+I.
+In July 2001, Blazek entered an internet "male
+for male" chat room from his computer in Des
+Moines and then sent an instant message asking
+"Brian" for his age and location. Brian responded
+that he was a 15 year old male in Chicago. Brian
+was in fact Inspector Dan Everett of the Chicago
+Police Department posing as a teenage boy to investigate internet crimes against children. Blazek
+and Brian discussed their respective sexual experiences. Blazek stated that he preferred "[yJounger
+smooth guys" and described his sexual preferences.
+Blazek and Brian continued their instant message
+and e-mail conversations for fifteen months. At the
+end of May 2002, Blazek became more explicitly
+sexual, inviting Brian to give him a massage and
+suggesting it could lead to sex. In July, Blazek gave
+a detailed description *1107 of how he would mas-
+, "[s]ometimes when guys get
+playful they lose their clothes." In September,
+Blazek engaged in graphic sexual conversations,
+discussing oral sex and suggesting a three-way
+sexual encounter with one of Brian's friends.
+Blazek arranged to meet Brian on October 26
+at a restaurant in Chicago. Blazek was arrested
+when he arrived at the restaurant from lowa. His internet conversations with "Brian" and his trip to
+Chicago were the basis for the convictions for attempting to entice a minor to engage in illegal
+sexual activity in violation of 18 U.S.C. § 2422(b),
+and for traveling in interstate commerce to engage
+in an illegal sexual act with a minor in violation of
+18 U.S.C. § 2423(a). After Blazek traveled to
+Chicago, postal inspectors obtained a warrant,
+searched his apartment, and seized his computer.
+They found hundreds of images and movies of child
+pornography. These materials were the basis for his
+convictions for the receipt and possession of child
+pornography in violation of 18
+U.S.C. 89
+2252(a)(2) and (a)(4)(B).
+[1] Blazek argues the evidence was insufficient
+to convict him of the enticement and interstate
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prfi=HTMLE&fn=_top&mt=F.. 2/27/2008
+
+
+
+[2] Blazek argues that the evidence was insufficient to prove he intended to entice a minor to engage in illegal sexual activity because Inspector
+Everett was the one doing the enticing. Like the
+district court, we disagree. Blazek began the relationship by contacting Brian and engaging in sexual
+conversations after learning Brian was fifteen.
+After extensive breaks in their communications, it
+was usually Blazek who reestablished the internet
+relationship. The jury instructions included the issues of entrapment and predisposition to commit
+the crime charged. Given the explicitly sexual talks
+that preceded Blazek's trip to Chicago in October
+2002, a reasonable jury could find that Blazek intended to entice a minor to engage in illegal sex.
+On appeal, Blazek argues for the first time that
+the evidence was insufficient to convict him of attempting to entice a minor because Inspector Everett was not a minor. We review this issue for plain
+error. Fed.R.Crim.P. 52(b). The contention is based
+upon a recent decision of the district court in
+United States
+Helder, No. 05-00125-01-Cr.
+(W.D.Mo. Aug. 5, 2005) (Judgment of Acquittal), a
+United Stais s ll
+pending on appeal in this court,
+United States
+Helder,
+appeal docketed, No.
+05-3387 (8th Cir. Sep. 1, 2005). The decision in
+Helder is inconsistent witand did not cite, our decision in United States
+Patten, 397 F.3d 1100
+(8th Cir.2005), that upheld an attempt conviction
+under 18 U.S.C. § 2422(b) in which the enticed
+"minor" was an undercover police officer. Though
+this issue was not raised or discussed in Patten,
+was raised and squarely rejected in United States (
+Meek, 366 F.3d 705, 717-20 (9th Cir.2004); Unitea
+States Root. 296 F.3d 1222. 1227-28 (11th
+Cir.2002), cert.
+denied537 U.S. 1176, 123 S.Ct.
+1006, 154 L.Ed.2d 921 (2003); and United States |
+Farner, 251 F.3d 510 (5th Cir.2001).
+Page 5
+468, 117 S.Ct. 1544, 137 L.Ed.2d 718 (1997):
+*1108 We ... hold that in a case such as thiswhere the law at the time of trial was settled and
+clearly contrary to the law at the time of appeal-it is
+enough that an error be "plain" at the time of appellate consideration.
+In this case, the law at the time of trial was not
+settled in this circuit; we had not addressed the issue. Thus, Johnson leaves open the question whether Blazek must prove that the error alleged was
+plain at the time of trial, which it clearly was not.
+But in any event, even if the rule in Johnson applies, and even if this court should ultimately affirm
+the district court's decision in Helder, thereby creating a conflict with at least three other circuits, the
+error is not plain at this time. Therefore, the evidence was sufficient to convict Blazek of attempted
+enticement of a minor.
+[4] Finally, Blazek argues the evidence was insuficient to convict him of traveling in interstate
+commerce "for the purpose of engaging in any
+sexual act ... with a person under 18 years of age
+that would be in violation of Chapter 109A" if it
+occurred within the territorial jurisdiction of the
+United States. 18 U.S.C. § 2423(b) (2002), 'N2 The
+indietment charged that Blazek traveled with the intent to engage in a sexual act with a person who had
+attained the age of twelve years but not the age of
+sixteen years in violation of 18 U.S.C. § 2243(a),
+which is part of chapter 109A. Blazek argues that
+the evidence was insufficient to convict him of a §
+2243(a) violation because "Brian" said he was fifteen in July 2001, when Blazek and Brian first met
+in a chat room, and therefore Brian must have been
+sixteen by the time Blazek traveled to Chicago in
+October 2002.
+FN2. This statutory prohibition was reorganized but not substantively altered in
+2003. Seel8 U.S.C. §§ 2423(b) and (f).
+Slapinein Cohuso dis Seile d entes e20 ub
+lain in Johnson
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F... 2/27/2008
+
+
+
+with the requisite criminal intent, here, for the purpose of engaging in a sexual act with a minor
+between the ages of twelve and sixteen. See Root.
+296 F.3d at 1231-32. At trial, Inspector Everett testified that "Brian" told Blazek in July 2002, long
+after their initial conversation, that he was fifteen
+and would be sixteen in January 2003. In September 2002, the month before the planned meeting in
+Chicago,
+Brian again told Blazek he was fifteen. In
+addition, Postal Inspector Robert Williams testified
+that, after Blazek's arrest, he told officers that he
+understood Brian was fifteen. Thus, there was sufficient evidence for a reasonable jury to find that
+Blazek traveled for the purpose of engaging in a
+sexual act with someone who was not yet sixteen
+Page 6
+sexual act with a person who has attained the age of
+12 years but has not attained the age of 16 years."
+That conduct is proscribed by chapter 109A. Seel8
+U.S.C. § 2243. Thus, the district court properly
+ruled that the prior conviction evidence was admissible under Rule 413. In addition, the court did
+not abuse its discretion in declining to exclude that
+vidence as unfairly prejudicial under the Rule 40.
+alancing test. See United States 1 LeCompte, 13.
+F.3d 767, 769-70 (8th Cir.1997).
+[6] At trial, over Blazek's objection, the govemment introduced evidence of his 1997 conviction
+for Abusive Sexual Contact with a Minor in violation of 18 U.S.C. § 2244(a)(1) and testimony that
+the conviction resulted from Blazek's fondling of
+his eleven-year-old nephew. The district court admitted this evidence under Rule 413(a) of the Federal Rules of Evidence, which provides that, "[i]n a
+criminal case in which the defendant is accused of
+an offense of sexual assault, evidence of the defendant's commission of another offense ... of sexual assault is admissible." Blazek argues that Rule
+413(a) does not apply because he was not charged
+with an "offense of sexual assault." Like the dis-
+Rule 413(d) defines an "offense of sexual assault" to include any federal or state crime "that involved-(1) any conduct proscribed*1109 by chapter
+109A of title 18, United States Code."Rule 413
+does not require that the defendant be charged with
+a chapter 109A offense, only that the instant offense involve conduct proscribed by chapter 109A.
+Here, Count Two charged Blazek with violating 18
+U.S.C. § 2423(b) by traveling in interstate commerce for the purpose of "knowingly engaging in a
+[7] Instruction 15 explained to the jury that the
+charged travel offense required the government to
+prove that Blazek traveled for the purpose of engaging in a sexual act with a minor at least twelve but
+less than sixteen years old. The last sentence of that
+instruction added: "It is not necessary
+United States to prove that the defendant knew the
+specific age of the victim or that he knew that the
+requisite age difference existed between the offender and the victim." On appeal, Blazek argues, as he
+did to the district court, that the last sentence *is a
+correct statement of the law, but it is misleading to
+the jury" because to violate 18 U.S.C. § 2243"the
+defendant would have to know or have to have an
+idea as to how old that victim was."
+[8] "In reviewing challenges to jury instructions, this Court recognizes that the district court
+has wide discretion in formulating the instructions,
+and we will affirm if the entire charge to the jury,
+when read as a whole, fairly and adequately conains the law applicable to the case." United States
+Sdoulam, 398 F.3d 981, 993 (8th Cir.2005
+(quotations omitted). Here, Instruction 13 told the
+jury the government must prove that Blazek
+traveled "for the purpose of engaging in a sexual
+act .. with an individual that was less than eighteen
+years of age." Instruction 14 explained that "[t]he
+government need only prove that the defendant
+knew, had reason to know or thought that the person was a minor." The challenged sentence in In-
+struction 15 was consistent with Instructions 13 and
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft-HTMLE&fn=_top&mt=F... 2/27/2008
+
+
+
+14 and, as Blazek admits, correctly stated the applicable law. The instructions as a whole were not
+inherently confusing in requiring the jury to distinguish between the intent to engage in sexual acts
+with a minor, and specific knowledge of the victim's age. There was no abuse of discretion.
+IV.
+[9] At sentencing, the district court increased
+Blazek's offense level and criminal history category
+under U.S.S.G. § 4B1.5(a) (2001),N which applied when "the defendant's instant offense of convietion is a covered sex crime," the career offender
+provision does not apply, and the defendant committed the instant offense
+"subsequent to sustaining
+at least one sex offense conviction." The court then
+sentenced Blazek to 235 months in prison, the bottom of his advisory guidelines range.
+Blazek argues
+that § 4B 1.5(a) does not apply and therefore his
+entence is unreasonable. We review a challenge to
+he district court's interpretation and application of
+he advisory gudelines de novo and the court's fac
+tual findings
+for
+:lear error. United States
+Mashek, 406 F.3d 1012, 1017 (8th Cir.2005).
+comite Che drlinses of conci vibe. Blazck
+Page 7
+chapter 117 offenses against minors. As explained
+in Part I of this opinion, this court in Patten and at
+least three other circuits have upheld convictions
+for attempted enticement under 18 U.S.C. § 2422(b)
+even though the intended victim was in fact an undercover police officer, because the defendant believed the victim to be a minor. Thus, by including
+attempts in the definition of covered sex crimes, application note 2 expressly included offenses in
+which the intended victim was a "minor victim"
+rather than a "minor," as those terms were defined
+in application note 1. Because Blazek's offenses of
+conviction included one or more covered sex
+crimes (the attempts), and because he admittedly
+lad a prior sex offense conviction, the district cour
+proptiy his sind n B1.5 la), wisck deas not con-
+The judgment of the district court is affirmed.
+C.A.8 (lowa),2005.
+U.S. |. Blazek
+to include "(A) an oflense
+perpetrated against a minor, under .. (iii) chapter
+117 ... or (B) an attempt or a conspiracy to commit
+offense described
+subdivisions (A)(i)
+through (iii) of this note." Blazek's enticement and
+travel offenses were violations of chapter 117. Ap-
+plication note 1 defined "minor" as a person under
+the age of 18 but defined "minor victim" to include
+"an undercover law enforcement officer who represented to the defendant that the officer was a
+ninor." Relying on this distinction, Blazek argue:
+hat he did not commit "covered sex crimes" be
+cause Inspector Everett was a "minor victim," not a
+"minor." We disagree. Application note 2 expressly
+included as covered sex crimes attempts to commit
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F... 2/27/2008
+
+
+
+Sandy Berger
+From Wikipedia, the free encyclopedia
+Samuel Richard "Sandy" Berger (born October
+28, 1945) served as the 19th United States National
+Security Advisor under President Bill Clinton from
+1997 to 2001. In his position, he helped to
+formulate the foreign policy of the Clinton
+Administration. During this time he advised the
+President regarding the Khobar Towers bombing,
+Operation Desert Fox and other actions against Iraq,
+the NATO bombing campaign against Yugoslavia,
+responses to the terrorist bombings of American
+embassies in Kenya and Tanzania, and the
+administration's policy of engagement with the
+People's Republic of China. '' He was also one of
+the prominent actors of the Camp David 2000
+Summit.
+Samuel R. "Sandy" Berger
+National Security Advisor to President Bill Clinton
+Born
+October 28, 1945
+Sharon, Connecticut
+Occupation
+Lobbyist, Financial Services Industry,
+Campaign Advisor
+Spouse
+Susan Berger
+Before joining the administration Berger had
+Children
+Three
+worked as an international trade attorney. Currently,
+he is chairman of an international advisory firm and chairman of the board of an international
+investment fund. Living in the Georgetown section of Washington, D.C., he is married to Susan Berger
+and has three children (two daughters and one son).
+In April 2005, Berger pled guilty to a misdemeanor charge of unauthorized removal and retention of
+classified material from the National Archives in Washington. According to the lead prosecutor in the
+case Berger only took copies of classified information and that no original material was destroyed;
+however, there is notable controversy and speculation that he might have removed or destroyed originals
+of other unknown documents as well.
+Berger currently serves as a foreign policy adviser to Senator Hillary Clinton in her presidential
+campaign. 21
+Contents
+• 1 Early life
+• 2 Clinton administration
+• 2.1 Fined for conflict of interest
+• 2.2 Chinese nuclear espionage
+• 3 Post-government
+• 3.1 Convicted of mishandling classified terror documents
+• 4 See also
+• 5 External links
+• 6 References
+
+
+
+Early life
+Originally from Millerton, New York where his parents ran an Army-Navy store (and born in nearby
+Sharon, Connecticut), Berger earned his Bachelor of Arts degree from Cornell University in 1967 and
+his Juris Doctor (J.D.) degree from Harvard Law School in 1971. At Cornell, Berger was a member of
+the Quill and Dagger society with Paul Wolfowitz and Stephen Hadley. Opposed to the Vietnam War,
+Berger began working for Senator George McGovern's presidential campaign in 1972. While there, he
+met Bill Clinton, forming a friendship that would last for decades. Berger later urged Clinton to run for
+president.
+After the McGovern campaign, Berger gained experience working in a variety of government posts,
+including serving as Special Assistant to former New York City Mayor John Lindsay and Legislative
+Assistant to former U.S. Senator Harold Hughes of Iowa and Congressman Joseph Resnick of New
+York. He was also Deputy Director of Policy Planning for the U.S. State Department from 1977 to 1980
+under Secretary of State Cyrus Vance during the Carter administration. 4]
+After leaving the State Department, Berger went on to join the law firm Hogan & Hartson where he
+helped expand the firm's international law practice. As a partner, he opened the firm's first two
+becoming Speder of the House, "was the ploi3) eason Be Ho a a Harson for in 197e olice of
+becoming Speaker of the House,
+the Chinese government. He was a lawyer-lobbyist." 5]
+Clinton administration
+Berger served as Senior Foreign Policy Advisor to Governor Clinton during the campaign, and as
+Alien Transition Difice or ation, Security ore clinical rani in Dor, ing r.
+Anthony Lake in the National Security Council. In Clinton's second term of office, Berger succeeded
+Lake as Special Assistant to the President for National Security Affairs from 1997 to 2001.
+Fined for conflict of interest
+In November 1997, Berger paid a $23,000 civil penalty to settle conflict of interest allegations stemming
+rom his failure to sell his stock of Amoco Corporation as ordered by the White House. Berger wa
+dvised by the White House to sell the stock in early 1994. Berger said he had planned to sell the stock
+but then forgot. He denied knowingly participating in decisions in which he had a financial interest.
+With no evidence that Berger intended to break the law, the U.S. Justice Department determined a civil
+penalty was adequate for a "non-willful violation" of the conflict of interest law. 6]
+Chinese nuclear espionage
+Further information: Cox Report and Timeline of Cox Report controversy
+In 1999, Berger was criticized for failing to promptly inform
+President Clinton of his knowledge that the People's Republic of
+China had managed to acquire the designs of a number of U.S. nuclear warheads. Berger was originally
+
+
+
+briefed of the espionage by the United States Department of Energy
+(DOE) in April 1996, but did not inform the president until July
+1997.718
+A number of Republicans, including then presidential hopeful
+Lamar Alexander, called for Berger's resignation. They accused
+him of ignoring the allegations of Chinese espionage. "For his
+unwillingness to act on this serious matter, Mr. Berger should
+resign", Alexander said. "If he does not, he should be relieved of his
+Sandy Berger with President
+Clinton and Madeleine Albright
+duties by President Clinton."(9) President Clinton rejected the calls:
+"The record is that we acted aggressively," Clinton said. "Mr.
+Berger acted appropriately. "[10]
+I asked DOE to widen and deepen its investigation, to intensify as they were planning
+66
+their counterintelligence efforts to brief the Congress[.] [W]ithin several weeks the FBI
+had opened up a full investigation on the prime suspect. So I took the actions that I
+believe were appropriate. I get an awful lot of threat information every day. I have to
+make a judgment as to what I brief the president on and what I don't. In 1997, when this
+was clearly a pattern and a systemic problem, I thought it was essential for the president
+99
+to know — Sandy Berger, May 29, 1999.'!]
+Post-government
+After leaving the Clinton administration, Berger became chairman of Stonebridge International, an
+international advisory firm he co-founded in 2001 which focuses on aiding companies in their expansion
+into markets such as Brazil, China, India, and Russia.(4) Berger is also Chairman of the DB Zwirn
+Global Advisory Board, an international investment fund and merchant capital provider founded in 2001
+and with offices throughout North America, Europe and Asia. [12) Berger is an Advisory Board member
+for the Partnership for a Secure America, a not-for-profit organization dedicated to recreating the
+bipartisan center in American national security and foreign policy.
+In late 2003, Berger was called to testify before the 9/11 Commission regarding steps taken against
+terrorism during his tenure and the information he provided to his successor, Condoleezza Rice. At the
+time, Berger was also acting as an informal foreign policy advisor to Senator John Kerry during his
+campaign for the presidency. He quit his advisory role after controversy arose regarding his preparations
+for testifying before the September 11 committee. '3]
+Convicted of mishandling classified terror documents
+On July 19, 2004, it was revealed that the U.S. Justice Department
+was investigating Berger for stealing classified documents in
+October 2003, by removing them from a National Archives reading
+room prior to testifying before the 9/11 Commission. The
+documents were five classified copies of a single report
+commissioned from Richard Clarke, covering internal assessments
+of the Clinton administration's handling of the unsuccessful 2000
+millennium attack plots. An associate of Berger said 14) Berger took
+
+
+
+one copy in September 2003 and four copies in October 2003.
+The National Archives building in
+Washington, DC
+When initially questioned by reporters, Berger claimed it was
+accidental that he put the top-secret copies in his attache-case and
+handwritten notes in his jacket and pants pockets. He later, in a guilty plea, admitted to deliberately
+removing the copies and cutting three up with scissors. Archive staff stated they witnessed Berger, on
+more than one occasion, stuffing into his pants and into his jacket papers he was illegally removing.!!5]
+Two of the copies were recovered by DOJ investigators and returned to the archives.
+Berger eventually pleaded guilty to a misdemeanor charge of unauthorized removal and retention of
+classified material on April 1, 2005. Under a plea agreement, U.S. attorneys recommended a fine of
+$10,000 and a loss of security clearance for three years. However, on September 8, U.S. Magistrate
+Judge Deborah Robinson increased the fine to $50,000 at Berger's sentencing. Robinson stated, "The
+court finds the fine [recommended by government prosecutors] is inadequate because it doesn't reflect
+he seriousness of the offense."[16] Berger was also ordered to serve two years of probation and to
+perform 100 hours of community service.!'?.
+Critics suggest Berger destroyed primary evidence revealing anti-terrorism policies and actions, and that
+his motive was to permanently erase Clinton administration pre-9/11 mistakes from the public record.
+Public statements to this effect have been made by talk-radio host Rush Limbaugh, ') former Clinton
+campaign advisor Dick Morris,''! USA Today reporter Jack Kelley, ǼJ multiple times by Fox News
+correspondent John Gibson (the last as recently as December 2006|21), and former House Speaker
+Dennis Hastert (Republican-Illinois), who said: "What information could be so embarrassing that a man
+with decades of experience in handling classified documents would risk being caught pilfering our
+nation's most sensitive secrets?" 22]
+After a long investigation, the lead prosecutor Noel Hillman, chief of the Justice Department's Public
+Integrity Section, stated that Berger only removed classified copies of data stored on hard drives stored
+in the National Archives, and that no original material was destroyed. 23) His and the FBI's opinion of
+the case initially led The Wall Street Journal to editorialize against the allegations. 24)[25)
+On December 20, 2006, more than a year after Berger pleaded guilty and was sentenced, a report issued
+by the archives inspector detailed how Berger had perpetrated the crime. Inspector General Paul
+Brachfeld reported that Berger took a break to go outside without an escort. "In total, during this visit, he
+removed four documents ... Mr. Berger said he placed the documents under a trailer in an accessible
+construction area outside Archives 1 (the main Archives building)." Berger acknowledged that he later
+retrieved the documents from the construction area and returned with them to his office. 26|211
+The report also stated "There were not any handwritten notes on the documents Mr. Berger removed
+from the archives. Mr. Berger did not believe there was unique information in the three documents he
+destroyed. Mr. Berger never made any copies of these documents." In the end, according to the report,
+"[Mr. Berger] substituted his sense of sensitivity instead of thinking of classification" in deciding to
+remove the documents. 28]
+In January 2007, departing Republican staff of The United States House Committee on Oversight and
+Government Reform released a report titled Sandy Berger's Theft of Classified Documents: Unanswered
+Questions. It states that the FBI or the Department of Justice never questioned Berger about two earlier
+visits he made on May 30, 2002 and July 18, 2003, when he reviewed White House working papers not
+yet inventoried by the National Archives, and speculates that, had Berger previously been entirely
+
+
+
+successful in actions at which he was later caught, "nobody would know they were gone." It also
+contains the FBI's statement as to why they concluded there was no exposure on those dates: "Berger
+was under constant supervision" 29][1730) Acting Assistant Attorney General Richard Heating disputed
+the findings of the Oversight Report and rejected the need for a polygraph since 'no new facts regarding
+law enforcement aspects of this investigation' had been discovered. 31]
+The report did, however, cause the Wall Street Journal to, in January 2007, retract their initial opinion of
+the case, saying there are substantial questions concerning the truth of Berger's statements and that other
+documents may have been removed. They now argue that Berger's taking of multiple copies of the same
+document contradict his statement that he took them only for his personal research, since they note that
+he could have simply taken one copy. 32[151 Mr. Berger continues to insist that he took the copies of the
+same document for personal convenience, and thought them overclassified (i.e. the information they
+contained was not actually sensitive to national security).
+On May 17, 2007, Berger relinquished his license to practice law as a result of the Justice Department
+investigation. Saying, "I have decided to voluntarily relinquish my license." He added that, "While I
+derived great satisfaction from years of practicing law, I have not done so for 15 years and do not
+envision returning to the profession. I am very sorry for what I did, and I deeply apologize." By giving
+up his license, Berger avoided cross-examinination by the Bar Counsel regarding details of his thefts. (33)
+See also
+• History of the United States National Security Council 1993-2003
+• Iraq disarmament crisis timeline 1997-2000
+• Mary McCarthy (CIA)
+External links
+• Archives Staff Was Suspicious of Berger (http://www.washingtonpost.com/ac2/wp-dyn/A4189-
+2004Jul21?language=printer) Washington Post
+• United States National Security Council page at the White House website
+(http://www.whitehouse.gov/nsc/)
+• Report on Berger (PDF) (http://i.a.cnn.net/cnn/2006/images/12/21/berger.document.pdf), Office
+of the Inspector General, National Archives and Records Administration
+References
+1. ^ Apple Jr., R. W., "A Domestic Sort With Global Worries" (http://select.nytimes.com/gst/abstract.html?
+ґes=F70F15F8345C0C768EDDA10894D|494D81&n=Tоp%2fReference%2fTimes%20Topics%2fPeople%
+2fB%2fBerger%2c%20Samue1%20R%2e), New York Times, August 25, 1999
+2. ^ Hillary Clinton's Advisor (http://www.ethicsscoreboard.com/list/berger2.html)
+3. nab Ahrens, Frank, "The Reluctant Warrior" (http://www.washingtonpost.com/wpsrv/inatl/longterm/iraq/keyplayers/berger022498.htm), Washington Post, February 24, 1998
+4. nab Stonebridge website (http://www.stonebridge-international.com/bios/bio01.html), Retrieved: January
+10,2007
+5. ^ Hentoff, Nat, "Dinner With Gen. Chi" (http://users.aol.com/beachbt/genchi.txt), Washington Post, January
+26, 1997
+6. ^ "Berger Agrees To Pay Penalty " (http://www.cnn.com/ALLPOLITICS/1997/11/10/email/berger/),
+CNN.com, November 10, 1997
+
+
+
+7. ^ Gerth, Jeff and Risen, James, "China Stole Nuclear Secrets From Los Alamos, U.S. Officials
+Say" (http://select.nytimes.com/gst/abstract.html?
+res=FA0B17F73E5C0C7A8CDDAD0894D1494D81&n=Top%2fReference%2fTimes%20Topics%
+2fPeople%2fB%2fBerger%2c%20Samuc1%20R%2e), New York Times, March 6, 1999
+8. ^ "The White House and China" (http://taiwansecurity.org/News/NYT-990306.htm), New York Times,
+Editorial, April 9, 1999
+9. ^ "Clinton's security adviser takes heat for China nuclear
+scandal" (http://www.cnn.com/US/9903/10/nuclear.secrets.02/), CNN.com, March 11, 1999
+10. ^ Gerstenzang, James and Drogin,
+a mutar sends 200 charp onage Case, Las angeles
+Times, March 12, 1999
+11. ^ Transcript (http://www.pbs.org/newshour/bb/europe/jan-june99/berger_5-27.html), NewsHour with Jim
+Lehrer, PBS, May 27, 1999, Retrieved: May 27, 2006
+12. ^ Schurr, Stephen, "DB Zwirn hires Clinton aide" (http://www.stonebridge-
+13.
+international.com/press/news010.html), Financial Times, March 15, 2006
+^ "Sandy Berger Quits Kerry
+Team" (http://www.cbsnews.com/stories/2004/07/19/national/main630625.shtml), CBSNews.com, July 20,
+14. ^ CNN.com - Sandy Berger to plead guilty on documents charge - Apr 1, 2005
+(http://edition.cnn.com/2005/LAW/04/01/berger.plea/)
+15. nab Smith, R. Jeffrey, Berger Case Still Roils Archives, Justice Dept., Washington Post, February 21, 2007
+(http://www.washingtonpost.com/wp-dyn/content/article/2007/02/20/AR2007022001344.html)
+16. ^ Sherman, Mark,
+"Berger Pleads Guilty to Taking Materials" (http://www.sfgate.com/cgi-bin/article.cgi?
+f=/n/a/2005/04/01/national/w111624S64.DTL), Associated Press via SFGate.com, April 2, 2005
+17. ^a b Margasak, Larry, "GOP Contradicts Justice Department" (http://www.guardian.co.uk/uslatest/story/0,,
+6334264,00.html), Associated Press, January 10, 2007
+18. ^ "Limbaugh: Sandy Berger incident "far worse" than Abu Ghraib
+(http://mediamatters.org/items/200407230011)", Media Matters for America, July 23, 2004. Retrieved on
+2006-12-22.
+19. ^ Dick Morris. "Sandy Berger Rolls Over for Bill and Hill
+(http://www.frontpagemag.com/Articles/ReadArticle.asp?ID=17647)", April 8, 2005. Retrieved on 2006-12-
+20. ^ "Conservatives baselessly linked Sandy Berger to Atta investigation
+(http://mediamatters.org/items/200508160002)", Media Matters for America, August 16, 2005. Retrieved on
+2006-12-22.
+21.
+^ "Why I Never Should Have Had Sandy Berger on The Big
+Story' (http://www.foxnews.com/story/0,2933,238163,00.html)", FOX News, December 21, 2006. Retrieved
+on 2006-12-23.
+22. ^ "The speaker speaks (http://www.powerlineblog.com/archives/007216.php)", Powerline, July 21, 2004.
+Retrieved on 2006-12-22.
+23. ^ Seper, Jerry. "Berger fined for taking papers (http://www.washtimes.com/national/20050909-122225-
+2387r.htm)", The Washington Times, September 9, 2005. Retrieved on 2006-12-22.
+24. ^ "Berger's Plea" (http://opinionjournal.com/editorial/feature.html?id=110006521), Editorial, Wall Street
+Journal, April 6, 2005
+25. ^ The Berger File (http://www.opinionjournal.com/editorial/feature.html?id=110006534). Opinion Journal.
+The Wall Street Journal (April 8, 2005). Retrieved on 2006-12-22.
+26. ^ Lichtblau, Eric, "Report Details Archives Theft by Ex-
+Adviser" (http://www.nytimes.com/2006/12/21/washington/21berger.html), New York Times, December 21,
+27. ^ Margasak, Larry, "Report Says Berger Hid Archive
+Documents" (http://apnews.myway.com/article/20061220/D8M4R7DO0.html), Associated Press, December
+20, 2006
+^ "Office of the Inspector General, National Archives and Records Administration report (page 9)
+(http://i.a.cnn.net/cnn/2006/images/12/21/berger.document.pdf)".
+29. ^ Sandy Berger's Theft of Classified Documents: Unanswered Questions
+http://republicans.oversight.house.gov/Media/PDFs/BergerReport010907.pdf), U.S. House of
+Representatives, January 9, 2007
+
+
+
+30. ^ Justice Dept. Conduct in Berger Case Questioned (http://reform.democrats.house.gov/story.asp?ID=404),
+Chairman Henry A. Waxman, August 6, 2004
+31. ^ Letter from Department of Justice (http://oversight.house.gov/documents/20070221164830-34067.pdf),
+U.S. House of Representatives, February 16, 2007
+32. ^ "The Berger Files: The Case of the Purloined Archives Gets Stranger All the
+Time"(http://www.opinionjournal.com/editorial/feature.html?id=110009522), Wall Street Journal, January
+13, 2007
+^ Clinton aide forfeits law license in Justice Probe (http://www.washingtontimes.com/national/20070516-
+113137-9942r.htm)
+Preceded by
+Deputy National Security Advisor
+Jonathan Howe
+1993-1997
+Preceded by
+United States National Security Advisor
+Anthony Lake
+1997-2001
+Succeeded by
+James Steinberg
+Succeeded by
+Condoleezza Rice
+Retrieved from "http://en.wikipedia.org/wiki/Sandy_Berger"
+Categories: 1945 births | American political scandals | American criminals | Cornell University alumni |
+Harvard Law School alumni | American Jews | Jewish American politicians | Living people | United
+States National Security Advisors | Clinton administration controversies | Clinton Administration
+personnel
+• This page was last modified on 6 February 2008, at 17:45.
+• All text is available under the terms of the GNU Free
+Documentation License. (See Copyrights for details.)
+Wikipedia® is a registered trademark of the Wikimedia
+Foundation, Inc., a U.S. registered 501(c)(3) tax-deductible
+nonprofit charity.
+
+
+
+Westlaw Delivery Summary Report for
+Date/Time of Request:
+Client Identifier:
+Database:
+Citation Text:
+Lines:
+Documents:
+Images:
+Wodnesday, February 27, 2008 14:29 Eastern
+US-PL-OLD
+PL 108-21, 2003 $ 151
+2770
+!
+PROTECT ACT ADDS 3559(E)
+The material accompanying this summary is subject to copyright. Usage is governed by contract with Thomson, West and
+their affiliates.
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full...
+
+
+
+UNITED STATES PUBLIC LAWS
+108th Congress - First Session
+Convening January 7, 2003
+Copr. © West Group 2003. No Claim to Orig. U.S. Govt. Works
+Additions and Deletions are not identified in this database.
+Vetoed provisions within tabular material are not displayed
+PROSECUTORIAL REMEDIES AND TOOLS AGAINST THE EXPLOITATION OF CHILDREN TODAY ACT
+OF 2003 (PROTECT ACT)
+AN ACT To prevent child abduction and the sexual exploitation of children, and for other purposes.
+Be it enacted by the Senate and House of Representatives of the United States
+of America in Congress assembled
+SECTION 1. SHORT TITLE; TABLE OF CONTENTS.
+« 18 USCA § 1 NOTE >>
+(a) SHORT TITLE.--This Act may be cited as the "Prosecutorial Remedies and Other Tools to end the Exploitation of Children Today Act of 2003" or "PROTECT Act".
+(b) TABLE OF CONTENTS.--The table of contents for this Act is as follows:
+Sec. 1. Short title; table of contents.
+Sec. 2. Severability.
+TITLE I--SANCTIONS AND OFFENSES
+Sec. 101. Supervised release term for sex offenders.
+Sec. 102. First degree murder for child abuse and child torture murders.
+Sec. 103. Sexual abuse penalties.
+Sec. 104. Stronger penalties against kidnapping.
+Sec. 105. Penalties against sex tourism.
+Sec. 106. Two strikes you're out.
+Sec. 107. Attempt liability for international parental kidnapping.
+Sec. 108. Pilot program for national criminal history background checks and feasibility study.
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full.. 2/27/2008
+
+
+
+TITLE II-INVESTIGATIONS AND PROSECUTIONS
+Sec. 201. Interceptions of communications in investigations of sex offenses.
+Sec. 202. No statute of limitations for child abduction and sex crimes.
+Sec. 203. No pretrial release for those who rape or kidnap children.
+Sec. 204. Suzanne's law.
+TITLE III-PUBLIC OUTREACH
+Subtitle A-AMBER Alert
+Sec. 301. National coordination of AMBER alert communications network.
+Sec. 302. Minimum standards for issuance and dissemination of alerts through AMBER alert communications
+network.
+Sec. 303. Grant program for notification and communications systems along highways for recovery of abducted
+children.
+Sec. 304. Grant program for support of AMBER alert communications plans.
+Sec. 305. Limitation on liability.
+Subtitle B--National Center for Missing and Exploited Children
+Sec. 321. Increased support.
+Sec. 322. Forensic and investigative support of missing and exploited children.
+Sec. 323. Creation of cyber tipline.
+Subtitle C--Sex Offender Apprehension Program
+Sec. 341. Authorization.
+Subtitle D--Missing Children Procedures in Public Buildings
+Sec. 361. Short title.
+*651 Sec. 362. Definitions.
+Sec. 363. Procedures in public buildings regarding a missing or lost child.
+Subtitle E-Child Advocacy Center Grants
+Sec. 381. Information and documentation required by Attorney General under Victims of Child Abuse Act of 1990.
+TITLE IV-SENTENCING REFORM
+Sec. 401. Sentencing reform.
+TITLE L-OBSCENITY AND PORNOGRAPHY
+Subtitle A--Child Obscenity and Pornography Prevention
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full.. 2/27/2008
+
+
+
+Sec. 501. Findings.
+Sec. 502. Improvements to prohibition on virtual child pornography.
+Sec. 503. Certain activities relating to material constituting or containing child pornography.
+Sec. 504. Obscene child pornography.
+Sec. 505. Admissibility of evidence.
+Sec. 506. Extraterritorial production of child pornography for distribution in the United States.
+Sec. 507. Strengthening enhanced penalties for repeat offenders.
+Sec. 508. Service provider reporting of child pomography and related information.
+Sec. 509. Investigative authority relating to child pornography.
+Sec. 510. Civil remedies.
+Sec. 511. Recordkeeping requirements.
+Sec. 512. Sentencing enhancements for interstate travel to engage in sexual act with a juvenile.
+Sec. 513. Miscellaneous provisions.
+Subtitle B--Truth in Domain Names
+Sec. 521. Misleading domain names on the Internet.
+TITLE VI--MISCELLANEOUS PROVISIONS
+Sec. 601. Penalties for use of minors in crimes of violence.
+Sec. 602. Sense of Congress.
+Sec. 603. Communications Decency Act of 1996.
+Sec. 604. Internet availability of information concerning registered sex offenders.
+Sec. 605. Registration of child pornographers in the national sex offender registry.
+Sec. 606. Grants to States for costs of compliance with new sex offender registry requirements.
+Sec. 607. Safe ID Act.
+Sec. 608. Illicit Drug Anti-Proliferation Act.
+Sec. 609. Definition of vehicle.
+Sec. 610. Authorization of John Doe DNA indictments.
+Sec. 611. Transitional housing assistance grants for child victims of domestic violence, stalking, or sexual as-
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full.. 2/27/2008
+
+
+
+Page 4
+sault.
+« 18 USCA § 1 NOTE >>
+SEC. 2. SEVERABILITY.
+If any provision of this Act, or the application of such provision to any person or circumstance, is held invalid.
+the remainder of this Act, and the application of such provision to other persons not similarly situated or to other
+circumstances, shall not be affected by such invalidation.
+TITLE I-SANCTIONS AND OFFENSES
+« 18 USCA § 3583 >>
+SEC. 101. SUPERVISED RELEASE TERM FOR SEX OFFENDERS.
+Section 3583 of title 18, United States Code, is amended--
+< 18 USCA § 3583 >>
+(1) in subsection (e)(3), by inserting "on any such revocation" after "required to serve";
+<< 18 USCA § 3583 >>
+(2) in subsection (h), by striking "that is less than the maximum term of imprisonment authorized under subsection (e)(3)"; and
+< 18 USCA § 3583 >>
+(3) by adding at the end the following:
+*652 "(k) Notwithstanding subsection (b), the authorized term of supervised release for any offense under section 1201 involving a minor victim, and for any offense under section 1591, 2241, 2242, 2244(a)(1), 2244(a)(2).
+2251, 2251A, 2252, 2252A, 2260, 2421, 2422, 2423, or 2425, is any term of years or life.".
+«< 18 USCA § 111>>
+SEC. 102. FIRST DEGREE MURDER FOR CHILD ABUSE AND CHILD TORTURE MURDERS.
+Section 1111 of title 18, United States Code, is amended--
+«< 18 USCA § 111>>
+(1) in subsection (a)--
+(A) by inserting "child abuse," after "sexual abuse,"; and
+alie by bey", a or perpetrated as part of a patterm or practice of assault or torture against a child or children;"
+< 18 USCA § 111 >>
+(2) by inserting at the end the following:
+"(c) For purposes of this section--
+"(1) the term 'assault' has the same meaning as given that term in section 113;
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 5
+PL. 108-21, April 30, 2003, 117 Stat 650
+"(2) the term 'child' means a person who has not attained the age of 18 years and is--
+"(A) under the perpetrator's care or control; or
+"(B) at least six years younger than the perpetrator;
+"(3) the term 'child abuse' means intentionally or knowingly causing death or serious bodily injury to a child;
+"(4) the term 'pattern or practice of assault or torture' means assault or torture engaged in on at least two occa- sions;
+"(5) the term 'serious bodily injury' has the meaning set forth in section 1365; and
+"(6) the term 'torture' means conduct, whether or not committed under the color of law, that otherwise satisfies
+the definition set forth in section 2340(1).".
+SEC. 103. SEXUAL ABUSE PENALTIES.
+(a) MAXIMUM PENALTY INCREASES.--(1) Chapter 110 of title 18, United States Code, is amended--
+<< 18 USCA § 2251 >>
+(A) in section 2251d) --
+(i) by striking "20" and inserting "30"; and
+(ii) by striking "30" the first place it appears and inserting "50";
+<< 18 USCA § 2252 >>
+(B) in section 2252(b)(1)--
+(i) by striking "15" and inserting "20"; and
+(ii) by striking "30" and inserting "40";
+«< 18 USCA § 2252 >>
+(C) in section 2252(b)(2) --
+(i) by striking "5" and inserting "10"; and
+(i) by striking "10" and inserting "20";
+« 18 USCA § 2252A »>
+(D) in section 2252A(b)(1) -
+(i) by striking "15" and inserting "20"; and
+(i) by striking "30" and inserting "40"; and
+« 18 USCA § 2252A >>
+(E) in section 2252A(b)(2)--
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+(i) by striking "5" and inserting "10"; and
+(ii) by striking "10" and inserting "20".
+(2) Chapter 117 of title 18, United States Code, is amended--
+< 18 USCA § 2422 >>
+(A) in section 2422(a), by striking "10" and inserting "20";
+< 18 USCA § 2422 >>
+(B) in section 2422(b), by striking "15" and inserting "30"; and
+< 18 USCA § 2423 >>
+(C) in section 2423(a), by striking "15" and inserting "30".
+« 18 USCA § 1591 »>
+*653 (3) Section 1591(b)(2) of title 18, United States Code, is amended by striking "20" and inserting "40".
+(b) MINIMUM PENALTY INCREASES.-(1) Chapter 110 of title 18, United States Code, is amended--
+<< 18 USCA § 2251 >>
+(A) in section 2251(d)--
+(i) by striking "or imprisoned not less than 10" and inserting "and imprisoned not less than 15";
+(ii) by striking "and both,";
+(iii) by striking "15" and inserting "25"; and
+(iv) by striking "30" the second place it appears and inserting "35";
+« 18 USCA § 2251A»>
+(B) in section 2251A(a) and (b), by striking "20" and inserting "30";
+« 18 USCA § 2252 >>
+(C) in section 2252(b)(1)--
+(i) by striking "or imprisoned" and inserting "and imprisoned not less than 5 years and";
+(ii) by striking "or both,"; and
+(iii) by striking "5" and inserting "15";
+« 18 USCA § 2252 >>
+(D) in section 2252(b)(2), by striking "2" and inserting "10";
+« 18 USCA § 2252A »>
+(E) in section 2252A(b)(1)--
+(i) by striking "or imprisoned" and inserting "and imprisoned not less than 5 years and";
+Page 6
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 7
+(ii) by striking "or both,"; and
+(iii) by striking "5" and inserting "15"; and
+« 18 USCA § 2252A >>
+(F) in section 2252A(b)(2), by striking "Z" and inserting "10".
+(2) Chapter 117 of title 18, United States Code, is amended--
+« 18 USCA § 2422 >>
+(A) in section 2422(b)--
+(i) by striking ", imprisoned" and inserting "and imprisoned not less than 5 years and"; and
+(ii) by striking ", or both"; and
+(B) in section 2423(a)--
+< 18 USCA § 2422 >>
+(i) by striking ", imprisoned" and inserting "and imprisoned not less than 5 years and"; and
+«< 18 USCA § 2423 >>
+(ii) by striking ", or both".
+SEC. 104. STRONGER PENALTIES AGAINST KIDNAPPING.
+< 28 USCA § 994 NOTE >>
+(a) SENTENCING GUIDELINES.--Notwithstanding any other provision of law regarding the amendment of
+Sentencing Guidelines, the United States Sentencing Commission is directed to amend the Sentencing
+Guidelines, to take effect on the date that is 30 days after the date of the enactment of this Act--
+(1) so that the base offense level for kidnapping in section 2A4.1(a) is increased from level 24 to level 32;
+(2) so as to delete section 2A4.1(b)(4)(C); and
+(3) so that the increase provided by section 2A4.1(b)(5) is 6 levels instead of 3.
+«< 18 USCA § 2423»>
+SEC. 105. PENALTIES AGAINST SEX TOURISM.
+(a) IN GENERAL.-Section 2423 of title 18, United States Code, is amended by striking subsection (b) and inserting the following:
+*654 "(b) TRAVEL WITH INTENT TO ENGAGE IN ILLICIT SEXUAL CONDUCT.-A person who travels in
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full.. 2/27/2008
+
+
+
+Page 8
+interstate commerce or travels into the United States, or a United States citizen or an alien admitted for permanent residence in the United States who travels in foreign commerce, for the purpose of engaging in any illicit
+sexual conduct with another person shall be fined under this title or imprisoned not more than 30 years, or both.
+"(c) ENGAGING IN ILLICIT SEXUAL CONDUCT IN FOREIGN PLACES.--Any United States citizen or alien admitted for permanent residence who travels in foreign commerce, and engages in any illicit sexual conduct
+with another person shall be fined under this title or imprisoned not more than 30 years, or both.
+"(d) ANCILLARY OFFENSES.--Whoever, for the purpose of commercial advantage or private financial gain,
+arranges, induces, procures, or facilitates the travel of a person knowing that such a person is traveling in interstate commerce or foreign commerce for the purpose of engaging in illicit sexual conduct shall be fined under
+this title, imprisoned not more than 30 years, or both.
+"(e) ATTEMPT AND CONSPIRACY.--Whoever attempts or conspires to violate subsection (a), (b), (c), or (d)
+shall be punishable in the same manner as a completed violation of that subsection.
+"(f) DEFINITION.--As used in this section, the term 'illicit sexual conduct' means (1) a sexual act (as defined in
+section 2246) with a person under 18 years of age that would be in violation of chapter 109A if the sexual ac
+occurred in the special maritime and territorial jurisdiction of the United States; or (2) any commercial sex ac
+(as defined in section 1591) with a person under 18 years of age.
+"(g) DEFENSE.--In a prosecution under this section based on illicit sexual conduct as defined in subsection
+f)(2), it is a defense, which the defendant must establish by a preponderance of the evidence, that the defendan
+easonably believed that the person with whom the defendant engaged in the commercial sex act had attained th
+age of 18 years.".
+< 18 USCA § 3559 >>
+(b) CONFORMING AMENDMENT.--Section 2423(a) of title 18, United States Code, is amended by striking
+"or attempts to do so,".
+SEC. 106. TWO STRIKES YOU'RE OUT.
+« 18 USCA § 3559 >>
+(a) IN GENERAL.--Section 3559 of title 18, United States Code, is amended by adding at the end the following
+new subsection:
+"(e) MANDATORY LIFE IMPRISONMENT FOR REPEATED SEX OFFENSES AGAINST CHILDREN.-
+"(1) IN GENERAL.-A person who is convicted of a Federal sex offense in which a minor is the victim shall be
+sentenced to life imprisonment if the person has a prior sex conviction in which a minor was the victim, unless
+the sentence of death is imposed.
+"(2) DEFINITIONS.--For the purposes of this subsection--
+https://web2.westlaw.com/print/printstream.aspx?prfl=HTMLE&destination=atp&sv=Full..
+
+
+
+transportation of minors);
+B) the term 'State sex offense' means an offense under State law that is punishable by more than one year
+ison and consists of conduct that would be a Federal sex offense if, to the extent or in the manner specified
+the applicable provision of this title-
+"(i) the offense involved interstate or foreign commerce, or the use of the mails; or
+Page 9
+country (as defined in section 1151);
+"(C) the term 'prior sex conviction' means a conviction for which the sentence was imposed before the conduct
+occurred constituting the subsequent Federal sex offense, and which was for a Federal sex offense or a State sex
+offense;
+"(D) the term 'minor' means an individual who has not attained the age of 17 years; and
+"(E) the term 'state' has the meaning given that term in subsection (c)(2).
+"(3) NONQUALIFYING FELONIES.-An offense described in section 2422(b) or 2423(a) shall not serve as a
+basis for sentencing under this subsection if the defendant establishes by clear and convincing evidence that--
+"(A) the sexual act or activity was consensual and not for the purpose of commercial or pecuniary gain;
+"(B) the sexual act or activity would not be punishable by more than one year in prison under the law of the
+State in which it occurred; or
+"(C) no sexual act or activity occurred.".
+«< 18 USCA § 2247 >>
+< 18 USCA § 2426>>
+(b) CONFORMING AMENDMENT.--Sections 2247(a) and 2426(a) of title 18, United States Code, are each
+amended by inserting ", unless section 3559(e) applies" before the final period.
+«< 18 USCA § 1204>>
+SEC. 107. ATTEMPT LIABILITY FOR INTERNATIONAL PARENTAL KIDNAPPING.
+Section 1204 of title 18, United States Code, is amended--
+(1) in subsection (a), by inserting ", or attempts to do so," before "or retains"; and
+« 18 USCA § 1204 >>
+(2) in subsection (c)--
+(A) in paragraph (1), by inserting "or the Uniform Child Custody Jurisdiction and Enforcement Act" before
+"and was"; and
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 10
+(B) in paragraph (2), by inserting "or" after the semicolon.
+< 42 USCA § 5119a NOTE >>
+SEC. 108. PILOT PROGRAM FOR NATIONAL CRIMINAL HISTORY BACKGROUND CHECKS AND
+FEASIBILITY STUDY.
+(a) ESTABLISHMENT OF PILOT PROGRAM.-
+(1) IN GENERAL.--Not later than 90 days after the date of the enactment of this Act, the Attorney General shall
+establish a pilot program for volunteer groups to obtain national *656 and State criminal history background
+checks through a 10-fingerprint check to be conducted utilizing State criminal records and the Integrated Auto.
+mated Fingerprint Identification system of the Federal Bureau of Investigation.
+(2) STATE PILOT PROGRAM.--
+(A) IN GENERAL.--The Attorney General shall designate 3 States as participants in an 18-month State pilot
+program.
+(B) VOLUNTEER ORGANIZATION REQUESTS.-A volunteer organization in one of the 3 States participating in the State pilot program under this paragraph that is part of the Boys and Girls Clubs of America, the Na-
+tional Mentoring Partnerships, or the National Council of Youth Sports may submit a request for a
+10-fingerprint check from the participating State. A volunteer organization in a participating State may not sub-
+(C) STATE CHECK.--The participating State under this paragraph after receiving a request under subparagraph (B) shall conduct a State background check and submit a request that a Federal check be performed
+through the Integrated Automated Fingerprint Identification System of the Federal Bureau of Investigation, to
+the Attorney General, in a manner to be determined by the Attorney General.
+(D) INFORMATION PROVIDED.--Under procedures established by the Attorney General, any criminal history record information resulting from the State and Federal check under subparagraph (C) shall be provided to
+the State or National Center for Missing and Exploited Children consistent with the National Child Protection Act.
+(E) COSTS.--A State may collect a fee to perform a criminal background check under this paragraph which
+may not exceed the actual costs to the State to perform such a check.
+(F) TIMING.--For any background check performed under this paragraph, the State shall provide the State
+to the National Center for Missing and Exploited Children within 7 business days after receiving the request
+from the State.
+(3) CHILD SAFETY PILOT PROGRAM.--
+(A) IN GENERAL.--The Attorney General shall establish an 18-month Child Safety Pilot Program that shall
+provide for the processing of 100,000 10- fingerprint check requests from organizations described in subpara-
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 11
+graph (B) conducted through the Integrated Automated Fingerprint Identification System of the Federal Bureau
+of Investigation.
+B) ELIGIBLE ORGANIZATIONS.--An organization described in this subparagraph is an organization in
+tate not designated under paragraph (2) that has received a request allotment pursuant to subparagraph (C
+*657 (C) REQUEST ALLOTMENTS.--The following organizations may allot requests as follows:
+(i) 33,334 for the Boys and Girls Clubs of America.
+(ii) 33,333 for the National Mentoring Partnership.
+(iii) 33,333 for the National Council of Youth Sports.
+(D) PROCEDURES.--The Attorney General shall notify the organizations described in subparagraph (C) of a
+process by which the organizations may provide fingerprint cards to the Attorney General.
+(E) VOLUNTEER INFORMATION REQUIRED.--An organization authorized to request a background check
+under this paragraph shall--
+(i) forward to the Attorney General the volunteer's fingerprints; and
+(ii) obtain a statement completed and signed by the volunteer that--
+(I) sets out the provider or volunteer's name, address, date of birth appearing on a valid identification document as defined in section 1028 of title 18, United States Code, and a photocopy of the valid identifying docu- ment
+(II) states whether the volunteer has a criminal record, and, if so, sets out the particulars of such record;
+III) notifies the volunteer that the Attorney General may perform a criminal history background check an
+hat the volunteer's signature to the statement constitutes an acknowledgment that such a check may be conduc- ted
+(IV) notifies the volunteer that prior to and after the completion of the background check, the organization
+may choose to deny the provider access to children; and
+(L) notifies the volunteer of his right to correct an erroneous record held by the Attorney General.
+the rin History ary a karound cocks pe National Centi or ish, he Exploy neil en l provide
+business days after receiving the request from the organization.
+(G) DETERMINATIONS OF FITNESS.--
+(i) IN GENERAL.--Consistent with the privacy protections delineated in the National Child Protection Act
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 12
+provider or volunteer unfit to provide care to children based upon criteria established jointly, the National Center for Missing and Exploited Children, the Boys and Girls Clubs of America, the National Mentoring Partnership, and the National Council of Youth Sports.
+58 (ii) CHILD SAFETY PILOT PROGRAM.--The National Center for Missing and Exploited Childr
+all convey that determination to the organizations making requests under this paragrap
+graph (2) or (3).
+b) RIGHTS OF VOLUNTEERS.--Each volunteer who is the subject of a criminal history background check un
+er this section is entitled to contact the Attorney General to initiate procedures to-
+(1) obtain a copy of their criminal history record report; and
+(2) challenge the accuracy and completeness of the criminal history record information in the report.
+(c) AUTHORIZATION OF APPROPRIATIONS.-
+(1) IN GENERAL.--There is authorized to be appropriated such sums as may be necessary to the National Center for Missing and Exploited Children for fiscal years 2004 and 2005 to carry out the requirements of this sec-tion.
+(2) STATE PROGRAM.--There is authorized to be appropriated such sums as may be necessary to the Attorney
+General for the States designated in subsection (a)(1) for fiscal years 2004 and 2005 to establish and enhance
+finger print technology infrastructure of the participating State.
+(d) FEASIBILITY STUDY FOR A SYSTEM OF BACKGROUND CHECKS FOR EMPLOYEES AND VO-
+LUNTEERS.--
+(1) STUDY REQUIRED.--The Attorney General shall conduct a feasibility study within 180 days after the date
+of the enactment of this Act. The study shall examine, to the extent discernible, the following:
+(A) The current state of fingerprint capture and processing at the State and local level, including the current
+available infrastructure, State system capacities, and the time for each State to process a civil or volunteer print
+from the time of capture to submission to the Federal Bureau of Investigation (FBI).
+(B) The intent of the States concerning participation in a nationwide system of criminal background checks to
+provide information to qualified entities.
+(C) The number of volunteers, employees, and other individuals that would require a fingerprint-based criminal background check.
+(D) The impact on the Integrated Automated Fingerprint Identification System (IAFIS) of the Federal Bureau
+of Investigation in terms of capacity and impact on other users of the system, including the effect on Federal
+Bureau of Investigation work practices and staffing levels.
+(E) The current fees charged by the Federal Bureau of Investigation, States and local agencies, and private
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 13
+companies to process fingerprints and conduct background checks.
+(F) The existence of "model" or best practice programs which could easily be expanded and duplicated in other States.
+(G) The extent to which private companies are currently performing background checks and the possibility
+*659 of using private companies in the future to perform any of the background check process, including, but
+not limited to, the capture and transmission of fingerprints and fitness determinations.
+(H) The cost of development and operation of the technology and the infrastructure necessary to establish a
+nationwide fingerprint-based and other criminal background check system.
+(I) The extent of State participation in the procedures for background checks authorized in the National Child
+Protection Act (Public Law 103-209), as amended by the Volunteers for Children Act (sections 221 and 222 of
+Public Law 105-251).
+(J) The extent to which States currently provide access to nationwide criminal history background checks to
+organizations that serve children.
+(K) The extent to which States currently permit volunteers to appeal adverse fitness determinations, and
+whether similar procedures are required at the Federal level.
+(L) The implementation of the 2 pilot programs created in subsection (a).
+(M) Any privacy concerns that may arise from nationwide criminal background checks.
+(N) Any other information deemed relevant by the Department of Justice.
+the elderly, or the disabled.
+TITLE II-INVESTIGATIONS AND PROSECUTIONS
+< 18 USCA § 2516 >>
+SEC. 201. INTERCEPTIONS OF COMMUNICATIONS IN INVESTIGATIONS OF SEX OFFENSES.
+Section 2516(1) of title 18, United States Code, is amended--
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 14
+« 18 USCA § 2516 >>
+*660 (1) in paragraph (a), by inserting after "chapter 37 (relating to espionage)," the following: "chapter 55
+(relating to kidnapping),"; and
+<< 18 USCA § 2516>>
+(2) in paragraph (c) -
+(A) by inserting "section 1591 (sex trafficking of children by force, fraud, or coercion)," after "section 1511
+(obstruction of State or local law enforcement),"; and
+(B) by inserting "section 2251A (selling or buying of children), section 2252A (relating to material constituting or containing child pornography), section 1466A (relating to child obscenity), section 2260 (production of
+exually explicit depictions of a minor for importation into the United States), sections 2421, 2422, 2423, an
+425 (relating to transportation for illegal sexual activity and related crimes)." after "sections 2251 and 225
+(sexual exploitation of children),".
+<< 18 USCA § 3283 >>
+SEC. 202. NO STATUTE OF LIMITATIONS FOR CHILD ABDUCTION AND SEX CRIMES.
+Section 3283 of title 18, United States Code, is amended to read as follows:
+"§ 3283. Offenses against children
+al suse, of liains or a could nervie age tr de rosestion per and fence proteing the see or a or
+<< 18 USCA § 3142>>
+SEC. 203. NO PRETRIAL RELEASE FOR THOSE WHO RAPE OR KIDNAP CHILDREN.
+Section 3142(e) of title 18, United States Code, is amended--
+(1) by striking "1901 et seq.), or" and inserting "1901 et seq.),"; and
+(2) by striking "of title 18 of the United States Code" and inserting "of this title, or an offense involving a minor
+victim under section 1201, 1591, 2241, 2242, 2244(a)(1), 2245, 2251, 2251A, 2252(a)(1), 2252(a)(2),
+2252(a)(3), 2252A(a)(1), 2252A(a)(2), 2252A(a)(3), 2252A(a)(4), 2260, 2421, 2422, 2423, or 2425 of this title".
+« 42 USCA § 5779»>
+SEC. 204. SUZANNE'S LAW.
+Section 3701(a) of the Crime Control Act of 1990 (42 U.S.C. 5779(a)) is amended by striking "age of 18" and
+inserting "age of 21".
+TITLE III-PUBLIC OUTREACH
+Subtitle A-AMBER Alert
+« 42 USCA § 5791>>
+SEC. 301. NATIONAL COORDINATION OF AMBER ALERT COMMUNICATIONS NETWORK.
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full.. 2/27/2008
+
+
+
+Page 15
+(a) COORDINATION WITHIN DEPARTMENT OF JUSTICE.--The Attorney General shall assign an officer of
+the Department of Justice to act as the national coordinator of the AMBER Alert communications network regarding abducted children. The officer so designated shall be known as the AMBER Alert Coordinator of the
+Department of Justice.
+*661 (b) DUTIES.-In acting as the national coordinator of the AMBER Alert communications network, the Co-
+ordinator shall--
+(1) seek to eliminate gaps in the network, including gaps in areas of interstate travel;
+(2) work with States to encourage the development of additional elements (known as local AMBER plans) in the
+network;
+(3) work with States to ensure appropriate regional coordination of various elements of the network; and
+(4) act as the nationwide point of contact for--
+(A) the development of the network; and
+(B) regional coordination of alerts on abducted children through the network.
+(c) CONSULTATION WITH FEDERAL BUREAU OF INVESTIGATION.--In carrying out duties under subsection (b), the Coordinator shall notify and consult with the Director of the Federal Bureau of Investigation
+concerning each child abduction for which an alert is issued through the AMBER Alert communications net- work.
+(d) COOPERATION.--The Coordinator shall cooperate with the Secretary of Transportation and the Federal
+Communications Commission in carrying out activities under this section.
+e) REPORT.--Not later than March 1, 2005, the Coordinator shall submit to Congress a report on the activitie
+f the Coordinator and the effectiveness and status of the AMBER plans of each State that has implemente
+such a plan. The Coordinator shall prepare the report in consultation with the Secretary of Transportation.
+<< 42 USCA § 5791a >>
+SEC. 302. MINIMUM STANDARDS FOR ISSUANCE AND DISSEMINATION OF ALERTS THROUGH
+AMBER ALERT COMMUNICATIONS NETWORK.
+(a) ESTABLISHMENT OF MINIMUM STANDARDS.--Subject to subsection (b), the AMBER Alert Coordinator of the Department of Justice shall establish minimum standards for--
+(1) the issuance of alerts through the AMBER Alert communications network; and
+(2) the extent of the dissemination of alerts issued through the network.
+(b) LIMITATIONS.--(1) The minimum standards established under subsection (a) shall be adoptable on a voluntary basis only.
+(2) The minimum standards shall, to the maximum extent practicable (as determined by the Coordinator in consultation with State and local law enforcement agencies), provide that appropriate information relating to the
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 16
+special needs of an abducted child (including health care needs) are disseminated to the appropriate law enforcement, public health, and other public officials.
+3) The minimum standards shall, to the maximum extent practicable (as determined by the Coordinator in cor
+ultation with State and local law enforcement agencies), provide that the dissemination of an alert through th
+AMBER Alert communications network be limited to the geographic areas most likely to facilitate the recovery
+of the abducted child concerned.
+4) In carrying out activities under subsection (a), the Coordinator may not interfere with the current system c
+oluntary coordination between local broadcasters and State and local law enforcement agencies for purposes o
+the AMBER Alert communications network.
+*662 (c) COOPERATION.--(1) The Coordinator shall cooperate with the Secretary of Transportation and the
+Federal Communications Commission in carrying out activities under this section.
+(2) The Coordinator shall also cooperate with local broadcasters and State and local law enforcement agencies in
+establishing minimum standards under this section.
+<< 42 USCA § 5791b >>
+SEC. 303. GRANT PROGRAM FOR NOTIFICATION AND COMMUNICATIONS SYSTEMS ALONG
+HIGHWAYS FOR RECOVERY OF ABDUCTED CHILDREN.
+(a) PROGRAM REQUIRED.--The Secretary of Transportation shall carry out a program to provide grants to
+States for the development or enhancement of notification or communications systems along highways for alerts
+and other information for the recovery of abducted children.
+(b) DEVELOPMENT GRANTS.--
+(1) IN GENERAL.--The Secretary may make a grant to a State under this subsection for the development of a
+State program for the use of changeable message signs or other motorist information systems to notify motorists
+about abductions of children. The State program shall provide for the planning, coordination, and design of systems, protocols, and message sets that support the coordination and communication necessary to notify motorists
+about abductions of children.
+(2) ELIGIBLE ACTIVITIES.--A grant under this subsection may be used by a State for the following purposes:
+(A) To develop general policies and procedures to guide the use of changeable message signs or other motorist
+information systems to notify motorists about abductions of children.
+3) To develop guidance or policies on the content and format of alert messages to be conveyed on changeab
+essage signs or other traveler information system
+(C) To coordinate State, regional, and local plans for the use of changeable message signs or other transportation related issues.
+) To plan secure and reliable communications systems and protocols among public safety and transportati
+gencies or modify existing communications systems to support the notification of motorists about abductions
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 17
+(E) To plan and design improved systems for communicating with motorists, including the capability for issuing wide area alerts to motorists.
+(F) To plan systems and protocols to facilitate the efficient issuance of child abduction notification and other
+key information to motorists during off-hours.
+message signs and trainina end guidamat o systems farion antrates to fairist apor alade tie o hai cabie
+(c) IMPLEMENTATION GRANTS.-
+(1) IN GENERAL.--The Secretary may make a grant to a State under this subsection for the implementation of a
+rogram for the use of changeable message signs or other motorist information systems to notify motorists abo
+bductions of *663 children. A State shall be eligible for a grant under this subsection if the Secretary deter
+ines that the State has developed a State program in accordance with subsection (b).
+(2) ELIGIBLE ACTIVITIES.--A grant under this subsection may be used by a State to support the implementaon of systems that use changeable message signs or other motorist information systems to notify motoris
+bout abductions of children. Such support may include the purchase and installation of changeable messag
+signs or other motorist information systems to notify motorists about abductions of children.
+(d) FEDERAL SHARE.--The Federal share of the cost of any activities funded by a grant under this section may
+not exceed 80 percent.
+period prescribed by the Secretary.
+(f) ADMINISTRATION.--The Secretary shall prescribe requirements, including application requirements, for
+the receipt of grants under this section.
+(g) DEFINITION.--In this section, the term "State" means any of the 50 States, the District of Columbia, or Pu-
+erto Rico.
+h) AUTHORIZATION OF APPROPRIATIONS.--There is authorized to be appropriated to the Secretary t
+arry out this section $20,000,000 for fiscal year 2004. Such amounts shall remain available until expended
+(i) STUDY OF STATE PROGRAMS.--
+I) STUDY.--The Secretary shall conduct a study to examine State barriers to the adoption and implementatio
+i State programs for the use of communications systems along highways for alerts and other information for tl
+recovery of abducted children.
+2) REPORT.-Not later than 1 year after the date of enactment of this Act, the Secretary shall transmit to Cor
+ress a report on the results of the study, together with any recommendations the Secretary determines appropri- ate
+https://web2.westlaw.com/print/printstream.aspx?prfl=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 18
+« 42 USCA § 5791c >>
+SEC. 304. GRANT PROGRAM FOR SUPPORT OF AMBER ALERT COMMUNICATIONS PLANS.
+(b) ACTIVITIES.-Activities funded by grants under the program under subsection (a) may include-.
+(1) the development and implementation of education and training programs, and associated materials, relating
+to AMBER Alert communications plans;
+(2) the development and implementation of law enforcement programs, and associated equipment, relating to
+AMBER Alert communications plans;
+(3) the development and implementation of new technologies to improve AMBER Alert communications; and
+(4) such other activities as the Attorney General considers appropriate for supporting the AMBER Alert communications program.
+*664 (c) FEDERAL SHARE.--The Federal share of the cost of any activities funded by a grant under the program under subsection (a) may not exceed 50 percent.
+(d) DISTRIBUTION OF GRANT AMOUNTS ON GEOGRAPHIC BASIS.--The Attorney General shall, to the
+maximum extent practicable, ensure the distribution of grants under the program under subsection (a) on a
+equitable basis throughout the various regions of the United States
+(e) ADMINISTRATION.--The Attorney General shall prescribe requirements, including application requirements, for grants under the program under subsection (a).
+(f) AUTHORIZATION OF APPROPRIATIONS.-(1) There is authorized to be appropriated for the Departmen
+of Justice $5,000,000 for fiscal year 2004 to carry out this section and, in addition, $5,000,000 for fiscal yea
+2004 to carry out subsection (b)(3).
+(2) Amounts appropriated pursuant to the authorization of appropriations in paragraph (1) shall remain available
+until expended.
+< 42 USCA § 5791d >>
+SEC. 305. LIMITATION ON LIABILITY.
+(a) Except as provided in subsection (b), the National Center for Missing and Exploited Children, including any
+plaint intake or forwarding program or in connection with activity that is wholly or partially funded by the
+United States and undertaken in cooperation with, or at the direction of a Federal law enforcement agency
+(b) The limitation in subsection (a) does not apply in any action in which the plaintiff proves that the National
+Center for Missing and Exploited Children, its officers, employees, or agents acted with actual malice, or
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full.. 2/27/2008
+
+
+
+PL. 108-21, 2003 S 151
+Page 19
+provided information or took action for a purpose unrelated to an activity mandated by Federal law. For purprep orited suren shale deemed, pre, se, obe an activity mand ted by Federal lavery, or protection of missing
+Subtitle B--National Center for Missing and Exploited Children
+SEC. 321. INCREASED SUPPORT.
+<< 42 USCA § 5777>>
+(a) IN GENERAL.--Section 408(a) of the Missing Children's Assistance Act (42 U.S.C. 5777(a)) is amended by
+striking "fiscal years 2000 through 2003" and inserting "fiscal years 2004 through 2005.".
+<< 42 USCA § 5773>>
+(b) ANNUAL GRANT TO NATIONAL CENTER FOR MISSING AND EXPLOITED CHILDREN.-- Section
+104(b)(2) of the Missing Children's Assistance Act (42 U.S.C. 5773(b)(2)) is amended by striking "$10,000,000
+for each of fiscal years 2000, 2001, 2002, and 2003" and inserting "S20,000,000 for each of the fiscal years 2004
+through 2005".
+<< 18 USCA § 3056>>
+*665 SEC. 322. FORENSIC AND INVESTIGATIVE SUPPORT OF MISSING AND EXPLOITED CHIL- DREN.
+Section 3056 of title 18, United States Code, is amended by adding at the end the following:
+"(f) Under the direction of the Secretary of Homeland Security, officers and agents of the Secret Service are authorized, at the request of any State or local law enforcement agency, or at the request of the National Center for
+Missing and Exploited Children, to provide forensic and investigative assistance in support of any investigation
+involving missing or exploited children.".
+SEC. 323. CREATION OF CYBER TIPLINE.
+Section 404(b)(1) of the Missing Children's Assistance Act (42 U.S.C. 5773(b)(1)) is amended--
+<< 42 USCA § 5773 >>
+(1) in subparagraph (F), by striking "and" at the end;
+<<42 USCA § 5773>>
+(2) in subparagraph (G), by striking the period at the end and inserting "; and"; and
+<< 42 USCA § 5773 >>
+(3) by adding at the end the following:
+"(H) coordinate the operation of a cyber tipline to provide online users an effective means of reporting Internet-related child sexual exploitation in the areas of--
+"(i) distribution of child pornography;
+"(ii) online enticement of children for sexual acts; and
+"(iii) child prostitution.".
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 20
+Subtitle C--Sex Offender Apprehension Program
+SEC. 341. AUTHORIZATION.
+Section 1701(d) of part Q of title I of the Omnibus Crime Control and Safe Streets Act of 1968 (42 U.S.C.
+3796dd(d)) is amended--
+<< 42 USCA § 3796dd >>
+(1) by redesignating paragraphs (10) and (11) as (11) and (12), respectively; and
+< 42 USCA § 3796dd >>
+(2) by inserting after paragraph (9) the following:
+(10) assist a State in enforcing a law throughout the State which requires that a convicted sex offender registe
+is or her address with a State or local law enforcement agency and be subject to criminal prosecution for failur
+to comply;".
+Subtitle D--Missing Children Procedures in Public Buildings
+< 42 USCA § 5601 NOTE >>
+SEC. 361. SHORT TITLE.
+This subtitle may be cited as the "Code Adam Act of 2003".
+< 42 USCA § 5792 >>
+SEC. 362. DEFINITIONS.
+In this subtitle, the following definitions apply:
+(1) CHILD.--The term "child" means an individual who is 17 years of age or younger.
+(2) CODE ADAM ALERT.--The term "Code Adam alert" means a set of procedures used in public buildings to
+alert employees and other users of the building that a child is missing.
+*666 (3) DESIGNATED AUTHORITY.--The term "designated authority" means--
+(A) with respect to a public building owned or leased for use by an Executive agency--
+(i) except as otherwise provided in this paragraph, the Administrator of General Services;
+(ii) in the case of the John F. Kennedy Center for the Performing Arts, the Board of Trustees of the John F.
+Kennedy Center for the Performing Arts;
+(iii) in the case of buildings under the jurisdiction, custody, and control of the Smithsonian Institution, the
+Board of Regents of the Smithsonian Institution; or
+iris he get of nother, bie buiding for which in the tied of that as, by specific or general statutory
+(B) with respect to the Supreme Court Building, the Marshal of the Supreme Court; with respect to the Thurgood Marshall Federal Judiciary Building, the Director of the Administrative Office of United States Courts; and
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 21
+with respect to all other public buildings owned or leased for use by an establishment in the judicial branch of
+government, the General Services Administration in consultation with the United States Marshals Service; and
+(C) with respect to a public building owned or leased for use by an establishment in the legislative branch of
+government, the Capitol Police Board.
+(4) EXECUTIVE AGENCY.--The term "Executive agency" has the same meaning such term has under section
+105 of title 5, United States Code.
+(5) FEDERAL AGENCY.--The term "Federal agency" means any Executive agency or any establishment in the
+legislative or judicial branches of the Government.
+(6) PUBLIC BUILDING.--The term "public building" means any building (or portion thereof) owned or leased
+for use by a Federal agency.
+« 42 USCA § 5792a »>
+SEC. 363. PROCEDURES IN PUBLIC BUILDINGS REGARDING A MISSING OR LOST CHILD.
+a) IN GENERAL.--Not later than 180 days after the date of enactment of this Act, the designated authority for
+ublic building shall establish procedures for locating a child that is missing in the buildin
+(b) NOTIFICATION AND SEARCH PROCEDURES.--Procedures established under this section shall provide,
+at a minimum, for the following:
+(1) Notifying security personnel that a child is missing.
+(2) Obtaining a detailed description of the child, including name, age, eye and hair color, height, weight, clothing, and shoes.
+(3) Issuing a Code Adam alert and providing a description of the child, using a fast and effective means of communication.
+(4) Establishing a central point of contact.
+(5) Monitoring all points of egress from the building while a Code Adam alert is in effect.
+(б) Conducting a thorough search of the building.
+*667 (7) Contacting local law enforcement.
+(8) Documenting the incident.
+Subtitle E--Child Advocacy Center Grants
+SEC. 381. INFORMATION AND DOCUMENTATION REQUIRED BY ATTORNEY GENERAL UNDER
+VICTIMS OF CHILD ABUSE ACT OF 1990.
+(a) REGIONAL CHILDREN'S ADVOCACY CENTERS.--Section 213 of the Victims of Child Abuse Act of
+1990 (42 U.S.C. 13001b) is amended--
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full.. 2/27/2008
+
+
+
+Page 22
+(1) in subsection (c)(4)--
+<< 42 USCA § 13001b>>
+(A) by striking "and" at the end of subparagraph (B)(ii);
+< 42 USCA § 13001b>>
+(B) in subparagraph (B)(iii), by striking "Board" and inserting "board"; and
+<< 42 USCA § 1300lb >>
+(C) by redesignating subparagraphs (C) and (D) as clauses (iv) and (D, respectively, of subparagraph (B), and
+by realigning such clauses so as to have the same indentation as the preceding clauses of subparagraph (B); and
+(2) in subsection (e), by striking "Board" in each of paragraphs (1)(B)(ii), (2)(A), and (3), and inserting "board".
+<<42 USCA § 13004>>
+(b) AUTHORIZATION OF APPROPRIATIONS.--The text of section 214B of such Act (42 U.S.C. 13004) is
+amended to read as follows:
+"(a) SECTIONS 213 AND 214.--There are authorized to be appropriated to carry out sections 213 and 214,
+$15,000,000 for each of fiscal years 2004 and 2005.
+"(b) SECTION 214A.--There are authorized to be appropriated to carry out section 214A, $5,000,000 for each of
+fiscal years 2004 and 2005.".
+TITLE IV-SENTENCING REFORM
+SEC. 401. SENTENCING REFORM.
+(a) ENFORCEMENT OF SENTENCING GUIDELINES FOR CHILD ABDUCTION AND SEX OF-
+FENSES.--Section 3553(b) of title 18, United States Code is amended--
+« 18 USCA § 3553>>
+(1) by striking "The court" and inserting the following:
+"(1) IN GENERAL.--Except as provided in paragraph (2), the court"; and
+<< 18 USCA § 3553 >>
+(2) by adding at the end the following:
+"(2) CHILD CRIMES AND SEXUAL OFFENSES.--
+"i) the court finds that there exists an aggravating circumstance of a kind, or to a degree, not adequately
+aken into consideration by the Sentencing Commission in formulating the guidelines that should result in a sentence greater than that described;
+"(ii) the court finds that there exists a mitigating circumstance of a kind or to a degree, that-
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full. 2/27/2008
+
+
+
+Page 23
+"(II) has not been taken into consideration by the Sentencing Commission in formulating the guidelines; and
+"(III) should result in a sentence different from that described; or
+impose an appropriate sentence, having due regard for the purposes set forth in subsection (a)(2). In the absence
+of an applicable sentencing guideline in the case of an offense other than a petty offense, the court shall also
+have due regard for the relationship of the sentence imposed to sentences prescribed by guidelines applicable to
+similar offenses and offenders, and to the applicable policy statements of the Sentencing Commission, together
+with any amendments to such guidelines or policy statements by act of Congress.".
+<< 28 USCA § 994 NOTE >>
+(b) CONFORMING AMENDMENTS TO GUIDELINES MANUAL.--The Federal Sentencing Guidelines are
+amended--
+(1) in section 5K2.0--
+(A) by striking "Under" and inserting the following:
+"(a) DOWNWARD DEPARTURES IN CRIMINAL CASES OTHER THAN CHILD CRIMES AND SEXUAL
+OFFENSES.--Under"; and
+(B) by adding at the end the following:
+"(b) DOWNWARD DEPARTURES IN CHILD CRIMES AND SEXUAL OFFENSES.--
+Under 18 U.S.C. § 3553(b)(2), the sentencing court may impose a sentence below the range established by th
+pplicable guidelines only if the court finds that there exists a mitigating circumstance of a kind, or to a degree
+"(1) has been affirmatively and specifically identified as a permissible ground of downward departure in the senencing guidelines or policy statements issued under section 994(a) of title 28, United States Code, taking ac
+ount of any amendments to such sentencing guidelines or policy statements by act of Congress
+"(2) has not adequately been taken into consideration by the Sentencing Commission in formulating the
+guidelines; and
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+"(3) should result in a sentence different from that described.
+Page 24
+(2) At the end of part K of chapter 5, add the following:
+"§ 5K2.22 Specific Offender Characteristics as Grounds for Downward Departure in child crimes and sexual offenses (Policy Statement)
+"In sentencing a defendant convicted of an offense under section 1201 involving a minor victim, an offense under section 1591, or an offense under chapter 71, 109A, 110, or 117 of title 18, United States Code, age may be
+a reason to impose a sentence below the applicable guideline range only if and to the extent permitted by § 5H1.1.
+"An extraordinary physical impairment may be a reason to impose a sentence below the applicable guideline
+range only if and to the extent permitted by § SH1.4. Drug, alcohol, or gambling dependence or abuse is not a
+reason for imposing a sentence below the guidelines.
+(3) Section 5K2.20 is amended by striking "A" and inserting "Except where a defendant is convicted of an offense under section 1201 involving a minor victim, an offense under section 1591, or an offense under chapter
+71, 109A, 110, or 117 of title 18, United States Code, a".
+(4) Section 5H1.6 is amended by inserting after the first sentence the following: "In sentencing a defendant convicted of an offense under section 1201 involving a minor victim, an offense under section 1591, or an offense
+under chapter 71, 109A, 110, or 117 of title 18, United States Code, family ties and responsibilities and com-
+(5) Section 5K2.13 is amended by--
+(A) striking "or" before "(3)"; and
+(B) replacing "public" with "public; or (4) the defendant has been convicted of an offense under chapter 71,
+109A, 110, or 117 of title 18, United States Code.".
+<< 18 USCA § 3553 >>
+(c) STATEMENT OF REASONS FOR IMPOSING A SENTENCE.--Section 3553(c) of title 18, United States
+Code, is amended.
+(1) by striking "described." and inserting "described, which reasons must also be stated with specificity in the
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 25
+(2) by inserting ", together with the order of judgment and commitment," after "the court's statement of reasons";
+*670 (3) by inserting "and to the Sentencing Commission," after "to the Probation System".
+(d) REVIEW OF A SENTENCE.--
+« 18 USCA § 3742>>
+(1) REVIEW OF DEPARTURES.--Section 3742(e)(3) of title 18, United States Code, is amended to read as fol-
+"(3) is outside the applicable guideline range, and
+"(A) the district court failed to provide the written statement of reasons required by section 3553(c);
+"(B) the sentence departs from the applicable guideline range based on a factor that--
+"(i) does not advance the objectives set forth in section 3553(a)(2); or
+"(ii) is not authorized under section 3553(b); or
+"(iii) is not justified by the facts of the case; or
+"(C) the sentence departs to an unreasonable degree from the applicable guidelines range, having regard for
+the factors to be considered in imposing a sentence, as set forth in section 3553(a) of this title and the reasons
+for the imposition of the particular sentence, as stated by the district court pursuant to the provisions of section
+3553(c); ог".
+< 42 USCA § 3742 >>
+(2) STANDARD OF REVIEW.--The last paragraph of section 3742(e) of title 18, United States Code, is
+amended by striking "shall give due deference to the district court's application of the guidelines to the facts"
+(3) DECISION AND DISPOSITION.--
+< 18 USCA § 3742 >>
+(A) The first paragraph of section 3742(f) of title 18, United States Code, is amended by striking "the sen- tence";
+« 18 USCA § 3742»
+(B) Section 3742(D)(1) of title 18, United States Code, is amended by inserting "the sentence" before "was imposed";
+« 18 USCA § 3742 >>
+(C) Section 3742(f)(2) of title 18, United States Code, is amended to read as follows:
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 26
+"(2) the sentence is outside the applicable guideline range and the district court failed to provide the required
+tatement of reasons in the order of judgment and commitment, or the departure is based on an impermissibl
+actor, or is to an unreasonable degree, or the sentence was imposed for an offense for which there is no applic
+able sentencing guideline and is plainly unreasonable, it shall state specific reasons for its conclusions and--
+"(A) if it determines that the sentence is too high and the appeal has been filed under subsection (a), it shall set
+aside the sentence and remand the case for further sentencing proceedings with such instructions as the court
+considers appropriate, subject to subsection (g);
+(B) if it determines that the sentence is too low and the appeal has been filed under subsection (b), it shall s
+side the sentence and remand the case for further sentencing proceedings with such instructions as the cou
+considers appropriate, subject to subsection (g);"; and
+<< 18 USCA § 3742>>
+*671 (D) Section 3742(f)(3) of title 18, United States Code, is amended by inserting "the sentence" before "is
+not described".
+<< 18 USCA § 3742 >
+(e) IMPOSITION OF SENTENCE UPON REMAND.--Section 3742 of title 18, United States Code, is amended
+by redesignating subsections (g) and (h) as subsections (h) and (i) and by inserting the following after subsection (f):
+"(g) SENTENCING UPON REMAND.--A district court to which a case is remanded pursuant to subsection
+(f(1) or (f)(2) shall resentence a defendant in accordance with section 3553 and with such instructions as may
+have been given by the court of appeals, except that-
+"(1) In determining the range referred to in subsection 3553(a)(4), the court shall apply the guidelines issued by
+the Sentencing Commission pursuant to section 994(a)(1) of title 28, United States Code, and that were in effect
+on the date of the previous sentencing of the defendant prior to the appeal, together with any amendments
+thereto by any act of Congress that was in effect on such date; and
+"(2) The court shall not impose a sentence outside the applicable guidelines range except upon a ground that--
+"(A) was specifically and affirmatively included in the written statement of reasons required by section
+3553(c) in connection with the previous sentencing of the defendant prior to the appeal; and
+"(B) was held by the court of appeals, in remanding the case, to be a permissible ground of departure.".
+<< 18 USCA § 3742>>
+(f) DEFINITIONS.--Section 3742 of title 18, United States Code, as amended by subsection (e), is further
+amended by adding at the end the following:
+"i) DEFINITIONS.--For purposes of this section--
+"(1) a factor is a 'permissible' ground of departure if it--
+"(A) advances the objectives set forth in section 3553(a)(2); and
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 27
+"(B) is authorized under section 3553(b); and
+"(C) is justified by the facts of the case; and
+"(2) a factor is an 'impermissible' ground of departure if it is not a permissible factor within the meaning of subsection ()(1).".
+« 28 USCA § 994 NOTE >>
+(g) REFORM OF GUIDELINES GOVERNING ACCEPTANCE OF RESPONSIBILITY.--Subject to subsectio
+j, the Guidelines Manual promulgated by the Sentencing Commission pursuant to section 994(a) of title 28
+United States Code, is amended-
+(1) in section 3E1.1(b)-
+(A) by inserting "upon motion of the government stating that" immediately before "the defendant has assisted
+authorities"; and
+(B) by striking "taking one or more" and all that follows through and including "additional level" and insert
+"timely notifying authorities of his intention to enter a plea of guilty, thereby permitting the government to avoid
+preparing for trial and permitting the government and the court to allocate their resources efficiently, decrease
+the offense level by 1 additional level";
+(2) in the Application Notes to the Commentary to section 3E1.1, by amending Application Note 6--
+(A) by striking "one or both of"; and
+*672 (B) by adding the following new sentence at the end: "Because the Government is in the best position to
+determine whether the defendant has assisted authorities in a manner that avoids preparing for trial, an adjust
+ment under subsection (b) may only be granted upon a formal motion by the Government at the time of senten
+cing."; and
+(3) in the Background to section 3E1.1, by striking "one or more of".
+<< 28 USCA § 994 >>
+(h) IMPROVED DATA COLLECTION.--Section 994(w) of title 28, United States Code, is amended to read as
+the guidelines. The report shall also include--
+"(A) the judgment and commitment order;
+"(B) the statement of reasons for the sentence imposed (which shall include the reason for any departure from
+the otherwise applicable guideline range);
+"(C) any plea agreement;
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 28
+"(D) the indictment or other charging document;
+"(E) the presentence report; and
+"(F) any other information as the Commission finds appropriate.
+(2) The Commission shall, upon request, make available to the House and Senate Committees on the Judiciary
+he written reports and all underlying records accompanying those reports described in this section, as well a
+other records received from courts.
+"(3) The Commission shall submit to Congress at least annually an analysis of these documents, any recomnendations for legislation that the Commission concludes is warranted by that analysis, and an accounting of
+hose districts that the Commission believes have not submitted the appropriate information and documents re
+quired by this section.
+"(4) The Commission shall make available to the Attorney General, upon request, such data files as the Commission may assemble or maintain in electronic form that include any information submitted under paragraph (1).
+Such data files shall be made available in electronic form and shall include all data fields requested, including
+the identity of the sentencing judge.".
+‹< 28 USCA § 994 NOTE >>
+(i) SENTENCING GUIDELINES AMENDMENTS.--(1) Subject to subsection (i), the Guidelines Manual promulgated by the Sentencing Commission pursuant to section 994(a) of title 28, United States Code, is amended
+(A) Application Note 4(b)(i) to section 4B1.5 is amended to read as follows:
+"(i) IN GENERAL.--For purposes of subsection (b), the defendant engaged in a pattern of activity involving
+prohibited sexual conduct if on at least two separate occasions, the defendant engaged in prohibited sexual con
+duct with a minor.".
+(B) Section 2G2.4(b) is amended by adding at the end the following:
+*673 "(4) If the offense involved material that portrays sadistic or masochistic conduct or other depictions of violence, increase by 4 levels.
+"(5) If the offense involved--
+"(A) at least 10 images, but fewer than 150, increase by 2 levels;
+"(B) at least 150 images, but fewer than 300, increase by 3 levels;
+"(C) at least 300 images, but fewer than 600, increase by 4 levels; and
+"(D) 600 or more images, increase by 5 levels.".
+(C) Section 2G2.2(b) is amended by adding at the end the following:
+"(6) If the offense involved--
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full.. 2/27/2008
+
+
+
+Page 29
+"(A) at least 10 images, but fewer than 150, increase by 2 levels;
+"(B) at least 150 images, but fewer than 300, increase by 3 levels;
+"(C) at least 300 images, but fewer than 600, increase by 4 levels; and
+"(D) 600 or more images, increase by 5 levels.".
+« 28 USCA § 994 NOTE »>
+2) The Sentencing Commission shall amend the Sentencing Guidelines to ensure that the Guidelines adequatel
+eflect the seriousness of the offenses under sections 2243(b), 2244(a)(4), and 2244(b) of title 18, United State
+() CONFORMING AMENDMENTS.-
+< 28 USCA § 994 NOTE >>
+(1) Upon enactment of this Act, the Sentencing Commission shall forthwith distribute to all courts of the United
+States and to the United States Probation System the amendments made by subsections (b), (g), and (i) of this
+section to the sentencing guidelines, policy statements, and official commentary of the Sentencing Commission.
+These amendments shall take effect upon the date of enactment of this Act, in accordance with paragraph (5).
+< 28 USCA § 994 NOTE >>
+cing suit bees Molicy s2a001, the sentencial Commisiny hath preming camamn at to the sententwith any amendment made by subsection (b) or that adds any new grounds of downward departure to Part K of
+<< 28 USCA § 994 NOTE >>
+(3) With respect to cases covered by the amendments made by subsection (i) of this section, the Sentencing
+Commission may make further amendments to the sentencing guidelines, policy statements, or official commentary of the Sentencing Commission, except that the Commission shall not promulgate any amendments that
+with respect to such cases, would result in sentencing ranges that are lower than those that would have applied
+<< 28 USCA § 994 NOTE >>
+(4) At no time may the Commission promulgate any amendment that would alter or repeal the amendments
+made by subsection (g) of this section.
+(5) Section 3553(a) of title 18, United States Code, is amended--
+< 18 USCA § 3553 >>
+(A) by amending paragraph (4)(A) to read as follows:
+"(A) the applicable category of offense committed by the applicable category of defendant as set forth in the
+guidelines--
+sube any and by the mention co guideline by at to congres 9gaydles gales or 2et, er sited sae coat,
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 30
+have yet to be incorporated by the Sentencing Commission into amendments issued under section 994(p) of title
+28); and
+"(ii) that, except as provided in section 3742(g), are in effect on the date the defendant is sentenced; or";
+« 18 USCA § 3553 >>
+(B) in paragraph (4)(B), by inserting ", taking into account any amendments made to such guidelines or policy
+statements by act of Congress (regardless of whether such amendments have yet to be incorporated by the Sentencing Commission into amendments issued under section 994(p) of title 28)" after "Code";
+«< 18 USCA § 3553>>
+(C) by amending paragraph (5) to read as follows:
+"(5) any pertinent policy statement--
+"(A) issued by the Sentencing Commission pursuant to section 994(a)(2) of title 28, United States Code, subject to any amendments made to such policy statement by act of Congress (regardless of whether such amend
+nents have yet to be incorporated by the Sentencing Commission into amendments issued under section 994(p
+"(B) that, except as provided in section 3742(g), is in effect on the date the defendant is sentenced.".
+<< 28 USCA § 994>>
+) COMPLIANCE WITH STATUTE.--Section 994(a) of title 28, United States Code, is amended by striki
+onsistent with all pertinent provisions of this title and title 18, United States Code," and inserting "consiste
+with all pertinent provisions of any Federal statute".
+< 18 USCA § 3553 NOTE >>
+(1) REPORT BY ATTORNEY GENERAL.--
+(1) DEFINED TERM.--For purposes of this section, the term "report described in paragraph (3)" means a report,
+submitted by the Attorney General, which states in detail the policies and procedures that the Department of
+Justice has adopted subsequent to the enactment of this Act--
+(A) to ensure that Department of Justice attorneys oppose sentencing adjustments, including downward departures, that are not supported by the facts and the law;
+(B) to ensure that Department of Justice attorneys in such cases make a sufficient record so as to permit the
+possibility of an appeal;
+(C) to delineate objective criteria, specified by the Attorney General, as to which such cases may warrant consideration of an appeal, either because of the nature or magnitude of the sentencing error, its prevalence in the
+district, or its prevalence with respect to a particular judge;
+D) to ensure that Department of Justice attorneys promptly notify the designated Department of Justice com
+onent in Washington concerning such adverse sentencing decisions; ano
+(E) to ensure the vigorous pursuit of appropriate and meritorious appeals of such adverse decisions.
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 31
+(2) REPORT REQUIRED.-
+*675 (A) IN GENERAL.--Not later than 15 days after a district court's grant of a downward departure in any
+case, other than a case involving a downward departure for substantial assistance to authorities pursuant to section 5K1.1 of the United States Sentencing Guidelines, the Attorney General shall submit a report to the Committees on the Judiciary of the House of Representatives and the Senate containing the information described under subparagraph (B).
+(B) CONTENTS.--The report submitted pursuant to subparagraph (A) shall set forth--
+(i) the case;
+(ii) the facts involved;
+(iii) the identity of the district court judge;
+(iv) the district court's stated reasons, whether or not the court provided the United States with advance notice
+of its intention to depart; and
+( the position of the parties with respect to the downward departure, whether or not the United States has
+filed, or intends to file, a motion for reconsideration.
+(C) APPEAL OF THE DEPARTURE.--Not later than 5 days after a decision by the Solicitor General regarding the authorization of an appeal of the departure, the Attorney General shall submit a report to the Committees
+on the Judiciary of the House of Representatives and the Senate that describes the decision of the Solicitor General and the basis for such decision.
+(3) EFFECTIVE DATE.--Paragraph (2) shall take effect on the day that is 91 days after the date of enactment of
+this Act, except that such paragraph shall not take effect if not more than 90 days after the date of enactment of
+this Act the Attorney General has submitted to the Judiciary Committees of the House of Representatives and
+the Senate the report described in paragraph (3).
+< 28 USCA § 994 NOTE >>
+(m) REFORM OF EXISTING PERMISSIBLE GROUNDS OF DOWNWARD DEPARȚURES.-Not later than
+180 days after the enactment of this Act, the United States Sentencing Commission shall--
+(1) review the grounds of downward departure that are authorized by the sentencing guidelines, policy statements, and official commentary of the Sentencing Commission; and
+(2) promulgate, pursuant to section 994 of title 28, United States Code--
+(A) appropriate amendments to the sentencing guidelines, policy statements, and official commentary to ensure that the incidence of downward departures are substantially reduced;
+B) a policy statement authorizing a downward departure of not more than 4 levels if the Government files
+notion for such departure pursuant to an early disposition program authorized by the Attorney General and th
+United States Attorney; and
+(C) any other conforming amendments to the sentencing guidelines, policy statements, and official comment-
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 32
+ary of the Sentencing Commission necessitated by this Act, including a revision of paragraph 4(b) of part A of
+chapter 1 and a revision of section 5K2.0.
+(n) COMPOSITION OF SENTENCING COMMISSION.--
+« 28 USCA § 991>>
+*676 (1) IN GENERAL.-Section 991(a) of title 28, United States Code, is amended by striking "At least three"
+and inserting "Not more than 3".
+« 28 USCA § 991 NOTE »>
+(2) APPLICABILITY.--The amendment made under paragraph (1) shall not apply to any person who is serving,
+or who has been nominated to serve, as a member of the Sentencing Commission on the date of enactment of
+this Act.
+TITLE |-OBSCENITY AND PORNOGRAPHY
+Subtitle A--Child Obscenity and Pornography Prevention
+<< 18 USCA § 2251 NOTE >>
+SEC. 501. FINDINGS.
+Congress finds the following:
+(1) Obscenity and child pornography are not entitled to protection under the First Amendment under Miller
+California, 413 U.S. 15 (1973) (obscenity), or New York | Ferber, 458 U.S. 747 (1982) (child pornography)
+and thus may be prohibited.
+(2) The Government has a compelling state interest in protecting children from those who sexually exploit them,
+including both child molesters and child pornographers. "The prevention of sexual exploitation and abuse o
+hildren constitutes a government objective of surpassing importance," New York | - Ferber, 458 U.S. 747, 75
+(1982), and this interest extends to stamping out the vice of child pornography at all levels in the distribution
+chain. Osborne | Ohio, 495 U.S. 103, 110 (1990).
+(3) The Government thus has a compelling interest in ensuring that the criminal prohibitions against child pornography remain enforceable and effective. "The most expeditious if not the only practical method of law enforcement may be to dry up the market for this material by imposing severe criminal penalties on persons
+selling, advertising, or otherwise promoting the product." Ferber, 458 U.S. at 760.
+(4) In 1982, when the Supreme Court decided Ferber, the technology did not exist to:
+(A) computer generate depictions of children that are indistinguishable from depictions of real children;
+8) a paris of images of mat chiden to coate can posite image die is riderial era particular child
+(C) disguise pictures of real children being abused by making the image look computer-generated.
+(5) Evidence submitted to the Congress, including from the National Center for Missing and Exploited Children,
+demonstrates that technology already exists to disguise depictions of real children to make them unidentifiable
+and to make depictions of real children appear computer-generated. The technology will soon exist, if it does not
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full.. 2/27/2008
+
+
+
+Page 33
+already, to computer generate realistic images of children.
+*677 (6) The vast majority of child pornography prosecutions today involve images contained on computer hard
+drives, computer disks, and/or related media.
+(7) There is no substantial evidence that any of the child pornography images being trafficked today were made
+other than by the abuse of real children. Nevertheless, technological advances since Ferber have led many crimsisting that the government prove beyond a reasonable doubt that the images are not computer-generated. Such
+(8) Child pornography circulating on the Internet has, by definition, been digitally uploaded or scanned into
+computers and has been transferred over the Internet, often in different file formats, from trafficker to trafficker.
+An image seized from a collector of child pornography is rarely a first-generation product, and the retransmission of images can alter the image so as to make it difficult for even an expert conclusively to opine that a particular image depicts a real child. If the original image has been scanned from a paper version into a digital
+format, this task can be even harder since proper forensic assessment may depend on the quality of the image
+scanned and the tools used to scan it.
+(9) The impact of the Free Speech Coalition decision on the Government's ability to prosecute child pornography offenders is already evident. The Ninth Circuit has seen a significant adverse effect on prosecutions since
+the 1999 Ninth Circuit Court of Appeals decision in Free Speech Coalition. After that decision, prosecutions
+generally have been brought in the Ninth Circuit only in the most clear-cut cases in which the government can
+specifically identify the child in the depiction or otherwise identify the origin of the image. This is a fraction of
+meritorious child pornography cases. The National Center for Missing and Exploited Children testified that, in
+light of the Supreme Court's affirmation of the Ninth Circuit decision, prosecutors in various parts of the country
+have expressed concern about the continued viability of previously indicted cases as well as declined potentially
+meritorious prosecutions.
+(10) Since the Supreme Court's decision in Free Speech Coalition, defendants in child pornography cases have
+almost universally raised the contention that the images in question could be virtual, thereby requiring the government, in nearly every child pornography prosecution, to find proof that the child is real. Some of these defense efforts have already been successful. In addition, the number of prosecutions being brought has been significantly and adversely affected as the resources required to be dedicated to each child pornography case now are
+significantly higher than ever before.
+(11) Leading experts agree that, to the extent that the technology exists to computer generate realistic images of
+child pornography, the cost in terms of time, money, and expertise is--and for the foreseeable future Will remain-
+- prohibitively expensive. As a result, for the foreseeable future, it will be more cost-effective to produce chilo
+ornography using real *678 children. It will not, however, be difficult or expensive to use readily available
+technology to disguise those depictions of real children to make them unidentifiable or to make them appear
+computer-generated.
+(12) Child pornography results from the abuse of real children by sex offenders; the production of child pornography is a byproduct of, and not the primary reason for, the sexual abuse of children. There is no evidence that
+the future development of easy and inexpensive means of computer generating realistic images of children
+would stop or even reduce the sexual abuse of real children or the practice of visually recording that abuse.
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 34
+(13) In the absence of congressional action, the difficulties in enforcing the child pornography laws will continue to grow increasingly worse. The mere prospect that the technology exists to create composite or computergenerated depictions that are indistinguishable from depictions of real children will allow defendants who possess images of real children to escape prosecution; for it threatens to create a reasonable doubt in every case of
+computer images even when a real child was abused. This threatens to render child pornography laws that protect real children unenforceable. Moreover, imposing an additional requirement that the Government prove beyond a reasonable doubt that the defendant knew that the image was in fact a real child--as some courts have
+done-threatens to result in the de facto legalization of the possession, receipt, and distribution of child pornography for all except the original producers of the material.
+(14) To avoid this grave threat to the Government's unquestioned compelling interest in effective enforcement of
+the child pornography laws that protect real children, a statute must be adopted that prohibits a narrowly-defined
+subcategory of images.
+(15) The Supreme Court's 1982 Ferber | New York decision holding that child pornography was not protected
+drove child pornography off the shelves of adult bookstores. Congressional action is necessary now to ensure
+that open and notorious trafficking in such materials does not reappear, and even increase, on the Internet.
+SEC. 502. IMPROVEMENTS TO PROHIBITION ON VIRTUAL CHILD PORNOGRAPHY.
+(a) Section 2256(8) of title 18, United States Code, is amended--
+< 18 USCA § 2256 >>
+(1) so that subparagraph (B) reads as follows:
+"(B) such visual depiction is a digital image, computer image, or computer-generated image that is, or is indistinguishable from, that of a minor engaging in sexually explicit conduct; or":
+<< 18 USCA § 2256 >>
+(2) by striking "; or" at the end of subparagraph (C) and inserting a period; and
+<< 18 USCA § 2256 >>
+(3) by striking subparagraph (D).
+<< 18 USCA § 2256 >>
+(b) Section 2256(2) of title 18, United States Code, is amended to read as follows:
+"(2)(A) Except as provided in subparagraph (B), 'sexually explicit conduct' means actual or simulated--
+*679 "(i) sexual intercourse, including genital-genital, oral-genital, anal-genital, or oral-anal, whether betwee
+ersons of the same or opposite sex
+"(i) bestiality;
+"(il) masturbation;
+"(iv) sadistic or masochistic abuse; or
+"M lascivious exhibition of the genitals or pubic area of any person;
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 35
+"(B) For purposes of subsection 8(B) of this section, 'sexually explicit conduct' means--
+"i) graphic sexual intercourse, including genital-genital, oral-genital, anal-genital, or oral-anal, whether
+between persons of the same or opposite sex, or lascivious simulated sexual intercourse where the genitals,
+breast, or pubic area of any person is exhibited;
+"(ii) graphic or lascivious simulated;
+"(1) bestiality;
+"(II) masturbation; or
+"(III) sadistic or masochistic abuse; or
+"(iii) graphic or simulated lascivious exhibition of the genitals or pubic area of any person;".
+<< 18 USCA § 2256 >>
+(c) Section 2256 is amended by inserting at the end the following new paragraphs:
+"(10) 'graphic', when used with respect to a depiction of sexually explicit conduct, means that a viewer can observe any part of the genitals or pubic area of any depicted person or animal during any part of the time that the
+sexually explicit conduct is being depicted; and
+"(11) the term 'indistinguishable' used with respect to a depiction, means virtually indistinguishable, in that the
+depiction is such that an ordinary person viewing the depiction would conclude that the depiction is of an actual
+minor engaged in sexually explicit conduct. This definition does not apply to depictions that are drawings, cartoons, sculptures, or paintings depicting minors or adults.".
+« 18 USCA § 2252A >>
+(d) Section 2252A(c) of title 18, United States Code, is amended to read as follows:
+"(c) It shall be an affirmative defense to a charge of violating paragraph (1), (2), (3)(A), (4), or (5) of subsection
+(a) that-
+"(1)(A) the alleged child pornography was produced using an actual person or persons engaging in sexually explicit conduct; and
+"(B) each such person was an adult at the time the material was produced; or
+"(2) the alleged child pornography was not produced using any actual minor or minors.
+No affirmative defense under subsection (c)(2) shall be available in any prosecution that involves child pornography as described in section 2256(8)(C). A defendant may not assert an affirmative defense to a charge of violating paragraph (1), (2), (3)(A), (4), or (5) of subsection (a) unless, within the time provided for filing pretrial
+such defense and the substance of any expert or other specialized testimony or evidence upon which the defendant intends to rely. If the defendant fails to comply *680 with this subsection, the court shall, absent a finding of
+extraordinary circumstances that prevented timely compliance, prohibit the defendant from asserting such de-
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 36
+fense to a charge of violating paragraph (1), (2), (3)(A), (4), or (5) of subsection (a) or presenting any evidence
+for which the defendant has failed to provide proper and timely notice."
+SEC. 503. CERTAIN ACTIVITIES RELATING TO MATERIAL CONSTITUTING OR CONTAINING
+CHILD PORNOGRAPHY.
+Section 2252A of title 18, United States Code, is amended--
+« 18 USCA § 2252A »>
+(1) in subsection (a)--
+(A) by striking paragraph (3) and inserting the following:
+"(3) knowingly--
+"(A) reproduces any child pornography for distribution through the mails, or in interstate or foreign commerce
+by any means, including by computer; or
+"(B) advertises, promotes, presents, distributes, or solicits through the mails, or in interstate of foreign commerce by any means, including by computer, any material or purported material in a manner that reflects the belief, or that is intended to cause another to believe, that the material or purported material is, or contains--
+"(i) an obscene visual depiction of a minor engaging in sexually explicit conduct; or
+"(ii) a visual depiction of an actual minor engaging in sexually explicit conduct;";
+« 18 USCA § 2252A >>
+(B) in paragraph (4), by striking "or" at the end;
+< 18 USCA § 2252A »>
+(C) in paragraph (5), by striking the comma at the end and inserting "; or"; and
+<< 18 USCA § 2252A >>
+(D) by adding after paragraph (5) the following:
+"(6) knowingly distributes, offers, sends, or provides to a minor any visual depiction, including any photograph,
+film, video, picture, or computer generated image or picture, whether made or produced by electronic, mechanical, or other means, where such visual depiction is, or appears to be, of a minor engaging in sexually explicit
+"(A) that has been mailed, shipped, or transported in interstate or foreign commerce by any means, including
+by computer;
+"(B) that was produced using materials that have been mailed, shipped, or transported in interstate or foreign
+commerce by any means, including by computer; or
+"(C) which distribution, offer, sending, or provision is accomplished using the mails or by transmitting or
+causing to be transmitted any wire communication in interstate or foreign commerce, including by computer,
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 37
+for purposes of inducing or persuading a minor to participate in any activity that is illegal."; and
+« 18 USCA § 2252A »>
+(2) in subsection (b)(1), by striking "paragraphs (1), (2), (3), or (4)" and inserting "paragraph (1), (2), (3), (4), or
+SEC. 504. OBSCENE CHILD PORNOGRAPHY.
+« 18 USCA § 1466A >>
+(a) IN GENERAL.--Chapter 71 of title 18, United States Code, is amended by inserting after section 1466 the
+following:
+*681 "§ 1466A. Obscene visual representations of the sexual abuse of children
+"(a) IN GENERAL.-Any person who, in a circumstance described in subsection (d), knowingly produces, distributes, receives, or possesses with intent to distribute, a visual depiction of any kind, including a drawing, cartoon, sculpture, or painting, that-.
+"(1)(A) depicts a minor engaging in sexually explicit conduct; and
+"(B) is obscene; or
+(2)(A) depicts an image that is, or appears to be, of a minor engaging in graphic bestiality, sadistic or mas
+chistic abuse, or sexual intercourse, including genital-genital, oral-genital, anal-genital, or oral-anal, whethe
+between persons of the same or opposite sex; and
+"(B) lacks serious literary, artistic, political, or scientific value;
+or attempts or conspires to do so, shall be subject to the penalties provided in section 2252A(b)(1), including the
+penalties provided for cases involving a prior conviction.
+"(b) ADDITIONAL OFFENSES.--Any person who, in a circumstance described in subsection (d), knowingly
+possesses a visual depiction of any kind, including a drawing, cartoon, sculpture, or painting, that--
+"(1)(A) depicts a minor engaging in sexually explicit conduct; and
+"(B) is obscene; or
+"(B) lacks serious literary, artistic, political, or scientific value;
+or attempts or conspires to do so, shall be subject to the penalties provided in section 2252A(b)(2), including the
+penalties provided for cases involving a prior conviction.
+"(c) NONREQUIRED ELEMENT OF OFFENSE.--It is not a required element of any offense under this section
+that the minor depicted actually exist.
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full...
+
+
+
+"(d) CIRCUMSTANCES.--The circumstance referred to in subsections (a) and (b) is that--
+Page 38
+(2) any communication involved in or made in furtherance of the offense contemplates the transmission o
+ransportation of a visual depiction by the mail, or in interstate or foreign commerce by any means, including b
+computer;
+"(3) any person travels or is transported in interstate or foreign commerce in the course of the commission or in
+furtherance of the commission of the offense;
+"(4) any visual depiction involved in the offense has been mailed, or has been shipped or transported in intertate or foreign commerce by any means, including by computer, or *682 was produced using materials tha
+ave been mailed, or that have been shipped or transported in interstate or foreign commerce by any means, in
+cluding by computer; or
+"(5) the offense is committed in the special maritime and territorial jurisdiction of the United States or in any
+territory or possession of the United States.
+"(e) AFFIRMATIVE DEFENSE.--It shall be an affirmative defense to a charge of violating subsection (b) that
+the defendant--
+"(1) possessed less than 3 such visual depictions; and
+"(2) promptly and in good faith, and without retaining or allowing any person, other than a law enforcement
+agency, to access any such visual depiction--
+"(A) took reasonable steps to destroy each such visual depiction; or
+"(B) reported the matter to a law enforcement agency and afforded that agency access to each such visual depiction.
+"(f) DEFINITIONS.--For purposes of this section--
+whether made or produced by electronic, mechanical, or other means;
+"(2) the term 'sexually explicit conduct' has the meaning given the term in section 2256(2)(A) or 2256(2)(B); and
+'(3) the term 'graphic, when used with respect to a depiction of sexually explicit conduct, means that a viewe
+an observe any part of the genitals or pubic area of any depicted person or animal during any part of the tim
+that the sexually explicit conduct is being depicted.".
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 39
+< 18 USCA prec. § 1460>>
+(b) TECHNICAL AND CONFORMING AMENDMENT.--The table of sections at the beginning of such
+chapter is amended by inserting after the item relating to section 1466 the following new item:
+"1466A. Obscene visual representations of the sexual abuse of children.".
+« 18 USCA § 1466A NOTE >>
+(c) SENTENCING GUIDELINES.--
+(1) CATEGORY.--Except as provided in paragraph (2), the applicable category of offense to be used in determining the sentencing range referred to in section 3553(a)(4) of title 18, United States Code, with respect to any
+person convicted under section 1466A of such title, shall be the category of offenses described in section 2G2.2
+of the Sentencing Guidelines.
+< 28 USCA § 994 NOTE >>
+(2) RANGES.--The Sentencing Commission may promulgate guidelines specifically governing offenses under
+section 1466A of title 18, United States Code, if such guidelines do not result in sentencing ranges that are lower
+than those that would have applied under paragraph (1).
+< 18 USCA § 2252A >>
+SEC. 505. ADMISSIBILITY OF EVIDENCE.
+Section 2252A of title 18, United States Code, is amended by adding at the end the following:
+"(e) ADMISSIBILITY OF EVIDENCE.--On motion of the government, in any prosecution under this chapter or
+SEC. 506. EXTRATERRITORIAL PRODUCTION OF CHILD PORNOGRAPHY FOR DISTRIBUTION IN
+THE UNITED STATES.
+Section 2251 of title 18, United States Code, is amended--
+<< 18 USCA § 2251 >>
+(1) by striking "subsection (d)" each place that term appears and inserting "subsection (e)";
+< 18 USCA § 2251 >>
+(2) by redesignating subsections (c) and (d) as subsections (d) and (e), respectively; and
+« 18 USCA § 2251 >>
+(3) by inserting after subsection (b) the following:
+"(c)(1) Any person who, in a circumstance described in paragraph (2), employs, uses, persuades, induces, enices, or coerces any minor to engage in, or who has a minor assist any other person to engage in, any sexually
+xplicit conduct outside of the United States, its territories or possessions, for the purpose of producing any
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 40
+visual depiction of such conduct, shall be punished as provided under subsection (e).
+"(2) The circumstance referred to in paragraph (1) is that-
+"(A) the person intends such visual depiction to be transported to the United States, its territories or possessions,
+by any means, including by computer or mail; or
+"(B) the person transports such visual depiction to the United States, its territories or possessions, by any means,
+including by computer or mail.".
+< 18 USCA §§ 2251, 2252, 2252A >>
+SEC. 507. STRENGTHENING ENHANCED PENALTIES FOR REPEAT OFFENDERS.
+Sections 2251(e) (as redesignated by section 506(2)), 2252(b), and 2252A(b) of title 18, United States Code, are
+each amended--
+(1) by inserting "chapter 71," immediately before each occurrence of "chapter 109A,"; and
+(2) by inserting "or under section 920 of title 10 (article 120 of the Uniform Code of Military Justice)," immediately before each occurrence of "or under the laws".
+SEC. 508. SERVICE PROVIDER REPORTING OF CHILD PORNOGRAPHY AND RELATED INFORMA-
+TION.
+(a) Section 227 of the Victims of Child Abuse Act of 1990 (42 U.S.C. 13032) is amended--
+<< 42 USCA § 13032>>
+(1) in subsection (b)(1)-
+(A) by inserting "2252B," after "2252A,"; and
+(B) by inserting "or a violation of section 1466A of that title," after "of that title),";
+<< USCA USCA § 13032»>
+(2) in subsection (c), by inserting "or pursuant to" after "to comply with";
+< 42 USCA § 13032 >>
+(3) by amending subsection (f)(1)(D) to read as follows:
+(D) where the report discloses a violation of State criminal law, to an appropriate official of a State or subd
+ision of a State for the purpose of enforcing such State law.
+« 42 USCA § 13032»>
+(4) by redesignating paragraph (3) of subsection (b) as paragraph (4); and
+< 42 USCA § 13032 >
+5) by inserting after paragraph (2) of subsection (b) the following new paragrap
+*684 "(3) In addition to forwarding such reports to those agencies designated in subsection (b)(2), the National
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 41
+Center for Missing and Exploited Children is authorized to forward any such report to an appropriate official of
+a state or subdivision of a state for the purpose of enforcing state criminal law.".
+(b) Section 2702 of title 18, United States Code, is amended--
+(1) in subsection (b)--
+<< 18 USCA § 2702»>
+(A) in paragraph (6), by striking subparagraph (B);
+« 18 USCA § 2702>>
+(B) by redesignating paragraphs (6) and (7) as paragraphs (7) and (8) respectively;
+« 18 USCA § 2702»>
+(C) by striking "or" at the end of paragraph (5); and
+(D) by inserting after paragraph (5) the following new paragraph:
+"(6) to the National Center for Missing and Exploited Children, in connection with a report submitted thereto
+under section 227 of the Victims of Child Abuse Act of 1990 (42 U.S.C. 13032);"; and
+(2) in subsection (c)--
+<< 18 USCA § 2702>>
+(A) by striking "or" at the end of paragraph (4);
+<< 18 USCA § 2702»›
+(B) by redesignating paragraph (5) as paragraph (6); and
+<< 18 USCA § 2702>>
+(C) by adding after paragraph (4) the following new paragraph:
+(5) to the National Center for Missing and Exploited Children, in connection with a report submitted theret
+under section 227 of the Victims of Child Abuse Act of 1990 (42 U.S.C. 13032); or".
+<< 18 USCA § 3486 >>
+SEC. 509. INVESTIGATIVE AUTHORITY RELATING TO CHILD PORNOGRAPHY.
+stoves asgay cier orders cried set a code is at al ration spected me elder and all that.
+« 18 USCA § 2252A »>
+SEC. 510. CIVIL REMEDIES.
+Socion 222A of title 18, United States Code, as amended by this Act, is amended by adding at the end the fol.
+"(f) CIVIL REMEDIES.--
+https://web2.westlaw.com/print/printstream.aspx?prf=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 42
+(1) IN GENERAL.-Any person aggrieved by reason of the conduct prohibited under subsection (a) or (b) o
+section 1466A may commence a civil action for the relief set forth in paragraph (2)
+"(2) RELIEF.--In any action commenced in accordance with paragraph (I), the court may award appropriate relief, including-
+"(A) temporary, preliminary, or permanent injunctive relief;
+"(B) compensatory and punitive damages; and
+"(C) the costs of the civil action and reasonable fees for attorneys and expert witnesses.".
+SEC. 511. RECORDKEEPING REQUIREMENTS.
+(a) IN GENERAL.--Section 2257 of title 18, United States Code, is amended--
+<< 18 USCA § 2257 >>
+(1) in subsection (d)(2), by striking "of this section" and inserting "of this chapter or chapter 71,";
+<< 18 USCA § 2257>>
+*685 (2) in subsection (h)(3), by inserting ", computer generated image, digital image, or picture," after "video
+tape"; and
+<< 18 USCA § 2257 >>
+(3) in subsection (i)--
+(A) by striking "not more than 2 years" and inserting "not more than 5 years"; and
+(B) by striking "5 years" and inserting "10 years".
+« 18 USCA § 2257 NOTE >>
+(b) REPORT.--Not later than 1 year after enactment of this Act, the Attorney General shall submit to Congress a
+eport detailing the number of times since January 1993 that the Department of Justice has inspected the record
+f any producer of materials regulated pursuant to section 2257 of title 18, United States Code, and section 75 ol
+title 28 of the Code of Federal Regulations. The Attorney General shall indicate the number of violations prosecuted as a result of those inspections.
+< 28 USCA § 994 NOTE »>
+SEC. 512. SENTENCING ENHANCEMENTS FOR INTERSTATE TRAVEL TO ENGAGE IN SEXUAL ACT
+WITH A JUVENILE.
+Pursuant to its authority under section 994(p) of title 28, United States Code, and in accordance with this sec-
+States Code, to deter and punish such conduct.
+SEC. 513. MISCELLANEOUS PROVISIONS.
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+(a) APPOINTMENT OF TRIAL ATTORNEYS.--
+Page 43
+(2) AUTHORIZATION OF APPROPRIATIONS.--There are authorized to be appropriated to the Department of
+Justice such sums as may be necessary to carry out this subsection.
+« 18 USCA § 1466A NOTE >>
+(b) REPORT TO CONGRESSIONAL COMMITTEES.-
+1) IN GENERAL.--Not later than 9 months after the date of enactment of this Act, and every 2 years thereafter
+he Attorney General shall report to the Chairpersons and Ranking Members of the Committees on the Judiciar
+of the Senate and the House of Representatives on the Federal enforcement actions under chapter 110 or section
+1466A of title 18, United States Code.
+(2) CONTENTS.--The report required under paragraph (1) shall include--
+(A) an evaluation of the prosecutions brought under chapter 110 or section 1466A of title 18, United States Code;
+(B) an outcome-based measurement of performance; and
+(C) an analysis of the technology being used by the child pornography industry.
+<< 28 USCA $ 994 NOTE >>
+(c) SENTENCING GUIDELINES.--Pursuant to its authority under section 994(p) of title 28, United States
+Code, and in accordance *686 with this section, the United States Sentencing Commission shall review and, as
+appropriate, amend the Federal Sentencing Guidelines and policy statements to ensure that the guidelines are adequate to deter and punish conduct that involves a violation of paragraph (3)(B) or (6) of section 2252A(a) of
+title 18, United States Code, as created by this Act. With respect to the guidelines for section 2252A(a)(3)(B),
+the Commission shall consider the relative culpability of promoting, presenting, describing, or distributing material in violation of that section as compared with solicitation of such material.
+Subtitle B--Truth in Domain Names
+SEC. 521. MISLEADING DOMAIN NAMES ON THE INTERNET.
+« 18 USCA § 2252B»>
+(a) IN GENERAL.--Chapter 110 of title 18, United States Code, is amended by inserting after section 2252A the
+following:
+"§ 2252B. Misleading domain names on the Internet
+"(a) Whoever knowingly uses a misleading domain name on the Internet with the intent to deceive a person into
+viewing material constituting obscenity shall be fined under this title or imprisoned not more than 2 years, or both.
+Copr. @ West 2008 No Claim to Orig. Govt. Works
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 44
+"(b) Whoever knowingly uses a misleading domain name on the Internet with the intent to deceive a minor into
+viewing material that is harmful to minors on the Internet shall be fined under this title or imprisoned not more
+than 4 years, or both.
+"(c) For the purposes of this section, a domain name that includes a word or words to indicate the sexual content
+of the site, such as 'sex' or 'porn', is not misleading.
+"(d) For the purposes of this section, the term 'material that is harmful to minors' means any communication,
+consisting of nudity, sex, or excretion, that, taken as a whole and with reference to its context--
+"(1) predominantly appeals to a prurient interest of minors;
+"(2) is patently offensive to prevailing standards in the adult community as a whole with respect to what is suitable material for minors; and
+"(3) lacks serious literary, artistic, political, or scientific value for minors.
+(e) For the purposes of subsection (d), the term 'sex' means acts of masturbation, sexual intercourse, or physci
+ontact with a person's genitals, or the condition of human male or female genitals when in a state of sexua
+stimulation or arousal.".
+«< 18 USCA prec. § 2251 >>
+(b) CLERICAL AMENDMENT.--The table of sections at the beginning of chapter 110 of title 18, United States
+Code, is amended by inserting after the item relating to section 2252A the following new item:
+"2252B. Misleading domain names on the Internet.".
+TITLE VI--MISCELLANEOUS PROVISIONS
+SEC. 601. PENALTIES FOR USE OF MINORS IN CRIMES OF VIOLENCE.
+‹< 18 USCA § 25 >>
+Chapter 1 of title 18, United States Code, is amended by adding at the end the following:
+*687 "§ 25. Use of minors in crimes of violence
+"(a) DEFINITIONS.--In this section, the following definitions shall apply:
+"(1) CRIME OF VIOLENCE.--The term 'crime of violence' has the meaning set forth in section 16.
+"(2) MINOR.--The term 'minor' means a person who has not reached 18 years of age.
+"(3) USES.--The term 'uses' means employs, hires, persuades, induces, entices, or coerces.
+"(1) for the first conviction, be subject to twice the maximum term of imprisonment and twice the maximum fine
+that would otherwise be authorized for the offense; and
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full 2/27/2008
+
+
+
+Page 45
+"(2) for each subsequent conviction, be subject to 3 times the maximum term of imprisonment and 3 times the
+maximum fine that would otherwise be authorized for the offense.".
+« 18 USCA prec. § 1»>
+(b) CLERICAL AMENDMENT.--The table of sections at the beginning of chapter 1 of title 18, United States
+Code, is amended by adding at the end the following:
+"25. Use of minors in crimes of violence.".
+SEC. 602. SENSE OF CONGRESS.
+(a) FOCUS OF INVESTIGATION AND PROSECUTION.--It is the sense of Congress that the Child Exploitation and Obscenity Section of the Criminal Division of the Department of Justice should focus its investigative
+and prosecutorial efforts on major producers, distributors, and sellers of obscene material and child pornography
+that use misleading methods to market their material to children.
+(b) VOLUNTARY LIMITATION ON WEBSITE FRONT PAGES. -It is the sense of Congress that the online
+ommercial adult entertainment industry should voluntarily refrain from placing obscenity, child pornography
+r material that is harmful to minors on the front pages of their websites to protect juveniles from material tha
+may negatively impact their social, moral, and psychological development.
+SEC. 603. COMMUNICATIONS DECENCY ACT OF 1996.
+Section 223 of the Communications Act of 1934 (47 U.S.C. 223) is amended--
+(1) in subsection (a)(1) --
+«< 47 USCA § 223 >>
+(A) in subparagraph (A), by striking ", lewd, lascivious, filthy, or indecent" and inserting "or child pornography"; and
+<< 47 USCA § 223 >>
+(B) in subparagraph (B), by striking "indecent" and inserting "child pornography"; and
+<< 47 USCA § 223 >>
+(2) in subsection (d)(1), by striking ", in context, depicts or describes, in terms patently offensive as measured
+by contemporary community standards, sexual or excretory activities or organs" and inserting "is obscene or
+child pornography".
+FENDERS. 604. INTERNET AVAILABILITY OF INFORMATION CONCERNING REGISTERED SEX OF-
+<< 42 USCA § 14071 >>
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 46
+«< 42 USCA § 14071 NOTE >>
+(b) COMPLIANCE DATE.--Each State shall implement the amendment made by this section within 3 years
+after the date of enactment of this Act, except that the Attorney General may grant an additional 2 years to :
+State that is making a good faith effort to implement the amendment made by this section.
+« 42 USCA § 14071 NOTE »>
+c) NATIONAL INTERNET SITE.--The Crimes Against Children Section of the Criminal Division of the D
+artment of Justice shall create a national Internet site that links all State Internet sites established pursuant t
+this section.
+SEC. 605. REGISTRATION OF CHILD PORNOGRAPHERS IN THE NATIONAL SEX OFFENDER RE-
+GISTRY.
+(a) JACOB WETTERLING CRIMES AGAINST CHILDREN AND SEXUALLY VIOLENT OFFENDER RE-
+GISTRATION PROGRAM.-Section 170101 of the Violent Crime Control and Law Enforcement Act of 1994
+(42 U.S.C. 14071) is amended--
+« USCA USCA § 14071»>
+(1) by striking the section heading and inserting the following:
+"SEC. 170101. JACOB WETTERLING CRIMES AGAINST CHILDREN AND SEXUALLY VIOLENT OF-
+FENDER REGISTRATION PROGRAM.";
+(2) in subsection (a)(3)--
+<< 42 USCA § 14071 >>
+(A) in clause (vii), by striking "or" at the end;
+(B) by redesignating clause (vili) as clause (ix); and
+<< 42 USCA § 14071 >>
+<< 42 USCA § 14071 >>
+(C) by inserting after clause (vii) the following:
+"(viii) production or distribution of child pornography, as described in section 2251, 2252, or 2252A of title
+18, United States Code; or".
+(bie, For arz of focal ye 290 Rot 200-, e suma mad to bear po at youth el apartment of
+made by this section.
+« 42 USCA § 14071>>
+SEC. 606. GRANTS TO STATES FOR COSTS OF COMPLIANCE WITH NEW SEX OFFENDER RE-
+GISTRY REQUIREMENTS.
+Section 170101(i)(3) of the Violent Crime Control and Law Enforcement Act of 1994 (42 U.S.C. 14071(i)(3) is
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full.. 2/27/2008
+
+
+
+PL. 108-21, April 30, 2003, 117 Stat 650
+amended to read as follows:
+Page 47
+*689 SEC. 607. SAFE ID ACT.
+« 18 USCA § 1001 NOTE »>
+(a) SHORT TITLE.--This section may be cited as the "Secure Authentication Feature and Enhanced Identification Defense Act of 2003" or "SAFE ID Act".
+(b) FRAUD AND FALSE STATEMENTS.--
+(1) OFFENSES.--Section 1028(a) of title 18, United States Code, is amended--
+«< 18 USCA § 1028>>
+(A) in paragraph (1), by inserting ", authentication feature," after "an identification document";
+<< 18 USCA § 1028 >>
+(B) in paragraph (2)--
+(i) by inserting ", authentication feature," after "an identification document"; and
+(ii) by inserting "or feature" after "such document";
+« 18 USCA § 1028 >>
+(C) in paragraph (3), by inserting ", authentication features," after "possessor)";
+<< 18 USCA § 1028>>
+(D) in paragraph (4) --
+(i) by inserting ", authentication feature," after "possessor)"; and
+(ii) by inserting "or feature" after "such document";
+(E)in paragraph 5), by inserting or authenticatin scle 102 implement each place that em appears;
+« 18 USCA § 1028>>
+(F) in paragraph (6)--
+(i) by inserting "or authentication feature" before "that is or appears";
+(i) by inserting "or authentication feature" before "of the United States";
+(iii) by inserting "or feature" after "such document"; and
+(iv) by striking "or" at the end;
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 48
+« 18 USCA § 1028 >>
+(G) in paragraph (7), by inserting "or" after the semicolon; and
+« 18 USCA § 1028>>
+(H) by inserting after paragraph (7) the following:
+"(8) knowingly traffics in false authentication features for use in false identification documents, document-making implements, or means of identification;".
+(2) PENALTIES.--Section 1028(b) of title 18, United States Code, is amended--
+(A) in paragraph (1) --
+(i) in subparagraph (A)--
+« 18 USCA § 1028>>
+(1) by inserting ", authentication feature, " before "or false"; and
+<< 18 USCA § 1028>>
+(II) in clause (i), by inserting "or authentication feature" after "document"; and
+<< 18 USCA § 1028>>
+(i) in subparagraph (B), by inserting ", authentication features," before "or false"; and
+<< 18 USCA § 1028>>
+(B) in paragraph (2)(A), by inserting ", authentication feature," before "or a false".
+<< 18 USCA § 1028>>
+(3) CIRCUMSTANCES.--Section 1028(c)(1)) of title 18, United States Code, is amended by inserting ", authentication feature," before "or false" each place that term appears.
+(4) DEFINITIONS.--Section 1028(d) of title 18, United States Code, is amended--
+<< 18 USCA § 1028>>
+(A) by redesignating paragraphs (1), (2), (3), (4), (5), (б), (7), and (8) as paragraphs (2), (3), (4), (7), (8), (9),
+(10), and (11), respectively;
+<< 18 USCA § 1028 >>
+(B) by inserting before paragraph (2), as redesignated, the following:
+*690 "(1) the term "authentication feature' means any hologram, watermark, certification, symbol, code, image
+sequence of numbers or letters, or other feature that either individually or in combination with another feature is
+used by the issuing authority on an identification document, document-making implement, or means of identification to determine if the document is counterfeit, altered, or otherwise falsified;".
+<< 18 USCA § 1028 >>
+(C) in paragraph (4)(A), as redesignated, by inserting "or was issued under the authority of a governmental entity but was subsequently altered for purposes of deceit" after "entity";
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 49
+« 18 USCA § 1028>>
+(D) by inserting after paragraph (4), as redesignated, the following:
+"(5) the term 'false authentication feature' means an authentication feature that--
+"(A) is genuine in origin, but, without the authorization of the issuing authority, has been tampered with or
+altered for purposes of deceit;
+"(B) is genuine, but has been distributed, or is intended for distribution, without the authorization of the issuing authority and not in connection with a lawfully made identification document, document-making implement,
+or means of identification to which such authentication feature is intended to be affixed or embedded by the re
+spective issuing authority; or
+"(C) appears to be genuine, but is not;
+"(6) the term 'issuing authority'-
+"(A) means any governmental entity or agency that is authorized to issue identification documents, means of
+identification, or authentication features; and
+"(B) includes the United States Government, a State, a political subdivision of a State, a foreign government, a
+political subdivision of a foreign government, or an international government or quasi-governmental organiza-
+<< 18 USCA § 1028 >>
+(E) in paragraph (10), as redesignated, by striking "and" at the end;
+<< 18 USCA § 1028 >>
+(F) in paragraph (11), as redesignated, by striking the period at the end and inserting "; and"; and
+<< 18 USCA § 1028 >>
+(G) by adding at the end the following:
+"(12) the term 'traffic' means--
+"(A) to transport, transfer, or otherwise dispose of, to another, as consideration for anything of value; or
+"(B) to make or obtain control of with intent to so transport, transfer, or otherwise dispose of.".
+(5) ADDITIONAL PENALTIES.--Section 1028 of title 18, United States Code, is amended--
+« 18 USCA § 1028»>
+(A) by redesignating subsection (h) as subsection (i); and
+« 18 USCA § 1028 >>
+(B) by inserting after subsection (g) the following:
+"(h) FORFEITURE; DISPOSITION.--In the circumstance in which any person is convicted of a violation of
+subsection (a), the court shall order, in addition to the penalty prescribed, the forfeiture and destruction or other
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 50
+disposition of all illicit authentication features, identification documents, document-making implements, or
+means of identification.".
+« 18 USCA § 1028 >>
+(6) TECHNICAL AND CONFORMING AMENDMENT.--Section 1028 of title 18, United States Code, is
+amended in the heading *691 by inserting ", AUTHENTICATION FEATURES," after "DOCUMENTS".
+SEC. 608. ILLICIT DRUG ANTI-PROLIFERATION ACT.
+« 21 USCA § 801 NOTE »>
+(a) SHORT TITLE.--This section may be cited as the "Illicit Drug Anti-Proliferation Act of 2003".
+(b) OFFENSES.-
+(1) IN GENERAL.--Section 416(a) of the Controlled Substances Act (21 U.S.C. 856(a)) is amended--
+<< 21 USCA § 856 >>
+(A) in paragraph (1), by striking "open or maintain any place" and inserting "open, lease, rent, use, or maintain
+any place, whether permanently or temporarily,"; and
+<< 21 USCA § 856 >>
+(B) by striking paragraph (2) and inserting the following:
+(2) manage or control any place, whether permanently or temporarily, either as an owner, lessee, agent, en
+loyee, occupant, or mortgagee, and knowingly and intentionally rent, lease, profit from, or make available fo
+use, with or without compensation, the place for the purpose of unlawfully manufacturing, storing, distributing.
+or using a controlled substance.".
+<< 21 USCA § 856 >>
+(2) TECHNICAL AMENDMENT.--The heading to section 416 of the Controlled Substances Act (21 U.S.C.
+856) is amended to read as follows:
+"SEC. 416. MAINTAINING DRUG-INVOLVED PREMISES."
+(3) CONFORMING AMENDMENT.--The table of contents to title II of the Comprehensive Drug Abuse and
+Prevention Act of 1970 is amended by striking the item relating to section 416 and inserting the following:
+"Sec. 416. Maintaining drug-involved premises.".
+« USCA USCA § 856>>
+"(d)(1) Any person who violates subsection (a) shall be subject to a civil penalty of not more than the greater of -
+(A) S250,000; or
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 51
+"(B) 2 times the gross receipts, either known or estimated, that were derived from each violation that is attributable to the person.
+"2) ra he pe penalty is eat ulted under pars raph cach, adore i be re than sedany the or the capi
+penalty under this subsection.
+"(e) Any person who violates subsection (a) shall be subject to declaratory and injunctive remedies as set forth
+in section 403(f).".
+< 21 USCA § 843»>
+« 21 USCA § 843>>
+(d) DECLARATORY AND INJUNCTIVE REMEDIES.--Section 403(f)(1) of the Controlled Substances Act
+(21 U.S.C. 843(f)(1)) is amended by striking "this section or section 402" and inserting "this section, section
+402, or 416".
+<< 28 USCA § 994 NOTE >>
+(e) SENTENCING COMMISSION GUIDELINES.--The United States Sentencing Commission shall--
+(1) review the Federal sentencing guidelines with respect to offenses involving gamma hydroxybutyric acid (GHB);
+*692 (2) consider amending the Federal sentencing guidelines to provide for increased penalties such that those
+penalties reflect the seriousness of offenses involving GHB and the need to deter them; and
+(3) take any other action the Commission considers necessary to carry out this section.
+(f) AUTHORIZATION OF APPROPRIATIONS FOR A DEMAND REDUCTION COORDINATOR.--There is
+authorized to be appropriated $5,900,000 to the Drug Enforcement Administration of the Department of Justice
+for the hiring of a special agent in each State to serve as a Demand Reduction Coordinator.
+(g) AUTHORIZATION OF APPROPRIATIONS FOR DRUG EDUCATION.--There is authorized to be appropriated such sums as necessary to the Drug Enforcement Administration of the Department of Justice to educate
+youth, parents, and other interested adults about club drugs.
+SEC. 609. DEFINITION OF VEHICLE.
+Section 1993(c) of title 18, United States Code, is amended--
+« 18 USCA § 1993»>
+(1) in paragraph (7), by striking "and" at the end;
+« 18 USCA § 1993>>
+(2) in paragraph (8), by striking the period at the end and inserting "; and"; and
+« 18 USCA § 1993>>
+(3) by adding at the end the following:
+"(9) the term 'vehicle' means any carriage or other contrivance used, or capable of being used, as a means of
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full.. 2/27/2008
+
+
+
+Page 52
+transportation on land, water, or through the air.".
+SEC. 610. AUTHORIZATION OF JOHN DOE DNA INDICTMENTS.
+(a) LIMITATION.-Section 3282 of title 18, United States Code, is amended-
+<< 18 USCA § 3282>>
+(1) by striking "Except" and inserting the following:
+"(a) IN GENERAL.--Except"; and
+<< 18 USCA § 3282 >>
+(2) by adding at the end the following:
+"(b) DNA PROFILE INDICTMENT.--
+"(1) IN GENERAL.--In any indictment for an offense under chapter 109A for which the identity of the accused
+is unknown, it shall be sufficient to describe the accused as an individual whose name is unknown, but who has
+a particular DNA profile.
+"(2) EXCEPTION.--Any indictment described under paragraph (1), which is found not later than 5 years after
+the offense under chapter 109A is committed, shall not be subject to--
+"(A) the limitations period described under subsection (a); and
+"(B) the provisions of chapter 208 until the individual is arrested or served with a summons in connection with
+the charges contained in the indictment.
+"(3) DEFINED TERM.--For purposes of this subsection, the term 'DNA profile' means a set of DNA identification characteristics.".
+<< FRCRP Rule 7>>
+(b) RULES OF CRIMINAL PROCEDURE.--Rule 7(c)(1) of the Federal Rules of Criminal Procedure is
+amended by adding at the end the following: "For purposes of an indictment referred to in section 3282 of title
+18, United States Code, for which the identity of the defendant is unknown, it shall be sufficient for the indict
+ment to describe the defendant as an individual whose name is unknown, but who has a particular DNA profile,
+as that term is defined in that section 3282.".
+*693 SEC. 611. TRANSITIONAL HOUSING ASSISTANCE GRANTS FOR CHILD VICTIMS OF DOMEST-
+IC VIOLENCE, STALKING, OR SEXUAL ASSAULT.
+Subtitle B of the Violence Against Women Act of 1994 (42 U.S.C. 13701 note; 108 Stat. 1925) is amended by
+adding at the end the following:
+"CHAPTER 11-TRANSITIONAL HOUSING ASSISTANCE GRANTS FOR CHILD VICTIMS OF
+DOMESTIC VIOLENCE, STALKING, OR SEXUAL ASSAULT
+< 42 USCA § 13975 >>
+"SEC. 40299. TRANSITIONAL HOUSING ASSISTANCE GRANTS FOR CHILD VICTIMS OF DOMESTIC
+VIOLENCE, STALKING, OR SEXUAL ASSAULT.
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full.. 2/27/2008
+
+
+
+Page 53
+"(a) IN GENERAL.--The Attorney General, acting in consultation with the Director of the Violence Against
+omen Office of the Department of Justice, shall award grants under this section to States, units of local gor
+mment, Indian tribes, and other organizations (referred to in this section as the 'recipient") to carry out pre
+grams to provide assistance to minors, adults, and their dependents--
+"(1) who are homeless, or in need of transitional housing or other housing assistance, as a result of fleeing a situation of domestic violence; and
+"(2) for whom emergency shelter services or other crisis intervention services are unavailable or insufficient.
+"(b) GRANTS.--Grants awarded under this section may be used for programs that provide--
+"(1) short-term housing assistance, including rental or utilities payments assistance and assistance with related
+expenses such as payment of security deposits and other costs incidental to relocation to transitional housing for
+persons described in subsection (a); and
+"(2) support services designed to enable a minor, an adult, or a dependent of such minor or adult, who is fleeing
+a situation of domestic violence to--
+"(A) locate and secure permanent housing; and
+"B) integrate into a community by providing that minor, adult, or dependent with services, such as transportation, counseling, child care services, case management, employment counseling, and other assistance.
+"(c) DURATION.--
+"(1) IN GENERAL.--Except as provided in paragraph (2), a minor, an adult, or a dependent, who receives assistance under this section shall receive that assistance for not more than 18 months.
+"(2) WAIVER.--The recipient of a grant under this section may waive the restriction under paragraph (1) for not
+more than an additional 6 month period with respect to any minor, adult, or dependent, who-.
+"(A) has made a good-faith effort to acquire permanent housing; and
+"(B) has been unable to acquire permanent housing.
+"(d) APPLICATION.--
+(1) IN GENERAL.-Each eligible entity desiring a grant under this section shall submit an application to th
+ttorney General at such time, in such manner, and accompanied by *694 such information as the Attorne
+General may reasonably require.
+"(2) CONTENTS.--Each application submitted pursuant to paragraph (1) shall--
+"(A) describe the activities for which assistance under this section is sought; and
+"(B) provide such additional assurances as the Attorney General determines to be essential to ensure compliance with the requirements of this section.
+https://web2.westlaw.com/print/printstream.aspx?prfl=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 54
+"(3) APPLICATION.--Nothing in this subsection shall be construed to require--
+"(A) victims to participate in the criminal justice system in order to receive services; or
+"(B) domestic violence advocates to breach client confidentiality.
+"(e) REPORT TO THE ATTORNEY GENERAL.--
+"(1) IN GENERAL.-A recipient of a grant under this section shall annually prepare and submit to the Attorney
+General a report describing--
+"(A) the number of minors, adults, and dependents assisted under this section; and
+"(B) the types of housing assistance and support services provided under this section.
+"(2) CONTENTS.--Each report prepared and submitted pursuant to paragraph (1) shall include information regarding--
+"(A) the amount of housing assistance provided to each minor, adult, or dependent, assisted under this section
+and the reason for that assistance;
+"(B) the number of months each minor, adult, or dependent, received assistance under this section;
+"(C) the number of minors, adults, and dependents who--
+"(i) were eligible to receive assistance under this section; and
+"(ii) were not provided with assistance under this section solely due to a lack of available housing; and
+"(D) the type of support services provided to each minor, adult, or dependent, assisted under this section.
+"(f) REPORT TO CONGRESS.--
+"(1) REPORTING REQUIREMENT.-The Attorney General, with the Director of the Violence Against Women
+Office, shall annually prepare and submit to the Committee on the Judiciary of the House of Representatives and
+the Committee on the Judiciary of the Senate a report that contains a compilation of the information contained in
+the report submitted under subsection (e).
+2) AVAILABILITY OF REPORT.--In order to coordinate efforts to assist the victims of domestic violenc
+e Attorney General, in coordination with the Director of the Violence Against Women Office, shall transmit
+copy of the report submitted under paragraph (1) to--
+"(A) the Office of Community Planning and Development at the United States Department of Housing and
+Urban Development; and
+"(B) the Office of Women's Health at the United States Department of Health and Human Services.
+"(g) AUTHORIZATION OF APPROPRIATIONS.-
+*695 "(1) IN GENERAL.--There are authorized to be appropriated to carry out this section $30,000,000 for each
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 2/27/2008
+
+
+
+Page 55
+of the fiscal years 2004 through 2008.
+"(2) LIMITATIONS.--Of the amount made available to carry out this section in any fiscal year, not more than 3
+percent may be used by the Attorney General for salaries and administrative expenses.
+"(3) MINIMUM AMOUNT.--
+"(A) IN GENERAL.--Except as provided in subparagraph (B), unless all eligible applications submitted by
+any States, units of local government, Indian tribes, or organizations within a State for a grant under this section
+have been funded, that State, together with the grantees within the State (other than Indian tribes), shall be alloc
+ated in each fiscal year, not less than 0.75 percent of the total amount appropriated in the fiscal year for grants
+land stal earl located nod is es a 02 pere, amte total amount appropriated i the scal yea tor
+grants pursuant to this section.".
+Approved April 30, 2003.
+LEGISLATIVE HISTORY--S. 151 (
+1104):
+HOUSE REPORTS: No. 108-47, Pt. 1 accompanying
+of Conference).
+1104 (Comm. on the Judiciary) and 108-66 (Comm.
+SENATE REPORTS: No. 108-2 (Comm. on the Judiciary).
+CONGRESSIONAL RECORD, Vol. 149 (2003):
+Feb. 24, considered and passed Senate.
+Mar. 27, considered and passed House, amended, in lieu of
+1104.
+Apr. 10, House and Senate agreed to conference report.
+WEEKLY COMPILATION OF PRESIDENTIAL DOCUMENTS, Vol. 39 (2003):
+Apr. 30, Presidential remarks and statement.
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full...
+
+
+--- F.3d-..
+..- F.3d -..., 2008 WL 253040 (C.A.11 (Ala.))
+(Cite as: -- F.3d ---)
+JNITED STATES OF AMERICA
+Plaintiff-Appellant, . BRUCE CLAYTON PUGH
+a.k.a. sknowgirl, a.k.a. alabamaprincess4, a.k.a.
+pgugh, Defendant-Appellee.
+C.A.11,2008.
+UNITED STATES OF AMERICA,
+Plaintiff-Appellant,
+BRUCE CLAYTON PUGH, a.k.a. sknowgirl, a.k.a.
+alabamaprincess4, a.k.a. pgugh, Defendant-Appellee.
+No. 07-10183 D.C. Docket No. 06-00009-CR-WS
+United States Court of Appeals, Eleventh Circuit.
+(January 31, 2008)
+Appeal from the United States District Court for the
+Southern District of Alabama
+Before MARCUS and PRYOR, Circuit Judges, and
+HANCOCK "N*, District Judge.
+*. Honorable James Hughes Hancock, United
+States District Judge for the Northern District
+of Alabarta, sitting by designation.
+MARCUS, Circuit Judge:
+This appeal tests the nature and extent o
+ppellate review over sentencing under the nev
+regime of advisory Sentencing Guidelines. After
+thorough review, we are constrained to conclude that
+even under the most recent Supreme Court precedent,
+affording substantial deference to the district court's
+sentencing determinations, the district court abused its
+discretion by imposing a probationary sentence on the
+defendant in this case.
+Here, the government appealed from the
+non-custodial sentence of defendant Bruce Clayton
+Pugh ("Pugh"), who downloaded on his computer
+over a period of several years at least 68 images of
+child pornography, as well as videos of an adult male
+raping an infant girl and of a young girl performing
+oral sex on an adult male. The advisory Sentencing
+Guidelines range recommended for the offense to
+which Pugh pled guilty-knowing possession of images
+of child pornography that were mailed, shipped or
+transported by computer in violation of 18 U.S.C. §4
+2252A(a)(5)(B) and 2256(8)(A)-was 97 to 120
+months' imprisonment. The district court nevertheless
+sentenced Pugh to a five-year probationary term. In so
+doing, the district court relied heavily on Pugh's
+history, characteristics and motive in imposing a
+non-custodial sentence for a crime that fell on the high
+end of the Guidelines sentencing table. But in our
+view, the district court did not provide a sufficiently
+compelling justification to support the degree of its
+variance, nor did it give any apparent weight to many
+other important statutory factors embodied by
+Congress in 18 U.S.C. § 3553(a) that must be
+considered at sentencing. As we see it, this
+probationary sentence utterly failed to adequately
+promote general deterrence, reflect the seriousness of
+Pugh's offense, show respect for the law, or address in
+any way the relevant Guidelines policy statements and
+directives. Accordingly, we hold that this sentence is
+unreasonable, and therefore vacate and remand so that
+the district court can re-calculate the defendant's
+sentence.
+I.
+The presentence report ("PSI") presented the
+following basic facts. During an investigation
+conducted in Oklahoma in May 2003, the FBI learned
+that Warren Paul Perkins, III, had emailed child
+pornography images to the America OnLine ("AOL")
+screen name "moonkiss." The FBI traced that screen
+name to Joyce Pugh, the defendant's sister and
+housemate, and obtained a warrant to search the
+computer systems and other
+related
+computer
+components owned by the Pughs. During a search of
+the Pugh home in Selma, Alabama in September 2003,
+a police detective observed several images of nude
+pubescent children in provocative poses in Pugh's
+computer files.
+When interviewed on the day of the search by an
+FBI agent, Pugh said he downloaded child
+pornography images but then deleted them. Pugh
+added that he may have forwarded child pornography
+to the "list me" areas in chat rooms. Pugh told the FBI
+that he entered chat rooms on the Internet pretending
+to be an underaged female and that people would then
+email him child pornography images. He also
+admitted that he once saw an image on his computer of
+a man having sex with a two- or three-year old who
+had a dog collar around her neck.
+A subsequent forensic examination of Pugh's
+
+
+computer by the FBI revealed some 70 images of child
+pornography, including a horrifying video of an infant
+girl being raped by an adult male, a video of a young
+girl performing oral sex on an adult male, and an
+image of male and female children engaged in sex acts
+vith an adult male. There were ten known child
+victims-young boys and girls whose identities have
+seen established by the government-in the images
+found on the defendant's computer.
+The FBI interviewed Pugh again in March 2005.
+At this time, Pugh told the investigators that he went to
+the chat rooms pretending to be an underaged girl
+sing the screen name "sknowgirl." Some users woul
+end Pugh child pornography thinking he was a youn
+girl. When erotica pictures came to him from other
+users, Pugh would separate them, save them, and send
+them to other users under the pretense that he was the
+subject of the pictures. According to Pugh, men were
+always trying to pick him up over the Internet, and he
+justified his pretense by thinking that he was keeping
+the men away from "real children."
+He said that everyone in the chat rooms sent him
+child pornography images, even though he asked them
+for adul pornography an explained that repay ely
+not the child pornography that others sent him, and
+that he never looked for child pornography on the
+Internet. Pugh offered that he did not want the
+pictures, which did not arouse him; rather, he only
+wanted to talk. However, he knew that his pretense
+would in fact cause people to send him child
+pornography.
+1. In Pugh's case, the "scat" images on his
+computer depicted women defecating in each
+other's mouths.
+In a January 2006 indictment, Pugh was charged
+by a federal grand jury sitting in the Southern District
+of Alabama with receipt and distribution of images of
+child pornography by computer in violation of 18
+U.S.C. § 2252A(a)(2) and (b)(1) (count one);
+possession of images of child pornography that had
+been mailed, shipped or transported by computer in
+violation of 18 U.S.C. §§ 2252A(a)(5)(B) and
+2256(8)(A) (count two); and receipt of obscene matter
+by interactive computer service in violation of 18
+U.S.C. § 1462 (count three). In March 2006, Pugh
+pled guilty to the possession count embodied in Count
+Two, pursuant to a written plea agreement.
+As part of the plea agreement, Pugh admitted to
+"knowingly possess[ing] a computer[ ] and compact
+disc which contained more than 3 images of child
+pornography ..." in violation of 18 U.S.C. §
+2252A(a)(5)(B). Pugh further admitted that a forensic
+examination of his computer revealed that he had
+approximately 68 images and two videos of child
+pornography, which had been downloaded from the
+internet using AOL.
+These images included the following:
+yungcumpusjpg: a video of a female infant with
+an adult male penis penetrating the infant's vagina.
+The adult male has ejaculated and semen is on the
+surface of the infant's labia.
+xxxjob.mpeg: a video of a child approximately 12
+years of age performing oral sex on an adult male.
+(1) jpg: phot[o] of a boy and girl both of whom
+are approximately 8 years of age and the girl has the
+penis of an adult male in her mouth.
+Pugh also admitted to connecting to the internet
+using AOL, visiting chat rooms pretending to be an
+underaged child, and viewing the child pornography
+sent to him by others in the chat rooms.
+Using the 2002 Guidelines Manual,
+as
+supplemented on April 30, 2003, the probation officer
+determined Pugh's base offense level to be 17 under
+U.S.S.G. § 2G2.2. The offense level then was
+enhanced 2 levels under U.S.S.G. § 2G2.2(b)(L)
+because the material involved prepubescent minors or
+minors under age 12; 5 levels under U.S.S.G. §
+2G2.2(b)(2)(B)
+because the offense involved
+distribution for the receipt of child pornogranhu but
+not for pecuniary gain; 4 levels under
+2G2.2(b)(3) because the material portrayed sadistic or
+masochistic conduct or other depictions of violence; 2
+levels under U.S.S.G. § 2G2.2(b)(5) for use of a
+computer or interactive computer service; and 3 levels
+under U.S.S.G. $ 2G2.2(b)(®) for more than 150 but
+fewer than 300 images.
+Subtracting 3 levels for
+acceptance of responsibility under U.S.S.G. § 3E1.1,
+Pugh's adjusted offense level was 30, and his criminal
+history category was level I. Thus, the advisory
+Sentencing Guidelines yielded a range of 97-120
+months' imprisonment.
+2. Pugh admitted possessing 68 still images
+plus 2 video clips, each of which counted as
+75 images under clarifying amendment 664
+
+
+.-- F.3d-...
+--- F.3d -..., 2008 WL 253040 (C.A.11 (Ala.))
+(Cite as: --- F.3d -..-)
+of the 2004 Guidelines Manual (providing
+that "[e]ach video, video-clip, movie or
+similar recording shall be considered to have
+75 images"), and U.S.S.G. § 1B1.11(b)(2)
+(directing that "[t]he court shall use the
+Guidelines Manual in effect on the date that
+the defendant is sentenced'").
+At the sentencing hearing, the district court
+adopted the PSI as published. Pugh's counsel then
+called John Frank Warren, III, Ph.D., ("Warren") to
+testify concerning Pugh's mental state and likelihood
+of recidivism. Warren, a clinical and forensic
+psychologist, testified that in his opinion, Pugh
+presented a "low-risk" on a "low-moderate-high" risk
+assessment scale, which measures an offender's risk of
+re-offending, but recognized that "no one is a no risk."
+Warren also opined that Pugh was not a pedophile,
+and was not addicted to child pornography, but rather,
+was addicted to adult pornography, an addiction that
+developed as a result of an abusive home life. Warren
+observed that in the late 1990s, Pugh had sought
+mental health treatment for his pornography addiction,
+but none of the therapists or the psychiatrist he met
+with addressed his concerns, and eventually, he
+stopped going.
+Warren further suggested that Pugh would be
+"easy pickings for more predatory or sociopathic
+peers" in a prison setting and that a prison sentence
+could lead Pugh to "more maladaptive coping and,
+arguably, a higher risk status following additional
+victimization."
+According to Warren, Pugh is
+receiving treatment from a psychologist in Selma,
+Warren acknowledged that he had viewed a video
+from Pugh's computer in which an adult male raped an
+infant female, and admitted that this experience would
+have a "horrible impact" on the child victim. Warren
+also explained that the impact on the children depicted
+in the other pornographic images on Pugh's computer
+was "very detrimental," and offered, "that's the reason
+we have laws about child pornography. " Finally, when
+questioned by the district court, Warren testified he
+had not diagnosed most defendants in the prior child
+pornography cases he worked on as pedophiles-in fact,
+he had diagnosed only two of about 45 or 50 as
+pedophiles-which he said was consistent with the
+literature. Warren added that in contrast to Pugh,
+however, most defendants in child pornography cases
+are diagnosed as having Internet child pornography
+paraphilia.
+Pugh then addressed the district court about the
+Following counsel's arguments, the
+chatic court concluied that it needed additional
+information before sentencing Pugh, and set a second
+sentencing hearing to take further testimony on these
+issues. In December 2006, at Pugh's second
+sentencing hearing, FBI Special Agents Fred Haynes
+("Haynes") and George Glaser ("Glaser") testified
+concerning their interviews with Pugh. Haynes
+specifically testified that during the first interview he
+conducted with the defendant in 2003, Pugh said that
+he had downloaded child pornography and that there
+were possibly hundreds of images on his computer.
+Pugh said that he did not actively seek the child
+pornography and never searched for it on the Internet
+but that he had seen it. He explained that it was sent to
+him while he was pretending to be an underaged
+person in chat rooms, which he claimed he did
+because "he felt like ... [by doing so] he was keeping
+the child predators away from the children." Notably,
+Pugh "admitted]" to Haynes "that he had forwarded
+child pornography to others on his list in the chat
+rooms." During a second interview in 2005, Haynes
+and Glaser showed Pugh images retrieved from his
+computer. Pugh said that when he first started
+receiving child pornography images, he reported the
+senders to AOL. Haynes and Glaser asked Pugh why
+he did not stop soliciting the child pornography and
+Pugh responded that he was "addicted to it." FN4
+3. The PSI also referenced an incident in
+2004 involving Pugh's
+The FBI was contacted by Patricia Smith
+("Smith"), another sister of Pugh's, who told them that
+she had been driving home from church with one of
+her daughters and her granddaughter. While in the car,
+her granddaughter had told her, "Mee Maw, know
+what? Uncle Bruce told me that he licked the hair off a
+girl." Ms. Smith asked the girl to repeat herself, and
+she said, "Uncle Bruce said he licked the hair off a
+girl's crotch, and she licked his off."
+Warren testified that he was skeptical of the story
+involving Pugh's great-niece. He said that in his
+experience working with and evaluating children of
+abuse, children "misinterpret a lot of things" and
+"incorporate something they've seen in a movie versus
+something they saw mommy do versus something
+they heard about at school. It comes out as a narrative
+that very often doesn't match what actually occurs."
+Warren concluded, "I discounted [this information]
+and found it relatively fantastic." Pugh also testified
+
+
+--- F.3d ---., 2008 WL 253040 (C.A.11 (Ala.))
+Page 4
+about his interpretation of what happened with his
+great-niece, which was consistent with the earlier
+statements of Warren and defense counsel. Pugh's
+mother and his sisters Joyce and Brenda also testified
+on Pugh's behalf; his mother and Joyce discounted the
+allegation regarding Pugh's great-niece.
+After two sentencing hearings in which the
+district court took testimony on this issue, ultimately
+no factual findings were made regarding whether or
+how the incident occurred.
+4. The record is confusing as to what Pugh
+exactly admitted to being addicted to during
+the FBI interviews-whether it was child
+pornography or internet conversations. Specifically,
+Special Agent Haynes testified that Pugh admitted in
+his second interview that "he was addicted to the
+conversations." Haynes later testified that when he
+asked Pugh why he didn't just stop eliciting the child
+pornography, Pugh responded "that he was addicted to
+it," and on cross-examination, Haynes answered yes
+when asked if "[Haynes] said that [Pugh] said that
+[Pugh] was addicted to child porn," and when asked if
+"[Pugh] told [Haynes] [Pugh] was addicted to the
+conversations he was having in the chat rooms." Pugh
+testified that he knew they were talking about child
+pornography at the second interview (when the
+alleged addiction comment was made), but explained,
+"I was nervous. I wish I hadn't said some of the things
+those images were not pornographic. Of the 118,000
+images, Glaser estimated that more than 1000 of the
+images were pornographic. Of those 1000-plus
+images, Glaser said that approximately 60 images
+were child pornography.
+Pugh then testified. As for his first interview with
+Haynes, Pugh said that he did not know at the
+beginning of the questioning that the FBI agents were
+talking about child as opposed to adult pornography.
+When asked why he did not clarify his statements after
+he learned that Haynes had been talking about child
+pornography, Pugh said: "I was too scared to say
+anything because I've seen movies, court shows where
+you say that you want to change your statement, they
+could use that against you, saying, oh, he's changing
+his story, you know." Regarding his habit of entering
+chat rooms disguised as a girl, Pugh explained that he
+was looking for conversation:
+When I first got AOL, I had tried to be myself,
+and people would not talk to me. And a friend of mine
+at the time had instant-messaged me with a female
+name, and he said, hey Bruce, it's me, Mark. And that's
+what gave me the idea of pretending to be a girl. And
+I'd go into a chat room, and you could type in 14,
+female, you know, describe what your age and sex is,
+and I would get instant messages galore. And I was
+like, oh, this is the way to go. But I was looking for
+chat. I never pushed it towards sexual chat. It was the
+males that I talked to that would push it towards sexual
+chat. I know it was wrong, but I would go along with it
+because I did enjoy talking to people.
+Following counsel's arguments, the district court
+adopted the findings and the calculations embodied in
+the PSI yielding an adjusted offense level of 30 and a
+criminal history category I, with a resulting advisory
+sentencing range of 97 to 120 months. Noting the
+seriousness of Pugh's crime and Congress's harsh
+treatment of it, the district court then explained its
+decision to impose a completely non-custodial
+Haynes further
+testified that during the
+interviews, Pugh understood the difference between
+child
+pornography. On
+cross-examination, when asked if Pugh might have
+said that he
+was addicted
+to the chat room
+conversations that resulted in him receiving child
+pornography, as opposed to being addicted to the child
+pornography, Haynes would not concede that he and
+Pugh had misunderstood each other.
+Glaser testified that as a certified "Computer
+Analysis and Response Team" or "CART" examiner,
+he had examined Pugh's computers. Glaser found
+images of obscene adult pornography and of child
+pornography on the machines. Glaser confirmed that
+there were 10 known victims-children whose
+identities have been established by the government-in
+the child pornography found on Pugh's computer.
+Glaser had no prior experience with a defendant like
+Pugh, who entered chat rooms disguised as a child to
+obtain adult pornography. Glaser said there were
+118,000 images on Pugh's computers, but most of
+The district court explained that Pugh had no
+significant criminal history, and no history that would
+suggest he had or would abuse children. The court
+determined that Pugh's possession of child
+pornography was "passive" and "incidental" to his
+actual goal of developing online relationships, even
+though Pugh pretended to be an underaged female in
+these online chats and
+occasionally sent chil
+pornography to others. FNS The court observed tha
+Pugh took steps to minimize the receipt of child
+
+
+--- F.3d-.--
+(Cite as: -- F.3d --)
+Page 5
+pornography by reporting it and talking about it with
+his mother, and the court noted that he had voluntarily
+entered treatment for addiction to adult pornography.
+5. The district court actually said that Pugh
+"produced" child pornography, but because
+there is no evidence of production in the record,
+we assume the district court meant "distribution"
+rather than production. The evidence concerning
+distribution, as we have already noted, includes
+Special Agent Haynes's testimony that Pugh
+"admit[ted] to [him] that he had forwarded child
+pornography to others on his list in the chat rooms."
+The district court then cited to Warren's opinion
+that Pugh was not a pedophile and presented a low risk
+of re-offending, that Pugh would not benefit from a
+custodial sentence, and that Pugh was addicted to
+adult, but not child pornography. The court also noted
+that Pugh had not re-offended since his arrest and had
+been compliant with the court's pre-sentencing orders.
+The court contrasted Pugh's case with other
+defendants who pay for or actively solicit child
+pornography, and concluded that an "unusual sentence
+for an unusual case" was necessary, and that it was
+"convinced" that it would "never" see Pugh again.
+The district court proceeded to sentence Pugh to a
+five-year probationary term on the conditions that
+Pugh (1) continue his mental health treatment; (2) not
+possess a computer with internet access; (3) consent to
+periodic, unannounced examinations of any computer
+equipment he possessed; (4) submit to searches based
+on reasonable suspicion; and (5) register with the state
+sex-offender registry.
+After the district court denied the United States's
+motion to reconsider the sentence and impose either a
+sentence within the Guidelines, or a sentence of at
+least one day in prison followed by a life term of
+supervised release, the United States timely appealed
+the sentence arguing that it was so disproportionately
+light in view of the seriousness of the offense that it
+amounted to an abuse of discretion, and was,
+Guidelines system codified in the Sentence Reform
+Act of 1984, 18 U.S.C. § 3551 et seq., 28 U.S.C. $5
+991-998 ("SRA")-which had been enacted to reduce
+the unwarranted disparities that had plagued the
+previous discretionary sentencing regime, id. at 250,
+252, 253, 255, 256, 264, 267-violated the Sixth
+Amendment. Id. at 232-35, In its place, the Court
+identified two features of the SRA that would remain
+and work together "to move sentencing in Congress'
+preferred direction." Id. at 264. The first was a
+continued important role for the Sentencing
+Guidelines. See id. at 264-65. Specifically, the Court
+held that "[t]he district courts, while not bound to
+apply the Guidelines, must consult those Guidelines
+and take them into account when sentencing." Id. at
+IL.
+Because the law of sentencing has been changing
+rapidly, we begin by providing some analysis of its
+current state. In United States | Booker, 543 U.S. 220
+(2005), the Supreme Court held that the mandatory
+The second was the continuation of appellate
+review. While Booker held that sentences could no
+longer be reviewed de novo, it determined that
+appellate
+courts
+thereafter
+would
+apply
+a
+"reasonableness" standard of review. According to
+Justice Stevens, the Court
+"expressly equated"
+reasonableness
+review
+"with
+the
+old
+abuse-of-discretion
+standard
+used
+to
+review
+sentencing departures." Rita | United States, 127
+S.Ct. 2456. 2471 n.2 (2007) (Stevens, J., joined by
+Ginsburg, J., concurring). As the Court explained in
+Booker, "reasonableness" standards are "not foreign
+to sentencing law." 543 U.S. at 262. "The Act has long
+required
+their
+use
+in
+important
+sentencing
+circumstances-both on review of departures, see18
+U.S.C. § 3742(e)(3) (1994 ed.), and on review of
+sentences imposed where there was no applicable
+Guideline, see$S 3742(a)(4), (b)(4), (e)(4)." Id.(citing
+United States White Face, 383 F.3d 733, 737-40
+(8th Cir.2004); United States | Tsosie, 376 F.3d 1210,
+1218-19 (10th Cir.2004); United States | Salinas, 365
+E.3d 582, 588-90 (7th Cir.2004); United States |
+Cook, 291 F3d 1297, 1300-02 (11th Cir.2002);
+United States | Olabanji, 268 F.3d 636, 637-39 (9th
+Cir.2001); United States Ramirez-Rivera, 241 F.31
+57, 40-41 (Ist (r.2001)); see also United States
+Winingear, 422 F.3d 1241, 1246 (11th Cir.2005) (per
+curiam) ("Before Booker, we reviewed departures
+from the Guidelines for reasonableness."). Booker
+recognized that reasonableness review could not
+"provide the uniformity that Congress originally
+sought" when it enacted the SRA and its original
+scheme of mandatory Guidelines. 543 U.S. at 263.
+Nevertheless, reasonableness review would still "tend
+to iron out sentencing differences." Id.
+
+
+.-- F.3d --.., 2008 WL 253040 (C.A.11 (Ala.))
+Page 6
+Booker further held that in performing this
+review, we must measure "reasonableness" against the
+factors outlined by Congress in 18 U.S.C. $ 3553(a).
+FN Booker, 543 U.S. at 261. The Supreme Court
+explained that the factors contained in Section 3553(a)
+would not
+only "guide"
+the district courts in
+sentencing, but that "[t]hose factors in turn will guide
+appellate
+courts, as they have in the past, in
+determining whether a sentence is unreasonable." Id.;
+accord-
+Viningear, 422 F.3d at 1246;see also United
+States Talley, 431 F.3d 784, 788 (11th Cir.2005)
+(per curiam) (We must evaluate whether the sentence
+imposed by the district court fails to achieve the
+purposes of sentencing as stated in section 3553(a).").
+We have also held that the burden of establishing that
+a sentence is unreasonable lies with the party
+challenging the sentence. Talley, 431 F.3d at 788.
+6. Section 3553(a) provides the following
+considerations for the court to consider:
+(1) the nature and circumstances of the offense
+and the history and characteristics of the defendant;
+(2) the need for the sentence imposed-
+(A) to reflect the seriousness of the offense, to
+promote respect for the law, and to provide just
+punishment for the offense;
+(B) to afford adequate deterrence to criminal
+conduct;
+(C) to protect the public from further crimes of the
+defendant; and
+(D) to provide the defendant with needed
+educational or vocational training, medical care, or
+other correctional treatment in the most effective
+manner;
+(3) the kinds of sentences available;
+(4) the kinds of sentence and the sentencing range
+established for ... the applicable category of offense
+committed by the applicable category of defendant as
+set forth in the guidelines:]
+(5) any pertinent policy statement A
+disparities among defendants with similar records who
+have been found guilty of similar conduct; and
+(7) the need to provide restitution to any victims
+of the offense.
+18 U.S.C. § 3553(a).
+he next opportunity the Supreme Court had t
+ddress the new sentencing regime came in Rita
+United States, 127 S.Ct. 2456 (2007), where the Court
+concluded that appellate courts could properly
+presume that a sentence imposed within a properly
+calculated Sentencing Guidelines range was
+reasonable. In reaching this conclusion, the Court
+unambiguously said that appellate courts must apply
+"reasonableness" review to a district court's sentence,
+which "merely asks whether the trial court abused its
+discretion." 127 S.Ct, at 2465. Rita also explained that
+"[w]here the judge imposes a sentence outside the
+Guidelines, the judge will explain why he has done
+so." 127 S.Ct. at 2468.
+The Supreme
+sentencing in Call Pourt most recently addressed
+United States, 128 S.Ct. 586
+(2007), and Kimbrough | United States, 128 S.Ct. 558
+EN Gall reviewed the reasonableness of a
+sentence falling far below the range recommended by
+the Guidelines (a probationary term instead of a
+sentence falling within the Guidelines range of 30-36
+months' imprisonment), and specifically addressed
+of appeals may apply a
+*proportionality test," and require that a sentence that
+constitutes a substantial variance from the Guidelines
+be justified by extraordinary circumstances." 128
+S.Ct. at 591, The Court determined that "while the
+extent of the difference between a particular sentence
+and the recommended Guidelines range is surely
+relevant, courts of appeals must
+sentences-whether inside, just outside, or significantly
+outside the Guidelines range-under a deferential
+abuse-of-discretion standard." Id.
+1. Kimbrough primarily involved issues
+related to the Guidelines for crack cocaine
+offenses.
+In its analysis, Gall reiterated that "a district court
+should begin all sentencing proceedings by correctly
+calculating the applicable Guidelines range." Id. at
+596. Gall further emphasized that "after giving both
+parties an opportunity to argue for whatever sentence
+they deem appropriate, the district judge should then
+consider all of the § 3553(a) factors to determine
+whether they support the sentence requested by a
+party." Id.
+Gall also repeated that appellate review of
+sentencing
+decisions employs the
+"familiar
+abuse-of-discretion standard of review," id. at 594,
+and then created a two-step process for conducting
+that review: first, the appellate court "must... ensure
+that the district court committed no significant
+procedural error, such as failing to calculate (or
+improperly calculating) the Guidelines range, treating
+the Guidelines as mandatory, failing to consider the §
+3553(a) factors, selecting a sentence based on clearly
+
+
+--- F.3d---.
+--- F.3d --, 2008 WL 253040 (C.A.11 (Ala.))
+Page 7
+erroneous facts, or failing to adequately explain the
+chosen sentence-including an explanation for any
+deviation from the Guidelines range." Gall, 128 S.Ct.
+at 597. The first step-aimed at addressing "procedural"
+errors-highlights the continued importance of the
+Guidelines, and the Booker Court's intention that the
+"continued use of the Guidelines in an advisory
+fashion would further the purposes of Congress in
+creating the sentencing system to be honest, fair, and
+rational." Talley, 431 F.3d at 787. So although the
+Court "reject [ed] ... an appellate rule that requires
+"extraordinary" circumstances to justify a sentence
+outside the Guidelines range ... [or] the use of a rigid
+mathematical formula that uses the percentage of a
+departure as the standard for determining the strength
+of the justifications required for a specific sentence," it
+nonetheless repeatedly emphasized that "appellate
+courts may therefore take the degree of variance into
+account and consider the extent of a deviation from the
+Guidelines." Gall, 128 S.Ct. at 595.
+Indeed, Gall explained that a district judge
+must make an individualized assessment based on
+the
+facts presented.
+If he decides
+that an
+outside-Guidelines sentence is warranted, he must
+consider the extent of the deviation and ensure that the
+justification is sufficiently compelling to support the
+degree of the variance. We find it uncontroversial that
+a major departure should be supported by a more
+significant justification than a minor one.
+Id. at 597 (emphases added). Thus, not only must
+the district courts "consult th[e] Guidelines and take
+them into account when sentencing, "Booker, 543 U.S.
+at 264, they must properly calculate the Guidelines
+range and includ[e] an explanation for any deviation
+from the Guidelines range." Gall, 128 S.Ct, at 597.
+After an appellate court has determined that "the
+district court's sentencing decision is procedurally
+sound,"Gall directs that "the appellate court should
+then consider the substantive reasonableness of the
+sentence imposed under an abuse-of-discretion
+standard." Id. at 597. The Court explained:
+When conducting this review, the court will, of
+course, take into account the totality of the
+circumstances, including the extent of any variance
+from the Guidelines range. If the sentence is within the
+Guidelines range, the appellate court may, but is not
+required to, apply a presumption of reasonableness.
+But if the sentence is outside the Guidelines range, the
+court may not apply a presumption of
+unreasonableness. It may consider the extent of the
+deviation, but must give due deference to the district
+court's decision that the § 3553(a) factors, on a whole,
+justify the extent of the variance. The fact that the
+appellate court might reasonably have concluded that
+a different sentence was appropriate is insufficient to
+justify reversal of the district court.
+Id. (citation omitted).
+Gall reminds us once again, as Pugh suggests, to
+appreciate the institutional advantage that district
+courts have in applying and weighing the Section
+3553(a) factors in individual cases. Nonetheless, it
+also remains true that the district court's choice of
+sentence is not unfettered. Again, Gall makes clear
+that the district court is obliged to "consider all of the
+§ 3553(a) factors to determine whether they support
+the sentence requested by a party." 128 S.Ct. at 596-97
+(emphasis added). The Section 3553(a)"factors in turn
+... guide appellate courts, as they have in the past, in
+determining
+whether a sentence is unreasonable."
+Booker, 543 U.S. at 261 accord Winingear, 422 F.3d
+at 1246;see also Talley, 431 F.3d at 788 (We must
+evaluate whether the sentence imposed by the district
+court fails to achieve the purposes of sentencing as
+stated in section 3553(a)."). The appellate court "will,
+of course, take into account the totality of the
+circumstances, including the extent of any variance
+from the Guidelines range." Gall, 128 S.Ct. at 597. Ns
+8. Because we review the "totality of
+circumstances,
+a district court need not
+discuss each
+Section 3553(a) factor, Talley, 431 F.3d at 786,
+although "[where the judge imposes a sentence
+outside the Guidelines, the judge will explain why he
+has done so." Rita, 127 S.Ct. at 2468.
+These directives leave no doubt that an appellate
+court may still overturn a substantively unreasonable
+sentence, albeit only after examining it through the
+prism of abuse of discretion, and that appellate review
+has not been extinguished. Thus, a sentence still may
+be substantively unreasonable if it does "not achieve
+he purposes of sentencing stated in § 3553(a).
+United States Martin, 455 F.3d 1227, 1237 (11t)
+Cir.2006). So, even though we afford "due deference
+to the district court's decision that the § 3553(a)
+factors, on a whole, justify the extent of the
+variance, "Gall, 128 S.Ct. at 597, we may find that a
+district court has abused its considerable discretion if
+it has weighed the factors in a manner that
+demonstrably yields an unreasonable sentence. We are
+
+
+(Cite as: --- F.3d -)
+Page 8
+therefore still required to make the calculus ourselves,
+and are obliged to remand for resentencing "if we are
+left with the definite and firm conviction that the
+district court committed a clear error of judgment in
+weighing the § 3553(a) factors by arriving at a
+sentence that lies outside the range of reasonable
+sentences dictated by the facts of the case." United
+States McBride, No. 06-16544, 2007 WL 4555205.
+at *3 (lith Cir. Dec. 28. 2007) (internal quotation
+marks omitted); United States Clay, 483 F.3d 739.
+743 (11th Cir.2007); cf. United States /
+Fernandez,
+443 F.3d 19, 34-35 (2d Cir.2006) (stating that "we will
+not second guess the weight (or lack thereof) that the
+judge accorded to a given factor ... [under § 3553(a) ],
+as long as the sentence ultimately imposed is
+reasonable in light of all the circumstances presented"
+(emphasis added)). This standard of review is
+altogether consonant with our traditional use of the
+abuse-of-discretion standard, under which we will
+reverse only if "we find that the district court has made
+a clear error of judgment...." United States | Frazier,
+387 F.3d 1244, 1259 (11th Cir.2004) (en bane).
+Moreover, a district court's unjustified reliance on
+any one Section 3553(a) factor may be a symptom of
+an unreasonable sentence. See United States | Crisp.
+454 F.3d 1285, 1292 (11th Cir.2006) (citing United
+States | Rattoballi, 452 F.3d 127, 137 (2d Cir.2006);
+United States
+Ture, 450 F.3d 352, 358-59 (8th
+Cir.2006); United States | Hampton,
+441 F.3d 284,
+288-89 (4th Cir.2006); United States
+Cage, 451
+E.3d 585(10th Cir.2006)); accord United States v.
+Ward, 506 F.3d 468, 478 (6th Cir.2007). Likewise,
+"[a] sentence may be substantively unreasonable when
+the district court selects the sentence arbitrarily, bases
+the sentence on impermissible factors [or] fails to
+consider pertinent section 3553(a) factors." Ward, 506
+F.3d at 478 (internal quotation marks omitted); see
+also United States | Ausburn, 502 F.3d 313, 328 (3d
+Cir.2007) (asking if the district court: "(1) exercised
+its discretion by giving meaningful consideration to
+the § 3553(a) factors; and (2) applied those factors
+reasonably by selecting a sentence grounded on
+reasons logical and consistent with the factors")
+(internal quotation marks omitted); United States
+Willingham, 497 F.3d 541, 543-44 (5th Cir.2007)
+(asking if sentence: "(1) does not account for a factor
+that should have received significant weight, (2) gives
+significant weight to an irrelevant or improper factor,
+or (3) represents a clear error of judgment in balancing
+the sentencing factors") (citation omitted); United
+States | Boleware, 498 F.3d 859, 861 (8th Cir,2007)
+(same).
+We hasten to add that while the application of
+these analyses may suggest an unreasonable sentence,
+they do not necessarily make a sentence unreasonable:
+Gall itself found that the district court did not commit
+reversible error simply because it "attached great
+weight" to a single factor. 128 S.Ct, at 600;see United
+States _ Pauley, No. 07-4270, 2007 WL 4555520, at
+*7 (4th Cir. Dec. 28, 2007). However, it remains
+uncontroverted that a sentence suffering from these
+"symptoms" may in fact be unreasonable, depending
+on an examination of the "totality of the
+circumstances." Gall, 128 S.Ct. at 597. And a review
+of the totality of the circumstances in this case through
+the lens of abuse of discretion yields the conclusion
+that Pugh's sentence is substantively unreasonable.
+III.
+The district court found "based on the facts of this
+case, based on [Pughs) personal characteristics and
+history, and based on a consideration of all of the other
+factors," that Pugh did not deserve a Guidelines
+range-much less a custodial-sentence. In reciting its
+rationale, the district court focused primarily on one of
+the many Section 3553(a) factors-"the nature and
+circumstances of the offense and the history and
+characteristics of the defendant." 18 U.S.C. §
+3553(a)(1). In particular, as we have noted, the district
+court emphasized that Pugh (1) was a first-time
+offender without a history suggesting that he had or
+would abuse children; (2) was addicted to adult
+pornography and had sought treatment for that
+addiction; (3) was not a pedophile and presented a low
+risk for recidivism, according to a psychologist who
+evaluated him; and (4) complied with the terms and
+conditions of his pretrial supervision. The district
+court further found that Pugh's possession offense was
+"passive" and "incidental" to his actual goal of
+developing online relationships, and that Pugh had
+taken steps to report his receipt of child pornography
+to AOL and his family.
+To be sure, we appreciate the thoughtfulness and
+care taken by the district court in sentencing Pugh-the
+court held two sentencing hearings, and deliberated
+extensively over its sentencing decision in this case.
+We also recognize the wide discretion afforded to
+district courts in sentencing, especially since the
+district court is in a "superior position to find facts and
+judge their import." Gall, 128 S.Ct. at 597 (internal
+quotation marks omitted). Accordingly, we accept, as
+we must, the findings of fact made by the district court
+
+
+--- F.3d-..-
+--- F.3d ----, 2008 WL 253040 (C.A.11 (Ala.))
+Page 9
+in this case; we discern no clear error in this regard.
+We do, however, observe these additional salient
+facts that were elicited, and uncontroverted, at the
+sentencing hearings: Pugh intentionally posed as a
+teenage girl and knew that he would receive child
+pornography through this posture; Pugh derived a
+benefit from these images, as evidenced by Pugh's
+admission that "this [wa]s the way to go" for him to
+achieve his "goal" of communication; Pugh repeatedly
+downloaded the child pornography images and videos
+at least 70 times over a period of several years; Pugh
+forwarded some of these images to others in the chat
+room; the images were grotesque, and, as noted,
+included a video of an adult male raping an infant girl
+and a picture of an adult male having sex with a
+toddler with a dog collar around her neck; Pugh failed
+report these images to the police; and the
+psychologist admitted that Pugh did not present "no"
+risk for recidivism. Likewise, we note that the federal
+penal code treats the possession of child pornography
+and child abuse as distinct offenses.
+9. See, e.g., United States | Goff. 501 F.3d
+250, 259 (3d Cir.2007) (where a defendant
+was charged with child pornography possession
+but "was not charged with molestation, ... pointing out
+nice Sues retire 00534)
+321, 332-34 (Sth Cir.2000) (collecting cases rejecting
+departures based on rationale that defendant had "not
+abused
+any child,
+inclination,
+predisposition or tendency to do so").
+Although the district court concluded, on these
+facts, that Pugh's conduct was "incidental"
+"passive," his
+conduct
+neither
+isolated,
+unintentional nor lawful. Nevertheless, Pugh argues in
+his supplemental brief that "the district judge regarded
+Pugh's passive and incidental, as opposed to willful,
+possession of the child pornography as a reasonable
+basis for giving him a less severe sentence than the
+sentences he has given to more typical child
+pornography offenders who solicit or purchase child
+pornography images." App'ee Supp. Br. at 19
+(emphasis added). This argument misses the mark.
+Pugh seems to suggest that because the district court
+found that his ultimate motive was not to gather child
+pornography, somehow his crime was not "willful."
+But on this record there can be no dispute that Pugh
+downloaded and forwarded child pornography
+consciously, intentionally,
+deliberately,
+voluntarily, regardless of whether the receipt of child
+pornography was his end goal or only a means by
+others to "chat" with him. C
+Cir.1979) (*a conscious, intentional, deliberate,
+voluntary decision, which, regardless of a venial
+motive, properly is described as willful") (internal
+quotation marks omitted). FNIO Indeed, he pled to
+"knowingly possessing]" 68 images and two videos
+of child pornography. While motive may be a valid
+concern at sentencing, it cannot obliterate the
+knowing, deliberate and repeated means by which this
+fious crime was committed. See, eg. United States
+Carlson, 498 F.3d 761, 766-67 (8th Cir.2007)
+(concluding that a district court's reliance on a
+defendant's intentions, which were "arguably better
+than a defendant who uses the funds for purely
+personal reasons" but nonetheless resulted in fraud on
+the government, "not particularly compelling" for a
+reduced sentence).
+10. In Bonner | City of Prichard, 661 F.2d
+1206. 1209 (11th Cir.1981) (en banc), we
+adopted as binding precedent all decisions of
+the former Fifth Circuit that were rendered
+prior to October 1, 1981.
+With this factual background in mind, we turn to
+whether (when viewed through the prism of abuse of
+discretion) the
+district
+court's
+sentence
+substantively unreasonable. While undertaking this
+calculus, we are not limited to considering only the
+factors expounded upon by the district court; as the
+Supreme
+Court
+has
+made clear,
+Section
+3553(a)"remains in effect, and sets forth numerous
+factors that guide sentencing. Those factors in turn
+will guide appellate courts, as they have in the past, in
+determining whether a sentence is unreasonable."
+Booker, 543 U.S. at 261. Indeed, we could not begin to
+review the reasonableness of a sentence without
+examining all of the relevant factors embodied in
+Section 3553(a).
+Having reviewed all of those factors in the
+context of this case, we conclude that in imposing a
+non-custodial sentence, the district court performed a
+although
+intensive,
+minimized-and in some instances, ignored-many of
+the important Section 3553(a) concerns that we are
+directed to consider by Congress and the Supreme
+Court. Id.; Gall, 128 S.Ct. at 596. As we have already
+observed, a sentence may be unreasonable if it is
+grounded solely on one factor, relies on impermissible
+factors, or ignores relevant factors. See supra at _At
+
+
+..- F.3d-..., 2008 WL 253040 (C.A.11 (Ala.))
+Page 10
+the end of the day, the sentence in this case is
+unreasonable, and the district court's analysis suffers
+from many of these "symptoms." We detail them
+below.
+First, Pugh's sentence does not afford adequate
+deterrence to criminal
+conduct,"i.e.,
+general
+deterrence. 18 U.S.C. § 3553(a)(2)(B); Martin, 455
+F.3d at 1240. This factor-along with retribution,
+rehabilitation, and incapacitation-expressly makes up
+one of the four purposes of sentencing identified by
+Congress in Section 3553(a). SeeS.Rep. No. 98-225, at
+75-76 (1983), reprinted in 1984 U.S.C.C.A.N. 3182,
+3259 ("to deter others from committing the offense" is
+one of the four purposes of sentencing). Congress
+intended that courts consider each of these four stated
+factors "in imposing sentence in a particular case." Id.
+at 68, 75, 1984 U.S.C.C.A.N. at 3251, 3258; id. at 77,
+1984 U.S.C.C.A.N. at 3260 ("The intent of subsection
+(a)(2) is ... to require that the judge consider what
+impact, if any, each particular purpose should have on
+the sentence in each case."). Indeed, as the Eighth
+the key purposes of sentencing....
+the key as poses of senteral dee ence States of
+Medearis, 451 F.3d 918, 920-21 (8th Cir.2006)
+(quotations omitted).
+This is particularly compelling in the child
+pornography context, as the Seventh Circuit has aptly
+said:
+Young children were raped in order to enable the
+production of the pornography that the defendant both
+downloaded and uploaded-both consumed himself
+and disseminated to others. The greater the customer
+demand for child pornography, the more that will be
+produced. Sentences influence behavior, or so at least
+Congress thought when in 18 U.S.C. § 3553(a) it made
+deterrence a statutory sentencing factor. The logic of
+deterrence suggests that the lighter the punishment for
+downloading and uploading child pornography, the
+greater the customer demand for it and so the more
+will be produced.
+United States | Goldberg, 491 F.3d 668, 672 (7th
+Cir.) (citations omitted), cert. denied, 128 S.Ct. 666
+(2007); see also Goff, 501 F.3d at 261 ("deterring the
+production of child pornography and protecting the
+children who are victimized by it are factors that
+should have been given significant weight at
+sentencing, but in fact received not a word from the
+District Court"). Pugh's probationary sentence, we
+think, tends to undermine the purpose of general
+deterrence, and in turn, tends to increase (in some
+palpable if unmeasurable way) the child pornography
+market. This problem is compounded not just because
+of the number of images Pugh downloaded over an
+extended time frame, but also because Pugh
+distributed some of the images to others.
+Pugh suggests, however, that the district court's
+observation that it had imposed "harsh but
+appropriate sentences" in other cases adequately
+addressed general deterrence and respect for the law (a
+factor discussed below). Even if this statement could
+be read as touching, albeit tangentially, on these
+factors, we still cannot say that the resulting sentence
+fairly reflects their consideration. Indeed, it is unclear
+to us how the district court's sentences in other cases
+can be seen as explaining how a probationary sentence
+for possession of child pornography in this case
+promotes general deterrence or, for that matter,
+respect for the law. This seems to be especially true
+here where unlike in Gall, no other co-defendants
+were sentenced for the same crime that Pugh has
+committed. Quite simply, by imposing a non-custodial
+sentence, the district court accorded no weight to
+general deterrence.
+Second, this sentence failed "to reflect the
+seriousness of the offense, to promote respect for the
+law, and to provide just punishment for the offense."
+18 U.S.C. § 3553(a)(2)(A). As described in the
+legislative history of Section 3553(a):
+This purpose-essentially the
+"just deserts'
+concept-should be reflected clearly in all sentences; it
+is another way of saying that the sentence should
+reflect the gravity of the defendant's conduct. From the
+public's standpoint, the sentence should be of a type
+and length that will adequately reflect, among other
+things, the harm done or threatened by the offense, and
+the publie interest in preventing a recurrence of the
+offense. From the defendant's standpoint the sentence
+should not be unreasonably harsh under all the
+circumstances of the case and should not differ
+substantially from the sentence given to another
+similarly situated defendant convicted of a similar
+offense under similar circumstances.
+S.Rep. No. 98-225, at 75-76, 1984 U.S.C.C.A.N.
+at 3258-59.
+ENIT
+11. Notably, this notion of "just deserts" or
+retribution is a distinct consideration from
+general deterrence. See United States | Foss, 501
+F.2d 522, 527 (Ist Cir.1974) (cited with approval in
+the legislative history of Section 3553(a)) ("[T]he
+
+
+--- F.3d --.-
+--- F.3d --., 2008 WL 253040 (C.A.11 (Ala.))
+(Cite as: --- F.3d -=-)
+Page 11
+view that punishment should fit the offender has never
+yet been held to eliminate general deterrence as a
+factor to be considered along with others.... This is so
+even though general deterrence concerns itself not
+with the individual offender but with the sentence's
+impact on others.").
+The contents of Pugh's computer contained
+depraved images, and there were 10 known (and
+countless unknown) victims in the 68 images and two
+videos. As the government emphasized and Pugh's
+own expert Warren conceded at the sentencing
+hearing, the pictures undeniably have a devastating
+impact on the young victims. In this connection, the
+Supreme Court has observed:
+The legislative judgment, as well as the judgment
+found in the relevant literature, is that the use of
+children as subjects of pomographic materials is
+harmful to the physiological, emotional, and mental
+health of the child....
+It has been found that sexually exploited children
+are
+unable
+to
+develop
+healthy
+affectionate
+relationships in later life, have sexual dysfunctions,
+and have a tendency to become sexual abusers as
+adults. Sexual molestation by adults is often involved
+in the production of child sexual performances. When
+such performances are recorded and distributed, the
+child's privacy interests are also invaded....
+The distribution of photographs
+and films
+depicting sexual activity by juveniles is intrinsically
+related to the sexual abuse of children.... [T]he
+materials produced
+are a permanent record of the
+children's participation and the harm to the child is
+exacerbated by their circulation....
+As one authority has explained:
+"[P]ornography poses an even greater threat to the
+child victim than does sexual abuse or prostitution.
+Because the child's actions are reduced to a recording,
+the pornography may haunt him in future years, long
+after the original misdeed took place. A child who has
+posed for a camera must go through life knowing that
+the recording is circulating within the mass
+distribution system for child pornography." Shouvlin,
+Preventing the Sexual Exploitation of Children: A
+Model Act, 17 Wake Forest L.Rev. 535, 545 (1981).
+See also [Schoettle, Child Exploitation: A Study of
+Child Pornography, 19 J. Am. Acad. Child Psychiatry
+289, 292 (1980) ] ("[I]t is the fear of exposure and the
+tension of keeping the act secret that seem to have the
+most profound emotional repercussions"); Note,
+Protection of Children from Use in Pornography:
+Toward Constitutional and Enforceable Legislation,
+12 U. Mich. J. Law Reform 295, 301 (1979)
+(interview with child psychiatrist) ("The victim's
+knowledge of publication of the visual material
+increases the emotional and psychic harm suffered by
+the child").
+New York | Ferber, 458 U.S. 747, 758-59 &
+nn.9-10 11982) (citations omitted); see also United
+States
+Yuknavich, 419 F.3d 1302, 1310 (11th
+Cir. 2005) ("possession of child pornography is not a
+victimless crime"); Goff. 501 F.3d at 259
+("Consumers such as Goff who
+"merely" or
+"passively' receive or possess child pornography
+directly contribute to this continuing victimization.").
+Moreover, Pugh's possession-and distribution-of
+child pornography undeniably created the demand for
+more. See Yuknavich, 419 F.3d at 1310 ("A child
+somewhere was used to produce the images
+downloaded ..., in large part, because individuals like
+[the defendant] exist to download the images.")
+Indeed, Pugh's own expert, Warren, also conceded
+that Pugh contributed to the demand for child
+pornography, increasing the victimization of still more
+children. The Supreme Court has explained:
+It is .•. surely reasonable for the State to conclude
+that it will decrease
+the production of child
+pornography if it penalizes those who possess and
+view the product, thereby decreasing demand....
+According to the State, since the time of our decision
+in Ferber, much of the child pornography market has
+been driven underground; as a result, it is now
+difficult, if not impossible, to solve the child
+pornography problem by only attacking production
+and distribution. Indeed, 19 States have found it
+necessary to proscribe the possession of this
+material.... The State's ban on possession and viewing
+encourages the possessors of these materials to
+destroy them. [In addition] ..., encouraging the
+destruction of these materials is also desirable because
+evidence suggests that pedophiles use child
+pornography to seduce other children into sexual
+activity.
+Osborne | Ohio, 495 U.S. 103, 109-11 (1990);
+see also United States Williams, 444 F.3d 1286.
+1290 (11th Cir.2006) ("Our concern is not confined to
+the immediate abuse of the children depicted in these
+images, but is also to enlargement of the market and
+the universe of this deviant conduct that, in turn,
+results in more exploitation and abuse of children."
+cert. granted, 127 S.Ct. 1874(2007); United States
+Davis, 204 F.3d 1064, 1066 (11th Cir.1999) (per
+curiam) ("We have recently explained that the harm
+
+
+.. F.3d ...., 2008 WL 253040 (C.A.11 (Ala.))
+Page 12
+resulting from possession of child pornography occurs
+vhen one sustains a market for such pictures.") (citing
+/nited States
+Miller, 146 F.3d 1281, 1285 (11th
+Cir. 1998)); Goff, 501 F.3d at 260 ("[T]he consumer of
+child pornography 'creates a market' for the abuse by
+providing an economic motive for creating and
+distributing the materials.").
+In short, regardless of Pugh's motive, his crime
+was a serious one, as recognized by Congress and the
+courts. Congress repeatedly has stressed the terrible
+harm child pornography inflicts on its victims, dating
+back to its first enactment of child pornography laws
+in 1977.
+FNI2 Since that time, it has not only made
+detailed findings, but has expanded repeatedly
+criminal
+exposure for the possession of child
+pornography:
+12.
+Congressional
+findings
+appear
+throughout the following authorities:
+• The Senate Report on the Protection of Children
+Against Sexual Exploitation Act of 1977 recognized
+that: "the use of children as prostitutes or as the
+subjects of pornographic materials is very harmful to
+both the children and the society as a whole ... [; s]uch
+encounters cannot help but have a deep psychological,
+humiliating impact on these youngsters and jeopardize
+the possibility of healthy, affectionate relationships in
+the future ... [; and] such base and sordid activities ...
+may permanently traumatize and warp the minds of
+the children involved...." S. Rep. 95-438, at 4-9
+(1977), reprinted in 1978 U.S.C.C.A.N. 40, 41-46.
+• Findings in the Child Protection Act of 1984
+recognized that "the use of children as subjects of
+pornographic
+materials is harmful
+physiological, emotional, and mental health of the
+individual child and to society." Pub.L. No. 98-292, §
+2, 98 Stat. 204 (1984).
+• Findings in the Child Abuse Victims' Rights Act
+of 1986 recognized that "Congress has recognized the
+physiological, psychological, and emotional harm
+caused by the production, distribution, and display of
+child pornography by strengthening laws prescribing
+such activity." Pub.L. No. 99-500, § 702(2), 100 Stat.
+1783 (1986).
+Findings in the Child Pornography Preventi
+it of 1996 recognized that: "(1) the use of children i
+the production of sexually explicit material, including
+photographs, films, videos, computer images, and
+other visual depictions, is a form of sexual abuse
+which can result in physical or psychological harm, or
+both, to the children involved; (2) where children are
+used in its production, child pornography permanently
+records the victim's abuse, and its continued existence
+causes the child victims of sexual abuse continuing
+harm by haunting those children in future years; (3)
+child pornography is often used as part of a method of
+seducing other children into sexual activity; ... (7) the
+creation or distribution of child pornography which
+includes an image of a recognizable minor invades the
+child's privacy and reputational interests, since images
+that are created showing a child's face or other
+identifiable feature on a body engaging in sexually
+explicit conduct can haunt the minor for years to
+come; ... (10)(A) the existence of and traffic in child
+pornographic images creates the potential for many
+types of harm in the community and presents a clear
+and present danger to all children; and (B) it inflames
+the desires of child molesters, pedophiles, and child
+pornographers who prey on children, thereby
+increasing the creation and distribution of child
+pornography and the sexual abuse and exploitation of
+actual children who are victimized as a result of the
+existence and use of these materials; (11)(A) the
+sexualization and eroticization of minors through any
+form of child pornographic images has a deleterious
+effect on all children by encouraging a societal
+perception of children as sexual objects and leading to
+further sexual abuse and exploitation of them; and (B)
+this sexualization of minors creates an unwholesome
+environment which affects the psychological, mental
+and emotional development
+of children
+undermines the efforts of parents and families to
+encourage the sound mental, moral and emotional
+development of children...." Pub.L. No. 104-208, §
+121, 110 Stat. 3009 (1996).
+• Findings in the Prosecutorial Remedies and
+Other Tools to End the Exploitation of Children Today
+Act of 2003 recognized that: "[c]hild pornography
+results from the abuse of real children by sex
+offenders; the production of child pornography is a
+byproduct of, and not the primary reason for, the
+sexual abuse of children." Pub.L. No. 108-21, 8
+501(12), 117 Stat. 650 (2003).
+1990. In Pub.L. No. 101-647, § 323, 104 Stat.
+4789 (1990), codified at 18 U.S.C. § 2252(a)(4)(b),
+Congress proscribed the knowing possession of child
+pornography, adding to a statute that had made the
+knowing receipt of this material a crime;
+1992. In Pub.L. No. 102-141, § 632, 105 Stat. 834
+(1992), codified at 28 U.S.C. § 994 note, Congress
+directly amended the Guidelines provision addressing
+offense of child pornography possession,
+increasing the base offense level by two levels;
+1995. In Pub.L. No. 104-71, §§ 2, 3, 109 Stat. 774
+
+
+... F.3d ----
+..- F.3d -..., 2008 WL 253040 (C.A.11 (Ala.))
+Page 13
+(1995), codified at 28 U.S.C. § 994 note, Congress
+again amended the Guidelines provision, increasing
+the base offense level by another two levels, and
+adding an enhancement if a computer was used to
+transport or ship the material;
+1996. In Pub.L. No. 104-208, § 121, 110 Stat.
+3009 (1996), codified at 18 U.S.C. § 2252A(a)(5)(B).
+Congress added another statutory provision for
+possession, almost identical to the existing one, but
+more targeted at the problem of new computer
+technologies; FN13
+13. This is the offense to which Pugh pled
+guilty, 18 U.S.C. § 2252A(a)(SX(B).
+1998. In Pub.L. No. 105-314, § 203, 112 Stat.
+2974 (1998), codified at 18 U.S.C. §§ 2252(a)(4)(b)
+and 2252A(a)(5)(b), Congress amended the statutory
+provisions proscribing possession by reducing the
+number of images needed for conviction from three to
+one; and
+2003. In Pub.L. No. 108-21, §§ 101, 401, 117
+Stat. 650 (2003), codified at 18 U.S.C. § 3583(k) and
+28 U.S.C. § 994 note, Congress increased the statutory
+maximum term of supervised release for child
+pornography possession to life, and directly amended
+the Guideline provision, adding an enhancement
+based on number of images.
+In light of these detailed legislative findings and
+numerous legislative enactments, we cannot help but
+underscore the seriousness of this crime.
+Although the district court recognized that child
+pornography is "a serious crime," the sentence it
+imposed did not reflect the seriousness of the crime.
+Nor did the sentence reflect
+any
+apparent
+consideration of promoting respect for the law. Even
+when
+measured through
+the lens of
+abuse-of-discretion review,
+these
+failings are
+conspicuous. See, e.g., United States | Perrin, 478
+F.3d 672, 676 (5th Cir.2007) ("Though it noted the
+severity of the offense, the court failed to explain how
+this severity, particularly the images' depravity and
+numerosity, factored into its decision to depart
+downward from the guideline range to the statutory
+minimum.").
+Indeed, even Pugh recognized the significance of
+his crime, proffering to the district court that "a
+lengthy period of home confinement" together with a
+"lifetime" of supervised release would "address the
+seriousness of the offense and promote respect for the
+law as well provide adequate punishment." His
+resulting
+probationary
+contrary-without any home confinement or long-term
+supervised release-afforded precious little if any
+weight to the principles underlying 18 U.S.C. §
+3553(a)(2)(A).
+Third, the sentence imposed did not reflect
+consideration of "any pertinent policy statement," 18
+U.S.C. § 3553(a)(5), despite the Guidelines' express
+policy statement for child pornography cases just like
+Pugh's. As early as the 2002 Guidelines Manual, the
+version applicable to Pugh's sentence, the relevant
+policy statement provided that, "[ilf the instant offense
+of conviction is a sex offense, the statutory maximum
+term of supervised release is recommended." U.S.S.G.
+§ SD1.2(c) (2002) (emphasis added). Concurrently,
+the statute itself directed that "the authorized term of
+supervised release for" a sex offense "involving a
+minor victim ... is any term of years or life." 18 U.S.C.
+§ 3583(k) (emphasis added), amended by Pub.L. No.
+109-248, 8 141(0X2), 120 Stat. 587(2006); see also
+United States
+Allison, 447 F.3d 402, 407 (5th
+Cir.2006) (noting that "the policy statement
+recommending a life term of supervised release cannot
+be read in a vacuum, as the policy statement is derived
+from the statutory authority in 18 U.S.C. § 3583(k)
+and is consistent with Congress's intention to punish
+[sex offenders] with life terms of supervised release
+because of the high rate of recidivism") (footnote
+The legislative history in 2003 surrounding the
+enactment of Section 3583(k) reveals that " 'Congress
+and the Sentencing Commission intended to impose
+life terms of supervised release on sex offenders.
+Congress explicitly recognized the high rate of
+recidivism in convicted sex offenders.' " Perrin, 478
+F.3d at 678 (quoting Allison, 447 F.3d at 406 (citing in
+turn 18 U.S.C. § 3583(k); H.R.Rep. No. 108-66,
+reprinted in 2003 U.S.C.C.A.N. 683 (2003)
+(conf.report))). The Fifth Circuit has explained:
+The legislative history of § 3583(k) states that the
+life term of supervised release was in response to the
+"long-standing concerns of Federal judges and
+prosecutors regarding the inadequacy of the existing
+supervision periods for sex offenders, particularly for
+the perpetrators of child sexual abuse crimes, whose
+criminal conduct may reflect deep-seated aberrant
+sexual disorders that are not likely to disappear within
+a few years of release from prison. The current length
+of the authorized supervision periods is not consistent
+
+
+... F.3d -...
+*-- F.3d -*.., 2008 WL 253040 (C.A.11 (Ala.))
+Page 14
+with the need presented by many of these offenders for
+long-term and in some cases, life-long monitoring and
+oversight."
+Allison, 447 F.3d at 405-06 (quoting H.R.Rep.
+No. 108-66, at 49-50 (2003), reprinted in 2003
+U.S.C.C.A.N. 683, 684; and citing United States |
+Moriarty, 429 F.3d 1012, 1025 (11th Cir.2005)). As
+the Fifth Circuit put it in another child pornography
+"[i]t is precisely this type of offender that
+supervised release was designed to rehabilitate."
+United States | Armendariz, 451 F.3d 352, 362 n.6
+(5th Cir.2006) (citing S.Rep. No. 98-225, at 124
+(1984), reprinted in 1984 U.S.C.C.A.N. 3182 ("[T]he
+primary goal [of supervised release] is to case the
+defendant's transition into the community after the
+service of a long prison term for a particularly serious
+offense, or to provide rehabilitation to a defendant
+who has spent a fairly short period in prison for
+punishment
+other purposes but still needs
+supervision and training programs after release."));
+see also United States Johnson, 529 U.S. 53, 59
+(2000) ("The objectives of supervised release would
+be unfulfilled if excess prison time were to offset and
+reduce terms of supervised release. Congress intended
+supervised release to assist individuals in their
+transition to community life. Supervised release
+fulfills rehabilitative ends, distinct from those served
+by incarceration.") (citing S.Rep. No. 98-225, at 124
+(1983)).
+Yet the sentence imposed, which contains no
+period of supervised release, did not reflect the policy
+statement, the statute, or these underlying concerns.
+Fourth, the sentence did not adequately reflect
+two related factors-the "kinds of sentences available"
+and "the sentencing range" established by the
+Guidelines. 18 U.S.C. § 3553(a)(3), (4). Nor did the
+district court "ensure that the justification [for the
+extent of its deviation from the Guidelines] [wa]s
+sufficiently compelling to support the degree of the
+variance." Gall, 128 S.Ct. at 597.
+Pugh's adjusted offense level was 30, and his
+criminal history category was level I, making his
+offense fall into "Zone D" of the Sentencing Table.
+See Sentencing Table, U.S.S.G. § SA. Notably, the
+Guidelines do not authorize a sentence of probation
+where the applicable Guidelines range is in Zone C or
+D of the Sentencing Table. SeeU.S.S.G. §§ 5B1.1 cmt.
+n.2, SC1.1(f). In addition, as we've already noted,
+Section 3583(k) of the statute provides that "any term
+of years or life" of supervised release is mandated for
+sex offenders like Pugh, and the Guidelines
+recommend a life term of supervised release. See
+supra at _As a result, this probationary sentence
+varies both from the recommended Guidelines range,
+and also from the "kinds of sentences" available under
+the Guidelines. See18 U.S.C. § 3553(a)(4). However,
+the district court did not so much as acknowledge that
+probation ordinarily was not available for this crime,
+nor that a life term of supervised release was
+recommended.
+Furthermore, while the district court accepted the
+Guidelines calculation, and asked on the record
+whether "Mr. Pugh deserves a 97-month sentence," it
+did not give any real weight to the Guidelines range in
+imposing the sentence. Not only did the district court
+impose probation, which is not permitted under the
+now-advisory Guidelines regime, but it departed just
+about as much as it could-some 97 months for an
+offense with a Guidelines calculation of 97-120
+months' imprisonment. The district court did not
+simply impose a 97-month downward variance;
+rather, it imposed a sentence of zero months'
+FN14
+imprisonment.
+14. We recognize that because the statute
+contains no mandatory minimum, Congress
+understood that a judge could sentence a
+defendant to zero months' imprisonment. The
+Seventh Circuit has "imagine[d] a case,
+involving the downloading of a handful of
+images none showing any prepubescent child
+or depicting any sexual activity, yet still
+constituting child pornography (the statute
+"pornography" as including besides actual
+sexual activity "lascivious exhibition of the
+genitals or pubic area, 18 U.S.C. §$ 2256(1).
+(2)(A)(v)), in which a permissible sentence
+might be light." Goldberg, 491 F.3d at 672.
+But plainly that is not the case here. While
+there may be other circumstances in which a
+non-custodial sentence may be reasonable,
+this is not one of them.
+In the Supreme Court's parlance, the degree of
+variance imposed by the district court here-far greater
+than the 30-month variance imposed in Gall-is
+undeniably "major." Gall, 128 S.Ct. at 597. "In
+reviewing the reasonableness of a sentence outside the
+Guidelines range, appellate courts may therefore take
+the degree of variance into account and consider the
+
+
+--- F.3d ---., 2008 WL 253040 (C.A.11 (Ala.))
+Page 15
+extent of a deviation from the Guidelines." Id. at 595
+(emphasis added). But the district court failed to even
+acknowledge that its sentence amounted to a
+97-month variance, and its implicit explanation for the
+variance-simply relying on Pugh's characteristics and
+motive-hardly matches the degree of variance it
+imposed. Quite simply, in our view, the district court
+did not support this "major departure" with a
+"significant justification." Id. at 597. This failing is
+particularly telling in light of the importance the
+Supreme Court accorded this factor in Gall.'I3
+15. The Supreme Court has recently held that
+a district judge has the authority to deviate
+from the Guidelines in a particular crack cocaine
+case because the Guidelines range for these offenses
+was based on "the mandatory minimum sentences set
+in the 1986 Act, and did not take account of 'empirical
+data and national experience." " Kimbrough, 128 S.Ct.
+at 575 (citation omitted). The Guidelines involved in
+Pugh's case, however, do not exhibit the deficiencies
+the Supreme Court identified in Kimbrough. First, the
+Guidelines range is derived at least in part from the
+early Parole Guidelines, rather than directly derived
+from Congressional mandate. See, e.g., Revised Draft
+Sentencing Guidelines 72 (Jan. 1987) ("The serious
+nature of th[e] offense [of transporting, receiving, or
+traflicking
+material involving
+exploitation of a minor] is reflected in the
+enhancement for the distribution of material depicting
+minors under age twelve. The amount of enhancement
+reflects the time specified by the parole guidelines.").
+Second, there is no indication
+that either the
+Guidelines range or the policy statement involved in
+Pugh's sentence suffers from any criticisms like those
+Kimbrough identified for the crack
+cocaine
+Guidelines. There, the Supreme Court found that the
+Sentencing Commission itself had "reported that the
+crack/powder disparity produces disproportionately
+harsh sanctions." Kimbrough, 128 S.Ct. at 575. Here,
+the Sentencing Commission has not made any similar
+statements; rather, the Guidelines and policy
+statement are based in part upon Congress's
+longstanding concern for recidivism in such cases, see
+supra at _ and even Pugh's expert admitted that no
+one, including Pugh, presents "no" risk for recidivism.
+Fifth, because the district court did not impose a
+substantial term of supervised release, the sentence did
+not adequately reflect the need to "protect the public
+from further crimes of the defendant." 18 U.S.C. §
+3553(a)(2)(C). The district court brushed aside
+consideration of this purpose of sentencing-aimed at
+incapacitation-by simply concluding that it was
+"convinced that I will never see you again."
+As Congress has found and as we have discussed,
+child sex offenders have appalling rates of recidivism
+and their crimes are under-reported. See Allison, 447
+F.3d at 405-406. Yet because the district court did not
+impose any custodial sentence on Pugh-not even one
+day-by law it could not impose any term of supervised
+release. See18 U.S.C.A. § 3583(a) (a "defendant
+[may] be placed on a term of supervised release after
+imprisonment"); U.S.S.G. § SD1.1; United States
+Chavez, 204 F.3d 1305, 1312-1313 (11th Cir.2000).
+And while the district court imposed some conditions
+on Pugh through probation (e.g.. continued mental
+health treatment, registering as sex offender, and
+visits), Pugh's compliance
+conditions will be monitored for only 5 years.
+This period of monitoring is extremely light for a child
+pornography offender. Had even a short term of
+imprisonment been imposed by the district court, Pugh
+could have been monitored for a substantial period of
+time, including the possibility of supervised release
+for the rest of his life, as permitted by the statutory
+penalties, 18 U.S.C. § 3583(k), and recommended by
+the Sentencing Commission.
+16. In Gall, the Supreme Court held that
+"o]ffenders on probation are ... subject to
+several standard conditions that substantially
+restrict their liberty." 128 S.Ct, at 595. We do not
+dispute this, but note that Gall did not involve a child
+pornography offense,
+which involves
+different
+considerations for supervised release, including the
+characteristics associated with child pornography
+offenders and the Guidelines recommendation of a life
+term of supervised release for such offenders.
+17. Moreover, even in cases not involving
+child sex offenses, supervised release is a
+stronger tool than probation. See United States
+Reese, 71 F.3d 582, 587-88 (6th Cir. 1995) ("There is
+an inherent difference between probation and
+supervised release. When probation is revoked for a
+violation, the rules set forth in 18 U.S.C. § 3565 limit
+the term of resentencing to the term allowable under
+the original offense.... By contrast, a violation of
+supervised release may result in a cumulative
+punishment that exceeds the original prison
+sentence.").
+Despite the district court's strong conviction that
+Pugh would not suffer from recidivism, the resulting
+
+
+--- F.3d-...
+Page 16
+sentence does not provide a sufficient mechanism to
+monitor Pugh for a lengthy time, and thus protect the
+public from any future crime, as contemplated in 18
+U.S.C. § 3553(a)(2)(C). This omission is particularly
+striking, since Pugh himself agreed to a lifetime of
+supervised release.
+18. On this note, we also disagree with
+Pugh's suggestion that the district court
+appropriately relied on his "self-motivated
+rehabilitation" like the district court did in Gall.In
+Gall, the offender completely stopped committing the
+offending conduct years before his arrest; here, at best,
+Pugh unsuccessfully sought treatment for an adult
+pornography addiction prior to his arrest but
+nonetheless did not
+stop
+downloading
+child
+pornography. We add that it is unclear how a related
+Section 3553(a) factor-"the need ... to provide the
+defendant with needed
+... medical care, "18 U.S.C.
+3553(a)(2)(D)-was furthered by the sentence the
+district court imposed. Presumably Pugh could be
+subject to longer-term treatment had a substantial term
+of supervised release been imposed.
+Sixth, and finally, the sentence did not adequately
+reflect "the need
+avoid unwarranted sentence
+disparities among defendants with similar records who
+have been found guilty of similar conduct." 18 U.S.C.
+$ 3553(a)(6). While the district court tound Pugh to be
+at "the low end of the spectrum of possession,"
+that the situation was "quite different from those I
+normally see," it nonetheless did
+not adequately
+explain how Pugh's non-custodial sentence avoided
+disparities with other similarly situated
+Indeed, we have typically treated child sex
+offenses as serious crimes, upholding severe sentences
+in these cases. See, e.g., United States | Mauldin, 224
+E. App'x 915 (11th Cir.2007) (unpublished) (affirming
+78-month sentence and life term of supervised release
+for possession of child pornography; United States I
+Hodnett, 210 F. App'x 949 (11th Cir.2006)
+(unpublished) (affirming 360-month sentence and life
+erm of supervised release for receipt, distribution, ans
+possession of child pornography); United States
+Thrift.
+205 F. App'x 816 (11th
+Cir.2006)
+(unpublished) (affirming 97-month sentence and life
+term of supervised release for use of internet to entice
+a minor to engage in sexual activity), cert. denied, 127
+S.Ct. 2143(2007).
+We have in some instances affirmed downward
+variances in these kinds of cases, but in each of them,
+substantial prison sentences had been imposed. See,
+e.g.,
+McBride, 2007 WL 4555205 (affirming
+84-month sentence for distribution of child
+pornography where Guidelines called for 151-188
+months); United States | Bohannon, 476 F.3d 1246
+(11th Cir.) (affirming 120-month sentence for use of
+internet to entice minor into sexual activity where
+Guidelines called for 135-168 months]
+cert.
+denied, 127 S.Ct. 2953 (2007); United States Gray
+453 F.3d 1323 (11th Cir.2006) (per curiam) (affirming
+72-month sentence for distribution of child
+pornography where Guidelines called for 151-188
+months); United States | Halsema, 180 F. App'x 103
+(11th Cir.2006) (unpublished) (affirming 24-month
+sentence for possession of child pornography where
+Guidelines called for 57-71 months). And in a similar
+case, another court upheld a substantial sentence, even
+though the defendant possessed many fewer images
+than Pugh. See United States | Nikonova, 480 F.3d
+371, 377 (5th Cir.) (affirming a 31-month sentence
+where the defendant possessed 13 images and the
+district court noted that, although the defendant may
+be "atypical," her offense fell "within the heartland of
+cases involving possession of child pornography"),
+cert. denied, 128 S.Ct. 163 (2007).
+In fact, Pugh has not cited and we cannot find a
+single case involving child pornography in which any
+court has upheld a non-custodial sentence like this
+FNI9 Rather, appellate courts have consistently
+overturned zero-imprisonment or other sharply
+downward-varying sentences in such cases on the
+ground that the resulting sentences were unreasonably
+lenient. See, e.g., United States | Fink, 502 F.3d 585,
+586 (6th Cir.2007) (vacating sentence of 70 months'
+imprisonment and five years' supervised release;
+Goff, 501 F.3d at 262 (vacating sentencing of four
+months' imprisonment and three years' supervised
+release); Goldberg, 491 F.3d at 668 (vacating sentence
+of one-day imprisonment and 10 years' supervised
+release); United States | Borho, 485 F.3d 904 (6th
+Cir.2007) (vacating sentence of 72 months'
+imprisonment and 5 years' supervised release); Perrin,
+478 F.3d at 672 (vacating sentence of 60 months'
+imprisonment and 10 years' supervised release);
+Armendariz, 451 F.3d at 352 (vacating sentence of
+five years' imprisonment and no supervised release).
+While these cases do not drive our decision, they do
+support the conclusion that the district court's
+probationary sentence will result in unwarranted
+disparities, further suggesting that the sentence
+imposed was unreasonable.
+
+
+--- F.3d -.-., 2008 WL 253040 (C.A.11 (Ala.))
+Page 17
+19. We have located only one case in which
+an appellate court has upheld a nonimprisonment sentence for a child pornography
+offense-but in that unpublished decision of the Fifth
+Circuit, which incidentally lacks any detailed
+U.S. [ Pugh
+-- F.3d -.., 2008 WL 253040 (C.A.11 (Ala.))
+Cir.2007)-
+IV.
+Taking the Section 3553(a) factors as a whole as
+well as the district court's findings and calculus, we
+are constrained to conclude that Pugh's probationary
+sentence was unreasonable, and that the district court
+abused its discretion in imposing it. We recognize that
+the appropriate weight given to each of the factors
+cannot be calibrated with a slide rule and that the
+district court properly has been accorded
+discretion in determining how to weigh those factors.
+However, the district court must give some weight to
+the factors in a manner that is at least loosely
+commensurate with their importance to the case, and
+in a way that "achieve[s] the purposes of sentencing
+stated in § 3553(a)." Martin, 455 F.3d at 1237, Where
+it does not, and instead "commits] a clear error of
+judgment in weighing the § 3553(a) factors by arriving
+at a sentence that lies outside the range of reasonable
+sentences dictated by the facts of the case," we must
+for resentencing.
+McBride,
+2007 WL
+4555205, at *3 (internal quotation marks omitted).
+Indeed, if we could not say so here, we would come
+perilously close to holding that appellate review is
+limited to procedural irregularity, so long as the
+district court says it has reviewed all of the Section
+3553(a) factors. We do not read Supreme Court
+precedent as having so eviscerated appellate review at
+the same time that it has mandated the appellate courts
+to continue to review sentences for reasonableness.
+We, therefore, VACATE Pugh's sentence, and
+REMAND the case to the district court for further
+review and resentencing. In so doing, we do not
+suggest what that sentence should be. We hold only
+that a sentence of probation, without a single day in
+jail or any period of supervised release is an
+unreasonable one.
+VACATED and REMANDED.
+C.A.11,2008.
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Journal D.A.R. 962
+H
+U.S. | Clark
+C.A.9 (Wash.),2006.
+United States Court of Appeals,Ninth Circuit.
+UNITED STATES of America, Plaintiff-Appellee,
+V.
+Michael Lewis CLARK, Defendant-Appellant.
+No. 04-30249.
+Argued and Submitted June 6, 2005.
+Filed Jan. 25, 2006.
+United States District Court for the Western District of Washington, Robert S. Lasnik, J., 315
+F.Supp.2d 1127, of violating the Prosecutorial
+Remedies and Other Tools to End the Exploitation
+of Children Today Act's (PROTECT Act) prohibition against traveling in foreign commerce to engage in a sexual act with a person under 18 years of
+age, and he appealed.
+Holdings: The Court of Appeals, McKeown,
+Circuit Judge, held that:
+(1) extraterritorial application of PROTECT
+Act did not violate principles of international law;
+(2) application of PROTECT Act to defendant
+did not violate due process; and
+(3) enactment of PROTECT Act was a valid
+exercise of Congressional authority under the Foreign Commerce Clause.
+Affirmed.
+Ferguson, Circuit Judge, filed dissenting opinion.
+West Headnotes
+[1] Criminal Law 110 €-18
+110 Criminal Law
+1101 Nature and Elements of Crime
+110k12 Statutory Provisions
+110k18 k. Extraterritorial Operation. Most
+Cited Cases
+Extraterritorial application of Prosecutorial Remedies and Other Tools to End the Exploitation of Children Today Act's (PROTECT Act) prohibition
+against traveling in foreign commerce to engage in
+a sexual act with a person under 18 years of age did
+not violate principles of international law; provision
+was exclusively targeted at extraterritorial conduct,
+and jurisdiction was based solely on a defendant's
+status as a U.S. citizen. 18 U.S.C.A. § 2423(c).
+12] Commerce 83 €-82.6
+83 Commerce
+8311 Application to Particular Subjects and
+Methods of Regulation
+83Il(J) Offenses and Prosecutions
+83k82.5 Federal Offenses and Prosecutions
+83k82.6 k. In General. Most Cited Cases
+Infants 211 €-13
+211 Infants
+211Il Protection
+211k13 k. Protection of Health and Morals.
+Most Cited Cases
+Two-month lapse in time between defendant's most
+recent transit between the United States and Cambodia and his arrest did not preclude application of
+Prosecutorial Remedies and Other Tools to End the
+Exploitation of Children Today Act's (PROTECT
+[3] Constitutional Law 92 €-4560
+92 Constitutional Law
+92XXVII Due Process
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prft=HTMLE&... 1/30/2008
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Journal D.A.R. 962
+92XXVII(H) Criminal Law
+92XXVII(H)4 Proceedings and Trial
+92k4560 k. Extraterritorial Application
+of Penal Laws. Most Cited Cases
+(Formerly 92k259)
+Criminal Law 110 € 18
+110 Criminal Law
+110I Nature and Elements of Crime
+110k12 Statutory Provisions
+110k18 k. Extraterritorial Operation. Most
+Cited Cases
+Application to defendant of Prosecutorial Remedies
+and Other Tools to End the Exploitation of Children Today Act's (PROTECT Act) prohibition
+against traveling in foreign commerce to engage in
+a sexual act with a person under 18 years of age, on
+basis of his sexual activities with children in Cambodia, did not violate Due Process Clause; defendant's American citizenship provided a sufficient
+Const.Amend. 5; 18 U.S.C.A. § 2423(c).
+[4] Commerce 83 €-4
+83 Commerce
+831 Power to Regulate in General
+83k2 Constitutional Grant of Power to Congress
+83k4 k. Commerce with Foreign Nations.
+Most Cited Cases
+Commerce 83 €-8(1)
+83 Commerce
+831 Power to Regulate in General
+83k2 Constitutional Grant of Power to Congress
+83k8 Exclusive or Concurrent Powers of
+Congress and the States
+83k8(1) k. In General; Application of
+State or Federal Law. Most Cited Cases
+Congress's power over foreign commerce is exclusive and plenary. U.S.C.A. Const. Art. 1, § 8, cl. 3.
+[5] Commerce 83 €-82.6
+83 Commerce
+83II Application to Particular Subjects and
+Methods of Regulation
+83I(J) Offenses and Prosecutions
+83k82.5 Federal Offenses and Prosecutions
+83k82.6 k. In General. Most Cited Cases
+Infants 211 €12(8)
+211 Infants
+211II Protection
+211k12 Constitutional and Statutory Provisions
+211k12(3) Validity
+211k12(8) k. Crimes Against Infants.
+Most Cited Cases
+Enactment of Prosecutorial Remedies and Other
+Tools to End the Exploitation of Children Today
+Act's (PROTECT Act) prohibition against traveling
+in foreign commerce to engage in a sexual act with
+a person under 18 years of age was a valid exercise
+of Congressional authority under the Foreign Commerce Clause. U.S.C.A. Const. Art. 1, § 8, cl. 3; 18
+U.S.C.A. § 2423(c).
+*1101 Michael Filipovic, Assistant Federal Public
+Defender, Vicki W.W. Lai, Research and Writing
+Attorney, Federal Public Defender's Office, Seattle,
+WA, for the defendant-appellant.
+John McKay, United States Attorney, Helen .
+Brunner, John J. Lulejian, Susan B. Dohrmann, As-
+sistant United States Attorneys, Seattle, WA, for
+the plaintiff-appellee.
+Appeal from the United States District Court for the
+Western District of Washington;*1102 Robert S.
+Lasnik, District Judge, Presiding. D.C. No. CR-
+03-00406-L.
+Before HUG, FERGUSON, and MCKEOWN, Circuit Judges.
+Opinion by Judge McKEOWN; Dissent by Judge
+FERGUSON.
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prft=HTMLE&.. 1/30/2008
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Journal D.A.R. 962
+McKEOWN, Circuit Judge.
+In this appeal we are confronted with a question of first impression regarding the scope of Congress's power under the Foreign Commerce
+Clause.FN1 At issue is whether Congress exceeded
+its authority "to regulate Commerce with foreign
+Nations," U.S. Const. art. 1, § 8, cl. 3, in enacting a
+statute that makes it a felony for any U.S. citizen
+who travels in "foreign commerce," ie. to a foreign
+country, to then engage in an illegal commercial
+tutional authority.
+FN1. We commend both counsel for their
+excellent and comprehensive briefing on
+this novel issue.
+Congressional invocation of the Foreign Commerce Clause comes as no surprise in light of growing concern about U.S. citizens traveling abroad
+who engage in sex acts with children. The United
+States reiterated its commitment to quelling sexual
+abuse abroad by signing The Yokohama Global
+Commitment
+tp://www.unicef.org/events/
+yokohama/outcome.html (last visited Dec. 29, 2005), which was
+concluded at the Second World Congress Against
+the Commercial Sexual Exploitation of Children.
+The Commitment welcomes "new laws to criminalize [child prostitution], including provisions with
+extra-territorial effect." Id. Notably, in an explanatory statement attached to the Commitment, the
+United States emphasized that it "believes that the
+Optional Protocol [on child prostitution] and [the
+International Labour Organization's Convention
+No. 182 regarding child labor] provide a clear start-
+1g point for international action concerning tr
+imination of commercial sexual exploitation d
+children." Id.
+Under the Commerce Clause, Congress has
+power "[t]o regulate Commerce with foreign Na-
+5-222
+"foreign Nations" prong of the clause. Cases involving the reach of the Foreign Commerce Clause
+vis-a-vis congressional authority to regulate our citzens' conduct abroad are few and far between. Se
+.g., United States Bredimus, 352 F.3d 200
+207-08 (5th Cir.2003) (affirming conviction under
+18 U.S.C. § 2423(b), which reaches any person who
+ravels in foreign commerce "for the purpose of
+ngaging in illicit sexual conduct).FN2 It is not so
+much that the contours of the Foreign Commerce
+Clause are crystal clear, but rather that their scope
+has yet to be subjected to judicial scrutiny.
+FN2. As discussed in § IV(A), the cases
+arise primarily under the dormant Foreign
+Commerce Clause and invoke the interplay
+between state and federal authority.
+The Supreme Court has long adhered to a
+framework for domestic commerce comprised
+of
+"three general categories of regulation in which
+Congress is authorized
+engage under its commerce power, "Gonzales
+Raich, 545U.S. 1, -.,
+125 S.Ct. 2195, 2205, 162 L.Ed.2d 1 (2005):(1) the
+use of the channels of interstate commerce; (2) the
+instrumentalities of interstate commerce, or persons
+or things in interstate commerce; and (3) activities
+that substantially affect interstate commerce.
+See
+also United States | Lopez, 514 U.S. 549, 558-59,
+115 S.Ct. 1624, 131 L.Ed.2d 626 (1995); Raich,
+125 S.Ct. at 2215 (Scalia, J., concurring) (noting
+that *1103 for over thirty years,
+"our cases have
+mechanically recited that the Commerce Clause
+permits congressional regulation of three categories"). This framework developed in response to the
+unique federalism concerns that define congressional authority in the interstate context. Lopez,
+514
+FEET
+No analogous framework exists for foreign commerce.
+Further distinguishing the two spheres "is evidence that the Founders intended the scope of the
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prft=HTMLE&.. 1/30/2008
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Journal D.A.R. 962
+oreign commerce power to be ... greater" as com
+ared with interstate commerce. Japan Line, Lid.
+County of Los Angeles, 441 U.S. 434, 448, 99 S.Ct.
+1813, 60 L.Ed.2d 336 (1979). This expansive latitude given to Congress over foreign commerce is
+sensible given that "Congress' power to regulate interstate commerce may be restricted by considerations of federalism and state sovereignty," whereas
+"[ijt has never been suggested that Congress' power
+to regulate foreign commerce could be so limited."
+Id. at 448 n. 13, 99 S.Ct. 1813.
+Adapting the interstate commerce categories to
+oreign commerce in specific contexts is noi
+an insurmountable task. See, e.g., United States | Cum
+mings, 281 F.3d 1046, 1049 n. 1 (9th Cir.2002)
+(analyzing constitutionality of the International Parental Kidnaping Act, 18 U.S.C. § 1204(a), under
+Lopez's
+three-category
+approach).
+times,
+however, this undertaking can feel like jamming a
+square peg into a round hole. Instead of slavishly
+marching down the path of grafting
+the interstate
+commerce framework onto foreign commerce, we
+step back and take a global, commonsense approach
+to the circumstance presented here: The illicit sexual conduct reached by the statute expressly includes
+commercial sex acts performed by a U.S. citizen on
+foreign soil. This conduct might be immoral and
+criminal, but it is also commercial. Where, as in
+this appeal, the defendant travels in foreign commerce to a foreign country and offers to pay a child
+to engage in sex acts, his conduct falls under the
+broad umbrella of foreign commerce and consequently within congressional authority under the
+Foreign Commerce Clause.
+Page 4
+Seattle and flew to Cambodia via Japan, Thailand,
+and Malaysia. He was traveling on a business visa
+that he renewed on an annual basis.
+While in Cambodia, Clark came to the attention of Action Pour Les Enfants, a nongovernmental organization whose mission is to rescue minor boys who have been sexually molested
+by non-Cambodians. Clark came under suspicion
+when street kids reported to social workers that he
+was molesting young boys on a regular basis. The
+organization in turn reported him to the Cambodian
+National Police. In late June 2003, the Cambodian
+police arrested Clark after discovering him in a
+Phnom Penh guesthouse engaging in sex acts with
+two boys who were approximately ten and thirteen
+years old. He was charged with debauchery. The
+United States government received permission from
+the Cambodian government to take jurisdiction over
+BACKGROUND
+Michael Lewis Clark, a seventy-one year old
+U.S. citizen and military veteran, primarily resided
+in Cambodia from 1998 until his extradition in
+2003. He typically took annual trips back to the
+United States and he also maintained real estate,
+bank accounts, investment accounts, a driver's license, and a mailing address in this country. Following a family visit in May 2003, Clark left
+*1104 U.S. officials-assisted by the Cambodian
+National Police and the Australian Federal Policeconducted an investigation that led to Clark's confession and extradition to the United States. As part
+of the investigation, the younger boy told authorities that he had engaged in sex acts with Clark because he needed money to buy food for his brother
+and sister. The older boy stated that Clark had hired
+him in the past to perform sex acts, on one occasion
+paying five dollars. Other young boys whom Clark
+had molested reported that they were paid about
+two dollars, and Clark stated that he routinely paid
+this amount. Clark acknowledged that he had been
+a pedophile since at least 1996, "maybe longer,"
+and had been involved in sexual activity with approximately 40-50 children since he began traveling in 1996.
+Upon his return to the United States, Clark was
+indicted under the provisions of the newly-enacted
+Prosecutorial Remedies and Other Tools to End the
+Exploitation of Children Today Act
+of 2003
+("PROTECT Act"), Pub.L. No. 108-21, 117 Stat.
+650 (2003). ENs He pled guilty to two counts under
+18 U.S.C. § 2423(c) and (e) FNe but reserved the
+right to appeal his pre-trial motion to dismiss based
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prft=HTMLE&.. 1/30/2008
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Journal D.A.R. 962
+1 constitutional, jurisdictional, and statutory col
+ruction grounds. See United States | Clark, 31
+F.Supp.2d 1127 (W.D.Wash.2004) (order denying
+Clark's motion to dismiss).
+FN3. Although Clark was reportedly the
+first person charged under the PROTECT
+Act's extraterritorial provisions, see Blaine
+Harden, Veteran Indicted on Sex Charges;
+Man Is First Charged Under Protect Law's
+Provision on Tourism, Wash. Post at A5
+(Sept. 25, 2003), the U.S. Immigration and
+Customs Enforcement's "Operation Predator" reports that thirteen arrests had been
+made
+as of July 19, 2005, http://
+www.ice.gov/graphics/
+news/
+factsheets/statistics.htm (last visited Dec.
+29,2005).
+FN4. Subsection (e) provides that an attempt or conspiracy to violate § 2423(c)
+shall be punishable in the same manner as
+a completed violation.
+On appeal, Clark's challenge centers on the
+constitutionality of § 2423(c). Adopted in 2003 as
+part of the PROTECT Act, § 2423(c) provides as
+follows:
+c) Engaging in illicit sexual conduct in foreigi
+laces. Any United States citizen or alien admitte
+for permanent residence who travels in foreign
+commerce, and engages in any illicit sexual conduct with another person shall be fined under this
+title or imprisoned not more than 30 years, or both.
+This provision was first proposed as part of the
+Sex Tourism Prohibition Improvement Act of 2002,
+Page 5
+108-66, at 5 (2003) (Conf.Rep.), as reprinted in
+2003 U.S.C.C.A.N. 683. This section was incorporated verbatim into the 2003 legislation but the Re-
+port on the PROTECT Act does not include the prior reference to constitutional authority.
+Before the PROTECT Act became law in 2003,
+§ 2423(b) required the government to prove that the
+defendant "travel[ed] in foreign commerce, or conspire[d] to do so, for the purpose of engaging in "
+specified sexual conduct with a person under eighteen years of age. Violent Crime Control and Law
+Enforcement Act of 1994, Pub.L. 103-322, 108
+Stat. 1796, Sec. 160001 *1105 (1994) (codified as
+amended at 18 U.S.C. § 2423(b)) (emphasis added).
+The PROTECT Act replaced this single section
+with new subsections (b) through (g), with the new
+subsection (b) remaining substantively the same as
+the former subsection (b). Subsection (c) is an entirely new section which deletes the "for the purpose of" language.'Ns The conference report accompanying the PROTECT Act explains that Conthe intent requirement from §
+2423(c) so that "the government would only have to
+prove that the defendant engaged in illicit sexual
+conduct with a minor while in a foreign country."
+H.R.Rep. No. 108-66 at 51; see alsoHl.R.Rep. No.
+107-525, at 2 (same statement in report for failed
+2002 bill). Consequently, for § 2423(c) to apply,
+the two key determinations are whether the defendant "travel[ed] in foreign commerce" and "engages
+in any illicit sexual conduct."
+FN5. Subsection (d) covers persons who
+provide ancillary services to
+facilitate
+travel "for the purpose of" engaging in illegal acts; subsection (e) covers attempt
+onduct with minors." ld. The provision was ne
+nacted, however, until it was added to the PRO
+TECT Act the following year. SeeH.R.Rep. No.
+The statute defines "illicit sexual conduct" in
+two ways: First, the definition includes "a sexual
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prft=HTMLE&.. 1/30/2008
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Journal D.A.R. 962
+act (as defined in section 2246 [18 U.S.C. § 2246] )
+with a person under 18 years of age that would be
+in violation of chapter 109A[18 U.S.C. §§ 2241 et
+seq.] if the sexual act occurred in the special maritime and territorial jurisdiction of the United
+States." 18 U.S.C. § 2423(f)(1). Chapter 109A, in
+turn, criminalizes various forms of sexual abuse including, for example, aggravated sexual abuse by
+threat, or other means, 18 U.S.C.
+2241(a)-(b); sexual abuse by threatening or placing
+that other person in fear, 18 U.S.C. § 2242; and
+sexual abuse of a minor or ward, 18 U.S.C. § 2243.
+These violations share the common characteristic
+that there is no economic component to the crime.
+In other words, they are non-commercial sex acts.
+In contrast, the second prong of the definition
+covers "any commercial sex act (as defined in section 1591[18 U.S.C. § 1591] ) with a person under
+18 years of age."
+18 U.S.C. § 2423(f)(2).
+"Commercial sex act," in turn, is defined as "any
+sex act, on account of which anything of value is
+given to or received by any person."
+1591(c)(1). Clark acknowledges that his conduct
+qualifies as illicit sexual conduct, and he admitted
+in his plea agreement that he "intended to pay each
+of the boys and each of the boys expected such payment in exchange for the sexual encounter." Ac-
+cordingly, it is this second "commercial sex act"
+prong that is at issue in Clark's appeal.
+Page 6
+77 (1979), we begin our analysis with Clark's non
+onstitutional claim.
+FN6. Clark initially raised issues related to
+his sentence but has since withdrawn this
+aspect of his appeal.
+*1106 I. SECTION 2423(C) COMPORTS WITH
+THE PRINCIPLES OF INTERNATIONAL LAW
+[1] We start with Clark's argument that extra-
+ANALYSIS
+Clark does not dispute that he traveled in
+"foreign commerce,
+" nor does he dispute that he
+engaged in illicit commercial sexual conduct. The
+challenge he raises is to congressional authority to
+regulate this conduct. In addition to his Commerce
+Clause challenge, Clark attacks his conviction on
+international law, statutory construction, and Due
+Process grounds. FN6 In recognition of the principle
+that courts have a "strong duty to avoid constitutional issues that need not be resolved in order to
+letermine the rights of the parties to the case undi
+onsideration."County Court of Ulster County
+Allen, 442 U.S. 140, 154, 99 S.Ct. 2213, 60 L.Ed.2d
+application is proper based on the nationality principle.
+FN7. Clark's challenge is distinct from the
+more common scenario where a party challenges only the extrateritorial reach of a
+statute without contesting
+congressional
+authorit
+, to enact the statute. See, e.g..
+Small || United States, 544 U.S. 385, -..,
+125 S.Ct. 1752, 1754, 161 L.Ed.2d 651
+(2005) (holding that the phrase "convicted
+in any court" in a statute criminalizing
+firearm possession by a convicted felon, 18
+U.S.C. § 922(g)(1), does not apply to extraterritorial
+convictions);
+Timberlane
+Lumber Co. | Bank of Am., 549 F.2d 597,
+608-15 (9th Cir.1976) (discussing the extraterritorial reach of U.S. antitrust laws to
+ctivities in toreign countries), supersede
+by statute as stated inMcGlinchy Shel
+Chemical Co., 845 F.2d 802, 813 n. 8 (9th
+Cir. 1988); United States
+F.2d 744, 750 (9th Cir.1973) (holding that
+SHE
+The legal presumption that Congress ordinarily
+intends federal statutes to have only domestic application, see Small | United States, 544 U.S. 385,
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prft=HTMLE&.. 1/30/2008
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Journal D.A.R. 962
+--, 125 S.Ct. 1752, 1755, 161 L.Ed.2d 651 (2005),
+is easily overcome in Clark's case because the text
+of § 2423(c) is explicit as to its application outside
+the United States. See18 U.S.C. § 2423(c) (titled
+"Engaging in illicit sexual conduct in foreign
+›laces" and reaching people "who
+pian commerceci see ciso Sale dra Haitian" Cos.
+Council, Inc., 509 U.S. 155, 176, 113 S.Ct. 2549,
+125 L.Ed.2d 128 (1993) (explaining that there must
+be "affirmative evidence of intended extraterritorial
+application"). By its terms, the provision is exclusively targeted at extraterritorial conduct.
+Having addressed this threshold issue, we ask
+whether the exercise of extraterritorial jurisdiction
+in this case comports with principles of international law. See United States
+Vasquez-Velasco, 15
+F.3d 833, 839 (9th Cir.1994) ("In
+determining
+whether a statute applies extraterritorially, we also
+presume that Congress does not intend to violate
+rinciples of international law.") (citing McCulloc/
+Sociedad Nacional de Marineros de Honduras
+372 U.S. 10, 21-22, 83 S.Ct. 671
+, 9 L.Ed.2d 547
+(1963)); see also United States | Neil, 312 F.3d
+419, 421 (9th Cir.2002). Of the five general principles that permit extraterritorial criminal jurisdiction, FNs the nationality principle most clearly applies to Clark's
+The nationality principle
+permits a country to apply its statutes to extrater
+itorial acts of its own nationals." United States |
+Hill, 279 F.3d 731, 740 (9th Cir.2002). Jurisdiction
+based solely on the defendant's status as a U.S. citizen is firmly established by our precedent See
+e.g.. United States
+| Walczak, 783 F.2d 852, 854
+(9th Cir.1986) (holding that jurisdiction over a U.S
+citizen who violated a federal
+statute while in
+Mckeel VAS slamic Repub. e Iran, 122 Fr2d S82.
+722 F.2d 582
+588 (9th Cir.1983) (noting that nationality principle
+ermits states to punish the wrongtul conduct of it
+itizens); United States | King, 552 F.2d 833, 85
+(9th Cir.1976) (commenting that nationality principle would apply to U.S. citizen defendants).
+Clark's U.S. citizenship is uncontested.FNº *1107
+Accordingly, extraterritorial application of §
+2423(c) to Clark's conduct is proper based on the
+nationality principle. "NIo
+Page 7
+FN8. The five jurisdictional bases are territorial, national, protective, universal, and
+passive
+personality.
+SeeRestatement
+(Third) of Foreign Relations Law of the
+nited States § 402 (1987); United State
+Hill. 279 F.3d 731. 739 (9th Cir.2002
+(listing the five principles).
+FN9. Because Clark is a U.S. citizen, we
+do not reach the issue whether reliance or
+the nationality principle is also proper
+when "alien[s] admitted for permanent residence" are prosecuted under § 2423(c). 18
+U.S.C. § 2423(c).
+FN10. Although the district court four
+hat extraterritorial jurisdiction was propc
+under both the nationality principle and
+universality
+principle,
+Clark,
+315
+F.Supp.2d at 1131, we decline to address
+whether the universality principle also applies in Clark's case because extraterritorial application of a criminal law need be
+justified by only one of the five principles
+M ex a emited States, 30 F52d 1308, 131,
+730 F.2d 1308. 1312
+(9th Cir.1984).
+Clark also seeks to invalidate the statute because, in his view, extraterritorial application is unreasonable. SeeRestatement (Third) of Foreign Re-
+lations Law of the United States § 403 (1987);
+Vasquez-Velasco, 15 F.3d at 840-41 (holding that
+extraterritorial application of U.S. statute to violent
+crimes associated with drug trafficking was reasonable under international law). The record provides
+no support for this argument. Clark cites no precedent in which extraterritorial application was found
+unreasonable in a similar situation. Cambodia cor
+sented to the United States taking jurisdiction an‹
+nothing suggests that Cambodia objected in any
+way to Clark's extradition and trial under U.S. law.
+Clark himself stated to a U.S. official in Cambodia
+that he "wanted to return to the United States" because he saw people dying in the Cambodian prison
+and was very much afraid that if [he] stayed in th
+rison, [he] would not survive." Having been save
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prft=HTMLE&.. 1/30/2008
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Journal D.A.R. 962
+from immediate prosecution in Cambodia, it is
+somewhat ironic that he now challenges the law in
+a United States court.
+Page 8
+II. CLARK'S CONDUCT FALLS WITHIN THE
+SCOPE OF § 2423(C)
+Clark posits that § 2423(c) can be saved from
+constitutional scrutiny by interpreting it to require
+that the illicit sexual conduct take place while the
+defendant is literally still traveling. The district
+court declined to dismiss the indictment on this
+ground, explaining that "Clark is attempting to add
+elements to the crime ... that simply do not exist in
+the statute." Clark, 315 F.Supp.2d at 1130. We
+trigger constitutional or other concerns is
+an issue we leave for another day.
+The legislative history also supports the plain
+reading that we adopt. The conference report explains that Congress eliminated the intent requirement so that "the government would only have to
+prove that the defendant engaged in illicit sexual
+conduct with a minor while in a foreign country."
+H.R.Rep. No. 108-66 at 51. From a practical perspective, it seems non-sensical for Congress to limit
+the scope of § 2423(c) to the unlikely scenario
+where the abuse occurs while the perpetrator is literally en route. This reading would eviscerate §
+2423(c) by severely limiting its use to only those
+people who commit the offense while physically
+onboard an international flight, cruise, or other
+mode of transportation. We decline to adopt Clark's
+strained reading of the statute.
+§ 2423(c). Cf. Jones | United States, 529 U.S. 848,
+850-51, 120 S.Ct. 1904, 146 L.Ed.2d 902 (2000)
+(avoiding constitutional
+statute's text to hold that certain owner-occupied
+residences do not qualify as property "used in"
+commerce).
+[2] The statute is plain on its face: Section
+2423(c) reaches "[a]ny United States citizen or alien admitted for permanent residence who travels in
+foreign commerce, and engages in any illicit sexual
+conduct with another person." It does not require
+that the conduct occur while traveling in foreign
+commerce. In Clark's case,
+the lapse in time
+between his most recent transit between the United
+States and Cambodia and his arrest was less than
+two months. We see no plausible reading of the
+statute that would exclude its application to Clark's
+conduct because of this limited gap.fNI' Because
+the statute is unambiguous and Clark's conduct falls
+squarely within the class of persons whose conduct
+Congress intended to criminalize under this statute
+we do not invoke the rule of lenity. Jones, 529 U.S
+at 858, 120 S.Ct. 1904 (*ambiguity concerning the
+ambit*1108 of criminal statutes should be resolved
+in favor of lenity") (citation omitted).
+FN11. Whether a longer gap between the
+travel and the commercial sex act could
+III. NO DUE PROCESS VIOLATIOn
+[3] The next question is whether extrateritorial
+application of § 2423(c) violates the Due Process
+Clause of the Fifth Amendment because there is an
+insufficient nexus between Clark's conduct and the
+United States. We hold that, based on Clark's U.S.
+citizenship, application of § 2423(c) to his extraterritorial conduct is neither "arbitrary [n]or fundamentally unfair." United States || Davis, 905 F.2d
+245, 249 (9th Cir.1990).FNI2
+FN12. Although Clark's citizenship alone
+is sufficient to satisfy Due Process concerns, his U.S. investments, ongoing receipt of federal retirement benefits and use
+of U.S. military flights also underscore his
+multiple and continuing ties with this
+country.
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prfl=HTMLE&. 1/30/2008
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Joumal D.A.R. 962
+Indeed,
+. "even resort to the Commerce Clause
+can[not] defy the standards of due process." Sec'y
+of Àgric. | Cent. Roig Refining Co., 338 U.S. 604,
+616, 70 S.Ct. 403, 94 L.Ed. 381 (1950).
+In Blackmer | United States, 284 U.S. 421, 52
+S.Ct. 252, 76 L.Ed. 375 (1932), the Supreme Court
+explained that the extrateritorial application of
+U.S. law to its citizens abroad did not violate the
+Fifth Amendment. The Court declared that despite
+moving his residence to France, the U.S.-citizen defendant "continued to owe allegiance to the United
+States. By virtue of the obligations of citizenship,
+the United States retained its authority over him,
+and he was bound by its laws made applicable to
+him in a foreign country." Id. at 436, 52 S.Ct. 252.
+This longstanding principle that citizenship alone is
+sufficient to satisfy Due Process concerns still has
+force. Citing Blackmer, we recently affirmed that
+"[t]here is no doubt that the United States may exercise jurisdiction over American nationals living
+abroad, regardless
+where the crime is commit-
+n.d.* Unied States Corey, 232 F.3d 1166, 1179
+n. 9 (9th Cir.2000).
+Clark offers no authority that calls into question this principle. Instead, he relies on cases that
+involved foreign nationals, which meant that the
+courts had no choice but to look beyond nationality
+to establish the defendants' ties with the United
+States. See, e.g., United States | Klimavicius-Viloria, 144 F.3d 1249, 1254 (9th Cir.1998) (defendant
+and crew "were all Columbians"); Davis, 905 F.2d
+at 247 ("Davis is not a citizen of the United States.").
+Clark is a U.S. citizen, a bond that "implies a
+duty of allegiance on the part of the member and a
+duty of protection on the part of the society. These
+are reciprocal obligations, one being a compensation for the other." Luria || United States, 231 U.S.
+9, 22, 34 S.Ct. 10, 58 L.Ed. 101 (1913). *1109 Predicated on this imputed allegiance, application of §
+2423(c) to Clark's extrateritorial conduct does not
+violate the Due Process Clause.™NI3 Having concluded that none of Clark's other arguments resolve
+this appeal, we turn to Clark's Commerce Clause
+Page 9
+challenge.
+FN13. Clark also raises notice and vagueness challenges, neither of which withstands scrutiny. Section 2423(c) was enacted in April 2003-while Clark was visiting the United States-and the commercial
+sex act did not occur until June 2003. Mere
+"ieniana per the la. vil mo i8 u.s.
+57, 68, 30 S.Ct. 663, 54 L.Ed. 930 (1910).
+Clark might have been ignorant of the law,
+but he had constitutionally sufficient notice. We are not persuaded by Clark's argument that the statute's "travels in foreign
+commerce" language gave him "no reasonable basis" to anticipate being haled into a
+U.S. court. For a criminal statute to survive
+a vagueness challenge, we require only
+that "a reasonable person of ordinary intelligence would understand what conduct the
+statute prohibits." United States | Lee, 183
+F.3d 1029, 1032 (9th Cir.1999). A reasonable person would easily understand §
+2423(c) to cover Clark's travel to Cambodia and sexual conduct with minors there.
+IV. CONGRESS'S FOREIGN COMMERCE
+CLAUSE POWER EXTENDS TO REGULAT-
+ING COMMERCIAL SEX ACTS ABROAD
+[4] In considering whether Congress exceeded
+its power under the Foreign Commerce Clause in
+enacting § 2423(c), we ground our analysis in the
+fundamental principle that "[i]t is an essential attribute of [Congress's power over foreign comfurther mindful of the Supreme Court's caution that
+"[dJue respect for the decisions of a coordinate
+branch of Government demands that we invalidate
+a congressional enactment only upon a plain showing that Congress has exceeded its constitutional
+bounds." United States | Morrison, 529 U.S. 598,
+607, 120 S.Ct. 1740, 146 L.Ed.2d 658 (2000). No
+plain showing has been made here. In light of Con-
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prfl=HTMLE&.. 1/30/2008
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Journal D.A.R. 962
+gress's sweeping powers over foreign commerce,
+we conclude that Congress acted within its constitutional bounds in criminalizing commercial sex acts
+committed by U.S. citizens who travel abroad in
+foreign commerce. FNI+
+FN14. Our review of the constitutionality
+of § 2423(c) is focused on congressional
+authority under the Commerce Clause. As
+pointed out by the Government, the Su-
+Page 10
+ment that the federal government can exercise no powers except those specifically
+enumerated in the Constitution, and such
+implied powers as are necessary and proper to carry into effect the enumerated
+powers, is categorically true only in re-
+Crisi righe aspara cop.,
+" United States
+299 U.S.
+304, 315-16,
+57 S.Ct. 216, 81 L.Ed. 255
+(1936). Standing alone, however, this reference does not establish that the Foreign
+Commerce Clause has no meaning or is
+without bounds. Nor does
+it necessarily
+mean that congressional regulation of external affairs has no limits.
+The Government has not argued-nor is there any indicthe legislation-that Congress enacted § 2423(c) based on an implied for
+eign affairs power. Cf. United
+Hernandez-Guerrero, 147 F.3d 1075, 107}
+(9th Cir. 1998)
+(noting that in exercising
+immigration power,
+arena of foreign affairs,
+"Congress is not
+subject to the rigid constraints that govern
+its authority in domestic contexts"). Nonetheless,
+given our charge to uphold the
+tatute absent a plain showing that it is un
+constitutional, United States Morrisor
+529 U.S. 598, 607, 120 S.Ct. 1740, 146
+L.Ed.2d 658 (2000), we acknowledge that
+Congress's plenary authority over foreign
+affairs may also provide a sufficient basis
+for § 2423(c). See, e.g., Curtiss-Wright Ex-
+port Corp., 299 U.S. at 315, 57 S.Ct. 216;
+United States | Belmont, 301 U.S. 324,
+331, 57 S.Ct. 758, 81 L.Ed. 1134 (1937) (
+"[C]omplete power over international affairs is in the national government ...").
+At the outset, we highlight that § 2423(c) contemplates two types of "illicit *1110 sexual conduct": non-commercial and commercial. Clark's
+conduct falls squarely under the second prong of
+the definition, which criminalizes "any commercial
+sex act ... with a person under 18 years of age." 18
+U.S.C. § 2423(f)(2). ENIS In view of this factual
+posture, we abide by the rule that courts have a
+"strong duty to avoid constitutional issues that need
+not be resolved in order to determine the rights of
+the parties to the case under consideration, "County
+Court of Ulster County, 442 U.S. at 154, 99 S.Ct.
+2213, and limit our holding to § 2423(c)'s regulation of commercial sex acts. FN16
+FN15. That the authorities arrested Clark
+before the money had actually changed
+hands is immaterial to our analysis. Clark
+does not dispute that he hired the boys to
+engage in sex acts with the promise of
+monetary payment, and the statute does not
+require that the victims be paid by the defendant prior to arrest. Seel8 U.S.C. §
+2423(e) (providing that an attempt to violate § 2423(c) shall be punishable in the
+same manner as a completed violation). In
+fact, the second count to which Clark pled
+guilty was that he traveled in foreign commerce and "thereafter attempted to engage
+in illicit sexual conduct."
+FN16. We do not decide the constitutionality of § 2423(c) with respect to illicit sexual conduct covered by the non-commercial
+prong of the statute, such as sex acts accomplished by use of force or threat. Seel8
+U.S.C. § 2423(f) (defining "illicit sexual
+conduct" in part by reference to crimes listed under 18 U.S.C. §§ 2241 et seq.). The
+situation presented by § 2423(c) is distinct
+from challenges in which courts have
+carved out a discrete subset of conduct
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prft=HTMLE&.. 1/30/2008
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Journal D.A.R. 962
+from a statute based on distinctions deduced from the statutory scheme. See, e.g..
+Raich, 125 S.Ct. at 2211 (disagreeing with
+this court's isolation of a "separate and distinct" class of activities beyond the reach
+of the federal statute and instead concluding that the subdivided class "was an esscheme, United State are Margy, 32y
+F.3d 1114, 1115 (9th Cir.2003) (holding a
+statute unconstitutional as applied to the
+limited category of simple intra-state possession of child pornography that had not
+traveled in interstate commerce). Here, the
+statute is plain on its face in dividing the
+definition of "illicit sexual conduct"
+two distinct, numbered prongs. We address
+only the prong that applies to Clark's conduct. This decision to limit our holding to
+commercial sex acts is an expression of judicial restraint, not an attempt to atomize a
+cohesive statutory scheme.
+A. THE COMMERCE CLAUSE: STRUCTURE
+AND HISTORY
+Chief Justice Marshall observed long ago that
+"[t]he objects, to which the power of regulating
+commerce might be directed, are divided into three
+distinct classes-foreign nations, the several states,
+and Indian Tribes. When forming this article, the
+convention considered them as
+entirely distinct."
+Cherokee Nation | Georgia, 30 U.S. 1, 18, 5 Pet
+1, 8 L.Ed. 25 (1831). Looking to the text, the single
+clause indeed embodies three subclauses for which
+distinct prepositional language is used: "To regulate
+Commerce with foreign Nations,
+and among the
+several States,
+and with the Indian Tribes." U.S.
+Const. art. I, § 8, cl. 3.
+Among legal scholars there has been considerable debate may be of the enter sunilauses, consig.
+ering that they share the common language "[to
+regulate Commerce." Some commentators take the
+view that Congress's powers over commerce with
+foreign nations and Indian tribes are broader than
+Page 11
+over interstate commerce. See, e.g.. Kenneth M.
+Casebeer, The Power to Regulate "Commerce with
+Foreign Nations" in a Global Economy and the Fu-
+ture of American Democracy: An Essay, 56 U.
+Miami L.Rev. 25, 33-41 (2001); 1 R. Rotunda & J.
+Nowak, Treatise on Constitutional Law § 4.2 (3d
+ed. 1999) ("Even during periods when the Justices
+were debating whether to significantly restrict the
+congressional power to regulate intrastate activities
+under the commerce power, there was no serious
+advocacy*1111 of restrictions on the federal
+powers in these other areas.").
+Other scholars maintain that Congress has coextensive powers under the Commerce Clause's
+subdivisions. See eg. Louis Henkin, Foreign Af-
+fairs and the Constitution 70 n. 9 (1972) ("It is generally accepted, however, that the power of Congress is the same as regards both [foreign and interstate commerce]."); Saikrishna Prakash, Our Three
+Commerce Clauses and the Presumption of In-
+trasentence Uniformity, 55 Ark. L.Rev. 1149, 1173
+(2003) ("In practice, we have three different Commerce Clauses when text and history indicate that
+we ought to have but one."). Despite the longrunning lively debate among scholars, no definitive
+view emerges regarding the relationship among the
+three subclauses. Nonetheless, Supreme Court precedent points to the conclusion that the Foreign
+Commerce Clause is different than the Interstate
+Commerce Clause. See Japan Line, 441 U.S. at
+448, 99 S.Ct. 1813 ("[T]here is evidence that the
+Founders intended the scope of the foreign commerce power to be ….. greater" as compared with in-
+Regardless of how separate the three subclauses may be in theory, the reality is that they
+have been subject to markedly divergent treatment
+by the courts. This approach is not surprising given
+the considerably different interests at stake when
+Congress regulates in the various arenas. Most notably, regardless of whether the subject matter is
+drugs, gender-motivated violence, or gun possession, a prominent theme runs throughout the interstate commerce cases: concern for state sovereignty
+and federalism. On the other hand, "[t)he principle
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prft=HTMLE&. 1/30/2008
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Journal D.A.R. 962
+of duality in our system of government does not
+touch the authority of the Congress in the regulation of foreign commerce." Bd. of Trustees of Univ
+of Ill.. 289 U.S. at 57, 53 S.Ct. 509. This distinction
+provides a crucial touchstone in applying the Foreign Commerce Clause, for which Congress's authority to regulate has not been defined with the
+precision set forth by Lopez and Morrison in the interstate context.
+We start with the component that has dominated judicial consideration of the Commerce
+Clause: "among the several States." After decades
+of expansive reading by the courts, see, e.g..
+Katzenbach | McClung, 379 U.S. 294, 303-04, 85
+S.Ct. 377, 13 L.Ed.2d 290 (1964) ("[W]here we
+find that the legislators ... have a rational basis for
+finding a chosen regulatory scheme necessary to the
+protection of commerce, our investigation is at an
+end."), the mid-1990s saw a retrenchment in Commerce Clause jurisprudence beginning with the watershed case of Lopez. In Lopez, the Court held that
+a statute which criminalized possession of a firearm
+in a school zone was beyond Congress's Commerce
+Clause authority. 514 U.S. at 552, 115 S.Ct. 1624.
+In so holding, the Court stressed its concern that an
+overly expansive view of the Interstate Commerce
+Clause "would effectually obliterate the distinction
+between what is national and what is local and create a completely centralized government." Id. at
+557, 115 S.Ct. 1624 (quoting NLRB 1
+The Court reiterated these concerns five years later
+in Morrison in striking down a provision under the
+Violence Against Women Act: "[T]he concern ...
+that Congress might use the Commerce Clause to
+completely obliterate the Constitution's distinction
+between
+lational and local authority seems we
+unded." Morrison. 529 U.S. at 615. 120 S.Ct. 174
+In addition to announcing a shift to a more constrained view of Congress's power over interstate
+commerce, Lopez and Morrison ossified the threecategory framework that the Court had long applied
+*1112 to interstate commerce cases. See Lopez, 514
+U.S. at 558-59, 115 S.Ct. 1624; Morrison, 529 U.S.
+Page 12
+at 609-14, 120 S.Ct. 1740; see also Raich, 125 S.Ct.
+at 2215 (Scalia, J., concurring) (noting that for over
+thirty years, "our cases have mechanically recited
+that the Commerce Clause permits congressional
+regulation of three categories"). As noted earlier,
+these three familiar categories are (1) the use of the
+channels of interstate commerce; (2) the instrumentalities of interstate commerce, or persons or
+things in interstate commerce; and (3) activities that
+substantially affect interstate commerce. See Lopez,
+514 U.S. at 558-59, 115 S.Ct. 1624. Within the interstate commerce arena, the guiding force of Lopez
+and Morrison quickly took firm hold, and lower
+ourts have adhered closely to tr
+tructure. See, e.g.. United States 1 Adams, 34
+F.3d 1024, 1027-28 (9th Cir.2003) (reciting the
+three categories set out in Lopez and Morrison and
+applying the third to a statute criminalizing the intrastate possession of child pornography).
+This past term the Court introduced a new
+wrinkle
+in
+interstate commerce's jurisprudential
+fabric when it held that the Controlled Substances
+Act was a valid exercise of Congress's powers under the Commerce Clause. See Raich, 125 S.Ct. at
+2201. Raich did not alter the fundamental threeprong rubric, but the Court took a more generous
+view of Congress's power over interstate commerce
+than seen in Lopez and Morrison. Over the dissent's
+pointed objections, the majority concluded that
+"Congress had a rational basis for concluding that
+leaving home-consumed marijuana outside federal
+control would similarly affect price and market
+conditions." Id. at 2207. This "rational basis" for
+finding a nexus between home-consumed marijuana
+and the interstate market put
+the regulation
+"squarely within Congress' commerce power." Id.
+pheres of state sovereignty from excessive federa
+'ncroachment." Id. at 2220 (O'Connor, J., dissen
+ing).
+Although the Supreme Court's view of the In-
+terstate Commerce Clause has "evolved over time,"
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prft=HTMLE&.. 1/30/2008
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Journal D.A.R. 962
+id. at 2205, Indian Commerce Clause jurisprudence
+straight line proposition. See
+e8. United States Sara, 541 U.S. P93, 200, 124
+S.Ct. 1628, 158 L.Ed.2d 420 (2004) ("[T]he Constitution grants Congress broad general powers to legislate in respect to Indian tribes, powers that we
+have consistently described as "plenary and exclusive' ... This Court has traditionally identified the In-
+dian Commerce Clause, U.S. Const., Art. I, § 8, cl.
+3, and the Treaty Clause, Art. II, § 2, cl. 2, as
+sources of that power.") (citations omitted). Indeed,
+the Supreme Court has commented on the "very
+different applications" of the Interstate and Indian
+Commerce Clause powers, explaining that interstate
+commerce jurisprudence "is premised on a structural understanding of the unique role of the States in
+our constitutional syster that is not readily imporcases involving the Indian Commerce
+Clause." Cotton Petroleum Corp. New Mexico,
+490 U.S. 163, 192, 109 S.Ct. 1698, 104 L.Ed.2d
+209 (1989). In contrast to the federal government's
+relationship with the states, its relationship with In-
+dian tribes is "based on a history of treaties and the
+assumption of a "guardian-ward" status." Morton
+Mancari, 417 U.S. 535, 551, 94 S.Ct. 2474,
+L.Ed.2d 290 (1974). The Commerce Clause stands
+as one of the main textual grants of Congress's
+plenary power to regulate this special relationship
+between the federal government and Indian tribes.
+Id. at 551-52, 94 S.Ct. 2474. In this context,*1113
+the Court has defined Congress's authority under
+the Indian Commerce Clause without reference to
+the rigid categories of Lopez and Morrison. See.
+e.g, Lara, 541 U.S. at 196, 200-207, 124 S.Ct.
+1628 (upholding Congress's authority to adjust tribal sovereignty in criminal matters under the Indian
+Commerce Clause without considering the threecategory framework).
+As with the Indian Commerce Clause, the Foreign Commerce Clause has followed its own distinct evolutionary path. Born largely from a desire
+for uniform rules governing commercial relations
+with foreign countries, the Supreme Court has read
+the Foreign Commerce Clause as granting Congress
+sweeping powers. See Bd. of Trustees of Univ. of
+Ill., 289 U.S. at 59, 53 S.Ct. 509 ("[W]ith respect to
+Page 13
+foreign intercourse and trade[.] the people of the
+United States act through a single government with
+unified and adequate national power."); see also
+Rotunda & Nowak § 4.2 (The Court has always recognized a plenary power in Congress to deal with
+matters touching upon foreign relations or foreign
+trade."); Robert J. Delahunty, Federalism Beyond
+the Water's Edge: State Procurement Sanctions and
+Foreign Affairs, 37 Stan. J. Int'l L. 1, 16-26 (2001)
+(describing the origins of the Foreign Commerce
+Clause). This view was laid down nearly two centuries ago when Chief Justice Marshall stated that
+"[i]t has, we believe, been universally admitted,
+that [the words of the Commerce Clause] comprehend every species of commercial intercourse
+Getvens li Uden, 2 U.S. ( orea) 1 1930
+L.Ed. 23 (T824).
+The Court has been unwavering in reading
+Congress's power over foreign commerce broadly
+See, eg., California Bankers Ass'n | Shultz, 416
+U.S. 21, 46, 94 S.Ct. 1494, 39 L.Ed.2d 812 (1974)
+(stating that Congress's plenary authority over foreign commerce "is not open to dispute"); Buttfield
+[ Stranahan, 192 U.S. 470, 492-93, 24 S.Ct. 349,
+48 L.Ed. 525 (1904) (describing the "complete
+(Scalia, J., dissenting) ("Congress has broad power
+under Article I, § 8, cl. 3, "to regulate Commerce
+with foreign Nations, ' and this Court has repeatedly
+upheld its power to make laws applicable to persons or activities beyond our territorial boundaries
+where United States interests are affected."). There
+is no counterpart to Lopez or Morrison in the foreign commerce realm that would signal a retreat
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prft=HTMLE&. 1/30/2008
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Journal D.A.R. 962
+Page 14
+S.Ct. 1813; see also Bd. of Trustees of Univ. of IIl.,
+289 U.S. at 59, 53 S.Ct. 509 (instrumentality of a
+state was not entitled to import articles duty free
+"with respect to foreign intercourse and
+trade[,] the people of the United States act through
+a single government with unified and adequate national power"). By contrast, under the dormant In-
+terstate Commerce Clause,
+"reconciliation of the
+conflicting claims of state and national power is to
+be attained only by some appraisal and accommodation of the competing demands of the state and national interests involved." Southern Pac. Co. | Ar-
+iz. ex rel. Sullivan, 325 U.S. 761, 768-69, 65 S.Ct.
+1515, 89 L.Ed. 1915 (1945).
+*1114 Clark's case illustrates the predominance
+of national interests and the absence of state sovereignty concerns in Foreign Commerce Clause jurisprudence. No state has voiced an interest in the proceedings nor is there an indication of any state interest at stake in determining the constitutionality
+of § 2423(c). Because this case is divorced from the
+common federal/state interplay seen in the Interstate Commerce Clause cases, we find ourselves in
+sparsely charted waters. We thus look to the text of
+§ 2423(c) to discern whether it has a constitutionally tenable nexus with foreign commerce.
+2423(c)'s commercial sex acts prong are straightforward. First, the defendant must "travel[ ] in foreign
+commerce." 18 U.S.C. § 2423(c). Second, the defendant must "engage[ ] in any illicit sexual conduct with another person, "id., which in this case
+contemplates "any commercial sex act ... with a
+person under 18 years of age." 18 U.S.C. §
+2423(f)(2). We hold that § 2423(c)'s combination of
+requiring travel in foreign commerce, coupled with
+engagement in a commercial transaction while
+abroad, implicates foreign commerce to a constitutionally adequate degree.
+Beginning with the first element, the phrase
+"travels in foreign commerce" unequivocally establishes that Congress specifically invoked the Foreign Commerce Clause. The defendant must therefore have moved in foreign commerce at some
+point to trigger the statute. In Clark's case, he
+traveled from the United States to Cambodia.
+"Foreign commerce" has been defined broadly
+for purposes of Title 18 of the U.S.Code, with the
+statutory definition reading, in full: "The term
+'foreign commerce', as used in this title, includes
+commerce with a foreign country." 18 U.S.C. § 10.
+Admittedly, this definition is not particularly helpful given its rearrangement of the words being
+defined in the definition itself. Courts have understandably taken the broad wording to have an expansive reach. See, e.g., United States | Montford,
+27 F.3d 137, 139-40 (5th Cir.1994) (discerning that
+"Congress intended foreign commerce to mean
+travel to or from, or at least some form of contact
+with, a foreign state"); Londos | United States, 240
+F.2d 1, 6 (5th Cir.1957) (concluding that foreign
+commerce under § 10 "means passing to and fro").
+B. SECTION 2423(C)'S REGULATION OF
+COMMERCIAL SEX ACTS IS A VALID EX-
+ERCISE OF CONGRESS'S FOREIGN COM-
+MERCE CLAUSE POWERS
+[S] Taking a page from Raich, we review the
+statute under the traditional rational basis standard.
+Raich, 125 S.Ct. at 2211. The question we pose is
+whether the statute bears a rational relationship to
+Congress's authority under the Foreign Commerce
+Clause.
+Although it is important to view the statute as a
+whole, parsing its elements illustrates why the statte fairly relates to foreign commerce. The ele
+nents that the government must prove under
+Once in Cambodia, the second element of §
+2423(c) was also met, namely, "engage[ment] i
+any illicit sexual conduct with another person,"1
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prft=HTMLE&.. 1/30/2008
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Journal D.A.R. 962
+U.S.C. § 2423(c), which in this case was commercial sex under § 2423(f)(2). As the Supreme Court
+recognized centuries ago, the Commerce Clause
+"comprehend [s] every species of commercial intercourse between the United States and foreign nations." *1115Gibbons, 22 U.S. at 193; see also Bd.
+of Trustees of Univ. of IIl., 289 U.S. at 56-57, 53
+S.Ct. 509 (same). Section 2423(c) regulates a pernicious "species of commercial intercourse": commercial sex acts with minors.
+The statute expressly includes an economic
+component by defining "illicit sexual conduct," in
+Page 15
+sex act, on account of which anything of value is
+given to or received by any person." 18 U.S.C. §
+1591(c)(1). Thus, in the most sterile terms, the statute covers the situation where a U.S. citizen engages in a commercial transaction through which
+money is exchanged for sex acts.
+The essential economic character of the commercial sex acts regulated by § 2423(c) stands in
+contrast to the non-economic activities regulated by
+the statutes at issue in Lopez and Morrison. See
+Morrison,
+U.S. at 613,
+120 S.Ct. 1740
+("Gender-motivated crimes of violence are not, in
+any sense
+of the phrase, economic activity.");
+Lopez, 514 U.S. at 561, 115 S.Ct. 1624 (explaining
+that firearm possession statute was purely a criminal statute). In both Lopez and Morrison, the Su-
+preme Court voiced strong concerns over Congress's use of the Commerce Clause to enact "a
+criminal statute that by its terms has nothing to do
+with "commerce' or any sort of economic enterprise, however broadly one might define those
+terms." Morrison, 529 U.S. at 610, 120 S.Ct. 1740
+(quoting Lopez, 514 U.S. at 561, 115 S.Ct. 1624).
+Like the statute regulating illicit drugs at issue in
+Raich, the activity regulated by the commercial sex
+pro125 s c at 2 , ain essen tals echin to.™
+eign trade and commerce, PNIs
+FN17.
+The
+evolving
+definition
+of
+"economics" presents a slight quirk to the
+analysis. Although the definition in the
+1966 Webster's Third New International
+Dictionary cited by the Supreme Court in
+Raich only refers to "the production, distribution, and consumption of commodities,"
+more recent versions of Webster's have added "services" to the definition. See, e.g..
+Merriam Webster's Collegiate Dictionary
+364 (10th ed.1993) (defining "economics"
+as the social science concerned with "the
+production, distribution, and consumption
+of goods and services"); Merriam-Webster
+Online Dictionary,
+www.m-w.com (same) (last visited Dec.
+29,2005).
+FN18. It is now universally acknowledged
+that foreign trade or commerce includes
+both goods and services. See, eg.. Agreement Establishing the Multilateral Trade
+Organization [World Trade Organization],
+Dec. 15, 1993, 33 I.L.M. 13, pmbl.
+("Recognizing that their relations in the
+field of trade and economic endeavour
+should be conducted with a view to ... expanding the production and trade in goods
+and services"); General Agreement on
+Trade in Services, Dec. 15, 1993, 33
+I.L.M. 44, pmbl. ("Recognizing the growing importance of trade in services for the
+growth and development of the world economy"); cf. Gulf Oil Corp. Copp Paving
+Co., Inc., 419 U.S. 186, 195, 95 S.Ct. 392,
+42 L.Ed.2d 378 (1974)(holding that, under
+the Interstate Commerce Clause, the " *in
+commerce" language of the Clayton and
+Robinson-Patman Act provisions ... appears to denote only persons or activities
+within the flow of interstate commerce-the
+practical, economic continuity in the generation of goods and services for interstate
+markets and their transport and distribution
+to the consumer.") (emphasis added). But
+see Lopez, 514 U.S. at 585-89, 115 S.Ct
+1624 (arguing that "commerce" as understood at the time of the ratification of the
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prf=HTMLE&..
+1/30/2008
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Journal D.A.R. 962
+Constitution encompassed only bartering
+and trafficking in goods) (Thomas, J., concurring).
+As in Raich, the fact that § 2423(c) has a criminal as well as an economic component does not put
+it beyond Congress's reach under the Foreign Commerce Clause. Indeed, § 2423(c) is far from unique
+in using the Foreign Commerce Clause to regulate
+crimes with a conom nond 1, 41 c Claid
+(describing*1116 "particular instrumentalities of
+interstate and foreign commerce that defendants
+used or caused to be used in carrying out the purported bribery" in violation of the Foreign Corrupt
+Practices Act); United States | Hsu, 155 F.3d 189,
+195-96 (3rd Cir. 1998) (discussing statute enacted as
+part of the Economic Espionage Act of 1996 that
+criminalizes the theft of trade secrets related to
+roducts "produced for or placed 1
+oreign commerce; United States" Gertz, 245
+F.2d 662, 666-67 (9th Cir.1957) (explaining that
+statute criminalizing the forging or counterfeiting
+of foreign currency is based on the Foreign Commerce Clause).
+The combination of Clark's travel in foreign
+commerce and his conduct of an illicit commercial
+sex act in Cambodia shortly thereafter puts the statute squarely within Congress's Foreign Commerce
+Clause authority. In reaching this conclusion, we
+view the Foreign Commerce Clause independently
+from its domestic brethren.
+Likewise, although our precedent illustrates
+that the inter-state categories may be adapted for
+use in specific foreign commerce contexts, see, e.g.
+Cummings, 281 F.3d at 1049 n. 1, the categories
+have never been deemed exclusive or mandatory,
+nor has the Supreme Court suggested their application in relation to the Foreign Commerce Clause.
+Cf. Prakash, 55 Ark. L.Rev. at 1166 ("Apparently,
+the Supreme Court has never discussed the applicability of the three-part Lopez test to gauging the
+limits of the foreign commerce power."). The categories are a guide, not a straightjacket. In Cummings, we upheld the constitutionality of the Inter-
+Page 16
+national Parental Kidnaping Crime Act ("IPKCA"),
+18 U.S.C. § 1204(a). See281 F.3d at 1051. In so
+holding, we applied the interstate commerce framework but noted that Congress has "broader power"
+in the foreign commerce area, and this context is
+quite relevant to our inquiry." Id. at 1049 n. 1. Critical to this understanding was the Supreme Court's
+now familiar statement in Japan Line that "the
+Founders intended the scope of the foreign commerce power to be ... greater" as compared with interstate commerce. Id. (quoting Japan Line, 441
+U.S. at 448, 99 S.Ct. 1813).
+At times, forcing foreign commerce cases into
+the domestic commerce rubric is a bit like one of
+the stepsisters trying to don Cinderella's glass slipper; nonetheless, there is a good argument that, as
+found by the district court, § 2423(c) can also be
+viewed as a valid regulation of the "channels of
+commerce." Our previous decisions have recognized that Congress legitimately exercises its authority to regulate the channels of commerce where
+a crime committed on foreign soil is necessarily
+tied to travel in foreign commerce, even where the
+actual use of the channels has ceased. See Cummings, 281 F.3d at 1050-51.
+Clark emphasizes that § 2423(b) requires that
+the foreign travel be with the specific intent to engage in illicit sex, whereas § 2423(c) does not have
+such a specific intent requirement. Although the intent element distinguishes the two statutory crimes,
+we do not see that it distinguishes the scope of Congress's Constitutional authority. Under § 2423(b),
+the crime is contained solely within the "travels in
+foreign commerce" provision of the statute. Under
+the crime charged in this case, § 2423(c) and (f)(2),
+Commerce Clause
+In sum, Clark has failed to demonstrate "a
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prf=HTMLE&.. 1/30/2008
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Journal D.A.R. 962
+*1117 engage in sex acts are indispensable ingredients of the crime to which Clark pled guilty. The
+fact that §$ 2423(c) and (f)(2) meld these economic
+and criminal components into a single statute does
+not put the conduct beyond Congress's reach under
+the Foreign Commerce Clause. The rational nexus
+requirement is met to a constitutionally sufficient
+degree. Congress did not exceed its power "to regulate Commerce with foreign Nations," U.S. Const.
+art. I, § 8, cl. 3, in criminalizing commercial sex
+acts with minors committed by U.S. citizens abroad.
+AFFIRMED.
+FERGUSON, Circuit Judge, dissenting:
+The Constitution cannot be interpreted according to the principle that the end justifies the means.
+The sexual abuse of children abroad is despicable,
+but we should not, and need not, refashion our Constitution to address it.
+The majority holds that
+"travel in foreign commerce, coupled with engagement in a commercial transaction while abroad, implicates foreign commerce to a constitutionally adequate degree." Maj. op. at 1114. I respectfully disagree.
+The Constitution authorizes Congress "[t]o regulate Commerce with foreign Nations." Art. I, § 8,
+cl. 3. The activity regulated by 18 U.S.C. § 2423(c),
+illicit sexual conduct, does not in any sense of the
+phrase relate to commerce with foreign nations.
+Rather, § 2423(c) is a criminal statute that punishes
+private conduct fundamentally divorced from foreign commerce. Article I, section 8, clause 3, while
+giving Congress broad authority over our commercial relations with other nations, is not a grant of international police power. I respectfully dissent from
+the majority's assertion that the Commerce Clause
+authorizes Congress to regulate an activity with a
+bare economic component, as long as that activity
+occurs subsequent to some form of international
+travel. I also note that the conduct in this case will
+not go unpunished, as the reasonable course of action remains of recognizing Cambodia's authority to
+prosecute Clark under its own criminal laws.
+Page 17
+I.
+Our national government is a government of
+"enumerated powers," see U.S. Const. art. I, § 8,
+which presupposes powers that are not enumerated.
+and therefore not accorded to Congress, see Gibbons | Ogden, 22 U.S. (9 Wheat.) 1, 85, 6 L.Ed. 23
+(1824). As such, the Commerce_Clause is "subject
+to outer limits." United States || Lopez, 514 U.S
+549, 556-57, 115 S.Ct. 1624, 131 L.Ed.2d 626
+(1995). Through a long line of cases, the Supreme
+Court has developed a tri-category framework that
+helps courts ascertain these outer limits, and wheth-
+r a particular enactment exceeds them. See, eg
+¡onzales | Raich, 545 U.S. 1, -..., 125 S.Ct. 219:
+2205, 162 L.Ed.2d 1 (2005). In the foreign commerce context, the majority would replace this
+time-tested framework with its own broad standard:
+whether a statute "has a constitutionally tenable
+nexus with foreign commerce." Maj. op. at 1114.
+The majority views the foreign commerce prong of
+the Commerce Clause "independently from its domestic brethren," id. at 1116, though Congress's authority in both spheres is governed by the same
+constitutional language: "[to regulate Commerce,"
+art. I, § 8, cl. 3. In so doing, the majority goes
+farther than our precedent counsels and dispenses
+with the tri-category framework that has grounded
+Commerce Clause analysis in the modern era.FNI
+FN1. Though the majority asserts that it is
+applying
+*the traditional rational
+basis
+standard," maj. op. at 1114 (citing Raich,
+125 S.Ct. at 2211), this statement is misleading to the extent that rationality review
+in the Commerce Clause context is applied
+as part of the "substantial effects"
+test,
+which is a more demanding inquiry than
+the open-ended "nexus" inquiry that the
+majority proposes. Compare Lopez, 514
+U.S. at 561-63, 115 S.Ct. 1624, with maj.
+op. at 1114-17. Courts apply rationality review to assess whether Congress had a
+"rational basis" for concluding that a particular activity "substantially affects" interstate commerce, Raich, 125 S.Ct. at 2208,
+not to inquire generally "whether the stat-
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prf=HTMLE&.. 1/30/2008
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Journal D.A.R. 962
+ute bears a rational relationship to Congress's authority under the [ ] Commerce
+Clause," maj. op. at 1114. Raich is further
+distinguished by the fact that Congress's
+power to effectuate a comprehensive regulatory scheme was central to that opinion,
+ee125 S.Ct. at 2206-07, while no compar
+bly general regulation of foreign com
+merce exists in this case.
+*1118 The majority portrays the raison d'etre
+of the tri-category framework as addressing
+"unique federalism concerns that define congressional authority in the interstate context." Maj. op.
+at 1103 (emphasis added) (citing Lopez, 514 U.S. at
+557, 115 S.Ct. 1624). It is thus able to conclude that
+this framework is generally inapplicable to foreign
+commerce cases. A fairer understanding of the tricategory framework is that it has evolved not only
+in response to federalism concerns that courts have
+read into Congress's Interstate Commerce power,
+but also to give content to what it means generally
+"[to regulate Commerce," art. I, § 8, cl. 3. Cf.
+Lopez, 514 U.S. at 551, 115 S.Ct. 1624 (citing not
+only federalism concerns in invalidating 18 U.S.C.
+§ 922(q), but also the fact that the statute "neither
+regulates a commercial activity nor contains a requirement that the [gun] possession be connected in
+any way to interstate commerce"): United States I!
+Morrison, 529 U.S. 598, 610, 120 S.Ct. 1740, 146
+L.Ed.2d 658 (2000) (noting that "the noneconomic,
+criminal nature of the conduct at issue" was central
+to the Supreme Court's decision in Lopez ). While
+Congress's authority to regulate foreign commerce
+may well be broader than its authority to regulate
+interstate commerce, see, eg., Japan Line, Ltd.
+County of Los Angeles, 441 U.S. 434, 448, 99 S.Ct.
+1813, 60 L.Ed.2d 336 (1979), its authority in the
+foreign sphere is not different in kind. In both
+spheres, Congress is only authorized "[t]o regulate
+Commerce," art. 1, § 8, cl. 3, and not those activities that are fundamentally divorced from commerce. So while the majority correctly notes that
+"[f]ederalism and state sovereignty concerns do not
+restrict Congress's power over foreign commerce,"
+maj. op. at 1113, it fails properly to consider the restrictions on the scope of Congress's Foreign Com-
+Page 18
+ret i pil er than the fite fegory framesit anal
+helps elucidate.
+Il.
+Inder the tri-category framework, and contra
+the District Court's conclusion, § 2423(c) is not
+he Supreme Court has held that Congress
+thority to regulate the channels of commerce e
+compasses keeping those channels "free from immoral and injurious uses." Heart of Atlanta Motel,
+Inc. | United States, 379 U.S. 241, 256, 85 S.Ct.
+348, 13 L.Ed.2d 258 (1964) (internal quotation
+marks omitted). Thus, Congress has the authority to
+criminalize the international transport of children
+for the purpose of sexual exploitation in the U.S.
+because such transport is an immoral and injurious
+se of the channels of commerce. CJ. United States
+• Hersh, 297 F.3d 1233, 1238 (lith Cir.2002)
+(upholding the conviction of a defendant who transported a Honduran boy to Florida to engage in
+*1119 sexual relations). Congress also has the authority to criminalize travel "for the purpose" of engaging in illicit sexual conduct, since travel with
+such harmful intent constitutes an injurious use of
+the channels of foreign commerce. See, eg. United
+Bredimus, 352 F.3d 200, 207-08 (5th
+Cir.2003).FN2 We have not necessarily limited
+Congress's reach under its channels of commerce
+authority based on the cessation of movement.
+wrongfully to remove the children from the U.S.
+281 F.3d 1046
+1050 (9th Cir.2002); see also
+United States | Shahani-Jahromi, 286 F.Supp.2d
+723, 734 (E.D.Va.2003) (holding that wrongful retention of a child in a foreign country, which im-
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prft=HTMLE&… 1/30/2008
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Journal D.A.R. 962
+peded that child's travel back to the U.S. through
+the channels of commerce, provided a sufficient
+basis for Congress to exercise its Foreign Commerce power).
+FN2. The statute upheld in Bredimus was
+the former 18 U.S.C. § 2423(b), which preceded the present statute and which included an intent requirement.
+Under this rubric, the current 18 U.S.C. §
+2423(b) contains a defensible link to the channels
+of foreign commerce, as it covers people who
+"[t]ravel with intent to engage in illicit sexual conduct." See, e.g., Nick Madigan, Man, 86, Convicted
+Under New Law Against Americans Who Go
+Abroad to Molest Minors, N.Y. Times, Nov. 20,
+2004, at A12 (defendant was arrested at Los
+Angeles International Airport with "dozens of pornographic photographs of himself with Filipino
+girls, sex toys and 100 pounds of chocolate and
+candy"). The activity regulated by § 2423(b), intention to engage in illicit sexual conduct, is at least
+tenably related to the channels of commerce in that
+the defendant engages in travel with illegitimate
+ends. The person indicted under § 2423(b) has a
+plane ticket in hand, has paid a travel agent to set
+up the trip, or has otherwise committed an act that
+is both wrongful (because of the criminal intent)
+and tangibly related to the channels of commerce.
+By contrast, § 2423(c) neither punishes the act
+of traveling in foreign commerce,
+or the wrongful
+use or impediment of use of the channels of foreign
+commerce. Rather, it punishes future conduct in a
+foreign country entirely divorced from the act of
+traveling except for the fact that the travel occurs at
+some point prior to the regulated conduct. The statute does not require any wrongful intent at the time
+• sc o mo a ao ue to
+regulated activity.
+The majority suggests that § 2423(c)"can ] b
+riewed as a valid regulation of the 'channels of
+commerce,' " maj. op. at 1116, because Congress's
+Page 19
+channels of commerce authority extends to regulating crimes committed abroad that are "necessarily
+tied to travel in foreign commerce, "id. But whereas
+the requisite ties to the channels of commerce exist
+in the case the majority cites, Cummings, 281 F.3d
+1046, these ties are entirely absent in § 2423(c).
+The
+statute in Cummings prohibited conductwrongful retention of children abroad-that was necessarily tied to injurious uses of the channels of
+commerce. The defendant in Cummings illegally
+transported his children to Germany so that he
+could retain them there, and his wrongful retention
+of them necessarily impeded their lawful use of the
+channels of commerce to return to the U.S. By contrast, § 2423(c) regulates an activity that is in no
+way connected to the wrongful use, or impediment
+of use, of the channels of foreign commerce. Section 2423(c) only *1120 requires that the regulated
+conduct occur at some point subsequent-perhaps
+even years subsequent-to international travel. The
+travel may well be lawful-the statute does not require any criminal intent during travel, nor does it
+otherwise connect the regulated activity to an abuse
+of the channels of commerce.
+The mere act of boarding an international
+flight, without more, is insufficient to bring all of
+Clark's downstream
+activities that involve an exchange of value within the ambit of Congress's Foreign Commerce power. On some level, every act by
+a U.S. citizen abroad takes place subsequent to an
+international flight or some form of "travel[ ] in
+foreign commerce." 18 U.S.C. § 2423(c). This cannot mean that every act with a bare economic component that occurs downstream from that travel is
+subject to regulation by the United States under its
+Foreign Commerce power, or the Commerce Clause
+will have been converted into a general grant of police power. It is telling to note that, theoretically,
+the only U.S. citizens who could fall outside the
+reach of § 2423(c) if they engage in illicit sexual
+conduct abroad are those who never set foot in the
+United States (i.e., U.S. citizens by virtue of their
+parent's citizenship), and thus never travel in
+"Commerce with foreign Nations." Art. I, § 8, cl. 3.
+In short, § 2423(c) is divorced from its asserted
+Commerce Clause underpinnings. The statute does
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prft=HTMLE&...
+1/30/2008
+
+
+
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006 Daily Journal D.A.R. 962
+not set another "guidepost" regarding Congress's
+Foreign Commerce power, contra United States |
+Clark,
+315
+F.Supp.2d
+1127, 1135
+(W.D.Wash.2004)-it exceeds it.
+Page 20
+back into the American economy. Analogously, the
+statute here does not even facially limit its application to sex with foreign minors in an effort to create
+a tenable link to "Commerce with foreign Nations."
+Art. I, § 8, cl. 3. This observation may seem
+slightly absurd, but so is the task of trying to show
+*1121 how sexual abuse of a minor overseas by a
+U.S. citizen constitutes an act of "Commerce with
+foreign Nations." Id.
+Il.
+Rather than engaging in a losing "channels of
+commerce" analysis, the majority applies a general
+"rational nexus" standard in this case, maj. op. at
+1117, and strains to find more foreign commerce in
+§ 2423(c) than the act of boarding an international
+flight. Specifically, the majority characterizes the
+crime regulated by § 2423(c), illicit sexual conduct,
+as sufficiently related to "Commerce with foreign
+Nations,
+" art. I, § 8, cl. 3, to bring it under Congress's Foreign Commerce authority.
+First, the underlying regulated activity is not
+"quintessentially economic,"
+maj. op. at 1115,
+simply because it has a bare economic aspect. Just
+as "[g]ender-motivated crimes of violence are not,
+in any sense of the phrase, economic activity, "Morrison, 529 U.S. at 613, 120 S.Ct. 1740, neither is
+"illicit sexual conduct." The plain purpose of §
+2423(c) is to regulate criminal conduct,
+As the Supreme Court cautioned in
+Lopez, "depending on the level of generality, any
+activity can be looked upon as commercial." 514
+U.S. at 565, 115 S.Ct. 1624.
+Further, the underlying act, even if considered
+economic or commercial, is certainly not a presence
+of commerce with foreign nations. In the most
+sterile terms, an act of paid sex with a minor that
+takes place overseas is not an act of commerce with
+other nations. Under the interpretation of the majority, the purchase of a lunch in France by an American citizen who traveled there by airplane would
+constitute a constitutional act of engaging in foreign commerce. Under such an interpretation, Congress could have the power to regulate the overseas
+activities of U.S. citizens many months or years
+after they had concluded their travel in foreign
+commerce, as long as the activities involved some
+sort of exchange of value-even if the partner in exchange was a U.S. entity that funneled the value
+IV.
+Viewed as a whole, it is clear that § 2423(c)
+of Congress's authority to regulate the channels of
+commerce. Sexual exploitation of children by foreigners is thoroughly condemnable, but the question before us is whether Congress properly invoked its power "[t]o regulate Commerce with foreign Nations, "id., in enacting § 2423(c) to address
+this problem. It did not. I therefore respectfully dissent.
+C.A.9 (Wash.),2006.
+U.S. I. Clark
+435 F.3d 1100, 06 Cal. Daily Op. Serv. 696, 2006
+Daily Journal D.A.R. 962
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rs=WLW8.01&prft=HTMLE&…. 1/30/2008
+
+
+Approved:
+AMolen.
+II
+Assistant United States Attorneys
+Before:
+HONORABLE RONALD L. ELLIS
+United States Magistrate Judge
+Southern District of New York
+- - -X
+08 MAG 0463
+SEALED COMPLAINT
+UNITED STATES OF AMERICA
+:
+V.
+:
+:
+:
+Violations of
+18 U.S.C. 55 371, 1952,
+2421, 2422, 1956
+COUNTY OF OFFENSE:
+NEW YORK.
+:
+MARK BRENER,
+a/k/a "Michael, "
+CECIL SUWAL,
+a/k/a "Katie,"
+a/k/a "Kate,
+TEMEKA RACHELLE LEWIS,
+a/k/a "Rachelle," and
+TANYA HOLLANDER,
+a/k/a "Tania Hollander, "
+Defendants.
+:
+:
+- - -X
+SOUTHERN DISTRICT OF NEW YORK, ss.:
+being duly sworn, deposes and says that
+he is a Special Agent with the Federal Bureau of Investigation,
+and charges as follows:
+COUNT ONE
+1. From in or about December 2004 to in or about
+March 2008, in the Southern District of New York and elsewhere,
+MARK BRENER, a/k/a "Michael," CECIL SUWAL, a/k/a "Katie," a/k/a
+"Kate," TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," and TANYA
+HOLLANDER, a/k/a "Tania Hollander, " the defendants, and others
+known and unknown, unlawfully, willfully, and knowingly did
+combine, conspire, confederate, and agree together and with each
+other to violate Sections 1952 (a) (3), 2421, and 2422(a) of Title
+18, United States Code.
+
+
+It was a part and an object of the conspiracy that
+MARK BRENER, a/k/a "Michael," CECIL SUWAL, a/k/a "Katie," a/k/a
+"Kate," TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," and TANYA
+HOLLANDER, a/k/a "Tania Hollander," the defendants, and others
+Known
+and unknown, would and did use and cause to be used
+facilities in interstate commerce, to wit, cellular telephones
+and e-mail, with intent to promote, manage, establish, and carry
+facilitate the promotion, management, establishment
+and carrying on of an unlawful activity, to wit, a business
+enterprise involving prostitution offenses in violation of
+applicable State law, and thereafter did perform and attempt to
+perform an act to promote, manage, establish, and carry on and to
+facilitate the promotion, management, establishment, and carrying
+on of said unlawful activity.
+in violation of Title 18, United
+States Code, Section 1952 (a) (3) .
+3.
+It was a further part and an object of the
+conspiracy that MARK BRENER, a/k/a "Michael," CECIL SUWAL, a/k/a
+"Katie," a/k/a "Kate, " TEMEKA RACHELLE LEWIS, a/k/a "Rachelle,"
+and TANYA HOLLANDER, a/k/a "Tania Hollander, " the defendants, and
+others known and unknown, unlawfully, willfully and knowingly
+would and did transport individuals in interstate and foreign
+commerce with intent that such individuals engage in
+prostitution, and in sexual activity for which a person can be
+charged with a criminal offense, in violation of Title 18, United
+States Code, Section 2421.
+4.
+It was a further part and an object of the
+conspiracy that MARK BRENER, a/k/a "Michael, " CECIL SUWAL, a/k/a
+"Katie," a/k/a "Kate, " TEMEKA RACHELLE LEWIS, a/k/a "Rachelle,"
+and TANYA HOLLANDER, a/k/a "Tania Hollander, " the defendants, and
+others known and unknown, unlawfully, willfully and knowingly
+travel in interstate and foreign commerce to engage in
+prostitution and in sexual activity for which a person can be
+States Code, Section 2422 (a).
+Overt Acts
+5.
+In furtherance of said conspiracy and to effect
+he illegal objects thereof, the following overt acts, among
+others, were committed in the Southern District of New York and
+elsewhere:
+about March 2008
+a/k/a "Katie," a/k/a "Kate, " the defendants, controlled a website
+2
+
+
+located at URL www.emperorsclubvip.com. that included photographs
+of prostitutes' bodies, with their heads hidden, along with
+hourly rates for different categories of prostitutes;
+b.
+From in or about December 2004 through in or
+about at least January 2008, MARK BRENER, a/k/a "Michael," and
+CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendants,
+received applications from women seeking to work as prostitutes
+with their prostitution business (hereinafter, the "Emperors
+Club") at various e-mail accounts;
+On or about January 9, 2008, MARK BRENER,
+a/k/a "Michael," CECIL SUWAL, a/k/a "Katie, " a/k/a "Kate," and
+TEMKA RACHELLE LEWIS, a/k/a "Rachelle," the defendants, spoke
+over the telephone about offering the Emperors Club's clients the
+opportunity to exercise a "buyout clause," which would permit
+clients to purchase direct access to one of the Emperors Club's
+prostitutes without having to contact the agency;
+d. On or about January 15, 2008, TEMEKA RACHELLE
+LEWIS, a/k/a "Rachelle, " the defendant, spoke with a client of
+the Emperors Club over the telephone about arranging for a
+prostitute to come to his room at a hotel in New York, New York;
+On or about January 15, 2008, a prostitute
+working with the Emperors Club went to a client's hotel in New :
+York, New York;
+On or about January 18, 2008, TEMEKA RACHELLE
+LEWIS, a/k/a "Rachelle,
+a "little bit nervous about it";
+9.
+On or about January 18, 2008, CECIL SUWAL,
+a/k/a "Katie," a/k/a "Kate, " the defendant, sent an e-mail to a
+sotential prostitute asking her to send photographs of herself to
+h. On or about January 22, 2008, TEMEKA RACHELLE
+i. On or about January 24, 2008, a prostitute
+working with the Emperors Club went to a hotel in Los Angeles,
+3
+
+
+California;
+j.
+On or about January 24, 2008, CECIL SUWAL,
+a/k/a "Katie," a/k/a "Kate," the defendant, received an e-mail
+from a potential prostitute declining to work for the Emperors
+Club in part because her friend had to have sex with a client
+"twice in an hour";
+к.
+On or about January 24, 2008, CECIL SUWAL,
+a/k/a "Katie," a/k/a "Kate, " the defendant, sent an e-mail to
+TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, attaching
+a list of the aliases used by more than 50 prostitutes working
+with the Emperors Club in, among other places, New York, New
+York; Los Angeles, California; Miami, Florida; London, England;
+and Paris, France;
+2223
+On or about January 24, 2008, CECIL SUWAL,
+a/k/a "Katie," a/k/a "Kate," the defendant, sent an e-mail to a
+prostitute working with the Emperors Club and asked if she would
+be available on February 11, 2008, in Europe for an extended
+prostitution date with a client to cost $25,000 or more.
+On or about January 26, 2008, TEMEKA RACHELLE
+LEWIS, a/k/a "Rachelle," the defendant, spoke with a client of
+the Emperors Club over the telephone about arranging for a
+prostitute to come to his room at a hotel in Los Angeles,
+California;
+n.
+On or about January 27, 2008, a prostitute
+working with the Emperors Club went to a client's hotel in Los
+Angeles, California;
+0.
+On or about January 27, 2008, TEMKA RACHELLE
+LEWIS, a/k/a "Rachelle," the defendant, spoke with an Emperors
+Club client over the telephone who asked LEWIS whether the QAT
+consulting company could be traced because he had heard of
+agencies like the Emperors Club getting "busted";
+a/k/a "Michael,?
+On or about January 28, 2008, MARK BRENER,
+CECIL SUWAL, a/k/a "Katie, " a/k/a "Kate," and
+TANYA HOLLANDER, a/k/a "Tania Hollander, " the defendants, met in
+the vicinity of Grand Central Terminal in New York, New York;
+On or about January 28, 2008, TEMEKA RACHELLE
+LEWIS, a/k/a "Rachelle," the defendant, spoke with an Emperors
+"lub client over the telephone about arranging for a prostitute
+to travel from New York to Washington, D.C., to his hotel;
+4
+
+
+On or about January 30, 2008, MARK BRENER,
+a/k/a "Michael," CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," and
+ГЕМЕКА RACHELLE LEWIS, a/k/a "Rachelle," the defendants, spoke
+over the telephone regarding problems with one of the Emperors
+Club's prostitutes who they believed might be abusing drugs;
+S.
+On or about January 30, 2008, CECIL SUWAL,
+a/k/a "Katie," a/k/a "Kate, " the defendant, sent TANYA HOLLANDER,
+a/k/a "Tania Hollander," the defendant, a text message over the
+telephone asking HOLLANDER to contact an Emperors Club client to
+arrange an appointment with an Emperors Club prostitute in New
+York on February 1, 2008;
+t.
+On or about January 30, 2008, CECIL SUWAL,
+a/k/a "Katie," a/k/a "Kate," the defendant, sent TANYA HOLLANDER,
+a/k/a "Tania Hollander, " the defendant, a text message over the
+telephone asking HOLLANDER to send two particular prostitutes on
+dates with Emperors Club clients in New York if possible, and
+HOLLANDER agreed;
+On or about January 31, 2008, TANYA HOLLANDER,
+a/k/a "Tania Hollander, " the defendant, sent CECIL SUWAL, a/k/a
+"Katie," a/k/a "Kate, " the defendant, a text message over the
+telephone informing SUWAL that she had scheduled a date for an
+Emperors Club client with an Emperors Club prostitute in Europe:
+On or about February 7, 2008, CECIL SUWAL,
+a/k/a "Katie,"
+a/k/a "Kate," and TEMEKA RACHELLE LEWIS, a/k/a
+"Rachelle," the defendants, spoke over the telephone about the
+fact that an Emperors Club client had complained that one of
+their prostitutes was "more sex than sexy";
+on or about February 11, 2008, CECIL SUWAL,
+a/k/a "Katie," a/k/a "Kate," and TEMEKA RACHELLE LEWIS, a/k/a
+"Rachelle," the defendants, communicated via text message about
+the fact that the three-day rates for two of the Emperors Club
+prostitutes were $50,000 and $35,000, respectively;
+x.
+On or about February 12, 2008, TEMEKA RACHELLE
+LEWIS, a/k/a "Rachelle," the defendant, spoke with an Emperors
+client' over the telephone about arranging for a prostitute
+to travel from New York to Washington, D.C.; and
+On or about February 13, 2008, an Emperors
+Club prostitute traveled from New York, New York, to a hotel in
+Washington, D.C.
+(Title 18, United States Code, Section 371.)
+5
+
+
+COUNT TWO
+6. From in or about December 2004, up through and
+including in or about March 2008, in the Southern District of New
+York and elsewhere, MARK BRENER, a/k/a "Michael," and CECIL
+SUWAL, a/k/a "Katie, " a/k/a "Kate," the defendants, and others
+known and unknown, unlawfully, willfully, and knowingly combined,
+conspired, confederated, and agreed together and with each other
+to commit
+an offense against the United States, to wit, to
+violate Title 18, United States Code, Section 1956.
+7.
+It was a part
+and an object of the conspiracy that
+MARK BRENER, a/k/a "Michael," and CECIL SUWAL, a/k/a "Katie,"
+a/k/a "Kate," the defendants, and others known and unknown, in an
+offense involving and affecting interstate and foreign commerce,
+knowing that the property involved in certain financial
+and unknowminerce
+transactions represented the proceeds of some form of unlawful
+activity, unlawfully, willfully, and knowingly would and did
+conduct such financial transactions, which in fact involved the
+proceeds of specified unlawful activity, to wit, the use of
+facilities in interstate commerce with the intent to promote,
+manage, establish, and carry on, and to facilitate the promotion,
+management, establishment, and carrying on of an unlawful
+no. car a on any 0g.
+merce with hacticate the
+activity, to wit, a business involving prostitution offenses in
+violation of applicable State law, in violation of Title 18,
+United States Code, Section 1952 (a) (3); interstate transportation
+of individuals to engage in prostitution, in violation of Title
+18, United States Code, Section 2421; and persuasion of
+individuals to travel in interstate
+and foreign commerce
+to
+engage in prostitution, in violation of Title 18, United States
+Code, Section 2422 (a), (a) with the intent to promote the
+carrying on of specified unlawful activity, and (b) knowing that
+the transactions were designed in whole and in part to conceal
+and disguise the nature, the location, the source, the ownership,
+and the control of the proceeds of specified unlawful activity,
+in violation of Title 18, United States Code, Sections
+1956 (a) (1) (A) (i) and 1956 (a) (1) (B) (i) .
+Overt Acts
+In furtherance of the conspiracy and to effect the
+illegal objects thereof, the following overt acts, among others,
+were committed in the Southern District of New York and
+elsewhere:
+a.
+In or about December 10, 2004, CECIL SUWAL,
+a/k/a "Katie," a/k/a "Kate,
+in the name of "AT Consulting Group, Ine.», opened a bank account
+
+
+In or about November 30, 2006, CECIL SUWAL,
+a/k/a "Katie," a/k/a "Kate," the defendant, opened a bank account
+in the name of "QAT International, Inc.";
+From in or about December 2004 to in or about
+January 2008, MARK BRENER, a/k/a "Michael," and CECIL SUWAL,
+a/k/a "Katie," a/k/a "Kate, " the defendants, received more than
+$1 million in proceeds from the Emperors Club prostitution
+business in bank accounts in the names of "QAT Consulting Group,
+Inc.," and "QAT International, Inc.";
+d. From in or about December 2004 to in or about
+defendant, wrote more than $100,000 in checks to cash from bank
+accounts in the names of "QAT Consulting Group, Inc.," and "QAT
+International, Inc.";
+From in or about December 2004 to in or about
+January 2008, CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the
+defendant, wrote more than $39,000 in checks to Protech
+Consultants, a company whose bank account MARK BRENER, a/k/a
+"Michael," the defendant, controlled; and
+f. From in or about December 2004 to in or about
+January 2008, CECIL SUWAL, a/k/a "Katie," a/k/a "Kate, " the
+defendant, wrote checks and sent wire transfers totaling more
+than $400,000 from bank accounts in the name of "QAT Consulting
+Group, Inc.," and "QAT International, Inc.," to more than 50
+prostitutes working with the Emperors Club in the United States
+and Europe.
+(Title 18, United States Code, Section 1956 (h) .)
+The bases for my knowledge and for the foregoing
+charges are, in part, set forth in the attached Affidavit of
+Kenneth Hosey in support of the Application for Arrest Warrants,
+Search Warrants, and Seizure Warrants, which is incorporated by
+reference herein.
+7
+
+
+the arrests of the a deponentreye dant sanat bey say for
+imprisoned or bailed, as the case may be.
+Sworn to before me this
+_ day of March, 2008.
+8
+
+
+536
+148 FEDERAL REPORTER, 2d BERIES
+McAllister Lighterage Line, Inc, is confailed so to do. Central Vermont R. Co.
+cerned. Its appeal has been discontinued in
+White, 238 U.S. 507, 35 S.Ct. 865, 59 La
+accordance with a stipulation and it will
+Eat 143% An as 19168, 25e on this
+not be mentioned further.
+record the determination of the trial judge
+has not been shown clearly erroneous and
+should not be disturbed.
+rentzen to remove and dispose of the sand
+ballast on the Emma Bakke and had sublet
+[3] In the absence of proof that Seathe disposal of the ballast to Seaboard board Great Lakes Corporation, the charwhich had chartered the scow to use in so
+terer of the scow, was guilty of negligence
+doing. Maritime did the work of loading
+which caused the damage to the motorship
+the scow with the sand ballast from the
+the cross libel of Lorentzen against it was
+motorship, by dumping it from a tub into
+properly dismissed.
+The Cullen No. 32, 2
+piles on the scow.
+Cir., 62 F.2d 68.
+Lorentzen in the second action sued Ma-
+[4] But it was error to dismiss the liritime and Seaboard and the scow,
+which bel of Lorentzen against Maritime whose
+was claimed by Seaboard, to recover for negligence contributed to cause the damage
+the damage to the motorship. From an in- to the motorship when the scow turned
+terlocutory decree in the first suit in favor over and struck the ship. Maritime should
+of the scow owner and against Lorentzen have been held for half the damage to the
+and Maritime jointly and primarily and ship.
+The Max Morris, 137 U.S. 1, S.
+against Seaboard secondarily for the dam- Ct. 29, 34 L.Ed. 586.
+age to the scow, Lorentzen has appealed
+22222
+From a final decree dismissing
+the libel in the second action on the merits
+but without costs to Maritime, Lorentzen
+There was ample evidence to support the
+findings of the trial court to the following
+effect.
+The scow
+was seaworthy and it
+capsized because of the negligence of Maritime in loading the sand in such piles as it
+did and in failing to come to the scow's
+assistance after the sand loaded in piles
+amidship from fore to aft had split and
+LA PAGE | UNITED STATES.
+caused the scow to list toward the motor-
+No. 12863.
+ship, where she hung on her lines for an
+Creult Court of Appeale, Elghth Cireult.
+hour or so before she turned over. The
+motorship was negligent in allowing wa-
+Jan. 10, 1045.
+ter to run upon the piles of sand from the
+Rehearing Denled Jan. 29, 1045,
+refrigerator and toilet discharge pipes on
+Wooden covers to deflect such l. Statutes -206
+water away from the scow had been put
+over de ends of these pipesay be hip five Area to at oil nonstred ao to
+but had been displaced during the loading
+of the scow or when she was shifted by
+2. Statutes e-207
+Maritime and the ship took no precautions
+other than the putting on of the covers.
+apply brad stat specialty dealt will no
+We accept those findings.
+another part of same act.
+[1,2] The trial judge also found that 3, Prostitutios el
+the scow captain was not negligent in going
+• The statutory offense of causing trans-..
+below to rest a while before the scow be- portation of a woman in interstate comgan to list and in remaining below until she merce for immoral purposes and the ofdid list. While the scow owner was bound fense of inducing a woman to go in interstate commerce on a common carrier for
+to ternal ec thrmy of the scow, bailey arora purposes are separate crimes
+Carroll, 2 Cir., 248 F. 466, the burden wi
+White Slave Traffic Act 35 2, 3, 18 U.S.
+on the appellant and Maritime to show that C.A. §5 398, 399.
+
+
+LA PAGE Y. UNITED STATES
+537
+Cite aa 148 F.M 538
+4 Criminal
+$196
+examination and as to the charge to the
+The test of difference in similar crimes jury and find no merit in either.
+is that there must be a difference in the
+The serious matter is the sufficiency of
+evidence necessary to establish particular the evidence to sustain the crime charged
+crime from that required to establish the
+in the indictment.
+The indictment is in
+other crime.
+one count under Section 2 of the Act, 36
+5. Prostitutlon 6-4
+Stat. 825, U.S.C.A. Title 18, § 398, and in
+the words of that section, charges that ap-
+Proof that woman made trip in interpellant
+"did cause to be transported and
+state commerce on common carrier followaid and assist in obtaining transportation
+ing telephone call by defendant requesting
+in interstate commerce" of Dora Thomas
+woman to return to defendant's house of
+"for the purpose of prostitution, debauchprostitution, though it might have supported conviction of offense of "inducing" woery, and other immoral purposes."
+The evidence established that Dora
+man to go in interstate commerce on & Thomas (who was an inmate of a house
+common carrier for immoral purposes, was
+not sufficient to support conviction of ofof prostitution operated by appellant at
+fense of "causing" woman to be transport-
+Fargo,
+North Dakota) had gone to Mined in interstate commerce for immoral purneapolis, Minnesota, for a vacation; that
+poscs.
+White Slave Traffic Act §§ 2,
+, 3,
+appellant telephoned her, one evening, to
+18 U.S.C.A. §$ 398, 399.
+return as "one of her girls was leaving"
+Bee Worde and Phrases, Permanent
+and she would be expected early next
+Edition, for all other defisitions
+of
+morning; that it was understood by both
+"Causing" and "Inducing".
+women that Dora Thomas would return to
+Fargo next day by train; and that she did
+SANBORN, Circuit Judge, dissenting.
+so return.
+Baldly, the
+evidence is that
+Dora Thomas made this interstate journey
+at her own expense because of appellant's
+Appeal from the District Court of the
+telephone request and that both women un-
+United States for the District of Minnederstood the immoral purpose for which
+sota; Gunnar H. Nordbye, Judge.
+the trip was to be taken.
+Since there was
+no evidence that appellant gave any aid
+Lucille La Page, alias Lulu Page, was
+or assistance in obtaining the transportaconvicted of violating White Slave Traffic
+tion, the sufficiency of the proof depends
+Act, 18 U.S.C.A. § 397 et seq., and she apupon whether it shows that appellant did
+peals.
+cause [Dora Thomas] to be transported"
+Reversed and remanded with directions.
+(italics added) within the meaning of sec-
+A. M. Cary, of Minneapolis,
+Minn.
+tion 2 of the Act.
+(Mark McCabe, of Minneapolis, Minn., on
+Appellant contends that where, as here,
+the only act of accused is that of persuadthe brief for appeliant.
+John
+. Graff, Asst. U. S. Atty., of St.
+ing or inducing an interstate trip by com-
+Paul, M
+In. (Victor E. Anderson,
+U. S.
+mon carrier for immoral purposes, such act
+Atty., of St. Paul, Minn., on the brief), for
+is not cousing such trip within the meaning
+of section 2 but is, if any crime, the one
+appellee.
+stated in section 3 of the 'Act, U.S.C.A.
+Before
+STONE,
+SANBORN, and
+Title 18, § 399.
+THOMAS, Circuit Judges.
+The pertinent language in the two sections is: Section 2.
+"Any person who shall
+STONE, Circuit Judge.
+knowingly
+* * cause to be transport-
+This is an appeal from a conviction for ed * • * in interstate * * * com
+violation of the White Slave Traffic Act, merce
+* * * any woman or girl for
+18 U.S.C.A. § 397 et seg.
+the purpose of prostitution": and section
+Appellant urges here three claimed er- 3, "Any person who shall knowingly per
+rors: (1) Improper restriction of cross- suade, induce
+••
+examination of a witness; (2) error in to go from one placete another in forter.
+the charge to the jury, and (3) insufficien- state
+set forth in the indictment.
+We have ex- speaking,
+amined the points as to restriction of crossimport" (United States Ken
+146 F.2d—34
+
+
+538
+146 FEDERAL REPORTER, 26 SERIES
+U.S. 440, 443, 37 S.Ct. 438, 439, 61 LEd. der section 2, and "persuading, inducing"
+836) and since to
+"persuade"
+or to "in- etc, to be transported under section 3 (see
+luce"* might very
+well come within a the Kavalin and Roark cases in note 5).
+broad definition of "cause", the contention
+The only way to make that distinction efis really that "cause" as used in section 2
+fective and to preserve any effect to this
+is limited by exclusion of the means of
+part of section 3 is to eliminate as causes
+bringing about specifically set forth in secfor transportation under section 2 the
+tion 3.
+kinds of causation covered in section 3 by
+[1-3] In construing these provisions of
+the expressions "persuade, induce, entice,
+or coerce."
+the two sections, we start with the rules
+that a statute should be construed so as to
+Appellee relies on decisions by this Court
+a broad statutory provision will not apply Cir., 94 F.2d 926; Gillenwaters Biddle,
+give effect to all of its language " and that as follows: Schrader
+to a matter specifically dealt with in an-
+8 Cir., 18 F.2d 206; Carey | Unitr! States,
+other part of the same Act.* Also, it has 8 Cir., 265 F. 515, and Huffman
+United
+been determined that the two sections cov- States, 8 Cir., 259 F. 35. The Schrader
+er separate crimes." One distinction be- case conviction was sustained solely by an
+tween the two sections has, under some application of the "aiding and abetting"
+facts, been based upon the necessity of use statute (Title 18 U.S.C.A. § 550).
+We
+of a common carrier. in section 3, § 399, need not determine whether that decision
+U.S.C.A., Title 18, while no such necessity should be followed since the fact situation
+§ 398, U.S.C.A, Title
+here does not admit of application of sec-
+18 (Coltabellotta
+exists in section United States, 2 Cir. tion 550 for the reason that appellant here
+United States, 8
+was the only person involved in this un-
+Cir., 22 F.2d 393, 395) but the sections are lawful transportation. However, it is not
+distinct also irrespective of the common amiss to state that the effect of section
+carrier feature and this distinction is be-
+399 upon application of section 550 or upon
+tween "causing to be transported", etc, un- section 398 was not brought to our atten-
+1 Webster'a. New
+International Dierecommend, counsel, or advise
+(sometonary, 2nd ed., defnes the verb "cause"
+thing to be done or proposed for belief)."
+as being "to be the cause or occasion
+Compare legal definitions in 21 Words
+of; to effect as an agent;
+to bring
+and Phrases, Permanent Edition, p. 220 -
+about; to bring into existence; to
+and pocket part and 32 Words and Phras
+make."
+м, Permanent Edition, D. 463 and pocket
+Compare judicially determined meanpart.
+inge in various legal aituations as shown
+3 In Ex parte Publie National Bank of
+In 6 Words and Phrases, Permanent Ell.
+New York, 2T8 U.8. 101, 104, 49 8.Ct
+tion
+р. 341 et вед.
+43, 44, 73 L.,Ed. 202, La stated:
+"No
+= jebeter'a New International Dierule of utatutory construction has been
+tionary, 2nd ed.,
+defines the verbe 'inmoro definitely atated or more often reduce"
+and "persuade" sa follows: inpeated than the cardinal rule that sigduce la "to lead on; to
+Influence: to
+nificasce and effect shall, if posaible,
+prevail on; to move by persuasion or inbe accurded to every word.
+As early sa
+fluence"; Dersuade la "1. to induce
+in Bacou's Abridgment, | 2, it was said
+(one) br argument, entreaty, or exthat "a statute ought, upon the whole,
+postulation into a determination, decito be so construed that, if it can be
+sion, conclusion, belief, or the like; to
+prevented, so clause, sentence, or word
+shall be superfluóus, void, or insignifiwin
+over by an appeal to one's reasoa
+and feelings, as into doing or believing
+cant"• Washington Market Co. v. Hotsomething: to bring (oneself or
+aE-
+02 5, 32 12 80 1 2
+U.S. 204, 208, 52 8.Ct
+76 LEd
+704; Peck y. Jenzess, 7 Ilow. 612, 622,
+that a doctrine la erroneous, into paying
+12 L.Ed. 841.
+in debta, or by many argumenta; t
+United States. Saledonia, 2 Oir
+ersuade oneself that all la well; 2. t
+3 F.21 302, 303, 30%; Savalin v. White
+• persuasion upon; to plead wit
+10 Cir., 44 F.24 40, 51; Roark v. United
+ze: 8. • • • to bring about,
+States, 8 Cir., 17 F.2d 570, 573, 51 4
+argument and persuasion, the doing.
+L.R. 870; and see United States v. Barpracticing, or believing of; to commend,
+ton, 2 Cir., 134 F.2d 484.
+
+
+I PAGE | UNITED STATES
+Cite sa 144 F.Rd 536
+539
+tion or considered in the Schrader case.* of section 2 for causing unlawful transpor-
+The Carey case was a general sentence of tation.
+The test of difference in similar
+three months on four counts of indictment
+crimes is that there must be a difference
+-two counts were for furnishing transporin the evidence necessary to establish the
+tation
+on
+two trips and the
+other two
+particular crime from that required to
+counts for "persuading" the victim to make
+tablish the other crime.
+these trips. While the judgment was af-
+Grmed, there was no consideration of the
+point involved here.
+The Huffman case
+was conviction on count one and acquittal
+essential evidence is necessary to establish
+by verdict on counts two, three and four
+a crime under section 37 and there is no
+of an indictment. Count one was for causfurther evidence. In short, if this evidence
+ing a woman to be transported on a trip
+establishes also a crime under section 2,
+under section 2; the second count was
+it must follow that any evidence sufficient
+identical covering a different trip; count
+to prove a crime under section 3 is likethree was for persuading, inducing and enwise sufficient to prove a crime under secticing (under section 3) the same woman
+tion 2. Since section 3 is of similar and
+on the first trip: and count four was idenof narrower application than section 2, the
+tical covering the other trip.
+A point preinevitable result is that all meaning of secsented and determined was whether the action 3 is included in section 2 and section
+quittal on counts two, three and four was
+3 states no crime not included in section 2
+inconsistent with the conviction on count
+This is to strike out section 3 and give it
+one.
+The judgment was
+affirmed.
+The no effect whatever. We think it is not our
+ground for affirmance is not as distinctly
+province thus to nullify a portion of an
+stated as might be (set pages 40-42 of 259
+Act, by statutory construction, when it is
+F.) but may fairly be said to be that the possible to reconcile the two sections givseveral counts pleaded the same transacing each a separate meaning and effect and
+tion in different manner or means of its
+thereby preserve both sections of the Act.
+commission so as "to avoid at the trial an
+In view of our foregoing determination,
+acquittal by reason of any unforeseen lack it is not necessary to examine the further
+of harmony between the allegations and
+contention of appellant that the judgment
+the proofs" (page 40 of 259 F.).
+Also, r
+eversed under authority 01
+liance is placed, by appellee, on Johnson
+Mortensen Venited States, 322 U.S. 369
+United States, 7 Cir.,
+215 F. 679, L.R.
+64 S.Ct. 1037.
+1915A, 862, but this case is not pertinent.
+The judgment is reversed and the case
+[4,5] The only one of the above cases
+remanded with directions to enter judgwhich bears upon the point before us is
+ment of acquittal.
+the Huffman case.
+If that case is to be
+understood as holding that to "induce,"
+SANBORN, Circuit Judge (dissenting).
+etc, transportation under section 3 is with-
+Since the evidence shows that the apin to "cause" to be transported under secpellant knowingly brought about the return
+tion 2, then the authority of that case is
+of Dora Thomas from Minneapolis, Minnematerially weakened, if
+t destroyed, by sota, to Fargo, North Dakota, for the purour later case of Roark United States, pose of prostitution, and therefore caused
+17 F.2d 570,
+We think the Huffman case should no
+573, 51 A.L.R, 870, her to be transported in interstate commerce, I think the conviction of the appellonger be followed to
+the effect that to
+lant under section 2 of the White Slave
+"induce," etc., under section 3 is to "cause" Traffic Act should be sustained. The Su-
+under section 2.
+Where the accused does preme Court has held that under that secno more to
+"cause", i, e, to bring about,
+tion
+the transportation than is shown here, the whether with or without her consent, or
+crime is a violation of section 3 for per- causing or aiding it, or furthering it in any
+Compare Gebardi United States
+287 U.8, 112, 123, 531
+LOt. 35, 77 LLEd
+206, 84 A.L. R. 370.
+1 For cases with somewhat similar fact
+tuations where court beld
+section
+o see Blackstock TUalte
+tates, 8 Cir., 261 F. 150, certiorari de
+aled 254 U.S. 634, 41 8.Ct. 8, 65 L. Ed
+49; Gillette v. United Stat
+8 Cir.,
+36 r. 215; United States Bartor
+2 Cir., 134 F.2d 484; Simpaos
+Btates, 9 Cir., 245 F. 278, 280.
+
+
+540
+146 FEDERAL REPORTER, 2d SERIES
+ished, when done with a purpose which is
+could be guilty of causing a woman to be
+transported in violation of section 2 and
+also of inducing her to be transported in
+violation of section 3. We said (page 573
+of 17 F.2d): "It would not require the
+Act should be given its full meaning, since
+same
+evidence to prove that a person
+that construction supports the policy ar
+knowingly transported or caused to be
+purposes of the enactment.
+Donnelley
+transported a woman in interstate commerce,
+and to prove that he induced the
+voman to go in such commerce.
+The acts
+nay be separate and distinet." We there
+The verb "cause" as used in section 2 is
+fore held that, for purposes of sentence,
+entitled to the meaning ascribed to it by
+the four counts of the indictment charged
+the trial court. This is indicated by the
+decisions of this Court in Huffman | Unittwo offenses, one under section 2, and the
+other under section 3. The opinion in the
+Roark case carries no implication that if
+and United ares 13 365, 36D 6 a person causes the unlawful transportation of a woman by persuasion or the offering of inducements, he may not be convicted under section 2 of the Act.
+Sour in Unite rulin 1ot chor Sey, 239
+may be convicted under either or both sections. Compare Reed v. United States, su-
+U.S. 440, 443, 37 S.Ct.
+38, 61 L.Ed. 836. pra, page 787 of 96 F.2d.
+The fact that the evidence shows that
+Sections 2 and 3 of the Act are obviouswhat was done by the appellant was also ly much alike and are aimed at the same
+an offense under section
+3 of the Act,
+evil. A violation of one section is frewhich section is "directed toward the perquently and perhaps usually a violation of
+suasion, inducement, enticement, or cocrcion
+the other. To my mind, that is an added
+of the probibited transportation,
+reason why neither section should be given
+Gebardi
+United States, supra, page 119 a restricted meaning or weakened in any
+of 287 U.S., page 36 of 53 S.Ct., 77 L.Ed.
+way by construction. I think that the evi-
+206, 84 A.L.R.
+370, I regard as having no
+dence in this case shows that the appellant
+substantial bearing on the question of apviolated both sections 2 and 3 of the Act.
+pellant's guilt under section 2 of the Act.
+I have no doubt that her conviction under
+section 2 was proper.
+think there is no conflict between Huff
+nan . Ynited States, supra, 259 F. 35, an‹
+case of Mortensen v. United States,
+Roark
+United States, 8 Cir., 17 F.2d
+322 1 5. 369, 64 S.C. 1037, has no apres.
+Roark entered a plea
+cation to this case. In the Mortensen case
+of guilty to an indictment containing four
+the Supreme Court held that there was no
+counts.
+Two of the counts charged him
+evidence that the transportation was for
+with violating section 2 of the Act, and the
+any immoral purpose (page 374 of 322 U.
+other two counts charged him with violat-
+S., page 1040 of 64 S.Ct.). In the instant
+ing section 3. Roark contended that, since
+case the evidence shows that the transporthe indictment showed that all of the
+tation of Dora Thomas from Minneapolis
+counts were based upon one transportation
+to Fargo was for an immoral purpose.
+of one woman, the indiçtment charged but
+I would affirm the judgment appealed
+one offense.
+We thought that a person
+from.
+
+
+UNITED STATES v. PELTON
+701
+Cite as 578 F.2d 701 (1878)
+ages. Generally, the intentional doing of (Second) of Torts § 594, Comment g (1976);
+a wrongful act with full knowledge of its 50 Am.Jur.2d § 198, at 708. Moreover, the
+character, and without cause or excuse, is fact that Coleman waited until Mid-America's agent had departed the meeting at
+which the bids were awarded before im-
+Id. 468 P.2d at 131. See Ford Guarantee pugning Mid-America's ability to perform
+244, 553 the contract is persuasive evidence that
+Abst zst, 25869 (19 C); Watkins Layton, publication was not made in good faith or ir
+182 Kan. 702, 324 P.2d 130, 135 (1958). It is a proper manner. The district court did not
+apparent from the above-quoted language err in ruling against qualified privilege.
+that "punitive damage malice" under Kan-
+Because the district court's instructions
+sas law contemplates the same reckless or
+andal for in Anne mat
+were not plainly erroneous, and no other
+error appearing, we affirm.
+Affirmed.
+court erred in finding that its agent Coleman's statements were not qualifiedly privileged. Whether the defense is available is
+ordinarily a question of law for the court.
+Munsell, supra, 494 P.2d at 1073.
+The essential elements of a conditionally
+privileged communication
+be enumerated as good faith, an interest
+to be upheld, a statement limited in its
+scope to this purpose, a proper occasion,
+and publication in a proper manner and
+to proper parties only.
+UNITED STATES of America, Appellee,
+V.
+Lloyd M. PELTON, Appellant.
+UNITED STATES of America, Appellee,
+Senogles | Security Benefit Life Insurance
+Со., 217 Kan. 438, 536 P.2d 1358, 1363
+(1975). See Bradford, supra 548 P.2d at
+Jacqueline RICH, Appellant.
+1229.
+Nos. 77-1682, 77-1695.
+[20, 21] Preliminarily, even if we disa-
+United States Court of Appeals,
+greed with the district court,
+the error
+Eighth Cireuit.
+would be harmless, for in awarding punitive
+damages the jury found that ARA acted
+Submitted Jan. 9, 1978.
+Decided June 7, 1978.
+gith ted prigit. See Schulzevsupra 45 Rehearing and Rehearing En Banc Denied
+qualified privilege.
+P.2d at 399. In any event, ARA cannot
+in No. 77-1695 July 8 and in No.
+claim qualified privilege here. The only
+77-1682 July 24, 1978.
+reasonable inference from the evidence in
+the case was that Coleman's statements
+were made in an effort to further the busi-
+Defendants were convicted in the Unitness interests of ARA by securing advaned States District Court for the Eastern
+tage over a competitor through injury to
+District of Missouri, H. Kenneth Wangelin,
+the competitor's reputation. ARA's pecuni- J., of violating the Mann Act, and they
+ary interest in this context is not an interest entitled to the protection of qualified Chief Judge, held that: (1) evidence was
+
+
+702
+Government made no direct or derivative 4. Criminal Law *=627.5(2), 1166(1)
+use of tapes, trial court did not abuse its
+Discovery matters are committed to
+discretion in denying access to tapes; (3)
+sound discretion of district court and an
+evidence did not support assertion that
+error in administering discovery rules is
+Government denied acceas to prospective
+reversible only on a showing that error was
+witnesses; (4) fact that attorney for grand
+prejudicial
+to defendant's substantive
+jury witness had said he was going to adrights. Fed.Rules Crim.Proc. rule 16, 18
+vise witness not to testify was insufficient U.S.C.A.
+to establish unavailability of witness so as
+5. Criminal Law •=627.8(4)
+to authorize admission of witness' grand
+jury testimony; (5) motion for severance
+Ex parte proceeding was appropriate
+where Government's denial of defendant's
+made prior to trial but not reviewed at close
+of Government's evidence or at conclusion
+request for tape recordings in Government's
+of all evidence was waived, and (6) status of
+prostitution under Nevada law where woman was sent to engage in prostitution had
+no bearing on illegality of agreement to
+transport woman in interstate commerce
+for purposes of prostitution.
+1. Criminal Law •586, 1151
+Motion for continuance is addressed to
+sound discretion of trial court and refusal to
+grant continuance will be set aside only
+upon showing of clear abuse of discretion.
+2. Criminal Law $=594(1)
+Where defense counsel supported motion for continuance only with speculation
+for safety of persona cooperating on case
+whose identity would be revealed to defendant if she heard tape.
+Fed.Rules Crim.
+Proc rule 16(dX1), 18 U.S.C.A.
+6. Criminal Law + 627.8(3)
+Government which denied defendant's
+request for disclosure of tape recordings of
+her voice in Government's possession on
+ground of concern for safety of persons
+cooperating on case whose identity would
+be revealed to defendant if she heard tapes
+and which made ex parte presentation to
+court resulting in court's determination
+that tapes contained nothing exeulpatory
+made sufficient showing for protective order. Fed.Rules Crim.Proc. rule 16(dX1), 18
+that there might be out-of-state witnesses
+whom he had been unable to interview prior
+7. Criminal Law $-627.5(2)
+to trial because of personal time strictures,
+District court acted within its discre-
+Government's opposition was based on fear
+tion in denying defendant access to tape
+that delay could lead to unavailability of
+recordings of her voice in Government's
+important government witnesses who were
+possession where tapes contained no exculthen in protective custody and 20-day peri- patory evidence and Government made no
+od from time of defendant's arrest to trial
+direct or derivative use of tapes. Fed.Rules
+was adequate time for trial preparation, Crim.Proc. rule 16(a)(1XA), 18 U.S.C.A.
+trial court did not abuse its discretion in 8. Criminal Law •627.6(1)
+refusing to grant continuance. 18 U.S.C.A.
+Discovery of prospective witnesses is
+§ 3161 et seq.
+not required under rule authorizing dis-
+3. Criminal Law $-621.7(2)
+covery in criminal case. Fed.Rules Crim.
+Proc. rule 16(a), 18 U.S.C.A.
+Ordinarily, when defendant requests
+inspection of his or her statements which 9. Criminal Law 8-627.6(1)
+are in the possession, custody or control of
+Trial court did not abuse its discretion
+Government, Government has duty of dis- in refusing to order pretrial discovery of
+Fed.Rules Crim.Proc. rule
+Government's witnesses. Fed.Rules Crim.
+16(aX1XA), 18 U.S.C.A.
+Proc. rule 16(a), 18 U.S.C.A.
+
+
+UNITED STATES | PELTON
+703
+Cite as 578 F.2d 701 (1978)
+10. Criminal Law •=700
+grand jury testimony. Federal Rules of
+Where defendant made no allegation Evidence, rules 804, 804(a)(1), 28 U.S.C.A.;
+whatsoever of contact between her employ- U.S.C.A.Const. Amend. 5.
+ee and Government prior to trial and where 17. Criminal Law 8-1144.13(3)
+Government denied having interviewed em-
+In considering contention that evidence
+ployee or even having known where she
+could be found and did not call employee as
+was insufficient to support conviction, rewitness, there was no support for defendviewing court must view evidence in light
+most favorable to Government.
+ant's assertion of governmental concealment of employee-witness.
+18. Prostitution •=4
+11. Criminal Law *=700
+Evidence of female defendant's partici-
+Government's indictment of witnesses
+pation in plan for transportation of women
+did not establish Government's concealment
+to Chicago and Nevada for prostitution purof prospective witnesses as defendant conposes was sufficient to sustain her convictended.
+tion of violating Mann Act. 18 U.S.C.A.
+95 2421 et seq., 2422.
+12. Criminal Law *-666
+Where witness was placed in protective
+19. Constitutional Law $-42.3(1)
+custody of Government due to incidents
+Male defendant lacked standing to atsuggesting that her safety was in jeopardy.
+tack Mann Act on basis that it violated and
+witness made personal choice not to speak
+derogated right of females to seek legal
+with defendant prior to trial, witness was
+employment. 18 U.S.C.A. §§ 2421, 2422
+present on trial date and made available to
+20. Criminal Law 897(1)
+defendant and defendant interviewed wit-
+Where defendant filed pretrial motion
+ness and decided not to call her, there was
+for severance but did not renew motion at
+no concealment of witness by Government
+close of Government's evidence or at concluas defendant contended.
+sion of all evidence, motion was waived.
+13. Criminal Law •=627.6(1)
+21. Criminal Law $1144.13(3, 5)
+Grand jury testimony is generally not
+In analyzing contention that evidence
+discoverable on pretrial motion.
+18 U.S.
+was insufficient to sustain conviction, court
+C.A. § 3500.
+would view evidence in light most favorable
+14. Criminal Law *=627.6(1)
+to Government and accept as established all
+reasonable inferences from evidence tend-
+If Government had called witness and
+ing to support jury's verdict.
+she had testified, defendant would
+been entitled to transcript of her grand
+22. Criminal Law 552(3), 561(1)
+jury testimony. 18 U.S.C.A. § 8500.
+It is not necessary that evidence exclude every reasonable hypothesis except
+15. Criminal Law $ 419(5)
+that of guilt but simply that it be sufficient
+Unavailability requirement of rule auto convince jury beyond reasonable doubt
+thorizing admission of hearsay statements
+of unavailable declarant places burden of
+that defendant is guilty; such standard also
+applies in cases where conviction rests on
+producing unavailable declarant upon procircumstantial evidence.
+ponent of evidence. Federal Rules of Evidence, rules 804, 804(aX1), 28 U.S.C.A.
+23. Criminal Law 552(4)
+Circumstantial evidence is intrinsically
+16. Criminal Law *542
+as probative as direct evidence for purposes
+That grand jury witness' attorney had
+of sustaining a conviction.
+said he was going to advise witness not to
+testify at defendant's trial was insufficient 24. Conspiracy 4=23
+to establish unavailability of witness so as
+Offense of conspiracy consists of an
+to authorize admission of transcript of her agreement between conspirators to commit
+
+
+704
+an offense attended by an act of one or 31. Prostitution •=1
+more of conspirators to effect object of
+It is the inducement of transportation
+conspiracy.
+which is prohibited under section of Mann
+Act prohibiting inducement of a woman to
+25. Conspiracy 24, 47(2)
+be transported in interstate commerce for
+Agreement between conspirators to
+purposes of prostitution and not actual procommit an offense need not be express or
+vision of that transportation. 18 U.S.C.A.
+formal and may be established by circum-
+§ 2422.
+stantial evidence.
+32. Prostitution •=1
+When an offer to travel interstate for
+Evidence regarding agreement be purposes of prostitution elicits a positive
+tween defendant and another person to response from woman to whom it is made,
+send women to Nevada to work as prostioffer constitutes requisite inducement untutes and to divide prostitutes' income was
+der Mann Act. 18 U.S.C.A. § 2422.
+sufficient to sustain defendant's conviction
+33. Prostitution •4
+of conspiracy to knowingly transport wom-
+Evidence that defendant made induceen in interstate commerce for purpose of
+ment sufficient to persuade woman to travprostitution in violation of Mann Act. 18
+el to Nevada to engage in prostitution was
+U.S.C.A. § 2421.
+sufficient to sustain defendant's conviction
+of violating Mann Act by persuading, indue-
+21. Prostitution *1
+ing and enticing woman to go in interstate
+Prohibition of Mann Act is not keyed to
+commerce for purposes of prostitution, notlegality or illegality of prostitution under
+withstanding assertion that women was
+law of state where transportation ends. 18
+willing to go to Nevada to work as prosti-
+U.S.C.A. § 2421 et seg.
+tute. 18 U.S.C.A. § 2422.
+28. Prostitution •=1
+Status of prostitution under Nevada
+law had no bearing on illegality of agreement to send women to Nevada to work as
+prostitutes under the Mann Act. 18 U.S.
+C.A. § 2421.
+29. Conspiracy =38
+Prostitution •2
+Claude Hanks, Clayton, Mo., Hanks Tay
+lor & Suddarth, Clayton, Mo., filed brief,
+for appellant, Pelton.
+Irl B. Baris, St. Louis, Mo., for appellant,
+Rich.
+David M. Rosen, Aast. U. S. Atty., argued, Robert D. Kingsland, U. S. Atty., St.
+Louis, Mo., on brief, for appellee.
+Consent is not a defense to charge of
+violating Mann Act or charge of conspiring
+to violate Mann Act. 18 U.S.C.A. §§ 2421, and WEBSTER,' Cireuit Judges.
+2422.
+GIBSON, Chief Judge.
+30. Prostitution •1
+This case involves charged violations of
+Woman's predisposition and willingness
+the Mann Act arising out of certain interto go to Nevada to work as prostitute did
+state activities undertaken by a prostitution
+not vitiate illegality of agreement to transoperation based in St. Louis, Missouri. In
+port her for purposes of prostitution in vio-
+July 1977, the Government returned an
+lation of Mann Act. 18 U.S.C.A. §5 2421,
+eight-count indietment against Jacqueline
+2422.
+"Pat" Rich, Lloyd Pelton and Ann Frazier.!
+of the Federal Bureau of Investigation, Judge
+Webster heard oral argument in this case, participated in the conference thereon, and concurred in the result.
+violation of 18 U.S.C. § 2421. The overt acts
+offered in support of this conspiracy charge
+
+
+UNITED STATES | PELTON
+705
+Cite as 578 F.2d 70Г (1978)
+The first four counts of the indictment re- Bray's stay there. It was agreed that he
+lated to travel by prostitutes between St.
+would receive $200 per girl for his place-
+Louis, Missouri, and Chicago, Illinois; the
+ment services. Rich gave Bray $200 to buy
+second four counts related to travel beclothes and $250 to buy an airplane ticket to
+tween St. Louis, Missouri, and Winnemucca,
+Nevada and to pay for a doctor's examina-
+Nevada.
+tion and the accessories that she would need
+In late September 1976, Fred Coughlin,
+at Penny's Cozy Corner. Rich was to rethen a sales representative for a boat comceive a percentage of the money which
+pany in the St. Louis area, asked Rich to
+Bray earned in Nevada. Bray flew to Ne-
+provide prostitutes for a forthcoming boat
+vada and attempted to become licensed as a
+show in Chicago. Rich agreed to let Coughprostitute.
+Her application for a license
+lin take two call girls whom she employed
+was denied because she was under the age
+to Chicago to "work" the boat show.
+of eighteen, and she returned to St. Louis.
+then directed Kathleen Bray and Charlotte
+Following Bray's return, Pelton and Rich
+Anderson to drive to Chicago with Coughmade plans and arrangements, similar to
+lin.
+She also arranged for the separate
+those which they had made for her Nevada
+transportation to Chicago of Kathleen Wagtrip, for sending Shirley Dawson and Chargoner, another call girl in her employ. All
+lotte Anderson to Winnemucca. Pursuant
+three women travelled to Chicago as arto these arrangements, Dawson and Anderranged by Rich and worked as prostitutes
+son travelled to Winnemucea in October
+at a boat show; while in Chicago they were
+1976, and began to work at Penny's Cozy
+managed pursuant to arrangements made
+Corner. They quiekly discovered that emby Rich. Bray became ill and returned to
+St. Louis earlier than the others,
+ployment in Nevada was not as lucrative as
+turned at the conclusion of the boat show.
+they had imagined it would be and they
+returned to St. Louis after only a short
+Upon Bray's return to St. Louis, plans
+tenure in Winnemucca.
+were made fo
+*ling her and another call
+girl known a
+to work at Penny's
+Cozy Corner,
+i prostitution in Winnemucca, Nevada.
+According to Bray, she
+was present at Rich's apartment when Rich
+and Pelton made arrangements for this
+trip. Pelton called an acquaintance of his
+at Penny's Cozy Corner and arranged for
+Rich and Pelton were tried jointly to a
+jury on the charges arising from the aforesaid events. Rich, who was charged in all
+eight counts, was found guilty on Counts
+I-VII and acquitted on Count VIII (Nevada
+trip of Anderson). She received an aggregate sentence of ten years' imprisonment.*
+were alleged to have occurred on September 29
+and 30, 1976, in connection with the transportation of three call girls to Chicago to "work" a
+boat show. Three of the overt acts alleged in
+Count I formed the basis of the substantive
+violations of 18 U.S.C. § 2421 with which Rich
+alone was charged in Counts II, III and IV.
+Count Il charged Rich with a § 2421 violation
+with regard to Kathleen Waggoner, a/k/a "Mo-
+nica"; Count III charged her with a similar
+violation with regard to Kathleen Bray, a/k/a
+"Baby"; and Count IV related to the interstate
+transportation of Charlotte Anderson, a/k/a
+"Frosty," in violation of 4 2421.
+Countcharged Rich and Pelton with conoffered in support of this conspiracy charge
+related to the transportation of three women,
+Shirley Dawson, Kathleen Bray and Charlotte
+Winnemucca, Nevada, for purposes of prostitution. Count charged Rich
+and Pelton with violating 18 U.S.C. § 2422 by
+persuading, inducing and enticing Shirley Dawson to go to Winnemucca to act as a prostitute
+and by causing her to be transported there as a
+passenger upon the line and route of a common
+carrier in interstate commerce. Counts VIl and
+VIll charged Rich and Pelton with similar violations with regard to Kathleen Bray and Charlotte Anderson, respectively.
+3. Frazier indicated a willingness to dispose of
+her case in Chicago under the provisions of
+Fed.R.Crim.P. 20; she was not tried with Rich
+and Pelton.
+4. Rich was sentenced to a five-year term of
+imprisonment on each of her seven convictions.
+
+
+706
+elton, who was charged only in
+Vill, was found guilty on Counts (con
+spiracy involving trips to Nevada) and VIl
+(Nevada trip of Bray) and acquitted on
+Counts VI and VIII (Nevada trips of Dawson and Anderson respectively).
+He received two concurrent sentences of three
+years' imprisonment.
+Both defendants appeal. We first consider appellant Rich's contentions.
+Continuance
+Rich was arrested on July 11, 1977, and
+arraigned on July 18. At her arraignment,
+the District Court" set an August 1 trial
+date, despite protestations by Rich's counsel
+that this date would be inconvenient to him.
+On July 27, Pelton, who had also been given
+an August 1 trial date when he was arraigned
+on July 11, filed a motion for a
+continuance and the Government filed a
+written response requesting a denial of the
+motion. On July 28, Rich moved for a
+continuance.
+When the case was called for trial on the
+morning of August 1, the District Court
+considered defendants'
+continuance
+motions.
+In support of their motions, both
+counsel asserted personal exigencies that
+had curtailed their pretrial preparation.
+Government counsel expressed opposition to
+the granting of a continuance, primarily
+[1,2] We note initially that a review of
+the trial transcript shows that Rich was
+vigorously defended at trial and belies the
+suggestion that counsel had less than adequate time to prepare for trial. The twenty-day period from time of arrest to trial
+appears adequate, particularly in view of
+the strictures of the Speedy Trial Act.
+Moreover, a motion for continuance is addressed to the sound discretion of the trial
+court, and a refusal to grant a continuance
+will be set aside only upon a showing of
+clear abuse of discretion.
+United States
+Jackson, 549 F.2d 517, 528 (8th Cir.), cert.
+430 U.S. 985, 97 S.Ct. 1682, 52
+L.Ed.2d 879 (1977); United States - Webb,
+583 F2d 391, 395 (8th Cir. 1976). Counsel
+for Rich supported his motion for continuance with the speculation that there might
+be witnesses in Chicago and Nevada whom
+he had been unable to interview prior to
+trial because of the personal time strictures
+of his life. In opposing a continuance, the
+Government presented specific and cogent
+reasons which went to the very viability of
+the prosecution. On these facta, we are
+unable to say that the trial court abused its
+discretion in refusing to grant a continuimportant Government witnesses who were
+then in protective custody.
+Court denied defendants' continuance motions, and on the afternoon of August 1,
+voir dire examination of potential jurors
+was conducted, a jury was impanelled and
+trial was commenced. Rich contends that
+the trial court's refusal to grant a continuance was erroneous because it precluded her
+attorney from making adequate preparation and investigation for her defense.
+She received concurrent terms of imprisonm
+on Counts I-IV. Her sentences on Counts
+VIl run concurrently with one another, but c
+secutively to the sentences in Counts I-IV.
+5. The Honorable H. Kenneth Wangelin, United
+States District Judge for the Eastern District of
+Missouri.
+Discovery of tape recordings in the Governments possession
+[3] Discovery of evidence in criminal
+cases is governed by the provisions of Rule
+16 of the Federal Rules of Criminal Procedure. Prior to trial, Rich made a request
+under Rule 16 for tape recordings of her
+voice which were in the Government's possession. Ordinarily, when a defendant requests inspection of his or her statements
+which are in the possession, custody or control of the Government, the Government
+has a duty of disclosure under Rule
+16(a)1XA).* In the instant case, the
+6. Rule 16(a)(I)A) provides in pertinent part:
+Upon request of a defendant the government.
+shall permit the defendant to inspect and
+copy or photograph: any relevant written or
+recorded statements made by the defendant,
+or copies thereof, within the possession, custody or control of the government * * *.
+
+
+UNITED STATES v. PELTON
+Cite as 578 F.26 701 (1878)
+707
+Government declined to disclose to Rich the exculpatory evidence and the fact that the
+tape recordings of her voice which were in Government made no direct or derivative
+its possession. Motivated by concern for use of the tapes, we find it difficult to
+understand how Rich could have been prejcase, whose identity would be revealed to
+udiced by being denied access to the tapes.
+Rich if she heard the tapes, the Government
+Moreover, a review of the record reveals
+that the protective order at issue here was
+16(dX1), which provides:
+entered in conformance with Rule 16(dX1),
+Upon a sufficient showing the court may
+which specifically authorizes ex parte proat any time order that the discovery or
+ceedings. The purpose of the order sought
+inspection be denied, restricted, or dehere was to protect the identity of persons
+ferred, or make such other order as is
+cooperating on the case. An adversary proappropriate. Upon motion by a party,
+ceeding would have defeated the very purthe court may permit the party to make
+pose of the requested order by revealing
+such showing, in whole or in part, in the
+their identities to Rich.
+form of a written statement to be inspected by the judge alone. If the court
+[5-7] A review of the record, which inenters an order granting relief following
+cludes the sealed tapes at issue here, consuch an ex parte showing, the entire text
+vinces us that an ex parte proceeding was
+of the party's statement shall be sealed
+appropriate on the facts of this case and
+and preserved in the records of the court
+that the Government made a sufficient
+to be made available to the appellate
+showing for a protective order under Rule
+court in the event of an appeal.
+The District Court acted well
+In support of its request, the Government
+within its discretion and in full compliance
+made an ex parte presentation to the court.
+with Rule 16(dX1) in denying Rich acceas to
+Upon listening to the tapes, the trial judge
+the tapes in the Government's possession.
+concluded that they contained nothing ex-
+Furthermore, Rich has made no showing
+culpatory of Rich. He then made the tapes
+that this order prejudiced her substantial
+a part of the record and issued a Rule
+rights. Her contention regarding the Rule
+16(dX1) order sealing them.
+16(dX1) order is without merit.
+were not used at trial. The Government
+also assures us that it made no use at trial
+of any evidence derived from the tapes.
+[4] Rich contends, nonetheless, that the
+court erred in denying her access to the
+recordings of her voice. Discovery matters
+are committed to the sound discretion of
+the district court and an error in administering the discovery rules is reversible only
+on a showing that the error was prejudicial
+al rights of the defendant
+United States Crow Dog, 532 5 24 1182
+1189 (8th Cir. I976), cert. denied, 430 U.S.
+129, 97 S.Ct. 1547, 51 L.Ed.2d 772 (1917)
+Jnited States Cole, 458 F.2d 902, 904-0
+(8th Cir.), cert. denied, 406 U.S. 922, 92 S.Ct.
+1788, 32 L.Ed.2d 122 (1972). Given the trial
+court's finding that the tapes contained no
+7. In denying defendants' motion for pretrial
+discovery of witnesses, the district judge made
+it clear that his ruling had no bearing whatsoever on the Government's duty under 18 U.S.C.
+Pretrial discovery of Government witnesses
+Prior to trial, defendant Rich moved to
+compel the Government "to make witnesses
+and statements" available. Etta Williams,
+a/k/a "Agnes Brittain," an unindicted coconspirator in Count I, was the only prospective Government witness identified in
+the motion. The District Court denied the
+motion and refused to order pretrial discovery of the Government's witnesses.'
+Rich contends that the trial court erred in
+refusing to order pretrial discovery of the
+Government's witnesses. She also suggesta
+that the Government interfered with her
+investigation of the case by concealing prospective witnesses from her.
+¡ 3500 to provide defendants with statements
+of witnesses after they had testified on direc
+examination at trial. It is clear that the
+Government complied fully with § 3500.
+
+
+708
+[8,9]
+Rich's attack
+on
+the
+District Williams' part was anything other than a
+Court's refusal to order pretrial discovery matter of her own personal choice. The
+of witnesses is wholly lacking in merit.
+fact that the Government had undertaken
+Discovery of prospective witnesses is not
+to protect her does not transform this
+equired under Fed.R.Crim.P. 16(a), Unite
+choice into governmental concealment.
+itates i. Krohn. 558 F.2d 390, 394 (8th Cir.
+Moreover, Rich's claim of prejudice because
+ert. denied, 434 U.S. 868, 98 S.Ct. 207, 5
+of her inability to interview Williams prior
+_Ed.2d 145 (1977); United States . Rog
+to trial is undereut by events which traners, 549 F-2d 490, 494 (8th Cir. 1976), cert
+spired during trial. Williams was present
+denied, 431 U.S. 918, 97 S.Ct. 2182, 53
+on the trial dates and was made available to
+L.Ed.2d 229 (197T), and we can find no
+the defendants after the Government deterabuse of discretion in the trial court's refusmined that it would not use her as a wital to order this pretrial discovery. Moreness. Defendants interviewed Williams at
+over, there is no support in the record for
+that time and decided not to call her as a
+the suggestion that the Government impedwitness. We conclude that Rich has failed
+ed Rich in the investigation of her case by
+to establish that the Government precluded
+denying her access to prospective witneases
+her from interviewing a witness willing to
+Charlotte Anderson, Ann Frazier, Kathleen
+talk with her prior to trial or that her lack
+Waggoner and Etta Williams.
+of pretrial contact with Williams was preju-
+[10, 11] Rich employed Charlotte Anderdicial to her defense.
+son as a call girl. She makes no allegation
+whatsoever of contact between Anderson
+and the Government prior to trial.
+Grand jury testimony of Kathleen Waggon-
+Government denies having interviewed An-
+derson or even having known where she
+could be found; it did not call Anderson as
+a witness. Clearly there is no support for
+an inference of governmental concealment
+of Anderson. During the period in question, Ann Frazier and Kathleen Waggoner,
+neither of whom was called as a witness by
+the Government at Rich's trial, had been
+charged with crimes by the Government.
+Rich presents this sole fact as the basis for
+her charge of concealment by the Government. The facta of this case simply do not
+support an equation
+concealment and we decline to infer such an
+Count II of the indietment underlying the
+instant case charged Rich with a § 2421
+violation with regard to the transportation
+of Kathleen Waggoner to Chicago. Waggoner's trip to Chicago was also one of the
+overt acts alleged in support of the conspiracy charged in Count I. On June 1, 1977,
+pursuant to a grant of use immunity, Waggoner testified before a grand jury investigating possible violations by Rich of 18
+U.S.C. §9 1503, 1952 and 2421. During her
+appearance before the grand jury, Waggoner denied that Rich had sent her to Chicago
+in 1976 to work as a prostitute at the boat
+show and also denied that Rich had ever set
+[12] Etta Williams was the Governher up on prostitution dates. As a consement's initial source of information in this
+quence of this testimony, Waggoner was
+case. Shortly after her involvement in the
+indicted on two counts of perjury before the
+investigation of the case began, her apartgrand jury in violation of 18 U.S.C. § 1623.
+ment was firebombed. This event, plus an-
+This indictment, which was handed down on
+other incident which suggested that her
+June 25, 1977, set forth verbatim those porsafety was in continuing jeopardy, resulted
+tions of the grand jury transcript in which
+in her being placed in the protective custo
+Waggoner denied that Rich had sent her to
+dy of the Government and being given a
+Chicago or set her up on prostitution dates.
+new identity. Understandably, she did not Waggoner was convicted on both counta of
+wish to speak to defendants prior to trial.
+perjury at a trial which took place after the
+Rich has not shown that this reluctance on
+trial of Rich and Pelton.
+
+
+UNITED STATES PELTON
+709
+Cile as 578 F.2d 701 (1878)
+[13] In a pretrial motion, Rich sought general nature of Waggoner's testimony be-
+"the testimony of all witnesses before any fore the grand jury, the use immunity ungrand jury which investigated this matter
+der which she had testified and the perjury
+which is favorable to this defendant." In
+indictment then pending against her. The
+ita answer to Rich's motion, the Governdistrict judge ultimately refused to allow
+ment stated that it would provide grand
+Rich to introduce the transcript of Waggonjury transcripts only insofar as it was reer's grand jury testimony into evidence.
+quired to do so by 18 U.S.C. § 3500. The
+Contemporaneously, however, he ruled that
+trial court sustained the Government's рові-
+Rich could read Waggoner's indictment to
+tion and denied Rich's motion. This ruling
+the jury. Although this indictment conwas consonant with the well-established
+tained testimony in which Waggoner denied
+rule in this circuit that grand jury testimothat Rich had sent her to Chicago or had set
+my line railed of die ra be in ere ial
+her up on prostitution dates, counsel for
+Rich chose not to introduce it into evidence.
+F.2d 928, 935 (8th Cir. 1970), cert. denied,
+Rich now contends that Waggoner's
+402 U.S. 973, 91 S.Ct. 1660, 29 L.Ed.2d 137
+grand jury testimony was admissible under
+Fed.R.Evid. 804(a)(1) and that the trial
+Waggoner was not called as a witcourt erred in refusing to allow her to introness at Rich's trial. If the Government had
+duce the relevant portions of this transeript
+called Waggoner and if she had testified,
+at trial. Rule 804 sets forth those instances
+Rich would have been entitled to a tranin which the hearsay statements of unavailscript of her grand jury testimony under 18
+able declarants may be admitted into evi-
+U.S.C. § 3500. Rich herself did not attempt
+dence at trial. Rich relies upon § (a)(1) of
+to call Waggoner as a witness.
+Rule 804, which provides that a declarant is
+assumed that Waggoner would refuse to
+"unavailable" if he or she "is exempted by
+testify and sought, on that basis, to introruling of the court on the ground of prividuce a transcript of Waggoner's grand jury
+lege from testifying concerning the subject
+testimony into evidence.
+matter of his statement."
+On the morning of the third day of trial,
+[15, 16] The unavailability requirement
+counsel for Rich made the following inof Rule 804 places the burden of producing
+chambers presentation to the trial court:
+I have caused a subpoena to be served
+an unavailable declarant upon the proponent of the evidence.
+United States
+upon Kathleen Waggoner to testify. It is
+Amaya, 533 F.2d 188, 191 (5th Cir. 1976),
+my understanding that she is under
+cert. denied, 429 U.S. 1101, 97 S.Ct. 1125, 51
+charges at the present time in this Court
+L.Ed.2d 551 (1977); see generally 11
+or in another Division and her attorney
+Moore's Federal Practice 1 804.02, at VIII-
+has indicated that he will advise her to
+239-40 (2d ed. 1976).
+Rich, the proponent
+invoke her privilege under the Fifth
+here, accordingly had the burden of estab-
+Amendment and refuse to testify. On
+lishing that Waggoner would invoke her
+that basis, Your Honor, I would request
+fifth amendment privilege and thus be unaan opportunity to utilize her Grand Jury
+vailable to testify. Our review of the rectestimony and introduce portions of the
+ord convinces us that Rich utterly failed to
+Grand Jury testimony which would be
+carry this burden. Counsel for Rich made
+relevant and request that the Governno effort to produce Waggoner, whom he
+ment furnish me with a copy of her
+had subpoenaed, and to demonstrate first-
+Grand Jury testimony. I believe that it
+hand and in the court's presence that she
+would be admissible pursuant to Rule 804
+did intend to refuse to testify in reliance on
+of the Federal Rules of Evidence.
+her fifth amendment privilege against self-
+The Government objected to the use of
+incrimination. Rather, he chose to raise the
+Waggoner's grand jury testimony.
+The
+issue of her privilege in an extenuated and
+court and both parties then discussed the circuitous manner which gave the court
+
+
+710
+nothing more than a speculative basis for evidence adduced against Rich. Suffice it
+determining whether she was available.
+to say that the evidence, when viewed in
+Rich's proof that Waggoner was unavailathe light most favorable to the Governble under Rule 804(a)1) was that Waggonment, is more than sufficient to support the
+er's attorney had said that he was going to
+jury's verdiets of guilty on Counts I-VII.
+advise Waggoner not to testify. There was
+We will now address defendant Pelton's
+no indication that Waggoner had in fact
+contentions.
+been so advised or that, if she had been, she
+had decided to exercise her privilege.
+We
+consider Rich's suggestion, that Waggoner
+might in the future be advised of and then
+choose to exercise her fifth amendment
+privilege, to be a wholly inadequate showing of unavailability under Rule 804(aX1).
+The trial court did not err in refusing, on
+this speculative basis, to allow Rich to introduce into evidence the transcript of Waggoner's testimony before the grand jury."
+Sufficiency of the evidence
+[17, 18] Rich contends that the evidence
+was insufficient to support her convictions.
+In considering this contention, we must
+riew the evidence in the light most favor
+ble to the Government. Glasser . Unite
+States, 315 U.S. 60, 80, 62 S.Ct. 457, 86
+L. Ed. 680 (1942). We have done so and we
+conelude that the evidence against Rich is
+legally sufficient to support her convictions.
+Indeed, the plethora of evidence of Rich's
+participation 'in the transportation of women to Chicago and Nevada is such that we
+cannot find a close question of evidentiary
+sufficiency on any of the seven counts on
+which she was convicted. Under these circumstances we choose not to catalogue the
+8. Rich
+also
+argues that the Governme
+Maryland, 373 U.S. 83, 83 S.Ct. 1194,
+L.Ed.2d 215 (1963), by falling to release Waggoner's grand jury testimony. Under Brady.
+governmental suppression at trial of "evidence
+favorable to an accused upon request violates
+due process where the evidence is material
+either to guilt or to punishment, irrespective of
+faith or bad faith of the prosecution."
+Tre No a ma no de pre ming.
+ment in the instant case. Unlike Brady, where
+the evidence suppressed by the prosecution did
+not come to the defendant's notice until after
+he had been tried, convicted and sentenced and
+his conviction had been affirmed, defendant
+Rich clearly had notice prior to trial of the
+evidence at issue here and in fact had access to
+Constitutionality of 18 U.S.C. § 2421
+[19] Pelton argues that since prostitution is legal in Winnemucca, Nevada, the
+destination of the female whose interstate
+transportation underlies his convictions, the
+Mann Act unconstitutionally violates and
+derogates "the rights of females to seek
+legal employment as guaranteed by the
+constitution of this country." As we have
+previously noted, "[it is rather late in the
+history of the Mann Act to still be contending for its unconstitutionality. The Act has
+been consistently upheld
+• • *" (Citations omitted.) United States | Garrett,
+521 F2d 444, 446 (8th Cir. 1975). Defendant Pelton is not a female whose ability to
+seek legal employment was constrained by
+the Mann Act and he consequently lacks
+tanding to attack tae statute on this basi
+ce United States i Garrett, supra at 44
+Because of his lack of standing, we pretermit analysis of the substance of his constitutional challenge, although we cannot help
+but note that its strength appears to lie in
+its ingenuity rather than in any degree of
+legal cogency. It is difficult to conceive of
+prostitution as being constitutionally guaranteed and protected.
+the crucial aspects of Waggoner's grand jury
+testimony through the Waggoner indictment.
+She chose not to introduce the indictment with
+this verbatim testimony Into evidence. We
+would ordinarily be hesitant to construe a tactial decision of this nature as an indicator of the
+nateriality of evidence. Rich's subsequen
+treatment of Waggoner's grand jury testimony.
+however, supports the initial Impression that
+Its worth to Rich's defense was nugatory. Al-
+though Rich has had access to Waggoner's
+grand jury testimony since Waggoner's trial,
+when it became a matter of public record, she
+has falled to specify any favorable evidence
+therein which she did not already have access
+to by way of Waggoner's indictment. On these
+facts, we reject Rich's claim that non-access at
+trial to Waggoner's grand jury testimony constituted a violation of her right to due process.
+
+
+Severance
+[20] Pelton filed a pretrial motion for
+severance which was denied by the District
+Court on July 27. At a pretrial proceeding
+on the morning of August 1, counsel for
+Pelton brought the severance issue back to
+the District Court's attention in a somewhat
+roundabout way, expressing the opinion
+that Pelton could not receive a fair trial
+because most of the evidence in the case
+was unrelated to Pelton. He made no formal motion for a severance at this time,
+however. Moreover, it is undisputed that
+Pelton did not renew the motion for severance at the close of the Government's evidence or at the conclusion of all the evidence.
+"deemed waived." United States v. Porter,
+441 F.2d 1204, 1212 (8th Cir.), cert. denied,
+404 U.S. 911, 92 S.Ct. 238, 30 L.Ed.2d 184
+(1971). Accordingly, we hold that Pelton
+has waived his right to assert the severance
+issue.
+UNITED STATES | PELTON
+711
+Cleas 578 F 26 701 (1878)
+that the evidence exelude every reasonable
+hypothesis except that of guilt but simply
+that it be sufficient to convince the jury
+beyond a reasonable doubt that the defend
+ant is guilty." United States
+Shahan
+517 F.2d 1173, 1177 (8th Cir.), cert. denied,
+428 U.S. 893, 96 S.Ct. 191, 46 L.Ed.2d 124
+(1975). This standard also applies in cases
+where the conviction rests on circumstantia
+evidence, see United States - Joyner, 58
+F.2d 1162, 1165 (8th Cir.), crt. denied, 423
+Sufficiency of the evidence
+Pelton was charged in only those four
+counts of the indictment related to the Ne-
+vada trips. He was acquitted on Counta VI
+and VIII, which charged him with inducing
+the transportation to Nevada of Shirley
+Dawson and Charlotte danderson. He was
+convicted on Count
+the conspiracy
+charge stemming from the Nevada trips,
+and on Count VII, the charge involving the
+inducement of Kathleen Bray to travel to
+Nevada.
+Pelton contends that his convictions on Counts VI and VIl are not supported by sufficient evidence.
+[21-23] In analyzing this contention, our
+point of departure must be those well-worn
+principles which require us to view the evidoneriment, liaber United Slate, the
+U.S. 60, 80, 62 S.Ct. 451, 86 L. Ed. 680 (1942),
+and to accept as established all reasonable
+inferences from the evidence that tend
+support the jury's verdict. United States
+Overshon, 494 F.2d 894, 896 (8th Cir.), cert.
+denied, 419 U.S. 858, 95 S.Ct. 96, 42 L.Ed.2d
+85 (1974). We must, moreover, be guided
+by the general rule that "it is not necessary
+Baciles probative as direct evidence
+United States, 348 UJ.S. 121, 140, 75
+S.Ct. 127, 99 L.Ed. 781 (1954). With these
+familiar principles in mind, we address Pelton's attack upon the sufficiency of the
+evidence supporting his convictions.
+Count V
+Count charged Pelton and Rich with a
+conspiracy to "knowingly transport in interstate commerce a woman or girl for the
+purpose of prostitution or debauchery and
+other immoral purposes (a violation of Title
+18, U.S.C. § 2421]." The indietment posited
+that in furtherance of this conapiracy Rich
+and Pelton agreed to send women and girls
+from St. Louis, Missouri, to Winnemucca,
+Nevada, for purposes of prostitution on various dates in October 1976, and that Rich
+gave Shirley Dawson, Kathleen Bray and
+Charlotte Anderson money to purchase tickets to Reno, Nevada.
+Pelton contends generally that the evidence supporting his conspiracy conviction
+does not prove the existence of an unlawful
+agreement between him and Rich. More
+specifically, he argues that any agreement
+that may have existed was lawful because
+prostitution is legal in Nevada and/or because the women in question travelled to
+Nevada on their own volition.
+[24,25] "The offense of conspiracy consists of an agreement between the conspirators to commit an offense, attended by an
+act of one or more of the conspirators to
+effect the object of the conspiracy." Unit-
+
+
+712
+od States Skillman, 442 F 2d 542, 547 (8th
+Cir.), cert. denied, 404 U.S. 838, 92 S.Ct. 82,
+30 L.Ed.2d 63 (1971). The agreement need
+not be express or formal and it may be
+established
+circumatantial
+evidence.
+United States Hutchinson, 488 F 2d 484,
+490 (9th Cir.
+978), cert. denied, 417 U.S
+915, 94 S.Ct. 2616, 41 L.Ed.2d 219 (1974).
+Indeed, this court has long recognized that
+since conspiracy is rarely susceptible of
+proof by direct evidence, it may properly be
+add the fending comato a piano
+and the attending circumstances.
+United States, 304 F.2d 810, 825 (8th Cir.),
+pert. denied, 371 U.3. 890, 85 S.CL 188,
+L. Ed.2d 123 (1962); Goode - United States,
+58 F.2d 105, 107 (8th Cir. 1332).
+[26] The conduct of the parties and the
+attending circumstances revealed by the
+record here support the existence of an
+agreement by Rich and Pelton to transport
+women to Nevada for prostitution purposes.
+Bray, one of the women so transported,
+testified that she was present at Rich's
+apartment in St. Louis when Rich and Pelton decided to send her and another call girl
+named Georgia to Penny's Cozy Corner, a
+house of prostitution in Winnemucca, Nevada. In Bray's presence, Pelton made a telephone call to Penny's and arranged for her
+to work there. Pelton and Rich then gave
+Bray instructions on what to do when she
+reached Winnemuoca. She was told to register as a prostitute, which would require
+lying about her age since she was not yet
+eighteen years old, to get a doctor's examination and then to go to Penny's. Bray,
+Rich and Pelton agreed that Bray would
+give 40% of her earnings to Penny's and
+split the remaining 60% with Rich.
+Bray
+also agreed to pay Pelton $200 for setting
+her up at Penny's. To finance the trip,
+Rich lent Bray $200 for clothes and $250 for
+airfare, a license and the accessories which
+would be necessary at Penny's. Bray subsequently flew from St. Louis to Nevada in
+accordance with the plans and arrangementa formulated by Rich and Pelton and
+attempted to become a prostitute. Upon
+being denied a license in Winnemucca because she was under age, she returned to
+St. Louis. We believe that the evidence in
+this case was sufficient to have convinced
+the jury beyond a reasonable doubt that
+Pelton was guilty of participating in a conspiracy with Rich knowingly to transport a
+woman to Nevada in interstate commerce
+for purposes of prostitution.
+[27, 28] We must reject as unavailing
+Pelton's attempt to legitimize his agreement with Rich by arguing that prostitution is legal in Nevada and that Bray had a
+desire to travel to Nevada and to work
+there as a prostitute which pre-existed his
+participation in the plans. Section 2421
+flatly prohibits transportation of women in
+interstate commerce
+"for the purpose of
+prostitution or debauchery, or for any other
+immoral purposes"; ite prohibition is not
+keyed to the legality or illegality of prostitution under the law of the state where the
+transportation ends. When Rich and Pelton agreed to send Bray to Nevada to work
+as a prostitute, they made an agreement to
+violate § 2421, and the status of prostitution under Nevada law has no bearing on
+the illegality of this agreement under the
+[29, 30] Equally lacking in legal merit is
+Pelton's suggestion that any agreement be
+may have had with Rich was legal because
+Bray was predisposed and willing to go to
+Nevada to work as a prostitute. Whether
+or not Bray was so predisposed and willing
+is immaterial to the illegality of Pelton's
+agreement with Rich to violate § 2421, for
+consent is neither a defense to a violation
+charged under § 2421, Gebardi | United
+States, 287 U.S. 112, 119, 53 S.C7
+• 35, 77
+L.Ed. 206 (1932);
+Hattaway
+United
+433 (5th Cir. 1968);
+States, 20 nited states, 25 - 24 900, 80.
+Wiley
+(8th Cir. 1958), nor to a violatio
+charged
+under § 2422
+Blumenfield
+United
+States, 284 F.2d 46, 58 (8th Cir.), cert. denied, 365 U.S. 812, 81 S.Ct. 698, 5 L.Ed.2d
+692 (1960). Pelton conspired with Rich to
+transport Bray in interstate commerce to
+Nevada for purposes of prostitution in vio
+lation of § 2421. Whatever Bray's degree
+of willingness to travel may have been, it
+does not vitiate the illegality of the agree-
+
+
+VERVAECKE Y. CHILES, HEIDER & CO., INC
+Cite as 578 F.20713 (1878
+713
+ment to transport her for purposes of prostitution.
+violating 18 U.S.C. § 2422 by persuading.
+inducing and enticing Kathleen Bray to go
+in interstate commerce to Nevada with the
+intent on their part that she engage in
+prostitution there, and with thereby knowingly causing her to be transported there as
+a passenger upon the line and route of a
+common carrier in interstate commerce.
+challenging the sufficiency of the evidence
+supporting his conviction on this count, Pelton does not dispute that Bray was transported to Nevada for purposes of prostitution. His attack on the sufficiency of the
+evidence pertains to the issue of inducement. He seema to contend that because
+there was evidence that Bray was willing to
+go to Nevada to work as a prostitute, the
+record will not support a finding of inducement on his part.
+[31-33] We are unable to agree. Even
+if we assume that Bray was willing to
+travel to Nevada to be a prostitute, the fact
+remains that by setting her up at Penny's
+Cozy Corner, Pelton helped provide the inducement which caused her to make the
+trip." It is the inducement of transportation which is prohibited under 5 2422, not
+the actual
+rovision of that transportation.
+Nunnally
+United States, 291 F.2d 205,
+206-07 (5th Cir. 1961). When an offer to
+travel interstate for purposes of prostitution elicits a positive response from a woman to whom it is made, it constitutes a
+equisite inducement under the statute
+Tarms | United States, 272 F.2d 478, 48
+(4th Cir. 1959), cert. denied, 361 U.S. 961, 80
+S.Ct. 590, 4 L.Ed.2d 543 (1960).
+The evidence here shows that Pelton made an inducement sufficient to persuade Bray to
+travel to Nevada. We believe that Pelton's
+conviction under § 2422 with regard to
+Bray's inducement is supported by sufficient evidence.
+Affirmed.
+9. Indeed, the fact that until Pelton "placed" he
+at Penny's, Bray may have harbored an unful
+filled wish to go to Nevada to be a prostitute
+570 F.20-10
+Maurice M. VERVAECKE, Appellant,
+Count VII
+CHILES, HEIDER & CO., INC., Dean Witter & Co., Incorporated, Arthur Young
+: Company, Northwestern Nation
+ank, Hospital Authority No. 1 of Sar
+County, Nebraska and Midlands Community Hospital, Appellees.
+No. 77-1923.
+United States Court of Appeals,
+Eighth Circuit.
+Submitted April 14, 1978.
+Decided June 9, 1978.
+Purchaser of corporate bonds brought
+securities fraud action against broker dealers, issuer's auditor and others. The United
+States District Court for the District of
+Nebraska, Albert G. Schatz, J., entered
+summary judgment dismissing the complaint, and purchaser appealed. The Court
+of Appeas, Ross, Cireuit Judge, held that:
+(1) reliance could not be presumed since
+case was not one involving primarily nondisclosure but, rather, was based on fraudulent misstatements and omissions in offering prospectus; (2) reliance element was
+lacking where purchaser did not see offering statements until after commitment to
+purchase had been made, and (8) it was not
+error to strike plaintiff's class action allega.
+tions either as to bond issue in which he had
+dealt or issue in which he had not traded.
+Affirmed.
+1. Securities Regulation *-143
+Reliance could not be presumed in securities fraud action brought by purchaser of
+corporate bonds and purchaser was obligated to state facts sufficient to raise a genuemphasizes rather than undercuts the causa
+relationship between Pelton's inducement an
+Bray's trip.
+
+
+1011
+Cite as 495
+d 1011 (8ch Cir. 2007)
+minor.
+18 U.S.C.A. $9 1470, 2422(b),
+UNITED STATES of America,
+Appellee,
+2423(b).
+2. Infants C-20
+Defendant's conversations with under-
+John T. SPURLOCK, Appellant.
+cover officer, who defendant believed was
+No. 06-3262.
+the adult mother of two young girls, were
+United States Court of Appeals,
+sufficient to support conviction for attempt
+Eighth Circuit.
+to entice minor victims to engage in unlaw-
+Submitted: Jan. 10, 2007.
+ful sexual activity; defendant described to
+the "mother" his desire to perform sex
+Filed: July 30, 2007.
+acts on her "daughters", he asked her to
+Background: Defendant was convicted in
+tell her daughters about his wishes, and to
+the United States District Court for the instruct the girls not to tell anyone, and he
+Western District of Missouri, Gary A. Fenmade plans with the mother to meet at a
+ner, J., of seven counts of violating federal
+motel to have sex with the daughters. 18
+child exploitation statutes, and was sen- U.S.C.A. $ 2422(b).
+tenced to 168 months in prison. Defendant
+appealed.
+3. Criminal Law C-44
+Holdings: The Court of Appeals, Colloton,
+The elements of attempt are (1) intent
+Circuit Judge, held that:
+to commit the predicate offense, and (2)
+(1) convictions did not require proof that
+conduct that is a substantial step toward
+the intended vietim was an actual mi- its commission.
+nor, as long as defendant believes that
+the victim is a minor;
+4. Sentencing and Punishment -765,
+(2) defendant's conversations with undercover officer were sufficient to support
+The burden is on a defendant claiming
+conviction for attempt to entice minor a two-level sentencing reduction for accepvietims to engage in unlawful sexual
+tance of responsibility to show that he
+clearly demonstrated acceptance of re-
+§ 3E1.1(a), 18
+1) defendant was not entitled to sentenc
+1g reduction for acceptance of respor
+5. Criminal Law 61158(1)
+A distriet court's factual determina-
+Bright, Cireuit Judge, filed opinion coneur- tion about whether the defendant accepted
+ring in part, and dissenting in part.
+responsibility is entitled to great deference, for sentencing purposes, and the ap-
+1. Infants 6-20
+pellate court will reverse it only if it is so
+Convictions for attempting to entice a
+clearly erneous as to be without foundaminor to engage in illegal sexual activity, tion.
+• $ 3E1.1(a), 18 U.S.C.A.
+attempting to transfer obscene material to
+someone under the age of 16, and attempt-
+6. Sentencing and Punishment c-765
+ing to travel in interstate commerce for
+Defendant convicted of multiple violathe purpose of engaging in illieit sexual tions of federal child exploitation statutes
+conduct do not require proof that the in- was not entitled to sentencing reduction
+tended victim is an actual minor, as long as for acceptance of responsibility; defendant
+defendant believes that the victim is a did not plead guilty, he did not indicate
+
+
+1012
+that his defense at trial would be purely imprisonment. Spurlock appeals, and we
+legal, he did not demonstrate contrition, affirm.
+and although he stipulated to a few basie
+facts, mostly relating to the foundation of
+prosecution exhibits, he did not stipulate to
+the content of the exhibits, or to the factu-
+In January 2005, Spurlock entered an
+al elements of guilt. 18 U.S.C.A. 99 1470,
+Internet chat room entitled "Daughters
+2422(b), 2423(b); U.S.S.G. § 3E1.1(a), 18
+Who Love Daddies," and made contact
+with a person who identified herself as
+T. Sentencing and Punishment c-765
+"Mary Roberts." "Mary" told Spurlock
+Timeliness of defendant's cooperation she had two young daughters, thirteenis a relevant factor in determining eligibili- year-old "Amber" and ten-year-old "Manty for a two-level sentencing reduction for dy." Unbeknownst to Spurlock, "Mary"
+acceptance of responsibility, both because
+was actually Detective Angie Wilson, an
+untimely admissions may force the governundercover agent with the FBI, and "Am-
+ment and the court to expend resources
+ber" and "Mandy" did not exist. Over the
+unnecessarily, and because the timeliness
+course of several Internet chats, Spurlock
+of a defendant's acceptance of responsibility is a measure of his true contrition and
+repeatedly expressed to "Mary" his desire
+to have sex with her and her daughters.
+remorse for the criminal conduct.
+U.S.S.G. § 3E1.1(a), 18 U.S.C.A.
+During one online conversation, Detective
+Wilson, posing as "Mary," pretended to
+allow the girls to chat directly with Spurlock. Spurlock described various sex acts
+that he wanted to perform on the girls,
+Travis D. Poindexter, Asst. Fed. Publie
+and instructed them to perform sex acts on
+Defender, Kansas City, MO, argued (Raymond C. Conrad, Jr., Fed. Public Defendone another. Still believing he was talking
+to the girls, Spurlock exposed himself on
+er, on the brief), for appellant.
+his webcam and began masturbating.
+Philip M. Koppe, Asst. U.S. Atty., Kansas City, MO, argued (Bradley J. Schloz-
+In both online and telephone conversaman, U.S. Atty., Katharine Fincham, Asst.
+tions with "Mary," Spurlock made plans to
+U.S. Atty., on the brief), for appellee.
+travel from his home in Texas to Kansas
+City, Missouri, to have sex with her daugh-
+Before COLLOTON, BRIGHT, and
+ters. On February 5, 2005, Spurlock ar-
+GRUENDER, Circuit Judges.
+rived in Kansas City and telephoned
+COLLOTON, Cireuit Judge.
+"Mary" to inform her that he had pur-
+Following a bench trial, John T. Spurchased condoms and checked into a motel.
+lock was convicted of seven counts of vio-
+FBI agents arrested Spurlock at the molating federal child exploitation statutes in
+tel. Spurlock admitted that he had travconnection with his attempt to entice two
+eled to Kansas City for the purpose of
+minors to engage in unlawful sexual activi- having sex with "Amber" and "Mandy,"
+ty. The district court' imposed concurwhom he believed to be thirteen and ten
+rent sentences of 168 and 120 months' years old.
+1. The Honorable Gary A. Fenner, United
+States District Judge for the Western District
+of Missouri.
+
+
+U.S. | SPURLOCK
+1013
+Cite as 495 F.3d 1011 (8ch Cir. 2007)
+A grand jury returned a seven-count by denying him a downward adjustment
+against Spurlock.
+Three for acceptance of responsibility, and that
+counts charged him with attempting to he is thus entitled to be resentenced based
+entice a person below the age of eighteen on a more favorable advisory guideline
+to engage in unlawful sexual activity, in
+violation of 18 U.S.C. § 2422(b). Two
+counts charged him with attempting to
+transfer obscene material to someone be-
+[1] Spurlock's first argument for a
+low the age of sixteen, in violation of 18 judgment of acquittal is that the statutes
+U.S.C. § 1470. One count charged him
+under which he was convicted did not prowith travel in interstate commerce for the hibit his conduct. He contends that bepurpose of engaging in illicit sexual con- cause he conversed only with an undercovduct, in violation of 18 U.S.C. § 2423(b).
+er agent, and the statutes required that an
+One count sought the forfeiture of properactual minor must be involved, the governty Spurlock used in commission of the
+ment proved no violation of federal law.
+This argument is foreclosed by our deci-
+Spurlock moved to dismiss the indietsions in United States v. Helder, 452 F.3d
+ment. He claimed that his conduct did not
+751 (8th Cir.2006), and United States v.
+violate the statutes under which he was
+Hicks, 457 F.3d 838 (8th Cir.2006). In
+charged, because no actual minor was in-
+Helder, we concluded that an actual minor
+volved. The district court denied the movictim is not required for the crime of
+tion. Spurlock then rejected the governattempted enticement under § 2422(b).
+ment's offer of a conditional guilty plea,
+452 F.3d at 756. In Hicks, we extended
+and asserted his right to go to trial. During the bench trial, Spurlock moved twice
+that reasoning to § 2423(b)'s prohibition of
+for a judgment of acquittal, reasserting his
+travel with intent to engage in illicit sexual
+conduet. 457 F.3d at 841. Helder and
+claim that the statutes did not prohibit his
+conduet. Spurlock also argued for acquit-
+Hicks control here, and apply with equal
+force to the third statute under which
+tal on the grounds that his conversations
+with "Mary" were not, by themselves, an
+Spurlock was convicted: attempt to knowattempt to entice her daughters to have
+ingly transfer obscene matter to a minor
+sex. The district court denied Spurlock's
+under § 1470. Spurlock's belief that the
+motions and found him guilty on all counts.
+person to whom he transferred obscene
+matter was under the age of sixteen is
+At sentencing, in calculating Spurlock's
+sufficient to convict him of attempt, even if
+offense level under the advisory sentencing
+the recipient was actually an adult. See
+guidelines, the court denied Spurlock's re- Helder, 452 F.3d at 755.
+quest for a two-level reduction for acceptance of responsibility under USSG [2] Spurlock next challenges his con-
+§ 3E1.1(a). The court sentenced Spurlock viction on Count One of the indictment.
+to 168 months' imprisonment on each of Count One alleges that independent of
+the enticement and interstate travel Spurlock's direct conversations with the
+counts, and to 120 months' imprisonment girls, his conversations with "Mary" were
+on each of the attempt to transfer obscene by themselves an attempt to entice her
+material counts, all to be served concur- daughters to engage in unlawful sexual
+rently. Spurlock appeals the denial of his activity, in violation of § 2422(b). Spurmotions for a judgment of acquittal. He lock argues that contact with an adult can
+also contends that the district court erred never, by itself, be an attempt to entice a
+
+
+1014
+minor. In Spurlock's view, the statute
+requires direct communication with a minor or a purported minor. We disagree.
+[3] The elements of attempt are (1)
+intent to commit the predicate offense, and
+(2) conduet that is a substantial step to-
+"the efficacy of § 2422(b) would be eviscerated if a defendant could circumvent the
+statute simply by employing an intermediary to carry out his intended objective."
+Murrell, 368 F.3d at 1287. We do not
+believe the statute exempts sexual predators who attempt to harm a child by ex-
+Blue Bird, 372 F.3d 989, 993 (8th Cir.
+ploiting the child's natural impulse to trust
+2004). We conclude that Spurlock intendand obey her parents. Accordingly, we
+ed to entice minor girls to have sex with
+conclude that Spurlock attempted to entice
+him, and that his conversations with their
+"Amber" and "Mandy" through his converpurported mother were a substantial step
+sations with their purported mother, and
+toward that end. See United States z
+we reject his challenge to the conviction on
+Murrell, 368 F.3d 1283, 1287-88 (11th Cir.
+2004); United States v. Hornaday, 392
+F.3d 1306, 1310 (11th Cir.2004). Spurlock
+[4, 5] Finally, we consider Spurlock's
+described to "Mary" his desire to perform
+claim that the district court erred at sensex acts on her daughters, provided her
+tencing by denying him a two-level reducwith suggestions about sex acts he would
+tion for acceptance of responsibility. Un-
+like the girls to perform on him, and asked
+der USSG § 3E1.1(a), the burden is on a
+her to tell the girls about his wishes. He
+defendant to show that he "clearly demonrelied on "Mary's" influence and control
+strate[d]" acceptance of responsibility.
+over her daughters, asking her to instruct
+See United States v. Thomas, 93 F.3d 479,
+the girls not to tell anyone what he
+489 (8th Cir.1996). A distriet court's facplanned to do to them. He made plans
+tual determination about whether the dewith "Mary" to meet at a motel in Kansas
+fendant accepted responsibility is entitled
+City where he would have sex with her and
+to great deference, and we will reverse it
+her daughters. He admitted at trial that
+only if it is so clearly erroneous as to be
+he "tried to persuade those two girls
+without foundation. United States v. Litthrough their mother to engage in sexual
+tle Hawk, 449 F.3d 837, 839 (8th Cir.2006).
+acts[.J" (Tr. at 76).
+Spurlock's conversations with "Mary"
+[6] In certain "rare situations," a debear the familiar hallmarks of criminal atfendant may clearly demonstrate accep-
+They went beyond mere preparatance of responsibility despite his decision
+tion; they were necessary to the consumto go to trial. USSG § 3E1.1, comment.
+mation of the crime; and they strongly (n.2). "This may occur, for example,
+corroborate Spurlock's criminal intent to where a defendant goes to trial to assert
+entice the girls. See United States u or preserve issues that do not relate to
+Jonsson, 15 F.3d 759, 761 (8th Cir.1994), factual guilt (eg, to make ... a challenge
+We join the Eleventh Circuit in noting that to the applicability of a statute to his con-
+2. Spurlock's claim that his contact with
+"Mary" did not constitute statutory rape or
+statutory sodomy under Missouri law is beside the point. Section 2422(b) prohibits an
+attempt knowingly to entice a minor to engage in "any sexual activity for which any
+person can be charged with a criminal offense." Count One of the indictment alleges
+that Spurlock's conversations with "Mary"
+were an attempt to entice her daughters to
+engage in sexual activity with him, for which
+Spurlock could be charged with statutory
+rape and statutory sodomy under Missouri
+law. Therefore, Spurlock's actions fall within
+the scope of the federal statute.
+
+
+U.S. | SPURLOCK
+1015
+Cite as 495 F.3d 1011 (8th Cir. 2007)
+duet)." Id. In such instances, a court ment to its burden of proof at trial by
+should look primarily to a defendant's pre- denying the essential factual elements of
+trial statements and conduct to determine guilt," USSG § 3E1.1, comment. (n.2), and
+if he has accepted responsibility, id, and preserved his right to urge an acquittal
+the timeliness of a defendant's acceptance based on any shorteomings or missteps in
+of responsibility is a relevant factor under the presentation of the government's case.
+3E1.1(a). Id., comment. (nn.1(h), 6). Of See United States v. Sumner, 119 F.3d
+course, even a defendant who pleads guilty 658, 660 (8th Cir.1997) ("[A] general denial
+is not entitled to the downward adjustment defense ... forces the government to
+as a matter of right, 2d, comment. (n.3), so prove every element of the crime
+neither is a defendant who goes to trial to charged.")
+preserve issues that do not relate to factual guilt. Spurlock claims he went to trial
+[7) The district court found that Spuronly to advance a legal argument, and that
+lock's actions resulted in "considerable efthe district court was required to find that
+fort and preparation on the part of the
+his case exhibits one of the
+"rare situagovernment and necessitated the governtions" in which a defendant who is convictment presenting its case at trial." (Tr. at
+ed at trial should receive the benefit of the
+84). Timeliness is a relevant factor in
+adjustment. We disagree.
+determining eligibility for a two-level re-
+At the pretrial conference, Spurlock did
+duction, both because untimely admissions
+not indicate that his defense at trial would
+may force the government and the court to
+be purely legal. He announced, rather,
+expend resources unnecessarily, see Unitthat he would rely on a defense of "general
+ed States v. Kiel, 454 F 3d 819, 824 (8th
+denial." (R. Doc. 42, at 3). Spurlock
+Cir.2006); United States v. Erhart, 415
+eventually stipulated to a few basic facts,
+F.3d 965, 972 (8th Cir.2005), and because
+mostly relating to the foundation for some
+the timeliness of a defendant's acceptance
+prosecution exhibits, but he did not stipuof responsibility is a measure of his true
+late to the content of the more than sixty
+contrition and remorse for the criminal
+exhibits the government introduced at triconduct. United States u. Sierra, 188 F.3d
+al, or to the factual elements of guilt.
+798, 804 (7th Cir.1999); United States v
+After the government presented its case-
+Ewing, 129 F.3d 430, 436 (7th Cir.1997).
+in-chief, Spurlock took the stand and ad-
+Spurlock's last-minute admissions, made
+mitted to the factual allegations against
+after he waited to confirm that the governhim. (Tr. at 74-77).
+nent was able to prove the charged of
+FREE
+enses in its case-in-chief, "had little effec
+did not clearly demonstrate acceptance of on the quantum of evidence the governresponsibility was not without foundation. ment was required to present," United
+At the pretrial conference, Spurlock had States v. King, 36 F.3d 728, 735 (8th Cir.
+an opportunity to admit the factual ele- 1994), and did not amount to persuasive
+ments of guilt and to narrow the case to showing of contrition and remorse. See
+purely legal issues—i.e, whether the fed- also United States v. Abfalter, 340 F.3d
+eral statutes under which he was charged 646, 652 (8th Cir.2003); United States u.
+require the involvement of an actual minor, Field, 110 F.3d 592, 594 (8th Cir.1997)
+and whether 18 U.S.C. § 2242(b) requires (upholding denial of acceptance-of-respondirect communication with a minor. But sibility adjustment where defendant "went
+through his general denial, Spurlock to trial contesting the factual elements of
+hedged his bet. He "put ] the govern- guilt" and made "no stipulations of guilty
+
+
+1016
+conduct ... limiting the trial to a constitu- of acquittal after a jury trial, see Helder,
+tional or statutory challenge").
+452 F.3d at 753, and dismissal of the in-
+Spurlock had an opportunity to proceed dictment, see Hicks, 457 F.3d at 840.
+in a manner that could have qualified as a Spurlock's decision to proceed to trial was
+"rare situation" in which a defendant goes indisputably motivated by an attempt to
+to trial and still earns an adjustment for preserve for appeal the same legal arguacceptance of responsibility. But he bears ment that had worked for similar defenthe burden to demonstrate his entitlement dants in the same court.?
+to that benefit, and he failed to make an The Guidelines specifically anticipate
+early demonstration of contrition, or to circumstances in which a defendant might
+take the initiative to narrow the case to require or prefer a trial in order to prethe straightforward legal issues that he serve certain legal issues. Commentary
+now says were the only reason for a trial. Note 2 to U.S. SENTENCING GUIDELINES
+We conclude that the distriet court did not
+MANUAL § 3E1.1 (2004) sets forth:
+clearly err when it denied an acceptance-
+a defendant may clearly demonstrate acof-responsibility reduction.
+ceptance of responsibility for his criminal conduct even though he exercises his
+***
+For these reasons, the judgment of the
+district court is affirmed.
+constitutional right to a trial. This may
+occur, for example, where a defendant
+goes to trial to assert and preserve issues that do not relate to factual guilt
+BRIGHT, Circuit Judge, concurring in
+part and dissenting in part.
+I concur in the majority's affirmance of
+Spurlock's conviction. I dissent, however,
+from the majority's conclusion about Spur-
+(e.g., to make a constitutional challenge
+to a statute or a challenge to the applicability of a statute to his conduct). In
+each such instance, however, a determination that a defendant has accepted
+responsibility will be based primarily on
+pre-trial statements and conduct.
+In this case, Spurlock exercised his right
+acceptance of responsibility.
+to trial to preserve a challenge to the
+The majority omits a crucial circumapplicability of 18 U.S.C. $ 2242(b) to his
+stance from its opinion. Contemporaneconduct. Thus, the court should deterously with Spurlock's pre-trial proceedmine his acceptance of responsibility on his
+ings, two other defendants faced virtually
+pre-trial statements and conduct.
+the same charges in the same district (but
+The PSI report indicates that Spurlock's
+before a different judge) as Spurlock. See
+pretrial statements and conduct undoubt-
+United States v. Helder, 452 F.3d 751 (8th
+edly demonstrate his acceptance of respon-
+Cir.2006); United States v. Hicks, 457
+sibility. Following his arrest, Spurlock ad-
+F.3d 838 (8th Cir.2006). Based on an ar- mitted the wrongfulness of his conduct and
+gument that the statute under which they confessed to all relevant conduct. Spurwere charged, 18 U.S.C. § 2422(b), re- lock also consented to the search of his
+quired the presence of an actual minor, computer and to officers' assuming his onrather than an adult pretending to be a line presence for further investigation.
+minor, the district court granted those de- Throughout his pre-trial proceedings,
+fendants' respective motions for judgment Spurlock conceded that he had engaged in
+3. Spurlock unsuccessfully argued the issue in
+his own case.
+
+
+UTO-OWNERS INS. | TRIBAL COURT OF SPIRIT LAK
+1017
+Ite as 495 F.3d 1017 (8th Cir. 2007
+the wrongful conduct, but maintained that
+the statute did not apply to his conduct.
+Spurlock, although requesting a trial,
+waived his right to a jury trial and stipulated to some of the government's evidence, including chain of custody of the
+AUTO-OWNERS INSURANCE
+COMPANY, Plaintiff/Appellee,
+V.
+The TRIBAL COURT OF the SPIRIT
+computer files. At trial, he did not object
+to the admission of the government's exhibits and only cross-examined one of
+three government witnesses.
+True, Spurlock put the government to
+some burdens at trial by his general denial. But the applicable note explains that
+the "adjustment is not intended to apply to
+a defendant who puts the government to
+Education Board, Defendant/Appellant,
+its burden of proof at trial ..., is convicted, and only then admits guilt and ex-
+Four Winds High School, Defendant,
+presses remorse." U.S. SENTENCING GUIDE-
+LINES MANUAL § 8E1.1 emt. n. 2 (2004)
+Tate Topa Tribal School, also known
+(emphasis added). Spurlock did not withas Four Winds Elementary School,
+hold admission of guilt until the govern-
+Defendant/Appellant,
+ment had met its burden of proof. He had
+previously admitted his conduct, stipulated
+Vivian Lohnes, as Court-Appointed Custo evidence, and conveyed an appreciation
+todian and Guardian of her Minor
+for the wrongfulness of his conduct. The
+Granddaughter, Mary DeLorme, De-
+acceptance of responsibility reduction canfendant.
+not become solely a question of how much
+No. 06-3562.
+work the government was required to do;
+we must ultimately focus on whether the
+United States Court of Appeals,
+defendant himself exhibited responsibility
+Eighth Circuit.
+and remorse for his conduct, which Spur-
+Submitted: May 17, 2007.
+lock did.
+Filed: Aug. 1, 2007.
+Spurlock faced the special and rare cir- Background: Insurer filed declaratory
+cumstances of seeing two other defendants
+judgment action against insured Indian
+avoid conviction on similar facts because of
+a statute's potential inapplicability. There
+elementary school and education board,
+seeking determination of whether commeris little question that Spurlock only went to
+trial to preserve that issue. Accordingly, I cial general liability policy and commercial
+dissent from the majority in this respect umbrella policy covered alleged sexual asand would have vacated Spurlock's sen- sault of student. The United States Distence and remanded for re-sentencing with
+trict Court for the District of North Dako-
+a reduction for acceptance of responsibilita, Ralph R. Erickson, J., denied insured's
+ty.
+motion to dismiss and granted insurer
+summary judgment. Insured appealed.
+Holdings: The Court of Appeals, Smith,
+Circuit Judge, held that:
+(1) court lacked diversity jurisdiction;
+
+
+
+& (242!) & DA(2007)
+1. C U.S. . Bass, Slip Copy, 2007 WL 2416437,, D.N.J., August 20, 2007(Crim. No. 07-232 (SRC).)
+...defendant's motion for reconsideration of the Order dated April 5, 2007, which granted the motion of the United States to detain the defendant pending trial; and the Hon. Stanley R. Chesler
+having referred this motion to the Undersigned; and the Court ...
+...FN1. In support of his motion, the defendants argues that the Court should reconsider its April
+5, 2007 Order to detain him because its analysis was not consistent with 18 U.S.C. § 3142(f) and
+the dictates of United States...
+...commit an offense identified in Section 3142(f) if released and that such a finding is necessary
+to order pretrial detention. Second, and relatedly, he argues that Himler's rationale and its requirement that proof of such recidivism is necessary despite the amendments to the Bail Reform
+Act. Third, the defendant argues that the Court should reconsider its detention decision given the
+absence of any allegations that he used a firearm in a violent manner, the absence of current...
+2. C U.S. |. Music, Slip Copy, 2007 WL 2067057,, W.D.Ky., July 16, 2007(No. 1:07-CR-21-R.)
+...the Minor was not pregnant. A one (1) count indictment was issued charging that the Defendant
+violated 18 U.S.C. § 2423 ; Transportation in Interstate Commerce With Intent to Engage in
+Criminal Sexual Activity with a Minor. After the indictment, the Minor .../
+...a hearing was held before the Honorable Magistrate Judge E. Robert Goebel ("Judge Goebel"),
+for the purposes of arraignment and detention. At that hearing, the Court ultimately determined
+that the Defendant had rebutted the presumption against detention as there were conditions and
+combinations of conditions that would reasonably assure the appearance of the Defendant as well
+as ...
+3. н
+...a no-contact provision not only with the Minor, but also her family and any other minor females; total home detention except for supervised medical treatment or meetings with his attorney; electronic monitoring; travel restrictions (including turning in his passport); third...
+U.S. | Abdullahu, 488 F.Supp.2d 433, 2007 WL 1556837, , D.N.J., May 24, 2007(No. 07-2050
+(JS).)
+...Attorney, Camden, NJ, for United States of America. OPINION DENYING DEFENDANT'S
+MOTION FOR RELEASE ON BAIL AND IN SUPPORT OF DETENTION ORDER
+SCHNEIDER, United States Magistrate Judge. This matter is before the Court on the request of
+lefendant Agron Abdullahu (hereinafter "defendant") for a detention hearing pursuant to 1:
+U.S.C. § 3142(f) On May 14, 2007, defendant filed his "Motion for Release on Bail." [Doc. No
+Teasons to be discussed, the Cour denies detendad a Motion and and at May 17, 2007. For the
+...this Opinion will set forth the Court's written findings of fact and a written statement of the
+reasons for the detention. FN1. At the conclusion of the May 17, 2007 detention hearing this
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&rs=WLW8.02&. 2/20/2008
+
+
+
+& (242!) & DA(2007)
+Court ruled from the Bench and read into the record the sum and substance of this Opinion. This
+written Opinion formalizes the Court's ruling. A detention Order was entered on May 17, 2007.
+[Doc. No. 14]. Background On May 7, 2007, this Court signed a Complaint ...
+...5, appeared before this Court for an initial appearance on May 8, 2007. On that date an Order
+of Temporary Detention was entered and a detention hearing was scheduled for May 11, 2007.
+[Doc. No. 7]. On May 11, 2007, defendant's counsel requested and was granted an extension for
+the date of the detention hearing until May 17, 2007. Findings of Fact 2 FN2. All of the facts
+summarized herein were included in the government's proffer at the May 17, 2007 detention
+hearing which included the May 7, 2007 Complaint naming the defendant and the reports of Pretrial Services. The proffer also...
+4. C U.S. | Capozzoli, Slip Copy, 2007 WL 129037, , N.D.Ind., January 12, 2007(No. 2:06 CR 167.)
+...Adam Tavitas, Merrillville, IN, for Defendant. Philip Craig Benson U.S. Attorney's Office,
+Hammond, IN, for Plaintiff. OPINION AND ORDER OF DETENTION ANDREW P. RO-
+DOVICH, United States Magistrate Judge. At the August 22, 2006 initial appearance, the government requested that the defendant ...
+...August 25, 2006, committing the defendant to a United States Medical Center for Federal Prisoners for a mental evaluation. A detention hearing was conducted on December 21, 2006, and
+the court now makes the following findings of fact: 1. The defendant currently is charged in a
+one count indictment with a violation of 18 U.S.C. § 2422(b) If convicted, the defendant faces a
+mandatory minimum sentence of ten years imprisonment and a maximum sentence of life imprisonment. 2. At the detention hearing, the government proffered evidence to supplement the indictment and the prebond report. The defendant also proffered evidence based upon ...
+...brother, the defendant has problems following directions and could not have made the trip to
+Lafayette. Under 18 U.S.C. § 3142(e), a defendant may be detained as a danger to the community if he is charged with a crime of violence under Section 3142(f)(1)(A) The defendant is
+charged with using the internet to solicit sex with someone he believed to be a 13 year old girl in
+violation of 18 U.S.C. § 2422(b) If this constitutes a crime of violence, there is a rebuttable presumption in favor of detention. In United States | Munro, 394 F.3d 865 (10th Cir.2005), the
+defendant was charged with using the internet to solicit sex with a minor in violation of Section
+2422(b) along with carrying a firearm during a crime of violence in violation of 18 U.S.C. §
+924(c) The Court of Appeals concluded that the attempted sexual abuse of a minor was a crime
+of violence and upheld the Section 924(c) conviction. 394 F.3d at 870-871 See also United States
+I Abad, 350...
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prfl=HTMLE&rs=WLW8.02&.. 2/20/2008
+
+
+
+& (225!) & DA(2007)
+U.S.
+- Sabhnani, 493 F.3d 63, 2007 WL 1965536, , C.A.2 (N.Y.), July 06, 2007(Docket No.
+07-2567-cr.)
+…..illegal aliens. The United States District Court for the Eastern District of New York Thomas C.
+Plan I, ordered detends detained Detenders ap faled 3 Soling: The Court of Appeals
+...Bail 491l In Criminal Prosecutions 49 49 Proceedings to Admit to Bail 49 49(3) Evidence 49
+49(4) k. Presumptions and Burden of Proof. When charge against federal defendant does not
+Linger seatti, germen as rdond dens of ricady prepaiguanly assure defendants at-
+2. C
+...and that no condition or combination of conditions can be imposed reasonably to assure his required attendance. 18 U.S.C.A. § 3142(e) [2] 110 Criminal Law 110XXIV Review 110XXIV(O)
+Questions of Fact and Findings 110 1158 In General 110 1158(1) k. In General. In general, Court
+of Appeals reviews district court's order of detention for clear error. 18 U.S.C.A. § 3142(e) [3]
+49 Bail 4911 In Criminal Prosecutions 49 41 Right to Release on Bail 49 42 k. In General. 49...
+U.S. I. Megahed, 519 F.Supp.2d 1236, 2007 WL 3132418, 21 Fla. L. Weekly Fed. D 29,,
+M.D.Fla., October 25, 2007(No. 8:07-ct-342-T-23MAP.)
+...2) fact that defendant was not charged with offense enumerated in Bail Reform Act did not preclude his pre-trial detention. Motion granted. West Headnotes [1] 49 Bail 491l In Criminal Pro-
+...49 Proceedings to Admit to Bail 49 49(3) Evidence 49 49(3 1) k. In General. Bail Reform Act
+authorizes detention in any case in which court determines after due process hearing (1) by preponderance of evidence that no conditions of ...
+3. →
+...General. Fact that defendant was not charged with offense enumerated in Bail Reform Act did
+not preclude his pre-trial detention based on prospect of future crimes. 18 U.S.C.A. § 3142 Jay
+L. Hoffer , U.S. Attorney's Office, Tampa, FL, for Plaintiff...
+U.S. L
+, Slip Copy, 2007 WL 3028307,, W.D.N.C., October 15, 2007(No. 1:07 cr
+69-2.)
+...heard before the undersigned, pursuant to a motion filed by defendant's counsel on September
+25, 2007 entitled "Motion to Reconsider Detention Order" (# 225) and from the evidence offered
+by the defendant and the evidence offered by the Government and the arguments of counsel...
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&rs=WLW8.02&.. 2/20/2008
+
+
+
+& (225!) & DA(2007)
+detain the defendant. The written detention order filed in this matter is incorporated herein by
+reference as if fully set forth herein. On September 25, 2007 defendant's counsel filed a motion
+entitled "Motion to Reconsider Detention Order" (# 225). In the motion, defendant's counsel sets
+forth that the defendant has been completely cooperative with the Government and that the ...
+...position that the defendant did not personally initiate any attempts to obstruct justice and that
+the court's basis for the detention of the defendant no longer exists. Thomas Boggs, attorney for
+the defendant, presented a proffer of evidence to the court...
+4. C
+U.S. |. Comstock, 507 F.Supp.2d 522, 2007 WL 2588815,, E.D.N.C., September 07, 2007(Nos.
+5:06-HC-2195BR, 5:06-HC-2202BR, 5:06-HC-2205BR, 5:06-HC-2206BR, 5:06-HC-2212BR.)
+...U.S.C.A. § 4248 [3] 92 Constitutional Law 92VI Enforcement of Constitutional Provisions
+92VI(C) Determination of Constitutional Questions 92VI(C)3 Presumptions and Construction as
+to Constitutionality 92 990 k. In General. Statutes are presumed constitutional. [4] 92 Constitutional Law 92XX Separation...
+…..of "Receipt [by computer] of materials depicting a minor engaging in sexually explicit conduct" in violation of 18 U.S.C. § 2252(a)(2), and to one count of forfeiture. He was sentenced to
+a 37-month prison term to be followed by a ...
+...release based on his guilty plea to one count of possession of child pornography in violation of
+18 U.S.C. § 2252(a) (5)(B) and (b)(2) Matherly's term of imprisonment expired on 23 November
+2006, and he is currently confined at....
+5. C U.S. |. Bass, Slip Copy, 2007 WL 2416437, , D.N.J., August 20, 2007(Crim. No. 07-232 (SRC).)
+...defendant's motion for reconsideration of the Order dated April 5, 2007, which granted the motion of the United States to detain the defendant pending trial; and the Hon. Stanley R. Chesler
+having referred this motion to the Undersigned; and the Court ...
+.FN1. In support of his motion, the defendants argues that the Court should reconsider its April
+5, 2007 Order to detain him because its analysis was not consistent with 18 U.S.C. § 3142(f) and
+the dictates of United States...
+...commit an offense identified in Section 3142(f) if released and that such a finding is necessary
+to order pretrial detention. Second, and relatedly, he argues that Himler's rationale and its requirement that proof of such recidivism is necessary despite the amendments to the Bail Reform
+Act. Third, the defendant argues that the Court should reconsider its detention decision given the
+absence of any allegations that he used a firearm in a violent manner, the absence of current...
+6. C
+07.5.01 scs) berger, 498 F.Sup 2d 738, 2007 WIL 2230182, D.N., July 27, 2007(Mag. No.
+....No. 07-2077(JS). July 27, 2007. Background: Defendant, who was charged with receiving and
+distibuer, Child porates phy, regeside, hel than decendan 5 as dir ented to Bat Court Joel
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&rs=WLW8.02&... 2/20/2008
+
+
+
+& (225!) & DA(2007)
+... that he was not charged with physically abusing a minor and had agreed not to use or access a
+computer. Detention ordered. West Headnotes [1] 49 Bail 49I1 In Criminal Prosecutions 49 41
+Right to Release on Bail 49 42 5 k .../
+..Bail 4911 In Criminal Prosecutions 49 49 Proceedings to Admit to Bail 49 49(3) Evidence 49
+49(4) k. Presumptions and Burden of Proof. If the government moves for detention on the basis
+of danger to the community, it must prove that by clear and convincing evidence, but if government or court believes detention is appropriate because there is a risk of flight, that must be
+proved by a preponderance of the evidence. 18 U.S.C.A. § 3142(e) [3] 49 Bail 4911 In Criminal
+Prosecutions 49 49 Proceedings to Admit to Bail 49 49(3) Evidence 49 49(4) k. Presumptions
+and Burden of Proof. If probable cause exists to believe that defendant committed an offense listed under statute prohibiting certain activities relating to material involving the sexual exploitation of minors, rebuttable presumption exists that no condition or combination of conditions will
+reasonably assure the safety of any other person and the appearance of the person as required;
+once the rebuttable presumption is established, the burden is then placed on the defendant to
+produce countervailing evidence that forms a basis for his...
+7. - U.S. |. Johnson, Slip Copy, 2007 WL 1712541, , E.D.Mich., June 13, 2007(No. 07-CR-30292.)
+...13, 2007. Janet L. Parker U.S. Attorney's Office , Bay City, MI, for Plaintiff. DECISION AND
+ORDER DENYING GOVERNMENT'S MOTION TO DETAIN CHARLES E. BINDER, United
+States Magistrate Judge. The Government moves for detention pursuant to 18 U.S.C. § 3142,
+but questions whether the detention hearing should be heard in this district. The Bail Reform Act
+does not provide explicit guidance as to whether the detention hearing should be held in the district of arrest or in the charging district. In this case, the conduct charged ...
+...relevant information is available in this district, the Court finds that it is proper to consider the
+Government's motion to detain in this district. On the issue of detention, the Government initially asserts that the presumption in favor of detention applies. The relevant statute provides
+that, [s]ubject to rebuttal by the person, it shall be presumed that no condition or ...
+...maximum term of imprisonment of ten years or more is prescribed in an offense involving a
+minor victim under section 2252(a) (2) of this title. 18 U.S.C. § 3142(e) The Court finds that
+the Government is correct-the presumption does in fact apply. As a matter of law, the Indictment in this case, standing alone, suffices to establish probable...
+8. H
+U.S. |. Abdullahu, 488 F.Supp.2d 433, 2007 WL 1556837, , D.N.J., May 24, 2007(No. 07-2050
+(JS).)
+..Attorney, Camden, NJ, for United States of America. OPINION DENYING DEFENDANTS
+MOTION FOR RELEASE ON BAIL AND IN SUPPORT OF DETENTION ORDER
+reasons to be discuses, the our denies detendants Motion and end fla May 17, 2007. For the
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&rs=WLW8.02&.. 2/20/2008
+
+
+
+& (225!) & DA(2007)
+...this Opinion will set forth the Court's written findings of fact and a written statement of the
+reasons for the detention. FN1. At the conclusion of the May 17, 2007 detention hearing this
+Court ruled from the Bench and read into the record the sum and substance of this Opinion. This
+written Opinion formalizes the Court's ruling. A detention Order was entered on May 17, 2007.
+[Doc. No. 14]. Background On May 7, 2007, this Court signed a Complaint ...
+...5, appeared before this Court for an initial appearance on May 8, 2007. On that date an Order
+of Temporary Detention was entered and a detention hearing was scheduled for May 11, 2007.
+[Doc. No. 7]. On May 11, 2007, defendant's counsel requested and was granted an extension for
+the date of the detention hearing until May 17, 2007. Findings of Fact 2 FN2. All of the facts
+summarized herein were included in the government's proffer at the May 17, 2007 detention
+hearing which included the May 7, 2007 Complaint naming the defendant and the reports of Pretrial Services. The proffer also...
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&rs=WLW8.02&.. 2/20/2008
+
+
+
+* Westlaw.
+U.S. | Scott
+C.A.6 (Tenn.),1993.
+NOTICE: THIS IS AN UNPUBLISHED OPIN-
+ION.(The Court's decision is referenced in a "Table
+of Decisions Without Reported Opinions" appearing in the Federal Reporter. Use FI CTA6 Rule 28
+and FI CTA6 IOP 206 for rules regarding the citation of unpublished opinions.)
+United States Court of Appeals, Sixth Circuit.
+UNITED STATES of America, Plaintiff-Appellee,
+Robert D. SCOTT, Defendant-Appellant.
+No. 92-6435.
+July 26, 1993.
+On A lestrn District Sae Peness oi or
+Western
+District
+91-20037, Gibbons, J.
+W.D.Tenn.
+AFFIRMED.
+Before GUY and BATCHELDER, Circuit Judges,
+and MILES, Senior District Judge.***
+PER CURIAM.
+*1 Defendant, Robert Scott, appeals his conviction for interstate transportation of a female minor
+and other females for purposes of prostitution, interstate transportation of a minor with intent that
+she engage in sexual intercourse with him, and conspiracy. Scott contends that the Speedy Trial Act
+was violated both because of the time between his
+arrest and indictment and the time between indict-
+Robert Scott was a 26-year-old native of
+Toledo, Ohio, who, according to one of his acquaintances, worked as a pimp. In November of
+1990, Scott encountered Betty Frey, also a resident
+of Toledo, who told him that she was planning to
+run away. Frey was born on July 14, 1973, and was
+considered a minor on the day that she met Scott.
+Frey asked Scott to take her to a small town in
+Michigan, where she was going to "play it off with
+her mom." Presumably, Frey planned to call her
+mother long distance and tell her that she had run
+away simply to worry her. Scott complied with
+Frey's request and took her to Michigan. Once
+there, the couple went to a motel and had sexual inhim. We affirm.
+At some point, Scott suggested that Frey accompany him to Columbus, Ohio. She agreed, and
+ultimately the pair traveled to Columbus
+on
+November 16 with Jeanine Sheppard, Theresa
+Riebesehl, and codefendant Derek Maes. The group
+checked into a Columbus motel, where Scott and
+Frey again had sexual intercourse. Scott then told
+Frey that he did not have enough money for them to
+return to Toledo and he therefore needed a favor
+from her. Scott wanted her to make some money by
+prostituting herself, and he gave Frey condoms and
+sent her out with Sheppard and Riebesehl. The
+three all engaged in sexual intercourse for money,
+and upon her return to the motel Frey gave Scott all
+of the money she made. This was the first time Frey
+had ever engaged in prostitution.
+The group returned to Toledo the next day,
+where they stayed in an apartment with Maes and
+Betty Sims, Scott's live-in girlfriend. Throughout
+November and December of 1990, Scott sent Frey
+out on the streets of Toledo to engage in prostitution. Often, Frey was accompanied by Ruth DeBolt,
+Claudia Tinsley, and codefendant Kimberly Bull.
+Late in December of 1990, Scott, Frey, Bull,
+DeBolt, and Tinsley left Toledo in Scott's automobile destined for Memphis, Tennessee. Maes,
+I.
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F... 2/21/2008
+
+
+
+Sheppard, Riebesehl, Lisa Gonzales, and codefendant David Powers followed Scott in Maes' vehicle.
+According to the government, the purpose of this
+trip was for the females to make money by prostituting themselves. On the trip down, the cars would
+stop at rest areas and truck stops and the females
+would attempt to prostitute themselves to truck
+drivers and others. Near Elizabethtown, Kentucky,
+the caravan stopped for the night when Scott's car
+broke down. Scott, Maes, and Powers left the seven
+women at an Elizabethtown motel while they returned to Toledo to retrieve another vehicle. Prior
+to leaving for Toledo, however, Scott and Frey
+once again had sexual intercourse. While in Elizabethtown, DeBolt, Frey, and Tinsley went to a local
+tavern where DeBolt made $40 on a "date" with
+one of the men she met.
+*2 When the three men returned the next day,
+the two carloads departed Elizabethtown for Memphis, Tennessee. They registered at a Days Inn
+Motel in Memphis at 4:15 a.m. on January 2, 1991.
+A motel security guard assisted four of the women
+with their luggage. On an elevator going up to their
+rooms, the guard commented that if the elevator
+stuck at least he would have company. One of the
+women retorted,
+"Well, you couldn't afford it."
+Later, codefendant Bull asked the guard whether he
+would like a "date," and also inquired where the
+"hookers hang out" in Memphis.
+While in the motel in Memphis, codefendant
+Powers asked Frey to become his prostitute. As
+they were talking, Bull entered the room and she
+and Frey began to fight. Frey sustained scratches
+behind her ear and a bite mark on her arm from the
+scuffle. Scott also attacked Frey while the group
+was in Memphis, but this was not the first time that
+he had assaulted Frey. Scott's assault of Frey in
+Memphis was precipitated by Frey's request for bus
+money so she could return home to Toledo. After
+Scott denied her request, Frey called her mother
+and told her she had been beaten and needed money
+for a bus ticket home. Frey's mother then called
+Memphis police, who descended upon the Days
+Inn.
+One of the items obtained by police was a
+photo album that contained several pictures of the
+parties involved in this case. The album, which was
+transferred to the trunk of Maes' car in Elizabethtown, Kentucky, after Scott's car broke down, included nude photos of several of the individuals
+and photos of some of the individuals engaged in
+oral sex. Frey testified that many of the photos were
+taken at the Columbus, Ohio, motel where the
+group stayed in November, but several other photos
+were taken while the group traveled from Toledo to
+Memphis.
+Frey also testified that Scott had given her and
+the other women instructions about how to observe
+police vice officers. According to Frey, Scott had
+told them to look under the seat of customers' cars
+for a radio or a gun to "make sure they ain't vice."
+If the women found such items, they were to open
+the door of the car and flee.
+On February 12, 1991, a grand jury returned a
+10-count indictment against Scott and others in
+which Scott was named in eight of the counts. The
+charges against Scott included: (1) unlawful, knowing, and intentional transport of a minor in interstate commerce for purposes of prostitution in violation of 18 U.S.C. §§ 2422 and 2423; (2) knowing
+transport of a minor in interstate commerce with intent that she engage in sexual intercourse with Scott
+in violation of
+Tennessee Code Annotated §
+39-13-506 and 18 U.S.C. § 2423; (3) knowing persuasion of a minor to travel in interstate commerce
+for purposes of prostitution in violation of 18
+U.S.C. § 2422 ; (4) knowing interstate transport of
+II.
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F... 2/21/2008
+
+
+
+*3 Initially, Scott contends that he was neither
+indicted nor brought to trial within the time limit
+required by the Speedy Trial Act. The trial court
+found that any periods of delay in Scott's case were
+excludable under the Act. We agree.
+According to 18 U.S.C. § 3161(b), an indictment against a defendant must be filed within 30
+days from the date of the defendant's arrest. In this
+case, Scott was arrested on January 7, 1991. On
+January 29, the government moved for an extension
+of time to indict Scott because two witnesses that
+the government had subpoenaed failed to appear at
+a grand jury proceeding on that date. Pursuant to §
+3161(h)(3)(A), NI the district court granted the
+government an additional 30 days, commencing
+February 4, in which to obtain
+against Scott. The government did so on February
+12, well within the additional time given it by the
+district court. Thus, Scott was indicted in a timely
+manner, and the district court did not abuse its discretion in granting the government additional time
+to bring an indictment given the
+bsence of essential witnesses. Cf. United States| Cianciola, 920
+F.2d 1295, 1301 (6th Cir.1990) (analyzing Speedy
+Trial Act issues under an abuse of discretion standard), cert. denied,501 U.S. 1219, 111 S.Ct. 2830
+(1991). Moreover, Scott has failed to show that actual prejudice resulted from the 36-day period
+between his arrest on January 7 and his indictment
+on February 12. See United States | Monger, 879
+F.2d 218, 222 (6th Cir.), cert. denied,493 U.S. 997
+(1989) (requiring actual prejudice in order to obtain
+reversal of district court's decision to grant an excludable continuance of indictment or trial).
+The Speedy Trial Act also requires that a defendant be brought to trial within 70 days following
+his indictment or first appearance before the court,
+whichever is later. Cianciola, 920 F.2d at 1298
+(citation omitted). Scott and three codefendants
+were indicted on February 12, but the last defendant
+(David Powers) did not make an initial appearance
+in district court until April 3, 1991. No motion for
+severance had been granted, and the district court
+therefore determined that the 70-day period for
+commencement of trial began on that date. Seel8
+U.S.C. § 3161(h)(7) (providing for "[a] reasonable
+period of delay when the defendant is joined for trial with a codefendant as to whom the time for trial
+has not run and no motion for severance has been
+granted"). Scott's trial did not begin until October
+21, 1990, over six months later. He contends that
+this length of time violated the commands of the
+Speedy Trial Act.
+Between January and October 1991, approximately 45 pretrial motions were filed by the parties in
+this case. In rejecting Scott's motion to dismiss the
+indictment for violation of the Speedy Trial Act,
+the trial court considered several motions that
+provided a basis for excluding time. On April 11,
+for example, Scott's codefendant Kimberly Bull
+moved for new counsel. The trial court granted her
+motion, and new counsel was appointed on April
+25. This time was considered excludable pursuant
+to 18 U.S.C. § 3161(h)(1)(F), which provides for
+excludable delay "resulting from any pretrial motion, from the filing of the motion through the conclusion of the hearing on, or other prompt disposition of, such motion[.J" The case was then set for
+trial on June 17, but Bull's counsel moved for a
+continuance to prepare for trial, and the case was
+reset for July 22. This time was also excluded. Fi-
+nally, because at various times both the government
+and defense counsel moved for continuances due to
+their inability to locate material witnesses, the trial
+court moved the trial to October 21. This time was
+excluded pursuant to § 3161(h)(3)(A), which
+provides for excludable delay of any period
+"resulting from the absence or unavailability of the
+defendant or an essential witness."
+BESTI
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prf=HTMLE&fn=_top&mt=F... 2/21/2008
+
+
+
+cumstances constitute denial of right to speedy trial,
+but, absent evidence of intentional prosecutorial
+delay and actual prejudice to the defendant, right to
+speedy trial is not violated by delay while motions
+are pending), cert. denied464 U.S. 986 (1983). In
+addition, many of the pretrial motions that the trial
+court considered were brought by Scott or his codefendants. Given that the trial court properly computed exclusions from the 70-day speedy trial period, defendant was brought to trial within the time
+limits established by the Speedy Trial Act.
+Page 4
+II.
+Scott next contends that the trial court violated
+Federal Rules of Evidence 402 and 403 by allowing
+the admission of a photo album depicting Scott and
+several other individuals in various stages of undress and engaged in sexual activity. According to
+Scott, the pictures are not an element of any of the
+substantive crimes with which he is charged and are
+therefore irelevant. Further, because some of the
+photos portray interracial sex, Scott argues that they
+are unduly prejudicial and would tend "to inflame
+racial and religious prejudices the jurors may harbor."
+There is no question that this evidence has
+the relationship
+among the
+parties. Some of the photos also showed the physical abuse that Betty Frey received, thereby corroborating the government's theory that she had been
+controlled by Scott. Thus, the admission of the
+photo album would not violate Federal Rule of
+Evidence 402, because the pictures have at least
+some relevance to this case.
+The decision as to whether evidence is admissible under Rule 403 is left to the sound discretion of
+the trial court, and the value of the evidence must
+be substantially outweighed by its prejudicial charac3. United State i Castro, 90l F.2d 83, 88 Rule
+Cir. 1990). We review this exercise of discretion "in
+the light most favorable to its proponent, maximizing its probative value and minimizing its prejudicial effect." United States | Zipkin, 729 F.2d 384,
+389 (6th Cir.1984).
+The trial court reviewed carefully the evidence
+and found the photo album highly probative as to
+the relationship among the parties and as to their intent and purpose for travelling to Memphis. We
+agree. Although some of them were taken prior to
+the trip in question, the photos tend to establish that
+the parties knew one another intimately. That the
+pictures were in Scott's possession tends to establish that he exerted some control over the women.
+One of the photos also showed one of the women
+lying naked on a bed with money on her stomach.
+As the district court noted, such evidence is relevant to the question of whether the women traded
+sex for money.
+*5 Scott's claim of unfair prejudice is groundless. Several courts have upheld the admission of
+exually explicit photos in cases involving viola
+lons of the Mann Act. See, e.g., United States |
+Boyd, 610 F.2d 521 (8th Cir.1979), cert. denied,444
+U.S. 1089 (1980); United States | Harris, 534 F.2d
+207 (10th Cir.1975), cert. denied,429 U.S. 941
+(1976). Moreover, the trial court questioned prospective jurors about their ability to view graphic
+photographs, some of which involved interracial
+sexual activity. The interracial nature of this case
+was evident when witnesses testified, and the photos simply constituted more evidence of the relationships among the individuals involved. The trial
+court did not abuse its discretion in allowing the admission of the photo album.
+IV.
+Finally, Scott challenges the suficiency of the
+addition, Scott contends that the government should
+have been required to prove that Scott knew that
+Betty Frey was a minor when he transported her
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F... 2/21/2008
+
+
+
+across state lines. Alternatively, he suggests that his
+lack of knowledge as to Frey's age should have
+been an affirmative defense to the charges regarding his involvement with a minor.
+In reviewing the sufficiency of the evidence,
+we must view the evidence, and all reasonable inrences from the evidence, in the light maost favor
+le to the goverment. United States Gibso
+675 F.2d 825, 829 (6th Cir.), cert. denied,459 U.S.
+972 (1982). We must affirm the conviction if "any
+rational trier of fact could have found the essential
+elements of the crime beyond a reasonable doubt."
+Jackson L O
+To support a conviction under the Mann Act,
+courts have required that a dominant purpose of the
+interstate transportation
+must be unlawtul conduct
+See, e.g., United States | Prater, 518 F.2d 817, 819
+(7th Cir.1975) ("An intention that the women or
+girls shall engage in the conduct outlawed by [the
+Act] ... must be found to exist before the conclusion
+of the interstate journey and must be the dominant
+interstate movement.") (citations
+omitted). Scott argues that he and the others were
+travelling South to escape the cold Toledo winter.
+However, sufficient evidence existed to allow a
+reasonable juror to conclude otherwise. Scott and
+the others had travelled previously to Columbus,
+Ohio, to engage in acts of prostitution. In addition,
+testimony at trial established that many of the women solicited clients while at rest areas and truck
+stops. The "date" that DeBolt procured while the
+group was in Elizabethtown, Kentucky; the inquiries to the Memphis security guard about where the
+"hookers hang out" in Memphis; and the pictures
+contained in Scott's photo album all evinced Scott's
+intent to transport women across state lines to engage in prostitution.
+*6 Knowledge that a girl is under 18 years of
+age when transported interstate is not part of the
+proof required of the government in order to sustain
+Page 5
+a minor at the time of the interstate transportation
+by offering her testimony that she was born on July
+14, 1973, and the interstate transportation occurred
+in late 1990 and early January of 1991. The Mann
+act does not require more. See, e.g., United State:
+Hamilton, 456 F.2d 171, 173 (3d Cir.), ceri
+denied, 406 U.S. 947 (1972).
+Defendant argues that Hamilton and its progeny are wrongly decided, because it is unconstitutional to lessen the government's burden in these
+cases by not requiring the government to prove that
+the defendant knew of the victim's age. But, the legislature has wide latitude to declare what constitutes an offense against society and to define the
+elements that constitute such an offense. Cf.
+Whalen | United States, 445 U.S. 684, 689 (1980).
+It does not offend due process for Congress to draft
+a statute that does not require the prosecution to
+show that a defendant believed the victim to be under the age of 18 when she was transported interstate, because the law has traditionally afforded
+minited States anti lansoo, 942 F.2d 775, 77 (Set
+Cir.1991) (discussing 18 U.S.C. § 2241, which prohibits those in the maritime and territorial jurisdiction of the United States and in a federal prison
+from knowingly engaging in a sex act with another
+who has not attained the age of 12, and rejecting
+claim that due process requires government to
+prove defendant's intent because "from ancient
+times the law has afforded special protection to
+those deemed too young to understand the consequences of their actions"), cert. denied,502 U.S.
+1042, 112 S.Ct. 897 (1992).
+Similarly, the Constitution does not require that
+provided for scho a diense bea i en Cond ss
+U.S.C. § 2243, which criminalizes knowing engagement in a sexual act with another under the age
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F...
+
+
+
+• 999 F.2d 541
+of 16 by those in the maritime and territorial jurisdiction of the United States or in a federal prison.
+According to Scott, no rational basis exists for the
+distinction between the two statutes.
+Scott was convicted of transporting a minor in
+interstate commerce with the intent that she engage
+in prostitution. He was also convicted for knowingly transporting a minor in interstate commerce
+with the intent that the minor would engage in
+sexual intercourse with him. Both of these convictions rested upon 18 U.S.C. § 2423, which provides:
+Whoever knowingly transports any individual
+under the age of 18 years in interstate or foreign
+commerce, or in any Territory or Possession of the
+United States, with intent that such individual engage in prostitution, or in any sexual activity for
+which any person can be charged with a criminal
+offense, shall be fined under this title or imprisoned
+not more than ten years, or both.
+*7 Assuming, without deciding, that Scott is
+"similarly situated" to a defendant accused of statutory rape of a minor under the age of
+16 within the territorial or maritime jurisdiction of
+the United States, we find that a rational basis exists for allowing
+the defense of mistake in 18
+U.S.C. § 2243 and denying such a defense under
+the Mann Act. The latter Act criminalizes prostitution or other criminal sexual activity that involves
+interstate commerce. Thus, minors in particular will
+often be very far from their usual support systems
+when transported interstate, and it is rational for
+Congress to want to heighten protection of such
+minor victims by denying Mann Act defendants the
+defense of mistake. Moreover, the Equal Protection
+change in the late See eg. Railway Espress a
+change in the law. See, e.g..
+New York, 336 U.S. 106, 110 (1949) ("It is no requirement of equal protection that all evils of the
+Page 6
+are imperfect. If the classification has some
+'reasonable basis,' it does not offend the Constitution simply because the classification 'is not made
+with mathematical nicety or because in practice it
+results in some inequality:' " (citations omitted).
+Denying Scott the defense of mistake, then, does
+not violate the Constitution.
+AFFIRMED.
+FN* Honorable Wendell A. Miles, United
+States District Court for the Western District of Michigan, sitting by designation.
+FN1. That section provides in pertinent
+part as follows:
+The following periods of delay shall be excluded in computing the time within which an information or an indictment must be filed, or in
+computing the time within which the trial of any
+such offense must commence:
+(3)(A) Any period of delay resulting from the
+absence or unavailability of the defendant or an essential witness.
+18 U.S.C. § 3161(h).
+C.A.6 (Tenn.), 1993.
+U.S. I Scott
+merely because the classifications made by its laws
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=
+_top&mt=F... 2/21/2008
+
+
+
+Afirmed.
+U.S. | Clarke
+C.A.11 (Fla.),2005.
+This case was not selected for publication in the
+ederal Reporter. Please use FIND to look at the ap
+icable circuit court rule before citing this opiniot
+Eleventh Circuit Rule 36-2. (FIND CTA11 Rule
+36-2.)
+United States Court of Appeals, Eleventh Circuit.
+UNITED STATES of America, Plaintiff-Appellee,
+V.
+George CLARKE, Defendant-Appellant.
+No. 05-12303
+Non-Argument Calendar.
+D.C. Docket No. 04-20656-CR-CMA.
+Dec. 15, 2005.
+Background: Defendant was convicted in the
+United States District Court for the Southern District of Florida of attempting to obtain a minor to
+engage in a commercial sex act, attempting to travel
+in foreign commerce to engage in illicit sexual conduct with another person, and attempting to induce
+a minor to engage in prostitution, and he appealed.
+Holdings: The Court of Appeals held that:
+(1) in order to convict defendant of attempting
+to induce a minor to engage in prostitution, government was not required to prove that the prostitution
+in question was illegal country to which defendant
+intended to travel;
+(2) trial court did not abuse its discretion in refusing to instruct jury regarding defense of entrapment by estoppel;
+(3) trial court did not abuse its discretion in
+preventing defendant from making legal arguments
+in opening statement; and
+rod(e) miad coudadid non abuse ig desperi op i.
+hiatric testimony
+West Headnotes
+[1] Prostitution 315H €-19(1)
+315H Prostitution
+315Hk19 Federal Offenses
+gage in prostitution with a minor. 18 U.S.C.A. §
+2422(b).
+[2] Criminal Law 110 €-772(6)
+110 Criminal Law
+110XX Trial
+110XX(G) Instructions: Necessity, Requisites, and Sufficiency
+110k772 Elements and Incidents of Of-
+fense, and Defenses in General
+110k772(6) k. Defenses in General.
+Most Cited Cases
+In prosecution for attempting to travel in foreign
+commerce to engage in illicit sexual conduct and
+attempting to induce a minor to engage in prostitution, trial court did not abuse its discretion in refusing to instruct jury regarding defense of entrapment
+by estoppel; defendant did not allege that detective
+identified himself to defendant as law enforcement
+officer, defendant's reliance on statements made by
+13| Criminal Law 110 €-704
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F... 2/21/2008
+
+
+
+110 Criminal Law
+110XX Trial
+110XX(E) Arguments and Conduct of Counsel
+110k702 Scope and Effect of Opening
+Statement
+110k704 k. For Defense. Most Cited
+Cases
+Criminal Law 110 C-730(2)
+110 Criminal Law
+110XX Trial
+110XX(E) Arguments and Conduct of Counsel
+110k730 Action of Court
+110k730(2) k. Opening Statement.
+Most Cited Cases
+In prosecution for attempting to travel in foreign
+commerce to engage in illicit sexual conduct and
+attempting to induce a minor to engage in prostitution, trial court did not abuse its discretion in limiting defendant's opening statement to prevent defendant from making legal arguments; defendant repeatedly disregarded court's ruling regarding use of
+legal terms such as "substantial steps" in opening
+argument, forcing government to object at each instance, and rather than merely stating evidence that
+would come out at trial, defendant argued he was
+led to believe by undercover detective that Costa
+Rican government tested prostitutes for diseases.
+[4] Criminal Law 110 €-474
+110 Criminal Law
+110XVII Evidence
+110XVII(R) Opinion Evidence
+110k468 Subjects of Expert Testimony
+110k474 k. Mental Condition or Capacity. Most Cited Cases
+In prosecution for attempting to travel in foreign
+ommerce to engage in illicit sexual conduct an
+Itempting to induce a minor to engage in prostiti
+tion, proposed expert psychiatrie testimony describing witness's assessment of defendant's depression
+as an explanation that provided insight into motiva-
+tions behind his actions, but not as an excuse for
+those actions, failed to support a legally acceptable
+theory demonstrating a lack of mens rea by negating either knowledge or intent, and thus, trial court
+did not abuse its discretion in prohibiting defendant
+from presenting the expert testimony.
+*129 Anne R. Schultz, U.S. Attorney's Office,
+Miami, FL, for Plaintiff-Appellee.
+Milton Hirsch and David Oscar Marcus, Miami,
+FL, for Defendant-Appellant.
+Appeal from the United States District Court for the
+Southern District of Florida.
+Before BLACK, CARNES and PRYOR, Circuit
+Judges.
+PER CURIAM:
+**1 George Clarke appeals his convictions for
+attempting to obtain a minor to engage in a commercial sex act, 18 U.S.C. §§ 1591(a), 1594(a), attempting to travel in foreign commerce to engage in
+illicit sexual conduct with another person, 18
+U.S.C. § 2423(c), (e), and attempting to induce a
+minor to engage in prostitution, 18 U.S.C. §
+2422(b). Clarke asserts the district court erred in its
+(1) interpretation of 18 U.S.C. § 2422(b) when it
+denied Clarke's motion for judgment of acquittal,
+(2) refusal to instruct the jury on the defense of entrapment by estoppel, and (3) limitation of Clarke's
+opening statement and prohibition of expert psychiatric testimony. The district court did not err, and
+we affirm Clarke's convictions.
+I. DISCUSSION
+A. Statutory interpretation of 18 U.S.C. § 2242(b)
+[1] Clarke asserts his conviction for persuading
+a minor to engage in prostitution "cannot stand," as
+he was neither charged with, nor could he have
+been convicted of, "engag[ing] in any sexual activity (including prostitution) for which any *130 person can be charged with a crime." According to
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F...
+
+
+
+Clarke, § 2422(b), as written, only makes it a crime
+to induce a minor to engage in any sexual activity if
+that sexual activity is criminal. Clarke claims the
+statutory construction, specifically, the lack of a
+comma following the word "prostitution,
+the phrase "for which any person can be charged
+with a criminal offense"
+must be read to modify
+the prior phrase "prostitution or any sexual activity." Clarke further asserts based upon this statutory
+construction of § 2422(b) that Congress only intended to punish a person for engaging in
+prostitution" overseas, but "not all forms of prostitution." Moreover, Clarke argues, although Congress has the power to criminalize the conduct of a
+U.S. citizen who engages in conduct in a foreign
+country that is deemed legal in that country, Congress only criminalized
+"engaging in underage
+prostitution as defined and proscribed by the law of
+the jurisdiction in which the act of prostitution occurs. " Accordingly, Clarke argues, the prosecution
+was required to, but did not, present evidence the
+type of prostitution in which he intended to engage
+was "the sort of prostitution for which any person
+can be charged with a crime in Costa Rica."
+"The interpretation of a statute is a question ‹
+law subject to de novo review." United States
+Murrell, 368 F.3d 1283, 1285 (11th Cir.), cert.
+denied,543 U.S. 960, 125 S.Ct. 439, 160 L.Ed.2d
+324 (2004) (citation omitted). Subsection (b) of §
+2422 states:
+Whoever, using the mail or any facility or
+means of interstate or foreign commerce ... knowingly persuades, induces, entices, or coerces any individual who has not attained the age of 18 years,
+to engage in prostitution or any sexual activity for
+which any person can be charged with a criminal
+offense, or attempts to do so, shall be fined under
+this nite had in pesoned not less than 5 years and
+ity." Moreover, prostitution is a form of sexual
+activity, and Clarke's reading results in the term
+"prostitution" being superfluous, which must be
+avoided. United States | Ballinger, 395 F.3d 1218
+1236 (11th Cir.) (en banc) (noting it is a cardinal
+principle of statutory construction that a statute
+must be construed such that no clause, sentence, or
+word shall be superfluous, void, or insignificant),
+• denied,.-- U.S. ...., 126 S.Ct. 368, 163
+L.Ed.2d 77 (2005). Finally, even if Clarke were
+correct that the Government was required to show
+the prostitution in question is illegal in Costa Rica,
+both Agent Patterson and Detective Love testified it
+is illegal to engage in prostitution with a minor in
+Costa Rica. Accordingly, the district court did not
+err in its interpretation of § 2422(b).
+modify both "prostitution" and "any sexual activ-
+B. Jury instruction on entrapment by estoppel
+[2] Clarke next contends the district court erred
+by failing to give an entrapment by estoppel instruction to the jury, as he provided sufficient evidence for the matter to go to the jury. Clarke contends whether he knew Detective Richard Love was
+acting on behalf of the Federal Bureau of Investigation is irrelevant, as the defense of entrapment by
+estoppel focuses on the conduct of government officials, rather than on the defendant's state of mind
+Clarke explains "law enforcement may not benefit
+from its own wrongful act," whereby a citizen is
+prosecuted for engaging in criminal conduct that
+law enforcement counseled him to undertake.
+Clarke asserts his reliance on Detective *131 Love
+was reasonable, especially since Detective Love
+held himself out to be "a very experienced, qualified, law-abiding purveyor of
+Moreover, Clarke argues, he was assured by De-
+tective Love the prostitutes were required to be
+tested for diseases once a month, and Detective
+Love "acknowledged that the logical and ordinary
+inference from his representation .. was that it was
+the government of Costa Rica that imposed such a
+requirement." Clarke further argues both Detective
+Love and the website assured him the sexual activities being offered were "safe" and "secure." Ac-
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=
+_top&mt=F...
+
+
+
+cording to Clarke, the representations of Detective
+Love and the website "told a single, consistent, coherent story: the sex tourism being offered to [him]
+was legal."
+iewed for an abuse of discretion. United States
+Trujillo, 146 F.3d 838, 846 (11th Cir.1998). "The
+trial court has authority to refuse to instruct the jury
+on a defense where the evidence used to support it,
+if believed, fails to establish a legally cognizable
+lefense." United States • Billue. 994 F.2d 1562.
+1568 (11th. Cir.1993). To assert the defense of entrapment by estoppel, a defendant must * *actually
+rely on a point of law misrepresented by an official
+of the state; and such reliance must be objectively
+reasonable-given the identity
+of the official, the
+point of law represented, and the suntance of the
+misrepresentation." " United States |
+Eaton, 179
+F.3d 1328, 1332 (11th Cir.1999) (citation omitted).
+"The defense "focuses on the conduct of the Government officials, not on the state of mind of the
+defendant.' "* Id. (citation omitted).
+**3 Clarke does not allege Detective Love ever
+identified himself to Clarke as a law enforcement
+officer. Clarke knew Detective Love as his alias,
+Richard Baxter, the owner of CRTV, who provided
+a travel
+service whereby clients were connected
+with
+prostitutes in Costa Rica.
+Accordingly,
+Clarke's reliance on statements made by Detective
+Love, in the guise of Richard Baxter, was objectively unreasonable,
+as a reasonable person would
+not rely upon a pimp for legal guidance. See id.
+Moreover, Clarke points to no statements in the record where he either asked Detective Love about
+the legality of the services provided by CRTV or
+was doing was not
+"kosher," and Clarke responded he "knew that" and
+figured as much. Contrary to Clarke's contentions,
+e terms "secure" and "safe" are not synonymor
+ith "legal." Moreover, Detective Love's stat
+Page 4
+does not indicate such behavior was legal. Furthermore, as the district court noted, the only
+"afirmative statement" made by Detective Love,
+that the prostitutes were required to be tested
+monthly for disease, was subsequently followed in
+the conversation by Detective Love's statement to
+Clarke that the conduct in which he intended to engage was not kosher. Accordingly, the district court
+did not abuse its discretion by refusing to instruct
+the jury regarding the defense of entrapment by estoppel.
+C. Fair trial
+Finally, Clarke asserts the "cumulative effect
+of adverse evidentiary and procedural rulings by the
+trial court deprived [him] of a fair trial under the
+5th and 6th Amendments." According to Clarke,
+the district court "unfairly limited" his opening
+statement by (1) excluding the board he intended to
+use a visual aid, and (2) sustaining objections by
+the Government when he stated the evidence would
+show he had not taken any "substantial steps" and
+law enforcement officers led him to *132 believe
+the Costa Rican government tested the prostitutes
+for diseases. Clarke contends as a result he was prevented from "laying two essential building blocks"
+of his defense, that the evidence would show (1) he
+had not taken the "substantial step" to distinguish
+his "non-criminal" conduct from criminal attempt,
+and (2) law enforcement officers led him to believe
+the conduct he was planning was "not proscribed by
+criminal sanctions." Clarke further contends he was
+prevented from presenting testimony, which
+ported his defense, by Dr. Haber, who would have
+testified Clarke (1) was not a pedophile, (2) was not
+We review for an abuse of discretion Clarke's
+claim the district court improperly limited his opening statement. See United States | Burns, 298 F.3d
+523, 543 (6th Cir.2002) (stating a district judge's
+conduct of a trial, including opening statements, is
+reviewed for an abuse of discretion). "A district
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F...
+
+
+
+court's decision regarding the admissibility of psychiatric evidence is generally subject to the abus
+of discretion standard of review." United States l.
+Westcott, 83 F.3d 1354, 1357 (11th Cir.1996).
+**4 An opening statement gives counsel the
+opportunity to state what evidence will be presented
+in order to make it casier for the jurors to undertand what is to follow, and is pot an occasion fo
+rgument. See United States Zielie, 734 F.2c
+1447, 1455 (11th Cir.1984)
+abrogated on other
+grounds by United States Chestang, 849 F.2d
+528, 531 (11th Cir.1988). "The scope and extent of
+ne defendants opening statement rests argely M
+he discretion of the trial court." United States
+Freeman, 514 F.2d 1184, 1192 (10th Cir.1975).
+The court "can exclude irelevant facts and stop argument if it occurs." Zielie, 734 F.2d at 1455.
+The Insanity Defense Reform Act provides:
+It is an affirmative defense to a prosecution
+under any Federal statute that, at the time of the
+commission of the acts constituting the offense, the
+defendant, as a result of a severe mental disease or
+defect, was unable to appreciate the nature and
+quality or the wrongfulness of his acts. Mental disease or defect does not otherwise constitute a de-
+Page 5
+18 U.S.C. § 17(a). When evaluating the admissibility of psychiatric evidence, courts
+consider the following principles: (1) "[p]sychiatric
+evidence of impaired volitional control or inability
+to reflect on the ultimate consequences of one's
+conduct is inadmissible whether offered to support
+an insanity defense or for any other purpose;" (2)
+"Congress intended to insure that the insanity defense is not improperly resurrected in the guise of
+showing some other affirmative defense such as
+that the defendant had a 'diminished responsibility"
+or some similarly asserted state of mind which
+would serve to excuse the offense;"
+"Congress was concerned about the danger that expert psychiatric testimony regarding inherently malcable psychological concepts can be misused at t
+I to mislead or confuse the iurv." United States
+Cameron, 907 F.2d 1051, 1061-62 (11th Cir.1990)
+(internal quotation and citation omitted) (emphasis
+in original). "Evidence offered as 'psychiatric evidto negate specific intent' is admissible,
+however, when such evidence focuses on the defendant's specific state of mind at the time of the
+charged offense." Id. at 1067. "Because psychiatric
+evidence (1) will only rarely negate specific intent,
+(2) presents an inherent danger that it will distract
+the jury[ ] from focusing on the actual presence or
+absence of mens rea,*133 and (3) may easily slide
+into wider usage that opens up the jury to theories
+of defense more akin to justification, district courts
+must examine such psychiatric evidence carefully
+to ascertain whether it would, if believed, support a
+legally acceptable theory of lack of mens rea." Id.
+(internal quotations and citation omitted).
+As an initial matter, Clarke failed to include the
+board he intended to use as a visual aid in the reord on appeal, as required by Federal Rule of Ap
+ellate Procedure 10(b)(2). See Fernandez |
+United States, 941 F.2d 1488, 1493 (11th Cir.1991)
+(holding the appellant is responsible for ensuring
+all documents buttressing his claims appear in the
+record). Consequently, we are unable to determine
+whether the district court abused its discretion by
+determining Clarke could display only the left-hand
+side during his opening statement.
+**5 [3] Prior to Clarke's opening statement, the
+court ruled he was prohibited from making legal argument in his opening statement. Clarke, however,
+repeatedly disregarded the court's ruling regarding
+the use of legal terms such as "substantial steps,"
+using such language and forcing the Government to
+object at each instance. In addition, rather than
+merely stating the evidence that would come out at
+trial regarding Detective Love's telling him the
+prostitutes were required to be tested, Clarke argued he was led to believe the Costa Rican government tested the prostitutes for diseases. Contrary to
+Clarke's contentions, he did not have a right to
+make legal arguments in his opening statement. See
+Zielie, 734 F.2d at 1455. Moreover, a court is per-
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F...
+
+
+
+mitted to stop a party from arguing during its opening statement, as occurred in the present case. See
+id. Accordingly, the district court did not abuse its
+discretion by prohibiting Clarke from making legal
+arguments during his opening statement.
+[4] Clarke also claims the district court abused
+its discretion by prohibiting expert psychiatric testimony. At the hearing, Dr. Haber testified Clarke intended to take the actions necessary to travel to
+Costa Rica, and knew what he was "signing up for
+was not legal." Dr. Haber also testified Clarke was
+conscious of his actions, had the capacity for selfreflection over the course of the telephone conversations, and had "a requisite understanding of his
+actions and their consequences." Dr. Haber described her assessment of Clarke's depression as an
+explanation that provided insight into
+the motivations behind his actions, but was not an excuse for
+those actions. Accordingly, even if believed, Dr.
+Haber's testimony failed to support a legally acceptable theory demonstrating a lack of mens rea, but,
+on the contrary, as she stated, only served to explain Clarke's actions, rather than negate either the
+knowledge or intent behind those actions. See
+Cameron, 907 F.2d at 1067. Consequently, the district court did not abuse its discretion in prohibiting
+from presenting expert psychiatric testimony.
+Page 6
+(Fla.))
+II. CONCLUSION
+The district court did not err in its interpretation of 18 U.S.C. § 2422(b). Additionally, the district court did not abuse its discretion when it refused to instruct the jury on the defense of entrap-
+AFFIRMED.
+C.A.11 (Fla.),2005.
+U.S. [. Clarke
+159 Fed.Appx. 128, 2005 WL 3438434 (C.A.11
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=F... 2/21/2008
+
+
+
+--- F.3d---., 2008 WL 581218 (C.A.11 (Fla.))
+UNITED STATES OF AMERICA, Plaintiff-Ap-
+pellee, . DONALD J. DEVERSO, Defendant-Ap-
+pellant.
+C.A.11,2008.
+UNITED STATES OF AMERICA, Plaintiff-Ap-
+pellee,
+V.
+DONALD J. DEVERSO, Defendant-Appellant.
+No. 06-16048 D.C. Docket No. 05-00034 CR-
+FTM-29-SPC
+United States Court of Appeals, Eleventh Circuit.
+(March 5, 2008)
+Appeal from the United States District Court for the
+Middle District of Florida
+Before DUBINA and KRAVITCH, Circuit Judges,
+and GOLDBERG,* Judge.
+DUBINA, Circuit Judge:DUBINA, Circuit Judge:
+Appellant Donald J. Deverso ("Deverso") appeals his convictions for possessing materials involving a depiction of a minor engaged in sexually
+explicit activity, in violation of
+18 U.S.C. §
+2252(a)(4)(B) and (b)(2) (Count One); transporting
+materials involving a depiction of a minor engaged
+in sexually explicit activity, in violation of 18
+U.S.C. § 2252(a)(1) and (b)(1) (Count Two; FNI
+and using a minor to engage in sexually explicit
+conduct outside of the United States for the purpose
+of producing a visual depiction of such conduct and
+transporting that visual depiction into the United
+States, in violation of 18 U.S.C. § 2251(c)(2)(B)
+and (e) (Count Three). Deverso's appeal presents
+three issues for review, two of which present novel
+questions concerning the authenticity of foreign
+public documents under Federal Rule of Evidence
+902(3) and a mistake of age defense under 18
+U.S.C. § 2251(c). After reviewing the record, reading the parties' briefs, and having the benefit of oral
+argument, we conclude that the Government properly authenticated the foreign document it admitted
+nto evidence, and Count Three does not contain :
+revers sementis to age. Accordingly, we affi
+I. BACKGROUND
+("Mrs.Deverso"). Mrs. Deverso turned over to investigators various computer media and printouts
+that she surreptitiously obtained from Deverso. De-
+verso was in some of the pictures that depicted
+young girls in various stages of undress. Investigators discovered that one of the girls in the pictures
+was Beverly Datanagan ("Beverly").
+During a subsequent search of Deverso's residence pursuant to a valid search warrant, investigators found compact and floppy disks, computer components, and a computer. Deverso originally set up
+his computer in a small room or closet that the family used for a nursery. It was the only computer
+with internet access, and Deverso's account was the
+only account that was password protected. Investigators reviewed the compact disks seized from De-
+verso's residence and discovered two disks, entitled
+MM Texas and Asians 7, that contained child pornography. One of the investigators testified that he
+had seen some of the images on the compact disks
+in other child pornography investigations.
+One of Deverso's fellow inmates, Michael
+Lewis ("Lewis"), testified that Deverso admitted
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=Fe... 3/6/2008
+
+
+
+--- F.3d-.--
+--- F.3d ---, 2008 WL 581218 (C.A.11 (Fla.))
+(Cite as: - F.3d --)
+was living with Deverso at the time of the search.
+Lewis testified that Deverso commented to him
+"that we all have a little pedophile in us." (R.
+Vol.6, p. 429.)
+Investigators also testified that they found
+Beverly's name on the back of one of the digital images and discovered romantic email chats between
+Deverso and Beverly. Under Deverso's account and
+in a folder titled Bev, investigators found pictures
+of Beverly, some of which were sexually explicit.
+Deverso allegedly took these pictures between Oc-
+tober 15 and 17, 2004.
+Dante Orate ("Orate"), Special Agent with
+DHS in Manila, testified that he personally met
+with Beverly after authorities helped him locate
+her. Beverly brought a birth certificate for Orate to
+review. Orate requested a copy of the birth certificate from the National Census and Statistics Office
+and had it certified at the U.S. Embassy. Orate
+stated that the copy of the birth certificate was exactly the same as the birth certificate Beverly
+showed him at their meeting. The date of birth on
+the copy of the birth certificate was November 10,
+1986. The Government proffered the document as
+evidence that Beverly was a minor at the time De-
+verso had sex with her, and Deverso objected on
+the grounds that the document was an incomplete
+document because it did not have a signature under
+the heading "Certificate of Attendant at Birth." (R.
+Vol.6, p. 322.)
+Beverly testified that her date of birth was
+November 10, 1986, and she was 17 when she met
+Deverso in October 2004. She stated that she had
+sex with Deverso when she was 17,
+and she told
+Deverso that she was 17. She also testified that De-
+verso sent her money for her 18th birthday.
+After the Government concluded its case-
+n-chief, Deverso moved for judgments of acquitta
+on all counts and moved for dismissal of Coun
+Two, arguing that it was unconstitutional facially
+and as-applied. The district court denied the motions.
+Deverso took the stand and denied having sex
+with Beverly in October 2004. Deverso also stated
+that Beverly did not tell him that she was 17; instead, Beverly represented herself to be 18 or 19.
+Deverso testified that the hotel clerk did not inquire
+about Beverly's age when they registered, and no
+one questioned her age when they purchased alcoholic drinks. Deverso stated that he sent Beverly
+money for her 19th, not 18th, birthday. Deverso
+also denied telling his fellow inmate anything about
+his travels or having sex with minors. He commented that his testimony was the truth.
+During the charge conference, Deverso objected to an instruction that "the defendant's awareness
+of the age of the minor is not an element of the of
+and that mistake of age is not a defense to
+Count Three. Instead, Deverso requested that the
+district court instruct the jury that mistake of age is,
+in fact, an affirmative defense to Count Three. The
+Government responded that the instruction was a
+correct statement of the law. The district court concluded that because knowledge of age is not an element of 18 U.S.C. § 2251, mistake of age is not a
+defense.
+The jury found Deverso guilty on all counts.
+The district court sentenced him to concurrent
+terms of 120 months imprisonment on Count One
+and 195 months imprisonment on Counts Two and
+Three. Deverso filed a timely notice of appeal.
+I. ISSUES
+1. Whether the district court erred in admitting
+a certified copy of a birth certificate as a foreign
+public document pursuant to Federal Rule of Evidence 902(3).
+ion in Whething to district thur abused is die o-
+age on Count Three
+Dever is thetah for ict count of a in deny ong
+Count One.
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=Fe... 3/6/2008
+
+
+
+-- F.3d -..., 2008 WL 581218 (C.A.11 (Fla.))
+III. STANDARDS OF REVIEW
+the defendant fails to object at trial to the admission
+of evidence, the court reviews the district court's
+ruling for plain error only. United States | Baker,
+432 F.3d 1189, 1202 (11th Cir.2005). "Where an
+appellant has objected to a jury instruction at trial,
+we review the court's decision to use that_instruction for abuse of discretion." United States | Dean,
+487 F.3d 840, 847 (11th Cir.2007), petition for cert.
+filed, 76 U.S.L.W. 3240 (U.S. Oct. 25, 2007) (No.
+07-553). "We review a district court's decision to
+deny a motion for judgment of acquittal based on
+" United States
+1 Dicieio, of tre cl izer, de n (vo." Cizd Sa. es
+determining whether the Government presented
+sufficient evidence, the court
+evidence in the light most favorable to the
+[G]overnment and draw all reasonable factual inferences in favor of the jury's verdict." Id.
+IV. DISCUSSION
+A. Admission of the birth certificate
+Deverso argues that the district court erred in
+admitting a copy of Beverly's birth certificate into
+evidence to establish that Beverly was under the
+age of 18 at the time of the alleged sexual encounter. First, he claims that the birth certificate is
+a business record, and the Government did not lay a
+proper foundation for its admission. See28 U.S.C. §
+1732 (governing admission of business records into
+evidence). Second, Deverso contends that the Government did not authenticate the birth certificate,
+and the document did not bear the required indicia
+of reliability. He claims that while the birth certificate may have been attested to by an appropriate individual listed in Federal Rule of Evidence 902(3),
+the document itself does not contain the minimum
+information to appear valid on its face. Deverso
+questions the authenticity of the document because
+the certificate states that it certifies that "Beverly
+Regidor Datanagan who was allegedly born on
+November 10, 1986 ... appears in the National In-
+dices for birth." (R. Exhibit No. 5.) Thus, Deverso
+argues that the document is not what the Government claims it to be-a birth certificate-but is, instead, a document containing an "alleged" date of
+A review of the record indicates that Deverso
+objected to the admission of the document on the
+grounds that what purports to be a copy of the original or certified copy of the original does not have
+a signature under the heading "Certificate of At-
+tendant at Birth." Specifically, he claimed that it
+was an incomplete document. (R. Vol.6, p. 322.)
+This trial objection is different than the objections
+Deverso proffers on appeal. Consequently, to obain relief, Deverso must demonstrate plain erro
+warranting relief. See United States Cotton, 53
+U.S. 625, 631-32, 122 S.Ct. 1781, 1785 (2002)
+('[BJefore an appellate court can correct an error
+not raised at trial, there must be (1) error, (2) that is
+plain, and (3) that affect[s] substantial rights ...
+[and] (4) ... seriously affect[s] the fairess, integrity, or public reputation of judicial proceedings."(quoting Johnson
+United States, 520 U.S.
+461, 466-67, 117 S.Ct. [544, 1549 (1997) (internal
+citations and quotation marks omitted)).
+The Government admitted the document as a
+foreign public document pursuant to Federal Rule
+of Evidence 902(3). This rule provides, in part, that
+Extrinsic evidence of authenticity as a condition precedent to admissibility is not required with
+respect to ... (3) Foreign public documents. A
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prfl=HTMLE&fn=_top&mt=Fe... 3/6/2008
+
+
+
+--- F.3d -..., 2008 WL 581218 (C.A.11 (Fla.))
+chain of certificates of genuineness of signature and
+official position relating to the execution or attestation. A final certification may be made by a secretary of an embassy or legation, consul general, consul, vice consul, or consular agent of the United
+States, or a diplomatic or consular official of the
+foreign country assigned or accredited to the United
+States. If reasonable opportunity has been given to
+all parties to investigate the authenticity and accur-
+Page 4
+sumptively authentic without final certification or
+permit them to be evidenced by an attested summary with or without final certification.
+FED. R. EVID. 902(3).
+There is no requirement in Rule 902(3) that the
+document itself be signed. See United States |
+Squillacote, 221 F.3d 542, 562 (4th Cir.2000). "The
+rules are written in the alternative-foreign documents may be authenticated by a certification from
+the official executing the document or by an official attesting to the document." Id.
+There are two requirements for the authentication of a foreign document. "First, there must be
+some indication that the document is what is purports to be. Thus, the proffered document must be
+executed by a proper official in his official capacity, or the genuineness of the document must be
+aites idio se apo petred sates bole, 130 asd
+523, 545 (2d Cir.1997) (noting that the rule is not
+concerned with establishing the truth of information
+contained in the proffered document but, instead, is
+concerned only with "assuring that evidence is what
+it purports to be"). "Second, there must be some indication that the official vouching for the document
+is who he purports to be." Squillacote, 221 F.3d at
+562. Accordingly, "the rules require that one of a
+specified group of foreign officials must issue a final certification attesting to the genuineness of signature and title of the person executing or attesting
+to the document, or of another official who has certified the signature and position of the person executing or attesting to the document." Id.
+The Government met these requirements here.
+The Government established that Agent Orate requested and obtained a copy of Beverly's birth certificate from the Philippine National Census and
+Statistics Office and that he had the copy authenticated and certified at the United States Embassy in
+Manila. The copy of Beverly's birth certificate was
+accompanied by a certificate from Richard Ambrad,
+Embassy Coordinator with the Government of the
+Philippines, attesting that the copy of Beverly's
+birth certificate was a true copy of an official record authorized by the law of the Philippines to be
+reported and recorded in the National Census and
+Statistics Office. That certification was accompanied by a final certification by Kimberly A. Russell,
+Vice Consul of the United States in the Philippines.
+Additionally, the copy of the birth certificate was
+stamped as a certified copy and affixed with the
+seal of Luzviminda N. Cruz, whom Vice Consul
+Russell certified was "Clerk II, National Statistics
+Office, Quezon City, Republic of the Philippines."
+Because the Government met the requirements for
+self-authentication of the foreign document, it did
+not have to lay a foundation for admission of the
+document as a business record. SeeFED.R.EVID.
+902, advisory committee note to para. (3) (stating
+that this paragraph "provides a method for extending the presumption of authenticity to foreign official documents by a procedure of certification").
+Furthermore, to the extent that Deverso challenges the reliability of the information contained
+in the birth certificate, such as Beverly's date of
+birth and the lack of signature of the attendant at
+birth, that challenge goes to the weight of the evid-
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prfi=HTMLE&fn=_top&mt=Fe... 3/6/2008
+
+
+
+-- F.3d -...
+-.- F.3d -.., 2008 WL 581218 (C.A.11 (Fla.))
+(Cite as: --- F.3d *--)
+certified copy of the birth certificate was identical
+to the birth certificate that Beverly showed him
+upon request. Consequently, Deverso cannot show
+error, let alone plain error, warranting a new trial
+due to the district court's admission of the birth certificate into evidence.
+B. Mistake of age jury instruction
+Deverso claims that the district court erred by
+refusing to give his mistake of age instruction as to
+Count Three. Deverso contends that knowledge of
+age is constitutionally mandated and because the
+Government charged that he did "knowingly" employ, use, persuade, entice, or coerce a minor to engage in sexually explicit conduct outside of the
+United States for the purpose of producing a visual
+depiction of such conduct, he could raise mistake of
+age as a defense. The Government responds that the
+district court properly refused to give a mistake of
+age instruction. We agree.
+Pursuant to 18 U.S.C. § 2251(c)(1),
+[a]ny person who, in a circumstance described
+in paragraph (2), employs, uses, persuades, induces,
+entices, or coerces any minor to engage in, or who
+has a minor assist any other person to engage in,
+any sexually explicit conduct outside of the United
+States, its territories or possessions, for the purpose
+of producing any visual depiction of such conduct,
+shall be punished as provided under subsection (e).
+Id.
+Subsection (2) states that the circumstance referred to in paragraph (1) is that -
+(A) the person intends such visual depiction to
+be transported to the United States, its territories or
+possessions, by any means, including by computer
+or mail; or
+(B) the person transports such visual depiction
+to the United States, its territories or possessions,
+by any means, including by computer or mail.
+18 U.S.C. § 2251(c)(2). The statute sets the age
+of majority at 18. 18 U.S.C. § 2256(1).
+Page 5
+Deverso first contends that he was entitled to a
+mistake of age defense jury instruction because
+knowledge of age is an element of the offense under § 2251. We disagree and hold that knowledge
+sraes i notaemen Video, Inc, Ti U.S. 64, 768
+n.5, 115 S.Ct. 464 (1994) (concluding, although in
+dicta, that a mistake of age defense to 18 U.S.C. §
+2251 is not constitutionally mandated and citing a
+Senate Conference Committee Report explaining
+that the deletion of the word "knowingly" from §
+251 reflected an intent to eliminate knowledge q
+ge as an element of the crime): United States 1
+Griffith, 284 F.3d 338, 349 (2d Cir.2002) (rejecting
+defendants' argument that the district court's charge
+to the jury omitting scienter of age under § 2251
+was erroneous); United States | Johnson, 376 F.3d
+689, 693 (7th Cir.2004) (finding that because defendant was charged with the attempt to manufacture child pornography, the Government had to
+prove knowledge of the minor's age; however, commenting that if the defendant were charged with the
+commission of the completed offense under § 2251,
+the Government would not have to prove u.s.
+ledge of the minor's age); United States |
+Dist. Ct., 858 F.2d 534, 538-41 (9th Cir.1988)
+(acknowledging that scienter as to age is not an element of 18 U.S.C. § 2251); H.R.REP. NO. 99-910,
+at 6 (1986), reprinted in 1986 U.S.C.C.A.N. 5952,
+5956 (noting that under § 2251 the Government
+"need not prove that the defendant actually knew
+the person depicted was in fact under 18 years of
+Deverso also argues that he was entitled to a
+mistake of age jury instruction because it is constitutionally mandated. He relies on United States
+District Court, 858 F.2d at 537-43, in which the
+Ninth Circuit engrafted a mistake of age defense into the statute after concluding that such a defense
+was required under the First Amendment although
+the statute did not have a scienter of age element.
+We reject Deverso's contention and hold that the
+Constitution does not mandate a mistake of age defense under § 2251. See United States || Crow, 164
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=Fe..
+
+
+
+--- F.3d ---
+--- F.3d -..., 2008 WL 581218 (C.A.11 (Fla.))
+F.3d 229, 236 (5th Cir.1999) (finding defendant's
+Cir. 1997) (considering Iowa statute similar to
+2251 and concluding that the First Amendment
+does not mandate a mistake of age defense to the
+offense of sexual exploitation of a minor). Accordingly, we reject Deverso's argument that the district
+court erred in its jury instruction on Count Three.
+C. Motion for judgment of acquittal
+Deverso contends that the district court erred in
+denying his motion for judgment of acquittal on
+Count One, possession of materials containing child
+pornography. He argues that the evidence was insufficient to support his conviction. Having reviewed the record, and taking the evidence in the
+light most favorable to the Government, see Dulcio,
+441 F.3d at 1276, we conclude that the evidence
+was more than sufficient to support Deverso's conviction on Count One.
+The evidence showed that after his arrest, De-
+verso admitted to another inmate that the disks belonged to him but that he intended to put the blame
+on his son, and that he had had sex with underage
+girls while he was in the Philippines. Additionally,
+an investigator testified that some of the child pornography contained on one of the disks had been
+found under Deverso's password-protected account
+on the hard drive of his computer. The investigator
+also stated that some of the child pornography on
+the disks contained the same images he had seen in
+other child pornography investigations. Deverso's
+son testified that none of the computer stuff belonged to him and that his father's account was the
+only account that was password-protected.
+Although Deverso testified and denied any
+knowledge of the child pornography on the disks,
+the jury was free to disbelieve his testimony in light
+of the evidence to the contrary. Given the opportun
+ty to evaluate Deverso's demeanor and credibility
+the jury was entitled not only to disbelieve his testi-
+Page 6
+mony but, in fact, to find that the opposite of his
+testimony was true. See United States | Martinez,
+3 F.3d 371, 374-75 (11th Cir.1996); United States
+Brown, 53 F.3d 312, 314-15 (11th Cir.1995).
+Thus, Deverso's testimony in his own defense,
+coupled with the corroborative evidence of his
+ult, steports the jury's guilty verdict. see Unite
+tates • Williams, 390 F.3d 1319, 1326 (11t
+Cir.2004) ("Where some corroborative evidence of
+guilt exists for the charged offense ... and the defendant takes the stand in [his] own defense, the
+[d]efendant's testimony, denying guilt, may establish, by itself, elements of the offense."). Accordingly, we conclude that the district court did not err
+in denying Deverso's motion for judgment of acquittal on Count One.
+I CONCLUSION
+For the foregoing reasons, we affirm Deverso's
+convictions.
+AFFIRMED.
+*Honorable Richard W. Goldberg, United
+States Court of International Trade Judge,
+sitting by designation.
+1. Deverso does not have a challenge with
+regard to the scienter instruction on Count
+Two because the district court gave a scienter jury instruction on this count. (R.
+Vol.8, p. 709-10.)
+2. We note, moreover, that the Government's inclusion of the word "knowingly"
+in the indictment was mere surplusage.
+Congress defines the elements of an offense, not the charging document. Surplusage in an indictment may be deleted
+ithout any legal error. See United States
+Ward, 486 F.3d 1212, 1227 (11th
+Cir.2007), cert. denied, 128 S.Ct. 398
+(2007). Furthermore, when the Government explained that it had charged
+"knowingly" to mean only that Deverso
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=Fe..
+
+
+
+-.- F.3d ----
+..- F.3d -..., 2008 WL 581218 (C.A.11 (Fla.))
+must have "knowingly produced the images, he knowingly took the pictures," De
+verso did not dispute that construction of
+Count Three, nor did he argue that he had
+clied on the language of the charge in fo
+mulating his defense. See United States
+Cancelliere, 69 F.3d 1116, 1121 (11th
+Cir.1995) (noting exception to the general
+rule regarding surplusage in the indictment
+when a defendant rests his entire defense
+on an erroneously charged surplus ele- ment).
+C.A.T1,2008.
+U.S. I. Deverso
+*-- F.3d --.., 2008 WL 581218 (C.A.11 (Fla.))
+Page 7
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&prft=HTMLE&fn=_top&mt=Fe...
+
+
+FILED
+FORT MYERS DIVISION
+05 AUG 31 PM 2: 1?
+UNITED STATES OF AMERICA
+V.
+DONALD J. DEVERSO
+CASE NO. 2:S05-Cr-34-FtM-29SPC
+18 USC § 2251(c)(2)(B)
+18 USC § 2251(e)
+18 USC § 2252(a)(1)
+18 USC § 2252(a)(4)(B)
+18 USC § 2252(b)(1)
+18 USC § 2252(b)(2)
+SECOND SUPERCEDING INDICTMENT
+The Grand Jury charges:
+COUNT ONE
+From a date unknown but by at least May 11, 2002, through on or about April 5,
+2005, in Lee County, Florida, in the Middle District of Florida, and elsewhere, the
+defendant,
+DONALD J. DEVERSO,
+did knowingly possess one or more matters) which contain a visual depiction that had
+been transported in interstate and foreign commerce, and which had been produced
+using materials which had been transported, by any means including by computer,
+where the production of such visual depiction involved the use of a minor engaging in
+sexually explicit conduct, and such visual depiction is of such conduct.
+In violation of Title 18, United States Code, Sections 2252(a)(4)(B) and
+2252(b)(2).
+
+
+COUNT TWO
+On or about October 20, 2004, in Lee County, in the Middle District of Florida,
+and elsewhere, the defendant,
+DONALD J. DEVERSO,
+did knowingly transport and ship in interstate and foreign commerce, by any means,
+including by computer, a visual depiction, the production of which involved the use of a
+minor engaging in sexually explicit conduct, and such visual depiction is of such
+conduct.
+In violation of Title 18, United States Code, Sections 2252(a)(1) and
+2252(b)(1).
+COUNT THREE
+Between October 15, 2004, through on or about October 17, 2004, in Lee
+County, in the Middle District of Florida, and the Philippines, the defendant,
+DONALD J. DEVERSO,
+did knowingly employ, use, persuade, induce, entice, or coerce a minor to
+engage in sexually explicit conduct outside of the United States for the purpose of
+producing a visual depiction of such conduct, and did transport such visual depiction
+to the United States by any means, including by computer, and which visual
+depiction had actually been transported in interstate and foreign commerce and mail.
+In violation of Title 18, United States Code, Section 2251(c)(2)(B) and 2251(e).
+2
+
+
+2.
+FORFEITURE
+The allegations contained in Counts One through Three, of this Second
+Superceding Indictment are hereby realleged and incorporated by
+reference for the purpose of alleging forfeitures pursuant to the provision
+of Title 18, United States Code, Section 2253.
+The defendant, Donald J. Deverso, shall forfeit to the United States of
+America, any visual depiction described in section 2251, 2251A, or 2252
+of this chapter, or any book, magazine, periodical, film, videotape, or other
+matter which contains any such visual depiction, which was produced,
+transported, mailed, shipped or received in violation of this chapter; any
+property, real or personal, constituting or traceable to gross profits or
+other proceeds obtained from such offense; and any property, real or
+personal, used or intended to be used to commit or to promote the
+commission of offense.
+If any of the property described above, as a result of any act or omission
+of the defendant:
+a.
+b.
+cannot be located upon the exercise of due diligence;
+has been transferred or sold to, or deposited with, a third party;
+has been placed beyond the jurisdiction of the court;
+has been substantially diminished in value; or
+e.
+has been commingled with other property which cannot be divided
+without difficulty,
+3
+
+
+the United States of America shall be entitled to forfeiture of substitute property under
+the provision of Title 18, United States Code, Section 2253(o).
+A TRUE BILL,
+8.31.05
+Date
+PAUL I. PEREZ
+United States Attorney
+Trial Councol
+B
+Asset Forfeiture
+Chief, Fort Myers Division
+N. Criminal Cases\ Devens., Doeak|_2005R01005_ygvif_indictment_package Final. fm
+
+
+FORM OBD-34 APR 1991
+Middle District of Florida
+Fort Myers Division
+THE UNITED STATES OF AMERICA
+VS.
+DONALD J. DEVERSO
+SECOND SS INDICTMENT
+Violations:
+Title 18, United States Code, Sections 2251(c)(2)(B), 2251(e), 2252(a)(1).
+2252(a)(4)(B), 2252(b)(1), and 2252(b)(2).
+A trus bill
+~ Foreperson
+of August, A.D. 20 his 3151 day
+Clerk
+Bail $.
+GPO 863 525
+
+
+FORT MYERS DIVISION
+UNITED STATES OF AMERICA
+CASE NO. 2:S05-cr-34-FtM-29SPC
+DONALD J. DEVERSO
+GOVERNMENT'S NOTICE OF INTENT TO INTRODUCE
+EVIDENCE UNDER FED. R. EVID. 404(b)
+United States Attorney for the
+The United States of America, by
+Middle District of Florida, notifies this Honorable Court and all counsel that it intends to
+introduce evidence, pursuant to Fed. R. Evid. 404(b), of other crimes, wrongs or acts
+the defendants committed before, during, and after the dates of the offenses alleged in
+the Indictment.
+The Government will present evidence that the defendant took numerous
+trips to various countries to engage in sexual intercourse with minors. The defendant
+made these trips to Asian countries, according to passport records and statements of
+the defendant.
+2.
+The Government will present evidence that the defendant had numerous
+e-mail "relationships" with a number of women, both of age and under age. The
+Government will present evidence that the defendant convinced these women and girls
+that they were his "fiances". These women and girls include
+a young
+Filipino girl,
+, and others. The e-mail addresses include:
+and others. The Government will present computer print-out evidence of the e-mails
+
+
+from the defendant that the defendant demanded sex from the women and girls in each
+of these "relationships" before marriage, so that: "I can be sure the marriage is a good
+one". There were no real "fiances"; the defendant was married and attempting to have
+sex with underage women.
+3.
+The Government will present evidence the defendant showed members)
+of his family pictures of young girls upon returning from various trips out of the country,
+declaring he had sex with these underage women. The defendant stated he "purchased
+these girls for a bachelor party I threw myself". The defendant showed member(s) of
+his family a CD containing bestiality.
+4.
+The Government will present evidence the defendant frequently visited
+on-line sites!
+5.
+The Government will present evidence members) of the defendant's
+family saw him viewing child pornography in the defendant's home from January 2003
+up to and including this year. The defendant showed members) of his family child
+pornography, telling member(s) of his family when abroad he could have sex with "a girl
+of any age".
+2
+
+
+The Government will present evidence the defendant maintains a storage
+facility in New York which contains downloaded child pornography.
+Respectfully submitted,
+PAUL I. PEREZ
+United States Attorney
+By:
+Florida Bar No. 0316716
+3
+
+
+U.S. |. Donald Deverso
+CASE NO. 2:S05-cr-34-FtM-29SPC
+CERTIFICATE OF SERVICE
+I hereby certify that on November 18, 2005, I electronically filed the foregoing
+with the Clerk of the Court by using the CM/ECF system which will send a notice of
+electronic filing to the following:
+Peter Ringsmuth
+
+
+FORT MYERS DIVISION
+UNITED STATES OF AMERICA
+VS.
+DONALD J. DEVERSO
+2 : S05-Ccr-34-FtM-29SPC
+Court's Instructions
+to the Jury
+Members of the Jury:
+It is now my duty to instruct you on the rules of law that
+you must follow and apply in deciding this case. When I have
+finished you will go to the jury room and begin your
+discussions - what we call your deliberations.
+It will be your duty to decide whether the Government has
+proved beyond a reasonable doubt the specific facts necessary
+to find the Defendant guilty of the crimes charged in the
+Second Superceding Indictment.
+You must make your decision only on the basis of the
+testimony and other evidence presented here during the trial;
+and you must not be influenced in any way by either sympathy
+or prejudice for or against the Defendant or the Government.
+You must also follow the law as I explain it to you
+whether you agree with that law or not; and you must follow all
+
+
+of my instructions as a whole.
+You may not single out, or
+disregard, any of the Court's instructions on the law.
+The Second Superceding Indictment or formal charge against
+any Defendant is not evidence of guilt.
+Indeed, every
+Defendant is presumed by the law to be innocent. The law does
+not require a Defendant to prove innocence or to produce any
+evidence at all. The Government has the burden of proving a
+Defendant guilty beyond a reasonable doubt, and if it fails to
+do so you must find that Defendant not guilty.
+Thus, while the Government's burden of proof is a strict
+oI heavy burden, it is not necessary that a Defendant's guilt
+be proved beyond all possible doubt. It is only required that
+the Government's proof exclude any "reasonable doubt"
+concerning the Defendant's guilt.
+A "reasonable doubt" is a real doubt, based upon reason
+and common sense after careful and impartial consideration of
+all the evidence in the case.
+Proof beyond a reasonable doubt, therefore, is proof of
+such a convincing character that you would be willing to rely
+and act upon it without hesitation in the most important of
+your own affairs. If you are convinced that the Defendant has
+-2-
+
+
+been proved guilty beyond a reasonable doubt, say so. If you
+are not convinced, say so.
+As I said earlier, you must consider only the evidence
+that I have admitted in the case. The term "evidence" includes
+the testimony of the witnesses and the exhibits admitted in the
+record. Remember that anything the lawyers say is not evidence
+in the case.
+It is your own recollection and interpretation
+of the evidence that controls. What the lawyers say is not
+binding upon you. Also, you should not assume from anything
+I may have said that I have any opinion concerning any of the
+issues in this case. Except for my instructions to you on the
+law, you should disregard anything I may have said during the
+trial in arriving at your own decision concerning the facts.
+In considering the evidence you may make deductions and
+reach conclusions which reason and
+common sense lead you to
+make; and you should not be concerned about whether the
+evidence is direct or circumstantial. "Direct evidence" is the
+testimony of one who asserts actual knowledge of a fact, such
+as an eye witness. "Circumstantial evidence" is proof of a
+chain of facts and circumstances tending to prove, or disprove,
+any fact in dispute. The law makes no distinction between the
+- 3-
+
+
+weight you may give to either direct oF circumstantial
+evidence.
+Now, in saying that you must consider all of the evidence,
+I do not mean that you must accept all of the evidence as true
+or accurate. You should decide whether you believe what each
+witness had to say, and how important that testimony was. In
+making that decision you may believe or disbelieve any witness,
+in whole or in part. Also, the number of witnesses testifying
+concerning any particular dispute is not controlling.
+In deciding whether you believe or do not believe any
+witness I suggest that you ask yourself a few questions: Did
+the witness impress you as one who was telling the truth? Did
+the witness have any particular reason not to tell the truth?
+Did the witness have a personal interest in the outcome of the
+case? Did the witness seem to have a good memory? Did the
+witness have the opportunity and ability to observe accurately
+the things he or she testified about? Did the witness appear
+to understand the questions clearly and answer them directly?
+Did the witness's
+testimony differ from other testimony or
+other evidence?
+-4-
+
+
+The fact that a witness has been convicted of a felony
+offense, or a crime involving dishonesty or false statement, is
+another factor you may consider in deciding whether you believe
+that witness.
+You should also ask yourself whether there was evidence
+tending to prove that the witness testified falsely concerning some
+important fact; or, whether there was evidence that at some other
+time the witness said or did something, or failed to say or do
+something, which was different from the testimony the witness gave
+before you during the trial.
+You should keep in mind, of course, that a simple mistake by
+a witness does not necessarily mean that the witness was not
+telling the truth as he or
+she
+remembers it, because people
+naturally tend to forget some things or remember other things
+inaccurately. So, if a witness has made a misstatement, you need
+to consider whether it was simply an innocent lapse of memory or an
+intentional falsehood; and the significance of that may depend on
+whether it has to do with an important fact or with only an
+unimportant detail.
+A Defendant has a right not to testify. If a Defendant does
+testify, however, you should decide in the same way as that of any
+other witness whether you believe the Defendant's testimony.
+-5-
+
+
+The testimony of some witnesses must be considered with
+more caution than the testimony of other witnesses.
+In this case the Government called as one of its witnesses
+a person with whom the Government has entered into a plea
+agreement providing for the possibility of a lesser sentence
+than the witness would otherwise be exposed to. Such plea
+bargaining, as it's called, has been approved as lawful and
+proper, and is expressly provided for in the rules of this
+Court.
+However, a witness who hopes to gain more favorable
+treatment may have a reason to make a false statement because
+the witness wants to strike a good bargain with the Government.
+So, while a witness of that kind may be entirely truthful when
+testifying, you should consider such testimony with more
+caution than the testimony of other witnesses.
+When knowledge of a technical subject matter might be
+helpful to the jury, a person having special training or
+experience in that technical field is permitted to state an
+opinion concerning those technical matters.
+Merely because such a witness has expressed an opinion,
+however, does not mean that you must accept that opinion. The
+same as with any other witness, it is up to you to decide
+whether to rely upon it.
+In this case you have been
+-6-
+
+
+permitted to take notes during the course of the trial, and
+most of you - perhaps all of you - have taken advantage of that
+opportunity and have made notes from time to time.
+You will have your notes available to you during your
+deliberations, but you should make use of them only as an aid
+to your memory. In other words, you should not give your notes
+any precedence over your independent recollection of the
+evidence or the lack of evidence; and neither should you be
+unduly influenced by the notes of other jurors.
+I emphasize that notes are not entitled to any greater
+weight than the memory or impression of each juror as to what
+the testimony may have been.
+Count One of the Second Superceding Indictment charges
+that the Defendant did knowingly possess one or more matters
+containing child pornography which had been transported in
+interstate or foreign commerce, including by computer. Title
+18, United States Code, Section 2252 (a) (4) (B), makes it a
+Federal crime or offense for any person to knowingly possess child
+pornography that has been transported in interstate or foreign
+commerce, including by computer.
+-7-
+
+
+The Defendant can be found guilty of that offense only if all
+of the following facts are proved beyond a reasonable doubt:
+First:
+That the Defendant knowingly possessed matters
+which
+the
+Defendant knew contained a visual
+depiction of a minor engaged in sexually explicit
+Second:
+That the Defendant knew the visual depiction
+contained in the matters was of a minor engaged in
+sexually explicit conduct;
+Third:
+The Defendant knew that production of such a visual
+depiction involved use of a minor in sexually
+explicit conduct; and
+Fourth:
+That the visual depiction had been transported in
+interstate or foreign commerce.
+The term "interstate or foreign commerce" means the movement
+of property from one state to another state or from one state to
+another country. The term "State" includes a State of the United
+States, the District of Columbia, and any commonwealth, territory,
+or possession of the United States. It is not necessary for the
+Government to prove that the Defendant knew that the alleged child
+pornography had moved in interstate or foreign commerce, only that
+it had so moved.
+The term "computer" means an electronic, magnetic, optical,
+electrochemical,
+or other high speed data processing device
+performing logical, arithmetic, or storage functions, and includes
+any data storage facility or communications facility directly
+related to or operating in conjunction with such device, but such
+-8-
+
+
+term does not include an automated typewriter or typesetter, a
+portable hand-held calculator, or other similar device.
+The term "child pornography" means any visual depiction,
+including any photograph, film, video, picture, or computer image
+or picture, whether made or produced by electronic, mechanical, or
+other means, of sexually explicit conduct where the production of
+such visual depiction involves the use of a minor engaging in
+sexually explicit conduct.
+The term "minor" means any person under the age of eighteen
+(18) years.
+The term "visual depiction" includes data stored on computer
+disk or by electronic means which is capable of conversion into a
+visual image.
+The term "sexually explicit conduct" means actual or
+simulated:
+(a) sexual
+intercourse,
+including
+genital-genital,
+oral-genital, anal-genital, or oral-anal contact, whether
+between persons of the same or opposite sex; or
+(b) lascivious exhibition of the genitals or pubic area of
+any person.
+Regarding the last type of sexually explicit conduct -
+"lascivious exhibition" - not every exposure of the genitals or
+pubic area constitutes a lascivious exhibition. In determining
+whether a visual depiction constitutes a lascivious exhibition, you
+should consider the context and setting in which the genitalia or
+-9-
+
+
+pubic area is being displayed.
+You may consider the overall
+content of the material. You may also consider such factors as
+whether the focal point of the visual depiction is on the minor's
+genitalia or pubic area, or whether there is some other focal
+point. You may consider whether the setting of the depiction is
+such as to make it appear to be sexually inviting or suggestive;
+for example, in a location or in a pose associated with sexual
+activity. In addition you may consider whether the minor appears
+to be displayed in an unnatural pose or in inappropriate attire.
+You may also consider whether the minor is partially clothed or
+nude. You may consider whether the depiction appears to convey
+sexual coyness or an apparent willingness to engage in sexual
+activity, and whether the depiction appears to have been designed
+to elicit a sexual response in the viewer. Of course, a visual
+depiction need not involve all of these factors to be a lascivious
+exhibition.
+Count Iwo of the Second Superceding Indictment charges that
+the Defendant did knowingly transport or ship in interstate and
+foreign commerce, by any means, including by computer, material
+involving the sexual exploitation of minors.
+Title 18, United
+States Code, Section 2252 (a) (1), makes it a Federal crime or
+offense for any person to knowingly transport or ship any visual
+depiction in interstate or foreign commerce, by any means including
+-10-
+
+
+by computer, if the production of such visual depiction involved
+the use of a minor engaging in sexually explicit conduct and the
+visual depiction is of such conduct.
+The Defendant can be found guilty of that offense only if all
+of the following facts are proved beyond a reasonable doubt:
+First:
+Second:
+Third:
+That the Defendant knowingly transported or shipped
+a visual
+depiction
+in interstate or foreign
+commerce by any means, including by computer;
+That the production of such visual depiction
+involved the use of a minor engaging in sexually
+explicit conduct;
+That such visual depiction is of a minor engaged in
+sexually explicit conduct; and
+Fourth:
+That the Defendant knew that at least one of the
+performers in such visual depiction was a minor and
+knew that the visual depiction was of such minor
+engaged in sexually explicit conduct.
+The terms "interstate Or foreign commerce," "computer,"
+"sexually explicit conduct," "visual depiction", and "minor" have
+been defined to you earlier and apply to Count Iwo.
+Count Three of the Second Superceding Indictment charges that
+the Defendant did knowingly employ, use, persuade, induce, entice,
+or coerce a minor to engage in sexually explicit conduct outside of
+the United States for the purpose of producing child pornography
+material, and did knowingly transport such material to the United
+States in interstate and foreign commerce by any means, including
+-11-
+
+
+by computer. Title 18, United States Code, Section 2251 (c) (2) (b),
+makes it a Federal crime or offense for any person to knowingly
+employ, use, persuade, induce, entice or coerce a minor to engage
+in sexually explicit conduct outside of the United States for the
+purpose of producing a visual depiction of such conduct, and
+transport such visual depiction to the United States by any means,
+including by computer, and which visual depiction had actually been
+transported in interstate or foreign commerce or mail.
+The Defendant can be found guilty of that offense only if all
+of the following facts are proved beyond a reasonable doubt:
+First:
+That the Defendant knowingly employed,
+persuaded, induced, enticed, or coerced a minor to
+take part in sexually explicit conduct for the
+purpost of producing a visual depiction of such
+Second:
+Third:
+That such visual depiction is of a minor engaged in
+sexually explicit conduct;
+That such production was made outside the United
+States; and
+Fourth:
+That the Defendant knowingly transported such visual
+depiction to the United States, its territories or
+massessions, by any means, including by computex or
+The Government need not prove that the Defendant knew that the
+minor was under 18 years old.
+A person "uses" a minor to produce child pornography if the
+minor serves as the subject of photography. The term "induce"
+means to stimulate the occurrence of or to cause.
+-12-
+
+
+The terms "sexually explicit conduct, " "visual depiction, " and
+"minor" have been described to you earlier and apply to Count
+Three.
+The term "transportation" simply means to send or carry
+something from one place to another. Transportation can be
+accomplished in any of a variety of ways, either directly because
+a person personally carries an item or indirectly because a person
+makes use of a third party, such as a commercial shipper or through
+the use of the mails. The transportation must, however, involve
+the movement of the materials into the United States.
+As I mentioned above, this transportation can be accomplished
+by any means, including by a computer. Images transmitted or
+received over the Internet to the United States would constitute
+transportation to the United States within the meaning of this
+statute.
+The law recognizes several kinds of possession. A person
+may have actual possession or constructive possession. A
+person may also have sole possession or joint possession.
+A person who knowingly has direct physical control of
+something is then in actual possession of it.
+A person who is not in actual possession, but who has both
+the power and the intention to later take control over
+-13-
+
+
+something either alone or together with someone else, is in
+constructive possession of it.
+If one person alone has possession of something, that
+possession is sole. If two or more persons share possession,
+such possession is joint.
+Whenever the word "possession" has been used in these
+instructions it includes constructive as well as actual
+possession, and also joint as well as sole possession.
+You will note that the Second Superceding Indictment
+charges that the offenses were committed "in or about" and "on
+or about" certain dates. The Government does not have to
+prove with certainty the exact date of the alleged offense.
+It is sufficient if the Government proves beyond a reasonable
+doubt that the offense was committed on a date reasonably near
+the date alleged.
+The word "knowingly," as that term is used in the Second
+Superceding Indictment or in these instructions, means that the
+act was done voluntarily and intentionally and not because of
+mistake or accident.
+In these charges, the Court has reviewed the pertinent
+parts of federal law which are alleged to have been violated.
+-14-
+
+
+Where a statute specifies several alternative ways in which an
+offense may be committed, the Second Superceding Indictment may
+allege the several ways in the conjunctive, that is, by using
+the word "and." However, if only one of the alternatives is
+proved beyond a reasonable doubt, that is sufficient for
+conviction, so long as the jury agrees unanimously as to that
+alternative.
+A separate crime or offense is charged in each count of
+the Second Superceding Indictment. Each charge, and the
+evidence pertaining to it, should be considered separately.
+The fact that you may find the Defendant guilty or not guilty
+as to one of the offenses charged should not affect your
+verdict as to any other offense charged.
+I caution you, members of the Jury, that you are here to
+determine from the evidence in this case whether the Defendant
+is guilty or not guilty. The Defendant is on trial only for
+those specific offenses alleged in the Second Superceding
+Indictment.
+Also, the question of punishment should never be
+considered by the jury in any way in deciding the case. If the
+-15-
+
+
+Defendant is convicted the matter of punishment is for the
+Judge alone to determine later.
+Any verdict you reach in the jury room, whether guilty or
+not guilty, must be unanimous. In other words, to return a
+verdict you must all agree. Your deliberations will be secret;
+you will never have to explain your verdict to anyone.
+It is your duty as jurors to discuss the case with one
+another in an effort to reach agreement if you can do so. Each
+of you must decide the case for yourself, but only after full
+consideration of the evidence with the other members of the
+jury. While you are discussing the case do not hesitate to
+reexamine your own opinion and change your mind if you become
+convinced that you were wrong. But do not give up your honest
+beliefs solely because the others think differently or merely
+to get the case over with.
+Remember, that in a very real way you are judges - judges
+of the facts. Your only interest is to seek the truth from the
+evidence in the case.
+When you go to the jury room you should first select one
+of your members to act as your foreperson. The foreperson will
+- 16-
+
+
+.. -
+preside over your deliberations and will speak for you here in
+court.
+A form of verdict has been prepared for your convenience.
+[Explain verdict]
+You will take the verdict form to the jury room and when
+you have reached unanimous agreement you will have your
+foreperson fill in the verdict form, date and sign it, and then
+return to the courtroom.
+If you should desire to communicate with me at any time,
+please write down your message or question and pass the note
+to the court security officer who will bring it to my
+attention. I will then respond as promptly as possible, either
+in writing or by having you returned to the courtroom so that
+I can address you orally. I caution you, however, with regard
+to any message or question you might send, that you should not
+tell me your numerical division at the time.
+-17-
+
+
+(USAFLS)
+Subject:
+Tuesdav. March 04. 2008 4:18 PM
+1): USAEO-PSC-Coordinators
+RE: transportation question
+Transportation-aiding and abetting
+The courts in the following cases held or recognized that although the term "transport,"
+within the meaning of 18 U.S.C.A. § 2423(a), criminalizing the transportation of a minor
+across state lines for unlawful sexual purposes, does not extend to causing the
+transportation of a minor, to support a conviction under 18 U.S.C.A. § 2423(a) under an
+aiding and abetting theory (18 U.S.C.A. § 2), it is sufficient to prove that the defendant
+caused
+the minor to be transported across state lines for unlawful sexual purposes.
+In U.S.
+Footman, 215 F.3d 145 (1st Cir. 2000), the court recognized that, although the
+term "transport," within the meaning of the 18 U.S.C.A. § 2423(a), criminalizing the knowing
+transport of a minor across state lines for purposes of prostitution, does not extend to
+"causing" the transportation of a minor, to support a conviction under 18 U.S.C.A. § 2423
+under an aiding and abetting theory (18 U.S.C.A. § 2), it is sufficient to prove that the
+defendant caused the minor to be transported across state lines for an unlawful sexual
+purpose. Thus, the court found, in a prosecution for transporting a minor across state lines
+for purposes
+of prostitution in violation of 18 U.S.C.A. § 2423(a), even if the trial court's
+instructions defining "knowing transportation" as "causing" the transportation of a minor in
+interstate commerce for the purpose of transportation was error, such error was harmless, as
+the definition was proper to support the defendant's conviction
+as an aider and abettor where
+the evidence indicated that another prostitute was the defendant's agent in transporting the
+minor across state lines,
+the women traveled in the defendant's car and the minor wired money
+back to the defendant,
+and the minor testified that she and other prostitutes traveled to
+another state at the defendant's direction.
+In U.S. Johnson, 132 F.3d 1279, 48 Fed. R. Evid. Serv. 562 (9th Cir, 1997), a prosecution
+for transportation of a minor with intent to engage in criminal sexual activity in violation
+of 42 U.S.C.A. § 2423(a), the court held that the trial judge's jury instructions-that it
+could find the defendant guilty if the jury determined that he had "transported or caused to
+be transported a minor from Norway to Fresno"-were not improper where the defendant was
+charged as an aider and abettor under 18 U.S.C.A. § 2(b). The court said that the defendant
+could be convicted of transportation of a minor with intent to engage in criminal sexual
+activity if he "transported or caused to be transported" a minor under the statute pertaining
+to aiding and abetting, 18 U.S.C.A. § 2(b), permitting a person causing a criminal act to be
+done by another to be punished as a principal actor. Thus, it was enough that the defendant
+caused the Norwegian minor's transport and possessed the requisite intent to engage in
+unlawful sexual conduct even if the entity carrying out the transport-the foreign student
+exchange program or the minor himself-lacked criminal intent. Further, the court found, the
+defendant's conviction was supported by evidence that the defendant, immediately after the
+arrival of the victim, who was a foreign exchange student, progressively introduced
+discussion and then engagement in sexual acts, as well as evidence of inconsistencies and
+misrepresentations in the defendant's application to serve as a host parent, expert testimony
+that the defendant's conduct indicated a sophisticated "grooming" process that did not arise
+spontaneously, and evidence of the defendant's prior sexual contacts with minors.
+see u.s. I
+Garrett, 720 F.2d 705 (D.C. Cir. 1983), in which the court held that the
+defendant
+s extensive involvement as a go-between in "facilitating" the interstate
+transportation of a young male to a customer for the purpose of prohibited sexual conduct for
+commercial exploitation satisfied every element of the offense of aiding and abetting the
+
+
+primary offense of transportation of a minor in interstate commerce for purposes of
+prohibited sexual conduct for commercial exploitation in violation of 18 U.S.C.A. § 2423.
+Also, the court held, the defendant's so-called withdrawal from the criminal venture, coming
+after the defendant satisfied himself that his active participation was no longer
+required to assure the success of the venture, namely, the transportation of the minor for
+the aforesaid criminal purposes, was insufficient to constitute abandonment of the criminal
+enterprise.
+A defendant will be deemed to have "transported" an individual, under Mann Act section
+prohibiting knowing transportation of any individual in interstate or foreign commerce with
+intent that such individual engage in prostitution or in criminal sexual activity, where the
+evidence shows that the defendant personally or through an agent performed the proscribed act
+f transporting, as opposed to situations where the victim travels under her own steam,
+-ons where the vice travel
+without need of anyone to transport her. 18 U.S.C.A. § 2421. U.S.
+• Holland, 381 F.3d 80 (20
+Cir. 2004) -
+A defendant will be deemed to have "transported" an individual, under Mann Act section
+prohibiting knowing transportation of any individual in interstate or foreign commerce with
+intent that such individual engage in prostitution or in criminal sexual activity, where the
+evidence shows that the defendant personally or through an agent performed the proscribed act
+Cir. 2004).
+Sufficient evidence established that codefendant aided and abetted defendant in the
+interstate transportation of a minor with the intent to commit an aggravated sexual assault;
+codefendant accompanied defendant to mall where victims were picked up, participated in
+cruising and smoking marijuana, threatened children to get them to remain in house after
+lefendant after the assault. 18 U.S.C.A. 66 2
+2004).
+Damon A. King
+Denuty Chief
+-=---Ociginal Message--
+---
+(USAMD) [mailto:
+Sent: Sameram March 01, 2008 8:28 PM
+(USACAC); USAEO-PSC-Coordinators
+Subject: RE: transportation question
+I would feel comfortable charging it. And you can add in 18 USC Section 2 (aiding and
+abetting) just to be safe
+Sent by Good Messaging (www.good.com)
+•-Original Message--
+(USACAC)
+Friday,
+February 29, 2008 09:49 PM Eastern Standard Time
+USAEO-PSC-Coordinators
+Subject:
+transportation question
+2
+
+
+We have a guy here who molested a neighbor boy almost every day for 2-3 years. The boy's
+family moved. In 2006 and again in 2007, the boy travelled from another state to Los Angeles
+to visit the defendant, and was again molested on each trip.
+I would like to charge defendant with 2423(a) - transportation of a minor with intent to
+engage in criminal sexual activity.
+However, I cannot prove that the defendant PAID for the
+boy's trip, or arranged the travel. Do you think it is sufficient if I can prove that the
+guy caused the travel, by speaking to the victim's parents and encouraging/suggesting that
+the boy come and visit him, and facilitated the travel by picking the boy up at the airport,
+allowing the boy to stay at his home, etc - all with the intention that he would molest the
+boy once the boy arrived?
+3
+
+
+(USAFLS)
+Subject:
+(USAFLS)
+Wednesdav, March 12, 2008 10:23 AM
+(USAFLS)
+RE: Another victim issue
+If any man is approaching her in an unwanted fashion and won't relent, I would suggest that she call campus security.
+I'm not sure that a school is a "public place" to the extent that anybody can come on campus and hassle students. I'm
+sure they wouldn't let unauthorized vendors come on campus so why would they let a grown man repeatedly harass
+one of their students. It would help if she has the name and the number of the investigator. Campus security would
+then be wise to warn him to not send a surrogate to hassle, i.e. aid and abet the continued harassment. Just a thought
+that may be worth exploring.
+• (USAFLS)
+Sent: Wednesday, March 12, 2008 8:20 AM
+(USAFLS)
+Subject: Another victim issue
+Hi
+- Apparently one of Epstein's investigators is following one of our victims around her campus. She
+keeps telling him that she doesn't want to talk and he continues to approach her. In addition to the direct
+contact, she feels intimidated that he is approaching other people on campus and that others will find out about
+her involvement with JE. This is the same victim who called us about Jeff Herman. Is there anything that we
+can do?
+
+
+- (USAFLS)
+From
+Sent
+Subject:
+(USAMD)
+Wednesdav. March 12, 2008 10:15 AM
+I (USAFLS)
+RE: Appointment of counsel for victims?
+Could you let me know if you get any info? I have a similar situation---an adult victim who was photographed when she
+was a child. She wants an attorney before she talks to us.
+From: |
+(USAFLS)
+Sent: Wednesday, March 12, 2008 8:27 AM
+To: USAEO-PSC-Coordinators
+Subject: Appointment of counsel for victims?
+Good morning, everyone. Sorry to bother.
+I am investigating a child exploitation case with a large number of victims. They were teenagers when they
+were victims and many are now over the age of 18. Investigators for the defense are following them around,
+showing up on campus, and making visits to their parents' homes. (Many victims' parents do not know about
+the conduct under investigation.) The victims have told the investigators that they do not want to talk, but they
+continue to be harassed. The case has not yet been indicted, so I can't simply ask the assigned district judge to
+rein in the defense.
+Does anyone have any experience or advice on getting counsel appointed for such victims? The guardian ad
+litem statute seems to be limited to victims who are currently minors and the material witness statute seems to
+be limited to situations where there is a strong possibility of flight.
+Any help and samples would be greatly appreciated. Thank you all.
+2
+
+
+Subject:
+- (USAFLS)
+Wednesdav, March 12, 2008 10:01 AM
+• (USAFLS)
+Re: Appointment of counsel for victims?
+Is there an anti-trafficking NGO nearby?
+If they have attorneys on staff, they are usually
+willing to provide pro bono counsel.
+The only trick is to make sure that they don't
+interfere with the prosecution. Another option may be a domestic violence NGO.
+Sent from my BlackBerry Wireless Device
+daininal Mascaro
+Fo: USAEO-PSC-Coordinators ‹
+Sent: Wed Mar 12 08:27:02 2008
+Subject: Appointment of counsel for victims?
+Good morning, everyone. Sorry to bother.
+I am investigating a child exploitation case with a large number of victims. They were
+teenagers when they were victims and many are now over the age of 18. Investigators for the
+defense are following them around, showing up on campus, and making visits to their parents'
+homes. (Many victims' parents do not know about the conduct under investigation.) The
+victims have told the investigators that they do not want to talk, but they continue to be
+harassed. The case has not yet been indicted, so I can't simply ask the assigned district
+judge to rein in the defense.
+Does anyone have any experience or advice on getting counsel appointed for such victims? The
+guardian ad litem statute seems to be limited to victims who are currently minors and the
+material witness statute seems to be limited to situations where there is a strong
+possibility of flight.
+Any help and samples would be greatly appreciated. Thank you all.
+
+
+Subject:
+- (USAFLS)
+Wednesdav. March 12, 2008 9:53 AM
+- (USAFLS)
+Re: Appointment of counsel for victims?
+Having said that, I recently had a case involving 16 victims where we got an order of
+protection to call off defense investigators. I will send you the motion so you have it in
+Tinal Meccano
+(ISAELS)
+To: USAEO-PSC-Coordinators
+Sent: Wed Mar 12 08:27:02 2008
+Subject: Appointment of counsel for victims?
+Good morning, everyone. Sorry to bother.
+I am investigating a child exploitation case with a large number of victims. They were
+a a to no kind our can Lone under netie one parents.
+seties have old the there for that they do not can ate, bre
+harassed. The case has not yet been indicted, so I can't simply ask the assigned district
+judge to rein in the defense.
+Does anyone have any experience or advice on getting counsel appointed for such victims? The
+guardian ad litem statute seems to be limited to victims who are currently minors and the
+material witness statute seems to be limited to situations where there is a strong
+possibility of flight.
+Any help and samples would be greatly appreciated. Thank you all.
+
+
+- (USAFLS)
+Subject:
+(USACT)
+Wednesdav. March 12, 2008 9:42 AM
+(USAFLS)
+RE: Appointment of counsel for victims?
+I believe so but we are permitted to appoint CJA to any potential witnesses. The way I normally do it is to subpoena my
+witnesses to the grand jury. Obviously anyone subpoenaed to the grand jury has a right to have an attorney. After
+talking to them, I let the court know that they want an attorney. I have had no problems at all. I am staring 1591 sex
+trafficking case on Monday involving many minors, some of which I have had CJA counsel appointed. In light of real
+witness tampering concerns I also had a protective order entered which required the defense counsel to inform us of
+the name of the investigator and then our FBI agent was permitted to call the witnesses to let them know only this
+individual could contact them and they were free to talk to the investigator or not.
+- (USAFLS)
+Sent: Wednesday, March 12, 2008 9:05 AM
+(USACT)
+Subject: RE: Appointment of counsel for victims?
+I know about the guardian ad litem provision but it is specifically limited to victims who are currently minors.
+Have you ever done this for a minor-victim who is now an adult? Would you mind sending a sample? Thank
+you!
+(USACT)
+Sent: Wednesdav, March 12, 2008 9:02 AM
+I (USAFLS)
+Subject: RE: Appointment of counsel for victims?
+I routinely get CJA counsel appointed for victims. I don't know how it is done in your district but we talk to the victims
+about whether they want counsel and then write a letter (especially if they are minors or in their late teens). There is a
+provision in the criminal code for appointing a guardian ad litem.
+(USAFLS)
+Sent: Wednesday, March 12, 2008 8:27 AM
+To: USAEO-PSC-Coordinators
+Subject: Appointment of counsel for victims?
+Good morning, everyone. Sorry to bother.
+
+
+I am investigating a child exploitation case with a large number of victims. They were teenagers when they
+were victims and many are now over the age of 18. Investigators for the defense are following them around,
+showing up on campus, and making visits to their parents' homes. (Many victims' parents do not know about
+the conduct under investigation.) The victims have told the investigators that they do not want to talk, but they
+continue to be harassed. The case has not yet been indicted, so I can't simply ask the assigned district judge to
+rein in the defense.
+Does anyone have any experience or advice on getting counsel appointed for such victims? The guardian ad
+litem statute seems to be limited to victims who are currently minors and the material witness statute seems to
+be limited to situations where there is a strong possibility of flight.
+Any help and samples would be greatly appreciated. Thank you all.
+
+
+Subject:
+- (USAFLS)
+wednesday March 12 2008 9:26 AM
+• (USAFLS)
+FW: Appointment of counsel for victims?
+Sent: Wednesday, March 12, 2008 9:23 AM
+(USAFLS)
+Subject: RE: Appointment of counsel for victims?
+Good morning. Two thoughts. First, can you approach your local Legal Aid clinic for some pro bono
+attorneys? I bet that some young associates from big firms would love to get out of the library and do
+some real justice. Second, consider sending the defense counsel a letter identifying the victims that
+do not wish to be interviewed and reminding counsel about 18 U.S.C. Section 1512(b). That may be
+a deterrent.
+Middle District of Florida
+Jacksonville Division
+• (USAFLS)
+Sent: Wednesday, March 12, 2008 8:27 AM
+To: USAEO-PSC-Coordinators
+Subject: Appointment of counsel for victims?
+Good morning, everyone. Sorry to bother.
+I am investigating a child exploitation case with a large number of victims. They were teenagers when they
+were victims and many are now over the age of 18. Investigators for the defense are following them around
+showing up on campus, and making visits to their parents' homes. (Many victims' parents do not know abou
+the conduct under investigation.) The victims have told the investigators that they do not want to talk, but they
+continue to be harassed. The case has not yet been indicted, so I can't simply ask the assigned district judge to
+rein in the defense.
+Does anyone have any experience or advice on getting counsel appointed for such victims? The guardian ad
+litem statute seems to be limited to victims who are currently minors and the material witness statute seems to
+be limited to situations where there is a strong possibility of flight.
+Any help and samples would be greatly appreciated. Thank you all.
+5
+
+
+
+
+- (USAFLS)
+Subject:
+Wednesday, March 12, 2008 9:23 AM
+• (USAFLS)
+RE: Appointment of counsel for victims?
+Good morning. Two thoughts. First, can you approach your local Legal Aid clinic for some pro bono
+attorneys? I bet that some young associates from big firms would love to get out of the library and do
+some real justice. Second, consider sending the defense counsel a letter identifying the victims that
+do not wish to be interviewed and reminding counsel about 18 U.S.C.
+Middle District of Florida
+Jacksonville Division
+- (USAFLS)
+Sent: Wednesday, March 12, 2008 8:27 AM
+To: USAEO-PSC-Coordinators
+Subject: Appointment of counsel for victims?
+Good morning, everyone. Sorry to bother.
+I am investigating a child exploitation case with a large number of victims. They were teenagers when they
+were victims and many are now over the age of 18. Investigators for the defense are following them around,
+showing up on campus, and making visits to their parents' homes. (Many victims' parents do not know about
+the conduct under investigation.) The victims have told the investigators that they do not want to talk, but they
+continue to be harassed. The case has not yet been indicted, so I can't simply ask the assigned district judge to
+rein in the defense.
+Does anyone have any experience or advice on getting counsel appointed for such victims? The guardian ad
+litem statute seems to be limited to victims who are currently minors and the material witness statute seems to
+be limited to situations where there is a strong possibility of flight.
+Any help and samples would be greatly appreciated. Thank you all.
+7
+
+
+- (USAFLS)
+Subject:
+Wednesdav. March 12, 2008 9:23 AM
+(USAFLS)
+Re: Appointment of counsel for victims?
+Nothing is preventing the women from getting an attorney on their own and/or seeking a
+restraining order even without an attorney.
+A law school clinic or legal aid should be able
+to help them.
+In the long run, it is better for your case if they take these steps on their
+own with minimal involvement from the prosecution.
+Arinin
+All Morrano
+Ecom:
+Sent: Wed Mar 12 08:27:02 2008
+Subject: Appointment of counsel for victims?
+Good morning, everyone. Sorry to bother.
+I am investigating a child exploitation case with a large number of victims. They were
+teenagers when they were victims and many are now over the age of 18. Investigators for the
+defense are following them around, showing up on campus, and making visits to their parents'
+(Many victims" parents do not know about the conduct under investigation.) The
+victims have told the investigators that they do not want to talk, but they continue to be
+harassed. The case has not yet been indicted, so I can't simply ask the assigned district
+judge to rein in the defense.
+Does anyone have any experience or advice on getting counsel appointed for such victims? The
+guardian ad litem statute seems to be limited to victims who are currently minors and the
+material witness statute seems to be limited to situations where there is a strong
+possibility of flight.
+Any help and samples would be greatly appreciated. Thank you all.
+
+
+Subject:
+(USAID)
+Wednesdav. March 12, 2008 10:39 AM
+(USAFLS)
+RE: Appointment of counsel for victims?
+We have had GAL's appointed pre-indictment. Here are a couple of examples. Neither was over 18, however. If they
+were minors at the time of the crime, I'd give it a run and see if the court raises the issue.
+Young. Guardian Young. GALdeclar Duncan. Guardia Duncan.GALdecl Duncan.GALMoti
+Order.wpd
+arion.wpd
+nOrder.wpd
+aration.wpd
+on.wpd
+(USAFLS)
+Sent: Wednesday, March 12, 2008 6:27 AM
+To: USAEO-PSC-Coordinators
+Subject: Appointment of counsel for victims?
+Good morning, everyone. Sorry to bother.
+I am investigating a child exploitation case with a large number of victims. They were teenagers when they
+were victims and many are now over the age of 18. Investigators for the defense are following them around,
+showing up on campus, and making visits to their parents' homes. (Many victims' parents do not know about
+the conduct under investigation.) The victims have told the investigators that they do not want to talk, but they
+continue to be harassed. The case has not yet been indicted, so I can't simply ask the assigned district judge to
+rein in the defense.
+Does anyone have any experience or advice on getting counsel appointed for such victims? The guardian ad
+litem statute seems to be limited to victims who are currently minors and the material witness statute seems to
+be limited to situations where there is a strong possibility of flight.
+Any help and samples would be greatly appreciated. Thank you all.
+1
+
+
+BATSELL T. UNITED STATES
+395
+Cibe as 403 F.2d 305 (1968)
+commerce for immoral purposes, to re-
+Harold Lee BATSELL, Appellant,
+spond to jury's request for further definition of word "induces", other than to
+state that words were to be given their
+UNITED STATES of America,
+Appellee (two cases).
+Nos. 18945, 19344.
+United States Court of Appeals
+Eighth Circuit.
+Nov. 19, 1968.
+Certlorari Denied Feb. 24, 1969.
+common usage, was not error. 18 U.S.
+C.A. § 2422.
+B. Criminal Law 1173(3)
+That jury returned verdict of not
+guilty under first section of Mann Act
+and guilty under second section did not
+ndicate that jury, which had unsuccess
+Prosecution for having persuaded,
+fully requested further definition o
+induced, enticed, and caused woman to go
+words "inducement" or "induces", was
+from one state to another for immoral
+confused as to the meaning of these
+purposes. The United States Distriet
+terms in second section. 18 U.S.C.A. §5
+Court for the District of Minnesota,
+2421, 2422.
+Earl R. Larson, J., rendered judgment,
+6. Prostitution =5
+and defendant appealed. The Court of
+Jury could properly return verdiet
+Appeals, Vogel, Circuit Judge, held that
+of not guilty under first section of Mann
+refusal to respond to jury's request for
+Act and guilty under second section even
+further definition of word "induces",
+though evidence would have justified
+other than to state that words were to
+finding of guilty under both sections.
+be given their common usage, was not
+18 U.S.C.A. S5 2421, 2422,
+7. Prostitution e-1
+Offenses prescribed by first and second sections of Mann Act are separate
+1. Prostitution C=1
+Word "induces" in second section of
+Mann Act is one of common usage and
+meaning and requires no explanation or
+definition. 18 U.S.C.A. § 2422,
+See publication Words and Phrases
+for other judicial constructions and
+and distinet. 18 U.S.C.A. 55 2421, 2422;
+8. Criminal Law 6-633(1)
+In presiding over jury trial, judge
+must exercise discretion in many ways,
+including determination of time to be
+allowed for argument, length of direct
+and cross-examination, keeping of opening statements within proper bounds,
+2. Criminal Law 6-1038(1)
+proper conduct of parties, witnesses and
+Defendant may not asaign as error
+counsel, excluding of witnesses, etc.
+any inaccuracy in instructions without
+first having called attention of trial court
+9. Criminal Law 6-711
+thereto, thus giving it opportunity of
+Limiting of counsel to one hour of
+making correction. Fed.Rules Crim.Proc.
+argument on each side, in case which was
+rule 30, 18 U.S.C.A.
+neither complex nor protracted, was not
+S. Criminal Law 6-1039
+abuse of discretion, and defendant was
+Trial court's failure to respond to
+not denied fair trial by limitation, court
+jury's request for further definition of
+having in fact allowed defense counse
+word "induces" in Mann Act was not
+one hour and 40 minutes.
+plain error. Fed.Rules Crim.Proc. rule
+62(b), 18 U.S.C.A.; 18 U.S.C.A. § 2422.
+4. Criminal Law *=863(2)
+having dense ded, induced victied and.
+Trial court's refusal, in prosecution
+for having persuaded, induced, enticed
+Cause for am toral propose to
+18 U.S
+and caused woman to go in interstate
+C.A. § 2422.
+
+
+396
+11. WItnesses 4-283
+Trial court's statement when defense
+counsel, after lengthy cross-examination
+of prosecution witness, said that he might
+like to recall witness, that if there were
+to be more cross-examinations counsel
+should continue now, whereupon crossexamination was continued and defense
+counsel concluded with "no further questions", was not improper although witness had been recalled four times by
+prosecution at earlier trial at which she
+claimed loss of memory.
+12. Criminal Law 942(2)
+New trial motion based upon alleged
+recantation of material witness should
+be viewed with disfavor.
+Fed.Rules
+Crim.Proc. rule 33, 18 U.S.C.A.
+13. Criminal Law 6-942(2), 1156(3)
+New trial motions based on alleged
+recantation of material witness are generally addressed to sound judicial discretion of trial court and there will be no
+reversal except for clear abuse.
+Fed.
+Rules Crim.Proc. rule 33, 18 U.S.C.A.
+14. Criminal Law 67942(2)
+Denial of new trial sought on ground
+of alleged recantation of material witness who, at hearing on motion, maintained that her testimony at trial had
+been truthful and testified that recantation had been due to fear and threats,
+was not abuse of discretion.
+Fed. Rules
+Crim. Proc. rule 33, 18 U.S.C.A.
+Ellis Olkon,
+Minneapolis, Minn., for
+appellant, and Sheldon J. Eviden,
+Minneapolis, Minn., on the briefs.
+I. The exact wording of the firat indietment in:
+The United Stntes Grand Jury
+charges:
+That on or about the 22nd day of
+May, 1906, in the Distriet of Minnesota,
+Fourth Division,
+HAROLD LEE BATSELI
+did knowingly procure and obtain an
+nirline passenger ticket from Northwest
+Airlines, Ine., a common carrier in
+interstate commerce, anid airline passenger ticket to be uaed by Gloria
+J. Earl Cudd, Asst. U. S. Atty., Minneapolis, Minn., for appellee, Patrick J.
+Foley, U.S. Atty., and Neil P. Convery,
+Asst. U. S. Atty., Minneapolis, Minn., on
+the brief.
+Before VOGEL, LAY and BRIGHT,
+Circuit Judges.
+VOGEL, Circuit Judge.
+We are concerned here with two separate appeals in a criminal conviction,
+The first appeal is from a judgment of
+conviction entered against appellant-defendant, Harold Lee Batsell, for violation
+of Section 2422 of the Mann Act, 18
+U.S.C.A. § 2421 et seg. The second appeal is from the District Court's denial
+of defendant's motion, pursuant to Rule
+33, Federal Rules of Criminal Procedure,
+18 U.S.C.A., for a new trial on the ground
+of newly discovered evidence. In each
+case we affirm.
+The issues in the appeal from the
+judgment of conviction will be considered
+first. The defendant was indicted in the
+Distriet of Minnesota under 18 U.S.C.A.
+§ 2421 for having procured interstate
+transportation for one Gloria Jean Hull
+(hereinafter "Miss Hull") from Minneapolis, Minnesota to New York City
+"for the purpose of prostitution, debauchery and other immoral purposes,
+and with intent on the part of [defendant] to induce, entice, and compel [Miss
+Hull] to give herself up to the practice
+of prostitution and debauchery and other
+immoral practices", and under 18 U.S.
+C.A. § 2422 for having persuaded, induced, enticed and caused Miss Hull to go
+from Minneapolis to New York for the
+aforesaid purposes.!
+Jean Hull for travel in interstate commerce from Minneapolis-St. Paul Interantional Airport, Wold Chamberinin
+Fiell, District of Minnesota, to New
+York City, State of New York, for the
+to induce, entice, and compel the said
+Gloria Jean Hull to give herself up
+to the practice of prostitution and
+debauchery and other Immoral prac
+tices, whereby the said Gloria Jean
+
+
+BATSELL Y. UNITED STATES
+397
+Cite as 403 F.24 395 (1909)
+The two indictments were consolidated
+key prosecution witness after the prosfor trial.. What is hereinafter referred
+ecution had been allowed to recall her
+to as the first trial was commenced in
+the United States District Court in Minon four separate occasions, constituted
+reversible error."
+neapolis, Minnesota, before the Honor- In order to properly resolve defendant's
+able Earl R. Larson and a jury on March
+contentions, it is necessary to analyze
+On March 27, 1967, after
+in some detail the proceedings of the
+considerable testimony had been taken,
+firat and second trials.
+the court granted defendant's motion for
+a mistrial.
+During the firat trial, Miss Hull, the
+- The second trial, also before Judge
+alleged victim of the unlawful act charg-
+Larson and a jury, commenced in St.
+ed against the defendant, suffered a
+Paul, Minnesota, on June 5, 1967. This
+"memory loss" until recalled by the prosetrial resulted in defendant's acquittal of
+cution for the fourth time. Upon being
+the charge under 18 U.S.C.A. § 2421
+recalled the fourth time, she testified,
+(the first. indictment) and defendant's
+after stating that her memory had reconviction for violation of 18 U.S.C.A.
+turned, that she made the trip from
+Minneapolis to New York without in-
+§ 2422 (the second indictment).
+ducement, enticement or persuasion by
+The defendant relies generally on three
+the defendant; that she went to New
+grounds in his appeal from the judgment
+York to run away from her problems;
+of conviction:
+that she did not know what she would be
+"I.
+"The defendant was denied a fair
+trial because the jury's confusion as to
+the word 'inducement' in the statute
+18 U.S.C. § 2422 was never clarified
+even after the jury requested clarification and the confusion was manifest
+in the inconsistent verdicts returned
+by the jury.
+doing in New York; that although she
+did have sexual adventures in New York,
+she did so of her own free accord; that
+she boarded the airplane in Minneapolis
+with the defendant; and that defendant
+purchased her plane ticket. At this
+point defendant's motion for a mistrial
+was granted.
+The second trial was delayed until Miss
+Hull, who disappeared after the first
+*II.
+trial, could be located by the FBI and
+confined as a material witness under a
+stories told by complaining witness,
+[the] evidence was insufficient to sugtain conviction.
+$10,000 bond. At this trial, Miss Hull
+testified that she was 18 years of age at
+the time of the alleged unlawful acts;
+that she first met defendant when she
+"III.
+"Refusal of the court to allow defendant to recall Gloria Jean Hull, the
+was 14 or 15; that she attended a reform
+school for girls at Sauk Center, Minnesota: that the night before the trip to
+Hull was transported in interstate commerce in violation of Title 18 U.S.C.
+The second indictment states:
+The United States Grand: Jury
+chargea:
+Fourti Diviaion,
+HAROLD LEE BATSELL
+nesota, to New York City, State of New
+York, for the purpose of prostitution
+and debauchery and for other immoral
+purposes and with the intent and purpose on the part of Harold Lee Batsell that Gloria Jean Hull should engage in the practice of prostitution and
+debauchery and otber immoral praotices, and Harold Lee Batsell did thereby knowingly eause Gloria Jean Hull
+to go and to be carried and transported
+se a pessenger upon the line and route
+of Northwest Orient Airlines, a common
+carrier in interstate commerce, in
+violation of Title 18, United States
+Code, Section 2422."
+
+
+398
+New York she stayed at the defendant's
+"JURY FOREMAN: There seemed
+father's home in Minneapolis, although
+to be some confusion on our part esher mother's residence was also in Minnepecially on the term 'inducement' and
+apolis; that she was driven to the airalso in the instructions on the four
+port accompanied by the defendant's
+points that had to do with each insister, the sister's boy friend, and the
+dictment. This is what we got hung
+defendant; that she went to New York
+up on.
+voluntarily after having been persuaded
+"THE COURT: I didn't give you
+by the defendant; that it was "understood" that what she would be doing in
+any definition in my instructions of
+New York would be prostitution; that
+inducement or persuasion or enticement, which are the terms that are
+after the defendant "persuaded" her to
+go to New York, she went voluntarily:
+used in the instructions. I didn't give
+that defendant purchased her airplane
+you any definitions of those terms
+ticket; and that defendant boarded the
+because I assumed that these are terms
+in common usage. On the matter of
+plane with her. She further testified
+that the defendant drove her from the
+"intent,' I did give you three instruc-
+New York airport to the Park Sheraton
+tions which might have some application on each of the two indictments.
+Hotel, where they met Nancy Ubel (who
+later became defendant's wife); that de-
+I listed the essential elements, which
+Do you want me
+fendant then took her to the Taft Hotel,
+where she registered after receiving $20
+to reread all of the instructions? Do
+you want me to reread the instructions
+from him; that he took her to her first
+as they go to the matter of 'intent' and
+"trick" the next morning; and that he
+also the essential elements for each
+subsequently took her to two or three
+other
+"tricks". During her sojourn in
+indictment?
+New York she continued to earn money
+"JURY FOREMAN: I think so."
+as a prostitute, giving most of it to
+After reiterating the essential ele-
+Nancy Ubel and to the defendant. Miss
+ments for the § 2421 indietment, the
+Hull's testimony with reference to the
+court stated:
+trip from Minneapolis to New York, the
+fact that the defendant accompanied her
+"With respect to Title 18, U.S.C.,
+on the trip, her activities in New York as
+Section 2422, I instructed you as fol-
+a prostitute, and the defendant's aclows:
+quaintance
+and relationship with her
+"The essential elements required to
+there is substantially corroborated by
+be proved in order to establish the
+the testimony of other witnesses.
+The
+offense charged under Title 18, Section
+defendant himself did not testify.
+2422, are these:
+The record indicates that the case was
+*1. The act of inducing, enticing
+submitted to the jury in the early after-
+• or persuading a woman or girl, in this
+noon of June 8, 1967. At 4:45 p.m.
+case Gloria Jean Hull, to travel in
+the jury returned to the courtroom and
+interstate commerce.
+the following transpired:
+"2. Doing such act with the intent
+"THE COURT: I have this written
+or purpose that the woman or girl
+note from the Foreman of the jury:
+would engage in prostitution or other
+*Please reread the final instructions to
+immoral practices.
+the jury including a definition
+terms, especially inducement and in-
+"8. Causing the interstate transtent; also, the specific four points on
+portation of a woman or girl, in this
+each indictment.' This is signed by
+case Gloria Jean Hull, by common
+Mr. Cherrier, your Foreman. Do you
+carrier for the immoral purpose.
+want me to read all of the instruc-
+"4. Doing such act or acts knowingly and wilfully.
+
+
+BATSELL UNTED STATES
+399
+Cite as 403 F.2d 305 (10SH)
+"The burden is on the prosecution
+As noted, defendant contends on appeal
+to prove all of the essential elementa
+that he was denied a fair trial because
+beyond a reasonable doubt.
+the Jury's alleged confusion as to the
+"(I will reread these four essential
+meaning of the word "inducement" in
+elements.)
+§ 2422 "was never clarified even after
+"(The four essential elements were
+the jury requested clarification • * *"
+reread.)
+In response to the jurors' written request, the trial court did not substitute
+"JURY' FOREMAN:
+One other
+point that you brought out earlier had
+to do with a person going on a common
+carrier with or without—I believe it
+was wilfully inducing-for the purpose
+of inducing an illegal act. I believe
+that was one of the four points on the
+intent.
+*THE COURT: You are talking
+about these four points in the essential
+elements?
+"JURY FOREMAN: Yes.
+"THE COURT: I will reread the
+essential elements in 2421.
+or use a synonym for the term "inducement" as used in the instruction or the
+words "induce" or "induces" as used in
+the statutes. Instead the court made it
+perfectly clear that the words
+"persuasion" and "enticement"
+were to be given their common usage and
+had not acquired a apecial legal meaning.
+The jurors, and defendant's counsel, appeared satisfied with such explanation.
+Furthermore, the court carefully and
+meticulously set out the elements of the
+offenses under 55 2421 and 2422.
+[1-4] The word "induces" in § 2422
+is one of common usage and meaning
+and requires no explanation or definition.
+*The other section, Section 2422, the
+four elements are:
+*1. The act of inducing, enticing
+or persuading a woman or girl, in this
+case Gloria Jean Hull, to travel in
+interstate commerce.
+"2. Doing such act with the intent
+purpose that the woman or girl
+rould engage in prostitution or other
+immoral practice.
+"3. Causing the interstate transportation of the woman or girl by
+common carrier for the immoral pur-
+In the first Mann Act case
+before the
+Supreme Court, Caminetti
+States, 1917, 242 U.S. 470, at 485-486,
+37 S.Ct. 192, at 194, 61 L.Ed. 442, the
+court stated:
+"It is elementary that the meaning
+of a statute must, in the first instance,
+be sought in the language in which the
+act is framed, and if that is plain, and
+if the law is within the constitutional
+authority of the law-making body
+which passed it, the sole function of
+the courts is to enforce it according
+to its terms. [Citations omitted.]
+"4. Doing such act or acts knowingly and wilfully.
+"Perhaps this might be sufficient
+for your purposes now."
+The jurors thereafter appeared satisfied with the court's explanation and
+defendant's counsel took no exception and
+made no request. On the following day,
+JuDe 9, 1967, the jurora returned their
+verdiet of not guilty as to § 2421 and
+guilty as to § 2422. Upon defendant's
+request, the jurors were polled. Each
+answered in the affirmative as to the
+"Where the language is plain and admita of no more than one meaning the
+duty of interpretation does not arise
+and the rules which are to aid doubt-
+Iul mean egs need no discussion.
+• Bathbone, 175 U.S. 414,
+421 [20 S.Ct 155,
+, 44 L.Ed. 219].
+There is no ambiguity in the terma
+of this act. It is specifically made an
+to knowingly transport or
+cause to be transported, ete., in inter
+state commerce, any woman or girl for
+the purpose of prostitution or debauchery, or for 'any other immoral
+purpose,' or with the intent and pur-
+
+
+400
+pose to induce any such woman or girl F.2d 66, 67-68; Rimerman
+United
+to become a prostitute or to give her-
+States, B Cir., 1967, 874 E:20 251, 255,
+self up to debauchery, or to engage in
+cert. denied, 1967, 387 U.S. 931. 87 S.Ct.
+any other immoral practice.
+2053, 18 L,Ed.2d 992; Aggers | United
+"Statutory words are uniformly pre-
+States, 8 Cir., 1966, 366 F24
+sumed, unless the contrary appears, to
+cert. denied, Coates
+United States,
+be used in their ordinary and usual
+1967, 385 U.S. 1010,
+87 S.Ct. 719, 17
+sense, and with the meaning commonly
+L.Ed.2d 548. We find no error, plain or
+attributed to them. * • •"
+otherwise, in the court's failure to furphasis supplied.)
+ther elucidate the meaning of the words
+This couth aid through Judge Cordine?
+"inducement" or "induces".
+in Terminal R. Ass'n of St. Louis
+[5-7] The defendant contends that
+Howell, 8 Cir., 1948, 165 F.2d 135, 140:
+the fact that the jury returned a verdict
+"It would be strange indeed if it
+of not guilty under § 2421 and guilty
+could be said to be error to lay down
+under § 2422 indicates its confusion as to
+the law in the exact language of the
+the meaning of "inducement" or
+statute upon which the action
+duces".
+We do not agree.
+within the province of the jury
+to find as it did. Even though it must
+Furthermore, we
+said in Williams
+be conceded that the evidence offered
+United States, 8 Cir., 1964, 328 F.
+by the government would fully have justi-
+256, 262, cert. denied, 1964, 377 U.S.
+fied a jury finding of guilty under both
+969, 84 S.Ct. 1651, 12 L.Ed.2d 739:
+§ 2421 and § 2422, the offenses pro-
+"A court may and generally should,
+where the law governing a case is ex-
+United States,
+pressed in a statute, employ the lan-
+8 Cir., 1945, 146 F.2d 536, 587, 156 A.L.R.
+guage of the statute in its instructions
+Even if it could be said that the
+Terminal R. Ass'n of St. Louis
+verdicts were inconsistent, this court has
+layard! Cir., 165 F.2d 136, 140
+held that the inconsistency of verdiets up-
+United States, 94 U.S.App
+on separate counts of an indietment does
+D.C. 347. 215 F.2d 336, 339. Except
+not entitle the defendant to a reversal
+where the statute is complex or not
+of the judgment upon the counts for
+expressed in ordinary
+which is not the situation here-any
+States, 8 war, 0968, 396 F.2d 60, 67-68;
+States, 8 pir.,
+amplification which a party may desire
+United States, 8 Cir., 1966,
+to have made must be the subject of
+366 F 2d 744, 748, cert. denied, Coates
+a requested instruction by him."
+United States, 1967, 385 U.S. 1010,
+See, also, Caldwell United States,
+87 S.Ct. 719, 17 L.Ed.2d 548.
+8 Cir., 1964, 838 F.zd 385, 391, cert.
+Under the defendant's general
+denied, 1964, 380 U.S. 984, 85 S.Ct.
+tion that he was denied a fair trial is the
+1354, 14 L.Ed.2d 277. In addition, Rule
+claim that the time for defense counsel's
+30, Federal Rules of Criminal Procedure,
+summation was unreasonably limited by
+18 U.S.C.A., precludes the assignment as
+the trial court. After both sides had
+error of any inaccuracy in the instruc- rested and the attorneys were about to
+tions without first having called the commence their arguments to the jury.
+attention of the trial court thereto, thus the court suggested that counsel should
+giving it the opportunity of making cor- limit themselves to not more than one
+No objection or exception was
+hour on a side. After defense counsel
+taken here and most certainly this is not had argued for more than an hour, he
+a plain error situation under Rule 52(b).
+was interrupted by the court and his
+inger | United States, 1965, 880 U.S
+attention called to the matter of time.
+85 S.Ct. 783, 13 L.Ed.2d 630;
+He was, however, granted another thirty
+Jones v. United States, 8 Cir., 1968, 396
+In all, defendant's counsel
+
+
+BATSELL V. UNITED STATES
+401
+Cite as 403 F.2d 305 (1068)
+used one hour and forty minutes for
+perieneed and trying his first felony
+his argument.
+case in federal court. We find no error.
+[8,9]
+In presiding over a jury trial,
+[10] Appellant's next contention is
+a judge is required to exercise his diathat the evidence was insufficient to suscretion in many ways, including the detain conviction because of the contratermination of the time to be allowed for
+dictory stories told by Miss Hull, the
+argument to the jury on each side, the
+prosecution's main witness. The conflict
+length of direct and cross-examination
+between Miss Hull's testimony at the
+of witnesses, the keeping of opening
+first and second trials was substantially
+statements within proper bounds, the
+and repetitiously brought to the jurors'
+proper conduct of parties, witnesses and
+attention during her extensive cross-excounsel, the excluding of witnesses from
+the courtroom during the examination of
+amination. It was the function of the
+jury to evaluate this testimony and sepaother witnesses, etc. This case was
+rate fact from fiction. Evidence is not
+neither complex nor protracted in extent.
+necessarily insufficient merely because
+Defense counsel succeeded in obtaining
+a witness' testimony has been contradicone hour and forty minutes for his sumtory and the explanations therefor diffimation, despite the court's previous sugcult of belief.
+We also note that Miss
+gestion that each side limit itaelf to one
+Hull's testimony concerning defendant's
+hour. At the close of defense counsel's
+persuasion of her to travel from Minneargument, he made no complaint to the
+apolis to New York City accompanied by
+court and at no time did he point out any
+the defendant and for the purposes of
+issues or facts which he had not had
+prostitution is substantially corroborated
+time to discuss with the jury. At no
+by other testimony. We find no insuffitime did counsel object to the original
+one-hour limitation given by the trial
+court, said in Butler I United States, 8
+Сіr., 1963, 317 F.2d 249, 257, 6 A.L.R.3d
+"It is axiomatic that the limitation
+of time for arguments of counsel is
+within the sound discretion of the
+"A reversal may be required where
+counsel is restricted within unreasonable bounds so that he is unable to fully
+and fairly present his case."
+see, also, United States | Mills, 6 Cit
+1966, 366 F.2d 512; United States i
+Barnard 1 Cited State, 9 E.., 1955,
+342 F.2d 309, cert. denied, 1965, 382 U.S.
+948, 86 S.Ct. 408, 15 L.Ed.2d 356, re
+earing denied, 1966, 382 U.S. 1002, 86
+S.Ct. 567, 15 L.Ed.2d 491. Here, the
+limiting of counsel to one hour of argument on each side was not, in our opinion, an abuse of discretion. In granting
+additional time thereafter, the court exercised substantial liberality with defense counsel, who claimed to be inex-
+Defendant's last claim of error in his
+appeal from the judgment of conviction is
+that the trial court refused to allow him
+to recall Miss Hull after the prosecution
+had been allowed to recall her on four
+separate occasions during the first trial.
+Be that as it may, Mias Hull was called
+by the prosecution but once during the
+second trial, which is the trial which resulted in defendant's conviction and with
+which we are here concerned.
+Hull's alleged loss of memory during the
+first trial and her inconsistent statements were well gone over in croasexamination; an examination of the
+transcript reveals that 38 pages thereof
+were utilized by government counsel in
+direct examination of Miss Hull, whereas
+defense counsel's cross-examination extends over 78 pages. As defense counsel
+approached the termination of his cros
+xamination, the following colloquy o
+truth now?
+"A Yes, I am telling the truth now.
+
+
+"Q Are you certain that tomorrow
+We turn now to defendant's appeal
+you will not have a new story?
+from the District Court's denial of de-
+"A I am certain I will not have a
+fendant's motion, pursuant to Rule 33,
+Federal Rules of Criminal Procedure, for
+"Q Then why for a day and one-
+a new trial on the ground of newly dishalf did you tell the Honorable Court
+While defendant's apand the ladies and gentlemen of the
+peal from his judgment of conviction was
+jury that you couldn't remember an
+pending in this court, he filed the above
+thing—a simple fact of whether y
+motion on the basis that Miss Hull, on
+ever boarded a plane?
+March 6, 1968, had repudiated her testimony and claimed that the defendant did
+"A I told you that answer a million
+not induce, persuade or entice her to go
+times already.
+from Minneapolis to New York in viola-
+"THE COURT: This is repetitious,
+tion of the Mann Act. This court then
+stayed disposition of the appeal and di-
+"MR. OLKON: No further quesrected that the District Court consider
+the motion for new trial. On April 17,
+"MR. CONVERY: No further ques-
+1968, the District Court held a hearing
+at which Miss Hull (then Mrs. Harpole)
+"THE COURT: You may be extestified. She maintained that her testimony at the second trial was the truth.
+In denying the motion for a new trial on
+"MR. OLKON: Your Honor, I
+the grounds of newly discovered evidence,
+would like to possibly recall her.
+the trial court stated:
+"THE COURT: The direct examina-
+"On April 17, 1968, Mrs. Harpole
+tion was one hour and eight minutes
+[Miss Hull] testified
+and you have had one hour and 45
+March 6, 1968, she had knowledge of
+minutes of cross-examination. If there
+a threat from a younger brother of a
+is more cross-examination you will confriend of defendant that if the defendtinue it right now.
+ant was convicted she would be killed.
+"MR. OLKON: Okay, there is more
+She testified also that on or about
+cross-examination."
+March 6 that she was afraid of her
+safety and the safety of her family.
+Cross-examination then continued for
+three more pages, after which defense
+It should be noted here that during
+counsel said, "No further questions."
+the first trial the victim's mother had
+been assaulted by persons considered
+We find no abuse of discretion
+by the mother to be friends of the
+upon the part of the trial court. An examination of the entire record indicates
+complete fairness by the court in all
+rulings and in granting defendant's requests.
+The trial court did not limit
+the cross-examination of Miss Hull, but
+directed only that if there was to be
+further cross-examination, it was to be
+completed at that time. As noted, after
+defense counsel continued with cross-
+"Again, it has to be emphasized that
+the victim testified on April 17, 1968,
+that she told the truth at the second
+trial. She has not, therefore, recanted
+her testimony. The threata the victim describes to her person are real.
+The threats or coercion defendant's
+counsel deacribes are in his mind as
+indicated in the March 6, 1968, tranexamination for some time, he ended with
+the statement, "No further questions."
+A thorough examination of the entire
+record convinces us that defendant had
+a fair trial and that no error was committed.
+[12,13] The trial court denied the
+motion, pointing out that motions fo
+new trial on the grounds of newly dis
+
+
+FLEISCHER T. C. I. B.
+403
+of a material witness should be viewed
+with disfavor.
+We also find that such
+motions are generally addressed to the
+sound judicial discretion
+of
+the trial
+court and that there will be no reversal
+on appeal except for a clear abuse of that
+discretion.
+United States
+Johnson,
+194: Comell, 106, Gnited States, 8 LEr.
+8 Cir.
+333, cert. denied, Caudle
+856 U.S. 921,
+Nathan FLEISCHER, Petitioner,
+denied, 1958, 356 U.S. 964, 78 S.Ct.
+991, 2 L.Ed.2d 1072
+[14] In McCroskey - United States,
+8 Cir., 1965, 339 F.20
+895, 897, we
+COMMISSIONER OF INTERNAL BEV-
+ENUE, Respondent.
+Nos. 219-220, Dockets 31638-31639.
+United States Court of Appeals
+Second Circuit.
+Argued April 9, 1968.
+Decided Oct. 31, 1968.
+"Thirty-fi United States, 32 F.2d
+127, 130 (8 Cir. 1929), listed five requirementa generally
+recognized for
+the granting of a new trial for newly
+discovered evidence: the evidence must
+in fact be newly discovered since the
+Proceedings on petition for review of
+decision and order of Tax Court that
+taxpayer's deductions for educational expenditures were not permissible. The
+Court of Appeals, Waterman, Circuit
+which the court may infer diligence:
+Judge, held that evidence sustained findthe evidence must not be merely cumuings that taxpayer, who was employed as
+lative or impeaching; it must be ma- an entertainer to provide hotel guests
+terial; and it muat be such that, on
+with hypnotic demonstrations and lee-
+a new trial, it 'would probably protures, did not undertake his work towards
+duce an acquittal".
+We have repeated- a doctorate in psychology primarily to
+ly recognized these in recent cases.
+maintain or to improve skills required by
+his employment or to meet express requirements of his employer and that his
+educational expenditures were not de-
+(333]; Edgar Finley, supra, p. 537
+of 312 F.2d [533]."
+The guide lines for passing on a motion
+for a new trial on the ground of newly
+11, 19, cert. denied, 1967, 386 U.S.
+976, 87 S.Ct. 1171, 18 L.Ed.2d 136;
+
+
+478
+272 FEDERAL REPORTER, 2d SERIES
+like the state courta of California where 1 Prostitution 4
+certain discretion lies with the trial court
+Evidence was sufficient to
+sustain
+judge to strike "priors," or find them
+conviction of a defendant for violation
+proved or not proved, this discretion
+of statute prohibiting the inducing of a
+does not exist under the law the Conwoman to go from one place to another
+gress has seen fit to enact for the guidin interstate commerce for purpose of
+ance of federal court judges.
+We can
+prostitution. 18 U.S.C.A. § 2422.
+debate the merits of the matter, but y
+cannot legislate. No cases are cited
+2. Prostitution e-4
+Fact that woman had previously exappellant on this point, and we find no
+pressed to operator of a house of prostimerit in it.
+tution her desire to return to such house
+The judgment of conviction is affirmed.
+or fact that such person paid her own
+fare in traveling in interstate commerce
+by common carrier to return to house
+after operator thereof had phoned and
+requested her to come back was immaterial, in view of other evidence, with
+respect to prosecution of operator for
+knowingly inducing a woman to go from
+Catherine Loulse HARMS and Ruth Twis.
+one place to another in interstate comdale Cousins, Appellants,
+merce for purpose of prostitution.
+V.
+U.S.C.A. § 2422.
+UNITED STATES of America,
+Appellee.
+8. Prostitution •=4
+No. 7943.
+Where person operating a house of
+United States Court of Appeals
+prostitution made a phone call to a woman she had previously known to induce
+Fourth Circuit.
+such woman to return to work for oper-
+Argued Oct. 7, 1959.
+ator, it was not essential that govern-
+Decided Nov. 20, 1959.
+ment, in prosecuting operator for violation of White Slave Traffic Act, show
+that operator directed or knew that other
+Prosecutions for violations of White
+woman would travel by interstate com-
+Slave Traffie Act. The United States
+merce, and having shown the knowing
+District Court for the Eastern District
+inducement or persuasion of woman to
+of Virginia, at Norfolk, Walter E. Hoffcome from one state to another and her
+man, J., entered judgment of conviction
+resultant trip by interstate carrier, goras to one defendant on three counts and
+ernment covered essential elements necjudgment of conviction as to the other
+essary to justify conviction of operator
+defendant on one count and they apfor knowingly inducing a woman to go
+pealed. The Court of Appeals, Field,
+from one place to another in interstate
+District Judge, held that evidence was
+commerce for purpose of prostitution.
+sufficient to sustain conviction of one
+18 U.S.C.A. § 2422.
+defendant on count of inducing a woman
+to go from one place to another in inter- 4. Prostitution ®-1
+state commerce for purpose of prostitu-
+Under statute making it a criminal
+tion, but that evidence was insufficient offense for any person knowingly to into sustain a conviction of defendants
+duce or coerce any woman or girl to go
+with respect to an alleged conspiracy to
+from one place to another in interstate
+commit offenses in violation of White
+commerce for purpose of prostitution,
+Slave Traffle Act.
+requisite inducement is any offer suffi-
+Affirmed in part, reversed in part
+cient to cause woman to respond. 18
+and remanded.
+U.S.C.A. § 2422.
+
+
+HARMS V. UNITED STATES
+479
+Cite as 272 # 2d 478
+5. Prostitution •4
+dence, and even though it is not neces-
+Evidence was insufficient to sustain sary that such circumstantial evidence
+conviction of operator of house of prosexclude every reasonable hypothesis contitution for violation of White Slave
+sistent with innocence, evidence should
+Traffie Act where operator, not knowing
+be sufficient to prove this element of
+either of the women involved prior to
+crime beyond a reasonable doubt.
+their time of arrival, agreed to allow
+such women to come to work at opera-
+10. Conspiracy 24
+tor's house after such women had tele-
+A party cannot conspire with him.
+phoned operator who was not shown to
+self.
+have known that call came from out of 11. Criminal Law @1177
+state. 18 U.S.C.A. § 2422.
+Where trial court found defendant
+6. Prostitution P1
+guilty on three counts and imposed a gen-
+Under statute making it criminal
+eral sentence and fine jointly upon the
+offense for anybody knowingly to percounts, and on appeal it was found that
+suade, induce, entice or coerce any womdefendant was improperly convicted on
+an to go from one place to another in
+two of the counts but the penalty iminterstate commerce for purpose of prosposed on her did not exceed that which
+titution, gravamen of offense is the inmight have been imposed on the one reducement or persuasion to travel in intermaining count had it stood alone, constate commerce for immoral purposes,
+viction of defendant must be affirmed.
+since the immoral acts or pursuits in
+themselves are exclusively the subject of
+regulation under police power of state
+Robert G. Doumar and Frederick T.
+where they are committed, and statute
+Stant, Norfolk, Va., for appellants.
+makes intent to transport women in in-
+John M. Hollis, U. S. Atty., Norfolk,
+terstate commerce for such immoral pur-
+Va., for appellee.
+poses an element of the crime, and government must present evidence showing
+Before HAYNSWORTH and BORE-
+intent of defendant in regard to inter-
+MAN, Cireuit Judges, and FIELD, Disstate aspect of offense and this intent
+trict Judge.
+must necessarily exist prior to or concurrent with the interstate trip of vic-
+FIELD, District Judge
+tim. 18 U.S.C.A. § 2422.
+Appellants, Harms and Cousins, who
+7. Conspiracy -47
+are sisters, along with one, Connie Jean
+Evidence was insufficient to sustain
+Day, were named as defendants in a five
+conviction of defendants, who were siscount indictment charging violations of
+ters, for conspiracy to violate White
+the White Slave Traffic Act. Harms was
+Slave Traffie Act, 18 U.S.C.A. §§ 371,
+charged in each of the first four counta
+with substantive offenses, the first count
+8. Conaplracy $-47
+charging her with violation of 18 U.S.C.
+§ 2423, involving a minor female, Sandra
+Proof of overt acts in themselves is
+The second count charged
+not sufficient to prove a conspiracy for
+it must be established that a conspiracy
+her with a violation of 18 U.S.C. § 2422
+existing at the time of the commission
+respectively.
+9. Conspiracy $-47
+The fifth count which named Cousins
+be established by circumstantial evivile he eye of cospital ery and charad a conspiracy a der 18 U.8.
+
+
+480
+C. § 371 to commit offenses in violation
+of the sections above referred to covering
+the period from November, 1955, to the
+date of the indictment.
+At the trial, the Court acquitted the
+defendant Harms on the first count of
+the indictment upon the motion of the
+Government. At the conclusion of the
+Government's evidence, the Court granted defendant's motion for judgment of
+acquittal as to the fourth count as well
+as the motion for acquittal of the third
+defendant, Connie Jean Day, on the fifth
+count.
+The jury returned a verdict of guilty
+on the second, third and fifth counts as
+to the defendant, Harms, and a verdict
+of guilty on the fifth count as to the
+defendant, Cousins. The Court denied
+appellant's motion to set aside the verdict
+and entered judgment of conviction of
+both defendants from which they have
+272 FEDERAL REPORTER, 2d SERIES
+[1,2] Under this evidence, we feel
+that the conviction of Harms on the second count unquestionably should be affirmed. The evidence set out above of
+the telephone invitation from Harms to
+Bruno and her response in making the
+interstate trip was sufficient to sustain
+the jury's finding that Harms effectually
+induced or persuaded Bruno to make the
+trip. McGuire v. United States, 8 Cir.,
+152 F.2d 577; La Page v. United States,
+8 Cir., 146 F.2d 536, 156 A.L.R. 965.
+The fact that Bruno had previously expressed the desire to return to Norfolk
+or that she paid her own fare, is immaterial in view of the other evidence and
+state Ted dice, de20 785.
+United
+[3] Nor do we feel that it was essential that the Government show that
+Harms directed or knew that Bruno
+would travel by interstate carrier. Having shown the knowing inducement or
+persuasion of Bruno to come from New
+With reference to the conviction of the
+Jersey to Virginia. and the fact of the
+appellant Harms on the second count, it
+resultant trip by interstate carrier, the
+is contended that there was not sufficient
+Government had covered the essential
+evidence to show that Harma knowingly
+elements necessary to justify a convieexercised the requisite persuasion or intion under Section 2422. It was not necducement of Bruno to travel in interstate
+essary for the Government to go further
+commerce. It is further contended that
+and attempt to show that Harms knowit was essential that the Government
+ingly caused the victim to travel by comshow that Harms either directed or knew
+mon carrier either by direction or knowlthat the victim, Bruno, would travel by
+edge that the vietim, Bruno, would use
+common carrier. The evidence indicated
+that mode of transportation.
+that Bruno and Harms had become ac-
+a word of very broad import and ita
+quainted in 1955 and from that time up
+meaning 18, generally known
+until January, 1957, Bruno had worked
+ed States - Kenofskey, 243 U.S. 440, 37
+as a prostitute for Harms in Norfolk on
+S.Ct. 438, 61 L.Ed. 836. The knowing
+several occasiona. In November, 1956,
+persuasion to make the interstate trip,
+Bruno left Norfolk to return to New
+of course, must be shown with some de-
+Jersey with the understanding that she
+gree of particularity, but once the knowmight return to Norfolk to resume her
+ing persuasion has been shown, if the
+work there in January. On January 2
+trip by interstate carrier follows, the
+or 3, 1957, Harms made a telephone call
+offense is complete. In considering the
+to Bruno in Atlantic City, New Jersey,
+comparable statute (18 U.S.C. $ 399)
+asking her to return to Norfolk and it
+was agreed that Bruno would come to
+Norfolk on January 7, 1957. On that
+date, Bruno traveled to Norfolk by interstate air line carrier, and, after her arrival, engaged in acts of prostitution in
+establishments maintained by Harms.
+Court stated:
+"It is also suggested that there
+must be some direct act showing an
+intent on the part of the inducer
+
+
+HARMS V. UNITED STATES
+481
+Cite as 272 F.2d 478
+that the transportation shall be by
+and Miller engaged in acta of prostitucommon carrier.
+This section does
+tion in Harms' establishment.
+not say so, but plainly says that one
+who induces and who shall thereby
+[5, 6] The evidence indicated that
+knowingly cause interstate com-
+Harma knew neither of these women primerce by common carrier is guilty
+or to the time of their arrival in Norfolk.
+of the offense if such transporta-
+The evidence also shows that both teletion follows: An affirmative direcphone calls were initiated by Ponder and
+tive act is not involved. The inducethat it was her suggestion that both she
+ment in and of itself, without conand Miller come to work for Harms. The
+sideration of intent and with no furevidence fails to show that Harms knew
+ther direct act, is the moving cause
+that Ponder was making the call from
+any point outside of the State of Virmay be any offer sufficient to cause
+ginia. While we do not know that Harms
+the woman to respond. The inducewould have been deterred or acted otherment sets in motion the successive
+wise than she did had she known that
+acta that constitute the crime. It is
+Ponder and Miller were calling from De-
+unnecessary to show control of the
+troit, neverthelesa we feel that the abmedium of transportation by the insence of evidence of such knowledge on
+ducer. It is sufficient if the accused
+the part of Harma has an important bearknows or should have known that
+ing on the validity of the conviction on
+interstate transportation by comthis third count.
+The constitutionality
+mon carrier would reasonably reof the White Slave Traffie Act has been
+sult and if it does."
+upheld as a proper exercise of the powers
+of Congress solely under the commerce
+[4] We agree with the above language to the effect that the requisite inducement is any offer sufficient to cause
+clause of the Federal Constitution, art. 1,
+§ 8, cl. 3. Hoke
+• United States, 227
+U.8. 808, 33 S.Ct. 281, 57 L.Ed. 523.
+the woman to respond, and that since
+Accordingly, the gravamen of the offense
+is the inducement or persuasion to travel
+suaded Bruno to make the trip then she
+in interstate commerce for the immoral
+"knowingly caused" Bruno to travel by
+purposes set forth in the Act. The iminteratate carrier within the meaning of
+moral acts or pursuits in themselves are
+the statute.
+excluaively the subject of regulation un-
+Tbe evidence with respect to the third
+der the police power of the state where
+count involving Linda Fay Ponder prethey are committed. The statute makes
+sents a different situation. As to thia
+the intent to transport the woman in
+count the evidence shows that sometime
+interstate commerce for such immoral
+prior to January 21, 1957, Ponder made
+a call from Detroit, Michigan, to Harms
+ed States
+purposes an element of the crime. Unit-
+Grace, 2 Cir., 73 F.2d 294;
+in Norfolk, asking Harms if she could
+Sloan | United States, 8 Cir., 287 F. 91.
+come to Norfolk to work for her as a
+It seems clear that the Government must
+prostitute. After queationing her in represent evidence showing the intent of
+gard to her age and appearance, Harms
+the defendant in regard to the interstate
+agreed that she would have a place for
+aspect of the offense. This intent of the
+Ponder.
+Ponder later called Harms
+again, asking if Ann Miller could come
+Iterstati
+with her, to which Harms agreed. Both
+Ponder and Miller traveled to Norfolk by
+interstate air line carrier on January 21,
+slates, 2 Cir., 12 F.2d 352; United States
+- Grace, supra. With respect to the
+1957. Upon their arrival at the Norfolk
+Airport, Ponder called Harms and pursuant to that call a meeting place was
+that she was inducing or persuading Ponarranged and thereafter both Ponder
+der to make an interstate trip to take
+372 F.2d—31
+
+
+482
+272 FEDERAL REPORTER, 2d SERIES
+her place in the admittedly illegal estabsister a hand, but it was her sister's
+lishment of Harms.
+The record shows
+business."
+that the District Judge granted a mo-
+Undoubtedly, there was a sufficieney of
+tion for judgment of acquittal with reevidence to convict Cousins of conspiracy
+spect to the fourth count involving Ann
+to maintain a house of prostitution, but
+Miller, and it is our opinion that the
+it does not necessarily follow that the
+Court should likewise have granted the
+evidence was sufficient on the charge of
+motion for judgment of acquittal on the
+conspiracy to violate the White Slave
+third count for the reason set forth
+Act in this case.
+Concededly, Cousins
+above.
+was absent from active participation on
+[7]
+With respect to the fifth count
+the Norfolk scene from early 1955 until
+charging Harms, Cousins and Day with
+after January 2, 1957. The government
+conspiracy, as we bave already noted the
+agent who had Harms under surveillance
+District Court granted a motion for
+during that period testifled that he had
+judgment of acquittal as to the defendnever seen Cousins during that entire
+ant, Day. While the indictment in the
+time nor until sometime after January.
+conspiracy count specified the period
+1957. She was not in Norfolk at the
+from November, 1955, to the date of the
+time of the call from Harma to Bruno.
+indictment, as a result of the disposition
+Under the circumstances, it would apof the first count, the District Judge in
+pear on the evidence that the conspiracy
+his charge to then
+jury indicated that the
+necessarily had to come into being, if at
+conspiracy, if ai
+did not take place
+all, subsequent to the telephone call to
+until shortly prin
+to January 7, 1957.
+Bruno and prior to her arrival at Nor-
+We think the Court acted correctly in so
+folk Airport on January 7th. There is
+confining the period of the alleged conno direct evidence of any agreement bespiracy and the question before us is
+tween Cousins and Harms, and, accordwhether the evidence supports the jury's
+ingly, the conviction of Harms on the
+verdiet on the conspiracy count pursuant
+alleged conspiracy rests solely on inferto such charge.
+ences drawn from her overt acts together
+The evidence shows that Harms and
+with the other evidence presented in this
+Cousins are sisters and were together in
+саве.
+a house of prostitution in Norfolk in
+[8,9] The overt acts of Cousins
+1954. However, Cousins moved to Florplaced her under a high degree of susida in the early part of 1955, and with
+picion. However, proof of overt acts in
+the exception of "two or three visits a
+themselves is not sufficient, for it must
+year," did not return to Norfolk until
+be
+established that the conspiracy
+or
+sometime after January 1, 1957.
+The
+agreement which is charged to have exevidence further shows that whenever
+isted and which is the gist of the offense
+she came to Norfolk during that period
+had been formed before and was existing
+she stayed at the residence of her sister,
+at the time of the commiasic
+of the
+Harms.
+overt act or acts. Dahly
+United
+mas ring aper or st
+States, 8 Cir., 50 F.2d 37
+United
+States v. Grossman, D.C., 55 F.2d 408.
+There must be proof of the unlawful
+running her establishments when the
+agreement, either expressed or implied,
+occasion demanded. Her assistance in a
+number of instances is clearly shown by
+the evidence. It is equally clear, how-
+8 Cir., 61 F.2d 250. The agreement of
+ever, that Harms was the "madam" and
+conspiracy may, of course, be proven and
+controlled both the purse and policy of
+established by circumstantial evidence.
+the business. The maid, Rebbie Knight,
+Glasser v. United States, 315 U.S. 60, 62
+in speaking of Cousins' activities, stated,
+"Well, she would maybe try to give her
+S.Ct. 457, 86 L.Ed. 680; Clune 1 United
+States, 169 U.S. 590, 16 S.Ct.
+-125, 40
+
+
+BUFORD Y. UNITED STATES
+Cite as 272 7.24 483
+483
+with innocence, nevertheless,
+State of Ohio, 297 U.S. 431, 56 S.Ct. 532,
+the evidence should be sufficient to prove
+80 L.Ed. 778.
+this element of the crime beyond a rea-
+As was stated in Dahly
+Affirmed in part, reversed in part and
+remanded,
+evidence is equally available with direct
+evidence to prove the conspiracy, but
+suspicion or conjecture cannot take the
+place of evidence. Guilt must be establiahed beyond a reasonable doubt, and,
+where the evidence is as consistent with
+innocence as with guilt, no conviction can
+properly be had." [50 F.2d 43.]
+When the evidence with respect
+to Cousins is appraised in this light, it
+occurs to us that it is not of such convincing degree as to warrant more than
+a mere probability or conjecture of guilt.
+With a total absence of direct proof of
+the essential agreement between Cousins
+and Harma, we feel that the inference
+drawn from the evidence with regard to
+Cousins on the fifth count is "so tenuous
+Travis SUrD, Appellant,
+UNITED STATES of America,
+Appellee.
+No. 16405.
+United States Court of Appeals
+Ninth Circult.
+Nov. 2, 1959.
+Rehearing Denied Dec. 10, 1959.
+as to amount to mere speculation
+United States, 4 Cir., 265 F.2d
+167, 173. We do not believe that the sum
+of the circumstantial elements in the record in this case is sufficient to support
+the conviction of the defendant Cousins
+on the conspiracy count; and since a person cannot conspire with himself or herself, it necessarily follows that the motion of both defendants as to the fifth
+count should have been granted.
+[11] Our conclusion requires the reversal of the conviction of Cousins and
+her discharge from further proceedings.
+Harms, however, received a general sentence of thirty months and a fine of $1,-
+000.00 imposed jointly upon counts two,
+three and five. We have found that she
+was improperly convicted on counts three
+Defendant was convicted of two substantive violations of narcotics laws and
+conspiracy. The United States District
+Court for the Northern District of California, Southern Division, Michael J.
+Roche, J., rendered judgment, and defendant appealed. The Court of Appeals,
+Healy, Circuit Judge, held that where informer had visited defendant's barber
+shop while equipped with radio transmitter and narcotics agent atated that
+he passed by barber ahop's entrance after
+informer had gone in, saw defendant and
+heard her make certain statement, at
+same time agent listening to radio receiver heard same atatement, and defendant subsequently admitted that it wa
+her conversation with informer to which
+and five. However, the penalty imposed
+upon her does not exceed that which
+might have been imposed under the secidentified sufficiently to allow in evidene
+ond count had it stood alone. The conthe admissions overheard by federa
+vietion on the second count being suff. agents.
+cient in itself to support the sentence,
+Affirmed.
+1. Holladd . Ualtod Stater, 348 U.8. 121, 75 8.Ct. 127, 00 KatEd. 150.
+
+
+Edward Raymond EGE, Joseph Boyd and
+Joseph Victor Bruno, Appellants,
+UNITED STATES of America,
+Appellee.
+No. 14955.
+United States Court of Appeals
+Ninth Circuit.
+April 1, 1957.
+Rehearing Denled May 15, 1957.
+One defendant was convicted of
+transporting woman from California to
+Arizona for purposes of prostitution and
+sach defendant and remaining two defendants were convicted of conspiring to
+transport women between California,
+Arizona, and Nevada for purposes of
+prostitution. The United States District Court for the Northern District of
+California, Southern Division, Edward
+P. Murphy, J., entered judgment, and
+The Court of Ap-
+peals, Chambers, Circuit Judge, held
+that, where the one defendant gave
+prostitute $50 for her expenses in traveling from San Francisco to house of
+prostitution in Arizona and made arrangements for the prostitute with another prostitute who was driving to the
+same destination, defendant persuaded
+and induced the prostitute to make the
+trip for purposes of prostitution in vio
+lation of the Mann Act, and that evidence sustained conviction of two of the
+alleged conspirators but not conviction
+of the third.
+Judgment affirmed in part and re
+versed in part.
+EGE Y. UNITED STATES
+Cite as 342 F.24 879
+879
+2. Conspiracy •47
+In prosecution for conspiring
+to
+transport women between several states
+for purposes of prostitution, evidence
+sustained conviction as to two of the alleged conspirators but not as to the
+third. 18 U.S.C.A. 55 371, 2421 et seg.,
+2422.
+3. Criminal Law 6-829(1)
+In prosecution for conspiring to
+transport women between certain states
+for purposes of prostitution, requested
+instruction that jurors would have to
+agree on at least one of the overt acts
+was proper, but refusal to so charge was
+not reversible error, in view of fact that
+instructions given, when properly interpreted, gave jury such requirement of
+unanimity. 18 U.S.C.A. $5 371, 2421 et
+веq., 2422.
+4 Criminal Law 8-1044
+If defendant does not move for directed verdict, he is not entitled to a
+review of the sufficiency of evidence.
+Walter M. Campbell, Lillie & Bryant,
+Los Angeles, Cal., Robert B. McMillan,
+Leo R. Friedman and George T. Davis,
+San Francisco, Cal., for appeliants.
+Lloyd H. Burke, U. S. Atty., Richard
+H. Foster, Asst. U. S. Atty., San Franciaco, Cal., for appellee.
+Before STEPHENS, CHAMBERS and
+BARNES, Circuit Judges.
+CHAMBERS, Circuit Judge.
+Ege, Boyd and Bruno have run afoul
+of the Mann Act.! A young California
+1. Prostitution •1
+•girl who had renamed herself Cindy was
+Where defendant gave prostitute
+their pawn.
+$50 for her expenses in traveling from
+As a child through the normal school
+San Francisco to house of prostitution
+years, Cindy had been moved from one
+in Arizona and made arrangements for
+foster home to another.
+After nine
+prostitute with another prostitute who
+years of school, 'she started to work.
+was driving to the same destination, de-
+She was employed as a clerk by three
+fendant persuaded and induced prosti-
+San Francisco concerns, each in rapid
+tute to make the trip for purposes of
+succession. She then graduated to the
+prostitution in violation of the Mann
+chorus line of the burlesque follies. She
+Act. 18 U.S.C.A. §5 2421, 2422.
+seems to have been an habitue of the
+I. Soe 18 U.S.C.A. $ 2421 et seg.
+
+
+880
+Sarong Club in San Francisco. At least
+in 1958 that club had among its clientele
+persons like the defendants Ege and
+Boyd who had commercial use for young
+women willing to accept their management in the prostitution field.
+Ege maintained in San Francisco sort
+of a supply house of women (of whom
+Cindy became one) and Boyd and Bruno
+operated houses of prostitution where
+and when they could find local law relaxed. Eventually, Cindy and Ege argued. In the vernacular, "they fell out."
+And that seems to have given the federal agents their chance to make a case.
+During her career, Cindy was sent by
+Ege to Scottsdale, near Phoenix, Arizona,
+where she worked in Boyd's "house"
+which operated there awhile.
+Then she
+returned to California where she came
+under the direct control of Bruno at his
+"house" at Delano, some thirty miles
+north of Bakersfeld.
+During the end
+of her circuit she plied her trade a day
+or two at Las Vegas, Nevada, There
+had been intermediate stops for her in
+brothels at Suisun, Sacramento and
+Barstow, under the aegis of Ege. It is
+around the necessary crossing of state
+lines by Cindy that the government
+found the required "commerce among
+the states" and thus the applicability of
+the Mann Act.
+It asserted that Ege,
+Boyd and Bruno all had a hand in the operation.
+Ege was indicted
+for transporting
+Cindy from San Francisco to Scottsdale
+for the purposes of prostitution.
+18 U.S.C.A. § 2421.
+A second count
+charged that Ege, Boyd and Bruno in
+violation of 18 U.S.C.A. § 371 did conspire together to commit an offense in
+that they and each of them did conspire
+in violation of 18 U.S.C.A. § 2421 knowingly "to transport women between California and Arizona and California and
+Nevada for the purposes of prostitution." The indictment then related a list
+of fourteen overt acts, mainly incident to
+shuttling Cindy about
+There was further amplification of the
+overt acts in a bill of particulars.
+242 FEDERAL REPORTER, 2d SERIES
+A jury found Ege guilty on the first
+count which was his alone. On the Becond or conspiracy count, Ege, Boyd and
+Bruno were all found guilty.
+sentenced to five years on the conspiracy
+charge and Ege was given an additional
+five years on his single count.
+sentences run consecutively.
+The single count against Ege
+[1] Ege's sole claim here concerning
+the first count is that the evidence of
+the government only showed that Ege
+may have "persuaded or induced" Cindy
+to go to Arizona from San Francisco in
+violation of § 2422 of Title 18, but that
+it was not shown that he "caused her to
+States, 8 Cir., 146 F.2d 536, 166 A.L.R.
+965. In that case, a woman was on vacation in Minneapolis from her employment as an inmate in a brothel in Fargo,
+The keeper of the house
+telephoned her and requested that she
+It was understood that she
+would resume her old employment in
+Fargo. The woman returned as requested, but paid her own way. Of course, in
+a loose sense LaPage did cause
+woman to be transported in interstate
+commerce. But we assume that § 2421
+requires a little more "causing" beyond
+just "persuading and inducing." Here
+Ege made the arrangements for Cindy
+with another woman in the trade, one
+Judy, (or he pointed to the arrangements) who was driving to the same
+Phoenix-Scottadale destination.
+(Judy
+also was in the group of women controlled by Ege.) Ege gave Cindy $50.00
+for her expenses to Phoenix, including
+share-the-ride expenses with Judy. This
+seems to have been no different than if
+he had presented Cindy with a plane or
+train ticket and told her to go.
+It is
+the same as if he handed Cindy the
+money and had taken her to the ticket
+window to make the purchase of a transportation ticket to Phoenix. Such conduct goes, we hold, beyond mere persuading or inducing. We hold that when the
+man puts up the money in advance, when
+
+
+EGE T. UNITED STATES
+881
+Cite sa 242 F.2d 879
+it is used for the interstate trip by the
+6. The quick appearance thereafter
+woman in accordance with his plan, when of Cindy at Scottsdale along with Judy
+he has persuaded and induced her to
+straight from Ege's quarters in San
+make the trip for the purposes of prosti- Franciaco.*
+tution, he has also caused the woman to
+7. Evidence that Boyd did make
+many calls to San Francisco from his
+motel late in September, 1953, and in
+The aufficiency of the evidence against
+Ege and Boyd on the conspiracy count
+Ege, the small booking agent and manager of prostitutes, operated from a
+home in San Francisco on which he had
+assumed the lease of Boyd. Boyd was
+in Arizona at Scottsdale near Phoenix
+operating his brothel in September-Octo-
+October.
+8. Boyd's subsequent admissions that
+he had telephoned Ege at San Francisco
+from Phoenix or Scottadale, apparently
+around the time Cindy was going to and
+she was working for him in his house at
+Scottadale.
+Out of the foregoing, the jury was entitled to infer from the circumstances
+[2] Ege took the witness stand in
+defense. Boyd and Bruno did not. They
+rested when the government closed its
+case in chief. We think within the limits of Dyer v. MacDousali, 2 Cir., 201
+9 Cir., 234 F.2d 675,
+the jury was entitled to draw many affirmative inferences from the improbabilities of Ege's
+story. These,
+when added to the evidence in chief, make hollow any claim
+by Ege that there was insufficient evidence of conspiracy as to him.
+And as to Boyd, we have the followthat there a conspiracy had been formed
+in September, 1953, between Ege and
+Boyd to transport Cindy to Arizona from
+California for Mann Act purposes and
+to infer that it was executed. There is
+no shortage of evidence of at least one
+overt act, as charged, and of the commencement of the act in the Northern
+District of California, and thus proper
+Bruno and the conspiracy
+Bruno appears to have been an old
+and experienced operator in the brothel
+field. We have little doubt that as such
+he probably knew when he ordered a
+•1. The fact that before Cindy went
+woman from Ege that she would be one
+with Judy in 1953 to Arizona Boyd and
+whom Ege was shuttling here and there
+and over interstate lines.
+Ege knew each other.
+We strongly
+suspect that Bruno made the arrange-
+2. Efforts of Ege in September, 1953,
+ments with Ege for Cindy to fly from
+to "place" Cindy somewhere.
+Phoenix to Bakersfield via Los Angeles
+3. Ege dispatches Cindy, transportabefore she rode with him from Bakerstion prepaid, to Scottsdale along with
+field to Delano, there to work at her new
+the above-mentioned Judy.
+profession and thus profit Ege and
+4. Boyd at Scottsdale received Cindy
+Bruno.
+But the evidence is just too
+and puts her to work for a week or two in
+weak to hold Bruno for a violation of
+the trade at his brothel.
+the Mann Act on the record here.
+5. Boyd's verbal act at Scottadale in
+Backtracking for a moment, the ev
+oliciting customers for his house when dence amounta to this
+Apparently,
+he stated that he was bringing over two
+women from California.
+2 During Cindy's stay at Boyd's "house"
+in Scottadale there seera to have been
+three girls serving the trade there. The
+origin of one girl is not shown. But Cindy and Judy were "two girls from Callfornia."
+• That is, there are no facts in evidenc
+bat Boyd knew in advance, or simultan
+
+
+882
+242 FEDERAL BEPORTER, 24 SERIES
+telephone to Ege at San Francisco. Ege
+to the formation of a new conspiracy betold her to promptly fly to Bakersfield
+tween Ege and Bruno, or a continuation
+from Phoenix and to go to work at Delaof the old Boyd-Ege conspiracy.
+Thus,
+no for Bruno. She followed instructions.
+we do not reach the contentions spin-
+Ege directed that when she reached the
+ning around the claim that we have here
+transfer stop at Los Angeles en route
+a charge of one conspiracy and proof of
+from Phoenix she should telephone Brutwo.
+no at a Delano number. This she did,
+Specifications affecting all conspiracy
+but she refused to state positively that
+defendants
+she talked to Bruno when she made the
+It is specified that the court erred in
+call. Upon her arrival at the Bakersfield
+not instructing the jury that the jurors
+airport, Bruno meets her in his Cadillac.
+must all agree on at least one of the
+He takes her to Delano where she worka
+overt acts. With much force the defendin the trade for him.
+We only know
+ant Boyd argues, in effect, each juror
+from evidence inadmissible against Brumight have selected his own overt act
+no that Boyd and Bruno knew each other.
+to the exclusion of others: that the
+Undoubtedly, Ege and Bruno knew each
+jurors may have "tacked" overt acts
+other,
+without all actually agreeing on any one.
+We think there is a permissible weak
+At first impression, it seems a powerful
+legitimate inference that Bruno and Ege
+argument. We reject it nonetheless.
+had formed a conspiracy. It would have
+The jury instructions ineluded:
+been stronger if Cindy had testified she
+1. "You must find *
+telephoned and talked to Bruno on the
+telephone upon arrival at Los Angeles.
+Fourth, that one of the conspirators
+There is nothing that showe that Bruno
+[after the formation of the conspiracy] knowingly committed at
+ver knew from whence Cindy came to
+least one of the overt acts charged
+Los Angeles there she made the tele
+in the indictment:"
+phone call to
+2. "Since the burden is upon the
+was not asked if Bruno knew from
+whence she came. She was not asked if
+prosecution to prove the accused
+Bruno said anything indieating he knew
+guilty beyond a reasonable doubt of
+she was under Ege's exclusive manageevery essential element of the crime
+ment, or if Bruno had said anything
+charged, the defendant has the right
+about arrangements with Ege. Perhaps,
+to rely upon a failure of the prosecution to establish such proof."
+it would have been futile to ask. It is
+obvious that Cindy's testimony disap-
+3.
+"You must consider each count
+pointed the government. It seems obseparately as though each was set
+vious she was scared.
+forth in a separate indictment, and
+While a conspiracy shown to exiat is
+in order to convict or acquit the
+ordinarily presumed to continue (and
+defendant on any count, you must
+it probably did), yet here the strongest
+reach a unanimous verdict as to
+each count. It will take all twelve of
+inference under the evidence is that the
+original one started by Ege and Boyd
+you to convict or sequit, as the case
+stopped when Cindy left Boyd's place.
+may be, on each count."
+There is no showing that Boyd helped
+4. "It is not necessary, as I have
+her on her way to Bruno—no transportaindicated, that all the overt acta
+tion of Cindy to the Phoenix airport on
+charged be proved, but it is necesdeparture or final conversations with
+sary that at least one of these be
+Boyd.
+No witnesses testified to any
+proved and that it be shown to have
+admissions by Bruno. There just is not
+been in furtherance of the object of
+enough competent evidence on Bruno as
+the conspiracy. Other overt acts
+ously with the telephone call, that Ege
+in permissible it la that Boyd did not
+was pulling Cindy away from Boyd and
+know.
+sending ber to Bruso,
+It any inference
+
+
+EGE LOVED STATES
+883
+than those charged may be given in
+conspiracy agreement into the zone of
+evidence, but proof of one of those
+crime and away from
+"talking" and
+charged in the indictment is indig-
+"thinking." Yet such overt acts may
+pensable."
+fall short of the substance required for
+"One's first impression is that defend-
+a treasonable overt act. Thus, in a way,
+ant's request for the highly specific intreason is sui generis.
+struction on unanimity should have been
+Second, here no objection was made to
+the submission to the jury of some overt
+acts upon which the evidence failed.
+one. - Why not give it? It would do no
+Really the substantial question for the
+harm."
+jury's consideration here was whether a
+Yet if each juror selected his own
+conspiracy existed at all.
+overt act from the list, that would be a
+Assuming the conspiracy, a claim that
+misconstruction of the instructions as
+there was no overt act is rather hollow.
+given: •There is no positive insurance
+Nonetheless, the defendants i
+against a jory going "haywire." Those
+tled to have the jury (not the trial court
+of us who believe in the jury system, benot this court) determine originally the
+lieve that the jury usually does not get
+question of the existence of an overt act.
+mixed up. We believe the margin for
+But the court's failure on its own moerror is lesa in simple instructions.
+tion (even yet not excepted to) to with-
+[3] In the preparation
+of instrucdraw certain overt acts from the jury
+tions, if is always a question of balance.
+must be viewed in the light of the fact
+If every instruction is granted that is
+that the proof shows almost conclusively
+the existence of an overt. act.
+not improper, either at the request of
+the defense or the government, the skein
+The Cramer case we do not regard as
+can get so twisted, snarled and knotted
+a harbinger of a holding that conapiracy
+that the opportunity for jury error incases require a special verdict on the
+creases. If sufficient and not wrong,
+overt acts. We believe that the decision
+brevity should be a fetish.
+there would have been affirmed if there
+justice will be done when simplicity is
+had been sufficient proof for a jury issue
+achieved, assuming adequacy is accomplished. The requested instruction was
+mission of each overt act was thoroughproper. We think its refusal was not
+ly objected to and the objection overerror; at least not reversible error.
+ruled. Here in Boyd's and Ege's case
+no objection was made on submitting to
+Anent this point, Boyd has argued
+the jury the full list of alleged overt acts.
+that in the absence of an express instruction for unanimity on one overt act
+Treason is a crime that gets special
+treatment almost all of the way.
+there as error in the absence of a special verdict which was not submitted.
+[4] At the trial, attorneys
+Above we have given our answer.
+than those severally representing the de-
+Akin
+fendants now) made their defense mainto this question is Bruno's contention
+that a special verdict should have been
+ly on the ground of no conspiracy. Ad-
+submitted to the jury on the overt acts.
+ditionally, they offered to the district
+judge the rejected instruction on unanim-
+The treason cases of Cramer v. U.S.,
+ity on one overt act. As we have indi-
+825 U.S. 1, 45 S.Ct. 918, 89 L.Ed. 1441
+cated above, we think the instructions as
+and Haupt _ U. S., 830 U.S. 631, 67 S
+given, properly interpreted, gave the
+Ct. 874, 91'
+1Ed. 1145 are cited.
+jury this requirement of unanimity. If
+First, we can say that the overt act
+a defendant does not move for a directed
+of the crime of treason of Article III, § 8
+verdict (these defendants did), he is not
+of the Constitution is a substantial part
+entitled to a review of the sufficiency of
+of the crime. Insubstantial overt acts
+evidence. We think it of far less conmay qualify to move a garden variety of sequence to a defendant to hold, as we
+
+
+884
+242 FEDERAL BEPOBTER, 2d SEBIES
+do here, that it was not error to remove properly construed, issuer did not unfrom the jury's consideration some stray
+dertake to make bondholders whole in
+overt act, when it was never requested
+event Great Britain went off gold standthat such be done. Not having requestard, and bonds were payable in current
+ed the withdrawal of certain alleged
+British legal tender rather than at gold
+overt acts, we thus find complaints are
+value.
+made that "unanimity on one overt act
+Affirmed.
+was not required" and "there should
+have been a special verdict." These, we
+hold to be without merit.
+The judgment is affirmed as to Ege
+and Boyd and reversed as to Bruno,
+1. Courts $359
+In case tried in Federal Court sitting in New York, New York law as to
+choice of law was controlling.
+2. Bonds 4-49, 103
+Under New York law, questions of
+construction and performance of bond
+agreement payable in England would be
+governed by English law.
+8. Payment 4-12(1)
+Under English law, "gold" in a payment clause may have three possible
+Sylvan LEMAIRE, on behalf of himself
+and all other bondholders of Kentucky
+and Indiana Terminal Railroad Company, similarly situated, Plaintiff-Ap-
+pellant,
+meanings: (1) to prescribe commodity
+in which payment must be made; (2) to
+prescribe that payment shall be made at
+gold value; (3) to prescribe nothing, but
+to describe composition of currency presently lawful in country of payment.
+KENTUCKY AND
+INDIANA TERMI-
+Seo publieation Worda and Phrases,
+NAL BAILROAD COMPANY, The Balfor other fudicial constructions and deftimore and Ohio Ballroad Company,
+mitions of "Gold".
+Chicago, Indianapolis & Loulaville Ballway Company and Southern Railway
+Company, Defendants-Appellees.
+No. 177, Docket 24204.
+United States Court of Appeals
+Second Circult.
+Argued Jan. 22, 1957.
+Decided April 2, 1957.
+Under "coupon gold" bonds
+were issued by American corporation in
+Great Britain in 1911 and which contained promise to pay bearer £100 sterling money of Great Britain at London
+with interest payable in gold, properly
+construed, issuer did not undertake to
+make bondholders whole in event Great
+Britain went off gold standard and bonds
+Class action by bondholder to obwere payable in current British legal
+tain judgment declaring amount of printender rather than at gold value.
+cipal and interest payable on bonds which
+were issued by American corporation in
+England and which were designated as
+gold coupon bonds. The United States
+Milton Pollack, New York City (Sam-
+District Court for the Southern District
+wel N. Greenspoon, New York City, on
+of New York, John M. Cashin, J., 140
+the brief), for plaintiff-appellant.
+F.Supp. 82, rendered judgment declaring
+Ralph M. Carson, of Davis, Polk,
+that they were payable in current British
+Wardwell, Sunderland & Kiendl, New
+tender; the bondholder appealed.
+The York City (Thomas O'G. FitzGibbon
+Court of Appeals, Clark, Chief Judge, and Francis W. Phillips, of Davis, Polk,
+held that under "coupon gold" bonds,. Wardwell, Sunderland & Kiendl, New
+
+
+816
+28 U.S.C. § 1402(b) (1952) plainly re- the White Slave Traffic Act. The Dislate to
+* * Abramovitch United States
+jurisdiction trict Court, Northrop, J., held that evi
+dence warranted convictions under all
+Lines,
+174 F.Supp. 587,
+591-592 (S.D. four counts, and that conversations be-
+N.Y.1959); cf. Hoiness |. United States,
+tween defendant's co-defendants and two
+335 U.S. 297, 301-302, 69 S.Ct. 70, 93
+of the vietims prior to transportation of
+L.Ed. 16 (1948).
+victims, to show corroboration between
+This issue need not be resolved here,
+the defendant and co-defendants, the infor even if transfer were available, plaintentions of the defendant, and the purtiff has not shown where such transfer
+pose of the transportation, were admiswould be in the interests of justice.
+sible, though the conversations took place
+Plaintiff is not barred from
+outside the presence of the defendant.
+recommencing this action against the United
+Defendant convicted.
+States in the appropriate distriet.
+The
+accident which forms the basis of this
+action occurred on December 16, 1960.
+Plaintiff is thus well within the two-year
+statute of limitations. 28 U.S.C. § 2401
+(b).
+Since plaintiff is neither a resident
+of this district, nor has she persuaded
+this court that an act or omission occurred in this district, she has failed to
+comply with 28 U.S.C. § 1402(b). Ac-
+cordingly, the motion of the
+U'nited
+States to dismiss is granted.
+Settle order on notice within ten (10)
+days.
+1. Criminal Law C-304(16)
+Federal District Court could take
+judicial notice of opinion of Chief Judge
+of District Court in prior prosecution in
+which defendant's co-defendants were
+found guilty.
+2. Prostitution C=3
+There was no fatal variance between
+first and second counts of indictment
+charging transportation of girls in interstate commerce for immoral purposes and
+evidence. 18 U.S.C.A. § 2421.
+3. Indictment and Information C-71
+Indictment need only furnish accused with such description of charge
+against him as will enable him to make
+his defense and as will protect him
+against double jeopardy.
+UNITED STATES of America
+William Michael AUSTREW also known
+as Bill Davis
+Harold Sapperstein
+Anne Sapperstein.
+Crim. No. 24648.
+United States District Court
+D. Maryland.
+Feb. 26, 1962.
+4. Criminal Law C=429(1)
+Birth certificate of girl, who was allegedly transported in interstate commerce for immoral purposes, was admissible to show that she was under eighteen, though girl's first and middle names
+were transposed on birth certificate,
+where it was properly sealed and certified. 18 U.S.C.A. § 2423.
+5. Criminal Law C-121(3)
+Under exception to hearsay rule, testimony of one as to his age is sufficient
+to establish his age.
+6. Prostitution C=4
+Birth certificate of girl who was al-
+The defendant was charged in a
+legedly under age of 18 years, and who
+four-count indictment with violations of was allegedly transported in interstate
+
+
+UNITED STATES | AUSTREW
+817
+coreme te Corroborate sirpe, in test 12. Prient of defendant, who is charged
+ficient to corroborate girl's own testimony as to her age, though birth certifi. with violation of Mann Act, that vietim
+ate had her first and middle names reversed. 18 U.S.C.A. § 2423.
+1. Criminal Law C=436
+Telephone and telegraph company
+records were admissible to establish in- 13. Prostitution C
+timate involvement of defendant, who
+Evidence warranted conviction fo
+was charged with violations of White violation of Mann Act. 18 U.S.C.A. §
+Slave Traffic Act, with co-defendants' en-
+2421,
+listment of girls in another state.
+18
+U.S.C.A. §$ 2, 2421-2423.
+14. Prostitution F1
+It was not necessary, in order to jus
+8. Criminal Law 6=423(1)
+lify conviction of defendant for procur
+Where several persons are jointly
+ing girl in interstate commerce for imindicted for commission of crime, and it
+moral purposes and for inducing girl to
+is proved that they acted in concert to actravel in interstate commerce for immorcomplish their end, evidence of declaraal purposes, to prove that girl actually entions and acts of each, in furtherance of
+gaged in prostitution after being transtheir criminal
+design, is admissible
+ported. 18 U.S.C.A. § 2422.
+against all, even though conspiracy is not
+formally charged in indictment.
+18 U.S.
+15. Prostitution 6=4
+C.A. § 2.
+Evidence warranted conviction of
+defendant for indueing girl, who had not
+9. Criminal Law 6-423(2), 424(1)
+attained her 18th birthday, to go in inter-
+Conversations between
+state commerce for purpose of engaging
+ants of defendant, who was charged with
+immoral practices. 18 U.S.C.A. S
+violations of White Slave Traffic Act, and
+victims before transportation of victims
+were admissible to show cooperation between defendant and co-defendants, intentions of defendant, and purpose of
+transportation,
+took place outside presence of defendant,
+16. Prostitution C4
+Evidence warranted conviction of defendant charged with inducing girls to go.
+in interstate commerce for purpose of engaging in immoral practices.
+18 U.S.
+but testimony concerning statements and
+actions of co-defendants after transporof victims was required
+stricken. 18 U.S.C.A. §§ 2, 2421-2423.
+10. Prostitution C-4
+Act of defendant, who is charged
+with violations of White Slave Traffic
+Act, in furnishing money used by vietim
+in accordance with plan of defendant is
+sufficient to establish element of inducement. 18 U.S.C.A. §$ 2421-2423.
+Joseph D. Tydings, U. S. Atty., John
+G. Underwood, and Carl J. Lorenz, Ji.,
+Asst. U. S. Attys., Baltimore, Md., for
+plaintiff.
+Nathan M. Cohen, Chicago, Ill., for
+defendant Austrew.
+William F. Mosner, Towson, Md., for
+defendants Sapperstein.
+11. Prostitution ©1
+Violation of Mann Act is complete
+when defendant knowingly induces interstate transportation of victim, and victim
+crosses state boundary, if defendant had
+intent that victim engage in immoral
+practice. 18 U.S.C.A. § 2421.
+NORTHROP, District Judge.
+The defendant, William Michael Austrew, alias Bill Davis, together with Harold Sapperstein and Anne Sapperstein,
+his wife, is charged in a four count in-
+
+
+818
+dietment 1 with violations of the White 2422 and 2423?; also, all of the named
+Slave Traffie Act, 18 U.S.C.A. §5 2421, defendants are charged in all of the
+1. The indietment reada as follows:
+"FIRST COUNT: The Grand Jury for
+the District of Maryland charges:
+"On or about the 13th day of July,
+195T. in the District of Maryland.
+also known
+HAROLD SAPPERSTEIN,
+part of the said WILLIAM MICHAEL
+ANNE SAPPERSTEIN
+did knowingis procure and obtain Capital
+Airs to ties to be sodies one
+and Gladys Germaine Moyers, also known
+as Betty Melean, in interstate commerce,
+Eive herself up to debauchery and other
+immoral practices, whereby the said girl
+was transported in interstate commerce.
+the purpose of prostitution, ilebauchers.
+And the Grand Ju-
+and other immoral purposes, and with the
+i for the District of Maryland further
+on the part of the
+sail WILLIAM MICHAEL AUSTREW,
+"On or nbout the 11th day of July,
+also known as BILL DAVIS, HAROLD
+1931.
+SAPPERSTEIS and AXNE SAPPER-
+WILLIAM MICHAEL AUSTREW,
+STEIN, to induce, entice and compel the
+sail girls to give themselves up to the
+practice of prostitution and to give themselves mp to debauchery and other immoral practices, whereby the said girls
+were transported in interstate commerce.
+ry for the Distriet of Maryland further
+"On or about the 13th day of July,
+WILLIAN MICHAEL ALSTREW,
+HAROLD SAPPERSTEIN,
+ANNE SAPPERSTEIN
+did knowingly
+persunde, induce.
+and coerce certain girls, to wit.
+• entice
+Shirles
+Monroe,
+Gladys Germaine
+Mosers, also known as Betty Mclean,
+each of whom had not then attnined her
+go from Friendcocreed to engage in prostitution, de-
+HAROLD SAPPERSTEIN,
+ANNE SAPPERSTEIN
+did knowingly procure and obtrin
+Capital Airlines ticket to be used by i
+ANNE SAPPERSTEIN
+did knowingly persuade, induce,
+anil coerce a certain girl, to wit, Dora Es-
+telle Heathcote, also known
+Anderson, also known as Sandra Lester,
+State and District of Maryland, to Chicago, Illinois, in interstate commerce, for
+the purpose of prostitution and debnuchery and for other immoral purposes, and
+with the intent and purpose on the part
+of the said WILLIAM MICHAEL AUS-
+TREW. also known as BILL DAVIS,
+HAROLD SAPPERSTEIS and ANNE
+SAPPERSTEIN, that the said girl slould
+engage in the practice of prostitution and
+debauclery and other immoral practices,
+said WILLIAM MI.
+CHAEL ALSTREW.
+STEIN, and ANNE SAPPERSTEIN, did
+knowingly cause the said girl to go and
+to be carried and transported as a passenger upon the lines and routes of com
+mon carriers in interstate commerce, to
+wit, National Airlines and Capital Air-
+2. Chapter 117—White Slave Traffie
+*§ 2421. Transportation generally
+*Whoerer knowingly transports in inerstate or forcign commerce, or in the
+District of Columbia or in any Terri
+tory or Possession of the United States,
+any womau or girl for the purpose of
+prostitution or debauchery, or for ans
+*ther immoral purpose, or with the intent
+and purpose to induce, entice, or com-
+
+
+UNITED STATES AUSTREW
+819
+counts as principals under the Aiding and Chicago, the Derby Club provides an out-
+Abetting Section, 18 U.S.C.A. § 2.
+let for its patrons" taste for alcohol, strip.
+A motion for separate trials, made on
+dancing, sexual intercourse, and other
+behalf of Austrew, was granted on Sepillicit low-life activities.
+Though there
+tember 26, 1961, and the Sappersteins
+was some conflict in the evidence on this
+were tried before Chief Judge Thomsen
+point, it is reasonably clear that there
+i this court and convicted on all fou
+was a cot in a rear room of this club,
+ounts. United States • Sappersteir
+where patrons and prostitutes in the em-
+198 F.Supp. 147 (D.Md.1961).
+ployment of Austrew engaged in sexual
+intercourse. Some time prior to the pe-
+Austrew was tried without a jury comriod with which we now are concerned,
+mencing on October 25, 1961. At the
+Anne Sapperstein worked at the Derby
+conclusion of the evidence and upon the
+Club, where her principal activities were
+request of counsel on both sides, permispocket-picking and B-drinking, that is,
+sion was granted for all argument and resoliciting drinks from customers.
+buttal to be made in the form of written
+memoranda; this accounts for much of
+In July of 1957, Anne Sapperstein and
+the delay in the rendition of this opinion
+her husband, Harold, came to Baltimore.
+and verdict.
+Shortly after their arrival in this city,
+they met one of the alleged vietims, Dora
+FINDING OF FACTS
+Austrew is the manager and lessee of a
+night club owned by Amos Amadio,
+known as the Derby Club, in Calumet
+City, Illinois. One of apparently many
+such clubs in this town just outside of
+Heatheote, to whom they offered employment as a barmaid at the Derby Club.
+Heatheote accepted, and the Sappersteins
+then obtained money for her trip to Calument City at the Baltimore office of the
+Western Union Telegraph Company.
+pel such woman or girl to become a prosor to give herself up to
+bauchery, or to engage in any other immoral practice; or
+"Whoever knowingly procures or obtains any ticket or tickets, or any form
+of transportation or evidence of the right
+thereto, to be used by any woman or girl
+in interstate or foreign commerce, or in
+the District of Columbia or any Territory or Possession of the United States,
+in going to any place for the purpose of
+prostitution or debauchery, or for any
+other immoral purpose, or with the intent
+or purpose on the part of such person to
+induce, entice, or compel her to give heror Possession of the United States, for
+the purpose of prostitution or debauchers, or for any other immoral purpose,
+or with the intent and purpose on the
+part of such person that such woman
+or girl shall engage in the practice of
+prostitution or debauchery, or any other
+immoral practice, whether with or without her consent, and thereby knowingly
+causes such woman or girl to go and
+to be carried or transported as a passenger upon the line or route of any
+common carrier or carriers in interstate
+or foreign commerce, or in the District
+of Columbia or in any Territory or Possession of the United States, shall be
+fined not more than $5,000 or imprigoned
+not more than five ears, or both."
+girl who has not attained her eighteentl
+birtlday, to go from one place to another
+by common carrier, in interstate com
+merce or within the District of Columbi
+or any Territory or Possession of the
+United States, with intent that she be
+induced or coerced to engage in prostiution, debauchery, or other immor
+ractice, shall be fined not more tha
+$10,000 or imprisoned not more than ten
+District of Columbia or in any Territory
+
+
+no discussion
+of prostitution
+until aftershe
+arrines in
+new city
+820
+This money was sent to the Sappersteins he could confront the Sappersteins, upon
+by Austrew, pursuant to two collect tele- their return from Baltimore, with her
+phone conversations between them.
+misunderstanding of the nature of her
+There can be no doubt about this transemployment; and second, so that she
+action and Austrew's part in it, for it is
+would have a greater exposure to the acfirmly established by the records of the
+tivities of the club, which it was hoped
+telephone and telegraph companies and
+would entice her to at least participate in
+by Austrew's own testimony.
+the strip-dancing. In the following few
+Part of the money sent by Austrew
+days Heathcote observed life at the Derwas used to purchase an airline ticket for
+by Club, including B-drinking and nude
+Heathcote in the name of Laura Anderdancing. But she was not altogether passon. With at least a portion of the balsive; during her brief stay in Calumet
+ance the Sappersteins bought the victim
+City, she herself danced upon at least two
+a set of luggage, helped her pack, and
+occasions, stripping to the nude each
+drove her to the airport; there they gave
+her Austrew's name and description, supplied her with the telephone number of
+the Derby Club, and put her on the plane.
+This
+was a
+National Airlines flight,
+which took her to Washington, D. C.,
+where she boarded a Capital Airlines
+plane bound for Chicago.
+On Friday, July 11, Heathcote arrived
+in Chicago and was met at Midway Airport by Austrew, who drove her to Calumet City and the Derby Club.
+this drive and for some time after they
+reached the club, Austrew and the victim
+engaged in a conversation in which he informed her that there were no barmaid
+positions available, as they were all filled
+by men, but that she "could either dance,
+B-drink, or hustle."
+Although the defense has suggested that by "hustle" was
+In Baltimore, on Sunday, July 13, 1957,
+the Sappersteins met Shirley Monroe, a
+girl who was then but fourteen years of
+age. By a sequence of events similar to
+those which led to Heathcote's arrival in
+Calumet City, Monroe and a third victim,
+Gladys Moyers, were enticed into making
+the same trip, both traveling under assumed names. However, while Heathcote had been told that she was to be a
+barmaid, Monroe and Moyers were told
+that they were to be strip-dancers.
+their flight to Chicago was diverted to
+Milwaukee because of poor weather con-
+Austrew, who testified that he
+had known the names of the two girls
+beforehand, eventually arrived at the
+Milwaukee airport, found the girls asleep
+there, and took them by car to Calumet
+meant "hustle drinks", the only reasonable interpretation of this remark is that
+Once in Calumet City, Austrew took
+Austrew was asking Heathcote to engage
+Monroe about the town. During the
+in prostitution. Batsell
+United States,
+early morning hours, in a room over
+257, at p. 262 (8th Cir.1954).
+another Calumet City bar, the Four Aces
+By her spontaneous use of the disjune-
+Club, these two engaged in sexual intertive in relating her conversation from the
+course. This fact, testified to by Monwitness stand, Heathcote indicated that
+roe, was controverted by the defendant;
+she was confronted with not just two, but
+furthermore, the defense contended that
+three, alternatives. This was her underher testimony was contradicted also by
+standing and it must have been Austhat of a disinterested witness, Andrew
+trew's intention.
+Rambush. The court is of the opinion
+At this same time Heathcote voiced
+that Monroe is more credible on this
+displeasure with the prospects confrontpoint than Austrew. Also, there is nothing her at the Derby Club, but, at Aus- ing in Rambush's testimony that would
+trew's insistence, she agreed to wait un- contradict Monroe's version of the facts.
+til the Tuesday following her arrival be-
+Rambush testified that Austrew and
+fore leaving. Austrew gave two reasons
+Monroe arrived at his home, where she
+for requesting her to stay: first, so that was to stay, some time after four o'clock
+
+
+
+
+UNITED STATES V. AUSTREW
+in the morning and that Austrew left vich, who frequented the Derby Club
+immediately thereafter; on the other during this period.
+hand, the vietim testified that she had After a few days in Austrew's emhad intercourse with the defendant be- ployment, Monroe left the Derby Club
+not after-reaching Ramand went to work at another Calumet
+bush's house. There is no inconsistency
+City night spot, the Cadillac Club. She
+between these two statements.
+stayed there for but one night and eventually returned to Baltimore.
+The day after her arrival in Calumet
+City, Monroe left and went to Chicago,
+CONCLUSIONS OF LAW
+only to return to the Derby Club five or
+no discussion six days later. Either upon her fret
+Before reaching the substantive law
+of this case, we must consider first sevarrival in Calumet City or upon her reeral objections made by the defense on
+• prostitution turn from Chicago-although the former
+which rulings were reserved until this
+until later
+alternative appears the more likely, the
+precise time is unclear-Austrew told
+[1] First, at the outset of the trial
+her of her duties at the club; she was
+of this defendant, defense counsel obto strip-dance, B-drink, and "turn tricks
+jected to the court's taking judicial noin the back room." The victim testified
+tice of Chief Judge Thomsen's earlier
+that she understood the quoted phrase
+opinion in this case, in which the Sapto mean that she was to prostitute herwere found guilty? United
+self with customers at the bar, the only
+Sapperstein, 198 F.Supp. 147
+reasonable interpretation to which this
+(D.Md.1961).
+This objection is wholly
+crude expression lends itself. United
+unmeritorious. MeCormick, Evidence, S
+States v. Marks, 274 F.2d 15, at p. 17
+326, at p. 695 (1954). Of course, while
+(7th Cir.1959). In any event, there was
+the court is cognizant of the law as it
+an agreement between Monroe and Ausis expounded in that opinion, the factual
+trew whereby she was to turn over to
+determinations made there have not in
+him or to whoever was tending the bar
+any way influenced those made here.
+the proceeds of her prostitution, a portion of which was to be returned to her
+[2, 3] A further objection alleges a
+fatal variance between the first and secon a percentage basis. Pursuant to this
+plan, she in fact did engage in prostituond counts of the indietment, both of
+tion for at least two nights, turned
+which deal with the transportation of
+over the proceeds to Austrew, and re-
+Monroe and Moyers, and the proof.*
+ceived from him a percentage.
+The first count charges the defendant
+she once again had sexual relations with
+with knowingly procuring airline tickets
+the defendant.
+for the use of these girls "in interstate
+in going to Calumet City,
+In addition to these activities, Monroe
+Illinois, for the purpose of prostitution."
+explored every phase of the debauched
+On the face of it, this count allows two
+world that was the Derby Club. In parinferences: that the tickets were for the
+ticular, on several occasions she perentire journey to Calumet City, or that
+formed a strip-dance of a character too
+they were for but a part of the journey.
+vulgar to relate. Such depravity, if it
+The latter inference is the more likely
+needs corroboration to bring it from the
+and conforms with the proof. The second
+realm of degenerate fantasy into the
+count charges the defendant with knowrealm of plausibility, was verified by a
+ingly persuading, inducing, enticing and
+disinterested witness, William Zacharecoercing the victims "to go from Friend-
+4. The indictment is set out in full above.
+
+
+822
+ship Airport, in the State of Maryland, 121 F.2d 992, at pp. 995-996 (4th Cir.
+to Milwaukee, Wisconsin, by common car- 1941), cert. denied 314 U.S. 627, 62 S.Ct.
+rier." This charge does give the cor- 111, 86 L.Ed. 503 (1941). Second, derect termini of the interstate transportaspite the transposition of names, the wittion; but, in a technical and strict sense,
+ness correctly stated every other fact
+it does not otherwise conform with the
+contained in the certificate, and this she
+If the defendant did induce apparently did without having seen it.
+Monroe and Moyers to travel, he did not The transposition is understandable;
+induce them to travel to Milwaukee, but
+while it weakens the document's evidentiary value, it is not believed that
+variances such as this—-if here there can
+such a defect makes it altogether inadbe said to be a variance at all—consismissible. Even if this were not so, un-
+Hoke United States, 227 105. 308, 31
+der an exception to the hearsay rule of
+great antiquity, one's own testimony as
+281, 57 L.Ed. 523 (1913): Bento his age is sufficient. McCormick, Evinett | United States, 227 U.S. 333, 33
+dence, § 297, at p. 621 (1954); 5 Wig-
+S.Ct. 288, 57 L.Ed. 531 (1913); Mellor
+more, Evidence, § 1493 (3rd ed. 1940).
+- United States, 160 F.2d 757 (8th Cir.
+The birth certificate is deemed to be ad-
+1947), cert. denied 331 U.S. 848, 67 S.Ct.
+missible for whatever probative value
+1734, 91 L.Ed. 1858 (1947).
+it might possess; it carries sufficient
+ment need only furnish the accused with
+weight to corroborate the witness' own
+such a description of the charge against
+him as will enable him to make his
+defense and as will protect him against
+double jeopardy.
+Under this sensible
+view, indietments have been upheld in
+which the transaction involved has been
+Fourth, objection was made to
+the admissibility of telephone and telegraph company records, submitted to establish Austrew's intimate involvement
+with the Sappersteins' enlistment procharacterized broadly only as one in i
+terstate commerce.
+United States
+Austre : is united States f36 n
+120 F.2d 592 (7th Cir.1941), cert. denied
+(1941): and Hughes
+United States,
+114 F.2d 285 (6th Cir.1940).
+An indictment such as this should not be set aside
+where its specificity is greater than that
+which the law requires-and
+certainly
+not where the alleged variance is so very
+based upon lack of relevancy and surely
+must be overruled. Even if the documentary evidence had not been proffered, Austrew's own testimony establishes the same fact; he admitted knowing of the Sappersteins' recruitments and
+sending them the money with which the
+victims were to travel from Baltimore
+to Calumet City. Also, Austrew admitted that he knew the names of these
+victims prior to meeting them at the two
+trivial.
+[4-6] Third, objection was made to
+[8,9] The fifth and final objection
+the admissibility of a birth certificate,
+relates to the admissibility of conversaoffered to prove the age of Shirley Montions between the co-defendants Sapperroe. The objection was based upon two
+steins and the two victim-witnesses,
+grounds: first, that the certificate was
+Heathcote and Monroe. All of these conimproperly certified; and second, that
+versations took place outside the prevthere was no evidence to show that the ence of the defendant and were perperson named in the certifiente was the sented to show cooperation between Aussame as the prosecuting witness, as the
+trew and the Baltimore procurers, the
+certificate reverses her first and middle
+intentions of Austrew, and the purpose
+names.
+The objection is overruled.
+First, the document was properly sealed
+and certified. Hilliard | United States,
+several persons are jointly indicted for
+the commission of a crime and it is
+
+
+UNITED STATES AUSTREW
+823
+Cite as 200 F.Supp. 810 (1082)
+proved that they acted in concert to ac- with the plan of the one suppiying it,
+complish their end, evidence of the dec- is sufficient to establisin the element of
+larations and acts of each, in the furinducement. Williams
+• United States,
+therance of their criminal design, is ad-
+271 F.2d 703, at |
+706-707 (4th Cir.
+missible against all: and, this is true
+1959), citing Ege United States, 24:
+even though conspiracy is not formal
+F.2d 879 (9th Cir.1957).
+charged in the indictment.
+Carpenter
+So, Austrew
+directly and principally—not merely by
+United States, 264 F.2d 565, at p.
+imputation-procured the tickets and
+(4th Cir.1959), cert. denied 360 U.S.
+induced the victims to go to Calumet
+936, 79
+S.Ct.
+City, regardless of the involvement of
+the Sappersteins and regardless of the
+applicability of the aiding and abetting
+United States, 141 F. 811 (4th Cir.1905).
+section. That he did not send the money
+Austrew's own admissions and the corto these girls directly, but used the aiding
+roborative records of the telephone and and abetting Sappersteins as a conduit,
+telegraph companies have provided that
+does not militate against this conclusion.
+quantum of proof necessary to establish
+Williams | United States, supra. He
+the fact that he and the Sappersteins
+clearly knew those for whom the money
+acted in concert; therefore, the prinwas intended, but even this knowledge
+ciple just stated is clearly
+is not essential to sustain th
+However, under this same principle, all
+tion of this principle.
+TaPine United
+testimony concerning statements and ac-
+States, 135 F.2d 353 (5th Cir.1943), cert.
+tions of the Sappersteins subsequent to
+denied 320 U.S. 740, 64 S.Ct. 40, 88 L.Ed.
+the transportation must be stricken.
+Hilliard
+United States, supra.
+the staten ents of the Sappersteins prior
+to the transportation are deemed admissible only to show a state of mind, the
+exclusionary hearsay rule is quite irrelevant.
+McCormick, Evidence, § 228,
+at pp. 465-467 (1954); 6 Wigmore,
+Evidence, §5 1766, 1770, 1772, and 1789
+(3rd ed. 1940). It might be added that,
+even if all of the testimony to which
+this objection has been made were excluded in toto, the remaining evidence
+nonetheless is sufficient to sustain the
+facts and conclusions contained in this
+opinion.
+Now, having disposed of these objections, we may reach the substantive
+law of this case.
+[10] First, the interstate transporta-
+[11, 12] Under the Mann Act, the offense is complete when it is shown, as
+has been done here, that the defendant
+knowingly induced the interstate transportation and that the victim crossed a
+However, this is true
+only where it is shown also that the defendant had the requisite intent and
+purpose that the victim "give herself
+up to the practice of prostitution, or
+* • * give herself up to debauchery,
+" 18 T
+cany other Maral ranited States
+272 F.2d 478 (4th Cir.1559), cert. denied
+361 U.S. 961, 80 S.Ct. 590, 4 L.Ed.2d
+543(1960). While the intention must
+exist prior to or concurrently with the
+transportation, it may be inferred from
+the character of the environment and
+tion is here well established in fact;
+this point need not be belabored, as it is
+admitted by the defense. And, it is
+well established in law that one need
+326, 33 S.Ct. 285, 57 L.Ed. 528 (1913);
+United States v. Boyette, No. 8248, 299
+only to have provided the necessary
+money for the transportation to
+deemed to have procured the tickets and
+the transportation oneself.
+more, the act of furnishing this money,
+which is used for the trip in accordance
+were the contrary true, all evidence re-
+
+
+lating to matters after the crossing of
+age of eighteen. Bennett United
+the state line and relating to the charac- States, supra.
+ter of the destination would be excluded,
+(14] With respect to the third and
+with the undesirable result that an existfourth counts, the government was not
+ing intent seldom would be established.
+required to prove that Heathcote ac-
+Subjective facts are difficult to prove,
+tually engaged in prostitution. It is not
+because it is the rare case in which the
+an essential element of the offense that
+party whose state of mind is the subthe defendant succeed in achieving his
+ject of inquiry has spoken. Typically,
+iniquitous end. United States | Marks,
+then, triers of fact must make reasonable
+supra. Indeed, it is enough to prove
+inferences from the conduct of the party
+that the environment into which the
+in question and the surrounding cireumvietim is brought *'would necessarily
+and naturally lead to a life of debauchery
+[13] From the facts in this case it
+of a carnal nature relating to sexual inis abundantly clear that Austrew, at all
+tercourse between man and woman."*
+times, intended that these girls live a Athanasaw United States, supra, 221
+life of prostitution and debauchery. The
+U.S. 326, at p. 333, 33 S.Ct. 285, at p.
+degenerate character of the Derby Club,
+287. This has been proven here.
+with its B-drinkers, pick pockets, strip-
+For the aforegoing reasons,
+dancers, and one-bed brothel in the rear
+the defendant, William Michael Austrew,
+room; the use of assumed names: Ausalso known as Bill Davis, must be found
+trew's substantial financial investment
+guilty on all four counts.
+$300.00; their inexperience with respect
+to the more innocuous
+activities for
+which Austrew claimed he wanted them;
+his telling Heathcote that she was to
+and Monroe that she was to
+"turn tricks in the back room"; Heathcote's dancing in the nude: Austrew's
+engaging in sexual intercourse with Monroe upon her first night in Calumet City
+and after her return from Chicago; his
+successful attempt to induce her to prostitute herself; his financial arrangement
+with her, which was consummated; and
+Monroe's disgusting
+dance, performed
+more than once and with Austrew's apparent knowledge and approbation:
+this establishes, beyond a reasonable
+doubt, Austrew's criminal intent.
+dominent active es prostited by ins
+statute." Any other conclusion would be
+frivolous and unmindful of the weight
+of the evidence.
+With respect to the second count of
+the indictment, it is sufficient that only
+one of the two victims named therein be
+proved to have been under the statutory
+5. See the discussion of Mortensen
+United States, 322 U.S. 360. 64 S.C
+1037, 58 L.Ed. 1331 (1944), by Thomsen,
+BREVEL PRODUCTS CORP., Plaintiff,
+H & B AMERICAN CORPORATION, Seldelhuber Steel Rolling Mill Corp., Big
+Boy Manufacturing Co. and Masters,
+Inc., Defendants.
+United States District Court
+Feb. 28, 1962.
+Patent infringement action, in which
+one defendant moved to dismiss complaint on ground of improper venue. The
+District Court, Dawson, J., held that
+California manufacturer, which, as noncorporate subsidiary of Washington corporation, maintained no manufacturing
+facilities, offices, warehouses, or sales
+force in New York, and which solicited
+Chief Judge, in United States Sapperstein, 198 F.Supp. 147 (D.Md.1961).
+
+
+U.S. _ GOETZKE
+Cite as 494 F.Jd 1231 (9th Cir. 2007)
+1231
+to ensurel] proper notice so a defendant erate as a withdrawal of the statutorily
+is able to challenge the information ... sufficient § 851 notice in this case.
+[and] make an informed decision about
+whether or not to plead guilty." Ante, at
+1226 (alterations in original) (internal
+quotation marks omitted). While I be-
+In sum, I would affirm the district
+lieve the majority imprudently relies on
+that purported purpose of the statute to
+ments demotic entited the gover.
+trump the plain meaning of its language,
+requirements. The government gave
+even under such approach the govern- Sperow "fair notice of which prior convicment's statement after trial is irelevant tig henlove mint emen mand forsanobecause it surely could not influence
+Sperow's decision to plead guilty or to
+withdraw that notice. Severino, 316 F.3d
+proceed to trial.
+at 944. Accordingly, I must respectfully
+dissent.
+Finally, contrary to the majority's assertion, I do not take the position that
+once the government files § 851 notice
+that satisfies the statutory requirements,
+in this case, which has no basis in our
+precedents. Ante, at 1228. The majority's novel contraption, with little explanation or justification, places a new burden
+UNITED STATES of America,
+Plaintiff-Appellee,
+on the government of ensuring until the
+end of the proceedings that an objectively
+David Anthony GOETZKE,
+reasonable person would conclude that the
+Defendant-Appellant.
+government continues to seek an enhanced
+No. 05-30267.
+sentence based on a prior conviction. But
+such notion cannot be found in the stat-
+United States Court of Appeals,
+e." Section 851 requires notice, "befor
+Ninth Circuit.
+ial, or before entry of a plea of guilty
+Argued and Submitted May 7, 2007.
+of "the previous conviction to be relied
+upon" for the senteneing enhancement.
+Filed Aug. 1, 2007.
+And Sperow got it. The government's la- Background: Defendant was convicted in
+ter amendment to the indictment (but not the United States District Court for the
+the § 851 notice) and its misstatement District of Montana, Jack D. Shanstrom,
+during trial were simply insufficient to op- J., of attempting to persuade, induce, en-
+5. In light of the majority's "apparent withdrawal" invention, a prosecutor may be wise
+in the future to file a terse notice containing
+only two sentences: (I) "The government
+seeks an enhanced sentence for the defendant's prior conviction for [identify prior conviction]"; and (2) "This notice is effective
+unless and until the government expressly
+amends or withdraws such notice in writing
+and signed by [name]." With such provision,
+no defendant could maintain a reasonable
+belief that the government apparently withdrew the previously filed § 851 notice based
+on a later amendment to the indictment or a
+slip of the tongue during the trial.
+
+
+1232
+tice, or coerce a minor to engage in unlaw- 4. Infants 6=13
+ful sexual activity, and he appealed.
+When a defendant initiates conversa-
+Holding: The Court of Appeals held that tion with a minor, deseribes the sexual acts
+evidence was sufficient to support convic- that he would like to perform on the minor, and proposes a rendezvous to perform
+Affirmed.
+those acts, he has crossed the line toward
+persuading, inducing, enticing, or coercing
+1. Infants C=20
+a minor to engage in unlawful sexual activ-
+The evidence that the defendant inity, as required for a conviction for attended to violate the statute and took a tempting to persuade, induce, entice, or
+substantial step in completing the violation coerce a minor to engage in unlawful sexuwas sufficient to support a conviction for
+al activity 18 U.S.C.A. 2422(b).
+attempting to persuade, induce, entice, or
+coerce a minor to engage in unlawful sexual activity; the defendant sent letters to a
+ten-year-old boy he had met when he and
+Mark T. Errebo, Errebo Law Offices,
+the boy were staying as guests in the same
+Billings, MT, for the defendant-appellant.
+home, he made advances of a sexual nature
+Marcia Hurd, Assistant United States
+to the boy in the letters, flattered him,
+Attorney, Billings, MT, for the plaintiffdescribed sex acts he wanted to perform
+appellee.
+on the boy, encouraged the boy to return
+to the home where they had met, which
+Appeal from the United States District
+was in another state from the boy's resi-
+Court for the Distriet of Montana; Jack D.
+dence, and promised him a motoreycle if
+Shanstrom, Distriet Judge, Presiding.
+he returned. 18 U.S.C.A. § 2422(b).
+D.C. No. CR-04-00129-JDS.
+2. Criminal Law 6-44
+To constitute a substantial step toward the commission of a crime, for pur-
+Before: PAMELA ANN RYMER and
+SUSAN P. GRABER, Circuit Judges, and
+JOHN S. RHOADES, SR.,* District
+poses of a conviction for attempt to commit
+a crime, the defendant's conduct must: (1)
+advance the criminal purpose charged, and
+PER CURIAM:
+(2) provide some verification of the existence of that purpose.
+A jury found David Anthony Goetzke
+guilty of attempting to persuade, induce,
+3. Criminal Law e-44
+entice, or coerce a minor, W, to engage in
+To constitute a substantial step to unlawful sexual activity in violation of 18
+ward the commission of a crime, for pur- U.S.C. § 2422(b). In this timely appeal,
+poses of a conviction for attempt to commit Goetzke argues that the evidence present-
+a crime, a defendant's actions must cross ed at trial was insufficient to support a
+the line between preparation and attempt finding of guilt beyond a reasonable doubt.
+by unequivocally demonstrating that the The facts are not in dispute. The issue is
+crime will take place unless interrupted by whether a rational jury could have found
+independent circumstances.
+that Goetzke's conduct demonstrated an
+* The Honorable John S. Rhoades, Sr., Senior
+United States District Judge for the Southern
+District of California, sitting by designation.
+
+
+U.S. GOETZKE
+1233
+intent to violate the statute and that he that we could go horseback riding."
+took a "substantial step" toward complet- Goetzke then wrote that
+ing the crime. We conclude that a rational
+I miss wrestling around with you. That
+jury could, and we affirm.
+was always fun. And giving you a back
+rub. I miss doing that. I like giving
+people a back rub, even when they don't
+In the summer of 2008, AG lived in
+have any clothes on. Then I can rub
+Louisiana with her 10-year-old son W,
+their butt. I hope it ain't bothering you
+who was developmentally disabled. At the
+about me talking about sex, being you're
+suggestion of her husband, who was then
+young, but I just wanted to tell you that
+working in Kuwait, AG sent W to a Monyou have a nice butt and am sure a nice
+tana ranch owned by a family friend, Ray
+Fettig, so that W might spend the summer Goetzke expressed his belief that W "was a
+great outdoors as his father had
+cute young man." He also wrote about his
+done as a child. Five or six days into the
+new video games, telling W that "I got
+trip, AG learned that Goetzke, a registered
+some new games for my Nintendo 64. I've
+sex offender whose sexual preference is
+got Turok Rage Wars, Mario Party 3, and
+young boys, was staying with Fettig. At
+Star Wars. I am to the last level...."
+her request, a social worker removed W
+Goetzke told W that he had gone to see
+from Fettig's residence and put him on a
+W's grandfather and that "I have known
+plane to Louisiana.
+your grandpa since I was your age." He
+Later in the fall, Goetzke began telethen wrote that "I liked talking to you on
+phoning W. He left messages calling W
+the phone, but I miss you even more, and I
+"little brother" and saying that he missed
+think about you all the time and wonder
+him. AG permitted Goetzke to speak to W
+how you're doing. I really do hope you
+one time while she listened on another line.
+will write back. Please. It would mean a
+Nothing untoward was said.
+lot to me to have you write back."
+Goetzke sent W a letter from Montana
+Goetzke signed off with "Love You Little
+in early February 2004, which AG inter-
+Brother."
+cepted. It included pictures, taken during
+AG turned the letter over to the authori-
+W's visit in Montana, of W riding horses
+ties who, posing as W and mimicking his
+and motoreycles. Goetzke asked for a piewriting style, responded. In March 2004,
+ture of W in the pants he wore while in
+Goetzke sent a much more sexually explicit
+Montana, and offered to take pictures and
+letter, which AG again intercepted. In the
+send them to W. The letter also told W
+letter, Goetzke confirmed that "you do
+have a nice butt." He explained:
+I don't know if you will understand, but
+The reason you wake up and your peter
+i am gay, meaning I like guys more tha
+is sticking out is because that means
+: do girls. I hope you won't hate me. I
+you're horny and you are growing into a
+lave always wanted to tell you you hav
+I nice butt, but I hope vou won't tell
+young man, and in a couple years, you
+will start to have sex. You know when
+anyone because it could get me into
+you were here and I gave you a back
+trouble, but I trust you to keep it berub, I wanted to rub your butt because
+tween us.
+you have a nice butt, and I wanted to
+he letter expressed Goetzke's "wish [tha
+put your peter in my mouth if you would
+• could come up here to Montanal s
+have let me. But the next time your
+
+
+1234
+peter gets hard, sticking out, play with going to see your butt the same way I
+it. Put it in your hand and move your
+do.
+hand up and down, and you will like the Goetzke asked W, "Is your peter long or
+way it feels. It will tickle. But anytime short when it's sticking out?" He then
+you don't know why about your body, told W that "I have a pieture of you in a
+you tell me, and I will help you under- baseball uniform. I have it at the head of
+stand. I really miss you. If you can, my bed. I wish Ray would have let you
+sleep upstairs." Goetzke signed off with
+Goetzke told W that
+"Love and miss you. Love always, Dave."
+An undercover agent wrote a response
+going to come to Montana again? for W, to which Goetzke did not reply.
+The last phone call was in March or April
+nice to have you here, as I had a lot of of 2004 when Goetzke called at 1:00 a.m.
+fun when you were here. But if you
+and AG told him to stop.
+ever do come to Montana again, would
+On October 26, 2004, a grand jury reyou let me see your butt naked and let
+turned an indictment charging Goetzke
+me put your peter in my mouth? I
+with an attempt to persuade a minor to
+would like that. And I hope you will
+keep writing to me. I like hearing from
+engage in sexual activity in violation of
+§ 2422(b). During the one-day trial, AG
+you and talking to you on the phone. I
+like the sound of your voice. But please
+testified regarding the phone calls, and an
+agent read the letters into evidence.
+don't tell anyone what we say in our
+Goetzke did not put on a defense. At the
+letters. It could get me into a lot of
+close of the evidence, Goetzke moved for
+trouble.
+an acquittal pursuant to Federal Rule of
+Goetzke further explained that, "[w]hen
+Criminal Procedure 29. Relying on Unityou wake up with your peter sticking out,
+ed States v. Meek, 366 F.3d 705 (9th Cir.
+that is called a hard-on, where your peter
+2004), the district court denied the motion.
+is hard and stiff." He then wrote:
+The jury convicted Goetzke.
+I have rode my horse a couple times on
+Goetzke's appeal challenges the suffithe weekend, and I hope someday you
+can come to Montana so then we could
+ciency of the evidence. To it, we apply the
+familiar standard articulated in Jackson ut
+go riding together and go fishing like we
+did when you were here and ride my
+Virginia, 443 U.S. 307, 319, 99 8.Ct. 2781,
+61 L.Ed.2d 560 (1979), and ask whether,
+bike. And if you come back to Montana,
+I would get you a motoreycle of your
+"after viewing the evidence in the light
+most favorable to the prosecution, any raown. Then we could ride and have fun. tional trier of fact could have found the
+But I was real happy to hear from you.
+essential elements of the crime beyond a
+Thank you, Little Brother. Is it okay if
+reasonable doubt."
+I call you my little brother? Because I
+had a lot of fun with you, and I think
+Il
+about you a lot and wish you were here.
+But I really do think you have a nice
+[1] The elements that the government
+butt. And thank you for not being mad had to prove to convict Goetzke are that he
+at me for saying you have a nice butt, knowingly (1) attempted to (2) persuade,
+because you really do have a nice butt. induce, entice, or coerce (3) a person under
+And when you get older, people are 18 years of age (4) to engage in sexual
+
+
+U.s. [ GOETZKE
+1235
+activity that would constitute a criminal
+when school was out, by promising the
+offense.' Meek, 366 F.3d at 718. The
+same kind of fun and a motoreycle of W's
+government prosecuted Goetzke for an at-
+The letters essentially began to
+tempt to persuade, induce, entice, or
+"groom" W for a sexual encounter in the
+coerce, rather than actually doing so, beevent he returned to Montana. See Unitcause W never received the letters due to
+ed States u. Brand, 467 F.3d 179, 203 (2d
+his mother's interception of them. An at-
+Cir.2006) ("*Child sexual abuse is often
+tempt conviction requires evidence that
+effectuated following a period of "groomthe defendant "intended to violate the stating" and the sexualization of the relationute and took a substantial step toward
+ship.'" (quoting Sana Loue, Legal and
+completing the violation." Id. at 720 (in-
+Epidemiological Aspects of Child Malternal quotation marks omitted).
+treatment, 19 J. Legal Med. 471, 479
+A rational juror could well have found
+(1998))), cert. denied, — U.S. —, 127
+that Goetzke knowingly tried to persuade,
+S.Ct. 2150, 167 L.Ed.2d 878 (2007).
+induce, entice, or coerce W to engage in
+cause of the allure of the recreational acprohibited sexual activity. He knew that
+tivities and the prospect of a motoreycle,
+W was underage, and Montana criminalthe letters fit neatly within the common
+izes oral sex when the victim is younger
+understanding of persuade, induce, or enthan 16. Goetzke specifically directed his
+letters to W. In his letters, Goetzke made
+See United States v. Dhingra, 371
+advances of a sexual nature-telling W
+F.3d 557, 562 (9th Cir.2004) (indicating
+that he was a "cute young man," suggestthat these terms are to be given their
+ing an exchange of pictures,
+how he liked giving W a backrub and
+wanted to rub his "nice butt," advising W
+how to stimulate himself, and expressing
+see W naked and to "put
+quently, the evidence was sufficient to find
+that Goetzke intended to persuade, induce,
+entice, or coerce W to engage in unlawful
+sexual activity.
+your peter in my mouth." Redolent of
+the fun they had together riding horses,
+fishing, and being massaged, the letters
+were crafted to appeal to W, flatter him,
+impress him, and encourage him to come
+back to Montana "maybe this summer"
+[2] A rational trier of fact also could
+find that Goetzke took a substantial step
+toward completing the crime. *To constitute a substantial step toward the commission of a crime, the defendant's conduct
+1. Title 18 U.S.C. § 2422(b) provides:
+Whoever, using the mail or any facility or
+means of interstate or foreign commerce, or
+within the special maritime and territorial
+jurisdiction of the United States knowingly
+persuades, induces, entices, or coerces any
+individual who has not attained the age of
+18 years, to engage in prostitution or any
+sexual activity for which any person can be
+charged with a criminal offense,
+tempts to do so, shall be fined under this
+title and imprisoned not less than 10 years
+other." Section 45-5-501(1)(b)(iv) defines
+the penis of another person." Mont.Code
+Ann. § 45-2-101(68)(a).
+2. Montana Code Annotated section 45-5-503
+punishes an individual "who knowingly has
+sexual intercourse without consent with an-
+3. To "persuade" is "to induce by argument,
+entreaty, or expostulation into some mental
+position"; to "induce'" is "to move and lead
+(as by persuasion or influence)"; and to "entice" is "to draw on by arousing hope or
+desire." Webster's Third New International
+Dictionary 757, 1154, 1687 (unabridged
+ed. 1993).
+
+
+must (1) advance the criminal purpose
+Similarly, travel by a defendant to meet
+charged, and (2) provide some verification a potential vietim is probative, but not
+of the existence of that purpose." Walters
+required, to advance and verify an intent
+v. Maass, 45 F.3d 1355, 1358-59 (9th Cir.
+to persuade, induce, entice, or coerce. In
+1995) (internal quotation marks omitted).
+Meek, 366 F.3d at 720, we found the defen-
+Goetzke mailed letters to W that flattered
+dant's "extensive[online] sexual dialog.
+him, described the sex acts that Goetzke
+transmission of a sexually-suggestive phowanted to perform on him, and encouraged tograph, repeated sexual references as to
+him to return to Montana. Those acts
+what [the defendant] would do when he
+both advanced and verified the existence of
+met the boy, and his travel to meet the
+Goetzke's purpose to persuade W to enminor at a local school" sufficient to evigage in sexual activity with him.
+dence his guilt under § 2422(b). Accord
+Brand, 467 F.3d at 202-04 (holding that
+Goetzke argues that, because he was not
+the defendant's initiating contact,
+in a position to have physical contact with
+advances, grooming behavior, and sexually
+W-they were thousands of miles apart
+explicit conversations provided overwhelmwhen he sent W the letters—he cannot be
+ing evidence of an attempt to entice, and
+guilty of violating § 2422(b). But Goetzke
+that his traveling to a prearranged meetwas charged with attempting to persuade,
+ing place was a final substantial step);
+induce, entice, or coerce W to engage in
+United States v. Blazek, 431 F.3d 1104,
+sexual activity with him—not with at-
+1106-07 (8th Cir.) (holding that the jury
+tempting to engage in sexual activity with
+could find intent to entice a minor based
+W. The latter is an attempt to achieve the
+on explicitly sexual talks followed by travel
+physical act of sex, for which physical
+to a prearranged meeting place), cert. deproximity is integral. But the former is an
+nied, 547 U.S. 1082, 126 S.Ct. 1800, 164
+attempt to achieve the mental act of as-
+L.Ed.2d 538 (2006); United States v. Patsent, for which physical proximity can be
+ten, 397 F.3d 1100, 1102-03 (8th Cir.2005)
+probative but is not required. See Dhin-
+(holding that evidence of internet chats, a
+gra, 371 F.3d at 562 (emphasizing that the
+phone call arranging a meeting, and travel
+statute focuses on the actor and the intent
+to the prearranged meeting place were
+of his actions to persuade, induce, or ensufficient); United States v. Munro, 394
+tice); Brand, 467 F.3d at 202 (holding that
+F.3d 865, 869 (10th Cir.2005) (holding that
+a conviction under § 2422(b) requires a
+the evidence was sufficient where the definding only of an intent to entice, not an
+fendant initiated sexual conversations,
+intent to perform the sexual act following tried to entice the victim by representathe persuasion); United States v. Murrell, tions about his car, house, and money, and
+368 F.3d 1283, 1286 (11th Cir.2004) (stat- went to a prearranged meeting place);
+ing that the underlying conduct that Murrell, 368 F.3d at 1288 (holding that the
+§ 2422(b) criminalizes is the persuasion of evidence was sufficient where the defenthe minor, rather than the sexual act it- dant traveled two hours to meet a minor
+self); United States v. Bailey, 228 F.3d
+for sex in exchange for money, carrying a
+637, 639 (6th Cir.2000) (observing that teddy bear, cash, and condoms). But no-
+"Congress has made a clear choice to crim- where in Meek did we hold, or even hint,
+inalize persuasion and the attempt to per- that physical proximity or travel is necessuade, not the performance of the sexual
+sary to constitute a substantial step under
+acts themselves").
+
+
+U.S. | GOETZKE
+1237
+between preparation and attempt by un- Goetzke did more than merely think
+equivocally demonstrating that the crime
+will take place unless interrupted by inde- about sexual activity with a minor or rependent circumstances." United States v. |
+duce his thoughts to a diary. He sent W
+Nelson, 66 F.3d 1036, 1042 (9th Cir.1995)
+letters replete with compliments, efforts to
+(internal quotation marks omitted). We
+impress, affectionate emotion, sexual adagree with the Third, Sixth, and Tenth vances, and dazzling incentives to return to
+Circuits that, when a defendant initiates Montana, and proposed that W return durconversation with a minor, describes the
+ing the upcoming summer. In short,
+sexual acts that he would like to perform Goetzke made his move. Indeed, given
+on the minor, and proposes a rendezvous their prior relationship and what Goetzke
+to perform those acts, he has crossed the
+knew of W and their circumstances, the
+line toward persuading, inducing, enticing,
+most substantial steps he realistically
+or coereing a minor to engage in unlawful
+could take were to communicate his affecsexual activity. See United States u. Ty-
+tions and carefully-crafted incentives to W
+karsky, 446 F.3d 458, 469 (3d Cir.2006)
+by telephone and mail, which he did. Ac-
+(concluding that instant messages arrangcordingly, a rational juror could conclude
+ing a meeting and appearing at the prearbeyond a reasonable doubt that Goetzke
+ranged meeting place each provided suffi- intended, and advanced and verified his
+cient evidence of a substantial step toward
+intention, to persuade, induce, entice, or
+persuading or inducing a minor); United
+coerce W to engage in unlawful sexual
+States v. Thomas, 410 F.3d 1235, 1245-46
+activity.
+(10th Cir.2005) (holding that the defendant's initiation of sexual conversation,
+AFFIRMED.
+writing insistent messages, and attempting
+to make arrangements to meet were a
+substantial step); Bailey, 228 F.3d at 639-
+40 (holding that the defendant's attempts
+to schedule meetings with minors constituted a substantial step). Unlike a bank
+robber who has yet to move toward a
+bank,' such a defendant will succeed in his
+persuasion, inducement, enticement, or
+coercion, unless interrupted by the fortuitousness of a circumstance independent
+from him, such as intercession by a parent
+4. In United States | Buffington, 815 F.2d
+act. Even so, analogically, the "movement"
+1292. 1303 (9th Cir.1987), we held that the
+toward completing the crime was Goetzke's
+evidence of an attempted bank robbery was
+mailing the letters to W.
+insufficient to constitute a substantial step
+because the defendants did "not take a single
+step toward the bank, they displayed no
+weapons and no indication that they were
+about to make an entry." Here, of course,
+the crime is persuasion, inducement, enticement, or coercion—not performing a physical
+LA: 3322
+
diff --git a/vision-fixhub/ds9-unparsed-05/b77971ccee5131ce1aa47ff3e613d6b0e4f2e56f2172a2c0cebd35a07ec4910e.receipt.json b/vision-fixhub/ds9-unparsed-05/b77971ccee5131ce1aa47ff3e613d6b0e4f2e56f2172a2c0cebd35a07ec4910e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..98b3022b77a403bac709525c52c12a0d6d6f25fb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b77971ccee5131ce1aa47ff3e613d6b0e4f2e56f2172a2c0cebd35a07ec4910e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -73691,
+  "dataset": "marble-joined",
+  "doc_id": "b77971ccee5131ce1aa47ff3e613d6b0e4f2e56f2172a2c0cebd35a07ec4910e",
+  "engine": "marble-apple-vision",
+  "event_count": 6194,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "9453a33e7c9262e0b38f0ca7f61de006cc5a413737f414d4ce14a87d8b75be38",
+  "output_sha256": "18f89ab41a58fc634ee3f6429668b89730a60217bafdf9806b2afe8b3ee29f8d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b7f96c0abf3b5b38d318a6b61285de1c5dcd78b846f0c45de7b074d07bda00b0.md b/vision-fixhub/ds9-unparsed-05/b7f96c0abf3b5b38d318a6b61285de1c5dcd78b846f0c45de7b074d07bda00b0.md
new file mode 100644
index 0000000000000000000000000000000000000000..9aaab1980f02777cab66a2c59f6ef102753daff0
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b7f96c0abf3b5b38d318a6b61285de1c5dcd78b846f0c45de7b074d07bda00b0.md
@@ -0,0 +1,310 @@
+Mr. Karin or
+Mr: Tourteau
+Ther
+Mr. Beislan cell
+Me tranchien
+Mr. Lafond(a/c,
+Mr. Lafond
+f. Pasquer
+Mr Santos
+Hotel Crillon
+lotel Raffae
+128 002
+Junot, Philippe
+9 Madison Aven
+-me
+PaX 3144159415 Berlioz France
+33(0) 609 515 909
+L'Amijean
+Rue de Varene
+Tue de Varene
+L'Arc
+54 0500
+. Arpege
+Ю 33 1 4551 473
+La Merlot
+Rue de la cherche midi
+La Poste
+9 rue per080 616
+agardere, Betty
+4 Rue Barbet de Jou
+feme
+Le Voltaire
+Madame Lemercier
+88 33e 163260283 (8)
+Maid
+sane • Parls
+awyer
+4401 4401 Stephane Coula
+S6 1078 6479 Stephane Couiaus
+Si 4401 4401 Geraldine Talavera
+tue Lis
+
+
+Massage A. Island
+Moseley, Bram
+Roberts, Theresa
+ormaldez, Danie
+19 West 23rd Strog
+lennifer
+/Sanchez, Carlos
+Eit ontonio Dealarcon 41
+Granda 1AM4 Snain
+Tropical Shipping
+Water Taxi
+340-775-6501
+ISRAEL
+Eshed, Ellsa
+Evani Duud Efrat
+GIL Avi
+Gutman, Arik
+Gutman, Arik
+Jerusalem Hyatt
+Nelma, Yakhof
+Havevei Zion #8
+Tenslam, Karl
+Olmert, Ehud
+ITALY (1)
+Torne di Pisa
+Kir Mergato 26
+
+JEFFREY (J)
+301 East 66th St
+Apt for todds
+
+
+KENYA (K)
+Muthalga Club
+U10 254 2 767154/5/8
+KINNERTON
+Irport Transfer
+207-403-222
+Charlle
+Chelsea Police Station
+0207-741 6212
+oles, Ala
+distered Osteon:
+im Courtfield Madical Centre
+Carls Court Swa Sin"
+Drivers
+732 13 729 Waller (g
+Watter (C
+Entwistle Isl
+28-87079
+Hair Assocs
+
+Harrods Limited
+871-730 1234
+35 Brompion Road
+07197307299. London SW1X7XL
+Harvey Nichols
+371-235 7207
+Holland & Holland
+272 132 1955 (NY)
+-
+Jackson Stops
+wyn & Bense
+207.581 58i
+John Hobbs Ltd.
+15/107A Pimlico Ro
+NIW HP
+89078 675 (ак)
+,a Famigli:
+51 0781
+Martin Tim/Debie Stom- 997 1 02 g ie loner
+Frossaar Entat
+Minicabs
+0800-854321
+Martine
+Nags Head
+Massade - (/K (al
+O'Neil Nessa
+Oping
+1865 726297
+Outred, Anthony
+9208-385 8735 Hedly'& Humpers
+(Movers)
+020752124 tours
+-
+Maxwell, Ghislaine
+inne tonend Swix BE
+
+im)
+fedex package lo: Simon Ed.
+xander Hse
+Ray. John
+
+
+212308 0519 emerg.
+Maronet, BIll
+Phon
+Massage - Florida (a)
+rs
+-dad
+card)
+(p)
+Mogens, Larry
+Police PB.
+anitar Bruno (cop hire Pat
+
+Pompano Helicopter
+8500357497 Steva
+Maxwell, Ghislaine
+1 74 32480
+001 407 695 3704
+Voi 68z0
+#cheeta Sal AR. RANCH (RH)
+Theirs manspa
+
+
+effre
+Passengertery
+c/o Dan and Nancy Sowla
+lighway
+Ling
+41.
+don Store
+NM 87056
+05 812 433
+Come taint
+Jeffrey
+3940 Bunk OuSe TR
+Guest loge cla
+3889
+oyd (Nertel)
+nolio (Nextel)
+Kate (Nexiel)
+03088 9383 Fera208 trent
+05 660 3976 Mercedes - back
+185 660 6240 Mercedes G500
+uburbar
+Tahoe
+15 670 9932 Filminer
+65 1200 Bradbury Slamm
+05862 2618 Pom Pascum 1
+aścuzz
+505 832 3238 Stables
+Healy, Shannon
+3510 Wollers Place, lexico 87106
+Suite 1000°
+wour Street NW
+іно NM 87103-2158
+Kerney Gar
+King. Brucer
+hond
+hong King Rest
+38. Box 61g/ Stanley
+Sanky Now Mexico 87056
+Massage - New Mexico
+Richardson, Bill
+Santa Fe Institute
+503 982-6900
+Singleton, Dr. & Mrs.
+ian Cristobal Rand
+-BODY. NM 87540
+BM
+Abolt Shelley
+Cowley, Dick
+Domh. Sam
+
+
+Hatsuhana (Japanese)
+
+Delay palace
+1 Ee 10 for roadway!
+Il Tre Meril
+Kinger, Georgeto
+Naw Vort
+Le Club
+88th (2-3)
+Le Comptoil
+Isabelle's
+35012127272 rue
+Madison Gourmet
+312 799 337 (6),
+Madison Towers
+Caren Pet
+195 Leningion Ar
+Madre, Le
+168 Wast 18h
+00T 212 27 8022
+Mark Hotel
+Massage - Californla
+Mayfair Regent
+851272 26 20
+cMullan, Patrick
+olographe
+Mercer Kitchen
+
+•
+
+
+•
+cosmay mil
+Mus Albany Country
+1 Club Lane
+Nine
+Albany. Columbus OF
+Oritz, Michal Group
+9465 Wilshire Bivd
+Bith Floor
+
+har.
+ink tax
+oreen (assistant)
+Qatman,
+Bob
+ave Charabo
+Costman & Associates, in
+Ive (h)
+•Hassla ovitz as-
+PortAble in NY
+Ovitz's pager
+Narcombe, Timothy W.
+Vewcombe Electronic Systems
+328 Arlington Ave
+Soda cares Avanue
+OH 43221 (h
+Pace Mail
+Newman, Larry Esa.
+All 2070th sireet
+Bur York
+MV 10021
+i West Creal arms Road
+Parkway
+-Col
+er - Skypage
+Come Col
+i numbe
+herry Castie's Di
+trice M
+x M
+emergency
+•Panice Oalman
+Quertani, Selma
+19 Yila Di Louragi,
+Call as of 1-13-03
+Packer, Mark
+anastel's
+Pagano, Joe
+43lle 281 Cooper (on)
+nda
+Canastel's Miami
+Don Fame any
+anomporary#@
+Sanca Monica
+Periman, Itzhak
+1 West 70th Stree
+New York,
+lew York 1002
+NY Apan-
+Private Line
+Pete
+Pilot
+Phillips, Lisa
+POT A FORMATION
+3514 PosAter Road
+Mesi Gilm Beach FL 33406
+05-1E18440 Washinton-Signa-
+3 66 1 3850 Washinton-Signs
+ture Fl Supi
diff --git a/vision-fixhub/ds9-unparsed-05/b7f96c0abf3b5b38d318a6b61285de1c5dcd78b846f0c45de7b074d07bda00b0.receipt.json b/vision-fixhub/ds9-unparsed-05/b7f96c0abf3b5b38d318a6b61285de1c5dcd78b846f0c45de7b074d07bda00b0.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..8fb6b987255a8957bf7ffee8485e6c5989148503
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b7f96c0abf3b5b38d318a6b61285de1c5dcd78b846f0c45de7b074d07bda00b0.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -148,
+  "dataset": "marble-joined",
+  "doc_id": "b7f96c0abf3b5b38d318a6b61285de1c5dcd78b846f0c45de7b074d07bda00b0",
+  "engine": "marble-apple-vision",
+  "event_count": 14,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "4228cb7f9301fa96a4414847a21068e70da3f76ca963bfccb7f0b890d8bb05a7",
+  "output_sha256": "014fe8bed25bdad02c83c8405f2a06c7131bdc3b88fb92bee60b4ab984f5dc2d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/b9ba129e66cbf077028d77609e466d2f38bf0624878cc7802cc759fc33425130.md b/vision-fixhub/ds9-unparsed-05/b9ba129e66cbf077028d77609e466d2f38bf0624878cc7802cc759fc33425130.md
new file mode 100644
index 0000000000000000000000000000000000000000..750a2a5fbc4828c9d090a6e4bba6c0a6665f8a54
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b9ba129e66cbf077028d77609e466d2f38bf0624878cc7802cc759fc33425130.md
@@ -0,0 +1,313 @@
+OLY-29
+
+
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+TO: Palm Beach National Bank & Trust Company
+3931 RCA Blvd.
+Suite 3102
+Palm Beach Gardens, FL 33410
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-29
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOUARE HEREBY COMMANDED to appear and testify before the Grand Jury ofthe United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 6, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):
+See attachments
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+auranagarauce with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+February 14, 2007
+This subpoena is issued upon application
+of the United States of America
+*If not applicable, enter "none."
+Name, Address and Phone Number of Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. BI. 33401-6235
+Tel:
+Fax:
+To be used in lieu of AOTIO
+FORM ORD-227
+JAN.86
+-
+
+
+Palm Beach National Bank and Trust Company
+3931 RCA Blvd.
+Suite 3102
+Palm Beach Gardens, FL 33410
+ATTACHMENT TO GRAND JURY SUBPOENA
+FGJ 07-103 OLY-29
+For the period of 1/1/04 through 12/31/06
+For the following individuals/entities:
+leffrey Enstein
+NES, LLC
+Jeffrey Epstein Household
+Janusz Banasiak [or Banasiar]
+JEGE, Inc.
+Alfredo Rodriguez
+(1) All account applications, account opening documents, signature cards, deposit slips,
+correspondence, account statements; and canceled checks (front and back).
+(2) For any and all credit cards, debit cards, lines of credit, mortgages, and/or loans, all
+monthly billing statements, individual charge invoices, payment records disclosing the
+dates, amounts, and method of payment, and checks used to make payments (front and
+back).
+This includes but is not limitad to, the following VISA accounts:
+
+
+U.S. Departm
+of Justice
+United States Attorney
+Southern District of Florida
+500 S. Australian Ave, Suite 400
+West Palm Reach, FL 33401-6235
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+authenticity. Therefore, you may be able to avoid appearing personally at the grand
+jury/trial at the time and place specified by completely filling out the attached Certification
+and Inventory and immediately returning it with the records to Special Agent
+, FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to March.6, 2007.
+Sincerely,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+BY:
+ASSISTANT UNITED STATES ATTORNEY
+
+
+CERTIFICATION OF BUSINESS RECORDS
+1, the undersigned,
+employed bylassociated with
+position of
+, declare that I am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+Date of execution:
+Place of execution:
+Signature:
+
+
+APPENDIX A
+DOCUMENT INVENTORY
+The documents submitted are as follows:
+Signature of Records Custodian:
+
+
+U.S. Department of Justice
+Washington, D.C. 20530
+Request for Financial Information (Authorization,
+Purchase Order, Receiving Report)
+This form shall only be used when requesting financial records of individuals ad partnerships of five or fewer individuals.
+1 Purchase Order Number:
+2 Date Order Prepared:
+2/14/2007
+Section A - Authorization and Purchase Order
+T3 Case Number: (Optional)
+FGJ 07-103(WPB) No. OLY-29
+4 Name and Address of Financial Institution:
+Palm Beach National Bank & Trust Company, 3931 RCA Blvd., Suite 3102, Palm Beach
+Gardens, FL 33410
+5 Deliver To:
+FBI Special Agent
+16 Return Date:
+3/6/2007
+7 Remarks:
+FOR REIMBURSEMENT PLEASE RETURN THIS FORM, THE RECORD OF
+SERVICES, AND A COPY OF THE SUBPOENA.
+8 Name of Requestor: (Cype or Print)
+AUSA
+9 Telenhone Numher
+10 Date of request:
+2/14/2007
+Section B - Financial Institution Invoice
+No Payment Shall Be Made Unless Expenses Are Itemized Below Or On Your Form To Be Attached.
+11 Service/Financial Records Provided:
+Quantity
+Unit Price
+Amount
+Cost
+FOR PROMPT PAYMENT INCLUDE TAX I.D. NUMBER.
+Please note that reimbursement cannot be made for the records pertaining to
+corporations or large partnerships of six or more. IMPORTANT: The DCIA
+Mandates the use of EFT/DD. In order to receive payment complete the
+attached EFT enrollment form.
+Per
+0.25
+Copy
+11.00
+Hour Clerical
+Tech
+17.00
+[Hour Manger
+Supervisor
+Do not proceed with compliance: If cost will exceed $500 without prior approval of
+Budget Officer Lazaro Feliciano Fax any request to (305) 530-7679
+12 Signature of Financial Institution Official:
+13 Date Signed:
+Section C - Receiving Report
+14 I certify that the articles and services listed were received:
+IS Date Received:
+Total Amount Claimed
+By Financial Institutior
+16 Disallowance
+(See Attached)
+17 Net to
+Financiat
+Institution
+19 Signature of Approving Official:
+0.00
+18 Right to Financial Privacy Act - Public Law 95-630
+(12 U.S.C. 3401-3422) Request Pursuant To: (Check One Only)
+SECTION
+• 3404
+• 3405
+• 3406
+• 3407
+• 3408
+• 3413 1
+• _ 3414
+Customer Authorization
+Administrative Subpoena or Summons
+Search Warrant
+Judicial Subpoena
+Formal Written Request
+Grand Jury Subpoena
+Special Procedures
+ОВЛЕСТ
+CLASS
+2540
+2541
+2542
+2543
+2544
+2545
+2546
+20 Accounting Classification Code
+FY/Fc!
+2 3
+4
+5
+PROJ
+21 Schedule and Voucher Number:
+DCH
+22 Remarks:
+Funds Available
+Date:
+Budget Officer:
+This fomwas electronically produced by Bite Federal Forts, Inc
+FORM OBD-211
+APR. B4
+
+
+GENERAL
+This is a multi-purpose form designed to serve as an Authorization, Purchase Over, Itemized Invoice, Receiving Report and Payment voucher in
+conjunction with "requests for financial information," pursuant to the Right toFinancial Privacy Act of 1978, P.L, 95-630, Tide XI, 12 U.S.C, 3415.
+NOTE:
+Payments under this purchase order will be due on the 30th calendar day after the date of actual receipt of a proper invoice in the office designated to receive
+the invoice. the date of the check issued in payment shall be considered to be the date payment is made.
+The Prompt Payment Act, Public Law 97-177,96 Stat. 85(31 U.S.C. 180), is applicable to payments under this purchase order and requires the payment to
+contractors of interest or overdue payments and improperly taken discounts. Determination of interest due will be made in accordance with the provisions of
+the Prompt Payment Act and the Office of Management and Budget Circular A-125.
+PREPARATION INSTRUCTIONS
+ITEM 1- A Purchase Order Number will be preprinted on each form. This number will be used for reference purposes on any correspondence relating to this spoific
+request for financial information.
+ITEM 2 - Self explanatory.
+ITEM 3 - This block may be used to idatify the specific case for which the firancial information is required. This block may be left blank.
+SECTION A - AUTHORIZATION AND PURCHASE ORDER (To be completed by the requestingofficial).
+ITEM 4 - Enter the name and mailing address of the financial institution beingrequested to furnish financial information.
+ITEM 5 - Enter the name and address to which the financial information is to besent by the financial institution. This will normally be the name and addressof the
+requesting official.
+TEM 6 - Enter the date the financial information is required.
+ITEM 7 - Include, if appropriate, any pertinent information related to the punhase order not provided for elsewhere on the form.
+ITEM 8, 9 and 10 - Sdf explanatory.
+SECTION B - FINANCIAL INSTITUTION INVOICE (To be completed by the financial intitution).
+ITEM 11 - Self-explanatory. Completion of this block constitutes an iterized bill or invoice for reimbursement for the costs incurred in providing the inforration
+requested.
+ITEM 12 and 13- Self-explanatory.
+SECTION C- RECEIVING REPORT (To be completed by the requesting official, whenthe requested financial information has been delivered).
+ITEM 14 and 15 - Self-explanatory.
+TEM 16 - This block should be used to reflect any differences between the amount claimed by the financial instrution and the correct amount to be reimburse
+ifferences may result from computation erros, or failure of the financial intitution to deliver information requeste
+ITEM 17 - Enter the amount certified to be proper for payment.
+ITEM 18 - Chock the box which identifies the appropriate procedure authorized by the Act, which necessitates the request for financial infonnation.
+ITEM 19 and 20 - These blocks must be signed and dated by an official of the oganization whose funds will be charged. His or her signature constitutes a statement that the
+records to which the invoice refers were required for official business and were provided by the financial institution in accordance with the ordering instrunent.
+ITEM 21 - The Schedule and Voucher Number will be entered by the office which actually schedules the approved amount for payment by the Treasury Department.
+ITEM 22 - Enter, if appropriate, any data not provided for elsewhere on the regiving report, such as, reasons for any claim amounts disallowed.
+-
+
+
+VENDOR ELECTRONIC FUNDS TRANSFER (EFT)
+ENROLLMENT FORM
+Please comply to this information if you have not done so already
+PAYEE/COMPANY INFORMATION:
+Vendor Company Name:
+Address:
+Taxpayer ID Number
+Contact Person Name
+Telephone Number
+i-mail Address (If you would
+ike to be notified via e-mail
+FINANCIAL INSTITUTION INFORMATION:
+Bank Name
+Bank Address
+Bank Phone Number
+Nine Digit ABA Routing Transit Number
+Type of Account (Checking or Saving)
+Depositor Account Number
+ignature of vendo
+thorizing Offici
+Name & Title of Authorizing
+Official
+Please Return or Fax to:
+U.S. Attorney's Office
+Southern District of Florida
+99 NE 4 street, Suite 200
+Miami, FL. 33132
+Attention: Jocelyn Collazo
+Fax Number: 305-530-7679
+The Debt Collection Improvement Act of 1996 requires that payments made by the Federal government, including vendor
+paydiet, deposited oy by electrun at a diana instein and are available to you on the date of a then ur funds
+If you have questions regarding the delivery of the remittance information, please contact the financial institution where
+your account is held.
+If you have any questions on the completion of this form, please contact Claudia Castellanos, at 305-961-9254.
+FORM OBD-211
+APR. 84
+Page 3 of3
diff --git a/vision-fixhub/ds9-unparsed-05/b9ba129e66cbf077028d77609e466d2f38bf0624878cc7802cc759fc33425130.receipt.json b/vision-fixhub/ds9-unparsed-05/b9ba129e66cbf077028d77609e466d2f38bf0624878cc7802cc759fc33425130.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c6ac1287a76fbc61722619e975c3d3e69cfe647e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/b9ba129e66cbf077028d77609e466d2f38bf0624878cc7802cc759fc33425130.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -108,
+  "dataset": "marble-joined",
+  "doc_id": "b9ba129e66cbf077028d77609e466d2f38bf0624878cc7802cc759fc33425130",
+  "engine": "marble-apple-vision",
+  "event_count": 9,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "0ce2511e0b8fb19a9e72e07cc5a56fdc78cb76b4a8aaf773838314b21bdac4ea",
+  "output_sha256": "57139ab49f8a451f69e89eed6807b978741837ccbeff23e4d17e45470005f07d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ba04facd7e7e27718ea37b0ccd413886e40acb054fea7ec1a14652921a065b3e.md b/vision-fixhub/ds9-unparsed-05/ba04facd7e7e27718ea37b0ccd413886e40acb054fea7ec1a14652921a065b3e.md
new file mode 100644
index 0000000000000000000000000000000000000000..d262979a2f214eb47607c4c79c5a5d8ee5808606
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ba04facd7e7e27718ea37b0ccd413886e40acb054fea7ec1a14652921a065b3e.md
@@ -0,0 +1,62 @@
+U.S. Department of Justice
+FILE COPY
+United States Attorney
+Southern District of Florida
+500 South Australian Ave., Suite 400
+Bat Balm Banah RL
+72001
+September 3, 2008
+FEDERAL BYPRESS
+Podhurst Orseck, P.A.
+City National. Bank Building
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+Re:
+Representations of Victims of Jeffrey Epstein
+Dear Mr. Josefsberg:
+To assist you in your position as attorney representative for the victims of Jeffrey
+Epstein's federal offenses, I have enclosed the following:
+the list of victims provided to Mr. Epstein's attorney,
+on July
+10,2008;
+a copy of a letter received from Mr. Epstein's attorney, Jay Lefkowitz, on
+September 2, 2008, confirming Mr. Epstein's agreement to pay your fees in
+connection with the representation of the identified victims:
+a confidential victim notification log containing contact information for those
+victims and information on when and how they have been contacted;'
+copies of victim notifications sent to some victims in July 2008;
+'Please note that three victims have moved recently. As soon as we have correct contact
+information, that will be provided to you.
+
+
+SEPTEMBER 3, 2008
+PAGE 2
+copies of amended victim notifications mailed on September 2 and 3, 2008;?
+a copy of the letter provided to Judge Davis to assist in the selection of the
+attorney representative (I believe that you already have a copy of this; and
+a proposed protocol for how to proceed once the attorney representative was
+selected.
+I also have enclosed a copy of Judge Marra's Order in the matter of In re Jane Does
+1 and 2, which is referenced in the amended victim notifications. In short, to avoid needless
+and repetitive litigation, Judge Marra has provided a procedure for all identified victims to
+gain access to the entire agreement between Mr. Epstein and the United States, so long as the
+victims (and their attorneys) agree to be bound by the Court's Protective Order. I believe that
+you already have a copy of the complete agreement, but, if not, please execute the Protective
+Order and return it to me. I would also ask that, prior to showing the Agreement to others,
+including your co-counsel and the victims, you have each of them review and execute the
+Protective Order. Please return those signed Protective Orders to me for my file.
+Please feel free to contact me with any questions or concerns. I also would appreciate
+it if you would send me your e-mail address so that I can send the updated victim log to you
+via e-mail.
+Sincerely,
+R. Alexander Acosta
+United States Attorney
+By:
+Assistant United States Attorney
+Enclosures
+"Please note that, although
+er is carbon copied on all of the victim notification
+letters, I redacted the addresses and contact information for the un-represented victims to reinforce
+the understanding that Mr. Epstein's counsel can only contact the victims via their counsel.
+3Please note that Mr. Epstein's counsel objected to this protocol when it was provided to
+them in October 2007.
diff --git a/vision-fixhub/ds9-unparsed-05/ba04facd7e7e27718ea37b0ccd413886e40acb054fea7ec1a14652921a065b3e.receipt.json b/vision-fixhub/ds9-unparsed-05/ba04facd7e7e27718ea37b0ccd413886e40acb054fea7ec1a14652921a065b3e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..43b56834b5638885bf7a0f26a827105a5a952786
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ba04facd7e7e27718ea37b0ccd413886e40acb054fea7ec1a14652921a065b3e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "ba04facd7e7e27718ea37b0ccd413886e40acb054fea7ec1a14652921a065b3e",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "99c9485d92dc0da9bc9fbbf6dfae700b51e1dc0ab0d09de33ec6c17f279a2923",
+  "output_sha256": "0d323c7eea07a50a6c78874a17f806d9d79a7b589ef6b222e66f6324f5723e6d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/baeb856f40a254eab2c21f0204d963762f185ebdfa686103a04dc431dc76b398.md b/vision-fixhub/ds9-unparsed-05/baeb856f40a254eab2c21f0204d963762f185ebdfa686103a04dc431dc76b398.md
new file mode 100644
index 0000000000000000000000000000000000000000..76b6d8109413cbd731a2a5d746258e5739449cf1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/baeb856f40a254eab2c21f0204d963762f185ebdfa686103a04dc431dc76b398.md
@@ -0,0 +1,28 @@
+From:
+Sent:
+To:
+Subject:
+• (USAFLS)
+Brendan White L
+Monday, June 30, 2008 11:20 AM
+1. (USAFLS)
+Re: Cancellation of Grand Jury Appearance
+Thank you for letting me know. I will inform Ms.
+Brendan
+-- Original Message ....
+From:
+(USAFLS)
+To: Brendan White
+Cc:
+Sent: Monday, June 30, 2008 10:59 AM
+Subject: Cancellation of Grand Jury Appearance
+Dear Mr. White: At this time, the subpoena of Ms.
+is withdrawn. If that should change, I will contact
+you.
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone
+Fax
+B-135
+753
diff --git a/vision-fixhub/ds9-unparsed-05/baeb856f40a254eab2c21f0204d963762f185ebdfa686103a04dc431dc76b398.receipt.json b/vision-fixhub/ds9-unparsed-05/baeb856f40a254eab2c21f0204d963762f185ebdfa686103a04dc431dc76b398.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c3dd152313112cd99b5d134d2372edbe2998abde
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/baeb856f40a254eab2c21f0204d963762f185ebdfa686103a04dc431dc76b398.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "baeb856f40a254eab2c21f0204d963762f185ebdfa686103a04dc431dc76b398",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3835e26babef430d1b7bfe70de1c6092f5fd9fb47a8a6d6e539dcd02cb773f0f",
+  "output_sha256": "1975c0b04cad6171eec45bb740febea70c28bf0aa4a6a3426dcf595f450b9165",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/bb0af1085d6c751647742575e3ef7e71660f3c5daa8dee721ae535d1f7297779.md b/vision-fixhub/ds9-unparsed-05/bb0af1085d6c751647742575e3ef7e71660f3c5daa8dee721ae535d1f7297779.md
new file mode 100644
index 0000000000000000000000000000000000000000..90ce44032c127c09c898479f028547efe478da88
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bb0af1085d6c751647742575e3ef7e71660f3c5daa8dee721ae535d1f7297779.md
@@ -0,0 +1,552 @@
+5/27/08 STARR SWEMISSION
+TO THE DAG
+
+
+06/02/08 MON 14:58 FAX 305 530 6440
+U.S. Department of Justice
+United States Altorney
+Southern District of Florida
+R1001
+UNITED STATES ATTORNEY'S OFFICE
+SOUTHERN DISTRICT OF FLORIDA
+99 NE 4TH STREET
+MIAMI, FLORIDA 33132-2111
+Jeffrey H. Sloman
+First Assistant U.S. Attorney
+305 961 9299
+Cyndee Campos
+Staff Assistant
+305 961 9461
+305 530-6444 lax
+FACSIMILE TRANSMISSION
+COVER SHEET
+DATE:
+June 2, 2008
+TO:
+Marie Villafana
+FAX NUMBER:
+SUBJECT:
+(561) 820 8777
+Epstein
+NUMBER OF PAGES, INCLUDING THIS PAGE: 9
+Message/Comments:
+This facsimile contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the
+original facsimile to us at the above address via the U.S. Postal Service. Thank you.
+
+
+.. 5F0420 2020120. 8440
+05/27/2008
+12
+18
+DO.FXODUTIVE OFFICE
+0002
+@ 003/013
+Kenneth W. Starr
+Kiridad & Ellis LID
+En 3110N 5900
+for b. litter
+Suri 1.LP
+The ime Cabine:
+•0: 405. N
+:S15%
+11:.
+50.3:30
+py watered dosses
+Me 27, 2008
+VIA FACSIMILE (202) 514-0467
+CONPIDANTIAL
+Honorable Mark Filip
+Olice of the Depily Alterner Ciencrul
+Liniler States Departmen: of Justice
+450 Penosy/vania Avenue. N. W
+Washington. iD.C. 20530
+Dear ludge Frip:
+This letter brelly supplenients our prior submission to you dated May 1), 3008. In that
+communicates, de arpently requested that your Ofice comduct an independent revien of the
+proposed federal prosecution of'our client. Jeificy Epstein. The dual reasons for our roguest that
+you revicw this mater are til the bedrock need for integrity in the enforcement di federal
+criminal lous, and ff the profound questions raised by the unprecedened estemann of federal
+it by the landed Siates Auorney's Ofice in Miami (the "LISAO"| to a pronment public figure
+she hes close lies to former Presiden Clinton.
+The need for review is
+all the more exigent. On Monday. May 19. 2008. lust
+Assistant Jetfrey Stoman of the LiSAO responded to an email From dig Telloniz informing 11.5
+Allarney dex Acosla thor we would he sccking four Office's toview. Mr. Somen': leker.
+which imposed a deadline of June 2, 2008 to comply with all the terme of the curen Non-
+Prosecution Agreemen! ¡the "Agreement"), ples new unilateral modificatens, on pain of being
+deemed in breacin of that Agreement. appears to have heen deliherateiy designed to deprive us o!
+an adequate opportnity to scch your Office's review in this matter.
+The USAO's desire to foreclose a complete revien is understandable, given 1h3t the
+Chile i'splotation and Onsconity Section ("CHOST) has already determaned choi nur substmleve
+yuens reperng why a decl prosecution of Mr. Lestein is not caramed were
+"compelling." Unwever, in contradiction to Mr. Stoman's assertion that C'LOS had provided an
+independent. de nevo review. COS made clear that it did not cio so. indeed. CHOS declined to
+examine severa! of the more troubling aspeets of the investigation of Mr. Epstem, inalung the
+deliberate leak to the New lord Times of sumerous highly conrideniol expects of lic
+investigation and negotiations hotecen the parties as well as the eccent emp al coul lossus
+fled against Mr. Fostein by Mr. Sloman's former law partner.
+The unnecessor and arbitrarily imposed deadling set by the USAO was done withon any
+respect for de cormal functioning and schedulme of sate judicial matters. 11 requires Tha
+Nir. bystein's counsei persusde the State Allomey of Palm Beach to issue a criminal information
+
+
+08/02/08. MON 14:59 FAX 305 530, 8440
+04/27/2008 12 18 FA
+NUFXECUTIVE OFFICE
+4003
+A004/01.
+Honorable Mark Filip
+Via. 27.2008
+lage:
+Io = charge thai the Stole Allerney bas pot despite a doo year investigation. deconsco to tre
+approprime, Mr. lipslein's counsel must also successfully espedite a plea of guily to iho charge
+eacate prior to July 8. 3008. which is tee date presendly ser hy the state coon Judge.
+Further. the imnecessary deadline is even more problematic because Mr. Brstein's chion
+le reconcile the state charge and seniones with the terms of'the Agreement requires an onusual
+and unprecedented threatened application of federal lars Thus. i places Mr Epsicin in che
+lughly unusual position of baving to demand that the Nile gequiesco lo a more socc
+punishment than it had already determined was appropriate.
+We have attempled io resolve these and other issues through the 1S00 and CEON
+incling caising our concerns about the DISAC's inappropriate conduct with respect to this
+mallel.
+But these avenues have now heen shut doun. Mr. Sloman's leder purpons to probibit
+any further compet between Mr. Epstein's defense team and CS. Altorney Acosta, and insleei
+regures us to communicale with the USAO only though Mr. Sloman's subordinates,
+While is pains as to say chis, this misguided proscention lion? the outse! gives the
+appearance mat i may bored been politically morivated Mir. Epstein is a bighty successtal. sell
+made hasinessman and philanthropist who cnicred the public arena oniy by sinus of his close
+pursonal associstion with lornice President Bill Clinton. There is blic donot as our mminds thal
+the 1S:10 never would have contemplated a prosecution in this case if Mr. instein were just
+amalier "John."
+%. horney Acosta previousty has stated that he is "sympothetic" in our federalisnrelated concerns. but he has taken the position that his authority is limited by entircement
+policies ser foch in Washington. D.C. As expressed in dar prior communication to von. We
+believe that a compicio and independent appraisal and resolution of this case most appropriately
+would be undertaken by your Oflice beginning with the rescission of the rhinory: unfair, and
+unprecedented dendline that Mr. Slomon demands to have imposed in this case.
+test we would appreciate a tolling of the arbir timeline imposed on our clem by the SNO
+in order do alloss time for your office to consider on reggest that you ondertole a revicn of this
+Case.
+Thank you for your time and attention.
+Respectfally submitted.
+Kenneth W. Strr
+Kirkland @ Flis iL?
+12 White
+Malun e Bird L
+
+
+03/02/2008
+MO: 06158F20 F2026161230 8440
+
+0a 19 08
+MON 13:21 FAX 1 213 680
+8500
+DO.J/ODAG
+KTRKLAND&EI.IS
+4004
+[0005/013
+KIRKLAND & ELLIS LLP
+Fax Transmittal
+777 South Figueroa Street
+Los Angeles, California 90017
+Phone. (213) 680-8400
+Fax: (213) 680-8500
+5/19 Cupry toEs.
+Please notify us immediately If any pages are not reccived.
+THE INFORMATION CONTAINED IN THIS COMMUNICATION IS CONFIDENTIAL, MAY
+BE ATTORNEY-CLIENT PRIVILEGED, MAY CONSTITUTE INSIDE INFORMATION, AND
+IS INTENDED ONLY FOR THE USE OF THE ADDRESSEE UNAUTHORIZED USE.
+DISCLOSURE OR COPYING IS STRICTLY PROHIBITED AND MAY BE UNLAWFUI..
+IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR,
+PLEASE NOTIFY US IMMEDIATELY AT:
+(213) 680-8400.
+To:
+Honorable Mark Filip
+From:
+Kenneth W. Star
+Message
+Company:
+Office of the Deputy Attorney General
+United States Deparment of Justice
+Date:
+May 19, 2008
+Pages wicover.
+9
+Fax #:
+(202) 514-0467
+Fax#:
+(213) 680-8500
+Direct #
+(202) 514-2101
+Direct #:
+(213) 680-8440
+
+
+08202/08 M9Y.14152 F2X2828 530 8440
+03.19-08
+MON 13:22 FAT | 213 680 8500
+DO.FOBCUTIVE OFFICE
+I.I.1*
+R005
+Ø006/013
+40002
+Kenneth W. Starr
+Kirkland & Ellis LLP
+90017-5800
+Fax: 219-680-8500
+Istarr@kirkland.com
+May 19.2008
+VIA FACSIMILE (202) 514-0467
+CONFIDENTLAL
+Honorable Mark Filip
+Office of the Depury Attomey General
+United States Department of Justice
+950 Pennsylvania Avenue. N.W.
+Washington, D.C. 20530
+Dear Judge Filip:
+In his contirmation hearings last lall, Judge Mukasey admirably lifted up the finest
+traditions of the Department of Justice in assuring the United States Senate, and the American
+people, of his solemn intent to ensure fairness and integrity in the administration of justice. Your
+(uvn confirmation hearings echoed that bedrock determination to assure that lhe Department
+conduci itself with honor and integrit!, especially in the enforcement of federal criminal iaw.
+We come to you in that spirit and respectfully ask for a review of the federal involvement
+in a quintessentially state matler involving our client, Jefficy Epstein. While we are weli aware
+of the rare instances in which a review of this sort is justified, we are confident that the
+well as those of other Tormer senior Justice Department officials whose advice we have sought,
+we have never before seen a case more appropriale for oversight and revicw. Thus, while neither
+of us has previously made such a request. we do so now in the recognition that both the
+Department's reputarion, as well as the due process rights of our client, are at issue.
+Recently, the Criminal Division concluded i very limited review of this matter ai the
+request of UV.S. Attorney Alex Acosta. Critically, however, this review deliberately excluded
+many important aspects of this case. Just this past Friday, on May 16, 2008, We received a letter
+from the head of CEOS informing us that CEOS had conducted a review of this case. By its own
+admission, the CHOS review was "limited, both factually and legally." Part of the self-imposed
+limitarion was CEOS's abstention from addressing our allegations of professional misconduct
+by federal prosccutors"-cen though such misconduct was, as we contend it is, inextricably
+intertwined with the credibility of the accusations being made against Mr. Epstein by the United
+States Attomey's Otfice in Miami ("L'SAO"). Moreover, CEOS did not assess the terms of the
+Deterred Prosecution Agreement now in effect, nor did CEOS revieff the federal prosecutors"
+inappropriate efforts to implement those tenns. We detail this point below.
+
+
+0402208. 20.215:00 F4020151230 6440
+D3-19.08 N0N 13:22 FAX 1 913 G60 8500
+NUEXECUTIVE OFFICE
+KIRKIAND&ELLIS LIP
+21006
+10007/013
+4003
+Ionorable Mark Filip
+May 19. 2008
+l'age 2
+By way of background. we were informed by Mr. Acosta that, at his request, CEOS
+would be conducting a revicw to determine whether federal prosccution was botl appropriato
+and, in his words. "fair." That is not whai occurred. Instead, CEOS has now acknowicdged that
+we had raised "many compelling arguments" against the USAO's suggested "novel application"
+of lederal law in this matter. Even so. CEOS concluded. in minimalist fashion. that "we do nor
+see anything tha! says to us categorically that a federal case should not be brought" and that the
+C.S. Adorney "would not be abusing his prosecutorial discretion should he authorize federal
+prosecution of Mr. Epstein" thus delegating back to Mr. Acosta the decision of whether federa!
+prosecution was warranted (emphasis added). Rather than assessing whether prosecution would
+be appropriate, CEOS. using a low bascline for its evaluation, determined only that it would not
+be impossible to prove.
+" certain allegations made against Mr, Epstein.
+The CEOS review
+failed to address the significant problems involving the appearance of impermissible selectivity
+that would necessurily result from a federai prosccution of Mr. Epstein.
+We respect CEOS's conclusion that its authority to review "misconduci" issues was
+preciuded by Criminal Division practice. We further respect CEOS's view thai it understood its
+mission as significantly limited. Specifically, the contemplated objoctive was to determine
+whether the U'SAO would he abusing its discretion by bringing a federal prosecution rather than
+making its own de novo reconnendations on the appropriate reach of federal law. However, we
+respectiully submit that a full review of all the facts is urgently necded at senior levels of the
+Justice Deputment. In an effort to inform you of the nature of the federal investigation against
+Mr. Lipstein, we sununarize the facts and circumstances of this matter below.
+The two basc-level concerns we hold are that (1) federal prosecution of this matter is not
+wuranted based on rhe purely-local conduct and the unprecedented application of federal
+statures lo facts such as these and (2) the actions of fedcral authorities are both highly
+questionable and give rise to an appearance of substantial impropriety. The issues that we have
+raised, but which have not yet been addressed or resolved by the Department, are more than
+Isolated allegations of professional inistakes or inisconduct.
+These issues, instead, affect the
+appearance and administration of criminal justice with profound consequences beyond the
+resolution in the matter at hand.
+In a precedent-shattering investigation of Jeftrey Epstein that raises important policy
+questions-and serious issues as to the fair and honorable enforcement of federal lan—the
+USAO in Miami is considering extending federal law beyond the bounds of precedent and
+rcason. Federal prosecutors stretched the underlying facts in ways that raise fundamental
+questions of basic professionalism. Perhaps most troubling, the USAO in Miami, as a condition
+of deferring prosecution, required a commingling of substantive federal criminal law with i
+roposed civil remedy engineered in a way that appears intended to profit particular lawvers i
+
+
+0372822088 09: 15100 2X26161239 8440
+09:08
+
+. 05
+19 05 N0X 10:23 FAN 1 213 880 8500
+DOJ/ODAG
+KIRKI ANDGELL.15
+1007
+10008/013
+LI.'
+Honorable Mark Filip
+May 19, 2008
+Page 3
+private practice in South Florida with personal relationships to some of the prosecutors involved.
+about low to proceed. That is where, in our fedcral republic, this matter should rest.
+Mr. Epstein faces a felony conviction in state court by virtue of his conduct, and the only reason
+the Stale has not resolved this matter is that the lederal prosecutors in Miami have continued to
+insist that We, Mr. Epstein's counsel, approach and demand from the State Altorney's Office al
+harsher charge and a more severe punishment than that Office believes are appropriate under the
+circumstances. Yet despite the U'SAO's refusa! to allow the State to resolve this matter on the
+lers the State has determined are appropriate, the USAO has not made any artempl to
+coordinate its efforts with the Stale. In fact, the USAO mandated that any federal agreemen:
+would be conditioned on Mr. Epstein persuading the State lo seck a criminal punishment unlike
+that imposed on other defendants within rhe jurisdiction of the State Atlomey for similar
+conduct.
+from the inception of the USAO's involvernent in this case, which at the end of the day
+is a case about solicitation of prostitution within the confines of Palm Beach County, Florida, wc
+have asked ourselves why the Department of Justice is involved. Regrettably, we are unable to
+suggest any appropriate basis for the Department's involvement. Mr. Epstein has no criminal
+history whatsoever. Also, Mr. Epstein has never been the subject of gencral media interest until
+a few years ago, after it was widely perceived by the public that he was a close friend of former
+President Bill Clinton.
+The conduct at issue is simply pot within the purview of federal jurisdiction and lies
+outside the heartland of the chree federal statutes that have been identified by prosecurors—18
+U.S.C. $$ 1591. 3422(b), and 2433(b).
+One of the other members of Mr. Epstein's defense leam, Jay Lefkowitz, has personally reviowed the reporter's
+contemporancous notes.
+: Although some of the women alleged 1o be involved were 16 and 17 years of age, several of these women
+opunly admitted to lying to Mr. Epstein about their age in their recent sworn statements
+
+
+06/02/08 MON 15:01 FAX 305 530 6440
+05/28/2008 09:09 FAX 2026161239
+05. NON 18:2N FAN 1 213 650 8500
+DOJ/ODAG
+KIRKLANDEELLIS LAP
+@00s
+4009/013
+40005
+Honorable Mark Filip
+May 19, 2008
+Page 4
+These statutes arc intended lo target crimes of a truly national and international scope
+Specifically, § 1591 was enacted to combat human trafficking, $ 2422 is aimed ar sexual
+predation of minors through the Internet. and § 2423 deals with sex tourism. The nature of these
+crimes results in multi-jurisdictional problems that state and local authorities cannot effectiveiv
+confront on their own. However, Mr. Epstein's conduct was purely local in nature and, chus
+does not implicate federal involvement. After researching every reported case brought under 18
+V.S.C. $$ 1591, 2422(b), and 2423(b), we found that not a single case involves facts or a
+scenario similar to the situation at hand. Our review of cach precedent reflects that there have
+been no reported prosecutions under § 1591 of a 'john' whose conduct with a minor lacked
+force, coercion. or fraud and who was not profiting from commercial sexual trafficking. There
+have likewise been no cases under § 2422(b)- a crime of communication--where there was no
+use of the Internei, and where the content of phone communications did not contain any inducing
+or enticing of' a minor to have illegal sexual activity as expressly required by the language of the
+stalure. Funhermore, the Governinent's contention that "routine and habil" can fill the factual
+and legal void created by the lack of evidence that such a communication ever occurred sets this
+cuse apart front every reported case brought under § 2422(b). Lastly, there are no reported cases
+of violations ol § 2423(b) of a person whose dominant purpose in traveling was merely to go to
+his own home.?
+Although these matters were within the scope of the CEOS review, rather than
+considering whether
+federal prosecution is appropriate, CEOS only determined that U.S
+Allome) Acosta "would not be abusing his prosecutorial discretion should he authorize lederal
+prosecution" in this case. The "abuse of discretion" standard constitutes an extremely low bar o!'
+evaluation and while it may be appropriate when the consideration of issues are exclusivel!
+factual in nature, this standard faiis to address concerns particulor to this situation, nanely the
+"novel application" of foderal statutes.
+The "abuse of discretion" standard in such pure legai
+matters of statutory application risks causing a lack of uniformity. The same federal statutes that
+would be stretched beyond their bounds in Miami have been limited to their heartlund in each ot
+the other federal districts. Also, because this case implicates broader issues of the administration
+al equal justice, federal prosecution in chis matter risks the appearance of selectivity in its
+stretching of federal law to fil these facts.
+Federal prosccution of'a man who engaged in consensual conduct in his horne that amounted to, at most, the
+olicilation of prostitution, is unprecedented, Since prostitution is fundamemally a state concern. (see United
+Water i. Evans, 176 F.3d 1176, r.l (1Ith Cir. 2007) (federal law "does not criminalize all acts of prostitution (:
+vice tracilionally governed by state rogulation))). and there is no evidence that Palm Beach County authorities
+and Florida prosecutors cannot effectively prosecute and punish the conduct, there is no reason why this maller
+should be extracted irom the hands of state prosecutors in Florida.
+
+
+05/28/2008
+MON
+09:09
+9I01 2026161239 8440
+• MA 19 OX
+VON 13:2+ FAX 1 213 680 8500
+DOJ/ODAG
+KIRKLANDGELLIS LLP
+E1009
+40010/013
+@ 006
+Honorable Mark Filip
+May 19. 2008
+Page f
+In fact, recent testimony of sevcral alleged "victims" contradicts claims made by federal
+prosccutors during the negotiations of a deferred prosecution agreement.
+The consistent
+representations of key Government witnesses (such as Taturn /
+Brittany
+anci Jennifer I
+confirm the following critical points:
+First, there was no
+communication, telephonic or otherwisc, that meets the requirements of § 2422(b). For instance.
+Ms.
+confirmed that Mr. Epstein never emailed, text-messaged, or used any facility of
+interstate commerce whatsoever. before or after her one (and only) visit to his home. Gonzalez
+Tr. (deposition) at 30. Second, the women who testified admitted that they lied to Mr. Epstein
+about their age in order to gain admittance into his home. Indeed, the women who brought their
+underage friends 1o Mr. Epstein testified that they would counsel their friends to lie ahout their
+ages as well. Ms. i
+stated the following: "I would tell my girlfriends just like
+approached me. Make sure you tell him you're 18. Well, these girls that I brought, I know that
+they were 18 or 19 or 20. And the girls that I didn't know and I don't know if they were lying or
+not, 1 would say make sure that you tell him you're 18."
+Tr. at 22. Third, there was no
+routine or habit of improper communication expressing an intent to transform a massage into an
+illegal sexual act, In fact, there was often no sexual activity at all during the massage. Ms.
+lestified that "Isjometimes (Mr. Epstein] just wanted his feet massaged. Somctimes he
+Just wanted a back massage."
+Tr. at 19
+also stated that Mr. Epstein
+"never Louched [her] physically" and that all she did was "massagel, | his back. his chest and his
+¿lighs and that was it"
+Tr. at 12-13. Finally, there was no force, cocrcion, fraud.
+violence, drugs, or even alcohol present in connection with Mr. Epstein's encounters with these
+women. Ms.
+stated that "[Mr. Epstein] never tried to force me to do anything." Beale Tr.
+tourist cases previously brought. The women in actuality were not younger than 16, which is
+the age of consent in most of the 50 states, and the sex activity was irregular and in large part.
+consisted of solo self-pleasuring.
+The recent crop of civil suits brought against Mr. Epstein confirm that the plaintifis dic
+not discuss any sexually-related activities with anyone prior to arriving at Mr. Epstein's
+residence. This reinforces our contention that no relephonic or Internet persuasion, inducement,
+enticement or coercion of a minor, or of any other individual, occurred. In addition, Mr. Jeffrey
+Herman, the former law partner of one of the federal prosecutors involved in this matter and the
+aliorney for most of the civil complainants (as described in detail below): was quoted in the Palin
+Beach Post as saying that "it doesn't matter" that his clients lied abour their ages and lold Mir.
+Epslein that they were 18 or 19.
+Not only is a federal prosecution of this matter unwarranted, but the inregularity of
+conduct by prosecutors and the unorthodox terms of the deferred prosecution agreement are
+beyond any reasonable interpretation of the scope of a prosecutor's responsibilities. The lis! of
+improprieties includes, but is not limited to, the following facts:
+
+
+MON 15:02 FAX 305 530 6440
+05/28/2008 09:10 FAX
+
+05-15:05
+MON 13:25 FA2 1 213 G80 6500
+DOJ/ODAC
+KIRKLAND&ELLIS ALR
+Ø1010
+@011/013
+IG007
+Honorable Mark Pilip
+May 19, 2008
+Page 6
+• Federal prosecutors made the unprecedented deniand that Mr. Epstein pay i
+minimum of $150,000 per person to an unnamed list of women they reterred to us
+minors and whom they insisted required representation by a guardian ad litem. M
+ostein's counsel later established that all but one of these individuals were actuai!
+adults, not minors. Even then, though demanding payment to the women, the
+USAO eventually asserted that it could not vouch for the veracity of any of the
+claims tbat these women might make.
+• Federal prosecutors made the highly wusual demand that Mr. Epstein pay the fees
+of a civil attomcy chosen by the prosecutors lo represent these alleged "victims"
+should they choose to bring any civil litigation against him. They also proposed
+sending a notice to the alleged "victims," stating, in an underlined sentence, that
+should they choose their own attorney, Mr. Epstein would not be required to pay
+their fees. The prosecutors further demanded that Mr. Epstein waive his right to
+challenge any of the allegations made by these "victims."
+• The Assistant U.S. Attorney involved in this matter recommended for the civil
+attorney, a highly lucrative position, an individual that we later discovered was
+closely and personally connected to the Assistant U.S. Attorney's own boyfriend.
+• Federal prosecutors represented to Mr. Epstein's counsel that they had identified
+(and laler rechecked and re-identitied) several alleged "victims" of federal crimes
+that qualified for paymen under 18 U.S.C. § 2255, a civil remedy designed 1o
+provide financial benefits to victims. Only through state discovery provisions did
+we later learn that many of the women on the rechecked "victim list could not
+possibly qualify under § 2255. The reason is that they, themselves, testified that
+they did not suffer any type of harm whatsoever, a prerequisite for the civil recovery
+under § 2255. Moreover, these women stated that they did not, now or in the past,
+consider themselves to be victims.
+• During the last few months, Mr. Herman, First Assistant Sloman's former law
+partner, has filed several civil lawsuits against Mr. Epstein on behalf of the alleged
+"victims." It is our understanding that cach of Mr. Herman's clients are on the
+
+
+- 05.
+19 • 06
+MON 15:02 FAX 305 530 6440
+MON
+13:26 PAT 1 213 G80 8500
+=..=
+_EXECUȚIVE OFFICE
+KIRKLANDSELLIS LLP
+
+40005
+Honorable Mark Filip
+May 19, 2008
+Page 7
+Govemment's confidential "list of victims." Most of these lawsuits seek $50
+million in money damages.*
+• Assistant U.S. Attorney David Weinstein spoke about the case in great detail 1o
+When counsel for Mr. Epstein complained about the media leaks, First Assistani
+Sloman responded by asserting that "Mr. Thomas was given, pursuant to his
+request, non-case specific information concerning specific federal statutes." Based
+on Mr. Thomas' contemporancous notes, that assertion appears to be false. For
+example, Mr. Weinstein told Mr. Thomas that federal authorities believed tat
+Mr. Epstein had lured girls over the iclephone and traveled in interstate commerce
+for the purposc of engaging in underage sex. He recounted to Mr. Thomas The
+U'SAO's theory of prosccution against Mr. Epstein, replete with an anaiysis of the
+key starutes being considered. Furthermore, after Mr. Epstein's defense ream
+complained about the Icak to the USAO, Mr. Weinstein, in Mr. Thomas' own
+description, then admonished him for talking to the defense, and getting him in
+trouble. Mr. Weinstein further told him not to believe the "spin" of Mr. Epstein's
+"high-priced attorneys," and then, according to Mr. Thomas. Mr. Weinstein
+forcefully "reminded" Mr. Thomas that all prior conversations were merely
+hypothetical.
+We are constrained to conclude that the actions of federal officials in this case strike at
+the heart of one of the vitally important, enduring values in this country: the honest enforcement
+of federal law, free of political considerations and free of the taint of personal financial
+motivations on the part of federal prosccutors that, at a minimum, raise the appearance of serious
+improprety.
+We were told by U.S. Attorney Acosta that as part of the review he requested, the
+Department had the authorit
+department is the irid, and discisiose to do mine any datersection i del, das oar
+conclusion, based on its limited review of the investigation, is that U.S. Attorney Acosta would
+101 abuse his discretion by proceeding agains Mr. Epstein. Thus, the decision of whethe
+As recently as two months ago. Mr. Sloman was still listed publicly as a pun of his former law firm. While we
+assume this was an oversight, Mr. Stoman's identirication as part If the firm raises the appearance of
+impropricty
+
+
+06/02/08 MON FAX FAX_305.530 8440
+05. 19 05 MON 13:26 FAX 1 213 680 8500
+DUJ/UDAG
+KIRKLANDELLAS ALP
+@012
+0013/013
+Dong
+Honorable Mark Filip
+May 19.2008
+Page 8
+prosccution is fair and appropriate has been placed, once again, in U.S. Altomey Acosta's
+hands.
+In light of the foregoing, we respectfully ask that you review this matter and discontinue
+all federal involvement so that the State can appropriately bring this matter io closure. We
+would greatly appreciate the opportunity to meet with you to discuss these importani issues
+Such a meeting would provide the Department with an opportunity to review the paramount
+issues of federalism and the appearance of sclectivity that are generated by the unprecedented
+atterupts to broaden the ambit of federal statutes to places that they have never before reached.
+We sincerely appreciale your attention to this matter.
+Respectfully submitted,
+Ned W. Stun
+Kennerh W. Start
+Kirkland & Ellis LLP
+Joe D. Whitley
+Alston & Bird LL.P
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/bb0af1085d6c751647742575e3ef7e71660f3c5daa8dee721ae535d1f7297779.receipt.json b/vision-fixhub/ds9-unparsed-05/bb0af1085d6c751647742575e3ef7e71660f3c5daa8dee721ae535d1f7297779.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..62504521305fe8ff03875553165c30649eb8713d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bb0af1085d6c751647742575e3ef7e71660f3c5daa8dee721ae535d1f7297779.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -352,
+  "dataset": "marble-joined",
+  "doc_id": "bb0af1085d6c751647742575e3ef7e71660f3c5daa8dee721ae535d1f7297779",
+  "engine": "marble-apple-vision",
+  "event_count": 19,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "98729cba605756af872d4a05034c3a1d0d05019a801b526b9425aae584480927",
+  "output_sha256": "bec9817b7ad736a407219729a608bac1abf1b416f163410215995195da0dbb7e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/bc11737687eef863536ff6fb6705f20437ca55c4aecdda6a29be9529bc69e469.md b/vision-fixhub/ds9-unparsed-05/bc11737687eef863536ff6fb6705f20437ca55c4aecdda6a29be9529bc69e469.md
new file mode 100644
index 0000000000000000000000000000000000000000..10ac7b660ef0556c991cd563837784905dd095c0
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bc11737687eef863536ff6fb6705f20437ca55c4aecdda6a29be9529bc69e469.md
@@ -0,0 +1,103 @@
+OLY-77
+
+
+TO: Wolf Camera
+3101 PGA Blvd
+Palm Beach Gardens, FL
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-77
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+September 25, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following document (s) or object(s):
+Al records and information refering or relating to a transaction completed February 14, 2005, in the
+All records and information referring or relating to any transactions completed during the period of 2003-2006
+for acarmill 2712 959472 29000
+Jeffrey Epstein
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your annenrance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CATES DISTRICT
+CLERK
+DATE:
+September 13, 2007
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the United States of Americn
+U
+*If not applicable, enter "none."
+Name Address and Phone Numher of Assistant UJ.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+Tel
+(x3047
+Fax
+To be used in lieu of AO110
+FORM ORD-227
+JAN.86
+
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+IN RE FEDERAL GRAND JURY SUBPOENA
+OLY-77 ADDRESSED TO
+WOLF CAMERA
+CERTIFICATION REGARDING DOMESTIC RECORDS
+OF REGULARLY CONDUCTED ACTIVITY
+, declare that I am employed by
+, and, by reason of my
+1, the undersigned,
+Wolf Camera, in the position of
+position, am authorized and qualified to make this declaration.
+1.
+Through my employment with Wolf Camera, I am familiar with the business records
+it maintains.
+2.
+• I certify that the records attached to this certification:
+2.
+(a)
+(b)
+(c)
+were made at or near the time of the occurrence of the matters set forth
+therein, by or from information transmitted by, a person with knowledge of
+those matters;
+were kept in the course of regularly conducted business activity; and
+were made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A
+(Document Inventory).
+
+
+
+3.
+I further certify that the documents attached hereto are responsive to the Grand Jury
+Subpoena served upon Wolf Camera.
+Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing
+information is true and correct.
+Executed this
+day of
+, 2007.
+Place of execution:
+Signature
+
+
+
+APPENDIX A
+DOCUMENT INVENTORY
+The documents submitted are as follows:
+Signature of Records Custodian:
diff --git a/vision-fixhub/ds9-unparsed-05/bc11737687eef863536ff6fb6705f20437ca55c4aecdda6a29be9529bc69e469.receipt.json b/vision-fixhub/ds9-unparsed-05/bc11737687eef863536ff6fb6705f20437ca55c4aecdda6a29be9529bc69e469.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4381b1d10d5b5790cb691d0a84e7e13b8d001d0c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bc11737687eef863536ff6fb6705f20437ca55c4aecdda6a29be9529bc69e469.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -82,
+  "dataset": "marble-joined",
+  "doc_id": "bc11737687eef863536ff6fb6705f20437ca55c4aecdda6a29be9529bc69e469",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "6fd48285f0ef937d4ad2135010efb34065178152189ad9577e1a077d80c292a8",
+  "output_sha256": "2d5cec20118dc2371b6e3c219a1a16ddae75023f6cc663155df7a728ee810334",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/bc3dea5b15c6f55db51a18846a03e07c867301c2d8f82176119081388934af17.md b/vision-fixhub/ds9-unparsed-05/bc3dea5b15c6f55db51a18846a03e07c867301c2d8f82176119081388934af17.md
new file mode 100644
index 0000000000000000000000000000000000000000..799ddf06c0508099942ece0a003caaaa3111c404
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bc3dea5b15c6f55db51a18846a03e07c867301c2d8f82176119081388934af17.md
@@ -0,0 +1,137 @@
+From
+Sent
+Subject:
+Russo, Frank (USAAK)
+Friday, September 14. 2007 1:02 PM
+RE: A question regarding an Alaska child exploitation case
+Final Trust.wpd
+Trust Exhbi
+E.WDI
+Trust Exhbit
+C.wpd
+Notice and
+Notice of
+sproval of trust_ foeneficiaries.wpd
+Good luck.
+From: Vitefans, Amn Marie 6. (USAFLS)
+Sent: Thursday, September 13, 2007 3:45 PM
+To: USAAK-CRAtty
+Subject: A question regarding an Alaska child exploitation case
+Hello everyone - Sorry to bother you. I have a child exploitation case with a large number of victims. Defense
+counsel has proposed setting up a victims' rights fund, rather than having each victim sue individually. He says
+that this was done in a case in Alaska. Does anyone know about such a thing? And, if so, who set up the fund?
+The court? The parties? And did all of the victims have to consent to the procedure?
+Thank you!
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+3153
+P-014103
+
+
+From
+Sent
+To:
+Subject:
+Thursday, September 13, 2007 8.10 PM
+RE: Epstein
+Hi Drew - I tracked down the AUSA in Alaska and he is sending the trust agreement out to me. I will let you
+know how things go in the morning.
+Thanks.
+Assistant U.S. Attorney
+500 S. Australian Ave. Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+•
+From: Costerbaan, Andrew
+Sent: Thursday, September 13, 2007 7:54 PM
+Toky
+BAFLS)
+Subject: RE: Epstein
+Thanks for the information, Marie. I'll get the details on the Boehm arrangements from the prosecutors and get back to
+you tomorrow. I believe the girls agreed to the arrangement, but I'll confirm that. I should have the indictment reviewed
+by then as well.
+From:
+Sent: 7
+To: co
+Subject: Epstein
+USAFLS)
+, 2007 7:37 PM
+Hi Drew - Sorry to bother you, but the plea negotiations are getting fast and furious. Epstein's lawyers are
+fixated on this idea of a "victim's fund" rather than having the girls file separate 2255 actions. I know that the
+reason they want to do it is not out of the goodness of their hearts but to keep this stuff out of the public Court
+files, but in some ways it will help the girls, too. Do you know anything about how the fund in Alaska was
+worked out? Did all the victims consent or did the Court just do it?
+Thank you for your help. I also turned in the indictment package to my immediate supervisor today, so I expect
+some edits back from her before it goes higher up the chain. If you had any thoughts, please let me know.
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+3164
+P-014104
+
+
+Phone 561 209-1047
+Fax 561 820-8777
+3165
+P-014105
+
+
+From:
+Sent:
+To:
+Subject:
+L. (USAFLS)
+busterdaal, Allorew
+Thursday, September 13, 2007 7:54 PM
+Villafana, Ann Marie C. (USAFLS)
+RE: Epstein
+Thanks for the information, Marie. I'll get the details on the Boehm arrangements from the prosecutors and get back to
+you tomorrow. I believe the girls agreed to the arrangement, but I'll confirm that. I should have the indictment reviewed
+by then as well
+From:
+USAFLS) [mailto
+Sent: Thursday, September 13, 2007 7:37 PM
+To: 0
+Subject, Epsten
+Hi Drew - Sorry to bother you, but the plea negotiations are getting fast and furious. Epstein's lawyers are
+fixated on this idea of a "victim's fund" rather than having the girls file separate 2255 actions. I know that the
+reason they want to do it is not out of the goodness of their hearts but to keep this stuff out of the public Court
+files, but in some ways it will help the girls, too. Do you know anything about how the fund in Alaska was
+worked out? Did all the victims consent or did the Court just do it?
+Thank you for your help. I also turned in the indictment package to my immediate supervisor today, so I expect
+some edits back from her before it goes higher up the chain. If you had any thoughts, please let me know.
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+3166
+P-014106
+
+
+(USAFLS)
+From:
+Sent:
+To:
+Subject:
+I. (USAFLS)
+Thursday, September 13, 2007 7:37 PM
+Epstein
+Hi Drew - Sorry to bother you, but the plea negotiations are getting fast and furious. Epstein's lawyers are
+fixated on this idea of a "victim's fund" rather than having the girls file separate 2255 actions. I know that the
+reason they want to do it is not out of the goodness of their hearts but to keep this stuff out of the public Court
+files, but in some ways it will help the girls, too. Do you know anything about how the fund in Alaska was
+worked out? Did all the victims consent or did the Court just do it?
+Thank you for your help. I also turned in the indictment package to my immediate supervisor today, so I expect
+some edits back from her before it goes higher up the chain. If you had any thoughts, please let me know.
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+3167
+P-014107
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/bc3dea5b15c6f55db51a18846a03e07c867301c2d8f82176119081388934af17.receipt.json b/vision-fixhub/ds9-unparsed-05/bc3dea5b15c6f55db51a18846a03e07c867301c2d8f82176119081388934af17.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..18e1117ac32e011a07bf7bacf0743394b8129140
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bc3dea5b15c6f55db51a18846a03e07c867301c2d8f82176119081388934af17.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -151,
+  "dataset": "marble-joined",
+  "doc_id": "bc3dea5b15c6f55db51a18846a03e07c867301c2d8f82176119081388934af17",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "53a92e8fba9bcc88354627a98f5d824592f6bbe9be91d6f39692e70302c16ce2",
+  "output_sha256": "511af576690d958b1dce398f661ff7e542fc04e2d204d5a88e30f63b7723557f",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/bce89794dc9ff24b3edf65dde45699a98e816dfec5d7b76425037b9ca4d9dac0.md b/vision-fixhub/ds9-unparsed-05/bce89794dc9ff24b3edf65dde45699a98e816dfec5d7b76425037b9ca4d9dac0.md
new file mode 100644
index 0000000000000000000000000000000000000000..5dae0707c54e81942aa457bb7a1e7843a99831f2
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bce89794dc9ff24b3edf65dde45699a98e816dfec5d7b76425037b9ca4d9dac0.md
@@ -0,0 +1,38 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+West Palm Beach, FL 33401
+(561) 820-8711
+500 S. Australian Ave, Ste 400
+Facsimile: (561) 820-8777
+June 12, 2009
+DELIVERY BY HAND
+Jack A. Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+One Clearlake Centre, Suite 1400
+250 Australian Ave S.
+West Palm Beach, FL 33401-5015
+Re: Jeffrey Epstein
+Dear Mr. Goldberger:
+Pursuant to the terms of the Non-Prosecution Agreement, the United States Attorney's
+Office for the Southern District of Florida hereby provides you with notice that the United States
+Attorney has determined, based on reliable evidence, that Jeffrey Epstein has willfully violated
+one of the conditions of the Non-Prosecution Agreement. Specifically, on May 26, 2009, Jeffrey
+Epstein, through his counsel, filed a "Motion to Dismiss the First Amended Complaint or, in the
+Alternative, for a More Definite Statement," in the matter of Jane Doe No. 101 | Jeffrey Epstein
+, Court File No. 09-CV-80591-KAM. "Jane Doe No. 101" was on the list provided to Mr.
+Epstein's attorneys of individuals whom the United States had identified as victims, as defined in
+18 U.S.C. § 2255, and "Jane Doe No. 101" has elected to proceed exclusively under 18 U.S.C. §
+2255. By filing the Motion to Dismiss, Mr. Epstein is contesting liability and, therefore, has
+violated Term 8 of the Non-Prosecution Agreement.
+Based upon Mr. Epstein's breach of that term, the U.S. Attorney's Office has elected to terminate
+the Non-Prosecution Agreement and to investigate and prosecute Mr. Epstein and others for federal
+offenses.
+Sincerely,
+Jeffrey H. Sloman
+Acting United States Attorney
+By:
+A. Marie Villafaña
+Assistant United States Attorney
+cc: Karen Atkinson, Chief, Northern Division
+Roy Black, Esq. (via electronic mail)
diff --git a/vision-fixhub/ds9-unparsed-05/bce89794dc9ff24b3edf65dde45699a98e816dfec5d7b76425037b9ca4d9dac0.receipt.json b/vision-fixhub/ds9-unparsed-05/bce89794dc9ff24b3edf65dde45699a98e816dfec5d7b76425037b9ca4d9dac0.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a9421349b154ce86dfd720fbdfb4b44e33f82928
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bce89794dc9ff24b3edf65dde45699a98e816dfec5d7b76425037b9ca4d9dac0.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "bce89794dc9ff24b3edf65dde45699a98e816dfec5d7b76425037b9ca4d9dac0",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "747d8354a5e9efb30274dc55fa76bea908d1b85d8372e91ccc65d01db5f28c3c",
+  "output_sha256": "bc48de4bab205b0a9cfd5ec906f130255b889df00f930ba66f8d95709829f724",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/bd38d7b01f439809415fb7554191a146921013299787e62604a19dc1867773ad.md b/vision-fixhub/ds9-unparsed-05/bd38d7b01f439809415fb7554191a146921013299787e62604a19dc1867773ad.md
new file mode 100644
index 0000000000000000000000000000000000000000..bfeb0830c4c0f268f197e8eb9a4216c3b6fdc8a1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bd38d7b01f439809415fb7554191a146921013299787e62604a19dc1867773ad.md
@@ -0,0 +1,466 @@
+Statements
+
+
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+CAYNE, JAMES E.
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+Important Message
+Please note: You may find more than one statement
+in this envelope. Beginning this month, all statements with
+the same Address and Social Security number / Taxpayer
+Identification number are being mailed in one envelope. For
+further details, please contact your account executive.
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 25, 2001
+INTERESTS II
+ATTN JEANIE BRENNANE
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Premise or Third Party Repurchase Agreements
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PURCHASE
+EPURCHASE
+PLACHASE PRICE/
+START DATE
+NO DATE
+PRINCIPAL
+06/19/01
+OPEN
+2.151.602.86
+TOTAL REPURCHASE AGREEMENTS
+The at all prent dis do not appear in any other section of this statemen.
+PRICING
+RATE
+3.970000
+REPOI ACCRUED
+INTEREST
+2,993.12
+NET AMOUNT
+2.154.595.98
+$2,154,595.98
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal furycer rear die Set revere date for portant iformation.
+07/01/01:02:12 001
+
+
+2 org
+Sear, Stears & Co. Inc
+45 Park Avenue
+New York. New York 10167
+Your messages
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 25, 2001
+STOP
+****** End of Statement******
+027
+07:01/01:02:12 001
+
+
+3 of 3
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+027
+07:01/01:02:12 001
+
+
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+CAYNE,JAMES E.
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+Important Message
+In an effort to deliver statements to you more efficiently,
+Bear Steams has enhanced the distribution of
+statements to household accounts. Beginning in June,
+all statements with the same Address and Social
+Security number / Taxpayer identification number wil
+be mailed in a single envelope. For further details,
+please contact your account executive.
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD April 28, 2001
+THROUGH
+May 25, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 27, 2001
+INTERESTS II
+ATTN JEANIE BRENNANE
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Premise or Third Party Repurchase Agreements
+with Bear,Stearns& Co. Inc. outstanding as of date of statement
+PURCHASE
+REPURCHASE
+PUACHASE PRICE!
+START DATE
+END DATE
+PRINCIPAL
+04/02/01
+OPEN
+2.102.605.50
+TOTAL REPURCHASE AGREEMENTS
+The at all prent dis do not appear in any other section of this statemen.
+PRICING
+RATE
+3.770000
+REPO/ ACCRUED
+INTEREST
+44,137.43
+NET AMOUNT
+2.146.742.93
+$2,146,742.93
+STOP
+****** End of Statement******
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four or ratanal purger red de Set revere date for portant iformation.
+05/26/01:12:59 001
+V478
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+027
+05/26/01:12:59 001
+V478
+
+
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+CAYNE. JAMES E.
+www.bearstearns.com
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD March 31, 2001
+THROUGH
+April 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30, 2001
+INTERESTS II
+ATTN JEANIE BRENNANE
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Premise or Third Party Repurchase Agreements
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PURCHASEr
+REPURCHASE
+PUACHASE PRICE!
+START DATE
+END DATE
+PRINCIPAL
+04/02/01
+OPEN
+2.102.605.50
+TOTAL REPURCHASE AGREEMENTS
+The at all prent dis do not appear in any other section of this statemen.
+PRICING
+RATE
+4.370000
+REPO/ NOCRUED
+INTEREST
+37,255.48
+NET AMOUNT
+2,139,860.98
+$2,139,860.98
+STOP
+****** End of Statement******
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four or ratanal furycer rear die Set revere ate fra portant iformation.
+04/28/01:19:29 001
+V471
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+027
+04/28/01:19:29 001
+V471
+
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD February 24, 2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 13-7047334
+LAST STATEMENT
+February 23, 2001
+ACCOUNT EXECUTIVE
+CAYNE,JAMES E.
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+Important Message
+Decimal Trading is Here for Nasdaq!
+Decimal Trading is the shift from fractional pricing
+(e.g.21 1/2) to decimal pricing (e.g.$21.50 yor
+equities and options. Nasdaq securities have been
+phased in during March and the remaining securities
+are scheduled to be trading in decimals in April.
+For details, visit our website at www.bearstearns.
+com.
+INTERESTS II
+ATTN JEANIE BRENNANE
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Premise or Third Party Repurchase Agreements
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PURCHASE
+EPURCHASE
+PUACHASE PRICE/
+START DATE
+NO DATE
+01/04/01
+PRINCIPAL
+OPEN
+2.202.605.50
+TOTAL REPURCHASE AGREEMENTS
+The at all prent dis do not appear in any other section of this statemen.
+PRICING
+RATE
+5.250000
+REPO/ ACCRUED
+INTEREST
+29,516.14
+NET AMOUNT
+2.232.121.64
+$2,232,121.64
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or writo to Cient Services at Bear, Stoams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The surren s four or ratanal purposes rear die Set revere date for portant iformation.
+
+
+2 org
+ear, Stears & Co. In
+45 Park Avenue
+New York, New York 10167
+Your messages
+Bear, Stearns Securities Corp, Net Capital and
+Net Capital Requirements:
+At November 30, 2000 and January 26, 2001, the
+Company's net capital of $2,620,960,000 and
+$2,202,436,000, all respectively.
+A complete copy of the Bear, Stearns Securities
+Corp, Statement of Financial Condition is available
+on the web site www.bearstearns.com, Alternatively,
+to request a free printed copy please call -
+toll free 1-866-299-9331,
+STOP
+****** End of Statement******
+027
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD February 24, 2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 13-7047334
+LAST STATEMENT
+February 23,2001
+
+
+3 of 3
+027
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+
+
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+CAYNE,JAMES E.
+www.bearstearns.com
+What's In This Statement
+Your Messages
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+13-7047334
+LAST STATEMENT
+January 26, 2001
+INTERESTS II
+ATTN JEANIE BRENNANE
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Premise or Third Party Repurchase Agreements
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PUACHASE
+EPURCHASE
+PLACHASE PRICE/
+START DATE
+NO DATE
+01/04/01
+OPEN
+PRINCIPAL
+2.202.605.50
+TOTAL REPURCHASE AGREEMENTS
+*As of statement dato
+The above posions do not appear in arry other section of this statement.
+PRICING
+RATE
+5.350000
+REPON ACCRUED
+INTEREST
+18.344.64
+NET AMOUNT
+2.220,950.14
+$2,220,950.14
+Your messages
+The interest, if any, charged to your account
+during December 2000 was computed on the net
+debit balance through December 28. The
+terest, if any, charged to your account durir
+anuary 2001 is computed from December 29. 2000
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Stoams Securities
+Corp.. One Metrolech Center North. Brooklyn. N.Y. 11201-3859.
+SP The suremen s four ratanal purger red de Set revere date for portant iformation.
+02/24/01:22:22 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+027
+02/24/01:22:22 001
+
+
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 30, 2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 13-7047334
+LAST STATEMENT
+December 29, 2000
+ACCOUNT EXECUTIVE
+CAYNE, JAMES E.
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+Important Message
+Decimal Trading is Coming!
+Decimal Trading is the shift from fractional pricing
+(e.g.,21 1/2) to decimal pricing (e.g.,$21.50)for
+equities and options.
+All trading on NYSE, AMEX, and regional exchanges
+will be in decimals effective as of 1/29/01.
+For details, visit our website at www.bearstearns.com.
+INTERESTS II
+ATTN JEANIE BRENNANE
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Premise or Third Party Repurchase Agreements
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PURCHASE/
+REFURCHASE/
+PURCHASE FRICE/
+START DATE
+END DATE
+01/04/01
+OPEN
+PRINCIPAL
+2.202.605.50
+PRICING
+RATE
+5.950000
+TOTAL REPURCHASE AGREEMENTS
+The at all pront dis do not appear in any other section of this statemen.
+REPO! ACCRUED
+INTEREST
+9,000.70
+NET AMOUNT
+2.211.606.20
+$2,211,606.20
+STOP
+****** End of Statement******
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s foul ratanal purger red de Set revere dise for portant iformation.
+01/27/01:15:33 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+027
+01/27/01:15:33 001
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/bd38d7b01f439809415fb7554191a146921013299787e62604a19dc1867773ad.receipt.json b/vision-fixhub/ds9-unparsed-05/bd38d7b01f439809415fb7554191a146921013299787e62604a19dc1867773ad.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..48f74ec037ca2e5dac25e11c41ca8647fa71fff3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bd38d7b01f439809415fb7554191a146921013299787e62604a19dc1867773ad.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1638,
+  "dataset": "marble-joined",
+  "doc_id": "bd38d7b01f439809415fb7554191a146921013299787e62604a19dc1867773ad",
+  "engine": "marble-apple-vision",
+  "event_count": 15,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "e898ba923da050b31d58bb2f224bf54b5770d69549a7fa92cd35f785e0eb7d57",
+  "output_sha256": "95b22680cd7aabe94302efaeb8fbb9320441c4ffff32ec528f91d8d1ccba3cf0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/bd76c9cbecbf1bba9b5d069f5b57dc97772356d022e814dfe6a2eedbcf22039d.md b/vision-fixhub/ds9-unparsed-05/bd76c9cbecbf1bba9b5d069f5b57dc97772356d022e814dfe6a2eedbcf22039d.md
new file mode 100644
index 0000000000000000000000000000000000000000..4cad1a79923decb698906a9cdee10581b0b1a595
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bd76c9cbecbf1bba9b5d069f5b57dc97772356d022e814dfe6a2eedbcf22039d.md
@@ -0,0 +1,1412 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+May 15, 2007
+VIA FACSIMILE
+Jack A. Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+One Clearlake Centre, Suite 1400
+250 Australian Ave S.
+West Palm Beach, FL 33401-5015
+Re: Subpoenas to JEGE, Inc. and Hyperion Air, Inc.
+Dear Mr. Goldberger:
+It was a pleasure speaking with you today. As we discussed, the deadlines for complying
+with the subpoenas to JEGE, Inc. and Hyperion Air, Inc. have been extended to May 29, 2007. If
+there are any categories for which no documents exist, please ask the Custodian of Records to
+provide a certificate of nonexistence of records.
+Also, following our conversation I received a voicemail from Lilly Ann Sanchez addressing
+the subpoenas. Since you have provided a written statement that you represent JEGE and Hyperion,
+I will assume that you alone serve as their counsel unless you tell me otherwise. With that in mind,
+pursuant to Rule 6(e), I do not intend to discuss matters related to these subpoenas with other
+attorneys.
+Thank you again for your assistance.
+Sincerely,
+R. Alexander Acosta
+Limitad Otaton Attorson
+By:
+Assistant United States Attorney
+cc:
+FBI
+
+
+ATTERBURY GOLDBERGER
+WEISS,
+•JOSEPH R.ATTERBURY
+*†JACK A GOLDBERGER
+JASON S.WEISS
+*Board Certified Criminal Trial Attorney
+† Member of New Jersey & Florida Bars
+May 10, 2007
+A. Marie Villafaña, Esq.
+Assistant United States Attorney
+Office of the United States Attorney
+Southern District of Florida
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+VIA HAND-DELIVERY
+JEGE, Inc. ("JEGE") and Hyperion Air, Inc. ("Hyperion")
+Dear Ms. Villafaña:
+I write as counsel to the above noted entities to respond to the subpoenas dated April 24,
+2007, served, respectively, on those entities. I understand from Gerald B. Lefcourt and Lilly Ann
+Sanchez, both counsel to Jeffrey Epstein, that as a result of a telephone conversation had
+amongst you, Mr. Lefcourt and Ms. Sanchez, you are now seeking documents reflecting:
+1. Ownership of JEGE and Hyperion;
+2. Assets of JEGE and Hyperion; and
+3. Employees of JEGE and Hyperion.
+As I believe Mr. Lefcourt and Ms. Sanchez told you, JEGE and Hyperion are each wholly
+owned by Mr. Epstein. Enclosed is an IRS Form 2553 ("Election by a Small Business
+Corporation") filed by JEGE, showing that Mr. Epstein is the sole shareholder of that entity. A
+similar document was filed on behalf of Hyperion, but we have not been able to locate it. As
+soon as we do, we will forward it to you. I have instead enclosed a share certificate reflecting
+Mr. Epstein's ownership of 100 shares of Hyperion. I can also represent that I have examined
+the books and records of that company and state that no other shares have been issued. Thus, Mr.
+Epstein is the sole owner of Hyperion, as well.
+One Clearlake Centre, Suite 1400 250 Australian Avenue South West Palm Beach, FL 33401
+P
+www.agwpa.com
+
+
+and Standard Airworthiness Certificate for the Boeing 727, showing ownership by JEGE; and (i)
+the Certificate of Aircraft Registration and Standard Airworthiness Certificate for the Gulfstream,
+showing ownership by Hyperion.
+As to employees, each of JEGE and Hyperion pays crew costs for the crew members
+(whom we understand you have interviewed), as well as the costs of contract crew members
+whom JEGE or Hyperion may sporadically engage. Neither JEGE nor Hyperion employs any
+other crew members or other personnel.
+Thank you for your cooperation in this matter. If you have any questions, please do not
+hesitate to call.
+cc:
+Federal Bureau of Investigation
+Gerald B. Lefcourt, Esq.
+Lilly Ann Sanchez, Esq
+2
+
+
+REGISTRATION NOT TRANSFERABLE
+UNITED STATES OF AMERICA
+DEPARIMENT OF TRANSPORTATION • FEDERAL AVIATION ADMINISTRATION
+CERTIFICATE OF AIRCRAFT REGISTRATION
+NATIONALITY AND
+AIRCRAFT SERIAL ND.
+MEGISTRATION MARKE #DORUE
+MANUFACTURER AND MANUFACTURER'S DESIGNATION OF AIRCRAFT
+BOEING
+727-31
+ICAO Aircratt Adress Code: 59100661
+JEGE INC
+103 FOULK RO STE 202
+WTLMINGTOR DE 19803-3742
+Jes sericade
+aas be is be eltich she emersed.
+Pis initicle is
+tise perpame saly
+ad is so • carl-
+Federal Avie-
+Marien
+erdia
+CORPORATICM
+is consist dut the ders descited aural les bass mared so for cagicer of De Fadersl
+- 1384, ted regelatines issued ther
+DATE OF ISSUE
+January 25, 2001
+At lenn 5050-309/979 Sagardse prarions
+- M91579.000
+U.9. Department
+at Transportatian
+Federal Aviation
+Adminiatration
+MATIOWALITY AND
+BEOSTRATICH MARC
+LANTEO STATER OF AMERICA
+DEFARTMENT OF TRANSPORTATION FEDERAL AVIATION ACMANSTRATION
+STANDARD AIRWORTHINESS CERTIFICATE
+2 MANUFACTURER, AND MODEL
+ARCHLAFT SEPSAL • CATEGORY
+BOEING T27-31
+TRANSPORT
+• AUTHORITY AND BANKS FOR
+Thie amertinen care
+pardon and to bal
+Exceptione
+le to Federal
+NONE
+scardence
+BATE OF BELA
+RMay 17 2001
+JOHN A DIAZ
+8017
+
+
+INCOAPORATED UNDER THE LAWS OF THE STATE OF DELAWARE
+HYPERION AIR, INC.
+TOTAL AUTHORIZED ISSUE
+1,500 SHARES PAR VALUE $.0001 EACH
+COMMON STOCK
+Jeffrey E. Epstein
+SCE REVERSE SIDE FOR
+CERTAIN DEFINITIONS
+This is 1o Certify chat_
+is the owner of
+One Hundred (100)-
+fully paid and
+nos-assessable shares of the above Corporation hansferable only on the books
+of the Corporation by the holder hereof in person or by duly authoriged Attorney
+upon surrender of this Certificale properly endorsed.
+Witness, the seal of the Corporation and the signatures of its dully authorized officers.
+Dated: As of July 26, 1991
+PRECISE CORPORATE PRINTING. MY
+
+
+Form 2553
+Election by a Small Business Corporation
+(Rev. July 1999)
+(Under section 1362 of the Internal Revenue Code)
+OMB No. 1545-0146
+Department of the Treasury
+• See Parts II and IIi on back and the separate instructions.
+Internal Revenue Service
+The corporation may either send or fax this form to the IRS. See page 1 of the instructions.
+Notes: 1. This election to be an S corporation can be accepted only if all the tests are met under Who may elect on page 1 of the instructions; all signatures
+in Parts / and if are originals (no photocopies), and the exact name and address of the corporation and other required form information are
+provided.
+2. Do not fle Form 1120S, U.S. Income Tax Retum for an S Corporation, for airy tax year before the year the election takes effect.
+3. If the corporation was in existence before the effective date of this election, see Taxes an 5 corporation may owe on page 1 of the instructions.
+Part 1|
+Election Information
+Name of corporation (see instructions)
+A Employer identification number
+Please
+JEGE, Inc..
+Number, street, and room or suite no. 0f a P.O. box, see instructions.)
+Type
+B Date incorporated
+or Print
+103 Foulk Road, Suite 202
+September 7,
+2000_
+City or town, state, and ZIP code
+C. State of Incorporatior
+Wilmington, DE_19803
+D
+Election is to be effective for tax year beginning (month, day, year)
+131/07
+/ 01
+E
+Name and title of officer or legal representative who the IRS may call for more information
+F
+Telephone number of officer
+or legal representative
+Darren K. Indyke,
+Vice President
+G
+If the corporation changed its name or address after applying for the EIN shown in A above, check this box
+Hi if this election takes effect for the first tax year the corporation exists, enter month, day, and year of the earfiest
+of the following: (1) date the corporation, first had shareholders, (2) date the corporation first had assets, or (3)
+date the corporation began doing business..
+•
+Selected tax year: Annual retum will be filed. for tax year ending (month and day) December December: 3.1
+If the tax year ends on any date pther than December 31, except for an automatic 52-53-week tax year ending with reference, to the month
+of December, you must complete Part Il on the back, If the date you enter is the ending date of an automatic 52-53-week tax year, write
+"52-53-week year" to the right of the date. See Temporary Regulations section 1.441-2T(e)(3).
+K Shareholders' Consent Statement.
+1 Name and address of each shareholder;
+shareholder's spouse having a community
+property interest in the corporation's
+stock; and each tenant in common, joint
+tenant, and tenant by the entirety. (A
+husband and wife (and their estates) are
+counted as one shareholder in
+determining the number of shareholders
+without regard to the manner in which the
+stock is owned)
+Under penalties of perjury, we declare that we consent
+to the election of the above-harried corporation to be an
+• L
+Stock owned
+5 corporation under section 1362(a) and that we have
+examined this consent statement, including
+accompanying schedules and statements, and to the
+best of our knowledge and belief, it Is true, correct, and
+complete. We understand our consent is binding and
+: M Social security
+number or employer
+Identification mumbier
+(see instructions
+may not be withdrawn after the corporation has made a
+Number
+of Shares
+Dotes
+acquired
+valid clection. (Sharehokers sign and date below)
+N
+Share
+holder's
+tax
+year
+ends
+(month
+and
+Hay)
+Signetire
+Date
+Jeffrey E. Epstein
+Suite B-3
+st. Thomas, USVI
+0007(
+100
+1/1/01
+12/31
+Under penalies of perjury. I declare that i have examined this etection, inching accompanying schedules and statemens, and to the best of my knowledge and belier.
+It is true, correct, and-complete
+some ass. Klin uma vice president
+Date * 1/24/01
+
+
+2:-MAY-2004 00: 36 Fron:
+AVIATION
+
+To: 0012127379536
+HALITY ANO
+REGISTRATON MANC
+UNITED STATE ON AMERICA
+DEPARTMENT OF TRANGPORATIÓM FEDÉRAL AVATION HOMEMATRATION
+STANDARD AIRWORTHINESS CERTIEICATE
+TE MOCACTURERANO MOORL
+GULFSTREAM O11598
+MAKER
+ISt
+P.1'1
+CATBOORY
+TRANSPORT
+NONE
+GATE
+1989
+AS0-TSB9-12
+DEPARTMENT OF TRANDPORTATIOM - FEDERAL AVIATION AÇINISTRATION
+CERTEICATE OF AIRCRAET BEGISTRATION
+TIONALTU
+FISTRATFON UL
+MANUFACTURER AND MANUPACTURER'S DESIGNATION OF AIRCRAFT
+GULFETAEIN AEROSPACE
+KAO Arcrets Adast Code 53110550
+MYPERION AIR INC
++03 FOULK RD STE 202
+WININGTON DE 19808-8742
+The certikey
+aNd be is the
+eit-
+Inact fer register
+purpose only
+and is no a cent-
+Atle of erie
+Federal Asla
+Er Adainigtaetion
+is cordiled ior da cata
+мінівікім
+debar Sumes al
+• Cied delation dared i
+не переном вызе !
+DATE OF ASSUE
+March 15. 1894
+
+U.8.
+Depersnient
+Federal Aviation
+Adminiatration
+
+
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401-6235
+Tel:
+Fax:
+May 14, 2007
+VIA HAND DELIVERY
+Jack A. Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+One Clearlake Centre, Suite 1400
+250 Australian Avenue South
+West Palm Beach, FL 33401-5015
+Dear Mr. Goldberger:
+Thank you for your letter of May 10, 2007, and the documents attached thereto. I have enclosed
+another copy of the grand jury subpoenas that were provided to Bruce Lyons, former counsel for Hyperion
+at the Federal Bureau of Investigation, 505 South Flagler Drive, Suite 500, West Palm Beach, FL 33401-
+5933.
+Thank you for your assistance with this matter.
+Sincerely,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By
+Assistant United States Attorney
+Enclosures
+cc: Special Agent
+_ FBI
+
+
+Diyision of Corporations - Online Services
+
+State of Delaware
+The Official Website for the First State
+Visit the Governor | General Assembly | Courts | Other Elected Officials | Federal, State & Local Sites
+State Directory | Help | Search Delaware /
+Citizen Services | Business Services | Visitor Info
+Department of State: Division of Corporations
+HOME
+About Agency
+Secretary's Letter
+Newsroom
+Frequent Questions
+Related Links
+Contact Us
+Office Location
+SERVICES
+Pay Taxes
+File UCC's
+Frequently Asked Questions View Search Results
+Entity Details
+File Number:
+
+THIS IS NOT A STATEMENT OF GOOD STANDING
+Incorporation Date /
+09/07/2000
+Formation Date:
+(mm/dd/yyyy)
+Status
+Validate Certificate
+INFORMATION
+Corporate Forms
+Corporate Fees
+UG Sensed Fees
+Entity Name:
+Entity Kind:
+Residency:
+JEGE, INC.
+CORPORATION
+DOMESTIC
+Entity Type: GENERAL
+State: DE
+REGISTERED AGENT INFORMATION
+Name:
+THE CORPORATION TRUST COMPANY
+Address:
+CORPORATION TRUST CENTER 1209 ORANGE STREET
+City:
+WILMINGTON
+County: NEW CASTLE
+State:
+DE
+Postal Code: 19801
+Phone:
+ore dealed marinate vailable cafe on can relieve saur for are rigo a
+nd more for a fee of $20.00
+Would you like C Status C Status, Tax & History Information
+- Submit
+Back to Entity Search
+To contact a Delaware Online Agent click here.
+site map | about this site | contact us | translate | delaware.gov
+https://sos-res.state.de.us/tin/controller
+
+
+
+State of Delaware
+The Official Website for the First State
+Visit the Govemor | General Assembly | Courts | Other Elected Officials | Federal, State & Local Site
+State Directory | Help | Search | This Site =] | Your Search...
+Citizen Services | Business Services | Visitor Infc
+Department of State: Division of Corporations
+HOME
+About Agency
+Secretary's Letter
+Newsroom
+Frequent Questions
+Related Links
+Contact Us
+Office Location
+SERVICES
+INFORMATION
+Corporate Forms
+Corporate Fees
+UCC Forms and Fees
+Taxes
+Expedited Services
+Service of Process
+REMOTE AGENTS "C"
+CAPITOL SERVICES, INC.
+615 South DuPont Highway
+Dover, DE 19901
+Kent County
+Ph:
+Fax:
+Website: http://www.capitolservices.com
+CORPAMERICA, INC.
+2711 Centerville Road
+Suite 400
+New Castle Co 19808
+Ph:
+or
+Fax:
+e-mail: info@corpamerica.com
+Website: http://www.CorpAmerica.com
+THE COMPANY CORPORATION
+2711 Centerville Road
+Suite 400
+Wilmington, DE 19808
+New Castle County
+Ph:
+or
+Fax:
+Website: http://www.corporate.com
+CORPORATION SERVICE COMPANY
+2711 Centerville Road
+Suite 400
+Wilmington, DE 19808
+New Castle County
+Ph:
+or
+Fax:
+e-mail: info@incspot.com
+Website: http://www.incspot.com
+CORPORATIONS & COMPANIES, INC.
+(CorpCo)
+910 Foulk Road
+Suite 201
+http://www.corp.delaware.gov/ragt-c.shtml
+THE CORPORATION TRUST COMPANY
+Corporation Trust Center
+1209 Orange Street
+Wilmington, DE 19801
+New Castle County
+Ph:
+Fax:
+Website: http://www.ctadvantage.com
+CORPORATIONS USA, LLC
+341 Raven Circle
+Wyoming, DE 19934
+Kent County
+Ph:
+or
+866/856-CUSA (2872)
+Fax: |
+Website: http://www.corporationsusa.com
+
+
+Wilmington, DE 19803
+New Castle County
+Ph:
+or
+Fax:
+
+Pay Taxes
+File UCC's
+Delaware Laws Online
+Name Reservations
+General Information
+Status
+Validate Certificate
+Last Updated: Wednesday, 21-Mar-2007 16:52:58 EDT
+site map | about this site | contact us | translate |
+delaware.gov
+http://www.corp.delaware.gov/ragt-c.shtml
+
+
+CT Corporation - Contact Information
+Home
+Products & Services
+
+Service Excellence
+News & Events / Industry Links
+CTAdvantage
+About CT
+Contact Information
+Overview/History | Contact Information | Employment
+We are always just a phone call or
+email away. Call 1
+email us at
+RUSECUR
+CERTIFED
+We're There for You
+Please select the juridiction in which you are located to contact the CT service
+office serving vour area. (Please note: The addresses listed below are for contact
+purposes only and should not be used on official documentation. Your service
+team can provide Registered Agent addresses.) We are always just a phone call
+or email away. Call 1-
+or email us at info@ctadvantage.com
+Select a state
+For Delaware:
+Corporation Trust Center
+1209 Orange Street
+Wilmington, DE 19801
+Phone:
+Toll Free:
+Fax:
+CTAdvantage.com™ is brought to you by CT Corporation @ 2007, a Wolters Kluwer company.
+Legal Disclaimer, Privacy Policy, Terms of Use
+http://ctadmin.ctadvantage.com/CTWebAdminApps/CTWebAdmin/pubcontent/ContactInformatio... 4/25/2007
+
+
+
+State of Delaware
+The Official Website for the First State
+Visit the Governor | General Assembly | Courts | Other Elected Officials | Federal, State & Local Site:
+State Directory | Help | Search Delaware |
+Citizen Services | Business Services | Visitor Info
+Department of State: Division of Corporations
+HOME
+About Agency
+Secretary's Letter
+Newsroom
+Frequent Questions
+Related Links
+Contact Us
+Office Location
+SERVICES
+Pay Taxes
+File UCC's
+Delaware Laws Online
+ame Reservatio
+eneral Informatio
+Status
+Validate Certificate
+INFORMATION
+Frequently Asked Questions View Search Results
+Entity Details
+File Number:
+
+THIS IS NOT A STATEMENT OF GOOD STANDING
+Incorporation Date
+07/18/1991
+Formation Date:
+(mm/dd/yyyy)
+Entity Name:
+Entity Kind:
+Residency:
+HYPERION AIR, INC.
+CORPORATION
+DOMESTIC
+Entity Type: GENERAL
+State: DE
+REGISTERED AGENT INFORMATION
+Name:
+Address:
+City:
+State:
+Phone:
+CORPORATION SERVICE COMPANY
+2711 CENTERVILLE ROAD SUITE 400
+WILMINGTON
+County: NEW CASTLE
+DE
+Postal Code: 19808
+Would you like Status r. Status, Tax & History Information Submit
+Back to Entity Search
+To contact a Delaware Online Agent click here.
+site map | about this site | contact us | translate | delaware.gov
+https://sos-res.state.de.us/tin/controller
+
+
+Page 1 of2
+Westlaw.
+Page 1
+CORPORATE RECORDS & BUSINESS REGISTRATIONS
+This Record Last Updated:
+Database Last Updated:
+Update Frequency:
+Current Date:
+Source:
+04/04/2001
+04-25-2007
+WEEKLY
+04/25/2007
+AS REPORTED BY THE SECRETARY OF STATE OR OTHER OFFICIAL
+SOURCE
+THE FOLLOWING DATA IS NOT AN OFFICIAL RECORD OF THE DEPARIMENT OF STATE OR THE
+STATE OF NEW YORK AND WEST, A THOMSON BUSINESS IS NOT AN EMPLOYEE OR AGENT
+THEREOF. ALL WARRANTIES, EXPRESS OR IMPLIED, REGARDING THE INFORMATION PROVIDED
+HEREIN, ARE DISCLAIMED BY THE DEPARIMENT OF STATE.
+COMPANY INFORMATION
+Company Name:
+Process Name:
+Process Address:
+County:
+J. EPSTEIN & COMPANY, INC.
+GOLD & WACHTEL, ESQS
+10 BAST 53RD STREET
+NEW YORK, NY 10022
+NEW YORK
+FILING INFORMATION
+Identification Number:
+Filing Date:
+State of Incorporation:
+Duration:
+Status:
+Status Attained Date:
+Corporation Type:
+Business Type:
+Where Filed:
+11/18/1988
+NEW YORK
+PERPETUAL
+INACTIVE
+04/04/2001
+PROFIT
+DOMESTIC BUSINESS CORPORATION
+DEPARTMENT OF STATB/DIVISION OF CORPORATIONS
+41 STATE STREET
+ALBANY, NY 12231
+• 2007 Thomson/West. No Claim to Orig. U.S. Govt. Works.
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full&vr=2.... 4/25/2007
+
+
+
+Page 2
+NAME INFORMATION
+Former Name:
+JEFFREY E. EPSTEIN, INC.
+AMENDMENT INFORMATION
+Amendments :
+04/04/2001 DISSOLUTION
+REFER TO MICROFILM NUMBER
+
+10/03/1997 NAME CHANGE
+REFER TO MICROFILM NUMBER
+
+02/22/1993 ERRONEOUS ENTRY REFER TO MICROFILM NUMBER
+
+09/23/1992 DISSOLUTION BY PROCLAMATION
+MICROFILM NUMBER DP-747315
+STOCK INFORMATION
+Stock:
+Authorized
+shares:
+200
+Call Westlaw CourtExpress at 1-877-DOC-RETR (1-
+to order copies of documents related to this or other
+matters.
+Additional charges apply.
+THE PRECEDING PUBLIC RECORD DATA IS FOR INFORMATION PURPOSES ONLY AND IS NOT THE
+OFFICIAL RECORD. CERTIFIED COPIES CAN ONLY BE OBTAINED FROM THE OFFICIAL SOURCE.
+END OF DOCUMENT
+• 2007 Thomson/West. No Claim to Orig. U.S. Govt. Works.
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full&vr=2..
+
+
+44-1
+:
+0 0 7 9 4
+US Department
+of Transportation
+ASSIGNMENT OF SPECIAL REGISTRATION NUMBERS
+Aircraft Make and Model
+BOE ING
+727÷31
+Serial Number
+Special Registration Number
+N
+N
+Present Registration Number
+Issue Date:
+ICAD AIRCRAFT ADDRESS CODE
+FOR N908JE.=
+
+'JEGE INC•
+103 FOULK RD STE 202
+WILMINGTON DE 19803-3742
+9089€
+NUMBER CHANGED TO.
+DATE -
+10 APR 18 2001
+MARCH 24, 2001
+This is your authority to change the United States registra
+Wen tuate ou be above described alican to the special
+Carry duplicate of this form in the aircraft together with the
+id registration certificate as interim authority to operate the
+aircraft pending receipt of revised certificate of registration.
+est alight standards Diste face thiness from your near.
+The latest FAA Form 8130-6, Application
+or Airworthiness on file is dated
+IULy: 23, 1991
+The airworthiness classification and category:
+STD TRANSP
+INSTRUCTIONS:
+SIGN AND RETURN THE ORIGINAL of this form to the Civil Aviation Registry, AF S-750, within 5 days after the special registration number is
+affixed on the aircraft. A revised certificate will then be issued. This authority is valid for 90 days from the issue date.
+The authority to use the special number expires:
+MARCH 24, 2002
+CERTIFICATION: I certify that the special registration number was placed on the
+aircraft described above.
+RETURN FORM TO:
+Civil Aviation Registry, AFS-750
+P.O. Box 25504
+Oklahoma City, Oklahoma 73125-0504
+Signature of Owner.
+Title of Owner:
+PRESIDEN
+Date Placed on Aircraft:
+4-6-01
+AC Form 8050-64
+(6/95) Supersedes Previous Edition
+
+
+
+a4=.
+•...
+FILED WITH FAM..
+'01 APR 9 AM 11 06
+OKLATONS CITY
+JJ.
+
+43-1-
+Insured Aircraft Title Service, Inc.
+P.O. Box 19527 • Oklahoma City, Oklahoma 73144 •
+(800)|
+T'
+FEDERAL AVIATION ADMINISTRATION
+CENIRAL RECORDS DIVISION
+OKLAHOMA CITY, OK
+Gentlemen:
+Please reserve N
+07000- CA0- 22087
+ONLY for:
+-64
+************
+Please reserve N
+DATE:_
+1-24-01
+WHEN AVAILABLE
+RESERVEN_
+**********************************
+******
+for assignment to the following aircraft:
+Current N#
+Boeing
+Make
+Which is (1) being purchased by: XX
+_ 727-31
+Model
+or (2) is registered to:_
+Serial #
+JEGE, Inc.
+c/o IATS, PO Box 19527
+Okla. City, OK 73144
+
+$10.00 01/24/2001
+Payment of the required $10 fee per number to reserve it for one year is attached. If
+the preferred N nurber is not available, please contact the undersigned for a selection
+of a new nurber.
+64 forn
+Please send the letter of confirmation for the-resdaved number to Insured Aircraft Title
+Service in the P.D.. Room.
+ADDITIONAL INFORMATION:
+*See Part III for the completion of the N number change.
+...,
+Lili
+REQUESTED BY:
+Denise Badger
+Serving the Aviation Financial Community for over 30 years
+
+
+'01 JAN 24 AM 11 19
+..'
+
+
+NITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATIC
+PARAL AVIATION ADMINISTRATION-MIKE MONRONEY AERONAUTICAL CENT
+AIRCRAFT REGISTRATION APPLICATION
+UNITED STATES
+REGISTRATION NUMBER NI
+AIRCRAFT MANUFACTURER & MODEL
+Boeing 727-31
+AIRCRAFT SERIAL No.
+ORM APPROVEL
+MB No. 2120-004
+8
+42-1
+CERT. ISSUE DATE
+฿ JAN 25 2001
+FOR FAA USE ONLY
+TYPE OF REGISTRATION (Check one box)
+• 1. Individual 2. Partnership 12 3. Corporallon 4. Coowner [I 5. Gove. L 8. Monition
+NAME OF APPLICANT (Person(s) show on evidence of ownership. If individual, give last name, frast name, and midle inita.)
+JEGE, Inc.
+TELEPHONE NUMBER: (
+ADDRESS (Permanent mailing addriss for first applicant listed.)
+Number and stret: 103 Foulk Road, Suite 202
+Rural Route:
+CITY
+P.O. Box:
+STATE
+TZIP CODE
+Wilmington
+DE
+19803
+CHECK HERE IF YOU ARE ONLY REPORTING A CHANGE OF ADDRESS
+ATTENTION! Read the following statement before signing this application.
+This portion MUST be completed.
+(L'S. Code The 18, Se. 1r to ary quaston in this applicaton may be grounds for punishment by fine and for imprisonment
+CERTIFICATION
+WE CERTIFY:
+* That unlea Saleel la owned by the undersigned applican, who is a clizen (inclusting corporations)
+(For vollng trust, give name of trustes:.
+CHECK ONE AS APPROPRIATE:
+a. O A resident alien, with alion registration (Form 1-151 or Form 1-551) No.
+. And sad airer is and and pred any ding i to ed is no or i or are rile to
+2) That the alreraft is not registered under the laws of any foreign country; an
+3) That legal evidence of ownership is attached or has been filed with the Federal Aviation Administration
+). or:
+NOTE: If executed for co-ownership all applicants must sign. Use reverse side if necessary.
+TYPE OR PRINT NAME BELOW SIGNATURE
+SIGNATURE
+IIPLE
+PART OF THIS
+N MUST
+IN INK
+SIGNATURE
+EACH
+SIGNATURE
+!
+President
+TOLE
+ISSUED TEMP CERT OF
+TILE REG TO EXPIRE
+TOlO5I7
+7/9/01
+DATE 2-24-01
+NOTE Ponding recalpt of the Certificate of Aircraft Registration, the arcraft may be operated for a period not in excess of 90
+days, during which time the PINK copy of this application must be carried in the alrcraft.
+AC Form 8050-1 (12/90) (0052-00-628-9007) Supersedes Previous Edition
+
+
+97 88 0v
+•
+
+FORM APPROVE
+MB NO. 2120-00
+UNITED STATES OF AMERICA
+U.S. DEPARTMENT OF TRANSORTATION DERAAVIATIN ADMINISTRATION
+AIRCRAFT BILL OF SALE
+=OR AND IN CONSIDERATION OF SI. EOVC THE
+• UNDERSIGNED OWNER(S)
+OF THE FULL
+IND BENEFICIAL TITLE OF THE AIRCRAFT DES.
+CRIBED AS FOLLOWS:
+UNITED STATES
+REGISTRATION NUMBER
+AIRCRAFT MANUFACTURER & MODEL
+Boeing
+727-31
+AIRCRAFT SERIAL No.
+4 *C015169
+41-1
+CONVEYANCE RECORDED
+DOES THIS
+DAY OF
+Den
+HEREBY SELL, GRANT, TRANSFER AND
+DELIVER ALL RIGHTS, TITLE, AND INTERESTS
+IN AND TO SUCH AIRCRAFT UNTO:
+NAME AND ADDRESS
+(IF INDIVIDUAL(S), GIVE LAST NAME, FIRST NAME, AND MIDDLE INITIAL.)
+JEGE, Inc.
+457 Madison Ave, 4th Floor
+New York NY" 10022
+
+2001 JAN 25 AM 9 04
+FEDERAL AVIATION
+*DAMAN STRASON
+PURCHASER
+DEALER CERTIFICATE NUMBER
+AND TO its successors
+*EXECUTORS, ADMINIGTRATORS, AND ASSIGNS TO HAVE AND TO HOLD
+SINGULARLY THE SAID AIRCRAFT FOREVER, AND WARRANTS THE TITLE THEREOF
+IN TESTIMONY WHEREOF
+I
+HAND AND SEAL THIS /QtL
+NAME (S) OF SELLER
+(TYPED OR PRINTED)
+DAY OF LIn
+17001
+TITLE
+(TYPED OR PRINTED)
+CC
+SIGN.)
+Real Estate Ex-
+change, Ina.
+Зі. f. Зини
+Vice President
+:
+BORON LEERED PURPOSES OF FAA READY 299523 MAY BE REQUIREO
+BY LOCAL LAW FOR VALIDITY OF THE INSTRUMENT.)
+$5.00. 01/19/2001
+ORIGINAL: TO FAA
+AC Form 8050-2 (9/92) (NSN 0052-00-629-0003) Supersedes Previous Edition
+
+
+8tL88L00VIH]
+
+• 0 0
+DEPARTMENT OF TRANSPORTATION
+FEDERAL AVIATION ADMINISTRATION
+-
+THIS FORM SERVES TWO PURPOSES:
+PART I acknowledges the recording of a security conveyance covering the collateral shown
+'ART II is a suggested form of release which may be used to release the collateral from th
+terms of the conveyance.
+PART I - CONVEYANCE RECORDATION NOTICE
+NAME (last name first) OF DEBTOR
+Real Estate Exchange, Inc.
+NAME and ADDRESS OF SECURED PARTY/ASSIGNEE
+Limited Service Corporation
+clo Timothy P. Stehle
+The Limited, Inc.
+4387 International Gateway
+Columbus, Ohio 43219
+40-1
+CC015168
+NAME OF SECURED PARTY'S ASSIGNOR (if assigned) NA
+CONVEYANCE RECORDED
+2001 JAN 25 AM 9 02
+FEDERAL AVIATION
+ADMINISTRATION
+SEE RECORDED
+CONVEYANCE
+NUMBER K028213
+FICHEN R3
+PAGER 39-21
+FAA REGISTRATION
+NUMBER
+| AIRCRAFT SERIAL
+NUMBER
+ENGINE MFR. And MODEL
+Pratt & Whitney, JT8D-219 (position 1 & 3) and JTBD-
+7B (position 2)
+NOPELLER MER. And MODEL
+AIRCRAFT MFR. (BUILDER) and MODEL.
+Boeing 727-31
+ENGINE SERIAL NUMBER (S)
+726121 (position 1), 654373 (position 2) & 726122 (position 3)
+PROPELLER SERIAL NUMBER (S)
+None
+CHE SECURITY CONVEYANCE DATED -11/16/00
+THE FAA AIRCRAFT REGISTRY ON 12|18/00
+filed 11/16/00
+COVERING THE ABOVE COLLATERAL WAS RECORDED BY
+AS CONVEYANCE NUMBER. KOLONE
+FAA CONVEYANCE EXAMINER
+at a care are rena re be are beared party and returned to the A Aircraft Registry
+THE NOTE OR OTHER EVIDENCE OF INDEBTEDNESS SECURED BY THE CONVEYANCE REFERRED TO HEREIN ON THE
+DATE OF RELEASE:
+Вы
+LIMITI
+SIGNATURE (in ink)
+Kenneth B. Gilmar
+TITLE
+President
+A PERSON SIGNING FOR A CORPORATION MUST BE A CORPORATE OFFICER OR HOLD A MANAGERIAL POSITION
+AND MUST SHOW HIS TITLE. A PERSON SIGNING FOR ANOTHER SHOULD SEE PARTS 47 AND 49 OF THE FEDERAL
+AVIATION REGULATIONS (14 CFR)
+AC Form 8050-41 (7-83) (0052-00-543-9001
+
+
+
+39.21
+U.S. DEPARTMENT OF TRANSPORTATION
+FEDERAL AVIATION ADMINISTRATION
+CROSS-REFERENCE-RECORDATION
+SEE CONVEYANCE NO
+FILING DATE:
+This form is to be used in cases where a conveyance covers several aircraft and engines, propellers, or locations. File original of this form
+with the recorded conveyance and a copy in each aircraft folder involved.
+TYPE OF CONVEYANCE
+DATE EXECUTED
+AIRCRAFT SECURITY AGREEMENT
+November 16, 2000
+FROM
+REAL ESTATE EXCHANGE, INC.
+TO OR ASSIGNED TO
+LIMITED SERVICE CORP.
+THE FOLLOWING COLLATERAL IS COVERED BY THE CONVEYANCE:
+AIRCRAET (List by registration number)
+DOCUMENT NO.
+K028213
+DATE RECORDED
+December 18, 2000
+I TOTAL NUMBER INVOLVED 1
+ENGINES
+MAKE(S)
+PRATT & WHITNEY JT8D-219
+PRATT & WHITNEY JT8D-7E
+PROPELLER
+MAKE(S)
+SPARE PARTS - LOCATIONS
+LOCATION
+RECORDED CONVEYANCE FILED IN:
+AC FORM 8050-23(1-96) (0052-00-582-6000)
+_ TOTAL NUMBER INVOLVED 3
+SERIAL
+NO.
+TOTAL NUMBER INVOLVED
+SERIAL
+NO.
+T TOTAL NUMBER INVOLVED
+BOEING 727-31, SN: MIl
+
+
+39-20.
+
+
+. "
+0 0 8 6
+AIRCRAFT SECURITY AGREEMENT
+•
+CONVEYANCE RECORDED
+Debtor:
+Real Estate Exchange, Inc.
+900 SW 5" Avenue
+Mezz. Level
+Portland, Oregon 97204
+Secured
+Party:
+2000 DEG 18 PM 1 35
+FEDERAL AVIATION
+ADMINISTRATION
+Limited Service Corporation
+c/o Timothy P. Stehle
+The Limited, Inc.
+4387 International Gateway
+Columbus, Ohio 43219
+Date:
+- 2000
+Complete description of collateral being mortgaged:
+Aircraft:
+FAA Registration Number -
+Make and Model - Boeing 727-31
+Serial Number -
+Engines: Iwo Pratt & Whitney engines, model number JT8D-219, serial
+numbers 726121 and 726122; and Pratt & Whitney engine, model
+number JT8D-7B, serial number 654373
+Spare Parts Locations: None
+(not exhaustive)
+together with all equipment and accessories attached thereto or used in connection therewith, all
+spare parts, all replacements, and all proceeds of the foregoing (whether accounts, general
+intangibles, instruments, documents, money, or goods), all of which are included in the term
+"Aircraft" as used herein.
+1. GRANT OF LIEN AND SECURITY INTEREST
+Section 1.01. Debtor hereby grants a lien on and security interest in the Aircraft to
+Secured Party for the purpose of securing the following obligations (the "Oblig3i815507ghe
+order named:
+FIRST:
+The payment of all indebtedness evidenced by and according to the
+terms of that certain promissory note dated as of October 22, 1998, executed by Debtor and
+payable to the order of Secured Party in the aggregate principal amount of Forty-Two Million
+Dollars ($42,000,000), with interest thereon at the rate of the prime rate of interest per annum
+announced from time to time by Bank One, N.A. (the "Prime Rate"), compounded from such
+39-19
+K028213
+35.00 1145/2050
+
+
+39.18
+FILED WITH A
+•00 NDU 16 PM 2 35
+..:
+
+
+
+39-17
+SECOND: (1) The prompt and faithful discharge and performance of (a) each
+agreement of Debtor herein contained made with or for the benefit of Secured Party it
+2. DEBTOR'S REPRESENTATIONS, WARRANTIES AND COVENANTS
+Section 2.01. Debtor hereby represents and hereby warrants to Secured Party that it is the
+absolute owner of all of the legal and equitable title to the Aircraft and in possession thereof and
+that the same is free and clear of all liens, encumbrances, and adverse claims whatsoever.
+Section 2,02. Debtor hereby agrees to (a) maintain, at its expense and with reputable,
+licensed insurers, insurance naming it and Secured Party as named insureds in the following
+types and amounts: (i) hull insurance in amount not less than $21,000,000; (ii) liability
+insurance in amount not less that $300,000,000 per occurrence as respects ground risks; and, (iii)
+liability insurance in amount not less that $300,000,000 with respect to the Aircraft for all times
+during which the Aircraft is engaged in flight operations; (b) convey or suffer to exist no interest
+in the Aircraft without the express written consent of Secured Party; and (c) indemnify and save
+and hold harmless Secured Party for and against any and all claims, losses or expenses arising
+out of Debtor's (i) possession, operation or use of the Aircraft or (ii) breach or failure to comply
+with any provision of the Note or this Security Agreement to be kept and performed by Debtor.
+Section 2.03. Debtor will, at its own cost and expense, (a) record, re-record, register, reregister, file and refile this Security Agreement, financing and continuation statements with
+respect thereto, and such other instruments as may from time to time be requested by Secured
+Party in all such jurisdictions and offices as Secured Party may from time to time request in order
+that (i) the lien and security interest provided by this Security Agreement is at all times a valid
+first and prior lien on and perfected security interest in the Aircraft, and (ii) the security for the
+Obligations and the rights and remedies of Secured Party may be established, confirmed,
+maintained and protected; and (b) furnish to Secured Party evidence satisfactory to Secured Party
+of every such recording, registering, filing and other action.
+Section 2.04. Debtor covenants, agrees and warrants that it will at all times defend and
+protect the lien and security interest created by this Security Agreement upon the Aircraft, and
+further covenants and agrees that it will hereafter from time to time, perform, execute, deliver
+and file or cause to be performed, executed, delivered and filed all such further and other acts,
+conveyances, transfers, instruments, financing statements, continuation statements and
+assurances as may be requested by Secured Party, for the better assuring, conveying, transferring,
+mortgaging, hypothecating and confirming unto Secured Party of all or any part of the Aircraft,
+Whether now owned or hereafter acquired by Debtor, or for securing the rights and remedies of
+Secured Party.
+2
+
+
+39-16
+
+
+39-15
+0 0 0 3 8
+Section 2.05. (a) Debtor will, at its own cost and expense, inspect, service, repair and
+maintain the Aircraft, or cause the Aircraft to be inspected, serviced, repaired and maintained, in
+good operating condition, and will cause the airworthiness certification of the Aircraft to be
+maintained in good standing at all times under the Federal Aviation Act.
+from time to time may become worn out, lost, destroyed, confiscated or rendered unfit for use.
+Such equipment and replacements (i) shall be in as good operating condition and shall have a
+Fall liens and encumbrances. All such equipment and replacements shall be and become a pa
+f the Aircraft and shall be subject to all the terms of this Security Agreement. Replacemen
+Debtor to Secured Party promptly after such replacements are made, and such reports shall
+describe in reasonable detail the items so used as replacements and the items replaced thereby.
+Any part or item of property may be removed from the Aircraft in order
+that the same may be replaced, inspected, repaired, reconditioned or otherwise serviced without
+affecting or impairing the lien and security interest of Secured Party with respect to such part or
+item of property. However, no replacement or equipment subject to the lien imposed by this
+Security Agreement or other item of property useful in connection with the operation of the
+Aircraft shall be removed therefrom or replaced except in accordance with this Section 2.05 and
+for the purposes of such replacement, inspection, repair, reconditioning or other service
+Section 2.06. (a) Immediately after any engine which becomes a part of the Aircraft is
+replaced in accordance with the provisions of Section 2.05, Debtor will execute and deliver a
+supplement to this Security Agreement in form and substance satisfactory to Secured Party (the
+"Supplement"), which Supplement, among other things, shall cause the property described
+therein to be subject to the lien and security interest created under this Security Agreement.
+Section 2.07. Debtor covenants and agrees that it will comply with all applicable federal,
+state, municipal, territorial and foreign laws, ordinances, regulations and rules applicable to any
+of the Aircraft, and that it will not cause or permit the Aircraft to be used or operated in any
+manner contrary to any such law, ordinance, regulation or rule. Debtor also agrees not to fly the
+Aircraft, or suffer the Aircraft to be flown or located, in any area excluded from coverage by any
+insurance policy in effect with respect to the Aircraft or required by the terms hereof. Debtor
+also agrees, without limiting the generality of the foregoing, (a) not to fly or suffer the Aircraft to
+be flown or located in any of the former so-called "Iron-Curtain" countries or areas, including
+without limitation Russia, Ukraine, Georgia, Hungary, the Czech Republic, the Slovak Republic,
+Croatia, Bosnia-Herzegovina, Bulgaria, Albania, Poland, Rumania, Latvia, Estonia, Lithuania,
+Viet Nam, China, Cuba and North Korea, or in any satellite country of, or any territory occupied
+by, or under control of, Russia or China, or in Iraq, Iran or Afghanistan; and (b) not to use, fly or
+locate any of the Aircraft, or suffer any of the Aircraft to be used, flown or located, in or near any
+recognized or threatened area of hostilities unless fully covered to Secured Party's satisfaction by
+3
+
+
+39-14..
+... i
+
+
+•
+. 0 0 0 9
+39.13
+war risk insurance or unless the Aircraft is operated or used under contract with the government
+of the United States of America under which contract such government assumes liability for any
+lamage, loss, destruction or failure to return possession of the Aircraft at the end of the term of
+such contract.
+Debtor will not take any action, or suffer any omission, that would cause
+the Aircraft to be ineligible to be maintained under Part 91, subpart F, of the Federal Aviation
+Regulations.
+Section 2.08. If Debtor shall default in the observance or performance of any of its
+discharge any lien or security interest, and Debtor shall give, or take all necessary steps to give,
+Secured Party access to the Aircraft for such purposes. Debtor shall promptly reimburse Secured
+Party, together with interest at a rate equal to two percent per annum in excess of the Prime Rate
+for any and all expenditures so made or incurred and such expenditures shall constitute part of
+the Obligations; provided, however, that Secured Party, though privileged so to do, shall be
+under no obligation to Debtor to make any such expenditures nor shall the making thereof relieve
+Debtor of any default in that respect.
+Section 2.09. Debtor will permit 'and/or arrange for inspection by Secured Party, its
+officers, employees and agents, of the Aircraft and all maintenance and operational records on
+the Aircraft at any reasonable time and from time to time upon the request of Secured Party.
+Section 2.10. (a) Debtor shall maintain such log books and other records pertaining to the
+Aircraft required by the rules and regulations of the Federal Aviation Administration. Debtor
+shall keep accurate and complete books and records regarding the Aircraft in accordance with
+generally accepted accounting principles. For the purpose of establishing the location and value
+of the Aircraft, Debtor shall furnish to Secured Party information adequate to identify the
+upon written request and shall furnish Secured Party with such additional information relating to
+the Aircraft as Secured Party shall reasonably request.
+(b) Debtor represents and warrants that the site at which the Aircraft will be
+permanently hangared or located (its "Permanent Site") is accurately and completely set forth on
+Exhibit A attached to this Security Agreement and that an exhibit to each Supplement will
+accurately and completely set forth the Permanent Site of any additional engines which become
+part of the Aircraft. Debtor shall not change, or permit to be changed, the Permanent Site of
+Aircraft, except to such new location as it may establish in accordance with paragraph () of this
+Section 2.10. In the event that the Aircraft is to be removed from its Permanent Site to a location
+within the United States of America for more than 180 days (or more than 60 days with respect
+to any such engine of less than 750 horsepower which is removed to the State of Louisiana),
+Debtor shall give Secured Party written notice of this fact, including information concerning
+proposed temporary locations, the length of time it is expected to be removed from its Permanent
+4
+
+
+3: =
+39-12
+.:*:
+
+
+39-11
+1 0 0 0 0 0 0 5 8 4 0
+apply to routine flights from or to the United States of America in the ordinary course of
+of Debtor's principal office nor the location where such books of account and records are kept
+will be changed except in accordance with paragraph (d) of this Section 2.10.
+(d) Debtor will not establish any different location for the Permanent Site of the
+Aircraft, or for the place where the books of account and records on the Aircraft are kept, until (i)
+it shall have given to Secured Party written notice, at least 10 days before doing so, of its
+intention to establish such new location, clearly describing each such new location and providing
+such other information in connection therewith as Secured Party may reasonably request, and (i1)
+with respect to each such new location, it shall have taken such action, satisfactory to Secured
+Party, as may be necessary to maintain the security interest of Secured Party in the Aircraft
+granted hereunder at all times fully perfected and in full force and effect.
+Section 2.11. Debtor will immediately notify Secured Party of any change, of which
+Debtor has knowledge, which materially and adversely affects or may materially and adversely
+affect either Secured Party's or Debtor's right, title or interest in or to, or the value of, the
+Aircraft.
+Section 2.12. Debtor will pay when due any and all taxes, charges and assessments
+which are levied upon or with respect to the Aircraft and the operation thereof.
+Section 2,13. Debtor will furnish to Secured Party or make available to Secured Party for
+review as and when requested by Secured Party any information or documentation or records
+reasonably requested by Secured Party.
+3. DEFAULT; REMEDIES
+5
+
+
+39-10
+
+
+39-9
+
+the interest thereon, shall immediately become due and payable at the sole option of Secured
+Party.
+Section 3.02. Upon the occurrence of any Event of Default, but subject always to any
+mandatory requirement of applicable law, Secured Party may, by notice to Debtor:
+(a) Take possession of all or any part of the Aircraft then subject to this Security
+Agreement and all of the rights of Debtor therein shall forthwith be surrendered to Secured Party,
+and Secured Party may by its agents, or otherwise, take possession of the Aircraft wherever
+found, with or without notice or process of law and without being responsible for any loss or
+damage, and for that purpose may enter upon any premises of Debtor without liability for suit,
+action or other proceeding by Debtor and remove the same. Secured Party, without being
+responsible for loss or damage, may hold, store and/or use, operate, manage and control the
+Aircraft, and may collect and receive all tolls, rents, revenues, issues and profits of the Aircrafi
+and every part thereof, until:
+(i) the Aircraft is sold pursuant to this Section 3.02; or
+(ii) the Obligations are satisfied and paid in full, at which
+time Secured Party shall deliver to the person or persons entitled
+thereto all of the Aircraft then held by Secured Party under this
+paragraph (a) of this Section 3.02.
+(b) Secured Party shall be deemed to have exercised reasonable care in the
+custody and preservation of such of the Aircraft as may be in Secured Party's possession if
+Secured Party takes such action for that purpose as Debtor shall request in writing, provided that
+Secured Party shall not be required to take any such requested action if, in the judgment of
+Secured Party, such action would impair Secured Party's security interest in the Aircraft or its
+rights in, or the value of, the Aircraft, and provided further that such written request is received
+by Secured Party in sufficient time to permit Secured Party to take the requested action. Debtor
+acknowledges that failure of Secured Party to comply with any such request shall not of itself be
+deemed a failure to exercise reasonable care, and no failure of Secured Party to preserve or
+protect any rights with respect to the Aircraft against prior parties, or to do any act with respect
+to the preservation of the Aircraft not so requested by Debtor, shall be deemed to be a failure to
+exercise reasonable care in the custody or preservation of the Aircraft.
+(c) Secured Party may, by its agent or otherwise, sell at public auction the
+Aircraft, or any part thereof, upon such conditions as to price, terms of payment and such other
+terms of sale as Secured Party may fix.
+(d) Notice of any sale pursuant to this Section 3.02 shall state the time when, and
+the place where, such sale is to be made, shall contain a brief description of the property to be
+sold and shall be deemed reasonable if it is mailed to Debtor at least 10 days before the date of
+such sale. Such sale may be held at any place where sales or public auctions are customarily held
+in the City of Columbus, State of Ohio, or in any city or county in a state where the Aircraft to be
+sold is located.
+6
+
+
+39-8
+"'.".
+
+
+:
+3 0 0 0 0 0 5 8 & 2
+39-7
+(e) Secured Party, with or without taking possession of the Aircraft, may take
+legal proceedings for:
+(i) the specific performance of any covenant or agreement
+herein contained or in aid of the execution of any right or power
+herein granted;
+(i) foreclosure hereunder;
+(iii) the sale, under the judgment or decree of any court of
+competent jurisdiction, of the Aircraft or any part thereof;
+(iv) the appointment of a receiver or receivers pending any
+foreclosure hereunder or the sale of the Aircraft under an order of a
+court of competent jurisdiction or under executory or other legal
+process;
+• the recovery of judgment for the outstanding balance of
+the Obligations and the collection of the same out of any properties
+of Debtor; or
+(vi) the enforcement of any other appropriate remedy, and
+Secured Party shall be entitled, as a matter of right, to the
+appointment of a receiver of all or any part of the Aircraft.
+Section 3.03. Debtor hereby irrevocably appoints Secured Party, its agents and attorneys,
+successors and assigns, and each of them, the true and lawful attorneys of Debtor, in its name and
+stead, to make all necessary transfers of any part or all of the Aircraft in connection with any sale
+or other disposal thereof made pursuant to Section 3.02, and for that purpose they may execut
+all necessary instruments of assignment and transfer, Debtor hereby ratifying and confirming al
+that its said attorneys shall lawfully do by virtue hereof. Nevertheless, Debtor shall, if so
+4. MISCELLANEOUS
+Section 4.01. Any notices hereunder shall be given to the parties at their respective
+addresses set forth herein.
+Section 4.02. This Security Agreement is to be interpreted under the local laws of the
+State of Ohio, except only to the extent of United States federal laws of mandatory application.
+
+
+39.i0..
+
+
+39-5
+0 0 0
+IN WITNESS WHEREOF, the parties hereto have executed and sealed this Agreement on the
+-
+day and year first above written.
+• ACKNOWLEDGMENT:
+ACKNOWLEDGMENT:
+San Eleffe
+DEBTOR:
+REAL ESTATE EXCHANGE, INC.
+By:
+Print Name:
+Its:
+SECURED PARTY:
+LIMITED SERVICE CORPORATION
+By:
+Print Name:
+Title: 0.7
+Timotity 8. 4p0s
+8
+
+
+39.4
+
+
+39-3
+0 0 58
+44
+IN WITNESS WHEREOF, the parties hereto have executed and sealed this Agreement on the
+day and year first above written.
+ACKNOWLEDGMENT:
+DEBTOR:
+REAL ESTATE EXCHANGE, INC.
+Sijaf. Butle
+ACKNOWLEDGMENT:
+Vanda K. bara
+Its:_
+Secretary
+SECURED PARTY:
+LIMITED SERVICE CORPORATION
+By:
+Print Name:
+Title:
+8
+
+
+39.22.
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/bd76c9cbecbf1bba9b5d069f5b57dc97772356d022e814dfe6a2eedbcf22039d.receipt.json b/vision-fixhub/ds9-unparsed-05/bd76c9cbecbf1bba9b5d069f5b57dc97772356d022e814dfe6a2eedbcf22039d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0b95754bc5a8f77059664f2c98a2ceab9a360317
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bd76c9cbecbf1bba9b5d069f5b57dc97772356d022e814dfe6a2eedbcf22039d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1273,
+  "dataset": "marble-joined",
+  "doc_id": "bd76c9cbecbf1bba9b5d069f5b57dc97772356d022e814dfe6a2eedbcf22039d",
+  "engine": "marble-apple-vision",
+  "event_count": 63,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "341bc6956c6f37476ae9aaa6cf45895567d6fd1b4dd50e39d81e63e69e987ef2",
+  "output_sha256": "f11f8c78679fa58849abc229d0e438745991d845adf981c72dc115126e739be3",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/bd8fb9db87717e86ced5387756f050fa50251e3af1455478105fc5fb6889d4a0.md b/vision-fixhub/ds9-unparsed-05/bd8fb9db87717e86ced5387756f050fa50251e3af1455478105fc5fb6889d4a0.md
new file mode 100644
index 0000000000000000000000000000000000000000..adea9ac14b4ba97a33d11ce72a15517208e7ba13
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bd8fb9db87717e86ced5387756f050fa50251e3af1455478105fc5fb6889d4a0.md
@@ -0,0 +1,458 @@
+Statements
+
+
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE FIRM
+VISIT OUR WEBSITE
+www.bearstearns.com
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+May 25, 2001
+Important Message
+Please note: You may find more than one statement
+in this envelope. Beginning this month, all statements with
+the same Address and Social Security number / Taxpayer
+Identification number are being mailed in one envelope. For
+further details, please contact your account executive.
+INTERESTS
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Premise or Third Party Repurchase Agreements
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PURCHASE/
+IEPURCHASE
+PLACHASE PRICE/
+START DATE
+NO DATE
+PRINCIPAL
+06/25/01
+OPEN
+2.313.747.45
+TOTAL REPURCHASE AGREEMENTS
+The at all pront dis do not appear in any other section of this statemen.
+PRICING
+RATE
+3.970000
+REPO/ ACCRUED
+INTEREST
+1,739.17
+NET AMOUNT
+2.315.486.62
+$2,315,486.62
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four or ratanal furycer rebr die Set revere date for portant formation.
+07/01/01;02:12 001
+
+
+2 org
+Sear, Stears & Co. Inc
+45 Park Avenue
+New York. New York 10167
+Your messages
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+May 25, 2001
+STOP
+****** End of Statement******
+027
+07:01/01:02:12 001
+
+
+3 of 3
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+027
+07:01/01:02:12 001
+
+
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE FIRM
+VISIT OUR WEBSITE
+www.bearstearns.com
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD April 28, 2001
+THROUGH
+May 25, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+April 27, 2001
+Important Message
+In an effort to deliver statements to you more efficiently,
+Bear Steams has enhanced the distribution of
+statements to household accounts. Beginning in June,
+all statements with the same Address and Social
+Security number / Taxpayer identification number wil
+be mailed in a single envelope. For further details,
+please contact your account executive.
+INTERESTS
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Premise or Third Party Repurchase Agreements
+with Bear,Stearns& Co. Inc. outstanding as of date of statement
+PURCHASE
+REPURCHASE
+PLACHASE PRICE/
+START DATE
+END DATE
+PRINCIPAL
+05/22/01
+OPEN
+5.029.771.53
+TOTAL REPURCHASE AGREEMENTS
+The at all prent dis do not appear in any other section of this statemen.
+PRICING
+RATE
+3.770000
+REPO/ NOCRUED
+INTEREST
+69,082.29
+NET AMOUNT
+5,098,853.82
+$5,098,853.82
+STOP
+****** End of Statement******
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four or ratanal purger red de Set revere date for portant iformation.
+05/26/01:12:59 001
+V478
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+027
+05/26/01:12:59 001
+V478
+
+
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+FIRM
+www.bearstearns.com
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD March 31, 2001
+THROUGH
+April 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+March 30,2001
+INTERESTS
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Premise or Third Party Repurchase Agreements
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PURCHASEr
+REPURCHASE
+PLACHASE PRICE/
+START DATE
+END DATE
+PRINCIPAL
+04/02/01
+OPEN
+3.229.771.53
+TOTAL REPURCHASE AGREEMENTS
+The at all pront dis do not appear in any other section of this statemen.
+PRICING
+RATE
+4.370000
+REPO! NOCRUED
+INTEREST
+57,179.07
+NET AMOUNT
+3.286.950.60
+$3,286,950.60
+STOP
+****** End of Statement******
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s foul ratanal purger red de Set revere die for portant iformation.
+04/28/01:19:29 001
+V471
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+027
+04/28/01:19:29 001
+V471
+
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE FIRM
+VISIT OUR WEBSITE
+www.bearstearns.com
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD February 24, 2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+February 23,2001
+Important Message
+Decimal Trading is Here for Nasdaq!
+Decimal Trading is the shift from fractional pricing
+(e.g.21 1/2) to decimal pricing (e.g.$21.50 yor
+equities and options. Nasdaq securities have been
+phased in during March and the remaining securities
+are scheduled to be trading in decimals in April.
+For details, visit our website at www.bearstearns.
+com.
+INTERESTS
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Premise or Third Party Repurchase Agreements
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PURCHASE
+EPURCHASE
+PLACHASE PRICE!
+START DATE
+NO DATE
+01/04/01
+OPEN
+PRINCIPAL
+3.379.771.53
+TOTAL REPURCHASE AGREEMENTS
+The at all pront dis do not appear in any other section of this statemen.
+PRICING
+RATE
+5.250000
+REPOL NOCRUED
+INTEREST
+45,290.82
+NET AMOUNT
+3.425,062.35
+$3,425,062.35
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four ratanal furyce rearde Set revere dae for portant iformation.
+
+
+2 org
+ear, Stears & Co. In
+45 Park Avenue
+New York, New York 10167
+Your messages
+Bear, Stearns Securities Corp, Net Capital and
+Net Capital Requirements:
+At November 30, 2000 and January 26, 2001, the
+Company's net capital of $2,620,960,000 and
+$2,202,436,000, all respectively.
+A complete copy of the Bear, Stearns Securities
+Corp, Statement of Financial Condition is available
+on the web site www.bearstearns.com, Alternatively,
+to request a free printed copy please call -
+toll free 1-866-299-9331,
+STOP
+****** End of Statement******
+027
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD February 24, 2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+February 23,2001
+
+
+3 of 3
+027
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+
+
+OFFICE SERVICING YOUR ACOUNT
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+FIRM
+www.bearstearns.com
+What's In This Statement
+Your Messages ................
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+January 26, 2001
+1
+INTERESTS
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Premise or Third Party Repurchase Agreements
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PUACHASE
+EPURCHASE
+PLACHASE PRICE!
+START DATE
+ND DATI
+01/04/01
+OPEN
+PRINCIPAL
+3.379.771.53
+TOTAL REPURCHASE AGREEMENTS
+*As of statement dato
+The above posions do not appear in arry other section of this statement.
+PRICING
+RATE
+5.350000
+REPON ACCRUED
+INTEREST
+28,148.80
+NET AMOUNT
+3.407.920.33
+$3,407,920.33
+Your messages
+The interest, if any, charged to your account
+during December 2000 was computed on the net
+debit balance through December 28. The
+terest, if any, charged to your account durir
+anuary 2001 is computed from December 29. 2000
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Sorvices at Bear, Stoams Securities
+Corp.. One Metrolech Center North. Brooklyn. N.Y. 11201-3859.
+SIP The surren s four or ratanal purposes rear die Set revere date for portant iformation.
+02/24/01:22:22 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+027
+02/24/01:22:22 001
+
+
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+FIRM
+VISIT OUR WEBSITE
+www.bearstearns.com
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 30, 2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+December 29, 2000
+Important Message
+Decimal Trading is Coming!
+Decimal Trading is the shift from fractional pricing
+(e.g.,21 1/2) to decimal pricing (e.g.,$21.50)for
+equities and options.
+I trading on NYSE, AMEX, and regional exchange
+ill be in decimals effective as of 1/29/01
+For details, visit our website at www.bearstearns.com.
+INTERESTS
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Premise or Third Party Repurchase Agreements
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PURCHASE/
+REFURCHASE/
+PURCHASE FRICE/
+START DATE
+END DATE
+01/04/01
+OPEN
+PRINCIPAL
+3.379.771.53
+TOTAL REPURCHASE AGREEMENTS
+The at all pront dis do not appear in any other section of this statemen.
+PRICING
+RATE
+5.950000
+REPO! ACCRUED
+INTEREST"
+13,811.06
+NET AMOUNT
+3,393,582.59
+$3,393,582.59
+STOP
+****** End of Statement******
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four or ratanal furycer rear die Set revere date for portant formation.
+01/27/01:15:33 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+027
+01/27/01:15:33 001
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/bd8fb9db87717e86ced5387756f050fa50251e3af1455478105fc5fb6889d4a0.receipt.json b/vision-fixhub/ds9-unparsed-05/bd8fb9db87717e86ced5387756f050fa50251e3af1455478105fc5fb6889d4a0.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..07bafa10d6002d68d5206546055294fd285fc9b6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bd8fb9db87717e86ced5387756f050fa50251e3af1455478105fc5fb6889d4a0.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1602,
+  "dataset": "marble-joined",
+  "doc_id": "bd8fb9db87717e86ced5387756f050fa50251e3af1455478105fc5fb6889d4a0",
+  "engine": "marble-apple-vision",
+  "event_count": 15,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "2c1ea6895513966ecb79995a038241cd0fdcddcf1361f36faf5ba81b03f49ded",
+  "output_sha256": "a3dd244be250aaa6ac58fe7225fe4707f3981896060efb79024d85d900e3d1a6",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/be2d3be3d3170a23d4134b88cc52271ef5c1205be1bd4aba9c7994093e5e6f0d.md b/vision-fixhub/ds9-unparsed-05/be2d3be3d3170a23d4134b88cc52271ef5c1205be1bd4aba9c7994093e5e6f0d.md
new file mode 100644
index 0000000000000000000000000000000000000000..a3175ff01c187b69f17372795324210dbb866962
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/be2d3be3d3170a23d4134b88cc52271ef5c1205be1bd4aba9c7994093e5e6f0d.md
@@ -0,0 +1,32 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+West Palm Beach, FL 33401
+(561) 820-8711
+500 South Australian Ave., Suite 400
+Facsimile: (561) 820-8777
+March 27, 2007
+DELIVERY BY FACSIMILE
+Michael E. Dutko, Esq.
+Bogenschutz & Dutko
+600 S. Andrews Ave, Suite 500
+Fort Lauderdale, FL 33301-2802
+Re
+Dear Mr. Dutko:
+Thas informed me that you spoke yesterday and agreed that Ms.
+can
+be interviewed by agents and myself. I have attached a revised proffer letter for your review. L
+have included the proposed interview date of April 2, 2007, but I also am available to attend the
+interview on April 3rd and 4th. If possible, we would like to meet at the U.S. Attorney's Office
+here in West Palm Beach
+I will be out of the District the remainder of the week, but please contact FBI Special
+Agent
+to schedule the date and location of the interview. If
+you have any questions or concerns about the proffer letter, you can reach me on my cell phone at
+Sincerely,
+R. Alexander Acosta
+United States Attorney
+By:
+Assistant United States Attorney
+Enclosure
+CC:
diff --git a/vision-fixhub/ds9-unparsed-05/be2d3be3d3170a23d4134b88cc52271ef5c1205be1bd4aba9c7994093e5e6f0d.receipt.json b/vision-fixhub/ds9-unparsed-05/be2d3be3d3170a23d4134b88cc52271ef5c1205be1bd4aba9c7994093e5e6f0d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..29bc2e35413b56a6fcbc9d950b7203665660cf5d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/be2d3be3d3170a23d4134b88cc52271ef5c1205be1bd4aba9c7994093e5e6f0d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "be2d3be3d3170a23d4134b88cc52271ef5c1205be1bd4aba9c7994093e5e6f0d",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "c65831942c8086607a468f41f792e551885842c5156d2ea4f9fbe34e75ac7b05",
+  "output_sha256": "3c9ae6efad81a22f9a5ab61817dfbbcbfd079e04a0de92d71c8a3affb2ff226d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/be65ae928b9c084fbb29447c7e6a7c3d0a2ddbf93b18d4171450801bf4021584.md b/vision-fixhub/ds9-unparsed-05/be65ae928b9c084fbb29447c7e6a7c3d0a2ddbf93b18d4171450801bf4021584.md
new file mode 100644
index 0000000000000000000000000000000000000000..d5885da881bad9fde6843e5e212256c3645e4ccb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/be65ae928b9c084fbb29447c7e6a7c3d0a2ddbf93b18d4171450801bf4021584.md
@@ -0,0 +1,1048 @@
+NO.
+NAME Operation Leap Year
+
+
+87
+RIMINAL COMPLAINT
+USAO NUMBER 2006R0 1|81
+COURT DOCKET NO.
+DJ FILE NO.
+E CONTENTS OF THIS FILE ARE SUBJECT TO THE PROVISIONS OF THE PRIVACY ACT (5 U.S.C. 552a).
+United States Attorney
+SOUTHERN
+IVISION
+FENDANTS:
+OPERATION LEAP YEAR
+District of FLORIDA
+& Northern Crim. 1
+- COUNTY PALM BEACH
+ASSIGNED TO
+NATURE OF OFFENSE Internet solicitation;
+interstate travel to have sex
+with a minor
+FENSE COUNSEL:
+CODE SECTIONS 18 USC 2422, 2423
+DATE OF OFFENSE
+GOVT. AGENCY FBI
+STAT. OF LIMITATIONS
+BOND (AMOUNT, DATE AND SURETY)
+RAIGNMENT
+E ALSO FILE NO..
+REST
+DATE
+CODE
+PLEA
+INDICT BY
+INDICTMENT.
+REMARKS
+_TRIAL.
+INITIALS
+
+
+GCO 1
+Case Name:
+U.S. | OPERATION LEAP YEAR_
+Matter #:
+USAO#:
+18 U.S.C. § 208 is a criminal conflict of interest statute that prohibits me from
+participating personally and substantially in an official capacity in any particular
+matter in which I have a financial interest or in which certain persons or
+organizations whose interests are imputed to me have a financial interest if the
+particular matter will have a direct and predictable effect on that interest. This
+statute is in addition to any state bar professional conduct rules that may apply.
+I understand that personal and substantial participation may encompass
+activities ranging from merely advising on strategy to signing pleadings or
+trying a case.
+I understand that a particular matter includes both specific party matters,
+as well as more general matters that focus on an identifiable group (e.g., a
+policy determination that more resources will be spent pursuing
+institutions | individuals committing health care fraud).
+I understand that financial interest is the potential for gain or loss as a
+result of governmental action and that such interests typically arise
+through ownership of stocks or sectored mutual funds, outside
+activities/employment, and spousal employment.
+I understand that those interests imputed to me include those of my
+spouses minor hideo, eneral, general any organization in which any
+person or organization with whom I am negotiating for or have any
+arrangement concerning prospective employment.
+I understand that a direct and predictable effect occurs when there is a
+close causal relationship between the matter and my financial interest or
+the financial interest held by someone whose interests are imputed to me.
+The effect may be positive or negative. The magnitude of the gain or loss
+is immaterial.
+I certify that, to the best of my knowledge, this matter will not directly and
+predictably affect my financial interests or those interests imputed to me and my
+participation in this matter With not
+iolate 18 U.S.C. § 208.
+15/23/06
+(Printed Name)
+If you cannot certify to the above statement, do not take any action on the case
+and immediately contact your supervisor or vour Ethics Advisor:
+
+member of my household or in which someone with whom I have a covered
+relationship is or represents a party.
+I understand that I have a covered relationship with the following:
+anyone with whom I have or seek a business, contractual, or financial relationship;
+a relative with whom I have a close personal relationship;
+anyone for whom my spouse, parent or dependent child serves or seeks to serve as
+an officer, director, trustee, general partner, agent, attorney, consultant, contractor,
+or employee;
+anyone for whom I worked in the last year as an officer, director, trustee, general
+partner, agent, attorney, consultant, contractor, or employee; and
+an organization in which I am an active member.
+I certify that, to the best of my knowledge, this matter is not likely to affect the
+financial interest of a member of my household, and no one with whom I have a
+covered relationship is or represents a party in this matter. Therefore, my
+parficifiation will not
+violate 5 C.F.R. 82635.502.
+1s/23/06
+(Printed Name)
+If vou cannot certify to the above statement, do not take any action on the case
+and immediately contact vour supervisor or vour Ethics Advisor.
+I acknowledge my ongoing responsibility to be aware of the potential for conflict
+or the appearance of a conflict and to disclose any financial or personal interest as
+Javolved in or be affected by the matter as
+105/23/06
+(Printed Name)
+
+
+U.S. ATTORNEY'S OFFICE
+SOUTHERN DISTRICT OF FLORIDA
+CRIMINAL MATTER/CASE INITIATION FORM
+MAG NO.
+RELATED CASE NO.
+USAOID
+COURT NO.
+PARTICIPANTS:
+1. OPERATION LEAP YEAR
+D.
+SUMMARY OF FACTS: Internet Solicitation - Interstate travel to have sex with a minor.
+PRIMARY CHARGE: 18 USC 2422(b), 2423(b)
+OFFENSE DATE FROM
+EST FINANCIAL MAGNITUDE:
+DATE TO
+PRIORITY: (Check one)
+National Priority Only -
+= District Priority Only - Both atonana Dot is ret tority
+AGENCY INFORMATION:
+Who is the investigating agency?
+Agency Name:
+FBI
+Agency File Number:
+Agent Name and Telephone Number:
+S/A
+Second Agency Name:
+Second Agency's File Number:
+Second Agency's Agent Name and Telephone Number:
+CHECK ALL THAT APPLY:
+This case involves TRIGGERLOCK Defendants)
+Olense discovered as results of (NICS) Brady
+Yes
+This case involves Victims)
+_ Non Government Witnesses
+_No
+- or both.
+Forfeiture of Assets may be involved.
+_OCDETF Case
+Operation Name:
+OCDETF Number: EC/FLS/
+- Special targets or subjects are involved:
+Attorneys
+Police Officers
+_ Public Officials
+_ Civil Servants
+Members of the Medical Profession
+- Resist. Cats the case is shed to tDo antonion be rega, include all
+Tax, Environmental, FDA and Civil Rights Cases)
+DOJ Division:
+DOJ File or Tax Division Number:
+DOJ Attorney and Telephone Number:
+REVIEWED FOR ACCURACY & COMPLETENESS; ACCEPTED FOR CASE INITIATION
+ASSIGNED TO: AUSA
+cell
+SUPERVISORY AUSA SIGNATURE:
+_DATE_
+5/31/06
+USAO 001(01CRM07a) REV.(08/12/02)
+
+
+PROGRAM CATEGORY (Check ALL categories that apply)
+(priorities are listed in parentheses)
+OFFICIAL CORRUPTION
+Fed. Corruption-Procurement (N-ALL)
+(011)
+Fed. Corruption-Program (N-ALL)
+Fed. Corruption-Law Enforcement (N-ALL)
+(012)
+(013)
+Fed. Corruption-Other (N-ALL)
+State Corruption (N-High Officials)
+(014)
+(015)
+Local Corruption (N-High Officials)
+(016]
+Other Official Corruption
+(012)
+ORGANIZED CRIME
+Organized Crime-Traditional
+(020)
+Organized Crime-Emerging Organizations
+(021)
+WHITE COLOR CRIME/FRAUD
+Fed. Procurement Fraud (N-$25,000 +)
+(031)
+Fed. Program Fraud (N-$25,000 +]
+(032)
+Tax Fraud (N-DOJ Tax Authorized)
+(033)
+OFinancial Institution Fraud
+Bankruptcy Fraud (N-$100,000 +)
+(036)
+(037)
+Advance Fee Schemes (N-$1000,000 + 10 or more victims)
+Other Fraud Against Business (Credit Card) Fraud
+(038)
+(039)
+Consumer Fraud (N-$100,000 + or 25 or more victims)
+(03A)
+Securities Fraud (N-$100,000 +)
+(03B)
+Commodities Fraud (N-$100,000 +)
+(03C)
+Other Investment Fraud (N-$100,000 +)
+(03D)
+Computer Fraud (N-ALL)
+(03F)
+Health Care Fraud (N-$25,000 + or bribes)
+(03G)
+Fraud Against Insurance Providers (N-$100K +/Arson-$250K +) (03H)
+Telemarketing Fraud
+(038)
+Insider Fraud Against Insurance Providers (N-ALL)
+MEWA/MET (Multiple Employer Welfare Arrangements and
+(03J)
+(03K)
+Multiple Employer Trust Fraud (N-$100,000 +)
+Antitrust Violations-Airlines
+Antitrust Violations-Banking
+Antitrust Violations-Defense Procurement
+Antitrust Violations-Extraterritorial Application
+Antitrust Violations-Financial Markets other than banking
+Antitruat Violations-Other (if no specific code applies]
+Other White-Collar Crime/Fraud
+(03M)
+(03N)
+(03P)
+(030)
+(03R)
+(03E)
+(03Z)
+DRUGS
+Drug Dealing (N-CCE; RICO; DEA Class I violator;
+(040)
+movement of $100,000 +; level 38 drug amounts;
+large criminal drug trafficking organization)
+-
+Simple Drug Possession (21:00844 onlv)
+OCDETF (N-ALL)
+CIVIL RIGHTS
+Other (If no specific code applies)
+Law Enforcement
+Slavery/Involuntary Servitude
+Racial Violence
+Access to Clinic Entrances (18 U.S.C §248)
+Hate Crimes Sep 11, 2001 Terrorist Attacks on the U.S.
+OPERATION TRIGGERLOCK
+Firearms cases
+— Firearms cases (Brady Violation)
+(045)
+(047)
+(050)
+(0SD)
+(05E)
+(05F)
+(05G)
+(05H)
+(053)
+(054)
+18 U.S.C. 922(a)(6), 924(a)(1)(A), 1001
+IMMIGRATION
+Immigration & Nationality Act
+CRIMES AGAINST GOVERNMENT PROPERTY
+(055)
+DOMESTIC VIOLENCE
+Crimes Against Government Property
+(056)
+GOVERNMENT REGULATORY OFFENSES
+. Counterfeiting and forgery of U.S. Government Currency
+or Securities (N-ALL
+Customs-Duty (N-$25,000/one or $500,000 more than one
+(061)
+(062)
+Customs-Currency
+(N-$25,000/one or $50,000/more than one)
+Energy Pricing & Related Fraud (N-$500,000 or illegal pricing]
+Health & Safety-Employees (N-life endangering)
+Copyright Violations (N-$500,000 + and three or more states
+Trafficking in Contraband Cigarettes (N-$100,000*)
+Wildlife Protection
+Marine Resources
+Energy Violations
+Environmental Crime
+Money Laundering/Structuring (Narcotica)
+Money Laundering/Structuring (Other)
+Other Government Regulatory Offenses
+INDIAN OFFENSES
+United States had jurisdiction
+INTERNAL SECURITY OFFENSE
+Internal Security
+ANTI-TERRORISM
+International Terrorism
+Domestic Terroriam (N-ALL)
+Terrorism Related Hoaxes
+Terrorist Financing
+OCDETF - Anti-Terrorism/ Environment
+OCDETF - Anti-Terrorism/Identity Theft
+OCDETF - Anti-Terrorism/Immigration
+OCDETF - Anti-Terrorism/OCDETF Drugs
+OCDETF - Anti-Terrorism/Non-OCDETF Drugs
+OCDETF - Anti-Terrorism/Violent Crime
+OCDETF - Anti-Terrorism/All Others
+OFFENSES INVOLVING THE ADMINISTRATION OF JUSTICE
+Offenses Involving the Administration of Justice
+ITSP - 18 U.S.C. 659, 2117, 2314, etc....
+LABOR MANAGEMENT OFFENSE
+- (N-$25,000)
+Union Official Corruption-Pension, Benefit Funds.
+Union Official Corruption-Bribery, Kickbacks (N=$5,000+)
+Other Labor/Management Offenses
+FUGITIVE CRIMES
+Escape, Failure to Appear, Bond Jump
+POSTAL SERVICE CRIMES
+18 U.S.C. 1708, 1709, 495, 510, etc.....
+18 U.S.C. 0007(3), 0013, etc....
+ELECTION FRAUD
+18 U.S.C. 371, 911, 1341-1343
+MOTOR VEHICLE CRIMES
+PORNOGRAPHY/OBSCENITY
+18 U.S.C. 2251-2256 (Child Protection Act of 1984)
+18 U.S.C. 1461-1465 (Obscenity)
+THEFT OF GOVERNMENT PROPERTY
+U.S.C. 641, ete... Excluding white collar under 031-03Z
+18 U.S.C. 1461, 1465 or U.S.C. 223
+OTHER CRIMINAL PROSECUTIONS
+All Others Not Covered Above
+DOMESTIC VIOLENCE
+- 18 U.S.C. 2261-2262; 922(g/8), 922(g)(9)
+REGION/DIVISION/SECTION CODES
+SOUTHERN REGION
+ECS
+ECONOMIC CRIMES SECTION
+ENS
+ENVIRONMENTAL CRIMES SECTION
+NAH HIDTA
+CENTRAL REGION
+— CCI CENTRAL CRIMINAL ONE
+-
+CC2 CENTRAL CRIMINAL TWO
+• OCS ORGANIZED CRIME
+NORTHERN REGION
+PCS
+PUBLIC CORRUPTION SECTION
+SMP
+MAJOR PROSECUTIONS SECTION
+SNS
+NARCOTICS SECTION
+CRD
+CIVIL RIGHTS SECTION
+EXE EXECUTIVE DIVISION
+N: (EVasquez| Villafaña, A. Marie - Cases \Operation Leap Year|CASE INITIATION FORMS|Criminal Matter-Case Initiation Form, wpd
+(063)
+(064)
+(066)
+(069)
+(06A)
+(06B)
+(06C
+(06D)
+(06E)
+(06F)
+(06G)
+(06Z)
+(065)
+(070)
+(071)
+(072)
+(073)
+(076)
+(07A)
+(07B)
+(07C)
+(07D)
+(07E)
+(07F)
+(070)
+(074)
+(075)
+(08A)
+(08B)
+(08C)
+(OBZ)
+(081)
+(082)
+(083)
+(084)
+(085)
+(086)
+(087)
+(087)
+(085)
+(089)
+
+
+*********************
+TX REPORT
+***************
+TRANSMISSION OK
+TX/RX NO
+CONNECTION TEL
+SUBADDRESS
+CONNECTION ID
+ST. TIME
+USAGE T
+PGS. SENT
+RESULT
+1699
+
+06/01 17:09
+OK
+United States Attorney's Office
+Southern District of Florida
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401-6235
+DATE: June 1, 2006
+TO:
+FAX#:
+Docketing
+ORGANIZATION: USAO/Ft. Lauderdale
+SUBJECT: In the Matter of: Operation Leap Year
+FROM:
+Legal Assistant
+, Extension 3032
+(Fax)
+NUMBER OF PAGES, INCLUDING THIS PAGE: 4
+COMMENTS: Please see attached case that needs a USAO/LIONS #.
+If you have any questions or concerns, please feel free to contact me.
+Thanks!
+
+
+United States Attorney's Office
+Southern District of Florida
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401-6235
+DATE: June 1, 2006
+TO:
+Docketing
+ORGANIZATION: USAO/Ft. Lauderdale
+FAX#:
+SUBJECT: In the Matter of: Operation Leap Year
+FROM:
+Legal Assistant
+, Extension 3032
+(Fax)
+NUMBER OF PAGES, INCLUDING THIS PAGE: 4
+COMMENTS: Please see attached case that needs a USAO/LIONS #.
+If you have any questions or concerns, please feel free to contact me.
+Thanks!
+Original document:
+To follow via regular mail
+To follow via Federal Express
+o tollow via interagency mai
+o follow via hand deliver
+To follow via email
+X_ Nothing to follow, FAX = original
+10.205.6!,K3/
+
+
+EXPERT WITNESS FORMS
+
+
+COCEIVED
+Request, Authorization and Contract for Services
+Expert Witness, Litigative Consult AYr f95 06ytral
+Contract/Purchase Order No.: 7L-USA-04-0207
+2/0
+DRACUDEMENE
+5. Preparer (Name & Tel.)
+Part I - Request for Services
+2. Sinnature of Requesting Official
+3. Point of Contact (Name and Tel.)
+4. Date of Request
+10/26/2006
+6. Originating Office (Name & Address)
+7. Case Name, Court & Ct. Docket No. | 8. DJ File No./USAO No.
+USAO WPB
+Operation Leap Year
+500 S. Australian Ave, Suite 400
+West Palm Reach. FI 33401
+10. Contractor Mailing Address
+11. Contractor TIN or SSN (individual)
+9. Contractor (Name and Tel.)
+Anna Salter, Ph.D.
+12. Contractor Specialty
+Licensed Psychologist
+NRHCP
+Telephone:
+13. Reason for Request (Place an "X" in the applicable Box in the Left Column)
+13.a. Expert Testimony on Behalf of U.S.
+13.b. Deposition Conducted by DOJ Attorney
+13.c. Medical Examination of Plaintiff/Witness/Defendant in Contemplation of Testimony on Behalf of U.S.
+13.d. Examination Under 18 USC 4241, Mental Competency to Stand Trial Only
+13.e. Dual Purpose Psychiatric Examination (Time of Offense and Competency ib Stand Trial) on the motion of:
+13.f. ADR Neutral Services
+13.g. Litigative Consultant Services
+13.h. Other (explain below):
+Attach the Statement of Work to this Form
+14. Negotiated Contractor Rates, Estimated Expenses, and Performance Dates (Note: Expenses incurred must be supported by receipts)
+Service/Expense
+Performance Dates (From-To) HourDay Quanty Rete rotar
+14.a. Examine Case
+$0.00
+14.b. Prepare Testimony
+$0.00
+14.c. Court Testimony
+$0.00
+14.d. Deposition
+$0.00
+14.e. Litigative Consultant/Neutral
+05/07/07 - 06/29/07
+HOUR
+6.00
+250.00
+$1,500.00
+14.f. Per Diem (if not part of fee)
+Day
+$0.00
+14.g. Privately Owned Vehicle (NTE coach rate)
+Mile
+$0.00
+14.h. Common Carrier Transportation Via GTA
+14.i. Common Carrier Transportation Reimbursed
+14.j. Miscellaneous
+14.k. Total Estimated Expenses
+$1,500.00
+15. Submit Invoices & EFT Information to:
+16. Payment will be made by: (Place an 'X* in the applicable Box and fill-in if not JMD/Finance)
+Attn: Procurement Dept.
+JD.S. Department of Justice
+US Attorneys Office
+JMD/Fitsace Staff
+Miami, FL 33132]30S/3)
+99 NE 4th Streetsino 2415:4 Wasbington, DC 20520-0001
+95:01 MY E- AVN Lut
+03Л309d
+Form OBD-47 (Revised 3-2005)
+
+
+
+Contract/Purchase Order No.: 7L-USA-04-0207
+17.a. Authorized Amount
+1500,
+17.f. Remarks
+17.b. YREGDOC
+GO4 10111
+Part Il - Funding Approval
+17. Appropriation Data
+17.c. Cost Center
+0E4004
+17.d. OBL Month
+0705
+17.e. Sub Object Code (SOC)
+1127
+PROG, OTM
+Note: The FEW Appropriation (15X0311) shall ONLY be used to fund Witness Services (i.e., items 13.a through 13.e above)
+18. Funding Amount (Place an "X in the applicable Box in the Left Column and fill-in the Amount and Performance Period)
+18.b. Amount
+18.c. Period (From - To)
+X
+19.a
+18.a. Fully Funded
+This Contract is FULLY FUNDED in the amount specified in Block 18.b to cover the
+estimated costs of the ENTIRE project whose performance period is specified in Block
+18.c. This amount shall NOT be exceeded without authorization and written modification
+#1500.00
+of this contract by the Contracting Officer.
+18.d. Incrementally Funded
+18.e. Amount
+This Contract is INCREMENTALLY FUNDED: The total estimated cost of the project is
+specified in Block 14.k. Currently, funding is provided only in the amount specified in
+Block 18.e to cover estimated costs incurred during the performance perlod specified in
+Block 18.f. The amount specified in Block 18.e shall NOT be exceeded without
+authorization and written modification of this contract by the Contracting Officer.
+Reminder: Witnesses are not entitled to Advance Payments.
+19. Funding Approval
+19.b. Name & Title of Approving Official
+5/07-6107
+18.f. Period (From - To)
+19.c. Date Approved
+5/4/07
+Part I!! - Contract
+This contract consists of the documents listed below. In the event of any inconsistency among the following documents, such inconsistency shall be
+resolved in the order in which said documents are listed.
+(1)
+OBD Form 47, Request, Authorization and Contract for Services of Expert Witness, Litigative Consultant, or ADR Neutral, consisting of 2
+pages.
+(2)
+Attachment 1, Contract Terms, Conditions, and Procedures, consisting of 3 pages.
+(3)
+Attachment 2, Statement of Work.
+(4)
+The Contractor's proposal, incorporated herein by reference.
+By signing this document, the Contractor agrees to perform services as described herein in accordance with the terms, conditions, and rates set forth in
+this contract.
+The contractor ale cal en paye or we prout lied by the otiador, alary in the background of is employees that could impus
+This coniract chall not becomo offeelive untilsigned by en authorized representative of the Contractor AND the Contracting Officer.
+20. Contractor Signature
+20.a. Signature of Authorized Person
+20.b. Name and Title of Signer
+Anna @ Balter Ph. D
+20.c. Date Signed
+6/18/07
+21. Contracting Officer Signature
+21.a. Signature of Contracting Officer
+21.b. Name of Contracting Officer
+21.c. Date Signed
+5/4/07
+Form OBD-47 (Revised 3-2005).
+
+
+
+Contract/Purchase Order Number: 7L-USA-04-0207
+A.1
+A.2
+Attachment 1- Contract Terms, Conditions and Procedures
+A. General Contract Terms and Conditions
+Inspection and Acceptance. Inspection and acceptance will be at destination, unless otherwise provided. Until delivery and acceptance,
+and after any rejection, risk of loss will be on the Contractor unless loss results from negligence of the Government.
+Invoice Requirements. After services are rendered, the Contractor shall prepare an invoice and submit it to the individual identified in
+Block 15 of this Contract (page 1 of Form OBD-47). To constitute a proper invoice, the invoice must contain the following information: (i)
+The name and Taxpayer Identification Number (TIN) of the business entity or individual (if an individual has no TIN, the Social Security
+Number may be used): (i) The date of the invoice; (ili) A description, itemization, and price for all services rendered and miscellaneous
+expenses incurred; (iv) The date or the period of time over which the services were rendered; and (I) The name, telephone number, and
+complete mailing address of the responsible official to whom payment is sent.
+A.3
+A.4
+A.5
+A.6
+A.7
+The invoice must also be accompanied by any travel receipts or receipts for miscellaneous expenses to substantiate the invoice amount.
+The Government case attorney will certify on the invoice that the services were received and the date the services were accepted. The
+Government case attorney will then forward the approved invoice and Form OBD-47 to the appropriate person within the litigating office for
+further processing.
+Payment by Electronic Funds Transfer. The Government reserves the right to make payments to the Contractor via Electronic Funds
+Transfer (EFT) in accordance with FAR clause 52.232-34, incorporated by reference into this Contract. If payment is to be made via EFT,
+the Contractor shall prepare Part I of Form OBD-47A. The form shail be completed by the Contractor and submitted to the address
+shown in Block 15 of this Contract (page 1 of Form OBD-47).
+Interest on Overdue Payments. (i) The Prompt Payment Act, Public Law 99-177 (96 Stat. 85, 31 U.S.C. 1801, as amended) is
+applicable to payments under this Contract and requires the payment of interest on overdue payments and improperly taken discounts; (i)
+Determination of interest due will be made in accordance with the Provisions of the Prompt Payment Act.
+Payment Inquiries. All follow-up invoices shall be marked "Duplicate of Original." Contractor questions regarding payment information or
+check identification should be directed to the Department of Justice Vendor Assistance Hotline
+Use of Taxpayer Identification Number. In accordance with the requirements of the Debt Collection Act of 1996, Public Law 104-134, it
+is the intent of the Department of Justice to use your Taxpayer Identification Number for purposes of collecting and reporting on any
+delinquent amounts arising out of your relationship with the Government.
+Contractor's Proposal. The Contractor' proposal to furnish the services under this Contract is hereby incorporated by reference into this
+Contract. In the event of any inconsistency between the Contractor's proposal and this Contract, this Contract shall be considered a
+superseding document.
+B. Federal Acquisition Regulation Clauses Incorporated by Reference
+This Contract incorporates the following Federal Acquisition Regulation (FAR) clauses by reference, with the same force and effect as if the clauses
+were given in full text. Upon request, the litigating component's administrative or procurement office will make the full text available. Also, the full text
+may be accessed electronically at the following Internet address: http://www.amet.gov/far/. The effective date of each FAR clause listed below is that
+which is current at the time this Contract is executed by both parties.
+B.1 The following FAR clauses apply to all contracts (the FAR clause number is in the left column and clause title in the right)
+52.225-13
+Restrictions on Certain Foreign Purchases
+52.232-7
+Payments under Time-and-Materials and Labor-Hour Contracts
+52.232-25
+Prompt Payment
+52.232-34
+Payment by Electronic Funds Transfer - Other than Central Contractor Registration
+52.233-4
+Applicable Law for Breach of Contract
+52.243-3
+Changes - Time-and-Materials or Labor-Hours
+52.246-6
+Inspection - Time-and-Material or Labor-Hour
+52.249-6
+Termination (Cost Reimbursement), Alternate IV
+B.2 The following FAR clause is added to the clauses in Block 18.a for those contracts valued at $100,000 or less
+52.213-4 Terms and Conditions - Simplified Acquisitions (other than Commercial items)
+B.3 The following FAR clauses are added to the clauses in Blocks B.1 and B.2 for those contracts valued at more than $100,000
+52.202-1
+Definitions
+52.203-3
+Gratuities
+52.203-5
+Covenant Against Contingent Fees
+52.203-6
+Restrictions on Subcontractor Sales to the Government
+
+
+
+Contract/Purchase Order Number: 7L-USA-04-0207
+52.203-7
+52.203-8
+52.203-10
+52.203-12
+52.204-4
+52.209-6
+52.215-2
+52.219-8
+52.222-3
+52.222-21
+52.222-26
+52.222-35
+52.222-36
+52.222-37
+52.223-6
+52.227-1
+52.227-2
+52.232-8
+52.232-17
+52.232-23
+52.233-1
+52.233-3
+52.237-2
+52.242-13
+52.244-2
+52.244-5
+52.247-63
+Anti-Kickback Procedures
+Cancellation, Recision, and Recovery of Funds for lilegal or Improper Activity
+Price or Fee Adjustment for Illegal or Improper Activity
+Limitations on Payments to Influence Certain Federal Transactions
+Printing/Copying Double-Sided on Recycled Paper
+Protecting the Government's Interest when Subcontracting with Contractor's Debarred, Suspended, or Proposed for Debarment
+Audit and Records-Negotiation
+Utilization of Small Business Concers
+Convict Labor
+Prohibition of Segregated Facilities
+Equal Opportunity
+Affirmative Action for Disabled and Veterans of the Vietnam Era
+Affirmative Action for Workers with Disabilities
+Employment Reports on Special Disabled Veterans, Veterans of the Vietnam Era and other Eligible Veterans
+Drug-Free Workplace
+Authorization and Consent
+Notice and Assistance Regarding Patent and Copyright Infringement
+Discounts for Prompt Payment
+Interest
+Assignment of Claims
+Disputes
+Protest After Award
+Protection of Goverment Buildings, Equipment, and Vegitation
+Bankruptcy
+Subcontracts
+Competition in Subcontracting
+Preference for U.S. Flag Air Carriers
+C. Other Full Text Clauses
+This Contract incorporates one of the following two clauses (C.1 or C.2) depending upon whether the Contract is FULLY FUNDED or INCREMENTALLY
+FUNDED, as specified in Part II, Block 18 of this Contract (Form OBD-47). This contract also incorporates Clause C.3 which describes required
+Contractor residency requirements.
+C.1 Limitation of Cost
+NOTE: This clause applies to FULLY FUNDED contracts.
+(7)
+The parties to this Contract estimate that performance of this Contract will not cost the Government more than the estimated cost specified
+elsewhere in this Contract. The Contractor agrees to use its best efforts to perform the work within the estimated cost specified in the
+Contract.
+(2)
+The Contractor shall notify the Contracting Officer whenever it has reason to belleve that - (1) the costs the Contractor expects to incur unde
+his Contract in the next 30 days, when added to all costs previously incurred, will exceed 75 percent of the estimated cost specified in th
+Contract; or (2) the total cost for the performance of this Contract will be either greater or substantially less than had been previously
+As part of the notification, the Contractor shall provide the Contracting Officer a revised estimate of the total cost of performing this Contract.
+(3)
+(4)
+(5)
+he Government is not obligated to reimburse the Contractor for any costs in excess of the estimated cost to the Goverment specified in th
+ontract, whether those costs were incurred during the course of the Contract or as a result of terminatio
+
+
+
+Contract/Purchase Order Number: 7L-USA-04-0207
+(6)
+If the estimated cost specified in the Contract is increased, any costs the Contractor incurs before the increase that are in excess of the
+previously estimated cost shall be allowable to the same extent as if incurred afterward, unless the Contracting Officer issues a termination or
+other notice directing that the increase is solely to cover termination or other specified expenses.
+(7)
+this Contract is terminated or the estimated cost is not increased, the Government and the Contractor shall negotiate an equitabl
+istribution of all property produced or purchased under the Contract, based upon the share of costs incurred by eact
+C.2 Limitation of Funds
+NOTE: This clause applies to INCREMENTALLY FUNDED contracts.
+(1)
+The parties to this Contract estimate that performance of this Contract will not cost the Government more than the estimated cost specified on
+Page 2, Part I! of this Contract (Form OBD-47) hereof. The Contractor agrees to use its best efforts to perform the work specified in the
+(2)
+(3)
+Page 2 of the Contract (Form OBD-47) specifies the amount presently available for payment by the Government and allotted to this Contract
+and the period of performance it is estimated the allotted amount will cover. The parties contemplate that the Government will allot additional
+funds incrementally to the Contract up to the full estimated cost to the Government specified in the Contract. The Contractor agrees to
+perform, or have performed, work on the Contract up to the point at which the total amount paid and payable by the Government under the
+Contract approximates but does not exceed the total amount actually allotted by the Government to the Contract.
+The Contractor shall notify the Contracting Officer whenever it has reason to believe that the costs it expects to incur under this Contract in the
+next 30 days, when added to all costs previously incurred, will exceed 75 percent of the total amount so far allotted to the Contract by the
+Government. The notice shall state the estimated amount of additional funds required to continue performance for the period specified in the
+(4)
+(5)
+(6)
+(7)
+Thirty (30) days before the end of the period specified on Page 2 of this Contract (Form OBD-47), the Contractor shall notify the Contracting
+Officer in writing of the estimated amount of additional funds, if any, required to continue timely performance under the Contract or for any
+further period specified in the Contract and when the funds will be required.
+If, after notification, additional funds are not allotted by the end of the period specified on Page 2 of this Contract or another agreed-upon date,
+upon the Contractor's written request, the Contracting Officer will terminate this Contract on that date in accordance with the provisions of the
+Termination clause of this Contract. If the Contractor estimates that the funds available will allow it to continue to discharge its obligations
+beyond that date, it may specify a later date in its request, and the Contracting Officer may terminate this Contract on that later date.
+Except as required by other provisions of this Contract - (1) the Government is not obligated to reimburse the Contractor for costs incurred in
+excess of the total amount allotted by the Government to this Contract; and (2) the Contractor is not obligated to continue performance under
+this Contract (including actions under the Termination clause of this Contract) or otherwise incur costs in excess of the amount then allotted to
+the Contract by the Government until the Contracting Officer notifies the Contractor in writing that the amount allotted by the Government has
+been increased and specifies an increased amount, which shall then constitute the total amount allotted by the Goverment to this Contract.
+The estimated cost shall be increased to the extent that the amount allotted by the Government exceeds the estimated cost specified in the
+(B)
+(9)
+Nothing in this clause shall affect the right of the Government to terminate this Contract. If this Contract is terminated, the Government and
+the Contractor shall negotiate an equitable distribution of all property produced or purchased under the Contract, based upon the share of
+costs incurred by each.
+If the Government does not allot sufficient funds to allow completion of the work, the Contractor is entitled to a percentage of the fee specified
+in the Contract equaling the percentage of completion of the work contemplated by this Contract.
+C.3 Contractor Employee Residency Requirement
+All contractor employees assigned to this contract and working within the United States shall meet the DOJ Residency Requirement. The Residency
+Requirement states that, for three of the five years immediately prior to applying for a position, the individual must have: 1) resided in the United States;
+2) worked for the United States overseas in a Federal or military capacity; or 3) be a dependent of a Federal or military employee serving overseas.
+This requirement can be waived for short-term (i.e., those employees performing duties for a cumulative total of 14 days or less) if there is a critical need
+for their specialized or unique skills (for example, interpreters for rare foreign languages). These individuals must be United States citizens or
+Permanent Resident Aliens. A waiver request from the head of the Component outlining the extenuating circumstances along with the requisite
+contractor clearance package shall be submitted through the Contracting Officer's Technical Representative (COTR) to the Department Security Officer
+(DSO) for approval. Each waiver request will be reviewed by the DSO and a determination made on a case-by-case basis.
+Additionally, a contractor employee who is not a U.S. citizen must be from a country allied with the United States. Since the countries on the Allied
+Countries List are subject to change, the head of the Component shall review the following website for current information:
+http://www.opm.gov/employ/html/Citizen.htm.
+
+
+
+Request, Authorization and Contract
+for Services of Litigative Consultant
+Operation Leap Year, 2006R01181
+Contract No. 7L-USA-04-0207
+Attachment 2
+Litigative Consultant Statement of Work
+The United States Attorneys' Office (USAO) conducts litigation in the Southern District of
+Florida on behalf of the United States of America. Frequently, there is a need for litigative
+consultant work prior to a case going to trial and during the trial. When appropriate, and pursuant
+to guidelines implemented by the Department of Justice, a USAO may enter into agreements with
+litigative consultants, functioning as independent contractors, to conduct record reviews and data
+analyses by written report. In this particular case, the USAO has determined that a litigative
+consultant is in litigation for the government and such services are not available from the agency
+being represented or from another agency.
+Through this statement of work, the USAO is seeking the services of a contractor to review
+records, analyze data, interview witnesses, and other work pertinent to the case.
+Summary of Case
+This case involves the solicitation of more than 12 minors to engage in prostitution and
+interstate travel to engage in sexual activity with minors. The case currently is under investigation.
+Four (4) targets have been identified to date.
+Retention
+Dr. Anna Salter is needed to serve as a consultant prior to indictment regarding the
+psychological traits of the defendant, obstacles in interviewing victims of sexual exploitation, and
+the effects of sexual abuse on victims.
+Dr. Anna Salter will be available to commence work for the USAO upon receipt of an
+executed copy of this Agreement or a verbal notice to proceed. Dr. Anna Salter agrees not to work
+for any other person or party involved in this case on matters relating to this case for thirty (30) days
+after she is verbally retained, or upon acceptance of this Agreement, unless notified earlier by the
+USAO. Should the thirty (30) days lapse without receipt of an executed agreement or notice to
+proceed, Dr. Salter is free to accept work from any other party.
+
+
+Scope of Work
+Dr. Anna Salter shall provide all plant, labor, material and equipment except as otherwise
+provided to perform litigative consultant services as required by USAO and in connection with such
+services agrees to perform such document review, studies and research by written report as an
+litigative consultant with respect to Dr. Salter's findings.
+Dr. Anna Salter may assist the USAO in the obtaining of one or more additional consultants,
+as needed to support the contractor in person or by written report, who are competent and willing to
+render a scientifically-supportable opinion and sign an appropriate affidavit, acceptable to the
+consultant, prepared by the USAO, based upon the findings of the consultant and the facts of the
+Case.
+Dr. Anna Salter must exercise neutrality and maintain independence. Dir. Salter shall
+determine the manner in which the services are to be performed and the specific hours to be worked
+by Dr. Salter.
+Dr. Anna Salter will be of good professional standing and moral character, generally board
+eligible or board certified in the area of specialty or having other appropriate qualifications through
+training or experience; to act as the USAO's litigative consultant in the Case, the rendering of oral
+and written opinions, the signing of affidavits, and directly consulting with the USAO.
+The full scope of Dr. Salter's work will be determined as the matter proceeds, and will be
+subject to the needs and requests of USAO. Occasionally, the complexity of the case requires more
+review hours than initially estimated. Any time it becomes apparent to Dr. Salter that she will need
+to exceed the time and cost estimates provided to complete her work, she will provide USAO with
+a revised estimate and shall proceed only after being granted permission by USAO.
+
+
+Request, Authorization and Contract
+for Services of Litigative Consultant
+Contract No. 7L-USA-04-0207
+Addendum
+Attachment 2
+Litigative Consultant Statement of Work
+Relationship of the Parties
+Notwithstanding any provision hereof, for all purposes of this Agreement Dr. Anna Salter
+shall be and act as an independent Dr. Anna Salter and not an employee of the USAO, thereby
+incurring all expenses associated with the work, including any overhead and other direct costs not
+directly related to the performance of this engagement. The USAO will not provide fringe benefits,
+including health insurance benefits, paid vacations, or any other employee benefit, for Dr. Anna
+Salter. Dr. Anna Salter shall make no representation as an agent, employee, partner, or joint venturer
+of USAO. Dr. Anna Salter shall have no authority to bind nor attempt to bind USAO or incur other
+obligations on behalf of USAO. Dr. Anna Salter is an independent Dr. Anna Salter and is solely
+responsible for all taxes, withholdings, and other statutory or contractual obligations of any sort,
+including, but not limited to, Workers' Compensation Insurance; and Dr. Anna Salter agrees to
+defend, indemnify and hold USAO harmless from any and all claims, damages, liability, attorneys'
+fees and expenses on account of an alleged failure by Dr. Anna Salter to satisfy any such obligations
+or any other obligation (under this Agreement or otherwise). If Dr. Anna Salter is a corporation, it
+will ensure that its employees and agents are bound in writing to Dr. Anna Salter's obligations under
+this Agreement.
+Confidentiality
+Dr. Anna Salter recognizes that the USAO has and will have privileged law enforcement
+information, as well as non-privileged information obtained from federal agencies and employees,
+and other proprietary information (collectively "information" which are valuable, special and unique
+assets of the USAO. Dr. Anna Salter agrees that other than provided by law, will at no time or
+under any circumstances, directly, or indirectly, divulge, disclose, or communicate such information
+to a third party, or use it for its own benefit without the prior written permission from the USAO.
+Dr. Anna Salter may disclose such information to its employees and subDr. Anna Salters, who may
+be working on the case, in order to facilitate testimony to be provided by the litigative Dr. Anna
+Salter in person or by written report, unless notified to the contrary by the USAO. Dr. Anna Salter
+and its employees and subDr. Anna Salters, will protect the information and treat it as strictly
+confidential.
+
+
+In the performance of services under this contract, Dr. Anna Salter, its employees and/or its
+subDr. Anna Salters may be required to perform operations, have access to, or handle data which
+contain sensitive, proprietary, or privacy information or data such as, but not limited to, review or
+to an individuals' tax records or medical records (such as patient files or prescription records), or
+other materials containing individual tax or medical information (such as medical utilization reports
+from carriers, workers' compensation claim files, personnel files, or court records which include
+medical or tax reports). Dr. Anna Salter agrees that the following additional safeguards apply to
+such information:
+1) Dr. Anna Salter shall be responsible for safeguarding the information or data while under
+the control of or available to Dr. Anna Salter and to prevent it from being compromised,
+altered, damaged, lost, or improperly disseminated. Dr. Anna Salter shall use such
+information solely for purposes of the particular court case.
+2) Access to any such information or document should be strictly limited to persons with a
+legitimate and compelling need for that information, such as support staff needed to assist
+in the preparation of testimony in person or by written report. Dr. Anna Salter shall ensure
+that any such persons use such information solely or purposes of the particular court case and
+3) Dr. Anna Salter shall ensure that all records are maintained securely so that access is
+strictly limited.
+4) At the end of Dr. Anna Salter's engagement in this matter, all copies of such records shall
+be returned to the USAO.
+5) All questions about these safeguards and the records which they cover shall be directed
+to the AUSA.
+6) The confidentiality provisions of this Section hereof shall survive any termination of this
+Agreement.
+Conflict of Interest
+Dr. Anna Salter warrants that he is under no obligation to any other entity that in any way
+conflicts with this Agreement, that he is free to enter into this Agreement, and is under no obligation
+to consult for others in matters covered by this Agreement. Dr. Anna Salter shall not, during the term
+of this Agreement, perform consulting services for others in any related cases within the scope of
+this Agreement but shall have the right to perform consulting services for others outside the scope
+of this Agreement.
+If, for any reason, the USAO or Dr. Anna Salter determines that Dr. Anna Salter and/or an
+employee or subDr. Anna Salter of Dr. Anna Salter faces a potential, perceived, or real conflict of
+interest, the USAO shall notify Dr. Anna Salter or Dr. Anna Salter shall notify the USAO of the
+potential, perceived, or real conflict of interest and Dr. Anna Salter and/or contract employee or
+subDr. Anna Salter shall cease all work on or reassign the task or proceed at the discretion of the
+USAO. At the USAO's option, Dr. Anna Salter may provide an acceptable replacement.
+
+
+Government Liability
+The United States, its agents, agencies, departments, employees, and/or contracting officials
+shall not be liable for any injury to Dr. Anna Salter, its subDr. Anna Salters, agents, personnel, or
+damage to Dr. Anna Salter property unless the injury or damage is due to negligence on the USAO's
+part and may be recoverable under the Federal Tort Claims Act.
+Return of Records
+Upon termination of this Agreement, Dr. Anna Salter will deliver all records, notes, data or
+memorandum that was received from the USAO, and are in Dr. Anna Salters possession or under
+Dr. Anna Salter's control and are the USAO's property or relates to the USAO's business. Dr. Anna
+Salter may properly destroy this material upon permission of the USAO.
+
+
+Required Procurement and Payment Data for Contracts for Services
+of Expert Witness, Litigative Consultant, or ADR Neutral
+Contract/Purchase Order Number:
+7L-USA-04-0207
+Part 1- Procurement Data
+The Office of Federal Procurement Policy Act, as amended, 41 U.S.C. 401 et. seq., requires that the Government collect certain procurement data and
+then disseminate it to Congress, the Executive Branch, and the private sector. Prior to award of this Contract, the Contractor shall provide information
+responsive to the below data request. Data from this section will be entered by the Government into the Federal Procurement Data System - Next
+Generation (FPDS-NG) operated by the General Services Administration (GSA).
+The Contractor, prior to, or immediately upon, award of this Contract, shall furnish the information below to the Contracting Officer.
+a. Type of Organization (Place an "X" in the applicable Box to the left of all that apply)
+Small Business *
+Non Profit Organization
+Small Disadvantaged Business
+State/Local Government
+Large Business
+Foreign Contractor
+Educational institution
+Domestic Contractor Performing Outside U.S.
+Hospital
+Historically Black College/University or Minority Institution
+Service Disabled Veteran Owned Small Business
+Other Veteran Owned Small Business
+* "Small Business" Is defined as having average annual sales not exceeding $5 million.
+b. Women-Owned Business?
+c. Taxpayer Identification Number (TIN)
+d. Data Universal Numbering System (DUNS)
+[may be Social Security No. or Employer
+[if you do not have a DUNS: contact DOJ Contracting
+Identification No.]
+Officer, call
+, or go to www.dnb.com]
+* Yes
+• No
+'e. Parent Company's Name (if applicable)
+f. Parent Company's TIN (if applicable)
+Part I! - Payment Data
+The Contractor, prior to or immediately upon award of this contract, shall furnish the information requested in Blocks b and c below to the address
+shown in block 15, page 1 of 2 of this contract (Form OBD-47), unless the Government determines that payment to the Contractor will not be made via
+Electronic Funds Transfer (EFT).
+a. Agency Information
+Name:
+b. Payee/Company Information
+Name:
+Anna Balter
+JMD/Finance Staff
+Street Address:
+City/State/Zip:
+Contact Person:
+Telephone:
+Facsimile:
+Street Address:
+Washington, DC 20530-0001
+EST Coordinator
+City/State/Zip:
+TIN (or SSN if an Individual):
+Contact Person: Genna Salter
+Telephone:
+c. Financial Institution Information
+any banke
+Bank Name:
+Contact Person:
+Nine-digit ABA Routing No.:
+Telephone:
+Depositor Account No.:
+Type of Account: Checkung
+(checking/savings/lockbox)
+The Debt Collection Improvement Act of 1996 requires that most payments made by the federal government, including vendor payments, must be made
+by Electronic Funds Transfer (EFT). A benefit of receiving payments by EFT is that your funds are directly deposited to your account at a financial
+institution and are available to you on the date of payment.
+If you have questions regarding the delivery of remittance information, please contact the financial institution where you account is held.lf you have any
+questions on the completion of this form, please contact the EFT hotline, Finance Staff, Justice Management Division on
+Form OBD-47A (Revised 3-2005)
diff --git a/vision-fixhub/ds9-unparsed-05/be65ae928b9c084fbb29447c7e6a7c3d0a2ddbf93b18d4171450801bf4021584.receipt.json b/vision-fixhub/ds9-unparsed-05/be65ae928b9c084fbb29447c7e6a7c3d0a2ddbf93b18d4171450801bf4021584.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..77805bf6cd332777d973c0a3c710240b6f100e88
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/be65ae928b9c084fbb29447c7e6a7c3d0a2ddbf93b18d4171450801bf4021584.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1287,
+  "dataset": "marble-joined",
+  "doc_id": "be65ae928b9c084fbb29447c7e6a7c3d0a2ddbf93b18d4171450801bf4021584",
+  "engine": "marble-apple-vision",
+  "event_count": 28,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "1f4dee43246cec2b243ca989a559abb3075320ef4df3c7ed1f58ffb27bb70be7",
+  "output_sha256": "eeed9250c88d8c9f89f29cddf38f070f3b3f20095197d1ff38fad332a322d9e9",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/bf0ea76c6321b237ea30b38e86236f3d4f067d906480964370fda01ae97fb56c.md b/vision-fixhub/ds9-unparsed-05/bf0ea76c6321b237ea30b38e86236f3d4f067d906480964370fda01ae97fb56c.md
new file mode 100644
index 0000000000000000000000000000000000000000..12b4bfa8230c171c0887ff4d824034dfe04662d8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bf0ea76c6321b237ea30b38e86236f3d4f067d906480964370fda01ae97fb56c.md
@@ -0,0 +1,172 @@
+New Jane
+Doe #
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+Old
+Jane
+Doe #
+n/a
+n/a
+n/a
+n/a
+n/a
+n/a
+12
+n/a
+6
+7
+n/a
+14
+13
+5
+3
+8
+9
+n/a
+n/a
+n/a
+n/a
+OPERATION LEAP YEAR
+REVISED INDICTMENT SUMMARY CHART (by victim)
+DOB
+Range of
+Overt Acts
+Substantive
+activity dates
+Counts
+August 1983
+January 1987
+October 1987
+August 1986
+October 1986
+June 1987
+April 1988
+November 1986|
+December 1986
+February 1987
+October 1986
+April 1987
+May 1987
+June 1987
+1998 - 2003
+2001 to 2003
+2003
+2004
+2004
+2004
+7/04
+7/04 - 11/04
+7/04 - 12/04
+7/04 - 11/05
+2004-2005
+8/04 - 2/05
+8/04-5/05
+11/04 - 3/05
+June 1987
+12/04 - 6/5/05
+1
+1-18
+19-31
+32-38, 41
+32,34,39
+40-45
+46,47,54, 57,
+59-64
+49-53, 55, 65
+66-73, 75-77,
+80-83,90
+67,74, 78-79,
+81, 84-89, 147
+91-95
+96,98-104
+96,97,104
+112-131
+132-148, 175
+n/a
+2
+12
+3
+n/a
+n/a
+13,26
+14,26
+4, 15,26
+5,16,26
+n/a
+6, 17
+7, 18
+8,19,27
+9,20, 27
+October 1987
+April 1988
+February 1986
+May 1986
+July 1988
+n/a
+2/05 - 10/05
+2/05 - 3/05
+8/03 - 3/04
+3/04
+2003-2005
+n/a
+90,149-151,
+156-181
+150-155
+182-188, 190
+189-190
+48,52, 56, 58,
+59
+182
+10, 21, 27,28,
+29
+n/a
+n/a
+n/a
+GJ Transcript
+Pages
+5/8/07|
+Transcript pp. 6-7
+5/22/07
+Transcript
+pp. 16-27
+5/22/07
+Transcript
+pp. 25-37
+5/22/07|
+Transcript pp. 4-13
+3/20/07|
+5/15/07
+Transcript
+pp. 3-17
+Transcript
+pp. 23-25, 27-28
+5/22/07
+Transcript
+pp. 39-47
+5/8/07
+Transcript
+pp. 3-12
+Transcript
+pp. 5-13,27
+5/8/07
+Transcript
+
+
+Pp. 24-25
diff --git a/vision-fixhub/ds9-unparsed-05/bf0ea76c6321b237ea30b38e86236f3d4f067d906480964370fda01ae97fb56c.receipt.json b/vision-fixhub/ds9-unparsed-05/bf0ea76c6321b237ea30b38e86236f3d4f067d906480964370fda01ae97fb56c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a0dd57eefb0c9c9ecbeffe0131dc4ba83a8e2871
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bf0ea76c6321b237ea30b38e86236f3d4f067d906480964370fda01ae97fb56c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "bf0ea76c6321b237ea30b38e86236f3d4f067d906480964370fda01ae97fb56c",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "8d5253a0ab136142f819a22cf5d7ce4d05ae56eec9b854d655cc3e0817b496ab",
+  "output_sha256": "4502213c0e0f154137cddc3416721d8f94588bc3d6944a306041b75dbaf9daf3",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/bf14e14ae9919492adc7b66d2e58fc37fb87af20c951c5522189bdfcf95ac026.md b/vision-fixhub/ds9-unparsed-05/bf14e14ae9919492adc7b66d2e58fc37fb87af20c951c5522189bdfcf95ac026.md
new file mode 100644
index 0000000000000000000000000000000000000000..81fa6bd0810b8530c3ace79ba2b2f4cb22582751
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bf14e14ae9919492adc7b66d2e58fc37fb87af20c951c5522189bdfcf95ac026.md
@@ -0,0 +1,63 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 South Australian Ave., Suite 400
+Wes Paim Beach. FL 33407
+July 19, 2007
+DELIVERY BY HAND
+Ms.
+Re: Grand Jury Investigation Confidential
+This letter is an invitation for you to testify before a federal Grand Jury, and is supplied in order to
+proven helpel parker from the Soune Dishi or florida. This theid responsibility of inmi inten
+federal crimes which may have been committed in this District.
+As a Grand Jury witness you will be asked to testify and answer questions under oath, and to
+produce records and documents. Only the members of the Grand Jury, attorneys for the United States
+and a stenographer are permitted in the Grand Jury room while you testify.
+The U.S. Department of Justice encourages prosecutors to notify an individual in appropriate
+cases that he or she is a target of a grand jury investigation. Accordingly, you are hereby notified that you
+are a target of a federal grand jury investigation in the Southern District of Florida concerning suspected
+violations of federal law, including but not limited to, possible violations of Title 18, United States Code,
+Sections 2, 371, 1512, 1591, 1952, 1956, 1960, 2421, 2422, and 2423.
+You are advised that the destruction or alteration of any document required to be produced before
+the grand jury constitutes serious violation of federal law, including but not limited to Obstruction of
+A "target" is a person as to whom the prosecutors or the Grand Jury have substantial evidence
+linking him or her to the commission of a crime and who, in the judgment of the prosecutors, is a putative
+defendant.
+This letter constitutes an invitation to you to testify on your own behalf before the grand jury
+about matters under investigation. Of course, you are not required to appear before the grand jury. The
+decision whether to do so is a voluntary matter which is entirely up to you. The grand jury, if
+in fact it learns of this opportunity afforded to you, will be instructed not to draw any adverse inference
+from your failure to appear should you decide not to accept this invitation. You must further understand
+that should you decide to testify, your testimony could be used against you if any
+Ms.
+July 20, 2007
+Page 2
+criminal charges should be filed against you.
+Should you decide to appear before the grand jury, you will have the same rights and obligations as any
+non-immunized grand jury witness. Specifically,
+You may refuse to answer any question if a truthful answer to the question would tend to
+incriminate you.
+You have the right to stop answering questions at any time.
+Anything you say may be used against you at the grand jury or in a subsequent legal proceeding.
+The grand jury will permit you a reasonable opportunity to step outside the grand jury room to
+consult with your attorney, if you so desire, at any point during the testimony you give.
+Please be further advised that the giving of false testimony before the grand jury will subject you to a
+prosecution for perjury in addition to the violations set forth above.
+As a target of a grand jury investigation who has been asked to appear before the grand jury, you
+may wish to retain the services of an attorney. If you cannot afford the services of independent counsel,
+the Court may be able to appoint counsel to represent you. If you would like the United States to ask the
+Court to appoint an attorney to represent you, please contact the undersigned at |
+. The
+United States is investigating other individuals, and you may be interested in cooperating with the United
+
+
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Assistant United States Attorney
+Ms. |
+July 20, 2007
+Page 3
+bec: Andrew Lourie, Esq.
+Matthew Menchel, Esq.
+Special Agent
diff --git a/vision-fixhub/ds9-unparsed-05/bf14e14ae9919492adc7b66d2e58fc37fb87af20c951c5522189bdfcf95ac026.receipt.json b/vision-fixhub/ds9-unparsed-05/bf14e14ae9919492adc7b66d2e58fc37fb87af20c951c5522189bdfcf95ac026.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9b844ff8fdc9373f0107ca3e5a64be02d5ac10e7
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bf14e14ae9919492adc7b66d2e58fc37fb87af20c951c5522189bdfcf95ac026.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "bf14e14ae9919492adc7b66d2e58fc37fb87af20c951c5522189bdfcf95ac026",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "8a75864f6b317b4e0a44c8ee8106a3402ff53577e3af8e8b4bbd8ea1517e2214",
+  "output_sha256": "70e51d7b527e305c3fc55f0bddf3ccbf1aa1cd5fee1e0b60c0be12137f000540",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/bf1e31c6a4607482854d68714b224987b0c7205862015971c3e951a97f9ed3bb.md b/vision-fixhub/ds9-unparsed-05/bf1e31c6a4607482854d68714b224987b0c7205862015971c3e951a97f9ed3bb.md
new file mode 100644
index 0000000000000000000000000000000000000000..28a0c7eb49dc2347cf962537ddc45c674650e3d4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bf1e31c6a4607482854d68714b224987b0c7205862015971c3e951a97f9ed3bb.md
@@ -0,0 +1,5153 @@
+Statements
+
+
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary .............................
+Transaction Detail
+Your Messages
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 29, 2002
+2
+Hollandlold
+HEALTH & SCIENCE INTERESTS II
+TRUST JEFFREY E EPSTEIN TTEE
+DTD 8/18/93
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Funds Deposited
+Amount Credited
+Miscellaneous
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+3,605.67
+....
+$3.605.67
+-3,605.67
+53605-67
+50.00
+Income Summary
+THIS PERIOD
+Dividends
+0.00
+Credit Balance Int.
+0.00
+Total
+$0.00
+YEAR TO DATE
+3.207,455.67
+36,400.20
+$3,243,855.87
+Important Message
+f any information regarding
+2002 interest, dividends
+niscellaneous incorr
+ross proceeds or origina
+sue reporten is the is tor
+12425 31.200 17, 2003.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+o Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3659.
+SP The suremen s four for ratanal purpose red de Set revere date for portant iformation.
+01/01/03;09:30 001
+
+
+2 org
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+12/0202
+TRANSACTION
+FUNDS REC
+12/10/02 FUNDS REC
+TOTAL
+MISCELLANEOUS
+TRANSACTION
+12/02/02
+JOURNAL
+12/11/02
+2 JOURNALI
+TOTAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+FARE ERRANK FROM
+ENRONSED TO CHIBANK FROM
+DESCRIPTION
+COMPETE IN
+PER LOA
+Your messages
+As part of the National Association of Securities Dealers (NASD)
+DEBIT AMOUNT
+DEBIT AMOUNT
+34.06
+3.571.61
+$-3,605.67
+027
+34.06
+3.571.61
+$3,605.67
+CRECIT AMOUNT
+01/01/03;09:30 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 29, 2002
+VE39
+
+
+3 of 3
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+01/01/03:09:30 001
+VE39
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary.............................
+Transaction Detail
+Fund Activity ....
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25, 2002
+3
+4
+5
+Hollandlold
+HEALTH & SCIENCE INTERESTS II
+TRUST JEFFREY E EPSTEIN TTEE
+DTD 8/18/93
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+273,405,326
+-273,405,326
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Cash & Equivalent -
+Equities —
+Market Value of Your Portfolio
+-80
+$0
+$218,868,126
+$54,537,200
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suren s four or ratanal purposes rearde Set revere ate for portant iformation.
+
+
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+V638
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Funds Deposited
+Dividends/Interest
+THIS PERICO
+215,469.3
+....•..
+45,381,612.04
+264,846,391.43
+54,633,031.70
+2,287.12
+Amount Credited
+Money Fund
+Miscellaneous
+Amount Debited
+Net Cash Activity
+losing Balanc
+$364,863,322.29
+-45,619,484.03
+-319,459,307.62
+5.365.078.791.65
+-215,469.36
+$0.00
+Same day tansfers of cash between acount lypes are not included in this
+section: such transfers, as well as details for all other transactions this period,
+appear in Transaction Detail.
+Cash Balance Summary
+Cash
+Margin
+Short
+Not Cast Balance
+OPENING
+180,011.46
+34,404.10
+1,053.80
+5215.4036
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+574,249.91
+2,287.12
+$576.537.03
+027
+CLOSING
+0.00
+0.00
+0.00
+....
+$0.00
+•••••••••••
+YEAR TO DATE
+3.207,455.67
+36,400.20
+$3,243,855.87
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25,2002
+
+
+Transaction Detail
+INVESTMENT ACTIVITY
+SETILEMENT TRADE
+DATE
+DATE
+TRANSACTION
+10/29/02
+10/24/02
+SOLD
+10/29/02 182402"$0B
+10/31/02
+*10/28/02
+SOLD
+10/31/02
+10/28/02
+"SOLD
+10/31702
+10/28/02
+"SOLD
+10/31/02
+10/28/02
+"SOLD
+19725/02
+JOURNAL
+
+JÖURNAL
+11725/02
+RECEIVED
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+INTERNATIONAL BUSINESS
+MACHINES CORP
+UNSOLICITED
+UNSOLICITED
+INTERNATIONAL BUSINESS
+INTERNATIONAL BUSINESS
+MACHINES CORP
+UNSOLICITED
+TXU CORP
+UNSOLICITED
+AS OF 10/28/02
+"YU CORP***''''**
+UNSOLICITED
+AS OF 10/28/02
+AUTONATION ING BEL
+PER LOA
+NOVA GROUP INC
+,5% SR SEC NOTE MATURING 2005
+500 DUE 11/15/l
+ITH CONTINGENT INT DUE 201
+00051/15/2008
+7.500
+SYMBOLGUSIP
+IBM
+iBM
+iBM
+TXU
+"AN
+
+027
+QUANTITY
+-92,000
+505,000
+93,000
+250,000
+225,000
+270,000
+100,000
+440,000
+10,000,000
+PRICE
+74.28250
+￾ 1263600"
+77.24090
+75.06360
+12.73660
+12.73660
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+October 25, 2002
+DEBIT AMOUNT
+6,828,261.79
+*6.350,685.42
+7,177,604.97
+18.750,335.14
+2,852,148.74
+'3,422,575.98
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+5 of 7
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SATEMENT TREE
+11/25/02
+TRANSACTION
+JOURNAL
+DESCRIPTION
+FINOVA GROUP INC
+7.5% SA SEC NOTE MATURING 2009
+500 DUE 11/15/09
+VITH CONTINGENT INT DUE 201
+TO
+PER LOA
+TOTAL
+DEPOSITS AND WITHDRAWALS
+JATI
+11/05/02
+1125/02
+TRANSACTION
+FUNDS REC
+FUNDS REC
+DESCRIPTION
+ENRE MISER NIR CITIBANK FROM
+FNDS WIRED TO CITIBANK FROM
+MARINE NYC
+FOl
+11/25/02
+FUNDS REC
+FARMER TO BRANK FROM
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+10/26/02
+10/31702
+"BOUGHT
+DESCRIPTION
+OPENINGBALANCE
+RETTIONS SHAALAGEMENTCLA
+SYMBOLCUSIP
+317928AA7
+QUANTITY
+-10,000,000
+PRICE
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25, 2002
+DEBIT AMOUNT
+CRECIT AMOUNT
+$45,381.612.04
+DEBIT AMOUNT
+970.00
+3.875,030.93
+... . . .
+50,757,030.7.
+$54,633,031.70
+SYMBOLCUSIP
+DICXX
+QUANTITY
+218,652,657.49
+'13,300,000
+027
+0000 L
+PRICE
+DEBIT AMOUNT
+13.300,000.00
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of 7
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+TRANSACTION
+11/01/02
+BOUGHT
+17701702 DIVIDEND
+DESCAIPTION
+RETYEHIONASS MANAGEMENT-CLA
+RETTONS SHANAGEMENT CLA
+SHARES
+MONTHLY DIVIDEND
+11701/02 DIVIDEND"
+MAKE TELE MONEY
+RECORD 10/31/02 PAY 10/31/02
+11701/02 REINVEST
+STONA SHAAAGEMENFCLA
+DIVIDEND REINVESTED
+17701/02
+''''REINVEST
+EAR STEARNS PRIME MONE
+(ARKET PORTFOLIO CL
+11/25/02
+REINVEST PRICE $ 1.00
+"SOLD
+RESYTANASEMANACEMENFCLA
+SHARES
+11/25/02
+'SOLD
+RARE TERNS PAME, MONEY
+i/250230LB*
+1/25/02 DIVIDEND
+11/25/02
+"DIVIDEND
+11/29/02
+TOTAL
+HARP FORS TRIME, MONEY
+DIVIDEND CLOSEOUT
+CLOSINGBALANCER
+SMACCUSI
+DICXX
+BMXX
+BICXX
+QUANTIT
+32,000,000
+PRICE
+1.0000
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25, 2002
+DEBIT AMOUNT
+32,000,000.00
+174,469.18
+145,014.85
+174,469.18
+'174,469.18
+145,014.85
+145,014.85
+163.595.937.37
+1.0000
+163,595,937.37
+•0.15
+1-00
+*•'*100,676,204*0000*••••••/•••160,678,204:00
+- 0.15
+*''154,427.86
+100,338.02
+0.00
+$-45,619,484.03
+$264,846,391.43
+027
+
+
+Transaction Detail (continued)
+INTEREST
+DATE
+11/21/02
+DESCRIPTION
+INTEREST ON CREDIT BALANCE
+AT O 3/4% 11/06 THRU
+11/20
+1172102 INTEREST ON CREDIT BALANCE"
+AT 1 1/4% 10/21 THRU 11/05
+11/26/02
+*PRE PAY CR INT 11/21/02
+11/25/02
+TOTAL
+MISCELLANEOUS
+DADDAY
+TRANSACTION
+10/28/02
+JOURNAL
+iö/28/02
+11764/02
+JOUANAL
+JOURNAL'
+11704/02
+JOURNAL"
+11725/02* OUANAL
+11/25/02
+JOUANAL'
+19725/02
+"JOURNAL"
+126/0
+JOURNAL
+TOTAL
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUCUSIP
+QUANTITY
+RATE (%)
+0.7500
+1.2500
+DESCRIPTION
+MARK TO MARKET
+"MARK TO MARKET SHORT POS
+"MARK TO MARKET**''
+"MARK TO MARKET SHORT POS
+PER
+JOURNAL FROM TYPE 2T01
+JOURNAL FROM TYPE 210 1"
+To 1
+TO COMP JRL AJO 11/25/02
+DEBIT AMOUNT
+*1,053.00
+0.80
+:*319.204511.41
+35,457.90
+254,796.21
+$-319,495,819.32
+STOP
+****** End of Statement******
+DEBIT AMOUNT
+CRECIT AMOUNT
+1,053.00
+-0.80
+5,457.4
+$36,511.70
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+October 25,2002
+93.14
+2163-65
+30.33
+$2.287.12
+V638
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ........................................
+Trades Not Yet Settled
+аа мамаааааааааааааааа
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+3
+6
+7
+Hollandlol
+HEALTH & SCIENCE INTERESTS II
+TRUST JEFFREY E EPSTEIN TTEE
+DTD 8/18/93
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+54,537,200
+215,469
+218,652,657
+$273,405,326
+268,145,952
+5,259,374
+ere are no "Stop Loss" orders or other pending bu
+r sell open orders on file for your accoun
+Market Value of Your Portfolio
+Cash & Equivalent
+Equities
+$218.868,126
+$244.518,752
+$54,537,200
+$23,627,200
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen is four or ratanal purpose red de Set revere date for portant iformation.
+
+
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+V637
+
+
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Securities Bought
+Money Fund
+Funds Withdrawn
+Amount Debited
+Net Cash Activity
+Closing Balance
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+513.000548.46
+13,534,453.16
+35,457.90
+$13,569,911.06
+-24,896,965.00
+-334,453.16
+-1,123,572.00
+5 26.354.990.16
+-12,785,079.10
+....
+$215,469.36
+Cash Balance Summary
+Cash
+Margin
+Short
+Not Cash Balance
+OPENING
+13,000,548.46
+0.00
+0.00
+S130005484
+Income Summary
+THIS PERIOD
+Dividends
+365,253.16
+Credit Balance Int.
+3,604.10
+Total
+$368.857.26
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+••••••••••••
+Total.
+027
+CLOSING
+180,011.46
+34,404.10
+1,053.80
+5215,469.36
+YEAR TO DATE
+2,633,205.76
+34,113.08
+$2.667.318.84
+218,868,126
+54,537,200
+•••••••••••••••••••••
+$273,405,326
+.. . .
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+Your Portfolio
+Allocation
+Equities
+19%
+Cash & Equivalent -
+81%
+Unshaded portions denole debit balance andor short
+market values. The alocation percentage is derived
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+DREYFUS CASH MANAGEMENT-CLA
+IN SO DATA HELD 1.6600%
+BEAR STEARNS PRIME MONEY
+DICXX
+BSMXX
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+AUTONATION INC DEL
+.... .
+INTERNATIONAL BUSINESS
+MACHINES CORP
+MBNA CORP
+.......
+TXU CORP
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+AN
+KRB
+TXU
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+QUANTITY
+118,121,468.19
+100,531,189.30
+PRICE
+1.0000
+1.0000
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+100,000
+....
+35.00
+440,000
+1,000,000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+MARKET
+VALUE
+215,469
+....
+118,121,468
+100,531,189
+$218,868,126
+ESTIMATED
+ANNUAL INCOME
+2,008,065
+1,698,977
+$3,707,042
+.700
+1.6900
+PRICE
+10.4200
+74.5600
+19.8900
+12.3100
+MARKET
+VALUE
+1,042,000
+32,433,600
+8,751,600
+12,310,000
+$54,537,200
+$54,537,200
+$4,591,242
+$273,405,326
+027
+ANNUNS NOD
+261,000
+
+500,000
+$884,200
+$884,200
+CURRENT
+YIELD (SI
+.8047
+401
+4.0617
+VE37
+
+
+5 of 7
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TREE
+09/30/02
+TRANSACTION
+JOURNAL
+09/30/02
+09/30/02
+DOUANAL
+JÖURNAL
+09/30/02
+JOURNAL
+1007702 *09/26/02"BOUGHT
+0/17/0
+10/14/02
+BOUGHT
+TOTAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+INTERNATIONAL BUSINESS
+MACHINES CORP
+URNAL FROM TYPE 2 TO
+BNA C883
+JOURNAL FROM TYPE 2 TO 1
+INTERNATIONAL BUSINESS"
+DOUCHAE FROM TYPE 2 TO 1
+MENA CORP **'"
+JOURNAL FROM TYPE 2 TO 1
+"INTERNATIONAL "BUSINESS"
+MACHINES CORP
+UNSOLICITED
+TXU CORP
+AVG PRICE SHOWN-DETAILS ON REQ
+ACTUAL CONFIRM TO YOUR AGENT
+SOLICITED
+DEPOSITS AND WITHDRAWALS
+DATE
+10/01/02
+TRANSACTION
+FND WIRED
+DESCRIPTION
+MDA
+MALARIAS BANS WIRED TO
+FD#07221
+10/24/02
+* CHECK"
+... . .
+VACI
+TOTAL
+SYMBOLCUSP
+IBM
+KRE
+iBM
+KAB
+TXU
+DEBIT AMOUNT
+1,115.399.00
+8,173.00
+$-1,123.572.00
+027
+QUANTITY
+235,000
+440,000
+235,000
+440,000
+*200,000
+000,00
+PRICE
+' 6435280
+11.95440
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York: 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+September 27, 2002
+DEBIT AMOUNT
+*''72,882,562.50
+12,014,402.50
+$-24.896.965.00
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of 7
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+09/28/02
+08/30/02SOLD
+1001102 DIVIDEND
+1001702 DIVIDEND
+10101/02
+•'''REINVEST
+10/01/02
+"REINVEST
+DESCAIPTION
+OPENINGBALANCE
+RENASS MANAGEMENT-CLA
+RSTITIONAS SHARLAGEMENTEL A
+MONTHLY DIVIDEND
+MAKE PORTED MONEY.
+RECORD 09/30/02 PAY 09/30/02
+SITIONS SHALAGEMENTCLA
+DIVIDEND REINVESTED
+MAKE FORT ME MONEY
+REINVEST PRICE $ 1.00
+10/15/02
+"SOLD
+10/25/02
+TOTAL
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+DESCRUPTION
+10/01/02 MBNA CORP
+REC 09/16/02 PAY 10/01/02
+TOTAL
+SYMBOUCUSIP
+KAB
+SYMBOUCUSIP
+BICXX
+DICXX
+ESMXX
+"DICXX"
+DICXX
+QUANTITY
+440,000
+QUANTITY
+231,518,204.33
+-1,200,000
+194,497.10
+139,956.06
+12,000,000
+218,652,657.49
+RATE (S)
+0.0700
+027
+PRICE
+1.0000
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD September 28,2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+DEBIT AMOUNT
+1,200,000.00
+194,497.10
+139,956.06
+194,497.10
+139.956.06
+.0000
+12,000,000.00
+$13.534,453.16
+DEBIT AMOUNT
+$-334,453.16
+30,800.00
+$30,800.00
+
+
+Transaction Detail (continued)
+INTEREST
+DATE
+10/21/02
+DESCRIPTION
+INTEREST ON CREDIT BALANCE
+AT 1 1/4% 09/21 THRU 10/20
+10021/02 SHTACCT FEE 09/21-102002
+TOTAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOL/CUSIP
+QUANTITY
+RATE (%)
+1.2500
+Trades Executed Pending Settlement
+SETILEMENT TRADE
+DATE
+DATE
+10/29/02
+10/24/02
+TRANSACTION
+SOLD
+10129/02
+TOTAL
+10/24/02
+- SOLD
+DESCRIPTION
+INTERNATIONAL BUSINESS
+MACHINES CORP
+UNSOLICITED
+.... ...
+TXU CORP
+UNSOLICITED
+TXU
+SYMBOLCUSIP
+IBM
+The above trades do not appear in any other section of this statement.
+STOP
+****** End of Statement******
+027
+DEBIT AMOUNT
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+3,604.10
+....
+1,053.80
+$4,657.90
+QUANTITY
+-92,000.00
+05,000.0
+PRICE
+DEBIT AMOUNT
+74.2825
+....
+12.6360
+$0.00
+6,828,261.79
+6,350,685.42
+$13,178,947.21
+V637
+
+
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ..............
+.......
+Trades Not Yet Settled
+Your Messages
+...
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+3
+Hollandlold
+HEALTH & SCIENCE INTERESTS II
+TRUST JEFFREY E EPSTEIN TTEE
+DTD 8/18/93
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+10
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+23,627,200
+13,000,548
+231,518,204
+$268,145,952
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+276,912,649
+-8,766,696
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Cash & Equivalent
+Equities -
+Market Value of Your Portfolio
+$23,627,200
+$35,777,000
+Current market value
+Last statement's market value
+S244.518.752
+# $241,135,649
+Important Message
+Confirmation: Unless we
+hear from you to the
+contrary, it is our
+understanding that any free
+redit balances in your
+ccount are bein
+maintained to facilitate
+such amount thirugh us.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+
+
+2 of 12
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+09/29/02;13:15 001
+
+
+3 of12
+Cash Flow Analysis
+THIS PERICO
+Opening Balance
+514,730.649.78
+Securities Sold
+42,261,330.51
+Money Fund
+20,513,204.93
+Dividends/Interest
+65,509.17
+Amount Credited
+562,840,044.61
+Securities Bought
+-32,255,941.00
+Money Fund
+-25,313,204.93
+Funds Withdrawn
+-7,001,000.00
+Amount Debited
+$-64,570,145.93
+Net Cash Activity
+-1,730,101.32
+Closing Balance
+$13,000,548.46
+Same day tansiers of cash between account types are not included in this
+section: such transfers, as well as details for all other transactions this period,
+appear in Transaction Detail.
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Income Summary
+Dividends
+Credit Balance Int.
+THIS PERIOD
+358,204.93
+9,954.14
+5368,159.07.
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total.
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OFENING
+CLOSING
+4,730,649.78
+13,000,548.46
+10,000,000.00
+0.00
+314,730.649.78 $13,000.548.46
+.......
+027
+YEAR TO DATE
+2,267,952.60
+30,508.98
+----.
+2,298.461.5
+244,518,752
+23,627,200
+$268,145,952
+09/29/02;13:15 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+Your Portfolio
+Allocation
+Equities
+8%
+Cash & Equivalent -
+92%
+Unshaded portions denole debt balance and'or short
+
+
+4 of 12
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DREYFUS CASH MANAGEMENT-CLA
+IN 30 DATA ARE ARED1.7000%
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+AUTONATION INC DEL
+INTERNATIONAL BUSINESS
+MACHINES CORP
+MENA CORP
+Total Equities& Options
+TOTAL EQUITIES
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+SYMBOLCUSIP
+DICXX
+BSMXX
+QUANTITY
+131,126,971.09
+100,391,233.24
+PRICE
+1.0000
+1.0000
+SYMBOLCUSIP
+AN
+KRB
+CASH
+MRGN
+MAGN
+QUANTITY
+100,000
+235,000
+440,000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+MARKET
+VALUE
+13,000,548
+131,126,971
+100,391,233
+$244,518,752
+ESTIMATED
+ANNUAL INCOME
+... 651'6222
+1.7000
+1,676,534
+1.6700
+$3,905,693
+PRICE
+11.9700
+60.3600
+18.7400
+MARKET
+VALUE
+1,197,000
+14,184,600
+8,245,600
+$23,627,200
+$23,627,200
+$4,169,893
+$268,145,952
+ANNUAL MOME
+141,000
+123,200
+$264,200
+$264,200
+CURRENT
+YIELD (%)
+0.9940
+1.4941
+027
+
+
+5 of 12
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT TRADE
+DATE
+TRANSACTION
+09/03/02
+08/28/02
+SOLD
+65763782 88728702 SOLB"
+09/03/02
+'28/28/02 'SOLD
+09/03/02
+08/28/02
+09/03/02
+08/28/02
+"SOLD
+*SOLD
+09/06/02
+JOURNAL
+09/06/02
+"JOURNAL
+09/12/02
+09/09/02
+"BOUGHT
+09/12/02
+09/09/02
+"SOLD
+09/18/02
+09713/02
+"BOUGHT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+BANK ONE CORP
+UNSOLICITED
+SEE NOTE "S" ON BACK
+"BEAR STEANS COMPANIES INC
+AVG PRICE SHOWN-DETAILS ON REQ
+UNSO CONFIRM TO YOUR AGENT
+MACHINES CORP
+UNSOLICITED
+MENA COAP
+UNSOLICITED
+MARRIOTT INTERNATIONAL ING NEW
+CLA
+UNSOLICITED
+SHORT
+SEE NOTE "S" ON BACK
+MENA CORP'**
+OURNAL FROM TYPE 1 TO :
+JOURNAL FROM TYPE 1 TO 2
+INTERNATIONAL BUSINESS
+ANG PRICE SHOWN DETALS ON REO
+TUAL CONFIRM TO YOUR AGE
+ISOLICITE
+"MENA CORP**
+AVG PRICE SHOWN-DETAILS ON REC
+ACTUAL CONFIRM TO YOUR AGENT
+UNSOLICITED
+INTERNATIONAL BUSINESS"
+MACHINES CORF
+UNSOLICITEL
+AS OF 09/13/02
+SYMBOLGUSIP
+ONE
+"BM
+"KRE
+MAR
+KRE
+BM
+KRB
+027
+QUANTITY
+-100,000
+: 100,000
+50,000
+60,000
+-500,000
+940,000
+940,000
+35,000
+500,000
+200,000
+PRICE
+40.32800
+- 43.14820
+'''76.66800
+*19.75000
+33.95000
+••••••••••••••••••••••••
+72-30860
+20.00040
+72.39120
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30,2002
+DEBIT AMOUNT
+4,026,676.11
+*8.308,627.42
+*3.830,282.11
+1,181,361.83
+16,944,486.55
+*2,532,903.50
+9,969,896.49
+14,490,242.50
+
+
+6 of 12
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+DATE
+TRANSACTION
+09/18/02
+09/13/02
+BOUGHT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+MARRIOTT INTERNATIONAL ING NEW
+IG PRICE SHOWN-DETAILS ON RE
+STUAL CONFIRM TO YOUR AGEI
+MARRIOTT INTERNATIONAL ING NEW
+ON SOLICITED
+SEE NOTE 'S ON BACK
+DOVER SHORT
+09/24/02
+09/19/02
+BOUGHT
+TOTAL
+DEPOSITS AND WITHDRAWALS
+DATE
+09/10/02
+TRANSACTION
+FND WIRED
+DESCRIPTION
+09/19702
+""NB" WIAŁD"
+SOLD DREYFUS
+09/12/02
+FND WIRED
+TOTAL
+ENDS WIRED TO
+FD#05382
+FD#00739
+FD#05360
+SYMBOLGUSIP
+MAR
+MAR
+DEBIT AMOUNT
+1,000.00
+2,000,000.00
+5,000,000.00
+$-7,001,000.00
+027
+QUANTITY
+200,000
+PRICE
+31.41370
+300,000
+29.73350
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS I
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+August 30, 2002
+DEBIT AMOUNT
+6,294,742.50
+8,938,052.50
+$-32,255,941.00
+$42,261,330.51
+
+
+7 of 12
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+08/31/02
+05/03/02 DIVIDEND
+09/03/02 DIViDEND
+09/03/02 REINVEST
+ÖS/03/02
+REINVEST
+09/0402
+BOUGHI
+ö9/05/02
+BOUGH
+09/11702
+'SOLD
+09/12/02
+SOLD
+09/17/02
+"SOLD"
+09/27/02
+SOLD
+.....
+09/27/02
+TOTAL
+OFFICE SERVICING YOUR ACOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCAIPTION
+OPENINGBALANCE
+PREYFUS CASH MANAGEMENT-CLA
+MONTHLY DIVIDEND
+MAKE PORNOLD ME, MONEY
+RECORD 08/30/02 PAY 08/30/02
+DREYFUS CASH MANAGEMENT-CL
+STITUTIONAL SHARE
+DIVIDEND REINVESTED
+EAR STEARNS PRIME MONE
+-OLIO CL
+REINVEST PRICE $ 1.00
+PRETTIONS SHARAGEMENT CLA
+RETONA SHANAGEMENFCLA
+STONES MANAGEMENT-CLA
+PRETENS MANAGEMENT-CLA
+RETONAS SARAGEMENTCLA
+CLOSINGBALANCE
+SYMBOUCUSIP
+BICXX
+BMXX
+DICXX
+"DICXX
+DiCXX
+DiCXX*
+DICXX
+DICXX
+QUANTITY
+226,404,999.40
+166,834.18
+146,370.75
+20,000,000
+.000,00d
+2,000,000
+5.000,00
+4,000,00đ
+9.200,000
+231,518,204.33
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+DEBIT AMOUNT
+166,834.18
+146,370.75
+166.834.18
+146,370.75
+20,000,000.00
+5,000,000.00
+0000"
+0000
+0000*
+.0000
+0000
+0000
+$-25,313,204.93
+2,000,000.00
+5.000,000.00
+4,000,000.00
+9,200,000.00
+$20,513,204.93
+
+
+8 of 12
+Transaction Detail (continued)
+DIVIDENDS
+DATE
+DESCRIPTION
+09/10/02
+INTERNATIONAL BUSINESS
+MACHINES CORP
+REC 08/09102 PAY 09/10102
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+09/23/02
+INTEREST ONCREDIT BALANCE
+AT 1 1/4% 08/21 THRU 09/20
+09/23/02
+'"SHÖRT REBATE RETRO 9/03/02
+Assansasnnsnnnsnnsaıiıs nonossanannnnnnnnsna ınnnnnnnnnnnnnnn
+09/23/02
+SHT ACCT FEE 08/21-09 20 02
+TOTAL
+MISCELLANEOUS
+DATE
+MO/DAY
+09/05/02
+69/05/02
+09/06/02
+09/06/02
+09/09/02
+09/09/02
+09/16/02
+05/18702
+RANSACTION
+OURNA
+JOUANAL"
+JOUANAL"
+jÖÜANAL'
+JÖUANAL'
+jÖUANAL'
+jÖUANAL
+"'OÜANAL"
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUCUSIP
+IBM
+SYMBOUCUSIP
+ESCRIPTIO
+OURNAL FROM TYPE 2 TO
+JÖURNAL" ROM TVPE 210°1"
+JOURNAL FROM TYPE 1102"
+JOURNAL FROM TYPE 1 102
+"MARK TO MARKET
+"MARK TO MARKET SHORT POS"
+''MARK TO MARKEI
+"MARK" TO MARKE1 SAORT P'OS"
+QUANTITY
+300,000
+RATE (S)
+0.1500
+QUANTITY
+RATE (S)
+1.2500
+DEBIT AMOUNT
+"5,000,000.00
+77,597.25
+434,486.00
+"910,000.00"
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+5,000,000.00
+77,597.25
+434,486.00
+910,000.00
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Secuities Corp.
+One Metratech Center North
+Brocktyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOO August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+45,000.00
+$45.000.00
+CAEDIT AMCUNT
+9,954.14
+*647.18
+sonsansasaanaans
+9,907.85
+$20,509.17
+
+
+9 of 12
+Transaction Detail (continued)
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+09/18/02
+09718/02
+09/23/02
+09/23/02
+09/23/02
+TRANSACTION
+OURNAL
+JOURNAL"
+jOURNAL
+JOURNAL"
+JOURNAL,
+69/27/02
+05/27102
+09/27/021
+09/27/02
+TOTAL
+'''JOUANAL"
+JOUANAL"
+JOUANALI
+JOURNAL
+DESCRIPTION
+JOURNAL FROM TYPE 1 10 2
+JOURNAL FROM TYPE 1102
+"JOURNAL FROM TYPE 2105
+"MARK TO MARKET
+"MARK TO MARKET SHORT POS
+"JOURNAL FROM TYPE 310°Y
+"JOURNAL" FROM TYPE 210%
+JOURNAL FROM TYPE 2101
+JOURNAL FROM TYPE S TO 1
+DEBIT AMOUNT
+4,044,000.00
+358,052.45
+725,258.00
+3,780,039.29
+10,555.03
+$-15,339,988.02
+Trades Executed Pending Settlement
+SELEMENT TREE
+70/01/02 09/26/02
+TRANSACTION
+BOUGHT
+TOTAL
+DESCRPTION
+INTERNATIONAL BUSINESS
+MACHINES CORP
+UNSOLICITED
+The above trades do not appear in any other section of this statement.
+SYMBOLCUSIP
+IBM
+027
+CRECIT AMOUNT
+4,044,000.00
+725,258.00
+'•358,05245
+•10,555.03
+3,780,039.29
+$15.339.988.02
+QUANTITY
+200,000.00
+PRICE
+64.3528
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+DEBIT AMOUNT
+12,882,562.50
+$12,882,562.50
+$0.00
+
+
+10 of 12
+lear, Steams & Co. Inc
+83 Madison Avenue
+New York, New York 10179
+Your messages
+138
+Bear, Stearns Securities Corp, Net Capital and Net Capital
+Requirements:
+A complete copy of the Bear, Stearns Securities Corp, Statement
+of Financial Condition is available on the web site
+www.bearstearns.com, Alternatively, to request a free printed copy
+please call -toll free 1-866-299-9331.
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+August 30, 2002
+Securities and other assets in your account are the firm's collateral
+for any margin loan made to you. If the securities and other assets in
+your account decline in value, so does the value of the collateral
+supporting your loan, and, as a result, the firm can take action, such
+as issue a margin call and/or sell securities or other assets in any of
+your accounts held with the member, in order to maintain the required
+equity in the account, It is important that you fully understand the
+risks involved in trading securities on margin. These risks include
+the following:
+> You can lose more funds than you deposit in the margin account.
+> The firm can force the sale of securities or other assets in your
+accounts).
+> The firm can sell your securities or other assets without contacting
+> You are not entitled to choose which securities or other assets in
+your accounts) are liquidated or sold to meet a margin call.
+> The firm can increase its "house" maintenance margin requirements
+at any time and is not required to provide you advance written notice.
+> You are not entitled to an extension of time on a margin call.
+027
+
+
+11 of 12
+Sear, Stears & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+13P
+This statement is provided to explain Bear, Steams & Co. Inc.'s
+(BSC") payment for order flow practices.
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+Pursuant to SEC Rule 11Ac1-6, please note the following:
+Bear, Stearns & Co, Inc, will post its quarterly routing statistics at the
+following web link:
+Customers of Bear, Stearns & Co. Inc, may request information on
+any order executed within the prior six months from the time of the
+request, Specifically, you may request the identity of the venue to
+which the identified orders were routed for execution, whether the order
+was directed by you to that venue, and the time of the executions, i
+any, that resulted from such orders.
+027
+
+
+12 of 12
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+13P
+The following account service fees will be charged to applicable
+accounts as of November 1, 2002:
+The service charge per transaction will be $5,00, Accounts
+transferred from Bear Stearns will be charged a $75.00 account
+transter fee. There will be a $50,00 fee for each stock certificate
+hat is sent out in registered form at the customer's request, W
+strongly recommend against holding stock certificates in physica
+form due to the possibility of theft, loss or damage.
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+August 30, 2002
+NOTICE OF CHANGE PURSUANT TO THE TRUTH IN LENDING
+SEC RULE 10b-16
+Effective as of November 15, 2002, the annual rate of interest charged
+on any credit extended to you by Bear Steams Securities for the
+purpose of purchasing, carrying or trading in any security or other
+property shall be based on either the Bear Stearns Margin Basis Rate,
+the Bear Stearns Securities Fed Funds Rate or the London Interbank
+Offering Rate (LIBOR"). The Bear Stearns Margin Basis Rate will be
+quoted daily by Bear Stearns at our main office in New York, Factors
+affecting the determination of the Bear Stearns Margin Basis Rate
+will include the short-term market interest rates quoted by money
+center banks and the Federal Reserve and the rate that Bear Stearns
+is charged for borrowing money, The Bear Stearns Securities Fed
+Funds Rate is the rate for U.S. dollar funds, as quoted by an
+independent broker of such funds selected by Bear Stearns Securities
+for the last transaction completed prior to 9:30 a,m, (Eastern Time)
+on the business day on which such rate is determined. The annual
+rate of interest will be no more than 3% above the Bear Stearns
+Margin Basis Rate or 4% above either the Bear Stearns Securities
+Fed Funds Rate or LIBOR and will appear on your monthly statements.
+Since the rate of interest charged is related to the Bear Stearns
+Margin Basis Rate, the Bear Stearns Securities Fed Funds Rate or
+LIBOR, any changes in these rates will cause corresponding changes
+in the rate charged to your account, which changes will be made
+the rate of terest charges you, we it lie you
+at least 30 days prior notice.
+The "Statement of Interest Charges Pursuant to the "Truth-in-Lending"
+SEC Rule 10b-16" previously provided to you remains in effect
+except to the extent specifically amended by this notice.
+027
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ....
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ........
+Trades Not Yet Settled
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+3
+Hollandlold
+HEALTH & SCIENCE INTERESTS II
+TRUST JEFFREY E EPSTEIN TTEE
+DTD 8/18/93
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+8
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+35,777,000
+14,730,650
+226,404,999
+$276,912,649
+•••••••••••••••••••••
+267,330,234
+9,582,415
+ere are no "Stop Loss' orders or other pending bu
+r sell open orders on file for your accoun
+Market Value of Your Portfolio
+Cash & Equivalent
+Equities -
+S241.135,649
+$234.190,234
+$35,777,000
+$33,140,000
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal furyce rear die Set revere date for portant iformation.
+
+
+2 of 8
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+THIS PERICO
+Opening Balance
+213,482.5
+Securities Sold
+34,444,028.43
+Money Fund
+28,428,249.18
+Dividends/Interest
+4,838.81
+Amount Credited
+562,877,116.42
+Securities Bought
+-27,931,700.00
+Money Fund
+-20,428,249.18
+Amount Debited
+6.48.359.949.18
+Net Cash Activity
+14,517,167.24
+.....
+Closing Balance.
+... $14,730.649.78
+Same day transfers of cash between account types are not included in this
+section; such transfers,
+as wall as detals for all other transactions this pariod,
+appear in Transaction Detail.
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+CLOSING
+213,482.54
+4,730,649.78
+0.00
+10,000,000.00
+....
+$213,482.54
+$14,730,649.78
+Income Summary
+Dividends
+Credit Balance Int.
+•••••••••••••••
+Total
+THIS PERIOD
+428,249.18
+4,838.81
+$433.087.99
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+YEAR TO DATE
+1,909,747.67
+20,554.84
+•••••••••••••••
+1,930,302.5
+241,135,649
+35,777,000
+5276.912.649
+027
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+Your Portfolio
+Allocation
+Equities
+12%
+Cash & Equivalent-
+88%
+Unshaded portions denole debt balance and'or short
+
+
+4 of a
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+Vew York, New York 10179
+DREYFUS CASH MANAGEMENT-CLA
+EST, 30 DAY A WIELD 1.7300%
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+AUTONATION ING DEL
+BANK ONE CORP
+BEAR STEARNS COMPANIES INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+MBNA CORP
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+DICXX
+BSMXX
+QUANTITY
+126,160,136.91
+100,244,862.49
+PRICE
+1.0000
+1.0000
+SYMBCUCUSIP
+AN
+ONE
+BSC
+BM
+KRB
+ACCT
+CASH
+CASH
+CASH
+ASH
+CASH
+OLANTITY
+100,000
+100,000
+100,000
+50,000
+1,000,000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+MARKET
+VALUE
+14,730,650
+126,160,137
+100,244,862
+$241,135,649
+ESTIMATED
+ANNUAL INCOME
+.700
+....
+1,704,163
+1.7000
+$3,848,885
+PRICE
+13.2000
+40.9500
+63.9300
+75.3800
+20.2000
+MARKET
+VALTE
+1,320,000
+4.095,000
+6,393,000
+,769,001
+20,200,000
+$35,777,000
+$35,777,000
+ANNUAL NOONE
+84,000
+60,000
+30,000
+280,000
+$454,000
+$454,000
+URREN
+2.0513
+0.9385
+0.7960
+1.3861
+027
+
+
+5 or 8
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SEEMENT T
+TRANSACTION
+08/01/02 07/29/02
+BOUGHT
+08/20/02
+08/15/02
+"BOUGHT
+08/20/02 08/15/02 "BOUGHT
+08/26/02 08/21/02
+"BOUGHT
+DESCRIPTION
+INTERNATIONAL BUSINESS
+ACHINES CO
+IG PRICE SHOWN-DETAILS ON R
+ACTUAL CONFIRM TO YOUR AGENT
+AOL TIME WARNER INC***
+AVG PRICE SHOWN-DETAILS ON REC
+ACTUAL CONFIRM TO YOUR AGENT
+UNSOLICITED
+TYCO INTERNATIONAL LE
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+UNSOLICITED
+"AUTONATION INC DEL
+UNSOLICITED
+AS OF 08/21102.
+$4,302,885
+$276,912,648
+SYMBOLGUSIP
+IBM
+QUANTITY
+200,000
+PRICE
+69.16530
+AOL
+TYC
+*AN
+500,000
+500,000
+100,000
+12.12000
+13.30040
+'73.10430
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+DEBIT AMOUNT
+13,845,062.50
+6.090,002.50
+6,680,202.50
+7,316,432.50
+
+
+6 of a
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SETTLEMENT TRADE
+DATE
+TRANSACTION
+08/28/02
+08/23/02
+SOLD
+08/28/02 08/23/02 SOLD
+08/28/02
+/''08/23/02S0LD
+TOTAL
+MONEY FUND ACTIVITY
+BATEAY
+TRANSACTION
+07/27/02
+07/30/02
+SOLD
+ö8/01/02
+"DIVIDEND'
+08/01/02 DIVIDEND
+08/01/02
+''''REINVEST
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+AOL TIME WARNER INC
+AVG PRICE SHOWN-DETAILS ON REO
+INSOLEN RAM TO YOUR AGENT
+INTERNATIONAL BUSINESS***
+TYCO INTERNATION. C...
+AVG PRICE SHOWN-DETAILS ON REQ
+ACTUAL CONFIRM TO YOUR AGENT
+UNSOLICITED
+DESCRIPTION
+OPENINGBALANCE
+RET AS ALACEMENTECLA
+REE AS NANCE MENICE*
+MONTHLY DIVIDEND
+MAKE FORGED, MONEY
+RECORD 07/31/02 PAY 07/31/02
+SYMBOLGUSP
+AOL
+iBM
+TYC
+QUANTITY
+-500,000
+250,000
+PRICE
+12.88580
+80.25990
+500,000
+- 16.02440
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+DEBIT AMOUNT
+6,412,703.56
+20,049,368.54
+7,981,956.33
+$-27,931,700.00
+$34,444,028.43
+SYMBOUCUSIP
+DICX
+"DICXX
+QUANTITY
+233,976,750.22
+13.800,000
+PRICE
+.0000
+DEBIT AMOUNT
+CAEDIT AMOUNT
+3,800,000.00
+276,700.19
+151,548.99
+276,700.19
+276,700.19
+027
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+TRANSACTION
+08/01/02
+REINVEST
+08/16/02 SOLD
+08/22/02 SOLD
+08/29/02 BOUGHT
+DESCRIPTION
+BEARE FORS PRIME, MONEY
+REINVEST PRICE $ 1.00
+REGIONAS SHAALAGEMENTCLA
+08/30/02
+TOTAL
+CLOSINGBALANCE
+INTEREST
+DATE
+DESCRIPTION
+8/21/02 INTEREST ON CREDIT BALANC
+T 1 1/4% 07/21 THRU 08/2
+TOTAL
+SYMBOUCUSIP
+MISCELLANEOUS
+JATE
+MODAY
+08/29/02
+
+TOTAL
+TRANSACTION
+JOURNAL
+OURNA
+DESCRIPTION
+JOURNAL FROM TYPE 1 TO 2
+JOURNAL FROM TYPE 1 TO 2
+SYMBOUGUSIP
+BMXX
+Dicxx*
+DiCX
+QUANTITY
+151,548.99
+12,800,000
+1,400,000
+*'20,000,000
+226,404,999.40
+PRICE
+.0000
+0000*
+1.0000**'
+QUANTITY
+RATE (SI
+1.2500
+DEBIT AMOUNT
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+DEBIT AMOUNT
+151,548.99
+12,800,000.00
+,400,000.00
+20,000,000.00
+$-20,428,249.18
+$28,428,249.18
+4,838.81
+$4,838.81
+DEBIT AMOUNT
+10,000,000.00
+$-10,000,000.00
+CRECIT AMOUNT
+10.000.000.00
+$10.000.000.00
+027
+
+
+8 of a
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Trades Executed Pending Settlement
+SETLEMENT TREE
+09/03/02
+08/28/02
+TRANSACTION
+SOLD
+09/03/02
+08/28/02
+*SOLD
+09/03/02
+08/28/02
+SOLD
+09/03/02
+08/28/02
+09/03/02
+08/28/02
+SOLD
+SOLD
+TOTAL
+DESCRIPTION
+BANK ONE CORP
+SOLICITE
+E NOTE 'S" ON BAI
+BEAR STEARNS COMPANIES INC
+VG PRICE SHOWN-DETAILS ON REC
+INSOLEN RM TO YOUR AGEN
+INTERNATIONAL BUSINESS
+MACHINES CORP
+UNSOLICITED
+MBNA CORP
+UNSOLICITED
+MARRIOTT INTERNATIONAL ING NEW
+CLA
+UNSOLICITED
+SHORT
+SEE NOTE 'S ON BACK
+The above trades do not appear in any ather section of this statemert.
+(STOP
+****** End of Statement******
+SYMBOLGUSIP
+ONE
+BSC
+BM
+KRB
+MAR
+027
+QUANTITY
+-100,000.00
+-100,000.00
+PRICE
+40.3280
+63.1482
+-50,000.00
+-60,000.00
+500,000.00
+76.6680
+19.7500
+33.9500
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+DEBIT AMOUNT
+4,026,676.11
+6.308.627. 42
+3.830,282.11
+1,181,361.83
+6,944,486.5
+$0.00
+$32.291.434.02
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .............................
+Your Portfolio Holdings
+Transaction Detail .................................
+Fund Activity .....•.•••••••••••••••••••••••IIIIIIIII
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+3
+4
+5
+5
+Hollandlold
+HEALTH & SCIENCE INTERESTS II
+TRUST JEFFREY E EPSTEIN TTEE
+DTD 8/18/93
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+33,140,000
+213,483
+233,976,751
+$267,330,234
+•••••••••••••••••••••
+320,890,052
+-53,559,819
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+Equities —
+8231.190.234 5320.890,.052
+$0
+$33,140,000
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four ratanal purpose red die Set revere dae for portant iformation.
+
+
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Securities Bought
+Money Fund
+Funds Withdrawn
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERICO
+3439,529.45
+86,886,227.52
+7,263.09
+$86,893,490.61
+•........
+-35,797,910.00
+-206,227.52
+-51,115,400.00
+6 87.119.537.52
+-226,046.91
+......
+$213,482.54
+.....
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+206,227.52
+7,263.09
+$213.490.61.
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+OPENING
+439,529.45
+Net Cash Balance
+$439,529.45
+CLOSING
+213,482.54
+....
+$213,482.54
+•.••.•
+027
+YEAR TO DATE
+1,481,498.49
+15,716.03
+51.497214.52
+234,190,234
+33,140,000
+....
+$267,330,234
+.....
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+Your Portfolio
+Allocation
+Equities
+12%
+Cash & Equivalent-
+88%
+Unshaded portions denole debt balance and'or short
+
+
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+DREYFUS CASH MANAGEMENT-CLA
+EST, 30 DAY ANG WIELD 1.7000%
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+BANK ONE CORP
+BEAR STEARNS COMPANIES INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+MENA CORP
+Total Equities& Options
+TOTAL EQUITIES
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+SYMBOUCUSIP
+DICXX
+BSMXX
+QUANTITY
+133,883,436.72
+100,093,313.50
+PRICE
+1.0000
+1.0000
+SYMBCLCUSIP
+ONE
+BSC
+KRB
+ACCT
+CASH
+CASH
+ASH
+CASH
+QUANTITY
+100,000
+100,000
+100,000
+1,000,000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+MARKET
+VALUE
+213,483
+133,883,437
+100,093,314
+$234,190,234
+ESTIMATED
+ANNUAL INCOME
+2,276,018
+1.7000
+1,771,652
+*••••••
+1.7700
+$4,047,670
+PRICE
+34.6500
+57.8500
+66.4000
+17.2500
+MARKET
+VALTE
+3,465,000
+5,785,000
+6,640,000
+17,250,000
+$33,140,000
+$33,140,000
+$4,531,670
+$267,330,233
+027
+STIMATE
+CURRENT
+INUAL INCON
+YELD IN
+84,000
+2.4242
+600000*
+1.0372
+60,000
+0.9036
+280,000
+$484,000
+$484,000
+1.6232
+07127102;17:22 001
+
+
+5 orB
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT TRADE
+DATE
+TRANSACTION
+07/22/02
+07/17/02
+BOUGHT
+07722782 "87717702'BO0GAN"
+07122/02
+'07/17/02"
+'BOUGHT
+07/23/02
+07/18/02
+BOUGHT
+TOTAL
+DATE
+07/01/02
+TRANSACTION
+FND WIRED
+07/24/02
+END WIRED
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+06/29/02
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+BANK ONE CORP
+UNSOLICITED
+SEE NOTE "S" ON BACK
+"BEAR STEANS COMPANIES INC
+UNSOLICITED
+INTERNATIONAL BUSINESS"
+MAGUE OP
+MENA COAP *
+G PRICE SHOWN-DETAILS ON R
+TUAL CONFIRM TO YOUR AGEN
+UNSOLICITED
+DESCRIPTION
+FD#07204
+FD#03192
+DESCAIPTION
+OPENINGBALANCE
+SYMBOLGUSP
+ONE
+BSC
+iBM
+KRB
+QUANTITY
+100,000
+100,000
+00,00
+1,000,000
+PRICE
+38.35600
+- 38:09900
+•7.13900°
+18.96050
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+June 28, 2002
+DEBIT AMOUNT
+3,841,602.50
+'5.815,902.50
+7,119,902.50
+19,020,502.50
+$-35.797,910.00
+DEBIT AMOUNT
+1,115,400.00
+50,000,000.00
+$-51,115,400.00
+SYMBOLCUSIP
+QUANTITY
+320,450,522.70
+027
+PRICE
+07127102;17:22 001
+DEBIT AMOUNT
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+TRANSACTION
+07/01:02
+SOLD
+67/01/02 DIVIDEND
+DESCAIPTION
+RETYEHIONASS MANAGEMENT-CLA
+RSETTONS SHANAGEMENT CLA
+SHARES
+MONTHLY DIVIDEND
+07/01/02 DIVIDEND"
+MAKE TELE MONEY
+RECORD 06/28/02 PAY 06/28/02
+07/64702 REINVEST
+RHYTON SALACEMENT CLA
+DIVIDEND REINVESTED
+07/01702
+'"REINVEST
+ARE TELE ME, MONEY
+REINVEST PRICE $ 1.00
+07/702
+'''SOLD
+PRETTINE SMANAGEMENTCLA
+87/49782***S8LB
+07/24/02
+"SOLD
+RETTONS SHARAGEMENT CLA
+CLOSINGBALANCER
+07/26102
+TOTAL
+INTEREST
+DATE
+DESCRUPTION
+07/22/02
+AT 11A% 0627 RU 0720E
+TOTAL
+SYMBOUCUSIP
+DICXX
+BMXX
+DiCXX
+DICXX
+DICXX
+QUANTITY
+QUANTITY
+-680,000
+112,914.02
+93,313.50
+17,000,000
+19:000,000
+50,000,000
+233,976,750.22
+RATE (%)
+1.2500
+027
+PRICE
+1.0000
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+DEBIT AMOUNT
+680,000.00
+112,914.02
+93,313.50
+112,914.02
+93.313.50
+1.0000
+1:0000
+0000"
+••••••••••••••••••••••••••••••••••••••
+$-206.227.52
+17,000,000.00
+19.080,000:80
+50,000,000.00
+$86.886,227.52
+DEBIT AMOUNT
+7,263.09
+$7,263.09
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ....
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity
+................
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+5
+Hollandlold
+HEALTH & SCIENCE INTERESTS II
+TRUST JEFFREY E EPSTEIN TTEE
+DTD 8/18/93
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+....
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+439,529
+320,450,523
+$320,890,052
+334,210,523
+- 13,320,470
+here are no Stop Loss" orders or other pending bu
+r sell open orders on file for your account
+Market Value of Your Portfolio
+$5,717,023
+$320.890.052
+Cash & Equivalent
+Equities
+90
+$328,493,500
+Current market value
+Last statement's market value
+Flease raport any dierence or nonreceipt of chocks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen is four ratanal purpose rear de Set revere dae for potamt iformation.
+
+
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+$15,141.93
+....
+313,982,989.00
+8,641.32
+1,181,398.52
+$315,173,028.84
+-314,748,641.32
+5-314.748.641.32
+424,387.52
+5439.529.45
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+15,141.93
+$15,141.93
+Income Summary
+THIS PERIOD
+Dividends
+1,182,391.32
+Credit Balance Int.
+7,648.52
+Total.
+$1,190,039.84
+Portfolio Composition
+Cash/Cash Equivalent
+Total.
+027
+CLOSING
+439,529.45
+5439,529.45
+............
+YEAR TO DATE
+1,275,270.97
+8,452.94
+$1,283.723.91
+320,890,052
+$320.890.052
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debit balance andor short
+market values. The alocation percentage is derived
+
+
+OFFICE SERVICING YOUR ACOOUNT
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+DREYFUS CASH MANAGEMENT-CLA
+EST, 30 DAY A VELD 1.8000%
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+BSMXX
+QUANTITY
+220,450,522.70
+100,000,000
+PRICE
+1.0000
+1.0000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SATLEMENT TAE
+06/11/02
+06/13/02
+06/17102
+TRANSACTION
+DELIVERED
+DELIVERED
+"DELIVERED"
+DESCRIPTION
+LIMITED BRANDS INC
+DEL TO 00005
+LIMITED BRANDS ING
+DEL TO 00005
+"LIMITED" BRANDS" INC
+DEL TO 00005
+MARKET
+VALUE
+439,529
+220,450,523
+100,000,000
+$320,890,052
+ESTIMATED
+ANNUAL INCOME
+3,968,109
+1,780,000
+$5,748,109
+$5,748,109
+$320,890,052
+.800
+....
+1.7800
+SYMBOLCUSP
+LTD
+"LTD
+QUANTITY
+5,000,000
+3,500,000
+2,250,000
+PRICE
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+DEBIT AMOUNT
+99,996,952.36
+71,747,835.04
+45,628,627.79
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+5 ord
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SETTLEMENT TRADE
+DATE
+06/25/02
+06/20/02
+TRANSACTION
+SOLD
+06/27/02 06/24/02 SOLD
+DESCRIPTION
+LIMITED BRANDS INC
+AVG PRICE SHOWN-DETAILS ON REQ
+TUAL CONFIRM TO YOUR AGE
+ISOLICITE
+LIMITED BRANDS INC
+NET PRICE OF $19,30 EQUALS
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTON
+06/01/02
+Ö6/03/02"DMDEND
+06/03/02 REINVEST
+08/12/02 BOUGHT
+08/14/02BOUGHT
+06/18/02 BOUGHT
+06/26/02 BOUGHT
+06/28/02B008HN
+DESCAIPTON
+OPENINGBALANCE
+RETONA SHANAEMENTECLA
+MONTHLY DIVIDEND
+NASSMANGEMENFCTA
+DIVIDEND REINVESTED
+TAKE FORES ME, MONEY
+SE A MANAGEMEN CLA"
+RESTED A MAICEMENT CLA
+SYMBOLGUSP
+LTD
+LTD
+QUANTITY
+-1,900,000
+-3,000,000
+PRICE
+20.50000
+19.30000
+SYMBOUCUSIP
+DICXX
+BMXX
+DICXX
+DiCXx
+DICXX
+QUANTITY
+5,701,881.38
+8.641.32
+100,000,000
+71,740,00
+46,000,00
+39,000,000
+'''58.000,000
+027
+PRICE
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+DEBIT AMOUNT
+38,711,325.10
+57.898,254.71
+$313,982,989.00
+*8,641.32
+1.0000"
+0000*
+0000
+0000
+1:0080
+DEBIT AMOUNT
+8,641.32
+100,000,000.00
+71,740,000.00
+46,000,000.00
+39,000,000.00
+"58,000,000.00
+
+
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MONDAY
+06/28/02
+TOTAL
+TRANSACTION
+DESCRIPTION
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+DESCRIPTION
+06/18/02
+LIMITED BRANDS ING
+1565000000000 SHS
+REC 06/07/02 PAY 06/18/02
+TOTAL
+INTEREST
+DATE
+06/21/02
+TOTAL
+DESCRIPTION
+INTEREST ON CREDIT BALANCI
+T 1 1/4% 05/21 THRU 06/2
+STOP
+****** End of Statement******
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUCUSIP
+SYMBOUCUSIP
+LTD
+QUANTITY
+SYMBOL/CUSIP
+QUANTITY
+QUANTITY
+320,450,522.70
+RATE (S)
+0.0750
+RATE (SI
+1.2500
+027
+PRICE
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+DEBIT AMOUNT
+$-314,748,641.32
+$8.641.32
+DEBIT AMOUNT
+1,173,750.00
+$1,173,750.00
+DEBIT AMOUNT
+CREDIT AMCUNT
+7,648.52
+$7,648.52
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail .................................
+Fund Activity .......•••••••••••••••••IIIIIIIIII/I
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26,2002
+3
+4
+Hollandlold
+HEALTH & SCIENCE INTERESTS II
+TRUST JEFFREY E EPSTEIN TTEE
+DTD 8/18/93
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+328,493.500
+15,142
+5,701,881
+$334,210,523
+.....
+299,146,258
+35,064,265
+Market Value of Your Portfolio
+$5.717.023
+$5.708,758
+Cash & Equivalent
+Equities
+$328,493,500
+$293,437,500
+Current market value
+Last statement's market value
+here are no "Stop Loss' orders or other pending bu
+r sell open orders on file for your accoun
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s foul ratanal purger red de Set revere dise for portant iformation.
+
+
+2 of 5
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 of 5
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited.
+Net Cash Activity
+Closing Balance,
+THIS PERICO
+515,126.18
+8,249.47
+15.75
+$8,265.22
+-8.249.47
+............
+5-8,249.47
+.....
+15.75
+$15,141.93
+Income Summary
+Dividends
+Credit Balance Int.
+Total L
+THIS PERIOD
+8,249.47
+15.75
+$8.265.22
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+15,126.18
+$15,126.18
+CLOSING
+15,141.93
+.........
+$15,141.93
+027
+YEAR TO DATE
+92,879.65
+804.42
+----.
+$93,684.07
+....
+5,717,023
+328,493,500
+$334,210,523
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26,2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+1%
+- Equities
+99%
+Unshaded portions denote debe balance andor short
+
+
+4 of 5
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+DESCRIPTION
+CASH BALANCE
+... .
+DREYFUS CASH MANAGEMENT-CLA
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+LIMITED BRANDS INC
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+DICXX
+QUANTITY
+5,701,881.38
+PRICE
+1.0000
+SYMBCUCUSIP
+LTD
+CASH
+QUANTITY
+15,650,000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26,2002
+MARKET
+VALUE
+15,142
+5,701,881
+$5,717,023
+ESTIMATED
+ANNUAL INCOME
+102,634
+1.8000
+$102,634
+PRICE
+20.9900
+MARKET
+VALUE
+328,493,500
+$328,493,500
+$328,493,500
+ESTIMATED
+ANNUAL INCOME
+4,695,000
+$4,695,000
+$4,695,000
+CURRENT
+YIELD (%)
+1.4293
+$4,797,634
+$334,210,522
+L20
+
+
+5 ors
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+04/27102
+05/01702 DIVIDEND
+05/01/02
+"REINVEST
+..••.
+05/31/02
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+05/21102 AT AT 0421 OR SANCE
+TOTAL
+STOP
+****** End of Statement******
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+OPENINGBALANCE
+PREYFUS CASH MANAGEMENT-CLA
+MONTHLY DIVIDEND
+CLOSINGBALANCE
+SYMBOUCUSIP
+BICXX
+DICXX
+SYMBOL/CUSIP
+QUANTITY
+QUANTITY
+5,693,631.91
+8,249.47
+5,701,881.38
+RATE (N)
+1.2500
+027
+PRICE
+DEBIT AMOUNT
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26,2002
+DEBIT AMOUNT
+8,249.47
+8,249.47
+$-8,249.47
+$8,249.47
+15.75
+$15.75
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .......•••••••••••••••••IIIIIIIIII/I
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28, 2002
+3
+4
+Hollandlold
+HEALTH & SCIENCE INTERESTS II
+TRUST JEFFREY E EPSTEIN TTEE
+DTD 8/18/93
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+293,437,500
+15,126
+5,693,632
+$299,146,258
+287,995,431
+11,150,827
+Market Value of Your Portfolio
+$5,708,758
+$6.970,801
+Cash & Equivalent
+Equities
+$293,437,500
+# S281,024,630
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen is four ratanal pur ye rearde Set revere die for portant iformation.
+
+
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Funds Withdrawn
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERICO
+587.968.21
+867,661.95
+2,110,798.60
+295.02
+.......
+$2.978.755.57
+... . .
+-910,798.60
+-2,140,799.00
+5 3.051,597.60
+-72,842.03
+....
+515,126.18
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+10,798.60
+295.02
+$11.093.62
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+87,968.21
+$87,968.21
+CLOSING
+15,126.18
+......
+$15,126.18
+027
+YEAR TO DATE
+84,630.18
+788.67
+$85,418.85
+5,708,758
+293,437,500
+529.146.258
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+1%
+- Equities
+99%
+Unshaded portions denote debe balance andor short
+
+
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+CASH BALANCE
+... .
+DREYFUS CASH MANAGEMENT-CLA
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+LIMITED ING
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+DICCX
+QUANTITY
+5,693,631.91
+PRICE
+1.0000
+SYMBCUCUSIP
+LTD
+CASH
+QUANTITY
+15,650,000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28, 2002
+MARKET
+VALUE
+15,126
+5,693,632
+$5,708,758
+ANNUAL INCOME
+ESTIMATE CURRENT
+*******•//--.
+108,179
+1.9000
+$108,179
+PRICE
+18.7500
+MARKET
+VALUE
+293,437,500
+$293,437,500
+$293,437,500
+ESTIMATED
+ANNUAL INCOME
+4,695,000
+$4,695,000
+$4,695,000
+CURRENT
+YIELD (%)
+1.6000
+$4,803,179
+$299,146,258
+027
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEEMENT TATE
+DATE
+TRANSACTION
+04/02/02 03/27/02
+SOLD
+DESCRIPTION
+LIMITED ING
+UNSOLICITED
+RULE 144
+TOTAL
+DEPOSITS AND WITHDRAWALS
+DATE
+04/01/02
+TRANSACTION
+FND WIRED
+DESCRIPTION
+* FROM DREYFUS TODAY
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+TRANSACTION
+03/29/02
+04101702 SOLD"
+04/01702 DIVIDEND
+04101702 REINVEST
+04/10/02
+'BOUGHT
+DESCRIPTION
+OPENINGBALANCE
+RETHIONS SHALACEMENTCLA
+SONA SANAGEMENCLA
+MONTHLY DIVIDEND
+RENA MANAGEMENTOLA
+DIVIDEND REINVESTED
+SYMBOL/GUSP
+LTD
+QUANTITY
+49,700
+PRICE
+17.51830
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2002
+DEBIT AMOUNT
+867,661.95
+$867,661.95
+DEBIT AMOUNT
+2,140,799.00
+$-2,140,799.00
+SYMBOUCUSIP
+"DICCX*
+QUANTITY
+6,882,833.31
+'2,100,000
+10,798.60
+900,000
+027
+PRICE
+1.0000
+DEBIT AMOUNT
+'2,100,000.00
+10,798.60
+10,798.60
+
+1.0000
+
+
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MODAY
+04/26/02
+TOTAL
+TRANSACTKN
+DESCRIPTION
+CLOSINGBALANCE
+INTEREST
+DATE
+DESCRIPTION
+04/22/02
+INTEREST ON CREDIT BALANCE
+AT 1 1/4% 03/21 THRU 04/20
+TOTAL
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUCUSIP
+SYMBOL/CUSIP
+QUANTITY
+STOP
+****** End of Statement******
+QUANTITY
+5,693,631.91
+RATE (%)
+1.2500
+027
+PRICE
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2002
+DEBIT AMOUNT
+$-910,798.60
+$2,110,798.60
+DEBIT AMOUNT
+295.02
+$295.02
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+LEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ........................................
+Trades Not Yet Settled
+Your Messages
+.......
+3
+5
+7
+Hollandlold
+HEALTH & SCIENCE INTERESTS II
+TRUST JEFFREY E EPSTEIN TTEE
+DTD 8/18/93
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+281,024,630
+87,968
+6.882.833
+S287,995,431
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+19,368,286
+268,627,145
+here are no "Stop Loss' orders or other pending bu
+r sell open orders on file for your accoun
+Cash & Equivalent
+Equities
+Market Value of Your Portfolio
+$6.970.801
+$6.908,286
+$12,460,000
+Current market value
+Last statement's market value
+$281,024,630
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal purposes rear die Set revere date for portant iformation.
+
+
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited.
+Net Cash Activity
+Closing Balance,
+THIS PERIOD
+535,430.12
+9,977.76
+52,538.09
+$62,515.85
+......
+-9,977.76
+$-9,977.76
+.........
+52,538.09
+87.968.21
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+62,477.76
+38.09
+$62,515.85
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total.
+Cash Balance Summary
+Cash
+OPENING
+35,430.12
+Net Cash Balance
+$35,430.12
+CLOSING
+87,968.21
+$87,968.21
+027
+YEAR TO DATE
+73,831.58
+493.65
+****---.
+$74,325.23
+6,970,801
+281,024,630
+....
+$287,995,431
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+2%
+Equities
+98%
+Unshaded portions denote debe balance andor short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+CASH BALANCE
+... .
+DREYFUS CASH MANAGEMENT-CLA
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+LIMITED ING
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+DICCX
+QUANTITY
+6,882,833.31
+1.0000
+SYMBCUCUSIP
+LTD
+CASH
+QUANTITY
+15,699,700
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+MARKET
+VALUE
+87,968
+6,882,833
+$6.970,801
+STIMATE
+ANUAL INCON
+117,008
+$117,008
+1.7000
+PRICE
+17.9000
+MARKET
+VALUE
+281,024,630
+$281,024,630
+$281,024,630
+ESTIMATED
+ANNUAL INCOME
+4,709,910
+$4,709,910
+$4,709,910
+CURRENT
+YELD (%)
+1.6760
+$4,826,918
+$287,995,431
+120
+
+
+5 of 7
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTEMENT TREE
+03/26/02
+TRANSACTION
+JOURNAL
+03/26/02
+JOURNAL
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+02/23/02
+TRANSACTKN
+03/01702 "BIVIBEND"
+03/01/02 REINVEST
+03/28/02
+TOTAL
+DIVIDENDS
+DATE
+DESCRIPTION
+03/19/02
+LIMITED INC
+REC 03/08/02 PAY 03/19/02
+TOTAL
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+ROME NG
+FROM |
+PER LOA
+SYMBOLCUSP
+LTD
+LTD
+QUANTITY
+4,999,700
+10,000,000
+PRICE
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York: 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+DESCRIFTION
+OPENINGBALANCE
+RATE TONS MANAGEMENTALA
+MONTHLY DIVIDEND
+"DREYFUS CASH MANAGEMENT-CLA
+NSTITUTIONAL SHARE.
+DIVIDEND REINVESTED
+CLOSINGBALANCE
+SYMBOUCUSIP
+*DICEX
+QUANTITY
+6,872,855.55
+9977.76
+6,882,833.31
+PRICE
+SYMBOUCUSIP
+LTD
+QUANTITY
+700,000
+RATE (5)
+0.0750
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+9,977.76
+$-9,977.76
+52,500.00
+$52,500.00
+9,977.76
+$9.977.76
+
+
+6 of 7
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+03/21/02
+INTEREST ON CREDIT BALANCE
+AT 1 1/4% 02/21 THRU 03/20
+TOTAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUCUSIP
+Trades Executed Pending Settlement
+04/02/02
+03/27/02
+TOTAL
+DESCRIPTION
+LIMITED INC
+The above trades do not appear in any other section of this statement.
+QUANTITY
+RATE (%)
+1.2500
+SYMBOL CUSIP
+LTD
+027
+DEBIT AMOUNT
+QUANTITY
+-49,700.00
+PRICE
+17.5183
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+38.09
+$38.09
+DEBIT AMOUNT
+$0.00
+867.661.95
+$867,661.95
+
+
+Bear, Stears & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+Your messages
+13P
+Pursuant to SEC Rule 11Ac1-6, Bear, Stears & Co, Inc will
+ublicly post its quarterly routing statistics at the following web link
+ttp://www.bearstearns.com/corporate/business/equities/orp.htr
+STOP
+****** End of Statement******
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22,2002
+Bear, Stearns Securities Corp, Net Capital and Net Capital
+Requirements:
+At November 30, 2001 and January 31, 2002, the Company's net
+capital of approximately $2,6 billion and $2,6 billion was
+approximately 9% and 8% of aggregate debit items and exceeded
+the minimum regulatory net capital requirement of approximately
+$604.1 million and $648,0 million by approximately $2.0 billion and
+$2.0 billion, all respectively.
+A complete copy of the Bear, Stearns Securities Corp. Statement
+of Financial Condition is available on the web site
+www.bearstearns.com,
+Alternatively, to request a free printed copy
+please call -toll free 1-866-299-9331,
+027
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .....
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 25, 2002
+3
+4
+5
+5
+Hollandlold
+HEALTH & SCIENCE INTERESTS II
+TRUST JEFFREY E EPSTEIN TTEE
+DTD 8/18/93
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+Market Value of Your Portfolio
+$6.908.286
+$6,896.894
+12,460,000
+35,430
+6,872,856
+$19,368,286
+18,551,894
+816,392
+Cash & Equivalent
+Equities
+1 511,65,060
+$12,460,000
+Current market value
+Last statement's market value
+ere are no "Stop Loss" orders or other pending bu
+r sell open orders on file for your accoun
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal furycer rear die Set revere date for portant iformation.
+
+
+2 of 5
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 of 5
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance,
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+$35,392.04
+....
+11,353.82
+38.08
+51.391.00
+-11,353.82
+$-11,353.82
+....
+38.08
+35,430.1:
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+11,353.82
+38.08
+.$11.391.90
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+total.
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+35,392.04
+$35,392.04
+CLOSING
+35,430.12
+$35,430.12
+027
+YEAR TO DATE
+11,353.82
+455.56
+....
+$11,809.38
+_...
+6,908,286
+12,460,000
+519,368,286
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 25, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+36%
+Equities
+64%
+Unshaded portions denote debe balance andor short
+
+
+4 of 5
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+CASH BALANCE
+. . . .
+DREYFUS CASH MANAGEMENT-CLA
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+LIMITED ING
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+DICCX
+QUANTITY
+6,872,855.55
+PRICE
+1.0000
+SYMBCUCUSIP
+LTD
+CASH
+QUANTITY
+700,000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 25, 2002
+MARKET
+VALUE
+35,430
+6,872,856
+$6,908,286
+ESTIMATED
+ANNUAL INCOME
+*******•//--.
+137,457 2.0000
+$137,457
+PRICE
+17.8000
+MARKET
+VALUE
+12,460,000
+$12,460,000
+$12,460,000
+$347,457
+$19,368,286
+ESTIMATED
+ANNUAL INCOME
+210,000
+$210,000
+$210,000
+CUARENT
+YIELD (SI
+1.6854
+027
+
+
+5 ors
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+TRANSACTION
+01/26/02
+ö2/01702"DIVDEND
+02/01/02
+"REINVEST
+.....
+02/22/02
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+0221/02 AT 11/% 121 THRU 02ANCE
+TOTAL
+STOP
+****** End of Statement******
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+OPENINGBALANCE
+PREYFUS CASH MANAGEMENT-CLA
+MONTHLY DIVIDEND
+CLOSINGBALANCER
+SYMBOUCUSIP
+DICCX
+SYMBOL/CUSIP
+QUANTITY
+QUANTITY
+6,861,501.73
+11,353.82
+6,872,855.55
+RATE (%)
+1.2500
+027
+PRICE
+DEBIT AMOUNT
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 25,2002
+DEBIT AMOUNT
+11,353.82
+11,353.82
+$-11,353.82
+$11,353.82
+38.08
+$38.08
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .•••••••••••••••••••I/I/
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .....
+Your Messages
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+3
+Hollandlold
+HEALTH & SCIENCE INTERESTS II
+TRUST JEFFREY E EPSTEIN TTEE
+DTD 8/18/93
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+6
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+11,655.000
+35,392
+6,861,502
+$18,551,894
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+17,272,750
+1,279,144
+There are no "Stop Loss' orders or other pending buy
+or sell open orders on file for your account
+Market Value of Your Portfolio
+$6.896.894
+$6.968.750
+Cash & Equivalent
+Equities
+$11,655,000
+$10,304,000
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen is four or ratanal purpose red de Set revere dae for portant iformation.
+
+
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Funds Withdrawn
+mount Debited
+************
+Net Cash Activity
+Closing Balance
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERIOD
+3534.974.56
+107,726.49
+417.48
+$108,143.97
+•........
+-17,726.49
+-90,000.00
+... 107.72649
+417.48
+฿35.392.04
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+34,974.56
+$34,974.56
+Income Summary
+THIS PERIOD
+Credit Balance Int.
+Total
+417.48
+5417.48
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+CLOSING
+35,392.04
+50.39200
+YEAR TO DATE
+417.48
+541-48
+6,896,894
+11,655,000
+518.551.894
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent
+38%
+Equities
+62%
+Unshaded portions denote debe balance andor short
+
+
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+CASH BALANCE
+.......
+DREYFUS CASH MANAGEMENT-CLA
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+LIMITED ING
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+DICCX
+QUANTITY
+6,861,501.73
+PRICE
+1.0000
+SYMBCUCUSIP
+LTD
+CASH
+QUANTITY
+700,000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+MARKET
+VALUE
+35,392
+6,861,502
+$6,896,894
+ESTIMATED
+ANNUAL INCOME
+144,092 2.1000
+$144,092
+PRICE
+16.6500
+MARKET
+VALUE
+11,655,000
+$11,655,000
+$11,655,000
+ESTIMATED
+ANNUAL INCOME
+210,000
+$210,000
+$210,000
+CURRENT
+YIELD (%)
+1.8018
+$354,092
+$18,551,894
+027
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+5 or 8
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+01/09/02
+TRANSACTION
+FND WIRED
+DESCRIPTION
+MASE NEARN BANKIRED TO
+ACO-
+$ COMING FROM DREYFUS TODAY
+TOTAL
+MONEY FUND ACTIVITY
+MILAY
+TRANSACTION
+01/01/02
+01/02/02
+'*REINVEST
+DESCAIPTION
+OPENINGBALANCE
+RHETONA MANAGEMENT CLA
+DIVIDEND REINVESTED
+07702/02 DIVIDEND
+01709/02
+''''SOLD
+•••••••/•••••
+01/25/02
+TOTAL
+PRETENDS MANAGEMENTEC A
+CLOSINGBALANCER
+INTEREST
+DATE
+DESCRIPTION
+01/22/02
+NTEREST ON CREDIT BALANC
+T 1 1/4% 12/31 THRU 01/2
+SYMBOL/CUSIP
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+DEBIT AMOUNT
+90,000.00
+$-90,000.00
+SYMBOUCUSIP
+BICCX
+QUANTITY
+6,933,775.24
+17,726.49
+90,000
+6,861,501.73
+PRICE
+DEBIT AMOUNT
+17,726.49
+1.0000
+17,726.49
+90,000.00
+51071726-49
+QUANTITY
+RATE (SI
+1.2500
+027
+DEBIT AMOUNT
+$-17,726.49
+CAEDIT AMOUNT
+25.50
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+INTEREST (continued)
+DATE
+DESCRIPTION
+01/22/02
+INTEREST ON CREDIT BALANCE
+AT 1 1/4% 12/21 THRU 12/30
+TOTAL
+SYMBOUCUSIP
+Your messages
+The interest, if any, charged to your account during December
+2001 was computed on the net debit balance through December 30.
+The impuls, ram Deaner 31, zr account during January 2002
+STOP
+****** End of Statement******
+QUANTITY
+RATE (%)
+1.2500
+027
+DEBIT AMOUNT
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HEALTH & SCIENCE INTERESTS II
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+391.98
+$417.48
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/bf1e31c6a4607482854d68714b224987b0c7205862015971c3e951a97f9ed3bb.receipt.json b/vision-fixhub/ds9-unparsed-05/bf1e31c6a4607482854d68714b224987b0c7205862015971c3e951a97f9ed3bb.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4c1f96eafb1638def3de7f35e742b3d83af2e36e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bf1e31c6a4607482854d68714b224987b0c7205862015971c3e951a97f9ed3bb.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -7852,
+  "dataset": "marble-joined",
+  "doc_id": "bf1e31c6a4607482854d68714b224987b0c7205862015971c3e951a97f9ed3bb",
+  "engine": "marble-apple-vision",
+  "event_count": 85,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "ca517617cf967e26b73c379c6e24d2f9ef1d165aca549c87f4e4e944f85e136d",
+  "output_sha256": "209501dc7f0757d87c01fac6398fc9b144a023b5a4321e5d73fe7cd28d76f3d5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/bf91bd13dd2b72a8bdaee7196e9c4e1618efe247817259ba26d024aa73b4a1a3.md b/vision-fixhub/ds9-unparsed-05/bf91bd13dd2b72a8bdaee7196e9c4e1618efe247817259ba26d024aa73b4a1a3.md
new file mode 100644
index 0000000000000000000000000000000000000000..f40695bb313c61885fcdcf69f2ad5d3581b0210c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bf91bd13dd2b72a8bdaee7196e9c4e1618efe247817259ba26d024aa73b4a1a3.md
@@ -0,0 +1,68 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+DELIVERY BY HAND
+Ms.
+August 15, 2007
+Re: Grand Jury Investigation-Confidential
+This letter is an invitation for you to testify before a federal Grand Jury, and is supplied in order to
+provide yethel perks oin the Southem Distric or florida. This theid responsity of inguire into
+federal crimes which may have been committed in this District.
+As a Grand Jury witness you will be asked to testify and answer questions under oath, and to
+produce records and documents. Only the members of the Grand Jury, attorneys for the United States
+and a stenographer are permitted in the Grand Jury room while you testify.
+The U.S. Department of Justice encourages prosecutors to notify an individual in appropriate
+cases that he or she is a target of a grand jury investigation. Accordingly, you are hereby notified that you
+are a target of a federal grand jury investigation in the Southern District of Florida concerning suspected
+violations of federal law, including but not limited to, possible violations of Title 18, United States Code,
+Sections 2, 371, 1512, 1591, 1952, 1956, 1960, 2421, 2422, and 2423.
+You are advised that the destruction or alteration of any document required to be produced before
+the grand jury constitutes serious violation of federal law, including but not limited to Obstruction of
+A "target" is a person as to whom the prosecutors or the Grand Jury have substantial evidence
+linking him or her to the commission of a crime and who, in the judgment of the prosecutors, is a putative
+defendant.
+This letter constitutes an invitation to you to testify on your own behalf before the grand jury
+about matters under investigation. Of course, you are not required to appear before the grand jury. The
+decision whether to do so is a voluntary matter which is entirely up to you. The grand jury, if
+in fact it learns of this opportunity afforded to you, will be instructed not to draw any adverse inference
+from your failure to appear should you decide not to accept this invitation. You must further understand
+that should you decide to testify, your testimony could be used against you if any
+Ms.
+August 15, 2007
+Page 2
+criminal charges should be filed against you.
+Should you decide to appear before the grand jury, you will have the same rights and obligations as any
+non-immunized grand jury witness. Specifically,
+You may refuse to answer any question if a truthful answer to the question would tend to
+incriminate you.
+You have the right to stop answering questions at any time.
+Anything you say may be used against you at the grand jury or in a subsequent legal proceeding.
+The grand jury will permit you a reasonable opportunity to step outside the grand jury room to
+consult with your attorney, if you so desire, at any point during the testimony you give.
+Please be further advised that the giving of false testimony before the grand jury will subject you to a
+prosecution for perjury in addition to the violations set forth above.
+As a target of a grand jury investigation who has been asked to appear before the grand jury, you may
+wish to retain the services of an attorney. If you cannot afford the services of independent counsel, the Court
+may be able to appoint counsel to represent you. If you would like the United States to ask the Court to appoint
+an attorney to represent you, please contact the undersigned at
+The United States is investigating
+other individuals, and you may be interested in cooperating with the United States against those other targets. If
+
+
+you hire an attorney, or if the Court appoints one to represent you, that counsel can contact me to discuss that
+possibility.
+Please advise me whether you wish to testify before the grand jury by close of business Friday, August
+31, 2007. IfI do not receive notification from you'or your counsel by this date, I will assume that you do not
+wish to testify before the grand jury.
+Sincerely,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+Assistant United States Attorney
+Ms.
+August 15, 2007
+Page 3
+bee:
diff --git a/vision-fixhub/ds9-unparsed-05/bf91bd13dd2b72a8bdaee7196e9c4e1618efe247817259ba26d024aa73b4a1a3.receipt.json b/vision-fixhub/ds9-unparsed-05/bf91bd13dd2b72a8bdaee7196e9c4e1618efe247817259ba26d024aa73b4a1a3.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7bbd4d3d11359c0972cb5d0c8aa84d6251dc3b77
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bf91bd13dd2b72a8bdaee7196e9c4e1618efe247817259ba26d024aa73b4a1a3.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "bf91bd13dd2b72a8bdaee7196e9c4e1618efe247817259ba26d024aa73b4a1a3",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "07742818843fd16f81299695c322b791e392bb35088b4db73c762c09d1fd8617",
+  "output_sha256": "34370947d402db209e5135f5171079127f90322c535ffd952f859f240ca50ee4",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/bf9bc7280cd3bcfddb2f1f9dffde9b15544dbd38a0b46715c9520ec612e1312f.md b/vision-fixhub/ds9-unparsed-05/bf9bc7280cd3bcfddb2f1f9dffde9b15544dbd38a0b46715c9520ec612e1312f.md
new file mode 100644
index 0000000000000000000000000000000000000000..064ce8c1b3f2df0d4294efe7aae07c7843e52e83
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bf9bc7280cd3bcfddb2f1f9dffde9b15544dbd38a0b46715c9520ec612e1312f.md
@@ -0,0 +1,3470 @@
+Statements
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summary .......
+....
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ..........................................
+Your Messages
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD December 1, 2005
+THROUGH
+December 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30,2005
+3
+4
+5
+5
+6
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+MONEY MARKET FUND BALANCE
+651,800
+74,046
+$725,846
+NET EQUITY THIS PERIOD
+•....
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+This portfolio indudes one or more unpriced securties that are no
+fected in the Total Value of Securtes and the Net Equity This Perio
+685,268
+40,578
+Market Value of Your Portfolio
+$74,046
+$72,068
+Cash & Equivalent
+Equities
+$651,800
+$613,200
+-...
+Current market value
+Last statement's market value
+If any information regarding
+2005interest, dividends,
+miscellaneous income, gross
+proceeds or original issue
+discount is required to be
+reported to the IRS for this
+account, a Consolidated Form
+1099will be mailed to you by
+January 31,2006or a 1042S
+by March 15,2006.
+The are rep one for or a her pending buy
+Flease report any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal furyce red de Set revere date for portant iformation.
+027
+v999
+
+
+2 of 6
+EARED THROUGH I
+OLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance.
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+228.25
+1,750.00
+$1,978.25
+-1,978.25
+5-1,978.25
+.. . ..
+50.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+1,978.25
+51.978.25
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+YEAR TO DATE
+16,676.24
+*••••••••
+......
+$16.676.24..
+74,046
+651,800
+.. . . .
+$725,846
+12/31/05:09:00001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD December 1, 2005
+THROUGH
+December 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30,2005
+Your Portfolio
+Allocation
+Cash & Equivalent
+10%
+Sauties
+Unshaded portions denole debe balance andor short
+market values. The alocation percentago is derived
+from the absolute market value of your portollo.
+
+
+4 of 8
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD December 1, 2005
+THROUGH
+December 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30,2005
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST. 30 DAY AVG YIELD 4.1100%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+QUANTITY
+74,046.27
+FRICE
+1.0000
+MARKET
+VALUE
+74,046
+$74,046
+ESTIMATED
+CURRENT
+ANNUAL INCOME
+2,814
+3.8003
+$2,814
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the Firm's Equity Research Department, The first rating represents the stock's total
+retur relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O= Outperform; P = Peer Perform; U = Underperform, The second
+rating represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW =
+Market Weight; MU = Market Underweight, In cases where a BSC rating is present, the name of an independent, third-party research provider and their rating may also be
+displayed, where such research is available. The various providers have normalized their ratings systems as follows: B = Buy; H = Hold; S = Sell, The ratings information
+contained herein is for informational purposes only and is not intended to provide tax, legal or investment advice, Bear Stearns is neither soliciting any action based on such
+information, nor endorsing any recommendation or opinion expressed by any independent, third-party research provider. The symbol indicates that continuing coverage of
+the subject company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost, Customers can access this research
+at www.bearstearns.com or can call (800) 517-2327 to request that a copy of this research be sent to them,
+DESCRIPTION
+ABERCROMBIE & FITCH CO-CLA
+BSC RATING: STOCK O/SECTOR MW
+CATHAY FINANCIAL, INC
+RATING: B
+SYMBOUCUSIP
+ANF
+CASH
+QUANTITY
+10,000
+PRICE
+65.1800
+651,800
+7,000
+ELD 1%
+1.0739
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+BPIBY
+CASH
+20,000
+Unpriced
+$651,800
+$651,800
+027
+
+
+5 or 8
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+MONEY FUND ACTIVITY
+TRANSACTION
+12/01/05
+i2/01/05
+"DIViDEND
+12/01/05
+REINVEST
+12/20/05
+BOUGHT
+12/30/05
+TOTAL
+DESCAIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT-CLA
+ISTITUTIONAL SHARE
+IVIDEND REINVES
+*DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+CLOSINGBALANCE
+SYMBOLCUSIP
+DICXX
+DICXX
+DICXX
+$9,814
+$725,846
+QUANTITY
+72,068.02
+228.25
+1,750
+74,046.27
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD December 1, 2005
+THROUGH
+December 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30, 2005
+PRICE
+DEBIT AMOUNT
+CREDIT AMOUNT
+228.25
+1.0000
+228.25
+1,750.00
+$-1,978.25
+$228.25
+
+
+6 of B
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+DIVIDENDS
+
+DESCRIPTION
+TOTAL
+SYMBOUCUSIP
+ANF
+QUANTITY
+10,000
+Your messages
+As part of the National Association of Securities Dealer's (NASD) Investor
+Education Program, you may obtain information on the NASD's Public
+Disclosure Program by contacting the NASD at telephone number
+(800) 289-9999 or via the internet address which is www.nasdr.com, In
+addition, a brochure explaining the Public Disclosure Program is available from
+STOP
+****** End of Statement******
+RATE (S)
+0.1750
+027
+DEBIT AMOUNT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD December 1, 2005
+THROUGH
+December 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30,2005
+CREDIT AMOUNT
+1,750.00
+$1,750.00
+12/31/05:09:00001
+v999
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings ...........................
+Transaction Detail .................................
+Fund Activity .......••••••••••••••••••••III••IIII
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD November 1, 2005
+THROUGH
+November 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31,2005
+3
+4
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+MONEY MARKET FUND BALANCE
+613.200
+72,068
+NET EQUITY THIS PERIOD
+$685,268
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+591,746
+93.522
+"This portfolio indudes one or more unpriced securtles that are not
+relected in the Total Value of Securites and the Net Equity This Period
+Market Value of Your Portfolio
+672,06/
+71,846
+Cash & Equivalent
+Equities-
+$613,200
+} $519,900
+......
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Please report any difference or non-receipt of checks or stocks, indicaled as delivered to you,
+1o Client Services at 800-634-1428: or write to Cien Services at Bear, Steams Securities
+Corp., One Metrotech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four erratanal purger red die Set revere dae for portant iformation.
+12/01/05:07:35 001
+4999
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+4999
+
+
+3 or 5
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+221.76
+$221.76
+-221.76
+5-221.76
+"....
+$0.00
+Income Summary
+THIS PERIOD
+Dividends
+221.76
+Total
+$221.76
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+YEAR TO DATE
+14,697.99
+*----------..
+$14,697.99
+72,068
+613,200
+
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD November 1, 2005
+THROUGH
+November 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31,2005
+Your Portfolio
+Allocation
+Cash & Equivalent
+10%
+Equities
+90%
+Unshaded portions denote debe balance andor short
+
+
+4 of 5
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD November 1, 2005
+THROUGH
+November 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31,2005
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+EST, 30 DAY AVG YIELD 3,9000%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+DICXX
+QUANTITY
+72,068.02
+PRICE
+1.0000
+MARKET
+VALUE
+72,068
+$72,068
+MAURE NOONE
+CURRENT
+2,667
+YIELD IN
+3.7007
+$2,667
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the Firm's Equity Research Department, The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform, The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+= Market Underweight, In cases where a BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers have normalized their ratings systems as follows: B = Buy; H = Hold; S = Sell, The ratings information contained herein
+is for informational purposes only and is not intended to provide tax, legal or investment advice, Bear Stearns is neither soliciting any action based on such information, nor
+endorsing any recommendation or opinion expressed by any independent, third-party research provider, The symbol indicates that continuing coverage of the subject
+company is temporarily not available due to legal reasons.
+tw, beastars com sahal (0) 517-2327 1 regred that a Copy of is rh a be set to tomers of Bear Stearns at no cost. Customers can access this research
+MARKET
+DESCRIPTION
+SYMBCUCUSIP
+QUANTITY
+PRICE
+VALUE
+ANNUAL NOME
+ABERCROMBIE & FITCH CO-CLA
+ANF
+CASH
+10,000
+61.3200
+613,200
+7,000
+1.1416
+BSC RATING: STOCK O/SECTOR MW
+CATHAY FINANCIAL, INC.
+......
+BANPAIS SA-SPONSOREDADR
+BPIBY
+CASH
+20,000
+Unpriced
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+$613,200
+$613,200
+027
+12/01/05:07:35 001
+vase
+
+
+5 or5
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+MONEY FUND ACTIVITY
+PAIDAY
+11/01/05
+TRANSACTON
+11.01/05
+DIVIDEND
+11/01/05
+REINVEST
+DESCRIPTION
+OPENINGBALANCER
+SYMBOUCUSIP
+DICXX
+DICXX
+DREYFUS CASH MANAGEMENT. CLA
+INSTITUTIONAL SHARES
+DIVIDEND REINVEST
+CLOSINGBALANCE
+11/30/05
+TOTAL
+$9,667
+$685,268
+QUANTITY
+71,846.26
+221.70
+72,068.02
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD November 1, 2005
+THROUGH
+November 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31,2005
+PRICE
+DEBIT AMOUNT
+CREDIT AMOUNT
+221.76
+221.76
+$-221.76
+$221.76
+v99e
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings ...........................
+Transaction Detail .................................
+Fund Activity .......••••••••••••••••••••III••IIII
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD October 1,2005
+THROUGH
+October 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2005
+3
+4
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+519,900
+71,846
+$591,746
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+569,504
+22.242
+"This portfolio indudes one or more unpriced securties that aro not
+relected in the Total Value of Securites and the Net Equity This Period
+Market Value of Your Portfolio
+$71,846
+$71,004
+Cash & Equivalent
+Equities
+S498,500
+$519,900
+......
+Current market value
+Last statement's market value
+ere are no "Stop Loss" orders or other pending b
+sell open orders on file for your accour
+Please report any difference or non-receipt of checks or stocks, indicaled as delivered to you,
+1o Client Services at 800-634-1428: or write to Cient Services at Bear, Steams Securities
+Corp., One Metrotech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four erratanal purposes rear de Set revere date for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or 5
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+....
+842.68
+$842.68
+-842.68
+-842.68
+$0.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+842.68
+$842.68
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+YEAR TO DATE
+14,476.23
+......
+514.476.23.
+71,846
+519,900
+$591.746....
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD October 1,2005
+THROUGH
+October 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2005
+Your Portfolio
+Allocation
+Cash & Equivalent-
+13%
+- Equities
+87%
+Unshaded portions denote debit balance and or shart
+
+
+4 of 5
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD October 1,2005
+THROUGH
+October 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2005
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CL A
+NSTITUTIONAL SHARES
+EST, 30 DAY AVG YIELD 3,7500%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+DICXX
+QUANTITY
+71,846.26
+PRICE
+1.0000
+MARKET
+VALUE
+71,846
+$71,846
+MALE MAED
+CURRENT
+YELD IN
+2,443 3.4003
+$2,443
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the Firm's Equity Research Department, The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform, The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+= Market Underweight, In cases where a BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers have normalized their ratings systems as follows: B = Buy; H = Hold; S = Sell, The ratings information contained herein
+is for informational purposes only and is not intended to provide tax, legal or investment advice, Bear Stearns is neither soliciting any action based on such information, nor
+endorsing any recommendation or opinion expressed by any independent, third-party research provider, The symbol indicates that continuing coverage of the subject
+company is temporarily not available due to legal reasons.
+tw, beastars com sahal (0) 517-2327 1 regred that a Copy of sis rehear be set to tomers of Bear Stearns at no cost. Customers can access this research
+MARKET
+DESCRIPTION
+SYMBCUCUSIP
+QUANTITY
+PRICE
+VALUE
+AHMET NOME
+ABERCROMBIE & FITCH CO-CLA
+ANF
+CASH
+10,000
+51.9900
+519,900
+7,000
+1.3464
+BSC RATING: STOCK O/SECTOR MW
+CATHAY FINANCIAL, INC.
+......
+BANPAIS SA-SPONSOREDADR
+BPIBY
+CASH
+20,000
+Unpriced
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+$519,900
+$519,900
+027
+
+
+5 or5
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+MONEY FUND ACTIVITY
+PAIDAY
+10/01/05
+10/03/05
+
+10/31/05
+TOTAL
+TRANSACTON
+DIVIDEND
+REINVEST
+DESCRIPTION
+OPENINGBALANCER
+SYMBOU/CUSIP
+DICXX
+VICX
+DREYFUS CASH MANAGEMENT CLA
+INSTITUTIONAL SHARES
+DIVIDEND REINVEST
+CLOSINGBALANCE
+$9,443
+$591,746
+QUANTITY
+71,003.58
+342.6
+71,846.26
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD October 1,2005
+THROUGH
+October 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2005
+PRICE
+DEBIT AMOUNT
+CREDIT AMOUNT
+842.68
+842.68
+$-842.68
+$842.68
+4997
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings ............................
+Transaction Detail
+Fund Activity ...................../...................
+Your Messages •............•...................
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD September 1, 2005
+THROUGH
+September 30,2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31,2005
+3
+6
+7
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+498.500
+71,004
+$569,504
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+667,544
+-98.040
+"This portfolio indudes one or more unpriced securties that are not
+relected in the Total Value of Securties and the Net Equity This Period
+Market Value of Your Portfolio
+$71,004
+Cash & Equivalent -
+Equities -
+$667.544
+$0
+$498,500
+......
+Current market value
+Last statement's market value
+ere are no "Stop Loss" orders or other pending b
+sell open orders on file for your accour
+Please report any difference or non-receipt of checks or stocks, indicaled as delivered to you,
+1o Client Services at 800-634-1428: or write to Cient Services at Bear, Steams Securities
+Corp., One Metrotech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four ratanal purger red die Set revere dae for portant iformation.
+v996
+
+
+2 of 8
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+10/01/05:11:50 001
+
+
+3 ora
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Securities Bought
+Money Fund
+Funds Withdrawn
+nount Debite
+Closing Balance
+THIS PERICO
+$0.00
+600,269.41
+$600,269.41
+-548,405.00
+-1,864.41
+-50,000.00
+$ 600.269.41
+$0.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+1,864.41
+$1.864.41
+Portfolio Composition
+Cast/Cash Equivalent
+Equities
+Total
+027
+YEAR TO DATE
+13,633.55
+______....
+$13,633.55
+71,004
+498,500
+
+10/01/05:11:50001
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD September 1, 2005
+THROUGH
+September 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31,2005
+Your Portfolio
+Allocation
+Cash & Equivalent-
+13%
+- Equities
+87%
+Unshaded portions denote debit balance and or shart
+
+
+4 of a
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD September 1, 2005
+THROUGH
+September 30,2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31, 2005
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+EST, 30 DAY AVG YIELD 3,6200%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+DICXX
+QUANTITY
+71,003.58
+PRICE
+1.0000
+MARKET
+VALUE
+71,004
+$71,004
+MAURE NOONE
+CURRENT
+YELD IN
+2,414
+3.3998
+$2,414
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the Firm's Equity Research Department, The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform, The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+= Market Underweight, In cases where a BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers have normalized their ratings systems as follows: B = Buy; H = Hold; S = Sell, The ratings information contained herein
+is for informational purposes only and is not intended to provide tax, legal or investment advice, Bear Stearns is neither soliciting any action based on such information, nor
+endorsing any recommendation or opinion expressed by any independent, third-party research provider, The symbol indicates that continuing coverage of the subject
+company is temporarily not available due to legal reasons.
+dependent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost, Customers can access this researc
+t www.bearsteams.com or can call (800) 517-2327 to request that a copy of this research be sent to ther
+MARKET
+DESCRIPTION
+SYMBOUCUSIP
+QUANTITY
+PRICE
+VALUE
+ABERCROMBIE & FITCH CO-CLA
+ANF
+CASH
+10,000
+49.8500
+498,500
+7,000
+1.4042
+BSC RATING: STOCK P/SECTOR MW
+CATHAY FINANCIAL, INC.
+......
+BANPAIS SA-SPONSOREDADR
+BPIBY
+CASH
+20,000
+Unpriced
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+$498,500
+$498,500
+027
+
+
+5 or8
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SELEMEN TRADE
+TRANSACTION
+09/12/05 09/07/05
+BOUGHT
+TOTAL
+DEPOSITS AND WITHDRAWALS
+DESCRIPTION
+ABERCROMBIE & FITCH CO-CLA
+UNSOLICITED
+DATE
+09/20/05
+TRANSACTION
+FND WIRED
+DESCRIPTION
+MDA#|
+INDS WIRED TO
+HPMORGENRCASE BANK, NA
+FD#02822
+TOTAL
+$9,414
+$569,504
+SYMBOUCUSP
+ANF
+QUANTITY
+10,000
+PRICE
+54.78000
+DEBIT AMOUNT
+50,000.00
+$-50,000.00
+CREDIT AMOUNT
+027
+10/01/05:11:50001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD September 1, 2005
+THROUGH
+September 30,2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31, 2005
+DEBIT AMOUNT
+548,405.00
+$-548,405.00
+CREDIT AMOUNT
+
+
+6 of a
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+09/01/05
+09/01/05
+DIVIDEND
+09/01/05
+REINVEST
+09/12/05
+*SOLD
+09/20/05
+SOLD
+09/30/05
+TOTAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCAIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT-CL A
+MONTHLY DIA ENARES
+DREYFUS CASH MANAGEMENT-CLA
+NSTITIONA SHARACEMENT-CLA
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+CLOSINGBALANCE
+SYMBOUGUSIP
+DICXX
+DICXX
+DICXX
+DICXX
+QUANTITY
+667,544.17
+1,864.41
+-548,405
+-50,000
+71,003.58
+027
+PRICE
+1.0000
+1.0000
+10/01/05:11:50 001
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD September 1, 2005
+THROUGH
+September 30,2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31, 2005
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,864.41
+1,864.41
+548,405.00
+50,000.00
+$-1,864.41
+$600,269.41
+
+
+7 of 8
+Bear, Stearns & Co. Ind
+383 Madison Avenue
+New York, New York 10179
+Your messages
+Bear, Stearns Securities Corp, Net Capital and Net Capital Requirements:
+A complete copy of the Bear, Stearns Securities Corp, Statement of Financial
+Condition is available on the web site www.bearstearns.com, Alternatively, to
+request a free printed copy please call - toll free 1-866-299-9331.
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD September 1, 2005
+THROUGH
+September 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+August 31,2005
+18P
+Securities and other assets in your account are the firm's collateral for any
+margin loan made to you. If the securities and other assets in your account
+decline in value, so does the value of the collateral supporting your loan, and,
+as a result, the firm can take action, such as issue a margin call and/or sell
+securities or other assets in any of your accounts held with the member, in
+order to maintain the required equity in the account. It is important that yo
+ully understand the risks involved in trading securities on margin, These risk
+include the following:
+- You can lose more funds than you deposit in the margin account,
+- The firm can force the sale of securities or other assets in your accounts).
+- The firm can sell your securities or other assets without contacting you.
+- You are not entitled to choose which securities or other assets in your
+accounts) are liquidated or sold to meet a margin call.
+- The in ancrease ta to alienance air nairement a ny
+- You are not entitled to an extension of time on a margin call.
+027
+
+
+8 of 8
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+This statement is provided to explain Bear, Stearns & Co. Inc, 's ("BSC")
+payment for order flow practices.
+formulas at better than the national best bid or best offer (NBBO), BSC
+receives no cash payment or other consideration for such order routing other
+than favorable executions or executions of limit orders at no additional charge.
+STOP
+****** End of Statement******
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD September 1, 2005
+THROUGH
+September 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+August 31, 2005
+Pursuant to SEC Rule 11Ac1-6, please note the following:
+Bear, Steams & Co, Inc, will post its quarterly routing statistics at the following
+web link: http://www.bearstearns.com/, Click on Individual Investor, Click on
+Equities, Click on Order Routing Practices.
+Customers of Bear, Stearns & Co. Inc, may request information on any order
+executed within the prior six months from the time of the request. Specifically,
+you may request the identity of the venue to which the identified orders were
+routed for execution, whether the order was directed by you to that venue, and
+the time of the executions, if any, that resulted from such orders.
+027
+10/01/05:11:50 001
+v996
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings ............................
+Transaction Detail .................................
+Fund Activity ...................../...................
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD July 30,2005
+THROUGH
+August 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 29,2005
+3
+4
+4
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+MONEY MARKET FUND BALANCE
+667,544
+NET EQUITY THIS PERIOD
+$667,544
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+665,772
+1,772
+the per he Toal ate of Bauties and 20 is quay is Perica
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+....
+.....
+$667.544
+$665,772
+Current market value
+Last statement's market value
+Please report any difference or non-receipe of checks or stocks, indicated as delivered to you,
+1o Client Services at 800-634-1428: or write to Cient Services at Bear, Steams Securities
+Corp., One Metrotech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four ratanal purger red de Set revere date for portant iformation.
+V895
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 of5
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERICO
+$0.00
+1,772.51
+$1,772.51
+-1,772.51
+$-1.772.51
+$0.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+1,772.51
+.$1.772.51
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+YEAR TO DATE
+11,769.14
+$11,769.14.
+667,544
+$667,544
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+NSTITUTIONAL SHARE
+ST. 30 DAY AVG YIELD 3,3400%
+TOTAL CASH & CASH EQUIVALENTS
+SIMBOL CUSIP
+DICXX
+QUANTITY
+667,544.17
+PRICE
+1.0000
+MARKET
+VALUE
+667,544
+$667,544
+ESTIMATED
+CURRENT
+ANNUAL INCOME
+21,361
+YELD (%)
+3.1999
+$21,361
+027
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD July 30,2005
+THROUGH
+August 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 29,2005
+Your Portfolio
+Allocation
+Cash & Equivalent
+Unshaded portions denole debit balance andor short
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+4 of 5
+Your Portfolio Holdings (continued)
+EQUITIES
+Equities & Options
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear
+Stearns at no cost, Customers can access this research at www.bearstearns,com or can call (800) 517-2327 to request
+that a copy of this research be sent to them.
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOUCUSIP
+BPIBY
+CASH
+QUANTITY
+20,000
+PRICE
+Unpriced
+$0
+$0
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+$21,361
+$667,544
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD July 30,2005
+THROUGH
+August 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+Juty 29,2005
+AMAN NOTED
+$0
+$0
+CURRENT
+YELD IN
+Transaction Detail
+MONEY FUND ACTIVITY
+MADAY
+TRANSACTION
+07/30/05
+08/01/05
+'DIVIDEND
+DESCRIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT CLA
+MONTHLY DID ENARES
+SYMBOUGUSIP
+DiCX
+QUANTITY
+665,771.66
+PRICE
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,772.51
+027
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+TRANSACTION
+08/01/05
+REINVEST
+DESCAIPTION
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+DIVIDEND REINVEST
+CLOSINGBALANCE
+SYMBOUCUSIP
+DICXX
+08/31/05
+TOTAL
+STOP
+****** End of Statement******
+QUANTITY
+1,772.51
+667,544.17
+027
+PRICE
+LEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD July 30,2005
+THROUGH
+August 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 29,2005
+DEBIT AMOUNT
+1,772.51
+CREDIT AMOUNT
+$-1,772.51
+$1.772.51
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings ...........................
+Transaction Detail ..................................
+Fund Activity ............../....../....................
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOO July 1,2005
+THROUGH
+July 29, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 30, 2005
+3
+4
+4
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+MONEY MARKET FUND BALANCE
+665.772
+NET EQUITY THIS PERIOD
+$665,772
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+664,165
+1,607
+a portfolio indudes ono or more unpriced securtes that are
+acted in the Total Value of Securtes and the Not Eguty This Per
+Market Value of Your Portfolio
+Cash & Equivalent
+....
+.....
+$665.772
+$664,165
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Please report any difference or non-receipe of checks or stocks, indicated as delivered to you,
+1o Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrotech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four ratanal purger red de Set revere date for portant iformation.
+07/30/05;10:09 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+07/30/05:10:09 001
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+1,607.05
+$1,607.05
+-1,607.05
+S-1.607.05
+$0.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+1,607.05
+.$1.607.05
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+YEAR TO DATE
+9,996.63
+... ..
+$9.996.63...
+665,772
+$665,772
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+NSTITUTIONAL SHARE
+ST. 30 DAY AVG YIELD 3,2000%
+TOTAL CASH & CASH EQUIVALENTS
+SIMBOL CUSIP
+DICXX
+QUANTITY
+665,771.66
+PRICE
+1.0000
+MARKET
+VALUE
+665,772
+$665,772
+ESTIMATED CURRENT
+ANNUAL INCOME
+19,307
+YELD (%)
+2.8999
+$19,307
+027
+07/30105;10:09 001
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOO July 1,2005
+THROUGH
+July 29, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 30, 2005
+Your Portfolio
+Allocation
+Cash & Equivalent
+Unshaded portions denole debit balance andor short
+V895
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+4 of 5
+Your Portfolio Holdings (continued)
+EQUITIES
+Equities & Options
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear
+Stearns at no cost, Customers can access this research at www.bearstearns,com or can call (800) 517-2327 to request
+that a copy of this research be sent to them.
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOUCUSIP
+BPIBY
+CASH
+QUANTITY
+20,000
+PRICE
+Unpriced
+$0
+$0
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+$19,307
+$665,772
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOO July 1,2005
+THROUGH
+July 29, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 30,2005
+AMAN NOTED
+$0
+$0
+CURRENT
+YELD IN
+Transaction Detail
+MONEY FUND ACTIVITY
+TRANSACTION
+07/01/05
+07/01/05
+'DIVIDEND
+DESCRIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT CLA
+MONTHLY DID ENARES
+SYMBOUGUSIP
+DiCX
+QUANTITY
+664,164.61
+PRICE
+DEBIT AMOUNT
+CREDIT AMOUNT
+607.0
+027
+07/30105;10:09 001
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+TRANSACTION
+07/01/05
+REINVEST
+DESCAIPTION
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+DIVIDEND REINVEST
+CLOSINGBALANCE
+SYMBOUCUSIP
+DICXX
+07/29/05
+TOTAL
+STOP
+****** End of Statement******
+QUANTITY
+1,607.05
+665,771.66
+027
+PRICE
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOO July 1,2005
+THROUGH
+July 29, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 30, 2005
+DEBIT AMOUNT
+1,607.05
+CREDIT AMOUNT
+$-1,607.05
+$1,607.05
+07/30/05:10:09001
+
+
+Bear, Stears & Co. Ine.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings ....
+Transaction Detail
+Fund Activity .....
+Your Messages
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 1,2005
+THROUGH
+June 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2005
+3
+3
+5
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+MONEY MARKET FUND BALANCE
+664,165
+$664,165
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+a portfolio indudes ono or mare unpriced securties that are
+acted in the Total Value of Securities and the Not Equity This Por
+662,207
+1,958
+Market Value of Your Portfolio
+Cash & Equivalent
+....
+.....
+$664.165
+$662,207
+Current market value
+Last statement's market value
+Confirmation: Unless we hear
+from you to the contrary, it is
+our understanding that any
+free credit balances in your
+account are being maintained
+to facilitate your intention to
+invest such amounts through
+uS.
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Please report any difference or non-receipt of checks or stocks, indicated as delivered to you,
+1o Client Services at 800-634-1428; or write lo Cient Services at Bear, Steams Securities
+Dorp., One Matralach Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four ratanal purger red de Set revere dise for portant iformation.
+07/01/05:10:42 001
+893(
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 of5
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Money Fund
+Amount Debited
+losing Balanc
+THIS PERIOD
+$0.00
+1,957.55
+51,957.55
+-1,957.55
+51.857.55
+$0.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+1,957.55
+$1,957.55
+YEAR TO DATE
+8,389.58
+$8.389.58
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+664,165
+$664.165
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+EST, 30 DAY AVG YIELD 3,0400%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+DICXX
+QUANTITY
+664,164.61
+PRICE
+1.0000
+MARKET
+VALUE
+664,165
+$664,165
+ESTIMATED
+CURRENT
+ANNUAL INCOME
+YELD INJ
+19,261
+2.9000
+$19,261
+027
+07/01/05:10:42 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOO June 1,2005
+THROUGH
+June 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31,2005
+Your Portfolio
+Allocation
+Tosh s Equivalent
+Unshaded portions denole debit balance andor short
+V893IP
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+4 of 5
+Your Portfolio Holdings (continued)
+EQUITIES
+Equities & Options
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear
+Stearns at no cost, Customers can access this research at www.bearstearns,com or can call (800) 517-2327 to request
+that a copy of this research be sent to them.
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOUCUSIP
+BPIBY
+CASH
+QUANTITY
+20,000
+PRICE
+Unpriced
+$0
+$0
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+$19,261
+$664,165
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOO June 1,2005
+THROUGH
+June 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2005
+AMAN NOTED
+$0
+$0
+CURRENT
+YELD IN
+Transaction Detail
+MONEY FUND ACTIVITY
+TRANSACTION
+06/01/05
+06/01/05
+'DIVIDEND
+DESCRIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT CLA
+MONTHLY DID ENARES
+SYMBOUGUSIP
+DiCX
+QUANTITY
+662,207.06
+PRICE
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,957.55
+027
+VASSIP
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MODAY
+TRANSACTION
+06/01/05
+REINVEST
+DESCAIPTION
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+DIVIDEND REINVEST
+CLOSINGBALANCE
+SYMBOUCUSIP
+DICXX
+06/30/05
+TOTAL
+Your messages
+Bear Stearns receives payments or other remuneration from the advisers,
+distributors or other affiliates of certain of the mutual funds available through
+Bear Stearns, Such payments or remuneration are for administrative,
+technological or other services provided in connection with fund accounts and
+are generally calculated based on the amount of assets held in the accounts.
+Sua distribution fees that Bear Steam ray receive Funds itose ar sates o
+not make payments to Bear Steams, including funds that may pay a higher or
+lower return, may be available to you,
+STOP
+****** End of Statement******
+QUANTITY
+1,957.55
+PRICE
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 1,2005
+THROUGH
+June 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2005
+DEBIT AMOUNT
+1,957.55
+CREDIT AMOUNT
+664,164.61
+$-1,957.55
+$1,957.55
+027
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings ...........................
+Transaction Detail .................................
+Fund Activity ......••••••••••••••••••••••II••IIII
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD April 30, 2005
+THROUGH
+May 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 29,2005
+3
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+MONEY MARKET FUND BALANCE
+662.207
+NET EQUITY THIS PERIOD
+$662,207
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+810,425
+-148.218
+This portfolio includes one or more unpriced securties that are no
+fected in tho Total Value of Securties and the Not Equity This Perio
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+....
+.....
+$662,207
+฿ $810,425
+Current market value
+Last statement's market value
+Please report any difference or non-receipe of checks or stocks, indicated as delivered to you,
+1o Client Services at 800-634-1428: or write to Cient Services at Bear, Steams Securities
+Corp., One Metrotech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s foul ratanal purger red die Set revere dae for potamt iformation.
+06/01/05:09:09 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+06/01/05:09:03 001
+
+
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Money Fund
+Funds Withdrawn
+Amount Debited
+Closing Balance
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CL A
+EST 30 DA VE 29000
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERIOD
+$0.00
+151,781.58
+$151,781.58
+-1,781.58
+-150,000.00
+$-151,781.58
+$0.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+1,781.58
+.51.781.58
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+YEAR TO DATE
+6,432.03
+*...
+$6,432.03
+662,207
+$662,207
+QUANTITY
+662,207.06
+FRICE
+1.0000
+MARKE
+VALU
+662,207
+$662,207
+ESTIMATED
+ANNUAL INCOM
+17,217
+$17,217
+WAREN
+HELD I
+2.5999
+027
+06/01/05:09:09 001
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD April 30, 2005
+THROUGH
+May 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 29,2005
+Your Portfolio
+Allocation
+Cash & Equivalent-
+100%
+Unshaded portions denole debt balance and'or short
+V978
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+4 of 5
+Your Portfolio Holdings (continued)
+EQUITIES
+Equities & Options
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear
+Stearns at no cost, Customers can access this research at www.bearstearns,com or can call (800) 517-2327 to request
+that a copy of this research be sent to them.
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOUCUSIP
+BPIBY
+CASH
+QUANTITY
+20,000
+PRICE
+Unpriced
+$0
+$0
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD April 30, 2005
+THROUGH
+May 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 29,2005
+AMAN NOTED
+CURRENT
+YELD IN
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+$17,217
+$662,207
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+05/31/05
+TRANSACTION
+FND WIRED
+TOTAL
+DESCRIPTION
+MDA#
+ENDS WIRED TO
+JeMOBEN HASE BANK, NA
+FHa0697B
+DEBIT AMOUNT
+150,000.00
+$-150,000.00
+CREDIT AMOUNT
+027
+06/01/05:09:09 001
+V978
+
+
+5 of5
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+04/30/05
+0502/05
+DIVIDEND
+05/02/05
+REINVEST
+05/31/05
+''SOLD
+05/31/05
+TOTAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCAIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT-CL A
+MONTHLY DIA ENARES
+DREYFUS CASH MANAGEMENT-CLA
+DIVIDEND RENTERPES
+. . . .
+REYFUS CASH MANAGEMENT-CL
+INSTITUTIONAL SHARES
+CLOSINGBALANCE
+SYMBOUGUSIP
+DICXX
+DICXX
+DICXX
+STOP
+****** End of Statement******
+QUANTITY
+810,425.48
+1,781.58
+- 150,000
+662,207.06
+027
+PRICE
+1.0000
+06/01/05;09:09 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD April 30, 2005
+THROUGH
+May 31,2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 29,2005
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,781.58
+1,781.58
+50,000.00
+$-1,781.58
+$151,781.58
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings ...........................
+Transaction Detail ..................................
+Fund Activity ............../....../....................
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD April 1, 2005
+THROUGH
+April 29, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 31,2005
+3
+4
+4
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+MONEY MARKET FUND BALANCE
+810,425
+NET EQUITY THIS PERIOD
+$810,425
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+808,681
+1,744
+a portfolio indudes ono or mare unpriced securtes that are
+acted in the Total Value of Securtes and the Not Eguty This Per
+Market Value of Your Portfolio
+Cash & Equivalent
+....
+.....
+$810.425
+$808,681
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Please report any difference or non-receipe of checks or stocks, indicated as delivered to you,
+1o Client Services at 800-634-1428: or write to Cient Services at Bear, Steams Securities
+Corp., One Metrotech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four ratanal purger red de Set revere date for portant iformation.
+04/30105;11:24 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+04/30/05:11:24 001
+V877
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERICO
+$0.00
+1,744.18
+$1,744.18
+-1,744.18
+5-1,744.18
+$0.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+1,744.18
+51.744.18
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+YEAR TO DATE
+4,650.45
+54.650.45
+810,425
+$810,425
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+NSTITUTIONAL SHARE
+ST. 30 DAY AVG YIELD 2,6900%
+TOTAL CASH & CASH EQUIVALENTS
+SIMBOL CUSIP
+DICXX
+QUANTITY
+810,425.48
+PRICE
+1.0000
+MARKET
+VALUE
+810,425
+$810,425
+ESTIMATED
+CURRENT
+ANNUAL INCOME
+YELD (%)
+20,261
+2.5000
+$20,261
+027
+04/30105;11:24 001
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD April 1, 2005
+THROUGH
+April 29, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 31,2005
+Your Portfolio
+Allocation
+Cash & Equivalent-
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+4 of 5
+Your Portfolio Holdings (continued)
+EQUITIES
+Equities & Options
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear
+Stearns at no cost, Customers can access this research at www.bearstearns,com or can call (800) 517-2327 to request
+that a copy of this research be sent to them.
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOUCUSIP
+BPIBY
+CASH
+QUANTITY
+20,000
+PRICE
+Unpriced
+$0
+$0
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+$20,261
+$810,425
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD April 1, 2005
+THROUGH
+April 29, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 31,2005
+AMAN NOTED
+$0
+$0
+CURRENT
+YELD IN
+Transaction Detail
+MONEY FUND ACTIVITY
+TRANSACTION
+04/01/05
+04/01/05
+'DIVIDEND
+DESCRIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT CLA
+MONTHLY DID ENARES
+SYMBOUGUSIP
+DiCX
+QUANTITY
+808,681.30
+PRICE
+DEBIT AMOUNT
+CREDIT AMOUNT
+027
+04/30105;11:24 001
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+TRANSACTION
+04/01/05
+REINVEST
+DESCAIPTION
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+DIVIDEND REINVEST
+CLOSINGBALANCE
+SYMBOUCUSIP
+DICXX
+QUANTITY
+1,744.18
+PRICE
+LEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD April 1, 2005
+THROUGH
+April 29,2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 31,2005
+DEBIT AMOUNT
+1,744.18
+CREDIT AMOUNT
+04/29/05
+TOTAL
+810,425.48
+$-1,744.18
+$1,744.18
+STOP
+****** End of Statement******
+027
+04/30/05:11:24 001
+V877
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings ............................
+Transaction Detail
+Fund Activity ........../../............................
+Your Message. ...........................I....
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 1,2005
+THROUGH
+March 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28,2005
+3
+3
+5
+6
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+MONEY MARKET FUND BALANCE
+808,681
+NET EQUITY THIS PERIOD
+$808,681
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+832,238
+-23,557
+is portfolio indudes ono or more unpriced socurties that are E
+acted in the Total Value of Securlies and the Not Equity This Parl
+Market Value of Your Portfolio
+Cash & Equivalent
+....
+.....
+$808.681
+$832.238
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Please report any difference or non-receipe of checks or slocks, indicaled as delivered to you,
+1o Client Services at 800-634-1428; or write lo Cient Services at Bear, Steams Securities
+Dorp., One Matrolach Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal purpose rear de Set revere dae for portant iformation.
+04/01/05:09:49 001
+7976
+
+
+2 of 6
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+04/01/05;09:49 001
+V976
+
+
+3 or 8
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Money Fund
+Funds Withdrawn
+Amount Debite
+Closing Balance
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+$0.00
+... ..
+26,443.37
+$26,443.37
+-1,443.37
+-25,000.00
+-26,443.37
+$0.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+1,443.37
+$1.443.37
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+YEAR TO DATE
+2,906.27
+$2,906.27
+808,681
+$808,681
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CL A
+EST 30 DAVE 2670086
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+QUANTITY
+808,681.30
+FRICE
+1.0000
+MARKETE
+808,681
+$808,681
+ESTIMATED
+NUAL INCOM
+16,982
+$16,982
+SUAREN
+(ELD E
+2.1000
+027
+04/01/05;09:49 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 1,2005
+THROUGH
+March 31,2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28,2005
+Your Portfolio
+Allocation
+Cash & Equivalent-
+100%
+Unshaded portions denole debt balance and'or short
+7976
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+4 of 6
+Your Portfolio Holdings (continued)
+EQUITIES
+Equities & Options
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear
+Stearns at no cost, Customers can access this research at www.bearstearns,com or can call (800) 517-2327 to request
+that a copy of this research be sent to them.
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOU/DUSIP
+BPIBY
+CASH
+QUANTITY
+20,000
+PRICE
+Unpriced
+$0
+$0
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 1,2005
+THROUGH
+March 31,2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28,2005
+AMAN NOTED
+CURRENT
+YELD IN
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+$16,982
+$808,681
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+03/28/05
+TRANSACTION
+FND WIRED
+TOTAL
+DESCRIPTION
+MDA# [
+ENDS WIRED TO
+IPMORGAN CHASE BANK, NA
+FD#05600
+DEBIT AMOUNT
+25,000.00
+$-25,000.00
+CREDIT AMOUNT
+027
+04/01/05;09:49 001
+7976
+
+
+5 orB
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+03/01/05
+03/01/05
+DIVIDEND
+03/01/05
+REINVEST
+03/28/05
+*SOLD
+03/31/05
+TOTAL
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCAIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT-CL A
+MONTHLY DIA ENARES
+DREYFUS CASH MANAGEMENT CLA
+*DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+CLOSINGBALANCE
+SYMBOUCUSIP
+DICXX
+DICXX
+DICXX
+QUANTITY
+832,237.93
+1,443.37
+-25,000
+808,681.30
+027
+PRICE
+0000
+04/01/05;09:49 001
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 1,2005
+THROUGH
+March 31,2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28,2005
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,443.37
+1,443.37
+25,000.00
+$-1,443.37
+$26,443.37
+7976
+
+
+6 of 6
+Bear, Stears & Co. Inc
+383 Madison Avenu
+New York, New York 10179
+Your messages
+Bear, Stearns Securities Corp, Net Capital and Net Capital Requirements:
+A complete copy of the Bear, Stearns Securities Corp, Statement of Financial
+Coquest a ise piable on py plead itali to ear tears 299. 9331
+Alternatively, to
+STOP
+****** End of Statement******
+027
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 1, 2005
+THROUGH
+March 31,2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28,2005
+04/01/05;09:49001
+7976
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings ...........................
+Transaction Detail .................................
+Fund Activity ........../../............................
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD February 1, 2005
+THROUGH
+February 28, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31,2005
+3
+4
+4
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+MONEY MARKET FUND BALANCE
+832.238
+NET EQUITY THIS PERIOD
+$832,238
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+830,775
+1,463
+is portfolio indudes ono or more unpriced securties that are E
+acted in the Total Value of Securlies and the Not Equity This Per
+Market Value of Your Portfolio
+Cash & Equivalent
+....
+.....
+$832,238
+$830,775
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Please report any difference or non-receipe of checks or stocks, indicated as delivered to you,
+1o Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrotech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen is four or ratanal purger rear de Set revere ase for portant iformation.
+03/01/05;11:09 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+03/01/05:11:09 001
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+1,462.90
+$1,462.90
+-1,462.90
+$-1,462.90
+$0.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+1,462.90
+.$1.462.90
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+YEAR TO DATE
+1,462.90
+.........
+$1,462.90.
+832,238
+$B32,238
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+NSTITUTIONAL SHARE
+ST. 30 DAY AVG YIELD 2,3400%
+TOTAL CASH & CASH EQUIVALENTS
+SIMBOL CUSIP
+DICXX
+QUANTITY
+832,237.93
+PRICE
+1.0000
+MARKET
+VALUE
+832,238
+$832,238
+ESTIMATED
+CURRENT
+ANNUAL INCOME
+YELD (%)
+17,477
+2.1000
+$17,477
+027
+03/01/05;11:09 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD February 1, 2005
+THROUGH
+February 28, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31, 2005
+Your Portfolio
+Allocation
+Tosh s Equivalent
+Unshaded portions denole debit balance andor short
+V872
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+4 of 5
+Your Portfolio Holdings (continued)
+EQUITIES
+Equities & Options
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear
+Stearns at no cost, Customers can access this research at www.bearstearns,com or can call (800) 517-2327 to request
+that a copy of this research be sent to them.
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOUCUSIP
+BPIBY
+CASH
+QUANTITY
+20,000
+PRICE
+Unpriced
+$0
+$0
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+$17,477
+$832,238
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD February 1, 2005
+THROUGH
+February 28,2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31, 2005
+AME NOTES
+$0
+$0
+CURRENT
+YELD IN
+Transaction Detail
+MONEY FUND ACTIVITY
+TRANSACTION
+02/01/05
+02/01/05
+DIVIDEND
+DESCRIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT CLA
+MONTHLY DID ENARES
+SYMBOUCUSIP
+DiCX
+QUANTITY
+830,775.03
+PRICE
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,462.90
+027
+03/01/05;11:09 001
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+TRANSACTION
+02/01/05
+REINVEST
+DESCAIPTION
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+DIVIDEND REINVEST
+CLOSINGBALANCE
+SYMBOUCUSIP
+DICXX
+QUANTITY
+1,462.90
+PRICE
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD February 1, 2005
+THROUGH
+February 28,2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31, 2005
+DEBIT AMOUNT
+1,462.90
+CREDIT AMOUNT
+02/28/05
+TOTAL
+832,237.93
+$-1,462.90
+$1,462.90
+STOP
+****** End of Statement******
+027
+03/01/05:11:09001
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings ...........................
+Transaction Detail ..................................
+Fund Activity ............../....../....................
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD January 1, 2005
+THROUGH
+January 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2004
+3
+4
+4
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+830.775
+$830,775
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+829,424
+1,351
+This portfolio includes one or more unpriced securties that are no
+elected in tho Total Value of Securies and the Not Equity This Period
+Market Value of Your Portfolio
+Cash & Equivalent
+....
+.....
+$830.775
+$829,424
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Please report any diference or non-receipt of chacks or stocks, indicated as delivered to you
+o Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3669.
+SP The suremen is four or ratanal purger red de Set revere dae for portant iformation.
+02/01/05:07:55 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERICD
+$0.00
+1,351.01
+$1,351.01
+-1,351.01
+5-1.351.01
+$0.00
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+830,775
+$830,775
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRPTION
+DREYFUS CASH MANAGEMENT-CLA
+NSTITUTIONAL SHARE
+ST. 30 DAY AVG YIELD 2,1700%
+TOTAL CASH & CASH EQUIVALENTS
+SIMBOL CUSIP
+DICXX
+QUANTITY
+830,775.03
+PRICE
+1.0000
+MARKET
+VALUE
+830,775
+$B30,775
+ESTIMATED
+CURRENT
+ANNUAL INCOME
+16,616
+YELD (%)
+2.0001
+$16,616
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD January 1, 2005
+THROUGH
+January 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2004
+Your Portfolio
+Allocation
+Cash & Equivalent
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+4 of 5
+Your Portfolio Holdings (continued)
+EQUITIES
+Equities & Options
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear
+Stearns at no cost, Customers can access this research at www.bearstearns,com or can call (800) 517-2327 to request
+that a copy of this research be sent to them.
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOUCUSIP
+BPIBY
+CASH
+QUANTITY
+20,000
+PRICE
+Unpriced
+$0
+$0
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+$16,616
+$830,775
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD January 1, 2005
+THROUGH
+January 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2004
+AMAN NOTED
+$0
+$0
+CURRENT
+YELD IN
+Transaction Detail
+MONEY FUND ACTIVITY
+TRANSACTION
+01/01/05
+01/03/05
+''REINVEST
+DESCRIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT CLA
+NSTITUTIONAL SHARE
+IVIDEND REINVES
+SYMBOUGUSIP
+DiCX
+QUANTITY
+PRICE
+DEBIT AMOUNT
+1,351.01
+CREDIT AMOUNT
+027
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+TRANSACTION
+01/03/05
+DIvIDEND
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+MT INCLUDED IN 2004 - 109
+CLOSINGBALANCE
+SYMBOUCUSIP
+DICXX
+01/31/05
+TOTAL
+STOP
+****** End of Statement******
+QUANTITY
+830,775.03
+027
+PRICE
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD January 1,2005
+THROUGH
+January 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2004
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,351.01
+$-1,351.01
+$1,351.01
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/bf9bc7280cd3bcfddb2f1f9dffde9b15544dbd38a0b46715c9520ec612e1312f.receipt.json b/vision-fixhub/ds9-unparsed-05/bf9bc7280cd3bcfddb2f1f9dffde9b15544dbd38a0b46715c9520ec612e1312f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b09941812a70c775d84ea6e855b104f3e1b4f67a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bf9bc7280cd3bcfddb2f1f9dffde9b15544dbd38a0b46715c9520ec612e1312f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -5759,
+  "dataset": "marble-joined",
+  "doc_id": "bf9bc7280cd3bcfddb2f1f9dffde9b15544dbd38a0b46715c9520ec612e1312f",
+  "engine": "marble-apple-vision",
+  "event_count": 71,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "37cac3756f74e2aceaaef8524c7d1a6052b935b67f8264029e639e4493ac17ba",
+  "output_sha256": "1c106af02b04cd96f7019c9017b622d7c147b554bb74469974b8363249db94ee",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/bfb5f8859040972d331421fc0c54193521dcc483e2dcb14659af09a61a52f83b.md b/vision-fixhub/ds9-unparsed-05/bfb5f8859040972d331421fc0c54193521dcc483e2dcb14659af09a61a52f83b.md
new file mode 100644
index 0000000000000000000000000000000000000000..9f00e7dc1ad8975b3dce039b31229a4af046f39f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bfb5f8859040972d331421fc0c54193521dcc483e2dcb14659af09a61a52f83b.md
@@ -0,0 +1,5691 @@
+Statements
+
+
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities C
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary.............................
+Transaction Detail
+Fund Activity .........................................
+Your Messages
+........•..
+.....
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 28, 2003
+3
+8
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+21,616,835
+-21,616,835
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent → 511
+$110,115
+Equities :
+..50
+$21.506.720
+Important Message
+I any information regardin
+2003interest, dividends
+niscellaneous income
+gross proceeds or origina
+To be reporter is the is or
+Last statement's market value
+DeMarch 15,2004. a 10425
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+1o Client Sarices at 800-634-1428; Or write to Cient Services at Bear, Stoams Securities
+Corp..
+_ Brooklyn, N.Y. 11201-3859.
+SP The suren s four or ratanal purposes red die Set revere date for portant iformation.
+
+
+2 of 8
+Bear. Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+Transaction Detail
+INVESTMENT ACTIVITY
+SETLEMENT TREE
+12/01/03 11/25/03
+TRANSACTION
+SOLD
+THIS PERICO
+$9.694.17
+21,372,449.58
+21,486,999.99
+28,853.18
+....
+$42,888,302.75
+....
+-21,382,225.14
+-1.53
+-21,515,770.25
+S42-897,996.92
+-9,694.17
+$0.00
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+9,694.17
+$9,694.17
+CLOSING
+0.00
+$0.00
+-....
+Income Summary
+THIS PERIOD
+Dividends
+33,204.12
+Credit Balance Int.
+1.65
+Total
+$33,205.77
+YEAR TO DATE
+316,229.46
+6,267.07
+5322-496.53
+AMERICAN INTERNATIONAL GROUP
+UNSOLICITED
+S OF 11/25/03
+SYMBOLCUSP
+AIG
+QUANTITY
+-25,000
+PRICE
+57.45000
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 28, 2003
+DEBIT AMOUNT
+1,428,087.56
+
+
+4 of a
+INVESTMENT ACTIVITY (continued)
+SETTLEMENT TRADE
+DATE
+12/01/03
+11/25/03
+TRANSACTION
+SOLD
+12/01/0311/25/03
+"SOLD
+***...
+12/01/0
+11/25/03
+SOLD
+2/01/01
+11/25/03
+SOLD
+12/01/03
+11/25/03
+SOLD
+.......
+2/01/0
+12/01/03
+12/01/03
+11/25/03
+11/25/03
+11/25/03
+SOLD
+SOLD
+SOLD
+DESCRPTION
+BANK OF AMER CORP
+AVG PRICE SHOWN-DETAILS ON REC
+ACTUAL CONFIRM TO YOUR AGENT
+UNSOLICITED
+CITIGROUP INC
+UNSOLICITED
+SEE NOTE'S' ON BACK
+FREDDIE MAC-VOTING COMMON
+(FORMERLY FEDERAL HOME LOAN
+MORTGAGE CORP!
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+UNSOLICITED
+FANNIE MAE
+(FEDERAL NATL MTG ASSN
+JNSOLICITED
+INTERNATIONAL BUSINESS
+UNSOLICITED
+... ...
+OHNSON& JOHNSO
+UNSOLICITED
+ACTUAL CONFIRM TO TOUR E
+UNSOLICITED
+WITH RIGHTS TO PURCHASE PREFRO
+STK UNDER CERTAIN CIRCUMSTANCE
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+UNSOLICITED
+SYMBOLGUSIP
+BAC
+FRE
+FNM
+BM
+KAB
+"PFE
+027
+QUANTITY
+40,000
+-27,375
+PRICE
+74.82540
+46.87010
+-30,000
+54.74270
+-5,000
+-20,000
+69.55000
+89.53200
+60,000
+100,000
+75,000
+50.86400
+24.19960
+• 33.40130
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Car
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 29,2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 28,2003
+DEBIT AMOUNT
+2,976,864.73
+1,275.478.72
+1,632,899.05
+345,685.25
+1,781,111.76
+3.034,341.12
+.403.223.6
+2,489,313.66
+
+
+5 or 8
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TRIES
+DATE
+TRANSACTION
+12/01/03 11/25/03
+SOLD
+12/01/03 11/25/03 SOLD
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+11/29/03
+TRANSACTION
+12/01/03
+BOUGHT
+12/01/03
+DIVIDEND
+12/01/03
+REINVEST
+12/09/03
+12209/03
+SOLD
+DIVIDEND
+PROCTER & GAMBLE CO
+AVG PRICE SHOWN-DETAILS ON REC
+ACTUAL CONFIRM TO YOUR AGENT
+ISOLICIT
+E NOTE 'S' ON BA
+TIME WARNER ING
+UESOICITED
+DESCAIPTION
+OPENINGBALANCE
+BEAR STEARNS PRIME MONEY
+MARKET PORTFOLIO CLY
+....
+BEAR STEARNS PRIME MONEY
+RECORD 11128003 PAT 128103
+*BEAR STEARNS PRIME MONEY
+MARKET PORTFOLIO CLY
+REINVEST PRICE $ 1.00
+.. . .
+EAR STEARNS PRIME MONE
+ARKET PORTFOLIO CL
+BEAR STEARNS PRIME MONEY
+MARKET PORTFOLIO CLY
+SYMBOLGUSIP
+PG
+TWX
+QUANTITY
+-25,000
+00,00
+PRICE
+96.92600
+16.08000
+SYMBOLCUSIP
+BSMXX
+BMXX
+ISMX
+QUANTITY
+100,420.73
+21,382,143.75
+81.39
+21,482,645.87
+PRICE
+1.0000
+DEBIT AMOUNT
+21,382,143.75
+81.39
+1.0000
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Car
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+November 28, 2003
+DEBIT AMOUNT
+2,410,434.82
+1,595, 009.31
+$21,372.449.58
+81.39
+21,482,645.87
+4,272.73
+027
+
+
+6 of a
+MONEY FUND ACTIVITY (continued)
+RATELY
+12/31/03
+TOTAL
+TRANSACTKN
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+12/04/03
+12/09/03
+12/10/03
+PFIZER INC
+IEC 11/14/03 PAY 12/04/0
+HG VS A/O & CXL TRADE
+JOHNSON& JOHNSON
+REC 11/18/03 PAY 12/09/03
+INTERNATIONAL BUSINESS
+MACHINES CORP
+REC 11/10/03 PAY 12/10/03
+TOTAL
+INTEREST
+DATE
+12/12/03
+INTEREST ON CREDIT BALANCE
+CR INT CALCULATED
+11/21-12/1103
+222/03 INTEREST ON CREDIT BAL
+ITEREST ON CREDIT BALANC
+ADJ 12/22/03 CRINT VS 12/12/03
+ENTRY
+SYMBOUCUSIP
+SYMBOUCUSIP
+PFE
+IBM
+QUANTITY
+75,000
+60,000
+20,000
+SYMBOUGUSIP
+QUANTITY
+QUANTITY
+0.00
+RATE (S)
+0.1500
+0.2400
+0.1600
+RATE (%)
+220
+PRICE
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Car
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 28, 2003
+DEBIT AMOUNT
+$-21,382,225.14
+$21,486,999.99
+DEBIT AMOUNT
+11,250.00
+.. . .
+14,400.00
+3,200.00
+$28,850.00
+1.53
+DEBIT AMOUNT
+1.53
+
+
+7 of a
+INTEREST (continued)
+DATE
+12/22/03
+INTEREST ON CREDIT BALANCE
+OCT 049-5188
+T 00.50000% 11/21 - 12/2
+TOTAL
+MISCELLANEOUS
+MADAY
+12/09/03
+12/15/03
+12/30/03
+TOTAL
+TRANSACTION
+JOURNAL
+ERIO
+JOURNAL
+"JOURNAL
+TO COMP
+"ADJUST BALANCE
+SYMBOUGUSIP
+QUANTITY
+RATE (SI
+DEBIT AMOUNT
+21,512,570.05
+,200.
+0.12
+$-21,515,770.25
+027
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+DEBIT AMOUNT
+$-1.53
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 28, 2003
+1.65
+$3.18
+
+
+8 of a
+Your messages
+As part of the National Association of Securities Dealers (NASD) Investor
+STOP
+****** End of Statement******
+WHOLLY OWNED SUBSIDIARY
+Bear Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 29,2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+November 28.2003
+Excess SIPC Account Protection Update
+Bear, Stearns Securities Corp, ('BSS"), a member of the Securities Investor
+Protection Corporation ('SIPC"), provides account protection for the net equity
+of a customer's funds and securities positions. SIPC provides $500,000 of
+primary net equity protection, including $100,000 for claims for cash ("SIPC
+Coverage*). Visit www.sipc.org for more information about SIPC Coverage.
+BSSC provides the additional protection ("Excess SIPC") through a commercial
+insurer, Effective February 16, 2004, the commercial insurer for Excess SIPC
+will change to Customer Asset Protection Company ("CAPCO"), a licensed New
+York insurance company. Account protection applies when a SIPC member
+firm fails financially and is unable to meet its obligations to its securities
+customers, but does not apply to losses from the rise or fall in the market
+value of investments or to SIPC ineligible assets such as options, futures,
+foreign exchange transactions, or any investment contracts that are not
+registered as securities.
+027
+
+
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ......
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity..........
+Trades Not Yet Settled
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31,2003
+3
+6
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+21,506,720
+9,694
+100,421
+$21,616,835
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+21,613,766
+3,070
+Cash & Equivalent -
+Equities -
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$110,11
+441.69
+$2172,075
+$21.506,720
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+do Client Services at 800-634-1428; or write to Cient Servicos at Bear, Stoama Securitios
+Corp..
+_ Brooklyn, N.Y. 11201-3859.
+SP The suren s four or ratanal purposes rear die Set revere date for portant iformation.
+11/29/03;09:04 001
+
+
+2 of 9
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+11/29 03:09:04 001
+
+
+3 org
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Securities Bought
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance,
+THIS PERICO
+5328, 764.63
+12,678.90
+21,069.17
+$33,748.07
+......
+-352,731.81
+-86.72
+.5.352.818.53
+-319,070.46
+9.694.11
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+328,764.63
+$328,764.63
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+21,042.97
+112.92
+$21,155.89
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+CLOSING
+9,694.17
+59,694.17
+YEAR TO DATE
+283,025.34
+6,265.42
+.....
+$289.290.76
+110,115
+21,506,720
+$21.616.835
+11/29/03:09:04 001
+"HOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31,2003
+Your Portfolio
+Allocation
+Cash & Equivalent-
+<1%
+Equities
+99%
+Unshaded portions denote debit balance andor shart
+from the absolute marker value of your portiolo
+
+
+4 of g
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+BEAR STEARNS PRIME MONEY
+LARKET PORTFOLIO CL
+VIDEND REINVESTEI
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AMERICAN INTERNATIONAL GROUP
+.. . ..
+BANK OF AMER CORP
+********-_-
+CITIGROUP INC
+•••••••••••••••••••••••••••••••
+FREDDIE MAC-VOTING COMMON
+(FORMERLY FEDERAL HOME LOAN
+MORTGAGE CORP
+FANNIE MAE
+(FEDERAL NATL MG ASSN)
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JOHNSON& JOHNSON
+MBNA CORP
+PRIZER INC
+SYMBOL/CUSIP
+BMXX
+QUANTITY
+100,420.73
+PRICE
+1.0000
+SYMBCUCUSIP
+AIG
+BAC
+FRE
+FNM
+IBM
+KRB
+PFE
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+........
+CASH
+CASH
+QUANTITY
+25,000
+40,000
+27,375
+30,000
+5,000
+20,000
+60,000
+100,000
+75,000
+MARKET
+VALUE
+9,694
+100,421
+$110,115
+PRICE
+57.9500
+75.4300
+47.0400
+54.4200
+70.0000
+90.5400
+49.2900
+24.5200
+33.5500
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31,2003
+ESTIMATED
+ANNUAL INCOME
+-.......
+904
+0.9002
+$904
+MARKET
+VALUE
+1,448,750
+3,017.200
+1,287,720
+1,632,600
+ANNE NOTED
+6,500
+0.4487
+128,000
+4.2423
+38,325
+2.9762
+••••••••••••••••••••••••••••••••
+31,200
+1.9111
+350,000
+1,810,800
+2,957,400
+2,452,000
+2,516,250
+
+12,800
+2.5714
+0.7069
+57,600
+40,000
+5,00
+1.9477
+1.6313
+.............
+1.7884
+027
+11/29/03:09:04 001
+
+
+5 org
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+PROCTER & GAMBLE CO
+........
+TIME WARNER INC
+NEW
+Total Equities& Options
+TOTAL EQUITIES
+SIMBOUCUSIP
+PG
+TWX
+CASH
+CASH
+QUANTITY
+25,000
+100,000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+BATEMENT DARE
+DATE
+11/12/03
+11/06/03
+TRANSACTION
+BOUGHT
+.....
+FANNIE MAE
+PART OF
+PRICE
+96.2400
+16.2800
+MARKET
+VALLE
+2,406,000
+1,628,000
+$21,506,720
+$21,506,720
+$414,829
+$21,616,835
+ANNES NOT
+45,500
+$413,925
+$413,925
+SYMBOLICUSIP
+FNM
+QUANTITY
+1,000
+PRICE
+70.07000
+027
+11/2903:09:04 001
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31,2003
+DEBIT AMOUNT
+70,482.30
+
+
+6 of g
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+DATE
+TRANSACTION
+11/12/03 11/06/03 BOUGHT
+TOTAL
+MONEY FUND ACTIVITY
+TRANSACTION
+11/01/03
+11/03/03
+DIVIDEND
+11/03/03
+REINVEST
+11/21/03
+SOLD
+11/28/03
+TOTAL
+DIVIDENDS
+DATE
+11/14/03
+PROCTER & GAMBLE CO
+REC 10/24/03 PAY 11/14/03
+FANNIE MAE
+(FEDERAL NATL MTG ASSN)
+DISCRETIONARY ORDER
+PART OF 5000 SHR
+SYMBOLCUSIP
+FNM
+QUANTITY
+4,000
+PRICE
+70.15000
+OPENINGBALANCE
+BEAR STEARNS PRIME MONEY
+MAKE POT A 031103
+BEAR STEARNS PRIME MONEY
+MAKE PRES 1.0
+MAKE PORIOLD CLE, MONEY
+CLOSINGBALANCE
+SYMBOUCUSIP
+PG
+SYMBOUCUSIP
+BMXX
+BMXX
+BMXX
+QUANTITY
+25,000
+QUANTITY
+112,926.19
+22:98
+-12,592.18
+100,420.73
+RATE (S)
+0.4550
+027
+PRICE
+1.0000
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Car
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31,2003
+DEBIT AMOUNT
+282,249.51
+CRECIT AMOUNT
+$ 352,731.81
+DEBIT AMOUNT
+86.72
+86.72
+2,592.1
+$-86.72
+$12,678.90
+11,375.00
+DEBIT AMOUNT
+11/2903:09:04 001
+
+
+7 of g
+DIVIDENDS (continued)
+DATE
+11/26/03
+CITIGROUP INC
+REC 11/03/03 PAY 11/26/03
+TOTAL
+INTEREST
+DATE
+11/21/03
+INTEREST ON CREDIT BALANCE
+AT O 1/2% 10/21 THRU 11/20
+TOTAL
+SYMBOUGUSIP
+SYMBOUCUSIP
+Trades Executed Pending Settlement
+SEEMENT TREE
+12/01/03
+11/25/03
+TRANSACTION
+SOLD
+1201/03
+11/25/03
+"SOLD
+AMERICAN INTERNATIONAL GROUP
+A3SF 172803
+BANK OF AMER CORP
+G PRICE SHOWN-DETAILS ON R
+TUAL CONFIRM TO YOUR AGE
+UNSOLICITED
+QUANTITY
+27,375
+RATE (S)
+0.3500
+QUANTITY
+RATE (%)
+0.5000
+SYMBOLCUSP
+AIG
+BAC
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+QUANTITY
+-25,000.00
+10,000.00
+PRICE
+57.4500
+74.8254
+11/29/03:09:04 001
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31,2003
+9,581.25
+$20,956.25
+112.92
+$112.92
+DEBIT AMOUNT
+1,428,087.56
+2,976,864.7
+
+
+8 org
+Trades Executed Pending Settlement
+(continued)
+SETTLEMENT TRIES
+12/01/03
+11/25/03
+TRANSACTION
+SOLD
+CITIGROUP INC
+IG PRICE SHOWN-DETAILS ON RE
+TUAL CONFIRM TO YOUR AGEN
+UNSOLICITED
+SEE NOTE'S ON BACK
+12/01/03 11/25/03
+SOLD
+12/01/0:
+....
+12/01/03
+11/25/03
+11/25/03
+SOLD
+SOLD
+UNSOLICITED
+.........
+FANNIE MAE
+EDERAL NATL MTG ASS
+LS 1051
+NTERNATIONAL BUSINES
+1201/03
+11/25/03
+12/01/0:
+______...
+12/01/03
+11/25/03
+11/25/03
+"SOLD
+SOLD
+SOLD
+JOHNSON& JOHNSON
+UNSOLICITED
+MBNA CORP
+UNSOLICITED
+PFIZER INC
+ACTUAL CONFIRM TO YOURS AGENT.
+UNSOLICITED
+SABOUCUSP
+FRE
+IBM
+KRB
+PFE
+027
+QUANTITY
+-27,375.00
+-30,000.00
+-5,000.00
+-20,000.00
+30,000.00
+-100,000.00
+-75,000.00
+PRICE
+46.8701
+54.7427
+69.5500
+OZES 68
+= 50.8640
+24.1996
+33.4013
+11/2903:09:04 001
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Car
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 31,2003
+DEBIT AMOUNT
+1,275,478.72
+1.632,899.05
+345,685.25
+1,781,111.76
+3,034,341.12
+2,403,223.60
+2,489,313.66
+984L6
+
+9 org
+Trades Executed Pending Settlement
+(continued)
+SETTLEMENT TRIES
+12/01/03
+11/25/03
+TRANSACTION
+SOLD
+12/01/03 11/25/03
+SOLD
+TOTAL
+PROCTER & GAMBLE CO
+VG PRICE SHOWN-DETAILS ON RE
+CTUAL CONFIRM TO YOUR AGEN
+INSOLICITEI
+SEE NOTE 'S' ON BAC
+TIME WARNER ING
+NEW
+UNSOLICITED
+The above trades do not appear in any other section of this statement.
+STOP
+****** End of Statement******
+SYMBOLCUSP
+PG
+QUANTITY
+-25,000.00
+PRICE
+96.9260
+TWX
+- 100,000.00
+6.080(
+027
+11/29/03;09:04 001
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Car
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 1, 2003
+THROUGH
+November 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+October 31,2003
+DEBIT AMOUNT
+2,410,434.82
+$0.00
+1,595, 009.31
+$21,372,449.58
+
+
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities C
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary.............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .......................
+.....
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2003
+3
+4
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+21,172,075
+328,765
+112,926
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+S21.613.766
+••••••••/••••••••••••
+20,934,613
+679,153
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$441,691
+$206,527
+Cash & Equivalent —
+Equities -
+S20.728,086
+$21.172,075
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp..
+_ Brooklyn, N.Y. 11201-3859.
+SP The suren s four or ratanal purposes rear de Set revere date for portant iformation.
+11/01/03;14:02 001
+
+
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+11/01/03:14:02 001
+
+
+3 or 7
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Amount Credited
+Securities Bought
+Money Fund
+Amount Debited
+Net Cash Activity
+losing Balanc
+THIS PERICO
+393,684.50
+974,146.37
+84.27
+10,039.17
+.......
+$984,269.81
+....
+-749,105.41
+-84.27
+---•
+5-749,189.68
+.....
+235,080.13
+....
+5328,764.63
+Income Summary
+Dividends
+Credit Balance Int.
+THIS PERIOD
+10,084.27
+39.17
+.$10.123.44
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+OPENING
+93,684.50
+Net Cash Balance
+$93,684.50
+CLOSING
+328,764.63
+......
+$328,764.63
+027
+YEAR TO DATE
+261,982.37
+6,152.50
+****---.
+$268,134.87
+441,691
+21,172,075
+821.613.766
+11/01/03:14:02001
+"HOLLY OWNED SUBSIDIARY
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2003
+Your Portfolio
+Allocation
+Cash & Equivalent —
+2%
+Equities
+98%
+Unshaded portions denote debit balance andor short
+
+
+4 of 7
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+BEAR STEARNS PRIME MONEY
+LARKET PORTFOLIO CL
+VIDEND REINVESTEI
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AMERICAN INTERNATIONAL GROUP
+.. . ..
+BANK OF AMER CORP
+*-------.
+CITIGROUP INC
+•••••••••••••••••••••••••••••
+FREDDIE MAC-VOTING COMMON
+(FORMERLY FEDERAL HOME LOAN
+MORTGAGE CORP
+.......
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JOHNSONS JOHNSON
+MBNA CORP
+PFIZER INC
+PROCTER & GAMBLE CO
+SYMBOL/CUSIP
+BMXX
+QUANTITY
+112,926.19
+1.0000
+SYMBOUOUSIP
+AIG
+BAC
+FRE
+IBM
+JNU
+KRB
+PFE
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+25,000
+40,000
+....
+27,375
+30,000
+20,000
+60,000
+100,000
+75,000
+.....
+25,000
+MARKET
+VALUE
+328,765
+112,926
+$441,691
+PRICE
+60.8300
+75.7300
+47.4000
+•....
+56.1300
+89.4800
+50.3300
+24.7500
+31.6000
+98.2900
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2003
+ESTIMATE
+NNUAL INCOM
+1,028
+$1,028
+....
+0.9103
+1,520,750
+3,029,200
+1,297,575
+1,683,900
+1,789,600
+3,019,800
+2,475,000
+2,370,000
+.. . .
+2,457,250
+027
+ANANAS NOTED
+6,500
+128,000
+38,325
+••••••••••I///
+31,200
+12,800
+57,600
+40,000
+45,000
+45,500
+11/01/03;14:02 001
+0.4274
+4.2255
+2.9536
+1.8528
+0.7152
+1.9074
+1.6162
+1.8987
+1.8517
+
+
+5 of 7
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+TIME WARNER INC
+NEW
+Total Equities& Options
+TOTAL EQUITIES
+SIMBOLCUSIP
+TWX
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT
+TRADE
+DATE
+10/16/03
+DATE
+TRANSACTION
+NAME CHG
+1/16/0
+NAME CHG
+101Z7I03
+10/22/03
+SOLD
+CASH
+QUANTITY
+100,000
+AOL TIME WARNER INC
+A011234 TO T007117
+N/C TIME WARNER INC
+TIME WARNER ING
+NO TIME WARNE A 011231
+.........
+I DU PONT DE NEMOURS & C
+AVG PRICE SHOWN-DETAILS ON REC
+ACTUAL CONFIRM TO YOUR AGENT
+DISCRETIONARY ORDER
+••••••••••••••••••••••••••••
+PRICE
+15.2900
+MARKET
+VALUE
+1,529,000
+$21,172,075
+$21,172,075
+$405,953
+$21,613,766
+CURRENT
+YELD IN
+$404,925
+$404,925
+SYMBOLCUS
+00184A105
+TWX
+DD
+QUANTITY
+- 100,000
+100,000
+-25,000
+PRICE
+39.20820
+027
+11/01/03;14:02 001
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2003
+DEBIT AMOUNT
+974,146.37
+
+
+6 of 7
+INVESTMENT ACTIVITY (continued)
+SATE EMENT TATE
+DATE
+TRANSACTION
+10/30/0310/27/03
+BOUGHT
+BANK OF AMER CORP
+TOTAL
+MONEY FUND ACTIVITY
+MATTAY
+10/01/03
+TRANSACTON
+OPENINGBALANCE
+10/01/03
+DIVIDEND
+BEAR STEARNS PRIME MONEY
+10/01/03
+REINVEST
+BEAR STEARNS PRIME MONEY
+MARKET PRICES 1.00
+CLOSINGBALANCE
+10/31/03
+TOTAL
+SYMBOLGUSP
+BAC
+QUANTITY
+10,000
+PRICE
+74.49740
+SYMBOU/CUSIP
+BMXX
+ISMX
+QUANTITY
+112,841.92
+84.27
+112,926.19
+PRICE
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Cam
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2003
+DEBIT AMOUNT
+749,105.41
+$-749,105.41
+$974,146.37
+DEBIT AMOUNT
+84.27
+*84.27
+$-84.27
+$84.27
+027
+11/01/03:14:02 001
+
+
+7 of 7
+DIVIDENDS
+DATE
+TD/D1/03
+MBNA CORP
+REC 09/15/03 PAY 10/01/03
+TOTAL
+INTEREST
+DATE
+10/21/03
+INTEREST ONCREDIT BALANCE
+AT 0 1/2% 09/21 THRU 10/20
+TOTAL
+SYMBOUCUSIP
+KRB
+SYMBOL/CUSIP
+STOP
+****** End of Statement******
+QUANTITY
+100,000
+QUANTITY
+RATE (S)
+0.1000
+RATE (%)
+0.5000
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+11/01/03:14:02001
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD October 1,2003
+THROUGH
+October 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30, 2003
+10,000.00
+$10,000.00
+CAEDIT AMOUNT
+39.17
+$39.17
+
+
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities C
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ...................../...................
+Your Message. ...........................I....
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 29,2003
+3
+5
+8
+Hollandlold
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+20,728,086
+93.685
+112.842
+NET EQUITY THIS PERIOD
+$20,934,613
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+20,913,103
+21,509
+There are no 'Stop Loss' orders or other pending buy
+or sell open orders on file for your account
+Cash & Equivalent -
+Market Value of Your Portfolio
+$206.527
+$135.393
+Equities -
+Current market value
+Last statement's market value
+Important Message
+$20,728,086
+$20,777,706
+statement. Effective this
+month, your account
+statement reflects all
+day of the month.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; Or Write to Clent Services at Bear, Steams Securities
+Corp..
+_ Brooklyn, N.Y. 11201-3859.
+SP The suremen s four ratanal purpose red die Set revere dae for portant iformation.
+027
+10/01/03;11:21 001
+
+
+2 of 9
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+10/01/03:11:21 001
+V813
+
+
+3 of9
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance,
+THIS PERIOD
+522,643.20
+87.79
+71,041.30
+$71,129.09
+-87.79
+S-87.79
+....
+71,041.30
+693.684.50
+Income Summary
+Dividends
+Credit Balance Int.
+THIS PERIOD
+71,112.79
+16.30
+571, 129.05
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+22,643.20
+$22,643.20
+CLOSING
+93,684.50
+$93,684.50
+027
+YEAR TO DATE
+251,898.10
+6,113.33
+5258.011-43
+206,527
+20,728,086
+$20.934.613
+10/01/03;11:21 001
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securites o
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 29, 2003
+Your Portfolio
+Allocation
+Cash & Equivalent-
+<1%
+Equities
+99%
+Unshaded portions denote debit balance and or shart
+
+
+4 of g
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+BEAR STEARNS PRIME MONEY
+LARKET PORTFOLIO CL
+VIDEND REINVESTEI
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AOL TIME WARNER INC
+•....
+AMERICAN INTERNATIONAL GROUP
+BANK OF AMER CORP
+......
+CITIGROUP INC
+......
+E I DU PONT DE NEMOURS & CO
+FREDDIE MAC-VOTING COMMON
+MORTGAGE CORAL HOME LOAN
+.. . .
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JOHNSON& JOHNSON
+MBNA CORP
+SYMBOL/CUSIP
+BMXX
+QUANTITY
+112,841.92
+PRICE
+1.0000
+SYMBCUCUSIP
+AOL
+AIG
+BAC
+DD
+FRE
+IBM
+INJ
+KRB
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+ASI
+... .
+CASH
+QUANTITY
+100,000
+25,000
+30,000
+27,375
+25,000
+30,000
+20,000
+60,000
+....
+100,000
+MARKET
+VALUE
+93,685
+112,842
+$206,527
+PRICE
+15.1100
+57.7000
+78.0400
+45.5100
+40.0100
+52.3500
+88.3300
+49.5200
+....
+22.8000
+WHOLLY OWNED SUBSIDIAR
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 29,2003
+ESTIMATED
+INNUAL INCOME
+1,016
+0.9004
+$1,016
+MARKET
+VALUE
+1,511,000
+1,442,500
+2,341,200
+1,245,836
+1,000,250
+1,570,500
+1,766,600
+,971,200
+2,280,000
+027
+6.500
+96,000
+•• !!!!
+38,325
+35,000
+31,200
+12,800
+57,600
+........
+40,000
+10/01/03;11:21 001
+0.4506
+4.1005
+••••••••••••
+3.0762
+.........
+3.4991
+1.9866
+0.7246
+1.9386
+1.7544
+
+
+5 org
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+PFIZER INC
+........
+PROCTER & GAMBLE CO
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+PFE
+PG
+CASH
+CASH
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+QUANTITY
+75,000
+25,000
+PRICE
+30.3800
+92.8200
+MARKET
+2,278,500
+2,320,500
+$20,728,086
+$20,728,086
+$408,941
+$20,934,613
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+08/30/03
+09/02/03
+"DIVIDEND
+09/02/03
+REINVEST
+DESCAIPTION
+OPENINGBALANCE
+BEAR STEARNS PRIME MONEY
+BEAR STEARNS PRIME MONEY
+MARKET PRICES 1,00
+SYMBOUCUSIP
+BMXX
+BMXX
+QUANTITY
+112,754.13
+87.79
+027
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 29,2003
+ANNUAL INCOME
+45,000
+45,500
+$407,925
+$407,925
+CURRENT
+YIELD (S
+1.9750
+1.9608
+PRICE
+DEBIT AMOUNT
+87.79
+87.79
+10/01/03;11:21 001
+
+
+6 of 9
+MONEY FUND ACTIVITY (continued)
+RATELY
+09/30/03
+TOTAL
+TRANSACTKN
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+09/04/03
+09/09/03
+....
+09/10/03
+DESCRUPTION
+PFIZER INC
+REC 08/15/03 PAY 09/04/03
+JOHNSON& JOHNSON
+REC 08/19/03 PAY 09/09/03
+....
+NTERNATIONAL BUSINESS
+MACHINES CORP
+REC 08/08/03 PAY 09/10/03
+09/12/03
+09/19/03
+E I DU PONT DE NEMOURS & CO
+REC 08/15/03 PAY 09/12/03
+AMERICAN INTERNATIONAL GROUP
+REC 09I05I03 PAY 09/1903
+08126/03
+.. . .
+BANK OF AMER CORP
+REC 09/05/03 PAY 09/26/03
+09/30/03
+*FREDDIE MAC VOTING COMMON
+HE IS END HOME LOAN
+TOTAL
+SYMBOL/GUSIP
+SYMBOUCUSIP
+PFE
+IBM
+DD
+AIG
+BAC
+FRE
+QUANTITY
+75,000
+60,000
+20,000
+25,000
+25,000
+30,000
+30,000
+QUANTITY
+112,841.92
+RATE (S)
+0.1500
+0.2400
+0.1600
+0.3500
+0.0650
+0.8000
+0.2600
+027
+PRICE
+DEBIT AMOUNT
+10/01/03;11:21 001
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Car
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 29,2003
+DEBIT AMOUNT
+$-87.79
+$87.79
+11,250.00
+14,400.00
+3,200.00
+8,750.00
+1,625.00
+24,000.00
+7,800.00
+$71,025.00
+
+
+7 of g
+INTEREST
+DATE
+09/22/03
+INTEREST ONCREDIT BALANCE
+AT 0 1/2% 08/21 THRU 09/20
+TOTAL
+SYMBOUCUSIP
+QUANTITY
+RATE (%)
+0.5000
+027
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear. Steams Securities Ca
+DEBIT AMOUNT
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD August 30,2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 29,2003
+16.30
+$16.30
+10/01/03:11:21 001
+V813
+
+
+8 of g
+Your messages
+Bear, Stearns Securities Corp, Net Capital and Net Capital Requirements:
+At May 31, 2003 and July 31, 2003, the Company's net capital of
+A complete copy of the Bear, Stearns Securities Corp, Statement of Financial
+Condition is available on the web site www.bearsteams.com. Alternatively, to
+request a free printed copy please call - toll free 1-866-299-9331,
+Bear, Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD August 30,2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+August 29, 2003
+Securities and other assets in your account are the firm's collateral for any
+margin loan made to you, If the securities and other assets in your account
+decline in value, so does the value of the collateral supporting your loan, and,
+as a result, the firm can take action, such as issue a margin call and/or sell
+securities or other assets in any of your accounts held with the member, in
+orly uto matatain the sea ined edity train securt, in imaginant has rou
+include the following:
+* You can lose more funds than you deposit in the margin account.
+* The firm can force the sale of securities or other assets in you
+accounts).
+* The firm can sell your securities or other assets without contacting you.
+* You are not entitled to choose which securities or other assets in your
+accounts) are liquidated or sold to meet a margin call.
+• any time an is notse is no to promie you ace and in re nomients at
+* You are not entitled to an extension of time on a margin call,
+027
+10/01/03;11:21001
+V9Ta
+
+
+LEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear. Steams Securities Co
+9 of 9
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD August 30, 2003
+THROUGH
+September 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 29,2003
+Pursuant to SEC Rule 11Ac1-6, please note the following:
+veb link: http://www.bearstearns.com/
+Equities, Click on Order Routing Practices.
+Customers of Bear, Stearns & Co, Inc, may request information on any order
+executed within the prior six months from the time of the request, Specifically,
+you may request the identity of the venue to which the identified orders were
+routed for execution, whether the order was directed by you to that venue, and
+the time of the executions, if any, that resulted from such orders.
+STOP
+End of Statement******
+027
+10/01/03:11:21001
+
+
+"HOLLY OWNED SUBSIDIARY
+Bear. Steams Securities C
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary .............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .......................
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+July 25, 2003
+3
+4
+5
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+20,777,706
+22,643
+112,754
+$20,913,103
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+21,483,942
+-570,839
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent -
+$135,391
+$114.233
+Equities -
+$20,777,706
+$21,369,709
+Current market value
+Last statement's market value
+Important Message
+Bear Stearns is pleased to
+announce our conversion to
+a calendar month-end
+statement. Effective
+September 2003,your
+account statement will
+reflect all activity and
+account valuation up to and
+including the last business
+day of the month.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+do Client Servicos at 800-634-1428; or write to Cient Servicos at Bear, Stoama Securitios
+Corp..
+_ Brooklyn, N.Y. 11201-3859.
+SP The surren s four or ratanal pur yes rearde Set revere date for portant iformation.
+09/30103;13:45 001
+
+
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+09/30/03;13:45 001
+
+
+3 ore
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance,
+THIS PERICO
+351.685.28
+206.19
+20,957.92
+$21,164.11
+•........
+- 206.19
+•....••
+5-206.19
+.......
+20,957.92
+....
+622.643.20
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+21,162.44
+1.67
+$21, 164.11
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+1,685.28
+$1,685.28
+CLOSING
+22,643.20
+$22,643.20
+027
+YEAR TO DATE
+180,785.31
+6,097.03
+•****.*..-.
+$186,882.34
+135,397
+20,777,706
+$20,913,103
+09/30/03;13:45 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear Steams Securites o
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 25, 2003
+Your Portfolio
+Allocation
+Cash & Equivalent-
+<1%
+Equities
+99%
+Unshaded portions denote debe balance andor short
+
+
+4 org
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+BEAR STEARNS PRIME MONEY
+LARKET PORTFOLIO CL
+VIDEND REINVESTEI
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AOL TIME WARNER INC
+•....
+AMERICAN INTERNATIONAL GROUP
+BANK OF AMER CORP
+......
+CITIGROUP INC
+.. ...
+E I DU PONT DE NEMOURS & CO
+FREDDIE MAC-VOTING COMMON
+MORTGAGE CORAL HOME LOAN
+.. . .
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JOHNSON& JOHNSON
+MBNA CORP
+SYMBOL/CUSIP
+BMXX
+QUANTITY
+112,754.13
+PRICE
+1.0000
+SYMBCUCUSIP
+AOL
+AIG
+BAC
+DD
+FRE
+IBM
+INJ
+KRB
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+... .
+CASH
+QUANTITY
+100,000
+25,000
+30,000
+27,375
+25,000
+30,000
+20,000
+30,000
+....
+100,000
+MARKET
+VALUE
+22,643
+112,754
+$135,397
+PRICE
+16.3600
+59.5700
+79.2500
+43.3500
+44.7400
+53.1500
+82.0100
+49.5800
+23.3400
+"HOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 25, 2003
+ESTIMATED
+ANNUAL INCOME
+1,026
+0.9099
+$1,026
+1,636,000
+1,489,250
+2,377,500
+1,186,706
+1,118,500
+1,594,500
+1,640,200
+2,974,800
+2,334,000
+027
+6.500
+96,000
+....
+38,325
+35,000
+31,200
+12,800
+57,600
+.. . .
+40,000
+0.4365
+4.0379
+...
+3.2295
+3.1292
+1.9567
+0.7804
+1.9363
+1.7138
+09/3003;13:45 001
+
+
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+PFIZER INC
+........
+PROCTER & GAMBLE CO
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+PFE
+PG
+CASH
+CASH
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+07/26/03
+DESCAIPTION
+OPENINGBALANCE
+08101103*
+'DIVIDEND
+08/01/03
+REINVEST
+BEAR STEARNS PRIME MONEY
+RECOND 0783103 PAY 0731/03
+BEAR STEARNS PRIME MONEY
+MARKET PRICES 1,00
+QUANTITY
+75,000
+25,000
+PRICE
+29.9200
+87.2900
+MARKET
+VALUE
+2,244,000
+2,182,250
+$20,777,706
+$20,777,706
+$408,951
+$20,913,103
+SYMBOLCUSIP
+BSMXX
+BMXX
+QUANTITY
+112,547.94
+206.19
+027
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 25, 2003
+ANNUAL INCOME
+45,000
+....
+45,500
+$407,925
+$407,925
+CURRENT
+YIELD (S
+2.0053
+2.0850
+PRICE
+DEBIT AMOUNT
+206.19
+206:19
+09/3003;13:45 001
+
+
+6 of 8
+MONEY FUND ACTIVITY (continued)
+RATELY
+08/29/03
+TOTAL
+TRANSACTKN
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+08/15/03
+PROCTER & GAMBLE CO
+08/22/03
+REC 07/18/03 PAY 08/15/03
+CITIGROUP INC
+REC 08/04/03 PAY 08/22/03
+TOTAL
+INTEREST
+DATE
+08/21/03
+TOTAL
+INTEREST ON CREDIT BALANCE
+AT O 1/2% 07/21 THRU 08/20
+SYMBOUCUSIP
+SYMBOL/CUSIP
+PG
+QUANTITY
+25,000
+27,375
+SYMBOUCUSIP
+QUANTITY
+QUANTITY
+112,754.13
+RATE (S)
+0.4550
+0.3500
+RATE (%)
+0.5000
+027
+PRICE
+DEBIT AMOUNT
+DEBIT AMOUNT
+09/30/03;13:45001
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Car
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIO July 26,2003
+THROUGH
+August 29, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT July 25,2003
+DEBIT AMOUNT
+$-206.19
+$206.19
+11,375.00
+9,581.25
+$20,956.25
+CAEDIT AMOUNT
+1.67
+$1.67
+
+
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ....
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ....
+..... . . . . . . . . . .
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 27, 2003
+3
+4
+6
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+21,369,709
+1,685
+112,548
+$21,483,942
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+20,909,370
+574,572
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$114,233
+$633,621
+Cash & Equivalent -
+Equities -
+
+$21,369,709
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+do Client Services at 800-634-1428; or write to Cient Servicos at Bear, Stoama Securitios
+Corp..
+_ Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal purger rear die Set revere ase for portant iformation.
+
+
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+V811
+
+
+3 or 7
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Securities Bought
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balanc
+THIS PERICO
+21,629.8
+.....
+500,556.95
+13,205.15
+$513,762.10
+-533,149.75
+-556.95
+$.533.706.70
+-19,944.60
+.51.685.28
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+21,629.88
+$21,629.88
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+13,756.95
+5.15
+$13,762.10
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+CLOSING
+1,685.28
+$1,685.28
+YEAR TO DATE
+159.622.87
+6,095.36
+5165.71823
+114,233
+21,369,709
+....
+521.483.942
+07/26/03:10:33 001
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 27,2003
+Your Portfolio
+Allocation
+Cash & Equivalent-
+<1%
+Equities
+99%
+Unshaded portions denote debit balance andor short
+from the absolute marker value of your portiolo
+
+
+4 of 7
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+BEAR STEARNS PRIME MONEY
+LARKET PORTFOLIO CL
+VIDEND REINVESTEI
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AOL TIME WARNER INC
+•....
+AMERICAN INTERNATIONAL GROUP
+BANK OF AMER CORP
+......
+CITIGROUP INC
+.. ...
+E I DU PONT DE NEMOURS & CO
+FREDDIE MAC-VOTING COMMON
+MORTGAGE CORAL HOME LOAN
+.. . . .
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JOHNSON& JOHNSON
+MBNA CORP
+SYMBOL/CUSIP
+BMXX
+QUANTITY
+112,547.94
+1.0000
+SYMBCUCUSIP
+AOL
+AIG
+BAC
+DD
+FRE
+IBM
+INJ
+KRB
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+ASI
+... .
+CASH
+QUANTITY
+100,000
+25,000
+30,000
+27,375
+25,000
+30,000
+20,000
+60,000
+....
+100,000
+MARKET
+VALUE
+1,685
+112,548
+$114,233
+PRICE
+15.3200
+64.6500
+83.5300
+....
+45.7300
+44.6900
+50.7500
+83.6700
+52.2300
+.. . .
+23.0000
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 27, 2003
+ESTIMATED
+NNUAL INCOM
+1,035
+$1,035
+MARKET
+VALUE
+1,532,000
+1,616,250
+2,505,900
+.....
+1,251,859
+1.117.250
+1,522,500
+1,673,400
+3,133,800
+2,300,000
+027
+0.9196
+6.500
+96,000
+38,325
+35,000
+31,200
+12,800
+57,600
+........
+40,000
+0.4022
+3.8310
+3.0614
+....
+3.1327
+2.0493
+0.7649
+1.8380
+1.7391
+
+
+5 of 7
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+PFIZER INC
+........
+PROCTER & GAMBLE CO
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+PFE
+PG
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+CASH
+CASH
+QUANTITY
+75,000
+25,000
+Transaction Detail
+INVESTMENT ACTIVITY
+DETENT TATE
+DATE
+TRANSACTION
+07/08/03 07/02/03
+BOUGHT
+TOTAL
+PRICE
+33.0400
+89.5500
+MARKET
+2,478,000
+2,238,750
+$21,369,709
+$21,369,709
+$408,960
+$21,483,942
+ANNUAL INCOME
+45,000
+.....
+45,500
+$407,925
+$407,925
+CURRENT
+YIELD (S
+1.8160
+.......•..
+2.0324
+SYMBOLCUSP
+FRE
+QUANTITY
+10,000
+PRICE
+53.00000
+027
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIO June 28,2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 27, 2003
+DEBIT AMOUNT
+533,149.75
+$533,149.75
+
+
+6 of 7
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+06/28/03
+OPENINGBALANCE
+07/01/03
+DIVIDEND
+07/01/03
+REINVEST
+07/10/03
+3 SOLD
+BEAR STEARNS PRIME MONEY
+MARKET PORTFOLIO
+ARD 0S3003 PAY 06/30/0:
+BEAR STEARNS PRIME MONEY
+MAKET POTION MIE MONEY"
+CLOSINGBALANCE
+07/25/03
+TOTAL
+DIVIDENDS
+DATE
+06/30/03
+07/01/03
+TOTAL
+REC 06/16/03 PAY 06/30/03
+"MENA CORP
+REC 06/13/03 PAY 07/01/03
+SYMBOUCUSIP
+BSMXX
+BSMXX
+ISMX
+SYMBOUCUSIP
+FRE
+QUANTITY
+20,000
+100,000*
+QUANTITY
+611,990.99
+556.95
+-500,000
+112,547.94
+RATE (5)
+0.2600
+0.0800
+027
+PRICE
+1.0000
+DEBIT AMOUNT
+07/26/03:10:33 001
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIO June 28,2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 27,2003
+DEBIT AMOUNT
+556.95
+556.95
+.....
+00,000.0
+$500,556.95
+$-556.95
+CREDIT AMCUNT
+5,200.00
+3,000.00
+$13,200.00
+V811
+
+
+7 of 7
+INTEREST
+DATE
+07/21/03
+INTEREST ON CREDIT BALANCE
+AT 0 3/4% 06/21 THRU 06/24
+07721/03
+INTEREST ON CREDIT BALANCE
+T O 1/2% 06/25 THRU 07/20
+TOTAL
+SYMBOL/CUSIP
+STOP
+****** End of Statement******
+QUANTITY
+RATE (SI
+0.7500
+0.5000
+027
+"HOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+DEBIT AMOUNT
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD June 28, 2003
+THROUGH
+July 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 27, 2003
+0.17
+4.98
+$5.15
+
+
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ....
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ....
+..... . . . . . . . . .
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD May 31, 2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 30, 2003
+3
+4
+6
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+20,275.749
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+21,630
+611,991
+NET EQUITY THIS PERIOD
+$20,909,370
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+20,677,883
+231,487
+Cash & Equivalent
+Equities
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$633,621
+$2,711,160
+$20.275,749
+$17,966,723
+Current market value
+Last statement's market value
+Important Message
+Confirmation: Unless we
+hear from you to the
+contrary, it is our
+understanding that any free
+credit balances in your
+account are being
+maintained to facilitate
+your intention to invest
+such amounts through us.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+do Client Services at 800-634-1428; or write to Cient Servicos at Bear, Stoama Securitios
+Corp...
+_ Brooklyn, N.Y. 11201-3859.
+SP The suremen is four or ratanal purpose rebr die Set revere dae for portant iformation.
+06/28/03;12:00 001
+V909
+
+
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+06/28/03:12:00 001
+V908
+
+
+3 or 7
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Securities Bought
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+$2,032,811.00
+67,642.13
+50,112.00
+$117,754.13
+-2,128,293.12
+-642.13
+$2,128.935.25
+-2,011,181.12
+521.629.88
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+2,032,811.00
+$2,032,811.00
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+49,867.13
+887.00
+$50,754.13
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+CLOSING
+21,629.88
+$21,629.88
+YEAR TO DATE
+145,865.92
+6,090.21
+$151,956.13
+633,621
+20,275,749
+......
+$20.909.370
+06/28/03;12:00 001
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 30,2003
+Your Portfolio
+Allocation
+Cash & Equivalent -
+Equities
+97%
+Unshaded portions denote debit balance andor short
+from the absolute market value of your portlavis.
+
+
+4 of 7
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+BEAR STEARNS PRIME MONEY
+LARKET PORTFOLIO CL
+VIDEND REINVESTEI
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AOL TIME WARNER INC
+•....
+AMERICAN INTERNATIONAL GROUP
+BANK OF AMER CORP
+.....
+CITIGROUP INC
+......
+E I DU PONT DE NEMOURS & CO
+FREDDIE MAC-VOTING COMMON
+MORTGAGE CORAL HOME LOAN
+.. . .
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JOHNSON& JOHNSON
+MBNA CORP
+SYMBOL/CUSIP
+BMXX
+QUANTITY
+611,990.99
+PRICE
+1.0000
+SYMBCUCUSIP
+AOL
+AIG
+BAC
+DD
+FRE
+IBM
+INJ
+KRB
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+100,000
+25,000
+30,000
+27,375
+25,000
+20,000
+20,000
+60.0000
+....
+100,000
+MARKET
+VALUE
+21,630
+611,991
+$633,621
+PRICE
+15.8200
+55.6900
+79.6100
+•...
+43.0100
+41.8300
+50.0000
+83.4200
+51.5400
+20.7500
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD May 31, 2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 30, 2003
+ESTIMATED
+ANNUAL INCOME
+6,304
+1.0301
+$6,304
+MARKET
+VALUE
+1,582,000
+1,392,250
+2,388,300
+•••••••••••••:
+1.177.399
+1,045,750
+1,000,000
+ANNA NOTED
+5,200
+96,000
+21,900
+35.0000*
+20,800
+1,668,400
+3,092,400
+.. . .
+2,075,000
+12,800
+57,600
+32,000
+027
+06/28/03;12:00 001
+0.3735
+4.0196
+•••••
+1.8600
+3.3469
+2.0800
+0.7672
+1.8626
+1.5422
+
+
+5 of 7
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+PFIZER INC
+........
+PROCTER & GAMBLE CO
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+PFE
+PG
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+CASH
+CASH
+QUANTITY
+75,000
+25,000
+Transaction Detail
+INVESTMENT ACTIVITY
+BATLEMENT DATE
+TRANSACTION
+06/09/03
+06/04/03
+BOUGHT
+96/09/03
+06/04/03
+BOUGHT
+06/09/03 06/04/03 BOUGHT*
+E I DU PONT DE NEMOURS & CO
+URS 00052 0 0
+.. . .
+DU PONT DE NEMOURS &
+ET DU PONT DE NEMOURS & CO
+PART OF
+N500093
+PRICE
+35.0000
+89.1700
+MARKET
+2,625,000
+2.229,250
+$20,275,749
+$20,275,749
+$373,604
+$20,909,370
+ANNUE NOE
+45,000
+.....
+41,000
+$367,300
+$367,300
+CURRENT
+YIELD (S
+1.7143
+1.8392
+SYMBOLCUSIP
+DD
+DD
+QUANTITY
+200
+1,500
+23,300
+PRICE
+43.30000
+43.32000
+#43-45000
+027
+06/2803;12:00 001
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD May 31, 2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 30,2003
+DEBIT AMOUNT
+8,711.96
+65,369.70
+018,439.3
+
+
+6 of 7
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+DATE
+TRANSACTION
+06/13/03 06/10/03
+BOUGHT
+FREDDIE MAC-VOTING COMMON
+¡FORMERLY FEDERAL HOME LOAN
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+05/31/03
+TRANSACTION
+DESCAIPTION
+OPENINGBALANCE
+06/02/03
+DIVIDEND
+BEAR STEARNS PRIME MONEY
+MARKET PORTFOLIO CL
+ECORD 05/30/03 PAY 05/30/0
+06/02/03
+REINVEST
+06/12/03
+SOLD
+MARKET PORTOLD GIE MONEY
+06/27/03
+TOTAL
+CLOSINGBALANCE
+SYMBOLCUSIP
+FRE
+QUANTITY
+20,000
+PRICE
+51.49010
+SYMBOUCUSIP
+BMXX
+BMXX
+BSMXX
+QUANTITY
+678,348.86
+642.13
+-67,000
+611.990.99
+PRICE
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Car
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 30, 2003
+DEBIT AMOUNT
+1,035,772.16
+CRECIT AMOUNT
+$2,128,293.12
+DEBIT AMOUNT
+642.13
+1.0000
+$-642.13
+342.1:
+67,000.00
+$67,642.13
+027
+06/28/03;12:00 001
+
+
+7 of 7
+DIVIDENDS
+DATE
+06/05/03
+06/10/03
+PFIZER INC
+REC 05/16/03 PAY 06/05/03
+INTERNATIONAL BUSINESS
+MACHO 03 PAY 06/1003
+06/10/03
+JOHNSON& JOHNSON"
+EC 05/20/03 PAY 06/1010
+06620/03
+"AMERICAN INTERNATIONAL GROUP
+REC 06106I03 PAY 06/20103
+........
+BANK OF AMER CORP
+REC 06/06/03 PAY 06/27/03
+SYMBOL/CUSIP
+PFE
+IBM
+AIG
+BAC
+TOTAL
+INTEREST
+DATE
+06/23/03
+INTEREST ON CREDIT BALANCE
+AT 0 3/4% 05/21 THRU 06/20
+TOTAL
+SYMBOU/CUSIP
+STOP
+****** End of Statement******
+QUANTITY
+75,000
+20,000
+60,000
+25,000
+30,000
+QUANTITY
+RATE (S)
+0.1500
+0.1600
+0.2400
+0.0470
+0.6400
+RATE (%)
+0.7500
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+06/28/03;12:00 001
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 30,2003
+11,250.00
+3,200.00
+14,400.00
+:175.0
+19,200.00
+$49,225.00
+887.00
+$887.00
+V9Ce
+
+
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary.............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .......................
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 25, 2003
+3
+4
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+17.966.723
+2,032.811
+678.349
+NET EQUITY THIS PERIOD
+620.677.883
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+20,039,818
+638,065
+here are no "Stop Loss' orders or other pending bu
+r sell open orders on file for your accoun
+Market Value of Your Portfolio
+$2,711,160
+$1,787,209
+Cash & Equivalent
+Equities
+$17,966.723
+$18,252,609
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; Or Write to Clent Services at Bear, Steams Securities
+Corp..
+_ Brooklyn, N.Y. 11201-3859.
+SP The suremen is four for ratanal purpose red de Set revere date for portant iformation.
+
+
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 ore
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+31.109.49.23
+905,095.79
+637.10
+18,217.98
+$923,950.87
+-637.10
+............ 5-637.10
+923,313.77
+$2.032-811.00
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+1,109,497.23
+$1,109,497.23
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+17,802.10
+1,052.98
+$18,855.08
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+CLOSING
+2,032,811.00
+$2,032,811.00
+YEAR TO DATE
+95,998.79
+5,203.21
+$101.202.00
+2,711,160
+17,966,723
+....
+520.677,883
+05/31/03:15:30 001
+"HOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 25,2003
+Your Portfolio
+Allocation
+Gash & Equivalent -
+Equities
+86%
+Unshaded portions denote debit balance and or shart
+
+
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+... . . .
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AOL TIME WARNER INC
+AMERICAN INTERNATIONAL GROUP
+BANK OF AMER CORP
+.. . . .
+CITIGROUP INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+.... .
+JOHNSON& JOHNSON
+.. . .
+PFIZER INC
+....
+PROCTER & GAMBLE CO
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+BSMXX
+QUANTITY
+678,348.86
+1.0000
+SIMBOUCUSIP
+AOL
+AIG
+KRB
+PFE
+PG
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+.. ..
+CASH
+QUANTITY
+100,000
+25,000
+30,000
+•....
+27.375
+20,000
+60,000
+... .
+100,000
+75,000
+25,000
+"HOLLY OWNED SUBSIDIARY
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 25,2003
+MARKET
+VALUE
+2,032,811
+678,349
+$2,711,160
+ESTIMATED
+INNUAL INCOME
+7,462
+1.1000
+$7,462
+PRICE
+15.2200
+57.8800
+74.2000
+41.0200
+88.0400
+54.3500
+... .
+20.0500
+.....
+1.020
+91.8200
+1,522,000
+1,447,000
+222000-
+1,760,800
+3.261,000
+.....
+2,005,000
+2326,500
+2,295,500
+$17,966,723
+$17,966,723
+027
+ANNUS NOME
+5,200
+76,800
+21,900
+12,800
+57,600
+........
+41,000
+$292,300
+$292,300
+CURRENT
+0.3594
+3.4501
+......
+1.9503
+0.7269
+1.7663
+1.5960
+... .
+1.9342
+1.7861
+
+
+5 of 8
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TATE
+TRANSACTION
+05/02/03
+04/29/03
+SOLD
+TOTAL
+MONEY FUND ACTIVITY
+RATLAN
+TRANSACTION
+04/26/03
+05/01/03 DIVIDEND'*
+GOLDMAN SACHS GROUP ING
+AVG PRICE SHOWN-DETAILS ON REQ
+DESCAIPTION
+OPENINGBALANCE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 25, 2003
+$299,762
+$20.677,883
+SYMBOLCUSIP
+GS
+QUANTITY
+-12,000
+PRICE
+75.84430
+DEBIT AMOUNT
+905,095.79
+$905,095.79
+SYMBOLCUSIP
+QUANTITY
+677,711.76
+PRICE
+DEBIT AMOUNT
+CAEDIT AMOUNT
+637.10
+027
+
+
+6 of 8
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+TRANSACTION
+05/01/03
+REINVEST
+.......
+05/30/03
+TOTAL
+BEARE FOR&PRIYE, MONEY
+REINVEST PRICE $ 1.00
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+DESCRPTION
+05/15/03
+PROCTER & GAMBLE CO
+REC 04/17/03 PAY 05/15/03
+05/23/03 MIGROUP INC.....
+REC 05/05/03 PAY 05/23/03
+05/29/03
+OLDMAN SACHS GROUP IN
+C 04/29/03 PAY 05/29/1
+TOTAL
+INTEREST
+DATE
+05/21/03
+NTEREST ON CREDIT BALANC
+Г 0 3/4% 04/21 THRU 05/2
+TOTAL
+SYMBOUCUSIP
+BSMXX
+SYMBOUCUSIP
+PG
+GS
+QUANTITY
+25,000
+27,375
+12,000
+SYMBOUCUSIP
+QUANTITY
+QUANTITY
+637.10
+678,348.86
+RATE (S)
+0.4100
+0.2000"
+0.1200
+RATE (%)
+0.7500
+027
+PRICE
+DEEIT AMOUNT
+DEBIT AMOUNT
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Car
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 25,2003
+DEBIT AMOUNT
+637.10
+$637.10
+$637.10
+10,250.00
+'5,475.00
+1,440.00
+$17,165.00
+1,052.98
+$1,052.98
+
+
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary.............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .......................
+.....
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD March 29, 2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2003
+3
+4
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+18.252.609
+1,109,497
+677,712
+NET EQUITY THIS PERIOD
+$20,039,818
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+19,186,804
+853,014
+here are no "Stop Loss' orders or other pending bu
+r sell open orders on file for your accoun
+Market Value of Your Portfolio
+$1.787,209
+$1,620,743
+Cash & Equivalent
+Equities
+$18,252,609
+$17.566,061
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; Or Write to Clent Services at Bear, Steams Securities
+Corp..
+_ Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal purger red de Set revere date for portant iformation.
+027
+04/26/03;12:12 001
+
+
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+04/26/03:12:12 001
+
+
+3 or 7
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Amount Credited
+Securities Bought
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERICO
+$943,713.80
+.. . .
+897,057.20
+682.95
+7,676.74
+$905,416.89
+.. . .
+-738,950.51
+-682.95
+.....
+$-739,633.46
+....
+165,783.43
+..............
+11.109.497.23
+Income Summary
+Dividends
+Credit Balance Int.
+Total L
+THIS PERIOD
+7,882.95
+476.74
+58.359.69
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+OPENING
+943,713.80
+Net Cash Balance
+$943,713.80
+CLOSING
+1,109,497.23
+....
+$1,109,497.23
+027
+YEAR TO DATE
+78,196.69
+4,150.23
+$82,346.92
+1,787,209
+18,252,609
+$20,039,818
+04/26/03:12:12 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD March 29,2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2003
+Your Portfolio
+Allocation
+Cash & Equivalent —
+8%
+Equities
+92%
+Unshaded portions denote debit balance and or shart
+
+
+4 of 7
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+... . . .
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AOL TIME WARNER INC
+AMERICAN INTERNATIONAL GROUP
+BANK OF AMER CORP
+CITIGROUP INC
+GOLDMAN SACHS GROUP INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+..............------.
+JOHNSON& JOHNSON
+MENA CORP,
+... . . .
+IZER IN
+....
+PROCTER & GAMBLE CO
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+BSMXX
+QUANTITY
+677,711.76
+PRICE
+1.0000
+SIMBCLCUSIP
+AOL
+AIG
+BAC
+GS
+IBM
+JNU
+......
+KRB
+PFE
+PG
+CASH
+CASH
+CASH
+........
+CASH
+CASH
+CASH
+CASH
+... . .
+CASH
+CASH
+CASH
+QUANTITY
+100,000
+25,000
+30,000
+......
+27,375
+12,000
+...
+20,000
+60,000
+....
+100,000
+75,000
+25,000
+"HOLLY OWNED SUBSIDIARY
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD March 29, 2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2003
+MARKET
+VALUE
+1,109,497
+677,712
+$1,787,209
+PRICE
+13.3200
+54.7500
+72.5800
+...
+38.4500
+75.8700
+.. . .
+83.8800
+56.2100
+.. . .
+18.5500
+30.3700
+89.1400
+ESTIMATED
+ANIVUAL INCOME
+*********--.
+7,658
+1.1300
+$7,658
+MARKET
+VALLE
+1,332,000
+1,368,750
+2,177,400
+1,052,569
+910,440
+...
+1,677,600
+3,372,600
+... .
+1,855,000
+2.277,750
+2,228,500
+$18,252,609
+$18,252,609
+ESTIMATE
+INNUAL INCOM
+4,700
+76,800
+21900
+5,760
+12,000*
+57,600
+.. . ..
+32,000
+45,000
+....
+41,000
+$296,760
+$296,760
+027
+04/26/03;12:12 001
+SURREN
+0.3434
+3.5271
+2.0806
+......
+0.6321
+0.7153
+1.7079
+1.7251
+.975
+1.8398
+
+
+5 of 7
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+DATE EMENT TATE
+04/04/03
+04/01/03
+
+' 4101/03
+TRANSACTION
+BOUGHT
+•BOUGHT
+84004/0304/01/03BOUGH
+84/7883'*84787/83''S0B"
+04/15/03
+04/10/03
+SOLD
+JOHNSON& JOHNSON
+DISCRETIONARY ORDER
+MENA COP ...
+SCRETIONARY ORDI
+AT OF 10000 SH
+SCRETIONARY ORD
+IRT OF 10000 SI
+AVG PRICE SHOWN-DETAILS ON REQ
+ACTUAL CONFIRM TO YOUR AGENT
+DISCRETIONARY ORDER
+VIACOM ING-CLB**
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+DISCRETIONARY ORDER
+$304,418
+$20.039.818
+SMONUS.
+"KRE
+VIAB
+QUANTITY
+10,000
+3,900
+6,100
+5:550
+8,325
+PRICE
+58.23000
+••15:19000
+•15.18000**
+=1:33440
+39.75470
+027
+04/26/03;12:12 001
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD March 29,2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2003
+DEBIT AMOUNT
+585,688.58
+59,796.51
+93.485.42
+2227,845:40
+*328,774.04
+
+
+6 of 7
+INVESTMENT ACTIVITY (continued)
+SATE EMENT TATE
+DATE
+TRANSACTION
+04/16/03
+04/11/03
+SOLD
+VIACOM INC-CL B
+AVG PRICE SHOWN-DETAILS ON REC
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+03/29/03
+0401703 DIVIDEND
+84/61703***REINVEST
+DESCAIPTION
+OPENINGBALANCE
+FARE FERNSOME, MONE
+RECORD 03/31/03 PAY 03/31/03
+"ARE PORTED OLE, MONEY"
+REINVEST PRICE $ 1.00
+......
+04/25/03
+TOTAL
+CLOSINGBALANCER
+DIVIDENDS
+DATE
+04/01/03 MBNA CORP
+REC 03/15/03 PAY 04/01/03
+TOTAL
+SYMBOUCUSIP
+KRB
+SYMBOLICUSIP
+VIAB
+QUANTITY
+-8,325
+PRICE
+41.16230
+SYMBOLCUSIP
+ESMXX"
+QUANTITY
+90,000
+QUANTITY
+677,028.81
+682.95
+677,711.76
+RATE (S)
+0.0800
+027
+PRICE
+DEBIT AMOUNT
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Cam
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD March 29,2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2003
+DEBIT AMOUNT
+340,437.76
+$-738,950.51
+$897,057.20
+DEBIT AMOUNT
+' 682.95
+682.95
+$-682.95
+$682.95
+7,200.00
+$7,200.00
+04/26/03;12:12 001
+
+
+7 of 7
+INTEREST
+DATE
+04/21/03
+INTEREST ONCREDIT BALANCE
+AT 0 3/4% 03/21 THRU 04/20
+TOTAL
+SYMBOUCUSIP
+QUANTITY
+RATE (%)
+0.7500
+STOP
+****** End of Statement******
+027
+"HOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+DEBIT AMOUNT
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD March 29, 2003
+THROUGH
+April 25, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2003
+476.74
+$476.74
+04/26/03:12:12 001
+
+
+WHOLLY OWNED SUBSIDIAR
+Bear. Steams Securities C
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ...................../...................
+Your Messages
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+February 28,2003
+3
+5
+7
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+17,566.061
+943,714
+677,029
+519,186,804
+••••••••••••
+18,308,773
+878,030
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$1.620,743
+$1.585,954
+Cash & Equivalent
+Equities
+$17,566,061
+I $16,722,819
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+do Client Services at 800-634-1428; or write to Cient Servicos at Bear, Stoama Securitios
+Corp..
+_ Brooklyn, N.Y. 11201-3859.
+SP The suremen s four ratanal purpose red de Set revere dae for portant formation.
+03/29/03;11:19 001
+
+
+Bear. Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+03/29/03:11:19 001
+
+
+3 or 7
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+5909.556.38
+630.56
+34,157.42
+34,787.98
+-630.56
+-630.56
+.....
+34,157.42
+943.713.80
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+34,255.56
+532.42
+$34,787.98
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+909,556.38
+$909,556.38
+CLOSING
+943,713.80
+$943,713.80
+027
+YEAR TO DATE
+70,313.74
+3,673.49
+•-.---.
+$73.987.23
+1,620,743
+17,566,061
+$19,186,804
+03/29/03:11:19 001
+EARED THROUGH F
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securites o
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+February 28,2003
+Your Portfolio
+Allocation
+Cash & Equivalent —
+8%
+Equities
+92%
+Unshaded portions denote debe balance andor short
+
+
+4 of 7
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+... . . .
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AOL TIME WARNER INC
+AMERICAN INTERNATIONAL GROUP
+BANK OF AMER CORP
+CITIGROUP INC
+GOLDMAN SACHS GROUP INC
+... ..
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JOHNSON& JOHNSON
+MENA CORP
+PFIZER INC
+PROCTER & GAMBLE CO
+SYMBOLCUSIP
+BSMXX
+QUANTITY
+677,028.81
+PRICE
+1.0000
+SIMBOUCUSIP
+AOL
+AIG
+BAC
+GS
+IBM
+JNU
+•......
+KRB
+PFE
+PG
+CASH
+CASH
+CASH
+.....
+CASH
+CASH
+CASH
+CASH
+......
+CASH
+CASH
+CASH
+QUANTITY
+100,000
+25,000
+30,000
+......
+27,375
+............
+12,000
+...
+20,000
+50,000
+90,000
+75,000
+aaaaaaaaaaaaaai
+25,000
+MARKET
+VALUE
+943,714
+677,029
+$1,620,743
+PRICE
+11.3500
+49.8500
+68.5800
+...
+35.4200
+70.1100
+.......
+80.7900
+57.3800
+15,4800
+31.8100
+88.6400
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28,2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28,2003
+NNUAL INCOM
+ESTATER CUREN
+***•••••*••••••••••••••
+7,921
+1.1700
+$7,921
+MARKET
+VALUE
+1,135,000
+1,246,250
+2,057,400
+969,623
+841,320
+...
+1,615,800
+2,869,000
+1,393,200
+385,75
+__... .
+2,216,000
+ESTIMATED
+ANNUAL INCOME
+4,700
+76,800
+21900
+5,760
+12,000*
+41,000
+28,800
+15,00
+... .
+41,000
+SURREN
+0.377
+3.7329
+.....
+2.258
+0.684€
+0.7427
+1.4291
+2.0672
+......
+1.8862
+1.8502
+027
+03/29/03;11:19 001
+
+
+5 of 7
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+VIACOM INC-CL B
+Total Equities& Options
+TOTAL EQUITIES
+SIMBOLCUSIP
+VIAB
+CASH
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+QUANTITY
+22,200
+PRICE
+37.6900
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+03/01/03
+03/03/03 DIVIDEND
+03/03/03 REINVEST
+03/28/03
+TOTAL
+OPENINGBALANCE
+MAKE PORTIL CLE MONEY
+RECORD 02/28/03 PAY 02/28/03
+MAKE POTLE GIE, MONEY
+REINVEST PRICE $ 1.00
+CLOSINGBALANCE
+SYMBOL/CUSIP
+BMXX
+BMXX
+MARKET
+VALLE
+836,718
+$17,566,061
+$17,566,061
+$284,881
+$19,186,804
+QUANTITY
+676,398.25
+630.56
+677,028.81
+027
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28, 2003
+URREN
+$276,960
+$276,960
+PRICE
+DEBIT AMOUNT
+630.56
+$-630.56
+630.56
+$630.56
+03/29103;11:19 001
+
+
+6 of 7
+DIVIDENDS
+
+INTERNATIONAL BUSINESS
+MACHINES CORP
+REC 02/10/03 PAY 03/10/03
+ö3/1103
+REC 02/18/03 PAY 03/11/03
+03121/03
+'AMERICAN INTERNATIONAL GROUP
+IN 0307103 PAY 03/2103
+03/28/03
+BANK OF AMER CORP
+REC 03/07/03 PAY 03/28/03
+TOTAL
+INTEREST
+DATE
+03/21/03
+TOTAL
+SYMBOL/CUSIP
+IBM
+JNJ
+AIG
+BAC
+SYMBOL/CUSIP
+QUANTITY
+20,000
+50,000*
+25,000**
+30,000
+QUANTITY
+RATE (S)
+0.1500
+0.2050
+0.0470
+0.6400
+RATE (S)
+0.7500
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+03/29/03:11:19 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securites o
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD March 1,2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+February 28,2003
+3,000.00
+10,250.00
+7,175.00
+19,200.00
+$33,625.00
+532.42
+$532.42
+
+
+7 of 7
+Your messages
+Bear, Stearns Securities Corp, Net Capital and Net Capital
+Requirements:
+A complete copy of the Bear, Stearns Securities Corp, Statement
+of Financial Condition is available on the web site
+www.bearstearns.com. Alternatively, to request a free printed copy
+please call - toll free - 1-866-299-9331,
+STOP
+End of Statement******
+LEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear. Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD March 1, 2003
+THROUGH
+March 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28,2003
+Pursuant to SEC Rule 11Ac1-6, please note the following:
+Polar Same i i seis an to routing statistics at the
+identified orders were routed for execution, whether the order was
+directed by you to that venue, and the time of the executions, if any, that
+esulted from such orders
+027
+03/29/03:11:19001
+
+
+WHOLLY OWNED SUBSIDIAR
+Bear. Steams Securities C
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary.............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .......................
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD February 1,2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31, 2003
+3
+4
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+16.722.819
+909,556
+676,398
+$18,308,773
+•••••••••••
+18,966,338
+-657,564
+here are no "Stop Loss' orders or other pending bu
+r sell open orders on file for your account
+Market Value of Your Portfolio
+$1.585,954
+$1,555,625
+Cash & Equivalent
+Equities
+$16.722,819
+$17,410,713
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp..
+_ Brooklyn, N.Y. 11201-3859.
+SP The suremen is four for ratanal furyce red de Set revere dae for portant iformation.
+
+
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+03/01/03;13:32 001|
+
+
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance,
+THIS PERICO
+5879.944.72
+718.18
+29,611.66
+$30,329.84
+-718.18
+$-718.18
+29,611.66
+$909.556.38
+Income Summary
+Dividends
+Credit Balance Int.
+THIS PERIOD
+29,758.18
+571.66
+$30,329.84
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+879,944.72
+$879.944.72
+CLOSING
+909,556.38
+.......
+$909,556.38
+.. . .
+027
+YEAR TO DATE
+36,058.18
+3,141.07
+$39,199.25
+1,585,954
+16,722,819
+$18,308,773
+.........
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD February 1,2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31, 2003
+Your Portfolio
+Allocation
+Bash & Equivalent -
+Equities
+92%
+Unshaded portions denote debe balance andor short
+
+
+OFFICE SERVICING YOUR ACOOUNT
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+... . .
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AOL TIME WARNER INC
+AMERICAN INTERNATIONAL GROUP
+BANK OF AMER CORP
+CITIGROUP INC
+GOLDMAN SACHS GROUP INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+............--.
+JOHNSON& JOHNSON
+MBNA CORP
+PFIZER INC
+PROCTER & GAMBLE CO
+SYMBOLCUSIP
+BSMXX
+QUANTITY
+676,398.25
+PRICE
+1.0000
+SIMBOUCUSIP
+AOL
+AIG
+BAC
+GS
+IBM
+JNU
+•......
+KRB
+PFE
+PG
+CASH
+CASH
+CASH
+.....
+CASH
+CASH
+CASH
+CASH
+......
+CASH
+CASH
+CASH
+QUANTITY
+100,000
+25,000
+30,000
+......
+27,375
+.............
+12,000
+...
+20,000
+50,000
+90.000
+75,000
+аладаваала:
+25,000
+MARKET
+VALUE
+909,556
+676,398
+$1,585,954
+PRICE
+11.3200
+49.2900
+69.2400
+.. . .
+33.3400
+69.4500
+......
+77.9500
+52.4500
+13,8500
+29.8200
+81.8600
+"HOLLY OWNED SUBSIDIARY
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD February 1,2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31, 2003
+ESTIMATED
+ANNUAL INCOME
+8,184 1.2099
+$8,184
+MARKET
+VALLE
+1,132,000
+1,232,250
+2,077,200
+912,683
+.............
+833,400
+...
+1,559,000
+2,622,500
+1,246,500
+2,236,500
+2,046,500
+027
+ESTIMATED
+ANNUAL INCOME
+SURREN
+4,700
+76,800
+.. . .
+21,900
+5,760
+12,000*
+0.3814
+3.6973
+2.3995
+0.6911
+•......
+.769
+41,000
+1.5634
+... .
+28,800
+2.3105
+......
+15,00
+2.0121
+....
+41,000
+... ...
+2.0034
+
+
+5 org
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+VIACOM INC-CLB
+Total Equities& Options
+TOTAL EQUITIES
+SIMBOLCUSIP
+VIAB
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+CASH
+QUANTITY
+22,200
+37.1900
+MARKET
+VALLE
+824,286
+$16,722,819
+$16,722,819
+$285,144
+$18,308,773
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+02/01/03
+02/03/03 DIVIDEND
+ö2/03/0RENVEST
+02/28/03
+TOTAL
+СЯІРТІ
+OPENINGBALANCE
+MAKE FORFELE, MONE
+RECORD 01/31/03 PAY 01/31/03
+MAKE TOLE ME, MONEY
+REINVEST PRICE $ 1.00
+CLOSINGBALANCER
+SYMBOUCUSIP
+BMXX
+BMXX
+QUANTITY
+675,680.07
+718.18
+676,398.25
+027
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD February 1,2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31,2003
+SURREN
+$276,960
+$276,960
+PRICE
+DEBIT AMOUNT
+718.18
+$-718.18
+718.18
+$718.18
+
+
+6 of 8
+DIVIDENDS
+
+TYCO INTERNATIONAL LTD
+REC 01/02/03 PAY 02/03/03
+0244/03PFIZER ----
+REC 01/17/03 PAY 02/14/03
+02/14/03 PROCTER & GAMBLE CO"
+REC 01/24/03 PAY 02/14/03
+02/27/03 GOLDMAN SACHS GROUP INC
+REC 01/28/03 PAY 02/27/03
+12/28/03
+CITIGROUP INC
+REC 02/03/03 PAY 02/28/03
+TOTAL
+INTEREST
+DATE
+12/21/03 INTEREST ONCREDIT BALANCE
+T 0 3/4% 01/21 THRU 02/20
+TOTAL
+SYMBOL/CUSIP
+TYC
+'PFE
+PG
+QUANTITY
+50,000
+RATE (S)
+0.0125
+75,0000.1500
+25,000*
+0.4100
+12,000 0.1200
+7,37
+0.2000
+SYMBOL/CUSIP
+QUANTITY
+RATE (SI
+0.7500
+STOP
+****** End of Statement******
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securites o
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD February 1, 2003
+THROUGH
+February 28, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31,2003
+625.00
+11,250.00
+10,250.00
+"1,440.00
+5,475.00
+$29,040.00
+571.66
+$571.66
+
+
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities C
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .........................................
+Your Messages
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2002
+3
+6
+7
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+Market Value of Your Portfolio
+$1,555,625
+$1.413.487
+17,410,713
+879,945
+675,680
+$18,966,338
+......
+19,529,785
+-563,447
+Cash & Equivalent
+Equities
+$17,410,713
+• $18.116.298
+Current market value
+Last statement's market value
+ere are no "Stop Loss' orders or other pending bu
+r sell open orders on file for your accoun
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp..
+_ Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal purposes rear die Set revere date for portant iformation.
+
+
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or 7
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Amount Credited
+Securities Bought
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERICO
+5738,561.03
+846,629.35
+753.62
+8,869.41
+......
+$856.252.38
+-714,115.07
+-753.62
+$-714,868.69
+141,383.69
+........
+879.944.71
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+6,300.00
+2,569.41
+$8,869.41
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+738,561.03
+$738,561.03
+CLOSING
+879,944.72
+$879,944.72
+1.••...
+027
+YEAR TO DATE
+6,300.00
+2,569.41
+---.
+$8,869.41
+1,555,625
+17,410,713
+$18,966,338
+....
+WHOLLY OWNED SUBSIDIAR
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+Equities
+92%
+Unshaded portions denote debit balance and or shart
+
+
+OFFICE SERVICING YOUR ACOUNT
+4 of 7
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+........
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AOL TIME WARNER INC
+AMERICAN INTERNATIONAL GROUP
+BANK OF AMER CORP
+CITIGROUP INC
+GOLDMAN SACHS GROUP INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JOHNSON& JOHNSON
+MBNA CORP
+PFIZER INC
+PROCTER & GAMBLE CO
+SYMBOLCUSIP
+BSMXX
+QUANTITY
+675,680.07
+1.0000
+SIMBOUCUSIP
+AOL
+AIG
+BAC
+GS
+IBM
+JNU
+......
+KRB
+PFE
+PG
+CASH
+CASH
+CASH
+.....
+CASH
+CASH
+CASH
+CASH
+......
+CASH
+CASH
+CASH
+QUANTITY
+100,000
+25,000
+30,000
+......
+27,375
+.. . .
+12,000
+...
+20,000
+50,000
+.. . .
+90,000
+75,000
+.. . .
+25,000
+MARKET
+VALUE
+879,945
+675,680
+$1,555,625
+PRICE
+11.6600
+54.1200
+70.0500
+.. . .
+34.3800
+68.1000
+...
+78.2300
+53.6100
+.. . .
+16.8300
+... .
+30.3600
+........
+85.5700
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2002
+NUAL INCON
+LET NOT CON
+8,311
+$8,311
+1.2300
+MARKET
+VALUE
+1,166,000
+1,353,000
+2,101,500
+....
+941,153
+817,200
+1,564,600
+2,680,500
+.. . .
+1,514,700
+2.277,000
+....
+2,139,250
+ESTIMATED
+ANNUAL INCOME
+4,700
+76,800
+...
+21,900
+20000
+SURREN
+).347
+3.6545
+.....
+2.326
+......
+0.7048
+0.7670
+41,000
+1.5296
+.. .
+... .
+28,800
+1.9014
+45,000
+1.9763
+....
+41,000
+1.9166
+027
+VE40
+
+
+5 of 7
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+VIACOM INC-CL B
+Total Equities& Options
+TOTAL EQUITIES
+SIMBOLCUSIP
+VIAB
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+CASH
+QUANTITY
+22,200
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT TRADE
+DATE
+DATE
+01/06/03
+12/31/02
+TRANSACTION
+SOLD
+01/06/03
+12/31/02 S0LB
+81787/63* *0162/03*•*S0LB
+TYCO INTERNATIONAL LTD
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+DISCRETIONARY ORDER
+"TYCO INTERNATIONAL L'D*''
+AVG PRICE SHOWN-DETAILS ON REQ
+ACTUAL CONFIRM TO YOUR AGEN
+DISCRETIONARY ORDER
+"YES INTERNATIONAL"L******
+AVG PRICE SHOWN-DETAILS ON REQ
+ACTUAL CONFIRM TO YOUR AGENT
+DISCRETIONARY ORDER
+PRICE
+38.5500
+MARKET
+VALLE
+855,810
+$17,410,713
+$17,410,713
+$285,271
+$18,966,338
+ESTIMATE
+INNUAL INCON
+$276,960
+$276,960
+CURRENT
+YIELD IS
+SYMBOLCUSP
+TYC
+"TYC
+QUANTITY
+-12,500
+12,500
+25,000
+PRICE
+17.01650
+
+• 1698250
+027
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2002
+DEBIT AMOUNT
+211,449.84
+213,129.79
+*422,049.72
+VE40
+
+
+6 of 7
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+DATE
+TRANSACTION
+01/10/03 01/07/03
+BOUGHT
+AOL TIME WARNER INC
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTON
+01/01/03
+Ö1/02/03 REINVEST
+61/02/03* BIMBEND
+DESCAIPTION
+OPENINGBALANCE
+.. . . .
+HARE FARMLAME, MONE
+REINVEST PRICE $ 1.00
+ARE TORTED MONEY"
+RECORD 12/31/02 PAY 12/31/02
+INCLUDED IN 2002 1099
+assassassass
+01/31/03
+TOTAL
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+01/02/03
+MBNA CORP
+REC 12/13/02 PAY 01/01/03
+TOTAL
+SYMBOUCUSIP
+KRB
+SYMBOLCUSIP
+AOL
+QUANTITY
+50,000
+PRICE
+14.16000
+SYMBOUCUSIP
+BMXX
+QUANTITY
+674,926.45
+753.62
+675,680.07
+PRICE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD January 1, 2003
+THROUGH
+January 31,2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2002
+DEBIT AMOUNT
+714,115.07
+$-714,115.07
+$846.629.35
+DEBIT AMOUNT
+'753.62
+29E9/..
+$753.62
+QUANTITY
+90,000
+RATE (5)
+0.0700
+027
+DEBIT AMOUNT
+$-753.62
+6,300.00
+$6,300.00
+VB40
+
+
+7 of 7
+INTEREST
+
+ADJ CRINT 6/21/02 - 12/20/02
+TO C 1 1/2%
+01721703 "INTEREST ON CREDIT BALANCE
+AT 0 1/8% 12/21 THRU 12/30
+01721/03
+''INTEREST ON CREDIT BALANCE
+AT 0 3/4% 12/31 THRU 01/20
+01/22/03 ADJCR INT 12/21-12/30/02
+TOTAL
+SYMBOL/CUSIP
+Your messages
+1 The in Dect, ta 2002 was computaccount
+STOP
+****** End of Statement******
+QUANTITY
+RATE (%)
+0.1250
+0.7500
+027
+DEBIT AMOUNT
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD January 1,2003
+THROUGH
+January 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2002
+1,999.69
+- 25.24
+418.28
+......
+126.20
+$2,569.41
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/bfb5f8859040972d331421fc0c54193521dcc483e2dcb14659af09a61a52f83b.receipt.json b/vision-fixhub/ds9-unparsed-05/bfb5f8859040972d331421fc0c54193521dcc483e2dcb14659af09a61a52f83b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f696454414571eeb6ad814ad672ad3f9fd56b3f0
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/bfb5f8859040972d331421fc0c54193521dcc483e2dcb14659af09a61a52f83b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12078,
+  "dataset": "marble-joined",
+  "doc_id": "bfb5f8859040972d331421fc0c54193521dcc483e2dcb14659af09a61a52f83b",
+  "engine": "marble-apple-vision",
+  "event_count": 94,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "b7ec09b09862d3d4fc7772ba4a426b87302f8e2d31b25a9b95bf99b2633d4271",
+  "output_sha256": "773bc9c6ee2a3f27986df114a375ed163c2848fa623779f866591938cf8e3144",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c09d5593c0bd070882bad6e8bb9ce9b5ba8d1490bbf45fc84c228f3573bd7150.md b/vision-fixhub/ds9-unparsed-05/c09d5593c0bd070882bad6e8bb9ce9b5ba8d1490bbf45fc84c228f3573bd7150.md
new file mode 100644
index 0000000000000000000000000000000000000000..f56243191ae74cd53ffba24ae3b0d35a875bb5e2
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c09d5593c0bd070882bad6e8bb9ce9b5ba8d1490bbf45fc84c228f3573bd7150.md
@@ -0,0 +1,132 @@
+Newsletter Center | Log In
+O site •web
+Sub yahow search RSS Feed
+button
+Mobile
+Access
+Local News
+Kalinian
+Wenther
+= Achines
+* Community Events
+* Society
+• Insider
+* Pate Falleriss
+Society Calendar
+* Business
+Beal Estate News
+: Minary Your Furtuns
+• Aris
+: Makes
+Soaphus
+* Arts Calendar
+* Fashion
+• Fashion Calendar
+• Opinion
+• Editorial Cartoon
+• Local Voices
+Kuplay
+* Letters to the Editor
+• Submit a leter
+* Lifestles
+* Announsoments
+Food
+Hare Kestaurants
+Weeth Avenue
+Butts
+Living Sinsen
+= PR Upd
+Shiny Shots
+• Our Shots
+• Your Shais
+* Ion Photos
+: Batertise
+Besies Media Kir
+= Buy Print Ad
+• Huy Online Ad
+* Contact TH
+Suhscriber Services
+Hain & FAD
+Pick up a cos
+Onder Back Issus
+Onder Phata Reprinte
+Reach the Newsnom
+Submit Announcement
+Suhmital.ener
+Real Estate
+Marketplace F Classifieds
+Automotive
+Advertise
+ENEWS
+Religion | Archives
+E-mail this page Print this page Most popular
+Advertisement
+Advertisement
+Two alleged victims of Palm Beach billionaire Jeffrey Epstein's sexual abuse have filed court
+papers seeking to unseal an agreement under which federal prosecutors agreed not to pursue
+federal charges against Epstein.
+The deferred prosecution agreement, reached between the U.S. Attorney's Office and Epstein's
+lawyers before he pleaded guilty to state felony charges, is under seal in Epstein's state criminal
+pstein, 55 is serving 18 months in jail in the state case. He pleaded guilty June 30 to two felon
+ounts: soliciting prostitution and procuring a person under 18 for prostitution
+Under the agreement, federal prosecutors agreed to defer any prosecution on federal charges until
+90 days after Epstein completes all requirements of his sentence. If he abides by all court
+
+
+conditions and restrictions, the federal case would be dropped.
+Aside from the criminal case, there are nine federal and six state lawsuits pending against the
+Manhattan money manager. All contain similar allegations: Epstein, through his employees and
+assistants, brought minor girls to his Palm Beach home at 358 El Brillo Way for erotic massages
+and sometimes sex.
+Representing victims Jane Doe No. 1 and Jane Doe No. 2, Hollywood attorney Brad Edwards
+asked the court to unseal the agreement so he can effectively represent his clients. He said he
+wants to be able to confer with other victims, their attorneys and the National Alliance of Victims'
+Rights Attorneys on strategy-
+"The victims can find no legitimate basis for the document to be sealed," Edwards wrote.
+In his response filed Wednesday, Assistant U.S. Attorney
+sought to keep the agreement
+sealed.
+"The non-prosecution agreement has never been filed under seal in federal court," and "the
+government accurately described the provisions of the agreement at the time the responses were
+filed with the court." wrote.
+On Aug. 14, U.S. District Judge Kenneth Marra ruled that the non-prosecution agreement should
+be unsealed for Edwards and any of the victims who want to see it.
+But the ruling bars Edwards and anyone else who sees the document from disclosing the terms to
+Edwards also asked the agreement be unsealed because "the government has inaccurately
+described the agreement."
+Edwards referred to an earlier filing by Assistant U.S. Attorney
+•. stating that the
+agreement contains a provision to protect the victims and that the victims were told of that
+language in October 2007.
+"Having now reviewed the non-prosecution agreement, the government's response to the victims'
+motion and the accompanying sworn declaration are simply untrue," Edwards wrote. "... The
+government should be required to correct its previously filed pleadings to accurately recount the
+non-prosecution agreement that it reached with Epstein."
+In the government's response,
+wrote that, since the document is under seal in state court, the
+motion to unseal it in federal court is irrelevant.
+"The parties who negotiated the agreement, the United States Attorney's Office and Jeffrey
+Epstein, determined that the agreement should remain confidential,"
+le also dismissed the claim that Edwards needs to unseal the agreement in order to confer with
+ther victims and their attorneys, because Marra's ruling "provides for a very simple procedure t
+allow other victims and their lawyers to see the agreement."
+contends Edwards' assertion that the government inaccurately described the agreement is
+meritless.
+He explained that there's been an ongoing dispute between Epstein's attorneys and the government
+about what comprises the agreement.
+The government believes there are three parts to the agreement executed in September 2007,
+October 2007 and December 2007; while Epstein's lawyers contend the agreement only consists
+of parts one and two.
+Victim notification letters and earlier court filings contain language from part three,
+wrote.
+Because Epstein's lawyers believe the agreement consists only of parts one and two, those were
+the portions disclosed to Edwards, said in his court filing.
+"The fact that an erroneous disclosure was inadvertently made to one petitioner after Epstein had
+already entered his guilty plea .. does not create an injury where one did not exist before,"
+By using this service you accept the terms of our Visitor Agreement.
+Copyright 2007 Palm Beach Daily News. All rights reserved.
+The Palm Beach Daily News
+Privacy Policy | About this site | Write to us
+
+
+•Cox Newspapers, Inc.
diff --git a/vision-fixhub/ds9-unparsed-05/c09d5593c0bd070882bad6e8bb9ce9b5ba8d1490bbf45fc84c228f3573bd7150.receipt.json b/vision-fixhub/ds9-unparsed-05/c09d5593c0bd070882bad6e8bb9ce9b5ba8d1490bbf45fc84c228f3573bd7150.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..878401d3572e496bc1310fb21bc44b262d9ddde9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c09d5593c0bd070882bad6e8bb9ce9b5ba8d1490bbf45fc84c228f3573bd7150.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "c09d5593c0bd070882bad6e8bb9ce9b5ba8d1490bbf45fc84c228f3573bd7150",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "dcfce693d0568106944372167dad6f54b940bbf237edeb34738b6040983d65b0",
+  "output_sha256": "b8c97c5c57ac1ffc917b00dc6e83c4133e1dbe7e00acec86fef050f2fd4142b7",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c0a7d4923cc8307e59515ad33aa450d9b54be81d1eb47e7ceb9b64654a280ac2.md b/vision-fixhub/ds9-unparsed-05/c0a7d4923cc8307e59515ad33aa450d9b54be81d1eb47e7ceb9b64654a280ac2.md
new file mode 100644
index 0000000000000000000000000000000000000000..a0c5ac6b22eb0ffc07b6f6e2792a8b9fb9fbadc6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c0a7d4923cc8307e59515ad33aa450d9b54be81d1eb47e7ceb9b64654a280ac2.md
@@ -0,0 +1,490 @@
+Statements
+
+
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .......................
+Your Portfolio Holdings
+.. . .
+Your Messages .....
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD December 1, 2006
+THROUGH
+December 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 29,2006
+1
+2
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Closing Balance
+THIS PERIOD
+$-0.02
+$-0.02
+Cash Balance Summary
+Margin
+OPENING
+-0.02
+Net Cash Balance
+$-0.02
+Portfolio Composition
+SHORT
+CLOSING
+-0.02
+....
+$-0.02
+ananaaaaaaaaaaan
+If any information regarding
+2006interest, dividends,
+miscellaneous income, gross
+proceeds or original issue
+discount is required to be
+reported to the IRS for this
+account, a Consolidated Form
+1099will be mailed to you by
+January 31,2007 or a 1042S
+by March 15,2007.
+LONG
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+027
+QUANTITY
+PRICE
+MAN. INCONE
+SPC The serena to termal pros on t rented as a potam tomation.
+12/30/06.09:23 001
+V003
+
+
+2 of 3
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+Your messages
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD December 1, 2006
+THROUGH
+December 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 29, 2006
+As part of the National Association of Securities Dealer's (NASD) Investor
+STOP
+****** End of Statement******
+027
+12/30/06 09:23 001|
+V00S
+
+
+3 of 3
+027
+12/30/06 09:23 001|
+Bear, Steams Securities Corp.
+One Metratech Center North
+V003
+
+
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summar.....•••••••••••••/
+Your Portfolio Holdings
+.. . .
+Your Messages .....
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD September 1, 2006
+THROUGH
+September 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 30, 2006
+1
+2
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Closing Balance
+THIS PERIOD
+$-0.02
+$-0.02
+Cash Balance Summary
+Margin
+OPENING
+-0.02
+Net Cash Balance
+$-0.02
+Portfolio Composition
+SHORT
+CLOSING
+-0.02
+....
+$-0.02
+LONG
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+027
+QUANTITY
+PRICE
+MAN. INCONE
+SPC The sermany start ratal prose on do not rented as a potam tomation.
+09/30/06.08:39 001
+
+
+2 of 5
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your messages
+serving shaiti ain eat ra mutuai und pays out ny shown assets.
+fund's prospectus fee table. Rule 12b-1 fees and other expenses described in
+a fund's prospectus fee table increase a fund's expense ratio and decrease the
+fund's yield, Revenue sharing fees, on the other hand, are paid out of the
+assets of the fund affiliate and not from the fund's assets and, therefore, have
+no impact on a funds expense ratio or yield.
+With respect to money market funds, Bear Steams negotiates revenue sharing
+payments separately with each fund family and not all fund families pay the
+same amount or pay according to the same formula. These payments are
+calculated based on a percentage of the dollar value of the fund assets held by
+Bear Stearns in customer accounts, Bear Stearns receives up to 0,66% per
+ear of the average daily assets of fund shares carried in customers account
+t Bear Stears. Money market funds whose affiliates do not make revenu
+sharing payments to Bear Stearns are generally not offered or recommended
+by Bear Stearns to its customers,
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD September 1, 2006
+THROUGH
+September 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+June 30, 2006
+These money market funds may in some cases have higher yields than money
+market funds whose affiliates do make revenue sharing payments. There is,
+therefore, a potential conflict of interest in the form of an additional financial
+incentive to Bear Stearns for making available to customers money market
+funds whose affiliates enter into revenue sharing arrangements. In certain
+circumstances, a portion of these revenue sharing payments may be passed
+on as compensation to certain Private Client Services account executives.
+With respect to non-money market fund shares held in Bear Stearns
+accounts, Bear Steams may receive Rule 12b-1 fees and other compensation
+described in a fund's prospectus but does not receive revenue sharing
+payments, With respect to non-money market fund shares held by certain
+Private Client Services customers away from Bear Stears, Bear Stearns does
+That in Series customa
+receive revenue sharing payments in limited circumstances, A portion of these
+revenue sharing payments are passed on as compensation to the Private
+Client Services account executive designated by the customer. Bear Stearns
+does not believe that these revenue sharing arrangements involving such
+Private Client Services customers pose a conflict of interest with respect to
+customers whose accounts are held at Bear Stearns.
+The prospectus and statement of additional information of mutual funds
+available through Bear Steams may contain additional information regarding
+revenue sharing payments made by affiliates of the fund company.
+09/30/06.08:39 001
+
+
+3 of 5
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc
+383 Madison Avenu
+New York, New York 10179
+Bear, Stearns Securities Corp. Net Capital and Net Capital Requirements:
+At May 31, 2006 and July 31, 2006, the Company's net capital of
+approximately $3.7 billion and $3,8 billion was approximately 7% and 7% of
+aggregate debit items and exceeded the minimum regulatory net capital
+532, blon an a 52-7 bilion, at esplit end 5 1.1 bilion by approximately
+A complete copy of the Bear, Stearns Securities Corp, Statement of Financial
+Condition is available on the web site www.bearstearns,com, Alternatively, to
+request a free printed copy please call - toll free 1-866-299-9331.
+027
+Bear, Steams Securities Corp.
+One Metrotech Center North
+STATEMENT PERIOD September 1, 2006
+THROUGH
+September 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+June 30, 2006
+Securities and other assets in your account are the firm's collateral for any
+margin loan made to you. If the securities and other assets in your account
+decline in value, so does the value of the collateral supporting your loan, and,
+as a result, the firm can take action, such as issue a margin call and/or sell
+securities or other assets in any of your accounts held with the member, in
+order to maintain the required equity in the account, It is important that you
+fully understand the risks involved in trading securities on margin, These risks
+include the following:
+- You can lose more funds than you deposit in the margin account.
+- The firm can force the sale of securities or other assets in your accounts).
+• The firm can sell your securities or other assets without contacting you.
+- You are not entitled to choose which securities or other assets in your
+accounts) are liquidated or sold to meet a margin call.
+- The firm can increase its "house" maintenance margin requirements at any
+time and is not required to provide you advance written notice.
+- You are not entitled to an extension of time on a margin call,
+09/30/06 08:39 001
+
+
+4 of 5
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+This statement is provided to explain Bear, Stearns & Co. Inc.'s ("BSC")
+BSC routes a majority of orders for customer securities transactions to the
+receives no cash payment or other consideration for such order routing other
+than favorable executions or executions of limit orders at no additional charge.
+STOP
+****** End of Statement******
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD September 1, 2006
+THROUGH
+September 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+June 30, 2006
+Pursuant to SEC Rule 606, please note the following:
+Bear, Stearns & Co. Inc, will post its quarterly routing statistics at the following
+web link: http://www.bearsteams.com/. Click on Individual Investor, Click on
+Equities, Click on Order Routing Practices.
+Customers of Bear, Stearns & Co. Inc, may request information on any order
+executed within the prior six months from the time of the request, Specifically,
+you may request the identity of the venue to which the identified orders were
+routed for execution, whether the order was directed by you to that venue, and
+the time of the executions, if any, that resulted from such orders.
+09/30/06 08:39 001
+
+
+5 of 5
+027
+09/30/06 08:39 001|
+Bear, Steams Securities Corp.
+One Metratech Center North
+
+
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .......................
+Your Portfolio Holdings
+.. . .
+Your Messages .....
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+1
+2
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Closing Balance
+THIS PERIOD
+$-0.02
+$-0.02
+Cash Balance Summary
+Margin
+OPENING
+-0.02
+Net Cash Balance
+$-0.02
+Portfolio Composition
+SHORT
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+QUANTITY
+PRICE
+MAN. INCONE
+027
+07/01/06:10:55 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD June 1,2006
+THROUGH
+June 30, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 31,2006
+CLOSING
+-0.02
+...
+$-0.02
+LONG
+
+
+2 of 3
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your messages
+NOTICE OF CHANGE PURSUANT TO TRUTH IN LENDING SEC RULE 10b-16
+borrowing money.
+The purpose of this notice is to advise you that effective no earlier than thirty
+(30) days from your receipt of this statement:
+If BSSC makes changes in any of the credit terms and conditions described
+written notice. The annual rate of interest you are charged may fluctuate with
+changes in the BSSC Margin Basis Rate, the BSSC Fed Funds Rate, LIBOR
+The changes in rates resulting from this fluctuation will be made without prior
+notice to you (as contrasted with changes in the credit terms and conditions,
+notice of which will be provided as described above).
+The Truth-in-Lending disclosure previously provided to you shall continue to
+apply except as specifically noted above.
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD June 1,2006
+THROUGH
+June 30, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+March 31, 2006
+1) The BSSC Fed Funds Rate shall be the rate for U.S. dollar funds, as
+such rate is determined,
+2) The rate of interest charged to you on any such credit extended to you in
+a currency other than US dollars shall be based on either (i) LIBOR, as
+ich rate is compiled by the British Bankers Association and published
+bomberg or Reuters, or (i) any other rate quoted by Reuters that
+applicable to the currency in which the obligation is denominated or, if a
+rate for such currency is not quoted by Reuters, the rate provided by
+3) In either case, the annual rate of interest will not exceed a specified
+percentage above the applicable rate, specifically (i) 3% above the BSSO
+Margin Basis Rate, (ii) 4% above the BSSC Fed Funds Rate, or (iii) 59
+bove LIBOR, any rate quoted by Reuters or the rate provided by BSSC
+cal bank, and will appear on your monthly statements
+The amount lent to you by BSSC upon which you are charged interest m
+include purchases of securities for which payment is made by check for
+which BSSC has not yet received credit.
+07/01/06:10:55 001
+
+
+3 of 3
+027
+07/01/06:10:55 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+
+
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summar.........................
+Your Portfolio Holdings
+.. . . .
+Bear, Steams Securities Corp.
+One Metratech Center North
+STATEMENT PERIOD March 1,2006
+THROUGH
+March 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 30, 2005
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Closing Balance
+THIS PERIOD
+$-0.02
+$-0.02
+Cash Balance Summary
+Margin
+OPENING
+-0.02
+Net Cash Balance
+$-0.02
+Portfolio Composition
+SHORT
+CLOSING
+-0.02
+...
+$-0.02
+LONG
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+QUANTITY
+PRICE
+MALA. INCINE
+SP The suremen s four or ratanal purpose red de Set revere date for portant iformation.
+04/01/06;10:28 001
+V906
+
+
+2 of 2
+Bear, Steams Securities Corp.
+One Metratech Center North
+027
+04/01/06:10:28 001
+V906
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/c0a7d4923cc8307e59515ad33aa450d9b54be81d1eb47e7ceb9b64654a280ac2.receipt.json b/vision-fixhub/ds9-unparsed-05/c0a7d4923cc8307e59515ad33aa450d9b54be81d1eb47e7ceb9b64654a280ac2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..27bfec15605be3711629cf4cb55637379354522f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c0a7d4923cc8307e59515ad33aa450d9b54be81d1eb47e7ceb9b64654a280ac2.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1370,
+  "dataset": "marble-joined",
+  "doc_id": "c0a7d4923cc8307e59515ad33aa450d9b54be81d1eb47e7ceb9b64654a280ac2",
+  "engine": "marble-apple-vision",
+  "event_count": 15,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "8ae456151fcddea5e1207f7fa5e7d19b91cbe410da63a20f23e689556a53d388",
+  "output_sha256": "3f0ebbd2d1ed02b7b898e723ce2deb2782c58a1aaf9a206d5ec53ce97c61cfc0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c0b9b17f3ebef14e0f8193da2c14896b26a6709a3beefff72f3778e5d77f72a5.md b/vision-fixhub/ds9-unparsed-05/c0b9b17f3ebef14e0f8193da2c14896b26a6709a3beefff72f3778e5d77f72a5.md
new file mode 100644
index 0000000000000000000000000000000000000000..f32cfda49d097f9c97c115388b78b2671758d83d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c0b9b17f3ebef14e0f8193da2c14896b26a6709a3beefff72f3778e5d77f72a5.md
@@ -0,0 +1,524 @@
+CM/ECF - Live Database - flsd
+Page 1 of2
+JMH
+U.S. Distriet Court
+Southern District of Florida (West Palm Beach)
+CIVIL DOCKET FOR CASE #: 9:08-cv-80993-DTKH
+Jane Doe No. 7 v. Epstein /
+Assigned to: Judge Daniel T. K. Hurley
+Referred to: Magistrate Judge James M. Hopkins
+Cause: 28:1391 Personal Injury
+Date Filed: 09/10/2008
+ury Demand: Plaintif
+Vature of Suit: 710 Labor: Fai
+Standards
+Jurisdiction: Federal Question
+Plaintiff
+Jane Doe No. 7
+represented by Adam D. Horowitz
+Herman & Mermelstein, P.A.
+18205 Biscavne Blvd.
+Suite 2218
+Miami , FL 33160
+Fax:
+Email
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Suite 2218
+Miami , FL 33160
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Stuart S. Mermelstein
+Herman & Mermelstein
+18205 Biscayne Boulevard
+Suite 2218
+Miami , FL 33160
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?707770149002069-L_801_0-1
+10/8/2008
+
+
+CM/ECF - Live Database - flsd
+V.
+Defendant
+Jeffrey Epstein
+
+represented by Robert Deweese Critton, Jr.
+Burman Critton Luttier & Coleman
+515 N Flagler Drive
+Suite 400
+West Palm Beach, FL 33401-2918
+Fax:
+Email:
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Date Filed
+09/10/2008
+09/10/2008
+09/15/2008
+10/03/2008
+10/03/2008
+10/03/2008
+# clear Docket Text
+1
+COMPLAINT against Jeffrey Epstein Filing fee S 350.00. Receipt#:
+544158, filed by Jane Doe No. 7.(vt) (Entered: 09/10/2008)
+2
+3
+Г
+Summons Issued as to Jeffrey Epstein. (vt) (Entered: 09/10/2008)
+NOTICE of Attorney Appearance by Robert Deweese Critton, Jr on behalf
+of Jeffrey Epstein (Critton, Robert) (Entered: 09/15/2008)
+4
+ACKNOWLEDGMENT OF SERVICE Executed as to 2 Summons
+Issued, 1 Complaint Acknowledgement filed by Jane Doe No. 7. (Herman,
+Jeffrey) (Entered: 10/03/2008)
+5
+NOTICE of Striking 4 Acknowledgment of Service filed by Jane Doe No.
+7 by Jane Doe No. 7 (Herman, Jeffrey) (Entered: 10/03/2008)
+SUMMONS (Affidavit) Returned Executed by Jane Doe No. 7. Jeffrey
+Epstein served on 9/23/2008, answer due 10/14/2008. (Herman, Jeffrey)
+(Entered: 10/03/2008)
+View Selected
+Download Selected
+PACER
+Login:
+Description:
+Billable Pages: D
+PACER Service Center
+Transaction Receipt
+10/08/2008 17:38:56
+du4480
+Docket
+Report
+Client Code:
+Search
+Criteria:
+Cost:
+9:08-cv-80993-
+DIKH
+110.08
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.p|7707770149002069-L_801_0-1
+10/8/2008
+
+
+•
+Case 9:08 cv-bu 93-DTKH Document1 Enteredul FLSD Docket 09. /200 Flage 11687 D.C.
+SEPT. 10, 2008
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.:
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+08-CV-80993-Hurley-Hopkins
+COMPLAINT
+Plaintiff, Jane Doe No. 7 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey
+Epstein, as follows:
+Parties, Jurisdiction and Venue
+Jane Doe No. 7 is a citizen and resident of the State of Florida, and is sui juris.
+This Complaint is brought under a fictitious name to protect the identity of the
+Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a
+minor.
+Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
+4.
+This is an action for damages in excess of $50 million.
+5.
+This Court has jurisdiction of this action and the claims set forth herein pursuant to 28
+U.S.C. §1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs;
+and (il) is between citizens of different states.
+6.
+Additionally, this Court has jurisdiction pursuant to 28 U.S.C. §1331 because
+Plaintiff alleges a claim under the laws of the United States. This Court has supplemental
+- 1-
+1 o17
+
+
+08-6l-80993/acey+Haph.ts1
+Entered url FLSD Docket 09) .J/2008 Page 2 of 7
+jurisdiction pursuant to 28 U.S.C. §1367(a) over all other claims set forth herein, which form part of
+the same case or controversy.
+This Court has venue of this action pursuant to 28 U.S.C. §§1391(a) and 1391(b) as a
+substantial part of the events or omissions giving rise to the claim occurred in this District.
+Factual Allegations
+8.
+At all relevant times, Defendant Jeffrey Epstein ("Epstein" was an adult male,
+approximately 52 years old. Epstein is a financier and money manager with a secret clientele limited
+exclusively to billionaires. He is himself a man of tremendous wealth, power and influence. He
+maintains his principal home in New York and also owns residences in New Mexico, St. Thomas
+and Palm Beach, FL. The allegations herein concern Epstein's conduct while at his lavish estate in
+Palm Beach.
+9.
+Upon information and belief, Epstein has a sexual preference and obsession for
+underage minor girls. He engaged in a plan and scheme in which he gained access to primarily
+economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave
+them money. In or about 2004, Jane Doe, then approximately 16 years old, fell into Epstein's trap
+and became one of his victims.
+10.
+Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted
+girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas.
+11. Epstein's scheme involved the use of young girls to recruit underage girls.
+a Palm Beach Community College student from Loxahatchee, Florida recruited girls
+ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion.
+Ms.
+upon information and belief, generally sought out economically disadvantaged
+HERMAN & MerMeLstein, P. A.
+- 2-
+
+
+Entered url FLSD Docket 09, J/2008 Page 3 of 7
+underage girls from western Palm Beach County who would be enticed by the money being offered -
+generally $200 to $300 per "massage" session - and who were perceived as less likely to complain to
+authorities or have credibility if allegations of improper conduct were made. This was an important
+element of Epstein's plan.
+12. Epstein's plan and scheme reflected a particular pattern and method. The underage
+victim would be brought to Epstein's mansion, where she would be introduced to
+Epstein's assistant. Ms.
+ould then bring the girl up a flight of stairs to a bedroom that
+contained a massage table in addition to other furnishings. The girl would then find herself alone in
+the room with Epstein, who would be wearing only a towel. He woulddirect he rigl to give him a
+massage. Epstein would then perform one or more lewd, lascivious and sexual acts, including
+masturbation and touching the girl's vagina.
+13. Consistent with the foregoing plan and scheme, when Jane Doe was 16 years old, she
+was recruited by
+to give Epstein a massage for monetary compensation. Jane was
+brought to Epstein's mansion in Palm Beach. Once there, Jane was introduced to
+who
+led her up the flight of stairs to the room with the massage table. In this room, Jane was directed by
+Epstein to give him a massage. During this massage, Epstein sexually assaulted Jane and
+masturbated. Epstein then paid Jane money.
+14.
+Jane returned on many occasions to the Palm Beach mansion to provide Epstein with
+massages for money. On those occasions, Epstein engaged in sexual contact and activity with Jane,
+which included, among other things, Epstein touching Jane's breasts, placing a vibrator on her
+vagina and masturbating himself. This sexual abuse continued over a period of approximately 18-24
+months.
+- 3-
+3017
+
+
+•
+Case 9:08-cv-8u.93-DTKH Docu....nt 1
+Entered ..! FLSD Docket 09, /2008 Page 4 of 7
+15.
+As a result of these encounters with Epstein, Jane experienced confusion, shame,
+humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
+COUNTI
+Sexual Assault and Battery
+16.
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 15 above.
+17.
+18.
+Jane Doe.
+Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane
+Doe, creating a reasonable fear of imminent peril and sexual assault.
+Epstein intentionally inflicted harmful or offensive sexual contact on the person of
+19.
+Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein's acts
+were intentional, unlawful, offensive and harmful.
+20.
+Epstein's plan and scheme in which he committed such acts upon Jane Doe were done
+willfully and maliciously.
+21.
+As a direct and proximate result of Epstein's assault on Jane, she has suffered and will
+continue to suffer severe and permanent traumatic injuries, including mental, psychological and
+emotional damages.
+WHEREFORE, Plaintiff Jane Doe No. 7 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this
+Court deems just and proper.
+22.
+23.
+COUNT II
+Intentional Infliction of Emotional Distress
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 15 above.
+Epstein's conduct was intentional or reckless.
+-4-
+
+
+Case 9:08-cv-8..93-DTKH Docur..ent 1
+Entered ... FLSD Docket 09. J/2008 Page 5 of 7
+24.
+Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds
+of decency.
+25.
+Epstein committed willful acts of child sexual abuse on Jane Doc. These acts resulted
+in mental or sexual injury that caused or were likely to cause Jane Doe's mental or emotional health
+to be significantly impaired.
+26.
+Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had
+reason to know that his intentional and outrageous conduct would cause emotional distress and
+damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing
+severe emotional distress to Jane Doe.
+27.
+As a direct and proximate result of Epstein's intentional or reckless conduct, Jane
+Doe, has suffered and will continue to suffer severe mental anguish and pain.
+WHEREFORE, Plaintiff Jane Doe No. 7 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this
+Court deems just and proper.
+COUNT III
+Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422
+28.
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 15 above.
+29.
+Epstein used a facility or means of interstate commerce to knowingly persuade,
+induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or
+sexual activity for which any person can be charged with a criminal offense.
+30.
+Epstein's acts and conduct are in violation of 18 U.S.C. $2422.
+31.
+As a result of Epstein's violation of 18 U.S.C. §2422, Plaintiff has suffered personal
+injury, including mental, psychological and emotional damages.
+- 5-
+
+
+Case 9:08-cv-8..93-DTKH Docu...ent 1
+Entered ... FLSD Docket 09 . J/2008 Page 6 of 7
+32.
+Plaintiff hired Herman & Mermelstein, P.A., in this matter and agreed to pay them a
+reasonable attorneys' fee.
+WHEREFORE, Plaintiff Jane Doe No. 7 demands judgment against Defendant Jeffrey
+Epstein for all damages available under 18 U.S.C. §2255(a), including without limitation, actual and
+compensatory damages, costs of suit, and attorneys' fees, and such other and further relief as this
+Court deems just and proper.
+JURY TRIAL DEMAND
+Plaintiff demands a jury trial in this action on all claims so triable.
+Dated: September 1D, 2008
+By:
+Jeffrey M. Herman (FL Bar No. 521647)
+Stuart S. Mermelstein (FL Bar No. 947245)
+Adam D. Horowitz (FL Bar No. 376980)
+HERMAN & MERMELSTEIN, P.A.
+10205 Всупе віча.
+.. Suite Z2I'
+Miami, Florida 33160
+Tel: |
+Fax:
+- 6-
+
+
+Origınal
+
+The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing, and service of pleading or other papers as required by law,
+except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of
+the Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)
+I(a) PLAINTIFFS
+DEFENDANTS
+JANE DOE NO. 7,
+JEFFREY EPSTEIN
+(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF
+ORANGE COUNTY
+COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT NEW YORK
+(IN U.S. PLAINTIFF CASES ONLY)
+(EXCEPT IN U.S. PLAINTIFF CASES)
+(c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER)
+ATTORNEYS (IF KNOWN)
+Herman & Mermelstein, P.A., 18205 Biscayne Blvd., Sulte 2218, Miami,
+FL 33160 M
+(d) CIRCLE COUNTY WHERE ACTION AROSE: PALM BEACH
+II. BASIS OF JURISDICTION
+(PLACE AN XONE BOX ONLY)
+• 1. U.S. Govemment
+X 3. Federal Question
+Plaintiff
+(U.S. Government Not a Party)
+• 2. U.S. Govemment
+• 4. Diversity
+Defendant
+(Indicate Cilizenship of Parties in Item
+HI)
+9:08CN 80993-Hturley-bopkins
+III. CITIZENSHIP OF PRINCIPAL PARTIES
+PLACE AN X IN ONE BOX FOR PLAINTIFF
+(For Diversity Case Only)
+AND ONE FOR DEFENDANT
+Incorporated of Principal Place of
+0 4
+Cilizen of This State
+Business in This State
+Citizen of Another State
+02 0 2
+Incorporated and Principal Place of 0 5 0 5
+Citizen or Subject of a Foreign Country 0 3 0 3
+Business in Another State
+Forsign Nation
+06 0 6
+IV. CAUSE OF ACTION
+DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY.
+CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE.
+ACTION FOR SEXUAL ASSAULT UNDER 18 U.S.C. §2422 AND STATE LAW
+IVa. _5 days estimated (for both sides) to try entire case
+V. NATURE OF SUIT
+(PLACE AN XIN ONE BOX ONLY)
+A CONTRACT
+A TORTS
+D 110 nearance
+00I
+120 Marke
+130 Miller Act
+140 Negotable Instrumen
+150 Rect
+avery of Overpaymeni
+5 Enforcement of
+Jupiters
+152 Recovery of Dolaed
+Studant Leans (Eed.
+Veterana) B
+• 163 Recovery of Overpayment
+of Velaran's Beneles B
+1800 me Coac
+O 165 Contract Product Liabilly
+PERSONAL INJURY
+• 310 Alplane
+1302 Personal Injury-Med Malpractic
+© 315 Alpiane Product Liabily
+1305 Personal Injury Product Liable
+• 320 Assault, Libel 5 Slander
+• 330 Federal Employes" Liably
+injury Product Liabilly
+O 340 Marine
+O 345 Marine Product ilablly
+PERSONAL PROPERTY
+• 350 Motor Vetkie
+© 365 Molar Vehicle Product Labity 370 Other Fraud
+X 360 Other Personal Injury
+Truth in Lending B
+10380
+Other Persorel
+Property Danage
+0335 Property Damage
+Product Liabily
+B FORFEITURE
+PENALTY
+• 010 Apriculture
+03 820 Oler Food & Drag
+C3 025 Drag Related Ser
+ef Property 21 USC 401
+0 630 Liquor Laws
+• 64D R.R. & Track
+A BANKRUPTCY
+A OTHER STATUS
+422 Apper: 28 USC 158
+0 423 Windrawal 28 USC 157
+D3 800 Oter
+A REAL PROPERTY
+A CIVIL RIGHTS
+B PRISONER PETITIONS
+A PROPERTY RIGHTS
+D 820 Copyrighes
+D 830 Palent
+1] 640 Trademark
+B SOCIAL SECURITY
+0 851 HIA (1395m
+0 052 Black Lung (0231
+D BS3 DIWC/DIWW (405(g5
+03635 R$405
+• 210 Land Conder
+mnation
+DI
+220 Forecosure B
+000
+240 Torts to Land
+245
+Tort Product Liabilly
+200 All Oner Real Property
+442 Employment
+© 443 Housing/Accommodations
+440Cther Chi Righis
+• 510 Motions so Vacale Sentenc»
+Habeas Corpus
+836 Death Ponally
+• 540 Mandamus & Other*
+0 500CM Rita
+A LABOR
+X710 Fair Labor Slandards
+© 720 Labor Management
+Relalions 9
+T30 Labor Mangeme
+porting & Declosu
+Act
+O 740 Ralway Labor Acl
+© 780 Other Labor Legation
+O 791 Empioyee Ret Ing.
+Securly Act B
+A FEDERAL TAX SUITS
+8100
+Status Reappointment
+Andoust
+• 450
+Commence/OC Rates/eic. B
+460
+Deportation
+• 470
+Compt Organe asona
+• 810 Selective Senice
+O 850 Securties/ Commodbes/
+Exchange
+• 875
+Customer Challenge
+D 891
+Agricultural Acts
+Economic Sublization Act
+Embonmental Matters
+BE
+Energy Allocation Act
+Freedom of Information Act
+Appeal of Fee Detonation
+Under Equal Access b
+Justica
+• 550 Corallutionally of Suta
+Sautes
+• 800
+Other Stadory Actens*
+A or B
+Declaratory reef and wate law claims
+for defamation
+02. Removed from 13. Romanded from 81; Relied
+• 6. Multidistrict Litigation
+Proceeding
+State Court
+Appellate Court
+Appeal to District Judge from
+• 5. Transferred from another district
+(Specify)
+Magistrate Judgment
+"l. REQUESTE
+N COMPLAIN
+CHECK IF THIS IS A
+• CLASS ACTION
+• UNDER F.R.C.P. 23
+DEMAND $
+Check YES only if demanded in X YES
+omplaint
+IURY DEMAND
+• NO
+VIL.
+RELATED
+CASE(S) IF ANY
+(See Instructions):
+Jane Doe 2 v. Jeffrey Epstein
+Jane Doe 3 v. Jeffrey Epstein
+Jane Doe 4 v. Jeffrey Epstein
+Jane Doe 5 v. Jeffrey Epstein
+DATE
+Sept 10,
+2008
+UNITED STATES DISTRICT COURT
+REV. 9/94
+(SEE ATTACHED)
+JUDGE KENNETH A, MARRA
+DOCKET NUMBER 08-CV-80119-MARRA-JOHNSON
+JUDGE KENNETH A, MARRA
+DOCKET NUMBER 08-CV-80232-MARRA-JOHNSON
+JUDGE KENNETH A MARRA
+DOCKET NUMBER 08-CV-80380-MARRA/JOHNSON
+JUDGE KENNETH A MARRA
+DOCKET NUMBER 08-80381-CIV-MARRA/JOHNSON
+SIGNATURE OF ATTORNEY OF RECORD
+FOR OFFICE USE ONLY: Receipt No..
+Amount: 3500
+Date Paid:
+
+_Milfp:
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/c0b9b17f3ebef14e0f8193da2c14896b26a6709a3beefff72f3778e5d77f72a5.receipt.json b/vision-fixhub/ds9-unparsed-05/c0b9b17f3ebef14e0f8193da2c14896b26a6709a3beefff72f3778e5d77f72a5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..fa949d7f6e6bc7707a6957ebde9a9816a67554af
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c0b9b17f3ebef14e0f8193da2c14896b26a6709a3beefff72f3778e5d77f72a5.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -385,
+  "dataset": "marble-joined",
+  "doc_id": "c0b9b17f3ebef14e0f8193da2c14896b26a6709a3beefff72f3778e5d77f72a5",
+  "engine": "marble-apple-vision",
+  "event_count": 13,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "8f81f0b513b4f80e72579e7f91cb0bcf683dd4fd3f50cfeeefd1bfd4b10db80f",
+  "output_sha256": "e56dde0f364a0c5f96add63fa0a9ef00f6076e37cbe58bfbdbe2fdbf16d7cb9f",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c0ba8209d379cfc20a05c383f540ff7ec80064e381e270e2c9cb847220901932.md b/vision-fixhub/ds9-unparsed-05/c0ba8209d379cfc20a05c383f540ff7ec80064e381e270e2c9cb847220901932.md
new file mode 100644
index 0000000000000000000000000000000000000000..a4e9787f8343446f4a84451337978518dda38d5b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c0ba8209d379cfc20a05c383f540ff7ec80064e381e270e2c9cb847220901932.md
@@ -0,0 +1,6369 @@
+BOC HCU
+ЛОСТ #: 600
+h.t tAi"
+:022990
+#at* s9.1
+•*!4i
+1 -
+-903
+402
+
+
+OG
+403
+
+
+404
+
+
+
+003.260.10
+405
+
+
+406
+
+
+40775
+11/6/3004
+407
+
+
+408
+
+
+POETHE
+niversal We
+ather & Aviation, Inc.
+Pisand Two Hundred Nincty-Five ard No: J0g**
+4 Aviation, Ine
+tundred Fifty-One and 23:100**
+ton, In:
+10773
+1N200
+
+§ **2.295.46
+10774
+TUV/20
+6 35012271
+409
+
+
+
+025e ррo
+*e pospi
+іс вре пиле
+93/11282004
+
+
+00e9
+
+1:90: 1*
+
+BADER DIF
+**537.23
+- Hundred Thirty-Seven and 22:100**
+19/10.9/11.9.20.913.9/30l
+411
+
+
+89698
+
+
+
+413
+
+
+414
+
+
+9L t
+(ності ТР
+Hostil
+DOINT
+
+416
+
+
+tand Scien Hundred Se
+and 20/100
+
+C-D 4TH FL
+and 20:100
+/ 301101
+10789
+11/8200
+**1,717.20
+DOLEARE
+fal
+417
+
+
+
+
+33460-30 1000036
+0F88850 3 1
+GENES
+418
+
+
+419
+
+
+420
+
+
+C-O 4TH FI
+BARTHE
+Dave Rodger
+To Thoused Seven tundred Staý-Sex and 40/1000***
+54106/14,04 m916.404)
+
+11N/200
+* **1,766,40
+421
+
+
+422
+
+Fordeprataly
+
+
+
+32
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FI. 33480
+LAST STMT
+11/30/04
+--- LAST PAGE
+ACCOUNT NO
+SINT DATE
+12/31/04
+4 E 90
+PG
+1
+COLONIAL BANK APPRECIATES YOUR BUSINESS.
+THANK YOU FOR BEING OUR CUSTOMER.
+* *
+******•* * * CHECKING ACCOUNT SUMMARY
+LEVIOUS BALANCE
+39,129.29
+225,000.00
+SEVERED PAS
+126,911.75
+IDING BALANCE
+137,217.54
+* CHECKING ACCOUNT TRANSACTIONS *
+DEPOSITS AND OTHER CREDITS
+ITE.....•
+..AMOUNT. TRANSACTION DESCRIPTION
+:/15
+125, 000.00 INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+1/21
+100, 000.00 INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+CHECKS
+ITE.. CHECK NO..
+1/17
+10779
+1/03
+10785*
+•AMOUNT
+DATE..CHECK NO..
+6,500.00 12/23
+10793*
+2,450.17 12/31
+10808*
+OTHER DEBITS
+ITE..
+..AMOUNT. TRANSACTION DESCRIPTION
+1/22
+100,757.58 OUTGOING WIRE DEBIT
+NES LLC 0110132758
+DATE..
+11/30
+12/03
+12/15
+12/17
+* CUSTOMER BALANCE SUMMARY
+... BALANCE
+DATE...
+39,129.29
+12/21
+36,679.12
+12/22
+161,679.12
+12/23
+155, 179.12
+12/31
+•. BALANCE
+255,179.12
+154,421.54
+152,217.54
+137,217.54
+* * * *
+AVG COLL BALANCE
+104,098.10
+YTD INTEREST PAID
+****
+CHENO/ATM CD
+AMOUN
+*'2,204.0
+15,000.00
+CHKNO/ATM CD
+423
+
+
+Каря
+424
+
+
+425
+
+
+.... =
+426
+
+
+427
+
+12952 7231236663
+RORZARTATH
+
+428
+
+
+429
+
+
+VEGE INC.
+2004
+430
+
+
+431
+
+
+32
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FL 33480
+LAST STNT
+12/31/04
+ACCOUNTE NO
+STMT DATE
+01/31/05
+28 E 90
+PG
+COLONIAL BANK APPRECIATES YOUR BUSINESS.
+HANK YOU FOR BEING OUR CUSTOMER
+******* * * CHECKING ACCOUNT SUMMARY
+EVIOUS BALANCE
+137,217.54
+2 CREDITS
+110, 000.00
+29 DEBITS
+208,989.50
+SERVICE CHARGES
+*********
+AVG COLL BALANCE
+93,622.58
+YTD INTEREST PAID
+.00
+¡DING DERRST PAID
+38,228:04
+* *
+CHECKING ACCOUNT TRANSACTIONS*********
+DEPOSITS AND OTHER CREDITS
+«TE.
+. AMOUNT. TRANSACTION DESCRIPTION
+CHKNO/ATM CD
+/03
+50, 000.00 INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+/06
+60, 000.00 INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+CHECKS
+sTE.. CHECK NO.
+/07
+10786
+/04
+10794*
+/12
+10795
+/03
+10796
+-/05
+10797
+./04
+10799*
+/10
+10800
+./04
+10801
+/03
+10802
+./12
+10803
+-/05
+10804
+/05
+10805
+./18
+10806
+-/05
+10807
+DATE. CHECK NO.
+54.00 01/18
+10810*
+492.90 01/18
+10811
+395.00
+01/18
+10812
+227.45
+01/14
+10813
+5,184.48
+01/06
+10814
+4,112.63
+01/20
+10819*
+30,409.68
+01/10
+10820
+2,092.33
+01/10
+10821
+421.00
+01/18
+10822
+2,038.94 01/10
+10823
+3,280.10 01/11
+10825*
+477.17 01/14
+10826
+216.49 01/11
+10827
+204.00 01/11
+10828
+OTHER
+DEBITS
+ITE....
+...AMOUNT. TRANSACTION DESCRIPTION
+......AMOUNT
+4,365.20
+б,630.00
+58,459.22
+2,304.00
+2,174.72
+60.00
+19,459.55
+3,142.96
+117.81
+547.30
+45.04
+175.00
+1,717.20
+185.33
+CHENO/ATM CD
+./06
+60,000.00
+OUTGOING WIRE DEBIT
+BANYAN AIR SERVICES INC 0110132758
+432
+
+
+
+
+---
+****
+DATE...
+12/31
+01/03
+01/04
+01/05
+11/0
+1/0
+LAST STMT
+12/31/04
+LAST PAGE
+ACCOUNT NO
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH EL 33480
+STMT DATE
+01/31/05
+28 E 90
+PG
+* * CUSTOMER BALANCE SUMMARY ** * * * * * * * *
+• BALANCE
+DATE..
+• BALANCE
+137,217.54
+01/10
+114,937.27
+186,569.09
+01/11
+112,989.70
+179,871.23
+01/12
+170,725.48
+01/14
+110,555.76
+168,550.76
+01/18
+108,076.76
+38,28B.04
+168,496.76
+01/20
+3B, 228.04
+433
+
+
+51.04 JAN 242
+$1071
+434
+
+
+435
+
+104201 05 00739 FIRST CAHIBBEAN INTE
+
+
+NEW YORK, NY 10022
+BADER DIS Time Avialia Corporation
+* Ninety-Two and 90/100*
+acon Corporation
+(11/2204)
+10794
+12/20/2004
+$ **492.90
+436
+
+
+437
+
+
+9034847-28
+
+457 MADISON AVE,
+NEW YORK. NY 10022
+BE Trade Air Coperati
+red Ninuty-Five and 00/100
+(11/1504)
+10795
+
+**191.00
+438
+
+
+1281E984
+32335 11293
+
+439
+
+
+107
+457 MADISON AVE.
+NEW YORK, NY 10022
+Lation Acupciates, Ltd
+and 45/
+440
+
+
+
+
+441
+
+
+SARTA THAS
+10797
+43-36L,
+NEW YORK. NY
+10022
+
+BARO'
+Pon Autenty cNY& NU
+Thousand One Hundred Frghay-Four and an. ler
+**5,184.48
+DOLLAF
+(0367}4| (lł0804;
+442
+
+
+FLAPER
+0009 129
+082057p08
+
+0@1201060ci
+OHHERCH
+CHENRY HILE SNO
+2026013673<
+
+
+
+C-O 4TH PL
+YORK
+NY :1002
+(5101210a)
+PHOE
+ING
+CO4TH FL
+MADISON AVE
+AYOM KY
+10021
+it and 63/100
+(102744
+444
+
+
+29607-306 лx-50
+58C0
+887: 990 T70 px-30
+445
+
+
+10800
+BADER
+JEGE ING,
+C-O.4TH FL
+457 MADISON AVE.
+EM YCAK, NT 1100
+Bion,
+Lne
+11 22020н
+
+446
+
+
+L+t
+M1001150e
+S 14357544382
+
+
+008
+
+22590
+
+PHOREAN KAMIN
+
+
+457 MADISON AVE.
+NEW YORK, NY 10022
+Nite A: Day Sodan
+Hundred Twenty-One and corice
+*10079 (11/02(M)
+10802
+12/20/2001
+5**421,00
+DO
+448
+
+
+ABEL
+DELE
+8/822609k1
+449
+
+
+457 MADISON AVE.
+NEW YORK, NY: 10022
+SABER DES
+- Dave Rodgen
+544(10/5/04 011/2404)
+10803
+/207
+200
+**2,031.54
+450
+
+
+451
+
+
+
+
+NEW YORK, NY 10022
+N.A. Propeny: Inc
+Three Theisand Two Hundred Eighty and 10:100
+2004 (12.0604)
+10804
+SIVE
+:2.20.2004
+5 **1,280:10
+452
+
+
+S8T6291990
+
+476-6100
+453
+
+
+10806
+457 MADIBON AVE
+NEW YORK, NY 10022
+12/20/2004
+AT &.T Wireless
+For Hundred Seventy-Seven and
+6**47711
+454
+
+
+1 661601200
+TES: 590W49
+
+1455
+
+
+ALMATVEST INA
+ClEOUerNTRE
+1080
+2-0 4TH F1
+NEW YORK, NY10022
+MAte Linted ,
+Sixicen and
+12/202004
+PO DOX TIDKE OYEMCLEY
+PLACE BIRVOM3ICMA 8: 220
+70-764
+456
+
+
+
+
+FLIK
+GOT
+457
+
+
+NEW YORK. NY 10022
+Canenal Avionics
+ed Four and 00l0g**
+5801910 (11/1x.04)
+10807.
+12/20/2004
+5 **304:00
+458
+
+
+é25129T995
+1i 03*
+
+459
+
+
+¡JEGE INC.
+C-0 4TH FL
+ST MADISON AVE
+/YORK, NY 10/22
+Bed 5rishwar richardinal Serices, Ine
+sand Three Hundred Sixty-Five
+2066-82 0112401)
+LORING.
+EW YORK NY 10002
+Ins
+MEGE INCI
+C-O LTH FL
++ST MADISON AVE
+NEM CONCH 10020
+108
+122M
+2004
+12m2o0
+460
+
+
+
+
+
+4.0
+
+
+0153
+3:347
+44-56116
+
+
+1081
+NEW YORK, NY 10022
+12/22/2004
+s **
+23040
+Three Hundred Four and 00/100
+462
+
+
+463
+
+1153
+
+
+
+10814
+12/23200
+1471
+464
+
+
+FT2E1 20159
+465
+
+
+y Ors
+466
+
+
+
+TI8255629
+00362.
+467
+
+
+4TH
+468
+
+
+469
+
+
+Cru ATH FL
+YORK. NY 10022
+1082
+12/02004
+1*44130
+470
+
+
+5601 0ML
+H00
+471
+
+
+VEGE INC
+C+O 4TH FL
+ST MADISON AVE
+EW YORK, NT 1000
+Tride Ale Corporation
+1082
+іззолові
+**(15 g0
+472
+
+
+3281 162,56 6
+
+CEBLER
+Ja -100%
+473
+
+
+NEW YORK, NY 10022
+sociațes, LId
+JEGE ING
+L C-O 4TH FL
+NEW YORK, NY: 10022
+coal : 2011035
+BADER OPE
+HEGE INC:
+C-O STH FL
+457 MADISON AVE.
+NEW YORK/NY 10022
+Jet Aviation A
+sociates, Lid.
+Irod Eighty-Five and 33/100
+$
+10827
+1250-200
+$
+0821
+
+20820
+12/30200
+71H5.33
+474
+
+
+.W4CA003
+CÀ NIDN THN
+-3013 10%
+*oste
+Sereosar
+1950
+BBT8068
+6LES6
+*LA20185629
+475
+
+
+32
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FL 33480
+--
+LAST STMT
+01/31/05
+ACCOUNT NO
+STMT DATE
+02/28/05
+22 € 90
+PG
+1
+COLONIAL BANK APPRECIATES YOUR BUSINESS.
+THANK YOU FOR BEING OUR CUSTOMER
+REVIOUS RALANCE
+******* * CHECKING ACCOUNT SUMMARY
+38,228.04
+1 CREDITS
+380, 000.00
+23
+DEBITS
+332, 096.65
+SERVICE CHARGES
+.00
+NDING BITANCE
+INTEREST PAID
+.00
+86,131.39
+******** CHECKING ACCOUNT TRANSACTIONS
+DEPOSITS AND OTHER CREDITS
+ATE....•:....AMOUNT. TRANSACTION DESCRIPTION
+2/14
+380, 000.00 INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+CHECKS
+ATE.. CHECK NO
+2/04
+10829
+2/07
+= 10830
+2/03
+10831
+2/01
+10832
+2/01
+10833
+2/01
+10834
+2/02
+10835
+2/07
+10836
+2/08
+10837
+2/08
+10838
+2/07
+10839
+DATE.. CHECK NO
+445.08 02/07
+10840
+450.00 02/09
+10841
+10,000.00
+02/07
+10842
+200.40
+02/09
+10843
+1,725.30
+02/24
+10844
+1,144.29
+02/16
+10845
+4,092.17
+02/28
+10853*
+3,280.10
+02/28
+10854
+1,254.91
+02/24
+10856*
+2,029.00 02/28
+10860*
+421.20 02/23
+10861
+OTHER
+DEBITS
+ATE.
+AMOUNT. TRANSACTION DESCRIPTION
+2/24
+74.61 CLARKE AMERICAN
+CHK ORDER
+**********
+AVG COLL BALANCE
+84,770.42
+YTD INTEREST PAID
+.00
+******
+CHENO/ATM CD
+• AMOUNT
+823,68
+687.00
+176.46
+4, 462.88
+209.51
+276, 000.00
+15,939.30
+1,694.65
+2,128.61
+579.21
+4,278.29
+CHENO/ATM CD
+476
+
+
+32
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FL
+33480
+LAST STMT
+01/31/05
+LAST PAGE
+ACCOUNT NO
+STMT DATE
+02/28/05
+22 E 90
+PG
+2
+*****
+* CUSTOMER BALANCE SUMMARY
+********
+DATE........ BALANCE
+DATE......... BALANCE
+01/31
+38,228.04
+02/09
+7,035.57
+02/01
+35,158.05
+02/14
+387,035.57
+02/02
+31,065.88
+02/16
+111, 035.57
+02/03
+21,065.88
+02/23
+02/04
+20,620.80
+02/24
+106,757.28
+104, 344.55
+02/07
+15,469.36
+02/28
+86, 131.39
+02/08
+12,185.45
+477
+
+
+457 MADISON +1
+NEW YORK, NY
+10CO2
+AT & T Wircher
+rod Forty-Five and ON t0)**
+10829)
+8156-
+E. 192005
+s*14500
+Hung/he
+478
+
+
+
+4 T40
+296606k48
+
+479
+
+
+10830
+JAK 07 100:2
+YEW
+BRDER de Track Aur C'ompiratiom
+tred Fiffy an/ 00 100*
+1 29:2005
+; ** 450 00
+*** DOLLARS
+(13/02/04)
+.. impile
+480
+
+
+120AE
+481
+
+
+482
+
+
+483
+
+
+457 14 40, 461
+SEX _2. 1.
+BALER THE
+Ired and 40-100
+1 2011035
+457 MADISO*, AVE
+NEW YORK N7 10022
+One Hundred Forty-ford and 2u 1rar*
+NEW YORK, NY *977
+MELO ...
+10832
+1 19 35
+*?.40
+10834
+1. 19:2005
+DOLLARE
+10833
+**:.73500
+484
+
+
+Wapenoe vei
+S10001
+-SLEZSVLT
+N::50
+78022SCZ4T
+IN3V3S300NEN
+Cedelto
+485
+
+
+Te TTe TITO
+10835
+4TH FL
+NEW YORI NY 10022
+26
+$ *°4
+.092.17
+486
+
+
+TeSTICLER
+487
+
+
+NA Property, in
+10836
+1/252001
+1*1.200.10
+488
+
+
+68₽
+
+
+depaset
+
+Deie Rod
+wr ad 91/100
+7/04 lo (/14/05)
+10837
+1/21/2009
+490
+
+
+491
+
+
+457 MADISON ALL.
+NEW YORK. MY
+10022
+GE Begia Serylors, Inc.
+Nine and 00/100*
+D11 (12/23.04)
+10838
+1/27/2009
+• **2,02900
+492
+
+
+493
+
+
+HIGE INC.
+C-O 4TM FL
+NEW YORK, NY 10022
+ales, Led.
+10839
+1/21/2003
+3*421,20
+DOC
+May /ille
+494
+
+
+E098 V
+95379
+0970376883-
+6013
+NENA HLEA
+SITENE LER
+
+En AFFICE
+953TY.
+
+496
+
+
+
+497
+
+
+MEGE INC.
+C-0 4TH FL
+457 MADISON AVt
+VEW YORK NT 10022
+Larace Office of Contral items '
+ley: Sit Those an in 11)
+10845
+: yes
+Hany fill
+498
+
+
+TRAI
+EMERGRE
+499
+
+
+
+
+
+STATEMENT PERIOD
+March 1, 2005 - March 31, 2005
+JEFFREY E EPSTEIN
+358 EL BRILLO MAY
+PALM BEACH FL 33480
+mproved the overall loc
+you Mane. Comba
+Account Summary
+Previous Balance
+Total Credit(s)
+Total Debit(s)
+Service Charge
+Ending Balance
+Account Details
+58.31.30 Averago Colleciod Balanco
+- 33,605.20
+- 0.00
+$ 52,526.19
+$ 63,279.44
+Checks Paid a indicatos check missing in sequence
+10500
+
+10857 A
+10858
+10859
+11000 A
+3/31
+3/3
+3/4
+3/4
+3/21
+20,394.27
+82.50
+3,240.18
+1,508.62
+1,276.73
+1,357.20
+2/28
+3/3
+3/4
+BALANCE
+86,131.39
+82,891.21
+80,107.B6
+377
+3/21
+3/29
+11001
+
+11006
+11007
+11000
+3/21
+3/21
+3/21
+3/29
+3/31
+AMOUN
+96.45
+230.01
+90.78
+881.43
+4,469.03
+BALANCE
+59,713.59
+57,939.15
+57,077.72
+BALANC
+32,52B.18
+OLOMAL BANK, N.
+EMBER FOR
+500
+
+
+Page 1of2
+Gabriel are you con 205
+www.colanlafbark.com
+STATEMENT PERIOD April 1, 2005 - April 30, 2005
+30034 д00
+• Colonial Bank appreciatos
+your business. Thank yo
+for being our Customer
+JEFFREY E EPSTEIN
+58 EL BRILLO WA
+ALM BEACH FL 334B
+Account Summary
+Previous Balance
+Total Credit(s)
+Total Debil(s)
+Service Charge
+Ending Balance
+$ 52,526.19 Average Collected Balance
++ 200,000.00
+- 228,100.68
+- 0.00
+$ 24,425.51
+$ 45,365.23
+Account Details
+Deposits and Other Credits
+4/12
+DESCHIPTION
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+200,000.00
+Checks Paid 4 indicates check missing in coquence
+11002
+11003
+11004
+11009 A
+11010
+11011
+11012
+11013
+11014
+11015
+11016
+11017
+11018
+11019
+4/12
+4/12
+4/12
+4/11
+4/11
+4/11
+4/11
+4/11
+4/11
+4/11
+4/11
+4/11
+4/13
+4/20
+COLONA BANK, MA
+401.91
+1,408,10
+3,015.94
+1,099,64
+770.75
+594.04
+1,352,46
+1,427.65
+362.23
+513.03
+1,725.30
+1,725.30
+11020
+11021
+11022
+11023
+11024
+11025
+11026
+11027
+11028
+11029
+11030
+11031
+11032
+11033
+4/18
+4/20
+4/18
+4/25
+4/20
+4/21
+4/21
+4/21
+4/21
+4/20
+4/25
+4/25
+4/22
+4/25
+501
+
+
+
+www.coionialbunk.com
+STATEMENT PERIOD April 1, 2005 - April 30, 2005
+089 16000
+Checks Paid (continuod)
+4 indicates chack missing in sequence
+11034
+4/22
+11036 A
+4/27
+11037
+4/25
+Other Debits
+DESCRIPTION
+4/12
+OUTGOING WIRE DEBIT
+NES LLC 0110132758
+3/31
+4/11
+4/12
+4/13
+BALANCE
+52,526.19
+42,956.79
+61,125.87
+57,125.87
+4,373.66
+547.56
+168.48
+11038
+11039
+11040
+4/28
+4/25
+400.00
+412.20
+2,662.50
+177,003.97
+4/18
+4/20
+4/21
+4/22
+BALANCE
+54,827.71
+43,742.56
+40,450.73
+34.283.47
+4/26
+BALANCE
+25,785.33
+25,385.33
+24,837.77
+24.425.51
+OLONIAL BANK, N
+EMBER FDI
+502
+
+
+
+COLONIAL BANK.
+The image(s) below are for your informational purposes only and may not accurately reflect the
+11019
+235R 38 Trai Air Caparadis
+Then Thousand Sere Hooded Hasty Or sel Miser-
+3076/83510
+... SOLLARS
+Hokier
+. 633596356B 3235447305
+Aara free
+
+."..=
+11022
+* DOLLARS
+
+1S: 1984. 35
+HA 040-61243
+
+503
+
+
+11023
+
+434497736 04-22-05 027l 07
+SALER & Dump tar
+BOLLARS
+11024
+SAGER S
+Tee Flaund Fety in N
+11025
+11026
+MALANS
+11027
+BABER THE
+
+
+
+
+
+
+1427478 #4/27/89
+2200
+
+9 ELE
+831945043h00 i
+
+
+
+504'
+
+
+11028
+On Taramd Fre
+IALIAs
+#D 1029F
+
+06ID132758r
+20000 20 7 264/
+11030
+4107MS
+• DOLL
+108I819950
+11031
+, ам
+11032
+2/IMI29 142211
+
+
+
+2319hE0€3400
+
+
+
+: *= !
+
+Re Menans
+
+
+411 3,701)
+
+5400614289 6315633412
+505
+
+
+11033
+- paLp
+11034
+Apt 200(09081
+11035
+
+BOLLARs
+11037
+SAGAR Br
+, "4
+11038
+Was Landern
+
+
+
+
+9UUA050966TD
+
+0OV
+
+
+FOR DEPOSIT ONLY
+
+
+
+sanst on
+
+
+.,':
+Thit fister
+506
+
+
+
+11039
+Fair Thesed Tender ad 1a8+
+...;
+FREE PUMOR
+
+
+6640192948 -
+11040
+Tara Th
+
+
+507
+
+
+
+astions abouf your account, e
+lonial Connection: 877-502-22
+STATEMENT PERIOD May 1,2005 - May 31, 2005
+→ Colonial Bank appreciates
+your business. Thank you
+for being our Customer.
+JEFFREY E EPSTEIN
+358 EL
+BRILLO WAY
+PALM BEACH FL 33480
+Account Summary
+Previous Balance
+Total Credit(s)
+Total Debils)
+Service Charge
+Ending Balance
+Account Details
+Deposits and Other Credits
+DESCRIPTION
+5/24
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paid * Indiates check missing in sequerice
+11041
+11042
+T1043
+11044
+11045
+5/31
+5/11
+5/17
+5/12
+5/11
+AMOKINT
+5,123.86
+224.93
+48.00
+4,184.62
+108.63
+4/30
+5/10
+5/11
+BALANCE DATE
+24,425.51
+5/12
+24,013.43 5/17
+23,352.18
+5/10
+$ 24,425.51
+Average Collected Balance
++ 50,000.00
+- 16,392.17
+- 0.00
+5 58,033.34
+$ 33,359.92
+AMOUN
+50,000.00
+11046
+11047
+11048
+11049
+11050
+BALANCE
+19,187.57
+19,139.57
+18,726.00
+5/10
+5/11
+5111
+5/19
+5/31
+5/24
+5/31
+412.08
+129,54
+198.14
+413.57
+5,568.80
+BALANCE
+68,726.00
+58,033.34
+508
+
+
+
+The image(s) below are for your informational purposes only and may not accurately reflect the
+This is not an original document or a substitute check
+11041
+BASER 38"
+Mum Humped
+
+
+Tan landed Torey-Fours 93100
+11042
+
+Han Pile,
+1270B28960
+11043
+Paty-Eigh and o0
+'+ '
+
+
+11044
+=**063264171
+Pe These Done lasted Say To a tate
+
+YTO THE DOIN
+FORK BA
+509
+
+
+Hey talk
+05/01/2001
+11049
+- runs
+
+3063
+She Ties ros
+
+
+
+
+510
+
+
+
+11050
+"EEN
+
+: 94539120-2071 5)
+HILL, H3
+1517
+511
+
+
+Pago 1 of2
+Gustin mout one 7-80,205
+STATEMENT PERIOD
+June 1, 2005 - June 30, 2005
+Colonial Bank apprecia
+i business. Thank y
+for being our Customer.
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FL 33480
+Account Summary
+revious Balanc
+olaf Credits
+- Telal Debie(s)
+Service Charge
+Ending Balance
+Account Details
+Deposits and Other Credits
+6/17
+DESCRIPTION
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paid + indicates check missing in sequence
+10501
+11051 4
+T1052
+11053
+11054
+11055
+11056
+11057
+6/8
+6/1
+62
+6/17
+6/7
+64B
+6/9
+6/16
+1,068,00
+2,200.00
+4,373.65
+17,272.15
+657.90
+234.09
+4,853.53
+5,525,00
+Dally Balance Summary
+5/31
+B/1
+ONE FAK, NA.
+55,033.34
+$ 5B,033.34 Average Collected Balance
++ 50,000.00
+- 48,099.79
+- 0.00
+$ 59,333.55
+$ 53,774.36
+50,000.00
+11058
+11059
+11060
+11061
+11062
+11063
+11064
+6/13
+6/B
+6/27
+6/21
+6/24
+6/22
+6/22
+6/2
+BALANC
+51,459.00
+6/7
+50,001.78
+6/8
+6/9
+3,037.20
+1.725.30
+$47.56
+392.43
+2.025.00
+399.03
+1,308.94
+BALANCE
+47.774.39
+42,920.86
+512
+
+
+
+Colate shout you 0-02-205
+STATEMENT PERIOD June 1, 2005 - June 30, 2005
+Daily Balance Summary (continued)
+8/13
+6/16
+6/17
+BALANCE
+39,883.66
+34,359.66
+67,086.51
+8/21
+6222
+624
+BALANCE DATE
+66,894.08
+61,906.11
+6/27
+50.881.11
+BALANCE
+59,333.55
+OLOMA
+EMBE
+1 BANK, NA.
+513
+
+
+
+The image(s) below are for your informatious opthe sen only and may not accurately reflecthe
+10501
+
+Carlyke Ga
+20000 06800*
+
+POLIOSIN
+КОБЗА3222
+0110 432758•
+/0000 2 20000/
+11052
+БA62R 2
+Tow Thes
+
+PALARS
+
+11053
+win lane
+Зная Thous
+•.. 0L0
+
+Hey fate
+
+within than
+514
+
+
+1/06/2001
+06/06/2005
+1105฿
+BASER 2I
+Undrenal Wante
+wim TX IG1RI
+He here
+11057
+
+Fine Thana
+1105B
+Vanes
+There These Thing-Seria wed 1511
+
+2202-1071 P4-1D
+
+
+
+
+
+
+
+1% RODE M
+
+•
+515
+
+
+11059
+SUREN
+# 71183004304024011
+11060
+47200
+fellarita
+DOULANS
+11061 |
+SMER 32 Unional Diner @ Are to
+Thra Had Marty Moe and nog.
+11063
+#399.03Ak
+- DOLLARS
+
+:
+
+
+
+
+
+1 тіс-ока по-10
+
+
+(e300 27
+
+2145PAR
+
+
+516
+
+
+
+11064
+For Theway Thee Indu Eider t
+
+- PALARS
+
+9000T1T5Y3
+ONLY
+
+Thank you for
+nking at Colonial Bank.
+517
+
+
+
+Outsin about you 27-0222
+www.coloniafank.com
+STATEMENT PERIOD July 1, 2005 - July 31,2005
+Colonial Bank appreciates
+our busines
+Thank you
+i being our Custom
+JEFFREY E EPSTEIN
+58 EL BRILLO MA
+ALM BEACH FL 3348
+Account Summary
+Pool or alo
+•Total Debit(a)
+Service Charge
+Ending Balance
+Account Details
+Deposits and Other Credits
+7/21
+DESCRIPTION
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paid 4 indicates check missing in sequence
+10502
+11065 A
+11066
+11067
+1106B
+7/28
+7/5
+7/5
+7/5
+7/18
+1,468.01
+650.25
+48.45
+1,725.30
+3,117.20
+Other Debits
+7/21
+DESCRIPTION
+OUTGOING WIRE DEBIT
+NES LLC 0110132758
+$ 59,333.55 Average Collected Balance
++ 200,000.00
+- 227,093.39
+-0.00
+$ 32,240.16
+$ 48,797.53
+200,000.00
+11069
+11070
+11071
+11072
+11073
+7/18
+7/22
+7/26
+7/25
+7128
+80,64
+343.78
+352.66
+410.37
+823.40
+218,073.33
+518
+
+
+
+Colonions are your aron 2al
+STATEMENT PERIOD
+July 1, 2005 - July 31, 2005
+10010 Boo
+6/30
+715
+7MB
+9,333,55
+56,908.55
+53,711.71
+722
+7725
+35,294.60
+34,884.23
+7128
+HALANCE
+34,531.57
+32,240.16
+COLONIAL
+BANK, NA.
+MEMBER FON
+
+519
+
+
+
+The image(s) below are for your informatius of thosen only and may not accurately reflect the
+10502
+мени
+SALAR Za Bankrien
+
+Гераа Пров 182019088 - 443481)
+
+
+08400002LA
+06/30/2005
+11067
+BABIR SIR
+:= :
+
+Hey file.
+6540387533 0976720754
+520
+
+
+
+11068
+Ther These Do limbed tor
+
+97537-m
+
+HILL, A3
+Hey Ble
+25:42
+11059
+0l. Ben 10000 i8t
+P0:1069
+Hey fille
+11070
+Thana Marshed Serip Than tad 2810
+• *3378
+: 3070₴41
+Pr13001
+11071
+BOLLARS
+- 3066117590
+NGE OFERATIONS ADGE
+49703440/46.
+AYTO THE DACEND
+NORTH FORK BANE
+
+Within Ara
+11072
+35283 Cople to
+Tow Ilse Ten and 1010
+
+
+521
+
+
+
+13073
+
+Kaka
+AZARE 46938
+522
+
+
+Pago 1 of 2
+Culein about your 87-02-205
+ACOOUNT NUMBER
+STATEMENT PERIOD August 1, 2005 - August 31, 2005
+Colonial Bank appreciates
+your business. Thank you
+for baing our Castorar.
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FL 33480
+Account Summary
+Previous Ealanco
+Total Credits
+Total Debit(s)
+Service Charge
+Ending Balance
+Account Details
+Deposits and Other Credits
+8/9
+DESCRIPTION
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+8/16
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paid
+* indicates chock missing in sequence
+10503
+
+11075
+11076
+11077
+11078
+11079
+11080
+8/18
+8/1
+8/5
+B/3
+8/3
+8/3
+8/3
+8/18
+86,387,00
+4,388.94
+7,811.60
+446.00
+1,725.30
+1,828,50
+481.20
+6,262.50
+$ 32,240.16 Average Collected Balanc
++ 150,000.00
+- 121,015.36
+- 0.00
+$ 60,624,80
+$60,431.76
+50,000.00
+100.000.00
+11081
+11082
+11083
+11084
+11085
+11086
+11087
+11089 A
+8/16
+8/16
+8/15
+8/30
+8/31
+8/31
+8/31
+831
+229.00
+397.77
+4,892.06
+2,089.00
+148.50
+180.20
+725.00
+3,022.79
+OLONIAL BANK. N.
+EMBER FON
+523
+
+
+
+Colonie are your sun -2a
+STATEMENT PERIOD
+August 1, 2005 - August 31, 2005
+COOTS E00
+7/31
+8/1
+8/3
+B/S
+BALANCE
+32,240.16
+8/9
+27,851.22 B/5
+23,37022
+8/16
+15.568.62
+8/18
+8/31
+BALANCE
+65,301.29
+60,624.80
+524
+
+
+
+The image(s) below are for your informational purposes only and may not accurately reflect the
+TD 10503
+I DOLLARS
+ри пора.
+C-1404 Px-30
+
+Per These Thra loaded Fee Eight wed Me
+11074
+MOLARS
+B95 sen
+
+Helle
+
+BASIR IN Take ta Coper
+Sane Thrand Eight Insted E
+11075
+** DOLLARS
+
+° 6336121657
+=.
+
+11076
+DOLLARA
+1 30638
+
+
+
+525(
+
+
+IMATH.
+G1628 pMAeleoa Apertoss lad
+Tw TMaw Lami
+11077
+POLLANs
+Apae
+- - .=
+11078
+BAL-DR 30* Thae
+Ceu Thane
+Key file
+SALIR JH
+. -42
+11079
+KALANE
+SAGIR T eTioperiontyem
+Tee Hended Tonip-Hine ad 00/104
+11081
+DOLLANS
+I03 53746902
+htt://or19055ncrcss/inauirv/servlet/inauirv
+
+: + 3
+
+
+
+
+
+
+36635236L0
+
+SE/W15209n
+9300043395 trags
+0200618182-6140421149
+526
+
+
+LET HAMITSEENEY
+HA. Prosity, Be
+Fear Thaland Tige Hashes
+11082
+HEALS
+totale
+11083
+Haile
+11084
+Toe Than Dig 100
+BASER ENE
+One landed food
+11085
+COLLARS
+11086
+61S7MI
+SOLAR
+B462R Tias, bain Comin
+мено.
+
+:. =
+
+
+
+
+!!*;
+4E0552983
+
+
+
+AN: 17 S80. 2Б.
+
+* ::
+
+: 7740182345
+Sim In
+3677o336re
+
+527
+
+
+
+11087
+Ties Am
+, "TaM
+..• ARLAAS
+
+#÷ : g
+
+11089
+BP JN seanada
+Thee Theeend Sa Hanke Twen-Tee mod 1811
+. *42»
+-. DORLAAS
+SN DMAn
+
+
+528
+
+
+STATEMENT PERIOD Saptember 1, 2005 - September 30, 2005
+© Colonial Bank appreciates
+your business. Thank you
+for baing our Customer.
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FL 33480
+Account Summary
+Previous Balance
+Total Credits)
+Total Debil(s)
+Service Charge
+Ending Balance
+$ 60,824.80 Average Collected Balance
++ 150,000.00
+- 178,263.16
+- 0.00
+$ 32,361.64
+Account Details
+Deposits and Other Credits
+DESCRIPTION
+9/28
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paid a indicades check missing in sequence
+10504
+
+11000*
+11091
+11092
+11093
+11094
+11095
+9/2
+2/1
+3/1
+9/19
+9/19
+S/B
+20,870.00
+2,654.00
+9,225.00
+2,095.41
+279.60
+1,200.00
+1,272.00
+1,725.30
+Other Debits
+DESCRIPTION
+9/28
+OUTGOING WIRE DEBIT
+NES LLC 0110132758
+LONIAL BANK, A
+MBER FI
+11096
+11097
+11098
+11099
+11100
+11101
+11102
+9/8
+S/S
+9/8
+9П7
+9/9
+927
+9/23
+$ 21,156.24
+AMOUN
+50,000,00
+50.40
+48.45
+123.42
+441.92
+3,837.20
+529.25
+4,892.06
+129,279.08
+529
+
+
+Pago 2 of 2
+Coleniol Gahet you: 7-02-20
+STATEMENT PERIOD
+September 1, 2005 - September 30, 2005
+O001s 500
+8/31
+9/1
+9/2
+9/7
+BALANCE
+60,824.80
+46,710.30
+26,040.39
+24,326.47
+LATE.
+5/19
+8/23
+ALANC
+2,378.8
+18,541.61
+17,062.01
+12,160.95
+9/27
+9/28
+BALANCE
+11,640.72
+32,361.64
+HLONA
+IDA, A.
+*02022/560150
+530
+
+
+
+The image(s) below are for your informatitus of theises only and may not accurately reflect the
+10504
+Sandy Theeroad The Hendod Soviety and
+* DOLAn
+
+My Pale
+
+11088
+SALER 23°
+Tri
+. 3078618390
+ala Prot
+
+531
+
+
+BAL 2R 33"
+11092
+DrELANS
+11093
+SALIA 3UE
+
+Hey ala
+11094
+I file
+11095
+1308
+5015389I0
+011096 400633332229 0310352750*
+Ar tale
+
+http://or|9055ncrcss/inquiry/servlet/inquiry
+.306979807947
+1334 PK-18
+:==
+
+
+
+4431006241:
+
+
+
+
+
+
+, NA
+DER
+
+532
+
+
+Hayfie.
+11101
+SALER Men detect all a re
+Han fille
+11101
+883 Cople Windee
+MORLARS
+http://orl9055ncress/inquiry/servlet/inquiry
+70817B852
+830
+
+
+HES RUIn
+30799฿3460
+• 5940693682
+
+
+a331152
+WILL MI
+533
+
+
+11102
+BALER UN
+Per Thinded lyle Handed Hay To and 156180
+• ORLANE
+
+
+
+000+5E113961
+534
+
+
+
+Contin one you: -502-205
+STATEMENT PERIOD
+belate 1, 2005 - Octobor 31, 2005
+Colonial Bank appreciate
+our business. Thank yo
+for being our Customer.
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FL 33480
+Account Summary
+Previous Balance
+Total Credits
+Total Debits)
+Service Charge
+Ending Balance
+Account Details
+Deposits and Other Credits
+DESCRIPTION
+1018
+DEPOSIT
+Checks Paid a indicatas check missing in sequence
+11103
+11104
+11105
+11106
+11107
+10B
+1016
+103
+103
+10/17
+4,650.00
+380.30
+108.75
+5,683.76
+2,045.09
+Other Debits
+DESCRIPTION
+10/17
+ANALYZED SERVICE CHAG
+$ 32,361.64 Averago Collected Balance
++ 27,100.00
+- 20,437.54
+- 0.50
+$ 39,023.60
+S 29,813.48
+AMOLINT
+27,100.00
+11110 A
+
+11113
+11114
+10/27
+10/27
+10/25
+10/27
+AMOLNT
+46.42
+2.242.03
+4,892.06
+0.50
+OLONIAL BANK N.
+MEMBER FOI
+535
+
+
+Page 2 of2
+Colorin ahet ione: 87-502- 2265
+STATEMENT PERIOD Getaber 1, 2005 - Detaber 31, 2005
+9/30
+10/3
+10/6
+BALANCE DATE
+32,361.64
+10/17
+26,569.13
+10/18
+21,538,83
+1025
+BALANCE
+39,023.60
+COLONIAL
+POLONA FANK, NA.
+536
+
+
+
+The image(s) below are for your informational purposes only and may not accurately reflect the
+1510:
+BURD
+Theme Han
+
+: 3
+POLION COBSAA3222C 0LIDA321
+11105
+Or lashed Eid 10180*
+
+
+11106
+These she tided They There wal 341
+smArtin deeded He
+DOLLARs
+
+
+
+537
+
+
+11107
+Ture Thered Forty The wed grou
+
+
+11110
+0L0001
+BASER 84 Montainty for a M
+Tap-lin and tridoris
+40238
+221 времен Дрова
+
+POLLIAZY
+D:10132758
+
+ЗБИ не триу
+Pow Thread Tige Boated Viany
+11113
+
+42105
+
+There Wasted Eighy Figheen 30100-
+11114
+
+
+Thank you for bank
+ing at Colonial Bank.
+9832
+190D.
+
+1547 +
+538
+
+
+
+www.coloniaibark.com
+STATEMENT PERIOD November 1, 2005 - Movember 30, 2005
+• Colonia/ Bank appreciatos
+your business. Thank you
+for being our Customer.
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FL 33480
+Account Summary
+Previous Balance
+Total Crecils)
+Total Debit(s)
+Service Charge
+Ending Balanco
+Account Details
+Deposits and Other Credits
+11/1
+DESCRIPTION
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paid
+A indicates check missing in sequence
+10505
+
+11109
+
+11115 л
+11/21
+11/2
+11/9
+11/1
+11/7
+275.00
+50.02
+1,481.34
+1,715.84
+2,000.00
+10/31
+11/1
+11/2
+BALANCE
+39,023.60
+87,307.76
+87,257.74
+MENDEA DANK, NA.
+$ 39,023.60 Average Collected Balance
++ 50,000.00
+- 0.00
+$ 44,223.23
+$ 64,342.51
+AMCUNT
+50,000.00
+11116
+11117
+11118
+11119
+11/15
+11/14
+11/16
+11/21
+16,430.00
+11.512.50
+6,443.61
+4,892.06
+11/7
+11/9
+11/14
+ALANCE
+35,257.74
+83,776.40
+72,263.90
+11/15
+11/18
+11/21
+BALANC
+55,833.90
+49,390,29
+44,223.23
+539
+
+
+
+• COLONIAL. BANK.
+The image(s) below are for your informational purposes only and may not accurately reflect the
+10505
+BALER 31 tie Clone Trangerion Silen, As
+inst Guess Ne 1001
+3066199040 0333246673
+Hangall
+#D 0505/ C0G7001530G 04032750
+
+
+SERIE
+Tay wil
+: 3062092720
+
+SMEAR ON Trade die Corpora
+Co Than
+11109
+
+
+BALER DA" Dream
+Co Those Saladed one/ 14
+11111
+ITUTES
+:=:
+
+
+540
+
+
+11115
+.r:i
+DALAAS
+11116
+== :
+
+522-4261
+11118
+GET THE
+Se Thensard Four
+
+
+11119
+For ThesE landed hing-Tes ad 31090
+- DALANS
+icn
+
+
+
+43 1813: 4TH
+
+
+
+fatella.
+981-930115.
+541
+
+
+
+Colonin and on 7-022265
+www.coloninbank.com
+STATEMENT PERIOD December 1, 2005 - Decomber 31, 2005
+Colonial Bank appreciate
+your business.
+Thank yo
+for being our Customer.
+JEFFREY E EPSTEIN
+358 EL BRILLO MAY
+PALM BEACH FL 33480
+Account Summary
+Previous Balance
+Total Credil(s)
+Total Debit(s)
+Service Charge
+Ending Balance
+$ 44,223.23 Averago Collected Balanco
++225,000.00
+- 226,900.50
+- 0.00
+$ 42,322.73
+Account Details
+Deposits and Other Credits
+12/19
+DESCRIPTION
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paid
+* indicates check missing in saquence
+1132 A
+11120 4
+11121
+11122
+11123
+11124
+11125
+12/15
+12/22
+126
+12/7
+12/12
+12/15
+12/15
+12/14
+15,000.00
+663.51
+260.10
+730.00
+397.56
+2.472.61
+7,500.00
+5,168.00
+Other Debits
+DESCRIPTION
+12/22
+OUTGOING WIRE DEBIT
+NES, LLO 0110132758
+GONNA FRANK, MA.
+11126
+11129 A
+11130
+11131
+
+11134
+
+11138
+12/14
+12/19
+1228
+12/27
+1227
+12/30
+12/30
+12/27
+$ 58,299.70
+225,000.00
+958.23
+3,407.06
+2,300.00
+
+181,021.74
+542
+
+
+
+estions about your account, e
+lonial Connection: 877-502-22
+STATEMENT PERIOD Decomber 1, 2005 - December 31, 2005
+0001E
+11/30
+1216
+7207
+1212
+HALANCE DATE
+44,223.23
+12/14
+43,963.15
+12/15
+43.233.13
+12/19
+42,835.57
+12/22
+BALANCE
+-36,409.34
+12/27
+11,436.70
+12/2B
+231.544.64
+12/30
+49,850.39
+BALANCE
+43,414.13
+43,114.13
+42,322.73
+COLORA FBANK, NA.
+543
+
+
+
+The image (s) below are for your informatitus of thoses only and may not accurately reflect the
+11128
+Flea Thanand IN B01100*-*11
+Tinamid Trai Ca, Is.
+HI POLARS
+.A15
+
+
+RC+1958 PX-18
+MUBARA
+11121
+
+Soon Handed Thing ad ta
+•... DELAS
+
+11122
+: 3068485410
+the hand imm
+MALANS
+Aritals
+
+544
+
+
+FOR
+46177
+мона дисто
+2121
+53170
+
+
+ROCARI
+Б2ТTI
+Зава О 09998905
+H IN 14
+A vanda.
+9ZTTT
+1-03
+OpEBES290є
+1==:
+2651 250525
+:H:
+GĘ268Tİ20E
+lina
+2157
+BANTION
+mart. "
+CZIII
+DONDE SANC
+
+11130
+Ture ilnind ed Wis-
+LABORATEEMT EMEMEE
+ENGR Dl Bales Armande
+Thre Thorasd Fow Huntel Sre
+Balea Arsah
+13/1 430
+, *3,431 08
+.. DOLANA
+
+SALIRIM SCig Jerm Oma 110
+Toa Tknaw Tier Ilost and ter
+11133
+121-4500
+I. DOLATE
+w[u .
+11134
+SALA D ea tene, hoe
+Toe ilushed Tones/ 6913-
+DOLANS
+: ": i
+
+
+
+
+
+BUHS
+NH-NH
+
+Ij BI
+
+
+42152
+MENE
+ХРОБІ
+546
+
+
+
+11137
+**WI
+BA 10313-04° EP 12/20/206
+Five Handed Fled o100
+-..
+11130
+
+, 1252).
+es iS 07246 1 ei8 20 ee
+forma house They Tighted 3011M-
+Mo sulades Bodys, be
+L.-10303271
+Thank you for banking at Colonial Bank
+547
+
+
+
+The image(s) below are for your informatitus of trpose only and may not accurately reflect the
+11136
+• "Ант»
+per LARs
+
+
+1113
+
+• 31»
+Our landed Tony Car wed 10v50
+
+11140
+BISONE
+
+07623401-1
+
+0M200
+01X-1
+
+http://or19055ncrcss/inquiry/scrvlet/inquiry
+548
+
+
+1114
+10/70
+11144
+The Hundred Thing There water
+11145
+BAIR IN LargE Marine
+Tee landed Slay Eye wed Tired
+• *101
+11145
+SALAR 2*
+DALLAS
+FR1 has
+2e1 An
+
+- 5740734223
+
+д ін 3
+
+
+
+:3060500360
+6648510859 3410245160
+
+
+•
+549
+
+
+11147
+O These The Hundred Siry-Figher wad to
+11148
+шини
+paud
+Lay Elaine
+4CO638132226
+0410132758Y
+4000 DUGO
+Time liai
+
+MILOSON
+Change Que
+11151
+SAGER ON Baine
+Endaway Jeontay Of SaM
+05M: M:2
+HiS now now
+SPІ тс-1348 РЕ*
+
+
+39733
+
+-:
+
+-20вO PN-18
+
+DA DEPOSIT DAL
+A O G MAMTENINGE OPERAT ICA6 40
+CAN PORK BART
+- 90, 92 NI
+550
+
+
+
+11153
+SER 2*
+Copier Vein
+*3411
+3062/13860
+DeLLARS
+
+
+hank you for banking at Colonial Bank.
+551
+
+
+Pago 1 of 1
+Contin one your 7-502-24
+www.calonia/bank.com
+STATEMENT PERIOD February 1, 2006 - February 28, 2006
+your busiess.
+for being our Customer.
+EGE INI
+JEFFREY E EPSTEI!
+358 EL BRILLO WAY
+PALM BEACH FL 33480
+Account Summary
+• Previous Balance
+Total Credit(s)
+Total Debil(s)
+Service Charge
+Ending Balance
+$ 15,507,35 Average Collected Balance
++ 350,000.00
+- 301,965.14
+- 0.00
+363,542.21
+Account Details
+Deposits and Other Credits
+DESCRIPTION
+2/1
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+2/22
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paid a indicates chack missing in sequence
+11155
+11156
+11157
+17158
+211
+29
+2/8
+2117
+285,000.00
+992.00
+991.86
+5,184.84
+1/31
+211
+BALANCE
+16,507.35 2/8
+315,507.35
+2/9
+30,507.35
+2/17
+11160 A
+17161
+11182
+11164 A
+2/27
+2/27
+2/24
+2/27
+BALANC
+29,515.40
+
+222
+2124
+2/27
+MEMBER FRANK, NA.
+FINANCIAL STRENGTH IN LOCAL. HANDS
+$ 99,547.99
+
+50,000.00
+4,351.48
+3,166.32
+1,460.64
+818.00
+BALANC
+73,338.61
+71,878,01
+63,542.21
+552
+
+
+
+6 COLONIAI. BANK.
+The image(s) below are for your informatious op the fem only and may not accurately reflect the
+
+50025
+11156
+628 real Wither & Alien, tol
+i Had Way Ten pod born.
+наке
+•'=-
+
+#28BŻ80G
+
+3111903782c
+
+11157
+SALER Darkne
+Mise in Minty-Oes and BrIN"
+- PALAS
+
+1931:
+Daine Cellege
+
+• -
+doe
+553
+
+
+11160
+518 DUel fincher di Ario, in
+Four Thrased There Hunded Tily-Der and 1160
+
+" E"
+523704014 041864604
+
+11161
+5628 Parentary ally A ne
+Three Thousand One Handed ley-Sie and 1018-
+381150-3149572
+
+1t1n3978
+
+22430051 31
+11154
+
+
+Thank you for banking at Colonial Bank
+
+
+нині" -
+- 3111983792€
+554
+
+
+Page 1 of t
+www.colonislbank.com
+STATEMENT PERIOD
+Tantch 1, 2006 - March 31, 2005
+Colonial Bank appreciatos
+your business. Thank you
+for baing our Customer.
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FL 33480
+Account Summary
+Previous Bulance
+Total Credits)
+Total Debit(s)
+Service Charge
+Ending Balance
+$ 63,542.21 Average Collected Balance
++ 200,000.00
+- 46,596.57
+- 0.00
+$ 216,945,64
+Account Details
+Deposits and Other Credits
+3/30
+DESCRIPTION
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paid
+4 indicates chock missing in sequance
+11159
+
+11165 A
+11166
+3/2
+3/1
+3/8
+3/13
+37,557.81
+75.75
+140.52
+300.11
+3/1
+3/2
+BALANCE
+63,542.21
+63,466.46
+25,908.65
+3/8
+3/13
+3/20
+11167
+11168
+11169
+11170
+3/8
+3/13
+321
+3/20
+BALANCE DATE
+25,260.93
+3/21
+19,885.98
+3/30
+17,789.86
+LONIAL BANK, /
+MBER FL
+FINANCHL STRENGTH IN LOCAL HANDS
+$ 35,071.50
+200,000.00
+507.20
+5,184.84
+844.22
+1.896.12
+BALANCE
+16,945.64
+216,945.64
+555
+
+
+
+COLONIAL BANK.
+The image(s) below are for your informational purposes only and may not accurately reflect the
+11159
+316/204
+
+
+Watch Fork
+
+Berney-Fire aal 10/100*1
+11163
+3120N
+.. DORLARS
+: 3075990000
+18.
+
+.193
+
+Our Flashed Party and sanser
+31165
+•.. POLLARS
+7909718591731 Fx-10
+
+11166
+BORLARS
+ПЕНО віЛ
+
+
+556
+
+
+35400
+
+To Thade
+
+11168
+... POLLARS
+62303
+
+The Thoused Che Hashed Fighto an
+H.A, Papery, in
+
+i..
+
+11169
+Chingte Tole
+
+
+ДРАКОД.
+11170
+One Thinsanel Flyie ibada ed Now Sin and 13100-
+:т:
+PRIS BEDLAN 3123
+00-150 M-42
+3060456060 25502320
+1517
+SAY HILL, H3
+
+• -
+557
+
+
+
+Centre out you around als
+www.colaninlbank.com
+STATEMENT PERIOD
+April 1, 2006 - April 30, 2006
+enclosed insert.
+JEFFREY E EPSTEIN
+358 EL BRILLO NA
+PALM BEACH FL 33480
+Account Summary
+Previous Balance
+Total Credit(s)
+Total Debil(s)
+Service Charge
+Ending Balance
+$ 216,945.64 Average Collecled Balance
++ 130,000.00
+- 259,56B.42
+- 0.00
+$ 87,377.22
+Account Details
+Deposits and Other Credits
+4/11
+4/18
+DESCRIPTION
+DEPOSIT
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+• Checks Paid * indicates check missing in sequence
+10506
+11171 A
+11172
+11173
+11174
+11175
+11176
+11177
+11178
+11179
+11180
+4/25
+4/6
+4/6
+4/5
+4/6
+4/4
+4/14
+4/17
+4/17
+4/20
+4/17
+184.00
+421.20
+385.78
+198.00
+337.84
+2,080.00
+327.27
+9,500.02
+25.20
+300.00
+3,300.00
+COLD BANANA.
+4/14
+4/13
+4/14
+4/17
+4/20
+4/27
+4/24
+4/28
+4/28
+4/28
+$ 107,589.47
+80,000.00
+50,000.00
+2.476.12
+6,981.40
+1.188.00
+76.89
+5,184.84
+558.30
+38.240.45.
+558
+
+
+Pago 2 of2
+Corin about your 0-0n2-205
+www.coloninlbankc.com
+STATEMENT PERIOD April 1, 2006 - April 30, 2006
+Other Debits
+DESCRIPTION
+4/6
+OUTGOING WIRE DEBIT
+NES, LLC 0110132758
+3/31
+4/4
+4/5
+4/5
+4/11
+BALANCE
+216,945.64
+214,856.64
+214,058.64
+27,314.82
+107,314.82
+AMOLINT
+186,199.00
+
+4/13
+4/14
+4/17
+4/18
+4/20
+TO RANGE ARE
+98,342.03
+4/25
+82,964.47
+4/27
+132,964.47
+428
+132,138.99
+BALANCE
+126,954.15
+126,770.15
+126,693.26
+87,377.22
+COME FBIK, NA.
+
+559
+
+
+
+• COLONIAL BANK
+The image(s) below are for your informatitus opurposes only and may not accurately reflect the
+10506
+EAST 1 homer Alone, le
+Повормт Альм, Ім
+DORLARS
+2301 person
+
+treate in
+
+
+Tea flashed Too One ad 301
+POLAND
+11172
+SAR JoE Wallarm
+
+11173
+One Handed rey Might are poliser
+=.4s.x=
+
+- 1213372363
+H11990724
+560
+
+
+76
+The Flushed The Seas matu
+Depole Winke
+11174
+PLANE
+Tea Tended light Him sad taro
+11175
+DO LANS
+FOLLITER
+1113222g 0100132758-
+/00000 1 27277
+11177
+SAR 3M The to Cogni
+Mes These For handed and 81500
+Than Andries Capornia
+11178
+
+
+
+
+
+Д: 8º 80 215.
+
+
+491 PX-38
+
+
+1433066955 - 1022231601
+561
+
+
+11179
+1*120
+BASER J4
+Sykes lung
+11180
+3A528 22° prel
+There Themsed Ther
+11181
+Too Thrused Tow Hear
+ONLARS
+F0L1162
+
+0410432758r
+700006 98 440/
+11183
+4/1000
+- GLAND
+: =:
+
+35386 135453
+
+:т:
+
+3071173520 #
+тіс-арка -10
+тач понят
+307-8
+
+
+HILL, MJ
+562
+
+
+90 98 0v
+899
+D
+4441
+50-38 1860-394
+BEGTOCACTO 0922988906
+6A79220199
+12
+1213;
+009962120E
+: м:
+LESE-SOTOT
+681
+096869920€
+1:.=
+952550008/
+2928€1
+ESSESH ILSEIGIETEE9
+*49184372,179 aol ninosa 022611420€
+.. sea a m
+Stared
+06TIT
+TEAMDALEMENADE TEA TENS
+RECEIP
+LOTTT
+PETERSE
+Onim
+Mara
+MODELS
+Sara
+
+
+11133
+
+#-N+
+1797401-
+1502 m
+564
+
+
+Contine about you on cal
+ACCOUNT NUMBER |
+STATEMENT PEFIOD May 1,2006 - May 31, 2006
+• Colonial Bank approciate
+our business. Thank yo
+for being our Customer.
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FL 33480
+Account Summary
+revious Balanc
+Total Credin(s
+Total Debil(s)
+Service Charge
+Ending Balance
+Account Details
+Deposits and Other Credits
+DESCRIPTION
+5/11
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paid & Indicates chack missing in saquence
+10507
+
+11189
+11191*
+11192
+11195 A
+11196
+11197
+1119B
+5/17
+5/10
+5/4
+5/1
+5/8
+5/B
+5/16
+5/12
+5/17
+82,000.00
+202,00
+38.11
+33.73
+93.33
+342.23
+260.10
+83.13
+1.167.14
+$ 87,377.22 Average Collected Balance
++ 100,000.00
+- 95,529.88
+- 0,00
+$ 91,847.34
+$ 108,273.97
+100,000.00
+11199
+11200
+11201
+11202
+11203
+11204
+11205
+11206
+5/15
+5/11
+5/12
+5/18
+5/18
+5/22
+524
+5/30
+2,143.00
+1,678.95
+1.167.63
+233.11
+5,184.84
+97.29
+183.81
+141.48
+OLONAL BANK, N..
+(EMBER FOI
+565
+
+
+. Page 2 ol2
+Gabani about your rsun al.
+STATEMENT PERIOE
+- May 31,2006
+4/30
+5/4
+5/8
+5710
+BALANCE
+87,377.22
+87,343.49
+B7,305.38
+86,869.82
+36,667.82
+5/12
+5/15
+5/16
+5/17
+BALANC
+85,088.87
+183,530.11
+181,395.11
+181,135.01
+97,667.87
+5/22
+5/24
+5/30
+DILOWAL BANK, NJ
+TEMBER FON
+566
+
+
+
+COLONIAL. BANK.
+The image(s) below are for your informational purposes only and may not accurately reflect the
+67928750-
+SAR 3*
+Tra Hooked
+Be spinin
+30624g
+212C-1060 рx-10
+
+BE +2190
+
+38
+000S
+03576
+55421655-
+2000-50
+Cargot
+• 4крс
+HATIONAL AIR TRAFFIC SERVICES
+11189
+DOiLARS
+
+
+
+11191
+
+Thie-That no 119-*
+ALLANE
+567
+
+
+11192
+Kity-Tume and 19100
+HaTS (Saran Linian
+11195
+SIRI* мони
+AD0 Man
+342°3
+• 303
+POLARS
+Tra londo
+084000628*
+11190
+Tow Thanies
+ALAM
+
+
+3060875570 270094529x7583
+2304 PN-18
+5367543/250
+4430B63561
+
+
+
+
+2704
+541+1
+ONA INe
+Olon Porke
+For. Dep. away
+568
+
+
+11199
+045-2027 elia Surina, tel
+Tea Than Oo Hondard forty-There
+11A00
+#011200/
+
+0110132750*
+10000457895/
+11201
+MALARS
+11202
+Traito Thirp-The auditi/100
+Mi-d
+:-
+
+что n«l.
+
+3111983782<
+
+30767858906335656751 1717733961
+
+
+569
+
+
+11204
+Wary Sire sal
+...
+4.93515 Pay the ner
+SE K
+
+232
+11205
+DEIR 3* Eyed Wine
+MASON
+I DONLARG
+5010866096 * -
+
+
+MALE ANS SU THIN
+0471B913
+570
+
+
+Pago I of 1
+www.colon/abenk.com
+STATEMENT PERIOD 3U15 Sune 30, 2006
+© Couries ines Thank you
+your business.
+for being our Customer.
+JEFFREY E EPSTEIN
+358 EL BRILLO MAY
+PALM BEACH FL 334B0
+Account Summary
+Previous Balance
+Total Credit(s)
+Total Debit(e)
+Service Charge
+Ending Balance
+Account Details
+Checks Paid
+* indicates chack missing in sequence
+11207
+11209 A
+11210
+11211
+11212
+11213
+11214
+6/16
+6/19
+6/16
+6/21
+6/19
+6/20
+6/19
+503.68
+720.25
+5,184.84
+426.18
+2,350.00
+7,852.24
+4,423.79
+5/31
+6/16
+6/19
+BALANCE
+91.847.34
+86,158.82
+78,664.78
+DATE.
+6/20
+6/21
+6/22
+$ 91,847.34 Average Collected Balance
++0.00
+- 46,908.97
+- 0.00
+$ 44,848.37
+$74,623.68
+11215
+11216
+11217
+
+11220
+11221
+6/23
+6/21
+620
+6/21
+6/22
+6/21
+2,290.28
+16,023.92
+250.25
+5,155.00
+232.69
+1,585.85
+BALANCE
+10,562.29
+47,371.34
+47,138.65
+COLONIAL BANK, N.A
+MEMBER FON
+571
+
+
+
+The image(s) below are for your informational purposes only and may not accurately reflect the
+This is not an original document or a substitute check
+18297
+
+
+WEETE-FOES PX-1E
+
+For Thou
+58618 Milan anned
+Faa Funded
+11209
+BELARS
+Hey Fell
+11210
+BALANA
+Nakes.
+11211
+• *L
+SOLARS
+Has fee
+
+PET I
+Passed est see bedse sates,
+MY TO THE DROER DI
+TANGE OPERATIONS
+
+
+E2330
+
+: 574094109
+10123
+PONT, IN
+#2122:
+3078995150*1.
+: 7340230920
+i which the
+572
+
+
+reads So mas Cap.
+PDLI2U2r 00634132200 0310432750
+See These Egalowed rap:Tor and 4100
+11212
+021500/
+11213
+For These For landed Tary-There wed 79188-1
+11214
+• DOLARS
+Tea Thered Toe unded Sury and 30r me
+11215
+.. DOLLAR
+11215
+• MAIN
+Share Than Jeesy-Then untru
+
+0242902e
+540
+
+HILL, MU
+
+306848847฿
+
+PITI
+10O WANTEAANCE DP.
+NOTTO THE ORDER Di
+CHIH FORBAN
+
+
+573
+
+
+
+11217
+WISHIN
+SHER TH
+700-40
+
+291 HE
+
+
+11219
+SHEIR J* Tea Alain Capuni
+The Thanaand Che Hidded 1-l, Fire wd W5110
+......• DOLLARS
+706621086A
+
+11220
+MALANS
+
+shine
+De Thead halt
+11221
+V1S00N
+- DOLLARS
+
+
+574
+
+
+
+Cutsian about our -02-2al
+www.colonisibank.com
+ACCOUNT NUMBERL
+STATEMENT PERIOD July 1, 2006 - July 31, 2006
+• Cour businass Thankates
+You bing us tomer
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FL 33480
+Account Summary
+Previous Balance
+Total Credits)
+Total Debit (8)
+Service Charge
+Ending Balance
+Account Details
+Deposits and Other Credits
+DESCRIPTION
+7/31
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+• Checks Paid
+* indicates check missing in sequance
+11208
+
+
+11225
+11226
+11227
+11228
+- 7/6
+7/31
+7/17
+7/25
+721
+7/24
+7124
+2,208.66
+633,35
+228.00
+588.48
+141.78
+360.15
+594.00
+$ 44,848.37
+Average Collecled Balance
++ 50,000.00
+- 29,731.40
+- 0.00
+$ 65,116.97
+$ 35,709.95
+50,000.00
+11229
+11230
+11231
+11232
+11233
+11234
+7/21
+7/24
+7/21
+724
+7/24
+7/21
+13,061.86
+5,328.36
+5,180.00
+OLOMAL BANK. N.
+EMBER FOI
+575
+
+
+
+Marial Cannerian: 877-502-22
+lonial Ce
+www.colonieibank.com
+6/30
+7/5
+7717
+BALANCE
+44,848.37
+42,639.71
+42,411.71
+STATEMENT PERIOD Juy 1,2000 - July 31, 2000
+7/24
+7/25
+23,382.71
+9.342.75 PATE
+18,338.80
+15,750.32
+COMBER BANK, NA.
+
+576
+
+
+
+
+
+The image(s) below are for your informatatus of the ses only and may not accurately reflect the
+NADES ENS ACE INDI
+11209
+TRe sardian demonits, bud
+07-27-73-10
+3064343820 2700116904
+11222
+
+11224
+Tard Faudied Tray Eye 1400109
+• GONLAMI
+132340 5940994589
+11225
+:
+нет 7*-17300032760
+577
+
+
+11228
+
+458-
+11227
+There Handed Sinty wal 1915p
+SHEER 3*
+1007
+
+11230
+Back i remation openin
+20
+
+
+
+578
+
+
+
+
+11232
+421604j410
+2ER6337
+11233
+Tus idol They wad 33n
+....
+
+6336158178 5714417624
+19 PS-
+
+579
+
+
+www.coloniathank.com
+STATEMENT PERIOD
+August 1, 2006 - August 31, 2006
+i Colonial Bank appreciat
+ur business. Thank y
+for being our Customer.
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FL 33480
+Account Summary
+Previous Balance
+Total Credits)
+Total Debits)
+Service Charge
+Ending Balance
+Account Details
+Deposits and Other Credits
+8/15
+DESCRIPTION
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+8/24
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paid
+A indicalas chock missing in sequence
+11223
+11235A
+11236
+11237
+11238
+11239
+11240
+8/4
+8/16
+8/23
+8/18
+8/16
+8/15
+8/15
+288.15
+180.74
+198.97
+1,947.00
+413.26
+1,578.95
+2,143.00
+$ 65,116.97 Averago Collected Balance
++ 283,195.31
+- 300,593.79
+- 0.00
+$ 57,718.49
+$72,195.22
+50,000.00
+243,195.31
+11241
+11242
+11243
+11244
+11245
+11246
+8/16
+821
+8/15
+8/18
+821
+8/21
+34,323.04
+1,300.48
+4,748.38
+1.246.56
+4,889.04
+3,890.00
+OLONIAL BANK, N.
+EMBER FORT
+580
+
+
+
+STATEMENT PERIOD August 1, 2006 - August 31, 2006
+000T3 E00
+www.coloniabank.com
+Other Debits
+DESCRIPTION
+8/16
+PRINTED CHECK CHARGE
+CLARKE AMERICAN CHK ORDER ZICF88270873500
+8/25
+OUTGOING WIRE DEBIT
+NES LLC 0110132758
+8/4
+8/15
+BALANC
+55,116.97
+64,828.82
+106,358.51
+8/16
+8/18
+B21
+80.93
+243,195.31
+BALANCE
+0,113.96
+68, 166.98
+57,917.46
+8/23
+8/24
+8/25
+BALANCE
+57,718.49
+300,913.80
+57.718.49
+820227580138"
+581
+
+
+
+6 COLONIAL BANK®
+The image(s) below are for your informatitus of the fes only and may not accurately reflect the
+--1
+11234
+5a528 go Caprint
+One Inded Fishy and 1u1t
+H300 01-4
+Her pal,
+35-641-42
+31IGES2432
+11238
+ASTRI HATE LI
+The leaded Katy-Eighted 12110
+45.350:2112
+Aslet
+
+05T31000
+31237
+D730028
+Lil
+5680
+582
+
+
+112:
+Tina li-
+Pall
+0033077 17 C0I0 CHAS
+11240
+Tong Tried De Hosed Fang There and
+al Rapher Forens, lu
+PO BE HER
+K063843220 C
+He kill
+
+11242
+Der Thereal Ther Hased ply and
+" DOLLARS
+
+
+
+1*30
+
+BE: 29 fit. 855
+6640767263 9500592401
+
+20150
+
+TENANCE OPERATIONS ACCI.
+AT TO THE LACER O
+ORTH FORM BASA
+583
+
+
+11244
+
+
+11245
+.. POLARS
+B40927
+
+
+
+11246
+
+
+
+
+2515 0
+
+*058
+Davilatoge
+584
+
+
+Page 1 o/ 2
+Colonial one on 07-50 2a699
+STATEMENT PERIOD
+supin 1, 2006 - September 30, 2006
+i Colonial Bank appreciates
+your business.
+Thank you
+for being our Customer.
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FL 33480
+Account Summary
+Previous Balance
+Total Credit(a)
+Total Debil(s)
+Service Charge
+Ending Balance
+$ 57,718.49 Average Collected Balance
++ 50,000.00
+- 69,675.04
+- 0.00
+$ 38,042.65
+he holidays are here! You can increase sales and decrease retums this holiday season. Call Colonial Bani
+derchant Services at (866) 643-2265 and ask about how to get starled with our gift and loyalty card progran
+$ 55,076,36
+Account Details
+Deposits and Other Credits
+9/8
+DESCRIPTION
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paid
+* indicates check missing in sequence
+11247
+11248
+11249
+11250
+11251
+11252
+11253
+946
+9/E
+9/5
+9/12
+9/12
+9/12
+Đ/12
+268.11
+601.85
+240.00
+1,609.70
+3,674.26
+393.72
+52,068.98
+50,000.00
+
+11256
+11257
+11258
+
+11261
+11262
+9/22
+9/14
+926
+9/28
+8/28
+8/27
+9/26
+3,250,00
+1.141.50
+400.61
+110.50
+10.52
+4,805.24
+MEMBER DICK, NA.
+585
+
+
+
+Jestions abouf your account, cal
+olonial Connection: 877-502-226
+8/31
+9/5
+9/B
+948
+BALANCE
+57,718.49
+57,478.41
+58,60B.45
+106,608.45
+STATEMENT PERIOD
+September 1, 200G - September 30, 2006
+9/12
+9/14
+W/22
+9/28
+BALANCE
+48,063.79
+9/27
+44,813.79
+9/28
+14,601.02
+38,564.28
+BALANCE
+38,563.76
+38,042.65
+COL
+OMAL
+BANK, NA.
+MEMBER
+FDIC
+
+32
+586
+
+
+
+The image(s) below are for your informatitus of theoses only and may not accurately reflect the
+BA5ER Ji* Lary E Marton
+11247
+- PALANE
+11248
+
+ад 2і
+
+47100
+spag yurg
+SERI MenTermad
+?!160
+
+s5o
+
+51628 g5 A00ksnimun, boe
+Toa ilundied Fany wd C100-e1i
+NOC Mentnarns, lm
+1124€
+. "2*#
+M.. DOLANE
+I50460
+P49 PX=16
+Wilheteil
+fordepasie poly
+fod painom.
+
+11250
+MICHA
+SALIR D la traden betog boe
+ha rias a Pas1M
+-41e ery vroa 2 119 23 17
+5685
+587
+
+
+
+190
+*72c-1500
+EL6C10529
+0403";
+:5290014910
+0:
+
+9528
+11256
+• Can No Tadada Partia
+588
+
+
+
+
+11260
+POLLA
+Debeen Benday OF Burs
+3 109512
+* 3710157485
+1126
+BAR 8 Coper Worke
+The pal jonat
+Chagale Windo
+BOLLA
+·4994
+5ti0419605
+
+589
+
+
+
+Contal shout you: 0-502-25
+STATEMENT PERIOD
+Detober 31, 2006
+• Colonial Bank appreciates
+your business. Thank you
+for being our Customer.
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FL 33480
+Account Summary
+Previous Balance
+Total Credit (s)
+Total Debit(s)
+Service Charge
+Ending Balance
+$ 38,042.65 Average Collected Balance
++ 50,000.00
+- 43,381.92
+- 0.00
+$ 44,660.73
+he holdays are here! You can increase sales and decrease retums this holiday season. Call Colonia/ Bank
+Merchant Services at (866) 643-2265 and ask about how lo get started with our gift and loyally card progran
+today.
+Account Details
+Deposits and Other Credits
+DESCRIPTION
+10/12
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paide indicates check missing in sequence
+10509
+11259 A
+
+11264
+11265
+10/10
+10/18
+10/17
+10/17
+10/18
+4,881.84
+฿40.29
+29,084.00
+2.162.84
+345.27
+11266
+11267
+11269 A
+11270
+GATE
+10/25
+10/26
+1024
+1025
+$ 49,781.68
+50,000.00
+'OLOMAL BANK, NJ
+MEMBER FON
+FANCIAL STRENGTH IN LOCAL HANDS
+N
+618.86
+3,975.00
+03.23
+780.79
+590
+
+
+
+Colonial about you out 2all
+www.colomisibenk.com
+9/30
+TO/1O
+10/12
+HALANCE
+38,042.65
+33,161.01
+83,161.01
+STATEMENT PERIOD
+October 1, 2006 - October 31, 2006
+10/17
+10/18
+10/24
+BALANCE
+51,314.17
+50,128.61
+50,035.38
+10/25
+10/26
+BALANC
+48,635.75
+14.,80.73
+GONNA FEE, NA.
+591
+
+
+
+The image(s) below are for your informatious of the see only and may not accurately reflect the
+10509
+
+Few These Eight Iuded Eight-One and 441130
+HA. Fraporte, Inc
+- VALAN
+1. 5740500658
+550
+11259
+timole
+
+
+50
+592
+
+
+
+He Ble
+11266
+TOMES RIT
+I Haved fight ise BAN
+наю.
+
+. 7540179662
+FAITH TATECT ONCIT OBSER
+112
+SIP Ta train operai
+There These New Fended Sendig five wal of
+
+
+
+30P8852836
+whor
+11270
+SOLANS
+2456-1
+
+367937966i
+
+
+14519
+
+693
+
+
+
+STATEMENT PERIOD November 1, 2006 - November 30, 2006
+your business.
+for being our Customer.
+JEFFREY E EPSTEIN
+58 E
+BRILLO MAY
+ALM BEACH FL 3348
+Account Summary
+Previous Balanco
+Total Credit(s
+Total Debil(s)
+Service Charge
+Ending Balance
+Account Details
+Deposits and Other Credits
+11/10
+DESCRIPTION
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+11/13
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paid * Indicates chock missing in sequence
+10510
+10511
+11268A
+
+11272
+11273
+11274
+11/10
+11/21
+112
+11/13
+11/10
+11/20
+11/16
+4,949.64
+47,000.00
+195.15
+950.08
+22,600.48
+213.80
+1.075.18
+$ 44,660.73 Average Collected Balance
++ 100,000.00
+- 142,935.92
+- 0.00
+$1,724.8T
+$ 54,818.61
+50,000.00
+50,000.00
+11275
+11278
+11277
+11278
+11279
+11280
+11/20
+11/29
+1128
+11/29
+1127
+292,74
+48,442.45
+619.19
+1,590.00
+16,765.03
+241.28
+COLONIAL
+COLORA BAK, NA.
+32
+594
+
+
+
+Cutie about you 0-0n2. 2all
+11/2
+11/10
+11/13
+BALANCE
+44,060.73
+44.485.58
+66,915.46
+115,965.38
+ACOOUNT NUMBER
+STATEMENT PERIOD Navember 1, 2006 - November 30, 2006
+11/16
+11/7
+11/20
+1121
+14,890,20
+NONE TAT
+114,597.46
+11/28
+11/29
+BALANC
+0,699.9
+19,109.93
+1.724.81
+OLONAL BANK. N.
+EMPER FO
+595
+
+
+
+& COLONIAL BANK
+The image(s) below are for your informatitus optre ses only and may not accuratly reflect the
+S0518
+430
+442 10-187 02-20
+MAN HE PAREN
+
+
+1O0L
+
+
+1126
+W1S30
+BED DE
+CM.29 00T 35
+[31.2
+LATIONAL AIR TRAFFIC SERVICES
+SUSH
+is -
+3066
+596
+
+
+11273
+Traited Titant of BOSe
+ALIEN SECOME YEESER
+11274
+One Thesed Soniy Fire and i
+11/162008
+wwww
+51940
+THAN N
+
+TIE SI
+
+
+P0210U
+ATONI, AR TRAFFIC SERICES
+
+
+
+
+11278
+
+
+
+
+_5740256707
+598
+
+
+
+Colonia about you are on: 2al
+STATEMENT PERIOD
+April 1, 2006 - April 30, 2006
+JEFFREY E EPSTEIN
+358 EL BRILLO MAY
+PALM BEACH FL 33480
+Account Summary
+Previous Balance
+Total Credits)
+Total Debit(s)
+Service Charge
+Ending Balance
+Account Details
+Deposits and Other Credits
+4/11
+4/18
+DESCRIPTION
+DEPOSIT
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paid 4 indicates check missing in sequeno
+10506
+
+11172
+11173
+11174
+11175
+11176
+11177
+11178
+11179
+• 11180
+4/25
+4/6
+4/6
+4/5
+4/6
+4/4
+4/14
+4/17
+4/17
+4/20
+4/17
+184.00
+421.20
+385.78
+198.00
+337.84
+2,089.00
+327.27
+9,500.02
+25.20
+300.00
+3,300.00
+$ 216,045.64 Average Collocted Balace
++ 130,000.00
+- 259,56B.42
+- 0.00
+$ 87,377.22
+$ 107,589.47
+80,000.00
+50,000.00
+4/14
+4/13
+4/14
+4/17
+4/20
+427
+4/21
+428
+4/28
+128
+НЕПЕРЕНЕ
+FINANCHL STRENGTH IN LOCAL HANDS
+599
+
+
+Page 2 of2
+Contine about you 2-502
+www.caloninbank.com
+STATEMENT PERIOD April 1,2006 - April 30, 2006
+Other Debits
+DESCRIPTION
+4/6
+OUTGOING WIRE DEBIT
+NES, LLC 0110132758
+331
+4/4
+4/8
+4/11
+BALANCE
+216,045.64
+214,856.64
+214,658.64
+27,314.82
+107,314.82
+185,199.00
+4/13
+4/14
+4/17
+4/18
+4/20
+BALANCE
+100,333.42
+4/24
+98,342.03
+4/25
+82,964.47 4/27
+132,964.47
+4/28
+132,138.99
+120354.CE
+126,770.15
+126,693.26
+837377.22
+MOMEN TOK, MA.
+020227580211"
+600
+
+
+
+The image(s) below are for your informational purposes only and may not accurately reflect the
+10506
+ВАБИ 3N ланки віба, н
+4"IHa
+DALAAT
+, 3074164680
+
+11171
+5AS2RS2
+Pral tras
+11172
+SAR OF
+The lied Galiy
+
+27%
+
+11173
+
+Come tonded Toty Fige ad Beer.
+• 3071990 історть нк-ле
+
+- 1213372363
+
+601
+
+
+BART Cople Washe
+These unded Thiry Armin w
+11174
+11175
+Try Thanand lighty-He 1.
+SAGAR ON TAN
+Have Thaniel Fire idol and or sp
+11177
+MALARS
+11178
+POLARS
+
+30637647i0
+
+
+1
+sisten
+
+115
+RS: 89 86. C5:
+
+
+
+
+M2491 PR-18
+: = :
+.3069195770
+-3.
+
+
+
+
+602
+
+
+11172
+- 000
+DOLLARs
+11180
+SER 3 Dale Tobatin
+• почита
+11181
+11183
+http://or19055ncrcss/inauirv/servlet/inquirv
+:=:
+
+
+
+
+ARM ME JUST
+
+3071173520 ******
+
+D1360
+SLE19037624
+
+a all bader The Bial
+603
+
+
+T PT 313
+AGR д* sai-d
+fied Hlanded Tily.-Targ aed 3en1
+Fies lhasded Frisy-Thee wd 1510
+SAGAR D*
+Capier s
+Ermeiy
+Mie Thremel Co llend-ed Eiger-Tome wd hon
+Tire Randod Thiny-Serss sad 15116
+11181
+•. DO,LAAS
+HURAX-Fila taina
+Plos
+DORLANS
+11187
+VINONN
+** SOLAAs
+11190
+
++i#1 89/14/84
+BELLsoutH [o» ecrªbA7°SłI7INs«эEª
+
+
+DRh ls pus n
+
+
+flic-icc m-,
+
+
+Tes
+183
+
+. ==
+485 i- vj"
+
+
+7 1
+301
+
+= = : |
+
+
+8 Tec-070I F6-09
+FORKE
+604
+
+
+
+0840000:
+S01e38310
+d701797401
+014191: 400634432220 0110132758»
+/00000538567
+301
+605
+
+
+
+Curiel Cant you: 7-502-2a05
+STATEMENT PERIOD May 1, 2006 - May 31, 2005
+• Colonial Bank appreciato
+your business, Thank you
+for being our Custorer.
+JEFFREY E EPSTEIN
+58 EL BRILLO MA
+ALM BEACH FL 3348
+Account Summary
+Previous Balance
+Total Credits)
+Total Debit(s)
+Service Charge
+Ending Balance
+Account Details
+Deposits and Other Credits
+5/11
+DESCRIPTION
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Pald * indicates chock missing in sequenco
+10507
+
+11189
+11191 A
+11192
+11195A
+11196
+11197
+1119B
+5/17
+5/10
+5/4
+5/1
+5/8
+5/8
+5/16
+5/12
+5/17
+82,000.00
+202.00
+38.11
+33.73
+93.33
+342.23
+260.10
+83.13
+1,467.14
+$ 87.377.22 Average Collected Balance
++ 100,000.00
+- 95,529.88
+- 0.00
+$ 91,847.34
+$ 10B,273.97
+11199
+11200
+11201
+11202
+11203
+11204
+11205
+11206
+5/15
+5/11
+5/12
+5/18
+5/18
+5/22
+5/24
+5/30
+2,143.00
+1,578.05
+1,467.63
+233.11
+5,184.84
+97.29
+163.81
+141.48
+OLONIAL BANK, N.
+EMBEA FOR
+FWANCIAL STRENGTH IN LOCAL HANDS
+32
+606
+
+
+
+Contine and your on 2a
+www.colanialbank.com
+4/30
+5/1
+5/4
+5/10
+BALANCE
+87,377.22
+87,343.49
+5/12
+87,305.39
+5/15
+B6,869.A2
+5/16
+B6.667.82
+5/17
+STATEMENT PERIOD
+May 1, 2000 - May 31, 2006
+BALAN
+85,088.8
+183,536.17
+181,395.11
+181,135.01
+97,067.87
+5/22
+5/24
+5/30
+92,152.63
+01,988.82
+91,847.34
+COLONIAL
+MEMBER.
+L BANK, NA.
+820227580170"
+• 37
+607
+
+
+
+The image(s) below are for your informational purposes only and may not accurately reflect the
+
+11188
+41104+
+°TAC-1050 PE-18 *
+- 000206209001421701
+58NNEE8» +2100
+
+
+09D8
+03576
+554ZI655-
+20-0-50
+and 4006
+MIR TRAFIC SERVICES
+1184
+*210*
+Clapshe Winter
+
+
+
+11191
+.. "
+608
+
+
+11192
+GAR 3H MATILind
+11195
+42100
+SIRST 200 sain, to
+342°3
+10000
+SIR LagEMe
+говносоав
+SULLAN
+11197
+11190
+VIKH
+to Thinne
+
+
+:* =
+F307543/250
+
+S2
+
+
+
+MY TO THE ORDER SU
+1492
+941 4 1
+•ONA INC
+Alan Pork
+Fuk Dep. any
+609
+
+
+54528 22"
+Tas Them
+11199
+1L000
+• DOLINI
+1128
+11201
+-.. DREAS
+11202
+Tre Handed They-They sad 11100
+Ballad
+BALAN
+
+
+
+##
+
+82050
+
+us da aside sag a9c1a/8s
+- 30767858906335656751 1717733961
+
+
+610
+
+
+
+11204
+VISTAs
+Weary Sera and 110
+it- 1293 02-18
+
+Beate Conte
+
+SERIE
+
+11206
+dulladollary-One 18100
+
+
+611
+
+
+
+STATEMENT PERIOD June 1, 2006 - June 30, 2006
+* Colonial Bank approciates
+your businoss.
+Thank you
+for being our Customer.
+JEFFREY E EPSTEIN
+358 EL BRILLO MAY
+PALM BEACH FL 33480
+Account Summary
+Previous Balance
+Total Credit(s)
+Total Debit(s)
+Service Charge
+Ending Balance
+$01.94734 Average Coloctod Balanco
+= 46,998.97
+- 0.00
+$ 44,848.37
+Account Details
+Checks Paid a indicates check missing in sequence
+• CHECK
+11207
+
+11210
+11211
+11212
+11213
+11214
+6/16
+6/19
+6/18
+6/21
+6/19
+6/20
+6/19
+503.68
+720.25
+5,184.84
+128.18
+2,350.00
+7,852.24
+4,423.79
+5/31
+6/16
+6/19
+BALANCE
+91,847.34
+86,15B.B2
+78,664.78
+6/20
+6/21
+6/22
+11215
+11216
+11217
+
+11220
+11221
+6/23
+6/21
+8/20
+6/21
+6/22
+6/21
+BALANCE
+10,562.23
+47,371.34
+47,138.65
+LATE
+$74,623.68
+AMOUN
+2,290.21
+16,023.92
+250.25
+5,155.00
+1,585.86
+BALANC
+14,848.37
+OLONIAL BANK, N.
+EMBER FOI
+32
+612
+
+
+
+The image(s) below are for your informational purposes only and may not accurately reflect the
+11207
+1"*I
+10T-1I0
+
+400647-8085
+07715311.
+11209
+
+PPET 1
+LeT 2042 Pe-10
+
+121€0512
+FOR DEPOST ONLY
+11210
+
+
+POLLANS
+
+AMENARA
+11211
+SAUR DI
+3078895150/
+
+.. +
+Which tha
+613
+
+
+11212
+Shirall Arlin
+Tae Thered There Handed Fly wed oo
+11213
+SOLANS
+SER 7 Team debation Comperle
+11214
+..• DORLARS
+AБ1R3"
+11215
+... ORLARS
+11216
+DoLAns
+
+138---H
+
+
+
+
+....
+
+FAT:
+-360
+096
+
+
+:
+*:
+614
+
+
+
+11217
+Two tando Fly wed 35080
+
+
+
+11219
+The Thesed The Manded Tily For ad bone"
+• Susa
+.... DALARS
+
+
+11220
+Tore Handed They-T
+:.:
+
+
+11221
+BALER TH
+Use 15
+
+
+Thank you for banking at Colonlal Bank.
+615
+
+
+ACCOUNT NUMBER I
+STATEMENT PERIOD July 1, 2006 - July 31, 2006
+Colonlal Bank appreciate
+your business.
+hank yo
+for being our Customer.
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FL 33480
+Account Summary
+Previous Balance
+Total Crodits
+Total Debit(a)
+Service Chargo
+Ending Balance
+Account Details
+Deposils and Other Credits
+7/31
+DESCRIPTION
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paid
+4 indicates check missing in sequence
+11208
+11222A
+11224A
+11225
+11228
+11227
+11228
+7/5
+7/31
+7/17
+7125
+7/21
+7/24
+724
+2,208.66
+833.35
+228.00
+588.48
+141.78
+360,13
+594.00
+S44,848.37
+Average Collected Balance
++ 50,000.00
+- 20,731.40
+- 0.00
+$ 65,116.97
+$ 35,703.95
+AMOUN
+50,000.00
+11229
+11230
+11231
+11232
+11233
+11234
+7121
+7724
+7121
+724
+7124
+7121
+670.45
+5,328.36
+5,189.00
+230.35
+197.00
+OLONIAL BANK, NJ
+EMBER FDM
+616
+
+
+
+Colstil Canetion: 77-502-2285
+www.colonleibenk.com
+6/30
+7/5
+7/17
+BALANCE
+44,848.37
+42,639.71
+42,411.71
+STATEMENT PERIOD July 1,200G -July 31, 2006
+
+7121
+7/24
+7/25
+BALANCE
+23,382.71
+16,338.80
+15,760.32
+7731
+BALANCE
+85,116.97
+4800227580131+
+617
+
+
+
+The image(s) below are for your informational purposes only and may not accurately reflect the
+11208
+- =
+• "Інм
+... SOLINE
+The Theasal The Handed Fight and serie
+In arian daland, lot.
+122250%
+3964343826 2709116904
+11222
+4:-42
+
+
+11224
+
+
+
+11225
+BeIR Her Canada
+For tacked Fighty-fight 10100
+H....
+...
+•.:
+
+36620
+httn://or19055ncrcss/inauirv/servlet/inauirv
+618
+
+
+11226
+SERE
+11227
+..... BORLARS
+11228
+wail ban laks, les
+Time tahind
+11230
+INALLARS
+
+1 are
+
+TH FORM FARE
+Faces Pe
+
+
+"=
+
+
+619
+
+
+
+11232
+Fine Thramd
+42100g410
+11233
+Tos llanded They de
+
+6336158178 5714417624
+13234
+
+
+te non
+620
+
+
+Pago 1 of 2
+MOCOUNT NUMBER
+STATEMENT PERIOD August 1, 2006 - August 31, 2006
+* Colonial Bank appreciates
+your business.
+Thank you
+for being our Customer.
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FL 33480
+Account Summary
+Previous Balance
+Total Credit(s)
+Total Debil(a)
+Servico Charge
+Ending Balance
+Account Details
+Deposits and Other Credits
+8/15
+8/24
+DESCRIPTION
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paid
+* indianies chack missing in sequenco
+11223
+11235 л
+11236
+11237
+11238
+11239
+11240
+B/4
+8/16
+B/23
+8/18
+8/16
+8/15
+8/15
+288.15
+180,74
+198.97
+1,947.00
+413.26
+1,578.95
+2,143.00
+$ 65,116.97 Average Collected Balance
++ 293,195.31
+-300,593.79
+- 0.00
+$ 57,718.49
+$72,195.22
+AMOUN
+50,000.00
+243,195.31
+11241
+11242
+11243
+11244
+11245
+11246
+8/16
+8/21
+B/15
+B/18
+8/21
+B/21
+AMOUN
+34,323.04
+1,380.18
+4,748.36
+1,246.56
+4,089.04
+3,880.00
+COLONIAL BANK, NA.
+MEMBER FINC
+621
+
+
+Page 2 ol 2
+Juestions about your account, cal
+Colonel Connection: 877-502-2265
+www.colonisibank.com
+Other Debits
+8/16
+8/25
+DESCRIPTION
+PRINTED CHECK CHARGE
+CLARKE AMERICAN CHK ORDER ZICF88270673500
+OUTGOING WIRE DEBIT
+NES LLC 0110132758
+STATEMENT PERIOD
+August 1, 200G - August 31, 2006
+00013 E00
+AMCUNT
+80.93
+243,195.31
+7/31
+8/4
+8/15
+BALANCE
+65,116.97
+64,828.82
+106,358.51
+8/16
+8/18
+8/21
+BALANCE
+70,113,98
+68,166.98
+57,917.46
+8/23
+8/24
+8/25
+BALANCE
+57.718.49
+300,913.80
+57,718.40
+MONA FEAR, MA.
+
+622
+
+
+
+The image(s) below are for your informational purposes only and may not accurately reflect the
+11723
+DEJERSES
+T475450
+11235
+5452RJ Capie Winder
+• CHIANS
+9468
+31 10252452
+11235
+•: "
+Der land Klary-Eph 1017
+HATS (ferine) Linin
+3075554796 1438539269
+Pay io to pedar clany Band
+b2358
+L AIR TRAPFIC SERVICES
+Ailab
+15|416
+*084500021
+11233
+LTW
+Li!
+623
+
+
+11230
+SALER BI*
+Pose Bondol Dotees and 36100*
+11240
+THaT
+11242
+BASERS crime, he
+ито.
+
+FICENS
+
+•PRTE Pİ-18
+FREE SEN
+
+17221 16 н
+
+BE: 19 SSE
+6640767263 0500592401
+
+1018343)
+
+:.::
+624
+
+
+11243
+11244
+On Theme Tar
+PLANS
+
+
+11245
+Fine Thras
+... PALAS
+
+5770
+
+11246
+:*:
+The The Eye Hand they
+... DOLAN
+
+55780
+
+ES. 15 C
+
+*J58
+NOT CAL
+625
+
+
+
+yestions about your account, cal
+alonial Connection: 877-502-226
+STATEMENT PERIOD September 1, 2006 - September 30, 2006
+Colonial Bank appreciates
+your business.
+Thank you
+or being our Customer.
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FL 33480
+Account Summary
+Previous Balance
+Total Credi(s)
+Total Debit(s)
+Service Charge
+Ending Balance
+$ 57.718.49 Average Collected Balance
++ 50,000.00
+- 89,875.84
+- 0.00
+$ 38,042.65
+$ 55,076.36
+Account Details
+Deposits and Other Credits
+9/B
+DESCRIPTION
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paid
+* indicates check missing in sequence
+11247
+11248
+11249
+11250
+11251
+1262
+9/G
+9/6
+9/5
+9/12
+9/12
+5/12
+9/12
+208.11
+601.85
+240.08
+1,809.70
+3,674.26
+393.72
+52,866.08
+50,000.00
+11255A
+11256
+11257
+1125B
+11260 A
+11261
+11262
+9/22
+5/14
+9/26
+9/28
+5/28
+9/27
+9/20
+110.50
+4,995.24
+COLORA BAK, NA.
+FINANCIAL STRENGTHIN LOCAL HANDS
+626
+
+
+Pago 2 of 2
+Questions abouf your account, calf
+Colonial Connection: 877-502-2265
+www.cofonlabank.com
+8/31
+9/5
+9/6
+9/8
+BALANCE
+57,718.49
+57,478.41
+56,80B.45
+106,608.45
+ACCOUNT NUMBER |
+STATEMENT PERIOD
+September 1, 2006 - September 30, 2006
+9/12
+9/14
+9/22
+9/26
+48,063.79
+44,813.75
+44,601.02
+38,564.28
+9/28
+BALANCI
+18,553.7
+38,042.65
+COLOMAI
+MEMBER
+FONG, NA
+627
+
+
+
+& COLONIAL BANK®
+The image(s) below are for your informational purposes only and may not accurately reflect the
+GAR Lary. Minnien
+11247
+
+-. роті
+
+11240
+1i./
+99140
+
+
+•Welled l
+
+11240
+Twa landed Taly allie
+*• DORLAS
+
+11250
+mc door re 2 059 23.17
+Do Thandar
+9484590 2700166685
+httn:/lnrI0055ncmcc/in/mirv/cprvlet/innmirv
+628
+3/2/2007
+
+
+• -0
+11256
+Thron Tananal Ta landerd Filly wid 00180
+DELIRI
+httt://nrlO055nrmcc/innuirv/sprulet/innuirv
+
+TCH 1880 1
+BEEL60: 05290
+3075382640-
+8512224100-12:50
+629
+2/707007
+
+
+
+мирім
+SAGAR ONE
+11261
+The wed 83/100/1021021
+
+
+* 3718157485
+
+630 ฿
+
+
+
+vestions about your account, ca
+Moniel Connection: 877-502-226
+STATEMENT PERIOD
+October 1, 2006 - October 31,2006
+Colonial Bank appreciates
+your business. Thank you
+for being our Customer.
+JEFFREY E EPSTEIN
+358 EL BRILLO MAY
+PALM BEACH FL 33480
+Account Summary
+Previous Balance
+Total Credin(s)
+Total Debit(a)
+Service Charge
+Ending Balance
+5 38.042.65
+Average Collected Balance
+$ 49,781,68
++ 50,000.00
+- 43,381.92
+- 0.00
+$ 44,660.73
+Marian a nirs at e 41-20 and lak about co get sta i holiday in an all Coloniar Bank
+Account Details
+Deposits and Other Credits
+10/12
+DESCRIPTION
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paid
+e indicates chock missing in sequence
+10509
+11259 A
+
+11264
+11265
+10/10
+10/18
+10/17
+10/17
+10/18
+4,B81.64
+840.29
+28,684.00
+2,162.84
+345,27
+50,000.00
+11266
+11267
+11269 A
+11270
+10/25
+10/26
+10/24
+10/25
+618.86
+3,975.00
+83.23
+
+
+32
+631
+
+
+
+STATEMENT PERIOO October 1, 2006 - October 31, 2006
+9/30
+10/10
+10/12
+BALANCE
+38,042.65
+33,161.01
+83,161.01
+10/17
+10/18
+10/24
+BALANCE DAT
+51,314.17
+10/25
+50,128.61
+10/28
+50,035.38
+BALANCE
+48,635.73
+44,660.73
+0202273000p4
+632
+
+
+
+5 COLONIAL BANK®
+The image(s) below are for your informational purposes only and may not accurately reflect the
+10509
+
+
+Tire Thus Right Suaded The eddy
+ег:» 5740500658
+350
+132042M1
+1125
+501593,
+1 Fora cane
+ACK Manian, her
+3864060т60 .. ...
+
+http://or19055ncrcss/inauirv/servlet/inauirv
+633
+
+
+
+11266
+CArTO THE
+5 in Egis
+
+
+11267L
+There These He rael Sure Fire a potte
+
+11270
+лік віл
+Free Handed Eighty wa 7h00
+
+
+
+
+14519
+
+634
+
+
+
+Coloria shoe on: 87-502-205
+STATEMENT PEROD November 1, 2006 - November 30, 2006
+Colonial Bank appreciatos
+your busmess. Thank you
+for being our Customer.
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FL 33480
+Account Summary
+Previous Balance
+Total Credit(s)
+Total Debit(s)
+Service Charge
+Ending Balance
+Account Details
+Deposits and Other Credits
+11/10
+DESCRIPTION
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+11/13
+INCOMING WIRE CREDIT
+JEFFREY E EPSTEIN
+Checks Paid
+¿ indicatos check missing in sequanca
+10510
+10511
+11268 4
+
+11272
+11273
+11274
+11/10
+11/21
+11/2
+11/13
+11/10
+11/20
+11/16
+4,949.64
+47,000,00
+195.15
+950.08
+22,600.48
+213.80
+1,075.18
+$ 44,660.73 Avorage Collecled Balance
++ 100,000.00
+- 142,935.92
+- 0.00
+$ 1,724.81
+$ 54,818.61
+AMOUN
+50,000.00
+50,000.00
+11275
+11276
+11277
+11278
+11279
+11280
+11/20
+11/29
+11/28
+11/29
+11/27
+MOUN
+292.74
+46,442.45
+619.19
+1,590.00
+18,765.93
+241.28
+COLONIAL BANK, NA
+MEMBER FDIC
+#122/590138
+635
+
+
+Page 2 o/ 2
+Questions about your account, call
+Colonial Connection: 877-502-2255
+10/31
+11/2
+11/10
+11/13
+BALANCE
+44,660.73
+44,465.58
+66,915.46
+115,965.38
+STATEMENT PERIOD
+I Espod
+November 1, 2006 - November 30, 2006
+11/16
+11/17
+11/20
+11/21
+BALANCE
+114,890.20
+114,597.46
+67.941.21
+20,941.21
+11/27
+11/28
+11/20
+19,100.93
+1,724.81
+COLONIAL
+BANK, N.A.
+MEMBER FDIC
+10202273/001.30
+37
+636
+
+
+
+The image(s) below are for your informational purposes only and may not accurately reflect the
+шаз
+
+Aten
+160
+11260
+One landed Many. Fore
+DOLLAN
+RATIONAL AR TRAFIC SERVICES
+whow
+44O6
+637
+
+
+11273
+Haa (is haus)7h
+Inoso
+• *313*
+LENO.
+SASER 23 Mn toate
+The Thespand Sa-may Fa
+,*IATLI
+=. ARLAM
+KODSLSI latoocorsa
+traume
+httn://or19055neress/incmirv/servlet/incuirv
+HAM !
+
+
+DUICA:
++02100
+
+8008
+"Kel /n/=
+/nana
+
+
+
+1044
+
+The There FisHeded Misty and 00100
+7673029(
+10
+
+639
+
+
+
+Contine shout you 7-02-215
+www.cofoninlnnk.com
+ACCOUNT NUMBER I
+STATEMENT PERIOD December 1,2006 - Decomber 31, 2006
+Cour but is Thanks
+your business.
+for boing our customer.
+JEFFREY E EPSTEIN
+358, EL BRILLO WAY
+PALM BEACH FL 33450
+Account Summary
+Previous Balance
+Tolal Credits)
+Tolal Debil(s)
+Service Charge
+Ending Balance
+$ 1,724.81
+Average Collected Balance
++ 0.00
+- 0.00
+- 0.00
+$ 1,724.81
+$ 1,724.81
+OLOMAL BANK, NA
+TEMBER FOIC
+
+640
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/c0ba8209d379cfc20a05c383f540ff7ec80064e381e270e2c9cb847220901932.receipt.json b/vision-fixhub/ds9-unparsed-05/c0ba8209d379cfc20a05c383f540ff7ec80064e381e270e2c9cb847220901932.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..27b21624c26e0a842c400ecde67b6f47501f7a09
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c0ba8209d379cfc20a05c383f540ff7ec80064e381e270e2c9cb847220901932.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -23388,
+  "dataset": "marble-joined",
+  "doc_id": "c0ba8209d379cfc20a05c383f540ff7ec80064e381e270e2c9cb847220901932",
+  "engine": "marble-apple-vision",
+  "event_count": 912,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "15c97071f628293859623de65378650f2ff275f3c9ede0588ec3d3b7f5d575cd",
+  "output_sha256": "e161d171599a1e7206da0c2eab2839f7617b73671cd6f18439ec4b1c7f37813c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c159cefbb235ac1244c270e36bd4b0085a529be462971d6726733da05b4b1d64.md b/vision-fixhub/ds9-unparsed-05/c159cefbb235ac1244c270e36bd4b0085a529be462971d6726733da05b4b1d64.md
new file mode 100644
index 0000000000000000000000000000000000000000..dc2d87539e224157dd66265e7b053114179f4447
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c159cefbb235ac1244c270e36bd4b0085a529be462971d6726733da05b4b1d64.md
@@ -0,0 +1,268 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+December 11, 2008
+VIA HAND DELIVERY
+Captain
+Palm Beach Sheriff's Office
+Corrections Division
+Re: Work Release Application of Jeffrey Epstein
+Dear Captain
+and was approved for participation in the Palm Beach Sheriff's Office's ("PBSO") work
+release program. Through a request for public records, I have received a copy of Mr
+Epstein's work release file. After doing some internet research of public records and
+making a few telephone calls, I discovered some inaccuracies and omissions in Mr.
+Epstein's file that i wanted to bring to your attention. During a recent meeting, Roy
+Eligibility for Participation
+I understand that Mr. Epstein would be ineligible for participation in the work
+release program if he committed three violations of F.S.S. 796 within the past five years.
+Mr. Epstein has been charged with and convicted of a felony violation of F.S.S. 796.07.
+In order to be convicted of a felony violation of that statute, one must commit "a third or
+subsequent violation." In other words, Mr. Epstein has committed at least three
+violations of Section 796.07, and in his "Alternative Custody Program Placement
+Synopsis," Mr. Epstein's charges are described as "Recommit: Prostitution."
+In addition to those three violations, Mr. Epstein also has been convicted of
+violating F.S.S. 796.03, procuring a person under the age of 18 for prostitution.
+Throughout his paperwork, this violation is referred to simply as "prostitution." The
+
+
+
+PAGE 3
+through 2/28/07).' These sworn filings show that Mr. Epstein worked for the Foundation
+for only one hour per week and earned no compensation. (See page 6 of each return.)
+All of these returns were signed under penalty of perjury by either Mr. Epstein or Darren
+Indyke, who is listed in Mr. Epstein's work release file as Mr. Epstein's "supervisor."
+Mr. Epstein's representations concerning his prior work duties and salary may violate the
+salary and employment verification requirements of C.O.P. #926.01(|(C)(7) and (8).
+In response to your requirement of "a detailed work schedule," Mr. Indyke has
+provided the following two sentences:
+[Mr. Epstein's] duties will require him to work six days a week, Monday
+through Saturday, at the Foundation's office located at
+from the hours of 8:00 A.M.
+to 8:00 P.M.
+As President of the Foundation, Mr. Epstein will be responsible for the
+general oversight and management of the Foundation, and particularly, to
+seek out, evaluate and determine worthy charitable causes to which the
+Foundation may make contributions.
+Mr. Indyke did not disclose that Mr. Epstein only worked one hour per week prior to his
+incarceration and has provided no explanation of why Mr. Epstein could perform these
+duties in one hour per week before he was incarcerated but now needs to spend 72 hours
+each week to do the same job. Again, this appears to be inconsistent with C.O.P.
+'The returns are available online at the following public websites:
+FY2006:
+http://www.guidestar.org/FinDocuments/2007/133/996/2007-133996471-0391c8db-F.pdf
+FY2005: (
+http://www.guidestar.org/FinDocuments/2006/133/996/2006-133996471-02c9625e-F.pdf
+FY2004:
+http://www.guidestar.org/FinDocuments/2005/133/996/2005-133996471-02056acf-F.pdf
+FY2003: http://www.guidestar.org/FinDocuments/2004/133/996/2004-133996471-1-F.pdf
+FY 2002: http://www.guidestar.org/FinDocuments/2003/133/996/2003-133996471-1-F.pdf
+FY2001: http://www.guidestar.org/FinDocuments/2002/133/996/2002-133996471-1-F.pdf
+FY2000: http://www.guidestar.org/FinDocuments/2001/133/996/2001-133996471-1-F.pdf
+FY1999: http://www.guidestar.org/FinDocuments/2000/133/996/2000-133996471-1-F.pdf
+FY1998: http://www.guidestar.org/FinDocuments/1999/133/996/1999-133996471-1-F.pdf
+
+
+PAGE 5
+is completely within the discretion of the Sheriff's Office. The purpose of this letter is
+simply to provide you with information concerning Mr. Epstein's offenses and his work
+situation. Judge Pucillo, who conducted the change of plea and sentencing, heard the
+factual proffer and imposed Mr. Epstein's sentence. She has not been consulted
+regarding Mr. Epstein's application for work release. I understand that Judge MoSorley's
+standing order states that she "takes no position with respect to the eligibility of any
+inmate sentenced in this Division unless specifically stated at time of sentencing."
+Because of her absence, Judge MoSorley did not conduct the sentencing and, therefore,
+did not have the opportunity to weigh any objections to work release at that hearing. It is
+unclear whether Judge Pucillo was aware of Judge McSorley's standing order when she
+imposed sentence. In utilizing your discretion, you may or may not choose to consult
+with the appropriate judge on this matter.
+Request for Notification
+As I had previously asked of Colonel
+I would appreciate if you would
+keep me informed of any changes to Mr. Epstein's release status so that I may fulfill my
+obligations to keep the victims identified through the federal investigation informed of
+Mr. Epstein's status. I have informed all of the known victims of Mr. Epstein of the
+change in his incarceration status and that you are the contact person if they have any
+questions. Some may ask that their locations be amongst the "Exclusionary Zones"
+programmed into Mr. Epstein's GPS unit. If you need their addresses, please let me
+know.
+Please feel free to contact me with any questions or concerns.
+Sincerely,
+United States Attorney
+By:
+Assistant United States Attorney
+CC:
+Colonel
+4, Northern Division I
+
+
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+(561) 820-8711
+Facsimile: (561) 820-8777
+December 11, 2008
+VIA HAND DELIVERY
+Captain
+Palm Beach Sheriff's Office
+Corrections Division
+Re: Work Release Application of Jeffrey Epstein
+Dear Captain |
+The U.S. Attorney's Office recently learned that Inmate Jeffrey Epstein applied for
+making a few telephone calls, I discovered some inaccuracies and omissions in Mr.
+Epstein's file that i wanted to bring to your attention. During a recent meeting, Roy
+Black, one of Mr. Epstein's attorneys, invited us to share our concerns with PBSO.
+Eligibility for Participation
+I understand that Mr. Epstein would be ineligible for participation in the work
+release program if he committed three violations of F.S.S. 796 within the past five years.
+Mr. Epstein has been charged with and convicted of a felony violation of F.S.S. 796.07.
+In order to be convicted of a felony violation of that statute, one must commit "a third or
+subsequent violation." In other words, Mr. Epstein has committed at least three
+violations of Section 796.07, and in his "Alternative Custody Program Placement
+Synopsis," Mr. Epstein's charges are described as "Recommit: Prostitution."
+In addition to those three violations, Mr. Epstein also has been convicted of
+violating F.S.S. 796.03, procuring a person under the age of 18 for prostitution.
+Throughout his paperwork, this violation is referred to simply as "prostitution." The
+
+
+
+PAGE 2
+charge is not a solicitation of prostitution charge, it is a procurement of a minor to engage
+in prostitution. Florida courts have defined the offense as "inducing a victim to engage
+in sexual activity" for money and "persuading, inducing, or prevailing upon a person to do
+something sexual" for financial gain. In other words, the statute addresses the recruiting
+of minors who have not previously been involved in prostitution to engage in sexual
+activity for commercial gain to a recruiter or "pimp"/"madame." The Florida Legislature
+has acknowledged the significant difference between solicitation under F.S.S. 796.07 and
+procurement of minors under F.S.S. 796.03 by requiring persons convicted of violating
+F.S.S. 796.03 to register as sex offenders. The distinction may be meaningful to the
+victims of Mr. Epstein's offenses, who could feel that they are being stigmatized as
+"prostitutes."
+Inaccuracies and Omission in Work Release Application and Related Documents
+Throughout the records related to Mr. Epstein's work release placement, he is
+alternatively referred to as working for "The Florida Science Foundation" or
+"self-employed," and Mr. Epstein lists his salary as $250,000. Mr. Epstein describes
+himself as "returning to work" and "eligible for re-employment" at The Florida Science
+Foundation. Please be advised that the only W-2 that Mr. Epstein provided is from
+Financial Trust Company, Inc., which shows that Mr. Epstein was employed in the U.S.
+Virgin Islands at a salary of $180,785.62, not $250,000.
+Mr. Epstein provided to you no documentation regarding his pre-incarceration
+employment with "The Florida Science Foundation" or its corporate alter-ego, "The
+C.O.U.Q. Foundation, Inc." As you will see, the Foundation, its offices, and Mr.
+Epstein's purported job schedule were all created on the eve of Mr. Epstein's
+incarceration in order to provide him with a basis for seeking work release.
+The Florida Science Foundation was not registered with the State of Florida and
+had no office space or telephone number until after Mr. Epstein was already incarcerated.
+The application filed with the State of Florida and signed under penalty of perjury by
+Richard Kahn lists Mr. Kahn's and the Foundation's telephone number as
+"561-659-8300." That is the telephone number of Atterbury, Goldberger and Weiss-one
+of the law firms representing Mr. Epstein. Richard Kahn is a partner at the law firm of
+Sullivan and Cromwell in New York and has no association with the Atterbury firm.
+Checking public records available on the internet, I located the IRS returns of "The
+C.O.U.Q. Foundation, Inc." for fiscal years 1999 through 2006 (which covers the period
+
+
+PAGE 3
+through 2/28/07).' These sworn filings show that Mr. Epstein worked for the Foundation
+for only one hour per week and earned no compensation. (See page 6 of each return.)
+All of these returns were signed under penalty of perjury by either Mr. Epstein or Darren
+Indyke, who is listed in Mr. Epstein's work release file as Mr. Epstein's "supervisor."
+Mr. Epstein's representations concerning his prior work duties and salary may violate the
+salary and employment verification requirements of C.O.P. #926.01(D(C)(7) and (8).
+In response to your requirement of "a detailed work schedule," Mr. Indyke has
+provided the following two sentences:
+[Mr. Epstein's] duties will require him to work six days a week, Monday
+through Saturday, at the Foundation's office located at
+from the hours of 8:00 A.M.
+to 8:00 P.M.
+As President of the Foundation, Mr. Epstein will be responsible for the
+general oversight and management of the Foundation, and particularly, to
+seek out, evaluate and determine worthy charitable causes to which the
+Foundation may make contributions.
+Mr. Indyke did not disclose that Mr. Epstein only worked one hour per week prior to his
+incarceration and has provided no explanation of why Mr. Epstein could perform these
+duties in one hour per week before he was incarcerated but now needs to spend 72 hours
+each week to do the same job. Again, this appears to be inconsistent with C.O.P.
+'The returns are available online at the following public websites:
+FY2006:
+http://www.guidestar.org/FinDocuments/2007/133/996/2007-133996471-0391c8db-F.pdf
+FY2005:
+http://www.guidestar.org/FinDocuments/2006/133/996/2006-133996471-02c9625e-F.pdf
+FY2004:
+http://www.guidestar.org/FinDocuments/2005/133/996/2005-133996471-02056acf-F.pdf
+FY2003: http://www.guidestar.org/FinDocuments/2004/133/996/2004-133996471-1-F.pdf
+FY 2002: http://www.guidestar.org/FinDocuments/2003/133/996/2003-133996471-1-F.pdf
+FY2001: http://www.guidestar.org/FinDocuments/2002/133/996/2002-133996471-1-F.pdf
+FY2000: http://www.guidestar.org/FinDocuments/2001/133/996/2001-133996471-1-F.pdf
+FY1999: http://www.guidestar.org/FinDocuments/2000/133/996/2000-133996471-1-F.pdf
+FY1998: http://www.guidestar.org/FinDocuments/1999/133/996/1999-133996471-1-F.pdf
+
+
+PAGE 4
+#926.01(V)(C)(7).
+Mr. Indyke has signed the "Alternative Custody Unit Program Agreement" as Mr.
+Ipstein's "employer." In that Agreement, Mr. Indyke promises to "notify the Alternativ
+ustody Unit immediately if the Participant: (1) Fails to appear for work at the scheduler
+time; and (2) Leaves the place of employment prior to the scheduled time." Both in this
+form and inform the sher its ince opt significant fins frist, ir. indyke lives
+and works in the New York metropolitan area. He likely will not be present at Mr.
+Epstein's workplace, so he may not know if Mr. Epstein "fails to appear for work" or
+"leaves the place of employment." In that event, Mr. Indyke also will not be able to
+supervise Mr. Epstein's actual work to determine whether he is truly doing the work of
+The Florida Science Foundation.? Second, Mr. Indyke does not "employ" Mr. Epstein.
+Instead, Mr. Epstein "employs" Mr. Indyke. Mr. Epstein is the President and founder of
+The Florida Science Foundation and Mr. Indyke is its Vice President. More importantly,
+Mr. Epstein is also the founder and President of the Financial Trust Company, his
+for-profit corporation. Mr. Indyke is Mr. Epstein's subordinate at that entity as well.
+One of Mr. Epstein's attorneys has suggested that Mr. Epstein is using his time on
+work release to manage investments resulting in investment income of millions of dollars.
+If that is true, then Mr. Epstein is acting outside of the scope of his employment with
+The Florida Science Foundation. Instead, that would be in keeping with Mr. Epstein's
+work for his for-profit corporation, which would inure to the benefit of Mr. Indyke.
+Because that work would result in a financial benefit to him, and because he is Mr.
+Epstein's subordinate at that corporation, Mr. Indyke may be reluctant to inform the
+Sheriff's Office of this violation of the terms of Mr. Epstein's Work Release contract.
+The "references" listed by Mr. Epstein all appear to have the same conflict of
+interest. Mr. Epstein did not list any past or present co-workers, supervisors, or clients.
+Instead, he has listed four attorneys who are currently retained-and paid-by Mr. Epstein.
+Their attorney-client privilege obligations might further restrain them from notifying the
+Sheriff's Office if Mr. Epstein was not abiding by the work release rules.
+As I previously mentioned to Colonel
+the decision regarding work release
+2On the application for registration of the Florida Science Foundation with Florida's
+Department of State, Mr. Indyke lists his true address in Livingston, New Jersey.
+
+
+PAGE 5
+is completely within the discretion of the Sheriff's Office. The purpose of this letter is
+simply to provide you with information concerning Mr. Epstein's offenses and his work
+situation. Judge Pucillo, who conducted the change of plea and sentencing, heard the
+factual proffer and imposed Mr. Epstein's sentence. She has not been consulted
+regarding Mr. Epstein's application for work release. I understand that Judge MeSorley's
+standing order states that she "takes no position with respect to the eligibility of any
+inmate sentenced in this Division unless specifically stated at time of sentencing."
+Because of her absence, Judge McSorley did not conduct the sentencing and, therefore,
+did not have the opportunity to weigh any objections to work release at that hearing. It is
+unclear whether Judge Pucillo was aware of Judge MeSorley's standing order when she
+imposed sentence. In utilizing your discretion, you may or may not choose to consult
+with the appropriate judge on this matter.
+Request for Notification
+As I had previously asked of Colonel
+, I would appreciate if you would
+keep me informed of any changes to Mr. Epstein's release status so that I may fulfill my
+obligations to keep the victims identified through the federal investigation informed of
+Mr. Epstein's status. I have informed all of the known victims of Mr. Epstein of the
+change in his incarceration status and that you are the contact person if they have any
+questions. Some may ask that their locations be amongst the "Exclusionary Zones"
+programmed into Mr. Epstein's GPS unit. If you need their addresses, please let me
+know.
+Please feel free to contact me with any questions or concerns.
+Sincerely,
+United States Attorney
+By:
+A. Marie Villafaña
+Assistant United States Attorney
+cc:
+Colonel Michael/
+, Northern Division I
+
diff --git a/vision-fixhub/ds9-unparsed-05/c159cefbb235ac1244c270e36bd4b0085a529be462971d6726733da05b4b1d64.receipt.json b/vision-fixhub/ds9-unparsed-05/c159cefbb235ac1244c270e36bd4b0085a529be462971d6726733da05b4b1d64.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..deb2a55c508e4427e6383519559bfb4113f9eafb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c159cefbb235ac1244c270e36bd4b0085a529be462971d6726733da05b4b1d64.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -285,
+  "dataset": "marble-joined",
+  "doc_id": "c159cefbb235ac1244c270e36bd4b0085a529be462971d6726733da05b4b1d64",
+  "engine": "marble-apple-vision",
+  "event_count": 12,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "4496f423c653abb27a4ba903a3fb56264516d0e3b9453826546d80461d9dc1c6",
+  "output_sha256": "dfd93eef2cebe8fd8501a4b2a52608dfcaeae910c444cacb906ec6928d481b61",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c1db01a8f111dbd529d0812e3c9a6249c6819dac40caa3fa40e451905ec7a326.md b/vision-fixhub/ds9-unparsed-05/c1db01a8f111dbd529d0812e3c9a6249c6819dac40caa3fa40e451905ec7a326.md
new file mode 100644
index 0000000000000000000000000000000000000000..d44f719a110d04eefe6345bbac648e151c58a94a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c1db01a8f111dbd529d0812e3c9a6249c6819dac40caa3fa40e451905ec7a326.md
@@ -0,0 +1,12551 @@
+07/29/2011 13:11 FAX
+2001/004
+KIRKLAND & ELLIS LLP
+Fax Transmittal
+300 North LaSalle Street
+Chicago, Illinois 60654
+hone: (312) 862-2001
+Fax: (312) 862-2201
+Please notify us immediately if any pages are not received.
+THE INFORMATION CONTAINED IN THIS COMMUNICATION IS CONFIDENTIAL, MAY
+OBECIOSURE OR COPING IS STRETLY PROHIBED AND MAY BE MEN AD
+IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR,
+PLEASE NOTIFY US IMMEDIATELY AT:
+(312) 862-2000.
+To:
+Company:
+United States Attorney, Southern
+District of Florida
+Company:
+Fax#:
+Direct #:
+CC:
+MartinG. Weinberg,
+Esq.
+From:
+Sandra Musumeci for
+Jay P. Lefkowitz, P.C.
+Message:
+Fax#:
+Direct #:
+Date:
+July 29, 2011
+Pages w/cover:
+4
+Fax #:
+Direct #:
+Please se hanktched lette, in response to your lter to Marin Weinberg of July 27, 2011, concerning Joffrey
+Documen2
+
+
+07/29/2011 13:12 FAX
+01002/004
+KIRKLAND & ELLIS LLP
+AND AFFILIATED FARTNERSHIPS
+601 Lexington Avenue
+lew York, New York 1002:
+lay P. Lefkowitz, P.C
+o Call Writer Directly
+lay.letkowitz@kirkland.com
+Facsimlle:
+www.kirkland.com
+July 29, 2011
+Delivery by Facsimile
+
+Assistant United States Attomey
+United States Attorney, Southern District of Florida
+500 S. Australian Avenue
+Suite 400
+West Palm Beach, FL 33401
+Re: Jeffrey Epstein
+Dear
+Chicago
+Thank you for your letter of July 27, 2011 to my co-counsel Martin Weinberg concerning
+the request by the New York District Attorney for copies of the Non-Prosecution Agreement
+("NPA") and the "victim list" in regards to Mr. Epstein. We continue for the reasons stated
+herein to believe that any such disclosure would violate the confidentiality agreement between
+your Office and Mr. Epstein as well as the provisions of Fed. R. Crim. P. 6(c).
+As to the NPA, you have repeatedly asserted in Doe v United States, No. 9:08-cv-80736-
+KAM, that the NPA was a confidential document. For instance, in paragraph 6 of Document 14,
+your own Declaration, you stated that the NPA contained "an express confidentiality provision."
+In opposing the Motion to Unseal the NPA that was filed by Jane Doe, you stated that you had
+informed Judge Marra of the confidentiality provision during an earlier telephonic statis
+conference occurring on August 14, 2008 which "the United States was obligated to honor,"
+Document 29 at 1, and that "the parties who negotiated the Agreement, the United States
+Attorney's Office and Jeffrey Epstein, determined that the Agreement should remain
+confidential," Document 29 at 2. Further, you deemed the NPA "confidential," for
+understandable purposes, in your September 3, 2008 letter to Robert Josefsberg in which you
+informed him that Judge Marra had set forth procedures for providing the NPA only to those
+counsel and "victims" who executed a Protective Order preventing its subsequent disclosure.
+The New York Assistant District Attorey, Ms. Morse, is representing the prosecution in
+an appeal regarding a sex offender registration determination, and any disclosure of the NPA to
+her has the potential to result in its use in that appeal and the real risk that the appellate court will
+unseal it. We believe it to violate both the spirit and the most logical interpretation of the NPA,
+Hong Kong
+London
+Los Angeles
+Munich
+Palo Alto
+San Francisco
+Shanghai
+Washington D.C.
+КЖЕ 19439748.2
+
+
+07/29/2011 13:12
+FAX
+0003/004
+KIRKLAND & ELLIS LLP
+July 29, 2011
+Page 2
+paragraph 13, for you to disclose it absent a subpoena -- which we could oppose in the
+jurisdiction from which it emanated. We further believe that when parol evidence supplements
+he text of paragraph 13 of the NPA, it is perfectly apparent from your prior submissions that you
+s well as we believed the NPA to contain "an express confidentiality provision" that you
+current willingness to disclose absent court process violates.
+As to the "victim list," again, not only is it confidential given its nexus to the NP'A, but
+your own prior letters tie the list to the Federal Grand Jury investigation and thus to the nondisclosure provisions of Fed. R. Crim. P. 6(e). On July 8, 2008, you wrote to Jack A.
+Goldberger, Esq., and informed him that on June 30, 2008, 'the United States Attorney's Office
+provided [him] with a list of thirty-one individuals 'whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein.'" (emphasis added). On July 9,
+2008, you wrote in a follow-up letter to Mr. Goldberger that "the U.S. Attomey's modification of
+the 2255 portion of the Agreement now limits our victim list to those persons whom the United
+States was prepared to include in an indictment. This means that, pursuant to Justice
+Department policy, these are individuals for whom the United States believes it has proof beyond
+a reasonable doubt that each of them was a victim of an enumerated offense." (emphasis added).
+First Assistant United States Attorney Jeffrey Sloman used similar language in tying the names
+of the "victims" to the basis for a potential indictment, sce December 6, 2007 letter from Mr.
+Sloman to Mr. Lefkowitz at 2, 3; see also your email to Mr. Lefkowitz and Mr. Black on August
+14, 2008 at 3:27 p.m., where you state that the list contains "only those 'individuals whom [the
+United States] was prepared to name in an Indictment...."" thus clearly providing the nexus
+between the list and the Grand Jury investigation and its corollary, the protections from nondisclosure enumerated in Fed. R. Crim. P. 6(e).
+In terms of case law, the names of witnesses that either testified or were identified during
+Grand Jury proceedings are subject to the secrecy provisions of Fed, R. Crim. P. 6(e). See, c.g.
+In re Grand Jury Subpoena, Judith Miller, 438 F.3d 1138, 1140 (D.C. Cir. 2006) ("Consistent
+with these purposes, we have recognized that grand jury secrecy covers 'the identities of
+witnesses or jurors, the substance of testimony as well as actual transcripts, the strategy or
+direction of the investigation, the deliberations or questions of jurors, and the like."") (citing In re
+Dow Jones & Co., Inc., 142 F.3d 496, 500 (D.C. Cir. 1998)); see also SEC v Dresser Industr.
+Inc., 628 F.2d 1368, 1382 (D.C. Cir. 1980); Fund for Constitutional Gov't v Nat'| Archives &
+Records Sery., 656 F.2d 856, 869 (D.C. Cir. 1981). Indeed, it is generally recognized that the
+scope of protection accorded to Grand Jury proceedings under Rule 6(e) is broad and
+encompasses, arrong other things, information such as the "victim list" at issue here:
+K&F 19439748.2
+
+
+07/29/2011 13:12 FAX
+i'":
+E004/004
+KIRKLAND & ELLIS LLP
+July 29, 2011
+Page 3
+We construe the secrecy provisions of Rule 6(e) to apply not only to disclosures
+In re Grand Jury Investigation, 610 F.2d 202, 216-17 (5th Cir. 1980).'
+We believe that confidentiality applies to the requested information. We believe that any
+non-compulsory handover of the list or NPA is inconsistent with the positions you have
+previously taken in related litigation. Accordingly, we request that you reconsider and decline
+the request of the New York District Attorney.
+Sincerely,
+Lefkowitz, P.C.
+Cc:
+Martin G. Weinberg
+JPL/sIm
+Decisions of the United States Court of Appeals for the Fifth Circuit handed down prior to September 30, 1981,
+are binding as precedent in the Eleventh Circuit. See Bonner v City of Prichard Ala., 661 F.2d 1206, 1207
+(11th Cir. 1981).
+K&E 19439748.2
+
+
+Roy BLAcK
+HOWARD M. SREBNICK
+SCOTT A. KORNSPAN
+LARRY A. STUMPE
+MARIA NEVRA
+JACKIE PERCZEK
+MARK A.J. SHAPIRO
+JARED LOPEZ
+BLACK
+SREBNICK
+KORNSPAN
+STUMPF
+JESSICA FONSECA-NADER
+KATHLEEN P. PHILLIPS
+MARCOS BEATON, JR.
+MATTHEW P. O'BRIEN
+JENIFER J. SOULKIAS
+NOAH FOX
+E-Mail:
+September 1, 2009
+Assistant U.S. Attorney
+United States Attorney's Office
+99 N.E. 4* Street
+Miami, Florida 33132
+RE: Jeffrey Epstein
+Dear
+Once again I need to send you a note about Jeffrey Epstein, mainly to keep
+you in the loop so we don't inadvertently violate any provision of his agreement
+with your office. As I am sure you are aware, Mr. Epstein has finished the
+incarceration portion of his sentence and is now serving the one year of
+community control as mandated by both his state plea and the terms of the nonprosecution agreement with the United States Attorney's Office for the Southern
+District of Florida.
+Mr. Epstein is in compliance with all terms of his community control and
+is applying for transfer of his supervision from the State of Florida to his primary
+residence, the Virgin Islands.
+This transfer is being requested through the
+Intrastate Compact for Transfer of Adult Supervision (ICAOS). The ICAOS is the
+mechanism for which transfers of probation and community control are
+effectuated. The process requires the offender to seek the approval of the sending
+state (in this case Florida) and, if they agree, the receiving state (in this case the
+United States Virgin Islands) and the United States Virgin Islands after
+investigation has pre-approved the transfer under the same exact conditions of
+supervision as imposed in Mr. Epstein's community control sentence in the State
+of Florida.
+Even though Mr. Epstein is requesting the transfer he is still at the home
+201 S. Biscayne Boulevard, Sulte 1300 - Miami, Florida 3313l • Phone: 305-371-6421 - Fax: 305-358-2006 - www.RoyBlack.com
+
+
+Jeffrey Sloman, Esq.
+September 1, 2009
+Page 2
+in Palm Beach following the rules of state community control. As Mr. Epstein's
+lawyers, we believe that his request to administratively transfer his community
+I am happy to discuss this with you at any time. I did not want to set an
+appointment to see you on this issue since I imagine you have more pressing
+matters to deal with than a transfer of a state community control matter.
+ery tuly yours
+Roy Black
+RB/wg
+Black, Srebnick, Kornspan & Stumpf, P.A.
+
+
+Roy BLACK
+HOWARD M. SREBNICK
+SCOTT A. KORNSPAN
+LARRY A. STUMPE
+MARIA NEYRA
+JACKIE PERCZEK
+MARK A.J. SHAPIRO
+JARED LOPEZ
+BLACK
+SREBNICK
+KORNSPAN
+& STUMPF
+JESSICA FONSECA-NADER
+KATHLEEN P. PHILLIPS
+AARON ANTHON
+MARCOS BEATON, JR
+MATTHEW P. O'BRIEN
+JENIFER J. SOULIKIA:
+E-Mail:
+February 18, 2010
+Assistant United States Attorney
+99 N.E. 4* Street
+Miami, FL 33132
+RE:
+Jeffrey Epstein
+Dear
+Thank you for your letter of February 11, 2010. We write to update you
+about ongoing efforts to reach an agreement with Robert Josefsberg regarding the
+amount of fees and costs properly owed to him by Mr. Epstein pursuant to the
+NPA.
+On February 16, 2010 Mr. Epstein's principal civil counsel Bob Critton
+advised Mr. Josefsberg in writing that he and Mr. Epstein would meet with Mr.
+Josefsberg on two occasions between now and March 1, 2010 to review Mr.
+Josefsberg's outstanding bills on a line-by-line basis and attempt to reach a nonadversarial resolution of all outstanding fee issues. Mr. Critton also transmitted
+to Mr. Josefsberg an Agreement for Special Master to Determine Amount of
+Attorneys' Fees and Costs ("Special Master Agreement"), signed by Mr. Epstein,
+containing terms and conditions previously agreed to by Mr. Josefsberg, which
+would mandate binding mediation before a neutral third party in the event the
+proposed settlement discussions did not resolve all outstanding issues in an
+expeditious manner.
+We want to assure you that Mr. Epstein fully intends to fulfill his obligations
+under the NPA. We regret that issues remain unresolved regarding whether all of
+the fees and costs being sought by the attorney representative - which now total
+$1,947,000 exclusive of the $526,466 already paid by Mr. Epstein - meet the
+criteria set forth by the NPA. We assure you that both Mr. Epstein's prior civil
+counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the NPA
+language, and Mr. Critton, each strongly believe that significant amounts of the
+fees and costs billed by Mr. Josefsberg are outside the scope of Mr. Epstein's fee-
+201 S. Biscayne Boulevard, Suite 1300 • Miami, Florida 3313l • Phone: 305-371-6421 • Fax: 305-358-2006 • www.RoyBlack.com
+
+
+Marie
+Esq.
+February 18, 2010
+Page 2
+related payment obligations under the NPA. We hope that the fee-related issues
+can be resolved by further settlement discussions or by relying on the Special
+Master Agreement signed Tuesday February 16, 2010 by Mr. Epstein. Mr. Epstein
+and his counsel believe that these options are consistent with the NPA, are good
+faith alternatives to contested litigation, and are reasonable given the unexpected
+magnitude of the bills and their inclusion of charges for legal work that was
+clearly related to the preparation of litigation and thus outside Par 7C of the
+Addendum as well as for extensive work performed by attorneys from outside Mr.
+Josefsberg's law firm.
+Mr. Josefsberg previously advocated for settling outstanding issues through
+a Special Master Agreement nearly identical to the one executed Tuesday by Mr.
+Epstein. In fact, Mr. Josefsberg and Mr. Epstein had each agreed in the past to
+a specific Master as a third-party neutral to conduct proceedings to resolve the fee
+issues. However, the selected Master withdrew.
+We hope that the Special Master Agreement will provide a basis for a prompt
+resolution of any issue not resolved by the parties through further discussions.
+Respectfully submitted,
+MARTIN WEINBERG, ESQ.
+/wg
+cc:
+Robert Senior, Esq.
+Black, Srebnick, Kornspan & Stumpf, P.A.
+
+
+March 20, 2011
+To whom it may concern:
+I served as U.S. Attorney for the Southern District of Florida from 2005 through 2009. Over the
+past weeks, I have read much regarding Mr. Jeffrey Epstein. Some appears true, some appears
+distorted. I thought it appropriate to provide some background, with two caveats: (i) under
+Justice Department guidelines, I cannot discuss privileged internal communications among
+Department attorneys and (ii) I no longer have access to the original documents, and as the
+matter is now nearly 4 years old, the precision of memory is reduced.
+The Epstein matter was originally presented to the Palm Beach County State Attorney. Palm
+Beach Police alleged that Epstein unlawfully hired underage high-school females to provide him
+sexually lewd and erotic massages. Police sought felony charges that would have resulted in a
+term of imprisonment. According to press reports, however, in 2006 the State Attorney, in part
+due to concerns regarding the quality of the evidence, agreed to charge Epstein only with one
+count of aggravated assault with no intent to commit a felony. That charge would have resulted
+in no jail time, no requirement to register as a sexual offender and no restitution for the underage
+victims.
+Local police were dissatisfied with the State Attorney's conclusions, and requested a federal
+investigation. Federal authorities received the State's evidence and engaged in additional
+investigation. Prosecutors weighed the quality of the evidence and the likelihood for success at
+trial. With a federal case, there were two additional considerations. First, a federal criminal
+prosecution requires that the crime be more than local; it must have an interstate nexus. Second,
+as the matter was initially charged by the state, the federal responsibility is, to some extent, to
+back-stop state authorities to ensure that there is no miscarriage of justice, and not to also
+prosecute federally that which has already been charged at the state level.
+After considering the quality of the evidence and the additional considerations, prosecutors
+concluded that the state charge was insufficient. In early summer 2007, the prosecutors and
+agents in this case met with Mr. Epstein's attorney, Roy Black. Mr. Black is perhaps best known
+for his successful defense of William Kennedy Smith. The prosecutors presented Epstein a
+choice: plead to more serious state felony charges (that would result in 2 years' imprisonment,
+registration as a sexual offender, and restitution for the victims) or else prepare for a federal
+felony trial.
+What followed was a year-long assault on the prosecution and the prosecutors. I use the word
+assault intentionally, as the defense in this case was more aggressive than any which I, or the
+prosecutors in my office, had previously encountered. Mr. Epstein hired an army of legal
+superstars: Harvard Professor Alan Dershowitz, former Judge and then Pepperdine Law Dean
+Kenneth Starr, former Deputy Assistant to the President and then Kirkland & Ellis Partner Jay
+Lefkowitz, and several others, including prosecutors who had formally worked in the U.S.
+
+
+Attorney's Office and in the Child Exploitation and Obscenity Section of the Justice Department.
+Defense attorneys next requested a meeting with me to challenge the prosecution and the terms
+previously presented by the prosecutors in their meeting with Mr. Black. The prosecution team
+and I met with defense counsel in Fall 2007, and I reaffirmed the office's position: two years,
+registration and restitution, or trial.
+Over the next several months, the defense team presented argument after argument claiming that
+felony criminal proceedings against Epstein were unsupported by the evidence and lacked a basis
+in law, and that the office's insistence on jail-time was motivated by a zeal to overcharge a man
+merely because he is wealthy. They bolstered their arguments with legal opinions from wellknown legal experts. One member of the defense team warned me that the office's excess zeal in
+forcing a good man to serve time in jail might be the subject of a book if we continued to
+proceed with this matter. My office systematically considered and rejected each argument, and
+when we did, my office's decisions were appealed to Washington. As to the warning, I ignored
+it.
+The defense strategy was not limited to legal issues. Defense counsel investigated individual
+prosecutors and their families, looking for personal peccadilloes that may provide a basis for
+disqualification. Disqualifying a prosecutor is an effective (though rarely used) strategy, as
+eliminating the individuals most familiar with the facts and thus most qualified to take a case to
+trial harms likelihood for success. Defense counsel tried to disqualify at least two prosecutors. I
+carefully reviewed, and then rejected, these arguments.
+Despite this army of attorneys, the office held firm to the terms first presented to Mr. Black in
+the original meeting. On June 30, 2008, after yet another last minute appeal to Washington D.C.
+was rejected, Epstein pled guilty in state court. He was to serve 18 months imprisonment,
+register as a sexual offender for life and provide restitution to the victims.
+Some may feel that the prosecution should have been tougher. Evidence that has come to light
+since 2007 may encourage that view. Many victims have since spoken out, filing detailed
+statements in civil cases seeking damages. Physical evidence has since been discovered. Had
+these additional statements and evidence been known, the outcome may have been different. But
+they were not known to us at the time.
+A prosecution decision must be based on admissible facts known at the time. In cases of this
+type, those are unusually difficult because victims are frightened and often decline to testify or if
+they do speak, they give contradictory statements. Our judgment in this case, based on the
+evidence known at the time, was that it was better to have a billionaire serve time in jail, register
+as a sex offender and pay his victims restitution than risk a trial with a reduced likelihood of
+success. I supported that judgment then, and based on the state of the law as it then stood and the
+evidence known at that time, I would support that judgment again.
+Epstein's treatment, while in state custody, likewise may encourage the view that the office
+should have been tougher. Epstein appears to have received highly unusual treatment while in
+jail. Although the terms of confinement in a state prison are a matter appropriately left to the
+
+
+State of Florida, and not federal authorities, without doubt, the treatment that he received while
+in state custody undermined the purpose of a jail sentence.
+Some may also believe that the prosecution should have been tougher in retaliation for the
+defense's tactics. The defense, arguably, often failed to negotiate in good faith. They would
+obtain concessions as part of a negotiation and agree to proceed, only to change their minds, and
+appeal the office's position to Washington. The investigations into the family lives of individual
+prosecutors were, in my opinion, uncalled for, as were the accusations of bias and / or
+misconduct against individual prosecutors. At times, some prosecutors felt that we should just
+go to trial, and at times I felt that frustration myself. What was right in the first meeting,
+however, remained right irrespective of defense tactics. Individuals have a constitutional right to
+a defense. The aggressive exercise of that right should not be punished, nor should a defense
+counsel's exercise of their right to appeal a U.S. Attorney to Washington, D.C. Prosecutors must
+be careful not to allow frustration and anger with defense counsel to influence their judgment.
+After the plea, I recall receiving several phone calls. One was from the FBI Special Agent-In-
+Charge. He called to offer congratulations. He had been at many of the meetings regarding this
+case. He was aware of the tactics of the defense, and he called to praise our prosecutors for
+holding firm against the likes of Messrs. Black, Dershowitz, Lefkowitz and Starr. It was a proud
+moment. I also received calls or communications from Messrs. Dershowitz, Lefkowitz and
+Starr. I had known all three individuals previously, from my time in law school and at Kirkland
+& Ellis in the mid 90s. They all sought to make peace. I agreed to talk and meet with each of
+them after Epstein pled guilty, as I think it important that prosecutors battle defense attorneys in
+a case and then move on. I have tried, yet I confess that has been difficult to do fully in this case.
+The bottom line is this: Mr. Jeffrey Epstein, a billionaire, served time in jail and is now a
+registered sex offender. He has been required to pay his victims restitution, though restitution
+clearly cannot compensate for the crime. And we know much more today about his crimes
+because the victims have come forward to speak out. Some may disagree with the prosecutorial
+judgments made in this case, but those individuals are not the ones who at the time reviewed the
+evidence available for trial and assessed the likelihood of success.
+Respectfully,
+R. Alexander Acosta
+Former U.S. Attorney
+Sothern District of Florida
+
+
+Case S:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 1 of 51
+1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+2
+WEST PALM BEACH DIVISION
+CASE NO. 08-80119-CIV-MARRA
+WEST PALM BEACH, FLORIDA
+1
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+JANE DOE, et al.,
+Plaintiffs,
+JUNE 12, 2009
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+x
+TRANSCRIPT OF MOTION HEARING
+BEFORE THE HONORABLE KENNETH A. MARRA,
+UNITED STATES DISTRICT JUDGE
+APPEARANCES:
+FOR THE PLAINTIFFS:
+ADAM D. HOROWITZ, ESQ.
+Mermelstein & Horowitz
+18205 Biscayne Boulevard
+Miami, FL 33160
+For Jane Doe
+BRADLEY J. EDWARDS, ESQ.
+Rothstein Rosenfeldt Adler
+401 East Las Olas Boulevard
+Fort Lauderdale, FL 33301
+Jane Doe 3, 4, 5, 6, 7
+ISIDRO M. GARCIA, ESQ.
+Garcia Elkins Boehringer
+224 Datura Avenue
+West Palm Beach, FL 33401
+Jane DOE II
+RICHARD H. WILLITS, ESQ.
+2290 10th Avenue North
+Lake Worth, FL 33461
+For C.M.A.
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 2 of 51
+2
+1
+2
+3
+4
+5
+6
+7
+8
+FOR THE DEFENDANT:
+ROBERT C. JOSEFSBERG, ESQ.
+Podhurst Orseck Josefsberg
+25 West Flagler Street
+Miami, FL 33130
+For Jane Doe 101
+(Via telephone)
+KATHERINE W. EZELL, ESQ.
+Podhurst Orseck Josefsberg
+25 West Flagler Street
+Miami, FL 33130
+For Jane Doe 101
+ROBERT D. CRITTON, JR., ESQ.
+MICHAEL BURMAN, ESQ.
+Burman Critton, etc.
+515 North Flagler Street
+West Palm Beach, FL 33401
+561.842.2820
+JACK A. GOLDBERGER, ESQ.
+Atterbury Goldberger Weiss
+250 Australian Avenue South
+West Palm Beach, FL 33401
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+AS AMICUS CURIAE:
+REPORTED BY:
+Assistant U.S. Attorney
+500 East Broward Boulevard
+Fort Lauderdale, FL 33394
+For U.S.A.
+MARTIN G. WEINBERG, ESQ.
+20 Park Plaza
+Boston MA 02116
+(Via telephone)
+JAY LEFKOWITZ, ESQ.
+(Via telephone)
+LARRY HERR, RPR-RMR-FCRR-AE
+official United States Court Reporter
+Federally Certified Realtime Reporter
+400 North Miami Avenue, Room 8N09
+Miami, FL 33128
+25
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 3 of 51
+THE COURT: We are here in the various Doe vs. Epstein
+1
+2
+cases.
+3
+May I have counsel state their appearances?
+4
+MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs
+5
+Jane 2 through Jane Doe 7.
+6
+THE COURT: Good morning.
+7
+MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane
+8
+Doe.
+9
+THE COURT: Good morning.
+10
+MR. GARCIA: Good morning, Your Honor. Sid Garcia for
+11 Jane Doe II.
+12
+THE COURT: Good morning.
+13
+MR. WILLITS: Good morning, Your Honor. Richard
+14 Willits, here on behalf of the plaintiff C.M.A..
+15
+THE COURT: Good morning.
+16
+MS. EZELL: Good morning, Your Honor. I'm Katherine
+17
+Ezell from Podhurst Orseck, here with Amy Adderly and Susan
+18 Bennett, and I believe my partner, Bob Josefsberg, is going to
+19
+appear by telephone.
+20
+THE COURT: MI. Josefsberg, are you there?
+21
+22
+MR. JOSEFSBERG: I am, Your Honor.
+THE COURT: Good morning.
+23
+MR. JOSEFSBERG: Good morning.
+24
+THE COURT: All right. Do we have all the plaintiffs
+25
+stated their appearances? Okay.
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 4 of 51
+4
+1
+Defense?
+2
+MR. CRITTON: Your Honor, Robert Critton on behalf of
+3
+4
+Mr. Epstein, and my partner, Michael Burman.
+THE COURT: Good morning.
+5
+MR. GOLDBERGER: Good morning, Your Honor. Jack
+6
+Goldberger on behalf of Mr. Epstein.
+7
+THE COURT: I see we have some representatives from
+8
+the United States Attorney's Office here.
+9
+MS.
+Good morning, Your Honor.
+10
+for the U.S. Attorney's office.
+11
+THE COURT: Good morning.
+12
+Who else do we have on the phone?
+13
+MR. CRITTON: Your Honor, we have two members of the
+14
+defense team are on the phone, also.
+15
+THE COURT: Who do we have on the phone?
+16
+MR. WEINBERG: Martin Weinberg. Good morning, Your
+17 Honor.
+18
+MR. LEFKOWITZ: Jay Lefkowitz. Good morning, Your
+19
+Honor.
+20
+THE COURT: Good morning.
+21
+I scheduled this hearing for very limited issues
+22
+23
+which, as you all know, there's been a motion by Mr. Epstein to
+stay the civil proceedings against him. The one issue I have
+24
+concern about is Mr. Epstein's contention or assertion that by
+25
+defending against the allegations in the civil proceedings, he
+
+
+Case 9:08-Cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 5 of 51
+1
+may expose himself to an allegation by the United States in the
+2
+non-prosecution agreement that he's violated that agreement and
+3
+therefore would subject himself to potential federal charges.
+4
+I had asked for some briefing on this. I asked the
+United States to present its position to me. And I received
+6
+the Government's written response, which I frankly didn't find
+7
+very helpful. And I still am not sure I understand what the
+8
+Government's position is on it.
+9
+So first let me hear from Mr. Epstein's attorneys as
+10
+to what do you believe the concern is. I don't believe the
+11
+non-prosecution agreement has ever been filed in this court; am
+12
+I correct?
+13
+MR. CRITTON: To my knowledge, Your Honor, it has not.
+14
+THE COURT: So I don't believe I've ever seen the
+15
+entire agreement. I've seen portions of it.
+16
+MR. EDWARDS: Your Honor, I believe that it was filed
+17
+under Jane Doe 1 and 2 vs. United States of America, case under
+18
+seal in your court.
+19
+THE COURT: okay.
+20
+MR. EDWARDS: In a separate case.
+21
+THE COURT: In that case, okay. Was it actually filed
+22
+in that case?
+23
+MR. EDWARDS: I filed it under seal.
+24
+THE COURT: In any event, what's Mr. Epstein's concern
+25
+about if you defend the civil actions, you're going to expose
+5
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 6 of 51
+yourself to a claim for a breach by the United States of the
+2
+non-prosecution agreement?
+3
+MR. CRITTON: Robert Critton.
+4
+Your Honor, our position on this case is, I'd say is
+5
+somewhat different. When this issue originally came before the
+6
+Court, as you are aware prior to my firm's involvement in the
+7
+case, there was a motion filed on behalf of Mr. Epstein seeking
+8
+a stay. And I think it was in Jane Doe 102 and then
+9
+subsequently Jane Doe 2 through 5 because all of those cases
+10
+were filed on or about the same time.
+11
+And at that time the Court looked at the issue and it
+12
+was based upon a statutory provision at that time. And the
+13
+Court said I don't find that it's applicable, or for whatever
+14
+reason I think the Court said I don't consider that to be a
+15
+pending proceeding or a proceeding at that particular time.
+16
+In that same order, which was in Jane Doe 2, I
+17
+believe it's -- not I believe, I know it's docket entry 33, the
+18|
+Court also went on to talk about at that particular point in
+19
+time dealt with the issue of the discretionary stay.
+20
+And the Court said at that time, I'm paraphrasing, but
+21
+the Court also does not believe a discretionary stay is
+22
+warranted. And what the Court went on to say is that if
+23
+defendant does not breach the agreement, then he should have no
+24
+concerns regarding his Fifth Amendment right against
+25
+self-incrimination.
+6
+
+
+Casé 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 7 of 51
+1
+The fact that the U.S. Attorney or other law
+2
+enforcement officials may object to some discovery in these
+3
+civil cases is not in and of itself a reason to stay the civil
+4
+litigation, so that any such issue shall be resolved as they
+arise in the course of the litigation.
+6
+And I would respectfully submit to the Court that the
+7
+position that the Government has taken in its most recent
+8
+filings changes the playing field dramatically. Because what
+9
+the Government in essence has said as distinct from the U.S.
+10
+saying is, well, we object to some discovery, or we may object
+11 to some discovery in the civil cases.
+12
+What they have, in essence, said is if you take some
+13
+action, Mr. Epstein, that we believe unilaterally, and this is
+14
+on pages 13 and 14 of their pleading or of their response memo
+15
+to the Court's inquiry, they say if Mr. Epstein breaches the
+•16
+agreement. They said it's basically like a contract, and if
+17
+one side breaches, the other side can sue.
+18
+In this instance what the Government will do is if we
+19
+believe that Mr. Epstein has breached the agreement, we'll
+20
+indict him. We will indict him. And his remedy under that
+21
+circumstance, which is an incredible and catastrophic catch 22
+22
+is, we'll indict him and then he can move to dismiss. That's a
+23
+great option.
+24
+In this particular instance my mandate in defending --
+25
+and that's a dramatic change in the Government's position,
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 8 of 51
+1 because the Government is not saying, and the Court was pretty
+2
+specific in what you asked the Government for in its response
+3 is, in essence, and it's the same question in a more limited
+4 fashion you're posing today is whether Mr. Epstein's defense of
+the civil action violates the NPA agreement, the
+6 non-prosecution agreement, between the U.S. and Mr. Epstein.
+7
+And the Government refuses to answer that question.
+8
+They won't come out and say, yes, it will, or no, it won't.
+9
+What they're doing is they want to sit on the sideline, and as
+10
+their papers suggest is, they want us to lay in wait and that
+11
+if, in fact, they believe he violates a provision of the NPA as
+12
+it relates to the defense of this case or these multitude of
+13
+cases, then they can come in and indict him -- no notice, no
+14
+opportunity to cure.
+15
+We don't think that's what the NPA says, but that's
+16
+certainly what their papers say. We'll indict him, no notice,
+171
+no opportunity to cure. We will indict him, and his remedy
+18||
+under that circumstance is that he can move to dismiss the
+19
+indictment.
+20
+Well, that's great except Mr. Epstein, his mandate to
+21
+me and I know his mandate to his criminal lawyers, is: Make
+22
+23
+certain I don't do anything, in particular in these civil cases
+that would in any way suggest that I am in willful violation of
+24
+the NPA.
+25
+8
+Now, in the Court's prior ruling in the docket entry
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 9 of 51
+1
+33, certainly some aspects of the NPA are within Mr. Epstein's
+2
+control. There's no question about that. But aspects that
+3
+relate to the defense of these cases, either in terms of the
+4
+civil lawyers who are defending these, I think there's 12 or 13
+pending cases in front of you, there's another four cases in
+6
+the state court, is the risk is substantial, it's real, and it
+7
+presents a chilling effect for the civil lawyers in moving
+8
+forward to determine whether or not we're taking some action
+9
+that in some way may be a violation of the NPA.
+10
+And the Government's, again, refusal or non-position
+11
+with regard to past acts that have been taken in the civil case
+12
+with regard to the defense or future acts that we may take with
+13
+regard to these contested litigation casts an extraordinary
+14
+cloud of doubt and uncertainty and fear that the defense of
+15
+these cases could jeopardize Mr. Epstein and put him in the
+16
+irreparable position of violating the NPA and then subsequently
+17|
+being indicted.
+18
+In this particular instance, again, Mr. Epstein has no
+19
+intention of willfully violating the NPA, but it's of great
+20
+concern to him. And I'd say with the position that the
+21
+Government has taken, no notice, no cure period, no opportunity
+22
+to discuss. Again, we think that's not what the NPA provides,
+23
+it's not what the deal was between the two contracting parties,
+24
+the United States and Mr. Epstein. But that's clearly what
+25
+their papers say under the circumstances, and it would create
+9
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 10 of 51 10
+1
+this irreparable harm to Mr. Epstein under the circumstances.
+2
+In essence, we're left with a catch 22 in defending
+the civil cases. We have a mandate to take no action, to take
+4 any action which may be deemed to be a violation of the NPA,
+either in the past or in the future, which would in any way
+6
+risk Mr. Epstein being indicted by the United States.
+7
+He has the clear risk of an indictment based upon the
+8
+papers that the Government filed. It's real, it's not remote,
+9
+and it's not speculative. It chills the action of the defense
+10
+in this instance of both Mr. Epstein and his attorneys in
+11
+trying to defend these cases and decide under the circumstances
+12
+can we do this, can we take this position with regard to
+13
+depositions, can we take this legal position with regard to
+14
+motions to dismiss, with regard to responses, with regard to
+15
+replies?
+16
+And we send out paper discovery. Is this in some way
+17
+if we contact someone who may be an associate of these
+18
+individuals as part of our investigation, is that potentially
+19
+in any way a violation of the NPA? Again, we don't think so.
+20
+And, obviously, again, my direction has been from my
+21
+client: Don't take any action that would result in me being
+22
+indicted under the NPA. Well, that's great. But, generally,
+23
+civil lawyers or civil lawyers in defending a personal injury
+24
+case or a tort case, which is exactly what these are, and from
+25
+a practical standpoint, we use various tools to do discovery.
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 11 of 51 11
+1
+They're standard. They're specific. They're very temporary.
+2
+Very typical.
+3
+But in this instance, as the Court knows, things are
+4
+not typical with regard to this case in any way, shape or form.
+5
+We can't even serve subpoenaes, there's objections and there's
+6
+-- we can't even serve objections to third parties so we can
+7
+obtain documents unless we have to filter it through the
+8
+plaintiffs' attorneys. They won't allow us to use their
+9
+clients' names, even in a subpoena that would never be filed in
+10
+the court.
+11
+How do we do a deposition of a third party? We wanted
+12
+to take the deposition of Jane Doe 4. Well, who is she? Well,
+13
+we can't tell you that. Well, who's the defendant? well, we
+14
+can't tell you that because nobody wants anybody to know
+15
+anything about the case. They want to present it strictly
+16
+through rose-colored glasses.
+17
+And in this particular instance, we simply can't
+18
+defend this case or take certain action with the spector
+19
+hanging over us that, in fact, the Government may deem it to be
+20
+a violation of the NPA, because very clearly in their response
+21
+papers, they don't say. They say we don't take the position,
+22
+and then they take a substantial position is we think there's
+23
+not all that substantial factors that would entitle him to a
+24
+stay.
+25
+Except for the one major issue which the Court posed
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 12 of 51 12
+1
+in the question is, is can he defend these cases? That's what
+2
+I really want to know. Can he defend these cases and, in
+3
+essence, what he has done in the past or what his defense team
+4
+has done in the past and what they're going to do in the
+future, can you give him, Epstein, assurances that the
+6
+Government under this situation, whatever he does, based on
+advice of counsel, that that cannot be a willful violation of
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+the NPA, which they can
+-- they, the U.S. -- can then turn
+around and say that's a violation of the agreement and,
+therefore, we're going to go proceed to indict you under the
+circumstances.
+our position is, Your Honor, is that the U.S. has now
+cavalierly suggested that, as they did in picking up on the
+court's docket entry or prior order, is, look, compliance with
+the NPA is solely up to Mr. Epstein. In this type of balance
+of equities, it doesn't speak in favor of a stay.
+Well, that's great. And maybe that was the position
+back in '08, on August 5th of '08, when the issue came up in
+front of the Court with regard to the initial stay.
+But the Government's papers under these circumstances
+suggested a very different set of circumstances. Their own
+22
+unilateral, which is the issue that we argued in the motion for
+23
+stay, is that the Government's position is that we can
+24
+unilaterally indict this man if we think he's breached the NPA.
+25
+We don't think that's right, but we have no buffer
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 13 of 51 13
+1
+between us and the Government. They'll say, and as the Court
+2
+knows, the Government has substantial power. The Government
+3
+does what it wants. Most of the time hopefully they're right.
+4
+Sometimes they make mistakes.
+5
+But in this particular instance, my client has rights.
+6 We think that there's notice provisions, we think there's cure
+7 provisions under the NPA. That's not what their paper says
+8
+under the circumstances.
+9
+And what we'd like to know from the Government, and
+10
+maybe the answer is basically what the Court asks is, let the
+11
+Government come forward today and say, based on the knowledge
+12
+that we have, or as of today's date, June 12th, 2009, we, the
+13
+Government, agree that there is no set of circumstances, not
+14
+that we're not aware of, but as of today's date, there is
+15
+nothing that exists that would be a violation of the NPA.
+16
+THE COURT: Well, that's way beyond what I'm
+17|
+interested in. I don't know what Mr. Epstein may have done
+18
+outside the context of defending this case that may constitute
+19
+a violation. And if he has done something outside the context
+20
+of defending this case that's a violation, I don't care.
+21
+That's between the United States and Mr. Epstein.
+22
+I'm only concerned about whether anything he does in
+23
+defending these civil actions is going to be a violation of the
+24
+non-prosecution agreement. If he has done something else, it's
+25
+none of my business, and I don't care, and I'm not going to
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009
+Page 14 of 51 14
+1
+even ask the Government to give you an assurance that he hasn't
+2
+done anything that might have violated the agreement up till
+3
+today. I'm only interested in defending these civil actions.
+4
+MR. CRITTON: Then I would respectfully submit to the
+5
+Court that the Government be asked in that limited context, are
+6
+they as of today, whether there were or not, but as of today is
+there anything that has been done or will you take the
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+position, the United States, that any position that MI. Epstein
+has taken with regard to defending these civil cases is in any
+way a violation of the NPA?
+THE COURT: Well, I'm not sure what they're going to
+say, but that might -- that cures the problem up to this point.
+But then we have to deal with what's going to happen from here
+on in. And that's another issue that we have to deal with.
+So I understand your position.
+But has anyone suggested to you on behalf of the
+United States that there is something that you've done in
+defending this case that they believe may or could be construed
+as a violation of the non-prosecution agreement? Has anyone
+pointed to anything that you've done? For example, the fact
+that you've wanted to take their -- I don't know if you've
+noticed depositions or not in this case, but if you've sent
+notice of taking deposition, if you sent requests for
+production of documents, if you sent interrogatories, if you
+issued third party subpoenas? Is anything you've done thus far
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on LSD Docket 06/24/2009 Page 15 of 51 15
+1
+in the context of this case been brought to your attention as a
+potential violation?
+3
+MR. CRITTON: I have received no notification nor am I
+4
+aware that we've received any notification of any action that
+5 we have taken today. As I suggested to the Court, I don't know
+6
+when they've done or not. And in their papers they suggested,
+7
+well, we don't know everything that's gone on in the civil
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+litigation.
+But from a practical standpoint, it was a number of
+comments that were made in their papers is, we can indict, we
+can see if there's a breach.
+Judge, I may have some --
+THE COURT: Before you go on.
+MR. CRITTON: I'm sorry.
+THE COURT: You've focused a great deal on the
+Government's response to my inquiry as supporting your position
+that you're in jeopardy. But you've made the suggestion, even
+before this brief was filed, that defending the case was going
+to potentially result in an assertion or allegation that you
+breached the non-prosecution agreement.
+So what was it that caused you to make that initial
+assertion? Because that's what caught my attention, was not --
+this brief that the Government has filed was in response to
+something that you filed initially in your most recent motion
+for a stay which raised the issue.
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 16 of 51 16
+1
+So what was it that gave you some concern to even
+2 raise the issue that defending this case is going to constitute
+3 a breach?
+4
+MR. CRITTON: Because there are other instances where
+5
+counsel other than myself, not in the civil aspects, where
+6
+allegations have been made and letters have been sent by the
+7
+United States suggesting that there's been a violation of the
+8
+NPA. And under those circumstances, some notification was
+9
+provided.
+10
+THE COURT: Did it have anything to do with defending
+11
+the civil actions?
+12
+MR. CRITTON: It did not.
+13
+THE COURT: So then why was that issue raised by you
+14| in the first instance?
+15
+MR. CRITTON: Because of the prospect that the
+16
+defendant could take, that the U.S. would take the position
+17| under the circumstances that a position that we took with
+18 regard to the contested litigation may well impact, that the
+19
+Government may have a very different view of what the
+20
+interpretation of the agreement is.
+21
+And as an example is a number of the parties, and I
+22
+know the Court doesn't want to get into a discussion, the issue
+23
+is, is under 2255 is that from the defendant's perspective the
+24
+deal that was cut on that, it was a very specific deal. It
+25
+dealt with both consensual and contested litigation. It dealt
+
+
+Case 9:08-Cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 17 of 51 17
+1
+with a secret list of individuals who we had no idea who was on
+2
+the list, and a commitment that he would under certain
+3
+circumstances be required to pay a minimum amount of damages,
+4
+which our position is under 2255 based upon the statute that
+was in effect at the time, a $50,000 as to anyone who wanted --
+6
+who came forward who was on the list and met certain criteria.
+7
+The position that now has been asserted by a number of
+8
+the plaintiffs under the circumstances, and it's been pled, and
+9
+actually a number of the complainants is, is Epstein agreed,
+10
+and they cite to a letter that was sent by Ms.
+from
+11 the Government, that says he has to plead guilty or he can't
+12
+contest liability. That may be true under very, very limited
+13
+or specific circumstances.
+14
+But what the plaintiffs have done in a number of the
+15
+cases, and these are pending motions, is they've said is, well,
+16
+we think C.M.A. cases is a good example, they've pled 30
+17
+separate counts of 2255 alleged violations. And they're saying
+18
+under the circumstances is, therefore, we have 2255 violations,
+19
+there's 30 of them, so 30 times 150, or should be, or whether
+20
+it's 150, that's the amount of money that we want, so maybe $15
+21
+million, or whatever the number is.
+22
+Some of the other plaintiffs' lawyers have been even
+23
+24
+more creative. They've said is, well, we'll agree that it's
+only one cause of action but that each number of violations;
+25
+that is, if 20 alleged incidents occurred, that we would
+
+
+Case 9:08-Cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 18 of 51 18
+1
+consider to be, or that we will argue are violations, then we
+2
+can take 20 times the 50, or the 150, depending on which
+3
+statute is applicable.
+4
+So the Government under that set of circumstance could
+say, and, again, this is one of the reasons that we raised it,
+6
+they could say, look, our deal with you was that you couldn't
+7
+contest liability, that you were waiving liability, or your
+8
+ability to contest an enumerated offense under 2255.
+9
+Again, part of the deal was as to an enumerated
+10
+offense. Okay. Well, what's that mean? What did he plead to?
+11
+Well, he really didn't plead to anything, which is another
+12
+issue associated with the 2255. But if the Government comes in
+13
+and says, no, wait a minute, our position was, is that you're
+14
+stuck with 2255 and the language within the NPA. And,
+15
+therefore, whether it's an offense or whether it's multiple
+16
+offenses or violations or each one represents an individual
+17
+cause of action, if the Government takes the position that's
+18
+adverse to what we think the clear reading of the agreement was
+19
+under those circumstances, they could claim a violation.
+20
+And as a result -- and that's one of the reasons we
+21
+put -- that was the most glaring one to us, so we raised that
+22
+issue. And then when the Government's response came with
+23
+regard to, is we can just proceed to indict if we think that
+24
+there's been a breach of the agreement.
+25
+That puts us at substantial risk and chills our
+
+
+Case 9:08-Cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 19 of 51 19
+1
+ability to move forward. Thank you, Your Honor.
+2
+THE COURT: Thank you. Who wants to be heard from the
+3
+plaintiffs first?
+4
+Is there any plaintiff's attorney who is contending
+5
+that the defense of these civil actions by Mr. Epstein is going
+6
+to constitute a breach of the non-prosecution agreement?
+7
+MR. JOSEFSBERG: Your Honor, this is Bob Josefsberg.
+8
+May I speak?
+9
+THE COURT: Yes, sir.
+10
+MR. JOSEFSBERG:
+We're not quite confident that any
+11 breaches of any agreement, which were third-party
+12
+beneficiaries, should be resolved by you. We're not saying it
+13
+shouldn't. But we have not raised any breach of agreement. We
+14
+think that is between the United States and Mr. Epstein.
+15
+What I find incredulous and disingenuous is that
+16 Mr. Epstein is saying that he wants a stay because he may be
+17
+forced into taking actions in the defense of this case that
+18
+would violate the agreement.
+19
+And let me make our position clear on that. If he
+20
+wants to move to take depositions, interrogatories, production,
+21
+and they are according to your rulings appropriate, not
+22
+invasive of the privacy of someone, and they are relevant, then
+23
+I don't know how those could in any way be violations of the
+24
+agreement.
+25
+What I find hypocritical is that there are two parts
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 20 of 51 20
+1
+to the agreement that I am a beneficiary of. One of them is
+2
+that he has agreed that on any action brought in the 2255, he
+3
+will admit to liability.
+4
+And I received on May 26 a motion to dismiss, which
+5
+we're prepared to respond to and disagree with, but totally
+6
+contesting liability, saying that the statute doesn't apply
+7
+because the girls are no longer minors and saying, and this is
+8
+the great one, saying that the predicate of the conviction
+9
+under 2255 has not been satisfied.
+10
+Now, the understanding that I have is the agreement
+11 between the Government and Mr. Epstein was that the Government
+12
+desired to see these victims made whole, and wanted them to be
+13
+in the same position as if Mr. Epstein had been prosecuted and
+14
+pled or convicted. And they would be able to have the
+15
+predicate of that criminal conviction, which just as a matter
+16
+of liability would just be introduced as proof that he's done
+17|
+this.
+18
+They, under the agreement, are supposed to admit to
+19
+liability on limited something that's under 2255. He has
+20
+filed, but since there is no conviction, there can be no civil
+21
+suit under 2255, with which we disagree. But it is totally in
+22
+opposite of the NPA.
+23
+The second part is there are many young ladies, and
+24
+this perhaps he can use this to his great advantage, who are
+25
+humiliated about this entire situation. Some of them won't
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 21 of 51 21
+come forward.
+2
+We were appointed by Judge Davis as a Special Master
+3
+to represent these young ladies. And some of them don't even
+4
+want to file suit. They don't even want to be known as Jane
+5
+Doe 103. They don't want any of the risks for these motions
+6
+that are pending.
+7
+8
+9
+10
+11
+12
+13
+14
+' 15
+16
+17
+18
+19
+20
+21
+And part of the agreement was that if we represented
+them and they settle, Mr. Epstein would pay our fees. And he
+has written us as of yesterday that he is under no obligation
+to pay our fees on settling cases.
+Now, those two matters, I believe, may be breaches.
+But I am not asking this Court at this time to do anything
+about them. Nor am I telling the Government, I'm not running
+to the Government and saying indict him because I want you to
+pressure him to do what he agreed to.
+I'm a third-party beneficiary for that agreement, and
+I may move to enforce certain parts of it. But as far as the
+issue of staying the litigation, that is the exact opposite of
+the intent and the letter of the NPA. The purpose of the NPA
+was so that these 34 young ladies, these victims who have been
+severely traumatized, may move on with their lives.
+22
+And to stay this action would be the exact opposite of
+23
+the purpose of that agreement and would be horrible
+24
+psychologically for all of my clients.
+25
+THE COURT: MI. Josefsberg, I understand your
+
+
+Case 9:08-cv-80119-KAM|
+Document 180 Entered on FLSD Docket 06/24/2009 Page 22 of 51 22
+1
+position. And I don't want to argue the merits of whether a
+2
+stay should or should not be granted.
+I'm just trying to understand what the ground rules
+4
+are going to be if I grant a stay or if I deny a stay. And
+5
+I've already denied a stay once. I have to decide this current
+6
+motion, and I just want to know what is going to happen if I
+deny the stay in terms of Mr. Epstein's exposure under the
+non-prosecution agreement. That's my concern.
+9
+So if you're telling me that you're not going to urge
+10
+the United States, on behalf of any of your clients, to take
+11
+the position that he's breached the agreement because he's
+12
+taking depositions, because he's pursuing discovery, because
+13
+he's conducting investigations that anyone in any other type of
+14
+civil litigation might conduct with respect to plaintiffs that
+15
+are pursuing claims against a defendant, that those typical
+16
+types of actions, in your judgment, are not breaches of the
+17
+18
+agreement and that he can go forward and defend the case as any
+other defendant could defend, and you're not going to run to
+19
+the United States and say, hey, he's breaching the agreement by
+20
+taking depositions and he's breaching the agreement by issuing
+21
+subpoenas to third parties in order to gather information
+22
+necessary to defend, then I don't have a problem. But if he's
+23
+going to be accused of breaching the agreement because he sends
+24
+out a notice of deposition of one of your clients, how is he
+25
+supposed to defend the case?
+
+
+Case 9:08-Cv-80119-KAM
+Document 180 Entered on FLSD Docket 06/24/2009 Page 23 of 51 23
+1
+MR. JOSEFSBERG: Your Honor, you're totally correct.
+2
+He can depose my client. That's not a problem. But the
+3
+problem is that these are not typical clients and this is not a
+4
+typical case. He has written in his pleadings that he wants to
+5
+publish the names of these girls in the newspapers so that
+6
+other people may come forward to discuss their sexual
+activities with these different plaintiffs. That's not your
+8
+typical case. But are rulings that you'll make in this case,
+9
+and they're not part of the NPA.
+10
+As far as my going to the Government is concerned, I
+11
+find it very uncomfortable for me to use the Government to try
+12
+to pursue my financial interest in litigation. And I know that
+13
+Mr. Epstein and his counsel will make much ado about it. So I
+14
+am not going to be running there.
+15
+However, if they start taking depositions regarding
+16
+liability, I will consider that to be a breach because they're
+17
+supposed to have admitted liability.
+18
+THE COURT: But, again, I don't have the agreement and
+19
+I don't remember reading the agreement. But what I'm being
+20
+told is the part of the agreement that admits liability is only
+21
+as to a 2255 claim, and there are numerous other personal
+22
+injury tort claims other than 2255 claims.
+23
+And there's a limit of damages on the 2255 claim, as I
+24
+understand it, but I presume that all the plaintiffs are going
+25
+to seek more than the limited or capped amount of damages in
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 24 of 51 24
+1
+the non-prosecution agreement as to the other claims.
+2
+And so why aren't they entitled to defend and limit
+3
+the amount of damages that your client is seeking on the
+4
+non-2255 tort claims?
+5
+MR. JOSEFSBERG: Your Honor, you are correct. on
+non-2255 tort claims, they are permitted to do the defense,
+7 whatever is appropriate.
+8
+My cases are pure 2255 on which liability under the
+9
+agreement is supposed to be admitted. Now, as to the amount of
+10
+damages, there are legal issues that will be before you and
+11
+under the C.M.A. cases that are getting before you, as to
+12
+whether it is 50 or 150. That has nothing to do with the NPA.
+13
+There are legal issues that are before you as to
+14
+whether it is per statute, per count. or per incident or per
+15
+plaintiff. Those have nothing to do with the NPA. There is no
+16
+amount in NPA. Those will be resolved.
+17
+Anyone who has brought a case that is outside of 2255,
+18 the defense is permitted to contest liability under the NPA.
+19| That's no violation.
+20
+Under the NPA if someone brought a case under just
+21
+22
+2255, Mr. Epstein, if he is to keep his word, cannot contest
+liability. And there would no need to stay this. Because it
+23
+is a self-fulfilling agreement. He can contest liability. And
+24|
+as far as the amount of damages, anyone that wants to go over
+25
+the statutory minimums, of course, he can contest that in any
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 25 of 51 25
+1
+way that is proper under the Rules of Evidence and your
+rulings. The NPA has no limitation on his contesting damages
+3
+above the minimum statutory amount.
+4
+The only thing that he has done is in his actions of
+5
+refusing to pay for settling defendants, and in his saying that
+he has no liability under 2255, those appear to be contrary to
+7
+what's in the NPA.
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+But I'm not in any position right now to claim a
+breach, and I don't know whether I'd be claiming a breach or
+enforcing it in front of you, suing him for fees, asking you to
+have him admit liability, or complaining to the Government.
+And that's why I'm not that helpful in this situation because I
+think it's the Government's role.
+But I do not waive the right to be a third-party
+beneficiary because pursuant to my appointment, which was
+agreed to by Mr. Epstein, I and my clients have certain rights,
+and we want to enforce them.
+But his defending this lawsuit will not in any way be
+a violation. His getting this lawsuit stayed would be a
+violation of the spirit of taking care of these girls, and
+there would be other issues. Like if there is a stay, Your
+Honor, would he be posting a bond?
+THE COURT: We don't need to talk about those issues.
+That's not my concern.
+MR. JOSEFSBERG: I agree, Your Honor, we don't.
+
+
+Document 180 Entered on FLSD Docket 06/24/2009 Page 26 of 51 26
+1
+THE COURT: That's not my concern. So, again, I just
+2
+want to make sure that if the cases go forward and if
+Mr. Epstein defends the case as someone ordinarily would defend
+a case that's being prosecuted against him or her, that that in
+and of itself is not going to cause him to be subject to
+criminal prosecution.
+MR. JOSEFSBERG: I agree, Your Honor.
+THE COURT: Any other plaintiff's counsel want to
+4
+5
+6
+7
+8
+9
+chime in?
+10
+MR. WILLITS: Richard Willits on behalf of C.M.A..
+I
+11
+would join, to weigh in on what Mr. Josefsberg said.
+12
+MR. JOSEFSBERG: Your Honor, I could not hear.
+13
+THE COURT: We'll get him to a microphone.
+14 Mr. Willits is speaking.
+15
+MR. WILLITS: On behalf of my client, C.M.A., we join
+16
+in what Mr. Josefsberg said, and we also want to point out
+17
+something to the court.
+18
+First, we want to make a representation to the Court,
+19
+we have no intention of complaining to the U.S. Attorney's
+20
+Office, never had that intention, don't have that intention in
+21
+the future, but, of course, subject to what occurs in the
+22
+future.
+23
+I want to point out to the Court that Mr. Epstein went
+24
+into this situation with his eyes wide open, represented by
+25
+counsel, knowing that civil suits had to be coming. If he
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009
+Page 27 of 51 27
+1
+didn't know it, his lawyers knew it.
+2
+He appears to be having second thoughts now about he
+3
+could have negotiated this way or he could have negotiated that
+4
+5
+way with the U.S. Attorney's Office. And they want to impose
+their second thoughts on the innocent plaintiffs. We don't
+6
+think that's fair. We think it's in the nature of invited
+7
+error, if there was any error whatsoever.
+8
+Thank you.
+9
+THE COURT: You agree he should be able to take the
+10
+ordinary steps that a defendant in a civil action can take and
+11
+not be concerned about having to be prosecuted?
+12
+MR. WILLITS: Of course. And we say the same thing
+13
+Mr. Josefsberg said. It's all subject to your rulings and the
+14
+direction of this Court as to what is proper and what is not
+15
+proper. And we're prepared to abide by the rulings of this
+16
+Court, and we have no intention of running to the State's
+17
+Attorney.
+18
+THE COURT: The U.S. Attorney?
+19
+MR. WILLITS: I'm sorry. The U.S. Attorney.
+20
+21
+THE COURT: Mr. Garcia.
+MR. GARCIA: Thank you, Your Honor.
+22
+If I may briefly, I think perhaps defense counsel
+23
+forgot about this, but on pages 17 and 19 of my memorandum of
+24
+law in opposition to the motion to dismiss, I did make
+reference to the non-prosecution agreement, and I did say that
+
+
+Case 9:08-Cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009
+Page 28 of 51 28
+1
+the contesting of the jurisdiction of this Court was a
+potential breach of the non-prosecution agreement.
+3
+So my client happens to have, and they have filed with
+4
+the Court a copy of her state court complaint, given the fact
+5
+that the non-prosecution agreement limits the non-contesting of
+6
+jurisdiction to claims exclusively brought under the federal
+7
+statute.
+8
+9
+I'm going to go ahead and withdraw those contentions
+on pages 17 and 19 of my memo of law because it doesn't apply
+10
+to my case. So to the extent that I raised this issue with
+11
+defense counsel and the Court, I'm going to withdraw that
+12 aspect of it.
+13
+THE COURT: Can you file something in writing on that
+14 point with the Court?
+15
+MR. GARCIA: Yes.
+16
+THE COURT: What do you say about this issue that
+17
+we're here on today?
+18
+MR. GARCIA: I think that the problem that I have with
+19
+it is that this non-prosecution agreement is being used by
+20
+defense counsel for the exact opposite purpose that it was
+21
+intended. My perception of this thing, and I wasn't around, is
+22
+that Mr. Epstein essentially bought his way out of a criminal
+23
+24
+prosecution, which is wonderful for the victims in a way, and
+wonderful for him, too.
+25
+Now he's trying to use the non-prosecution agreement
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 29 of 51 29
+1
+as a shield against the plaintiffs that he was supposed to make
+2 restitution for.
+3
+And, certainly, he can take my client's depo. He's
+4
+done extensive discovery in the state court case -- very
+5
+intrusive, I might add. And we don't care, because we can win
+this case with the prosecution agreement or without the
+7
+prosecution agreement.
+We are ready to go forward.
+8
+THE COURT: You're not going to assert to the United
+9
+States Government that what he's doing in defending the case is
+10 a violation for which he should be further prosecuted?
+11
+MR. GARCIA: Absolutely not.
+12
+THE COURT: Anyone else for the plaintiffs?
+13
+MR. HOROWITZ: Judge, Adam Horowitz, counsel for
+14 plaintiffs Jane Doe 2 through 7.
+15
+I just wanted to address a point that I think you've
+16
+articulated it. I just want to make sure it's crystal clear,
+17 which is that we can't paint a broad brush for all of the
+18
+cases.
+19
+The provision relating to Mr. Epstein being unable to
+20
+contest liability pertains only to those plaintiffs who have
+21
+chosen as their sole remedy the federal statute. My clients,
+22
+Jane Doe 2 through 7, have elected to bring additional causes
+23
+of action, and it's for that reason we were silent when you
+24
+said does anyone here find Mr. Epstein to be in breach of the
+25
+non-prosecution agreement. That provision, as we understand
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 30 of 51 30
+1
+it, it doesn't relate to our clients.
+2
+THE COURT: Okay. But, again, you're in agreement
+3 with everyone else so far that's spoken on behalf of a
+4
+plaintiff that defending the case in the normal course of
+5
+conducting discovery and filing motions would not be a breach?
+6
+MR. HOROWITZ: Subject to your rulings, of course,
+7
+yes.
+8
+THE COURT: Thank you.
+9
+Anyone else have anything to say from the plaintiffs?
+10
+MS.
+• If you would be so kind
+as to maybe
+11
+help us out. I appreciate the fact that you're here, and I
+12
+know you're not a party to these cases and under no obligation
+13
+to respond to my inquiries. But as I indicated, it would be
+14 helpful for me to understand the Government's position.
+15
+MS.
+: Thank you, your Honor. And we, of
+16
+course, are always happy to try to help the Court as much as
+17
+possible. But we are not a party to any of these lawsuits, and
+18 in some ways we are at a disadvantage because we don't have
+19
+access. My access is limited to what's on Pacer. So I don't
+20
+really know what positions Mr. Epstein may have taken either in
+21
+correspondence or in discovery responses that aren't filed in
+22
+the case file.
+23
+But your first order was really just what do you think
+24
+about a stay, and then the second order related to this hearing
+25
+and asked a much more specific question, which is whether we
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 31 of 51
+31
+believe that Mr. Epstein's
+defense was a breach of the
+2
+agreement.
+3
+And I've tried to review as many of the pleadings as
+4
+possible. As you know, they're extremely voluminous. And I
+5
+haven't been through all of them. But we do believe that there
+6
+has been a breach in the filing that Mr. Josefsberg referred
+7
+to, and contrary to Mr. Critton, we do understand that we have
+8
+an obligation to provide notice, and we are providing notice to
+9
+Mr. Epstein today.
+10
+The pleading that we found to be in breach -- the
+11| non-prosecution agreement, sought to do one thing, which was to
+12
+place the victims in the same position they would have been if
+13
+Mr. Epstein had been convicted of the federal offenses for
+14
+which he was investigated.
+15
+And that if he had been federally prosecuted and
+16
+convicted, the victims would have been entitled to restitution,
+17
+regardless of how long ago the crimes were committed,
+18
+regardless of how old they were at the time, and how old they
+19
+are today, or at the time of the conviction.
+20
+And it also would have made them eligible for damages
+21
+under 2255.
+22
+And so our idea was, our hope was that we could set up
+23
+a system that would allow these victims to get that restitution
+24
+without having to go through what civil litigation will expose
+25 them to.
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 32 of 51 32
+1
+You have a number of girls who were very hesitant
+2
+about even speaking to authorities about this because of the
+3
+trauma that they have suffered and about the embarrassment that
+4
+they were afraid would be brought upon themselves and upon
+5
+their families.
+So we did through the non-prosecution agreement tried
+to protect their rights while also protecting their privacy.
+8
+So, pursuant to the non-prosecution agreement -- on the other
+9
+hand, we weren't trying to hand them a jackpot or a key to a
+10
+bank. It was solely to sort of put them in that same position.
+11
+So we developed this language that said if -- that
+12
+provided for an attorney to represent them. Most of the
+13
+victims, as you know from the pleadings, come from not wealthy
+14
+circumstances, may not have known any attorneys who would be in
+15
+a position to help them.
+16
+So we went through the Special Master procedure that
+17
+resulted in the appointment of Mr. Josefsberg, and the goal was
+18
+that they would be able to try to negotiate with Mr. Epstein
+19
+for a fair amount of restitution/damages. And if Mr. Epstein
+20
+took the position, which apparently he has, which is that the
+21
+$50,000 or $150,000 floor under 2255 also would be a cap. That
+22
+if they were to proceed to file suit in Federal Court to get
+23
+fair damages under 2255, Mr. Epstein would admit liability, but
+24
+he, of course, could fight the damages portion, which means
+25
+that, of course, he would be entitled to depositions; of
+
+
+Document 180 Entered on FLSD Docket 06/24/2009 Page 33 of 51 33
+1
+course, he would be entitled to take discovery, and we don't
+2
+believe that any of that violates the non-prosecution
+agreement.
+4
+The issue with the pleading that he filed, the motion
+5
+to dismiss the case, I believe it's Jane Doe 101, represented
+6
+by Mr. Josefsberg, is that that is a case that was filed
+exclusively under 18 U.S.C., Section 2255. She met that
+8
+requirement. Mr. Epstein is moving to dismiss it, not on the
+9
+basis of damages, he is saying that he cannot be held liable
+10
+under 2255 because he was not convicted of an offense.
+11
+The reason why he was not convicted of an offense is
+12
+because he entered into the non-prosecution agreement. So that
+13
+we do believe is a breach.
+14
+The issue really that was raised in the motion to stay
+15
+and that I addressed in our response to the motion to stay is
+16
+that Mr. Epstein's -- Mr. Epstein wants to stay the litigation
+17
+in order to leave, in order to sort of attack the cases of the
+18
+victims whether they are fully within the non-prosecution or
+19
+not, non-prosecution agreement or not, and leave the Government
+20
+without a remedy if he does, in fact, breach those terms. And
+21
+that is why we opposed the stay.
+22
+THE COURT: I'm not sure what you mean by that last
+23
+statement.
+24
+MS.
+Well, because this issue related to
+25
+the motion to dismiss on Mr. Josefsberg's client came up after
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 34 of 51
+34
+1
+2
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+we had filed that response. And what we said in the response
+to the motion to stay is that the reason why he wants to stay
+the litigation is so that the non-prosecution agreement
+terminates based on a period of time, as he puts it. And then
+afterwards he would be able to come in here and make all of
+these arguments that clearly violate the non-prosecution
+agreement but we would be without remedy.
+THE COURT: But you're not taking the position that
+other than possibly doing something in litigation which is a
+violation of an express provision of the non-prosecution
+agreement, any other discovery, motion practice, investigations
+that someone would ordinarily do in the course of defending a
+civil case would constitute a violation of the agreement?
+MS.
+: No, Your Honor. I mean, civil
+litigation is civil litigation, and being able to take
+discovery is part of what civil litigation is about. And while
+there may be, for example, if someone were to try to subpoena
+the Government, we would obviously resist under statutory
+reasons, all that sort of stuff. But, no, Mr. Epstein is
+entitled to take the deposition of a plaintiff and to subpoena
+21
+records, etc.
+22
+THE COURT: And even if he seeks discovery from a
+23
+Government agency, you have the right to resist it under the
+24
+rules of procedure but that would not constitute a violation,
+25
+again unless there's a provision in the prosecution agreement
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 35 of 51 35
+that says I can't do this?
+2
+MS.
+Correct.
+3
+THE COURT:
+That's your position?
+4
+MS.
+Yes.
+5
+THE COURT:
+Thank you.
+6
+MS.
+Thank you, Your Honor.
+7
+THE COURT: Mr. Critton, did you want to add anything?
+8
+MR. CRITTON: Yes, sir. Just a few responses to some
+9
+of the issues that have been raised.
+10
+The most glaring, at least from our perspective, is
+11
+both Mr. Josefsberg's comments that he believes that there's a
+12
+violation of the NPA as
+well as Ms.
+with regard to
+13
+Jane Doe 101.
+14
+Mr. Josefsberg, while he was the attorney rep who was
+15
+selected by Judge Davis to represent a number of individuals,
+16
+alleged victims that may have been on the list, he represents
+17
+many of them. And the type of response that was filed in 101
+18
+would probably be very similar to what we will file if he
+19
+files -- and he filed 102 as well. But if he files 103, 104
+20
+and 105, or whatever number he files, we may well take that
+21
+same legal position in our motions and in our response or in
+22
+reply.
+23
+And what we've been, in essence, told today is we
+24
+consider that to be a violation of the NPA under the
+25
+circumstances.
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 36 of 51 36
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+102 is a perfect example that he filed is, we have
+e-mails going back and forth between the Government and my
+clients' attorneys at the time that suggested that 102 probably
+doesn't even fit within the statute of limitations.
+So under Mr. Josefsberg's argument is as well, we've
+only brought a 2255 claim. We don't care whether she's within
+or is outside the statute of limitations. Because she was on
+the list and under the circumstances, he has to admit
+liability, which we contest is under that set of circumstances
+you're stuck with it. You can fight damages if you can, but
+she's a real person and you can't raise statute of limitations.
+The other point that kind of strikes out is there's
+probably a difference. And I'm happy to provide a copy of the
+NPA or a redacted portion of the NPA which deals with the civil
+issues, which are paragraphs 7, 8, 9 and 10, and the entire
+addenda in camera for the Court to look at, if plaintiff's
+counsel and the Government, I guess, really, because they're
+not a party, is if they have no objection because they all have
+access based on a prior court order to the non-prosecution
+20
+agreement.
+21
+So I'm happy to provide that to the Court today and
+22
+show it to counsel so that the Court can review that.
+23
+But our position with regard to the 2255 claims is
+24
+that -- there were two types of claims that could be filed, one
+25
+was consensual litigation, the second was contested litigation.
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 37 of 51 37
+1
+And under the consensual, in essence, which Mr. Epstein did, is
+2
+he'g
+offered $50,000 of the statutory minimum for that time
+period to all of those individuals.
+4
+THE COURT: Can I interrupt you a second?
+5
+MR. CRITTON: Yes, sir.
+THE COURT: I'm not here, and I don't believe it's my
+7
+role to decide whether or not there is or is not a breach of
+8
+the agreement. I'm just trying to understand what the
+9
+Government's position is regarding your defending these cases.
+10
+Now, I'm just saying this as an example. If, for
+11
+example, in the non-prosecution agreement there was a provision
+12
+that said explicitly: Jeffrey Epstein shall not move to
+13
+dismiss any claim brought under 2255 by any victim no matter
+14
+how long ago the allegations or the acts took place, period.
+15
+If that was in the agreement and you filed a motion to
+16
+dismiss by someone who brought a claim, it might sound like it
+17
+might be a violation.
+18
+MR. CRITTON: I agree.
+19
+THE COURT: So you would know that when you filed your
+20
+motion because it was right there for you to read.
+21
+And so to stay the case because I want to do something
+22
+that the contract expressly prohibits me from doing, so stay
+23
+the case until the agreement expires so then I can do something
+24
+that the agreement said I couldn't do so you won't be in fear
+25
+of prosecuting, I'm not sure that that is what I'm concerned
+
+
+Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 38 of 51 38
+about.
+1
+2
+I'm concerned about discovery, investigation, motion
+3
+practice, that's not prohibited by a provision of the
+4
+agreement. If there's something that's prohibited by the
+5
+agreement that you, knowing what the agreement says, go ahead
+6
+and do, anyway, I guess that's a risk you're going to have to
+7
+take. If there's a legitimate dispute about it, I guess some
+8
+arbiter is going to decide whether it's a breach or not.
+9
+But, again, that's something you and Mr. Burman,
+10 Mr. Goldberger, and you are all very good lawyers, and he's got
+11
+a whole list of lawyers representing him, and you've got the
+12
+agreement and you're going to make legal decisions on how to
+13
+proceed, and you're going to have to go and make your own
+14
+decisions.
+15
+I'm concerned about things that aren't in the
+16|
+agreement, that aren't covered, that you're going to be accused
+17
+of violating because, again, you take depositions, you send out
+18 subpoenas, you file motions that are not prohibited by the
+19
+agreement. And that's what I'm concerned about.
+20
+MR. CRITTON: And I understand that, Your Honor.
+21
+But at the same time, it's as if the lawyers and the
+22
+clients, based upon our interpretation of the agreement, and,
+23
+believe me, we would not have filed 101, the motion to dismiss,
+24
+but for believing that there was a good faith basis to do that
+25
+under the circumstances.
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 39 of 51 39
+1
+And now, in essence, we're being accused not only by
+2
+-- not accused, but it's been suggested that there's a breach
+of the NPA, not only by Mr. Josefsberg on behalf of 101, but as
+4
+well Ms.
+on behalf of the United States.
+5
+That's the perfect example. They're basically saying
+we think you violated. We may send you notice under the
+7
+circumstances. So does that mean that on 101 we have to back
+8
+off of it because we think in good faith that it's a motion and
+9
+is that something that this Court ultimately will rule?
+10
+THE COURT: I don't know that I'm the one who is going
+11
+to make that decision. Again, that's not the kind of thing
+12
+that I was concerned about. I was more concerned about the
+13
+normal, ordinary course of conducting and defending a case that
+14
+would not otherwise expressly be covered under the agreement,
+15
+that you're going to then have someone say, ah, he's sent a
+16
+notice of deposition, he's harassing the plaintiffs. I don't
+17
+know if there's a no contact provision in the agreement or no
+18
+harassment type of provision in the agreement. Ah, this is a
+19
+breach because you sent discovery, or he's issuing subpoenas to
+20
+third parties trying to find out about these victims'
+21
+backgrounds, he's breaching the agreement.
+22
+Those are the kind of things that I was worried about.
+23
+MR. CRITTON: The concern that we have is as part of
+24 doing this general civil litigation, it's not just the
+25
+discovery process. And I understand the issues that the Court
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 40 of 51 40
+1
+has raised.
+2
+But part of it is that often cases are disposed of
+3
+either on a summary basis or certainly legal issues that come
+4 before the Court during the course of the case, just like in a
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+criminal case. That's clearly part of the, I'd say the defense
+of the case under the circumstances; and if, in fact, an
+individual can't legally bring a cause of action for certain
+reasons, such as has been suggested in 101, and may be
+suggested in 102 when that pleading is filed, that certainly is
+a position that puts my client at risk.
+As another example that I use with C.M.A., that they
+filed this 30-count complaint. Now, they have the state court
+claims as well. But they, in essence, have said they filed
+another pleading with the Court that says depending on what the
+Court rules, in essence, on whether we can file multiple claims
+or one cause of action with multiple violations, we may dump
+the state court claims and, therefore, we'll just ride along on
+that. That's a very different --
+Mr. Epstein would never have entered into, nor would
+his attorneys have allowed him to enter into that agreement
+under those circumstances where he had this unlimited
+liability. That clearly was never envisioned by any of the
+defendants -- by the defendant or any of his lawyers under the
+circumstances.
+And if that's claimed to be a violation, either by the
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 41 of 51
+41
+1
+attorneys; i.e., he's not recapitulating on liability under the
+2
+2255, and that's all we have now. That's our exclusive remedy.
+3
+And the Government says, yeah, that's right, that's
+a
+4
+violation of the NPA. It again chills us from moving forward,
+5
+filing the necessary motion papers and taking legal positions
+6
+that may put my client at risk for violating the NPA and then
+7
+creating the irreparable harm of, after having been in jail,
+8
+after having pled guilty to the state court counts, after
+9
+registering on release as
+a sex offender, he's complied and
+10
+done everything, taken extraordinary efforts to comply with the
+11
+NPA, puts him at substantial risk. And that's what our worry
+12
+is moving forward.
+13
+MR. JOSEFSBERG: Your Honor, may I be heard. May I
+14
+make three comments? It will take less than a minute.
+15
+THE COURT: Yes, sir.
+16
+MR. JOSEFSBERG: Mr. Critton refers to the alleged
+17
+victims. I want you to know that our position is that pursuant
+18
+to the NPA they're not alleged victims. They are actual, real
+19
+victims, admitted victims.
+20
+Secondly, he argues about the statute of limitations
+21
+on 102. I know that you don't want to hear about that, and I'm
+22 not going to comment about it. But please don't take our lack
+23
+of argument about this as being we agree with anything.
+24
+Last and most important, we totally agree with
+25
+Mr. Critton in his suggestion that he hand you a copy of the
+
+
+Case 9:08-Cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 42 of 51
+42
+1
+NPA. I think that many of the questions you asked will be
+2
+answered when you read the NPA, and I think it's very unfair of
+3
+everyone who is sitting in front of you who have the NPA to be
+4
+discussing with you whether it's being breached, whether there
+5
+should be a stay when you're not that familiar with it.
+6
+If we would give you a copy of it, I think it would be
+7 much more helpful in making your ruling.
+8
+THE COURT: Maybe Judge Colvat will resolve this issue
+9
+for me.
+10
+MR. JOSEFSBERG: Even if he doesn't, Your Honor, I
+11 believe we are allowed to show it to you.
+12
+THE COURT: I'll tell you what: I'll wait for Judge
+13
+Colvat to rule, and then if he rules that it should remain
+14
+sealed, then I'll consider whether or not I want to have it
+15
+submitted to me in camera.
+16
+Anything else, Mr. Josefsberg?
+17
+MR. JOSEFSBERG: No. I thank you on behalf of myself
+18
+and the other counsel on the phone for permitting us to appear
+19 by phone.
+20
+THE COURT: All right. Anyone else have anything they
+21
+want to add?
+22
+MR. EDWARDS: Brad Edwards on behalf of Jane Doe.
+23
+I only had one issue here, and when I read your motion
+24
+that you wanted to hear on the narrow issue of just defense in
+25
+the civil actions filed against him violates the
+
+
+Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 43 of 51 43
+1
+non-prosecution agreement,
+I was expecting that we were going
+2
+to hear something from the Government similar to the affidavit
+3
+that was filed by Mr. Epstein's attorneys wherein he indicates
+4
+as of the day of this affidavit attached to the motion to stay,
+5
+the U.S. Attorney's Office has taken the position that Epstein
+6
+has breached the non-prosecution agreement and it names
+specifically investigation by Epstein of this plaintiff and
+8
+other plaintiffs, Epstein's contesting damages in this action.
+9
+Epstein, or his legal representatives, making statements to the
+10฿
+press. And we didn't hear any of those things.
+11
+So that's what I was expecting that the U.S.
+12
+Attorney's Office was going
+to expound on and say, yes, we've
+13
+made some communications to Epstein. He's violating.
+14
+What we're hearing right now, today, just so that I'm
+15
+clear, and I think the Court is clear now, is that the
+16
+non-prosecution agreement is what it is. There have been no
+17 violations, but for maybe what MI. Josefsberg brought up.
+18
+But there are very few restrictions on Mr. Epstein.
+19
+He went into this eyes wide open. And whether or not I agree
+20
+with the agreement, how it came to be in the first place, is
+21
+neither here nor there.
+22
+But there have been no violations or breaches up to
+23
+this point. And his affidavit that was filed, I'm just
+24
+troubled by where it even came from. I mean, it's making
+25
+specific allegations that the U.S. Attorney's Office is
+
+
+'Case 9:08-CV-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 44 of 51 44
+1
+threatening a breach, and this is part of the motion to stay,
+2
+3
+which we're all battling here.
+So I just wanted to indicate to the Court or remind
+4
+5
+the Court that there have been specific allegations made, the
+United States Attorney's Office is making these allegations of
+6
+breach, which we haven't heard any of the evidence of.
+7
+Thank you.
+8
+9
+THE COURT: All right.
+MS.
+, did you want to respond to that
+10
+suggestion that there were other allegations of breach besides
+11
+the one that you've just mentioned today?
+12
+MS.
+: No, Your Honor.
+13
+THE COURT: Thank you. I appreciate your giving me
+14
+the information, which I think has been very helpful today, and
+15
+I'll try and get an order out as soon as possible.
+16
+[Court adjourned at 11:10 a.m.].
+17
+CERTIFICATE
+18
+I hereby certify that the foregoing is an accurate
+19
+transcription of proceedings in the above-entitled matter.
+20
+s/Larry Herr
+21
+DATE
+22
+23
+LARRY HERR, RPR-CM-RMR-FCRSC
+Official United States Court Reporter
+400 N. Miami Avenue
+Miami, FL 33128 - 305/523-5290
+(Fax) 305/523-5639
+email: Lindsay165@aol.com
+24
+25
+Quality Assurance by Proximity Linguibase Technologies
+
+
+abide 27:15
+ability 18:8 19:1
+able 20:14 27:9
+32:18 34:5,15
+about 4:24 5:25 6:10
+6:18 9:2 11:15
+13:22 20:25 21:13
+23:13 25:23 27:2
+27:11,23 28:16
+30:24 32:2,2,3
+34:16 38:1,2,7,15
+38:19 39:12,12,20
+39:22 41:20,21,22
+41:23
+above 25:3
+above-entitled 44:19
+Absolutely 29:11
+* 368130:19,19
+according 19:21
+accurate 44:18
+accused 22:23 38:16
+39:1,2
+action 7:13 8:5 9:8
+10:3,4,9,21 11:18
+15:4 17:24 18:17
+20:2 21:22 27:10
+29:23 40:7,16 43:8
+actions 5:25 13:23
+14:3 16:11 19:5,17
+22:16 25:4 42:25
+activities 23:7
+acts 9:11,12 37:14
+actual 41:18
+actually 5:21 17:9
+Adam 1:13 3:4
+29:13
+add 29:5 35:7 42:21
+addenda 36:16
+Adderly 3:17
+additional 29:22
+address 29:15
+addressed 33:15
+adjourned 44:16
+Adler 1:17
+admit 20:3,1825:11
+32:23 36:8
+admits 23:20
+admitted 23:17 24:9
+41:19
+ado 23:13
+advantage 20:24
+adverse 18:18
+advice 12:7
+affidavit 43:2,4,23
+afraid 32:4
+after 33:25 41:7,8,8
+afterwards 34:5
+again 9:10,18,22
+10:19,20 18:5,9
+23:18 26:1 30:2
+34:25 38:9,17
+39:11 41:4
+Document 180
+against 4:23,25 6:24
+22:15 26:4 29:1
+42:25
+agency 34:23
+ago 31:17 37:14
+agree 13:13 17:23
+Entered on FLSD Docket 06/24/2009
+16:10 18:11 21:12
+30:9 35:7 41:23
+back 12:18 36:2 39:7
+42:16,20
+backgrounds 39:21
+anyway 38:6
+balance 12:15
+apparently 32:20
+bank 32:10
+appear 3:19 25:6
+based 6:12 10:7 12:6
+42:18
+13:11 17:4 34:4
+37:1841:23,24
+appearances 1:12
+36:19 38:22
+3:3,25
+basically 7:16 13:10
+agreed 17:9 20:2
+21:15 25:16
+agreement 5:2,2,11
+5:15 6:2,23 7:16
+7:19 8:5,6 12:9
+13:24 14:2,19
+15:20 16:20 18:18
+18:24 19:6,11,13
+19:18,24 20:1,10
+20:18 21:7,16,23
+22:8,11,17,19,20
+22:23 23:18,19,20
+24:1,9,23 27:25
+28:2,5,19,25 29:6
+appears 27:2
+39:5
+applicable 6:13 18:3
+basis 33:9 38:24
+apply 20:6 28:9
+40:3
+appointed 21:2
+battling 44:2
+appointment 25:15
+Beach 1:2,4,21 2:10
+32:17
+2:13
+appreciate 30:11
+before 1:11 6:5
+44:13
+15:13,18 24:10,11
+appropriate 19:21
+24:7
+behalf 3:14 4:2,6 6:7
+arbiter 38:8
+14:16 22:10 26:10
+argue 18:1 22:1
+26:15 30:3 39:3,4
+argued 12:22
+argues 41:20
+being 9:17 10:6,21
+argument 36:5
+23:19 26:4 28:19
+31:11 32:6,8 33:3
+29:19 34:15 39:1
+33:12,19 34:3,7,11
+arguments 34:6
+34:13,25 36:20
+37:8,11,15,23,24
+believe 3:18 5:10,10
+5:14,16 6:17,17,21
+38:4,5,5,12,16,19
+38:22 39:14,17,18
+articulated 29:16
+asked 5:4,4 8:2 14:5
+39:21 40:20 43:1,6
+21:11 31:1,5 33:2
+33:5,13 37:6 38:23
+ahead 28:8 38:5
+al 1:4
+allegation 5:1 15:19
+allegations 4:25 16:6
+37:14 43:25 44:4,5
+alleged 17:17,25
+35:16 41:16,18
+allow 11:8 31:23
+allowed 40:20 42:11
+along 40:17
+already 22:5
+always 30:16
+Amendment 6:24
+America 5:17
+amount 17:3,20
+23:25 24:3,9,16,24
+25:3 32:19
+another 9:5 14:14
+18:11 40:11,14
+answer 8:7 13:10
+answered 42:2
+anybody 11:14
+anyone 14:16,19
+17:5 22:13 24:17
+24:24 29:12,24
+30:9 42:20
+anything 8:22 11:15
+13:22 14:2,7,20,25
+asking 21:12 25:10
+aspects 9:1,2 16:5
+asserted 17:7
+believes 35:11
+believing 38:24
+beneficiaries 19:12
+beneficiary 20:1
+Assistant 2:15
+associate 10:17
+associated 18:12
+assurance 14:1
+assurances 12:5
+attached 43:4
+attack 33:17
+attention 15:1,22
+Atterbury 2:12
+attorney 2:15 7:1
+19:4 27:17,18,19
+32:12 35:14
+attorneys 5:9 10:10
+11:8 32:14 36:3
+40:20 41:1 43:3
+Attorney's 4:8,10
+26:19 27:4 43:5,12
+43:25 44:5
+August 12:18
+Australian 2:12
+authorities 32:2
+Avenue 1:21,23 2:12
+2:23 44:22
+aware 6:6 13:14 15:4
+a.m 44:16
+between 8:6 9:23
+13:1,21 19:14
+beyond 13:16
+Biscayne 1:14
+Bob 3:18 19:7
+Boebringer 1:20
+bond 25:22
+Boston 2:18
+both 10:10 16:25
+35:11
+bought 28:22
+Boulevard 1:14,17
+2:15
+Brad 3:7 42:22
+BRADLEY 1:16
+breach 6:1,23 15:11
+16:3 18:24 19:6,13
+23:16 25:9,9 28:2
+29:24 30:5 31:1,6
+31:10 33:13,20
+37:7 38:8 39:2,19
+44:1,6,10
+breached 7:19 12:24
+15:20 22:11 42:4
+Page 45 opage 45
+43:6
+breaches 7:15,17
+19:11 21:11 22:16
+43:22
+breaching 22:19,20
+22:23 39:21
+brief 15:18,23
+briefing 5:4
+briefly 27:22
+bring 29:22 40:7
+broad 29:17
+brought 15:1 20:2
+24:17,20 28:6 32:4
+36:6 37:13,16
+43:17
+Broward 2:15
+brush 29:17
+buffer 12:25
+Burman 2:8,9 4:3
+38:9
+business 13:25
+C
+C 2:1 44:17,17
+came 6:5 12:18 17:6
+18:22 33:25 43:20
+camera 36:16 42:15
+capped 23:25
+care 13:20,25 25:20
+case 1:3 5:17,20,21
+5:22 6:4,7 8:12
+11:15,18 13:18,20
+14:18,22 15:1,18
+16:2 19:17 22:17
+22:25 23:4,8,8
+24:17,20 26:3,4
+28:10 29:4,6,9
+30:4,22 33:5,6
+34:13 37:21,23
+39:13 40:4,5,6
+cases 3:2 6:9 7:3,11
+8:13,22 9:3,5,5,15
+10:3,11 12:1,2
+14:9 17:15,16
+21:10 24:8,11 26:2
+29:18 30:12 33:17
+catastrophie 7:21
+catch 7:21 10:2
+caught 15:22
+cause 17:24 18:17
+26:5 40:7,16
+caused 15:21
+causes 29:22
+cavalierly 12:13
+certain 8:22 11:18
+17:2,6 21:17 25:16
+40:7
+certainly 8:169:1
+
+
+29:3 40:3,9
+A 031825
+chose 6921
+circumstances 9:25
+10:1,11 12:11,20
+12:21 13:8,13 16:8
+16:17 17:3,8,13,18
+18:19 32:14 35:25
+36:8,9 38:25 39:7
+40:6,21,24
+civil 4:23,25 5:25 7:3
+7:3,11 8:5,22 9:4,7
+9:11 10:3,23,23
+13:23 14:3,9 15:7
+16:5,11 19:5 20:20
+31:24 34:13,14,15
+34:16 36:14 39:24
+claim 6:1 18:19
+23:21,23 25:8 36:6
+37:13,16
+claimed 40:25
+claiming 25:9
+claims 22:15 23:22
+23:22 24:1,4,6
+28:6 36:23,24
+40:13,15,17
+clear 10:7 18:18
+19:19 29:16 43:15
+clearly 9:24 11:20
+34:6 40:5,22
+client 10:21 13:5
+23:2 24:3 26:15
+28:3 33:25 40:10
+clients 11:9 21:24
+22:10,24 23:3
+25:16 29:21 30:1
+36:3 38:22
+client's 29:3
+cloud 9:14
+Colvat 42:8,13
+come 8:8,13 13:11
+21:1 23:6 32:13
+34:5 40:3
+comes 18:12
+coming 26:25
+comment 41:22
+comments 15:10
+35:11 41:14
+commitment 17:2
+Document 180
+committed 31:17
+communications
+43:13
+Entered on FLSD Docket 06/24/2009
+course 7:5 24:25
+Davis 21:2 35:15
+26:21 27:12 30:4,6
+day 43:4
+30:16 32:24,25
+deal 9:23 14:13,14
+33:1 34:12 39:13
+15:15 16:24,24
+Co26-lajning 25:11
+complaint 28:4
+ampliance 12:1
+mplied 41
+omply 41:10
+oncern 4:24 5:10,2
+9:20 16:122:8
+25:24 26:1 39:23
+concerned 13:22
+23:1027:11 37:25
+38:2,15,19 39:12
+39:12
+concerns 6:24
+conduct 22:14
+conducting 22:13
+30:5 39:13
+confident 19:10
+consensual 16:25
+consider 6:14 18:1
+constitute 13:18
+16:2 19:6 34:13,24
+contact 10:17 39:17
+contending 19:4
+contention 4:24
+contest 17:12 18:7,8
+24:18,21,23,25
+contested 9:13 16:18
+contesting 20:6 25:2
+context 13:18,19
+contract 7:16 37:22
+contracting 9:23
+contrary 25:6 31:7
+control 9:2
+convicted 20:14
+31:13,16 33:10,11
+conviction 20:8,15
+20:20 31:19
+copy 28:4 36:13
+41:25 42:6
+correct 5:12 23:1
+24:5 35:2
+correspondence
+30:21
+counsel 3:3,4,7 12:7
+16:5 23:13 26:8,25
+27:22 28:11,20
+29:13 36:17,22
+42:18
+count 24:14
+counts 17:17 41:8
+court 1:1 2:22 3:1,6
+3:9,12,15,20,22,24
+4:4,7,11,15,20
+5:11,14,18,19,21
+5:24 6:6,11,13,14
+6:18,20,21,22 7:6
+8:1 9:6 11:3,10,25
+12:19 13:1,10,16
+14:5,11 15:5,13,15
+16:10,13,22 19:2,9
+21:12,25 23:18
+25:23 26:1,8,13,17
+26:18,23 27:9,14
+27:16,18,20 28:1,4
+28:4,11,13,14,16
+29:4,8,12 30:2,8
+30:16 32:22 33:22
+34:8,22 35:3,5,7
+36:16,19,21,22
+37:4,6,19 39:9,10
+39:25 40:4,12,14
+40:15,17 41:8,15
+42:8,12,20 43:15
+44:3,4,8,13,16,22
+covered 38:16 39:14
+creative 17:23
+26:628:22 40:5
+Critton 2:8,9 4:2,2
+4:13 5:13 6:3,3
+14:4 15:3,14 16:4
+16:12,15 31:7 35:7
+35:8 37:5,18 38:20
+39:23 41:16,25
+crystal 29:16
+cure 8:14,17 9:21
+current 22:5
+cut 16:24
+C.M.A 1:24 3:14
+17:16 24:11 26:10
+26:15 40:11
+D
+D 1:13 2:8
+damages 17:3 23:23
+23:25 24:3,10,24
+25:2 31:20 32:23
+32:24 33:9 36:10
+43:8
+date 13:12,14 44:21
+Datura 1:21
+dealt 6:19 16:25,25
+decide 10:11 22:5
+decisions 38:12,14
+defend 5:25 10:11
+11:18 12:1,2 22:17
+22:18,22,25 24:2
+defendant 1:8 2:8
+6:23 11:13 16:16
+22:15,18 27:10
+defendants 25:5
+defending 4:25 7:24
+9:4 10:2,23 13:18
+13:20,23 14:3,9,18
+15:18 16:2,10
+25:18 29:930:4
+34:12 37:9 39:13
+defense 4:1,14 8:4,12
+9:3,12,14 10:9
+12:3 19:5,17 24:6
+24:18 27:22 28:11
+28:20 31:1 40:5
+depending 18:2
+deposition 11:11,12
+14:23 22:24 34:20
+depositions 10:13
+14:22 19:20 22:12
+22:20 23:15 32:25
+38:17
+desired 20:12
+determine 9:8
+developed 32:11
+difference 36:13
+different 6:5 12:21
+16:19 23:7 40:18
+direction 10:20
+27:14
+disadvantage 30:18
+disagree 20:5,21
+discovery 7:2,10,11
+10:16,25 22:12
+29:430:5,21 33:1
+34:11,16,22 38:2
+Page 46 opage 46
+39:19,25
+discretionary 6:19
+6:21
+discuss 9:22 23:6
+discussing 42:4
+discussion 16:22
+disingenuous 19:15
+dismiss 7:22 8:18
+10:14 20:4 27:24
+33:5,8,25 37:13,16
+38:23
+disposed 40:2
+dispute 38:7
+distinct 7:9
+DISTRICT I:1,1,11
+DIVISION 1:2
+docket 6:17 8:25
+12:14
+documents 11:7
+Doe 1:4,15,18,22 2:3
+2:7 3:1,5,8,11 5:17
+6:8,9,16 11:12
+21:5 29:14,22 33:5
+35:13 42:22
+doing 8:9 29:9 34:9
+37:22 39:24
+done 12:3,4 13:17,19
+13:24 14:2,7,17,20
+14:25 15:6 17:14
+doubt 9:14
+dramatic 7:25
+dramatically 7:8
+dump 40:16
+during 40:4
+E
+E 44:17,17
+each 17:24 18:16
+East 1:17 2:15
+Edwards 1:16 3:7,7
+5:16,20,23 42:22
+42:22
+effect 9:7 17:5
+efforts 41:10
+either 9:3 10:5 30:20
+40:3,25
+elected 29:22
+eligible 31:20
+Elkins 1:20
+email 44:24
+embarrassment 32:3
+enforce 21:17 25:17
+enforcement 7:2
+enforcing 25:10
+enter 40:20
+entered 33:12 40:19
+entire 5:15 20:25
+36:15
+entitle 11:23
+entitled 24:2 31:16
+32:25 33:1 34:20
+
+
+Case 9:08-CV-80119-KAM Document 180
+entry 6:17 8:25
+extraordinary 9:13
+enumerated 18:8,9
+extremely 31:4
+envisioned 40:22
+Epstein 1:7 3:1 4:3,6
+eyes 26:24 43:19
+Ezell 2:5 3:16,17
+4:22 6:7 7:13,15
+e-mails 36:2
+7:19 8:6,20 9:15
+9:18,24 10:1,6,10
+12:5,15 13:17,21
+14:8 17:9 19:5,14
+19:16 20:11,13
+fact 7:1 8:11 11:19
+14:20 28:4 30:11
+21:8 23:13 24:21
+25:16 26:3,23
+28:22 29:19,24
+30:20 31:9,13
+factors 11:23
+fair 27:6 32:19,23
+faith 38:24 39:8
+32:18,19,23 33:8
+33:16 34:19 37:1
+37:12 40:19 43:5,7
+far 14:25 21:17
+43:9,13,18
+23:10 24:24 30:3
+Epstein's 4:24 5:9,24
+8:4 9:1 22:731:1
+33:16 43:3,8
+equities 12:16
+Entered on FLSD Docket 06/24/2009
+form 11:4
+7:18 8:1,2,7 9:21
+Fort 1:18 2:16
+10:8 11:19 12:6
+ESQ 1:13,16,20,23
+2:1,5,8,8,11,14,17
+fear 9:14 37:24
+federal 5:3 28:6
+29:21 31:13 32:22
+federally 2:22 31:15
+fees 21:8,10 25:10
+few 35:8 43:18
+essence 7:9,12 8:3
+10:2 12:3 35:23
+37:1 39:1 40:13,15
+essentially 28:22
+fight 32:24 36:10
+file 21:4 28:13 30:22
+32:22 35:18 38:18
+ete 2:9 34:21
+even 11:5,6,9 14:1
+15:17 16:1 17:22
+21:3,4 32:2 34:22
+36:4 42:10 43:24
+event 5:24
+ever 5:11,14
+everyone 30:3 42:3
+everything 15:7
+41:10
+evidence 25:1 44:6
+exact 21:18,22 28:20
+exactly 10:24
+example 14:20 16:21
+17:16 34:17 36:1
+37:10,11 39:5
+40:11
+except 8:20 11:25
+exclusive 41:2
+exclusively 28:6 33:7
+exists 13:15
+expecting 43:1,11
+expires 37:23
+explicitly 37:12
+expose 5:1,25 31:24
+exposure 22:7
+expound 43:12
+express 34:10
+expressly 37:22
+39:14
+extensive 29:4
+extent 28:10
+filed 5:11,16,21,23
+6:7,10 10:8 11:9
+15:18,23,24 20:20
+28:3 30:21 33:4,6
+34:1 35:17,19 36:1
+36:24 37:15,19
+38:23 40:9,12,13
+42:25 43:3,23
+files 35:19,19,20
+filing 30:5 31:6 41:5
+filings 7:8
+filter 11:7
+financial 23:12
+find 5:6 6:13 19:15
+19:25 23:11 29:24
+39:20
+firm's 6:6
+first 5:9 16:14 19:3
+26:18 30:23 43:20
+fit 36:4
+FL 1:15,18,21,24 2:3
+2:6,10,13,16,23
+44:23
+Flagler 2:2,6,9
+floor 32:21
+FLORIDA 1:1,4
+focused 15:15
+forced 19:17
+foregoing 44:18
+forgot 27:23
+forward 9:8 13:11
+17:6 19:1 21:1
+22:17 23:6 26:2
+frankly 5:6
+from 3:17 4:7 5:9 7:9
+14:13 15:9 16:23
+17:10 19:2 30:9
+32:13,13 34:22
+35:10 37:22 41:4
+front 9:5 12:19
+fully 33:18
+further 29:10
+future 9:12 10:5
+12:5 26:21,22
+G
+3:10 27:20,21
+28:15,18 29:11
+gather 22:21
+general 39:24
+generally 10:22
+getting 24:11 25:19
+girls 20:7 23:5 25:20
+give 12:5 14:1 42:6
+giving 44:13
+glaring 18:21 35:10
+go 12:10 15:13 22:17
+24:24 26:2 28:8
+29:7 31:24 38:5,13
+going 3:18 5:25 12:4
+14:11,13 15:18
+16:2 19:5 22:4,6,9
+22:18,23 23:10,14
+29:8 36:2 38:6,8
+38:12,13,16 39:10
+39:15 41:22 43:1
+Goldberger 2:11,12
+4:5,6 38:10
+gone 15:7
+good 3:6,9,10,12,13
+3:15,16,22,23 4:4
+4:5,9,11,16,18,20
+17:16 38:10,24
+39:8
+Government 7:7,9
+14:1,5 15:23 16:19
+17:11 18:4,12,17
+20:11,11 21:13,14
+23:10,11 25:11
+29:9 33:19 34:18
+34:23 36:2,17 41:3
+7:25 9:10 12:20,23
+15:16 18:22 25:13
+granted 22:2
+great 7:23 8:20 9:19
+10:22 12:17 15:15
+ground 22:3
+guess 36:17 38:6,7
+guilty 17:11 41:8
+H 1:23
+hand 32:9.9 41:25
+hanging 11:19
+happen 14:13 22:6
+happens 28:3
+happy 30:16 36:13
+36:21
+harassing 39:16
+harassment 39:18
+harm 10:1 41:7
+having 27:2,11
+31:24 41:7,8
+hear 5:9 26:12 41:21
+42:24 43:2,10
+heard 19:2 41:13
+30:24 43:14
+help 30:11,16 32:15
+helpful 5:7 25:12
+30:14 42:7 44:14
+her 26:4 28:4
+hesitant 32:1
+him 4:23 7:20,20,22
+8:13,16,17 9:15,20
+11:23 12:5 21:14
+26:4,5,13 28:24
+38:11 40:20 41:11
+42:25
+himself 5:1,3
+Honor 3:10,13,16,21
+4:2,5,9,13,17,19
+5:13,16 6:4 12:12
+19:1,7 23:1 24:5
+25:22,25 26:7,12
+27:21 30:15 34:14
+Page 47 opage 47
+35:6 38:20 41:13
+42:10 44:12
+HONORABLE 1:11
+hope 31:22
+hopefully 13:3
+Horowitz 1:13,14
+3:4,4 29:13,13
+30:6
+horrible 21:23
+humiliated 20:25
+hypocritical 19:25
+idea 17:1 31:22
+I1 1:22 3:11
+impact 16:18
+important 41:24
+impose 27:4
+incident 24:14
+incidents 17:25
+indicate 44:3
+indicated 30:13
+indicates 43:3
+indict 7:20,20,22
+8:13,16,17 12:10
+indicted 9:17 10:6
+indictment 8:19 10:7
+individual 18:16
+40:7
+individuals 10:18
+17:1 35:15 37:3
+information 22:21
+44:14
+initial 12:19 15:21
+initially 15:24
+injury 10:23 23:22
+innocent 27:5
+inquiries 30:13
+inquiry 7:15 15:16
+instance 7:18,24
+9:18 10:10 11:3,17
+13:5 16:14
+instances 16:4
+intended 28:21
+intent 21:19
+intention 9:19 26:19
+26:20,20 27:16
+interest 23:12
+interested 13:17
+14:3
+interpretation 16:20
+38:22
+interrogatories
+14:24 19:20
+interrupt 37:4
+introduced 20:16
+intrusive 29:5
+invasive 19:22
+investigated 31:14
+
+
+•Case 9:08-cv-80119-KAM Document 180
+investigation 10:18
+38:2 43:7
+investigations 22:13
+34:11
+invited 27:6
+involvement 6:6
+irreparable 9:16
+10:1 41:7
+ISIDRO 1:20
+issue 4:23 6:5,11,19
+7:4 11:25 12:18,22
+14:14 15:25 16:2
+16:13,22 18:12,22
+21:18 28:10,16
+33:4,14,24 42:8,23
+42:24
+issued 14:25
+K
+Katherine 2:5 3:16
+keep 24:21
+KENNETH 1:11
+key 32:9
+kind 30:10 36:12
+39:11,22
+knew 27:1
+know 4:22 6:17 8:21
+11:14 12:2 13:9,17
+14:21 15:5,7 16:22
+19:23 22:6 23:12
+25:9 27:1 30:12,20
+31:4 32:13 37:19
+39:10,17 41:17,21
+knowing 26:25 38:5
+knowledge 5:13
+issues 4:21 24:10,13
+25:21,23 35:9
+36:15 39:25 40:3
+issuing 22:20 39:19
+i.e 41:1
+J
+J 1:16
+Jack 2:11 4:5
+Jane 1:4,15,18,22
+2:3,7 3:5,5,7,11
+11:12 21:4 29:14
+Jay 2:20 4:18
+Jeffrey 1:7 37:12
+jeopardize 9:15
+jeopardy 15:17
+join 26:11,15
+Josefsberg 2:1,2,5
+3:18,20,21,23 19:7
+19:7,10 21:25 23:1
+24:5 25:25 26:7,11
+26:12,16 27:13
+31:6 32:17 33:6
+35:14 39:3 41:13
+41:16 42:10,16,17
+Josefsberg's 33:25
+Judge 1:11 15:12
+21:229:13 35:15
+judgment 22:16
+June 1:5 13:12
+jurisdiction 28:1,6
+just 18:23 20:15,16
+22:3,6 24:20 26:1
+29:15,16 30:23
+35:8 37:8,10 39:24
+40:4,17 42:24
+43:14,23 44:3,11
+Entered on FLSD Docket 06/24/2009
+limitation 25:2
+limitations 36:4,7,11
+mean 18:10 33:22
+34:14 39:7 43:24
+known 21:4 32:14
+knows 11:3 13:2
+L
+lack 41:22
+ladies 20:23 21:3,20
+Lake 1:24
+language 18:14
+LARRY 2:21 44:21
+last 33:22 41:24
+Lauderdale 1:18
+law 7:1 27:24 28:9
+lawsuit 25:18,19
+lawsuits 30:17
+lawyers 8:21 9:4,7
+10:23,23 17:22
+27:1 38:10,11,21
+least 35:10
+leave 33:17,19
+Lefkowitz 2:20 4:18
+legal 10:13 24:10,13
+35:21 38:12 40:3
+legally 40:7
+legitimate 38:7
+letter 17:10 21:19
+17:12 20:19 23:25
+limits 28:5
+Lindsay165@aol.c...
+list 17:1,2,6 35:16
+litigation 7:4,5 9:13
+15:8 16:18,25
+31:24 33:16 34:3,9
+34:15,15,16 36:25
+long 31:17 37:14
+longer 20:7
+look 12:14 18:6
+M
+made 15:10,17 16:6
+20:12 31:20 43:13
+make 8:21 13:4
+15:21 19:19 23:8
+23:13 26:2,18
+27:24 29:1,16 34:5
+38:12,13 39:11
+making 42:7 43:9,24
+mandate 7:24 8:20
+many 20:23 31:3
+Marie 2:14 4:9
+MARRA 1:11
+Martin 2:17 4:16
+Master 21:2 32:16
+matter 20:15 37:13
+liability 17:12 18:7,7
+20:3,6,16,19 23:16
+23:17,20 24:8,18
+24:22,23 25:6,11
+like 7:16 13:9 25:21
+limit 23:23 24:2
+may 3:3 5:1 7:2,10
+9:9,12 10:4,17
+11:19 13:17,18
+14:18 15:12 16:18
+16:19 17:12 19:8
+19:16 20:4 21:11
+21:17,21 23:6
+27:22 30:20 32:14
+34:17 35:16,20
+39:6 40:8,16 41:6
+41:13,13
+maybe 12:17 13:10
+17:20 30:10 42:8
+members 4:13
+memo 7:14 28:9
+Mermelstein 1:14
+Miami 1:15 2:3,6,23
+2:23 44:22,23
+microphone 26:13
+might 14:2,12 22:14
+29:5 37:16,17
+minimum 17:3 25:3
+minimums 24:25
+minute 18:13 41:14
+more 8:3 17:23
+23:25 30:25 39:12
+morning 3:6,9,10,12
+3:13,15,16,22,23
+4:4,5,9,11,16,18
+4:20
+most 7:7 13:3 15:24
+18:21 32:12 35:10
+41:24
+motion 1:10 4:22 6:7
+12:22 15:24 20:4
+22:6 27:24 33:4,14
+33:15,25 34:2,11
+37:15,20 38:2,23
+39:8 41:5 42:23
+43:4 44:1
+motions 10:14 17:15
+21:5 30:5 35:21
+38:18
+move 7:22 8:18 19:1
+19:20 21:17,21
+37:12
+moving 9:733:8
+41:4,12
+much 23:13 30:16
+30:25 42:7
+multiple 18:15 40:15
+40:16
+multitude 8:12
+myself 16:5 42:17
+N
+N 44:22
+names 11:923:5
+43:6
+narrow 42:24
+nature 27:6
+necessary 22:22 41:5
+Page 48 opage 48
+need 24:22 25:23
+negotiate 32:18
+negotiated 27:3,3
+never 11:9 26:20
+newspapers 23:5
+nobody 11:14
+non-contesting 28:5
+non-position 9:10
+non-prosecution 5:2
+5:11 6:2 8:6 13:24
+22:8 24:1 27:25
+28:2,5,19,25 29:25
+31:11 32:6,8 33:2
+33:12,18,19 34:3,6
+34:10 36:19 37:11
+поп-2255 24:4,6
+normal 30:4 39:13
+North 1:23 2:9,23
+nothing 13:15 24:12
+notice 8:13,16 9:21
+13:6 14:23 22:24
+noticed 14:22
+notification 15:3,4
+NPA 8:5,11,15,24
+9:1,9,16,19,22
+10:4,19,22 11:20
+12:8,15,24 13:7,15
+14:10 16:8 18:14
+20:22 21:19,19
+23:924:12,15,16
+24:18,20 25:2,7
+35:12,24 36:14,14
+39:341:4,6,11,18
+42:1,2,3
+number 15:9 16:21
+17:7,9,14,21,24
+32:1 35:15,20
+numerous 23:21
+object 7:2,10,10
+objection 36:18
+objections 11:5,6
+obligation 21:9
+30:1231:8
+obtain 11:7
+obviously 10:20
+34:18
+occurred 17:25
+oecurs 26:21
+off 39:8
+offender 41:9
+offense 18:8,10,15
+33:10,11
+offenses 18:16 31:13
+offered 37:2
+
+
+'Case 9:08-cv-80119-KAM Document 180
+office 4:8,10 26:20
+15:6,10 41:5
+27:443:5,12,25
+paragraphs 36:15
+44:5
+paraphrasing 6:24
+Official 2:22 44:22
+Park 2:18
+officials 7:2
+part 10:18 18:9
+often 40:2
+20:23 21:7 23:9,20
+okay 3:25 5:19,21
+34:16 39:23 40:2,5
+18:10 30:2
+44:1
+Olas 1:17
+particular 6:15,18
+old 31:18,18
+7:24 8:22 9:18
+once 22:5
+11:17 13:5
+one 4:23 7:17 11:25
+parties 9:23 11:6
+17:24 18:5,16,20
+16:21 22:21 39:20
+18:21 20:1,822:24| partner 3:184:3
+31:11 36:24 39:10
+parts 19:25 21:17
+40:16 42:23 44:11
+party 11:11 14:25
+only 13:22 14:3
+30:12,17 36:18
+17:24 23:20 25:4
+past 9:11 10:5 12:3,4
+29:20 36:6 39:1,3
+pay 17:3 21:8,10
+42:23
+open 26:24 43:19
+pending 6:15 9:5
+opportunity 8:14,17
+17:15 21:6
+9:21
+people 23:6
+opposed 33:21
+per 24:14,14,14,14
+opposite 20:22 21:18
+perception 28:21
+21:22 28:20
+perfect 36:1 39:5
+opposition 27:24
+perhaps 20:24 27:22
+option 7:23
+period 9:21 34:4
+order 6:16 12:14
+37:3,14
+22:21 30:23,24
+permitted 24:6,18
+33:17,17 36:19
+permitting 42:18
+44:15
+person 36:11
+ordinarily 26:3
+personal 10:23
+34:12
+23:21
+ordinary 27:10
+perspective 16:23
+39:13
+35:10
+originally 6:5
+pertains 29:20
+Orseck 2:2,5 3:17
+phone 4:12,14,15
+other 7:1,17 16:4,5
+42:18,19
+17:22 22:13,18
+picking 12:13
+23:6,21,22 24:1
+place 31:12 37:14
+25:21 26:8 32:8
+43:20
+34:9,11 36:12
+plaintiff 3:7,14
+42:18 43:844:10
+24:15 30:4 34:20
+otherwise 39:14
+out 8:8 10:16 22:24
+26:16,23 28:22
+30:11 36:12 38:17
+39:20 44:15
+outside 13:18,19
+Entered on FLSD Docket 06/24/2009
+point 6:18 14:12
+26:16,23 28:14
+29:15 36:12 43:23
+pointed 14:20
+portion 32:24 36:14
+31:15
+prosecuting 37:25
+prosecution 26:6
+28:23 29:6,7 34:25
+prospect 16:15
+portions 5:15
+plaintiffs 1:5,13 3:4
+3:24 11:8 17:8,14
+17:22 19:3 22:14
+23:7,24 27:5 29:1
+29:12,14,20 30:9
+39:16 43:8
+plant's 19:4 26:8
+playing 7:8
+Plaza 2:18
+plead 17:11 18:10,11
+pleading 7:14 31:10
+33:4 40:9,14
+sadings 23:431:3
+please 41:22
+pled 17:8,16 20:14
+41:8
+Podhurst 2:2,5 3:17
+protecting 32:7
+provide 31:8 36:13
+position 5:5,8 6:4 7:7
+7:25 9:16,20 10:12
+10:13 11:21,22
+12:12,17,23 14:8,8
+14:15 15:16 16:16
+16:17 17:4,7 18:13
+18:17 19:19 20:13
+22:1,11 25:8 30:14
+31:12 32:10,15,20
+34:8 35:3,21 36:23
+37:9 40:10 41:17
+over 11:19 24:24
+own 12:21 38:13
+P
+Pacer 30:19
+pages 7:14 27:23
+28:9
+paint 29:17
+Palm 1:2,4,21 2:10
+2:13
+paper 10:16 13:7
+papers 8:10,169:25
+10:8 11:21 12:20
+positions 30:20 41:5
+possible 30:17 31:4
+44:15
+possibly 34:9
+posting 25:22
+potential 5:3 15:2
+28:2
+potentially 10:18
+15:19
+power 13:2
+practical 10:25 15:9
+practice 34:11 38:3
+predicate 20:8,15
+prepared 20:5 27:15
+present 5:5 11:15
+presents 9:7
+press 43:10
+pressure 21:15
+presume 23:24
+pretty 8:1
+prior 6:6 8:25 12:14
+36:19
+privacy 19:22 32:7
+probably 35:18 36:3
+36:13
+problem 14:12 22:22
+23:2,3 28:18
+procedure 32:16
+34:24
+proceed 12:10 18:23
+32:22 38:13
+proceeding 6:15,15
+proceedings 4:23,25
+44:19
+process 39:25
+production 14:24
+19:20
+prohibited 38:3,4,18
+prohibits 37:22
+proof 20:16
+proper 25:1 27:14
+27:15
+prosecuted 20:13
+26:4 27:11 29:10
+provided 16:9 32:12
+provides 9:22
+providing 31:8
+29:19,25 34:10,25
+37:11 38:3 39:17
+provisions 13:6,7
+psychologically
+publish 23:5
+purpose 21:19,23
+28:20
+pursuant 25:15 32:8
+41:17
+pursue 23:12
+pursuing 22:12,15
+put 9:15 18:21 32:10
+41:6
+puts 18:25 34:4
+40:10 41:11
+Q
+question 8:3,7 9:2
+12:1 30:25
+questions 42:1
+quite 19:10
+R
+R 44:17
+raise 16:2 36:11
+raised 15:25 16:13
+18:5,21 19:13
+28:10 33:1435:9
+40:1
+read 37:20 42:2,23
+reading 18:18 23:19
+ready 29:7
+real 9:6 10:8 36:11
+41:18
+really 12:2 18:11
+30:20,23 33:14
+36:17
+Realtime 2:22
+reason 6:147:3
+29:23 33:11 34:2
+reasons 18:5,20
+34:19 40:8
+recapitulating 41:1
+received 5:5 15:3,4
+20:4
+recent 7:7 15:24
+records 34:21
+redacted 36:14
+Page 49 opage 49
+reference 27:25
+referred 31:6
+refers 41:16
+refusal 9:10
+refuses 8:7
+refusing 25:5
+regard 9:11,12,13
+10:12,13,14,14
+11:4 12:19 14:9
+16:18 18:23 35:12
+36:23
+regarding 6:24
+23:15 37:9
+regardless 31:17,18
+registering 41:9
+relate 9:3 30:1
+related 30:24 33:24
+relates 8:12
+relating 29:19
+release 41:9
+relevant 19:22
+remain 42:13
+remedy 7:20 8:17
+29:21 33:20 34:7
+41:2
+remember 23:19
+remind 44:3
+remote 10:8
+тер 35:14
+replies 10:15
+reply 35:22
+REPORTED 2:21
+Reporter 2:22,22
+44:22
+represent 21:3 32:12
+35:15
+representation
+26:18
+representatives 4:7
+43:9
+represented 21:7
+26:24 33:5
+representing 38:11
+represents 18:16
+35:16
+requests 14:23
+required 17:3
+requirement 33:8
+resist 34:18,23
+resolve 42:8
+resolved 7:4 19:12
+24:16
+respect 22:14
+respectfully 7:6 14:4
+respond 20:5 30:13
+44:9
+response 5:6 7:14
+8:2 11:20 15:16,23
+18:22 33:1534:1,1
+35:17,21
+responses 10:14
+30:21 35:8
+restitution 29:2
+31:16,23
+
+
+Document 180
+restitution/damages
+seen 5:14,15
+32:19
+selected 35:15
+restrictions 43:18
+self-fulfilling 24:23
+result 10:21 15:19
+18:20
+self-incrimination
+6:25
+resulted 32:17
+send 10:16 38:17
+review 31:3 36:22
+39:6
+Richard 1:23 3:13
+sends 22:23
+26:10
+sent 14:22,23,24
+ride 40:17
+16:6 17:10 39:15
+right 3:24 6:24
+39:19
+12:25 13:3 25:8,14
+separate 5:20 17:17
+34:23 37:20 41:3
+42:20 43:1444:8
+set 12:21 13:13 18:4
+rights 13:5 25:16
+32:7
+settle 21:8
+risk 9:6 10:6,7 18:25
+settling 21:10 25:5
+38:640:10 41:6,11
+severely 21:21
+risks 21:5
+Robert 2:1,8 4:2 6:3
+sexual 23:6
+role 25:13 37:7
+shape 11:4
+Room 2:23
+Rosenfeldt 1:17
+show 36:22 42:11
+rose-colored 11:16
+Sid 3:10
+Rothstein 1:17
+RPR-CM-RMR-F...
+sideline 8:9
+44:21
+silent 29:23
+RPR-RMR-FCRR...
+similar 35:18 43:2
+2:21
+simply 11:17
+rule 39:9 42:13
+since 20:20
+rules 22:3 25:1 34:24
+sir 19:9 35:8 37:5
+40:15 42:13
+ruling 8:25 42:7
+rulings 19:21 23:8
+sitting 42:3
+25:227:13,15 30:6
+situation 12:6 20:25
+run 22:18
+25:12 26:24
+running 21:13 23:14
+sole 29:21
+27:16
+solely 12:15 32:10
+some 4:7 5:4 7:2,10
+7:11,129:1,8,9
+10:16 15:12 16:1,8
+17:22 20:25 21:3
+30:18 35:8 38:7
+Entered on FLSD Docket 06/24/2009
+Special 21:2 32:16
+suggest 8:10,23
+specific 8:2 11:1
+suggested 12:13,21
+16:24 17:13 30:25
+14:16 15:5,6 36:3
+43:25 44:4
+39:2 40:8,9
+specifically 43:7
+suggesting 16:7
+spector 11:18
+suggestion 15:17
+speculative 10:9
+41:25 44:10
+spirit 25:20
+suing 25:10
+spoken 30:3
+suit 20:21 21:4 32:22
+standard 11:1
+suits 26:25
+standpoint 10:25
+summary 40:3
+15:9
+supporting 15:16
+start 23:15
+supposed 20:18
+state 3:3 9:6 28:4
+22:25 23:17 24:9
+29:440:12,17 41:8
+29:1
+sure 5:7 14:11 26:2
+statement 33:23
+29:16 33:22 37:25
+statements 43:9
+Susan 3:17
+States 1:1,11 2:22
+system 31:23
+4:8 5:1,5,17 6:1
+s/Larry 44:20
+9:24 10:6 13:21
+14:8,17 16:7 19:14
+T
+22:10,19 29:9 39:4
+T 44:17,17
+take 7:12 9:12 10:3,3
+10:12,13,21 11:12
+statute 17:4 18:3
+11:18,21,22 14:7
+14:21 16:16,16
+29:21 36:4,7,11
+18:2 19:20 22:10
+27:9,10 29:3 33:1
+statutory 6:12 24:25
+25:3 34:18 37:2
+stay 4:23 6:8,19,21
+7:3 11:24 12:16,19
+34:15,20 35:20
+38:7,17 41:14,22
+taken 7:7 9:11,21
+14:9 15:5 30:20
+41:10 43:5
+21:22 22:2,4,4,5,7
+24:22 25:21 30:24
+33:14,15,16,21
+34:2,2 37:21,22
+42:5 43:4 44:1
+takes 18:17
+taking 9:8 14:23
+19:17 22:12,20
+23:15 25:20 34:8
+S
+same 6:10,16 8:3
+20:13 27:12 31:12
+32:10 35:21 38:21
+satisfied 20:9
+saying 7:10 8:1
+17:17 19:12,16
+20:6,7,8 21:14
+25:5 33:9 37:10
+39:5
+says 8:15 13:717:11
+18:13 35:1 38:5
+40:14 41:3
+scheduled 4:21
+seal 5:18,23
+sealed 42:14
+second 20:23 27:2,5
+30:24 36:25 37:4
+Secondly 41:20
+secret 17:1
+Section 33:7
+see 4:7 15:11 20:12
+seek 23:25
+seeking 6:7 24:3
+seeks 34:22
+talk 6:18 25:23
+telephone 2:4,19,20
+someone 10:17 19:22
+24:20 26:3 34:12
+34:17 37:16 39:15
+something 13:19,24
+14:17 15:24 20:19
+26:17 28:13 34:9
+37:21,23 38:4,9
+Sometimes 13:4
+somewhat 6:5
+sorry 15:14 27:19
+sort 32:10 33:17
+34:19
+sought 31:11
+sound 37:16
+South 2:12
+SOUTHERN 1:1
+speak 12:16 19:8
+speaking 26:14 32:2
+staying 21:18
+Street 2:2,6,9
+strictly 11:15
+stuck 18:14 36:10
+subject 5:3 26:5,21
+submit 7:6 14:4
+submitted 42:15
+subpoena 11:9 34:17
+tell 11:13,14 42:12
+telling 21:13 22:9
+temporary 1:
+terminates 34:4
+terms 9:3 22:7 33:20
+thank 19:1,2 27:8,21
+30:8,15 35:5,6
+42:17 44:7,13
+their 3:3,25 7:14,14
+8:10,16 9:25 11:8
+subpoenaes 11:5
+subpoenas 14:25
+22:21 38:18 39:19
+subsequently 6:9
+9:16
+substantial 9:6
+11:22,23 13:2
+18:25 41:11
+sue 7:17
+suffered 32:3
+14:21 15:6,10
+21:21 23:6 27:5
+29:21 32:5,7,7
+themselves 32:4
+thing 25:4 27:12
+28:21 31:11 39:11
+things 11:3 38:15
+think 6:8,14 8:15 9:4
+9:22 10:19 11:22
+Page 50 opage 50
+12:24,25 13:6,6
+17:16 18:18,23
+19:14 25:13 27:6,6
+27:22 28:18 29:15
+30:23 39:6,8 42:1
+42:2,6 43:15 44:14
+third 11:6,11 14:25
+22:21 39:20
+third-party 19:11
+21:16 25:14
+thoughts 27:2,5
+threatening 44:1
+three 41:14
+through 3:5 6:9 11:7
+11:16 29:14,22
+31:5,24 32:6,16
+till 14:2
+time 6:10,11,12,15
+6:19,20 13:3 17:5
+21:12 31:18,19
+34:4 36:3 37:2
+38:21
+times 17:19 18:2
+today 8:4 13:11 14:3
+14:6,6 15:5 28:17
+31:9,1935:23
+36:21 43:14 44:11
+44:14
+today's 13:12,14
+told 23:20 35:23
+tools 10:25
+tort 10:24 23:22
+24:4,6
+totally 20:5,21 23:1
+41:24
+TRANSCRIPT 1:10
+transcription 44:19
+traumatized 21:21
+tried 31:3 32:6
+troubled 43:24
+try 23:11 30:16
+trying 10:11 22:3
+28:25 32:9 37:8
+two 4:13 9:23 19:25
+type 12:15 22:13
+types 22:16 36:24
+typical 11:2,4 22:15
+ultimately 39:9
+unable 29:19
+uncertainty 9:14
+under 5:17,17,23
+7:20 8:18 9:25
+
+
+Document 180
+10:1,11,22 12:6,10
+44:9,12
+12:20 13:7,8 16:8
+violate 19:18 34:6
+16:17,23 17:2,4,8
+violated 5:2 14:2
+17:12,18 18:4,8,19
+39:6
+20:9,18,19,21 21:9
+violates 8:5,11 33:2
+22:724:8,11,18,20
+24:20 25:1,6 28:6
+violating 9:16,19
+30:12 31:21 32:21
+32:23 33:7,10
+violation 8:23 9:9
+34:18,23 35:24
+10:4,19 11:20 12:7
+36:5,8,9 37:1,13
+12:9 13:15,19,20
+38:25 39:6,14 40:6
+13:23 14:10,19
+40:21,23 41:1
+15:2 16:7 18:19
+understand 5:7
+24:19 25:19,20
+14:15 21:25 22:3
+29:10 34:10,13,24
+23:24 29:25 30:14
+35:12,24 37:17
+31:7 37:8 38:20
+40:25 41:4
+39:25
+violations 17:17,18
+understanding
+17:24 18:1,16
+20:10
+19:23 40:16 43:17
+unfair 42:2
+unilateral 12:22
+voluminous 31:4
+unilaterally 7:13
+12:24
+vS 1:6 3:1 5:17
+United 1:1,11 2:22
+W
+4:85:1,5,17 6:1
+₩ 2:5
+9:24 10:6 13:21
+wait 8:10 18:13
+14:8,17 16:7 19:14
+42:12
+22:10,19 29:8 39:4
+waive 25:14
+44:5,22
+waiving 18:7
+unless 11:7 34:25
+want 8:9,10 11:15
+unlimited 40:21
+12:2 16:22 17:20
+until 37:23
+21:4,4,5,14 22:1,6
+urge 22:9
+25:17 26:2,8,16,18
+use 10:25 11:8 20:24
+26:23 27:4 29:16
+23:11 28:25 40:11
+35:7 37:21 41:17
+used 28:19
+41:21 42:14,21
+U.S 2:15 4:10 7:1,9
+8:6 12:8,12 16:16
+wanted 11:11 14:21
+26:19 27:4,18,19
+17:5 20:12 29:15
+43:5,11,25
+42:24 44:3
+U.S.A 2:16
+wants 11:14 13:3
+U.S.C 33:7
+19:2,16,20 23:4
+24:24 33:16 34:2
+warranted 6:22
+various 3:1 10:25
+very 4:21 5:7 11:1,2
+11:20 12:21 16:19
+16:24 17:12,12
+23:11 29:4 32:1
+35:18 38:10 40:18
+42:2 43:18 44:14
+Via 2:4,19,20
+victim 37:13
+vietims 20:12 21:20
+28:23 31:12,16,23
+32:13 33:18 35:16
+39:20 41:17,18,19
+41:19
+wasn't 28:21
+way 8:23 9:9 10:5,16
+10:19 11:4 13:16
+14:10 19:23 25:1
+25:18 27:3,4 28:22
+ways 30:18
+wealthy 32:13
+weigh 26:11
+Weinberg 2:17 4:16
+4:16
+Weiss 2:12
+well 7:10 8:20 10:22
+11:12,12,13,13
+12:17 13:16 14:11
+15:7 16:18 17:15
+4:10 17:10 30:10
+30:15 33:24 34:14
+35:2,4,6,12 39:4
+17:23 18:10,11
+33:24 35:12,19,20
+36:5 39:4 40:13
+Entered on FLSD Docket 06/24/2009
+went 6:18,22 26:23
+32:16 43:19
+were 6:10 14:6 15:10
+18:7 19:11 21:2
+29:23 31:17,18
+32:1,4,22 34:17
+36:24 43:1 44:10
+weren't 32:9
+West 1:2,4,21 2:2,6
+2:10,13
+we'll 7:19,22 8:16
+17:23 26:13 40:17
+we're 9:8 10:2 12:10
+13:14 19:10,12
+20:5 27:15 28:17
+39:1 43:14 44:2
+we've 15:4 35:23
+36:5 43:12
+whatsoever 27:7
+while 32:734:16
+whole 20:12 38:11
+wide 26:24 43:19
+willful 8:23 12:7
+willfully 9:19
+Willits 1:23 3:13,14
+26:10,10,14,15
+withdraw 28:8,11
+wonderful 28:23,24
+word 24:21
+worried 39:22
+worry 41:11
+Worth 1:24
+writing 28:13
+written 5:6 21:9 23:4
+40:8
+102 6:8 35:19 36:1,3
+40:9 41:21
+103 21:5 35:19
+104 35:19
+105 35:20
+11:10 44:16
+12 1:59:4
+12th 13:12
+13 7:149:4
+147:14
+150 17:19,20 18:2
+24:12
+1727:23 28:9
+18 33:7
+18205 1:14
+19 27:23 28:9
+2
+23:5 5:17 6:9,16
+20 2:18 17:25 18:2
+2009 1:5 13:12
+22 7:21 10:2
+2255 16:23 17:4,17
+17:18 18:8,12,14
+20:2,9,19,21 23:21
+23:22,23 24:8,17
+24:21 25:6 31:21
+32:21,23 33:7,10
+36:6,23 37:13 41:2
+2290 1:23
+250 2:12
+26 20:4
+3.
+× 1:9
+30 17:16,19,19
+30-count 40:12
+305.358.2800 2:3,7
+yeah 41:3
+yesterday 21:9
+young 20:23 21:3,20
+305.931.22001:15
+305/523-5290 44:23
+305/523-5639 44:23
+33 6:17 9:1
+$15 17:20
+$150,000 32:21
+$50,000 17:5 32:21
+37:2
+33128 2:23 44:23
+331302:3,6
+33160 1:15
+33301 1:18
+33394 2:16
+33401 1:21 2:10,13
+021162:18
+33461 1:24
+08 12:18,18
+08-80119-CTV-M...
+1:3
+4
+4 1:18 11:12
+400 2:23 44:22
+4011:17
+15:17
+1
+1036:15
+10th 1:23
+5
+101 2:3,7 33:5 35:13
+| 51:186:9
+35:17 38:23 39:3,7
+5th 12:18
+Page 51 opage 51
+50 18:2 24:12
+500 2:15
+5152:9
+561.582.7600 1:24
+561.659.8300 2:13
+561.832.8033 1:22
+561.842.2820 2:10
+61:18
+6
+617.227.3700 2:19
+7
+71:18 3:5 29:14,22
+36:15
+8
+836:15
+8N09 2:23
+936:15
+954.356.7255 2:16
+954.522.3456 1:19
+
+
+Defense
+
+
+Entered on FLSD Docket 07/21/2008 | FEcT DIO D.C.
+July 18, 2008
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+08-80804-Civ-MARRA/JOHNSON
+CASE NO.:
+JANE DOE,
+a/k/a JANE DOE #1,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+and
+Defendants.
+NOTICE OF REMOVAL
+In accordance with 28 U.S.C. §§ 1441, 1446, and 1332(a)(1), the defendants,
+Jeffrey Epstein,
+and
+hereby remove this action' from
+Palm Beach County Circuit Court to the United States District Court for the
+Southern District of Florida, and respectfully state as follows:
+Introduction
+Six months ago, this plaintiff filed virtually the identical lawsuit in this
+Court. See Jane Doe #/ v. Epstein, Case No. 08-cv-80069-KAM (S.D. Fla. filed
+• Doe v. Epstein er al., Case No. 50 2008 CA 006596 XXXX MB (Fla. 15th Cir. Cl.
+filed Mar. 6, 2008).
+Lewis Tein..
+3059 GRAND AVIMUS, SUITE 340, COCONUT GROVE, FLORIDA 33133
+1 of 316
+
+
+Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 3 of 100
+redacted, is attached hereto (Exhibit A). Two days later, counsel for Jane Doe #1
+filed a notice of voluntary dismissal without prejudice in the First Federal Action.
+See Doe #1 v. Epstein, Case No. 08-CV-80069-KAM, DE 9.
+Two weeks later (March 6, 2008), having changed lawyers, Jane Doe #1
+refiled her complaint in Florida Circuit Court as the instant case, adding two
+nominal defendants:
+, Mr. Epstein's personal secretary, and
+,, one of Jane Doe #I's contemporaries. These defendants have nothing to
+do with the plaintiff's case against Mr. Epstein, except that the presence of
+as a defendant in this new case, because she is a citizen of Florida (Am.
+Compl. 4), would ostensibly prevent complete diversity.?
+As discussed below, however,
+was named in the refiled
+lawsuit only to destroy diversity jurisdiction, and to prevent any application of 18
+U.S.C. § 3509(k), a mandatory stay provision applicable in federal court ? Haley
+2 Defendant Kellen is a citizen of New York (Am. Compl. 915), and is therefore a
+nonresident defendant for purposes of diversity jurisdiction and removal.
+3 Section 3509(k) of Title 18, United States Code, provides as follows:
+criminal action and any mention of the civil action during the criminal
+roceeding is prohibited. As used in this subsection, a criminal action is
+pending until its final adjudication in the trial court.
+3
+Lewis,
+"Teinr.
+3059 GRAND AVENUE, SUITE 340, COCONUT GROVE, FLOMIDA 33133
+3 of 316
+
+
+Entered on FLSD Docket 07/21/2008 Page 5 of 100
+Doe" lawsuits presently pending against Epstein, filed by this plaintiff's former
+lawyer.
+This case is properly removed to federal court, first, because there is
+complete diversity among the real parties-in-interest, second, because the amount
+in controversy exceeds $75,000, and third, because this Notice complies with the
+requirements of 28 U.S.C. § 1446.
+Discussion
+A. This case is properly removable because it falls within the original
+jurisdiction of the United States District Court for the Southern
+District of Florida.
+A state-court case is properly removable when "it could have been brought,
+originally, in a federal district court." Lincoln Prop. Co. v. Roche, 546 U.S. 81, 83
+(2005) (citing 28 U.S.C. § 1441(a)). This case was originally filed in federal
+district court, and it is the same case today. Even though it was reconfigured to
+look like a state-court lawsuit, this action falls squarely within the bounds of the
+diversity-jurisdiction statute. See 28 U.S.C. § 1332(a)(1) (establishing that federal
+district courts have original jurisdiction over cases where the amount in
+controversy [is more than $75,000] ... and [when the controversy] is between
+citizens of different states").
+5
+Lewis Tein..
+5 of 316
+
+
+Entered on FLSD Docket 07/21/2008 Page 7 of 100
+To cement this point, the Eleventh Circuit Court of Appeals has said that
+"[w]hen [a] complaint does not claim a specific amount of damages, removal from
+state court is proper if it is facially apparent from the complaint that the amount in
+controversy exceeds the jurisdictional requirement." Williams v. Best Buy Co.,
+Inc., 269 F.3d 1316, 1319 (11th Cir. 2001). This case meets that standard, and
+satisfies the first prong of diversity jurisdiction.
+2. There is complete diversity among the real parties to this
+controversy.
+Diversity jurisdiction requires complete diversity. Carden v. Arkoma
+Assocs., 494 U.S. 185, 187 (1990) ("Since its enactment, we have interpreted the
+diversity statute to require 'complete diversity' of citizenship." (citing Strawbridge
+v. Curtiss, 7 U.S. (3 Cranch) 267, 267-68 (1806))). See also MacGinnitie v. Hobbs
+Group, LLC, 420 F.3d 1234, 1239 (11th Cir. 2005) (stating that "[c]omplete
+diversity requires that no defendant in a diversity action be a citizen of the same
+state as any plaintiff'). As demonstrated below, this case satisfies the statutory
+requirement of complete diversity.
+(a) Plaintiff Jane Doe is a citizen of Florida. (Am. Compl. 9 1.) 6
+• Jane Doe may, in fact, be a citizen of Georgia, not Florida, as she pled in her Amended
+Complaint. See New York Post, Jul. 1, 2008 (reporting that "On his way into court [for
+his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by
+Doe, who has since moved to another state."); Jane Doe Depo. at 77, 112 (indicating that
+7
+Tot 316
+
+
+Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 9 of 100
+Oct. 15, 2007) (Moreno, J.) (citing Riley v. Merrill Lynch, Pierce, Fenner & Smith,
+Inc., 292 F.3d 1334, 1337 (11th Cir. 2002)); accord, e.g., Tedder v. F.M.C. Corp.,
+590 F.2d 115, 117 (5th Cir. 1979) (denying motion to remand where two resident
+defendants were joined for the fraudulent purpose of defeating federal jurisdiction).
+In this case, the plaintiff relies on her original allegations to support three causes of
+action against
+civil conspiracy (Am. Compl. 19| 20-23); Intentional
+Infliction of Emotional Distress (Am. Compl. 99| 23-28); and civil RICO (Am.
+Compl. 19 29-34). These allegations, however, do not support these claims, or
+any other theory of liability that would allow recovery against
+CS.
+Parks v. The New York Times Co., 308 F.2d 474, 477 (5th Cir. 1962) (observing
+that "determination of fraudulent joinder is to be based on whether there was a real
+intention on colorable grounds to procure a joint judgment") (emphasis added).®
+(a) Nonresident defendants have a right of removal.
+The removal statute was enacted specifically "to protect defendants." Legg v.
+Wyeth, 428 F.3d 1317, 1325 (11th Cir. 2005). Cf., e.g., Picquet v. Amoco Prod.
+Co., 513 F. Supp. 938, 941 (M.D. La. 1981) (explaining that courts developed the
+fraudulent-joinder doctrine to protect "the right [of removal] granted to
+8 In Bonner v. City of Prichard, 661 F.2d 1206, 1207 (11th Cir. 1981) (en banc), the
+Tomer FiC Circui undered prials adopted i, binding precedent all decisions of the
+9
+9 of 316
+
+
+Entered on FLSD Docket 07/21/2008 (
+
+action arising from an alleged sexual assault of a minor "shall be stayed until the
+end of all phases of [any] criminal action") (emphasis added). In this case, there is
+a parallel federal criminal grand jury action pending in the Southern District of
+Florida, In re Grand Jury, No. FGJ 07-103(WPB) (S.D. Fla.), which arises out of
+the same allegations pled here. Thus, in resorting to fraudulent joinder, the
+plaintiff has sought to avoid any application of this otherwise controlling statute.
+Cf. Doe v. Francis, No. 5:03 CV 260 MCR/WCS, 2005 WL 517847, at *1-2 (N.D.
+Fla. Feb. 10, 2005) (staying civil diversity action over plaintiffs' objections on
+grounds that "the language of 18 U.S.C. § 3509(k) is clear that a stay is required in
+a case ... where a parallel criminal action is pending which arises from the same
+occurrence involving minor victims") (emphasis added).
+Even outside the context of a mandatory federal statute, "the Supreme Court
+[has] admonished [that] 'the Federal courts should not sanction devices intended to
+prevent a removal to a Federal court where one has that right, and should be
+equally vigilant to protect the right to proceed in the Federal court."" Legg, 428
+F.3d at 1325 (citing Wecker v. Nat'l Enameling & Stamping Co., 204 U.S. 176,
+186 (1907)). See also id. (observing that "Congress ' did not extend [to defendants
+a right of removal] with one hand, and with the other give plaintiffs a bag of tricks
+11
+3059 GRAND AVEMUE, SUITE 340, COCONUT GROVE, FLORIDA 33133
+11 of 316
+
+
+Entered on FLSD Docket 07/21/2008 Page 13 of 100
+complaint contains four claims for relief, the first and second claims state only one
+cause of action") (emphasis added). Using her original allegations and adding
+nothing, Jane Doe has tried to add claims against
+for civil
+conspiracy (Am. Compl. 11 20-23), Intentional Infliction of Emotional Distress •
+(Am. Compl. 991 24-28), and civil RICO (Compl. 19 29-34) in order to append a
+nondiverse defendant to her Complaint. These claims, however, are untenable
+under Jane Doe's own allegations, and therefore cannot be used to destroy
+diversity jurisdiction.
+(b) There is no possibility that the plaintiff can establish a cause of
+action against
+under Florida law.
+(i) The conspiracy claim against Robson must fail.
+As a general rule, "[a]n actionable conspiracy [under Florida law] requires
+an actionable underlying fort or wrong." Wright v. Yurko, 446 So. 2d 1162, 1165
+(Fla. Sth DCA 1984) (citations omitted) (emphasis added).
+This case is governed by the general rule. CI. Churruca v. Miami Jai-Alai, Inc., 353
+So. 2d 547, 550 (Fla. 1977) (noting that while there is "ordinarily... no independent tort
+for conspiracy," there is a narrow exception to this rule when "the plaintiff can show
+some peculiar power of coercion possessed by the conspirators by virtue of their
+combination"') (emphasis added). See generally Liappas v. Augoustis, 47 So. 2d 582, 583
+(Fla. 1950) (observing that * instances of conspiracy which is in itself an independent tort
+are rare and should be added to with caution'" (quoting Fleming v. Dane, 22 N.E.2d
+609, 611, (Mass. 1939))) (emphasis added). Plainly, this case involves the general rule,
+not the narrow exception, because only one person could have caused Jane Doe's
+injuries. CJ. Martin v. Marlin, 529 So. 2d 1174, 1179 (Fla. 3d DCA 1988) (upholding
+13
+13 of 316
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 15 of 100
+Buchanan v. Miami Herald Publ'g Co., 230 So. 2d 9, 12 (Fla. 1969) (holding that
+where Count I of the complaint had failed to state a cause of action for malicious
+prosecution, there could be no civil-conspiracy claim in Count Il "based on the
+allegations of Count I"'). Because the statute she expressly pleads as the basis for
+Count 1, Chapter 800, Florida Statutes, provides no civil remedy, Jane Doe cannot
+prevail on Count I. Therefore, she cannot prevail on her claim for conspiracy
+(Count II) to violate Chapter 800, Florida Statutes (Count I).
+(ii) The plaintiff cannot prevail against nondiverse defendant
+on her claim for Intentional Infliction
+of Emotional Distress (IIED).
+Even if the plaintiff, for the sake of argument, can assert an IIED claim
+against Jeffrey Epstein, the plaintiff still does not have a cause of action for IIED
+against
+First, the plaintiff cannot recover damages in connection
+with her own illegal conduct; and second, the plaintiff's purported IIED claim fails
+• as a matter of law.
+15
+
+
+Entered on FLSD Docket 07/21/2008 Page 17 of 100
+omitted) (emphasis added); Turner v. Anderson, 704 So. 2d 748, (Fla. 4th DCA
+1998) ("[NJo public policy should allow appellant to recover damages as a result of
+engaging in criminal conduct such as occurred in this case."). Cf. Ewell v. Daggs,
+108 U.S. 143, 149 (1883) (stating that "'[njo court will lend its aid to a [plaintiff]
+who founds [a] cause of action upon an immoral or an illegal act'") (quoting
+Holman v. Johnson, 98 Eng. Rep. 1120 (K.B. 1775)); see also id. (explaining that
+this policy is ""not for the sake of the defendant, but because [the courts] will not
+lend their aid to such a plaintiff'" (quoting Holman, 98 Eng. Rep. 1120))
+(emphasis added); Balas v. Ruzzo, 703 So. 2d 1076, 1082 (Fla. 5th DCA 1997)
+(Harris, J., concurring) (remarking in the context of an action brought against an
+alleged prostitution house that "the court should continue its tradition of not
+interceding in civil conflicts involving transactions that are either illegal or are
+against public policy").
+Based on the foregoing, the plaintiff cannot blame someone else
+) for the consequences of her own criminal conduct. Cf. Feld & Sons, Inc.
+v. Pechner, Dorfman, Wolffe, Rounick and Cabot, 458 A.2d 545, 552 (Pa. Super.
+Ct. 1983) (holding that law-firm clients could not recover damages flowing from
+their own criminal acts, even though clients' lawyers had suggested the unlawful
+conduct to begin with). See also Turner v. Anderson, 704 So. 2d 748, 751 (Fla. 4th
+17
+
+
+Entered on FLSD Docket 07/21/2008 Page 19 of 100
+(iii) The plaintiff cannot prevail on her claim for civil remedies
+for criminal practices or racketeering ("civil RICO") pled in
+Count IV.
+A cause of action under section 772.104, Florida Statutes ("Civil Remedies
+for Criminal Practices") requires a showing of direct injury. Even assuming for
+the sake of argument that Jane Doe can establish that the defendants engaged in a
+"pattern of criminal activity," she cannot establish that she was directly injured by
+those activities.
+Section 772.104 allows someone to bring a civil RICO claim only if "he or
+she has been injured by reason of" any RICO violation. § 772.104, Fla. Stat.
+(2007). Here, the allegations in Count IV, even if they are true, do not add up to a
+civil RICO claim because there is no proximate cause between the purported
+"pattern of criminal activity" and Jane Doe's alleged injuries.
+In a doomed attempt to satisfy the extremely high burden of pleading civil
+RICO under Florida law, the Amended Complaint lists a series of violations rooted
+in Florida's prostitution statutes. (Am. Compl. 9| 31.) According to the Amended
+Complaint, the defendants participated in a criminal enterprise... or conspiracy]"
+(Am. Compl. 9| 30) over an unspecified length of time "to repeatedly find and
+bring [Jeffrey Epstein] underage girls ... in order for Epstein to solicit, coerce,
+entice, compel, or force such girls in acts of prostitution and/or lewdness" (Am.
+19
+19 of 316
+
+
+Entered on FLSD Docket 07/21/2008 Page 21 of 100
+where petitioners alleged that they had "suffered emotional pain, anguish,
+humiliation, insult, indignity, loss of self-esteem, inconvenience, hurt and
+emotional distress" as a result of being forced repeatedly, over time, to "perform
+sexual acts to retain their employment"). Here, even if the Amended Complaint
+can be read to plead that the defendants schemed to solicit other massages from
+other people (see, e.g., Am. Compl. 11 9, 11, 12, 32), those activities are not
+alleged in any way to have impacted Jane Doe. Cf., e.g., Palmas Y Bambu, S.A. v.
+E.I. Dupont De Nemours & Co., Inc., 881 So. 2d 565, 570 (Fla. 3d DCA 2004)
+(holding that "'indirect injuries, that is injuries sustained not as a direct result of
+predicate acts ... will not allow recovery under Florida RICO.'" (quoting
+O'Malley v. St. Thomas Univ., Inc., 599 So. 2d 999, 1000 (Fla. 3d DCA 1992)))
+(emphasis added).
+Because the Amended Complaint does not satisfy the direct-injury
+requirement under Florida's RICO law, Jane Doe has failed to allege a cause of
+action against
+for violation of section 772.103, Florida Statutes.
+B. This Notice satisfies the procedural requirements of 28 U.S.C. § 1446.
+1. This notice of removal is timely.
+In accordance with 28 U.S.C. § 1446, this notice of removal is timely. Only
+defendant Epstein has been served with process. Defendants
+21
+3059 GRAND AVENUE, SUITE 340, COCONUT GROVE, FIORIDA 33133
+21 of 316
+
+
+Entered on FLSD Docket 07/21/2008 Page 23 of 100
+WHEREFORE, the Defendants, Jeffrey Epstein, I
+lin, and U
+1, remove this case from Palm Beach Circuit Court to the United States
+District Court for the Southern District of Florida.
+Respectfully submitted,
+LEWIS TEIN, P.L.
+3059 Grand Avenue, Suite 340
+By:
+Will Teri
+GUY A. LEWIS
+Fla. Bar No. 623740
+MICHAEL R. TEIN
+Fla. Bar No. 993522
+ATTERBURY, GOLDBERGER & WEISS, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, Florida 33401
+By: Jack A. Goldberger
+Fla. Bar No. 262013
+Attorneys for Defendant Jeffrey Epstein
+23
+3059 GRAND AVENJI, SUITE 340, COCOMUT GROVE, FLORIDA 33133
+23 of 316
+
+
+
+Service List
+Theodore J. Leopold, Esq.
+Ricci-Leopold, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+Fax: 561 6972383
+Counsel for Plaintiff Jane Doe
+Douglas M. McIntosh, Esq.
+Jason A. McGrath, Esq.
+McIntosh, Sawran, Peltz. & Cartaya, P.A.
+Centurion Tower
+1601 Forum Place, Suite 1110
+West Palm Beach, Florida 33401
+Fax. 561 682-3206
+Counsel for Defendant
+Bruce E. Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, Florida 33401
+Fax. 561 828 0983
+Counsel for Defendant
+Robert D. Critton, Esq.
+Michael J. Pike, Esq.
+Burman, Critton, Luttier &
+Coleman, LLP
+515 N. Flagler Drive, Suite 400
+West Palm Beach, Florida 33401
+Fax. 561 515 3148
+Co-Counsel for Jeffrey Epstein
+25
+25 of 316
+
+
+Rainyment 1 Entered on FLSD Docket 07/21/2008 Page 27 of 100
+Reporting and Transcriptina, Inc.
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, ELORIDA
+CASE NO. 2006 CF09454AXX
+STATE OF FLORIDA,
+-VS-
+JEFFREY EPSTEIN,
+Defendant.
+DEPOSITION OF
+Wednesday, February 20, 2008
+2:00 p.m. - 4:30 p.m.
+Palm Beach County Courthouse
+205 North Dixie Highway
+West Palm Beach, Florida 33401
+COPY
+:. 4
+Reported By:
+Judith F. Consor, FPR
+Notary Public, State of Florida
+Consor & Associates Reporting and Transcription
+Phone - 561.682.0905
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+27 of 316
+
+
+Ratument 1 Entered on FLSD Docket 07/21/2008 Page 29 of 100
+Reporing aud Transcripsinn, Inc.
+Page 3
+1
+2
+3
+IN DEX
+WITNESS:
+PAGE:
+DIRECT EXAMINATION
+BY MR. TEIN:
+4
+5
+7
+8
+9
+10
+- - -
+NOEXHIBITS MARKED
+-
+....
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+.......CERTIFIED QUESTIONS...
+Page
+53
+55
+59
+111
+112
+Line
+22
+1
+2
+14
+2
+...
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+20 of 316
+
+
+Case 9:08-cv-80804-KAM Dortment 1 Entered on FLSD Docket 07/21/2008 Page 31 of 100
+Cansor & Associates
+Page 5
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+my questions, will you just please let me know?
+A.
+Yes.
+e. And if at any time you're not feeling well
+or something like that, you'll tell us, right?
+A.
+Yes.
+0. Do you feel okay today?
+A.
+Yes.
+like that, right?
+A.
+No.
+Q.
+Not taking any alcohol or drugs or anything
+So you feel ready to have your deposition
+taken?
+A.
+Yes.
+e.
+what is your address?
+A.
+I'm currently living at my aunt's house and
+I don't know it off the top of my head.
+Where is it?
+A.
+In Jupiter.
+Who is your aunt?
+A.
+e.
+A.
+e.
+A.
+e.
+Who else is living there?
+my uncle.
+Anyone else living there?
+No.
+The contempt motion that your mother filed
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+31 of 316
+
+
+Rerument 1 Entered on FLSD Docket 07/21/2008 Page 33 of 100
+Heporsing and Transcripsion, Inc.
+Page 7
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Q.
+A.
+A.
+R.
+A.
+Where is that?
+Palm Beach Lakes.
+Have you spent the night over there?
+No, sir.
+Do you know the address there?
+I do not.
+Isn't your sister
+planning on living
+?
+with you and
+A.
+No.
+you know that this court case is a
+criminal prosecution, correct?
+A.
+Correct.
+And you know that it's a criminal
+prosecution against a man who has no criminal background.
+Do you know that?
+A.
+I do now.
+e.
+You agree that court is a very serious
+matter?
+A.
+Yes.
+e.
+And you're here with your lawyer
+Mr. Leopold, right?
+A.
+Yes.
+And you know that Mr. Leopold recently
+filed a lawsuit in federal court against Jeffrey Epstein,
+seeking fifty million dollars.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+33 01316
+
+
+Dacument 1 Entered on FLSD Docket 07/21/2008 Page 35 of 100
+Honoring and Transcriptian, Inc.
+Page 9
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR. LEOPOLD: Lewis, we're not going to do
+that.
+MR. TEIN: My name is not Lewis.
+I'm going to finish my question. Okay?
+MR. LEOPOLD: Do not answer until you hear
+from me.
+BY MR. TEIN:
+Other than conversations that you have had
+with Mr. Leopold - I'm not asking about that -- are you
+aware that Mr. Leopold has filed a lawsuit in federal
+court seeking fifty million dollars from Jeffrey Epstein
+on your behalf?
+MR. LEOPOLD: Same objection.
+Anything that you learn through
+conversations between you and me, do not answer.
+Those are protected. If you know through any
+other realm of knowledge, you may answer.
+THE WITNESS:
+NO.
+BY MR. TEIN:
+.. Q.
+You have no idea that Mr. Leopold filed a
+fif-y million-dollar lawsuit on your behalf against.
+Jeffrey Epstein?
+MR. LEOPOLD: Same objection.
+Do not answer that question if it's through
+discussions that you and I had. Outside of that,
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+35 of 316
+
+
+Redyment 1 Entered on FLSD Docket 07/21/2008 Page 37 of 100
+Reposing und Transcriptina, Ine.
+Page 11
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+objections.
+Check your rules.
+MR. LEOPOLD: Excuse me. For the record,
+Counsel asked me a question. I'll state the
+answer on the record. He asked me the question am
+I going to be answering that way throughout the
+deposition. So long as there's improper
+foundation and predicate asked by the attorney, I
+will protect my client and I make the record where
+appropriate. If counsel wishes to ask an
+appropriate worded question with the proper
+foundation and predicate, I will certainly allow
+the client to answer the question.
+MR. GOLDBERGER: Why don't you just state
+attorney/client privilege and just be done with
+it?
+MR. LEOPOLD: I want the record to be
+clear.
+18
+19
+20
+21
+22
+23
+24
+25
+MR. TEIN: You want to waste time is what
+you want to do.
+You were supposed to be here this morning
+and you totally broke the deal, the agreement that
+you had with us if your hearing got cancelled.
+But let's move on and maybe you'll stop
+obstructing this deposition.
+MR. LEOPOLD: I think the record is very
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+37 of 316
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 39 of 100
+1 Reporting and Transcription, Ine
+Page 13
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an attorney, filed a fifty-million-dollar lawsuit on your
+behalf against jeffrey Epstein, yes or no?
+MR. LEOPOLD: Same objection.
+MR. TEIN: We've heard the objection 10
+times already.
+MR. LEOPOLD: Counsel, excuse me.
+MR. TEIN: Just say attorney/client
+privilege. Stop interrupting my questions.
+MR. LEOPOLD: I'm entitled to make an
+objection for the record, which I'm doing, and
+I'11 make the same objection. And if it calls for
+attorney/client privilege, any conversations you
+and I have had, do not answer the question.
+And I think that it might be appropriate,
+for the record, to ask questions via
+as opposed to
+I think that
+would be more appropriate for this deposition.
+BY MR. TEIN:
+Go ahead. Please answer yes or no.
+A.
+R.
+Yes.
+Thank you.
+In fact, you know that Mr. Herman held a
+press conference after he filed the fifty-million-dollar
+lawsuit on your behalf, don't you?
+A.
+After it happened.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+39 of 316
+
+
+Ralpent 1 Entered on FLSD Docket 07/21/2008 Page 41 of 100
+" Reporting aml Transcription, Ine.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+..."
+Page 15
+MR. LEOPOLD: We're going to leave or we're
+going to take a break, because his demeanor is not
+appropriate. There's no reason to have this kind
+of demeanor. If you want to have this kind of
+demeanor with me --
+MR. TEIN: You are obstructing this
+deposition.
+MR. GOLDBERGER: Why don't you guys go
+outside and just talk about -
+MR. LEOPOLD: She -- her job is very
+difficult and she's not going to be able to take
+us both talking at the same time.
+MR. GOLDBERGER: Off the record.
+MR. LEOPOLD: We're not going off the
+record, Jack. We're not, Jack. Her job is very
+difficult. I'm going to make the record.
+I don't think it is appropriate, especially
+in the small confines of this room, to be very
+aggressive with this young lady.
+MR. TEIN: That's not happening. Stop,
+stop actually -
+MR. LEOPOLD: If you're going to interrupt
+me, we're going to cancel this deposition -
+MR. TEIN: Stop misrepresenting.
+THE COURT REPORTER: I need one at a time,
+1655 Palm Beach Lakes Blvd., Sulte 500 - West Palm Beach, FL 33401
+41 of 316
+
+
+Dakument 1 Entered on FLSD Docket 07/21/2008 Page 43 of 100
+p Reponing and Transcriptin, Jone.
+Page 17
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+You were supposed to be here at nine a.m.;
+it's now after two. Take your break and come
+back.
+MR. LEOPOLD: Okay. If the demeanor keeps
+up, we will not be here beyond those five minutes.
+MR. TEIN: Take your break and come back.
+MR. LEOPOLD: Okay. So I suggest that you
+relax.
+break.
+five-minute break.
+take deep breaths.
+take a break.
+MR. TEIN: I suggest that you take your
+MR. GOLDBERGER: Let them take that
+MR. LEOPOLD: But I would suggest that you
+MR. TEIN: Suggest whatever you want. Go
+(Thereupon, a recess was taken.)
+BY MR. TEIN:
+you agree that giving testimony
+today at your deposition is something very serious, don't
+you?
+A.
+e.
+A.
+Yes.
+Yes.
+And you respect the court, don't you?
+Let me show you Exhibit 31-001. Can you
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+43 of 310
+
+
+Dokidgent 1 Entered on FLSD Docket 07/21/2008 Page 45 of 100
+P? Reporting and Transcripsion, Inc.
+Page 19
+1
+...
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Did you send that message to a friend of
+yours on MySpace?
+A.
+Sure, yes.
+Were you referring to this deposition?
+A.
+Yes.
+0. Do you find the term n-i-g-g-e-r offensive?
+A.
+That's not anywhere in there.
+R.
+What word did you use in there?
+MR. LEOPOLD: Where are you referring to,
+Counsel? There's 20 plus words in there.
+MR. TEIN: Don't make a speaking objection.
+THE WITNESS: Are you referring to
+anything --
+MR. LEOPOLD: No,
+Don't -- don't --
+let him ask you the question.
+BY MR. TEIN:
+e.
+What question were you asking,
+MR. LEOPOLD: She doesn't ask questions.
+You ask the questions. What is the question
+pending?
+BY MR. TEIN:
+what is the last word on there in
+the text of your message before the closing?
+A.
+Niggaa.
+e.
+Don't you find that term offensive?
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+45 of 316
+
+
+Rotiment 1 Entered on FLSD Docket 07/21/2008 Page 47 of 100
+consor & Associate:
+sy Reporting and Transcription, In
+Page 21
+.....
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY MR. TEIN:
+l. Let me ask you,
+did you in fact
+write your friend this message about this deposition?
+A.
+Yes.
+l. So you wrote your friend that this
+deposition is stupid court s-h-i-t, correct?
+A.
+Yes.
+Because you think this deposition is stupid
+court s-h-i-t, don't you?
+A.
+No.
+e.
+You wrote that to your friend, didn't you?
+A.
+Yes.
+R.
+You think that court is stupid, don't you?
+A.
+In some cases.
+And you think that court is bull s-h-i-t,
+don't you?
+A.
+No.
+And you think this deposition is bull
+s-h-i-t, don't you?
+A.
+No.
+e. You wrote that to your friend, didn't you?
+MR. LEOPOLD: Objection. Asked and
+answered.
+MR. TEIN: That's not an objection.
+BY MR. TEIN:
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+47 of 318
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Dolidpent 1 Entered on FLSD Docket 07/21/2008 Page 49 of 100
+tonsor & Associates
+MR Reporting and Transeripcion, Inc.
+Page 23
+BY MR. TEIN:
+e.
+you think that giving testimony
+today, under oath, is bull s-h-i-t, don't you?
+A.
+No.
+Q. And you wrote that to your friend on
+MySpace last week, didn't you?
+MR. LEOPOLD: Objection. Asked and
+answered.
+THE WITNESS: No, I did not.
+BY MR. TEIN:
+You didn't write this exhibit?
+A.
+I wrote that, but I didn't write what you
+said.
+You wrote in this exhibit, "I got some
+stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't
+you write that?
+A.
+Yes.
+Referring to this deposition, didn't you?
+A. Referring to the court. I was later
+informed that it was a deposition.
+e. I'm going to ask you some questions now
+about what happened when you went to Jeff Epstein's house
+three years ago. Okay?
+A.
+Uh-huh.
+e.
+When the police interviewed you one month
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+49 of 316
+
+
+Rpoyment 1 Entered on FLSD Docket 07/21/2008 Page 51 of 100
+1 Reporting aid Transcripcion, Inc.
+. Page 25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+" 10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+Yes.
+Before you got to Epstein's house
+never said anything to you on the telephone about sexual
+activity with Epstein, did she?
+A.
+No.
+And before you got to Epstein's house
+never sent you a message over the Internet about
+sexual activity with Epstein, did she?
+A.
+No.
+e. Did
+ever try to convince you to
+engage in any sexual activity with Epstein?
+A. No.
+e. Did
+every try to convince
+you to engage in any sexual activity with Epstein?
+A. I don't know who
+is.
+2. Do you have a friend
+?
+A.
+No.
+Okay. Before you went so Epstein's house
+did anyone call or e-mail you to induce you to engage in
+sexual activity with Epstein?
+A.
+No.
+Q.
+so you're sure that before you got to
+Epstein's house no one tried to persuade you to engage in
+sexual activity with Jeffrey Epstein?
+A.
+No.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+51 of 318
+
+
+Rogument 1 Entered on FLSD Docket 07/21/2008 Page 53 of 100
+nor& Asociates
+Page 27
+MR. LEOPOLD: If you do it one more time,
+we're leaving.
+BY MR. TEIN:
+....
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR. LEOPOLD: I'm going to make the record.
+You cannot interrupt me when I'm making the
+record. Out of professional conduct, you cannot
+do that. I'm entitled
+to make the record. I made
+an objection, asked and answered. Your demeanor
+is inappropriate.
+You're willing and you are able
+and you're responsible to ask a question in a
+professional manner, and ask the question and once
+you get the answer, to either follow up on it oI
+move on, but not continuously browbeat and ask the
+same question over and over because you don't like
+the answer.
+MR. TEIN: Calm down, sir.
+MR. LEOPOLD: Trust me, I'm very calm here.
+When I'm not calm, you'll know it. I'm very calm.
+So please continue on. But I will not
+allow you to continue to harass her in the
+demeanor that you're doing. Ask her a question
+and move on.
+MR. TEIN: Are you done?
+MR. LEOPOLD: Thank you. I am.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+53 of 316
+
+
+Resument 1 Entered on FLSD Docket 07/21/2008 Page 55 of 100
+2
+3
+4
+5
+6
+7
+8
+Page 29
+put up with it and I don't need to put up with it
+and it's not appropriate. And I'm sure
+Mr. Goldberger knows all this, because I know that
+he wouldn't do this. So I will not put up with
+it. And I think it's highly inappropriate to do
+this with this child sitting here, the way you're
+acting, primarily towards me, and I will not put
+up with it.
+MR. TEIN: Will you please stop your speech
+so I can ask questions?
+MR. LEOPOLD: So long as you act
+professionally, I will do so. But if you continue
+to do it this way, I will leave.
+MR. TEIN: Suit yourself.
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY MR. TEIN:
+are you sure that before you got to
+Epstein's house no one tried to persuade you to engage in
+sexual activity with Epstein for money?
+MR. LEOPOLD: Asked and answered.
+Objection.
+MR. TEIN: Did you get her answer?
+THE COURT REPORTER: No, I did not.
+THE WITNESS: I'm sure.
+BY MR. TEIN:
+e. Let me ask you a few questions about your
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+55 of 316
+
+
+Ragument 1 Entered on FLSD Docket 07/21/2008 Page 57 of 100
+Reporting one Transcripsinn, Inc.
+Page 31
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+No.
+All right. Let me ask you two final areas
+of questioning about this and we'll move onto something
+eIse. Okay?
+A. Uh-huh. Yes. I'm sorry.
+2. Before you got to Epstein's did anyone
+associated with Epstein ever call you on the phone and
+try to persuade, induce, entice or coerce you to engage
+in any sexual activity?
+A. NO.
+l. Before you got to Epstein's did anybody
+associated with Epstein ever contact you on the Internet
+and try to persuade, induce, entice or coerce you to
+engage in any sexual activity?
+A.
+No.
+who told you that when you got to
+Jeff Epstein's house you should lie to jell about your
+age?
+A.
+Was it
+or was it the other girl in
+the car who you rode over with to Epstein's house?
+that day?
+A.
+e.
+A.
+Who was the other girl in the car with you
+I honestly don't know.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+57 of 316
+
+
+Rodument 1 Entered on FLSD Docket 07/21/2008 Page 59 of 100
+1 Reporting and Transcription, Inc.
+Page 33
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+when you first met Jeff he tried to find
+out how old you were, right?
+A.
+Not when we first introduced each other;
+when we get upstairs, then, yes.
+During the massage Jeff asked you how old
+you were,
+correct?
+A.
+Yes, yes.
+e. Now hadn't you already told Jeff's
+assistant, the one who walked you upstairs, that you went
+to college and had just moved down here from ohio?
+A.
+I never spoke to the lady.
+Q. Do you want to rethink that answer?
+MR. LEOPOLD: Is that a question?
+BY MR. TEIN:
+Do you want to rethink that answer?
+A. No. I didn't really speak with her that
+much.
+e.
+Do you want to try to refresh your memory
+on that?
+MR. LEOPOLD: Do you have something to
+refresh her memory with?
+MR. TEIN: Do you want to stop making
+speaking objections?
+MR. LEOPOLD: No. But to refresh someone's
+memory, you show them a document.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+59 of 318
+
+
+Entered on FLSD Docket 07/21/2008 Page 61 of 100
+5nsor & Associates
+° Reporting and Transcripsion, Inc.
+Page 35
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+You can answer the question.
+A.
+Sure.
+Is there anything that would refresh your
+memory that in fact you told Mr. Epstein's assistant, the
+one who walked you upstairs, that you went to college and
+you had just moved down here from Ohio?
+A.
+I don't remember saying that, but if you --
+I don't remember saying that myself, so -
+That would be a lie, right?
+A.
+No. I really don't remember.
+e.
+So you told Jeff that you were 18 years
+old, correct?
+A.
+Yes.
+2. Do you remember Detective Michelle Pagan of
+the Police Department, Palm Beach Police Department?
+A.
+Yes.
+Do you remember you spoke to her?
+A.
+Yes.
+Do you remember that you told Detective
+Pagan that when you lied about your age to Jeff you said
+it really fast because you didn't want to make it sound
+like you were lying?
+A.
+I don't remember the words exactly, but I
+do remember telling her I told him I was 18.
+0.
+And do you remember telling Detective Pagan
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+61 of 318
+
+
+Dagument 1 Entered on FLSD Docket 07/21/2008 Page 63 of 100
+Mansor & Associates
+Reporting and Transcription, Ine.
+Page 37
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY MR. TEIN:
+0. Let me put it again.
+Does it sound right to you that you told
+Detective Pagan that when you lied about your age to
+Jeffrey Epstein, you said it really fast because you
+didn't want to make it sound like you were lying?
+MR. LEOPOLD: Objection. Lack of
+foundation, asked and answered.
+THE WITNESS: I could have possibly said
+that, yes.
+BY MR. TEIN:
+You didn't want Mr. Epstein to know that
+you were lying about your age, right?
+A.
+correct.
+e.
+You didn't want Mr. Epstein to know that
+you were not 18 yet, right?
+A.
+Correct.
+You wanted Mr. Epstein to believe that you
+really were 18, right?
+A.
+Correct.
+e.
+Do you remember when Mr. Epstein asked
+where you went to school?
+A.
+Yes.
+e.
+And you told Mr. Epstein you went to
+Wellington, right?
+50r pir 10 m
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+83 01318
+
+
+Doçument 1 Entered on FLSD Docket 07/21/2008 Page 65 of 100
+(Reporting ond Transcriptite, Jee.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+:16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 39
+that would do that to a witnesses or to a person
+that's sitting in this chair is not acting
+professionally. You can't ask a question like
+that. You can do it, but it's not proper. And
+I'm sure you weren't trained that way, certainly
+not ethically.
+MR. TEIN: Will you stop?
+MR. LEOPOLD: I'm not going to stop,
+because the way you're asking that question is
+improper and you know it.
+MR. TEIN: You're losing your cool.
+BY MR. TEIN:
+Ms.
+MR. LEOPOLD: Trust me. I'm very calm.
+When I lose my cool, you'll know it.
+MR. TEIN: I do know it.
+BY MR. TEIN:
+Q. Ms.
+Mr. Epstein never asked you
+to do anything other than massage him, correct?
+A. Incorrect; because he asked me to take off
+my bra, so that would be two things he's asked me to do.
+2. Other than asking you to take your bra off,
+Mr. Epstein never asked you to do anything with him other
+than massage, correct?
+MR. LEOPOLD: Objection. Foundation,
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+85o1316
+
+
+Bpgument 1 Entered on FLSD Docket 07/21/2008 Page 67 of 100
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 41
+l. You told the police twice when you spoke to
+Michelle Pagan that "at no time did he touch me. " Didn't
+you say that to the police?
+A. Yeah.
+e. And you're saying that that was not fully
+truthful. Is that what you're saying now?
+A.
+Correct.
+e. And you're saying if you're not fully
+trithful, that's not a lie. Correct?
+A. You took that out of context like really
+bac. I didn't mean like that. Touching my legs and --
+he never kept his hands to himself the entire time.
+That's what I'm trying to say.
+You told the police, "At no times did he
+touch me. " You agree with that, correct?
+A.
+No, I don't agree with that, because he did
+touch me.
+Did you tell the police that he did not
+touch you, yes or no?
+A.
+It's a possibility, but I do not remember.
+e.
+Okay. And you did not have any type of sex
+with Jeff, correct?
+A.
+No.
+l. And you did not have any type of oral sex
+with Jeff, correct?
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+67 of 316
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 69 of 100
+consor « Associates
+i Reparing and Transcription, in
+Page 43
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+things, but it wasn't joking about it at all.
+R.
+You joked about it, didn't you?
+A.
+No.
+You said to
+that if you did this
+every weekend you'd be rich, didn't you?
+A.
+No. That's what
+told me.
+You didn't tell that to
+MR. LEOPOLD: Objection. Asked and
+answered.
+THE WITNESS: No.
+BY MR. TEIN:
+After you left Epstein's house you took the
+money and you went shopping with
+and the other
+girl in the car, correct?
+A.
+Incorrect. I didn't spend any of the
+money.
+A.
+e.
+didn't you?
+You went to Marshall's, didn't you?
+I went along, yes, but I didn't --
+You went shopping with them at Marshall's,
+MR. LEOPOLD: objection.
+THE WITNESS: I guess you could say that.
+MR. LEOPOLD: Objection. Lack of predicate
+and foundation. Mischaracterization of earlier
+testimony.
+1655 Paln Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+60 of 316
+
+
+yament 1
+nor & AsSociatesket 07/21/2008 Page 71 of 100
+(Hoporing and Transcripiro, Ine.
+Page 45
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+It was not this year, no.
+Was it 2007?
+A. I'd have to say at least two years ago or a
+year ago, yeah. So it would be 2007, 2006; but it was a
+while ago.
+e.
+How many federal prosecutors or FBI agents
+came to your house?
+A.
+I'm trying to remember. I want to say four
+people came.
+R.
+Did they give you their business cards?
+A.
+If they did, I don't remember, and they
+weren't toward me. Maybe my parents have them. I don't
+know.
+Did they give you their cell phone numbers?
+A.
+2.
+phones?
+parents.
+parent's?
+A.
+e.
+A.
+e.
+A.
+No.
+Did you ever speak to them on their cell
+No, sir.
+Did they speak to your parents?
+That's something you'd have to ask my
+Do you know whether they spoke to your
+No, sir.
+You have no idea?
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+71 of 318
+
+
+Riddlent 1 Entered on FLSD Docket 07/21/2008 Page 73 of 100
+nsor & Associates
+i Heporting and Transeriprion. Inc
+Page 47
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+fashion, you may answer.
+THE WITNESS: Okay.
+I wouldn't know.
+BY MR. TEIN:
+e.
+You don't know?
+A.
+No.
+MR. LEOPOLD: Objection. Foundation.
+Attorney/client privilege.
+BY MR. TEIN:
+e.
+And you say you don't know who
+is?
+A.
+No, sir.
+Does it refresh your recollection that he's
+A.
+e.
+•A.
+No.
+That he's
+boss?
+No.
+Does it refresh your memory that he's the
+ex-partner of jeff Herman, the first lawyer who sued
+you -- sued Mr. Epstein on your behalf for fifty million
+dollars?
+A.
+No, sir. I don't know who he is.
+Without telling me any conversations that
+you've had with your lawyers, how is it that you selected
+Mr. Herman as your lawyer from the 81,000 members of the
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+73 of 316
+
+
+Roguent 1 Entered on FLSD Docket 07/21/2008 Page 75 of 100
+" Hoporting anel Transcripsiren, Inc.
+Page 49
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Mr. Herman in the presence of
+A. None.
+0. What discussions did you have in the
+presence of her aunt?
+A.
+Of my aunt?
+MR. GOLDBERGER: It's the witness's. aunt.
+BY MR. TEIN:
+Oh, of your aunt.
+The only one that we've ever discussed of
+A.
+ever had.
+l. And so you were in a conversation with
+Mr. Herman and your aunt?
+A.
+Yes, sir.
+And you discussed privileged matters during
+that conversation?
+MR. LEOPOLD: Object to the form. I think
+you might have to educate her on that question.
+BY MR. TEIN:
+e.
+You discussed the lawsuit?
+A.
+Yes.
+e.
+Did
+tell you about any
+conversations that she had with Mr. Herman?
+A. As far as I'm concerned, she's never spoken
+or she's never had a conversation. She only opened the
+doo: and then left. She's the one who answered the door.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+78 of316
+
+
+Dagument 1 Entered on FLSD Docket 07/21/2008 Page 77 of 100
+Reparsing anel Transcriprien, Inc.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 51
+A.
+No.
+e. And we've learned that many of the girls,
+some of whom are as old as 23, were told by the
+government that they would get money at the end of the
+criminal prosecution. Does that sound familiar to you?'
+A.
+No, sir.
+0.
+Other than Mr. Leopold here -- I'm not
+asking about Mr. Herman either --
+A.
+Uh-huh.
+e. - did anyone ever discuss with you that
+you could get reimbursement for your damages?
+A.
+No, sir.
+l. Did you or any member --
+MR. LEOPOLD: Are you referring to a
+criminal matter or a civil matter?
+BY MR. TEIN:
+l. Did you or any member --
+MR. LEOPOLD: Excuse me. Let me object to
+the form of the question.
+BY MR. TEIN:
+e.
+Did you or any member of your family ever
+get a victim notification letter from anyone?
+A.
+I no longer live at that residence and I
+wouldn't know.
+So your testimony is that you have never
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 79 of 100
+Roporting and Transcriptin, Inc.
+Page 53
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+it back at the end of the meeting?
+A.
+No. They - yeah. No. They have it. I'm
+guessing. I don't have it.
+2. How much money are you hoping to get out of
+Mr. Epstein?
+MR. LEOPOLD: Objection to the form of the
+question. Attorney/client privilege.
+BY MR. TEIN:
+e. How much money are you hoping to get, you,
+yourself, hoping to get out of Epstein?
+MR. LEOPOLD: Same. Same objection,
+attorney/client privilege.
+Don't answer the question.
+BY MR. TEIN:
+I'm not asking about what your lawyer told
+you.
+MR. LEOPOLD: I'm instructing her not to
+answer the question, because any of those
+conversations involve her counsel.
+MR. TEIN: Certify that.
+MR. LEOPOLD: Please.
+................. CERTIFIED QUESTION......
+BY MR. TEIN:
+Now,
+deposition, didn't you?
+you lied to get out of this
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+79 of 316
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 81 of 100
+Roporting and Transcripciran, Inc.
+Page 55
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+.CERTIEQ...
+BY MR. TEIN:
+You asked your co-workers--
+MR. LEOPOLD: It's vague and ambiguous.
+BY MR. TEIN:
+You asked your co-workers at the
+Quarterdeck Tavern to lie for you, didn't you?
+A. No. I informed my boss about what was
+going on and he told me that he would help in any way
+that he can.
+e.
+Okay. You got your friend
+to lie
+by switching name tags with you, correct?
+A.
+Incorrect. It was a coincidence that same
+night she was not wearing her name tag; she was wearing
+mine. But I was also not wearing -- I was wearing my
+name tag. Everyone switches name tags. It just so
+happens it was a coincidence that same night the people
+came with the papers.
+MR. TEIN: Will you put up Exhibit 18-001?
+MR. GOLDBERGER: And mark 18-001 for
+identification purposes to this deposition.
+MR. LEOPOLD: None of them have been marked
+yet. Can we mark them and put them as attachment
+to the depositions? Because I think you've shown
+three photos now. And this is the only one that
+1655 Paim Beach Lakes Bivd., Suite 500 - West Palm Beach, FL 33401
+81 of 316
+
+
+Document 1 • Entered on FLSD Docket 07/21/2008 Page 83 of 100
+Reporting onal Transcriptisa, Inc.
+Page 57
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+Yes.
+your friend, who you say the day
+that the process servers went to serve you with a
+subpoena for this deposition, just happened -- just by
+coincidence, was wearing your name tag?
+A.
+Yes, sir.
+And just by coincidence, you were wearing
+her name tag, correct?
+A.
+Yes.
+e. Your testimony under oath is that's just a
+coincidence, right?
+A.
+Total honesty.
+l. It just happens to be the day that you were
+going to be served with a subpoena, correct?
+A.
+That wasn't the first day that -
+MR. LEOPOLD:
+just answer the
+question. It calls for a yes or no.
+THE WITNESS: Yes.
+BY MR. TEIN:
+
+You said that wasn't the first day you were
+going to be -- you thought you were being served with a
+subpoena, correct?
+A.
+Correct.
+You knew before the day that you switched
+name tags with
+that the process servers were
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+
+
+Entered on FLSD Docket 07/21/2008 Page 85 of 100
+'Roporting and Transcripcion, Ine.
+Page 59
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+85 of 316
+MR. LEOPOLD: I'll certify it.
+.......CERTIFIEDQUS......
+She's answered that question.
+She's explained it five
+tines already. The fact that Counsel doesn't like the
+answer, that's a different query.
+MR. TEIN:
+Stop making speaking objections.
+MR. LEOPOLD: I'm not. I'm not going to
+put up with it, because it's in appropriate, Jack,
+and you know it. I will not allow Counsel to
+berate a witness, whether it's in a criminal case
+or a civil case, whether my client or -
+MR. TEIN: Calm down.
+MR. LEOPOLD:
+Excuse me.
+No, I'm not going to allow it. That is not
+proper.
+MR. GOLDBERGER: Okay.
+MR. LEOPOLD: If he wants to say that she's
+lying after asking it five times and her
+explaining in great detail, he can do that. But
+I'm not going to allow her to answer, nor be
+harassed by him. It's improper.
+MR. GOLDBERGER: Okay. But your response
+that Counsel doesn't like the question -- or
+doesn't like the answer -- just let me finish.
+MR. LEOPOLD: Absolutely. I wasn't going
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+
+
+Ricument 1 Entered on FLSD Docket 07/21/2008 Page 87 of 100
+* Roporting and Transoripsies, InE....
+1
+2
+3
+4
+5
+6
+7
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+87 of 316
+Page 61
+MR. LEOPOLD: This is really big stuff that
+you're going through. But that's fine; just ask
+your question and move on. But do it one time.
+If you don't understand it, I'll let you follow
+up, but I'm not going to allow you to ask the same
+question time and again and then call her a liar.
+Just ask the question, get the answer and move to
+the next subject matter.
+MR. TEIN:
+Ted, I'm sitting right across
+the table from you.
+MR. LEOPOLD: Yes, sir.
+MR. TEIN: Please be quiet. Don't yell.
+MR. LEOPOLD: I will not be quiet.
+MR. TEIN: Stop yelling.
+MR. LEOPOLD: Lewis, when I'm yelling
+you'll know it. I will not --
+MR. TEIN: My name is not Levis.
+MR. LEOPOLD: I thought your first name was
+Lewis, Mr. Tein.
+MR. TEIN: You watched me for three days at
+the evidentiary hearing where you sat in the back
+of the courtroom. You should know who I am.
+MR. LEOPOLD: Well, that's the impression
+you must have made in the courtroom.
+I will not be quiet.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 89 of 100
+Reporting and Transcription, Ine.
+Page 63
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Where were you when
+told this
+someone that you were not at the Quarterdeck Tavern?
+A.
+Eating nachos.
+At the Quarterdeck Tavern?
+A.
+Yes.
+What did you do so that
+would lie to
+the process servers for you?
+A.
+R.
+Nothing.
+You just got him to lie for you, didn't
+you?
+A.
+wasa't there.
+No. I had no influence on him saying I
+He took 'that upon himself?
+Isn't it true that Mr. Epstein's process
+servers had to ask the police to get you out of the
+restaurant so that they could serve you?
+MR. LEOPOLD: Objection. Lack of
+foundation, predicate.
+BY MR. TEIN:
+You can answer the question.
+MR. LEOPOLD: If you know. Don't guess.
+THE WITNESS: No. Can you repeat the
+question?
+MR. TEIN: Don't coach.
+MR. LEOPOLD: Don't guess.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+89 of 316
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 91 of 100
+Reporting and Transcription, Inc.
+Page 65
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+e.
+When did you delete your Myspace page?
+A.
+A couple days ago.
+Q.
+Who told you to take your MySpace page down
+a couple of days ago?
+A.
+Nobody. I'm sick and tired of MySpace.
+You all of a sudden got sick and tired of
+MySpace and just a few days before this deposition you
+decided to delete your Myspace page, correct?
+A.
+Correct.
+e.
+Is that your testimony under oath?
+A.
+Yes.
+Did you take your MySpace page down because
+you thought the government might subpoena it?
+A.
+Incorrect.
+Hadn't your Myspace page been up for over
+three months before you took it down?
+A.
+Correct. But I also had made tons of
+MySpaces over the last years. I just get tired of them
+and delete them because -- drama -- and make new ones.
+We're going to talk about that.
+So you deleted your MySpace page after you
+were already under subpoena for this deposition, correct?
+A.
+Correct.
+What about the MySpace page didn't you want
+us to see,
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+91 of 316
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 93 of 100
+(" Roporting and Transcription, Joc.
+Page 67
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+e.
+A.
+And where is the one body piercing?
+Belly.
+When did you get that?
+For my birthday, with my stepmother and my
+father.
+e.
+And when was that?
+A.
+When I was 14.
+2. Okay. So you had that body piercing when
+you met Epstein, correct?
+A. It might have been, or maybe that -- yeah,
+either my 14th birthday of my 15th. I honestly don't
+remember.
+Now you've lied about your age to get into
+bars by using driver's licenses that aren't yours,
+correct?
+A.
+e.
+never done that?
+A.
+e.
+correct?
+A.
+Incorrect.
+Are you swearing under oath that you've
+Yes, I swear under oath.
+And you've lied about your age to buy beer,
+Incorrect.
+You're swearing under oath that you've
+never lied to stores about your age?
+A. I've never lied to a store about my age or
+1655 Paim Beach Lakes Bivd., Suite 500 - West Palm Beach, FL 33401
+83 of 316
+
+
+Ragument 1 Enteredon FLSD Docket 07/21/2008 Pago 9501100
+M? Reporting and Transcripcion, Inc.
+Page 69
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Now you can explain your answér.
+A.
+I know that I have seen all of these and I
+know that this one is mine.
+Can you go down?
+MR. LEOPOLD: Just for the record, you're
+pointing to the photo.
+THE WITNESS: I'm pointing to --
+BY MR. TEIN:
+You're pointing to the one where it says
+your age is 18?
+A.
+Correct.
+That's yours, right?
+A.
+Correct. That's mine from a couple years
+ago that I have not been on, because I don't use that.
+Please keep going down, please. And I think that's it,
+because there's no one -- just that one is mine.
+So the one you pointed to where it says
+your age is 18, that's yours, correct?
+A.
+Correct.
+And when you wrote 18 as your age on your
+MySpace page, that was a lie, wasn't it?
+A.
+Correct.
+R.
+Did you lie about your Myspace page back
+then because you couldn't post on MySpace unless you were
+18?
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+85 of 316
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 97 of 100
+Page 71
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+THE WITNESS: I don't know which MySpace
+you're talking about.
+BY MR. TEIN:
+e. The MySpace page that you're just pointing
+to, where it says you were 18.
+A.
+Yes.
+And you were lying about your age, right?
+A.
+Uh-huh.
+Why did you finally post your true age on
+your Myspace profile -
+A. Uh --
+-- four days before you were scheduled to
+testify before the Grand Jury?
+A. I honestly don't know which Myspace,
+because I've had like a bazillion MySpaces, and in that
+year, I had two, that one and another one, and that one's
+been deleted. So I don't know which one you're referring
+to.
+25
+e.
+You remember that you changed your age on
+your MySpace page from 18 to your true age just four days
+before you went and testified in the Grand Jury?
+A.
+No.
+You don't remember that.
+A.
+No.
+Do you remember Detective Recarey? Did you
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+97 of 316
+
+
+Dogyment 1 Entered on FLSD Docket 07/21/2008 Page 99 of 100
+1 Roporting and Transcriptinn, Inc.
+Page 73
+1
+2
+3
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+THE WITNESS: No. I'm pretty sure my dad
+drove me, because he was there with me.
+BY MR. TEIN:
+2. Did any detective tell you to change your
+age on your MySpace page, to put your true age?
+A.
+No, sir.
+Now you also lied on your MySpace page
+about your income, didn't you?
+A.
+Yes.
+l. And you lied, saying that you made a
+quarter million dollars a year and higher, correct?
+A.
+As a joke, yes.
+That was a lie, wasn't it?
+A.
+Yes.
+e. And you also lied on your MySpace page,
+saying that you were married, didn't you?
+A. Possibly. And that might have been an
+exxor on my part.
+e.
+Now you also lie to the police, don't you?
+A.
+No.
+e.
+Well, you lied to the police in your
+tape-recorded statement that you gave to Detective
+Michelle Pagan three years ago, didn't you?
+A.
+To my knowledge, no, I did not.
+e.
+Well, you lied to the police when you
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+89 of 318
+
+
+Case 9:08-cv-80804-KAM Document 1|
+Entered on FLSD Docket 07/21/2008 FiCTiON D46O. D.C.
+July 18, 2008
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+08-80804-Civ-MARRA/JOHNSON
+CASE NO.:_
+JANE DOE,
+a/k/a JANE DOE #1,
+Plaintiff,
+V'S.
+JEFFREY EPSTEIN,
+and
+Defendants.
+NOTICE OF REMOVAL
+In accordance with 28 U.S.C. §§ 1441, 1446, and 1332(a)(I), the defendants,
+Jeffrey Epstein,
+, and
+, hereby remove this action' from
+Palm Beach County Circuit Court to the United States District Court for the
+Southern District of Florida, and respectfully state as follows:
+Introduction
+Six months ago, this plaintiff filed virtually the identical lawsuit in this
+Court. See Jane Doe #/ v. Epstein, Case No. 08-cv-80069-KAM (S.D. Fla. filed
+Doe v. Epstein el al., Case No. 50 2008 CA 006596 XXXX MB (Fla. 15th Cir. C1.
+filed Mar. 6, 2008).
+1 of 316
+
+
+Document
+
+Jan. 24, 2008) (the "First Federal Action"). The First Federal Action named
+Jeffrey Epstein as the sole tortfeasor, made the identical operative allegations as
+the instant Amended Complaint, and demanded damages of $50 million. (The
+amount of the demand against Epstein is evidently the product of recent reports in
+the press that Epstein is wealthy.)
+The First Federal Action was quickly followed by a series of substantially
+identical "Jane Doe" lawsuits, all filed by the same attorney in a three-month span.
+Compare Jane Doe #1 v. Epstein, Case No. 08-cv-80069-KAM (S.D. Fla. filed
+Jan. 24, 2008), with Jane Doe #2 v. Epstein, No. 08-CV-80119-KAM (S.D. Fla.
+filed Feb. 6, 2008) (asserting identical causes of action based on the same operative
+allegations), Jane Doe #3 v. Epstein, No. 08-CV-80232-KAM (S.D. Fla. filed Mar.
+5, 2008) (same), Jane Doe #4 |. Epstein, No. 08-CV-80380-KAM (S.D. Fla. filed
+Apr. 14, 2008) (same), and Jane Doe #5 v. Epstein, No. 08-80381-CV-KAM (S.D.
+Fla. filed Apr. 14. 2008) (same).
+On February 20, amid these filings, Jane Doe #1 was deposed in State of
+Florida v. Jeffrey Epstein, 502006CF009454AXXXMB (Fla. 15th Cir. Ct., filed
+Jul. 19, 2006), a parallel state-court criminal action. During that deposition, she
+made numerous admissions that completely undermined the allegations against
+Epstein that she had pled in her complaint. A copy of her deposition, with names
+2
+2 of 316
+
+
+Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 3 of 100
+redacted, is attached hereto (Exhibit A). Two days later, counsel for Jane Doe #1
+filed a notice of voluntary dismissal without prejudice in the First Federal Action.
+See Doe #1 v. Epstein, Case No. 08-CV-80069-KAM, DE 9.
+Two weeks later (March 6, 2008), having changed lawyers, Jane Doe #1
+refiled her complaint in Florida Circuit Court as the instant case, adding two
+nominal defendants: |||||||| Mr. Epstein's personal secretary, and
+HI one of Jane Doe #I's contemporaries. These defendants have nothing to
+do with the plaintiff's case against Mr. Epstein, except that the presence of H
+M'MM as a defendant in this new case, because she is a citizen of Florida (Am.
+Compl. 9| 4), would ostensibly prevent complete diversity.?
+As discussed below, however,
+I was named in the refiled
+lawsuit only to destroy diversity jurisdiction, and to prevent any application of 18
+U.S.C. § 3509(k), a mandatory stay provision applicable in federal court : Haley
+• Defendant Kellen is a citizen of New York (Am. Compl. 9 5), and is therefore a
+nonresident defendant for purposes of diversity jurisdiction and removal.
+3
+Section 3509(k) of Title 18, United States Code, provides as follows:
+3
+Lewis
+"Teinr.
+3059 GRAND AVERSE, SUITE 340, COCONUT GROVE, FLORIDA 33133
+3 of 316
+
+
+
+Robson, besides having nothing to do with the substantive allegations of the
+plaintiff's $50,000,000 case, is a community-college student with no assets
+whatever.
+Even if this case purports to identify a new (and strategically nondiverse)
+tortfeasor, the refiled lawsuit is still directed against only one defendant-Jeffrey
+Epstein. Then and now, the operative allegations are the same: Jane Doe alleges
+that Jeffrey Epstein assaulted her "in violation of Chapter 800 of the Florida
+Statutes."* (Am. Compl. 9| 18.) To sharpen her lawsuit, the plaintiff says she is
+seeking damages in connection with a "conspiracy" (Am. Compl. 9| 22), a "plan"
+(Am. Compl. 1 32), a "scheme" (Am. Compl. 9 32), and an "enterprise" (Am.
+Compl. 132). These theories of liability, however, cannot be supported by the
+allegations in the Amended Complaint. Even if everything in the Amended
+Complaint were true, recovery against
+under any formulation, is
+impossible under Florida law.
+Focusing on the real parties to this controversy, the instant case could have
+(once again) been brought here in federal court-just like the four other "Jane
+18 U.S.C. § 3509(k) (emphasis added).
+* Chapter 800, Florida Statutes, is entitled, "Lewdness; Indecent Exposure."
+4
+3059 GRANU AVEMUE, SUITE 34D, COCONUT GROVE, FLORIDA 33133
+4 of 316
+
+
+Entered on FLSD Docket 07/21/2008 Page 5 of 100
+Doe" lawsuits presently pending against Epstein, filed by this plaintiff's former
+lawyer.
+This case is properly removed to federal court, first, because there is
+complete diversity among the real parties-in-interest, second, because the amount
+in controversy exceeds $75,000, and third, because this Notice complies with the
+requirements of 28 U.S.C. § 1446.
+Discussion
+A. This case is properly removable because it falls within the original
+jurisdiction of the United States District Court for the Southern
+District of Florida.
+A state-court case is properly removable when "it could have been brought,
+originally, in a federal district court." Lincoln Prop. Co. v. Roche, 546 U.S. 81, 83
+(2005) (citing 28 U.S.C. § 1441(a)). This case was originally filed in federal
+district court, and it is the same case today. Even though it was reconfigured to
+look like a state-court lawsuit, this action falls squarely within the bounds of the
+diversity-jurisdiction statute. See 28 U.S.C. § 1332(a)(1) (establishing that federal
+district courts have original jurisdiction over cases where the amount in
+controversy [is more than $75,000] ... and [when the controversy] is between
+citizens of different states").
+5
+3059 GRAND AVENUE, SURE 340, COCONUT GAOVE, FLORIDA 33133
+5 of 316
+
+
+
+1. The amount in controversy in this action exceeds $75,000.
+This case is a duplicate of the First Federal Lawsuit. In that case, Jane Doe
+pled "damages in excess of $50 million." See Doe v. Epstein, No. 08-80069-KAM
+(S.D. Fla. filed Jan. 24, 2008) (Compl. 9 6). That allegation is now deleted and the
+Amended Complaint substitutes a generic prayer for relief.! It is clear, however,
+that Jane Doe still seeks more than $75,000 in damages.
+This case, precisely like the First Federal Action, seeks damages in
+connection with an alleged assault. (Am. Compl. 19 16-19.) The Amended
+Complaint alleges that Jane Doe "has suffered and will continue to suffer severe
+and permanent traumatic injuries, including mental, psychological, and emotional
+damages." (Am. Compl. {| 19.) These are the identical injuries Jane Doe asserted
+in the First Federal Action, and are no less serious simply because pled under a
+state-court caption. Cf., e.g., Woods v. Southwest Airlines, Co., 523 F. Supp. 2d
+812, 820 (N.D. III. 2007) (determining, in the context of diversity jurisdiction, that
+the $75,000 threshold had been satisfied, and "clearly [surpassed]," based on "the
+nature of the injuries alleged" in the complaint).
+' The Complaint seeks damages for "[more than].... $15,000." (Am. Compl. 96.) This
+boilerplate is routinely used in Florida pleading practice to trigger application of section
+26.012, Florida Statutes, the statute that establishes the jurisdictional amount required for
+filing in Florida's Circuit Court (as opposed to County Court).
+6
+Lewis, Teinn
+6 of 316
+
+
+Entered on FLSD Docket 07/21/2008 Page 7 of 100
+To cement this point, the Eleventh Circuit Court of Appeals has said that
+"[w]hen [a] complaint does not claim a specific amount of damages, removal from
+state court is proper if it is facially apparent from the complaint that the amount in
+controversy exceeds the jurisdictional requirement." Williams v. Best Buy Co.,
+Inc., 269 F.3d 1316, 1319 (1Ith Cir. 2001). This case meets that standard, and
+satisfies the first prong of diversity jurisdiction.
+2. There is complete diversity among the real parties to this
+controversy.
+Diversity jurisdiction requires complete diversity. Carden v. Arkoma
+Assocs., 494 U.S. 185, 187 (1990) ("Since its enactment, we have interpreted the
+diversity statute to require 'complete diversity' of citizenship." (citing Strawbridge
+v. Curtiss, 7 U.S. (3 Cranch) 267, 267-68 (1806)). See also MacGinnitie v. Hobbs
+Group, LLC, 420 F.3d 1234, 1239 (IIth Cir. 2005) (stating that "[c]omplete
+diversity requires that no defendant in a diversity action be a citizen of the same
+state as any plaintiff'). As demonstrated below, this case satisfies the statutory
+requirement of complete diversity.
+(a) Plaintiff Jane Doe is a citizen of Florida. (Am. Compl. 9 1) °
+"Jane Doe may, in fact, be a citizen of Georgia, not Florida, as she pled in her Amended
+Complaint. See New York Post, Jul. 1, 2008 (reporting that "On his way into court [for
+his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by
+Doc, who has since moved to another state."); Jane Doe Depo. at 77, 112 (indicating that
+7
+Lewis."
+3059 GRAND AVENUE, SURE 340, COCONUT GROVE, FLORIDA 33133
+7 of 316
+
+
+
+(b) Defendant Jeffrey Epstein is a citizen of the U.S. Virgin Islands?
+(c) Defendant
+is a citizen of New York. (Am. Compl. 1 5.)
+3. Defendant|
+• was fraudulently joined to defeat diversity.
+"A non-diverse defendant who is fraudulently joined does not defeat
+diversity because his citizenship is excluded from the diversity calculus." Shenkar
+v. Money Warehouse, Inc., No. 07-20634-CIV, 2007 WL 3023531, at *1 (S.D. Fla.
+her twin sister lives with her mother in Georgia); Affidavit of
+at 9 1(stating, "I am the mother and natural guardian for Jane Doe #1" with jurat executed
+in Georgia before a Georgia notary), DE 4-2, Jane Doe No. 1 v. Epstein, Case No. 08-
+80069-Civ-Marra (1/29/08); Intervenor's Complaint, at 9| 2 (filed by "Jane Doe's Mother"
+and stating that "Jane Doe's Mother is a citizen and resident of the State of Georgia."),
+DE 5-2, Jane Doe No. I v. Epstein, Case No. 08-80069-Civ-Marra (1/29/08); Petition for
+Removal of Disability of Non-Age, at 11 1, 2, 7 (filed "on behalf of S.D.G.," alleging that
+"The mother is
+and her address is... Ga.," and stating that
+"S.D.G. is also the unnamed party in a lawsuit filed by her father on her behalf in the
+UJ.S. District Court for the Southern District of Florida, Case No. 08-80069, which was
+filed without the consent of the mother"), In re Sandberg v. Gonzalez, Case No. 50 2008
+DR 001141 (Palm Beach Co. Family Ct.) (1/31/08). If this turns out to be the case, there
+is complete diversity, regardless off
+citizenship. Although the Eleventh Circuit
+has recently indicated that a district court may not conduct jurisdictional discovery under
+such circumstances, another division of this Court has since allowed it. Compare Lowery
+v. Ala. Power Co., 483 F.3d 1184, 1215-16, 1221 (11th Cir. 2007) (holding that
+jurisdictional discovery to determine citizenship upon removal is inappropriate), with
+Calixto v. BASF Constr. Chemicals, LLC, slip op., Case No. 07-60077-CIV-ZLOCH,
+2008 WL 1840717, *1 (S.D. Fla. Apr. 22, 2008) (ordering that parties "shall engage in
+jurisdictional discovery for the Court to determine the citizenship of BASF and whether it
+has subject-matter jurisdiction over this action").
+- The Amended Complaint erroneously states that Jeffrey Epstein is a citizen of New
+York.
+8
+Lewis..
+..Teinr
+3059 GRAND AVENUE, SUITE 340, COCONUt GROVE, FLCHICA 33133
+8 of 316
+
+
+Entered on FLSD Docket 07/21/2008 Page 9 of 100
+Oct. 15, 2007) (Moreno, J.) (citing Riley v. Merrill Lynch, Pierce, Fenner & Smith,
+Inc., 292 F.3d 1334, 1337 (11th Cir. 2002)); accord, e.g., Tedder v. F.M.C. Corp.,
+590 F.2d 115, 117 (5th Cir. 1979) (denying motion to remand where two resident
+defendants were joined for the fraudulent purpose of defeating federal jurisdiction).
+In this case, the plaintiff relies on her original allegations to support three causes of
+action against
+: civil conspiracy (Am. Compl. 19| 20-23); Intentional
+Infliction of Emotional Distress (Am. Compl. 11 23-28); and civil RICO (Am.
+Compl. 11 29-34). These allegations, however, do not support these claims, or
+any other theory of liability that would allow recovery against
+CS.
+Parks v. The New York Times Co., 308 F.2d 474, 477 (5th Cir. 1962) (observing
+that "determination of fraudulent joinder is to be based on whether there was a real
+intention on colorable grounds to procure a joint judgment") (emphasis added).®
+(a) Nonresident defendants have a right of removal.
+The removal statute was enacted specifically "to protect defendants." Legg v.
+Wyeth, 428 F.3d 1317, 1325 (1Ith Cir. 2005). Cf., e.g., Picquet v. Amoco Prod.
+Co., 513 F. Supp. 938, 941 (M.D. La. 1981) (explaining that courts developed the
+fraudulent-joinder doctrine to protect "the right [of removal] granted to
+8 In Bonner v. City of Prichard, 661 F.2d 1206, 1207 (11th Cir. 1981) (en banc), the
+Eleventh Circuit Court of Appeals adopted as binding precedent all decisions of the
+former Fifth Circuit rendered prior to October 1, 1981.
+9
+9 of 316
+
+
+Entered on FLSD Docket 07/21/2008 Page 10 of 100
+[defendants] by ... Congress"). In this case, by reconstituting her original federal
+lawsuit and refiling it in state Court, the plaintiff has clearly sought to avoid the
+strictures of the mandatory stay of this case that federal law requires under 18
+U.S.C. $ 3509(k)?
+In federal court, pursuant to 18 U.S.C. § 3509(k), this action must be
+automatically stayed pending final disposition of an ongoing parallel criminal
+action against Mr. Epstein. See 18 U.S.C. § 3509(k) (providing that a parallel civil
+• By filing in state court, the plaintiff's attorney has also evidently sought to avoid the
+clear command of our local rules forbidding public comment about the merits of a
+pending lawsuit. Compare S.D. Fla. Local Rule 77.2(7) ("A lawyer or law firm
+associated with a civil action shall not during its investigation or litigation make or
+participate in making an extrajudicial statement, other than a quotation from or reference
+to public records, which a reasonable person would expect to be disseminated by means
+of public communication if there is a reasonable likelihood that such dissemination will
+interfere with a fair trial and which relates to (a) Evidence regarding the occurrence or
+transaction involved. (b) The character ... of a party ... (d) The lawyer's opinion as to
+the merits of the claims . . . ."), with Ricci~Leopold Home Page, http://
+www.riccilaw.com (click on "Breaking News," then access the hyperlink entitled,
+03/13/08 - Consumer Justice Attorney Ted Leopold Files Case to aid Jane Doe in seeking
+justice against sexual predator Jeffrey Epstein and his associates. ) (describing character
+of party defendant Epstein as a "sexual predator" (a term defined by Florida criminal
+statutes) and quoting the plaintiff's attorney "Ted Leopold, managing partner" as
+characterizing Epstein as "an extremely powerful and wealthy man," with "vast
+resources," who acted "in the vilest way" at his "lavish mansion" with "lurid fantasies"
+and inflicting "untold damage," and opining that he should "be held accountable;" also
+quoting the plaintiff's attorney as opining that "[this case is both about justice and
+making sure that a wealthy and powerful man knows that he is not above the law;" also
+quoting the plaintiff's attorney's view of the evidence that plaintiff "continues to endure
+emotional trauma daily") (Web site last visited July 17, 2008).
+10
+10 of 316
+
+
+Case 9:08-cv-80804-KAM Document 1 |
+Entered on FLSD Docket 07/21/2008 Page 11 of 100
+action arising from an alleged sexual assault of a minor "shall be stayed until the
+end of all phases of [any] criminal action") (emphasis added). In this case, there is
+a parallel federal criminal grand jury action pending in the Southern District of
+Florida, In re Grand Jury, No. FGJ 07-103(WPB) (S.D. Fla.), which arises out of
+the same allegations pled here. Thus, in resorting to fraudulent joinder, the
+plaintiff has sought to avoid any application of this otherwise controlling statute.
+Cf. Doe v. Francis, No. 5:03 CV 260 MCR/WCS, 2005 WL 517847, at *1-2 (N.D.
+Fla. Feb. 10, 2005) (staying civil diversity action over plaintiffs' objections on
+grounds that "the language of 18 U.S.C. § 3509(k) is clear that a stay is required in
+a case ... where a parallel criminal action is pending which arises from the same
+occurrence involving minor victims") (emphasis added).
+Even outside the context of a mandatory federal statute, "the Supreme Court
+[has] admonished [that] 'the Federal courts should not sanction devices intended to
+prevent a removal to a Federal court where one has that right, and should be
+equally vigilant to protect the right to proceed in the Federal court."" Legg, 428
+F.3d at 1325 (citing Wecker v. Nat'l Enameling & Stamping Co., 204 U.S. 176,
+186 (1907)). See also id. (observing that "Congress " did not extend [to defendants
+a right of removal] with one hand, and with the other give plaintiffs a bag of tricks
+11
+Lewis Tein»..
+3059 GRAND AVENUE, SUITE 340, COCOMUT GROVE, FLORIDA 33133
+11 of 316
+
+
+Case 9:08-cv-80804-KAM Document 1|
+Entered on FLSD Docket 07/21/2008 Page 12 of 100
+to overcome it'' (quoting McKinney v. Bd. of Trustees of Maryland Cmty. Coll.,
+955 F.2d 924, 928 (4th Cir. 1992))).
+To protect a nonresident defendant's right of removal, a federal court will
+"determine the matter of jurisdiction" by examining "the true situation both as to
+parties and causes of action." Bernblum v. Travelers' Inc. Co., 9 F. Supp. 34, 35
+(W.D. Mo. 1934) (emphasis added). See also id. (observing that "[t]he federal
+courts will ... strike out the fiction injected into a case by a party to prevent
+removal"). In accordance with these principles, a plaintiff cannot destroy diversity
+jurisdiction simply by conjuring up a nondiverse defendant; there must be at least
+some "possibility that the state law might impose liability on [the nondiverse]
+defendant under the circumstances alleged in the complaint." Florence v. Crescent
+Res., LLC, 484 F.3d 1293, 1299 (11th Cir. 2007) (citations omitted). See also,
+Holloway v. Morrow, No. 07-0839-WS-M, 2008 WL 401305, at *5 (S.D. Ala. Feb.
+11, 2008) (emphasizing that "[Jhe potential for legal liability must be reasonable,
+not merely theoretical'" (quoting Legg v. Wyeth, 428 F.3d 1317, 1325 n.5 (11th
+Cir. 2005))) (emphasis added).
+In this case, the plaintiffs have tried to whip Jane Doe's original, onedefendant complaint into a froth that looks non-federal. Cf. Owens v. Swan, 962 F.
+Supp. 1436, 1439 (D. Utah 1997) (noting that "although plaintiffs' amended
+12
+3059 GRANO AVEMUK, SUITE 340, CoCOMUT GROVE, FLDMIDA 33133
+12 of 316
+
+
+Entered on FLSD Docket 07/21/2008 Page 13 of 100
+complaint contains four claims for relief, the first and second claims state only one
+cause of action") (emphasis added). Using her original allegations and adding
+nothing, Jane Doe has tried to add claims against
+for civil
+conspiracy (Am. Compl. 19 20-23), Intentional Infliction of Emotional Distress
+(Am. Compl. 19 24-28), and civil RICO (Compl. 99 29-34) in order to append a
+nondiverse defendant to her Complaint. These claims, however, are untenable
+under Jane Doe's own allegations, and therefore cannot be used to destroy
+diversity jurisdiction.
+(b) There is no possibility that the plaintiff can establish a cause of
+action against
+under Florida law.
+(i) The conspiracy claim against Robson must fail.
+As a general rule, "[a]n actionable conspiracy [under Florida law] requires
+an actionable underlying fort or wrong." Wright v. Yurko, 446 So. 2d 1162, 1165
+(Fla. Sth DCA 1984) (citations omitted) (emphasis added).!°
+This case is governed by the general rule. Cf. Churruca v. Miami Jai-Alai, Inc., 353
+So. 2d 547, 550 (Fla. 1977) (noting that while there is "ordinarily ... no independent tort
+for conspiracy," there is a narrow exception to this rule when "the plaintiff can show
+some peculiar power of coercion possessed by the conspirators by virtue of their
+combination") (emphasis added). See generally Liappas v. Augoustis, 47 So. 2d 582, 583
+(Fla. 1950) (observing that "' instances of conspiracy which is in itself an independent tort
+are rare and should be added to with caution'" (quoting Fleming v. Dane, 22 N.E.2d
+609, 611, (Mass. 1939))) (emphasis added). Plainly, this case involves the general rule,
+not the narrow exception, because only one person could have caused Jane Doe's
+injuries. Cf. Martin v. Marlin, 529 So. 2d 1174, 1179 (Fla. 3d DCA 1988) (upholding
+13
+Lewis Teinn.
+3059 GRAND AVENUE, SUITE 340, COCONUT GAOVE, FLORIDA 33133
+13 of 316
+
+
+Entered on FLSD Docket 07/21/2008 Page 14 of 100
+Here, Jane Doe cannot assert a cause of action for "violation of Chapter 800,
+Florida Statutes" (Am. Compl. 9 18) because there is no private right of action
+under that Chapter. See generally Am. Home Assurance Co. v. Plaza Materials
+Corp., 908 So. 2d 360, 374 (Fla. 2005) (observing that "not every statutory
+violation carries a civil remedy" (citing Villazon v. Prudential Health Care Plan,
+Inc., 843 So. 2d 842, 852 (Fla. 2003))). See also, e.g., Miami Herald Publ'g Co. v.
+Ferre, 636 F. Supp. 970 (S.D. Fla. 1985) (King, C.J.) holding that violation of
+Florida's criminal extortion statute does not give rise to a civil cause of action for
+damages); Mantooth v. Richards, 557 So. 2d 646, 646 (Fla. 4th DCA 1990) (per
+curiam) (affirming dismissal of plaintiff's claim for parental kidnapping where
+"the mentioned statutes concern only criminal violations and do not afford a civil
+remedy'") (citation omitted) (emphasis added); Wright v. Yurko, 446 So. 2d 1162,
+1165 (Fla. Sth DCA 1984) (holding that "[a]n act which does not constitute a basis
+for a cause of action against one person cannot be made the basis for a civil action
+for conspiracy").
+In this case, Jane Doe's claim under Count II (civil conspiracy) fails because
+it derives exclusively from Count I (violation of Chapter 800, Florida Statutes). Cf.
+grant of summary judgment against claim for independent conspiracy, noting that
+"[w]hen the concerted acts of the defendants do not create a greater harm than if the act.
+vere committed by one person alone, then there can be no recovery')
+14
+14 of 316
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 15 of 100
+Buchanan v. Miami Herald Publ'g Co., 230 So. 2d 9, 12 (Fla. 1969) (holding that
+where Count I of the complaint had failed to state a cause of action for malicious
+prosecution, there could be no civil-conspiracy claim in Count II "based on the
+allegations of Count I"'). Because the statute she expressly pleads as the basis for
+Count 1, Chapter 800, Florida Statutes, provides no civil remedy, Jane Doe cannot
+prevail on Count I. Therefore, she cannot prevail on her claim for conspiracy
+(Count II) to violate Chapter 800, Florida Statutes (Count I).
+(ii) The plaintiff cannot prevail against nondiverse defendant
+on her claim for Intentional Infliction
+of Emotional Distress (HED).
+Even if the plaintiff, for the sake of argument, can assert an IIED claim
+against Jeffrey Epstein, the plaintiff still does not have a cause of action for lIED
+against
+First, the plaintiff cannot recover damages in connection
+with her own illegal conduct; and second, the plaintiff's purported IIED claim fails
+• as a matter of law.
+15
+
+
+Entered on FLSD Docket 07/21/2008 Page 16 of 100
+1.
+The plaintiff seeks damages in connection with her
+own illegal conduct.
+The plaintiff concedes that she went to Jeffrey Epstein's house "to give
+Epstein a massage for monetary compensation." (Am. Compl. 9| 13.) The plaintiff
+also concedes, in the guise of an allegation, that
+"brought Jane Doe
+to Epstein's mansion in Palm Beach" to help the plaintiff execute her own plan.
+(Am. Compl. 9| 13.) Yet, the plaintiff's plan was illegal: under Florida law, it is a
+crime "to practice massage" without a license. § 480.047, Fla. Stat. (1997). To say
+it another way, the plaintiff admits that she went to Mr. Epstein's house to commit
+a crime.
+Based on these allegations, it is clear that the plaintiff seeks damages in
+connection with her own illegal conduct; this is enough to support a finding of
+fraudulent joinder. See Florence v. Crescent Resources, LLC, 484 F.3d 1293, 1298
+n.3 (11th Cir. 2007) (acknowledging that "under some circumstances, application
+of an affirmative defense can support a finding of fraudulent joinder). This
+conclusion is supported by well-established principles.
+Under Florida law, a plaintiff cannot recover damages flowing from her own
+illegal conduct. See Hall v. Hall, 93 Fla. 709, 112 So. 622, 628 (1927) (referring to
+"the universal rule of our law that one in a court of justice cannot complain ... of
+another's wrong whereof he was a partaker") (internal quotation marks and citation
+16
+
+
+Entered on FLSD Docket 07/21/2008 Page 17 of 100
+omitted) (emphasis added); Turner v. Anderson, 704 So. 2d 748, (Fla. 4th DCA
+1998) ("[NJo public policy should allow appellant to recover damages as a result of
+engaging in criminal conduct such as occurred in this case."). Cf. Ewell v. Daggs,
+108 U.S. 143, 149 (1883) (stating that "'[nJo court will lend its aid to a [plaintiff]
+who founds [a] cause of action upon an immoral or an illegal act'") (quoting
+Holman v. Johnson, 98 Eng. Rep. 1120 (K.B. 1775)); see also id. (explaining that
+this policy is "not for the sake of the defendant, but because [the courts] will not
+lend their aid to such a plaintiff'" (quoting Holman, 98 Eng. Rep. 1120))
+(emphasis added); Balas v. Ruzzo, 703 So. 2d 1076, 1082 (Fla. Sth DCA 1997)
+(Harris, J., concurring) (remarking in the context of an action brought against an
+alleged prostitution house that "the court should continue its tradition of not
+interceding in civil conflicts involving transactions that are either illegal or are
+against public policy").
+Based on the foregoing, the plaintiff cannot blame someone else
+) for the consequences of her own criminal conduct. Cf. Feld & Sons, Inc.
+v. Pechner, Dorfman, Wolffe, Rounick and Cabot, 458 A.2d 545, 552 (Pa. Super.
+Ct. 1983) (holding that law-firm clients could not recover damages flowing from
+their own criminal acts, even though clients' lawyers had suggested the unlawful
+conduct to begin with). See also Turner v. Anderson, 704 So. 2d 748, 751 (Fla. 4th
+17
+3059 GRAND AVENUE, SUITE 340, COCONUT GROVE, FIORIDA 33133
+
+
+Entered on FLSD Docket 07/21/2008 Page 18 of 100
+DCA 1998) (approving reasoning in Feld & Sons, holding that "no public policy
+should allow [a plaintiff] to recover damages as a result of engaging in criminal
+conduct" where the plaintiff had provided false testimony at an arbitration
+proceeding).
+The plaintiff's HED claim fails as a matter of law.
+To state a cause of action for IIED, a complaint must allege four elements:
+(1) deliberate or reckless infliction of mental suffering; (2) outrageous conduct; (3)
+the conduct caused the emotional distress; and (4) the distress was severe. Metro.
+Life Ins. Co. v. McCarson, 467 So. 2d 277, 278 (Fla. 1985). Whether conduct is
+outrageous enough to support a claim of intentional infliction of emotional distress
+is a question of law, not a question of fact. Liberty Mut. Ins. Co. v. Steadman, 968
+So. 2d 592, 595 (Fla. 2d DCA 2007) (citations omitted).
+In this case, without reaching the question of "outrage," the plaintiff has
+failed to show that
+conduct - - allegedly arranging an illegal
+sexual massage that the plaintiff herself agreed to perform - - itself caused the
+plaintiff to suffer any emotional distress. Even if the alleged agreement was
+fraudulently induced, the plaintiff's IIED claim flows from Epstein's alleged
+conduct, not the joint conduct of Robson and Doe in planning the massage.
+18
+3059 GRAND AVENUI, SUITE 340, COCONUT GROVE, FLORIDA 33133
+18 of 316
+
+
+Document
+Entered on FLSD Docket 07/21/2008 Page 19 of 100
+(iii) The plaintiff cannot prevail on her claim for civil remedies
+for criminal practices or racketeering ("civil RICO") pled in
+Count IV.
+A cause of action under section 772.104, Florida Statutes ("Civil Remedies
+for Criminal Practices") requires a showing of direct injury. Even assuming for
+the sake of argument that Jane Doe can establish that the defendants engaged in a
+"pattern of criminal activity," she cannot establish that she was directly injured by
+those activities.
+Section 772.104 allows someone to bring a civil RICO claim only if "he or
+she has been injured by reason of' any RICO violation. § 772.104, Fla. Stat.
+(2007). Here, the allegations in Count IV, even if they are true, do not add up to a
+civil RICO claim because there is no proximate cause between the purported
+"pattern of criminal activity" and Jane Doe's alleged injuries.
+In a doomed attempt to satisfy the extremely high burden of pleading civil
+RICO under Florida law, the Amended Complaint lists a series of violations rooted
+in Florida's prostitution statutes. (Am. Compl. {31.) According to the Amended
+Complaint, the defendants participated in a criminal enterprise ... or conspir[acy]"
+(Am. Compl. 9 30) over an unspecified length of time "to repeatedly find and
+bring [Jeffrey Epstein] underage girls ... in order for Epstein to solicit, coerce,
+entice, compel, or force such girls in acts of prostitution and/or lewdness" (Am.
+19
+Lewis Teinn.
+3059 GRAND AVENUE, SUITE 340, COCONUT GROVE, FLORIDN 33133
+19 of 315
+
+
+Entered on FLSD Docket 07/21/2008 Page 20 of 100
+Compl. 1| 32). The alleged "pattern of criminal activity" comprises violations of
+Chapter 796, Florida Statutes-the chapter that proscribes various crimes of
+prostitution. '
+These allegations do not tie directly into Jane Doe's alleged psychic injuries.
+In contrast to a cognizable RICO claim, this action concerns only an isolated
+occurrence. More important, the alleged injuries in this case are pled to have
+resulted from an alleged sexual assault, an assault "in violation of Chapter 800 of
+the Florida Statutes" (Am. Compl. 9| 18)-not anything having to do with the
+facilitation of prostitution, or more succinctly, the violation of Florida's
+prostitution law.
+Civil RICO claims are extraordinarily difficult to plead successfully. There
+are examples in the case law of RICO claims stemming from a prostitution
+enterprise, but they are vastly different from what plaintiff pleads here. They
+involve, for example, prostitutes who sued a house of prostitution (as an
+"enterprise") for inflicting systematic and repetitive abuse on them, over time. See
+Balas v. Ruzzo, 703 So. 2d 1076, 1077 (Fla. Sth DCA 1997) (offering an example
+of a civil RICO claim against the operators of an alleged "house of prostitution,"
+" The Amended Complaint alleges a "pattern of criminal activity" comprising the
+following criminal violations: §§ 796.03, 796.07(2)(f), 796.07(2)(h), 796.045, and
+796.04, Fla. Stat. (Am. Compl. 931.)
+20
+3059 GRAND AVENUE, SUITE 340, CoCoNUT GROVE, FuCHInA 33133
+20 of 316
+
+
+Entered on FLSD Docket 07/21/2008 Page 21 of 100
+where petitioners alleged that they had "suffered emotional pain, anguish,
+humiliation, insult, indignity, loss of self-esteem, inconvenience, hurt and
+emotional distress" as a result of being forced repeatedly, over time, to "perform
+sexual acts to retain their employment"). Here, even if the Amended Complaint
+can be read to plead that the defendants schemed to solicit other massages from
+other people (see, e.g., Am. Compl. 99 9, 11, 12, 32), those activities are not
+alleged in any way to have impacted Jane Doe. Cf., e.g., Palmas Y Bambu, S.A. v.
+E.I. Dupont De Nemours & Co., Inc., 881 So. 2d 565, 570 (Fla. 3d DCA 2004)
+(holding that "'indirect injuries, that is injuries sustained not as a direct result of
+predicate acts ... will not allow recovery under Florida RICO.'" (quoting
+O'Malley v. St. Thomas Univ., Inc., 599 So. 2d 999, 1000 (Fla. 3d DCA 1992))
+(emphasis added).
+Because the Amended Complaint does not satisfy the direct-injury
+requirement under Florida's RICO law, Jane Doe has failed to allege a cause of
+action against TH
+• for violation of section 772.103, Florida Statutes.
+B. This Notice satisfies the procedural requirements of 28 U.S.C. § 1446.
+1. This notice of removal is timely.
+In accordance with 28 U.S.C. § 1446, this notice of removal is timely. Only
+defendant Epstein has been served with process. Defendants
+21
+3059 GRAND AVENUI, SUITE 340, COCCUT GROVE, FLORIDA 33133
+21 of 316
+
+
+Entered on FLSD Docket 07/21/2008 Page 22 of 100
+have not yet been served. In a multi-defendant lawsuit, removal is timely when
+effected within 30 days after the last defendant is served. See Hill Dermaceuticals,
+Inc. v. RX Solutions, United Health Group, Inc., No. 6:08-cv-330-Orl-31KRS,
+2008 WL 1744794, at *3 (M.D. Fla. Apr. 11, 2008) (concluding that removal
+petition was timely where it was filed within 30 days after the last defendant was
+served).
+2. Notice has been given, and state-court papers have been filed.
+In accordance with 28 U.S.C. § 1446(d), defendants have served this Notice
+of Removal on July 18, 2008. All papers filed in State Court are attached to this
+Removal Petition.
+3. There is unanimity among the defendants.
+In accordance with 28 U.S.C. § 1446(b) the undersigned are authorized to
+represent that all of the defendants join this Petition and consent to removal.
+Conclusion
+Because this is a civil action between citizens of different states, excluding
+any fraudulently joined parties, and the amount in controversy exceeds $75,000,
+exclusive of interests and costs, this Court has original jurisdiction over this action
+pursuant to 28 U.S.C. § 1332(a)(1).
+22
+3059 GRAND AVENUE, SUITE 340, COCOMUT GROVE, FLORIDA 33133
+22 of 316
+
+
+
+WHEREFORE, the Defendants, Jeffrey Epstein, S
+and
+remove this case from Palm Beach Circuit Court to the United States
+District Court for the Southern District of Florida.
+Respectfully submitted,
+LEWIS TEIN, P.L.
+3059 Grand Avenue, Suite 340
+Coconut Grove, Florida 33133
+Tel: 305 442 1101
+Fax: 305 442 6744
+By:
+Wilh Toi
+GUY A. LEWIS
+Fla. Bar No. 623740
+MICHAEL R. TEIN
+Fla. Bar No. 993522
+ATTERBURY, GOLDBERGER & WEISS, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, Florida 33401
+Tel. 561 659 8300
+Fax. 561 835 8691
+By:
+Jack A. Goldberger
+Fla. Bar No. 262013
+Attorneys for Defendant Jeffrey Epstein
+23
+23 of 316
+
+
+Entered on FLSD Docket 07/21/2008 Page 24 of 100
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that the foregoing document is being served this day,
+July 18, 2008, on counsel of record identified on the service list by U.S. Mail.
+willie:
+Michael R. Tein
+24
+24 of 316
+
+
+Entered on FLSD Docket 07/21/2008 Page 25 of 100
+Service List
+Theodore J. Leopold, Esq.
+Ricci-Leopold, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+Fax: 561 697 2383
+Counsel for Plaintiff Jane Doe
+Douglas M. Mcintosh, Esq.
+Jason A. McGrath, Esq.
+McIntosh, Sawran, Peltz & Cartaya, P.A.
+Centurion Tower
+1601 Forum Place, Suite 1110
+West Palm Beach, Florida 33401
+Fax. 561 682-3206
+Counsel for Defendant
+Bruce E. Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, Florida 33401
+Fax. 561 828 0983
+Counsel for Defendant
+Robert D. Critton, Esq.
+Michael J. Pike, Esq.
+Burman, Critton, Luttier &
+Coleman, LLP
+515 N. Flagler Drive, Suite 400
+West Palm Beach, Florida 33401
+Fax. 561 515 3148
+Co-Counsel for Jeffrey Epstein
+25
+3059 GRANO AVENUE, SUITE 340, COCONUT GROVE, FIORIDA 33133
+25 of 316
+
+
+
+
+26 of 316
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 27 of 100
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CASE NO. 2006 CF09454AXX
+STATE OF FLORIDA,
+-vS-
+JEFFREY EPSTEIN,
+Defendant.
+DEPOSITION OF
+!
+Wednesday, February 20, 2008
+2:00 p.m. - 4:30 p.m.
+Palm Beach County Courthouse
+205 North Dixie Highway
+West Palm Beach, Florida 33401
+CoPy
+Reported By:
+Judith F. Consor, FPR
+Notary Public, State of Florida
+Consor & Associates Reporting and Transcription
+Phone - 561.682.0905
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+27 of 316
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 28 of 100
+Page 2
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+22
+24
+25
+APPEARANCES:
+On behalf of the State:
+LANNA BELOHLAVEK, ESP.
+ASSISTANT STATE ATTORNEY
+401 North Dixie Highway
+West Palm Beach, Florida 33401
+561.355.7100
+on behalf of the Defendant:
+MICHAEL R. TEIN, ESP.
+KATHRYN A. MEYERS, ESQ.
+LEWIS TEIN, PL
+3059 GRAND AVENUE, SUITE 340
+COCONUT GROVE, EL 33133
+On behalf of the Defendant:
+JACK A. GOLDBERGER, ESQ.
+AFTERBURY, GOLDBERGER & WEISS
+250 AUSTRALIAN AVENUE SOUTH
+SUITE 1400
+WEST PALM BEACH, FLORIDA 33401
+561.659.8300
+ALSO PRESENT:
+ON BEHALE OF THE WITNESS: THEODORE J. LEOPOLD, ESQ.
+KEITH J. BRETT, DIRECTOR OF MULIIMEDIA DIVISION,
+LEGAL-EZE
+-
+-
+-
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+28 of 316
+
+
+Resument 1 Entered on FLSD Docket 07/21/2008 Page 29 of 100
+Reporting anel Transeripcinn, Inc.
+Page 3
+1
+2
+3
+INDEX
+WITNESS:
+DIRECT EXAMINATION
+BY MR. TEIN:
+PAGE:
+4
+4
+5
+7
+8
+9
+10
+11
+12
+-
+NO EXHIBIIS MARKED
+-
+-
+....IDQU.
+Page
+53
+55
+59
+111
+112
+Line
+22
+1
+2
+14
+2
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+29 of 310
+
+
+Dolment 1 Entered on FLSD Docket 07/21/2008 Page 30 of 100
+1.
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 4
+Deposition taken before Judith F. Consor,
+Court Reporter and Notary Public in and for the State of
+Florida at Large, in the above cause.
+- - -
+Thereupon,
+having been first duly sworn or affirmed, was examined
+and testified as follows:
+THE WITNESS: I do.
+DIRECT EXAMINATION
+BY MR. TEIN:
+e.
+Good afternoon. Please tell me your full
+name.
+A.
+e.
+A.
+And can you please spell it.
+Q.
+Thank you.
+May I call you
+A.
+Uh-huh.
+e.
+I'm going to ask you a few
+questions, several questions today. If at any time you
+wan: to take a break, you just let me know. Okay?
+A.
+Okay.
+l. If you at any time don't understand one of
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+30 of 316
+
+
+galont1 Entered on FLSD Docket 07/21/2008 Page 31 01100
+Konorting and Transcripies, Ine.
+Page 5
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+my questions, will you just please let me know?
+A.
+Yes.
+e. And if at any time you're not feeling well
+or something like that, you'll tell us, right?
+A.
+Yes.
+e. Do you feel okay today?
+A.
+Yes.
+Not taking any alcohol or drugs or anything
+like that, right?
+A.
+No.
+e.
+So you feel ready to have your deposition
+taken?
+A.
+Yes.
+what is your address?
+A.
+I'm currently living at my aunt's house and
+I don't know it off the top of my head.
+R.
+Where is it?
+A.
+In Jupiter.
+e.
+Who is your aunt?
+A.
+R.
+A.
+Who else is living there?
+my uncle.
+Anyone else living there?
+A.
+No.
+The contempt motion that your mother filed
+Ph. 561.682.0905 - Fax. 561.682,1771
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+31 of 310
+
+
+!
+Getlgent1 Entered on FLSD Dockat 07121/2008 Page 32of 100
+• Reporting and Transcripsien, Inc.
+1
+2
+4
+Page 6
+against your father regarding your fifty million-dollar
+lawsuit against Jeffrey Epstein says that you live with
+your aunt and uncle and have been living there; is that
+correct?
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+Yes.
+9. How long have you been living with your
+aunt and uncle?
+A.
+Since my father kicked me out.
+e.
+That was Thanksgiving of this past year?
+A. Yes, sir.
+e.
+Okay. Didn't your firefighter boyfriend
+get an apartment for the two of you?
+A.
+No, sir. He has an apartment, but by
+himself.
+Did he get an apartment for the two of you
+to live in?
+A.
+No, sir.
+Are you planning to move in with him?
+A.
+Maybe one day in the future.
+1.
+Do you have a plan to move in with him
+presently?
+A. No.
+e.
+Have you been to the apartment that you and
+have discussed moving in together?
+A.
+I have been to the apartment.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+32 of 316
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 33 of 100
+Cansor & Associates
+Reporting anal Transcripting, Ine.
+Page 7
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+....
+33 of 315
+A.
+Q.
+A.
+0.
+A.
+Where is that?
+Palm Beach Lakes.
+Have you spent the night over there?
+No, sir.
+Do you know the address there?
+I do not.
+Isn't your sister
+planning on living
+?
+with you and
+A.
+No.
+in you know that this court case is a
+criminal prosecution, correct?
+A.
+Correct.
+And you know that it's a criminal
+prosecution against a man who has no criminal background.
+Do you know that?
+A.
+I do now.
+e.
+You agree that court is a very serious
+matter?
+A.
+Yes.
+e.
+And you're here with your lawyer
+Mr. Leopold, right?
+A.
+Yes.
+And you know that Mr. Leopold recently
+filed a lawsuit in federal court against Jeffrey Epstein,
+seeking fifty million dollars.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+
+
+Dadument 1 Entered on FLSD Docket 07/21/2008
+
+A Asociates
+Reporting and Transcription, Inc.
+Page 8
+1
+2
+3
+4
+5
+6
+MR. LEOPOLD: Let me just object.
+let me instruct you. Anything that
+you have learned through conversations between you
+and me are protected. So if you know any of that
+information outside of those discussions, you may
+answer. But if the only way you know it is
+through our discussions, do not answer that
+question.
+BY MR. TEIN:
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+you know that MI. Leopold recently
+filed a lawsuit in federal court on your behalf against
+Jeffrey Epstein seeking fifty million dollars?
+MR. LEOPOLD: Same objection.
+If you know the answer to that outside of
+our discussions, you may answer. If it is the
+only way that you know the answer is through our
+discussions, do not answer that question.
+THE WITNESS: Okay.
+MR. LEOPOLD: Attorney/client privilege.
+BY MR. TEIN:
+e.
+You can answer the question unless --
+MR. LEOPOLD: Same objection.
+MR. TEIN: Let me finish.
+MR. LEOPOLD: Excuse me. We're --
+MR. TEIN: No. Let me finish.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+34 or 316
+
+
+Ratument 1 Entered on FL$D Docket 07/21/2008 Page 35 of 100
+Reparing and Transcripsion, Inc.
+Page 9
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+MR. LEOPOLD: Lewis, we're not going to do
+that.
+MR. TEIN: My name is not Lewis.
+I'm going to finish my question. Okay?
+MR. LEOPOLD: Do not answer until you hear
+from me.
+BY MR. TEIN:
+Other than conversations that you have had
+with Mr. Leopold -- I'm not asking about that -- are you
+aware that Mr. Leopold has filed a lawsuit in federal
+court seeking fifty million dollars from Jeffrey Epstein
+on your behalf?
+MR. LEOPOLD: Same objection.
+Anything that you learn through
+conversations between you and me, do not answer.
+Those are protected. If you know through any
+other realm of knowledge, you may answer.
+THE WITNESS: No.
+BY MR. TEIN:
+21
+22
+23
+24
+25
+You have no idea that Mr. Leopold filed a
+fifty million-dollar lawsuit on your behalf against
+Jeffrey Epstein?
+MR. LEOPOLD: Same objection.
+Do not answer that question if it's through
+discussions that you and I had. Outside of that,
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+35 of 316
+
+
+Dadment 1 Entered on FLSD Docket 07/21/2008 Page 36 of 100
+Reporsing and Transcription, Inc.
+Page 10
+you may answer. So do not answer that question if
+that is the only basis by which you understand
+that answer.
+THE WITNESS:
+No.
+BY MR. TEIN:
+...'
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+You didn't know that?
+MR. LEOPOLD: Don't answer that question.
+Again, it's attorney/client privilege. Any
+information you've learned through conversations
+between you and I are protected. If you know it
+through any other realm, you may answer.
+MR. TEIN: Are you going to say that for
+every question in the deposition, Mr. Leopold?
+MR. LEOPOLD: When you ask improper
+questions like that without the proper --
+MR. TEIN: You're going to stop your
+speaking objections right now. Okay?
+MR. LEOPOLD: Without the proper --
+MR. TEIN: You need to stop your speaking
+objections.
+Let's continue.
+MR. LEOPOLD: Counsel, you just asked me a
+question and I'm going to state it on the
+record --
+MR. TEIN: You need to stop your speaking
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+38 or 316
+
+
+Rodyment 1 Entered on FLSD Docket 07/21/2008
+Reporing and Transcripsiren, Ine.
+
+Page 11
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+objections. Check your rules.
+MR. LEOPOLD: Excuse me. For the record,
+Counsel asked me a question. I'll state the
+answer on the record. He asked me the question am
+I going to be answering that way throughout the
+deposition. So long as there's improper
+foundation and predicate asked by the attorney, I
+will protect my client and I make the record where
+appropriate. If counsel wishes to ask an
+appropriate worded question with the proper
+foundation and predicate, I will certainly allow
+the client to answer the question.
+MR. GOLDBERGER: Why don't you just state
+attorney/client privilege and just be done with
+it?
+MR. LEOPOLD: I want the record to be
+clear.
+MR. TEIN: You want to waste time is what
+you want to do.
+You were supposed to be here this morning
+and you totally broke the deal, the agreement that
+you had with us if your hearing got cancelled.
+But let's move on and maybe you'll stop
+obstructing this deposition.
+MR. LEOPOLD: I think the record is very
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+37 of 316
+
+
+Dodument 1 Entered on FLSD Docket 07/21/2008 Page 38 of 100
+| Heporting one Transcription, Inc.
+Page 12
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+clear where we stand thus far.
+Is there a recording taken of this
+deposition?
+THE COURT REPORTER: Yes.
+MR. LEOPOLD: Just make sure that's
+preserved.
+BY MR. TEIN:
+Go to Exhibit 20-01 - well, before you do
+that,
+are you aware that a lawyer named Jeffrey
+Herman filed a lawsuit on your behalf, yes or no?
+MR. LEOPOLD: Objection.
+Any conversations that you and I have had
+regarding that, if that is the only way by which
+you understand how to answer that question, do not
+answer. It's attorney/client privilege, as well
+as any conversations you may have had with the
+attorney from Miami. That is also attorney/client
+privilege. And I'm assuming --
+MR. TEIN: You're actually wrong about the
+attorney/client privilege.
+MR. LEOPOLD: I'm assuming Counsel is not
+asking you to divulge attorney/client --
+MR. TEIN: Of course not.
+BY MR. TEIN:
+R.
+are you aware that Jeffrey Herman,
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+38 of 316
+
+
+Daument 1 Entered on FLSD Docket 07/21/2008 Page 39 of 100
+Reporing and Transcription, Ine.
+Page 13
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an attorney, filed a fifty-million-dollar lawsuit on your
+behalf against Jeffrey Epstein, yes or no?
+MR. LEOPOLD: Same objection.
+MR. TEIN: We've heard the objection 10
+times already.
+MR. LEOPOLD: Counsel, excuse me.
+MR. TEIN: Just say attorney/client
+privilege. Stop interrupting my questions.
+MR. LEOPOLD: I'm entitled to make an
+objection for the record, which I'm doing, and
+I'll make the same objection. And if it calls for
+attorney/client privilege, any conversations you
+and I have had, do not answer the question.
+And I think that it might be appropriate,
+for the record, to ask questions via
+as opposed to
+I think that
+would be more appropriate for this deposition.
+BY MR. TEIN:
+e.
+A.
+e.
+Go ahead.
+Please answer yes or no.
+Yes.
+Thank you.
+In fact, you know that Mr. Herman held a
+press conference after he filed the fifty-million-dollar
+lawsuit on your behalf, don't you?
+A.
+After it happened.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+39 of 315
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 40 of 100
+nor & Associates
+Page 14
+:
+1
+2
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+0.
+You know that he had a press conference,
+don't you, yes or no?
+A.
+Yes.
+e.
+In fact, let's go to Exhibit 20-01.
+MR. GOLDBERGER: Look behind you. You'll
+see it.
+BY MR. TEIN:
+Have you ever seen that picture before?
+A.
+Yes.
+l. Is that a picture of your father, your
+stepmother and Mr. Herman at the press conference
+regarding your lawsuit?
+A. Yes.
+Now you know that this is a very serious
+matter, don't you?
+MR. LEOPOLD: Asked and answered.
+objection.
+MR. GOLDBERGER: All right. You can
+object. You're representing a witness here,
+MI. Leopold. You can object on privilege grounds.
+You cannot make legal objections. You have no
+standing to do so.
+MR. LEOPOLD: I'm going to make them and
+then --
+MR. GOLDBERGER:
+We're --
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+40 of 318
+
+
+Dollment 1 Entered on FLSD Docket 07/21/2008
+
+Reporting and Transcription, Inc.
+...
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+...
+Page 15
+MR. LEOPOLD: We're going to leave or we're
+going to take a break, because his demeanor is not
+appropriate. There's no reason to have this kind
+of demeanor. If you want to have this kind of
+demeanor with me --
+MR. TEIN: You are obstructing this
+deposition.
+MR. GOLDBERGER: Why don't you guys go
+outside and just talk about --
+MR. LEOPOLD: She -- her job is very
+difficult and she's not going to be able to take
+us both talking at the same time.
+MR. GOLDBERGER: Off the record.
+MR. LEOPOLD: We're not going off the
+record, Jack. We're not, Jack. Her job is very
+difficult. I'm going to make the record.
+I don't think it is appropriate, especially
+in the small confines of this room, to be very
+aggressive with this young lady.
+MR. TEIN: That's not happening. Stop,
+stop actually -
+MR. LEOPOLD: If you're going to interrupt
+me, we're going to cancel this deposition -
+MR. TEIN: Stop misrepresenting.
+THE COURT REPORTER: I need one at a time,
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+41 ot 310
+
+
+Dagliment 1 Entered on FLSD Docket 07/21/2008 Page 42 of 100
+Page 16
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+no matter who it is.
+MR. IEOPOLD: I think we're going to take a
+break. Perhaps you might want to talk to your
+co-counsel --
+MR. TEIN: I don't need to talk to him.
+MR. LEOPOLD: But we're going to take a
+break.
+MR. TEIN: We're not taking a break unless
+the witness needs a break.
+You're obstructing this deposition, Ted.
+MR. LEOPOLD: Come on,
+You all want to continue in this
+demeanor --
+MR. TEIN: You're obstructing the
+deposition. Stop making speeches. We're not
+discussing this with you. The questions are to
+your client. Go take your five-minute break.
+MR. LEOPOLD: Fine. We need to make sure
+the record's clear and clean.
+And I want to make sure, as I've already
+asked you -- I know that you're one of the best in
+town -- that this audio -- this needs to be
+preserved. Okay?
+MR. TEIN: Go take your five-minute break,
+Mr. Leopold, now.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+42 of 316
+
+
+Dasument 1 Entered on FLSD Docket 07/21/2008
+pi Reporting and Transcripsino, Inc.
+
+Page 17
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+You were supposed to be here at nine a.m.;
+it's now after two. Take your break and come
+back.
+MR. LEOPOLD: Okay. If the demeanor keeps
+up, we will not be here beyond those five minutes.
+MR. TEIN: Take your break and come back.
+MR. LEOPOLD: Okay. So I suggest that you
+relax.
+MR. TEIN: I suggest that you take your
+break.
+MR. GOLDBERGER: Let them take that
+five-minute break.
+take deep breaths.
+take a break.
+MR. LEOPOLD: But I would suggest that you
+MR. TEIN: Suggest whatever you want. Go
+(Thereupon, a recess was taken.)
+BY MR. TEIN:
+Q.
+you agree that giving testimony
+today at your deposition is something very serious, don't
+you?
+A.
+A.
+Yes.
+Yes.
+And you respect the court, don't you?
+Let me show you Exhibit 31-001. Can you
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+43 of 316
+
+
+no 820 07212000 Pa 0 100
+Page 18
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+read that out loud, please.
+A.
+Okay. What do you want?
+e.
+Will you read that out loud, please.
+A.
+oh.
+e.
+Thank you.
+A.
+Lol hah my baddd...101 yah i got some
+stupid court shit on the 20th...bullshit...and damn you
+still have court shit with him? Like after so long wow
+im sorry... well yah well we will definitely havta make
+plans for sure. because i miss u tons times a million and
+no no no i love you...o and p.s. i love ur default pic
+niggaa. Muah xo.
+e. Did you send that message last week to a
+friend of yours on Myspace?
+A. I wouldn't know. There's no dates and I've
+deleted that Myspace, so -
+We're going to talk about that in a second.
+A. Okay.
+Did you send that message last week --
+A.
+Right.
+Let me finish my question.
+Did you send that message last week to a
+friend of yours on MySpace?
+A.
+I wouldn't know the date, but obviously,
+it's to a friend.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+14 of 316
+
+
+Datidment 1 Entered on FLSD Docket 07/21/2008 Page 45 of 100
+I Reporting and Transcrintion, Inc.
+Page 19
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Did you send that message to a friend of
+yours on MySpace?
+A.
+Sure, yes.
+Were you referring to this deposition?
+A.
+Yes.
+Do you find the term n-i-g-g-e-r offensive?
+A.
+e.
+That's not anywhere in there.
+What word did you use in there?
+MR. LEOPOLD: Where are you referring to;
+Counsel? There's 20 plus words in there.
+MR. TEIN: Don't make a speaking objection.
+THE WITNESS: Are you referring to
+anything --
+MR. LEOPOLD: No,
+Don't -- don't --
+let him ask you the question.
+BY MR. TEIN:
+e.
+What question were you asking,
+MR. LEOPOLD: She doesn't ask questions.
+You ask the questions. What is the question
+pending?
+BY MR. TEIN:
+what is the last word on there in
+the text of your message before the closing?
+A.
+Niggaa.
+e: Don't you find that term offensive?
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+45 of 316
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Dagiment 1 Entered on FLSD Docket 07/21/2008 Page 46 of 100
+• Reporing and Transeripsion, Inc
+Page 20
+A.
+No.
+MR. LEOPOLD: Can you spell it for the
+record, please.
+THE WITNESS: N-i-g-g--
+MR. TEIN: No, no, no. You are not going
+to be asking questions.
+MR. LEOPOLD: I'm not asking questions.
+I'm asking for the record the word to be spelled,
+because we don't have a video here today.
+MR. TEIN: These exhibits are part of the
+record. You --
+MR. LEOPOLD: Well, it's not marked as an
+exhibit.
+MR. IEIN: Stop interrupting me,
+Mr. Leopold. I have marked and identified as an
+exhibit and you will get it.
+MR. IEOPOLD: There has been no
+identification of this document in the record.
+MR. TEIN: Mr. Leopold, stop interrupting
+this deposition.
+MR. LEOPOLD: What is the exhibit number
+marked for identification?
+MR. TEIN: 31-001.
+MR. LEOPOLD: Do we have copies? Is it on
+the record anywhere?
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+48 of 318
+
+
+Doldument 1 Entered on FLSD Docket 07/21/2008 Page 47 of 100
+M? Reporting and Transcription, Inc
+Page 21
+.....
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY MR. TEIN:
+Q. m
+Let me ask you,
+did you in fact
+write your friend this message about this deposition?
+A.
+Yes.
+l. So you wrote your friend that this
+deposition is stupid court s-h-i-t, correct?
+A.
+Yes.
+Because you think this deposition is stupid
+court s-h-i-t, don't you?
+A.
+No.
+You wrote that to your friend, didn't you?
+A.
+R.
+Yes.
+You think that court is stupid, don't you?
+A. In some cases.
+And you think that court is bull s-h-i-t,
+don't you?
+A.
+No.
+e. And you think this deposition is bull
+s-h-i-t, don't you?
+A.
+No.
+e.
+You wrote that to your friend, didn't you?
+MR. LEOPOLD: Objection. Asked and
+answered.
+MR. TEIN: That's not an objection.
+BY MR. TEIN:
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+47 of 316
+
+
+Dad ment 1 Entered on FLSD Docket 07/21/2008
+TRoporting and Transcription, Inc.
+
+Page 22
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+• 19
+20
+21
+22
+23
+24
+25
+•
+e.
+You wrote that to your friend, didn't you?
+MR. LEOPOLD: Objection. Asked and
+answered, for the fourth time.
+MR. TEIN: You are improperly objecting,
+Mr. Leopold. You have no grounds to object. And
+that's not an objection.
+MR. LEOPOLD: It is an objection.
+MR. TEIN: Then terminate the deposition if
+you think it's been asked and answered.
+MR. LEOPOLD: Counsel, I am not precluded
+from just making an objection to the form of the
+question. As the courts well know, and if you
+practice here in West Palm Beach, many of the
+judges require you to set the objection with
+specificity. And I will do that. And if you
+don't want me to, you can make the record. But I
+will do that.
+MR. TEIN: Here's what we'll do, Ted. You
+can -- I will allow you to reserve an objection to
+form for every single one of my questions.
+otherwise, all you're doing is obstructing.
+MR. LEOPOLD: I won't do that.
+MR. TEIN: Of course; because you want to
+obstruct.
+MR. LEOPOLD: All right.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+48 of 316
+
+
+Dolidpent 1 Entered on FLSD Docket 07/21/2008 Page 49 of 100
+2022 Reporting onil Transcription, Inc.
+Page 23
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY MR. TEIN:
+you think that giving testimony
+today, under oath, is bull s-h-i-t, don't you?
+A. No.
+0. And you wrote that to your friend on
+Myspace last week, didn't you?
+MR. LEOPOLD: Objection. Asked and
+answered.
+THE WITNESS: No, I did not.
+BY MR. TEIN:
+A.
+You didn't write this exhibit?
+I wrote that, but I didn't write what you
+said.
+2.
+You wrote in this exhibit, "I got some
+stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't
+you write that?
+A.
+Yes.
+Referring to this deposition, didn't you?
+A.
+Referring to the court. I was later
+informed that it was a deposition.
+I'm going to ask you some questions now
+about what happened when you went to Jeff Epstein's house
+three years ago. Okay?
+A.
+Uh-huh.
+e.
+When the police interviewed you one month
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+49 of316
+
+
+Dogyment 1 Entered on FLSD Docket 07/21/2008 Page 50 of 100
+Cõnsor & Associates
+12 Hoporning and Transcription, Inc.
+-
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+:21
+22
+23
+24
+25
+Page 24
+after you went to Epstein's house, you swore on your
+mother's grave that you and Epstein did not engage in sex
+of any kind?
+A.
+Yes.
+Didn't you tell that to the police?
+A. Yes. And I will continue. I have never
+had sex with him.
+Did what happened upstairs at Jeff
+Epstein's house take you completely by surprise,
+A.
+Yes.
+Now the civil complaint that you filed
+against Mr. Epstein for fifty million dollars alleged
+tha: you were totally shocked by what happened when you
+got there.
+A.
+Yes.
+Were you totally shocked by what happened
+when you got to Epstein's house?
+A.
+Yes.
+e.
+You didn't expect it at all, did you?
+A. No.
+e. You had absolutely no idea why your friend
+was taking you to Epstein's house, right?
+A. I was informed it was a massage.
+Q. All you thought that it was going to be was
+a massage, correct?
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+50 of 316
+
+
+Rpgument 1 Entered on FLSD Docket 07/21/2008 Page 51 of 100
+77m Honorting and Transcripcion, Inc.
+. Page 25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+: 10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+Yes.
+e. Before you got to Epstein's house
+never said anything to you on the telephone about sexual
+activity with Epstein, did she?
+A.
+No.
+l. And before you got to Epstein's house
+never sent you a message over the Internet about
+sexual activity with Epstein, did she?
+A. No.
+e. Did
+ever try to convince you to
+engage in any sexual activity with Epstein?
+A. No.
+e. Did
+every try to convince
+you to engage in any sexual activity with Epstein?
+A.
+I don't know who
+is.
+e. Do you have a friend
+A. No.
+Okay. Before you went so Epstein's house
+did anyone call or e-mail you to induce you to engage in
+sexual activity with Epstein?
+A. No.
+R.
+So you're sure that before you got to
+Epstein's house no one tried to persuade you to engage in
+sexual activity with Jeffrey Epstein?
+A.
+No.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+51 of 316
+
+
+Disarment 1 Entered on FLSD Docket 07/21/2008 Page 52 of 100
+Reporting and Transcripsion, Ine.
+Page 26
+You're sure that - let me ask the question
+1
+2
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+again.
+You're sure that before you got to
+Epstein's house no one tried to persuade you to engage in
+sexual activity with Epstein for money. Are you?
+MR. LEOPOLD: Objection. Asked and
+answered.
+THE WITNESS: No. And I've already
+answered that a bazillion times.
+BY MR. TEIN:
+e.
+the question -
+He's coaching you now. So I'm going to ask
+MR. LEOPOLD: Counsel, I've made an
+objection for the record.
+MR. TEIN: Stop speaking.
+MR. LEOPOLD: I'm not going to stop
+speaking. You can't interrupt me when I'm making
+the record.
+MR. TEIN: You're coaching the witness.
+MR. LEOPOLD: Counsel --
+MR. TEIN: Stop coaching the witness.
+BY MR. TEIN:
+e.
+let me ask you -
+MR. LEOPOLD: If you continue to --
+MR. TEIN: Stop interrupting my questions.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+52 of 316
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 53 of 100
+Reposing and Transcripsins, Inc.
+Page 27
+1
+2
+3
+4
+5
+6
+MR. LEOPOLD: If you do it one more time,
+we're leaving.
+BY MR. TEIN:
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR. LEOPOLD: I'm going to make the record.
+You cannot interrupt me when I'm making the
+record. Out of professional conduct, you cannot
+do that. I'm entitled to make the record. I made
+an objection, asked and answered. Your demeanor
+is inappropriate. You're willing and you are able
+and you're responsible to ask a question in a
+professional manner, and ask the question and once
+you get the answer, to either follow up on it or
+move on, but not continuously browbeat and ask the
+same question over
+and over because you don't like
+the answer.
+MR. TEIN: Calm down, sir.
+MR. LEOPOLD: Trust me, I'm very calm here.
+When I'm not calm, you'll know it. I'm very calm.
+So please continue on. But I will not
+allow you to continue to harass her in the
+demeanor that you're doing. Ask her a question
+and move on.
+MR. TEIN: Are you done?
+MR. LEOPOLD: Thank you. I am.
+1655 Palm Beach Lakes Bivd., Suite 500 - West Palm Beach, FL 33401
+53 of316
+
+
+I Ental on F. Doe 0721208 Page 5905100
+Reporing and Transcripsion, Inc..
+Page 28
+MR. TEIN: Stop misrepresenting the record
+and calm down. I'm going to ask my question.
+Stop it.
+BY MR. TEIN:
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR. LEOPOLD: I think the record is very
+clear.
+MR. GOLDBERGER: Let me just clarify
+something. When you object to the form of a
+question, you're not instructing the witness not
+to answer the question, are you?
+MR. LEOPOLD: No. And I'm not making that
+objection; only on attorney/client privilege.
+MR. TEIN: Will you stop speaking now so I
+can ask my question? Are you done?
+Okay. I'm going to ask my question.
+BY MR. TEIN:
+Listen,
+MR. LEOPOLD:
+Hold on. Stop.
+I've been doing this for 20 plus years and
+have met a lot of attorneys, but I've never had an
+experience like this where I've --
+MR. TEIN: Stop your speeches.
+MR. LEOPOLD: If you continue to do this,
+whether it's with me or with my client, I will not
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+54 of 316
+
+
+Dacument 1 Entered on FLSD Docket 07/21/2008 Page 55 of 100
+ēnsor & Associates
+Reporting one Transcription, Inc.
+1
+2
+3
+4
+5
+6
+7
+8
+Page 29
+put up with it and I don't need to put up with it
+and it's not appropriate. And I'm sure
+Mr. Goldberger knows all this, because I know that
+he wouldn't do this. So I will not put up with
+it. And I think it's highly inappropriate to do
+this with this child sitting here, the way you're
+acting, primarily towards me, and I will not put
+up with it.
+MR. TEIN: Will you please stop your speech
+so I can ask questions?
+MR. LEOPOLD: So long as you act
+professionally, I will do so. But if you continue
+to do it this way, I will leave.
+MR. TEIN: Suit yourself.
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY MR. TEIN:
+e.
+are you sure that before you got to
+Epstein's house no one tried to persuade you to engage in
+sexual activity with Epstein for money?
+MR. LEOPOLD: Asked and answered.
+objection.
+MR. TEIN: Did you get her answer?
+THE COURT REPORTER: No, I did not.
+THE WITNESS: I'm sure.
+BY MR. TEIN:
+Let me ask you a few questions about your
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+55 of 316
+
+
+Doçument 1 Entered on FLSD Docket 07/21/2008 Page 56 of 100
+so Amisociates
+1 Reporting aud Transcription, Inc.
+Page 30
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+contact with Jeffrey Epstein. Okay?
+A.
+(Witness nods head up and down.)
+Jeff never e-mailed you, did he?
+A.
+8.
+A.
+e.
+No.
+Jeff never text messaged you, did he?
+No.
+Jeff never chatted in a chat room with you,
+did he?
+A. No.
+e. Before you got to Epstein's house you had
+never spoken to Jeff, had you?
+A. No.
+e. And before you got to Epstein's house you
+had never met Jeff?
+A.
+Correct.
+Before you got to Epstein's house you had
+never told Jeff that you were under 18, right?
+A.
+No.
+e.
+Before you got to Epstein's house had you
+ever told Jeffrey that you were under 18?
+A.
+No. I never spoke to the man before that.
+e. And you only went to Jeff Epstein's house
+that one time three years ago, correct?
+A.
+Yes.
+You never went there again, correct?
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+56 of 318
+
+
+Ragument 1 Entered on FLSD Docket 07/21/2008 Page 57 of 100
+2 Reporting and Transcripcien, Inc.
+Page 31
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+No.
+l. All right. Let me ask you two final areas
+of questioning about this and we'll move onto something
+else. Okay?
+A.
+Uh-huh. Yes. I'm sorry.
+e. Before you got to Epstein's did anyone
+associated with Epstein ever call you on the phone and
+try to persuade, induce, entice or coerce you to engage
+in any sexual activity?
+A. No.
+2. Before you got to Epstein's did anybody
+associated with Epstein ever contact you on the Internet
+and try to persuade, induce, entice or coerce you to
+engage in any sexual activity?
+A.
+No.
+who told you that when you got to
+Jeff Epstein's house you should lie to jeff about your
+age?
+A.
+0.
+Was it
+or was it the other girl in
+the car who you rode over with to Epstein's house?
+A.
+e.
+Who was the other girl in the car with you
+that day?
+A.
+I honestly don't know.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+57 of 316
+
+
+Entered on FLSD Docket 07/21/2008 Page 58 of 100
+Roporting and Transcription, Ine.
+Page 32
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+Had you ever seen her before?
+No, sir.
+You told the police that when you rode over
+to Epstein's you had no idea who she was, right?
+A.
+Correct.
+You told the police that you didn't know
+her name, but she was like really dark, kind of like a
+Spanish girl?
+A.
+e.
+A.
+Yes.
+Those were your words, right?
+Yes.
+Do you now know who she is?
+A. No, sir.
+So it was
+who told you to lie about
+your age to Jeff Epstein?
+A. Yes, sir.
+And
+told you that if you weren't 18,
+Epstein wouldn't let you into his house, right?
+A.
+That's - yes, yes.
+e. All right. Let's talk for a minute about
+when you first met Jeff. Okay?
+A.
+Sure.
+e. When you first met Jeff he tried to find
+out how old you were, right?
+A.
+Excuse me?
+1655 Palm Beach Lakes Bivd.; Suite 500 - West Palm Beach, FL 33401
+58 of 316
+
+
+Rayment 1 Entered on FLD Docket 07/21/2008 Page 59 of 100
+* Reporting one Transcription, Inc.
+Page 33
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+R.
+When you first met Jeff he tried to find
+out how old you were, right?
+A.
+Not when we first introduced each other;
+when we get upstairs, then, yes.
+During the massage Jeff asked you how old
+you were, correct?
+A.
+Yes, yes.
+0.
+Now hadn't you already told Jeff's
+assistant, the one who walked you upstairs, that you went
+to college and had just moved down here from Ohio?
+A.
+I never spoke to the lady.
+9. Do you want to rethink that answer?
+MR. LEOPOLD: Is that a question?
+BY MR. TEIN:
+e.
+A.
+Do you want to rethink that answer?
+No. I didn't really speak with her that
+much.
+e.
+Do you want to try to refresh your memory
+on that?
+MR. LEOPOLD: Do you have something to
+refresh her memory with?
+MR. TEIN:
+Do you want to stop making
+speaking objections?
+MR. LEOPOLD:
+No. But to refresh someone's
+memory, you show them a document.
+1655 Paln Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+59 of 316
+
+
+Racument 1 Entered on FLSD Docket 07/21/2008 Page 60 of 100
+Reporzing anil Transcriptinn, Inc.
+Page 34
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR. TEIN: I know how to do this.
+MR. LEOPOLD: Then show her a document.
+MR. TEIN: Stop speaking.
+MR. LEOPOLD: I'm not going to stop
+speaking. I'm going
+: to continue to make the
+record.
+MR. TEIN: You're obstructing. Please
+stop.
+MR. LEOPOLD: I'm not obstructing. But if
+you want to refresh her recollection, you need to
+show her something.
+That's not a proper question. I object to
+the foundation and the predicate of that question.
+MR. TEIN: Are you done?
+MR. LEOPOLD: I am now. Thank you.
+BY MR. TEIN:
+e.
+Do you want to try to refresh your memory
+as to whether you had any conversation with the woman who
+walked you upstairs in Epstein's house in which you told
+her that you went to college and had just moved down from
+Ohio?
+MR. LEOPOLD: Objection. Object to the
+form of the question. Lack of foundation and
+predicate.
+BY MR. TEIN:
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+60 of 316
+
+
+
+1 Reporting and Transcription, Inc
+Page 35
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+e.
+A.
+You can answer the question.
+Sure.
+Is there anything that would refresh your
+memory that in fact you told Mr. Epstein's assistant, the
+one who walked you upstairs, that you went to college and
+you had just moved down here from Ohio?
+A.
+I don't remember saying that, but if you --
+I don't remember saying that myself, so --
+That would be a lie, right?
+A.
+No. I really don't remember.
+So you told Jeff that you were 18 years.
+old, correct?
+A.
+Yes.
+e.
+Do you remember Detective Michelle Pagan of
+the Police Department, Palm Beach Police Department?
+A.
+Yes.
+Do you remember you spoke to her?
+A.
+Yes.
+Do you remember that you told Detective
+Pagan that when you lied about your age to Jeff you said
+it really fast because you didn't want to make it sound
+like you were lying?
+A.
+I don't remember the words exactly, but I
+do remember telling her I told him I was 18.
+And do you remember telling Detective Pagan
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+61 of 316
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 62 of 100
+dansor & Associates
+m" Reparing and Transcription, Ine
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 36
+that when you lied to Epstein about your age that you
+said it really fast so Epstein wouldn't realize you were
+lying?
+A. No, I don't remember saying those words
+exactly to her. I remember telling her that I told
+Epstein I was 18.
+2. Does it sound right to you that you told
+Detective Pagan that you said your age really fast to
+Epstein --
+MS. BELOHLAVEK: Objection. Asked and
+answered.
+BY YR. TEIN:
+e.
+-- so he wouldn't think that you were
+lying?
+MR. LEOPOLD: Objection. Asked and
+answered, lack of foundation, mischaracterization
+of her earlier testimony. She's already answered
+that question.
+BY MR. TEIN:
+You can answer it.
+MR. LEOPOLD: Same objection. It's been
+asked and answered.
+You can answer. I've made the objection.
+THE WITNESS: I forget the question, now.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+82 of 316
+
+
+Resument 1 Entered on FLSD Docket 07/21/2008 Page 63 of 100
+Reporting bad Transcripsion, Ine.
+Page 37
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+/19
+20
+21
+22
+23
+24
+25
+BY MR. TEIN:
+Let me put it again.
+Does it sound right to you that you told
+Detective Pagan that when you lied about your age to
+Jeffrey Epstein, you said it really fast because you
+didn't want to make it sound like you were lying?
+MR. LEOPOLD: Objection. Lack of
+foundation, asked and answered.
+THE WITNESS: I could have possibly said
+that, yes.
+BY MR. TEIN:
+e.
+You didn't want Mr. Epstein to know that
+you were lying about your age, right?
+A.
+Correct.
+e.
+You didn't want Mr. Epstein to know that
+you were not 18 yet, right?
+A.
+Correct.
+You wanted Mr. Epstein to believe that you
+really were 18, right?
+A.
+Correct.
+Do you remember when Mr. Epstein asked
+where you went to school?
+A. Yes.
+e. And you told Mr. Epstein you went to
+Wellington, right?
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+63 of316
+
+
+payment 1 Entered on FLSD Docket 07/21/2008 Page 64 of 100
+Roporting and Transcription, Inc.
+Page 38
+...
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+Yes.
+Q. Was that the truth?
+A.
+Q.
+No.
+In fact, you went to Royal Palm, right?
+A.
+Yes.
+So you lied to Mr. Epstein again, correct?
+A.
+Yes.
+l. Is Wellington the college that you told
+Jeff's assistant that you were attending?
+A. I don't remember having that conversation
+with her, so I wouldn't know if that's what I said.
+That was a lie, though, wasn't it?
+MR. LEOPOLD: Objection to the form of the
+question, lack of foundation. You're making an
+assumption. She just answered you she can't tell
+you that.
+MR. TEIN: Speaking objection. And you
+well know that, Mr. Leopold.
+MR. LEOPOLD: She' can't answer that
+question. The way you phrased that question;
+you're purposely making her not be honest in her
+testimony. She can't answer a question like that.
+She doesn't remember. So then you say, "so you
+were lying." That's improper and you know that.
+That's not a proper question. And any attorney
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+64 of 316
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 65 of 100
+fansor & Associates
+Reporting and Transcription, Ine.
+1
+2
+3
+4
+5
+6
+7
+8
+Page 39
+that would do that to a witnesses or to a person
+that's sitting in this chair is not acting
+professionally. You can't ask a question like
+that. You can do it, but it's not proper. And
+I'm sure you weren't trained that way, certainly
+not ethically.
+MR. TEIN: Will you stop?
+MR. LEOPOLD: I'm not going to stop,
+because the way you're asking that question is
+improper and you know it.
+MR. TEIN: You're losing your cool.
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY MR. TEIN:
+Ms.
+MR. LEOPOLD: Trust me.
+I'm very calm.
+When I lose my cool, you'll know it.
+MR. TEIN: I do know it.
+BY MR. TEIN:
+Ms.
+Mr. Epstein never asked you
+to do anything other than massage him, correct?
+A. Incorrect; because he asked me to take off
+my bra, so that would be two things he's asked me to do.
+e. Other than asking you to take your bra off,
+Mr. Epstein never asked you to do anything with him other
+than massage, correct?
+MR. LEOPOLD: Objection. Foundation,
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+85 of316
+
+
+mnsor SAS5 Cia Poket 07/21/2008 Page 66 of 10C
+mt Roporzing and Transcriprimo, Inc.
+Page 40
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+predicate.
+THE WITNESS: Correct.
+BY MR. TEIN:
+0.
+You told the police, in your words, that
+you did not whack him off, right?
+A.
+Correct.
+e.
+What does that mean?
+A.
+Whack, like whacking off?
+e.
+Your term, what does that mean?
+A.
+Masturbating.
+e.
+Mr. Epstein never tried at any time to grab
+you: hand, did he?
+A.
+No.
+Mr. Epstein never tried to put your hand
+anywhere, did he?
+A.
+No.
+0.
+At no time did you touch MI. Epstein's
+penis, did you?
+A. NO.
+e. And he did not touch you, correct?
+A.
+Incorrect.
+e.
+Well, you told the police, "At no time did
+he touch me." Were you lying to the police then?
+A. No. Well, I wasn't being fully truthful,
+but I wasn't lying.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+88 of 316
+
+
+Beaurent 1 Enterad on FLSD Docket 07/21/2008 Page 67 0f100
+Roporzing and Transcriptirn, Ine.
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 41
+You told the police twice when you spoke to
+Michelle Pagan that "at no time did he touch me. " Didn't
+you say that to the police?
+A. Yeah.
+e. And you're saying that that was not fully
+truthful. Is that what you're saying now?
+A.
+Correct.
+And you're saying if you're not fully
+trithful, that's not a lie. Correct?
+A. You took that out of context like really
+bac. I didn't mean like that. Touching my legs and --
+he never kept his hands to himself the entire time.
+That's what I'm trying to say.
+You told the police, "At no times did he
+touch me. " You agree with that, correct?
+A.
+No, I don't agree with that, because he did
+touch me.
+l. Did you tell the police that he did not
+touch you, yes or no?
+A.
+It's a possibility, but I do not remember.
+e.
+Okay. And you did not have any type of sex
+with Jeff, correct?
+A.
+No.
+2. And you did not have any type of oral sex
+with Jeff, correct?
+1655 Palm Beach Lakes Blvd., Sulte 500 - West Palm Beach, FL 33401
+87 of316
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 68 of 100
+Lonsor & Associates
+deporting and Transcripium, ox..
+Page 42
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+No.
+e.
+No type of intercourse with Jeff, correct?
+A.
+Correct.
+e.
+All right. Let's talk about what happened
+after the massage was over.
+A.
+okay.
+After the massage, you told Epstein that
+you wanted to bring your twin sister back so she could
+make some money, correct?
+A.
+Incorrect.
+Your twin sister is
+right?
+A.
+Correct.
+e.
+And you love
+very much, don't you?
+A.
+Yes.
+e. And when you left the house you were joking
+with the other girls, weren't you?
+A. Incorrect.
+0.
+Well, when
+and the other girl in the
+car that day made their statements to the police they
+told the police that you were joking afterwards. Are you
+saying that they were lying to the police about that?
+A.
+No. But a question or -- questions from
+- like she asked me questions, but it wasn't
+joking. She was kind of like in a happy way, like, "Oh,
+what did you do? What did you do?" Like those kind of
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+6B of 316
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 69 of 100
+Page 43
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+things, but it wasn't joking about it at all.
+e.
+You joked about it, didn't you?
+A.
+No.
+You said to
+that if you did this
+every weekend you'd be rich, didn't you?
+A.
+No. That's what
+told me.
+R.
+You didn't tell that to
+MR. LEOPOLD: Objection. Asked and
+answered.
+THE WITNESS: No.
+BY MR. TEIN:
+After you left Epstein's house you took the
+money and you went shopping with
+and the other
+girl in the car, correct?
+A.
+Incorrect. I didn't spend any of the
+money.
+A.
+didn't you?
+You went to Marshall's, didn't you?
+I went along, yes, but I didn't --
+You went shopping with them at Marshall's,
+
+MR. LEOPOLD: Objection.
+THE WITNESS: I guess you could say that.
+MR. LEOPOLD: Objection. Lack of predicate
+and foundation.
+Mischaracterization of earlier
+testimony.
+1655 Paln Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+
+
+'" '
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Document 1 Entered on FLSD Docket 07/21/2008 Page 70 of 100
+i Roaring and Transcriptian, Inc
+Page 44
+BY MR. TEIN:
+And
+bought a purse, right?
+A.
+Yes.
+e. And you were with her the whole time at
+Marshall's, correct?
+A. Yes.
+2. Now tell me about when the federal
+prosecutors told you about getting reimbursed.
+A. I have no idea what you're talking about.
+e. Tell me about when the federal prosecutors
+spoke to you about getting money you feel you're entitled
+to from Mr. Epstein.
+A.
+I don't know what you're talking about.
+e.
+Do you know who Marie Villafona is?
+A.
+No, sir.
+Did you ever meet with any federal
+prosecutors?
+A.
+think they were like FBI.
+0.
+prosecutors?
+A.
+e.
+A.
+I think -- yeah. I think they were -- I
+Uh-huh. Did you meet with federal
+They came to my house one time, yes.
+When did they come to your house?
+Very long ago.
+2. Was it this year, 2008?
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+70 of 318
+
+
+Sament 1r
+'Hoporting and Transcriprine, Ine.
+
+Page 45
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+It was not this year, no.
+e.
+Was it 2007?
+A.
+I'd have to say at least two years ago or a
+year ago, yeah. So it would be 2007, 2006; but it was a
+while ago.
+e.
+came to your house?
+A.
+people came.
+How many federal prosecutors or FBI agents
+I'm trying to remember. I want to say four
+Did they give you their business cards?
+A.
+If they did, I don't remember, and they
+weren't toward me. Maybe my parents have them. I don't
+know.
+e.
+A.
+e.
+Did they give you their cell phone numbers?
+No.
+Did you ever speak to them on their cell
+phones?
+A.
+parents.
+parent's?
+A.
+R.
+A.
+No, sir.
+Did they speak to your parents?
+That's something you'd have to ask my
+Do you know whether they spoke to your
+No, sir.
+e. You have no idea?
+Ph. 561.682.0905 - Fax, 561.682.1771
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+71 of 318
+
+
+...
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Delayment 1 Entered on FLSD Docket 07/21/2008 Page 72 of 100
+Reporting and Transcripsinn, Inc.
+Page 46
+A.
+No, sir.
+MR. LEOPOLD: Objection. Asked and
+answered.
+BY MR. TEIN:
+So if I say the name to you Marie
+Villafona, you don't know who that is?
+A.
+No, sir.
+How many women and how many men came to
+your house?
+A.
+e.
+you= house?
+A.
+I want to say two ladies and two guys.
+Did someone named Jeffrey Sloman come to
+I don't know names, sir.
+Do you know who Jeffrey Sloman is?
+A.
+e.
+A.
+No, sir.
+Do you know who Jeffrey Herman is?
+Yes.
+That's the lawyer who first sued Epstein on
+your behalf, right?
+A.
+Yes.
+Has Mr. Herman advanced your family any
+money?
+MR. LEOPOLD: Any conversations that you've
+had with Mr. Herman regarding that issue, you are
+not to disclose. If you've learned in some other
+1655 Palm Beach Lakes Bivd., Sulte 500 - West Palm Beach, FL 33401
+72 of316
+
+
+Case 9:08-Cv-80804-KAM
+Pocument 1 Entered on FLSD Docket 07/21/2008
+
+mi Renorsing anal Tranacription, Inc.
+Page 47
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+fashion, you may answer.
+THE WITNESS:
+okay.
+I wouldn't know.
+BY MR. TEIN:
+You don't know?
+A.
+No.
+MR. LEOPOLD: Objection. Foundation.
+Attorney/client privilege.
+BY MR. TEIN:
+And you say you don't know who Jeff Sloman
+is?
+A.
+No, sir.
+Does it refresh your recollection that he's
+the number two prosecutor at the U.S. Attorney's Office?
+A.
+e.
+A.
+No.
+That he's Marie Villafona's boss?
+No.
+Does it refresh your memory that he's the
+ex-partner of Jeff Herman, the first lawyer who sued
+you -- sued Mr. Epstein on your behalf for fifty million
+dollars?
+A.
+No, sir. I don't know who he is.
+Without telling me any conversations that
+you've had with your lawyers, how is it that you selected
+Mr. Herman as your lawyer from the 81,000 members of the
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+73 of 316
+
+
+Rogument 1 Entered on FLSD Docket 07/21/2008 Page 74 of 100
+Consor i Apsociates
+• Reponing anel Transcription, Inc.
+Page 48
+...
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Florida Bar?
+A.
+I did not select him.
+Who did?
+A.
+My father.
+R.
+Did you ever meet Mr. Herman?
+A.
+Once.
+e.
+Don't -- don't tell me what you discussed
+with him. Where did you meet him?
+A. I was shopping in my -- he showed up at my
+friend's house.
+Whose house?
+A. My friend
+l. Is that
+from the Quarterdeck
+Tavern?
+A.
+Yes.
+And did you have a meeting with him at
+house?
+A.
+Yes. I guess you could say that.
+And who else was there?
+A.
+e.
+My Aunt
+And what was that meeting about?
+MR. LEOPOLD: objection. That calls for
+attorney/client privilege.
+BY MR. TEIN:
+What discussions did you have with
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+74of316
+
+
+Rockpent 1 Entered on FLSD Docket 07/21/2008 Page 75 of 100
+Insor & Associates
+i Keporting and Transcriptien, Inc.
+Page 49
+....
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Mr. Herman in the presence of
+A.
+None.
+e. What discussions did you have in the
+presence of her aunt?
+A.
+Of my aunt?
+MR. GOLDBERGER: It's the witness's. aunt.
+BY MR. TEIN:
+A.
+oh, of your aunt.
+The only one that we've ever discussed or
+ever had.
+And so you were in a conversation with
+Mr. Herman and your aunt?
+A.
+Yes, sir.
+And you discussed privileged matters during
+that conversation?
+MR. LEOPOLD: Object to the form. I think
+you might have to educate her on that question.
+BY MR. TEIN:
+e.
+You discussed the lawsuit?
+A.
+Yes.
+e.
+Did
+tell you about any
+conversations that she had with Mr. Herman?
+A. As far as I'm concerned, she's never spoken
+or she's never had a conversation.
+She only opened the
+doo: and then left. She's the one who answered the door.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+75o1318
+
+
+Doçument 1 Entered on FLSD Docket 07/21/2008 Page 76 of 100
+A Reporing auel Transcription, Ine.
+Page 50
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Why did the meeting take place at
+:
+....
+76 of 316
+house?
+A.
+I spent the night that night at her house.
+And when was this?
+A.
+A while ago.
+How long ago?
+A.
+A month and a half ago. I'm guessing.
+A month and a half ago?
+A.
+Uh-huh.
+So was it before of after Mr. Herman filed
+the fifty-million-dollar lawsuit against Epstein?
+A. After.
+l. Did you meet with an FBI agent named
+Nesbitt Kurkendall, a woman?
+I don't know.
+l. Did Ms. Kurkendall speak to you about
+getting reimbursed from Mr. Epstein?
+A.
+I've never had a discussion with anyone
+about getting reimbursed from Mr. Epstein.
+Have you met with an agent named Jason
+Richards?
+A.
+A.
+e.
+Not to my knowledge.
+How about an agent named Tim Slater?
+No, sir.
+How about an agent named Junior Ortiz?
+1655 Palm Beach Lakes Bivd., Suite 500 - West Palm Beach, FL 33401
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 77 of 100
+Reporting and Transcription, Inc.
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 51
+A.
+No.
+2. And we've learned that many of the girls,
+some of whom are as old as 23, were told by the
+government that they would get money at the end of the
+criminal prosecution. Does that sound familiar to you?'
+A.
+No, siI.
+other than Mr. Leopold here -- I'm not
+asking about Mr. Herman either --
+A.
+Uh-huh.
+-- did anyone ever discuss with you that
+you: could get reimbursement for your damages?
+A.
+No, sir.
+e.
+Did you or any member --
+MR. LEOPOLD: Are you referring to a
+criminal matter of a civil matter?
+BY MR. TEIN:
+e.
+Did you or any member -
+MR. LEOPOLD: Excuse me. Let me object to
+the form of the question.
+BY MR. TEIN:
+Did you or any member of your family ever
+get a victim notification letter from anyone?
+A. I no longer live at that residence and I
+wouldn't know.
+So your testimony is that you have never
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+TT o1318
+
+
+Entered on FLSD Docket 07/21/2008 Page 78 of 100
+77 Hopering ani Transaription, Ana.
+Page 52
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+78 of 310
+regerved a victim notification letter, correct?
+rect.
+And your testimony is that you don't know
+if your parents have ever received a victim notification
+letter, correct?
+A.
+Correct.
+Have you given any evidence to prosecutors
+OI law enforcement in this case?
+A.
+What do you mean by evidence?
+Well. Anything that you can touch of feel.
+A.
+No.
+MR. LEOPOLD: Objection to the form of the
+question.
+BY MR. TEIN:
+So you haven't given anything physical -
+A. NO.
+e.
+- any item to any prosecutor, police
+officer or law enforcement agent, correct?
+A.
+My cell phone four years ago or three years
+ago, but that's it.
+e.
+You gave your cell phone to whom?
+A.
+Michelle Pagan.
+Did she keep it?
+A.
+Q.
+Ask her.
+You gave it to her and then you didn't get
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 79 of 100
+ansor & Assocíates
+→ Roporting, and Transcription, Inc.
+Page 53
+1
+2
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+it back at the end of the meeting?
+A. No. They -- yeah. No. They have it. I'm
+guessing. I don't have it.
+l. How much money are you hoping to get out of
+Mr. Epstein?
+MR. LEOPOLD: Objection to the form of the
+question. Attorney/client privilege.
+BY MR. TEIN:
+How much money are you hoping to get, you,
+yourself, hoping to get out of Epstein?
+MR. LEOPOLD: Same. Same objection,
+attorney/client privilege.
+Don't answer the question.
+BY MR. TEIN:
+I'm not asking about what your lawyer told
+you.
+MR. LEOPOLD: I'm instructing her not to
+answer the question, because any of those
+conversations involve her counsel.
+MR. TEIN: Certify that.
+MR. LEOPOLD: Please.
+••••
+BY MR. TEIN:
+78 of 316
+Now,
+deposition, didn't you?
+you lied to get out of this
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+
+
+Case 9:08-Cv-80804-KAM Document 1
+Entered on FLSD Docket 07/21/2008 Page 80 of 100
+711 Roporsing and Transcription, Inc.
+Page 54
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+No, sir.
+Q. You didn't want to come to court today and
+tell the story that you had told to the police under
+oath, did you?
+MR. LEOPOLD: Object to the form of the
+question. Lack of foundation, predicate.
+THE WITNESS: No. I have no problem coming
+here and talking to you.
+BY MR. TEIN:
+And to avoid getting served with a lawful
+subpoena, you lied about your name, didn't you?
+A.
+No.
+And in fact, just lying yourself wasn't
+enough, was it?
+MR. LEOPOLD: Objection to the form of the
+question.
+Don't answer it. It's not a question.
+Object to the form of the question. Lack
+of foundation.
+MR. TEIN: Are you instructing her not to
+answer?
+MR. LEOPOLD: I am.
+MR. TEIN: Certify it.
+MR. LEOPOLD: Please.
+80 of 316
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 81 of 100
+Reporting and Transcripcion, Inc.
+Page 55
+1
+2
+3
+4
+5
+....CERTIFIED QUESTION........
+BY MR. TEIN:
+You asked your co-workers --
+MR. LEOPOLD: It's vague and ambiguous.
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY MR.. TEIN:
+e.
+You asked your co-workers at the
+Quarterdeck Tavern to lie for you, didn't you?
+A. No. I informed my boss about what was
+going on and he told me that he would help in any way
+that he can.
+R.
+Okay. You got your friend
+to lie
+by switching name tags with you, correct?
+A.
+Incorrect. It was a coincidence that same
+night she was not wearing her name tag; she was wearing
+mine. But I was also not wearing -- I was wearing my
+name tag. Everyone switches name tags. It just so
+happens it was a coincidence that same night the people
+came with the papers.
+MR. TEIN: Will you put up Exhibit 18-001?
+MR. GOLDBERGER: And mark 18-001 for
+identification purposes to this deposition.
+MR. LEOPOLD: None of them have been marked
+yet. Can we mark them and put them as attachment
+to the depositions? Because I think you've shown
+three photos now. And this is the only one that
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+81 of 316
+
+
+Dogyment 1 Entered on FLSD Docket 07/21/2008 Page 82 of 100
+Page 56
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+has been marked for identification yet.
+BY MR. TEIN:
+e.
+--
+MR. LEOPOLD: Hold on just a second. Just
+so the record is clear --
+MR. TEIN: I'm not speaking to you.
+MR. LEOPOLD: Okay. Then don't speak to me
+then. But I'll speak to Mr. Goldberger, perhaps.
+But at least for the record, can we put on
+the record what the previous two photographs were
+marked for identification?
+MR. GOLDBERGER: We will make sure that the
+record is clear at the end of the deposition so
+that there's no ambiguity.
+MR. LEOPOLD: Thank you.
+BY MR. TEIN:
+e.
+• I've put a photograph marked 18-001
+up on the screen. Do you see that?
+A. Yup.
+A.
+Who is that in the photo?
+on the left and me on the right.
+right?
+A.
+Yes.
+your friend at the
+Quarterdeck Tavern, right?
+1655 Palr Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+82 of 316
+
+
+Document 1 Entered on FLSD Docket 07/21/2008
+' Heporting and Transcriptina, Inc.
+
+Page 57
+1
+2
+3
+4
+5
+6
+7
+A.
+Yes.
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+83 of 316
+your friend, who you say the day
+that the process servers went to serve you with a
+subpoena for this deposition, just happened -- Just by
+coircidence, was wearing your name tag?
+A.
+Yes, sir.
+e. And just by coincidence, you were wearing
+her name tag, correct?
+A.
+Yes.
+Your testimony under oath is that's just a
+coincidence, right?
+A.
+Total honesty.
+It just happens to be the day that you were
+going to be served with a subpoena, correct?
+A.
+That wasn't the first day that --
+MR. LEOPOLD:
+just answer the
+question. It calls for a yes or no.
+THE WITNESS: Yes.
+BY MR. TEIN:
+e.
+You said that wasn't the first day you were
+going to be -- you thought you were being served with a
+subpoena, correct?
+A.
+Correct.
+e.
+You knew before the day that you switched
+name tags with
+that the process servers were
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+
+
+Case 9:08-CV-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 84 of 100
+Reporting and Transcription. Inc.
+Page 58
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+looking for you, didn't you?
+A.
+No. I knew --
+MR. LEOPOLD: Just answer it. It calls for
+a yes or no.
+THE WITNESS: Okay. No.
+84 of 316
+BY MR. TEIN:
+e.
+Now you can explain the answer that your
+counsel stopped you from explaining.
+A.
+Okay. I work at Quarterdeck and people
+were telling me that people were looking for me. So yes,
+I was aware that people were searching for me. But I had
+no :dea who they were or what their intentions were. But
+I thought they were just people I didn't want to talk to.
+So I just didn't want to talk to them. And every time
+they'd come to work I wasn't there. And so happens the
+night that they came in me and my friend switched name
+tags. No big deal.
+e.
+That's a lie, isn't it?
+MR. LEOPOLD: Objection. Don't answer that
+question. That's harassment and I will not allow
+it. He could ask the questions and we '11 allow a
+jury to make that determination, but not counsel.
+I will not allow her to answer that'
+question.
+MR. TEIN: Certify it.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+
+
+Entered on FLSD Docket 07/21/2008 Page 85 of 100
+MY Ronorsing and Transcriptian, Inc.
+Page 59
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+85 of 316
+MR. LEOPOLD: I'll certify it.
+....CERTIFIED QUESTION.................
+She's
+answered
+that question. She's explained it five
+tines already. The fact that Counsel doesn't like the
+answer, that's a different query.
+MR. TEIN: Stop making speaking objections.
+MR. LEOPOLD: I'm not. I'm not going to
+put up with it, because it's in appropriate, Jack,
+and you know it. I will not allow Counsel to
+berate a witness, whether it's in a criminal case
+or a civil case, whether my client or -
+MR. TEIN: Calm down.
+MR. LEOPOLD: Excuse me.
+No, I'm not going to allow it. That is not
+proper.
+MR. GOLDBERGER: Okay.
+MR. LEOPOLD: If he wants to say that she's
+lying after asking it five times and her
+explaining in great detail, he can do that. But
+I'm not going to allow her to answer, nor be
+harassed by him. It's improper.
+MR. GOLDBERGER: Okay. But your response
+that Counsel doesn't like the question -- or
+doesn't like the answer -- just let me finish.
+MR. LEOPOLD: Absolutely. I wasn't going
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+
+
+Entered on FLSD Docket 07/21/2008 Page 86 of 100
+ēnsor & Associates
+i Roporting and Transcription, Inc
+Page 60
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+to interrupt you.
+MR. GOLDBERGER: Just requires us to say we
+like the answer to that question. And it's not
+you and I or you and MI. Tein who are testifying
+here. It's the witness.
+MR. LEOPOLD: Fine. But after the sixth
+time of asking the same question and then coming
+back and pointing a finger at her and saying,
+"You're a liar" -
+MR. TEIN: That didn't happen.
+MR. LEOPOLD: That's fine. But I'm not
+going to allow her to answer that question,
+because she's answered that same question and has
+explained it.
+Now Counsel might be sitting there rubbing
+his head with a migraine. That's his problem.
+But if he can't ask a question appropriately in a
+professional manner, we will leave. I will not
+allow her to be berated like that.
+MR. GOLDBERGER: Actually, we're very happy
+with the answer.
+MR. LEOPOLD: That's great.
+MR. GOLDBERGER: Do you want us to get into
+that?
+86 of 316
+MR. TEIN: Ted --
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+
+
+pocument 1 Entered on FLSD Docket 07/21/2008 Page 87 of100
+Reporting and Transcription, Ine...
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+...
+87 of 316
+Page 61
+MR. LEOPOLD: This is really big stuff that
+you're going through. But that's fine; just ask
+your question and move on. But do it one time.
+If you don't understand it, I'll let you follow
+up, but I'm not going to allow you to ask the same
+question time and again and then call her a liar.
+Just ask the question, get the answer and move to
+the next subject matter.
+MR. TEIN: Ted, I'm sitting right across
+the table from you.
+MR. LEOPOLD: Yes, sir.
+MR. TEIN: Please be quiet. Don't yell.
+MR. LEOPOLD: I will not be quiet.
+MR. TEIN: Stop yelling.
+MR. LEOPOLD: Lewis, when I'm yelling
+you'll know it. I will not -
+MR. TEIN: My name is not Lewis.
+MR. LEOPOLD: I thought your first name was
+Lewis, Mr. Tein.
+MR. TEIN: You watched me for three days at
+the evidentiary hearing where you sat in the back
+of the courtroom.
+You should know who I am.
+MR. LEOPOLD: Well, that's the impression
+you must have made in the courtroom.
+I will not be quiet.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+
+
+Entered on FLSD Docket 07/21/2008 Page 88 of 100
+Roporting and Transcripcien, Inc.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 62
+MR. TEIN: That's obnoxious. Stop being
+obnoxious. It's stupid. Let's go ahead with the
+questions.
+MR. LEOPOLD: I will make the record.
+MR. TEIN: Let's get on with the questions.
+MR. LEOPOLD: Do you need a break?
+(Thereupon, a recess was taken.)
+BY MR. TEIN:
+e. okay. i
+after you told your manager
+at the Quarterdeck Tavern everything that was going on
+and he told you he would help you any way he could, he
+hid you in the kitchen from the process servers, correct?
+A. Incorrect.
+l. Isn't it true that lying to avoid service
+is a meaningless lie to you,
+A.
+Incorrect.
+What is your manager's name?
+A.
+I have three. Would you like to know
+all --
+Who's the one who lied for you?
+A.
+e.
+A.
+e.
+A.
+And what did
+do to lie for you?
+Said I wasn't there.
+And who did he tell wasn't there?
+Ask him.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+85 of 316
+
+
+Entered on FLSD Docket 07/21/2008 Page 89 of 100
+Reporting and Transcription, Inc.
+Page 63
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+R.
+Where were you when
+told this
+someone that you were not at the Quarterdeck Tavern?
+A.
+Eating nachos.
+At the Quarterdeck Tavern?
+A.
+Yes.
+What did you do so that
+would lie to
+the process servers for you?
+A.
+Nothing.
+You just got him to lie for you, didn't
+you?
+A.
+wasa't there.
+No. I had no influence on him saying I
+He took that upon himself?
+Isn't it true that Mr. Epstein's process
+servers had to ask the police to get you out of the
+restaurant so that they could serve you?
+MR. LEOPOLD: Objection. Lack of
+foundation, predicate.
+BY MR. TEIN:
+You can answer the question.
+MR. LEOPOLD: If you know. Don't guess.
+THE WITNESS: No. Can you repeat the
+question?
+MR. TEIN: Don't coach.
+MR. LEOPOLD: Don't guess.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+80 o1318
+
+
+Entered on FLSD Docket 07/21/2008 Page 90 of 100
+Roporting and Transcription, Inc
+...-
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 64
+MR. TEIN: That's a coaching.
+MR. LEOPOLD: No. That's an instruction to
+the client.
+MR. TEIN: No. You don't do that.
+THE WITNESS: Can you repeat the question?
+MR. LEOPOLD: Let me just state for the
+record --
+BY MR. TEIN:
+9. Once the police -- isn't it true that
+Mr. Epstein's process servers had to ask the police to
+get you out of the restaurant so that they could serve
+you?
+A.
+Incorrect. My boss called the police.
+And once the police showed up, to stop you
+from lying to avoid service, you made up another lie that
+the process servers had harassed you. Isn't that
+correct?
+A.
+Incorrect.
+You lie all the time, don't you?
+MR. LEOPOLD: Objection.
+THE WITNESS: Incorrect.
+BY MR. TEIN:
+e.
+A.
+deleted it.
+You have a Myspace page, don't you?
+No longer do I have a MySpace page. I
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+D0 o1316
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 91 of 100
+7) Корня ал талеро, ос.
+Page 65
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+0.
+When did you delete your Myspace page?
+A.
+A couple days ago.
+Who told you to take your MySpace page down
+a couple of days ago?
+A.
+Nobody. I'm sick and tired of MySpace.
+e.
+You all of a sudden got sick and tired of
+Myspace and just a few days before this deposition you
+decided to delete your MySpace page, correct?
+A.
+Correct.
+e.
+Is that your testimony under oath?
+A.
+Yes.
+R.
+Did you take your Myspace page down because
+you thought the government might subpoena it?
+A.
+Incorrect.
+Hadn't your MySpace page been up for over
+three months before you took it down?
+A.
+Correct. But I also had made tons of
+MySpaces over the last years. I just get tired of them
+and delete them because -- drama -- and make new ones.
+R.
+We're going to talk about that.
+So you deleted your MySpace page after you
+were already under subpoena for this deposition, correct?
+A.
+Correct.
+0.
+us to see,
+What about the MySpace page didn't you want
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+01 of 316
+
+
+Ament 1
+Entered on FLSD Docket 07/21/2008 Page 92 of 100
+Reporting and Transcripzion, Inc.
+Page 66
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+e.
+in a second.
+A.
+Nothing.
+Well, we're going to come back to Myspace
+You do that.
+I'm going to ask you some questions
+about why you lie about your age so often, okay?
+MR. LEOPOLD: Objection to the form.
+Argumentative.
+BY MR. TEIN:
+You lie about your age all the time, don't
+you?
+MR. LEOPOLD: Objection, argumentative.
+THE WITNESS: Incorrect.
+82 of 316
+BY MR. TEIN:
+e.
+You lie about your age to get body
+piercings, don't you?
+A.
+Incorrect.
+You have body piercings, don't you?
+Yes.
+A.
+e.
+You have four body piercings; isn't that
+right?
+A.
+Five.
+e.
+Other than the piercings on your ears --
+I'm not talking about that -
+A.
+oh, then no; just one.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+
+
+Doçument 1 Entered on FLSD Docket 07/21/2008 Page 93 of 100
+pi Hoporting and Transcription, Jnk.
+Page 67
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+And where is the one body piercing?
+A.
+Belly.
+When did you get that?
+A.
+For my birthday, with my stepmother and my
+father.
+e. And when was that?
+A.
+When I was 14.
+Okay. So you had that body piercing when
+you met Epstein, correct?
+A. It might have been, or maybe that -- yeah,
+either my 14th birthday or my 15th. I honestly don't
+remember.
+R.
+Now you've lied about your age to get into
+bars by using driver's licenses that aren't yours,
+correct?
+A.
+e.
+Incorrect.
+Are you swearing under oath that you've
+never done that?
+A.
+Yes, I swear under oath.
+And you've lied about your age to buy beer,
+correct?
+A.
+Incorrect.
+You're swearing under oath that you've
+never lied to stores about your age?
+A.
+I've never lied to a store about my age or
+1655 Paim Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+83 of316
+
+
+Entered on FLSD Docket 07/21/2008 Page 94 of 100
+{" Reporsing and Transcripsion, Inc.
+Page 68
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+anything.
+You try to look much older than you are,
+don't you?
+A.
+Incorrect.
+And you've lied about your age on your
+MySpace pages, don't you?
+A.
+Incorrect.
+e.
+All right. Let's 1ook at Exhibit 26-01
+one.
+MS. BELOHLAVER: 26-001?
+MR. TEIN: Yes.
+...i
+94 of 318
+BY MR. TEIN:
+e.. On this page you lied to everyone that you
+were 18, didn't you?
+A.
+Correct.
+Let's go to Exhibit 33.
+MS. BELOHLAVEK: That's 33-001?
+TEIN: Correct.
+BY MR. TEIN:
+l. On this page you lied to everyone that you
+were 19, didn't you?
+A.
+Incorrect.
+MR. LEOPOLD: Just answer the question.
+THE WITNESS: Oh, incorrect.
+BY MR. TEIN:
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+
+
+Doçument 1 Entered on FLSD Docket 07/21/2008 Page 95 of 100
+I Reporting and Transeriprito, Inc.
+Page 69
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+! 18
+19
+20
+21
+22
+23
+24
+25
+Now you can explain your answer.
+A.
+I know that I have seen all of these and I
+know that this one is mine.
+Can you go down?
+MR. LEOPOLD: Just for the record, you're
+pointing to the photo.
+THE WITNESS: I'm pointing to --
+BY MR. TEIN:
+You're pointing to the one where it says
+your age is 18?
+A.
+Correct.
+That's yours, right?
+A.
+Correct. That's mine from a couple years
+ago that I have not been on, because I don't use that.
+Please keep going down, please. And I think that's it,
+because there's no one -- just that one is mine.
+So the one you pointed to where it says
+your age is 18, that's yours, correct?
+A.
+Correct.
+e.
+And when you wrote 18 as your age on your
+MySpace page, that was a lie, wasn't it?
+A.
+Correct.
+l. Did you lie about your MySpace page back
+then because you couldn't post on MySpace unless you were
+18?
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+95 of316
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 96 of 100
+1 ротід на талеро, ос
+Page 70
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+Correct. There was a rule many years ago
+that you had to be 18 to have a MySpace.
+e. So you lied about your age so you could
+post on MySpace, right?
+A.
+Yes.
+Let's go back to the top one on this page,
+33-01.
+Are you testifying now under oath that this
+Myspace page where the headline says, "Iwins do have more
+fun, " and the location is given as Lox, abbreviation for
+Loxahatchee, and the age is 19, and it says
+is it your testimony that you did not post
+that?
+A.
+Correct.
+e. Now let's go back to the one that you were
+pointing to before on this page, where it says your age
+is 18 and you lied about your age to post Myspace, okay?
+A.
+Uh-huh, yes.
+Q. All right. Why did you finally put your
+true age on your Myspace profile four days before you
+were scheduled to testify before the Grand Jury?
+A.
+I don't know what you're talking about.
+MR. LEOPOLD: If you don't understand, ask
+him to ask the question again.
+MR. TEIN: Don't coach.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+96 of 318
+
+
+Document 1 Entered on FLSD Docket 07/21/2008 Page 97 of 100
+Consor & Associate.
+• Roporting al Transcription, In
+Page 71
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+THE WITNESS: I don't know which MySpace
+you're talking about.
+BY MR. TEIN:
+e. The MySpace page that you're just pointing
+to, where it says you were 18.
+A.
+Yes.
+e.
+And you were lying about your age, right?
+A.
+Uh-huh.
+Why did you finally post your true age on
+your Myspace profile --
+A.
+Uh --
+-- four days before you were scheduled to
+testify before the Grand Jury?
+A. I honestly don't know which Myspace,
+because I've had like a bazillion MySpaces, and in that
+year, I had two, that one and another one, and that one's
+been deleted. So I don't know which one you're referring
+to.
+You remember that you changed your age on
+your MySpace page from 18 to your true age just four days
+before you went and testified in the Grand Jury?
+A.
+No.
+e.
+You don't remember that.
+A.
+No.
+Do you remember Detective Recarey? Did you
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+97 of 316
+
+
+Doçument 1 Entered on FLSD Docket 07/21/2008 Page 98 of 100
+Reporting and Transcription, Inc.
+Page 72
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ever meet a Detective Recafey?
+A. I don't know the names.
+0. How many different detectives have you met
+with on this case from Palm Beach?
+A. Probably a good six or seven, maybe.
+l. Did one of the detectives tell you before
+you testified in the Grand Jury that you should take your
+MySpace age and put your true age?
+No.
+Didn't Detective Recarey have to come to
+your house to pick you up to get you to testify in front
+of the Grand Jury?
+A.
+Possibly; maybe because I didn't have a
+rice; I was only 14 or 15 at the time.
+Your mom didn't drive you?
+A.
+l.
+A.
+No.
+Stepmom didn't drive you?
+I think my dad. Oh, my dad; my dad drove
+me.
+e.
+Your dad drove you?
+A.
+Yes, sir.
+e.
+So your testimony is Detective Recarey did
+not drive you, correct?
+MR. LEOPOLD: Objection. /asked and
+answered.
+1655 Palm Beach Lakes Bivd., Suite 500 - West Palm Beach, FL 33401
+88 of 316
+
+
+Case 9:08-Cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008
+Reporting and Trenscription, Inc.
+
+Page 73
+1
+2
+3
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+THE WITNESS: No. I'm pretty sure my dad
+drove me, because he was there with me.
+BY MR. TEIN:
+e. Did any detective tell you to change your
+age on your MySpace page, to put your true age?
+A.
+No, sir.
+Now you also lied on your MySpace page
+about your income, didn't you?
+A.
+Yes.
+l. And you lied, saying that you made a
+quarter million dollars a year and higher, correct?
+A.
+As a joke, yes.
+That was a lie, wasn't it?
+A.
+Yes.
+l. And you also lied on your Myspace page,
+saying that you were married, didn't you?
+A. Possibly. And that might have been an
+error on my part.
+e.
+Now you also lie to the police, don't you?
+A.
+No.
+Well, you lied to the police in your
+tape-recorded statement that you gave to Detective
+Michelle Pagan three years ago, didn't you?
+To my knowledge, no, I did not.
+Well, you lied to the police when you
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+99 of 316
+
+
+Diment Entered FLD De 07212008 Page 100 of 100
+mor & Associates
+Page 74
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+accused Mr. Epstein of attempting to murder your father,
+didn't you?
+A.
+No. I never heard a statement saying that
+Mr. Epstein tried to murder my father.
+e. You made that statement, didn't you?
+MR. LEOPOLD: Do you have a statement to
+show her? That's been asked and answered.
+MR. TEIN: I'm sorry. I didn't hear the
+witness' answer, Mr. Leopold.
+BY MR. TEIN:
+you told the police, didn't you,
+that Mr. Epstein almost killed your father, didn't you?
+A.
+No.
+8. Three years ago, before Mr. Epstein even
+knew about this investigation, you told the police that
+Epstein had "already come to my dad's house and did
+something to my dad's tires and my dad almost died. I
+didn't want my dad to get hurt, because Jeff already
+almost killed him."
+Didn't you say that?
+A.
+Not to my knowledge or recollection.
+I
+have never said anything like that.
+e.
+That would have been a complete lie,
+wouldn't it have been?
+A.
+Yeah.
+1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
+100 o1316
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/c1db01a8f111dbd529d0812e3c9a6249c6819dac40caa3fa40e451905ec7a326.receipt.json b/vision-fixhub/ds9-unparsed-05/c1db01a8f111dbd529d0812e3c9a6249c6819dac40caa3fa40e451905ec7a326.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..645f5b1c38519d16513eb08957f9d31edb19dddd
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c1db01a8f111dbd529d0812e3c9a6249c6819dac40caa3fa40e451905ec7a326.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -16279,
+  "dataset": "marble-joined",
+  "doc_id": "c1db01a8f111dbd529d0812e3c9a6249c6819dac40caa3fa40e451905ec7a326",
+  "engine": "marble-apple-vision",
+  "event_count": 242,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "741ca0f2d350e2855c48fb4d12315830ad85626595bb6d985ecb6d1b66ff0e7b",
+  "output_sha256": "31a5fa680b81059046ee441d44884c9ae50166247dd04e2d6f79e0df263393fa",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c209362970822abb3322c08aa55ffff3757f2325eb3197bd693423fc3c3b83b4.md b/vision-fixhub/ds9-unparsed-05/c209362970822abb3322c08aa55ffff3757f2325eb3197bd693423fc3c3b83b4.md
new file mode 100644
index 0000000000000000000000000000000000000000..278c89b813b503f62853eb0766c8e92c913099e1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c209362970822abb3322c08aa55ffff3757f2325eb3197bd693423fc3c3b83b4.md
@@ -0,0 +1,712 @@
+12/4/07 Acosta to Stam
+
+
+Southern District of Florida
+R ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+99 N.E. 4 Street
+Miami, FL 33/32
+(305) 96/-9/00 - Telephone
+(305) 530-6444 - Facsimile
+DELIVERY BY FACSIMILE
+Kenneth W. Starr, Esq
+Kirkland & Ellis LLP
+777 South Figueroa Street
+Los Angeles, CA 90017
+Re: Jeffrey Epstein
+Dear Mr. Starr:
+I write in response to your November 28" letter, in which you raise concerns regarding the
+Non-Prosecution Agreement between this Office and your client, Mr. Epstein. I take these concerns
+seriously. As your letter focused on the Section 2255 portion of the Agreement, my response will
+focus primarily on that issue as well. I do wish to make some more general observations, however.
+Section 2255 provides that "[a]ny person who, while a minor, was a victim of a violation of
+[enumerated sections of Title 18] and who suffers personal injury as a result of such violation..
+may sue in any appropriate United States District Court and shall recover the actual damages such
+person sustains and the cost of the suit, including a reasonable attorney's fee." Thus, had this Office
+proceeded to trial, and had Mr. Epstein been convicted, the victims of his actions would have been
+able to seek to relief under this Section.
+The Non-Prosecution Agreement entered into between this Office and Mr. Epstein responds
+to Mr. Epstein's desire to reach a global resolution of his state and federal criminal liability. Under
+this Agreement, this District has agreed to defer prosecution for enumerated sections of Title 18 in
+not harm the interests of his victims. This third point deserves elaboration. The intent is to place
+the victims in the same position as they would have been had Mr. Epstein been convicted at trial.
+No more; no less.
+With this in mind, I turn to the language of the Agreement. Paragraph 8 of the Agreement
+provides:
+If any of the individuals referred to in paragraph (7), supra, elects to file suit pursuant
+to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the United States
+
+
+District Court for the Southern District of Florida over his person and/or the subject
+matter,' and Epstein waives his right to contest liability and also waives his right to
+contest damages up to an amount as agreed to between the identified victim and
+Epstein, so long as the identified victim elects to proceed exclusively under 18
+U.S.C. § 2255, and agrees to waive any other claim for damages, whether pursuant
+to state, federal, or common law. Notwithstanding this waiver, as to those
+individuals whose names appear on the list provided by the United States, Epstein's
+signature on this agreement is not to be construed as an admission of any criminal or
+civil liability other than that contained in 18 U.S.C. § 2255.
+Although these two sentences are far from simple, they appear to incorporate our intent to narrowly
+tailor the Agreement to place the identified victims in the same position as they would have been had
+Mr. Epstein been convicted at trial. I would note that I have conferred with our prosecutors and have
+been told that Paragraph 8 was vigorously negotiated and that the final language was suggested
+largely by defense counsel.
+The concerns raised in your letter with respect to Paragraph 8 fall within several general
+categories. First, you raise concerns regarding the nature of Section 2255. As you note,
+Section 2255 is a civil statute implanted in the criminal code; in contrast to other
+criminal statutes, Section 2255 fails to correlate payments to specific injuries or
+losses. Instead the statute presumes that victims have sustained damages of at least
+a minimum lump sum without regard to whether the complainants suffered actual
+medical, physiological or other forms of individualized harm.
+These concerns were, I would expect, aired when Congress adopted this statute. Even if they were
+not, this provision is now law. Rule of law requires now requires this District to consider the
+victims' rights under this statute in negotiating this Agreement.
+Second, you raise concerns regarding the identity-of-the-victims issue. Your concerns appear
+based on the belief that Paragraph 8 is a blanket waiver of liability with respect to any number of
+unnamed and undisclosed victims. I would invite you to confer with your co-counsel regarding this
+matter. Although the language of Paragraph 8 could be so construed, our First Assistant informed
+Mr. Lefkowitz some weeks ago that this was not our position. As Mr. Lefkowitz has noted, were
+Mr. Epstein convicted at trial, the plaintiff-victims in a subsequent Section 2255 suit would still have
+had some burden to prove that they were "victims." It is also the case, however, that were Mr.
+Epstein convicted at trial, the plaintiff-victims would not have to show that a violation of an
+enumerated section of Title 18 took place. Accordingly, our First Assistant informed Mr. Lefkowitz
+some weeks ago that we understood that if a victim-plaintiff elects to proceed to trial, Mr. Epstein's
+' Although not identified as an issue by defense counsel, having reviewed this language, I note that
+Paragraph 8 raises the question of what is meant by "subject matter." I have conferred with the AUSA who
+negotiated this language, and have been informed that parties intended this to address issues of venue. This
+Office will not interpret this paragraph as any waiver of subject matter jurisdiction. Please inform me if
+defense counsel disagrees.
+-2-
+
+
+legal team might conduct due diligence to confirm the that victim-plaintiff in fact had inappropriate
+contact with Mr. Epstein. Once again, our interpretive principle is our intent to place the victim in
+the same position she would have been had Mr. Epstein proceeded to trial.
+Third, you raise concerns regarding our decision not to create a restitution fund. Throughout
+the negotiations, defense counsel suggested several similar arrangements, including a Trust fund.
+Again, our decision not to create a fund flows from our belief that the Agreement should provide the
+same relief to the victims as they would have been entitled had we proceeded to trial. A restitution
+fund or trust fund would place an upper limit on the victims' recovery. It is not for this Office to
+make that decision for the victims. They may choose to walk away, they may choose to settle, or
+they may choose to sue. The choice should remain with each individual victim.?
+Fourth, you raise concerns regarding the selection process for the attorney representative.
+As you may be aware, the suggestion that we appoint an attorney representative originated with
+defense counsel. Defense counsel, I believe, found it advantageous to attempt to negotiate a
+settlement of the many victims' claims with one attorney representative. My Office agreed to
+appoint such a representative, in part, because we too thought it valuable for the victims to have the
+advice of an attorney who could advise them of their choices: whether to walk away, to settle or to
+Sue.
+Since the signing of the Agreement, several issues have arisen with respect to this provision.
+First, I elected to assign this Office's right to appoint the representative to an independent third-party,
+former federal Judge
+I did this to avoid any suggestion that this Office's choice of
+representative was intended to influence the outcome of civil litigation. Second, your co-counsel
+expressed concerns similar to those raised in your letter regarding the criteria used to select the
+representative. These criteria were:
+(1) Experience doing both plaintiffs' and defense litigation;
+(2) Experience with state and federal statutory and common law tort claims;
+(3) Ability to communicate effectively with young women;
+(4) Experience litigating against large law firms and high profile attorneys who may
+test the veracity of the victims' claims;
+(5) Sensitivity to the nature of the suit and the victims' interest in maintaining their
+privacy;
+(6) Experience litigating in federal court in the Southern District of Florida;
+* Your letter references U.S. | Boehm, No. 3:04CR00003 (D. Ala 2004) as a model for a restitution fund
+settlement. I asked our prosecutor to contact the AUSA in that case. In that matter, the District of Alaska
+sought out and obtained the consent of all the victims before entering into that settlement. In addition, they
+developed an elaborate procedure for deciding which victim would receive what. My view, in this case, is
+that those types of negotiations are better handled between Mr. Epstein and the victims' representatives, and
+that this Office should not act as intermediary. Finally, I would note that in Boehm as well, the victims'
+identities were not initially disclosed. As the AUSA wrote in that case: "This filing is made ex parte
+because Boehm, in his plea agreement, waived any rights he had pertaining to the selection of beneficiaries
+and the disbursement of funds to such beneficiaries."
+-3-
+
+
+(7) The resources to hire experts and others, while working on a contingency fee
+basis, in order to prepare for trial if a settlement cannot be reached (defense counsel
+has reserved the right to challenge such litigation); and
+(8) The ability to negotiate effectively.
+At my direction, our First Assistant provided our criteria to your co-counsel, Mr. Lefkowitz, in
+advance, and at co-counsel's request, he noted in our communication with Judge
+, defense
+counsel's objection to criteria 7. I have now reviewed these criteria and find them balanced and
+reasonable. They appear designed to provide the victims with an attorney who can advise them on
+all their options, whether it be to walk away, to settle (as your client prefers), or to litigate. Again,
+our intent is not to favor any one of these options, but rather to leave the choice to each victim.
+Fifth, you assert that this Office "has improperly insisted that the chosen attorney
+representative should be able to litigate the claims of the individuals," should a resolution not be
+possible. This issue, likewise, has already been raised and addressed in discussions between your
+co-counsel and our First Assistant. We understand your position that it would be a conflict of
+interest for the attorney representative to subsequently represent victim-plaintiffs in a civil suit. Your
+interpretation of the ethics rules may be correct, or it may be wrong. Far from insisting that the
+attorney representative can represent victim-plaintiffs in subsequent litigation, our First Assistant
+and I have repeatedly told defense counsel that we take no position on this matter. Indeed, I fully
+expect your defense team to litigate this issue with the attorney representative if a resolution is not
+reached.
+T have responded personally and in some detail to your concerns because I deeply care about
+both the law and the integrity of this Office. I have responded personally and in some detail as well
+because your letter troubled me on a number of levels. My understanding of the negotiations in this
+matter informs my concerns.
+The Section 2255 provision issue was first discussed at a July 31, 2007, meeting between
+FAUSA Sloman, Criminal Chief Menchel, West Palm Beach Chief Lourie, AUSA Villafafia, and
+two FBI agents who met with Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. On that date, the
+prosecutors presented a written, four-bullet-point term sheet that would satisfy the federal interest
+in the case and discussed the substance of those terms. One of these four points was the following
+provision:
+Epstein agrees that, if any of the victims identified in the federal investigation file
+suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the U.S
+District Court for the Southern District of Florida over his person and the subject
+matter. Epstein will not contest that the identified victims are persons who, while
+minors, were victims of violations of Title 18, United States Code, Sections(s) 2422
+-4
+
+
+In mid August 2007, your defense team, dissatisfied with my staff s review of the case, asked
+to meet with me. Mr. Lefkowtiz indicated your busy schedule, and asked me to put off until
+September 7, 2007, so that you could attend. Mr. Lefkowitz also indicated that he might appeal my
+decision to Washington D.C., if my decision was contrary to his client's interest. I agreed to the
+September 7 meeting, despite the fact that our AUSA had an indictment ready for presentation to
+the grand jury. An explicit condition of that agreement, however, was an understanding between Mr.
+Lefkowitz and myself that any appeal to Washington would be undertaken expeditiously.
+On September 7, 2007, I, along with FAUSA Sloman, AUSAs McMillan and Villafaña, and
+FBI agents, met with you, Mr. Lefkowitz, and Ms. Sanchez. I understood that you wished to present
+federalism-based concerns regarding our prosecution. To ensure a full consideration of your
+arguments, I invited Drew Oosterbaan, Chief of the Criminal Division's Child Exploitation and
+Obscenity Section, to travel from Washington to attend our meeting. During the September 7"
+meeting, your co-counsel, Mr. Lefkowitz, offered a plea resolution. The inclusion of a Section 2255
+remedy was specifically raised and discussed at the September 7" meeting. Indeed, according to
+AUSA Villafaña's notes, you thanked her for bringing it to your attention. Again, no objection to
+the Section 2255 issue was raised.
+After considering the arguments raised at the September 7" meeting, and after conferring
+with the FBI and with Chief Oosterbaan, our Office decided to proceed with the indictment. At that
+time, I reminded Mr. Lefkowitz that he had previously indicated his desire to appeal such a decision
+to the Attorney General, the Deputy Attorney General, or the Assistant Attorney General for the
+Criminal Division, and I offered to direct our prosecutors to delay the presentation of the indictment
+to allow you or he to appeal our decision if you so chose. He decided not to do so.
+Instead, Mr. Epstein elected to negotiate the Non-Prosecution Agreement. These negotiations
+were detailed and time-consuming. Mr. Epstein's defense team, including yourself, Professor
+Dershowitz, former United States Attorney Guy Lewis, Ms. Lilly Ann Sanchez and Messrs. Roy
+Black, Jack Goldberger, Gerry Lefcourt and Jay Lefkowitz had the opportunity to review and raise
+objections to the terms of the Agreement. Again, no one raised objections to the Section 2255
+language.
+Since the signing of the Agreement, the defense team and our Office have addressed several
+issues that have arisen under the Agreement. Although the exchanges were at times a bit litigious,
+it appears that these issues have been resolved by mutual consent, some in favor of your client, some
+It is against these many previous foregone opportunities to object that I receive with surprise
+your letter requesting an 11" hour, after-the-fact review of our Agreement. Although it happens
+rarely, I do not mind this Office's decision being appealed to Washington, and have previously
+directed our prosecutors to delay filings in this case to provide defense counsel with the option of
+appealing our decisions. Indeed, although I am confident in our prosecutors' evidence and legal
+analysis, I nonetheless directed them to consult with the subject matter experts in the Criminal
+-5-
+
+
+Division's Child Exploitation and Obscenity Section to confirm our interpretation of the law before
+approving their indictment package. I am thus surprised to read a letter addressed to Department
+Headquarters that raises issues that either have not been raised with this Office previously or that
+have been raised, and in fact resolved, in your client's favor.
+I am troubled, likewise, by the apparent lack of finality in this Agreement. The AUSAs who
+have been negotiating with defense counsel have for some time complained to me regarding the
+tactics used by the defense team. It appears to them that as soon as resolution is reached on one
+issue, defense counsel finds ways to challenge the resolution collaterally. My response thus far has
+been that defense counsel is doing its job to vigorously represent the client. That said, there must
+be closure on this matter. Some in our Office are deeply concerned that defense counsel will
+continue to mount collateral challenges to provisions of the Agreement, even after Mr. Epstein has
+entered his guilty plea and thus rendered the agreement difficult, if not impossible, to unwind.
+Finally, I am most concerned about any belief on the part of defense counsel that the
+Agreement is unethical, unlawful or unconstitutional in any way.?
+In closing, I would ask that you consult with co-counsel. If after consultations within the
+defense team, you believe that our Agreement is unethical, unlawful or unconstitutional, I would ask
+that you notify us immediately so that we can discuss the matter by phone or in person. I have
+consulted with the chief prosecutor in this case, who has advised me that she is ready to unwind the
+Agreement and proceed to trial if necessary or if appropriate.
+I would reiterate that it is not the intention of this Office ever to force the hand of a defendant
+to enter into an agreement against his wishes. Your client has the right to proceed to trial. Although
+time is of the essence (I understand that certain filings are due to our Office no later than December
+7" and that certain events must take place no later than December 14,"), I am directing our
+prosecutors not to issue victim notification letters until this Friday at 5 p.m., to provide you with time
+to review these options with your client. We are available by phone or in person, in the interim, to
+" It is not clear from your letter whether you believe that attorneys in this Office have acted improperly.
+Your letter, for example, alludes to the need to engage in an inquiry to assure that disclosures to potential
+witnesses did not undermine the reliability of the results of this federal investigation. As a former
+Department of Justice attorney, I am certain that you recognize that this is a serious allegation. I have
+raised this matter with AUSA Villafaña who informed me that the victims were not told of the availability
+of Section 2255 relief during the investigation phase of this matter. If you have specific concerns, 1 ask that
+-6-
+
+
+address any matters that might remain unaddressed in this letter. We expect a written decision by
+this Friday at 5 p.m., indicating whether the defense team wishes to reaffirm, or to unwind, the
+Agreement.
+Sincerely,
+1. 1AM
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+cc:
+Alice Fisher, Assistant Attorney General
+-7-
+
+
+Aex ltr
+Southern District of Florida
+99 NE. 4' Street
+Miami, FL 33/32-2111
+(305) 961-9299
+Facsimile: (305) 530-6444
+November 30, 2007
+DELIVERY BY FACSIMILE
+Kenneth W. Starr, Esq.
+Kirkland & Ellis LLP
+777 South Figueroa Street
+Los Angeles, CA 90017
+Re:
+Jeffrey Epstein
+Dear Mr. Starr:
+I write in response to your letter of November 28, 2007, to Assistant Attorney General Fisher.
+There are a number of issues that must be addressed, but I believe that a history of the negotiations
+with the various counsel for Mr. Epstein would best illustrate how the Non-Prosecution Agreement
+was reached. I then will address some of your client's attempts to attack the agreement that he
+signed, and I finally will address how our Office intends to proceed.'
+At the end of 2006, Guy Lewis contacted AUSA A. Marie Villafaña when he learned that she
+was handling the federal investigation of Mr. Epstein. He asked to meet with her and she stated that
+she believed such a meeting would be premature. In December, Lilly Ann Sanchez and Gerald
+Lefcourt again contacted AUSA Villafaña to set a meeting. AUSA Villafaña requested documents
+in advance of such a meeting, but the request was refused. Ms. Sanchez then contacted AUSA
+Andrew Lourie, who agreed to meet with Ms. Sanchez and Mr. Lefcourt. On February 1, 2007, Ms.
+Sanchez and Mr. Lefcourt met with AUSAs Lourie and Villafaña, as well as a member of the Federal
+Bureau of Investigation, presented defense counsel's view of the case, and promised a willingness
+to assist in the investigation. The Office was unpersuaded by their presentation, and the
+investigation continued
+By the late Spring and early Summer, the focus of the investigation left investigating the facts
+of the victims' claims and turned more to Mr. Epstein's background, his asserted defenses, co-
+'First Assistant U.S. Attorney Jeffrey Sloman is sending a letter under separate cover
+addressing some of the items in the correspondence from you and Mr. Lefkowitz, since he has been
+directly involved in discussions of those issues.
+
+
+
+conspirators, and possible witnesses who could corroborate the victims' statements. The
+investigation also began to look into financial aspects of the case, requiring the issuance of several
+subpoenas. At that time, Mr. Lefcourt began leveling accusations of improprieties with the
+investigation and sought a meeting with Matthew Menchel, who was then Chief of the Criminal
+Section. By that time, our Office had already received a proposed initial indictment package, which
+had been reviewed by the supervisors in our West Palm Beach Office and by attorneys with the
+Justice Department's Child Exploitation and Obscenity Section, but which was awaiting review by
+Mr. Menchel and FAUSA Sloman. The Office deferred presenting the indictment to the grand jury
+to accommodate your client's request for a meeting. The Office also agreed to wait several weeks
+for that meeting to occur to allow four of Mr. Epstein's attorneys to be present, and also provided
+Mr. Epstein's counsel with a list of the statutes that were the subject of the federal investigation.
+On June 26, 2007, FAUSA Sloman, Mr. Menchel, AUSAs Lourie and Villafaña, and two
+Special Agents with the FBI met with four attorneys for Mr. Epstein, specifically, Alan Dershowitz,
+Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. During that meeting, Professor Dershowitz and
+other members of the defense team presented legal and factual arguments against a federal
+indictment. Counsel for the defense also requested the opportunity to present written arguments,
+which was granted. The arguments and written materials provided by the defense were examined
+by the Office and rejected.
+On July 31, 2007, FAUSA Sloman, Mr. Menchel, AUSAs Lourie and Villafaña, and two FBI
+agents again met with Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. On that date, the Office
+presented a written sheet of terms that would satisfy the Office's federal interest in the case and
+discussed the substance of those terms. That term sheet is attached hereto. As you will note, one
+of those terms was:
+Epstein agrees that, if any of the victims identified in the federal investigation file
+suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the U.S.
+District Court for the Southern District of Florida over his person and the subject
+matter. Epstein will not contest that the identified victims are persons who, while
+minors, were victims of violations of Title 18, United States Code, Sections(s) 2422
+and/or 2423.
+During that meeting, the focus was on Mr. Epstein's unwillingness to spend time in prison, and
+various suggestions were raised by defense counsel, including the proposal that Mr. Epstein could
+serve a sentence of home confinement or probation. This was repeatedly mentioned by counsel for
+Mr. Epstein as being equivalent to a term of incarceration in a state or federal prison. Mr. Epstein's
+counsel mentioned their concerns about his safety in prison, and our Office offered to explore a plea
+to a federal charge to allow Mr. Epstein to serve his time in a federal facility. Counsel were also
+presented with a conservative estimate of the sentence that Mr. Epstein would face if he were
+convicted: an advisory guideline range of 188 - 235 months of imprisonment with a five-year
+
+
+
+mandatory minimum prison term, to be followed by lifetime supervised release. Counsel was told
+that Mr. Epstein had two weeks to accept or reject the proposal.
+Mr. Epstein's counsel, still dissatisfied with the Office's review of the case, demanded to
+meet with me and to have the opportunity to meet with someone in Washington, D.C. To
+accommodate Mr. Black, the meeting was put off until September 7, 2007, despite the fact that the
+indictment was ready for presentation to the grand jury. In the interim, AUSA Villafaña and the
+investigators met with the Chief of the Child Exploitation Section, Drew Oosterbaan, to review, yet
+again, the evidence and legal theories of prosecution. Chief Oosterbaan strongly supported the
+indictment and even offered to join the trial team and provide additional support from his Section.
+On September 7, 2007, I met with you, Mr. Lefkowitz, and Ms. Sanchez, along with Chief
+Oosterbaan, FAUSA Sloman, and AUSAs McMillan and Villafaña.? You and other counsel for Mr.
+Epstein again presented arguments regarding the sufficiency of the federal interest in the case and
+other legal and factual issues. Your arguments were discussed afterwards and the unanimous
+opinion of all of the attorneys present was in favor of prosecution.
+During the September 7" meeting, your co-counsel, Mr. Lefkowitz, also offered a plea
+resolution. His offer, in essence, was that your client be subject to home confinement at his Palm
+Beach home, using private security officers who would serve as "wardens," if necessary. Mr.
+Lefkowitz expressed the belief that such a sentence would be particularly appropriate because, as a
+wealthy white man, your client may be the subject of violence or extortion while in prison. Finally,
+both you and your co-counsel expressed the belief that Mr. Epstein's extensive charitable giving
+should be considered in our prosecution decision. I summarily rejected these proposals, and
+indicated that the twenty-four month offer presented previously by this Office stood. I should add
+that there were four other prosecutors present at the meeting, representing a combined experience
+of more than fifty years. Never had any of them heard, or heard of, an attorney making a similar
+argument, and especially not in a child exploitation case.
+The issue of the inclusion of a restitution-type remedy for the victims pursuant to 18 U.S.C.
+§ 2255 was specifically raised and discussed at the September 7 meeting, and you thanked AUSA
+Villafaña for bringing it to your attention as a novel approach to allowing the victims to receive
+essentially federal restitution while allowing a plea to a state charge.
+After considering everything said and written by Mr. Epstein's legal defense team, and after
+conferring with Chief Oosterbaan, I informed you that we still intended to proceed to indictment.
+Since counsel had indicated a desire to appeal the matter to the Attorney General, the Deputy
+"I note that this meeting had been delayed several weeks to allow for Mr. Black's
+participation, yet he was not present.
+
+
+
+Attorney General, or the Assistant Attorney General for the Criminal Division, I agreed to delay the
+presentation of the indictment for two weeks to allow you to speak with someone in Washington,
+D.C., if you so chose.
+Instead, Mr. Epstein elected to negotiate the Non-Prosecution Agreement, and on September
+12, 2007, counsel for the United States (AUSAs Lourie, Garcia, and Villafaña) and counsel for Mr.
+Epstein (Messrs. Lefcourt, Lefkowitz, and Goldberger) met with State Attorney Barry Krisher and
+Assistant State Attorney Lanna Belohlavek to discuss a plea to an Information in the state court that
+would satisfy the federal interest in the case. As noted on the term sheet of July 31", one of those
+essential terms was a guilty plea to a charge requiring sex offender registration. During that meeting,
+the issue of sex offender registration was raised, and Mr. Goldberger told the federal prosecutors that
+there was no problem, Mr. Epstein would plead guilty to the charge of solicitation of minors for
+prostitution (Fl. Stat. 796.03), which was one of the statutes listed on the original term sheet.
+Although our Office had wanted Mr. Epstein to plead guilty to three different offenses, we agreed
+to this compromise.? Of course, we later learned that, at the time Mr. Goldberger made that
+statement, he incorrectly believed, based upon a statement from ASA Belohlavek, that Fl. Stat.
+796.03 did not require sex offender registration.
+The parties then began working first on a plea agreement to a federal charge and, when it was
+clear that there was no guarantee the Mr. Epstein would serve his sentence in a minimum security
+prison camp, the discussion turned to a Non-Prosecution Agreement. Both the federal plea
+agreement and the Non-Prosecution Agreement included references to Section 2255 because neither
+the contemplated federal charges nor the proposed state charges encompassed all of the identified
+victims. If Mr. Epstein had been prosecuted under the planned indictment, the identified victims
+would have been eligible for restitution and damages under Section 2255. As explained above, one
+of the United States' interests, which had to be satisfied by the Non-Prosecution Agreement, was
+providing appropriate compensation to the victims. This provision of the Agreement was heavily
+negotiated. As Mr. Lefkowitz wrote in his November 29'* e-mail to Mr. Sloman, which we received
+the same day as your letter, your client "offered to provide a restitution fund for the alleged victims
+in this matter; however that option was rejected by [our] Office." The option was rejected for several
+reasons. First, the Office does not serve as legal representatives to the victims and has no authority
+to bind the victims, nor could it provide a monetary figure that would represent a "loss" amount for
+restitution purposes. Second, there would be no legal basis for federal restitution without a
+conviction for a federal offense. And, third, it was my belief that this Office should not be put in the
+position of administering a restitution fund. Our Section 2255 proposal put the victims in the same
+position that they would have been in if we had proceeded to trial and convicted Mr. Epstein of his
+3 Another significant compromise reached at the meeting was a reduction in the amount of
+jail time - from twenty-four months down to eighteen months, which would be served at the Palm
+Beach County Jail rather than a state prison facility.
+
+
+
+crimes, with the exception that the victims were provided with counsel.* Your client and his
+attorneys agreed with this alternative.
+The negotiation of the Agreement was lengthy and difficult. Mr. Lefkowitz and AUSA
+Villafaña went through several drafts of both a federal Plea Agreement and a Non-Prosecutior
+Agreement. Throughout these negotiations, when a member of the defense team was dissatisfied
+with the Office's position, it was repeatedly appealed through the Office. So several members of the
+defense team spoke with Andrew Lourie, currently chief of staff to Assistant Attorney General
+Fisher, and FAUSA Sloman regarding the terms of the Agreement, including the Section 225:
+provisions. At the eleventh hour, when your legal team realized that Fl. Stat. 796.03 would requir
+Mr. Epstein to register as a sex offender, you sought to change the most essential term of the
+agreement - a term that Messrs. Goldberger, Lefkowitz, and Lefcourt had specifically agreed to at
+the September 12" meeting with the State Attorney's Office - asking to allow Mr. Epstein to plead
+to a charge that would not require registration. When AUSAs Villafaña, Lourie, and Sloman rejected
+the suggestion, several members of the defense team appealed directly to me, which also failed
+When that failed, according to press reports, apparently Mr. Lefcourt "leaked" a letter intended for
+me to the press containing the reasons why he did not believe Mr. Epstein should have to register.
+Prior to signing the Non-Prosecution Agreement, Mr. Epstein's defense team included
+yourself, Ms. Sanchez, and Messrs. Dershowitz, Lefcourt, Lefkowitz, Lewis, Black, and Goldberger.
+At least one other "criminal law expert" was involved in plea negotiations, and several associates
+at your firm conducted research on discrete issues. This impressive legal team reviewed the
+Agreement and counseled Mr. Epstein. Based upon that counsel, Mr. Epstein decided that it was in
+his best interests to enter into the Non-Prosecution Agreement, and the Non-Prosecution Agreement
+itself is signed both by Mr. Lefcourt and Ms. Sanchez as well as by Mr. Epstein.
+Since the signing of the Agreement on September 24*
+", more than two months' ago, it appears
+that several attorneys on your legal team are dissatisfied with the Agreement. Counsel have objected
+to several steps taken by the U.S. Attorney's Office to effectuate the terms of the Agreement, in
+essence presenting collateral challenges to portions of the Agreement. Your letter is the latest
+example. It is not the intention of this Office ever to force the hand of a defendant to enter into an
+agreement against his wishes. Your client has the right to proceed to trial. If your client is
+dissatisfied with his Agreement, or believes that it is unlawful or unfair, we stand ready to unwind
+the Agreement. One of the reasons the Office agreed to forego federal prosecution was to avoid the
+expenditure of extensive resources, yet these interminable "negotiations" have caused the
+*As FAUSA Sloman will address in his letter to Mr. Lefkowitz, Section 2255 provides that
+the perpetrator shall pay the attorney's fees of the victim, so the appointment of counsel was not such
+a benefit to the victims but, rather, was done, in part, to benefit Mr. Epstein by allowing him to try
+to privately negotiate a group resolution of all claims with one attorney.
+
+
+
+expenditure of excessive management resources, and the Office is unwilling to invest any more of
+those resources. The prosecution of the case also has been delayed almost eight months to allow you
+to raise any and all issues; we will not tolerate any further delay.
+Accordingly, please provide us with a definitive statement, signed by your client, of his
+intention to abide by each and every term of the Agreement by close of business on Tuesday,
+December 4, 2007. By that time, you must also provide us with the agreements) with the State
+Attorney's Office and a date and time certain for the plea and sentencing, which must occur no later
+than December 14, 2007. If we do not receive these items by that time, we will deem the agreement
+to be rescinded and will proceed with the prosecution. There must be closure in this matter.
+Sincerely,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+cc:
+
+
+Southern District of Florida
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+99 N.E. 4 Street
+Miami, FL 33/32
+(305) 961-9100 - Telephone
+(305) 530-6444 - Facsimile
+DELIVERY BY FACSIMILE
+Kenneth W. Starr, Esq
+Kirkland & Ellis LLP
+777 South Figueroa Street
+Los Angeles, CA 90017
+Re:
+Jeffrey Epstein
+Dear Mr. Starr:
+I write in response to your November 28" letter, in which you raise concerns regarding the
+Non-Prosecution Agreement between this Office and your client, Mr. Epstein. I take these concerns
+seriously. As your letter focused on the Section 2255 portion of the Agreement, my response will
+focus primarily on that issue as well. I do wish to make some more general observations, however.
+Section 2255 provides that "[a]ny person who, while a minor, was a victim of a violation of
+[enumerated sections of Title 18] and who suffers personal injury as a result of such violation...
+may sue in any appropriate United States District Court and shall recover the actual damages such
+person sustains and the cost of the suit, including a reasonable attorney's fee." Thus, had this Office
+proceeded to trial, and had Mr. Epstein been convicted, the victims of his actions would have been
+able to seek to relief under this Section.
+The Non-Prosecution Agreement entered into between this Office and Mr. Epstein responds
+to Mr. Epstein's desire to reach a global resolution of his state and federal criminal liability. Under
+this Agreement, this District has agreed to defer prosecution for enumerated sections of Title 18 in
+favor of prosecution by the State of Florida, provided that the Mr. Epstein satisfies three general
+federal interests: (1) that Mr. Epstein plead guilty to a "registerable" offense; (2) that this plea
+include a binding recommendation for a sufficient term of imprisonment; and (3) that the Agreement
+not harm the interests of his victims. This third point deserves elaboration. The intent is to place
+the victims in the same position as they would have been had Mr. Epstein been convicted at trial.
+No more; no less.
+With this in mind, I turn to the language of the Agreement. Paragraph 8 of the Agreement
+provides:
+If any of the individuals referred to in paragraph (7), supra, elects to file suit pursuant
+to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the United States
+
+
+District Court for the Southern District of Florida over his person and/or the subject
+matter,' and Epstein waives his right to contest liability and also waives his right to
+contest damages up to an amount as agreed to between the identified victim and
+Epstein, so long as the identified victim elects to proceed exclusively under 18
+U.S.C. § 2255, and agrees to waive any other claim for damages, whether pursuant
+to state, federal, or common law. Notwithstanding this waiver, as to those
+individuals whose names appear on the list provided by the United States, Epstein's
+signature on this agreement is not to be construed as an admission of any criminal or
+civil liability other than that contained in 18 U.S.C. § 2255.
+Although these two sentences are far from simple, they appear to incorporate our intent to narrowly
+tailor the Agreement to place the identified victims in the same position as they would have been had
+Mr. Epstein been convicted at trial. I would note that I have conferred with our prosecutors and have
+been told that Paragraph 8 was vigorously negotiated and that the final language was suggested
+largely by defense counsel.
+The concerns raised in your letter with respect to Paragraph 8 fall within several general
+categories. First, you raise concerns regarding the nature of Section 2255. As you note,
+Section 2255 is a civil statute implanted in the criminal code; in contrast to other
+criminal statutes, Section 2255 fails to correlate payments to specific injuries or
+losses. Instead the statute presumes that victims have sustained damages of at least
+a minimum lump sum without regard to whether the complainants suffered actual
+medical, physiological or other forms of individualized harm.
+These concerns were, I would expect, aired when Congress adopted this statute. Even if they were
+not, this provision is now law. Rule of law requires now requires this District to consider the
+victims' rights under this statute in negotiating this Agreement.
+Second, you raise concerns regarding the identity-of-the-victims issue. Your concerns appear
+based on the belief that Paragraph 8 is a blanket waiver of liability with respect to any number of
+unnamed and undisclosed victims. I would invite you to confer with your co-counsel regarding this
+matter. Although the language of Paragraph 8 could be so construed, our First Assistant informed
+Mr. Lefkowitz some weeks ago that this was not our position. As Mr. Lefkowitz has noted, were
+Mr. Epstein convicted at trial, the plaintiff-victims in a subsequent Section 2255 suit would still have
+had some burden to prove that they were "victims." It is also the case, however, that were Mr.
+Epstein convicted at trial, the plaintiff-victims would not have to show that a violation of an
+enumerated section of Title 18 took place. Accordingly, our First Assistant informed Mr. Lefkowitz
+some weeks ago that we understood that if a victim-plaintiff elects to proceed to trial, Mr. Epstein's
+' Although not identified as an issue by defense counsel, having reviewed this language, 1 note that
+Paragraph 8 raises the question of what is meant by "subject matter." I have conferred with the AUSA who
+negotiated this language, and have been informed that parties intended this to address issues of venue. This
+Office will not interpret this paragraph as any waiver of subject matter jurisdiction. Please inform me if
+defense counsel disagrees.
+-2-
+
+
+legal team might conduct due diligence to confirm the that victim-plaintiff in fact had inappropriate
+contact with Mr. Epstein. Once again, our interpretive principle is our intent to place the victim in
+the same position she would have been had Mr. Epstein proceeded to trial.
+Third, you raise concerns regarding our decision not to create a restitution fund. Throughout
+the negotiations, defense counsel suggested several similar arrangements, including a Trust fund.
+Again, our decision not to create a fund flows from our belief that the Agreement should provide the
+same relief to the victims as they would have been entitled had we proceeded to trial. A restitution
+fund or trust fund would place an upper limit on the victims' recovery. It is not for this Office to
+make that decision for the victims. They may choose to walk away, they may choose to settle, or
+they may choose to sue. The choice should remain with each individual victim.?
+Fourth, you raise concerns regarding the selection process for the attorney representative.
+As you may be aware, the suggestion that we appoint an attorney representative originated with
+defense counsel. Defense counsel, I believe, found it advantageous to attempt to negotiate a
+settlement of the many victims" claims with one attorney representative. My Office agreed to
+appoint such a representative, in part, because we too thought it valuable for the victims to have the
+advice of an attorney who could advise them of their choices: whether to walk away, to settle or to
+SUe.
+Since the signing of the Agreement, several issues have arisen with respect to this provision.
+First, I elected to assign this Office's right to appoint the representative to an independent third-party,
+former federal Judge
+• I did this to avoid any suggestion that this Office's choice of
+representative was intended to influence the outcome of civil litigation. Second, your co-counsel
+expressed concerns similar to those raised in your letter regarding the criteria used to select the
+representative. These criteria were:
+(1) Experience doing both plaintiffs' and defense litigation;
+(2) Experience with state and federal statutory and common law tort claims;
+(3) Ability to communicate effectively with young women;
+(4) Experience litigating against large law firms and high profile attorneys who may
+test the veracity of the victims' claims;
+(5) Sensitivity to the nature of the suit and the victims' interest in maintaining their
+privacy;
+(6) Experience litigating in federal court in the Southern District of Florida;
+= Your letter references U.S. | Boehm, No. 3:04CR00003 (D. Ala 2004) as a model for a restitution fund
+settlement. I asked our prosecutor to contact the AUSA in that case. In that matter, the District of Alaska
+sought out and obtained the consent of all the victims before entering into that settlement. In addition, they
+developed an elaborate procedure for deciding which victim would receive what. My view, in this case, is
+that those types of negotiations are better handled between Mr. Epstein and the victims' representatives, and
+that this Office should not act as intermediary. Finally, I would note that in Boehm as well, the victims'
+identities were not initially disclosed. As the AUSA wrote in that case: "This filing is made ex parte
+because Boehm, in his plea agreement, waived any rights he had pertaining to the selection of beneficiaries
+and the disbursement of funds to such beneficiaries."
+-3-
+
+
+(7) The resources to hire experts and others, while working on a contingency fee
+basis, in order to prepare for trial if a settlement cannot be reached (defense counsel
+has reserved the right to challenge such litigation); and
+(8) The ability to negotiate effectively.
+At my direction, our First Assistant provided our criteria to your co-counsel, Mr. Lefkowitz, in
+advance, and at co-counsel's request, he noted in our communication with Judgel
+i, defense
+counsel's objection to criteria 7. I have now reviewed these criteria and find them balanced and
+reasonable. They appear designed to provide the victims with an attorney who can advise them on
+all their options, whether it be to walk away, to settle (as your client prefers), or to litigate. Again,
+our intent is not to favor any one of these options, but rather to leave the choice to each victim.
+Fifth, you assert that this Office "has improperly insisted that the chosen attorney
+representative should be able to litigate the claims of the individuals," should a resolution not be
+possible. This issue, likewise, has already been raised and addressed in discussions between your
+co-counsel and our First Assistant. We understand your position that it would be a conflict of
+interest for the attorney representative to subsequently represent victim-plaintiffs in a civil suit. Your
+interpretation of the ethics rules may be correct, or it may be wrong. Far from insisting that the
+attorney representative can represent victim-plaintiffs in subsequent litigation, our First Assistant
+and I have repeatedly told defense counsel that we take no position on this matter. Indeed, I fully
+expect your defense team to litigate this issue with the attorney representative if a resolution is not
+reached.
+I have responded personally and in some detail to your concerns because I deeply care about
+both the law and the integrity of this Office. I have responded personally and in some detail as well
+because your letter troubled me on a number of levels. My understanding of the negotiations in this
+matter informs my concerns.
+The Section 2255 provision issue was first discussed at a July 31, 2007, meeting between
+FAUSA Sloman, Criminal Chief Menchel, West Palm Beach Chief Lourie, AUSA Villafaña, and
+two FBI agents who met with Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. On that date, the
+prosecutors presented a written, four-bullet-point term sheet that would satisfy the federal interest
+in the case and discussed the substance of those terms. One of these four points was the following
+provision:
+Epstein agrees that, if any of the victims identified in the federal investigation file
+suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the U.S.
+District Court for the Southern District of Florida over his person and the subject
+matter. Epstein will not contest that the identified victims are persons who, while
+minors, were victims of violations of Title 18, United States Code, Sections(s) 2422
+and/or 2423.
+-4-
+
+
+In mid August 2007, your defense team, dissatisfied with my staff's review of the case, asked
+to meet with me. Mr. Lefkowtiz indicated your busy schedule, and asked me to put off until
+September 7, 2007, so that you could attend. Mr. Lefkowitz also indicated that he might appeal my
+decision to Washington D.C., if my decision was contrary to his client's interest. I agreed to the
+September 7 meeting, despite the fact that our AUSA had an indictment ready for presentation to
+the grand jury. An explicit condition of that agreement, however, was an understanding between Mr.
+Lefkowitz and myself that any appeal to Washington would be undertaken expeditiously.
+On September 7, 2007, I, along with FAUSA Sloman, AUSAs McMillan and Villafaña, and
+FBI agents, met with you, Mr. Lefkowitz, and Ms. Sanchez. I understood that you wished to present
+federalism-based concerns regarding our prosecution. To ensure a full consideration of your
+arguments, I invited Drew Oosterbaan, Chief of the Criminal Division's Child Exploitation and
+Obscenity Section, to travel from Washington to attend our meeting. During the September 7'h
+meeting, your co-counsel, Mr. Lefkowitz, offered a plea resolution. The inclusion of a Section 2255
+remedy was specifically raised and discussed at the September 7" meeting. Indeed, according to
+AUSA Villafaña's notes, you thanked her for bringing it to your attention. Again, no objection to
+the Section 2255 issue was raised.
+After considering the arguments raised at the September 7 meeting, and after conferring
+with the FBI and with Chief Oosterbaan, our Office decided to proceed with the indictment. At that
+time, I reminded Mr. Lefkowitz that he had previously indicated his desire to appeal such a decision
+to the Attorney General, the Deputy Attorney General, or the Assistant Attorney General for the
+Criminal Division, and I offered to direct our prosecutors to delay the presentation of the indictment
+to allow you or he to appeal our decision if you so chose. He decided not to do so.
+Instead, Mr. Epstein elected to negotiate the Non-Prosecution Agreement. These negotiations
+were detailed and time-consuming. Mr. Epstein's defense team, including yourself, Professor
+Dershowitz, former United States Attorney Guy Lewis, Ms. Lilly Ann Sanchez and Messrs. Roy
+Black, Jack Goldberger, Gerry Lefcourt and Jay Lefkowitz had the opportunity to review and raise
+objections to the terms of the Agreement. Again, no one raised objections to the Section 2255
+language.
+Since the signing of the Agreement, the defense team and our Office have addressed several
+issues that have arisen under the Agreement. Although the exchanges were at times a bit litigious,
+it appears that these issues have been resolved by mutual consent, some in favor of your client, some
+not so.
+It is against these many previous foregone opportunities to object that I receive with surprise
+your letter requesting an 11" hour, after-the-fact review of our Agreement. Although it happens
+rarely, I do not mind this Office's decision being appealed to Washington, and have previously
+directed our prosecutors to delay filings in this case to provide defense counsel with the option of
+appealing our decisions. Indeed, although I am confident in our prosecutors' evidence and legal
+analysis, I nonetheless directed them to consult with the subject matter experts in the Criminal
+-5-
+
+
+Division's Child Exploitation and Obscenity Section to confirm our interpretation of the law before
+approving their indictment package. I am thus surprised to read a letter addressed to Department
+Headquarters that raises issues that either have not been raised with this Office previously or that
+have been raised, and in fact resolved, in your client's favor.
+I am troubled, likewise, by the apparent lack of finality in this Agreement. The AUSAs who
+have been negotiating with defense counsel have for some time complained to me regarding the
+tactics used by the defense team. It appears to them that as soon as resolution is reached on one
+issue, defense counsel finds ways to challenge the resolution collaterally. My response thus far has
+been that defense counsel is doing its job to vigorously represent the client. That said, there must
+be closure on this matter. Some in our Office are deeply concerned that defense counsel will
+continue to mount collateral challenges to provisions of the Agreement, even after Mr. Epstein has
+entered his guilty plea and thus rendered the agreement difficult, if not impossible, to unwind.
+Finally, I am most concerned about any belief on the part of defense counsel that the
+Agreement is unethical, unlawful or unconstitutional in any way.?
+In closing, I would ask that you consult with co-counsel. If after consultations within the
+defense team, you believe that our Agreement is unethical, unlawful or unconstitutional, I would ask
+that you notify us immediately so that we can discuss the matter by phone or in person. I have
+consulted with the chief prosecutor in this case, who has advised me that she is ready to unwind the
+Agreement and proceed to trial if necessary or if appropriate.
+I would reiterate that it is not the intention of this Office ever to force the hand of a defendant
+to enter into an agreement against his wishes. Your client has the right to proceed to trial. Although
+time is of the essence (I understand that certain filings are due to our Office no later than December
+Tih and that certain events must take place no later than December 14), I am directing our
+prosecutors not to issue victim notification letters until this Friday at 5 p.m., to provide you with time
+to review these options with your client. We are available by phone or in person, in the interim, to
+' It is not clear from your letter whether you believe that attorneys in this Office have acted improperly.
+Your letter, for example, alludes to the need to engage in an inquiry to assure that disclosures to potential
+witnesses did not undermine the reliability of the results of this federal investigation. As a former
+Department of Justice attorney, I am certain that you recognize that this is a serious allegation. I have
+raised this matter with AUSA Villafaña who informed me that the victims were not told of the availability
+of Section 2255 relief during the investigation phase of this matter. If you have specific concerns, 1 ask that
+you raise these with me immediately, so that I can make appropriate inquiries.
+-6-
+
+
+address any matters that might remain unaddressed in this letter. We expect a written decision by
+this Friday at 5 p.m., indicating whether the defense team wishes to reaffirm, or to unwind, the
+Agreement.
+Sincerely,
+P. MAD
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+CC:
+Alice Fisher, Assistant Attorney General
+-7-
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/c209362970822abb3322c08aa55ffff3757f2325eb3197bd693423fc3c3b83b4.receipt.json b/vision-fixhub/ds9-unparsed-05/c209362970822abb3322c08aa55ffff3757f2325eb3197bd693423fc3c3b83b4.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..865d1f4bde906b867f4e9cf872f45bdcf7583866
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c209362970822abb3322c08aa55ffff3757f2325eb3197bd693423fc3c3b83b4.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -861,
+  "dataset": "marble-joined",
+  "doc_id": "c209362970822abb3322c08aa55ffff3757f2325eb3197bd693423fc3c3b83b4",
+  "engine": "marble-apple-vision",
+  "event_count": 27,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "a455a2c62f520cf92a7f861d2ab9f8ba90740118f8289c986d669632c1ec0005",
+  "output_sha256": "23a2ccf9f65ade6ce5509efd2abbe3753b0c75cae32c2a51e29bca55db11bac0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c211eb5c0a0ff241ab9c513170498d07bd7c1dccf14a097d21d390eba650891a.md b/vision-fixhub/ds9-unparsed-05/c211eb5c0a0ff241ab9c513170498d07bd7c1dccf14a097d21d390eba650891a.md
new file mode 100644
index 0000000000000000000000000000000000000000..af97992ea6dc2a5d6b2447c7f71f60547996a94a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c211eb5c0a0ff241ab9c513170498d07bd7c1dccf14a097d21d390eba650891a.md
@@ -0,0 +1,163 @@
+06/23/2818 11:03
+
+PAGE 02/87
+DRAFT - FOR DISCUSSION ONLY
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+Jane Doe,
+Plaintift,
+:
+:
+-against-
+JEFFREY EPSTEIN,
+08-CV-90119
+(Southern District of Florida)
+STIPULATION OF
+CONFIDENTIALITY
+Defendant.
+WHEREAS, plaintiff Jane Doe and defendant Jeffrey Epstein ("Epstein") are presently
+engaged in discovery in the above-captioned civil action pending in the United States District
+Court for the Southern District of Florida;
+WHEREAS, thirteen related civil actions are currently pending against defendant
+Epstein: (collectively with the above-captioned action, the "Related Pending Actions"). The
+Related Pending Actions are identified on Schedule A attached hereto;
+WHEREAS, counsel in all Related Pending Actions shail be collectively referred to
+herein as ("'Counsel");
+WHEREAS, Ghislaine Noelle Maxwell ("Maxwell"), a non-party, was served with a
+subpoena dated September 21, 2009 issued out of the United States District Court for the
+Southern District of New York (the "Subpoena'") to testify at a deposition in connection with the
+above-captioned matter;
+WHEREAS, Maxwell has requested, and Counsel has agreed, that all aspects of her
+involvement in this matter, including but not limited to, the issuance of the Subpoena, the fact of
+
+
+
+PAGE 03/87
+DRAET - FOR DISCUSSION ONLY
+Maxwell's appearance for deposition, and/or the substance of Maxwell's testimony is to be
+afforded the highest degree of confidentiality;
+IT IS HEREBY STIPULATED AND AGREED as follows:
+1.
+The deposition taken pursuant to the subpoena (the "Maxwell Deposition" will
+be Counsel's sole opportunity to examine Maxwell in connection with the Related Pending
+Actions. Failure of any Counsel to participate in the Maxwell Deposition shall waive that
+counsel's right to examine Maxwell in connection with any of the Related Pending Actions;
+2. The Maxwell Deposition will be limited to one seven hour day and will be
+conducted at the offices of her counsel, Cohen & Gresser LLP, 100 Park Avenuc, New York,
+NY:
+Counsel will not examine, or attempt to examine, Maxwell with regard to her
+personal sexual conduct or her sexual relationship with defendant Jeffrey Epstein except to the
+extent that counsel has a good faith basis to believe that such conduct is directly related to
+criminal activity on the part of Jeffrey Epstein;
+Counsel shall keep confidential and refrain from any public disclosure or
+dissemination whatsoever the transcript and/or any audio or videotape recording of the Maxwell
+Deposition. To the extent excerpts from or transcripts of the Maxwell Deposition are to be filed
+with any court in connection with any of the Related Pending Actions, Counsel must make best
+efforts to secure an order permitting the filing of those materials under seal. Counsel for
+Maxwell will be given notice of any such filing prior to Counsel seeking such a sealing order
+from the appropriate court. All parties acknowledge that should any of the Related Pending
+Actions against Jeffrey Epstein proceed to trial, the deposition video and/or transcript will likely
+be published to the jury in whole or part; nothing in this agreement shall prohibit such ordinary
+2
+
+
+
+PAGE 04/07
+DRAFT - FOR DISCUSSION ONLY
+trial usage of Maxwell's deposition nor place any edditional constraints on any party related to
+the usage of Maxwell's deposition in the trial.
+5. Counsel shall keep confidential and refrain from any public comment or
+disclosure whatsoever (including but not limited to disclosure or comment to the press and/or
+media): (i) the fact that Maxwell has been subpoenaed for deposition in connection with the
+Related Pending Actions; (ii) the fact that Maxwell has appeared for deposition in the Related
+Pending Actions; (ili) any substance whatsoever of the Maxwell Deposition; or (iv) any other
+facts or opinions whatsoever referring to or referencing Maxwell in connection with the Related
+Pending Actions. This provision shall be construed as broadly as possible to expressly prohibit
+any public comment or disclosure (including but not limited to the press and/or media) by
+Plaintiffs' Counsel with regard to Maxwell or her involvement in this matter.
+6.
+Upon the conclusion of each of the Related Pending Actions, all transcripts and/or
+any audio or videotape recordings of the Maxwell Deposition maintained in connection with the
+concluded Related Pending Action, shall be destroyed within thirty (30) days. Certification of
+destruction shall be provided to Maxwell's counsel within thirty (30) days of such destruction.
+7. Plaintiffs' Counsel hereby acknowledges that any violation of the Terms and
+Conditions in Paragraphs 4 and 5 above (the "Confidentiality Provisions"), will result in
+irreparable harm to Maxwell. In the event of such violation, Counsel expressly agrees:
+That such a violation constitutes sanctionable conduct pursuant to the law,
+Federal Rules of Civil Procedure, and court rules of the United States
+District Court of the Southern District of New York;
+3
+
+
+
+PAGE 05/87
+DRAFT - FOR RISCUSSION ONLY
+b.
+To immediately undertake all efforts to prevent the further public
+dissemination of disclosures made in violation of the Confidentiality
+Provisions;
+c.
+That the Maxwell Deposition shall be rendered null and void, and cannot
+be used in any way in connection with the Pending Related Actions or any
+other litigation;
+d.
+That Maxwell may seek injunctive relief (including a Temporary
+Restraining Order), to prevent the use or further dissemination of the
+Maxwell Deposition, and that Maxwell will not be required to post a bond
+in connection with obtaining such relief; and
+e.
+To pay a liquidated damages to Maxwell upon Maxwell's prevailing in
+whole or in part in any action alleging a breach of this agreement equal to
+Maxwell's total legal fees and costs related to the Subpoena and/or
+Maxwell's involvement in the Related Pending Actions.
+The United States District Court of the Southern District of New York shall have
+exclusive jurisdiction over all claims or disputes arising out of or related to this agreement. This
+agreement shall be interpreted in accordance with New York law, without regard to choice of
+law principles.
+Nothing in this agrcement shall serve to waive any substantive right provided by
+applicable law and/or the Federal Rules of Civil Procedure, and all signatories hereto expressly
+reserve all substantive rights with regard to the Maxwell Deposition. The parties hereto
+expressly reserve the right to seck Court intervention in aid of such substantive rights.
+4
+
+
+06/23/2810 11:03
+
+COHEN & GRESSER LLP
+By:
+Brett D. Jaffe
+100 Park Avenuc, 23rd Floor
+New York, NY 10017
+Attorneys for Ghislaine Noelle Maxwell
+Dated:
+DRAFT - FOR DISCUSSION ONLY
+FARMER, JAFFE, WEISSING, EDWARDS,
+FISTOS & LEHRMAN, PL
+By:.
+Bradley J. Edwards
+425 N. Andrews Ave., Suite 2
+Fort Lauderdale, FL 33301
+Attorneys for Plaintiff Jane Doe
+Dated:
+GARGA LAW FIRM PA
+By:.
+Istaro Maget Garcia
+22% Datura St., Suite. 900
+West Palm Beach, FL 33401
+Atorneys for Plamil Jou doe II
+Dated:
+BURMAN, CRITTON, LUTTIER &
+COLEMAN, LLP.
+By:.
+Michael James Pike
+PAGE 06/07
+Dated:
+5
+
+
+06/23/2010
+11:03
+
+PAGE 07/87
+DRAFT - FOR DISCUSSION ONLY
+6
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/c211eb5c0a0ff241ab9c513170498d07bd7c1dccf14a097d21d390eba650891a.receipt.json b/vision-fixhub/ds9-unparsed-05/c211eb5c0a0ff241ab9c513170498d07bd7c1dccf14a097d21d390eba650891a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..66397d8e003342ae02a88045c767e976a6dda6de
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c211eb5c0a0ff241ab9c513170498d07bd7c1dccf14a097d21d390eba650891a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -431,
+  "dataset": "marble-joined",
+  "doc_id": "c211eb5c0a0ff241ab9c513170498d07bd7c1dccf14a097d21d390eba650891a",
+  "engine": "marble-apple-vision",
+  "event_count": 13,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "49fa810c54b93ebb3a54777b03c0a8ff27f9f75853bd3333282826fc1d508969",
+  "output_sha256": "477bf146166ebf52f3052cd2a70e5bd5700725940c1f6432b0bf1248cfe5f4fc",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c3e8598d3059dfd4fab6e3f352a33e8c4affe5f7858bc7027a7aed18158f0a18.md b/vision-fixhub/ds9-unparsed-05/c3e8598d3059dfd4fab6e3f352a33e8c4affe5f7858bc7027a7aed18158f0a18.md
new file mode 100644
index 0000000000000000000000000000000000000000..adc58cfd7853c6309830599bf26abc680afe73d0
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c3e8598d3059dfd4fab6e3f352a33e8c4affe5f7858bc7027a7aed18158f0a18.md
@@ -0,0 +1,89 @@
+5/22/07 Lefcount to,
+
+
+LAW OFFICES OF
+GERALD B. LEFCOURT, P.C.
+A PROFESSIONAL CORPORATION
+148 EAST 78™ STREET
+NEW YORK, NEW YORK 10021
+GERALD B. LEFCOURT
+lefcourt@lefcourtlaw.com
+SHERYL E. REICH
+RENATO C STABILE
+FAITH A. FRIEDMAN
+TELEPHONE
+FACSIMILE
+May 22, 2007
+VIA E-MAIL
+Office of the United States Attorney
+Southern District of Florida
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Jeffrey Epstein
+Dear
+I write as counsel to Jeffrey Epstein, the subject of a grand jury investigation being
+conducted by your office.
+I understand from you that in the next month or two a decision will be made by your
+office whether to seek an indictment of Mr. Epstein. This will confirm that, prior to any such
+deceit veingmade, I and other attorneys on behalf of Mr. pstein will be given an opportunity
+Additionally, because we believe that any decision to indict requires both a complex legal
+analysis in a detailed factual context and resolution of significant policy concerns, if our meeting
+does not resolve the matter, we would like an opportunity to make a presentation first to
+Attorney, and then, again, if no resolution is reached, the opportunity to meet with United States
+
+
+LAW OFFICES OF
+GERALD B. LeFcouRT, P.C.
+Office of the United States Attorney
+Southern District of Florida
+May 22, 2007
+Page 2
+Attorney Alexander Acosta.
+Thank you for your cooperation in this matter. If you have any questions, please do not
+hesitate to call.
+Very truly yours,
+Gerald B. Lefcourt
+CC.
+Lilly Ann Sanchez, Esq.
+
+
+Villafana, Ann Marie C. (USAFLS)
+From:
+Sent:
+To:
+Cc:
+Subject:
+Attachments:
+Lourie, Andrew (USAFLS)
+Tuesday, May 22, 2007 3:11 PM
+Menchel, Matthew (USAFLS); Sloman, Jeff (USAFLS)
+Villafana, Ann Marie C. (USAFLS)
+FW: Jeffrey Epstein
+2007-05-22 letter to AUSA Lourie.pdf
+Gentlemen,
+Marie and I have already met with Lefcourt, which is really the meeting | promised him. I spoke to him last week and he
+said he had more information they wanted to present. I told him he could make an appointment to come in again if he
+wanted to and that we would meet with him again, but I did not promise that we would wait to give him a meeting
+"before" we charged.
+So, I think he is really ready for the next level rather than a second meeting with me. Mike Tein also mentioned to me
+at some point that they wanted to make a presentation on the law and I suggested to him that he contact Matt without
+telling him exactly what stage of review we were at. I don't know if Tein and Lefcourt have crossed wires or not.
+In any event, I am forwarding this letter to you. I am going to suggest to Lefcourt the same thing that I suggested to
+Tein. I assume you would grant his attorneys a chance to make whatever presentation they desire. It would probably
+be helpful to us in any event to hear their legal arguments in case we have missed something. Whether Alex would be
+present or grant them another meeting after that is his call.
+Andy
+From: Gerald Lefcourt [mailto:GBL@lefcourtlaw.com]
+Sent: Tuesday, May 22, 2007 2:05 PM
+To: Lourie, Andrew (USAFLS)
+Cc: Villafana, Ann Marie C. (USAFLS); Lilly Ann Sanchez
+Subject: Jeffrey Epstein
+Andy, attached is a letter seeking meetings, as discussed with you, but with others if it is not resolved. Thanks for your
+attention. Could you email back so that I know you have received this letter?
+Gerald B. Lefcourt
+Gerald B. Lefcourt, P.C.
+148 E. 78th Street
+New York. New York 10021
+Tel.
+Fax
+gbl@lefcourtlaw.com
diff --git a/vision-fixhub/ds9-unparsed-05/c3e8598d3059dfd4fab6e3f352a33e8c4affe5f7858bc7027a7aed18158f0a18.receipt.json b/vision-fixhub/ds9-unparsed-05/c3e8598d3059dfd4fab6e3f352a33e8c4affe5f7858bc7027a7aed18158f0a18.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..636e18911181ad61feaaa96d108dd9824397c68e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c3e8598d3059dfd4fab6e3f352a33e8c4affe5f7858bc7027a7aed18158f0a18.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -48,
+  "dataset": "marble-joined",
+  "doc_id": "c3e8598d3059dfd4fab6e3f352a33e8c4affe5f7858bc7027a7aed18158f0a18",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3db3b85e1ac95f1e6f585935d6f17840f92084fcb0bbf45c93039d2c1e1378dd",
+  "output_sha256": "5af7de132bcc176abce2180a113a5f1d8a5f11a5acdca16ac57bfd598ccf46b3",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c51ad68b43f6843bba65b5d0df480d385dd11e5630878359135b089c6b560a4c.md b/vision-fixhub/ds9-unparsed-05/c51ad68b43f6843bba65b5d0df480d385dd11e5630878359135b089c6b560a4c.md
new file mode 100644
index 0000000000000000000000000000000000000000..4c2efe64893786c6a9b64813b7dff537922494ce
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c51ad68b43f6843bba65b5d0df480d385dd11e5630878359135b089c6b560a4c.md
@@ -0,0 +1,138 @@
+Villafana, Ann Marie C. (USAFLS)
+From:
+Sent:
+To:
+Subject:
+Attachments:
+MAIL. < MAIL@flabar.org>
+Tuesday, November 04, 2008 12:22 PM
+Re: FW: Request for Written Staff Opinion ATTN Elizabeth Clark Tarbert; Logbook #
+28386
+graycol.gif; 28386gef denial.doc; Florida Bar Ltr re Ethics Opinion.pdf; Final Victim
+Notification -- Sample.pdf, Final Victim Notification Represented Sample.pdf
+Dear!
+My letter in response to your inquiry is attached below. This letter will be faxed and mailed to you later today.
+If you have questions, please do not hesitate to call me at
+Sincerely,
+Gail E. Ferguson
+Assistant Ethics Counsel
+(See attached file: 28386gef denial.doc)
+on 09/29/2008 12:05:05 PM
+To: "Ethics Opinions" < etopinion@flabar.org>
+Subject: FW: Request for Written Staff Opinion ATTN Elizabeth Clark Tarbert; Logbook # 28386
+Staff: Gail Ferguson/The Florida Bar
+Dear Ms. Tarbert - Here is my earlier e-mail.
+Thank you.
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+P-015234
+
+
+From:
+Sent: Thursday, September 18, 2008 7:21 PM
+To: eto@flabar.orq
+Cc:
+Subject: Request for written Stair Opinion
+Dear Sir or Madam: Please see the attached correspondence. Thank you for your assistance.
+<<Florida Bar Ltr re Ethics Opinion.pdf>>
+<<Final Victim Notification -- Sample.pdf>>
+<<Final Victim Notification Represented Sample.pdf>>
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+(See attached file: Florida Bar Lir re Ethics Opinion.pdf (See attached file: Final Victim
+Notification -- Sample.pdj) (See attached file: Final Victim Notification Represented Sample.pdf)
+P-015235
+
+
+VIA FACSIMILE (561) 820-8777
+& U.S. MAIL
+Assistant United States Attorney
+Southern District of Florida
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Re: Ethics Inquiry 28386
+Dear
+I received your request for an advisory ethics opinion dated September 18, 2008. You ask
+whether you violated Rule 4-7.4, Rules Regulating The Florida Bar, by complying with your
+statutory obligation to contact victims to inform them of the resolution of their matters and by
+complying with a court order to advise them that the services of an independent attorneyrepresentative would be offered to them free of charge.
+Unfortunately, I cannot provide the opinion you requested, because you are asking about your
+past conduct and legal questions that relate to your obligations under federal statutes and a court
+order. Florida Bar ethics attorneys are only authorized to provide opinions regarding an
+attorney's own future conduct. We are not authorized to render opinions concerning an
+attorney's past conduct or legal questions. See Procedures 2 (a)(1)(B) and 2(a)(1)(D), Florida
+Bar Procedures for Ruling on Questions of Ethics (www.floridabar.org).
+Although I cannot provide an opinion, I can discuss the relevant rules. Generally speaking, Rule
+4-7.4 (a), prohibits an attorney from soliciting clients in person or through an agent, or in writing
+without complying with the attorney advertising rules, if the lawyer's primary motive is
+pecuniary gain, and states:
+(a) Solicitation. Except as provided in subdivision (b) of this rule, a lawyer
+shall not solicit professional employment from a prospective client with whom the
+lawyer has no family or prior professional relationship, in person or otherwise, when
+a significant motive for the lawyer's doing so is the lawyer's pecuniary gain. A
+lawyer shall not permit employees or agents of the lawyer to solicit in the lawyer's
+behalf. A lawyer shall not enter into an agreement for, charge, or collect a fee for
+professional employment obtained in violation of this rule. The term "solicit"
+P-015236
+
+
+Ms. A. Marie Villafana
+Page 2
+includes contact in person, by telephone, telegraph, or facsimile, or by other
+communication directed to a specific recipient and includes (i) any written form of
+communication directed to a specific recipient and not meeting the requirements of
+subdivision (b) of this rule, and (il) any electronic mail communication directed to a
+specific recipient and not meeting the requirements of subdivision (c) of rule 4-7.6.
+Emphasis added. If your contact with victims is neither motivated by pecuniary gain nor to assist
+another lawyer whose significant motive is pecuniary gain, then it is unlikely that your contact
+with victims could be characterized as improper solicitation in violation of Rule 4-7.4 (a).
+Although your letter does not reference Rule 4-4.2 (*Communication with Person Represented
+by Counsel"), this rule prohibits a lawyer from communicating directly with a person the lawyer
+knows is represented in a particular matter, and states:
+(a) In representing a client, a lawyer shall not communicate about the subject of
+the representation with a person the lawyer knows to be represented by another
+lawyer in the matter, unless the lawyer has the consent of the other lawyer.
+Notwithstanding the foregoing, an attorney may, without such prior consent,
+communicate with another's client in order to meet the requirements of any court
+rule, statute or contract requiring notice or service of process directly on an adverse
+party, in which event the communication shall be strictly restricted to that required by
+the court rule, statute or contract, and a copy shall be provided to the adverse party's
+attorney.
+Emphasis added. It would be prudent for you to comply with this rule by limiting your contact to
+the lawyers of represented victims. Whether or not you were required to comply with this rule in
+the past, or whether you would be required to comply with it in the future, given your obligations
+under the federal statutes and the relevant court order involves legal questions beyond the scope
+of an ethics opinion.
+Finally, Rule 4-3.4, prohibits a lawyer from deliberately violating a court's order, and states:
+A lawyer shall not:
+(c) knowingly disobey an obligation under the rules of a tribunal except for an
+open refusal based on an assertion that no valid obligation exists;
+Emphasis added.
+P-015237
+
+
+Ms. A. Marie Villafana
+Page 3
+Thus, Rule 4-3.4 (c), requires you to comply with any orders issued by the court. Again, I can
+provide no opinion on how to accomplish compliance, because interpretation of the court order
+requires legal advice beyond the scope of an ethics opinion.
+If you disagree with my denial of' your request for an advisory ethics opinion, you have thirty (30)
+days to request that the Professional Ethics Committee review the denial. A request for review
+must be addressed to Elizabeth Clark Tarbert, Ethics Counsel, at 651 E. Jefferson Street,
+Tallahassee, Florida 32399. The request must be postmarked no later than thirty (30) days from
+the date of this letter, not the date of receipt. The request must contain the original inquiry
+number and clearly state the issues for review. You may include a written argument explaining
+why you believe you should be issued an advisory ethics opinion. Procedures governing your
+request for review and committee procedures may be found in Procedures 3(d), 4 and 6, Florida
+Bar Procedures for Ruling on Questions of Ethics (available on The Florida Bar's website at
+www.floridabar.org). The Professional Ethics Committee meets approximately four times per
+year. You will be notified of the committee's decision promptly.
+If you have any questions, please call me at
+Sincerely,
+Gail E. Ferguson
+Assistant Ethics Counsel
+GEF/gef
+28386gef denial
+P-015238
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/c51ad68b43f6843bba65b5d0df480d385dd11e5630878359135b089c6b560a4c.receipt.json b/vision-fixhub/ds9-unparsed-05/c51ad68b43f6843bba65b5d0df480d385dd11e5630878359135b089c6b560a4c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4034091ae7b0a1d3fcf95dbc97d4b33027722869
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c51ad68b43f6843bba65b5d0df480d385dd11e5630878359135b089c6b560a4c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -204,
+  "dataset": "marble-joined",
+  "doc_id": "c51ad68b43f6843bba65b5d0df480d385dd11e5630878359135b089c6b560a4c",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "155a5889a37097e6589d6f6e2ec333cfb58b7650c17687527b0d07799eb16bb7",
+  "output_sha256": "f14b5bcf553bb1a252ad6807ea25040dcc0962ef2285147728978b048af17cbf",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c605c49357dee7b2982a5655eaa4b188ecc940e675c45998f3b5d1fcb02afafc.md b/vision-fixhub/ds9-unparsed-05/c605c49357dee7b2982a5655eaa4b188ecc940e675c45998f3b5d1fcb02afafc.md
new file mode 100644
index 0000000000000000000000000000000000000000..a09f6d83efb75c0dd8a29d843028757f62c77262
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c605c49357dee7b2982a5655eaa4b188ecc940e675c45998f3b5d1fcb02afafc.md
@@ -0,0 +1,5126 @@
+404
+process, messenger service, transportation, building. Government moved for partial sumand deposition transcripts). The Second Cir- mary judgment. The District Court, Chin, J.
+cuit, however, has disallowed reimbursement held that: (1) lease unambiguously provided
+for computer research on the grounds that it
+that written consent to sublease was re-
+"is merely a substitute for an attorney's time
+quired, precluding claim that government
+that is compensable under an application for
+orally consented to sublease; (2) court could
+attorneys' fees and is not a separately taxapply federal common law to question of
+able cost." United States | Merritt Meridi- whether landlord's consent to sublease was
+an Const. Corp, 95 F.3d 158, 178_(2d Cir.
+subject to requirement that it not be unrea-
+1996); see also LeBlanc-Sternberg |. Fletch- sonably withheld; (3) court would apply law
+e; 143 F.3d 748, 763 (2d Cir.1998). There- of New York, as there was no federal comfore, I will not allow plaintiff's attorney to be
+mon law on question and no need to create
+reimbursed $125.13 for her computer reany; and (4) under New York law there was
+no requirement that consent not be unreaccordingly, plaintill's attorney is entitle
+) an award of costs in this case in th
+amount of $3,525.86.
+sonably withheld.
+Motion granted.
+CONCLUSION
+For the foregoing reasons, plaintiff's mo- 1. Contracts e=147(2)
+tion for attorney's fees and costs, pursuant to
+42 U.S.O. $ 1988, is granted in part, and intert leagy emen unate forth the parties
+plaintiff's attorney, Margaret Somerset, is
+awarded $94,738.16. That sum shall be paid
+need look no further.
+within forty-five (45) days of the entry of this
+IT IS SO ORDERED.
+Vhether the text of an agreement i
+mbiguous or unambiguous is a matter of la
+to be decided by the court.
+3. Contracts e-143(2)
+contract is not deemed ambiguous ur
+ess it is reasonably susceptible of more tha
+UNITED STATES of America, Plaintiff,
+one interpretation, and the court makes this
+determination by reference to the contract
+Jeffrey E. EPSTEIN, Ivan S. Fisher, Ellyn
+alone.
+Bank, Debra Elisa Cohen, Diane Fisher
+d/b/a the Fisher Group, Fisher & Soffer 4. United States (=7UCT)
+a/k/a Fisher & Sophir,
+D. Ger-
+Provision of lease with United States as
+zog, Robert Heilbrun, Suzanne McDer- landlord, that "Tenant may sublet...with the
+mott, Christopher H. Martin, Jesse Sie- advance written permission of Landlord,"
+gel a/k/a Jessie Siegel, Siegel, Martin & precluded any oral sublease agreement.
+Heilbrun, Ron Soffer, and Carmen Tausik, Defendants.
+5. Landlord and Tenant (-76(3)
+No. 96 CIV. 8307(DC).
+Generally, under New York law, when a
+United States District Court,
+lease requires a tenant to obtain the prior
+S.D. New York.
+written consent of the landlord to sublet or
+assign leased premises, a landlord may re-
+March 31, 1998.
+fuse consent arbitrarily, unless the lease contains a clause specifically stating that the
+brought proceediver to evict tenants form consent.
+as landlord, landlord may not unreasonably withhold such
+
+
+U.S. | EPSTEIN
+405
+Suzanne MeDermott, New York City, pro
+6. Federal Courts 6-413
+Federal court could apply federal com-se.
+mon law, as opposed to state law, to determination of rights under real property lease
+with government as landlord.
+Christopher H. Martin, New York Defenders Service, New York City, prose.
+Jessie Siegel, New York City, pro se.
+Siegel, Martin & Heilbrun, by Robert Heil-
+Law of New York, rather than federal brun, New York City, pro se.
+common law, would be applied to question
+Ron Soffer, New York City, pro se.
+whether consent of government, as landlord,
+to tenant's sublease of premises was subject
+Carmen Tausik, New York City, pro se.
+to requirement that it not be unreasonably
+withheld; there was no body of federal common law governing question and no pressing
+need for national uniformity calling for creation of such law, while state law of landlord
+and tenant was well developed and parties
+probably entered into lease believing state
+8. United States e-70(7)
+Under New York law, there was no requirement that consent of federal government, as landlord, to sublease not be unreasonably withheld; there was no provision to
+that effect in lease, and under those cireumstances consent could be withheld for any
+reason or no reason.
+CHIN, District Judge.
+In this case, the United States (the "Government") seeks to evict defendants from a
+building formerly used as a residence by the
+Deputy Consul General of the Islamic Re-
+public of Iran ("Iran"). After diplomatic and
+consular relations with Iran were severed in
+1980, the Office of Foreign Missions ("OFM")
+of the United States Department of State
+took possession of the building pursuant to
+the Foreign Missions Act, 22 U.S.C. $ 4301
+et seg.
+OFM leased the building to defendant Jeffrey E. Epstein in 1992. Epstein
+sublet the building to defendant Ivan S. Fisher in 1996, purportedly without the Government's consent.
+Fisher, in turn, sublet a
+Mary Jo White, United States Attorney,
+portion of the building to several subtenants.
+by Serene K. Nakano, Assistant United
+In 1996, the Government purported to ter-
+States Attorney, New York City, for the
+minate Epstein's lease and brought this ac-
+United States.
+tion to eject Epstein and Fisher from the
+Wachtel & Masyr, LLP, by Steven J. Co-
+building. The Government later amended its
+hen, New York City, for Jeffrey E. Epstein.
+complaint to assert a claim for ejectment
+against the subtenants as well.! The Gov-
+Gage & Pavlis, by G. Robert Gage, Jr.,
+ernment also sought to recover back rent
+Ellen J. Casey, New York City, for Ivan S.
+from Epstein and Fisher.
+Fisher, Diane Fisher, Fisher & Soffer.
+Epstein and Fisher oppose ejectment on
+Ellyn Bank, New York City, pro se.
+numerous grounds, some of which were re-
+Debra Elisa Cohen, New York City, pro jected when I heard oral argument in this
+se.
+case on December 17, 1997. Defendants'
+sole remaining defenses are that (1) OFM
+D. Gerzog, New York City, pro
+orally consented to Epstein's proposed sublet
+se.
+of the premises to Fisher, and (2) OFM did
+Robert Heilbrun, New York City, pro se.
+1. The additional defendants are Ellyn Bank, De-
+bra Elisa Cohen, Diane Fisher d/b/a The Fisher
+Graup. Eisher & Soffer ak/a Fisher & Sophir,
+D. Gerzog, Robert Heilbrun, Suzanne
+McDermott, Christopher H. Martin, Jesse Siegel
+a/k/a Jessie Siegel, Siegel, Martin & Heilbrun,
+not properly terminate Epstein's lease be-
+Ron Soffer, and Carmen Tausik (collectively, the
+"Subtenants"). The Subtenants were added as
+defendants after the Government learned that
+Fisher had sublet to them without consent of
+OFM.
+
+
+cause it breached an implied covenant of signment and Sublease Clause. Epstein was
+quest to sublet to Fisher.
+end of January, 1997.
+Because I find as a matter of law that (1)
+Epstein and his family continued to reside
+the lease unambiguously required the prior at the Premises until January of 1996, at
+written consent of OFM for Epstein to sublet
+which time Epstein abandoned. OFM did
+or assign the premises, thereby rendering
+not discover that Epstein had abandoned the
+any alleged oral consent invalid, and (2) OFM
+Premises, however, until several months lawas entitled under the lease to unreasonably
+ter. In March of 1996, Epstein commenced
+withhold its written consent to Epstein's renegotiations with Xenophon Galinas for a
+quest to sublet to Fisher, the Government's
+possible sublease or assignment of the Premmotion for partial summary judgment on its
+ises. The proposed arrangement between
+claim for ejectment is granted as against all
+Epstein and Galinas included payment by
+Galinas to Epstein of $100,000 for improvements to the Premises made by Epstein dur-
+BACKGROUND
+ing his tenancy. At the same time, Epstein
+also commenced negotiations to sublet the
+A. The Facts
+The premises at 34 East 69th Street in
+Manhattan (the "Premises") were once the
+residence of the former Deputy General Consul of Iran. When the United States severed
+diplomatic ties with Iran in 1980, the Deputy
+General Consul vacated, but the Premises
+remained the property of Iran. The Government, through the Secretary of State, was
+stein, however, that he would not enter into a
+sublease unless it was approved by the State
+Department and Fisher could be assured
+that he could remain in the Premises beyond
+January 81, 1997. Epstein told Fisher that
+he had a right of first refusal under the lease
+amendment, and that pursuant to this right,
+he would take all necessary steps to renew at
+entrusted with the care and maintenance of
+the Premises under the Foreign Missions Act
+In the meantime, Galinas contacted OFM
+("FMA"), 22 U.S.C. § 4305(c), and the Viendirectly about a new lease for the Premises
+na Convention on Consular Relations, Apr.
+beginning in February of 1997. Negotiations
+24, 1963, art. 27(1)(a), 21 U.S.T. T7, 596
+between Galinas and OFM culminated in a
+U.N.T.S. 261, a multilateral treaty entered
+"letter agreement" dated April 12, 1996 by
+into by the United States and Iran, among
+which Galinas agreed to rent the Premises
+other nations.
+for a five-year term beginning February 1,
+In 1992, OF entered into a two-year
+1997 for $16,000 per month, with yearly inlease with Epstein, to run from February 1,
+creases, up to $18,000 per month for the last
+1992 through January 31, 1994. The agreed
+year of the lease term. This agreement was
+rent was $15,000 per month. Pursuant to
+expressly made subject to Epstein exercising
+the lease's Use Clause, only Epstein, his
+his right of first refusal and renewing his
+family, servants, or approved subtenants or
+lease for personal use only. In other words,
+assignees could occupy the premises. Under OFM told Galinas that it would not consent
+the Assignment and Sublease Clause, Ep- to any request by Epstein for a sublet bestein was required to obtain prior written yond January 31, 1997, and that it would
+consent of OFM to assign or sublet the permit Epstein to renew the lease beyond
+Premises. The lease contained no clause that date only if he occupied the premises
+prohibiting OFM from unreasonably with- personally.
+holding its consent to a sublet or assignment.
+On April 16, 1996, Epstein notified OFM
+On August 28, 1992, OFM and Epstein by letter that he intended to exercise his
+extended the lease for three more years, to
+right of first refusal and renew the lease.
+January 31, 1997. The lease amendment did Epstein contends that in a telephone confernot alter either the Use Clause or the As- ence between Richard Massey of OFM and
+
+
+U.S. | EPSTEIN
+407
+Jeffrey Schantz, Epstein's transaction coun- May 10, 1996, OFM again wrote to Epstein
+sel, on April 19, 1996, OFM orally consented
+reiterating that the exercise of his right of
+to Epstein's request to sublet the Premises
+first refusal was premature, and explaining
+to Fisher. The same day, Epstein wrote
+that the prior arrangement with Galinas was
+back, requesting "written confirmation" of
+not a binding contract, but rather merely an
+OFM's alleged approval. By letter dated
+"expression of interest." Then, on May 16,
+April 26, 1996, OF formally responded to
+1996, OFM officials visited the Premises and
+Epstein's request. In this letter, Thomas E
+diseovered that Fisher, not Epstein, was in
+Burns, a representative of OFM, informed
+possession.
+Epstein of OFM's intention to lease the
+Throughout this period, Epstein continued
+Premises to Galinas beginning February 1,
+to pay, and OFM continued to accept, rent
+1997 in the event that Epstein decided not to
+for the Premises, despite its knowledge that
+renew the lease and occupy the premises
+Fisher was in possession. OFM accepted
+personally, and denied Epstein's request to
+and deposited Epstein's May 1996 rent check
+sublet the Premises to Fisher. OFM's staton May 28, 1996. On June 3, 1996, OFM
+ed reasons for the denial were to (1) "minisent Epetein a notice of default, as required
+mize any difficulties in tarning
+by the lease, stating that he was in violation
+house to the tenant we have selected should
+of (1) the Use Clause, because he was no
+Mr. Epstein decide not to
+reoceupy the
+longer personally occupying the premises,
+premises under the new lease," and (2) "miniand (2) the Assignment and Sublease Clause,
+mize the potential for damage to the premisbecause he had sublet to Fisher without prior
+es from a short-term tenant occupancy."
+written consent of OFM. Consistent with the
+(Schantz Aff., Exh. D). OFM did, however,
+terms of the Lease, Epstein was given 30
+grant Epstein permission to sublet the Premdays to cure the default.
+On June 28, 1996,
+ises to Galinas for the remainder of 1996.
+OFM accepted Epstein's June rent check.
+On May 3, 1996, Epstein again wrote to
+The cure period then expired on July 10,
+OFM, formally exercising his right of first
+1996. Epstein had not cured by this time,
+refusal, believing such right to have been
+but rather than terminating the lease, OFM
+triggered by the April 12, 1996 letter agreeserved Epstein with a 10-day notice to cure
+ment between OFM and Galinas.
+Thereafand demanded the July rent. OFM then
+ter, on May T, 1996, Epstein and Fisher
+accepted Epstein's check for the July rent.
+entered into a sublease agreement at a rental
+Finally, on August T, 1996, OFM notified
+price of $20,000 per month, despite OFM's
+Epstein that the amended lease would be
+express denial of Epstein's request for perterminated as of August 23, 1996 for failure
+mission to sublet to Fisher. Fisher claims to
+to cure the defaults.
+OFM demanded that
+have
+Epstein vacate the Premises and return the
+sublease was approved by the State Depart- Despite OFM's notice of termination, Ep-
+nent and that Epstein had properly exer- stein tendered August rent on August 30
+ised his right of first refusal to renew the 1996. On September 13, 1996, OFM wrote to
+lease. The original sublease was to com- Epstein stating that rent was being accepted
+with OFM was extended, and the new rent 1996, OFM wrote to Fisher advising that the
+under that lease did not exceed $20,000 per lease agreement between OFM and Epstein
+month, the sublease would be automatically had been terminated, that he was occupying
+extended. for an additional five-year period. the premises illegally, and demanded that the
+On May 8, 1996, OFM wrote to Epstein Premises be vacated immediately. Fisher
+informing him that his attempt to exercise met with an Assistant United States Attor-
+
+
+swear under oath that he never orally ap-
+I heard oral argument on the motions on
+proved the sublet to Fisher. Fisher con- December 17, 1997. Collectively, Epstein
+tends that he offered to continue paying rent and Fisher asserted four arguments in oppodirectly to OFM rather than to Epstein, an sition to the Government's motion for sumoffer to which the Government never re- mary judgment.? They contend that there
+sponded. At that time, Fisher stopped pay- are genuine issues of material fact as to
+ing rent to Epstein pursuant to the sublease.
+whether the Government properly terminated the lease entered into between OFM and
+Epstein. Specifically, they argue, factual
+questions exists as to (1) whether the Government waived Epstein's alleged default of
+the lease by accepting rent after the Govern-
+The Government commenced this action
+against Epstein and Fisher in October of
+It seeks a declaration by the Court
+that it is entitled to exclusive possession of
+the Premises and that it is entitled to have
+Epstein and Fisher ejected therefrom because Epstein's lease was properly terminated as of August 23, 1996. In addition, the
+Government seeks dismissal of Fisher's first
+and second counterclaims, which seek equitable relief against the Government. Finally,
+the Government demands back rent from
+ment became aware that Fisher was occupying the premises; (2) whether the OFM-
+Epstein lease permitted oral approval of an
+assignment or sublease (ie, whether the As-
+signment and Sublet Clause is ambiguous on
+the issue of whether an assignment or sublet
+could be approved orally); (3) whether OFM
+in fact orally approved the sublease to Fisher; and (4) whether the Government breached an obligation of good faith and fair dealing
+inherent in its lease with Epstein by unreasonably withholding written approval of a
+sublet to Fisher, assuming the Court holds as
+In February of 1997, Epstein commenced a
+holdover proceeding in the Civil Court of the
+City of New York against Fisher for nonpayment of rent under the terms of the sublease.
+Fisher removed the state court action to this
+a matter of law that oral approval was, not
+permitted by the lease.
+At the conclusion of the argument, I resolved several of the issues pertaining to
+these motions on the record.
+matter, I denied Epstein's motion to remand
+The Government moved for partial sumand granted Fisher's motion to consolidate.
+mary judgment on its claim for ejectment of
+I then addressed the Government's motion
+Epstein and Fisher. In addition, it sought
+for summary judgment and its application
+an order requiring Epstein and Fisher to pay
+concerning the creation of an escrow fund.
+into an escrow fund $15,000 per month from
+I granted summary judgment in favor of
+August 23, 1996 to the date this action is
+the Government on Epstein's and Fisher's
+finally decided. Epstein cross-moved against
+waiver argument, holding that "no reason-
+Fisher to remand its holdover action to state able fact finder could conclude from [the]
+court, and Fisher cross-moved against Ep-
+undisputed facts and the sequence of events,
+stein for consolidation of the holdover action
+including the acceptance of rent after the
+with the pending federal action.
+cure period but before the actual termination
+. In its first counterclaim, Fisher seeks a declara
+still has an interest in the Court's decision as to
+ion that the sublease is valid and that Fisher i
+whether OFM properly terminated its lease with
+lawfully entitled to full possession and use of the
+Epstein. Moreover, Fisher's rights as subtenant
+derive from Epstein's rights as overtenant, for if I
+decide as a matter of law that the lease was
+mencing January 31, 1997, because Epsteir
+properly exercised his right of first refusal.
+. Technically, Epstein asserted only the first ar
+ument, and Fisher asserted all four arguments
+Epstein is no longer occupying the Premises, but
+four arguments in opposition to the Government's motion as though they were asserted by
+Epstein and Fisher jointly.
+
+
+U.S. V EPSTEIN
+of the lease, that that could constitute a Group and Ron Soffer, agreed to be bound
+waiver in light of the very clear nonwaiver by any order I entered with respect to Fishclause in the lease." (Tr. at 39). I reserved er's right to occupy the Premises. On March
+decision, however, on the following issues: 13, 1998, after the Government submitted its
+(1) whether the lease unambiguously re- motion, Diane Fisher executed the stipulaquired that OFM's consent to an assignment tion and order, also agreeing to be bound.
+or sublet be in writing, in which case Massey To date, Soffer still has not executed the
+could not have orally consented, as a matter stipulation. Hence, the Government's motion
+of law, to Epstein's sublet of the Premises to for summary judgment against the Subten-
+Fisher, (2) whether OFM was permitted un- ants is still pending with respect to Soffer
+der the lease to unreasonably withhold con-only.
+sent to Epstein's consent to a sublet to Fisher, or whether it was bound by an implied
+obligation of good faith and fair dealing, and
+(3) whether, assuming the latter, OFM in fact
+A. Standards for Summary Judgment
+withheld its consent unreasonably.
+The standards applicable to motions for
+Finally, I ordered Epstein to pay into an
+summary judgment are well-settled. A court
+escrow fund eight days' worth of the $15,000
+may grant summary judgment only where
+rent for the month of August 1996 and an
+there is no genuine issue of material fact and
+additional $15,000 for September 1996 (bethe moving party is therefore entitled to
+cause OFM had already accepted his tender
+judgment as a matter of law. See Fed.
+of rent through August 23, 1996, and Epstein
+R.Civ.P. 56(c). Accordingly, the court's task
+had collected rent from Fisher through Sepis not to "weigh the evidence and determine
+tember 30, 1996). Additionally, I ordered
+the truth of the matter but to determine
+Fisher to pay into the fund
+$15,000 per
+hether there is a genuine issue for trial.'
+month, beginning October 1, 1996 to date,
+Anderson | Liberty Lobby, Inc, 477 U.S
+and continuing for each month thereafter.
+242, 249, 106 S.Ct. 2505, 91 L.Ed.2d 202
+(1986). Summary judgment is inappropriate
+2. The Government's Addition of the
+if, resolving all ambiguities and drawing all
+Subtenants as Defendants
+In the course of discovery on its claims for
+relief against Epstein and Fisher, the Gov-
+Kress de Co., 398 U.S. 144, 158-69, 90 S.Ct.
+ernment learned that Fisher had further sub-
+1598, 26 L.Ed.2d 142 (1970)), there exists a
+let the Premises to the Subtenants, also withdispute about a material fact "such that a
+out the prior written consent of OFM. The
+reasonable jury could return a verdiet for the
+Government then sought leave to amend the
+nonmoving party.". Anderson, 477 U.S. at
+complaint pursuant to Federal Rule of Civil
+248, 106 S.Ct. 2505.
+Procedure 15 to name the Subtenants as
+Once the moving party meets its initial
+additional defendants in the action. I grant- burden of production, the burden shifts to
+ed the Government's motion on the record at the nonmoving party to demonstrate that
+e December 17, 1997 oral argument. The there exist genuine issues of material far
+overnment thereafter filed a second amend- Matsushita Elec. Indus. Co I. Zenith Rad
+ed complaint and served a copy on each of Corp, 475 U.S. 574, 585-86, 106 S.Ct. 1348,
+89 L.Ed.2d 538 (1986). To defeat a motion
+In an effort to settle the case, I held a for summary judgment, however, the nonconference on January 28, 1998. At the con- moving party "must do more than simply
+clusion of that conference, the Government show that there is some metaphysical doubt
+requested permission to file a motion seeking as to the material facts." Id. at 586, 106
+partial summary judgment against the Sub- S.Ct. 1348. There is no issue for trial unless
+tenants. By stipulation and order dated there exists sufficient evidence in the record
+March 5, 1998, all of the named Subtenants, favoring the party opposing summary judgexcept for Diane Fisher d/b/a The Fisher ment to support a jury verdict in that party's
+
+
+410
+favor. Anderson, 477 U.S. at 249, 106 S.Ct. ises to Fisher. The Assignment and Sublet
+2505. As the Supreme Court stated in Clause expressly states that *Tenant may
+Anderson, "If the evidence is merely color- sublet all or part of the Premises, or assign
+able, or is not significantly probative, sum- this lease or permit any other person to use
+mary judgment may be granted." Id at the Premises with the advance written per-
+249-50, 106 S.Ct. 2505 (citations omitted). mission of Landlord" (Massey Decl., Exh.
+With these standards in mind, I turn to the B at 4) (emphasis added). Epstein's and
+Government's motions for partial summary
+Fisher's argument that the word "may" sug
+gests that OFM could approve a sublease or
+assignment in writing or orally is tortured.
+B. The Government's Motion for Partial Only one interpretation of this clause is tena-
+Summary Judgment against Epstein
+ble: prior written consent of OFM was required for a sublet. Epstein's and Fisher's
+argument would render the language of the
+Whether the Lease Permitted Oral
+clause meaningless, and I am obliged to read
+Consent to a Proposed Sublet or As-
+the lease in a manner that gives full force
+and effect to all clauses contained therein.
+Epstein and Fisher contend that summary
+See Lloyds Bank PIC 1 Republic of Ecuajudgment should be denied because there
+dor, No. 96 Civ. 1789 (DC), 1998 WL 118170,
+exists a genuine issue of material fact as to
+at *8 (S.D.N.Y. Mar. 16, 1998). Accordingly,
+whether OFM orally consented to Epstein's
+OFM could not have orally consented to Ep-
+request to sublet the Premises to Fisher.
+stein's proposed sublet to Fisher, as a matter
+The Government, on the other hand, argues
+of law, and, therefore, I need not reach the
+that the lease unambiguously required that a
+question of whether OFM actually gave oral
+sublet or assignment of the Premises be apconsent.
+proved in advance in writing, and that, therefore, even if OFM did orally consent, such
+2. Whether the Lease Permitted OFM
+consent was invalid as a matter of law.
+to Unreasonably Withhold Written
+[1-3] In contract disputes, the Court be-
+Consent to a Proposed Sublet
+gins by examining the language of the con-
+The last issue to be decided on this motion
+tract itself to determine the parties' intent.
+is whether OFM was entitled to refuse Ep-
+Stroll | Epstein, 818 F.Supp. 640, 643
+stein's proposed sublet to Fisher arbitrarily,
+(S.D.N.Y.), affd, 9 F.3d 1537 (2d Cir.1993).
+or whether it breached a duty of good taith
+If the agreement sets forth the parties' inand fair dealing implicit in the lease agreetent clearly and unambiguously, the Court
+ment by unreasonably refusing to grant such
+need look no further.
+See Sterling Drug Ine.
+consent in writing. Resolution of this issue
+| Bayer AG, 792 F.Supp. 1357, 1365-66
+turns on whether federal contract law or
+(S.D.N.Y.1992), off'd in part, remanded in New York landlord-tenant law applies.
+part, 14 F.3d 733 (2d Cir: 1994). Whether the [51 Generally, under New York law,
+text of an agreement is ambiguous or unamwhere a lease requires a tenant to obtain the
+biguous is a matter of law to be decided by
+prior written consent of the landlord to subthe Court. Sterling Drug, 792 F.Supp. at
+1366. A contract is not deemed ambiguous
+let or assign leased premises, a landlord may
+unless it is reasonably susceptible of more
+refuse consent arbitrarily, unless the lease
+contains a clause specifically stating that the
+than one interpretation, and the Court makes
+landlord may not unreasonably withhold such
+this determination by reference to the contract alone. Banque Arabe et Internationale
+consent. See Dress Shirt Sales, Inc. I Hotel
+Martinique Assocs., 12 N.Y.2d 339, 289
+D'Investissement | Maryland Natl Bank,
+N.Y.8.2d 660, 662, 190 N.E.2d 10 (Ct.App.
+57 F.3d 146, 152 (2d Cir:1995).
+1968). The Assignment and Sublet Clause in
+[4] The lease clearly provides that Ep-
+the lease between OFM and Epstein restein was required to obtain the advance quired Epstein to obtain prior written conwritten consent of OFM to sublet the Prem- sent of OFM to a proposed sublet, but it
+
+
+U.S. L EPSTEIN
+411
+contained no provision prohibiting OFM from
+unreasonably withholding such written const tendlord and t. 6L 201041, 1012, 10et
+States Postal Seru, 671 F.2d 1041,
+sent.
+7th Cir.1982); Reed | United States Posta
+The Government, relying on New York
+Serv, 660 F.Supp. 178, 181 (D.Mass. 1987)
+landlord-tenant law, asserts that it was enti-
+The question remains, therefore, what law
+tled to withhold its consent to Epstein's proapplies in the absence of a federal rule on
+posed sublet to Fisher for any reason, or for
+point.
+no reason at all. Epstein and Fisher, howev-
+As the Supreme Court has made clear, my
+er, disagree. They contend that, because the
+power to create federal common law in the
+Government is a party to the lease, interpreabsence of federal landlord-tenant law is limtation of the lease is governed by principles
+ited. Several recent Supreme Court deciof federal common law, not New York State
+sions have reaffirmed the principle that the
+law. Pursuant to federal common law of conpower of the federal courts to fashion princitracts, Epstein and Fisher continue, the lease
+ples of federal common law is limited. See,
+between OFM and Epstein contains an imeg, O'Melveny & Myers 1 FDIC, 512 U.S.
+plied covenant of good faith and fair dealing,
+79, 87-88, 114 S.Ct. 2048, 129 L.Ed.2d 67
+citing Neal & Co. | United States, 36 F'ed.
+(1994) (noting that cases where the formula-
+Cl. 600 (1996), aff'd, 121 F.3d 683 (Fed.Cir.
+tion of a "special federal rule" are "few and
+The requirement of good faith and
+restricted"); Komen | Kemper Fin. Serus,
+fair dealing, they argue, prohibits OFM from
+Inc.,
+500 U.S. 90, 98, 111 S.Ct. 1711, 114
+L.Ed.2d 152 (1991) (noting that a federal
+refusal to consent to Epstein's proposed sublet of the Premises to Fisher, they contend,
+was motivated by its desire to enter into a
+lease with Galinas at a higher rent beginning
+February 1, 1997. Such conduct was unreasonable, they argue, and, therefore, OFM
+breached the implied covenant of good faith
+and fair dealing in the lease.
+[6, 7] I conclude that New York landlordtenant law rather than general federal contract principles should apply.
+As a threshold
+matter, although I agree as a policy matter
+that federal law should apply, there is no
+federal statutory or common law governing
+landlord-tenant
+relations.
+Federal
+law
+should apply because the United States is a
+party.
+I have jurisdiction over this action
+based on 28 U.S.C. § 1345 and the FMA, 22
+U.S.C. § 4301 et seg. The subject matter of
+this action is a landlord-tenant dispute, however, and while application of federal law is
+appropriate in federal question cases where
+applicable federal substantive law exists,
+there is no federal statutory or common law
+4. In United States | Bedford Associates, 657 F.2d
+1300 (2d Cir.1981), cert. denied, 456 U.S. 914,
+102 S.Ct. 1767, 72 L.Ed.2d 173 (1982), the Second Circuit upheld the district court's application of federal contract law to determine whether
+the United States and a potential lessor of a
+commercial building had in fact made a contract,
+stating that "[Jhis court undoubtedly has power
+court "should endeavor to fill the interstices
+of federal remedial schemes with uniform
+federal rules only when the scheme in question evidences a distinet need for nationwide
+legal standards or when express provisions in
+analogous statutory schemes embody congressional policy choices readily applicable to
+the matter at hand") (citations omitted).
+While this recent Supreme Court authority
+leaves room for federal courts to create principles of federal common law in certain narrow circumstances, generally a "significant
+conflict between some federal policy or interest and the use of state law" is required
+before "judicial creation of a special federal
+rule [is] justified." O'Melveny, 512 U.S. at
+87, 114 S.Ct. 2048. While few courts have
+addressed the precise issue of whether leases
+to which the Government is a party are
+governed by general federal common law of
+contracts or state landlord-tenant law, there
+is some case law on point. The Second Circuit has not yet spoken definitively on this
+issue,' but recently noted the existence of a
+to apply federal law in disputes between the
+United States and its lessors.
+" Id. at 1309 n. 7.
+The Fo3d 988 (2a Cir.1997), acknowledged eh.
+116 F 3d 988 (2d
+Bedford Associates decision, but implied that Bedford Associates involved the issue of creation of a
+lease only, stating that there is "room for fair
+debate" as to whether federal or state law ap-
+
+
+412
+conflict between the Federal Circuit and the termined under state law, even when the
+Seventh Circuit concerning "whether federal United States is a party." United States 1
+ommon law or state law applies to the inter- O'Block, 788 F.2d 1483, 1485 (10th Cir.1986
+retation of Postal Service Leases." Kerin (citing Oregon ex rel. State Land Bd. 1
+| United States Postal Seru, 116 F.3d 988, Corvallis Sand & Gravel Co, 429 U.S. 36
+990 (2d Cir.1997). On the one hand, the
+378-81, 97 8.Ct. 582, 50 L.Ed.2d 550 (1977)) 7
+Federal Circuit has held that federal law
+Second, application of state substantive
+applies to resolve disputes between the Unit- law directly on point is eminently more logied States and its lessors or tenants. See,
+cal than application of general principles of
+.g., Forman 1 United States, 767 F.2d 875
+federal contract law. While application of
+79-80 (Fed.Cir.1985); • Kelley • Uniter
+general federal contract law to Government
+States, 19 Cl.Ct. 155, 162 (1989). On the
+contracts may be appropriate in certain inother hand, the Seventh Circuit has held that
+stances, where, as here, the particular govstate substantive law governs in landlordernment contract is a lease for the use of
+tenant disputes involving the Government.
+real property, the adoption of state common
+See Powers | United States Postal Sero, 671
+law of landlord-tenant relations, a body of
+F.2d 1041, 1043-46 (7th Cir: 1982).*
+law that has developed precisely to address
+The Second Circuit in Kerin did not reach
+the rights and duties of individuals in the
+the issue of whether federal common law or
+unique relationship of landlord and tenant,
+state law applied because, in that case, federmakes sense. Application of the state rule,
+al law and state law led to the same result.
+which permits a landlord to refuse consent to
+See Kerin, 116 F.3d at 991. I agree with the
+a sublet or assignment arbitrarily in the ab-
+Seventh Circuit's conclusion, for two reasons.
+sence of a clause to the contrary, better
+serves the interests of the Government as a
+First, although Epstein and Fisher argue
+landlord because it permits the Government
+that a federal rule should be created to proto have unfettered discretion in deciding who
+mote the creation of a uniform body of law in
+occupies its property. Given the sensitive
+landlord-tenant disputes involving the Government, there is no "distinet need" for a
+political considerations that often come into
+play when governmental property, such as
+nationwide legal standard or a uniform national rule. See Kamen, 500 U.S. at 98, 111
+the property here in issue owned by Iran, is
+S.Ct. 1711. Landlord-tenant law traditionalinvolved, the Government should have as
+much discretion as possible.
+ly has been a matter of state law.
+no compelling reason to disrupt expectations
+Noting that federal landlord-tenant law
+that tenants and landlords may have under
+does not exist, Judge Posner stated in Powstate law merely because they are entering
+e78:
+into a lease with the federal government.
+The Federal Courts could of course create
+that law, picking and choosing among existing state laws and proposed reforms in
+accordance with the recommendations of
+plies to the interpretation of a lease to which the
+Government is a party. Id. at 990-91.
+• While the Forman court stated that federal lav
+overns in landlord-tenant disputes involving th
+feited by the Government must pay the Government a reasonable rent for the period of his
+occupancy); Reed, 660 F.Supp. at 181 (holding
+that Massachusetts law governs the rights of the
+parties under a Postal Service lease).
+Government, it nevertheless relied on state law
+cases in interpreting the particular provision of
+the Postal Service lease at issue. See 767 F.2d at
+7. Indeed, the Supreme Court has articulated that
+6. Other courts, too, have applied state substantive law as the rule of decision in landlord-tenant
+disputes_involving the Government. See, e.g.
+Braxton F. United States, 858 F.2d 650, 655 (1 1t)
+Cir. 1988) (holding that Florida law applies to
+determine whether one who occupies land for-
+[state law] as the federal rule of decision.'*
+Karen, 500 U.S. at 98, 111 S.Ct. 1711 (emphasis
+added guis. 5, 58, 99 .c. ell 8, 95,
+L.Ed.2d 711 (1979)).
+
+
+U.S. I EPSTEIN
+413
+eminent scholars and practitioners. It is like cases to landlord-tenant disputes. A
+not to be expected that the federal courts construction contract does not implicate the
+would do a very good job of devising a Government's rights, as a possessor of a
+model code of landlord-tenant law, since
+valuable leasehold, to regulate the possession
+they have very little experience in land- and use of real property under its control.
+lord-tenant matters; and though eventual-
+Thus, as between general federal contract
+ly some body of law would emerge it would
+principles and specific state landlord-tenant
+not in all likelihood be a uniform body, law, the latter should be applied. Land is
+because there are [thirteen] federal cirunique. It is logical, therefore, that a landcuits and the Supreme Court could be
+lord should have virtually complete say in
+expected to intervene only sporadically
+who occupies its property. See Mans Theatres Corp. & Mid-Island Shopping Plaza
+... [W]e do not have to balance compet-
+Co., 94 A.D.2d 466, 464 N.Y.8.2d 793, 798 (2d
+ing federal and state interests in this case
+Dep't 1988) (noting that landlords have a
+after all. The overriding federal interest
+"substantial interest in controlling the ashere is in certainty of right and obligation
+signability of leases"), affd, 62 N.Y.2d 930,
+flowing from conformity to known law; the
+479 N.Y.S.2d 213, 468 N.E.2d 51 (Ct.App.
+state interest is in offering its landlords a
+1984). It makes sense for the law to permit
+like certainty. These interests converge in
+a landlord to unreasonably withhold consent
+favor of adopting ... state law rather than
+to a proposed sublet unless the parties spefederal common law.
+cifically bargain otherwise. See Alex M.
+Powers, 671 F.2d at 1045-46.
+This reasoning
+Johnson, Jr., Correctly Interpreting Longis quite convincing, particularly in a case
+Term Leases Purswant to Modern Contract
+such as this, where the Government and
+Low: Toward a Theory of Relational Leases,
+Epstein, in all likelihood, "entered [a] legal
+74 Va. L.Rev. 751, 758 (1988) (discussing the
+relationship with the expectation that their
+majority view that absent contractual agreerights and obligations would be governed by
+ment to the contrary landlords are permitted
+state-law standards." Kamen,
+500 U.S. at
+to unreasonably withhold consent to a sublet
+98, 111 S.Ct. 1711.
+or assignment, and noting
+that the rule
+Finally, Epstein's and Fisher's reliance on
+stems from the "paramount importance of
+Neal & Co. | United States, 36 Fed. Cl. 600
+the lessor's ability to control the selection of
+(1996), aff'd, 121 F.3d 683 (Fed.Cir.1997), is
+his tenants so as to protect the value of his
+therefore misplaced.
+reversionary interest" in the leasehold).
+States Court of Federal Claims stated that
+[8] I therefore adopt the relevant rule of
+"[e]very contract, including those in which
+New York landlord-tenant law for purposes
+the Government is a party, contains an imof deciding the remaining issue in this displied covenant of good faith and fair dealing,"
+pute, and hold that, consistent with New
+id at 681, and from this statement, Epstein
+York law, OFM was entitled to arbitrarily
+and Fisher extrapolate that there exists an
+withhold its consent to Epstein's request to
+implied covenant of good faith and fair dealsublet the Premises to Fisher. Even assuming in the lease agreement between Epstein
+ing OFM had a hidden agenda in refusing
+and the Government at issue here.
+Epstein's request to sublet to Fisher, specifi-
+The facts of Neal & Co. are distinguishcally, that it preferred to enter into a new
+able, however. Neal & Ca involved a conlease with Galinas at a higher rental price, it
+struction contract to build a housing project
+was entitled to withhold its consent to a
+entered into between the Government and a sublet for a good reason, a bad reason, or no
+contractor, not a lease for occupancy of real
+reason at all. There existed no implied coveproperty. While a lease is a type of contract,
+nant of good faith and fair dealing in its lease
+the considerations surrounding a lease of real
+with Epstein requiring OFM to act reasonproperty are sufficiently different from those
+ably in deciding whether to approve Ep-
+involved in a conventional contract as to milistein's proposed sublet, and, therefore, OF'M
+tate against the extension of Neal & Co. and
+cannot be held liable for a breach thereof.
+
+
+414
+- Thus, I need not reach the issue of whether
+OFM in fact unreasonably withheld consent.
+UNION CARBIDE CORPORATION, indi-
+And, as Fisher was occupying the Premises
+vidually and on behalf of and as the sucpursuant to an illegal sublet, OFM was withcessor in interest of Seadrift Polypropyin its rights to terminate Epstein's lease.
+lene Company, Plaintiff,
+Accordingly, the Government's motion for
+partial summary judgment on its claim for
+ejectment of Epstein and Fisher from the
+Premises is hereby granted.
+C. The Government's Motion for Partial
+Summary Judgment Against the Subtenants
+Eleven of the twelve Subtenants signed a
+stipulation agreeing to be bound by the
+Court's decision on the Government's claim
+for ejectment against Epstein and Fisher.
+now grant the Government's motion for partial summary judgment against Epstein and
+Fisher; hence, the motion is also granted
+with respect to these eleven Subtenants.
+The remaining Subtenant, Ron Soffer, did
+not sign the stipulation. He has not responded to the Government's motion because the
+motion is not returnable until April 20, 1998.
+Soffer, however, can have no greater rights
+than Fisher. Hence, the Government's motion is granted as to Soffer as well.
+course, if Soffer believes he has some basis
+for arguing that he has greater rights than
+Fisher has, he may make a motion for reconsideration within ten days hereof.
+MONTELL i: Montell Polyolefins;
+Montell North America Incorporated;
+Montell USA Incorporated; Technipol
+S.r.l.; Montedison S.p.A.; Montell Fi-
+nance USA, Ine.; Royal Dutch Petroleum Company, p.l.e.; The Shell Transport
+and Trading Company, p.l.c.; Shell Pe-
+troleum
+The Shell Petroleum
+Company Limited; Shell Petroleum
+Inc.; Shell Oil Company; Shell Polypropylene Company; Shell Canada Limited;
+Shell International Chemical Company
+Limited; and Shell Internationale Re-
+search Maatschappij
+, Defendants.
+No. 95 Civ. 0134(SAS).
+United States District Court,
+S.D. New York.
+Aug. 4, 1998.
+Producer of polypropylene resin brought
+antitrust action against alleged conspirators,
+arising out of one conspirator's termination
+of negotiation to construct new resin manufacturing plants. Following settlement with
+one alleged conspirator, remaining conspirator moved for summary judgment. The Dis-
+CONCLUSION
+trict Court, Schindlin, J., held that: (1) there
+was fact issue whether conspiracy existed to
+For the foregoing reasons, the Government's motion for summary judgment on its
+limit trade in resin; (2) termination was ancilclaim for ejectment is granted as to Epstein,
+lary restraint of trade, precluding determina-
+Fisher, and all of the Subtenants.
+tion that it was per se violation of Sherman
+Act $ 1; and (3) there was no unreasonable
+SO ORDERED.
+restraint of trade, under rule of reason standard.
+Summary judgment granted in part.
+1. Federal Civil Procedure 6-2484
+Due to the potential chilling effect of
+prolonged antitrust litigation on competition,
+parties that forward economically implausible
+antitrust claims must come forward with
+more persuasive evidence to support them
+
+
+
+Page 1
+Maria Tankenson Hodge
+Current Firm Information Unknown
+hodgfran@islands.vi
+Position:
+Member
+Education:
+University of California at Berkeley, Boalt Hall School of Law, Berkeley, CA,
+1971
+J.D., Doctor of Jurisprudence
+University of California, Santa Cruz, California, 1989
+B.A.Govt., Bachelor of Arts in Government
+Admitted:
+California, 1972
+Virgin Islands, 1974
+U.S. Court of Appeals 3rd Circuit
+U.S. Supreme Court, 1983
+Affiliations:
+The West Indian Company, Limited, Director, 1989 - Present
+Representative Clients:
+Public Services Commission
+The West Indian Company, Limited
+Virgin Islands Port Authority
+References:
+Chase Manhattan Bank, N.A., St. Thomas, Virgin Islands
+Kodak Corporation,
+Hato Rey, Puerto Rico
+Prudential Securities, St. Thomas, Virgin Islands
+West Practice Categories:
+Estate Planning
+Family Law
+Litigation & Appeals
+Real Estate Law
+Land Use & Zoning
+• 2007 Thomson/West. No Claim to Orig. U.S. Govt. Worka.
+https://web2.westlaw.com/print/printstream.aspx?prft=HTMLE&destination=atp&sv=Full... 5/22/2007
+
+
+
+Page 2
+Areas of Practice:
+General Civil Litigation
+Appellate Practice
+Real Estate
+Civil Practice
+END OF DOCUMENT
+• 2007
+Thomson/West. No Claim
+to Orig. U.S.
+Govt. Works.
+https://web2.westlaw.com/print/printstream.aspx?prfl=HTMLE&destination=atp&sv=Full... 5/22/2007
+
+
+
+
+Selected Entity Name: J. EPSTEIN & COMPANY, INC.
+Selected Entity Status Information
+Current Entity Name: J. EPSTEIN & COMPANY, INC.
+Initial DOS Filing Date: NOVEMBER 18, 1988
+County:
+NEW YORK
+Jurisdiction:
+NEW YORK
+Entity Type:
+DOMESTIC BUSINESS CORPORATION
+Current Entity Status: INACTIVE
+Selected Entity Address Information
+DOS Process (Address to which DOS will mail process if accepted on behalf of the entity)
+GOLD & WACHTEL, ESQS
+10 EAST 53RD STREET
+NEW YORK, NEW YORK, 10022
+NONE
+Registered Agent
+NOTE: New York State does not issue organizational identification numbers.
+Search Results
+New Search
+Division of Corporations, State Records and UCC Home Page NYS Department of State Home Page
+http://appsext8.dos.state.ny.us/corp_public/CORPSEARCH.ENTITY_INFORMATION?p_nameid=1423231 &p_corpid-13073.... 5/14/2007
+
+
+
+Selected Entity Name: JEFFREY E. EPSTEIN, INC.
+Selected Entity Status Information
+Current Entity Name: J. EPSTEIN & COMPANY, INC.
+Initial DOS Filing Date: NOVEMBER 18, 1988
+County:
+NEW YORK
+Jurisdiction:
+NEW YORK
+Entity Type:
+DOMESTIC BUSINESS CORPORATION
+Current Entity Status: INACTIVE
+Selected Entity Address Information
+DOS Process (Address to which DOS will mail process if accepted on behalf of the entity)
+GOLD & WACHTEL, ESQS
+10 EAST 53RD STREET
+NEW YORK, NEW YORK, 10022
+NONE
+Registered Agent
+NOTE: New York State does not issue organizational identification numbers.
+Search Results
+New Search
+Division of Corporations, State Records and UCC Home Page NYS Department of State Home Page
+http://appsext8.dos.state.ny.us/corp_public/CORPSEARCH.ENTITY_INFORMATION?p_nameid=1423230&p_corpid=13073.... 5/14/2007
+
+United States District Court Eastern District of Pennsylvania - Docket Report
+
+CLOSED, STANDARD
+United States District Court
+Eastern District of Pennsylvania (Philadelphia)
+CIVIL DOCKET FOR CASE #: 2:02-cv-07671-CN
+Assigned to: HONORABLE CLARENCE C. NEWCOMER Date Terminated: 10/21/2003
+Cause: 28:1332 Diversity-Breach of Contract
+Jury Demand: None
+Nature of Suit: 195 Contract Product
+Liability
+Jurisdiction: Diversity
+Plaintiff
+represented by JEFFREY D. HOFFERMAN
+GOLLATZ GRIFFIN & EWING PC
+4 PENN CENTER PLAZA
+SUITE 200
+1600 JOHN FITZGERALD
+KENNEDY BOULEVARD
+PHILADELPHIA, PA 19103-2813
+215-563-9400
+Fax: 215-665-9988
+Email: jhofterman@ggelaw.com
+ATTORNEY TO BE NOTICED
+Defendant
+LESLIE WEXNER
+represented by CHRISTOPHER J. GUITON
+DRINKER BIDDLE & REATH
+ONE LOGAN SQ
+18TH & CHERRY STS
+PHILA, PA 19103
+215-988-2546
+ATTORNEY TO BE NOTICED
+_J. FOX
+DRINKER BIDDLE & REATH LLP
+ONE LOGAN SO
+18TH & CHERRY STS
+PHILA, PA 19106-6996
+215-988-2714
+Fax: 215-988-2757
+Email: foxlj@dbr.com
+https://ecf.paed.uscourts.gov/cgi-bin/DktRpt.p|?261521028494284-L_353_0-1
+
+
+United States District Court Eastern District of Pennsylvania - Docket Report
+
+ATTORNEY TO BE NOTICED
+Defendant
+ABIGAIL WEXNER
+H/W
+represented by CHRISTOPHER J. GUITON
+(See above for address)
+ATTORNEY TO BE NOTICED
+J. FOX
+(See above for address)
+ATTORNEY TO BE NOTICED
+Defendant
+JEFFREY E. EPSTEIN
+INDIVIDUALLY
+doing business as
+J. EPSTEIN AND COMPANY, INC.
+represented by CHRISTOPHER J. GUITON
+(See above for address)
+ATTORNEY TO BE NOTICED
+_ J. FOX
+(See above for address)
+ATTORNEY TO BE NOTICED
+Defendant
+GHISLAINE MAXWELL
+represented by CHRISTOPHER J. GUITON
+(See above for address)
+ATTORNEY TO BE NOTICED
+I J. FOX
+(See above for address)
+ATTORNEY TO BE NOTICED
+Date Filed
+10/02/2002
+#
+10/02/2002
+12/16/2002
+Docket Text
+1 COMPLAINT against JEFFREY E. EPSTEIN, GHISLAINE
+MAXWELL, ABIGAIL WEXNER, LESLIE WEXNER ( Filing fee S
+150 receipt number 803892.), filed by NELSON SHANKS.(ti, )
+Additional attachment(s) added on 2/13/2003 (Idb, ). (Entered:
+10/03/2002)
+Summons Issued as to JEFFREY E. EPSTEIN, GHISLAINE
+MAXWELL, ABIGAIL WEXNER, LESLIE WEXNER.Four Forwarded
+To: Counsel on 10/3/02 (ti, ) (Entered: 10/03/2002)
+2 | ORDER THAT JEFFREY E. EPSTEIN ; GHISLAINE MAXWELL ;
+ABIGAIL WEXNER ; LESLIE WEXNER HAVE UNTIL 12/31/02 TO
+ANSWER, MOVE, OR OTHERWISE PLEAD TO THE COMPLAINT;
+https://ecf.paed.uscourts.gov/cgi-bin/DktRpt.p|?261521028494284-L_353_0-1
+
+
+United States District Court Eastern District of Pennsylvania - Docket Report
+
+12/30/2002
+01/15/2003
+02/07/2003
+02/14/2003
+02/27/2003
+03/18/2003
+04/07/2003
+04/24/2003
+04/30/2003
+J. FOX WILL ACCEPT SERVICE ON BEHALF OF ALL
+DEFENDANTS ETC. SIGNED BY JUDGE CLARENCE C.
+NEWCOMER ON 12/16/02. 12/17/02 ENTERED AND COPIES
+MAILED (ph, ) (Entered: 12/17/2002)
+3 MOTION FOR DISMISSAL PURSUANT TO FRCP 12(b)(2),
+MEMORANDUM, CERTIFICATE OF SERVICE FILED BY
+EPSTEIN, GHISLAINE MAXWELL, ABIGAIL WEANER, LESLIE
+WEXNER. (ph, ) Additional attachments) added on 2/13/2003 (ldb, ).
+(Entered: 12/31/2002)
+4 STIPULATION & ORDER THAT PLAINTIFF SHALL HAVE UNTIL
+1/31/03 TO FILE A RESPONSE TO DEFENDANT'S MOTION TO
+DISMISS. SIGNED BY JUDGE CLARENCE C. NEWCOMER ON
+1/15/03. 1/15/03 ENTERED AND COPIES MAILED.(rv, ) (Entered:
+01/15/2003)
+5 STIPULATION AND ORDER THAT PLAINTIFF SHALL HAVE
+UNTIL 2/14/03 TO FILE A RESPONSE TO DEFENDANT'S MOTION
+TO DISMISS FILED IN THIS MATTER ON 12/30/02. SIGNED BY
+JUDGE CLARENCE C. NEWCOMER ON 2/7/03. 2/10/03 ENTERED
+AND COPIES MAILED (ph, ) (Entered: 02/10/2003)
+6 REPLY filed by NELSON SHANKS to Defendant's Motion to Dismiss
+pursuant to F.R.C.P. 12(b)(2), Certificate of Service. (rv, ) (Entered:
+02/18/2003)
+7 | REPLY to Plaintiff's Response to Defendants' Motion to Dismiss filed by
+JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, ABIGAIL
+WEXNER, LESLIE WEXNER, Certificate of Service. (ar, ) (Entered:
+02/28/2003)
+8 OPINION AND ORDER DENYING DEFENDANTS' MOTION FOR
+DISMISSAL. SIGNED BY JUDGE CLARENCE C. NEWCOMER ON
+3/18/03.3/19/03 ENTERED AND COPIES MAILED (ph, ) (Entered:
+03/19/2003)
+9 STIPULATION AND ORDER THAT JEFFREY E. EPSTEIN,
+GHISLAINE MAXWELL, ABIGAIL WEXNER, LESLIE WEXNER'S
+ANSWER IS EXTENDED TO 4/18/03. SIGNED BY JUDGE
+CLARENCE C. NEWCOMER ON 4/7/03. 4/8/03 ENTERED AND
+COPIES MAILED (ph, ) (Entered: 04/08/2003)
+10| STIPULATION AND ORDER THAT ABIGAIL WEXNER AND
+LESLIE WEXNER'S ANSWER IS DUE 4/30/03. SIGNED BY JUDGE
+CLARENCE C. NEWCOMER ON 4/24/03. 4/25/03 ENTERED AND
+COPIES MAILED (ph, ) (Entered: 04/25/2003)
+11 | ANSWER, affirmative defenses to Complaint by JEFFREY E.
+EPSTEIN, GHISLAINE MAXWELL, ABIGAIL WEXNER, LESLIE
+WEXNER, Certificate of service.(ph, ) Additional attachments) added
+on 5/16/2003 (ph, ). (Entered: 05/01/2003)
+https://ecf.paed.uscourts.gov/cgi-bin/DktRpt.pl?261521028494284-L_353_0-1
+
+
+United States District Court Eastern District of Pennsylvania - Docket Report
+
+| 04/30/2003
+05/05/2003
+05/19/2003
+05/22/2003
+05/29/2003
+06/19/2003
+07/08/2003
+07/14/2003
+07/18/2003
+08/13/2003
+Issue Joined (ph, ) (Entered: 05/01/2003)
+12 NOTICE of Hearing: Pretrial Conference set for 5/13/2003 03:15 PM in
+Judge's Chambers, Room 13614 (13th Floor) before HONORABLE
+CLARENCE C. NEWCOMER. (mf) (Entered: 05/05/2003)
+13 STIPULATION AND ORDER THAT PLAINTIFF SHALL HAVE
+UNTIL 5/30/03 TO RESPOND TO DEFENDANTS' ANSWER AND
+COUNTERCLAIMS FILED ON 4/30/03. SIGNED BY JUDGE
+CLARENCE C. NEWCOMER ON 5/19/03. 5/19/03 ENTERED AND
+COPIES MAILED (ph, ) (Entered: 05/19/2003)
+ORDER THAT DISCOVERY IS DUE 8/13/03; DISPOSITIVE
+MOTIONS BY 8/13/03; RESPONSES TO DISPOSITIVE MOTIONS
+BY 8/25/03; FINAL PRETRIAL/SETTLEMENT CONFERENCE BY
+9/24/03 AT 11:15 A.M.; PRETRIAL MEMORANDA BY 9/17/03;
+COUNSEL SHALL BE PREPARED FOR TRIAL BY 9/23/03. SIGNED
+BY JUDGE CLARENCE C. NEWCOMER ON 5/22/03. 5/22/03
+ENTERED AND COPIES MAILED (ph, ) (Entered: 05/22/2003)
+15 MOTION TO DISMISS COUNTERCLAIM FOR FAILURE TO
+STATE A CLAIM UPON WHICH RELIEF CAN BE GRANTED,
+MEMORANDUM, CERTIFICATE OF SERVICE FILED BY NELSON
+SHANKS.(ph, ) Modified on 5/29/2003 (ph,). Additional attachments)
+added on 6/16/2003 (vw, ). Additional attachments) added on 6/16/2003
+(vw, ). Additional attachments) added on 6/16/2003 (vW, ). Additional
+attachments) added on 6/16/2003 (vW, ). (Entered: 05/29/2003)
+16 STIPULATION AND ORDER THAT THE TIME IN WHICH THE
+DEFENDANTS MUST SUBMIT A REPLY TO PLAINTIFF'S
+MOTION TO DISMISS COUNT II OF DEFENDANTS'
+COUNTERCLAIM, IS EXTENDED UNTIL AND INCLUDING
+6/30/03 . SIGNED BY JUDGE CLARENCE C. NEWCOMER ON
+6/19/03. 6/19/03 ENTERED AND COPIES MAILED (ph, ) (Entered:
+06/19/2003)
+17 STIPULATION AND ORDER THAT DEFENDANTS MUST SUBMIT
+A REPLY TO PLAINTIFF'S MOTION TO DISMISS COUNT II OF
+DEFENDANTS' COUNTERCLAIM BY 7/14/03 ETC . SIGNED BY
+JUDGE CLARENCE C. NEWCOMER ON 7/8/03. 7/9/03 ENTERED
+AND COPIES MAILED AND FAXED 7/8/03(ph, ) Additional
+attachments) added on 7/9/2003 (ldb, ). (Entered: 07/09/2003)
+18 | Reply to plaintiff's motion to dismiss pursuant to FRCP 12(b)(6),
+Certificate of service filed by ABIGAIL WEXNER, LESLIE WEXNER.
+(ph, ) Additional attachments) added on 7/17/2003 (ph, ). (Entered:
+07/15/2003)
+19 | Response to defendants' reply to motion to dismiss counterclaim for
+ailure to state a claim upon which relief can be granted, Certificate o1
+service filed by NELSON SHANKS. (ph, ) (Entered: 07/21/2003
+20 MOTION FOR JUDGMENT ON THE PLEADINGS AGAINST
+https://ecf.paed.uscourts.gov/cgi-bin/DktRpt.p|?261521028494284-L_353_0-1
+
+
+United States District Court Eastern District of Pennsylvania - Docket Report
+
+08/21/2003
+08/26/2003
+08/26/2003
+08/26/2003
+08/27/2003
+08/28/2003
+08/28/2003
+09/04/2003
+09/05/2003
+09/05/2003
+JEFFREY EPSTEIN WITH RESPECT TO COUNT I OF THE
+COMPLAINT (BREACH OF CONTRACT), CERTIFICATE OF
+SERVICE FILED BY NELSON SHANKS..(ph, ) (Entered: 08/13/2003)
+21 ORDER THAT UPON CONSIDERATION OF PLAINTIFF'S MOTION
+TO DISMISS AND DEFENDANTS' RESPONSE, IT IS ORDERED
+THAT SAID MOTION IS DENIED ETC.. SIGNED BY JUDGE
+JAMES R. MELINSON ON 8/21/03.8/22/03 ENTERED AND COPIES
+MAILED (ph, ) (Entered: 08/22/2003)
+22 PLAINTIFF'S MOTION TO COMPEL FILED BY NELSON
+SHANKS, CERTIFICATE OF COUNSEL, CERTIFICATE OF
+SERVICE.(ar, ) (Entered: 08/26/2003)
+23| ANSWER AND AFFIRMATIVE DEFENSES OF PLAINTIFF TO
+COUNTERCLAIMS OF DEFENDANTS LESLIE AND ABIGAIL
+WEXNER BY NELSON SHANKS, CERTIFICATE OF SERVICE.(ar,)
+(Entered: 08/26/2003)
+24 | Supplement to Plaintiff's Motion for Judgment on the Pleadings Against
+Defendant Jeffrey Epstein with Respect to Count I of Plaintiffs
+Complaint (Breach of Contract) filed by NELSON SHANKS, Certificate
+of Service. (ar, ) (Entered: 08/26/2003)
+25 | Memorandum in opposition to plaintiff's motion for judgment on the
+›leadings as to count one - breach of contract, Certificate of service file
+y JEFFREY E. EPSTEIN. (ph, ) Additional attachment(s) added ol
+9/4/2003 (ph, ). (Entered: 08/28/2003)
+26 | Reply to EPSTEIN'S memorandum in opposition to plaintiff's motion for
+judgment on the pleadings, Certificate of service by NELSON SHANKS.
+(ph, ) (Entered: 08/29/2003)
+27 MOTION TO STRIKE DEFENDANT'S MEMORANDUM IN
+OPPOSITION FOR VIOLATION OF COURT ORDER, CERTIFICATE
+OF SERVICE filed by NELSON SHANKS. (SEE #26). (ph, ) (Entered:
+08/29/2003)
+28 ORDER DENYING PLAINTIFF'S MOTION FOR JUDGMENT ON
+THE PLEADINGS WITH RESPECT TO COUNT I, THE COURT
+FINDS THAT THERE ARE FACTUAL ISSUES IN THIS CASE AS
+TO WHETHER A CONTRACT WAS FORMED BETWEEN THE
+PARTIES AND THE TERMS OF ANY SUCH CONTRACT.. SIGNED
+BY JUDGE CLARENCE C. NEWCOMER ON 9/4/03.9/4/03
+ENTERED AND COPIES MAILED AND FAXED. (ph, ) (Entered:
+09/04/2003)
+29
+RESPONSE to plaintiff NELSON SHANKS' motion to compel,
+Certificate of service filed by JEFFREY E. EPSTEIN, GHISLAINE
+MAXWELL, ABIGAIL WEXNER, LESLIE WEXNER. (ph, ) (Entered:
+09/08/2003)
+30 MOTION FOR PROTECTIVE ORDER TO QUASH NOTICE OF
+https://ecf.paed.uscourts.gov/cgi-bin/DktRpt.pl?261521028494284-L_353_0-1
+
+
+United States District Court Eastern District of Pennsylvania - Docket Report
+
+09/09/2003
+09/10/2003
+09/18/2003
+09/23/2003
+09/23/2003
+10/21/2003
+10/24/2003
+DEPOSITIONS, MEMORANDUM, CERTIFICATION OF COUNSEL,
+CERTIFICATE OF SERVICE filed by JEFFREY E. EPSTEIN,
+GHISLAINE MAXWELL, ABIGAIL WEXNER, LESLIE WEXNER...
+(ph, ) Additional attachments) added on 10/1/2003 (ph, ). Additiona.
+attachments) added on 10/10/2003 (ph, ). (Entered: 09/08/2003)
+31 ORDER MOOTING PLAINTIFFS' MOTION TO COMPEL THE
+PRODUCTION OF DOCUMENTS AND RESPONSES TO
+INTERROGATORIES ETC.. SIGNED BY JUDGE CLARENCE C.
+NEWCOMER ON 9/9/03.9/10/03 ENTERED AND COPIES MAILED
+AND FAXED 9/9/03(ph, ) (Entered: 09/10/2003)
+2 | Reply to defendants' motion for a protective order to quash notice ‹
+epositions and supplemental memorandum of law in connection wi
+aintiff's motion to compel discovery responses, Certification of couns
+ertificate of service filed by NELSÓN SHANKS. (ph, ) Addition
+attachment(s) added on 9/18/2003 (fh, ). (Entered: 09/11/2003)
+33 | ORDER DENYING AS MOOT DEFENDANT'S MOTION TO QUASH
+NOTICE OF DEPOSITIONS, UPON REPRESENTATION THAT THE
+PARTIES HAVE AGREED UPON THE LOCATIONS OF THE
+NOTICED DEPOSITIONS ETC.. SIGNED BY JUDGE CLARENCE
+C. NEWCOMER ON 9/18/03.9/18/03 ENTERED AND COPIES
+MAILED (ph, ) (Entered: 09/18/2003)
+34| ORDER THAT THE COURT'S PRETRIAL SCHEDULING ORDER IS
+AMENDED AS FOLLOWS: DISCOVERY BY 10/10/03,
+SETTLEMENT/FINAL PRETRIAL CONFERENCE ON 10/20/03 AT
+11:15; PRETRIAL MEMORANDA AND JOINT PROPOSED JURY
+INSTRUCTIONS 10/15/03; COUNSEL SHALL BE PREPARED FOR
+TRIAL ON 10/20/03 . SIGNED BY JUDGE CLARENCE C.
+NEWCOMER ON 9/23/03. 9/24/03 ENTERED AND COPIES MAILED
+(ph, ) (Entered: 09/24/2003)
+SETTLEMENT CONFERENCE SET FOR 10/20/2003 11:15 AM
+BEFORE HONORABLE CLARENCE C. NEWCOMER. (ph,)
+(Entered: 09/24/2003)
+35 STIPULATION AND ORDER THAT THE COURT DISMISS THE
+CAPTIONED MATTER, INCLUDING ALL CLAIMS AND
+COUNTERCLAIMS, WITH PREJUDICE.. SIGNED BY JUDGE
+CLARENCE C. NEWCOMER ON 10/21/03. 10/21/03 ENTERED AND
+COPIES MAILED AND FAXED.(ph, ) (Entered: 10/21/2003)
+36 STIPULATION AND ORDER THAT PURSUANT TO FRCP 41(a)(1)
+(i) AND THE SETTLEMENT AGREEMENT, THAT THE PARTIES
+REQUEST THE COURT DISMISS THE CAPTIONED MATTER,
+INCLUDING ALL CLAIMS AND COUNTERCLAIMS, WITH
+PREJUDICE.. SIGNED BY JUDGE CLARENCE C. NEWCOMER ON
+10/24/03. 10/24/03 ENTERED AND COPIES MAILED AND FAXED
+BY CHAMBERS(ph, ) (Entered: 10/24/2003)
+https://ecf.paed.uscourts.gov/cgi-bin/DktRpt.p|?261521028494284-L_353_0-1
+
+
+United States District Court Eastern District of Pennsylvania - Docket Report
+
+PACER Login: du4480
+Description:
+Billable Pages:
+PACER Service Center
+Transaction Receipt
+05/22/2007 18:33:24
+[Client Code:
+Docket Report Search Criteria: |/2:02-cv-07671-CN
+Cost:
+0.32
+https://ecf.paed.uscourts.gov/cgi-bin/DktRpt.p|7261521028494284-L_353_0-1
+
+
+CIVIL ACTION
+Plaintiff,
+:
+:
+1
+LESLIE and ABIGAIL WEXNER, et al.
+Defendants.
+:
+:
+NO. 02-7671
+ORDER
+AND NOW, this
+day of September, 2003, upon consideration of
+Defendants' Motion For A Protective Order to reschedule and relocate the depositions of
+each Defendant, IT IS HEREBY ORDERED that Defendants' Motion is GRANTED and
+the Notices of Deposition issued are quashed without prejudice to have them rescheduled
+by agreement of the parties.
+BY THE COURT:
+Clarence C. Newcomer, S.J.
+PHLIT45448611
+
+
+IN THE UNITED STATES DISTRICT COUR
+OR THE EASTERN DISTRICT OF PENNSYLVANI
+:
+CIVIL ACTION
+Plaintiff,
+LESLIE and ABIGAIL WEXNER, et al.
+Defendants.
+:
+:
+NO. 02-7671
+DEFENDANTS' MOTION FOR A PROTECTIVE ORDER
+TO QUASH NOTICE OF DEPOSITIONS
+Defendants, by and through their counsel, hereby move this Court,
+pursuant to Fed. R. Civ. P. 26(c)(2), for a protective order to reschedule and relocate the
+depositions of Jeffrey Epstein, Ghislaine Maxwell, and Abigail and Leslie Wexner, who
+received notices of oral deposition to be taken in the offices of Plaintiff's counsel,
+Gollatz, Griffin & Ewing, located in Philadelphia, Pa.: Jeffrey Epstein and Ghislaine
+Maxwell, noticed for September 9, 2003; Abigail and Leslie Wexner, noticed for
+September 10, 2003.
+In support of this motion, Defendants submit the accompanying
+Memorandum of Law.
+PHLIT4544861
+
+
+I J. Fox
+Attorney Identification No. 15261
+Christopher J. Guiton
+DRINKER BIDDLES NEATH LLP
+One Logan Square
+18th and Cherry Streets
+Philadelphia, PA 19103-699€
+Counsel for Defendants
+PHLIT454486\1
+
+
+CIVIL ACTION
+Plaintiff,
+:
+LESLIE and ABIGAIL WEXNER, et al.
+Defendants.
+:
+NO. 02-7671
+MEMORANDUM OF LAW IN SUPPORT OF DEFENDANTS' MOTION FOR A
+PROTECTIVE ORDER TO QUASH NOTICE OF DEPOSITIONS
+Without any consultation with counsel for Defendants to find mutually acceptable
+dates and times, on August 27, 2003, Plaintiff Nelson Shanks provided notices to
+Defendants' counsel of the oral depositions of Defendants Jeffrey Epstein, Ghislaine
+Maxwell, Abigail Wexner and Leslie Wexner to be taken on September 9'' and 10", 2003
+in the offices of Gollatz, Griffin & Ewing, P.C., in Philadelphia, Pa.
+As Plaintiff well knows, defendants Jeffrey Epstein and Ghislaine Maxwell reside
+in the U.S. Virgin Islands, and defendants Abigail and Leslie Wexner reside in New
+Albany, Ohio.
+While Plaintiff may be permitted to designate his location of choice for the
+depositions, this Court has the power and duty under Fed. R. Civ. P. 26(c) to determine
+the most appropriate location for each deposition. See e.g., O'Connor I. Trans Union
+Corp., 1998 U.S. Dist. LEXIS 6774 (E.D. Pa. May 11, 1998). This Court has previously
+determined "that as a general rule, if a deponent lives a substantial distance from the
+deposing party's residence, the deposing party should be required to take the deposition at
+
+
+a location in the vicinity in which the deponent resides." First Fidelity Bancorporation:
+National Union Fire Ins. Co., 1992 U.S. Dist. LEXIS 3367 (E.D. Pa. Mar. 5, 1992).
+Pursuant to Fed. R. Civ. P. 26(c)(2), defendants seek an order that would protect
+them from the undue burden and expense of traveling to Philadelphia for these
+depositions; defendants Jeffrey Epstein and Ghislaine Mawell will submit to a deposition
+in the Virgin Islands; and defendants Abigail and Leslie Wexner seek an order that would
+protect them from being forced to travel from New Albany, Ohio to Philadelphia for their
+depositions.
+Under the circumstances, the Notice served on August 27, 2003 requiring each of
+the defendants to fly to Philadelphia is unreasonable and unduly burdensome. As the
+Court well knows, the basis for asserting jurisdiction over these defendants does not
+include any instance when any of them visited Pennsylvania. It was Plaintiff who
+traveled to New York and Ohio in connection with this matter. Accordingly, if these
+depositions are to proceed, they should occur at the locations of the defendants. It is far
+less dislocating for Plaintiff's lawyer to travel to take these depositions in the Virgin
+Islands and Ohio than it would be to force four people to take the time required to travel
+to Philadelphia.
+Although Plaintiff had earlier expressed a commitment to working out a schedule
+that is convenient to all parties, Plaintiff has unilaterally scheduled the depositions with
+no regard to the inconvenience it may impose on the parties to be deposed. Such conduct
+is in direct contrast with the manner in which Defendants have attempted to depose
+Plaintiff.
+PHLIT45448611
+
+
+For example, Defendants noticed the deposition of Plaintiff Nelson Shanks for
+June 9, 2003. Immediately thereafter, Defendants agreed with Plaintiff to postpone that
+date so that the parties could come to a mutually agreeable date for the deposition.
+Plaintiff still, nearly three months later, has yet to agree to a date in which Shanks can be
+deposed, but has instead unilaterally designated September 9* and 10" in Philadelphia as
+the time and place for Defendants' depositions. Defendants object to these depositions
+being taken in Philadelphia given the difficulty for these individuals to make
+arrangements to be deposed miles away from their respective residences.
+Based upon Plaintiff's recent reluctance to discuss, much less honor, any mutual
+agreements, Defendants ask this Court to quash Plaintiff's Notice of Depositions and
+grant this protective order, rescheduling the depositions for a date and time that is
+suitable for both the Defendants and Plaintiff, and relocating the depositions from
+Philadelphia to the U.S. Virgin Islands for Mr. Epstein and Ms. Maxwell; and New
+Albany, Ohio for the Wexners.
+Accordingly, this Court should grant Defendants' motion for a protective order
+and quash the depositions of Jeffrey Epstein, Ghislaine Maxwell, and Abigail and Leslie
+Wexner, without prejudice to have them rescheduled at a convenient location.
+CONCLUSION
+For all of the foregoing reasons, Defendants respectfully request that the
+Court grant its Motion for a Protective Order or such other relief as the Court deems
+appropriate.
+
+
+J. Fox
+Attorney Identification No. 89866
+DRINKER BIDDLE & REATH LLP
+One Logan Squar
+Philadel Cia, PA 19103-699
+Attorneys for Defendants
+PHLIT1454486\1
+
+
+CERTIFICATE OF SERVICE
+1, Christopher J. Guiton, hereby certify that on this 5" day of September
+2003, I caused a true and correct copy of the foregoing Defendants' Motion for a
+Protective Order and accompanying Memorandum of Law to be served as follows:
+VIA HAND DELIVERY
+Jeffrey Hofferman, Esquire
+Gollatz, Griffin & Ewing, P.C.
+Four Penn Center, Suite 200
+Philadelphia, PA 19103
+(Attorney for Plaintiff)
+By:
+Christopher J. Guiton
+PHLIT1454486\1
+
+
+CIVIL ACTION
+:
+Plaintiff,
+LESLIE and ABIGAIL WEXNER, et al.
+Defendants.
+NO. 02-7671
+CERTIFICATION OF GOOD FAITH EFFORTS
+TO RESOLVE DISCOVERY DISPUTES
+BEFORE FILING MOTION
+J. Fox, Esquire, hereby certifies that he is counsel for
+Defendants and that prior to filing Defendants' Motion for a Protective Order to
+reschedule and relocate the depositions of Jeffrey Epstein, Ghislaine Maxwell, and
+Abigail and Leslie Wexner, he engaged in good-faith efforts with Plaintiff's counsel,
+Jeffrey Hofferman, to resolve this dispute. He wrote Mr. Hofferman a letter requesting
+rescheduling. Mr. Hofferman did not bother to respond to the letter.
+|J. Fox
+Counsel for Defendants,
+
+
+
+Department of Licensing and Consumer Affai
+DE.CA Home
+Business License
+Taxi Operators License
+Board Certifications
+Consumer Affairs
+Commissioner Robertsan
+Ahout the DLCA
+Business Search
+Business License Search
+Business Name Search
+Category A-Z New Business Listings
+Image for Premium Listings
+Records per page:
+110 =
+Found 34 Records
+1234 Next
+Records 1 to 10
+Enter Business Name (use fewer letters for more results)
+financial
+Search
+--Bookkeeping Services--
+DEPAUL FINANCIAL SERVICES
+340-692-1829
+FREDERIKSTED, St. Croix
+License #: 2-2020117-2006
+WINSLOW & WINSLOW FINANCIAL SERVICES, INC.
+940-713-9713
+FREDERIKSTED, St. Croix
+License #: 2-2025606-2006
+-Business & Management Consulting--
+BARRY FINANCIAL SERVICES INC
+St. Thomas
+License #: 1-2025931-2007
+EMAX FINANCIAL GROUP
+340 719-4600
+Christiansted, St. Croix
+License #: 2-2030892-2007
+FINANCIAL TRUST COMPANY, INC.
+340-775-2525
+St. Thomas
+Golden Roc
+Chr
+St. Cro
+Phone: (-
+Fax: (34
+Adminis
+*SE
+http://www.dlca.gov.vi/bussearch.asp?norecs=10&name=financial
+
+
+
+License #: 1-2021802-2006
+GLOBAL FINANCIAL STRATEGIES, LLC
+St. Thomas
+License #: 1-1004878-2007
+GOLDEN EAGLE FINANCIAL, LLLP
+340-774-2273
+St. Thomas
+License #: 1-2013600-2006
+GULFSTREAM FINANCIAL, LLC
+St. Thomas
+License #: 1-2028797-2007
+HORIZON FUEL AND FINANCIAL MANAGEMENT
+340-719-7915
+Christiansted. St. Croix
+License #: 2-2030321-2007
+HORIZON FUEL AND FINANCIAL MANAGEMENT,
+LIMITED LIABILITY LIMITED PARTNERSHIP
+340-719-7915
+CHRISTIANSTED, St. Croix
+License #: 2-2020644-2006
+Found 34 Records
+1234 Next
+Records 1 to 10
+ficial Website of the USVI Department of Licensing and Consumer Affair
+Vebmastering by Vastimagin
+Site Last Updated May 19, 2003
+http://www.dlca.gov.vi/bussearch.asp?norecs=10&name=financial
+
+
+
+Not Reported in F.Supp.
+Not Reported in F.Supp., 1998 WL 67676 (S.D.N.Y.)
+(Cite as: Not Reported in F.Supp.)
+Page 1
+H
+U.S. |. Epstein
+S.D.N.Y.,1998.
+Only the Westlaw citation is currently available.
+United States District Court, S.D. New York.
+UNITED STATES OF AMERICA, Plaintiff,
+Jeffrey E. EPSTEIN and Ivan S. Fisher,
+Defendants.
+No. 96 Civ. 8307(DC).
+Feb. 19, 1998.
+Mary Jo White, United States Attorney for the
+Southern District of New York, by Serene Nakano,
+Assistant United States Attorney, New York City,
+for the United States.
+Gage & Pavlis, by G. Robert Gage, Jr., Ellen J.
+Casey, New York City, for Ivan S. Fisher.
+MEMORANDUM DECISION
+CHIN, J.
+*1 In this case, the United States (the "Government"
+) seeks to evict defendants Jeffrey E. Epstein and
+İvan S. Fisher from a building formerly used as a
+residence by the Deputy Consul General of the
+Islamic Republic of Iran ("Iran"). After diplomatic
+and consular relations with Iran were severed in
+1980, the Office of Foreign Missions ("OFM") of
+the United States Department of State took
+possession of the building pursuant to the Foreign
+Missions Act, 22 U.S.C. § 4301 et seg. OFM
+leased the building to Epstein in 1992. Epstein
+eventually sublet the premises to Fisher,
+purportedly without the Government's consent.
+Fisher, in turn, sublet a portion of the premises to
+several other lawyers.
+In 1996, the Government purported to terminate
+Epstein's lease and brought this action to evict
+Epstein and Fisher. The other sub-tenants were
+later added as defendants. The Government also
+seeks to recover back rent from Epstein and Fisher.
+the
+Government requested
+objection on the condition that the retur b
+protected by an appropriate confidentiality ordet
+Government, however, were unable to agree on the
+separate proposed protective orders
+for my
+consideration.
+The Goverment's proposed order contains a
+provision ("Proposed Paragraph 7(c)") that would
+permit the United States Attorney's Office for the
+Southern District of New York to disclose any
+confidential information governed by the protective
+order to other government agencies for the purpose
+of enforcing the criminal or civil laws of the United
+States. Thus, the Government secks to reserve the
+right to use confidential information produced by
+Fisher in this case in unrelated civil or criminal
+matters. The Government contends that Proposed
+Paragraph 7(c) is necessary because the
+Attorney's Office has a statutory duty to enforce the
+laws, citing 28 U.S.C. § 547(c), and that it therefore
+cannot ignore any evidence of a violation of
+law-even evidence that comes to its attention only
+because it is produced pursuant to a protective order
+in discovery in a civil case. Fisher objects to
+Proposed Paragraph 7(c). He contends that use of
+any confidential documents produced in this case
+should be limited to this lawsuit.
+Fisher's objection is sustained, for three reasons.
+First, confidentiality orders are intended "to "secure
+the just, speedy, and inexpensive determination' of
+civil disputes by encouraging full disclosure of all
+evidence that might conceivably be relevant."
+Martindell | International Tel. & Tel. Corp., 594
+F.2d 291, 295 (2d Cir.1979). Unless protective
+orders are "fully and fairly enforceable," persons
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rlti=1&prft=HTMLE&fn=_top...
+
+
+
+Not Reported in F.Supp.
+Not Reported in F.Supp., 1998 WL 67676 (S.D.N.Y.)
+(Cite as: Not Reported in F.Supp.)
+relying upon such orders will be inhibited from
+providing essential testimony and information in
+civil litigation,
+"thus undermining a procedural
+system that has been successfully developed over
+the years for disposition of civil differences." Id. A
+provision that would permit the use of confidential
+information outside of this lawsuit would defeat the
+very purpose of the protective order.
+*2 Second, although the Court recognizes the strong
+public interest in obtaining all relevant evidence
+required for law enforcement purposes, the
+Government as investigator * 'has awesome
+owers' [that] render unnecessary its exploitation o
+Id. (guoting GAI
+Page 2
+not be included in the protective order "merely to
+accommodate the Government's desire to inspect
+protected
+[information]
+for possible use
+criminal lor civill investigation." Martindell," 594
+› witnesses d
+rdeit esses deposiien ait sipis be decedo buli
+its statutory obligation to enforce the law through
+rdinary criminal and civil process and b
+SO ORDERED.
+S.D.N.Y.,1998.
+U.S. [. Epstein
+(S.D. Reported in Fi.Sup,
+1998 WL 67676
+END OF DOCUMENT
+the Government to investigate suspected violations
+of the law.
+Third, tax information has traditionally been treated
+and confidential information.
+6103 of the Internal Revenue Code, for example,
+specifically prohibits
+officer or employee of the United States, from "
+disclos[ing] any return or return information
+obtained ... in any manner in connection with his [or
+her] service as such an officer or employee." 26
+U.S.C. § 6103(a). Section 6103 also spells out the
+limited situations when an officer or employee may
+disclose return information. See, e.g., § 6103(h)(2)
+(disclosure of returns and return information to
+Department of Justice employees), § 6103(h)(4)
+(disclosure of returs or return information in
+judicial
+administrative proceedings).
+This
+section provides specifie limits on the disclosure of
+returns and return information and bolsters the
+conclusion that Fisher's tax return is entitled to
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rlti=1&prft=HTMLE&fn=_top... 5/22/2007
+
+
+640
+tered trade dress, in violation of § 43(a) of Moreover, Hargen also claims that FT's plasthe Lanham Act. Hargen contends that FT
+tie boxes are functional because they allow
+cannot obtain relief under the Lanham Act for easy shipping, allow for shelf display and
+because FT's trade dress is funetional.*
+stacking, protect the crystals from chipping.
+protect the crystals from dissolving in moist
+[10, 11] A trade dress is functional when
+places, and are designed to hold the crystal
+the trade dress "is essential to the uses or
+purposes of the article or if it affects the cost
+deodorant in the same way that a soap dish
+or quality of the article." Inwood Lats, Inc
+holds soap. Memo in Support of Summary
+| Ives Labs, Inc, 456 U.S. 844, 850 n. 10,
+Judgment at 11-13. See Rosenblatt dep. at
+102 S.Ct. 2182, 2187 n. 10, 72 L.Ed.2d 606
+95; vol. IV at 19. As is apparent, disputed
+issues of material fact remain about the fune-
+(1982). A produet's trade dress must be
+tionality or non-functionality of the plaintiff's
+trade dress. Therefore, Hargen's motion for
+summary judgment on FT's trade dress
+claims is denied.
+III. Causes of Action Under New York
+Law
+ecause Hargen has undertaken no ind
+endent analysis of FT's New York causes
+etion, Hargen's motion for summary jud
+nent on these causes of action is denie
+Conclusion
+Hargen's motion for summary judgment is
+denied.
+SO ORDERED.
+However, if a trade dress is found to be
+functional, its features may be copied even if
+confusion would result. American Greetings
+Corp. . Dan-Dee Imports, Inc., 807 F.2d
+1136, 1141 (3d Cir.1986).
+FT states that its packaging design was
+chose led, and the resign ten pret a so.
+of the deodorant stone.
+Rosenblatt dep. at
+520-522. FT also states that FT colored the
+package blue because it liked that color, not
+cosmetic packaging.
+the evidence before us indicates FT and at
+least one other producer of deodorant stones
+pack their deodorant products in other packaging besides plastie boxes.
+• For example,
+plaintiff also packs its deodorant stone in a
+soft plastic pouch, a triangular cardboard
+box, a shrink-wrapped soap dish and satin
+pouches of various colors.
+Rosenblatt aff.
+195, 9,
+13.
+Moreover,
+another company,
+Michael R. STROLL, Plaintiff,
+whose name Rosenblatt could not recall at
+his deposition, distributes a similar product
+in a velvet,
+drawstring pouch.
+dep. at 379-380. This evidence suggests that
+plaintif's packaging in this case may not be
+functional.
+Defendant claims that FT's packaging is
+functional because the packaging is allegedly
+Jeffrey EPSTEIN, Defendant.
+No. 92 Civ, 1021 (KC).
+United States District Court,
+S.D. New York.
+April 15, 1993.
+efficient and compact, because the packaging
+allows consumers to see the product, and
+because the packaging is commonly used in
+bee aste hand roin deodorant industry. against first venturer, suking to recover unt
+4. Defendant alternatively claims that even if the
+however, is not claiming exclusive rights to the
+packaging is not functional, plaintiff cannot
+use of blue in its packaging. Memo in Opp. to
+Summary Judgment at 13. Rather, plaintiff
+claims a proprietary interest in the entirety of its
+
+
+STROLL | EPSTEIN
+641
+Cite as 818 F.Supp. 640 (S.D.N.Y. 1993)
+der contract in which second venturer reapply. N.Y.MeKinney's Uniform Commerleased his interest in venture. First venturcial Code 56 3-104(1)(d), 3-403, 3 403(2)(b).
+ment, and second venturer cross-moved for
+for other bleat More on pree
+summary judgment.
+The Distriet Court,
+initions.
+Conboy, J., held that: (1) agreement under 5. Contracts e176(2)
+which first joint venturer agreed to return
+capital contribution to second joint venturer
+of law the erit is any gous is matter.
+upon return of all interests in venture by
+second
+venturer unambiguously indicated
+6. Contracts e-143(2)
+that first venturer was acting solely in repre-
+Contract is "ambiguous" If it is reasonsentative capacity, not personal capacity, and
+ably susceptible of more than one interpreta-
+(2) modification of original joint venture
+tion.
+agreement making first joint venturer personally liable for managing affairs of joint
+for sher bleat oard and parat
+venture could not be construed as imposing
+initions.
+personal liability on first joint venturer in
+event joint venture subsequently bought out
+second venturer's interest.
+Motions granted in part and denied in
+part.
+Unambiguous contract language is not
+rendered ambiguous simply because parties
+urge different interpretations in litigation.
+8. Contracts -143.5
+Whether contract is ambiguous is to be
+1. Federal Courts 6-409
+In diversity action, federal court sitting
+in New York must apply New York law,
+including New York's choice-of-law rules.
+2. Contracts 6-144
+Under New York's choice-of-law rules,
+determined by considering contract as whole,
+under New York law.
+9. Joint Adventures 6-4(1)
+Agreement under which first joint venturer agreed to return capital contribution to
+second joint venturer upon return of all interests in venture by second venturer unambiguously indicated that first venturer was
+acting solely in representative capacity, not
+cant relationship to transaction and parties.
+personal capacity, when he agreed to return
+second venturer's contribution, under New
+3. Joint Adventures C-4(1)
+York law; agreement indicated that first
+New York was state with most signifiventurer was acting both as officer of vencant relationship to agreement in which one
+ture and as agent for venture, although first
+joint venturer agreed to return capital contrijoint venturer did not sign contract expressly
+bution to another venturer, and thus, New
+in representative capacity.
+York law governed meaning of agreement, in
+diversity action; contract was executed in
+10. Contracts •-179
+New York and one party was New York
+Contract which demonstrates on its face
+citizen.
+that defendant was acting solely in representative capacity will not be rendered ambigu-
+4. Bille and Notes e-147
+ous under New York law simply because
+Contract under which one joint venturer defendant failed to sign contract in represenagreed to return capital contribution to an-tative capacityother venturer was not "negotiable instrument" as it was not payable to order or
+11. Principal and Agent 136(1)
+bearer, and thus, provision of New York
+Under New York law, agent for dis-
+Uniform Commercial Code governing inter- closed principal will not be held personally
+pretation of negotiable instruments did not liable unless there is clear and explicit evi-
+
+
+642
+dence of agent's intent to substitute or add execution of agreement under which second
+his own personal liability for, or to, that of joint venturer's capital contribution was to be
+returned by venture could not make first
+venturer personally liable under such con-
+12. Evidence C=384
+If contract is unambiguous on its face,
+tract.
+extrinsic evidence may not be presented to 18. Contracts 0170(1)
+create ambiguity, under New York law.
+Where contract is unambiguous on its
+face, evidence of conduct occurring subsequent to execution of contract may not be
+Modification of original joint venture introduced to create ambiguity.
+joint venture could not be construed as im- Arthur M. Handler, Whitman & Ransom,
+posing personal liability on first joint ventur- New York City, for plaintiff.
+er in event of joint venture subsequently Elliot Silverman, Gold & Wachtel, New
+buying out second venturer's interest in ven- York City, for defendant.
+14. Evidence 6=384
+Where parties have expressed their
+agreement in unambiguous and integrated
+writing, New York's parol-evidence rule operates to exclude evidence of all prior and
+contemporaneous negotiations or agreements
+offered to contradiet or modify terms of writing.
+15. Evidence 6-397(2)
+Writing is "integrated" for purpose of
+New York's parol-evidence rule if it completely and accurately embodies all mutual
+rights and obligations of parties.
+See publication Words and Phrases
+for other judicial constructions and definitions.
+ORDER
+CONBOY, District Judge:
+We have before us an action for breach of
+contract
+Plaintiff Michael R. Stroll
+(Stroll") seeks to recover from defendant
+Jeffrey Epstein ("Epstein") money allegedly
+owed pursuant to a contract in which Stroll
+relinquished his interest in a joint venture.
+Epstein asserts that he executed the contract
+in a representative capacity, as an agent for
+the venture and as an officer of the Intercontinental Asset Group ("I.A.G."), and that,
+therefore, he is not personally liable under
+the contract.
+Pending before the Court are two motions:
+(1) defendant Epstein's motion to dismiss the
+16. Evidence 6-997(1)
+complaint for failure to state a claim upon
+Evidence that first joint venturer orally
+which relief can be granted, or, in the alterpromised to personally repay second venturnative, for summary judgment; ' and (2)
+er's capital contribution contradicted unamplaintiff Stroll's cross-motion for summary
+biguous terms of integrated written agreejudgment. For the reasons that follow, Ep-
+ment entered by first venturer in his represtein's motion for summary judgment is
+sentative capacity, and thus was inadmissible granted, and Stroll's cross-motion is denied.
+under New York's parol-evidence rule.
+Discussion?
+17. Joint Adventures (=4(1)
+A. The November 1984 Contract
+Alleged partial payment or promise to
+[1-3] Defendant Epstein moves for sumpay personally by first joint venturer after mary judgment on the ground that the No-
+1. As this Court will consider matters extrinsic to 2. This Court has diversity jurisdiction over the
+the complaint, we will treat defendant Epstein's
+present action pursuant to 28 U.S.C. § 1332(a),
+motion to dismiss as a motion for summary judgas plaintiff Stroll is a citizen of Florida, defenment. See Fed.R.Civ.P. 12(b).
+dant Epstein is a citizen of New York, and the
+sum in controversy is $440,000.
+
+
+STROLL 1 EPSTEIN
+643
+Cite as 818 F.Supp. 640 (S.D.N.Y. 1993)
+vember 1984 contract unambiguously indi-
+F.Supp. at 1366. A contract is ambiguous if
+cates the parties' intention that Epstein was
+it is reasonably susceptible of more than one
+interpretation. Chimart, 498 N.Y.S.2d at
+346, 489 N.E.2d at 283. Unambiguous concontribution in the joint venture.?
+[4-8] "Under New York law,'
+... the
+Court must look first to the parties' written
+agreement to determine the parties' intent
+and [must] limit its inquiry to the words of
+the agreement itself if the agreement sets
+forth the parties' intent clearly and unambiglously." Sterling Drug Inc. : Bayer AG
+192 F.Supp. 1357, 1365 (S.D.N.Y.1992). See
+also Chimart Associates | Paul, 66 N.Y.2d
+570, 498 N.Y.S.2d 344, 346, 489 N.E.2d 231,
+233 (Ct.App.1986) (Where a contract is unambiguous on its face, the Court may not
+consider evidence extrinsie to the contract to
+determine the parties' intent.). Whether a
+contract is ambiguous is a matter of law to be
+determined by the Court.
+Lill
+In a diversity action, a federal court sitting in
+New York must apply New York law, including
+New York's choice of law rules.
+feld Fur Merchants, Inc. | Kilbourne & Donahue,
+Inc., 704 F.Supp. 466, 468 (S.D.N.Y.1989). See
+Claron Co. / Stentor Electric Míg. Co., 313 U.S
+487. 496. 61
+S.Ct. 1020, 102l, 85 L.Ed. 1477
+(1941): see also Erie R. Co. | Tompkins, 304 U.S
+L.Ed. 1188 (1938).
+Under New York's choice of law rules, when a
+court is construing the meaning of a contract,
+the Court should
+"apply the local law of that
+state which bas the greatest interest in or the
+most significant relationship to the transaction
+and the parties.".
+of N. Am.,
+cert. denied, 440 U.S. 912, 99 S.Ct. 1226,
+L.Ed 2d 461 (1979). In the present action, the
+state with the most significant relationship to the
+transaction is New York: the contract being sued
+upon was executed in New York, defendant Ep-
+stein is a New York citizen, and I.A.G. is a New
+Moreover, both parties agree
+that New York law applies in this case.
+ingly, we look to New York law to construe the
+meaning of the November 1984 contract.
+3. Initially, we note that Epstein contends that
+this action
+is time-barred pursuant to N.Y.
+C.P.L.R. § 213(2) (McKinney 1990), which provides a six-year statute of limitations for breach
+of contract claims. Stroll contends that the statute of limitations was tolled as he received a
+$10,000 personal check from Epstein in May of
+more accore dated or his recep i pero pay
+funds. See Commissioners of the State Ins. Fund
+I Warner, 156 A.D.2d 131, 54B N.Y.5.2d 883,
+883 (Ist Dep't 1989) (stating the common law
+rule that the statute of limitations will be tolled if
+tractual language is not rendered ambiguous
+simply because the parties urge differen
+nterpretations in litigation." Sterling, 79
+F.Supp. at 1366. Moreover, whether a contract is ambiguous is to be determined by
+onsidering the contract as a whole. Wing
+Wing, 112 A.D.2d 932, 492 N.Y.S.2d 450, 45
+(2d Dep't 1985).
+[9] Applying the above-mentioned principles, this Court concludes that the November
+1984 contract, when read as a whole, unambiguously indicates the parties' intention that.
+Epstein was acting solely in a representative
+capacity when he agreed to return Stroll's
+capital contribution. The body of the contract makes clear that Epstein executed the
+the creditor can show that the payment "was a
+payment of a portion of the admitted debt
+accompanied by circumstances amounting to an
+absolute and unqualified acknowledgment by the
+debtor of more being due, from which a promise
+may be inferred to pay the remainder.").
+Ep-
+stein asserts that he paid Stroll $10,000 because
+Stroll had purchased a horse for him.
+Epstein
+presents no evidence of this purchase,
+though.
+Because all reasonable inferences on a summary
+judgment motion are to be drawn in favor of the
+on-moving party, Knight i U.5. Fire Ins. Lo
+04 F.2d 9, 11 (2d Cir.1986), we hold that the
+present action is not time-barred for the purposes of this motion.
+Stroll contends that § 3-403(2)(b) of the New
+York Uniform Commercial Code should govern
+our interpretation of the November 1984 con-
+See N.Y.U.C.C. § 3-403(2)(b) (McKinney
+1991). We disagrce. Section 3-403 governs ne-
+Finnish Fur Sales Co.
+Tuliete Shuloff Furs, Inc., 770 F.Supp. 139, 1
+(S.D.N.Y.1991); Rotuba Exudes, In. 14S. 3as
+46 N.Y.2d 223, 413 N.Y.S.2d 141.
+N.E.2d 1068, 1070 (Ct.App.1978). As Stroll concedes, the present contract is not a negotiable
+nstrument because it is not "payable to order oi
+to bearer." See N.Y. U.C.C. § 3-104(1)(d)
+(McKinney 1991), We have found no case which
+applies § 3-403(2Xb) to a non-negotiable instrument. Moreover, at least one New York court
+has specifically held that if the contract being
+sued upon is a not a negotiable instrument, $ 3-
+403 cannot be applied to determine whether an
+agent executed the contract in an individual capacity. Pepsi-Cola Buffalo Bottling Corp.
+N.Y.S.2d 107. 108 (4ch Dep't 1986).
+
+
+644
+contract in a representative capacity. In one set Group and as agent for the joint venture
+sentence, the contract states that the Novemyou... agreed to accept my rescission of my
+ber 1984 contract shall consist of terms and
+acquisition ... and my tender to you of all
+conditions verbally agreed upon on Septemmy interests in the venture and you are to
+ber 10, 1984. In an adjacent sentence,
+return all amounts contributed by me to the
+contract states that the following agreement
+venture..." (emphasis added). This senwas reached on September 10, 1984:
+tence indicates that when the contract, after
+your capacity as both an officer of Interconthis sentence, uses only personal pronouns to
+timental Asset Group and as agent for the
+refer to Epstein, it is referring to Epstein in
+joint venture you verbally agreed to accept
+a representative capacity.
+my rescission of my acquisition of the joint
+venture ab initio, and my tender to you of all
+my interests in the venture and you are to
+return all amounts contributed by me to the
+venture..." (emphasis added). Read together, these two sentences clearly indicate
+that the November 1984 contract was executed by Epstein in his representative capacity.
+Stroll asserts that the above-quoted sentence demonstrates that Epstein acted in a
+representative capacity only when he agreed
+to accept Stroll's demand for rescission, and
+that Epstein personally agreed to buy out
+Stroll's interest in the venture. We find
+Stroll's interpretation of this sentence
+strained and unreasonable as there is nothing in the sentence to indicate that the
+phrase "in your capacity as ... an officer...
+and as agent..." does not apply to the
+entire sentence.
+In an attempt to establish Epstein's personal liability, Stroll points to selected phrases of the contract which use personal pronouns to refer to Epstein (eg. "I hereby
+accept your demand for rescission and tender
+upon the terms and conditions contained
+Epstein, the contract states, "in your capacity as both an officer of Intercontinental As-
+5. Under New York common law, an agent for a
+disclosed principal will not be held personally
+liable
+*'unless there is clear and explicit eví-
+dence of the agent's intention to substitute or
+shat of his principal per pal us Properties, Ore 10
+hat of his principal.
+Jenson, 146 A.D.2d 522. 536 N.Y.S.2d 1001
+008 (Ist Dep't) (quoting Mencher - Weiss, 30
+%.Y. 1, 4, 114 N.E.2d 177 (CL.App.1953))
+stated in Saleman Sign Co. . Beck, 10 N.Y.2d 63
+217 N.Y.S.2d 55, 57, 176 N.E.2d 74, 76 (Ct.App.
+1961), the rational underlying this presumption
+against personal liability was the "great danger
+[10, 11] Finally, Stroll argues that Ep-
+stein's signature on the contract reveals the
+parties" intention to hold Epstein personally
+liable because Epstein did not sign the contract as an agent or as a corporate officer.
+Epstein signed the contract as follows: /a/
+Jeffery Epstein I.AG. Under New York
+law, a signature in a representative capacity
+would have been "Jeffrey Epstein for LA.G."
+or "L.A.G., by Jeffrey Epstein". 2 N.Y.Jur,
+2d, Agency, $ 181.
+However, under New
+York common law principles of ageney, which
+govern this contract, a contract which demonstrates on its face that the defendant was
+acting solely in a representative capacity will
+not be rendered ambiguous simply because
+the defendant failed to sign the contract in a
+representative capacity. See Stylianides |
+De Lorean Motor Co, 115 Misc.2d 861, 454
+N.Y.S.2d 799, 800 (N.Y.Sup.Ct.1982); 2
+N.Y.Jur.2d 55 180, 182
+See generally ELl
+Dee Clothing Co., Inc. | Marsh, 247 N.Y.
+395, 160
+N.E. 651 (Ct.App.1928)
+('[Where one party to a written contract is
+known to the other party to be in fact acting
+as agent for some known principal, he does
+not become personally liable whether he
+signs individually or as [an] agent.").
+Ac-
+cordingly, because the body of the contract
+clearly indicates that Stroll knew, or should
+in allowing a single sentence in a long contrac
+o bind individually a person who signed] onl
+as a corporate officer." Other cases have ap
+plied this presumption even where the contract
+was only a page or two long and where the agent
+signed in
+an individual capacity. See, c.g..
+hoenthal . Benstein, 276 A.D. 200, 93 N.Y.5.2d
+187, 188-90 (1949). Accordingly, we hold that
+New York common law governs the present casc.
+where the contract was only one and a half pages
+long, and where the defendant signed in an individual capacity.
+
+
+STROLL | EPSTEIN
+645
+Cite sa 818 F.Supp. 640 (S.D.N.Y. 1993)
+have known,* Epstein was acting in a repre-
+The following will constitute our agreesentative capacity, the failure of Epstein's
+signature to meet the technical requirements
+of a representative signature is insufficient to
+render the contract ambiguous as to the par-
+Based on the above analysis, the Court
+concludes that the November 1984 contract,
+when read as a whole, is unambiguous on its
+face and indicates the parties' intention that
+Epstein was acting in a representative capacity when he agreed to return Stroll's capital
+Stroll, however, seeks to introduce extrinsic evidence to generate ambiguity in the
+contract. Specifically, Stroll seeks to introduce a prior written contract executed by
+Stroll, I.A.G., and Epstein on June 18, 1982.
+Stroll argues that an interpretation of the
+November 1984 contract as imposing personal liability on Epstein would be consistent
+with Epstein's assumption of personal liability under the June 1982 contract.
+[12] As noted above, if a contract is unambiguous on its face, extrinsic evidence may
+not be presented to create an ambiguity in
+the contract. Therefore, Stroll cannot introduce the June 1982 contract to create an
+ambiguity in the November 1984 contract.
+However, even if we
+consider the
+June 1982 contract, our conclusion that the
+November 1984 contract is unambiguous and
+does not establish personal liability remains
+unchanged. The June 1982 contract is a
+modification of Stroll and I.A.G.'s original
+joint venture agreement, with one of the
+modifications making Epstein personally responsible for managing the affairs of the
+joint venture. The contract makes no mention of any future refund of Stroll's capital
+contribution, or of a buy out in the event of a
+rescission.
+The relevant provisions of the June 1982
+contract are:
+The purpose of this letter is to ... modify
+certain provisions of the Joint Venture
+agreement which will continue to be operative.
+1. For all purposes hereof and in respect
+of the management of the affairs of the
+Joint Venture as hereinafter provided, Jeffrey E. Epstein ("Epstein") shall act on
+behalf of L.A.G. and notwithstanding the
+separate legal existence of I.A.G., as between the parties hereto, I.A.G. and Ep-
+stein shall be treated as one and the same.
+(emphasis added). The definition of "hereof"
+is "of this" (ie, of this agreement).
+THE RANDOM HOUSE DICTIONARY OF
+THE ENGLISH LANGUAGE 664 (Ist ed.
+1966). Therefore, the June 1982 contract,
+when read in the light most favorable to
+Stroll, merely makes Epstein liable for the
+purposes of the modified joint venture agree-
+A buy out was not a purpose of the
+modified joint venture agreement.
+fore, the June 1982 contract cannot be construed as imposing personal liability on Ep-
+stein in the event of I.A.G. buying out Stroll's
+interest in the joint venture.
+B. Parole Evidence
+[14,15] Where the parties have
+expressed their agreement in an unambiguous
+and integrated writing, "the parole evidence
+rule operates to exclude evidence of all prior
+and contemporaneous negotiations or agreements offered to contradiet or modify the
+terms of their writing A ler & has 15
+Wachner,
+721 F.Supp.
+(S.D.N.Y.1988). A writing is integrated if it
+"completely and accurately embodies all the
+mutual rights and obligations of the parties."
+Id at 476. New York law provides that a
+"'contract which appears complete on its face
+is an integrated agreement as a matter of
+6. The Court observes that the November 1984
+(quoting Battery S.S. Corp. - Refineria Panama, S.A., 513 F.2d 735, 738 n. 3 (2d Cir.
+1975)). The parole evidence rule serves to
+protect a party to a written contract from
+infirmity of memory, perjury, or the death of
+witnesses. Adler, 721 F.Supp. at 476.
+[16] We have examined the November
+1984 contract and find it to be a complete
+integration of the parties" agreement. See
+contract was drafted by Stroll's attorneys.
+
+
+646
+Id. at 476-478. Moreover, even the plaintiff
+does not contest that the November 1984
+contract is a complete integration.
+Stroll seeks to introduce evidence that during the September 10, 1984 meeting at the
+office of Stroll's attorney, Epstein orally
+promised to personally repay Stroll's capital
+contribution. In addition, Stroll seeks to introduce evidence that at the November 15,
+1984 meeting, Epstein took Stroll aside and
+orally reiterated his personal promise to return Stroll's capital contribution.
+However,
+the evidence Stroll seeks to present directly
+contradiets the unambiguous terms of the
+November 1984 contract. The contract
+states that, "[o]n September 10, 1984, you
+[Epstein] and I [Stroll] met in the law office
+of Henry M. Grannan....
+During the
+course of this meeting, in your capacity as
+both an officer of Intercontinental Asset
+Group and as an agent for the joint venture
+you verbally agreed to accept my rescission
+... and my tender to you of all my interests
+.. and vou are to return all amounts contributed by me...." (emphasis added).
+Moreover, the November 1984 contract
+states that the terms of the November 1984
+contract are the same as those agreed upon
+at the September 10, 1984 meeting. Therefore, because the evidence Stroll seeks to
+present contradiets the unambiguous terms
+of the integrated November 1984 contract,
+this evidence is inadmissible under the parole
+evidence rule.
+C. Subsequent Conduet
+stein made a part payment on the debt of
+$10,000, by personal check. Stroll also asserts that in September 1991, Epstein promised to pay him $75,000 from a fee Epstein
+was expecting to receive. Epstein concedes
+7. In order to establish that there is a genuine
+issuc of material fact, Stroll may introduce evidence of conduct subsequent to the November
+1984 contract either to establish that a novation
+curred, or to show that, at some time subse
+quent to the November 1984 cuntract, Epstein
+agreed to personally guarantee I.A.G.'s debt,
+novation is not enforccable absent conside:
+tion. Kasper | Roberis, 119 Misc.2d 829, 46
+N.Y.S.2d 642, 644 (N.Y.Civ:Ct.1983). Moreover,
+an oral promise to guarantee the debt of another
+is not enforccable if the party making the guarantee did not receive "new consideration which
+that he paid Stroll $10,000, but claims that he
+paid this money to Stroll because Stroll had
+purchased a horse for him. Moreover, Ep-
+stein asserts that at no time subsequent to
+the execution of the November 1984 contract
+did he ever promise to personally repay
+Stroll's capital contribution.
+(18] Where a contract is unambiguous on
+its face, evidence of conduct occurring subsequent to the execution of the contract may
+not be introduced to create ambiguity in the
+contract. See Allied Chemical Corporation
+1 Alpha Portland Industries, 58 A.D.2d 975,
+397 N.Y.S.2d 480, 482 (4th Dep't 1977).
+Therefore, even if we view the evidence in
+the light most favorable to Stroll, a partial
+payment or a promise to pay personally
+made by Epstein subsequent to the execution
+of the November 1984 contract cannot make
+Epstein personally liable under the November 1984 contract.
+Because Epstein has established that he is
+not personally liable under the November
+1984 contract, he has met his burden of
+establishing that there is no genuine issue of
+material fact.?
+Conclusion
+dant Epstein was acting solely in a representative, and not in a personal, capacity. Ac-
+cordingly, Epstein's motion for summary
+judgment is granted, and Stroll's motion for
+summary judgment is denied. The Clerk of
+the Court is directed to enter judgment in
+favor of the defendant.
+SO ORDERED.
+... is beneficial to him." Karl Elmer Forest
+Hills Corp. v: Gonzalez, 159 A.D.2d 613, 553
+N.Y.S.2d 22, 23 (2d Dep't 1990). We hold that
+had no other written notation on it. Therefore
+ven viewing the evidence in the light most fa
+November 1984 contract to personally refund the
+remainder of Stroll's capital contribution.
+
+
+
+Page 1
+Shanks _ Wexner
+E.D.Pa.,2003.
+Only the Westlaw citation is currently available.
+United States District Court,E.D. Pennsylvania.
+Nelson SHANKS, Plaintiff,
+Leslie and Abigail WEXNER, h/w, Jeffery E.
+Espstein, individually, and d/b/a J. Epstein and
+Company, Inc., and Ghislaine Maxwell, Defendants.
+No. Civ.A. 02-7671.
+March 18, 2003.
+OPINION
+NEWCOMER, J.
+I. Introduction
+*1 This case arises out of a contract dispute.NI
+The Plaintiff claims that the Defendants contracted
+Wexner and her three children. The Plaintiff alleges
+that the Defendants breached this contract by
+refusing to pay for the portrait after it was
+delivered.
+Currently before the Court is the
+Defendants' Motion to Dismiss for Lack of Personal
+Jurisdiction. For the following reasons the Motion
+will be denied.
+FN1. The Defendants deny that a contract
+was ever formed. For purposes of this
+Motion only we will accept that there was
+a contract between the two parties.
+II. Legal Standard for Personal Jurisdiction
+As a federal court sitting in diversity, our personal
+urisdiction inquiry is two-fold. First, we mus
+lecide whether the Pennsylvania Long Arm Statute
+authorizes jurisdiction over the Defendants, and
+second, we must decide whether exercising
+jurisdiction over these Defendants satisfies the Due
+Process Clause of the Constitution. Vetrotex
+Continused o. 25 4 So sti, isl ibe Gir. otar,.
+jurisdiction over the Defendants offends du
+rocess. 42 Pa. Cons.Stat. Ann. § 5322(b) (Wes
+2003).
+here are two requirements to satisty due process 1
+le personal jurisdiction context. First a party mus
+minimum
+contacts
+with Pennsylvania
+suficient to show that the party has purposely
+availed itself to the laws of this forum. IMO Indus.
+1 Kiekert AG, 155 F.3d 254 (3d Cir.1998). When
+determining whether these minimum contacts are
+present, it is the quality and not necessarily the
+quantity of contacts that is determinative. Hanson
+Denckla, 357 U.S. 235, 253 (1958). Further,
+because the Plaintiff claims that specific jurisdiction
+exists in this case, the relevant contacts are those
+that gave rise to the cause of action.EN2 If
+minimum contacts exist, the Court must decide
+whether forcing the out-of-state defendants to
+submit to jurisdiction in Pennsylvania conforms
+with traditional notions of fair play and substantial
+justice. Grand Entertainment Group, Ltd. I Star
+Media Sales, Inc., 988 F.2d 476, 481 (3d Cir.1993)
+(citing International Shoe Co. I Washington, 326
+U.S. 310, 316 (1945)). In making this determination
+Fizd (98, TOi. Ma cir ir) eriog Cahi Metal
+Industry Co. . Superior Court, 480 U.S. 102, 113
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rlti=1&prft=HTMLE&fn=_top...
+
+
+
+Page 2
+FN2. The Plaintiff makes two claims in
+this case, breach of contract and
+promissory estoppel. The Court will not
+engage in a specific jurisdiction analysis
+for each of the Plaintiff's two claims. Both
+claims center on essentially the same
+events and circumstances, and therefore,
+the
+considerations for jurisdictional
+urposes are identical. See Remick |
+Manferdy, 238 F.3d 248, 255 (2001
+are dis en k ein
+considerations).
+II. Procedure for Determining Minimum Contacts
+When a Defendant moves for dismissal under
+12(b)(2) for lack of personal jurisdiction the burden
+shifts to the party seeking to impose jurisdiction.
+Ass'n, 819 F.2d 434 (3d Cir.1987). In response to a
+12(b)(2) motion, a party must make a prima facie
+showing that minimum contacts warranting personal
+jurisdiction
+exist. 'N3 Mellon Bank (East) PSFS
+Nat. Ass'n |. Farino, 960 F.2d 1217, 1223 (3d
+Cir. 1992).
+FN3. The Court notes that although a
+Plaintiff need only make a prima facie
+showing of jurisdiction to defeat a motion
+under Fed.R.Civ.P. 12(b)(2), a Plaintitt
+has to establish personal jurisdiction by a
+preponderance of the evidence at trial.
+Carteret Saving Bank |. Shushan, 954
+F.2d 141, 146 (3d
+Cir.1992).
+The
+Defendants need not do anything to
+preserve their right to raise personal
+jurisdiction again at trial.
+*2 The law in the Third Circuit, however, is not
+clear as to what a Court should consider in deciding
+whether the Plaintiff has met this burden. Two lines
+of cases differ as to whether afirmative proof of
+minimum contacts is required, or if the Plaintiff can
+merely rely on contacts alleged in his pleadings.
+Several cases have stated that a plaintiff cannot rely
+on the bare pleadings alone, but must sustain his
+burden of proof by establishing with reasonable
+particularity sufficient contacts through sworn
+affidavits or other competent evidence. Time Shar
+Vacation Club Atlantic Resorts, Ltd., 735 F.2
+51, 66 and n. 9 (3d Cisi9s4), Nonal Painl
+Supply,
+Cossio,
+F.Supp.
+(E.D.Pa.1998); Rose | Granite City Police Dept.,
+813 F.Supp. 319, 321 (E.D.Pa.1993). Following
+these cases, a court would not accept the allegations
+of jurisdictional facts in a complaint as true without
+some afirmative proof. See Time Share Vacation
+Club, 735 F.2d 61, 66 at nt. 9. ("Once [a Rule
+12(b)(2) motion] is made, plaintiff must respond
+with actual proofs,
+not mere allegations.")
+However, several other cases have held the
+contrary, finding that a court should accept the
+allegations in a complaint as true. Carteret Saving
+Bank | Shushan, 954 F.2d 141, 142 at nt. 1(3d
+Cir. 1992); Oxford First Corp. | PNC Liquidating
+Corp., 372 F.Supp. 191, 192-93 & n. 2(E.D .Pa.
+174); See, also, Behagen | Amateur Basketball
+Ass'n of U.S.A., 744 F.2d 731, 733 (10th Cir.1984).
+FN4
+FN4. Despite the apparent contradictory
+nature of these precedents, several cases
+have claimed that a District Court should
+both require proof of jurisdictional facts,
+and accept all factual allegations in the
+complaint
+as true.
+See Feinberg
+Centeral Asia Capitial Corp., 936 F.Supp.
+250, 254 (E.D.Pa.1996) (stating that
+Plaintiff must go beyond the pleadings and
+make an affirmative proof" and later citing
+Carteret for the proposition that the Court
+allegations in the Complaint are taken as
+true, a plaintiff may not solely rely on bare
+pleadings to satisfy his jurisdictional
+burden"). This Court will decline to follow
+this approach because of its contradictory
+nature and the lack of guidance it will give
+to future litigants.
+These precedents give little guidance in a case, such
+as this one, where the exhibits submitted by the
+Plaintiff may not be suficient to support
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rlti=1&prft-HTMLE&fn=_top.. 5/22/2007
+
+
+
+Page 3
+jurisdiction on their own, but if considered in
+conjunction with assertions made in the Complaint
+would satisfy the minimum contacts requirement. If
+the Court were to follow the Time Share approach
+of requiring competent evidence of all jurisdictional
+facts,
+Court would have to dismiss the
+Plaintiff's case. If the Court followed the procedure
+of Carteret of accepting factual allegations in the
+Complaint, than jurisdiction has been established.
+Because the Defendants
+did
+not
+attempt to
+controvert any of the allegations in the Plaintiff's
+Complaint, this Court finds that the most fair
+procedure is to accept them as true for the purpose
+of this Motion. This approach is followed in several
+other circuits. Brown' |. Flowers Industries, Inc.,
+688 F.2d 328, 332 (Sth Cir.1982); Turnock | Cope
+816 F.2d 332, 333 (7th
+Cir.1987); Dowless |
+Warren-Rupp Houdailles, Inc.,
+800_ F.2d 1305,
+1307
+(4th
+Cir. 1986);
+Behagen .
+Amateur
+Basketball Ass'n of U.S.4., 744 F.2d 731, 733 (10th
+Cir. 1984); Jet Charter Service, Inc. | Koeck, 907
+F.2d 1110,
+1111 (11th Cir.1990). While
+this
+procedure places a burden on the party challenging
+jurisdiction to at least question the allegations of
+jurisdictional facts, this burden is consistent with
+the other
+requirements placed on Defendants
+bringing a 12(b)(2) motion. When a complaint is
+filed there is no afirmative duty to plead personal
+jurisdiction because it is assumed that personal
+jurisdiction
+Homex Corp. |
+Homasote Co., 437 F.2d 87, 88 (2d Cir.1971). It is
+incumbent on a party to raise the lack of personal
+jurisdiction. See Zelson |. Thomforde, 412 F.2d 56
+(3d Cir.1969) (district court cannot raise personal
+jurisdiction sua sponte ). Further, if a party wishes
+to challenge personal jurisdiction of a Court he
+must do so at the responsive pleading stage or he
+will have waived his objection. Fed. R. Civ. P.
+12(h)(1) (personal jurisdiction is waived if not
+raised). It logically follows that a party must
+respond to the allegations upon which the power of
+a court is premised and that any failure to do so will
+result in the party admitting those facts for the
+purpose of the 12(b)(2) Motion. This procedure
+also strikes a balance between the two contradictory
+lines of cases cited above. It still requires the
+Plaintiff to do more than simply rely on bare
+pleadings, albeit only when those pleadings are
+III. Jurisdictional Facts
+*3 Considering the above analysis the Court will
+accept the facts as pleaded in the Plaintiff's
+Complaint and accompanying exhibits. NS These
+allegations show that the
+Defendant has the
+following relevant contacts with Pennsylvania: 1) a
+fax sent from the Defendants to the Plaintiff seeking
+to set up a meeting between Mrs. Wexner and the
+Plaintiff in New York City; 2) a fax sent from the
+Defendants to the Plaintiff detailing his itinerary for
+his trip to Ohio to meet with and photograph the
+subjects of the portrait; 3) a letter from the Plaintiff
+to Ms. Wexner thanking her for her hospitality
+during his stay in Ohio; 4) a fax from the
+Defendants
+measurements of Ms. Wexner and her children,
+which were to be used to make mannequins in
+preparation for the portrait; 5) a letter from
+Defendant Maxwell to the Plaintiff contirming the
+price of the portrait; 6) a letter to Defendant
+Maxwell from the Plaintiff regarding a proposed
+frame for the painting; 7) a courier hired by the
+Defendants who traveled to Pennsylvania
+and
+picked up the painting; and, 8) an invoice sent from
+the Plaintiff to the Wexners. The Defendants also
+admit that the Defendants initiated the relationship
+by contacting the Plaintiff in Pennsylvania.
+FN5. Some of the contacts asserted in the
+Plaintiff's brief were not made by the
+Defendants personally but by other parties
+The Plaintiff has alleged in his complaint
+that these parties were acting as the agents
+of the Defendants. Accordingly, these
+contacts will be imputed to the Defendants.
+Wells Fargo & Co. I. Wells Fargo Express
+Co., 556 F.2d 406, 419 (9th Cir.1977).
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rlti=1&prft=HTMLE&fn=_top...
+
+
+
+Page 4
+IV. Analysis of minimum contacts
+Based on the above facts it is clear that the
+Defendants did have sufficient minimum contacts to
+justify personal jurisdiction. The Defendants
+reached out to a Pennsylvania resident to have him
+paint the portrait. Jurisdiction is proper when
+parties "reach out beyond one state and create
+continuing relationships and obligations with the
+citizens of another state." Burger King Corp. |
+Rudzewicz, 471 U.S. 462, 256 (1985). In cases
+where a out-of-state resident contracts with a forum
+resident, whether the out-of-state resident initiated
+the relationship is crucial. See Vetrotex Certainteed
+Corp. . Consolidated Fiber, 75 F.3d 147 (3d
+Cir. 1996).
+Simply initiating a contractual relationship with a
+Pennsylvania resident,
+however, is not
+contact in this case which goes towards establishing
+personal jurisdiction. Indeed, the Defendants also
+engaged
+in crucial
+communications
+performance of the contract directed at the state of
+Pennsylvania. See Grand Entm't Group, Led. |. Star
+Media Sales, Inc., 988 F.2d 476, 482 (3d Cir.1993)
+telephone contacts
+may
+support
+jurisdiction). These contacts cannot be dismissed as
+mere informational contacts, rather some of them go
+to the heart of the transaction. Specifically, the May
+16, 2000, letter from the Defendants finalized the
+price of the portrait. These contacts evidence a
+conscious decision by the Defendants to do business
+with
+a Pennsylvania
+resident
+operating in the
+Commonwealth of Pennsylvania.
+Perhaps the most meaningful contact occurred when
+the portrait was delivered to the Defendants' agent
+crucial to the breach of contract claim because
+delivery of the portrait was necessarily an implied
+condition of the contract. Not only is it significant
+to the contract, but by sending a courier to drive on
+Pennsylvania roads, make a pick up at a
+Pennsylvania business, and then return to Ohio, the
+Defendants purposely availed themselves to the
+benefits of doing business in the Commonwealth.
+While merely passing through a state is not a
+sufficient contact to warrant jurisdiction, when a
+party makes a business delivery in the state
+purposeful
+availment has been
+established.
+Papachristou |. Turbines, Inc., 902 F.2d 685, 685
+(8th Cir.1990); see Carney | Bill Head Trucking,
+Inc-s
+83 F.Supp.2d 554, 557 (E.D.Pa.2000)
+(drawing a distinction between merely passing
+through a state and stopping and making a delivery).
+*4 The Defendants argue that they are not amenable
+to personal jurisdiction in Pennsylvania because
+they never physically entered the state. They
+attempt to support this argument with the fact that
+the only two face-to-face meetings between the
+parties occurred in New York and Ohio. As noted
+above, however, for jurisdictional purposes the
+courier pickup
+of the painting was a physical
+contact with the state because the courier was an
+agent of the Defendants. See note 5 supra.
+Moreover, the lack of any physical contacts with the
+state would not bar this Court from exercising
+personal jurisdiction over the Defendants. Burger
+King Corp. | Rudzewicz, 471 U.S. 462, 476 (1983)
+. The Court is also not troubled by the Defendants'
+assertions that the majority of negotiations for the
+contract occurred in New York. Nothing
+in due
+process restricts more than one state from having
+personal jurisdiction over a party to a given
+transaction. The contacts the Defendants may have
+had with New York are not relevant to whether
+there are sufficient contacts with Pennsylvania. As
+discussed above, the initiation of the relationship
+with the Pennsylvania Plaintiff, the entangling
+contacts with Pennsylvania during the painting of
+the portrait, and the final delivery of the portrait to
+the Defendants at the Pennsylvania Plaintiff's
+business, satisfy the minimum contacts requirement
+regardless of the fact that significant negotiations
+may have taken place in New York.
+L. Traditional Notions of Fair Play and Substantial
+Justice
+Because the Court concludes that the Defendants
+sufficient minimum contacts to warrant
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rlti=1&prft=HTMLE&fn=_top...
+
+
+
+on the Defendants to convince the Court that these
+principles will be offended by this Court's exercise
+of jurisdiction. Mesalic i Fiberfioat Corp.,
+897
+F.2d 696. 701 (3d Cir.1990). We conclude that the
+Defendants cannot meet this burden. The interests
+of both the Commonwealth of Pennsylvania and the
+Plaintiff are substantially forwarded by hearing the
+case in this Court. The Plaintiff, a Pennsylvania
+resident, should be able to seek a remedy in his
+home state. It is certainly no more unfair for the
+Plaintiff
+to
+bring
+the
+Defendants
+into
+a
+Pennsylvania court, than it would be to force the
+Plaintiff to travel to Ohio in search of a remedy.
+Moreover, Pennsylvania has an interest in assuring
+that its residents have a convenient forum to remedy
+breaches of contracts, particularly when it appears
+that the vast majority of the contract was performed
+within the Commonwealth. Accordingly, the Court
+sees no reason why exercising jurisdiction over the
+Defendants would violate traditional notions of fair
+play and substantial justice.
+VI. Conclusion
+For the foregoing reasons, the Defendants Motion
+to Dismiss for Lack of Personal Jurisdiction is
+denied. An appropriate order will follow.
+E.D.Pa.2003.
+Shanks | Wexner
+Not Reported in F.Supp.2d, 2003 WL 1343018
+(E.D.Pa.)
+END OF DOCUMENT
+Page 5
+https://web2.westlaw.com/print/printstream.aspx?sv=Full&rlti=1&prft=HTMLE&fn=_top... 5/22/2007
+
+
+
+Department of Licensing and Consumer Affai
+DL.CA Home
+Business License
+Taxi Operators License
+Board Certifications
+Consumer Allairs
+Commissioner Reberisen
+Ahout the DLCA
+Business Search
+Business License Search
+Business Name Search Category A-Z New Business Listings
+About
+Imagers Preflith Listings
+Records per page: |10
+Enter Business Name (use fewer letters for more results)
+Found 34 Records
+Prev 1234 Next
+Records 21 to 30
+Search
+financial
+-Collection Agency--
+PROGRESSIVE FINANCIAL SERVICES, INC.
+866-484-0204
+St. Thomas, USVI 00803, St. Thomas
+License #: 0-1002135-2006
+--Consultant - Tax--
+WINSLOW & WINSLOW FINANCIAL SERVICES, INC.
+940-713-9713
+FREDERIKSTED, St. Croix
+License #: 2-2025606-2006
+-Development & Sale of Own Property--
+CARIBBANK FINANCIAL GROUP
+St. Croix
+License #: 2-2006639-2005
+-Fiduciary Service-
+ANTILLES FINANCIAL GROUP, LLLP
+St. Croix
+License #: 2-2022028-2006
+FINANCIAL TRUST COMPANY, INC.
+340-775-2525
+Golden Roc
+Chr
+St. Cro
+Phone: (
+Fax: (34
+Administer
+Fax: (CE
+a st
+Prop. &e Pr
+i Sub l
+St Thon
+http://www.dlca.gov.vi/bussearch.asp?a=name&name=financial&norecs=10&dir=3&islan... 5/14/2007
+
+
+
+St. Thomas
+License #: 1-2021802-2006
+--Gasoline Station--
+GREEN CAY MARINA
+St. Croix
+License #: 2-2024637-2006
+--Holding Company-
+PARTICLE FINANCIAL, LLLP
+St. Thomas
+License #: 1-1003805-2006
+--Hotel & Guest House B 40-99 beds--
+TAMARIND REEF HOTEL
+C'STED, St. Croix
+License #: 2-2024547-2006
+--Marinas--
+GREEN CAY MARINA
+St. Croix
+License #: 2-2024637-2006
+--Rental of Commercial Space--
+GREEN CAY MARINA
+St. Croix
+License #: 2-2024637-2006
+Found 34 Records
+Prev 1234 Next
+Records 21 to 30
+Official Website of the USVI Department of Licensing and Consumer Affairs
+Sie Last Updatey May i7, 2003
+http://www.dlca.gov.vi/bussearch.asp?a=name&name=financial&norecs=10&dir=3&islan..
+
+
+
+U.S. District Court
+United States District Court for the Southern District of New York (Foley Square)
+CIVIL DOCKET FOR CASE #: 1:02-cv-05332-SHS
+Citibank, N.A. 1 Epstein, et al
+Armand to. Judge Sidney H. Stein
+Cause: 28:1391 Personal Injury
+Plaintiff
+Citibank, N.A.
+Date Filed: 07/11/2002
+Date Terminated: 07/26/2005
+Jury Demand: None
+Nature of Suit: 190 Contract: Other
+Jurisdiction: Diversity
+represented by Marshall H. Fishman
+Kramer, Levin, Naftalis & Frankel,
+L.L.P.
+919 Third Avenue
+New York, NY 10022
+Defendant
+Jeffrey E. Epstein
+Defendant
+Financial Trust Company, Inc.
+Date Filed
+07/11/2002
+#
+07/11/2002
+07/11/2002
+represented by Gerald B. Lefcourt
+Law Office Gerald B. Lefcourt
+148 East 78th Street
+New York, NY 10021
+Email: letcourt@lefcourtlaw.com
+represented by Gerald B. Lefcourt
+(See above for address)
+Docket Text
+1
+COMPLAINT filed. Summons issued and Notice pursuant to 28 U.S.C.
+636(c). FILING FEE S 150.00 RECEIPT # 444722. (jol) (Entered:
+07/16/2002)
+Magistrate Judge Theodore H. Katz is so designated. (jol) (Entered:
+07/16/2002)
+2| RULE 1.9 CERTIFICATE filed by Citibank, N.A.. (jol) (Entered:
+07/16/2002)
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.pl?273504181304452-L_353_0-1
+
+
+
+| 07/17/2002
+07/17/2002
+07/17/2002
+08/02/2002
+08/16/2002
+09/03/2002
+09/20/2002
+3| AFFIDAVIT OF SERVICE of summons, complaint & rule 1.9 statement
+as to Jeffrey E. Epstein by first class mail on 7/15/02 . Answer due on
+8/5/02 for Jeffrey E. Epstein . (db) (Entered: 07/19/2002)
+3 AFFIDAVIT OF SERVICE of summons, complaint & rule 1.9 statement
+as to Financial Trust by Helen Kim on 7/15/02 . Answer due on 8/5/02
+for Financial Trust . (db) (Entered: 07/19/2002)
+3
+AFFIDAVIT OF SERVICE of summons, complaint & rule 1.9 as to
+Jeffrey E. Epstein by Helen Kim on 7/15/02 . Answer due on 8/5/02 tor
+Jeffrey E. Epstein . (db) (Entered: 07/19/2002)
+4
+ORDER, Counsel are directed to appear in courtroom 23A on 9/13/02, at
+10:30 a.m. for an initial case management conference purs. to FRCP 16 .
+(signed by Judge Sidney H. Stein ); Copies mailed. (SD) (Entered:
+• STIPULATION and ORDER, that defendants' time to answer, move o
+therwise respond to the complaint in the above-captioned action i
+hereby extended to and including 9/3/02 . ( signed by Judge Sidney H
+Stein ) (dle) (Entered: 08/19/2002)
+7 NOTICE OF MOTION (Filed on Service Date) by Jeffrey E. Epstein,
+dismisin The Coral ind or, in he Riterative, for an order, the ,
+proceedings should be stayed pending the adjudication of the first-filed
+action ; Return Date 9/26/02. (rec'd in the night deposit box on 10/9/02 at
+16 NOTICE OF MOTION (FILED ON SERVICE DATE) by Citibank,
+the statement pursuant to Local Civil Rule 56.1. (kw) Modified on
+09/30/2002
+8 MEMORANDUM OF LAW by Jeffrey E. Epstein, Financial Trust in
+upport of [7-1] motion for an order, purs. to Rules 1, 12 and 13(a) of th
+RCP, dismissing the Complaint, [7-2] motion for an order, th
+proceedings should be stayed pending the adjudication of the first-filed
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.p|?273504181304452-L_353_0-1
+
+
+
+action. (rec'd in the night deposit box on 10/9/02 at 5:07 p.m.) (sac)
+(Entered: 10/16/2002)
+9 RULE 1.9 CERTIFICATE filed by Jeffrey E. Epstein, Financial Trust.
+(rec'd in the night deposit box on 10/9/02 at 5:06 p.m.) (sac) (Entered:
+10/16/2002)
+10 DECLARATION of Edward S. Feig by Jeffrey E. Epstein, Financial
+Trust in support Re: [7-1] motion for an order, purs. to Rules 1, 12 and 13
+(a) of the FRCP, dismissing the Complaint, [7-2] motion for an order, the
+proceedings should be stayed pending the adjudication of the first-filed
+action. (rec'd in the night deposit box on 10/9/02 at 5:07 p.m.) (sac)
+11 MEMORANDUM OF LAW by Citibank, N.A. in opposition to [7-1]
+notion for an order, purs. to Rules 1, 12 and 13(a) of the FRCI
+dismissing the Complaint, [7-2] motion for an order, the proceedings
+should be stayed pending the adjudication of the first-filed action. (sac
+(Entered: 10/16/2002)
+12 AFFIDAVIT of Marshall H. Fishman by Citibank, N.A. in opposition to
+rismisinion e amplit, 1-2 motion for an order, the proceedings
+the proceeding
+should be stayed pending the adjudication of the first-filed action. (sac)
+13| AFFIDAVIT of Dayle Davison by Citibank, N.A. in opposition to [/-]
+10/22/2002
+10/22/2002
+14 REPLY MEMORANDUM by Jeffrey E. Epstein, Financial Trust in
+support re: [7-1] motion for an order, purs. to Rules 1, 12 and 13(a) of the
+FRCP, dismissing the Complaint, [7-2] motion for an order, the
+proceedings should be stayed pending the adjudication of the first-filed
+action. (rec'd in the night deposit box on 10/9/02 at 5:07 p.m.) (sac)
+15 REPLY DECLARATION of Edward S. Feig by Jeffrey E. Epstein,
+Financial Trust in support re: [7-1] motion for an order, purs. to Rules 1,
+12 and 13(a) of the FRCP, dismissing the Complaint, [7-2] motion for an
+order, the proceedings should be stayed pending the adjudication of the
+first-filed action (rec'd in the night deposit box on 10/9/02 at 5:07 p.m.)
+(sac) (Entered: 10/16/2002)
+17| MEMORANDUM OF LAW by Citibank, N.A. in support of [16-1]
+motion for summary judgment pursuant to Rule 56 of the FRCP on each
+of the first and second claims for relief asserted in the complaint in this
+action. (kw) (Entered: 10/28/2002)
+18| MEMORANDUM OF LAW by Jeffrey E. Epstein, Financial Trust in
+opposition to [16-1] motion for summary judgment pursuant to Rule 56
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.p|?273504181304452-L_353_0-1
+
+
+
+10/22/2002
+10/22/2002
+10/24/2002
+09/17/2003
+09/17/2003
+of the FRCP on each of the first and second claims for relief asserted in
+the complaint in this action. (Rec. in the night deposit box). (kw)
+(Entered: 10/28/2002)
+19
+RULE 56.1 STATEMENT filed by Jeffrey E. Epstein, Financial Trust.
+(Rec. in the night deposit box). (kw) (Entered: 10/28/2002)
+20| REPLY MEMORANDUM by Citibank, N.A. re: [16-1] motion for
+summary judgment pursuant to Rule 56 of the FRCP on each of the first
+and second claims for relief asserted in the complaint in this action. (kw)
+(Entered: 10/28/2002)
+21 SUPPLEMENTAL DECLARATION of EDWARD S. FEIG by Jeffrey
+. Epstein, Financial Trust Re: . in response to the latest mudslingin
+actic by Citibank. (vb) (Entered: 10/29/2002
+22 NOTICE of attorney appearance for Jeffrey E. Epstein, Financial Trust
+by Gerald B. Lefcourt. (cd) (Entered: 09/19/2003)
+23| STIPULATION and ORDER; that the counsel representing defendants in
+this matter Gerald B. Lefcourt, P.C., in the place of Arent Fox Kinter
+Plotkin & Kahn, PLLC . ( signed by Judge Sidney H. Stein ) (pl)
+(Entered: 09/22/2003)
+09/17/2003
+12/18/2003
+07/26/2005
+25 TRANSCRIPT of proceedings held on 9/17/03 before Judge Sidney H.
+Stein.(ml, ) Modified on 1/6/2004 (kkc, ). (Entered: 12/18/2003)
+26 STIPULATION AND ORDER OF DISMISSAL, IT IS HEREBY
+PACER Service Center
+Transaction Receipt
+05/22/2007 18:17:02
+PACER Login: du4480
+Client Code:
+Description:
+_ Docket Report Search Criteria:) 1:02-cv-05332-SHS
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.pl?273504181304452-L_353_0-1
+
+
+
+Billable Pages: 3
+Cost:
+110.24
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.pl?273504181304452-L_353_0-1
+
+
+
+U.S. District Court
+United States District Court for the Southern District of New York (Foley Square)
+CIVIL DOCKET FOR CASE #: 1:96-cv-08307-DC
+USA 1 Epstein, et al
+Demand to: Judge Denny Chin
+Cause: 28:1345 USA Plaintiff
+Plaintiff
+United States of America
+Date Filed: 11/04/1996
+Date Terminated: 03/17/1999
+Jury Demand: Defendant
+Nature of Suit: 230 Rent Lease &
+Jurisdiction: U.S. Government Plaintiff
+represented by M. Chinta Gaston
+MARY JO WHITE
+U.S. Attorney for SDNY
+100 Church Street
+19th Floor
+New York, NY 10007
+Defendant
+Jeffrey E. Epstein
+Defendant
+Ivan Fisher
+represented by Steven J Cohen
+Wachtel & Masyr, LLF
+110 East 59th Street
+New York, NY 10022
+represented by Eileen J. Casey
+Gage Buschmann & Pavlis
+120 West 45th Street
+New York, NY 10036
+G. Robert Gage, Jr.
+Gage Buschmann & Pavlis
+120 West 45th Street
+New York, NY 10036
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.p|?321462322339233-L_353_0-1
+
+
+
+Counter Claimant
+Ivan Fisher
+represented by G. Robert Gage, Jr.
+(See above for address)
+Counter Defendant
+United States of America
+Cross Claimant
+Ivan Fisher
+represented by M. Chinta Gaston
+(See above for address)
+represented by G. Robert Gage, Jr.
+(See above for address)
+Cross Defendant
+Jeffrey E. Epstein
+represented by Steven J Cohen
+(See above for address)
+Defendant
+Ellyn Bank
+Defendant
+Debra Elisa Cohen
+represented by Ellen Yaroshefsky
+Clayman & Rosenberg
+305 Madison Avenue, Ste. 1301
+New York, NY 10165
+Fax:
+Email: ellen@clayro.com
+Defendant
+Diane Fisher
+doing business as
+The Fisher Group
+Defendant
+Fisher & Soffer
+also known as
+Fisher & Sophir
+Defendant
+represented by Eileen J. Casey
+(See above for address)
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.p1?321462322339233-L_353_0-1
+
+
+
+D. Gerzog
+Defendant
+Robert Heilbrun
+represented by Robert Heilbrun
+Siegel & Heilbrun
+575 Madison Avenue
+New York, NY 10022
+Defendant
+Suzanne McDermott
+Defendant
+Christopher H. Martin
+Defendant
+Jessie Siegel
+also known as
+Jesse Siegel
+Defendant
+Siegel, Martin & Heilbrun
+represented by Robert Heilbrun
+(See above for address)
+represented by Robert Heilbrun
+(See above for address)
+represented by Robert Heilbrun
+(See above for address)
+Defendant
+Ron Soffer
+Defendant
+Carmen Tausik
+TERMINATED: 08/06/1998
+Defendant
+John Does 1 through 10
+Defendant
+X Corporations 1 throught 10
+Cross Claimant
+Jeffrey E. Epstein
+represented by Steven J Cohen
+(See above for address)
+Cross Defendant
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.p|?321462322339233-L_353_0-1
+
+
+
+Ivan Fisher
+represented by G. Robert Gage, Jr.
+(See above for address)
+Date Filed
+11/04/1996
+11/04/1996
+01/24/1997
+#
+01/31/1997
+02/11/1997
+02/11/1997
+02/11/1997
+02/24/1997
+02/26/1997
+03/07/1997
+03/07/1997
+03/10/1997
+04/03/1997
+Docket Text
+1| COMPLAINT filed; Summons issued and Notice pursuant to 28 U.S.C.
+636(c); FILING FEE $ WAIVED (USA). (riem) (Entered: 11/06/1996)
+Magistrate Judge Ellis is so Designated. (ricm) (Entered: 11/06/1996)
+2| STIPULATION and ORDER, by and between parties reset answer due
+for 2/3/97 for Ivan Fisher... So Ordered.... ( signed by Judge Denny
+Chin). (pI) (Entered: 01/27/1997)
+3 WAIVER OF SERVICE Returned Executed as to Ivan Fisher mailed on
+12/3/96 Answer due on 2/3/97 for Ivan Fisher (Is) (Entered: 02/05/1997)
+4 | Affidavit of service as to Jeffrey E. Epstein by Walter Doulin, co-worker
+on 1/31/97 Answer due on 2/20/97 for Jeffrey E. Epstein (Is) (Entered:
+02/13/1997)
+4 | Affidavit of service as to Jeffrey E. Epstein by mail on 2/1/97 Answer
+due on 2/21/97 for Jeffrey E. Epstein (Is) (Entered: 02/13/1997)
+5| AMENDED COMPLAINT by USA, (Answer due 2/24/97 for Ivan
+Fisher, for Jeffrey E. Epstein ) amending [1-1] complaint; Summons
+issued. (Is) (Entered: 02/13/1997)
+6 Affidavit of service of Amended Complt. and Amended Summons as to
+Ivan Fisher by Federal Express on 2/11/97 Answer due on 3/3/97 for Ivan
+Fisher (Is) (Entered: 02/24/1997)
+7| Affidavit of service of the amended s/c as to Jeffrey E. Epstein by
+Federal Express to Steven Cohen, Esq. on 2/13/97. Answer due on 3/5/97
+for Jeffrey E. Epstein. (lam) Modified on 02/26/1997 (Entered:
+02/26/1997)
+8 STIPULATION, extending time for deft Ivan Fisher to answer the
+Amended Complaint is extended from 2/28/97 to 4/7/97, reset answer
+due for 4/7/97 for Ivan Fisher ( signed by Judge Denny Chin). (Kg)
+(Entered: 03/07/1997)
+9
+STIPULATION and ORDER, Extending defendant's time to answer,
+move or otherwise respond to the Amended Complaint, Reset answer
+due for 3/26/97 for Jeffrey E. Epstein. SO ORDERED: ( signed by Judge
+Denny Chin). (ae) (Entered: 03/11/1997)
+10| Affidavit of service as to Jeffrey E. Epstein by Michelle Heapy on
+2/27/97 and by mail on 2/28/97. (kw) (Entered: 03/11/1997)
+11| STIPULATION and ORDER, extending time for deft Jeffrey E. Epstein
+to answer to the Amended Complaint is extended to 4/7/97 , reset answer
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.pl?321462322339233-L_353_0-1
+
+
+
+04/08/1997
+04/08/1997
+04/09/1997
+04/09/1997
+05/01/1997
+05/14/1997
+06/28/1997
+07/14/1997
+07/14/1997
+07/14/1997
+07/14/1997
+07/14/1997
+07/14/1997
+07/28/1997
+07/28/1997
+07/28/1997
+due for 4/7/97 for Jeffrey E. Epstein (signed by Judge Denny Chin).
+(kg) (Entered: 04/03/1997)
+12 ANSWER to Complaint by Jeffrey E. Epstein (Attorney Steven J. Cohen)
+(pI) (Entered: 04/09/1997)
+13 | ANSWER by Ivan Fisher (Attorney G. Robert Gage Jr.) to amended
+omplaint; jury demand ; Firm of: Gage Buschmann & Pavlis by attorne!
+7. Robert Gage Jr. for defendant Ivan Fisher (Is) (Entered: 04/09/1997
+13 COUNTERCLAIM by Ivan Fisher against USA (Is) (Entered:
+04/09/1997) |
+CROSSCLAIM by Ivan Fisher against Jeffrey E. Epstein (Is) (Entered:
+04/09/1997)
+14| STIPULATION and ORDER, extending time for deft Jeffrey E. Epstein
+to respond to deft Ivan S. Fisher's cross-claim , Response to crossclaim
+deadline set for 5/13/97 ( signed by Judge Chin). (kg) (Entered:
+05/01/1997)
+15 | ANSWER by Jeffrey E. Epstein to [13-1] cross claim of defendant Ivan
+S. Fisher. (ae) (Entered: 05/15/1997)
+24 | REPLY MEMORANDUM of LAW by USA re: in Support of its Motion
+for Partial Summary Judgment and for other Relief (djc) (Entered:
+07/31/1997)
+16 Ru 651(4) statement filed by Jeffrey E. Epstein (pl) (Entered:
+17 MEMORANDUM by Jeffrey E. Epstein in opposition to the
+Governments' motion for partial summary judgment (pl) (Entered:
+07/16/1997)
+18| AFFIDAVIT in opposition of Jeffrey A. Schantz Re: Plaintiffs' motion
+for partial summary judgment (pl) (Entered: 07/16/1997)
+19 MEMORANDUM by Ivan Fisher in opposition to Governments' motion
+for Partial Summary Judgement (pI) (Entered: 07/16/1997)
+20 | Rule 56.1(b) statement filed by Ivan Fisher (pl) (Entered: 07/16/1997)
+AFFIDAVIT in opposition of Ivan S. Fisher (pl) (Entered: 07/16/1997)
+22 MEMORANDUM of LAW by USA in support of its Motion for Partial
+Summary Judgment and other Relief (djc) (Entered: 07/31/1997)
+23 | SUPPLEMENTAL DECLARATION of Serene K. Nakano (djc)
+(Entered: 07/31/1997)
+25 NOTICE OF MOTION by USA for summary judgment, purs to Rule 56
+(b) of the FRCP dismissing the counterclaims of defendant Ivan S. Fisher
+against the Government for declaratory relief and purs to Rule 65 of the
+FRCP directing defendants Jeffrey E. Epstein and Fisher to pay into a
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.pl?321462322339233-L_353_0-1
+
+
+
+10/10/1997
+11/12/1997
+12/23/1997
+01/05/1998
+01/13/1998
+01/20/1998
+01/20/1998
+01/20/1998
+01/20/1998
+Court fund within thirty days of decision on this motion monies for the
+use and benefits of the premises known as 34 East 69th Street, NY, in the
+ahis unt of is 5,001,0 perminedh Return dates 12199 mite 5 date tha
+1, Return date 7/28/97; w. Rule 5 6..
+Statement and Declarations (djc) Modified on 07/31/1997 (Entered:
+07/31/1997)
+26
+ORDER, reset discovery due for 12/5/97; reset pretrial conference for
+10:00 12/5/97 ( signed by Judge Denny Chin); Copies mailed (ed)
+(Entered: 10/14/1997)
+27 | Filed Memo-Endorsement on letter to Judge Chin from Steven J. Cohen
+dated 11/10/97; the objection to production of the entire lease is
+overruled; Mr. Epstein shall produce the entire lease; if he wants,
+production of the lease can be subject to a reasonable confidentiality
+stipulation and order; ( signed by Judge Denny Chin) (Is) (Entered:
+11/12/1997)
+28| SECOND AMENDED COMPLAINT by USA (Answer due 1/5/98 for
+Ivan Fisher, for Jeffrey E. Epstein) amending [5-1] amended complaint
+against Ellyn Bank, Debra Elisa Cohen, Diane Fisher, Fisher & Soffer,
+D. Gerzog, Robert Heilbrun, Suzanne McDermott, Christopher
+H. Martin, Jessie Siegel, Siegel, Martin, Ron Soffer, Carmen Talsig, John
+Does 1 - 10, X Corporations 1-10; Summons issued. (sac) (Entered:
+12/30/1997)
+29 | Filed Memo-Endorsement on letter dated 12/30/97 from Ellen J. Casey,
+granting parties request for additional time, until 1/7/98 to submit the
+additional legal authorities and discovery materials ( signed by Judge
+Denny Chin) (kw) Modified on 01/07/1998 (Entered: 01/06/1998)
+30| STIPULATION and ORDER, reset answer to Second Amended
+Complaint due for 2/2/98 for Jeffrey E. Epstein ( signed by Judge Denny
+Chin). (emil) (Entered: 01/14/1998)
+31 | Affidavit of service of Second Amended Complaint as to Ellyn Bank by
+personal service on 1/10/98; Answer to Second Amended Complaint due
+on 1/30/98 for Ellyn Bank (ae) (Entered: 01/22/1998)
+31
+Affidavit of service of Second Amended Complaint as to Debra Elisa
+Cohen by Mr. Searson, Doorman on 1/2/98; Answer to Second Amended
+Complaint due on 1/22/98 for Debra Elisa Cohen (ae) (Entered:
+31| Affidavit of service of Second Amended Complaint as to
+D.
+Gerzog by Pat Bowles, Secretary, authorized to accept service on 1/5/98;
+Answer to Second Amended Complaint due on 1/26/98 for
+Gerzog (ae) (Entered: 01/22/1998)
+31 | Affidavit of service of Second Amended Complaint as to Robert
+Heilbrun by Pat Bowles, Secretary, authorized to accept service on
+1/5/98; Answer to Second Amended Complaint due on 1/26/98 for
+Robert Heilbrun (ae) (Entered: 01/22/1998)
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.p1?321462322339233-L_353_0-1
+
+
+
+| 01/20/1998
+01/20/1998
+01/20/1998
+01/20/1998
+31 | Affidavit of service of Second Amended Complaint as to Suzanne
+McDermott by personal service on 1/10/98; Answer to Second Amended
+Complaint due on 1/30/98 for Suzanne McDermott (ae) (Entered:
+01/22/1998)
+31 Affidavit of service as to Jessie Siegel by Pat Bowles, Secretary,
+authorized to accept service on 1/5/98; Answer to Second Amended
+Complaint due on 1/26/98 for Jessie Siegel (ae) (Entered: 01/22/1998)
+31
+Affidavit of service of Second Amended Complaint as to Siegel, Martin
+by Pat Bowles, Secretary, authorized to accept service on 1/5/98; Answer
+to Second Amended Complaint due on 1/26/98 for Siegel, Martin (ae)
+(Entered: 01/22/1998)
+31 | Affidavit of service of Second Amended Complaint as to Kon Softer b
+Pat Bowles, Secretary, authorized to accept on 1/5/98; Answer to Second
+Amended Complaint due on 1/26/98 for Ron Soffer (ae) (Entered:
+01/20/1998
+01/22/1998
+02/04/1998
+02/06/1998
+02/19/1998
+02/24/1998
+31
+Affidavit of service of Second Amended Complaint as to Carmen Talsig
+by Pat Bowles, Secretary, authorized to accept service on 1/5/98; Answer
+to Second Amended Complaint due on 1/26/98 for Carmen Talsig (ae)
+(Entered: 01/22/1998)
+32 STIPULATION and ORDER, reset answer to second amended complaint
+due for 1/30/98 for Fisher & Soffer, for Diane Fisher, for Ivan Fisher
+(signed by Judge Denny Chin). (djc) Modified on 01/23/1998 (Entered:
+01/23/1998)
+35 | ORDER, that the Clerk of the Court shall establish an interest-bearing
+account (the "account") and that payment of any funds tendered pursuant
+to or in accord with this order shall be deposited by the Clerk of the
+Court into the account and that the Clerk of the Court shall maintain the
+account until such further order of this Court. Send $225,000.00 to Texas
+Chris acct. (signed by Judge Denny Chin); Copies mailed; copy of doemt
+sent to Cashiers office (djc) (Entered: 02/23/1998)
+33 Transcript of record of proceedings before Judge Chin filed for dates o
+December 17, 1997 (bm) (Entered: 02/06/1998
+34 MEMORANDUM DECISION, I will enter a protective order that does
+not contain Proposed Paragraph 7(c). The Government may not use
+confidential information produced in discovery pursuant to the protective
+order for any purpose other than prosecuting this lawsuit, absent further
+order of the Court ( signed by Judge Denny Chin); Copies mailed (ae)
+Modified on 02/23/1998 (Entered: 02/20/1998)
+36 PROTECTIVE ORDER, regarding procedures that will govern the
+03/05/1998
+37
+ANSWER by Jeffrey E. Epstein (Attorney Steven J. Cohen) to second
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.p1?321462322339233-L_353_0-1
+
+
+
+03/05/1998
+03/16/1998
+03/16/1998
+03/16/1998
+03/20/1998
+03/24/1998
+04/01/1998
+amended complaint (ae) (Entered: 03/09/1998)
+37 CROSSCLAIMS by Jeffrey E. Epstein against Ivan Fisher (ae) (Entered:
+03/09/1998)
+38 STIPULATION and ORDER, reset answer to second amended complaint
+due for 2/27/98 for Jeffrey E. Epstein, for Ivan Fisher, for Ellyn Bank, for
+Debra Elisa Cohen, for Diane Fisher, for Fisher & Soffer, for Robert
+Heilbrun, for Suzanne McDermott, for Christopher H. Martin, for Jessie
+Siegel, for Siegel, Martin, for Ron Soffer, for Carmen Talsig, for John
+Does 1 - 10, for X Corporations 1-10 ( signed by Judge Denny Chin).
+39 | Filed Memo-Endorsement on letter by Serene K. Nakano to Judge Chin
+dated 2/24/98, reset Government's motion for summary judgment filing
+deadline for 3/13/98 ( signed by Judge Denny Chin) (ae) (Entered:
+03/10/1998)
+40| ANSWER by Ivan Fisher, Fisher & Soffer (Attorney Eileen J. Casey) to
+amended complaint; by attorney Eileen J. Casey for defendant Fisher &
+Soffer (djc) (Entered: 03/20/1998)
+40| AMENDED COUNTERCLAIM by Ivan Fisher: amending [13-1]
+counter claim (djc) (Entered: 03/20/1998)
+40 | AMENDED CROSSCLAIM by Ivan Fisher, Jeffrey E. Epstein [37-1]
+cross claim (djc) (Entered: 03/20/1998)
+41| ANSWER by Ivan Fisher to [37-1] cross claim; Firm of: Gage & Pavlis
+(cd) (Entered: 03/24/1998)
+42 STIPULATION and ORDER, answer to the second amended complaint
+due for 3/16/98 for Fisher & Soffer, for Diane Fisher ( signed by Judge
+Denny Chin). (cd) (Entered: 03/25/1998)
+43| NOTICE OF MOTION by USA for an order, purs. to Rule 56(a),
+04/01/1998
+04/01/1998
+04/01/1998
+attached. (sac) (Entered: 04/02/1998)
+44 MEMORANDUM by USA in support of [43-1] motion for an order,
+purs. to Rule 56(a), granting summary judgment on the second cause of
+action of the second amended complaint as against defts Diane Fischer
+d/b/a The Fischer Group and Rom Soffer (sac) (Entered: 04/02/1998)
+45 ANSWER by Jeffrey E. Epstein to [13-1] cross claim ; by attorney
+Steven J. Cohen for cross-defendant Jeffrey E. Epstein (sac) (Entered:
+04/02/1998)
+46| MEMORANDUM OPINION #80385, the Government's motion for
+Sumera and diment on ischains signemy fidge Deny lo in ; Copies
+mailed. (emil) (Entered: 04/03/1998)
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.pl?321462322339233-L_353_0-1
+
+
+
+04/09/1998
+47 | Filed Memo-Endorsement on letter to Judge Chin from Serene K.
+Nakano dated 04/02/98, the Court having already found in its March 31,
+04/09/1998
+04/10/1998
+05/21/1998
+ove of a copy of him no sotter by droning a copy tai th
+tention at
+›vernight mail to the attention of Mr. Soffer at 34 East 69th Street, NY
+VY as soon as it is received by counsel for the Government (signed by
+Judge Denny Chin) (djc) (Entered: 04/13/1998)
+49| CERTIFICATE OF SERVICE by USA re 4/7/98, memorandum
+endorsement (cd) (Entered: 04/14/1998)
+48| ORDER that the prior orders of this Court dated 12/17/97 and 12/31/97
+monies by defts Jeffrey E. Epstein and Ivan S. Fisher are moditled to the
+extent that Fisher is ordered to deposit the sum of $15,000.00 per month
+to the Clerk of the Court by the 10th day of each month until the date that
+this action is finally determined ( signed by Judge Denny Chin); Copies
+mailed. Sent to Cashier's Office on 4/14/98. (emil) (Entered: 04/14/1998)
+50 ORDER, Fisher seeks a stay of entry of judgment pending appeal of my
+as i coulude that a stay is not waranted here, for Fisher has not met
+" of proving that a stay is warranted. Accordingly
+05/22/1998
+51
+05/22/1998)
+ORDER & JUDGMENT; it is ordered, adjudged and decreed that the
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.p|7321462322339233-L_353_0-1
+
+
+
+of defts Ivan S. Fisher and Fisher & Soffer a/k/a Fisher & Sophir alleged
+in their answer to the second amended complaint (the "Fisher
+counterclaim"), is granted in all respects. The Soffer ejectment motion is
+granted as against deft Ron Soffer. Defts Jeffrey E. Epstein, Ivan s
+roup, Fisher & Soffer a/k/a Fisher & Sophi
+I D. Gerzog,
+obert Heilburn, Suzanne McDermott, Christopher H. Martin, Jess
+05/27/1998 (Entered: 05/26/1998)
+Case closed (sac) (Entered: 05/26/1998)
+05/22/1998
+05/22/1998
+05/22/1998
+05/22/1998
+05/29/1998
+Diane Fischer d/b/a The Fischer Group and Rom Soffer (signed by Judge
+Denny Chin); Copies mailed. (djc) Modified on 05/29/1998 (Entered:
+05/27/1998)
+Memo endorsed on motion, doc. #25; motion granted per opinion dated
+3/31/98 ( signed by Judge Denny Chin); Copies mailed. (kw) (Entered:
+05/27/1998)
+Case reopened. CASE CLOSED IN ERROR. (dcap) (Entered:
+08/28/1998)
+52 | Letter filed by USA to Judge Chin dated 12/31/97, re: in response to (a)
+the citations by defendants Jeffrey E. Epstein and Ivan S. Fisher to the
+testimony of witnesses whose depositions were taken after the
+submission of the Government's motion for partial summary judgment;
+and (b) the Court's invitation to the parties to supplement the record and
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.p|?321462322339233-L_353_0-1
+
+
+
+05/29/1998
+06/05/1998
+07/06/1998
+07/08/1998
+their memorandum of law concerning any further legal authorities (ae)
+(Entered: 06/01/1998)
+53 | Letter filed by Ellen J. Casey o/b/o Ivan Fisher to Judge Chin dated
+1/7/98, re: in response to the government's motion for partial summary
+judgment (ae) (Entered: 06/01/1998)
+54 NOTICE OF APPEAL by Ivan Fisher ; from [51-1] judgment order.
+Copies of notice of appeal mailed to Attorney(s) of Record: Serene K.
+Nakano, Esq., fee pd., $105.00, rec # 317761 . (as) (Entered: 06/08/1998)
+55 | ORDER, pitff shall file and serve any opposition by 7/10/98; and deft
+shall file and serve her reply, if any, by 7/15/98 (signed by Judge Denny
+Chin); Copies mailed. (kg) (Entered: 07/07/1998)
+56 | Filed Memo-Endorsement on letter by David Wikstrom to Judge Chin
+dated 7/5/98, counsel for defendant Ivan Fisher, requests a conference
+07/10/1998
+07/10/1998
+07/27/1998
+08/04/1998
+08/04/1998
+08/06/1998
+08/11/1998
+57 DECLARATION in opposition by Serene K. Nakano for pltff USA re the
+motion by deft Suzanne McDermott for summary jdgmt. (Is) (Entered:
+07/10/1998)
+58 GOVT'S MEMORANDUM OF LAW by USA in opposition to motion of
+deft Suzanne McDermott for partial summary jdgmt. (Is) (Entered:
+07/10/1998
+59 RETURN OF SERVICE executed as to Forcible eviction on 7/16/98.
+Order left at residence. Tenants moved out & took their personal
+belongings. (sac) (Entered: 07/28/1998)
+60 NOTICE OF MOTION by I
+D. Gerzog for an order granting
+summary judgment, pursuant to Rule 56 of the FRCP; affirmation in
+support is attached. (kw) (Entered: 08/05/1998)
+61
+MEMORANDUM by
+D. Gerzog in support of [60-1] motion
+for an order granting summary judgment, pursuant to Rule 56 of the
+FRCP. (kw) (Entered: 08/05/1998)
+NOTICE of dismissal of complaint against defendant Carmen Tausik,
+purs to Rule 41(a)(1) of the FRCP; Plaintiff United States of America
+ereby dismisses the second amended complaint as against defendan
+Carmen Tausik (signed by Judge Denny Chin) (djc) (Entered
+08/06/1998)
+63 ANSWER to Complaint by Robert Heilbrun, Christopher H. Martin,
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.pl?321462322339233-L_353_0-1
+
+
+
+Jessie Siegel, Siegel, and Martin. (Attorney Robert Heilbrun) (kW)
+(Entered: 08/11/1998)
+08/26/1998
+64
+09/15/1998
+09/15/1998
+09/18/1998
+09/22/1998
+09/22/1998
+09/24/1998
+10/09/1998
+10/14/1998
+10/19/1998
+10/22/1998
+65 | Rule 56.1 statement filed by USA (djc) (Entered: 09/16/1998)
+66 MEMORANDUM of LAW by USA in opposition to [60-1] motion for
+an order granting summary judgment, pursuant to Rule 56 of the FRCP
+(dic) (Entered: 09/16/1998)
+67 SEALED DOCUMENT placed in vault (kb) (Entered: 09/18/1998)
+68 | Certificate of service of Second Amended S&C as to Ivan Fisher, Diane
+Fisher, Fisher & Soffer by Ellen J. Casey, atty, on 12/23/97 (sac
+Entered: 09/23/1998
+68 Certificate of service of Second Amended S&C as to Jeffrey E. Epstein
+by Steven Cohen, atty, on 12/23/97 (sac) (Entered: 09/23/1998)
+NOTICE of attorney appearance for Debra Elisa Cohen by Ellen
+Yaroshefsky (Is) (Entered: 09/28/1998)
+70 | Notice that the record on appeal has been certified and transmitted to the
+U.S. Court of Appeals: [54-1] appeal by Ivan Fisher on October 9, 1998.
+(dt) (Entered: 10/09/1998)
+71 | Filed Memo-Endorsement on letter to Judge Chin from Ellen
+Yaroshefsky dated 10/8/98; counsel for Dera Cohen requests that the
+Court permit the adjournment of Ms. Cohen's deposition beyond the
+current discovery cutoff date. I have reviewed this letter; the Govt's letter
+of today; and Ms. Yarostefsky's 2d letter of today, the request for an
+adjournment of Ms. Cohen's deposition is denied ; ( signed by Judge
+72 | ORDER, the Court has received Ron Soffer's letter of 9/24/98. Mr. Soffer
+is a named defendant in this action. If he wishes to be dismissed trom the
+case, he may make either a motion to dismiss or a motion for summary
+judgment, w/out a premotion conference ( signed by Judge Denny Chin);
+Copies mailed (ae) (Entered: 10/19/1998)
+73 ANSWER by Debra Elisa Cohen to the Second amended complaint; by
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.p|?321462322339233-L_353_0-1
+
+
+
+11/09/1998
+02/03/1999
+attorney Ellen Yaroshefsky. (bw) (Entered: 10/23/1998)
+74 MANDATE OF USCA (certified copy) Re: Dismissed [54-1] appeal by
+Ivan Fisher. It is ordered that the appeal be, and it hereby is dismissed.
+(98-6133) Carolyn Clark Campbell, Cler, USCA. (as) (Entered:
+11/09/1998)
+75 STIPULATION and ORDER, the parties agree to settle and compromise
+03/09/1999
+03/17/1999
+1/12/99 (Is) (Entered: 03/15/1999)
+77 | Order of dismissal; that this action is hereby dismissed with prejudice
+03/17/1999
+08/12/1999
+Denny Chin) (pi) (Entered: 03/18/1999)
+Case closed (pI) (Entered: 03/18/1999)
+78| SEALED DOCUMENT placed in vault (kb) (Entered: 08/12/1999)
+PACER Service Center
+Transaction Receipt
+05/22/2007 18:18:00
+PACER Login: du4480
+Client Code:
+Description: Docket Report Search Criteria: 1:96-cv-08307-DC
+Billable Pages: 8
+Cost:
+D.64
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.p|?321462322339233-L_353_0-1
+
+
+
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.p|?321462322339233-L_353_0-1
+
+
+
+U.S. Distriet Court
+United States District Court for the Southern District of New York (Foley Square)
+CIVIL DOCKET FOR CASE #: 1:97-cv-01489-DC
+Petitioner
+Jeffrey E. Epstein
+Date Filed: 03/05/1997
+Date Terminated: 03/31/2000
+Jury Demand: None
+Nature of Suit: 230 Rent Lease &
+Ejectment
+Jurisdiction: Federal Question
+represented by William B. Wachtel
+Wachtel & Masyr, LLP
+110 East 59th Street
+New York. NY 10022
+Fax: LUMM
+Email: wachtel@wmllp.com
+Respondent
+Ivan Fisher
+Respondent
+John Doe
+Respondent
+X Corp
+Date Filed
+03/05/1997
+#
+1
+represented by Eileen J. Casey
+Gage Buschmann & Pavlis
+120 West 45th Street
+New York NY 10036
+represented by Eileen J. Casey
+(See above for address)
+represented by Eileen J. Casey
+(See above for address)
+Docket Text
+NOTICE OF REMOVAL from New York Civil Court County of New
+York; FILING FEE $ 150.00 RECEIPT # 282380 Index # 058689/97.
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.p1?569396355749046-L_353_0-1
+
+
+
+03/05/1997
+03/05/1997
+03/14/1997
+03/14/1997
+03/21/1997
+03/21/1997
+03/24/1997
+03/28/1997
+03/28/1997
+04/07/1997
+02/24/1998
+(sac) (Entered: 03/06/1997)
+CASE REFERRED TO Judge Chin (sac) (Entered: 03/06/1997)
+2 NOTICE of Notice of Filing of Notice of Removal by Ivan Fisher. (kg)
+(Entered: 03/06/1997)
+3 NOTICE OF MOTION by Jeffrey E. Epstein to remand to the Civil
+Court, City of NY, County of NY , Return date 4/11/97 (cd) (Entered:
+03/17/1997) |
+4 MEMORANDUM by Jeffrey E. Epstein in support of [3-1] motion to
+remand to the Civil Court, City of NY, County of NY (cd) (Entered:
+03/17/1997)
+(rism pered: 03/241 10 96 CY 8307. Notice of assignment to follow.
+5 Notice of asgmnt _ to Judge Denny Chin Copy of notice and judge s rules
+mailed to Attorney(s) of record: Eileen J. Casey, William B. Wachtel.
+(riem) (Entered: 03/24/1997)
+6
+Case Information Statement Addendum and Case Designation to a
+Magistrate Judge filed. Case is designated to Magistrate Judge Pitman.
+(em) (Entered: 03/24/1997)
+NOTICE OF CROSS MOTION by Ivan Fisher to consolidate this action
+with the action pending in the Court entitled U.S. of America L Jeffrey
+E. Epstein and Ivan S. Fisher, #96cv8307 , Return date 4/14/97 (pl)
+8 | MEMORANDUM by Ivan Fisher in opposition to [3-1] motion to
+remand to the Civil Court, City of NY, County of NY, in support [7-1]
+ross motion to consolidate this action with the action pending in th
+Court entitled U.S. of America L. Jeffrey E. Epstein and Ivan S. Fisher
+#96cv8307 (pl) (Entered: 03/31/1997)
+9 REPLY MEMORANDUM OF LAW by Jeffrey E. Epstein in support of
+re: [3-1] motion to remand to the Civil Court, City of NY, County of NY
+(ae) (Entered: 04/08/1997)
+PROTECTIVE ORDER, regarding procedures that will govern the
+handling of confidential information ( signed by Judge Denny Chin);
+Copies mailed (original in 96cv8307, doc #36) (cd) (Entered:
+02/25/1998)
+STIPULATION and ORDER, reset answer to second amended complaint
+due for 2/27/98 for X Corp, for John Doe, for Ivan Fisher ( signed by
+Judge Chin ) (orig. doc. filed in case #96 civ. 8307, doc. #38) (ae)
+Filed Memo-Endorsement on letter by Serene K. Nakano to Judge Chin
+dated 2/24/98, reset The Government's motion for summary judgment
+filing deadline for 3/13/98 ( signed by Judge Denny Chin ) (orig. doc.
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.pl?569396355749046-L_353_0-1
+
+
+
+03/24/1998
+filed in case #96 civ. 8307, doc. #39) (ae) (Entered: 03/11/1998)
+Terminated documents 3-1 and 7-1 as per instruction of Judge Chin dated
+3/9/98 (emil) (Entered: 03/11/1998)
+STIPULATION and ORDER, reset answer to the second amended
+complaint due for 2/27/98 for Ms. Fisher and Fisher & Softer ( signed by
+Judge Denny Chin). (original fld in 96cv8307, doc #42) (cd) (Entered:
+03/25/1998)
+04/09/1998
+03/31/2000
+03/31/2000
+04/13/1998)
+10 | ORDER; this action is hereby dismissed. ( signed by Judge Denny
+Chin); Copies mailed. (sac) (Entered: 04/03/2000)
+Case closed. (sac) (Entered: 04/03/2000)
+PACER Service Center
+Transaction Receipt
+05/22/2007 18:19:02
+PACER Login: |(du4480
+Client Code:
+Description:
+Docket Report | Search Criteria: ||1:97-cv-01489-DC
+Billable Pages: |2
+Cost:
+0.16
+https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.pl?569396355749046-L_353_0-1
+
+
+561
+of time, constitute irreparable harm. Te- ing enforcement of ARIN's Religious Affilnafly, 309 F.3d at 178, quoting, inter alia, iations policy pending disposition of her
+Elrod | Burns, 427 U.S. 347, 373, 96 S.Ct.
+request for a permanent injunction (hear-
+2673, 49 L. Ed.2d 547 (1976).
+ing scheduled for August 28, 2003), and
+ordering defendants to reinstate her to her
+former position with full back pay and
+benefits. For all of the foregoing reasons,
+[33] Defendants will suffer little or no the Court also will deny defendants' moharm if the Court grants this preliminary tion to dismiss.'
+injunction. They are not subject to crimi- Defendants agreed at the hearing that
+nal prosecution under the Garb Statute, they would not demand a bond in the event
+there is no showing of actual or threatened the Court ruled in plaintiff's favor, and
+accordingly, bond will be waived.
+this litigation, and as we have seen, there
+Clause.
+X. Public Interests
+[34] Where there is no compelling
+state interest to justify a burden on reli
+gious freedom, "the public interest clearly
+favors
+the protection of constitutional
+rights." Tenafly, 309 F.3d at 178, quoting
+Council of Alternative Political Parties |
+Hooks, 121 F.3d 876, 884 (8d Cir.1997)
+XI. Conclusion
+35] The Court will grant plaintiff's "
+est for a preliminary injunction enjoi
+1. Plaintiff's complaint also challenges the
+Garb Statute and the Religious Affiliations
+policy under the free exercise of religion
+clauses of the Pennsylvania Constitution anc
+the newly enacted Pennsylvania Religious
+Freedom Protection Act, 71 Pa. Stat. Ann.
+§ 2401, et seq., Act of December 9, 2002, P.L.
+1701, No. 214, § 1, et seg., effective immediately. The 1895 predecessor to the current
+Garb Statute was upheld against a similar
+state constitutional challenge by the Supreme
+ourt of Pennsylvania in Commonwealth |
+Terr. 229 Pa. 132, 78 A. 68 (1910), and thi
+Court is not at liberty to reconsider that vintage ruling.
+FINANCIAL TRUST COMPANY, INC.
+and Jeffrey E. Epstein, Plaintiffs,
+CITIBANK, N.A. and Citigroup, Inc
+1/b/a "Citigroup," Defendants
+No. CIV. 2002-108.
+District Court, Virgin Islands,
+D. St. Thomas and St. John.
+June 19, 2003.
+The Pennsylvania Religious Freedom Protection Act of 2002 has not been judicially
+interpreted and this Court is hesitant to sail
+the uncharted waters within its reach. In any
+event, as defendants contend, it does not appear that plaintiff provided proper notice to
+the agency imposing the alleged substantial
+burden on the free exercise of religion (i.e., to
+ARIN), as required by section 5(b) of that Act,
+71 Pa. Stat. Ann. § 2405, and defendants do
+not suggest that the Court should address this
+state statutory claim first, in order to avoid
+the First Amendment issues. Accordingly, the
+Court does not address plaintiff's claim under
+Pennsylvania's Religious Freedom Protection
+
+
+562
+and fraudulently induced them to borrow and officers initiated contact with borrowfunds to invest in collateralized bond obli- ers in Virgin Islands for loans that were
+gation transaction managed by entity with subject of litigation. 5
+$ 4903.
+which bank's subsidiary had investment
+banking relationship. On bank's motions to
+4. Federal Courts e-1023
+dismiss and to transfer, the District Court,
+Virgin Islands was proper venue for
+Moore, J., held that: (1) bank was subject Virgin Islands borrowers' action against
+to general personal jurisdiction in Virgin New York bank for fraudulently inducing
+Islands; (2) fact issues remained as to it to participate in transaction, even
+whether there was fiduciary relationship though borrowers agreed to submit to jurparticularity.
+at to let me in a one deterie of
+rowers did not agree to sue or be sued
+Motions granted in part, and denied in
+exclusively in New York, bank was subject
+part.
+to general personal jurisdiction in Virgin
+Islands, and bank officials solicited borrowers while they were in Virgin Islands.
+1. Federal Courts e-96
+28 U.S.C.A. § 1391(a).
+When defendant moves to dismiss for
+lack of personal jurisdiction, plaintiff must 5. Federal Courts 8-143, 144
+make prima facie showing of sufficient con-
+Party seeking transfer of venue for
+tacts between defendant and forum territo- convenience of parties and witnesses and
+ry to support in personam jurisdiction. in interest of justice bears burden of estab-
+Fed.Rules Civ.Proc.Rule 12(b)(2), 28 lishing by preponderance of evidence that
+transfer is necessary. 28 U.S.C.A.
+2. Federal Courts 6-96
+§ 1404(a).
+In evaluating motion to dismiss for 6. Federal Courts •-101, 103, 105
+lack of personal jurisdiction, court must
+Although trial judge is afforded great
+accept all of plaintiff's allegations as true
+discretion in deciding motion to transfer
+and construe disputed facts in favor of
+for convenience of parties and witnesses,
+Fed.Rules Civ.Proc.Rule
+he or she should not disturb plaintiff's
+12(b)(2), 28 U.S.C.A.
+choice of forum unless balance of factors
+3. Federal Courts 6-1023
+'strongly weighs in favor of transfer. 28
+Bank and its parent company were
+U.S.C.A. § 1404(a).
+subject to general personal jurisdiction in
+Virgin Islands in borrowers' action alleg-
+7. Federal Courts 6-1023
+ing that bank officials fraudulently induced
+Transfer of venue for convenience of
+them to borrow funds to invest in transac- parties and witnesses from Virgin Islands
+tion, even if bank had closed all of its to Southern Distriet of New York was not
+operations in Virgin Islands, where bank warranted in Virgin Islands borrowers'
+operated bank branches and marketed and fraud action against New York bank,
+provided banking services in Virgin Is- where borrowers resided in Virgin Islands,
+lands before litigation commenced, contin- most of documents needed to try case had
+ued to process its outstanding loans in already been filed in Virgin Islands court,
+Virgin Islands via its Puerto Rican offices, bank was currently litigating other cases
+and initiated litigation in Virgin Islands, in Virgin Islands, and there was no evi-
+
+
+FINANCIAL TRUST CO., INC. | CITIBANK N.A
+563
+dence that key witnesses were unable to rowers' claim against lender for breach of
+travel to Virgin Islands.
+28 U.S.C.A. fiduciary duty by failing to disclose conflict
+§ 1404(a).
+of interest in connection with investment.
+8. Contracts e-206
+12. Banks and Banking 6-100
+Choice of law provision in promissory
+Under Virgin Islands law, subseripnote did not govern borrowers' claims tion agreement between fund manager and
+against lender for fraud, misrepresenta- investors did not bar investors' claim
+tion, misinformation, and breach of fiduin alterined bond bleaten trace leine te and to brance orie
+tion managed by entity with which bank's investors of manager's relationship with its
+subsidiary, even though agreement acsubsidiary had investment banking relaknowledged that investors did not rely on
+tionship, where borrowers' claims did not
+bank's advice in making investment, where
+involve construction, validity, or perforbank was not party to agreement, and did
+mance of note.
+not speak to long-term relationship be-
+9. Federal Civil Procedure e-1831
+tween bank and investors.
+Issue of whether bank adequately disclosed to investors its relationship with
+fund manager presented fact questions
+that could not be resolved on motion to
+dismiss investors' action alleging that bank
+misrepresented facts and fraudulently induced them to borrow funds to invest in
+collateralized bond obligation transaction
+managed by fund manager with which
+bank's subsidiary had investment banking
+relationship.
+13. Banks and Banking 6=100
+Under Virgin Islands law, borrowers'
+allegation that bank negligently failed to
+disclose that they or their affiliates had
+pecuniary interest in investment and that
+borrowers relied upon information and advice provided by bank officials to their
+detriment adequately stated claim of neglimisrepresentation. Restatement
+(Second) of Torts $ 552.
+10. Banks and Banking •=100
+14. Federal Civil Procedure e=636
+Under Virgin Islands law, borrowers'
+allegation that lenders failed to disclose
+Borrowers's allegation that bank offitheir relationship with fund manager and
+cials did not disclose bank's relationship
+did not promptly assist them in underwith fund manager before advising borstanding how to remove it as fund managrowers to invest with manager failed to
+er adequately alleged that lenders' fraudu-_ plead fraud claims against bank with suffilent conduct caused their financial losses,
+cient particularity, where complaint did
+where borrowers claimed that they could not state who made alleged misrepresentahave obtained new fund manager or retions to borrowers, or exactly what false
+duced their losses in some other fashion if
+statement or representation was made.
+they had known of conflict of interest.
+Fed.Rules Civ.Proc.Rule 9(b), 28 U.S.C.A.
+11. Federal Civil Procedure 1831
+Issue of whether lender had substantial control over borrowers' business affairs presented fact questions that could
+Maria Tankenson Hodge, Hodge &
+not be resolved on motion to dismiss bor- Francois, St. Thomas, VI, for the plaintiffs.
+
+
+564
+Gregory H. Hodges, Dudley, Topper and
+Feuerzeig, LLP, St. Thomas, VI, for the
+defendants.
+In April 1999, Dayle Davison ["Davison"], Vice President of Citibank in New
+York and Epstein's private banker, and
+other Citibank employees telephoned Ep-
+MEMORANDUM OPINION
+stein while he was in the Virgin Islands
+and recommended that the plaintiffs invest
+MOORE, Distriet Judge.
+through placement agent Salomon Smith
+After careful consideration of the par-
+Barney ['SSB"], a "subsidiary or affiliate"
+ties' written and oral arguments, I will of the defendants, in a collateralized bond
+deny the defendants' motions to dismiss
+obligation transaction managed by AIG.
+for lack of personal jurisdiction and to
+(Compl. 11 12, 24; Epstein Decl. 118-10;
+transfer this case to New York. Further, I
+Davison Aff. 1111, 102-18.) According to
+find that the amended complaint adequatethe plaintiffs, during the negotiations of
+ly states claims of breach of fiduciary duty
+this deal Davison represented to Epstein
+and negligent misrepresentation. Finally,
+that he was "virtually assured of receiving
+I will grant the defendants' motion to disan 18-20% return on [his] investment, with
+miss Counts I, II, III, and VI for failure to
+a possible return of as much as 30%" and
+meet Federal Rule of Civil Procedure
+assured him that Citibank was going to
+9(b)'s heightened pleading requirement for
+remain actively involved in the investment.
+fraud, but I will grant leave for the plain-
+(Epstein Decl. 1 11.)
+tiffs to amend their pleadings.
+After further discussion between Ep-
+stein and Davison, Citibank offered to loan
+I. FACTUAL AND PROCEDURAL
+BACKGROUND
+Epstein $10 million on the express condition that the money be used exclusively to
+In their amended complaint, Jeffrey E.
+fund FTC's investment in the AIG-man-
+Epstein ["Epstein"] and Financial Trust
+aged venture. (Id. 11 12-13.) On August
+Company, Inc. ["FTC"] [collectively "plain-
+2, 1999, Epstein executed a promissory
+tiffs"] allege that Citibank, N.A. ["Citinote in favor of Citibank in the amount of
+bank"] and Citigroup, Inc. ["Citigroup"]
+$10 million [the "1999 Note"]. (Pls.' Mem.
+[collectively "defendants") misrepresented
+Of Law in Opp'n to Mot. To Dismiss, Ep-
+facts and fraudulently induced them to
+stein Deel. 115; Mem. Of Law in Support
+borrow $10 million to invest in a venture
+of Defs.' Mot. To Dismiss, Ex. A.) In addimanaged by AIG Global Investment Cortion, Citibank and FTC entered into a
+poration ["AIG"]. The plaintiffs allege that hypothecation agreement. (Mem. Of Law
+the defendants failed to disclose informa- in Support of Defs! Mot, to Dismiss, Ex. B
+tion and negligently and fraudulently mis- at 7)
+On June 15, 2000, Epstein executed and
+tionship with AIG (Counts I, II, III, IV delivered to Citibank an amended and reand VI, that the plaintiffs detrimentally stated promissory note ['the Amended
+relied on these misrepresentations (Counts 1999 Note"] that superseded the 1999
+I, II, III, and VI), and that the defendants Note. The Amended 1999 Note extended
+breached their fiduciary duty to the plain- the maturity date of the 1999 Note to
+tiffs (Count D. The plaintiffs seek rescis- August 2, 2001. (Id. Ex. D.) In connection
+sion of the promissory note and punitive with the Amended 1999 Note, Epstein and
+damages (Counts VI and VII). (Am. FTC also signed an agreement entitled
+"First Amendment to Note and Affirma-
+
+
+FINANCIAL TRUST CO., INC. |. CITIBANK N.A.
+565
+tion of Hypothecation Agreement and Cer- mation from Chase Manhattan, the Trusttain Documents Referred to Therein" [the ee of the fund. (Pls' Mem. Of Law in
+"first Extension Agreement"] in which Opp'n to Mot. To Dismiss, Schantz Decl.
+they reaffirmed the Amended 1999 Note in 916-8. ) Chase Manhattan, however, reits entirety, the Hypothecation Agreement, ferred the plaintiffs back to Citigroup. In
+and each document and term thereunder. June, the plaintiffs learned for the first
+(Id. Ex. E.) Each of these documents-the time that AIG itself owned twenty-eight
+original 1999 Note, the 1999 hypothecation percent (28%) of the income notes of the
+agreement, the Amended 1999 Note, and AIG investment. Thus, plaintiffs would
+the first Extension Agreement-contains not need other income note holders with as
+clauses stating that New York law would much of an investment in the income notes
+govern the "construction, validity, and per as they originally had believed because
+formance" of the 1999 Note and the
+AIG's interest would not count toward any
+Amended 1999 Note. (Id. Ex. A at 8-9;
+vote to remove it as manager. In July
+Ex. B at 7-8; Ex. D at 10; Ex. E at 2-3.)
+2001, the plaintiffs finally received the in-
+Sometime in the spring of 2001, Epstein
+formation they had requested from Citiand FTC diseovered that the AIG Investbank. (Id. 199-10.)
+ment was "suddenly and rapidly deterio-
+At this time, Davison and SSB reprerating." (Pls' Mem. Of Law in Opp'n to
+sentatives urged the plaintiffs not to at-
+Mot. To Dismiss, Epstein Decl. 1 20.) Ac-
+tempt to seek to remove AIG as the fund
+cording to the plaintiffs, FTC's advisors
+manager. In August 2001, FTC's attorcontacted Davison and other employees of
+ney arranged a telephone conference with
+Citibank, and requested Citibank's help in
+representatives from Citibank and SSB.
+coordinating the replacement of the AIG
+Plaintiffs contend that during this conferfund's manager. (Id. 121; Schantz Decl.
+ence they learned for the first time that
+15) In May 2001, Davison informed the
+Citibank could not assist them in seeking
+plaintiffs that, in order to remove AIG as
+to remove AIG because SSB had an inthe fund manager, FTC would need sixtyvestment banking relationship with AIG
+six and two-thirds percent (66% %) of the
+that might be adversely affected by such
+votes of income note holders. Because the
+an action. (Id. at 9911-18.)
+plaintiffs did not know the identities or
+respective percentages of ownership of the
+On June 11, 2002, the plaintiffs filed
+other income note holders, they requested
+their complaint in this Court. One month
+that Davison provide them with that inforlater on July 11, 2002, Citibank sued the
+mation. The plaintiffs claim that Davison plaintiffs in the Southern District of New
+initially assured them that she would pro- York, alleging that they had defaulted on
+vide such information promptly, but later both the loan at issue here and a second
+informed them that she was having diffi- $10 million loan.' See Citibank, N.A. |
+culty obtaining the information from SSB,
+Epstein, Index No. 02-CV-5332-SHS
+and recommended that they seek the infor- (S.D.N.Y.2002). On November 27, 2002, I
+1. Sometime in 2000, Davison informed Ep-
+stein about a second, similar investment fund
+to be managed by Mass Mutual [the "Mass
+Mutual Fund"]. On June 15, 2000, Epstein
+borrowed an additional $10 million from Citibank, that Epstein agreed to invest in the
+Mass Mutual Fund. (Mem. Of Law in Support
+of Defs.' Mot. To Dismiss, Ex. D.) Although
+the plaintiffs have stated an intent to seck to
+amend the complaint to include claims related to the Mass Mutual Fund, they have not yet
+done so. (See Pls.' Mem. Of Law in Opp'n to
+Mot. To Dismiss at 12 n. 12.)
+
+
+566
+issued an order restraining Citibank and the defendants are currently doing busi-
+Citigroup from pursuing their New York ness in the Virgin Islands and that this
+lawsuit pending decisions on these mo- Court has jurisdiction over the defendants
+tions. Financial Trust Co., Inc. |. Citi- under the Virgin Islands' Long-Arm Statbank, N.A., Order, Civ. No.2002-108 ute. The plaintiffs insist that the defen-
+| Nov. 27, 2002). In light of subse- dants' depiction of Citigroup as a "holding
+quent events, however, I sua sponte vacat- company" is belied by Citigroup's publie
+ed this prohibition. Financial Trust Co, disclosures that the plaintiffs claim do not
+Inc. • Citibank, N.A., Order, Civ. identify Citibank as a separate subsidiary
+No.2002-108 (
+1. Dec. 13, 2002).
+or affiliate of Citigroup. (Pls' Mem. Of
+The defendants charge that plaintiffs' Law in Opp'n to Mot. to Dismiss at 16-24.)
+suit in the Virgin Islands is merely "a
+[1,2] I agree with the plaintiffs and
+transparent attempt to launch a preempfind that this Court has personal jurisdietive strike to hamper Citibank's efforts to
+tion over the defendants under the Virgin
+recover the $20 million in promissory notes
+Islands Long-Arm Statute and that, under
+... upon which Epstein has defaulted."
+the United States Constitution, the defen-
+(Mem. Of Law in Support of Def's Mot.
+dants have had enough "minimum con-
+To Dismiss at 2.) The defendants move to
+tacts" with the Virgin Islands to require
+dismiss this action under Federal Rule of
+them to defend a lawsuit in this jurisdic-
+Civil Procedure 12(b)(2) for lack of persontion. This Court sitting in diversity exeral jurisdiction, or alternatively, to transfer
+cises personal jurisdiction over a non-resithis case to the Southern District of New
+dent defendant pursuant to the forum's
+York under 28 U.S.C. § 1404(a). Finally,
+long-arm statute and in compliance with
+the defendants aver that the amended
+the Due Process Clause of the Fourteenth
+complaint fails to state a cause of action
+"minimum contacts" reupon which relief may be granted under
+quirement. See In re Tutu Wells Contam-
+Federal Rule of Civil Procedure 12(b)(6)
+ination Litig, 846 F.Supp. 1243, 1264
+and does not allege fraud with the requi-
+(D.Vi.1993) (citing International Shoe Co.
+site particularity as required by Federal
+Rule of Civil Procedure 9(b). I address
+|. Washington, 326 U.S. 810, 66 S.Ct. 154,
+90 L.Ed. 95 (1945)). When a defendant
+moves under Rule 12(b)(2) to dismiss for
+lack of personal jurisdiction, the plaintiff
+II. DISCUSSION
+must make a prima facie showing of suffi-
+A. This Court has Personal Jurisdic. cient contacts between the defendant and
+tion over Citibank and Citigroup the forum territory to support in person-
+The defendants maintain that Citibank am jurisdietion, see Mellon Bank (Bast)
+discontinued its presence in the Virgin Is- PSFS Natl Ass'n | Farino, 960 F.2d
+lands in 1999 and that Citigroup is merely 1217, 1223 (3d Cir.1992), and the court
+a holding company that "does not have and must accept all of the plaintiff's allegations
+never has had any assets, offices or em- as true and construe disputed facts in faployees in the Virgin Islands." In addi- vor of the plaintiff, see Carteret Sau. Bank,
+tion, the defendants insist that the events FA |. Shushan, 954 F.2d 141, 143 n. 1 (3d
+giving rise to this cause of action have no Cir.1992). The nature of these contacts
+connection with the Virgin Islands. (Mem. must be such that the defendant should be
+of Law in Support of Defs' Mot. to Dis- reasonably able to anticipate being haled
+miss at 6-9.) The plaintiffs counter that into court in the forum state. See World-
+
+
+567
+Cite as 268 F.Supp. 2d 561 (D.Virgin Islands 2003)
+Wide Volkswagen Corp. | Woodson, 444 tionship between the defendants and the
+U.S. 286, 297, 100 S.Ct. 569, 62 L.Ed.2d plaintiffs, I find that the plaintiffs have
+490 (1980).
+established that Citibank and Citigroup
+are sufficiently linked. For example, Citi-
+1.
+This Court has Personal Jurisdic- group's website plainly states that it does
+tion over the Defendants under the business through Citibank and other units
+Virgin Islands Long-Arm Statute throughout the world. Indeed, during oral
+The Virgin Islands long-arm statute, 5 argument on these motions, the defendants
+| $ 4903, provides, in relevant part: presented a letter sent to Epstein concern-
+(a) A court may exercise personal juris. ing the loans, identifying the two as linked
+diction over a person, who acts directly together as "Citigroup, private bank" and
+or by an agent, as to a claim for relief
+"The Citigroup Private Bank, Citibank,
+arising from the person's
+N.A." At least at this preliminary stage, I
+find that Citibank and Citigroup are in-
+(1) transacting any business in this
+volved in the subject matter of this litigaterritory;
+tion. Accordingly, I conclude that this
+Court has jurisdiction under the Virgin
+(3) causing tortious injury by an act
+Islands Long-Arm Statute over both the
+or omission in this territory;
+defendants.
+(4) causing tortious injury in this territory by an act or omission outside this
+territory if he regularly does or solicits
+business, or engages in any other persistent course of conduct, or derives
+substantial revenue from goods used or
+consumed or services rendered, in this
+2. The Defendants' "Minimum Contacts" in the Virgin Islands Meet
+the Constitution's Due Process Re-
+quirements
+In addition to finding jurisdiction under
+this forum's long-arm statute, I must also
+determine whether the defendants' con-
+. § 4903. Under subsection (a)(1),
+duct here in the Virgin Islands rises to the
+the term "transacting any business" can be level of "minimum contacts" as required
+satisfied by "only a single act which in fact by the Constitution. The Due Process
+amounts to the transaction of business Clause of the Fourteenth Amendment rewithin a state or territory." Guardian quires that a court determine whether a
+Ins. Co. | Bain Hogg Intl Ltd, Civ. defendant had the "minimum contacts"
+No.1996-180, 2000 WL 1690315, **2-3, with the forum necessary for the defentober 20, 20 I us i Got 3 m
+dant to have "reasonably anticipated being
+haled into court there." World-Wide
+ternational Moving Consultants, Inc., 18
+Volkswagen, 444 U.S. at 297, 100 S.Ct. 559.
+• 60, 66-67 (
+.1980)). It is suffi- A finding of minimum contacts demands
+cient, thérefore, that. Citibank entered into the demonstration of " 'gome act by which
+a contract with a Virgin Islands resident, the defendant purposely availed itself of
+and that the defendants solicited the plainthe privilege of conducting business within
+tiffs—while they were in the Virgin Is-
+the forum State, thus invoking the proteclands—-to borrow $10 million to invest in
+tion and benefits of its laws.'" Pennzoil
+the AIG-managed fund.
+Prods. Co. I Colelli & Assocs, Inc., 149
+[3] With respect to the relationship be-
+F.3d 197, 203 (3d Cir.1998). A plaintiff
+tween Citibank and Citigroup and the rela- can meet this burden in one of two ways:
+
+
+by establishing specific or general jurisdic-
+Having found that minimum contacts extion over a defendant. Mesalic |. Fiberf- ist, I must decide whether compelling
+loat Corp, 897 F.2d 696, 699 (3d Cir.1990). these out-of-territory defendants to submit
+A court's general jurisdiction "is based on to jurisdiction in the Virgin Islands comthe defendant's general business contacts ports with traditional notions of fair play
+with the forum [territory] and permits a
+and substantial justice. Grand Entmt
+court to exercise its power in a case where
+Group, Ltd. |. Star Media Sales, Inc., 988
+the subject matter of the suit is unrelated F.2d 476, 481 (3d Cir.1993) (citing Internato those contacts." Metropolitan Life Ins.
+tional Shoe, 326 U.S. 310 at 316, 66 S.Ct.
+Co. | Robertson-Ceco Corp., 84 F.3d 560,
+154). Applying these considerations here,
+568 (2d Cir.1996). Under this test, the
+I find it reasonable to assert jurisdiction
+plaintiff must establish that the defenover Citibank and Citigroup. The burden
+on the defendants to defend this lawsuit in
+dant's contacts with the forum jurisdiction
+the Virgin Islands is not severe, most of
+are "continuous and systematic." Id.
+the relevant documents have already been
+I find that this Court has general jurisfiled in this Court and several airlines
+diction over the defendants. Citibank opmake daily flights connecting New York
+erated bank branches and marketed and
+and St. Thomas. The Virgin Islands obviprovided banking services in the Virgin
+ously has a valid interest in protecting its
+Islands for years before and after April
+residents from out-of-state financial insti-
+1999 and until 2002, just months before the
+tutions. Resolving the case in this Court
+commencement of this litigation. On Janis just as efficient as trying it in New York
+and there is no evidence that the interests
+uary 31, 2002, Citibank closed its last reof New York or the Virgin Islands would
+maining bank branch in the U.S. Virgin
+be better served if this matter were not
+Islands, and Citibank no longer makes real
+estate-related loans in the Virgin Islands.
+litigated in this jurisdiction. See, e.g.,
+Mesalic, 897 F.2d at 701 (citing Asahi
+(Malins Aff. 113-4.) Citibank, however,
+Metal Indus. Co. . Superior Ct, 480 U.S
+continues to process its outstanding loans
+102, 113, 107 S.Ct. 1026, 94 L.Ed.2d 92
+here via its Puerto Rican offices, and initi-
+(1987)). Accordingly, I find that this
+ates litigation in this Court. (Jd. 15) All
+Court has general jurisdiction over the
+of the foregoing plainly demonstrates that
+defendants and that litigating this matter
+Citibank, and Citigroup through Citibank,
+in this forum comports with the Constituhave continuously and systematically contion's due process requirements.
+ducted business in the Virgin Islandsincluding initiating contact with the plain-
+B. Venue in this Court is Proper untiff's for the loans that are the subject of
+der 28 U.S.C. § 1391(a)
+this litigation-and therefore, are subject
+[4] Defendants also argue that this is
+to this Court's general jurisdiction. See, an improper venue in which to litigate this
+e.g, Metropolitan Life Ins. Co., 84 F.3d at dispute. (Mem. in Supp. of Defs' Mot. to
+569 (finding that "our review of general Dismiss at 20-21.) I agree with the plainjurisdiction cases reveals that contacts are tiffs, however, that the Virgin Islands is a
+commonly assessed over a period of years proper choice of venue. (Pls' Mem. of
+prior to the plaintiff's filing of the com- Law in Opp'n to Mot. to Dismiss at 24-29.)
+plaint" and listing cases). Accordingly, I Although the plaintiffs agreed to submit to
+will deny the motion to dismiss for lack of the jurisdiction of New York courts and to
+personal jurisdiction.
+waive the defense of an inconvenient fo-
+
+
+569
+rum, they did not agree to sue or be sued proper under section 1391(a)(2). Accordexclusively in New York. The Amended ingly, I will deny the defendants" request
+1999 Note states that
+to dismiss this matter for improper venue.
+the undersigned [Epstein] hereby irrevocably submits to the jurisdiction of C. This Case Need Not Be Transferred to New York
+any New York state or federal court
+sitting in New York City, and the undersigned hereby irrevocably agrees that diction and venue are proper in this Court,
+any action may be heard and determined the defendants have requested that I
+in such New York state court or in such transfer this case to the United States
+federal court. The undersigned hereby District Court for the Southern District of
+irrevocably waives, to the fullest extent
+New York. They aver that this claim actuhe may effectively do so, the defense of
+ally arose in New York and that the clausan inconvenient forum to the maintees in the agreements stipulating to the
+nance of any action in any jurisdietion.
+application of New York Law and the
+(Mem. In Support of Defs.' Mot. To Displaintiffs' agreement to submit to the jurismiss, Ex. D at 10) The Amended 1999
+diction of New York courts require that
+Note, however, does not limit "the underthis matter be litigated in New York.
+signed" to a specific forum or bar the
+(Mem. Of Law in Support of Defs.' Mot. to
+plaintiffs from suing the defendants in any
+forum having personal jurisdiction over
+the defendants. Moreover, under the fed-
+[5, 6] Transfer to a new forum under
+eral venue statute, a diversity case such as
+the federal venue statute requires that the
+this can be brought in a "district where
+transfer be "[flor the convenience of the
+any defendant resides, if all defendants
+parties and witnesses [and] in the interest
+reside in the same State." 28 U.S.C.
+of justice." 28 U.S.C. § 1404(a). Citibank
+§ 1391(a). This statute further provides
+and Citigroup bear the burden of estabthat "[flor purposes of venue ..., a defenlishing by a preponderance of the evidence
+dant that is a corporation shall be deemed
+that transfer is necessary. In re Charles
+to reside in any judicial district in which it
+Schwab & Co. Sec. Litig., 69 F.Supp.2d
+is subject to personal jurisdiction at the
+734, 735 (D.Vi.1999) (citing Shutte | Armtime the action is commenced." 28 U.S.C.
+co Steel Corp, 431 F.2d 22, 25 (3d Cir.
+1891(c). Because I have found that both
+1970)). Although a trial judge is afforded
+Citibank and Citigroup are subject to this
+great discretion in deciding this motion, he
+Court's personal jurisdiction and are thus
+or she should not disturb a plaintiff's
+deemed residents of the Territory for ven- choice of forum unless the balance of facle purposes, venue is proper in the Virgin tors strongly weighs in favor of transfer.
+Islands under section 1391(a)(1). In addi- Jackson |. Executive Airlines, Inc., Civ.
+tion, these claims may be litigated in a No.2000-121, 2001 WL 664673, *2, 2001
+"district in which a substantial part of the U.S. Dist. 8004 LEXIS at *7 ( June
+events or omissions giving rise to the claim 7, 2001). A defendant seeking a transfer
+occurred." 28 U.S.C. § 1391(a)(2). The will not overcome this presumption unless
+solicitation of the plaintiffs while they were the defendant can prove that the "balance
+in the Virgin Islands and the mailing of of convenience of the parties is strongly in
+documents to the plaintiffs constitute a favor of defendant." Shutte., 431 F.2d at
+sufficiently substantial part of the events 25. Among the factors to be considered in
+
+
+(1) plaintiff's choice of forum; (2) defen- stated that their key witnesses are unable
+dant's preference; (3) where the claim to travel to the Virgin Islands. See Ju-
+arose; (4) convenience to the parties; mara, 56 F.3d at 879. Finally, it is not at
+(5) convenience to witnesses—but only all clear that New York law must be apto the extent that the witnesses may plied to determine the causes of action
+actually be unavailable for trial in one of raised by plaintiffs, but to the extent that
+the fora; (6) location of books and rec- another jurisdiction's jurisprudence does
+ords; (7) practical considerations that apply, this Court is fully capable of applycould make the trial easier, more expedi- ing such law. For the foregoing reasons, I
+tious, or less expensive; (8) congestion find that the requisite factors weigh in
+of the possible fora; and (9) the familiar- favor of litigating this matter in the Virgin
+ity of the trial judge with the applicable Islands, and thus I will deny the motion to
+state law in diversity cases.
+See generally Jumara - State Farm Ins
+Co., 55 F.3d 878, 879-80 (3d Cir.1995).
+[7] Considering the totality of the circumstances surrounding this case, 1 make
+D. The Amended Complaint Adequately States Claims upon
+Which Relief May be Granted Un-
+der Federal Rule of Civil Procethe following findings. First, Epstein and
+Financial Trust have selected this forum,
+The defendants aver that I should disand they are residents of the Virgin Is-
+miss this action pursuant to Federal Rule
+lands with strong ties to this community.
+of Civil Procedure 12(b)(6) because the
+Epstein owns a seventy-acre island, and he
+amended complaint fails to state a claim
+and Financial Trust employ some twenty
+upon which relief may be granted. In
+people. (Pls.' Mem. Of Law in Opp'n to
+considering a Rule 12(b)(6) motion, I ac-
+Mot. To Dismiss, Epstein Deel. 11 2, 4-5.)
+cept all allegations in the complaint as
+It is important that local plaintiffs with
+true, and draw all reasonable inferences in
+grievances against defendants subject to
+favor of the non-moving party. In re
+this Court's jurisdiction be permitted to
+Rockefeller Cir. Props., Inc, 311 F.3d 198,
+seek redress here in the Virgin Islands.
+215 (8d Cir.2002). "The inquiry is not
+noted, no forum selection
+whether plaintiffs will ultimately prevail in
+clause binds the parties to bring suit in
+a trial on the merits, but whether they
+any particular jurisdiction.
+should be afforded an opportunity to offer
+dants contacted the plaintiffs and entered
+evidence in support of their claims." Id
+into negotiations concerning the AIG in-
+(citing Scheuer . Rhodes, 416 U.S. 232,
+vestment while they were in the Virgin 236, 94 S.Ct. 1688, 40 L.Ed.2d 90 (1974),
+Islands, and at least one agreement was overruled on other grounds, Harlow
+addressed to the plaintiffs through trans- Fitzgerald, 457 U.S. 800, 102 S.Ct. 2727, 73
+mission to the plaintiffs' attorneys in New L.Ed.2d 396 (1982)). The defendants raise
+York, intending that it be sent to the Vir- several arguments in support of their mogin Islands. I do not find that the defen- tion, each of which I address in turn.
+dants will suffer any great inconvenience
+(Mem. of Law in Support of Defs.' Motion
+by litigating this matter here. As the
+plaintiffs point out, most of the documents
+needed to try the case have already been
+1. Virgin Islands Law Governs this
+filed in this Court, and the defendants are
+currently litigating other cases in this
+[8] Throughout their brief, the defen-
+Court. Moreover, the defendants have not dants rely on New York law to support
+
+
+FINANCIAL TRUST CO., INC. |. CITIBANK N.A.
+571
+their 12(b)(6) motion. Their reliance on or negotiation of any securities or com-
+New York law, however, is misplaced. In modities, and that there is no private right
+the Amended 1999 Note, the parties stipu- of action. (Defs' Mem. Of Law in Support
+lated only that
+of Mot. To Dismiss at 44-46.) The plain-
+[this note shall be governed by, and tiffs counter that New York's Martin Act
+construed in accordance with, the laws does not apply to nor bar their claims.
+of the State of New York, including (Pls. Mem. Of Law in Opp'n to Mot. To
+matters of construction, validity and per- Dismiss at 48-49.
+formance, without giving effect to princi-
+The plaintiffs correctly assert that New
+ples of conflicts of law....
+York law does not govern their claims. In
+(Mem. Of Law in Support of Defs! Mot. Count IV of the amended complaint, the
+To Dismiss, Ex. D at 10) The issues plaintiffs allege that the defendants failed
+raised by the plaintiffs, however, do not
+to diselose that they or their affiliates had
+involve the "construction, validity and per-
+a pecuniary interest in the AIG Investformance" of the note; rather, they involve
+ment "despite mismanagement" of the AIG
+allegations of fraud, misrepresentation, mifund. The plaintiffs contend that they resinformation, and breach of a fiduciary
+lied on the information and advice given by
+duty of the defendants in advising the
+defendants, and suffered a substantial peplaintiffs about the AIG-managed fund.
+Accordingly, I find that New York law
+does not govern these claims, and instead
+shall look to Virgin Islands law to determine whether the plaintiffs have stated
+claims cognizable in this jurisdiction.
+2. New York's Martin Act Does Not
+Compl.11 56-57.) In Count. the plaintiffs accuse the defendants of breaching a
+fiduciary duty owed to them. (la. 111 59-
+61.) Neither of these claims involves the
+"construction, validity and performance" of
+the Amended 1999 Note, and therefore,
+they are not governed by New York law?
+Apply to this Lawswit
+The defendants aver that the Martin
+Act, New York General Business section
+352 et seq., bars the plaintiffs' claims for
+negligent misrepresentation (Count IV)
+and breach of fiduciary duty (Count
+because, under the Act, only New York
+State's Attorney General has the power to
+bring such claims resulting from the sale
+2. The Martin Act is New York's blue sky law.
+General Business Law section 352-c prohibits
+various fraudulent and deceitful practices in
+the distribution, exchange, sale and purchase
+of securities. The Martin Act vests exclusive
+authority in the New York Attorney General
+to investigate and prosecute violations of the
+Act. The Martin Act does not, however, provide for a private cause of action. See Nairo
+bi Holdings Lid. . Brown Bros. Harriman &
+Co., Civ. No.2002-1230, 2002 WL 31027550
+*4.
+2002 U.S. Dist. LEXIS 16995 at *10
+(S.D.N.Y. Sept. 10, 2002) ("[l]t is well estab-
+• The Amended Complaints Nondis
+osure Allegations are Factual Is
+sues to be Determined at Trial
+Citibank and Citigroup claim that every
+count in the amended complaint is premised upon their alleged failure to disclose a
+conflict of interest. They aver, however,
+that SSB's relationship with AIG was dislished that there exists no private right of
+action for claims that are within the purview
+of the [Martin] Act.); Granite Partners, L.P. I
+Bear, Steams, & Co., Inc., 17 F.Supp.2d 275,
+291 (S.D.N.Y.1998) (same); Deutsch | Integrated Barter Intl, Inc. 700 F.Supp. 194
+(S.D.N.Y.1988); CPC Intl, Inc. . McKesson
+orp., 70 N.Y.2d 268, 276, 519 N.Y.S.2d 804
+514 N.E.Zd 116 (N.Y.1987) (noting that "la
+majority of this court now holds that there is
+no cause of action impliedly created under
+[the Martin Act]").
+
+
+572
+closed to the plaintiffs both in the "pitch the plaintiffs' losses under New York law.
+book" and in the Offering Circular used to (Mem. Of Law in Supp. of Defs' Mot. to
+market the AIG investment. Accordingly, Dismiss at 40-44) As noted above, Virgin
+therefore, the defendants assert that each Islands law governs these claims. The
+count of the amended complaint should be plaintiffs maintain that they have adedismissed to the extent that it is premised quately stated causation by alleging that
+on the defendants' alleged failure to dis- the defendants did not disclose their relaclose the relationship between AIG and tionship with AIG and did not promptly
+SSB. (Mem. Of Law in Support of Defs.' assist them in understanding how to re-
+Mot. To Dismiss at 36-39.) The plaintiffs move AIG as fund manager-presumably
+challenge the defendants' reliance on these because of a conflict of interest or loyalty
+documents and the propriety of consider- owed to AIG. But for this delay, the plaining them under Rule 12(b)(6). Alternatiffs complain that they could have obtively, they claim that these documents
+tained a new fund manager or reduced
+confirm the defendants' failure to disclose
+their losses in some other fashion. Ac-
+the existence of a continuing investment
+cordingly, the amended complaint adebanking relationship with AIG that would
+quately alleges that the defendants'
+render the defendants unable to advise the
+wrongful conduct caused their financial
+plaintiffs in an impartial, objective manner.
+(Pla' Mem. Of Law in Opp'n to Mot. To
+[9] Although generally, a distriet court
+may not consider matters extraneous to
+5. Plaintiffs' Claims of Breach of Fi-
+duciary Duty and Negligent Misrepresentation Need Not Be Disthe pleadings, I may consider "a document integral to or explicitly relied upon
+Citibank and Citigroup argue that the
+in the complaint ... without converting
+claim of breach of fiduciary duty should be
+the motion to dismiss into one for sumjudgment." U.S. Express Lines
+dismissed because the Subscription Agreement between AIG and the plaintiffs ex-
+Ltd. | Higgins, 281 F.3d 383, 388 (3d
+plicitly states that they did not owe the
+Cir.2002) (emphasis added) (quoting In re
+plaintiffs such a duty. Moreover, they as-
+Burlington Coat Factory Litig., 114 F.3d
+sert that New York law does not recognize
+1410, 1426 (3d Cir.1997)), Because
+a fiduciary duty owed by a bank to its
+parties dispute whether the document in
+customer or by a broker to its customer.
+question is the actual "pitch book" refer. Finally, the defendants argue that the
+enced in the amended complaint, however, plaintiffs' negligent misrepresentation
+I find that whether the defendants dis- claim must also be dismissed because the
+closed SSB's relationship to AIG to the defendants owed the plaintiffs no fiduciary
+plaintiffs is a disputed fact that precludes duty. (Mem. Of Law in Supp. of Defs."
+a Rule 12(b)(6) dismissal.
+Mot. to Dismiss at 46-50.) The plaintiffs
+counter that, even under New York law,
+4. The Complaint Adequately Alleges the issue whether a fiduciary duty exists
+that the Defendants' Wrongful Con requires a fact-specific analysis of the toduct Caused the Plaintifis' Losses tality of the circumstances surrounding the
+[10] Citibank and Citigroup argue that relationship between the plaintiffs and the
+the plaintiffs have failed to allege ade- defendants. The plaintiffs contend, howquately that the defendants' actions caused ever, that under the controlling Virgin Is-
+
+
+573
+lands law, they have stated claims for arms-length banking relationship. They
+breach of fiduciary duty and negligent mis- claim that they and the defendants have a
+representation. They argue that the de- fifteen-year relationship and that the defendants owed them a fiduciary duty be- fendants acted as their financial advisor. I
+cause they "cultivated a relationship of find that, for purposes of surviving a Rule
+trust over a fifteen-year span as their pri- 12(b)(6) motion, the amended complaint
+vate banker" and then used this trust to adequately states a claim for breach of
+market new and inherently risky invest- fiduciary duty.
+ment opportunities which became even [12] In addition, I find that the defenmore risky because of defendants' tortious dants' argument that the Subscription
+conduct. (Pls.' Mem. Of Law in Opp'n to Agreement between AIG and the plaintiffs
+Mot. To Dismiss at 41-46.)
+bars these claims against them is without
+merit. A fair reading of the Subscription
+• The Amended Complaint Adequate
+v Stateg a Claim for Breach of f]
+Agreement compels the conclusion that its
+main purpose is to protect AIG's interests
+in its dealing with Epstein and FTC. The
+In Count of the amended complaint,
+agreement discusses at length the process
+the plaintiffs allege that the defendants
+by which AIG, through its agent, Citibank,
+cultivated a relationship of trust with the
+will deliver income notes to Epstein, the
+plaintiffs over fifteen-years as their private
+purchaser. The Subscription Agreement
+banker, and that the defendants breached
+contains a clause stating that neither AIG,
+their fiduciary duty owed to the plaintiffs
+SSB, nor Citibank
+by failing to disclose a conflict of interest
+is acting as a fiduciary or financial or
+and effectively "forced" the plaintiffs to
+investment adviser for the Purchaser
+keep their funds in a failing investment.
+and the Purchaser is not relying on any
+The plaintiffs claim that the defendants
+written or oral advice, counsel or repre-
+"served as [their] financial investment adsentations of the Company, the Investvisor and broker, as well as providing othment Manager, the Placement Agent
+er financial and banking services to
+[SSB], the Agent or any of their respec-
+[p]laintiffs, and thereby formed a fiduciary
+tive affiliates ... [and that] [t]he Purrelationship with [p]laintiffs and other inchaser has consulted with its own legal,
+vestors." (Am.Compl.11 10, 59-60.)
+regulatory, tax, business investment fi-
+[11] In typical lender-borrower relanancial, and accounting advisers to the
+tionships, there is a presumption that the
+extent it has deemed necessary, and has
+parties operate at arms-length and in their
+made its own investment decisions based
+own interest. Jo-Ann's Launder Ctr.,
+upon its own judgments and upon any
+Inc. |. Chase Manhattan Bank, N.A., 854
+advice from such advisers as it has
+F.Supp. 387, 392 (D.Vi.1994). A fiduciary
+deemed necessary and not upon any
+relationship may arise, however, dependview expressed by the Company, the
+ing upon the particular circumstances of
+Investment Manager, the Placement
+the financial relationship. This may occur,
+Agent, the Agent or any of their respecfor example, when a lender has substantial
+tive affiliates.
+control over the borrower's business af- (Mem. In Supp. of Defs.' Mot. To Dismiss,
+fairs. Id. Here, the plaintiffs have alleged Ex. C. at 10-11, 1 i.) Although this docuthat their relationship with Citibank and ment alludes to Citibank's role in this one
+Citigroup was not the "garden-variety" at transaction, the agreement does not speak
+
+
+574
+to the fifteen-year relationship between Mot. to Dismiss at 51-52) Whereas the
+the defendants and the plaintiffs that is plaintiffs, in their amended complaint, have
+the gravamen of the amended complaint. set out their request for rescission of the
+Moreover, Citibank is not a party to nor Amended 1999 Note and punitive damages
+did it sign the Subscription Agreement. I in the form of additional causes of action, I
+find, therefore, that the Subscription
+will require them to reframe them as part
+Agreement does not dispose of the plain- of the ad damnum elause.
+tiffs' breach of fiduciary duty claim as a
+matter of law.
+•. The late a et complies lien ate.
+representation
+D. Counts I, II, III, and VI of the
+Plaintiffs' Amended Complaint
+Fail to Meet Federal Rule of Civil
+Procedure 9(b)'s Heightened
+Pleading Standard for Claims of
+[13] In the Virgin Islands, the elements of negligent misrepresentation are:
+[o]ne who, in the course of his business,
+Finally, the defendants argue that
+profession or employment, or in any oth-
+Counts I, II, III, and VI should be diser transaction in which he has a pecunimissed due to the plaintiffs' failure to
+ary interest, supplies false information
+plead fraud with the requisite particularity
+for the guidance of others in their busias required under Federal Rule of Civil
+ness transactions, is subject to liability
+Procedure 9(b). They aver that the
+for pecuniary loss caused to them by
+amended complaint is "rife with sweeping
+their justifiable reliance upon the inforconclusory allegations but fatally short on
+mation, if he fails to exercise reasonable
+detail" and that the fraud claims fail to
+care or competence in obtaining or comexplicitly reference Citigroup, do not state
+municating the information.
+any dates on which the alleged conduct
+RESTATEMENT (SECOND) OF TORTS § 552
+occurred, and do not name any specific
+(1977). Count IV of the amended comemployees of the defendants. The defenplaint alleges that the defendants neglidants contend that the complaint simply
+gently failed to disclose that they or their
+does not put them on notice of what exactaffiliates had a pecuniary interest in the
+ly each is accused. (Mem. of Law in Supp.
+AIG investment and that the plaintifis reof Mot. to Dismiss at 32-85.) The plainlied upon the information and advice protiffs counter that, although the amended
+vided by the defendants to their detriment.
+complaint does not specify who within Citi-
+(Am.Compl.11 55-56.)
+I find that Count
+group or Citibank recommended the AIG
+IV thus adequately states a claim of negliinvestment, the defendants are aware of
+gent misrepresentation.
+which of their employees are implicated in
+this matter. Moreover, the plaintiffs sub-
+6. The Rescission and Punitive Dam- mit that the defendants are responsible for
+ages Counts are not Causes of Ac- the "universal fungibility" of the Citigroup
+tion
+and Citibank names. The plaintifis ask
+The defendants contend that this Court that this Court find that the amended comshould dismiss Counts VI and VII-for plaint meets Rule 9(b)'s requirements, or,
+damages—-because each claim seeks specif- allegations of fraud under Federal Rule
+ie relief without asserting any claim for 15(a). (Pls' Mem. Of Law in Opp'n to
+relief. (Mem. Of Law in Supp. of Defs.' Mot. To Dismiss at 30-32, 39-41.)
+
+
+575
+Federal Rule of Civil Procedure 9(b) [the defendants] did not, in fact, truthfully
+requires parties alleging fraud to describe hold." (Id. 1150) Count III claims that.
+the circumstances constituting fraud "with the defendants are liable to the plaintiffs
+particularity." Rule 9(b) requires that the for their failure to disclose this informaplaintiff "givel ] defendants notice of the tion, "because they knew that their nonclaims against them, providel] an in- disclosure would justifiably induce the
+creased measure of protection for their Plaintiffs to proceed with the proposed inreputations, and reduce[ ] the number of vestment." (Id. 152) Finally, Count VI
+frivolous suits brought solely to extract again claims that the defendants' conduct
+settlements." In re Rockefeller Ctr. "constituted the making of fraudulent mis-
+Props, Inc, 311 F.3d at 215 (quoting I» re representations to, and/or fraudulent con-
+Burlington Coat Factory Sec Litig, 114 calment and non-disclosure of material
+F.3d at 1418). "Rule 9(b) requires a plaintiff to plead (1) a specifie false representation of material fact; (2) knowledge by the
+[14] I agree with the defendants' asperson who made it that it was false; (3)
+sertions that Counts I, II, III, and VI do
+ignorance of its falsity by the person to
+not meet Rule 9(b)'s heightened pleading
+whom it was made; (4) the intention that it
+requirements. First, nowhere does the
+should be acted upon; and (5) that the
+complaint state who made the alleged misplaintiff acted upon it to his damage."
+representations to the plaintiffs. See In re
+Shapiro |. UJB Fin. Corp, 964 F.2d 272,
+Rockefeller Ctr. Props, Inc., 311 F.3d at
+284 (3d Cir.1992). Although the rule does
+218 (finding that complaint failed to comnot require a recitation of "every material
+ply with Rule 9(b) because the allegation
+detail" of the alleged fraud, it does require,
+failed to identify the speaker, and "there is
+at a minimum, "that plaintiffs support
+no indication that the speaker had the
+their allegations of fraud with all of the
+authority to speak on behalf of [the defenessential factual background that would
+dant] or that the employee was in regular
+accompany 'the first paragraph of any
+contact with the [defendant]). Second,
+newspaper story'-that is, the 'who, what,
+the complaint fails to allege exactly what
+when, where and how of the events at
+false statement or representation was
+issue." In re Rockefeller Ctr. Props,
+made. Instead, it claims that the defen-
+311 F.3d at 217 (quoting In re Burlington,
+dants' failure to inform them of SSB's
+114 F.3d at 1422).
+relationship with AIG was fraudulent. This
+In Count I, plaintiffs allege that the does not meet Rule 9(b)'s requirement that
+lefendants' conduet "constituted the mak- there be a false statement that the defen
+ing of fraudulent misrepresentations ... dants knew was false. In addition, the
+regarding the AIG Investment" that the plaintiffs' allegation that the defendants
+defendants knew were materially mislead- misrepresented their claims that they asing "because of their failure to state or pired to "the highest standards of moral
+disclose the additional or qualifying infor- and ethical conduct" is vague. Accordingmation regarding the investment banking ly, I find that Counts I, II, III, and VI do
+relationship" of SSB with AIG. (Id. 146.) not meet Rule 9(b)'s heightened pleading
+Count II vaguely states that the defen- requirement, and, therefore, I will dismiss
+dants' "statements and conduets ... in- them. I shall, however, grant the plaincluded the expression of opinions which tiffs thirty days within which to amend the
+
+
+576
+complaint to comport with Rule 9(b).* See TY DAYS within which to file an amended
+In re Burlington Coat Factory Sec. Litig,
+complaint with respect to these counts.
+114 F.3d at 1434 (noting that ordinarily
+when a complaint is dismissed under Rule
+9(b) for failure to plead fraud with the
+requisite particularity, leave to amend the
+complaint is granted).
+III. CONCLUSION
+For the foregoing reasons, I will deny Elizabeth A. REEVES, et al., Plaintiff,
+Citibank's and Citigroup's motions to dismiss for lack of personal jurisdiction, to
+dismiss for improper venue, and to transfer this matter to the United States District Court for the Southern District of
+New York. I find that the amended complaint adequately states claims of breach of
+fiduciary duty and negligent misrepresentation, and therefore, will deny the defendants' Rule 12(b)(6) motion to dismiss for
+failure to state a claim. Finally, because
+ST. MARY'S COUNTY
+COMMISSIONERS, et
+al., Defendants.
+No. CIV.A.AW-02-2449.
+United States District Court,
+D. Maryland,
+Southern Division.
+June 13, 2008.
+find that Counts I, II, III, and VI fail to
+meet Federal Rule of Civil Procedure
+9(b)'s heightened pleading standard for
+claims of fraud, I will dismiss these claims
+and grant the plaintiffs leave to amend the
+Landowner brought action against
+county commissioners and individuals for
+violations of due process rights and a taking under the Fifth Amendment related to
+county's denial of her application for a
+ORDER
+conditional use permit to construct an Al-
+For the reasons given in the Memoranzheimer's facility on her land. On cross
+dum Opinion of even date, it is HEREBY
+motions for summary judgment, the Dis-
+ORDERED that the defendants' motion to
+trict Court, Williams, J., held that: (1)
+dismiss for lack of personal jurisdiction
+takings claims were not ripe for adjudicaunder Federal Rule 12(b)(2), motion to
+tion, and (2) even if claims were ripe, they
+dismiss under Federal Rule of Civil Procevere barred by res judicat
+dure 12(b)(6), and motion to transfer this
+Motion grantec
+matter are DENIED. Counts I, II, III,
+and VI fail to meet Federal Rule of Civil
+Procedure 9(b)'s heightened pleading stan- 1. Eminent Domain e=277
+dard for claims of fraud and are hereby
+Federal courts cannot adjudicate tak-
+DISMISSED WITHOUT PREJUDICE.
+ings claims premised on use restrictions
+The plaintiffs, however, shall have THIR-
+until the relevant state or state agency has
+• Citibank and Citigroup also argue th
+unt II, alleging fraud, is impermissib
+based on the defendants' unspecified alleged
+false "expression of opinions." (Mem. OF
+Law in Supp. of Defs.' Mot. to Dismiss at 50-
+51) Because I will dismiss this claim under
+Rule 9(b), I need not address this issue at this
+time.
+
+
+329
+Cite as 351 F.Supp. 2d 329 (D.Virgin Islands 2004)
+2. Federal Civil Procedure e-636
+FINANCIAL TRUST COMPANY, INC.
+and Jeffrey E. Epstein, Plaintiffs,
+Courts should apply heightened pleading requirement for fraud with some flexibility and should not require plaintiffs to
+plead issues that may have been concealed
+TIBANK, N.A. and Citigroup, In
+b/a "Citigroup," Defendant:
+No. CIV.2002-108.
+Distriet Court, Virgin Islands,
+Appellate Division,
+D. St. Thomas and St. John.
+Dec. 30, 2004.
+Background: Borrowers brought action
+against bank, alleging that false statements or statements where material facts
+were omitted were made by bank pursuant
+to a course of conduct to fraudulently induce them into a series of investments and
+related loans. Bank moved to dismiss the
+complaint for failure to meet heightened
+pleading requirement for fraud and for
+failure to state a claim upon which relief
+could be granted.
+Holdings: The District Court, Moore, J.,
+held that:
+(1) borrowers' specific factual allegations
+were sufficient to plead fraud claim
+with the requisite particularity, and
+(2) borrowers stated fraud claim against
+bank.
+Motion denied.
+by the defendants. Fed.Rules Civ.Proc.
+Rule 9(b), 28 U.S.C.A.
+3. Federal Civil Procedure C-636
+Although heightened pleading requirement for fraud does not require a
+recitation of every material detail of the
+alleged fraud, it does require that plaintiffs
+support their allegations of fraud with all
+of the essential factual background that
+would accompany the first paragraph of
+any newspaper story—that is the "who,
+what, when, where and how" of the events
+at issue; requirements may be satisfied if
+the complaint describes the circumstances
+of the alleged fraud with precise allegations of date, time or place or by using
+means of injecting precision and
+some means of substantiation into their
+allegations of fraud. Fed.Rules Civ.Proe.
+Rule 9(b), 28 U.S.C.A.
+4. Federal Civil Procedure e=636
+Borrowers' specific factual allegations
+were sufficient to plead fraud claim against
+bank with the requisite particularity; borrowers, who alleged that false statements
+or statements where material facts were
+omitted were made by bank pursuant to a
+course of conduct to fraudulently induce
+them into a series of investments and re-
+1. Fraud 6-41
+lated loans, alleged that bank vice president made specific false representation
+plaintiff is required to plead (1) a specific and omissions of material facts of the relafalse representation or omission of materi- tionship between investment corporation
+al fact; (2) knowledge by the person who and bank in April and May of 1999, that
+made it of its falsity; (8) ignorance of its vice president and others at bank knew of
+falsity by the person to whom it was made; the relationship between bank and invest-
+(4) the intention that it should be acted
+ment corporation and that borrower was
+upon; and (5) that the plaintiff acted upon
+unaware of that relationship, and that borit to his damages. Fed.Rules Civ.Proe.
+rower acted upon the information and but
+Rule 9(b), 28 U.S.C.A.
+for bank's actions he would not have been
+
+
+330
+ajured. Fed.Rules Civ.Proc.Rule 9(b), 28 which relief can be granted pursuant t
+U.S.C.A.
+ederal Rule of Civil Procedure 12(bx6
+5. Banks and Banking ©228
+I. Factual and Procedural History
+Jury question was presented as to
+In their second amended complaint, Jefwhether preliminary offering circular frey E. Epstein and Financial Trust Com-
+(*pitch book"), which was allegedly given pany, Ine. ['FTC"] allege that Citibank,
+to investor, disclosed ongoing business re- N.A. and Citigroup, Ine. [collectively "Citilationships between bank and company in bank"] misrepresented facts and frauduwhich investor invested funds borrowed lently induced them to borrow $ 10 million
+from bank, and therefore whether "be- to invest in a venture managed by AIG
+speaks caution" doctrine precluded inves- Global Investment Corporation ["AIG"]
+tor from stating fraud claim against bank. and another $10 million to invest in a
+venture managed by Mass Mutual. The
+6. Banks and Banking C-226
+Borrowers stated fraud claim against
+bank based on allegations that false statements or statements where material facts
+were omitted were made by bank pursuant to a course of conduct to fraudulently
+induce them into a series of investments
+and related loans; claims alleging fraud relating to each investment would not be
+treated separately since such claims were
+predicated on allegations that bank fraudulently induced borrowers into believing
+they had a preferred relationship with
+bank where bank was acting in borrowers'
+best interest in all of their transactions.
+plaintiffs allege that the defendants failed
+to disclose information and negligently and
+fraudulently misrepresented facts concerning their relationship with AIG, that the
+plaintiffs detrimentally relied on these misrepresentations and omission, and that the
+defendants breached their fiduciary duty
+to the plaintiffs. The plaintiffs seek rescission of the promissory notes and punitive damages.
+Previously, I ruled that this court has
+personal jurisdiction over Citibank and Ci-
+tigroup, venue in this court is proper under 28 U.S.C. § 1391(a), this case need not
+be transferred to New York, the amended
+complaint adequately states claims upon
+which relief may be granted under Federal
+Rule of Civil Procedure 12(b)(6) for the
+breach of fiduciary duty and negligent misrepresentation claims, and counts I, II, III
+and VI of the first amended complaint
+Maria Tankenson Hodge, Esq., Hodge &
+Francois, St. Thomas, VI, for plaintiffs.
+per and Feuerzeig, LLP, St. Thomas, VI,
+for defendants.
+MEMORANDUM OPINION
+MOORE, District Judge.
+Defendants have moved to dismiss the
+econd amended complaint for taure 1
+eet Federal Rule of Civil Procedur
+9(b)'s heightened pleading requirement for
+fraud and for failure to state a claim upon
+o. |. Citibank, 268 F.Supp.2d 561 (D.Vir
+rin Islands 2008)
+II. LEGAL ANALYSIS
+1. Federal Rule of Civil Procedure
+[1-3] In order to state a viable fraud
+claim, Rule 9(b) requires a plaintiff to
+
+
+331
+Cite as 351 F.Supp.2d 329 (D.Virgin Islands 2004)
+plead (1) a specific false representation or interests. For example, it is alleged that
+omission of material fact; (2) knowledge in conversations between April 29, 1999
+by the person who made it of its falsity; and May 2, 1999, Dayle Davison, a Vice
+(3) ignorance of its falsity by the person to President of Citibank in the Private
+whom it was made; (4) the intention that it Banking Division, called Epstein to introshould be acted upon; and (5) that the duce him to an "exceptional investment
+plaintiff acted upon it to his damages." In opportunity." (Compl.f 13) In follow-up
+re Rockefeller Ctr. Props, Inc, 311 F.3d telephone conversations during that same
+198, 215 (3d Cir.2002). Courts should ap- two week period, Davison and her associply Rule 9(b) with some flexibility and ates made additional specific representashould not require plaintiffs to plead issues tions about the AIG Investment, without
+that may have been concealed by the de- disclosing Citibank and AIGs relationfendants. Rolo |. City Investing Co. Liq-
+Davison also during that period
+uidating Trust, 165 F.3d 644 (3d Cir.1998).
+represented that Citibank had "done
+Although the rule does not require a recitheir due diligence" and would remain actation of "every material detail" of the
+tively involved in the deal. (Compl.114.)
+alleged fraud, it does require "that plain-
+In August 2001, in an effort to dissuade
+tiffs support their allegations of fraud with
+Epstein from seeking to remove AIG as
+all of the essential factual background that
+the manager of the AIG Investment,
+would accompany 'the first paragraph of
+John Purcell, a Citibank representative,
+any newspaper story'-that is the who,
+told Jeffrey Schantz, a lawyer for Ep-
+what, when, where and how' of the events
+stein, that Citibank was acting in Ep-
+at issue.'"
+In re Rockefeller Ctr. Props.,
+stein's interests and that Epstein should
+Inc., 311 F.3d at 217 (quoting In re Burtrust Citibank rather than talk about aclington, 114 F.3d at 1422). However, the
+tions which would run counter to Citi-
+Third Circuit Court of Appeals has held
+that the "requirements of Rule 9b) may
+be satisfied if the complaint describes the
+circumstances of the alleged fraud with
+"precise allegations of date, time or place'
+or by using some means of 'injecting precision and some means of substantiation into
+their allegations of fraud.'" Board of
+Trustees of Teamsters Local 863 Pension
+Fund | Foodtown, Inc., 296 F.3d 164, 178
+n. 10 (3d Cir.2002) (internal citations omit-
+(Compl.1 37) These facts all allege that
+defendants failed to state or disclose "additional or qualifying information regarding" their relationship with AIG.
+These specific facts are enough to plead
+fraud with the particularity required by
+Rule 9(b). The plaintiffs have alleged that
+Davison, Epstein's primary contact at Citibank, made specific false representation
+and omissions of material facts of the relationship between AIG and Citibank in
+[4] Plaintiffs allege that false state- April and May of 1999. The complaint has
+ments or statements where material facts
+also alleged that Davison, and others at
+were omitted were made pursuant to a Citibank, knew of the relationship between
+course of conduct to fraudulently induce
+Citibank and AIG and that they knew
+plaintiffs into a series of investments and Epstein was unaware of this relationship.
+related loans. Plaintiffs allege that Citi- Finally, as I had previously ruled, the combank's actions did not conform to the plaint also alleges that Epstein acted upon
+representations in the statements, that this information and but for Citibank's aedefendants were acting in plaintiffs' best tions he would not have been injured.
+
+
+332
+The basic purpose of Rule 9(b) has been edge by the person who made it that it was
+fulfilled—plaintiff has alleged enough in- false; (3) ignorance of its falsity by the
+formation, including specifie names and person to whom it was made; (4) the
+dates, to put Citibank on notice of the intention that it should be acted upon; and
+fraudulent actions it has alleged to have (5) that the plaintiff acted upon it to his
+committed. Moreover, since some of the damage.'" Financial Trust Co., 268
+misrepresentations were alleged to be F.Supp.2d at 575 (quoting Shapiro | UJB
+omissions, Rule 9 does not require specifi- Fin. Corp, 964 F.2d 272, 284 (3d Cir.
+cation of time, place, and nature of misrep- 1992)).
+resentation for these statements; rather, it
+requires only that the plaintiff identify the
+[5] The defendants base their argufacts not communicated. See Golden ment that plaintifis have failed to state a
+Trade, S.r.L. | Jordache, 143 F.R.D. 504
+(S.D.N.Y.1992);
+claim upon which relief can be granted for
+Cottman Transmission
+fraud on their allegation that the alleged
+Sys Inc. I. Dubinsky, 95 F.R.D. 351, 353
+omission of the relationship between AIG
+(E.D.Pa.1982) ("Conduct which never oeand defendants was disclosed and thus the
+curred cannot be described with greater
+"bespeaks caution" doctrine applies to the
+particularity other than to state that it did
+case. Under this theory, when some risks
+are disclosed in documents, the documents
+The information contained in the second
+amended complaint is enough for counts 1,
+II, III, and VI to survive this motion to
+dismiss for failure to plead fraud with particularity pursuant to Federal Rule of Civil
+Procedure 9(b).
+"bespeak caution" to the investor and the
+investor cannot later premise a fraud claim
+on the events of which he has been
+warned. Kline | First Western Gout
+Sec., Inc., 24 F.3d 480, 482 (3d Cir.1994).
+The defendants' claim that the Preliminary
+Offering Circular [the "pitch book"], which
+B. Federal Rule of Civil Procedure
+was allegedly given to Epstein, disclosed
+ongoing business relationships between Ci-
+The defendants also argue that 12(b)(6)
+tibank and AIG and should invoke the
+mandates dismissal of the complaint for
+"bespeaks caution" doctrine.
+failure to state a claim upon which relief
+can be granted. To the extent that plain-
+I have previously ruled that whether the
+tiffs are attempting to reargue their previ-
+"pitch book" referenced in the amendec
+ous motion to dismiss, I reiterate my rulcomplaint is the document that plaintiffs
+ing that Virgin Islands law governs this rely on is a disputed fact that precludes a
+case, that the complaint adequately alleges Rule 12(bX6) dismissal. Financial Trust
+that the defendants' wrongful conduct Co., 268 F.Supp.2d at 572. Nothing in any
+caused the plaintiffs' loses, and that plain- of the briefs have convinced me that the
+tiffs' claims of breach of fiduciary duty and parties do not dispute which pitch book
+negligent misrepresentation should not be Epstein received, what disclosures were
+dismissed. Financial Trust Co., 268 made in any such pitch book, and whether
+F.Supp.2d at 576. The only claims left to those disclosures revealed the alleged conbe decided are the fraud claims.
+flict. As such, a ruling on the "bespeaks
+In order to state a claim for fraud, the caution" doctrine is not appropriate at this
+plaintiff must prove "(1) a specific false juneture in the case because it involves
+representation of material fact; (2) knowl- deciding issues of disputed fact.
+
+
+333
+Cite as 351 F.Supp.2d 329 (D.Virgin Islands 2004)
+[6] Plaintiffs have alleged all necessary Defendants essentially argue that plainelements of fraud. They have alleged that tiff's loans and investment in the AIG and
+defendants intentionally misrepresented Mass Mutual funds should be viewed as
+material facts, through omissions and two separate transactions. This view,
+statements assuring the plaintiffs that they however, belies the alleged conduct of Citiwere acting in Epstein's personal best in- bank. The underlying conduct alleged in
+terest. They have also alleged that the the second amended complaint is that Citiperson who made these misrepresenta- bank fraudulently induced plaintiffs into
+tions, Davison, knew of the relationship believing they had a preferred relationship
+between AIG and Citibank and that Ep- with Citibank where Citibank was acting
+stein and FTC did not know of this rela- in Epstein's best interest in all of their
+tionship. Finally, plaintiffs have also al- transactions, including investing in the
+leged that "but for" defendants misleading
+AIG and the Mass Mutual funds. Essenstatements and omissions, plaintiff would
+tially, plaintiffs argue they were induced
+not have proceeded with their loan and
+into a high stakes relationship with Citiinvestment programs and would not have
+bank based on fraudulent statements and
+suffered these damages. Plaintiffs have
+omissions, and but for these statements,
+thus alleged enough information to survive
+they would not have enjoyed the type of
+a Rule 12(b)(6) motion on their fraud
+relationship with Citibank to be in the
+claims.
+position either for Citibank to present
+them an offer to loan them large sums of
+C. The Mass Mutual Investment
+money to invest in the Mass Mutual fund
+Claims
+or for plaintiff's to trust Citibank's invest-
+Although it is unclear from the second
+ment advice. I believe that whether the
+amended complaint which counts concern
+underlying complained about conduct was
+the Mass Mutual Fund, it is clear that at
+two separate transactions or whether the
+least some of the causes of actions allege
+conduet should be viewed as Citibank's rethat Citibank defrauded Epstein in relalationship as a whole with Epstein is a
+tion to his loans and investment in the
+matter of fact that goes to the issue of
+Mass Mutual Fund. Separately, defendants
+damages and is not appropriate for a Rule
+argue that the court should dismiss the
+12(b)(6) motion.' Therefore, I rule that
+claims alleging fraud relating to the Mass
+the fraud claims should not be separated
+Mutual Fund for failure to plead fraud
+into two different types-AIG and Mass
+specifically under Rule 9(b) and failure to
+Mutual--and thus my previous analysis of
+state a claim upon which relief can be the applicability of Rule 9(b) and Rule
+granted under Rule 12(b)(6). The plain-
+12(b)(6) apply equally to all claims for
+tiff's basic allegation is that "because of damages alleged to occur because of Ep-
+Defendants' false assurances and omis- stein's investments in the AIG and Mass
+sions of true statements concerning their Mutual funds.
+relationship with AIG and the AIG Investment, Plaintiffs made the investment in
+III. CONCLUSION
+the Mass Mutual Fund and suffered signif-
+For the foregoing reasons, I will deny
+icant losses." (Compl."1 65.)
+defendants' motion to dismiss.
+1. This opinion is supported by the structure of
+the second amended complaint which does
+not differentiate the counts between the Mass
+Mutual and AIG funds as defendant attempts
+
+
+334
+ORDER
+For the reasons given in the accompanyng memorandum of even date, it is hereby
+ORDERED that the defendant's motion
+to dismiss is hereby DENIED.
+(4) plaintiffs failed to state securities fraud
+claim against auditors.
+So ordered.
+1. Federal Courts e-71
+Personal jurisdiction extends to the
+limits of the due process clause of the
+Fifth Amendment. U.S.C.A. Const.
+Amend. 5.
+2. Constitutional Law e-305(5)
+In re ROYAL AHOLD
+There are two primary factors to con-
+SECURITIES & ERISA
+sider in evaluating personal jurisdiction
+LITIGATION.
+under the due process clause of the Fith
+Amendment: (1) whether the defendant
+No. CIV.1:03-MD-01539.
+has sufficient minimum contacts with the
+United States District Court,
+United States and (2) whether the exer-
+D. Maryland.
+cise of jurisdietion over the defendant
+would offend traditional notions of fair
+Dec. 21, 2004.
+play and substantial justice. U.S.C.A.
+Background: Investors brought consoli- Const.Amend. 5.
+dated securities fraud actions arising out 2 Federal Courts 6=86
+of an approximately $ 1.1 billion restatemant of aries together at me e
+To satisfy the minimum contacts test
+billion reduction in revenue, announced by for personal jurisdietion over a foreign de-
+Netherlands company involved in super- fendant, a plaintiff must demonstrate that
+market and food service business in the the defendant either: (1) engages in sys-
+United States. Named as defendants were tematic or continuous activities in the
+the company, its American subsidiaries, United States, and thus general jurisdicauditors, underwriters, and individual ex- tion exists: or (2) purposefully directs his
+ecutives. Defendants filed multiple motions actions at the United States and the litigato dismiss.
+tion arises from or is related to those
+Holdings: The District Court, Blake, J.,
+actions, and thus specifie jurisdiction exits.
+held that:
+4. Federal Courts €-76.10
+(1) subject matter jurisdiction existed over
+In determining whether specific persecurities fraud claims asserted by forsonal jurisdiction exists, district court coneign purchasers of shares on foreign
+siders: (1) the extent to which the defenexchanges;
+dant has purposefully availed himself of
+(2) plaintiffs stated securities fraud claims the privilege of conducting activities in the
+against chief officers of Dutch compa- state; (2) whether the plaintiff's claims
+ny;
+arise out of those activities directed at the
+(3) allegation in complaint were sufficient state; and (3) whether the exercise of perto state market manipulation claims sonal jurisdiction would be constitutionally
+reasonable.
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/c605c49357dee7b2982a5655eaa4b188ecc940e675c45998f3b5d1fcb02afafc.receipt.json b/vision-fixhub/ds9-unparsed-05/c605c49357dee7b2982a5655eaa4b188ecc940e675c45998f3b5d1fcb02afafc.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0f3c228bbadb77c72dbe04a97191d5a1438c0a18
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c605c49357dee7b2982a5655eaa4b188ecc940e675c45998f3b5d1fcb02afafc.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -7776,
+  "dataset": "marble-joined",
+  "doc_id": "c605c49357dee7b2982a5655eaa4b188ecc940e675c45998f3b5d1fcb02afafc",
+  "engine": "marble-apple-vision",
+  "event_count": 592,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "721fe721ecf51cad94d301325d6ca573f7fa379cd1f672c710e53bf5cee18edb",
+  "output_sha256": "7cbed4b6101d108e9b37fd05cf3c9be6c57f1df60c915482ca85b0578ec89851",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c61a58b37ecd2df322d36d1e4595a170b735ce8105dbbe1aaced20947667ece5.md b/vision-fixhub/ds9-unparsed-05/c61a58b37ecd2df322d36d1e4595a170b735ce8105dbbe1aaced20947667ece5.md
new file mode 100644
index 0000000000000000000000000000000000000000..67a4eea5afc0466b53446ec621d3593827944b6c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c61a58b37ecd2df322d36d1e4595a170b735ce8105dbbe1aaced20947667ece5.md
@@ -0,0 +1,51 @@
+OLY-38
+
+
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+TO: Perry Bard, DC
+Health First Chiropractic Center
+West Palm Beach, FL 33409
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-38
+SUBPOENA FOR:
+x PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 13, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+All documents referring or relating to Jeffrey Epstein, including but not limited to billing statements,
+record of payments, appointment books, treatment notes, and correspondence.
+*Please coordinate your compliance
+vour annearance with Special Agen
+ad confirm the date and time, and location of
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+DATE:
+March 2, 2007
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the United States of America
+*If not applicable, enter "none."
+* FLORIDA
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. ET. 33401-6235
+Te
+Fal
+To be used in lieu of AO 10
+FORM ORD-227
+JAN.86
diff --git a/vision-fixhub/ds9-unparsed-05/c61a58b37ecd2df322d36d1e4595a170b735ce8105dbbe1aaced20947667ece5.receipt.json b/vision-fixhub/ds9-unparsed-05/c61a58b37ecd2df322d36d1e4595a170b735ce8105dbbe1aaced20947667ece5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9478cad68598a6ffdcc0f57fdff4883d45743932
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c61a58b37ecd2df322d36d1e4595a170b735ce8105dbbe1aaced20947667ece5.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "c61a58b37ecd2df322d36d1e4595a170b735ce8105dbbe1aaced20947667ece5",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "68ec78643d6a01495e6bdc4a40a90fe49f63c0b077d8ff3c63eafd39c30a3412",
+  "output_sha256": "ee8d97330e7f7b81ab977f0ab47bd03df85f37d03f75f675b63fc464114d790b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c6466e428a90ba9db437c65e0f4181719e019a4f8d911df43afbd7662551d718.md b/vision-fixhub/ds9-unparsed-05/c6466e428a90ba9db437c65e0f4181719e019a4f8d911df43afbd7662551d718.md
new file mode 100644
index 0000000000000000000000000000000000000000..e54ab404cede31db603b0e3a38b29123f05b0461
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c6466e428a90ba9db437c65e0f4181719e019a4f8d911df43afbd7662551d718.md
@@ -0,0 +1,5051 @@
+New York County Clerk's Index No. 30129/2010
+Net Burk Supreme Omurt
+APPELLATE DIVISION-FIRST DEPARTMENT
+PEOPLE OF THE STATE OF NEW YORK,
+-against
+JEFFREY E. EPSTEIN,
+Respondent,
+Defendant-Appellant.
+APPENDIX
+CYRUS R. VANCE, JR.
+NEW YORK COUNTY DISTRICT
+ATTORNEY's OFFICE
+JAY P. LEFKOWITZ
+SANDRA LYNN MUSUMECI
+KIRKLAND & ELLIS LIP
+:
+Attorneys for Respondent
+Attorneys for Defendant-Appellant
+REPRODUCED ON RECYCLED PAPER
+
+
+
+
+TABLE OF CONTENTS
+Appellant's Pre-Argument Statement, dated February 9, 2011.............. A1
+Appellant's Notice of Appeal, dated February 9, 2011 .................... A3
+Order Appealed From, dated January 18, 2011 with Notice of Entry........ A4
+Palm Beach Police Department - Probable Cause Affidavit of
+Det. Joe Recarey - Defendant
+dated May 1, 2006
+Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein,
+dated July 23, 2006 ............
+A28
+2006 Grand Jury Indictment of Felony Solicitation of Prostitution -
+Jeffrey E. Epstein.
+A29
+Information for Procuring Person under 18 for Prostitution -
+Jeffrey E. Epstein, dated June 26, 2008
+A31
+Guilty Plea for Felony Solicitation of Prostitution and Procuring
+Person under 18 for Prostitution - Jeffrey E. Epstein,
+dated June 30, 2008.............
+A32
+udgment tor Procuring Person under 18 for Prostitution
+effrey E. Epstein. dated June 30, 200
+.......... A33
+Sentence for Procuring Person under 18 for Prostitution -
+Jeffrey E. Epstein, dated June 30, 2008
+... A34
+Community Control Standard Conditions, dated June 30, 2008.
+A35
+Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein,
+dated June 30, 2008........
+A47
+
+
+ii
+Order Granting Jeffrey E. Epstein's Motion for Travel,
+dated December 18, 2009 .....
+A48
+Letter from Florida Department of Corrections Regarding Termination
+of Supervision, dated July 21, 2010..
+A49
+Letter from Palm Beach Sheriff's Office Regarding
+Jeffrey Epstein's Participation in the Work Release Program,
+dated August 12, 2010 ........
+......
+...
+A50
+Letter from Jack A. Goldberger to NYS Sex Offender Registry
+Regarding Florida Registration Level applicable to
+Jeffrey E. Epstein, dated August 12, 2010
+.. . ...
+A51
+Letter from Martin G. Weinberg to NYS Board of Examiners of
+Sex Offenders Regarding Level and Designation Determination
+for Jeffrey Epstein, dated August 16, 2010
+A53
+Letter from Stephen R. Alexander, Psy.D. to Jack Goldberger
+Regarding Opinion of Jeffrey E. Epstein, dated August 16, 2010..
+A58
+Recommendation of Board of Examiners of Sex Offenders, Including
+Risk Assessment Instrument, dated August 19, 2010 and Case
+Summary, dated August 23, 2010
+A62
+etter trom Supreme Court attaching Notification, Recommendatio
+nd Notice of Right to Appeal, dated August 26, 201
+.....
+A67
+Letter from Supreme Court to Jeffrey E. Epstein informing of SORA
+Level Determination Hearing, dated August 26, 2010
+............... A68
+Order Sheet for Jeffrey Epstein, dated August 26, 2010..................
+A69
+Letter from Supreme Court to Counsel Informing of
+SORA Level Determination Hearing (with attachment),
+dated August 26, 2010 ........
+. -**** *
+A71
+
+
+iii
+Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz Requesting a
+Continuance of the Hearing, dated September 9, 2010.
+A77
+Letter from Supreme Court to Sex Offender Registry Unit Enclosing
+Final Determinations, dated January 19, 2011
+A78
+Court Action Sheet - Jeffrey Epstein, No. 30129-2010..........
+A80
+Handwritten Notations on Court Jacket - Jeffrey Epstein,
+No. 30129-2010 ....................
+.........................A81
+Transcript of SORA Hearing, dated January 18, 2011 .......•…......... A82
+
+
+
+
+Al
+Appellant's Pre-Argument Statement, dated February 9, 2011
+Ipp. A1-A2]
+SUPREME COURT FOR THE STATE OF NEW YORK
+COUNTY OF NEW YORK
+PEOPLE OF THE STATE OF NEW YORK,
+Plaintiff-Respondent,
+Index No.: 30129-2010
+- against -
+JEFFREY E. EPSTEIN,
+PRE-ARGUMENT STATEMENT
+Defendant-Appellant.
+1. TITLE OF ACTION: As set forth in caption.
+2. FULL NAMES OF ORIGINAL PARTIES AND ANY CHANGE IN THE PARTIES
+is set forth in caption. There has been no change in the parties
+3. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR APPELLANT
+OR PETITIONER:
+Jay P. Lefkowitz, P.C.
+elephone
+acsimil
+4. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR
+RESPONDENT:
+CYN R. VanDASTRICT ATTORNEY'S OFFICE
+Telephone:
+5. COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL
+IS TAKEN: New York Supreme Court (Criminal Term), New York County.
+6. THE NATURE AND OBJECT OF THE CAUSE OF ACTION OR SPECIAL
+PROCEEDING: Sex Offender Registration Act (SORA) hearing, pursuant to Article 6-C of the
+Correction Law.
+7. RESÜLT REACHED IN THE COURT OF ADMINISTRATIVE BODY BELOW:
+Supreme Court, New York County, adjudged appellant Jeffrey E. Epstein to be a Level 3 sexual
+offender, without additional designation.
+GROUNDS FOR SEEKING REVERSAL, ANNULMENT, OR MODIFICATION: The
+Court's designation of appellant Jeffrey E. Epstein as a Level 3 sexual offender was an abuse of
+
+
+A2
+discretion and constituted reversible legal error based, in part, on the following: (1) the Court
+improperly relied on untrustworthy double and triple hearsay contained in the recommendation
+of the Board of Examiners of Sex Offenders, even though the District Attorney, as the party
+appearing on behalf of the State, rejected much of the Board's recommendation as not
+constituting clear and convincing evidence to support a Level 3 designation where such hearsay
+allegations were rejected as a basis for state prosecution; (2) the Court failed to provide th
+parties with an opportunity to present evidence on contested issues, as required by statute, an
+instead relied wholesale upon the recommendation of the Board, over the objection of the
+District Attorney, without any inquiry; (3) the Court did not apply the guidelines established by
+the Board, as required by statute; and (4) the Court failed to set forth the findings of fact and
+conclusions of law on which its determinations in support of a Level 3 designation were based,
+as required by statute.
+9. THERE IS NO RELATED ACTION OR PROCEEDING NOW PENDING IN ANY
+COURT OF THIS OR ANY OTHER JURISDICTION.
+10. THERE IS NO ADDITIONAL APPEAL PENDING IN THIS ACTION.
+Dated: February 9, 2011
+Lefkowitz, P.C.
+Sandra Lynn Musumeci
+KIRKLAND & ELLIS LLP
+601 Lexington Avenue
+New York, New York 10022-4611
+Telephone
+facsimile
+Attorneys for Defendant-Appellant Jeffrey E.
+Esptein.
+-2-
+
+
+. "
+:
+A3
+Appellant's Notice of Appeal, dated February 9, 2011
+SUPREME COURT FOR THE STATE OF NEW YORK
+COUNTY OF NEW YORK
+THE PEOPLE OF THE STATE OF NEW
+YORK,
+Plaintiff,
+NOTICE OF APPEAL
+Index No. 30129-2010
+CRIMINAL TERM PART 66
+JUSTICE RUTH PICKHOLZ
+- against -
+JEFFREY E. EPSTEIN,
+Defendant.
+PLEASE TAKE NOTICE that the above named defendant, Jeffrey E. Epstein, hereby
+appeals to the Appellate Division of the New York Supreme Court in and for the First
+ії. -
+Department, from an order entered in the above entitled action in the office of the Clerk of New
+York County on the 18th day of January 2011, which order adjudged defendant Jeffrey E.
+Epstein to be a Level 3 sexual offender pursuant to Article 6-C of the Correction Law, and this
+appeal is taken from each and every part of that order as well as from the whole thereof.
+Dated: February 9, 2011
+To:
+Clerk, New York County
+NEW RUK DISTRICT ATTORNEY'S
+OFFICE
+One Hogan Place
+New York, NY, 10013
+Telephone:
+Shira Lynn Miusumeci
+KIRKLAND & ELLIS LLP
+Attorneys for Defendant
+Jeffrey E. EPs
+FILED
+FEB 0.92011
+SUPREME COURT
+NEW YORK COUNTY
+APPRALE FUNKAU
+
+
+A4
+Order Appealed From, dated January 18, 2011 with Notice of Entry
+Ipp. A4-A5]
+TO
+FROM:
+ARE
+STATE OF NEW YORK
+BOARD OF EXAMINERS OF SEX OFFENDERS
+D:4 TOWER PLACE VE
+ALBANY, NEW YORK 12203-3764
+NEWYORK COUNT SUPREME COURT
+SARDEXAMINER STEPHEN D: WEBER SDW
+REPORTED ADDRESSA
+NEWTORIN 10021
+DATER
+r8492010
+NYSIDE OR BOARD IDE AOS 969
+ASUPERVISING OFFICER:
+SUPERVISING AGENCY:
+NONE OFFENDER IS UNSUPERVISED
+The above referenced individual has committed an offense in another Jurisdiction and, has established Testende la Nat
+Yoik State at the address indicated, It hs been determined thát, the offender is required to register and be liKe sossed
+as a sex offender in New York State.
+The NYS Board of Examiners of Sex Offenders is recommending a risk level and designation for the offender, asundicated
+onthe attached risk assessment instrumen, case summäry and designation form. Pursuant lo Coffection Law Seetich
+168 k(2); the County or Supreme Court in the county of residence of the offender shall determine the offender chiskavel
+and desighations The Court musts defermine whether, the offender meets the definilion, of sexually Violeht-bifehde
+predicate sex offénder or sexual predator as set forth in Correction Law Section 168-a(7)-
+Please note: pursuant to Chapter 684 of the Laws, of 2005; as of October o0s
+and 168-n have been amended, to provide that the Court shall conduct the, risk level and designation hearing i the se
+offender, having been given notice including the date, time, and place of the proceeding fails to appear, without sufficent
+excuse. Please hote that until the court determines the offender's risk level, no community notification can occult
+A copy of the order, setting forth the risk level and designation determinations, and the rindings and conclusions stlaw B
+which such determinations are, based, shall be submitted to the Division of Criminal Justice Services Sex Offender
+„Registry Unit by the Court/ In addition, please complete, andjattach this form indicating; the offender's risk lever ans
+designation to the Courts order. Please distribute the remaining copies as indicated bejav
+Information below is to be completed by Sentencing Court
+FINAL RISK LEVEL DETERMINATION (circle one)
+2
+DESIGNATION: Please check any that apply pursuant to Article 6-Crof the NYS Correction Lawa
+Sexually Violent Offender:
+-Sexual Predator
+Predicaté Sex Offendere
+A No such designa
+Judge's Name, (please print):
+Judge's signature:
+Date signed:
+WHITE COPY: Sax Offender Registry. Unit 9
+DCUS, 4 tower: Pi. Albany, NY 12203)
+YELLOW COPY:. Cour
+PINK CoPY Offender
+
+
+A5
+SUPREME COURT FOR THE STATE OF NEW YORK
+COUNTY OF NEW YORK
+THE PEOPLE OF THE STATE OF NEW
+YORK,
+Plaintiff,
+- against -
+JEFFREY E. EPSTEIN,
+Defendant.
+NOTICE OF ENTRY
+Index No. 30129-2010
+CRIMINAL TERM PART 66
+JUSTICE RUTH PICKHOLZ
+PLEASE TAKE NOTICE that the within is a copy of an order entered in this action on
+the 18th day of January 2011, in the office of the Clerk of the County of New York.
+Dated: February 9, 2011
+To:
+Clerk, New York County
+Cyrus R. Vance, Jr.
+NEW YORK DISTRICT ATTORNEY'S
+OFFICE
+One Hogan Place
+New York, NY 10013
+Telephone:
+Lefkowitz, P.C.
+Sandra Lvnn Musumeci
+Telephone:
+Facsimile:
+Attorneys for Defendant Jeffrey E. Epstein
+FILED
+FEB 0.9 2011
+SUPREME COURT
+NEW YORK COUNTY
+APPEALS BUREAU
+
+
+A6
+Palm Beach Police Department - Probable Cause Affidavit of I/
+dated May 1, 2006
+Ipp. A6-A27]
+Agency ORI# FLO 500600
+Police Casell: 05-368 (2)
+- Defendant
+Defendant:
+Racc/Scx:
+DOB:
+Charges:
+White Female
+05-25-1975
+Principal in the 1" Unlawful Sexual Activity with a Minor (4) counts
+Principal in the 1" Lewd and Lascivious Molestation (1) count
+From March 15, 2005, through February 2006, the Palm Beach Police Department conducted a sexual
+battery investigation involving Jeffrey Epstein,
+and
+Sworn taped statements were
+taken from five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place
+at the residence of Jeffrey Epstein, 358 Bl Brillo Way, Palm Beach. Several of the victims were recruited by and
+brought to the residence by
+to perform massages for Epstein, for which
+received
+monetary compensation: During the visit they would be introduced to
+Epstein's assistant, who in
+tum would record their telephone numbers and name. The victims would be brought to Epstein's bedroot to
+provide the massage. Epstein would enter the room and order the victims to remove their clothing to provide the
+massage. As the victims complied and provided the massages, Epstein would rub his fingers on their vaginas.
+On occasion, Epstein would introduce a massager/vibtator and rub the victims vaginas as they provided the
+massage. On three separate occasions, Epstein had intercourse and inserted his penis/fingers in the victims
+vaginas. At the conclusion of the massages the victims were paid sums of money ranging from $200 - $1,000.
+The facts, as reported, are as follows:
+On 03/15/2005, A fourteen year old white female, hereinafter referred to as
+and
+her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. SG
+• reported that a subject known to her as "Jeff" had touched her vaginal area with a vibrator/massager while within
+his residence. "Jeff" was later identified as Jeffrey Epstein through a photo line up.
+During a sworn taped interview,
+tated that
+a cousin o
+boyfriend and classmate at Roval Palm Beach High School, worked for a wealthy man and did sexual favors for
+him. She also admitted that
+had offered her an opportunity to make money.
+During the beginning of
+the month of February 2005
+plained that she was first approached by
+to go with her to Epstein's
+house. SG stated that
+along with a Hispanic female, later identified at :
+pick her up at
+her father's house on a Sunday.
+las not sure of the exact dates but knew it was a Sunday.
+told her
+fathet that they were going shopping but in reality
+drove them to Palm Beach. During the drive a
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det Joe Recarcy, who is personally known to rue.
+State of Florida
+County of Palm Beach
+Signature of Police Officer (F.S.S. 117.10)
+Signature
+05/07/2006
+resting Officer
+Pagel of22
+
+
+A7
+Agency ORX FLO 500600
+conversation occurred between
+and
+whercas
+she should say she was eighteen. It was later confirmed by thi
+on February 6, 2005. According to SG's father,
+reportedly tole...
+that if Jeff asked her age,
+a.tather that
+picked his daughter up
+drove a pick up truck.
+described Epstein's house as a two-story pink house with a Cadillac Escalade parked in the
+driveway. She recalled that Jeff's house was on a dead end street. Upon arriving at the house
+tated that
+they walked up a driveway, past what appeared to be a small guard/security room. A male approaching them
+asking what they wanted.
+stated they were there to see Epstein. The male allowed them to continue
+walking up to the house
+stated the man told them that Epstein was not there but was expected back. He
+allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside.
+Shortly thercafter, Epstein and his assistant, described as white female with blond hair and later identified as
+, entered the kitchen. Epstein introduced himself to ....
+-described Epstein as being
+approximately forty-five ycars old, having a long face and bushy eyebrows, with graying hair.
+and Epstein left the kitchen leaving|
+alone in the kitchen. They retumed a short time later.
+They all spoke briefly in the kitchen.
+was instructed to follow
+upstairs.
+recalled walking up a
+flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there.
+was a larac hathroom to the right and a hot pink and green sofa in the room. There was a door on each side of
+the sofa.
+called there being a mural of a naked woman in the room, as well as several photographs of
+naked women on a shelf.
+told the victim that Epstein would be up in a second.
+Epstein entered the room wearing only a towel and told
+to take off her clothes.
+stated Epstein
+was ster when he told her to take off her clothes.
+said she did not know what to do as she was the only one
+there in the room so she took off her shirt leaving her bra on. Epstein had removed his towel and told the SG to
+take off everything
+stated Epstein was nude when he took his towel off, placing it on the floor as he laid
+down on the table.
+dated she then removed her pants leaving her thong panties on. Epstein then instructed
+her to give him a massage poi
+nto a specific lotion for her to use. As
+began to give Epstein the massage,
+he told her to get on his back.
+stated she straddled herself on Epstein's back whereby her exposed buttocks
+were touching Epstein's bare buttocks.
+said Epstein was specific in his instruction to her on how to massage
+him, telling her to go clockwise or counter clockwise, Epstein then turned over and instructed
+to massage his
+ches
+as now standing on the ground and resumed massaging Epstein's chest area.
+fated Epstein, held
+onto the small of her back as she massaged his chest and shoulder area. Epstein then turned to his side and
+started to rub his penis in an up and down motion. Epstein then pulled out a purple vibrator and began to
+The foregoing instrument was sworn to or affirmed
+before me this 1"' day of May, 2006 by
+Det Joe Recarcy, who is personally known to me.
+Oh 1 fucky
+Signature of Police Officer (F.S.S. 117.10)
+State of Florida
+County of Palm Bench
+Signature/A
+ting Officer
+05/61/2006
+Page 20f22
+
+
+A8
+Agency ORI# FLO 500600
+sage
+vaginal arca.
+ated there was no penetration as the vibrator was on top of her underwear.
+recalier Epstein ciaculating because he had to use the towel to wipe himself as he got off the table. Epstein
+then left the room and
+got dressed. She went back downstairs where she met with
+said she
+was paid three hundred dollats in cash from Epstein. Before she left. Epstein asked
+to leave her phone
+number. As
+and Figueroa were leaving the house,
+told
+she received two hundred
+dollars that day for bringing her.
+During the course of the investigation, parental consent was granted f
+o assist with the
+investigation. At our directior
+conducted controlled taped phone calls to
+cellular telephone 561-
+308-0282
+poke with
+in an attempt to arrange another meeting with Epstein.asked
+what did she need to do to make more money.
+stated, "the more you do, the more you get paid."
+had subsequently called back
+nd lefl a voice mail message for her indicating that she had set up an
+annointment folace to go to Epstoin's house at 11:00 am on April 5, 2005. This message was recorded from
+s voice mail.
+Based on the above, trash pulls were established at Epstein's residence with Supervisor Tony Higgins of
+the Sanitation Bureau of the Town of Palm Beach. The trash puil from April S, 2005 revealed a telephone
+message for Epstein which stated Halcy an
+s name at 11:00 am. This was the time frame:
+had
+informe
+to be ready to go work at Epstein's house.
+On October 3, 2005, Sgt Frick and I went to
+residence and viewed her vehicle parked in the
+driveway, a red Dodge Neon. Sgt. Frick and I knocked on the door and met with
+was
+told that we were investigating a olaim involving Jeffrey Epstein of Bl Brillo Way, in Palm Beach.
+was
+asked if she would accompany us back to the police station for furthet questioning. She was also told that at the
+conclusion of the interview she would be returned home.
+voluntarily came with us back to the Palt
+Beach Police Department.
+Upon our arrival at the police station,
+was brought to the intervicw room in the Detective Bureau
+where I obtained a taped, swarn statement. I began the interview by asking
+how she became
+acquainted with Epstein.
+stated that approximately two years ago, just after she turned 17 years of age,
+she was approached by a friend named
+at the Canopy Beach Resort in Rivera Beach,
+was asked
+if she wanted to make money. She was told she would have to provide a massage and should make $200.00.
+thought about the offer and agreed to meet with Jeffrey.
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det Joe Recarcy, who is personally known to me.
+Signatire of Police Officer (E.S.S. 117.10)
+State of Florida
+County of Palm Beach
+Signaturari
+Pesting Officer
+Page 3nf 22
+
+
+A9
+Agency ORI# FLO 500600
+(Unknown last name) and
+(Unknown last name) picked
+up and she was taken to
+Epstein's house. Upon her arrival to the house she was introduced to Epstein in the kitchen of the house. She
+was also introduced to a white female known to her as
+. She was led upstairs to the main bedroom known
+to her as Jeff Epstein's bedroom.
+arranged the massage table and covered the table with a sheet. She
+brought out the massage oils and laid them next to the massage bed. I
+then left the room and informed
+Jeff would be in, in a minute. Jeff entered the bedroom wearing only a towel. He removed the towel
+and laid nude on the massage table. He laid on the table onto his stomach and picked a massage oil for
+to rub on him. During the massage, [
+stated "He tried to touch me and I stopped him." 1 asked how he
+tried to touch her.
+stated that Epstein grabbed her buttocks and she felt uncomfortable.
+told
+Epstein, I'll massage you but I don't want to be touched.
+stated she performed the massage naked. At
+the conclusion of the massage, Epstein paid
+$200.
+After the massage Epstein stated to
+that he understood she was not comfortable, but he would
+pay her if she brought over some girls. Fle told her the younger the better.
+stated she once tried to bring
+a 23 yeat old female and Epstein stated that the female was too old.
+stated that in total she only
+remembers six girls that she brought to see Epstein, each time she was paid $200.
+stated she bad
+brought the following gin
+h16 year old female),
+La 16 year old
+female) and
+said that at the time she brought these girls to Epstein's house they were alll 4
+through 16 years of age. I asked
+which one was the youngest.
+advised SG was the youngest as
+she was fourteen when the massage occurred.
+stated every girl she brought knew what to expect when
+they arrived. They were told they would provide a massage, possibly naked, and allow some touching. I asked
+was aware. She stated every girl che brought know what to expect. She explaind he knew that
+wanted to make money. She approached
+and explained about going to work fot Jeff,
+agreed and
+arrangements were made to bring her to Epstein's house on a weekend.
+stated that she and
+(Later identified as ....
+-p......) picked upl
+at her house.
+stated that at that time she was driving
+a red pickup truck. They traveled to Epstein's house and entered through the kitchen door. They met with the
+house chef and Epstein's assistant
+was introduced to Epstein while they were in the kitchen area.
+led
+upstairs and Epstein went upstairs. When the massage was over
+returned to the kitchen area.
+| stated she was paid $200.00 for bringing
+to Epstein's house.
+stated
+told her she was
+paid $300.00 for the massage.
+stated the
+number to avoid being contacted by
+vas the last person she brought to Epstein's house. She had changed her cellular
+She continued stating that she had no direct contact with Epstein
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det Joe Recarey, who is personally known to me.
+State of Florida
+County of Palm Beach
+Signature of Police Ófficer(F.S.S. 117.10)
+Page Yof 22
+
+
+A10
+Agency ORK FLO 500600
+. when he was going to travel to Palm Beach.
+said when Epstein announces to his assistant,
+that
+he is traveling to Palm Beach,
+would then contact
+to arrange girls to "work" for Epstein.
+stated that once her parents discovered that she was visiting Epstein thev disapproved of the encounters with him
+and she stopped.
+further stated that
+still tries to call
+'s house and leaves messages.
+Sgt Frick entered the room and explained to
+that based on her own statements, she had
+implicated herself by bringing underage girls to Epstein's house.
+provided cellular telephone numbers for
+the girls she had mentioned previously. Additionally, she also provided possible addresses and arcas in which
+they lived.
+As
+was being taken home in the vehicle, a tape recorder was nlaced within the vehicle to record
+any conversations within the vehicle. During the drive back to her home,
+made the comment "I'm like
+a Heidi Fleiss." (Hollywood Madam who sent girls to clients for sexual favors in California).
+was
+dropped off at her house without incident.
+On October 3, 2005,
+and I went to speak with
+sixteen year-old female who was
+brought to Epstein's residence by
+We met with
+mother at their front door. We explained
+the ongoing investigation and asked to speak with JS as we had information that she had "worked" for Jeft.
+•Mrs. St introduced us to her husband and allowed us entry into the home. We sat in the dining room and met
+As she was under the age of eighteen, Mrs S was advised we would be
+speaking with her. She expressed if her daughter had information, she wanted to assist, We interviewed
+who
+denied having any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeff's house with
+approximately eight months ago and sat in the kitchen with the house chef, but nothing happened.
+As the parents were present during the interview, we felt that
+was withholding information from us. She made
+several comments as to putting the entire incident behind her. I left my telephone number and advised should she
+wish to speak with me again to telephone me.
+and I thanked Mrs. S for her time and left the area. She
+stated she would ask
+gain after we left as to what happened at Epstein's house. I. informed her thal
+had
+my telephore number and hopefully she would call.
+On October 4, 2005, Det Dawson and I drove to the " ' " home and met with ...
+-
+and
+During a sworn taped statement,
+stated approximately a year ago.
+when she was seventeen years old, she was taken to a house by
+. stated she knows
+because they both attend Royal Palm Beach High School. She was told she could make money working
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det Joe Recarey, who is personally known to me.
+Ca. 1. Judiyi
+Signature of Police Officer (T.S.S. 117.10)
+State of Florida
+County of Palm Beach
+Signatur
+esting Officer
+Page Sof 22
+
+
+A11
+Agency ORI# FLO 500600
+for Jeff. She was told she would have to provide a massage to Jeff. C.,.- stated upon her arrival to the house
+. she was brought to the kitchen area by
+• They met with the house chef who was already in the kitchen
+area..
+stated
+would wait for her in the kitchen. ! was introduced to|
+,, Jeff's
+assistant, who brought her upstairs to the master bedroom.
+prepared the room and massage table for a
+massage. Epstein entered the room wearing only a towel and she provided a massage.
+* " stated she kept
+her clothes on during the massage. She advised sometime during the massage, Epstein grabbed her buttocks and
+pulled her close to him. I
+... said she was uncomfortable by the incident involving Jeff. At the conclusion of
+the massage, she was paid $200.00 for the massage. I asked...
+... if she has any formal training in massages to
+which she replied no. I asked her if
+received any monies for taking her to perform the massage.
+stated
+had received money for taking her there but was unsure in the amount.
+'c stated she
+returmed to Epstein's house on another occasion with
+and another girl
+i stated
+she waited in the kitchen with
+, while =
+im was taken upstairs by
+i stated she only did the
+nassage once as she was uncomfortable with the whole experience.
+At the conclusion of the interview, the tape was stopped. I was informed that
+had attempted to
+reach
+*: via cell phone. A voice mail message on October 4, 2005 at 10:59 am, revealed a female voice
+who identified herself as
+who requested:
+• to call her back reference the police questioning. -
+provided the incoming telephone number as
+stated she inadvertently told....
+about the police investigation because .
+had called her to tell her about how she just received a rental car
+from Jeff Epstein.
+had called her to tell her that she was given a rental car, a 2005 Silver Nissan Sentra,
+to utilize to visit family and visit Epstein. -
+asked her what was going on at the house that the police would
+be asking questions.
+stated*
+. then called Jeff and
+and asked what was going on
+reference the ongoing police investigation. According to
+has since then been trying to contact her
+to ask about the police questions. I instructed
+not to contact
+and do not provide any more
+information to...
+as she would notify Jeff Epstein and
+what was transpiring.
+On Ootober4, 2005, I made telephone contact with
+who had left several messages for me to contact
+her. During the message, she advised she was not completely truthful when we met in person but would like to
+speak with me to advise what had happened. She further advised she did not want to speak of this incident in
+front of her mother. At approximately 3:48 pm I made telephone contact with During a taped recorded
+statement JS stated the following: approximately a year ago, when she was sixteen years of age,
+I took her
+to Epstein's house twice, She knows
+because they both attend Royal Pal Beach High School. The first
+time she went,
+drove to the house. They entered through the kitchen area where she was
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det Joe Recarcy, who is personally. Known to me.
+State of Florida
+County of Palm Beach
+Signature Arresting Officer
+Signature of Police Officer (F.S.S. 117.10)
+Pagebof 22
+
+
+A12
+Probahle Cause Affidavit
+Agency ORIN FLO 500600
+introduced to
+and Epstein. She was taken upstairs to a bedroom by
+who set the room up with a
+massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the
+table and picked out a lotion fo
+to rub on him. At one point during the massage he tried to remove her shirt,
+at which point she became very upset and discontinued the massage. Both
+and Epstein had a verbal
+disagreement, at which time she left without being paid. She got with
+who was sitting in the
+kitchen and told her "let's go." advised she received no money for that day.
+Iso said that
+had told her if she was uncomfortable with what was going on, to let him know and he'll stop. She knew that the
+more you do the more you get paid.
+dvised that several wecks later she agreed to be taken a second time
+by
+. Once they arrived at the residence,
+sat in the kitchen and
+took her
+upstairs to the taster bedroom again.
+set the room up with a massage bed and brought out the oils to
+use. Epstein then entered the room wcaring a towel. He laid on the table and picked out a lotion fot
+on him. At one point during the massage he tried to touch ber buttocks. Asl
+vas wearing tight jeans and had a
+tight belt on Epstein was unable to touch her buttocks. Epstein then rolled onto his back during the massage and
+then attempled to touch her breasts
+then became upset again and told Epstein she didn't want to be touched.
+liscontinued the massage and was paid $200.00
+then went downstairs where
+was waiting
+for her. She told
+she yanted to leave.
+said she never returmed to the house.
+ated she is aware
+that her friend, -
+S was also at the house and had a problem with Epstein.
+I later rescarched
+:, dob
+, and met with her at her residence. During a sworn
+taped statement,
+stated the following: on or about November 2004, she was approached at Royal Palm
+Beach High School by
+,, a fellow student.
+asked" if she wanted to make money.
+She agreed and was told she would provide a massage to wealthy man in Palm Beach.
+picked her up
+and drove her to a house in Paim Beach. She was brought into the kitchen area of the house. She further stated
+that fellow Royal Palm Beach High School students
+and
+) came with them. They were
+brought into the kitchen where she was introduced to Epstein and other females. _.
+:stated she was
+introduced to a female helper of Epstein, the female was described as white female (unknown name ), with
+blond hair. She stated that the assistant was familiar with
+The assistant brought her upstairs into a
+master bedroom area. The assistant set up the massage table and put out lotions to be used. She told"
+Epstein would be available in a minutc. Epstein entered the room wearing only a towel. Epstein removed his
+towel, and laid naked on the massage table and picked a lotion to rub on his thighs and back..
+| further
+stated during the massage, Epstein asked her to remove her clothes. She complied and removed her pants and
+blouse.
+didn't remember if she had removed her bra but feels that she did. :.
+. was certain that she
+stayed in her thong underwear.
+continued the massage and at one point she climbed onto the massage
+The foregning instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det Joe Recarey, who is personally known to me.
+perion
+Signature of Police Officer (F.S.S. 117.10)
+State of Florida
+County of Palm Beach
+Signature Akrating Officer
+Page7 of 22
+
+
+A13
+Agency ORI FLO 500600
+table, straddling Epstein to massage his back. While doing this her buttocks were touching Epsteins.
+was instructed to return to the ground at which time Epstein turned to have his chest rubbed. =.
+advised she
+was sure he was masturbating based on his hand movements going up and down on his penis area.-.
+.. did
+not want to look at his penis area because she was uncomfortable. Epstein removed a large white vibrator which
+was rext to the massage table and turned it on.
+.. stated Epstein began rubbing the vibrator over her thong
+underwear on her vaginal area. Shortly thereafter, Epstein ejaculated and removed himself from the table. He
+walked over to where the shower was and opened the glass door. She waited as he was taking a shower in her
+direct view. When I asked....' how old she was when this occurred, she stated she had just turned
+seventeen, At the conclusion of the shower, i.
+: was paid either $350.00 or $400.00. She stated she
+wasn't sure, but knows it was close to $400.00.
+stated she never returned to provide a massage for
+Epstein.
+At approximately 2:10 pm, Det Dawson and I met with
+at her residence. As
+was only seventeen years of age, I had notified her mother, that she would be interviewed reference an ongoing
+investigation in Palm Beach. I assured her that het daughter was not a suspect. I explained the possibility of her
+being either a witness or victim. Mrs L advised she wanted!
+to cooperate and consented to the interview:
+During a sworn taped statement,
+stated the following: at the age of sixteen, during the month of
+September 2004, she was approached by
+for a chance to make money.
+vas friends with
+associates of
+and knew the same peopid
+had been previously told by her faends from Royal Palm
+Beach High School, what
+did for Epstein.
+called a person known to
+and
+scheduled the appointment.
+picked
+p and drove her to Palm Beach to a street called "Brillo Way".
+They drove to the end of the street and entered a large driveway. Th
+er entered the kitchen arca of the house and
+met with Epstein.
+was introduced to Jeff Epstein.
+led
+apstairs to the main bedroom area and
+set up the room with a massage table and set out the oils.
+stated that while going up the stairs and into the
+bedroom she observed numerous photographs of naked young girls.
+dimmed the lights and turned on
+soft music.
+exited the room and Epstein entered the room wearing only a towel. Epstein picked oils and
+instructed her to rub his legs, under his buttocks, back and chest area. Epstein asked her to get comfortable.
+advised she did not remove her clothes. She was wearing tight jeans and a cropped tank top exposing her belly
+area. During the massage, Epstein removed his towel and laid on the massage table naked. As L rubbed
+Epstein's chest arca, he attempted to reach down her pants to touch her buttocks area however was unable to i
+due so due to the tightness of the jeans and a tight belt.
+advised Epstein began to masturbate as she rubbed
+his chest. Epstein moaned as she rubbed his chest. She observed he was continuing to masturbate and
+The foregoing instrument was sworn to or affirnied
+before me this 1" day of May, 2006 by
+Det Joe Recarey, who is personally known to me.
+1. pestos
+Signature of Police Officer (F.S.S. 117.10)
+State of Florida
+County of Palm Beach
+Siguature A
+lesting Officer
+PageBof 22
+
+
+A14
+Agency ORI# FLO 500600
+attempted to teach up her tank top and touch her breasts
+pulled back and Epstein stopped, however he
+kept masturbating until he climaxed. He cleaned himself with the towel he was previously wearing. YL was
+paid $200.00 for the massage and left the area. She met with
+who was waiting in the kitchen area and
+left the house.
+then explained she never provided another massage for Enstein. She did however, gọ to the house
+with
+and
+-, as they took another friend of
+dvised she was present when
+• went to work for Epstein. She advised she rode over and sat in the kitchen area with
+to
+wait for "
+advised while they waited for 1.
+the house chef prepared lunch for them as it was
+almost lunchtime when they went. When ....
+was finished with the massage they left the aren. I asked
+ever told her what would be expected when she provided a massage.
+stated yes,
+told her
+that a massage would be expected, possibly naked and possibly some touching involved. YL has no farmal,
+training in providine massages.
+poke about a third and last time she went to Epstein's house.
+drove another gir
+(sixteen years of age) who is
+friend, to Epstein's house
+knew that
+had made money massaging Epstein and wanted to make money herself.
+took them in the kitohen
+area of the house and introduced ML to
+and
+toold
+upstairs to the main bedroom.
+advised she doesn't know what happened a
+did not speak about what happoned in the room.
+received
+$100.00 from
+for going with her to Epstein's house and recommending
+On October 6, 2005, at 11:45 am, I met with
+.., dob
+, at Lynn University and
+explained to her why we there to interview her. She advised she was aware of the ongoing investigation. m
+stated she had previously spoken with in, i.:
+• who told her she was interviewed by detectives. During a
+• sworn taped statement,
+stated she knew that
+worked fot Jeff Epstein in Palm Beach.
+advised she originally had been taken to the Epstein house by
+, whom she met when they both
+attended Royal Palm Beach High School. She began going to the house when she was sixteen years of age and
+stated she had been there a lot of times to provide massages over the past two years. I asked her if she had
+formal training in providing massages, which
+•stated she had not.
+advised she was told what was
+expected of her by providing massages and she would have to remove clothing but if she felt uncomfortable just
+to say-so and Epstein would stop pushing the issue, ..
+began providing massages and advised she kept her
+clothes on. She considered Epstein a pervert and he kept pushing to go further and further.
+•explained she
+would keep telling him she had a boyfriend and would not be right to her boyfriend. It wasn't until recently that
+began removing her clothes and staying in her thong underwear to provide a massage.
+explained
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det Jne Recarey, who is personally known to me.
+State of Florida
+County of Palm Beach
+Signature of Police Officer (F.S.S. 117.10)
+Signature/Arresting Officer
+Page 9of 22
+
+
+"A15
+Agency ORI FLO 500600
+Epstein wanted to be rubbed on his back and recently he began turning over and have her rub his chest as he
+masturbated. He would try to touch her breasts as she rubbed his chest. = stated "Jeff would try to get away
+with more and more on each massage"... stated Epstein would try to touch her more and on one occasion
+he attempted to usc a massager/vibrator on her.
+i drove
+to the house for the original massage. -
+left
+her cell phone number and every time Epstein would come into town,
+a would call her for an
+appointment to "work". Each time she went,
+* would meet her at the kitchen door area. She would bring
+her upstairs and prepare the massage table. -
+• advised Epstein would ask her questions about herself. Epstein
+Inew she was a soccer player and would be attending Lynn University. I asked:
+if Epstein knew het real
+1. stated Epstein did and didn't care. The most recent massage she provided was on October 1, 2005.
+During the massage, she asked Epstein if she could borrow one of his vehicles to visit her family and boyfriend in
+Orlando, Florida. Epstein had told her she could borrow one of his vehicles but later stated he would rent her a
+car. She continued with the massage as Epstein grabbed her buttocks and caressed the buttocks cheeks. I
+asked" : if she was wearing undergarments to which she replied her thong underwear. Once he tried to touch
+her breasts, she would pull away from him and he would stop.
+" was asked if he ever used a vibrator on her.
+- was aware of the vibrator but advised she never would allow him to use the vibrator on her. She described
+the vibrator as the large white vibrator with a huge head ot the tip of the vibrator. She stated he kept the vibrator
+in a closet near the massage table.
+. stated that on October 3, 2005, she was contacted by Epstein's assistant,
+, who informed her
+that Jeff Epstein had rented her a new Nissan Sentra and she should come by the house to pick it up.
+informed
+she would have the car for a month.
+• stated Epstein krew her car was not working properly
+and that she had missed appointments in the past because of her car being inoperable.
+: explained the car is
+currently parked next to the Lyon University Gym field. I asked her if she ever took any one to the house.
+explained she took L....
+;,a friend of hers who attended Royal Palın Beach High School, who has
+relocated to Orlando to attend colleg. I asked if she ever allowed another female in the room.
+:advised no
+one was brought into the room with her.
+At the conclusion of the interview, Det Dawson and I went to the gym area of Lynn University and
+located the Silver Nissan Sentra bearing Florida tag l
+The vehicle is registered to Dollar Rent a Car
+out of the Palm Beach International Airport. The vehicle was rented by Janusz Banasiack, later Iearned to be
+Epstein's houseman, and paid with Epstein's credit card.
+On September 11, 2005,
+was arrested by the Palm Beach Police Department
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det Joe Recarey, who is personally known to me.
+Signature of Police Officer (F.S.S. 117.10)
+State of Florida
+County of Palin Beach
+•Signature/Arresting Officer
+Page/Oof 22
+
+
+A16
+Agency ORI# FLO 500600
+for misdemeanor possession of marijuana. During the atrest
+cold the arresting officer that she had information
+about sexual activity taking place at the residence of Jeffrey Epstein. Additionally, during the ongoing trash pulls
+from Epstein's residence, discarded papers were found which contained
+mame and cell phone number.
+On October, 11, 2005, Det Dawson and I met wit
+and obtained a sworn taped statement.
+explained she had been going to Epstein's house since 2002, when she was sixteen years of age. Since then she
+has gone to the house hundreds of times.
+stated she became his "number one girl." She explained that on
+her first visit she was brought to the house by fellow Royal Palm Beach Hich School classmatc,:
+I said she was brought through the kitchen area where she met
+for the first time.
+was led to
+the master bedroom, Epstein s root.
+explained that as she was walking up the stairs she observed several
+photographs of naked women along the walls and tables of the house. Hall further explained that she was
+brought into the bedroom, where
+prepared the room by setting up the massage table and provided the oils
+for her to rub on Epstein.
+explained she remembered the steam room area, which contained two large
+showers. Epstein entered the room from the steam room area and introduced himself. Epstein lay on the table
+and told her to get comfortable.
+removed her skirt and kept her shirt on. Epstein then instructed her to
+remove her shirt.
+removed her shirt and remembered she was not wearing a bra.
+stated she provided
+the massage wearing only her panties. She continued rubbing his legs, thighs and feet.
+advised he tured
+over onto his back. Epstein touched her breasts and began to masturbate. Epstein ejaculated which meant the
+massage was over. At the conclusion of the massage,
+was paid $200.00. They walked togetber downstairs
+where
+and
+were waiting.
+stated
+•... received an unknown amount of
+money for taking her to Epstein. Epstein instructed to leave her cellular telephone number so that he could
+contact her when he is in town.
+stated that during her many visits a routine was established between her and Epstein. She would enter
+the house and get naked in the bedroom: She would then start with a back massage. Epstein would roll on to his
+back and allow her to massage his chest area.
+stated Epstein would then began to masturbate himself and at
+the same time would insert his fingers in her vagina and masturbate her with his fingers. AH explained Epstein
+would continue this process until he ejaculated. He would then utilize a vibrator/massager on her vagina until
+climaxed.
+advised that during her frequent visits, Epstein asked for her real age,
+atated she was sixteen.
+Epstein advised her not to tell anyone her real age.
+advised that things escalated within the home as Epstein
+would instruct and payl
+to have intercourse with his female friend,
+explained the
+intercourse included using strap on dildos, large rubber penis" and other devices that Epstein had at his disposal.
+Epstein would watch thern have intercourse and masturbate himself. Occasionally, Epstein would then join in
+State of Florida
+County of Palm Beach
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det Joe Recarey, who is personally known to me.
+One 1. Jus
+Signature of Polico Officer (F.S.S. 117.10)
+Signature/ Arresting Officer
+Pagel|of 22
+
+
+A17
+Agency ORI# FLO 500600
+during the female on female intercourse and provide oral sex to both
+the tim
+was sixteen years of age.
+and
+This occurred during
+advised this continued to escalate during two years. The routine became familiar to
+Epstein's
+assistant
+would telephone her every time Epstein was in the Town of Palm Beach and would place
+appointments for her to visit and work for Epstein. Each time something new was introduced, additional monies
+were produced and offered for
+allow the acts to happen.
+consented to perform all these acts but was
+adamant that there was an understanding with Epstein that no vaginal penetration would occur with his penis.
+explained that Epstein's penis was defored.
+explained that his penis was oval shaped.
+claimed when
+Epstein's penis was crect, it was thick toward the bottom but was thin and small toward the head portion.
+called Epstein's penis "egg-shaped."
+stated Epstein would photograph
+and her naked and
+having sex and proudly display the photographs within the home.
+rated during one visit to Epstein's house
+in which she provided a massage to Epstein, his female friend,
+,, was also present.
+provided the massage in which
+and her would fondle each others breasts and kiss for Epstein to
+enjoy. Towards the end of this massage, Epstein grabbed
+and turned ber over onto her stomach on the
+massage table and foroibly inserted his penis into her vagina.
+wated Epstein began to pump his penis in her
+vagina.
+becamic upset over this. She said her head was being held against the table forcibly, as he continued
+to pump inside her. She screated "No!" and Epstein stopped. She told him that she did not want to have his
+penis inside of her. Epstein did not eiaculate inside of her and apologized for his actions and subsequently paid
+her a thousand dollars for that visit.
+tated she knows he still displays her photographs through out the house.
+On October 12, 2005, Det Dawson and I met with...
+who stated during
+a sworn taped statement, that nothing happened between her and Epstein.
+• appeared nervous during the
+interview. I assured her that I have spoken with other people who advised differently.
+; stated on several
+occasions she provided a massage to Epstein. She stated she was brought to the Epstein house in March of
+2005.
+, a classinate at Royal Palm Beach Hieh School, approached her and asked her if she
+wanted to "work"
+i made the arrangements with
+1, Epstein's assistant.
+..... who has no formal
+training in providing massages, stated she provided a massage, fully clothed for $200.00. AsI sensed hesitancy
+in her answers, I asked
+if she had been contacted by anyone from Epstein's organizations ot his house.
+stated she was interviewed already by a private investigator for Epstein. He identified himself as "Paul".
+and inquired about the police investigation, and left his telephone number
+for additional contact.
+'provided no additional information, as it appeared her responses were almost scripted.
+The foregoing instrument was sworn to or affirmed
+before mo this 1" day of May, 2006 by
+Det Joe Rccaroy, who is personally known to me.
+1. Jargy
+Signature of Police Officer (F.S.S. 117.10)
+State of Florida
+County of Palm Beach
+Signature Arresting Officer
+Page |Zt 22
+
+
+A18
+Agency ORI# FLO 500600
+On November 6, 2005, at approximately 3:30 pm, I met with i -.....
+at the
+Palm Beach Police Department. *
+• was identified as a potential witness/victim through information
+obtained during the trash pulls. During the sworn taped statement, ....
+- advised she was at Jeffrey Epstein's
+house one time, approximately two months ago. She was approached by a girl,
+• ..: who was dating
+' roommate, for an opportunity to make some quick money. =
+i advised she needed to make some
+quick cash to make the rent that month. She agreed to go to the house. She had been told by ...
+that
+the massage would have to be done in her underwear. She advised "...'3 drove with her and brought her into the
+house. They walked into the kitchen area, and took the stairs upstairs....
+.. further stated she was brought
+into a master bedroom area. She adyised she recalled seeing portraits of naked women throughout the room. A
+massage table was already out near the sauna/shower area in the master bedroom. Epstein entered the room
+wearing only a towel and introduced himself as "Jeff." At Epstein's direction,
+i removed their
+clothing down to their panties, Epstein laid on his stomach area and they provided a massage on his legs and feet
+atca. I asked
+if she had any formal massage training and she replied "no." "
+"At Eptin's directionided a massage on his legs and feet
+..s advised she was
+topless and the panties she wore were the boy shorts lace panties. She and = " continued the massage until the
+last ten minutes of the massage, Epstein, told i_. - to leave the room so that'
+could finish the massage.
+got dressed, and left the room as Epstein turned over onto his back. Epstein then removed the towel and
+• laid naked. Epstein requested that.
+• rub his chest area.
+• stated as she did this, Epstein, began
+masturbating.
+stated Epstein pulled down her boy short panties, and he produced a large white vibrator
+• with a large head. She stated it was within his reach in a drawer in his master bathroom. He rubbed the vibrator
+on her vaginal area.
+advised he never penetrated her vagina with the vibrator. He continued to rub her
+vagina with the vibrator as he continued to masturbate.
+stated she was very uncomfortable during the
+• incident but knew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped
+himself with the towel he had on previously and went into the shower area.
+got dressed and met with
+in the kitchen aren. Epstein came into the kitchen and provider
+$200.00 for bringing
+'and
+paid $200.00 to
+for providing the massage.
+was told to leave her telephone number with
+for future contact.
+Trovided her cellular telephone number..
+was asked if she was recently
+contacted about this investigation by anyone from the Epstein organization. She replied she was called but it was
+for work. She stated she was called by
+for her to return to "work" for Epstein.
+stated "work" is
+the term used by
+to provide the massages and other things.
+advised she declined as she was not
+comfortable in providing that type of "work."
+On November 7, 2005,
+mand I met with
+sworn taped statement,
+- stated she met Jeffrey Epstein through
+During a
+when they were still
+The forgoing instrument was sworn to or affirmed
+before mé this 1" day of May, 2006 by
+Det Joe Recarey, who is personally known to me.
+State of Florida
+County of Palm Beach
+Мивір
+Sigmature of Police Officer (F.S.S. 117.40)
+Signature/Arresting Officer
+Page/30f 22
+
+
+1•1 • VA
+A19uu.
+Agency ORI# FLO 500600
+attending Royal Palm Beach High School.
+would approach females who wished to work for Epstein.
+• stated she was offered to work for Epstein but decline.
+" explained that "work" means give
+massages. She was asked about any formal training in providing massages which she said "no."
+• said
+she accompanied
+and other females who were taken to Epstein's house to provide massages. !
+further stated she had been to the house approximately 4 or 5 times in the past year. She accompanied
+with
+and.
+.. Each time the girls were taken
+over, they were previously told they would have to provide a massage, possibly naked. They were also told that
+should Epstein require them to do anything. extra, and they were not comfortable just to tell him and he would
+stop.
+• stated
+received $200.00 for each girl she brought over to massage Jeffrey Epstein.
+When I asked which girl appeared to be the youngest, she replied, who was really young, fifteen years old at
+the most.
+• further stated each time she went to the house, she sat in the kitchen and waited with
+until the massago was over. She further stated that the cook would make lunch or a snack for them as they
+waited. I asked her if there was anything that caught her attention within the home.
+stated there were a
+lot of naked girls in photographs throughout the house.
+On November 8, 2005, at approximately 2:00pm, I met with
+at the
+Palm Beach Police Department. During a sworn taped statement,
+stated she had met Epstein
+approximately two years ago when she was first approached by
+,, a classmate at Royal Palm Beach
+High School.
+approached her about working for Epstein and providing a massage to him for $200.00.
+had made the arrangements however was unable to take her the day the arrangements were made.
+had
+• also attended Royal Palm Beach High School and was familiar
+with Epstein.
+recalled sho was brought there and entered through the back kitchen door. She had met
+with an assistant
+and another assistant
+brought her upstairs as she observed several
+photographs of naked females throughout the house.
+stated Epstein came in the room, wearing only a
+towel, and laid on the table.
+stated he picked out the oils he wanted her to use and requested she
+remove her clothing to provide the massage.
+stated that on the first massage she provided she did not
+remove her clothing.
+• stated she had returned several times after that. Each time she returned it was
+more than a massage. Epstein would walk into the master bedroom/bathroom area wearing only a towel. He
+would masturbate as she provided a massage.
+stated she was unsure if he climaxed as he masturbated
+under the towel. Additionally, she never looked below his waist. She claimed that Epstein would convince her to
+emove her clothes. She eventually removed her clothes and stayed in ber thong panties. On occasion, Epsteit
+vould use a massager/vibrator, which she described as white in color and a large head. Epstein would rub the
+vibrator/massager on her vaginal area as he would masturbate.
+stated she had been to the house
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det Joe Recarey, who is personally known to me.
+Che 1. Rushes
+Signature of Police Officer (T.S.S. 117.10)
+State of Florida
+County of Palm Beach
+Page/4of22
+
+
+A20
+Agency ORI# FLO 500600
+numerous titnes.
+added she has no formal training in providing a massage.
+stated she brought
+two females during her visits to provide massages.
+stated she brought a girl named"'." ."and....
+• from Royal Palm Beach High School.
+.. stated she received $200.00 for each girl she brought.
+On November 8, 2005, I met with.
+at the Palm Beach Police
+Department. During a sworn taped statement,
+stated she had met Joffrey Epstein approximately one year
+ago. She was approached by a subject known to her as
+had asked her if she wanted to make money
+providing massages to Epstein. '
+'bad heard that several girls from Royal Palm Beach High School were
+doing this and making money. She agreed and was taken to the house by
+had introduced her to
+and Epstein and brought her upstairs to a master bedroom where a massage table was prepared and the proper
+oils were selected. AH left the room and waited downstairs for her; •....
+stated Epstein entered the room
+wearing a towel and laid on his stomach. She provided a massage wearing only her thong panties.
+advised Epstein had masturbated every time she provided a massage. She stated Epstein continued to
+masturbate until he climaxed. Once that occurred the massage was over. She felt the whole situation was weird
+but she advised she was paid $200.00 for providing the massage. She also stated
+was paid $200.00 by
+Epstein for bringing "
+stated she had gone a total of 15 times to Epstein's residence to provide a
+massage and things had escalated from just providing a massage. Epstein began touching her on her buttocks and
+grabbed her closer to him as he masturbated. Epstein also grabbed her breasts and fondled her breasts with his
+bands as she provided the massage..
+stated on one occasion, while she was only seventeen yoats of age, he
+offered extra monies to have vaginal intercourse. She stated this all occurred on the massage table.
+stated
+Epstein penetrated her vagina with his penis and began having intercourse with her until he reached the point of
+climax. Epstein removed his penis from her vagina and climaxed onto the massage table.
+• received
+$350.00 for her massage. I asked her if she had any formal training in providing massares.
+stated she did
+not.
+continued to state on one other occasion, Epstein introduced his girlfriend,
+into the massage.
+was brought into room with.
+to provide a massage. Epstein had them kiss and fondle each other
+around the breasts and buttocks as they provided a massage to Epstein. Epstein, watched and masturbated as
+this occurred. On other occasions, Epstein, introduced the large white vibrator/massager in the massage. Epstein
+stroked the vibrator/massager on
+vagina as she provided the massage.
+On November 14, 2005, Det Sandman and I met with
+During a
+sworn taped statement she advised she started going to the house approximately one year ago and has been there
+approximately five or six times.
+also stated she was sixteen years old when she first went to Epstein's
+house. On her first visit she was brought by a fellow student from Royal Palm Beach High School known to her
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det Joe Recarey, who is personally known to me.
+The 1.-perstag
+Signature of Police Officer (F.S.S. 117.10)
+State of Florida
+County of Palm Beach
+Page /9822
+
+
+A21
+Agency ORIN FLO 500600
+as
+itated
+• brought her into the house and she was introduced to
+n then
+brought her upstairs into a master bathroom, located within the bedroom.
+stated she met Epstein in the
+bathroom. He laid on the table and picked the massage oils. She provided the massage as he laid naked on the
+massage bed. She stated she rubbed his calves and back area. Upon the end of the massage, Epstein removed
+himself from the massage table and paid her $300.00 for the massage. ,
+• said each subsequent time she
+went to the house, she was notified by
+¡ that Epstein was in town and would like her to "work".
+• stated she returned to the house and was again led upstairs byl
+. She provided the massage,
+clothed.
+• was asked if she ever removed her clothing to provide a massage.
+• stated it was not
+until the third time that she went that she removed her clothing.
+stated she was notified by
+that
+Epstein wanted het to come to work. She arrived at the house and was led upstairs by
+1. She started
+providing the massage when Epstein asked her to remove her clothing.
+•temoved her pants, shirt and
+bra. She stayed in her thong panties and continued rubbing Epstein. Epstein turned over onto his back and she
+rubbed his chest area.
+stated she knew he was masturbating hitself as she providing the massage.
+stated she believed he climaxed based on his breathing. She did not want to vicw either the climax or
+the fact that ho was masturbating.
+stated once the breathing relaxed he got up and told her to get
+dressed. She was paid $300.00 for her services.
+stated on the last time she went to provide a
+massage, she was notified by
+to come to the house and "work".
+stated she was now
+dating het current boyfriend and did not fcel comfortable going. She recalled it was approximately January 2005.
+She said she went, already thinking that this would be the last time. She went upstaits and went into the master
+bathroom. She met with Epstein, who was wearing only a towel, and laid onto the table.
+Epstein caugit her looking at the clock on several occasions. Epstein asked her if she was in a hurry, =p-...
+stated her boyfriend was in the car waiting for her.
+further stated that Epstein got upset as he wasn't
+enjoying the massage. She told him that she didn't want to continue and she would not be back. Epstein told her
+to leave as she was ruining his massage.
+advised she had no formal training in providing any massages.
+stated although she had a falling out with Epstein, she still received a Christmas bonus from Epstein.
+stated sho was wired moncy from Western Union for her Christmas bonus. Subpoena results from
+Western Union revealed money was sent from Jeffrey Epstein on December 23, 2004. . .
+received
+$200.00 from Epstein for her Christmas bonus.
+On Noverber 15, 2005, Det.
+and I met with
+During a sworn taped
+statement
+stated she met Jeffrey Epstein over a year ago. She was sixteen years of age and was
+approached by
+, a fellow Royal Palm Beach High School student, who informed her that she could
+make $200.00 providing a massage to Epstein. :
+had informed her that she would have to provide this
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det Joe Recarcy, who is personally known to me.
+Signature of Police Officer (F.S.S: 117.10)
+State of Florida
+County of Palm Beach
+Siguaturity
+esting Officer
+Pagel(of 22
+
+
+A22
+Agency ORX# FLO 500600
+massage topless.
+:. made the arrangements with Epstein and his assistants and took!
+to the house
+stated
+and she entered through a glass door that led into a kitchen. She was taken upstairs by ...., to a
+master bedroom. She recalled the master bathroom had a large pink couch, sauna and matching shower.
+Epstein entered into the room wearing only a towel.
+and:
+*removed their clothing remaining only in
+thong underwear. She further stated that Epstein laid on his chest on the table. The oils were selected on which
+ones to use. Both -
+and
+* provided the massage on his legs, back and feet. Forty minutes into the
+massage, Epstein turned over onto his back, and requested.
+, wait downstairs in the kitchen ate for
+Epstein instructed
+b finish the massage. As:
+got dressed
+starting rubbing Epstein's chest.
+left the room, and Epstein began masturbating asl
+rubbed Epstein's chest.
+Lated Epstein continued
+masturbating until he climaxed on the towel he was wearing. When asked if he had removed the towel she stated
+he turned the towel around so that the opening would allow him to expose himself. After he cleaned himself off
+with the towel he instructed
+he massage was done and to get dressed and meet with him downstairs.
+got dressed and met with Epstein in the kitchen area. She was paid $200.00 dollars for providing the massage,
+stated she was aware that.
+also received monies for the same thing. The second time she went to the
+house she was again approached by
+advised if she wanted to return to the house to provide another
+massage,
+agreed and the arrangements were made by
+for her to return to the house.
+stated i
+drove her to the house and knocked on the same glass door which leads to the kitchen area. They wete allowed
+entry into the house by one of the staff members.
+. led her upstairs to the master bedroom and master
+bathroom area. =-.. left
+this time to do the massage alone. Epstein entered the room again wearing only a
+towel.
+pegan removing her ciothing as she did the last time she was at the house. Epstein instructed her to
+get naked. He laid on the table onto his stomach as
+began massaging his legs and back. As
+inished
+with Epstein's back and legs, Epstein then turned over onto his back.
+started to rub his chest and he began
+masturbating. As
+rubbed his chest, Epstein leaned over and produced a massager/vibrator. He turned it on
+and began rubbing MD's vagina and masturbating himself at the same time.
+stated she continued to rub his
+chest as this was occurring. She described the vibrator/massager as large grey with a large head. Epstein
+rubbed her vagina for approximately two to three minutes with the massager/vibrator. He then removed the
+vibrator from her vaginal area and concentrated on masturbating himself.
+• stated Epstein climaxed onto the
+towel again and informed her that the massage was done.
+Laot dressed and met with "w.. who was waiting
+in the kitchen area. She received $200.00 for the massage,
+said she never returned to the house and had no
+desire to return to the hause.
+las asked if she received any formal massage training. She advised she had
+no formal training.
+was asked if Epstein knew her real age.
+•tated he knew, as he asked her questions
+about herself and high school. He was aware she attended, and is still attending Royal Palm Beach High School.
+The foregoing instrument was sworn to or affirmed
+hefore me this 1" day of May, 2006 by
+Det Joc Recarey, who is personally known to me.
+State of Florida
+County of Palm Beach
+Signature of Policé Officer
+Signature
+tresfing Officer
+Pageppt 22
+
+
+A23
+Agency ORI# FLO 500600
+During the course of the investigation a search warrant was executed at Jeffrey Epstein's home located at
+358 El Brillo-Way in Palm Beach. While in the home I observed the pink and green couch within the master
+bedroom area just as the girls previously mentioned. The stairway, which is located from the kitchen area to the
+master bedroom area, is lined with photos of naked young girls. Additionally, numerous photographs of naked
+young females, some of which appeared to be the girls I previously interviewed, were on display throughout the
+house. Also located in the house were various phone message books. The telephone message books have a
+duplicato copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn
+on the perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers
+were on the copy of the messages. I recogtized various numbers and names of girls that had already been
+interviowed. The body of the messages wete time of the day that they called for confirmation of "work." Other
+names and telephone numbers were located in which the body of the messages were, "I have girls for him" or "I
+have 2 girls for him." These messages were taken by |
+who signed the botlom of the messagcs.
+During the execution of the warrant, I located a Royal Palm Beach High School transcript for
+- in Epstein's
+bedroom desk. This desk had stationary marked Jeffrey E Epstein. I located a wood colored armoire beside
+Epstein's bed that contained a bottle of "Joy Jelly," which is used to provide a warm massage. Several massage
+tables were located throughout the second floor of the residence, including a massage table found in Epstein's
+bedroom. On the first floor of the residence I found two covert cameras hidden within clocks. One was located
+in the garage and the other located in the library arca on a shelf behind Epstein's desk. A computer was located
+which was believed to contain the images from the covert cameras. The computer's hard drive was reviowed
+which showed several images of
+and other witnesses that have been interviewed. All of these
+images appeared to come from the camera positioned behind Epstein's desk.
+On Deceraber 13, 2005, Det. Dawson and I met with
+During a sworn taped
+statement
+ated that when she was sixteen years old she was taken to Epstein's house to provide a massage
+for mone
+stated it was before Christmas last year (2004) when an associate,
+approached her and
+asked if she needed to make money for Christmas.
+ade arrangements to take
+to the house and drove
+to the house to "work." They were encountered by a white female with long blond hair.
+was unable to
+remember the name of the white female with blond hair but knew she was Epstein's assistant. She was led
+upstairs by the white female who explained that there would be lotions out already and Epstein would choose the
+lotion he wanted her to use. She was led through a spiral staircase which led to a master bedroom and
+bathroom. The massage table was already set up in the bathroom.
+escribed the bathroom as a large
+spacious bathroom with a steam room and shower beside it. - was introduced to Epstein who was on the
+phone when she entered the room. Epstein was wearing a white towel and laid on his stomach so that
+may
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det Joe Recarey, who is personally known to me.
+Signature of Police Officer (F.S.S. 117.10)
+State of Florida
+County of Palm Beach
+Signature/Arresting Officer
+Page/gof 22
+
+
+A24
+Ageney ORI# FLO 500600
+massage his feet and calves.
+tarted the rassage with the oils Epstein chose and rubbed his feet and calves.
+Epstein got off the phone and requested she massage his back as well.
+pegan rubbing his back and got to
+the small of his back. During the rubbing of his back, Epstein asked her to get comfortable. He requested she
+remove her pants and shirt
+removed her shirt and pulled her pants off.
+tayed in her bra and thong
+panties. As she finished massaging the small of Epstoin's back, he then turned onto his back. Epstein
+instructed MI, to rub his chest and pinch his nipples. As she began to rub his chest, Epstein asked her questions
+about herself.
+membered telling him she attended Royal Palm Beach High School. Epstein asked her if
+she was sexually active. Before
+could answer, he also asked what sexual position does she enjoy.
+stated she was shy and didn't like talking about those things. She continued rubbing his chest. Epstein reached
+up and unsnapped her bra from the front.
+explained the bra she used had a front snapping device. Epstein
+rubbed her breasts and asked her if she like having her breasts rubbed.
+said "no, I don't like that." Epstein
+then removed his towel and laid on the bed naked exposing his penis to
+He began touching his penis and
+triastutbated as he touched her breasts. ML explained Epstein then touched her vaginal area by rubbing her
+vagina with his fingers on the outside of her thong panties.
+_ tensed up and stated Epstein was aware that she
+was uncomfortable. I
+• stated that Epstein said to her, "Relax, I'm not going inside.". She further explained
+Epstein commented to her how beautiful and sexy she was. Epstein then moved her thong panties to one side
+and began stroking her clitoris.
+said, "He commented how hard my clit was." He then inserted two fingers in
+her vagina and was stroking her within her vagina. She tried pulling back to pull out his fingers from within her
+vagina. Epstein removed his fingers from within her vagina and apologized for putting his fingers inside her.
+During this time, he kept his hand on her vaginal area and continued to rub her vagina.
+stated he rubbed her
+really hard as he was masturbating.
+said he climaxed onto the towel he had been previously wearing and got
+•up from the table. Epstein told ber there was $200.00 dollars for her on the dresser within the master bathroom.
+Epstein also told her that there was an additional $100.00 that was to be given to
+or bringing her there to
+massage him. Epstein told her to leave her telephone number with his assistant as he wanted to see her again.
+Epstein stated his assistant would contact her to work again soon. I asked her if she ever received any formal
+massage training to which.... stated she did not.
+stated it was the only time she ever went to work for Jeff
+and knew what happened to her was wrong. She further stated that she had never been contacted for any
+additional work.
+On January 9, 2006, I located and interviewed another victim,
+as a potential victim/witness from information obtained during trash pulls from Epstein's residence.
+was identified
+stated she
+met Epstein when she was fifteen years of age. She was approached by a friend from Royal Palm Beach High
+School, I
+, to be taken to Jeffrey Epstein's house to work. She was originally told she would be able
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det Joe Recarey, who is personally known to me.
+Can 1 feder
+Signature of Police Officer (F.S.S. 117.10)
+State of Florida
+County of Palm Beach
+Signatur
+esting Officer
+05701/2006
+Pagc/gof.22
+
+
+A25
+Agency ORIN FLO 500600
+"to model lingerie for a wealthy Palm Beacher,
+vas taken to Epstein's house located on El Brillo Way.
+introduced
+to Jeffiey Epstein. Epstein had his mersonal chef prepare dinner for
+At the
+conclusion of dinner,
+and Epstein brough
+upstairs into a master bedroom area.
+observed a large
+massage table with a sheet on it. Epstein entered through a door and exited wearing only a towel.
+informed
+hat they were going to provide a massage on Epstein
+asked why were they doing this instead
+of modeling lingerie.
+explained to that this was his routine and to rub his calves and feet. Epstein had
+told
+to get comfortable.
+removed her pants and blouse.
+stated she stayed only in panties as she did
+not wear a bre that evening.
+• stated while rubbing his calves and feet, Epstein tumed over onto his back.
+Epstein told
+- to rub his chest and rub his nipples
+stated that as she started rubbing his chest, Epstein
+began masturbating himself. Epstein touched her breasts and stroked her vagina with his fingers. Epstein
+continued to masturbate himself as he stroked her vagina. Epstein ejaculated on his towel and paid
+200.00
+for the massage. Epstein told
+that if she told anyote what happened at his house that bad things could
+happen.
+vere brought home by Epstein's houseman and
+vas afraid that Epstein knew where
+she lived
+stated that several days later she received a telephoric call from
+who coordinated for
+b return to "work." {
+returned to the house and was brought to Epstein's bedroom area by
+who
+prepared the room for the massage. Epstein entered the room wearing only a towel. Epstein had
+move her
+clothing and provide the massage naked.
+began rubbing his feet and calves and Epstein turned over onto his
+back. Epstein rubbed her vagina with his fingers. Epstein began to masturbate himself with an upwards and
+downward motion on his penis. Epstein continued to touch her vagina with one hand and masturbate with the
+other hand. Once Epstein ejaculated onto the towel he was wearing, the massage was over.
+was paid
+$200.00 for the massage. Epstein again told
+not to speak of what happened at his house or bad things would
+happen.
+wanted to notify authorities however she was afraid of what would happen to either her or her
+family.
+During the course of the investigation, several subjects were identified as a potential witness/victim
+through information obtained during the trash pulls, physical surveillance and telephone message books retrieved
+from the search warrant. While conducting research on the subjects, I discovered that the females were age
+eighteen or older. Interviews were conducted on the consenting adults whose statements provided the same
+massage routine when they went to "work" for Epstein. The females would be notified by
+and
+made appointments for the females to "work" for Epstein. The females would come to Epstein's house and were
+enter the room wearing only a towel, and ask them to get comfortable. The females would then provide the
+massage naked as Epstein would either touch their vaginas with his fingers and/or utilize the massager/vibrator on
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det Joe Recarey, who is personally known to mc.
+n. I. peso
+Signature of l'olice Officer (F.S.S. 117.10)
+State of Florida
+County of Palm Beach
+Signature/Arresting Officer
+05701/2006
+Pagoof 22
+
+
+14: 01
+A26 'ELL"
+Agency ORI# FLO 500600
+their vaginal area. He would masturbate during the massage and upon his climaxing, the massage would end. The
+girls were then paid two or three hundred dollars for the massage.
+On November 21, 2005 I interviewed Jose Alessi, a former houseman for Jeffrey Epstein. Alessi stated
+he was employed for eleven years with Mr. Epstein, from approximately 1993 through 2004. Alessi stated he
+was the house manager, driver and house maintenance person. It was his responsibility to prepare the house for
+Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private
+plane. I asked Mr. Alessi about the massages that have occurred at Epstein's home. Alessi stated Epstein
+receives three massages a day. Each masseuse that visited the house was different. Alessi stated that towards
+the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi
+stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Epstein's
+bedroom or bathroom. He knew this because he often set up the massage tables. I asked if there were things
+going on other than a massage. Alessi stated that there were times towards the end of his employment that he
+would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage.
+Additionally, he stated the bed would almost always have to be made after the massage.
+On January 4, 2006 I interviewed anothor former houseman, Mr Alfredo Rodriguez. During a sworn
+taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately six months, from
+November 2004 through May of 2005. His responsibilities as house manager included being the butler,
+chauffeur, chef, houseman, run errands for Epstein and provide for Epstein's guests. I asked Rodriguez about
+masseuses coming to the house. Rodriguez stated Epstein would have two massages a day. Epstein would have
+one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated
+he would be informed to expect someone and make them comfortable until either
+or Epstein would
+meet with them. Rodriguez stated once the masseuses would arrive, he would allow them entry into the kitchen
+area and offer them something to drink or eat. They would then be encountered by either
+Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any of the masseuses
+appeared young in age. Rodriguez stated the girls that would come appeared to be too young to be masseuses.
+He stated one time under Epstein's direction, he delivered a dozen roses to Royal Palm Beach High School for
+one of the girls that came to provide a massage. He knew the girls were still in high school and were of high
+school age. I asked Rodriguez about the massages. He felt there was a lot more going on than just massages.
+He would often clean Mr. Epstein's bedroom after the alleged massages and would discover massagers/vibrators
+and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put then
+away in an armoire. He described the armoire as a small wood armoire which was on the wall close to Epstein's
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det Joe Recarey, who is personally known to me.
+1. Judep
+Signature of Police Officer (F.S.S. 117.10)
+State of Florida
+County of Palm Beach
+Pagezof 22
+
+
+A27 raul.
+tHUL
+30/ JU
+Agency ORIN FLO 500600
+bed. On one occasion Epstein ordered Rodriguez to go to the Dollar rent a car and rent a car for the same girl
+he brought the roses to, so that she could drive her self to Epstein's house without incident. Rodriguez said the
+girl always needed rides to and from the house. Rodriguez produced a green folder which contained documents,
+and a note with Mr. Epstein's stationary with direction to deliver a bucket of roses to Royal Palm Beach High
+School after
+high school drama performance. Also in that same note was direction to rent a car forl
+and
+direction to extend the rental contract.
+During the course of the investigation, subpoenas were obtained for cell phone and home phone records
+from several victims and witnesses along with the cell phone records of
+An analysis of these
+records was conducted which found numerous telephone calls were made between.
+and the victims.
+These records indicate the dates the calls were made are consistent with the dates and times they
+victims/witnesses stated they were contacted. Specifically, The phone records showed
+called
+during the exact times and dates whet victim
+advised the incident occurred
+also coordinated
+the encounters with
+andr.
+.. during the time frame the girls
+stated they occurred.
+Pursuant to a lawful subpoena I obtained Epstein's private plane records fot 2005 from Jet Aviation.
+The plane records show arrival and departure of Epstein's plane at Palm Beach International airport. These
+records were comnared to the cell phone records of
+This comparison found that all the phone calls
+made to
+and the victims were made in the days fust prior to their arrival or during the time Epstein
+was in Palm Beach.
+Jeffrey Epstein, who at the time of these inzidents was fifty one years of age, did have vaginal intercourse
+either with his penis or digitally with
+and-.., who were minors at the time this occurred, and
+who at the time of the incident was fits
+rinsanf age, did use a vibrator on the external vaginal arca of
+fourteen year old minor. Therefore, as
+coordinated and aided in the recruitment of minors to
+frequent Epstein's house so that sexual services were provided to Epstein, scheduled the said minors to return to
+the work for Epstein, secured their appointments for the purpose of sexual activity and lewd and lascivious acts
+and arranged the bedroom for said minors, there is sufficient probable cause to charge
+with four
+counts of Principal in the I" degrec Unlawful Sexual Activity with a Minor, in violation of Flonda State Statute
+794.05(1), a second degree felony and there is sufficient probable cause to charge her with Lowd and
+Lascivious Molestation, in violation of Florida State Statute 800.04 (5), a second degree felony.
+The foregoing instrument was sworn to or affirmed
+before me this 1" day of May, 2006 by
+Det Joe Recarey, who is personally known to me.
+1. pesty
+Signature of Police Officer (F.S.S. 117.10)
+State of Florida
+County of Palm Beach
+Pagezzof 22
+
+
+A28
+Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein, dated July 23, 2006
+EPSTEIN, JEFFREY
+ALAS NAMES:
+OVER NAMES: O
+NONE:
+Sunday, July 23, 2005
+2:02:41 AM
+INCARCERATION DATE/TIME 07123/2008 1:56
+PRISONER TYPE LOCAL CHARGES
+DOB: |
+RIS: • W/M
+AGE: 53
+HEIGHT: 61.0 In
+SSN:
+WEIGHT: 180
+ADDRESS: 358 EL BRILLO WY
+ID#:
+
+SID M:
+ALIEN B:
+•FBI #:
+FOUCH: 1291
+AFIS:
+U.S. MARSHAL#.
+deTS #:
+ЛАСКЕТ#: 0338617
+7К: 2006036744
+S
+PALM BEACH SHERIFFS OFFICE
+BOOKING CARD
+BKG.LOC: MDC INTAKE
+BKG. ID#: 6199
+HAIR COLOR: GRY
+EYE COLOR BLU
+CITY: PALM BEACH
+STATE: FL
+ZIP: 33480
+NGIC:
+DOC #:
+INCIDENT #
+ARREST ADDRESS:3228 GUN CLUB ROAD
+ARREST DATE: 07/23/2006
+BKG. DATE:
+07/23/2008
+WARRANT/CASE: 0600945465A99 W
+ARREST OFPICER: CASTILLO
+TRANS. OFFICER: SELF SURRENDER
+CITY: WPB
+ARREST TIME: 1:30
+BKG. TIME:
+1:56
+COURT DIVISION: T - MARX, KRISTA
+ARREST AGENCY: 01 - PESO
+TRANS. AGENCY:
+STATE: Fl.
+ZP: 33406
+CURRENT BOND:
+$3,000.00
+CASE TYPE: FELONY
+NOTE:
+STATUTE:
+798.07 2E (FT)
+0
+COUNT:DESCRIPTION:
+CASE FLAG:
+T PROSTITUTION-OFFER COMMIT ENGAGE 3RD SUBSO OFF
+0
+CT1) FELONY SOLICITATION OF PROSTITUTION (3F)
+0
+*SEALED INDICTMENT** NO INFORMATION GIVEN ** SEALED INDICTMENT JUDGE KROLL
+HOLDS:
+HOLD DATE/TIME:
+HOLD BY:
+HOLD DEPT.:
+HOLD REM.DATE/TIME: HOLD REM. BY:
+HOLD REM. DEPT:
+ALERT DESCRIPTION:
+VeR 3 ALERTS:
+KEEP SEPARATE FROM:
+NONE
+VER 6 NAMES:
+SSIGNED HOUSING:
+CIC INTAKE:
+ALMS REL:
+ED. CLEAR RELI
+SLEASE DATE/TIME: _.
+JURT DATE/TIME:
+CLERK O
+ALERT NARRATIVE:
+NTA DATE/TIME:
+NOIC RELEASE:
+PHOTO ID:
+RELEASE MOVE:
+... RELEASE INFORMATION:
+COURT LOCATION:
+F.P. ENTERED:
+CLASSIPICATION:
+• WARRANTE
+STATE ATTY L] CENTRAL ROOS O
+NTA LOC:
+F.P. CLEAR:
+MED.CLEAR IN:
+CLASS O]
+
+
+A29
+2006 Grand Jury Indictment of Felony Solicitation of Prostitution - Jeffrey E. Epstein
+[pp. A29-430]
+A TRUE BILL
+IN THE NAME OF AND BY THE AUTHORITY OF THE STATE OF FLORIDA
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
+CIRGUIT OF THE STATE OF FLORIDA
+For Palm Beach County, at the Spring Term thereof, in the year of our Lord Two
+Thousand and Six, to-wit: The Grand Jurors of the State of Florida, inquiring in and for
+the body of said County of Palm Beach, upon their oaths do present that JEFFREY E.
+EPSTEIN in the County of Palm Beach aforesaid, in the Ciroult and State aforesald,
+COUNT ONE
+FELONY SOLICITATION OF PROSTITUTION
+on or about or between the 1st day of August in the year of our Lord Two Thousand and
+Four and October 31, 2005, did solicit, induce, entice, or procure another to commit
+prostitution lewdness, or assignation, contrary to Florida Statute 796.07(1) on three or
+more occasions between August 01, 2004 and October 31, 2005, contrary to Florida
+Statute 796.07(2)(f) and (4)(c). (3 DEG FEL)(LEVEL 1)
+against the form of the statute, to the evil example of all others, and against the peace
+and dignity of the State of Florida.
+I hereby certify that I have advised the Grand Jury returning this indictment as
+authorized and required by law.
+7871
+pons 4/111018*3l
+Post-it° Fax Note
+" Mr. FONDA
+From
+alasha trader
+co.
+SAG
+Phone 518-457-4160 PhonSlel-355-7252
+x* 518-45-4ll02rx» 54)-35
+Assistant State Attorney of the
+Fifteenth Judicial Circuit of the
+of Florida, prosecuting for the said
+State
+
+
+A30
+GRAND JURY FOREPERSON
+DẠTE
+Jeffrey E: Epstein, Race: White, Sex: Male, DOB: .
+Issue Warrant
+
+
+A31
+Information for Procuring Person under 18 for Prostitution - Jeffrey E. Epstein,
+dated June 26, 2008
+IN THE CIRCUIT COURT OF THE RIFTBENTH JUDICIAL CIRCUIT
+• IN AND FOR PALM BEACH COUNTY, STATE OF FLORIDA
+CRIMINAL DIVISION "W" (LB) 08CF9381
+ARISES FROM BOOKING NO.:
+
+STATE OF FLORIDA
+VS.
+JEFFREY B BPSTEIN, W/M, 01/20/1953, 090-44-3348
+INFORMATION FOR:
+1)
+•PROCURING PERSON UNDER 18 FOR PROSTITUION
+In the Name and by Authority of the State of Florida:
+BARRY B. KRISCHIR, State Atomy for the Fienth Judicia Ciruit, Palm B cash Clay, Blorida, by and
+through his undersigned Assistant State Attorney, charges that JBFPRBY B BPSTBIN on or about or between
+the 1" day of August in the year of our Lord Two Thousand and Four and October 9, 2005, did knowingly and
+unlawfully procure for prostitution, or caused to be prostituted,
+La person under the age of 18 years,
+contrary to Florida Statute 796.03. (2 DEG FELL)
+Assistant State Attorney
+STATE OF FLORIDA
+COUNTY OF PALM BEAG
+Appeared before me
+Asistant State Attorney for Palm Beach County,
+Florida, personally known to me, who, being first duly sworn, says that the allegations as set forth in the
+foregoing information are based upon facts that have been sworn to as true, and which, if true, would constitute
+the offense therein charged, that this prosecution is instituted in good faith, and certifies that testimony under
+oath has been received from the material witness ormitman As for the offence.
+Assistani State Attomey
+Sworn to and subscribed to before me thighle
+fday of June, 2008.
+Damark Pina
+Lanariopera
+MY COMMESSIOH / DO560798 EXPIRES
+NOTARY PUBLIC, State of Florida
+August 2, 2010
+BONDED THU TRON E
+FCIC REFERENCE NUMBERS:
+1) PELONY SOLICITATION OF PROSTITUTION 3699
+GAA 11IN 2 A man
+
+
+A32
+Guilty Plea for Felony Solicitation of Prostitution and Procuring Person under 18 for
+Prostitution - Jeffrey E. Epstein, dated June 30, 2008
+PLEA IN THE CIRCUIT COURT
+THE FOLLOVING IS TO REFLECT ALL TERMS OF THE NEGOTIATED SETTLEMENT
+Name: Jeffrey E. Epstein
+Plea: Guity X
+Case No.
+06CF009454AMB
+08CF009381AMB
+Charge
+Felony Solicitation of Prostitution
+Procuring Person Under 18 for Prostitution 1
+Count Lesser.
+1
+No
+No
+Degree
+3 FEL
+2 FEL
+PSl: Waived/Not Requited _X_.
+ADJUDICATION:
+Adjudicate ix 1
+Required/Requested.
+SENTENCE:
+On QBCF009454AMB, the Defendant is sentenced to 12 months in the Palm Betch County
+Detention Facity, with credit for 1 (one) day time served.
+On 03CF0093฿1 AMB, the Defendant in sentenced to 5 months in the Palm Beach County
+Detention Facilty, with credi for 1 (one) day time served. This 6 month sentence is to be
+served consecutive to the 12 manth sentence in OBCF009454AMB, Following this 6
+month sentence, the Defendant will be placed on 12 months Community Control 1 (one).
+The corditions of community control are attached hereto and incorporated horein.
+OTHER COMMENTS OR CONDITIONS:
+As a special condilion of his community control, the Defendant is to have no umsupervised
+contact with-minors, and the supervising adult must be approved iny the Department of
+Cortections.
+The Defendant is designated as a Sexual Offender pursuant to Florida Statute 943.0435 and
+must abide by all the comesponding requirements of the statute, a copy of which is attached
+hereto and incorporated. herein.
+The Defendant must provide a DNA sample in court at the time of this
+6/30/08
+Date of Plea
+Affothey fortre Defendant
+Defendant
+
+
+A33
+Judgment for Procuring Person under 18 for Prostitution, dated June 30, 2008
+PAGE B6/20
+4050
+THE CRIMINAL. DIVISION OF THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA.
+IN AND FOR PALM BEACH COUNTY
+CASE NO.
+3841-4381
+_ DIV.
+OBTS NU1C0 8CF-938/7X
+STATE OF FLORIDA
+COMMUNITY
+CONTROL
+VIOLATOR
+PROBATION
+VIOLATOR
+HAVE SHEISTMENTS
+CFN 20080267252
+OR BK 22760 PG Ø565
+RECORDED 07/17/200B 08:06:42
+Pal» Beach County, FlorIda
+Sharon R. Bock, CLERK & COMPTROLLER
+Pg 0565; (1pg)
+Jettrey E.. Epstein
+DEFENDANT
+N
+DATE OF BIRTH
+RACE
+M
+GENDER
+SOCIAL SECURITY NUMBER
+JUDGMENT
+The ahove Defendant, being personally before this Court represented by
+Having beon tried and found guilty of
+the following crime(s):
+J. Goldberger
+Having entered a plea of guilty lo
+the following crime(s):
+fattorney
+Having enicred a plan of nolo
+contendere to the following
+crime(a):
+COUNT
+Procuries Person Under
+for Prostitutia
+OFFENSE STATUTE NUMBER (5)
+DEGREE
+794.03
+2°F
+'X
+and no cause having been shown why the Defendant should not be adjudicated guilty. IT IS ORDERED THAT the Defendant is hereby
+ADJUDICATED GUILTY of the ahove crime(s).,
+and having been convicted or found guilty of, or having entered a plea of nolo contendere ar guilty,regardless ni adjudication, to atlempts or
+offenses relating lo sewal battery (ch. 794). lead and fascitious conduct (ch. 300). or murder (s. 782.01), aggravated hattery (s. 784.045).
+burglary (s. 910.021, carjacking (s. 812.133). or home invasion rohhery (s. 613.135). or any mher offense spicified in section 949.325. the
+defendant shall he required to submit blood specimens.
+. 1
+and gned cause heing shown: IT IS ORDERED THAT ADJUDICATION OF GUILT BE WITHHEL PUN 3 0 2100
+SENTENCE
+STAYED
+set forth in separate order).
+SENTENCE
+DEFERRED
+/ 1 The Court hereby defers impusition of sentence until
+The Defendant in Open Court was advised of his right to appcal from the Judgment hy filing notice of appeal with the Clerk of Court within thiny days
+folinwing the date senience is imposed or probation is ordered pursuant to this adjudication. The defendant was also advised of his richi to the assistance
+ofcounsel in taking said appeal at the expense of the State upon showing of indigency
+NE AND ORDERED in Open CrueLge Palm, Beget County, Floridi. this
+3D day n June
+Wehe Dallane
+JUL TA
+CIRCUIT COURT HIDCIF
+
+
+A34
+Sentence for Procuring Person under 18 for Prostitution - Jeffrey E. Epstein,
+dated June 30, 2008
+84/26/2010 14:51
+
+PAGE 87/20
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDA
+¡IAL CIRCUIT.
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+SENTENCE
+(As to Count(s).
+Defendan JeffRey Ep stein
+Case Numbe 2008CF 9381AXX
+OBTS Number.
+The Defendant, being personally before this Court, accompanied by the defendant's attorney of record,
+_, and having been adjudicated guilty herein, and the Court having given
+the Defendant an opportunity to be heard and to offer matters in mitigation of sentence, and to show cause why
+defendant should not be sentencer as provided by law, and no cause being shown,
+IT IS THE SENTENCE OF THE COURT that:
+The Defendant pay a fine of $
+- pursuant to 9
+_, Florida Statutes, plus all costs and additional
+charges as outlined in the Order assessing additional charges, costs and fines as set forth in a separate order entered
+herein
+The Defendant is hereby committed to the custody of the
+1) Department of Corrections
+[M Sheriff of Palm Beach County, Florida
+| ] Department of Corrections as a youthful offender
+for a term of _
+Lamas
+- Il is further ordered that the Defendant shall be allowed a
+total of _
+days as credit for time incarcerated prior to imposition of this sentence. Itis further ordered that
+the composite term of all sentences imposed for the counts specified in the order shall run
+[Y consecutive to [ Jconcurrent with (check one) the following:
+" 1
+Any active sentence being served.
+JUM 30 2057
+Specific sentences: 200 CF-94544XX
+In the event the above sentence is to the Department of Corrections, the Sheriff of Palm Beach County, Florida is
+hereby ordered and directed to deliver the Defendant to the Department of Corrections together with a copy of the
+Judgment and Sentence, and any other documents specified by Florida Statute. Additionally, pursuant to 5947.16(4),
+Florida Statutes, the Court retains jurisdiction over the Defendant.
+Pursuant to §§322.055, 322.056. 322.26. 322.274, Fla. Stat., the Department of Highway Safety and Motor
+Vehicles is directed to revoke the Defendant's privilege to drive. The Clerk of the Court is Ordered to report
+the conviction and revocation to the Department of Highway Safety and Motor Vehicles.
+The defendant in Open Court was advised of the right to appeal from this Sentence by filing notice of appeal within
+thirty days from this date with the Clerk of the Court. The Defendant was also advised of the right to the assistance of
+counsel in taking said appeal at the expense of the Stale upon showing of indigency.
+DONBAND ORDERED in Open Court af west Palm Bcach, Palm Beach County. Florida this.
+JINE
+, 200%
+pay of
+Form Circuit 5 (rev 8/2000)
+CIRCUIT COURT JUDGE. AT 2800!
+
+
+A35
+Community Control Standard Conditions, dated June 30, 2008
+[pp. A35-A46]
+PAGE 09/20
+
+HER ERE THAT YOU SHALL COMPLY WITH THE FOLLOWING SONDITIONS OF SUPER VISION:
+1.
+COMMUNITY CONTROL S
+ANDARD CONDITIONS:
+You will remain confired to your residence except one half hour before and after your approved tinployment,
+community service work, or any other activities approved by your probation officer.
+You will maintain an howly accounting of all your activities on a daily log which you will submit to your supervising
+officer upon request
+(c)
+The Department of Corrections, may at its discretion, places you on Blectronic Monitoring during the term of your
+Community Control. If placed, oD Electronic Monitoring, you will wear a monitor at all times. You will maintain a •
+private phone line, be financially responsible for any lost or damaged equipment and follow all rules and regulatioos as
+instructed. Tho telephone will be available within five working days of boing placed on Blectronic Monitoring Program.
+While on electronic monitoriog you will remain, confined to your residence and are probibiced from being outside the
+residential walls.
+(d)
+If while being monitored and the monitor is found to have been tampered with you shall be taken into custody
+intumcdistely, if the officer deternines that your were not at your schedules place of wotk or school while allowed to be
+outside the resideoce then in that event you shall be taken into custody immediately. If taken into custody, you shall be
+held without bond and shall, on the next working day, brought before a Judge presiding over his or her case for further
+(e)
+disposition at che discretion of the presiding. Inder.
+If plackd on Electronic Monitoring you will pay to the Stale of Florida, for the cost of Blectronic Monitoring $1.00 per
+day, per P.S.948.09,
+Defendant walt be residies. at 358 El Brillo Way,
+Beach
+Morida
+33480
+II.
+DRUG URENDER PROBATION SIANDARD CONDITTONS
+(a) You will submit to and, unless oberwise waived, be financially rosponsible for drug testing, urinalysis at least on a
+monthly basis, and counseling if deemed appropriate by your supervising officer.
+(b) You will enter and successfully complete a non-scsure or inpatient drug treatment program if deemed appropriate by
+your officer.
+(c) You will comply with any curlew restrictions, confinement approved residence or travel restrictions as instructed by
+your officer and approved by the Officer's Supervisor.
+•SELO TENDER STANDARD CONDITIONS!
+you sball rubmit to a mandatory curfew from 10:00 PM to 6:00 AM
+(if the victing was under the ago of 18 years) you shall not live within 1000 fect of a rchool, day care center, park,
+piayground, or other place where children regularly congregate.
+(c) you shall enter, actively participate in, and successfully complete a'sex offender prentmedt program with a therapist
+partcularly trained to treat sex offender, at probationer's or community controlces expenso.
+You shall not have any contact with the victito directly or indirectly, including through a third person, unless approved
+by the victim, the therapist and sentencing court.
+(if the victim was under the ago of 18 years) you shall not, until you succesufully attend and complete the sex offender
+program, have any ubsupervised contact pith a child under che age of 18 years, anless autborized by the sentencing
+court, without an adult present who is responsible for the child's welfare and which adult has been advised of the crime
+and is approved by the scatencing court
+if the victim was under the age of 18 years) you shall not wolk for pay or as a volunteer in any school, day cire center.
+fark, playground, or other place where children regularly congregate.
+Unlessehonedse indicatit it the picntment plan prawided toy the sexual offender treaten
+prograf, you sha bot view,
+Jown, or posses any obscene, pornographic or sexually stimulating visual or auditory material, including relephone,
+electronic media, computer programs or computer services that are relevant to your deviant bebavior pattero.
+You shall subtit two specimens of blood to the Florida Department of Law Baforcement to be registered wich the DNA
+Data Bank.
+"(k) You sball tiake restirution to the victim as ordered by this court pursuant to P.S. 775.089 for all necessery medical and
+related professional services relating to the physical, pryebintric and psycbological care of the victim.
+residenco, or yehicle.
+9 Defendant to have contact with his paradaton
+oficer at a minimum one tine a weak. So
+6 Detendant to work @ Fovida science Foundation,
+ian Austniian Axe...
+
+
+A36
+
+PAGE 10/20
+C OFFENDER PROBATI
+FRY CONTROL STANDARD
+DITIONS:
+you shall submit to a mandatory curfew from 10:00 PM to 6:00 AM
+(if the victira was under the age of 1B years) you shall not live within 1000 fect of a school, day care center, park,
+playground, or other place where children regularly congregate.
+(E)
+you shall enter, actively participate it, and successfully complete a sex offender treatment prograra with a theripist
+particularly trained to treat sex bffender, at probatoner's or community contrólers expense.
+(d)
+you shall not bave any contact with the victim; directly or iodirectly, including through a third person, unless approved
+by the victim, the therapist and sentencing court.
+(E)
+(If the victim was under the age of 18 years) you shall not, until you successfully attend nud complete the set offehder
+ptogram, bavc any unsupervised contact with a child under the ago of 18 years, unless authorized by the scotencing
+court, without an adult present who is responsible for the child's welfare and which adult has been advised of the crime
+icate
+(g)
+and is approved by the sentencing court.
+(if the victims was under the age of 18 years) you shall not work for pay or as a volunteer in any school, day care center,
+park, playground, or other place where children regularly congregate.
+Unless otherwise indicated in the treatrent plat provided by the sexual offender treatment program, you shall not view,
+own, or posses any obscene, pornographic or sexually stimulating visual or auditory material, including telepbone.
+electronic media, computer programs or computer services that are relevant to your deviant bobevior patter.
+(b)
+You shall submit two specimens of blood to the Florida Department of Law Bnforcement to be registered with the DNA.
+Data Bank.
+(i)
+You shall make restitution to the victim as ordered by this court pursuant to F.S. 775.089 for all necessary medical and
+related professional sortices relating to the physical, psychiatric and paychological care of the victim.
+()
+You shal! submit to a warrantless search by your probation officer or community control officer of your person,
+residence, or yahicla
+you shall, as part of a treatment program, participate onci/twice annually in polygraph examination to obtain information
+десевзвту for risk management and trcatment and to reduce your denial mechanists: Your polygtaph examinations must
+be conducted by a polygrapher trained specifically in the use of polygraph for monitoring sex offenders and it shall be
+paid by you. The results of the polygraph examinations shall not be used as evidenced in court to prove that a violation
+of community supervision occurred.
+You sball maințain a driving log. you sbail not drive a'motor vehiçle while alone without prior approval of your
+supervising officer.
+(if ibere was sexual contact) you sball submit to, at probationer's or community controlee's expense, an HIV test with
+the results to be released to the victim, or the victim's parents or guardian.
+You will not obtain or use a Post Office Box without the prior approval of the supervising officer.
+You will submit to electronic monitoring when deomed necossary by the community control or probation officer and his
+or her supervisor, and ordered by the court at the recommendation of the Department of Corrections.
+EKTANT PROVIDED BY LAW
+ONE AND ORDERED. AT West Palm Beach, Palm Beach County, Florida, ais
+une Pro Tunic: 10/5/2005.
+Honorable Sandra K. MoSgrlor
+Judge, Circuit Court
+bave received a copy of the terns and conditions of my supervision. I have read and understand these condil ms*-- agico to report to the Department of
+ortections Probation Office for further instructions. Also. hereby consent to the disclosure of my alcohol and drug abuse patient records, the confidentiality
+(which is federelly regulated under 42CFR, Part IT, for the duration of my supervirion.
+JEFEND
+LP 10/11
+DATE
+
+
+A37
+04/26/2810 14:51
+
+PAGE 11/20
+948.101 Terras and onditions of community control and criminal quarantine community
+control.-
+(1) The court shall determine the terms and conditions of community control, Conditions
+pocified in this subsaction de nat require oral pronouncamont at the time of sentencing and
+may be considered standard conditions of community cantrol.
+(a) The court shall roquiro Intonova supervision and survaillance for an affondor placed into
+community control, which may include but is not limiced to:
+1. Spacified contact with the parole and probation officer.
+2. Confinemont to an agreed-upon rosidonca during hours away from employmont and public
+sarvice activitios.
+3. Mandatory public sorvico.
+4. Supervision by the Departmant of Corractions by moans of an electronic monitoring device
+or system.
+5. The standard conditions of probation sat forth in s. 942.03.
+(b] For an offonder placed on criminal quarantine community control, the court shell requira:
+1. Bloctrone monitoring 24 hours per day.
+2. Confirmore to a designatad rustdance durny designated hours.
+(2) The onumeration of specific kinds of terms and conditions does not prevent the court from
+addirz thorate any other torms or conditions that the court considers proper. However, the
+contancing court may only Impose a condition of supervision allowim an offonder convicted of
+= 794.011, s 800.01, s. 827.071, or 5. 847.0145 to reside in anothor state if the order
+stipulates that it is contingent upon the approvel of the recoiving stata intorstate compact
+nuthority. The court may rescind of modify at any time the tarms and conditions thuratofore
+Imposed by it upon the offonder in community control. Homorer, If the court withholds
+adjudication of fullt or imposes a period of incarcaration as i condition of community control,
+the parlod may not exceed 361 days, and incarceration shall be restricted to a county facility,
+a probation and restitution conter under the jurisdiction of the Departmont of Corrections, a
+probation program drut punishment phase 1 securo rosidartial treatmont institution, or a
+commurity rouldential facility owtred of operated by any antity providing such sorvices.
+(3) The court may place e dafondant who is being santanced for criminal transmission of HIV in
+violation of s. 775.0077 on criminal quarantine community control. The Departmont of
+Corrections shall davelop and administer a criminal quarantino community control program
+amphad zing interslya supervision with 24-hour per-day electrone monitoring. Criminal
+quarantine commurity contral status must include survelllance and may Include athor monsures
+normally associated with community control, excopt that spacific conditions necessary to
+monitor this population may be ordered.
+
+
+A38
+
+PAGE 12/20
+1943.0435 Sexual offendors required to rogister with the department; penalty..
+(1) As usad in this section, the term:
+(a)1. "Saxual offonder" moans a person who maats the critoria in sub-subparagraph a., subsubparagraptib., sub-subparagrapt c., or sub-subparagraph d., as follows:
+1. (1) Has beon convicted of committing, or attempting, soliciting, or conspiring to cotrimit, any
+if the criminal offorses proscribad in the followiny statutes in this state or similar offenses ir
+another jurisdiction: 3. 787.01, s. 187.02, or s. 187.025(2)(c), whare the victim is a minor and
+oxcluding s. 447.0115(4); s. 847.0137; s. 947.0138; s, B47.0145; or s. 905.701(1); or ary similar
+offianse committed in this state which has beon redesignated from a former statute number to
+one of those listed in this sub-sub-subparngraph; and
+(II) Har bean rolansed on of aftur October 1, 1997, from the sanction Imposod for any
+conviction of an offurse described in sub-sub-subparagraph (l). For purposas of sunt-sedosubparagraph (1), a sanction imposed in this state or in any other jurisdiction Includes, but is
+not limited to, a fins, probation, community control, parolo, conditionel rolosso, control
+refonse, or incarcoration in a state prison, fodoral prisen, privato correctional facility, or local
+datantion facility;
+b. Establishos or maintains a residance in this state and who has not boon designatad as a
+sexual prodator by a court of this state but who has boon desigrubed as a sexual prodator, as a
+sexually violon: prodator, or by another saxual offender designation in another stata or
+jurisdiction and was, As a rosult of such designatlon, subfocted to ragistration or community or
+public notification, or both, or would be if the person ware a resident of that state or
+jurisdiction, without regard to whothor the person otherwise moets the critoria for registration
+as i sexual offender;
+c. Establishos or maintains a residonce in this state who is in cho custody or contral of, or
+under the supervision of, arry other state or jurisdiction as a result of a conviction for
+contimittie, or attempting, soliciting, or conspiring to commit, arry of the criminal offenses
+proscribed in the following statutes or similar offerse in another jurisdiction: s. 787.01, 5.
+787.0Z, or s. 787.025(Z)(c), whore tho victim is a minor and the deforant is not the victim's
+parent or guardian; 1 794.011, oxcludiny s. 794.011(10); 3. 794.05; %. 796.03; 5. 296.035; 5.
+800.04; s. 825.1025; 1. 827.071; 3. 847.013); s. 847.0135, oxcluding s. 847.0135(4); 5.
+847.0137; 5. 847.0138; s. 817.0145; or s. 745.701(1); or arry similar offerse committed in this
+stato which has boon redesignated from a formor statuto number to ano of those listed in this
+sub. subparagraph; or
+d. Or or after July 1, 2007, hes been adjudicated delinquent for committing, or attortipting,
+soliciting, of corspirie to commit, any of the criminal affonses proscribed in tha following
+stabutes in this state or similar offenses in another jurisdiction when the fuvonilo was 14 years
+of mgo or older at the time of the affonsa:
+11) Saction 794.011, axcluding s. 794.011(10);
+(II) Soction 800,04/4)(b) whore the victim is under 12 years of age or whore the court finds
+saxual activity by the ise of force or coorcion;
+(Ill) Soction 800.04(5)(c)1. where the court Finds molestation involving unclothed gonit
+
+
+A39
+
+PAGE 13/20
+(V) Soction 800.04(5)(d) where the court finds the use of forco or coercion and unclothod
+gormitals.
+2. For all qualifying offonsos listed in sub-subparagraph (1)(a)1.d., the court shall make a
+written finding of the age of the offondor at the time of the afforse.
+For bach violation of a qualifying offonse (isted In this subsoction, the court shall make a
+written finding of tha age of the victim at the time of the offensa. For a violation of s.
+600.04(1), the court shall additionally mako a writton finding indicating that tha offense did or
+old not Involve sexual activity and indicating that the offanse did or did not involve force or
+coercion. For a violation of s. 800.04(5), the court shall additionally make a writton finding
+that the offonss did or did not Involve unclothed genitals or goritad arde and that the offorse
+did or did not Involva the use of forca ar coarcion.
+(b) "Convictod moems that thare has boon a detormination of gullt as a result of a trial or Un
+untry of a ples of guilty or nols contenders, rogardless of whether adjudication Is withheld,
+and includes an adjufication of delinquency of a juvenile as specified in this soction.
+Coruction of a similar offanse Includes, but Is not limitad to, a conction by a fodoral or
+mititary tribunel, Including courts-martial conducted by the Armad Forces of the Unita Statos,
+and includes a conviction or entry of a plos of guilty or mula contendure resulting in a sanction
+In any state of the Unitad States or other jurisdiction. A sanction Includes, but is not Imited
+to, a fino, probation, community control, parole, conditional raluase, control rolosse, or
+Incarcoration in a state prison, fodoral prisan, private correctional facility, or local datontion
+Facility.
+(c) "Permanent residence" and "temporary residunce" have tha same mearing ascribad in s.
+775.21.
+(d) "Institution of higher aducation" means a carner contor, communty collage, college, stato
+university, or indepondent postrocondary institution.
+(°) "Chango in evoltmont or omployment status" menns the commencement or tormination of
+umollmart or employment or a chungo in location of onrolimant, or employmont.
+(f) "Electronic mail addross" lus tho same moanny as provided in s. 068.602.
+(g) "Irstart message nuine" mears an identifior that allows a person to communicate in roaf
+time with anuthor parson using the intornet.
+(2) A sexual offandor shall:
+(a) Roport In parson at the shoriff's office:
+1. In the county in which the offundor establishes or maintains a pormanent or tamporary
+residence within 48 hours after:
+a. Establishing permanont or tomporary residonco in this state; or
+. Boing roleased from the custody, cantrol, or supervisen of the Drpartment of Correction
+or from the custody of a private correctional facility; ol
+I. In the county where he or she was convicted within 19 hours after being convicted for B
+qualifying offonse for registration under this saction if the offondor is not in the custody or
+
+
+A40
+
+PAGE 14/20
+control of, or undor the suporviston of, the Dopertmant of Corrections, of Is not in the custody
+of a private correctori facility.
+Any charge in the sexual offender's permanent or temporary residence, name, arry electronic
+mail address and any instant inessage name required to be provided pursuant to paragraph
+(4)(0), after the saxuel offonder reports in person at the shariffs office, shall be accomplishad
+in the manner provided in subsoctions (4), (7), and (8).
+(b) Provida his or her name, date of birth, social security number, race, sax, hoight, waight,
+halt and oye color, tattoos or other iduntifylng marks, occupation and place of omployment,
+address of permanent or lopal residence or addrass of any current temporary residenca, within
+the state and out of state, including a rural route address and a post office box, any electronic
+mafl adcross and arty instant message name requirod to be provided purtuant to parngraph
+(4){d), date and place of each conviction, and a brief description of the crima or crimus
+committed by the offordor. A post office box shall not be provided in llou of a plysical
+residortial addross.
+1. If cho sexual offonder's place of residonce is a motor veirclo, trailer, mobile homo, or
+manufactured homo, es defined in chapter 320, tho saxul offender shall aise provide to the
+dopartment through the sheriffs office written notice of the valicia Idontification number; the
+(iconso tag number; the ropistration number; and a description, Including color schora, of the
+motor vehicla, traller, mobile homo, or manufacturad home. If the sexual offender's place of
+residance is a vessel, livo-aboard vossel, or houseboat, as defined in chaptor 327, the saxual
+offender shall also provide to the department writton notice of tha hull Identification numbor;
+the manutacturer's sariel number; tha name of the vessel, Ifve-eboard vessel, or houseboat; tho
+registration numbor; and a description, including color schome, of tho vessel, liva-aboard
+vassol, or housebant.
+Z. If the sexund offander is enrolled, employed, or carryíng on a vocation at an institution of
+Mighor aducation in this state, the sexial offandor shall also provide to the department through
+the shuriffs office the name, address, and county of anch institution, including anch campus
+attarcad, and the saxual offonder's onrollmont or employment status. Each chongo in
+onralimont of employmart status shall bo roported in person et the sumiffs affica, within 15
+hours after eny change in status. The shariff staill promptly notify each institution of the saxual
+offonder's prosonce and any chango in tha saxual offondor's onrollmont or omployment status.
+Whom a saxual offonder roports at the sheriff's office, the shariff shall take a photograph and a
+set of fingerprints of the offondor and forward the photographs and fingorprints to tha
+promptly provide to the department the information rocolvad from the sexual offandor.
+(3) Within 45 hours aftar the report required undor subsection (2), a sexual offendor shall
+report in person at a drivor's license office of the Dopartmont of Highway Safuly and Motor
+Voticlos, unloss a driver's licenso or idantification card that complies with the recuiraments of
+5. 322. 141(3) was provously securad or updated undor s, 914.607. At the driver's license office
+che taxial offondor shall:
+(m) If othererise qualifiod, secure a Florida driver's liconsa, ronora a Florida drivor's licersa, or
+octire an Identification card. The saxual offorder shall identify himself or herself as a saxual
+offender who is roquired to comply with this saction and shall provide proof that the saxun!
+offonder roported as roquirod in subsection (2). Tha raxual offendor shall provide arry of tho
+information specifiod in subsection (2), if requested. The sexual offordor shall submit to tha
+taking of a photopraph for use in Issuing a driver's licersa, renomad licersa, or identification
+card, and for use by the dopartment in maintaining current records of sexual offandors.
+
+
+A41
+
+PAGE 15/20
+(b) Pay the costs assassed by the Department of Higtway Safety and Motor Volticles for issuing
+or renowing e driver's liconso or identification card as roquired by this section. Tha driver's
+lIcense or idontificatfon card Issued must bo in compliance with s. 322. 141(3).
+(c) Provide, upon request, any additional Information necessary to confirm the Identity of the
+saxual offoncer, including a sot of fingerprints.
+(4)(a) Each timo a saxual offonder's drivar's licerse or idantification card is subject to ronawal,
+and, without regard to the status of the offender's driver's license or Identification card, within
+48 hours after any change in tha offendor's pormanent or tomporary residence of changa in tha
+offander's namo by reason of marriago or othor logal process, tha offorder stull roport in
+person to a driver's carse office, and shall be subjact to the requirements spacified in
+stabsaction (3). The Dopartmont of Highwary Safoly and Motor Vehiclos shull forward to the
+dopertment all photographs and information provided by saxul offenders. Notwithstanding the
+restrictions set forth in s. 122.142, to Department of Highway Safaty and Motor Vohicles is
+authorized to rolouse a roproduction of a color photograph or dipftal-image Ifcore to the
+Department of Law Enforcement for purposes of public natffication of saxual offenders as
+provided in this section and is. 943.043 and 941.606.
+(b) A sexual effondor who vacates a permanont residence and falls to establish or maintain
+anothor permanent or tomporary rusidence shall, within 45 hours aftar vacating the permanent
+rascanca, report in porson to the shoriffs office of the county in which ho or she is located.
+The soxual offendat shali specify the date upon which he or the intends to or did vacate such
+ronfdanco. Tha saxual offender must provide of update all of the registration information
+requirad under paragraph (2)(b). The sexual offondor must provide un address for the residence
+or other (ocntion that he or sho is or will be occupying during the time in which he or she fails
+to establish or mentain a permanent or temporary residonce.
+(c) A sexual offender who romalms at a permanent residance after reporting his or heir intent
+to vecabe such residence stall, within 48 hours after the date upon which the offarcer
+(nicated he or she would or did vacate such residence, roport in parson to the agency to which
+ho or she reported pursuant to paragraph (b) for the purpose of reporting his or her address at
+such residence. Whon the shoriff racetvis the report, the shoriff shall promptly correy the
+infotmation to the dapartmont. An offender who makes a roport as required under paragraph
+(b) but fails to make roport us resuired uncer this pergraph commits a felony of the second
+dagron, praristmblo as proved in s. 775.001, s. 775.08], or s. 775.004.
+(d) A saxud offander must register arry olactronic mall address of instant mossage name with
+the departmont prior to using such alectronic mail address or Instant message nama on or aftor
+Octobor 1, 2007. The dopartmant shall establish an online systor through which sexual
+offendors may securely accoss and update all eloctronic mall address and instant message
+name information.
+15) This sectlan does not apply to a sexual offonder who is also a sexual prodator, as definod in
+s. 725.21. A sexual prodator must rogister as roguired under s. 775.21.
+(6) County and local law enforcomont aponcios, in conjunction with the departmont, shall
+verify che addresses of soxual offundors who are not undor tha care, custody, control, or
+supervision of the Dapartmont of Corrections in a mannar that is consistont with the provisions
+of the Faderal Adam Walsh Child Protection and Safety Act of 2006 and arry othor fodoral
+standards applicable to such verification or roquirad to be mot as a condition for the rocript of
+faderal funds by the stata. Local I enforcomont agoncies shalt report to the departmont arry
+failure by a sexual affondor to comply with registration roquiremonts.
+
+
+A42
+
+16/20
+(7) A sexual offandor who intonds to establish residonce in another state or jurisdiction ochor
+than the State of florida shall roport in person to the shariff of the county of current residence
+within 45 hours before the date he or sho intands to loave this state to establish rosidonce.in
+another state or jurisdiction. The notification must include the address, municipality, county,
+and state of intended residancia. The shariff shall promptly provide to the department the
+Information rocolvad from the sexual offonder. The dopartmont shall notify tho statowide law
+onforcement agency, or a comparable agoncy, in the intended state or jurisdiction of residonce
+of the sexual offondar's intonded residenco. Tho failuro of a soxual offundor to provide his or
+her Intonded place of residonce is punishable as provided in sutraction (9).
+(5) A sexual offender who indicatos his of hor intent to resice in another stato or jurisdiction
+other than the State of Florida and later docides to romain In this state shall, within 48 hours
+after the date upon wirich the saxual efforder indicated ho or she would leave this state,
+report in person to the sheriff to which the sexual offondor reported the intended change of
+renderce, and raport his or hor Intent to remaln in this statm. The sheriff shall promptly roport
+this information to the dopertment. A sexual offendor who reports his or hor intont to reside in
+another state or Jurisdiction but who remalns in this state without roporting to the shaiff in
+the manner requirod by this subsaction commits a folony of the socond dogros, purishable as
+provided in s. 775.063, x. 725.083, or s. 775.084.
+(9)(a) A soxie! oflandor who does hot comply with tha roguirements of this saction commits a
+folorry of the third dugree, purishahle as provided in s. 775.062, s. 775.063, or s. 775.0B4.
+(b) A sexual offender who commits arty act or omission in violation of this section may be
+prosocuted for the act or omfssion in the courty in which the act or omission was commftted,
+the county of the last rogistered address of the sexual offordar, or tha county in which the
+convictlon occurred for the offerse or offonses that moot tha criteria for designating a parson
+as a sexual offender.
+(e) An arrest on charpes of failure to register when the offunder has beon provided and advised
+of Its of har statutory obligations to ragistor undor subsection (2), cha service of an
+information or a complaint for a violation of this section, or an arraignmant on chargos for o
+violation of this sectlon constitutes actual notice of the duty to rogistor. A saxual affordor's
+failure to immeciatoly register as required by this section fullowing such arrest, sarvice, or
+arratgnmont constitutes grounds for a subsequent charge of failure to registar. A sexual
+offandor charged with the crime of failure to rogistor who assorts, or intends to assert, a lack
+of notice of the duty to register as a defonso in a charpe of fallure to register shall
+Iminolately rogistor as required by this soction. A saxual offonder who is chargod with n
+subsoquet fallura to registor may not assert the defense of a lack of notice of the duty to
+register.
+(d) Registration followiny such arrest, sorvice, or arraignmart is not a dafense and doos not
+rationo the saxuxi offendor of criminat liability for the failure to rogister.
+(10) The department, the Dopartment of Hipway Safoty and Motor Vohicles, the Departmont
+of Corractlons, the Dopartmont of Juvenile Justice, any law onforcement agoncy in this state,
+and tho parsonrial of those departmonts; an aloctad or appolnted official, public amplayto, or
+school administrator; or an omployoo, agoncy, or any individual or entity acting at the roquest
+or upon the direction of any law enforcoment agoncy is immune from civll liabflity for damages
+for good faith complance with the raquiromonts of this section or for the rolease of
+information under tris section, and shall be presumed to have actod In good faith in compiling,
+recording, reporting, or reloasing the information. The prosumption of good faith is not
+ovorcome if a technical or clorical error is made by the department, the Dapartment of
+I#gway Safaty and Motor Votricles, the Department of Corrections, the Dapartment of Juvenile
+
+
+A43
+
+PAGE 17/28
+Justice, the personnel of those departments, or any Individual or antity acting at the request
+or upor the direction of arty of thosa departments in compiling or providing information, or if
+Information is Incomplete or incorract bacause a saxual offender fails to report or falsely
+roports his or har currant place of permanent or temporary residence.
+(11) Excopt as providad in s. 943.04354, a saxual offender must maintain rogistration with the
+dopartmont for the duration of his or her life, unless the sexual offender has roceived a full
+pardon or hes had a conviction set aside in a postcarviction proceeding for any offerse that
+• musts the criteria for classifying the person as a sexual offonder for purposes of rogistration.
+However, a saxual offandor:
+(m)1. Who lurs bean lawfully reloased from confinement, supervision, or sanction, whichemon is
+lator, for at lost 25 yoers and furs not boor arrested for any folony or misdomonnar offerso
+since reloass, provided that the saxual offender's requirement to register was not based upon
+an adult conviction:
+4. For a violation of x. 787.01 or ≤ 787.02;
+b. For a violations of s. 794.011, exclueliny s. 794.011(10);
+c. For a viclation of s. 800.04(4)(b) whore the court finds the offense Invelved a victim under
+12 yoars of age or sexual activity by tha usa of force or coercion;
+d. For a violation of s, 800.01(5)(b);
+o. For a violation of s. 4D0.04(5)k. 2. whure the court finds tha affanse involvad unclathed
+goritals or perrital aros;
+f. For any attompt of corspiracy to commit arry such offorsa; or
+%. Por a violation of similar law of another Jurisdiction,
+may petition the crimind dision of tha crcule court of the circule in which the saxin!
+offonder reckles for the purpose of removing tha requirement for registration as a sexuni
+offender.
+2. The court may grant or derry rollaf if the offunder demonstrates to the court that ho or she
+has not been arrested for ay crime since rolonse; the requested relief complies with the
+provisions of the fodoral Ader Walsh Child Protection and Safaty Act of 2006 and erry other
+lodoral standards applicablo to the ronoval of rogistration roquiroments for a soxual offonder
+or requirad to be met as a condition for the receipe of fadoral funds by the state; and the court
+is othorwise satisfied that tha offondor is not a current or potontial thrant to public safoty. Tho
+state attorney in the circuit in which the patition is filled must be given notice of the petition
+at loost 3 wooks bafore the houring on the mattor. The state attornoy may present evidenco in
+opposition to the roquasted rellof or may othorwise demonstrate the rossoms why the petition
+should ba dared, If the court dontos the petition, the court may sat a future date at which the
+sexual offonder may again petition the court for relief, subjact to the standards for rollal
+provided in this subsection.
+1. The dopartment shall remave an affondor from clasdfication as a sexual offondor for
+purposes of registration If the offendor providas to the dapartment a cortiflad copy of the
+court's written findings or ordar that indicates that the offendor is no longer required to
+comply with tha roquirements for rogistration as a saxual offender.
+
+
+A44
+14: 51
+
+18/20
+(b) As defined in sub-subparagraph (1)(a)1.b. must maintmin rogistration with the departmont
+for the duration of hts or hor life until the person provides the departmont with an order issued
+by the court that dosignated the porson as a sexual prodator, as a saxually violont predator, or
+by another saxual offander designation in the state of Jurisdietion in which tha ordor was
+issued which states that such designation has bean removed or demonstrates to the
+departmont that such dodgration, if not imposad by a court, has boor ronovad by oporation of
+lew or court order in tha state or jurisdiction in which the designation was made, and providod
+such person no longor meats the criteria for rogistration as a saxual offandor under the laws of
+this state.
+(12) The Legislature finds that sexual offenders, espocially thosa who have committed offenses
+against minors, ofton pose a high risk of ungaging in sexual offonsas ovon after baling rolossed
+from incarceration of commitmont and that protection of the public from sexual affordars is a
+bectuse of the public's interest in public safoty and in the effective aporation of government.
+Roleasing inFormation concorning saxual offondors to law enforcemont agorcias and to parsons
+who roquest such information, and the reloase of such Information to the public by a law
+enforcement agancy of public agoncy, will further the governmontal interests of public snfoty.
+Tho designation of a porson as a saxual offondor is not a sontence or a punishment but fs simply
+the status of the offendor which is the rosalt of a conviction for having committed cortain
+crimes.
+(13) Any person who has reason to ballove that a sexual offander is not complying, or has not
+complled, with the requirements of this section and who, with the Intent to assist the saxual
+offender in eluding e law enforcement agency that is sooking to find the sexual offender to
+noncompliance with the requiremonts of this saction:
+(a) Withholds Information from, or doss not notify, the law onforcement agancy about the
+saxual offender's noncompllance with the roquiremants of this section, and, if known, tha
+wtorosbourts of the sarual offendor;
+(b) Harbors, or attempts to harbor, or assists another person in harboring or attampting to
+harbor, the saxual offender; or
+(c) Conceals or attempts to conceal, or assists another person in concoaling or attempting to
+concoal, tha sexual offendor; or
+(d) Provides information to the law onfarcoment ngancy rogarding the sexual offender that the
+person knows to be false Information,
+commits a felorry of the third dogros, punishablo as providad in s. 775.082, 5. 275.083, or s.
+7L5.084.
+(14)(a) A saxual offender must roport in person each year during the month of the saxual
+offance's birthdry and during the slath month following the saxual offandor'y birth month to
+the sheriff's office in the county in which he or she resides or is otharwise located to reregister.
+(b) Howevor, a sexunl offerior who is roquired to reyister es a result of a corviction for:
+1. Soction 787.01 or s. 787.02 where the victim is a minor and the offondor is not the victim's
+parant or guardian;
+
+
+04/26/2018
+
+A45
+PAGE 19/20
+1. Saction 794.011, oxcluding s. 794.011(10);
+3. Section 800.04(4j(b) whore the court finds the offonse involved a victim under 12 years of
+age or sexuel actlvity by the use of force or coercion;
+4. Saction 800.04(5) (b);
+5. Soction 800.04(5)(c)1. where the court finds molestation involving unclothed garitals or
+portal aran;
+6. Saction 800.04(5)c. 2. where the court finds molestation involving unclothed gonitals or
+genital area;
+7. Section 800.04(5)(d) whore the court finds the use of force or corcion and unclothed
+poritals or porrital anas;
+8. Arry attampt or consprecy to commit such offense; or
+9. A violation of a similar law of another jurtselfction,
+must renegister each year during the month of the saxue offender's birthday and ovary third
+month thereafter.
+(c) The sheriffs office may detormine the appropriate times and days for ropoting by the
+saxual offontor, which shall be consistent with the roporting roquirements of this subsection.
+Rarogistration shall include any changes to the following information:
+1. Neme; social security numbar; ago; race; sax; date of birth; haight; weight; hair and oyo
+color, address of any permanant residence and address of arry current tomporary rosidence,
+within the state or out of state, Including = rural route address and a post office box; arry
+• doctronic mall address and any instant messago name required to be provided pursuant to
+paragraph (4)(d); date and place of any amployment; vohicla mate, modai, color, and licarso
+tag number; fingerprints; and photograph. A post office box shall not be providod in liou of a
+physical resential addross.
+2. If the sexual offonder is enrolled, amployed, or carrying on a vocation at an institution of
+Matior aducation in this state, the sexual offondor shall also provido to the department tha
+nama, address, and county of such institution, including each campus attarded, and the saxual
+afforder's enrollmont or amploymart status.
+3. It the saxual offender's place of residence is a motor vehicle, trailor, mobile homo, or
+manufactured home, es defined in chaptor 320, the saxual offondar shall also provide tha
+voticle idantification number; the license tag number; the rogistration number; and a
+description, Including color schora, of tha motor valicle, traflor, mobile horra, or
+manufactured horne. If the saxual offondor's place of residorca is a vessel, Ifve-abord vessel,
+or houseboat, as doffred in chapter 327, tho sexual offender shall also provide the huft
+Idontification number; the manufacturor's sorial numbar; the namo of the vessel, live-aboard
+vossol, or housoboat; the registration numbor; and a description, Including color schome, of
+the vassal, liva-aboard vessel or tenseboat.
+4. Any soxual offonder who fails to roport in parson as roquired at the shariff's office, or who
+fails to respond to any addross verification corresponderico from the department within 3
+weaks of the date of the correspondonce or who fails to roport alectronic mail addressos or
+
+
+84/26/2818
+
+A46
+PAGE 28/28
+Instant mossaga names, commits a folory of the chird degram, puristsblo as provided in s.
+775.007, s. 775.063, or s. 775.0B4.
+(d) The shariffs office sha!!, within 2 working days, eloctronically submit and update all
+Information providad by the saxual offondor to the departmont in a manner proscribed by the
+departmont.
+
+
+A47
+Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein, dated June 30, 2008
+
+NAME:
+EPSTEIN, JEFFREY
+JACKET#: 0338617
+ALIAS NAMES:
+OVER O NAMES: O
+EPSTED JEFFREY - EPSTEIN, JEFFREY EDWARD-
+Monday. June 30, 2008
+PALM BEACH SHERIFFS OFFICE
+11:33:10 AM
+BOOKING CARD
+NCARCERATION DATE/TIME 06/30/2008 11:12
+BKG.LOC: MOBILE BOOKING
+*RISONER TYPE: LOCAL CHARGES
+BKG. ID N: 854B
+0OB:
+ABE:
+SSN:
+55
+RAS:
+•WAN
+HEIGHT: 6 f 0 in
+WEIGHT: 200
+HAIR COLOR: GRY
+EYE COLOR: BLU
+ADDRESS: 358 EL BRILLO WY
+ID#: 20080830061
+SID#: 06587245
+ALIEN I:
+FBI E: 787075K6
+CITY: PALM BEACH
+POUCM: 3050
+AFTS: 2006038744
+U.S.MARSHAL A
+OBTS H:
+STATE: FL ZIP: 334B0
+NCIC:
+DOC I:
+INCIDENT #:
+PAGE B4/28
+*: 2008039316
+CITIZEN
+COUNTRY: USA
+ARREST ADDRESS:205 N DIXIE HWY (MAIN CT HOUSE)
+ARREST DATE:
+06/30/2008
+BKG. DATE:
+06/30/2008
+WARRANTICASER:
+ARREST OFFICER: D/S DELPLATO
+TRANS. OFFICER: D/S MCINTOSH
+CITY: WPB
+ARREST TIME: 10:15
+ARG. TIME:
+11:12
+COURT OVISION:
+ARREST AGENCY: 01 - P9SO
+TRANS, AGENCY: 01 - PBSO
+STATE: FL
+ZIP:
+CURRENT BOND:
+$0.00
+CASE TYPE: RECOMMIT-FELONY
+NOTE:
+STATUTE:
+9999.0004 (NN)
+-0
+CT:
+DESCRIPTION:
+-RE-COMMIT
+CASE FLAG: NO BOND
+DENO I
+PROCURE PERSON UNDER AGE OF 18 FOR PROSTITUTION /CASE: 2008CF009381AXCX.W
+-58:00
+20,00
+11
+HOLDS:
+HOLD DATE/TIME:
+HOLD BY:
+HOLD DEPT:
+HOLD REM.DATE/TIME: HOLD REM. BY:
+HOLD REM. DEPT:
+ALERT DESCRIPTION:
+ALERT NARRATIVE:
+DNA NOT ON FILE/FELONY CONVICTION
+OVER J ALERTS:
+20
+KEEP SEPARATE FROM:
+NONE",
+SER 6 NAMES:
+ASSIGNED HOUSING:
+ICIC INTAKE:
+'ALMS REL.:
+IED. CLEAR REL:
+ELEASE DATE/TIME:
+OURT DATE/TIME:
+CLERK 2
+NCIC RELEASE
+PHOTO ID:
+RELEASE MOVE:
+RELEASE INFORMATION:
+COURT LOCATION:
+WARRANTS L!
+NTA DATE/TIME:
+F.P. ENTERED:
+CLASSIFICATION;
+NTA LOC:
+F.P. CLEAR:
+MED.CLEARIN: DE JUL: 12008
+STATE ATTY I.!
+CENTRAL ACDS !]
+CLASS 11
+
+
+A48
+Order granting Jeffrey E. Epstein's Motion for Travel, dated December 18, 2009
+IN THE CIRCUIT COURT OF THE FIFTEENTH
+JUDICIAL CIRCUIT IN AND FOR PALM BEACH
+COUNTY, FLORIDA - CRIMINAL DIVISION
+CASED: 206879381 AMB
+STATE OF FLORIDA
+FILED
+VS.
+Olroult Criminal Department
+Jeffrey Epsten
+DEL: 1 8 2009
+SHARON R. BOCK
+Defendant.
+Clerk & Comptroller
+Palm Beach County
+I shes unoon 0» Motion to toil
+THIS MATTER comes before the court upon D'. mots fo trave!
+The Court, having been made aware that both counsel have agreed to sald motion..
+Accordingly, it is hereby:
+ORDERED and ADJUDGED that O" motion is grated under.
+Officer:
+Carma
+Florida, this.
+DONE and ORDERED in Chambers, West Palm Beach, Palm Beach County,
+_ day of
+12/18/09
+ircuit Court Judge
+
+
+A49
+Letter from Florida Department of Corrections Regarding Termination of Supervision,
+dated July 21, 2010
+FLORIDA
+DEPARTMENT of
+CORRECTIONS
+SATE OTTONS
+Ân Equal Opportuniy Eniployer
+2601 Binir Stone Rond Tallahassee, FL 32399-2500
+Date: 2/21/201Q
+200.027 AMID: 29
+Govemor
+CHARLIE CRIST
+SANES. MADONOUCH.
+http://www.dc.state.fl.us
+TERMINATION OF SUPERVISION
+DC# W35755
+DOCKET/UC NO(S) 50200BCF009381AXXX
+Mr. Epstein
+358 B Brillio Way
+Zalm Beach, FL 33480
+Dear Mr. Epstein
+You are hereby notified that you have completed your terms) of supervision, as referenced above, and are no
+longer under the supervision of the Department of Corrections.
+If you were adjudicated guilty of a felony offense, your name will be submitted to the Plorida Parole Commission
+for consideration for restoration of the civil rights that you lost as a result of your felony conviction (right to vote,
+right to hold publio office, and the right to serve on a jury). If your rights are restored, a certificate of restoration of
+civil rights will be mailed by the Office of Executive Clemency to your last mailing address of record usually within
+one year following the termination of supervision. If your rights are not restored through this initial referral, you
+will be notified by the Florida Parole Commission and furnished an additional application for submission for
+restoration of civil rights with a hearing. If you have any questions about your civil rights, you may contact the
+Office of Executive Clemency for further information by calling (850) 488-2952 or by writing to that office at
+Florida Parole Commission, 2601 Blair Stone Road, Building C, Tallahasses, Florida 32399-2450. Information and
+application forms may be accessed through the following web site: www.state.fl.us/fps/exclem.html.
+After eight (8) years from termination of your supervision, you may apply to regain your right to own firearms.
+Applications can be obtained from the Office of Executive Clemency or be coessed by the website noted above.
+If adjudication was withheld, you did not lose your civil rights, however, the Florida Department of Law
+regarding this law.
+wishes for a very successful future.
+Sincerely,
+Candice Elkins
+If you were on supervision for a sexual offense, attached is a copy of the Notice of Responsibilities, whic
+outlines your continued responsibilities in eccordance with Florids Statute
+Original: Offender
+Copy:
+Offender File
+Florida Parole Commission (if applicable)
+Clerk of Court (if required)
+(Revised 03/03)
+
+
+A50
+Letter from Palm Beach Sheriff's Office Regarding Jeffrey Epstein's Participation
+in the Work Release Program, dated August 12, 2010
+"PALM BEACH COUNTY*
+SHERIFF'S OFFICE
+RIC L. BRADSHAW, SHERIFF
+ALTERNATIVE CUSTODY UNIT
+PHONE:
+FAX: (561) 688-4929
+E-MAIL:
+August 12" 2010
+To Whom It May Concern:
+Jeffery Epstein DOB L
+was a participant of the Palm Beach County Sheriff's Office
+work release program. Epstein was a participant of the work release program starting
+10/10/08 and ending 07/22/09.
+If you have any questions or concerns please contact me.
+3228 Gun Club Road • West Palm Beach, Florida 33406-3001
+• (561) 688-3000
+http://www.pbso.org
+- 1-
+B/12/2010
+Decument!
+
+
+A51
+Letter from Jack A. Goldberger to NYS Sex Offender Registry Regarding Florida Registration Level
+applicable to Jeffrey E. Epstein, dated August 12, 2010
+LIpp. A51-A52]
+ATȚERBURY GOLDBERGER
+WEISS,
+* JOSEPH R.AT TERBURY
+*I JACKA. GOLDBERGER
+"JASON S. WEISS
+Board Certified Criminal Trial Attorne
+Member of New Jersey & Florida Bar
+August 12, 2010
+New York State Division of Criminal Justice Services
+Sex Offender Registry
+4 Tower Place
+Albany, N.Y. 12203
+RE: Jeffrey E. Epstein
+To Whom It May Concern:
+The undersigned represented Jeffrey E. Epstein in the investigation that lead to his entry
+of a guilty plea on June 30, 2008 to a felony charge in the State of Florida that required
+sex offender registration. The purpose of this letter is to clarify the level of registration that
+was applicable to Mr. Epstein's case
+Under Florida's registration scheme there are two levels of registration available based on
+a risk assessment. Florida characterizes these two levels as sexual predator and sexual
+offender. The sexual predator designation is obviously the more serious classification.
+Mr. Epstein, based on the offense on which his guilty plea was entered, was classified as
+a sexual offender, Florida's lowest level of sexual registration. In fact, within the sexual
+offender designation there are two sub-levels of reporting requirements. One classification
+requires reporting to the local Sheriff's Office twice a year and one requires reporting four
+times a year. In Mr. Epstein's case he is required to report at the lowest level, two times
+per year. Accordingly, under the Florida registration scheme, Mr. Epstein's registration
+requirements are at the lowest level for a person for whom registration is required.
+During the incarcerative portion of Mr. Epstein's sentence, he was allowed to participate
+in the Sheriff's Office work release program, an option that would not have been available
+to him had he been at a higher registration level. Additionally, while Mr. Epstein was in
+probationary status, he was allowed to travel on a limited basis for business purposes.
+This would not have been available to him had he been classified as a sexual predator.
+One Clearlake Centre, Suite 1400 250 Australian Avenue South West Palm Beach, FL 33401
+• p 561.659.8300 f56l.835.8691 www.agwpa.com
+
+
+A52
+• I hope this information assists your department in determining the registration requirements
+for Mr. Epstein. Should you desire to speak to me or need any further information, please
+feel free to contact me.
+JAG/sim
+
+
+A53
+Letter from Martin G. Weinberg to NYS Board of Examiners of Sex Offenders Regarding
+Risk Level and Designation Determination for Jeffrey Epstein, dated August 16, 2010
+Ipp. A53-A57]
+MARTIN G. WEINBERG, P.C.
+ATTORNEY AT LAW
+20 PARK PLAZA, SUITE 1000
+BOSTON, MASSACHUSETTS 02116
+EMAIL ADDRESSES:
+August 16, 2010
+New York State
+Board of Examiners of Sex Offenders
+4 Tower Place
+Albany, New York 12203-3764
+Re:
+Jeffrey Epstein
+NYSID
+Dear Sir or Madam:
+This letter and the accompanying materials are submitted to the Board pursuant to its notice
+of August 2, 2010, concerning the risk level and designation determination to be made with respect
+to Jeffrey Epstein. Their purpose is to demonstrate to the Board that, based upon Mr. Epstein's
+history and personal characteristics, the circumstances of the offense which triggered the registration
+requirement, his acceptance of responsibility, his successful completion of his sentence and
+subsequent supervision, and the extraordinary unlikelihood of his ever again reoffending, the
+appropriate risk level designation is level 1.
+Overview
+Mr. Epstein, who is presently 58 years old, is a successful and respected financial advisor
+who also founded and heads a philanthropic organization, the C.O.U.Q. Foundation, Inc. which
+funds medical, educational, and advanced scientific research. The offense which led to the
+requirement that he register as a sex offender in Florida, which in turn triggered this state's reporting .
+requirement, ended almost five years ago and involved an exchange of money and consensual
+conduct with a young woman who, for all but a few months of the prostitution offense charged, was
+over the age of 17. Notably, as addressed in greater detail, infra, the conduct which occurred after
+A.D. reached the age of 17 would not even have been a misdemeanor under the cognate New York
+statute at the time the offense was committed.
+Mr. Epstein pled guilty to that offense in the Circuit Court for Paim Beach County, Florida,
+and has fully and sincerely accepted responsibility for his conduct. There have been no subsequent
+incidents of criminal misconduct of any description.
+
+
+A54
+Florida has classified Mr. Epstein as its lowest level sex offender, with the lowest level of
+reporting requirement, as verified by the attorney who represented Mr. Epstein in the Florida
+proceedings:
+Under Florida's registration scheme there are two levels of registration available based on
+a risk assessment. Florida characterizes these two levels as sexual predator and sexual
+offender. The sexual predator designation is obviously the more serious classification.
+Mr. Epstein, based on the offense on which his guilty plea was entered was classified as a
+sexual offender, Florida's lowest level of sexual registration. In fact, within the sexual
+offender designation there are two-sub-levels of reporting requirements. One classification
+requires reporting to the local Sheriff's Office wice a year and one requires reporting four
+times a year. In Mr. Epstein's case, he is required to report at the lowest level, two times per
+year. Accordingly, under the Florida registration scheme, Mr. Epstein's registration
+requirements are at the lowest level for a person for whom registration is required.
+Letter of Jack A. Goldberger, Esq., Ex. A. That Florida authorities did not - and do not - believe that
+Mr. Epstein presented a risk of reoffense is evidenced not just by Mr. Epstein's lowest-level
+reporting designation but also by the fact that he was permitted, while serving his sentence in the
+West Palm Beach County Jail, to leave the jail on a daily basis on work release for most of the period
+of his 13-month incarceration and that during his subsequent year of community control supervision
+(a probationary-type sentence), both the court and his probation officer agreed to permit him to travel
+outside Florida for business purposes on a significant number of occasions. He has now completed
+his year of community control supervision, having fully complied with all the requirements and
+obligations imposed on him.
+In addition, Mr. Epstein has participated in therapy with a clinical psychologist, Stephen R.
+Alexander, Psy. D., who, based on his evaluation of, and therapy sessions with, Mr. Epstein and his
+long experience as a forensic psychologist, attests that Mr. Epstein presents no threat to the
+community and that the risk of his reoffending is "negligible":
+Since my initial assessment of Mr. Epstein he has been extremely cooperative with all of the
+services provided to him. He has spent a great deal of time and energy focusing on his
+behavior and the attitudes, beliefs and expectations that undergird his approach to life. He
+has examined his priorities and undergone a comprehensive self-exploration on more than
+one occasion, primarily because of the vast changes that have occurred in his life and the
+upheaval these events have caused. Throughout it all Mr. Epstein has remained willing to
+focus on himself and how to turn even the most dire personal circumstances into productive
+experiences to the fullest extent possible. In my opinion Mr. Epstein has been highly
+cooperative with and benefited from the treatment provided. Relying upon my 25 years of
+experience as a forensic psychologist and the plethora of data gathered by me, 1 state with
+confidence that Mr. Epstein poses no threat to himself or the community. It is abundantly
+clear that he has learned his lesson and the probability of his reoffending is negligible. Mr.
+2
+
+
+A55
+Epstein poses no threat to either himself or the general community, and he requires no
+additional intervention or treatment for his no-risk/low-risk status to be maintained into the
+future.
+Letter of Stephen R. Alexander, Psy. D., submitted herewith as Ex. B.'
+All of these circumstances - Mr. Epstein's low-risk classification in Florida, the state
+where the offense was committed, the low-risk assessment inherent in the decisions of Florida
+authorities responsible for the protection of the community, who knew him first-hand, to admit
+him to work release during his period of incarceration and to permit him to travel outside of
+fact that Mr. Epstein is a mature, responsible, professional adult who uses neither alcohol nor
+drugs all support the conclusion that the supervision which accompanies a level 1 designation
+will more than suffice to serve the purposes of SORA. That conclusion is supported by the
+calculation of Mr. Epstein's risk assessment guidelines score.
+The Conduct Underlying the Offense Triggering the Florida Registration Requirement
+Would For the Most Part Not Even Have Been a Registerable Offense in New York Had
+the Conduct Occurred in New York
+The offense which required Mr. Epstein to register as a sex offender in the state of Florida
+was a violation of Fla. Stat. §796.03, which criminalizes procuring a person under the age of 18 (the
+age of consent in Florida) for prostitution, specifically, here, one "A.D." The nearest New York
+cognate among the registerable offenses listed in N.Y. Correction Law §168-a is N.Y. Penal Law
+§230.04 (patronizing a prostitute). The information to which Mr. Epstein pled guilty charged that
+the offense occurred between August 1, 2004, and October 9, 2005, see Information, Ex. C, that
+latter date being the day before A.D.'s 18th birthday: Thus, for almost all of the duration of the
+charged offense, A.D. was over the age of 17, and the wholly consensual conduct in exchange for
+money which occurred between the two would not even have been a registerable offense in New
+York. See §168-a(2)(a)(i)(§230.04 a registerable offense only if "person patronized" is in fact under
+17 years old). Indeed, at the time of the offense at issue, the conduct which occurred after A.D.
+turned 17 years of age would not even have been a crime under that statute if the conduct had taken
+place in New York.' Mr. Epstein's offense ranks among the least serious of those which trigger the
+requirement of SORA registration. The single Florida offense which required registration involved
+'Dr. Alexander's CV is included in Ex. B.
+' In 2007, §230.04 was amended to extend its coverage to prostitution offenses involving individuals
+of any age, not just those under the age of 17, as the statute was written when Mr. Epstein's offense
+was committed in 2004-05. Under §230.04 as written in 2004-05, the offense, to the extent that A.D.
+was in the last three months of her 16th year, would only have been a misdemeanor had it been
+committed in New York.
+3
+
+
+A56
+only one woman, and there was no force or violence involved at any time, nor did A.D. suffer from
+any mental disability, mental incapacity, or physical helplessness. The points attributable to the
+Current Offense factors (factors 1-7) total less than 70.
+Criminal History
+Prior to the offense at issue, Mr. Epstein had no prior criminal history whatsoever. Mr.
+Epstein's date of birth is January 20, 1953, and he was, accordingly, more than twenty years of age
+when the offense at issue was committed. Mr. Epstein does not use alcohol or illegal drugs and has
+no history of either drug or alcohol abuse. Accordingly, Mr. Epstein should be scored at zero for the
+Criminal History factors (factors 8-1 1).
+Post-Offense Behavior
+On June 30, 2008, Mr. Epstein pled guilty to the offense which subjected him to the
+requirement that he register as a sex offender in Florida and has fully accepted responsibility for his
+conduct. Mr. Epstein served approximately 13 months in a West Palm Beach County jail (rather than
+in a state correctional facility). During most of his period of confinement, from October 10, 2008,
+through July 22, 2009, the date of his release, Mr. Epstein participated in the jail's work release
+program, see Letter of Deputy K. Smith, Ex. D, which permitted him to leave the jail in the morning
+six days a week for his place of employment, the Florida Science Foundation, and return in the
+evening. That Mr. Epstein satisfactorily complied with the requirements of the program is evidenced
+by the fact that he remained in the work release program up to the time of his release from custody.
+After his release on July 22, 2009, Mr. Epstein was subject to a one-year period of
+community control, which required, among other conditions, that he maintain contact with the
+probation office as required, that he be confined to his residence during the hours when he was not
+working or performing public service, that he not leave his county of residence without the consent
+of his probation officer, that he commit no further violations of the law, and that he maintain
+employment. During Mr. Epstein's period of community control from July 22, 2009, through July
+21, 2010, he was permitted by the court, with the assent of his probation officer and without
+opposition by the state's attorney, to travel (including overnight stays) to New York and to the Virgin
+Islands for business purposes on a number of occasions, thus demonstrating a substantial level of
+trust by both the court and his supervising probation officer in Mr. Epstein's ability to refrain from
+unlawful conduct of any kind and to conform his conduct to the terms of his community control
+order and to the orders authorizing his travel, which he did on every such occasion. Mr. Epstein
+successfully completed his term of community control on July, 21, 2010, see Florida Department of
+Corrections Termination of Supervision notice, Ex. F, having at all times fully complied with all
+obligations and restrictions imposed upon him.
+Mr. Epstein has never refused or been expelled from any treatment since the time of his
+sentencing (factor 12(2)): See pages 2-3, supra. Based on his professional expertise and the
+" One such travel order is attached as Ex. E.
+4
+
+
+A57
+substantial time he has spent with Mr. Epstein, Dr. Alexander is able to state unequivocally that Mr.
+Epstein has learned his lesson, that he presents no threat to the community, and that there is
+negligible risk that he will ever reoffend. Accordingly, Mr. Epstein should be scored at zero for the
+Post-Offense Behavior factors (factors 12-13).
+Release Environment
+Factor 14 contemplates that the risk level assessment will be made, as required under New
+York law, prior to the offender's release from incarceration. Here, as the preceding section shows,
+Mr. Epstein was released from jail more than a year ago and was subject to close supervision for a
+period of one year afterwards. During the same time, he continued to meet with Dr. Alexander. The
+score for factor 14 should, accordingly, be zero.
+Mr. Epstein maintains a vacation residence in Manhattan, which he owns, as well as
+residences in Florida and the Virgin Islands. Mr. Epstein's interactions in connection with both his
+employment and philanthropic work are with adult business professionals, scientists, and educators.
+There is nothing in either Mr. Epstein's living or employment situations which could even remotely
+be considered "inappropriate." The score on factor 15 too should be zero.
+Overrides
+None of the listed factors are of any relevance or applicability to Mr. Epstein's risk level
+designation.
+Conclusion
+Based on all the relevant factors, Mr. Epstein should be classified as a level 1 sex offender.
+Even should the Board somehow conclude that Mr. Epstein's risk assessment guidelines score
+exceeds 70, the circumstances addressed in this letter differentiate this case so markedly from the
+norm of level 2 sex offenders that the Board should recommend a level 1 classification, as it is
+empowered to do under the Sex Offender Guidelines. The ultimate issue is the risk that the offender
+will reoffend, and the information provided to the Board with this letter persuasively demonstrates
+that such a risk is virtually nonexistent in this case.
+y truly your
+Machine Keebe
+Weinberg 4.
+5
+
+
+A58
+Letter from Stephen R. Alexander, Psy. D. to Jack Goldberger Regarding Opinion of Jeffrey E. Epstein,
+dated August 16, 2010
+Ipp. A58-A61]
+- -
+Stephen R. Alexander, Psy.D.
+Clinical Psychologist
+825 Forest Hill Boulevard. Suite 20
+West Palm Beach, Florida 33406
+August 16, 2010
+Jack Goldberger, Esq.
+Atterbury, Goldberger and Weiss, P.A.
+250 South Australian Avenue, Suite 1400
+West Palm Beach, Florida 33401
+Re.: Jeffrey Epstein
+Dear Mr. Goldberger:
+Since my initial assessment of Mr. Epstein he has been extremely cooperative with all of
+the services provided to him. He has spent a great deal of time and energy focusing on
+his behavior and the attitudes, beliefs and expectations that undergird his approach to life.
+He has examined his priorities and undergone a comprehensive self-exploration on more
+than one occasion, primarily because of the vast changes that have occurred in his life
+and the upheaval these events have caused. Throughout it all Mr. Epstein has remained
+willing to focus on himself and how to turn even the most dire personal circumstances
+into productive experiences to the fullest extent possible. In my opinion Mr. Epstein has
+been highly cooperative with and benefited from the treatment provided. Relying upon
+my 25 years of experience as a forensic psychologist and the plethora of data gathered by
+me, I state with confidence that Mr. Epstein poses no threat to himself or the community.
+It is abundantly clear that he has Icarned his lesson and the probability of his reoffending
+is negligible. Mr. Epstein poses no threat to either himself or the general community, and
+he requires no additional intervention or treatment for his no-risk/low-risk status to be
+maintained into the future.
+If any questions remain or I can be of additional assistance, please contact my office.
+Sincerely,
+Stephen R. Alexander, Psy.D.
+Clinical Psychologist
+SRA/b
+Epstein-06037-L2A
+
+
+A59
+Stephen R. Alexander, Psy.D.
+Clinical Psychologist
+1825 Forest Hill Boulevard, Suite 204
+West Palm Beach, Florida 33406
+Psy.D.
+M.S.
+B.A.
+EDUCATION
+Florida Institute of Technology; Clinical Psychology, 1985
+Sastern Kentucky University; Clinical Psychology, 198(
+Jniversity of North Carolina at Chapel Hill; 197
+LICENSURE
+Florida Board of Psychological Examiners: Psychologist, PY0003713
+CERTIFICATIONS
+Supreme Court of Florida: Family Court Mediator 19355 CF
+Supreme Court of Florida: County Court Mediator 19355 CF
+PROFESSIONAL EXPERIENCE
+Clinical Psychologist: Private practice providing services to children, adolescents
+adults and families. Specialization in psychodiagnostic evaluations (personality, forensic,
+psychoeducational), forensic psychology, and psychotherapy. July 1989 to present.
+Chief Psychologist: Juvenile and Family Divisions of the Fifteenth Judicial Circuit and
+Division of Youth Affairs, Paim Beach County, Florida. September 1987 to July 1989.
+Duties: Supervise Psychological Services provided to Juvenile and Family Court
+including psychological evaluations of children, adolescents and adults
+in delinquency, dependency, custody, and sex abuse cases; testimony as
+Expert Witness.
+Program Supervision of Sable Palm Youth Service Center, a 48 bed
+residential treatment program for emotionally and behaviorally disturbed
+adolescents; family therapy approach to treatment.
+Program Supervision of the Youth Service Bureau, a community based
+family counseling/delinquency prevention program.
+Directing program evaluation and basic research within the Division of
+Youth Affairs.
+Directing APA Approved continuing education office for professiona
+taff under the Chief Psychologist (5 Psy.D./Ph.D. psychologists, and 20
+M.A./M.S.W. counselors).
+
+
+A60
+Division of out A veis Pal Bei Dinite ore Deteries a rea
+1987
+Duties: Psychodiagnostic evaluations of children, adolescents and adults for the
+ourt in delinquency, dopendency, custody and sex abuse cases. Clinice
+upervisor of the Sable Palm Youth Service Cente
+Staff Psychologist: Scotland County Mental Health Center, Laurinberg, North Carolina.
+February to August 1982.
+Duties: Indpatient) Consin po Scothed County School scrim. Competency
+evaluations for courts.
+Staff Psychologist: Robeson County Mental Health Center, Lumberton, North Carolina.
+August 1980 to July 1981.
+Duties: Outpatient Individual and family psychotherapy (60% child services,
+40% adult outpatient). Psychodiagnostic evaluations for Center patients,
+local courts, and the Division of Vocational Rehabilitation.
+Program evaluation of 15 Head Start Centers in a four county area for
+H.E.W.
+Consultant to Red Springs City School system, Southeastern Sheltered
+Workshop, and Robeson County Group Homes.
+INTERNSHIP
+PRACTICUM PLACEMENTS
+Neuropsychiatry Unit: Wuesthoff Memorial Hospital, Rockledge, Florida. 20 hours
+per week (200 total hours); January to March, 1984.
+
+
+A61
+Center for Student Development: Florida Institute of Technology, Melboume, Florida
+10 hours per week (200 total hours); June to December 1983.
+Ielbourne Head Start Center: Melbourne, Floride. 10 hours per week (100 tot
+ours); September to December 198
+Robeson County Mental Health Center: Lumberton, North Carolina. 40 hours per
+week (1040 total hours); January to June 1980.
+Jniversity of Kentucky Medical Center (Outpatient Psychiatry): ' Lexingtor
+kentucky. 20 hours per week (640 total hours); January to December 1979
+PUBLICATIONS & RESEARCH PAPERS
+Alexanders Upationed manus. Delinquency prevention in a Youth Service
+lexander, S. (1992). Choosing and using experts. In, Child Custody and Visitation i
+lorida. Eau Claire, WI: National Businese Institute, In
+AWARDS
+1993 Special Service Award presented by the Legal Aid Society and the Palm Beach
+County Bar Association for pro bono services to the community.
+PROFESSIONAL POSITIONS
+Education Chair of the Palm Chapter of the Florida Psychological Association, 1994.
+President of the Palm Chapter of the Florida Psychological Association, 1995.
+COMMUNITY SERVICE POSITIONS
+Board of Directors Fern House, West Palm Beach, Florida. Fern House is a residential
+rehabilitation center for male alcoholics and drug addicts. 2004 to present.
+
+
+
+Offender Name:
+NYSID #:
+OS1909
+1ST Reviewer Initials:
+50w
+The following is the Board of Examiners of Sex Offenders' recommendation pursuant to Section 168-l of Article 6-C of the NYS Correction Law as to whether the offender shall be
+designated a Sexually Violent Offender, Predicate Sex Offender, or Sexual Predator as defined in subdivision seven of Section 168-a or whether the offender does not fit any of those
+categories due to his conviction.
+Please check all that apply:
+] Sexually Violent Offender - a sex offender who has been convicted of a sexually violent offense defined in Correction Law section 168-a (3).
+Please check which conviction(s) apply, also please indicate whether the conviction was for an attempt at an offense:
+Attempt
+Attempt
+130.35 - Rape Ist degree
+130.53 - Persistent sexual abuse
+130.50 - Sodomy 1st degree/Criminal Sexual Act Ist degree
+130.65-a - Aggravated sexual abuse 4th degree
+130. 65 - Sexual Abuse Ist degree
+130.90 - Facilitating a sex offense with a controlled substance
+130.66 - Aggravated sexual abuse 3rd degree
+foregoing on of a convicted of are pie a crime tired inside 483,05
+130.67- Aggravated sexual abuse 2nd degree
+of the penal law or as a crime of terrorism defined in section 490.25 of such law.
+130.70 - Aggravated sexual abuse Ist degree
+a conviction of as fense in any ory pride for abide in dude ail of a reloany
+130.75 - Course of sexual conduct against a child Ist degree
+in any other jurisdiction for which the offender is required to register as a sex
+offender in the jurisdiction which the conviction occurred.
+-
+130.25 - Rape 3rd degree
+255.25 - Incest
+135.25 - Kidnapping Ist degree
+130.30 - Rape 2nd degree
+Article 263 offense - Sexual Performance by a Child
+130.40 - Sodomy 3rd degree/
+135.05 - Unlawful Imprisonment 2nd degree
+Criminal Sexual Act 3rd
+(*Note: 135.05, 135.10, 135.20, 135.25 - the
+i30.45 - Sodomy 2nd degree/
+135.10 - Unlawful Imprisonment Ist degree
+- Criminal Sexual Act 2nd
+Recommendation of Board of Examiners of Sex Offenders, Including Risk Assessment Instrument,
+A62
+130.80 - Course of sexual conduct against a child 2nd degree
+[pp. A62-A66]
+Predicate Sex Offender - a sex offender who has been convicted of an offense set forth in subdivision 2 or 3 of Correction Law Section 168-a when the offender has been previously
+convicted of an offense set forth in subdivision 2 or 3 of Section 168-a, regardless of the date of the prior conviction and regardless of whether the offender was
+required to register for the previous conviction.
+Please identify below the offenders previous qualifying conviction(s) as well as the offender's current qualifying conviction, also please indicate whether the conviction was for an attempt at an
+offense:
+Current Previous • Attemps
+130.20 - Sexual Misconduct
+130.60 - Sexual Abuse 2nd degree
+Znd
+dated August 19, 2010 and P. A -Amary, dated August 23, 2010
+Continued on the next page.
+
+I. (Cont'd)
+230.04 - Patronizing a prostitute 3rd degree (victim <17 years old)
+230.05 - Patronizing a prostitute 2nd degree
+230.06 - Patronizing a prostitute 1st degree
+230.30 (2) - Promoting prostitution 2nd degree
+230.32 - Promoting prostitution Ist degree
+235.22 - Disseminating indecent material to minors Ist degree
+a conviction of or a conviction for an attempt to commit any provisions of a
+listed sex offense committed or attempted as a hate crime defined in section
+485.05 of the penal law or as a crime of terrorism defined in section 490.25
+of such law.
+130.52 - Forcible touching (victim<18 years old)
+130.55 - Sexual abuse 3rd degree (victim<18 years old)
+Conviction/Attempt to commit any provision of 130.52 or 130.35 of the
+penal law regardless of age of victim and the offender has previously been
+convicted of: (i) a sex offense listed in Correction Law Section 168-a (2), or
+(ii) a sexually violent offense listed in Correction Law Section 168-a (3), or
+(il) any of the provisions of section 130.52 or 130.55 of the penal law or an
+attempt thereof.
+A conviction of (i) an offense in any other jurisdiction which includes all of the
+essential elements of any such crime provided for in Correction Law Section
+168-a (2) (a), or (ii) a felony in any other jurisdiction for which the offender is
+required to register as a sex offender in the jurisdiction in which the conviction
+occurred, or (ill) any of the provisions of 18 U.S.C. 2251, 18 U.S.C. 2251A, 18
+U.S.C. 2252, 18 U.S.C. 2252A, or 18 U.S.C. 2260 provided the elements of
+such crime of conviction are substantially the same as those which are part of
+such offense as of March 11, 2002.
+130.35 - Rape Ist degree
+130.50 - Sodomy Ist degree/Criminal Sexual Act ist degree
+130. 65 - Sexual Abuse Ist degree
+130.66 - Aggravated sexual abuse 3rd degree
+130.67- Aggravated sexual abuse 2nd degree
+130.70 - Aggravated sexual abuse Ist degree
+130.75 - Course of sexual conduct against a child 1st degree
+130.80 - Course of sexual conduct against a child 2nd degree
+130.53 - Persistent sexual abuse
+130.65-2 - Aggravated sexual abuse 4th degree
+130.90 - Facilitating a sex offense with a controlled substance
+a conviction of or a conviction for an attempt to commit any
+Law Senion a a l omited rates per as intercion.
+defined in section 485.05 of the penal law or as a crime of
+terrorism defined in section 490.25 of such law.
+a conviction of an offense in any other jurisdiction which includes
+all of the essential elements of any such felony provided for
+above or conviction of a felony in any other jurisdiction for which
+the offender is required to register as a sex offender in the
+jurisdiction which the conviction occurred.
+250.45(2),(3)and(4) - Unlawful surveillance 2nd degree
+250.50 - Unlawful surveillance Ist degree
+Sexual Predator - a sex offender who has been convicted of a sexually violent offense defined in Correction Law Section 168-a (3) and who suffers from a mental abnormality or
+personality disorder that makes him or her likely to engage in predatory sexually violent offenses.
+None of the above.
+63
+
+
+SEX OFFENDER REGISTRATION ACT
+RISK ASSESSMENT INSTRUMENT
+RISK FACTOR
+VALUE
+I. CURRENT OFFENSE(S)
+1. Use of Violence
+Used forcible compulsion
+Inflicted physical injury
+Armed with a dangerous instrument
++10 X
++151
++30
+2. Sexual Contact with Victim
+Contact over clothing
++5
+Contact under clothing
++10
+Sexual intercourse, deviate sexual intercourse
++25 X
+or aggravated sexual abuse
+3. Number of Victims
+Two
+Three or more
+4. Duration of offense conduct with victim
+Continuing course of sexual
+misconduct
++20
++30 X
++20 X
+5. Age of victim
+Il through 16
+10 or less, 63 or more
+6. Other victim characteristics
+Victim suffered from mental disability or
+incapacity or from physical helplessess
++20 X
++30
++20
+7. Relationship with vietim
+Stranger or established for purpose of
+victimizing or professional relationship
++20
+TI. CRIMINAL HISTORY
+%. Age ar irst act of sexual misconduct
+20 or less
++10
+9. Number and nature of prior crimes
+Prior history/no sex crimes or felonies
+Prior history/non-violent felony
+Prior violent felony, or misdemeanor sex
+crime or endangering welfare of a child
+10. Recency of prior uffense
+Less than 3 years
+Il. Drug or Alcohol abuse
+History of abuse
++5
++15
++30
++10
++15
+COLUMNS 1- 11 SUBTOTAL
+SCORE
+10
+25
+30
+20
+20
+SEX OFFENDER REGISTRATION ACT
+RISK ASSESSMENT INSTRUMENT
+RISK FACTOR
+VALUE
+TIL POST-OFFENSE BEHAVIOR
+TL. Acceptance of Responsibility
+Not accepted responsibility
+Not accepted responsibility / refused or
+expelled from treatment
++10
++15
+13. Conduct while confined / supervised
+Unsatisfactory
+Unsatisfactory with sexual misconduct
++10
++20
+TV. RETEASE ENVIRONMENT
+14. Supervision
+Release with specialized supervision
+Release with supervision
+Release without supervision
+15. Living / employment situation
+Living or employment inappropriate
++5
++151
++10
+COLUMNS 12-15 SUBTOTAL
+COLUMNS 1-11 SUBTOTAL
+TOTAL RISK FACTOR SCORE (add 2 subtotals)
+SCORE
+130
+130
+20
+Level 1 (low)
+Level 2 (moderate )
+Level 3 (high)
+0 to +70
++75 t0 +105
+• +110 to +300
+Offender
+Name:
+NYSID #:
+OS1909
+Docket #:
+RISK LEVEL:
+Assessor's
+Signature
+8-19-10
+A. Overrides (If any override is circled, offender is presumptively
+a Level 3)
+1. Offender has a prior felony conviction for a sex crime
+2. Offender inflicted serious physical injury or caused death
+3. The federa sad inter ta will coited.
+4. There has been a clinical assessment that the offender has
+a psychological, physical, or organic abnormality that
+decreases ability to control impulsive sexual behavior
+B. Departure
+1. A departure from the risk level is warranted
+Yes
+• No
+2. If yes, circle the appropriate risk level 1 2
+3. If yes, explain the basis for departure (See Summary)
+Noted ThE an often re trades regies at coum impacte
+statement in determining a sex offender's level of risk.
+El
+FT A00180990
+130
+
+A65
+DATE:
+NYSID #: OS1909
+8/23/2010
+CASE SUMMARY
+This assessment is based upon a review of the inmate's file which may include but is not limited to the
+pre-sentence investigation, prior criminal history and post-offense behavior.
+Jeffrey Epstein is a 57-year-old sex offender who pled guilty in the state of Florida on 6/30/2008 to two felony
+sex offenses, Procuring a Person Under 18 for Prostitution and Felony Solicitation of Prostitution. He was
+sentenced to12 months in jail followed by 12 months of Community Control.
+It would appear he was convicted in London England of Unlawful Possession of an Offensive Weapon, a Sword
+Stick, and was sentenced to a Conditional Discharge on 1/4/1973.
+Regarding the instant offense, Epstein was approximately 5l years of age on or about the year 2005 when he
+sexually assaulted numerous females between the approximate ages of 14 and 17. Most of the victims were
+recruited by one of Epstein's female employees from a local high school in the Palm Beach Florida area. Some of
+the female participants were age 18 or older. The contact included vaginal intercourse, mouth to vagina sodomy,
+the touching of the breasts and vagina, placing his fingers inside the vagina and Epstein using a vibrator on the
+victim's vaginal area. The available police reports from the Palm Beach Police Department include conversations
+with numerous female victims who in most cases, did not know Epstein when they were victimized. Most of the
+females were embarrassed to speak with police regarding what had happened to them while they were at Epstein's
+home. Sworn statements were taken from at least five victims and seventeen witnesses concerning massages and
+unlawful sexual activity that took place at the residence of Jeffrey Epstein. Most of the victims were paid at least
+$200.00 each time they performed a massage.
+The victims were told they would be giving Epstein a massage and they were escorted to his bedroom. Most
+victims noted numerous pictures of naked young females, (some of the photos depicted females who would be
+eventually interviewed by police), on display throughout the home. The offender would enter the room only
+wearing a towel. In most cases he would remove the towel and ask the victim to remove her clothing. In some
+cases he would masturbate into a towel while receiving a massage. In other cases he would touch the breasts or
+vagina of the victim with his hands or use the vibrator. One 14 year old. described how Epstein touched her
+vaginal area with a vibrator and thereafter, when contacted by law enforcement, she had to identify the offender
+through the use of a photo array. Another 16-year-old victim described giving Epstein massages for tavo years
+and at times, he grabbed her buttocks and caressed her butt cheeks as she gave him a massage. Another
+16-year-old described going to the offender's home at least 100 times. He would touch her breasts, insert his
+fingers into her vagina and sometimes use the vibrator on her while masturbating. He would also pay this
+underage victim to have sex with a female friend while he watched. Occasionally, he would join both girls and
+perform oral sex on both. This 16-year-old victim described for police how one time, Epstein turned her over on
+the massage table and forcibly raped her. When she screamed, "NO," he stopped and subsequently apologized for
+his actions.
+The offenders conduct while on Community Control will be considered satisfactory and he does not have a
+history of substance abuse. Based upon his plea of guilty, Epstein will be credited with accepting responsibility
+for his actions. He will be scored for sexual and deviate sexual intercourse, forcible compulsion, numerous
+victims and their ages, a continued course of sexual misconduct, a prior misdemeanor conviction in England
+absent specific information, for his stranger relationship to most victims and for establishing a relationship with
+these underage girls for the purpose of victimization.
+The Board acknowledges correspondence received from the offender's attorney.
+
+
+A66
+NYSID #: OS1909
+DATE:
+8/23/2010
+CASE SUMMARY
+Jeffrey Epstein used his wealth and power in such a way so that he could take advantage of many teenage girls to
+satisfy his own sexual perversions. He scores as a Level Ill Sex Offender with absolutely no basis for downward
+departure.
+
+
+A67
+Letter from Supreme Court attaching Notification, Recommendation and Notice of Right to Appeal,
+dated August 26, 2010
+Suprene Court
+- of lie
+State of Wet Work
+TO:
+PART 66
+FROM: CORRESPONDENCE UNIT
+SUBJECT: SEX OFFENDER RISK ASSESSMENT
+RE: Jeffrey Epstein
+SCID. #30129-2010
+Please refer to the attached:
+1) Notification to sex offender, defense attorney and D.A.'s office of the
+scheduled risk assessment;
+2.) Recommendation from Board of Examiners
+3.) Notice of Right to Appeal and Appeal Application.
+Please be advised that the above named defendant. his assigned counsel, Sex Crimes Unit of the D.A.'s
+office, City and State Correctional Facilities have been notified of the sex offender risk level assessment
+hearing which has been scheduled in your part.
+Upon completion of the risk assessment, you must endorse the calendar and worksheel and forward the
+COURT FILE AND ASSESSMENT DOCUMENTS to this office.
+BE FURTHER ADVISED THAT THE DIVISION OF PAROLE, MAY HOLD THE
+DEFENDANT UNTIL A RISK LEVEL HAS BEEN ASSIGNED.
+A REQUEST FOR 18B ASSIGNMENT HAS BEEN MADE. ONCE YOU
+ARE NOTIFIED THAT ANATTORNEY HAS BEEN ASSIGNED PLEASE
+SEND THE ATTACHED NOTIFICATION LETTER AND BOARD OF
+EXAMINER'S PACKAGE TO HIM/HER
+
+
+A68
+Letter from Supreme Court to Jeffrey E. Epstein Informing of SORA Level Determination Hearing,
+dated August 26, 2010
+Supreme Onurt
+of the
+State of Weir Wack
+August 26. 2010
+100 CENTRE STREET
+NEW YORK, N.Y. 10013
+Mr. Jeffrey Epstein
+9 East 71" Street
+New York. N.Y. 10021
+Re: SCID # 30129-2010
+Dear Mr. Epstein:
+Please he advised that pursuant to the 1996 Sex Offender Registration Act. the court must conduct a
+hearing lo determine whether you will be classified as a level 1, 2 or 3 sex offender and if' you will be
+designated as a sexual predator. a sexually violent offender or a predicate ses offender. The court's
+decision will determine how long you must registeras a sex offenderand how much information can he
+provided to the public concerning your registration. The court's determination may be higher. laserorthe
+same as the one recommended by the Board of Examiners.
+• Your hearing has been scheduled for September 15, 2010 at 9:30 a.m.. before the Hon. Ruth Pickholz.
+in part 66 located at 111 Centre Street. New York. N.Y. You have aright to attend this hoaring. you
+wish to waive your appearance for the hearing enclosed is a waiver form which must he notorized and
+returned to this office within ten days of receipt. A request has been made for an attorney to
+represent you at this hearing.
+If you fail to appear at this proceeding, without sufficient excuse, it shall be hekd in your absence. Failure
+to appear may result in a longer period of registration or a higher level of community notification because
+you are not present to offer evidence or contest evidence offered by the District Attorney:
+Enclosed please find the Board of Examiners summary with their recommendation that you he assigned
+arisk level of 3 and a document which describes what your duties will be after you are assigned risk level.
+At the conclusion of the determination hearing you will receive a copy of the count's final recommendation
+with a nolice lo appeal.
+enes.
+Very truly yours.
+Mary A. Price. (C'S
+Supreme Court - Criminal Term. New York ( nunty
+
+
+Court
+County
+A69
+Order Sheet for Jeffrey Epstein, dated August 26, 2010
+Ipp. A69-A70]
+Supreme Court. Criminal Term
+New York
+ORDER SHEET
+Date
+August 26.2010
+Part
+Correspondence Unit
+The People of the State of New York,
+VS.
+Dricker Ind.#
+30129-2010
+Jeffrey lipstein
+Defendant
+Flighest Charge (l'enal 1 aw)
+Homicide
+Felony
+Miscemeanor
+Violations
+Special Proceeding
+Sex ()ffender Hearing
+Being satisfied afict a review of the fmancial status of the defendant named, that he is financially unable do altain
+crensel, and upon his request for the appuintment of counsel, it is.
+(Ordered that the following member of the Bar be and hereby is appointed to represent such defendant in all
+matters pertaining to this action:
+Procuring a person unde 18pa Mentalities.
+. Idjourned Date
+Scpr. 15. 2010
+•leourned Part
+06
+Assigning /nige
+Ruth Pickhole.
+Pamled
+Bailed
+Incarceraree
+9 las 71ª Set, New York. N.Y.
+Defendant's Status:
+Defendant's Alress:
+Comments:
+Prior Money:
+Clerk's Name:
+57
+Telephone #
+• -
+•
+
+
+A 70
+TRANSMISSION VERIFICATION REPORT
+TAME: CORRES IN LN10:58
+FAX
+CORRESP UNIT
+SER. # BROKS356431
+ATE, TIME
+AX NO. /NAM
+DURATION
+PAGE (S)
+RESULT
+MODE
+฿8/26
+10:58
+18B ASSİGNED
+00: 00:18
+01
+STANDARD
+Court
+County
+Supreme Court, Criminal Term
+New York
+ORDER SHEET
+Dale August 26:2010
+Part
+Correspondence Unit
+The Pcople of the State of New York.
+vS.
+Docker Ind.#
+30129-2010
+Jeffrey Einstein
+Deferint
+Highest Charge (Penal 1aw)
+Homicide
+Feinny
+Misdemeanor
+Violation
+Special Proceeding
+Six Offender Fleting
+runsel, and upon his reque
+ei, sition hit rogues for of ap fireme stater the defendant named, that he is francinly unalic to rileni
+(edered that the following member of the Bar be and hereby is appointed to represent such de fondlar in all
+matters pertaining to this action:
+Procuries a person Unde/Sue Crantotate.
+'_..l that
+Sor 15 2010
+Adjourned Part
+
+
+A71
+Letter from Supreme Court to Come is, dated A SOR 26, 2vel Determination Hearing
+Ipp. A71-A76]
+Supreme Onurt
+of the
+State of Nein Work
+DO CENTRE STREE
+YEW YORK, N.V. 1001:
+August 20.2010
+Defense Atlorney
+18B To Be Assigned
+Ms. Inn-Young Park
+NYC District Attorneys Office
+1 Hogan Place. Room 83)
+New York. N.Y. 10013
+Re: Jeffrey Epstein
+SCID # 30129-2010
+Dear Sir/Madam:
+The above named defendant is scheduled for a Sex Offender Risk Level Determination hefore the Hon.
+Ruth Pickholz in part 66 on September 15. 2010 at 9:30 a.m. The defendant has been notified under
+separate cover of this hearing and forwarded a copy of the Board of Examiners recommendation.
+advised of his/her right to appear: advised of the name and address of the attorney assigned 1o
+represent him or that one is heing assigned. risk level guidelines, and of his right to waive his
+appearance.
+Enclosed please find a copy of'the Board of lixaminers recommendation.
+Very truly yours.
+Supreme Court - Criminal Term
+New York County
+enc.
+
+
+
+Offender Name:
+NYSID #:
+OS1909
+"he following is the Board of Examiners of Sex Offenders' recommendation pursuant to Section 168-i of Article 6-C of the NYS Correction Law as to whether the offender shall be
+esignated a Sexually Violent Offender. Predicate Sex Offender, or Sexual Predator as defined in subdivision seven of Section 168-a or whether the offender does not fit any of those
+ategories due to his conviction.
+lease check all that apply:
+Sexually Violent Offender - a sex offender who has been convicted of a sexually violent offense defined in Correction Law section 168-a (3).
+Please check which conviction(s) apply: also pleuse indicate whether the conviction was for an attempt at an offense:
+Allempi
+Attempt
+130.35 - Rape Ist degree
+130.53 - Persistent sexual abuse
+130.50 - Sodomy Ist degree/Criminal Sexual Act Ist degree
+130. 65 - Sexual Abuse Ist degree
+130.60 - Aggravaled sexual abuse 3rd degree
+130.67- Aggravated sexual abuse 2nd degree
+130.70 - Aggravated sexual abuse 1st degree
+130.65-a - Aggravated sexual abuse 4th degree
+130.90 - Facilitating a sex offense with a controlied substance
+forning or of or convictio fara prem as coming proud inscion 85.05
+of the penal law or as a crime of terrorism defined in section 490.25 of such law:
+130.75 - Course of sexual conduct against a child 1st degree
+130.80 - Course of sexual conduct against a child 2nd degree
+sonia in an or as in at predictor abi or ore an or tony.
+in any other jurisdiction for which the offender is required to register as a sex
+offender in the jurisdiction which the conviction occurred.
+Predicate Sex Offender - a sex offender who has been convicted of an offense set forth in subdivision 2 or 3 of Correction Law Section 168-a when the offender has been previously
+convicted of an offense set forth in subdivision 2 or 3 of Section 168-a, regardless of the date of the prior conviction and regardless of whether the offender was
+required to register for the previous conviction.
+offense:
+Current Previous Attempl
+Current Previous
+130.20 - Sexual Misconduct
+130.25 - Rape 3rd degrec
+130.30 - Rape 2nd degree
+130.40 - Sodomy 3rd degree/
+Criminal Sexual Act 3rd
+i30.45 - Sodomy Ind degree!
+Criminal Sexual Act 2nd
+Attemp:
+130.60 - Sexual Abuse 2nd degree
+255.25 - Incest
+Article 263 offense - Sexual Performance by a Child
+135.05 - Unlawful Imprisonment 2nd degree
+135.10 - Unlawful Imprisonment Ist degree
+-
+135.20 - Kidnapping 2nd degree
+135.25 - Kidnapping Ist degree
+(*Note: 135.05. 135.10. 135.20, 135.25 - the
+victim must be less than 17 years old and the
+offender must not he the parent of the victim)
+Continued on the next page.
+A
+
+1. (Cont'd)
+Jurrent Previous Attempi
+230,04 - Patronizing a prostitute 3rd degree (victim <17 years old)
+230.05 - Patronizing a prostitute 2nd degree
+230.06 - Patronizing a prostitute Ist degree
+230.30 (2) - Promoting prostitution 2nd degrec
+230,32 - Promoting prostitution Ist degree
+235.22 - Disseminating indecent material to minors Ist degree
+a conviction of or a conviction for an attempt to commit any provisions of a
+listed sex offense committed or attempled as a hate crime defined in section
+485.05 of the penal law or as a crime of terrorism defined in section 490.25
+of such law:
+130.52 - Forcible touching (victim<18 years old)
+130.55 - Sexual abuse 3rd degree (victim<18 years old)
+Conviction/Attempt to commit any provision of 130.52 or 130.55 of the
+penal law regardless of age of victim and the offender has previously been
+convicted of: (i) a sex offense listed in Correction Law Section 168-a (Z), or
+(il) a sexually violent offense listed in Correction Law Section 168-a (3), er
+(ill) any of the provisions of section 130.52 or 130.55 of the penal law: or an
+attempt thereof.
+A conviction of (i) an offense in any other jurisdiction which includes all of the
+essential elements of any such crime provided for in Correction Law Section
+168-a (2) (a), or (ii) a felony in any other jurisdiction for which the offender is
+required to register as a sex offender in the jurisdiction in which the conviction
+occurred, or (ill) any of the provisions of 18 U.S.C. 2251, 18 U.S.C. 2251A, 18
+U.S.C. 2252, 18 U.S.C. 2252A, or 18 U.S.C. 2260 provided the elements of
+such crime of conviction are substantially the same as those which are part of
+such offense as of March 11, 2002.
+130.35 - Rape Is degree
+130.50 - Sodomy Ist degree/Criminal Sexual Act Ist degree
+130. 65 - Sexual Abuse Ist degree
+130.66 - Aggravated sexual abuse 3rd degrec
+130.67- Aggravated sexual abuse 2nd degree
+130.70 - Aggravated sexual abuse 1st degree
+130.75 - Course of sexual conduct against a child ist degree
+130.80 - Course of sexual conduct against a child 2nd degree
+130.53 - Persistent sexual abuse
+130.65-2 - Aggravaied sexual abuse 4th degree
+130.90 - Facilitating a sex offense with a controlled substance
+a conviction of or a conviction for an attempt to commit any
+provisions of a sexually violent offense as set forth in Correction
+Lav Section 168-a (3) committed or attempted as a hate crime
+defined in section 485.05 of the penal law or as a crime of
+terrorism defined in section 490.25 of such law.
+a conviction of an offense in any other jurisdiction which includes
+all of the essential elements of' any such felony provided for
+above or conviction of a felony in any other jurisdiction for which
+the offender is required to register as a sex offender in the
+_ jurisdiction which the conviction oçcurred.
+250.45(2).(3)and(4) - Unlawful surveillance 2nd degree
+250.50 - Unlawful surveillance 1st degree
+Sexual Predator - a sex offender who has been convicted of a sexually violent offense defined in Correction Law Section 168-a (3) and who suffers from a mental abnormality or
+personality disorder that makes him or her likely to engage in predatory sexually violent offenses.
+FTA00180999
+None of the above.
+
+
+SEX OFFENDER REGISTRATION ACT
+RISK ASSESSMENT INSTRUMENT
+RISK FACTOR
+VALUE
+T. CURRENT OFFENSE(ST
+T. lise of Vinlence
+lised forcible compulsion
+inflicted physical injury
+Armed with a dangerous instrument
++10
++15
+·30
+1. Sexual Contact with Victim
+Contact over chatting
++5
+Contact under clothing
++10
+Sexual intercurse: deviate scxual imercourse
++25
+or aggravated sexual abuse
+3. Number of Victims'
+Twin
+Three or more
+d. Duration of offense conduct with victim
+Continuing course of sexual
++20
++30 X
++20
+misconduct
+5. Ageof victim
+11 through 16
+10 or less, 63 or more
++20 X
++30
+6. Other victim characteristics
+Victim suffered from mental disability or
++20
+incapacity or from physical helplessness
+1. Relationship with victim
+Stranger or estahlished for purpose of
+victimizing or professional relationship
++20|
+TI. CRIMINAL HISTORT
+8. Age at first act of sexual misconduct
+20 or less
++10
+9. Number and nature of prior crimes
+Prior history/no sex crimes or felonies
+Prior history/non-violent felony
+Prior violent felony. or misdemeanor sex
+crime or endangering welfare of a child
++5
++15
++30
+10. Recency of prior offense
++10
+Less than 3 ycars
+11. Drug or Alcohol abuse
++15
+History of abuse
+COLUMNS I - 11 SUBTOTAL
+SCORE
+10
+25
+30
+20
+20
+20
+130
+SEX OFFENDER REGISTRATION ACT
+RISK ASSESSMENT INSTRUMENT
+RISK FACTOR
+VALUE
+TIL. POST-OFFENSE BEHAVIOR
+13. Acceptance of Responsibility
+Not accepted responsibility
+Not accepted responsibility / refused or
+expelled from treatment
++10|
++15
+i3. Conduct while confined 7 supervised
+Unsatisfactory
+Unsatisfactory with sexual misconduct
++10
++20
+TV. RELEASE ENVIRONMENT
+14. Supervision
+Release with specialized supervision
+Release with supervision
+Reicase without supervision
++5
++15
+is. Living / employment situation
++10
+Living or empicyment inappropriate
+COLUMNS 12-15 SUBTOTAL
+COLUMNS 1-11 SUBTOTAL
+TOTAL RISK FACTOR SCORE (add 2 subtotals)
+Level 1 (low)
+Level 2 (moderate )
+Level 3 (high)
+0 t0 +70
++75 to +105
++110 to +300
+statement in determining a sex offender's level of risk.
+SCORE
+130
+130
+Offender
+Name:
+NYSID #:
+OS1909
+Docket #:
+RISK LEVEL: 3
+Assessor's
+Signature
+A. Overrides (If any override is circled, offender is presumptively
+a Level 3)
+1. Offender has a prior felony conviction for a sex crime
+2. Offender inflicted serious physical injury or caused death
+3. The one a sade renter hate wil eatend
+4. There has been a clinical assessment that the offender has
+a psychological, physical, or organic abnormality that
+decreases ability to control impulsive sexual behavior
+B. Departure
+1. A departure from the risk level is warranted
+• Yes
+& No
+2. If yes. circle the appropriate risk level 1
+3. If yes. explain the basis for departure (See Summary)
+
+A75
+DATE:
+JEFFREY EEPSTEIN
+NYSID #: OS1909
+8/23/2010
+CASE SUMMARY
+This assessment is based upon a review of the inmate's file which may include but is not limited to the
+pre-sentence investigation. prior criminal history and post-offense behavior.
+Jeffrey Epslein is a 57-ycar-old sex offender who pled guilty in the state of Florida on 6/30/2008 to two felony
+sex offenses. Procuring a Person Under i8 for Prostitution and Felony Solicitation of Prostitution. He was
+sentenced tol2 months in jail followed by 12 months of Community Control.
+It would appear he was convicted in London England of Unlawful Possession of an Offensive Weapon, a Sword
+Stick, and was sentenced to a Conditional Discharge on I/4/1973.
+Regarding the instant offense, Epstein was approximately 5l years of'age on or about the year 2005 when he
+sexually assaulted numerous females between the approximate ages of 14 and 17. Most of the victims were
+recruited by one of Epstein's female employees from a local high school in the Palm Beach Florida area. Some of
+the female participants were age 18 or older. The contact included vaginal intercourse, mouth to vagina sodomy,
+the touching of the breasts and vagina, placing his fingers inside the vagina and Epstein using a vibrator on the
+victim's vaginal area. The available police reports from the Palm Beach. Police Department include conversations
+with numerous female victims who in most cases, did not know Epstein when they were victimized. Most of the
+females were embarrassed to speak with police regarding what had happened to them while they were at Epstein's
+home. Sworn statements were taken from at least five victims and seventeen witnesses concerning massages and
+unlawful sexual activity that took place at the residence of Jeffrey Epstein. Most of the victims were paid at least
+$200.00 each time they performed a massage.
+The victims were told they would be giving Epstein a massage and they were escorted to his bedroom. Most
+victims noted numerous pictures of naked young females, (some of the photos depicted females who would be
+eventually interviewed by police), on display throughout the home. The offender would enter the room only
+wearing a towel. In most cases he would remove the towel and ask the victim to remove her clothing. In some
+cases he would masturbate into a towel while receiving a massage. In other cases he would touch the breasts or
+vagina of the victim with his hands or use the vibrator. One 14 year old described how Epstein touched her
+vaginal area with a vibrator and thereafter. when contacted by law enforcement, she had to identify the offender
+through the use of'a photo array. Another 16-year-old victim described giving Epstein massages for two years
+and at times, he grabbed her buttocks and caressed her butt cheeks as she gave him a massage. Another
+16-year-old described going to the offender's home at least 100 times. He would touch her breasts, insert his
+lingers into her vagina and sometimes use the vibrator on her while masturbating. He would also pay this
+underage victim to have sex with a female friend while he watched. Occasionally, he would join both girls and
+perform oral sex on both. This 16-year-old victim described for police how one lime, Epstein turned her over on
+the massage lable and forcibly raped her. When she scrcamed. "NO," he stopped and subsequently apologized for
+his actions.
+• The offenders conduct while on Community Control will be considered satisfactory and he does not have a
+history of substance abuse. Based upon his plea of guilty. Epstein will be credited with accepting responsibility
+. - for his actions. He will he scored for sexual and deviate sexual intercourse, forcible compulsion, numerous
+victims and their ages. a continued course of sexual misconduct. a prior misdemeanor conviction in England
+absent specific information. for his stranger relationship to most victims and for establishing a relationship with
+these underage girls for the purpose of' victimization.
+The Board acknowledges correspondence received from the offender's attorney.
+
+
+A76
+DATT:
+NYSID #: OS1909
+8/23/2010
+CASE SUMMARY
+Jeffrey Epstein used his wealth and power in such a way so that he coull take advantage of many teenage girls to
+seist; his own sexual perversions. Te seres as a Level I Sex Oriender with absolutely no basis for downward
+
+
+A77
+Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing,
+dated September 9, 2010
+09/07/2010 09:55 FAX
+@002/002
+KIRKLAND & ELLIS LLP
+AND AFTILIATED PARTNIRSHIPS
+Not 1oo. No Avi 0022
+Jay P. Lefkowitz, P.C.
+To Call Writer Direelly:
+lelkowitz@kirkland.com
+Facsimile:
+www.kirkland.com
+September 7, 2010
+BY FACSIMILE-
+The Honorable Ruth Pickholz
+New York County Supreme Court
+Part 66
+111 Centre Street
+New York, NY 10013
+Re: SCID No. 30129-2010
+Dear Justice Pickholz:
+I am writing regarding the hearing for Mr. Jeffrey Epstein in the above-referenced matter,
+which is currently scheduled for 9:30 a.m. on Wednesday, September 15, 2010.
+We respectfully request a continuance of the hearing. Kirkland & Ellis was only recently
+retained by Mr. Epstein to represent him in this matter and due to the holidays this week and
+because the matter arises out of Florida, we will need some time in order to collect information
+to prepare for the hearing.
+We are available on or after October 4, 2010 for a hearing on this matter if that would be
+acceptable to the Court. We are available to discuss at the Court's convenience.
+Respectfully submitted,
+Ananasa
+Chicago
+Hong Kong
+London
+Los Angeles
+Munich
+Palo Allo
+San Francisco
+Shanghai
+Washington, D.C.
+
+
+A78
+Letter from Supreme Court to Sex Offender Registry Unit Enclosing Final Determinations,
+dated January 19, 2011
+[pp. A78-479]
+Supreme Omart
+af the
+State of Nin Hork
+100 CENTRE STREET
+HEW YORK. NY 10013
+January 19, 2011
+Sex Offender Registry Unit
+NYS Division of Criminal Justice Services
+4 Tower Place
+Albany, NY 12203
+Dear Sir/Madam:
+Enclosed please find the Final Determinations on the following cases:
+Name
+Jeffrey Epstein
+Ind.#
+Risk Level
+30129-2010
+Three (3)
+Respectfully yours,
+Encl.
+Correspondence Unit
+Supreme Court, Criminal Term
+cc: Mr. Jeffrey Epstein
+9 East 71st Street
+New York, NY 10021
+
+
+A79
+FROM:
+FRE
+STATE OF NEW YORK
+BOARD OF EXAMINERS OF SEX OFFENDERS
+34 TOWER PLACEV
+ALBANY NEW YORK 12203-3764
+NEW YORK COUNT SUPREME COURT
+BOARD EXAMINER- STEPHEN D- WEBËR
+REPORTED ADDRESS
+SOW
+9 EAST 71ST STREET
+NEW YORK: NY 10021
+DATE 8492010
+NYSID OR BOARD ID#S OS1909
+SUPERVISING OFFICER:
+SUPERVISING AGENCY,
+NONE, OFFENDER IS UNSUPERVISED
+The above referenced individual has committed an offense in another Jurisdiction and has established residence i Naw
+York State at the address indicated. It has been d
+as a sex offender in New York Slate.
+Ined, thát, the offender is required to register and be Ask absessed
+The NYS Board of Examiners of Sex Offenders is recommending a risk level, and desighation for the offender a nAdicated
+onithe attached risk assessment instrumenl, case summary and designation form. Pursuant to CorrectioniLaw Sectora
+158-k(2), the County or Supreme Court in the county of residence of the offender shall determine the offender sisk level
+and desighation: The Court must determine whether, the offender meets the definition, bf sexually Violeht Offender
+predicate sex offender or sexual predator as set forth in Correctior Law Section 168-a(7).,
+Please note pursuan! to Chapter 684 of the Laws of 2005; as
+and 168-n; have been amended, to provide that the Court shall conquer
+4 2005, Correction Law section 1684 68k
+une, risk level and designation hearing litha tex
+brender, having been given nolice Including the date, time, and place of the proceeding tails to appear, without suricient
+exduse Please hote that until the court determines the offender's risk lovel, no community notification cal occult
+A copy of the order, settling forth the hak level and designaijon determinatons, and the rindings and condusions fawi bre
+Which such determinations are based shall be submitted to the Division of Cilminal Justice Services sex Orender
+Registry Unit by, the Cout In addition, please complete, and attach this form Indicating the offenders hek lavel end
+designation to the Couts order Please distrite the remaining copies as indicated been
+Information below is to be completed by Sentencing Court
+FINAL RISK LEVEL DETERMINATION (circle one)
+DESIGNATION: Please check any that apply, pursuant to Article 6-Cröf the NYS Correction Lawe
+Sexually, Viblent Offender.
+Sexual Predators
+•Predicate Sex Offerider:
+HAD No such desighatolk
+Judges Name (pléase print):
+duages signature:
+Date signed:
+12 201
+WHITE COPY: Sex Offender Registry: Unit
+DCJS, 4 Tower: Pli, Albany; NY.12203
+YELLOW COPY: Court
+¿PINK COPY 1 Offender
+
+
+A80
+Court Action Sheet - Jeffrey Epstein, No. 30129-2010
+COUNTY OF
+PEOPLE VS
+Jeffrey Epstein
+N.Y.S.L.D. NO.
+ADDRESS
+DATE OF BIRTH
+IBIC/RTENANO, 30/29-2010
+_ SEX 4
+NOTICE OF APPEARANCE
+FILED BY-
+ADDRESS
+TELEPHONE NO.
+RET O
+SUBSTITUTION
+FILED BY
+ADDRESS
+L.A. O
+TELEPHONE
+RET O
+L.A. O
+KIRKLAND & ELLIS LLP
+AND AFFILIATED PARINERSHIPS
+JAY P. LEFKOWITZ, P.C.
+Mew York 10022
+701946-470 Fax
+446-4970 • Fax
+(aylefhowitz@hkirkland.com
+.-. VEICK
+INTERPRETER
+COURT CLERK -
+ARTICLE 730 EXAMINATION
+ORDERED.
+JUSTICE
+COURT CLERK
+COURT REPORTER
+ORDERED
+JUSTICE
+COURT CLERK -
+COURT REPORTER
+20
+18B 0
+20-
+18B O
+_ 20
+RECOGNIZANCE
+ROR-
+BAIL FIXED
+AMOUNT
+COURT CLERK
+_ 20-
+JUSTICE
+COUNSEL PRESENT -.
+ON CONSENT OF ADA
+COURT REPORTER _
+BAILED
+SURETY
+_ 20.
+COURT CLERK.
+ROR REVOKED-BW
+JUSTICE -
+BAIL FORF-BW
+JUSTICE -
+BAIL EXONERATED
+JUSTICE
+SURR. BY SURETY.
+20
+20
+- 20.
+SUBSEQUENT ACTION RE RECOGNIZANCE
+20-
+JUSTICE
+COURT REPORTER
+COURT CLERK
+PART
+-20.
+COMMITTED TO COMMISSIONER OF MENTAL HYGIENE:
+JUSTICE
+ADA PRESENT
+COUNSEL PRESENT
+
+
+
+VCrI
+JeFFReY EPSTeiN
+(SOM)
+PT66
+9-15-10 Aily 10/5.
+-10/5 18 11-9
+R.Corcoral
+A. BODIER
+1/19
+29.3010. Ruth Pill it, 18-201 DeG Menda
+-18-2011
+Lath Richolz
+30129-2011
+5C1D
+ALA-JenNifer Gapive/
+sef thing- Jay Kifkowitz
+J.beideecter
+T. in Sprinc
+Attori
+Handwritten Notations on Court Jacket - Jeffrey Epstein, No. 30129-2010
+A81
+
+A82
+Transcript of SORA Hearing, dated January 18, 2011
+IPp. A82-496]
+SORA HEARING
+1 SUPREME COURT
+NEW YORK COUNTY
+TRIAL TERM
+PART 66
+THE PEOPLE OF THE STATE OF NEW YORK:
+INDICTMENT#
+30129/2010
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+18
+19
+20
+21
+AGAINST
+JEFFREY EPSTEIN
+Defendant.
+-X SORA HEARING
+111 Centre Street
+New York, New York 10013
+January 18, 2011
+BEFORE:
+HONORABLE RUTH PICKHOLZ
+Justice of the Supreme Court
+APPEARANCES:
+For the People:
+AsSiStant District Attorney
+For the Defense:
+KIRKLAND & ELLI, LLP
+153 East 53rd Street
+lew York, New York 10022
+BY: JAY LEFKOWITZ
+ESQ.
+SANDRA MUSUMÉCI, ESQ.
+23
+24
+25
+page 1
+Vikki J. Benkel.
+Senior Court Reparter
+
+
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A83
+SORA HEARING
+page 2
+COURT CLERK: This is number two on the calendar,
+matter of Jeffrey Epstein.
+Your appearances please.
+for the People.
+Good afternoon, Your Honor.
+MR. LEFKOWITZ: Jay Lefkowitz and Sandra Musumeci
+for Mr. Epstein.
+THE COURT: Mr. Epstein is not here.
+MR. LEFKOWITZ: That's correct.
+THE COURT: Are you waiving his appearance?
+MR. LEKWOWITZ: Yes.
+Your Honor, this case is on for a
+SORA hearing this afternoon.
+The People did receive the board's recommendation
+of a Level Three. However, we received the underlying
+information from them and also had some contact with
+Florida, and we don't believe that we can rely on the entire
+probable cause affidavit.
+I don't know if the board sent that to you as
+well.
+THE COURT: I don't know why you cannot rely on
+it.
+Because in Florida of all of the
+victims in that probable cause affidavit, they actually only
+went forward on one case. There was only an indictment for
+Senior Cour! Reporter
+
+
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A84
+SORA HEARING
+page 3
+one victim and that is what the defendant plead to.
+So it is unlike a situation where everything was
+indicted and then we get to sort of assess points for all of !
+the victims, if it was part of a plea bargain. They did not
+actually choose to go forward on any except for the one
+victim.
+So under the board guidelines, the risk assessment
+interim guidelines, it actually says, you know, by way of
+contrast if an offender is not indicted for an offense, it
+is strong evidence that the offense did not occur and I
+don't think --
+THE COURT: Do you find that if somebody is not
+indicted it is strong evidence that it did not occur?
+I don't know that we can rely on it
+as clear and convincing evidence if the prosecutor's office
+never went forward on it. The prosecution said that the
+victims, although they spoke to the police early on, did not
+cooperate with them. So we don't have any follow up
+information.
+THE COURT: But the board found a Level Three.
+I have to tell you, I am a little overwhelmed
+because I have never seen the prosecutor's office do
+anything like this. I have never seen it. I had a case
+with one instance it was a marine who went to a bar, and I
+wish I had the case before me, but he went to a bar and a 17
+
+
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A85
+SORA HEARING
+page 4
+year old, he was an adult obviously, he was a Marine, a 17
+year old came up to him and one thing lead to another and he
+had sex with her and the People would not agree to a
+downward modification on that.
+So I am a little overwhelmed here because I see --
+I mean I read everything here, I am just a little
+overwhelmed that the People are making this application.
+I could cite many many, I have done many SORAs
+much less troubling than this one where the People would
+never make a downward argument like this.
+• I agree with Your Honor, it is
+incredibly unusual for us to make a downward argument. But
+the problem is the one thing that we have from the board is
+it seems to be in contradiction to their own guidelines
+which if something was not indicted, you are not supposed to
+rely on it.
+THE COURT: They obviously took that into
+consideration.
+And I tried to reach -- I reached
+the authorities in Florida to try to see if they had all the
+interview notes or other things that we can then
+subsequently rely on that might be considered clear and
+convincing evidence, if they had interviewed these women on
+their own, and they never did. No one was cooperative and
+they did not go forward on any of the cases and none of them
+
+
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A86
+SORA HEARING
+page 5
+were indicted. So I don't know.
+THE COURT: And you spoke to the prosecutor?
+: The actual prosecutor left the
+office. I spoke to the prosecutor that took over the case.
+THE COURT: Maybe you can find the prosecutor that
+left the office.
+You have done more in other cases looking into it.
+I have never seen the prosecutor's office do this. I have
+to tell you, I am shocked.
+- Right, but I spoke to the prosecutor
+that took over the case and they don't have anything, any
+affidavits, any statements, any notes.
+THE COURT: Why don't you speak to the prosecutor
+that did do the case, I am sure you could find that
+prosecutor.
+: I can find her, but based upon what
+the other prosecutor said, they did not speak to that
+prosecutor either.
+THE COURT: You did not speak to the prosecutor
+yourself, you did not speak to them, that is hearsay. You
+did not speak to the prosecutor that handled the case.
+That's right.
+THE COURT: I don't think you did much of an
+investigation here.
+: I mean I called the prosecutor.
+• st
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+• 13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A87
+SORA HEARING
+page 6%
+Even though the first prosecutor left, presumably the
+prosecutor's office has the file.
+THE COURT: I would still call the prosecutor.
+• Anything from these women they would.
+have forwarded it to us.
+THE COURT: I don't know that, I think you have to
+speak to the prosecutor.
+But be that as it may, I hear your argument.
+Anything else?
+• I mean that is why I don't think we
+can, I don't think we are entitled to rely on this because
+they did not go forward.
+THE COURT: The board made a recommendation.
+Correct.
+May I speak, Your Honor?
+THE COURT: Yes.
+Good afternoon.
+I would like to bring a few additional points to
+Your Honor's attention that don't come across in the board
+recommendation.
+The first is that Mr. Epstein is not a resident of
+New York, unlike most of these out of state, he has not
+changed his address and moved to New York, he maintains a
+vacation home in New York. His primary residence is the
+U.S. Virgin Islands.
+
+
+2
+3
+4
+5
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A88
+SORA HEARING
+page 7
+He is registered in the U.S. Virgin Islands, he
+has been since his release from jail. He notifies the
+Virgin Island authorities every time he leaves that
+jurisdiction. Virgin Island authorities rated him at the
+lowest level of registration.
+He also registered in Florida, which is the state
+of this particular offense, and the only reason that this
+conviction is even before Your Honor.
+The offense for which he was convicted is not a
+registrable offense in New York. He is only registrable
+here arguably because based on the provision of SORA that
+says if a crime is registrable in the state of conviction,
+then it is registrable here in New York. And the Florida
+authorities that considered that rated him at the lowest
+level of their SORA statute.
+He additionally has a vacation home in New Mexico
+and is registered in New Mexico. The New Mexican
+authorities when they considered his offenses, determined he
+need not register at all. Nevertheless, he has voluntarily
+registered with New Mexico and maintains that registration.
+Additionally, because of his possession of a
+vacation home in New York, he has been voluntarily
+registered with New York SOMU, the Sex Offender Monitoring
+Unit since May of this year. He notifies them whenever he
+comes to travel to New York. He never comes to New York for
+
+
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+20
+21
+22
+23
+24
+25
+A89
+SORA HEARING
+page 8
+more than seven days or at least he has not since he has
+been registered. He has no intention to ever be here for
+longer than a period of ten days.
+Like I said, he does notify the authorities when
+he is here. He fully understands the reason for voluntary
+registration, he wants to be compliant with the Federal SORA
+Taw which requires wherever you own a property to register.
+To require Mr. Epstein to register as a Level
+Three offender in New York would actually require him to
+come to New York more than he does normally, it would
+require him to come every 90 days and renew his
+registration.
+He is very diligent in registering with New York
+authorities.
+All of the other jurisdictions that have
+considered his case have determined that he either not
+register at all or register at the lowest level, and he has
+been more than compliant with all of those requirements.
+Your Honor, we would join in the prosecutor's
+application.
+THE COURT: I am sure you would.
+MS. MUSUMECI: By way of background, we have been
+in contact with the prosecutor's office on this matter since
+I believe certainly since Mr. Epstein got his notification,
+which I believe was in August. We have met with the
+
+
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A90
+SORA HEARING.
+page 9
+prosecutor and provided numerous materials for the
+prosecutor to consider. We have included in that a
+deposition from the detective who headed this investigation
+who acknowledged in a sworn deposition that the lead
+prosecutor who originally had the case, whose name I cannot
+pronounce,
+,, I apologize for the
+mispronunciation, said to the detective after her
+investigation, there are no real victims here.
+All of the alleged conduct that is cited in the
+board's write up was commercial conduct. All of the alleged
+conduct the women went voluntarily, there are no allegations
+of force certainly none.
+THE COURT: There was no allegation of force in
+the marine either, who met a girl in a bar, a young girl 17,
+there was no force there.
+MS. MUSUMECI: It is our understanding that the
+prosecutor in Florida conducted a full investigation, as
+full as she was able with the cooperation afforded by these
+complainants, and determined that the only case that she
+could present to the grand jury was this indictment for a
+non registrable offense then --
+THE COURT: But it is registrable here.
+I don't know what you mean non registrable
+offense.
+MS. MUSUMECI: Let me explain, Your Honor.
+
+
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A91
+SORA HEARING
+page, 10
+Mr. Epstein plead to two charges, one was an
+indictment which is an offense that is not registrable, it
+is a Florida indictment for --
+THE COURT: Then why does he have to register
+here?
+MS. MUSUMECI: It was a second offense that he :
+plead to --
+THE COURT: That is registrable.
+MS. MUSUMECI: That is registrable.
+That offense was by information and that is the
+only registrable offense, that is what the DA's office is
+considering in doing their scoring.
+The indictment which was the only case that the
+prosecutor even prosecuted through grand jury is not even a
+registrable offense.
+THE COURT: He plead guilty to a registrable
+offense.
+1: Yes.
+THE COURT: What did he plead guilty to?
+He plead guilty to the procuring a
+person under 18 for prostitution.
+THE COURT: Procuring a person under 18 for
+prostitution.
+Right.
+THE COURT: How old was she?
+
+
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+• 17
+18
+19
+20
+21
+22
+23
+24
+25
+A92
+SORA HEARING
+page 11
+It appears the first time they met
+she was either 16 or 17, then for the remainder of their
+relationship she was probably 17.
+THE COURT: How long was their relationship?
+She met, she gave him approximately
+15 massages, including with sexual contact, and ultimately
+when she is 17 had intercourse with him.
+THE COURT: She is a child.
+MS. MUSUMECI: Your Honor, I would note that under
+SORA it is clear that prostitution offenses are only
+registrable when in fact by clear and convincing evidence
+the women or victim is 17, is under 17.
+THE COURT: Well, she met him at 16, he procured
+her at 16 from what I read.
+MS. MUSUMECI: There is evidence we challenged.
+THE COURT: He plead guilty to that, didn't he?
+MS. MUSUMECI: He plead guilty to under 18, which
+is the law in Florida, which is a different standard than
+what the law is in New York. And there is no evidence,
+there is no clear and convincing evidence as to her specific
+age at the time of the specific conduct.
+THE COURT: Well, the DA just told me she was most
+Tikely 17, she just said it on the record.
+MS. MUSUMECI: Your Honor, we agree that the
+evidence is that she was 17 on the one occasion she had
+
+
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A93
+SORA HEARING
+page 12
+consensual intercourse with him and 17 is not registrable or
+criminal under New York law.
+And the prostitution aspect of having intercourse
+with a 17 year old is not registrable conduct.
+THE COURT: Why does he have to register here?
+Because it is a register able
+offense in Florida, New York State board of examiners --
+THE COURT: Recognizes it.
+Recognizes it, yes.
+THE COURT: I have had many cases like that where
+it was not registrable here but it was in the state where
+the person came from and New York recognized that.
+MS. MUSUMECI: Your Honor, we are not saying that
+he should not register. Mr. Epstein has already registered
+and recognizes his duty to register.
+THE COURT: I am glad of that, very glad of that.
+I am sorry he may have to come here every 90 days.
+He can give up his New York home if he does not
+want to come every 90 days.
+Anything else?
+I rely on the board.
+MS. MUSUMECI: Your Honor, we would reserve our
+right to appeal Your Honor's ruling.
+THE COURT: Of course, do so:
+For the record, Your Honor, he is
+
+
+RECORD PRESS, INC., 229 West 36th Street, N.Y. 10018-28829-
+www.recordpress.com
+
+
+
diff --git a/vision-fixhub/ds9-unparsed-05/c6466e428a90ba9db437c65e0f4181719e019a4f8d911df43afbd7662551d718.receipt.json b/vision-fixhub/ds9-unparsed-05/c6466e428a90ba9db437c65e0f4181719e019a4f8d911df43afbd7662551d718.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..be755b14b0c3c33a1628292dfc01ae1341fd61d2
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c6466e428a90ba9db437c65e0f4181719e019a4f8d911df43afbd7662551d718.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -4074,
+  "dataset": "marble-joined",
+  "doc_id": "c6466e428a90ba9db437c65e0f4181719e019a4f8d911df43afbd7662551d718",
+  "engine": "marble-apple-vision",
+  "event_count": 119,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "f0e23ff147a816f18d3a1bbb31146e685b5ad7501a03aca00365a9ea6e9fb3c2",
+  "output_sha256": "0628600950435faf4bfadf8093c3abab18a8aee7d3c0f13957131a48dffd7a39",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c80be77fe6bc9f7499de533c217f26d92bae248bc4d49c87e22935758d29765b.md b/vision-fixhub/ds9-unparsed-05/c80be77fe6bc9f7499de533c217f26d92bae248bc4d49c87e22935758d29765b.md
new file mode 100644
index 0000000000000000000000000000000000000000..e70bd6787f8dfd126e81ea5e23fe930abdc06ab6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c80be77fe6bc9f7499de533c217f26d92bae248bc4d49c87e22935758d29765b.md
@@ -0,0 +1,15016 @@
+Statements
+
+
+Bear, Stearns & Co. Inc.
+What's In This Statement
+Financial Summary •••••••••••••••I/I//
+Transaction Detail
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+INTERNATIONAL CHARITABLE
+INTERESTS | 2/28/94
+C/O FINANCIAL TRUST COMAPNY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+20,586
+-20,586
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent - 80.
+$20,586
+Last statement's market value
+This summary is for informational purposes only. It is not intended as a tax document
+SPC This statements four beratined purposes cedrit ne reene date at dote intomation
+
+
+2 of 5
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or 5
+Cash Flow Analysis
+Opening Balance
+Miscellaneous
+Amount Credited
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+520,585.50
+9,417,281.63
+$9,417,281.63
+-1,323.92
+-9,436,543.21
+50437.867.13
+-20,585.50
+$0.00
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+20,585.50
+$20,585.50
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+Short Dividends
+THIS PERIOD
+0.00
+0.00
+$0.00
+-1,323.92
+027
+CLOSING
+0.00
+$0.00
+....
+YEAR TO DATE
+29,216.23
+10,531.16
+... .
+$39,747.39
+-19,004.69
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+
+
+4 of 5
+Transaction Detail
+DATE
+04/30/02
+MISCELLANEOUS
+DATE
+MODAY
+04/29/02
+04/29/02
+04/29/02
+ö4/29/02
+TOURNAL"
+JOUANAL'
+05/01/02
+ö5/01/02
+05/63/02
+JOUANAL
+85/06/02**
+"JUANAL"
+05/06/02
+05/06/02 JOURNAL"
+Bear, Steams & Co. Inc.
+SYMBOUCUSIP
+SPY
+QUANTITY
+RATE (5)
+TO CLOSE LINE
+CASH
+TO CLOSE LINE
+"TO CLOSE LINE"
+"ASH*
+TO CLOSE LINE
+* JAL *
+Ti-USD
+TO COMPLETE TRANSFER
+JEL
+FROM: SN
+12-050
+* JRL *
+04/02 CLA CA8]
+* JRL
+"TO CLOSE LINE'
+"CASH"
+TO CLOSE LINE
+DEBIT AMOUNT
+4,229,546.33
+455,953.49
+•*••''1,323.92
+19,261.58
+70:00
+4,729,063.97
+027
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+DEBIT AMOUNT
+1,323.92
+$-1,323.92
+CRECIT AMOUNT
+4,229,546.33
+455,953.49
+1,323.92
+70:00
+*4,729,063.97
+
+
+5 of 5
+Bear, Steams & Co. Inc.
+New York. New York 10179
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+LANSACTI
+05/13/02
+JUANA
+05/13/02
+2 JOURNAL
+ADJ PNL VS|
+* JAL
+STANDARD & POORS DEPOSITORY
+DEBIT AMOUNT
+1,323.92
+CRECIT AMOUNT
+1,323.92
+$-9,436,543.21
+$9.417,281.63
+STOP
+****** End of Statement******
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+
+
+OFFICE SERVICING YOUR ACOUNT
+Bear, Steams & Co. Inc.
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28,2002
+What's In This Statement
+Financial Summary...........................
+Your Portfolio Holdings
+Transaction Detail...................
+Fund Activ..............
+3
+4
+4
+10
+INTERNATIONAL CHARITABLE
+INTERESTS | 2/28/94
+C/O FINANCIAL TRUST COMAPNY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+20,586
+$20,586
+23,771,340
+-23,750,755
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent -
+1.
+- 820,586,
+Equities — $0
+$23,895,931
+$2,132,291 : $-2,256,882
+Current market value
+Last statement's market value
+Short market value
+SP The suren s four or ratanal furyce rear die Set revere date for portant iformation.
+04/27/02;13:44 001
+
+
+2 of 14
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+04/27/02;13:44001
+
+
+3 of 14
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Money Fund
+Funds Withdrawn
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+appear in Transaction Detail.
+THIS PERICO
+522,526,001.44
+63,069.72
+20,582,347.26
+8,774.38
+34,733,663.49
+$55,387,854.85
+-2,244,751.50
+-19,200,000.00
+-872,453.00
+-5,788.63
+-55,570,277.66
+$.77,893.270.79
+-22,505.415.94
+520.585.-50
+Cash Balance Summary
+Margin
+Short
+Net Cash Balance
+OPENING
+20,285,741.77
+2,240,259.67
+$22,526,001.44
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+Short Dividends
+THIS PERIOD
+14,780.26
+6,411.38
+521.191.64
+-5,788.63
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+027
+CLOSING
+20,585.50
+0.00
+$20,585.50
+YEAR TO DATE
+29,216.23
+10,531.16
+....
+$39.747.39
+-17,680.77
+20,586
+$20,586
+04/27/02;13:44 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+from the absolute market value of your portfolio.
+
+
+4 or 14
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+New York. New York 10179
+SIMBOUCUSIP
+QUANTITY
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TREE
+04/01/02
+DATE
+04/01/02 03/26/02 OUGHT
+04/02/02 03/27/02*BOUGHT
+ELECTRONIC DATA SYSTEMS CORP
+COMMS 0313-02
+54.00
+"VANKEE CANDLE INC
+COVER BY BUCK
+AS 0112-02
+51.00
+AMERICAN GREETINGS CORP-CLA
+OVER SHORT
+8 800 02 19.02
+AS OF 0312102
+56,00
+MARKE
+ALU
+20,586
+$20,586
+NAME MOTO CRENS
+$20,585
+SIMBOLCUSP
+EDS
+AM
+QUANTITY
+900
+850
+800
+58.90000
+
+16.93000
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28, 2002
+DEBIT AMOUNT
+53,079.00
+19,533.72
+13,615.00
+
+
+5 or 14
+DATE
+04/03/02
+03/28/02
+Bear, Steams & Co. Inc.
+04/03/02 03/28/02 BOUGHT
+04/03/02
+03/28/02
+BOUGH
+0403/02
+03/28/02
+04/05/02
+04/02/02 BOUGHT
+04/05/02 84/02/02
+CONSTELLATION BRANDS INC
+CLA
+SEVEASE ON BACK
+56,00
+GENUINE PARTS CO
+NITH RIGHTS TO PURCHASE PREFRI
+STK UNDER CERTAIN CIRCUMSTANCE
+42,00
+'SHOPKÖ STORES INC
+COVER SHORT,
+1S-300 09-04-01. 1300 01-22-
+2, -500 12-26-0
+OMMISSION
+147,00
+TUESDAY MORNING CORP-NEW
+COVER SHORT,
+S -100 03-04-02
+NOKIA CORP SPONSORED ADR
+COVER SHOT A SPAR
+COMMISSION 13-02
+72,00
+"SHOPKO STORES INC
+COMMISSION
+132,00
+SYMBOLCUSIP
+SIZ
+'GPC
+TUES
+NOK
+SKO
+027
+QUANTITY
+800
+54.29600
+600°
+36.90000
+2,100
+18.03770
+1,200
+
+20.06000
+*2,200
+'18.99680
+04/27/02;13:44 001
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28,2002
+DEBIT AMOUNT
+43,507.80
+22,197.00
+38,041.17
+28,715.00
+24,159.00
+41,039.96
+
+
+6 of 14
+04/08/02
+DAT03102
+Bear, Steams & Co. Inc.
+04/10/02 04/05/02"BOUGHT
+04/10/02
+04/05/02
+04/10/02
+04/05/02
+04/10/02 04/05/02** OUGHT
+04/10/02
+04005/02
+04710702 04/05/02"BOUGHT
+ESCRIPTIO
+ONSTELLATION BRANDS IN
+CLA
+SEVEASE ON BACK
+5300230802. 70003010
+ACTION PERFORAMNANGE COMPANES
+UNSOLICITED
+COVER SHORT,
+AMERICAN GREETINGS CORP-CLA
+COVER SHORT.
+DIAMONDS TRUST-UNIT SERIES 1
+COVER SHORT,
+VS -8850 12-31-01, -800 02-25
+COMISION
+579,00
+"GENUINE PARTS CO"*
+WITH RIGHTS TO PURCHASE PREFRD
+TK UNDER CERTAIN CIRCUMSTANO
+NSOLICITE
+COVER SHORT
+"KELLWOOD "C0'***
+WITH RIGHTS TO PURCHASE PREFRO
+STK UNDER CERTAIN CIRCUMSTANCE
+DOVER SHOR
+XECUTION BYBUC
+VS-800 11-12-01, -1000 12-12-
+01, -800 09-06-01, -900 12-17-
+SYMBOLCUSIP
+SIZ
+AM
+HUM
+"KWD
+027
+QUANTITY
+54.00870
+600°
+1,300
+9,650
+48.86000
+17.20000
+103.01000
+'2,100"
+1,000
+•*37.07000
+14.06000
+4,100
+23.80000
+04/27/02;13:44 001
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28,2002
+DEBIT AMOUNT
+86,524.92
+29,358.00
+22,451.00
+994,640.50
+77,594.00
+14,130.00
+97,841.00
+
+
+7 of 14
+SETTLEMENT TRADE
+DATE
+64/10/02
+04/05/02
+64/18/02 04/05/02***BOUGAT
+04/10/02
+' 04/05/02
+'''BÖÜGHT
+04/10102
+r'*84/05/02
+04/10/02
+04/05/02
+04/10/02
+0405/2
+04/10/02
+204/05/02
+*BÖUGHT
+04711702"
+LEGGETT & PLATT INC
+AVG PRICE SHOWN-DETAILS ON REQ
+CTUAL CONFIRM TO YOUR AGEN
+INSOLICITEC
+COVER SHORT,
+"MOVAB8 SHOUP INC..
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGEN
+UNSOLICITED
+COVER SHORT,
+"SAFEWAY INC
+UNSOLICITED
+COVER SHORT.
+*SMUCKER JMCO
+AVG PRICE SHOWN-DETAILS ON RE
+ACTUAL CONFIRM TO YOUR AGENT
+NSOLICITE
+OVER SHO
+STANDARD & POORS DEPOSITORY
+RECEIPTS (SPDRS) (BOOK ENTRY)
+INITS UNDIVIDED BENEFICIAL IN
+OVER SHORT
+VS - 1100 02-04-02, -700 02-13-
+02, -1900 02-01-02
+WEST MARINE INC
+OVER SHORI
+XECUTION BY NIT
+VS-2400 01-24-02
+VANKEE CANDLE INC
+UNSOLICITED
+COVER SHORT,
+"HOT TOPIC INC'***
+EXECUTION BY RSSF
+VS 1600 03-05-02
+SEC FEE
+1.08
+SYMBOLGUSIP
+LEG
+"MOV
+SUM
+SPY
+WMAR
+00A.
+"HOT
+027
+QUANTITY
+1,000
+1,200
+900
+1,700
+3,700
+24.66700
+*21.94500***
+43.56000
+33.94290
+712.82000
+2,400
+*850
+2170000"
+22.30000
+''''22223390"
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28, 2002
+DEBIT AMOUNT
+24,737.00
+26,418.00
+*39,267.00
+57,821.93
+417,671.00
+52,095.00
+19,014.50
+35,558.16
+
+
+8 of 1a
+SATEMENT TREE
+04/11/02
+04T0B10Z
+04/16/02
+04/16/02
+JOURNAL****"
+04/18/02
+"JOURNAL"
+04/16/02
+04/16/02
+JOUANAL'
+04/18/02
+04/16/02
+04/16/02
+"JÖURNAL
+04716/02
+JOURNALI
+POLO RALPH LAUREN CORP-CLA
+SEE NOTE 'S' ON BACK
+VS 1000 05-23-01
+COMMISSION
+SEC FEE
+.60.00
+COCO WHO SAL USE NEW
+CANDIES INC........
+TO:
+- 2-USD
+JAL
+"CACHE ING NEW
+TO:
+12-USD
+CIRCUIT CITY STORES INC
+CIRCUIT CITY GROUP
+•jAL
+FINLAY ENTERPRISES INC"
+TO:
+-2-USD
+¡APPAREL" CRO
+SUP LTD
+TO:
+-2-USD
+JAD
+• 2-USD
+• JAL
+HEAAX LTD
+COM NEW
+TO:
+72-USD
+72-USD
+SYMBOLCUSP
+QUANTITY
+-1,000
+27.58740
+1,100
+'CAND"*****
+*.---70,989L
+"CACH
+20,100
+4,200
+"FNLY
+*28,900
+48,450
+2,500
+EAR
+23,700
+IMNY
+3,700
+027
+LEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28, 2002
+DEBIT AMOUNT
+27,511.56
+
+
+9 or 14
+04/16/02
+04/16/02
+04/16/02
+JOURNAL"
+04/16/02
+04/16/02
+
+84/16/02
+"JOURNAL
+04/16/02
+HEAD NI
+NY REGISTRY
+TO:
+- 2-USD
+JAI
+MAXWELL SHOECO INC-CLA
+-2-USD
+* JRL
+"NOVEL DENIM HOLDINGS LTD"
+1-2-USD
+JAL
+POLO RALPH LAUREN CORP-CLA
+-2-USD
+JAL
+OFFICE DEPOT INC
+TO:
+-2-USD
+JAL
+SYMBOL TECHNOLOGIES INC
+1-2-USD
+JAL
+-2-USD
+SYMBOLGUSIP
+HED
+MAXS
+VLD
+*ODP
+SBL
+*TEL
+URGI
+QUANTITY
+-12,500
+2,700
+32,650
+-7,400
+800
+3,900
+2,100
+35,500
+One Metratech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28,2002
+DEBIT AMOUNT
+$-2,244,751.50
+$63,069.72
+
+
+10 of 14
+DEPOSITS AND WITHDRAWALS
+DATE
+04/08/02
+CHECK
+PRES 1A131901:415102
+BUCKINGHAM CAPITAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+03/29/02
+04/01/02
+04/03/02
+04/09/02
+04/10/02
+04/12/02
+04/16/02
+OPENINGBALANCE
+BOUG
+04/17/02
+04/17/02
+1/17%
+04/17/02
+DOES SHREE MANLIO
+DOMESTIC PRIME MAM PORTFOLIO
+FUND
+ADJUST TYPE/CHECK FROM SELL
+Bear, Steams & Co. Inc.
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28,2002
+DEBIT AMOUNT
+872,453.00
+$-872,453.00
+SYMBOUCUSIP
+GTXX
+GOXX
+QUANTITY
+1,369,930
+15,000,000
+4,000,000
+150,000
+-600,000
+200,000
+- 100,000
+0.20
+4.196,720.72
+-15:523.209:08
+4.196,720.92
+027
+1.0000
+1.0000"
+10000
+1.0000
+1.0000*
+1.0000*
+1.0000*
+1.0000*
+1:000*
+DEBIT AMOUNT
+5,000,000.0
+*4.000.000.00
+200,000.00
+150,000.00
+600,000.00
+100,000000
+0.20
+4,196,720.72
+**5.523,209.08
+
+
+11 of 14
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+04/17/02
+FUND
+ADJUST TYPE/CHECK FROM SELL
+04/18/02 DIVIDEND*
+84/18/02'BMBEND**'
+84/48/02P0NB
+HETALASURERS FUNDING
+OMESTIC PRIME M/M PORTFOLI
+ADJUST POSITION
+••••••••
+04/26/02
+CLOSINGBALANCE
+
+BROWN SHOE COMPANY
+REC 03/18/02 PAY 04/01/02
+0401/02 GENUINE PARTS...
+DIV CHG
+2700 SHS SHORT
+REC 03/08/02 PAY 04/01/02
+04101702 KELLW
+REC 031802 PAY 0312002
+04767/02 EARS 82800K8
+DIV CHG
+RIC 030102 PAY 04011027
+04/05/02
+IMBOL TECHNOLOGIES IN
+© 03/11/02 PAY 04/05/
+SYMBOUCUSIP
+BWS
+SYMBOUCUSIP
+GIDXX
+"GTOXX
+QUANTITY
+18,700
+10,100
+QUANTITY
+4,196,720.92
+0.00
+RATE (S
+0.1000
+0.0100
+027
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28,2002
+DEBIT AMOUNT
+9,616.33
+''2800.33
+•••••••••••••
+$-19,200,000.00
+$20,582,347.26
+DEBIT AMOUNT
+**** 783.00*****
+65600*
+233450**
+CREDIT AMCUNT
+1,870.00
+101.00
+
+
+12 of 14
+DIVIDENDS (continued)
+DATE
+04/15/02
+CIRCUIT CITY STORES ING
+CIRCUIT CITY GROUP
+REC 03/29/02 PAY 04/15/02
+04/15/02"#AMILY "BOLLAR STORES INC"
+REC 03/15/02 PAY 04/15/02
+**'''DIAMONDS TRUST UNIT SERIES 1
+RE 031 02 5 04 1027
+04/15/02
+"LEGGETT & PLATT INC
+DIV CHG
+1000 SHS SHORT
+REC 03/15/02 PAY 04/15/02
+04/16/02
+NOKIA CORP SPONSORED ADR
+REPSTO 1 SER A FM 5 PAR
+DIV CHG
+1200 SHS SHORT
+REC 03/26/02 PAY 04/16/02
+INTEREST
+DATE
+04/22/02
+INT CR
+APR 02
+MISCELLANEOUS
+04/01/02
+0407/02 QUANAL
+OFFICE SERVICING YOUR ACOUNT
+SYMBOUGUSIP
+CC
+·60
+"DIA"
+LEG
+NOK
+SYMBOUCUSIP
+MARK TO MARKET
+'MARK TO MARKET SHORTPOS***
+QUANTITY
+4,200
+4,900
+RATE (S)
+0.0175
+0.0650
+QUANTITY
+RATE (%)
+DEBIT AMOUNT
+16,622.00
+027
+DEBIT AMOUNT
+1.611.31
+120.00
+283.82
+$-5,788.63
+DEBIT AMOUNT
+CRECIT ANNOUNT
+'16,622.00
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28,2002
+73.50
+
+....
+$2,363.00
+6.411.38
+$6,411.38
+
+
+13 of 14
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+04/02/02
+04/02/02
+04/08/02
+04/08/02
+04/15/02
+04/15/02
+04/18/02
+04/16/02
+ANSACT
+URNI
+"JOURNAL
+ÖUANAL"
+JOUANAL"
+JOURNAL'
+"JOUANAL
+"JOURNAL
+04/16/02
+04/17/02
+ö4/17/02
+04/17/02
+04/17/02
+"JOUANAL
+"JOURNAL
+JOUANAL'
+"JOUANAL
+"JOURNAL'
+04/17/02
+"JOUANAL
+04/17/02 JOURNAL
+04/1702
+JOUANAL
+04/22/02
+JOUANAL
+OFFICE SERVICING YOUR ACOUNT
+Bear, Steams & Co. Inc.
+FROM: SV
+[2-USD
+* JRL *
+T0:sjV
+* JAIL *
+MARK TO MARKET
+MARK TO MARKET SHORT POS
+MARK TO MARKET
+MARK TO MARKET SHORT POS
+5-USD
+• JAL *
+[2-US0
+PER LOA
+* JRL
+FROM: SIV
+0: SIN
+* JAL *
+* JAL *
+* JRL *
+tO:
+PER LOA
+JRL
+FROM SM
+FROM: SU
+* JAL *
+'''SMVER
+[2:050*
+[2-USD**
+12-050"
+T5-USD"
+[2-U50
+APR 02
+DEBIT AMOUNT
+15,000,000.00
+10,323.00
+1,966.00
+1,731.64
+1,018,724.85
+*4,196,720.92
+15.523,209.08
+283.82
+19,819,646.18
+344.84
+027
+15,000,000.00
+10,323.00
+1,966.00
+1,731.64
+4,196,720.92
+15,523,209.08
+283.82
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28, 2002
+
+
+14 of 14
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+04/22/02
+04/23/02
+'JOURNAL"
+04/23/02 TOURNAL*
+DESCRIPTICI
+MVCR
+• JAL *
+APR 02
+2:USD
+DEBIT AMOUNT
+9.616.33
+$-55,599,188.66
+CRECIT AMOUNT
+2,101.70
+9.616.33
+$34,762,574.49
+STOP
+****** End of Statement******
+027
+04/27/02;13:44 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28, 2002
+
+
+Bear, Steams & Co. Inc.
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+What's In This Statement
+Financial Summary.............................
+Your Portfolio Holdings
+Transaction Detail ..............................
+FundA..............................
+Trades Not Yet Settle...................
+3
+4
+53
+56
+ImllmInklumll
+INTERNATIONAL CHARITABLE
+INTERESTS | 2/28/94
+C/O FINANCIAL TRUST COMAPNY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+-124.591
+22,526,001
+1,369.930
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+$23,771,340
+••••••••
+22,304,844
+1,466,496
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account
+Cash & Equivalent -
+Equities
+Market Value of Your Portfolio
+$7,666,148
+$2,132,291 : $-2,256,882
+Current market value
+Last statement's market value
+Short market value
+$23,895,931
+$19,301,360
+: $-4.662,664
+SP The suremen s foul ratanal purger red de Set revere die for portant iformation.
+03/29/02;22:30 001
+
+
+2 of 57
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+03/29/02;22:30 001
+
+
+3 or 57
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Money Fund
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance.
+appear in Transaction Detal.
+THIS PERICO
+55.847,610.07
+23,032,124.55
+1,001,392.62
+5,374.08
+305,223.92
+฿24,344,115.17
+-6,810,279.21
+-551,392.62
+-2,918.01
+-301,133.96
+S-7,665.723.80
+16,678,391.37
+322.526.001.44
+Cash Balance Summary
+Margin
+Short
+Net Cash Balance
+OPENING
+CLOSING
+1,195,451.88
+20,285,741.77
+4,652,158.19
+2,240,259.67
+.........
+$5,847,610.07
+$22,526,001.44
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+Short Dividends
+THIS PERIOD
+5,455.87
+1,310.83
+56.766.70.
+-2,918.01
+Portfolio Composition
+SHORT
+Cash/Cash Equivalent
+Equities
+Total
+2,256,882
+$2,256,882
+YEAR TO DATE
+14,435.97
+4,119.78
+$18.555.75
+-11,892.14
+LONG
+23,895,931
+2,132,291
+526.028,222
+027
+03/29/02;22:30 001
+CLEARED THRESH SONARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+Your Portfolio
+Allocation
+Equities
+7%
+Short Equities
+7%
+Cash & Equivalent-
+86%
+Unshaded portions denole debi balance and'or short
+from the absolute market value of your portolio.
+
+
+4 of 57
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+THE TREASURERS FUNDING
+DOMESTIC PRIME MAM PORTFOLIO.
+THE TREASURERS FUNDING
+DOMESTIC PRIME MIM PORTFOLIO
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+ACTION PERFORMANCE COMPANIES
+INC
+•......
+AMERICAN GREETINGS CORP-CLA
+COSTCO WHOLESALE CORP NEW
+CONSTELLATION BRANDS INC
+CLA
+CANDIES INC
+CACHE INC NEW
+... ..
+CIRCUIT CITY STORES INC
+CIRCUIT CITY GROUP
+DIAMONDS TRUST-UNIT SERIES 1
+. . . .
+ELECTRONIC DATA SYSTEMS CORP
+NEW
+FINLAY ENTERPRISES INC
+_________... ..
+SYMBOLCUSIP
+GTOXX
+GTDXX
+QUANTITY
+23,209.0
+846,720.92
+1.0000
+1.0000
+SYMBOUCUSIP
+ATN
+AM
+COST
+STZ
+CAND
+CACH
+CC
+DIA
+EDS
+SHRT
+SHAT
+SHRT
+MRGN
+MEGN
+MAGN
+SHRT
+QUANTITY
+-600
+-2,100
+1,100
+2,400
+70,989
+20,100
+4,200
+9,650
+-900
+*28,900
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+MARKET
+VALUE
+22,526,001
+....
+523,209
+846,721
+$23,895,931
+ESTIMATED
+ANNUAL INCOME
+7,482
+2 1.4300
+.......
+12,108 1.4300
+$19,590
+49.2500
+18.1500
+39.8200
+54.9600
+2.2000
+6.9500
+8.040
+103.7100
+57.9900
+12.0000
+MARKET
+VALU
+-29,550
+-38,115
+43,802
+-131,904
+156,176
+.......
+139,695
+75,768
+1,000,802
+-52,191
+346,800
+027
+ESTIMATED
+ANNUAL INCOME
+-340
+CURRENT
+YIELD (%)
+2.2039
+294
+15,710
+-540
+0.3880
+1.5697
+1.0347
+
+
+5 of 57
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+G-Ill APPAREL GROUP LTD
+GENUINE PARTS CO
+.. . ..
+IT TOPIC I
+HEARX LTD
+COM NEW
+¡-MANY INC
+HEAD N
+NY REGISTRY
+HUMANA INC
+KELLWOOD
+CO
+LEGGE
+& PLATT INO
+MOVADO GROUP INC
+WELL
+SHOE CO
+VC-CL A
+NOVEL DENIM HOLDINGS LTD
+NOKIA CORP: SPONSORED ADR
+REPSTG 1 SER A FM 5 PAR
+POLO RALPH LAUREN CORP-CL A
+OFFICE DEPOT INC
+SAFEWAY INC
+SMUCKER JM CO
+SIMBOUCUSIP
+GIll
+GPC
+HOTI
+EAR
+IMNY
+HED
+HUM
+KWD
+LEG
+MOV
+MAXS
+NVLD
+NOK
+RL
+ODP
+SWY
+SJM
+SKO
+STANDARD & POORS DEPOSITORY
+SPY
+RECEIPTS (SPDR'S) (BOOK ENTRY
+UNITS UNDIVIDED BENEFICIAL INT
+SYMBOL TECHNOLOGIES ING
+SBL
+OFFICE SERVICING YOUR ACOUNT
+Bear, Steams & Co. Inc.
+MRGN
+SHRT
+••••••••••••
+MRGN
+*....
+IRGI
+MRGN
+RE
+SHAT
+SHRT
+SHRI
+SHRT
+MRGN
+MRGN
+SHRT
+ARGI
+SHAT
+SHRT
+SHR
+MAGN
+QUANTITY
+48,450
+-2,700
+4,100
+23,700
+3,700
+12,500
+,000
+-4,100
+- 1,000
+-1,200
+2,700
+.......
+32,650
+-1,200
+2,400
+800
+-900
+-1,700
+-4,300
+-3,700
+3,900
+8.0000
+36.7700
+......
+20.9000
+.....
+1.0500
+4.9600
+3.2900
+13.5300
+1.29
+24.8000
+21.9500
+16.0000
+9.3000
+20.7400
+29.1800
+19.8500
+45.0200
+33.8000
+18.1000
+114.5200
+11.2400
+MARKE
+FALL
+387,600
+-99,279
+85,690
+24,885
+18,352
+.....
+41,125
+13,530
+99,58
+4,80
+-26.340
+43.200
+303,645
+-24,888
+70,032
+15,880
+40,518
+-57,460
+77,830
+-423,724
+43,836
+027
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+ESTIMATE
+NNUAL INCOM
+CURRENT
+YIELD (S
+3,132 3.154
+3.1547
+.........
+2,300
+-2,624
+-480
+-144
+-242
+- 1,088
+-5,324
+78
+5.5927
+2.6348
+... ..
+1.9355
+0.5467
+0.9724
+1.8935
+1.2565
+.177
+
+
+6 of 57
+Your Portfolio Holdings (continued)
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+Equities & Options (continued)
+TUESDAY MORNING CORP-NEW
+TIMBERLAND CO-CLA
+***********
+UNITED RETAIL GROUP INC
+VEST MARINE INC
+....
+.. . .
+YANKEE CANDLE INC
+Total Equities& Options
+TOTAL EQUITIES
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+SYMBOLCUSIP
+TUES
+TBL
+URGI
+WMAR
+YCC
+SHRT
+*******•
+ARGN
+SHAT
+QUANTITY
+2,100
+35,500
+.**.-.
+2,400
+-1,700
+20.4010
+.. ..
+42.2500
+.. . .
+6.9600
+.. . .
+20.2000
+23.1300
+MAKE
+ALLI
+-28,561
+....
+88,725
+247,080
+18,48
+-39,321
+$-124,591
+$-124,591
+$-7,862
+$23,771,340
+ANNUAL NOONE
+CURRENT
+YIELD (S
+.... ...
+.........
+... . .
+$-27,452
+$-27,452
+Transaction Detail
+INVESTMENT ACTIVITY
+SATLEMENT DATE
+DATE
+02/25/02
+02/20/02
+KENNETH COLE PRODUCTIONS INC
+QUANTITY
+3,400
+18.09860
+DEBIT AMOUNT
+61,754.24
+204,00
+...................
+027
+
+
+7 of 57
+SETTLEMENT TRADE
+DATE
+02/25/02
+02/20/02
+02/25/02 02/20/02 BOUGHT
+20/92/20
+202/20102
+02725/02
+02/20/02
+02725/02 02/20/02 BOUGHT
+20/5220
+
+'BOUGHT
+0226/02
+0272702BOUGAT
+CIRCUIT CITY STORES INC
+CIRCUIT CITY GROUP
+ECUTION BY BUL
+: 800 02-20-01
+48,00
+K-SWISS ING CLA"
+EXECUTION BY VKCO
+20-02-200090
+IS OF 02/20/02
+"NAUTICA ENTERPRISES INC
+EXECUTION BY RSSF
+VS 600 11-13-01
+SEC FEE
+.13
+AS OF 02/20/02
+TOMMY HILFIGER CORP-ORD"
+108.00
+AS OF 02/20/02
+FOREST LABORATORIES INC
+COVER SHORT,
+VS-500 01-25-02, -900 01-23-0
+DOMMISSION
+84.00
+AS OF 02/20/02
+RADIOSHACK CORP
+OVER SHOR
+XECUTION BY BUC
+VS - 1300 02-19-02, -600 02-13-
+COMMISSION
+114,00
+AS OF 02/20/02
+"AMERICAN EAGLE OUTFITTEAS INC
+NEW
+ECUTION BY JPI
+$ 2900 02-21-
+SYMBOLCUSIP
+cc
+NAUT
+TOM
+RSH
+"AEOS
+027
+QUANTITY
+800
+24.40000
+600
+-600
+1,800
+3185000"
+13.66000
+11.52490
+*7:50000
+1,900
+27.36560
+2,900
+*25.60750
+CLEARED THROUGH IT
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+19,583.00
+'''19,125.00*
+8,180.87
+20,867.82
+11,39900
+52,123.64
+74,276.75
+
+
+8 of 57
+SETTLEMENT TRADE
+DATE
+02/26/02
+02/21702
+0226/02 02/2102 BOUGHT
+02/26/02 02/21/02
+*BOUGHT
+02/26/02 02/21/02"SOLD
+02/26/02
+02726/02 022102BOUGHT
+02/26/02
+'*02/21/02 SOLD
+BEBE STORES INC
+EXECUTION BY ASSF
+VS 800 02-21-02
+"KENNETH COLE PRODUCHONS IN"
+VS 1600 02-21-02
+96,00
+ESTEE LAUDER COMPANIES INC
+CLA
+VS 1300 02-21-02
+COMMISSION
+78.00
+"NAUTICA ENTERPRISES INC"
+EXECUTION BY JPHO
+VS 2000 11-13-01
+SEC FEE
+.42
+"IC PENNEY CO INC
+SEE NOTE "S" ON BACH
+'S 3500 02-11-0
+OMMISSIO
+210,00
+SEC FEE
+"QUIKSILVER INC'**
+1.11
+S 3100 02-21-0
+OMMISSIO
+186.00
+"ANNTAYLOR STORES CORP**
+SEE NOTE 'S' ON BACK
+SECTION BY BUCK
+VS - 1300 02-21-02
+SEC PASSION
+78.00
+.80
+SYMBOLGUSIP
+BEBE
+EL
+"NAUT
+JCP
+ANN
+027
+QUANTITY
+800
+1,300
+-2,000
+3,500
+21.50000
+
+29.75000
+13.74590
+
+• 3,100
+*•19.50850**•**
+-1,300
+* 40.91070"
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+17,215.00
+29,952.92
+38,768.00
+27,476.38
+73,109.04
+**** 60,677.35
+......
+53,090.11
+
+
+9 of 57
+SETTLEMENT TRADE
+DATE
+02/26/02
+02/21/02
+02727102 02/22/02 BOUGHT
+20/22/20
+02/22/02
+02727102*02/22/02**S0LD
+02/27702
+02/22/02
+BOUGH
+02/28/02
+' 02/25/02BOUGHT
+20182/20
+02/25/02
+CHICOS FAS ING
+SHORT
+VS -2100 02-21-02
+OMMISSION
+1.26,00
+"CIRCUIT CITY STORES INC"
+CIRCUIT CITY GROUP
+138,00
+ESTE CAVE COMPANIES NE
+VS 1500 02-12-02
+DOMMISSION
+SEC FER
+80000
+"NAUTICA ENTERPRISES INC**
+EXECUTION BY JPHO
+SEC FEE 11-13-01. 20011-28-01
+SKECHERS USA INC
+/S 3300 02-22-02
+COMMISSION
+198,00
+COSTCO WHÖLESALE CORP-NEW
+EXECUTION BY SLKC
+VS 1100 02-25-02
+CIRCUT CY GRODFESINE
+EXECUTION BY INET
+VS 2600 02-25-02
+COMMISSION
+52,00
+SYMBOL/GUSP
+CHS
+EL
+•NAUT
+SKX
+027
+QUANTITY
+-2,100
+32.93780
+2,300
+*1,800
+3,300
+1,700
+2,600
+'16.24670
+29.39540
+#13:51870
+13.91690
+'44.41000
+16.95000
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+69,027.34
+37,520.41
+43,987.43
+®24,31829
+*46,138.77
+48,866.00
+44,137.00
+
+
+10 or 57
+SETTLEMENT TRADE
+DATE
+02/28/02
+02/25/02
+ö2/28/0202/25/02 BOÜGHT
+02728/02
+'''02/25/02*BÖUGHT
+02/28/02
+02/25/02
+02/28/02
+02/25/02
+02/28/02
+'*02/25/02BÖUGHT
+02/28/0202/25/02 SOLD
+DOLLAR GENERAL CORP
+72,00
+"SKECHERS USA INC
+20-5200050
+*TARGET CORP..
+9...
+"TIX COMPANIES INC NEW
+5 800 02-25-02
+IMMISSIO
+48.00
+SHOUTION BY BUCK
+VS 00 02.235-02
+SEC FER
+"CHICOS FAS INC"
+18.00
+YS MISSOR 21-02
+"BILLARDS INC-CLA
+126,00
+28.00
+SYMBOLCUSIP
+DG
+*SEX
+TX
+ANN
+CHS
+"DDS
+QUANTITY
+1,200
+14.24510
+13.50000
+• 1,300
+- 44.29000
+800°
+34.33000
+800°
+42.00000
+2,100
+*'''32.65590
+800
+- 18.60000
+027
+CLEARED THROUGH IT
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+17,181.12
+* 21,711.00
+57,670.00*****
+27,527.00
+33,536.49
+68,718.39
+14,816.77
+
+
+11 of 57
+SETTLEMENT TRADE
+DATE
+02/28/02
+02/25/02
+02/28/02 02/25/02 BOUGHT
+02/28/02
+02/25/02
+20/82/20
+02/25/02
+03/01702
+02/26/02
+03701:02
+02726/02
+DIAMONDS TRUST-UNIT SERIES 1
+SHORT
+XECUTION BY BUCH
+VS -800 02-25-02
+SEC MISSION
+122.00
+"DAIMLERCHRYSLER AG:
+COM
+OVER SHOR
+RECUTION BY BUO
+VS-500 11-12-01, -300 10-17-0
+COMMISSION
+48.00
+ECOLAB INC
+COVER SHORT
+EXECUTION BY MALI
+VSMMSS1012-01
+28.00
+'STANDARD & POORS DEPOSITORY
+48.00
+AMERICAN EAGLE OUTFITERS NE
+EXECUTION BY INET
+COMMIS 0226-02
+39,00
+"CHILDRENS PLACE RETAIL STORES
+EXECUTION BY JPHO
+SEC FEE 01-28-02
+"87
+SYMBOLGUSP
+DIA
+*DEX
+ECL
+*SPY
+"PLE
+027
+QUANTITY
+-800
+800
+101.53700
+39.29970
+*400
+800
+1,300
+-1,700
+45.29960
+T7.35000
+24.35650
+*34.05800
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+81,165.38
+• 31,502.76
+18,162.84
+89,015.66
+31,717.45
+57,882.73
+
+
+12 or 57
+SETTLEMENT TRADE
+DATE
+03/01/02
+02/26/02
+03/01/02 02/26/02 SOLD
+0370170202/26/02
+• BOUGH
+03/01702
+02/26/02
+03/01/02
+'02/26/02 SOLD
+03/01/02 02/26/02SOLD
+03/01/02
+02/26/02
+GADZOOKS INC
+EXECUTION BY RHCO
+SEC FEE 1-03-02, 200 10-05-01
+HOT TOPIC ING**
+ECUTION BY RSS
+S 1400 02-13-0
+SEC FEE
+LOVE COMPANIES 12?
+40 050226-02
+72,00
+WAL-MART STORES ING"
+VS 1200 02-26-02
+COMMISSION
+72,00
+ANNTAYLOR STORES CORP**
+SEE NOTE "S* ON BACK
+SHORT
+S - 1300 02-26-0
+OMMISSIO
+78.00
+SEC FEE
+VS - 1100 02-26-02
+COMMISSION
+SEC FEE
+"GAP INC
+136,00
+COMMISSION
+AS OF 02/26/02
+28.00
+SYMBOLICUSIP
+GADZ
+"HOTT
+LOW
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+17,543.48
+30,994.53
+ANN
+QUANTITY
+-1,100
+1,200
+1,200
+1,300
+15.96250
+22.15000
+- 46.39840
+''62.10000
+41.90130
+55,765.08
+74,607.00
+*''54,377.87
+*••1,100
+187900/
+GPS
+• 12.51530
+••• 20,587.68
+17,564:42
+027
+
+
+13 or 57
+SETTLEMENT TRADE
+DATE
+03/01/02
+02/26/02
+03/01702 02/26/02 BOUGHT
+20/10/60
+02/26/02
+*BOUGHT
+03/04/02: *02/27/02*BOUGHT
+03/04/02
+
+Z0/+0/E0
+
+03704/02
+02727/02
+GAP ING
+VS -5500 02-26-02
+SO ASSION
+1330.00
+LINENS N THINGS INC
+DOVER SHOR
+54.00
+NEWELL RUBBERMAID INC
+EXECUTION BY SIMM
+VS-200 09-17-01, -600 10-16-0
+1
+COMMISSION
+56,00
+AMERICAN LETTERS INC
+NEW
+EXECUTION BY INET
+COM 51027-02
+18,00
+CHILDRENS PLACE RETAIL STORES
+EXECUTION BY JPHO
+SE 00 0 1 28-02
+.31
+COACH NO
+RECUTION BY BUC
+5 800 02-05-02, 100 02-07-
+COMMISSION
+SEC FEE
+51.00
+KENNETH COLE PRODUCTIONS INC
+VS 800 02-27-02
+COMMISSION
+48,00
+SYMBOLCUSIP
+GPS
+LIN"
+NWL
+"AEOS
+PLCE
+COH
+KCP
+027
+QUANTITY
+-5,500
+*900
+800
+600
+-600
+900
+800
+13.73830
+27.89430
+29.80000
+'24.75000
+34.24500
+49.55000
+18.21170
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+75,214.51
+- 25,173.87
+23,911.00
+14,883.00
+20,531.69
+44,525.33
+14,632.36
+
+
+14 of 57
+SETTLEMENT TRADE
+DATE
+03/04/02
+02/27102
+03/04/02 02/27/02 SOLD
+03704/02 02/27102"
+03/04/02*02/27/02 BOUGHT
+Bear, Steams & Co. Inc.
+03/04/02
+03/04/02
+ö3/04/02
+02/27/02
+02727/02
+02/27/02
+GADZOOKS INC
+EXECUTION BY SOCO
+SEC FE 10-05-01, 100 06-29.-01
+HOT TOPIC INC*
+XECUTION BY RSS
+S 1900 02-13-0
+SEC FEE
+.64
+LIZ CLABORNE INC
+00140501-08-02, 700011002
+1.40
+"OFFICE DEPOT INC
+VITH RIGHTS TO PURCHASE PREFR
+TK UNDER CERTAIN CIRCUMSTANC
+TS 15000277-02K
+COMMISSION
+90.00
+"PACIFIC SUNWEAR OF CALIFORNIA
+EXECUTION BY ASSF
+"DUIKSILVER INC
+66.00
+WET SEAL INC-CLA
+EXECUTION BY SLKC
+VS 800 01-10-02, 600 12-21-01
+SEC FEE
+SYMBOL/GUSP
+GADZ
+"HOTT
+*OOP
+PSUN
+WISLA
+027
+QUANTITY
+-800
+1,900
+3,100
+17.57500
+' 22.14170
+2993330"
+19.25000
+3,100
+7,700
+24.36800
+
+32.14000
+IOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+14,044.78
+42,053.59
+92,590.83
+28,980.00
+75,555.80
+20.689.50
+44,980.32
+
+
+15 of 57
+SETTLEMENT TRADE
+DATE
+03/04/02
+02/27/02
+03/04/02 02/27/02 SOLD"
+03/04/02
+02/27/02
+03/04/02
+02/27/02
+03/05/02 02/28/02 BOUGHT
+03705/02
+02/28/02 BOUGHT
+03765/02 02728/02 BOUGHT
+WOLVERINE WORLD WIDE INC
+WITH RIGHTS TO PURCHASE PREFRD
+K UNDER CERTAIN CIRCUMSTANO
+ECUTION BY BUN
+00005027-02
+54.00
+"ANTAYLOR" STORES CORP**
+SEE NOTE 'S' ON BACK
+SHORT
+VS -600 02-27-02
+COMMISSION
+SEC FEE
+36.00
+"GAP INC
+COVER SHORT,
+EXECUTION BY BUC
+COMMIS02-26-02
+102,00
+POLYCOM INC
+PROSPECTUS UNDER SEPARATE MAL
+COVER SHORT
+EXECUTION BY TWPT
+VS -900 01-25-02
+PERICAN EAGLE OUTFITERS ING"
+
+CHICOS FAS INC"
+VS 1600 02-28-02
+COMMISSION
+96.00
+"KENNETH COLE PHODUCTIONS INE"
+EXECUTON BY BUCK
+VS 600 02-28-02
+COMMISSION
+36,00
+SYMBOLCUSP
+www
+*GPS
+"AEOS
+CHS
+"KEP
+027
+QUANTITY
+900
+600
+16.01730
+' 41.71960
+1,700
+*900
+700
+600
+12.37000
+25.97000
+- 24.84330
+34.12680
+"18.00000"
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+14,484.57
+24,980.38
+1,146.0
+23,388.00
+17,405.31
+54,713.88
+10,851:00
+
+
+16 + 57
+SETTLEMENT TRADE
+DATE
+03/05/02
+DATE
+02/28/02
+03/05/02 02/28/02BÖÜGHT
+HOT TOPIC INC
+EXECUTION BY WEDE
+SEC FO 0213-02, 1108 02-07-02
+POLO RALPH LAUREN CORP CLA
+SECUTON BY BUCKCK
+: 1000 02-28-0
+IMMISSIO
+03/65/02
+'''02/28/02*BÖUGHT
+03/05/02
+02/28/02
+03706/02
+
+13/01/0
+03/06/02
+03/01/02
+03/06/02 03/01/02*"BOUGHT
+SEE NOTE 'S ON BACK
+EXECUTION BY BUCH
+VS 180002-28-02
+COMMISSION
+108,00
+GAPING
+UNSOLICITED
+AVG PRICE SHOWN-DETAILS ON REC
+ACTUAL CONFIRM TO YOUR AGENT
+COVER SHORT,
+BEBE STORES INC
+EXECUTION BY INET
+VS 800 02-21-02
+SEC FESSION
+22.00
+BEST BUY COMPANY INC
+VS 400 03-01-02
+COMMISSION
+24,00
+CHILDRENS PLACE RETAIL STORES
+EXECUTION BY PHO
+SEC FE 01-28-02, 1000 01-30-02
+CHICO FAN INC
+EXECUTION BY BUCI
+/S 3100 03-01-0:
+COMMISSION
+186.00
+SYMBOLGUSIP
+HOTT
+'GPS
+"BEBE
+*BBY
+PLCE
+'CHS
+027
+QUANTITY
+-1,700
+1,000
+22.86500
+- 26.69760
+1,800
+- 43.02500
+2,400
+800
+400
+3,100
+12.11910
+23.92710
+68.00000
+34.76500
+34.63430
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brooklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+38,854.91
+'''26,772.60"
+77,568.00*****
+29,253.84
+19,102.39
+27,239.00
+52,131.71
+107,567.33
+
+
+17 of 57
+SETTLEMENT TRADE
+DATE
+03/06/02
+DATE
+03/01/02
+63/66/02 03/01702**BOUGAT
+03708/02
+03/06/02
+*23/01/02 SOLD*
+03/06/02
+''03/01/02 BOUGHT
+03/06/02
+03/01/02
+20/0/ED20/90/80
+'SOLD
+KENNETH COLE PRODUCTIONS ING
+COMMISSION
+78,00
+DOLLAR GENERAL CORP'**
+114,00
+E20 207-02T
+SEC FEE
+.88
+"SHARPER IMAGE CORP
+EXECUTION BY NITE
+SEC PO 12-28-01, 20012-21-01
+SEC FEE
+"TARGET CORP"***
+SEE NOTE *S" ON BAC
+EXECUTION BY BUCI
+S 800 03-01-0
+IMMISSIO
+48,00
+"TALBOTS INC
+S 100001-0-02, 500 01-16.02
+SEC FESSION
+-20.00
+"WET SEALING-CLA"
+EXECUTION BY MON
+SEC FE 12-21-01, 170012-17-01
+SEC FEE
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+SYMBOLGUSIP
+QUANTITY
+KCP
+1,300
+18.88280
+DEBIT AMOUNT
+24,640.64
+"BE
+1,900
+- 7420000"
+**•****27,109.00
+"HOT"****'''
+2,500. 23.28070....
+••*58.185.87
+*SHAP
+-1,000
+*14.62000
+8Lt09TL
+800
+42.67710
+34,204.68
+40.71510
+60,966.73
+"WTSLA
+2,000
+*''33-77500
+67,533.98
+027
+
+
+18 or 57
+03/06/02
+
+03/06/02 03/01/02 SOLD
+03/06/02
+13/01/0
+03/06/02
+03/01702
+03/07702
+03/04/02
+03/07/02
+03/04/02
+CALL AMERN EAGLE APR 025****
+2002/02/9023
+ANG PRICE SHOWN DETALS ON RED
+ACTUAL CONFIRM TO YOUR AGENT
+AS OF 03105002
+"BEBE STORES ING
+SECTION BY NET
+VS - 1500 03-01-02
+SEC FESSION
+-55.00
+EDO CORP
+SEE NOTE 'S' ON BACK
+COVER SHORT,
+XECUTION BY BUO
+5 - 1700 09-20-0
+COMMISSION
+102,00
+EMERSON ELECTRIC C
+-26.00
+CHILDRENS FLACE RETAIL STORES"
+EXECUTION BY JPHO
+VS 300 01-30-02, 1100 01-04-02
+, 900 01-07-02
+1.20
+COACH INC
+$ 700 02-07-02, 700 12-11-0
+0 12-04-
+OMMISSION
+1.19.00
+SYMBOLCUSIP
+DAQUDE
+BEBE
+*EDO
+EMA
+"PLCE"
+COH
+027
+QUANTITY
+49
+-1,500
+OL:
+400
+2,300
+500
+2.38750
+''23 92120"
+28-31650
+59.16440
+
+51.90840
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+11,519.42
+35,821.26
+48,255.05
+23,626.40
+79,671.64
+77,756.43
+
+
+19 or 57
+DATE
+03/07/02
+03/04/02
+Bear, Stearns & Co. Inc.
+GYMBOREE CORP
+EXECUTION BY INET
+VS 1600 02-04-02, 2100 02-060
+SEC FESION
+120,00
+,84
+03/07/02 03/04/02 SOLD"
+03/07/02"
+03/04/02
+03/07/02 03/04/02
+03/07/02 03/04/02"BOUGHT
+83787702 83784702'503
+1.61
+HE SWEAR OF CALFORNIA
+EXECUTION BY INET
+VS 700 03-04-02
+DOMMISSION
+21.00
+CONSTELLATION BRANDS INC
+SEE NOTE IS ON BACK
+SHORT.
+42.00
+MERSON ELECTRIC CO"
+OVER SHOR
+S-800 02-05-02k
+COMMISSION
+36.00
+"TUESDAY MOANING CORP-NEW
+SECTION BY INE
+S - 1400 03-04-0
+COMMISSION
+SEC FEE
+42.00
+SYMBOLCUSIP
+GYMB
+моН.
+PSUN
+'SIZ
+"EMR
+"TUES
+027
+QUANTITY
+4,000
+4,600
+700°
+700°
+13.89070
+
+23.75000
+•53.01000
+600
+1,400*
+- 62.50000
+20.93500
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+55,426.96
+107,129.81
+16,661.00
+*37,049.44
+"37,551.00
+29,251.56
+
+
+20 of 57
+SETTLEMENT TRADE
+DATE
+03/05/02
+63/08/02 03/05/02 *SOLD
+03/05/02
+ö3/08/02
+*03/05/02
+03/08/02 03/05/02"
+'''SOLD
+03/05/02
+03/08/02 03/05/02 SOLD
+AMERICAN EAGLE OUTFITERS ING
+NEW
+RECUTION BY JPH
+S 3800 01-30-0
+SEC FEE
+1.44
+"ALLOY INC
+(FRM ALLOY ONLINE INC)
+EXECUTION BY INET
+VS 2300 04-17-01
+COMMISSION
+69,00
+SEC FEE
+"ANNAYLOR STORES CORP
+SEE NOTE "S* ON BACK
+EXECUTION BY GKMC
+VS 800 03-05-02
+COMMISSION
+56.00
+"COSTCO WHOLESALE CORP. NEW
+EXECUTION BY INET
+VS 800 03-05-02
+COMMISSION
+24.00
+COACH IN..
+VS 700 12-04-01, 100 10-12-01
+COMMISSION
+48,00
+58
+"CHICOS FAS INC
+VS 2300 03-01-02
+SEC FESSION
+1228,00
+"KENNETH COLE PRODUCTIONS ING"
+SEC FEE
+AS OF 03/05/02
+519.00
+SYMBOLCUSIP
+AEOS
+"ALOY
+ANN
+"COS
+COH
+CHS
+'KCP
+027
+QUANTITY
+-3,800
+2,300
+800°
+800
+800*
+2,300
+1,700
+25.21780
+•'''11:39380
+39.81000
+''33.94960
+-47:80000
+35.20300"
+20.40110
+IOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+95,811.20
+32,181.25
+31,919.00
+
+38,176.42
+80,812.68
+34,547.34
+
+
+21 or 57
+SETTLEMENT TRADE
+DATE
+DATE
+03/05/02
+63/08/02 03/05/02 *SOLD
+ö3/08/02
+03/05/02
+03/05/02
+03/08/02 03/05/02* BOUGHT
+13/05/0
+*SOLD
+03/08/02 03/05/02 SOLD
+FOOTSTAR INC
+'S 500 01-15-02
+OMMISSION
+SEC FEE
+,20.00
+FEDERATED DEPARTMENT STÖRES
+INC-DEL
+EXECUTION BY DAIN
+VS 800 12-06-01, 300 12-05-0
+COMMISSION
+SEC FEE
+77.00
+FOSSIL INC
+EXECUTION BY REDI
+VS 500 12-19-01, 700 12-31-01
+COMMISSION
+"GADZOOKS ING***
+EXECUTION BY RHCO
+SS 200 06-29-01
+,31
+"HOT TOPIC IN
+EXECUTION BY INE
+COMMISSA 05-03
+123,00
+ESTEE LAUDER COMPANIES INC
+EST N 500 02102
+SEC FISSION
+48,00
+.38
+"MASCO CORP"'***
+WITH RIGHTS TO PURCHASE PREFRO
+STK UNDER CERTAIN CIRCUMSTANCE
+COMMISSIÓN
+SEC FEE
+96,00
+.68
+SYMBOLCUSP
+FTS
+FOSL
+"GADZ
+'HOI
+EL
+MAS
+027
+QUANTITY
+-500
+"1,700
+26.41380
+•42:34000"
+1,200
+-1,200
+'4,100
+J0E
+-1,600
+26.08980
+• 17.09500
+
+31.19000
+- 28.31950
+IOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+13,161.70
+*'47,147.29
+31,268.29
+20,498.69
+®*93,974.70
+.....
+24,888.62
+45,199.52
+
+
+22 or 57
+
+03/08/02 03/05/02 SOLD
+Bear, Steams & Co. Inc.
+03/05/02
+03/05/02
+03708/02
+03/05/02
+"SÖLD"
+03708/02"
+03/05/02 SOLD
+03/08/02 03/05/02 SOLD
+PACIFIC SUNWEAR OF CALIFORNIA
+S0000502
+SKECHERS USA INC
+EXECUTION BY VRCO
+COMMIS500-04-02, 1006108-02
+SEC FESSION
+SHARPER IMAGE CORP
+EXECUTION BY NITE
+SEC FEE
+SEC FEE 1221-01, 15001224-01
+TX COMPANIES INC NEW
+VS 700 11-13-01, 400 12-03-01
+COMMISSION
+SEC FEE
+"TALBOTS INC"
+EXECUTION BY DAN
+VS 300 01-16-02, 800 02-04-02,
+83,00
+WAL-MART STORES INC
+EXECUTION BY GMC
+VS 1200 02-26-02
+SEC PISSION
+171.00
+"ZALE CORP NEW"
+VS 200 01-08-02, 600 12-26-01
+COMMISSION
+48,00
+SEC FEE
+.52
+SYMBOL/GUSP
+PSUN
+*SKX
+"SHAP
+027
+QUANTITY
+2,000
+2,300
+23.44250
+16.05290
+2,100
+1,100
+-1,400
+14.78000
+37.01100
+'39.47230
+1,200
+- 61.25070
+800
+• 42.64100
+CLEARED THROUGH IT
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+46,900.00
+36,745.11
+*31.022.53
+40,630.48
+55,147.39
+73,400.73
+34,049.28
+
+
+23 of 57
+
+03/08/02 03/05/02BOÜGHT
+ö3/08/02
+03/05/02
+03/08/02 *03/05/02*BOUGHT
+103/05/02
+*BOUGHT
+*03/05/02
+ANNTAYLOR STORES CORP
+SEE NOTE "S' ON BACK
+OVER SHOR
+ECUTION BY GM
+0 10 02 2 02 00 022
+APOLLO GROUP ING-CLA
+ONE ON BY SL
+5 - 1050 12-13-0
+BUS WHOLESALE CLUB ING
+SHOUTION BY BUCK
+20-50-0002
+COMMISSION
+SEC FEE
+72.00
+BILLARDS INC-CLA
+ING PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+COVER SHORT,
+DIAMONDS TRUST UNIT SERIES
+3-100 11-06-01, -500 11-08
+-1050 02-19-02, -500 11-1
+1, -400 01-02-02, -300 02-13
+12, -450 12-19-0
+"STAPLES INC'**
+COVER SHORT,
+EXECUTION BY SBSH
+VS - 1700 02-13-02
+SYMBOLCUSF
+ANN
+"APOL
+BJ
+'IDS
+"DIA
+"SPLS
+027
+QUANTITY
+4,000
+40.11520
+1,050
+1,200
+500
+3,300
+• 51.71750"
+42.04200
+106.17250
+1,700
+
+IOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+160,755.80
+54,31838
+50,362.64
+• 11,041:80
+350,582.25
+*34,457.00
+
+
+24 or 57
+
+Bear, Steams & Co. Inc.
+03/08/02 03/05/02BOÜGHT
+20180/E0
+03/05/02
+03/11702 *03/08/02*BOUGHT
+03/11/02
+03106/02
+03/11702
+203/0/2
+'BOUGHT
+03/11702 83/08/02 BOUGHT
+STANDARD & POORS DEPOSITORY
+RECEIPTS (SPDRS) (BOOK ENTRY
+COVER SHORTED BENEFICLAL INT
+500231802. 80022500
+"URBAN OUTFTTERS INC
+OVER SHOR
+85-900 12-1804
+WAL-MART STORES INC
+SHORT,
+VS -800 03-05-02
+COMMISSION
+SEC FEE
+18.00
+AMERICAN EAGLETTERS INC
+NEW
+EXECUTION BY INET
+VS 2900 03-06-02
+DOMMISSION
+87,00
+ANNAYLOR STORES CORP
+SEE NOTE 'S' ON BACK
+EXECUTION BY LEHM
+476,00
+BED BATH & BEYOND INC
+1S 1500 05-0602
+COMMISSION
+45.00
+"COSTCO WHOLESALE COAP NEW
+XECUTION BY SLA
+S 1700 03-06-0
+SYMBOLCUSIP
+SPY
+URBN
+WMT
+"AEOS
+ANN
+*BBBY
+B0ST
+027
+QUANTITY
+1,700
+116.29500
+900
+800*
+2,900
+6,800
+1,700*
+'22.17000
+61.19840
+1'22:58330
+40.36810
+31.32660"
+"38.85000"
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+197,818.50
+19,968.00
+48,894.98
+'**'74,293.57
+274,994.08
+*47,049.90
+'66,060.00
+
+
+25 or 57
+ELEMENT TATE
+03/11/02
+03/06/02
+03/11/02 03/06/02 BOUGHT
+03/17/02 03/06/02
+• BOUGHT
+0371770203/06/02
+03/11/02
+03/06/02
+03/11/0203/06/02S0LB
+03/1102
+03/06/02
+03/17702*03/06/02*"BOUGHT
+OFFICE SERVICING YOUR ACOUNT
+Bear, Steams & Co. Inc.
+CHRISTOPHER & BANKS CORP
+EXECUTION BY INET
+DO 05 03-06-02
+159,00
+COACH INCH
+VS 700 03-06-02
+COMMISSION
+42,00
+VS 300 03-06-02
+"FOOT LOCKER INC
+18,00
+SEC FISSION
+INS DATED DEPARTIMENF STORES
+EXECUTION BY BUCI
+/S 500 03-06-02
+COMMISSION
+30.00
+EXECUTION BY RHCO
+VS 800 06-29-01
+SEC FEE
+,21
+"GENESCOING
+WITH RIGHTS TO PURCHASE PREFRD
+K UNDER CERTAIN CIRCUMSTAN
+ECUTION BY BU
+VSMMISS300G-02
+36,00
+"GYMBOREE CORP
+EXECUTION BY INET
+VS 1500 03-06-02
+COMMISSION
+45,00
+SYMBOLGUSIP
+CHeS
+COH
+FD
+"GCO"
+"GYMB
+027
+QUANTITY
+5,300
+700
+0OE.
+2,100
+500
+****800
+600
+26.00970
+46.90000
+19.98000
+''*1734050
+42.56000
+* 17.01000******
+* 24.65800
+
+CLEARED THROUGH ITE
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+138,025.41
+32,887.00
+6,027.00
+36,273.50
+21,325.00
+•*13:592.79
+14,845.80
+18,427.80
+
+
+26 of 57
+03/11/02
+
+03/11/02 03/06/02 SOLD
+03/11/02
+03/06/02
+"BÖUGHI
+03/17/02
+03/06/02
+03/11/02 03/06/02 BOUGHT
+03/17/02
+03/06/02
+03/120203/07/02BOUGHT
+Bear, Steams & Co. Inc.
+HOT TOPIC INC
+EXECUTION BY INET
+NO MS 03-06-02
+111,00
+ESTEE LAUDER COMPANIES INC
+160.00
+SYMBOL TECHNOLOGIES INC
+EXECUTION BY SBSH
+VS MIS 03-06-02
+161,00
+"BILLARDS" INCOLA
+OVER SHORT
+5 - 1200 02 1-02. 800 02-25
+02, -1100 02-26-02
+186.00
+UP MORGAN CHASE & CO**
+COVER SHORT,
+8 CUS0 02319-02
+OMMISSIO
+51,00
+WALMART STORES INC
+48,00
+"BROWN SHOE COMPANY"
+VS 3100 03-07-02
+COMMISSION
+186,00
+SYMBOLGUSIP
+HOTT
+DDS
+PM
+WM
+BWS
+027
+QUANTITY
+3,700
+1,000
+21.81220
+30.95470
+00EZ
+3,100
+850
+*800
+3,100
+10.89300
+21.85250
+- 33.92000
+61:10000"
+18.57640
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+80,831.14
+30,879.23
+25,229,90
+67,94375
+'28,89800
+48,943.00
+57,787.84
+
+
+27 or 57
+SETTLEMENT TRADE
+DATE
+03/12/02
+03/07/02
+03/12/02 03/0702"BOÜGHT
+03/12/02 03/07/02 SOLD"
+Bear, Steams & Co. Inc.
+03/12/02
+
+03/12/02
+*03/07/02 BOUGHT
+03/12/02 03/07/02 "BOUGHT
+03/12/02 83/07/02 SOLD
+03/12/02 03/07/02 BOUGHT
+BEST BUY COMPANY INC
+COMMIS 0307-02
+114.00
+CATO CORP CL'A"
+EXECUTION BY SLKE
+/S 1900 03-07-02
+FOOT LOCKER INC
+EXECUTION BY RSSF
+VS 800 01-10-02, 1900 12-31-01
+OMMISSION
+EC FE
+799,00
+HOT TOPIC INC.
+EXECUTION BY INET
+VS 500 03-07-02
+COMMISSION
+15.00
+LOWES COMPANIES INC
+VS 1500 03-07-02
+COMMISSION
+90,00
+"STEVEN MADDEN LTD
+2500 03-07-02
+"SHARPER IMAGE CORP
+SEC PID 122401. 0 122701
+SEC FEE
+"TARGET CORP"****
+SEE NOTE "S' ON BACK
+XECUTION BY BUC
+S 1200 03-07-4
+COMMISSION
+72,00
+SYMBOLGUSIP
+BBY
+"CACOA
+"HOTT
+LOW
+SH00
+"SHAP
+027
+QUANTITY
+1,900
+1,900
+2,700
+500*
+2,500
+-1,500
+1,200
+72.40000
+-20.18500
+1738930"
+2134000"
+'43.25910
+= 1500000
+15.05850"
+43.31000
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+137,689.00
+38.366.50
+46,746.40
+10,700.00
+64,993.65
+37,515.00
+22,572.41
+52,059.00
+
+
+28 of 57
+SETTLEMENT TRADE
+DATE
+03/12/02
+03/07/02
+63/13/02 03/08/02*"SOLD
+03/13/02
+03108/02
+ZOVEL/EO
+03/13/02
+ZOVELICO
+03713/02 03/08/02"BOUGHT
+SAKS INC
+COMMISSION
+113,76
+BESTBUY COMPANY INC.**
+500 320702)
+98.00
+"CHICOS FAS INC"
+VS 800 03-01-02, 1600 02-28-02
+COMMISSION
+SEC FEE
+1.28.00
+"FOOT LOCKER ING
+EXECUTION BY BUC
+/S 4300 12-31-01, 1400 09-28-
+SEC FESSION
+1342,00
+"GADZOOKS INC
+5020 01 20 0702012
+KÖHLS CORP"
+ES 600 01-10-02CK
+SEC FESSION
+86,00
+LOWES COMPANIES INC
+VS 800 03-08-02
+COMMISSION
+48.00
+SYMBOLGUSIP
+SKS
+"BBY
+CHS
+GADZ
+KSS
+"LOW
+027
+QUANTITY
+1,896
+800
+2,400
+-5,700
+3,400
+600*
+*800
+12.19580
+* 75.15570**
+35.49710
+17.66630
+16.83940
+69.00000
+- 43.80000
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+23,252.00
+60,060.65
+85,032.76
+100,339.39
+57,238.10
+41,348.37
+*35, 103.00
+
+
+29 of 57
+SETTLEMENT TRADE
+DATE
+03/13/02
+
+63/13/02 03/08/02 BOUGHT
+NAUTICA ENTERPRISES INC
+EXECUTION BY JPHO
+1. 1500 11-6-01. 1500 12-31-0
+SEC FEE
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCI
+EXECUTION BY BUCH
+VS 800 03-08-02
+DOMMISSION
+48,00
+03/13/02
+03/13/02"
+n*0308/02
+140.00
+.63
+0371370203/08/02 SOLD
+03/13702
+*03/08/02
+03/13/02 03/08/02 SOLD
+"SKECHERS USAINC
+SEC FESSION
+TENCE STORE INC
+ES 120001-0702
+COMMISSION
+SEC FEE
+136.00
+"TIMBERLAND CO-CLA
+/ 160003-0802
+OMMISSION
+96,00
+"WET SEALING-CLA**
+EXECUTION BY SLKC
+VS 800 12-17-01, 1100 12-07-01
+SEC FEE
+SYMBOLCUSIP
+NAUT
+"OBP
+ZaK
+SKX
+"STGS
+"WTSLA
+027
+QUANTITY
+-5,200
+300
+15.16750
+2005000'
+2,000
+2,900
+1,200
+1,900
+20.87380
+
+38.09710
+32.76630
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+78,854.81
+'16,103.00
+41,591.97
+50,201.51
+*35,483.58
+61,066.36
+62,240.03
+
+
+30 or 57
+SETLEMENT TATE
+03/13/02
+
+03/13/02 03/08/02 "BOUGHT
+03713/02
+*03/08/02
+03/13/02 03/08/02 BOUGHT
+03/13/02"
+03/13/02
+03708/02
+ZALE CORP NEW
+EXECUTION BY MDLD
+273.00
+"EASTMAN KODAK CO"
+VER SHO
+5-BO00 O1-Y M02, 1300 01-0
+02
+COMMISSION
+147.00
+KELLWOOD 'C0***
+WITH RIGHTS TO PURCHASE PREFRO
+STK UNDER CERTAIN CIRCUMSTANCE
+COVER SHORT,
+SU30007-1B-01. 300 11-12-
+LINENS N THINGS INC
+COVER SHORT,
+63.00
+MICHAELS STORES INC
+VS -500 11-30-01, - 1000 12-05-
+COMMISSION
+105,00
+URBAN OUTFITTERS INC
+002160: 0020
+SYMBOLCUSIP
+KWD
+*MIK
+•URBN
+027
+QUANTITY
+-3,900
+2,100
+900°
+40.84400
+3280000*
+25.60080
+30.6888
+36.20000
+1,300
+
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+159,001.21
+' 69,042.00
+*41,072.28
+27,697.92
+"54,420.00
+31,365.02
+
+
+31 or 57
+SETTLEMENT TRADE
+DATE
+03/14/02
+03/11/02
+03/14/02 03/11/02 BOUGHT
+03714/02 03711/02
+• BOUGHT
+
+*'*SOLD
+03/14702
+03/11702
+''''BOUGHT
+2017 LED
+
+03714/02"
+03/11/02
+Bear, Steams & Co. Inc.
+83774702 03771702'BOUG
+CHILDRENS PLACE RETAIL STORES
+XECUTION BY JPHO
+S 800 03-11-02
+COACH INC
+(ECUTION BY BUO
+S 1900 03-11-0
+COMMISSION
+114.00
+FOOTSTAR INC*
+YS MISS -11-02
+72,00
+"FOOT LOCKER ING
+VS 1800 09-28-01
+COMMISSION
+SEC FEE
+
+"LIZ CLAIBORNE ING
+OSS 1MSS03-1102
+102,00
+LOWES COMPANIES INC
+36.00
+TALBOTS INC"
+ES 500012-27-01, 1200 02-05.02
+- 400 11-27-01, 1800 12-21-01,
+900 11-28-0
+SEC FESSION
+336,00
+2.48
+"TIMBERLAND" CO'CLA
+EXECUTION BY GMO
+COMMS 0211-02
+147,00
+SYMBOLCUSP
+PLCE
+COH
+FTS
+LOW
+027
+QUANTITY
+800
+1,900
+1,200
+1,800
+1,700
+600
+4,800
+32.87500
+48.18830
+• 31.18360
+''17.23370
+28.30000
+41.79800
+34.43430
+2,100*
+''39:3730
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+26,315.00
+91,686.77
+ZE LOS'LE.
+61:268'0E
+25129.80
+00 22281.
+164,931.16
+84:112:25
+
+
+32 or 57
+SETTLEMENT TRADE
+DATE
+03/14/02
+03/11/02
+63/14/02 03/11702**BOUGAT
+20/94/60
+'*03/12/02**BOUGHT
+03/15/02 03/12/02 BOUGHT
+03/15/02
+'03/12/02
+20184/60
+03/13/02
+*BOUGHT
+03/18/02
+03/13/01
+*SOLD
+03/18/02
+13/13/0
+*SOLD
+EMERSON ELECTRIC CO
+COMMISSION
+30,00
+POUNDAY NETWORKS INC****
+4S-3900 01-1-02
+JONES APPAREL GROUP INC
+VS 2300 03-12-02
+COMMISSION
+138.00
+LIZ CLAIBORNE INC
+EXECUTION BY GSCO
+VS 800 03-12-02
+COMMISSION
+56.00
+"TALBOTS INC
+S 100 11 28 01. K600 12.05.01
+COMMISSION
+SEC FEE
+902,00
+COACH ING
+EXECUTION BY BUCH
+VS 800 03-13-02
+COMMISSION
+48.00
+JONES APPAREL GROUPING"
+EXECUTION BY FCAP
+VS 2300 03-12-02
+DOMMISSION
+SEC FE
+1,21.00
+"QUIKSILVER INC"
+EXECUTION BY RHCO
+VS 1100 02-21-02, 1100 02-27-0
+, 100 01-30-0
+OMMISSIO
+SEC FEE
+791.00
+SYMBOLCUSIP
+EMA
+"FBAY
+'SNY
+"COH
+SNY
+*ZaK
+027
+CLEARED THROUGH IT
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+32,977.00
+CRECIT AMOUNT
+**31,965.75
+81,694.90'
+22,695.00
+QUANTITY
+500
+65.86400
+3,900
+-8:19250
+2,300
+-35.45300.......
+800
+
+-1,700
+35.05790
+800
+49.54260
+2,300%
+2,300
+'2221810
+59,480.53
+39,697.08
+82,392.76
+50,924.88
+
+
+33 or 57
+SETTLEMENT TRADE
+DATE
+03/18/02
+03/13/02
+63/18/02 03/13/02 BOUGHT
+03718/02
+03/19/02
+03/13/02
+*03/14/02
+03/19/02
+*03/14/02
+03719/02
+03/14/02
+BOUGH
+TIX COMPANIES ING NEW
+EXECUTION BY RHCO
+OMMISSION
+5 1003-01, 8009525-0
+SEC FEE
+1.45
+"ALBERTSONS IN..
+VS -950 10-17-01
+SAKS INCI
+6 20 10801 06 08-19
+OOMMISSION
+STAGE STORES INC
+91.00
+ES IU001B7-02. 1100 01-03-02
+800 01-02-02, 2500 12-28-01
+1000 12-26-01
+COMMISSION
+165.00
+'SHARPER IMAGE CORP
+EXECUTION BY NITE
+1 20 201 20 2328
+SEC FEE
+MOVADO GROUP INC
+COVER SHORT,
+VS -900 08-29-01
+COMMISSION
+54,00
+SYMBOLGUSP
+TJX
+"AES
+SKS
+SPIS
+SHAP
+MOV
+027
+QUANTITY
+-2,500
+950
+38.58900
+**32:5000
+1,300
+5,500
+13.13610
+27.79840
+-7,850
+16.19360
+900
+19.94710
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+96,281.05
+1*30,947:00
+17,182.93
+152,708.90
+127,102.85
+18,021.39
+
+
+34 ol57
+SETTLEMENT TRADE
+DATE
+03/19/02
+03/14/02
+03/20/02 03/15/02 "SOLD*"
+03/20/02
+53715/02
+*SOLD
+03/20/02
+03/15/02
+"'SOLD
+03/20/02 03/15/02 SOLD
+03/20/02"
+**03/15/02 SOLD*
+03/20/02
+*03/15/02
+*SOLD
+SHOPKO STORES ING
+ES -10 102-01 - 2000 10.15
+COMMS0 02-05-01
+210,00
+"AMERICAN EAGLE OUTFITERS INC"
+B 0.302 80 012902.
+4800 02-01-02, 2900 03-06-02
+2900 02-21-02, 2700 01-31-02
+SEC FEE
+5.99
+CHARMING SHOPPES INC
+EXECUTION BY NITE
+VS 4100 07-18-01, 4800 02-13-0
+SEC FEE
+1.00
+FOOT LÖCKER ING
+FOSSILINC**
+EXECUTION BY FLIT
+VS 1700 12-31-01, 2800 12-18-0
+1 1200 02-12-02, 4200 01-02-02
+SEC FEE
+4,96
+"GENESCOING"
+NITH RIGHTS TO PURCHASE PREFRI
+STK LINDER CERTAIN CIRCUMSTANC
+VS 600 03-06-02, 1600 01-25-02
+800 01-30-02, 1600 01-24-02
+OMMISSION
+276,00
+"GYMBOREE CORP"
+EXECUTION BY FLTT
+VS 1500 03-06-02
+SEC FEE
+.30
+SYMBOL/CUSP
+SKO
+"*EOS
+"CHAS
+"FOSL
+GCO
+"GYMB
+027
+QUANTITY
+3,500
+16.02490
+14,200
+8,900
+28,100
+:12,300
+4,600
+"28.09680
+7.48150
+16.72310
+26.88040
+*27.15000
+12.96250
+One Metratech Center North
+Brocktyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOO February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+56,312.15
+398,953.57
+66,569.35
+467,930.06
+"330,608.96
+124,597.12
+19,428.45
+
+
+35 or 57
+DATE
+03/20/02
+03/15/02
+03/20/02 03/15/02 SOLD
+03/20/02
+13/15/0
+*SOLD
+03/2002: *03/15/02**S0LB
+03/21/02
+*03/18/02
+*SOLD
+03/27702
+03/18/02
+100 10-1020-00 1-01-37.1
+0 10-03-01
+DOMMISSION
+SEC FEE
+1,37.00
+"STACE STORES INC
+NEW
+EXECUTION BY SBSH
+Be 0 1201 20 220
+"SHARPER IMAGE OORP
+EXECUTION BY FLIT
+V9 350 12-20-01, 200012-18-01
+SEC FEE
+WOLVERINE WORLD WIDE INC*•*
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+S00 0 2 02 2021202
+COMMISSION
+SEC FEE
+AMERICAN EAGLE OUTFTTERS ING
+NEW
+EXECUTION BY JPHO
+2500 02-04-02, 1500 02-15-02,
+JOSEPHA BANK CLOTHIERS INC
+EXECUTION BY JEFF
+VS 600 10-25-01, 2500 05-23-01
+, 500 04-12-01
+SEC FEE
+SYMBOLGUSIP
+KSWS
+SIGS
+"SHAP
+"AEOS
+Jose
+027
+QUANTITY
+-2,900
+7,000
+2,350
+2,900
+39.16300
+28.23500
+16.60000
+=16:79740
+-19,500
+27.84230
+3,600
+11.01000
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+113,468.99
+197,627.03
+8,994.4
+48,522.72
+542,901.70
+39,620.40
+
+
+36 or 57
+SETTLEMENT TRADE
+DATE
+03/21/02
+03/18/02
+03/21/02 03/15/02 SOLD
+Bear, Steams & Co. Inc.
+*03/18/02
+2011ZE
+*SOLD
+03/21702 *03/18/02*S0LB
+03/21802
+03/18/02
+*SOLD
+83727302'
+**03/78/02''S0B
+CHRISTOPHER & BANKS CORP
+EXECUTION BY FLTT
+SEC FEE 03-0-02
+2,51
+CENE COLE PRIOUCTIONS NE
+FOOT LOCKER ING
+EXECUTION BY WEDB
+VS 1100 01-24-02, 1200 01-23-0
+DOMMISSION
+SEC F
+551.00
+GUITAR CENTER INC
+EXECUTION BY NITE
+SS FED 11-14-01
+.86
+LIZ CLAIBORNE INC
+ES 170003Y B02 800 03-12-02
+2300 01-10-02, 1000 12-05-0
+OMM0SS:17.02, 600 121.01
+SEC FEE
+"RESTORAMON HARDWARE"IN" BEL"
+EXECUTION BY JPHO
+VS 2571 12-17-01, 4529 12-14-0
+SEC FEE
+1,35
+SYMBOLGUSIP
+CHBS
+*KCP
+LIZ
+"STO
+027
+QUANTITY
+-5,300
+4,800
+2,300
+3.600
+7,100
+31.55000
+21.80000
+16.40000
+• 15.80400
+29.18850
+7,100
+*12.60750
+CLEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+167,197.49
+104,287.43
+37,543.43
+206.794.24
+18.84899
+*89,496.90
+
+
+37 01 57
+SETTLEMENT TRADE
+DATE
+03/21/02
+03/18/02
+03/21/02 03/18/02 SOLD
+
+03/18/02
+TALBOTS INC
+1. 00 1-001. 150 10 230.0
+SEC FEE
+3081.00
+"TOMMY HILFIGER CORP-ORD
+ECUTION BY BUC
+$ 1400 02-13-02, 6700 01-30
+2, 600 02-15-02, 1800 02-20-02
+, 3700 02-19-02
+SEC MISSION
+WET SEAL INC-CL
+2.55.00
+EXECUTION BY MONT
+03/27/02
+03/27/02
+03/27702
+03/18/02
+03/18/02
+03/18/02
+BOUGH
+BELIA'S CORP
+CL A
+COVER SHORT,
+EXECUTION BY FLTI
+VS -200 12-17-01, - 1600 01-04
+OSHKOSHB GOSHING CLA"
+COVER SHORT
+EXECUTION BY FLT
+VS-800 11-26-01
+SAK INC
+COVER SHORT,
+VS - 1304 04-19-0
+COMMISSION
+78.24
+SYMBOLGUSP
+TLB
+TOM
+WISLA
+"BLIA
+GOSHA
+SKS
+027
+QUANTITY
+-6,350
+35.27570
+-14,200
+10,700
+14.79660
+33.97500
+1,800
+*800
+304
+6.10000
+39.15000
+14.10000
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+223,601.33
+209,241.56
+363,512.04
+10,995.00
+31,335.00
+18,479.64
+
+
+38 of 57
+SETTLEMENT TRADE
+DATE
+03/21/02
+03/18/02
+63/22/02 03/19/02 *SOLD"
+03/22/02
+**03/19/02 BÖUGHT
+SHOPKO STORES INC
+COVER SHORT,
+IS -700 12-05-01
+NOISSINOO
+42,00
+AMERICAN EAGLE "OUTFITTERS INC"
+NEW
+5020 0 2 0 213010
+"SHOPKO STORES INC
+03/25/02
+03/20102
+03/25/02
+03/20/02
+*SOLD
+03/25/02
+03/20/02 SOLD
+COMMISSION
+48.00
+"AMERICAN EAGLE OUTFITERS INC
+NEW
+EXECUTION BY JPHO
+SEC FEE 12-18-01. 1002-17-01
+"ALLOY INC
+FRM ALLOY ONLINE INC
+EXECUTION BY NITE
+VS 2300 04-17-01
+SEC FEE
+'ANNTAYLOR STORES CORP
+SEE NOTE "S' ON BACK
+TS 6800 03-0602, 800 03-05.02
+COMMISSION
+532,00
+SYMBOL/GUSP
+SKO
+"AEOS
+*SKO
+"AEOS
+ALOY
+ANN
+027
+QUANTITY
+700
+2,300
+800
+2,600
+2,300
+-7,600
+17.61260
+1'28:53330
+17.80000
+'28.63930"
+13.55000
+'43.48110
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+12,385.82
+''85.570.60
+14,303.00
+*74,446.06
+*31149.53
+"329,904.40
+
+
+39 or 57
+SETTLEMENT TRADE
+DATE
+03/25/02
+03/20/02
+Bear, Steams & Co. Inc.
+03/25/02 03/20/02 SOLD
+03/25/02
+03/20/02
+*SOLD
+03/25/02 *03/20/02*SOLD
+03/25/02
+*03/20/02
+*SOLD
+03/25/02
+03/20/02
+BROWN SHOE COMPANY
+EXECUTION BY MOKE
+- 2500 1127-01: 80008-32-001
+00008-24-01, 800 08-27-01
+OMMISSION
+749,00
+JOSEPHA BANK CLOTHIERS INC
+TS 2300 04-1201, 1200 10-03-0
+3500 10-04-
+MISSIO
+SEC FEE
+1,50.00
+*BED BATH & BEYOND INC
+EXECUTION BY NITE
+VS 1500 03-06-02
+SEC FE
+.74
+BEST BUY COMPANY INC
+EXECUTION BY GSCO
+COMMISSION
+329,00
+SEC FEE
+5.60
+CHILDRENS PLACE RETAIL STORES
+EXECUTION BY JPHO
+VS 800 03-11-02, 400 01-07-02,
+000 01-09-02, 2000 01-03-0
+400 01-14-02, 2200 01-02-0
+5800 12-31-01, 1900 12-12-01
+COLUMBIA SPORTSWEAR CO
+EXECUTION BY FLTT
+VS 300 01-02-02, 400 12-21-01,
+600 12-19-01, 1300 12-18-01,
+SEC F12-17-01, 1400 12-20-01
+SYMBOLCUSIP
+BWS
+JOSB
+*BBBY
+*PLCE
+*COLM
+027
+QUANTITY
+-10,700
+19.50590
+-7,000
+-1,500
+4,700
+13.37980
+2.5605
+77:35000
+27,000
+34.76230
+5,200
+33.34930
+IOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+207,945.99
+93,292.19
+48,825.01
+ґ969'ZL
+938,553.02
+173,398.75
+
+
+40 or 57
+SETTLEMENT TRADE
+DATE
+03/25/02
+03/20/02
+Bear, Steams & Co. Inc.
+03/25/02 03/20/02 SOLD
+03/25/02
+03/20/02
+03/25/02 *03/20/02*SOLD
+03/25/02
+03/20/02
+03725(02
+03/20/02
+03/25/02 03/20/02
+COACH INC
+EXECUTION BY GSCO
+VS 800 03-13-02, 1900 03-11-02
+700 03-06-02, 400 10-12-01.
+100 1002-01 80 01002-01. 3
+0 09-26-0
+CANDIES ING*"
+IS 328902-Y502, 911 12-01-00
+COMMISSION
+86,00
+SEC FEE
+15
+CATO COAP CLA
+(01300B076 2700 1280
+SEC FEE
+"KENNETH COLE PRODUCTIONS INC
+CLA
+EXECUTION BY MOKE
+VS 2600 11-09-01, 1200 02-08-0
+2, 500 02-11-02
+SEC MISSION
+1339.00
+"DIRECT FOCUS INC
+EXECUTION BY NITE
+VS 2600 12-10-01, 1200 02-11-0
+2
+SEC FEE
+2.01
+DEB SHOPSING***
+EXECUTION BY SLKC
+VS 2200 03-07-01
+SEC FEE
+291
+DOLLAR TREE STORES INC
+EXECUTION BY INET
+VS 800 01-31-02, 1700 01-30-02
+OMMISSION
+EC FE
+1,75.00
+SYMBOLICUSIF
+COH
+*CAND
+"CACOA
+DEXI
+"DEBS
+"BLTR
+027
+QUANTITY
+-11,850
+52.33410
+4,300
+4,600
+4,300
+= 2.17330
+22.92000
+•**20:53150
+3,800
+2,200
+2,500
+35.18400
+27.52000
+34.13090
+IOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+619,305.29
+9,244.04
+105,415.41
+®87,968.12
+133,682.19
+60,528.09
+85,235.97
+
+
+41 of 57
+SETTLEMENT TRADE
+DATE
+03/25/02
+03/20/02
+DOLLAR GENERAL CORP
+EXECUTION BY GSCO
+03/25/02 03/20/02 SOLD"
+03/25/02
+*03/20/02
+03/25/02 03/20/02
+03/25/02
+*03/20/02
+03/25/02
+03/20/02
+"FOOTSTAR ING™*
+5 1209102, 00 01-150
+COMMISSION
+SEC FEE
+2302,00
+FOOT LOCKER INC
+VS 400 01-23-02, 7200 09-19-01
+, 500 09-18-01, 1000 01-29-02,
+SEC FEE
+FAMILY DOLLAR STORES INC
+EXECUTION BY GSCO
+VS 4100 01-28-02, 800 02-07-02
+COMMISSION
+343,00
+SEC FEE
+2.48
+"FEDERATED DEPARTMENT STORES
+EXECUTION BY FCAP
+VS 500 03-06-02, 300 12-05-01,
+1700 12-18-01, 2700 12-04-01,
+900 12-11-01, 2800 10-19-01
+COMMISSION
+GUITAR CENTER INC
+623,00
+EXECUTION BY FLTT
+s 1900 11-14-01, 4000 12-31
+1900 01-02-02, 500 12-03-
+SEC FE 11-20-01
+2.49
+SYMBOLGUSP
+DG
+"FTS
+FDO
+FD
+GIRO
+027
+QUANTITY
+-5,500
+5,600
+19,200
+4,900
+8,900
+17.05950
+''30.85000
+16.94330
+33.73000
+42.70000
+10,050
+16.48880
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+93,425.84
+'172,350.40
+324,139.48
+164,916.52
+379,386.29
+165,694.95
+
+
+42 of 57
+SETTLEMENT TRADE
+DATE
+03/25/02
+03/20/02
+03/25/02 03/20/02 SOLD
+03/25/02 03/20/02
+• SOLD
+Bear, Steams & Co. Inc.
+03725/02
+03/20/02
+03/25/02 03/20/02*
+03/25/02
+03/20/02
+03725/02 *83/20/02*SOLB
+GART SPORTS CO
+EXECUTION BY FLTT
+SEC FEE 01-16-02, 89801-3002
+GALYANS TRADING INC
+EXECUTION BY NITE
+VS 2600 01-23-02
+SEC FEE
+.58
+HOT TOPIC INC**
+EXECUTION BY RSSF
+VS 6750 02-06-02, 3700 03-06-0
+2, 500 03-07-02, 2850 11-12-01
+, 4650 11-26-01, 6600 02-06-02
+400 10-19-01, 1050 11-05-0
+200 11-06-0
+HOME DEPOTING
+EXECUTION BY FCAP
+VS 1600 01-24-02, 800 01-25-02
+COMMISSION
+168,00
+SEC FEE
+1,78
+'R'SWISS ING CLA
+EXECUTION BY FLIT
+"KOHLS CORP"
+IS 4001-06-01, 100 11-050
+SE PESON
+357.00
+5.39
+"LIZ"CLAIBSANE INE"
+1200 10-05-01; 1900 10-11-01
+1900 10-11-01
+SYMBOLCUSIP
+GRTS
+GLYN
+"HOT
+HD
+KSS
+027
+QUANTITY
+-3,400
+2,600
+29,700
+31.18000
+• 14.62700
+
+2,400
+4,100"*
+5,100
+49.30000
+-41.07020
+70.35000
+*21,300
+*''29.78250
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+105,995.40
+38,014.62
+670,737.56
+*118,135.22
+168,370.29
+358,407-61
+633,084.73
+
+
+43 of 57
+SETTLEMENT TRADE
+DATE
+03/25/02
+03/20/02
+03/25/02 03/20/02 SOLD"
+03/25/02
+03/20/02
+03/25/02
+03/20/02 SOLD*
+037250203/20/02'SOLD
+LOWES COMPANIES INC
+EXECUTION BY FCAP
+S 1200 02-26-02, 800 03-08-02
+0-40-60 002
+SEC FISSION
+1154,00
+'STEVEN MADDEN LTD
+EXECUTION BY JEFF
+1, 2100 02-07-02: 2100 06-19-0
+1, 3500 02-08-02, 4600 02-11-0
+2, 3700 01-30-02, 2400 01-29-
+2, 700 03-07-02
+MAXWELL SHOE CO INC-CLA
+EXECUTION BY FLIT
+VS 1700 12-05-01, 2000 12-24-0
+1: 800 11-14001. 2500 03-06-0
+SEC FEE
+2,28
+POLO RALPH LAUREN CORP CLA
+SEE NOTE 'S ON BACK
+S 1200 09-27-01, 400 09-20-1
+900 11-06-01, 1600 04-16-4
+1500 07-27-01, 2400 08-08-0
+2600 07-11-01, 1600 07-20-0
+"PACIFIC SUNWEAR OF CALIFORNIA"
+BE 310 027.52. 700 030-02
+, 2000 03-05-02, 3400 02-07-02
+, 1600 02-14-02, 2100 02-13-02
+1600 12-20-01
+SYMBOLGUSIP
+LOW
+SH00
+"MAXS
+'*PSUN
+QUANTITY
+-2,200
+43.80000
+24,900
+16.91280
+9,500
+-18,100
+15.95000
+29.46260
+:14,500
+• 26.03470
+LEARED THROUGH IT
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+96,189.55
+421,107.40
+51.507.7
+532,164.06
+**377,482.48
+
+
+44 of 57
+SETTLEMENT TRADE
+DATE
+03/25/02
+03/20/02
+03/25/02 03/20/02 SOLD"
+03/25/02
+:''03/20/02"SOLD"
+03/25/02
+/ 03/20/02
+03/25/02"
+03/20/02
+03/25/02 03/20102 SOLD
+03/25/02 03/20/02 SOLD
+PAXAR CORP
+EXECUTION BY MOKE
+. 240001-21-02, 1200 01-21-02
+SEC MISSION
+308,00
+1.09
+QUIKSILVER INC
+RESTORATION HARDWARE ING DEL
+EXECUTION BY JEFF
+VS 97112-14-01, 12500 12-06-0
+SEC FEE
+2,40
+*SKECHERS USA INC
+LECUTION BY BUC
+S 3100 11-14-01, 5000 12-20-
+852,00
+'STAGE STORES INC
+NEW
+EXECUTION BY SLKC
+VS 3300 11-20-01, 1000 12-04-0
+SEC FEE
+1,62
+"SHOE CARNIVAL ING-IND
+EXECUTION BY FLTI
+VS 5300 12-08-00, 7600 11-30-0
+SEC FE 1 - 1-00
+2.93
+"SYMBOL TECHNOLOGIES INC"
+EXECUTION BY MOKE
+VS 1100 10-03-01, 2800 02-15-0
+2, 2300 03-06-02
+COMMISSION
+434,00
+SEC FEE
+1.06
+SYMBOLCUSIP
+PXA
+'ZOK
+"RSTO
+SKX
+027
+QUANTITY
+-4,400
+16.40320
+31,300
+13,471
+14,200
+4,300
+24.21900
+
+16.62670
+25.09000
+-13,100
+6,200
+1490000"
+- 1.32830
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+71,849.99
+756,150.32
+159,631.46
+35,228.54
+107,870.38
+195,172.07
+69,785.40
+
+
+45 of 57
+SETTLEMENT TRADE
+DATE
+03/25/02
+03/20/02
+Bear, Steams & Co. Inc.
+03/25/02 03/20/02 SOLD
+03/25/02
+03/20/02
+03/25/02
+*03/20/02
+03/25/02
+'03/20/02*SÖLD
+"TANGER FACTORY OUTLET CENTERS
+VS 1900 01-17-02, 2100 01-15-0
+2
+DISSIMINO
+15 Va
+
+TIMBERLAND CO-CLA
+1. 50 1-31.01. 400 010222
+SEC FISSION
+7.07.00
+OMMY HILFIGER CORPOR
+ECUTION BY BUO
+VS 3500 10-02-01, 1100 10-01-6
+1, 900 09-27-01, 5600 10-03-0
+1400 09-28-01, 1700 09-18-0
+SEC FESSION
+3072.00
+*WET SEALING-CLA
+EXECUTION BY MON
+VS 1700 08-02-01, 2600 08-03-
+1 l
+SEC FEE
+2,18
+SYMBOLCUSP
+TGT
+*SKT
+TBL
+"TOM
+WISLA
+027
+QUANTITY
+-6,700
+44.35000
+4,000*
+11,950
+26.70560
+39.39970
+14,200
+14.38180"
+4,300
+• 33.67330
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+296,656.54
+106,565.79
+470,087.36
+203,351.49
+144,778.01
+
+
+46 of 57
+SETTLEMENT TRADE
+DATE
+03/25/02
+03/20/02
+03/25/02 03/22/02 BOUGHT
+20152/60
+03/20/02
+*BOUGHT
+03/25/02 03/20/02 BOUGHT
+03/25/02
+03/20/02
+"BOUGHI
+20197(60
+ZALE CORP NEW
+EXECUTION BY DBAB
+. 1700 122201, 1700 12-1201
+3177.00
+CALL AMEAN EAGLE APR 025
+EXP 01/20/2002
+CLOSING CONTRACT
+DIAMONDS TRUST-UNT SERIES 1
+COVER SHORT,
+VS -450 12-19-01, -50 12-31-01
+30.00
+"SIX FLAGS ING**
+COVER SHORT,
+EXECUTION BY DAE
+CS-MISSI0R-23-0
+133,00
+"STANDARD & POORS DEPOSITORY
+DOVER SHOR
+COMMISSION
+18,00
+"BAOWN SHOE COMPANY***
+ES 8100B 02, 1300 1231-0
+1, 3600 08-24-01
+COMMISSION
+480,00
+SEC FEE
+2.34
+SYMBOLGUSIP
+"CAOUDE
+*PKS
+SPY
+"EWS"
+027
+QUANTITY
+-6,100
+40.52390
+49
+500
+1,900
+300
+= 2.71430
+105.18000
+• 1682340
+115.55000
+8,000
+19:44990"
+IOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+246,750.08
+13,479.22
+52,635.00
+32,112.46
+34,698.00
+i55,101.86
+
+
+47 of 57
+SETTLEMENT TRADE
+DATE
+03/21/02
+Bear, Steams & Co. Inc.
+03/26/02 03/21/02 SOLD
+03/21702
+03/26/02*
+03/21/02
+03/26/02"
+*03/21/02
+83726702"
+COSTCO WHOLESALE CORP-NEW
+EXECUTION BY MONT
+- 1700 10-13-01. 601201004
+00 12-11-01, 800 03-05-0
+0-90-80 00
+SEC FEE
+5,48
+CANDIES INC
+ECUTION BY RE
+2100 12-31-01, 3600 09-21
+0030003-2801
+SEC FEE
+120,00
+KENNETH COLE PRODUCTIONS INC
+3700 02-1-022, 600 02-28-02,
+SEC FISSION
+292.00
+CIRCUIT CITY STORES INC
+CIRCUIT CITY GROUP
+ISOLICIT
+P 2/22/
+CIRCUIT CITY STORES ING
+CIRCUIT CITY GROUP
+VSP 225022
+"BEE'SHOPSING""
+SYMBOLCUSIP
+COST
+CAND
+*CC
+"BEBS
+027
+QUANTITY
+-8,900
+40.98210
+6,000
+4,900
+= 2.17000
+0.6342
+2,300
+2,600
+3,600
+18.66000
+18.66000
+27.14200
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+364,720.21
+12,884.80
+100,797.06
+42,756.35
+48,333.27
+37,694.73
+
+
+48 of 57
+SETTLEMENT TRADE
+DATE
+03/21/02
+Bear, Stearns & Co. Inc.
+03/26/02 03/21/02 SOLD
+
+:'''03/21702•*SöLö
+03/21/02
+"SÖLD"
+103/2102
+:*03/21702
+.20/92/60
+03/21/02
+"SOLB"
+"SÖLD
+LIZ CLAIBORNE INC
+EXECUTION BY OPCO
+: 20 10-18-01: 1200 0-1201
+497.00
+SEC FEI
+3,10
+LOWES COMPANIES INC
+UNSOLICITED
+'STEVEN MADDEN LTD
+EXECUTION BY NITE
+VS 2100 01-24-02, 2000 01-28-0
+3 0 0 002 50 01160
+2.19
+POLO RALPH LAUREN CORP-CL'A
+SEE NOTE 'S"
+VS 650 04-18-01, 2700 07-17-01
+- 0203201. 170042001
+497,00
+UNSOLICITED
+/SP 2/13/02
+"OFFICE DEPOT INC
+VITH RIGHTS TO PURCHASE PREFRI
+TK UNDER CERTAIN CIRCUMSTANO
+VSF 227/02
+OFFICE DEPOT INC
+WITH RIGHTS TO PURCHASE PREFRI
+STK UNDER CERTAIN CIRCUMSTANCI
+UNSOLICITED
+VSP 2/13/02
+SYMBOLCUSIP
+TIZ
+LOW
+"SH0O
+RL
+*ODP
+ODP
+ODP
+027
+QUANTITY
+-7,100
+29.04730
+- 1,900
+-8,700
+44.83000"
+16.75230
+-7,100
+29.14300
+-1,200
+-1,500%
+1,900
+19.72000
+19.72000
+19.72000
+CHEARE THRO SUEOARY
+One Metratech Center North
+Brocktyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+205,720.73
+85,042.72
+145,727.82
+206,400.19
+23,579.64
+29,474.55
+37,334.43
+
+
+49 01 57
+SETTLEMENT TRADE
+DATE
+03/21/02
+03/26/02 03/21/02 SOLD
+03/21/02
+03/21/02
+
+SKECHERS USA INC
+08001 0 52 00 02202
+30020202002.
+STACE STORES INC
+00 01 00 2020
+SEC FESSION
+1.25,00
+SHOE CARNI
+IVAL
+ING-IND
+EXECUTION BY REDI
+yS 3000 11-28.00, 270011-160
+SEE FESSION
+1.29.00
+TROPICAL SPORTWEAR
+INTERNATIONAL CORP
+EXECUTION BY REDI
+VS 1500 02-11-02, 3200 01-30-0
+1,61.00
+TOMMY HILFIGER CORP ORD
+COMMISSION
+SEC FEE
+SYMBOLGUSIP
+SKX
+SIGS
+SOVL
+TSIC
+"TOM
+027
+QUANTITY
+-22,200
+15.99900
+3,500
+5,700
+4,700
+''2554500
+
+23.56060
+8,650
+'14.36200"
+IOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+353,603.47
+89,286.15
+85,232.34
+110,624.15
+123,608.93
+
+
+50 or 57
+SETTLEMENT TRADE
+DATE
+03/21/02
+0326/02 03/21702 BOUGHT
+
+'' 03/21702*BOUGHT
+20/92/60
+03/21/02
+03/21/02
+03/21/02
+03721/02
+03/26/02 03/21702 BOUGHT
+Bear, Stearns & Co. Inc.
+WET SEAL INC-CLA
+EXECUTION BY MONT
+S 5750 07-13-01, 1200 07-26-
+* 30001. 4950 07-12.
+"AMDOCS LIMITED"
+UNSOLICITED
+COVER SHORT,
+"ALBERTSONS INC****
+ITH RIGHTS TO PURCHASE COMMO
+TK UNDER CERTAIN CIRCUMSTANO
+UNSOLICITED
+SEE NOTE 'S' ON BACK
+COVER SHORT
+BUS WHOLESALE CLUB INC
+UNSOLICITED
+COVER SHORT,
+BEBE STORES INC
+COVER SHORT,
+5S-1500 03-01-02
+KROGER C.....
+ITH RIGHTS TO PURCHASE COMM
+K UNDER CERTAIN CIRCUMSTAN
+UNSOLICITED
+COVER SHORT,
+"LVMH MOET HENNESSYLOUIS
+VUITTON-SPONSORED ADR
+COVER SHORT,
+EXECUTION BY SLKC
+S -800 11-14-01, -700 12-19
+. -5000 04-17-0
+"NORDSTROM INC
+ISOLICIT
+VER SHO
+SYMBOLGUSIP
+WTSLA
+DOX
+BJ
+*WN
+027
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+462,444.96
+QUANTITY
+-13,900
+500
+33.27100
+•'25.70000
+12,885.00
+95032.22000........
+30,675.50
+000'S.
+1,000
+6,500
+44.80000
+23.39000
+22.48000
+10.44310
+800"
+"25.15000"
+224,350.00
+35,100.00
+22,550.00
+67,895.15
+*20,176.00
+
+
+51 or 57
+SETTLEMENT TRADE
+DATE
+03/21/02
+03/26/02 03/21/02 BOÜGHT
+'' 03/21702*BOUGHT
+03/27102
+*03/22/02
+03/27102
+03/22/02
+*SOLD
+20/22/60
+03/22/02
+'SOLD"
+VS- 900 01-25002
+RADIOSHACK CORP
+G PRICE SHOWN-DETAILS ON R
+TUAL CONFIRM TO YOUR AGE
+WITH RIGHTS TO PURCHASE COMMON
+STK UNDER CERTAIN CIRCUMSTANCE
+COVER SHORT,
+EXECUTION BY NITE
+VS-700 12-12-01, -1600 12-11-
+"AMERICAN EAGLE OUTFITTERS INC
+NEW
+ECUTION BY JP
+SEC REE 12-17-01
+2,00
+DEB SHOPSING**
+EXECUTION BY FLIT
+800 10-2-01. 00 01- 0-21,01
+00 03-07-0
+SEC FE
+1,64
+"LIZ CLAIBORNE INC
+VS 1800 12-19-01, 2400 12-20-0
+1100 09-17-
+IMMISSI
+318.00
+SEC FEE
+2,26
+SYMBOLICUSIP
+PLCM
+ASH
+SCOR
+"AEOS
+DEBS
+027
+QUANTITY
+900
+*3,800
+24.01000
+29.81840
+2,300
+* 26.27170
+4,900
+4,100
+• 27.12500
+26.63000
+5,300
+28.32880
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+21,624.00
+- 11357592
+60,439.91*
+132,895.50
+109,166.36
+149,807.38
+
+
+52 of 57
+SETTLEMENT TRADE
+DATE
+03/27/02
+03/22/02
+03/27/02 03/22/02"BOUGHT
+03/27/02
+03/22/02
+20/LZ/60
+03/22/02
+03/27/02 03/22/02 BOUGHT
+ö3/27/02
+20/Z2/ED.
+03/27/02 03/22/02"BOUGHT
+POLO RALPH LAUREN CORP-CLA
+SEE NOTE 'S' ON BACK
+XECUTION BY BUC
+S 650 02-05-02, 900 06-15-0
+20 0 01 20 0 202:
+"EMERSON ELECTRIC CO'
+"P MORGAN CHASE & CO
+AVG PRICE SHOWN-DETAILS ON REC
+ACTUAL CONFIRM TO YOUR AGENT
+UNSOLICITED
+COVER SHORT
+"MEMBERWORKS ING
+COVER SHORT
+EXECUTION BY RED
+0O S30 20-01
+16.00
+"SHOPKO STORES ING
+UNSOLICITED
+COVER SHORT,
+VSP 1/23/02
+AS OF 03/22/02
+VANS INC
+EXECUTION REDI
+YS MISS 2-01-02
+30.00
+WHOLE FOODS MARKET INC
+COVER SHORT,
+EXECUTION BY NITE
+VS-450 10-31-01
+SYMBOLCUSP
+"EMA
+PM
+MBRS
+SKO
+SNEA
+027
+QUANTITY
+-6,800
+28.50420
+1,000
+*850
+800
+*450
+62.64000
+*34.71710
+18.84500
+= 17:3700
+12.20880
+47.23671
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+193,402.65
+"62,710.00
+29,569.04
+15,107.00
+' 26,160.00
+18,358.20
+
+
+
+53 or 57
+DATE
+03/28/02 03/25/02 BOUGHT
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+02/23/02
+OPENINGBALANCE
+62/2502**S018
+02/27/02
+63/64/02* SOLD
+03/07/02
+63/08/02
+03/11702
+'''BOUGHI
+03/14/02
+BOUGHI
+03/21/02
+''DIVIDEND
+03/21/02*DIVIDEND
+New York. New York 10179
+SEARS ROEBUCK & CO
+DOVER SHORT
+BE SUTTON - B-02, 6350 01-10
+COMMISSION
+609,00
+MONTHLY DIVIDEND
+"DOMEST PRIME AM PORTFOLIO
+MONTHLY DIVIDEND
+SYMBOLCUSP
+QUANTITY
+10,150
+51.05390
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+DEBIT AMOUNT
+518,821.09
+$-6,810,279.21
+SYMBOU/CUSIP
+"ТЬXX
+"GTDXX"
+QUANTITY
+1,818,537.38
+200,000
+300,000
+[ö0,ö00
+00,000
+300,000
+400,000
+150,000
+0000
+0000*
+(0000
+0000
+0000
+0000
+0000
+DEBIT AMOUNT
+400,000.00
+150,000.00
+$23,032,124.55
+200,000:00
+300,000.00
+(60,000.00
+100,000.00
+300,000.00
+*707.37
+685.25
+027
+
+
+54 of 57
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+03/21:02
+REINVEST
+DOMES SHES PRANSL
+MONTHLY DIVIDEND REINVESTED
+03/21/02 REINVEST
+MONTHLY DIVIDEND REINVESTED
+CLOSINGBALANCE
+03/28/02
+DATE
+02/28/02
+03701/02
+TUX COMPANIES INC NEW
+REC 02/07/02 PAY 02/28/02
+"OSHKOSHE GOSHING CLA
+DIV CHG
+800 SHS SHORT
+REC 02/14/02 PAY 03/01/02
+03/01/02
+DIV CHG
+1700 SHS SHORT
+REC 02/15/02 PAY 03/01/02
+03/17/02
+'LL CLABORNE INC....
+REC 02/19002 PAY 03/1102
+03/11/02
+'TARGET CORP***
+REC 02/20/02 PAY 03/10/02
+03/11302' DIAMONDS TAUSTUNT SERIES'1"
+DIV CHG
+11600 SHS SHORT
+REC 02/20/02 PAY 03/11/02
+03711702 ELECTRONIC" BATA SYSTEMS CORP
+NEW
+DIV CHG
+900 SHS SHORT
+REC 02/20/02 PAY 03/11/02
+SYMBOUCUSIP
+GIDXX
+SMACCUSP
+"GOSHA
+"LIZ
+'''BA
+QUANTITY
+2,800
+'41,400
+QUANTITY
+707.37
+685.25
+1,369,930
+RATE (5)
+0.0450
+
+0.0600
+027
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+707.37
+685.25
+$-551,392.62
+$1,001,392.62
+CREDIT AMCUNT
+126.00
+DEBIT AMOUNT
+4800*
+272.00
+156428*
+135.00
+"2,328.73
+96.00
+
+
+55 of 57
+DIVIDENDS (continued)
+0311/02
+EMERSON ELECTRIC CO
+DIV CHG
+REC 021502 PAN 031102
+63/11702 "NEWELL AUBBERMAID" INC"
+REC 02/28/02 PAY 03/15/02
+03/25/02
+'"CATO CORP CLA'
+REC 03/11/02 PAY 03/25/02
+03/25/02
+'TALBOTS INC.....*
+REC 03/11/02 PAY 03/25/02
+... . . .
+03/28/02
+HOME DEPOT INC
+REC 03/14/02 PAY 03/28/02
+INTEREST
+DATE
+03/21/02
+INT CR
+MAR 02
+MISCELLANEOUS
+DATE
+MO/DAY
+02/25/02
+022502 OURNAL
+ear, Steams & Co. Inc
+83 Madison Avenu
+SYMBOUGUSIP
+EMR
+'NWL
+•WN
+"CACOA"
+TLB
+QUANTITY
+RATE (S)
+2,700"
+12,850
+2,400
+0.1350
+0.0800
+0.0500
+SYMBOUCUSIP
+QUANTITY
+RATE (%)
+MARK TO MARKET
+MARK TO MARKET SHORT POS
+DEBIT AMOUNT
+10,505.00
+.. . . .
+027
+DEBIT AMOUNT
+658.75
+168.00'
+"72.00"
+$-2,918.01
+DEBIT AMOUNT
+10,505.00
+03/29/02;22:30 001
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+364.50
+1,028.00
+120.00
+$4,063.25
+1,310.83
+$1,310.83
+
+
+56 of 57
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+03/04/02
+03/04/02
+03/11/02
+63/17702
+63/17/02
+03/11/02
+03/18/02
+03/18/02
+63/2102
+03/21/02
+03/25/02
+03/25/02
+OURNAL
+jOUANAL'
+JOUANAL
+JOUANAL'
+"JOUANAL"
+JOUANAL"
+JOURNAL"
+Vew York, New York 10179
+MARK TO MARKET
+"MARK TO MARKET SHORT POS
+T2-USD
+* JAL *
+"MARK TO MARKET
+"FROM: SUV
+• JRL * i
+"MARK TO MARKET SHORT POS"
+MARK TO MARKET
+'"'MARK TO MARKET SHORT POS"
+"SWVER"
+MAR 02
+'SMVCR
+MAR 02
+"MARK TO MARKET
+MARK TO MARKET SHORT POS
+Trades Executed Pending Settlement
+SELEMENT TRE
+04/01/02
+04/01/02
+
+..........
+13/27/0
+UGH
+ELECTRONIC DATA SYSTEMS CORP
+NEW
+YANKEE CANDLE INC
+AMERICAN GREETINGS CORP. CLA
+DEBIT AMOUNT
+149,313.00
+300,000.00
+133,224:00
+27,107.00
+1,133.96
+44,604.00
+$-665,886.96
+SIMBOLICUSIP
+EDS
+YCC
+"AM
+027
+CRECIT AMOUNT
+149,313.00
+300,000.00
+133,224:00
+27,107.00
+5,223.92
+44,604.00
+$669,976.92
+QUANTITY
+900.00
+850.00
+800.00
+58.9000
+22.9032
+16.930(
+03/29/02;22:30 001
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+53,079.00
+19,533.72
+13,615.00
+
+
+57 of 57
+Bear, Steams & Co. Inc.
+Trades Executed Pending Settlement
+(continued)
+SEE MENT TREE
+04/03/02
+03/28/02
+04/03/02
+03/28/02
+04/03/02
+03/28/02
+04/03/02 03/28/02 BOUGHT
+DESCRPTION
+CONSTELLATION BRANDS ING
+CLA
+GENUINE PARTS CO
+WITH RIGHTS TO PURCHASE PREFRD
+SHOPKO STORES INC
+TUESDAY MORNING CORP-NEW
+The above trades do not appear in any other section of this statement.
+STOP
+****** End of Statement******
+SYMBOLCUSP
+SIZ
+GPC
+SKO
+"TUES
+QUANTITY
+800.00
+600.00
+2,100.00
+1,400.00
+54.2960
+36.9000
+18.0377
+20.5000
+027
+03/29/02;22:30 001
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+DEBIT AMOUNT
+43,507.80
+22,197.00
+38.041.17
+28.715.00
+$218,688.69
+$0.00
+
+
+lear, Steams & Co. Inc
+83 Madison Avenu
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+What's In This Statement
+Financial Summary ••••••••••••••••••//•III I''
+Your Portfolio Holdings
+Transaction Detail ..............................
+Fund Activity.......
+Trades Not Yet Settled
+3
+4
+10
+42
+45
+INTERNATIONAL CHARITABLE
+INTERESTS | 2/28/94
+C/O FINANCIAL TRUST COMAPNY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+14,638.696
+5,847,610
+1,818,538
+$22,304,844
+••••••••••
+22,091,445
+213,399
+here are no "Stop Loss" orders or other pending bu
+r sell open orders on file for your accoun
+Market Value of Your Portfolio
+$7,666,148
+$7,068,313
+Cash & Equivalent -
+Equities
+$19,301,360
+: S-4.662,664
+$19,206,063
+:$-4,182,931
+Current market value
+Last statement's market value
+Short market value
+SIP The suremen s four or ratanal furyce rear die Set revere date for portant formation.
+
+
+2 of 47
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or 43
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Miscellaneous
+THIS PERICO
+55.251.642.67
+6,521,682.29
+1,001,866.80
+4,785.62
+305,569.90
+Amount Credited
+57,833,904.61
+Securities Bought
+-5,929,608.51
+Money Fund
+-1,001,866.80
+Dividends/Interest Charged
+-4,976.47
+Miscellaneous
+-301,485.43
+Amount Debited
+-7.237,937.2
+Net Cash Activity
+595,967.40
+Closing Balance.
+_ 35.847,.610.07
+Same day transfers of cash between account types are not included in thi
+section; such transfers, as well as dotalls for all other transactions this period
+appear in Transaction Detal.
+Cash Balance Summary
+Margin
+Short
+Net Cash Balance
+OPENING
+1,119,750.47
+4,131,892.20
+$5,251,642.67
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+Short Dividends
+THIS PERIOD
+5,373.30
+1,279.12
+56.652.42
+4,976.47
+Portfolio Composition
+SHORT
+Cash/Cash Equivalent
+Equities
+Total
+4,662,664
+$4,662,664
+027
+CLOSING
+1,195,451.88
+4,652,158.19
+....
+$5,847,610.07
+YEAR TO DATE
+8,980.10
+2,808.95
+S11.78905
+-8,974.13
+LONG
+7,666,148
+19,301,360
+626-967,508
+LEARED THROUGH IT
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+25%
+Short Equities.
+14%
+Equities
+61%
+Unshaded portions denote debit balance and'or short
+from the absolute marker value of your portiolo.
+
+
+OFFICE SERVIING YOUR ACCOUNT
+4 of 47
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+THE TREASURERS FUND INC
+DOMESTC PRIME MAM PORTFOLIO.
+THE TREASURERS FUND ING
+DOMESTIC PRIME MIM PORTFOLIO
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AMDOCS LIMITED
+AMERICAN EAGLE OUTFITTERS ING
+NEW
+ALLOY INC
+(FRM ALLOY ONLINE INC)
+ACTION PERFORMANCE COMPANIES
+INC
+ALBERTSONS INC
+gananaıııaanaaaananaaaanaani
+AMERICAN GREETINGS CORP-CL A
+... .
+APOLLO GROUP INC-CL A
+... . .
+BUS WHOLESALE CLUB INC
+------••
+BROWN SHOE COMPANY
+JOSEPH A BANK LOTHIERS INC
+... . . . .
+BEST BUY COMPANY INC
+................. • I BBE•:
+SYMBOLCUSIP
+GTDXX
+GTDXX
+QUANTITY
+822,501.71
+996,035.67
+1.0000
+1.0000
+SYMBOUCUSIP
+DOX
+AEOS
+ALOY
+ATN
+ABS
+•......
+AM
+APOL
+....
+BJ
+BWS
+JOSE
+.....
+BBY
+SHRT
+MRGN
+MRGN
+SHAT
+SHAT
+.. . .
+SHRT
+SHAT
+MRGN"
+MRGN"
+MAGN"
+QUANTITY
+-500
+38,900
+4,600
+-600
+-1,900
+....
+-2,100
+........
+-1,050
+....
+-3,800
+........
+15,600
+. . ..
+10,600
+3,200
+MARKET
+VALUE
+5,847,610
+822,502
+996,036
+$7,666,148
+28.8000
+24.9000
+15.2900
+37.5900
+27.6300
+.. . .
+13.8000
+.......
+47.3800
+41.1100
+15,4000
+8.2500
+67.6100
+LEARED THROUGH IT:
+HOLLY OWNED SUBSIDIAR'
+One Metratech Center North
+Brocktyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOO January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAPAYER NUMBER
+January 25, 2002
+ESTIMATED
+ANNUAL INCOME
+12,338
+14,941
+$27,279
+MARKET
+VALUE
+-14,400
+968,610
+70,334
+-22,554
+-52,497
+.....
+-28,980
+.. .
+-49,749
+-156,218
+240,240
+... .
+37,45
+16.3
+1.500
+1.5000
+ESTIMATED
+ANNUAL INCOME
+CURRENT
+YELD (N)
+LZ0
+1,444
+....
+-840
+6,240
+2.7506
+...... .
+2.8986
+2.5974
+
+
+5 or 43
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+CHILDRENS PLACE RETAIL STORES
+COSTCO WHOLESALE CORP. NEW
+SOLUMBIA SPORTSWEAR CO
+COACH N
+CONSTELLATION BRANDS INC
+CLA
+••..
+CANDIES INC
+CACHE INC NEW
+CATO CORP CLA
+.....
+CHARMING SHOPPES INC
+KENNETH COLE PRODUCTIONS INC
+CL A
+nanna
+CIRCUIT
+CITY STORES INC
+CIRCUIT CITY GROUP
+.. . .
+DILLARDS INC-CL /
+DIAMONDS TRUST-UNIT SERIES 1
+DAIMLERCHRYSLER A.G.
+COM
+.....
+DELIA*S CORP
+CLA
+........
+DIRECT FOCUS INC
+_____________...
+DEB SHOPS INC
+DOLLAR TREE STORES INC
+DOLLAR GENERAL CORP
+SYMBOL/CUSIP
+COST
+COLM
+COH
+STZ
+CAND
+CACH
+CACOA
+CHRS
+KCP
+CC
+DDS
+DIA
+DCX
+DLIA
+DFXI
+.........
+DEBS
+... .
+DLTR
+DG
+Bear, Steams & Co. Inc.
+MRGN
+MAGN
+MAGN
+MRGN
+SHR
+MRGN
+MAGN
+MRGN
+MRGN
+....
+MRGN
+MRGN
+SHAT
+SHRT
+SHRT
+SHAT
+MRGN
+............
+MRGN
+.....
+MRGN
+.. . .
+MRGN
+QUANTITY
+32,300
+6,400
+5,200
+......
+11,650
+1,700
+81,289
+20,100
+2,700
+8,900
+8,000
+3,100
+-1,700
+12,650
+B00
+-1,800
+3,800
+........
+9,900
+2,500
+... . .
+2,400
+32.3800
+45.2300
+30.5300
+44.7500
+50.93004
+2.3000
+5.2600
+20.0500
+6.5900
+19.0000
+16.5500
+18.7000
+99.9800
+37.8800
+7.4900
+28.7100
+...........
+23.8700
+29.2500
+14.0000
+MARKET
+VALUE
+1,045,874
+289,472
+158,756
+521,338
+86,581
+186,965
+105.726
+''54,135
+58,651
+152,000
+51,305
+-31,790
+1,264,747
+30,304
+-13,482
+109,098
+236,313
+......
+73,125
+.. ..
+33,600
+027
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+ANNA NONE
+CURRENT
+YELD IN
+....
+... . .
+1,458
+217
+-272
+20,493
+- 1,662
+2,970
+307
+2.6933
+0.4230
+0.8556
+1.6203
+........
+5.4844
+1.2568
+.913
+
+
+6 of 47
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+ELECTRONIC DATA SYSTEMS CORP
+NEW
+EASTMAN KODAK CO
+COLAB INI
+EDO CORP
+EMERSON ELECTRIC CO
+....
+FOOTSTAR INC
+FOUNDRY NETWORKS INC
+FOOT LOCKER INC
+FAMILY DOLLAR STORES INC
+... . .
+FEDERATED DEPARTMENT STORES
+INC-DEL
+FINLAY ENTERPRISES INC
+заааад ааааааааааааааааааааа
+FOSSIL INC
+FOREST LABORATORIES INC
+GADZOOKS INC
+GUITAR CENTER INC
+.....
+GART SPORTS CO
+G-III APPAREL GROUP LTD
+GALYANS TRADING INC
+GENESCO INC
+GENUINE PARTS CO
+GYMBOREE CORP
+......
+HOT TOPIC INC
+SYMBOLCUSIP
+EDS
+EK
+ECL
+EDO
+EMR
+.....
+FTS
+FDRY
+FDO
+FD
+FNLY
+FOSL
+FRX
+GADZ
+GTRC
+GRTS
+GIll
+GLYN
+Isig
+GYMB
+HOTT
+SHRT
+SHAT
+SHRT
+SHRT
+SHR1
+MRGN
+SHRT
+MRGN
+MRGN
+MRGN
+MRGN
+MAGN
+SHRT
+MRGN
+MRGN
+MRGN
+MRGN
+MRGN
+MRGN
+SHAT
+MRGN
+MRGN
+QUANTITY
+-900
+-2,100
+-400
+1,700
+,700
+4.900
+3,900
+61,900
+4,900
+9,500
+28,900
+.....
+13,500
+7,300
+13,650
+3,400
+48,450
+2,600
+4,000
+-2,700
+4,000
+37,600
+58.0000
+30.3600
+44.9000
+24.1200
+57.7200
+26.3300
+5.8900
+16.
+38.3600
+10.7500
+24.7000
+79.2800
+15.6100
+16.5400
+24.5000
+7.8800
+12.0600
+24.7100
+35.2900
+13.7500
+20.8900
+MARKET
+-52,200
+-63.756
+-17,960
+....
+-8.024
+129.017
+-22,971
+1.005,875
+161.
+,504
+364,420
+310.675
+333,450
+110,992
+113,953
+225,771
+83,300
+381,786
+31,356
+98,840
+-95,283
+55,000
+785,464
+027
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+ESTIMATED
+ANNUAL INCOME
+-540
+CURRENT
+YIELD IN
+1.0345
+3,7805.9289
+5.9289
+.... ..
+-216
+1.2027
+.....
+0.4975
+....
+2,635
+..........
+2.6854
+..........
+1,274
+0.7888
+-3,132
+3.2871
+
+
+7 of 47
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+HEARX LTD
+COM NEW
+MANY IN
+HEAD NIT
+NY REGISTRY
+HOME DEPOT INC
+HUMANA INC
+JP MORGAN CHASE & CO
+K-SWISS INC-CL A
+KELLWOOD CO
+KOHLS CORP
+KROGER CO
+ESTEE LAUDER COMPANIES INC
+CL A
+LINENS N THINGS INC
+LVMH MOET HENNESSY LOUIS
+VUITTON-SPONSORED ADR
+LEGGETT & PLATT INC
+LIZ CLAIBORNE INC
+MOVADO GROUP INC
+MEMBERWORKS INC
+STEVEN MADDEN LTD
+.............
+MAXWELL SHOE CO INC-CL A
+MASCO CORP
+MICHAELS STORES INC
+SYMBOUCUSIP
+EAR
+IMNY
+HED
+HD
+HUM
+IPM
+KSWS
+KWD
+KSS
+KR
+EL
+LIN
+LVMHY
+LEG
+LIZ
+MOV
+MBRS
+SHOO
+MAXS
+MAS
+MIK
+MRGN
+MAGN
+..•..
+IRGI
+MAGN
+SHRT
+SHRT
+MRGN
+SHRT
+MRGN
+SHRT
+MRGN
+SHRT
+SHRT
+SHRT
+MRGN
+SHRT
+SHRT
+MRGN
+MRGN
+SHRT
+QUANTITY
+23,700
+3,700
+12,500
+2,400
+.000
+-1,700
+6,400
+5,700
+5,700
+-1,000
+2,000
+-1,800
+-6,500
+- 1,000
+41,400
+-2,100
+-800
+31,100
+12,200
+-1,500
+1.0200
+5.9900
+3.3600
+51.0000
+3.
+1100
+28.
+900
+33.
+7750
+23.
+8000
+65.
+8300
+21.
+1600
+29.9900
+26.5100
+8.6500
+24.6500
+28.8900
+18.4000
+15.7600
+14.9900
+5.1000
+26.3300
+31.5500
+MARKET
+VALUE
+24,174
+22,163
+42,000
+122,400
+- 13.
+10
+-47,923
+216.1
+60
+135,660
+375.231
+21,160
+59,980
+-47,718
+-56,225
+-24,650
+1,196,046
+-38,640
+- 12,608
+466,189
+196,420
+42,128
+-47,325
+027
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+CURRENT
+YELD IN
+2,300 54762
+5.4762
+480
+.392:
+-2,312
+384
+3,648
+400
+-709
+-480
+9,315
+-252
+864
+4.8244
+0.1776
+2.689
+0.6669
+1.2610
+1.9473
+0.7788
+0.6522
+2.0509
+
+
+8 of 47
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+NOVEL DENIM HOLDINGS LTD
+NEWELL RUBBERMAID INC
+NAUTICA ENTERPRISES INC
+NOKIA CORP: SPONSORED ADR
+REPSTO 1 SER A FM 5 PAR
+NORDSTROM INC
+•••----...
+OLYCOM IN
+POLO RALPH LAUREN CORP-CLA
+OFFICE DEPOT INC
+....
+PACIFIC SUNWEAR OF CALIFORNIA
+INC
+OSHKOSH B GOSH INC CL A
+PAXAR CORP
+aaaaaaaaaaaaaaaaaa.
+JC PENNEY CO INC
+QUIKSILVER INC
+RESTORATION HARDWARE ING DEL
+RADIOSHACK CORP
+SAKS INC
+SKECHERS USA INC
+CLA
+SAFEWAY INO
+SMUCKER JM CO
+SIX FLAGS ING
+_______...
+STAGE STORES INC
+NEW
+SYMBOLCUSIP
+NVLD
+NWL
+NAUT
+AWN
+PLCM
+RL
+ODP
+PSUN
+GOSHA
+PXR
+JCP
+ZOK
+RSTO
+RSH
+SKS
+SKX
+SWY
+SJM
+PKS
+.......
+STGS
+Bear, Steams & Co. Inc.
+MRGN
+SHRT
+MRGN
+SHRT
+SHAT
+SHAT"
+MRGN
+SHRT
+MRGN
+MAGN
+MRGN
+MRGN
+SHRT
+SHRT
+MRGN
+SHRT
+SHAT
+.........
+SHAT
+............
+MRGN
+QUANTIT
+32,650
+-800
+9,600
+-1,200
+-800
+.....
+.800
+33,400
+3,100
+8,700
+-800
+4,400
+3,500
+31,400
+20,571
+-5,700
+-4,500
+36,700
+-900
+1,700
+-1,900
+21,500
+10.7300
+..............
+29.0400
+13.9000
+19.4100
+25.0800
+22.5300
+27.7000
+18.8500
+21.4400
+41.2500
+16.3000
+20.2800
+18.7400
+11.0000
+27.1100
+11.2500
+13.6000
+43.0700
+35.0500
+13.7400
+26.9500
+MARKET
+VALLE
+350,335
+-23,232
+133,440
+-23,292
+-20,064
+40.554
+925,180
+58,435
+186,528
+-33,000
+71,720
+70,980
+588,436
+226,281
+- 154,527
+-50,625
+499,120
+-38,763
+-59,585
+-26,106
+579,425
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+-672
+253
+288
+CURRENT
+YELD IN
+2.8926
+1.0862
+1.4354
+....
+192
+1,750
+-1,254
+0.5818
+2.4655
+0.8115
+1,088
+1.8260
+
+
+9 of 47
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+SEARS ROEBUCK & CO
+SHARPER IMAGE CORP
+SHOPKO STORES INC
+SHOE CARNIVAL INC-IND
+STAPLES INC
+STANDARD & POORS DEPOSITORY
+RECEIPTS (SPDR'S) (BOOK ENTRY)
+UNITS UNDIVIDED BENEFICIAL INT
+SYMBOL TECH
+NOLOGIES INC
+SYNOOR INTERNATIONAL CORP-DEL
+TROPICAL SPORTWEAR
+INTERNATIONAL CORP
+TARGET CORP
+TUX COMPANIES INC NEW
+TANGER FACTORY OUTLET CENTERS
+INC
+....
+TALBOTS INC
+....
+TIMBERLAND CO-CLA
+....
+TOMMY HILFIGER CORP-ORD
+.........
+UNITED RETAIL GROUP INC
+URBAN OUTFITTERS INC
+VANS INC
+aaaaaaaaaaaaaaaaaaaass aan
+bananaiiiaaaaaaaaaaaaaaaaaaaa
+WEST MARINE INC
+HOLE FOODS MARKET IN
+.....
+WET SEAL INC-CLA
+SYMBOLCUSIP
+SHRP
+SKO
+•.......
+SCVL
+SPLS
+SPY
+SBI
+SCOR
+TSIC
+TGT
+SKT
+TLB
+TBL
+TOM
+URGI
+.. ..
+URBN
+VANS
+WAR
+WEMI
+WISLA
+SHRT
+......
+MRGN
+••••••••••••
+SHRT
+IRGI
+SHRT
+SHRT
+MRGN
+SHRT
+MRGN
+MRGN
+MRGN
+MRGN
+MRGN
+....
+ARGN
+MAGN
+SHRT
+SHAT
+.. . ..
+SHRT
+SHRT
+QUANTITY
+-10,150
+14,800
+.. . .
+-10,800
+18,800
+-1,700
+-4,900
+7,800
+2,300
+4,700
+2,800
+4,000
+15,750
+......
+10,350
+35,250
+.. . .
+35,500
+2,200
+-1,500
+.. ..
+-2,400
+.. ..
+-450
+..........
+34,200
+109.7000
+7.4000
+25.0400
+21.0000
+44.3900
+35.7700
+23.4900
+36.5800
+/.......
+34.7600
+12.5000
+.. . .
+8.1200
+.....
+26.0500
+12.1500
+........
+19.5000
+42.8200
+30.2000
+MARKE
+FALLE
+-540,488
+202,760
+- 150,876
+295,348
+-31,450
+-537,530
+57,720
+-57,592
+98,700
+71,024
+100,156
+93,960
+576,135
+359,766
+440,625
+288,260
+57,310
+-18,225
+.. . .
+-46,800
+-19,269
+1.032.840
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+ESTIMATE
+NNUAL INCOM
+-9,338
+CURRENT
+YIELD (S
+1.7277
+.....
+•••••••••••••••••••••••
+-7,066
+1.3145
+156
+0.2703
+384
+504
+9,760
+0.5407
+0.5032
+......
+0.387
+10040
+0.8748
+
+
+10 or 47
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+WOLVERINE WORLD WIDE INC
+TAKE CANDLE NI
+..........
+ZALE CORP NEW
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+wwW
+YCC
+zLe
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+MRGN
+SHRT
+.....
+MRGN
+QUANTITY
+2,000
+•.........
+-1,700
+10,800
+Transaction Detail
+INVESTMENT ACTIVITY
+01/28/02 01/23/02
+01728/02 01/23/02 "BOUGHT
+aaaaaaaaani
+10-82-110000-50200215
+SEC FEE
+"FOOT LOCKER ING"
+EXECUTION BY MONT
+20-83-1009150
+COMMISSION
+112,00
+16.0000
+.. ..
+20.4500
+42.5500
+MARKE
+32,000
+14,76
+459,540
+$14,638,696
+$14,638,696
+$8,672
+$22,304,844
+360
+CURRENT
+YIELD (%)
+1.1250
+.....
+$-18,607
+$-18,607
+SIMBOLCUSIP
+CWTR
+QUANTITY
+-1,600
+16.76300
+
+027
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+23,377.72
+26,805.39
+
+
+11 or 4
+SETTLEMENT TRADE
+01/28/02 01/23/02
+61/28/02 01723/02**BO0GAT
+01728/02 01/23/02 SOLD
+01728/02 01723/02 BOUGHT
+01/28/02
+''*01723/02SOLD
+01728/02 01/23/02
+"SÖLD"
+01728/02
+001723/02
+Bear, Stears & Co. Ine.
+GERBER CHILDRENSWEAR INC
+S 6900 12-08-9
+OMMISSION
+345.00
+SEC FEE
+.68
+"CALYANS TRABING INE
+EXECUTION BY SLKC
+VS 2600 01-23-02
+HOT TOPIC INC***
+WITH DUE BILL SPLT 3:2
+S 2 0 1 02. 1901-1502
+"PAXAR CORP*****
+VS 2400 01-23-02
+COMMISSION
+144,00
+"TOMMY HILFIGER "CORP-ORD
+ECUTION BY FCA
+350 08-17-01, 1450 08-16-
+COMMISSION
+SEC FEE
+126,00
+"FOREST LABORATORIES INC
+/S -900 01-23-0
+1.54.00
+GYMBOREE CORP
+SMELTION BY INET
+VS -900 01-23-02
+SEC FISSION
+27.00
+SYMBOLGUSIP
+GCW
+"HOT
+*PXA
+"TOM
+"FRX
+GYMB
+027
+QUANTITY
+-6,900
+2,600
+2,950
+2,400
+-1,800
+900°
+900
+6.50000
+*''13:22540
+•'33.89430
+15.02200
+14.74840
+83.75000
+14.00020
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+44,489.32
+****34,401.04
+'99,971.69
+36,211.80
+26,405.72
+75,304.86
+"12,557.99
+
+
+12 or 47
+SETTLEMENT TRADE
+DATE
+01/28/02
+01/23/02
+01728/02 01/23/02 SOLD
+01723/02
+01728/02
+*01/23/02
+Bear, Steams & Co. Inc.
+01729/02
+01/24/02
+
+'*01/24/02"
+81729702 81724702 BOUGAT
+NTERVOICE BRITE INC
+OVER SHORT
+IS 500 08-09.07
+SHOPKO STORES INC
+SECUTION BY BUCK
+COMMISSION
+SEC FEE
+210.00
+"TRACTOR SUPPLY CO
+COVER SHORT
+EXECUTION BY INE
+15-900 01-02-02
+SOMMISSION
+27.00
+URBAN OUTTIERS INC"*'
+SECUTION BY INET
+VS -500 01-23-02
+OMMISSIO
+EC FE
+- 15.00
+'ANNTAYLOR STORES CORP
+SEE NOTE 'S' ON BACK
+VS 800 12-19-01, 1200 12-10-01
+700 12-17-0
+OMMISSION
+SEC FEE
+"COACH INC
+1.58.00
+ESS 80IO-BY B2, 300 01-02-02.
+300 12-18-01
+COMMISSION
+SEC FEE
+- 99.00
+700T LOCKER" INC
+COMMISSION
+168,00
+AS OF 01/24/02
+SYMBOLGUSP
+INV
+*SKO
+URBN
+ANN
+"COH
+027
+QUANTITY
+500
+3,500
+900*
+500°
+9.15000
+10.10230"
+25.31470
+2,700
+36.81500
+44-25460
+2,800
+*14.54820
+02/23/02:11:32 001
+CLEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+4,590.00
+35,132.51
+90'980 ZE
+12,627.16
+99.222.00
+*6T:856.51
+40,917.96
+
+
+13 of 47
+SETTLEMENT TRADE
+DATE
+01/29/02
+01/24/02
+0172902 01/24/02 SOLD"
+01/29/02
+01724/02
+017290201724/02
+01729/02
+01/24/02
+01/29/02
+01724/02
+01729/02
+01724/02
+GENESCO INC
+WITH RIGHTS TO PURCHASE PREFRD
+TK UNDER CERTAIN CIRCUMSTANO
+ECUTION BY BUO
+УS 1600 0.24-02
+HOT TOPIC INC
+96.00
+830 01 62 1501300
+1, 1600 11-20-01
+SEC FEE
+3.09
+"HOME DEPOT INC
+US MMSSI0-2-02
+96.00
+"STEVEN MADDEN LTD"
+EXECUTION BY SLKC
+VS 2100 01-24-02
+"PACIFIC SUNWEAR OF CALIFORNIA"
+EXECUTION BY RSSF
+SEC FE 1-08-02, 600 12-3101
+PAXAR CORP****
+EXECUTION BY BUC
+COMMISSION 24-0
+72,00
+ROSS STORES INC
+ECUTION BY MO
+500 01-10-02, 2000 01-08-1
+SEC FEE
+1,30
+SYMBOL/CUSP
+GCO
+*PSUN
+*PXR
+ROST
+027
+QUANTITY
+6,000
+2,100
+1,200
+1,200
+2,500
+23.98800
+''''34.25171"
+48.02000
+'''16.59000
+''22:58130
+1515460"
+34.5367
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+38,491.80
+205,492.14
+*76,943.00
+*34,854.00
+27,082.15
+18,272.52
+86,325.45
+
+
+14 of 47
+SETTLEMENT TRADE
+DATE
+01/29/02
+01/24/02
+0172902 01/24/02 SOLD"
+01/29/02
+01/24/02
+01729/02
+01/24/02
+01729/02 01724/02
+
+'0124702
+TOYS A US INC
+WITH RIGHTS TO PURCHASE COMMON
+0OMMIS0024-02
+210,00
+TOMMY HILFIGER CORP-ORD"
+P55600B1601. 3150 1-130
+COMMISSION
+SEC FEE
+1202,00
+DIAMONDS TRUST-UNIT SERIES 1
+50 10280 00 1020
+54.00
+FLEMING COMPANIES INC
+TH RIGHTS TO PURCHASE PREF
+K UNDER CERTAIN CIRCUMSTAN
+54.00
+LEXMARK INTERNATIONAL INC
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+COVER SHORT,
+EXECUTION BY FECO
+VS-400 01-14-02, -900 01-02-0
+"VAL CORP NEW***
+XECUTION BY DBAB
+VS - 1500 01-24-02
+305,00
+SYMBOLGUSIP
+TOY
+"TOM
+"FLM
+LXK
+027
+QUANTITY
+3,500
+4,700
+900
+*900
+18.92840
+' 1490840"
+58.10000
+
+1,300
+*54.59810
+:1.500
+*'14.81600
+02/2302;11:32 001
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+66,474.40
+69,771.42
+88,359.00
+17,649.87
+71,083.53
+22,103.66
+
+
+15 of 47
+SETTLEMENT TRADE
+DATE
+01/29/02
+01/24/02
+0173002 01/25/02 "BOUGHT
+01730/02
+01725/02 BOUGHT
+01730/02 01/25/02"BOUGHT"
+01/30/02 01/25/02 BOUGHT
+
+01/25/02
+01730/02 01/25/02 SOLD
+WEST MARINE INC
+SHORT,
+EXECUTION BY INET
+
+SO ASION
+72,00
+.56
+"GENESCO INC"**
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+VS 1600 01-25-02
+96.00
+"HOME DEPOT INC
+VOMMIS31025-02
+48.00
+NORDSTROM ING
+VS 3300 01-25-02
+COMMISSION
+198,00
+CHAISTOPHER & BANKS CORP
+COVER SHORT,
+5 30001-05020
+"FAMILY DOLLAR STORES ING"
+VER SHOR
+5-600 11-01-01, 500 11-12
+COMMISSION
+66.00
+"FOREST LABORATORIES INC
+•30.00
+SYMBOLCUSP
+WMAR
+WN
+CHES
+"FDO
+027
+QUANTITY
+-2,400
+15.31190
+800°
+3,300
+300"*
+7,700
+500
+'24.30240
+47.15000
+24.67660
+'3250000
+32.50000
+- 81.16520
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+36,661.00
+# 38,994.84
+37,783.00
+*81,645.78
+'9,785.00
+*35,831.00
+40,536.99
+
+
+16 or 47
+SETTLEMENT TRADE
+DATE
+01/30/02
+01/25/02
+01730102 01/25/02 SOLD"
+
+01728/02
+
+01/28/02
+*BOUGHT
+10128(02
+
+01728/02 SOLD*
+
+01728/02
+DNI WONTO
+SHORT
+EXECUTION BY INET
+SEMMISSION
+"DAL COAP NEW*'*
+-51,00
+COMMISSION
+SEC FEE
+126.00
+AS OF 01/25/02
+ANNTAYLOR STORES CORP
+SEE NOTE 'S' ON BACK
+0OMMI501-2-02
+48.00
+HELORENS PLACE RETAL STORES
+XECUTION BY JPH
+'S 2800 01-28-0
+AMILY DOLLAR STORES IN
+XECUTION BY BUC
+VS 4100 01-28-02
+COMMISSION
+246.00
+N. SEATED DEPARTMENT STORES
+NS 80001-0202, 100 12-31-01
+COMMISSION
+SEC FEE
+"STEVEN MADDEN LTD
+SYMBOL/CUSP
+PLCM
+DAL
+ANN
+307d
+FDO
+SH00
+027
+QUANTITY
+-1,800
+1,800
+30.75600
+''14:50070"
+800
+2,800
+4,100**
+900*
+2,000
+37.90000
+*32.84880
+32.14000
+
+15.98000
+02/23/02:11:32 001
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+55,290.96
+26,139.86
+30,383.00
+79:166 16
+132,035.00
+37,026.01
+31,975.00
+
+
+OFFICE SERVICING YOUR ACOUNT
+Bear, Steams & Co. Inc.
+17 of 47
+SETTLEMENT TRADE
+DATE
+01/31/02
+01/28/02
+01731/02 01/28/02 SOLD
+TOYS A US INC
+TR UNDER ER AN CHUMSTANCE
+ECUTION BY BUO
+S 3500 01-24-0
+OMMISSIO
+SEC FEE
+1200.00
+"TOMMY HILFIGER CORP-ORD
+01/28/02
+BOUGH
+1, 1000 10-26-01, 1050 10-24-0
+SO FESSION
+1205.00
+ACTION PERFORM
+MANCE COMPANIES
+OVER SHORT
+VS -300 01-09-02
+01/31/02
+''01/28/02 BOUGHT
+COMMISSION
+01728/02
+96,00
+ö1731/02
+'*01728/02
+*BOUGHT
+08 3012 020 300 01-22
+"RADIOSHACK CORP
+COMMISSION
+108,00
+SMOUGUS
+TOM
+CHS
+GYMB
+RSH
+027
+QUANTITY
+-3,500
+19.71970
+4,900
+• 15.52510
+300
+3,900°
+1,800
+39.42000
+30.16400
+14.29800
+-'30.86980
+IOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+68,792.91
+75,762.84
+11,841.00
+48,373.40
+55,777.20
+55,688.64
+
+
+18 or 47
+DATE
+02/01/02
+01/29/02
+ö2/01/0201/29/02$ÖLD
+Bear, Stearns & Co. Inc.
+
+*''01/29/02"BÖUGHT"
+02701/02
+02/01/02
+01729/02
+01/29/02
+"BOUGH
+ö2/01/02"
+0129/02
+02/01/02
+**01/29/02
+BOUGH
+AMERICAN EAGLE OUTFITTERS INC
+NEW
+ECUTION BY JPI
+: 800 01-29-0
+COACH INC
+ES 30012- BY 01. 300 12.20.01.
+500 12-10-01
+DOMMISSION
+SEC FEE
+1,96.00
+FOOT LOCKER INC
+VS 1000 01-29-02
+COMMISSION
+60.00
+HOT TOPIC INC
+WITH DUE BILL SPLT 3: 2
+STEVEN MADDEN LTD
+EXECUTION BY INET
+: 2400 01-29-
+IMMISSIO
+72.00
+"TOMMY HILFIGER CORP-ORD"
+SAS AS024B1, 1000 10-09-01
+668.00
+CHICOS FAS INC
+48,00
+SYMBOLCUSIP
+AEOS
+COH
+SHOO
+"TOM
+*CHS
+027
+QUANTITY
+800
+1,000
+6,500
+2,400
+2,800
+26.28500
+• 46.10680
+13.63600
+31.30670
+14.64700
+15.17210
+800
+30.36100
+CLEARED THROUGH IT
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+21,043.00
+73,658.77
+13,711.00
+203,508.55
+35,239.80
+42,298.24
+24,351.80
+
+
+19 or 47
+SETTLEMENT TRADE
+DATE
+02/01/02
+01/29/02
+02764702 81730702 BOUGHT
+02/04/02 "01730/02"BOUGHT'
+02/04/02 01730/02"SOLD
+01/30/02
+'*01730/02 BOUGHT
+02704/02 01730/02 "BOUGHT
+01730/02
+Bear, Steams & Co. Inc.
+DELIA'S CORP
+CLA
+COVER SHORT
+EXECUTION BY OPOO
+VS - 1500 12-17-01
+NEVERICAN EAGLE OUTFIES INE"
+XECUTION BY JPH
+S 4800 01-30-0
+"CHILDRENS PLACE RETAIL'STORES
+513000130-02
+COACHING...
+OMMISSIO
+"GART SPORTS CO"
+EXECUTION BY NITE
+VS 800 01-30-02
+"GENESCOINC"
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY VKCO
+VS 800 01-30-02
+COMMISSION
+56.00
+"KOHLS CORP
+EXECUTION BY RHCO
+VS 600 01-10-02
+COMMISSION
+SEC FEE
+-42.00
+SYMBOLCUSIP
+DLIA
+"AEOS
+"PLE**'''
+COH
+BLTA
+"GRTS
+GCO
+KSS
+027
+QUANTITY
+4,800
+7.25000
+• 2650250"
+800
+1,700
+800°
+800
+600*
+• 4482810
+32.59500
+20.38000
+'24.10000
+' 63.83050
+CLEARED THROUGH ITE
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+10,890.00
+'''127,227.00
+'41,878.25***"
+35,798.94
+55,426.50
+16.319.00
+19,351.00
+38,240.72
+
+
+20 of 47
+STENT TATE
+DATE
+01/30/02
+62/64/02 01730/02 SOLD
+'01730/02 "BOUGHT
+01730/02
+"SÖLD"
+01730/02
+*SOLD
+0270470201730/02 "BOUGHT
+027040201730/02 BOUGHT
+Bear, Steams & Co. Inc.
+PACIFIC SUNWEAR OF CALIFORNIA
+"QUIKSILVER INC"
+VS 1500 01-30-02
+COMMISSION
+90.00
+REEBOK INTERNATIONAL LTD
+WITH RIGHTS TO PURCHASE COMMON
+STK UNDER CERTAIN CIRCUMSTANCE
+VS 700 10-03-01, 100 11-13-01
+OMMISSIO
+- 38.00
+ROSS STORES INC
+EXECUTION BY GSCO
+VS 800 01-08-02
+COMMISSION
+SEC FEE
+40.00
+TROPICAL "SPORTWEAR
+NTERNATIONAL CORI
+ES 3200 01-90-02
+"TARGET CORP''''*
+UNSOLICITED
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+SEE NOTE *S' ON BACK
+AS OF 01/30/02
+SYMBOLGUSIP
+SH0O
+*PSUN
+*ZaK
+ABK
+ROST
+TGT
+027
+QUANTITY
+3,700
+2,200
+800°
+800
+3.200
+14.54800
+22.86000
+18.02950
+29.50500
+35.28890
+20.50000
+• 41.45700
+02/23/02:11:32 001
+CLEARED THROUGH IT
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+53,953.60
+50,276.24
+27,149.25
+23,540.64
+28,175.69
+65,615.00
+66,443.20
+
+
+21 or 47
+DATE
+01/30/02
+ö204/0201/30/02"BÖÜGHT
+02/04/02 01730/02 "BOUGHT
+01/30/02
+02/05/02
+ö2/05/02
+
+02/05/02
+*1731/02
+02/05/02
+''''SOLD
+Bear, Steams & Co. Inc.
+TOMMY HILFIGER CORP-ORD
+EXECUTION BY MSCO
+OSMMISSIO-30-02
+469,00
+CHRISTOPHER & BANKS CORP"
+DOVER SHORT
+65600 01-08 02, 300 01-07-0
+CHICOS FAS INC...........
+DOVER SHORI
+EXECUTION BY COWN
+/S -900 01-07-02
+OMMISSION
+63.00
+UNITED STATIONERS INC
+OVER SHORT
+85-800 01-02.07
+AENRICAN EAGLE OUTFITERS ING
+VS 0300 01-31.02
+COLUMBIA SPORTSWEAR CO
+ES 80001-04 02, 100 12-31-01
+SEC MISSION
+-27.00
+"DOLLAR TREE STORES INC"*
+580001-91-0256
+FEDERATED DEPARTMENT STORES
+ING-DEL
+S5 300 12 31.01, 60 0-0302,
+600 12-10-0
+OMMISSIO
+150,00
+SEC FEE
+1,55
+SYMBOL/GUSP
+TOM
+*CHBS
+*CHS
+USTR
+"AEOS
+COLM"
+FD
+027
+QUANTITY
+6,700
+12.25710
+900°
+32.00500
+*900
+* 29.10000
+800°
+38.11000
+4,900
+25.48200
+900
+29.00150
+800°
+'33.12000
+2,500
+41.20000"
+CLEARED THROUGH IT
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+82,606.57
+28,819.50
+26,268.00****
+30,503.00
+"124,876.80
+26,058.95
+26,571.00
+102,833.45
+
+
+22 o147
+SETTLEMENT TRADE
+DATE
+02/05/02
+01/31/02
+62/65/02 01731702*"SOLD
+02/05/02 01731/02 SOLD
+02/05/02
+02/05/02
+
+BOUGHI
+02706/02
+:02/01702BOUGHT
+02/06/0202/01/02SOLD
+JONES APPAREL GROUP ING
+S 1000 12-11-0
+OMMISSION
+SEC FEE
+-50.00
+R'SWISSING CLA
+EXECUTION BY VKCO
+SEC F 04-30-01
+SECE SUWER OF CAPON .
+S 0 20 01 00 19001
+SEC FEE
+REEBOK INTERNATIONAL LTD
+WITH RIGHTS TO PURCHASE COMMON
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY RHC
+VS 1200 11-13-01
+SEC MISSION
+154.00
+UNITED STATIONERS INC
+AMERICAN EAGLE OUTFIERS INC
+
+'ANNTAYLOR STORES CORP
+SEE NOTE 'S' ON BAC
+EXECUTION BY BACK
+VS 800 01-28-02
+COMMISSION
+SEC FEE
+18.00
+SYMBOLGUSIP
+JNY
+"KSWS"
+ABK
+"USTR
+"AEOS
+'ANN
+027
+QUANTITY
+-1,000
+33.10350
+800
+'37:60000
+2,500
+00*****23.17000
+1,200
+29.65000
+4,800
+800
+38.75000
+25.89700
+- 3798000
+02/23/02:11:32 001
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+33,028.00
+*30,064.54
+' 57,909.13
+35,480.46
+58,140.00
+124,320.60
+30,320.54
+
+
+23 or 47
+SETTLEMENT TRADE
+DATE
+02/01/02
+ö206/02"02/01/02"$ÖLb
+
+20/90/20
+02/01/02
+02/01/02
+20/90/20
+02/01/022
+02706/02 02/01702BOUGHT
+BORDERS GROUP INC
+5 1800 01-08-0
+OMMISSIO
+SEC FEE
+108.00
+"COLUMBIA" SPORTSWEAR CO"
+EXECUTION BY GSCO
+/S 800 12-31-01
+DOMMISSIOI
+SEC FEE
+30.00
+FOOTSTAR INC
+EXECUTION BY BUCH
+VS 800 01-15-02
+COMMISSION
+SEC FEE
+38,00
+"FEDERATED DEPARTMENT STORES
+INC-DEL
+OMMISSIO
+EC FE
+FOSSILING
+130.00
+"PACIFIC SUNWEAR OF CALIFORNIA"
+EXECUTION BY AHCO
+S 800 11-30-01
+SEC FE
+.28
+"PAXAR CORP"*'*"'
+VS 800 02-01-02
+COMMISSION
+48.00
+SYMBOLGUSIP
+BGP
+"COLM
+FTS
+FD
+FOSL
+PSUN
+**PR
+QUANTITY
+-1,800
+800
+800*
+500°
+700
+800
+*800
+23.66110
+• 3232530"
+27.65930
+40.77130
+23.73400
+23.02800"
+- 16.50000
+02/23/02:11:32 001
+CLEARED THROUGH IT
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+42,466.34
+''25,804.85
+22,064.10
+20,340.34
+16,598.55
+18,405.52
+13,263.00
+
+
+24 ol 47
+DATE
+02/01/02
+Bear, Steams & Co. Inc.
+02/06/02 02/01/02 SOLD
+02706/02
+12/01/0
+'''201/02
+'BOUGHT
+02/06/02 02/01/02 SOLD
+0207/02
+n''022/04/02
+CONIS 101301, 600 10.00-01
+48,00
+SEC FEE
+RADIOSHACK CORP
+SHEUTION BY BUCK
+S0 10 0201-02
+108,00
+STANDARD & POORS DEPOSITORY
+SECUTION BY BUCK
+YS MISSION 01-02
+114,00
+UAL COAP NEW***
+COVER SHORT,
+ES -18001 25-52, 150 01-24
+COMMMISSION
+231.00
+"VANS INC
+SHORT,
+VS -1500 02-01.02
+COMMISSION
+SEC FE
+115.00
+AMERICAN EAGLE OUTFITTERS INC"
+EXECUTION BY JPHO
+S 12300 02-04-0
+S OF 02/04/0
+SYMBOLCUSIP
+ABK
+RSH
+*SPY
+DAL
+"VANS
+220
+QUANTITY
+-800
+- 1,800
+1,900
+*3,300
+-1,500
+12,300
+29.50000
+30.44000
+13.1000
+14.04610
+• 13.05260
+- 2461540
+02/23/02:11:32 001
+IOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+23,536.64
+54,668.17
+214,757.77
+46,598.13
+19,518.60
+*302,784.42
+
+
+25 or 47
+DATE
+02/07/02 02/04/02 SOLD"
+
+0207/02
+02/04/02 BOUGHT
+02/07702
+*SOLD
+8278702 02784702'508
+020770202/04/02'BOUGHT
+BORDERS GROUP INC
+: 1700 01-08-0
+IMMISSIO
+SE OF 0204102
+
+COLUMBIA SPORTSWEAR CO
+AS OF 02104102
+"CHICOS FAS INC**
+.24
+234,00
+"DOLLAR GENERAL CORP"
+VS 2400 02-04-02
+AS 0 0200402
+144,00
+FEDERATED DEPARTMENT STORES
+VS 300 12-10-01, 600 12-06-0
+COMMISSION
+54,00
+SEC FEE
+AS OF 02/04/02
+GAB208KS' INC***
+RECUTON BYE. 500 05 10-01
+SEC FEE
+AS OF 02/04/02
+"GYMBOREE CORP
+EXECUTION BY SBSH
+VS 1600 02-04-02
+AS OF 02/04/02
+SYMBOLGUSIP
+BGP
+W700
+CHS
+FD
+"GADZ"
+027
+QUANTITY
+-1,700
+500
+3,900
+2,400
+900
+:7,600
+23.65000
+
+30.09640
+• 16.46020
+40.02750
+14.25000
+13.80000
+02/23/02:11:32 001
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+40,087.39
+*15,724.76
+117,624.96
+39,663.48
+35,955.20
+22,784.65
+22,095.00
+
+
+26 or 47
+DATE
+02/07/02 02/04/02 SOLD
+ö2/07/02
+'''*02/04/02
+*''*SOLD
+02/07/02 02/04/02 SOLD
+
+
+HOT TOPIC INC
+WITH DUE BILL SPLT 3:2
+VS SO 1-2-02, 100 11-20-01
+15020021)
+5,26
+JONES APPAREL GROUP ING
+XECUTION BY BUCK
+'S 700 12-11-01, 1000 01-02-0
+, 600 01-03-02
+COMMISSION
+SEC FEL
+1128.00
+S OF 02/04/0
+K-SWISS INC-CLA
+ВЕРОЙ 3 °
+.46
+AS OF 02/04/02
+MASCO CORP"****
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+38.00
+"NAUTICA ENTERPRISES INC**
+S2 00-62
+AS OF 02/04/02
+.26
+PACIFIC SUNWEAR OF CALIFORNIA
+XECUTION BY RSS
+S 1200 11-30-01, 700 12-041
+540 0 12-190
+1.11
+S OF 02/04/02
+SYMBOLCUSIP
+HOTT
+JNY
+'KSWS
+MAS
+NAUT
+PSUN
+027
+QUANTITY
+-10,700
+32.74900
+32.41300
+2,300
+-800
+800*
+38.02000
+26.79530
+-1,200
+3,300
+- 13.91000
+
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+350,394.04
+74,395.78
+30,400.54
+- 21,372.91
+16.676.74
+73,728.99
+
+
+27 or 47
+DATE
+02/07/02 02/04/02 SOLD"
+02707/02
+
+02/04/022
+02704/02
+*SOLD
+SKECHERS USA INC
+84,00
+"STRIDE RITE "CORP"
+WITH RIGHTS TO PURCHASE PREFRO
+STK UNDER CERTAIN CIRCUMSTANCE
+VS 5000 12-20-01
+COMMISSION
+SEC FEE
+350.00
+"TALBOTS INC
+VS 800 02-04-02
+OMMISSION
+48.00
+S OF 02/04/02
+"CHICOS FAS ING"
+COVER SHORT
+VS -750 01-07-02
+AS OF 020402)
+45.00
+RADIOSHACK CORP
+SHORT
+500 130402
+$1.00
+AS OF 02/04/02
+*STANDARD & POORS DEPOSITORY
+VS - 2200 02-04-02
+132,00
+SYMBOLCUSP
+SKX
+SAR
+CHS
+SPY
+027
+QUANTITY
+5,000*
+15.03490
+
+800
+*750
+900%
+2,200
+
+
+29.83080
+•'T1.62600
+LEARED THROUGH IT
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+21,147.86
+*32,760.00
+00'E62 22.
+• 186.
+26,778.31
+245,426.51
+
+
+28 or 47
+DATE
+02/08/02 02/05/02 SOLD*
+02/08/02
+02705/02
+'BOUGHT
+02/08/02
+02/05/02
+02/08/02
+02/05/02
+BOUGH
+02/08/02
+''02/05/02 SOLD"
+ö2/08/02
+'''82285702'BO0GHT
+ESCRIPTION
+VILSONS LEATHER EXPERTS IN
+COVER SHORT,
+VS 2700 01-08-02, -1000 01-09
+13 OF 0204102
+BORDERS GROUP INC
+1S 90001-9 BOK
+COMMISSION
+SEC FEE
+54,00
+COACH ING
+VS 800 02-05-02
+COMMISSION
+48.00
+HOT TOPIC INC
+WITH DUE BILL SPLT 3: 2
+EXECUTION BY MON
+VS 2200 11-29-01, 1800 11-28-0
+700 11-09-01, 500 10-19-0
+SEC FE
+POLO RALPH LAUREN CORP-CLA
+SEE NOTE "S* ON BACH
+VS 1000 02-05-02
+COMMISSION
+60,00
+PRACTIC SUNWEAR OF CALFORNIA
+SE 2 0 01 20 12001
+SEC FEE
+""UIKSILVER"IN*"
+0S MISS02-05-02
+60.00
+SYMBOLCUSIP
+WLSN
+*BGP
+COH
+"PSUN
+20K
+027
+QUANTITY
+3,700
+-900
+800°
+5,200
+1,000
+:500
+1,000
+10.47180
+* 23.18760
+43.95930
+31.93410
+25.99000
+• 17273300"
+02/23/02:11:32 001
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+38,760.66
+20,799.52
+35,230.44
+166,039.82
+
+10,774.83
+17,208:00
+
+
+29 0147
+SETTLEMENT TRADE
+DATE
+02/08/02
+02/05/02
+62/08/02 02/05/02***BOUGAT
+02/08/02 "02/05/02"BOUGHT**
+02/08/02 02/05/02 SOLD
+02/08/02
+*02/05/02
+02711/02 02/06/0250LB
+02717702 02/08/02 "BOUGHT"
+02717/02
+0206/02
+*BOUGHT
+SKECHERS USA INC
+85200 0862*
+COMMISSION
+126,00
+TALBOT INC
+S 1200 02-05-0
+IMMISSIO
+DOVER SHORT
+85-600 01-07:02
+"EMERSONELECTRIC CO"
+EXECUTION BY OPCO
+5 - 1700 02-05-0
+OMMISSION
+SEC FEE
+1.19.00
+ZEBRA TECHNOLOGIES CORP-CLA
+6540-0-80
+"GADZOOKS IN......
+EXECUTION BY SLKC
+VS 900 05-10-01, 200 09-04-01
+SEC FEE
+EXECUTION BY SBSI
+0-90200012SN
+HOT TOPIC INC.
+WITH DUE BILL SPLT 3: 2
+EXECUTION BY INET
+COMMIS 02-06-02
+135,00
+SYMBOLCUSP
+SKX
+TLE
+*EMA
+ZBRA
+''''GADZ
+"GYMB
+027
+EARED THROUGH I
+HOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+QUANTITY
+2,100
+14.68500
+DEBIT AMOUNT
+30,979.50
+CRECIT AMOUNT
+1,200
+• 41,647.32
+60028.76000.......*
+'17,271.00**'
+-1,700
+''34.87610"
+93,153.97
+• 52.50750
+73.525.50
+-1,100
+* 13.90000******
+*' 15.274.77
+2,400
+* 13.71500
+32,931.00
+4,500
+''30.09250
+135,566.25
+
+
+30 0147
+SETTLEMENT TRADE
+DATE
+02/11/02
+62/11/02 02/06/02S0LВ
+02717/02
+
+02/12/02
+BOUGH
+
+02712/02
+HOT TOPIC INC
+WITH DUE BILL SPLT 3:2
+0-90-20 0009 S
+NOISSIWINOO
+100,00
+"TONES APPAREL "GROUP"IN*'*'
+1 1 100 121-03-02, 700 12-1-01
+COMMISSION
+198,00
+RACHERS USA INC
+'S 2400 02-06-0
+OMMISSIO
+144,00
+"AMDOCS LIMITED"
+COVER SHORT,
+24,00
+AMERICAN EAGLE OUTFITTERS INC
+NEW
+
+ANNTAYLOR STORES CORP
+EXECUTION BY ONBACK
+S 2300 12-17-01, 2900 12-11
+, 500 12-03-0
+SEC FESSION
+3.90.00
+COACH INC
+XECUTION BY BUCI
+'S 800 02-07-02
+COMMISSION
+48,00
+SYMBOLICUSIP
+HOTT
+''NY
+SKX
+"DOX
+"AEOS
+ANN
+COH
+027
+QUANTITY
+5,000
+3,300
+2,400
+*400
+5,700
+30.50650
+• 31.62638"
+13.74980
+31.10000
+24.11000
+40.83740"
+800
+41.95000
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+152,647.50
+''104,152.22
+33158.52
+12,479.00
+36,180.00
+232,355.68
+33,623.00
+
+
+31 01 47
+SETTLEMENT TRADE
+DATE
+02/12/02
+02212/02020702 BOUGHT
+02/12/02 02/07/02 BOUGHT
+02/12/02
+BOUGH
+02/12/02
+02/07702
+0271202 02/07/02
+02/12/02 02/07/02 SOLD
+02/12/02 02/07/02 SOLD
+Bear, Steams & Co. Inc.
+FAMILY DOLLAR STORES INC
+800 02-07-0
+IMMISSIO
+48,00
+HOT TOPIC INC***
+STE 12302 17 02 0602
+"HOT TOPIC ING
+5 4800 020-
+OMMISSION
+138,00
+STEVEN MADDEN LTD
+IS 2100 02-07:02
+"NAUTICA ENTERPRISES INC
+EXECUTION BY JPHO
+VS 800 01-04-02, 1200 11-14-01
+1700 11-26-01, 300 01-03-02
+SEC FEE
+.83
+PACIFIC SUNWEAR OF CALIFORNIA"
+PE SO 209400
+"ROSS STORES INC
+EXECUTION BY MON
+VS 3000 01-08-02
+SEC FEE
+1.62
+"TIMBERLAND CO-CLA
+EXECUTION BY FCAP
+S700 01-10-02, 600 01-01102
+1700 01-11-02
+COMMISSION
+SEC FER
+1328.00
+SYMBOLGUSIP
+FDO
+"HOTT
+"HOTT
+SHOO
+NAUT
+"PSUN"
+"ROST
+"TBL
+027
+QUANTITY
+800
+8,800
+*4,600
+2,100
+4,000
+3,400
+3,000
+8,800
+32.03800
+
+14.05000
+13.70000
+''2146200"
+' 35.93570
+32.39850
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+25,693.40
+97,208.86
+9 5200
+54,784.17
+*72,985.80
+'107,790.48
+284,471.52
+
+
+32 o147
+DATE
+02/12/02
+02/12/02 02/07/02 "BOUGHT
+
+02708/02
+Аналов.
+02/13/02
+02/08/01
+02713/02
+202708/02
+'BOUGHT
+02713/02
+02/08/02
+BJS WHOLESALE CLUB ING
+SHOUTION BY BUCK
+VS -3400 02-07-02
+SECTION
+2201.00
+"CHRISTOPHER & BANKS CORP
+15.00
+HASBRO INC"
+STIR UNDER CERTAIN CHAUTANCE
+SEE NOTE 'S' ON BACK
+COVER SHORT,
+E5-800 10-02-01. 700 08-30-0
+BEST BUY COMPANY INC
+24,00
+BORDERS GROUP INC
+VS 2100 01-08-02, 600 01-09-02
+OMMISSION
+162,00
+KENNETH COLE PRODUCTIONS ING
+1200 02-08-
+MMISSI
+72.00
+"FOOT LOCKER ING
+VS 5100 02-08-02
+COMMISSION
+306,00
+SUBOUCUS
+"CHBS
+"HAS
+BBY
+"BGP
+KCP"
+027
+QUANTITY
+-3,400
+500
+46.96170
+
+13.25000
+*400
+2,700*
+1,200
+5,100
+68.00000
+3.2500
+16.00000
+
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+159,448.38
+''13,775.25
+19,980.00
+27,239.00
+62,597.05
+19,287.00
+76,465.53
+
+
+Bear, Steams & Co. Inc.
+New York. New York 10179
+33 o147
+SETTLEMENT TRADE
+DATE
+02/13/02
+02/08/02
+6213/02 02/08/02*BÖ0CA1
+ö2/1302 02/68/02"S0LВ"
+02713/02
+02/08/02
+*SOLD
+02/13/02
+*02/08/02 SOLD*
+02713/02 02/08/02BOUGHT
+02/13/02
+0208/02
+VS 800 02-08-02
+"STEVEN MADDENLYD
+LECUTION BY JEF
+S 3500 02-08-0
+"NORDSTROM IN**'**
+VS 800 01-25-02
+DOMMISSION
+48,00
+SEC FEE
+.28
+TIMBERLAND CO-CLA
+VS 1400 01-04-02
+COMMISSION
+SEC FEE
+81.00
+CONSTELLATION BRANDS INC
+SHE NOTE S° ON BACK
+SHORT,
+VS-170 206-02
+COMMISSION
+102,00
+DIAMONDS TRUST-UNIT SERIES
+COVER SHORT,
+300220 0 1 170
+COMMISSION
+54,00
+TESTE LAUDE COMPANIES NEC
+COMMIS 510-16-01
+54.00
+SYMBOLCUSIP
+HOTT
+*SH00"
+'''WN
+TeL
+QUANTITY
+800
+*800
+CLEARED THROUGH IT:
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+16,887.00
+*49,890:00
+21.09000
+- 1425000"
+• 2295000
+''31.51260
+49.72320
+18,296.72
+44,017.97
+84,411.17
+1,700
+*.90*7.3000••••87,639.00*
+EL
+900
+30.10000"
+27,159.00
+027
+
+
+34 or 47
+DATE
+02/13/02
+02/08/02
+02/14/02 02/11702 BOUGHT
+ö2/14/02
+
+02714/02
+02/11/02
+02/11702
+02/11/02
+02/14/02 02/11/02"
+02714/02
+02/11702
+BOUGH
+02714/02 02771702*"OUGHT
+Bear, Steams & Co. Inc.
+STANDARD & POORS DEPOSITORY
+ECEIPTS (SPDRS) (BOOK ENTRY
+OVER SHORTED BENEFICIAL IN
+5 00 02 0-02
+IMMISSION
+48,00
+AMERICAN EAGLE OUTHTTERS INC
+NEW
+ECUTION BY JPH
+$ 900 02-11-0
+CLARE COLE PRODUCTIONS NG"
+VS 4200 02-11-02
+COMMISSION
+252.00
+"DIRECT FOCUS INC
+EXECUTION BY OPOO
+VS 1200 02-11-02
+STEVEN MADDEN LTD
+EXECUTION BY JEFF
+VS 4600 02-11-03
+JC PENNEY CO INC
+SEE NOTE "S' ON BACK
+VS 3500 02-11-02
+AS OF 02/1102
+210,00
+"SKECHERS USA INC
+DSAMISSION 11-02
+450,00
+"TROPICAL "SPORTWEAR***
+NTERNATIONAL CORI
+EXECUTION BY NIT
+VS 1500 02-11-02
+SYMBOLCUSIP
+SPY
+AEOS
+KCP
+"SHOO"
+SKX
+027
+QUANTITY
+800
+109.76000
+900
+4,200
+1,200
+4,600
+3,500
+*7,500
+24.95000
+16.40470
+' 29.15080
+14-45830
+21.85940
+14.35510
+21.10000
+02/23/02:11:32 001
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+87,871.00
+22,470.00
+69,166.74
+*34,995.96
+66,523.18
+76,732.90
+108,128.25
+*31,665.00
+
+
+35 ol 47
+DATE
+02/14/02
+02/11/02
+0271402 02/11/02 "BOUGHT
+02/15/02
+02/12/02
+02715/02 02/12/02*B00GHT
+2/15/0
+202/12/02
+''''SOLD
+02/15/02
+02/15702 02/12/02 SOLD
+DILLARDS INC-CLA
+VS - 1700 02-11-02
+DOMMISSION
+SEC FER
+102.00
+"DIAMONDS TRUST-UNIT SERIES T
+0 0 0 1 0 0 01050
+72,00
+OMMISSION
+96.00
+EC FE
+80
+'ESTEE LAUDER COMPANIES INC
+CLA
+VS 2000 02-12-02
+COMMISSION
+120,00
+VS 1300 01-03-02
+SEC FEE
+.27
+NORDSTROM INC
+00 0 01 25-02
+SEC FEE
+1850,00
+"REEBOK INTANATIONAL LYD"
+WITH RIGHTS TO PURCHASE COMMON
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY WEDB
+VS 1100 10-11-01, 1200 10-08-0
+COMMISSION0-01
+238,00
+SYMBOLCUSIP
+DDS
+"DIA
+CHS
+"NAUT
+'WN
+"ABK
+027
+QUANTITY
+-1,700
+1,200
+-1,600
+2,000
+-1,300
+2,500
+3,400
+15.52730
+* 32.97200
+'''30.52680
+13.65250
+
+'28.3300Ö
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+26,279.01
+•118,875.00
+52,643.40
+•••.
+51,188.61
+17,732.98
+58,230:12
+96067.55
+
+
+36 of 47
+SETTLEMENT TRADE
+DATE
+02/15/02
+02/12/02
+02/15/02 02/12/02"S0LD"
+02/13/02
+*BOUGHT
+02/13/02
+02719/02 02/13/02"BOUGHT
+''*02/13/02
+82799702'
+TIMBERLAND CO-CLA
+UNSOLICITED
+AS OF 02/12/02
+"VANKEE CANBLE INC
+COMMISSION
+SEC FEE
+102.00
+CHARMING SHOPPES ING
+XECUTION BY NIT
+/S 4800 02-13-0
+HOT TOPIC IN*****
+58900 02-13-027
+AUTICA ENTERPRISES IN
+ECUTION BY RSS
+200002, 7012101.
+"OFFICE DEPOT INC
+S120002-13-02
+COMMISSION
+72,00
+OFFICE DEPOT INC...
+WITH RIGHTS TO PURCHASE PREFRO
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY INET
+S 1900 02-13-0
+OMMISSIO
+38,00
+(ECUTION BY JP-
+5 2100 02-13-
+SYMBOLCUSP
+TBL
+"CHAS
+"HOTT
+NAUT
+*OOP
+*OBP
+"PSUN"
+027
+QUANTITY
+-5,700
+1,700
+31.68160
+- 19:17000
+4,800
+3,900%
+-1,900
+1,200
+1,900
+6.16000
+21.75000
+13.67880
+18.00000
+''17;03580
+2,100
+2177400"
+02/23/02:11:32 001
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+180, 183.41
+32,471.51
+29,583.00
+84,840.00
+25,974.33
+21,687.00
+'' 12,42102
+*44,354.40
+
+
+37 or 47
+
+02/19/02 02/13/02 BOUGHT
+'*02/13/02BÖUGHT
+02719/02
+02/13/02 "BOUGHT
+02719/02
+02/13/02
+*BOUGHI
+02719/02
+'02713/02"SOLD*
+RESTORATION HARDWARE INC DEL
+EXECUTION BY INET
+1. 500 12-2-01. 200012-190
+SEC FESSION
+2185,00
+*TOMMY HILFIGER CORP ORD
+0S MASS 213-02
+84,00
+WOLVERINE WORLD WIDE INC
+SIR UNDER ERA CHARANCE
+COMMISSION 3-02
+120.00
+"BUS WHOLESALE CLUB INC"**
+COVER SHORT,
+EXECUTION BY VKCO
+YS IS 0-07-02
+42,00
+"CHARLOTTE RUSSE HLDG INC
+6:00 2 180. 12001207
+SHORINDS TRUST UNIT SERIES 1
+1S 30002-1-024
+COMMISSION
+SEC FE
+18.00
+SYMBOLCUSIP
+RSTO
+"TOM
+www
+CHIC
+"DIA
+027
+QUANTITY
+-15,500
+2,000
+10.00160
+1261790"
+15.60000
+600
+2,700
+300
+•44.30000
+20.95500
+' 99.58000
+02/23/02:11:32 001
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+154,542.47
+17,764.06
+31,335.00
+26,637.00
+56,593.50
+29,840.55
+
+
+Bear, Steams & Co. Inc.
+38 0147
+SETLEMENT TATE
+
+02/19/0202/13/02BOÜGHT
+20/6L/20
+12/13/0
+*SOLD
+02/13/02
+ELECTRONIC DATA SYSTEMS CORP
+NEW
+SHOUTION BY BACK
+YAM 0213-02
+SEC FEE
+151.00
+MARTHA STEWART LIVING
+MINIMEDIA INO CL
+OVER SHORT
+VS -2000 12-19-01
+COMMISSION
+120.00
+NOKIA CORP SPONSORED ADR
+REPSTG 1 SER A FM 5 PAF
+SHORT
+52002-19-02
+SEC MISSION
+172.00
+RADIOSHACK CORP
+02719702 0273/02'SOD
+COMMISSION
+SEC FEE
+'STAPLES INCI
+SHORT
+VS-1/700 02 13:02
+COMMISSION
+SEC FEE
+-739.00
+151.00
+SYMBOLGUSIP
+EDS
+*MSO
+NOK
+RSH
+'''''SPLS
+027
+QUANTITY
+-900
+60.07000
+2,000
+-1,200
+16.06390
+....
+22.9900
+1,700
+-1,700
+28.32780
+'18.88250
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+53,993.18
+"32,262.80
+7,500.
+18,022.53
+32,033.76
+
+
+Bear, Steams & Co. Inc.
+39 or 47
+
+STANDARD & POORS DEPOSITORY
+RECEIPTS (SPDRS) (BOOK ENTRY
+SHOR UNDIVIDED BENEFICLAL INT
+02/20/02 02/14/02 SOLD
+02/20/02
+02/14/02
+02/20/02
+02/14/02 BOUGHT
+02/20/02 02/14/02 BOUGHT
+02/20/02
+"RECEIVED
+02/2170202/15/02BOUGHT
+0221702 0215/02 BOUGHT
+42,00
+"AMERICAN EAGLE OUTFITERS INC
+NEW
+EXECUTION BY JPHO
+2, 1500 01-2-02, 1500 01-17-0
+1500 01-14-0
+SIC FE 11-02, 3.01-3-02
+GADZOOKS INC
+EXECUTION BY JEFF
+yS 1500 09-04-01, 1500 08-27-0
+SEC FEE
+BEC FEE SUNWEAR OF CALFORUÄ
+XECUTION BY JPH
+S 1600 02-14-0
+EWELL RUBBERMAID IN
+OVER SHOR
+S-00 0-2001. 200 09-17-0
+COMMMISSION
+54.00
+"CANDIES INC
+"'AMERICAN EAGLE OUTITERS INC"
+NEW
+XECUTION BY RSS
+'S 1500 02-15-0
+"HOT TOPIC INC...
+EXECUTION BY WEDB
+VS 1900 02-15-02
+SYMBOLCUSIP
+SPY
+AEOS
+GADZ
+*PSUN
+"AND
+"AEOS
+027
+QUANTITY
+-700
+111.86000
+9,400
+3,000
+*900
+*3,389
+1,900
+'25. 03650"
+15.28100
+21.22600
+28.50000
+• 24.52220
+•'20.50000
+IOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+78,243.82
+235.324.56
+45,827.31
+3.976.60
+25,719.00
+36,798.30
+*38,965.00
+
+
+40 or a7
+SETTLEMENT TRADE
+DATE
+02/21/02
+02/15/02
+ö2/210202/15/02 BOUGHT
+ö2/21/02 02/15/02
+• BOUGHT
+20/12/20
+*02/15/02
+02/22/02
+02/22/02
+*02/19/02
+02/22/02
+NAUTICA ENTERPRISES INC
+EXECUTION BY JPHO
+SE 1 - 13-01
+.15
+SYMBOL TECHNOLOGIES INC
+VS 2800 02-15-02
+COMMISSION
+140,00
+TOMMY HILFIGER CORP-ORD"
+36,00
+"NORDSTROM INC
+SECUTION BY BUCH
+VS -800 02-15-02
+OMMISSIO
+EC FE
+- 18,00
+ANNTAYLOR STORES CORF
+SEE NOTE 'S* ON BACH
+VS 2700 12-03-01
+1.88.00
+BEST BUY COMPANY INC
+VS 800 02-19-02
+DOMMISSION
+48,00
+"CHICOS FAS INC"
+XECUTION BY BUO
+S 2300 02-04-0
+COMMISSION
+SEC FEE
+1.20.00
+SYMBOLCUSIP
+NAUT
+TOM
+ANN
+*BBY
+*CHS
+027
+QUANTITY
+-700
+2,800
+600*
+800
+2,700
+13.92500
+= 8.24170
+• 1162920"
+25.86000
+40.80310
+800"
+2,300
+
+31.68580
+02/23/02:11:32 001
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+9,732.35
+23,231.76
+7,028.52
+20,624.68
+109,989.72
+55,503.00
+72,723.24
+
+
+41 or a7
+SETTLEMENT TRADE
+DATE
+02/22/02
+62/22/02 02/19/02***BOUGAT
+02/22/02
+'''0279702*S016
+20122/20
+02/22/02
+BOUGH
+02/22/02
+02/18/02 SOLD
+20122/20
+CIRCUIT CITY STORES ING
+CIRCUIT CITY GROUP
+EXECUTION BY BUCH
+VS 3100 02-19-02
+COMMISSION
+186,00
+OMMY HILFIGER "COAP-ORD
+S 4500 02-19-0
+IMMISSIO
+270.00
+AMERICAN GREETINGS CORP-CL
+SHORT
+EXECUTION BY BUCH
+VS -2100 02-19-02
+COMMISSION
+126.00
+"BUS WHOLESALE CLUB INC
+SHORT
+VS - 1000 02-19-02
+OMMISSIO
+EC FE
+-60.00
+BEBE STORES INC
+C 10 01 202. 2001-14
+SHORINDS TRUST UNIT SERIES 1
+S -1050 02Y9-02
+COMMISSION
+SEC FEB
+1.53.00
+"GAP INC
+COMMISSION
+154,00
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+69,722.53
+CRECIT AMOUNT
+• 51,791.55
+SYMBOLCUSIP
+QUANTITY
+cc
+3,100
+22.42630
+"TOM
+4,500
+" 44590*
+AM
+......2,10015.50000••
+BJ
+-1,000
+41.84330
+BEBE
+3,800
+19.93360
+"DIA
+-1,050
+98.40200
+GPS
+2,200
+12.30860
+* 28,208.57
+41,767.67
+75,762.68
+103,242.55
+27,247.92
+027
+
+
+42 0 47
+SETLEMENT TATE
+DATE
+02/22/02
+02/22/02 02/19/02$0
+02/2202
+2279(02
+02/22/02
+MONEY FUND ACTIVITY
+DATE
+MONDAY
+01/26/02
+TRANSACTKN
+ö2/01/02
+OPENINGBALANCE
+Bear, Steams & Co. Inc.
+INTERVOICE-BRITE INC
+COVER SHORT,
+S 00 0 0 80KC
+JP MORGAN CHASE & CO
+SHOUTION BY BUCK
+20-61-20 5021-00
+182.00
+RADIOSHACK CORP
+VS - 1300 02-19-02
+COMMISSION
+SEC FEE
+-58,00
+.. . .
+STANDARD & POORS DEPOSITOR
+RECEIPTS (SPDRS) (BOOK ENTRY
+UNITS UNDIVIDED BENEFICIAL IN
+VS -900 02-19-02
+COMMISSION
+54,00
+SYMBOL/GUSP
+INTV
+SPY
+QUANTITY
+900
+1,700
+1,300
+-900
+4.50000
+29.70000
+*27.04800
+110.06000
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+4,065.00
+50,372.24
+35,068.87
+98,983.51
+SYMBOUCUSIP
+GTOXX
+QUANTITY
+1,816,670.58
+400,000
+300,000
+027
+.0000
+0000
+$-5,929,608.51
+DEBIT AMOUNT
+*300,000.00
+$6,521,682.29
+400,000.00
+
+
+43 o1 a7
+Bear, Steams & Co. Inc.
+New York. New York 10179
+MONEY FUND ACTIVITY (continued)
+DATE
+MODAY
+02/08/02
+02/12/02
+02/13/02
+BOUGH
+02/15/02
+BOUGH
+02/2402
+"DIVIDEND
+DOMEST PRIME PORTOLID
+"DOMEST REPORTFOO
+MONTHLY DIVIDEND
+ö2/24/02
+"DIVIDEND
+02/24702REINVEST
+MONTHLY DIVIDEND
+MONTHLY DIVIDEND REINVESTED
+ö2/21102
+'''REINVEST
+MONTHLY DIVIDEND REINVESTED
+CLOSINGBALANCER
+02/22/02
+
+MOVADO GROUP INC
+DIV CHG
+2100 SHS SHORT
+REC 01/17/02 PAY 01/31/02
+SYMBOUCUSIP
+MOV
+SYMBCUCUSIP
+GIDXX
+GTXX
+QUANTITY
+QUANTITY
+200.000
+-600,000
+300,000
+200,000
+731.36
+1,135.44
+1,818,537.38
+RATE (S)
+027
+1.0000
+0000*
+1.0000
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+200,000.00
+600,000.00
+300,000.00
+200,000.00
+731.36
+7,135.44
+731.36
+1,135.44
+$-1.001,866.80
+$1.001.866.80
+DEBIT AMOUNT
+63.00
+
+
+44 of 47
+DIVIDENDS (continued)
+
+STANDARD & POORS DEPOSITORY
+8250 SHS SHORT
+REC 12/26/01 PAY 01/31/02
+02711/02 MASCO COPP.....
+REC 01/11/02 PAY 02/11/02
+02/11/02
+'''ALBERTSONS INC*..*
+1900 SHS SHORT
+02/17702
+'DIAMONDS TRUST-UNIT SERIES T
+DIV CHG
+14300 SHS SHORT
+REC 01/23/02 PAY 02/11/02
+02/15/02 "TANGER FACTORY OUTLET CENTERS
+REC 01/31.02 PAY 02/15/02
+02/15/02
+''HASBRO INC......*
+DIV CHG
+1500 SHS SHORT
+REC 02/01/02 PAY 02/15/02
+0279/02
+DEB SHOPS INC
+REC 01/31/02 PAY 02/19/02
+INTEREST
+DATE
+02/21/02
+INT CR
+FEB 02
+SYMBOL/CUSIP
+SPY
+'''MAS
+DIA
+HAS
+- DEBS
+SYMBOUCUSIP
+QUANTITY
+RATE (S)
+'2,4000.1350
+4,000
+9,900
+•0.6100
+0.0750
+QUANTITY
+RATE (%)
+027
+DEBIT AMOUNT
+3,240.35
+361.00
+1,267.12
+45.00*
+$-4.976.47
+DEBIT AMOUNT
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+324.00
+,440.0
+$3,506.50
+1,279.12
+$1,279.12
+
+
+45 or 47
+MISCELLANEOUS
+DATE
+MO/DAY
+RANSACTION
+01/28/02
+OURNAL
+01/28/02
+JOURNAL"
+02/01/02
+JOUANAL
+JOURNAL"
+JOURNAL,
+020702 JOUANAL*
+ö2/11702
+62/11702
+02/19/022
+02/21/02
+0221/02
+MARK TO MARKET
+"MARK TO MARKET SHORT POS
+*01/02 CLA CHE"
+27
+*''MARK TO MARKET
+"MARK TO MARKET SHORT POS
+*FROM: SIV
+12:0SB*
+• JRL*
+TO: SIV
+* JRL *
+'MARK TO MARKET
+"MARK TO MARKET SHORT POS
+"MARK TO MARKET
+'''MARK TO MARKET SHORT POS"
+'SMVCR
+SMVCR
+FEB 02
+Trades Executed Pending Settlement
+SETILEMENT
+TRADE
+DATE
+DATE
+02/25/02
+02/20/02
+02/25/02
+02/20/02
+KENNETH COLE PRODUCTIONS ING
+CLA
+"IRCUIT CITY STORES INC
+CIRCUIT CITY GROUF
+DEBIT AMOUNT
+51,037.00
+''35.00
+44,536.00
+300,000.00
+103,078:00"
+36,107.00
+1,450.43
+$-536,243.43
+SYMBOLCUSIP
+KCP
+027
+CRECIT AMOUNT
+51,037.00
+44,536.00
+*300,000:00
+103,078.00
+36,107.00
+5,569.90
+$540,327.90
+QUANTITY
+3,400.00
+800.00
+18.0986
+24.4000
+02/23/02:11:32 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+61,754.24
+19,583.00
+
+
+46 of 47
+Trades Executed Pending Settlement
+(continued)
+BETLEMENT TRIE
+02/25/02
+02/20/02
+02/25/02
+02/20/02
+02/25/02
+02/20/02
+02/25/02 02/20/02 BOUGHT
+02/25/02 02/20/02 BOUGHT
+226/02 02/21/02 BOUG
+/0
+BOUGH
+•••••.
+02/26/02
+02/21/02
+nanaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaar
+02/26/02
+02/21/02
+BOUGH
+02/26/02
+02/21/02
+02/26/02
+02/21/02
+02/26/02
+02/26/02
+02/26/02
+02/26/02
+02/27/02
+02/21/02
+02/21/02
+02/21/02
+02/21/02
+02/22/02
+02/27/02
+..........
+02/27/02
+02/22/02
+02/22/02
+FOREST LABORATORIES INC
+K-SWISS INC-CLA
+NAUTICA ENTERPRISES INC
+RADIOSHACK CORP
+TOMMY HILFIGER CORP-ORD
+AMERICAN EAGLE OUTFITERS INC
+NEW
+ANNTAYLOR STORES CORP
+BEBE STORES INC
+CHICOS FAS INC
+ENNETH COLE PRODUCTIONS IN
+CLA
+ESTEE LAUDER COMPANIES INC
+CLA
+VAUTICA ENTERPRISES INC
+JC PENNEY CO INC
+QUIKSILVER INC
+CIRCUIT CITY STORES INO
+CIRCUIT CITY GROUP
+ESTEE LAUDER COMPANIES INC
+CLA
+NAUTICA ENTERPRISES INC
+SYMBOLICUSIP
+FRX
+KSWS®
+NAUT
+RSH
+TOM
+..........
+AEOS
+ANN
+BEBE
+CHS
+KCP
+EL
+NAUT
+JCP
+*ZOK
+EL
+NAUT
+027
+QUANTITY
+,400.00
+600.00
+600.00
+1,900.00
+,800.00
+2,900.00
+-1,300.00
+........
+800.00
+2,100.00
+......
+1,600.0
+1,300.00
+-2,000.00
+-3,500.00
+3,100.00
+.. . .
+2,300.00
+1,500.00
+-1,800.00
+79.5000
+31.8500
+13.6600
+27.3656
+11.5249
+•'25.6075
+40.9107
+21.5000
+32.9378
+..........
+18.651:
+29.7500
+3.7459
+20.9529
+9.5085
+....
+16.2467
+29.3954
+13.5187
+02/23/02:11:32 001
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIO January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+111,399.00
+1.125.0
+8,180.87
+2,123.6-
+20,867.82
+74,276.75
+53,090.11
+17,215.00
+69,027.34
+29,952.92
+38,768.00
+27,476.38
+73,109.04
+60,677.35
+.... ..
+37,520.41
+3,987.4
+24,318.29
+
+
+47 of 47
+Trades Executed Pending Settlement
+(continued)
+SKECHERS USA INC
+SYMBOLICUSIP
+SKX
+QUANTITY
+3,300.00
+13.9169
+LEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+DEBIT AMOUNT
+46,138.77
+$589,401.90
+$299,189.46
+The above trades do not appear in arry other section of this statement.
+STOP
+****** End of Statement******
+027
+
+
+lear, Steams & Co. Inc
+83 Madison Avenu
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+What's In This Statement
+Financial Summary •••••••••••••••••//•III I''
+Your Portfolio Holdings
+Transaction Detail ..............................
+Fund Activity.......
+Trades Not Yet Settled
+3
+4
+10
+42
+46
+INTERNATIONAL CHARITABLE
+INTERESTS | 2/28/94
+C/O FINANCIAL TRUST COMAPNY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+Market Value of Your Portfolio
+$7.068.313
+$10,076,713
+15,023,132
+5,251,643
+1.816.670
+$22,091,445
+21,127,381
+964,064
+Cash & Equivalent -
+Equities -
+$19,206,063
+: S-4,182,931
+$15,373,236 : $-4,322,568
+Current market value
+Last statement's market value
+Short market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+SIP The suremen s foul ratanal purger red de Set revere dise for portant iformation.
+
+
+2 of 47
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 of 47
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Funds Deposited
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Money Fund
+Funds Withdrawn
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+THIS PERICO
+55,664.267.63
+5,169,957.72
+3,404,224.98
+26,387.82
+3,465.33
+7,846,674.89
+....
+16,450.710.7
+.. . .
+-8,160,124.46
+-804,224.98
+-52,775.64
+-3,997.66
+-7,842,
+S-16.863.335.70
+-412,624.96
+Closing Balance.
+$5,251,642.67
+Same day tansfers of cash between accourt types are not included in this
+section; such transfers, as well as dotalls for all other transactions this poriod,
+appaar in Transaction Detail.
+Cash Balance Summary
+Margin
+Short
+Net Cash Balance
+OPENING
+1,290,647.87
+4,373,619.76
+$5,664,267.63
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+Short Dividends
+THIS PERIOD
+3,606.80
+1,529.83
+55.136.63
+3,997.66
+Portfolio Composition
+SHORT
+Cash/Cash Equivalent
+Equities
+Total
+4,182,931
+$4,182,931
+027
+CLOSING
+1,119,750.47
+4,131,892.20
+$5,251,642.67
+YEAR TO DATE
+3,606.80
+1,529.83
+......
+$5,136.63
+-3,997.66
+LONG
+7,068,313
+19,206,063
+526.274376
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent
+24%
+Short Equities
+13%
+Equities
+63%
+Unshaded portions denote debit balance and or shart
+from the absolute market value of your portolio.
+
+
+4 of 47
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+THE TREASURERS FUNDING
+DOMESTIC PRIME MAM PORTFOLIO.
+THE TREASURERS FUNDING
+DOMESTIC PRIME MIM PORTFOLIO
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AMDOCS LIMITED
+AMERICAN EAGLE OUTFITTERS INC
+NEW
+ALLOY INC
+(FRM ALLOY ONLINE ING)
+ACTION PERFORMANCE COMPANIES
+INC
+B88....
+ALBERTSONS INC
+.. . .
+ANNTAYLOR STORES CORP
+... .
+APOLLO GROUP INC-CLA
+.. . .
+BROWN SHOE COMPANY
+. . . .
+BE STORES IT
+JOSEPH A BANK CLOTHIERS INC
+BEST BUY COMPANY ING
+SYMBOLCUSIP
+GTOXX
+GTDXX
+QUANTITY
+•:521,770.35
+1,294,900.23
+1.0000
+1.0000
+SYMBOUCUSIP
+DOX
+AEOS
+ALOY
+ACTN
+ABS
+•....
+ANN
+1.......
+APOL
+....
+BWS
+.....
+BEBE
+JOSB
+.....
+BBY
+SHRT
+MRGN
+MAGN
+SHRT
+SHRT
+....
+MRGN
+SHRT
+MAGN
+SHRT
+MRGN"
+MAGN
+QUANTITY
+-900
+16,800
+4,600
+900*
+-1,900
+-•..
+11,100
+-1,050
+.......
+15,600
+......
+3,800
+*••••••••••
+10,600
+2,000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+MARKET
+VALUE
+5,251,643
+521,770
+1,294,900
+$7,068,313
+ESTIMATED
+ANNUAL INCOME
+9,392
+1,8000
+.......
+23,308 1.8000
+$32,700
+37.1000
+28.0200
+19.7400
+35.0000
+29.9900
+... .
+36.5300
+44.3400
+....
+15.5000
+3.4500
+'7.0700
+72.1900
+MARKET
+VALUE
+-33,390
+470,736
+90,804
+31,500
+-56,981
+.. ..
+405,483
+-46,557
+241,800
+89,110
+74,942
+144,380
+027
+ESTIMATEC
+ANNUAL INCOME
+CURRENT
+YIELD (%)
+-1,444
+1240
+2.5342
+2.5806
+
+
+5 or 47
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+BORDERS GROUP INC
+.. . . .
+COLDWATER CREEK INC
+CHILDRENS PLACE RETAIL STORES
+INC
+COSTCO WHOLESALE CORP-NEW
+COLUMBIA SPORTSWEAR CO
+.. ...
+CHRISTOPHER & BANKS CORP
+COACH INC
+CHARLOTTE RUSSE HLDG INC
+CANDIES INC
+CACHE INC NEW
+CHICOS FAS INC
+.......
+CATO CORP CLA
+CHARMING SHOPPES INC
+KENNETH COLE PRODUCTIONS INC
+DIAMONDS TRUST-UNIT SERIES 1
+DAIMLERCHRYSLER AG.
+COM
+DELA'S CORP
+DIRECT FOCUS INC
+DEB SHOPS INC
+EASTMAN KODAK CO
+ECOLAB INC
+SYMBOLCUSIP
+BGP
+CWTR
+•*******
+PLCE
+COST
+COLM
+........
+CHBS
+COH
+CHIC
+CAND
+CACH
+CHS
+CACOA
+CHRS
+KCP
+DIA
+DCX
+DLIA
+DEXI
+DEBS
+EK
+ECL
+MRGN
+.......
+IRGN
+••••••••••••
+MRGN
+MAGN
+MRGN
+SHRT
+MRGN
+MAGN
+SHAT
+MRGN
+......
+MRGN
+MAGN
+SHAT
+SHRT
+SHRT
+MRGN
+SHAT
+SHRT
+QUANTITY
+7,100
+28,200
+6,400
+7,400
+2,300
+13,850
+2,700
+77,900
+20,100
+4,050
+2,700
+.....
+4,100
+2,600
+-14,300
+-800
+3,300
+2,600
+9,900
+-2,100
+-400
+23.3400
+16.6800
+... . .
+32.0000
+44.2000
+33.7300
+32.8000
+44.2900
+9.1200
+2.3900
+6.0500
+29.5500
+20.3500
+5.3100
+17.2000
+98.4800
+41.1000
+6.7600
+36.5000
+5.540
+28.5600
+11.9300
+165,714
+26,688
+902,400
+282,880
+249,602
+-75.440
+613,417
+51.624
+186,181
+121.
+605
+119,678
+54,945
+21,771
+44,720
+1,408,264
+-32,880
+-22,308
+94,900
+52,841
+-59,976
+-16.772
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+ANNUAL NOTO
+CURRENT
+YELD IN
+.......
+.....
+.....
+.. . ..
+1,458
+2.6536
+23,595
+- 1,662
+1.6755
+... ..
+5.0547
+2970*
+3,780
+5 6022
+:1746
+..........
+....
+216
+.287
+
+
+6 of 47
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+EDO CORP
+FOOTSTAR INC
+DUNDRY NETWORKS IN
+SOT LOCKER IN
+FAMILY DOLLAR STORES INC
+FEDERATED DEPARTMENT STORES
+INC-DEL
+FINLAY ENTERPRISES INC
+FOSSIL INO
+FLEMING COMPANIES INC
+GADZOOKS INC
+....
+GUITAR
+'ER INC
+....
+GART SPORTS CO
+GI APPAREL GROUP LTD
+GERBER CHILDRENSWEAR INC
+GAP INC
+....
+GENUINE PARTS CO
+GYMBOREE CORP
+HOT TOPIC INC
+HEARX LTD
+COM NEW
+I-MANY INC
+HEAD NI
+NY REGISTRY
+.....••......
+SYMBCLCUSIP
+EDO
+FTS
+FDRY
+FDO
+FNLY
+FOS
+FLM
+GADZ
+GTRO
+......
+GATS
+GIII
+GYMB
+.....
+HOTT
+EAR
+IMNY
+.....
+HED
+SHRT
+......
+MRGN
+••••••••••••
+SHRT
+.. . .
+SHRT
+MRGN
+MRGN
+MRGN
+SHRT
+MAGN
+MAGN
+MRGN
+MAGN
+.......
+MAGN
+......
+SHRT
+MAGN
+ARGN
+MAGN
+MAGN
+QUANTITY
+-1,700
+... ..
+5,700
+-3,900
+..**.-.
+51,400
+-1,100
+•••••••••••••
+14,300
+28,900
+14,200
+900
+13,000
+13,650
+2,600
+.......
+48,450
+3,900
+......
+- 2,200
+... ..
+-2,700
+-3,000
+26,450
+23,700
+3,700
+•......
+12,500
+24.5000
+......
+23.2000
+.. .
+8.0100
+14.1100
+1.8000
+0.400
+9.7700
+20.5400
+18.9800
+14.5000
+15.9000
+22.9900
+7.0500
+.600
+4.5300
+.......
+34.7400
+14.2500
+33.3500
+.....
+1.1000
+8.6000
+3.3100
+MARKET
+VALLE
+-41,650
+132,240
+-31,239
+25,25
+-34,980
+577,720
+282,353
+291,668
+-17,082
+188,500
+217,035
+59,774
+341,573
+45,540
+-31,966
+-93,798
+42,750
+882,108
+26,070
+31,820
+41,375
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+ESTIMATED
+ANNUAL INCOME
+-204
+CURRENT
+YIELD (S
+0.4898
+_____-..
+-286
+0.8176
+-72
+0.4215
+- 196
+-3,078
+2,300
+0.6132
+3.2815
+5.5589
+
+
+7 of 47
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+HASBRO INC
+HUMANA INC
+INTERVOICE-BRITE INC
+... ..
+NES APPAREL GROUP I!
+K-SWISSING-CLA.
+KELLWOOD 0.
+......
+KOHLS CORP
+KROGER CO
+.. . .
+ESTEE LAUDER COMPANIES INC
+CL A
+LEXMARK
+INTERNATIONAL INC
+CLA
+.....
+LINENS N THINGS INC
+.. . . .
+LVMH MOET HENNESSY LOUIS
+VUITTON-SPONSORED ADR
+LEGGETT & PLATT INC
+LIZ CLAIBORNE INC
+MOVADO GROUP INC
+MEMBERWORKS INC
+MARTHA STEWART LIVING
+OMNIMEDIA INC CL A
+STEVEN MADDEN LTD
+MAXWELL SHOE COINCLA
+MASCO CORP
+MICHAELS STORES INC
+SYMBOLCUSIP
+HAS
+HUM
+......
+INTV
+INY
+KSWS
+....
+KWD
+KSS
+KR
+EL
+LXK
+LIN
+LVMHY
+LEG
+LIZ
+MOV
+MBRS
+MSO
+SHOO
+MAXS
+MAS
+MIK
+ACCT
+SHRT
+....
+SHRT
+••••••••••••
+SHRT
+•.••.
+MRGN
+•*••••••••••
+SHRT
+MRGN
+SHRT
+SHAT
+SHAT
+SHAT
+.......
+SHRT
+SHAT
+MAGN
+SHAT
+SHAT
+SHRT
+MRGN
+MAGN
+SHRT
+QUANTITY
+- 1,500
+-1,000
+....
+-1,400
+......
+6,600
+......
+8,000
+-5,700
+6,300
+1,000
+-900
+-1,300
+1,800
+-6,500
+-1,000
+41,400
+......
+-2,100
+-800
+-2,000
+10,700
+......
+2,200
+2,400
+- 1,500
+16.3400
+12.9100
+9.5600
+......
+32.9800
+36.7600
+22.9900
+66.3400
+20.7100
+35.0200
+53.8500
+28.7400
+8.3200
+24.0200
+26.3000
+18.6500
+16.6200
+16.3800
+16.4000
+16.7400
+26.8500
+33.4100
+MARKET
+VALUE
+-24,510
+-12,910
+-13,384
+217,668
+294,080
+-131,043
+417,942
+20.71
+-31,518
+-70,005
+-51,732
+-54,080
+-24,020
+.....
+1,088,820
+-39,165
+-13,296
+-32,760
+175,480
+04,22
+64,440
+-50,115
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+ESTIMATED
+ANNUAL INCOME
+CURRENT
+YIELD IS
+0.7344
+_____-..
+480
+-3,648
+0.1632
+2.7838
+....
+-180
+0.5711
+-709
+-480
+9,315
+-252
+1.3110
+9983
+•••••••••
+0.8555
+0.6434
+1,296
+2.0112
+
+
+8 of 47
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+NOVEL DENIM HOLDINGS LTD
+NEWELL RUBBERMAID ING
+NAUTICA ENTERPRISES INC
+POLO RALPH LAUREN CORP-CLA
+PACIFIC SUNWEAR OF CALIFORNIA
+INC
+....
+OSHKOSH B GOSH INC CL A
+QUIKSILVER INC
+RESTORATION HARDWARE INC DEL
+RADIOSHACK CORP
+REEBOK INTERNATIONAL LTD
+ROSS STORES INC
+SAKS INC
+... . .
+SKECHERS USA INC
+CLA
+.. .
+SAFEWAY INC
+SMUCKER JM CO
+SIX FLAGS INC
+STAGE STORES INC
+NEW
+SEARS ROEBUCK & 00
+SHARPER IMAGE CORP
+..••....
+SHOPKO STORES INC
+_____-..
+SHOE CARNIVAL INC-IND
+SYMBCLCUSIP
+NVLD
+NWL
+NAU
+RL
+PSUN
+GOSHA
+ZOK
+RSTO
+RSH
+RBK
+ROST
+SKS
+SKX
+SWY
+SJM
+PKS
+STGS
+SHRE
+SKO
+SCVL
+MRGN
+......
+SHRT
+*******•
+ARGN
+MRGN
+SHAT
+MRGN
+MAGN
+SHRT
+MAGN
+MAGN
+SHRT
+.......
+MRGN
+SHAT
+....
+SHRT
+....
+SHAT
+MRGN
+SHRT
+SHRT
+............
+MRGN
+QUANTITY
+32,650
+....
+-1,700
+18,700
+•••••*••••
+32,400
+....
+2,101
+-800
+28,900
+36,071
+1,800
+6,200
+6,300
+4,500
+23,300
+-900
+1,700
+-1,900
+21,500
+-10,150
+14,800
+-7,300
+18,800
+11.0000
+27.5500
+... .
+13.8400
+....
+27.7100
+23.0000
+41.8200
+18.2100
+0.1000
+30.2200
+28.8800
+34.9700
+I0.1900
+15.8800
+40.0900
+32.5000
+.. . .
+16.0800
+25.3500
+51.7500
+10.5600
+10.2500
+14.3500
+MARKE
+JALUE
+359,150
+-46,835
+258,808
+397,804
+278,300
+-33,456
+526,269
+364,317
+-54,396
+179,056
+220,311
+-45,855
+370,004
+-36,081
+-55,250
+-30,552
+545,025
+-525,263
+156,288
+- 74,825
+269,780
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+ANNUAL NOTE
+CURRENT
+YIELD (S
+1,428
+.......
+3.0490
+---__..
+....
+1920.5739
+0.5739
+-396
+0.7280
+1,071
+0.4861
+-1,088
+9,338
+1.9692
+1.7778
+
+
+9 of 47
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+STRIDE RITE CORP
+SYMBOL TECHNOLOGIES ING
+SYNCOR INTERNATIONAL CORP-DEL
+TAX COMPANIES IN T
+TANGER FACTORY OUTLET CENTERS
+INC
+ALBOTS IN
+TIMBERLAND CO-CLA
+OMMY HILFIGER CORPOR
+TRACTOR SUPPLY CO
+UNITED RETAIL GROUP INC
+UNITED STATIONERS INC
+URBAN OUTFITERS INC
+WILSONS LEATHER EXPERTS INC
+WHOLE FOODS MARKET INC
+WET SEAL INC-CLA
+....
+ZALE CORP NEW
+ZEBRA TECHNOLOGIES CORP-CL A
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+SRR
+SBL
+SCOR
+TJX
+SKT
+TLB
+TBL
+TOM
+TSCO
+URG
+USTR
+URBN
+WLSN
+WEMI
+WISLA
+ZBRA
+MRGN
+.......•....
+MRGN
+••••••••••••
+SHRT
+....
+IRGN
+ARGN
+MRG*
+MRGN"
+MAGN
+SHRT
+MAGN
+SHAT
+.....
+SHRT
+SHAT
+MAGN
+MAGN
+SHAT
+QUANTITY
+5,000
+......
+5,000
+... .
+- 2,300
+2,800
+4,000
+13,750
+6,25
+36,250
+-900
+35,500
+-2,300
+1,700
+... ..
+3,700
+450
+4,20
+10,800
+-1,400
+6.9900
+15.8800
+28.2500
+40.0000
+23.1700
+37.4200
+38.6500
+15.2000
+37.4000
+6.9500
+37.4200
+6.000
+4.000
+41.5600
+26.5900
+
+52.7300
+MARKET
+VALUE
+34,950
+79,400
+-64,975
+....
+112,000
+92,680
+514,525
+014,563
+551,000
+-33,660
+246,725
+86,066
+44,200
+51,800
+18,702
+09,378
+474,228
+-73,822
+$15,023,132
+$15.023,132
+027
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+ESTIMATE
+CURRENT
+NNUAL INCOM
+YIELD (S
+1,000
+2.8612
+... ..
+100
+0.1259
+.....
+504
+9,760
+).4500
+... .
+10.5309
+4,400
+).8552
+$-11,530
+$-11,530
+
+
+10 or 47
+Bear, Steams & Co. Inc.
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TATE
+01/02/02
+12/27/01
+' 227781 BOUGHT
+01702702*12/27781*3008A1
+01703/02
+12/28/01
+VOVEL DENIM HOLDINGS LTD
+VS 900 12-27-01
+COMMISSION
+18,00
+
+VS 800 2 27-01CK
+DOMMISSION
+48,00
+"NOVEL DENIM HOLDINGS LTD
+EXECUTION BY REDI
+VS 500 12-28-01
+COMMISSION
+10.00
+"SHAP
+NVLD
+$21,170
+$22,091,444
+QUANTITY
+900
+1,900
+"800
+11.11200
+• :73008"
+5: 13000
+500
+m1.22910
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+10,033.80
+22,302:00
+28,187:00
+5,639.55
+
+
+11 or 4
+SETTLEMENT TRADE
+DATE
+DATE
+01/03/02
+12/28/01
+6163/02* 72/28/01***BOUGAT
+01/03/02
+*12/2801
+01703/02
+
+01703/02
+
+Bear, Steams & Co. Inc.
+SKECHERS USA INC
+VS 80012-28-01
+COMMISSION
+48,00
+'STAGE STORES INC**
+NEW
+75,00
+"SHARPER IMAGE CORP
+15 800 12 2Y 90KC
+"WILSONS LEATHER EXPERTS INC
+EXECUTION BY JEFF
+VS 2400 10-05-01
+SEC FEE
+.41
+"DAIMLERCHRYSLER A.G.
+SYMBOLCUSIP
+SKX
+"STGS
+"SHAP
+NSTM
+*SCX
+01/03/02 12728/0100GHT
+01703/02
+12/28/01
+"BOUGHi
+COMMISSION
+56.00
+**•****•***••••••*••••••••••••••••''*ECL**
+COVER SHORT,
+5 40011-2200
+COMMISSION
+28,00
+MINNESOTA MINING & MFG CO
+COUNT MACO
+S -200 10-15-0
+OMMISSIO
+14,00
+QUANTITY
+800
+2,500
+.008.
+-2,400
+*800
+14.58530
+22-62440
+11.90500
+"M.13160
+42.40770
+**•••**•*•••••••**400
+п****•*•**40.04350****••••*•••*16,060:40****
+200
+"120.07500"
+24,044.00
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+11,731.24
+'''$6,657.00
+9.539.00
+26,700.43
+33.997.16
+027
+
+
+12 or 47
+SETTLEMENT TRADE
+DATE
+01/03/02
+12/28/01
+Bear, Steams & Co. Inc.
+01/03/02*12/28/01"BÖÜGHT
+01703/02
+12/28/01
+BOUGH
+81704/02
+12/31701
+12/31701
+
+
+BÖUGHT
+POTASH CORP OF SASKATCHEWAN
+WITH RIGHTS TO PURCHASE COMMON
+K UNDER CERTAIN CIRCUMSTAN
+OMMISSION
+"RYLAND GROUP ING
+9,00
+24.00
+"STANLEY WORKS"
+WITH RIGHTS TO PURCHASE PREFRD
+K UNDER CERTAIN CIRCUMSTANO
+OVER SHO
+ES -400 10-0-UC
+OMMISSION
+24.00
+"BROWN SHOE COMPANY
+V 1300 1231-014
+DOMMISSION
+78.00
+ALDRENS PLACE FREIAL STORES"
+EXECUTION BY JPHO
+VS 5800 12-31-01
+COLUMBIA" SPORTSWEAR CO"
+95901231-0KG
+CANDIES INC
+EXECUTION BY REDI
+VS 2100 12-31-01
+COMMISSION
+42,00
+SYMBOLGUSIP
+POT
+RYL
+SWK
+BWS
+"COLM
+"CAND
+027
+QUANTITY
+150
+60.94000
+*400
+= 7500250"
+400
+46.67610
+1,300
+5,800
+900
+2,160
+16.39710
+27.32350
+33.62000
+1.87800
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+9,165.00
+30,040.00
+18,709.44
+21,409.23
+158,491.30
+30,273.00
+4,000.80
+
+
+13 or 47
+SEEMENT TRIE
+01/04/02
+DATE
+12/31/01
+01/04/02 12731701 BOUGHT
+12731701 BOUGHT
+ö1/04/02
+12/31701
+*BOUGHT
+ö1/04/02
+12/31701
+01/04/02
+12/31/01
+01/04/02
+12/3101
+
+*12/31/01
+
+2/3101
+Bear, Steams & Co. Inc.
+FOOT LOCKER INC
+AS OF 12/31/01
+"FEDERATED DEPARTMENT STORES
+INC-DEL
+C04003231-01
+24.00
+"FINLAY ENTERPRISES INC
+XECUTION BY SLK
+S 3000 12-31-0
+"FOSSILINC..*
+
+"GUITAR CENTER ING
+EXECUTION BY NITE
+VS 4000 12-31-01
+HOT TOPIC INC****
+EXECUTION BY SSH
+VS 1900 12-31-01
+"JILL GROUP INC
+XECUTION BY SLK
+S 700 12-31-0
+NOVEL BENIM HOLDINGS LID*
+EXECUTION BY REDI
+: 1600 12-31-1
+IMMISSIO
+32,00
+NAUTICA ENTERPRISES INC
+
+*PACIFIC SUNWEAR OF CALIFORNIA
+SYMBOLCUSIP
+FD
+FOSL
+"GTRC
+"LL"
+'NVLD
+NAUT
+*PSUN
+027
+QUANTITY
+6,200
+400
+15.83890
+* 40.45470
+*3,000
+2,400
+4,000
+1,900
+700
+1.600
+1,000
+9.08910
+00t2t1z
+= 13.67640
+*31.97000"
+E21.5500
+#1:18570
+12.80000
+20.16130
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+98,635.18
+16,220.88
+27,282.30
+
+54,720.60
+'60,758.00
+15,373.50
+17,944:12
+19,215.00
+20,176.30
+
+
+14 or 47
+SETTLEMENT TRADE
+DATE
+01/04/02
+12/31/01
+01764782"T2737781*S0LB"
+:*12737701BOUGHT"
+12/31701
+*SOLD
+12/31701
+01/04/0212/31/01BOUGHT
+12/31701
+"BOUGHi
+Bear, Steams & Co. Inc.
+SHARPER IMAGE CORP
+EXECUTION BY SCHB
+VS 2800 12-31-01
+"WILSONS LEATHER EXPERTS "INC"
+510010-050
+"CHEESECAKE FACTORY INC
+GOES MONT
+VS -900 10-24-01
+DIAMONDS TRUST-UNIT SERIES 1
+EXECUTION BY MLCO
+VS -8900 12-31-01
+COMMISSION
+23.00
+SEC FEE
+13,5
+FOUR SEASONS HOTELS INC
+COME SHOT SHARES.
+ES 850 1-20-0
+COMMISSION
+51.00
+COVER SHORT.
+48,00
+NORDSTROM INC
+5. 900010-1-01 11500 110-1
+1, -900 10-17-01
+1, -700 09-24-01, -1500 10
+01, -500 09-19-0
+-600 09-1
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+32,569.20
+19,324.82
+SYMBOLCUSIP
+SHAP
+WLSN"
+"CAKE
+DIA*
+QUANTITY
+2,800
+:1,000
+*900
+8,900
+850
+11.62650
+* 1:34000
+* 34.75000
+101.29150
+46.92300
+*31,290.00
+39,950.55
+*..•***•••••••**800
+*********57:30790****••••••** 45.909.32****
+12,100
+20.41960
+247,818.16
+900,842.84
+027
+
+
+15 or 47
+SETTLEMENT TRADE
+01/04/02
+
+01764/02 12/31701 BÖUGHT
+Bear, Steams & Co. Inc.
+PF CHANGS CHINA BISTRO INC
+DOVER SHORT
+05 - 1500 12: 7-00
+SEARS ROEBUCK & CO
+12/31/01
+0102/02
+......
+1/07/0
+2 01/02/02
+20/40/10
+01/02/02
+01/02/02
+*BOUGHT
+8170702 8102/02B00GA1
+*STANDARD & POORS DEPOSITORY
+RECEIPTS (SPDRS) (BOOK ENTRY
+UNITS UNDIVIDED BENEFICIAL INT
+"CHILDRENS PLACE REAL STORES"
+XECUTION BY JPH
+'S 2200 01-02-0
+EUMON BY ITSWEAR CO
+AS OF 01/02/02
+"COACH INC
+5510001-02-02
+COMMISSION
+66,00
+FEDERATED DEPARTMENT STORES
+VS 800 01-02-02
+48.00
+"FINLAY ENTERPRISES INC.
+EXECUTION BY SLKG
+VS 2200 01-02-02
+SYMBOLGUSIP
+PFCB
+SPY
+"PLE
+"COLM"
+COH
+'''#NLY
+027
+QUANTITY
+5,200
+7,750
+2,200
+800
+1,700
+*800
+2,200
+48.37140
+47.99770
+116.25000
+27.92370
+33.16500
+37.82820
+•40-47500
+• 8.80000
+CLEARED THROUGH IT
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+72,572.10
+249,915.04
+901,495.00
+26,547.00
+41,692.02
+32,443.00
+"19,375.00
+
+
+16 or 47
+SETTLEMENT TRADE
+DATE
+01/07/02
+01/02/02
+ö1/ö702"01/ö2/02"BÖÜGHT
+01707/02*01/02/02 BOUGHT
+
+n'0102/02
+01/02/02 BOUGHT
+ö1707/02
+01702/02
+*''*BOUGHT"
+01707702 81/02/02 SOLD
+Bear, Steams & Co. Inc.
+01787702 81/02/02
+GUITAR CENTER INE
+EXECUTION BY GSCO
+COMSS002-02
+95,00
+JONES APPAREL GROUP INC
+XECUTION BY BUC
+/S 1000 01-02-02
+COMMISSION
+60,00
+MACE SAWEAR OF CHAUFORNIA"
+1S 10 0-0205
+•STAGE STORES INC
+"SHARPER IMAGE CORP
+ECUTION BY SCH
+S 1200 01-02-
+TIMBERLAND "CO-CLA"
+5500001-02-02
+COMMISSION
+540,00
+BUS WHOLESALE CLUB INC**
+SHEATION BY BACK
+OS MISSION -02-02
+108.00
+SEC FEE
+1.18
+BIAMONBS TAUST-UNN SERIES' T
+SHORT
+VS -400 01-02-02
+COMMISSION
+SEC FEE
+20.00
+SYMBOLCUSIP
+GIRC
+"SUN
+SOIS
+SHAP
+027
+QUANTITY
+1,900
+1,000
+1,100
+800
+1,200
+9,000
+1,800
+13.19430
+32.99150
+19.82000
+23.25000
+- 11.49330
+37.07050
+43.56000
+:480
+• 99:50008
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+25,179.17
+33,066.50
+21,817.00
+18,615.00
+13,806.96
+334,189.50
+*78,283.82
+39,760:40
+
+
+17 or 47
+SETTLEMENT TRADE
+DATE
+04707102 01702/02
+6167020172/0250LB
+Bear, Stears & Co. Ine.
+New York. New York 10179
+0107/02
+
+
+01708/02 01/03/02"BOUGHT
+89388702 81783702'BO0GH1
+01708/02 01/03/02 "BOUGHT
+K MART CORP
+CEO E 8U0K
+90,00
+LEXMARK INTERNATIONAL INC***
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+SHORT
+VS-900 01-02-02
+COMMISSION
+54.00
+TRACTOR SUPPLY CO"
+SHORT
+EXECUTION BY INET
+VS -900 01-02-02
+COMMISSION
+SEC FER
+27.00
+"UNITED STATIONERS ING
+EXECUTION BY INET
+VS -900 01-02-02
+SEC ASSION
+27.00
+AMERICAN EAGLE OUTFITTERS INC
+NEW
+ECUTION BY JP-
+5 3700 01-03-
+"ANNTAYLOR STORES COAP
+SEE NOTE "S' ON BACK
+108,00
+CHLORENS PLACE RETAIL STORES
+EXECUTION BY JPHO
+VS 2000 01-03-02
+SYMBOLGUSIP
+"USTR
+"AEOS
+"ANN
+'"PLCE"
+027
+QUANTITY
+1,800
+900°
+900
+900
+4.81250
+*'585551
+*33.95350"
+33.51260
+3,700
+1,800
+2,000
+27.12250
+35.35200
+28.42830
+LEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+8,767.50
+CRECIT AMOUNT
+52,629.79
+30,515.69
+30,718.88
+100,368.25
+63,756:60
+56,371.60
+
+
+18 of 47
+SEE MEN TRE
+DATE
+01/08/02
+01/03/02
+01708/02 01703/02 BOUGHT"
+61708/02
+'' 1/03/02 "BOUGHT
+ö1/08/02
+01/03/02
+*BOUGHT
+ö1/08/02
+01/03/02
+ö1/08/02
+01/03/02
+01208/0201/03/02
+*BOUGHT
+01/08/02
+01/03/02
+20180/10
+01703/02
+01703/02
+Bear, Steams & Co. Inc.
+FOOT LOCKER INC
+UNSOLICITED
+"FEDERATED DEPARTMENT STORES
+INC-DEL
+S 600 01-03-02
+NOISINIO
+36.00
+... ON SHOOZOND
+EXECUTION BY RHCO
+VS 900 01-03-02
+"HOT TOPIC INC***
+EXECUTION BY MONT
+VS 500 01-03-02
+JONES APPAREL GROUP ING
+VS 1700 01-03-02
+COMMISSION
+102,00
+"NAUTICA ENTERPRISES INC"
+EXECUTION BY MON
+VS 2400 01-03-03
+"PACIFIC SUNWEAR OF CALIFORNIA
+ECUTION BY RS
+:1100 01-03-
+"STAGE STORES INC
+NEW
+RECUTION BY HRZ
+S 1100 01-03-
+"TALBOTS INC.
+OSMISS00-09-02
+60,00
+"TIMBERLAND CO-CLA
+XECUTION BY BUC
+S 4700 01-03-0
+COMMISSION
+282,00
+SYMBOUCUSP
+FD
+"GADZ
+"HOTT
+NAUT
+'""SUN"
+*STGS
+027
+QUANTITY
+6,200
+600
+15.69160
+40.40000
+900
+*500
+1,700%
+2,400
+1,100
+1,100
+1,000
+4,700
+
+32.90000
+• 32.91720
+• 13.17300
+21.50000
+'23.57930
+'37.60590
+37.91060
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+97,721.92
+24,291.00"
+12,609.15
+00 995 91
+56.076.24
+OZ DES' LE
+23,665.00
+25.952.23
+37,680.90
+178,476.82
+
+
+19 or 47
+SETTLEMENT TRADE
+DATE
+01/08/02
+01/03/02
+01708/02 "01/03/02"BÖUGHT
+01709/02 01/04/02"BOUGHT
+01709/02 01/04/02 BOUGHT
+01/09102
+''01/04/02 BOUGHT
+01709/02 01/04/02"BOUGHT
+01709/02 81/04/02"BOUGHT
+01709/02 01/04/02 "BOUGHT
+8169702 81764702*BOUGAT
+WILSONS LEATHER EXPERTS INC
+EXECUTION BY JEFF
+SEC FEE 10 05-01
+.40
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+COVER SHORT,
+AMERICAN EAGLE OUTATTERS INC
+NEW
+LECUTION BY RSS
+: 1200 01-04-
+"CHILDRENS PLACE RETAIL STORES
+"COLUMBIA SPORTSWEAR CO"
+ECUTION BY MON
+: 800 01-04-0
+"FOOT LOCKER ING
+162,00
+"FINLAY ENTERPRISES INC
+EXECUTION BY WAWP
+VS 2800 01-04-02
+FOSS......
+EXECUTION BY JEFF
+VS 1600 01-04-02
+HOT TOPIC INC.*
+EXECUTION BY MONT
+VS 500 01-04-02
+SYMBOLCUSIP
+WLSN
+"AEOS
+COLM
+"FLY
+"HOT
+220
+QUANTITY
+-2,150
+12.18500
+4,500
+= 4.24200
+1,200
+* 28.73750
+1,100
+
+800
+35.50000
+2,700
+' 15.49600
+2,800
+9.15000
+'20.65590
+300
+' 3377500"
+CLEARED THROUGH IT
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+26,182.35
+19,359.00
+34,500.00****'
+*32,177.57
+28,415.00
+42,016.20
+25,635.00
+33,064.44
+16.572.50
+
+
+20 of 47
+SETTLEMENT TRADE
+DATE
+01/09/02
+01/04/02
+01709/02 01/64/02"BÖUGHT
+01709102 01704/02 BOUGHT
+01709/02 01/04/02 BOUGHT
+01/09/02
+'*01704/02"BÖUGHT
+01709/02
+'01/04/02 BOUGHT"
+Bear, Steams & Co. Inc.
+01/09/02
+'' D1/04/02
+NAUTICA ENTERPRISES INC
+EXECUTION BY MONT
+AS 24 0100-0202
+"PACIFIC SUNWEAR OF CALIFOANIA
+EXECUTION BY JPHO
+VS 1400 01-04-02
+RECHERS USA NC
+VS 2200 01-04-02
+COMMISSION
+132,00
+TIMBERLAND CO-CLA
+VS 2700 01-04-02
+COMMISSION
+162,00
+"TOMMY HILFIGER CORP ORD
+ECUTION BY BUN
+3 MISSIO.0
+84.00
+BUS WHOLESALE CLUB INC
+EE:30013/2604
+COMMISSION
+54.00
+"DIAMONDS TRUST-UNT SERIES T
+COMING BUCK
+24,00
+SYMBOLCUSIP
+NAUT
+*PSUN
+SKX
+"TOM
+BJ
+027
+QUANTITY
+2,400
+2,200
+13.77880
+'22:72900
+- 16.17780
+2,700
+900*
+400
+'38.86520
+
+40.25000
+
+CLEARED THROUGH ITE
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+33,084.12
+30,435.60
+35,592.96
+105,113.04
+20,265.86
+36,294.00
+40,983.00
+
+
+21 or 47
+SETTLEMENT TRADE
+DATE
+01/09/02
+01/04/02
+01/09/02 01/04/02 SOLD
+ö1709/02
+1/04/0
+BÖUGHT
+DELIA'S CORP
+CLA
+SECUTION BY INET
+S - 1600 01-04-0
+OMMISSIO
+SEC FEE
+- 18.00
+INTERNET SEC SYSINC
+SHORT
+EXECUTION BY INET
+VS -650 01-04-02
+COMMISSION
+SEC FEE
+39.50
+"KMART CORP
+01709/02
+"SOLD"
+01/10/02
+ö1710/02
+/01707702
+01710/02 01707/02
+"UNITED STATIONERS ING
+EXECUTION BY INET
+VS -700 01-04-02
+COMMISSION
+SEC FEB
+.31.00
+ANNTAYLOR STORES CORP
+SEE NOTE 'S' ON BACK
+EXECUTION BY BUCH
+VS 1200 01-03-02
+COMMISSION
+SEC FEE
+72.00
+"BUS WHOLESALE CLUB INC
+VS 2600 01-07-02
+COMMISSION
+156,00
+"BEBE STORES' INC
+EXECUTION BY ASSF
+VS 2500 12-24-01
+SEC FEE
+.90
+SYMBOLGUSIP
+DLIA
+"iSSX
+"USTR
+027
+QUANTITY
+-1,600
+-650
+3,500
+:700
+1,200
+2,600
+2,500
+6.46810
+35.73440
+1.08340
+35.20860
+35.95000
+42.02000
+''23:50000"
+IOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+10,285.80
+23,192.51
+14,916.24
+24,609.65
+43,052.35
+09,423.00
+59,734:10
+
+
+22 o147
+SETTLEMENT TRADE
+DATE
+DATE
+01/10/02
+01/07/02
+01710/02 01767702"BOUGHT
+01710102 01707/02 SOLD"
+01710/02
+'01707/02
+ö1/10/02
+: 01707/02 BOUGHT
+01/10/02 0107/02 SOLD
+01710/02 0107/02 SOLD"
+Bear, Steams & Co. Inc.
+BEST BUY COMPANY INC
+COMMISSIO 07-02
+96,00
+CHILDRENS PLACE RETAIL STORES
+IS 130001-07-02
+GYMBOREE CORP"
+EXECUTION BY WEDB
+VS 1600 12-17-01
+.29
+*STAGE STORES INC
+NEW
+ECUTION BY HR
+$ 1300 01-07-
+*BUS WHOLESALE CLUB INC
+VS AS 002-02
+54.00
+CHRISTOPHER & BANKS CORP
+SEC FISSION
+-27.00
+"CHICOS FAS INC"
+WITH DUE BILL SPLT 3: 2
+SECUTION BY BUCK
+VS - 1800 01-07-02
+COMMISSION
+108,00
+SEC FEE
+1.14
+SYMBOLGUSIP
+BBY
+SOIS
+"GYMB
+"CHBS
+"CHS
+QUANTITY
+1,300
+-1,600
+900
+900
+1,800
+74.47500
+28.62380
+-11.88000
+24.10000
+42.00000
+
+'42.00750
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+119,271.00
+37,225.94
+18,992.71
+*39,345.00
+37,869.00
+29,075.08
+75,489.36
+
+
+23 or 47
+SETTLEMENT TRADE
+DATE
+01/10/02
+01/07/02
+0171002 01707/02 "BOUGHT"
+ö1/11/02
+1/08/0
+*SOLD
+
+101/08/02
+
+•'''SOLD
+CLAIRES STORES INC (FLA)
+COVER SHORT,
+ES - UTO 18-16-01, 900 10-17-
+COMMISSION
+114,00
+"TOYS R USING
+COVER SHOR
+VS -900 09-17-01
+COMMISSION
+54.00
+AMERICAN EAGLE OUTFITTES INC
+EXECUTION BY JPHO
+SEC FEE 01-04-02, 30001-03-02
+BORDERS GROUP ING
+660,00
+COACH ING
+
+SO MISSION
+38.00
+"BOLLAR TREE STORES INC
+EXECUTION BY REDI
+SO 1901. 2500010401
+COMMISSION
+SEC FEE
+"GYMBOREE CORP
+EXECUTION BY WEDB
+VS 1700 12-17-01
+SEC FEE
+.30
+SYMBOLGUSIP
+CLE
+TOY
+"AEOS
+"BGP
+COH
+"BLTR
+GYMB
+027
+QUANTITY
+1,900
+15.83960
+*900
+-1,500
+11,000
+........
+-800
+3,300
+1,700
+
+29.1650đ
+0299802.
+13.3500
+29.67100
+T1.38770
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+30,224.24
+'19,781.25
+43,731.84
+0z2610Ez
+34,616.47
+97,831.83
+*19,343.79
+
+
+24 ol 47
+SETTLEMENT TRADE
+01/11/02
+DATE
+01/08/02
+61/11/02 01708/02**"BOUGAT
+
+''*01/08/02
+01/08/02
+'BOUGHT
+
+01708/02 BOUGHT
+01717702 01/08/02 BOUGHT
+
+
+KOHLS CORP
+COMe 01 00 1 2001
+SEC FEE
+"LIZ'CLAIBORNE INC'...
+WITH DUE BILL SPLT 2: 1
+CSMMISSI0-08-02
+72,00
+"PACIFIC SUNWEAR OF CALIFORNIA"
+"ROSS STORES INC
+EXECUTION BY SLKO
+/S 3200 01-08-02
+ROSS STORES INC
+5 58001-0-027
+"SKECHERS USAINC
+RECUTION BY BUC
+1S MIS 00-08-0
+90.00
+"TIX COMPANIES ING NEW
+5 130001-0-02
+78,00
+85800 0108022
+OMMISSION
+48,00
+SYMBOLCUSIP
+KSS
+"LIZ
+"PSUN"
+ROST
+ROST
+SKX
+027
+QUANTITY
+-800
+1,200
+3,200
+5,800
+1,300
+"800
+69.92790
+• 32.59050"
+21.12000
+33.83000
+33.57050
+• 1570610
+40.38700
+•*39:88120
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+55,878.48
+* 3.675.60
+31,695.00
+108,271.00
+194,723.90
+23,664.15
+52,596.10
+"31:967:98
+
+
+Bear, Steams & Co. Inc.
+25 of 47
+STENT TATE
+DATE
+01/11/02
+01/08/02
+01711702 01708/02 SOLD
+
+' 01708/02 SOLD
+0171770201708/02
+077170201/08/02
+*BOUGHI
+8777302 81708/02*SOB
+120,00
+CHAISTOPHER & BANKS CORP**
+SHORT
+EXECUTION BY INET
+COMMS SI-0-02
+27.00
+EASTMAN KODAK CO
+IS - 1300 01-08-0
+OMMISSION
+SEC FEE
+38.00
+"MAY DEPARTMENT STORES CO
+COVER SHORT,
+YS MS 924-01
+42,00
+DISA SADL
+SIR UNDER ERA CHAMSTAN
+DOVER SHORT
+XECUTION BY BUC
+3-500 09-17-01, -800 12-05-
+'UNITED STATIONERS INC
+SHORT.
+EXECUTION BY INET
+VS -700 01-08-02
+COMMISSION
+SEC FEE
+31.00
+SYMBOLCUSIP
+*CHBS
+*EK*
+MAY
+TOY
+"ÜSTA"
+027
+QUANTITY
+2,000
+900°
+-1,300
+700
+1,300
+42.70450
+- 31.95850
+28.98400
+' 37.00160
+
+:700
+*35.43000"
+LEARED THROUGH IT
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+85,544.00
+*28,72021
+37,585.63
+25,958.12
+29,422.69
+24,764.62
+
+
+26 or 47
+SETTLEMENT TRADE
+01/11/02
+DATOBIO
+0171402 01709/02 SOLD"
+01714/02
+01/09/02
+01714/0201/09/02
+01714/02 01/09/02 BOUGHT
+WILSONS LEATHER EXPERTS INC
+SHORT,
+EXECUTION BY INET
+VS -2700 01-08-02
+COMMISSION
+SEC FEE
+.51.00
+"ANNTAYLOR STORES CORP"
+SEE NOTE 'S' ON BACK
+S 600 01-03-02, 2300 12-19-0
+COMMISSION
+SEC FEE
+1.37.00
+BORDERS GROUP INC**
+VS 600 01-09-02
+COMMISSION
+36.00
+CHILDRENS PLACE RETAIL STORES
+XECUTION BY JPH
+S 2000 01-09-0
+"COACHINC....
+01/14/02
+07709/02
+48.00
+HOT TOPIC INC***
+42,00
+01714/02
+01/09/02
+KOHLS CORP
+XECUTION BY BUC
+S 100 11-30-01, 1500 12-03-0
+, 1200 11-07-01
+COMMISSION
+168,00
+SEC FEE
+2,96
+SYMBOLCUSP
+WLSN
+*BGP
+"PLCE"
+COH
+HOTT
+KSS
+027
+QUANTITY
+-2,700
+2,900
+600°
+2,000
+800*
+2,800
+12.70050
+'36.07830
+20.72500
+•'28.55830"
+33.01000
+70.27010
+LEARED THROUGH IT
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+34,194.83
+104,436.50
+12,486.00
+57,131.60
+'32,603.00
+46.271.00
+196,570.32
+
+
+27 or 47
+SETTLEMENT TRADE
+DATE
+01/14/02
+01/09/02
+ö1714/02 01709/02 SOLD
+Bear, Steams & Co. Inc.
+01714/02"
+01/09/02
+01714/02 *01:0902*SOLD
+01714/02
+01709(02
+01714/02
+'*01709/02
+NAUTICA ENTERPRISES INC
+EXECUTION BY JPHO
+SEC FEE 11-1901, 30011-2001
+ANTON PERFORANCE COMPANIES
+27:00
+CHRISTOPHER & BANKS CORP'
+SHORT
+EXECUTION BY INET
+VS -500 01-09-02
+COMMISSION
+SEC FEE
+25.00
+CHICOS FAS INC
+WITH DUE BILL SPLT 3:2
+VS -900 01-09-02
+OMMISSIO
+EC FE
+551.00
+RADIOSHACK CORP
+SHORT
+VS -900 01-09-02
+DOMMISSION
+152,00
+WILSONS LEATHER EXPERTS INC
+SHORT.
+EXECUTION BY INET
+OMISSION 09-02
+SEC FEE
+20,00
+SYMBOLICUSIP
+NAUT
+ACT
+*CHBS
+CHS
+*RSH
+WISN
+027
+QUANTITY
+-1,500
+900°
+13.57330
+33.25460
+-500*
+"900
+-900
+7,000
+32.78980
+#40.86000
+30.51000
+''12.86700
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+20,344.64
+29,886.69
+16,364.65
+36,70444
+27,389.58
+12,821.80
+
+
+Bear, Steams & Co. Inc.
+28 or 47
+SETTLEMENT TRADE
+DATE
+01/15/02
+01/10/02
+01715/02 01/10/02 SOLD
+01715/02
+01/10/02
+01/15/02
+'*01/10/02"*
+01/15/02 01/10/02*
+'BOUGHT
+01715/02
+01710/02
+01715/02
+01710/02
+*BOUGHT
+0177502"
+AMERICAN EAGLE OUTFITTERS INC
+NEW
+EXECUTION BY RSSF
+VS 3400 01-03-02, 1100 12-20-0
+SEC FEE
+3. 20 121201. 00 2 1809
+BUS WHOLESALE CLUB INC
+1552600 01-07-024
+COMMISSION
+SEC FEE
+1.66.00
+"FOOT LOCKER INC
+OS MMISS0-1002
+102,00
+KOHLS CORP'''*
+VS 1200 01-10-02
+COMMISSION
+72.00
+'LIZ CLAIBORNE INC
+WITH DUE BILL SPLT 2: 1
+COMMISSION 10-0
+NAUTICA ENTERPRISES INC
+5100011-2007
+SEC FEE
+.21
+"ROSS STORES INC"
+EXECUTION BY SLK
+VS 1000 01-10-0
+"SKECHERS'USAINE
+CLA
+(ECUTION BY BUC
+5 2300 01-10-
+COMMISSION
+138.00
+SYMBOLGUSIP
+AEOS
+'LIZ
+ROST
+*SKX
+027
+QUANTITY
+-12,500
+28.29130
+2,600
+1,700
+1,200
+1,000
+1,000
+*2,300"
+"41.46330
+15.87480
+- 68.95000
+* 2296920
+13.51500
+
+• 517170
+IOLLY OWNED SUBSIDIA
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+353,620.94
+107,631.96
+27,104.16
+82,827.00
+•'79,558.80
+13,499.79
+33,615.00
+35,047.91
+
+
+29 or 47
+SETTLEMENT TRADE
+DATE
+01/15/02
+01/10/02
+01715/02 01/10/02 SOLD
+61/15/02 "01/10/02 BOUGHT.
+01715/02 01710/02 "BOUGHT
+01715/02
+01715/02
+*01/10/02
+07710/02
+*SOLD
+81715/02 01710/02 SOLD
+01716/02 0771702
+''*BOUGHT
+Bear, Steams & Co. Inc.
+TIMBERLAND CO-CLA
+ECUTION BY ML
+MISSON 10-
+399,00
+WET SEAL INC-CLA
+EXECUTION BY INET
+VS 800 01-10-02
+COMMISSION
+24.00
+OVER SHO
+ECUTION BY BUO
+VS - 1900 10-23-01, -600 12-06
+01, -1500 11-27-01
+OOMMISSION
+240,00
+1-BOOCONTACTS INC
+COVER SHORT
+EXECUTION BY NITE
+VS-2000 12-07-01, -1900 11-15
+RADIOSHACK CORP
+SXECUTION BY BUCK
+VS -900 01-10-02
+SEC MISSION
+51.00
+"SEARS ROEBUCK & CO"
+SHORT TED
+AMERICAN EAGLE OUTFIES INC
+EXECUTION BY JPHO
+VS 2400 01-11-02
+SYMBOLCUSIP
+TBL
+TOM
+WTSLA**
+"GPS
+"CTAC
+RSH
+"AEOS
+027
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+223,313.07
+21,424.83
+QUANTITY
+5,700
+39.10510
+* 15.37440
+800
+-26.80200...
+*4,000
+16.73330
+3.900
+12.51500
+900*
+29.68280
+21,480.60
+67,188.20
+48,823.50
+26,644.93
+6,350
+2,400
+'''51.14000
+27:10900
+324,289.62
+65,076.60
+
+
+30 or 47
+SETTLEMENT TRADE
+DATE
+01/16/02
+01/11/02
+Bear, Stearns & Co. Inc.
+01716/02 01711/02 "BOUGHT
+01/16/02
+
+01716/02
+*01/11/02
+01716/02
+
+01716/0201/71/02 SOLD
+01716/02"
+''01711/02 S0L
+89798702 81779702'5008
+ANNTAYLOR STORES CORP
+SEE NOTE 'S' ON BACK
+0-61-21 008 S
+SEC FISSION
+18.00
+"BEST BUY COMPANY INC
+0010001-11-02
+24,00
+"BORDERS GROUP INC
+(ECUTION BY BUC
+5 2900 01-08-
+COMMISSION
+SEC FEB
+974.00
+"HOT TOPIC INC
+EXECUTION BY MONT
+VS 500 01-04-02, 300 01-09-02
+SEC FEE
+"JILL GROUP INC
+EXECUTION BY SLKC
+VS 700 12-31-01, 200 12-11-01
+SEC FEE
+NAUTICA ENTERPRISES...
+EXECUTION BY NITE
+SEC FE 1-20-01, 400 01-04-02
+SEC FEE
+"PACIFIC SUNWEAR OF CALIFORNIA"
+EXECUTION BY RSSF
+VS 800 01-04-02
+SEC FEE
+.27
+"HOSS STORES INC"
+EXECUTION BY SBSH
+VS 800 01-08-02
+SEC FEE
+.40
+SYMBOL/GUSP
+ANN
+"BBY
+"BGP
+JILL
+*PSUN
+HOST
+027
+QUANTITY
+-800
+*400
+2,900
+800°
+900°
+1,300
+-800
+800
+35.75000
+7324800"
+21.47860
+33.79000
+20.92000
+# 13.62000*****
+''22 15000
+' 3273330"
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+28,536.57
+• 29,338.20
+
+27,016.59
+18,812.71
+17,690.73
+17,704.73
+*26,171.24
+
+
+31 01 47
+SETTLEMENT TRADE
+DATE
+01/16/02
+01/11/02
+01716/02 01719702 SOLD
+01/16/02 *01/11/02*SOLD
+01716/02
+"SÖLD"
+01716/02 01/11/02
+*SOLD
+Bear, Steams & Co. Inc.
+20191/10
+
+TIMBERLAND CO-CLA
+EXECUTION BY BUCH
+COMMISSION 11-02
+102,00
+SE FISSION
+SEEN 2300
+VS 1800 01-08-02
+COMMISSION
+108.00
+1.16
+"FOUNDRY NETWORKS INC
+COMMISSION
+SS OF 01/1102
+GYMBOREE CORP
+SECTION BY INET
+VS - 1800 01-11-02
+517:00
+51.00
+MART CORP
+COMMIS 502-05-01
+81.00
+SYMBOLCUSIP
+TBL
+TOM
+2C
+FDAY
+GYMB
+027
+QUANTITY
+1,700
+39.34160
+-700
+15.37000
+1,800
+* 42.92000
+3,900
+8.55560
+1,800
+12.93560
+2,700
+*3.12670
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+66,997.72
+10,701.83
+• 77,131.84
+33,23433
+23,214.73
+8,538.09
+
+
+32 o147
+SETTLEMENT TRADE
+DATE
+01/16/02
+01/11/02
+01716/02 01711/02 SOLD"
+01/16/02
+01/11702
+01/17/02 01/14/02 BOUGHT
+01717702 "01794/02"BOUGHT
+0171770201714/02 BOUGHT
+ö1777702 *87714702*SOLB
+LINENS THINGS ING
+SHORT,
+VS -900 01-11-02
+SEMMISSION
+"SMUCKER JM00
+51.00
+COMMISSION
+118.00
+SCIENTIFIC ATLANTA INC
+WITH RIGHTS TO PURCHASE COMMON
+STK UNDER CERTAIN CIRCUMSTANCE
+SHORT.
+VS 01 18-02
+COMMISSION
+84.00
+AFRICAN EAGLE OUTFITERS NIC
+ECUTION BY JPI
+: 1500 01-14-
+CHILDRENS PLACE RETAIL STORES
+
+FOOT LOCKER INC
+78.00
+"HOT TOPIC INC'***
+XECUTION BY MON
+S 1100 01-09-02, 500 01-03-0
+10-18-21008
+4,43
+AS OF 01/14/02
+SABOUCUSE
+"AEOS
+"PLCE"
+"HOT
+027
+QUANTITY
+-900
+27.21000
+-800
+-1,400
+1,300
+8,700
+34.43440
+26.02000
+27.12670
+27.95000
+15.71780
+'33.90380"
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+24,419.63
+*27,484.10
+36,328.45
+40,705.05
+39,145.00
+19,746.14
+294,343.63
+
+
+33 or 47
+SETTLEMENT TRADE
+DATE
+01/17/02
+01/14/02
+01/1702 01/14/02 SOLD*
+0177/02
+01/14/02
+01777102*01/14/02**SOLD
+01717702 01794/02"SOLD*
+01717102"
+01714/02
+''BÖUGHT"
+01717/02 01/14/02 "BOUGHT
+TOMMY HILFIGER CORP-ORD
+"BEBE STORES INC
+,89.00
+CISCO SYSTEMS INC
+COVER SHORT,
+27,00
+COMMISSION
+SEC FEE
+27.00
+EASTMAN KODAK CO
+ECUTION BY BUC
+5-800 01-14-0
+COMMISSION
+SEC FEB
+18.00
+"GYMBOREE CORP
+6520 01090
+MART CORP"****
+UNSOLICITED
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGEN
+DOVER SHORT
+SYMBOL/GUSP
+TOM
+"BEBE
+eSCO
+'SCO
+'*EK
+"GYMB
+027
+QUANTITY
+-3,000
+2,300
+900°
+*900
+15.44620
+'23.88810
+19.69000
+''20:02000
+800
+• 26.32000
+1,800
+5,400
+12.97000
+= 2.86670
+LEARED THROUGH IT
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+46,142.90
+54,857.80
+17,763.00
+*17,975.72
+'20,992.68
+23,361.00
+15,750.18
+
+
+Bear, Steams & Co. Inc.
+34 or 47
+SETTLEMENT TRADE
+DATE
+01/17/02
+01/14/02
+LEXMARK INTERNATIONAL INC
+WITH RIGHTS TO PURCHASE PREFRD
+SHORINDER CERTAIN CIRCUMSTANCE
+24,00
+01717/02 01/14/02 SOLD
+
+*01/14/02
+
+'*01714/02
+"SMUCKER MCO
+SMELTION BY BUCK
+VS -900 01-14-02
+COMMISSION
+SEC FEE
+155.00
+"SEARS ROEBUCK & CO"
+JNSOLICITEC
+SHORT
+WAL-MART STORES ING
+SHORT.
+VS -900 01-14-02
+COMMISSION
+SEC FEE
+-76.00
+01/18/02
+01715/02
+01718/02 01715/02 BOUGHT
+01718/02 "01715/02"BOUGHT
+NOISSININOO
+OT LOCKER IN
+ECUTION BY BU
+CSMMISSION 15-02
+"HOT TOPIC INC**
+EXECUTION BY RS
+VS 2900 01-15-02
+342,00
+84,00
+SYMBOLCUSP
+IXK
+SJM
+WMT
+FTS
+"HOTT
+027
+QUANTITY
+-400
+-900
+3,800
+900°
+58.12880
+33.26000
+50.75000
+- 56.08880
+5,700
+2,900
+24.04600
+15.03680
+34.16250
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+23,
+29,864.55
+92,581.1
+50,410.16
+137,419.20
+24,150.52
+99,086.25
+
+
+35 of 47
+SETTLEMENT TRADE
+DATE
+DATE
+01/18/02
+01/15/02
+61/18/02 01715/02**"BO0GAT
+01/18/02
+n0175/02
+ö1/18/02
+01/15/02
+01122/02 01/16/02
+'BOUGHT
+01/22/02
+H716/0
+*SOLD
+ö1722/02
+001716/02
+*BOUGHT
+01722/02
+TANGER FACTORY OUTLET CENTERS
+ECUTION BY BUC
+COMMISSION
+126,00
+есте...
+COVER SHORT,
+EXECUTION BY INE
+/S -2800 12-05-0
+COMMISSION
+84,00
+INTERNET SEC SYSING***
+DOVER SHORT
+EXECUTION BY INE
+VS -650 01-04-02
+JOMMISSION
+19.50
+"KMART CORP
+OVER SHORT
+EXECUTION BY BUCI
+VS -900 12-05-01
+COMMISSION
+27.00
+AERICAN EAGLE OUTFITERS INC
+BORDERS GROUP INC
+VS 1600 01-08-02
+COMMISSION
+- 36,00
+"HOT TOPIC INC***
+XECUTION BY RS
+S 5800 01-16-0
+SYMBOLCUSIP
+SKT
+iSSX
+"AEOS
+*BGP
+"GRTS
+027
+QUANTITY
+2,100
+2,800
+650
+900
+-7,600
+2,600
+5,800*
+22.51980
+• 1850590°
+31.07911
+2.44260
+**27:45750
+"22.67000
+
+' 34.40250
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+47,432.58
+CRECIT AMOUNT
+51,915.52
+20,235.92
+2,240.34
+004+6Er...
+36,160.45
+53,344.64
+199,549.50
+
+
+36 01 47
+SETILEMENT TRADE
+DATE
+DATE
+01/22/02
+01/16/02
+09722782 "87718702S0LB"
+01722/02 01718/02 SOLD"
+01/22/02
+n0116/02
+01722/02
+''*01716/02"SOLD
+01722/02
+''0716/02"BÖUGHT"
+01722/02"
+01716/02
+'''*SOLD
+89723702 817702*BOUGHT
+STEVEN MADDEN LTD
+EXECUTION BY VKCO
+VS 1500 01-16-02
+"HOSS'STORES INC"
+5180001-0502
+.89
+TX COMPANIES ING NEW
+VS 1300 01-08-02, 200 12-04-01
+COMMISSION
+SEC FEE
+90.00
+TALBOTS INC
+VS 800 01-16-02
+COMMISSION
+48.00
+"TOMMY HILFIGER "CORP.ORD"
+VS 1100 08-08-01, 800 08-09-01
+COMMISSION
+SEC FEB
+114,00
+K MART CORP
+UNSOLICITED
+AVG PRICE SHOWN-DETAILS ON REC
+CTUAL CONFIRM TO YOUR AGEN
+COVER SHORT,
+LANDS ENDIN.
+VS - 1600 01-16-02
+COMMISSION
+SEC FEE
+11900
+"AMERICAN EAGLE OUTFITERS' INE"
+SYMBOLGUSIP
+SHOO
+027
+QUANTITY
+:1,800
+1,500*
+800
+1,900
+1,800
+-1,600
+15.18000
+' 32.79230
+''38.66430"
+''35.62831
+'15.32230
+
+::47.03930
+*''2735830
+LEARED THROUGH
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+22,785.00
+59,010.25
+57,890.58
+28,565.65
+28.982.93
+3,168.00
+*75,150.73
+*41,052.45
+
+
+37 or 47
+SETTLEMENT TRADE
+DATE
+01/23/02
+01/17/02
+BOUGhT
+01723/02 01/17/02"BÖUGHT
+01723/02 01717702 "BOUGHT"
+01723/02
+01717/02
+*BOUGHT
+ö1/23/02
+''*01/17/02'S0LD
+01723702"
+'*01717/02 BOUGHT
+Bear, Steams & Co. Inc.
+01723/02 01717702 BOUGHT
+FOOT LOCKER INC
+US MMISSI0-17-02
+96.00
+LIZ CLAIBORNE INC
+ST 125100 20 0006422
+LIZ"CLAIBORNE INC
+IS 700 01 -7-020K
+COMMISSION
+42.00
+HANGER FACTORY OUTLET CENTERS
+EXECUTION BY BUCH
+/S 1900 01-17-02
+COMMISSION
+114,00
+TOMMY HILFIGER "CORP-ORD"
+VS 900 08-09-01, 500 08-03-01
+OMMISSION
+SEC FEE
+COMMS 10023-01
+138,00
+"JACOBS ENGINEERING GROUP INC
+WITH RIGHTS TO PURCHASE PREFRD
+SOVER SHOREATAIN CIRCUMSTANCE
+EXECUTION BY FBCO
+VS -300 09-19-01
+COMMISSION
+21,00
+SYMBOUCUSP
+SKT
+TOM
+TEC
+027
+QUANTITY
+20,350
+700
+1,900
+2,300
+300
+14.72730
+
+22.96610
+15.15510
+98.13000
+62.06310"
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+23,674.68
+17,679.36
+2 764 F
+'*27.197.82
+225,852.00
+18,654.93
+
+
+38 or 47
+SETTLEMENT TRADE
+DATE
+01/23/02
+01717/02
+Bear, Steams & Co. Inc.
+01/23/02*01/1702"BOÜGHT
+01723/02
+
+01723/02
+01717/02
+*BOUGHT
+01/24/02
+2 01/18/02
+01724702 01718/02"SOLD"
+01724/02 01/18/02 SOLD
+OVER SHOP
+RECUTION BY BUO
+IS -1600 01-16-02
+OMMISSION
+96.00
+"SMARTFORCE PUB LTD CO''
+27.00
+URBAN OUTFITTERS ING
+COVER SHORT,
+EXECUTION BY MON
+IS -700 12-18-01
+FOSSILING
+EXECUTION BY SLKO
+/S 1200 01-18-0
+AS OF 01/18/02
+"GERBER CHILDRENSWEAR INC
+VS 5400 12-06-99, 3100 12-08-9
+COMMISSION
+SEC FEE
+825.00
+AS OF 01/18/02
+"JILL GROUP INC"
+EXECUTION BY JEFF
+SEC FEE
+.44
+AS OF 01/18/02
+SYMBOLCUSIP
+LE
+*SMTF
+"URBN"
+"FOSL
+*GOW
+027
+QUANTITY
+5,100
+1.80000
+300°
+700
+1,200
+8,500
+• 47.77630
+18.22270
+23.50400
+20.22000
+6.55700
+-1,500
+19.31400
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+9,348.00
+76,553.08
+16.442.43
+16,467.80
+24.279.00
+55,293.66
+28,955.56
+
+
+39 or 7
+SETTLEMENT TRADE
+DATE
+01/24/02
+01/18/02
+0172402 01718/02 SOLD"
+K-SWISS INC-CLA
+EXECUTION BY VKCO
+- 5000430501. 1000 092601
+SO 0111802
+ROSS STORES INC
+
+01718/02
+01724/02
+01718/02
+0172402 01718/02
+ö1725/02
+' 01722/02
+SEC FEE
+AS OF 01/1802
+TX COMPANIES INC NEW
+TS 70012 BY BUCK
+COMMISSION
+AS OF 01/18102
+12.00
+OMMY HILFIGER CORPOR
+XECUTION BY BUC
+/S 850 08-03-01, 900 08-22-01
+1400 11-14-01, 1350 08-07-01
+COMMISSION
+270,00
+SEC FEE
+1.02
+AS OF 01/18/02
+SCIENTIFIC ATLANTA INC
+WITH RIGHTS TO PURCHASE COMMON
+SET AN EMAN CRUISTANCE
+US MISSION 11-02
+84,00
+AMERICAN EAGLE OUTFITERS INC
+EXECUTION BY JPHO
+VS 1500 01-22-02
+SYMBOLGUSIP
+KSWS
+ROST
+*TOM
+SFA
+027
+QUANTITY
+-1,400
+1,100
+700*
+4,500
+35.30000
+'32.43580
+39.00000
+14.97300
+26.86000
+
+LEARED THROUGH IT
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+49,404.25
+35,608.84
+"27,242.59
+67,092.48
+37,703.00
+40,945.05
+
+
+40 01 47
+SETTLEMENT TRADE
+DATE
+01/25/02
+01/22/02
+6172502* 01722/02**SOLB
+01/25/02"
+01/22/02
+ö1/25/02
+•'01722/02
+01725/02 "01722/02'SOLD*
+0172502*
+01722/02
+01/25/02 01/22/02 "BOUGHT
+HOT TOPIC INC
+500 1 82 92
+SEC FEE
+PACIFIC" SUNWEAR OF CALIFOANIA"
+EXECUTION BY RSSF
+VS 600 01-04-02, 1100 01-03-02
+900 01-08-02
+REEBOK INTEANATIONAL LTD
+VS 800 10-03-01
+SEC SON
+13,00
+TOMMY HILFIGER CORP-ORD
+COMMISS 007-01, 145026, 07-01
+48
+'BEBE STORES INC
+XECUTION BY INE
+S -1500 01-22-0
+COMMISSION
+SEC FEE
+-15.00
+"CHICOS FAS ING"
+"FAMILY DOLLAR STORES INC
+COVER SHORT,
+48.00
+SYMBOLCUSIP
+HOTT
+"PSUN
+RBK®
+*TOM
+"BEBE"
+CHS
+FDO
+027
+QUANTITY
+-3,000
+2,600
+800*
+34.29500
+2233500"
+28.50000
+2,100
+-1,500
+7,350
+800
+14.93350
+• 22.66540
+- 31.15000
+LEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+102,868.45
+''58,055.12
+22,736.65
+31,218.87
+*33,937.59
+24,983.00
+
+
+41 or a7
+SETTLEMENT TRADE
+DATE
+01/25/02
+01/22/02
+01725/02 01/22/02 SOLD"
+GYMBOREE CORP
+SHORT
+202210 00
+SEC FISSION
+-80.00
+"KELLWOOD "CO'***
+WITH RIGHTS TO PURCHASE PREFRO
+STK UNDER CERTAIN CIRCUMSTANCE
+SHORT.
+VS -600 01-22-02
+COMMISSION
+36.00
+SHOPKO STORES INC
+SHORT
+VS - 1300 01-22-02
+DOMMISSION
+78.00
+SEC FEE
+.20
+WAL-MART STORES INC
+.. . .
+COVER SHORT
+EXECUTION BY'BUCH
+'S -900 01-14-0
+OMMISSIO
+54.00
+01725/02
+01722/02
+*SOLD
+01/25/02
+01/22/02
+DEPOSITS AND WITHDRAWALS
+DATE
+01/14/02
+01/23/02
+CHECK
+"CHECK"
+BINGHN CHIN MON
+LES FR 01101102-03/31/0
+UCKINGHAM CAPIT
+SYMBOL/CUSIP
+GYMB
+KWD
+*SKO
+QUANTITY
+-3,000
+600
+1,300
+900*
+14.00000
+23.10960
+
+57.12000
+DEBIT AMOLNT
+26,387.82
+26.387.82
+027
+LEARED THROUGH IT
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+41,894.37
+13,814.55
+12,906.80
+51,477.00
+$-8,160,124.46
+$5.169.957.72
+
+
+42 0 47
+DEPOSITS AND WITHDRAWALS (continued)
+DATE
+01/23/02
+FUNDS REC
+PKESTAU10102-033902
+BUCKINGHAM CAPITAL
+MONEY FUND ACTIVITY
+DATE
+MODAY
+01/01/02
+01/02/02
+01/02/02
+OPENINGBALANCE
+REINVEST
+ö1/02/02
+DIVIDEND
+MONTHLY DIVIDEND REINVESTED
+01/02/02
+"REINVEST
+ö1/02/02 DIVIDEND
+87763702'"501B
+01/07102 SOLD
+01/07/02*
+01/09/02
+*SOLD
+AMT INCLUDED IN 2001 - 1099
+DOMESHA SHARES EMBANELO
+MONTHLY DIVIDEND REINVESTED
+DOMES SHE MEN BALO
+AMT INCLUDED IN 2001 - 1099
+DOES PRIME A PORTFOL
+DOMESTIC PRIME MAM PORTFOLIO
+Bear, Steams & Co. Inc.
+DEBIT AMOUNT
+$-52,775.64
+SYMBOUCUSIP
+"GIDXX
+XxaIo.
+26,387.82
+$26.387.82
+QUANTITY
+4,412,445.60
+500,000
+267.57
+2.286.11
+700,000
+300,000
+800,000
+800,000
+1.0000
+1.0000
+1.0000
+1.0000
+1.0000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+267.57
+2,286.11
+500,000.00
+267.57
+2,286.11
+60,000.00
+300,000.00
+800,000.00
+800,000.00
+
+
+43 o1 a7
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+01/14/02
+01/18/02
+"SOLD"
+01/23/02
+Ö1/23/02
+"DIVDEND
+01/23/02
+*''DIVIDEND
+01/23/02 REINVEST
+01/23/02
+''REINVEST
+01/25102
+
+BROWN SHOE COMPANY
+REC 12/17/01 PAY 01/02/02
+01/02/02 "GENUINE PARTS CO'''***
+DIV CHG
+RIC 120127 PAIS202
+01702/02 SEARS ROEBUCK 8 CO**
+REC 1310 PAS0110202
+Bear, Steams & Co. Inc.
+SYMBOUCUSIP
+GIDXX
+*GTOXX
+MONTHLY DIVIDEND
+DONE PREM PORTFOLIO
+MONTHLY DIVIDEND
+MONTHLY DIVIDEND REINVESTED
+ONEST PREM PORTFOLIO
+MONTHLY DIVIDEND REINVESTED
+CLOSINGBALANCE
+SYMBOUCUSIP
+BWS
+"GPC
+QUANTITY
+14,300
+QUANTI
+100.000
+300,000
+400,000
+435.56
+1,235.74
+1,816,670.58
+RATE (S)
+0.1000
+027
+1.0000
+0000*
+1.0000
+CLEARED THROUGH IT
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+400,000.00
+300,000.00
+400,000.00
+435.56
+1,235.74
+*435.56
+1,235.74
+$-804,224.98
+1,430.00
+$3,404,224.98
+DEBIT AMOUNT
+769.50
+T,012.00
+
+
+44 01 47
+DIVIDENDS (continued)
+
+ESTEE LAUDER COMPANIES INC
+CLA
+REC 1294000 0110002
+01/04/02
+DIV CHG
+RIC 1210100010402
+'CATO CORP CLAI
+REC 12/24/01 PAY 01/07/02
+01714/02"DIAMONDS TAUST-UNIT SERIES"
+DIV CHG
+8200 SHS SHORT
+REC 12/26/01 PAY 01/14/02
+ö1/15/02
+'SWISS INC-CLA'
+REC 12/31/01 PAY 01/15/02
+01715/02 ECOLA ....
+DIV CHG
+800 SHS SHORT
+REC 12/18/01 PAY 01/15/02
+01715/02 "FAMILY DOLLAR STORESING
+DIV CHG
+1900 SHS SHORT
+REC 12/14/01 PAY 01/15/02
+ö1/15/02
+• HOUR SEASONS HOTELS INC
+LIMITED VOTING SHARES
+DIV CHG
+850 SHS SHORT
+REC 12/31/01 PAY 01/15/02
+1/15/02 LEGGETT & PLATT INC***
+EGGETT & PLATT IN
+DIV CHI
+SYMBOL/CUSIP
+EL
+"DIA"
+KSWS
+LEG
+QUANTITY
+2,700
+9,400
+RATE (S)
+0.1350
+0.0150
+027
+DEBIT AMOUNT
+45.00
+51.00
+1,748.90
+108.00
+114.00
+"29.26"
+120.00
+$-3.997.66
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+364.50
+147:00
+$1.935.50
+
+
+45 of 47
+INTEREST
+DATE
+01/22/02
+INT CR
+JAN 02
+MISCELLANEOUS
+DATE
+MO/DAY
+01/03/02
+01/03/02*10
+01703/02
+01:03/02
+01/03/02
+01703/02
+01/0702*
+JOUANAL,
+
+JOURNAL'
+01/14/02
+61/22/02
+01/22102Y0UANAL
+01722/02
+JOURNAL"
+01722/02
+SYMBOUCUSIP
+QUANTITY
+RATE (SI
+......
+OREST ROM BROP
+CASH
+MOVE BKD P&L TO BOOKKEEPING
+SFFSET FROM BKD PR**''
+"CASH"
+MOVE BKD P&L TO BOOKKEEPING
+OFFSET FROM BIRD PAL'
+"CASH
+MOVE BKD P&L TO BOOKKEEPING
+127
+"MARK TO MARKET
+'''MARK TO MARKET SHORT POS
+**'MARK TO MARKET
+MARK TO MARKET SHORT POS
+JAN 02
+'MARK TO MARKET
+MARK TO MARKET SHORT POS
+DEBIT AMOUNT
+173,567.13
+7,050, 192.84
+617,564.23
+'*70.00
+*''31,976.00
+92,716.00
+818.76
+62,434.00
+$-8.029,338.96
+027
+DEBIT AMOUNT
+CRECIT AMOUNT
+173,567.13
+7,050,192.84
+617,564.23
+*31,976.00
+"92,716.00
+5,350.69
+62,434:00
+$8,033.800.89
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+1,529.83
+$1,529.83
+
+
+OFFICE SERVIING YOUR ACCOUNT
+BEARR
+46 ot 47
+Trades Executed Pending Settlement
+SETLEMENT TARE
+01/28/02
+01/23/02
+0172802"
+01/23/02
+01/28/02
+01/23/02
+01/28/02 01/23/02 "SOLD"
+01/28/02 01/23/02
+... .
+1/28/0
+01/23/02 S0*
+01/28/02
+01/23/02
+01/28
+11/23/02
+BOUGH
+01/28
+11/23/02
+01
+01/28
+3/02
+01.
+01/28/02
+01/23/02
+01/29/02
+01/24/02
+.......
+01/29/02
+01/24/02
+01/29/02
+01/24/02
+.....
+01/29/02
+01/24/02
+ganananaanaaııganaaaaaaaaan
+01/29/02
+01/24/02
+........
+01/29/02
+01/24/02
+01/29/02
+01/24/02
+____________-..
+01/29/02
+01/24/02
+OUGH
+COLDWATER CREEK ING
+FOOT LOCKER INC
+FOREST LABORATORIES ING
+GERBER CHILDRENSWEAR INC
+GALYANS TRADING ING
+"GYMBOREE CORP*
+HOT TOPIC INC
+BRITE INC
+PAYAR
+SH
+Ol
+ORES INC
+FIGER
+CORP-ORD
+URBAN OUTFITTERS ING
+.......
+ANTAYLOR STORES CORP
+COACH INC
+DIAMONDS TRUST-UNIT SERIES 1
+.....________••---------____....
+OOT LOCKER IN
+FLEMING COMPANIES INC
+WITH RIGHTS TO PURCHASE PREFRD
+GENESCO INC
+WITH RIGHTS TO PURCHASE PREFRD
+HOT TOPIC INC
+HOME DEPOT INC
+SYMBOLCUSP
+CWTR
+FRX
+*GCW
+GLYN
+"GYMB
+HOTT
+INTV
+PXR
+SKO
+TOM
+ISCO
+URBN
+ANN
+COH
+DIA
+FLM
+GCO
+HOTT
+027
+QUANTITY
+600.00
+,600.00
+900.00
+6,900.00
+2,600.00
+-900.00
+2,950.00
+. . ..
+500.00
+2,400.00
+3,500.00
+,800.00
+900.00
+-500.00
+2,700.01
+-1,400.00
+900.00
+... ..
+2,800.00
+....•...
+900.00
+.600.0
+-6,000.00
+...........
+1,600.01
+16.7630
+14.5317
+83.7500
+6.5000
+13.2254
+14.0002
+33.8943
+......
+9.1500
+.....san
+15.0220
+10.1023
+14.7484
+35.6034
+............
+25.3147
+36.8150
+
+8.100
+14.5482
+19.5343
+23.9880
+34.2517
+...............
+48.0200
+CLEARED THROUGH ITE
+One Metratech Center Narth
+Brocktyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+26,805.39
+23,377.72
+75,304.86
+44,489.32
+34,401.04
+12,557.99
+99,971.69
+4,590.00
+...........
+36,211.80
+35,132.51
+26,405.72
+32,085.06
+12,627.16
+99,222.00
+..........
+51,856.5
+88,359.00
+..... .
+40,917.96
+17,649.87
+38,491.80
+76,943.00
+205.492.14
+
+
+47 of a7
+Trades Executed Pending Settlement
+(continued)
+SETLE MENT TRAE
+01/29/02 01/24/02
+BOUGhT
+01/29/02 01/24/02
+0129/02
+01/24/02
+01/29/02
+:01/24/02
+01/29/02 01/24/02
+01/29/02
+01/24/02
+......
+01/29/02
+01/24/02
+..................•*•• •••••*****•**••••
+01/29/02
+01/24/02
+anananaaaanaıiııaaaaaaaaananaaaanannaaaııaan
+01/29/02
+01/24/02
+.......
+01/30/02
+01/25/02
+BOUGH
+01/30/02
+01/25/02
+01/30/02
+01/25/02
+01/30/02
+01/25/0
+.....
+01/30/02
+01/25/02
+01/30/02 01/25/02
+01/25/02
+01/30102
+01/25/02
+01/30/02
+01/25/02
+LEXMARK INTERNATIONAL ING
+WITH RIGHTS TO PURCHASE PREFRD
+STEVEN MADDEN LID
+PACIFIC SUNWEAR OF CALIFORNIA
+PAXAR CORP"
+ROSS STORES INC
+anisisananasnsssaınaannl
+TOYS R US INC
+WITH RIGHTS TO PURCHASE COMMON
+TOMMY HILFIGER CORP-ORL
+UAL CORP NEW
+WEST MARINE INC
+CHRISTOPHER & 1
+BANKS CORP
+FAMILY DOLLAR STORES INC
+FOREST LABORATORIES INC
+GENESCO INC
+WITH RIGHTS TO PURCHASE PREFRD
+HOME DEPOT INC
+NORDSTROM INC
+POLYCOM INC
+JAL CORP NEW
+The above trades do not appear in ary other section of this statement
+SIMBOLCUSP
+LXK
+SHOO
+PSUN
+PXR
+ROS
+TOY
+TOM
+UAL
+WMAR
+CHBS
+FDO
+FRX
+GCO
+HD
+PLCM
+UAL
+027
+QUANTITY
+1,300.00
+2,100.00
+-1,200.00
+1,200.00
+2,500.00
+.... .
+3,500.00
+-4,700.00
+....
+-1,500.00
+.......
+-2,400.00
+300.00
+1,100.00
+-500.00
+1,600.00
+800.00
+.. .
+3,300.00
+-1.800.00
+1,800.00
+54.5981
+16.5900
+22.5813
+15.1546
+34.5367
+18.9284
+14.9084
+.. . .
+14.8160
+....
+15.3119
+... .
+32.5000
+32.5000
+81.1652
+24.3024
+47.1500
+4.6766
+.....
+0.756
+.............
+16.6007
+One Metratech Center North
+Brocktyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOO January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAPAYER NUMBER
+December 31, 2001
+DEBIT AMOUNT
+71,083.53
+34,854.00
+27,082.15
+18,272.52
+86,325.45
+66,474.40
+69,771.42
+.. . .
+22,103.66
+36,661.00
+40,536.99
+9,765.00
+. . .
+35,831.00
+38,994.84
+37,783.00
+. . .
+81,645.78
+$787,731.32
+55,290.96
+29,739.81
+$1,067,376.73
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/c80be77fe6bc9f7499de533c217f26d92bae248bc4d49c87e22935758d29765b.receipt.json b/vision-fixhub/ds9-unparsed-05/c80be77fe6bc9f7499de533c217f26d92bae248bc4d49c87e22935758d29765b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..acb0863ffdaf607479587b846a0fce5e6811b4d8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c80be77fe6bc9f7499de533c217f26d92bae248bc4d49c87e22935758d29765b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -54818,
+  "dataset": "marble-joined",
+  "doc_id": "c80be77fe6bc9f7499de533c217f26d92bae248bc4d49c87e22935758d29765b",
+  "engine": "marble-apple-vision",
+  "event_count": 307,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "30219f5ea11630043b836daf3402538441a5337ace4f4c7051c4baf594c8b0af",
+  "output_sha256": "fbb660ed7c6998749adfb81ab258492dc2d0f50cf831769da37dd8aa2702b507",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c830d509f6a9d959821220f38cab18b625a751cbcca6580d14bda8dce7468c13.md b/vision-fixhub/ds9-unparsed-05/c830d509f6a9d959821220f38cab18b625a751cbcca6580d14bda8dce7468c13.md
new file mode 100644
index 0000000000000000000000000000000000000000..13c62d44dc7917f44010f662a5911d4ca679f044
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c830d509f6a9d959821220f38cab18b625a751cbcca6580d14bda8dce7468c13.md
@@ -0,0 +1,3615 @@
+3
+4 italics-/
+5 Date
+6
+7
+8
+3/3/2004
+9
+10
+3/7/2004
+11
+3/11/2004
+B
+C
+D
+E
+F
+Time
+Call
+length/message
+info/Passengers
+12
+13
+14
+15
+16
+17
+18
+19
+3/13/2004
+3/19/2004
+3/25/2004
+3/31/2004
+3/31/2004
+4/2/2004
+22
+23
+24
+25
+4/2/2004
+4/3/2004
+4/3/2004
+4/5/2004
+Event
+Epstein's Flight
+arrives at PBIA
+11:23:00 PM (Boeing 727)
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+5:42:00 PM 1159B)
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+11:20:00 PM
+1159B)
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+11:50:00 AM
+11598)
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+3:42:00 PM 11598)
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+11:53:00 PM 1159B)
+Epstein's Flight
+departs from PBIA
+11:55:00 AM (Boeing 727)
+4:10:00 PM Call
+11:30:00 AM Call
+Epstein's Flight
+arrives at PBIA
+11:03:00 PM (Boeing 727)
+9:47:00 AM Call
+9:51:00 AM Call
+11:04:00 AM Call
+From
+To
+is 17 years old
+Valsan, 1 male, 1
+female
+Jeffrev Eostein, Teala
+Valsan, 1 female
+Jeffrey Epstein
+Valdsan
+Jeffrey Fostein.
+Tindal, Pax 1,
+Jeffrey Epstein
+female
+jean Luk
+Brunnel, 1 female
+
+
+1
+2
+Epstein in town
+3
+4
+5 Date
+26
+27
+4/6/2004
+28
+4/10/2004
+D
+E
+F
+Time
+er 18
+Event
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+10:51:00 AM 1159B)
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+1:23:00 PM 1159B)
+From
+To
+Call
+length/message
+info/Passengers
+Lorry Frostin Bront
+1 Brent Tindall,
+Ghislaine Maxwell, Brent
+Tindall,
+29
+30
+31
+32
+33
+34
+35
+4/11/2004
+4/15/2004
+4/16/2004
+4/19/2004
+Epstein's Flight
+departs from PBIA
+2:17:00 PM (Boeing 727)
+11:30:00 AM Call
+Epstein's Flight
+arrives at PBIA
+9:08:00 PM
+(Boeing 727)
+Epstein's Flight
+departs from PBIA
+3:45:00 PM
+(Boeing 727)
+Jaliray Epstein.
+emale
+Chislaine Maxwell,
+Brent
+Tindall, Mark Epstein
+36
+37
+38
+39
+40
+41
+42
+4/22/2004
+4/27/2004
+5/1/2004
+5/4/2004
+5/7/2004
+Epstein's Flight
+arrives at PBIA
+10:21:00 PM (Boeing 727)
+Epstein's Flight
+departs from PBIA
+11:07:00 AM (Boeing 727)
+Epstein's Flight
+arrives at PBIA
+11:07:00 PM (Boeing 727)
+Epstein's Flight
+departs from PBIA
+4:45:00 PM (Boning 727)
+8:31:00 AM Call
+male, male
+Jeffrey Epstein, Brent
+Tindall, |
+Jeffrey Epstein
+
+
+1
+3
+4 Italics-
+5 Date
+431
+44
+45
+46
+47
+48
+49
+50
+51
+52
+53
+54
+55
+56
+57
+58
+59
+60
+61
+5/8/2004
+5/8/2004
+5/8/2004
+5/14/2004
+5/17/2004
+5/21/2004
+5/24/2004
+5/28/2004
+6/4/2004
+6/7/2004
+6/11/2004
+6/13/2004
+6/20/2004
+B
+E
+F
+Time
+Event
+8:51:00 AM Call
+8:51:00 AM Call
+7:13:00 PM Call
+Epstein's Flight
+arrives at PBIA
+10:26:00 AM (Boeing 727)
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+4:22:00 PM 1159B)
+Epstein's Flight
+arves at PBIA
+(Gulfstream G-
+10:13:00 PM 1159B)
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+9:31:00 AM 1159B)
+10:44:00 AM
+Call
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+2:59:00 PM
+11598)
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+10:19:00 AM 11598)
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+1:51:00 AM 1159B)
+Epstein's Flight
+departs from PBIA
+4:08:00 PM (Boeing 727)
+From
+To
+[Call
+length/message
+info/Passengers
+Brent
+lindal
+Brent Tindall,
+female
+Jeffrey Epstein, Brent
+Tindall
+Jeffrey Epstein, Brent
+Tindall,
+Jeffrey Epstein
+Gossman
+Jeffrey Epstein, Brent
+Tindall,
+Epstein's Flight
+arrives at PB/A
+6:15:00 PM (Boeing 727)
+
+
+1
+2
+Epstein in town
+3
+4
+Italics-4
+B
+C
+D
+E
+F
+5 Date
+62
+63
+64
+65
+66
+67
+68
+69
+70
+72
+73
+74
+75
+76
+77
+78
+79
+80
+Time
+6/21/2004
+6/22/2004
+7/4/2004
+7/5/2004
+7/7/2004
+7/7/2004
+7/8/2004
+7/8/2004
+7/8/2004
+7/8/2004
+7/8/2004
+7/8/2004
+7/8/2004
+7/8/2004
+7/10/2004
+7/10/2004
+81
+82
+84
+85
+7/11/2004
+7/12/2004
+7/13/2004
+7/14/2004
+Event
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+11:23:00 AM 1159B)
+12:43:00 PM Call
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+10:20:00 PM 11598)
+7:03:00 PM Call
+8:47:00 PM Call
+8:50:00 PM Call
+7:20:00 PM Call
+7:52:00 PM Call
+8:36:00 PM Call
+8:40:00 PM Call
+8:50:00 PM Call
+8:59:00 PM Call
+9:00:00 PM Call
+9:07:00 PM Call
+5:44:00 PM Call
+6:04:00 PM Call
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+10:47:00 AM 1159B)
+10:24:00 PM Call
+7:50:00 PM Call
+3:58:00 PM Call
+From
+To
+Call
+length/message
+info/Passengers
+Jeffrey Epstein
+male, Brent
+Tindall
+0:03:00
+0:03:00
+0:05:00
+Tindall
+Brent
+
+
+1
+3
+4 Italics-
+5 Date
+86
+7/15/2004
+87
+7/15/2004
+88
+7/15/2004
+89
+7/15/2004
+90
+7/15/2004
+91
+7/15/2004
+92
+7/15/2004
+93
+7/15/2004
+94
+7/15/2004
+95
+96
+7/15/2004
+7/15/2004
+97
+98
+7/15/2004
+7/16/2004
+99
+100
+101|
+7/16/2004
+7/16/2004
+7/16/2004
+102
+103
+104|
+105
+106
+107
+108
+7/16/2004
+7/16/2004
+7/16/2004
+7/16/2004
+7/16/2004
+7/16/2004
+7/16/2004
+7/16/2004
+B
+D
+E
+F
+Time
+Event
+9:18:00 AM Call
+9:41:00 AM Call
+9:49:00 AM Call
+12:40:00 PM Call
+12:41:00 PM Call
+12:43:00 PM Call
+1:34:00 PM Call
+7:36:00 PM Call
+8:10:00 PM Call
+10:01:00 PM Call
+10:04:00 PM Call
+10:06:00 PM Call
+1:55:00 AM Call
+10:35:00 AM Call
+11:07:00 AM Call
+11:10:00 AM Call
+12:15:00 PM Call
+1:44:00 PM Call
+1:45:00 PM Call
+2:10:00 PM Call
+2:11:00 PM Call
+2:14:00 PM Call
+4:47:00 PM Call
+7:29:00 PM Call
+From
+To
+as Seet
+Call
+length/message
+info/Passengers
+0:09:00
+
+
+1
+2
+Epstein in town
+3
+4 Italics-/
+C
+D
+E
+F
+5 Date
+Time
+111
+112
+113
+114
+115
+116
+117
+118
+119
+7/16/2004
+7/17/2004
+7/17/2004
+7/17/2004
+7/18/2004
+7/18/2004
+7/18/2004
+7/19/2004
+7/19/2004
+120
+121
+122
+123
+124
+125
+126
+127
+128
+129
+7/19/2004
+7/19/2004
+7/19/2004
+7/19/2004
+7/19/2004
+7/20/2004
+7/20/2004
+7/22/2004
+130
+131
+132
+7/22/2004
+7/23/2004
+7/23/2004
+Event
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+10:02:00 PM (1159B)
+4:26:00 PM Call
+4:53:00 PM Call
+9:05:00 PM Call
+3:35:00 PM Call
+3:56:00 PM Call
+9:16:00 PM Call
+9:33:00 AM Call
+1:48:00 PM Call
+Epstein's Flight
+departs from PBIA
+5.35:00 PM (Boeing 727)
+5:42:00 PM Call
+8:36:00 PM Call
+9:51:00 PM Call
+11:58:00 PM Call
+12:00:00 AM Call
+12:04:00 AM Call
+10:58:00 AM Call
+Epstein's Flight
+arrives at PBIA
+9:50:00 PM (Boeing 727)
+11:31:00 AM Call
+11:32:00 AM Call
+From
+To
+Call
+length/message
+info/Passengers
+_ Brent Tincem
+Jean
+Luc Brunel, Zsu Zse,
+Czifrik,
+Brent Tindall,
+female, 1 female, 1
+female
+Jeffrey Epstein, S
+Brent Tindan
+
+
+1
+3
+Busteal
+4 italics
+B
+C
+D
+E
+F
+5 Date
+1331
+7/23/2004
+134
+7/23/2004
+135
+7/23/2004
+136
+7/23/2004
+137
+7/23/2004
+138
+7/23/2004
+139
+7/24/2004
+140
+7/24/2004
+141
+142
+143
+7/25/2004
+7/25/2004
+7/25/2004
+144
+145
+146
+147
+148
+149
+150|
+151
+152
+153
+154
+155
+156
+7/25/2004
+7/30/2004
+7/30/2004
+8/3/2004
+8/4/2004
+8/6/2004
+8/6/2004
+8/7/2004
+8/7/2004
+8/10/2004
+Time
+Event
+12:38:00 PM Call
+4:15:00 PM Call
+4:22:00 PM Call
+4:38:00 PM Call
+4:41:00 PM Call
+4:48:00 PM Call
+5:49:00 PM Call
+6:58:00 PM Call
+11:39:00 AM Call
+1:42:00 PM Call
+2:03:00 PM Call
+Epstein's Flight
+departs from PBIA
+4:35:00 PM (Boeing 727)
+1:14:00 PM Call
+1:15:00 PM Call
+8:49:00 PM Call
+11:45:00 AM Call
+1:23:00 PM Call
+Epstein's Flight
+arrives at PB/A
+10:25:00 PM (Boeing 727)
+4:30:00 PM Call
+4:31:00 PM Call
+Epstein's Flight
+departs from PBIA
+10:23:00 AM (Boeing 727)
+From
+To
+Call
+length/message
+info/Passengers
+0:03:00
+Jeffrey Epstein, Brent
+Tindall, I
+Jeffrer Fastain
+
+
+1
+3 Eusteal out
+4 Italics
+5 Date
+1157
+8/17/2004
+158
+8/17/2004
+159
+8/17/2004
+160
+8/17/2004
+161
+8/17/2004
+162
+8/18/2004
+163
+8/19/2004
+164
+8/19/2004
+165
+8/19/2004
+166
+167
+168
+169
+170
+171
+172
+173
+174
+175
+176
+177
+178
+8/19/2004
+8/19/2004
+8/19/2004
+8/20/2004
+8/20/2004
+8/20/2004
+8/20/2004
+8/20/2004
+8/20/2004
+8/20/2004
+8/20/2004
+8/23/2004
+B
+D
+E
+F
+Time
+Event
+5:07:00 PM Call
+5:32:00 PM Call
+5:55:00 PM Call
+7:34:00 PM Call
+8:52:00 PM Call
+3:28:00 PM Call
+10:38:00 AM Call
+12:47:00 PM Call
+12:49:00 PM Call
+Epstein's Flight
+arrives at PBIA
+4:50:00 PM (Boeing 727)
+5:00:00 PM Call
+7:05:00 PM Call
+3:34:00 PM Call
+4:02:00 PM Call
+4:03:00 PM Call
+5:29:00 PM Call
+5:45:00 PM Call
+5:51:00 PM Call
+5:58:00 PM Call
+9:03:00 PM Call
+11:11:00 AM Call
+From
+To
+Call
+length/message
+info/Passengers
+Jeffrey Epstein, Ireen
+
+
+1
+3
+Frat calle
+4 italic:
+5 Date
+179)
+8/24/2004
+B
+D
+Time
+180
+181
+182
+183
+184
+185
+186
+8/24/2004
+8/24/2004
+8/25/2004
+8/25/2004
+8/25/2004
+187
+188
+189
+190
+191
+192
+193
+194
+195
+196
+197
+198
+199
+200
+201
+202
+8/25/2004
+8/25/2004
+8/25/2004
+8/26/2004
+8/26/2004
+8/26/2004
+8/26/2004
+8/26/2004
+8/26/2004
+8/27/2004
+8/27/2004
+8/27/2004
+8/27/2004
+8/27/2004
+8/27/2004
+8/27/2004
+Event
+9:28:00 AM Call
+Epstein's Flight
+departs from PBIA
+10:51:00 AM (Boeing 727)
+11:25:00 AM Call
+7:11:00 AM Call
+12:15:00 PM Call
+12:19:00 PM Call
+Epstein's Flight
+arrives at PBIA
+5:31:00 PM (Boeing 727)
+6:40:00 PM Call
+6:58:00 PM Call
+9:05:00 AM Call
+4:59:00 PM Call
+5:34:00 PM Call
+8:22:00 PM Call
+8:53:00 PM Call
+8:56:00 PM Call
+7:25:00 AM Call
+9:16:00 AM Call
+9:17:00 AM Call
+10:12:00 AM Call
+10:46:00 AM Call
+3:36:00 PM Call
+4:06:00 PM Call
+From
+To
+F
+Call
+length/message
+info/Passengers
+Ghislaine Maxwell,
+
+
+1
+4 Italic:
+5 Date
+203
+204
+205
+206
+207
+208
+8/27/2004
+8/29/2004
+8/31/2004
+9/1/2004
+9/1/2004
+9/1/2004
+B
+-
+209
+210
+211
+213
+214
+215
+216
+217
+218
+219
+220
+221
+222
+9/1/2004
+9/1/2004
+9/1/2004
+9/16/2004
+9/16/2004
+9/16/2004
+9/17/2004
+9/17/2004
+9/19/2004
+10/2/2004
+10/5/2004
+223
+224
+225
+10/5/2004
+10/5/2004
+Time
+Event
+4:33:00 PM Call
+3:12:00 PM Call
+2:41:00 PM Call
+10:02:00 AM Call
+10:05:00 AM Call
+5:01:00 PM Call
+Epstein's Flight
+departs from PBIA
+5:56:00 PM (Boeing 727)
+7:49:00 PM Call
+8:07:00 PM Call
+6:04:00 PM Call
+6:09:00 PM Call
+Epstein's Flight
+arrives at PBIA
+10:16:00 PM (Boeing 727)
+9:45:00 AM Call
+3:48:00 PM Call
+Epstein's Flight
+departs from PBIA
+7:36:00 AM (Boeing 727)
+Epstein's Flight
+arrives at PBIA
+9:49:00 PM (Boeing 727)
+7:19:00 AM Call
+Epstein's Flight
+departs from PBIA
+8.02:00 AM (Boeing 727)
+9:35:00 AM Call
+D
+E
+F
+Croma
+Call
+length/message
+info/Passengers
+0:04:00
+0:03:00
+Jeffrey Epstein, I
+David Mullen,
+Jeffrey Epstein
+David Mullen
+
+
+1
+3
+4 Italics-
+5 Date
+225
+227
+228
+229
+230
+231
+10/5/2004
+10/8/2004
+10/8/2004
+10/8/2004
+10/8/2004
+232
+10/8/2004
+B
+E
+F
+Time
+Event
+2:18:00 PM Call
+11:39:00 AM Call
+4:57:00 PM Call
+4:58:00 PM Call
+5:30:00 PM Call
+Epstein's Flight
+arrives at PBIA
+8:05:00 PM (Boeing 727
+From
+To
+233
+[234
+235
+236
+237
+238
+239
+240
+241
+242
+243
+244
+10/10/2004
+10/16/2004
+Call
+length/message
+info/Passengers
+Jeffrey Epstein
+David
+Mullen, 1 pax
+David
+Mullen,
+10/16/2004
+10/17/2004
+10/29/2004
+10/29/2004
+10/29/2004
+10/30/2004
+10/30/2004
+Epstein's Flight
+departs from PBIA
+6:00:00 PM (Boeing 727)
+12:42:00 PM Call
+Epstein's Flight
+arrives at PBIA
+8:08:00 PM (Boeing 727)
+Epstein's Flight
+departs from PBIA
+8:04:00 AM (Boeing 727)
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+12:36:00 AM 1159B)
+9:25:00 AM Call
+5:29:00 PM Call
+1:47:00 AM Call
+8:21:00 AM Call
+Jeffrey Epstein
+Ghislaine Maxwella
+Jeffrey Epstair
+
+
+B
+D
+E
+F
+1
+Sirst calle
+4 Italics
+5 Date
+245
+10/30/2004
+246
+10/30/2004
+247
+10/30/2004
+248
+10/30/2004
+249
+10/30/2004
+250
+10/30/2004
+251
+10/30/2004
+252
+10/31/2004
+253
+254
+11/1/2004
+255
+256
+257
+258
+259
+260
+261
+262
+263
+264
+265
+11/5/2004
+11/7/2004
+11/8/2004
+11/8/2004
+11/8/2004
+11/8/2004
+11/8/2004
+11/8/2004
+11/8/2004
+11/8/2004
+11/8/2004
+11/9/2004
+Time
+Event
+9:49:00 AM Call
+10:20:00 AM Call
+10:20:00 AM Call
+10:23:00 AM Call
+10:24:00 AM Call
+11:06:00 AM Call
+1:18:00 PM Call
+9:26:00 PM Call
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+7:50:00 PM 1159B)
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+10:46:00 PM 1159B)
+2:54:00 PM Call
+12:39:00 PM Call
+12:40:00 PM Call
+12:44:00 PM Call
+2:56:00 PM Call
+2:57:00 PM Call
+3:01:00 PM Call
+4:00:00 PM Call
+6:24:00 PM Call
+8:15:00 PM Call
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+5:32:00 PM 1159B)
+[From
+To
+Call
+length/message
+info/Passengers฿
+0:04:00
+0:04:00
+Jeffrey Epsteir
+Jean Luk
+Brunnel, 1 female,
+Voldson, 1 male-Jeff
+0:05:00
+266
+267
+
+
+1
+3
+4 Italics
+5 Date
+268
+269
+11/10/2004
+B
+Time
+270
+271
+272
+273
+274
+275
+276
+277
+278
+279
+280
+281
+282
+283
+284
+285
+11/10/2004
+11/10/2004
+11/10/2004
+11/10/2004
+11/10/2004
+11/10/2004
+11/10/2004
+11/10/2004
+11/11/2004
+11/11/2004
+11/11/2004
+11/11/2004
+11/11/2004
+11/11/2004
+11/12/2004
+11/13/2004
+286
+287
+288
+289
+290
+291
+11/14/2004
+11/14/2004
+11/14/2004
+11/17/2004
+11/17/2004
+Event
+9:46:00 AM Call
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G
+12:21:00 AM 11598
+8:03:00 PM Call
+9:34:00 PM Call
+9:40:00 PM Call
+9:40:00 PM Call
+9:41:00 PM Call
+9:47:00 PM Call
+9:56:00 PM Call
+7:19:00 AM Call
+7:23:00 AM Call
+2:50:00 PM Call
+4:38:00 PM Call
+7:51:00 PM Call
+8:35:00 PM Call
+5:40:00 PM Call
+3:57:00 AM Call
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+12:13:00 PM 1159B)
+7:14:00 PM Call
+7:16:00 PM Call
+9:35:00 AM Call
+10:55:00 AM Call
+D
+E
+F
+From
+Call
+length/message
+info/Passengers
+Volsan,
+
+
+1
+3 Eusicall
+4 Italics
+B
+D
+E
+F
+5 Date
+292
+293
+294
+Time
+11/17/2004
+11/17/2004
+295
+296
+297
+298
+299
+300
+301
+302
+11/18/2004
+11/18/2004
+11/18/2004
+11/18/2004
+11/19/2004
+11/19/2004
+11/22/2004
+11/22/2004
+303
+304
+305
+306
+307
+308
+309
+310
+311
+312
+313
+11/23/2004
+11/28/2004
+11/28/2004
+11/28/2004
+12/1/2004
+12/1/2004
+12/3/2004
+12/3/2004
+12/3/2004
+Event
+3:34:00 PM Call
+4:29:00 PM Call
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+12:10:00 AM 1159B)
+4:37:00 PM Call
+9:56:00 PM Call
+9:57:00 PM Call
+1:00:00 PM Call
+5:51:00 PM Call
+12:14:00 PM Call
+2:30:00 PM Call
+Epstein's Flight
+departs from PBIA
+2:35:00 PM (Boeing 727)
+2:27:00 PM Call
+5:52:00 PM Call
+6:22:00 PM Call
+12:46:00 PM Call
+12:49:00 PM Call
+7:59:00 AM Call
+11:48:00 AM Call
+Epstein's Flight
+arrives at PBIA
+7:34:00 PM (Boeing 727)
+From
+To
+Call
+length/message
+info/Passengers
+Jeffrey Epstein
+David Matter
+Jeffrey Epstein l
+David Mullen,
+
+
+3
+Fireall
+4 Italics-
+5 Date
+B
+Time
+Event
+314
+315
+316
+317
+318
+319
+320
+321
+322
+323
+324
+325
+326
+327
+328
+329
+12/4/2004
+12/5/2004
+12/6/2004
+12/6/2004
+12/6/2004
+12/7/2004
+12/8/2004
+12/8/2004
+12/8/2004
+12/8/2004
+12/8/2004
+12/10/2004
+12/10/2004
+12/13/2004
+12/13/2004
+330
+331
+12/13/2004
+12/14/2004
+332
+[333
+334
+335
+12/14/2004
+12/15/2004
+12/15/2004
+2:55:00 PM Message Pad
+5:46:00 PM Call
+12:35:00 PM Call
+12:36:00 PM Call
+2:50:00 PM Call
+1:15:00 PM Call
+9:11:00 AM Call
+9:12:00 AM Call
+9:28:00 AM Call
+5:24:00 PM Call
+6:42:00 PM Call
+11:43:00 AM Call
+2:09:00 PM Call
+10:05:00 AM Call
+10:37:00 AM Call
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+6:11:00 PM 1159B)
+9:06:00 AM Call
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+10:12:00 PM 1159B)
+2:32:00 PM Call
+6:38:00 PM Call
+D
+E
+F
+From
+To
+Jeffrey
+hafrav Fostain,
+Jeffray Epstein
+Call
+length/message
+info/Passengers
+F would like to
+work@4:00 PM if
+possible [Alex is
+scheduled for 5:00
+today] the movie is @
+7:30 (no signature)
+Jeffrey Epstein, David
+Mullen, D
+-, Barok, 1 SS
+Secret Service, 1 SS
+Secret Service, 1
+Fomale, 1 Female
+
+
+1
+4 italics
+5 Date
+335
+12/16/2004
+337
+12/16/2004
+338
+12/16/2004
+339
+12/16/2004
+340
+12/16/2004
+341
+12/17/2004
+342
+343
+344
+345
+346
+347
+348
+12/17/2004
+12/18/2004
+12/19/2004
+12/20/2004
+12/20/2004
+12/20/2004
+349
+12/21/2004
+350
+351
+12/21/2004
+352
+12/21/2004
+353: 12/21/2004
+354
+12/21/2004
+355
+12/29/2004
+356
+12/29/2004
+357
+358
+359
+360
+12/30/2004
+12/30/2004
+12/30/2004
+B
+C
+D
+E
+Time
+Event
+12:47:00 PM Call
+12:49:00 PM Call
+12:49:00 PM Call
+4:44:00 PM Call
+5:12:00 PM Call
+6:29:00 PM Call
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+10:35:00 PM 1159B)
+11:23:00 AM Call
+7:38:00 PM Call
+12:22:00 PM Call
+12:26:00 PM Call
+4:53:00 PM Call
+Epstein's Flight
+departs from PBIA
+Gulfstream G-
+8:44:00 AM
+(1159B)
+2:24:00 PM Call
+3:10:00 PM Call
+3:12:00 PM Call
+3:22:00 PM Call
+4:49:00 PM Call
+11:15:00 PM Call
+12/30/2004
+10:09:00 AM Call
+11:07:00 AM Call
+11:08:00 AM Call
+From
+To
+Jeffrey Epstein
+Alexandra H Call
+Turns 18
+F
+Call
+length/message
+info/Passengers
+Jeffrey Epstein, L
+Ghislaine Maxwell,
+0:03:00
+
+
+1
+3
+4 italics
+B
+D
+E
+F
+5 Date
+136T
+362
+363
+12/30/2004
+12/30/2004
+364
+365
+366
+367
+368
+1/1/2005
+1/2/2005
+1/2/2005
+1/2/2005
+1/2/2005
+369
+370
+371
+372
+373
+374
+375
+376
+377
+378
+379
+380
+381
+382
+383
+384
+1/3/2005
+1/5/2005
+1/5/2005
+1/5/2005
+1/5/2005
+1/5/2005
+1/5/2005
+1/5/2005
+1/5/2005
+1/5/2005
+1/5/2005
+1/5/2005
+1/5/2005
+1/6/2005
+1/6/2005
+Time
+Event
+4:25:00 PM Call
+10:30:00 PM/Call
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+4:09:00 PM 1159B)
+4:01:00 PM Text Message
+8:20:00 PM/Call
+8:52:00 PM/Call
+8:53:00 PM|Call
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+4:04:00 PM 1159B)
+12:40:00 PM Call
+1:14:00 PM Call
+1:19:00 PM Call
+1:51:00 PM Call
+1:52:00 PM/Call
+1:53:00 PM Call
+2:37:00 PM Call
+3:10:00 PM Call
+4:42:00 PM Call
+6:16:00 PM Call
+9:25:00 PM Call
+10:16:00 PM Call
+12:24:00 AM Call
+11:19:00 AM Call
+From
+To
+Call
+length/message
+info/Passengers
+David
+Mullen,
+Jean Luc Brunel
+100
+Jeffrey Epstein
+Ghislaine
+Maxwell, David Mullen
+D:01:00
+
+
+1
+3
+First calia
+4 italics
+5 Date
+385
+386
+1/6/2005
+B
+C
+D
+E
+F
+Time
+Call
+length/message
+info/Passengers
+387
+388
+389
+390
+391
+392
+393
+394
+1/6/2005
+1/7/2005
+1/9/2005
+1/9/2005
+1/10/2005
+1/10/2005
+1/11/2005
+1/11/2005
+395
+3961
+397
+398
+399
+400
+401
+402
+403
+404
+405
+406
+407
+408
+1/11/2005
+1/11/2005
+1/11/2005
+1/11/2005
+1/14/2005
+1/14/2005
+1/15/2005
+1/15/2005
+1/15/2005
+1/16/2005
+1/16/2005
+1/16/2005L
+Event
+2:39:00 PM Call
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+11:50:00 PM 1159B)
+2:14:00 PM Call
+9:15:00 PM Call
+10:12:00 PM Call
+8:24:00 PM Call
+8:25:00 PM Call
+11:00:00 AM Call
+11:45:00 AM Call
+Epstein's Flight
+departs from PBIA
+8:03:00 PM (Boeing 727)
+5:26:00 PM Call
+5:27:00 PM Call
+9:01:00 PM Call
+1:22:00 PM Call
+Epstein's Flight
+arrives at PBIA
+6:18:00 PM (Boeing 727)
+12:47:00 PM Call
+8:40:00 PM Call
+8:40:00 PM Call
+4:25:00 PM Call
+6:57:00 PM Call
+7:05:00 PM Call
+From
+To
+Jeffrey Epstein, |
+Jeffrey Epstein, S
+1 Female. 1
+Female
+Neffrey Enstein
+
+
+1
+3
+4 Italics-
+5 Date
+B
+D
+E
+F
+Time
+409
+410
+411
+412
+413
+414
+415
+416
+417
+418
+1/17/2005
+1/17/2005
+1/18/2005
+1/18/2005
+1/18/2005
+1/19/2005
+1/19/2005
+1/19/2005
+419
+420
+421
+422
+423
+424
+425
+426
+427
+428
+429
+430
+431
+1432
+1/19/2005
+1/20/2005
+1/20/2005
+1/21/2005
+1/23/2005
+1/24/2005
+1/24/2005
+1/24/2005
+1/24/2005
+1/24/2005
+1/24/2005
+1/24/2005
+1/24/2005
+1/24/2005
+Event
+Epstein's Flight
+departs from PBIA
+5:10:00 PM (Boeing 727)
+7:26:00 PM Call
+11:26:00 AM Call
+1:24:00 PM Call
+7:25:00 PM Call
+4:02:00 PM Call
+4:25:00 PM Call
+8:36:00 PM Call
+Epstein's Flight
+arrives at PBIA
+11:52:00 PM (Boeing 727)
+12:32:00 PM Call
+5:18:00 PM Call
+1:13:00 PM Call
+3:10:00 PM Call
+10:24:00 AM Call
+10:26:00 AM Call
+10:27:00 AM Call
+10:36:00 AM Call
+10:43:00 AM Call
+3:21:00 PM Call
+5:16:00 PM Call
+6:40:00 PM Call
+9:46:00 PM/Call
+From
+To
+Call
+length/message
+info/Passengers
+Jeffrey Epstein
+Cellen, David Mullen
+, Tod Myster, 1
+pax, 1 pax
+Jeffrey Epstein
+
+
+-
+3
+4 Italics-
+5 Date
+433
+434
+435
+436
+1/24/2005
+1/25/2005
+1/25/2005
+1/25/2005
+437
+1/25/2005
+B
+C
+Time
+Event
+10:11:00 PM Call
+11:59:00 AM Call
+12:01:00 PM Call
+12:40:00 PM Call
+12:45:00 PM Message Pad
+438
+439
+440
+441
+442
+443
+444
+445
+446
+447
+448
+449
+450|
+451
+452
+453
+454
+1/26/2005
+1/26/2005
+1/26/2005
+1/26/2005
+1/26/2005
+1/26/2005
+1/26/2005
+1/26/2005
+1/27/2005
+1/28/2005
+1/28/2005
+1/30/2005
+1/30/2005
+1/30/2005
+1/30/2005
+1/30/2005
+12:00:00 AM Message Pad
+6:59:00 AM Call
+7:07:00 AM Call
+7:13:00 AM Call
+1:20:00 PM Message
+1:23:00 PM Call
+2:14:00 PM Call
+4:14:00 PM Call
+Epstein's Flight
+departs from PBIA
+7:46:00 PM (Boeing 727)
+1:13:00 PM Call
+7:42:00 PM Call
+2:53:00 PM Call
+5:02:00 PM Call
+6:28:00 PM Call
+6:42:00 PM Call
+6:59:00 PM Call
+D
+E
+F
+From
+To
+Fostein
+Epstein
+Jeffrey
+J.E.
+J.E.
+LEpstein
+Epstein
+Cell
+Call
+length/message
+info/Passengers
+Jeffrey
+Jeffrey
+Called again about
+working today (No
+signature)
+She is asking If you
+want her to work
+today? The best time
+will be 2 pm or 9:45 PM
+(No signature)
+She said that instead of
+1:45 she'll be at 2:00
+pm (AR)
+Jeffrey
+deffrey
+Juli B
+Jeffrey
+Epstein
+
+
+1
+3
+First CasE
+4 Italics-...
+5 Date
+455
+456
+457
+458
+459
+460
+461
+462
+463
+1/30/2005
+1/30/2005
+2/2/2005
+2/2/2005
+2/2/2005
+2/2/2005
+2/2/2005
+212/2005
+B
+C
+D
+E
+F
+Time
+Event
+7:40:00 PM Call
+7:42:00 PM Call
+11:03:00 AM Call
+11:07:00 AM Call
+2:03:00 PM Call
+2:52:00 PM Call
+2:53:00 PM Call
+5:52:00 PM Call
+From
+To
+TCall
+length/message
+info/Passengers
+464
+465
+466
+467
+468
+469
+470|
+471
+472
+473
+474
+475
+476
+477
+478L
+213/2005
+2/3/2005
+2/3/2005
+2/3/2005
+213/2005
+2/3/2005
+2/3/2005
+213/2005
+2/3/2005
+2/3/2005
+2/3/2005
+2/3/2005
+213/2005
+2/3/2005
+214/2005L
+Epstein's Flight
+arrives at PBIA
+12:40:00 AM (Boeing 727)
+11:33:00 AM Call
+12:42:00 PM Call
+1:03:00 PM Call
+1:17:00 PM Call
+5:58:00 PM Call
+6:25:00 PM Call
+6.26:00 PM Call
+6:27:00 PM Call
+6:33:00 PM Call
+6:38:00 PM Call
+7:17:00 PM Call
+7:53:00 PM Call
+8:01:00 PM Call
+7:31:00 AM Call
+Jeffrey Epstein
+Jean Luc
+Brunnel, David Mullen,
+Female Female, Female
+0:03:00
+0:04:00
+0:04:00
+0:10:00
+
+
+B
+1
+3
+Fintenses
+4 Halics
+5 Date
+479
+480
+481
+482
+483
+484
+485
+486
+487
+488
+489
+490
+491
+492
+493
+494
+495
+496
+497
+498
+499
+500
+501
+502
+503
+214/2005|
+214/2005|
+2/5/2005
+2/5/2005
+2/5/2005
+2/6/2005
+2/7/2005
+Time
+Event
+1:08:00 PM Call
+1:09:00 PM Call
+3:45:00 PM Call
+7:24:00 PM Call
+7:25:00 PM Call
+12:18:00 AM Call
+Epstein's Flight
+departs from PBIA
+5:39:00 AM (Boeing 727)
+2/7/2005
+2/7/2005
+217/2005
+217/2005
+217/2005
+2/9/2005
+219/2005
+2/9/2005
+2/9/2005
+2/10/2005
+2/10/2005
+2/10/2005
+2/10/2005
+2/10/2005
+2/10/2005
+2/10/2005
+2/10/2005
+9:01:00 AM Call
+11:48:00 AM Call
+1:11:00 PM Call
+2:58:00 PM Call
+3:10:00 PM Call
+9:46:00 AM Call
+10:01:00 AM Call
+11:30:00 AM Call
+11:57:00 AM Call
+4:09:00 PM Call
+4:12:00 PM Call
+4:15:00 PM Call
+4:33:00 PM Call
+4:56:00 PM Call
+4:56:00 PM Call
+5:25:00 PM Call
+9:26:00 PM Call
+D
+E
+F
+From
+length/message
+info/Passengers
+0:03:00
+David Mullen, Jansen,
+0:05:00
+
+
+3
+First GE
+4 Italics
+5 Date
+504
+B
+C
+Time
+505
+506
+507
+508
+509
+510
+511
+512
+513
+514
+515
+516
+517
+518
+519
+520
+521
+522
+523
+524
+525
+526
+527
+528)
+2/10/2005
+2/11/2005
+2/11/2005
+2/11/2005
+2/11/2005
+2/11/2005
+2/11/2005
+2/11/2005
+2/12/2005
+2/12/2005
+2/12/2005
+2/12/2005
+2/12/2005
+2/12/2005
+2/12/2005
+2/12/2005
+2/12/2005
+2/12/2005
+2/13/2005
+2/13/2005
+2/13/2005
+2/13/2005
+2/14/2005
+2/15/2005
+Event
+Epstein's Flight
+arrives at PIA
+11:54:00 PM (Boeing 727)
+3:12:00 PM Call
+3:36:00 PM Call
+3:38:00 PM Call
+3:51:00 PM Call
+3:53:00 PM Call
+5:01:00 PM Call
+11:04:00 PM Call
+12:02:00 AM Call
+12:12:00 AM Call
+10:51:00 AM Call
+10:58:00 AM Call
+11:00:00 AM Call
+11:31:00 AM Call
+11:32:00 AM Call
+1:51:00 PM Call
+3:05:00 PM Call
+4:23:00 PM Call
+9:44:00 AM Call
+11:07:00 AM Call
+4:58:00 PM Call
+11:14:00 PM Call
+2:58:00 PM Call
+7:25:00 AM Call
+D
+From
+To
+Epstein
+F
+Call
+length/message
+info/Passengers
+Jeffrey
+
+
+1
+3
+4 Italics
+B
+C
+5 Date
+1529
+2/15/2005
+530
+2/15/2005
+531
+2/15/2005
+532
+2/15/2005
+533
+2/15/2005
+534
+535
+536
+537
+538
+539
+540
+541
+542
+543
+544
+545
+2/15/2005
+2/15/2005
+2/15/2005
+2/15/2005
+2/15/2005
+2/16/2005
+2/16/2005
+2/16/2005
+2/21/2005
+2/21/2005
+2/21/2005
+Time
+Event
+9:10:00 AM Call
+12:48:00 PM Call
+1:16:00 PM Call
+3:43:00 PM Call
+3:59:00 PM Call
+Epstein's Flight
+departs from PBIA
+5:42:00 PM (Boeing 727)
+8:31:00 PM Call
+10:11:00 PM Cali
+10:13:00 PM Call
+10:39:00 PM Call
+2:29:00 PM Call
+5:49:00 PM Call
+6:38:00 PM Call
+2:14:00 PM Call
+6:11:00 PM Call
+6:26:00 PM Call
+546
+2/21/2005
+547
+548
+2/22/2005
+Epstein's Flight
+arrives at PBIA
+8:05:00 PM (Boeing 727)
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+10:37:00 AM 1159B)
+D
+E
+F
+From
+Call
+length/message
+info/Passengers
+0:04:00
+Jeffrey Epstein, Ghislaine
+Maxwell,
+0:03:00
+James Stanley, Sophia
+Stainly, Alexa Stanley.
+Stanley
+James
+Stanley, Sophia Stanley,
+Alexa Stanley, Stanley.
+David Mullen
+
+
+1
+3
+Pistole
+4 italics
+B
+5 Date
+/Time
+549
+550
+551
+552
+553
+554
+555
+556
+557
+558
+559
+560
+561
+562
+563
+564
+565
+566
+567
+568
+569
+570
+571
+572
+2124/2005
+2/25/2005
+2/25/2005
+2/25/2005
+2/25/2005
+2/25/2005
+2/25/2005
+2/25/2005
+2/26/2005
+2/26/2005
+2/26/2005
+2/26/2005
+2/26/2005
+2/26/2005
+2/26/2005
+2/26/2005
+2126/2005
+2/26/2005
+2/26/2005
+2/26/2005
+2/26/2005
+2/26/2005
+2/26/2005
+2/27/2005
+Event
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+3:40:00 PM 1159B)
+8:13:00 AM Call
+8:14:00 AM Call
+1:08:00 PM Call
+1:08:00 PM Call
+6:11:00 PM Call
+6:13:00 PM Call
+6:18:00 PM Call
+12:41:00 AM Call
+2:02:00 AM Call
+10:10:00 AM Call
+10:11:00 AM Call
+10:12:00 AM Call
+10:13:00 AM Call
+10:15:00 AM Call
+10:20:00 AM Call
+10:42:00 AM Call
+10:44:00 AM Call
+10:55:00 AM Call
+11:09:00 AM Call
+10:20:00 PM Call
+10:30:00 PM Call
+11:08:00 PM Call
+11:36:00 AM Call
+From
+581.270-7024
+E
+F
+To
+Call
+length/message
+info/Passengers
+Jeffrey Epstein
+Jeffrey
+Epstein
+
+
+1
+3
+First cal
+4 Italics-Ammun
+B
+D
+E
+F
+5 Date
+1573
+574
+2128/2005
+2/28/2005
+Time
+Event
+12:09:00 PM Call
+12:28:00 PM Call
+From
+To
+Fostein
+Epstein
+575
+576
+577
+578
+579
+580
+581
+582
+583
+584
+585
+586
+587
+588
+1589
+2/28/2005
+2128/2005
+2128/2005
+2128/2005
+3/1/2005
+3/1/2005
+3/1/2005
+3/1/2005
+3/4/2005
+3/4/2005
+3/4/2005
+3/4/2005
+3/4/2005
+12:30:00 PM Message Pad
+2:34:00 PM Call
+2:41:00 PM Call
+3:45:00 PM Call
+9:03:00 AM Call
+9:14:00 AM Call
+Epstein's Flight
+departs from PBIA
+10:50:00 AM (Boeing 727)
+6:13:00 PM Call
+1:07:00 PM Call
+1:07:00 PM Call
+5:21:00 PM Call
+5:22:00 PM Call
+6:14:00 PM Call
+Waffcon
+Epstein
+Call
+length/message
+info/Passengers
+Jeffrey
+Jeffrey
+She is wondering 101:00
+2:30 is OK cuz she
+needs to stay in school
+(no signature)
+Jeffrey
+0:03:00
+Jeffrey Epstein, Ghislaine
+Maxwell, David Mullen,
+590
+591
+592
+593
+594
+595
+3/4/2005
+3/5/2005
+3/7/2005
+3/7/2005
+3/7/2005
+3/8/2005
+Epstein's Flight
+arrives at PBIA
+11:45:00 PM (Boeing 727)
+12:52:00 AM Call
+9:30:00 AM Call
+9:45:00 AM Call
+11:01:00 AM Call
+7:37:00 AM Call
+
+
+1
+3 Wales
+5 Date
+596
+597
+598
+599
+600
+601
+602
+603
+604
+605
+606
+607
+608
+609
+610
+611
+612
+613
+614
+615
+616
+617
+618
+619
+620
+3/8/2005
+3/8/2005
+3/8/2005
+3/8/2005
+3/8/2005
+3/8/2005
+3/8/2005
+3/8/2005
+3/9/2005
+3/9/2005
+3/9/2005
+3/9/2005
+3/9/2005
+3/9/2005
+3/10/2005
+3/10/2005
+3/10/2005
+3/10/2005
+3/10/2005
+3/10/2005
+3/10/2005
+3/10/2005
+3/10/2005
+3/10/2005
+B
+D
+E
+F
+Time
+Event
+Epstein's Flight
+departs from PBIA
+11:42:00 AM (Boeing 727)
+6:52:00 PM Call
+7:20:00 PM Call
+7:26:00 PM Call
+7:38:00 PM Call
+7:48:00 PM Call
+11:22:00 PM Call
+11:25:00 PM Call
+9:26:00 AM Call
+12:13:00 PM Call
+12:14:00 PM Call
+12:15:00 PM Call
+7:08:00 PM Call
+9:30:00 PM Call
+7:36:00 AM Call
+8:04:00 AM Call
+8:12:00 AM Call
+10:58:00 AM Call
+11:00:00 AM Call
+3:45:00 PM Call
+5:46:00 PM Call
+6:47:00 PM Call
+7:18:00 PM Call
+7:19:00 PM Call
+From
+To
+length/message
+info/Passengers
+Lesten
+Epstein
+Jeffrey
+Jeffrey
+10
+0
+1O
+Jeffrey
+Epstein
+
+
+1
+3 Malices
+B
+5 Date
+621
+622
+623
+624
+625
+626
+627
+628
+629
+630
+631
+632
+633
+634
+635
+636
+637
+638
+639
+640
+641
+642
+643
+644
+645
+646
+Time
+Event
+3/11/2005
+3:59:00 PM Call
+3/11/2005
+5:50:00 PM Call
+3/12/2005
+11:44:00 AM Call
+3/12/2005
+11:50:00 AM Call
+3/12/2005
+3:42:00 PM Call
+3/12/2005
+6:37:00 PM Call
+3/13/2005
+11:17:00 AM Call
+3/14/2005
+11:31:00 AM Call
+3/14/2005
+12:36:00 PM Call
+3/14/2005
+2:11:00 PM/Call
+3/14/2005
+2:25:00 PM Call
+3/14/2005
+2:51:00 PM Call
+3/14/2005
+3:33:00 PM Call
+3/14/2005
+10:48:00 PM Call
+3/14/2005
+Petty Cash
+3/15/2005
+3/15/2005|
+3/15/2005
+3/15/2005
+3/15/2005
+3/16/2005
+3/16/2005
+3/16/2005
+3/16/2005
+3/18/2005
+6:27:00 AM Call
+1:08:00 PM Call
+5:18:00 PM Call
+6:23:00 PM Call
+J.B. Petty Cash
+1:56:00 PM Call
+2:25:00 PM Call
+2:28:00 PM Call
+3:00:00 PM Call
+Epstein's Fligh
+arrives at PBIA
+12:48:00 PM (Boeing 727)
+D
+E
+F
+From
+To
+Jeffrey
+Epstein
+Epstein
+[Epstein
+Jeffrey
+Jeffrey
+Juli B
+Cell
+Cash for Alexandria
+Alexandria
+Cash req. by JE
+Call
+length/message
+info/Passengers
+$400.00
+$300.00
+Jeffrey Epstein, Ghislaine
+Maxwell,
+
+
+1
+2
+Epstein in town
+3
+4 Italics-/
+B
+C
+5 Date
+647
+648
+649
+650
+651
+652
+653
+654
+655
+656
+657
+658
+659
+660
+661
+662
+663
+664
+665
+666
+667
+668
+669
+670
+671
+3/22/2005
+3/29/2005
+3/29/2005
+3/29/2005
+3/29/2005
+3/29/2005
+3/29/2005
+3/29/2005
+3/31/2005
+3/31/2005
+3/31/2005
+3/31/2005
+3/31/2005
+3/31/2005
+3/31/2005
+4/1/2005
+4/1/2005
+4/1/2005
+4/1/2005
+4/3/2005
+4/4/2005
+4/5/2005
+4/5/2005
+Time
+Event
+Epstein's Flight
+departs from PBIA
+1:07:00 PM (Boeing 727)
+7:02:00 AM Call
+7:03:00 AM Call
+7:59:00 AM Call
+11:52:00 AM Call
+2:45:00 PM Call
+2:47:00 PM Call
+3:09:00 PM Call
+9:26:00 AM/Call
+9:31:00 AM Call
+9:53:00 AM|Call
+10:51:00 AM Call
+Epstein's Flight
+arrives at PBIA
+11:10:00 AM (Boeing 727)
+11:45:00 AM Call
+2:56:00 PM/Call
+9:39:00 AM Call
+9:39:00 AM Call
+10:37:00 AM Call
+3:30:00 PM Call
+11:36:00 AM Call
+9:27:00 AM Call
+9:26:00 AM Call
+9:28:00 AM Call
+D
+E
+F
+From
+To
+Jeffrey
+Epstein
+Call
+length/message
+info/Passengers
+female,
+1 female
+0:03:00
+Jeffrey Epstein, Ghislaine
+Maxwell,
+
+
+1
+3
+4 Italics
+5 Date
+1572
+673
+674
+4/5/2005|
+4/5/2005
+4/5/2005
+B
+C
+D
+E
+F
+675
+6761
+677
+678
+679
+680
+681
+682
+683
+684
+685
+686
+687
+688
+689
+690
+691
+692
+693
+1694
+4/6/2005
+4/6/2005
+4/6/2005
+4/6/2005
+4/8/2005
+4/8/2005
+4/8/2005
+4/8/2005
+4/9/2005
+4/9/2005
+419/2005
+4/9/2005
+4/9/2005
+4/9/2005
+4/9/2005
+4/9/2005
+4/11/2005
+4/11/2005
+Time
+Event
+9:28:00 AM Call
+9:29:00 AM Call
+10:06:00 AM Call
+Epstein's Flight
+departs from PBIA
+10:54:00 AM (Boeing 727)
+3:03:00 PM Call
+4:50:00 PM Call
+Trash Pull (Jeffrey
+Epstein Stationary)|
+2:04:00 PM Call
+2:49:00 PM Call
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+10:02:00 PM 1159B)
+Trash Pull
+(Ghislaine Maxwell
+Stationary)
+9:48:00 AM Call
+9:48:00 AM Call
+9:49:00 AM Call
+11:13:00 AM Call
+11:14:00 AM Call
+11:17:00 AM Call
+11:18:00 PM Call
+11:19:00 PM Call
+4:10:00 PM Call
+5:13:00 PM Call
+From
+To
+Call
+length/message
+info/Passengers
+1, David Mullen,
+(Multiple girls' names
+and times)
+0:06:00
+York + East 63 = 3rd
+(front) [Friday]
+tomorrow or Sun
+11am
+
+
+3
+Eust cal
+4 Italics-/
+5 Date
+695
+696
+697
+698
+699
+4/12/2005
+4/15/2005
+4/15/2005
+4/15/2005
+B
+C
+Time
+Event
+Epstein's Flight
+departs from PBIA
+(Gulfstream G.
+6:20:00 PM 1159B)
+9:02:00 AM Call
+9:31:00 AM Call
+9:37:00 AM Call
+700
+701
+702
+703
+704
+705
+706
+707
+708
+709
+710
+711
+712
+713
+714
+4/15/2005
+4/27/2005
+4/27/2005
+4/28/2005
+4/28/2005
+4/28/2005
+4/28/2005
+4/28/2005
+4/28/2005
+4/29/2005
+4/29/2005
+4/29/2005
+4/29/2005
+4/29/2005
+Trash Pull (727
+Stationary)
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G
+11:58:00 AM 1159B)
+11:09:00 PM Call
+6:38:00 AM Call
+10:44:00 AM Text Message
+11:16:00 AM Call
+11:17:00 AM Call
+3:40:00 PM Call
+3:41:00 PM Call
+7:01:00 AM Call
+9:22:00 AM Call
+11:38:00 AM Call
+12:05:00 PM Call
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+8:22:00 PM 1159B)
+D
+E
+F
+From
+To
+Call
+length/message
+info/Passengers
+Jeffrey Epstein
+Friday 5:30
+-(LM)
+Thur
++ Mon
+Jeffrey Epstein, Ghislaine
+Maxwell
+male, 1 female
+Enstein
+Jeffrey
+ch
+B
+
+
+1
+3
+4 Italics-
+B
+D
+E
+F
+5 Date
+715
+716
+717
+718
+719
+720
+721
+722
+723
+724
+725
+726
+727
+728
+729
+730
+Time
+4/29/2005
+4/29/2005
+4/30/2005
+5/2/2005
+5/2/2005
+5/2/2005
+5/2/2005
+5/2/2005
+5/5/2005
+5/5/2005
+5/5/2005
+5/5/2005
+5/5/2005
+5/6/2005
+Event
+8:50:00 PM Call
+9:53:00 PM Call
+12:09:00 AM Call
+10:02:00 AM Call
+3:31:00 PM Call
+4:14:00 PM Call
+4:16:00 PM Call
+5:26:00 PM Call
+8:09:00 AM Call
+9:23:00 AM Call
+9:25:00 AM Call
+10:28:00 PM Call
+10:30:00 PM Call
+7:45:00 AM Call
+From
+To
+Call
+length/message
+info/Passengers
+0:03:00
+731
+732
+733
+734
+735
+5/6/2005
+5/9/2005
+5/9/2005
+5/10/2005
+5/10/2005
+736
+737
+738
+5/10/2005
+5/13/2005
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+11:27:00 PM 1159B)
+2:37:00 PM Call
+4:29:00 PM Call
+9:23:00 AM Call
+9:49:00 AM Call
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+4:34:00 PM 1159B)
+4:11:00 PM Call
+1 female, David Mullen,
+Larry Morrison
+David Mamen,
+
+
+1
+3
+4 Italics-
+5 Date
+739
+740
+741
+742
+743
+744
+745
+746
+747
+748
+749
+750
+751
+752
+753
+754
+755
+5/13/2005
+5/19/2005
+5/19/2005
+5/19/2005
+5/20/2005
+5/20/2005
+5/20/2005
+5/21/2005
+5/21/2005
+5/21/2005
+5/21/2005
+5/21/2005
+5/21/2005
+5/21/2005
+5/21/2005
+5/21/2005
+B
+756
+757
+758
+759
+760
+761
+762
+5/24/2005
+5/29/2005
+5/29/2005
+5/30/2005
+5/30/2005
+Time
+Event
+5:08:00 PM Call
+12:44:00 PM Call
+6:05:00 PM Call
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+10:12:00 PM 1159B)
+2:15:00 PM Call
+2:15:00 PM Call
+2:15:00 PM Call
+9:36:00 AM Call
+10:15:00 AM Call
+1:31:00 PM Call
+3:12:00 PM Call
+3:19:00 PM Call
+3:44:00 PM Call
+4:18:00 PM Call
+4:18:00 PM Call
+6:40:00 PM Call
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+11:14:00 AM 1159B)
+11:32:00 AM Call
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+6:07:00 PM 1159B)
+7:01:00 PM Call
+7:09:00 PM Call
+D
+E
+F
+From
+ITo
+Call
+length/message
+info/Passengers
+n d
+---Jellrey
+Epstein
+5
+5
+5
+5
+Jeffrey Epstein
+Jeffrey Epstein, David
+Mullen...
+
+
+1
+3
+4 Italics
+B
+D
+E
+F
+5 Date
+1763
+764
+765
+5/30/2005
+6/1/2005
+6/1/2005
+766
+767
+768
+769
+770
+771
+772
+773
+774
+775
+776
+777
+778
+779
+6/1/2005
+6/3/2005
+6/3/2005
+6/3/2005
+6/3/2005
+6/3/2005
+6/3/2005
+6/3/2005
+6/7/2005
+6/8/2005
+6/8/2005
+6/8/2005
+Time
+Event
+7:09:00 PM Call
+12:18:00 PM Call
+1:55:00 PM/Call
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+4:31:00 PM 1159B)
+1:20:00 PM Call
+3:08:00 PM Call
+5:40:00 PM Call
+7:48:00 PM Call
+7:49:00 PM Call
+11:23:00 PM Call
+11:55:00 PM Call
+10:28:00 AM Call
+11:52:00 AM Call
+12:42:00 PM Call
+7:36:00 PM Call
+From
+To
+Call
+length/message
+info/Passengers
+780
+781
+782
+783
+784
+785
+6/8/2005
+6/9/2005
+6/9/2005
+6/9/2005
+6/9/2005
+6/9/2005
+Epstein's Flight
+arrives at PBIA
+10:33:00 PM (Boeing 727)
+12:22:00 PM Call
+1:34:00 PM Call
+1:35:00 PM Call
+6:12:00 PM Call
+7:51:00 PM Call
+Jeffrey Epstein
+] David Mullen,
+1, Mark Zeff,
+Doug Shuttle,
+
+
+1
+3
+First calle
+4 Italic
+5 Date
+1786
+787
+788
+789
+790
+791
+792
+793
+794
+795
+796
+797
+798
+799
+800
+801
+802
+803
+804
+805
+806
+6/9/2005
+6/10/2005
+6/10/2005
+6/10/2005
+6/11/2005
+6/11/2005
+6/11/2005
+6/11/2005
+6/11/2005
+6/14/2005
+6/14/2005
+6/14/2005
+6/14/2005
+6/14/2005
+6/17/2005
+6/17/2005
+6/17/2005
+6/18/2005
+6/18/2005
+6/20/2005
+B
+807
+808
+809
+8101
+6/20/2005
+6/20/2005
+Time
+Event
+8:55:00 PM Call
+10:24:00 AM Text Message
+9:22:00 PM Call
+9:55:00 PM Text Message
+12:49:00 AM Call
+6:39:00 AM Text Message
+8:46:00 AM Call
+8:46:00 AM Call
+9:34:00 AM Call
+11:39:00 AM Call
+11:39:00 AM Call
+1:17:00 PM Call
+3:31:00 PM Call
+3:40:00 PM Call
+4:56:00 PM Call
+7:08:00 PM Call
+7:17:00 PM Call
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+10:35:00 AM 1159B)
+10:58:00 PM Call
+4:39:00 PM/Call
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+4:39:00 PM 1159B)
+6:00:00 PM Call
+D
+E
+F
+From
+To
+Call
+length/message
+info/Passengers
+Jeffrey
+Epstein
+Neffrey Enstein.
+remale?
+
+
+1
+2
+Epstein in town
+3
+4 Italics
+5 Date
+811
+812
+813
+814
+815
+816
+817
+818
+819
+820
+821
+822
+823
+824
+825
+826
+827
+828
+829
+830
+6/30/2005
+7/5/2005
+7/6/2005
+717/2005
+7/8/2005
+7/15/2005
+7/16/2005
+7/17/2005
+7/17/2005
+7/18/2005
+7/22/2005
+7/22/2005
+7/23/2005
+7/25/2005
+7/25/2005
+7/25/2005
+B
+D
+E
+F
+Time
+831
+832
+7/25/2005
+Event
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+10:01:00 PM 1159B)
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+11:29:00 AM 1159B)
+12:31:00 PM Call
+11:19:00 AM Call
+9:45:00 AM Call
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+12:19:00 AM 1159B)
+11:53:00 AM Call
+1:10:00 PM Call
+5:15:00 PM Call
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+1:49:00 PM 1159B)
+12:33:00 AM Call
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+11:26:00 PM 1159B)
+11:14:00 AM Call
+1:05:00 AM Call
+1:06:00 AM Call
+1:14:00 PM Call
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+5:09:00 PM 1159B)
+From
+To
+Call
+length/message
+_info/Passengers
+Female
+male, Dana Bums
+0:05:00
+Jeffrey Epstein:
+Jeffrev Enstein.
+
+
+2
+3
+4
+italics
+Epstein in town
+5 Date
+833
+8/18/2005
+B
+Time
+834
+835
+836
+837
+838
+839
+840
+8/22/2005
+9/1/2005
+9/3/2005
+9/4/2005
+9/4/2005
+841
+842
+843
+844
+845
+846
+847
+848
+849
+850
+851
+852
+853
+9/5/2005
+9/9/2005
+9/9/2005
+9/9/2005
+9/9/2005|
+9/9/2005|
+9/9/2005
+9/11/2005
+9/11/2005
+9/11/2005
+Event
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+3:19:00 PM 1159B)
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+3:57:00 PM 1159B)
+1:49:00 PM Text Message
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+2:12:00 PM
+1159B)
+2:08:00 PM Message pad
+3:40:00 PM
+Message pad
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+3:59:00 PM 1159B)
+Epstein's Flight
+arrives at PBIA
+Gulfstream G-
+12:22:00 AM 1159B)
+4:49:00 PM Call
+5:01:00 PM Call
+8:59:00 PM Call
+9:25:00 PM Call
+9:46:00 PM Call
+15:00 AM Message pa
+pstein's Fligh
+departs from PBIA
+(Gulfstream G-
+2:06:00 PM 1159B)
+7:57:00 PM Call
+D
+E
+From
+To
+Mr. J. Epstein
+J.E.
+J.E.
+F
+Call
+length/message
+info/Passengers
+Jeffrey Epstein, David
+Mullen,
+Telephoned (L)
+Telephoned (J)
+Jeffrey Epstein, Ghislane
+Maxwell,
+Female
+Jeffrey Epstein, l
+0:03:00
+(No
+I got a car for
+Signature
+
+
+1
+2
+Epstein in town
+3
+4 Italics
+B
+C
+D
+E
+F
+5 Date
+Time
+854
+9/18/2005
+855
+856
+9/20/2005
+Event
+Epstein's Flight
+arrives at PBIA
+(Gulfstream G-
+9:36:00 PM 1159B)
+Epstein's Flight
+departs from PBIA
+(Gulfstream G-
+8:16:00 PM 1159B)
+From
+To
+Call
+length/message
+info/Passengers
+Neffrev Eostein.
+Jeffrey Epstein
+857
+858
+859
+9/23/2005
+10/11/2005
+10/20/2005
+Trash Pull (Jeffrey
+Epstein Stationary)
+Trash Pull
+Trash Pull
+(Scribblings
+w/addresses, times.
+$247) JE - David
+Diagram w/handwritten
+mote 'Drawn bor
+high
+school transcripts
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/c830d509f6a9d959821220f38cab18b625a751cbcca6580d14bda8dce7468c13.receipt.json b/vision-fixhub/ds9-unparsed-05/c830d509f6a9d959821220f38cab18b625a751cbcca6580d14bda8dce7468c13.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..97051772422cd6edf839f3cf2e1fa21d34b45486
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c830d509f6a9d959821220f38cab18b625a751cbcca6580d14bda8dce7468c13.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -6210,
+  "dataset": "marble-joined",
+  "doc_id": "c830d509f6a9d959821220f38cab18b625a751cbcca6580d14bda8dce7468c13",
+  "engine": "marble-apple-vision",
+  "event_count": 39,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "569026cb5814aa2b998dcf1c61d57dd4bd2411d0530b533eb5ecebf2a3cfcb51",
+  "output_sha256": "8ce85e2dfb1a919d69e8315e8f176ac0eb89c04747876fd78eaa0643136d2468",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c8a7cf87ebfa9eaa01afe844e3fda694e489d5d57a815f14ce5a090867f6623c.md b/vision-fixhub/ds9-unparsed-05/c8a7cf87ebfa9eaa01afe844e3fda694e489d5d57a815f14ce5a090867f6623c.md
new file mode 100644
index 0000000000000000000000000000000000000000..cefde86dc9d57ec2d22efaa6679df76a1620c9ba
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c8a7cf87ebfa9eaa01afe844e3fda694e489d5d57a815f14ce5a090867f6623c.md
@@ -0,0 +1,429 @@
+Statements
+
+
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+GNMA GOVT BOND
+What's In This Statement
+Financial Summa......••••••••••••.....•..
+Transaction Detail
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2004
+THROUGH
+October 29, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Avallable
+LAST STATEMENT
+September 30, 2004
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN &
+6100 RED HOOK QUARTER STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Amount Credited
+Securities Bought
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+10,183,593.75
+$10,183,593.75
+-10,183,593.75
+$-10,183,593.75
+$0.00
+Income Summary
+Bond Purchase Int.
+THIS PERIOD
+0.00
+YEAR TO DATE
+-104,957.59
+SP The suren s four or ratanal purposes rear de Set revere date for portant iformation.
+10/30104;12:19 001
+
+
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEEMENT TATE
+TRANSACTION
+T0/14/04
+09/22/04
+BOUGHT
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+10/14/04 09/22/04 CANCEL BUY
+DESCRIPTION
+-NMA-30YR(FNMA)GTL
+SETT. 10/04
+ENMA 3OYR(FNMAJGTD
+SYMBOLGUSIP
+5A80009
+QUANTITY
+10,000,000
+PRICE
+101.83594
+
+-10,000,000
+101.83594
+TOTAL
+STOP
+****** End of Statement******
+027
+10/30/04:12:19 001
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD October 1,2004
+THROUGH
+October 29, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+September 30,2004
+DEBIT AMOUNT
+10,183,593.75
+CREDIT AMOUNT
+10,183,593.75
+$-10,183,593.75
+$10,183,593.75
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+10/30/04:12:19 001
+
+
+ACCOUNT EXECUTIVE
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+GNMA GOVT BOND
+What's In This Statement
+Financial Summ.............................
+Trades Not Yet Settled
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 1, 2004
+THROUGH
+September 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+August 31, 2004
+Hollandlol
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN &
+6100 RED HOOK QUARTER STE B3
+ST THOMAS VI 00802
+Income Summary
+THIS PERICO
+Bond Purchase Int.
+0.00
+YEAR TO DATE
+-104,957.59
+Trades Executed Pending Settlement
+SETLEMENT
+TRADE
+DATE
+TRANSACTION
+10/14/04
+09/22/04
+BOUGhT
+TOTAL
+DESCRIPTION
+FNMA-30YR(FNMA)GTD
+SETT, 10/04
+BEF 101208405506 m
+AS OF 0212210X
+The above trades do nat appear in any other section of this statement
+SIMBOLCUSP
+
+QUANTITY
+10,000,000.00
+PRICE
+101.8359
+DEBIT AMOUNT
+10,183,593.75
+$10,183,593.75
+CREDIT AMOUNT
+$0.00
+STOP
+****** End of Statement******
+SPC The remany to it real purpose end ended at a potame tomation..
+10/01/04:08:36 001
+V963
+
+
+2 of 2
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+10/01/04;08:36 001
+V963
+
+
+ACCOUNT EXECUTIVE
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+GNMA GOVT BOND
+What's In This Statement
+Financial Summay ..!
+Transaction Detail
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOO July 31,2004
+THROUGH
+August 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Avallable
+LAST STATEMENT
+January 30,2004
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN &
+6100 RED HOOK QUARTER STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Amount Credited
+Securities Bought
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+10,899,961.68
+$10,899,961.68
+-10,899,961.68
+$-10,899,961.68
+$0.00
+Income Summary
+THIS PERIOD
+Bond Purchase Int.
+0.00
+VEAR TO DATE
+-104,957.59
+SIP The surren s four or ratanal purposes red de Set revere date for portant iformation.
+09/01/04;09:08 001
+
+
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TATE
+TRANSACTION
+08/12/04
+08/10/04
+BOUGHT
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+08/12/04
+DELIVERED
+DESCRIPTION
+FEDL HOME LOAN MIG
+SERIES 218 CL PO
+DUE 02/01/2032
+REF #
+FEDL HOME LOAN MTG1
+SERIES 218 CL PO
+BS
+TOTAL
+STOP
+****** End of Statement******
+SYMBOL/CUSP
+QUANTITY
+13,222,091
+PRICE
+82.43750
+-13,222,091
+027
+09/01/04:09:08 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOO July 31,2004
+THROUGH
+August 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+January 30, 2004
+DEBIT AMOUNT
+10,899,961.68
+CREDIT AMOUNT
+10,899,961.68
+$-10,899,961.68
+$10,899,961.68
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+09/01/04:09:08 001
+
+
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+GNMA GOVT BOND
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 1, 2004
+THROUGH
+January 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+December 31, 2003
+What's In This Statement
+Financial Summary.......................
+Transaction Detail
+Your Messages
+1
+2
+2
+Hollandlol
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN &
+6100 RED HOOK QUARTER STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Amount Credited
+Securities Bought
+Dividends/Interest Charged
+Amount Debitod
+Closing Balance
+THIS PERIOD
+$0.00
+5,986,627.56
+$5,986,627.56
+-5,881,669.97
+-104,957.59
+- 5.986.627.5
+$0.00
+.....
+Income Summary
+THIS PERIOD
+Bond Purchase Int.
+-104,957.59
+YEAR TO DATE
+-104,957.59
+PC This summary is for informational purposes only. It is not intended as a tax docum
+This statement should he retained for your records. See revere cide for imortant intomat
+01/31/04;10:09 001
+V824
+
+
+Transaction Detail
+INVESTMENT ACTIVITY
+SATE EMENT TATE
+TRANSACTION
+01/30/04 01/15/04
+BOUGHT
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+01/30/04
+"DELIVERED
+DESCRIPTION
+GOVERNMENT NATIONAL MIG ASSN
+SERIES 2004-2 CLASS SB
+vE 116284 06 0
+BS
+.......
+VERNMENT NATIONAL MG AS
+50080 012 455 58
+6080
+TOTAL
+Your messages
+STOP
+****** End of Statement******
+SYMBOLICUSIP
+QUANTITY
+44,389,962
+ACCR. INT.
+44,389,962
+PRICE
+13.25000
+027
+01/31/04:10:09 001
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 1,2004
+THROUGH
+January 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Avallable
+LAST STATEMENT
+December 31, 2003
+DEBIT AMOUNT
+5,881,669.97
+104,957.59
+CREDIT AMOUNT
+*5,986,627.56
+$-5,986,627.56
+$5,986,627.56
+V924
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+01/31/04:10:09 001
+V924
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/c8a7cf87ebfa9eaa01afe844e3fda694e489d5d57a815f14ce5a090867f6623c.receipt.json b/vision-fixhub/ds9-unparsed-05/c8a7cf87ebfa9eaa01afe844e3fda694e489d5d57a815f14ce5a090867f6623c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e45ef06eda8b104098df4d7330b89d212ca0fb18
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c8a7cf87ebfa9eaa01afe844e3fda694e489d5d57a815f14ce5a090867f6623c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -511,
+  "dataset": "marble-joined",
+  "doc_id": "c8a7cf87ebfa9eaa01afe844e3fda694e489d5d57a815f14ce5a090867f6623c",
+  "engine": "marble-apple-vision",
+  "event_count": 15,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "d8db4dc070e61c2a1fc45fd8d28a576da9027926bff2252cce5912b67c05d742",
+  "output_sha256": "7a74da3ccbc5766b0454720e54d4189b0051407df132b88131104b9482febbb8",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c92cc506f99e621c3756778b2d80a4c6bddac95e5d81c2d692b185778b878ab8.md b/vision-fixhub/ds9-unparsed-05/c92cc506f99e621c3756778b2d80a4c6bddac95e5d81c2d692b185778b878ab8.md
new file mode 100644
index 0000000000000000000000000000000000000000..e0085aa578347bdf0dafd212853bfaabc29eac88
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c92cc506f99e621c3756778b2d80a4c6bddac95e5d81c2d692b185778b878ab8.md
@@ -0,0 +1,18 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 S. Australian Ave, 4th Floor
+West Palm Beach, Florida 33401
+(561) 820-8711
+A. Marie Villafaña
+Facsimile (561) 820-8777
+FACSIMILE COVER SHEET
+TO: Dennis Block, Esq.
+DATE: August 15,2007
+FAX NO.
+# OF PAGES:
+PHONE NO._
+RE: Subpoena
+FROM: A. MARIE VILLAFAÑA, Assistant U.S. Attorney
+PHONE NO. 561 209-1047
+COMMENTS:
diff --git a/vision-fixhub/ds9-unparsed-05/c92cc506f99e621c3756778b2d80a4c6bddac95e5d81c2d692b185778b878ab8.receipt.json b/vision-fixhub/ds9-unparsed-05/c92cc506f99e621c3756778b2d80a4c6bddac95e5d81c2d692b185778b878ab8.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..996fad736ecafe559388cd194ae23857cdf2abff
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c92cc506f99e621c3756778b2d80a4c6bddac95e5d81c2d692b185778b878ab8.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "c92cc506f99e621c3756778b2d80a4c6bddac95e5d81c2d692b185778b878ab8",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "03f8ff62ed68381042fba8f45335360a0743ae4c4ddd832daeaa2e53d1e97087",
+  "output_sha256": "874fff20162e7bb5f03e2e77e0cac9ae1ff36e1778c67804d9fcb01481596dcb",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c97b462ee0b4951fd9c7f9255e7fb5776507267ca2990573ce75f7f5eb816277.md b/vision-fixhub/ds9-unparsed-05/c97b462ee0b4951fd9c7f9255e7fb5776507267ca2990573ce75f7f5eb816277.md
new file mode 100644
index 0000000000000000000000000000000000000000..569414bae1b1eb8674662048d2781f85a85e8261
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c97b462ee0b4951fd9c7f9255e7fb5776507267ca2990573ce75f7f5eb816277.md
@@ -0,0 +1,53 @@
+From:
+Sent:
+To:
+Cc:
+Subject:
+Acosta, Alex (USAFLS);
+Re: Agreement
+1 agree. Ask Jack to make that change.
+From Disinal Message -
+Sent: Fri Jun 27 21:28:46 2008
+Subject: Agreement
+Hi Hadn't heard back, so I figured this would be casiest way to communicate.
+I got a call back from Jack Goldberger, incensed that I was somehow accusing him of trying to get out of the agreement. I was taken
+aback because the response was completely out of line with the questions I was asking. From my dealings with Jack, this just made
+me more suspicious than I was originally.
+Anyhow, Jack said that "this was the only way to do the consecutive jail time." And he "swore" that Epstein would be in custody 24-
+hours-a-day during the community confinement portion of the sentence. He also insisted that Epstein had been charged with a
+substantive procurement offense, not attempt.
+He did, however, let it slip that Epstein would not be at the jail, he would be at the stockade out on the fairgrounds (a low security
+"camp"). Since we specifically discussed this at the meeting with Barry Krisher months ago that Epstein would be at the Gun Club
+facility (the jail), this certainly violates the spirit of the agreement, if not the letter.
+who used to be with the Palm Beach County State Attorney's Office before joining our office. She said,
+first, that it was extremely strange to call it the "Palm Beach County Detention Center," rather than the jail, but I explained that I
+thought Epstein's people were trying to make us believe he was going to the jail even though he wasn't and this was their way to
+"finesse" the situation.
+also explained that the normal way for the plea agreement to read is a consecutive term of six months imprisonment to be
+followed by one year of community control - in other words, Goldberger's statement that this was the "only way" to do the
+consecutive sentence is false. I did find a statute that says that if two sentences are imposed consecutively that result in a sentence of
+greater than one year, the judge is supposed to send the defendant to a state prison rather than a county facility, so that may be why
+they are wording it this way.
+never seen imprisonment used as a condition of "community control." She has seen such a condition in connection with a sentence o
+probation, but not community control.
+Also, she and I did a state guideline calculation for Epstein's plea, and, if done correctly, he should be looking at 51 months. The only
+way that Lanna could avoid that calculation is if she tells the judge that there was no sexual contact. That, of course, would be
+completely false.
+In short, something smells very bad. My suggestion is to ask that we ask them to add one word to the second sentencing paragraph of
+the plea agreement with the state, as follows: the Defendant is sentenced to 18 months Community Control 1 (one). As a special
+condition of this Community Control, the Defendant must serve the first 6 months INCARCERATED [or IMPRISONED] in the Palm
+Beach County Detention Facility ...
+If they object to this small change - which according to Goldberger is intended by the language already there - then we will know that
+something is extremely fishy.
+08-80736-CV-MARRA
+116
+P-015005
+
+
+What do you think?
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+08-80736-CV-MARRA
+117
+P-015006
diff --git a/vision-fixhub/ds9-unparsed-05/c97b462ee0b4951fd9c7f9255e7fb5776507267ca2990573ce75f7f5eb816277.receipt.json b/vision-fixhub/ds9-unparsed-05/c97b462ee0b4951fd9c7f9255e7fb5776507267ca2990573ce75f7f5eb816277.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..83f326ae317110882a265fb322b99d971cabeac1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c97b462ee0b4951fd9c7f9255e7fb5776507267ca2990573ce75f7f5eb816277.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "c97b462ee0b4951fd9c7f9255e7fb5776507267ca2990573ce75f7f5eb816277",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "311de04f3d7669f8fa6ced989f3252860124faaec2a6b78c67c805b5a85a0f4c",
+  "output_sha256": "e36c0b422970fcebf6307437820a14d7124099871e2d0a65a00256c5323693cb",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c9893b5fd9c5cb3b6278d39244099304c5d9ff968171116b67dd7fe86764673a.md b/vision-fixhub/ds9-unparsed-05/c9893b5fd9c5cb3b6278d39244099304c5d9ff968171116b67dd7fe86764673a.md
new file mode 100644
index 0000000000000000000000000000000000000000..891b3616381ff5a4250978f8085b6591d88a555a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c9893b5fd9c5cb3b6278d39244099304c5d9ff968171116b67dd7fe86764673a.md
@@ -0,0 +1,1448 @@
+EXTENSION ATTACHED
+Fom 990-PF
+Return of Private Foundation
+OMB No 1545-0052
+or Section 4947(a)(1) Nonexempt Charitable Trust
+Treated as a Private Foundation
+Department of the Treasury
+2006
+Internal Revanue Service
+Note: The foundation may be able to use a copy of this retum to satisfy state reporting requirements.
+For calendar year 2006, or tax year beginning
+March 1
+, 2006, and ending
+February 28
+, 20 07
+G Check all that apply:
+_ Initial return
+• Final return
+• Amended return
+• Address change
+• Name change
+Use the IRS
+Name of foundation
+A Employer identification number
+label.
+The C.O.U.Q. Foundation
+Otherwise,
+Number and street (or PO box number if mail is not delivered to street address)
+print
+Room/suite
+B Telephone number (see page 11 of the instructions)
+or type.
+c/o George V. Delson Associates,
+See Specific
+City or town, state, and ZIP code
+C if exemption application is pending, check here • L
+Instructions.
+New York, NY 10022
+D 1. Foreign organizations, check here .
+H Check type of organization: Z] Section 501(c)(3) exempt private foundation
+_ Foreign organizations meeting the 85% tes
+• Section 4947(a)(1) nonexempt charitable trust
+• Other taxable private foundation
+heck here and attach computatio
+1 Fair market value of all assets at end J Accounting method: Cash • Accrual
+of year (from Part II, col. (c),
+• Other (specify)
+F If the foundation is in a 60-month termination
+line 16) • $
+22,832,814 (Part I, column (d) must be on cash basıs.)
+under section 507(b)(1)(B), check here
+Part | Analysis of Revenue and Expenses (The total of
+(a) Revenue and
+(d) Disbursements
+amounts in columns (b), (c), and (d) may not necessanly equal
+(b) Net investment
+(c) Adjusted net
+for chantable
+expenses per
+income
+income
+the amounts in column (a) (see page 11 of the instructions))
+purpose
+books
+cash basis onh
+Revenue
+1
+Contrbutions, gifts, grants, etc., received (attach schedule)
+2
+Check • if the foundation is not required to attach Sch. B
+3 Interest on savings and temporary cash investments
+4 Dividends and interest from securities
+5a Gross rents
+b Net rental income or (loss)
+6a Net gain or (loss) from sale of assets not on line 10
+b Gross sales price for all assets on line 6a
+0
+7 Capital gain net income (from Part IV, line 2)
+8 Net short-term capital gain
+9
+• Income modifications
+10a Gross sales less returns and allowances
+b Less: Cost of goods sold
+c Gross profit or (loss) (attach schedule)
+11
+Other income (attach schedule)
+12
+Total. Add lines 1 through 11
+St.1
+13
+Compensation of officers, directors, trustees, etc.
+Other employee salaries and wages
+15 Pension plans, employee benefits
+16a Legal fees (attach schedule) .
+b Accounting fees (attach schedule)
+c Otherpotes//(ges (attach schedule)
+Ipterest
+414,646
+414,646
+(52,333)
+17T
+0
+284,468
+646,781
+94,468
+509,114
+170,000
+120,000
+50,000
+(sep&age 14 of the instructions)
+le) and depletion
+25,000
+Occupancy
+Trave Copterces and meetings
+Printing and pubtications
+Toll operating and acantatio i
+23
+24
+Total operating and administrative expenses.
+Add lines 13 through 23
+25
+26
+27
+Contributions, gifts, grants paid
+Total expenses and disbursements. Add lines 24 and 25
+Subtract line 26 from line 12:
+a Excess of revenue over expenses and disbursements
+b Net investment income (if negative, enter -0-)
+c Adjusted net income (if negative, enter -0-).
+For Privacy Act and Paperwork Reduction Act Notice, see the instructions.
+591,636
+590,633
+1,003
+786,636
+1,186,000
+1,972,636
+710,633
+710,633
+51,003
+1,186,000
+1,237,003
+(1,325,855)
+0
+Cat. No. 11289X
+For 990-PF (2005)
+
+
+Part I|
+Balance Sheets
+Attached schedules and amounts in the desanption column
+should be for end-of-year amounts only (See instructions)
+Beginning of year
+(a) Book Value
+Assets
+Liabilities
+1
+Cash-non-interest-bearing
+2 Savings and temporary cash investments
+3
+Accounts receivable
+Less: allowance for doubtful accounts •
+4 Pledges receivable •
+Less: allowance for doubtful accounts •
+5 Grants receivable
+6 Receivables due from officers, directors, trustees, and other
+disqualified persons (attach schedule) (see page 16 of the
+instructions)
+7 Other notes and loans receivable (attach schedule) •
+Less: allowance for doubtful accounts •
+8
+Inventories for sale or use
+9
+Prepaid expenses and deferred charges
+10a Investments—U.S. and state government obligations (attach schedule)
+b Investments-corporate stock (attach schedule)
+c Investments—corporate bonds (attach schedule) .
+11
+Investments—land, buildings, and equipment: basis •
+Less: accumulated depreciation (attach schedule) • …
+12
+13
+14
+Investments-mortgage loans
+Investments-other (attach schedule)
+st: 4
+Land, buildings, and equipment: basis •
+Less: accumulated depreciation (attach schedule) •
+15
+16
+Other assets (describe •
+Total assets (to be completed by all filers-see page 17 of
+the instructions. Also, see page 1, item l)
+17
+Accounts payable and accrued expenses
+18 Grants payable
+19
+Deferred revenue
+20
+Loans from officers, directors, trustees, and other disqualified persons
+21
+Mortgages and other notes payable (attach schedule)
+22
+Other liabilities (descrbe •
+4,112,136
+15,458,186
+19,570,322
+13,426,719
+18,244,467
+23
+Total liabilities (add lines 17 through 22)
+Foundations
+SFAS
+check here
+or Fund Balances
+and complete lines 24 through 26 and lines 30 and 31.
+24
+25
+26
+Temporarily restricted
+Permanently restricted
+Foundations that do not follow SFAS 117, check here •
+and complete lines 27 through 31.
+27
+28
+29
+30
+Capital stock, trust principal, or current funds .
+Paid-in or capital surplus, or land, bldg., and equipment fund.
+Retained earnings, accumulated income, endowment, or other funds .
+19,570,322
+Total net assets or fund balances (see page 18 of the
+instructions)
+19,570,322
+31
+Total liabilities and net assets/fund balances (see page 18 of the
+instructions)
+19,570,322
+Part II! Analysis of Changes in Net Assets or Fund Balances
+1 Total net assets or fund balances at beginning of year-Part II, column (a), line 30 (must agree with
+end-of-year figure reported on prior year's return)
+2 Enter amount from Part I, line 27a
+3 Other increases not included in line 2 (itemize) •
+4 Add lines 1, 2, and 3
+5 Decreases not included in line 2 (itemize) •
+6 Total net assets or fund balances at end of year (line 4 minus line 5) —Part Il, column (b), line 30
+18,244,467
+18,244,467
+18,244,467
+1
+4
+5
+6
+Page 2
+End of year
+(b) Book Value
+(c) Fair Market Value
+4,817,748
+4,817,748
+18,015,066
+22,832,814
+19,570,322
+(1,325,855)
+18,244,467
+18,244,467
+
+
+Part IV Capital Gains and Losses for Tax on Investment Income
+2 Story bick ware thee, or Common stock, 20 sis. MC Tate
+(b) How acquired
+P-Purchase
+D-Donation
+Page 3
+| Date acquire
+no, day. yi
+) Date so
+no, day. yi
+1a Statement 5
+b
+d
+e
+(e) Gross sales price
+In Deprelawabellowed
+1) Cost or other bast
+slus expense of sale
+1) Gain or (los
+plus (f) minus
+a o
+Complete only for assets showing gain in column (h) and owned by the foundation on 12/31/69
+D) FM]. as of 12/31/69
+) Adjusted Das
+s of 12/31/6
+coll a But Cot less than -0-8
+(k), but not less than -0-) or
+Losses (from col. (h))
+C
+d
+e
+2 Capital gain net income or (net capital loss)
+If gain, also enter in Part I, line 7
+If (loss), enter -O- in Part I, line 7
+2
+3 Net short-term capital gain or (loss) as defined in sections 1222(5) and (6):
+If gain, also enter in Part I, line 8, column (c) (see pages 13 and 18 of the instructions).
+If (loss), enter -0- in Part I, line 8
+Part
+Qualification Under Section 4940(e) for Reduced Tax on Net Investment Income
+(For optional use by domestic private foundations subject to the section 4940(a) tax on net investment income.)
+If section 4940(d)(2) applies, leave this part blank.
+Was the foundation liable for the section 4942 tax on the distributable amount of any year in the base period?
+• Yes
+If "Yes," the foundation does not qualify under section 4940(e). Do not complete this part.
+1 Enter the appropriate amount in each column for each year; see page 19 of the instructions before making any entries.
+(52,333)
+• No
+Adjusted qualıfying distrbutions
+Calendar year (or tax year beginnıng in)
+2005
+1,255,795
+2004
+936,665
+2003
+1,041,560
+2002
+1,243,915
+2001
+902,103
+Net value of nonchantable-use assets
+22,630,448
+20,159,106
+12,227,806
+12,221,528
+7,498,097
+(col (b) divided by col (c))
+0.055491
+0.046463
+0.085179
+0.101944
+0.120310
+2 Total of line 1, column (d)
+3 Average distribution ratio for the 5-year base period-divide the total on line 2 by 5, or by the
+number of years the foundation has been in existence if less than 5 years
+2
+0.409387
+3
+0.081877
+4 Enter the net value of noncharitable-use assets for 2006 from Part X, line 5
+4
+22,142,808
+5 Multiply line 4 by line 3
+5
+1,812,987
+6 Enter 1% of net investment income (1% of Part I, line 27b)
+6
+7 Add lines 5 and 6
+7
+... =
+1,812,987
+8 Enter qualıfying distrbutions from Part XII, line 4
+8
+1,237,003
+If line 8 is equal to or greater than line 7, check the box in Part VI, line 1b. and complete that part using a 1% tax rate. See
+the Part VI instructions on page 19.
+
+
+Page 4
+Part VI
+Excise Tax Based on Investment Income (Section 4940(a), 4940(b), 4940(e), or 4948see page 19 of the instructions)
+1a Exempt operating foundations described in section 4940(d)(2), check here • • and enter "N/A" on line 1.
+Date of ruling letter:
+(attach copy of ruling letter if necessarysee instructions)
+b Domestic foundations that meet the section 4940(e) requirements in Part
+check
+here • • and enter 1% of Part I, line 27b
+c All other domestic foundations enter 2% of line 27b. Exempt foreign organizations enter 4%
+of Part I, line 12, col. (b)
+2
+Tax under section 511 (domestic section 4947(a)(1) trusts and taxable foundations only. Others enter -0-)
+3
+Add lines 1 and 2
+4
+Subtitle A (income) tax (domestic section 4947(a)(1) trusts and taxable foundations only. Others enter - 0-)
+5
+Tax based on investment income. Subtract line 4 from line 3. If zero or less, enter -0-
+3
+4
+5
+6 Credits/Payments:
+a 2006 estimated tax payments and 2005 overpayment credited to 2006
+b Exempt foreign organizations—tax withheld at source
+c Tax paid with application for extension of time to file (Form 8868)
+d Backup withholding erroneously withheld
+| ба
+6b
+6c
+6d
+18,872
+7 Total credits and payments. Add lines 6a through 6d
+18,872
+8
+Enter any penalty for underpayment of estimated tax. Check here • if Form 2220 is attached
+9 Tax due. If the total of lines 5 and 8 is more than line 7, enter amount owed
+10 Overpayment. If line 7 is more than the total of lines 5 and 8, enter the amount overpaid
+11
+Enter the amount of line 10 to be: Credited to 2007 estimated tax •
+18,872
+Refunded
+9
+10
+11
+0
+18,872
+Part VII-A L
+Statements Regarding Activities
+1a During the tax year, did the foundation attempt to influence any national, state, or local legislation or did it
+Yes
+participate or intervene in any political campaign?
+1a
+No
+/
+b Did it spend more than $100 during the year (either directly or indirectly) for political purposes (see page 20
+of the instructions for definition)?
+1b
+If the answer is "Yes" to ta or 1b, attach a detailed description of the activities and copies of any matenals
+published or distributed by the foundation in connection with the activities.
+c Did the foundation file Form 1120-POL for this year?
+1c
+d Enter the amount (if any) of tax on political expenditures (section 4955) imposed during the year:
+(1) On the foundation.
+• $
+- (2) On foundation managers. • $
+e Enter the reimbursement (if any) paid by the foundation during the year for political expenditure tax imposed on
+foundation managers.
+$
+2 Has the foundation engaged in any activities that have not previously been reported to the IRS? . . .
+2
+If "Yes," attach a detailed description of the activities.
+3
+Has the foundation made any changes, not previously reported to the IRS, in its governing instrument, articles of
+incorporation, or bylaws, or other similar instruments? If "Yes," attach a conformed copy of the changes . ..
+4a Did the foundation have unrelated business gross income of $1,000 or more during the year?
+b If "Yes," has it filed a tax retum on Form 990-T for this year?
+3
+4a
+4b
+5
+N
+A
+5 Was there a liquidation, termination, dissolution, or substantial contraction during the year?
+If "Yes," attach the statement required by General Instruction T.
+6 Are the requirements of section 508(e) (relating to sections 4941 through 4945) satisfied either:
+• By language in the governing instrument, or
+• By state legislation that effectively amends the governing instrument so that no mandatory directions that
+conflict with the state law remain in the governing instrument?
+7 Did the foundation have at least $5,000 in assets at any tume dunng the year? I! "Yes," complete Part Il, col (c), and Part XV.
+6
+7
+1
+8a Enter the states to which the foundation reports or with which it is registered (see page 20 of the
+instructions) • New York
+b If the answer is "Yes" to line 7, has the foundation furnished a copy of Form 990-PF to the Attorney General
+(or designate) of each state as required by General Instruction G? If "No," attach explanation .
+8b
+9 Is the foundation claiming status as a private operating foundation within the meaning of section 4942)(3)
+or 4942()(5) for calendar year 2006 or the taxable year beginning in 2006 (see instructions for Part XIV on
+page 28)? If "Yes," complete Part XIV.
+10
+Did any persons become substantial contributors during the tax year? if "Yes," attach a schedule listing their
+names and addresses
+10
+
+
+Part VII-A Statements Regarding Activities Continued
+11a At any time during the year, did the foundation, directly or indirectly, own a controlled entity within the
+meaning of section 512(b)(13)? If "Yes," attach schedule. (see instructions)
+b If "Yes," did the foundation have a binding witten contract in effect on August 17, 2006, covering the interest,
+rents, royalties, and annuities described in the attachment for line 11a?
+12
+13
+Did the foundation acquire a direct or indirect interest in any applicable insurance contract?
+Did the foundation comply with the public inspection requirements for its annual returns and exemption application?
+Website address •
+14
+The books are in care of
+• George V. Delson Associates
+Telephone no. •..
+Located at
+New York, NY
+ZIP+4 •...
+15
+Section 4947(a)(1) nonexempt chantable trusts filing Form 990-PF in lieu of Form 1041—Check here
+and enter the amount of tax-exempt interest received or accrued during the year
+Part VIl-B| Statements Regarding Activities for Which Form 4720 May Be Required
+File Form 4720 if any item is checked in the "Yes" column, unless an exception applies.
+1a During the year did the foundation (either directly or indirectly):
+(1) Engage in the sale or exchange, or leasing of property with a disqualified person?
+• Yes
+2 No
+(2) Borrow money from, lend money to, or otherwise extend credit to (or accept it from) a
+disqualified person?
+(3) Furnish goods, services, or facilities to (or accept them from) a disqualified person? .
+• Yes
+• Yes
+(4) Pay compensation to, or pay or reimburse the expenses of, a disqualified person?, • Yes
+• No
+• No
+• No
+(5) Transfer any income or assets to a disqualified person (or make any of either available for
+the benefit or use of a disqualified person)?
+•Yes / No
+(6) Agree to pay money or property to a government official? (Exception. Check "No" if
+the foundation agreed to make a grant to or to employ the official for a period after
+termination of government service, if terminating within 90 days.)
+• Yes 2 No
+b If any answer is "Yes" to 1a(1)-(6), did any of the acts fail to qualify under the exceptions described in Regulations
+section 53.4941(d)-3 or in a current notice regarding disaster assistance (see page 22 of the instructions)?
+Organizations relying on a current notice regarding disaster assistance check here
+c Did the foundation engage in a prior year in any of the acts described in 1a, other than excepted acts, that
+were not corrected before the first day of the tax year beginning in 2006?
+Taxes on failure to distribute income (section 4942) (does not apply for years the foundation was a private
+operating foundation defined in section 4942()(3) or 4942()(5))
+a At the end of tax year 2006, did the foundation have any undistributed income (lines 6d and
+6e, Part XIII) for tax year(s) beginning before 20067
+• Yes • No
+If "Yes," list the years
+20.., 20.., 20..., 20....
+b Are there any years listed in 2a for which the foundation is not applying the provisions of section 4942(a)(2)
+(relating to incorrect valuation of assets) to the year's undistributed income? (if applying section 4942(a)(2)
+to all years listed, answer "No" and attach statement-see page 22 of the instructions.).
+c If the provisions of section 4942(a)(2) are being applied to any of the years listed in 2a, list the years here.
+• 20 .... , 20 .... , 20 ...., 20
+3а Did the foundation hold more than a 2% direct or indirect interest in any business
+enterprise at any time during the year? .
+• Yes 2 No
+b If "Yes," did it have excess business holdings in 2006 as a result of (1) any purchase by the foundation or
+disqualified persons after May 26, 1969; (2) the lapse of the 5-year penod (or longer period approved by the
+Commissioner under section 4943(c)(7)) to dispose of holdings acquired by gift or bequest; or (3) the lapse
+of the 10-, 15-, or 20-year first phase holding period? (Use Schedule C, Form 4720, to determine if the
+foundation had excess business holdings in 2006.)
+4a Did the foundation invest during the year any amount in a manner that would jeopardize its charitable purposes?
+b Did the foundation make any investment in a prior year (but after December 31, 1969) that could jeopardize its chantable
+purpose that had not been removed from jeopardy before the first day of the tax year beginning in 2006?
+Page 5
+A
+12
+13
+10022
+L
+Yes
+No
+1b
+N
+A
+1c
+2b
+3b
+4a
+N
+A
+4b
+
+
+Page 6
+Part VII-B Statements Regarding Activities for Which Form 4720 May Be Required Continued
+Sa Dunng the year did the foundation pay or incur any amount to:
+(1) Carry on propaganda, or otherwise attempt to influence legislation (section 4945(e))? . • Yes
+Z No
+(2) Influence the outcome of any specific public election (see section 4955); or to carry on,
+directly or indirectly, any voter registration drive?
+(3) Provide a grant to an individual for travel, study, or other similar purposes?
+• Yes
+• Yes
+E No
+2 No
+(4) Provide a grant to an organization other than a charitable, etc., organization described in
+section 509(a)(1), (2), or (3), or section 4940(d)(2)? (see instructions) .
+. • Yes 2 No
+(5) Provide for any purpose other than religious, charitable, scientific,
+literary, or
+educational purposes, or for the prevention of cruelty to children or animals?
+. DYes 2 No
+b If any answer is "Yes" to 5a(1)-(5), did any of the transactions fail to qualify under the exceptions described in
+Regulations section 53.4945 or in a current notice regarding disaster assistance (see page 23 of the instructions)?
+5b
+N
+A
+Organizations relying on a current notice regarding disaster assistance check here .
+c If the answer is "Yes" to question 5a(4), does the foundation claim exemption from the tax
+because it maintained expenditure responsibility for the grant?
+•Yes • No
+If "Yes," attach the statement required by Regulations section 53.4945-5(d).
+6a Did the foundation, during the year, receive any funds, directly or indirectly, to pay premiums
+on a personal benefit contract?
+•Yes 2 No
+b Did the foundation, during the year, pay premiums, directly or indirectly, on a personal benefit contract?
+6b
+If you answered "Yes" to 6b, also file Form 8870.
+7a At any time during the tax year, was the foundation a party to a prohibited tax shelter transaction? . • Yes
+b If yes, did the foundation receive any proceeds or have any net income attributable to the transaction?
+- No
+7b
+Part VIII
+N
+A
+Information About Officers, Directors, Trustees, Foundation Managers, Highly Paid Employees,
+and Contractors
+1 List all officers, directors, trustees, foundation managers and their compensation (see page 23 of the instructions).
+(b) Title, and average
+(a) Name and address
+hours per week
+devoted to position
+to not neg, entere
+(d) Contributions to
+(e) Expense account,
+employee benefit plans
+and deferred compensation
+other allowances
+Jeffrey E. Epstein
+6100 Red Hook Quarters, St. Thomas, USVI
+Darren K. Indyke
+457 Madison Ave., New York, NY
+Ghislaine Maxwell
+c/o George V. Delson Associates
+New York, NY
+Pres./Director
+0
+0
+One hour
+VP/Director
+0
+One hour
+Treasurer
+0
+0
+One hour
+2 Compensation of five highest-paid employees (other than those included on line 1—see page 24 of the instructions).
+If none, enter "NONE."
+(a) Name and address of each employee paid more than $50,000
+(b) Title, and average
+hours per week
+devoted to position
+(c) Compensation
+(d) Contrbutions to
+employee benefit
+(e) Expense account,
+plans and deferred
+other allowances
+compensation
+None
+Total number of other employees paid over $50,000
+
+
+Part VIII
+Information About Officers, Directors, Trustees, Foundation Managers, Highly Paid Employees,
+and Contractors Continued
+3
+Five highest-paid independent contractors for professional services (see page 24 of the instructions). If none, enter
+"NONE."
+(a) Name and address of each person paid more than $50,000
+(b) Type of service
+David Grosot
+Consulting
+San Francisco, CA 94131
+(c) Compensation
+50,000
+Total number of others receiving over $50,000 for professional services
+Part IX-A
+Summary of Direct Charitable Activities
+List the foundation's four largest direct chantable activities dung the tax year Include relevant statistical information such as the number
+of organizations and other beneficianes served, conferences convened, research papers produced, etc
+50,000
+Expenses
+1
+2
+3
+Part IX-B
+Summary of Program-Related Investments (see page 24 of the instructions)
+Descbe the two largest program-related investments made by the foundation dunng the tax year on lines 1 and 2
+1
+Amount
+2
+All other program-related investments See page 25 of the instructions.
+3
+Total. Add lines 1 through 3
+
+
+Pago 8
+Part X
+Minimum Investment Return (All domestic foundations must complete this part. Foreign foundations,
+see page 25 of the instructions.)
+1 Fair market value of assets not used (or held for use) directly in carrying out charitable, etc.,
+purposes:
+a Average monthly fair market value of securities
+b Average of monthly cash balances
+c Fair market value of all other assets (see page 25 of the instructions)
+d Total (add lines 1a, b, and c)
+1a
+1b
+1c
+1d
+4,464,942
+18,015,066
+22,480,008
+e Reduction claimed for blockage or other factors reported on lines 1a and
+1c (attach detailed explanation)
+1e |
+2 Acquisition indebtedness applicable to line 1 assets .
+3
+Subtract line 2 from line 1d
+2
+3
+22,480,008
+4 Cash deemed held for charitable activities. Enter 1½% of line 3 (for greater amount, see page 26
+of the instructions)
+4
+Net value of noncharitable-use assets. Subtract line 4 trom line 3. Enter here and on Part i line 4
+Minimum investment return. Enter 5% of line 5 .
+337,200
+22,142,808
+1,107,140
+Distributable Amount (see page 26 of the instructions) (Section 4942()(3) and ()(5) private operating
+foundations and certain foreign organizations check here
+• and do not complete this part.)
+1 Minimum investment return from Part X, line 6.
+1
+1,107,140
+2a Tax on investment income for 2006 from Part VI, line 5.
+b Income tax for 2006. (This does not include the tax from Part VI.)
+2a
+2b
+c Add lines 2a and 2b
+3
+4
+5
+Distributable amount before adjustments. Subtract line 2c from line 1 .
+Recoveries of amounts treated as qualifying distrbutions
+Add lines 3 and 4
+Deduction from distributable amount (see page 26 of the instructions) .
+2c
+3
+4
+5
+6
+0
+1,107.140
+1,107,140
+Distributable amount as adjusted. Subtract line 6 from line 5. Enter here and on Part XIII,
+line 1
+7
+1,107,140
+Part XII
+Qualifying Distributions (see page 26 of the instructions)
+1
+Amounts paid (including administrative expenses) to accomplish charitable, etc., purposes:
+a Expenses, contributions, gifts, etc.—total from Part I, column (d), line 26
+• •
+b Program-related investments—total from Part IX-B
+1a
+1b
+1,237,003
+2 Amounts paid to acquire assets used (or held for use) directly in carrying out chantable, etc.,
+purposes
+2
+3
+Amounts set aside for specific charitable projects that satisfy the:
+a Suitability test (prior IRS approval required) .
+b Cash distribution test (attach the required schedule)
+4
+Qualifying distributions. Add lines 1a through 3b. Enter here and on Part V, line 8, and Part Xill, line 4
+За
+3b
+4
+1,237,003
+5
+Foundations that qualify under section 4940(e) for the reduced rate of tax on net investment income.
+Enter 1% of Part I, line 27b (see page 27 of the instructions) . . . . .
+6
+Adjusted qualifying distributions. Subtract line 5 from line 4
+5
+6
+1.237,003
+ote: The amount on line 6 will be used in Part V, column (b), in subsequent years when calculating whether the foundatio
+ualifies for the section 4940(e) reduction of tax in those year
+
+
+Part XIII Undistributed Income (see page 27 of the instructions)
+(a)
+Corpus
+1
+Distributable amount for 2006 from Part XI,
+line 7
+2 Undistbuted income, if any, as of the end of 2005:
+a Enter amount for 2005 only
+b Total for pror years: 20.
+.,20
+,20
+3 Excess distributions carryover, if any, to 2006:
+a From 2001 . . •
+794,417
+b From 2002
+638,745
+c From 2003 . . .
+432,491
+d From 2004 . . .
+e From 2005
+139,200
+f Total of lines 3a through e
+2,004,853
+4
+Qualifying distributions for 2006 from Part XII,
+line 4: • $
+1,237,003
+a Applied to 2005, but not more than line 2a
+b Applied to undistbuted income of prior years (Election
+required-see page 27 of the instructions)
+c Treated as distributions out of corpus (Election
+required-see page 27 of the instructions)
+d Applied to 2006 distributable amount
+e Remaining amount distributed out of corpus
+5
+Excess distributions carryover applied to 2006
+129,863
+0
+(If an amount appears in column (d), the same
+amount must be shown in column (a).)
+6
+Enter the net total of each column as
+indicated below:
+a Corpus. Add lines 3f, 4c, and 4e. Subtract line 5
+2,134,716
+b Prior years' undistrbuted income. Subtract
+line 4b from line 2b.
+c Enter the amount of prior years' undistributed
+income for which a notice of deficiency has been
+issued, or on which the section 4942(a) tax has
+been previously assessed
+d Subtract line 6c from line 6b. Taxable
+amount-see page 27 of the instructions
+e Undistributed income for 2005. Subtract line
+4a from line 2a. Taxable amount-see page
+27 of the instructions
+f Undistrbuted income for 2006. Subtract lines
+4d and 5 from line 1. This amount must be
+distributed in 2007
+7
+Amounts treated as distbutions out of corpus
+to satisfy requirements imposed by section
+170(b)(1)(E) or 4942(g)(3) (see page 28 of the
+instructions)
+0
+8
+Excess distributions carryover from 2001 not
+applied on line 5 or line 7 (see page 28 of the
+instructions)
+794,417
+9
+Excess distributions
+carryover to 2007.
+Subtract lines 7 and 8 from line 6a
+1,340,299
+10 Analysis of line 9:
+a Excess from 2002
+b Excess from 2003
+638,745
+432,491
+c Excess from 2004
+d
+Excess from 2005
+e Excess from 2006
+139,200
+129,863
+Page 9
+Years pror to 2005
+200)
+1,107,140
+0
+0
+0
+1,107,140
+0
+0
+0
+0
+
+
+Page 10
+Part XIV Private Operating Foundations (see page 28 of the instructions and Part VII-A, question 9)
+1a If the foundation has received a ruling or determination letter that it is a private operating
+foundation, and the ruling is effective for 2006, enter the date of the ruling
+b Check box to indicate whether the foundation is a private operating foundation descrbed in section
+2a Enter the lesser of the adjusted net
+Tax year
+Prior 3 years
+income from Part | or the minimum
+L 4942()(3) o • 4942()(5)
+(e) Total
+investment return from Part
+X for
+(a) 2006
+(b) 2005
+(c) 2004
+(d) 2003
+each year listed
+b 85% of line 2a.
+c Qualifying distributions from Part XII,
+line 4 for each year listed
+d Amounts included in line 2c not used directly
+for active conduct of exempt activities
+e Qualıfying distributions made directly
+for active conduct of exempt activities.
+Subtract line 2d from line 2c
+3
+Complete 3a, b, or c for the
+alternative test relied upon:
+a "Assets" alternative test-enter:
+(1) Value of all assets
+(2) Value of assets qualıfying
+section 4942()(3)(B)(i)
+b "Endowment" alternative test-enter of
+minımum investment return shown in Part
+X. Ine 6 for each year isted
+• "Support" alternative test-enter:
+(1) Total support other than gross
+investment income (interest,
+dividends, rents, payments on
+securities loans (section
+512(a)(5)), or royalties)
+(2) Support from general public
+and 5 or more exempt
+organizations as provided in
+section 4942()(3)(B)(iii)
+(3) Largest amount of support from
+an exempt organization
+(4) Gross investment income
+Part XV
+Supplementary Information (Complete this part only if the foundation had $5,000 or more in assets
+at any time during the year—see page 28 of the instructions.)
+1
+Information Regarding Foundation Managers:
+a List any managers of the foundation who have contributed more than 2% of the total contributions received by the foundation
+before the close of any tax year (but only if they have contributed more than $5,000). (See section 507(d)(2)-)
+Jeffrey E. Epstein
+Listery man a pa of the for dater eho of 10g or on of then so a of a or gration intra equaly large portion of the
+2 Information Regarding Contribution, Grant, Gift, Loan, Scholarship, etc., Programs:
+a The name, address, and telephone number of the person to whom applications should be addressed:
+b The form in which applications should be submitted and information and materials they should include:
+c Any submission deadlines:
+d Any restrictions or limitations on awards, such as by geographical areas, charitable fields, kinds of institutions, or other
+factors:
+
+
+Part XV Supplementary Information (continued)
+Grants and Contributions Paid During the Year or Approved for Future Payment
+Recipient
+Purpose or grant or
+Name and address (home or business)
+a Paid during the year
+Page 11
+Amount
+Statement 6
+Total
+b Approved for future payment
+1,186,000
+Total
+3b
+0
+
+
+Part XVI-A Analysis of Income-Producing Activities
+Enter gross amounts unless otherwise indicated.
+Unrelated business income
+(a)
+Business code
+(b)
+Amount
+Page 12
+Excluded by section 512, 513, or 514
+(c)
+Exclusion code
+(d)
+Amount
+(e)
+Related or exempt
+function income
+(See page 29 of
+the instructions.)
+1 Program service revenue:
+a
+b
+0
+9
+Fees and contracts from government agencies
+2 Membership dues and assessments
+3 Interest on savings and temporary cash investments
+4 Dividends and interest from securities
+5 Net rental income or (loss) from real estate:
+a Debt-financed property
+b Not debt-financed property
+6 Net rental income or (loss) from personal property
+7 Other investment income
+8 Gain or (loss) from sales of assets other than inventory
+9 Net income or (loss) from special events
+10 Gross profit or (loss) from sales of inventory
+11 Other revenue: a From partnerships
+b
+d
+14
+18
+14
+414,646
+(52,333)
+94,468
+12 Subtotal. Add columns (b), (d), and (e)
+456,781
+13 Total. Add line 12, columns (b), (d), and (e)
+13
+456,781
+(See worksheet in line 13 instructions on page 29 to verify calculations.)
+Part XVI-B Relationship of Activities to the Accomplishment of Exempt Purposes
+Line No.
+Ene accomplishment of he foundations exempt purposes other any proping tunds for such purposes to
+page 29 of the instructions.)
+N/A
+
+
+*Form 990-PF (2006)
+Part XVII Information Regarding Transfers To and Transactions and Relationships With Noncharitable
+Exempt Organizations
+1 Did the organization directly or indirectly engage in any of the following with any other organization described
+Yes
+No
+in section 501(c) of the Code (other than section 501(c)(3) organizations) or in section 527, relating to political
+organizations?
+a Transfers from the reporting foundation to a noncharitable exempt organization of:
+(1) Cash
+(2) Other assets
+• .
+1a(1)
+1a(2)
+b Other transactions:
+(1) Sales of assets to a noncharitable exempt organization
+1b(1)
+(2) Purchases of assets from a noncharitable exempt organization . .
+1b(2)
+(3) Rental of facilities, equipment, or other assets
+1b(3)
+(4) Reimbursement arrangements
+• ...
+1b(4)
+(5) Loans or loan guarantees
+...
+1b(5)
+(6) Performance of services or membership or fundraising solicitations
+1b(6)
+c Sharing of facilities, equipment, mailing lists, other assets, or paid employees
+1c
+d If the answer to any of the above is "Yes," complete the following schedule. Column (b) should always show the fair market
+value of the goods, other assets, or services given by the reporting foundation. If the foundation received less than fair market
+value in any transaction or shanng arrangement, show in column (d) the value of the goods, other assets, or services received.
+(a) Line no. (b) Amount involved
+(c) Name of nonchantable exempt organization
+(d) Descoption of transfers, transactions, and sharing arrangements
+2a Is the foundation directly or indirectly affiliated with, or related to, one or more tax-exempt organizations
+descrbed in section 501(c) of the Code (other than section 501(c)(3)) or in section 527?
+. O Yes
+b If "Yes," complete the following schedule.
+(a) Name of organization
+(b) Type of organization
+(c) Descrption of relationship
+VI No
+Sign Here
+der penalties of penury, I declare that I have exarined this retum, including accompanying schedules and statements, and to the best of my knowledge an
+hief, it is true, correct, and complete Declaration of preparer (öther than taxpayer or fiduciary) is based on all information of which preperer has any knowledg
+saved
+Signature of officer or trustee
+112-18-07
+Date
+vie President
+Title
+Date
+Paid
+Preparer's
+Use Only
+Check if
+self-employed • O
+Preparer's SSN or PTIN
+(See Signature on page 31
+of the instructions)
+Preparer's
+signature
+Firm's name (or yours if
+self-employed), address,
+and ZIP code
+12/11/67
+George V. Delson Associates
+, New York, NY 10022
+EIN P
+Phone no. (
+
+
+FORM 990-PF - Y/E 2/28/07
+Part I, Line 11
+Other Income
+Second City Capital Partners I, LP
+K-l Entity
+Prior period adjustment
+94,468
+190,000
+284,468
+Part I, Line 16(c)
+Other Professional Fees
+Consulting
+Second City Capital Partners I, L.P.
+K-1 Entity
+Total
+50,000
+120,000
+170,000
+-
+STATEMENT 1
+STATEMENT 2
+
+
+FORM 990-PF - Y/E 2/28/07
+STATEMENT 3
+Part I, Line 23
+Other Expenses
+Second City Capital Partners L.P.
+K-l entity
+Filing Fees
+Professional fees - Second City
+Capital Partners L.P. K-l entity
+Bad debt expense - Second City
+Capital Partners L.P. K-l entity
+Total
+1,926
+1,003
+6,556
+582,151
+591,636
+
+
+EIN
+FORM 990-PF - Y/E 2/28/07
+STATEMENT 4
+Part II, Line 13
+Other Investments
+Bear Stearns Asset Backed
+Securities Partners LP
+Second City Capital
+Partners 1, LP
+Book Value
+7,289,911
+6,136,808
+13,426,719
+Fair
+Market Value
+11,870,413
+6,144,653
+18.015,066
+STATEMENT 5
+Part IV, Line 2
+Capital Gain Net Income (Loss)
+Second City Capital
+Partners I, LP K-1 entity
+(52,333)
+---
+-- —
+
+
+THE C.O.U.Q. FOUNDATION INC.
+FORM 990-PF Y/E 2/28/07
+PART I, LINE 25 AND PART XV
+CONTRIBUTIONS PAID
+Date
+3/7/2006
+5/3/2006
+5/30/2006
+6/1/2006
+6/14/2006
+6/28/2006
+7/12/2006
+7/18/2006
+7/18/2006
+8/10/2006
+8/11/2006
+9/1/2006
+9/6/2006
+9/8/2006
+9/27/2006
+10/3/2006
+10/5/2006
+10/5/2006
+11/10/2006
+11/16/2006
+11/27/2006
+1/17/2007
+1/18/2007
+2/7/2007
+2/21/2007
+2/22/2007
+Name
+Stockholm School of Economics
+The Continium Center for Health & Hearing
+Hunter College
+Martha Graham Dance Company
+Little Flower Children's Services
+Robin Hood
+Ballet Florida
+Georgia Southern University
+William J. Clinton Foundation
+Freestate Shooters
+Zvi Tzedakah Fund
+Institute of International Education
+Alliance for Lupus Research
+Happy Hearts Fund
+Ovarian Cancer Research Fund
+The Trilateral Commission
+Faith in The Future, Inc.
+National Council of Jewish Women
+The Institute for Music & Brain Science
+Santa Fe Institute
+Ballet Florida
+Save Darfur Coalition
+Stockholm School of Economics
+Saint Peter's Prep
+Scholar Rescue Fund
+Amount
+25,000
+25,000
+3,000
+10,000
+10,000
+50,000
+20,000
+10,000
+25,000
+25,000
+100,000
+100,000
+5,000
+100,000
+50,000
+50,000
+5,000
+5,000
+25,000
+100,000
+75,000
+15,000
+150,000
+50,000
+150,000
+1,186,000
+STATEMENT 6
+Purpose
+Scholarship
+
+
+OFFICE COPY
+Form
+8868
+Application for Extension of Time To File an
+(Rev Apnl 2007)
+Exempt Organization Return
+OMB No 1545-1709
+Department of the Treasury
+Intemal Revenue Service
+• File a separate application for each return.
+• If you are filing for an Automatic 3-Month Extension, complete only Part I and check this box
+• If you are filing for an Additional (not automatic) 3-Month Extension, complete only Part I (on page 2 of this form).
+Do not complete Part Il unless you have already been granted an automatic 3-month extension on a previously filed Form 8868.
+Part |
+Automatic 3-Month Extension of Time. Only submit original (no copies needed).
+Section 501(c) corporations required to file Form 990-T and requesting an automatic 6-month extension-check this box and
+complete Part I only
+. • O
+All other corporations (including 1120-C filers), partnerships, REMICs, and trusts must use Form 7004 to request an extension of
+time to file income tax retums.
+Electronic Filing (e-file). Generally, you can electronically file Form 8868 if you want a 3-month automatic extension of time to file
+one of the retums noted below (6 months for section 501(c) corporations required to file Form 990-T). However, you cannot file Form
+8868 electronically if (1) you want the additional (not automatic) 3-month extension or (2) you file Forms 990-BL, 6069, or 8870, group
+retums, or a composite or consolidated Form 990-T. Instead, you must submit the fully completed and signed page 2 (Part I) of Form
+8868. For more details on the electronic filing of this form, visit www.irs.gov/efile and click one-file for Charities & Nonprofits.
+Type or
+Name of Exempt Organization
+Employer identification number
+print
+File by the
+Number, street, and room or suite no. If a P.O. box, see instructions.
+due date for
+filing your
+c/o George V. Delson Associates,
+return
+See
+instructions
+City, town or post office, state, and ZIP code. For a foreign address, see instructions.
+New York, NY 10022
+Check type of return to be filed (file a separate application for each return):
+• Form 990
+• Form 990-T (corporation)
+• Form 990-BL
+• Form 990-T (sec. 401(a) or 408(a) trust)
+Form 990-EZ
+Form 990-T (trust other than above)
+/ Form 990-PF
+Form 1041-A
+• Form 4720
+• Form 5227
+• Form 6069
+• Form 8870
+• The books are in the care of • Harry Beller
+Telephone No. • !..
+FAX No. + !..
+• If the organization does not have an office or place of business in the United States, check this box
+. • O
+• if this is for a Group Return, enter the organization's four digit Group Exemption Number (GEN).
+for the whole group, check this box......• •. If it is for part of the group, check this box.
+.. • • and attach
+a list with the names and EINs of all members the extension will cover.
+1 I request an automatic 3-month (6 months for a section 501(c) corporation required to file Form 990-T) extension of time
+until ......
+October 15
+....,20.!.., to file the exempt organization return for the organization named above. The extension is
+for the organization's retum for:
+• calendar year 20....... or
+• • tax year beginning .
+March 1
+February 28
+.20. 07.
+, 20.06, and ending
+2 If this tax year is for less than 12 months, check reason: • Initial return • Final return • Change in accounting period
+3a If this application is for Form 990-BL, 990-PF, 990-T, 4720, or 6069, enter the tentative tax,
+less any nonrefundable credits. See instructions.
+b if this appiication is for Form 990-PF or 990-1, enter any refundable credits and estimated tax
+payments made. Include any prior year overpayment allowed as a credit.
+За
+$
+3b $
+8,000
+18,872
+System). See instructions.
+3c $
+Caution. If you are going to make an electronic fund withdrawal with this Form 8868, see Form 8453-EO and Form 8879-EO
+for payment instructions.
+For Privacy Act and Paperwork Reduction Act Notice, see Instructions.
+Cat No 27916D
+Form 8868 (Row. 4-2007)
+
+
+OFFICE COPY
+Form 8868 (Rev. 4-2007)
+Page 2
+• If you are filing for an Additional (not automatic) 3-Month Extension, complete only Part Il and check this box
+. *
+Note. Only complete Part Il if you have already been granted an automatic 3-month extension on a previously filed Form 8868.
+• If you are filing for an Automatic 3-Month Extension, complete only Part | (on page 1).
+Part Il
+Additional (not automatic) 3-Month Extension of Time. You must file original and one copy.
+Туре ог
+Name of Exempt Organization
+Employer identification number
+print
+File by tho
+Number, street, and room or suite no. If a PO box, see instructions
+For IRS use only
+extended
+due date for
+c/o GEORGE V. DELSON ASSOCIATES,
+filing the
+retum. See
+City, town or post office, state, and ZIP code For a foreign address, see instructions.
+instructons,
+NEW YORK, NY 10022
+Check type of return to be filed (File a separate application for each retum):
+• Form 990
+2 Form 990-PF
+• Form 990-BL
+• Form 990-T (sec. 401(a) or 40B(a) trust)
+• Form 990-EZ
+Form 990-T (trust other than above)
+Form 1041-A
+• Form 4720
+Form 5227
+Form 6069
+Form 8870
+STOP! Do not complete Part Il if you were not already granted an automatic 3-month extension on a previously filed Form 8868.
+• The books are in the care of *
+HARRY BELLER
+Telephone No. + (...
+FAX No. • (.
+...).
+• If the organization does not have an office or place of business in the United States, check this box
+• If this is for a Group Retum, enter the organization's four digit Group Exemption Number (GEN)
+for the whole group, check this box......• • . If it is for part of the group, check this box.
+. . . .
+. If this is
+. * • and attach a
+list with the names and EiNs of all members the extension is for.
+4 I request an additional 3-month extension of time until
+JANUARY 15
+., 20...
+08
+5 For calendar year…......., or other tax year beginning....
+MARCH 1
+....20.06, and ending......
+FEBRUARY 28
+......20.97.
+6 If this tax year is for less than 12 months, check reason:
+• Initial return
+• Final return • Change in accounting period
+7
+State in detail why you need the extension CERTAIN INFORMATION NECESSARY FOR A COMPLETE AND ACCURATE RETURN
+IS NOT YET AVAILABLE
+Ba If this application is for Form 990-BL, 990-PF, 990-T, 4720, or 6069, enter the tentative tax,
+less any nonrefundable credits. See instructions.
+8a $ 8,000
+b If this application is for Form 990-PF, 990-T, 4720, or 6069, enter any refundable credits and
+estimated tax payments made. Include any prior year overpayment allowed as a credit and any
+amount paid previously with Form 8868.
+8b $ 18,872
+c Balance Due. Subtract line 8b from line Ba. Include your payment with this form, or, if required, deposit
+with FTD coupon or, if required, by using EFTS (Electronic Federal Tax Payment System). See instructions.
+8c $ 0
+Signature and Verification
+Under penalties of perjury, I declare that i have examined this form, including accompanying schedules and statements, and to the best of my knowledge and belief,
+it is true, correct, and complete, and that I am authonzed to propare this form.
+Signature •
+Title •
+Date •
+Notice to Applicant. (To Be Completed by the IRS)
+We have approved this application Pleaso attach this form to the organization's return.
+We have not approved this application However, we have granted a 10-day grace period from the later of the date shown below or the due
+date of the organization's return (including any prior extensions). This grace period is considered to be a valid extension of time for elections
+otherwise required to be made on a timely refum. Please attach this form to the organization's retum.
+ve nave not approved this application. After considering the reasons stated in item 7, we cannot grant your request for an extension of time
+o file. We are not granting a 10-day grace perioc
+We cannot consider this application because it was filed after the extended due date of the retum for which an extension was requested
+By:
+Director
+Date
+Alternate Mailing Address. Enter the address if you want the copy of this application for an additional 3-month extension
+returned to an address different than the one entered above.
+Name
+Type or
+print
+Number and street (include suite, room, or apt. no.) or a P.O. box number
+City or town, province or state, and country (including postal or ZIP code)
+Form 8868 (Rev 4-2007)
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/c9893b5fd9c5cb3b6278d39244099304c5d9ff968171116b67dd7fe86764673a.receipt.json b/vision-fixhub/ds9-unparsed-05/c9893b5fd9c5cb3b6278d39244099304c5d9ff968171116b67dd7fe86764673a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7039f3a39e00a96aa294b7a3ca13b995ed1ad909
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c9893b5fd9c5cb3b6278d39244099304c5d9ff968171116b67dd7fe86764673a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1060,
+  "dataset": "marble-joined",
+  "doc_id": "c9893b5fd9c5cb3b6278d39244099304c5d9ff968171116b67dd7fe86764673a",
+  "engine": "marble-apple-vision",
+  "event_count": 20,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "3bc9c0f9cd74bd3133224daf8fcc3a59368cb9fe46b0adf96fd39801d755c155",
+  "output_sha256": "28e00465aad8a22d0165878bab0cf9ec07a2c652d09363273dcc2978118f7263",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c98c2f5ae3745d399d56f06de687ce4ce1789737323241910feacf24d5024ec5.md b/vision-fixhub/ds9-unparsed-05/c98c2f5ae3745d399d56f06de687ce4ce1789737323241910feacf24d5024ec5.md
new file mode 100644
index 0000000000000000000000000000000000000000..3bc9c0a4771a1d5012cfb532a9dc7906ce1e3157
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c98c2f5ae3745d399d56f06de687ce4ce1789737323241910feacf24d5024ec5.md
@@ -0,0 +1,269 @@
+LAW OFFICE
+• Brad Edwards •
+AND ASSOCIATES
+October 10, 2008
+United States Attorney's Office
+500 South Australian Avenue :
+West Palm Beach, Florida 33401
+Re:
+Jane Does 1 and 2
+Case Number: 08-80736-CIV-MARRA/JONSON
+Dear
+In accordance with the Order to Compel Production and Protective Order signed
+Sincerelv
+Esquire
+Enclosures
+2028 HARRISON STREET, SUITE 202, HOLLYWOOD, FLORIDA 33020
+
+
+Case 9:08-cV-80736-KAM
+Entered on FLSD Dc at 08/21/2008 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80736-CIV-MARRA/JOHNSON
+IN RE: JANE DOES 1 AND 2,
+Petitioners.
+ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER
+THIS CAUSE comes before the Court on the Petitioners' ore tenus motion seeking the
+production of the Non-Prosecution Agreement between the United States Attorney's Office for the
+Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the
+Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
+Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
+including any modifications and addenda thereto, in accordance with the following procedures:
+(a)
+The USAO shall produce a copy of the Non-Prosecution Agreement,
+including any modifications and addenda thereto (collectively referred to as the "Agreement"), to
+the attorneys for Petitioners.
+(b)
+Petitioners and their attorneys shall not disclose the Agreement or its terms
+to any third party absent further court order, following notice to and an opportunity for Epstein's
+counsel to be heard.
+(c)
+Before counsel for petitioners show the Agreement to their clients or discuss
+the specific terms with them, they must provide a copy of this Order to petitioners, who must review
+and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
+petitioners must promptly provide a copy of that acknowledgment to the USAO.
+If any individuals who have been identified by the USAO as victims of
+
+
+Epstein and/or any attorneys) for those individuals request the opportunity to review the
+Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
+individuals also agree that they shall not disclose the Agreement or its terms to any third party
+absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
+(e)
+Prior to producing the documents to any other individuals who have been
+identified by the USAO as victims of Epstein and/or any attorney(s) for those individuals, a copy
+of this Order must be provided to said individuals, who must review and acknowledge their receipt
+of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
+provide a copy of that acknowledgment to the USAO.
+DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
+this 21" day of August, 2008.
+KENNETH A. MARRA
+UNITED STATES DISTRICT JUDGE
+Copies furnished to: all counsel of record
+By signing below, I certify that I have reviewed and agree to be bound by the terms of this
+Order.
+Dated: 9-18-08
+Printed Name:
+2
+
+
+Entered on FLSD DC at 08/21/2008 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80736-CTV-MARRA/JOHNSON
+IN RE: JANE DOES 1 AND 2,
+Petitioners.
+ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER
+THIS CAUSE comes before the Court on the Petitioners' ore tenus motion seeking the
+production of the Non-Prosecution Agreement between the United States Attorney's Office for the
+Southern District of Florida ("USAO"') and Jeffrey Epstein ("Epstein"). After consideration of the
+Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
+Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
+including any modifications and addenda thereto, in accordance with the following procedures:
+The USAO shall produce a copy of the Non-Prosecution Agreement,
+including any modifications and addenda thereto (collectively referred to as the "Agreement"), to
+the attorneys for Petitioners.
+(b)
+Petitioners and their attorneys shall not disclose the Agreement or its terms
+to any third party absent further court order, following notice to and an opportunity for Epstein's
+counsel to be heard.
+(c)
+Before counsel for petitioners show the Agreement to their clients or discuss
+the specific terms with them, they must provide a copy of this Order to petitioners, who must review
+and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
+petitioners must promptly provide a copy of that acknowledgment to the USAO.
+If any individuals who have been identified by the USAO as victims of
+
+
+Epstein and/or any attorney(s) for those individuals request the opportunity to review the
+Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
+individuals also agree that they shall not disclose the Agreement or its terms to any third party
+absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
+(e)
+Prior to producing the documents to any other individuals who have been
+identified by the USAO as victims of Epstein and/or any attorney(s) for those individuals, a copy
+of this Order must be provided to said individuals, who must review and acknowledge their receipt
+of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
+provide a copy of that acknowledgment to the USAO.
+DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
+this 21" day of August, 2008.
+KENNETH A. MARRA
+UNITED STATES DISTRICT JUDGE
+Copies furnished to: all counsel of record
+Order.
+By signing below, I certify that I have reviewed and agree to be bound by the terms of this
+Dated: 9/18/08
+Printed Names
+2
+
+
+Aug.
+- 2008 9:30AM
+No. 1962 P. 1
+The Law Office of
+BRAD EDWARDS & ASSOCIATES, LLC
+FACSIMILE COVER SHEET
+DATE:
+TO:
+FAX NUMBER:
+FROM:
+RE:
+OUR FILE NO.:
+MESSAGE:
+08/28/08
+Brad Edwards, Esquire
+Jane Does 1 and 2/Epstein
+08-015
+Signed Protective Order Attached.
+Please forward the Agreement at this time.
+We are transmitting
+_ pages including this cover sheet.
+THE INFORMATION CONTAINED IN THIS TRANSMISSION IS CONFIDENTIAL AND MAY ALSO BE
+SUBJECT TO ATTORNEY-CLIENT PRIVILEGE OR MAY CONSTITUTE PRIVILEGED WORK
+2028 Harrison Street, Suite 202, Hollywood, Florida 33020
+
+
+Aug. 28. 2098 9:30AM
+Case 9:08-Cv-80736-KAM
+No. 1962 P. 2
+Entered on FLSD DC at 08/21/2008 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80736-CTV-MARRAJJOHNSON
+IN RE: JANE DOES 1 AND 2,
+Petitioners.
+/
+ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER
+THIS CAUSE comes bcfore the Court on the Petitioners' ore tenus motion seeking the
+production of the Non-Prosecution Agreement between the United States Attorney's Office for the
+Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the
+Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
+Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
+including any modifications and addenda thereto, in accordance with the following procedures:
+(a)
+The USAO shall produce a copy of the Non-Prosecution Agreement,
+including any modifications and addenda thercto (collectively referred to as the "Agreement"), to
+the attorneys for Petitioners.
+(b) Petitioners and their attorneys shall not disclose the Agreement or its terms
+to any third party absent further court order, following notice to and an opportunity for Epstein's
+counsel to be heard.
+(c)
+Before counsel for petitioners show the Agreement to their clients or discuss
+the specific terms with them, they must provide a copy of this Order to petitioners, who must review
+and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
+petitioners must promptly provide a copy of that acknowledgment to the USAO.
+If any individuals who have been identific by the USAO as victims of
+
+
+Aug. 28. 2008 9:30AM
+No. 1962 P. 3
+Entered on FLSD D6 at 08/21/2008 Page 2 of 2
+Epstein and/or any attorey(s) for those individuals request the opportunity to review the
+Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
+individuals also agree that they shall not disclose the Agreement or its terms to any third party
+absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
+(e) Prior to producing the documents to any other individuals who have been
+identified by the USAO as victims of Epstein and/or any altorney(s) for those individuals, a copy
+of this Order must be provided to said individuals, who must review and acknowledge their receipt
+of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
+provide a copy of that acknowledgment to the USAO.
+DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
+this 21" day of August, 2008.
+KENNETH A. MARRA
+UNITED STATES DISTRICT JUDGE
+Copies furnished to: all counsel of record
+Order By signing below, eti that have reviewed and are to be bound by the torms of this
+Dated: 8/25/08
+Printed Name
+2
+
+
+LAW OFFICE
+• Brad Edwards •
+AND ASSOCIATES
+October 29, 2008
+United States Allorney's Olice
+500 South Australian Avenue
+West Palm Beach, Florida: 33401
+Re:
+Jane Does 1 and 2
+Case Number: 08-80736-CIV-MARRA/JONSON
+Dear
+In accordance with the Order to Compel Production and Protective Order signed
+by Judge Marra on August 21, 2008, I am providing to you herein a copy of the Order
+signed by another individual who has seen and reviewed the Non-Prosecution Agreement
+between the United States Attorney's Office and Jeffrey Epstein.
+Sincerely,
+Esquire
+2028 HARRISON STREET, SUITE 202, HOLLYWOOD, FLORIDA 33020
+
+
+Entered on FLSD Dc at 08/21/2008 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80736-CIV-MARRAJOHNSON
+IN RE: JANE DOES 1 AND 2,
+Petitioners.
+ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER
+THIS CAUSE comes before the Court on the Petitioners' ore tenus motion seeking the
+production of the Non-Prosecution Agreement between the United States Attorney's Office for the
+Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the
+Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
+Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
+including any modifications and addenda thereto, in accordance with the following procedures:
+(a)
+The USAO shall produce a copy of the Non-Prosecution Agreement,
+including any modifications and addenda thereto (collectively referred to as the "Agreement"), to
+the attorneys for Petitioners.
+(b)
+Petitioners and their attorneys shall not disclose the Agreement or its terms
+to any third party absent further court order, following notice to and an opportunity for Epstein's
+counsel to be heard.
+Before counsel for petitioners show the Agreement to their clients or discuss
+the specific terms with them, they must provide a copy of this Order to petitioners, who must review
+and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
+petitioners must promptly provide a copy of that acknowledgment to the USAO.
+If any individuals who have been identified by the USAO as victims of
+
+
+Epstein and/or any attorney(s) for those individuals request the opportunity to review the
+Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
+individuals also agree that they shall not disclose the Agreement or its terms to any third party
+absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
+(e)
+Prior to producing the documents to any other individuals who have been
+identified by the USAO as victims of Epstein and/or any attorney(s) for those individuals, a copy
+of this Order must be provided to said individuals, who must review and acknowledge their receipt
+of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
+provide a copy of that acknowledgment to the USAO.
+DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
+this 21" day of August, 2008.
+KENNETH A. MARRA
+UNITED STATES DISTRICT JUDGE
+Copies furnished to: all counsel of record
+By signing below, I certify that I have reviewed and agree to be bound by the terms of this
+Order.
+Dated: 10/28/08
+Printed Name:
+2
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/c98c2f5ae3745d399d56f06de687ce4ce1789737323241910feacf24d5024ec5.receipt.json b/vision-fixhub/ds9-unparsed-05/c98c2f5ae3745d399d56f06de687ce4ce1789737323241910feacf24d5024ec5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..daea92cb97953aad8f921cd283296cab98cc182b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c98c2f5ae3745d399d56f06de687ce4ce1789737323241910feacf24d5024ec5.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -554,
+  "dataset": "marble-joined",
+  "doc_id": "c98c2f5ae3745d399d56f06de687ce4ce1789737323241910feacf24d5024ec5",
+  "engine": "marble-apple-vision",
+  "event_count": 12,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "782c3f873eb86344a8f775cd94cac2b2674f3b26b41fb4057c0f7fe2bf39f67d",
+  "output_sha256": "9da1198f01a627eb9e3806a1099d35daab002b6d21cd784330f2b9075fb6031b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c99d0812e4d7b7d171c4e82d259f11db028fa7961a3c081e221963e079505bc0.md b/vision-fixhub/ds9-unparsed-05/c99d0812e4d7b7d171c4e82d259f11db028fa7961a3c081e221963e079505bc0.md
new file mode 100644
index 0000000000000000000000000000000000000000..6441756de58cb665809bc8552547ab3b7294fcf2
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c99d0812e4d7b7d171c4e82d259f11db028fa7961a3c081e221963e079505bc0.md
@@ -0,0 +1,116 @@
+OLY-50
+
+
+•
+TO: Datena Motors Inc.
+1637 S. Military Trail
+West Palm Beach, FL
+Unued States District Court FILE COPY
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-50
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Juryofthe United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+May 1, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+For the period of January 1, 2004 to the present, all documents and information referring or relating to
+any rental agreement in the name of Alfredo Rodriguez, DOB: 4/12/1954.
+*Please coordinate your compliance with this subnoena and confirm the date and time, and location of
+Your annearance with Special Agen
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+May 31, 2007
+This subpoena is issued upon application
+of the United States of America
+ant U.S. Attorney
+"If not applicable, enter "none."
+3UU SO. Australian Avenue, Suite 400
+West Palm Beach. EL 33401-6235
+Tel: (
+Fax:
+x3047
+To be used in lieu of AOTIO
+FORM ORD-227
+JAN.86
+
+
+U.S. Departm.
+of Justice
+United States Attorney
+Southern District of Florida
+500 S. Ausiralian Ave, Suite 400
+West Balm Beach, FL 33401-6235
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+authenticity. Therefore, you may be able to avoid appearing personally at the grand
+jury/trial at the time and place specified by completely filling out the attached Certification
+and Inventory and immediately returning it with the records to Special Agent
+FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to June 12, 2007.
+Sincerely,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+BY:
+
+
+CERTIFICATION OF BUSINESS RECORDS
+1, the undersigned,
+employed by/associated with
+position of
+• declare that I am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+Date of execution:
+Place of execution:
+Signature:
+
+
+APPENDIX A
+DOCUMENT INVENTORY
+The documents submitted are as follows:
+Signature of Records Custodian:
+
+
+GRAND JURY NON-DISCLOSURE NOTICE
+The attached subpoena duces tecum for records from your office is served upon
+you in connection with the investigation of suspected violations of federal criminal law.
+Pursuant to an official criminal investigation being conducted by this office, you are
+requested not to disclose the existence of this request or your compliance to anyone. Any
+such disclosure could obstruct and impede the investigation and thereby interfere with the
+enforcement of the law.
diff --git a/vision-fixhub/ds9-unparsed-05/c99d0812e4d7b7d171c4e82d259f11db028fa7961a3c081e221963e079505bc0.receipt.json b/vision-fixhub/ds9-unparsed-05/c99d0812e4d7b7d171c4e82d259f11db028fa7961a3c081e221963e079505bc0.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..982fced7ad1f1c4c519cedb26bb82beec173e6b3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c99d0812e4d7b7d171c4e82d259f11db028fa7961a3c081e221963e079505bc0.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -72,
+  "dataset": "marble-joined",
+  "doc_id": "c99d0812e4d7b7d171c4e82d259f11db028fa7961a3c081e221963e079505bc0",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "52316d708d50aca7c9c2a93d1c76eacc5a302643f9e421c3630aed9caad6913b",
+  "output_sha256": "aff966f2b86653a8b58a8ff82024ff1a5abcc26cc9ae5f67305a4d3c4e2c15eb",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c9d6e79ffa1bb56016a51d2992b133a29ce60dd8e75447e4680cb492e4bf2110.md b/vision-fixhub/ds9-unparsed-05/c9d6e79ffa1bb56016a51d2992b133a29ce60dd8e75447e4680cb492e4bf2110.md
new file mode 100644
index 0000000000000000000000000000000000000000..e79b8d64822fff5d05710f7fb4ff5dbe32cdc0c8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c9d6e79ffa1bb56016a51d2992b133a29ce60dd8e75447e4680cb492e4bf2110.md
@@ -0,0 +1,125 @@
+From
+Sent
+To:
+Subject:
+Anderson, James C. (USAWY)
+Tuesday, December 18, 2007 10:22 AM
+RE: 2422(b) based upon telephone contact
+In Wyoming we just prosecuted the following 2422(b) case based only on a
+telephone:
+Block, USDC-WY-07CR00208-B (we plea bargained the case and allowed
+defendant to plead to distribution of obscene material due to problens related to
+the victim)
+-----Original Message-...-
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Tuesday, December 18, 2007 7:07 AM
+To: USAEO-PSC-Coordinators
+Subject: 2422(b) based upon telephone contact
+•
+Hi everyone -- Sorry to trouble you, but I have a defense attorney who is
+claiming that NO ONE has ever been prosecuted anywhere in the United States for a
+violation of 2422(b) based exclusively on the use of a telephone as the facility
+of interstate commerce. I know that is false because I have prosecuted two of
+these, but it would be really helpful if you could provide me with examples of
+other cases throughout the country.
+Thank you so much.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+2232
+P-014465
+
+
+From:
+Sent:
+To:
+Subject:
+Hurd, Marcia (USAMT)
+Tuesday, December 18, 2007 10:21 AM
+RE: 242(0) based upon telephone contact
+Hey there! I'm getting ready to charge one here, he is obviously out of touch--
+-----Original Message-----
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Tuesday, December 18, 2007 7:07 AM
+To: USAEO-PSC-Coordinators
+Subject: 2422(b) based upon telephone contact
+Hi everyone -- Sorry to trouble you, but I have a defense attorney who is
+claiming that NO ONE has ever been prosecuted anywhere in the United States for a
+violation of 2422(b) based exclusively on the use of a telephone as the facility
+of interstate commerce. I know that is false because I have prosecuted two of
+these, but it would be really helpful if you could provide me with examples of
+other cases throughout the country.
+Thank you so much.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+west Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+2233
+P-014466
+
+
+Levy, Mike (USAPAE)
+Tuesday, December 18, 2007 9:54 AM
+To:
+Subject:
+Attachments:
+RE: 2422(b) based upon telephone contact
+Second Superseding Indictment.wpc
+Look at counts 11 and 12. Defendant was convicted.
+-----Original Message----.
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Tuesday, December 18, 2007 9:07 AM
+To: USAEO-PSC-Coordinators
+Subject: 2422(b) based upon telephone contact
+Hi everyone .. Sorry to trouble you, but I have a defense attorney who is
+claiming that NO ONE has ever been prosecuted anywhere in the United States for a
+violation of 2422(b) based exclusively on the use of a telephone as the facility
+of interstate commerce. I know that is false because I have prosecuted two of
+these, but it would be really helpful if you could provide me with examples of
+other cases throughout the country.
+Thank you so much.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+2235
+P-014467
+
+
+From
+Subject:
+Martin, Kim (USAKS) 2
+Tuesday, December 18, 2007 9:51 AN
+RE: 2422(b) based upon telephone contact
+Hi Ann Marie,
+United stad shi
+a few years back. It is a published case in the 10th Cir.
+I hope that is helpful.
+Let me know if you need any additional information!!
+----Original Message---
+rom: Villafana, Ann Marie C. (USAFLS
+Sent: Tuesday, December 18, 2007 8:07 AM
+To: USAEO-PSC-Coordinators
+Subject: 2422(b) based upon telephone contact
+Hi everyone -- Sorry to trouble you, but I have a defense attorney who is
+claiming that NO ONE has ever been prosecuted anywhere in the United States for a
+violation of 2422(b) based exclusively on the use of a telephone as the facility
+of interstate commerce. I know that is false because I have prosecuted two of
+these, but it would be really helpful if you could provide me with examples of
+other cases throughout the country.
+Thank you so much.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+west Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+2237
+P-014468
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/c9d6e79ffa1bb56016a51d2992b133a29ce60dd8e75447e4680cb492e4bf2110.receipt.json b/vision-fixhub/ds9-unparsed-05/c9d6e79ffa1bb56016a51d2992b133a29ce60dd8e75447e4680cb492e4bf2110.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..48730ad84bf68476783eee5fd63e1efbb38e29cc
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c9d6e79ffa1bb56016a51d2992b133a29ce60dd8e75447e4680cb492e4bf2110.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -352,
+  "dataset": "marble-joined",
+  "doc_id": "c9d6e79ffa1bb56016a51d2992b133a29ce60dd8e75447e4680cb492e4bf2110",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "0edae1e8f2e17818adbca8aaccc16d8cac44916b9db461f12a0538e0674b260d",
+  "output_sha256": "fc1d5807c1cc3802c5dc060357330da10d6c079d02e42139e991ed395a1251e2",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c9d8fa7b5d5620b4dc96452491d999f6c86f8588cbf71d702e879bedb546a895.md b/vision-fixhub/ds9-unparsed-05/c9d8fa7b5d5620b4dc96452491d999f6c86f8588cbf71d702e879bedb546a895.md
new file mode 100644
index 0000000000000000000000000000000000000000..e3b0e98a2b2d55e38829ecb2656a4dc9393f637c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c9d8fa7b5d5620b4dc96452491d999f6c86f8588cbf71d702e879bedb546a895.md
@@ -0,0 +1,4837 @@
+Ray Black It dated
+2/9/09
+Lefkowitz
+It dated
+2/13/07
+Anything
+bhun
+3/3
+and 6/8
+EPSTEIN -ATTY'S FEES CORR.
+
+
+file
+pastern
+Jay P. Loikowiz,
+To CallWiler Diacly
+lefkowi@grkland.com
+KIRKLAND & ELLİS LLP
+AND APPLIATED BARTHERSHIPS
+Citigroup Center
+163 East 53rd Street
+New York, New York 10022-4611
+www.kirkland.com
+September 2, 2008
+VIA FACSIMILE (561) 820-8777
+United States Attorney's Office
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epstein
+Dear
+. In response to your letter dated August 26, 2008, I am confirming that Mr. Goldberger
+should continue to be listed as the contact person in the mended victim notification letters and
+should receive the carbon copies of those letters as they are sent.
+Also, we plan on speaking to Mr. Josefsberg this week to discuss a procedure for paying
+his fees. We intend to comply fully with the agreement and Mir. Epstein will pay Mr. Jostsberg's
+usual and customary hourly rates for his work pursuant to the agreement facilitating settlements
+under 2255.
+Sincerely,
+ofkowit
+co:
+, Chief, Northern Division
+Jack Goldberger
+Chloago
+Hong Kong
+London
+Los Angeles
+San Franclaco
+Wushington,
+
+
+ROBERT . JOSEFSBERG
+To:
+Subject:
+ROBERT L JOSEFSBERG
+Inesday. February 03. 2009 2:16 PM
+Re: Epstein
+Roy - I need to go on record regarding Mr Epsteins message that without any settlements
+there will be a "push back" on any future payments. First, Mr Epstein has no authority to
+"push back" on payments. Secondly, although I am vey interested in settling some cases, I
+will not let Mr Epstein coerce me into settling for some clients so that I can get paid
+for representing others. It would be unethical for me to settle any cases in order to
+avoid Mr Epstins threatened "push back". If I do settle any cases, it will have nothing to
+do with Mr epstein waving the money carrot in front of me. Third, on friday, Jan 23rd, (or
+Sat the 24th) you advised that Mr Epstein would promptly pay all costs and all legal fees
+through and including 1/23. I. told you that I questioned his authity to "stop" paying for
+time and costs incurred after 1/23. BUT - I appreciated the fact that he would promptly
+pay our next bill - covering only through 1/23. I told you that I would not send out this
+new bill untill Mr epstein paid our prior, 120 and 90 day overdue statements. I didn't
+want a "new" statement to delay payment on the old overdue statments. Does your last email
+mean that Mr epstein is breaching his agreement to promptly pay for all time/costs
+incurred up to 1/23 ? I will send a new statement covering everything from approx 12/15
+through 1/23. Please let me know whether Mr Epstein will comply with your message of
+1/23, or he will "push back" on this next statement. My next statement will be sent the
+day after Mr Epstein pays the other old staements. If he did actually send the check
+today, I should have the next statment mailed by thurs or fri. Thus far Mr Epstein has
+made 3 changes re where I should send the statements. In order to avoid further delay and
+confusion, please let me know where you want me to send the next statements. I apologize
+if this email has typos!, eto but its the best I can do while I'm in trial. I do not
+apologize for the tone of this note - I am hurt and upset - I think that Mr Epstein is
+taking advantage of me, and taking advantage of our (Roy/Bob) relationship. Will further
+discuss this w you by phone or in personm. Thanks
+From: Roy BLACK <
+From: Roy BRAcMessage
+To: ROBERT L. JOSEFSBERG
+Sent: Tue Feb 03 12:47:59 2009
+Subject: Epstein
+Bob: I am told a check went out today. I am also told there will be push back on further
+expenses without a settlement. So we need to discuss settling the cases. Jeffrey will not
+pay more for the fees and expenses without the start of settlement negotiations. So let's
+discuss. Roy
+
+
+L
+BERT PATTON
+To:
+Subject:
+ROBERT. JOSEFSBERC
+--Original Messagerom: Roy BLACK [mailto
+2009 8:53 AM
+Subject: Re: Epstein
+delay. lent has informed me and I will send you a note today on his position. Borry fox the
+>> "ROBERT |. JOSEFSBERG" <RJOSEFSBERG@PODHURST.com> 2/6/2009 2:39 PM
+Having not heard from you, I assume that you atill do not have sufficient direction, or
+are still lacking client input. I've had 3 or 4 issues pending since our conversation of
+1/23 or 1/24. I've waited two weeks for your responses, and + am running out of time. I
+understand and sympathize with your situation. I wish someone would attempt to understand
+my situation. You are leaving me very limited alternatives.
+-===- Original Message -
+From: Roy BLACK <
+To: ROBERT L. JOSEFSBERG
+Sent: Thu Feb 05 12:04:21 2009
+Subject: Re: Epatein
+I am talking to the client thig afternoon. So I have no direction yet.
+>>> "ROBERT I. JOSEFSBERG" «
+2/5/2009 11:17 AM
+Roy - you wrote on 2/3 that you were advised that "a check went out today". It did not.
+This morning 100, 000 was wired. There was 200,000 that was more than 90 days overdue. The
+›o percent payment 1a not acceptable, Unfortunately, this matter is going to blow up. My
+partner, Podhurst wants to bring this to a head by
+tomorrow. I will try to reach you
+during the lunch break in my arbitration. You were supposed to get back to me on yesterday
+- after you received "client input". I understand your situation - but it is apparent that
+your client does not care about his agreements, and is. Making everything impossible. I
+though it was appropriate to let you know before we take further action.
+From: Roy BLACK
+ron- Original Message - o
+To: ROBERT I. JOSEFSBERG
+Sent: Tue Feb 03 13:41:21 2009
+Subject: Re: Epatein
+no problem. I will keep you informed.
+>>> "ROBERT L. JOSEFSBERG" <
+> 2/3/2009 1:33 PM
+['11 be at my arbitration from approx 9 till 6. I'll try to call you during a break - o
+ou can call me after 6. Why don't you email me after you get your client input - and I'1]
+call you after that.
+----- Original Mesgage ----. -
+From: Roy BLACK <
+To: ROBERT . JOSEFSBERG
+Sent: Tue Feb 03 13:19:40 2009
+Subject: Re: Epstein
+1
+
+
+Bob let's talk tomorrow. I need more input from the client before we diacues this.
+››› "ROBERT . JOSEFSBERG" <
+> 2/3/2009 1:11 PM
+- I'm not satisfied with my last email to you - am in a rush because I'm in an 8 day
+arbitration. I need to talk to you - will you (at the milt hirsch function tonight? I'1]
+try to get there btwn 6:45 and 7:30 - if we don't talk there, please call me after 7:30 -
+at 632 9230
+Original Message
+From: ROBERT. JOSEFSBERG
+To: 'RBLACk@royblack.com' <
+Sent: Tue Feb 03 12:55:53 2009
+Subject: Re: Epstein
+Fine - can we settle
+? - as to the "delay" in talking about settlement ,
+when I met with Jay I in early Dec he said that Jeff would not be ready to talk about
+settling till the end of Jan. Both you and Jay did not return my 3 or 4 calls to each of
+you between Jan 10 and approx Jan 25 when I finally dpoke to you.
+----- Original Message
+From: Roy BLACK <
+To: ROBERT • JOSEFSBERG
+Sent: Tue Feb 03 12:47:59 2009
+Subject: Epstein
+Bob: I am told a check went out today. I am also told there will be push back on further
+Jeffrey will not
+pay more wot one fee the expenses i need disture ge settlement cast atten to detot
+diacuss. Roy
+2
+
+
+13/2009 13:11 FAX
+@002/003
+AND AFFILIATED PARTNERSHIPS
+Jay P. Lefkowitz, HE
+lefkowitz@kirkland.com
+www.kirkland.com
+
+February 13, 2009
+Chicago
+VIA FACSIMILE
+Robert. Josefsberg, Esq.
+Podhurst Orseck, P.A
+City National Bank Building
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+Dear Bob,
+We have received copies of your firm's invoices for the last several months as related
+your representation of a select group of individuals in connection with a matter between
+Mr. Epstein and the United States Attorney's Office in the Southern District of Florida (the
+"USAO"). We write this letter to (1) address issues raised by those invoices and (2) suggest a
+resolution to this matter that would benefit all parties involved.
+First and foremost, after thoroughly reviewing the invoices from your firm, it is clear that
+the services you have provided to the women at issue far exceed the scope of services for which
+Mr. Epstein agreed to pay under the federal Deferred Prosecution Agreement (the "Agreement")
+and Addendum. Pursuant to the relevant Agreement and Addendum, Mr. Epstein agreed to pay
+the attorney representative for his representation of a select group of individuals at "his or her
+regular customary hourly rate."
+Importantly, the Addendum limits the scope of this
+representation and specifies that the Agreement "shall not obligate Epstein to pay the fees and
+costs of contested litigation filed against him." The Addendum further provides that Mr.
+Epstein's obligation to pay the fees of an attorney representative ceases when the work
+performed is aimed at pursuing "a contested lawsuit pursuant to 18||
+1. § 2255" or "any other
+contested remedy." Simply put, the Agreement and Addendum only require Mr. Epstein to pay
+fees expended in connection with negotiating a settlement for each of the relevant individuals,
+not for services relating to any type of pre-litigation effort. Thus, any charges related to work
+performed beyond, or extraneous to, reaching a settlement should not be Mr. Epstein's"
+responsibility. Mr. Epstein fully intends to fulfill his agreement and pay for all fees associated
+with settlement at your firm's regular hourly rates. However, Mr. Epstein will not pay for any
+services beyond those directed towards reaching a settlement. To resolve this matter, we are
+Hong Kong
+London
+Los Angeles
+Washington, LI
+
+
+02/13/2009
+13:12 FAX
+0003/003
+
+Robert Josefsberg
+February 13, 2009
+available and ready to discuss the invoices with you on a line-by-line basis and believe that we
+can come to an agreeable resolution as to the fees accumulated to date. During the same
+discussion, we hope to clarify with you the exact number of women who have agreed to utilize
+your services for the purpose of reaching a settlement with Mr. Epstein.
+| § 2255, at the time of the alleged violations. Each individual would receive this
+amount, without any need to offer proof of claim or injury and without any further delay. We
+hope that you discuss this offer with your clients in the next 30 days, as Mr. Epstein's offer to
+settle will remain open until March 13, 2009.
+Very truly yours,
+
+
+ROBERT. JOSEFSBERG
+To:
+Subject:
+ROBERT L. JOSEFSBERG
+Tuesdav, Februar 03. 2009 2:16 PM
+m'
+Re: Epstein
+Roy - I need to go on record regarding Mr Epsteins message that without any settlements
+there will be a "push back"
+on any future payments. First, Mr Epstein has no authority to
+"push back" on payments. Secondly, although
+I am vey interested in settling some cases,
+will not let Mr Epstein
+coerce me into settling for some clients so that I can get paid
+for representing others.
+It would be unethical for me to settle any cases in order to
+avoid Mr Epstins threatened "push back". If I do settle any cases, it will have nothing to
+do with Mr epstein waving the money carrot in front of me. Third, on friday, Jan 23rd, (or
+Sat the 24th) you advised that Mr Epstein would promptly pay all costs and all legal fees
+through and including 1/23. I told you that I questioned his authity to "stop" paying for
+time and costs incurred after 1/23. BUT - I appreciated the fact that he would promptly
+pay our next bill - covering only through 1/23. I told you that I would not send out this
+new bill untill Mr epstein paid our prior, 120 and 90 day overdue statements. I didn't
+want a "new" statement to delay payment on the old overdue statments. Does your last email
+mean that Mr epstein is breaching his agreement to promptly pay for all time/costs
+incurred up to 1/23 ? I will send a new statement covering everything from approx 12/15
+through 1/23. Please let me know whether Mr Epstein will comply with your message of
+1/23, or he will "push back" on this next statement. My next statement will be sent the
+day after Mr Epstein pays the other old staements. If he did actually send the check
+today, I should have the next statment mailed by thurs or fri. Thus far Mr Epstein has
+made 3 changes re where I should send the statements. In order to avoid further delay and
+confusion, please let me know where you want me to send the next statements. I apologize
+if this email has typos!, etc but its the best I can do while I'm in trial. I do not
+apologize for the tone of this note - I am hurt and upset - I think that Mr Epstein is
+taking advantage of me, and taking advantage of our (Roy/Bob) relationship. Will further
+discuss this w you by phone or in personm. Thanks
+----- Original Message -----
+Fron: Roy BLACK <
+To: ROBERT I. JOSEFSBERG
+Sent: Tue Feb 03 12:47:59 2009
+Subject: Epstein
+Bob: I am told a check went out today. I am also told there will be push back on further
+expenses without a settlement. So we need to discuss settling the cases. Jeffrey will not
+pay more for the fees and expenses without the start of settlement negotiations. So let's
+discuss. Roy
+
+
+Jay P. Lefhowitz,
+AND AMILIATED PARTHERSHIPS
+Cligroup Center
+163 Ecst 63rd Strat
+New York, New York 10022-4811
+www.kinkland.com
+September 2, 2008
+VIA FACSIMILE (561) 820-8777
+United States Attorney's Office
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epstein
+Dear
+• In response to your letter dated Àrgust 26, 2008, I am confirming thet Mr. Goldberger
+should continue to be listed as the contact person in the ämended victim notification letters and
+should receive the carbon copies of those letters as they are sent.
+Also, we plan on speaking to Mr. Joscfsberg this week to discuss a procedure for paying
+his fees. We intend to comply fully with the agreement and Mr. Epstein will pay Mr. Josfsberg's
+usual and cutory hourly rates for his work pursuant to the agreement facilitating settlements
+under 2255.
+Sincerely,
+Jay fina
+etko wit
+cc:
+Chief, Northern Division
+Jack Goldberger
+Hong Kong
+London
+Los Angelas
+Muniah
+San Prancisco
+aled
+0619-252-S0E
+WAGO: S 600Z 80 unc
+06TS 2S2 S0E 6T:8T 6002/80/90
+
+
+TRIAL & APPELLATE LAWYERS
+Aaron S. Podhurat
+Robert C. Josefsberg
+Joel D.
+Steven. Marks
+Victor M. Diaz, Jr.
+Katherine W. Ezell
+Stephen F. Rosenthal
+Join Cravate, millet
+Robert Orseck (1934-1978)
+Walter H. Beckham, Jr.
+Karen Podhurst Dern
+Of Counsel
+February 20, 2009
+Jay P. Lefkowitz, ill
+Kirkland & Ellis LLP
+Citigroup Center
+153 East 53" Street
+New York, NY 10022-4611
+Dear Mr. Lefkowitz:
+I received your letter dated February 13, 2009. What your client is doing is obvious, and it
+is in breach of his Non-Prosecution Agreement. The agreement speaks for itself. Enclosed is a copy
+of the marching orders I received from Mr. Sloman. Pursuant to these directions and the ethical
+requirements of the legal profession to zealously represent my clients, I have attempted to efficiently
+and effectively pursue my clients' claims against Mr. Epstein. Perhaps your client thought that he
+could victimize and intimidate countless underage girls, that he would then agrce to provide minimal
+compensation to them for the damage he inflicted upon them and that I would then simply let them
+come in and "sign the paperwork" for the absolute minimum recovery. Myrole is not a clerical one
+where I merely document a settlement that simply offers the statutory minimum even though courts
+have provided recovery for each occurrence. What's more, your letter presumes that I should allow
+my clients to accept such an offer without fully evaluating their claims. Settling their cases in a
+vacuum would amount to malpractice.
+As we see it, each of our 9 or 10 clients has three choices: to do nothing, to settle, or to sue
+your client. In order to make an educated decision, we are required to conduct a comprehensive
+review of each client's personal history, the events surrounding their abuse at the hands of Mr.
+Epstein and what has happened to them since he sexually exploited and abused them. Collateral
+interviews and psychological evaluations are crucial components of corroborating facts and assessing
+a fair damages calculation. Extensive legal research into their potential legal claims and resulting
+damages must also take place. Such an investigation is, of course, going to be helpful at trial if any
+of them choose to litigate their claims. This, however, does not change the fact that everything
+we've done is necessary in order to determine if we should settle: As a matter of fact, you and I
+discussed hiring Sandy Marks, a jury consultant. Again, such an exercise would be extremely
+helpful at trial, but an analysis of what would happen at trial is exceptionally beneficial at the
+settlement stage.
+Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800, Miami, FL 33130
+Miami 305.358.2800 Fax 305.358.23B2 • Fort Lauderdale 954.463.4346
+
+
+February 20, 2009
+You are welcome to set up a conference call or visit us so we can go through my bills line
+by line in search of any charges related to work performed beyond, or extraneous to, reaching a
+settlement." To be clear, nothing in our bills is extraneous to settlement of our clients' claims. Our
+bills represent our work on behalf of 9 or 10 clients. I will take this opportunity to remind you that
+of the $412,827.76 that we have sent you itemized bills for, only $163, 992.15 has been paid. Mr.
+Black wrote on February 3* that he was advised that a check had been sent out that day. It had not.
+By the time we got 50% of outstanding fees, outstanding bills were more than 90 days overdue.
+Failure to pay our fees jeopardizes your client's agreement with the United States Attorney's Office.
+My exchange with Mr. Black (copies of e-mails are attached) illustrates that promises that
+have been written or said by you or Mr. Black have been breached. I find myself in a position where
+I do not know if Mr. Epstein is bound by what you or Mr. Black say. Before we go further, I need
+confirmation that you and/or Roy Black can commit Mr. Epstein.
+One of Mr. Black's e-mails clearly states that "Jeffrey will not pay more for the fees and
+expenses without the start of settlement negotiations." I am frankly baffled by your client's
+misguided pretense. When I met with you on November 26, 2008, you said Mr. Epstein would not
+be ready to talk about settling until the end of January. Both you and Mr. Black did not return three
+or four calls to each of you between January 10 and approximately January 25. Just so the record
+is clear, we have diligently pursued reaching the stage of active settlement negotiations and have
+been stonewalled by your side, until your February 13'h "take it or leave it" $50,000 per client offer.
+In addition, I have attempted to tackle any procedural and logistical problems in an efficient,
+economical and timely manner. At each step, I have either encountered delay or a complete lack
+of response. For example, I wasted a lot of time and energy on your client's frivolous claim that I
+cannot represent my clients at trial. You shocked me with that position on November 21" and
+promised to get back to me to discuss it. Since we met in November, we haven't received a response
+regarding this issue. You apparently have finally abandoned this position. In addition, at that
+November meeting, I told you that some victims have severe psychological problems and that their
+claims warranted far in excess of $150,000 but that we are sensitive to concerns about them using
+the money otherwise. As a result, we discussed putting the money in special trusts expressly
+restricted for payment of psychological treatment. Again, I have received no response.
+Finally, the March 13* cutoff date is nonsensical. I trust that you wouldn't dare be
+attempting to say that Mr. Epstein's offer is withdrawn after that. As I said before, your client is in
+ne prospect of numerous civil trials, v
+to avoid fairly compensating my clients for the harm he inflicted upon them.
+Very truly yours,
+poth
+Robert C. Josefsb
+CC:
+Alan Dershowitz
+
+
+Miami, Florida 33130
+$ 00.44°
+JUN 24 2009
+MAILED FROM ZIP CODE 33130
+Assistant U.S. Attorney
+Office of the U.S. Attorney
+Seventh District of Florida
+500 East Broward Blvd., 7* Floor
+Fort Lauderdale, FL 33394
+3339453016 C001
+
+
+" 03/03/2009' 18:32 FAX
+@002/004
+Jay P. Lefkowitz,,
+To Call Writer Directly
+lafkowitz@tifkland.com
+AND AFFLIATED PARTNERSHIPS
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4811
+www.kirkland.com
+Facsimile:
+212) 446-4900
+
+For Settlement Purposes Oniy
+March 3, 2009
+VIA FACSIMILE
+Robert. Josefsberg, Esq.
+Podhurst Orseck, P.A.
+City National Bank Building
+25 West Flagler Streel, Suite 800
+Miami, FL 33130
+Dear Mr. Josefsberg,
+I write in response to your letter dated February 20, 2009. Firsi, there is no merit whatsoever to
+your contention that Mr. Epstein has breached the Non-Prosecution Agreement, and your
+implication that he has is simply unsupported by the facts. As you state in that letter, the
+"agreement speaks for itself" and should be honored as such. My February 13, 2009 letter to you
+was an attempt to ensure tbat the portion of the Agreement concerning restitution be carried out
+as intended and written. Indeed, our objections to your expanded role in representing the alleged
+victims and to Mr. Epstein's obligations to pay fees incurred outside of the settlement context are
+valid. Furthermoro, nowhere in the Agreement or Addendum does it state that a fee dispute or
+contentions as to the exact role of the attorney representative constitute a breach of that
+Agreement. In fact, there is a requirement that fee disputes be resolved with a special master.
+As I further explain below, your letter and accompanying documents, as well as the description
+of services performed in your invoices, lead us to believe that there has been a misunderstanding
+as to your role.
+With your letter, you enclosed a communication from Mr. Sloman to Judge
+October 25, 2007 and an additional document, presumably also from Mr. Sloman, entitled
+"PROPOSAL FOR PROCEEDING ONCE ATTORNEY IS SELECTED." While you refer to
+these documents as your "marching orders." neither document is pari of the signed Agreement
+between Mr. Epstein and the United States Attorney's Office ("USAO"). The October 25, 2007
+letter was not even addressed to you, but rather to Judge
+, the individual responsible for
+selecting an appropriate attorney representative. And since the October 2007 letter was drafted,
+there have been several communications between Mr. Epstein's defense team and the USAO
+which served to further clarify the Agreement with respect the role of the attorney representative.
+Chicago
+Hong Kong
+London
+Los Angeles
+
+
+03/03/2009 18:33 FAX
+2003/004
+
+Robert. Josefsberg
+March 3, 2009
+and regarding Epstein's Agreement to pay such attorney representative his or her regular
+customary hourly rate ..." (emphasis added). However, you never inquired as to the existence
+of such a joint statement to help inform you of your defined role. Indeed, you failed to reach out
+to anyone on Mr. Epstein's defense team to obtain such a document.
+Even though the October 2007 letter does not provide any direct instructions as to your particular
+responsibilities, it does quote relevant portions of the Agreement which expressly limit Mr.
+Epstein's obligation to pay the attorney representative. Specifically, the Agreement "shall not
+obligate Epstein to pay the fees and costs of contested litigation filed against him." Furthermore,
+the proposed instructions are represented in a document that was not agreed upon between the
+USO and Mr. Epstein's defense team. Indeed, we clearly rejected the notion that (1) the
+selected attorney be able to fulfill any role beyond negotiating a settlement, and (2) that Epstein
+would pay for any services beyond those incurred while trying to reach a settlement.
+While we have no objections to your representation of the relevant individuals, we believe that
+your role, as made clear in the Agreement, is limited to settlement negotiations. In other words,
+under the Agreement, if an individual wants to consider any measure beyond settlement with
+Mr. Epstein, she must pursue those avenues through another lawyer. Based on the language of
+the Agreement, it is our position that you are not responsible for pursing your clients' claims, as
+you state in your letter.
+Furthermore, Mr. Epstein is certainly not trying to "victimize and intimidate" anyone. The offer
+to settle was an earest effort to avoid any further delay in resolving this matter. Notably, the
+government has expressly provided that it takes no position regarding potential claims of
+goverment witnesses.! Given this lack of support. Mr. Postein's offer of $50,000 to resolve
+claims that are not time-barred (as we believe
+" claim to be), without any
+On several occasions, USAO representatives have asserted that the goveriment takes no position as to the
+-laims of the individuals identified as alleged victims. For the sake of confidentiality, we will not produce th
+relevant documents. One such communication, however, was made in a December 6, 2007 letter from United
+States Attorney Acosta to myself, in which he stated that "the Office has no intention to take any position in any
+civil litigation arising between Mr. Epstein and any individual victim..."
+
+
+• 03/03/2009 18:34 FAX
+2004/004
+
+Robert. Josefsberg
+March 3, 2009
+I hope these matters can be resolved in an amicable manner. I would welcome the opportunity to
+meet with you face-to-face so that we are able to move forward. I am certain that a great deal of
+the confusion can be resolved through an in-person meeting. Due to the fact that there are many
+lawyers involved, 1 fear that some your past correspondence was not returned in a timely
+manner. I will endeavor to make certain that this does not happen again.
+Very truly yours,
+'P. Lefkowitz
+$50,000 represents the statutory minimum under 18|
+• § 2255,
+constitutionally questionably statute for
+reasons we will not address here, at the time of the alleged conduct. This is the rount for which fir. Epstei
+agreed to settle claims with the relevant individuals pursuant to the terms of the Agreement
+
+
+TRIAL & APPELLATE LAWYERS
+Aaron S. Podhurst
+Robert Closefsberg
+Joel D. H
+Steven ( Marks
+Victor M. Diaz, Jr.
+Katherine W. Ezell
+Stephen F. Rosenthal
+Ricardo M. Martinez-Cid
+Ramon A. Rasco
+Alexander T. Rundlet*
+John Gravante, II
+Robert Orseck (1934-1978)
+Walter H. Beckham, Jr.
+Karen Podhurst Dern
+Of Counsel
+June 8, 2009
+Via Fax and U.S. Mail
+Robert Critton, Esq.
+Burman, Critton, Luttier
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+Re:
+Epstein Case
+Our File No.: 30608
+Dear Bob:
+I was shocked when I heard from Bob Josefsberg that Jeffrey Epstein and counsel do not
+The Agreement
+Paragraph 7 of the Non-Prosecution Agreement ("NPA") provides for the selection of an
+attorney representative ("Atty Rep") for the individuals who are on a list of individuals whom the
+United States has identified as victims, as defined in 18 || LI. § 2255 ("Vietims"), which list was
+to be provided and was provided to Epstein's attorneys, Jack Goldberger and Michael Tien, after
+Epstein signed the NPA and was sentenced.
+Subsequently, there was an Addendum to the Non-Prosecution Agreement ("Addendum"),
+the stated intent of which was to clarify certain provisions of page 4, paragraph 7 of the NPA. In
+paragraph 7A of the Addendum, it was agreed that the United States had the right to assign to an
+independent phstein party, is. Asynsibi, recting tedgety Pard i vas thindependent
+was the independent
+third-party chosen by the United States in consultation with and with the good faith approval of
+Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800, Miami, FL 33130
+Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+Robert Critton, Esq.
+June 8, 2009
+Spstein's counsel. Judge
+, in turn and in accordance with paragraph 7, selected our partner
+Robert . Josefsberg as Atty Rep for the victims. Both parties had the right to object to his selectiot
+prior to his final designation. Mr. Josefsberg was formally designated as Atty Rep on or about
+September 2, 2008, without objection from either side.
+Pursuant to paragraph 7 of the NPA, Mr. Josefsberg is to be paid for [his services as Atty
+Rep] by Epstein. Paragraph 7B of the Addendum directed the Parties to jointly prepare a short
+written submission to Judge
+regarding the role of the Atty Rep and Epstein's Agreement to
+pay such Alty Rep his customary hourly rate for representing the victims. The United States
+prepared a proposal and submitted it to Judge
+_, to which Epstein apparently objected. Not only
+did neither Epstein nor his counsel deign to join with the United States in preparing such a proposal,
+but they failed and refused to submit their own proposed protocol. In that circumstance, Epstein
+clearly. waived his right to submit a joint proposal or any proposal at all. Accordingly, he has no
+right to object to the proposal submitted by the United States. A clear reading of the Addendum at
+7B demonstrates that there was no disagreement, nor could there have been any misunderstanding
+regarding what is referred to as "Epstein's Agreement to pay ... [Mr. Josefsberg's] regular
+customary hourly rate."
+This obligation is reiterated in the first sentence of paragraph 7C. Epstein's choosing not to
+submit a proposal as to the role of the Atty Rep in no way relieved him of his obligation to pay the
+Atty Rep his regular hourly rate for his representation of the designated victims, so long as they are
+engaged in the settlement process. This is particularly apt when Epstein chose to avail himself of
+this settlement opportunity so as to preclude the Atty Rep's filing of a lawsuit on behalf of the
+victim. Epstein's obligation to pay the Atty Rep's fees and costs pursuant tot he NPA and its
+Addendum ceases only in the event that the Atty Rep files contested litigation against Epstein on
+behalf of a victim.
+The Recent Settlement
+During the last six months there have been meetings, emails and phone conversations
+between Roy Black, Jay Lefkowitz and Bob Josefsberg that corroborate our position. Please check
+with Jay and Roy as to their recollection of these matters.
+Despite his putting up one road block after another, Mr. Epstein, through you as his counsel,
+and the Atty Ren recently settled the claim of one of Epstein's listed and identified victims, our client
+This firm is in the process of putting together our final bill relating to our
+representation of Ms.
+entitlement issue is resolved. We fully expect Jeffrey Epstein to honor his agreement by paying the
+fees and costs related to this representation according to the terms of the NPA and the Addendum.
+We are also prepared to make a second settlement proposal (for another client) and expect similar
+
+
+Robert Critton, Esq.
+June 8, 2009
+treatment of attorney fees in that matter.
+Remedies
+There are several alternatives available to us, should Jeffrey Epstein refuse to honor his
+terms of the agreement between Epstein and the United States. In the alternative, other Epstein
+counsel have stated that all fee disagreements should be resolved by á special master. We are not
+averse to that. I am sure that I need not remind you that with regard to the Atty Rep's work thus far,
+there has been complete performance on our side and partial performance by the Defendant. Epstein
+did make partial payment of our initially invoiced fees earlier in these proceedings. When he
+stopped paying, his counsel communicated that he would start paying again when there were
+settlements. This in itself constitutes an acknowledgment of his obligation to do so. Having initially
+paid and thus inducing continued performance by the Atty Rep, Epstein is now equitably estopped
+to deny his contractual obligation. The Atty Rep, on the other hand, has fully completed his part of
+the bargain by providing the necessary services to make it possible for
+her claim without filing a contested lawsuit, and the Atty Rep is entitled to be paid in fill for those
+services by Epstein. Finally, there is the implied obligation of good faith and fair dealing inherent
+in every contract, including those intended to benefit third parties.
+Please advise us of your position prior to Friday's hearing, because your position may
+influence our involvement at that hearing.
+Very truly yours,
+Katherine WiEzel
+Katherine W. Ezell
+KWE/mce
+
+
+Stachments:
+I (USAFLS)
+KATHERINE W. EZELL I
+20090616162817672.pét
+every atta ce discuss tomo this 02 eagent 1 was both parties agree in ting that
+
+
+Subject:
+I (USAFLS)
+KATHERINE W. EZELL
+Tharsday June 11
+009 6:13 PM
+L (USAFLS)
+Letter from Critton Denying any Fees and hearing tomorrow
+that we believe you are one ones any s of your weir for cur fred you were alertin
+tomorrow, Kathy
+
+
+AND AFFILIATED PARTNERSHIPS
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4611
+Jay P. Lefkowitz,
+jay.lefkowitz@kirkland.com
+Facsimile:
+www.kirkland.com
+June 12, 2009
+VIA FEDERAL EXPRESS
+Mited States Aloney's ofice
+500 South Australian Ave., Suite 400
+West Palm Beach, Florida 33401
+Re:
+Jeffrey Epstein
+Dear Ms.
+I am in possession of your June 12, 2009 letter giving notice of breach. I respectfully
+submit that the Motion to Dismiss that is referenced therein did not constitute a willful breach of
+Mr. Epstein's obligations under the non-prosecution agreement. Mr. Epstein's counsel
+unanimously determined that the filing of this Motion to Dismiss was not a breach of the nonprosecution agreement, and the Motion to Dismiss was filed by counsel without Mr. Epstein's
+final approval.
+I want to inform you that immediately upon receipt of your letter, Mr. Epstein directed his
+counsel to file the attached Notice withdrawing all but issue number VIII of the previously filed
+Motion to Dismiss. The same issue also is described briefly in subparagraph D on page 3 of the
+the civil dockets causes you to have additional concerns about any other filing, consistent with
+the notice provisions of the non-prosecution agreement and consistent with our prior practice
+regarding such matters, please provide me with notice and the opportunity to address the same
+I believe that with today's filing withdrawing these issues Mr. Epstein, through counsel,
+has fully remedied any perceived breach. Please advise if you for any reason disagree.
+Respectfully submitted,
+Souply
+lay P. LefKowitz
+Chicago
+Hong Kong
+London
+Los Angeles
+
+
+CC:
+H de Esq.
+
+
+Case 9:09-cv-80591-KAM Document 53 Entered on FLSD Docket 06/12/2009 Page 1 of 2
+CASE NO.: 09-CIV- 80591 - KAM
+DOE NO. 101,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT JEFFREY EPSTEIN'S NOTICE OF WITHDRAWL OF ARGUMENTS I
+THROUGH VII OF THE DEFENDANT'S MOTION TO DISMISS PLAINTIFF'S FIRST
+AMENDED COMPLAINT (DE29)
+Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, hereby
+withdraws arguments I through VII as set forth in the Defendant's Motion to Dismiss the
+Plaintiff's First Amended Complaint (FAC) [DE 29], dated May 26, 2009. Defendant withdraws
+his arguments contained subparagraphs A, B, I and Sections I (The Complaint Must Be
+Dismissed Because Plaintiff Is Not A Minor), II (The FAC Must Be Dismissed Because The
+Defendant Has Not Been Convicted Of A Predicate Offense), III (Count One Of The FAC Must
+Be Dismissed Because It Does Not Please A Violation Of 18
+• § 2422(b)), IV (Count Two
+Must Be Dismissed Because It Does Not Plead A Violation Of 18
+1. 82423(b)), L (Count
+Three Must Be Dismissed Because It Does Not Plead A Violation Of 18
+• § 2251, VI
+(Counts Four and Five Must Be Dismissed Because They Do Not Plead Violation of 18|
+§§ 2252(a)(1) Or 2252(a)(1), and VII (Count Six Must Be Dismissed Because 18 |
+1. 8
+2252A(g) Was Not Enacted Until 2006).
+Defendant will rely only on those arguments set forth in subparagraph D, on page 3, and
+Paragraph VIII (Any Surviving Count Should Be Merged Into A Single Count) of the
+
+
+Case 9:09-cv-80591-KAM
+Document 53 Entered on FLSD Docket 06/12/2009 Page 2 of 2
+Defendant's Motion to Dismiss the First Amended Complaint Or, In The Alternative, For A
+More Definite Statement [DE 29] dated May 26, 2009.
+Counsel for Dopendant EPSTEIN
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day on lin in aard genified on the following Service List in the manner specified by
+Robert . Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+agesg@bellsouth.ne
+'ounsel for Defendant Jeffrey Epstei
+Counsel for Plaintiff
+Respectfully submitted./
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bay No. 224162
+crit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+(Counsel for Defendant Jeffrey Epstein)
+
+
+Jay P. Lefkowitz, F
+lefkowitz/@kirkland.com
+AND AFTILIATED PARTNERSHIPS
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4611
+www.kirkland.com
+Facsimile:
+June 15, 2009
+VIA FACSIMILE
+United States Attorney's Office
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epstein
+Dear
+I am attaching a letter authored by my co-counsel, Robert Critton, on today's date. It
+represents our agreement with a proposal that Kathy Ezell indicated in a letter dated June 8, 2009
+would be fully acceptable to her and Bob Josefsberg as a means to resolve expeditiously all
+outstanding fee issues regarding the attorney representative. Mr. Epstein has directed his counsel
+to take immediate steps to address and resolve the attorney representative's outstanding feerelated issues and we are doing so without delay. The suggestion of a Special Master, agreed to
+by both parties, to resolve the issues in the immediate future, will assure all parties that there will
+be no delay and no need for adversarial litigation regarding fees.
+More generally, I want to assure you that Mr. Epstein has directed all counsel to make
+sure that there is no filing that could constitute a breach of the NPA. Accordingly, a new internal
+addressed in the NPA (a document including sentences within paragraph 8 that even Mr. Acosta
+agreed were "far from simple"), we intend to address such issues with you prior to any filing and
+hope that you will agree to review the draft filing and inform us whether or not from your
+perspective it would, if filed, constitute a "breach". This will be especially important regarding
+issues that we believe fall at the intersection of Section 2255 and the civil litigation. We reserve
+our right, if you believe a proposed filing to conflict with the NPA or if you wish not to address
+these issues with us, thereafter to address such substantive issues with the Court.
+Chicago
+Hong Kong
+London
+Los Angeles
+
+
+Ms. 1
+June 15, 2009
+We hope that these proposals—in combination with our immediate withdrawal of the
+previously filed Motion to Dismiss-resolve all outstanding issues at the intersection of the NPA
+and 2255. Please advise if any remain.
+Sincerely,
+Enclosure
+cc:
+
+
+J. MICHAEL BURMAN, P.A.'
+MARK T. LUTTIER, P.A.
+MICHAEL 1. PIKE
+HEATHER MCNAMARA RUDA
+June 15, 2009
+BARBARA M, McKENNA
+ASHLIE STOKEN-BARINK
+BETTY STOKES
+PARALEGALS
+RITA H. BUDNYK
+OF COUNSEL
+Sent by E-mail and U.S. Mail
+Robert Josefsberg, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+Re: Epstein Matter
+Dear Bob:
+On June 8, 2009, Kathy Ezell wrote a letter to me regarding outstanding fee
+payment issues. At page 3, she stated that she was not adverse to an earlier proposal
+that had been discussed amongst the parties to rely on a Special Master to resolve
+utstanding fee-related issues. We agree with Kathy's "proposal" that we rely on a
+Special Master to resolve all outstanding fee issues. Let's work during our Wednesday
+meeting to select an appropriate Special Master and let's agree to see whether, in the
+interim, we can resolve these issues even before they are submitted to the S.M.
+Cordially yours,
+Roberto
+• Critton, Jr.
+RDC/clz
+CC:
+Jack Goldberger, Esq.
+L'A •W
+*Y•E • R • S
+515 N. FLAGLER DRIVE / SUITE 400 / WEST PALM BEACH, FLORIDA 33401
+
+
+500 S. Australian Ave, Ste 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+June 17, 2009
+DELIVERY BY ELECTRONIC MAIL
+Jay P. Lefkowitz, Esq.
+Kirkland & Ellis LLP
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4675
+Re: Jeffrey Epstein
+Dear Jay:
+Thank you for your letter of June 15, 2009. I did not receive your letter until late
+yesterday afternoon because I am shuttling back and forth between the Fort Lauderdale and
+West Palm Beach offices. The best way to reach me is via e-mail.
+With respect to the substance of your letter, the Office has not completed its review
+of Mr. Epstein's civil filings and correspondence related to the payment of the attorney
+representative's fees, so I cannot confirm that all outstanding issues have been resolved. If
+and when additional breaches are identified, timely notice will be provided in accordance
+with the terms of the Non-Prosecution Agreement.
+As to your proposal, our Office cannot and will not become involved in the civil suits
+filed against Mr. Epstein; as counsel for Mr. Epstein has expressed on several occasions, it
+is inappropriate for the government to involve itself in civil litigation. We likewise do not
+think it is appropriate to review civil pleadings in order to provide advisory opinions, even
+at your request.
+The duty to stay within the bounds of the Non-Prosecution Agreement lies with Mr.
+Epstein and he alone has the power to remain in compliance. Mr. Epstein has a highly skilled
+team to assist him, and compliance with the Agreement is not difficult, as you suggest. For
+example, it is not complicated to understand that, when a named victim files a claim
+
+
+JAY P. LEFKOWITZ, ESQ.
+JUNE 17, 2009
+
+exclusively under Section 2255, Mr. Epstein cannot assert that there is no liability, just as
+providing the state plea agreement to our Office in advance of entering the state guilty plea
+was not complicated.
+I remain hopeful that Mr. Epstein will take all of his obligations seriously and elect
+to err on the side of caution in making decisions that relate to the performance of his duties.
+Sincerely,
+Jeffrey H. Sloman
+Acting United States Attorney
+By
+Assistant United States Attorney
+cc:
+, Chief, Northern Division
+Jack Goldberger, Esq.
+Roy Black, Esq.
+
+
+Jay P. Lefkowitz, 1
+To Call Writer Direcily
+lefkowita@kirkland.com
+AND AFFILIATED PARTNERSHIPS
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4611
+www.kirkland.com
+Facsimile:
+June 15, 2009
+VIA FACSIMILE
+United States Attorney's Office
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epstein
+Dear
+I am attaching a letter authored by my co-counsel, Robert Critton, on today's date. It
+represents our agreement with a proposal that Kathy Ezell indicated in a letter dated June 8, 2009
+would be fully acceptable to her and Bob Josefsberg as a means to resolve expeditiously all
+outstanding fee issues regarding the attorney representative. Mr. Epstein has directed his counsel
+to take immediate steps to address and resolve the attorney representative's outstanding feerelated issues and we are doing so without delay. The suggestion of a Special Master, agreed to
+by both parties, to resolve the issues in the immediate future, will assure all parties that there will
+be no delay and no need for adversarial litigation regarding fees.
+More generally, I Want to assure you that Mr. Epstein has directed all counsel to make
+sure that there is no filing that could constitute a breach of the NPA. Accordingly, a new internal
+screening process has been established to provide focused decision-making on each filing. To
+the extent we believe any filing may be perceived as implicating any of the issues generically
+addressed in the NPA (a document including sentences within paragraph 8 that even Mr. Acosta
+agreed were "far from simple"), we intend to address such issues with you prior to any filing and
+hope that you will agree to review the draft filing and inform us whether or not from your
+perspective it would, if filed, constitute a "breach". This will be especially important regarding
+issues that we believe fall at the intersection of Section 2255 and the civil litigation. We reserve
+our right, if you believe a proposed filing to conflict with the NPA or if you wish not to address
+these issues with us, thereafter to address such substantive issues with the Court.
+Chicago
+Hong Kong
+London
+Los Angeles
+
+
+Ms. Al
+June 15, 2009
+We hope that these proposals—in combination with our immediate withdrawal of the
+previously filed Motion to Dismiss—resolve all outstanding issues at the intersection of the NPA
+and 2255. Please advise if any remain.
+Sincerely,
+Enclosure
+cc: VKaren Atkinson, Esq.
+
+
+EPFREY PEPI
+SICHAEL
+' FLORIDA BOARD CERTIFTED
+TRIAL LAWYE
+June 15, 2009
+ARBARA M. MCKENN
+SHLIE STOKEN-BARD
+BETTY STOKES
+PARALIALS
+RITA H. BUDNYK
+OF COUNSEL
+Sent by E-mail and U.S. Mail
+Robert Josefsberg, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+Re: Epstein Matter
+Dear Bob:
+On June 8, 2009, Kathy Ezell wrote a letter to me regarding outstanding fee
+payment Issues. At page 3, she stated that she was not adverse to an earlier proposal
+that had been discussed amongst the parties to rely on a Special Master to resolve
+outstanding fee-related issues. We agree with Kathy's "proposal" that we rely on
+Special Master to resolve all outstanding fee issues. Let's work during our Wednesday
+meeting to select an appropriate Special Master and let's agree to see whether, in the
+interim, we can resolve these issues even before they are submitted to the S.M.
+Cordially yours,
+Roberyt
+Critton, Jr.
+RDC/clz
+CC:
+Jack Goldberger, Esq.
+L'A• W •Y
+515 N. FLAGLER DRIVE / SUITE 400 / WEST PALM BEACH, FLORIDA 33401
+
+
+Jay P. Lefkowitz,
+lefkowitz@kirkland.com
+AND AFFILIATED PARTNERSHIPS
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4611
+www.kirkland.com
+Facsimile:
+VIA FEDERAL EXPRESS
+United States Attorney's Office
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epstein
+Dear
+I appreciate your letter of June 17, 2009. I sincerely hope that any and all issues that
+could generate an adversarial relationship between Mr. Epstein and the United States Attorney's
+Office are in our past. Like you, we hope that the ongoing, complex, and at times vigorous
+litigation will not again require your involvement, nor result in any belief on your part that any
+legal position taken by Mr. Epstein's counsel conflicts with the Non-Prosecution Agreement
+("NPA").
+In order to avoid future misunderstandings, however, I would like to have a discussion
+with you specifically about our ongoing obligations as you understand them under the NPA. As
+you know from past experience, and as Mr. Acosta previously acknowledged in letters to my
+partner Ken Starr (on December 4, 2007) and Lilly
+_ Sanchez (on December 19, 2007), the
+language of 9 8 is "far from simple," and, in certain respects, subject to significant ambiguity.
+I believe it is both necessary and appropriate to seek immediate clarification from the
+government about its understanding of a few provisions in the NPA. It is likely by no fault of our
+own that these issues will come before a judge or an independent third party, whose job it will be
+to interpret the intent of the parties. In those circumstances, I think the court would most likely
+turn to both of us and directly seek our views, as the drafters of the agreement, before rendering
+its own opinion. Therefore, I believe it would bring about the finality that we both seek in a
+much reduced time frame if we could discuss several of the more ambiguous provisions
+contained in the NPA.
+Chicago
+Hong Kong
+London
+Los Angeles
+Washington, I
+
+
+One specific example comes to mind. First, we clearly understood during the course of
+negotiating the NPA, and believe that both the language of the NPA and our prior
+correspondence with your Office confirm, that the waiver of liability set forth in Paragraph 8 at
+most was designed to allow an identified individual the right to assert a single violation of a
+section 2255 predicate. The waiver of liability does not embrace situations where a particular
+plaintiff asserts multiple violations. Thus, compliance with paragraph 8's waiver of liability
+would require at most that Mr. Epstein stipulate to the existence of a single enumerated predicate
+that would entitle an otherwise eligible plaintiff to actual damages (or the applicable statutory
+minimum damages where actual damages fall short of that floor), leaving aside the issue of
+whether the waiver is applicable to contested litigation or only the cases where there would be
+agreed damage resolutions. In addition, if we believe that a predicate act is time-barred, as
+indeed we understand was the case with respect to all such acts in relation to one plaintiff, a
+proper construction of the waiver of liability would not preclude the reliance on a statute of
+limitations defense.
+Given your Office's prior acknowledgements that the language of the NPA is far from
+clear, we very much would appreciate an opportunity to discuss Paragraph 8 with you in the very
+near future in order to clarify a few pivotal questions raised by the NPA. I assure you that
+Mr. Epstein intends to abide fully by the terms of the NPA. And it is my sincere hope that our
+discussion can avert future risks that anything we do will cause you to believe that there has been
+a breach of the NPA.
+Finally, I enclose a letter in response to your June 15 letter in order to provide you with
+our perspective on the issues you raised. I hope our differing views on certain events over the
+past several years as reflected in my letter will not in anyway divert us from a common goal of
+having Mr. Epstein complete his NPA obligations without further tension with your Office.
+Sincerely,
+Jayp. hel
+Jay P. Lefkowitz,
+Enclosures
+
+
+AND AFFILIATED PARTNERSHIPS
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4611
+Jay P. Lefkowitz, 1
+lefkowitz@kirkland.com
+Facsimile:
+www.kirkland.com
+VIA FEDERAL EXPRESS
+United States Attorney's Office
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epstein
+Dear
+Chicago
+We prepared this answer in response to your letter dated June 15, 2009 and before
+receiving your follow up letter of June 17, 2009. At this point it has been almost three years
+since the federal government first intervened in what was originally a matter investigated and
+charged by state prosecutorial authorities. It has been almost a year since Mr. Epstein pleaded
+guilty in state court and began serving his sentence in county jail, pursuant to the terms and as a
+direct result of the federal Non-Prosecution Agreement (the "NPA"). When Mr. Epstein was
+sentenced, the U.S. Attorney promised me and my co-counsel that the United States Attorney's
+Office's involvement would cease with Mr. Epstein's execution of the NPA and incarceration in
+state custody. We were also promised that the federal government would not intervene in
+discretionary state or county decisions regarding the implementation of Mr. Epstein's sentence.
+We take this opportunity to address in detail each of the alleged instances you describe to
+support your position that Mr. Epstein has engaged in a pattern of breaching the NPA.
+Mr. Epstein's overriding commitment is, and has always been, to complete his jail sentence,
+fulfill his other obligations under the NPA, and reach final settlements of pending section 2255
+cases with plaintiffs who are agreeable to such settlements. We respectfully submit (and support
+through documentary evidence) that there have been no past breaches of the NPA. There have
+been no "willful" breaches of the NPA. There has been no pattern of breaches of the NPA.
+As an initial matter, it is important to consider your letter of June 15 and its contents in
+context. Mr. Epstein has satisfied, and continues to satisfy, his obligations pursuant to the NPA.
+Mr. Epstein pleaded guilty to a registerable state offense. He has already registered as a sex
+Hong Kong
+London
+Los Angeles
+
+
+offender, and has served over 11 months of his sentence in county jail. While such a plea and
+punishment were not otherwise sought by the State Attorney, Mr. Epstein agreed to the plea, the
+sentence, and the obligation to register as a sex offender as a direct result of obligations he
+agreed to undertake pursuant to the NPA. Furthermore, Mr. Epstein has already paid over
+$300,000 in civil settlements and fees for the attorney representative, and has agreed to submit
+issues regarding further fees to a Special Master pursuant to a proposal suggested by the attorney
+representative himself. The claimants whose matters have already been settled were identified
+by you as victims and, in one case, as a sign of good faith, Mr. Epstein paid a settlement to an
+individual he had no recollection of ever meeting, solely because she appeared on your July 2008
+list.
+We are prepared to address each of the statements contained in your June 15 letter. First,
+your statement that Mr. Epstein did not use his "best efforts" to enter his guilty plea and to be
+sentenced is, respectfully, without merit. Exhibit 1, June 15, 2009 Letter at 2. The date of entry
+of the state plea was deferred with the express written consent of United States Attorney Acosta,
+who recognized and expressly provided us with the opportunity to pursue an independent
+assessment of this matter by the Justice Department. The subsequent nine-month "delay" was a
+direct result of the Justice Department's determination that it was appropriate to convene an
+intense and time-consuming review. Thus, the delay was not dictated at all by Mr. Epstein, but
+instead, by the review process agreed to and, if you recall, initiated by Mr. Acosta.
+On June 23, 2008, the Justice Department concluded its final review and only seven days
+later, Mr. Epstein promptly entered his plea (on June 30, 2008) and immediately began serving
+his sentence. As the following timeline of events leading up to Mr. Epstein's entry of plea
+makes clear, the facts do not support your conclusion that Mr. Epstein willfully breached the
+NA by delaying his sentence, and, instead, compellingly demonstrates that Mr. Epstein's
+participation in high-level Department of Justice reviews cannot factually or legally ground a
+claim that he "willfully" breached the NPA:
+• The NPA, signed on September 24, 2007, provides that Mr. Epstein "begin serving his
+sentence not later than January 4, 2008." See Exhibit 2, NPA 1 11.
+• On November 28, 2007, Mr. Epstein's defense counsel contacted Assistant Attorney
+General Alice Fisher to request a review of certain provisions of the NPA. We informed
+the USAO of this request the very next day in a letter to Mr. Acosta. See Exhibit 3,
+November 29, 2007 Letter from J. Lefkowitz to U.S. Attorney Acosta at 4.
+• In a December 4, 2007 letter, Mr. Acosta stated that he supported the defense's appeal to
+Washington. See Exhibit 4, December 4, 2007 letter from U.S. Attorney Acosta to K.
+Starr with a copy to AAG Alice Fisher at 5 ("I do not mind this Office's decision being
+
+
+appealed to Washington, and have previously directed our prosecutors to delay filings in
+this case to provide defense counsel with the option of appealing our decision.").
+• On December 11, 2007, pursuant to Mr. Acosta's request, the defense team sent him
+submissions detailing the defense's concerns related to the NPA.
+See Exhibit 5,
+December 11, 2007 Letter from K. Starr to U.S. Attorney Acosta.
+• On December 14, 2007, Mr. Acosta met with members of the defense team to discuss the
+serious issues raised about the NPA.
+• In a December 19, 2007 letter, Mr. Acosta stated that "the issues raised are important and
+must be fully vetted irrespective of timeliness concerns." See Exhibit 6, December 19,
+2007 Letter from U.S. Attorney Acosta to Attorney Lilly L
+Sanchez at 3. He also
+stated that he had spoken with AAG Fisher to ask that she review this matter and to
+expedite the process. la.
+• In the beginning of January, 2008, Mr. Acosta and 1 discussed the need for further
+consideration of the issues raised by the defense. He postponed the plea and sentencing
+until the Child Exploitation and Obscenity Section (CEOS) was finished with its review
+of the case.
+• In a February 29, 2008 email I sent to Mr. Acosta, I confirmed that that "there were
+significant irregularities with the deferred prosecution agreement" and that he would ask
+CEOS to evaluate the matter. I also confirmed Mr. Acosta's agreement to postpone the
+state plea deadline until after the matter was reviewed. On that same day, First Assistant
+U.S. Attorney Sloman responded in writing as follows: "Please be assured that it has not,
+and never has been, this Office's intent to interfere or restrict the review process' for
+either Mr. Epstein or CEOS. I leave it to you and CEOS to figure out how best to
+proceed and will await the results of that process." See Exhibits 7 and 8, February 29,
+2008 Emails to U.S. Attorney Acosta and from Assistant U.S. Attorney Sloman.
+• Given that CEOS determined that it would not review many of the defense's objections
+and that its review would be limited on the rest of the objections, CEOS's decision,
+rendered on May 15, 2008, left open the need for a more thorough review of critical
+issues by others at the Justice Department.
+• In a May 28, 2008 email from Mr. Sloman to myself, Mr. Sloman further postponed the
+deadline to plead until the Deputy Attorney General's Office (DAG) completed its
+review. See Exhibit 9, May 28, 2008 Email from Assistant U.S. Attorney Sloman to J.
+Lefkowitz.
+
+
+Page 4
+• A final letter of determination was not issued by the Department of Justice until June 23,
+2008.
+• Just one week after that date, Mr. Epstein promptly entered his plea and immediately
+began serving his state sentence on June 30, 2008.
+While you state that a breach occurred because Mr. Epstein and the defense team did not
+provide you with the state plea documents until the last business day before the plea, neither
+Mr. Epstein nor his counsel bear sole responsibility for timing of the delivery of these
+documents. It was the responsibility of the State Attorney's Office to provide the defense with
+the plea agreement. Defense counsel did not receive the plea agreement from the State until
+10:00 A.M. on June 27, 2008 (the Friday before the plea). See Exhibit 10, June 27, 2008 Email
+from State Attorney Lanna Belohlavek to J. Goldberger. Once the plea agreement was reviewed
+by Mr. Epstein's defense team, Mr. Goldberger sent it to you that same afternoon. At 5:55 P.M.
+on June 27, 2008, following your receipt of the agreement sent to you by Mr. Goldberger,
+Messrs. Black and Goldberger received a responsive letter from you alleging that the plea
+agreement violated the NPA. See Exhibit 11, June 27/28, 2008 Email String between Assistant
+U.S. Attorney
+and R. Black and J. Goldberger (attaching Notice of Non-Compliance).
+Second, you state that language contained in the first draft of the plea agreement
+proposed by the State violated the NPA, because it called for community control in lieu of jail.
+Exhibit 1, June 15, 2009 Letter at 2. You now suggest that this "error" evidences Mr. Epstein's
+alleged efforts to undermine the NPA. I respectfully submit that you are mistaken in both cases.
+The language in the first draft of the plea agreement was prepared by the State and, as stated
+above, it was not sent to the defense until the very day that it was sent to you.
+Moreover, as Mr. Goldberger confirmed to you in a telephone conversation on the same
+day that he received your June 27 letter, the plea agreement, as originally drafted by the State,
+would have resulted in the exact same 12-month and 6-month consecutive jail sentences,
+followed by one year of community control, as was required by the NPA and ultimately imposed
+on Mr. Epstein. Although defense counsel asked the State to change the language of the plea
+agreement to alleviate your concerns, the same exact sentence and period of incarceration as
+required by the NPA would have been imposed on Mr. Epstein had the language of the State's
+first draft been allowed to apply. See Exhibit 11, June 27/28, 2008 Email String between
+Assistant U.S. Attorney
+and R. Black and J. Goldberger (confirming a telephone
+conversation between the parties on June 27 that the state plea agreement was in compliance
+with the NPA and indicating a request by Assistant U.S. Attorney
+to modify the
+language in the state plea agreement); see also Exhibit 12, the initial version and the signed
+version of the state plea agreements.
+
+
+Page 5
+The bottom line here is that while Florida counsel for Mr. Epstein fully believed that the
+initial language in the State's draft would result in a sentence identical to the mandates of the
+NPA, changes were made solely to conform to your requests. Neither the USAO or the
+administration of federal criminal justice suffered any prejudice: lawyers often make linguistic
+alterations of form; we did so here. The changes were made in short order, namely, during the
+Friday and Saturday before Mr. Epstein's state plea; the plea and plea agreement completely
+complied with the NPA as did Mr. Epstein's sentence; and there was neither a breach, nor harm.
+Moreover, all communications were through counsel. Mr. Epstein was not a party to these
+communications and in no way can be considered, factually or legally, to have committed a
+"willful" breach of the NPA in this regard.
+Third, you state that defense "counsel obstructed [your] ability to abide by [your]
+obligations to notify the victims of the outcome of the federal investigation." Exhibit 1, June 15,
+2009 Letter at 2. We believe that this statement misconstrues the intentions and conduct of the
+defense team and, does not support any charge of "obstruction" against Mr. Epstein, as would be
+required to sanction him for a "willful" breach of the NPA. In October 2007, a full nine months
+before Mr. Epstein was sentenced, we first raised the issue of the notification. On October 10,
+2007, I stated in a letter to Mr. Acosta that the defense team did not believe "it was the
+government's place to be co-counsel to the identified individuals," and reasonably proposed that
+the alleged victims be contacted by the selected attorney representative. See Exhibit 13, October
+10, 2007 Letter from J. Lefkowitz to U.S. Attorney Acosta at 4-5.
+Then, on November 28, 2007, you sent defense counsel the proposed victim notification
+letter indicating that the alleged victims had a federal right to be notified of the resolution of this
+matter pursuant to the Crime Victims' Rights under § 3771. See Exhibit 14, November 29, 2007
+Draft Victim Notification Letter from Assistant U.S. Attorney
+Mr. Epstein's counsel
+objected to your draft letter and the proposed method and procedure for notifying the alleged
+victims and challenged whether you were in fact obligated to notify these individuals pursuant to
+18
+§ 3771. Those objections were made in a timely and appropriate manner and our
+dialogue regarding notification issues continued. As you know, the notification letter was not
+finalized for several months.
+The key point here is that our objections to the letter were made in good faith and were
+well-founded. After all, on December 6, 2007, Mr. Acosta agreed to many of our objections and
+adopted several of our modifications to resolve problems raised by the draft notification letter.
+See Exhibit 15, December 6, 2007 Letter from U.S. Attorney Acosta to J. Lefkowitz. This fact
+confirms both the good-faith nature of our objections and that neither Mr. Epstein nor his counsel
+could be considered to have violated the NPA by raising those objections in the first place.
+Fourth, Mr. Epstein did not, as you stated, refuse "to fulfill promptly Mr. Epstein's
+obligation to secure the services of an attorney representative for the victims." Exhibit 1, June
+
+
+Page 6
+15, 2009 Letter at 2. It was the United States' obligation to sclect a suitable attorney
+representative, subject to the good-faith approval of Mr. Epstein's counsel. See Exhibit 2, NPA
+17. Indeed, due to a concern we had raised, your Office specifically modified the procedure to
+select an attorney representative and delegated that task to Judge |
+. See Exhibit 16,
+Addendum to NPA 1 7A. Again, the fact that your Office accommodated our concerns validates
+their legitimacy and undermines any claim that the NPA was breached by raising those concerns
+with you. To the contrary, Mr. Epstein executed the Addendum in an attempt to resolve
+outstanding, highly unorthodox and complex issues at the intersection of civil and criminal law.
+A letter to Judge L
+(authored by then FAUSA Sloman) dated October 25, 2007 followed.
+See Exhibit 17, October 25, 2007 Letter to Judge
+Once Mr. Podhurst's firm was selected by Judge
+1, Mr. Epstein did not object to the
+selection. Moreover, as you have acknowledged to the court, the open issues involving the
+attorney representative portions of the NDA were not finally resolved until September 3, 2008.
+See Exhibit 18, December 22, 2008
+Supplemental Declaration at 3 1 9. Only five days
+later, on September 8, 2008, I sent a letter to Robert Josefsberg advising him that Mr. Epstein
+would pay his fees pursuant to the NPA for his role as an attorney representative. See Exhibit
+19, September 8, 2008 Letter from J. Lefkowitz to R. Josefsberg. Furthermore, in an effort to
+comply with the obligations under the NPA, Mr. Epstein already has paid Mr. Podhurst's firm
+over $160,000 in legal fees, despite significant concerns over the scope of the work for which he
+is billing Mr. Epstein, and has agreed with Mr. Josefsberg's proposal that a Special Master be
+empowered to resolve any fee related issues that the Podhurst firm and Mr. Epstein's civil
+counsel cannot resolve. See Exhibit 20, June 15, 2009 Letter from Robert Critton to Kathy Ezell.
+There is nothing about the exchanges between counsel and the USAO regarding the attorney
+representative that even begins to approach a "willful" breach by Mr. Epstein.
+Fifth, you suggest that Mr. Epstein willfully breached the NPA because of the actions of
+Mr. Tein and Mr. Goldberger, whom you state failed to approve the victim notification letter that
+contained incorrect information. See Exhibit 1, June 15, 2009 Letter at 2. The incorrect
+information in the letter was a
+proposed unilateral modification to the NPA without prior
+approval by Mr. Epstein or any member of the defense team. It was only first suggested by your
+Office in a letter from Mr. Acosta on December 19, 2007. We never agreed to that language. In
+fact, I personally raised several objections to the suggested modification in my letter to Mr.
+Acosta, dated December 21, 2007. See Exhibit 21, December 21, 2007 Letter from J. Lefkowitz
+to U.S. Attorney Acosta. I personally became aware of the inclusion of that language on
+Wednesday, August 13, 2008 and discussed the matter with you immediately. See Exhibits 22
+and 23, August 13 and 15, 2008 Letters from Assistant U.S. Attorney
+to J. Lefkowitz
+(confirming that the "December modification" is not a part of the NPA). Again, that oversight
+was not a willful breach or an expression of intent to violate the terms of the Agreement, but
+instead represented the efforts of counsel, acting in good faith, in an attempt to insure that the
+letter contained only previously agreed-upon language.
+
+
+Page 7
+Sixth, you raise the issue of a delayed withdrawal of a motion to quash. See Exhibit 1,
+June 15, 2009 Letter at 2-3. There is no motion to quash that still remains pending. The fact that
+the motion was not withdrawn for some time was merely due to an administrative oversight that
+has long been remedied, but at no time did it prejudice the Government in any way. Nor did it
+result from an effort by myself or co-counsel to gain some tactical advantage. Furthermore, no
+effort was made by any counsel to seek a judicial decision on the pending motion. The motion
+had no adverse effect on the Government, and the delay in its withdrawal is legally and factually
+unrelated to the type of material and willful breach that alone could warrant remedies-not least
+of all because Mr. Epstein has suffered irreversible prejudice by complying with the core
+provisions of the NPA. Again, he has been imprisoned, he has pled guilty, he is registered, he
+has paid sums to claimants, all to comply with his obligations under the NPA.
+Seventh, you state that additional issues arose in November regarding the issuance of
+work release to Mr. Epstein. Exhibit 1, June 15, 2009 Letter at 3. We have previously reviewed
+this very matter with you and other individuals in your Office in November 2008. At that time,
+Mr. Roy Black met with you,
+in Miami to
+review the work release issue. Among other significant documents shown to you, we presented
+you with your own email in which you had previously acknowledged that the sheriff had
+discretion in the matter. See Exhibit 24, July 3, 2008 Email from Assistant U.S. Attorney
+to Michael Gauger ("If Mr. Epstein is truly eligible for the [work release] program, we
+have no objection to him being treated like any other similarly situated prisoner ...").
+Furthermore, Mr. Acosta, as already stated, had previously assured me and other counsel that the
+USAO would not interfere in the ordinary implementation of discretionary administrative
+decisions by state or county officials. We believe we were under no obligation (in the NPA or
+anywhere else) to notify you of such discretionary and ordinary state-made decisions, and the
+fact that your Office confirmed that Mr. Epstein was entitled to the same discretionary
+administrative decisions as other similarly situated inmates fundamentally undermines any claim
+that Mr. Epstein breached the NPA in connection with the state and county officials' decision. In
+any event, after thoroughly reviewing and evaluating Mr. Epstein's application, the Palm Beach
+County Sheriff's Office properly exercised its discretion, in full compliance with its stated
+requirements, policies and procedures, to grant Mr. Epstein work release. In addition, after the
+Sheriff's Office received a multi-page letter from you to Captain Sleeth, which recited the very
+allegations of errors on Mr. Epstein's work release application to which you refer in your latest
+letter, each allegation was fully reviewed, and the Sheriff's office found its initial decision
+appropriate.
+Eighth, it is both unreasonable and unjustifiable to hold Mr. Epstein responsible--never
+mind declare him in breach—with regard to Judge MeSorley's nunc pro tune order. Exhibit 1,
+June 15, 2009 Letter at 3. Neither Mr. Epstein nor defense counsel had anything to do with and
+certainly no prior knowledge of this order. Defense counsel only learned of it after you brought
+it to our attention. The facts are as follows: the Department of Corrections requires an order
+
+
+Page 8
+placing someone on community control before the Department of Corrections will supervise that
+person. Judge Pucillo, the retired judge that took Mr. Epstein's plea, inadvertently neglected to
+enter the order placing Mr. Epstein on Community Control 1. When Judge McSorley learned of
+this, she properly entered the order nunc pro tune to the date of the plea. See Exhibit 25, Order
+of Community Control. If you will note on the 3-page court event form, circled at the top of
+page 2, is "1
+1" (community control 1). Mr. Epstein was properly placed on community
+control 1 on the day of his plea to begin only after he completes his jail sentence, and the nunc
+pro tune order simply ratifies the oral pronouncement made by the court at the time of the plea.
+Given that the NPA expressly provides that Mr. Epstein is to serve a sentence of 12 months in
+"community control consecutive to his two terms in county jail," Exhibit 2, NPA 9| 2(b), your
+assertion that the inclusion of community control "directly contradicted the terms of the NPA is
+incorrect.
+Finally, the motion to dismiss that was the topic of discussion on June 12 has been
+withdrawn. As indicated in the letter I sent you on June 15, we have adopted an internal
+screening process aimed at eliminating future concerns about anything that reasonably could be
+considered a breach of the NPA. See Exhibit 26, June 15, 2009 Letter from J. Lefkowitz to
+Assistant U.S. Attorney
+Mr. Epstein has directed all counsel to make certain that no
+filing could be construed as a breach of the NPA. Furthermore, we proposed a supplemental new
+process, as stated in my June 15 letter to you, that would have provided you, if you chose, the
+opportunity to review any such filing before it is submitted to the court so that you may
+determine whether or not it constitutes a breach.
+That being said, I wish to reiterate our firm belief that the NPA allowed Mr. Epstein the
+right to contest litigation whenever an express waiver of all other state, federal or common law
+claims or the right to bring contested litigation in the future was not sufficiently or correctly
+pleaded. As you know, we spent several weeks negotiating the language of the NPA with you
+and Mr. Acosta. We firmly believe that the motion to dismiss that was recently filed (and then
+promptly withdrawn) did not constitute a violation.
+First, Paragraph 8 of the NPA clearly limits those who may benefit from any waivers by
+Mr. Epstein to an "identified individual" who "elects to proceed exclusively under 18 USC 2255,
+and agrees to waive any other claim for damages, whether pursuant to state, federal, or common
+law". Exhibit 2, NPA 18. More is required of a plaintiff than to simply allege, as did
+Doe
+101, that she "exclusively seeks civil remedies pursuant to 18 USC 2255." Exhibit 27, Amended
+Complaint 9 24. Such an averment satisfies only the exclusivity portion of the twin conditions
+set forth in the NPA at 9| 8. The word "and" followed by the requirement of an affirmative
+waiver of any other claims, federal, state, or common law mandates an additional affirmative act
+by the plaintiff. No such waiver was filed or even pled.
+Doe 101 did no more than restate
+that her complaint in civil action no 9:09-cv-80591-KAM was only for 2255 damages. She
+never affirmatively waived all future claims in state or federal court, as required by the NPA.
+
+
+Page 9
+Because of this threshold issue,
+Doe 101 did not, through the attorney representative, satisfy
+the NPA 9| 8 requirements.! While Mr. Epstein's counsel still believe for these reasons that the
+motion did not conflict with Mr. Epstein's obligations under the NPA, the motion was in relevant
+part withdrawn at Mr. Epstein's insistence-further demonstrating that Mr. Epstein has
+prioritized his desire to avoid contentious additional litigation with the USAO over this matter.
+In short, our good-faith efforts to raise litigation issues will be more carefully scrutinized
+in the future as to limit the possibility of being construed by your Office as supporting a notice
+that Mr. Epstein is in "willful" breach. Issues regarding the scope of the 9j 8 waivers are
+unorthodox and even unprecedented. They result in part from the NPA being executed before
+you identified the individuals listed, see Exhibit 2, NPA 9 7, and, importantly, given the
+evolution of the civil litigation, before any joint statement as required by the terms of the NPA
+was provided to Mr. Josefsberg. Nevertheless, as we stated on June 15, we had intended to
+provide you with future filings in advance so that we could discuss their interaction with the
+NPA before rather than after any filing, However given your rejection of that procedure, in a
+good faith attempt to avoid future conflict, we would nevertheless hope to clarify some of the
+more ambiguous parts of 918 of the agreement with you as soon as possible. To repeat, it is
+Mr. Epstein's overriding intent to fulfill his obligations under the NPA -- an intent we as his
+attorneys will do everything in our power to effectuate.
+The facts demonstrate that Mr. Epstein has clearly not committed any breach of the NPA,
+much less a willful breach. As we have reiterated and as has been proven by Mr. Epstein's own
+actions, Mr. Epstein has no intention of breaching the NPA and has never had any such intention.
+Although you claim that Mr. Epstein received the benefits of the NPA and the Government only
+its burdens, I believe the reality is to the contrary. Mr. Epstein has suffered significant and
+irreversible prejudice: he has been imprisoned in a county jail for almost a year, he has pleaded
+guilty to a state felony that required sex registration and has, in fact, registered as a sex offender,
+he accepted civil burdens in his ongoing litigation that may result in millions of dollars of future
+payments, he has settled cases that could be won, in deference to the NPA and he is paying and
+1 That
+Doe 101 did not meet the threshold requirements for the imposition of the waiver of liability portion
+of Paragraph 8 of the NPA is demonstrated by the filings of Doe II in 09-80469-CIV-Marra, a federal
+lawsuit filed in March, 2009 seeking "exclusively 2255" damages, while Doe II already had a pending
+state court suit filed in July of 2008 seeking damages against Epstein for sexual assault and conspiracy.
+oe Il in her federal complaint alleged Epstein could "not contest liability for claims brought exclusivel
+§2255". Exhibit 27, Amended Complaint 1 24. In her response to Epstein's Motion to
+Dismiss in which Epstein challenged the "exclusivity" claim, she argued at page 7 that "Epstein appeared to be
+violating the agreement ... [NPA]". However, her attorney withdrew that claim at the June 12, 2009 hearing
+(and in her subsequent Amended Response) agreeing that the state filing negated the "exclusivity" of the federal
+2255 lawsuit. On the current record, nothing prevents Doe 101 from filing a parallel state court claim.
+
+
+Page 10
+will pay hundreds of thousands of dollars in legal fees for his adversaries to pursue him in court.
+The Government may have endured some delays and administrative costs due to certain of its
+own its decision - such as to evaluate the Sheriff's exercise of discretionary authority in
+implementing the Sheriff's own work release program —but neither the Government nor any
+civil plaintiff has suffered any harm, any prejudice, or any disadvantage as a result of the events
+you have identified. We signed a contract -- the NPA -- with you in good faith, and in exchange,
+Mr. Epstein gave consideration that cannot be returned (12 months of his freedom and his
+reputation). He is legally entitled to its benefits. He committed no "willful breach." As such,
+we believe it would constitute both a contractual and constitutional error to seck further remedy
+or to in any way withdraw from the NPA.
+We will continue to make our best efforts to communicate with you about any potential
+problems and hope, in the interest of fairness, you will do the same.
+Sincerely,
+Fun Phely
+ay P. Lefkowitz, P.C
+Enclosures
+
+
+DEDICATED TO JUSTICE & SAFETY
+LEOPOLD-KUVIN.
+July 6, 2009
+Assistant U.S. Attorney
+500 E. Broward Blvd, 7th Floor
+Ft. Lauderdale, FL 33394
+Re: B.B. | JEFFREY EPSTEIN
+OUR FILE NO.: 080303
+Dear Ms.
+As you are aware, this firm represents Plaintiff, Jane Doe, a/k/a/ B.B. in the civil litigation
+against Jeffrey Epstein styled B.B. |. Jeffrey Epstein, case no.: 502008CA037319 MB AB. We
+are hereby requesting that a copy of the non-prosecution agreement be provided to my office as
+If there are any questions or concerns regarding the production of this agreement, please contact
+me at once.
+Sincerely,
+PENCER T. KUVIN
+STK/mlb
+2925 PGA Boulevard • Suite 200 Palm Beach Gardens Florida 33410 = 561.515.1400 : fax 561.515.1401 = leopoldkuvin.com
+CRASHWORTHINESS • MANAGED CARE ABUSE • CONSUMER CLASS ACTIONS • PERSONAL INJURY • WRONGFUL DEATH
+
+
+500 E. Broward Boulevard, 7th Floor
+Fi. Lauderdale, FL 33394
+(954) 356-7255
+July 7, 2009
+DELIVERY BY ELECTRONIC MAIL
+Jay P. Lefkowitz, Esq.
+Kirkland & Ellis LLP
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4675
+Re: Jeffrey Epstein
+Dear Jay:
+Thank you for your letters of June 19th. From your letters, it appears that you have
+misconstrued the Office's past efforts at alleviating Mr. Epstein's unfounded fears of
+disparate treatment. You seem to have interpreted those efforts as either: (1) an
+acknowledgement of the validity of those fears, or (2) an acquiescence to the efforts of Mr.
+Epstein to avoid the full terms of the Non-Prosecution Agreement. So, for example, you
+write that, in an email to Mr. Acosta, you "confirmed that 'there were significant
+irregularities with the deferred prosecution agreement,'" and that "Mr. Acosta agreed to
+many of our objections and adopted several of our modifications ... [and] [this fact
+confirms both the good-faith nature of our objections and that neither Mr. Epstein nor his
+counsel could be considered to have violated the NPA by raising those objections in the first
+place." Neither your e-mails nor Mr. Acosta's consistent attempts to maintain a good
+working relationship with you act as modifications to the NPA or indications that the Office
+agreed or acquiesced to your positions.
+While your letter provides great detail regarding all of the objections that you raised'
+'In an effort to terminate the endless "battle of letters" that this case has become, I have
+the procedure to select an attorney representative and delegated that task to Judge
+
+
+JAY P. LEFKOWITZ, ESQ.
+JULY 7, 2009
+
+throughout the nine-month delay between the signing of the NPA and Mr. Epstein's
+commencement of performance, you neglect to mention that all of your objections were
+soundly rejected at each and every level of review, from West Palm Beach, to Miami, to the
+Child Exploitation and Obscenity Section, and, finally, to the highest levels of review at the
+Department of Justice. As Senior Associate Deputy Attorney General John Roth stated:
+Even if we were to substitute our judgment for that of the U.S. Attorney, we
+believe that federal prosecution of this case is appropriate. Moreover, having
+reviewed your allegations of prosecutorial misconduct, and the facts
+underlying them, we see nothing in the conduct of the U.S. Attorney's Office
+that gives us any reason to alter our opinion.
+With regard to your proposal to engage in additional discussions regarding the scope
+of the NPA, we respectfully decline. A great deal of time and effort went into the negotiation
+and signing of the NPA, and the Agreement speaks for itself. Contrary to your assertion,
+both the government and the victims have suffered harm and prejudice due to the willful
+breaches of the NPA by Mr. Epstein. The Office will continue to evaluate its position and
+will proceed accordingly.
+By:
+Sincerely,
+Jeffrey H. Sloman
+Acting United States Attorney
+s/A.
+A.
+Villafaña
+Assistant United States Attorney
+CC:
+Chief, Northern Division
+Jack Goldberger, Esq.
+Roy Black, Esq.
+fact that your Office accommodated our concerns validated their legitimacy ..." As you have been
+told repeatedly, the decision to delegate that task to a Special Master was made independently and
+before any of Mr. Epstein's attorneys voiced a concern about that process. Mr. Lefkowitz, you were
+provided with a list of potential attorney representatives and with information in writing regarding
+the alleged "conflict of interest," and you made the selection that you later claimed was problematic.
+Notwithstanding your agreement on the selection of the attorney-representative, our Office,
+independently, elected to ask an independent third party to make the final decision.
+
+
+MICHAEL BURMAN, P.A
+REGORY W. COLEMAN, P.
+MICHAEL J. PIKE
+HEATHER McNAMARA RUDA
+I FIVE TRIAL LAW CERTIED
+July 8, 2009
+DELQUI J. BENAVENT
+ARALBIAL/ INVESTIGATO
+BARBARA M. McKENNA
+ASHLIE STOKEN-BARING
+SETTY STOKES
+ARALEGALS
+RITA H. BUDNYK
+OF COUNSEL
+SENT BY FEDERAL EXPRESS
+_ Esq.
+Assistant U.S. Attorney
+500 East Broward Boulevard, 7' Floor
+Ft. Lauderdale, FL 33394
+Re:
+Doe No. 8 |. Jeffrey Epstein
+Case No. 09-CV-80802-Marra/Johnson
+Dear Ms.
+As you are aware, I am Mr. Epstein's attorney in the civil cases that have been
+filed against him. While I am certainly familiar with the NPA, it is clear to me that my
+interpretation of it may differ from yours (USAO) or one of the many plaintiffs' attorneys
+as it relates to what I can do or assert in defense of Mr. Epstein.
+As I expressed to Judge Marra, my charge from Mr. Epstein is to take no action
+that could reasonably be considered to be a violation of the NPA. With that in mind, I
+am sending our motion to dismiss in
+Doe #8, along with a copy of her complaint.
+While I know you expressed to Mr. Lefkowitz that you (USAO) were not inclined
+to review pleadings and offer advisory opinions, I would ask that you reconsider and
+review our motion.
+The Plaintiff
+Doe No. 8 is not exclusively asserting a claim pursuant to 18
+. §2255, and thus, the terms of the NPA are not implicated. In fact,
+Doe No.
+8's counsel, Adam Horowitz, who also is counsel for Plaintiffs
+Does Nos. 2 through
+7 in other civil actions against Mr. Epstein, in the June 12, 2009 hearing before U.S.
+District Judge Kenneth Marra (at which you were also present) conceded that -
+The provision (of the NPA) relating to Mr. Epstein being unable to contest
+liability pertains only to those plaintiffs who have chosen as their sole remedy
+L•A•W • Y•E•R•S
+515 N. FLAGLER DRIVE / SUITE 400 / WEST PALM BEACH, FLORIDA 33401
+
+
+July 8, 2009
+the federal statute. My clients,
+Doe 2 through 7, have elected to bring
+additional causes of action, and it's for that reason we were silent when you
+said does anyone here find Mr. Epstein to be in breach of the nonprosecution agreement.
+This provision, as we understand it,
+it does not
+relate to our clients.
+June 12, 2009, Transcript of hearing in
+Doe, et al . Epstein, Case No. 08-
+80119-Civ-Marra, U.S. District Ct., S.D. Fla., p. 29, line 19-25, p. 30, line 1. A
+copy of the relevant portions of the hearing transcript is enclosed.
+I agree with his comments as they relate to all of his clients, including
+Doe 8.
+I believe that nothing in this motion involves any aspect of the NPA. If you disagree,
+would you please contact me as soon as possible. I must file this motion by July 14 as
+per my extension agreement with Mr. Horowitz. However, I stand ready to have a
+discussion or meeting with you regarding this motion or any other civil related pleadings
+or matter that may implicate the NPA. I look forward to your response.
+Cordially yours,
+Robert D. Criton, Jr.
+RDC/clz
+cc by pdf:
+Jack A. Goldberger, Esq.
+Martin G. Weinberg, Esq.
+Roy Black, Esq.
+Jay Lefkowitz, Esq.
+
+
+CASE NO.: 09-CV-80802-MARRA-JOHNSON
+DOE NO. 8
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT EPSTEIN'S MOTION TO DISMISS PLAINTIFF'S COMPLAINT
+Defendant, JEFFREY EPSTEIN ('Epstein"), by and through his attorneys, moves
+to dismiss Counts 1 and III of Plaintiff's Complaint as the causes of action are barred by
+the applicable statute of limitations.' Rule 12(b)(6); Local Gen. Rule 7.1 (S.D. Fla.
+2009). In support of dismissal, Defendant states:
+Plaintiff's Complaint attempts to allege three Counts; the first two counts are
+pursuant to state common law, and the third count is brought pursuant to 18
+§2255. Civil remedy for personal injuries. Count | attempts to allege a cause of action
+for "Sexual Assault and Battery," Count I for "Intentional Infliction of Emotional
+Distress;" and Count Ill for "Coercion and Enticement to Sexual Activity in Violation of
+18
+§2422," pursuant to 18
+. §2255.
+' Plaintiff's Complaint attempts to assert both state common law claims and a claim pursuant to
+18
+§2255. Since
+Doe 8 did not relinquish her state claims and correspondingly did
+not file her complaint relying, exclusively, on 18 USC 2255, she is not entitled to the litigation
+benefits including certain waivers that directly or indirectly accrue to other civil plaintiffs from the
+defendant's fulfilling obligations resulting from his separate confidential agreement with the
+United Staes Attorney's Office. Plaintiff's counsel conceded that the provisions of the NPA are
+not implicated where a plaintif brings additional causes of action and do et all steed
+exclusively under §2255. See June 12, 2009, Hearing Transcript in
+Case No. 08-80119-CIv-Marra, p. 29, line 19-25, p. 30, line 1.
+
+
+| Doe No. 8 L. Epstein
+Pursuant to the allegations on the face of Plaintiff's complaint, Count I, based on
+Florida's common law of assault and battery, and Count III, brought pursuant to 18
+• §2255, are barred by the applicable statute of limitations. Although a statute of
+limitations bar to a claim is an affirmative defense, and a plaintiff is not required to
+negate an affirmative defense in her complaint, a Rule 12(b)(6) dismissal on statute of
+limitations grounds is appropriate where, as here, "it is 'apparent from the face of the
+complaint' that the claim is time-barred." See generally, La Grasta |. First Union
+Securities, Inc., 358 F.3d 840, 845-846 (11" Cir. 2004).
+Count I is barred by the applicable statute of limitations.
+As to Count I, which is plead pursuant to state law, it is well settled that this Court
+is to apply Florida law.
+Erie R.Co. | Tompkins, 58 S.Ct. 817 (1938). Pursuant to
+Florida law, the statute of limitations for assault and battery is four years, §95.11(3)(o).,
+Fla. Stat. §95.11(3)(o), Fla. Stat., provides -
+Actions other than for recovery of real property shall be commenced as
+follows:
+(3) Within four years.—
+(o) An action for assault, battery, false arrest, malicious prosecution,
+malicious interference, false imprisonment, or any other intentional tort,
+except as provided in subsections (4), (5), and (7).
+In her Complaint, Plaintiff alleges in relevant part that -
+9. ... In or about 2001,
+Doe, then approximately 16 years old, fell
+into Epstein's trap and became one of his victims.
+According to the allegations of the Complaint,
+Doe had one encounter with
+Defendant at his Palm Beach mansion in or about 2001 when
+was approximately
+
+
+Doe No. 8 . Epstein
+16 years old. See Complaint, 913, endnote 1 hereto.' Based on the allegations of the
+Complaint, it has been at least 8 years since the alleged conduct by EPSTEIN, well past
+the four year statute of limitations, thus requiring dismissal of Count I. Based on the
+allegations, Plaintiff is now at least 24 years old.
+Subsections (4) and (5) referenced in §95.11(3)(o) are not applicable. Plaintiff
+may attempt to argue that subsection (7) of §95.11, Fla. Stat. applies. See endnote 2
+hereto for statutory text of subsection (7), including statutes referenced therein?
+However, a review of Plaintiff's allegations in Count I establish that Plaintiff is attempting
+to assert a cause of action based on the elements of Florida's common law assault and
+battery to which a four year statute of limitation applies. (Compare Count II, 124,
+wherein Plaintiff tracks the language §39.01(2), Fla. Stat. (2001), pertaining to "abuse.").
+Pursuant to Florida law, although the term "assault and battery" is most
+commonly referred to as if it were a legal unit, or a single concept, "assault and battery
+are separate and distinct legal concepts, assault being the beginning of an act which, if
+consummated, constitutes battery." ЗA Fla.Jur.2d Assault §1. An assault and battery
+are intentional acts. See generally, Spivey |. Battaglia, 258 So.2d 815 (Fla. 1972); and
+Travelers Indem. Co. |. PCR, Inc., 889 So.2d 779 (Fla. 2004).
+On the face of the Complaint, the applicable four year statute of limitations has
+expired, and accordingly, Count I is barred an required to be dismissed.
+Count III - 18
+. $2255
+
+
+Doe No. 8|. Epstein
+Page 4
+As to the applicable statute of limitations for Count Ill which is brought pursuant to
+18
+§2255, §2255(b), (both the 2001 version, which Defendant asserts is the
+applicable statute, and the amended version, effective July 27, 2006), provides:
+(b) Statute of limitations.—Any action commenced under this section
+shall be barred unless the complaint is filed within six years after the right
+of action first accrues or in the case of a person under a legal disability,
+not later than three years after the disability.
+As noted above, according to the allegations of the Complaint,
+encounter with Defendant at his Palm Beach mansion in or about 2001 when
+Doe had one
+was
+approximately 16 years old. See Complaint, 113, endnote 1 hereto. Based on the
+allegations of the Complaint, it has been at least 8 years since the alleged conduct by
+EPSTEIN, well past the six year statute of limitations, thus requiring dismissal of Count
+Ill. Based on the allegations, Plaintiff is now at least 24 years old, well pass the age of
+majority. (The age of majority under both federal and state law is 18 years old. See 18
+• §2256(1), defining a "minor" as "any person under the age of eighteen years;"
+and §1.01, Definitions, Fla. Stat., defining "minor" to include "any person who has not
+attained the age of 18 years."). Thus, on the face of the Complaint, Count Ill is timed
+barred and required to be dismissed.
+Conclusion
+Accordingly, Counts I and Ill of Plaintiff's Complaint are subject to dismissal. On
+the face of the Complaint, the causes of action which Plaintiff attempts to allege are
+barred by the applicable statute of limitations of 4 and 6 years, respectively.
+WHEREFORE, Defendant requests that this Court dismiss Counts 1 and Ill of
+Plaintiff's Complaint with prejudice.
+
+
+Doe No. 8 | Epstein
+Page 5
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+_day of.
+, 2009:
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ahorowitz@hermanlaw.com
+Irivera@hermanlaw.com
+Counsel for Plaintiff
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Doe #8
+Respectfully submitted,
+& COLEMAN, LLP
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+(561) 842-2820
+By: Robert D. Critton, Jr.
+Florida Bar #224162
+Michael J. Pike
+Florida Bar #617296
+Counsel for Defendant Jeffrey Epstein
+rcrit@bclclaw.com
+mpike@bclclaw.com
+'Complaint, 113 alleges in relevant part -
+... Doe was recruited by another girl, who told her that she could make some
+money, but did not tell her what was involved. At all relevant times, the girl who
+recruited
+Doe was acting on behalf of and as an agent for Epstein.
+was
+
+
+Doe No. 8 . Epstein
+Page 6
+contacted by this girl by telephone.
+was then picked up and brought to
+Epstein's mansion in Palm Beach. Once there, she was lead up a flight of stairs to
+the room with the massage table. Epstein came into the room and directed
+to remove her clothes and give him a massage.
+was frightened and felt
+trapped. As directed by Epstein, |
+removed her clothes. Epstein then during
+the massage touched
+on her breasts and vagina, and he grabbed her hand
+and placed it on his penis. Epstein masturbated himself during the massage.
+Epstein then left money for
+2 §95.11(7), Fla. Stat. -
+(7) For intentional torts based on abuse.--An action founded on alleged abuse,
+as defined in s. 39.01, s. 415.102, or s. 984.03, or incest, as defined in s. 826.04,
+may be commenced at any time within 7 years after the age of majority, or within 4
+years after the injured person leaves the dependency of the abuser, or within 4
+years from the time of discovery by the injured party of both the injury and the
+causal relationship between the injury and the abuse, whichever occurs later.
+§39.01(2), Fla. Stat. (2001) -
+(2) "Abuse" means any willful act or threatened act that results in any physical,
+mental, or sexual injury or harm that causes or is likely to cause the child's
+physical, mental, or emotional health to be significantly impaired. Abuse of a child
+includes acts or omissions. Corporal discipline of a child by a parent or legal
+custodian for disciplinary purposes does not in itself constitute abuse when it does
+not result in harm to the child.
+§415.102(1), Fla. Stat. (2001) -
+(1) "Abuse" means any willful act or threatened act that causes or is likely to cause
+significant impairment to a vulnerable adult's physical, mental, or emotional
+health. Abuse includes acts and omissions.
+§984.03 (2), Fla. Stat. (2001) -
+"Abuse" means any willful act that results in any physical, mental, or sexual injury
+that causes or is likely to cause the child's physical, mental, or emotional health to
+be significantly impaired. Corporal discipline of a child by a parent or guardian for
+disciplinary purposes does not in itself constitute abuse when it does not result in
+harm to the child as defined in s. 39.01.
+
+
+505-9312200
+Herman &Mermelsteln, P
+02:33:18 p.m.
+01-06-2009
+CASE NO.: 09-CV-80802-Marra-Johnson
+DOE NO. 8,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+May 28, 2009
+COMPLAINT
+Plaintiff, Jane Doe No. 8 ("Jane" or '
+Doe"), brings this Complaint against Jeffrey
+Epstein, as follows:
+Parties, Jurisdiction and Venue
+Jane Doe No. 8 ("Jane Do"") is a citizen and resident of the State of Florida, and is
+sui juris.
+2.
+minor.
+This Complaint is brought under a fictitious name to protect the identity of the
+Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a
+Defendant Jeffrey Epstein is a citizen and resident of the State of New York, and
+presently serving a prison sentence in Palm Beach County, Florida for, inter alia, solicitation of
+prostitution and solicitation of minors to engage in prostitution..
+4.
+This is an action for damages in excess of $50 million.
+This Court has jurisdiction of this action and the claims set forth herein pursuant to 28
+I. §1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs;
+MERMELSTEIN & HOrOWITZ, P. A.
+- 1-
+1017
+
+
+02:33:35 p.m.
+01-06-2009
+5/8
+and (il) is between citizens of different states.
+6.
+Additionally, this Court has jurisdiction pursuant to 28|
+. §1331 because
+Plaintiff alleges a claim under the laws of the United States. This Court has supplemental
+jurisdiction pursuant to 28. §1367(a) over all other claims set forth herein which form part of
+the same case or controversy.
+This Court has venue of this action pursuant to 28L
+. §§1391(a) and 1391(b) as a
+substantial part of the events or omissions giving rise to the claim occurred in this District.
+Factual Allegations
+8.
+At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male in his
+early 50's. Epstein is a financier and money manager with a secret clientele limited exclusively to
+billionaires. He is himself a man of tremendous wealth, power and influence. He maintains his
+principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach,
+FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach.
+Upon information and belief, Epstein has a sexual preference and obsession for
+9.
+underage minor girls. He engaged in a plan and scheme in which he gained access to primarily
+economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave
+them money. In or about 2001, Jane Doe, then approximately 16 years old, fell into Epstein's trap
+and became one of his victims.
+10.
+Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted
+girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas.
+11.
+Epstein's scheme involved the use of young girls to recruit underage girls. These
+underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation
+- 2-
+
+
+02:34:03 p.m.
+01-06-2009
+6/8
+in his Palm Beach mansion. Epstein, upon information and belief, generally sought out economically
+disadvantaged underage girls from Palm Beach County who would be enticed by the money being
+offered - generally $200 to $300 per "massage" session - and who were perceived as less likely to
+complain to authorities or have credibility if allegations of improper conduct were made.
+12. Epstein's plan and scheme reflected a particular pattern and method. The underage
+victim would be brought or directed to Epstein's mansion, where she would be led up a flight of
+stairs to a room that contained a massage table in addition to other furnishings. The girl would then
+find herself alone in the room with Epstein, who would be wearing only a towel. He would then
+remove his towel and lie naked on the massage table, and direct the girl to remove her clothes.
+Epstein would then perform one or more lewd, lascivious and sexual acts.
+13.
+Consistent with the foregoing plan and scheme,
+Doe was recruited by another
+girl, who told her that she could make some money, but did not tell her what was involved. At all
+relevant times, the girl who recruited
+Doe was acting on behalf of and as agent for Epstein.
+| was contacted by this girl by telephone.
+was then picked up and brought to Epstein's
+mansion in Palm Beach. Once there, she was led up the flight of stairs to the room with the massage
+table. Epstein came into the room and directed
+to remove her clothes and give him a massage.
+I was frightened and felt trapped. As directed by Epstein,
+| removed her clothes. Epstein
+then during the massage touched on her breasts and vagina, and he grabbed her hand and placed
+it on his penis. Epstein masturbated himself during the massage. Epstein then left money for
+14.
+As a result of this encounter with Epstein, I
+experienced confusion, shame,
+humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
+•
+- 3-
+
+
+02:35:06 p.m.
+01-06-2009
+718
+24. Epstein committed willful acts of child sexual abuse on. Doe. These acts resulted
+in mental or sexual injury that caused or were likely to cause Doe's mental or emotional health
+to be significantly impaired.
+25.
+Epstein's conduct caused severe emotional distress to
+Doe. Epstein knew or had
+reason to know that his intentional and outrageous conduct would cause emotional distress and
+damage to
+Doe, or Epstein acted with reckless disregard of the high probability of causing
+severe emotional distress to Doe.
+26.
+As a direct and proximate result of Epstein's intentional or reckless conduct, Doe
+has suffered and will continue to suffer severe mental anguish and pain, psychological and emotional
+injuries and los of enjoyment of life..
+WHEREFORE, Plaintiff ||| Doe No. 6 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this
+Court deems just and proper.
+COUNT III
+Coercion and Enticement to Sexual Activity in Violation of 18|
+1. $2422
+27.
+Plaintiff
+Doe repeats and realleges paragraphs 1 through 14 above.
+28.
+Epstein used a facility or means of interstate commerce to knowingly persuade,
+induce or entice |||| Doe, when she was under the age of 18 years, to engage in prostitution or
+sexual activity for which any person can be charged with a criminal offense.
+29. On June 30, 2008, Epstein entered a plea of guilty to violations of Florida §§ 796.07
+and 796.03, in the 15th Judicial Circuit in and for Palm Beach County (Case nos. 2008-cf-
+009381AXXXMB and 2006-cf-009454AXXXMB), for conduct involving the same plan and
+scheme as alleged herein.
+- 5-
+
+
+02:35:42 p.m. 01-06-2009
+8/8
+30.
+As to Plaintiff
+Doe, Epstein could have been charged with criminal violations of
+Florida Statute §$796.07(2) (including subsections (Д. (d), (e), (f), (g), and (h) thereof), and other
+criminal offenses including violations of Florida Statutes §$798.02 and 800.04 (including
+subsections (5), (6) and (7) thereof).
+31. Epstein's acts and conduct are in violation of 18|
+782422.
+1§2422, Plaintiff has suffered personal
+32. As aresult of Epstein's violation of 18 |
+injury, including mental, psychological and emotional damages,
+33.
+Plaintiff hired Mermelstein & Horowitz, P.A. (f/k/a Herman & Mermelstein, P.A.), in
+this matter and agreed to pay them a reasonable attorneys' fee..
+WHEREFORE, Plaintiff.
+Doe No. 6 demands judgment against Defendant Jeffrey
+Epstein for all damages available under 18 |
+§2255 (a), including without limitation, actual and
+compensatory damages, costs of suit, and attorneys' fees, and such other and further relief as this
+Court deems just and proper.
+JURY TRIAL DEMAND
+Plaintiff demands a jury trial in this action on all claims so triable.
+Dated: May 27,2009
+Respectfully submitted,
+By:_
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssmn@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiff
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: 305-931-2200
+Fax: 305-931-0877
+MERMELSTEIN & HORoWITz, P. A.
+- 6-
+
+
+-
+1
+2
+4
+5
+6
+7
+8
+11
+12
+13
+14
+15
+17
+18
+19
+20
+21
+22
+23
+24
+25
+WEST PALM BEACH DIVISION
+CASE NO. 08-80119-CIV-MARRA
+WEST PALM BEACH, FLORIDA
+DOE, et al..
+Plaintiffs,
+JUNE 12, 2009
+VB.
+JEFFREY EPSTEIN,
+Defendant.
+TRANSCRIPT OF MOTION HEARING
+BEFORE THE HONORABLE KENNETH A. MARRA,
+UNITED STATES DISTRICT JUDGE
+APPEARANCES:
+FOR THE PLAINTIPES:
+ADAM D. HOROWITZ, ESQ.
+Mermelstein & Horowitz
+18205 Biscayne Boulevard
+Miami, FL 33160
+For
+Doe
+305.931.2200
+BRADLEY J. EDWARDS, ESQ.
+Rothatein Rosenfeldt Adler
+401 East Las Olas Boulevard
+Fort Lauderdale, FL 33301
+_ Doe 3, 4, 5, 6, 7
+954.522.3456
+ISIDRO M. GARCIA, ESQ.
+Garcia Elkins Boehringer
+224 Datura Avenue
+West Palm Beach, FL 33401
+| DOE II
+561.832.8033
+RICHARD H. WILLITS, ESQ.
+2290 10th Avenue North
+Lake Worth, FL 33461
+For
+561.582.7600
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+FOR THE DEFENDANT:
+REPORTED BY:
+ROBERT I. JOSEFSBERG, ESQ.
+Podhurst Orseck Josefsberg
+25 West Flagler Street
+Miami, FL 33130
+For
+• Doe 101
+305.358.2800
+(Via telephone)
+KATHERINE W. EZELL, ESQ.
+Podhurst Orseck Josefsberg
+25 West Flagler Street
+Miami, FL 33130
+For
+| Doe 101
+305.358.2800
+ROBERT D. CRITTON, JR., ESQ.
+MICHAEL BURMAN, ESQ.
+Burman Critton, etc.
+515 North Flagler Street
+West Palm Beach, FL 33401
+561.842.2820
+JACK A. GOLDBERGER, ESQ.
+Atterbury Goldberger Weiss
+250 Australian Avenue South
+West Palm Beach, FL 33401
+561.659.8300
+* ESQ.
+Assistant U.S. Attorney
+500 East Broward Boulevard
+Fort Lauderdale, FL 33394
+For U.S.A.
+954.356.7255
+MARTIN G. WEINBERG, ESQ.
+20 Park Plaza
+Boston MA 02116
+(Via telephone)
+JAY LEFKOWITZ, ESQ.
+(Via telephone)
+617.227.3700
+LARRY HERR, RPR-RMR-FCRR-AE
+Official United States Court Reporter
+Federally Certified Realtime Reporter
+400 North Miami Avenue, Room 8N09
+• Miami, FL 33128
+305.523.5290
+
+
+3
+1
+2
+3
+4
+THE COURT:
+We are here in the various Doe vs. Epstein
+cases.
+| 2 through i
+May I have counsel state their appearances?
+MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs
+1 Doe 7.
+THE COURT: Good morning.
+MR. EDWARDS: Brad Edwards, counsel for plaintiff HI
+7
+8| Doe.
+9
+10
+THE COURT: Good morning.
+MR. GARCIA: Good morning, Your Honor. Sid Garcia for
+11
+Doe II.
+12
+13
+15
+16
+17
+THE COURT: Good morning.
+MR. WILLITS: Good morning, Your Honor. Richard
+14 Willita, here on behalf of the plaintiff ||..
+THE COURT: Good morning.
+MS. EZBLI: Good morning, Your Honor. I'm Katherine
+Ezell from Podhurst Orseck, here with Amy Adderly and Susan
+18
+Bennett, and I believe my partner, Bob Josefsberg, is going to
+appear by telephone.
+19
+20
+21
+22
+23
+24
+25
+stated their appearances? Okay.
+THE COURT: Mr. Josefsberg, are you there?
+MR. JOSEFSBERG: I am, Your Honor.
+THE COURT: Good morning.
+MR. JOSEFSBERG: Good morning.
+THE COURT: All right. Do we have all the plaintiffs
+
+
+29
+1
+as a shield against the plaintiffs that he was supposed to make
+2
+restitution for.
+And, certainly, he can take my client's depo. He's
+4
+done extensive discovery in the state court case -- very
+5
+intrusive, I might add. And we don't care, because we can win
+6
+this case with the prosecution agreement or without the
+7
+prosecution agreement.
+We are ready to go forward.
+8
+THE COURT: You're not going to assert to the United
+States Government that what he's doing in defending the case is
+10 | a violation for which he should be further prosecuted?
+11
+12
+MR. GARCIA: Absolutely not.
+THE COURT: Anyone else for the plaintiffs?
+MR. HOROWITZ: Judge, Adam Horowitz, counsel for
+13
+15
+17
+14| plaintiffs •
+I Doe 2 through 7.
+I Just wanted to address a point that I think you've
+16 articulated it. I Just want to make sure it's crystal clear,
+which is that we can't paint a broad brush for all of the
+1B
+cases.
+19
+20
+21
+22
+23
+The provision relating to MI. Epstein being unable to
+contest liability pertains only to those plaintiffs who have
+chosen as their sole remedy the federal statute. My clients,
+Doe 2 through 7, have elected to bring additional causes
+of action, and it's for that reason we were silent when you
+24
+said does anyone here find Mr. Epstein to be in breach of the
+25
+non-prosecution agreement. That provision, as we understand
+
+
+30
+2
+5
+6
+it, it doesn't relate to our clients.
+THE COURT: Okay. But, again, you're in agreement
+with everyone else so far that's spoken on behalf of a
+plaintiff that defending the case in the normal course of
+conducting discovery and filing motions would not be a breach?
+MR. HOROWITZ: Subject to your rulings, of course,
+8
+THE COURT: Thank you.
+Anyone else have anything to say from the plaintiffs?
+9
+10
+Ms. I
+I, if you would be so kind as to maybe
+11 help us out. I appreciate the fact that you're here, and I
+12 know you're not a party to these cases and under no obligation
+13
+to respond to my inquiries. But as I indicated, it would be
+14| helpful for me to understand the Government's position.
+Thank you, Your 'Honor. And we, of
+15
+16
+17
+MS.
+course, are always happy to try to help the Court as much as
+possible. But we are not a party to any of these lawsuits, and
+18
+in some ways we are at a disadvantage because we don't have
+19
+20
+access. My access is limited to what's on Pacer. So I don't •
+really know what positions Mr. Epstein may have taken either in
+21
+correspondence or in discovery responses that aren't filed in
+the case file.
+23
+24
+But your first order was really just what do you think
+25
+about a stay, and then the second order related to this hearing
+and asked a much more specifie question, which is whether we
+TOTAL AOCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
+
+
+DEDICATED TO JUSTICE & SAFETY
+LEOPOLD-KUVIN™
+July 31, 2009
+Assistant U.S. Attorney
+500 E. Broward Blvd, 7th Floor
+Ft. Lauderdale, FL 33394
+Re: B.B. | JEFFREY EPSTEIN
+OUR FILE NO.: 080303
+Dear Ms. L
+betten the .. Atomeys dice and Julie poin
+9, regarding the non-prosecution agreement
+Please advise whether or not this document will be produced.
+Sincer
+SINCERT. KUVIN
+STK/mlb
+2925 PGA Boulevard : Suite 200 m Palm Beach Gardens • Florida 33410 | 561.515.1400 « fax 561.515.1401 = leopoldkuvin.com
+CRASHWORTHINESS • MANAGED CARE ABUSE • CONSUMER CLASS ACTIONS • PERSONAL INJURY - WRONGFUL DEATH
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+August 4, 2009
+VIA ELECTRONIC MAIL
+Spencer T. Kuvin, Esq.
+Leopold~Kuvin, P.A.
+2925 PGA Boulevard
+Suite 200
+Palm Beach Gardens, FL 33410
+Re: Jeffrey Epstein/B.B. - Requested Disclosure of Non-Prosecution Agreement
+Dear Mr. Kuvin:
+Thank you for your letter regarding the disclosure of the Non-Prosecution Agreement
+signed by Jeffrey Epstein. I understand that you are asking for a copy of that Agreement in
+connection with your representation of "B.B." As you are aware, the Agreement contains a
+confidentiality provision. Based upon a lawsuit filed by some of Mr. Epstein's victims, U.S.
+District Judge Kenneth Marra has issued a Protective Order requiring the U.S. Attorney's Office
+to provide copies of the Agreement to certain individuals under certain circumstances. The
+Order states:
+If any individuals who have been identified by the USAO [U.S. Attorney's
+Office] as victims of Epstein and/or any attorney(s) for those individuals request
+the opportunity to review the Agreement, then the USAO shall produce the
+Agreement to those individuals, so long as those individuals also agree that they
+shall not disclose the Agreement or its terms to any third party absent further
+court order, following notice to and an opportunity for Epstein's counsel to be
+heard...
+(Court File No. 08-CV-80737-MARRA, DE 26, 1 (e).)
+The language "individuals who have been identified by the USAO as victims of Epstein"
+refers to a specific list of individuals who were the subject of the federal investigation. A list
+of those individuals was provided to Mr. Epstein's attorney. Your client, B.B., was not
+identified during that investigation, and, therefore was not on the list. By stating this I am not,
+in any way, denigrating any harm that your client may have suffered. I am simply stating that,
+who was positively identified, such that she would have been the subject of charges within a
+
+
+SPENCER T. KUVIN, ESQ.
+AUGUST 4, 2009
+PAGE 2
+possible federal indictment.
+For this reason, your client is not covered by the Court's Protective Order and the
+Agreement's confidentiality provision remains intact. If you are unable to get a copy of the
+Agreement via the civil discovery process in the lawsuit that you have filed against Mr. Epstein,
+please ask his counsel if they will consent to my production of the Agreement to you and I will send
+a copy to you.
+By:
+Sincerely,
+Jeffrey H. Sloman
+Acting United States Attorney
+o/Q. Marie Villafaña
+A.
+Assistant U.S. Attorney
+Cc:
+
+
+Roy BLACK
+LARRY A. STUMPF
+MARIA NEVRA
+JACKIE PERCZEK
+MARK A.J. SHAPIRO
+JARED
+BLACK
+SREBNICK
+KORNSPAN
+STUMPF
+JESSICA FONSECA-NADER
+KATHLEEN P. PHILLIPS
+MATTHEW P. O'BRIEN
+JENIPER J. SOULKIAS
+E-Mail: |
+September 1, 2009
+1, Esq.
+Assistant U.S. Attorney
+United States Attorney's Office
+99 N.E. 4** Street
+Miami, Florida 33132
+RE:
+Jeffrey Epstein
+Dear Jeff:
+Once again I need to send you a note about Jeffrey Epstein, mainly to keep
+you in the loop so we don't inadvertently violate any provision of his agreement
+with your office. As I am sure you are aware, Mr. Epstein has finished the
+incarceration portion of his sentence and is now serving the one year of
+prosecution green and fed by let tite tate pread the for the the hom
+District of Florida.
+Mr. Epstein is in compliance with all terms of his community control and
+is applying for transfer of his supervision from the State of Florida to his primary
+residence, the Virgin Islands. This transfer is being requested through the
+Intrastate Compact for Transfer of Adult Supervision (ICAOS). The ICAOS is the
+mechanism for which transfers of probation and community control are
+effectuated. The process requires the offender to seek the approval of the sending
+state (in this case Florida) and, if they agree, the receiving state (in this case the
+United States Virgin Islands) and the United States Virgin Islands after
+investigation has pre-approved the transfer under the same exact conditions of
+supervision as imposed in Mr. Epstein's community control sentence in the State
+of Florida.
+Even though Mr. Epstein is requesting the transfer he is still at the home
+201 S. Biscayne Boulevard, Suite 1300 - Miami, Florida 3313l - Phone: 305-371-6421 - Fax: 305-358-2006 - www.RoyBlack.com
+
+
+,, Esq.
+September 1, 2009
+in Palm Beach following the rules of state community control. As Mr. Epstein's
+lawyers, we believe that his request to administratively transfer his community
+control is in full compliance with both his state plea agreement and the nonprosecution agreement with the United States Attorney's Office. Nonetheless we
+have taken to heart your previous suggestion of erring on the side of caution and
+thus we are advising you of this request
+I am happy to discuss this with you at any time. I did not want to set an
+appointment to see you on this issue since I imagine you have more pressing
+matters to deal with than a transfer of a state community control matter.
+RB/wg
+
+
+500 S. Australian Ave, Ste 400
+West Palm Beach, FL. 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+September 18, 2009
+DELIVERY BY ELECTRONIC MAIL
+Roy Black, Esq.
+Black Srebnick Kornspan & Stumpf P.A.
+201 S. Biscayne Blvd, Suite 1300
+Miami, FL 33131
+Re: Jeffrey Epstein
+Dear Roy:
+I write in response to your letter to Mr. Sloman regarding the transfer of supervision
+of Mr. Epstein's community control to the Virgin Islands. I requested from Mr. Goldberger
+a copy of the documentation that Mr. Epstein submitted in support of his request and a copy
+of the interstate compact that you had mentioned. I have not received these documents.
+Rather than wait any longer, I am advising you of our Office's preliminary concerns. The
+Office may have additional concerns upon receipt of the requested items.
+The Non-Prosecution Agreement called for Mr. Epstein to serve eighteen months in
+county jail followed by twelve months of community control. Mr. Epstein's eighteen-month
+jail term was reduced to slightly more than twelve months based upon Mr. Epstein's "work
+release" of more than twelve hours per day, seven days per week. Mr. Epstein has been on
+community control for less than two months and he is already asking that he be allowed to
+transfer his supervision. The request comes on the heels of an instance where Mr. Epstein
+was found by the Palm Beach Police Department walking on the beach. I understand that
+he told the police that he was "walking to work," despite the fact that his "office" was more
+than eight miles away, and the beach where he was found was not en route from his
+residence to his workplace.
+Throughout the negotiation of the NPA, representations were repeatedly made by you
+and your colleagues that Mr. Epstein would serve his complete sentence, including
+community control, in Palm Beach County. During his change of plea and sentencing, Mr.
+
+
+RoY BLACK, ESQ.
+SEPTEMBER 18, 2009
+
+Epstein told the Court that he intended to remain in Palm Beach County during his period of
+community control - a fact that was important to Judge Pucillo in making her decision
+whether or not to accept the plea agreement. Mr. Epstein's presence in Palm Beach County
+was important to the Court, our Office, and, presumably, the State Attorney's Office, because
+it allowed all of these entities to monitor Mr. Epstein's performance of his obligations.
+Relocating to the Virgin Islands, where Mr. Epstein lives on a private island without any
+independent law enforcement presence, would eliminate that ability.
+The Office's ability to determine whether Mr. Epstein has breached the NPA and to
+file charges against him when/if he breaches that Agreement was a key piece of consideration
+for the decision to enter that Agreement. Another key piece was the ability of victims to
+pursue claims against Mr. Epstein under 18
+• § 2255.
+Your September 1, 2009 letter to Mr. Sloman, in essence, asked whether it would be
+the Office's position that Mr. Epstein's move to his private island would violate the terms
+of the NPA. For the reasons stated above, even upon our preliminary review, it is the
+position of the Office that the transfer of community control would frustrate the purpose of
+the agreement and thereby violate its terms. No final decision has been made, of course,
+because Mr. Epstein has not yet moved. However, if Mr. Epstein elects to go forward with
+the transfer of community control with the knowledge of the Office's objection, that will be
+considered, along with all of the previous violations by Mr. Epstein, as set forth in my letters
+of June 15 and July 7, 2009, in determining the Office's final course of action.
+I look forward to receiving the materials requested from Mr. Goldberger.
+Sincerely,
+Jeffrey H. Sloman
+Acting United States Attorney
+By: A.
+A.
+Assistant United States Attorney
+cC:
+, Chief, Northern Division
+
+
+DEDICATED TO
+LEOPOLD-KUVIN.
+January 4, 2010
+Assistant U.S. Attorney
+500 E. Broward Blvd, 7th Floor
+Ft. Lauderdale, FL. 33394
+Re:
+B.B. _. JEFFREY EPSTEIN
+OUR FILE NO.: 080303
+Dear Ms.
+After taking the deposition of Police Chief, Michael Reiter, it came to our attention that
+apparently a computer which was initially seized during the search warrant conducted on Mr.
+Epstein's home was returned by the FBI to a private investigator employed by Mr. Epstein. We
+would like to determine who this computer was returned to, and when it was returned. It would
+assist us greatly if you could check your records to determine when, and if, this was ever done.
+Additionally, according to the sworn testimony of Chief Reiter, his department was provided
+with a letter containing a list of potential victims of Mr. Epstein. This letter contained language
+pursuant to a previously unknown Federal Statute which apparently directed him to destroy the
+letter after reading it. We hereby request that your office advise what Statute or Code that letter
+was referring to. Finally, we would like to schedule the depositions of FBI Special Agents
+Nesbitt Kirkendall, Junior Ortiz and Mr, Solomon. Please let me know who we need to direct
+our subpoenas to in order to schedule these depositions.
+I appreciate your immediate attention to this matter. Should you have any additional questions
+about these issues, please do not hesitate to contact me at once.
+STK:mlb
+2925 PGA Boulavard
+• Sulte 200 : Palm Beach Gardens : Florida 33410 561.515.1400 fax 561.515.1401 leopoldkuvin.com
+CRASHWORTHINESS • MANAGED CARE ABUSE • CONSUMER CLASS ACTIONS • PERSONAL INJURY - WRONGFUL DEATH
+
+
+ROY BLACK
+ARRY A. STUMPF
+MARIA NEYRA
+JACKIE PERCZEK
+MARK A.J. SHAPIRO
+JARED
+BLACK
+SREBNICK
+KORNSPAN
+& STUMPF
+JESSICA FONSECA-NADER
+KATHLEEN P. PHILLIPS
+AARON ANTHON
+MARCOS BEATON, JR.
+MATTHEW P. O'BRIEN
+JENIFER J. SOULIKIAS
+E-Mail: RBlack@RoyBlack.com
+January 20, 2010
+Assistant United States Attorney
+United States Attorney's Office
+500 South Australian Avenue
+Suite 400
+West Palm Beach, Florida 33401
+RE: Jeffrey Epstein
+Dear
+We are now facing a difficult issue about the attorney's fees in the civil cases
+brought against. Mr. Epstein related to your prior criminal investigation. I
+broached this subject with you on the phone a couple of weeks ago, but I could
+see our discussion was not fruitful at that time. Since we could not come to any
+agreement on how to handle this, we must proceed ahead based on our
+understanding of the non-prosecution agreement.
+Mr. Epstein has paid the attorney representative $526,000 and accepts his
+obligation under the NPA to pay additional reasonable legal fees that precede
+litigation claims under 97C of the Addendum. However we believe that the
+request by the attorney representative for over $1.5M additional fees is both
+unreasonable and outside the Addendum's criteria for payment.
+Litigation may ensue since we have been unable to resolve these matters
+through an agreement. We never contemplated that the legal fee agreement would
+result in a bill for $2. 1M when the Addendum was entered. We understand you
+and Jay had different views on whether an attorney representative could both sue
+Epstein for some clients and remain as counsel to settle other cases. We believe
+that the attorney representative could either settle the cases and be paid hourly
+or litigate and be paid out of the judgment, but not both. The language of the NPA
+is in need of legal construction regarding whether Epstein's obligations end when
+201 S. Biscayne Boulevard, Suite 1300 - Miami, Florida 3313l • Phone: 305-371-6421 • Fax: 305-358-2006 - www.RoyBlack.com
+
+
+January 20, 2010
+the attorney representative brings a lawsuit for any of his clients - a matter that
+a court should settle free from any consideration that initiating litigation to resolve
+this outstanding issue would be perceived as a breach.
+Just to be sure, Mr. Epstein will pay whatever fees a court determines are
+owed and we only want assurance that litigating the legal and factual issues over
+such liability will be consistent with and not violate the NPA. We don't think it is
+the government's position that Epstein must simply pay any bill he receives,
+regardless of the amount and type of work done, particularly one for $2. 1M. So we
+have no alternative but to go to court to resolve this issue. We are sending you
+this letter because the attorney representative is using the threat of a breach as
+leverage to get his fees. I don't believe the government's power to indict and
+incarcerate should be used to assist a private lawyer in collecting an exorbitant
+legal fee. Thus we are putting you on notice, and asking that if you disagree with
+our legal opinion that a suit is not in conflict with the NPA, to tell us without
+delay.
+Cordially yours,
+Martin G. Weinberg, Esq.
+Robert D. Critton, Jr.
+Roy Black,
+By:
+Vroe
+MW:RC:RB/wg
+
+
+To:
+Cc:
+Subject:
+-(USAFLS)
+Roy BLACK L
+Thursday, January 21, 2010 2:59 PM
+1. (USAFLS)
+owlmgw@worldnet.att.net
+Yesterday's Letter
+: On second thought my letter yesterday went too far in one respect. So that there is no misunderstanding of
+the last paragraph of yesterday's letter, our concern is not that the attorney representative in fact has used the threat of
+a breach as leverage to get his fees, only that there exists the legitimate concern that the agreement could be so used
+and the reality that any concern about such use significantly and unfairly burdens Mr Epstein's right to resort to the
+courts to resolve outstanding legal issues regarding the criteria for payment and the amount of payment owed. I hope
+this clarifies our concern in this one area. Thanks Roy
+
+
+500 S. Australian Ave, Ste 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+February 11, 2010
+DELIVERY BY ELECTRONIC MAIL
+Roy Black, Esq.
+Black Srebnick Kornspan & Stumpf P.A.
+201 S. Biscayne Blvd, Suite 1300
+Miami, FL 33131
+Re: Jeffrey Epstein
+Dear Mr. Black:
+Thank you for meeting with our Office last week. During our discussion, you and your
+colleagues raised three issues: (1) whether our Office would consider it a breach of the Non-
+Prosecution Agreement for Mr. Epstein to file suit against the victim's attorney-representative
+relating to the amount of attorney's fees; (2) whether our Office would consider it a breach of the
+Non-Prosecution Agreement for Mr. Epstein to argue that he has no liability for claims raised
+exclusively under 18|
+- § 2255 as to any of the victims on the identified list; and (3) whether
+our Office would have any objection to Mr. Epstein applying for early termination of his community
+control.
+As we have told you before, our Office cannot give advisory opinions as to what will and will
+not be a breach of the Non-Prosecution Agreement. Furthermore, as to the first item, your colleagues
+admitted that efforts to reach an agreement with Robert Josefsberg regarding the amount of fees
+owed have not been completed. Similarly, as to the second item, your colleagues admitted that there
+are no currently pending cases arising exclusively under 18 |
+1. § 2255 as to any of the victims
+on the identified list. Given that these matters may never arise and, if they do arise, there will be
+innumerable legal and factual issues that have not been shared with our Office, we again decline to
+provide any advisory opinions. As discussed during the meeting, the purpose of having the parties
+and a Special Master involved at the beginning of the process in the selection of the attorneyrepresentative was to avoid dealing with this issue at the end of the process. As with all matters
+related to the Agreement, we expect that Mr. Epstein will act in good faith and comply with the letter
+and spirit of the NPA.
+As to the third item, we have reviewed your letter to Mr. Sloman of February 8, 2010. While
+Mr. Acosta did state in his letter of December 19, 2007, that he did not believe that the Office was
+
+
+ROY BLACK, ESQ.
+FEBRUARY 11, 2010
+
+obligated to notify the victims identified through the federal investigation of proceedings occurring
+in state court, the U.S. Department of Justice's position may have changed in the interim in light of
+internal guidance regarding prosecutors' obligations pursuant to 18
+• § 3771, 42|
+10607, and Fed. R. Crim. P. 60 (effective December 1, 2008).
+In light of Mr. Acosta's prior statements to Mr. Epstein's counsel that Mr. Epstein would be
+eligible for any benefit available to other similarly-situated state defendants, the Office agrees that
+Mir. Epstein may apply for early termination or modification of community control in accordance
+with Fl. Stat. §$ 948.05 and 948.10(4), assuming that Mr. Epstein has completed "the sanctions
+imposed in the community control plan." The Office takes no position regarding such an
+application; it is entirely within the discretion of the State Attorney's Office and the Palm Beach
+County Circuit Court Judge as to whether it is in "the best interests of justice and the welfare of
+society" to allow Mr. Epstein to terminate prematurely his community control. Mr. Epstein and his
+counsel may not make a representation to the State Attorney's Office, the Court, or any victim that
+the U.S. Attorney's Office agrees with, joins in, or does not oppose such a motion. In light of prior
+erroneous statements in court filings, we respectfully request that a copy of any court filing be
+provided to our office.
+If such a motion is made, in accordance with your proposal, the U.S. Attorney's Office will
+notify the federal victims that the application was filed and, if a hearing is scheduled, the date, time,
+and location of such hearing. The communication will consist merely of a notification and will
+neither encourage nor discourage attendance or submission of materials related to the application.
+Sincerely,
+Jeffrey H. Sloman
+By:
+s/A.
+A.
+Villafaña
+Assistant United States Attorney
+cc:
+Chief, Northern Division
+
+
+ROY BLACK
+LARRY A. STUMPF
+MARIA NEYRA
+JACKIE PERCZEK
+MARK A.J. SHAPIRO
+JARED |
+BLACK
+SREBNICK
+KORNSPAN
+& STUMPF
+=PA.=
+JESSICA FONSECA-NADER
+KATHLEEN P. PHILLIPS
+AARON ANTHON
+MARCOS BEATON, JR.
+MATTHEW P. O'BRIEN
+JENIFER J. SOUMKIAS
+NOAH FOX
+E-Mail: RBlack@RoyBlack.com
+February 18, 2010
+1, Esq.
+Assistant United States Attorney
+99 N.E. 4' Street
+Miami, FL 33132
+RE: Jeffrey Epstein
+Dear Ms
+Thank you for your letter of February 11, 2010. We write to update you
+about ongoing efforts to reach an agreement with Robert Josefsberg regarding the
+amount of fees and costs properly owed to him by Mr. Epstein pursuant to the
+NPA.
+On February 16, 2010 Mr. Epstein's principal civil counsel Bob Critton
+advised Mr. Josefsberg in writing that he and Mr. Epstein would meet with Mr.
+Josefsberg on two occasions between now and March 1, 2010 to review Mr.
+Josefsberg's outstanding bills on a line-by-line basis and attempt to reach a nonadversarial resolution of all outstanding fee issues. Mr. Critton also transmitted
+to Mr. Josefsberg an Agreement for Special Master to Determine Amount of
+Attorneys' Fees and Costs ("Special Master Agreement"), signed by Mr. Epstein,
+containing terms and conditions previously agreed to by Mr. Josefsberg, which
+would mandate binding mediation before a neutral third party in the event the
+proposed settlement discussions did not resolve all outstanding issues in an
+expeditious manner.
+We want to assure you that Mr. Epstein fully intends to fulfill his obligations
+under the NPA. We regret that issues remain unresolved regarding whether all of
+the fees and costs being sought by the attorney representative - which now total
+$1,947,000 exclusive of the $526,466 already paid by Mr. Epstein - meet the
+criteria set forth by the NPA. We assure you that both Mr. Epstein's prior civil
+counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the NPA
+language, and Mr. Critton, each strongly believe that significant amounts of the
+fees and costs billed by Mr. Josefsberg are outside the scope of Mr. Epstein's fee-
+201 S. Biscayne Boulevard, Suite 1300 - Miami, Florida 3313I - Phone: 305-371-6421 • Fax: 305-358-2006 • www.RoyBlack.com
+
+
+,, Esq.
+February 18, 2010
+related payment obligations under the NPA. We hope that the fee-related issues
+can be resolved by further settlement discussions or by relying on the Special
+Master Agreement signed Tuesday February 16, 2010 by Mr. Epstein. Mr. Epstein
+and his counsel believe that these options are consistent with the NPA, are good
+faith alternatives to contested litigation, and are reasonable given the unexpected
+magnitude of the bills and their inclusion of charges for legal work that was
+clearly related to the preparation of litigation and thus outside Par 7C of the
+Addendum as well as for extensive work performed by attorneys from outside Mr.
+Josefsberg's law firm.
+Mr. Josefsberg previously advocated for settling outstanding issues through
+a Special Master Agreement nearly identical to the one executed Tuesday by Mr.
+Epstein. In fact, Mr. Josefsberg and Mr. Epstein had each agreed in the past to
+a specific Master as a third-party neutral to conduct proceedings to resolve the fee
+issues. However, the selected Master withdrew.
+We hope that the Special Master Agreement will provide a basis for a prompt
+resolution of any issue not resolved by the parties through further discussions.
+Respectfully submitted,
+MARTIN WEINBERG, ESQ.
+ROY
+LACK, ESQ.
+/ wg
+cc:
+1, Esq.
+Robert Senior, Esq.
+
+
+Rox BLACk
+LARRY A. STUMPE
+MARIA NEYRA
+JACKIE PERCZEK
+MARK A.J. SHAPIRO
+JARED |
+BLACK
+SREBNICK
+KORNSPAN
+& STUMPF
+=PA.=
+JESSICA FONSECA-NADER
+KATHLEEN P. PHILLIPS
+MARCOS BEATON, JR.
+MATTHEW P. O'BRIEN
+JENIFER J. SOULIKIAS
+E-Mail: RBlack@RoyBlack.com
+March 5, 2010
+99 N.E. 4" Street
+Miami, FL 33132
+_, Esq.
+Assistant United States Attorney
+99 N.E. 4' Street
+Miami, FL 33132
+Assistant United States Attorney
+99 N.E. 4' Street
+Miami, FL 33132
+RE: Jeffrey Epstein
+Dear Counsel:
+We write this letter to renew our request that the United States Attorney's
+Office provide us, as Mr. Epstein's counsel in the federal NPA matter, with clarity
+as to what legal issues we can advise his civil counsel can be litigated without
+obligations under paragraph of the PA: I eter from dich counsel Robert
+Critton is attached. On February 11, 2010, you advised us that for reasons
+including the fact that at the time there were "no currently pending cases arising
+exclusively under 18 USC §2255 as to any of the victims on the identified list" you
+would "decline to provide any advisory opinions" in response to our requests
+during our meeting of February 3.
+Since February 11, 2010, a lawsuit has been filed by the attorney
+representative on behalf of
+Doe 103. Her identity is known by us and she
+is on the "identified list." Her lawsuit raises only §2255 claims. Although she has
+not waived her right to file any other state or federal or common law claim so as
+to fit squarely within the letter of 98 of the NPA, she does, in her lawsuit, quote
+18 and claim rights as a beneficiary of that agreement, see Case No. 10-80309
+(S.D. Fla.), Complaint, 1125-26, thus requiring that civil counsel consider
+201 S. Biscayne Boulevard, Suite I300 • Miami. Florida 33131 • Phone: 305-371-6421 • Fax: 305-358-2006 • www.RoyBlack.com
+
+
+March 5, 2010
+responsive motions that relate to the scope of waiver of liability that is
+memorialized in the NPA. Additionally, Mr. Epstein and his counsel have
+scheduled a meeting to review the attorney representatives outstanding bills but
+have been told that if there is no settlement agreement, then the attorney
+representative intends to initiate litigation rather than adopt the Special Master
+procedure that we referred to in our February 18, 2010 correspondence to you.
+It is the intention of Mr. Epstein's civil counsel to not contest that at least
+one predicate §2255 offense was committed believing that such a "waiver"
+satisfies, facially, Mr. Epstein's obligations under the NPA, see attached letter from
+Mr. Critton. As we said during our meeting on February 3, we have an obligation
+to provide advice to Mr. Epstein's civil counsel, Robert Critton, whether his raising
+of certain legal challenges to the Complaint will be perceived as being in conflict
+with Mr. Epstein's NPA obligations. These issues include:
+1.
+Whether Mr. Epstein can contend that any waiver of liability is
+satisfied by his not contesting the occurrence of a single rather than
+multiple predicate offenses as to each claimant? This issue is pertinent
+since
+Doe 103 has brought six separate claims for §2255 relief each
+implicating the statutory minimum damage recovery. Amongst the
+predicates alleged include a predicate offense allegation of a statute that
+was not even enacted until 2006, i.e., over a year after
+Doe 103 turned
+18, and substantially after her last alleged contact with Mr. Epstein. Any
+requirement that Mr. Epstein not contest liability for that predicate would
+violate the ex post facto laws. Two other predicates are not supported by
+trustworthy evidence. It is our contention that Mr. Epstein satisfies his
+NPA obligations by not contesting that he committed at least one predicate
+offense. Prior correspondence from your office is not inconsistent with our
+belief that the required scope of waiver was to a predicate offense in the
+singular, see, e.g., Mr.Acosta's letter to Ken Starr, December 4, 2007, p.2
+("were Mr. Epstein convicted at trial, the plaintiff-victims would not have to
+show that a violation of an enumeration section of Title 18 took place")?
+Whether Mr. Epstein can contend that the statutory provisions of
+§2255 in effect at the time of the offense (e.g., 2004-5) govern the minimum
+statutory damage amount ($50,000 rather than $150,000) under ex post
+facto laws, see United States |. Scheidt, 2010 W.L. 144837 (E.D. Cal., 2010)
+(indicating that the statute in effect at the time of the violation governs the
+minimum damage remedy)?
+
+
+March 5, 2010
+3.
+Whether personal injury is a separate §2255 element from the
+predicate offense element so that Mr. Epstein could "agree" to the occurrence
+of a predicate pursuant to his NPA obligations but still contest that the
+plaintiff was injured, see United States |. Scheidt, supra (finding each to be
+a separate element) and the letter from Mr. Acosta to Mr. Starr, supra
+December 4, 2007 letter at p. 2 which agrees that Mr. Epstein can contest the
+injury element under the NPA ("were Mr. Epstein convicted at trial, the
+plaintiff-victims in a subsequent Section 2255 suit would still have had some
+burden to prove that they were 'victims")?
+4.
+Whether the 6-year civil statute of limitations contained in 18 USC
+§2255 could be raised as an affirmative defense if the facts or allegations
+demonstrate a greater than 6-year period between the accruing of the cause
+of action and the complaint, i.e., whether Mr. Epstein can "agree" (for civil
+§2255 purposes) to the occurrence of a predicate offense and still claim it
+occurred greater than 6 years before the filing of a Complaint?
+5. Whether Mr. Epstein can contest certain claims that are unsupported
+by trustworthy proof (or in certain cases by any proof at all) so long as he has
+waives his right to deny the occurrence of at least one predicate offense as
+required by 18 of the NPA?
+Whether damages are to be awarded based on injury to a plaintiff or
+based on the number of separately proven claims, see United States |
+Baker, 2009 WL 4572785 (E.D.Tex., 2009) where the Court rejected the
+contention that damages were to be allocated per violation?
+We are not asking the government to adopt our legal positions; instead we
+are simply seeking the right for Mr. Epstein's civil counsel to raise principled good
+faith legal issues without fear of the irreparable collateral consequences that
+would result from any notice by you that you believed that a litigation position
+adopted by Mr. Epstein's civil counsel constituted a willful breach. Paragraph 8
+and its waiver provisions are not clear (or as stated by Mr. Acosta are "far from
+simple," see Mr. Acosta letter to Ms. Sanchez, December 19, 2007). Paragraph 8
+does not "speak for itself." That the provisions of 18 are "far from simple" is
+illustrated in the construction of those paragraphs by Mr. Epstein's prior counsel,
+Jay Lefkowitz, who repeatedly advised Mr. Acosta, by letter, that he considered the
+waiver of liability to be limited to those who agreed to damages, and was
+inapplicable to those who chose to litigate, see, e.g., letters from Jay Lefkowitz to
+
+
+1, Esq.
+March 5, 2010
+Page 4
+Alex Acosta October 10, 2007, p.4 and November 29, 2007, p.2. Again, we are
+only requesting that you inform us whether in the event Mr. Epstein did not
+contest the commission of at least one predicate - the statutory precondition for
+the filing of a $2255 lawsuit - you would nevertheless believe that the raising of
+any of the legal arguments outlined above would violate the NPA
+/ wg
+Respectfully submitted,
+MARTIN WEINBERG, ESQ.
+ROY BLACK, ESQ.
+By
+Kay
+
+
+BEHBURMAN COTEDANUS
+J. MICHAEL BURMAN, PA.12
+GRECORY W. COLEMAN, P.A.
+ROBERT D. CRITTON, JR, PA. '
+BERNARD A. LEBEDEKER
+MARK T. LUTTIER, P.A.
+MICHAEL J. PIKE
+DAVID A. YAREMA
+'FLORIDA BOARD CERTIFIED CIVIL TRIAL LAWYER
+ADMITTED TO PRACTICE IN FLORIDA AND COLORADO
+March 4, 2010
+BATY STO ES
+OFCOL BUONK
+EF-COUNM. RICCI
+Roy Black, Esq.
+Black, Srebnick, Kornspan & Ptumpf
+201 S. Biscayne Boulevard, Suite 1300
+Miami, FL 33131
+Martin G. Weinberg, Esq.
+Martin G. Weinberg, PC
+20 Park Plaza, Suite 1000
+Boston, MA 02116
+Re:
+Jeffrey Epstein
+Dear Roy and Marty:
+This letter represents my thoughts on issues concerning the NPA and my ability to
+fully defend Mr. Epstein in the civil case recently filed by Mr. Josefsberg.
+Based on a State criminal court ruling last summer, the Non-Prosecution Agreement
+("NPA") was made available to the public. With regard to the civil aspect of the NPA,
+specifically paragraphs 7 and 8 (including the Addendum), our interpretation has been
+substantially different from that of the attorney representative, Mr. Josefsberg, and other
+attorneys representing alleged victims. They have interpreted those civil portions of the
+agreement to assist them in their civil cases in a manner which we believe is inconsistent
+with both the written word and the intent of the NPA.
+Mr. Epstein has continued to fulfill his responsibilities under all aspects of the NPA.
+Mr. Josefsberg has represented or currently represents twelve individuals. Of those
+twelve individuals, eleven have resolved their claims.
+Of those eleven claims, only two
+individuals filed contested litigation,
+Doe 101 and
+Doe 102.
+Mr. Epstein and Mr. Josefsberg have attempted to resolve the issue associated with
+attorneys fees and costs. Mr. Epstein has, as you know, paid an excess of $500,000.00
+toward the claimed outstanding fees and costs. It is the belief of all attorneys who
+represent Mr. Epstein that the fees and costs incurred by the attorney representative (for
+many attorneys and consultants) are excessive and duplicative. Mr. Epstein provided Mr.
+Josefsberg a signed Special Master Agreement for resolving the fees/costs issues in
+February 2010, in substantially the same format which was agreed upon as of December
+of 2009. The only significant change was use of an out-of-state special master. We were
+advised by Mr. Josefsberg and Mr. Podhurst that they no longer agree with using that
+process.
+303 BANYAN BOULEVARD • SUITE 400 • WEST PALM BEACH, FL. 33401 • PHONE: 561-842-2820 • FAX: 561-844-6929 • MAIL@BCLCLAW.COM
+WWW.BCLCLAW.JOM
+
+
+March 4, 2010
+• Doe 103 now has been filed. While Mr. Epstein clearly recognizes his
+obligation under the NPA to waive liability to a single predicate offense, Mr. Josefsberg
+has filed an action asserting multiple counts against Mr. Epstein based on multiple
+predicate acts, including one wherein the statute was not even in effect at the time of the
+alleged violation. Mr. Josefsberg is also aware and agreed that Mr. Epstein could file a
+declaratory action related to the interpretation of the NPA. Mr. Josefsberg reserved the
+right to contest issues that might be raised in such an action.
+It is facially unfair, unjust and inconsistent with the spirit and intent of the NPA that
+Mr. Epstein be precluded from fully defending himself (except for the waiver of liability as
+to a single act) especially where no facts exist to support the claim, a statute was not in
+effect at the time of the alleged incident, etc.
+It is my understanding that you are sending a letter to the USAO.! have no
+objection to your including my letter which expresses some of my concerns with which Mr.
+Epstein is now confronted based on Mr. Josefsberg's interpretation of the NPA. While I
+am not asking the USAO to confirm Mr. Epstein and his attorneys' interpretation of the
+NPA and/or its spirit and intent, I would request that the USAO give Mr. Epstein the
+opportunity to fully defend himself, in the civil suit, except for that which is specifically
+required of him under the NPA.
+Cordially yours
+/
+RobertD. Critton, Jr.
+RDC/clz
+
+
+500 S. Australian Ave, Ste 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+April 2, 2010
+DELIVERY BY ELECTRONIC MAIL
+Roy Black, Esq.
+Black Srebnick Kornspan & Stumpf P.A.
+201 S. Biscayne Blvd, Suite 1300
+Miami, FL 33131
+Re: Jeffrey Epstein
+Dear Mr. Black:
+The Office is in receipt of your letter of March 29, 2010. We have had a series of
+correspondence, telephone calls, and meetings regarding the issue of Mr. Epstein's obligation to his
+victims. We have repeatedly stated that Mr. Epstein is expected to abide by the letter and spirit of
+the Non-Prosecution Agreement. And we have repeatedly informed you that the U.S. Attorney's
+Office does not intend to provide advisory opinions to Mr. Epstein or his attorneys regarding the
+handling of the civil suits filed against him. Yet again, you have asked us to provide such an
+advisory opinion. The request relates to Mr. Epstein's Motion to Dismiss in toto the suit filed
+against him by Jane Doe 103, whom we understand is one of the victims identified through the 2006
+through 2007 investigation that culminated in the signing of the Non-Prosecution Agreement.
+Jane Doe 103 is represented by Robert Josefsberg, the attorney-representative selected by the
+Special Master in accordance with the Non-Prosecution Agreement, and the Complaint raises claims
+exclusively under 18|
+I. § 2255. As such, Mr. Epstein has waived his right to contest liability.
+Despite this waiver, Mr. Epstein and his attorneys want the Court to dismiss the Complaint. In a
+word, yes, the Office believes that this is a breach of the Non-Prosecution Agreement.
+Sincerely,
+By:
+Jeffrey H. Sloman
+Mailalano
+Assistant United States Attorney
+
+
+ROY BLACK, ESQ.
+APRIL 2, 2010
+
+cc:
+Chief, Northern Division
+
+
+• Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 1 of 19
+Unsealed 05/09/10
+Sealed
+IN THE UNITED STATES DISTRICT COURT
+FOR THE SOUTHERN DISTRICT OF FLORIDA
+Civil Action No.
+10-80309
+DOE No. 103,
+Plaintiff,
+FILED by [B
+FEB 2 3 2010
+STEVENS OST OFF
+S.D. ot FLA - MIAMI
+JEFFREY EPSTEIN,
+Defendant.
+COMPLAINT AND DEMAND FOR JURY TRIAL
+Plaintiff,
+Doe No. 103 ("Plaintiff"), brings this Complaint against Defendant, Jeffrey
+Epstein ("Defendant"), and states as follows:
+PARTIES, JURISDICTION, AND VENUE
+1. At all times material to this cause of action, Plaintiff was a resident of Palm Beach
+County, Florida.
+2. This Complaint is brought under a fictitious name to protect the identity of
+Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse of a then
+minor.
+At all times material to this cause of action, Defendant owned a residence located
+at 358 El Brillo Way, Palm Beach, Palm Beach County, Florida.
+Defendant is presently a citizen of the United States Virgin Islands. Pursuant to
+the plea agreement entered by the Defendant in state court and the sentencing which occurred on
+June 30, 2008, Defendant is currently under community control in Palm Beach County, Florida.
+Sealed
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miaml 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+late
+
+
+• Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 2 of 19
+.:
+5.
+6.
+Defendant is an adult male born on January 20, 1953.
+This Court has jurisdiction over this action and the claims set forth herein
+pursuant to 18
+§ 2255.
+7.
+This Court has venue of this action pursuant to 28
+§ 1391(b), as a
+substantial part of the events giving rise to the claim occurred in this District.
+STATEMENT OF FACTS
+8.
+At all relevant times, Defendant was an adult male spanning the ages of 45 and 55
+years old. Defendant is known as a billionaire financier and money manager with a secret
+clientele limited exclusively to billionaires. He is a man of tremendous wealth, power, and
+influence. He owns a fleet of aircraft that includes a Gulfstream IV, a helicopter, and a Boeing
+727, as well as a fleet of motor vehicles. Until his incarceration pursuant to the plea entered and
+sentencing, which occurred on June 30, 2008, he maintained his principal place of residence in
+the largest dwelling in Manhattan, a 51,000-square-foot eight-story mansion on the Upper East
+Side. He also owns a $6.8 million mansion in Palm Beach, Florida, a $30 million 7,500-acre
+ranch in New Mexico he named "Zorro," a 70-acre private island known as Little St. James in
+the U.S. Virgin Islands, a mansion in London's Westminster neighborhood, and another
+residence in the Avenue Foch area of Paris. The allegations herein concern Defendant's conduct
+while at his lavish residence in Palm Beach and numerous other locations both nationally and
+internationally.
+9.
+Defendant has a sexual preference for underage minor girls. He engaged in a
+plan, scheme, or enterprise in which he gained access to countless vulnerable and relatively
+economically disadvantaged minor girls, and sexually assaulted, molested, and/or exploited these
+girls, and then gave them money.
+Podhurst Orseck, P.A.
+2
+25 West Flagler Street, Suite B00, Miami, F1. 33130, Miami 305.35.2800 Fax 305.358.2382 • Fort Lauderdale 95. 453.436 1
+
+
+• Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 3 of 19
+10.
+Beginning in or around 1998 through in or around September 2007, Defendant
+used his resources and his influence over vulnerable minor girls to engage in a systematic pattern
+of sexually exploitative behavior.
+11.
+Defendant's plan and scheme reflected a particular patter and method.
+Defendant coerced and enticed impressionable, vulnerable, and relatively economically less
+fortunate minor girls to participate in various acts of sexual misconduct that he committed upon
+them. Defendant's scheme involved the use of underage girls, as well as other individuals, to
+recruit underage girls. Defendant and/or an authorized agent would call and alert Defendant's
+assistants shortly before or after he arrived at his Palm Beach residence. His assistants would
+call economically disadvantaged and underage girls from West Palm Beach and surrounding
+areas who would be enticed by the money being offered and who Defendant and/or his assistants
+perceived as less likely to complain to authorities or have credibility issues if allegations of
+improper conduct were made. The then minor Plaintiff and other minor girls, some as young as
+14 years old, were transported to Defendant's Palm Beach mansion by Defendant's employees,
+agents, and/or assistants in order to provide Defendant with "massages."
+12.
+Many of the instances of illegal sexual conduct committed by Defendant were
+perpetrated with the assistance, support, and facilitation of at least three assistants who helped
+him orchestrate this child exploitation enterprise. These assistants would arrange times for
+underage girls to come to Defendant's residence, transport or cause the transportation of
+underage girls to Defendant's residence, escort the underage girls to the massage room where
+Defendant would be waiting or would enter shortly thereafter, urge the underage girls to remove
+their clothes, deliver cash from Defendant to the underage girls and/or their procurers at the
+conclusion of each "massage appointment," and assist Defendant in taking nude photographs
+Podhurst Orseck, P.A.
+3
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+:
+Entered on FLSD Docket 03/09/2010 Page 4 of 19
+.:
+and/or videos of the underage girls with and/or without their knowledge. Defendant would pay
+the procurer of each girl's "appointment" hundreds of dollars.
+13.
+Defendant designed this scheme to secure a private place in Defendant's Palm
+Beach mansion where only persons employed and invited by Defendant would be present, so as
+to reduce the chance of detection of Defendant's sexual abuse and/or exploitation, as well as to
+make it more difficult for the minor girls to flee the premises and/or to credibly report his actions
+to law enforcement or other authorities. The girls were usually transported by his employee(s),
+agent(s), and/or assistant(s) and/or by taxicab(s) and/or motor vehicle(s) paid for by Defendant,
+which also made it difficult for the girls to flee his mansion.
+Upon her initial arrival at Defendant's Palm Beach mansion, each underage
+victim would generally be introduced to one of Defendant's assistants, who would gather the
+girl's personal contact information. The minor girl would be led up a remote flight of stairs to a
+room that contained a massage table and a large shower.
+15. At times, if it was the girl's first "massage" appointment, another female would
+be in the room to "lead the way." Generally the other female would leave, or Defendant would
+dismiss her. Often, Defendant would start his massage wearing only a small towel, which
+eventually would be removed. Defendant and/or the other female would direct the girl to
+massage him, giving the minor girl specific instructions as to where and how he wanted to be
+touched, and then direct her to remove her clothing.
+. Defendant would then perform one or more
+lewd, lascivious, and sexual acts, including masturbation; fondling the minor's breasts and/or
+sexual organs; touching the minor's vulva, vagina, and/or anus with a vibrator, back massager,
+his finger(s), and/or his penis; digitally penetrating her vagina; performing intercourse, oral sex,
+and/or anal sex; and/or coercing or attempting to coerce the girl to engage in lewd acts and/or
+Podhurst Orseck, P.A.
+4
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.23B2 • Fort Lauderdale 954.463.4346
+
+
+• Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 5 of 19
+:.
+prostitution and/or enticing the then minor girl to engage in sexual acts with another female in
+Defendant's presence. The exact degree of molestation and frequency with which the sexual
+exploitations took place varied and is not yet completely known; however, Defendant committed
+such acts regularly on a daily basis and, in most instances, several times a day. In order to
+facilitate the daily exchanges of money for sexual assault and abuse, Defendant kept U.S.
+currency readily available.
+Defendant traveled out of Florida to Palm Beach for the purpose of luring
+minor girls to his mansion to sexually abuse and/or batter them. He used the telephone to contact
+these minor girls for the purpose of coercing them into acts of prostitution and to enable himself
+to commit sexual battery against them and/or acts of lewdness in their presence, and he conspired
+with others,
+including his employee(s), assistants), drivers), pilots), and/or agents), to
+facilitate these acts and to avoid police detection. Defendant's systematic pattern of sexually
+exploitative behavior described above also occurred in Defendant's other domestic and/or
+international residences, places of lodging, and/or modes of transportation.
+17.
+Consistent with the foregoing plan and scheme, Defendant used his money,
+wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff.
+A vulnerable young girl, Plaintiff was merely a seventeen year old high school student when she
+was first lured into Defendant's sexually exploitative world in or about January 2004. Plaintiff
+was recruited while at work by a co-worker, one of the minor victims Defendant paid to procure
+underage females. Plaintiff went to Defendant's Palm Beach mansion accompanied by this coworker. Upon arriving, Plaintiff was led by one of Defendant's assistants up a flight of stairs to a
+spa room with a shower and a massage table. Defendant entered this room wearing only a towel.
+Defendant suddenly removed his towel, exposing his naked body, and then lay on the massage
+Podhurst Orseck, P.A.
+5
+25 West Flagler Street, Suite 800, Miami, FL.33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+• Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 6 of 19
+table. Defendant told Plaintiff to massage his back and take off her clothing, which she refused
+to do. Defendant then began to try to touch the minor Plaintiff and/or take off her clothing.
+After Defendant's relentless pawing, she reluctantly removed some of her clothing. During this
+encounter, Defendant turned over on his back and fondled Plaintiff's breasts, despite her
+repeatedly telling him not to do so. As Plaintiff massaged Defendant, Defendant proceeded to
+masturbate until ejaculation. Defendant then paid Plaintiff two hundred dollars, and Plaintiff
+was escorted out of Defendant's mansion and left Defendant's property.
+18. A similar pattern of grooming continued, and the sexual exploitation
+progressively escalated, over the course of approximately seventeen months during which
+Defendant would often travel to Palm Beach. Prior to arriving and while in Palm Beach,
+Defendant and/or his agents) would frequently call Plaintiff at her home telephone number
+and/or other telephone numbers, arranging for encounters with her for Defendant, sometimes
+twice daily. While usually such contacts were made by his assistants, Defendant personally
+called Plaintiff repeatedly, despite being told to leave Plaintiff alone. After the first few
+encounters, Defendant coerced Plaintiff to remove all her clothing, and Defendant penetrated the
+minor Plaintiff's vagina digitally. Defendant sexually abused and/or battered and/or exploited
+Plaintiff at least a hundred times between approximately January 2004 and May 2005. Such
+exploitation included, but was not limited to, Defendant's sexual abuse and battery of Plaintiff
+with vibrator(s), back massager(s), his finger(s), and his penis. At times, Defendant manipulated
+Plaintiff to interact sexually with another female. During one encounter, Defendant penetrated
+the minor Plaintiff's vagina with his penis, all the while narrating and demonstrating his sexual
+battery of Plaintiff to another female present in the room. While some of the precise dates that
+Defendant's acts of sexual exploitation occurred are unknown to Plaintiff, these dates are known
+Podhurst Orseck, P.A.
+6
+25 West Flagler Street, Suite 800, Miami, FL. 3730, Miami 303.358.2800 Fax 305.38.2382 • Fort Lauderdale 954463.4346 1
+
+
+• Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 7 of 19
+to Defendant, as he and/or his assistants kept written records, some of which are in the custody
+of law enforcement, of each instance in which he committed lewd acts upon minor girls,
+including the then minor Plaintiff.
+19.
+Defendant's preference for underage girls was well-known to those who regularly
+procured them for him. The above-described acts of abuse began to occur during a time when
+Defendant knew that Plaintiff was a minor. Defendant, at all times material to this cause of
+action, knew and/or should have known of Plaintiff's age of minority. In fact, Defendant
+repeatedly urged the minor Plaintiff to become legally emancipated in order to accompany him
+as he traveled, both nationally and internationally. Additionally, Defendant, knowing that
+Plaintiff was merely seventeen years old, lured her by inviting her to stay with him at his
+mansion in Manhattan and arranging and/or paying for airplane tickets, theater tickets, and a
+personal chauffeur as gifts for her upcoming birthday.
+20.
+As part of Defendant's persistent process of grooming Plaintiff and immersing her
+in his lewd and abusive lifestyle, Defendant regularly showered the adolescent Plaintiff with
+gifts, including, but not limited to lingerie, flowers, bikini bathing suits), art books), purse(s),
+envelopes of U.S. currency, use of a car, and/or other accoutrements.
+21.
+Defendant possessed photographs of nude underage girls, some of which may
+have been taken with hidden cameras set up in his residence in Palm Beach. On the day of
+Defendant's arrest, police found two hidden cameras and photographs of underage girls in
+Defendant's mansion. Defendant took lewd photographs of Plaintiff with his hidden cameras
+and transported lewd photographs of Plaintiff and other victims elsewhere using a facility or
+means of interstate and/or foreign commerce.
+On one occasion, Defendant manipulated the
+minor Plaintiff to pose nude for him and photographed her using several rolls of film. One or
+Podhurst Orseck, P.A.
+7
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.3592382 • Fort Lauderdale 954.463.4346 /
+
+
+• Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 8 of 19
+more of those nude photographs of Plaintiff that were taken by the Defendant when she was a
+minor were confiscated by the Palm Beach Police Department during its execution of a search
+warrant of Defendant's Palm Beach mansion on October 20, 2005.
+22.
+Defendant was particularly skillful at discerning his minor victims' respective
+hopes, dreams, and ambitions. As he did with many of his victims, Defendant lured Plaintifi
+early-on with modeling opportunities, impressing her with his modeling business and contacts
+with supermodels, indicating that he could help her with a modeling career.
+23. Knowing that the minor Plaintiff was an excellent student and desired to attend
+New York University or Columbia University, Defendant pretended to show great interest in her
+college admission, and offered to help her with her applications and to assist her with her
+tuition. Defendant had told Plaintiff of his substantial connections within the academic
+community, a matter about which he often bragged. Defendant took it upon himself to take
+control of Plaintiff's college application process and led Plaintiff to believe that he was sincere
+about helping her. Even though she had earned a Bright Futures Scholarship to the Florida
+college of her choice,
+Defendant insisted that she would not need it, and that, with his
+involvement, she would be admitted into one or both of the universities in New York. As a
+result of Defendant's manipulation, Plaintiff did not apply timely for the Bright Futures
+Scholarship or to any college, and therefore missed the fall semester of her freshman year. When
+the Palm Beach Police Department executed the search warrant on Defendant's mansion, among
+the artifacts found and confiscated were Plaintiff's high school transcript.
+In June 2008, after an investigation by the Palm Beach Police Department, the
+State Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's
+Office, Defendant entered pleas of "guilty" to one count of solicitation of prostitution, in
+Podhurst Orseck, P.A.
+8
+25 West Flagler Stret, Suite 800, Miami, F1.33130, Miami 305.35.2800 Fax 305.35.282, • Fort Lauderdale 954463.4346 1
+
+
+• Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 9 of 19
+violation of Fla. Stat. § 796.07, and one count of solicitation of a minor to engage in prostitution,
+in violation of Fla. Stat. § 796.03 in the Fifteenth Judicial Circuit in Palm Beach County, Florida.
+25.
+As a condition of that plea, Defendant entered into a Non-Prosecution Agreement,
+Addendum, and Affirmation (collectively, the "NPA") with the United States Attorney's Office
+for the Southern District of Florida on September 24, 2007, October 29, 2007, and December 7,
+2007, respectively. In so doing, Defendant acknowledged that Plaintiff was one of his victims
+and agreed to the following provisions of the NPA:
+8. If any of the [acknowledged victims] elects to file suit pursuant to 18
+§2255, Epstein will not contest the jurisdiction of the United States District Court
+for the Southern District of Florida over his person and/or the subject matter, and
+Epstein waives his right to contest liability and also waives his right to contest
+damages up to an amount agreed to between the identified individual and Epstein,
+so long as the identified individual elects to proceed exclusively under 18
+$2255, and agrees to waive any other claim for damages, whether pursuant to
+state, federal or common law.
+Except as to those individuals who elect to proceed exclusively under 18
+1. §2255, as set forth in paragraph (8), supra, neither Epstein's signature on
+this agreement, nor its terms, nor any resulting waivers or settlements by Epstein
+are to be construed as admissions of evidence or evidence of civil or criminal
+liability or a waive of any jurisdictional or other defense as to any person, whether
+or not her name appears on the list provided by the United States (emphasis
+added).
+26. Plaintiff was among the individuals identified by the United States Attorney's
+Office as victims of Defendant upon whose testimony it intended to base its federal prosecution
+of Defendant for his illegal conduct. Consequently, Defendant is estopped by his state court plea
+and the Non-Prosecution Agreement from denying the acts alleged in this Complaint and must
+effectively admit liability to Plaintiff,
+Doe No. 103.
+COUNT ONE
+Podhurst Orseck, P.A.
+9
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+'Case 9:10-cv-80309-WJZ Document 1
+Entered on FLSD Docket 03/09/2010 Page 10 of 19
+(Cause of Action for Coercion and Enticement of Minor to Engage in Prostitution or
+Sexual Activity pursuant to 18
+§ 2255 in Violation of 18
+. § 2422(b))
+27.
+Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
+allegations contained in paragraphs 1 through 26 above.
+28.
+Defendant used a facility or means of interstate and/or foreign commerce to
+knowingly persuade, induce, entice, or coerce Plaintiff, when she was under the age of 18 years,
+to engage in prostitution and/or sexual activity for which any person can be charged with a
+criminal offense, or attempted to do so, pursuant to 18
+§ 2255 in violation of 18
+• 8
+2422(b).
+29.
+Plaintiff was a victim of one or more offenses enumerated in 18
+§ 2255,
+and, as such, asserts a cause of action against Defendant pursuant to this Section of the United
+States Code.
+30.
+As a direct and proximate result of the offenses enumerated in 18
+• § 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future continue to suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy,
+separation from her family, and other damages associated with Defendant's manipulating and
+luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
+and psychological expenses, and Plaintiff will in the future incur additional medical and
+psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn
+income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in
+nature, and Plaintiff will continue to suffer these losses in the future.
+Podhurst Orseck, P.A.
+10
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 11 of 19
+WHEREFORE, Plaintiff demands judgment against Defendant for all damages available
+under 18
+§ 2255, including, without limitation, actual and compensatory damages,
+attorney's fees, costs of suit, and such other further relief as this Court deems just and proper,
+and hereby demands trial by jury on all issues triable as of right by a jury.
+COUNT TWO
+(Cause of Action for Travel with Intent to Engage in Illicit Sexual Conduct pursuant
+to 18
+$ 2255 in Violation of 18
+- § 2423(b)).
+31.
+Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
+allegations contained in paragraphs 1 through 26 above.
+32.
+Defendant traveled in interstate and/or foreign commerce for the purpose of
+engaging in illicit sexual conduct, as defined in 18
+1. § 2423(f), with minor females,
+including the then minor Plaintiff, in violation of 18
+§ 2423(b). (
+33.
+Plaintiff was a victim of one or more offenses enumerated in 18
+• § 2255,
+and, as such, asserts a cause of action against Defendant pursuant to this Section of the United
+States Code.
+34.
+As a direct and proximate result of the offenses enumerated in 18|
+• § 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future continue to suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy,
+separation from her family, and other damages associated with Defendant's manipulating and
+luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
+and psychological expenses, and Plaintiff will in the future incur additional medical and
+psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn
+Podhurst Orseck, P.A.
+11
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+Case 9:10-cv-80309-WJZ Document 1
+Entered on FLSD Docket 03/09/2010 Page 12 of 19
+income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in
+nature, and Plaintiff will continue to suffer these losses in the future.
+WHEREFORE, Plaintiff demands judgment against Defendant for all damages available
+under 18
+§ 2255, including, without limitation, actual and compensatory damages,
+attorney's fees, costs of suit, and such other further relief as this Court deems just and proper,
+and hereby demands trial by jury on all issues triable as of right by a jury.
+COUNT THREE
+(Cause of Action for Sexual Exploitation of Children pursuant to 18
+$ 2255 in
+Violation of 18
+- § 2251)
+35.
+Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
+allegations contained in paragraphs 1 through 26 above.
+36.
+Defendant knowingly persuaded, induced, enticed, or coerced the then minor
+Plaintiff to engage in sexually explicit conduct for the purpose of producing a visual depiction of
+such conduct, in violation of 18
+§ 2251.
+37.
+Plaintiff was a victim of one or more offenses enumerated in 18
+§ 2255,
+and, as such, asserts a cause of action against Defendant pursuant to this Section of the United
+States Code.
+38.
+As a direct and proximate result of the offenses enumerated in 18
+- § 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future continue to suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy,
+separation from her family, and other damages associated with Defendant's manipulating and
+luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
+Podhurst Orseck, P.A.
+12
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2362 • Fort Lauderdale 954.463.4346
+
+
+Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 13 of 19
+and psychological expenses, and Plaintiff will in the future incur additional medical and
+psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn
+income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in
+nature, and Plaintiff will continue to suffer these losses in the future.
+WHEREFORE, Plaintiff demands judgment against Defendant for all damages available
+under 18
+§ 2255, including, without limitation, actual and compensatory damages,
+attorney's fees, costs of suit, and such other further relief as this Court deems just and proper,
+and hereby demands trial by jury on all issues triable as of right by a jury.
+COUNT FOUR
+(Cause of Action for Transport of Visual Depiction of Minor Engaging in Sexually Explicit
+Conduct pursuant to 18/
+§ 2255 in Violation of 18/
+$ 2252(a)(1)
+39.
+Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
+allegations contained in paragraphs 1 through 26 above.
+40.
+Defendant knowingly mailed, transported, shipped, or sent via computer and/or
+facsimile in or affecting interstate and/or foreign commerce at least one visual depiction of the
+§ 2252(a)(1).
+minor Plaintiff engaging in sexually explicit conduct, in violation of 18
+41.
+Defendant transported lewd photographs of Plaintiff and other victims elsewhere
+using a facility or means of interstate and/or foreign commerce.
+42.
+Plaintiff was a victim of one or more offenses enumerated in 18
+§ 2255,
+and, as such, asserts a cause of action against Defendant pursuant to this Section of the United
+States Code.
+43.
+As a direct and proximate result of the offenses enumerated in 18
+• § 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future continue to suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+Podhurst Orseck, P.A.
+13
+25 West Flagler Stre, Suite 800, Miami, FL. 3130, Miami 305.36 2800 Fax 305.358.2382 - Fort Zauderdale 54163.4346 T
+
+
+'Case 9:10-cv-80309-WJZ Document 1
+Entered on FLSD Docket 03/09/2010 Page 14 of 19
+.. =
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy,
+separation from her family, and other damages associated with Defendant's manipulating and
+luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
+and psychological expenses, and Plaintiff will in the future incur additional medical and
+psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn
+income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in
+nature, and Plaintiff will continue to suffer these losses in the future.
+WHEREFORE, Plaintiff demands judgment against Defendant for all damages available
+under 18
+§ 2255, including, without limitation, actual and compensatory damages,
+attorney's fees, costs of suit, and such other further relief as this Court deems just and proper,
+and hereby demands trial by jury on all issues triable as of right by a jury.
+COUNT FIVE
+(Cause of Action for Transport of Child Pornography pursuant to 18 8 2255
+in Violation of 18
+§ 2252A(a)(1))
+44.
+Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
+allegations contained in paragraphs 1 through 26 above.
+45.
+Defendant knowingly mailed, transported, shipped, or sent via computer and/or
+facsimile in or affecting interstate and/or foreign commerce child pornography, in violation of 18
+. § 2252A(a)(1).
+Defendant transported lewd photographs of Plaintiff and other victims elsewhere
+using a facility or means of interstate and/or foreign commerce.
+47.
+Plaintiff was a victim of one or more offenses enumerated in 18
+§ 2255,
+and, as such, asserts a cause of action against Defendant pursuant to this Section of the United
+States Code.
+Podhurst Orseck, P.A.
+14
+25 West Flagler Street, Sulte 800, Miami, FL. 33130, Miami 305.358.2600 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 15 of 19
+48.
+As a direct and proximate result of the offenses enumerated in 18
+§ 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future continue to suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy,
+separation from her family, and other damages associated with Defendant's manipulating and
+luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
+and psychological expenses, and Plaintiff will in the future incur additional medical and
+psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn
+income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in
+nature, and Plaintiff will continue to suffer these losses in the future.
+WHEREFORE, Plaintiff demands judgment against Defendant for all damages available
+under 18
+§ 2255, including, without limitation, actual and compensatory damages,
+attorney's fees, costs of suit, and such other further relief as this Court deems just and proper,
+and hereby demands trial by jury on all issues triable as of right by a jury.
+COUNT SIX
+(Cause of Action for Engaging in a Child Exploitation Enterprise pursuant to 18
+1 $ 2255 in Violation of 18]
+§ 2252A (g))
+49.
+Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
+allegations contained in paragraphs 1 through 26 above and Counts One through Five above.
+50.
+Defendant knowingly engaged in a child exploitation enterprise, as defined in 18
+• § 2252A(g)(2), in violation of 18 |
+§ 2252A(g)(1). As more fully set forth above,
+Defendant engaged in actions that constitute countless violations of 18
+§ 1591 (sex
+trafficking of children), Chapter 110 (sexual exploitation of children in violation of 18
+Podhurst Orseck, P.A.
+15
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+Entered on FLSD Docket 03/09/2010 Page 16 of 19
+2251, 2252(a)(1), and 2252(A)(a)(1)), and Chapter 117 (transportation for illegal sexual activity
+in violation of 18
+§§ 2421. 2422(b), and 2423(b)). As more fully set forth above in
+paragraphs 1 through 26, Defendant's actions involved countless victims and countless separate
+incidents of sexual abuse, which he committed against minors, including Plaintiff, in concert
+with at least three other persons.
+S1.
+Plaintiff was a victim of one or more offenses enumerated in 18
+§ 2255,
+and, as such, asserts a cause of action against Defendant pursuant to this Section of the United
+States Code.
+52.
+As a direct and proximate result of the offenses enumerated in 18
+• § 2255
+being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
+and will in the future continue to suffer, physical injury, pain and suffering, emotional distress,
+psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
+loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy,
+separation from her family, and other damages associated with Defendant's manipulating and
+luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
+and psychological expenses, and Plaintiff will in the future incur additional medical and
+psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to ear
+income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in
+nature, and Plaintiff will continue to suffer these losses in the future.
+under 18
+WHEREFORE, Plaintiff demands judgment against Defendant for all damages available
+§ 2255, including, without limitation, actual and compensatory damages,
+Podhurst Orseck, P.A.
+16
+25 West Flagler Street, Suite 00, Miami, FL. 3130, Miami 305.358.2800 Fax 305.358.282 • Port Lauderdale 951.463.4316
+
+
+Entered on FLSD Docket 03/09/2010 Page 17 of 19
+attorney's fees, costs of suit, and such other further relief as this Court deems just and proper,
+and hereby demands trial by jury on all issues triable as of right by a jury.
+Date:
+Februay 23, 2010.
+Respectfully Submitted,
+By:
+Robert Josefsberg
+Bar No. 040856
+Katherine W. Ezell
+Bar No. 114771
+Podhurst Orseck, P.A.
+25 West Flagler St., Suite 800
+Miami, Florida 33130
+Telephone: (305) 358-2800
+Fax: (305) 358-2382
+riosefsberg@podhurst.com
+Attorneys for Plaintiff
+Podhurst Orseck, P.A.
+17
+25 West Flagler Stret, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 T
+
+
+' Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010
+
+I0I8OU2
+$JS44*
+CIVIL COVER SHEET
+The JS 44 civil cover sheet and the information contained hercin neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided
+by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for these ofthe Clerk of Court for the purpose of initiating
+the civil docket shect. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM)
+I. (a) PLAINTIFFS
+Doe No. 103
+10-8030
+ANTS
+Epstein
+FILED by EB
+(b) County of Residence of First Listed Plaintiff West Palm Beach
+County of Residence of First Listed Deferent
+United States Virom ilant:
+(EXCEPT IN U.S. PLAINTIFF CASES)
+(IN U.S. PLAINTEF CASES ONLY)
+( Altomey's (Firm Nemo, Address, and Telephose Number)
+NOTE: IN LAND CONDEMNATION CASES, FEB: 203-2010 THE TRACT
+LAND INVOLVED.
+Robert . Josefsberg, Esq./Katherine W. Ezell, Esq.
+STEVEN M. LARIMORE
+Podhurst Orseck, P.A.
+Altomeys (If Known)
+CLERK U.S. DIST. CT.
+25 W. Flagler St., Suite 800
+Miami FI 33130
+Robert D. Critton, Esq., Burman, cital, PaliSA CALAMG, LL.P,
+303 Banyan Blvd., Suite 400, West Palm Beach, FL 33401
+(d) Check County Where Action Aroso: • MIAMI-DADE • MONROE O BROWARD
+6 PALM BEACH O MARTIN
+O ST. LUCIE
+• INDIAN RIVER
+O OKEECHOBEE
+HIGHLANDS
+HI. BASIS OF JURISDICTION
+(Place an "? in One Box Only)
+• I U.S. Government
+My Federal Question
+Plaintiff
+(U.S. Goverament Not a Party)
+O 2 U.S. Government
+Defendant
+34
+Diversity
+III. CITIZENSHIP OF PRINCIPAL PARTIES(Place an *X" in Ona Bax for Plainstr
+{For Diversity Cases Only)
+and One Bez for Defendant)
+Citizca of This State
+Incorporated or Principal Place
+of Business In This State
+• Chizes of Ansther State
+2
+2 Incorporated and Principal Place
+0
+10 5
+(Indicate Citizenship of Panies in Item IN)
+• Rusiacss In Another State
+Citizea or Subject of a O
+Foreign Country
+1 a 1 Porcien Nation
+IV. NATURE OF SUIT
+(Pluse an "X" in One Bos Onlvi
+CONTRACT
+TORTS
+• 110 Insurance
+PERSONAL INJURY
+PERSONAL INJURY
+120 Marine
+• 310 Airplane
+362 Personal Injury -
+130
+Act
+O 315 Airplane Product
+Mad. Malpractice
+140 Negotlable Instrument
+Liability
+365 Personal Injury -
+150 Recovery of Overpayment
+• 320 Assault, Libel &
+Product Liability
+& Enforcoment of Judgment
+Slander
+• 368 Asbestos Personal
+• 151 Medioare Act
+• 330 Federal Emplayers"
+• 152 Recovery of Defaulted
+Liability
+Injury Product
+Liability
+Studeni Loans
+O 340 Marine
+PERSONAL PROPERTY
+(ExcL Velerans)
+O 345 Marine Product
+370 Diher Fawad
+• 153 Recovery of Overpayment
+of Veieren's Benefits
+Liability
+371 Trath in Lending
+C 350 Motor Vehick
+380 Other Personal
+• 160 Stockholders" Sults
+• 355 Mater Vehiele
+Property Damage
+• 190 Other Contract
+Product Liability
+185 Paoperly Damag:
+195 Contreet Produet Liability
+I0 360 Other Personal
+196 Franchise
+Injany
+Product Lisbility
+REAL PROPERTY
+CIVIL RIGHTS
+PRISONER PETITIONS
+• 2I0 Land Condemnalion
+D 441 Voting
+510 Motions so Vacate
+• 220 Foreolosure
+• 442 Employment
+• 230 Reat Lease & Ejeciment
+O 443 Housing/
+Sentence
+Habeas Corpus:
+240 Tests to Land
+Accommodations
+• 245 Tort Product Liability
+• 444 Welfere
+g
+530 General
+535 Death Penalty
+• 290 All Other Rcal Property
+445 Amer, w/Disabilities
+Employment
+540 Mandamus & Other
+446
+• Other
+Amer. w/Disabilities
+530 Civil Rights
+3 440 Other Civil Rights
+555 Prison Coadition
+FOREEITURE ENALTY
+610 Agriculture
+620 Other Food & Drug
+625 Drug Related Seizure
+of Property 21 USC 881
+630 Liquor Laws
+640 R.R. & Track
+650 Airline Reps.
+660 Occupational
+BANKRUPTCY
+• 422 Appeal 28 USC 158
+• 423 Withdrawal
+28 USC 157
+PROPERTY RIGHTS
+O 820 Copyrights
+• 830 Patent
+• 840 Tredemark
+Safaty/Health
+690 Other
+SOCIAL SECURITY
+• 710 Fair Labor Standards
+• 861 HIA (139560
+Act
+• 862 Black Lung (923)
+720 Labor/Mgmt. Relations
+• 863 DIWC/DIWW (405(g))
+730 Labor/Mgmt.Reportisg
+• 804 SSID Tille XVI
+& Disclosure Ace
+• 865 RSI (405(g))
+740 Railway Labor Act
+FEDERAL TAX SUITS
+790 Olber Labor Litigation
+• 870 Taxes (U.S. Plaintiff
+791 Emp]. Rei. Inc, Sccurity
+er Defendant)
+© 871 1R5-Third Party
+26 USC 7609
+OTHER STATUTES
+400 State Rapportionment
+410 Antitrust
+430 Banks and Banking
+430 Commerce
+450 Deportation
+470 Rackesser Influeneed and
+Corrupt Organizations
+480 Consumer Credit
+490 Cable/Sat TV
+$10 Selective Service
+850 Securities/Commodities/
+Exchange
+• 875 Customer Challenge
+12 USC 3410
+890 Other Siatutory Actions
+891 Agricultural Acts
+892 Economic Stabilization Act
+893 Environmental Matters
+894 Energy Allocation Act
+895 Freedom ef Information Act
+IN MIGRATION
+• 900 Appeal of Foo Determination
+462 Naturalization
+Under Equal Access so Justice
+Application
+463 Habras Corpus-Alien
+Detainee
+465 Other Immigration
+Actions
+950 Coastitationality of Sele
+Statules
+ORIGIN
+50 1 Original
+Proceeding
+(Place an "X" in One Box Only)
+0 2
+Romoved from
+• 3
+•Re-filod.
+• 4 Reinstated or • 5
+Transferred from CJ 6 Multidistrict
+State Court
+(see VI below)
+Reopened
+another district
+(specify)
+• 7
+Litigation
+Appcal to District
+Judge from
+Magistrate
+Judement
+a) Re-filed Case • YES FINO
+b) Related Cases 7 YES O NO
+VI. RELATED/RE-FILED
+CASE(S).
+(Soo instructions
+second pago):
+JUDGE Kenneth A. Marra
+DOCKET NUMBER See Attached.
+Cil the U.S. Civil Statule under which you are filing and Write a Brief Statement of Causc (Do not eite jurisdictional statules unless
+diversity):
+VII. CAUSE OF ACTION 18
+2255 (Predicate Statutes 18
+2422(b), 2423(b), 2423(e), 2251, 2252, 2252A(a)(1), 2252A(g)(1)
+LENGTH OF TRIAL via 5
+days estimated (for both sides to try entire case)
+VIII. REQUESTED IN
+• CHECK IF THIS IS A CLASS ACTION
+DEMAND S
+COMPLAINT:
+UNDER
+CHECK YES only if demanded in complaint:
+23
+ABOVE INFORMATION IS TRUE & CORRECT TO
+IN exces o€ $75,000." JURY DEMAND:
+Soaled No
+THE BEST OF MY KNOWLEDGE
+SIGNATURE OF ATTORNEY OF RECORD
+s/ Katheire W. Ezell
+FOR OFFICE USE ONLY
+21ö3/10
+AMOUNT 350.00
+RECEIPT" 10/ 8042.
+IFP
+2/23/1
+
+
+Entered on FLSD Docket 03/09/2010 Page 19 of 19
+•
+VI.
+WEST PALM BEACH DIVISION
+ATTACHMENT TO CIVIL COVER SHEET
+FOR:
+_ Doe 103 L. Jeffrey Epstein
+RELATED PENDING CASES
+08-80119 - KAM
+08-80232 - KAM
+08-80380 - KAM
+08-80381 - KAM
+08-80811 - KAM
+08-80893 - KAM
+08-80993 - KAM
+08-80994 - KAM
+09-80469 - KAM
+09-80802 - KAM
+09-81092 - KAM
+
+
+RoY BLACK
+HOWARD M. SREENICK
+LARRY A. STUMPF
+MARIA NEYRA
+JACKIE PERCZEK
+MARK A..J. SHAPIRO
+JARED
+BLACK
+SREBNICK
+CORNSPAN
+& STUMPF
+E-Mail:
+March 29, 2010
+99 N.E. 4" Street
+Miami, FL 33132
+1, Esq.
+Assistant United States Attorney
+99 N.E. 4" Street
+Miami, FL 33132
+1, Esq.
+Assistant United States Attorney
+500 South Australian Avenue
+West Palm Beach, FL 33401-6223
+RE: Jeffrey Epstein
+Dear Counsel:
+Jeffrey Epstein has an April 5, 2010 deadline for the filing of a Motion to
+Dismiss, and thereafter an Answer, to claims brought by
+to 18 USC §2255 that were referenced in our earlier letter to you dated March 5,
+2010, to which there has been no response. We firmly believe that the issues
+raised in the draft motion that is appended to this letter do not conflict with, nor,
+if filed, breach Mr. Epstein's obligations under the NPA.
+Please advise if any of the issues in the draft motion authored by his civil
+counsel Robert Critton are, from your perspective, in conflict with the §2255
+provisions of the NPA so that we may reassess our legal opinion that Mr. Epstein's
+civil counsel can litigate the legal issues contained in the draft motion without fear
+that the litigation will be construed by your office as being in violation of the NPA.
+If the government believes that any of the issues intended to be raised in defense
+of the
+Doe 103 lawsuit are in breach of Mr. Epstein's obligations under the
+NPA, we request notice so that we could decide before any filing whether to file a
+201 S. Biscayne Boulevard, Suite 1300 • Miami, Florida 3313l • Phone: 305-371-6421 • Fax: 305-358-2006 • www.RoyBlack.com
+
+
+Esg.
+March 29, 2010
+,, Esq.
+Declaratory Judgment action asking the Court presiding over the
+Doe 103
+lawsuit to determine whether the raising of the issue by motion or defense would
+the issue lict with Men: Westerome noracted duties under thin, it in to wit trau
+if in conflict witl
+ours, is correct.
+Again, Mr. Epstein's paramount priority, and ours, is that the terms of Mr.
+Epstein's agreement with the government be followed and fulfilled.
+Your truly,
+MARTIN WEINBERG, ESQ.
+in Bale
+/ wg
+
+
+CASE NO. 10-80309-CIV-
+DOE No. 103,
+Plaintiff,
+VS.
+JEFFERY EPSTEIN,
+Defendant.
+/
+DEFENDANT EPSTEIN'S MOTION TO DISMISS, & FOR MORE
+DEFINITE STATEMENT & STRIKE DIRECTED TO PLAINTIFF
+DOE NO. 103'S COMPLAINT (dated 2/23/2010]
+Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned
+counsel, moves to dismiss Counts One through Six of Plaintiff
+DOE 103's
+Complaint for failure to state a cause of action, as specified herein. Rule 12(b)(6),
+Fed.R.Civ.P. (2009); Local Gen. Rule 7.1 (S.D. Fla. 2009). Defendant further moves for
+more definite statement and to strike. Rule 12(e) and (f), In support of his motion,
+Defendant states:
+The Complaint attempts to allege 6 counts, all of which are purportedly brought
+pursuant to 18
+§2255 - Civil Remedies for Personal Injuries.
+Dismissal is
+required on the following grounds: (1) 18
+. §2255 allows for a single recovery of
+"actual damages."
+(A.) Statutory Considerations: the statute does not allow for the
+Plaintiff to allege multiple counts, six in this case, or multiple predicate act violations or
+incidents, in an effort to multiply or seek duplicate recoveries of her "actual damages"
+1
+
+
+based on the number of predicate act violations or incidents. The statutory minimum is
+just that - a minimum; nothing prevents a plaintiff from proving and recovering "actual
+damages" in excess of the minimum amount. (B.) Constitutional Considerations: in
+the alternative, constitutional principles require that the statute be interpreted as allowing
+for a single recovery of one's damages. Thus, to the extent Plaintiff is seeking to
+improperly multiply or seck duplicate recoveries of her actual damages, the action is
+required to be dismissed. (2) The statute in effect during the time of the alleged conduct
+applies - the version in effect from 1999 to July 26, 2006, not the statute as amended in
+2006, effective July 27, 2006. To the extent Plaintiff' is attempting to rely on the
+amended version of the statute, such reliance is improper and also requires dismissal of
+the entire action. (3) Count VI is also subject to dismissal because the predicate act relied
+upon by Plaintiff did not come into effect until July 27, 2006, well after the conduct
+alleged by Plaintiff occurred.
+Supporting Memorandum of Law
+Principles of Statutory Interpretation
+It is well settled that in interpreting a statute, the court's inquiry begins with the
+plain and unambiguous language of the statutory text. CBS, Inc. . Prime Time 24
+Venture, 245 F.3d 1217 (11" Cir. 2001); U.S. |. Castroneves, 2009 WL 528251, *3 (S.D.
+Fla. 2009), citing Reeves I. Astrue, 526 F.3d 732, 734 (11" Cir. 2008); and Smith I
+Husband, 376 F.Supp.2d at 610 ("When interpreting a statute, [a court's] inquiry begins
+with the text."). "The Court must first look to the plain meaning of the words, and
+scrutinize the statute's 'language, structure, and purpose.'" Id. In addition, in construing
+a statute, a court is to presume that the legislature said what it means and means what it
+said, and not add language or give some absurd or strained interpretation. As stated in
+2
+
+
+CBS, Inc., supra at 1228 - "Those who ask courts to give effect to perceived legislative
+intent by interpreting statutory language contrary to its plain and unambiguous meaning
+are in effect asking courts to alter that language, and [Jourts have no authority to alter
+statutory language.... We cannot add to the terms of [the] provision what Congress left
+out.' Merritt, 120 F.3d at 1187." See also Dodd | U.S., 125 S.Ct. 2478 (2005); 73
+Am.Jur.2d Statutes §124.
+Title 18 of the
+is entitled "Crimes and Criminal Procedure." §2255 is
+contained in "Part 1. Crimes, Chap. 110. Sexual Exploitation and Other Abuse of
+Children." 18
+§2255 (2002)', is entitled Civil remedy for personal injuries, and
+provides:
+(a) Any minor who is a victim of a violation of section 2241(D, 2242, 2243, 2251,
+2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suffers
+personal injury as a result of such violation may sue in any appropriate United
+States District Court and shall recover the actual damages such minor sustains
+and the cost of the suit, including a reasonable attorney's fee. Any minor as
+described in the preceding sentence shall be deemed to have sustained damages
+of no less than $50,000 in value.
+(b) Any action commenced under this section shall be barred unless the complaint
+period win sie a is alter he right of action is acres or in sa case of
+See endnote 1 hereto for statutory text as amended in 2006, effective July 27,
+2006. Prior to the 2006 amendments, the version of the statute quoted above was in
+effect beginning in 1999.'
+' The above quoted version of 18
+1. §2255 was the same beginning in 1999 until
+amended in 2006, effective July 27, 2006.
+3
+
+
+Motion to Dismiss
+(1) The remedy afforded pursuant to 18
+$2255 allows for a single
+recovery of "actual damages" by a plaintiff against a defendant. The recovery
+afforded is not on a per violation or per incident or per count basis.
+(A.)
+Statutory Considerations.
+18
+1. §2255 - Civil Remedy for Personal
+Injuries, creates a federal cause of action or "civil remedy" for a minor victim of sexual,
+abuse, molestation and exploitation, and allows for a single recovery of the "actual
+damages" sustained and proven by a "minor who is a victim of a violation" of an
+enumerated predicated act and who suffers personal injury as a result of such violation."
+"18
+§2255 gives victims of sexual conduct who are minors a private right of
+action." Martinez. |. White, 492 F.Supp.2d 1186, 1188 (N.D. Cal. 2007). 18
+§2255 "merely provides a cause of action for damages in 'any appropriate United States
+District Court."" Id, at 1189.
+Under the plain meaning of the statute, §2255 does not allow for the actual
+damages sustained to be duplicated or multiplied on behalf of a plaintiff against a
+defendant on a "per violation" or "per incident" or "per count" basis. No where in the
+2 In other $2255 actions filed against Defendant, Defendant has previously asserted the
+position that 18
+1. §2255's creates a single cause of action on behalf of a plaintiff
+against a defendant, as opposed to multiple causes of action on a per violation basis or as
+opposed to an allowance of a multiplication of the statutory presumptive minimum
+damages or "actual damages." EPSTEIN asserts his position regarding the single
+recovery of damages in order to properly preserve all issues pertaining to the proper
+application of §2255 for appeal. EPSTEIN will fully honor his obligations as set forth
+in the Non-Prosecution Agreement with the United States Attorney's Office;
+principally, as related to the claims made in this case by
+• Doe 103, the
+obligations as set forth in paragraph 8 of that Agreement. In particular, EPSTEIN
+will not contest the allegation that he committed at least one predicate offense as
+alleged by L
+Doe 103, a waiver sufficient to satisfy the 2255 statutory condition
+that
+Doe 103 was a victim of the commission of one of the enumerated
+predicate violations as required.
+4
+
+
+statutory text is there any reference to the recovery of damages afforded by this statute as
+being on a "per violation" or "per incident" or "per count" basis. 18
+2255(a)
+creates a civil remedy for "a minor who is a victim of a violation of section 2241(D,
+2242, 2243, 2251, 2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who
+suffers personal injury as a result of such violation ...." The statute speaks in terms of
+the recovery of the actual damages such minor sustains and the cost of suit, including
+attorney's fees." See 18
+§2255(a) (2002). See Smith |. Husband, 428 F.Supp.2d
+432 (E.D. Va. 2006); Smith |. Husband, 376 F.Supp.2d 603 (E.D. Va. 2006); Doe |
+Liberatore, 478 F.Supp.2d 742, 754 (M.D. Pa. 2007); and the recent cases in front of this
+court on Defendant's Motions to Dismiss and For More Definite Statement - Doe No. 2
+|. Epstein, 2009 WL 383332 (S.D. Fla. Feb. 12, 2009); Doe No. 3 ||. Epstein, 2009 WL
+383330 (S.D. Fla. Feb. 12, 2009); Doe No. 4 | Epstein, 2009 WL 383286 (S.D. Fla. Feb.
+12, 2009); and Doe No. 5 |. Epstein, 2009 WL 383383 (S.D. Fla. Feb. 12, 2009); see also
+U.S. |. Scheidt, Slip Copy, 2010 WL 144837, fn. 1 (E.D.Cal. Jan. 11, 2010); U.S. |
+Renga, 2009 WL 2579103, fn. 1 (E.D. Cal. Aug. 19, 2009); U.S. |. Ferenci, 2009 WL
+2579102, fn. 1 (E.D. Cal. Aug. 19, 2009); U.S. |. Monk, 2009 WL 2567831, fn. 1 (E.D.
+Cal. Aug. 18, 2009); U.S. |. Zane, 2009 WL 2567832, fn. 1 (E.D. Cal. Aug. 18 2009).
+As to the meaning of "actual damages," the Eleventh Circuit in McMillian I
+.. 81 F.3d 1041, 1055 (11th Cir. 1996), succinctly explained:
+3 In McMillian, the 11* Circuit was faced with the task of the interpretation of the
+statutory term
+"actual direct compensatory damages" under FIRREA, 12
+§1821(g)(3)(1). In doing so, the Court began with the plain meaning of the phrase. Se
+Perrin . United States, 444 U.S. 37, 42-43, 100 S.Ct. 311, 314, 62 L.Ed.2d 199 (1979)
+"A fundamental canon of statutory construction is that, unless otherwise defined, word
+vill be interpreted as taking their ordinary, contemporary common meaning."): Unite
+States |. Mclymont 45 F.3d 400, 401 (11th Cir.), cert. denied, 514 U.S. 1077, 115 S.Ct.
+5
+
+
+"Compensatory damages" are defined as those damages that "will
+compensate the injured party for the injury sustained, and nothing more; such
+as will simply make good or replace the loss caused by the wrong or injury."
+Black's Law Dictionary (6th Ed.1991). "Actual damages," roughly
+synonymous with compensatory damages, are defined as "[r]eal,
+substantial and just damages, or the amount awarded to a complainant
+in compensation ter his i pal and el logs or ha, i also direct
+damages are such as follow immediately upon the act done." Id. Thus,
+"actual direct compensatory damages" appear to include those damages,
+flowing directly from the repudiation, which make one whole, as opposed
+to those which go farther by including future contingencies such as lost
+profits and opportunities or damages based on speculation. [Citation
+omitted]. ...
+FN15. According to Corpus Juris Secundum, " 'Compensatory damages'
+and get ol a tas are syno nees terry danded al
+Damages § 2 (1966).
+(Emphasis added).
+See also, Fanin I. U.S. Dept. of Veteran Affairs, 2009 WL 1677233 (11" Cir. June
+17, 2009), citing Fitzpatrick |. IRS, 665 F.2d 327, 331 (11" Cir. 1982), abrogated on
+other sounds by Doe I. Chao, 510 U.S. 611, 124 S.CL. 1204 (2004) "Actual damages"
+recoverable under the Privacy Act are "proven pecuniary losses and not for generalized
+mental injuries, loss of reputation, embarrassment or other non-qualified injuries;" and
+the statutory minimum of $1,000 under the Privacy Act is not available unless the
+plaintiff suffered some amount of "actual damages.").
+Considering the plain meaning of "actual damages" and the purpose of such
+damages is to "make one whole," to allow a duplication or multiplication of the actual
+damages sustained is in direct conflict with the well entrenched legal principle against
+duplicative damages recovery. See generally,
+I Waffle House, Inc.., 534 U.S.
+1723, 131 L.Ed.2d 581 (1995) ("[T]he plain meaning of this statute controls unless the
+language is ambiguous or leads to absurd results.").
+6
+
+
+•
+279, 297, 122 S.Ct. 754, 766 (2002)"As we have noted, it 'goes without saying that the
+courts can and should preclude double recovery by an individual."), citing General
+Telephone, 446 U.S., at 333, 100 S.Ct. 1698.
+The purpose of damages recovery where a Plaintiff has suffered personal injury
+as a result of Defendant's misconduct is to make the plaintiff whole, not to enrich the
+plaintiff. See 22 Am.Jur.2d Damages §36, stating the settled legal principle that -
+The law abhors duplicative recoveries, and a plaintiff who is injured by a
+defendant's misconduct is, for the most part, entitled to be made whole, not
+enriched. Hence, for one injury, there should be one recovery, irrespective of
+the availability of multiple remedies and actions. Stated otherwise, a party
+cannot recover the same damages twice, even if recovery is based on
+different theories.
+, a plaintiff who alleges separate causes of action is not permitted to recover
+more than the amount of damages actually suffered. There cannot be a
+double recovery for the same loss, even though different theories of liability
+are alleged in the complaint. ....
+See also, 22 Am.Jur.2d Damages § 28 -
+The law abhors duplicative recoveries; in other words, a plaintiff who is
+injured by reason of a defendant's behavior is, for the most part, entitled to be
+made whole, not to be enriched. The sole object of compensatory damages is
+to make the injured party whole for losses actually suffered; the plaintiff
+annot be made more than whole, make a profit, or receive more than on
+ecovery for the same harm. Thus, a plaintiff in a civil action for damage:
+cannot, in the absence of punitive or statutory treble damages, recover more
+than the loss actually suffered. The plaintiff is not entitled to a windfall, and
+the law will not put him in a better position than he would be in had the
+wrong not been done or the contract not been broken.
+See also recent case of U.S. |. Baker, 2009 WL 4572, at *8, (E.D. Tx. Dec. 7,
+2009), wherein the Court was inclined to agree with the defendant's interpretation of
+§2255(a) of allowing for a single recovery of the statutory minimum damages amount as
+opposed to the government's argument that "the minimum amount of damages mandated
+by 18
+§2255(a)
+applies to each of (pornographic) image produced by
+7
+
+
+[defendant]." The government attempted to argue that restitution should be equal to the
+statutory minimum amount times the 55 photos produced by defendant. In rejecting the
+government's argument, the Court reiterated that the statutory minimum is a floor for
+damages - in other words, a mandated minimum. Nothing prevents a plaintiff from
+proving that he or she suffered damages in a greater amount.
+In attempting to bring six counts pursuant to §2255, Plaintiff's complaint alleges in
+part that "Plaintiff was merely a seventeen year old high school student when she was
+first lured into Defendant's sexually exploitive world in or about January 2004."
+Complaint, 117. According to the allegations, Plaintiff "was recruited while at work by a
+co-worker, one of the minor victims Defendant paid to procure underage females." Id.
+The Complaint further alleges, 9917-26, that Defendant "sexually abused and/or battered
+and/or exploited Plaintiff at least 100 times between January 2004 and May 2005." If
+Plaintiff were 17 in January, 2004, she was at least 18 (the age of majority) in January
+2005, if not sooner.*
+Plaintiff alleges identical damages in each of the six counts. Complaint, 19130, 34,
+38, 43, 48, and 52. See endnote 2 hereto for Complaint allegations.? In other words,
+Plaintiff is alleging and seeking recovery of duplicative damages in each of the six
+counts.
+To the extent Plaintiff is seeking to duplicate her "actual damages" on a per
+incident or per violation or per count basis, Plaintiff's action is required to be dismissed
+for failure to state a cause of action.
+" Defendant is moving for more definite statement requiring Plaintiff to specifically state
+her date of birth because her age and when she reached the age of majority may impact
+her ability to even pursue a §2255 claim.
+8
+
+
+Had Congress wanted to write in a multiplier of actual damages recoverable it
+could have easily done so. For an example of a statute wherein the legislature included
+the language "for each violation" in assessing a "civil penalty," see 18
+8216,
+entitled "Penalties and injunctions," of Chapter 11 - "Bribery, Graft, and Conflict of
+Interests," also contained in Title 18 - "Crimes and Criminal Procedure." Subsection (b)
+of §216 gives the United States Attorney General the power to bring a "civil action ...
+against any person who engages in conduct constituting an offense under" specified
+sections of the bribery, graft, and conflicts of interest statutes. The statute further
+provides in relevant part that "upon proof of such conduct by a preponderance of the
+evidence, such person shall be subject to a civil penalty of not more than $50,000 for
+each violation or the amount of compensation which the person received or offered for
+the prohibited conduct, which ever amount is greater." As noted, 18
+. §2255 does
+not include such language.
+B.
+Constitutional Considerations As set forth above, it is Defendant's
+position that the text of 18
+- §2255 does not allow a Plaintiff to pursue the recovery
+of actual damages or the minimum afforded under the statute on a "per violation" or "per
+incident" basis by attempting to allege multiple counts thereunder. In the alternative, if
+one were to assume that the language of §2255 were vague or ambiguous, under the
+constitutional based protections of due process, judicial restraint, and the rule of lenity
+applied in construing a statute, Defendant's position as to the meaning of the statute
+would prevail.
+See United States | Santos, 128 S.Ct. 2020, 2025 (2008). As
+summarized by the United States Supreme Court in Santos, supra, at 2025:
+See argument in sections (2) and (3) that follow which represent the predicate for the rule of
+lenity issue discussed in B
+
+
+... The rule of lenity requires ambiguous criminal laws to be interpreted in
+avor of the defendants subjected to them. See United States . Gradwell, 24:
+J.S. 476, 485, 37 S.Ct. 407, 61 L.Ed. 857 (1917); McBoyle |. United States
+283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931); United States |. Bass,
+404 U.S. 336, 347-349, 92 S.Ct. 515, 30 L.Ed.2d 488 (1971). This venerable
+rule not only vindicates the fundamental principle that no citizen should be
+held accountable for a violation of a statute whose commands are uncertain,
+or subjected to punishment that is not clearly prescribed. It also places the
+weight of inertia upon the party that can best induce Congress to speak more
+clearly and keeps courts from making criminal law in Congress's stead. ...
+In Santos, the Court was faced with the interpretation of the term "proceeds" in
+• §1956. "The federal money-laundering
+the federal money laundering statute, 18|
+statute prohibits a number of activities involving criminal "proceeds."" Id, at 2023.
+Noting that the term "proceeds" was not defined in the statute, the Supreme Court stated
+the well settled principle that "when a term is undefined, we give it its ordinary
+meaning." Id, at 2024. Under the ordinary meaning principle, the government's position
+was that proceeds meant "receipts," while the defendant's position was that proceeds
+meant "profits."
+The Supreme Court recognized that under either of the proffered
+"ordinary meanings," the provisions of the federal money-laundering statute were still
+coherent, not redundant, and the statute was not rendered "utterly absurd." Under such a
+situation, citing to a long line of cases and the established rule of lenity, "the tie must go
+to the defendant." Id, at 2025. See portion of Court's opinion quoted above. "Because
+the 'profits' definition of 'proceeds' is always more defendant friendly that the "receipts'
+definition, the rule of lenity dictates that it should be adopted." Id.
+The recent case of United States |. Berdeal, 595 F.Supp.2d 1326 (S.D. Fla. 2009),
+further supports Defendant's argument that the "rule of lenity" requires that the Court
+resolve any statutory interpretation conflict in favor of Defendant. Assuming for the sake
+of argument that Plaintiff's multiple counts, leading to a multiplication of the statutory
+10
+
+
+damages
+amount, is a
+reasonable interpretation,
+like Defendant's reasonable
+interpretation, under the "rule of lenity," any ambiguity is resolved in favor of the least
+draconian measure. In Berdeal, applying the rule of lenity, the Court sided with the
+Defendants' interpretation of the Lacey Act which makes illegal the possession of snook
+caught in specified jurisdictions. The snook had been caught in Nicaraguan waters. The
+defendants filed a motion to dismiss asserting the statute did not encompass snook caught
+in foreign waters.
+The United States disagreed. Both sides presented reasonable
+interpretations regarding the reach of the statute. In dismissing the indictment, the Court
+determined that the rule of lenity required it to accept defendants interpretation.
+To allow a duplication or multiplication would subject Defendant EPSTEIN to a
+punishment that is not clearly prescribed - an unwritten multiplier of the "actual
+damages" or the presumptive minimum damages. The rule of lenity requires that
+Defendant's interpretation of the remedy afforded under §2255 be adopted.
+In addition, under the Due Process Clause's basic principle of fair warning -
+... a criminal statute must give fair warning of the conduct that it makes a
+crime .
+As was said in United States |. Harriss, 347 U.S. 612, 617, 74
+S.Ct. 808, 812, 98 L.Ed. 989,
+"The constitutional requirement of definiteness is violated by a criminal
+statute that fails to give a person of ordinary intelligence fair notice that
+his contemplated conduct is forbidden by the statute. The underlying
+principle is that no man shall be held criminally responsible for conduct
+which he could not reasonably understand to be proscribed.'
+Thus we have struck down a [state] criminal statute under the Due Process
+Clause where it was not 'sufficiently explicit to inform those who are subject
+to it what conduct on their part will render them liable to its penalties.'
+Connally | . General Const. Co., 269 U.S. 385, 391, 46 S.Ct. 126, 127, 70
+L.Ed. 322. We have recognized in such cases that a statute which either
+forbids or requires the doing of an act in terms so vague that men of common
+intelligence must necessarily guess at its meaning and differ as to its
+application violates the first essential of due process of law,' ibid., and that
+11
+
+
+'No one may be required at peril of life, liberty or property to speculate as to
+the meaning of penal statutes. All are entitled to be informed as to what the
+State commands or forbids.' Lanzetta |. New Jersey, 306 U.S. 451, 453, 59
+S.Ct. 618, 619, 83 L.Ed. 888.
+Thus, applying the statutory analysis, in A. and these well-entrenched
+constitutional principles of statutory interpretation and application in B., Plaintiff's cause
+of action - Counts One through Six - to the extent Plaintiff is attempting to multiply
+actual damages or the presumptive amount of damages, is required to be dismissed for
+failure to state a cause of action.
+(2) In addition, if Plaintiff is relving on the amended version of 18
+. 82255,
+uch reliance is improper and requires dismissal of the entire action.
+It is
+efendant's position
+that 18|
+• $2255. in effect prior to the 2006
+amendments applies to this action.
+(3) Further, Count Six is also required to be dismissed as it relies on a predicate
+aet that was not in effect at the time of the alleged conduet.
+Plaintiff does not specifically allege in her Complaint on which version of 18
+- §2255 she is relying. However, in the purported Count Six of her Complaint, 150,
+she alleges that Defendant "knowingly engaged in a child exploitation enterprise, as
+defined in 18
+§2252A(g)(2), in violation of 18
+• §2252A(g)(I)." §2252A is
+one of the specified predicate acts under 18
+|. §2255. However, subsection (g) of
+§2252 was not added to the statute until 2006. Thus, to the extent that Plaintiff is relying
+on the amended version, such reliance is improper and the entire action is required to be
+dismissed. Further, in the alternative, Count Six is required to be dismissed as it relies on
+a statutory predicate act that did not exist at the time of the alleged conduct.
+The statute in effect during the time the alleged conduct occurred is 18
+§2255 (2005) - the version in effect prior to the 2006 amendment, eff. Jul. 27, 2006,
+® Points (2) and (3) are addressed together as the legal arguments overlap.
+12
+
+
+(quoted above), and having an effective date of 1999 through July 26, 2006. See
+endnote 1 hereto. Plaintiff's Complaint alleges that Defendant's conduct occurred during
+the time period from the age of 17, January 2004 until approximately May 2005.
+Complaint, 1917, 18. Thus, the version in effect in 2004-2005 of 18
+$2255
+applies.
+Under applicable law, the statute in effect at the time of the alleged conduct
+applies. See U.S. |. Scheidt, Slip Copy, 2010 WL 144837, fn. 1 (E.D.Cal. Jan. 11, 2010);
+U.S. |. Renga, 2009 WL. 2579103, fn. 1 (E.D. Cal. Aug. 19, 2009); U.S. |. Ferenci, 2009
+WL 2579102, fn. 1 (E.D. Cal. Aug. 19, 2009); U.S. |. Monk, 2009 WL 2567831, fn. 1
+(E.D. Cal. Aug. 18, 2009); U.S. L. Zane, 2009 WL 2567832, fn.1 (E.D. Cal. Aug. 18
+2009). In each of these cases, the referenced footnote states -
+Prior to July 27, 2006, the last sentence in Section §2255(a) read "Any
+person as described in the preceding sentence shall be deemed to have
+sustained damages of no less than $50,000 in value." Under the civil statute,
+the minimum restitution amount for any violation of Section 2252 (the
+predicate act at issue) is $150,000 for violations occurring after July 27, 2006
+and $50,000 for violations occurring prior to $50,000.
+Even with the typo (the extra "$50,000") at the end of the quoted sentence, it is
+clear that the Court applied the statute in effect at the time of the alleged criminal conduct
+constituting one of the statutorily enumerated predicate acts, which is consistent with
+applicable law discussed more fully below herein.
+It is an axiom of law that "retroactivity is not favored in the law." Bowen, 488
+U.S., at 208, 109 S.Ct., at 471 (1988). As eloquently stated in Landgraf |. USI Film
+Products, 114 S.Ct. 1483, 1497, 511 U.S. 244, 265-66 (1994):
+.. the presumption against retroactive legislation is deeply rooted in our
+13
+
+
+expectations should not be lightly disrupted. NI" For that reason, the "principle that the
+legal effect of conduct should ordinarily be assessed under the law that existed when the
+conduct took place has timeless and universal appeal." Kaiser, 494 U.S., at 855, 110
+S.Ct., at 1586 (SCALIA, J., concurring). In a free, dynamic society, creativity in both
+commercial and artistic endeavors is fostered by a rule of law that gives people
+confidence about the legal consequences of their actions.
+FN18. See General Motors Corp. I. Romein, 503 U.S. 181, 191, 112 S.Ct. 1105,
+1112, 117 L.Ed.2d 328 (1992) ("Retroactive legislation presents problems of
+unfairness that are more serious than those posed by prospective legislation, because
+it can deprive citizens of legitimate expectations and upset settled transactions");
+[Further citations omitted].
+It is therefore not surprising that the antiretroactivity principle finds expression in
+several provisions of our Constitution. The Ex Post Facto Clause flatly prohibits
+retroactive application of penal legislation.™NI? Article I, § 10, cl. 1, prohibits States
+from passing another type of retroactive legislation, laws "impairing the Obligation of
+Contracts." The Fifth Amendment's Takings Clause prevents the Legislature (and other
+government actors) from depriving private persons of vested property rights except for
+a "public use" and upon payment of "just compensation." The prohibitions on "Bills of
+Attainder" in Art. I, §§ 9-10, prohibit legislatures from singling out disfavored persons
+and meting out summary punishment for past conduct. See, e.g.. United States |
+Brown, 381 U.S. 437, 456-462, 85 S.Ct. 1707, 1719-1722, 14 L.Ed.2d 484 (1965). The
+Due Process Clause also protects the interests in fair notice and repose that may be
+compromised by retroactive legislation; a justification sufficient to validate a statute's
+prospective application under the Clause "may not suffice" to warrant its retroactive
+application. Usery |. Turner Elkhorn Mining Co., 428 U.S. 1, 17, 96 S.Ct, 2882, 2893,
+49 L.Ed.2d 752 (1976).
+FN19. Article I contains two Ex Post Facto Clauses, one directed to Congress (§ 9,
+cl. 3), the other to the States (§ 10, cl. 1). We have construed the Clauses as
+applicable only to penal legislation. See Calder |. Bull, 3 Dall. 386, 390-391, 1
+L.Ed. 648 (1798) (opinion of Chase, J.).
+These provisions demonstrate that retroactive statutes raise particular concerns. The
+Legislature's unmatched powers allow it to sweep away settled expectations suddenly
+and without individualized consideration. Its responsivity to political pressures poses a
+risk that it may be tempted to use retroactive legislation as a means of retribution
+against unpopular groups or individuals. As Justice Marshall observed in his opinion for
+**1498 the Court in Weaver . Graham, 450 U.S. 24, 101 S.Ct. 960, 67 L.Ed.2d 17
+(1981), the Ex Post Facto Clause not only ensures that individuals have "fair warning"
+about the effect of criminal statutes, but also "restricts governmental power by
+restraining arbitrary and potentially vindictive legislation." Id., at 28-29, 101 S.Ct., at
+963-964 (citations omitted). FNZ0
+FN20. See Richmond |. J. A. Croson Co., 488 U.S. 469, 513-514, 109 S.Ct. 706,
+732, 102 L.Ed.2d 854 (1989) ("Legislatures are primarily policymaking bodies that
+promulgate rules to govern future conduct. The constitutional prohibitions against
+the enactment of ex post facto laws and bills of attainder reflect a valid concern
+about. the use of the political process to punish or characterize past conduct of
+14
+
+
+private citizens. It is the judicial system, rather than the legislative process, that is
+best equipped to identify past wrongdoers and to fashion remedies that will create
+he conditions that presumably would have existed had no wrong been committed"
+(STEVENS, J., concurring in part and concurring in judgment); James . Unitea
+States, 366 U.S. 213, 247, n. 3, 81 S.Ct. 1052, 1052, n. 3, 6 L.Ed.2d 246 (1961)
+(retroactive punitive measures may reflect "a purpose not to prevent dangerous
+conduct generally but to impose by legislation a penalty against specific persons or
+classes of persons*).
+These well entrenched constitutional protections and presumptions against
+retroactive application of legislation establish that 18[
+• §2255 (2005) in effect at the
+time of the alleged conduct applies to the instant action, and not the amended version.
+B. Not only is there no clear express intent stating that the statute is to apply
+retroactively, but applying the current version of the statute, as amended in 2006, would
+be in clear violation of the Ex Post Facto Clause of the United States Constitution as it
+would be applied to events occurring before its enactment and would increase the penalty
+or punishment for the alleged crime. U.S. Const. Art. 1, §9, cl. 3, §10, cl. 1. U.S. |
+Seigel, 153 F.3d 1256 (11" Cir. 1998); U.S. |. Edwards, 162 F.3d 87 (3d Cir. 1998); and
+generally, Calder . Bull, 3 U.S. 386, 390, 1 L.Ed. 648, 1798 WL 587 (Calder) (1798).
+The United States Constitution provides that "InJo Bill of Attainder or ex
+post facto Law shall be passed" by Congress. U.S. Const. art. I, § 9, cl. 3. A law
+violates the Ex Post Facto Clause if it * *appli[es] to events occurring before its
+enactment ... [and] disadvantage[s] the offender affected by it' by altering the
+definition of criminal conduct or increasing the punishment for the crime."
+Lynce I. Mathis, 519 U.S. 433, 117 S.Ct. 891, 137 L.Ed.2d 63 (1997) (quoting
+Weaver |. Graham, 450 U.S. 24, 29, 101 S.Ct. 960, 67 L.Ed.2d 17 (1981)).
+U.S. |. Siegel, 153 F.3d 1256, 1259 (11" Cir. 1998).
+§2255 is contained in Title 18 of the United States Codes - "Crimes and Criminal
+Procedure, Part I. Crimes, Chap. 110. Sexual Exploitation and Other Abuse of Children."
+18
+§2255 (2005), is entitled Civil remedy for personal injuries, and imposes a
+presumptive minimum of damages in the amount of $50,000, should Plaintiff prove any
+15
+
+
+violation of the specified criminal statutes and that she suffered personal injury and
+sustained actual damages. Thus, the effect of the 2006 amendments, effective July 27,
+2006, would be to triple the amount of the statutory minimum previously in effect during
+the time of the alleged acts.
+The statute, as amended in 2006, contains no language stating that the application
+is to be retroactive.
+Thus, there is no manifest intent that the statute is to apply
+retroactively, and, accordingly, the statute in effect during the time of the alleged conduct
+is to apply. Landgraf |. USI Film Products, supra, at 1493, ("A statement that a statute
+will become effective on a certain date does not even arguably suggest that it has any
+application to conduct that occurred at an earlier date.").
+This statute was enacted as part of the Federal Criminal Statutes targeting sexual
+predators and sex crimes against children. H.R. 3494, "Child Protection and Sexual
+Predator Punishment Act of 1998;" House Report No. 105-557, 11, 1998
+678, 679 (1998). Quoting from the "Background and Need For Legislation" portion of
+the House Report No. 105-557, 11-16, H.R. 3494, of which 18|
+§2255 is included,
+is described as "the most comprehensive package of new crimes and increased penalties
+ever developed in response to crimes against children, particularly assaults facilitated by
+computers."
+Further showing that §2255 was enacted as a criminal penalty or
+punishment, "Title II - Punishing Sexual Predators," Sec. 206, from House Report No.
+105-557, 5-6, specifically includes reference to the remedy created under §2255 as an
+additional means of punishing sexual predators, along with other penalties and
+punishments. Senatorial Comments in amending §2255 in 2006 confirm that the creation
+of the presumptive minimum damage amount is meant as an additional penalty against
+16
+
+
+those who sexually exploit or abuse children. 2006 WL 2034118, 152 Cong. Rec. S8012-
+02. Senator Kerry refers to the statutorily imposed damage amount as "penalties." Id.
+The cases of U.S. |. Siegel, supra (11" Cir. 1998), and U.S. |. Edwards, supra (3d
+Cir. 1998), also support Defendant's position that application of the current version of 18
+• §2255 would be in clear violation of the Ex Post Facto Clause. In Siegel, the
+Eleventh Circuit found that the Ex Post Facto Clause barred application of the Mandatory
+Victim Restitution Act of 1996 (MVRA) to the defendant whose criminal conduct
+occurred before the effective date of the statute, 18 3664(Đ(1)(A), even though
+the guilty plea and sentencing proceeding occurred after the effective date of the statute.
+On July 19, 1996, the defendant Siegel pleaded guilty to various charges under 18
+§371 and §1956(a)(1)(A), (conspiracy to commit mail and wire fraud, bank fraud, and
+laundering of money instruments; and money laundering). He was sentenced on March
+7, 1997. As part of his sentence, Siegel was ordered to pay $1,207,000.00 in restitution
+under the MVRA which became effective on April 24, 1996. Pub.L. No. 104-132, 110
+Stat. 1214, 1229-1236. The 1996 amendments to MVRA required that the district court
+must order restitution in the full amount of the victim's loss without consideration of the
+defendant's ability to pay. Prior to the enactment of the MVRA and under the former 18
+. §3664(a) of the Victim and Witness Protection Act of 1982 (VWPA), Pub.I. No.
+97-291, 96 Stat. 1248, the court was required to consider, among other factors, the
+defendant's ability to pay in determining the amount of restitution.
+When the MVRA was enacted in 1996, Congress stated that the amendments to the
+VWPA "shall, to the extent constitutionally permissible, be effective for sentencing
+proceedings in cases in which the defendant is convicted on or after the date of enactment
+17
+
+
+of this Act [Apr. 24, 1996]." Siegel, supra at 1258. The alleged crimes occurred between
+February, 1988 to May, 1990. The Court agreed with the defendant's position that 1996
+MVRA "should not be applied in reviewing the validity of the court's restitution order
+because to do
+so would violate the Ex Post Facto Clause of the United States
+Constitution. See U.S. Const. art I, §9, cl. 3."
+The Ex Post Facto analysis made by the Eleventh Circuit in Siegel is applicable to
+this action. In resolving the issue in favor of the defendant, the Court first considered
+whether a restitution order is a punishment. Id, at 1259. In determining that restitution
+was a punishment, the Court noted that §3663A(a)(1) of Title 18 expressly describes
+restitution as a "penalty." In addition, the Court also noted that "[a]lthough not in the
+context of an ex post facto determination, ... restitution is a 'criminal penalty meant to
+have strong deterrent and rehabilitative effect.' United States |. Twitty, 107 F.3d 1482,
+1493 n. 12 (11th Cir.1997)." Second, the Court considered "whether the imposition of
+restitution under the MVRA is an increased penalty as prohibited by the Ex Post Facto
+Clause." Id, at 1259. In determining that the application of the 1996 MVRA would
+indeed run afoul of the Constitution's Ex Post Facto Clause, the Court agreed with the
+majority of the Circuits that restitution under the 1996 MVRA was an increased penalty?
+"The effect of the MVRA can be detrimental to a defendant. Previously, after considering
+the defendant's financial condition, the court had the discretion to order restitution in an
+amount less than the loss sustained by the victim. Under the MVRA, however, the court
+7 The Eleventh Circuit, in holding that "the MVRA cannot be applied to a person whose
+criminal conduct occurred prior to April 24, 1996," was "persuaded by the majority of
+Circuits. See U.S.. Futrell, 209 F.3d
+with the Second, Third, Eighth, Ninth, and
+1286, 1289-90 (11" Cir. 2000).
+18
+
+
+must order restitution to each victim in the full amount." Id, at 1260. See also U.S. |
+Edwards, 162 F.2d 87 (3" Circuit 1998).
+In the instant case, in answering the first question, it is clear that that imposition of
+a minimum amount of damages, regardless of the amount of actual damages suffered by a
+minor victim, is meant to be a penalty or punishment. See statutory text and House Bill
+Reports, cited above herein, consistently referring to the presumptive minimum damages
+amount under §2255 as "punishment" or "penalties." According to the Ex Post Facto
+doctrine, although §2255 is labeled a "civil remedy," such label is not dispositive; "if the
+effect of the statute is to impose punishment that is criminal in nature, the ex post facto
+clause is implicated." See generally, Roman Catholic Bishop of Oakland |. Superior
+Court, 28 Cal.Rptr:3d 355, at 360, citing Kansas |. Hendricks, 521 U.S. 346, 360-61
+(1997). The effect of applying the 2006 version of §2255 would be to triple the amount
+of the presumptive minimum damages to a minor who proves the elements of her §2255
+claim. The fact that a plaintiff proceeding under §2255 has to prove a violation of a
+criminal statute and suffer personal injury to recover damages thereunder, further
+supports that the imposition of a minimum amount, regardless of a victim's actual
+damages sustained, is meant and was enacted as additional punishment or penalty for
+violation of criminal sexual exploitation and abuse of minors.
+Accordingly, this Court is required to apply the statute in effect at the time of the
+alleged criminal acts. Not only is there no language in the 2006 statute stating that it is to
+apply retroactively, but further, such application of the 2006 version of 18
+• §2255
+to acts that occurred prior to its effective date would have a detrimental and punitive
+19
+
+
+effect on Defendant by tripling the presumptive minimum of damages available to a
+plaintiff, regardless of the actual damages suffered.
+As discussed above, 18
+§2255 was enacted as part of the criminal
+statutory scheme to punish and penalize those who sexually exploit and abuse minors,
+and thus, the Ex Post Fact Clause prohibits a retroactive application of the 2006 amended
+version. Even if one were to argue that the statute is "civil" and the damages thereunder
+are "civil" in nature, under the analysis provided by the United States Supreme Court in
+Landgraf |. USI Film Products, 511 U.S. 244, 114 S.Ct. 1483 (1994), pertaining to civil
+statutes, not only is there no express intent by Congress to apply the new statute to past
+conduct, but also, the clear effect of retroactive application of the statute would be to
+increase the potential liability for past conduct from a minimum of $50,000 to $150,000,
+and thus in violation of the constitutional prohibitions against such application. As noted,
+18
+§2255 is entitled "Civil remedy for personal injuries." Notwithstanding this
+label, the statute was enacted as part of the criminal statutory scheme to punish those who
+sexually exploit and abuse minors.
+Regardless of the actual damages suffered or proven
+by a minor, as long as a minor proves violation of a specified statutory criminal act under
+§2255 and personal injury, the defendant is held liable for the statutory imposed
+minimum.
+Notwithstanding the above legal analysis, in the recent case of Individual Known
+to Defendant As 08MIST096.JPG and 08mist067.jpg | Falso, 2009 WL. 4807537 (N.D.
+N.Y. Dec. 9, 2009), United States District Court for the Northern District of New York
+® Plaintiff has attempted to allege 6 counts pursuant to 18 L
+hes actual damages, the tabsurdy of antrodaine application is more magnified. dearly.
+er actual damages. '
+the result is an unconstitutional increase in either a penalty or civil liability.
+20
+
+
+addressed the issue of whether §2255 is a civil or criminal statute for purposes of the
+constitutional prohibition against double jeopardy.
+The New York Court stated that
+"looking to the plain language of §2255(a), it is clear that the statutory intent was to
+provide a civil remedy. This is exemplified by the title ... and the fact that the statute
+aims to provide compensation to individuals who suffered personal injury as a result of
+criminal conduct against them." The New York Court in analyzing whether §2255
+violated the Constitutional prohibition against double jeopardy, concluded that although
+the behavior to which §2255 is criminal, it did not find that the "primary aim" was
+"retribution and deterrence." "The statute serves civil goals." The "primary aim" is "the
+compensation for personal injuries sustained as a result of criminal conduct."
+Therefore, because
+Doe 103 has invoked the provisions of the criminal Non-
+Prosecution Agreement (NPA) between EPSTEIN and USAO (see paragraphs 25 and 26
+of complaint), plaintiff cannot avoid the full protection of the rule of lenity and due
+process to which EPSTEIN is entitled in the context of these unique factual
+circumstances.
+Although there does not exist any definitive ruling of whether the damages
+awarded under §2255 are meant as criminal punishment or a civil damages award,
+Defendant is still entitled to a determination as a matter of law that the statute in effect at
+the time of the alleged criminal conduct applies.
+As explained by the Landgraf court, supra at 280, and at 1505,?
+" In Landgraf, the United States Supreme Court affirmed the judgment of the Court of Appeals
+and refused to apply new provisions of the Civil Rights Act of 1991 to conduct occurring before
+the effective date of the Act. The Court determined that statutory text in question, §102, was
+subject to the presumption against statutory retroactivity.
+21
+
+
+When a case implicates a federal statute enacted after the events in suit, the court's
+first task is to determine whether Congress has expressly prescribed the statute's proper
+reach. If Congress has done so, of course, there is no need to resort to judicial default
+rules. When, however, the statute contains no such express command, the court must
+determine whether the new statute would have retroactive effect, i.e., whether it would
+impair rights a party possessed when he acted, increase a party's liability for past
+conduct, or impose new duties with respect to transactions already completed. If the
+statute would operate retroactively, our traditional presumption teaches that it does not
+govern absent clear congressional intent favoring such a result.
+Here, there is no clear expression of intent regarding the 2006 Act's application to
+conduct occurring well before its enactment. Clearly, however, as discussed in part B
+herein, the presumptive minimum amount of damages of $150,000 was enacted as a
+punishment or penalty upon those who sexually exploit and abuse minors. See discussion
+of House Bill Reports and Congressional background above herein. The amount triples
+the previous amount for which a defendant might be found liable, regardless of the
+amount of actual damages a plaintiff has suffered and proven. The new statute imposes a
+substantial increase in the monetary liability for past conduct.
+As stated in Landgraf, "the extent of a party's liability, in the civil context as well as
+the criminal, is an important legal consequence that cannot be ignored." Courts have
+consistently refused to apply a statute which substantially increases a party's liability to
+conduct occurring before the statute's enactment. Landgraf, supra at 284-85. Even if
+plaintiff were to argue that retroactive application of the new statute "would vindicate its
+purpose more fully," even that consideration is not enough to rebut the presumption
+against retroactivity. Id, at 285-86.
+"The presumption against statutory retroactivity is
+founded upon sound considerations of general policy and practice, and accords with long
+held and widely shared expectations about the usual operation of legislation." Id.
+Thus, Plaintiff's action should be dismissed and she should be required to plead her
+action under the applicable version of 18|
+• §2255.
+22
+
+
+Motion For More Definite Statement and To Strike, Rule 12(e) and (f),
+As noted above, Plaintiff alleges that she was 17 year old high school student as
+of January, 2004, and that the alleged conduct involving EPSTEIN. occurred "between
+approximately January 2004 and May 2005. Thus, Plaintiff had to be 18 (no longer a
+minor) by January of 2005. Under the principles of statutory construction, the language
+of §2255(a) is clear - "Any minor who is a victim of a violation of section ...of this title
+and who suffers personal injury as a result of such violation may sue in any appropriate
+United States District Court and shall recover the actual damages such minor sustains
+and the cost of the suit, including a reasonable attorney's fee. Any minor as described in
+the preceding sentence shall be deemed to have sustained damages of no less than
+$50,000 in value."
+As Plaintiff's date of birth is significant to her §2255 claim, she should be
+required to more definitely state her date of birth so that Defendant and this Court are
+able to determine precisely when she reached the age of majority. (The age of majority
+under both federal and state law is 18 years old. See 18
+. §2256(1), defining a
+"minor" as "any person under the age of eighteen years;" and §1.01, Definitions, Fla.
+Stat., defining "minor" to include "any person who has not attained the age of 18 years.")
+In addition, when Plaintiff reached the age of majority may impact her ability to even
+assert a §2255 claim. See §2255(b).
+To the extent that Plaintiff is relying on any alleged conduct that occurred after
+her 18 birthday as an element of her §2255 claim, such allegations should be stricken as
+immaterial and she should be required to more definitely state the dates of the alleged
+conduct. See Rule 12(f). Defendant also seeks to strike 1910, 11, 12, 13, 14, 15, and 16,
+23
+
+
+of Plaintiff's Complaint as immaterial and impertinent. None of the allegations in those
+paragraphs specifically pertain to the Plaintiff. Not until 917 does Plaintiff assert
+allegations pertaining to her and the conduct of Defendant directly involving her. What
+EPSTEIN may or may not have allegedly done with respect to other alleged girls does
+not effect Plaintiff's claim brought pursuant to §2255. The allegations in 9110-16 are not
+related to the elements of Plaintiff's §2255 claim and, thus, are required to be stricken.
+Conclusion
+Pursuant to the above, Plaintiff entire action is required to be dismissed. 18
+• §2255 allows for a single recovery of the actual damages sustained in proven;
+neither the "actual damages" sustained not the statutory minimum is subject to
+duplication or multiplication on a per violation or per count or per incident basis. Also,
+the statute in effect during the time of the alleged conduct applies, not the version as
+amended, effective July 27, 2006. Count VI is also required to be dismissed as it relies
+on a statutory predicate act that did not take effect until 2006. In addition, Plaintiff
+should be required to more definitely state her date of birth, and any conduct occurring
+after her 18" birthday should be stricken, and 9910 - 16 of the Complaint should also be
+stricken.
+WHEREFORE, Defendant requests that this Court dismiss the entire action
+against him, and further grant his motion for more definite statement and to strike.
+Robert D. Critton, Esq.
+Attorney for Defendant
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+with the Clerk of the Court using CM/ECF. Ї also certify that the foregoing document is
+24
+
+
+He macer hiday by all on of record dynified on the following. Service List in
+Robert. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street. Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+Counsel for Plaintiff
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Respectfully submitted,
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@belclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+npike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+1
+18 USCA §2255 (1999-July 26, 2006):
+PART I--CRIMES
+CHAPTER 110--SEXUAL EXPLOITATION AND OTHER ABUSE OF
+CHILDREN
+§ 2255. Civil remedy for personal injuries
+(a) Any minor who is a victim of a violation of section 2241(, 2242,
+2243, 2251, 2251A., 2252, 2252A, 2260, 2421, 2422, or 2423 of this title
+25
+
+
+and who suffers personal injury as a result of such violation may sue in
+any appropriate United States District Court and shall recover the actual
+lamages such minor sustains and the cost of the suit, including a
+reasonable attorney's fee. Any minor as described in the preceding
+sentence shall be deemed to have sustained damages of no less than
+$50,000 in value.
+(b) Any action commenced under this section shall be barred unless the
+complaint is filed within six years after the right of action first accrues or
+in the case of a person under a legal disability, not later than three years
+after the disability.
+CREDIT(S)
+(Added Pub.L.. 99-500, Title 1, § 101(b) [Title VII, § 703(a)], Oct. 18,
+1986, 100 Stat. 1783-75, and amended Pub.L.. 99-591, Title I, § 101(b)
+[Title VII, § 703(a)], Oct. 30, 1986, 100 Stat. 3341-75; Pub.L. 105-314,
+Title VI, § 605, Oct. 30, 1998, 112 Stat. 2984.)
+18
+$2255, as amended 2006, Effective July 27, 2006:
+PART I--CRIMES
+CHAPTER 110-SEXUAL EXPLOITATION AND OTHER ABUSE OF
+CHILDREN
+§ 2255. Civil remedy for personal injuries
+(a) In general.--Any person who, while a minor, was a victim of a violation
+of section 2241(D, 2242, 2243, 2251, 2251A, 2252, 2252A, 2260, 2421,
+violation, regardless of whether the injury persured while such person as a
+minor, may sue in any appropriate United States District Court and shall
+than $150,000 in value.
+(b) Statute of limitations.--Any action commenced under this section shall
+section Fist acres or in the cas of a person binder lear disabity, not aler
+than three years after the disability.
+CREDIT(S)
+(Added Pub.L. 99-500, Title I, § 101(b) [Title VII, § 703(a)), Oct. 18, 1986,
+100 Stat. 1783-75, and amended Pub.L, 99-591, Title I, § 101(b) [Title VII, §
+703(a)], Oct. 30, 1986, 100 Stat. 3341-75; Pub.L. 105-314, Title VI, § 605,
+26
+
+
+Oct. 30, 1998, 112 Stat. 2984; Pub.L.. 109-248, Title VII, § 707(b). (D. July
+27, 2006, 120 Stat. 650.)
+2 Paragraphs 30, 34, 38, 43, 48, and 52 of Plaintiff's Complaint alleges:
+30. As a direct and proximate result of the offenses enumerated in 18
+ast suffered, and will in the future continue to suffer, physical injury, pain ar
+offering, emotional distress, psychological and/or psychiatric trauma, ment
+and psychological expenses, and Plaintiff will in the future suffer additional medical
+and psychological expenses. Plaintiff has suffered a loss of income, a loss of the
+capacity to earn income in the future, and a loss of the capacity to enjoy life. These
+injuries are permanent in nature, and Plaintiff will continue to suffer these losses in
+The "Wherefore" clauses in each of the six counts are also identical -
+WHEREFORE Plaintiff demands judgment against Defendant for all damages
+available under 18
+§2255, including, without limitation, actual and
+compensatory damages, attorney's fees, costs of suit, and such other relief this Court
+deems just and proper, and hereby demands trial by jury on all issues triable as of
+right by a jury.
+27
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/c9d8fa7b5d5620b4dc96452491d999f6c86f8588cbf71d702e879bedb546a895.receipt.json b/vision-fixhub/ds9-unparsed-05/c9d8fa7b5d5620b4dc96452491d999f6c86f8588cbf71d702e879bedb546a895.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..95799e85c5e20c36ad68620383d8e95057604f78
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c9d8fa7b5d5620b4dc96452491d999f6c86f8588cbf71d702e879bedb546a895.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -6846,
+  "dataset": "marble-joined",
+  "doc_id": "c9d8fa7b5d5620b4dc96452491d999f6c86f8588cbf71d702e879bedb546a895",
+  "engine": "marble-apple-vision",
+  "event_count": 157,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "a31b5da7b868d8d5ae2a06cdace6c1901bdfcbff5311eb059c5eafef9edb6579",
+  "output_sha256": "a1d5c3dd0d7dfaa6c594a90a276c05f26db9cbfa5291f4d91372e2fee56da1ec",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/c9e60250d198de6ab996831b6e8853ae87dbc933e04c7567ef56a8047fd2038b.md b/vision-fixhub/ds9-unparsed-05/c9e60250d198de6ab996831b6e8853ae87dbc933e04c7567ef56a8047fd2038b.md
new file mode 100644
index 0000000000000000000000000000000000000000..dbf9ca7448400da8b9b20939ea19d263d5a755ea
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c9e60250d198de6ab996831b6e8853ae87dbc933e04c7567ef56a8047fd2038b.md
@@ -0,0 +1,1692 @@
+Statements
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summay...........................
+Transaction Detail
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 31, 2002
+1
+2
+Hollandlol
+HERITAGE INTERESTS
+FINANCIAL TRUST CO TEE
+DTD 7-30-91
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Funds Deposited
+Amount Credited
+Miscellaneous
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+....
+5,863.76
+$5,863.76
+-5,863.76
+5.5.863.76
+50.00
+Income Summary
+THIS PERIOD
+Dividends
+0.00
+Credit Balance Int.
+0.00
+Total
+$0.00
+YEAR TO DATE
+41,410.63
+1,830.90
+*....
+$43,241.53
+ease report any difference or non-receipt of chacks or stocks, indicated as delivered to you
+Client Services at 800-634-1428; or write to Cient Services at Bear, Stoams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four or ratanal purpose red de Set revere date for portant iformation.
+08/31/02;13:23 001
+
+
+2 org
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+08/02/02
+TOTAL
+TRANSACTION
+DEPOSIT
+MISCELLANEOUS
+DATE
+MO/DAY
+08/02/02
+TOTAL
+TRANSACTION
+JOURNAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+SE IT ABEIN CORP OO HERIT
+DEBIT AMOUNT
+DESCRIPTION
+PER LOA
+DEBIT AMOUNT
+5,863.76
+$-5,863.76
+STOP
+****** End of Statement******
+027
+CREDIT AMOUNT
+5,863.76
+$5,863.76
+CREDIT AMOUNT
+08/31/02;13:23 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 31, 2002
+V566
+
+
+3 of 3
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+08/31/02;13:23 001
+V566
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary .............................
+Transaction Detail
+Fund Activity ....
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 26, 2002
+3
+4
+4
+Hollandlold
+HERITAGE INTERESTS
+FINANCIAL TRUST CO TTEE
+DTD 7-30-91
+*
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+5,764,642
+-5,764,642
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent - 80,
+$5.764,642
+Last statement's market value
+Please report any diference or non-receipt of chacks or stocks, indicated as delivered to you
+o Client Services at 800 634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3659.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+This statement should he retained for your records. See revere cide for imortant intomat
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or 5
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Funds Deposited
+Dividends/Interest
+Miscellaneous
+THIS PERICO
+533,397.94
+6,004,972.33
+10,452,624.91
+611.94
+232,910.00
+Amount Credited
+Money Fund
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+$16,691,119.18
+-258,716.24
+-16,465,800.88
+,5-16.724-517.12
+-33,397.94
+$0.00
+Same day tansfers of cash between acount lypes are not included in this
+section; such transfers, as well as details for all other transactions this period,
+appear in Transaction Detail.
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+33,397.94
+$33,397.94
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+15,011.95
+611.94
+$15,623.89
+027
+CLOSING
+0.00
+$0.00
+-....
+YEAR TO DATE
+41,410.63
+1,830.90
+$43.241.53
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD April 27, 2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 26,2002
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+4 of 5
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+05/23/02
+TRANSACTION
+FUNDS REC
+DESCRIPTION
+FNDS WIRED TO CITIBANK FROM
+BANKERS NYC
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MODAY
+04/27/02
+05/01/02
+TRANSACTION
+DESCRIPTION
+OPENINGBALANCE
+DIVIDEND
+REYFUS CASH MANAGEMENT-CL
+NSTITUTIONAL SHARE.
+MONTHLY DIVIDEND
+05/01/02
+REINVEST
+REYFUS CASH MANAGEMENT-CL
+STITUTIONAL SHARE
+DIVIDEND REINVESTED
+05/15/02 BOUGHT
+PRENTINA SMANAGEMENFCLA
+05/23/02 SOLD
+05/24002 BIVIBEND
+PRETTINE SANAGEMENICLA
+05/31/02
+TOTAL
+CLOSINGBALANCE
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 26, 2002
+DEBIT AMOUNT
+CREDIT AMOUNT
+10.452.624.91
+$10,452,624.91
+SYMBOUGUSIP
+BICX
+DICXX
+QUANTITY
+5,731,244.14
+8,716.24
+250,000
+5.989,960.38
+0.00
+PRICE
+DEBIT AMOUNT
+CREDIT AMOUNT
+*8,716.24
+8.716.24
+250,000.00
+1.0000
+1.0000*
+$-258,716.24
+5,989,960.38
+/6,295.71
+$6,004,972.33
+027
+
+
+5 or 5
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+05/21/02
+INTEREST ON CREDIT BALANCE
+AT 1 1/4% 04/21 THRU 05/20
+05/24/02
+.....
+PREPAY CREDIT INT 5/21/02*
+TOTAL
+05/23/2
+MISCELLANEOUS
+DATE
+MO/DAY
+05/14/02
+TRANSACTION
+JOURNAL
+DESCRIPTION
+FROM:
+SIDE POCKET WITHDRAWAL
+* JRL *
+05/21/02
+JOURNAL
+JOURNAL FROM TYPE 2 TO 1
+05/21702*1
+•''TOURNAL FROM TYPE 2101
+05/24/02
+JOURNAL"
+PER LOA
+TOTAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOL/CUSIP
+QUANTITY
+RATE (%)
+1.2500
+STOP
+****** End of Statement******
+027
+DEBIT AMOUNT
+CRECIT AROUNT
+232,910.00
+232,910.00
+$465,820.00
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 26,2002
+CREDIT AMOUNT
+39.31
+...
+572.63
+$611.94
+DEBIT AMOUNT
+'232,910.00"
+16,465,800.88
+$-16,698,710.88
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail .................................
+Fund Activity .......••••••••••••••••••••III••IIII
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 28, 2002
+3
+5
+Hollandlold
+HERITAGE INTERESTS
+FINANCIAL TRUST CO TTEE
+DTD 7-30-91
+*
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+....
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+33,398
+5,731,244
+$5,764,642
+5,905,571
+- 140,929
+There are no 'Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+$5.764,642
+$5.905.571
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+04/27/02;12:01 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+04/27/02;12:01001
+
+
+3 of 5
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+THIS PERICO
+Opening Balance
+5183.304.80
+Money Fund
+8,977.76
+Dividends/Interest
+93.14
+Amount Credited
+$9,070.90
+.........
+Money Fund
+-8,977.76
+Funds Withdrawn
+-150,000.00
+Amount Debited
+......... 158.977.76
+Net Cash Activity
+-149,906.86
+Closing Balance
+533,397.94
+ne day transfers of cash between account types are not included in t
+tion: such transfers, as well as details for all other transactione this peri
+appear in Transaction Detail.
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+182,892.38
+412.42
+$183,304.80
+Income Summary
+Dividends
+Credit Balance Int.
+Total.
+THIS PERIOD
+8,977.76
+93.14
+$9,070.90
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+027
+CLOSING
+33,397.94
+0.00
+.........
+$33,397.94
+YEAR TO DATE
+26,398.68
+1,218.96
+....
+27,617.6
+5,764,642
+......
+$5.764,642
+04/27/02;12:01 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 28,2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debit balance and'or short
+
+
+4 of 5
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+DESCRIPTION
+CASH BALANCE
+.......
+DREYFUS CASH MANAGEMENT-CLA
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+DICCX
+QUANTITY
+5,731,244.14
+PRICE
+1.0000
+MARKET
+VALUE
+33,398
+5,731,244
+$5,764,642
+ESTIMATED
+ANNUAL INCOME
+108,894 1.9000
+$108,894
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+$108,894
+$5,764,641
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+04/01/02
+TRANSACTION
+FND WIRED
+DESCRIPTION
+TOTAL
+DEBIT AMOUNT
+150,000.00
+$-150,000.00
+CREDIT AMOUNT
+027
+04/27/02;12:01 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 28, 2002
+
+
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+5 ors
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+03/29/02
+64/01702 DIVIDEND
+04/01/02
+""REINVEST
+DESCRIPTION
+OPENINGBALANCE
+PREYFUS CASH MANAGEMENT-CLA
+MONTHLY DIVIDEND
+..•.....
+04/26/02
+TOTAL
+CLOSINGBALANCER
+INTEREST
+DATE
+DESCAIPTION
+0422102 AT AT 0321 EUR ONCE
+TOTAL
+SYMBOL/CUSIP
+MISCELLANEOUS
+TRANSACTION
+04/10/02
+JOURNAL
+4/10/02 TURNAL
+DURNA
+TOTAL
+DESCRIPTION
+JOURNAL FROM TYPE 2 TO 1
+............
+URNAL FROM TYPE 2 TO 11
+SYMBOUCUSIP
+DICCX
+QUANTITY
+QUANTITY
+5,722,266.38
+8,977.76
+5,731,244.14
+RATE (%)
+1.2500
+PRICE
+DEBIT AMOUNT
+DEBIT AMOUNT
+412.42
+$-412.42
+027
+CRECIT AMOUNT
+412.42
+$412.42
+04/27102;12:01 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 28,2002
+DEBIT AMOUNT
+CREDIT AMOUNT
+8,977.76
+8,977.76
+$-8,977.76
+$8,977.76
+CREDIT AMCUNT
+93.14
+$93.14
+VS57
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN, IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary •••••••••••I
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .........................................
+Your Messages
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+February 22,2002
+3
+4
+Hollandlold
+HERITAGE INTERESTS
+FINANCIAL TRUST CO TTEE
+DTD 7-30-91
+*
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+183,305
+5,722,266
+65,905,571
+5,897,098
+8,473
+oh sel apen orstes on i re your ator pending bury
+Market Value of Your Portfolio
+Cash & Equivalent
+$5.905,571
+$5.897,098
+Current market value
+Last statement's market value
+Flease raport any dierence or non-receipt of chacks or stocks, indicated as delivered to you,
+to Client Services at 800 634-1428; or Writa to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+
+
+2 of 6
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited.
+Net Cash Activity
+Closing Balance,
+THIS PERICO
+5183,126.76
+8,295.31
+178.04
+$8,473.35
+•........
+-8,295.31
+$-8,295.31
+.........
+178.04
+......
+$183.304.80
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+8,295.31
+178.04
+$8,473.35
+Portfolio Composition
+Cash/Cash Equivalent
+Tota
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+182,714.34
+412.42
+$183,126.76
+CLOSING
+182,892.38
+412.42
+.......
+183,304.80
+... ...
+027
+YEAR TO DATE
+17,420.92
+1,125.82
+---.
+518,546.74
+5,905,571
+85.905.571
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+February 22, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+100%
+Unshaded portions denole debt balance and'or short
+market values. The alocation percentage is derived
+
+
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+... .
+DREYFUS CASH MANAGEMENT-CLA
+TOTAL CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+DICCX
+QUANTITY
+5,722,266.38
+PRICE
+1.0000
+MARKET
+VALUE
+183,305
+5,722,266
+$5,905,571
+NINUAL INCON
+97,279
+1.7000
+$97,279
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+$97,279
+$5,905,570
+Transaction Detail
+MONEY FUND ACTIVITY
+TRANSACTION
+02/23/02
+03/01702BIVBEND
+03/01102 "REINVEST
+DESCRIPTION
+OPENINGBALANCE
+PRETEN SAAGEMENFCL A
+MONTHLY DIVIDEND
+RAYONA SANAGEMENTEC A
+DIVIDEND REINVESTEL
+SYMBOUCUSIP
+DICC
+DiCCX*
+QUANTITY
+5,713,971.07
+8.295.31
+PRICE
+027
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+February 22, 2002
+DEBIT AMOUNT
+CREDIT AMOUNT
+8,295.31
+8.295.31
+VSSS
+
+
+5 of 8
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MONDAY
+03/28/02
+TOTAL
+TRANSACTKN
+DESCRIPTION
+CLOSINGBALANCE
+INTEREST
+DATE
+03/21/02
+TOTAL
+DESCRIPTION
+INTEREST ON CREDIT BALANCE
+AT 1 1/4% 02/21 THRU 03/20
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUCUSIP
+SYMBOL/CUSIP
+QUANTITY
+QUANTITY
+5,722,266.38
+RATE (%)
+1.2500
+027
+PRICE
+DEBIT AMOUNT
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+February 22, 2002
+DEBIT AMOUNT
+CREDIT AMOUNT
+$-8,295.31
+$8,295.31
+CREDIT AMOUNT
+178.04
+$178.04
+
+
+6 of 6
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+Your messages
+138
+Pursuant to SEC Rule 11Ac1-6, Bear, Stearns & Co, Inc will
+publicly post its quarterly routing statistics at the following web link
+ttp://www.bearstearns.com/corporate/business/equities/orp.htr
+STOP
+****** End of Statement******
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+February 22,2002
+Bear, Stearns Securities Corp, Net Capital and Net Capital
+Requirements:
+At November 30, 2001 and January 31, 2002, the Company's net
+capital of approximately $2,6 billion and $2,6 billion was
+approximately 9% and 8% of aggregate debit items and exceeded
+the minimum regulatory net capital requirement of approximately
+$604.1 million and $648,0 million by approximately $2.0 billion and
+$2.0 billion, all respectively.
+A complete copy of the Bear, Stearns Securities Corp. Statement
+of Financial Condition is available on the web site
+www.bearstearns.com,
+Alternatively, to request a free printed copy
+please call -toll free 1-866-299-9331,
+027
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary •••••••••••I
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .....
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+January 25, 2002
+3
+4
+4
+4
+Hollandlold
+HERITAGE INTERESTS
+FINANCIAL TRUST CO TTEE
+DTD 7-30-91
+*
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+183,127
+5,713,971
+$5,897,098
+5,887,775
+9,323
+There are no 'Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+$5.897,098
+$5.887.775
+Current market value
+Last statement's market value
+Flease raport any dierence or non-receipt of chacks or stocks, indicated as delivered to you,
+to Client Services at 800-634.1428; or writa to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3659.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+02/23/02;10:07 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+02/23/02;10:07 001
+
+
+3 of 5
+Cash Flow Analysis
+THIS PERIOD
+Opening Balance
+3182.305.22
+Money Fund
+8,500.61
+Dividends/Interest
+821.54
+Amount Credited
+$9,322.15
+•........
+Money Fund
+-8,500.61
+Amount Debited
+38.500-61
+Net Cash Activity
+821.54
+Closing Balance.
+.5183.126.76
+Same day tansfers of cash between acount types are not included in this
+section; such transfers, as wall as details for all other transactions this period,
+appear in Transaction Detal.
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Balance Summary
+Cash
+Margin
+Short
+Nor Cash Balanco
+OPENING
+181,892.80
+0.00
+412.42
+.5132.30.22
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+9,125.61
+196.54
+$9.322.15.
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+027
+CLOSING
+182,714.34
+412.42
+0.00
+5183.26.76
+YEAR TO DATE
+9,125.61
+947.78
+.....
+$10,073.39
+5,897,098
+55.897.098
+02/23/02;10:07 001
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+January 25, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+4 of 5
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+.......
+DREYFUS CASH MANAGEMENT-CLA
+INST ARE 1000%
+TOTAL CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+DICCX
+QUANTITY
+5,713,971.07
+PRICE
+1.0000
+MARKET
+VALUE
+183,127
+5,713,971
+$5,897,098
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+ANUAL INCON
+LET NOT CON
+*********-*****..
+114,279 2.0000
+$114,279
+$114,279
+$5,897,097
+Transaction Detail
+MONEY FUND ACTIVITY
+TRANSACTION
+01/26/02
+02/01702 BIMBEND
+Ö2/01102 "REINVEST
+DESCRIPTION
+OPENINGBALANCE
+PRETEN SAAGEMENFCL A
+MONTHLY DIVIDEND
+RAYONA SANAGEMENTEC A
+DIVIDEND REINVESTED
+SYMBOUGUSIP
+DICCX
+QUANTITY
+5,705,470.46
+8.500.61
+PRICE
+027
+02/23/02;10:07 001
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+January 25, 2002
+DEBIT AMOUNT
+CREDIT AMOUNT
+8,500.61
+8.500.61
+
+
+5 or 5
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MODAY
+02/22/02
+TOTAL
+TRANSACTKN
+DESCRIPTION
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+DESCRIPTION
+02/01/02
+TYCO INTERNATIONAL LTD
+REG 01/02/02 PAY 02/01/02
+TOTAL
+INTEREST
+DATE
+02/21/02
+TOTAL
+DESCRIPTION
+INTEREST ON CREDIT BALANC
+T 1 1/4% 01/21 THRU 02/2
+MISCELLANEOUS
+DATE
+MODAY
+TRANSACTION
+01/28/02
+JOURNAL
+1/28/02 JOURNAL
+OURNA
+TOTAL
+DESCRIPTION
+MARK TO MARKET
+* MARK TO MARKET SHORT POS
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUCUSIP
+QUANTITY
+5,713,971.07
+PRICE
+SYMBOUCUSIP
+TYC
+QUANTITY
+50,000
+RATE (S)
+0.0125
+DEBIT AMOUNT
+SYMBOUCUSIP
+QUANTITY
+RATE (%)
+1.2500
+DEBIT AMOUNT
+DEBIT AMOUNT
+412.42
+$-412.42
+027
+CREDIT AMOUNT
+412.42
+....
+$412.42
+02/23/02;10:07 001
+CLEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+January 25, 2002
+DEBIT AMOUNT
+CREDIT AMOUNT
+$-8,500.61
+$8,500.61
+CREDIT AMOUNT
+625.00
+$625.00
+CREDIT AMOUNT
+196.54
+$196.54
+VB27
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ••••••••••••
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .....
+Your Messages
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+December 31, 2001
+3
+5
+Hollandlold
+HERITAGE INTERESTS
+FINANCIAL TRUST CO TTEE
+DTD 7-30-91
+*
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+....
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+182,305
+5,705,470
+$5,887,775
+......
+8,411,593
+-2,523,818
+Cash & Equivalent
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Equities
+Market Value of Your Portfolio
+$5.887.775
+$5,466,593
+$0
+$2,945,000
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as delivered to you.
+to Client Services at 800-634-1428; or Write to Cient Services at Bear, Steams Securities
+Corp.. One Metrolech Center North, Brooklyn, N.Y. 11201-3659.
+SP The suren s four or ratanal purposes rear die Set revere date for portant iformation.
+
+
+2 of 6
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 ore
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+THIS PERICO
+Opening Balance
+$1,368,453.85
+Securities Sold
+2,749,103.71
+Money Fund
+2,407,331.37
+Dividends/Interest
+1,163.66
+Amount Credited
+....
+$5,157.598.74
+Money Fund
+4,007,331.37
+Funds Withdrawn
+-186,416.00
+Miscellaneous
+-2,150,000.00
+Amount Debited
+56.343.747.37
+Net Cash Activity
+-1,186,148.63
+Closing Balance
+$182.305.22
+Same day tansfers of cash between acount lypes are not included in this
+section; such transfers, as well as details for all other transactions this period.
+appear in Transaction Detail.
+Cash Balance Summary
+Cash
+Margin
+Short
+Not Cash Balance
+OPENING
+38,800.57
+1,329,652.30
+0.98
+51.368.453.85
+Income Summary
+THIS PERIOD
+Credit Balance Int.
+751.24
+Total
+.$751.24
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+027
+CLOSING
+181,892.80
+0.00
+412.42
+5182,305.22
+YEAR TO DATE
+751.24
+.........••.
+$751.24
+5,887,775
+35,87,775
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+December 31, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+... .
+DREYFUS CASH MANAGEMENT-CLA
+TOTAL CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+DICCX
+QUANTITY
+5,705,470.46
+1.0000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SEEMENT TRE
+01/08/02 01/03/02
+TRANSACTION
+SOLD
+01/09/02 01/04/02 SOLD*
+TOTAL
+DESCRIPTION
+TYCO INTERNATIONAL LTD
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+UNSOLICITED
+TYCO INTERNATIONIL C.......
+VG PRICE SHOWN-DETAILS ON RE
+CTUAL CONFIRM TO YOUR AGEN
+UNSOLICITED
+MARKET
+VALUE
+182,305
+5,705,470
+$5,887,775
+ANNUAL INCOME
+ESTIMATE CURRENT
+119,815 2.1000
+$119,815
+$119,815
+$5,887,775
+SABOUCUSP
+QUANTITY
+-25,000
+-25,000
+PRICE
+55.07460
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+December 31, 2001
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,375,341.84
+$2,749,103.71
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+5 of 8
+Transaction Detail (continued)
+DEPOSITS AND WITHDRAWALS
+D1T0BI02
+RANSACTION
+ND WIRE
+01/09/02
+*FND WIRED
+DESCRIPTION
+FNDS WIRED TO
+"INDS WIRED TO
+TOTAL
+$ COMING FROM DREYFUS
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+TRANSACTION
+01/01/02
+ö1702/02
+"REINVEST
+81702702 BIMBEND
+DESCRIPTION
+OPENINGBALANCE
+RESTINA"S MANAGEMENT-CLA
+DIVIDEND REINVESTED
+"RATE ASSEMENTECA
+AMT INCLUDED IN 2001 - 1099
+88769/02*008
+01/16/02
+BÖUGHT
+STIONS SHALNAGEMENFCLA
+01/25/02
+TOTAL
+CLOSINGBALANCE
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+December 31, 2001
+DEBIT AMOUNT
+36,416.00
+150,000.00
+$-186,416.00
+CREDIT AMOUNT
+SYMBOUCUSIP
+DiCCX"
+"DICCX
+QUANTITY
+4,098,139.09
+*7,331.37
+'2.400,000"
+4.000,000
+5,705,470.46
+PRICE
+DEBIT AMOUNT
+*7,331.37
+1:800
+1.0000
+4,000.000.00
+$-4,007,331.37
+CAEDIT AMOUNT
+7,331.37
+2,400,000:00
+$2,407,331.37
+027
+
+
+6 of 8
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+01/22/02
+INTEREST ON CREDIT BALANCE
+AT 1 1/4% 12/21 THRU
+12/30
+M7Z2/02 INTEREST ON CREDIT BALANCE
+T 1 1/4% 12/31 THRU 01/20
+01/22/02 SHTACCT FEE 12/21-01 2002
+TOTAL
+MISCELLANEOUS
+DATE
+MO/DAY
+TRANSACTION
+01/07/02
+JOURNAL
+ö1/07/02
+ÖUANAL"
+ö1/09(02
+JOURNAL
+0171/02
+"JUANAL"
+01/11002 JOURNAL
+TOTAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUCUSIP
+QUANTITY
+RATE (%)
+1.2500
+1.2500
+DESCRIPTION
+MARK TO MARKET
+"MARK TO MARKET SHORT POS"
+T0047-30185
+PER LOA
+JOURNAL FROM TYPE 2 10 1
+JOURNAL FROM TYPE 201"
+DEBIT AMOUNT
+0.98
+2,150,000.00
+,329,653.2
+$-3,479,654.26
+Your messages
+027
+DEBIT AMOUNT
+CRECIT AMOUNT
+0.98
+1,329,653.28
+$1,329,654.26
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+HERITAGE INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+December 31, 2001
+CREDIT AMOUNT
+62.74
+688.50
+41242
+$1,163.66
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/c9e60250d198de6ab996831b6e8853ae87dbc933e04c7567ef56a8047fd2038b.receipt.json b/vision-fixhub/ds9-unparsed-05/c9e60250d198de6ab996831b6e8853ae87dbc933e04c7567ef56a8047fd2038b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..21ea77c53a9738935db61c9ba420c395ab9a355d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/c9e60250d198de6ab996831b6e8853ae87dbc933e04c7567ef56a8047fd2038b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -2792,
+  "dataset": "marble-joined",
+  "doc_id": "c9e60250d198de6ab996831b6e8853ae87dbc933e04c7567ef56a8047fd2038b",
+  "engine": "marble-apple-vision",
+  "event_count": 32,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "7e4126e33faaa3b00068b1e2cf15f34fc99c6f4153f338d8bcd035d14ce9d40f",
+  "output_sha256": "8e26158cd2bca3017583060d95d4146578e8db1160b785618d5d3d69d1352bd0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ca13d89f6315f3bb2155408a199fdcf8a7b943d20f6edb48808f2d881ba50265.md b/vision-fixhub/ds9-unparsed-05/ca13d89f6315f3bb2155408a199fdcf8a7b943d20f6edb48808f2d881ba50265.md
new file mode 100644
index 0000000000000000000000000000000000000000..c4bd5c44b017cf84d6ab40c717afc38bb1ae4cf5
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ca13d89f6315f3bb2155408a199fdcf8a7b943d20f6edb48808f2d881ba50265.md
@@ -0,0 +1,286 @@
+Jeffrey Epstein craved big homes, elite friends - and, investigators say, underage girls
+
+GE PRINTTHIS
+PalmBeachPost.com
+Jeffrey Epstein craved big homes, elite friends- and,
+investigators say, underage girls
+By Andrew Marra
+UPDATED
+WEEKLY
+Palm Beach Post Staff Writer
+Monday, August 14, 2006
+Browse
+Specials
+& Deals
+From Local
+Dealerships
+WINGED GARGOYLES guarded the gate at Jeffrey Epstein's Palm Beach
+mansion. Inside, hidden cameras trolled two rooms, while the girls came and went.
+For the police detectives who sifted through the garbage outside and kept records of
+visitors, it was the lair of a troubling target.
+Autos
+PalmBeachPost.com
+Jeffrey Epstein
+Billionaire
+financier
+Jeffrey
+Epstein has
+been indicted
+for felony solicitation of
+prostitution by a grand
+jury following
+accusations by teen girls.
+• Past headlines
+Epstein, one of the most mysterious of the
+country's mega-rich, was known as much
+for his secrecy as for his love of fine things:
+magnificent homes, private jets, beautiful
+women, friendships with the world's elite.
+But at Palm Beach police headquarters, he
+was becoming known for something else:
+the regular arrival of teenage girls he hire
+to give him massages and, police say.
+More local news
+Epstein was different from most sexual
+Latest breaking news, photos and all of today's Post stories. abuse suspects; he was far more powerful
+Share This Story
+He counted among his friends former
+President Bill Clinton, Donald Trump and
+Prince Andrew, along with some of the most prominent legal, scientific and business minds in the
+country.
+When detectives started asking questions and teenage girls started talking, a wave of legal resistance
+followed.
+If Palm Beach police didn't know quite who Jeffrey Epstein was, they found out soon enough.
+http://palmbeachpost.printthis.clickability.com/pt/cpt?action=cpt&title=Jeffrey+Epstein+cra.. 1/2/2008
+
+
+Jeffrey Epstein craved big homes, elite friends - and, investigators say, underage girls
+
+Epstein, now 53, was a quintessential man of mystery. He amassed his fortune and friends quietly,
+always in the background as he navigated New York high society.
+When he first attracted notice in the early 1990s, it was on account of the woman he was dating:
+Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell.
+In a lengthy article, headlined "The Mystery of Ghislaine Maxwell's Secret Love," the British Mail on
+Sunday tabloid laid out speculative stories that the socialite's beau was a CIA spook, a math teacher, a
+concert pianist or a corporate headhunter.
+"But what is the truth about him?" the newspaper wondered. "Like Maxwell, Epstein is both flamboyant
+and intensely private."
+The media frenzy did not begin in full until a decade later. In September 2002, Epstein was flung into
+the limelight when he flew Clinton and actors Kevin Spacey and Chris Tucker to Africa on his private
+jet.
+Suddenly everyone wanted to know who Epstein was. New York magazine and Vanity Fair published
+lengthy profiles. The New York Post listed him as one of the city's most eligible bachelors and began
+describing him in its gossip columns with adjectives such as "mysterious" and "reclusive."
+Although Epstein gave no interviews, the broad strokes of his past started to come into focus.
+Building a life of extravagance
+He was born blue-collar in 1953, the son of a New York City parks department employee, and raised in
+Brooklyn's Coney Island neighborhood. He left college without a bachelor's degree but became a math
+teacher at the prestigious Dalton School in Manhattan.
+The story goes that the father of one of Epstein's students was so impressed with the man that he put him
+in touch with a senior partner at Bear Stearns, the global investment bank and securities firm.
+In 1976, Epstein left Dalton for a job at Bear Stearns. By the early 1980s, he had started J. Epstein and
+Co. That is when he began making his millions in earnest.
+Little is known or said about Epstein's business except this: He manages money for the extremely
+wealthy. He is said to handle accounts only of $1 billion or greater.
+It has been estimated he has roughly 15 clients, but their identities are the subject of only speculation.
+All except for one: Leslie Wexner, founder of The Limited retail chain and a former Palm Beacher who
+is said to have been a mentor to Epstein.
+Wexner sold Epstein one of his most lavish residences: a massive townhouse that dominates a block on
+Manhattan's Upper East Side. It is reported to have, among its finer features, closed-circuit television
+and a heated sidewalk to melt away fallen snow.
+That townhouse, thought to be the largest private residence in Manhattan, is only a piece of the
+extravagant world Epstein built over time.
+In New Mexico, he constructed a 27,000-square-foot hilltop mansion on a 10,000-acre ranch outside
+http://palmbeachpost.printthis.clickability.com/pt/cpt?action=cpt&title=Jeffrey+Epstein+cra... 1/2/2008
+
+
+Jeffrey Epstein craved big homes, elite friends - and, investigators say, underage girls
+
+Santa Fe. Many believed it to be the largest home in the state.
+In Palm Beach, he bought a waterfront home on El Brillo Way. And he owns a 100-acre private island in
+the Virgin Islands.
+Perhaps as remarkable as his lavish homes is his extensive network of friends and associates at the
+highest echelons of power. This includes not only socialites but also business tycoons, media moguls,
+politicians, royalty and Nobel Prize-winning scientists whose research he often funds.
+"Just like other people collect art, he collects scientists," said Martin Nowak, who directs the Program
+for Evolutionary Dynamics at Harvard University and was reportedly the recipient of a $30 million
+research donation from Epstein.
+Epstein is said to have befriended former Harvard President Larry Summers, prominent law Professor
+Alan Dershowitz, Donald Trump and New York Daily News Publisher Mort Zuckerman.
+And yet he managed for decades to maintain a low profile. He avoids eating out and was rarely
+photographed.
+"The odd thing is I never met him,"
+said Dominick Dunne, the famous chronicler of the trials and
+tribulations of the very rich. "I wasn't even aware of him," except for a Vanity Fair article.
+Epstein's friendship with Clinton has attracted the most attention.
+Epstein met Clinton as early as 1995, when he paid tens of thousands of dollars to join him at an
+intimate fund-raising dinner in Palm Beach. But from all appearances, they did not become close friends
+until after Clinton left the Oval Office and moved to New York.
+Epstein has donated more than $100,000 to Democratic candidates' campaigns, including John Kerry's
+presidential bid, the reelection campaign of New Mexico Gov. Bill Richardson and the Senate bids of
+Joe Lieberman, Hillary Rodham Clinton, Christopher Dodd and Charles Schumer.
+Powerful friends and enemies
+A Vanity Fair profile found cracks in the veneer of Epstein's life story. The 2003 article said he left Bear
+Stearns in the wake of a federal probe and a possible Securities and Exchange Commission violation. It
+also pointed out that Citibank once sued him for defaulting on a $20 million loan.
+The article suggested that one of his business mentors and previous employers was Steven Hoffenberg,
+now serving a prison term after "bilking investors out of more than $450 million in one of the largest
+Ponzi schemes in American history."
+As he amassed his wealth, Epstein made enemies in disputes both large and small. He sued the man who
+in 1990 sold him his multimillion-dollar Palm Beach home over a dispute about less than $16,000 in
+furnishings.
+A former friend claimed Epstein backed out of a promise to reimburse him hundreds of thousands of
+dollars after their failed investment in Texas oil wells. A judge decided Epstein owed him nothing.
+"It's a bad memory. I would rather not have ever met Jeffrey Epstein," said Michael Stroll, the retired
+http://palmbeachpost.printthis.clickability.com/pt/cpt?action=cpt&title=Jeffrey+Epstein+cra... 1/2/2008
+
+
+Jeffrey Epstein craved big homes, elite friends - and, investigators say, underage girls
+
+former president of Williams Electronics and Sega Corp. "Suffice it to say I have nothing good to say
+about him."
+Among the characteristics most attributed to Epstein is a penchant for women.
+He has been linked to Maxwell, a fixture on the high-society party circuits in both New York and
+London. Previous girlfriends are said to include a former Ms. Sweden and a Romanian model
+"He's a lot of fun to be with," Donald Trump told New York magazine in 2002. "It is even said that he
+likes beautiful women as much as I do, and many of them are on the younger side. No doubt about it,
+Jeffrey enjoys his social life."
+Investigation leads to Epstein
+Although he was not a frequenter of the Palm Beach social scene, he made his presence felt. Among his
+charitable donations, he gave $90,000 to the Palm Beach Police Department and $100,000 to Ballet
+Florida.
+In Palm Beach, he lived in luxury. Three black Mercedes sat in his garage, alongside a green Harley-
+Davidson. His jet waited at a hangar at Palm Beach International Airport. At home, a private chef and a
+small staff stood at the ready. From a window in his mansion, he could look out on the Intracoastal
+Waterway and the West Palm Beach skyline. He seemed to be a man who had everything.
+But extraordinary wealth can fuel extraordinary desires.
+In March 2005, a worried mother contacted Palm Beach police. She said another parent had overheard a
+conversation between their children.
+Now the mother was afraid her 14-year-old daughter had been molested by a man on the island.
+The phone call triggered an extensive investigation, one that would lead detectives to Epstein but leave
+them frustrated
+Palm Beach police and the state attorney's office have declined to discuss the case. But a Palm Beach
+police report detailing the criminal probe offers a window into what detectives faced as they sought to
+close in on Epstein.
+Detectives interviewed the girl, who told them a friend had invited her to a rich man's house to perform
+a massage. She said the friend told her to say she was 18 if asked. At the house, she said she was paid
+$300 after stripping to her panties and massaging the man while he masturbated.
+Police interview 5 alleged victims
+The investigation began in full after the girl identified Epstein in a photo as the man who had paid her.
+Police arranged for garbage trucks to set aside Epstein's trash so police could sift through it. They set up
+a video camera to record the comings and goings at his home. They monitored an airport hangar for
+signs of his private jet's arrivals and departures.
+They quickly learned that the woman who took the 14-year-old girl to Epstein's house was
+In a sworn statement at police
+http://palmbeachpost.printthis.clickability.com/pt/cpt?action=cpt&title=Jeffrey+Epstein+cra. 1/2/2008
+
+
+Jeffrey Epstein craved big homes, elite friends - and, investigators say, underage girls
+
+headquarters, T
+• then 18, admitted she had taken at least six girls to visit Epstein, all between the
+ages of 14 and 16. Epstein paid her for each visit, she said.
+During the drive back to her house,
+Cold detectives, "I'm like a Heidi Fleiss."
+Police interviewed five alleged victims and 17 witnesses. Their report shows some of the girls said they
+had been instructed to have sex with another woman in front of Epstein, and one said she had direct
+intercourse with him.
+In October, police searched the Palm Beach mansion. They discovered photos of naked, young-looking
+females, just as several of the girls had described in interviews. Hidden cameras were found in the
+garage area and inside a clock on Epstein's desk, alongside a girl's high school transcript.
+Two of Epstein's former employees told investigators that young-looking girls showed up to perform
+massages two or three times a day when Epstein was in town.
+They said the girls were permitted many indulgences. A chef cooked for them. Workers gave them rides
+and handed out hundreds of dollars at a time.
+One employee told detectives he was told to send a dozen roses to one teenage girl after a high school
+drama performance. Others were given rental cars. One, according to police, received a $200 Christmas
+bonus.
+The cops moved to cement their case. But as they tried to tighten the noose, they encountered other
+forces at work.
+In Orlando they interviewed a possible victim who told them nothing inappropriate had happened
+between her and Epstein. They asked her whether she had spoken to anyone else. She said yes, a private
+investigator had asked her the same questions.
+When they subpoenaed one of Epstein's former employees, he told them the same thing. He and a
+private eye had met at a restaurant days earlier to go over what the man would tell investigators.
+Detectives received complaints that private eyes were posing as police officers. When they told Epstein'
+ocal attorney, Guy Fronstin, he said the investigators worked for Roy Black, the high-powered Miam
+lawyer who has defended the likes of Rush Limbaugh and William Kennedy Smith.
+While the private eyes were conducting a parallel investigation, Dershowitz, the Harvard law professor,
+traveled to West Palm Beach with information about the girls. From their own profiles on the popular
+Web site MySpace.com, he obtained copies of their discussions about their use of alcohol and
+marijuana.
+He took his research to a meeting with prosecutors in early 2006, where he sought to cast doubt on the
+teens' reliability.
+The private eyes had dug up enough dirt on the girls to make prosecutors skeptical. Not only did some
+of the girls have issues with drugs or alcohol but also some had criminal records and other troubles,
+Epstein's legal team claimed. And at least one of them, they said, lied when she told police she was
+younger than 18 when she started performing massages for Epstein.
+http://palmbeachpost.printthis.clickability.com/pt/cpt?action=cpt&title=Jeffrey+Epstein+cra... 1/2/2008
+
+
+Jeffrey Epstein craved big homes, elite friends - and, investigators say, underage girls
+
+After the meeting, prosecutors postponed their decision to take the case to a grand jury.
+In the following weeks, police received complaints that two of the victims or their families had been
+harassed or threatened. Epstein's legal team maintains that its private investigators did nothing illegal or
+unethical during their research.
+By then, relations between police and prosecutors were fraying. At a key meeting with prosecutors and
+the defense, Detective
+the lead investigator, was a no-show, according to Epstein's
+attorney.
+"The embarrassment on the prosecutor's face was evident when the police officer never showed up for
+the meeting," attorney Jack Goldberger said
+Later in April,
+case was taking an unexpected turn.
+walked into a prosecutor's office at the state attorney's office and learned the
+The prosecutor, Lanna Belohlavek, told
+he state attorney's office had offered Epstein a plea
+deal that would not require him to serve jail time or receive a felony conviction.
+told her he disapproved of the plea offer.
+The deal never came to pass, however.
+Future unclear after charge
+On May 1, the department asked prosecutors to approve warrants to arrest Epstein on four counts of
+unlawful sexual activity with a minor and to charge his personal assistant.
+I now 27, for her
+alleged role in arranging the visits. Police officials also wanted to charge
+the self-described
+Heidi Fleiss, with lewd and lascivious acts.
+By then, the department was frustrated with the way the state attorney's office had handled the case. On
+the same day the warrants were requested, Palm Beach Police Chief
+wrote a letter to
+State Attorney Barry Krischer suggesting he disqualify himself from the case if he would not act.
+Two weeks later
+vas told that prosecutors had decided once again to take the case to the grand
+jury.
+It is not known how many of the girls testified before the grand jury. But Epstein's defense team said
+one girl who was subpoenaed
+- the one who said she had sexual intercourse with Epstein — never
+showed up.
+The grand jury's indictment was handed down in July. It was not the one the police department had
+wanted.
+Instead of being slapped with a charge of unlawful sexual activity with a minor, Epstein was charged
+with one count of telony solicitation of prostitution, which carries a maximum penalty of five years in
+prison. He was booked into the Palm Beach County Jail early July 23 and released hours later.
+Epstein's legal team "doesn't dispute that he had girls over for massages," Goldberger said. But he said
+their claims that they had sexual encounters with him lack credibility.
+http://palmbeachpost.printthis.clickability.com/pt/cpt?action=cpt&title=Jeffrey+Epstein+cra... 1/2/2008
+
+
+Jeffrey Epstein craved big homes, elite friends - and, investigators say, underage girls
+
+"They are incapable of being believed," he said. "They had criminal records. They had accusations of
+theft made against them by their employers. There was evidence of drug use by some of them."
+What remains for Epstein is yet to be seen.
+The Palm Beach Police Department has asked the FBI to investigate the case. It also has returned the
+$90,000 Epstein donated in 2004.
+In New York, candidates for governor and state attorney general have vowed to return a total of at least
+$60,000 in campaign contributions from Epstein. Meanwhile, Epstein's powerful friends have remained
+silent as tabloids and Internet blogs feast on the public details of the police investigation.
+Goldberger maintains Epstein's innocence but says the legal team has not ruled out a future plea deal. He
+insists Epstein will emerge in the end with his reputation untarnished.
+"He will recover from this," he said.
+Find this article at:
+http://www.palmbeachpost.com/localnews/content/local_news/epaper/2006/08/14/m1a_EPSTEIN_0814.htm
+• Check the box to include the list of links referenced in the article.
+http://palmbeachpost.printthis.clickability.com/pt/cpt?action=cpt&title=Jeffrey+Epstein+cra...
+1/2/2008
diff --git a/vision-fixhub/ds9-unparsed-05/ca13d89f6315f3bb2155408a199fdcf8a7b943d20f6edb48808f2d881ba50265.receipt.json b/vision-fixhub/ds9-unparsed-05/ca13d89f6315f3bb2155408a199fdcf8a7b943d20f6edb48808f2d881ba50265.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..afaac567c431bef669c3ecb7bfa7f211973813dc
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ca13d89f6315f3bb2155408a199fdcf8a7b943d20f6edb48808f2d881ba50265.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -161,
+  "dataset": "marble-joined",
+  "doc_id": "ca13d89f6315f3bb2155408a199fdcf8a7b943d20f6edb48808f2d881ba50265",
+  "engine": "marble-apple-vision",
+  "event_count": 14,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "ea160083839ff8b3bd987e44f7d9ec05149ca83cf951ec28d20af62a2d36c1a8",
+  "output_sha256": "ef1337f2ab7f77919ea100dc0e7b7c07d8ee38dd4938931a3a57fe6387a882dc",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ca2e9bd59038883eeb5f7e8095f1081bd57ecd0ac29e5fdcdb3b4b1cdd27c757.md b/vision-fixhub/ds9-unparsed-05/ca2e9bd59038883eeb5f7e8095f1081bd57ecd0ac29e5fdcdb3b4b1cdd27c757.md
new file mode 100644
index 0000000000000000000000000000000000000000..0e6313bcff167608c9cff0d1ec0cb3b4b6655644
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ca2e9bd59038883eeb5f7e8095f1081bd57ecd0ac29e5fdcdb3b4b1cdd27c757.md
@@ -0,0 +1,1649 @@
+Case 9:08-CV-80736-KAM Document 190 Entered on FLSD Docket 06/19/2013 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA
+JANE DOE #1 and JANE DOE #2,
+petitioners,
+FLEOM MaCI
+JUN 18 2013
+VS.
+UNITED STATES OF AMERICA,
+respondent.
+OMNIBUS ORDER
+THIS CAUSE is before the court on various motions.
+Upon consideration, it is ORDERED AND ADJUDGED:
+1. The petitioners' protective motion seeking recognition of the availability of various
+remedies attaching to the CVRA violations alleged in this proceeding [DE 128] is DENIED
+WITHOUT PREJUDICE to renew the request for any particular form of relief or remedy in
+connection with the court's final disposition of petitioners' CVRA petition on the merits.
+2. The intervenors' motion to strike the petitioners' supplemental authority regarding
+privilege claims [DE 177] is DENIED AS MOOT.
+3. The petitioners' sealed motion for the court to deny the government's motion to dismiss
+based on existing pleadings, or alternatively, for leave to file a sur-reply [DE 152] is DENIED AS
+MOOT.
+
+
+Case 9:08-CV-80736-KAM Document 190 Entered on FLSD Docket 06/19/2013 Page 2 of 3
+3. The petitioners' motion to compel discovery from the government [DE 130] is
+GRANTED. Within THIRTY (30) DAYS from the date of entry of this order, the government
+shall:
+a. File answers to all outstanding requests for admissions in the open court file;
+b. Produce responsive documents in response to all outstanding requests for production of
+documents encompassing any documentary material exchanged by or between the federal
+government and persons or entities outside the federal government (including without limitation all
+correspondence generated by or between the federal government and Epstein's attorneys), and
+c. Produce all other responsive documents in response to all outstanding requests for
+production of documents. To the extent any claim of privilege is asserted in connection with the
+production of any documents falling within this broader category of materials only (i.e. materials
+other than communications generated between the federal government and outside persons or
+entities), the government shall further:
+(i) contemporaneously file and serve, in the public portion of the court file, a privilege log
+clearly identifying each documents by author(s), addressee(s), recipient (s), date, and general subject
+matter and such other identifying data as required under Fed. R. Civ. P. 26.1 (g), and
+(ii) contemporaneously submit all responsive documents withheld on claim of privilege to
+the court for in camera inspection by submitting the same for filing with the court under seal.
+As to any documents falling into this broader category of materials (identified in 93.c.), and
+as to which the government has asserted claim of privilege with accompanying privilege log,
+petitioners shall have THIRTY (30) DAYS after service of the privilege log within which to file
+motion to compel contesting any asserted privilege claim, limited to SEVEN (7) PAGES in length,
+2
+
+
+Case 9:08-CV-80736-KAM Document 190 Entered on FLSD Docket 06/19/2013 Page 3 of 3
+and the government shall thereafter have FIFTEEN (15) DAYS after service of the petitioners's
+motion motion to file its response, if any, limited to SEVEN (7) PAGES in length. No further
+submissions on asserted privilege claims shall be entertained without the express invitation of the
+court.
+DONE AND ORDERED in Chambers at West Palm Beach, Florida this 18ª day of June,
+2013.
+Kenneth A. Marra
+United States District Judge
+cc. All counsel
+- SEALED
+NOT SEALED
+3
+
+
+2pend ps
+New York County Clerk's Index No. 30129/2010
+Mayll
+To be Argued By:
+TAY P. LEFKOWITZ
+Neur Hurk Supreme Cmurt
+APPELLATE DIVISION—FIRST DEPARTMENT
++
+PEOPLE OF THE STATE OF NEW YORK,
+-against-
+JEFFREY E. EPSTEIN,
+Respondent,
+Defendant-Appellant.
+BRIEF FOR DEFENDANT-APPELLANT
+JAY P. LEFKOWITZ
+SANDRA LYNN MUSUMECI
+KIRKLAND & ELLIS LLP
+601 Lexington Avenue
+New York, New York 10022
+jay.lefkowitz@kirkland.com
+sandra.musumeci@kirkland.com
+Attorneys for Defendant-Appellant
+REPRODUCED ON RECYCLED PAPER
+
+
+New York County Clerk's Index No. 30129/2010
+Neur Lurk Supreme Qmurt
+APPELLATE DIVISION-FIRST DEPARTMENT
+PEOPLE OF THE STATE OF NEW YORK,
+-against—
+JEFFREY E. EPSTEIN,
+Respondent,
+Defendant-Appellant.
+APPENDIX
+CYRUS R. VANCE, JR.
+NEW YORK COUNTY DISTRICT
+ATTORNEY'S OFFICE
+One Hogan Place
+New York, New York 10013
+danyappeals@dany.gov
+Attorneys for Respondent
+JAY P. LEFKOWITZ
+SANDRA LYNN MUSUMECI
+KIRKLAND & ELLIS LLP
+601 Lexington Avenue
+New York, New York 10022
+jay.lefkowitz@kirkland.com
+sandra.musumeci@kirkland.com
+Attorneys for Defendant-Appellant
+REPRODUCED ON RECYCLED PAPER
+
+To:
+Big JimLaw@aol.com/BiaJimLaw@aol.com];
+Subject:
+RE:
+Tue 10/24/2006 5:51:08 PM
+Villatana, Ann Marie C. (USAFLS)
+Hi Jim -- Thank you for the e-mail, and I will even forgive the football reference. I was
+just set for trial, so the earliest I will be able to reschedule the testimony will be after
+Thanksgiving. I will give you a call to discuss the immunity issue but I am concerned
+about other things we have talked about - if Ms.
+is given immunity, will she be
+forthcoming and answer the questions? Or am I going to jump through hoops to get her
+immunity and then have to worry about filing motions to compel, motions for orders to
+show cause why she shouldn't be held in contempt, etc., etc.?
+As always, thank you for your assistance.
+Regards,
+Marie
+A. Marie Villafaña
+Assistant U.S. Attorney
+561 209-1047
+ann.marie.c.villafana@usdoj.gov
+reed to redact
+portions
+- internal emails
+drafts
+From: BigJimLaw@aol.com [mailto:BigJimLaw@aol.com_
+Sent: Tuesday, October 24, 2006 12:00 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Re:
+Sorry I did not get back to you sooner. I have been out of town for several weeks. As
+to Miss
+she still does not wish to testify in this case and has a Fifth Amendment
+basis for her position. She wishes not to accept the "proffer letter " cover of immunity,
+which again is her right. I think it is a waste of time to have her appear Friday to just
+take the Fifth. I suggest that you huddle with your people. (It is football season). If
+you want to push the issue you will have to get formal immunity. I will accept service
+now and in the future for you so you don't have to chase
+down. Jim Eisenberg
+
+
+Villafana, Ann Marie C. (USAFLS)|/O=USA/OU=FLS/CN=RECIPIENTS/CN=AVILLAFANA];
+Subject:
+Fri 2/2/2007 2:36:10 PM
+BigJimLaw@aol.com
+I just wrote you a letter confirming that Ms.
+will be at the grand jury room with me. Please keep me
+informed as to the time. I must warn you, my leiter is critical of your office, although not at all critical of
+you. If you change your mind about forcing Ms
+nou have to make a rangemenab for cord care to be court hales, Jim isenball at once so she does
+
+
+To:
+Cc:
+Subject:
+Attachments:
+Lourie, Andrew (USAFLS)
+Tuesday, May 22, 2007 3:11 PM
+Menchel, Matthew (USAFLS); Sloman, Jeff (USAFLS)
+FW: Jeffrey Epstein
+2007-05-22 letter to AUSA Lourie.pdf
+Gentlemen,
+Marie and I have already met with Lefcourt, which is really the meeting | promised him. I spoke to him last week and he
+said he had more information they wanted to present. I told him he could make an appointment to come in again if he
+wanted to and that we would meet with him again, but I did not promise that we would wait to give him a meeting
+"before" we charged.
+So, I think he is really ready for the next level rather than a second meeting with me. Mike Tein also mentioned to me
+at some point that they wanted to make a presentation on the law and I suggested to him that he contact Matt without
+telling him exactly what stage of review we were at. I don't know if Tein and Lefcourt have crossed wires or not.
+In any event, 1 am forwarding this letter to you. I am going to suggest to Lefcourt the same thing that I suggested to
+Tein. I assume you would grant his attorneys a chance to make whatever presentation they desire. It would probably
+be helpful to us in any event to hear their legal arguments in case we have missed something. Whether Alex would be
+present or grant them another meeting after that is his call.
+Andy
+From: Gerald Lefcourt [mailto:GBL@lefcourtlaw.com]
+Sent: Tuesday, May 22, 2007 2:05 PM
+To: Lourie, Andrew (USAFLS)
+Cc: Villafana, Ann Marie C. (USAFLS); Lilly Ann Sanchez
+Subject: Jeffrey Epstein
+Andy, attached is a letter seeking meetings, as discussed with you, but with others if it is not resolved. Thanks for your
+attention. Could you email back so that I know you have received this letter?
+Gerald B. Lefcourt
+Gerald B. Lefcourt, P.C.
+148 E. 78th Street
+New York. New York 10021
+Tel.
+Fax
+gbl@lefcourtlaw.com
+153
+
+
+Villafana, Ann Marie C. (USAFS)
+To:
+Subject:
+Menchel, Matthew (USAFLS)
+Monday, May 14, 2007 10:52 AM
+Villafana, Ann Marie C. (USAFLS); Lourie, Andrew (USAFLS)
+Re: Operation Leap Year
+Marie,
+You will not have approval to go forward tomorrow with an indictment or to poceed
+by complaint.
+Alex has your memo and lefcourt's letter but he is out of the
+district at the US Attorney's conference for the next several days.
+I'm having trouble understanding - given how long this case has been pending -
+what the rush is.
+This is obviously a very significant case and alex wants to
+take his time making sure he is comfortable before proceeding.
+Sent from my BlackBerry Wireless Handheld
+-----Original Message-----
+From: Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov>
+To: Lourie, Andrew (USAFLS) <ALourie@usa.doj.gov›; Menchel, Matthew (USAFLS)
+<MMenchel@usa.doj.gov>
+Sent: Mon May 14 10:38:15 2007
+Subject: Operation Leap Year
+Good morning: I just received a call that Epstein's plane is flying from the
+Virgin Islands to Newark now, so it looks like Epstein is going to show up for
+his court appearance tomorrow. Can you let me know if the indictment is going
+tomorrow or, if not, whether we are authorized to proceed by Complaint?
+Thank you.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL
+33401
+Phone 561 209-1047
+179
+
+
+To:
+Subject:
+Lourie, Andrew (USAFLS)
+hursday, May 24, 2007 9:25 AI
+FW: Jeffrey Epstein
+Please put in your file. thx
+From: Gerald Lefcourt [mailto: GBL@lefcourtlaw.com]
+Sent: Wednesday, May 23, 2007 5:00 PM
+To: Lourie, Andrew (USAFLS)
+Subject: RE: Jeffrey Epstein
+Thanks for the email. I will get back to you as to timing of the meeting.
+Gerald B. Lefcourt
+Gerald B. Lefcourt, P.C.
+148 E. 78th Street
+New York, New York 10021
+Tel.
+Fax
+gbl@lefcourtlaw.com
+From: Lourie, Andrew (USAFLS) [mailto:Andrew.Lourie@usdoj.gov]
+Sent: Tuesday, May 22, 2007 6:32 PM
+To: Gerald Lefcourt
+Subject: RE: Jeffrey Epstein
+I have your letter. I think we are on the same page, but to be sure | do want to clarify that we spoke the other week and
+I did say that if you want to meet with me again, I am ready to do so. The wording of your letter, however, suggests
+implicitly that I agreed to contact you before a decision is made to seek an indictment of Mr. Epstein. If that was your
+understanding, then please allow me to clarify. Our investigation is ongoing and if we decide to seek an indictment, we
+don't intend to call Mr. Epstein's representatives to let him know that. Of course, in the interim, if you would like to
+make a presentation to us, we are willing to listen.
+Along those lines, given the fact that we have already met once, with schedules being what they are, it makes sense for
+our criminal chief, Matt Menchel, to be included when you make another presentation, rather than working up the
+chain incrementally. I realize you were being respectful in not attempting to leapfrog over me, which I appreciate. |
+will pass on your request to meet with the U.S. Attorney as well, but can't commit for him one way or another. When
+you have some dates in mind, let me know and I will try to set up a meeting in Miami.
+From: Gerald Lefcourt [mailto:GBL@lefcourtlaw.com]
+Sent: Tuesday, May 22, 2007 2:05 PM
+To: Lourie, Andrew (USAFLS)
+Cc: Villafana, Ann Marie C. (USAFLS); Lilly Ann Sanchez
+Subject: Jeffrey Epstein
+141
+
+
+Andy, attached is a letter seeking meetings, as discussed with you, but with others if it is not resolved. Thanks for your
+attention. Could you email back so that I know you have received this letter?
+Gerald B. Lefcourt
+Gerald B. Lefcourt, P.C.
+148 E. 78th Street
+New York, New York 10021
+Tel.
+Fax
+gbl@lefcourtlaw.com
+142
+
+
+To:
+Monday, June 18, 2007 5:04 PM
+Menchel, Matthew (USAFLS); Sloman, Jeff (USAFLS); Lourie, Andrew (USAFLS); Atkinson,
+Karen (USAFLS)
+Subject:
+I just received a call from the FBI telling me that Vanity Fair is sniffing around again. The reporter is a former
+letective. He told the FBI agent that his sources tell him "the State has been bought off," and asked if our
+investigation had been sent to "the circular file." Nesbitt responded, "All I can tell you is that we have an oper
+investigation."
+On another note, 1 am going to see the grand jury tomorrow and 1 anticipate a number of questions regarding the
+status of the indictment. I'm not sure what, if anything, I can tell them.
+And I did not hear back regarding making changes to the indictment. Can I get some feedback on that?
+Thank you.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+128
+
+
+To:
+Subject:
+Thursday, June 21, 2007 3:24 PM
+Menchel, Matthew (USAFLS)
+RE: Meeting Next Week
+Sounds good. I will stop by on Monday afternoon. Could you just let you assistant know that I may be
+stopping by to get a copy of whatever the defense sends over?
+Thanks.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+From: Menchel, Matthew (USAFLS)
+Sent: Thursday, June 21, 2007 2:58 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Cc: Lourie, Andrew (USAFLS)
+Subject: RE: Meeting Next Week
+Meeting on Monday is fine. I have meetings with Alex and Jeff till around 11 but after that I'm free. As for who is going
+to be at the meeting from our side, I thought you, me, Andy, and Jeff. I thought it best to leave Alex out of it at this
+venture. As for the Epstein camp, I'm not entirely sure because I don't think Lily was sure last time we spoke. Probably
+her, Lefcourt, Black and maybe Lewis.
+Lily told me that they wanted to present something in writing before the meeting which was why she was pushing us for
+the statutes. I view the meeting more as us listening and them presenting their position so | would say that you don't
+need to prepare anything (you are quite knowledgeable on the law in any event) but if you disagree we can discuss on
+Monday. As for the documents that they have yet to produce, I'II mention it to Lily if you like or we can raise it with
+them at the Tuesday meeting.
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Thursday, June 21, 2007 1:37 PM
+To: Menchel, Matthew (USAFLS)
+Cc: Atkinson, Karen (USAFLS); McMillan, John (USAFLS); Lourie, Andrew (USAFLS); Sloman, Jeff (USAFLS)
+Subject: Meeting Next Week
+Importance: High
+Hi Matt: I would like to prepare for next week's meeting, and I am wondering if you can tell me who will
+attend, both from our side and for Mr. Epstein. I am hoping that we can meet on Monday to discuss any issues
+and/or strategy before the meeting on Tuesday, so please let me know when you will be available on Monday.
+114
+
+
+Also, if there are any issues that you would like me to be prepared to address - either with you on Monday or
+with defense counsel on Tuesday - please give me a list and I will bring the appropriate items with me.
+Since Lilly has been communicating with you directly about the meeting, and I have given them the list of
+statutes that they have requested, perhaps you could ask her to reciprocate by providing us with their written
+analysis (or documents they want us to consider) prior to the meeting so we can address any issues then and
+there. Also, during a previous meeting, I asked Lilly and Gerry for copies of Epstein (or his assistants') agendas
+and calendars to show that, as they claim, Epstein's travels to Florida were consciously coordinated so that he
+could maintain his Florida residency for tax purposes. Lilly said she would try to get them to us, but has never
+done so. I have subpoenaed all of the corporate entities with which Epstein is affiliated and they all claim that
+they do not have any responsive documents.
+I will plan to be in Miami by around 10:00 on Monday morning, so any time after that is fine.
+Thank you.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+115
+
+
+To:
+Cc:
+Subject:
+Tuesday, July 03, 2007 6:26 AM
+Sloman, Jeff (USAFLS); Menchel, Matthew (USAFLS); Lourie, Andrew (USAFLS)
+Atkinson, Karen (USAFLS); Ball, Shawn (USAFLS)
+Epstein
+Importance:
+High
+I have received a couple of calls and an e-mail from Lilly Ann Sanchez asking for an extension of time to
+respond to several subpoena. She also states that they intend to provide us with a "supplement" to their
+presentation and what they believe will be their resolution with the state. I intend to send a response stating that
+the subpoenas for financial documents can be put off, but we want to get the computer equipment that was
+removed from Epstein's home prior to the state search warrant as soon as possible. I also intend to invite her to
+call me to discuss a resolution of the federal investigation that could include concurrent time.
+If anyone has communicated anything to any of Epstein's attorneys that is contrary to this, please contact my
+assistant, Shawn Ball, as soon as possible. I have asked Shawn to send out the e-mail while 1 am in trial. You
+will all receive a copy of the e-mail when it is sent.
+Thank you.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+106
+
+
+To:
+Subject:
+Friday, July 13, 2007 3:14 PM
+Menchel, Matthew (USAFLS)
+RE: Epstein
+Hi Matt -- My trial is over, so I now have to time to focus back on this case and
+our e-mail exchange. There are several points in your e-mail that I would like
+to address, and I also would like to address where we are in the case.
+First, I wanted to address the comment about jumping the chain of command. After
+that concern was brought to my attention several months ago, I have tried very
+hard to be cognizant of the chain of command, and, as was evident at the meeting
+with Epstein's attorneys, Andy and I have discussed the case extensively. My
+original e-mail asking for everyone's input was addressed to Andy, you, and Jeff,
+and Karen Atkinson was cc'd. (Karen and I also have discussed the case in great
+detail.) The response to your e-mail was addressed only to you because I thought
+you would want to discuss privately our disagreement. It was addressed to Jeff
+as well because you said that you had Jeff's Blackberry and it was a holiday when
+you would be out of the office. If there is a particular instance of violating
+the chain of command that you would like to discuss, I would be happy to discuss
+Second, the reason why I sent the original e-mail to everyone was to see if
+anyone had any objections to the proposed language. I waited several days to
+send out the e-mail to Lilly to get everyone's response. In your response, you
+did not raise any concerns, nor did anyone else. Given your indication that the
+U.S. Attorney would be satisfied with an agreement involving no federal
+prosecution, I certainly didn't think that an agreement involving some federal
+component would be objectionable. Andy, Jeff, you, and I all have discussed the
+greater flexibility of a pre-indictment plea.
+The statement that I have not respected Alex's position regarding the prosecution
+of the case demonstrates why you hear the frustration in the tone of my e-mail.
+For two and a half months I have been asking about what that position is. I have
+asked for direction on whether to revise the indictment, whether there are other
+issues that Alex wants addressed prior to deciding, whether there is additional
+investigation that needs to be done, etc. None of that direction has been
+forthcoming, so I am left with a grand jury, victims, and agents all demanding to
+know why we aren't presenting an indictment. Perhaps that lack of direction is
+through no fault of yours, but I have been dealing with a black box, so I do not
+know to whom I should address my frustration. My recollection of the original
+meeting with Alex and Jeff is quite different than your summary. In that
+meeting, I summarized the case and the State Attorney's Office's handling of it.
+I acknowledged that we needed to do work to collect the evidence establishing a
+federal nexus, and I noted the time and money that would be required for an
+investigation.
+I said that I was willing to invest that time and the FBI was
+willing to invest the money, but I didn't want to get to the end and then have
+the Office be intimidated by the high-powered lawyers. I was assured that that
+
+
+would not happen. Now I feel like there is a glass ceiling that prevents me from
+moving forward while evidence suggests that Epstein is continuing to engage in
+this criminal behavior. Additionally, the FBI has identified two more victims.
+If the case is not going to go forward, I think it is unfair to give hope to more
+girls.
+As far as promising the FBI that an indictment was a foregone conclusion, I don't
+know of any cases in the Office where an investigation has been opened with the
+plan NOT to indict. And I have never presented an indictment package that has
+resulted in a declination. I didn't treat this case any differently. I worked
+with the agents to gather the evidence, and I prepared an indictment package that
+I believe establishes probable cause that a series of crimes have been committed.
+More importantly, I believe there is proof beyond a reasonable doubt of Epstein's
+criminal culpability.
+Lastly, I was not trying to "dictate" a meeting with the U.S. Attorney or anyone
+else. I stated that I "would like" to schedule a meeting, asking to have the
+same courtesy that was extended to the defense attorneys extended to the FBI and
+an Assistant in the Office. With respect to your questions regarding my
+judgment, I will simply say that disagreements about strategy and raising
+concerns about the forgotten voices of the victims in this case should not be
+classified as a lapse in judgment. This Office should seek to foster spirited
+debate about the law and the use of prosecutorial discretion, and I think that
+those debates do occur with other AUSAs. I know of past instances where
+disagreements about the application of the law to different defendants and
+defense attorneys has resulted in a call for the resignation of the AUSA who
+dared to challenge the Executive Office's conclusions. I found that very
+disheartening and hoped that this Administration would be different. However, my
+first and only concern in this case (and my other child exploitation cases) is
+the victims.
+If our personality differences threaten their access to justice,
+then please
+put someone on the case whom you trust more, and who will also
+protect their rights.
+In the meantime, I will be meeting with the agents on Monday to begin preparing a
+revised indictment package containing your suggestions on the indictment and
+responding to the issues raised by Epstein's attorneys. Andy and I have
+discussed the most recent letter and noted the disingenuousness of their
+arguments.
+For example, they would like to use a linguist to establish the plain
+meaning of "using" in connection with "knowingly persuading, " but they want us to
+disregard the plain meaning of "mail or any facility or means of interstate or
+foreign commerce" and instead treat that language as though it says only "the
+internet." They have simply ignored binding precedent from the Eleventh Circuit
+and the Supreme Court in making their arguments about the Commerce Clause and the
+interpretation of 2242(b). If there are any specific issues that you or the U.S.
+Attorney would like to see addressed, please let me know.
+Again, this e-mail has been addressed only to you, but if you would like to share
+it with anyone else in Miami or here, please feel free.
+I hope that you have a nice weekend.
+61
+
+
+Marie
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+west Palm Beach, FL 33401
+Phone 561 209-1047
+-----Original Message-----
+From: Menchel, Matthew (USAFLS)
+Sent: Thursday, July 05, 2007 3:30 PM
+To: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Lourie, Andrew (USAFLS)
+Subject: RE: Epstein
+Marie,
+Both the tone and substance of your email are totally inappropriate and, in
+combination with other matters in the past, it seriously calls your judgment into
+question.
+As you well know, the US Attorney has not even decided whether to go forward with
+a prosecution in this matter, thus you should have respected his position before
+engaging in plea negotiations.
+Along that same line, despite whatever contrary representations you made to the
+agents in this matter, it was made clear to you by the US Attorney and the First
+Assistant from the time when you were first authorized to investigate Mr. Epstein
+that the office had concerns about taking this case because of petit policy and
+a number of legal issues. Despite being told these things, you prepared a pros
+memo and indictment that included a definitive date for indictment. It has come
+to my attention that you led the agents to believe that the indictment of this
+matter was a foregone conclusion and that our decision to put off that date and
+listen to the defense attorneys' concerns is indicative of the office having
+second thoughts about indicting. As you well knew, you were never given
+authorization by anyone to seek an indictment in this case.
+Lily Sanchez called me before, not after, the June 26th meeting. It was an
+informal discussion and not in the nature of an official plea offer but rather a
+feeling out by both sides as to what it might take to resolve the matter. As you
+are also well aware, the only reason why this office even agreed to look into the
+Epstein matter in the first instance was because of concerns that the State had
+not done an adequate job in vindicating the victims' rights. As you and the
+agents conceded, had Epstein been convicted of a felony that resulted in a jail
+sentence and sex offender status, neither the FBI nor our office ever would have
+interceded. You should also know that my discussion with Lily Sanchez was made
+62
+
+
+with the US Attorney's full knowledge. Had Lily Sanchez expressed interest in
+pursuing this avenue further, I certainly would have raised it with all the
+interested individuals in this case, including you and the agents. In any event,
+I fail to see how a discussion that went nowhere has hurt our bargaining
+position. I am also quite confident that no one on the defense team believes
+that the federal investigation in this matter has been for show.
+Nor are your arguments that I have violated the Ashcroft memo, the USAM or any
+other policy well taken. As Chief of the Criminal Division, I am the person
+designated by the US Attorney to exercise appropriate discretion in deciding
+whether certain pleas are appropriate and consistent with the Ashcroft memo and
+the USAM -- not you.
+As for your statement that my concerns about this case hurting Project Safe
+Childhood are unfounded, I made it clear to you that those concerns were voiced
+by the US Attorney. Whether or not you are correct, matters of policy are always
+within his purview and any decisions in that area ultimately rest with him.
+Finally, you may not dictate the dates and people you will meet with about this
+or any other case. If the US Attorney or the First Assistant desire to meet with
+you, they will let you know. Nor will I direct Epstein's lawyers to communicate
+only with you. If you want to work major cases in the district you must
+understand and accept the fact that there is a chain of command - something you
+disregard with great regularity.
+Matt
+-----Original Message-...-
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Wednesday, July 04, 2007 5:16 PM
+To: Sloman, Jeff (USAFLS); Menchel, Matthew (USAFLS)
+Subject: FW: Epstein
+Hi Matt -- I am in trial, so I just got your message.
+First, it is inappropriate for you to enter into plea negotiations without
+consulting with me or the investigative agencies, and it is more inappropriate to
+make a plea offer that you know is completely unacceptable to the FBI, ICE, the
+victims, and me. These plea negotiations violate the Ashcroft memo, the U.S.
+Attorney's Manual, and all of the various iterations of the victims' rights
+legislation. Strategically, you have started the plea negotiations as though we
+are in a position of weakness, anxious to make the case go away, by telling the
+defense that we will demand no federal conviction. We left the meeting on June
+26th in a stronger position than when we entered, and your statement that a state
+resolution would satisfy us takes away that advantage. If you make it seem like
+the U.S. Attorney doesn't have faith in our investigation, Epstein has no
+incentive to make a deal.
+63
+
+
+Second, your discussion makes it appear that my investigation is for "show" only
+and completely undermines my ability to deal with Epstein's attorneys directly.
+In my eight years of civil practice (before the six years that I have spent with
+this Office), I have litigated against attorneys far more formidable than Roy
+Black and Alan Dershowitz and have managed to convince the Eighth, Ninth, and
+Federal Circuits that my legislative interpretation was correct. Your concerns
+about this prosecution hurting the rest of the Project Safe Childhood Program are
+unfounded.
+My trial should end early next week. I would like to make a presentation to the
+U.S. Attorney, Jeff, Andy, and you with our side of the investigation and a
+revised indictment.
+The presentation will address the points raised by Epstein's
+counsel and will convince you all of the strength of the case.
+In the meantime, please direct all communications from Epstein's counsel to me.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+-----Original Message--..--
+From: Sloman, Jeff (USAFLS)
+Sent: Tuesday, July 03, 2007 1:47 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Epstein
+Marie, my blackberry is giving me trouble so i'm using jeff's. I told lily that
+a state plea with jail time and sex offender status may satisfy the usa.
+It was
+a non-starter for them Matt
+Sent from my GoodLink synchronized handheld (www.good.com)
+64
+
+
+To:
+Cc:
+Subject:
+Attachments:
+Gerald Lefcourt [GBL@lefcourtlaw.com]
+Wednesday, July 18, 2007 5:19 PM
+Lilly Ann Sanchez; Roy BLACK
+RE: Jeffrey Epstein
+2007-07-18 Villafana re NES subpoena.pdf
+Marie please consider this letter in response to the subpoena to NES.
+Gerald B. Lefcourt
+Gerald B. Lefcourt,
+P.C.
+148 E. 78th Street
+New York, New York 10021
+Tel.
+Fax
+gbl@lefcourtlaw.com
+-----Original Message-----
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.gov]
+Sent: Wednesday, July 04, 2007 4:07 PM
+To: Lilly Ann Sanchez
+Cc: Gerald Lefcourt
+Subject: RE: Jeffrey Epstein
+ear Lilly and Gerry: Thank you for your e-mail and your message. This e-mail
+was supposed to have gone out yesterday while I was in trial. I have no
+objection to the two-week extension with respect to NES, New York Strategy Group,
+and Epstein Virgin Islands Foundation.
+With respect to the subpoena to the investigator, I would like to get the
+computer equipment as soon as possible.
+sometime sage more rict pring age to thoration plated to hot shed
+why the equipment was removed. I will be in trial this week, so please contact
+Jason Richards at the FBI directly at 561 833-7517.
+I look forward to your July 11th submission. If you would like to discuss the
+possibility of a federal resolution of Mr. Epstein's case that could run
+oncurrently with any state resolution, please leave a message on my voicemail a
+he office (561 209-1047) and I will get back to you after trial has ended fo
+the day.
+Thank you.
+A. Marie Villafaña
+Assistant U.S. Attorney
+51
+
+
+561 209-1047
+-----Original Message-----
+From: Lilly Ann Sanchez [mailto:LAS@FOWLER-WHITE.coM]
+Sent: Friday, June 29, 2007 4:05 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Cc: Gerald Lefcourt
+Subject: Jeffrey Epstein
+As i stated in my earlier voicemail today, we were calling to request a two-week
+extension on the return date of the following outstanding subpoenas:
+2. NY Strategy
+3. Investigator Riley
+4. Certification for St. Thomas entity
+We will be providing an additional submission to the Office by July 11 and hope
+to be able to reach a state-based resolution shortly thereafter.
+as your voicemail to me indicted, you would not oppose a one to two-week
+extension. accordingly, we would like to extend the return date two weeks-- to
+regards
+Lilly Ann Sanchez, Esq.
+FOWLER WHITE BURNETT P.A.
+Espirito Santo Plaza, 14th Floor
+1395 Brickell Avenue
+Miami, Florida 33131-3302
+Telephone: (305) 789-9200
+Direct Dial: (305) 789-9279
+Facsimile: (305) 728-7579
+Isanchez@fowler-white.com
+52
+
+
+-rom
+Sent
+To:
+Subject:
+Thursday, September 06, 2007 9:29 AM
+Sloman, Jeff (USAFLS)
+RE: Meeting on Friday
+Hi Jeff'- The ASAIC will be there for the meeting. I think she also will be at the OLEOs.
+A. Marie Villațaña
+Assistant U.S. Attorney
+561 209-1047
+From: Sloman, Jeff (USAFLS)
+Sent: Tuesday, September 04, 2007 11:44 AM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: RE: Meeting on Friday
+Let's get together at 1:30. FBI is welcome but let's try to limit it to one representative. Is that o.k.?
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Tuesday, September 04, 2007 11:29 AM
+To: Sloman, Jeff (USAFLS)
+Subject: Meeting on Friday
+Hi Jeff - 1 just left you a voicemail, so you can disregard that. We had a very good meeting with Drew on Friday. No one
+was sure whether you want an FBI presence at the meeting on Friday and Drew thought I should ask you. Could you let
+me know? And does the meeting with Epstein's team start at 2:00? Is there a plan for a pre-meeting meeting with our
+Thanks.
+A. Marie Villafaña
+Assistant U.S. Attorney
+561 209-1047
+3250
+
+
+To:
+Subject:
+Thursday, September 06, 2007 5:47 PM
+Sloman, Jeff (USAFLS)
+RE: Epstein
+Hi Jeff - Funny you should ask. I have been wondering the same thing. Here is the term sheet and guidelines calculation
+that we provided at the last meeting. You and Matt and I had also discussed a possible federal plea to an Information
+charging a 371 conspiracy, with a Rule 11 plea with a two-year cap, but I think Matt must have asked Alex about it and it
+was nixed. Just to be prepared for tomorrow, I was just starting to draft a Rule 11 plea agreement in case Alex changes
+his mind and a formal non-prosecution agreement containing the state plea terms. As soon as those are ready, I will e-
+mail them to you.
+Conf Plea
+gotiations
+There are three concerns that I hope we can address tomorrow. First, that there is an absolute drop-dead date for
+accepting or rejecting because it is strategically important that we indict before the end of September, which means
+presenting the indictment on September 25"". Second, the agents and I have not reached out to the victims to get their
+approval, which as Drew politely reminded me, is required under the law. And third. I do not want to make any promises
+about allowing Epstein to self-surrender because I still believe that we have a good chance of getting him detained.
+On another note, Junior got a call today from the Palm Beach Police Chief because he got information that there will be an
+article released tomorrow about our meeting and that Epstein is going to plead to a state charge and the Chief wanted to
+know if the victims had been consulted about the deal. There has been some coverage in the New York press about Ken
+Starr, but 1 haven't seen anything local yet.
+A. Marie Villafaña
+Assistant U.S. Attorney
+561 209-1047
+From: Sloman, Jeff (USAFLS)
+Sent: Thursday, September 06, 2007 5:35 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Epstein
+Please refresh my recollection. What is the "deal" on the table?
+3245
+
+
+Recipient
+Sloman, Jeff (USAFLS)
+3246
+Read
+Read: 9/6/2007 5:58 PM
+
+
+Vonday, September 10, 2007 5:24 PN
+To:
+Sloman, Jeff (USAFLS); Lourie, Andrew (USAFLS
+Subject:
+FBI
+Jeff and Andy - The agents are asking whether Alex had a chance to talk to the SAIC. Do you know?
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+3231
+
+
+From
+ent
+To:
+Subject:
+ursday. September 13, 2007 8:10 F
+sterbaan, Andre
+Hi Drew - I tracked down the AUSA in Alaska and he is sending the trust agreement out to me. I will let you
+know how things go in the morning.
+Thanks.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+From: Oosterbaan, Andrew
+Sent: Thursday, September 13, 2007 7:54 PM
+To: Villatana, Ann Marie C. (USAFLS)
+Subject: RE: Epstein
+Thanks for the information, Marie. I'll get the details on the Boehm arrangements from the prosecutors and get back to
+you tomorrow. I believe the girls agreed to the arrangement, but I'll confirm that. I should have the indictment reviewed
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann. Marie. C. Villafana@usdoj.gov]
+Sent: Thursday, September 13, 2007 7:37 PM
+To: Oosterbaan, Andrew
+Subject: Epstein
+Hi Drew - Sorry to bother you, but the plea negotiations are getting fast and furious. Epstein's lawyers are
+fixated on this idea of a "victim's fund" rather than having the girls file separate 2255 actions. I know that the
+reason they want to do it is not out of the goodness of their hearts but to keep this stuff out of the public Court
+files, but in some ways it will help the girls, too. Do you know anything about how the fund in Alaska was
+worked out? Did all the victims consent or did the Court just do it?
+Thank you for your help. I also turned in the indictment package to my immediate supervisor today, so I expect
+some edits back from her before it goes higher up the chain. If you had any thoughts, please let me know.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+3164
+
+
+To:
+Subject:
+Monday, September 17, 2007 10:35 AN
+Garcia, Rolando (USAFLS); Lourie, Andrew (USAFLS)
+RE: Epstein
+Hi Rolando - Here is the last e-mail that I sent to Jay last night. Jay talked with his client about it and reports
+that they are leaning towards options 1 or 4. They are going to try to make that decision today (there seems to
+be some dissension in the ranks because Jack Goldberger gave some incorrect information), and draft a
+proposed either Non-Prosecution Agreement or Plea Agreement. As you can see from my list below, there are a
+number of things in their last draft that were unacceptable. All of the loopholes that I sewed up they tried to
+open. So. Jay is supposed to be consulting with Roy Black regarding the correct state information and then will
+give me a call.
+I agreed to ask the Judge to take the hearing off calendar tomorrow and to postpone the grand jury appearances
+that were scheduled from tomorrow. but I told him in no uncertain terms that I am indicting on the 25" so this
+needs to be resolved early this week. Andy and I talked about all of this as well. Long answer to a short
+question, sorry.
+Hi Jay - This can wait until after the show, but my voice is going so I thought I would type it up. I
+talked to Andy and he still doesn't like the factual basis. In his opinion, the plea should only address
+the crimes that we were addressing, and we were not investigating Mr. Epstein abusing his girlfriend.
+So, these are the only options that he recommended:
+1. We go back to the original agreement where Mr. Epstein pleads only to state charges and serves
+his time in the state, except that we can agree to only 18 months imprisonment.
+2. Mr. Epstein pleads guilty to the state charges and also pleads to either two obstruction counts or to
+one count of violating 47 USC 223(a)(1)(B), with a joint non-binding recommendation of 18 months,
+so that Mr. Epstein can serve his time federally.
+3. (My suggestion only, not Andy's): I go back to the U.S. Attorney and ask him to agree to an ABA-
+plea to a 371 count (conspiracy to violate 2422(b)) with a binding 20-month recommendation so that
+Mr. Epstein can serve all of his time in a federal facility.
+Or 4. Mr. Epstein pleads to one obstruction count, and serves part of his time federally and part state.
+On your other proposed changes, some are fine and some are problematic.
+Re your paragraph 2: As to timing, it is my understanding that Mr. Epstein needs to be sentenced in
+the state after he is sentenced in the federal case, but not that he needs to plead guilty and be
+sentenced after serving his federal time. Andy recommended that some of the timing issues be
+addressed only in the state agreement, so that it isn't obvious to the judge that we are trying to create
+federal jurisdiction for prison purposes. My understanding is that Mr. Epstein should sign a state plea
+agreement, plead guilty to the federal offenses, plead guilty to the state offenses, be sentenced on the
+federal offenses, and then be sentenced on the state offenses, and then start serving the federal
+sentence.
+Re your paragraph 3: As to the reservation of Mr. Epstein's right to withdraw his state plea or to
+appeal his state plea or sentence, that is fine, but we need the caveat that, if he were to do so, the
+United States could proceed on our charges.
+Re your paragraph 6: With respect to the waiver of the right to appeal the federal sentence, given the
+way we have drafted the information, it is possible that getting to the 18 month sentence will require
+an upward departure. The version of the agreement that you were working from is a federal non-
+3140
+
+
+prosecution agreement, the ones I have sent you recently are plea agreements that get filed with the
+court. Please see if the appeal waiver language in those versions is alright.
+Re your paragraph 7: As I mentioned, we will not waive the presentence investigation. I know that
+this will delay Mr. Epstein's sentencing by 70 days, but that will allow him to get all of his affairs in
+order. As to bail, it will be set at the time of arraignment, and we can work out a joint recommendation
+regarding the amount and its limitations. I have no objection to making a joint recommendation that
+Mr. Epstein remain out on bond pending his sentencing, but I'm not sure that it belongs in a plea
+agreement, especially since I can't bind the court on that issue. However, I can assure you, and we
+can put it on the record during the plea colloquy, that I will join in your recommendation that he remain
+out on bond pending sentencing. The same goes for the prison camp issue. As I mentioned, I have
+opposed a designation only once in a very particular case. I can assure you, and we can put it on the
+record at the plea colloquy that I will not oppose your recommendation for Mr. Epstein's designation.
+Re your paragraph 8: As 1 mentioned over the telephone, I cannot bind the girls to the Trust
+Agreement, and I don't think it is appropriate that a state court would administer a trust that seeks to
+pay for federal civil claims. We both want to avoid unscrupulous attorneys and/or litigants from
+coming forward, and I know that your client wants to keep these matters outside of public court filings,
+but I just don't have the power to do what you ask. Here is my recommendation. During the period
+between Mr. Epstein's plea and sentencing, I make a motion for appointment of the Guardian Ad
+Litem. The three of us sit down and discuss things, and I will facilitate as much as I can getting the
+girls' approval of this procedure because, as I mentioned, I think it is probably in their best interests.
+In terms of plea agreement language, let me suggest the following:
+The United States agrees to make a motion seeking the appointment of a Guardian ad Litem to
+represent the identified victims. Following the appointment of such Guardian, the parties agree to
+work together in good faith to develop a Trust Agreement, subject to the Court's approval, that would
+provide for any damages owed to the identified victims pursuant to 18 U.S.C. Section 2255. Then
+include the last two sentences of your paragraph 8.
+Re the two paragraphs following your paragraph 8: I will include our standard language regarding
+resolving all criminal liability and i will mention "co-conspirators," but I would prefer not to highlight for
+the judge all of the other crimes and all of the other persons that we could charge. Also, we do not
+have the power to bind Immigration and we make it a policy not to try to, however, I can tell you that,
+as far as | know, there is no plan to try to proceed on any immigration charges against either Ms.
+Also, on the grand jury subpoenas, I can prepare letters withdrawing them as of the signing of the
+plea agreement, but I would prefer to take out that language. In my eyes, once we have a plea
+agreement, the grand jury's investigation has ended and there can be no more use of the grand jury's
+subpoena power.
+I had hoped that we were far closer to resolving this than it appears that we are. Can I suggest that
+tomorrow we either meet live or via teleconference, either with your client or having him within a quick
+phone call, to hash out these items? I was hoping to work only a half day tomorrow to save my voice
+for Tuesday's hearing and grand jury, if necessary, but maybe we can set a time to meet. If you want
+to meet "off campus" somewhere, that is fine. I will make sure that I have all the necessary decision
+makers present or "on call," as well.
+If we can resolve some of these issues today, let's try to, and then save only the difficult issues for
+tomorrow.
+Sorry for the long e-mail, and for ruining your date with your daughter.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 56l 209-1047
+3141
+
+
+From: Garcia, Rolando (USAFLS)
+Sent: Monday, September 17, 2007 10:26 AN
+To: Villafana, Ann Marie C. (USAFLS
+Subject: Epstein
+Marie,
+Where are we at in the plea negotiations?
+3142
+
+
+To:
+Cc:
+Subject:
+Importance:
+Tuesday, September 18, 2007 9:31 AM
+Acosta, Alex (USAFLS); Lourie, Andrew (USAFLS); Garcia, Rolando (USAFLS)
+Atkinson, Karen (USAFLS); McMillan, John (USAFLS)
+Epstein Negotiations
+High
+Hi all - I think that we may be near the end of our negotiations with Mr. Epstein, and not because we have
+reached a resolution. As I mentioned yesterday, 1 spent about 12 hours over the weekend drafting Informations,
+changing plea agreements, and writing factual proffers. I was supposed to receive a draft agreement from them
+yesterday, which never arrived. At that time, they were leaning towards pleading only to state charges and
+doing all of the time in state custody.
+Late last night I talked to Jay Lefkowitz who asked about Epstein pleading to two twelve-month federal charges
+with half of his jail time being spent in home confinement pursuant to the guidelines. I told him that I had no
+objection to that approach but, in the interest of full disclosure, I did not believe that Mr. Epstein would be
+eligible because he will not be in Zone A or B. This morning Jay called and said that I was correct but, if we
+could get Mr. Epstein down to 14 months, then he thought he would be eligible.
+My response: have him plead to two separate Informations. On the first one he gets 12 months' imprisonment
+and on the second he gets twelve months, with six served in home confinement, to run consecutively.
+I just received an e-mail asking if Mr. Epstein could just do 12 months imprisonment instead.
+As you can see, Mr. Epstein is having second thoughts about doing jail time. I would like to send Jay an e-mail
+stating that if we do not have a signed agreement by tomorrow at 5:00, negotiations will end. I have selected
+tomorrow at 5:00 because it gives them enough time to really negotiate an agreement if they are serious about it,
+and, if not, it gives me one day before the Jewish holiday to get witnesses lined up for Tuesday's grand jury
+appearance, when 1 plan to present the indictment, and it gives the office sufficient time to review the
+indictment package.
+Do you concur?
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+3123
+
+
+To:
+Cc:
+Subject:
+Tuesday, September 18, 2007 11:43 AM
+'Lourie, Andrew; Garcia, Rolando (USAFLS)
+Atkinson, Karen (USAFLS)
+RE: Draft Agreements?
+He also removed any promise to plead to a registrable offense and the promise related to the girls' damages
+claims.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian A ve, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Tuesday, September 18, 2007 11:18 AM
+To: 'Lourie, Andrew'; Garcia, Rolando (USAFLS)
+Cc: Atkinson, Karen (USAFLS)
+Subject: FW: Draft Agreements?
+Importance: High
+Andy and Rolando: Please see below so you understand my frustration. This document is completely different
+from what Jay just told Andy they would agree to. He has it written as 16 months" imprisonment followed by 8
+months federal supervised release. He wants us to recommend an improper calculation of the guidelines, and he
+wants to waive the PSI so he can keep all of his information confidential. I have already told Jay that the PSI
+language and other language in this agreement was unacceptable to our office. I will send back a plea
+agreement that reads consistent with what Jay represented to Andy but I don't believe that this will be resolved
+by Tuesday unless they come down here and we have a group contract writing session with the state attorney's
+office and the decision-makers.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 56| 820-8777
+From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com]
+Sent: Tuesday, September 18, 2007 11:09 AM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: RE: Draft Agreements?
+Confidential - For Settlement purposes only.
+Marie -- Please look this over and let's see if we can identify any issues that we need to discuss in greater detail. Since
+you can't go to only one count of obstruction, but 18 would become about 15 with gain time, I have made a proposal of a
+total 24 month sentence based on two informations. This would include a period of home detention. We can then follow
+3112
+
+
+this with a state plea as well so he serves the additional time there. I need to see your language for proffers on the two
+charges - (taking Nadia and Sarah out of the jurisdiction to avoid process.)
+Alternatively, at this stage, we could have just one count for 12 months and then 6 months incarceration under the state,
+followed by community control and probabtion. I am not sure which is more practicable.
+Please let me know when you are free to speak.
+Thanks - Jay
+"Villafana, Ann Marie C. VUSAFLSI)"
+<Ann.Marie, C.Villafana @usdoj.gov>
+09/18/2007 09:14 AM
+To "Jay Lefkowitz" <JLefkowitz@kirkland.com>
+COC
+Subject RE: Draft Agreements?
+Hi Jay - I know that the U.S. Attorney will not go below 18 months of prison/jail time (and I would strongly
+oppose the suggestion).
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com]
+Sent: Tuesday, September 18, 2007 8:59 AM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Re: Draft Agreements?
+an alternative to what we discussed just now might be to plead to one count of 1512, serve 12 months plus supervised
+release which would be one year of home detention (if we can make that work), followed by two years of probation in the
+state on the state charges with the first 6 months being community control.
+"Villafana, Ann Marie C. \USAFLS\) <Ann.Marie.C. Villafana @usdoj.gov>
+09/18/2007 08:44 AM
+To "Jay Lefkowitz" <JLefkowitz@kirkland.com>
+CC
+Subject Draft Agreements?
+3113
+
+
+Hi Jay - I was hoping there would be things for me to read this morning, but I will try to remain patient.
+I believe there are only two types of agreements that would apply to this case: (1) a plea agreement to a federal
+charge or charges; and (2) a non-prosecution agreement (which is really a deferred prosecution agreement
+because the defendant agrees that if he violates the agreement, the U.S. can prosecute him).
+A plea agreement is part of the court file. It is not accessible on-line via PACER, but someone can go to the
+Clerk's Office to obtain a copy.
+A non-prosecution agreement would not be made public or filed with the Court, but it would remain part of our
+case file. It probably would be subject to a FOIA request, but it is not something that we would distribute
+without compulsory process.
+On the obstruction charges, many of the facts I included in that first proffer were hypothesized based upon our
+discussions and the agents' observations of Ms. Groff. We will need to interview her to confirm the accuracy of
+those facts. On a second count, we could rely on the incident where Mr. Epstein's private investigators
+followed
+father, forcing him off the road. Or, if there is something more recent related to any grand
+Hope that helps.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+3114
+
+
+To:
+Subject:
+_ourie, Andrew [Andrew.Lourie2@usdoj.gov]
+Wednesday, September 19, 2007 4:21 PM
+RE: epstein
+I will reach out to Alex to discuss.
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie. C. Villafana@usdoj.gov]
+Sent: Wednesday, September 19, 2007 4:13 PM
+To: Villafana, Ann Marie C. (USAFLS); Lourie, Andrew
+Cc: Garcia, Rolando (USAFLS)
+Subject: RE: epstein
+Oh, and they took out the appeal waiver.
+A. Marie Villafaña
+Assistant U.S. Attorney
+56| 209-1047
+From: Villatana, Ann Marie C. (USAFLS)
+Sent: Wednesday, September 19, 2007 4:05 PM
+To: 'Lourie, Andrew'
+Cc: Garcia, Rolando (USAFLS)
+Subject: RE: epstein
+Importance: High
+I just got their "red-lined" version. I will forward it to you. Here are the issues that Rolando and I specifically discussed
+with them and rejected, that they have re-inserted into the agreement.
+1. We agree to recommend that no PSI be prepared.
+2. They have converted it into an ABA plea - as though we wouldn't notice?
+They want us to agree to the incorrect calculation of the guidelines
+4. Instead of agreeing that the girls can sue Epstein, they cannot sue him and instead are bound to apply to a trust
+administered by the State Court (Jay and I have addressed this at least three times and it keeps appearing in his
+S. They changed the state charge that he has to plead guilty to to a non-registrable offense and he doesn't have to
+plead to that charge until after he has finished serving his federal sentence.
+6. They want us not to oppose a request for a prison camp designation.
+7. They have re-added paragraphs 17 through 19, all of which are addressed by paragraph 2.
+There are other problems too, but these are the highlights. This is NOT good faith negotiations.
+A. Marie Villafaña
+Assistant U.S. Attorney
+561 209-1047
+From: Lourie, Andrew [mailto:Andrew.Lourie2@usdoj.gov]
+Sent: Wednesday, September 19, 2007 3:50 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Cc: Garcia, Rolando (USAFLS)
+Subject: RE: epstein
+3044
+
+
+Good job. A few thoughts:
+I would eliminate the first sentence of para 2. Is there another way to deal with the issue in para 3 without this in the plea
+agreement ? Do we need para 10? Isn't para 11 sufficient without 10? Is it our place to include para 13 in this
+agreement? I think it belongs in the state agreement and it looks out of place here.
+I think you should include Roy or another member of the FL Bar on the plea agreement so we are not slowed down at the
+last minute by Pro Hac stuff.
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie. C. Villafana@usdoj.gov]
+Sent: Wednesday, September 19, 2007 2:36 PM
+To: Lourie, Andrew
+Subject: RE: epstein
+FYI - The Palm Beach Post reported the whole deal in today's paper and claimed to have a "federal source" and a "spy"
+in Epstein's camp.
+A. Marie Villafaña
+Assistant U.S. Allorney
+561 209-1047
+From: Lourie, Andrew [mailto:Andrew.Lourie2@usdoj.gov]
+Sent: Wednesday, September 19, 2007 2:33 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: RE: epstein
+Can you send me copy of the last thing you sent them? Thanks.
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie. C. Villafana@usdoj.gov]
+Sent: Wednesday, September 19, 2007 2:31 PM
+To: Lourie, Andrew; Garcia, Rolando (USAFLS)
+Subject: RE: epstein
+We are still waiting for a "redline" of the agreement that they seemed happy with yesterday. Barry and Lanna and
+Epstein's attorneys are coming to our office on Monday to finalize everything with the plan of getting him at least
+arraigned on Monday afternoon. They tried to drag it into Tuesday and I said no.
+1. Marie Villafaña
+Assistant U.S. Attorney
+561 209-1047
+From: Lourie, Andrew [mailto:Andrew.Lourie2 @usdoj.gov]
+Sent: Wednesday, September 19, 2007 2:25 PM
+To: Villafana, Ann Marie C. (USAFLS); Garcia, Rolando (USAFLS)
+Subject: epstein
+What is the latest?
+3045
+
+
+To:
+Cc:
+Subject:
+Importance:
+Wednesday, September 19, 2007 4:33 PM
+Lourie, Andrew; Garcia, Rolando (USAFLS)
+RE: Draft Plea Agreement
+High
+Andy and Rolando -- This is my proposed response (below). I know that you keep
+saying he is going to plead, and he will plead if we cave on everything, but I
+really do not think that Mr. Epstein is going to engage in serious negotiations
+until he sees the Indictment and shows up in mag court (preferably in flipflops). In reviewing the indictment package, if you would like to maintain
+flexibility for the future, we could indict Mr. Epstein just on Count 1 (the
+conspiracy charge), and, if he won't plead to 5 years at that time, supersede
+with the remaining counts and just go to trial. But we gave them an initial
+deadline of early August with the 24-month sentence. We are now seven weeks
+later and we are just spinning our wheels.
+Jay -- The same problems that I e-mailed you about on Sunday and discussed
+yesterday with you and Rolando and that you discussed with Andy are still in
+here. Paragraphs 4, 7, 8, 9, and 11 have specifically been discussed and
+rejected. Paragraphs 17 through 19 have been addressed in paragraph 2 and will
+not be repeated.
+You have removed our paragraphs 4 (regarding the application of
+the Sentencing Guidelines) and 18 (appeal waiver) both of which are specifically
+required by the Office's Appellate Division. You have replaced Mr. Epstein's
+plea to a registrable offense, to one that does not require registration, and you
+have again delayed the plea until after Mr. Epstein completes his federal prison
+sentence.
+Rolando and I specifically told you that was unacceptable, and Barry
+Krischer also has informed us that he will not keep his case open for that
+period. You also have inserted that this is a Rule 11(c)(1)(C) plea, which binds
+the judge, which you know we have specifically rejected.
+There are other, smaller, changes that the Office probably cannot agree to, but
+the bigger issues are these. If you or your client insists on these, there can
+be no plea agreement.
+A. Marie Villafaña
+Assistant U.S. Attorney
+561 209-1047
+-----Original Message-----
+From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com]
+Sent: wednesday, September 19, 2007 3:44 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Fw: Draft Plea Agreement
+3041
+
+
+
+For settlement purposes only
+Marie - I wanted to get this to you before I took off for nyc. I am landing at 7
+and would like to speak shortly thereafter.
+I am still considering which of the options you suggested Sunday. In this email,
+I am sending you a redline of your federal resolution.
+deferred prosecution agreement because it may well be that we cannot reach
+agreement here. I don't think there are that many issues left open, although
+clearly we still need to have further discussions. I also like your suggestion
+from Sunday that we consider a C plea.
+I know that Alex would have to sign off on it and that he has not done so as of
+nOW.
+Regarding my schedule, I am available tonight to speak, all afternoon tomorrow (I
+am in fed court in nyc on another criminal matter tomorrow am), and then all day
+Friday.
+I will plan on seeing you Monday.
+I am confident that one of the approaches we
+have discussed will work out.
+Jay
+----- Original Message --...-
+From: Jay Lefkowitz
+Sent: 09/19/2007 03:35 PM EDT
+To: Jay Lefkowitz
+Subject: Draft Plea Agreement
+(See attached file: 9.19.07 Draft Plea Agreement
+(Clean). doc)
+(See attached file: 9.19.07 Draft Plea Agreement
+(Redlined). doc)
+***********************************************************
+The information contained in this communication is confidential, may be attorneyclient privileged, may constitute inside information, and is intended only for
+the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland
+& Ellis International LLP.
+Unauthorized use, disclosure or copying of this communication or any part thereof
+is strictly prohibited and may be unlawful. If you have received this
+communication in error, please notify us immediately by return e-mail or by e-
+mail to postmaster@kirkland. com, and destroy this communication and all copies
+thereof, including all attachments.
+*******••••****************************
+********
+****
+3042
+
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA
+JANE DOE #1 and JANE DOE #2,
+Petitioners.
+VS.
+UNITED STATES OF AMERICA,
+Respondents.
+UNITED STATES OF AMERICA'S RESPONSE TO
+PETITIONERS' REQUEST FOR PRODUCTION
+Respondent United States of America, in response to petitioners' Request for Production,
+submits the following:
+Request for Production No. 1:
+FBI Case File on the Epstein case (P).
+(a)
+(b)
+(c)
+(d)
+Prosecution Memorandum, "Operation Leap Year," May 1, 2007 (82 pages),
+Author: A. Marie Villafana. Addressees: R. Alexander Acosta, United States Attorney; Jeff
+Sloman, First Assistant U.S. Attorney; Matthew Menchel, Chief, Criminal Division; Andrew
+Lourie; Managing Assistant U.S. Attorney, Northern Region; and Karen Atkinson, Chief,
+Northern Region. (P).
+Draft Indictment (54 pages)(P).
+(e) Draft indictments (P)
+Request for Production No. 2:
+Letter to Miss C.W., dated June 7, 2007, RE: Crime Victims' and Witnesses'
+Rights (2 pages); Author: A. Marie Villafana.
+Letter to Miss T.M., dated August 11, 2006, RE: Crime Victims' and Witnesses'
+1
+
+
+Rights (2 pages); Author: A. Marie Villafana.
+Letter to C. W., dated January 10, 2008, RE: Case Number.
+(2 pages);
+Author: Twiller Smith, Victim Specialist, Federal Bureau of Investigation, West Palm Beach,
+Florida.
+Letter to James Eisenberg, dated January 10, 2008; RE;
+→ 12
+pages); Author: Twiller Smith, Victim Specialist, Federal Bureau of Investigation, West Palm
+Beach, Florida.
+Letter to S.R., dated May 30, 2008, RE:
+_ (2 pages);
+Author: Twiller Smith, Victim Specialist, Federal Bureau of Investigation, West Palm Beach,
+Letter to Brad Edwards, Esq., dated July 9, 2008, RE: Jeffrey Epstein/C.W.:
+Notification of Identified Victim (2 pages); Author: A. Marie Villafana.
+Letter to Brad Edwards, Esq., dated July 9, 2008, RE: Jeffrey Epstein/S.R.:
+Notification of Identified Victim (2 pages); Author: A. Marie Villafana.
+(b)
+Letter to R. Alexander Acosta, dated October 10, 2007, RE: Jeffrey Epstein (6
+pages); Author: Jay P. Lefkowitz, Kirkland & Ellis
+Letter to R. Alexander Acosta, dated November 29, 2007, RE: Jeffrey Epstein (4
+pages), Author: Jay Lefkowitz, Kirkland & Ellis, with attachment of draft Crime Victims'
+Rights - Notification of Resolution of Epstein Investigation (4 pages), dated November 29,
+2007; Author: A. Marie Villafana.
+Letter to R. Alexander Acosta, dated December 5, 2007, RE: Jeffrey Epstein (2
+pages), Author: Kenneth W. Starr and Jay Lefkowitz, Kirkland & Ellis
+Letter to Jay P. Lefkowitz, Esq., Kirkland & Ellis, dated December 6, 2007, RE:
+Jeffrey Epstein (4 pages); Author: Jeffrey H. Sloman, First Assistant U.S. Attorney, with
+attached draft letter RE: Crime Victims' Rights - Notification of Resolution of Epstein
+Investigation (4 pages); Author: A. Marie Villafana.
+Letter to R. Alexander Acosta, dated December 11, 2007, RE: Jeffrey Epstein (13
+pages), Author: Jay Lefkowitz
+Letter to Lilly Ann Sanchez, dated December 19, 2007, RE: Jeffrey Epstein (3
+pages)
+Letter to R. Alexander Acosta, dated December 21, 2007, RE: Jeffrey Epstein (7
+pages), Author: Jay Lefkowitz
+Letter to R. Alexander Acosta, dated December 26, 2007, RE: Jeffrey Epstein (5
+2
+
+
+pages), Author: Jay Lefkowitz
+Request for Production No. 3 (confidentiality provision)
+Letter to Matthew Menchel, Chief, Criminal Division, U.S. Attorney's Office, dated
+August 2, 2007, RE: Jeffrey Epstein (3 pages), Author: Lilly Ann Sanchez
+Letter to Lilly Ann Sanchez, Esq., dated August 3, 2007, RE: Jeffrey Epstein (2 pages),
+Author: Matthew Menchel
+E-mail, Marie Villafana to Gerald Lefcourt, dated September 10, 2007 5:23 p.m., RE:
+Jeffrey Epstein (2 pages with 4 page draft Non-Prosecution Agreement)
+Revised Ai, Mate Vilem 2 paged to pug, dated September in A8215 pm tehed)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 12, 2007 3:44 p.m., RE:
+Jeffrey Epstein (2 pages)
+E-mail, Jay Lefkowitz to Marie Villafana and Andrew Lourie, dated September 12, 2007
+5:55 p.m., RE: Jeffrey Epstein (2 pages)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 13, 2007 7:27 p.m., RE: no
+subject (1 page)
+E-mail, Jay Lefkowitz to Marie Villafana, dated September 13, 2007, 7:35 p.m., RE: no
+subject (2 pages)
+E-mail, Jay Lefkowitz to Marie Villafana, dated September 14, 2007 9:40 a.m., RE:
+Follow up (1 page)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 14, 2007 9:54 a.m., RE: Plea
+documents (1 page with 2 page draft Information, and 7 page draft Plea Agreement, attached)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 14, 2007 9:56 a.m., RE:
+Follow up (2 pages)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 17, 2007 11:45 a.m., RE:
+Non-Prosecution Agreements (1 page with 4 page draft Non-Prosecution Agreement attached)
+Dran Agreements il pilatana to Jay Lerkowitz, dated September 18, 2007 8:44 a.m., RE:
+E-mail, Jay Lefkowitz to Marie Villafana, dated September 18, 2007 9:18 a.m., RE Draft
+Agreements? (2 pages)
+3
+
+
+E-mail, Jay Lefkowitz to Marie Villafana, dated September 18, 2007 11:09 a.m., RE:
+Draft Agreements? (2 pages, with 6 page draft Non-Prosecution Agreement)
+E-mail, Jay Lefkowitz to Marie Villafana, dated September 18, 2007 11:52 a.m., RE:
+Draft Agreements? (2 pages, with 5 page draft Non-Prosecution Agreement)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 18, 2007 12:44 p.m., RE:
+Draft Agreements? (3 pages)
+E-mail, Marie Villafana to Jay Lefkowitiz, dated September 18, 2007 1:22 p.m., RE:
+Draft Agreements? (4 pages, with 9 page draft Plea Agreement)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 18, 2007 2:53 p.m., RE:
+Factual Proffer (1 page)
+E-mail, Marie Villatana to Jay Lefkowitz, dated September 19, 2007 10:39 a.m. RE:
+Draft Agreements? (1 page)
+E-mail, Jay Lefkowitz to Marie Villafana, dated September 19, 2007 10:45 a.m., RE:
+Draft Agreements? (1 page)
+E-mail, Marie Villafana to Jay Lefkowitiz, dated September 19, 2007 11:18 a.m., RE:
+Draft Agreements? (1 page)
+E-mail, Jay Lefkowitz to Marie Villafana, dated September 19, 2007 11:36 a.m., RE:
+Draft Agreements? (2 pages)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 19, 2007 11:46 a.m., RE:
+Draft Agreements? (3 pages)
+E-mail, Jay Lefkowitz to Marie Villafana, dated September 19, 2007 3:44 p.m., RE: FW
+Draft Plea Agreement (1 page, with 12 page draft Plea Agreement)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 20, 2007 3:52 p.m., RE:
+Final version of Plea Agreement - Epstein (2 pages, with 8 page draft Plea Agreement)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 20, 2007 3:54 p.m., RE
+Epstein Plea Agreement (1 page, with 8 page draft Plea Agreement)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 20, 2007 5:33 p.m., RE:
+Final version of Plea Agreement - Epstein (2 pages)
+E-mail, Jay Lefkowitz to Marie Villafana, dated September 20, 2007 6:12 p.m., RE: Plea
+Agreement - Epstein (1 page)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 20, 2006 6:42 p.m., RE: Plea
+4
+
+
+Agreement - Epstein (2 pages)
+E-mail, Jay Lefkowitz to Marie Villafana, dated September 21, 2007 10:44 a.m.., RE:
+Plea Agreement - Epstein (2 pages, with 4 page draft Non-Prosecution Agreement)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 21, 2007 10:57 a.m., RE:
+Plea Agreement - Epstein (3 pages)
+E-mail, Barry Krischer, State Attorney to Marie Villafana, dated September 21, 2007
+12:03 p.m., RE: Meeting with Epstein's attorneys (1 page)
+E-mail, Jay Lefkowitz to Marie Villafana, dated September 21, 2007 2:46 p.m., RE:
+Reminder (1 page, with 1 page Plea in the Circuit Court Form 005 attached)
+E-mail, Marie Villatana to Jay Lefkowitz, dated September 21, 2007 2:54 p.m., RE:
+Reminder (2 pages)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 21, 2007 2:55 p.m., RE:
+Immigration Question (1 page)
+E-mail, Jay Lefkowitz to Alex Acosta, dated September 23, 2007 11:58 a.m., RE: Jeffrey
+Epstein - confidential (2 pages)
+E-mail, Jay Lefkowitz to Marie Villafana, dated September 23, 2007 1:42 p.m., No
+Subject (1 page)
+E-mail, Ami Sheth, Kirkland & Ellis to Marie Villafana, dated September 23, 2007 1:57
+p.m., RE: FW: Draft Agreement (1 page with 6 page draft Non-Prosecution Agreement)
+E-mail, Marie Villafana to Jay Lefdowitz, dated September 23, 2007 4:03 p.m., RE:
+Draft Agreement (2 pages with 6 page draft Non-Prosecution Agreement attached)
+E-mail, Alex Acosta to Jay Lefkowitz, dated September 23, 2007 4:31 p.m., RE: (no
+subject) (2 pages)
+E-mail, Marie Villafana to Jay Lefkowtiz, dated September 23, 2007 8:01 p.m., RE:
+Revised agreement (1 page)
+E-mail, Jay Lefkowitz to Marie Villafana, dated September 23, 2007 8:31 p.m., RE: Fw
+(1 page with 7 page draft Non-Prosecution Agreement attached)
+E-mail, Jay Lefkowitiz to Marie Villafana, dated September 23, 2007 8:35 p.m., RE: no
+subject (1 page)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 23, 2007 8:37 p.m., RE: no
+subject (1 page)
+5
+
+
+E-mail, Jay Lefkowitz to Marie Villafana, dated September 23, 2007 8:39 p.m., RE: no
+subject (2 pages)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 23, 2007 8:58 p.m., RE:
+Epstein Agreement (1 page with 6 page draft Non-Prosecution Agreement attached)
+E-mail, Jay Lefkowitz to Marie Villafana, dated September 24, 2007 7:54 a.m., RE:
+Epstein (1 page)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 24, 2007 10:14 a.m., RE:
+Epstein agreement as reviewed by the U.S. Attorney (1 page with 6 page draft Non-Prosecution
+Agreement attached)
+E-mail, Jay Lefkowitz to Marie Villafana, dated September 24, 2007 11:46 a.m., RE:
+Epstein agreement as reviewed by the U.S. Attorney (1 page with 6 page Non-Prosecution
+Agreement, and 8 page Non-Prosecution Agreement, attached)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 24, 2007 1:28 p.m., RE:
+Epstein agreement as reviewed by the U.S. Attorney (3 pages with 7 page draft Non-Prosecution
+Agreement attached)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 24, 2007 2:16 p.m., RE: The
+final final (1 page with 7 page Non-Prosecution Agreement attached)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 24, 2007 4:03 p.m., RE: Do
+you have a signed copy? (1 page)
+E-mail, Jay Lefkowitz to Marie Villafana, dated September 24, 2007 4:06 p.m., RE: Do
+you have a signed copy? (1 page with 9 page Non-Prosecution Agreement attached)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 24, 2007 4:32 p.m., RE: Do
+you have a signed copy? (1 page)
+Request for Production No. 5 (legal representation of victims)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 25, 2007 8:37 p.m., RE:
+Other attorneys (1 page)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 26, 2007 11:01 a.m., RE:
+Other attorneys (2 pages)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 26, 2007 11:49 a.m., RE:
+One more thing (2 pages)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 27, 2007 10:52 a.m., RE
+Conference Call with Bert Ocariz (1 page)
+6
+
+
+E-mail, Jay Lefkowitz to Marie Villafana, dated September 27, 2007 10:57 a.m., RE:
+Conference call with Bert Ocariz (2 pages)
+E-mail, Marie Villafana to Jay Lefkowtiz, dated September 27, 2007 11:08 a.m., RE:
+Conference Call with Bert Ocariz (2 pages)
+E-mail, Marie Villafana to Jay Lefkowitz, dated September 27, 2007 3:06 p.m., RE:
+Conference Call with Bert Ocariz (3 pages)
+E-mail, Marie Villafana to Jay Lefkowitz, dated October 3, 2007 3:15 p.m., RE: no
+subject (2 pages, with 1 page Special Master Proposal attached)
+E-mail, Marie Villafana to Jay Lefkowitz, dated October 3, 2007 3:38 p.m., RE: no
+subject (2 pages)
+E-mail, Marie Villafana to Jay Lefkowitz, dated October 3, 2007 4:23 p.m., RE:
+Proposed Letter to Special Master (2 pages with 2 page Proposed Letter to the Special Master
+attached)
+E-mail, Marie Villafana to Jay Lefkowitz, dated October 3, 2007 7:30 p.m., RE:
+Proposed Letter to Special Master (1 page)
+E-mail, Marie Villafana to Jay Lefkowitz, dated October 5, 2007 7:49 p.m., RE:
+Proposed Letter to Special Master (2 pages)
+E-mail, Jay Lefkowitz to Marie Villafana, dated October 5, 2007 11:04 a.m., RE:
+Proposed Letter to Special Master (3 pages with 4 page letter from Jay Lefkowitz to Marie
+Villafana attached)
+Letter to Jeffrey Sloman, dated October 8, 2007, RE: Jeffrey Epstein (3 pages), Author:
+Lilly Ann Sanchez
+E-mail, Marie Villatana to Lilly Ann Sanchez, October 9, 2007 5:09 p.m., RE: Jeffrey
+Epstein (1 page with two page letter to Lilly Ann Sanchez attached)
+E-mail, Jeff Sloman to Jay Lefkowitz, dated October 22, 2007 4:41 p.m., RE: Epstein (3
+pages with 4 page draft letter to Hon. Edward B.
+, and 2 page Addendum to the Non-
+Prosecution Agreement, attached)
+E-mail, Jay Lefkowitz to Jeff Sloman, dated October 22, 2007 5:10 p.m., RE: Epstein (3
+pages)
+E-mail, Jeff Sloman to Jay Lefkowitz, dated October 24, 2007 3:45 p.m., RE: Epstein -
+Addendum and Letter to Judge
+(2 page Addendum to the Non-Prosecution Agreement,
+and 4 page draft letter to Hon. Edward B.
+, attached)
+7
+
+
+E-mail, Jeff Sloman to Jay Lefkowitz, dated October 24, 2007 5:30 p.m., RE: Epstein -
+Letter to Judge
+(1 page with 4 page letter to Hon. Edward B.
+attached)
+Letter to Hon. Edward B
+,, Akerman Senterfitt, dated October 25, 2007, RE:
+Service as a Special Master (4 pages); Author: Jeff Sloman
+E-mail, Jeff Sloman to Jay Lefkowitz, dated October 31, 2007 11:51 a.m., RE: Epstein
+(2 pages)
+E-mail, Jay Lefkowitz to Jeff Sloman, dated November 8, 2007 1:24 p.m., RE: No
+subject (1 page)
+E-mail, Jay Lefkowitz to Jeff Sloman, dated November 16, 2007 2:00 p.m., RE: No
+subject (1 page)
+E-mail, Jeff Sloman to Jay Lefkowitz, dated November 27, 2007 1:55 p.m., RE: Epstein
+(1 page)
+Letter to Jeffrey Sloman, dated December 7, 2007, RE: Jeffrey Epstein, Author: Lilly
+Ann Sanchez (1 page Affirmation signed by Jeffrey E. Epstein, 1 page Notice of Hearing, and 1
+page fax transmittal sheet, attached)
+E-mail, Marie Villafana to Jack Goldberger, dated June 28, 2008 11:31 a.m., RE: Notice
+of Non-Compliance (1 page)
+Request for Production No. 8 (Lobbying efforts at DOJ)
+E-mail, Jeff Sloman to Jay Lefkowitz, dated February 25, 2008 7:43 p.m., RE: Epstein (1
+page)R
+E-mail, Jeff Sloman to Jay Lefkowitz, dated February 27, 2008 9:45 p.m., RE: Fw:
+Epstein (2 pages)
+Letter to Jay Lefkowitz, Esq., dated May 15, 2008, RE: Investigation of Jeffery Epstein
+(5 pages), Author: Andrew G. Oosterbaan, Chief, Child Exploitation and Obscenity Section,
+Criminal Division, U.S. Department of Justice
+E-mail, Jay Lefkowitz to Alex Acosta, dated May 19, 2008 10:54 a.m., RE: confidential
+communication (3 pages)
+Letter to Honorable Mark Filip, Deputy Attorney General, dated May 19, 2008, No
+Subject (8 pages), Authors: Kenneth W. Starr, Kirkland & Ellis, and Joe D. Whitley, Alston &
+Bird
+8
+
+
+Letter to Honorable Mark Filip, Deputy Attorney General, dated May 27, 2008, No
+Subject (2 pages), Authors: Kenneth W. Starr, Kirkland & Ellis, and Joe D. Whitley, Alston &
+Bird
+E-mail, Jeff Sloman to Jay Lefkowtiz, dated May 28, 2008 4:51 p.m., RE: Jeffrey
+Epstein (1 page)
+Letter to Kenneth Starr and Joe D. Whitley, dated June 3, 2008, No Subject (1 page),
+Author: John Roth, Senior Associate Deputy Attorney General
+Letter to John Roth, Senior Associate Deputy Attorney General, dated June 19, 2008, No
+Subject (14 pages), Author: Stephanie D. Thacker, Allen Guthrie McHugh & Thomas,
+Charleston, West
+Letter to Jay Lefkowitz and Kennth Starr, dated June 23, 2008, No Subject (1 page),
+Author: John Roth, Senior Associate Deputy Attorney General
+Request for Production No. 19: (prosecutor misconduct)
+Letter to R. Alexander Acosta, dated December 11, 2007, RE: Jeffrey Epstein (20
+pages); Author: Jay Lefkowitz
+Letter to Jay P. Lefkowitz, Esq., dated December 13, 2007, RE: Jeffrey Epstein (5
+pages); Author: A. Marie Villafana.
+E-mail, Jay Lefkowitz to Alex Acosta, dated February 29, 2008 3:11 p.m., RE: Fw
+Epstein (1 page)
+Letter to Office of Professional Responsibility, U.S. Department of Justice, dated April
+21, 2008, RE: Self Reporting - Jeffrey H. Sloman, FAUSA S.D.F.L. (3 pages, with 5 pages of
+attachments); Author: Jeffrey H. Sloman (P)
+Letter to Office of Professional Responsibility, U.S. Department of Justice, dated April
+22, 2008, RE: Self-Report of Allegation of Conflict of Interest (9 pages); Author: A. Marie
+Villafana (P)
+Memorandum to Office of Professional Responsibility, dated April 23, 2008, Subject:
+Self Reporting - Jeffrey H. Sloman, Corrected Version of the previously submitted April 21,
+2008 letter to OPR (1 page, with 3 page letter attached); Author: Jeffrey H. Sloman (P)
+Letter to Deputy Attorney General Mark Filip, dated May 19, 2008, No Subject, Authors:
+Kenneth W. Starr and Joe D. Whitley, attachment entitled "Summary of Misconduct Issues in the
+Matter of Jeffrey Epstein"
+9
+
+
+An "attorney for the government" did not confer with Jane Doe #1 or Jane Doe #2 about the
+specific terms of the Non-Prosecution Agreement prior to:
+(a)
+(b)
+(c)
+its execution on September 24, 2007;
+the execution of the Addendum to the Non-Prosecution Agreement on October
+29,2007; and
+the commencement of the performance of the Non-Prosecution Agreement on
+June 30, 2008.
+
+
+To:
+Cc:
+Subject:
+Tuesday, July 16, 2013 4:03 PM
+Sanchez, Eduardo (USAFLS)
+Lee, Dexter (USAFLS)|
+RE: Responses to RFAS
+Recipient
+Sanchez, Eduardo (USAFLS)
+Lee, Dexter (USAFLS)
+Read
+Read: 7/16/2013 4:17 PM
+Read: 7/16/2013 5:49 PM
+Hi Ed - There are some issues that I think you want to include in the RFA's:
+Overall - you need to change "the government" to "the USAO"
+No. 2(a): My contact with JD#2's attorney, Jim Eisenberg, to ask him whether we should send the letter to him
+or directly to JD#2, is what started the firestorm regarding victim notifications. I think that is significant
+because she is one of the petitioners in this case.
+No. 2(c): Remove "and her then-attorney"
+No. 2(d): The USAO denies that the language in its 2006 and 2007 victim notification letters to Jane Doe #1
+and Jane Doe #2 were affected in any way by contact with counsel for Jeffrey Epstein. The USAO also denies
+that the language in the FBI's letters to Jane Doe #1 and Jane Doe #2 were affected in any way by contact with
+counsel for Jeffrey Epstein. The language of the July 9, 2008 letter to Jane Doe #1 in care of Bradley Edwards
+was altered after receiving objections to victim notifications from counsel for Jeffrey Epstein and reevaluation
+of the victim notification obligations by the USAO.
+No. 2(e): You need to make clear that Jane Doe #2 was never officially notified about the NPA because it was
+determined that she was not a person whom the USAO was prepared to name in an indictment.
+No. 7: You need to make clear that the FBI was still actively investigating the case as of that time, including
+interviewing additional victims. We did grand jury appearances in March and April 2008.
+No. 9(e): You can make clear that the FBI notified Jane Doe #1 at the request of the USAO because they met
+with her at my request. You again need to reiterate that Jane Doe #2 was never officially notified about the
+NPA because it was determined that she was not a person whom the USAO was prepared to name in an
+indictment due to her videotaped denial that she was sexually abused by JE, that he was an "awesome man" and
+that she would like to marry him.
+No. 11: Do you think that your answer waives the attorney-client/work product/deliberative process
+privilege? Also, you have deleted the fact that the November 2007 letters didn't go out because of the appeal to
+Washington.
+No. 13(a): I might change to say "although the USAO had notified Jane Doe #1, through FBI agents, of the
+existence of' an agreement and had summarized its essential terms, .…."
+1
+
+
+No. 13(b): I recommend adding: During interviews with Jane Doe #1 and Jane Doe #2 prior to entering into
+the Non-Prosecution Agreement, both were asked their opinions about prosecution by an "attorney for the
+government" and Jane Doe #1 was asked about her willingness to serve as a witness at trial by an "attorney for
+the government." Both were provided with contact information for an "attorney for the government" and
+invited to contact that attorney at any time. At no time prior to the signing of the Non-Prosecution Agreement
+or Jeffrey Epstein's June 30, 2008 guilty plea did Jane Doe #1 or Jane Doe #2 ask to confer with an attorney for
+the government.
+No. 13(c): You may want to say something about the USAO's knowledge that JD#2 was represented by
+counsel paid for by Epstein.
+No. 13(d): No, other than the confidentiality provision that appears in the agreement, there was nothing
+specifically aimed at talking to the victims.
+No. 16 - Wait until I finish. I need to go back and double-check. Just keep this highlighted for now.
+No. 23 - Do you want to add something about - "provided that Epstein does not breach the agreement"
+No. 26 - Do you want to add something about the information being covered by other privileges? (investigative
+privilege)?
+Thank you for all of your help with these!
+A. Marie Villafaña
+Assistant U.S. Attorney
+Southern District of Florida
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+ann.marie.c.villafana@usdoj.gov
+561-209-1047
+From: Sanchez, Eduardo (USAFLS)
+Sent: Monday, July 15, 2013 7:59 PM
+To: Villafana, Ann Marie C. (USAFLS); Lee, Dexter (USAFLS)
+Subject: RE: Responses to RFAs
+Attached are my suggested edits and thoughts.
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Monday, June 24, 2013 9:56 PM
+To: Lee, Dexter (USAFLS); Sanchez, Eduardo (USAFLS)
+Subject: Responses to RFAs
+Hi Dexter and Ed - Here is my stab at a response. There are a number that I cannot answer.
+2
+
+
+• Isn't the only real factual issue whether or not we conferred with the victims PRIOR TO SIGNING the NPA?
+The closest that they come to asking that is 13(b) and even that isn't quite right. Should we suggest that they
+send a revised RFA asking simply:
+"An attorney for the government did not confer with Jane Doe #1 or Jane Doe #2 prior to entering into the
+NPA."
+« File: Response to Requests for Admissions.docx >>
+A. Marie Villafaña
+Assistant U.S. Attorney
+Southern District of Florida
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+ann.marie.c.villafana@usdoj.gov
+561-209-1047
+3
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/ca2e9bd59038883eeb5f7e8095f1081bd57ecd0ac29e5fdcdb3b4b1cdd27c757.receipt.json b/vision-fixhub/ds9-unparsed-05/ca2e9bd59038883eeb5f7e8095f1081bd57ecd0ac29e5fdcdb3b4b1cdd27c757.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..bb2df2b63c5bd493bbcbb14fb0074e58111df31e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ca2e9bd59038883eeb5f7e8095f1081bd57ecd0ac29e5fdcdb3b4b1cdd27c757.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -2318,
+  "dataset": "marble-joined",
+  "doc_id": "ca2e9bd59038883eeb5f7e8095f1081bd57ecd0ac29e5fdcdb3b4b1cdd27c757",
+  "engine": "marble-apple-vision",
+  "event_count": 54,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "05400c7b1c17a6a00caa792e9a3eb5f398c7c8e6c26f6fb7a6cccf2ac533993b",
+  "output_sha256": "ab2c22fd10f76302fd523a0757fd9c0450aac1b0eaec3d3407ae4815a2516477",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ca3a938e3c846197a8ffb6722fb1c3ee1d5d447413f7fa06aa12c26ba56d27a8.md b/vision-fixhub/ds9-unparsed-05/ca3a938e3c846197a8ffb6722fb1c3ee1d5d447413f7fa06aa12c26ba56d27a8.md
new file mode 100644
index 0000000000000000000000000000000000000000..91b8d7419848ee82715580ce36cc979e9d515328
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ca3a938e3c846197a8ffb6722fb1c3ee1d5d447413f7fa06aa12c26ba56d27a8.md
@@ -0,0 +1,45 @@
+HERMAN & MERMELSTEIN PA
+ATTORNEYS AT LAW
+Jeffrey.M. Herman
+701005 021 2000.
+Fax 305.931.0877
+18205 Biscayne Blvd.
+Suite 2218
+Miami, Florida 33160
+www.hermanlaw.com
+September 16, 2008
+Via Fax and Regular Mail
+Assistant U.S. Attorney
+500 Australian Ave., Fourth Floor
+West Palm Beach, FL 33401
+Re:
+Jeffrey Epstein
+Dear Ms.
+This concerns your letters to us and to sexual assault victims of Mr. Epstein dated September
+2, 2008. Please be advised that we strenuously object to your letters on various grounds, and believe
+that they are in violation of the Florida Bar Rules.
+First, your letters attempt to steer the victims to a particular attorney, Mr. Josefsberg, and
+advise them that Mr. Josefsberg will be making an unsolicited contact to them in the next two weeks.
+This contact with prospective clients and solicitation reflected in your letters is contrary to Fla. Bar.
+Rule 4-7.4. Additionally, your letters are misleading in the following respects: (1) the action
+advocated to the victims in paragraph 2 refers generally to the victims' waiver of "any other claim for
+damages", failing to advise them that this waiver may include a valuable claim to punitive damages
+against an alleged billionaire; and (2) the letters imply in paragraph 3 that Mr. Epstein's agreement to
+pay attorney fees is a significant concession, when in fact a victim is entitled to reasonable attorneys'
+tees under the Statute upon proof of a violation, irrespective of Mr. Epstein's agreement.
+We accordingly demand that the U.S. Attorneys' office immediately cease and desist from
+directing unrepresented victims into unsolicited attorney contacts and misleading them about their
+rights in claims against Mr. Epstein. We demand that you instruct Mr. Josefsberg not to solicit
+victims, and to send letters to unrepresented victims correcting the misleading statements contained
+in your September 2, 2008 letters.
+
+
+sq.
+September 16, 2008
+Page 2
+Finally, we demand that you make no contact with our clients directly, and contact them only
+through our office. Our clients includel
+I and
+Sincerely,
+Jeffrey M. Herman
+JMH/Ir
diff --git a/vision-fixhub/ds9-unparsed-05/ca3a938e3c846197a8ffb6722fb1c3ee1d5d447413f7fa06aa12c26ba56d27a8.receipt.json b/vision-fixhub/ds9-unparsed-05/ca3a938e3c846197a8ffb6722fb1c3ee1d5d447413f7fa06aa12c26ba56d27a8.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ffa6010fc788624cdc3083e74a111082c4b627c5
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ca3a938e3c846197a8ffb6722fb1c3ee1d5d447413f7fa06aa12c26ba56d27a8.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "ca3a938e3c846197a8ffb6722fb1c3ee1d5d447413f7fa06aa12c26ba56d27a8",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e6858e29c8aab80404d9d4c94528649e96d91393e56aaa3bff739641e30e4874",
+  "output_sha256": "f1c9e249d6b1e7edaeedf8bf5b514c60647ce600cdb89c93271eec6a120462c8",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/cada4afe924c923ba4bc9b06d009465230af01b034125b8d5e3039b6ee047ad6.md b/vision-fixhub/ds9-unparsed-05/cada4afe924c923ba4bc9b06d009465230af01b034125b8d5e3039b6ee047ad6.md
new file mode 100644
index 0000000000000000000000000000000000000000..226cbea7163c860ab9d0e9d3558af0ffaca6c46b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cada4afe924c923ba4bc9b06d009465230af01b034125b8d5e3039b6ee047ad6.md
@@ -0,0 +1,48 @@
+OLY-75
+FBI ANALYST CHARTS
+JD # 3
+
+
+Viuted States District court
+SOUTHERN DISTRICT OF FLORIDA
+TO: HARRY BELLER
+NES, LLC
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FG.J 07-103(WPB)/No. OLY-75
+SUBPOENA FOR:
+X PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+September 11, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following document(s) or objects):
+*Please coordinate vaur comnlizuco with this subpoena and confirm the date, time, and location of vour:
+appearance with
+, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+August 16, 2007
+This subpoena is issued upon application
+of the United States of America
+*If not applicable, enter "none."
+DAN DESTRIKET ONT
+Name, Address and Phone Number of Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. EL. 33401-6235
+Tel:
+Fax:
+To be used in lieu of AO110
+FORM ORD-227
+JAN.86
diff --git a/vision-fixhub/ds9-unparsed-05/cada4afe924c923ba4bc9b06d009465230af01b034125b8d5e3039b6ee047ad6.receipt.json b/vision-fixhub/ds9-unparsed-05/cada4afe924c923ba4bc9b06d009465230af01b034125b8d5e3039b6ee047ad6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3b78036b6835e55ae0bb2e5785419779bf0a331b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cada4afe924c923ba4bc9b06d009465230af01b034125b8d5e3039b6ee047ad6.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "cada4afe924c923ba4bc9b06d009465230af01b034125b8d5e3039b6ee047ad6",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "258075910f03719c6d6500ffd7be67dbb9282e0492a6eaae40a460e61cd8d1f3",
+  "output_sha256": "c141f7233644760d16058d191c98b238d7cc670249fb2153d127fe58b9a878e4",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/cb080063892043f39c690f08e430fd623bbd46b2a38c4eb07365ea08de7f6140.md b/vision-fixhub/ds9-unparsed-05/cb080063892043f39c690f08e430fd623bbd46b2a38c4eb07365ea08de7f6140.md
new file mode 100644
index 0000000000000000000000000000000000000000..9ec085e4b0d2a9422cc071993b1c5e6c7dd3700c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cb080063892043f39c690f08e430fd623bbd46b2a38c4eb07365ea08de7f6140.md
@@ -0,0 +1,2582 @@
+
+
+Janusz BanadiaR
+Visa statemats for
+- ocloc-os/o5
+
+
+United States Attorney
+Southern District of Florida
+500 South Australian Averve, Svite 400
+West Palm Beach, Florida 33401-6235
+el: (561) 820-871.
+a: (56]) 820-877
+June 75,2007
+VIA FACSIMILE
+Colonial Bank
+Hoover, AL 35243
+Re: Federal Grand Jury Subpoenas OLY-01 and OLY-28
+Dear Ms. Muller:
+I write to follow up on Colonial Bank's response to two federal grand jury subpoenas
+numbered OLY-01 and OLY-28. Colonial Bank has responded to both of these subpoenas, but
+it appears that some items are incomplete.
+I have enclosed copies of the subpoenas, but, in short, they seek all account opening
+documentation and correspondence related to Jeffrey Epstein,
+[or
+Janusz Banasiak [or Banasiar],
+Alfredo Rodriguez,
+NES, LLC, Jeffrey Epstein Household, and JEGE, Inc. The subpoenas also ask for account
+statements, canceled checks, and billing statements for accounts and credit cards related to those
+individuals/entites for the period of January 1, 2004 through December 31, 2006.
+The items that appear to be missing are:
+(1) Billing statements for VISA account number
+February 1, 2005 through April 30, 2005.
+for the period of
+
+
+Anita Muller-Page 2
+(2) Billing statements for the following VISA account numbers for the period of
+9004 through December 31, 2006:
+(3) Account statements and canceled checks for the period of January 1, 2004 through
+December 31, 2006, for accounts in the names of
+lor
+and/or
+(4) Account statements, account opening documents, correspondence and canceled
+checks (front and back), related to a multitude of accounts related to Mr. Epstein, including
+account numbers
+From the review of the documents we have received thus far, it appears that there
+probably are several more accounts related to Mr. Epstein and the other listed
+individuals/entities. For example, there appear to be several more VISA cards associated with
+the NES, LLC master account. So, in addition to providing the items specifically listed in this
+letter, please re-review the records of the bank to determine if there are more documents
+responsive to the two subpoenas.
+I have enclosed another Certification of Business Records to authenticate and records
+that you produce in response to this letter. Please send the Certification and the records to
+Special Agent
+1, Federal Bureau of Investigation,
+West Palm Beach, FL 33401.
+If you have any questions, please feel free to contact me at
+your assistance.
+Thank you for
+Sincerely,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Assistant United States Attorney
+
+
+.."
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+IN RE FEDERAL GRAND JURY SUBPOENAS
+OLY-01 AND OLY -28
+ADDRESSED TO COLONIAL BANK
+CERTIFICATION REGARDING DOMESTIC RECORDS
+OF REGULARLY CONDUCTED ACTIVITY
+I, the undersigned,
+Colonial Bank in the position of
+, declare that I am employed by
+, and, by reason of my
+position, am authorized and qualified to make this declaration.
+In my employment with Colonial Bank, I am familiar with the business records it
+1.
+maintains.
+I certify that the records attached to this certification:
+(a)
+were made at or near the time of the occurrence of the matters set forth
+(b)
+(c)
+therein, by or from information transmitted by, a person with knowledge of
+those matters;
+were kept in the course of regularly conducted business activity; and
+were made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A
+(Document Inventory).
+I further certify that the documents attached hereto are responsive to the Grand Jury
+
+
+
+Subpoenas served upon Colonial Bank.
+I further certify that Colonial Bank has no documents responsive to request number
+_ in Grand Jury Subpoena number
+- [Fill in or strike out as appropriate.]
+Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing
+information is true and correct.
+Executed this
+day of
+_ 2007.
+Place of execution:
+Signature
+
+
+
+APPENDIX A
+DOCUMENT INVENTORY
+The documents submitted are as follows:
+Signature of Records Custodian:
+
+
+06/19/2007 14:39 FAX 5618021787
+USAO WPB FL
+*******
+TX REPORT
+$#8
+******************
+4001
+TRANSMISSION OK
+TX/RX NO
+CONNECTION TEL
+SUBADDRESS
+CONNECTION ID
+ST. TIME
+USAGE T
+PGS. SENT
+RESULT
+4930
+06/19 14:38
+00'55
+6
+OK
+United States Attorney
+Southern District of Florida
+500 S. Australian Ave, 4th Floor
+West Palm Beach, Florida 33401
+FACSIMILE COVER SHEET
+attn: Anita Muller
+TO:
+DATE:
+FAX NO.
+PHONE NO.
+FROM:
+PHONE NO.
+COMMENTS:
+June 19, 2007
+# OF PAGES: 6
+RE: Grand Jury Subpoenas OLY-01 & OLY-28
+
+
+United States Attorney
+Southern District of Florida
+500 S. Australian Ave, 4th Floor
+West Balm Reach Elorida 33401
+FACSIMILE COVER SHEET
+1, attu: Anita Muller
+TO:
+DATE:
+FAX NO.
+PHONE NO.
+FROM:
+PHONE NO.
+COMMENTS:
+June 19, 2007
+# OF PAGES: 6
+RE: Grand Jury Subpoenas OLY-01 & OLY-28
+Assistant U.S. Attorney
+
+
+TO:
+COLONIAL BANK
+Fa
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-01
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTIS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury ofthe United States District
+Court at the place, date and time specified below.
+PLACE:
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+ROOM:
+Room 4-A
+DATE AND TIME:
+August 18, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+All applications, signature cards, credit or background investigations conducted, and correspondence
+related to Jeffrey Epstein,
+Janusz Banasiak,
+Alfredo Rodriguez, and/or VISA Account Number
+For the period of January 1, 2004 to the present, all monthly billing statements, individual charge
+invoices, repayment records disclosing the dates, amounts, and method of repayment, and checks used
+to make repayments (front and back) for VISA Account Number
+Please coordinate your compliance of this subpoena and confirm the date and time of your appearance with
+Federal Bureau of Investigation, Telephone:
+Special Agent
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf'
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+August 2, 2006
+This subpoena is issued upon application
+of the Upited States of America
+want U.S. Attorney
+rney
+500 So. Australian Avenue, Suite 400
+IT 27101 6235
+*If not applicable, enter "none."
+Tel
+Fas
+To be used in lieu of AQ110
+FORM ORD-227
+
+
+JAN.86
+RECEIVED
+BY SERVER
+SERVED
+RETURN OF SERVICE'
+DA /0/01 ME est Palm Beach, F
+DA 8/(08l06 MAcE Hooner, AL CUrA VAR)
+SERVED ON (NAME)
+SERVED BY
+ColoNiAL Bank CAvita Muller)
+TITLE
+FBI Special Agent
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Retur of Service and
+Statement of Service Fees is true and correct.
+Eman on 3/08/06
+Signature of Serve
+Address of Server
+ADDITIONAL INFORMATION
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
+Rule 45(c), Federal Rules of Civil Procedure.
+1825, Rule 17(b) Federal Rules of Criminal Procedure)"
+
+
+TO: COLONIAL BANK
+Hoover, AL 35243
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-01
+SUBPOENA FOR:
+] PERSON
+DOCUMENTS OR OBJECTIS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+ROOM:
+Room 4-A
+DATE AND TIME:
+August 18, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+All applications, signature cards, credit or background investiontions conducted, and correspondence
+related to Jeffrey Epstein,
+lor
+Janusz Banasiak,
+,, Alfredo Rodriguez, and/or VISA Account Numberl
+For the period of January 1, 2004 to the present, all monthly billing statements, individual charge
+nvoices, repayment records disclosing the dates, amounts, and method of renayment, and cheeks use
+o make repayments (front and back) for VISA Account Number
+Please coordinate your compliance of this subpoena and confirm the date and time of vour appearance with
+Special Agent
+Federal Bureau of Investigation, Telephone!
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+August 2, 2006
+This subpoena is issued upon application
+of the Upited States of America
+*If not applicable, enter "none."
+Name Address and Phone Number of Assistant IT.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+Tel:
+Fax
+To be used in lieu of AO110
+FORM ORD-227
+
+
+JAN.86
+RECEIVED
+BY SERVER
+SERVED
+DA 08/03/06
+DAT 08/68/06
+RETURN OF SERVICE'
+PA est Palm Beach, FI
+ruct Hoover, AL CUrA VAR)
+SERVED ON (NAME)
+SERVE
+ColoNiAL Bank (Anita Muller)
+TITLE
+FBI Special Aget
+STATEMENT OF SERVICE FEES
+TRAVEL
+SERVICES
+TOTAL
+DECLARATION OF SERVICE
+Statemeat or Serie fates of pere and nor the laws of the United States of America that the foregoing information contained in the Retum of Service and
+Eran on 08/28/06.
+Signature of Serv
+Address of Server
+ADDITIONAL INFORMATION
+1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules, of Criminal Procedure, or
+Rule 45(c), Federal Rules of Civil Procedure.
+2. "Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
+States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal
+Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
+1825, Rule 17(b) Federal Rules of Criminal Procedure)"
+
+
+Washington, D.C. 20530
+Request for Financial Information (Authorization,
+Purchase Order, Receiving Report)
+This form shall only be used when requesting financial records of individuals and partnerships of five or fewer individuals.
+I Purchase Order Number/DCN#:
+11011-1960
+2 Date Order Prepared:
+08/02/2006
+3 Case Number: (Optional)
+FGJ 05-02(WPB) NO.051-01 (OLY-01)
+Section A - Authorization and Purchase Order
+4 Names and Address of Financial Institution: Attn.: Anita Muller. Rescarch Dent
+Colonial Bank,
+oover, AL 35243 - Fax
+5 Deliver To: Special Agent
+Federal Bureau of Investigation,
+Suite 500, Florida 33401, Tel.: 1002) co
+7 Remarks:
+FOR REIMBURSEMENT PLEASE RETURN THIS FORM, THE RECORD OF
+SERVICES, AND A COPY OF THE SUBPOENA.
+8 Name of Requestor: (Type or Print)
+Villafaña, AUSA
+6 Return Date
+08/18/2006
+9 Telephone Number:
+10 Date of request:
+08/02/2006
+11 Service/Financial Records Provided:
+Section B - Financial Institution Invoice
+No Payment Shall Be Made Unless Expenses Are Itemized Below Or On Your Form To Be Attached.
+Quantity
+Please note that reimbursement cannot be made for the records pertaining to
+corporations or large partnerships of six or more.
+IMPORTANT: The DCIA Mandates the use of EFT/DD. In order to receive
+payment complete the attached EFT enrollment Form.
+0.25
+Unit Price
+Cost
+Pcr
+Copy
+11.00
+17.00
+Hour Clerical
+Tech
+Hour Manager
+or Supervisor
+Do not proceed with compliance: If cost will exceed $300 without prior approval of
+Assistant U.S. Attorney/Budget Officer.
+PLEASE REFERENCE THE ABOVE DCN# ON YOUR INVOICE FOR PAYMENT.
+12a Signature of Financial Institution Official:
+12b Phone of Financial Institution Official: | 13 Date Signed:
+Section C - Receiving Report
+14 I certify that the articles and services listed were received:
+18 Right to Financial Privacy Act - Public Law 95-630
+(12 U.S.C. 3401-3422) Request Pursuant To: (Check One Only)
+SECTION
+• 3404
+• 3405
+• 3406
+• 3407
+• 3408
+• 3413
+I
+• 3414
+Customer Authorization
+Administrative Subpoena or Summons
+Search Warrant
+Judicial Subpoena
+Formal Written Request
+Grand Jury Subpoena
+Special Procedures
+22 Remarks:
+Funds Available
+Date
+Budget Officer
+This form was electronically produced by Flie Federal Forms, Ine.
+15 Date Received:
+otal Amount Claime
+y Financial Institutic
+16 Disallowance
+(See Attached)
+17 Net to
+Financial
+Institution
+19 Signature of Approval Official:
+OBJECT
+CLASS
+2540
+2541
+2540
+2540
+2540
+254)
+2540
+-20 Accounting Classification Code
+0E 4004
+21 Schedule and Voucher Number:
+DC#
+-PROJ
+Form OBD211
+APR 84
+Page 1 of3
+
+
+GENERAL
+his is a multi-purpose for designed to serve as an Authorization, Purchase Order, Itemized Invoice, receiving Report and Payment voucher i
+onjunction with "requests for financial information," pursuant to the Right to Financial Privacy Act of 1978, P.L. 95-630, Title XL, 12 U.S.C. 3415
+NOTE:
+Payments under this purchase order will be due on the 30° calendar day after the date of actual receipt of a proper invoice in the office designated to
+receive the invoice.
+The Prompt Payment Act, Public Law 97-177, 96 Stat. 85 (31 U.S.C. 180), is applicable to payments under this purchase order and requires the payment
+to contractors of interest or overdue payments and improperly taken discounts. Determination of interest due will be made in accordance with the
+provision of the Prompt Payment Act and the Office of Management and Budge Cireular A-125.
+PREPARATION INSTRUCTIONS
+ITEM 1 - A Purchase Order Number will be preprinted on each form. This number will be used for reference purposes on any correspondence relating to this
+specific request for financial information.
+ITEM 2 - Self explanatory.
+ITEM 3 - This block may be used to identify the specific case for which the financial information is required. This block may be left blank.
+SECTION A - AUTHORIZATION AND PURCHASE ORDER (To be completed by the requesting official).
+ITEM 4 - Enter the name and mailing address of the financial institution being requested to furnish financial information.
+ITEM 5 - Enter the and address to which the financial information is to be sent by the financial institution. This will normally be the name and the address of the
+requesting official.
+ITEM 6 - Enter the date the financial information is required.
+ITEM 7 - Include, if appropriate, any pertinent information related to the purchase order not provided for elsewhere on the form
+ITEM 8, 9 and 10 - Self-explanatory.
+SECTION B - FINANCIAL INSTITUTION INVOICE (To be completed by the financial institution).
+ITEM 11 - Self-explanatory. Completion of this block constitutes an itemized bill or invoice for reimbursement for the costs incurred in providing the information
+requested. The DCIA Mandates the use of EFT/DD. In order to receive payment complete the attached EFT enrollment Form.
+ITEM 12 and 13 - Self-explanatory.
+SECTION C - RECEIVING REPORT (To be completed by the requesting official, when the requested financial information has been delivered).
+ITEM 14 and 15 - Self-explanatory.
+ITEM 16 - This block should be used to reflect any differences between the amount claimed by the financial institution and the correct amount to be reimbursed.
+Differences may result form computation errors, or failure of the financial institution to deliver information requested.
+ITEM 17 - Enter the amount certified to be proper for payment.
+ITEM 18 - Check the box which identifies the appropriate procedure authorized by the Act, which necessitates the request for financial information.
+"EM 19 and 20 - These blocks must be signed and dated by an official of the organization whose funds will be charged. His or her signature constitutes
+atement that the records to which the invoice refers were required for official business and were provided by the financial institution in accordance with t
+ordering instrument.
+ITEM 21 - The Schedule and Voucher Number will be entered by the office which actually schedules the approved amount for payment by the Treasury
+Department.
+ITEM 22 - Enter, if appropriate, any data not provided for elsewhere on the reæiving report, such as, reasons for any claim amounts disallowed.
+
+
+
+VENDOR ELECTRONIC FUNDS TRANSFER (EFT)
+ENROLLMENT FORM
+Please comply to this information if you have not done so already
+PAYEE/COMPANY INFORMATION:
+Vendor Company Name:
+Address:
+Taxpayer ID Number
+Contact Person Name
+Telephone Number
+FINANCIAL INSTITUTION INFORMATION:
+Bank Name
+Bank Address
+Bank Phone Number
+Nine Digit ABA Routing Transit Number
+Type of Account (Checking or Saving)
+Depositor Account Number
+ignature of Vendor
+uthorizing Officia
+Name & Title of Authorizing
+Official
+Please Return or Fax to:
+U.S. Attorney's Office
+Southern District of Florida
+99 NE 4 street, Suite 200
+Miami, FL.
+33132
+Attention:
+Fax Number:
+The Debt Collection Improvement Act of 1996 requires that payments made by the Federal government, including vendor
+payments, must be made by electronic funds transfer (EFT). A benefit of receiving payments by EFT is that your funds
+are directly deposited to your account at a financial institution and are available to you on the date of payment.
+If you have questions regarding the delivery of the remittance information, please contact the financial institution where
+your account is held.
+If you have any questions on the completion of this form, please contact
+at 305-961-9254.
+Page 3 of3
+
+
+Washington, D.C. 20530
+Request for Financial Information (Authorization,
+Purchase Order, Receiving Report)
+This form shall only be used when requesting financial records of individuals and partnerships of five or fewer individuals.
+1 Purchase Order Number/DCN#:
+2 Date Order Prepared:
+11011-1960
+08/02/2006
+3 Case Number: (Optional)
+FGJ 05-02(WPB) NO.051-01 (OLY-01)
+Section A - Authorization and Purchase Order
+4 Names and Address of Einancial Institution: Attn.: Anita Muller, Research Dept.
+Colonial Bank,
+Hoover, AL 35243 - Fax
+Federal Bureau of Investigation
+5 Deliver To: Special Agent
+Suite 500, Florida 33401
+7 Remarks:
+FOR REIMBURSEMENT PLEASE RETURN THIS FORM, THE RECORD OF
+SERVICES, AND A COPY OF THE SUBPOENA.
+8 Name o
+Print)
+AUSA
+6 Return Date
+08/18/2006
+• Talanhone Alumber:
+10 Date of request:
+08/02/2006
+11 Service/Financial Records Provided:
+Section B - Financial Institution Invoice
+No Payment Shall Be Made Unless Expenses Are Itemized Below Or On Your Form To Be Attached.
+Quantity
+Cost
+Unit Price
+Per
+Copy
+Please note that reimbursement cannot be made for the records pertaining to
+corporations or large partnerships of six or more.
+IMPORTANT: The DCIA Mandates the use of EFT/DD. In order to receive
+payment complete the attached EFT enrollment Form.
+0.25
+11.00
+17.00
+Hour Clerical
+Tech
+Hour Manager
+or Supervisor
+Do not proceed with compliance: If cost will exceed 5300 without prior approval of
+Assistant U.S. Attorney/Budget Officer.
+PLEASE REFERENCE THE ABOVE DCN# ON YOUR INVOICE FOR PAYMENT.
+12a Signature of Financial Institution Official:
+12b Phone of Financial Institution Official:
+Section C - Receiving Report
+14 I certify that the articles and services listed were received:
+18 Right to Financial Privacy Act - Public Law 95-630
+(12 U.S.C. 3401-3422) Request Pursuant To: (Check One Only)
+SECTION
+• 3404
+• 3405
+• 3406
+• 3407
+• 3408
+• 3413
+•] 3414
+Customer Authorization
+Administrative Subpoena or Summons
+Search Warrant
+Judicial Subpoena
+Formal Written Request
+Grand Jury Subpoena
+Special Procedures
+22 Remarks:
+7 Funds Available
+Date
+Budget Officer
+This form was electronically produced by Elite Federal Forms, Inc.
+13 Date Signed:
+15 Date Received:
+Total Amount Claimed
+By Financial Institution
+16 Disallowance
+(See Attached)
+17 Net to
+Financial
+Institution
+19 Signature of Approval Official:
+OBJECT
+CLASS
+2540
+2541
+2540
+2540
+2540
+2545
+2540
+-20 Accounting Classification Code-
+-3
+14
+21 Schedule and Voucher Number:
+DC#
+5
+_PROJ
+Fomn OBD211
+APR 84
+Page 1 of3
+
+
+GENERAL
+This is a multi-purpose form designed to serve as an Authorization, Purchase Order, Itemized Invoice, receiving Report and Payment voucher it
+onjunction with "requests for financial information," pursuant to the Right to Financial Privacy Act of 1978, P.L, 95-630, Title XL, 12 U.S.C. 3415
+NOTE:
+Payments under this purchase order will be due on the 30" calendar day after the date of actual receipt of a proper invoice in the office designated to
+receive the invoice.
+The Prompt Payment Act, Public Law 97-177, 96 Stat. 85 (31 U.S.C. 180), is applicable to payments under this purchase order and requires the payment
+to contractors of interest or overdue payments and improperly taken discounts. Determination of interest due will be made in accordance with the
+provision of the Prompt Payment Act and the Office of Management and Budge Circular A-125.
+PREPARATION INSTRUCTIONS
+ITEM 1 - A Purchase Order Number will be preprinted on each form. This number will be used for reference purposes on any correspondence relating to this
+specific request for financial information.
+ITEM 2 - Self explanatory.
+ITEM 3 - This block may be used to identify the specific case for which the financial information is required. This block may be left blank.
+SECTION A - AUTHORIZATION AND PURCHASE ORDER (To be completed by the requesting official).
+ITEM 4 - Enter the name and mailing address of the financial institution being requested to furnish financial information.
+ITEM 5 - Enter the and address to which the financial information is to be sent by the financial institution. This will normally be the name and the address of the
+requesting official.
+ITEM 6 - Enter the date the financial information is required.
+ITEM 7 - Include, if appropriate, any pertinent information related to the purchase order not provided for elsewhere on the form
+ITEM 8, 9 and 10 - Self-explanatory.
+SECTION B - FINANCIAL INSTITUTION INVOICE (To be completed by the financial institution).
+ITEM 11 - Self-explanatory. Completion of this block constitutes an itemized bill or invoice for reimbursement for the costs incurred in providing the information
+requested. The DCIA Mandates the use of EFT/DD. In order to receive payment complete the attached EFT enrollment Form.
+ITEM 12 and 13 - Self-explanatory.
+SECTION C - RECEIVING REPORT (To be completed by the requesting official, when the requested financial information has been delivered).
+ITEM 14 and 15 - Self-explanatory,
+ITEM 16 - This block should be used to reflect any differences between the amount claimed by the financial institution and the correct amount to be reimbursed.
+Diffcrences may result form computation errors, or failure of the financial institution to deliver information requested.
+ITEM 17 - Enter the amount certified to be proper for payment.
+ITEM 18 - Check the box which identifies the appropriate procedure authorized by the Act, which necessitates the request for financial information.
+EM 19 and 20 - These blocks must be signed and dated by an official of the organization whose funds will be charged. His or her signature constitutes
+atement that the records to which the invoice refers were required for official business and were provided by the financial institution in accordance with th
+ordering instrument.
+ITEM 21 - The Schedule and Voucher Number will be entered by the office which actually schedules the approved amount for payment by the Treasury
+Department.
+ITEM 22 - Enter, if appropriate, any data not provided for elsewhere on the reaiving report, such as, reasons for any claim amounts disallowed.
+APR. B4
+Page 2 of3
+
+
+VENDOR ELECTRONIC FUNDS TRANSFER (EFT)
+ENROLLMENT FORM
+Please comply to this information if you have not done so already
+PAYEE/COMPANY INFORMATION:
+Vendor Company Name:
+Address:
+Taxpayer ID Number
+Contact Person Name
+Telephone Number
+E-mail Address (If you would
+like to be notified via e-mail)
+FINANCIAL INSTITUTION INFORMATION:
+Bank Name
+Bank Address
+Bank Phone Number
+Nine Digit ABA Routing Transit Number
+Type of Account (Checking or Saving)
+Depositor Account Number
+ignature of Vendor
+uthorizing Officia
+Name & Title of Authorizing
+Official
+Please Return or Fax to:
+U.S. Attorney's Office
+Southern District of Florida
+99 NE 4 street, Suite 200
+Miami, FL. 33132
+Attention:
+Fax Number:
+The Debt Collection Improvement Act of 1996 requires that payments made by the Federal government, including vendor
+yments, must be made by electronic funds transfer (EFT). A benefit of receiving payments by EFT is that your fun
+e directly deposited to your account at a financial institution and are available to you on the date of paymer
+If you have questions regarding the delivery of the remittance information, please contact the financial institution where
+your account is held.
+If you have any questions on the completion of this form, please contact
+at 305-961-9254.
+
+
+
+FD-448 (Rev. 6-2-97)
+FBI FACSIMILE
+COVER SHEET
+PRECEDENCE
+_ Immediate
+• Priority
+X Routine
+ele vin th
+Time Transmitted:
+ender's Initial
+umber of Page
+(including cover sheet)
+To: COLONIAL BANK
+Name of Office
+Facsimile Number:
+Attn:
+Date: 08/08/2006
+Name
+Room
+Telephone
+From: _FBI
+Subject: Subpoena Request
+Name of Office
+Special Handling Instructions:
+Originator's Name: SA Tim Slater
+Originator's Facsimile Number:
+Approved:
+Brief Description of Communication Faxed:
+Telephone:
+WARNING
+Information attached to the cover sheet is U.S. Government Property. If you are not the intended recipient of this
+information, disclosure, reproduction, distribution, or use of this information is prohibited (18.USC, § 641). Please notify the
+originator or the local FBI Office immediately to arrange for proper disposition.
+
+
+Colonial
+BaneGroup.
+August 22, 2006
+Via Federal Express
+Special Agent I
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401-6235
+Re:
+Subpoena Issued to Colonial Bank
+Dear
+I enclose herewith
+Response to the Subpoena Duces Tecum issued to its
+Research Department in Birmingham, Alabama, on or about August 2, 2006, regarding VISA
+Account Number
+,, Jeffrey Epstein,
+and Alfredo Rodriguez. Also enclosed is a statement representing
+the subpoena.
+Thank you for allowing Colonial Bank an extension of time within which to respond to
+shallon
+DBBjr/pac
+Enclosures
+Post Ofice Box J10S Montomery Nabana 36101-1108
+AN EQUAL OPPORTUNITY EMPLOYER
+
+
+MADISON W 53701-1111
+MEMO STATEMENT
+ACCOUNT NUMBER
+STATEMENT DATE
+- GENOT AMBAT ONLY "
+05-16-06
+3187.41
+ANUSZ BANASIA
+NES MC
+NEW YORK
+NY
+10022-6845.
+N00071
+Cardholder Total
+Post
+Tran
+pEta
+05-24 05-23
+05-25 05-24
+05-26 05-26
+05-29 05-20
+05-29
+05-27
+Purchasee
+And Oher Debita
+S1FL.44
+CARDHOLDER SUMMARY
+Quin
+Adrances
+80.00
+cracks
+40.00
+CARDHOLDER AÇTIVITY
+=
+Irapragulan Descripilon
+** NOTICE MEMO ITEM LISTED BELOW ***
+
+ASIA GRILL 212-7599816 NY
+
+
+241A3046149001991771569
+CHINA FUN NEW YORK NY
+
+ALSO AT STENEW YORKN
+TOTAL AMDUNT OF MEMO ITEMIS
+coal
+5167.11
+Amound
+M92.85
+M45,30
+M38.27
+M26.70
+M43.82
+1187.4
+FOR CUSTOMER SERVICE OR
+LOST/STOLEN CARDS CALL
+TOLL FREE
+1-800-221-5020
+INTERNATIONAL
+1-608-240-7700
+SEND INQUIRIES TO:
+CREDIT SPITE RESOLUTE CENTER
+MADISON WI S3701-1111
+ACCOUNT NUMBER
+STATEMENT DATE
+08/18/05
+CREDIT LIMIT
+$9,000.00
+DISPUTED AMOUNT
+$0.00
+ACCOUNT SUMMARY
+CASHLADNANGER,
+CASH ADVANCE FIN
+CRERITE.
+$187.44
+.. 00
+51a7.M
+Pape 1 of 1
+
+
+- - -
+MADISON WI 63701-1111
+COLONIAL BANK
+MEMO STATEMENT
+ACCOUNT NUMBER
+STATEMENT DATE
+05-18-08
+502.00
+JANUSZ BANASIAR
+- NES LIG
+= L €
+.D022-684:
+Carabalder Trat
+Purchases
+And Other Debra
+$42.04
+ÇARDHOLDER SUMMARY
+Cash
+Advances
+50.9Q
+Credits
+50.00
+Post Tran
+Date, Pate
+KIDN
+05-04 05-04
+=
+******* NOTICE MEMO ITEMS LISTED BELOW ******000*
+
+LEGENDS #11 WEST PALM BEA FL
+no TOTAL AMQUNT OF MEND DEME:
+Toal
+$42,04
+M42.04
+$42.04
+FOR CUSTOMER SERVICE OR
+LOST/STOLEN CARDS CALL
+TOLL FREE
+1-800-221-5920
+INTERNATIONAL
+1-808-240-7700
+SEND INQUIRIES TO:
+ACCOUNT NUMBER
+STATEMENT DATE
+05/18/08
+CREDIT LIMIT
+pa nan an
+ACCOUNT SUMMARY
+URCHASES E
+ITHER CHARGE!
+MACH ANANCE FEEE
+$42.04
+
+
+10:00
+CREDIT BRUTE RESTLING CENTER
+MADISON WI 53701-1111
+t.uw
+DISPUTED AMOUNT
+$0.00
+TOTAL ACTIVTY
+$42.04
+
+
+
+UU-10-4b
+10: 28
+F. U6
+COLONIAL BANK
+MEMO STATEMENT
+ACCOUNT NUMBER
+STATEMENT DATE
+TOTAL ACTMTY
+04-7-08
+5672,15
+IANUSZ BANASIA
+ME 6 6022-6813
+Cardholder Tonal
+Purchase
+nd Other Debit
+9472,19
+CARDHOLDER SUMMARY
+Cash
+* Advanceo
+50,00
+- Cradlia
+50.00
+13-17 03-12
+
+13-27 03-21
+. 24275306086766763354554
+0411 04-10 24755426101641011083195
+=
+*** NOTICE MEMO ITEMS LISTED BELOW WHOO:
+GREGS BODY AND PAINT 5618335626 FL
+BUDGET RENT-A-CAR WEST PALM BEA FL
+
+LEILA WEST PALM BCH FL
+никосооних TOTAL, AMQUNT OF MEMO ITEM(S):
+$473.18
+M213.00
+M9213
+FOR CUSTOMER SERVICE OR
+LOST/STOLEN CARDS CALL
+TOLL FREE
+1-800-221-5820
+INTERNATIONAL
+1-508-240-7700
+SEND INQUIRIES TO:
+ACCOUNT NUMBER
+STATEMENT DATE
+04/17/08
+CREDIT LIMIT
+ACCOUNT SUMMARY
+$472.18
+109
+EACH ARMANCE ECCO
+
+
+15:28
+P.07
+ISPUTE RESOLUTIO
+MADISON WI 53701-111
+DISPUTED AMOUNT
+$0.00
+all Arentsch bak
+$472.19
+
+
+
+P. OB
+O BOX 111
+MADISON W 53701-1111
+COLONIAL BANK
+MEMO STATEMENT
+ACCOUNT NUMBER
+STATEMENT DATE
+* MEMO STATEMENT ONLY M
+DO NOT REMIT PAYMENT
+03-16-05
+6243.63
+latellalalaalall
+JANUSZ BANASIAR
+FL 4
+M.0022-6843
+N00S04
+Cardholder Total
+Post Tran
+Date Patu
+03-10
+03-10
+Purchases
+And Other Debts
+$243.82
+CARDHOLDER SUMMARY
++ Advances
+$0.00
+Credina
+52.00
+=
+Iranspation Deacription
+KARA* NOTICE MEMO ITEMS LISTED BELOW *000
+
+ROGER DEAN CHEVROLET INC WEST PALM BCG FL
+MANDA TOTAL AMQUNT OF MEMO ITEMS):
+$243.83
+M243.83
+FOR CUSTOMER SERVICE OR
+LOST/STOLEN CARDS CALL
+TOLL FREE
+1-800-221-5920
+INTERNATIONAL
+1-808-240-7700
+SEND INQUIRIES TO:
+ACCOUNT NUMBER
+STATEMENT DATE
+03/18/06
+CREDIT LIMIT
+43 nan an
+ACCOUNT SUMMARY
+PURCHASES
+SASH ADVANCES
+MACU AMIANCE ECCE
+$243.83
+
+
+CREDIT SPUTE RESOLUTE CENTER
+MADISON ON 5370-1111
+P.09
+DISPUTED AMOUNT
+$0.00
+5243,83
+
+
+
+15:28
+P. 10
+• BOX 11
+ADISON WI 53701-11
+COLONIAL BANK
+MEMO STATEMENT
+ACCOUNT NUMBER
+STATEMENT DATE
+TOTAL ACTMTY
+*DO NOT TEM PAT ONLY**
+02-16-08
+5037.37
+JANUSZ BANASIAR
+NON
+FL 4
+10022-6843
+IMPORTANT INFORMATION
+Your total Finance charge Paid for 2005 was SD.00.
+JANUZ BAHARTS
+Cardholder Total
+Purchase
+ind Other Debit:
+$837,37
+CARDHOLDER SUMMARY
+Cash
+Advancea
+10,00
+Credits
+$0.00
+Post Tran
+Date Date
+01-17 01-17
+02-14 02-14
+02-15 02-14
+Transaction Descrietion
+*** NOTICE MEMO ITEMS LISTED BELOW *00
+
+GULF STREAM MOTORS 4076805363 FL
+2444500804B377841903810
+H-D OF PALM BEACH W PALM BEACH FL
+
+RACETRAC582 00005829 W PALM BCH FL
+(KAKA DO NOT TOTAL, AMOUNT OF MEMO ITEMIS):
+Tata
+Activit
+
+M206.83
+M354.74
+M74,00
+5637.37
+FOR CUSTOMER SERVICE OR
+LOSTISTOLEN CARDS CALL
+TOLL FREE
+1-800-221-5820
+INTERNATIONAL
+1-809-240-7700
+SEND INQUIRIES TO:
+ACCOUNT NUMBER
+STATEMENT DATE
+02/18/06
+CREDIT LIMIT
+ACCOUNT SUMMARY
+SASH ADVANCES
+S837.37
+..00.
+
+
+CREDIT SPUTE RESOLUTIOCENTER
+MADISON WI 53701-1111
+P. 11
+woiytew.co
+DISPUTED AMOUNT
+50.00
+$637.37
+
+
+
+AUG-16-2006 15:20
+P. 12
+PABSON W 53701-1111
+COLONIAL BANK
+MEMO STATEMENT
+ACCOUNT NUMBER
+STATEMENT DATE
+01-16-06
+52,฿49.42
+JANUSZ BANASIAR
+NES TIC
+NER YORI
+FL
+10022-6845
+N0t490
+IMPORTANT INFORMATION
+Your total finance sharge paid for 2005 was $0,09.
+Sargholder Teal
+Purchases
+And Other Debits
+82,B48.42,
+CARDHOLRER SUMMARY
+Cash
+Advances
+F0.p0
+Credits
+50,00
+ÇARDHOLDER ACTIVITY
+Post Tran
+Date Date.
+Transaction Descriplion
+MANX NOTICE MEMO ITEMS LISTED BELOW ********
+12-19 12-19
+
+GULF STREAM MOTORS 4078896363 FL
+12-22 12-22
+
+DOLLAR RENT-A-CAR PBIOOO WEST PALM BEA FL
+HH1154845
+01-02 01-02 24108388002542454534978
+DOLLAR RENT-A-CAR PBIOOO WEST PALM BEA FL
+HH1185811
+11-03 01-0
+11-09 01-0
+
+BELLA BLU NEW YORK NY
+
+HAMMACHER SCHLEMMER 800-233-4800 OH
+31-08 01-01
+
+1-09 01-0
+
+FOCACCIA FIORENTINA NY NY
+01-08 01-08
+
+LABSINTHE RESTAURANT NEW YORK NY
+01-16 01-15
+
+SHELL OIL 20830305519 FORT LAUDERDA FL
+Tomal
+$2,849.42
+M311.62
+M898.38
+MB93.71
+M160.19
+M231.98
+M74,93
+57.B49.43
+FOR CUSTOMER SERVICE OR
+LOST/STOLEN CARDS CALL
+TOLL FREE
+1-800-221-5820
+INTERNATIONAL
+1-808-240-7700
+SEND INQUIRIES TO:
+ACCOUNT NUMBER
+STATEMENT DATE
+01/16/05
+CREDIT LIMIT
+sa nanan
+ACCOUNT SUMMARY
+12.049.42
+CASH ARVANCES.
+
+
+AUG-16-2006_15:29
+CREDIT SPITE RESOLUTE CENTER
+MADISON WI 59701-111
+P. 13
+DISPUTED AMOUNT
+80.00
+$2,849.42
+
+
+
+P. 14
+MADISON VI 53701-1111
+COLONIAL BANK
+MEMO STATEMENT
+ACCOUNT NUMBER
+STATEMENT DATE
+TOTAL ACTMITY
+12-18-05
+51,082.16
+*DENOT HEMINATELY
+JANUSZ. BANASIAR
+NES ITC
+NED YORK IN
+10022-6843
+M00G07
+Cardholder Total
+Post
+Tran
+Date Date
+11-17 11-16
+11-21
+11-21
+11-23 11-22
+11-25 11-24
+11-28 11-27
+12-0k 12-01
+Purchases
+And Other Dabits
+$1.842.16
+CARPHOLRER SUMMARY
+Cast
+* Advences
+50.00
+- Oracits
+S2,00
+CARDHOLDER AÇTIVITY
+Referance Number
+
+
+
+
+
+
+
+Transaction Decription
+a* NOTICE MEMO ITEMS LISTED BELOW **
+EXXONMOBIL87 07894991 WEST PAL FL
+LEGENDS #11 WEST PALM BEA FL
+CITY CELLAR WINE BAR & WEST PALM BCH FL
+CAFE L' EUROPE PALM BEACH FL
+DOLLAR RENT-A-CAR PBIOOO WEST PALM BEA FL
+HH1120490
+THE HOME DEPOT 6306 PINECREST FL
+LEGENDS #11 WEST PALM BEA FL
+OCEANAARA TOTAL AMOUNT OF MEMO ITEMS):
+51,86216
+Amolmt
+M65,01
+M28.39
+M80.70
+M193.89
+M066.15
+M500.00
+M27.92
+$1,862.19
+FOR CUSTOMER SERVICE OR
+LOSTISTOLEN CARDS CALL
+TOLL FREE
+1-800-221-5920
+INTERNATIONAL
+1-608-240-7700
+SEND INQUIRIES TO:
+ACCOUNT NUMBER
+STATEMENT DATE
+12/18/05
+CREDIT LIMIT
+can an
+ACCOUNT SUMMARY
+61,862.18
+100
+PARU ADVANCE EEES
+
+
+ISPUTE RESOLUTIO
+MADISON WI 53701-111
+P. 15
+DISPUTED AMOUNT
+$0.00
+51,962.10
+Pago 1 of 1
+
+
+- AUG-16-2006 16:29
+P.16
+RABION W 53701-1111
+COLONIAL BANK
+MEMO STATEMENT
+ACCOUNT NUMBER
+STATEMENT DATE
+* MEMO STATEMENT ONLY *
+DO NOT REMIT PAYMENT
+11-16-05
+51,026.55
+IANUSZ BANASIAI
+ME 022-6065
+NODADA
+MUSZ BANAGAR
+CARDHOLDER SUMMARY
+Cash
+* Advances
+Carcholder Total
+Putchases
+And Other Debits
+$1,828.55
+$9.02
+* Credi
+50,00
+Post Tran
+Date Date
+.. Reterence Number
+* NOTICE MEMO ITEMS USTED BELOW ROTO
+10-1B 10-17
+
+LEGENDS #11 WEST PALM BEA FL
+10-21 10-20
+
+10-24 10-24
+
+AIR CARGO INC FORKED RIVER N.
+10-31 10-29 24108385302642431832383
+DOLLAR RENT-A-CAR PBIODO WEST PALM BEA F
+10-91 10-29 24206575803205699100440
+11-01 11-01
+
+11-03 11-0:
+
+11-04 11-0:
+
+
+1-04 11-0
+1-09 11-0
+
+9B00414
+
+
+SILVER STAR 212-2484250 NY
+11-09 11-06
+11-14 11-12
+
+
+
+CAFFE MED NEW YORK NY
+1-14 11-13
+
+11-14 11-12
+
+AT HERE NOW NEW YORK N
+1-14 11-12
+ATSY'S AT 69TH STREET NEW YORK N
+
+11-16 11-15
+
+TATANY 72 NEW YORK NY
+XXONMOBIL87 07694991 WEST PAL F
+SOAK ON CAN MELAL MONO TOTAL AMDUNT QF MEMO ITEMIS
+$1,62659
+422.8
+121.0
+1292.1:
+4B77.2
+114.45
+128.87
+M37,60
+FOR CUSTOMER SERVICE OR
+LOST/STOLEN CARDS CALL
+TOLL FREE
+1-800-221-5820
+INTERNATIONAL
+1-606-240-7700
+SEND INQUIRIES TO:
+ACCOUNT NUMBER
+STATEMENT DATE
+11/15/05
+CREDIT LIMIT
+to nann
+ACCOUNT SUMMARY
+PACH ARMANCE FEE
+$1,828,55
+•
+
+
+CREDIT ESPUTE RESOUND CENTER
+MADISON WI 53701-1111
+P.17
+DISPUTED AMOUNT
+$0.00
+$1,826.55
+
+
+
+P.18
+PO BSON W1 53701-1111
+COLONIAL BANK
+MEMO STATEMENT
+ACCOUNT NUMBER
+STATEMENT DATE
+TOTAL. ACTIVITY
+MONOT RATI PAYON
+10-17-05
+$14.50
+laladonabalabblleladedobedhellalerlnhll
+JANUSZ BANASIAR
+NES LICI
+NEW YORK
+10022-6843
+NaGANS
+Cardhelder Total
+Purchasen
+And Other Debts
+$2,196.02
+CARDHOLDER SUMMARY
+Cash
+• Advanovs
+$0.09
+Transaction Descriplion
+Credis
+52,181.12_
+Toily
+-$14.80
+Post Tran
+Date. Pale
+09-20 09-20
+09-21 09-21
+09-29 09-28
+Referense Number
+
+
+
+
+DOMINOS PIZZA $4₽04Q09 W PALM BEACH FL
+o* TOTAL AMQUNT OF MEMO ITEMISI
+Amoumt
+2,181.1
+2,181.12 C
+M14,90
+$14.90
+
+
+MADISON WO 13701-1111
+P. 19
+DISPUTED AMOUNT
+$0.00
+2,181.12.
+$14.80
+Pago 1 of 1
+
+
+P. 20
+MABSOW 83701-1111
+COLONIAL BANK
+MEMO STATEMENT
+ACCOUNT NUMBER
+STATEMENT DATE
+TOTAL ACTIVNY
+* MEMO STATEMENT ONLY *
+O NOT REMIT PAYMEN
+09-18-05
+5788.40
+JANUSZ
+BANASIAR
+NEW YORK
+NY
+E FL 4
+10022-6843
+NOSHES
+Cardholder Total
+09-05 09-08
+08-12 08-10
+Purchases
+And Other Debhs
+$788.48
+CARDHOLDER SUMMARY
+Cash
++ Advancee
+50,00
+- Credits
+50.00
+=
+*HE NOTICE MEMO ITEMS LISTED BELOW ***
+244038952478D0524B00285
+IMPROV CITY PLACE 581-8331812 FL
+
+BREGS BODY AND PAINT WEST PALM BEA F
+Во УхоЖрЖИ TOTAL AMOUNT OF MEMQ ITEMO)
+$789.42
+107.1
+881.
+5789.49
+FOR CUSTOMER SERVICE DR
+LOSTISTOLEN CARDS CALL
+TOLL FREE
+1-800-221-5920
+INTERNATIONAL
+1-608-240-7700
+SEND INQUIRIES TO:
+ACCOUNT NUMBER
+STATEMENT DATE
+08/16/05
+CREDIT LIMIT
+e3 an an
+ACCOUNT SUMMARY
+CHARGES
+PACH ARMANITE CECO
+$788.48
+
+
+ISPUTE RESOLUTIOI
+MADISON 53701-1111
+P. 21
+DISPUTED AMOUNT
+$0.00
+CREPITS_
+5780.48
+Paga 1 of 1
+
+
+P.22
+PO BSOM W 53701-1111
+COLONIAL BANK
+MEMO STATEMENT
+ACCOUNT NUMBER
+STATEMENT DATE
+0B-16-05
+52,297.97
+- E NOT TANT BATANNY™
+tslladmaraodadadldndod-tollodelalonduloll
+JANUSZ BANASIAR
+NES LLC
+NER YORK
+10022-6843
+NO0473
+Cardhoidar Total
+Post Tran
+Dale Data
+07-21
+07-21
+08-04
+.08-04
+08-08
+08-08
+08-08 0B-07
+08-08 06-08
+Puichasss
+And Otar Debits
+12,297.97
+CAHDHOLDER SUMMARY
+Cash
++ Advances
+10.00
+Grechts
+$0.00
+Transaciion Description
+
+AT MOUSE MEAM MOTOR WES PALBAFL
+
+CHINA FUN NY NY
+
+NDIAN TANDOOR-OVEN RSTR NEW YORK NY
+
+IEDITERRANEO NEW YORK NY
+
+300U0000000n0c0000o0gooorya
+Total
+Activitty
+$2,287.57
+TERTRE
+M622.02
+M20.88
+M34,89
+M55.70
+11,565.2
+2,297.8
+FOR CUSTOMER SERVICE OR
+LOST/STOLEN CARDS CALL
+TOLL FREE
+1-800-221-5920
+INTERNATIONAL
+1-608-240-7700
+SEND INQUIRIES TO:
+ACCOUNT NUMBER
+STATEMENT DATE
+0B/18/05
+CREDIT LIMIT
+es nmam
+ACCOUNT SUMMARY
+5228L27
+.02
+CASH ADVANCER.
+PACH ARL/ANAE CEES
+
+
+AUG-10-4UUB 10:49
+•O BOX 111
+JADISON WI 53701-111
+r.2s
+DISPUTED AMOUNT
+$0,00
+$2,297.97
+
+
+
+P. 24i
+MADISON WI 53701-1111
+COLONIAL BANK
+MEMO STATEMENT
+ACCOUNT NUMBER
+STATEMENT DATE
+* MEMO STATEMENT ONLY **
+DO NOT REMIT PAYMENT
+07-18-05
+$249.99
+JANUSZ BANASIAR
+NES LLC
+NED YORK
+NY
+_FL
+15022-6843
+NoD47e
+oct Tran
+Date
+Dato
+05-27 06-25
+Garsholdar Total
+Purchase:
+ind Other Debh
+$245.99
+CARDHOLDER SUMMARY
+Cash
++ Advances
+80,00
+Credite
+$0.00
+=
+Referenes Number
+Transaction Deacripton
+MOON MEANDO DOOOOOOM NOTICE MEMO ITEMS LISTED BELOW ORLANKON
+
+200s0488044455 CINCINNATI OH
+DEPARTURE DATE 06-27-05
+PB| DL B LGA DL B PBI
+A0000000 KAAN
+оохоеюх TOTAL AMQUNT OF MEMO ITEMSX
+$249,99
+M249.98
+1248.88
+FOR CUSTOMER SERVICE OR
+LOST/STOLEN CARDS CALL
+TOLL FREE
+1-900-221-5820
+INTERNATIONAL
+1-808-240-7700
+SEND INQUIRIES TO:
+ACCOUNT NUMBER
+STATEMENT DATE
+07/18/05
+CREDIT LIMIT
+ACCOUNT SUMMARY
+URCHASES_
+THER CHARGE
+CASH ARVANCER.
+MOSH ANVANCE CEFO
+$249.99
+
+
+DISPUTE RESOLUTIO
+• BOX 11
+ADISON WI 53701-11
+P. 25
+DISPUTED AMOUNT
+$0.00
+CREDITS.
+$249.99
+
+
+
+P.26
+MADISON 53701-1111
+COLONIAL BANK
+MEMO STATEMENT
+ACCOUNT NUMBER
+STATEMENT DATE
+TOTAL ACTNITY
+* MEMO STATEMENT ONLY **
+DO NOT REMIT PAYMENT
+06-16-05
+81,712.58
+ANUSZ BANASIAI
+HE 002-6043
+Cardholder Tonal
+Post Tran
+Date pate
+06-08 06-08
+06-13
+08-11
+08-13 08-11
+06-13 06-11
+Purchase
+And Other Debits
+51,712.58
+CARDHOLDER SUMMARY
+- Avance
+89,00
+Credito
+$0.00
+
+
+
+
+Transastion Descciplien.
+• NOTICE MEMO ITEMS LISTED BELOW EXOT
+ALM BEACH CYCLES WEST PALM BEA F
+WALGREEN
+WALGREEN
+OOO WEST PALM BEA FL
+WALGREEN
+00045950 WEST PALM BEA FL
+ER TOTAL AMOUNT RE MEMO ITEMIGE
+£1,712.59
+M619.31
+M101.59
+FOR CUSTOMER SERVICE OR
+LOST/STOLEN CARDS CALL
+TOLL FREE
+1-800-221-5820
+INTERNATIONAL
+1-608-240-7700
+SEND INQUIRIES TO:
+ACCOUNT NUMBER
+STATEMENT DATE
+05/18/05
+CREDIT LIMIT
+ACCOUNT SUMMARY
+.31.712.59
+RASH ANNANE EFER
+
+
+MADISON WI 53701-1111
+P.27
+DISPUTED AMOUNT
+$0.00
+$1,712.59
+
+•
+
+
+P.28
+MADISON 11 53701-1111
+COLONIAL BANK
+MEMO STATEMENT
+ACCOUNT NUMBER
+STATEMENT DATE
+TOTAL ACTINITY
+05-16-05
+51,676.31
+JANUSZ BANASIAR
+NES LIG
+NEW YORK
+0022-6843
+Cardhalder Total
+031IF
+ale_Dat
+05-09 05-08
+Purchases
+And Ohar Debits
+51.675.31
+CARDHOLDER SUMMARY
+Cash
+Advances
+$0,00
+Credis
+50.00
+=
+CARPHOLDER AÇTIVITY
+7000
+
+POLO #827 PALM BEACH FL
+DOCKON COLONOMINA IOTAL AMOUNI OF MEMO ITEMILE):
+Total
+Actvily
+$1.576.31
+41,676,3
+11.6255
+FOR CUSTOMER SERVICE OR
+LOST/STOLEN CARDE CALL
+TOLL FREE
+1-800-221-5820
+INTERNATIONAL
+1-608-240-7700
+SEND INQUIRIES TO:
+ACOOUNT NUMBER
+STATEMENT DATE
+05/16/05
+CREDIT LIMIT
+ACCOUNT SUMMARY
+URCHASES
+THER CHARGE
+_CASH ADVANCES
+PASH ANIAN L FEES
+$1.576.31
+00
+
+
+CREDIT SPUTE RESOLING CENTER
+MADISON WI 53701-1111
+P .29
+DISPUTED AMOUNT
+50,00
+$1,878.31
+
+
+
+P.30
+
+DOLOMAL BANK
+44703177400052x30842@0234371377
+1 В-ішта
+BALL
+posted 8-9-06
+https://checkimage.mibank.com/inquiry/servlet/inquiry
+8/14/2006
+
+
+
+Dats Unchanged
+This payment was procassed on 6/2172000 2:45:05 PM
+This payment was exporled on 6/21/2005 3:15:16 PM
+Account To Credit
+Paymeril Type AGH
+Payment Info
+Account
+Payment AtTA
+Customer Information
+NES
+Dust. Name
+Debit Address
+457 MADISON AVE FL4
+Type /Personal
+ZIp, City, Stele T0022
+Phone#
+Posting Detalls
+NEW YORK
+Alternale Phone
+NY
+Payee
+: 1 of 7 entered. $19,606,27 total.
+User Info
+corner entered one
+Payment Entered By
+Print Sitte
+BZFCRICO
+CSSUP
+6/20/2006 3:20:10 PM
+EXTRANET
+METV gE
+19606.27
+Payment Dale 6/20/2006
+Accourd To Debit.
+Roung Number
+
+Bank Mame, Phone
+COLONIAL BANK, NA
+Addross 0039 W LAKE MARY BIVD
+City, Stale, Zip LAKE MARY
+Debll Name
+HARRY BELLER
+Joint Name
+Zip. City, State
+NEW YORK
+10022
+«BANK CARD SERVICES
+Bank
+Cum. Coll Status $Z
+E-Mail Addrese
+Caller D
+Resull Code
+Totai Amarunt: $ 19,608.27
+anny at nau
+Confimadon # 1875200
+[12748
+INY
+Cobscior ID S
+Electronic
+payment.
+posted 6-20-06
+ttps://nj61.speedpay.com/spentry.asp?Action=EditForm&FormName=Payments&PAYMENT_ID=1875200.
+8/16/200€
+
+at allo
+10 • 0|
+Page 1 of i %
+47axA584004521300LA60035700402
+".':
+Amy Bie.
+posed 16-14-06
+8/14/2006
+https://checkimage.mibank.com/inquiry/servlev/inquiry
+
+
+Page 1 of l
+Dale Unchanged
+This pasterd mes peocessed on 5/5/2006 2:46:04 PM
+This payment was exported on 575/2006 3:22:07 PM
+Account To Credk
+Acoound
+Paymeni Type ACH, Payment Info
+Payment And
+10685.10
+(3.00
+Payment Date 515/2006
+Customer Information
+Cust. Name
+NES
+Debit Address 457 MADISON AVE FL 4
+Type Personat
+LLO
+Zp, Cly, Stale 10022
+Phonce
+Posting D
+NEW YORK
+Alarsale Phone
+NY
+| Account To Debil
+Rouing Number
+Checking /
+
+Bank Name, Phons UPMORGAN CHASE BANK, NA
+Address 1111 POLARIS PARKWAY
+City, State. Zip COLUMBUS
+JEFFERY EPSTEN
+Payee
+MET1
+Debit Name
+Joird Name
+Zip, City, State
+/10022
+UNEW YORK
+: 1 of7 antered, $10,685.10 total.
+User info
+Collector ID
+Collactor Group
+Payment Entered On
+Payment Entered By
+Print She
+BFFNFREDER
+CSSUP
+5/5/2006 11:01:50 AM
+EXTRANET
+Bank
+CuT. Coll. Status $ Z
+E-Mali Address
+Caller ID
+SEANK CARD SERVICES
+Flesull Code
+Tolal Amount: $ 10,888.10
+Qn00_0T
+Confinmadon # 1603785
+
+Collecor ID $L
+Electronic.
+Paymest
+posted
+5-5-06
+ttps://nj61.speedpay.com/spentry.asp?Action=EditForm&FormName=Payments&PAYMENT_ID=1803795
+8/16/200€
+
+AVG-16-2006
+Page l ofi 34
+COLONIA
+=
+44703153400052121302M0020077407
+1301
+Hoper
+3-31-06
+ported
+https://checkimage.mibank.com/inquiry/servlet/inquiry
+8/15/2006
+
+
+AUG-1b-ZUUb
+1b:31
+Р.ЭБ
+
+VASA
+GOLDMAL BANK
+Pille be zag-даяе
+
+8220
+17i нит
+posted 3-8-06
+https://checlcimage.mibank.com/inquiry/servlet/inquiry
+8/15/2006
+
+
+Page | of 1
+Dala Unchanged
+• This paymend was processed on 12/12/2006 2:45:06 PM
+This payment was expored on 12/12/2005 3:18:03 PM
+Account To Credit
+Payment Type ACH Payment Info
+Accurt
+Paymeni Am!
+Customer Informallon
+Cust Hame
+NES
+Debit Address M57 MADISON AVE FL 4
+Typa /Parsonal
+ZIp, Cliy, Stake 10022
+Phoned
+Posting Detalls
+NEW YORK
+Allerate Phone
+Payee NET1
+: 1 ol 7 entered, $30,000,00 Lotal.
+User Info
+Collector ID
+Collector Group
+Payment Enlared On
+Paymant Entered By
+Print Sile
+JAMBSERRA
+CSSUP
+12/2/2006 11:47:09 AM
+EXTRANET
+30000.00
+52.00
+Payment Dake 12/12/2005
+Account To Debll
+Rating Number
+Checking Fla
+Bank Name, Phone COLONIAL BANK, NA
+Address 4698 WLAKE MARY BLVD
+Clty, Sials, Zp LAKE MARY
+Debi Name
+JERRY BELLER
+Joirl Name
+Zp. Clly. State
+
+NEW YORK
+Bank
+SEANK CARD SERVICES
+Cur. Coll. Status SZ
+E-Mall Address
+Caller ID
+Reate Code
+
+Tolal Amount: 530003,00
+confirmedon # 1564377
+Collector D SL
+Electronic
+payment
+posted 12-12-05
+MUG 10 - 600b
+ttps://nj61.speedpay.com/spentry.asp?Action=EditForm&FormName=Payments&PAYMENT_ID=1564377
+8/16/2006
+
+10av0o1ut
+8B/15/2086 13:45
+
+M I LOCKBOX
+
+POISON W1 537011111
+COLONIAL BANN
+PROCESSING CENTER
+MILMAUKEL
+AUKED BE 58281-5052..
+- NES LLC
+ERRADISON AVE ELS
+NEW YORK
+PORN AME
+10022-6843
+COLONIAL BANK
+NOBOUNT NUMREN
+PAYMENT DUE DATE
+AMDUNT BUE
+CURRENT BALANCE
+AMOUNT ERCLOSED
+$--
+TO BRAMAKE HECK DAYABLE.
+- 4470125340006213005A70032743662
+8517.000
+511,7A200
+you have authorzed automano paymans
+le payment mount that you hav
+authorized (new balance or minimum
+payrnard) wil be dabhind two business day?
+alter the payment idea date.
+THE ADDRESS CN THE PRIVER, EDE SHOULD ASPEN
+NTHE WINDOW OF THE REMITTANCE ENVELOR
+cymente tocelved at uthor than th
+amit to addresa on the lace of thl
+creen may be days to the demo
+Posting Date 2005 Dec 07
+200
+
+Sog No.
+293
+$11,743.66
+AcconDt No.
+https://checkimage.mibank.com/Inquiry/page/itemprint.jsp7BEANNAME-ArebfvcltcmL/s.. 8/15/2006
+
+
+0B/15/2006 13:45
+
+M I LOCKBOX
+P.38
+PAGE B2/03
+Page 1 of l
+7970
+54- There. LiS 41 00502
+11/29/2003
+:S-11.74366
+Nots of Banked Jurice
+- Coleslal 9ek -
+ID 00N 1042
+Mllpade: W5120/407
+Hyper
+ELLE
+•
+Posting Date 2005 Dec 07
+200
+
+5oq No.
+294
+$11,743.66
+https://cheokimage.mibank.com/Inquiry/page/temprint.jsp7BEANNAME-ArchiveTtamLis.. 8/15/2006
+
+
+19:01
+03/16/2008 08:33 FAX 60B 223 2030
+r.JY
+N & I DIRECT
+@002
+Pago 1 of 1
+CADEN 3701-1111
+COLONIAL BANK
+AYMENT bUE DAY
+ALCHURT BUTE
+GUANAT BALANCE
+TRIFE
+3418.00
+
+If your have nuthorized auroreso peryt
+the payment amount that you have
+luthorized fnew balance of minimum
+payment die dade.
+Paymanıs received at other than he
+remit to addreas on the face of this
+atament may be sutjact to a opiny
+poling of up to 5 days uttar the de
+of raceipt
+Posting Date 2005 Nov 02
+200
+Betch
+
+Seg No.
+•211
+
+
+AUG-1b-ZUUb 15:31
+06/16/2006 09:83 FAX B0B 223 2830
+P.40
+M & I DIRECT
+l/ 003
+
+7904
+10/25/2009
+15-740037
+Sighte.
+Cute of.
+Backrand Bervicce
+Bight Thanamed Three Hardend Slay and 93/180H*8ra40
+РО Вык 3052
+Minder, W1 1121-3052
+ED
+Posting Date 2005 Now 02
+200
+
+Soq No.
+
+
+AUG-16-20U6 15:31
+08/16/2008 08:33 FAX BOB 223 2830
+P.41
+M a I DIRECT
+21004
+
+PRISON W 82701-1111
+COLONIAL HANK
+ADORINT HUMEDA
+PAYMENT OLE DATE
+ANOLMY DUE
+CANNONY RALANCE
+AROUNT ENCLOPED
+$
+10-11-00
+CASADO
+TASSE
+10022-604
+
+If you have authorized summede payment,
+the paymant amount that you Mave
+authorted (now balance or minimum
+paymark) wil be debited hum bumtand days
+after the payment due deta.
+THE ADRIAR OU THE REVERSE RIDE DAOULD APPEAR
+IN TIM WIMUCH OF THE POETTANCE, DRYEROFE
+Paymanta recalved at other than the
+amit to address on tha lace of thie
+of receipt.
+i
+• -
+Poning Dato 2005 Oct 07
+200
+
+249
+$17,175.54
+Account No..
+
+
+AUG-1b-2006 15:31
+0B/18/200B 08:34 FAX B08 223 2830
+P.42
+M 2 I DIRECT
+g005
+Page 1 of1
+Т83Б
+NZTiAeS
+$-1217314
+Banktand Serriem
+-s Das Hundr ad Sancreyofive ind 340 oomd
+Celanlal huk
+Orek Ced Prosscatra Contor
+РО Вом 30.02
+Monir: 21 9201-2012
+•.."
+58 00
+maliom, ll
+* •
+Posting Datc 2005 Oct 07
+200
+
+Soq No.
+250
+$17,175.54
+Aocount No.
+
+
+AUU-16-4UUB 10:31
+08/18/2006 09:34 FAX 908 223 2820
+M & I DIRECT
+2006
+Page I of 1
+DO 5371-111
+COLONIAL BANK
+ADDOUNT MUMBER
+AYMENT DUE BAT
+•ERMENT BALANCE
+AMOUNT ENGLAND
+23-10-65
+4702.00
+TAA0D.50
+10822-6063
+
+a you have authorizad automato paymarta
+authoried (new bal car ni have
+THE ADCARSE DN THE REVERE WON MOULD APPEAR
+IN THE VENDORM OF THE REMITTANGE SVELOPE
+aymanta recalved at other than E
+mit lo address on the face of th
+of recalpt.
+Posting Date 2005 Aug 31
+200
+Butch
+
+253
+S15,893.99
+Aocount No.
+
+
+AUG-16-2006 15:31
+08/16/2006 08:34 FAX BOB 223 2830
+P.44
+N & I DIRECT
+@ 007
+
+774₴
+-Than 105 3 000
+1 5 arom
+Isrand Serrian
+Candal Bunk
+Cradle Chand Procaina Cance
+PO Sex 30F3
+Mbadase WL 19201-2018
+Hey Pale
+Be Had I-D
+EMULATE HOTT
+Posting Date 2005 Ang 31
+200
+
+254
+$15,893.99
+Acoount No.
+
+
+AUU-16-ZUUG 15:31
+108/16/2006 08:30 FAX 608 223 2890
+P.45
+M & I DIRECT
+Pago 1 ofl
+BRISON 5701111
+COLONIAL BANK
+ACDOUT NUMBER
+DAVUENT BUK BATE
+AMONAY DUE
+CHERENT BALANCE
+AROUNT ENCLORED
+HAARON HEARYARLE
+
+08-13-4
+S1,D0.00
+120,12155
+payment amauru that you hav
+authorized (new balance or minimum
+ple ten paymen die olo business digo
+HE ADORESS ON THE IYARE SCE MORED APPE
+TOO ON THE POTTA BELON
+Payments received at other than the
+rama to address on the face of this
+Enting of a a day in be late
+of recaler
+Posting Dato 2005 Aug 03
+200
+
+341
+$20,124.39
+
+
+AUG-16-2006 15:32.
+08/18/2006 08:34 FAX 60B 223 2830
+P.46
+M A I DIRECT
+0009
+Pago 1 of1
+му L.Epub
+766B
+727/2065
+15 -2,124
+-er a t
+Fa Bi
+Bratand Service
+Teay1
+Lracand Osa Eended Tra- Fer d 39107
+Collemidd Bank
+Ordl Onl Presralay Casto
+VO Man, Jа12
+Mtmddon Wr 19281-9052
+FOKiHEe
+Posting Date 2005 Ang 03
+200
+
+342
+$20,124.39
+
+
+- -
+--
+08/16/2006 08:34 FAW B08 223 2830
+N & I DIRECT
+@010
+Page 1 ofl
+OBSCAT 5701-1117
+MILUAUKEE VI 55201-3852
+COLONLAL BANK
+ACCOUNT NUMBER
+AVUBIT DUK 0AI
+MOUNT OUT
+BURRENT BALANCE
+AMOUNT CLIMED
+$
+07-11-00
+
+'10622-689
+447031S740005213005630011259466
+Plaste Mari
+1
+antamen may be subjed to a dalmy ki
+codling of up to 5 daya anar the date
+Posting Date 2005 Jul 12
+200
+
+ScaNo.
+163
+$11,259.46
+
+
+AUG-16-2006 15:32
+08/16/200B 08;34 FAN 608 228 2830
+P.4B
+N& I DIRECT
+@011
+
+7605
+Than 4 Uf V1 000
+T06/2001
+_15-1129945
+Sehened Scrvicea
+setand Tea Heedned Ytow Mas wad 46/100
+Calosie oik
+Credis Dani Proseseicy Cecet
+POBe 1653
+Mlmane V1 5021-943
+Pall
+""*.
+St siwoand
+Posting Date 2005 Jul 12
+200
+
+164
+Amouar
+$11.259.46
+
+
+'Page l ofi"
+• BOX 111
+IADISON Wi 53701-111
+BANK
+CARD PROCESSING CENTER
+PALWAUKEE UX 5320X-7052
+NES LLC
+COLONIAL BANK
+ACCOUNT MUMBER
+AYMENT DUE DATI
+AMOUNT DUE
+CHARENT BALANCE
+ANQUNT ENCLOSED
+TO A RAN HERE AYARLY
+$719.00
+514,27002
+AVE FL 4
+10022-6843
+
+you have authorized automadio payment
+• payment amount that you hav
+authorized (new balance or minimum
+payment) will be deblted two businets daya
+ahter the paymem due date.
+HE AGREEA ON THE HEVERSE SIDE SHOULD APPRAM
+N THE WINDOW OF THE AEMITTANCE RAVE DRE
+Panil to a dares on the ace of the
+Posting Date 2005 Jua 13
+200
+
+225
+$14,370.92
+https://checkimage.mibank.com/inquiry/pagc/itemprint.jsp7BEANNAME=ArchiyeltemL.is. 8/16/2006
+
+
+r.uu
+
+7513
+5L. Themar, LIE VI DUNO
+a do
+Fantand Spicas
+Fourtes Thanand Three Hundred Scramy and 92/100
+Colomlal Bank
+Credit Card Processing Carror.
+PO Bax 3052
+Milk 53201-1033
+Accoun
+6/2/1005
+15-14370.92
+Gallan 8 5
+Hey fall.
+BLURSE ENE
+1:
+Posting Date 2005 Jun 13
+200
+
+226
+$14,370.92
+https://cbcckimagc.mibank.com/inquiry/page/itemprint.jsp?BEANNAME=ArchiveltemLis..._ 8/16/2006
+
+
+Iu uvuu du-vó
+5.01
+
+=
+PA DRO11 53704-1119
+LlalasklacdlloonallaIlllmoGsloohololalordalodell
+ERLBNT®E RONK
+CARD PROCESSINB CENTE
+ELDAUKEE NI 53201-3052
+NES ALATE
+AINT
+0622-6895
+COLONIAL BANK
+ACCOUNT MIJABER
+PAYMENT QUE DATE
+AMDUNT DUE
+CUARENT BALANCE
+ANOUNT ENCLASED
+LO RAKKAN BECEAYARLE
+05-13-06
+S77B0
+316,57330
+
+Iyou have sumortzed automatic payments,
+he payment amount that you have
+authorized (new balance or minimum
+psyment) wil be debited two busnera days
+aftor the paymem due dato.
+THE ADDREDE ON THE REVERSE SIDE SHOULD AMPRAN
+INTHE WINDOW OF THE REMITTANCE EMYTLOR•
+Paymants recelved at other than the
+remit to eddreas on the face of this
+statement may be cublect to a delay in
+crediting of up to 5 days after the dale
+Posting Date 2005 May 06
+200
+
+79
+$15,573.36
+https://checkimage.mibank.com/inquiry/page/itempriat.jsp?BEANNAME-ArchiveltcmL.js... 8/16/2006
+
+
+
+Tethey E. Kguncin
+AlCD Ral Honk Querios, 5m 83
+SL There, LES VI 00803
+OLONIAL BANK NATIONAL, ASSOCIATIO
+Am Desce R34
+7436
+4/19/2005
+5-1537336
+Huskrud Savioa
+Fifteen Thered Flue Huadred Sorenty-Three and 36/100
+Calvalal Bank
+Crodit Card Frostaine Canlar
+PO Box 3013
+Milwanker, WT 53201-3033
+Account i
+-, Pala.
+D
+DORS ENE
+Posting Date 2005 May 06
+200
+Betch
+
+80
+$15,573.36
+https://checkimage.mibauk.com/inquiry/page/itemprint.jsp?BEANNAME-ArchiveltemLis... 8/16/2006
+TOTAL P.52
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/cb080063892043f39c690f08e430fd623bbd46b2a38c4eb07365ea08de7f6140.receipt.json b/vision-fixhub/ds9-unparsed-05/cb080063892043f39c690f08e430fd623bbd46b2a38c4eb07365ea08de7f6140.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7158a0d6c4c74108b0004e796f9fc2b3986684f8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cb080063892043f39c690f08e430fd623bbd46b2a38c4eb07365ea08de7f6140.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -5591,
+  "dataset": "marble-joined",
+  "doc_id": "cb080063892043f39c690f08e430fd623bbd46b2a38c4eb07365ea08de7f6140",
+  "engine": "marble-apple-vision",
+  "event_count": 185,
+  "fix_ids": "[\"builtin.duplicate-list-marker\", \"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "53a41ba919c4a2d842d230ca62551781049a751c6e3923832acb962de7f1ae52",
+  "output_sha256": "71fc58fca5e514d5bdc20a02b6edcddca658d74596221919538fd88386c5dcc4",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/cb1793a85a70c951148ed46b44f73fe4be5c9e59e862fbdb58ba77be90fd44db.md b/vision-fixhub/ds9-unparsed-05/cb1793a85a70c951148ed46b44f73fe4be5c9e59e862fbdb58ba77be90fd44db.md
new file mode 100644
index 0000000000000000000000000000000000000000..7caef1e1a39aa6966049be5969cff96487e86eb5
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cb1793a85a70c951148ed46b44f73fe4be5c9e59e862fbdb58ba77be90fd44db.md
@@ -0,0 +1,464 @@
+- (USAFLS)
+To:
+Subject:
+Attachments:
+• (USAFLS) <
+Monday, August 25, 2008 9:48 AM
+Acosta, Alex (USAFLS);
+(USAFLS); |
+(USAFLS);
+(USAFLS)
+Letter re Epstein and Protective Order
+080822 Lefkowitz Itr to
+(USAFLS): |
+Good morning, everyone.
+I have attached a letter from Jay Lefkowitz that came in by fax on Friday night. The good news is that they
+eem to be in agreement regarding Mr. Josefsberg. Most of the letter doesn't really require a comment, but
+wanted to get
+eedback regarding the notification to the victims of their right to see th
+agreement. Here is the language from my proposed victim notification letter:
+"In addition, a judge has ordered that the United States make available to any designated victim
+(and/or her attorney) a copy of the actual agreement between Mr. Epstein and the United States, so
+long as the victim (and/or her attorney) reviews, signs, and agrees to be bound by a Protective
+Order entered by the Court. If Ms.
+would like to review the Agreement, please let me
+know, and I will forward a copy of the Protective Order for her signature."
+Lefkowitz objects, but I am wondering whether
+agrees that the spirit of our discussions with
+Judge Marra requires such a notification. If we make the entire agreement available to Mr.
+Josefsberg and he conveys that information to all of his clients, the concern becomes moot, I
+suppose.
+Lastly, from my discussion with
+it appears that the Office does not want to add to the list the names of
+victims identified after the date of signing the September agreement unless our investigation had provided
+enough information that we were prepared to include them in the indictment —L.. the New York girls - and
+that you do not want me to re-add
+to the list, even though we have extensive corroboration of her
+involvement with Epstein. Can someone please confirm?
+Thank you all.
+<<080822 Lefkowitz Itr to
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone
+Fax
+385
+P-015173
+
+
+(USAFLS)
+To:
+Subject:
+(USAFLS) <
+Monday, August 25, 2008 10:25 AM
+(USAFLS); Acosta, Alex (USAFLS); |
+(USAFLS);
+I (USAFLS)
+RE: Letter re Epstein and Protective Order
+| (USAFLS): L
+During our telephonic hearing, I received the clear impression that Judge Marra wanted the other victims
+(non-parties to the Jane Doe litigation), would be given the opportunity to see the Agreement, subject to each
+one agreeing to be bound by the protective order. I believe it would be contrary to Judge Marra's intent for
+us to go through the trouble of creating a mechanism for the other non-party victims to have access to the
+Agreement, and then not tell them there is an Agreement.
+Also, does CVRA impose any obligation on us, independent of what Judge Marra ordered, to advise the victims
+of the Agreement?
+- (USAFLS)
+Sent: Monday, August 25, 2008 9:48 AM
+To: Acosta, Alex (USAFLS);
+(USAFLS)
+(USAFLS);
+Subject: Letter re Epstein and Protective Order
+(USAFLS);
+(USAFLS); |
+Good morning, everyone.
+I have attached a letter from Jay Lefkowitz that came in by fax on Friday night. The good news is that they
+seemed to gin areement reach regarding tiber catio the vier do or their ly requise a comment, but 1
+agreement. Here is the language from my proposed victim notification letter:
+"In addition, a judge has ordered that the United States make available to any designated victim
+(and/or her attorney) a copy of the actual agreement between Mr. Epstein and the United States, so
+long as the victim (and/or her attorney) reviews, signs, and agrees to be bound by a Protective
+Order entered by the Court. If Ms.
+would like to review the Agreement, please let me
+know, and I will forward a copy of the Protective Order for her signature."
+Lefkowitz objects, but I am wondering whether
+agrees that the spirit of our discussions with
+Judge Marra requires such a notification. If we make the entire agreement available to Mr.
+Josefsberg and he conveys that information to all of his clients, the concern becomes moot, I
+suppose.
+Lastly, from my discussion with
+, it appears that the Office does not want to add to the list the names of
+victims identified after the date of signing the Sep736 EV-MARR unless our investigation had provided-015174
+386
+
+
+enough information that we were prepared to include them in the indictment-
+., the New York girls - and
+that you do not want me to re-add
+to the list, even though we have extensive corroboration of her
+involvement with Epstein. Can someone please confirm?
+Thank you all.
+<< Pile: 080822 Lefkowitz Itr to
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone
+Fax
+387
+P-015175
+
+
+KIRKLAND & ELLIS LLP
+AND ANILIATED PARTNEESIHPS
+Clinious Conter
+New York. New York 10022-4611
+lay P I etkowir, Pl
+To Call Writer Directly
+www kirkland com
+Packanule
+August 22, 2008
+VIA FACSIMILE (
+linited States Allorney's Olice
+Southern District of Florida
+500 South Australian Avenuc. Suite 400
+West Palm Beach. Florida 33401
+Re: Jefrey Lpsiein
+Dear
+I write this leuer to correct cerlain misstatements made in your lener dated August ?1.
+2008. and the accompanying draft notification.
+First, you state that "Mr. Josefsberg expended time, effon and funds in preparing to serve
+as attorney representative in October of 2007." Neither 1. nor any other altorcy on Mr.
+Epstein's defense leam. was notified of this work by Mr. Josefsberg.
+Second. in the victim notification letter, no judge "has ordered that the United States"
+make available a copy of the Non-Prosceution Agreement. Scetion () of the Order to C'ompel
+Production and Prutcetive Order provides that if any of the alleged "victins" andior their
+altorneys "request the opportunity to review the Agreement." the (SAO shall comply with the
+equest so long as those individuals agree not to disclose the Non-P'rosccution Agreement. Ther
+sno court order royuiring the government to provide the alleged "victims" with notice that th
+Ne comiciny prucins oathi agree he Given date and dues itie his will wive
+an attorney representative win is fully aware of the terms of the Nion-Prosecurion Agrecment.
+this conflicting paragraph of'your notice is unnecessary in any event and should he excised.
+Third. misstatements in your prior notification were not made "with the approval of
+Mr. Hipstein's counsel."
+response near cose win me repoint of ter pus a
+P-015176
+
+
+KIRKLAND & ELLIS LLP
+August 23. 2008
+Page 2
+$ 22,55 is as stated in paragraphs 7 and Softhe Agrcement and the Addendu to the Agrcement.
+no more. no less.
+Filth. while you stale, in your letter. that the USAO does not intend to delete any of the
+names on the list provided to Mr. Epstein's counsel, you do not confirm that the prior list is final
+and complete. There can he no expansion of the list of individuals that you informed us had
+been memonalized as of September 24. 2007 and disclosed to Mr. Epslein on June 30. 2008 (the
+date of'sentence pursuantto the Agreement's disclosure requirements). Please confim the exact
+name and number of individuals the government plans on notifying as provided for under the
+Agreement.
+Sixth. based on express language in prior communications from your Office, we are in
+agreement that paragraphs 7 and 8 of the Agreement are in need of clarification and
+implementation. We will work with the attorney representative in attempling to reach a fair
+resolution of the outstanding civil matters in a manner that is in accordance with the Agreement.
+Serench. We have previously communicated our objections to the propricty of the
+allomey ropresentative engaging in contested litigation. We again dispure the assertion that
+Mr. Joselsberg's duties include filing contested litigation. In any case. thar issue is not ripe for
+resolution at this point. but again, given his agreement to be the attorney representative. we will
+aidress these matters directly with Mr. Josefsherg.
+TyP. Tetkowitz.
+Chief. Nonhern Division
+P-015177
+
+
+To:
+CC:
+Jay I'. Lulkowitz.
+Message:
+KIRKLAND & ELLIS LLP
+Fax Transmittal
+Citinroun Center
+New York, New York 10072-4611
+Phone:
+Fax:
+Please notify us immediately if any pages are not recelved.
+THE INFORMATION CONTAINED IN THIS COMMUNICATION IS CONFIDENTIAL, MAY
+BE ATTORNEY-CLIENT PRIVILEGED, MAY CONSTITUTE INSIDE INFORMATION, AND
+IS INTENDED ONLY FOR THE USE OF THE ADDRESSEE. UNAUTHORIZED USE.
+DISCLOSURE OR COPYING IS STRICTLY PROHIBITED AND MAY BE UNLAWFUL
+IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR,
+PLEASE NOTIEY US IMMEDIATELY AT:
+Company:
+Linited States Attorney's Office
+Company:
+United States Attorncy's Oflice
+Date:
+Pages w/cover:
+August 22, 2008
+3
+Fax #:
+Fax #:
+Fax #:
+Direct #:
+Direct #:
+Direct #:
+P-015178
+
+
+- (USAFLS)
+To:
+Subject:
+Hi
+that?
+- (USAFLS) <
+Monday, August 25, 2008 1:54 PM
+(USAFLS)
+RE: Letter re Epstein and Protective Order
+- Thank you for your response. Did you ever send the agreement to Brad? Do you want me to do
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone |
+Fax
+(USAFLS)
+Sent: Monday, August 25, 2008 10:25 AM
+To:
+(USAFLS); Acosta, Alex (USAFLS); |
+(USAFLS)
+Subject: RE: Letter re Epstein and Protective Order
+(USAFLS);
+(USAFLS);
+During our telephonic hearing, I received the clear impression that Judge Marra wanted the other victims
+(non-parties to the Jane Doe litigation), would be given the opportunity to see the Agreement, subject to each
+one agreeing to be bound by the protective order. I believe it would be contrary to Judge Marra's intent for
+us to go through the trouble of creating a mechanism for the other non-party victims to have access to the
+Agreement, and then not tell them there is an Agreement.
+Also, does CVRA impose any obligation on us, independent of what Judge Marra ordered, to advise the victims
+of the Agreement?
+I. (USAFLS)
+Sent: Monday, August 25, 2008 9:48 AM
+To: Acosta, Alex (USAFLS);
+(USAFLS);
+(USAFLS)
+Subject: Letter re Epstein and Protective Order
+Good morning, everyone.
+(USAFLS);
+(USAFLS); |
+388
+P-015179
+
+
+I have attached a letter from Jay Lefkowitz that came in by fax on Friday night. The good news is that they
+seem to be in agreement regarding Mr. Josefsberg. Most of the letter doesn't really require a comment, but I
+wanted to get
+feedback regarding the notification to the victims of their right to see the
+agreement. Here is the language from my proposed victim notification letter:
+"In addition, a judge has ordered that the United States make available to any designated victim
+(and/or her attorney) a copy of the actual agreement between Mr. Epstein and the United States, so
+long as the victim (and/or her attorney) reviews, signs, and agrees to be bound by a Protective
+Order entered by the Court. If Ms.
+_would like to review the Agreement, please let me
+know, and I will forward a copy of the Protective Order for her signature."
+Lefkowitz objects, but I am wondering whether
+agrees that the spirit of our discussions with
+Judge Marra requires such a notification. If we make the entire agreement available to Mr.
+Josefsberg and he conveys that information to all of his clients, the concern becomes moot, I
+suppose.
+Lastly, from my discussion with
+, it appears that the Office does not want to add to the list the names of
+victims identified after the date of signing the September agreement unless our investigation had provided
+enough information that we were prepared to include them in the indictment-
+., the New York girls - and
+that you do not want me to re-add
+to the list, even though we have extensive corroboration of her
+involvement with Epstein. Can someone please confirm?
+Thank you all.
+<< File: 080822 Lefkowitz Itr to
+>>>
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone
+Fax
+389
+P-015180
+
+
+• (USAFLS)
+To:
+Subject:
+(USAFLS) <
+Monday, August 25, 2008 2:18 PM
+- (USAFLS)
+RE: Letter re Epstein and Protective Order
+I have not sent Brad the Agreement, and would appreciate it if you could take care of that. Are we sending
+out parts | and II, and leaving out the December 2007 letter? Thanks.
+- (USAFLS)
+Sent: Monday, August 25, 2008 1:54 PM
+(USAFLS)
+Subject: RE: Letter re Epstein and Protective Order
+Hi
+that?
+- Thank you for your response. Did you ever send the agreement to Brad? Do you want me to do
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone |
+Fax
+(USAFLS)
+Sent: Monday, August 25, 2008 10:25 AM
+To:
+- (USAFLS); Acosta, Alex (USAFLS); [
+(USAFLS)
+Subject: RE: Letter re Epstein and Protective Order
+(USAFLS);
+(USAFLS); L
+During our telephonic hearing, I received the clear impression that Judge Marra wanted the other victims
+(non-parties to the Jane Doe litigation), would be given the opportunity to see the Agreement, subject to each
+one agreeing to be bound by the protective order. I believe it would be contrary to Judge Marra's intent for
+us to go through the trouble of creating a mechanism for the other non-party victims to have access to the
+Agreement, and then not tell them there is an Agreement.
+P-015181
+
+
+Also, does CVRA impose any obligation on us, independent of what Judge Marra ordered, to advise the victims
+of the Agreement?
+(USAFLS)
+Sent: Monday, August 25, 2008 9:48 AM
+To: Acosta, Alex (USAFLS);
+(USAFLS);
+(USAFLS)
+Subject: Letter re Epstein and Protective Order
+(USAFLS);
+(USAFLS);
+Good morning, everyone.
+have attached a letter from Jay Lefkowitz that came in by fax on Friday night. The good news is that they
+ven to bo in arement readi rear lose nication the victims ofter ly requise a comment, but i
+agreement. Here is the language from my proposed victim notification letter:
+"In addition, a judge has ordered that the United States make available to any designated victim
+(and/or her attorney) a copy of the actual agreement between Mr. Epstein and the United States, so
+long as the victim (and/or her attorney) reviews, signs, and agrees to be bound by a Protective
+Order entered by the Court. If Ms.
+would like to review the Agreement, please let me
+know, and I will forward a copy of the Protective Order for her signature."
+Lefkowitz objects, but I am wondering whether
+agrees that the spirit of our discussions with
+Judge Marra requires such a notification. If we make the entire agreement available to Mr.
+Josefsberg and he conveys that information to all of his clients, the concern becomes moot, I
+suppose.
+Lastly, from my discussion with
+it appears that the Office does not want to add to the list the names of
+victims identified after the date of signing the September agreement unless our investigation had provided
+enough information that we were prepared to include them in the indictment -
+... the New York girls - and
+that you do not want me to re-add
+to the list, even though we have extensive corroboration of her
+involvement with Epstein. Can someone please confirm?
+Thank you all.
+< File: 080822 Lefkowitz Itr to
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone
+391
+P-015182
+
+
+Fax
+392
+P-015183
+
+
+To:
+Subject:
+• (USAFLS)
+- (USAFLS) <
+Monday, August 25, 2008 2:20 PM
+(USAFLS)
+RE: Letter re Epstein and Protective Order
+Yes, that was my plan. I will send it out today. Thanks.
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+(USAFLS)
+Sent: Monday, August 25, 2008 2:18 PM
+To:
+• (USAFLS)
+Subject: RE: Letter.re.Epstein and Protective Order
+I have not sent Brad the Agreement, and would appreciate it if you could take care of that.
+out parts | and II, and leaving out the December 2007 letter? Thanks.
+Are we sending
+1. (USAFLS)
+Te: Monday August 25, 2008 1:54 PM
+| (USAFLS)
+Subject: RE: Letter re Epstein and Protective Order
+Hi
+that?
+- Thank you for your response. Did you ever send the agreement to Brad? Do you want me to do
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+393
+P-015184
+
+
+Phone
+Fax
+To:
+(USAFLS)
+Sent: Monday, August 25, 2008 10:25 AM
+(USAFLS); Acosta, Alex (USAFLS);
+(USAFLS)
+Subject: RE: Letter re Epstein and Protective Order
+(USAFLS);
+(USAFLS); |
+During our telephonic hearing, I received the clear impression that Judge Marra wanted the other victims
+(non-parties to the Jane Doe litigation), would be given the opportunity to see the Agreement, subject to each
+one agreeing to be bound by the protective order. I believe it would be contrary to Judge Marra's intent for
+us to go through the trouble of creating a mechanism for the other non-party victims to have access to the
+Agreement, and then not tell them there is an Agreement.
+Also, does CVRA impose any obligation on us, independent of what Judge Marra ordered, to advise the victims
+of the Agreement?
+(USAFLS)
+Sent: Monday, August 25, 2008 9:48 AM
+To: Acosta, Alex (USAFLS);
+(USAFLS);
+(USAFLS)
+Subject: Letter re Epstein and Protective Order
+(USAFLS);
+(USAFLS); L
+Good morning, everyone.
+I have attached a letter from Jay Lefkowitz that came in by fax on Friday night. The good news is that they
+cem to be in agreement regardi
+wanted to get
+eedback regarding is no Mation the levier ident heily require a comment, but:
+agreement. Here is the language from my proposed victim notification letter:
+"In addition, a judge has ordered that the United States make available to any designated victim
+(and/or her attorney) a copy of the actual agreement between Mr. Epstein and the United States, so
+long as the victim (and/or her attorney) reviews, signs, and agrees to be bound by a Protective
+Order entered by the Court. If Ms.
+would like to review the Agreement, please let me
+know, and I will forward a copy of the Protective Order for her signature."
+Lefkowitz objects, but I am wondering whether
+agrees that the spirit of our discussions with
+Judge Marra requires such a notification. If we make the entire agreement available to Mr.
+Josefsberg and he conveys that information to all of his clients, the concern becomes moot, I
+suppose.
+Lastly, from my discussion with. it appears that the Office does not want to add to the list the names of
+victims identified after the date of signing th85807964CNaMOARRY unless our investigation had provideB-015185
+394
+
+
+enough information that we were prepared to include them in the indictment-
+., the New York girls - and
+that you do not want me to re-add
+_to the list, even though we have extensive corroboration of her
+involvement with Epstein. Can someone please confirm?
+Thank you all.
+<< File: 080822 Lefkowitz Itr to
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone
+Fax
+395
+P-015186
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/cb1793a85a70c951148ed46b44f73fe4be5c9e59e862fbdb58ba77be90fd44db.receipt.json b/vision-fixhub/ds9-unparsed-05/cb1793a85a70c951148ed46b44f73fe4be5c9e59e862fbdb58ba77be90fd44db.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..38beb2c86b133452d18c45a8406e28fc4d59a27c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cb1793a85a70c951148ed46b44f73fe4be5c9e59e862fbdb58ba77be90fd44db.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -505,
+  "dataset": "marble-joined",
+  "doc_id": "cb1793a85a70c951148ed46b44f73fe4be5c9e59e862fbdb58ba77be90fd44db",
+  "engine": "marble-apple-vision",
+  "event_count": 15,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "61bc2c96f6d7437cd01d8e557fff0aa94d40fdd92b02548502f457af8c6599fc",
+  "output_sha256": "5b7207ea93630aec4cff4b6256a33f7fc7269d21913a522bfba31fb6d5bdb89d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/cc0288d46023d592107de60cd453d669ff1a442333afe0a357e99074111c25e5.md b/vision-fixhub/ds9-unparsed-05/cc0288d46023d592107de60cd453d669ff1a442333afe0a357e99074111c25e5.md
new file mode 100644
index 0000000000000000000000000000000000000000..0f0b52c92c0ad722e75b4075e5f0a3876c1dd15c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cc0288d46023d592107de60cd453d669ff1a442333afe0a357e99074111c25e5.md
@@ -0,0 +1,121 @@
+12/7/07 Sanchez to Stoman
+
+
+D0-07-07
+04:53pm
+
+LAW OFFICES
+FOWLER WHITE BURNETT
+ESPIRITO SANTO PIAZA
+1395 BRICKELL AVENUE, 14TlI FLOOR
+MIAMI, FLORIDA 33121-3302
+T-BEE P.001/004 F-876
+FAX TRANSMITTAL
+DATE: December 7, 2007
+Name
+NUMBER OF PAGES: 3
+(Excluding transmittal page)
+Fax Number
+FROMI
+FAX NUMBER:
+MATTER NO: 71200
+REMARKS: please see attached.
+TETEPHONE NUMBER: (
+Original documents will L will not follow by mail.
+TIME OF TRANSMITTAL:
+- a.т./p.m. TRANSMITTED BY:
+Photocopy should he taken of this transinisuion Uit is to be ratained since Jacsimila puper has limired storaga life.
+THE INFORMATION CONTAINED IN THIS FACSIMILE MESSAGE IS ATTORNEY PRIVILEGED AND CONFIDENTIAL
+INFORMATION INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF
+THIS MESSAGE IS NOT THE INTENDED RECIPIENT. YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION,
+DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED, IF YOU HAVE RECEIVED THIS
+COMMUNICATION IN ERROR, PLEASE IMMEDIATELY NOTIFY US BY TELEPHONE (IF LONG DISTANCE, PLEASE CALL
+COLLECT) AND RETURN THE ORIGINAL MESSAGE TO US AT THE ABOVE ADDRESS VIA THE U.5. POSTAL SERVICE.
+PLEASE NOTIFY US IMMEDIATELY BY CALLING (305) 789-9200, IF THERE IS ANY PROBLEM.
+
+
+Dec-07-07
+04:54pm
+FOWLERWHITE
+ATTORNEYS AT LAW
+BURNETT
+MIAMI • FORT LAUDERDALE • WeSTPALM BEACH • ST. PETERSBURG
+
+T-BEE P.002/004 F-876
+ESPINTO SANG PLAZA
+FOUHIRONTH FLOOR
+130S BACKE!, AVENUE
+MIAMI, FLOmos 33131
+LOMONE (3051 789-920
+C5HLE (305) 768:920
+www.FOMLET-WHME,.COM
+• LILLY ANN SANCHEZ.
+DiRECT PREHE No.: (305) 783-9270
+IPECT FACSIMILE No.: (305) 728-767
+SANCHE2@rOWLEN-WMITR.cO
+December 7, 2007
+First Assistant United States Attorney
+United States Attorney's Office
+Southem District of Florida
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epstein
+Dear Jeff:
+Pursuant to your letter dated December 6, 2007, attached is a signed
+Affirmation of the Non-Prosccution Agreement and Addendum to sure dated
+October 30, 2007 (collectively " Agreement") signed by my client Jeffrey B. Epstein
+(ste attached).
+Moreover, pursuant to the terns of the Agreement, please note that the plea
+and sentencing hearing have been scheduled for January 4, 2008 at 8:30 a.m. before
+Judge Sandra MeSorley (please sea attached notice of hearing). In addition, 4s
+expressed in my voicemail message to you earlier, I would requost that the Offic
+old off on sending any victim notification letters until we can further discuss the
+contents therein, Please call me at your earliest convenience.
+CC.
+[m]W3|200130paLAs(12/7-15:51]
+FOWLER WHITE BURNETT P.A.
+
+
+Dec-07-07
+04:55pm
+3057B89201
+T-R66 P.0D3/004 F-878
+Affirmation
+1, Jeffrey B. Epstein do hereby ro-affirm the Non-Proscoution Agreement and Addendur 1o
+samé dared October 30, 2007,
+Date
+
+
+Dac-07-07 04:56pm
+Fron-Fowler-White Burnett
+
+T-866 P.004/004 F-076
+IN THE CIRCUIT COURT OF THE FIFTEENTH
+JUDICIAL CIRCUIT, IN AND FOR PALM BEACH
+COUNTY, FLORIDA
+CASENO.: 2006CF009454AXX
+STATB OF FLORIDA
+VS.
+JEFFREY EPSTEIN,
+Defendent.
+NOTICE OF HEARING
+PLRASE TAKE NOTICE that the undersigned has called up for hearing the following:
+JUDGE:
+Sandra MeSorley
+DATE:
+Januery 4, 2008
+8:30 am.
+PLACE:
+Room I1F, Palm Beach County Courthouse
+MATTER:
+Plea Conference
+I HEREBY CBRTIFY tbat a copy of the foregoing has been furnished by mall to Lanna
+33401 this Ray et December, 20 0c, 401 North Dixie Highway, West Palm Beach, Florida
+ATTERBURY, GOLDBERGER & WEISS, P.A.
+250 Australian Avente South
+Suite 1400
+West Palm Busch, Florida 33401
+(561 659-8300
+INN
+GOLDBERGER, ESQUIRE
+ce: The Honorable Sandra MeSorley
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/cc0288d46023d592107de60cd453d669ff1a442333afe0a357e99074111c25e5.receipt.json b/vision-fixhub/ds9-unparsed-05/cc0288d46023d592107de60cd453d669ff1a442333afe0a357e99074111c25e5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..cd64b84d8c3405a5e4695dc56d52607ebf74cc79
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cc0288d46023d592107de60cd453d669ff1a442333afe0a357e99074111c25e5.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -169,
+  "dataset": "marble-joined",
+  "doc_id": "cc0288d46023d592107de60cd453d669ff1a442333afe0a357e99074111c25e5",
+  "engine": "marble-apple-vision",
+  "event_count": 9,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "0d5a96f92fa38f71ba7cfcfc9db470afcfea15c46555eb7eba7e3544cf67f1b9",
+  "output_sha256": "2617b5a0cdf3fc271676a6e6606191972fa3186a438ac8542eb6c133c2ac924d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/cd525b51281611609f58ea01936002d8f07cce2a01fc4290877c1df70a9aa460.md b/vision-fixhub/ds9-unparsed-05/cd525b51281611609f58ea01936002d8f07cce2a01fc4290877c1df70a9aa460.md
new file mode 100644
index 0000000000000000000000000000000000000000..9d9044062132e209f5ec4dcd1a6c66f18a0e4fac
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cd525b51281611609f58ea01936002d8f07cce2a01fc4290877c1df70a9aa460.md
@@ -0,0 +1,76 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 South Australian Ave., Suite 400
+Wes Paim Beach, FL 33407
+(561) 820-8717
+DELIVERY BY FACSIMILE
+Ms.
+In care of Bruce Lyons, Esq.
+August 31, 2007
+Re: Grand Jury Investigation Confidential
+Dear Ms.
+This letter is an invitation for you to testify before a federal Grand Jury, and is supplied in
+order to provide helpful background information about the Grand Jury. The Grand Jury consists
+of from sixteen to twenty-three persons from the Southern District of Florida. It is their
+responsibility to inquire into federal crimes which may have been committed in this District.
+As a Grand Jury witness you will be asked to testify and answer questions under oath, and
+to produce records and documents. Only the members of the Grand Jury, attorneys for the United
+States and a stenographer are permitted in the Grand Jury room while you testify.
+The U.S. Department of Justice encourages prosecutors to notify an individual in
+appropriate cases that he or she is a target of a grand jury investigation. Accordingly, you are
+hereby notified that you are a target of a federal grand jury investigation in the Southern District
+of Florida concerning suspected violations of federal law, including but not limited to, possible
+violations of Title 18, United States Code, Sections 2, 371, 1512, 1591, 1952, 1956, 1960, 2421,
+2422, and 2423.
+You are advised that the destruction or alteration of any document required to be produced
+before the grand jury constitutes serious violation of federal law, including but not limited to
+Obstruction of Justice.
+A "target" is a person as to whom the prosecutors or the Grand Jury have substantial
+Ms.
+August 31, 2007
+Page 2
+evidence linking him or her to the commission of a crime and who, in the judgment of the
+prosecutors, is a putative defendant.
+This letter constitutes an invitation to you to testify on your own behalf before the grand
+jury about matters under investigation. Of course, you are not required to appear before the
+grand jury. The decision whether to do so is a voluntary matter which is entirely up to you. The
+grand jury, if in fact it learns of this opportunity afforded to you, will be instructed not to draw
+any adverse inference from your failure to appear should you decide not to accept this invitation.
+You must further understand that should you decide to testify, your testimony could be used
+against you if any criminal charges should be filed against you.
+Should you decide to appear before the grand jury, you will have the same rights and
+obligations as any non-immunized grand jury witness. Specifically,
+You may refuse to answer any question if a truthful answer to the question would
+tend to incriminate you.
+You have the right to stop answering questions at any time.
+
+
+Anything you say may be used against you at the grand jury or in a subsequent
+legal proceeding.
+The grand jury will permit you a reasonable opportunity to step outside the grand
+jury room to consult with your attorney, if you so desire, at any point during the
+testimony you give.
+Please be further advised that the giving of false testimony before the grand jury will
+subject you to a prosecution for perjury in addition to the violations set forth above.
+As a target of a grand jury investigation who has been asked to appear before the grand
+jury, you may wish to retain the services of an attorney. If you cannot afford the services of
+independent counsel, the Court may be able to appoint counsel to represent you. If you would
+like the United States to ask the Court to appoint an attorney to represent you, please contact the
+undersigned at 561 209-1047. The United States is investigating other individuals, and you may
+be interested in cooperating with the United States against those other targets. If you hire an
+attorney, or if the Court appoints one to represent you, that counsel can contact me to discuss that
+possibility.
+Ms.
+August 31, 2007
+Page 3
+Please advise me whether you wish to testify before the grand jury by close of business
+Nednesday, September 12, 2007. If I do not receive notification from you or your counsel by
+his date, I will assume that you do not wish to testify before the grand jury
+Sincerely,
+UNITED STATES ATTORNEY
+By:
+Ms. L
+July 20, 2007
+Page 3
+bec:
diff --git a/vision-fixhub/ds9-unparsed-05/cd525b51281611609f58ea01936002d8f07cce2a01fc4290877c1df70a9aa460.receipt.json b/vision-fixhub/ds9-unparsed-05/cd525b51281611609f58ea01936002d8f07cce2a01fc4290877c1df70a9aa460.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0fb27a6342cf799f9bd28d35ee86c95d63a8e1c7
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cd525b51281611609f58ea01936002d8f07cce2a01fc4290877c1df70a9aa460.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "cd525b51281611609f58ea01936002d8f07cce2a01fc4290877c1df70a9aa460",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "a0419ba91403c69e61c147e764fe05849aa4db2e386266ce12ac4a84a71c4067",
+  "output_sha256": "fa2d7411847fda256ea8a0d285a198a459f6e87de39fd71714d587a52d3f26c4",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/cd98e3f9331e9cc896e0cddf4da5d8fe636b9226283bec0152b1ff1d9c3a7e7b.md b/vision-fixhub/ds9-unparsed-05/cd98e3f9331e9cc896e0cddf4da5d8fe636b9226283bec0152b1ff1d9c3a7e7b.md
new file mode 100644
index 0000000000000000000000000000000000000000..2450745291c1d7b336eff769afd43c21ea420220
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cd98e3f9331e9cc896e0cddf4da5d8fe636b9226283bec0152b1ff1d9c3a7e7b.md
@@ -0,0 +1,109 @@
+OLY-42
+
+
+TO: Eve's Garden
+119 W 57* Street #1201
+New York, NY 10019
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-42
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+May 1, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+All records and information referring or relating to Sale No.
+and information referring or relating to transactions with
+I dated 3/3/2005, including all records.
+and/or Jeffrey Epstein.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+vour annentance with Special Agent I
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+April 16, 2007
+This subpoena is issued upon application
+ofthatt
+*If not applicable, enter "sore."
+Name Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+300 So. Australian Avenue, Suite 400
+West Palm Beach. BL. 33401-6235
+Tel:
+Fax:
+To be used in lieu of AO110
+FORM ORD-227
+JAN.8G
+
+
+BUT ORE
+U.S. Departme of Justice
+United States Attorney
+Southern District of Florida
+500 S. Australian Ave., Suite 400
+Vart Balm Ranch FL. 33401-6235
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+authenticity. Therefore, you may be able to avoid appearing personally at the grand
+jury/trial at the time and place specified by completely filling out the attached Certification
+and Inventory and immediately returning it with the records to Special Agent I
+FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to May. 1, 2007.
+Sincerely,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+BY:
+ASSISTANT UNITED STATES ATTORNEY
+
+
+CERTIFICATION OF BUSINESS RECORDS
+1, the undersigned,
+employed bylassociated with
+position of
+, declare that I am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+Date of execution:
+Place of execution:
+Signature:
+
+
+APPENDIX A
+DOCUMENT INVENTORY
+The documents submitted are as follows:
+Signature of Records Custodian:
diff --git a/vision-fixhub/ds9-unparsed-05/cd98e3f9331e9cc896e0cddf4da5d8fe636b9226283bec0152b1ff1d9c3a7e7b.receipt.json b/vision-fixhub/ds9-unparsed-05/cd98e3f9331e9cc896e0cddf4da5d8fe636b9226283bec0152b1ff1d9c3a7e7b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..8c6e9274180110553155e76232fe1dac6264c168
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cd98e3f9331e9cc896e0cddf4da5d8fe636b9226283bec0152b1ff1d9c3a7e7b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -60,
+  "dataset": "marble-joined",
+  "doc_id": "cd98e3f9331e9cc896e0cddf4da5d8fe636b9226283bec0152b1ff1d9c3a7e7b",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "7dc3a719f1b524cb5cf15ad8be38a30b2bf0469388e0991076931b498bee5f8b",
+  "output_sha256": "5810152b7d04eaaecd88b6e6b38bc7e7c8a5a7926f3935b5bb504105e50c5837",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ce06d92ba0f0b5f7aff01763621bd9ea61f87ad8f090dfe951616eba48690f2a.md b/vision-fixhub/ds9-unparsed-05/ce06d92ba0f0b5f7aff01763621bd9ea61f87ad8f090dfe951616eba48690f2a.md
new file mode 100644
index 0000000000000000000000000000000000000000..98d85e3d2e2aadca3a586ccf00e1eca2a92cfd86
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ce06d92ba0f0b5f7aff01763621bd9ea61f87ad8f090dfe951616eba48690f2a.md
@@ -0,0 +1,356 @@
+AO 91 (Rev. 5/85) Criminal Complaint AUSA VILLAFAÑA
+FILED by
+UNITED STATES OF AMERICA
+United States District Court
+DEC - | 2009
+SOUTHERN DISTRICT OF FLORIDA
+CEVER US. DIST C
+D. OF FLA. - WE
+CRIMINAL COMPLAINT
+VS.
+CASE NUMBER: 09-8308-LRJ
+ALFREDO RODRIGUEZ,
+Defendant.
+/
+I, the undersigned complainant, being duly sworn, state the following is true and correct to the best
+of my knowledge and belief.
+From at least as early as January 18, 2007, through on or about November 3, 2009, in Palm Beach
+County, in the Southern District of Florida, and elsewhere, the defendant,
+ALFREDO RODRIGUEZ,
+did corruptly conceal a record, document, or other object, with the intent to impair the object's availability
+for use in an official proceeding and otherwise corruptly obstructed or impeded an official proceeding,
+in violation of Title 18, United States Code, Section 1512(c)
+I further state that I am a _
+Special Agent with the Federal Bureau of Investigation
+Complaint is based on the following facts:
+_ and that this
+Please see attached Affidavit
+Continued on the attached and made a part hereof.
+Special Aggnt
+Federal Bureau of Investigation
+Sworn to before me, and subscribed in my presence,
+upon my finding of probable cause
+December /
+Date
+, 2009
+at
+West Palm Beach, Florida
+City and State
+LINNEA R. JOHNSON
+UNITED STATES MAGISTRATE JUDGE
+Sean
+Signature of Judiciat officer
+3
+
+
+AFFIDAVIT
+being duly sworn, do state and attest as follows:
+I am a Special Agent with the Federal Bureau of Investigation (FBI) and have
+been so employed for three (3) months. I am currently assigned to the Safe Streets Task
+Force, Miami Field Division, FBI Squad PB-2. Prior to joining the Miami Field Division,
+I attended the FBI Academy in Quantico, Virginia, for five (5) months where I received
+training in federal criminal laws and investigation techniques, including the laws related to
+obstruction of justice.
+This affidavit is based upon my own personal knowledge of the facts and
+circumstances surrounding the investigation, and information provided to me by other law
+enforcement officers. This affidavit does not purport to contain all the information known
+to me about this case but addresses only that information necessary to support a finding of
+probable cause for the issuance of a criminal complaint charging Alfredo Rodriguez with
+obstruction of official proceedings, in violation of Title 18, United States Code, Section
+1512(c).
+3.
+On October 27, 2009, agents of the FBI met with and interviewed a
+cooperating witness
+The
+reported that, while conducting discovery in a
+pending civil case before the United States District Court for the Southern District of Florida,
+he came into contact with Alfredo Rodriguez ("Rodriguez"), who was a subpoenaed witness
+in the civil case.
+4.
+Rodriguez had been interviewed by FBI agents on January 18, 2007, in
+connection with a federal criminal investigation into the sexual exploitation of minors. Prior
+
+
+to being interviewed by FBI, Rodriguez had also been contacted and interviewed by local
+police detectives, and had been asked to produce documents related to the criminal
+investigation. The civil litigation involving the
+related to civil damages claims made by
+victims of the criminal activity that formed the basis of the state and federal criminal
+investigations.
+The explained to agents that Rodriguez had been deposed under oath on
+two occasions. The first deposition occurred on July 27, 2009, and the second deposition
+was conducted on August 9, 2009. In connection with those depositions, Rodriguez was
+served with a subpoena duces tecum that called for the production of several types of
+documentary evidence. The
+was present for both depositions and Rodriguez testified
+that he had no documents responsive to the subpoena duces tecum.
+6.
+In August 2009, after the conclusion of the second deposition, the
+received
+a phone call from Rodriguez. Rodriguez informed the that he had additional information
+that he had not previously disclosed to any law enforcement agency or any of the civil
+attorneys. Rodriguez described the information as, the Holy Grail or Golden Nugget and
+explained that he had compiled lists of additional victims in the case and their contact
+information. Rodriguez explained that the information contained hundreds of additional
+victims and their phone numbers from diverse geographic locations, including New York,
+New Mexico, and Paris, France.
+7.
+Rodriguez asked the
+to pay him $50,000.00 and, in return, Rodriguez.
+would turn over the documents relating to the victims. In his initial and subsequent
+2
+
+
+communications with Rodriguez, the
+explained to Rodriguez that he was under
+subpoena to turn over such information and that it would be illegal for Rodriguez to demand
+money for turning over the information. Rodriguez persisted that he would only turn over
+the information in his possession in exchange for $50,000.00.
+On October 28, 2009, in a consensually-monitored phone call, the
+telephoned Rodriguez. Rodriguez again indicated that he would not turn over the
+information relating to the additional victims without monetary compensation. Rodriguez
+was told that an associate of the
+would be in touch with him regarding the information
+and exchange. The associate that the
+referred to was, in fact, an undercover employee
+(UCE) of the FBI.
+9.
+On October 29, 2009, the FBI UCE contacted Rodriguez via telephone.
+Rodriguez again explained that he would only turn over the information in exchange for
+monetary compensation. The UCE advised Rodriguez that it would take several days to
+acquire the funds and that once the funds were obtained, he/she would contact Rodriguez.
+During the conversation, Rodriguez admitted that he knew that the information was relevant
+to the FBI's criminal investigation and was called for by the investigation. Rodriguez
+explained that he had not turned over the information to the FBI because: (1) it was his
+"property" and he should be compensated for it; and (2) he was afraid that the target of the
+investigation would make him "disappear" or otherwise harm him, and the information was
+his "insurance policy."
+10. On November 2, 2009, the UCE made contact with Rodriguez via telephone.
+3
+
+
+In that conversation, Rodriguez and the UCE continued the discussion regarding the purchase
+of the documents and scheduled a meeting for the following day.
+11.
+On November 3, 2009, Rodriguez met with the UCE at a predetermined
+location. During the meeting, Rodriguez produced a small bound book and several sheets
+of legal pad paper containing hand written notes. Rodriguez explained that he had taken the
+bound book from his former employer's residence while employed there in 2004 to 2005 and
+that the book had been created by persons working for his former employer. Rodriguez
+discussed in detail the information contained within the book, and identified important
+information to the UCE. In addition, Rodriguez admitted he had previously lied to FBI.
+Rodriguez asked the UCE about the $50,000.00, took possession of the money, and began
+counting it.
+12. Rodriguez was then detained for Obstruction of Official Proceedings, Title 18,
+U.S. Code, Section 1512(c), and questioned. After Miranda warnings were administered by
+agents, Rodriguez waived his rights and signed a written waiver of those rights. Rodriguez
+admitted that he had the documents and book in his possession and had never turned them
+over to local law enforcement or the FBI. In addition, Rodriguez advised he had witnessed
+nude girls whom he believed were underage at the pool area of his former employer's home,
+knew that his former employer was engaging in sexual contact with underage girls, and had
+viewed pornographic images of underage girls on computers in his employer's home.
+Rodriguez was then released from custody for further investigation.
+13.
+The items that Rodriguez had attempted to sell to the UC for $50,000.00
+4
+
+
+were reviewed by an agent familiar with the underlying criminal investigation. As Rodriguez
+had described, the items contained information material to the underlying investigation that
+would have been extremely useful in investigating and prosecuting the case, including the
+names and contact information of material witnesses and additional victims. Had those items
+been produced in response to the inquiries of the state law enforcement officers or the FBI
+Special Agents, their contents would have been presented to the federal grand jury.
+Based upon the foregoing, your affiant believes that probable cause exists to believe
+that, from at least as early as January 18, 2007 through on or about November 3, 2009, in
+Palm Beach County, in the Southern District of Florida, and elsewhere, Alfredo Rodriguez
+did corruptly conceal a record, document, or other object, with the intent to impair the
+object's availability for use in an official proceeding and otherwise corruptly obstructed or
+impeded an official proceeding, in violation of Title 18, United States Code, Section 1512(c).
+FURTHER YOUR AFFIANT SAYETH NAUGHT.
+SPECIAL AGENT
+FEDERAL BUREAU OF INVES HGATION
+Sworn to and subscribed before me
+this
+_ day of December, 2009.
+INNEA R. JOHNSON
+UNITED STATES MAGISTRATE JUDGE
+5
+
+
+Case No.
+UNITED STATES OF AMERICA
+VS.
+ALFREDO RODRIGUEZ,
+Defendant.
+09-8308-LRJ
+1.
+CRIMINAL COVER SHEET
+Did this matter originate from a matter pending in the Northern Region of the Unite
+States Attorney's Office prior to October 14, 2003'
+. Yes X
+Did this matter originate from a matter pending in the Central Region of the United
+States Attorney's Office prior to September 1, 2007?
+_ Yes_X No
+Respectfully submitted,
+ACTING UNITED STATES ATTORNEY
+Assistant United States Attorney
+Florida Bar No.
+500 East Broward Boulevard, 7th Floor
+Ft Lauderdale, FL 33394
+ann.marie.c.villafana@usdoj.gov
+
+
+P$3-shortform
+(12/4/08)
+NOT TO BE READ BY AGENTS: This report is provided for the purpose AL DETERMINATION ONLY and shal otherise be confidental
+pursuant to: 18 USC 3153(c)(1).
+_AUSA
+_DEFENSE COUNSEL
+FOR COURTROOM USE ONLY
+RETURN TO PRETRIAL SERVICES OFFICER IMMEDIATELY AFTER HEARING
+MUST NOT BE TAKEN OUT OF COURTROOM
+SOUTHERN DISTRICT OF FLORIDA/WPB
+ABBREVIATED PRETRIAL SERVICES REPORT
+CHARGE(S):
+JUDICIAL OFFICER:
+THE HONORABLE
+U.S. MAGISTRATE JUDGE
+DOCKET NUMBER:
+DEFENDANT
+NAME: Aifreda Nun Rodriguez, EMPLOVERSCHOOL AND ADDRESS: FTIPT
+ADDRESS.
+Firearms in residence: Yes (No)
+TIME AT ADDRESS:
+Vicious animals: Yes No)
+TIME IN SD/FL:
+17yr5
+LENGTH OF TIME UNEMPLOYED:
+MONTHLY INCOME:
+TIME EMPL/SCHOOL:
+RESIDES WITH:
+TELEPHONE NUMBER:
+(e)
+DEFT. TELEPHONE
+CELL PHONE:
+RENT/MTG
+$ 450/mo
+CIRCLE ONE:
+(OWN/B)YING)
+(RENTING) (NO CONTRIBUTION) (UNKNOWN)
+DEFENDANT HISTORY
+DUE TO TIME CONSTRAINTS, THE FOLLOWING ABBREVIATED PRETRIAL SERVICES REPORT WAS PREPARED FOR YOUR HONOR'S
+CONSIDERATION. THE FOLLOWING INFORMATION IS UNVERIFIED, EXCEPT WHERE NOTED.
+DEFENDANT HISTORY / RESIDENCE / FAMILY TIES:
+DATE OF BIRTH:
+SSN:
+CITIZENSHIP:
+Aterilizerl
+DATE OF ENTRY:
+PLACE OF BIRTH:
+RACE/SEX:
+IMMIGRATION STATUS:
+PASSPORTS/VISAS (valid or capired) LOCATION:
+PRIMARY LANG: Spanish
+English
+FOREIGN TRAVEL (PAST 5 YEARS\
+/ No
+Where:
+Where:
+When:
+When:
+OTHER/ PRIOR RESIDENCES (Including other states or countries)
+DATES
+LIVED WITH WHOM
+
+
+NAME
+FAMILY AND FRIENDS
+RELATIONSHIP
+ADDRESS /TELEPHONE NUMBER
+I DREN
+CURRENT MARITAL STATUS: (MARRIED) (DIVORCED (CO-HABITATING) (SINGLE) (SEPARATED) (WIDOWED) (UNKNOWN)
+<2)
+NAME OF SPOUSE OR SIGNIBICANT OTHERI
+ADDRESS:
+NAME OF EX-SPOUSE
+NAME/AGE OF CHILDREN
+ADDRESS
+Length of Relationship or:
+FREQUENCY
+OF CONTACT
+riel
+SUPPORT
+YES / NO
+AMT/FREQ
+EDUCATIONAL HISTORY:
+HIGHEST LEVEL OF EDUCATION
+(HIGH SCHOOL DIPLOMA) (NO HIGH SCHOOL DIPLOMA / GED) (VOCATIONAL/APPRENTICE GRADUATE)
+(ASSOCIATE'S DEGREE) (BACHELOR'S DEGREE) (MASTER'S DEGREE) (DOCTORATE) (UNKNOWN)
+NAME/LOCATION
+| LAST GRADE/CREDIT COMPLETED AND/OR
+YEAR COMPLETED
+
+
+3.
+MILITARY EXPERIENCE (ACTIVE AND/OR RESERVE DUTY):
+BRANCH OF SERVICE...
+I DATE OF ENTRY
+I DATE OF DISCHARGE
+I TYPE OF DISCHARGE mained
+PRESENT EMPLOYMENT:
+NAME AND ADDRESS:
+PRESENT LENGTH OF TIME EMPLOYED:
+(UNKNOWN) UNÈMPLOYED)
+PRESENT JOB DESCRIPTION:
+PRESENT MONTHLY SALARY:
+DATES/NAME OF EMPLOYER
+PREVIOUS EMPLOYMENT
+- ADDRESS OF EMPLOYER
+JOB DESCRIPTION/SALARY
+FINANCES
+ASSETS (INCLUDING VALUES)
+LIABILITIES/DEBTS (INCLUDING RENT/MORTGAGE)
+5.
+HEALTH:
+PHYSICAL HEALTH:
+(NONE)
+(UNKNOWN) (MINOR MEDICAL ONLY) (SIGNIFICANT MEDICAL UNDER CONTROL) (RECURRENT MEDICAL)
+(UNCONTROLLED SIGNIFICANT DISORDER) (EVALUATION OR TX IN PROGRESS)
+MEDICAL ILLNESSES/CONDITIONS
+MEDICATIONS
+SPECIFIC TREATMENT
+
+
+DIAGNOSIS
+MENTAL HEALTH PROBLEMS
+(NONE) (UNKNOWN) (HISTORY/NON-ACTIVE) (CURRENT/ON-GOING)
+DATES
+MEDICATIONS
+TREATMENT
+TYPE OF SUBSTANCE
+Age use began
+SUBSTANCE ABUSE HISTORY:
+(NONE) (PAST) (CURRENT)
+LAST USE
+FREQUENCY
+TREATMENT:
+(None) (In-patient) (Out-patient)
+6.
+8.
+9.
+PRIOR RECORD:
+HECK CONDUCTED THROUGH THE LOCAL, STATE AND FEDERAL DATABASES REVEALED:
+NO PRIOR ARREST HISTORY.
+SEE ATTACHED RECORD.
+PENDING
+OFFENSE CHARGED AND CIRCUMSTANCES OF THE ARREST: THE DEFENDANTIS PRESENT BEFORE YOUR
+HONOR TODAY FOR AN INITIAL APPEARANCE BASED ON THE ABOVE NOTED CHARGES. NO FURTHER
+INFORMATION IS AVAILABLE REGARDING THE CIRCUMSTANCES OF THE ARREST.
+ASSESSMENT OF NONAPPEARANCE AND DANGER: AN ASSESSMENT HAS NOT BEEN MADE DUE TO TIME
+CONSTRAINTS.
+RECOMMENDATION: A BOND RECOMMENDATION IS WITHHELD AT THIS TIME.
+U.S. PROBATINO
+DATE: 12.9.09
+TIME OF INTERVIEW:
+4
diff --git a/vision-fixhub/ds9-unparsed-05/ce06d92ba0f0b5f7aff01763621bd9ea61f87ad8f090dfe951616eba48690f2a.receipt.json b/vision-fixhub/ds9-unparsed-05/ce06d92ba0f0b5f7aff01763621bd9ea61f87ad8f090dfe951616eba48690f2a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..10b17afa7ac8c59d8d8edeef8158863d9f8671f7
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ce06d92ba0f0b5f7aff01763621bd9ea61f87ad8f090dfe951616eba48690f2a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -132,
+  "dataset": "marble-joined",
+  "doc_id": "ce06d92ba0f0b5f7aff01763621bd9ea61f87ad8f090dfe951616eba48690f2a",
+  "engine": "marble-apple-vision",
+  "event_count": 11,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "76e4295dbeac077191c6018ff5450fe604427485db2e9346fad3540b6a32475b",
+  "output_sha256": "8c7f01c21ae87b343d8b734d9072b035bd79b689208f515ce78d88dc1b6ea5d3",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ce2e1b0413f28cb87d8401cc9a5cea25940537294bc47a3c82a1217d6ceee5a2.md b/vision-fixhub/ds9-unparsed-05/ce2e1b0413f28cb87d8401cc9a5cea25940537294bc47a3c82a1217d6ceee5a2.md
new file mode 100644
index 0000000000000000000000000000000000000000..e59156957ed3aef9d06f85b62fb0ae010387e1b6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ce2e1b0413f28cb87d8401cc9a5cea25940537294bc47a3c82a1217d6ceee5a2.md
@@ -0,0 +1,5522 @@
+09-22783
+Original Transcript
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+CIV-MARRA/JOHNSON
+Defendant.
+DEPOSITION OF
+MARK EPSTEIN
+11:30 a.m.
+One Penn Plaza,
+New York, New York
+Jacklyn Lisi
+an Alesander Gallo Company
+Suite 130
+15 East Las Olas Boulevar
+
+
+
+
+1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE,
+Plaintiff,
+Vs.
+CIV-MARRA/JOHNSON
+JEFFREY EPSTEIN,
+Defendant.
+DEPOSITION Of MARK EPSTEIN, taken by
+Defendants, at the offices of Esquire Deposition Solutions,
+One Penn Plaza, New York, New York 10119, on Monday,
+September 21, 2009, commencing at 11:30 a.m., before Jacklyn
+Lisi, a Shorthand Reporter and notary public, within and for
+the State of New York.
+an Alexander Galle Company
+Suite 1300
+s Boulevard
+ve, FL 33301
+
+
+1
+2
+4
+5
+6
+7
+8
+9
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+25
+2
+APPEARANCES:
+ROTHSTEIN ROSENFELDT ADLER, ESQS.
+Attorneys for Plaintiffs, EW, IM and Jane Doe
+Las Olas City Centre, Suite 1650
+401 East Las Olas Boulevard
+Fort Lauderdale, Florida 33301
+BY: BRAD J. EDWARDS, ESQ.
+LEOPOLD KUVIN, ET AL
+Attorneys for Plaintiff, BB
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, Florida 33410
+BY: ADAM LANGINO, ESQ.
+(via telephone)
+COHEN & GRESSER, LLP
+Attorneys for the Witness, Mark Epstein
+100 Park Avenue
+New York, New York 10017
+BY: MARK S. COHEN, ESQ.
+ALEXIS G. STONE, ESQ.
+PODHURST ORSECK, et al
+Attorneys for Plaintiffs, Jane Does 101 and 102
+25 West Flagler Street, Suite 800
+Miami, Florida 33130
+BY: KATHERINE EZELL, ESQ.
+(via telephone)
+MERMELSTEIN & HOROWITZ, ESQS.
+Attorneys for Plaintiffs, Jane Does 2 through
+8205 Biscayne Boulevard, Suite 2211
+BY: ADAM H. HOROWITZ, ESQ.
+Alexander Galle Compaay
+Toll Free: 800.211.3376
+acsimile: 954.331.4418
+Suite 1300
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+3
+APPEARANCES (continued)
+RICHARD H. WILLITS, ESQ.
+Attorney for Plaintiff,
+2290 10th Avenue North, Suite 404
+Lake Worth, Florida 33461
+(via telephone)
+BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
+Attorneys for the Defendant, Jeffrey Epstein
+515 North Flagler Drive, Suite 400
+West Palm Beach, Florida
+33401
+BY: ROBERT CRITTON, ESQ.
+(via telephone)
+***
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+is Alexander Gallo Company
+Suite 1300
+
+
+4
+STIPULAIIONS
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+IT IS HEREBY STIPULATED, by and between the attorneys
+for the respective parties hereto, that all rights provided
+by the C.P. I.R., and Part 221 of the Uniform Rules for the
+Conduct of Depositions, including the right to object to any
+question, except as to form, or to move to strike any
+testimony at this examination is reserved; and in addition,
+the failure to object to any question or to move to strike
+any testimony at this examination shall not be a bar or
+waiver to make such motion at, and is reserved to, the trial
+of this action.
+This deposition may be sworn to by the witness being
+examined before a Notary Public other than the Notary Public
+before whom this examination was begun, but the failure to
+do so or to return the original of this deposition to
+counsel, shall not be deemed a waiver of the rights provided
+by Rule 3116 of the C.P.L.R. and shall be controlled
+thereby.
+The filing of the original of this deposition is
+waived.
+21
+22
+23
+24
+25
+*
+*
+*
+an Alexander Gallo Company
+Suite 1300
+
+
+5
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+THE REPORTER: Please state your name
+and address for the record?
+THE WITNESS: (Witness refused to give
+his address to the court reporter.)
+MR. COHEN: On the record.
+For the witness, Mark Epstein, Mark
+Cohen and Alexis Stone of Cohen & Gresser, 100
+Park Avenue, New York, New York.
+MR. EDWARDS: Brad Edwards on behalf
+of
+and Jane Doe.
+MR. CRITTON: Robert Critton on
+behalf of Jeffrey Epstein.
+MS. EZELL: Kathy Ezell on behalf of
+Jane Does
+MR. HOROWITZ: Adam Horowitz on
+behalf of Plaintiffs, Jane Does
+MR. WILLITS: Richard Willits on
+behalf of
+MR. LANGINO: Adam Langino on behalf
+of Plaintiff, I
+MR. EDWARDS Okay. That's everybody.
+MR. COHEN: Okay.
+Before I start,
+this is Mark Cohen on behalf of Mark Epstein,
+I just want to put on the record the details
+an Alexander Gallo Company
+Toll Free: 800.211.337€
+Suite 1300
+
+
+6
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+of a conversation I've had with Mr. Edwards
+and make sure that all counsel is agreeable to
+this.
+My client, Mark Epstein, is very
+concerned about being videotaped and having
+his image recorded.
+He is concerned about possible future
+uses of his image. And so Mr. Edwards and I
+have agreed that this recording, the videotape
+of my client, will be confidential and will
+not be revealed in public unless and until
+there is an order by a court in one of the
+cases that are involved in these depositions
+that orders that the video be made public.
+We are prepared to proceed on that
+basis.
+As I understand, Mr. Edwards is
+prepared to proceed, but obviously we need the
+agreement of all counsel.
+MR. WILLITS: Richard Willits agrees.
+MR. CRITTON: Robert Critton agrees.
+MS. EZELL: Kathy Ezell agrees.
+MR. EDWARDS: Adam?
+MR. HOROWITZ: Adam Horowitz, that's
+sa Alexaeder Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+7
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+fine.
+MR. LANGINO: The same with Adam
+Langino, that's fine.
+MR. COHEN: All right. Thank you.
+MR. EDWARDS And Sid Garcia is not in
+and he is not supposed to be in; right?
+MR. CRITTON: This is Bob Critton.
+I assume -- I don't know whether he
+was going to come or not, but I assume that
+everyone will also abide and not give Mr.
+Garcia a copy of the video until he also
+affirms in writing to Mr. Cohen that he's
+agreed to be bound by the same agreement.
+MR. EDWARDS: Okay.
+THE VIDEOGRAPHER: This is tape
+number one to the videotape deposition of Mark
+Epstein in the matter of Jane Doe versus
+Jeffrey Epstein being held before the United
+States District Court in the Southern District
+of Florida, case file number 08-80893.
+This deposition is being held at
+Esquire Deposition Solutions, One Penn Plaza,
+New York, New York on September 21, 2009. The
+time is 11:41 a.m.
+1e Alexander Galle Compasy
+Toll Free: 800.211.3376
+Suite 1300
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+8
+M. Epstein
+My name is Peter Ledwith. I'm the
+videographer. The court reporter is Jackie
+Lisi.
+counsel, will you please introduce
+yourselves and who you represent?
+MR. EDWARDS: Brad Edwards. I
+represent
+Jane Doe.
+MR. COHEN: Mark Cohen and 'Ally
+Stone. I represent the witness, Mark Epstein.
+MR. CRITTON: Robert Critton on
+behalf of the defendant, Jeff Epstein.
+MR. WILLITS: Richard Willits on
+behalf of
+MR. LANGINO: Adam Langino on behalf
+of Plaintiff
+MR. HOROWITZ: Adam Horowitz on
+behalf of plaintiffs Jane Does numbers
+THE VIDEOGRAPHER: Will the court
+reporter please swear in the witness?
+MARK EPSTEIN,
+having been first duly affirmed, was examined
+and testified as follows:
+THE WITNESS: I am an atheist, but I
+in Alesander Gallo Compasy
+Toll Free: 800.211.3376
+515 East Las Olas Bote aro
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+9
+M. Epstein
+will affirm I'll tell the truth.
+EXAMINATION BY
+MR. EDWARDS:
+e. Can you tell us your name?
+A. Mark Epstein.
+THE VIDEOGRAPHER: Can you put the
+microphone on your shirt, please?
+THE WITNESS: Mark Epstein.
+l. Okay. And your date of birth,
+please?
+A.
+l. And what is your relationship with
+the defendant in this case, Jeffrey Epstein?
+A. He is my brother.
+l. Are you currently married?
+A. No.
+l. What is your current address?
+A. I'm not giving out my address. I'm
+concerned about my personal safety because of
+the nature of this case. You can use his
+address. You can use my attorney's address.
+l. Please elaborate on that for me that
+you are concerned for your safety because of
+the nature of this case?
+an Alesander Galle Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+10
+1
+2
+3
+4
+5
+M. Epstein
+A. Because I've read -- well, I know
+that Jeffrey hired a detective or someone from
+the police when he went out on his days out.
+So obviously there is probably a concern for
+safety.
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+I don't want anything to do with this
+case. I have nothing to do with this case. I
+don't want my identifying information on any
+kind of public record.
+MR. COHEN: If it will make it
+easier, Mr. Edwards, this is Mark Cohen
+speaking. Mr. Mark Epstein is authorizing my
+firm to accept service if there is a future
+subpoena or a need to contact him again.
+THE WITNESS: Before we go on, I want
+to make a statement.
+I want to say on the record that
+initially I was improperly served with a
+subpoena from Florida, it was supposed to come
+from New York.
+It also did not include the required
+documents giving me my rights and obligations
+under the Florida laws.
+So it's a breach of
+some kind of ethics.
+«a Alexaader Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+11
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+So in my book, you are either
+incompetent, devious or have no ethical
+compass.
+So you are not on my high list.
+Continue with your questions. I just wanted a
+record of that.
+MR. CRITTON: Brad, can you move the
+phone a little closer to Mr. Epstein? I heard
+you and I heard Mr. Cohen fine, but I'm having
+trouble with Mr. Epstein.
+MR. EDWARDS: All right.
+MR. CRITTON: Thank you.
+MR. EDWARDS: I apologize for your
+feelings about the subpoena.
+THE WITNESS: Not accepted.
+This is too serious of a matter.
+BY MR. EDWARDS:
+l. You do realize that you are
+subpoenaed to testify today in cases that
+involve your brother having sex or engaging in
+sex acts with minors; correct?
+MR. CRITTON: Form?
+MR. COHEN: That's --
+A. I know there is a case against my
+a Alexander Galle Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+12
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+brother. I know that.
+e. And you are aware that there are
+multiple attorneys on the phone that represent
+girls who were under-age when Mr. Epstein had
+sex with them?
+A. I know there are multiple attorneys
+on the phone.
+l. Okay. Have you read the newspaper
+articles about your brother that detail your
+brother having sex with under-age girls?
+MR. CRITTON: Form.
+A. I've read some of the papers.
+l. You agree that sex with minors is
+wrong?
+MR. CRITTON: Form.
+MR. COHEN: Objection.
+e. You can answer.
+A. I have no opinion on that.
+Q. Okay.
+A. I'm not here to give opinions. I'm
+here for facts. So ask me questions about
+facts and I'll be glad to answer them.
+Q. Well, do you agree with the laws that
+protect under-age children from adult sexual
+an Alexander Gallo Company
+Toll Free: 800.211.337€
+Facsimile: 954.331.4416
+Suite 1300
+
+
+13
+1
+2
+3
+4
+5
+6
+M. Epstein
+8
+predators?
+MR. COHEN: Objection.
+MR. CRITTON: Form.
+A. My information on the case is my
+brother I know had to spend sometime in jail
+for some prostitution charge.
+So I assume the attorneys are
+representing the prostitutes he was involved
+with, so I don't know what the ages of them
+are or were.
+I'm not involved with the case. I
+don't watch all the details about it. That's
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+all.
+21
+23
+24
+25
+l. Would it surprise you to learn that
+there were more than 30 girls between the ages
+of 12 and 15 that your brother engaged in sex
+acts with?
+MR. CRITTON: Form.
+A. I don't get surprised by very many
+things in this world.
+l. But you and your brother are a year
+apart; right?
+A. 18 months.
+l. And you grew up together?
+aa Alexander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+14
+1
+2
+3
+4
+5
+M. Epstein
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A. Sure.
+e. You still talk to him?
+A. Occasionally, rarely.
+l. So when I ask you, does it surprise
+you, you are saying that it doesn't surprise
+you that your older brother engaged in sex
+with more than 30 girls between 12 and
+15 years old?
+MR. COHEN: Objection.
+MR. CRITTON: Form.
+A. I don't know how to answer that
+question. I don't know if it's true, and I
+don't know what the story is.
+It's not -- ask me a question about
+facts. I'm not going to give you opinions
+here, that's not what I'm here for.
+e. Do you have children?
+A. Yes, I do.
+Q. How old?
+A. Seven and five.
+l. Boys or girls?
+A. What does my children have to do with
+this? Leave my family out of this, please.
+l. I think it's a fair question.
+an Alezaader Gallo Compray
+Toll Free: 800.211.337
+acsimile: 954.331.441
+Suite 1300
+
+
+15
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+A. I think it's a fair answer.
+l. I need an answer.
+A. You got one.
+l. Boys or girls?
+A. Next question.
+MR. EDWARDS: Counsel?
+MR. COHEN: I would suggest you move
+to an area that's likely to lead to you
+gathering relevant evidence.
+We can come back to this burning
+question maybe later.
+MR. CRITTON: Let me also add that I
+can only object to form, but I also want to
+put on the record, other than his name and he
+is related to Mr. Epstein, there is not one
+piece of evidence or --
+THE COURT REPORTER: I can't hear
+you.
+MR. CRITTON: I'm sorry. I just want
+to note for the record that other than his
+name and his relationship to Mr. Epstein, to
+Jeffrey Epstein, there has been nothing of
+relevance or materiality that would lead to
+admissible evidence at the time of trial.
+in Alexander Galle Company
+Facinie: 954-31416
+Suite 1300
+
+
+16
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+This is being done to harass or
+humiliate Mr. Mark Epstein and/or my client.
+It certainly borders on that, but he is not an
+expert, his opinions are irrelevant in this
+case, and as is his own family situation
+but --
+MR. EDWARDS: Mr. Critton, as you
+stated first, I think that your objection is
+limited to the form. Thanks.
+Can I mark this as an exhibit?
+(Plaintiff's Exhibit 1 was so marked
+for identification.)
+MR. COHEN: I will say that I join in
+Mr. Critton's objection for the record.
+BY MR. EDWARDS:
+l. How frequently do you talk with your
+brother now?
+A. Maybe once every couple of weeks or
+so, but "now" being just the last month or
+two.
+l. Okay. When you first learned of a
+criminal investigation into your brother, did
+you talk to him about the substance of those
+allegations?
+as Alexander Gallo Company
+oll Free: 800.211.337
+icsimile: 954.331.44:
+Suite 1300
+
+
+17
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+A. NO.
+e. Have you ever asked him or had a
+conversation with him about the allegations
+that he's had sex with numerous under-age
+kids?
+A. NO.
+l. Is there a reason why you wouldn't
+ask him questions about him engaging in sex
+with 13, 14-year old kids?
+A. We are not very close. We don't talk
+very often.
+MR. CRITTON: Form.
+l. But when you do talk to him, that
+conversation doesn't come up?
+A. NO.
+l. He went to jail. Did he ever tell
+you why he went to jail?
+A. No.
+e. Are you familiar with the property at
+301 East 66th Street?
+A. Yes, I am.
+Q. Who owns that property?
+A. Dara Partners.
+Q. And what is Jeffrey Epstein's
+*a Alezander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+18
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+21
+22
+23
+24
+25
+M. Epstein
+affiliation with that property?
+A. He rents some apartments in there.
+l. How many apartments does Jeffrey
+Epstein rent at 301 East 66th Street?
+A. It's either 8 or 10, I am not sure.
+e. Who are the residents of the
+apartments that Jeffrey Epstein rents at that
+location?
+A. I have no idea.
+MR. CRITTON: Brad, what was the
+answer to the last one?
+MR. COHEN: He has no idea.
+A. I know his pilots used to stay there,
+but I don't think he is using pilots any more.
+Q. Why does he rent so many places at
+the same location?
+A. I have no idea.
+l. Have you ever had any affiliation
+with that location?
+A. Sure.
+Q. In what way?
+A. I'm one of the partners of Dara
+Partners.
+l. So does your brother rent from you?
+ander Galle Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+19
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+A. No, he rents from Dara Partners. My
+partner handles that property, I don't know
+any of the tenants in that building other than
+one or two.
+l. What are the names of the one or two
+that you do know?
+A. It is my ex, so I'm not going to give
+you her name.
+l. Is that somebody who lives in one of
+the places rented by your brother Jeffrey
+Epstein?
+A. No.
+l. Do you know any of the tenants that
+live in the places rented by your brother,
+Jeffrey Epstein?
+A. No.
+e. Do you know
+A. I know the name. I don't know her.
+2. Do you know what her relationship is
+to your brother?
+A. I think she worked for him.
+Q. In what capacity?
+A. I have no idea.
+l. Do you know if she lives in 301 East
+a Alesander Gallo Compasy
+Toll Free: 800.211.337
+acsimile: 954.331.4411
+Suite 1300
+
+
+20
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+66th Street?
+A. I don't know where she lives.
+e. Would you know her if you saw her?
+A. No.
+l. You've never seen her before?
+A. I might have seen her somewhere, I
+don't know.
+l. Have you ever talked to her?
+A. I don't recall talking to her.
+Q. Do you know
+A. I know of her.
+Q. How do you know of her?
+A. In the papers.
+Q. What papers?
+A. Newspapers. I read some articles.
+Q. Newspapers about your brother?
+A. Relating to his case, yes.
+Q. Okay. And what is your understanding
+of her relationship with your brother?
+A. I don't have an understanding about
+it.
+MR. CRITTON: Form.
+A. My brother and I do not have a close
+relationship, so what he does is his business
+an Alexander Galle Company
+oll Free: 800.211.337
+acsimile: 954.331.441
+Suite 1300
+
+
+21
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+and what I do is my business.
+We don't communicate back and forth
+about our personal lives very often. I talk
+to him to find out if he is well. That's all
+I need to know.
+l. Does he tell you that he is well
+these days?
+A. Yes.
+e. Do you know what his future plans are
+in terms of where he intends to live once he
+is off probation or house arrest?
+A. I have no idea.
+l. Is that a topic that you would ever
+talk to him about?
+A. NO.
+l. So what is it that you talk to him
+about when you call?
+A. See how he is doing, see if he is
+okay.
+l. Does he call you as well?
+A. Sometimes.
+Q. What is his telephone number?
+A. Where?
+e. What are the telephone numbers that
+as Alexander Gallo Compaay
+Toll Free: 800.211.3376
+Suite 1300
+
+
+22
+1
+2
+M. Epstein
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+you reach him at?
+A. A lot of times I call his office and
+I have them tell him to call me.
+e. What is his office number?
+A.
+e. Who do you speak to at his office?
+A. Whoever answers the phone.
+e. Do you know any of the people in his
+office that typically answer the phone?
+A. Some.
+O. Who are you familiar with there?
+A. Darren. An attorney, Darren.
+Q. Darren Indyke?
+A. Yes.
+e. So normally the way that you get in
+touch with your brother is to call his office
+and they forward you on to him?
+A. No, I tell them to have him call me.
+Well, sometimes, I mean I've called him
+directly too, but most of the time he is not
+there so it's easier just to leave a message
+to have him call me.
+Q. Well, these days now that he is on
+house arrest, normally if you called him he'd
+an Alexander Gallo Compeny
+Toll Free: 800.211.3376
+Suite 1300
+
+
+23
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+be there, right?
+A. I don't know the term house arrest.
+I don't know if he'd be there or not. And if
+I called there and sometimes he doesn't answer
+or the phone doesn't get answered, so I don't
+know where he is.
+Q. What's the number that you would call
+to reach him?
+A.
+l. Is it your understanding that is a
+cell phone or is that the land line?
+A. I thought it was a land line.
+e. And what is your telephone number?
+A. I'm not giving you any identifying
+information.
+MR. EDWARDS: We can come back to
+that?
+MR. COHEN: Why don't we come back to
+that.
+MR. EDWARDS: Okay.
+l. Are you familiar with your brother's
+businesses?
+A. NO.
+l. Do you know a person by the name of
+an Alezander Gallo Company
+Toll Free: 800.211.337
+Suite 1300
+
+
+24
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+Jean Luc Brunel?
+A. NO.
+l. How often are you at the property at
+301 East 66th Street?
+A. I pick up my children there
+sometimes. Maybe -- well, actually, they are
+in school now so I'm not there that often,
+because I pick them up at school.
+During the summers I would pick them
+up there once a week.
+Q. Is that where the subpoena was served
+on you?
+A. No, the subpoena was served on me in
+the street of New York.
+e. Near that building?
+A. NO.
+l. No where near that building?
+A. It was in The City of New York, it
+depends on what you mean by "near."
+Q. Have you been to your brother's house
+in New York?
+A. Yes.
+e. How many occasions?
+A. Under five.
+as Alexander Gallo Compasy
+Toll Free: 800.211.3376
+Suite 1300
+
+
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+l. Have you been to your brother's house
+in Palm Beach?
+A. When.
+e. Ever?
+A. Yes.
+e. How many occasions?
+A. Probably dozens.
+I. When is the last time you were there?
+A. Probably about a decade ago. I was
+outside once more recently than that.
+During one of the hurricanes, he
+asked me to take a look at the property, but I
+did not go in.
+e. Why not?
+A. There was no inside damage. I went
+to see the property just to see if there was
+damage to the property. I was in Florida at
+the time.
+2. Why has it been more than 10 years
+since you've been to that property?
+A. My brother and I are not very close.
+2. What is the reason why you are not
+very close?
+A. We just went our own ways.
+an Alezander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+26
+1
+2
+3
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+e. Does it have to do with the fact that
+he likes under-age girls and engages in that
+type of illegal activity?
+MR. COHEN: Objection.
+MR. CRITTON: Form.
+A. I'm not going to make that
+assumption, but it has nothing do with
+anything like that. We just went our own
+ways. Different interests, different things.
+e. Knowing your brother, if when your
+children are 13, 14 years old, would you let
+them alone with him?
+MR. COHEN: Objection.
+MR. CRITTON: Form.
+A. Yes, I would.
+e. Do you know anything about Jean Luc
+Brunel?
+A. I never heard the name before. You
+just mentioned it before.
+Q. Are you familiar with the modeling
+agency MC Squared?
+A. No.
+e. Do you know if your brother has any
+involvement with that modeling agency?
+an Alezander Gallo Company
+Toll Free: 800.211.337€
+Suite 1300
+
+
+27
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+A. NO.
+l. It goes back to you not being that
+close with your brother?
+A. We don't talk about business. He
+doesn't tell me about his business and I don't
+ask.
+e. Are you aware that your brother is
+friendly or friends with David Copperfield?
+A. No. The magician?
+e. Right.
+A. I have no idea, no.
+l. Do you know any common interest that
+he shares with David Copperfield?
+A. Magic?
+I have no idea.
+e. Does your brother do magic?
+A. I have no idea.
+MR. CRITTON: Form.
+l. There is evidence in this case that
+David Copperfield was at your brother's house
+on occasions with under-age girls.
+Were you ever there then?
+A. NO.
+MR. CRITTON: Form.
+an Alexander Galle Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+28
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+21
+22
+23
+24
+25
+M. Epstein
+l. There will also be evidence in this
+case that your brother and Jean Luc Brunel
+were involved sexually with minors in your
+brother's house.
+were you ever there then?
+MR. CRITTON: Form.
+A. No.
+When? When did this take place?
+Q. Any of the times that your brother
+and Jean Luc Brunel were in the same house.
+A. What time period is that?
+l. Between 2000 and 2005.
+A. I already told you I haven't been
+there for over a decade. So use your fucking
+head and realize that I wasn't there.
+Next question.
+e. When was the last time you were in
+the New York house?
+A. When my mother was still alive. So
+it's got to be over five years ago, I think.
+l. All right. I'm going to go back to a
+time that you are more familiar with your
+brother.
+where did you grow up?
+an Alexacder Galle Company
+Toll Free: 800.211.3376
+Suite 1300
+www.esquiresolutlons.com
+
+
+29
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+A. Coney Island, Seagate, in Brooklyn.
+e. And did you go to the same school as
+your brother then?
+A. Yes.
+Q. What schools were those?
+A. P.S. 188 for elementary school, Mark
+Iwain Junior High School and Lafayette High
+School.
+l. And at Lafayette High School, were
+you familiar with any of your brother's
+girlfriends?
+A. Probably. I don't remember who they
+were. I don't remember my own girlfriends
+from high school.
+l. Did your brother ever have boyfriends
+at that age?
+MR. CRITTON: Form.
+A. What do you mean by boyfriends? You
+mean friends that were boys?
+Q. No, I mean was he sexually involved
+with boys in high school?
+A. No, not that I know of.
+MR. COHEN: Objection.
+MR. CRITTON: Form.
+ander Galls Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+30
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+l. Do you know of your brother to engage
+in homosexual sex?
+A. No, I don't.
+MR. CRITTON: Form.
+MR. COHEN: Objection.
+e. Do you know Leslie Wexner?
+A. I never met him, but I knew of him.
+e. How do you know him?
+A. He is a public figure. He owns The
+Limited.
+l. Have you ever been told that your
+brother and Leslie Wexner have a long time
+sexual relationship?
+MR. CRITTON: Form.
+A. No.
+MR. COHEN: Same objection.
+I. That's not something your brother's
+ever told you?
+MR. CRITTON: Form.
+A.
+No.
+l. I know you said that you and your
+brother don't talk about business much.
+Do you talk about his girlfriends,
+boyfriends, sex life, anything like that?
+an Alexander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+31
+1
+2
+3
+4
+M. Epstein
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A. No.
+l. Have you ever worked with your
+brother?
+A. No.
+l. After high school, where did your
+brother go?
+A. Io school, you mean?
+e. Sure.
+A. Cooper Union.
+l. And do you know what he studied
+there?
+A. He majored in physics, I think.
+l. Did he graduate?
+A. NO. No.
+l. After Cooper Union, where did he go?
+A. NYU, The Courant Institute. It's the
+math graduate program there.
+e. Do you know what he studied there?
+A. It's the math graduate program there.
+He studied mathematics.
+l. Did he graduate from NYU?
+A. Not that I know of.
+e. Do you know where he went after NYU?
+A. Home.
+in Alexander Gallo Company
+Toll Free: 800.211.337
+acsimile: 954.331.441
+
+
+32
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+e. For how long?
+A. What do you mean where did he go
+after? I don't understand your question.
+e. Did he go to work? Did he stay in
+school; masters, doctorate program?
+A. He went to work.
+e. Where did he go to work?
+A. He started teaching, I don't know if
+it was immediately after, but I know he was
+teaching for a while.
+e. Where did he teach?
+A. Dalton.
+Q. Was that a high school?
+A. I'm not sure what year it starts. It
+might be K through 12. I don't know what
+Dalton is.
+l. By this point in time in your
+brother's life, your life, were you already
+going your separate ways or were you still --
+A. No, we were still close then.
+e. You were close with your brother
+through high school and at least up to the
+point we are now at when your brother left NYU
+and he started working at Dalton?
+an Alezander Callo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+33
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+M. Epstein
+24
+25
+A. Yes.
+9. What was he doing in terms of at
+Dalton, was he a math teacher, a piano
+teacher?
+A. Math teacher, I believe.
+l. Did you ever know him to teach piano?
+A. No. At Dalton?
+Q. Right.
+A. I don't know.
+e. Okay.
+A. He plays very well. I don't know if
+he taught it.
+l. See we can only go off of what we
+read in the papers too.
+A. Okay.
+Q. How long was he at Dalton, to your
+knowledge?
+A. A couple of years or so. I don't
+know.
+l. All right. And what was his next
+employment after Dalton?
+A. I think he went to Bear Stearns.
+e. Do you know how he got that job at
+Bear Stearns?
+a= Alexander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+34
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+A. Yeah. He met, what's his name? Ace
+Greenberg, who was, I think the number 2 guy
+at Bear Stearns at the time.
+And my brother was hired to help them
+set up their options departments. They were
+just getting involved with options, as far as
+I remember.
+l. All right. How long was he at Bear
+Stearns?
+A. A few years.
+l. What year did your brother graduate
+high school?
+A. I got out in '71, so I guess he got
+out in '69, I think.
+e. From Lafayette?
+A. Yes.
+e. Do you know what year it was that he
+first started at Bear Stearns?
+A. Somewhere around '76.
+Q. Do you know why it is he left Bear
+Stearns?
+A. No.
+Q. Did you talk to him much while he was
+at Bear Stearns? Were you still close then?
+Toll Free: 800.211.3376
+an Alexander Galla Company
+
+
+35
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+A. Pretty much, yes.
+l. And, I'm sorry, did you know what
+year he left Bear Stearns?
+A. No. Around what year he left? No.
+l. Do you know about how long he worked
+there, five years?
+A. A few years is the closest I can tell
+you.
+Q. I know you told us what he did when
+he started. Do you know what he was doing
+when he finished?
+A. No.
+e. Were you aware of any problems that
+he had at Bear Stearns?
+A. NO.
+l. Were you aware of any insider-trading
+investigation involving -- or where your
+brother was a witness at Bear Stearns?
+A. NO.
+l. And do you know why it is that your
+brother left Bear Stearns?
+A. No.
+e. Do you know where he went to work
+after he left Bear Stearns?
+an Alexander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+Fort Lauderdale, FL 3330
+ww.esquiresolutions.con
+
+
+36
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+A. I know for a while he was working on
+his own going after insider-trading, and also
+recouping money for people.
+l. Okay. What does that mean? Just
+elaborate?
+A. Well, there were people who got burnt
+by brokers who were doing -- there were a lot
+of insider-trading things going on. And a lot
+of investors got burnt.
+And my brother was working with an
+attorney, and they were going after the
+brokers and trying to recoup money for the
+investors that got burnt.
+l. Was he also working for the federal
+government to recover money for the government
+as well?
+A. I have no idea.
+Q. He never told you that?
+A. No.
+e. Do you know what companies he was
+working for to recover money?
+A. I think he was working for himself.
+2. Do you know what the company was
+called?
+an Alezaader Callo Company
+Facsinie: 954-311.4378
+Suite 1300
+
+
+37
+1
+2
+3
+4
+5
+6
+M. Epstein
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A. No.
+e. Do you know how long he had that
+company open?
+A. NO.
+l. Was it a successful company?
+A. I think so.
+e. Where is the next place he went?
+A. I don't know if he ever worked for
+anybody else except for himself after that.
+l. All right. What is the next endeavor
+that he pursued then?
+A. He was just -- had the company he
+had, I guess. Managing money, as far as I
+know.
+e. Okay. But managing money is
+something different than being a money bounty
+hunter?
+A. Well, after the bounty hunter he was
+working managing money for people. That's
+all.
+e. Do you know how he started that
+company?
+A. No, I don't.
+e. Were you still close with him then?
+as Alexander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+38
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+A. Not as, but we were still kind of
+close. We didn't talk business. I had my
+businesses, which kept me very busy, and he
+had his.
+And when we'd talk, a lot of our
+conversations had to do with our parents. We
+had our own group of friends. He lived
+uptown, I lived downtown. Different worlds.
+Q. At this point in time he was still
+living in New York?
+A. Yes, or he might have had a Florida
+house then, I'm not sure if he did at that
+point. I don't remember when he first got
+that place, but he's had it for a while.
+l. That's the house at 358 Old Brillo
+Way in West Palm Beach?
+A. I don't know the number, but it's old
+Brillo.
+l. The same house in West Palm Beach,
+that's the house we are talking about?
+A. I believe so.
+Q. Has your brother ever discussed
+working for the government, either back in the
+Bear Stearns days, afterwards, up through the
+aa Alexander Callo Company
+Facile: 954311-378
+Suite 1300
+
+
+39
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+present?
+A. Not to me.
+e. Has he ever indicated to you that he
+was to be a confidential informant for the
+government?
+A. No.
+l. When is the first time that you
+remember your brother having some sort of an
+affiliation with Leslie Wexner?
+A. It's a while ago. I'm not sure
+exactly when, but at least 10 -- I'm trying to
+think where I was in my life.
+I don't know, maybe 20 years ago. I
+don't know how long he has been working with
+him, but he has been working with him for a
+while.
+e. Do you know where they met?
+A. No.
+e. Do you know what brought them
+together?
+A. Somebody introduced them. Somebody
+introduced them, somebody who was in the
+insurance business.
+e. Do you remember who that was?
+an Alexander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+40
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+A. NO.
+e. And what was your understanding of
+the relationship between your brother and
+Leslie Wexner?
+A. He manages money.
+l. As far as you knew, that's all that
+there was?
+A. Yes.
+l. Do you remember at any point in time
+your brother being sexually abused when he was
+younger?
+A. No.
+e. Would you know it if it happened?
+A. By who?
+e. Anybody.
+A. No. When we were kids I would have
+probably known about it.
+l. Do you know of him ever seeing a
+psychologist in his lifetime?
+A. No.
+I. So even through today's date, to the
+best of your knowledge, he hasn't seen one?
+A. I don't know.
+2. When did you first learn that your
+an Alesander Gallo Company
+oll Free: 800.211.337
+acsimile: 954.331.441
+Suite 1300
+
+
+41
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+brother, as an adult, was sexually attracted
+to young girls?
+MR. COHEN: objection.
+A. I didn't learn that. I mean, I saw
+it in the newspapers, but that's newspapers.
+I never heard anything directly I didn't know.
+Q. The first time you ever knew it was
+the same way that we learned it, was through
+the newspapers?
+A. Yes.
+l. Once he started working for Bear
+Stearns, did you hang out with your brother on
+a personal level?
+A. Not very often.
+THE WITNESS: Excuse me, one second.
+(Brief pause.)
+THE WITNESS: Sorry.
+BY MR. EDWARDS:
+e. Has anyone ever asked you about his
+attraction to young girls?
+A. No. People made comments about the
+newspaper articles what they were hearing, but
+they didn't ask me. It was just more of
+letting me know that they knew what was going
+1= Alexander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+42
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+on.
+e. Who would that have been?
+A. Friends, mutual acquaintances, people
+I knew. People started E-mailing me telling
+me my brother was in the newspaper. So I got,
+you know --
+e. When was that?
+A. Whenever the articles starting coming
+in.
+l. But there were articles on your
+brother that precede the criminal
+investigation. And there are people that knew
+your brother and saw him around town prior to
+that investigation.
+Anybody tell you about his attraction
+to young girls back then or ask you about it?
+A. No. Most people that we know know
+that we are not that close and they don't talk
+to me about him and, you know, the only people
+that we know together are really people from
+the old days.
+l. okay. So is this really -- other
+than newspaper articles, this deposition, as
+we sit here today and my previous statements
+in Alesaader Galla Company
+Toll Free: 800.211.3376
+Suite 1300
+Fort Lauderdale, FL 3330
+ww.esquiresolutions.cor
+
+
+43
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+that he engaged in sex with under-age girls,
+is the first you are hearing of it?
+A. Well, other than the newspaper
+articles?
+l. Right.
+A. Yes. I mean, I read some things in
+the papers about it. I don't understand your
+question.
+l. Has anybody else ever talked to you
+about, you know, your brother is engaging in
+sex with under-age girls or targeting young
+girls for sex?
+A. No.
+e. Do you now have any business
+relationship with your brother?
+A. No.
+l. Have you ever?
+A. What do you mean by business
+relationship?
+When we were kids we used to lend
+each other money. So I don't want to say no
+and get caught for saying something like that,
+but we are not in business together. Our
+names have never appeared on any business
+an Alezander Galla Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+44
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+document together.
+e. And why is that? Obviously your
+brother is very successful, so why would you
+not be associated with him?
+A. I made my own success.
+l. What is your brother's current net
+worth?
+A. I have no idea.
+l. Do you know approximately what it is?
+A. I don't know my net worth. I don't
+know his.
+l. What properties does he own that you
+know of?
+A. He has a house in Florida, a house in
+New York and a house in New Mexico.
+l. Have you been to the ranch in New
+Mexico?
+A. I was only at the property once,
+before he built anything. After he bought it,
+I was in New Mexico.
+Q. How long were you there?
+A. I was in New Mexico three or
+four days.
+Q. With your brother?
+*a Alexander Callo Compaay
+Toll Free: 800.211.3376
+Suite 1300
+
+
+45
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+A. NO.
+e. How many times have you been at his
+Florida house the same time he was there?
+A. Not in the last decade ever.
+l. Prior to the last decade, I think you
+told me a dozen times?
+A. 20 years ago, probably a couple dozen
+times.
+e. And how long would you stay? Would
+you ever stay there overnight?
+A. Yes. Years ago, I would maybe for a
+couple of days, for a weekend. I was working
+then, so I'd only have weekends.
+l. During that period of time, would he
+have girls coming over during the day?
+A. No, he had a girlfriend at the time
+most of the time.
+Q. Who was that?
+Early on there was this girl
+It was an old girlfriend.
+2. Do you know where she is now?
+A. In New York.
+Q. Do you know her address?
+A. She is Uptown on the east side
+* Alexander Gallo Cempany
+Toll Free: 800.211.3376
+Suite 1300
+
+
+46
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+somewhere.
+e. Do you know any of his other adult
+girlfriends?
+A. No. No.
+Well, I don't know how to
+characterize. I know some females that he
+knew from years back but, you know, I'm not
+sure if they were girlfriends. I don't know
+what their relationship was.
+l. Who are those people?
+A. Well, there was a (Glynn) Ghislaine
+Maxwell.
+l. How do you know Ghislaine Maxwell?
+A. I met her through my brother.
+Q. How many times have you been around
+or hung out with Ghislaine Maxwell?
+A. Maybe a dozen or so, but we met
+when -- about the time -- my father and her
+father died about the same time.
+My father died in 1991, so in that
+period of time almost 20 years ago, I used to
+see her more frequently.
+I. How frequently would you see her?
+A. Then?
+an Alexander Gallo Company
+Toll Free: 800.211.3376
+Facsimile: 954.331.4416
+Suite 1300
+
+
+47
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+l. Yes.
+A. Monthly.
+I. Would it always be with your brother?
+A. Yes.
+l. You met her through your brother?
+A. Yes.
+e. What was your understanding of the
+relationship between Ghislaine Maxwell and
+your brother?
+A. Well, they were friends, and she
+worked for him.
+l. Did she ever live with him?
+A. I don't know. I'm not sure. I think
+she always had her own place, so I don't know
+if she lived with him or not.
+e. When you say that she worked for him,
+what did she do for him?
+A. I know she helped take care of the
+properties, like hiring the household help.
+Q. Did you ever hear that she helped to
+bring young girls to him for sex?
+A. I read that somewhere in one of the
+articles.
+Q. Is that something, knowing Ghislaine
+an Alexander Gallo Company
+Toll Free: 800.211.337
+acsimile: 954.331.441
+Suite 1300
+
+
+48
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+Maxwell and knowing your brother, would that
+surprise you to hear that?
+MR. COHEN: Objection.
+A. I don't know Ghislaine Maxwell. I
+mean I know her, but you can tell me anything,
+it's not going to surprise me.
+e. When you would see your brother and
+Ghislaine Maxwell, where would you be; at his
+house, at a function, out to dinner?
+A. Probably at his house more than
+anything.
+e. Which house would that be?
+A. More likely Florida.
+e. Do you know how he met her?
+A. No.
+2. Do you know where she is now?
+A. No.
+e. When is the last time you saw
+Ghislaine Maxwell?
+A. Probably around when my mother died,
+that's five and a half years ago.
+l. Have you ever met Leslie Wexner?
+A. No.
+Q. Have you ever met Donald Trump?
+an Alexander Galle Compaay
+oll Free: 800.211.337
+acsimile: 954.331.441
+Suite 1300
+
+
+49
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+A. Yes.
+O. Was that through your brother?
+A. Yes.
+e. Where was that?
+A. We flew up on my brother's plane from
+Florida together. Donald was on the plane.
+e. When?
+A. Somewhere between 5 and 10 years ago.
+l. Okay. So we are talking about --
+A. It's either late '90's early 2000.
+Probably more like late '90's.
+l. Was that the only time you've met
+Donald Trump?
+A. Yes.
+l. Which plane was this of your
+brother's?
+A. I don't remember.
+l. Was this one of the big planes, the
+727?
+A. No. It wasn't that one, no.
+l. Okay. How many people were on this
+airplane?
+A. It was my brother, myself, Donald,
+the pilot the co-pilot. I don't remember -- I
+an Alexander Gallo Company
+Toll Free: 800.211.337
+acsimile: 954.331.4411
+Suite 1300
+
+
+50
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+don't remember if anybody else was on the
+plane.
+e. What was the purpose of Donald Trump
+riding on your brother's airplane?
+A. You'll have to ask Donald. I think
+he wanted a ride back to New York.
+0. What was your understanding of the
+relationship of Donald Trump and your brother?
+A. They were friends.
+Q. Do you know how they met?
+A. No.
+l. When you say "friends, " how
+frequently did they associate?
+A. I have no idea.
+Q. What was your understanding -- did
+you --
+A. I had no understanding. They were
+friends. That was my understanding.
+Q. When they were in the airplane
+together, they talked as if they were friends?
+A. Yeah, I talked to him like he was my
+friend. I never met the guy. I am a friendly
+guy.
+l. Were there girls on the plane?
+1= Alexander Gallo Corpaay
+Toll Free: 800.211.3376
+Suite 1300
+
+
+51
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+A. I don't remember who was on the
+plane. I don't remember if anybody else was
+on the plane.
+l. Do you know if the pilot was?
+A. Yeah. He had a pilot and a co-pilot
+for a long time. The co-pilot's name was
+Larry. And the pilot's name -- I have his
+picture in my face -- into my head, but I
+don't remember his name.
+l. Larry Kisofsky. Does that sound --
+A. I don't know his last name. His name
+is Larry.
+l. Is that somebody that still works for
+him?
+A. I have no idea.
+l. When did your brother get his first
+airplane?
+A. Probably around 1990.
+Somewhere
+around there, because he had it when my father
+was in the hospital in '91.
+e. You remember that?
+A. Yes.
+l. Was your father ever on his airplane?
+A. I don't remember.
+as Alexander Gallo Compasy
+Toll Free: 800.211.3376
+Suite 1300
+
+
+52
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+e. Okay. And how many times do you
+think that you've been on one of your
+brother's airplanes with your brother?
+A. Less than a dozen.
+Q. And any of the times that you were on
+the airplane, were there girls on the airplane
+with you?
+A. What do you mean girls? There were
+women on the plane.
+l. Okay. Ever any under-age girls?
+A. I don't think so.
+I. So they were young girls, you don't
+know if they were under-age?
+A. I'm not going to speculate on their
+ages.
+l. Did you know these girls, or were
+these girls that were familiar with your
+brother?
+A. I didn't know them. I mean, unless
+it was Ghislaine or Eva years ago, but
+otherwise I didn't know them.
+Q. But the specific girls I'm talking
+about are the girls you are not going to
+speculate on their age.
+an Alexasder Gallo Company
+Fact me: 854311-3316
+Suite 1300
+
+
+53
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+Were these girls your brother had on
+the plane because he knew them or did you know
+them, I guess that's my question?
+A. It wasn't me, no.
+No, once I flew down to Florida on
+his plane and I had a girlfriend with me, one
+of my girlfriends at the time.
+l. Did you ever know of any sex or sex
+acts to go on on the airplane with your
+brother?
+A. Not when I was there.
+e. When you would fly on his airplane,
+would this be from New York to Florida or vice
+versa?
+A. Yeah. And then there were a couple
+of times that I flew to or flew back to
+Cleveland. My father was in a Cleveland
+clinic for a few months, so I flew on the
+plane then.
+e. And do you know -- did you ever meet
+David Copperfield?
+A. NO.
+Q. Did you ever meet Alan Dershowitz?
+A. I might have met him once.
+is Alexander Galle Compasy
+Toll Free: 800.211.3376
+Facsimile: 954.331.441€
+Suite 1300
+
+
+54
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+e. Where would that have been?
+A. In Florida.
+Q. What was the occasion?
+A. I went to Jeff's house for something,
+and I think Alan was there and I think he
+introduced us.
+Q. How long ago was that?
+A. A long time ago.
+l. '90's?
+A. It would have to be.
+Q. Have you ever met Bill Clinton?
+A. Yes.
+e. Through your brother?
+A. NO.
+2. Have you ever been with your brother
+at a time when Bill Clinton was also around?
+A. I don't understand your question.
+l. Did you ever go to your brother's
+house when Bill Clinton was also there?
+A. NO.
+l. Have you ever been on your brother's
+airplane with Bill Clinton?
+A. NO.
+e. Have you ever known Bill Clinton to
+an Alesaader Callo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+55
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+fly on your brother's airplane?
+A. I read that he went to Africa on his
+plane.
+l. Did you know of him to fly on your
+brother's airplane on any occasions other than
+when they went to Africa?
+A. No.
+l. Have you ever met Kevin Spacey?
+A. No.
+l. Chris Tucker?
+A. No.
+Q. Do you know what your brother's
+relationship is with Bill Clinton?
+A. He knew him, he flew him to Africa.
+I don't know how he met him. I don't know
+what their relationship is.
+Q. Other than the flight to Africa, has
+your brother ever talked to you about his
+relationship with Bill Clinton?
+A.
+He mentioned they were somewhere
+once, it might have been in Europe. And I
+think he mentioned something about Bill
+Clinton. I'm not sure, but I think there was
+someplace that he was and Clinton was there,
+an Alexander Galle Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+56
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+and he mentioned that he was there and Clinton
+was there, but...
+e. Has he ever mentioned to you that he
+provided girls to Bill Clinton?
+A. NO.
+l. Have you ever met Prince Andrew?
+A. No.
+e. Has your brother ever discussed his
+relationship with Prince Andrew?
+A. I know he knew him, or he saw him.
+That's all.
+2. What is your understanding as to how
+your brother made his money?
+A. I don't have an understanding of it.
+l. He's never talked to you about that?
+A. No. He is an investor. He invested
+things. As far as I know, he invested money.
+Q. Do you know who his clients are?
+A. Other than Wexner, no.
+e. Do you believe he has any other
+clients other than Wexner?
+A. I have no idea. I never questioned
+it.
+Q. How do you know Wexner was his
+at Alexander Gallo Company
+Facile: 954-211-376
+Suite 1300
+
+
+57
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+client?
+A. Wexner was his client really early
+on. He told me about it.
+l. Was Wexner his only client that he
+ever talked about?
+A. Again, we don't talk business. I
+didn't tell him about many of my clients
+either.
+l. Is it your understanding that Leslie
+Wexner is no longer your brother's client?
+A. I have no idea.
+e. Do you know how your brother's
+business is doing now?
+A. I have no idea.
+l. When you call Florida to make sure he
+is doing all right, isn't one of the main
+things your brother does is business; and
+aren't you asking essentially, is your
+business doing all right?
+A. No, I'm asking him how his health is.
+l. So he responds that his health is
+fine, and that's basically the end of the
+telephone call?
+A. Yeah, or we'll tell each other a
+1a Alexander Galle Company
+Toll Free: 800.211.3376
+Sulte 1300
+
+
+58
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+M. Epstein
+funny story about something, about some
+friends or whatever.
+e. Do you know who his closest friends
+are these days?
+A. No.
+l. Do you know of any friends of your
+brother's who are not also on your brother's
+payroll?
+A. I don't know his friends.
+l. Do you know who his assistants are
+these days?
+A. No.
+l. Is
+, does she still work
+for him?
+A. I have no idea.
+e. When is the last time you saw
+21
+22
+23
+24
+25
+A. I don't think I saw
+If
+I met her, it was a few years ago.
+Q. Where would that have been?
+A. Maybe 301.
+l. And how many occasions have you ever
+seen
+?
+A. Once or twice. I once saw her in the
+aa Alexander Calle Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+59
+1
+2
+3
+4
+5
+6
+M. Epstein
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+elevator of 301.
+e. Other than at 301, have you seen
+anywhere else?
+A. No.
+e. Do you know of
+relationship
+with your brother?
+A. No.
+l. I know I asked you about Jean Luc
+Brunel, I don't remember did I ask you whether
+you are familiar with the modeling company MC
+Squared?
+A. Yes, you did.
+MR. COHEN: You did.
+l. Are you familiar with the modeling
+company Karin Models?
+A. No.
+l. Have you ever attempted to ascertain
+who is staying in the various apartments that
+your brother rents at 301?
+A. No.
+e. Are they usually occupied?
+A. I have no idea.
+Q. What is your obligation to that
+property? What do you do?
+an Alezander Gallo Company
+Toll Free: 800.211.337
+Facsimile: 954.331.441
+
+
+60
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+M. Epstein
+21
+22
+23
+24
+25
+A. Nothing.
+l. What does your company do for that
+property?
+A. We own most of it and manage it.
+l. Well, in managing it, what does that
+entail?
+A. Leasing out spaces, paying the bills.
+l. Something breaks, you fix it?
+A. Well, we have staff there that takes
+care of that, yes.
+Q. Who would the staff member be that
+would --
+A. A guy named Andy is the head super.
+e. Andy who?
+A. I don't know his last name.
+2. This is the head supervisor for your
+company?
+A. For that building. He is the
+superintendent for that building.
+Q.
+Have you ever had that position of
+superintendent for that building?
+A. No.
+Q. Ever owned real estate with your
+brother?
+an Alexander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+61
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+A. No.
+e. Do you know of the name
+A. No.
+e.
+A. No.
+l. Did you talk to your brother about
+the criminal investigation when it began?
+MR. COHEN: Objection.
+Asked and answered.
+A. No.
+l. I know you call now to check on his
+health. Did it concern you that he was being
+criminally investigated?
+MR. COHEN: Objection.
+A. Well, it concerned me, he is my
+brother.
+l. So why is it you didn't have that
+conversation with him?
+A. If there was something he wanted to
+tell me, he would have told me.
+Q. And that's not something he ever
+talked to you about?
+A. Right.
+an Alexander Galle Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+62
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+e. And even though the allegations --
+you are familiar with the allegations; right?
+A. Some, I guess.
+e. The allegations are that he was
+engaging in sex with under-age girls.
+That's not something that you wanted
+to take upon yourself to talk to your brother
+about?
+A. No.
+l. It's not something that really
+bothers you?
+A. NO --
+MR. COHEN: Objection.
+A. -- no more than anybody else being
+accused of that.
+l. If you found that to be true,
+hypothetically, you find that it's true that
+your brother is engaging in sex with
+under-aged girls; 13, 14, 15-year old girls,
+is that something that you would discuss with
+him?
+MR. COHEN: Objection.
+A. I'll use one of my mother's lines,
+I'll worry about that when the time comes.
+in Altzaader Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+63
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+l. You realize that he has plead guilty
+to that; right?
+A. Yes.
+Q. So hasn't the time come?
+A. No, not for me. I know it was a plea
+deal, so I don't know the details.
+Like I said, he pled guilty to some
+prostitution charge. So you are representing
+a bunch of prostitutes if I just go by what
+the law says. So, you know, I don't pay
+attention to that.
+l. If the evidence in this case are that
+these girls are in middle school and high
+school, some of them are virgins and none of
+them have engaged in prostitution prior to
+meeting your brother, does that change?
+A. Your question started with an "if."
+I'm not going to speculate on anything.
+MR. COHEN: Mr. Edwards, can we take
+a short bathroom break?
+MR. EDWARDS: Sure.
+THE VIDEOGRAPHER: 12:33, off the
+record.
+(Discussion held off the record.)
+an Alexaader Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+64
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+MR. COHEN: Let's go back on the
+record. Are all counsel who appeared by phone
+on the phone now?
+THE WITNESS: If anybody's not do
+speak up. Should we do another roll call?
+MR. CRITTON: This is Bob Critton.
+Let me just put on the record, I recognized
+about just before we took the break I must
+have bumped my microphone.
+So when I've been inserting
+objections, and based on what the court
+reporter indicated, she hadn't heard me for
+about 30 or 35 minutes.
+I just want to assert, any question
+that had either a leading, isn't it true, or a
+suggestion that Mr. Jeffrey Epstein had some
+sexual contact or contact with under-age
+girls, I would have objected to.
+I did object to, apparently it didn't
+come through; any leading guess, any questions
+for which there was no predicate, I have no
+objection to the actual questions with regard
+to who was on the plane, or if he saw his
+brother, what the discussions they had, but
+an Alexander Gallo Company
+oll Free: 800.211.337
+acsimile: 954.331.441
+
+
+65
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+any other questions to suggest the answer or
+leading question, I would reserve that
+objection on form.
+MR. EDWARDS: Okay.
+MR. CRITTON: My microphone's on now.
+You'll have to hear me.
+MR. EDWARDS: That's unfortunate.
+MR. CRITTON: Thank you for your warm
+reception.
+THE VIDEOGRAPHER: It's 12:40.
+On the record.
+BY MR. EDWARDS:
+l. When you were at your brother's house
+in Palm Beach, I know you said it was 10 years
+ago, how many computers would you estimate
+were in the house?
+A. I have no idea.
+l. Did he ever talk to you after the
+criminal investigation about the computer
+evidence that there is in this case?
+A. NO.
+l. Did you ever go visit your brother
+when he was in jail?
+A. NO.
+ander Callo Campasy
+Toll Free: 800.211.3376
+Suite 1300
+
+
+66
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+e. Why not?
+A. I did not.
+l. I'm sorry, I didn't hear you?
+A. I did not go.
+l. Right. Why wouldn't you go visit
+your brother in jail?
+A. Timing, part of it. I have my own
+life up in New York. We'd speak occasionally,
+I knew he was okay. I don't see him that much
+when he was in New York, so...
+e. Okay. What was done with the
+computers in your parents' house when your
+parents passed away?
+A. My mother had a computer. I think I
+took it for my kids.
+l. Is that a computer that your brother
+ever worked on or used?
+A. I doubt it.
+l. Did you ever know your brother to
+share images by way of computers of under-age
+girls or young looking girls?
+MR. CRITTON: Form.
+A. He rarely E-mailed, so I don't even
+know if he had any use for computers.
+an Alexaader Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+67
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+l. What was his E-mail address, or what
+is his E-mail address?
+MR. CRITTON: Form.
+A. I don't know it by heart.
+2. Do you know who the server is,
+Hotmail, Gmail?
+A. No.
+e. AOL?
+A. No, I don't know it by heart.
+l. When you say he rarely E-mails --
+A. Well, then. Then, I used to never
+get E-mails from him, but more recently I got
+a couple, some, but there is not a lot of
+E-mail communication back and forth.
+l. Okay. In the last year and a half,
+how many E-mails have you received from your
+brother?
+A. I just had a spate of them, half a
+dozen or a dozen or so, because there is a
+reunion coming up for all the old Coney Island
+kids, so we've been talking about that.
+Q. Is your brother planning on
+attending?
+A. I don't think so.
+an Alesander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+68
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+l. When is it?
+A. In October.
+e. So what has been the substance of the
+conversation if your brother's not planning on
+coming?
+A. Who is going, that kind of stuff.
+And just some funny pictures that came up on
+some of our old friends and what they 1o0k
+like today. It's kind of comical.
+l. Do you know where your brother is
+working right now?
+A. NO.
+l. Have you heard of the Florida Science
+Foundation?
+A. Yes.
+l. What is it?
+A. I have no idea.
+2. How have you heard of it?
+A. That is where he was working on his
+work release.
+Q. How do you know that?
+A. He called me and I called there, and
+when they answered the phone they said Florida
+Science Foundation.
+an Alesander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+69
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+l. Did you ever ask him what the Florida
+Science Foundation does?
+A. NO.
+l. Have you known your brother to be
+into science?
+A. Yes, very much.
+l. Since when?
+A. His whole life.
+Q. How many times have you talked to him
+since he was arrested?
+A. When was he arrested?
+l. Back in 2005, 2006?
+A. Altogether, a couple of dozen times.
+l. And what is the substance of that
+conversation, other than you asking if he is
+in good health?
+A. About friends, family stuff.
+l. When is the first time that you know
+of your brother targeting young girls --
+A. I don't know that.
+l. -- For sex?
+MR. COHEN: Objection.
+MR. CRITTON: Form, last question.
+MR. COHEN: Also asked and answered.
+ander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+70
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+21
+22
+23
+24
+25
+M. Epstein
+MR. CRITTON: About three times.
+l. Have you known of your brother ever
+hiring prostitutes?
+A. No.
+l. Has your brother ever discussed with
+you the manner in which he lures 13 or 14 or
+15-year old kids to the house?
+MR. CRITTON: Form.
+MR. COHEN: Objection.
+A. Yes. I'm not going to answer that
+question. It's a leading question.
+l. Well, I'm asking you an open
+question. Has he ever talked to you about the
+manner --
+A. That is assuming he does it. I'm not
+assuming he does anything. We don't talk
+about girls. We don't talk about young girls.
+MR. CRITTON: Objection to the last
+question.
+Q. On several occasions during this
+deposition you've referred to these girls as
+prostitutes.
+Do you know any of them?
+A. No.
+in Alesander Callo Company
+Toll Free: 800.211.337€
+Suite 1300
+
+
+71
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+21
+22
+23
+24
+25
+M. Epstein
+l. Do you know their parents?
+A. No.
+e. Do you know who they were before they
+met your brother?
+A. Not a clue.
+l. Do you know what your brother did
+with them?
+A. No.
+e. Do you know who they are today?
+A. No.
+Q. So why is it that you call all of
+these girls prostitutes?
+A. Well, I said some of them. I mean
+the charge he pled guilty to, from what I
+understand, is something to do with
+prostitution.
+So if these are the girls involved in
+that, that by definition makes them
+prostitutes. The way I -- that, to me, is
+English.
+l. So the basis for you referring to
+these girls as prostitutes, is that your
+brother pled guilty to a prostitution charge?
+A. Yeah. What else do I have to go by?
+an Alexander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+72
+M. Epstein
+I mean, you usually don't get charged for
+prostitution unless there is a prostitute.
+MR. COHEN: Let him ask the question.
+e. Okay, but these are young girls that
+you are calling prostitutes that you don't
+know their family; right?
+A. I have no idea. I've already
+answered that.
+MR. CRITTON: Form.
+You asked him to speculate and now
+you are going after him.
+I think that is inappropriate.
+l. In the conversations that you've had
+with your brother since his arrest, has he
+ever expressed to you the least bit of remorse
+for anything that he has done?
+MR. CRITTON: Form. Predicate.
+A. We didn't talk about what he's done.
+Q. So then the answer is no then; right?
+MR. CRITTON: Form.
+MR. COHEN: Same objection.
+A. The answer to what I said is no, the
+way I put it.
+MR. EDWARDS: I don't have anything
+Toll Free: 800.211.337
+acsimile: 954.331.441
+an Alexander Gallo Company
+
+
+73
+1
+2
+3
+M. Epstein
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+23
+24
+25
+right now.
+Anybody else?
+MR. COHEN: Okay. It sounds like no
+one has any questions.
+MR. LANGINO: Yeah, we have
+questions. I don't know who comes next.
+MS. EZELL: Go ahead, Richard.
+MR. COHEN: Sir, can you identify
+yourself?
+MR. WILLITS: Okay. Richard Willits
+here. I'm going to ask a few questions.
+EXAMINATION BY
+MR. WILLITS:
+l. Mr. Epstein, approximately when were
+you served with a subpoena?
+A. A couple of weeks ago. I think it
+was -- no, a few weeks ago. I don't remember.
+l. Since you -- at the time you got
+served with a subpoena, did you have any
+discussions with your brother about your
+upcoming deposition?
+A. No, I told him I was served with a
+subpoena.
+e. And what did he tell you?
+an Alezander Callo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+74
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+A. He said he is sorry that I had to get
+dragged into this.
+e. Did you have any other discussions
+about the deposition?
+A. No.
+e. Do you have a lawyer there
+representing you today?
+A. Yes.
+Q. Are you paying for that lawyer?
+A. Is this pertinent?
+MR. COHEN: You can answer. It's
+okay.
+THE WITNESS: What was your question?
+l. Are you personally paying for the
+lawyer who is there representing you today?
+A. No.
+e. Who is paying?
+A. Jeffrey.
+MR. WILLITS: I don't have any other
+questions.
+THE COURT REPORTER: Who is next?
+Identify yourself, please?
+MS. EZELL: I have just a couple of
+questions, Mr. Epstein.
+an Alexander Gallo Congaay
+Toll Free: 800.211.337€
+Suite 1300
+
+
+75
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+THE WITNESS: Go ahead.
+EXAMINATION BY
+MS. EZELL:
+l. -- And in New York, and I didn't
+quite catch the address?
+A. I'm sorry, you were breaking up.
+Could you repeat the question?
+Q. I'm going to ask you about the
+apartment building in New York where you said
+your ex-wife lives.
+A. Yeah.
+l. I didn't catch the name of the
+partnership that owns that?
+A. D-a-r-a, Dara.
+Q. And you are a partner in that?
+A. Yes.
+l. Jeffrey Epstein?
+A. Excuse me?
+l. Jeffrey Epstein is also a partner in
+that?
+A. NO.
+e. Do you --
+MR. EDWARDS: Kathy, we can't hear
+you.
+Toll Free: 800.211.3376
+is Alexander Gallo Company
+
+
+76
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+MS. EZELL: Can you hear me now?
+MR. COHEN: You just faded back in.
+BY MS. EZELL:
+l. Your brother has the capacity to make
+people believe that he is interested in them?
+MR. COHEN: Can we have the question
+again?
+THE WITNESS: I didn't get that.
+MR. COHEN: I'm sorry, could you
+repeat that, you were fading in and out?
+BY MS. EZELL:
+e. Do you agree that your brother has a
+rather extraordinary capacity to make people
+believe that he is interested in them and
+their well-being?
+MR. COHEN: Objection.
+MR. CRITTON: Form.
+A. I have no idea.
+e. You've known your brother, have
+you -- people --
+MR. COHEN: I'm sorry, you faded out
+again.
+MR. EDWARDS: Kathy, we are only
+catching every second or third word. You may
+1a Alesander Callo Compasy
+Facile: 954-31-378
+Suite 1300
+
+
+77
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+want to pick up your receiver.
+MS. EZELL: Thank you.
+I can do
+that. Is this better?
+MR. COHEN: Much better.
+THE WITNESS: Much better.
+BY MS. EZELL:
+l. Okay, sorry.
+In all the years you've known your
+brother, have you known him to be a master
+manipulator?
+MR. COHEN: Objection.
+MR. CRITTON: Form.
+A. No. I mean, I don't know what you
+mean by that.
+Q. Have you known him to be very good at
+manipulating people to get them to do what he
+wants?
+A. I have no idea.
+MR. COHEN: Objection.
+MR. CRITTON: Form.
+e. You have no idea, was that your
+answer?
+A. Yes. I have no idea.
+I don't see
+him with many people.
+an Alexander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+78
+1
+2
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+M. Epstein
+l. Did he have that capacity when you
+were growing up?
+MR. COHEN: Objection.
+MR. CRITTON: Form.
+A. I don't know what -- I don't know how
+to answer that question.
+e. When you were growing up, did you
+notice that he developed the capacity to deal
+with people in a way that made them think he
+was very interested in their welfare?
+MR. COHEN: Objection.
+MR. CRITTON: Form.
+MS. EZELL: I couldn't hear the
+21
+22
+23
+24
+25
+answer.
+A. The answer is, I don't know what you
+are talking about. We grew up. We were kids
+growing up in Brooklyn, you know.
+Capacity? He had a good capacity for
+mathematics, I can say that.
+Q. Right.
+Right. So I'm asking you if
+he had a good capacity for dealing with
+people?
+MR. COHEN: Objection.
+MR. CRITTON: Form.
+Toll Free: 800.211.3376
+an Alesasder Callo Cempany
+
+
+79
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+A. I have no idea. I don't know what --
+how do you define a good capacity for dealing
+with people?
+People didn't walk around punching
+him in the face, so I guess he dealt with them
+okay.
+e. Okay. When you were boys together,
+could he talk other boys into doing things?
+Was he a leader?
+MR. COHEN: Objection.
+A. I have no idea.
+How far back in history am I supposed
+to be going with this?
+These are stupid questions.
+MR. COHEN: I know they are, but we
+are almost done.
+l. Are you saying you can't answer those
+questions?
+MR. COHEN: He has answered them.
+Move on, counsel.
+MS. EZELL: I don't have any others,
+but I didn't hear him answer those questions.
+MR. COHEN: Would you like the
+record read back or would you like to read it
+an Alezander Galle Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+80
+M. Epstein
+when you get it?
+Thank you.
+MS. EZELD: I got what he said.
+MR. COHEN: Anyone else?
+MR. LANGINO: Yes.
+This is Adam Langino, and I represent
+THE WITNESS:
+MR. COHEN:
+THE WITNESS: I thought he said
+and it was a dog.
+MR. COHEN: No, they are using
+letters.
+MR. LANGINO: Everybody can hear me
+okay?
+MR. EDWARDS: Yes.
+MR. COHEN: Yes.
+MR. EDWARDS: Got you.
+MR. COHEN: You are coming through
+fine.
+EXAMINATION BY
+MR. LANGINO:
+l. Was Jeffrey Epstein close to his
+father?
+an Alesander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+81
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+A. Yes.
+l. Did you notice any changes in Jeffrey
+Epstein after he started a relationship with
+Ms. Maxwell?
+MR. CRITTON: Form.
+A. I didn't spend a lot of time with
+him -- too much time with him. I don't know
+what you are talking about.
+l. Do you have an opinion if Jeffrey
+Epstein changed at all once he started a
+relationship with Ms. Maxwell?
+MR. COHEN: Objection.
+A. I have no idea.
+Changed in what way?
+l. I could not hear that last response.
+Excuse me?
+A. Changed in what way?
+I don't understand your question.
+Q. Well, you know Jeffrey Epstein better
+than I do. So my question is --
+A. Maybe. I don't know how well you
+know him. I think there are people who know
+him better than I do, so you could be one of
+them.
+aa Alexander Gallo Compasy
+Toll Free: 800.211.3376
+Suite 1300
+
+
+82
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+e. Okay. The question is once he
+started a relationship with Ms. Maxwell, dia
+you notice a change in him?
+Was he more agitated? Was he
+happier? Was he sadder?
+Did you notice any type of emotional
+change in your brother once he started a
+relationship with Ms. Maxwell?
+A. I can't connect anything to that, no.
+e. Do you have an opinion of Ms.
+Maxwel1?
+MR. COHEN: Objection.
+MR. CRITTON: Form.
+A. I had very little dealings with her.
+l. So what is your answer?
+A. I don't have an opinion of her.
+l. All right. And who is your brother's
+best friend?
+A. I already answered.
+Q. I didn't hear it?
+A. I have no idea.
+Q. Okay. Can you give me the name of
+one of his close friends?
+A. I have no idea.
+an Alezander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+83
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+e. Can you give me a name of one his
+close friends from Coney Island where you guys
+grew up?
+A. There is a Warren.
+e. Warren what?
+A. Eisenstein.
+e. Do you know his address?
+A. NO.
+Q. Do you know his telephone number?
+A. No.
+Q. Do you know if he still lives in New
+York?
+A. No, he lives out of state.
+e. Do you know which state?
+A. Texas.
+e. Texas?
+A. Yes.
+e. Do you know which city in Texas?
+A. Dallas or Houston, one of the big
+ones. I'm not sure.
+Q. Do you know his date of birth?
+A. No.
+e. Okay. Thank you for your time. I
+have no further questions.
+a= Alexander Gallo Company
+Toll Free: 800.211.337
+acsimile: 954.331.441
+Suite 1300
+www.esquiresolutlons.com
+
+
+84
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+oh, sorry, can you spell his last
+name, I didn't catch that, the friend's last
+name?
+A. It's Eisenstein.
+e. Can you spell it?
+A. NO.
+2. Did you and Mr. Eisenstein go to the
+same primary school?
+A. I think he went to the same schools,
+yeah. He was my brother's age. I think he
+was in the same school.
+l. And which school was that once again?
+A. P.S. 188.
+e. And that is in Brooklyn?
+A. Yes.
+MR. LANGINO: All right. Thank you
+very much.
+MR. COHEN: Thank you.
+Anyone else?
+MR. HOROWITZ: Yes, this is Adam
+Horowitz. Just a few questions.
+Can you hear me okay?
+MR. COHEN:
+Yes, we hear you great.
+MR. HOROWITZ: Great.
+1a Alesander Gallo Company
+oll Free: 800.211.337
+acsimile: 954.331.441
+Suite 1300
+
+
+85
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+EXAMINATION BY
+MR. HOROWITZ:
+l. Mr. Epstein, any family members that
+you would say your brother Jeffrey is now
+close with?
+A. NO.
+e. Not a single family member that he is
+close with?
+A. No, we don't have a very big family.
+l. Other than yourself, who are the
+closest blood relatives?
+A. There are some cousins that are
+around.
+2. Any cousins that live in Florida?
+A. We do have a cousin in Florida, yes.
+e. Who is that?
+A. I'm not telling you my cousin's
+names. I'm not having you bother my cousins
+over this nonsense. They know less of this
+than I do.
+l. You are refusing to answer the
+question?
+A. Yes.
+l. And this is a first cousin of his?
+an Alesander Gallo Compasy
+Toll Free: 800.211.337
+acsimile: 954.331.4411
+Suite 1300
+
+
+86
+1
+2
+3
+4
+5
+6
+M. Epstein
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A. Yes.
+l. Where in Florida does he live?
+A. Next question.
+l. I'd like to get some background on
+this person that you are not going to give me
+the name of.
+Where does he or she live?
+A. Next question.
+l. Is it a male or female?
+A. Next question.
+Q. Mr. Epstein, to your knowledge, does
+your brother Jeff like getting massages?
+A. I have no idea.
+I think everybody likes getting
+massages.
+Q. How long have you known your brother
+to enjoy getting massages?
+MR. COHEN: Objection.
+A. I have no idea. I don't think about
+what he does.
+l. Has he ever talked to you about
+getting massages?
+A. No.
+2. Have you ever gotten a massage with
+#E Alesander Gallo Company
+Face mie: 954-31-3318
+Suite 1300
+
+
+87
+1
+2
+3
+M. Epstein
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+him?
+A. No.
+l. Have you ever seen him get a massage?
+A. Not that I remember.
+l. Does he ever complain about physical
+injuries for which he'd like to get a massage?
+A. No, we don't talk about that. No.
+l. Has he ever complained to you about
+back pain, shoulder pain?
+A. No.
+I don't complain about my back pain
+either, so I don't put much weight on that.
+l. Have you known of anyone to give him
+a massage?
+A. No. There was a girl years ago, but
+I'm talking 20 years ago, there was some woman
+that he used in Florida, I don't remember her
+name, but I know there was a woman who used to
+give him massages.
+l. Where would she go to give him
+massages?
+A. I believe to his home.
+e. She would come to his home about 20
+years ago?
+an Alezasder Gallo Company
+Toll Free: 800.211.3376
+
+
+88
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+A. I don't know. I don't remember.
+e. On the different occasions you've
+been to his home in Palm Beach, have you ever
+seen or known of him to receive a massage?
+A. Not that I remember, no.
+Q. What about on the different times
+that you've been on a plane with your brother
+Jeff, have you seen or known of him to get a
+massage on those trips?
+A. No.
+l. Has he ever treated you to a massage?
+A. No, I buy my own, thank you.
+e. Other than your brother, do you have
+any family members who have been accused of
+sexual abuse?
+A. NO.
+MR. HOROWITZ: All right. I've got
+no other questions.
+MR. CRITTON: Mr. Epstein, my name is
+Bob Critton and I represent your brother Jeff.
+I have just a few questions.
+THE WITNESS: Go ahead.
+EXAMINATION BY
+MR. CRITTON:
+Toll Free: 800.211.3376
+Suite 1300
+an Alexander Gallo Company
+
+
+89
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+21
+22
+23
+24
+25
+M. Epstein
+l. If I understand your testimony, you
+haven't been to your brother's house in Palm
+Beach in approximately 10 years?
+A. Yeah.
+l. And the conversations you've had with
+him over the past five, six, seven, eight
+years have been basically hey, Jeffrey, how
+are you doing? And/or he'll say hey, Mark,
+how are you doing?
+A. Well, the one's prior to five years
+ago, 90 percent of the phone calls were
+dealing with my mother.
+My mother had a bunch of medical
+issues for 10 years before she died. She had
+been in a very big car accident, so...
+l. Your mother died approximately
+five years ago?
+A. Five and a half years ago, yes.
+e. So conversations that you had with
+your brother prior to your mother's death
+would have mostly centered around her and her
+condition?
+A. Mostly, yes.
+Q. And then subsequently, after your
+an Alexander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+90
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+mother passed away, the conversations that you
+had with your brother, if I understood your
+testimony, were basically, "How are you
+doing?" "How are you doing?"
+A. More or less. A funny story about a
+friend or something, yes.
+Q. With regard to the criminal charges
+that were brought against your brother and
+whatever has occurred with regard to those
+criminal charges, would it be a correct
+statement that you have never discussed any of
+those issues with your brother?
+A. That's correct.
+l. With regard to the civil cases that
+have been filed against your brother, would it
+be a correct statement that you have never
+discussed any of the allegations of the civil
+cases?
+A. That's correct.
+Q. And with regard to the newspaper
+articles that have been written or the lawyers
+who have sought publicity to put information
+in the newspaper about your brother's
+confessions to sensationalize the story, would
+sa Alessader Gallo Company
+oll Free: 800.211.337
+acsimile: 954.331.441
+Suite 1300
+
+
+91
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+it be a correct statement that you never
+discussed those newspaper articles with him?
+MR. EDWARDS: Objection to the form.
+l. Let me ask it in a simpler form.
+With regard to any newspaper article
+that you've seen about your brother relating
+to allegations here and people in Palm County,
+would it be a correct statement that you have
+not discussed those with your brother?
+A. Correct.
+MR. CRITTON: That's all I have.
+Thank you, sir.
+MR. COHEN: I have no questions.
+MR. EDWARDS: I only have two
+follow-up questions.
+EXAMINATION BY
+MR. EDWARDS:
+e. When you called your brother to tell
+him that you were subpoenaed, did he tell you
+that he would hire you an attorney?
+A. NO.
+l. How did it come to be that he hired
+you an attorney and an attorney is here with
+you today?
+an Alesander Gallo Company
+Suite 1300
+
+
+92
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+M. Epstein
+A. Another attorney called me and said
+that they would provide me with an attorney.
+e. Who was that?
+A. Jack.
+e. Jack Goldberger?
+A. I believe so, yes.
+l. And was that within days of your
+phone call to your brother?
+A. Within weeks. I don't remember
+exactly when I was served. It's not high on
+my priority list.
+l. You don't want to have anything to do
+with this case?
+A. I have nothing to do with this case.
+Q. The last question I have to ask you
+is some of the girls have described your
+brother's penis as being egg-shaped.
+Is that something that you would know
+from being his brother and growing up?
+MR. CRITTON: Form.
+MR. COHEN: Objection.
+A. I read that, and that was a shock. I
+never heard that and/or ever saw that.
+Q. Have you ever seen his penis?
+an Alexander Gallo Conpany
+
+
+93
+1
+2
+3
+M. Epstein
+5
+6
+7
+8
+A. Yes.
+e. Do you remember anything unusual or
+egg-shaped about it?
+A. NO.
+MR. EDWARDS: All right. Anybody
+else have anything?
+l. Oh, did your brother tell you how to
+testify today?
+A. Did he tell me he had to testify
+today?
+l. Did he tell you how to testify --
+A. No.
+e. -. Io come here and say you don't
+know anything about it?
+A. No, nobody tells me what to do.
+MR. COHEN: Okay. We are done.
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+(Continued on the next page to
+include jurat and signature.)
+an Alexander Gallo Company
+Suite 1300
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+94
+M. Epstein
+THE VIDEOGRAPHER: The time is 1:03
+p.m., and we are off the record.
+This is the end of tape one.
+(Time noted: 1:03 p.m.)
+MARK EPSTEIN
+Subscribed and sworn to
+Before me this
+day of
+, 2009.
+Notary Public
+der Gallo Company
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+WITNESS
+M. Epstein
+95
+IN DEX
+EXAMINATION BY
+Mr. Edwards
+Mr. Willits
+Ms. Ezell
+Mr. Langino
+Mr. Horowitz
+Mr. Critton
+PAGE NO.
+9.91
+73
+75
+80
+85
+88
+Plaintiff's
+EXHIBITS
+1
+DESCRIPTION
+Document
+PAGE NO.
+16
+inder Gallo Compaay
+Suite 1300
+
+
+96
+1
+CERTIFICATION
+2
+3
+4
+5
+6
+7
+8
+I, Jacklyn Lisi, a Shorthand Reporter, and
+Notary Public, within and for the State of New York, do
+hereby certify:
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+22
+24
+25
+That MARK EPSTEIN, the witness whose
+examination is hereinbefore set forth, was first duly sworn
+by me, and that transcript of said testimony is a true
+record of the testimony given by said witness.
+I further certify that I am not related to any
+of the parties to this action by blood or marriage, and that
+I am in no way interested in the outcome of this matter.
+this
+IN WITNESS WHEREOF, I have hereunto set my hand
+day of
+• 2009.
+sacklyn tere
+ACKLYN LIS
+in Alezander Gallo Compray
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+97
+DEPOSITION ERRATA SHEET
+Esquire Deposition Solutions
+RE:
+File No. 13061
+Case Caption: JANE DOE
+VS. JEFFREY EPSTEIN
+Deponent: Mark Epstein
+Deposition Date: September 21, 2009
+To the Reporter:
+I have read the entire transcript of my Deposition taken
+in the captioned matter or the same has been read to me.
+I request that the following changes be entered upon the
+record for the reasons indicated. I have signed my name to
+the Errata Sheet and the appropriate Certificate and
+authorize you to attach both to the original transcript.
+Page No._
+_Line No._
+Change to:_
+Reason for change:_
+Page No.
+_Line No.
+Change to:
+Reason for change:_
+Page No.
+Line No.
+Change to:
+Reason for change:
+rander Gallo Company
+Toll Free: 800.211.3376
+acsimile: 954.331.4418
+Suite 1300
+
+
+98
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+21
+22
+23
+24
+25
+Deposition of Mark Epstein
+Page No.
+_Line No.
+Change to:
+Reason for change:
+Page No.
+_Line No.
+_Change to:_
+Reason for change:
+Page No.
+Line No.
+Change to:
+Reason for change:
+Page No..
+_Line No.
+_Change to:
+Reason for change:
+Page No.
+Line No.
+Reason for change:
+Page No.
+_Line No..
+Change to:
+_Change to:
+Reason for change:
+SIGNATURE:
+DATE:
+ader Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+WORD INDEX
+EPSTEIN, MARK
+
+
+
+
+•a Alexander Gallo Company
+Toll Free: 800.211.3376
+
+
+an Alexander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+ort Lauderdale, FL 3330
+ww.esquiresolutions.co
+
+
+sa Alexander Gallo Company
+Toll Free: 800.211.337
+acsimile: 954.331.441
+Suite 1300
+
+
+102
+an Alexander Gallo Company
+Facsimile: 994-311-3376
+Suite 1300
+ort Lauderdale, FL 3330
+ww.esquiresolutions.cor
+
+
+an Alesaader Callo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+104
+*n Alesaader Gallo Company
+oll Free: 800.211.337
+acsimile: 954.331.441
+Suite 1300
+
+
+105
+an Alexander Gallo Company
+Toll Free: 800.211.3376
+Sulte 1300
+
+
+an Alexander Gallo Company
+Toll Free: 800.211.3376
+Facsimile: 954.331.441€
+Suite 1300
+
+
+an Alesander Gallo Company
+Fact mie: 854-211.3376
+Suite 1300
+
+
+an Alexander Gallo Compaay
+oll Free: 800.211.337
+csimile: 954.331.441
+Suite 1300
+
+
+100
+an Alexander Gallo Company
+oll Free: 800.211.337
+acsimile: 954.331.441
+Suite 1300
+
+
+aa Alexander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+an Alexander Galle Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+110
+an Alexander Gallo Company
+Toll Free: 800.211.3376
+Suite 1300
+
+
+an Alexander Gallo Company
+Toll Free: 800.211.337
+Suite 1300
+
+
+111
+an Alexander Galle Compang
+Toll Free: 800.211.3376
+Suite 1300
+
+
+an Alezander Gallo Company
+Toll Free: 800.211.337
+'acsimile: 954.331.441
+Suite 1300
+
diff --git a/vision-fixhub/ds9-unparsed-05/ce2e1b0413f28cb87d8401cc9a5cea25940537294bc47a3c82a1217d6ceee5a2.receipt.json b/vision-fixhub/ds9-unparsed-05/ce2e1b0413f28cb87d8401cc9a5cea25940537294bc47a3c82a1217d6ceee5a2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..23cf50e4db09ab6c67205df10837c35a93073752
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ce2e1b0413f28cb87d8401cc9a5cea25940537294bc47a3c82a1217d6ceee5a2.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -15926,
+  "dataset": "marble-joined",
+  "doc_id": "ce2e1b0413f28cb87d8401cc9a5cea25940537294bc47a3c82a1217d6ceee5a2",
+  "engine": "marble-apple-vision",
+  "event_count": 121,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "b17e4e70848f476d689482c109920ba73c86cb52a6374db7500402a67074a2fc",
+  "output_sha256": "4999ee6d008b76f11d9f0a889d42018218822ada3f3391e44c8fc68f836e457d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ceade7125d9c92a1cf77616b20f3c52e20f04a9f977dac98c6fb794beb57d9d2.md b/vision-fixhub/ds9-unparsed-05/ceade7125d9c92a1cf77616b20f3c52e20f04a9f977dac98c6fb794beb57d9d2.md
new file mode 100644
index 0000000000000000000000000000000000000000..475dd204a090b4e7f7f62fac1e134a7491491482
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ceade7125d9c92a1cf77616b20f3c52e20f04a9f977dac98c6fb794beb57d9d2.md
@@ -0,0 +1,289 @@
+To:
+Subject:
+Monday, November 19, 2007 9:23 AN
+Richards, Jason R
+RE: Epstein
+Thanks, Jason. I will pass along the info. I think he is serving two sentences
+of less than 1 year, so the county will be in charge, but let me know what the
+state says, too.
+Any word on our search warrant?
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+-----Original Message-----
+From: Richards, Jason R.
+Sent: Friday, November 16, 2007 9:38 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Re: Epstein
+According to the jail supervisor Epstein would not qualify for work release as a
+sex offender, however the work release could still be ordered by the judge. The
+catch is... that rule applies to county time--sentences of 1 year or less. The
+supervisor said sentences over 1 year are handled by the state. He will provide
+me with a state contact on Monday so I'll give you an update as I learn more.
+Have a good weekend!
+----- Original Message -----
+From: Villafana, Ann Marie C. (USAFLS) <Ann. Marie.C.Villafana@usdoj.gov>
+To: Sloman, Jeff (USA); Garcia, Rolando (USA)
+Cc: Acosta, Alex (USA); Atkinson, Karen (USA)
+Sent: Fri Nov 16 13:31:42 2007
+Subject: RE: Epstein
+Hi all - The FBI had their meeting with the ASA this morning. She wasn't aware
+sit not angelebte for want release win ee For see Mir
+if she would do that, she said she would have to talk to Barry. She also
+wouldn't say whether they would oppose such a petition, if one were filed. Lanna
+said that because Epstein is going to be housed at the jail, the Sheriff's Office
+will determine whether Epstein is eligible for work release, not the Florida
+Department of Corrections. I have asked FBI to find out whether "sexual
+predators" (which will be Epstein's legal designation) are eligible to
+participate in work release. I am still reviewing all of the statutes to see
+2588
+P-014299
+
+
+whether there is anything that would bar the judge from granting a petition for
+work release. As soon as I find an answer, I will let you know.
+Lanna would still like us to do the victim notifications. The State does not
+have a procedure (like we do federally) where the Court has to provide a separate
+room for victims who want to attend judicial proceedings, so I do not know how
+many victims will actually want to be present.
+Jeff - As soon as you hear from Judge
+can you let me know? It is going to
+take us a while to track down everyone, especially with the holiday, and I want
+to make sure they have been provided adequate notice.
+Thank you.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+From: Stoman, Jeff (USAFLS)
+Sent: Thursday, November 15, 2007 6:02 PM
+To: Garcia, Rolando (USAFLS); Villafana, Ann Marie C. (USAFLS)
+Cc: Acosta, Alex (USAFLS)
+Subject: Epstein
+Rolando informs me that Krischer said that the plea & sentencing will take place
+on the same day (December 16th ) in order to reduce the media frenzy. Krischer
+said that Epstein will be treated as a sex offender regardless of whether he
+registers or not. He said that "registration" takes place after Epstein completes
+problem is that just like any other sex offender, he can petition the court for
+work release. When Rolando asked Krischer whether he was going to oppose such a
+petition, Krischer responded that he will if it is in the agreement.
+I spoke to Lefkowitz. Lefkowitz confirmed the above understanding. We did not,
+however, discuss anything about work release - just that Epstein will be a sex
+offender and he'll be treated like any other sex offender.
+Lefkowitz confirmed that they will not contact any other victims. He also asked
+Jack Goldberger to provide him with any copies of agreements etc. he has with the
+State. Jay will forward them to me as soon as he receives them.
+2589
+P-014300
+
+
+Finally, Lefkowitz said that the statement in his letter that he "reserves [thel
+right to object to certain aspects of the §2255 provisions of the Agreement"
+refers to their belief that a lawyer who files a lawsuit for some of the class
+may have a direct conflict that may disqualify him/his firm if he's accepting
+fees to negotiate the settlement of the other members of the class. Lefkowitz
+point out the potential conflict to whoever is selected. My view is that those
+issues are between Epstein's lawyers and the victims' lawyers.
+2590
+P-014301
+
+
+To:
+Subject:
+Richards, Jason R.
+Friday, November 16, 2007 9:38 PM
+Re: Epstein
+According to the jail supervisor Epstein would not qualify for work release as a
+sex ottender, however the work release could still be ordered by the judge. The
+catch 15... that rule applies to county time--sentences of 1 year or less.
+supervisor said sentences over 1 year are handled by the state. He will provide
+me with a state contact on Monday so I'll give you an update as I learn more.
+Have a good weekend!
+..--- Original Message -----
+From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov>
+To: Sloman, Jeff (USA); Garcia, Rolando (USA)
+Cc: Acosta, Alex (USA); Atkinson, Karen (USA)
+Sent: Fri Nov 16 13:31:42 2007
+Subject: RE: Epstein
+Hi all - The FBI had their meeting with the ASA this morning. She wasn't aware
+of the December 16th date, and she said that she could include something in their
+plea agreement about not being eligible for work release. When the FBI asked her
+if she would do that, she said she would have to talk to Barry. She also
+wouldn't say whether they would oppose such a petition, if one were filed.
+said that because Epstein is going to be housed at the jail, the Sheriff's Office
+will determine whether Epstein is eligible for work release, not the Florida
+Department of Corrections. I have asked FBI to find out whether "sexual
+predators" (which will be Epstein's legal designation) are eligible to
+participate in work release. I am still reviewing all of the statutes to see
+whether there is anything that would bar the judge from granting a petition for
+work release. As soon as I find an answer, I will let you know.
+Lanna would still like us to do the victim notifications. The State does not
+have a procedure (like we do federally) where the Court has to provide a separate
+room for victims who want to attend judicial proceedings, so I do not know how
+many victims will actually want to be present.
+Jeff - As soon as you hear from Judge
+can you let me know? It is going to
+take us a while to track down everyone, especially with the holiday, and I want
+to make
+sure they have been provided adequate notice.
+Thank you.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+2591
+P-014302
+
+
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+From: Sloman, Jeff (USAFLS)
+Sent: Thursday, November 15, 2007 6:02 PM
+To: Garcia, Rolando (USAFLS); Villafana, Ann Marie C. (USAFLS)
+Cc: Acosta, Alex (USAFLS)
+Subject: Epstein
+Rolando informs me that Krischer said that the plea & sentencing will take place
+on the same day (December 16th ) in order to reduce the media frenzy. Krischer
+said that Epstein will be treated as a sex offender regardless of whether he
+registers or not. He said that "registration" takes place after Epstein completes
+his sentence. Therefore, he will be treated like any other sex offender. The
+problem is that just like any other sex offender, he can petition the court for
+work release. When Rolando asked Krischer whether he was going to oppose such a
+petition, Krischer responded that he will if it is in the agreement.
+I spoke to Lefkowitz. Lefkowitz confirmed the above understanding. We did not,
+however, discuss anything about work release - just that Epstein will be a sex
+offender and he'll be treated like any other sex offender.
+Lefkowitz confirmed that they will not contact any other victims. He also asked
+Jack Goldberger to provide him with any copies of agreements etc. he has with the
+State. Jay will forward them to me as soon as he receives them.
+Finally, Lefkowitz said that the statement in his letter that he "reserves [the]
+right to object to certain aspects of the §2255 provisions of the Agreement"
+refers to their belief that a lawyer who files a lawsuit for some of the class
+may have a direct conflict that may disqualify him/his fírm if he's accepting
+fees to negotiate the settlement of the other members of the class. Lefkowitz
+point out the potential conflict to whoever is selected. My view is that those
+issues are between Epstein's lawyers and the victims' lawyers.
+2592
+P-014303
+
+
+To:
+Cc:
+Subject:
+Friday, November 16, 2007 1:32 PM
+Sloman, Jeff (USAFLS); Garcia, Rolando (USAFLS)
+Acosta, Alex (USAFLS); Atkinson, Karen (USAFLS)
+RE: Epstein
+Hi all - The FBI had their meeting with the ASA this morning. She wasn't aware of the December 16" date.
+and she said that she could include something in their plea agreement about not being eligible for work release.
+When the FBI asked her if she would do that, she said she would have to talk to Barry. She also wouldn't say
+whether they would oppose such a petition, if one were filed. Lanna said that because Epstein is going to be
+housed at the jail, the Sheriff's Office will determine whether Epstein is eligible for work release, not the
+Florida Department of Corrections. I have asked FBI to find out whether "sexual predators" (which will be
+Epstein's legal designation) are eligible to participate in work release. 1 am still reviewing all of the statutes to
+see whether there is anything that would bar the judge from granting a petition for work release. As soon as I
+find an answer. I will let you know.
+Lanna would still like us to do the victim notifications. The State does not have a procedure (like we do
+federally) where the Court has to provide a separate room for victims who want to attend judicial proceedings.
+so 1 do not know how many victims will actually want to be present.
+Jeff - As soon as you hear from Judge
+, can you let me know? It is going to take us a while to track down
+everyone, especially with the holiday, and T want to make sure they have been provided adequate notice.
+Thank you.
+A. Marie Villațaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach. FL 33401
+Phone 56l 209-1047
+Fax 56l 820-8777
+From: Sloman, Jeff (USAFLS)
+Sent: Thursday, November 15, 2007 6:02 PM
+To: Garcia, Rolando (USAFLS); Villafana, Ann Marie C. (USAFLS)
+Cc: Acosta, Alex (USAFLS)
+Subject: Epstein
+Rolando informs me that Krischer said that the plea & sentencing will take place on the same
+day (December 16"") in order to reduce the media frenzy. Krischer said that Epstein will be
+treated as a sex offender regardless of whether he registers or not. He said that "registration"
+takes place after Epstein completes his sentence. Therefore, he will be treated like any other
+sex offender. The problem is that just like any other sex offender, he can petition the court for
+work release. When Rolando asked Krischer whether he was going to oppose such a petition,
+Krischer responded that he will if it is in the agreement.
+2595
+P-014304
+
+
+I spoke to Lefkowitz. Lefkowitz confirmed the above understanding. We did not, however,
+discuss anything about work release - just that Epstein will be a sex offender and he'll be
+treated like any other sex offender.
+Lefkowitz confirmed that they will not contact any other victims. He also asked Jack
+Goldberger to provide him with any copies of agreements etc. he has with the State. Jay will
+forward them to me as soon as he receives them.
+Finally, Lefkowitz said that the statement in his letter that he "reserves [the] right to object to
+certain aspects of the §2255 provisions of the Agreement" refers to their belief that a lawyer
+who files a lawsuit for some of the class may have a direct conflict that may disqualify him/his
+firm if he's accepting fees to negotiate the settlement of the other members of the class.
+Lefkowitz point out the potential conflict to whoever is selected. My view is that those issues
+are between Epstein's lawyers and the victims' lawyers.
+Tracking:
+2596
+P-014305
+
+
+To:
+Cc:
+Subject:
+Sloman, Jeff (USAFLS)
+Thursday, November 15, 2007 6:02 PM
+Garcia, Rolando (USAFLS); Villafana, Ann Marie C. (USAFLS)
+Acosta, Alex (USAFLS)
+Epstein
+Rolando informs me that Krischer said that the plea & sentencing will take place on the same
+day (December 16**) in order to reduce the media frenzy. Krischer said that Epstein will be
+treated as a sex offender regardless of whether he registers or not. He said that "registration"
+takes place after Epstein completes his sentence. Therefore, he will be treated like any other
+sex offender. The problem is that just like any other sex offender, he can petition the court for
+work release. When Rolando asked Krischer whether he was going to oppose such a petition,
+Krischer responded that he will if it is in the agreement.
+I spoke to Lefkowitz. Lefkowitz confirmed the above understanding. We did not, however,
+discuss anything about work release - just that Epstein will be a sex offender and he'll be
+treated like any other sex offender.
+Lefkowitz confirmed that they will not contact any other victims. He also asked Jack
+Goldberger to provide him with any copies of agreements etc. he has with the State. Jay will
+forward them to me as soon as he receives them.
+Finally, Lefkowitz said that the statement in his letter that he "reserves [the] right to object to
+certain aspects of the §2255 provisions of the Agreement" refers to their belief that a lawyer
+who files a lawsuit for some of the class may have a direct conflict that may disqualify him/his
+firm if he's accepting fees to negotiate the settlement of the other members of the class.
+Lefkowitz point out the potential conflict to whoever is selected. My view is that those issues
+are between Epstein's lawyers and the victims' lawyers.
+2598
+P-014306
+
+
+To:
+Cc:
+Subject:
+Wednesday. November 14, 2007 3:48 PM
+Sloman, Jeff (USAFLS)
+Atkinson, Karen (USAFLS)
+Hi Jeff - I am writing to get your blessing on having a meeting with Barry Krisher at the State Attorney's
+Office. The FBI has been trying to set up a meeting with Lanna, the ASA assigned to the case. She canceled
+once, then put them off, and is very reluctant to meet with them. Barry and Lanna should be able to clear up the
+issue regarding sex offender registration/work release and also should be able to tell us whether a plea and
+sentencing can be scheduled this month. Karen has agreed to go with me and, of course, the meeting will be
+very friendly.
+Do you have any objection?
+A. Marie Villațaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+Tracking:
+2599
+P-014307
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/ceade7125d9c92a1cf77616b20f3c52e20f04a9f977dac98c6fb794beb57d9d2.receipt.json b/vision-fixhub/ds9-unparsed-05/ceade7125d9c92a1cf77616b20f3c52e20f04a9f977dac98c6fb794beb57d9d2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d4e77c13663263f0c1bc08f2ef14f0df5a231cef
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ceade7125d9c92a1cf77616b20f3c52e20f04a9f977dac98c6fb794beb57d9d2.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -628,
+  "dataset": "marble-joined",
+  "doc_id": "ceade7125d9c92a1cf77616b20f3c52e20f04a9f977dac98c6fb794beb57d9d2",
+  "engine": "marble-apple-vision",
+  "event_count": 10,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "620fbbf48cae79f36232d40886d59cfad0ff5b44c7fb06b80084b50e0ebc1e9a",
+  "output_sha256": "0d8b34b835cdf77c30d771ffa83463fcaef23f8cbbab01feff35585d32b308d1",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/cef618b301ae762dac79498f0de987e63eb06b657f7636ddb27b159181f67507.md b/vision-fixhub/ds9-unparsed-05/cef618b301ae762dac79498f0de987e63eb06b657f7636ddb27b159181f67507.md
new file mode 100644
index 0000000000000000000000000000000000000000..db4c48e1d8f521dd5ea5bd914a00b2b8a2e459c4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cef618b301ae762dac79498f0de987e63eb06b657f7636ddb27b159181f67507.md
@@ -0,0 +1,27 @@
+
+
+From:
+Sent:
+To:
+Subjeet:
+L. (USAFLS)
+Lilly Ann Sanchez [
+Friday, December 01, 2006 8:40 AM
+1. (USAFLS)
+JE
+I hope that the two weeks you will be out of the district is for a well-deserved vacation. I have been so
+busy lately that I am also looking forward to taking some time off closer to the end of the year.
+I am planning to be out of the office the weeks of Dec. 18 and Dec. 25 to spend much quality time with
+my son who is now 8 years old and growing up too fast. Since it looks like we will miss each other
+before the New Year, I will be in touch at that time and hopefully we will be able to meet shortly
+thereafter. In the interim, I will check on the document requests you made and get back to you.
+Regards.
+Lilly Ann Sanchez, Esq.
+FOWLER WHITE BURNETT P.A.
+>>
+" USAFLS)"
+• 11/17/2006 9:22 AM >>> Hi Lilly -- This is the correct e-mail
+address. I hope that you received the letter that I faxed yesterday. I will be out of the office today, but I
+will be back on Monday.
+Thank you.
+Assistant U.S. Attorney
diff --git a/vision-fixhub/ds9-unparsed-05/cef618b301ae762dac79498f0de987e63eb06b657f7636ddb27b159181f67507.receipt.json b/vision-fixhub/ds9-unparsed-05/cef618b301ae762dac79498f0de987e63eb06b657f7636ddb27b159181f67507.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6414d127086a301c8553e6df6c4768da3eb38361
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cef618b301ae762dac79498f0de987e63eb06b657f7636ddb27b159181f67507.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "cef618b301ae762dac79498f0de987e63eb06b657f7636ddb27b159181f67507",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "382c9ad2448511ca14250d5e287e116152625759019725a94bf9af7dc591e8d9",
+  "output_sha256": "8bfd695f279c366c2d223e6a76fda4e92d404f9fddecb77878bf9260e60fe67f",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/cf263dad8ed5c4b3b66fc45b4fe945420f8277cb98102f7fdf28f5653be7f12c.md b/vision-fixhub/ds9-unparsed-05/cf263dad8ed5c4b3b66fc45b4fe945420f8277cb98102f7fdf28f5653be7f12c.md
new file mode 100644
index 0000000000000000000000000000000000000000..3c27b6dc8417bc29930ea65e3123c675d425fbeb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cf263dad8ed5c4b3b66fc45b4fe945420f8277cb98102f7fdf28f5653be7f12c.md
@@ -0,0 +1,46 @@
+OLY-11
+
+
+TO:
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-11
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+ROOM:
+Room 4-A
+DATE AND TIME:
+August 25, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following document (s) or object(s):
+Please coordinate your compliance of this subpoena and confirm the date and time of your
+appearance with Special Agent
+Federal Bureau of Investigation,
+Telephone:
+Please see additional information on reverse
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+STATES DISTRICT
+DATE:
+August 15, 2006
+This subpoena is issued upon application
+of the United States pf Ameriga
+ana
+Name, Address and Phone Number of Assistant U.S. Attorney
+West Palm Beach, FL 33401-6235
+x3047
+Tel:
+Fax:
diff --git a/vision-fixhub/ds9-unparsed-05/cf263dad8ed5c4b3b66fc45b4fe945420f8277cb98102f7fdf28f5653be7f12c.receipt.json b/vision-fixhub/ds9-unparsed-05/cf263dad8ed5c4b3b66fc45b4fe945420f8277cb98102f7fdf28f5653be7f12c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..90a1d14b2db9936daf613a3abd6f1344df7c21df
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cf263dad8ed5c4b3b66fc45b4fe945420f8277cb98102f7fdf28f5653be7f12c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "cf263dad8ed5c4b3b66fc45b4fe945420f8277cb98102f7fdf28f5653be7f12c",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "732bf8ef278934c679835e775ca57b9b6976645532889a579d7fdc0649e7a29c",
+  "output_sha256": "8a392221cb685f9256259fde22e1809655a83099185309e5404ab39040abe4cb",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/cf7b2a5ae8f059fd00535b1b68d2a40ab3d523914fe24a4f443de3848ab3f69d.md b/vision-fixhub/ds9-unparsed-05/cf7b2a5ae8f059fd00535b1b68d2a40ab3d523914fe24a4f443de3848ab3f69d.md
new file mode 100644
index 0000000000000000000000000000000000000000..340dda97d9e05096684b6e9ee94dcedfd86419a4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cf7b2a5ae8f059fd00535b1b68d2a40ab3d523914fe24a4f443de3848ab3f69d.md
@@ -0,0 +1,70 @@
+TABLE OF CONTENTS
+PBPD
+TAB
+A
+B
+C
+D
+E
+F
+G
+I
+J
+K
+L
+M
+N
+P
+R
+S
+T
+U
+V
+W
+X
+Y
+Z
+AA
+DESCRIPTION
+JANE DOE #1
+JANE DOE #2
+JANE DOE #3
+JANE DOE #4
+JANE DOE #5
+JANE DOE #6
+JANE DOE #7
+JANE DOE #8
+JANE DOE #9
+JANE DOE #10
+JANE DOE #11
+JANE DOE #12
+JANE DOE #13
+JANE DOE #14
+JANE DOE #15
+JANE DOE #16
+JANE DOE #17
+JANE DOE #18
+JANE DOE #19
+JANE DOE #20
+302
+n/a
+In/a
+n/a
+X
+x
+- JANE DOE #21?
+EPSTEIN EMPLOYEES - Mullen,
+Visoski
+Phone Ch
+Transcr
+n/a
+ly
+x
+n/a
+n/a
+n/a
+n/a
+n/a
+n/a
+n/a
+n/a
diff --git a/vision-fixhub/ds9-unparsed-05/cf7b2a5ae8f059fd00535b1b68d2a40ab3d523914fe24a4f443de3848ab3f69d.receipt.json b/vision-fixhub/ds9-unparsed-05/cf7b2a5ae8f059fd00535b1b68d2a40ab3d523914fe24a4f443de3848ab3f69d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2f39532f73324b44f37428b52b5e59375ee8e7bb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cf7b2a5ae8f059fd00535b1b68d2a40ab3d523914fe24a4f443de3848ab3f69d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "cf7b2a5ae8f059fd00535b1b68d2a40ab3d523914fe24a4f443de3848ab3f69d",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "b9e26cfcc485f558d285b00600c363aa111e594095db8b379bc58b5b557b4182",
+  "output_sha256": "8accdc46ed72406acdc6d6b6a1c8f65b5cdbb04f498e74ecec0cd7e38442d723",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/cf96e6bed1356c021455a85e8b49b9cf0084d28d19f4d90aced167d71aa8265b.md b/vision-fixhub/ds9-unparsed-05/cf96e6bed1356c021455a85e8b49b9cf0084d28d19f4d90aced167d71aa8265b.md
new file mode 100644
index 0000000000000000000000000000000000000000..5a190b433d1a049c2c0a5e615a4b69771827ffc3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cf96e6bed1356c021455a85e8b49b9cf0084d28d19f4d90aced167d71aa8265b.md
@@ -0,0 +1,68 @@
+-...
+1/23/07 Villataña to Sanchez
+
+
+
+
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+OO South Anstralian Avenue, Suite 400
+Vest Palm Ranch Florida, 33401-623:
+January 23, 2007
+DELIVERED VIA FAX
+Fowler, White and Burnett
+Espirito Santo Plaza
+14" Floor
+1395 Brickell Avenue
+Miami, FL 33131-3300
+•Dear
+•
+I just received your letter of January 18, 2007 regarding representation of Mr. Epstein's current and
+former employees. Iknow that Mr. Epstein has offered representation to some individuals who have refused
+the offer. Accordingly, it is impossible to determine whether an individual is or is not represented without
+If you would like, please send me a list of those individuals who have accepted Mr. Epstein's offer
+of payment for representation and the names of their attorneys. I will then contact those attorneys directly.
+If any formal or informal joint defense agreements have been made, please let me know.
+Sincerely,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By
+
+
+
+
+01/23/2007 16:47 FAX 5618021787
+USAO WPB FL
+*********************
+**฿
+TX REPORT
+*************
+0001
+TRANSMISSION OK
+TX/RX NO
+CONNECTION TEL
+SUBADDRESS
+CONNECTION ID
+ST. TIME
+USAGE T
+PGS. SENT
+RESULT
+3782
+
+01/23 16:47
+00/52
+United States Attorney's Office
+Southern District of Florida
+500 Australian Ave., Suite 400
+West Palm Beach, FL 33401
+TO:
+ORGANIZATIÓN: Fowler, White and Burnett
+SUBJECT,
+DATE: January 23, 2007
+FROM:
+Assistant United States Attorney
+NUMBER OF PAGES, INCLUDING THIS PAGE:
+2
+
+
diff --git a/vision-fixhub/ds9-unparsed-05/cf96e6bed1356c021455a85e8b49b9cf0084d28d19f4d90aced167d71aa8265b.receipt.json b/vision-fixhub/ds9-unparsed-05/cf96e6bed1356c021455a85e8b49b9cf0084d28d19f4d90aced167d71aa8265b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..68ecd893a620d32a0646e3cb9f6d14443e16f264
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cf96e6bed1356c021455a85e8b49b9cf0084d28d19f4d90aced167d71aa8265b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -83,
+  "dataset": "marble-joined",
+  "doc_id": "cf96e6bed1356c021455a85e8b49b9cf0084d28d19f4d90aced167d71aa8265b",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "39b3949f90d8ecd4c4a470714cd96e244089a8d867d981284f6c4d77c0288de8",
+  "output_sha256": "5fc48e9c7710f683ec0c908060fa55d4057c6a9690df9401f855a55de4a79340",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/cfb28c42a9e568c2360c68fa254a37f97eed887edc0db60f191ddea2d4a286a5.md b/vision-fixhub/ds9-unparsed-05/cfb28c42a9e568c2360c68fa254a37f97eed887edc0db60f191ddea2d4a286a5.md
new file mode 100644
index 0000000000000000000000000000000000000000..d8a847aad584ad389f6805f0adf0945953786e6a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cfb28c42a9e568c2360c68fa254a37f97eed887edc0db60f191ddea2d4a286a5.md
@@ -0,0 +1,6885 @@
+STATE MOTN UNSEAL NIA
+
+
+THE PALM BEACH POST MONDAY, JUNE 15, 2009
+The Palm Beach Post
+ALEX TAYLOR, Publisher
+TIM BURKE, Executive Editor
+RANDY SCHULTZ, Editor of the Editorial Page
+Unseal the Epstein deal
+A rich, middle-aged Palm Beacher
+Palm Beach sex offender
+who preyed on girls almost 40 years
+younger already has received too
+deserves no more breaks.
+many breaks from the system. He
+doesn't deserve another.
+In July 2008, at the age of 55 and
+of course, want it kept secret. Last
+after paying the equivaweek, a Palm Beach County judge
+lent of a small country's
+set a hearing for June 25.
+gross domestic product
+Epstein attorney Jack Goldberger
+claims that the file should stay sealed
+Epstein escaped federal
+to protect the "orderly administration
+of justice" and "protect a compelling
+guilty in state court to
+government interest." Oh, and third
+Epstein
+a pair of charges related
+parties might get hurt. The compelto his luring five girls
+ling interest is Epstein's, and there
+- ages 14 to 17 — to
+is no privacy issue since the victims
+his house. The girls undressed and
+themselves are making the request.
+massaged him in return for $200 to
+Palm Beach police spent 11
+$300. Hes serving only 18 months
+months investigating Epstein, only
+in the, Palm Beach County Jail, and
+to
+see then-State Attorney Barry
+he's serving only nights. And now he
+Krischer kick the case to a grand
+wants just one more favor:
+jury. Mr. Krischer backed off when
+When Epstein entered his state
+one of Epstein's gold-plated attorplea, the terms of his federal deal
+neys, Alan Dershowitz, announced
+were sealed trom the public. That
+that some of the victims had posted
+violated normal procedures. Attor
+MySpace comments about their alco
+neys tor some of the victims, who
+hol and marijuana use.
+have filed civil lawsuits, want that
+Epstein's "best" defense has been
+plea deal unsealed, probably because
+that he didnt know the girls were
+the details would help their cases.
+underage.
+"How he verified that,"
+But given the nature of this case,
+Mr. Goldberger said, "I don't know."
+there's also a public interest. One con- Investigators found a high school
+dition of the federal plea, for example,
+transcript in Epstein's house. He
+was that he take the state deal. That's
+didn't know? The public should know
+what Jeffrey Epstein did, and what
+the file unsealed. Epstein's lawyers, the system did for him.
+
+
+IN THE CIRCUIT COURT OF THE FIFTEENTH
+JUDICIAL CIRCUIT, IN AND FOR PALM BEACH
+COUNTY, FLORIDA
+CASE NO. 2008CF009381A
+DIVISION W
+STATE OF FLORIDA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+MOTION TO MAKE COURT RECORDS CONFIDENTIAL
+Comes now the Defendant, JEFFREY EPSTEIN, by and through his undersigned
+attorney's, pursuant to Florida Rule of Judicial Administration 2.420 and the Administrative
+Orders of this Court, specifically AO 2.303 and moves this Court to treat as confidential
+the following records.
+A. A document referred to as "Non-Prosecution Agreement" filed under seal in the
+court file on July 2, 2008.
+B. Aled under seat mte cou The on August 25, 20 Non-Prosecution Agreement-
+1. The above referenced documents were Ordered Sealed at a hearing held before
+the Honorable Judge Deborah Dale Pucillo on June 30, 2008.
+2. A Motion to Vacate Order Sealing Records and Unseal Records was filed
+by Non-Party EW on or about May 15, 2009.
+3. A Motion to Intervene and Petition for Access was filed by Non-party Palm
+Beach Post on June 1, 2009.
+4. This Court granted Non-Party
+• and Palm Beach Post Motion to Intervene
+on June 10, 2009 but took no immediate action on E. W.'s Motion to Vacate
+Order Sealing Records and Unsealing Records or on Palm Beach Posts Petition
+For Access, pending a further hearing.
+
+
+5.. The documents should remain confidential for the following reasons:
+a. To prevent a serious imminent threat to the fair, impartial, and orderly
+administration of justice.
+b. To protect a compelling government interest.
+c. To avoid substantial injury to innocent third parties.
+d. To avoid substantial injury to a party by disclosure of matters protected
+by a common law and privacy right, not generally inherent in these
+specific type of proceedings, sought to be closed.
+WHEREFORE, Defendant moves this Honorable Court to enter an Order keeping
+the above referenced records confidential, and maintaining them under seal.
+I HEREBY CERTIFY that this motion is made in good faith and supported by a
+sound and factual legal basis.
+hAN
+JACKA. GOLDBERGER, ESQ.
+WITNESS my hand and seal in the County and State last aforesaid this 11 day
+of June, 2009.
+CHARLENE A. GRIFFITH
+Commission # DD 880359
+xpires May 15, 201
+anded Thee Tray Fain issance 800-44-701
+Notary Public State of Flora
+My Commission Expires
+
+
+WE HEREBY CERTIFY that a true and correct copy of the foregoing has been
+furnished via
+Mail; & Facsimile; • Overnight Delivery to R. Alexander Acosta,
+United States Attorney's Office-Southern District, 500 S. Australian Ave., Suite 400,
+West Palm Beach, FL 33401, Judith Stevenson Areo, Esq., State Attorney's Office-
+West Palm Beach, 401 North Dixie Highway, West Palm Beach, FL 33401, William
+J Berger, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas Blvd., Suite
+1650, Fort Lauderdale, FL 33394; Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT
+ADLER, 401 East Las Olas Blvd., Suite 1650, Fort Lauderdale, FL 33394; Deanna K.
+Shullman, 400 North
+Drive, Suite 1100, P.O.Box 2602 (33601) Tampa, FL 33602,
+Robert D. Critton, BURMAN, CRITTON, LUTTIER, & COLEMAN, 515 N. Flagler Dr.
+Suite 400, West Palm Beach, Florida 33401. this 11 day of June, 2009.
+BURMAN, CRITTON, LUTTER & COLEMAN AVISS: AY GOLDBERGER &
+250 An
+11L €
+JACK A. GOLDBERGER, ESQ
+
+
+AFTERBURN COLDBERGER & WEISS, DA.
+June 11, 2009
+'JOSEPH R.ATTERBURY
+• JACK A GOLDBERGER
+JASON S.WEISS
+Board Cercified Criminal Trial Attorney
+¿ Member of New Jersey & Florida Bars
+Honorable Jeffrey Colbath
+Palm Beach County Courhouse
+205 North Dixie Highway
+West Palm Beach, Florida 33401
+RE: State of Florida | Jeffrey Epstein
+Case No. 2008 CF009381A
+Dear Judge Colbath,
+Enclosed please find a courtesy copy of Jeffrey Epstein's Motion to Make Court Records
+Confidential filed with the Clerk of the Court on June 11, 2009.
+Very
+uly yours,
+LAL
+JAG/cg
+Enc.
+ce: Alexander Acosta, U.S. Attorney
+State Attorney
+William Berger, Esq.
+Bradley Edwards, Esq.
+Deanna Shullman, Esq.
+Robert Critton, Esq.
+One Clearlake Centre, Suite 1400
+250 Australian Avenue South West Palm Beach, FL 33401
+www.agwpa.com
+
+
+ATTERBURY GOLDBERGER & WEISS, RA
+One Clearlake Centre, Suite 1400
+250 Australian Avenue South
+neopost'
+045J85005852
+$O.440
+06/11/2009
+Mailed From 334C
+Alexander Acosta
+United States Attorney's Office
+3362316237#I1I
+
+THURSDAY, JUNE 11, 2009
+Judge delays ruling on request
+to unseal plea deal in sex case
+Y SUSAN SPENCER-WENDE
+alm Beach Post Staff Writt
+women now suing Epstein one else gets treated like
+are asking Colbath to un- that," Edwards said.
+WEST PALM BEACH - A
+seal the deal that Epstein
+Epstein, 56, a reported
+circuit judge on Wednes- brokered with federal money manager of billionday did not unseal the
+prosecutors. A lawyer for
+deal that money manager
+aires, is currently serving
+The Palm Beach Post also
+an 18-month sentence
+Jeffrey Epstein of Palm
+has joined in the request.
+Beach struck with fedthe Palm Beach County
+"It's a secret agreeeral prosecutors to avoid
+Stockade after pleading
+ment. A secret, sweetheart
+charges,
+guilty nearly a year ago
+agreement," said former
+to give Epstein's lawyers
+in state court to felony
+Circuit Judge Bill Berger,
+solicitation of prostitution
+who now represents some
+demonstrate
+and procuring teenagers
+of the women.
+for prostitution.
+why it should
+"Everybody
+The saga began years
+on this deal except the
+ago when the Palm Beach
+victims and the public,"
+Police Department began
+Berger said. "The public
+investigating
+should be outraged it has
+young women were begone as far as it has."
+ing brought to Epstein's
+knowledged at a hearing
+mansion on El Brillo Way
+that Epstein's deal was not
+representing the women,
+to massage him and have
+Brad Edwards, has seen
+sex with him in exchange
+sealed in state court in acthe sealed document. A for money.
+cordance with the rules.
+federal judge allowed him
+Epstein's
+and his clients to view it, in federal filings,
+BEL
+
+
+WEDNESDAY, JUNE 10, 2009
+Women
+want sex
+plea deal
+unsealed
+Their attorneys will ask a judge
+to open Jeffrey Epstein's records.
+By SUSAN SPENCER-WENDE
+alm Beach Post Staff Write
+WEST PALM BEACH — When wealthy
+money manager Jeffrey Epstein of Palm
+Beach pleaded guilty last year to procuring teens tor prostitution, his case
+detoured around local and
+state rules regarding the
+sealing of court documents.
+At a plea conference on
+the state charges, a judge,
+a defense lawyer and a prosecutor huddled at the bench
+and decided that a deal Epstein
+Epstein had struck with federal prosecu
+tors to avoid charges should be sealed,
+according to a transcript of the hearing
+But Florida rules of judicial admin-
+See EPSTEIN, 4A F
+See past coverage of Jeffrey Epstein's sex
+scandals. PalmBeachPost.com/epstein
+
+
+Public has right to know details
+of deal, Post attorney will claim
+• EPSTEIN from 1A
+practice and representing
+torney Lanna
+one of the women.
+approached
+such as protecting a trade
+The Palm Beach Post also
+secret or a compelling gov- will ask Colbath to unseal Pucillo, who had left the
+the agreement. Fost attor, bench nine years earlier
+ney Deanna Shullman will
+was filling in temporarily
+occurred
+in argue that the public has a as a senior judge.
+Epstein's case, according right to know the specifics
+According to atranscript,
+to court records.
+of Epstein's deal.
+Goldberger told Pucillo that
+Epsteins own attorneys,
+According to
+Epstein had entered a confidential agreement with
+referred to his confiden- moved in circles that inthe US. attorney's office
+tial deferred prosecution
+President Clinton,
+in which federal prosecuagreement with the US.
+Donald Trump and Prince
+tors brokered not pursuing
+attorney's office, struck in
+charges against him if he
+September 2007, as "un-
+Moneyman of Mystery," deprecedented" and "highly
+clared a 2002 New York magcourt. Pucillo then said she
+unusual." And it was
+azine profile of Epstein.
+wanted a sealed copy of the
+significant
+inducement"
+5b, is in the
+agreement filed in his case,
+for Epstein to accept the
+Palm Beach County Stockand Goldberger concurred
+state's deal, observed the
+ade, serving an 18-month
+that he wanted it sealed.
+state judge who accepted
+sentence after pleading
+later signed off
+his plea,
+County Judge guilty nearly a year ago
+Deborah Dale Pucillo.
+to felony solicitation of
+The Florida Supreme
+Epstein now laces at prostitution and procuring
+Court has expressed "serileast a dozen civil lawsuits
+teenagers for prostitution.
+ous concern" and launched
+in federal and state courts
+He is allowed out from 7
+an all-out inquiry into sealfiled by young women who am. to 11 p.m., escorted by
+ing procedures across the
+said they had sex with
+a deputy, said Palm Beach
+state following media rehim and now are seeking County
+ports in 2006 of entire cases
+spokeswoman Teri Barbera.
+being sealed and disappear
+Attorneys for some of
+During a Palm Beach ing from court records.
+want his Police
+"The public's constitufederal vestigation,
+five victims tional right of access to court
+prosecutors unsealed and and 17
+witnesses
+will ask Circuit Judge Jef staterents. They toilave
+records must remain inviolate, and this court is fully
+frey Colbath to do so today.
+voung women brought bv
+against public his assistants to Epsteins
+committed to safeguarding
+this right," justices wrote in
+policy for these documents
+mansion on El Brillo Way their final report.
+to be have been sealed and for massages and sexual
+Epstein's
+office on
+hidden from public scrutiny.
+activity, and
+as a member of the public,
+paid forwara then being
+Tuesday referred
+questions to Goldberger,
+has a right to have
+it Epstein's plea confer who declined to commen
+these documents unsealed."
+ence last year, his attorney, Pucillo also has decline
+wrote former Circuit Judge
+Goldberger,
+and to comment.
+Bill Berger, now in private
+then-Assistant State At- @susan_spencer
+
+
+4
+THURSDAY, JULY 2, 2009
+METRO REPORT
+IN COURT
+WEST PALM BEACH - An appellata
+court on Wednesday granted financier
+Jeffrey Epstein's request to block
+the unsealing of his non-prosecution
+agreement with the U.S.Attorney's
+Office while the court consid
+ers his appeal. A circuit judge
+had ordered the release of the
+documents, but Epstein's attorney
+argued that it would cause "irreparable harm." Attornevs for
+vomen now suing Epstein and fo
+The Palm Beach Post sought the
+documents' release. The Fourth
+District Court of Appeal blocked
+the unsealing while both sides
+present legal arguments and the
+court considers them. Epstein
+pleaded guilty last year to solicitaion of prostitution and procuring
+teenagers for prostitution.
+
+¿ FRIDAY, JULY 10; 2009
+EPSTEIN SEX PARTNER LOSES LAWSUIT AGAINST NEWSPAPER
+Pervy Palm Beach moneybags Jeffrey
+$100 million because, in 2007, the paper outed her as
+Epstein, who's at the tail-end of his 18-
+a transgender person (boy to girl) and, she claimed,
+month sentence for solicitation of prostitumade her look like "a promiscuous slut." The paper
+tion, is the talk of the legal world again.
+quoted her MySpace page as saying she fantasized
+One of the young girls he invited up for
+about being with multiple partners. A New York appelstrange sex when she was 16 lost her
+late court sided with the tabloid, saying that Cordero
+defamation lawsuit against The New York
+Epstein
+Post last week. Ava Cordero was asking for
+herselt gave the public the reasonable impression of
+promiscuity. Ya think?
+Got a news tip? Call Jose at
+or e-mail
+
+
+IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
+FOURTH DISTRICT
+DOCKETING STATEMENT
+AND NOTICE OF APPEARANCE OF COUNSEL
+(Revised as of May 1, 2001)
+The Court requires the following information in order to facilitate disposition of the case.
+APPELLANT/PETITIONER: If this case involves an original writ, is an appeal of a non-final order or is a case
+involving child custody, this docketing statement must be completed and returned within five days. In all other
+cases, the appellant must file the docketing statement within 20 days from the date of the acknowledgment of the notice
+of appeal.
+
+PLEASE PROVIDE THE FOLLOWING INFORMATION:
+DOCKETING STATEMENT OF: (CHECK ONE)
+1. STYLE OF CASE
+Jeffrey Epstein .
+State of Florida
+APPELLANT/PETITIONER
+APPELLEE/RESPONDENT
+DCA CASE
+NUMBER
+4D09-2554
+LOWER COURT
+CASE NUMBER
+2008 CF 009381A
+2a. NOTICE OF APPEARANCE OF COUNSEL FOR APPELLANT (If party is not represented by counsel,
+party should so indicate and provide accurate mailing address and phone number).
+See attached.
+_Bar Number_
+Name_
+Address.
+Attorney For:
+Phone Number_
+Fax Number.
+2b. APPELLEE'S TRIAL COUNSEL AND/OR APPELLATE COUNSEL (IF KNOWN)
+See attached
+Bar Number
+Name_
+Address
+Attorney For_
+_Phone Number_
+_Fax Number.
+3. INTERESTED PERSONS: List names of all persons or entities having an interest in this matter. Please
+waty er appean or apeles or entities are parties, lawyers or otherwise, and as to parlies, designate
+See attached.
+
+
+4. JUDGES BELOW: List the name of all judges, deputy commissioners and hearing officers/examiners who
+were involved in this action below. Specify the judge who entered the order appealed.
+Honorable Jeffrey J. Colbath (entered order appealed)
+5. JURISDICTION: State the basis for this court's jurisdiction; including the following: (1) the appellate rule
+providing jurisdiction claimed 9.100(c)(1) and 9.140(b)(1)D); (2) the date of filing in the lower tribunal of the order
+June 25,2009
+; (3) if this is an appeal from a final order, the date of the return of verdict
+in a jury action
+: the service date of any Fla. R. Civ. P. 1.530 motion_
+and the date of entry of the order deciding such motion.
+6. PENDING MATTERS IN LOWER TRIBUNAL: Are there any matters, including counts of claims or
+counterclaims, still pending in the lower tribunal? If yes, please explain exactly what remains pending.
+Not in the criminal case. There are civil cases pending against Mr. Epstein.
+7. CURRENT AND PRIOR PROCEEDINGS IN THIS COURT:
+List by style and case number of this court, all cases which are or have been pending before this court
+involving issues arising from the same lower tribunal case and the current status of same:
+None.
+Criminal appeals: List by style and case number of this court all co-defendants currently or previously
+on appeal to this court.
+None.
+Similar Issues: List by style and case number of this court, all cases which are or have been pending
+before this court which are related to this action or which involve an issue which will be similar or determinative
+to the issue in this case on appeal.
+I .L. Epstein, Case No. 4D09-2409.
+If you become aware of appeals filed subsequent to the submission of this docketing statement
+involving a co-defendant in a criminal case, the same controversy or parties, or substantial similar issues,
+please file an amended response to this question.
+2
+
+
+8. Court Transcript:
+Do you intend to order any portion of the transcript for the appeal? Yes
+If yes, have all arrangements been made for its preparation? Yes
+If yes, date ordered
+If no, why not?
+Already filed with court.
+Estimated date of completion:
+Estimated number of pages:
+Name and address of court reporter(s):
+NoV
+No
+9. CUSTODY STATUS IN CRIMINAL APPEALS: Is the appellant in custody and serving a sentence
+imposed as a result of a conviction which is the subject of this appeal?
+If so, state the length of the sentence imposed.
+18 months jail followed by 12 months community control
+10. ISSUES:
+N/A
+If this case involves the determination of the constitutionality of a statute, cite the statute involved.
+Please state in short form the anticipated issues raised. For example, on criminal issues: denial of
+motion for judgment of acquittal, denial of motion to suppress evidence, error in sentence; on civil issues,
+award of alimony, error in valuation of assets for equitable distribution, error in determining contract damages;
+error in admission of hearsay at trial.
+Error in unsealing confidential federal non-prosecution agreement and addendum.
+11. TYPE OF CASE: PLACE A CHECK BY THE MOST APPROPRIATE TYPE OF CASE:
+A. Civil
+1. Domestic Relations - divorce, child custody, paternity or support
+2. Child dependency
+3. Adoption/Termination of Parental Rights
+4. Professional Malpractice
+5. Products Liability
+6. Negligence
+7. Contract or Indebtedness
+8. Condominium - rules violations, developer suits
+9. Foreclosure - mortgage, lien
+10. Inmate Appeal - gain time, rule challenges, disciplinary action
+11. Attorney's Fees
+12. All others - specify —
+3
+
+
+B. Criminal
+1. Direct Appeal - judgment and sentence
+2. Direct Appeal - sentence only
+3. Direct Appeal - juvenile
+4. Collateral Attack - (Rule 3.850 or habeas corpus) - judgment and sentence
+5. Collateral Attack - (Rule 3.800, Rule 3.850 or habeas corpus) - sentence only
+6. Collateral Attack - juvenile
+7. Appeal by the State
+8. All Others - specify _unsealing of confidential federal non-prosecution agreement
+C. Administrative
+1. Department of Professional Regulation
+2. Unemployment Appeals Commission
+3. Rule Challenge - specify agency
+4. All others - specify
+Certificate of Service
+of
+I certify that a copy hereof has been furnished by
+July
+, 2009, to:
+See attached.
+mail
+mail/hand delivery/fax
+this
+8tt day
+(Print Name)
+4
+
+
+2a.
+NOTICE OF APPEARANCE OF COUNSEL FOR APPELLANT
+BARBARA J. COMPIANI
+KREUSLER-WALSH, COMPIANI & VARGAS, P.A.
+West Palm Beach. FL: 33401-5913
+Phone:
+Fax: 1]
+Email:
+Appellate counsel for petitioner
+ROBERT D. CRITTON
+BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
+West Palm Beach. FL 33401
+Phone:
+Fax:
+Counsel for petitioner
+JACK A. GOLDBERGER
+ATTERBURY, GOLDBERGER & WEISS, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach. FL.
+33401
+Phone:
+Fax:
+Counsel for petitioner
+
+
+2b.
+APPELLEE'S TRIAL COUNSEL AND/OR APPELLATE COUNSEL (IF KNOWN)
+WILLIAM J. BERGER
+ROTHSTEIN ROSENFELDT ADLER
+401 East Las Olas Boulevard, Suite 1650
+Fort Lauderdale, FL. 33394
+Phone:
+Fax:
+Counsel for non-party intervener,
+DEANNA K. SHULLMAN
+THOMAS, LOCICERO & BRALOW, P.L.
+400 North |
+Drive, Suite 1100
+P. O. Box 2602 (33601)
+Tampa, FL 33602
+Phone:
+Fax:
+Counsel for non-party intervener, Palm Beach Newspapers d/b/a The Palm Beach Post
+SPENCER T. KUVIN
+LEOPOLD-KUVIN, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Phone:
+Fax:
+Counsel for non-party intervener,
+STATE ATTORNEY'S OFFICE-WEST PALM BEACH
+401 North Dixie Highway
+Phone:
+Fax: |
+Counsel for respondent, State of Florida
+U.S. Attorney's Office--Southern District
+500 South Australian Avenue, Suite 400
+Phone: (561)
+Fax:
+
+
+INTERESTED PERSONS:
+to of
+State Attorney's Office--West Palm Beach
+(counsel for respondent, State of Florida)
+(non-party intervener)
+William J. Berger of
+Rothstein Rosenfeldt Adler
+(counsel for non-party intervener,)
+Honorable Jeffrey J. Colbath
+(circuit court judge)
+Barbara J. Compiani of
+Kreusler-Walsh, Compiani & Vargas, P.A.
+(appellate counsel for petitioner)
+Robert D. Critton of
+Burman, Critton, Luttier & Coleman
+(counsel for petitioner)
+Jeffrey Epstein
+(petitioner)
+Jack A. Goldberger of
+Atterbury, Goldberger & Weiss, P.A
+(counsel for petitioner)
+of
+Kreusler-Walsh, Compiani & Vargas, P.A.
+(appellate counsel for petitioner)
+Spencer T. Kuvin of
+Leopold-Kuvin, P.A.
+(counsel for non-party intervener,)
+Honorable Kenneth A. Marra
+(judge, Southern District of Florida)
+Palm Beach Newspapers d/b/a The Palm Beach Post
+(non-party intervener)
+Deanna K. Shullman of
+Thomas, Locicero & Bralow, P.L.
+(counsel for non-party intervener, The Palm Beach Post)
+U.S. Attorney -Southern District
+
+
+...
+State of Florida
+(respondent)
+(non-party intervener)
+
+
+U.S. ATTORNEY'S OFFICE
+SOUTHERN DISTRICT
+500 South Australian Avenue, Suite 400
+WILLIAM J. BERGER
+ROTHSTEIN ROSENFELDT ADLER
+401 East Las Olas Boulevard, Suite 1650
+Fort Lauderdale, FL 33394
+Counsel for
+SPENCER T. KUVIN
+LEOPOLD-KUVIN, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Counsel for
+JACK A. GOLDBERGER
+ATTERBURY, GOLDBERGER & WEISS, P.A.
+250 Australian Avenue South, Suite 1400
+Counsel for petitioner
+STATE ATTORNEY'S OFFICE
+701 North Dixie Highway
+Nest Palm Beach, FL 3340
+DEANNA K. SHULLMAN
+HOMAS, LOCICERO & BRALOW, P.I
+00 North
+Drive, Suite 1100
+P. O. Box 2602 (33601)
+Tampa, FL 33602
+Counsel for The Palm Beach Pos
+ROBERT D. CRITTON
+BURMAN, CRITTON, LUTTIER & COLEMAN
+Counsel for petitioner
+
+
+KREUSLER-WALSH,
+COMPIANI & VARGAS, P.A.
+501 SOUTH FLAGLER DRIVE
+WEST PALM BEACH, FLORIDA 33401-5913
+
+GATES POSTAGE
+PITNEY BOWES
+$ 000.61°
+JUL 08
+2009
+U.S. Attorney's Office-Southern District
+500 South Australian Avenue, Suite 400
+3340186235 C023
+
+COURT OR
+000
+Fourth District Court of Appeal
+1525 Palm Beach Lakes Blvd.
+West Palm Beach, Florida 33401
+ACKNOWLEDGMENT OF NEW CASE
+DATE:
+STYLE:
+July 1, 2009
+JEFFREY EPSTEIN
+I STATE OF FLORIDA
+4DCA#:
+4D09-2554
+The Fourth District Court of Appeal has received the Petition reflecting
+a filing date of 7/1/09
+The county of origin is Palm Beach.
+The lower tribunal case number provided is 20098CF009381A
+The filing fee is Paid In Full - $300.
+Case Type: Certiorari
+Criminal
+The Fourth District Court of Appeal's case number must be utilized on all pleadings and correspondence
+filed in this cause. Moreover, ALL PLEADINGS SIGNED BY AN ATTORNEY MUST INCLUDE THE
+ATTORNEY'S FLORIDA BAR NUMBER.
+Please review and comply with any handouts enclosed with this acknowledgment.
+RECEIPT
+JEFFREY EPSTEIN
+I STATE OF FLORIDA
+4DCA#:
+4D09-2554
+Receipt # R2009-1015476
+Method of Payment: CK
+Check # 25986
+PAYER: MM
+Filing Fee: $300.00
+Total: $300.00
+
+
+cc: Barbara J. Compiani
+Deanna K. Shullman
+Hon. Jeffrey J. Colbath
+Jack A. Goldberger
+State Attorney-P.B.
+Spencer T. Kuvin
+Robert D. Critton, Jr.
+U.S. Attorney'S Office
+William J. Berger
+
+
+DISTRICT COURT OF APPEAL
+FoURTH DISTRICT
+1525 PALM BEACH LANES BLD.
+WEST PALM BEACH, FLORIDA 33401
+HASLER
+017H15532982
+$0.449
+07/01/2009
+Mailed From 33401
+US POSTAGE
+CK
+U.S. Attorney'S Office
+Southern District
+500 South Australian Avenue
+Suite 400
+4D09-2554
+33401+6235
+
+
+IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
+FOURTH DISTRICT, 1525 PALM BEACH LAKES BLVD., WEST PALM BEACH, FL 33401
+July 1, 2009
+JEFFREY EPSTEIN
+CASE NO.: 4D09-2554
+L.T. No. : 20098CF009381A
+STATE OF FLORIDA
+Appellant / Petitioner(s),
+Appellee / Respondents).
+BY ORDER OF THE COURT:
+ORDERED that the motion to file under seal is granted.
+ORDERED FURTHER that this court grants the Motion to Use One Appendix to
+Support the Emergency Petition for Writ of Certiorari and Emergency Motion to Review
+Denial of Stay.
+ORDERED FURTHER that this court grants petitioner's Emergency Motion to
+Review the Order June 26, 2009, that denies the motion for stay. The June 25, 2009,
+order granting the motion to unseal is stayed pending further order of this court.
+ORDERED FURTHER that within ten (10) days of this order respondent shall
+show cause why the petition should not be granted. Respondent shall address this
+court's jurisdiction to review the order as well as the merits of the petition.
+ORDERED FURTHER that petitioner may have ten (10) days thereafter to reply.
+I HEREBY CERTIFY that the foregoing is a true copy of the original court order.
+Served:
+Sharon R. Bock, Clerk
+Robert D. Critton, Jr.
+leanna K. Shullmal
+lon. Jeffrey J. Colbat
+dI
+Barbara J. Compiani
+Spencer T. Kuvin
+Jack A. Goldberger
+U.S. Attorney's Office
+William J. Berger
+COURT OF
+DISTRICT
+Fourth District Court of Appeal
+OF F
+
+
+DISTRICT COURT OF APPEAL
+FOURTH DISTRICT
+1525 PALM BEACH LAKES BuVD.
+WEST PALM BEACH, FLORIDA 33401
+HASLER
+017H15532992
+$0.442
+07/01/2009
+Malled From 33401
+US POSTAGE
+4D09-2554
+U.S. Attorney'S Office
+Southern District
+500 South Australian Avenue
+Suite 400
+33623+8237"1
+19688
+
+N THE DISTRICT COURT OF APPEA
+OURTH DISTRICT OF FLORIDA
+CASE NO. 4D09-2554
+JEFFREY EPSTEIN,
+Petitioner,
+VS.
+STATE OF FLORIDA, FALM BACH NEWSPAPERS, INC.
+Respondents.
+Pending in the Fifteenth Judicial Circuit in and for Palm Beach County, Florida,
+Case Nos. 2006 CF 9454AMB, 2008 CF 9381AMB
+'ALM BEACH NEWSPAPERS, INC. d/b/a THE PALM BEACH POST'
+ESPONSE TO EMERGENCY PETITION FOR WRIT OF CERTIORAR
+THOMAS, LoCICERO & BRALOW PL
+Deanna K. Shullman
+James B. Lake
+101 N.E. 3rd Avenue, Suite 1500
+Ft. Lauderdale, Florida 33301
+
+
+TABLE OF CONTENTS
+TABLE OF AUTHORITIES
+ii
+INTRODUCTION.
+1
+JURISDICTION
+2
+NATURE OF THE RELIEF SOUGHT
+STATEMENT OF THE CASE AND FACTS.
+SUMMARY OF THE ARGUMENT ...
+2
+3
+7
+ARGUMENT .....
+1.
+STANDARD OF REVIEW.
+8
+8
+II. THE TRIAL COURT CORRECTLY UNSEALED THE NPA
+8
+A. The NPA was not Properly Sealed in the First Instance.
+8
+1. Closure of the Non-Prosecution Agreement Improperly Occurred
+without a Motion, Notice, Hearing, or a Proper Order.
+11
+2. Closure of the Addendum Improperly Occurred without any Procedures to
+Protect the Right of Access at all.
+12
+B. No Basis Exists for Current Closure of the Non-prosecution Agreement or
+Its Addendum..
+13
+1. Petitioner Cannot Identify a Rule 2.420(c)(9) Interest that Warrants
+Closure.
+16
+2. The Federal Court's Decisions in Case No. 08-80736 (S.D. Fla. 2008) Did
+Not Preclude the Lower Court's Orders Unsealing the NPA.
+19
+3. Federal Rule of Criminal Procedure 6 Did Not Preclude the Lower Court's
+Orders Unsealing the NPA...
+.21
+CONCLUSION
+25
+26
+
+
+TABLE OF AUTHORITIES
+Federal Cases
+Craig \ Harney,
+331 U.S. 367 (1947)
+Doe | Hammond,
+502 F. Supp. 2d 94 (D.D.C. 2007)..
+In re Grand Jury Investigation of Ven Fuel,
+441 F. Supp. 1299 (M.D. Fla. 1977) ..
+Lockhead Martin Corp. _ Boeing Co.,
+393 F. Supp. 2d 1276 (M.D. Fla. 2005)
+Oregonian Publishing Co. | United States District Court,
+920 F.2d 1462 (9th Cir. 1990)
+U.S. | Rosen,
+ieds states 2kost (raD. Va. 2007)
+796 F.3d 1390 (11th Cir. 1986) .
+State Cases
+Anderson | E.T.,
+862 So. 2d 839 (Fla. 4th DCA 2003).
+Barron | Florida Freedom Newspapers, Inc.,
+531 So. 2d 113 (Fla. 1988)
+Combs | State,
+436 So. 2d 93 (Fla. 1983)
+Doe | Museum of Science and History of Jacksonville, Inc.,
+Case No. 92-32567, 1994 WL 741009 (Fla. 7th Jud. Cir. June 8, 1994)
+Fla. Sugar Cane League, Inc. | Fla. Dept. of Envtl. Reg.,
+Case No. 91-2108 (Fla. 2d Jud. Cir. Sept. 20, 1991)
+Hous. Auth, of the City of Daytona Beach | Gomillion,
+639 So. 2d 117 (Fla. 5th DCA 1994) ..
+In re Amendments to Florida Rule of Judicial Administration 2.420
+954 So. 2d 16 (Fla. 2007)
+Sarasota Herald Tribune, Div. of the New York Times Co. I Holtzendorf,
+507 So. 2d 667(Fla. 2d DCA 1987) ...
+Sarasota Herald Tribune | State,
+924 So. 2d 8 (Fla. 2d DCA 2006) ....
+Sentinel Communications Co. . Watson,
+615 So. 2d 768 (Fla. 5th DCA 1993).
+Wallace | Guzman,
+687 So. 2d 1351 (Fla. 3d DCA 1997)
+ii
+8
+24
+23, 24
+.23
+.9
+23
+8
+10
+8
+17
+.22
+21
+9
+2
+9
+21
+
+
+• Other Authorities
+Fla. Const. Art. I, § 23
+Fla. Const. Art. I, § 24.
+Fla. R. App. P. 9.100(d)
+Fla. R. Jud. Admin. 2.420
+iii
+18
+2
+2
+18
+
+
+INTRODUCTION
+This appeal concerns attempts to thwart public scrutiny of how government
+responded to the prostitution of children in Palm Beach County. In the order at
+issue below, the trial court correctly unsealed a non-prosecution agreement and its
+addendum. A predecessor judge found that the agreement significantly induced
+Petitioner to accept a plea agreement that allowed him to serve 18 months in jail
+for luring children to his Palm Beach mansion for "massages" or sexual activity.
+At the time that the non-prosecution agreement and its addendum (collectively "the
+NPA") were accepted for filing, no basis for closure was asserted or found. Thus,
+the NPA was not properly sealed, and the prior closure order was properly vacated.
+Moreover, no basis currently exists for closure, and the pending petition - like
+Petitioner's filings below - contain nothing more than unsubstantiated assertions
+that confidentiality is required. Thus, continued closure is not warranted.
+Certainly unsealing the documents was not such a clear departure from the
+essential requirements of law as to warrant certiorari relief. Consequently, the
+pending petition must be denied.
+In addition, this Court should exercise its inherent authority under Rule
+9.410 of the Florida Rules of Appellate Procedure to sanction Petitioner for his
+frivolous and bad faith attempts to cloak the resolution of the criminal charges
+1
+
+
+against him in secrecy by awarding to Respondent, Palm Beach Newspapers, Inc.
+d/b/a The Palm Beach Post ("the Post") its attorneys' fees and costs in responding
+to this petition.
+JURISDICTION
+The Post adopts Respondent
+'s statement concerning jurisdiction.
+Insofar as this Court finds jurisdiction, the Post requests that this Court expedite its
+consideration of this matter, so as to remedy the denial to date of the public's and
+press's constitutional and common law rights of access. Art. I, § 24, Fla. Const.;
+Fla. R. App. P. 9.100(d); Sarasota-Herald Tribune||. State, 924 So. 2d 8, 11 (Fla.
+2d DCA 2006) (rule 9.100(d) permits "expedited" review of orders excluding the
+press).
+NATURE OF THE RELIEF SOUGHT
+The Post asks this Court to deny the pending petition and to let stand the
+circuit court's Orders dated June 25, 2009 and June 26, 2009, which unsealed the
+NPA, and directed the Clerk of Court in and for the Fifteenth Judicial Circuit of
+Florida to release these records to the public.!
+' Petitioner has sought review of the June 26, 2009 Order by motion rather than
+by petition for writ of certiorari. Though the June 26 Order does address the
+matter of Petitioner's request for stay, the order also directs the Clerk of Courts to
+release the records, review of which should have been sought by certiorari.
+2
+
+
+STATEMENT OF THE CASE AND FACTS
+This proceeding concerns the public's constitutional and common law rights
+of access to records crucial to the disposition of criminal charges against Petitioner
+Jeffrey Epstein. Specifically, Petitioner seeks review of two orders unsealing a
+non-prosecution agreement and its addendum (collectively the "NPA"), which are
+records of the trial court below. State . Epstein, Case Nos. 06 CF9454AMB, 08
+CF9381AMB.
+Petitioner was investigated by the State of Florida for felony solicitation of
+children for prostitution. (A-7 at p. 3, 1. 15 - p. 4, 1. 4; A-8.) The victims allege
+Epstein brought and paid teenage girls to come to his home for sex and/or
+"massages." (A-11 at 9| 6 and n. 1.) Epstein's minor victims are numerous (A-7 at
+p. 20, Il. 13-18) and the case drew attention of the highest-ranking law enforcement
+officials in Palm Beach County. Frustrated during the course of the investigation,
+Police Chief Michael Reiter even penned a letter to State Attorney Barry Krischer,
+calling his office's handling of the investigation "highly unusual" and suggesting
+that he disqualify himself from the case if the state would not act (A-11 at 9| 6; A-
+18 at p. 36, I1. 7-14?.) A federal investigation of Epstein's conduct as it relates to
+soliciting children for prostitution ensued.
+" References to "A-" are to Petitioner's Appendix.
+3
+
+
+Then abruptly, in June 2008, Epstein pleaded guilty in the trial court below
+to felony solicitation of minors for prostitution, was designated a Sexual Offender
+pursuant to Florida law, and was sentenced to 18-months jail and community
+control.
+(A-8.) Before accepting the terms of his state plea, Epstein entered into
+a non-prosecution agreement with federal prosecutors. (A-7 at p. 38, Il. 9-18.) The
+non-prosecution agreement and its addendum were filed under seal in the lower
+court on July 2, 2008 and August 25, 2008, respectively?
+According to Epstein's lawyers (and presumably the NPA itself*), taking
+the state plea was a condition of the NPA. (A-7 at p. 38, II. 13-18.) The NPA is
+invalidated if Epstein fails to fulfill the obligations of the state plea deal (A-7 at p.
+38, 11. 22 - 25.) In accepting the state plea, the trial court viewed the NPA a
+"significant inducement in accepting" the plea and recognized that the NPA
+influenced the defendant to make the state plea. (A-7 at p. 39, ll. 19-21; p. 40, Il.
+10-13.)
+In considering the plea at the hearing, the court requested a sealed copy of
+the non-prosecution agreement and asked whether Petitioner had signed it. (A-7 at
+3 The NPA and its addendum were filed under seal in this Court on July 1,
+2009.
+4 The Post and its lawyers have not seen the NPA, though it was reviewed, in
+camera, by the trial court (A-19).
+4
+
+
+p. 40, Il. 4-6.) Epstein's lawyer indicated it was signed and interjected that he
+"would like to seal the copy." (A-7 at p. 40, II. 7-9.) Representatives from the
+U.S. Attorneys' Office were present at the hearing (A-7 at p. 39, II. 22-23) but
+stated no objection to filing the non-prosecution agreement in the state court file.
+Thereupon, without any further consideration, the trial court requested a sealed
+copy of the non-prosecution agreement. (A-7 at p. 40, Il. 9-10.) On July 2, 2008,
+without any further proceedings on the issue, the court entered an Agreed Order
+Sealing Document in Court File, which allowed Epstein to file the non-prosecution
+agreement that was attached to the Agreed Order under seal. (A-9.) By its terms,
+the closure order was limited to the non-prosecution agreement and did not include
+its addendum. The order makes no findings with respect to closure and never
+expires. (A-9.) The addendum was filed six weeks later, on August 25, 2008,
+without any further order of the Court with respect to closure.
+Since Epstein pleaded guilty to soliciting a minor for prostitution, he has
+been named in at least 12 civil lawsuits that - like the charges in this case - allege
+Epstein lured teenage girls to his Palm Beach mansion for sex and/or "massages."
+(A-1)? At least 11 cases are pending. In another lawsuit, one of the Epstein's
+S See also A-11 at 91 6 (citing Doe | Epstein, Case No. 08-80069 (S.D. Fla.
+2008); Doe No. 2|. Epstein, Case No. 08-80119 (S.D. Fla. 2008); Doe No. 3.L
+Epstein, Case No. 08-80232 (S.D. Fla. 2008); Doe No. 4. | Epstein, Case No. 08-
+(Footnote continued on next page)
+
+
+accusers has alleged that federal prosecutors failed to consult with her regarding
+the disposition of possible charges against Epstein. (A-1; A-18 at p. 22, 1. 20 - p.
+23, 1. 15.)°
+Given the important public interest in this matter, on June 1, 2009, the Post
+moved to intervene below for the purpose of obtaining access to the NPA. The
+Court granted the Post's motion to intervene on June 10, 2009 (Supp.A.-1 at 1.)'
+The trial court granted the Post's petition for access on June 25, 2009 (A-16, A-18)
+and on June 26, 2009 denied Epstein's motion for stay and directed the clerk to
+release the records at noon on Thursday, July 2, 2009. (A-17, A-19.) Epstein's
+emergency petition for writ of certiorari regarding the June 25, 2009 order and his
+emergency motion to review the June 26, 2009 order followed.
+80380 (S.D. Fla. 2008); Doe No. 5 . Epstein, Case No. 08-80381 (S.D. Fla. 2008);
+I. Epstein, Case No. 08-80811 (S.D. Fla. 2008); Doe |. Epstein, Case No.
+08-80893 (S.D. Fla. 2008); Doe No. 7 . Epstein, Case No. 08-80993 (S.D. Fla.
+2008); Doe No. 6|. Epstein, Case No. No. 08-80994 Fla. Fla. Doe II :
+Epstein, Case No. 09-80469 (S.D. Fla. 2009); Doe No. 101 . Epstein, Case No.
+09-80591 (S.D. Fla. 2009); Doe No. 102|. Epstein, Case No. 09-80656 (S.D. Fla.
+2009); Doe No. 8|. Epstein, Case No. 09-80802 (S.D. Fla. 2009)).
+' See also (A-11 at 916) (citing In re: Jane Doe, Case No. 08-80736 (S.D. Fla.
+2008)).
+" References to "Supp.A." correspond to the supplemental appendix filed by the
+Post simultaneous with this brief.
+6
+
+
+SUMMARY OF THE ARGUMENT
+Petitioner's initial filing of the NPA under seal was achieved without any
+regard for the public's constitutional, statutory and common law rights of access.
+Florida law flatly prohibits the standardless permanent closure that was achieved in
+this case. The public has a right to know what transpires in its courtrooms
+generally and in particular has an interest in understanding how the resolution of
+this highly unusual prosecution occurred.
+Moreover, no present basis for closure exists. Petitioner has not shown -
+and cannot show - that continued closure is proper. Instead, he has made
+conclusory assertions and relied on red herrings in attempting to keep the public
+from understanding how government responded to his solicitation of children to
+perform sex acts.
+The trial court, having reviewed the records in camera, saw through
+Petitioner's flimsy arguments. The trial court did not depart from the essential
+requirements of law in ordering the records unsealed.
+
+
+ARGUMENT
+I.
+STANDARD OF REVIEW.
+The standard of review for a petition for writ of certiorari is whether the trial
+court departed from the essential requirements of law. See Combs | State, 436
+So. 2d 93, 95 (Fla. 1983); Anderson |. E.I., 862 So. 2d 839, 840 (Fla. 4th DCA
+2003).
+II. THE TRIAL COURT CORRECTLY UNSEALED THE NPA.
+The NPA was neither properly sealed in the first instance nor is properly
+sealed at present. The trial court did not depart from the essential requirements of
+law in unsealing the records.
+A. The NPA was not Properly Sealed in the First Instance.
+The NPA - a significant inducement to Petitioner's acceptance of the plea -
+was accepted for filing under seal without any deference to the public's right of
+access to court records. Such standardless closure cannot withstand scrutiny.
+Florida has traditionally served as a model for open government and courts.
+It is well-settled in Florida that "[a] trial is a public event [and] [w]hat transpires in
+the court room is public property. " Miami Herald Publ'g Co. . Lewis, 426 So. 2d
+1, 7 (Fla. 1982) (quoting Craig|. Harney, 331 U.S. 367, 376 (1947)). When
+considering a request to seal judicial records, this Court's "analysis must begin
+8
+
+
+with the proposition that all civil and criminal court proceedings are public events,
+records of court proceedings are public records and there is a strong presumption in
+favor of public access to such matters." Sentinel Communications Co. | Watson,
+615 So. 2d 768, 770 (Fla. Sth DCA 1993). Indeed, the people of this State added
+Article I, Section 24 to the Declaration of Rights in the Florida Constitution to
+make clear that the right of access to the records of all three branches of
+government is of constitutional magnitude. All citizens possess the right to
+"inspect or copy" such records.
+Plea agreements and related documents typically are public record. See
+Oregonian Publishing Co. | United States District Court, 920 F.2d 1462, 1465
+(9th Cir. 1990) ("plea agreements have typically been open to the public"); United
+States | Kooistra, 796 F.3d 1390, 1390-91 (11th Cir. 1986) (documents relating to
+defendant's change of plea and sentencing could be sealed only upon finding of a
+compelling interest that justified denial of public access). Florida law likewise
+recognizes a strong public right of access to documents a court considers in
+connection with sentencing. See Sarasota Herald Tribune, Div. of the New York
+Times Co. |. Holtzendorf, 507 So. 2d 667, 668 (Fla. 2d DCA 1987) ("While a
+judge may impose whatever legal sentence he chooses, if such sentence is based on
+a tangible proceeding or document, it is within the public domain unless otherwise
+9
+
+
+privileged.").
+Under Florida law, closure of judicial records is warranted only under very
+limited circumstances. In particular, the party seeking closure must demonstrate
+that:
+restricting public access is necessary to prevent a serious and
+imminent threat to the administration of justice;
+no alternatives, other than a change of venue, would protect the
+defendant's right to a fair trial; and
+closure would be effective in protecting the rights of the accused,
+without being broader than necessary to accomplish this purpose.
+Miami Herald Publ'g Co. L. Lewis, 426 So. 2d 1, 6 (Fla. 1982). This test, as well
+as the standard announced in Barron . Florida Freedom Newspapers, Inc., 531 So.
+2d 113 (Fla. 1988), was essentially codified in former Rule of Judicial
+Administration 2.051, now 2.420, which was applicable in both criminal and civil
+cases. Sarasota-Herald Tribune, 924 So. 2d at 11.
+In April 2007, the Florida Supreme Court adopted emergency amendments
+to Rule 2.420 in response to Florida media reports of hidden cases and secret
+dockets, a process that has come to be known as "super-sealing." In re
+Amendments to Florida Rule of Judicial Administration 2.420, 954 So. 2d 16 (Fla.
+2007). In adopting the interim rule, the Florida Supreme Court confirmed its
+commitment to safeguarding the public's constitutional right of access to court
+10.
+
+
+records, which the Court held "must remain inviolate." Id. at 17. By its terms,
+Rule 2.420 does not apply to criminal cases; however, later this year the Supreme
+Court will consider amendments to the rule that essentially seek to apply the
+standards applicable in civil cases to criminal ones. See In re Amendments to
+Florida Rule of Judicial Administration 2.420, Case No. 07-2050 (Fla. 2007). In
+the circuit below, however, the new Rule 2.420 procedures have been in effect
+since September 29, 2008. (Supp.A.-2.) In addition, the sealing of the NPA
+violated principles of Florida law established long before the amendments to Rule
+2.420. Consequently, the unsealing of these documents was proper.
+1. Closure of the Non-Prosecution Agreement Improperly
+Occurred without a Motion, Notice, Hearing, or a Proper
+Order.
+The non-prosecution agreement was sealed pursuant to an agreed order
+dated July 2, 2008 (A-9.) At the time, Fifteenth Judicial Circuit Administrative
+Order 2.032 applied to requests for closure of court records in the lower court.
+(Supp.A.-3.) The order requires a motion, notice, and a hearing, none of which
+occurred in this case. (Id. at 99l 1 - 3.) The order further provides that closure is
+proper only upon showing that the factors set forth in Lewis have been met (Id. at 9|
+4) and that "[the reasons supporting sealing the file must be stated with specificity
+in the order sealing the court record" (Id. at 9| 5), neither of which occurred in this
+11
+
+
+case.
+Contrary to Petitioner's assertion (Petition at 13) neither this rule, nor the
+common law of Florida, nor the Florida constitution contemplates sua sponte
+closure of court records upon simple request of the Court or any party. Nor was
+the closure, in fact, sua sponte, as Epstein himself requested closure (A-7 at p. 40,
+II. 7-9.) and admittedly filed the NPA in the court file under seal pursuant to an
+agreed order (A-18 at p. 11, Il. 22-23). The agreed order (A-9) contains none of
+the findings required by Lewis or paragraph 5 of the Administrative Order. The
+closure order is invalid and was properly vacated.
+2. Closure of the Addendum Improperly Occurred without any
+Procedures to Protect the Right of Access at all.
+With respect to the sealing of the addendum to the non-prosecution
+agreement, no procedures were put in place at all. The original non-prosecution
+agreement was attached to the July 2, 2008 agreed order, which allowed to be filed
+under seal the "attached document" only. (A-9.) It appears from the record that
+the addendum - which was not attached to the July 2, 2008 order but was filed six
+weeks later - was simply filed and accepted under seal without any order allowing
+for closure. Closure of the addendum was thus improper on that basis as well. The
+trial court properly unsealed these documents.
+12
+
+
+B.
+No Basis Exists for Current Closure of the Non-prosecution
+Agreement or Its Addendum.
+After the Post intervened, at a June 10, 2009 hearing on the issue of closure,
+the trial court asked Epstein's counsel about the Post's motion (A-11) specifically.
+Epstein's counsel replied:
+If the Post's position is the public has a right to acc - access this then
+there is a procedure in place and ultimately the Court has to conduct a
+hearing and do a balancing test where you look at whether there is
+some compelling government interest and that's going to require an
+evidentiary hearing. So I have no great objection to filing the Request
+for Closure and then having a hearing in front of the Court.
+(Supp.A.-1 at p. 3, 1. 22 - p. 4, 1. 5.) Importantly, Petitioner's counsel did not
+assert that he had complied with these requirements, but that he would. The Court
+reset the hearing for June 25, 2009.
+Petitioner filed a Motion to Make Court Records Confidential (A-13) on
+June 11, 2009. In it, Epstein cited four reasons the NPA should remain under seal:
+1. to prevent a serious and imminent threat to the administration of justice ; 2. to
+protect a compelling government interest; 3. to avoid substantial injury to innocent
+8 This assertion apparently has been abandoned by Petitioner, because his
+petition asserts that he has asserted three bases for confidentiality, and does not
+include this basis. Accordingly, it will not be addressed, except to make note of
+the fact that Epstein has not at any point in this proceeding identified a threat to the
+administration of justice, much less a serious and imminent threat.
+13
+
+
+third parties; and 4. to avoid substantial injury to a party by disclosure of matters
+protected by a common law and privacy right, not generally inherent in these
+specific type of proceedings sought to be closed. (A-13 at | 5.) The motion failed
+to explain how these interests were implicated, failed to address alternatives to
+closure, and failed to explain how closure would protect the interests. (A-13.)
+The lower court heard argument on June 25, 2009. The United States
+Attorneys' Office was provided notice of the hearing, but chose not to appear. (A-
+18 at p. 7, Il. 10-14.) In fact, the U.S. Attorney's Office has taken no position on
+this matter throughout the lower court proceedings and specifically informed
+counsel for
+• that it had no position (A-18 at p. 7, Il. 10-14.) At that hearing,
+the Court found that the proper procedures to initially seal the records were not
+followed and then heard argument from Epstein's counsel on his June 11, 2009
+motion (A-13). Epstein's counsel consented to that procedure. (A-18 at p. 9, Il. 16
+-18.) The Judge held that neither the State, nor the U.S. Government, nor Epstein
+had shown why the NPA ought to remain confidential and ordered the records
+unsealed. (A-16.)
+" It is important to note that the State Attorney's Office appeared at the hearing
+for the limited purpose of objecting to the release of minor victim's names, which
+turned out to be a non-issue because the Court, having reviewed the documents in
+camera, determined that no victim's names were included in the documents (A-19
+at p. 21, Il. 14-19.) The federal government, as mentioned above, took no position
+(Footnote continued on next page)
+14
+
+
+The trial court did not depart from the essential requirements of law in
+unsealing the NPA. Administrative Order of the Fifteenth Judicial Circuit 2.303
+applies to Petitioner's June 11, 2009 request to seal the records in this case.
+(Supp.A.-2.) That administrative order - consistent with Lewis and its progeny -
+applies Rule 2.420's standards to requests for closure of records in criminal
+proceedings in the Fifteenth Judicial Circuit. Any order authorizing closure must
+contain findings that one of the interests set forth in Rule of Judicial
+Administration 2.420(c)(9)(A) is met and that closure is no broader than necessary
+to protect that interest. (Supp.A.-2 at f| 4.); see also Lewis, 426 So. 2d at 3.
+Motions seeking closure must include a "signed certification by the party making
+the request that the motion is being made in good faith and is supported by a sound
+factual and legal basis." (Supp.A.-2 at 9| 1.) Epstein's initial oral request for
+closure failed to comply with the requirements of then-applicable law, and he has
+never presented a sound factual or legal basis for present closure. Consequently,
+unsealing the documents was fully consistent with the essential requirements of
+law.
+and did not appear at any of the hearings on this matter. Nor has either agency
+appealed the lower court's decision.
+15
+
+
+1. Petitioner Cannot Identify a Rule 2.420(c)(9) Interest that
+Warrants Closure.
+Though Epstein's belated written motion identified four interests set forth in
+Rule 2.420(c)(9) that purportedly warrant closure, he failed to explain - either in
+his motion or at the hearing - how any of them applied. Instead, Petitioner
+asserted closure was proper because these broad interests would be served by
+closure, principles of comity require closure, and because the records contain
+information protected from disclosure by Federal Rule of Criminal Procedure 6.
+Even though Petitioner now attempts to craft his arguments around the interests set
+forth in Rule 2.420(c)(9), the trial court cannot be said to have departed from the
+essential requirements of the law in holding that Epstein's burden had not been
+met.
+Epstein's petition asserts that closure is necessary to protect a compelling
+government interest because, he claims, the U.S. Attorneys' Office - who has been
+notified of these proceedings and has taken no position whatsoever - has a
+compelling interest in having the confidentiality provision of its contract with Mr.
+Epstein honored. See Petition at 15. Assuming such a provision exists (the Post
+has not seen the document), Petitioner is in no position to assert a compelling
+interest on the government's behalf, given its decision to take no position on the
+matter. If such an interest exists, the U.S. government is the party to assert it, and
+16
+
+
+it has specifically failed to do so. The trial court did not depart from the essential
+requirements of law in holding that Petitioner failed to demonstrate a compelling
+interest in closure.
+Epstein next asserts that closure is warranted to protect the interest of
+"innocent third parties" and identifies those third parties as Mr. Epstein's coconspirators. (Petition at 15). Again, Mr. Epstein lacks standing to assert the
+interests of third parties. Doe. Museum of Science and History of Jacksonville,
+Inc., Case No. 92-32567, 1994 WL 741009 (Fla. 7th Jud. Cir. June 8, 1994)
+(plaintiff lacks standing to assert privacy interest of third party, minor victims of
+sexual assault by defendant's former employee, who had been convicted) (copy
+attached at Supp.A.-4). In addition, even if the third parties Mr. Epstein identifies
+- his purported co-conspirators - were before the Court, they would have no
+privacy interest in matters pertaining to their criminal conduct. Post-Newsweek
+Stations, Florida, Inc. I. Doe, 612 So. 2d 549 (Fla. 1992) (Does, whose names
+were implicated in criminal prostitution scheme, had no right to privacy by virtue
+of their participation in a crime and thus their names could not be redacted from
+records provided to the public). Thus, the trial judge did not depart from the
+essential requirements of law in finding insufficient third-party interests to justify
+closure.
+17
+
+
+The third interest Epstein seeks to invoke is his own right to privacy. See
+Petition at 15. While Epstein actually does have standing to assert his own right to
+privacy, Florida law is clear that closure is only proper to protect a "substantial
+injury to a party by disclosure of matters protected by a common law or privacy
+right not generally inherent in the specific type of proceeding sought to be closed."
+Fla. R. Jud. Admin. 2.420(c)(9)(A)(vi) (emphasis added). Epstein argues
+disclosure of a plea agreement is not generally inherent in a state court plea hearing
+See Petition at 16. That argument is absurd. Of course Epstein's plea agreement is
+generally inherent in his criminal prosecution. It is the very reason that
+prosecution ended, and as the lower court recognized in accepting the plea, it was a
+"significant inducement" to Petitioner to take the state's deal. (A-7 at p. 39, ll. 19-
+21.; p. 40, Il. 10-13.)
+Moreover, Florida's constitutional right to privacy is expressly subordinate
+to the rights of Floridians to access the records of their government. To wit,
+Article I, § 23, which sets forth the right to privacy, further provides: "It)his
+section shall not be construed to limit the public's right of access to public records
+and meetings as provided by law." Fla. Const. Art. I, § 23. As the Florida
+Supreme Court has recognized, the privacy amendment has not been construed to
+protect names and addresses contained in public records. Post Newsweek, 612 So.
+18
+
+
+2d at 552. The trial court, having reviewed the NPA in camera, certainly had an
+opportunity to assess whether a privacy interest not inherent in his criminal
+prosecution for felony solicitation of children for prostitution is implicated by the
+NPA. It cannot in good faith be argued that the trial court departed from the
+essential requirements of law in determining that no such privacy interest was
+implicated.
+2. The Federal Court's Decisions in Case No. 08-80736
+(S.D. Fla. 2008) Did Not Preclude the Lower Court's
+Orders Unsealing the NPA.
+Nor did the trial court's rejection of Petitioner's comity argument depart
+from the essential requirements of law. In the Southern District of Florida, one of
+the minor victims of Epstein filed a Petition for Enforcement of Crime Victim's
+Rights Acts (A-1)." The victim also asked the federal court to allow her to share
+the NPA with third parties (A-3). Judge Marra denied the motion, finding - as the
+U.S. Government had argued (A-4) - that the NPA was not a record of the federal
+court. (A-6) ("First, as respondent points out, the Agreement was not filed in this
+10 The Post adopts and incorporates
+•'s arguments and analysis on this issue
+in addition to the arguments it sets forth herein.
+" The Post notes that A-3 through A-5 were not part of the record below. If the
+Court is inclined to consider these federal court pleadings, then in fairness it must
+consider those related pleadings which are attached hereto as Supp.A.-5 through
+Supp. A.-7 of the Post's Supplemental Appendix.
+19
+
+
+case, under seal or otherwise."). The federal court also declined to provide any
+relief from restrictions on the parties' use and dissemination of the discovery
+document without prejudice. (A-6 at p.2.)
+Petitioner argues that the Post should be required to seek relief in Judge
+Marra's court. He mischaracterizes the nature of the proceedings there. There is
+no document to unseal in Judge Marra's court. The NPA is not a record of that
+court, and thus any effort by the Post to obtain access to the NPA there would be
+futile, and any order requiring it be unsealed by the lower court herein does not
+conflict with any decision of the federal court. (A-16 at p.3.)
+In fact, when Judge Marra has been asked to seal records of his court that
+quote the NPA, he has refused to do so, and has required such records to be filed in
+the public court file (Supp.A.-S through Supp.A.-7)'2 Thus, though the NPA is not
+a record of the federal court, the federal court has rejected attempts to file portions
+of it under seal. As a result, portions of the NPA appear in the public court file in
+12 Page 4 of Supp.A.-5 and paragraph 5 of Supp.A.-6, both publicly on file in the
+tederal court, quote from the NPA. In addition, Epstein's own lawyers quoted
+extensively from the NPA in seeking to stay one of the civil suits against him. (A-
+11 at 9 6; A-18, p. 35
+through Supp. 1-6 and Supp.36, LL incorporating by reference Supp.A.
+I. Epstein, Case No. 08-CV-80811 (S.D.
+Fla. 2008) at Dkt. 33 pp. 2-5)).)
+20
+
+
+the federal civil litigation against Epstein. (Supp.A-5 at p. 4; Supp.A.-6 at 9| 5;
+Supp.A.-7 at pp. 2-5.) The proverbial cat is already out of the bag.
+Notwithstanding, the NPA is a record of this lower court. The lower court
+did not enter an order conflicting with Judge Marra's rulings (A-16 at p. 3 -
+expressly noting lack of conflict with Judge Marra's orders) and did not depart
+from the essential requirements of law in unsealing the NPA.
+3. Federal Rule of Criminal Procedure 6 Did Not Preclude
+the Lower Court's Orders Unsealing the NPA.'3
+Finally, unsealing the NPA did not conflict with federal law. Records
+available under state law are sealed by federal law only when federal law
+absolutely conflicts with state law and requires confidentiality of the records. The
+Supremacy Clause of the United States Constitution, Art. VI, U.S. Const., comes
+into play only when federal law clearly requires the records to be closed, and the
+state is clearly subject to its provisions. E.g. Wallace | Guzman, 687 So. 2d
+1351, 1353 (Fla. 3d DCA 1997) (exemptions to federal Freedom of Information
+Act do not apply to state agencies); Hous. Auth. of the City of Daytona Beach I
+Gomillion, 639 So. 2d 117 (Fla. Sth DCA 1994) (Federal Privacy Act does not
+exempt from disclosure records of housing authority which are open for inspection
+13 The Post adopts and incorporates
+I's arguments and analysis on this issue
+in addition to the arguments it sets forth herein.
+21
+
+
+under Florida Public Records Act); Ela. Sugar Cane League, Inc. | Fla. Dept. of
+Envtl. Reg., Case No. 91-2108 (Fla. 2d Jud. Cir. Sept. 20, 1991), per curiam
+affirmed, 606 So. 2d 1267 (Fla. 1st DCA 1992 (documents received by state
+agency in course of settlement negotiations to resolve federal lawsuit and
+confidential settlement agreement with U.S. Department of Justice open to
+inspection because federal law did not clearly require confidentiality) (Supp.A.-8.)
+Federal law imposes no such preemption of the Florida constitution and common
+law in this case.
+In particular, Federal Rule of Criminal Procedure 6(e) does not restrict
+access to the NPA. Federal Rule 6(e) restrains grand jurors, court reporters,
+government attorneys, interpreters and the like from disclosing matters occurring
+before the grand jury. Petitioner - apparently the former target of the grand jury -
+is none of these persons. His actions in filing the NPA under seal do not implicate
+Rule 6(e) no matter what information the NPA contains. The lower court's actions
+in unsealing the NPA likewise do not implicate Rule 6, because the lower court
+also is not restrained by Rule 6(e).
+Moreover, the information contained in the NPA does not constitute
+"matters occurring before the grand jury" within the meaning of Rule 6. The
+secrecy rule is limited to such matters for the purpose of "preventing targets of an
+22
+
+
+investigation from fleeing or tampering with witnesses or grand jurors,
+encouraging witnesses to appear voluntarily and speak fully and frankly, avoiding
+damage to the reputation of subjects or targets of the investigation who are not
+indicted, and encouraging grand jurors to investigate suspected crimes without
+inhibition and engage in unrestricted deliberations." Lockhead Martin Corp. z.
+Boeing Co., 393 F. Supp. 2d 1276, 1279 (M.D. Fla. 2005). The rule aims to
+"prevent disclosure of the way in which information was presented to the grand
+jury, the specific questions and inquiries of the grand jury, the deliberations and
+vote of the grand jury, the targets upon which the grand jury's suspicion focuses,
+and specific details of what took place before the grand jury." In re Grand Jury
+Investigation of Ven-Fuel, 441 F. Supp. 1299, 1302-03 (M.D. Fla. 1977). In other
+words, Rule 6 is implicated if disclosure would reveal secret inner workings of the
+grand jury. U.S. L. Rosen, 471 F. Supp. 2d 651, 654 (E.D. Va. 2007).
+Disclosure of details of a government investigation that is independent of a
+parallel grand jury proceeding does not violate Rule 6. Id. Statements by a
+prosecutor's office about its own investigation, therefore, are not covered by the
+secrecy rule. Id. at 655. Likewise, the mere mention of other targets of an
+investigation does not implicate the grand jury secrecy rule. E.g., In re Interested
+Party, 530 F. Supp. 2d 136,140-42 (D.D.C. 2008) (government not prohibited by
+23
+
+
+Rule 6 from disclosing plea agreement and other materials); Doe I. Hammond, 502
+F. Supp. 2d 94, 99-101(D.D.C. 2007) (same). Moreover, "when the fact or
+document is sought for itself, independently, rather than because it was stated
+before or displayed to the grand jury, there is no bar of secrecy." In re Grand Jury
+Investigation of Ven-Fuel, 441 F. Supp. at 1304. Here, the Post seeks to review
+the NPA for its own intrinsic value, and not for the purpose of discerning what
+transpired before the grand jury now more than a year ago. It is clearly well within
+the public's right and interest to review the NPA, given the circumstances
+surrounding the investigation and prosecution of Petitioner as well as the civil
+claims by women who say Epstein sought to make them his child prostitutes.
+These facts clearly constitute a proper basis for unsealing these improperly sealed
+documents.
+Finally, and even assuming for a moment that the NPA contains grand jury
+information - which the Post doubts - when the grand jury's work has concluded,
+and the accused apprehended, the veil of secrecy no longer is necessary and safely
+may be lifted. In re Grand Jury Investigation of Ven-Fuel, 441 F. Supp. at 1303.
+Here, Petitioner has been convicted, and nothing in the record suggests the grand
+jury's work is ongoing. Consequently, no basis exists for finding that the trial
+court departed from the essential requirements of law.
+24
+
+
+CONCLUSION
+The trial court was correct in unsealing the non-prosecution agreement and
+its addendum. These materials were not properly sealed in the first instance.
+Moreover, Epstein has not and cannot provide any basis for closure at this juncture.
+The trial court did not depart from the essential requirements of law in unsealing
+the NPA. Its order should be affirmed, and the Post should be awarded its fees and
+costs and such other further relief as this Court deems proper.
+Respectfully submitted,
+THOMAS, LOCICERO & BRALOW, PL
+sett
+B. take
+Deanna K. Shullman
+Florida Bar No.:
+James B. Lake
+Florida Bar No.:
+101 N.E. Third Avenue, Suite 1500
+Fort Lauderdale, FL 33301
+Telephone:
+Facsimile:
+Attorneys for The Palm Beach Post
+25
+
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been
+furnished via U.S. Mail to: Hon. Jeffrey Colbath, Palm Beach County
+Courthouse, 205 N. Dixie Highway, Room 11F, West Palm Beach, FL 33401; R.
+Alexander Acosta, United States Attorney's Office - Southern District, 500 S.
+Australian Ave., Ste. 400, West Palm Beach, FL 33401; Barbara Burns, Esq.,
+State Attorney's Office - West Palm Beach, 401 North Dixie Highway, West Palm
+Beach, FL 33401; Jack Alan Goldberger, Esq., Atterbury Goldberger, et al., 250
+S. Australian Ave., Ste. 1400, West Palm Beach, FL 33401; Robert D. Critton,
+Esq., Burman, Critton, Luttier & Coleman, 515 N. Flagler Drive, Suite 400, West
+Palm Beach, FL 33401;
+, Esq., 501 S. Flagler Drive, Suite
+503, West Palm Beach, FL 33401-5913; Spencer T. Kuvin, Esq., Leopold-Kuvin,
+P.A., 2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410; and
+Bradley J. Edwards, Esq. and William J. Berger, Esq., Rothstein Rosenfeldt
+Adler, 401 East Las Olas Blvd., Suite 1650, Fort Lauderdale, FL 33394 on this 10"
+day of July, 2009.
+Swet Blake
+Attamey
+26
+
+
+CERTIFICATE OF TYPE, SIZE AND STYLE
+Counsel for Petitioners certifies that this Petition is typed in 14 point
+(proportionately spaced) Times New Roman.
+is Bille
+Attorney
+27
+
+
+- Not an Official Document
+Report Selection Criteria
+Case ID:
+Docket Start Date:
+Docket Ending Date:
+502008CF009381AXXXMB
+Case Description
+Case ID:
+502008CF009381AXXXMB
+Case Caption: EPSTEIN, JEFFREY E
+Division:
+W -COLBATH
+Thursday , June 26th, 2008
+Court:
+CF - FELONY
+Location:
+MB - MAIN BRANCH
+Jury:
+N-Non Jury
+Type:
+CF - FELONY
+Status:
+CLSD - CLOSED CASE
+Related Cases
+No related cases were found.
+Case Event Schedule
+No case events were found.
+Case Parties
+Seq
+# Assoc
+Expn
+Date
+2
+Type
+JUDGE
+ID
+
+3
+4
+DEFENDANT
+3 30-JUN- ATTORNEY
+2008
+Name
+COLBATH, JUDGE
+JEFFREY
+Aliases: none
+EPSTEIN, JEFFREY E Aliases: none
+GOLDBERGER, ESQ, Aliases: none
+JACK A
+Docket Entries
+http://courtcon.co.palm-beach.fl.us/pls/jiwp/ck_public_qry_doct.cp_dktrpt_docket_report?b.. 8/4/2009
+
+
+- Not an Official Document
+
+Docket
+Number
+Docket Type
+0000C - CASE INITIATED TIMELINESS
+RPT
+26-JUN-2008
+Book and Page No.
+Attached To:
+1
+1A
+1 B
+none.
+INFO - INFORMATION SHEET
+26-JUN-2008
+ARISES FROM 2006CF009454AXX
+AREC - ARREST RECORD
+26-JUN-2008
+none.
+TEXT - SEE DOCUMENT
+DESCRIPTION
+26-JUN-2008
+1 C
+ROUGH ARREST - NO PROBABLE CAUSE FILED
+WOAR - WAIVER OF ARRAIGNMENT
+26-JUN-2008
+FILED BY JACK GOLDBERG
+EVSCH - HEARING EVENT
+SCHEDULED
+27-JUN-2008
+http://courtcon.co.palm-beach.fl.us/pls/jiwp/ck_public_gry_doct.cp_dktrpt_docket_report?b... 8/4/2009
+
+
+- Not an Official Document
+
+2
+none.
+JDN - JUDICIAL NOTES
+27-JUN-2008
+SET CASE FOR 6/30/08 @ 8:30 AM FOR STATUS CHECK
+EVHLD - EVENT HELD
+30-JUN-2008
+CR-DAMES. PLEAD & ADJ GUILTY AS CHARGED. STIP/FOUND:
+SEXUAL OFFENDER. PBCJ 6 MOS W/CD FOR 1 DAY, TO RUN
+CONSECUTIVE W/06-9454AXX. PBCJ SENTENCE FOLLOWED BY
+12 MOS PROB. DEFT MUST REGISTER AS A SEXUAL
+OFFENDER W/IN 48 HRS OF RELEASE. DNA SWAB. MER
+2A
+GUIL - JUDGMENT OF GUILTY
+30-JUN-2008
+2 B
+none.
+FNGR - FINGERPRINTS
+30-JUN-2008
+2 C
+none.
+SORD - SENTENCE ORDER
+30-JUN-2008
+2 D
+none.
+SORC - SENTENCE ORDER -
+CONTINUED
+30-JUN-2008
+http://courtcon.co.palm-beach.fl.us/pls/jiwp/ck_public_qry_doct.cp.
+_dktrpt_docket_report?b... 8/4/2009
+
+
+- Not an Official Document
+
+2E
+2F
+2 G
+2H
+none.
+RITE - WAIVER OF RIGHTS
+30-JUN-2008
+none.
+PLS - PLEA SHEET
+30-JUN-2008
+none.
+GLSS - GUIDELINE SCORESHEET
+30-JUN-2008
+none.
+OAFC - ORDER ASSESSING
+FEES/COST
+30-JUN-2008
+3
+(JUDGE PUCILLO FOR MCSORLEY) IN THE AMOUNT OF $473.00
+AS CONDS OF PROB. MER
+AREC - ARREST RECORD
+01-JUL-2008
+RECOMMIT
+RCMIT - RECOMMITMENT
+01-JUL-2008
+none.
+CLSD - CLOSED CASE
+http://courtcon.co.palm-beach.fl.us/pls/jiwp/ck_public_gry_doct.cp.
+_dktrpt_docket_report?b. 8/4/2009
+
+
+- Not an Official Document
+
+||08-JUL-2008
+none.
+RCPT - RECEIPT FOR PAYMENT
+14-JUL-2008
+4
+A Payment of -$473.00 was made on receipt CFMB30200. From
+Bond ID: 00073142
+ORD - ORDER
+21-JUL-2008
+(JUDGE MCSORLEY) OF PROBATION.. NUNC PRO TUNC 6/30/08
+PROC - CRT REPORTER
+TRANSCRIPT OF
+22-JUL-2008
+PLEA CONFERENCE, TAKEN 6/30/08
+MOT - MOTION
+04-DEC-2008
+7
+TO CLARIFY SENTENCE TO CORRECT SCRIVENER'S ERROR
+FILED BY JACK GOLDBERGER
+AGOR - AGREED ORDER
+04-MAY-2009
+8
+(JUDGE COLBATH) THAT THE ORDER OF COMMUNITY
+CONTROL IS CORRECTED TO DELETE SPECIAL CONDITION
+#26 AND #27.
+MOT - MOTION
+http://courtcon.co.palm-beach.fl.us/pls/jiwp/ck_public_qry_doct.cp_dktrpt_
+_docket_report?b... 8/4/2009
+
+
+- Not an Official Document
+
+9
+12-MAY-2009
+(NONPARTY E.WS) TO VACATE ORDER SEALING RECORDS
+AND UNSEAL RECORDS.
+ORSH - ORDER SETTING HEARING
+15-MAY-2009
+SET FOR 5/29/09 RE:MOTION TO VACATE ORDER TO SEAL AND
+UNSEAL RECORD
+EVSCH - HEARING EVENT
+SCHEDULED
+19-MAY-2009
+10
+12
+none.
+NOH - NOTICE OF HEARING
+26-MAY-2009
+SET FOR 5/29/09 10:30
+PONG - PLEA OF NOT GUILTY
+29-MAY-2009
+none.
+EVSCH - HEARING EVENT
+SCHEDULED
+01-JUN-2009
+NON PARTY
+L'S MOTION TO VACATE ORDER SEALING
+RECORDS AND UNSEAL RECORDS
+EVCAN - EVENT
+http://courtcon.co.palm-beach.fl.us/pls/jiwp/ck_public_qry_doct.cp_dktrpt_docket_report?b.. 8/4/2009
+
+
+- Not an Official Document
+
+11
+CANCELLED/SETTLED
+01-JUN-2009
+none.
+RNOH - RE-NOTICE OF HEARING
+01-JUN-2009
+13
+SETTING CASE FOR OTHER HEARING ON 6/10/2009 AT 10:30
+AM FILED BY BRADLEY EDWARDS, ESQ. RE: NON PARTY
+MO TION TO VARATE ORDER SEALI REO ON AID INSEAEA)
+RECORDS, HEARING SEET FOR 5/29/2009 IS CANCELLED
+MOT - MOTION
+03-JUN-2009
+TO VACATE ORDER SEALING RECORD AND UNSEAL RECORDS
+FILED BY BRADLEY EDWARDS, ESQ.
+14
+MOT - MOTION
+03-JUN-2009
+PALM BEACH POST'S MOTION TO INTERVENE AND PETITION
+FOR ACCESS FILED BY DEANNA SHULLMAN, ESQ.
+EVRST - EVENT RESET
+10-JUN-2009
+15
+CR-BELTRAN. MOTION TO INTERVENE-GRANTED. NO ACTION
+ON MOTION TO UNSEAL. RESET FOR MOTION HRG ON 6/25/09.
+BLE
+ORD - ORDER
+10-JUN-2009
+http://courtcon.co.palm-beach.fl.us/pls/jiwp/ck_public_qry_doct.cp_dktrpt_docket_report?b... 8/4/2009
+
+
+- Not an Official Document
+
+16
+17
+(COLBATH)
+CEF - COURT EVENT FORM
+10-JUN-2009
+none.
+ORD - ORDER
+10-JUN-2009
+(COLBATH)
+EVSCH - HEARING EVENT
+SCHEDULED
+11-JUN-2009
+19
+none.
+MOT - MOTION
+11-JUN-2009
+18
+TO MAKE COURT RECORDS CONFIDENTIAL. FILED BY J.
+GOLDBERGER, ESQ
+MOT - MOTION
+15-JUN-2009
+TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW.
+FILED BY S. KUBIN, ESQ
+EVSCH - HEARING EVENT
+SCHEDULED
+25-JUN-2009
+TO STAY DISCLOSURE
+http://courtcon.co.palm-beach.fl.us/pls/jiwp/ck_public_gry_doct.cp_dktrpt_docket_report?b... 8/4/2009
+
+
+- Not an Official Document
+
+(EVHLD - EVENT HELD
+25-JUN-2009
+CR-WIGGINS (COLBATH) DEFT PRES W/J.GOLDBERGER,
+GRANTED, CASE RESET FOR MOTION TO STAY DISCLOSURE
+EVSCH - HEARING EVENT
+SCHEDULED
+25-JUN-2009
+20
+21
+TO STAY DISCLOSURE
+CEF - COURT EVENT FORM
+25-JUN-2009
+none.
+MOT - MOTION
+25-JUN-2009
+TO STAY DISCLOSURE OPF THE NON- PROSECUTION
+AGREEMENT AND ADDENDUM PENDING REVIEW. FILE BY R.
+CRITON, PA
+EVHLD - EVENT HELD
+26-JUN-2009
+25
+CR-WIGGINS. MOTION TO STAY, DENIED. WRITTEN ORDER TO
+FOLLOW. DOCUMENTS IN QUESTION ARE DELAYED UNTIL
+NOON ON THURSDAY 02-JUL-2009. MOTION TO COMPEL THE
+DEFT TO POST BOND - DENIED.
+MOT - MOTION
+26-JUN-2009
+http://courtcon.co.palm-beach.fl.us/pls/jiwp/ck_public_gry_doct.cp_dktrpt_docket_report?b... 8/4/2009
+
+
+- Not an Official Document
+
+31
+32
+FOR ATTY'S FEES AND COSTS. FILED BY D. SHULLMAN, PA
+CEF - COURT EVENT FORM
+26-JUN-2009
+none.
+ORD - ORDER
+26-JUN-2009
+23
+(JUDGE COLBATH) THAT THE MOTIONS TO SEAL THE COURT
+RECORDS ARE DÉNIED. THE MOTIONS TO INTERVENE ARE
+GRANTED. THE MOTION TO UNSEAL THE DOCUMENTS IS
+GRANTED.
+RESP - RESPONSE TO:
+29-JUN-2009
+24
+26
+MOTION TO STAY AND SUPPORTING MEMORANDUM OF LAW.
+FILED BY S. KUVIN, ESQ
+ODMO - ORDER DENYING MOTION
+29-JUN-2009
+](COLBATH) TO STAY DISCLOSURE AGREEMENT
+PROC - CRT REPORTER
+TRANSCRIPT OF
+01-JUL-2009
+27
+PROCEEDINGS BEFORE THE COURT,
+PROC - CRT REPORTER
+TRANSCRIPT OF
+01-JUL-2009
+http://courtcon.co.palm-beach.fl.us/pls/jiwp/ck_public_gry_doct.cp_dktrpt_docket_report?b.. 8/4/2009
+
+
+- Not an Official Document
+
+22
+28
+29
+30
+IPROCEEDINGS BEFORE THE COURT
+ORD - ORDER
+02-JUL-2009
+THAT THE MOTION TO FILE UNDER SEAL IS GRANTED.
+ORDERED FURTHER THAT THIS COURT GRANTS THE MOTION
+TO USE ONE APPENDIX TO SUPPORT THE EMERGENCY
+PETITION FOR WRIT OF CERTIORARI AND EMERGENCEY
+MOTION TO REVIEW DENIAL OF STAY. ORDERED FURTHER
+THAT THIS COURT GRANTS PETITIONERS EMERGENCEY
+MOTION TO REVIEW THE ORDER JUNE 26, 2009, THAT DENIES
+THE MOTION FOR STAY. THE JUNE 25, 2009 ORDER GRANTING
+THE MOTION TO UNSEAL IS STAYED PENDING FURTHER
+ORDER OF THE COURT. ORDERED FURTHER THAT WITHIN
+TEN (10) DAYS OF THIS ORDER RESPONDENT SHALL SHOW
+CAUSE WHY THE PETITION SHOULD NOT BE GRANTED.
+RESPONDENT SHALL ADDRESS THIS COURTS JURISDICTION
+TO REVIEW THE ORDER AS WELL AS THE MERITS OF THE
+PETITION. ORDERED FURTHER THAT PETITIONER MAY HAVE
+TEN (10) DAYS THEREAFTER TO REPLY.
+MOT - MOTION
+06-JUL-2009
+NONPARTY
+'S MOTION FOR ATTORNEYS FEES AND
+COSTS FILED BY W. BERGER
+RESP - RESPONSE TO:
+06-JUL-2009
+(NTERVENER'S) MOTION TO STAY AND SUPPORTING
+MEMORANDUM OF LAW. FILED BY S. KUVIN, ESQ
+EXLT - EXHIBIT LIST
+08-JUL-2009
+none.
+http://courtcon.co.palm-beach.fl.us/pls/jiwp/ck_public_qry_doct.cp_dktrpt_docket_report?b... 8/4/2009
+
+
+07/20/728-159 14622 FRONTONS & LOCICEYSAO MPL
+T-113 P802/0078931
+IN THE DISTRICT COURT OF APPEAL
+FOURTH DISTRICT OF FLORIDA
+CASE NO. 4D09-2554
+JEFFREY EPSTEIN,
+Petitioner,
+VS.
+TATE OF FLORIDA, PALM BEACH NEWSPAPERS, INC.
+L, and
+Respondents.
+Pending in the Fifteenth Judicial Circuit in and for Palm Beach County, Florida,
+Case Nos. 2006 CF 9454AMB, 2008 CF 9381AMB
+PALM BEACH NEWSPAPERS, INC. d/b/a THE PALM BEACH POST'S
+MOTION FOR APPELLATE ATTORNEYS' FEES AND COSTS
+THOMAS, LOCICERO & BRALOW PL
+Deanna K. Shullman
+James B. Lake
+101 N.E. 3rd Avenue, Suite 1500
+Ft. Lauderdale, Florida 33301
+
+
+07/20/2009 15:22 FAX |
+87-20-109 14:22
+T-113 P083/08P-937
+RESPONDENT PALM BEACH POST'S
+MOTION FOR APPELLATE ATTORNEYS' FEES AND COSTS
+Pursuant to Florida Rules of Appellate Procedure 9.400 and 9.410 and
+Administrative Order Number 2.303 of the Fifteenth Judicial Circuit of Florida,
+Respondent Palm Beach Newspapers, Inc., d/b/a The Palm Beach Post (the "Post")
+moves this Court for an award of attorneys' fees and costs in connection with this
+review proceeding. In support thereof, the Post states:
+1.
+The Post is a daily newspaper that has covered this matter and related
+proceedings. In an effort to inform its readers concerning these matters, the Post
+relies upon (among other things) law enforcement records and judicial records.
+On June 10, 2009, the trial court granted the Post's Motion to
+Intervene in this action for the purpose of seeking access to court records.
+Specifically, the Post sought access to a non-prosecution agreement that was
+docketed on July 2, 2008, and an addendum docketed on August 25, 2008.
+3. On June 25, 2009, the trial court heard oral argument on the Post's
+(and other non-parties') motions. The Court found that the documents had not
+properly been sealed in the first instance and further denied Petitioner Jeffrey
+Epstein's Motion to Make Court Records Confidential dated June 11, 2009.
+2
+
+
+07/20/2008 15:23 FAX
+USAO WPB CONER
+07-20-109 14:22
+FROM-THOMAS & LOCICERO
+T-113 P084/087°581
+4.
+The Post is entitled to its fees and costs in this matter pursuant to
+Administrative Order Number 2.303 of the Fifteenth Judicial Circuit of Florida.'
+Specifically, that order allows sanctions to be imposed against the moving party "if
+a motion to seal is not made in good faith and is not supported by a sound legal and
+factual basis." Admin. Or. 15" Jud. Cir. Fla. 2.303.
+5. The Post also is entitled to fees and costs in this matter pursuant to
+Florida Rule of Judicial Administration 9.410, which gives appellate courts
+discretion to impose sanctions if an appeal "presents no justiciable question and is
+so devoid of merit on the face of the record that there is little prospect it will ever
+succeed." E.g. Visoly I. Sec. Pac. Cred. Corp., 768 So. 2d 482, 490-91 (Fla. 3d
+DCA 2000) (citing Fla. R. App. P. 9.410). Frivolous appeals include those in
+which a case is found:
+a.
+to be completely without merit in law and not supported by a
+reasonable argument for an extension, modification or reversal
+of existing law;
+b.
+c.
+to be contradicted by overwhelming evidence;
+as having been undertaken primarily to delay or prolong the
+resolution of the litigation, or to harass or maliciously injure
+another; or
+as asserting material factual statements that are false.
+d.
+Id. at 491.
+'A copy of Administrative Order 2.303 is attached at Tab 2 to the Post's
+Supplemental Appendix, which was filed with its response brief.
+3
+
+
+07/20/2009 15:23 FAX
+07-28-189 14:22 EROM-THOMAS & LOCICERUSAO WPA GONERN,
+7-113p805/0070°91
+6.
+In this case, Mr. Epstein's certiorari petition - like his initial filing of
+these documents under seal and his June 11, 2009 Motion to Make Court Records
+Confidential - was neither made in good faith nor supported by a sound legal and
+factual basis. The certiorari petition asserted three interests that ostensibly would
+be protected by closure but cited no record evidence in support of that assertion.
+Indeed, both in his motion below and at the hearing on the motion, Epstein made
+no genuine effort to demonstrate by evidence how and why any material interests
+would be served by closure. Instead, Epstein's arguments addressed extraneous,
+inapplicable issues that did not support closure and demonstrated his lack of good
+faith in bringing his motion. Moreover, Epstein's assertion that the trial court's
+orders contradicted and were preempted by federal court rulings was simply false.
+Epstein likewise failed to substantiate his arguments in this proceeding, instead
+again relying on red herrings and unsubstantiated blanket assertions to support his
+baseless claim that closure is or was proper in this case.
+7.
+Rather, it appears Epstein opposed unsealing of these records simply
+for the purpose of shielding from public view documents material to the resolution
+of criminal charges against him for soliciting children for prostitution. In other
+words, the petition to this Court was merely a ploy intended to delay the public
+access to judicial records that that the Florida Constitution and common law
+guarantee.
+4
+
+
+07/20/2009 15:23 FAX
+87-20-69 14:222 FROM-THOMAS & LOCICE SAO MPE CONER
+T-113 P006/007E°931
+In sumi, Epstein's arguments for restricting access to his nonprosecution agreement and its addendum are without merit, Epstein's petition to
+this Court was likewise without support in fact or law, and the Post is entitled to an
+award of its fees and costs in defending its rights of access.
+WHEREFORE, the Post respectfully requests that this Court award to it its
+fees and costs and grant such other relief as the Court deems proper.
+Respectfully submitted,
+THOMAS, LOCICERO & BRALOW
+PL
+Sut Blue
+James B. Lake
+Florida Bar No.:
+101 N.E. Third Avenue, Suite 1500
+Fort Lauderdale, JAL 33301
+Telephone:
+Facsimile:
+deanna.shullman@tlolawfirm.com
+Attorneys for The Palm Beach Post
+5
+
+
+07/2017-28-159 14:22 RON-THOMAS a LOCICERUSAO MPR GONRLMI
+T-113 PBB7/087 F-937
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been
+furnished U.S. Mail to: Hon. Jeffrey Colbath, Palm Beach County Courthouse,
+205 N. Dixie Highway, Room 1IF, West Palm Beach, FL 33401; and via facsimile
+and U.S. Mail to: R. Alexander Acosta, United States Attorney's Office -
+Souther District, 500 S. Australian Ave., Ste. 400, West Palm Beach, FL 33401;
+Barbara Burns, Esq., State Attorney's Office - West Palm Beach, 401 North
+Dixie Highway, West Palm Beach, FL 33401; Jack Alan Goldberger, Esq.,
+Atterbury Goldberger, et al., 250 S. Australian Ave., Ste. 1400, West Palm Beach,
+FL 33401; Robert D. Critton, Esq., Burman, Critton, Luttier & Colernan, 515 N.
+Flagler Drive, Suite 400, West Palm Beach, FL 33401; |
+Esq., 501 S. Flagler Drive, Suite 503, West Palm Beach, FL 33401-5913; Spencer
+T. Kuvin, Esq., Leopold-Kuvin, P.A., 2925 PGA Boulevard, Suite 200, Palm
+Beach Gardens, FL 33410; and Bradley J. Edwards, Esq. and William J.
+Berger, Esq., Rothstein Rosenfeldt Adler, 401 East Las Olas Blvd., Suite 1650,
+Fort Lauderdale, FL 33394 on this 20th day of July, 2009.
+pet Bo leler,
+6
+
+
+07/20/2009 15:22 FAX
+USAO WPB CONFR
+4001
+United States Attorney's Office
+Southern District of Florida
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401-6235
+DATE:
+1-20-09
+тО:
+Aust
+ORGANIZATION:
+FAX#:
+SUBJECT:
+FROM:
+ax)
+NUMBER OF PAGES, INCLUDING THIS PAGE:
+COMMENTS:
+FYI
+8
+Original document:
+-
+To follow via regular mail .
+To follow via Federal Express
+To follow via hand delivery
+Nothing to follow, FAX = original
+
+
+07/20/2009 15:22 FAX
+07-20-'09 14:21
+EROMEAHONAS & LOCICERYSAO MPA
+THOMAS LOCICERO
+& BRALOW
+THIS r001/00703s1
+To:
+(Fax)
+facsimile transmittal
+Marilyn, Judicial Assistant to Judge
+Colbath
+R. Alexander Acosta, Esq., USAO
+Barbara Burns, Esq., ASAO
+Jack Alan Goldberger, Esq.
+Bradley J. Edwards, Esq.
+William J. Berger, Esq.
+Robert D. Critton, Esq.
+Spencer I. Kuvin, Esq.
+FAX
+From:
+Re:
+[Urgent
+Please see attached.
+Deanna K. Shuliman, Esq.
+State. J. Epstein
+Date:
+Pages;
+7
+| For review
+T Pleaso comment T
+Please reply L
+Please recycle O
+CONFIDENTIALITY STATEMENT
+This electronic message transmission contains information from the law firm of Thomas, LoCicero & Bralow PL and is confidential or
+privilaged. The information is intended to be for the use of the individual or entity named above. If you are not the intended recipient, be aware
+thad any disclosure, copying, distribution gruse of the contents of this information is prohibited. If you have reedived this electronic transmission
+In error, please notify us by tok phone
+immediatsly. Thank you for your cooperation.
+IRS Circular 230 Disclosure. To the eatent this correspondence contains foderal tax advice, such sdvice was not inlended to be used, and cannot
+be used by any istpayer, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (i) promoting, markering, or
+recommending to saother party any transaction or mener addressed herein. If you would like us to prepare writen tax advice designed to provide
+penalty protection, plense contact us and we will be happy to discuss the matter with you in more detail
+
+
+
+CASE NO. 4D09-2554
+PALM BEACH COUNTY
+L.T. CASE NO. 2008 CF 009381A
+JEFFREY EPSTEIN,
+Petitioner,
+STATE OF FLORIDA,
+Respondent.
+AGREED MOTION TO FILE ONE REPLY SUPPORTING
+PETITION FOR WRIT OF CERTIORARI AND FOR THE TIME TO RUN
+FROM SERVICE OF THE LAST-FILED RESPONSE
+Petitioner, JEFFREY EPSTEIN, requests this Court's permission to file one
+reply supporting his petition for certiorari to the three separate responses filed by
+respondents and for the time to run from service of the last-filed response, for the
+following reasons:
+Mr. Epstein filed an Emergency Petition for Certiorari to review an
+order compelling disclosure of a confidential federal non-prosecution agreement
+and addendum.
+1
+
+
+On July 1, 2009, this Court ordered respondent to show cause within
+10 days why the petition should not be granted. This Court allowed Mr. Epstein 10
+days to reply.
+3.
+Three groups of respondents filed responses: (1)
+.; (2) |
+.; and
+(3) Palm Beach Newspapers, Inc. d/b/a Palm Beach Post ("the Post"). Each
+respondent is represented by different counsel. The responses were served by mail
+and on different days.
+Due to the overlap of arguments in the three responses, it would
+benefit the parties and this Court if Mr. Epstein filed one reply to the three
+responses.
+Accordingly, Mr. Epstein requests permission to file one reply to the three
+responses. Mr. Epstein requests this Court to order that the reply is due 10 days
+from service of the last-filed response.
+Opposing counsel has contacted counsel for respondents (William J. Berger
+for
+; Diana L. Martin for
+; and Deanna K. Shullman for the Post), who
+have all advised they have no objection to this motion.
+2
+
+
+HEREBY CERTIFY that a copy of the foregoing has been sent by aid and
+this 14tk day of July, 2009, to:
+U.S. Attorney's Office-Southern District
+500 South Australian Avenue, Suite 400
+State Attorney's Office-West Palm Beach
+401 North Dixie Highway
+WILLIAM J. BERGER
+ROTHSTEIN ROSENFELDT ADLER
+401 East Las Olas Boulevard, Suite 1650
+Fort Lauderdale, FL 33301
+Counsel for
+SPENCER T. KUVIN
+DIANA L. MARTIN
+LEOPOLD-KUVIN, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Counsel for
+DEANNA K. SHULLMAN
+400 North
+_ Drive, Suite 1100
+P. O. Box 2602 (33601)
+Tampa, FL 33602
+Counsel for The Palm Beach Post
+HONORABLE JEFFREY COLBATH
+15th Judicial Circuit
+Palm Beach County Courthouse
+205 North Dixie Highway
+ROBERT D. CRITTON of
+BURMAN, CRITTON, LUTTIER & COLEMAN
+and
+JACK A. GOLDBERGER of
+ATTERBURY, GOLDBERGER & WEISS, P.A.
+250 Australian Avenue South, Suite 1400
+and
+3
+
+
+!!! and
+BARBARA J. COMPIANI of
+KREUSLER-WALSH, COMPIANI & VARGAS, P.A.
+West Palm Beach, FL 33401-5913
+Counsel for Petitioner
+By: Jane sensle-Olen
+Clord Bar NS-ER. WALSH
+4
+
+
+KREUSLER-WALSH,
+COMPIANI d VARGAS, P.A.
+501 SOUTH FLAGLER DRIVE
+WEST PALM BEACH, FLORIDA 33401-5913
+SINTES POSTAÇE
+mlmlinhallnmslllnl
+U.S. Attorney's Office-Southern District
+500 South Australian Avenue, Suite 400
+3340136235 C023
+Inllmlnlnllnunthllmhdnlahhellmallmmilbl
+
+
+CASE NO: 4D09-2554
+L.T. No. 2008 CF 9381
+JEFFREY EPSTEIN,
+Petitioner,
+STATE OF FLORIDA,
+et. al,
+Respondents.
+ILL'S MOTION TO FILE PORTION OF RESPONSE UNDER SEAL
+Respondent,
+., moves to file under seal a portion of her response
+(dealing with this Court's lack of jurisdiction) to the petition for writ of
+certiorari, on the following grounds:
+In a portion of her response, attached hereto in the sealed envelope,
+discusses page-by-page the sealed document, the Non-Prosecution
+Agreement. Public disclosure of this portion of ||
+I's response would
+violate this Court's order staying disclosure of the NPA.
+For this reason,
+• moves to file the attached under seal. Copies of
+the sealed portion have been served only on the attorneys for petitioner and
+the U.S. Attorney.
+
+
+The undersigned counsel spoke with
+attorney for
+petitioner, and represents that she does not oppose this motion to file under
+seal.
+I HEREBY CERTIFY that a correct copy of the foregoing has been
+served by mail this. _ day of July, 2009, on the parties listed below.
+ROTHSTEIN ROSENFELDT ADLER
+Attorneys for
+401 East Las Olas Blvd., Suite 1650
+Fort Lauderdale, Florida 33301
+Telephone
+Telecoit 95)32-8663
+Wiliam J. Berger
+SERVICE LIST
+Kreusler-Walsh, Compiani & Vargas, P.A.
+West Palm Beach, Fl 33401-5913
+Deanna K. Shullman
+400 North
+P.O. Box 2602
+Tampa, F1 33602
+Drive, Suite 1100
+2
+
+
+Spencer T. Kuvin
+Leopold- Kuvin, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Robert D. Critton of
+Burman, Critton, Luttier & Coleman
+West Palm Beach, Fl 33401
+Jack A. Goldberger of
+Atterbury, Goldberger, & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, Fl 33401
+U.S. Attorney's Office-Southern District
+500 South Australian Avenue, Suite 400
+West Palm Beach, F1 33401
+State Attorney's Office- West Palm Beach
+401 North Dixie Highway
+West Palm Beach, F1 33401
+Honorable Jeffrey Colbath
+Palm Beach County Courthouse
+205 North Dixie Highway
+West Palm Beach. F1 33401
+3
+
+
+CASE NO: 4D09-2554
+L.T. No. 2008 CF 9381
+JEFFREY EPSTEIN,
+Petitioner,
+STATE OF FLORIDA,
+., THE PALM BEACH POST,
+B.B,
+Respondents.
+• 'S RESPONSE TO PETITION FOR CERTIORARI'
+Respondent, I
+I, would show this Court as follows:
+1. Introduction:
+In an unprecedented request that should shock the conscience of this
+Court, a convicted child sex offender seeks to conceal from the public the
+details of his deal with the U.S. Attorney (filed in the lower court) that led
+him to plead guilty to state charges of procuring a minor to engage in
+prostitution (a 2nd degree felony) and felony solicitation of prostitution (a
+3rd degree felony). His request would make a sham of the public's state
+L. has also filed herewith under seal a request to dismiss the petition for
+lack of jurisdiction. That response is filed under seal because it discusses
+page-by-page the sealed document.
+
+
+constitutional right to open government. The lower court properly denied
+this attempt. This Court, it is respectfully submitted, should deny the
+petition for certiorari and vacate the order staying disclosure of the sealed
+documents.
+is one of three respondents to the petition for writ of certiorari.
+The other two, The Palm Beach Post and
+1, are filing their own
+responses. The respondents have tried not to repeat the arguments of each
+other.
+1 limits her response here to arguments in the petition based on
+certain federal court rulings.
+. incorporates by reference the other
+responses.
+The proceedings that have led to the petition for writ of certiorari
+before this Court began with
+I's May 12, 2009 motion below to vacate
+the Agreed Order Sealing Document entered by the trial court on July 2,
+2008 at the plea and sentencing hearing in the state court criminal
+proceedings against petitioner. The Agreed Order authorized the filing
+under seal of the Non-Prosecution Agreement (NPA") between petitioner
+and the United States.
+also moved to unseal an Addendum to the NPA
+that was sealed on August 23, 2008 without any hearing or court order
+whatsoever.
+2
+
+
+-
+The Palm Beach Post and!!
+were granted leave to intervene and
+file their own motions similar to i
+'s.
+The lower court, after two hearings, granted the motions and ordered
+the NPA and Addendum to be unsealed. Petitioner seeks review of that
+order and the order denying his motion to stay pending appellate review.
+For the reasons stated below and in the other responses, it is submitted his
+requests should be denied.
+2. Judge Marra expressly authorized the lower court to resolve
+the issue of whether the state court records should be unsealed.
+Petitioner places great emphasis on rulings entered by United States
+District Judge Kenneth Marra, asserting that the order under review here
+"violated" those rulings.
+In fact, at a June 12, 2009 hearing' attended by petitioner's counsel,
+Judge Marra expressly authorized the lower court, the Honorable Judge
+Jeffrey Colbath, to resolve the issue of whether the state court records should
+be unsealed.
+Responding to a request that he look at the NPA in camera, Judge
+Marra stated:
+THE COURT: Maybe Judge Colvat [sic] will resolve this
+issue for me.
+2 The hearing was in the federal civil lawsuits against petitioner.
+3
+
+
+MR. JOSEFSBERG: Even if he doesn't, Your Honor, I believe
+we are allowed to show it to you.
+THE COURT: I'll tell you what: I'll wait for Judge Colvat
+[sic] to rule, and then if he rules that it should remain sealed, then I'll
+consider whether or not I want to have it submitted to me in camera.
+1-13
+, page 42, lines 8-15(emphasis added).)
+All of petitioner's assertions that Judge Colbath's order under review
+here "violated" Judge Marra's orders, that the lower court gave only "lip
+service" to Judge Marra, that the supremacy clause and the doctrine of
+federal grand jury secrecy are violated, are all shown by the above quotes to
+be false assertions. Judge Marra looked forward to a resolution by the lower
+court of what is purely a state law issue: should these state court records be
+unsealed?
+3. The federal court orders do not support the petition and in fact
+undermine it.
+Even if we were to ignore Judge Marra's quotes above, his written
+orders do not support the petition and in fact undermine it.
+The first federal order petitioner relies on is an "Order To Compel
+Production And Protective Order" dated August 21, 2008. The second is an
+"Order" dated February 12, 2009. (Copies, respectively, are A-2 and A-6 in
+petitioner's Appendix.*)
+3 Reference to
+'s Appendix is by "(
+|_."
+4
+
+
+These orders were entered in a proceeding brought by two of
+petitioner's victims, Jane Does 1 and 2, against the United States under the
+federal Crime Victim's Rights Act, 18 U.S.C. sec. 3771. Petitioner was not
+a party to the proceeding. (A-1.) That proceeding is separate from the
+federal damages actions brought by petitioner's victims. It should also be
+noted that there has never been a federal court prosecution of petitioner.
+There was no federal indictment or information filed.
+In the proceeding where Judge Marra entered the two orders relied on
+by petitioner, the Jane Does sought to obtain production directly from the
+files of the U.S. Attorney of a copy of the NPA. They were not asking
+Judge Marra to "unseal" a state court record.
+Thus, the context of Judge Marra's two orders was a proceeding by
+two private citizens solely against the United States to get a federal judge to
+order the federal prosecutor to produce a document directly from the
+federal prosecutor's files, not to unseal state court records. The factors
+going into this extraordinary request-
+-to order the federal prosecutor to turn
+over documents directly from the files of the prosecutor--are not at all
+relevant to the purely state law issues before this Court on whether a
+* Reference to petitioner's Appendix is by: "(A-_).".
+" Undersigned's firm represents both Jane Does, filed the papers giving rise
+to the orders and attended the hearings referenced therein.
+
+
+document was improperly sealed by a state court and should be unsealed by
+that court.
+The issues before this Court must be resolved by interpreting and
+applying the state constitution, state open government policies, state rules of
+judicial administration and the administrative orders of the state circuit court
+below. They have nothing whatsoever to do with the federal government.
+In the August 21, 2008 order, Judge Marra granted the Jane Does' ore
+tenus motion seeking production of the NPA directly from the U.S.
+Attorney, but with restrictions. He ordered the U.S. Attorney to produce a
+copy of the NPA to Jane Does' attorneys under a nondisclosure restriction.
+Notably, the order makes no reference whatsoever to the state court order
+sealing the NPA in the state court record (even though the state court order
+(A-9) had already been entered on July 2, 2008) or to the fact that the NPA
+was already sealed in the state court file (at the plea colloquy on June 30,
+2008). That is because the dispute before Judge Marra solely involved two
+crime victims seeking a document directly from the files of the U.S.
+Attorney, not from the state court file, and had nothing to do with unsealing
+•state court records.
+The second order entered on February 12, 2009 was on the Jane Does'
+written motion to remove any restrictions on disclosure so their attorneys
+6
+
+
+could discuss the NPA with third parties. Again, the context was two crime
+victims trying to publicly disclose a document directly from the files of the
+U.S. Attorney. Judge Marra denied the motion because the Jane Does had
+not shown that they should be able to publicly disclose a document they got
+directly from the U.S. Attorney's files. This issue, again, has nothing to do
+with whether the lower court should unseal the state court records.
+But in so ruling, Judge Marra indirectly acknowledged the state trial
+court's jurisdiction to unseal its own records. Judge Marra stated: "If a
+specific tangible need arises in a civil case petitioners or other alleged
+victims are pursuing against Epstein, relief should be sought in that case,
+with notice to the United States, the other party to the Agreement." (A-6,
+page 2.)
+Judge Marra's orders were entered after the NPA was sealed by the
+lower court; they can have nothing whatsoever to do with whether the NPA
+was properly sealed.
+Neither federal order, by their express terms, precludes the lower
+court from unsealing its own court records. Judge Marra did not enjoin and
+does not have jurisdiction to enjoin the lower court from unsealing its own
+records. Younger |. Harris, 401 U.S. 37 (1971). As Judge Marra noted,
+"the [NPA] was not filed in this case [the federal proceeding], under seal or
+7
+
+
+otherwise." (A-6, page 1.) The copy of the NPA in the file of the lower
+court is a state court record, not a federal court record. Playing Judge Marra
+off on the lower court is a red herring.
+CONCLUSION
+For the foregoing reasons, the petition should be denied and the stay
+on disclosure vacated.
+I HEREBY CERTIFY that a copy of the foregoing has been served by
+mail on the parties listed below this Slay of July, 2009.
+I HEREBY CERTIFY that the foregoing is submitted in Times New
+Roman 14-point font and complies with the font requirement of Rule 9.100.
+ROTHSTEIN ROSENFELDT ADLER
+Attorneys for
+401 East Las Olas Blvd., Suite 1650
+Fort Lauderdale, Florida 33301
+Telephone, (954) 522-3456
+27-8663
+By:U
+William J. Berger
+8
+
+
+SERVICE LIST
+Kreusler-Walsh, Compiani & Vargas, P.A.
+West Palm Beach, FI 33401-5913
+Deanna K. Shullman
+400 North
+P.O. Box 2602
+Tampa, FI 33602
+Drive, Suite 1100
+Spencer T. Kuvin
+Leopold- Kuvin, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Robert D. Critton of
+Burman, Critton, Luttier & Coleman
+West Palm Beach, F1 33401
+Jack A. Goldberger of
+Atterbury, Goldberger, & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FI 33401
+U.S. Attorney's Office-Southern District
+500 South Australian Avenue, Suite 400
+West Palm Beach, Fl 33401
+State Attorney's Office- West Palm Beach
+401 North Dixie Highway
+West Palm Beach, F1 33401
+9
+
+
+Honorable Jeffrey Colbath
+Palm Beach County Courthouse
+205 North Dixie Highway
+10
+
+
+CASE NO: 4D09-2554
+L.T. No. 2008 CF 9381
+JEFFREY EPSTEIN,
+Petitioner,
+STATE OF FLORIDA,
+et. al,
+Respondents.
+APPENDIX TO
+RESPONSE TO PETITION FOR WRIT OF CERTIORARI
+ROBERT D. CRITTON
+BURMAN, CRITTON, LUTTIER & COLEMAN
+and
+JACK A. GOLDBERGER
+ATTERBURY, GOLDBERGER & WEISS, P.A.
+250 Australian Avenue South, Suite 1400
+and
+and
+BARBARA J. COMPIANI of
+KREUSLER-WALSH, COMPIANI & VARGAS, P.A.
+West Palm Beach, FL 33401-5913
+Counsel for Petitioner
+
+
+Tab
+Document
+Proceedings in Southern District Court
+Transcript of Epstein's Motion to Stay Civil Proceedings (6/12/09)
+1-1
+
+
+I HEREBY CERTIFY that a copy of the foregoing Appendix has been
+served by mail on the parties listed below this 13 day of July, 2009.
+ROTHSTEIN ROSENFELDT ADLER
+Attorneys for
+401 East Las Olas Blvd., Suite 1650
+Fort Lauderdale, Florida 33301
+Telephone (954) 522-3456
+Telecopie 90132738663
+SERVICE LIST
+and
+Barbara J. Compiani or
+Kreusler-Walsh, Compiani & Vargas, P.A.
+West Palm Beach, F1 33401-5913
+Deanna K. Shullman
+400 North
+| Drive, Suite 1100
+P.O. Box 2602 (33601)
+Tampa, FI 33602
+Spencer T. Kuvin
+Leopold- Kuvin, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Robert D. Critton of
+Burman, Critton, Luttier & Coleman
+West Palm Beach, F1 33401
+
+
+Jack A. Goldberger of
+Atterbury, Goldberger, & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FI 33401
+U.S. Attorney's Office-Southern District
+500 South Australian Avenue, Suite 400
+West Palm Beach, Fl 33401
+State Attorney's Office- West Palm Beach
+401 North Dixie Highway
+West Palm Beach, FI 33401
+Honorable Jeffrey Colbath
+Palm Beach County Courthouse
+205 North Dixie Highway
+
+
+09-22785
+SCANNED
+4
+5
+6
+JANE DOE, et al.,
+Plaintiffs,
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+WEST PALM BEACH DIVISION
+CASE NO. 08-80119-CIV-MARRA
+WEST PALM BEACH, FLORIDA
+JUNE 12, 2009
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+TRANSCRIPT OF MOTION HEARING
+BEFORE THE HONORABLE KENNETH A. MARRA,
+UNITED STATES DISTRICT JUDGE
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+APPEARANCES:
+FOR THE PLAINTIFFS:
+ADAM D. HOROWITZ, ESQ.
+Mermelstein & Horowitz
+18205 Biscayne Boulevard
+Miami, FI, 33160
+For Jane Doe
+BRADLEY J. EDWARDS, ESQ.
+Rothstein Rosenfeldt Adler
+401 East Las Olas Boulevard
+Fort Lauderdale, FL 33301
+Jane Doe 3, 4, 5, 6, 7
+ISIDRO M. GARCIA, ESQ.
+Garcia Elkins Boehringer
+224 Datura Avenue
+Jane DOE II
+RICHARD H. WILLITS, ESO.
+2290 10th Avenue North
+Lake Worth, FI 33461
+For
+
+
+1
+2
+3
+6
+7
+FOR THE DEFENDANT:
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+REPORTED BY:
+ROBERT C. JOSEFSBERG, ESQ.
+Podhurst Orseck Josefsberg
+25 West Flagler Street
+Miami, FL 33130
+For Jane Doe 101
+(Via telephone)
+KATHERINE W. EZELL, ESO.
+Podhurst Orseck Josefsberg
+25 West Flagler Street
+Miami, FL 33130
+For Jane Doe 101
+ROBERT D. CRITTON, JR., ESQ.
+MICHAEL BURMAN, ESQ.
+Burman Critton, etc.
+515 North Flagler Street
+West Palm Beach, EL 33401
+JACK A. GOLDBERGER, ESQ.
+Atterbury Goldberger Weiss
+250 Australian Avenue South
+West Palm Beach, EL 33401
+EsQ.
+Assistant U.S. Attorney
+500 East Broward Boulevard
+Fort Lauderdale, FL 33394
+For U.S.A.
+MARTING. WEINBERG, ESP.
+20 Park Plaza
+Boston MA 02116
+(Via telephone)
+JAY LEPKOWITZ, ESQ.
+(Via telephone)
+I, RPR-RMR-ECRR-AE
+Official United States Court Reporter
+Federally Certified Realtime Reporter
+400 North Miami Avenue, Room 8N09
+Miami, FL
+33128
+
+
+1
+2
+3
+4
+5
+THE COURT: We are here in the various Doe vs. Epstein
+cases.
+7
+May I have counsel state their appearances?
+MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs
+Jane 2 through Jane Doe 7.
+THE COURT: Good morning.
+MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane
+Doe.
+9
+10
+THE COURT: Good morning.
+MR. GARCIA: Good morning, Your Honor. Sid Garcia for
+11| Jane Doe II.
+12
+13
+THE COURT: Good morning.
+MR. WILLITS: Good morning, Your Honor. Richard
+14 Willits, here on behalf of the plaintiff
+15
+THE COURT: Good morning.
+16
+MS. EZELI: Good morning, Your Honor. I'm Katherine
+17| Ezell from Podhurst Orseck, here with Amy Adderly and Susan
+18 Bennett, and I believe my partner, Bob Josefsberg, is going to
+19 appear by telephone.
+20
+THE COURT: Mr. Josefsberg, are you there?
+21
+22
+23
+24
+MR. JOSEESBERG: I am, Your Honor.
+THE COURT: Good morning.
+MR. JOSEFSBERG: Good morning.
+THE COURT: All right. Do we have all the plaintiffs.
+25
+stated their appearances? Okay.
+
+
+1
+2
+Defense?
+MR. CRITTON: Your Honor, Robert Critton on behalf of
+3
+4
+5
+MI. Epstein, and my partner, Michael Burman.
+THE COURT: Good morning.
+MR. GOLDBERGER: Good morning, Your Honor. Jack.
+6
+7
+Goldberger on behalf of Mr. Epstein.
+THE COURT: I see we have some representatives from
+8
+the United States Attorney's Office here.
+Good morning, Your Honor.
+9
+10
+11
+12
+13
+MS.
+for the U.S. Attorney's office.
+THE COURT: Good morning.
+Who else do we have on the phone?
+MR. CRITTON: Your Horor, we have two members of the
+14 defense team are on the phone, also.
+15
+THE COURT: Who do we have on the phone?
+16
+MR. WEINBERG: Martin Weinberg. Good morning, Your
+17| Honor.
+18
+MR. LEFKOWITZ: Jay Lefkowitz. Good morning, Your
+19| Honor.
+20
+THE COURT: Good morning.
+I scheduled this hearing for very limited issues
+21
+22
+23
+24
+25
+which, as you all know, there's been a motion by Mr. Epstein to
+stay the civil proceedings against him. The one issue I have
+concern about is Mr. Epstein's contention or assertion that by
+defending against the allegations in the civil proceedings, he
+
+
+5
+I may expose himself to an allegation by the United states in the
+non-prosecution agreement that he's violated that agreement and
+3
+therefore would subject himself to potential federal charges.
+4
+I had asked for some briefing on this. I asked the
+5
+United States to present its position to me. And I received
+6
+the Government's written response, which I frankly didn't find
+71 very helpful. And I still am not sure I understand what the
+8
+9
+Government's position is on it.
+So first let me hear from Mr. Epstein's attorneys as
+10
+to what do you believe the concern is. I don't believe the
+11
+non-prosecution agreement has ever been filed in this Court; am
+12
+I correct?
+13
+14
+MR. CRITTON: Io my knowledge, Your Honor, it has not.
+THE COURT: So I don't believe I've ever seen the
+15
+entire agreement. I've seen portions of it.
+16
+MR. EDWARDS: Your Honor, I believe that it was filed.
+17
+under Jane Doe 1 and 2 vs. United States of America, case under
+18| seal in your court.
+19
+THE COURT: Okay.
+20
+MR. EDWARDS: In a separate case.
+THE COURT: In that case, okay. Was it actually filed
+21
+23
+24
+25
+22 in that case?
+MR. EDWARDS: I filed it under seal.
+THE COURT: In any event, what's Mr. Epstein's concern
+about if you defend the civil actions, you're going to expose
+
+
+yourself to a claim for a breach by the United States of the
+2
+non-prosecution agreement?
+MR. CRITTON: Robert Critton.
+4
+Your Honor, our position on this case is, I'd say is
+5
+somewhat different.
+When this issue originally came before the
+6
+Court, as you are aware prior to my firm's involvement in the
+7
+case, there was a motion filed on behalf of Mr. Epstein seeking
+8
+a stay. And I think it was in Jane Doe 102 and then
+9
+subsequently Jane Doe 2 through 5 because all of those cases
+were filed on or about the same time.
+11
+And at that time the Court looked at the issue and it
+12
+was based upon a statutory provision at that time. And the
+13
+Court said I don't find that it's applicable, or for whatever
+14
+reason I think the Court said I don't consider that to be a
+15
+pending proceeding or a proceeding at that particular time.
+16
+17
+In that same order, which was in Jane Doe 2, I
+believe it's -- not I believe, I know it's docket entry 33, the
+18
+Court also went on to talk about at that particular point in
+19
+time dealt with the issue of the discretionary stay.
+20
+And the Court said at that time, I'm paraphrasing, but
+21
+the Court also does not believe a discretionary stay is
+22
+warranted. And what the Court went on to say is that if
+23
+defendant does not breach the agreement, then he should have no
+24
+concerns regarding his Fifth Amendment right against
+25
+self-incrimination.
+
+
+1
+The fact that the U.S. Attorney or other law
+2
+enforcement officials may object to some discovery in these
+3
+civil cases is not in and of itself a reason to stay the civil
+4
+5
+litigation, so that any such issue shall be resolved as they
+arise in the course of the litigation.
+6
+And I would respectfully submit to the Court that the
+position that the Government has taken in its most recent
+8
+filings changes the playing field dramatically. Because what
+9
+the Government in essence has said as distinct from the U.S.
+10
+saying is,
+well, we object to some discovery, or we may object
+11
+to some discovery in the civil cases.
+12
+What they have, in essence, said is if you take some
+13
+14
+action, Mr. Epstein, that we believe unilaterally, and this is
+on pages 13 and 14 of their pleading or of their response memo
+15
+to the Court's inquiry, they say if Mr. Epstein breaches the
+16
+agreement. They said it's basically like a contract, and if
+17
+18
+one side breaches, the other side can sue.
+In this instance what the Government will do is if we
+19 believe that Mr. Epstein has breached the agreement, we '11
+20
+indict him. We will indict him. And his remedy under that
+21
+circumstance, which is an incredible and catastrophic catch 22
+22
+is, we'll indict him and then he can move to dismiss. That's a
+23
+great option.
+24
+In this particular instance my mandate in defending --
+25
+and that's a dramatic change in the Government's position,
+
+
+1
+because the Government is not saying, and the Court was pretty
+2
+specific in what you asked the Government for in its response
+3
+is, in essence, and it's the same question in a more limited
+4
+fashion you're posing today is whether Mr. Epstein's defense of
+5
+the civil action violates the NPA agreement, the
+6
+non-prosecution agreement, between the U.S. and Mr. Epstein.
+7
+And the Government refuses to answer that question.
+8
+9
+They won't come out and say, yes, it will, or no, it won't.
+What they're doing is they want to sit on the sideline, and as
+10
+11
+their papers suggest is, they want us to lay in wait and that
+if, in fact, they believe he violates a provision of the NPA as
+12
+it relates to the defense of this case or these multitude of
+13
+cases, then they can come in and indict him -- no notice, no
+14
+opportunity to cure.
+15
+We don't think that's what the NºA says, but that's
+16
+certainly what their papers say. We'll indict him, no notice,
+17
+no opportunity to cure. We will indict him, and his remedy
+18 under that circumstance is that he can move to dismiss the
+19| indictment.
+20
+Well, that's great except Mr. Epstein, his mandate to
+21
+22
+me and I know his mandate to his criminal lawyers, is: Make
+certain I don't do anything, in particular in these civil cases
+23
+that would in any way suggest that I am in willful violation of
+24 the NPA.
+25
+Now, in the Court's prior ruling in the docket entry
+
+
+1 33, certainly some aspects of the NP are within MI. Epstein's
+2
+control. There's no question about that: But aspects that
+3
+relate to the defense of these cases, either in terms of the
+4
+5
+civil lawyers who are defending these, I think there's 12 or 13
+pending cases in front of you, there's another four cases in
+the state court, is the risk is substantial, it's real, and it
+presents a chilling effect for the civil lawyers in moving
+8
+9
+forward to determine whether or not we're taking some action
+that in some way may be a violation of the NPA.
+10
+And the Government's, again, refusal or non-position
+11
+with regard to past acts that have been taken in the civil case
+12
+with regard to the defense or future acts that we may take with
+13
+regard to these contested litigation casts an extraordinary
+14
+cloud of doubt and uncertainty and fear that the defense of
+15
+these cases could jeopardize MI. Epstein and put him in the
+16
+irreparable position of violating the NPA and then subsequently
+17
+being indicted.
+18
+In this particular instance, again, Mr. Epstein has no
+19| intention of willfully violating the NPA, but it's of great
+20
+concern to him. And I'd say with the position that the
+21
+Government has taken, no notice, no cure period, no opportunity
+22
+to discuss. Again, we think that's not what the NPA provides,
+23
+it's not what the deal was between the two contracting parties,
+24 ฿
+the United States and Mr. Epstein. But that's clearly what
+25
+their papers say under the circumstances, and it would create
+
+
+10
+1
+this irreparable harm to Mr. Epstein under the circumstances.
+2
+3
+In essence, we're left with a catch 22 in defending
+the civil cases. We have a mandate to take no action, to take
+4
+any action which may be deemed to be a violation of the NPA,
+5
+either in the past or in the future, which would in any way
+6
+risk Mr. Epstein being indicted by the United States.
+7
+He has the clear risk of an indictment based upon the
+8
+9
+papers that the Government filed. It's real, it's not remote,
+and it's not speculative. It chills the action of the defense
+10
+11
+in this instance of both Mr. Epstein and his attorneys in
+trying to defend these cases and decide under the circumstances
+12
+can we do this, can we take this position with regard to
+13
+depositions, can we take this legal position with regard to
+14
+motions to dismiss, with regard to responses, with regard to
+151
+replies?
+16
+And we send out paper discovery. Is this in some way
+17
+if we contact someone who may be an associate of these
+18 individuals as part of our investigation, is that potentially
+19 | in any way a violation of the NPA? Again, we don't think so.
+20
+And, obviously, again, my direction has been from my
+21
+client: Don't take any action that would result in me being
+22฿
+23
+indicted under the NPA. Well, that's great. But, generally,
+civil lawyers or civil lawyers in defending a personal injury
+24 case or a tort case, which is exactly what these are, and from
+25
+a practical standpoint, we use various tools to do discovery.
+
+
+11
+They're standard. They're specific. They're very temporary.
+2
+Very typical.
+3
+But in this instance, as the Court knows, things are
+4
+not typical with regard to this case in any way, shape or form.
+5
+We can't even serve subpoenaes, there's objections and there's
+6
+-- we can't even serve objections to third parties so we can
+7'
+obtain documents unless we have to filter it through the
+8
+plaintiffs' attorneys. They won't allow us to use their
+9
+clients' names, even in a subpoena that would never be filed in
+10
+the court.
+11
+How do we do a deposition of a third party? We wanted
+12
+13
+to take the deposition of Jane Doe 4. Well, who is she? Well,
+we can't tell you that. Well, who's the defendant? Well, we
+14
+15
+can't tell you that because nobody wants anybody to know
+anything about the case. They want to present it strictly
+16
+through rose-colored glasses.
+17
+And in this particular instance, we simply can't
+18 defend this case or take certain action with the spector
+19
+I hanging over us that, in fact, the Government may deem it to be
+20
+21
+a violation of the NPA, because very clearly in their response
+papers, they don't say. They say we don't take the position;
+22
+and then they take a substantial position is we think there's
+23
+not all that substantial factors that would entitle him to a
+24
+stay.
+25
+Except for the one major issue which the Court posed
+
+
+12
+in the question is, is can he defend these cases? That's what
+2
+I really want to know. Can he defend these cases and, in
+3
+essence, what he has done in the past or what his defense team
+has done in the past and what they're going to do in the
+5
+6
+future, can you give him, Epstein, assurances that the
+Government under this situation, whatever he does, based on
+7 advice of counsel, that that cannot be a willful violation of
+8
+the NPA, which they can -- they, the U.S. -- can then turn
+9
+around and say that's a violation of the agreement and,
+10 ฿
+therefore, we're going to go proceed to indict you under the
+11
+circumstances.
+12
+Our position is, Your Honor, is that the U.S. has now
+13
+14
+cavalierly suggested that, as they did in picking up on the
+court's docket entry or prior order, is, look, compliance with
+15
+the NPA is solely up to Mr. Epstein. In this type of balance
+16
+of equities, it doesn't speak in favor of a stay.
+17
+Well, that's great. And maybe that was the position
+18
+back in '08, on August 5th of '08, when the issue came up in
+19 front of the Court with regard to the initial stay.
+20
+But the Government's papers under these circumstances
+21
+suggested a very different set of circumstances. Their own
+22
+unilateral, which is the issue that we argued in the motion for
+23
+stay, is that the Government's position is that we can
+24
+25
+unilaterally indict this man if we think he's breached the NPA.
+We don't think that's right, but we have no buffer
+
+
+13
+1
+between us and the Government. They'll say, and as the Court
+2
+knows, the Government has substantial power. The Government
+3
+does what it wants. Most of the time hopefully they're right.
+4
+5
+6
+Sometimes they make mistakes.
+But in this particular instance, my client has rights.
+We think that there's notice provisions, we think there's cure
+71
+provisions under the NPA. That's not what their paper says
+8
+under the circumstances.
+And what we'd like to know from the Government, and
+10
+maybe the answer is basically what the Court asks is, let the
+11
+Government come forward today and say, based on the knowledge
+12
+that we have, or as of today's date, June 12th, 2009, we, the
+13
+Government, agree that there is no set of circumstances, not
+14
+that we're not aware of, but as of today's date, there is
+15(
+nothing that exists that would be a violation of the NPA.
+16
+THE COURT: Well, that's way beyond what I'm
+17
+interested in. I don't know what Mr. Epstein may have done
+18
+outside the context of defending this case that may constitute
+19
+a violation. And if he has done something outside the context
+20
+of defending this case that's a violation, I don't care.
+21
+That's between the United States and Mr. Epstein.
+22
+I'm only concerned about whether anything he does in
+23
+defending these civil actions is going to be a violation of the
+24
+25
+non-prosecution agreement. If he has done something else, it's
+none of my business, and I don't care, and I'm not going to
+
+
+14
+1
+even ask the Government to give you an assurance that he hasn't
+2
+done anything that might have violated the agreement up till
+3
+today. I'm only interested in defending these civil actions.
+4
+MR. CRITTON: Then I would respectfully submit to the
+5
+Court that the Government be asked in that limited context, are
+6
+they as of today, whether there were or not, but as of today is
+there anything that has been done or will you take the
+8
+9
+position, the United States, that any position that MI. Epstein
+has taken with regard to defending these civil cases is in any
+10
+way a violation of the NPA?
+11
+THE COURT: Well, I'm not sure what they're going to
+12
+13
+say, but that might -- that cures the problem up to this point.
+But then we have to deal with what's going to happen from here
+14
+on in. And that's another issue that we have to deal with.
+15
+So I understand your position.
+16
+But has anyone suggested to you on behalf of the
+17
+United States that there is something that you've done in
+18 defending this case that they believe may or could be construed
+19
+20
+as a violation of the non-prosecution agreement? Has anyone
+pointed to anything that you've done?
+For example, the fact
+21
+22
+23
+24
+that you've wanted to take their -- I don't know if you've
+noticed depositions or not in this case, but if you've sent
+notice of taking deposition, if you sent requests for
+production of documents, if you sent interrogatories, if you
+25
+issued third party subpoenas? Is anything you've done thus far
+TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION.
+
+
+15
+1
+in the context of this case been brought to your attention as a
+2
+potential violation?
+3
+MR. CRITTON: I have received no notification nor am I
+4
+aware that we've received any notification of any action that
+5
+6
+we have taken today. As I suggested to the Court, I don't know
+when they've done or not. And in their papers they suggested,
+7
+well, we don't know everything that's gone on in the civil
+8
+litigation.
+9
+But from a practical standpoint, it was a number of
+comments that were made in their papers is, we can indict, we
+11
+12
+13
+can see if there's a breach.
+Judge, I may have some --
+THE COURT: Before you go on.
+14
+MR. CRITTON: I'm sorry.
+THE COURT: You've focused a great deal on the
+15
+16 Government's response to my inquiry as supporting your position
+17
+that you're in jeopardy. But you've made the suggestion, even
+18 before this brief was filed, that defending the case was going
+19
+to potentially result in an assertion or allegation that you
+20
+21
+breached the non-prosecution agreement.
+So what was it' that caused you to make that initial
+22
+assertion? Because that's what caught my attention, was not --
+23
+24
+this brief that the Government has filed was in response to
+something that you filed initially in your most recent motion
+25
+for a stay which raised the issue.
+
+
+16
+1
+So what was it that gave you some concern to even
+2
+raise the issue that defending this case is going to constitute
+3
+a breach?
+4
+MR. CRITION: Because there are other instances where
+5
+counsel other than myself, not in the civil aspects, where
+6
+allegations have been made and letters have been sent by the
+7 United States suggesting that there's been a violation of the
+8
+NPA. And under those circumstances, some notification was
+9
+provided.
+10
+THE COURT: Did it have anything to do with defending
+11
+the civil actions?
+12
+MR. CRITTON: It did not.
+13
+THE COURT: So then why was that issue raised by you
+14 in the first instance?
+15
+MR. CRITTON: Because of the prospect that the
+16 defendant could take, that the U.S. would take the position
+17"
+under the circumstances that a position that we took with
+18
+19
+regard to the contested litigation may well impact, that the
+Government may have a very different view of what the
+20
+interpretation of the agreement is.
+21
+And as an example is a number of the parties, and I
+22| know the Court doesn't want to get into a discussion, the issue
+23
+is, is under 2255 is that from the defendant's perspective the
+24
+25
+deal that was cut on that, it was a very specific deal. It
+dealt with both consensual and contested litigation. It dealt
+
+
+17
+with a secret list of individuals who we had no idea who was on
+2
+the list, and a commitment that he would under certain
+3
+circumstances be required to pay a minimum amount of damages,
+4
+which our position is under 2255 based upon the statute that
+5
+7
+was in effect at the time, a $50,000 as to anyone who wanted --
+on the list and met certain criteria.
+who came forward who was
+The position that now has been asserted by a number of
+8
+9
+the plaintiffs under the circumstances, and it's been pled, and
+actually a number of the complainants is, is Epstein agreed,
+10
+and they cite to a letter that was sent by Ms.
+from
+11
+the Government, that says he has to plead guilty or he can't
+12
+contest llability. That may be true under very, very limited
+13
+14
+or specific circumstances.
+But what the plaintiffs have done in a number of the
+15
+16
+cases, and these are pending motions, is they've said is, well,
+cases is a good example, they've pled 30
+17
+we think
+separate counts of 2255 alleged violations. And they're saying
+18
+19
+20
+under the circumstances is, therefore, we have 2255 violations,
+there's 30 of them, so 30 times 150, or should be, or whether
+it's 150, that's the amount of money that we want, so maybe $15
+21
+22
+million, or whatever the number is.
+Some of the
+other plaintiffs' lawyers have been even
+23
+24
+more creative. They've said is, well, we'll agree that it's
+only one cause of action but that each number of violations;
+25
+that is, if 20 alleged incidents occurred, that we would
+
+
+18
+consider to be, or that we will argue are violations, then we
+2
+can take 20 times the 50, or the 150, depending on which
+3
+statute is applicable.
+4
+So the Government under that set of circumstance could
+5
+6
+say, and, again, this is one of the reasons that we raised it,
+they could say, look, our deal with you was that you couldn't
+7
+contest liability, that you were waiving liability, or your
+8
+ability to contest an enumerated offense under 2255.
+9
+Again, part of the deal was
+as to an enumerated
+10
+offense. Okay. Well, what's that mean? What did he plead to?
+11
+12
+Well, he really didn't plead to anything, which is another
+issue associated with the 2255. But if the Government comes in
+13
+and says, no, wait a minute, our position was, is that you're
+14
+stuck with 2255 and the language within the NPA. And,
+15
+therefore, whether it's an offense or whether it's multiple
+16
+offenses or violations or each one represents an individual
+17
+cause of action, if the Government takes the position that's
+18
+adverse to what we think the clear reading of the agreement was
+19฿
+under those circumstances, they could claim a violation.
+20
+And as a result -- and that's one of the reasons we
+21
+put -- that was the most glaring one to us, so we raised that
+22
+issue. And then when the Government's response came with
+23
+regard to, is we can just proceed to indict if we think that
+24
+25
+there's been a breach of the agreement.
+That puts us at substantial risk and chills our
+
+
+19
+1
+2
+ability to move forward. Thank you, Your Honor.
+THE COURT: Thank you. Who wants to be heard from the
+3
+plaintiffs first?
+4
+Is there any plaintiff's attorney who is contending
+5
+that the defense of these civil actions by Mr. Epstein is going
+6
+7
+to constitute a breach of the non-prosecution agreement?
+MR. JOSEFSBERG: Your Honor, this is Bob Josefsberg.
+8
+May I speak?
+9
+10
+THE COURT: Yes, sir.
+MR. JOSEFSBERG: We're not quite confident that any
+11
+12
+13
+breaches of any agreement, which were third-party
+beneficiaries, should be resolved by you. We're not saying it
+shouldn't. But we have not raised any breach of agreement. We
+14
+15
+think that is between the United States and Mr. Epstein.
+What I find incredulous and disingenuous is that
+16 Mr. Epstein is saying that he wants a stay because he may be
+17
+forced into taking actions in the defense of this case that
+18 would violate the agreement.
+19
+And let me make our position clear on that. If he
+20
+wants to move to take depositions, interrogatories, production,
+21
+22
+and they are according to your rulings appropriate, not
+invasive of the privacy of someone, and they are relevant, then
+23
+I don't know how those could in any way be violations of the
+agreement.
+25
+What I find hypocritical is that there are two parts
+
+
+20
+I to the agreement that I am a beneficiary of. One of them is
+2
+that he has agreed that on any action brought in the 2255, he
+3
+will admit to liability.
+4
+And I received on May 26 a motion to dismiss, which
+5
+6
+we're prepared to respond to and disagree with, but totally
+contesting liability, saying that the statute doesn't apply
+because the girls are no longer minors and saying, and this is
+8
+the great one, saying that the predicate of the conviction
+9
+10
+11
+under 2255 has not been satisfied.
+Now, the understanding that I have is the agreement
+between the Government and Mr. Epstein was that the Government
+12
+13
+desired to see these victims made whole, and wanted them to be
+in the same position as if Mr. Epstein had been prosecuted and
+14
+pled or convicted. And they would be able to have the
+15
+16
+predicate of that criminal conviction, which just as a matter
+of liability would just be introduced as proof that he's done
+17
+this.
+18
+19
+They, under the agreement, are supposed to admit to
+liability on limited something that's under 2255. He has
+20
+21
+filed, but since there is no conviction, there can be no civil
+suit under 2255, with which we disagree. But it is totally in
+22 opposite of the NPA.
+23
+The second part is there are many young ladies, and
+24 this perhaps he can use this to his great advantage, who are
+25
+humiliated about this entire situation. Some of them won't
+
+
+21
+come forward.
+2
+3
+We were appointed by Judge
+as a Special Master
+to represent these young ladies. And some of them don't even
+4
+want to file suit. They don't even want to be known as Jane
+5
+Doe 103. They don't want any of the risks for these motions
+6
+that are pending.
+7
+And part of the agreement was that if we represented
+8
+9
+them and they settle, Mr. Epstein would pay our fees. And he
+has written us as of yesterday that he is under no obligation
+10
+11
+12
+to pay our fees on settling cases.
+Now, those two matters, I believe, may be breaches.
+But I am not asking this Court at this time to do anything
+13
+14
+about them. Nor am I telling the Government, I'm not running
+to the Government and saying indict him because I want you to
+15
+16
+pressure him to do what he agreed to.
+I'm a third-party beneficiary for that agreement, and
+17
+I may move to enforce certain parts of it. But as far as the
+18
+issue of staying the litigation, that is the exact opposite of
+19) the intent and the letter of the NPA. The purpose of the NPA
+20
+was so that these 34 young ladies, these victims who have been
+21
+22
+severely traumatized, may move on with their lives.
+And to stay this action would be the exact opposite of
+23
+the purpose of that agreement and would be horrible
+24
+psychologically for all of my clients.
+25
+THE COURT: Mr. Josefsberg, I understand your
+
+
+22
+position. And I don't want to argue the merits of whether a
+2
+stay should or should not be granted.
+3
+I'm just trying to understand what the ground rules
+4
+are going to be if I grant a stay or if I deny a stay. And
+5
+I've already denied a stay once. I have to decide this current
+6
+motion, and I just want to know what is going to happen if I
+7
+deny the stay in terms of Mr. Epstein's exposure under the
+8
+non-prosecution agreement. That's my concern.
+9
+So if you're telling me that you're not going to urge
+10
+the United States, on behalf of any of your clients, to take
+11
+the position that he's breached the agreement because he's
+12
+taking depositions, because he's pursuing discovery, because
+13
+he's conducting investigations that anyone in any other type of
+14
+civil litigation might conduct with respect to plaintiffs that
+15
+are pursuing claims against a defendant, that those typical
+16
+types of actions, in your judgment, are not breaches of the
+17
+agreement and that he can go forward and defend the case as any
+18 ฿
+other defendant could defend, and you're not going to run to
+19
+the United States and say, hey, he's breaching the agreement by
+20
+taking depositions and he's breaching the agreement by issuing
+21
+subpoenas to third parties in order to gather information
+22
+necessary to defend, then I don't have a problem. But if he's
+23
+going to be accused of breaching the agreement because he sends
+24
+out a notice of deposition of one of your clients, how is he
+25
+supposed to defend the case?
+
+
+1
+MR. JOSEFSBERG: Your Honor, you're totally correct.
+2
+He can depose my client. That's not a problem. But the
+3
+problem is that these are not typical clients and this is not a
+4
+typical case. He has written in his pleadings that he wants to
+5
+publish the names of these girls in the newspapers so that
+6
+other people may come forward to discuss their sexual
+7
+8
+activities with these different plaintiffs. That's not your
+typical case. But are rulings that you'll make in this case,
+and they're not part of the NPA.
+10
+As far as my going to the Government is concerned, I
+11
+12
+find it very uncomfortable for me to use the Government to try
+to pursue my financial interest in litigation. And I know that
+13
+14
+15
+16
+17
+18
+19
+20
+Mr. Epstein and his counsel will make much ado about it. So I
+am not going to be running there.
+However, if they start taking depositions regarding
+liability, I will consider that to be a breach because they're '
+supposed to have admitted liability.
+THE COURT: But, again, I don't have the agreement and
+I don't remember reading the agreement. But what I'm being
+told is the part of the agreement that admits liability is only
+21
+as to a 2255 claim, and there are numerous other personal
+22฿
+injury tort claims other than 2255 claims.
+And there's a limit of damages on the 2255 claim, as I
+23
+24l
+understand it, but I presume that all the plaintiffs are going
+25
+to seek more than the limited or capped amount of damages in
+
+
+24
+the non-prosecution agreement as to the other claims.
+2
+And so why aren't they entitled to defend and limit
+3
+the amount of damages that your client is seeking on the
+4
+non-2255 tort claims?
+5
+6
+MR. JOSEFSBERG: Your Honor, you are correct. On
+non-2255 tort claims, they are permitted to do the defense,
+whatever is appropriate.
+8
+My cases are pure 2255 on which liability under the
+9
+agreement is supposed to be admitted. Now, as to the amount of
+10
+damages, there are legal issues that will be before you and
+11
+under the
+cases that are getting before you, as to.
+12
+whether it is 50 or 150. That has nothing to do with the NPA.
+13
+There are legal issues that are before you as to
+14
+15
+whether it is per statute, per count or per incident or per
+plaintiff. Those have nothing to do with the NPA. There is no
+16 amount in NPA. Those will be resolved.
+17
+Anyone who has brought a case that is outside of 2255,
+18 the defense 1s permitted to contest liability under the NPA.
+19| That's no violation.
+20
+Under the NPA if someone brought a case under just
+21
+2255, Mr. Epstein, if he is to keep his word, cannot contest
+22
+23
+liability. And there would no need to stay this. Because it
+is a self-fulfilling agreement.
+He can contest liability. And
+24.
+as far as the amount of damages, anyone that wants to go over
+25
+the statutory minimums, of course, he can contest that in any
+
+
+25
+1 1
+way that is proper under the Rules of Evidence and your
+2
+rulings. The NPA has no limitation on his contesting damages
+3
+above the minimum statutory amount.
+4
+The only thing that he has done is in his actions of
+5
+refusing to pay for settling defendants, and in his saying that
+6
+he has no liability under 2255, those appear to be contrary to
+what's in the NPA.
+8
+But I'm not in any position right now to claim a
+10
+breach, and I don't know whether I'd be claiming a breach or
+enforcing it in front of you, suing him for fees, asking you to
+11
+have him admit liability, or complaining to the Government.
+12
+And that's why I'm not that helpful in this situation because I
+13
+think it's the Government's role.
+14
+But I do not waive the right to be a third-party
+15
+16
+beneficiary because pursuant to my appointment, which was
+agreed to by Mr. Epstein, I and my clients have certain rights,
+17
+and we want to enforce them.
+18
+But his defending this lawsuit will not in any way be
+19| a violation, His getting this lawsuit stayed would be a
+20
+violation of the spirit of taking care of these girls, and
+21 there would be other issues. Like if there is a stay, Your
+22 Honor, would he be posting a bond?
+23
+THE COURT: We don't need to talk about those issues.
+24 That's not my concern.
+25
+MR. JOSEFSBERG: I agree, Your Honor, we don't.
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+17
+18
+20
+21
+22
+23
+25
+THE COURT: That's not my concern. So, again, I just
+want to make sure that if the cases go forward and if
+Mr. Epstein defends the case as someone ordinarily would defend
+a case that's being prosecuted against him or her, that that in
+and of itself is not going to cause him to be subject to
+criminal prosecution.
+MR. JOSEESBERG: I agree, Your Honor.
+THE COURT: Any other plaintiff's counsel want to
+chime in?
+MR. WILLITS: Richard Willits on behalf of
+.. •
+I
+would join, to weigh in on what MI. Josefsberg said.
+MR. JOSEFSBERG: Your Honor, I could not hear.
+THE COURT: We'll get him to a microphone.
+Mr. Willits is speaking.
+MR. WILLITS: On behalf of my client,
+• we join
+16, in what Mr. Josefsberg said, and we also want to point out
+something to the Court.
+First, we want to make a representation to the Court,
+19 we have no intention of complaining to the U.S. Attorney's
+Office, never had that intention, don't have that intention in
+the future, but, of course, subject to what occurs in the
+future.
+I want to point out to the Court that Mr. Epstein went
+241 into this situation with his eyes wide open, represented by
+counsel, knowing that civil suits had to be coming. If he
+
+
+27
+2
+3
+4
+5
+6
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+didn't know it, his lawyers knew it.
+He appears to be having second thoughts now about he
+could have negotiated this way or he could have negotiated that
+way with the U.S. Attorney's Office. And they want to impose
+their second thoughts on the innocent plaintiffs. We don't
+think that's fair. We think it's in the nature of invited
+erIor, if there was any error whatsoever.
+Thank you.
+THE COURT: You agree he should be able to take the
+ordinary steps that a defendant in a civil action can take and
+not be concerned about having to be prosecuted?
+MR. WILLITS: Of course. And we say the same thing
+Mr. Josefsberg said. It's all subject to your rulings and the
+direction of this Court as to what is proper and what is not'
+proper. And we're prepared to abide by the rulings of this.
+Court, and we have no intention of running to the State's
+Attorney.
+21
+22
+23
+24
+25
+THE COURT: The U.S. Attorney?
+MR. WILLITS: I'm sorry. The U.S. Attorney.
+THE COURT: MI. Garcia.
+MR. GARCIA: Thank you, Your Honor.
+If I may briefly, I think perhaps defense counsel
+forgot about this, but on pages 17 and 19 of my memorandum of
+Law in opposition to the motion to dismiss, I did make
+reference to the non-prosecution agreement, and I did say that
+
+
+28
+the contesting of the jurisdiction of this Court was a
+2
+3
+potential breach of the non-prosecution agreement.
+So my client happens to have, and they have filed with
+4
+5
+the Court a copy of her state court complaint, given the fact
+that the non-prosecution agreement limits the non-contesting of
+6
+jurisdiction to claims exclusively brought under the federal
+7
+statute.
+8
+I'm going to go ahead and withdraw those contentions
+9
+10
+on pages 17 and 19 of my memo of law because it doesn't apply
+to my case. So to the extent that I raised this issue with
+11
+defense counsel and the Court, I'm going to withdraw that
+12
+aspect of it.
+13
+THE COURT: Can you file something in writing on that
+14 point with the Court?
+15
+MR. GARCIA: Yes.
+16
+THE COURT: What do you say about this issue that
+17
+we're here on today?
+18
+MR. GARCIA: I think that the problem that I have with
+19 it is that this non-prosecution agreement is being used by
+20
+defense counsel for the exact opposite purpose that it was
+21
+intended. My perception of this thing, and I wasn't around, is
+22, that Mr. Epstein essentially bought his way out of a criminal
+23
+prosecution, which is wonderful for the victims in a way, and
+24
+wonderful for him, too.
+25
+Now he's trying to use the non-prosecution agreement
+
+
+29
+as a shield against the plaintiffs that he was supposed to make
+2
+restitution for.
+3
+And, certainly, he can take my client's depo. He's
+4
+done extensive discovery in the state court case -- very
+5
+intrusive, I might add. And we don't care, because we can win
+6
+this case with the prosecution agreement or without the
+7 prosecution agreement. We are ready to go forward.
+8
+THE COURT: You're not going to assert to the United
+9
+States Government that what he's doing in defending the case is
+10
+a violation for which he should be further prosecuted?
+11
+12
+MR. GARCIA: Absolutely not.
+THE COURT: Anyone else for the plaintiffa?
+13
+MR. HOROWITZ: Judge, Adam Horowitz, counsel for
+14
+15
+plaintiffs Jane Doe 2 through 7.
+I just wanted to address a point that I think you've
+16
+articulated it. I just want to make sure it's crystal clear,
+17
+which is that we can't paint a broad brush for all of the
+18
+cases.
+19
+The provision relating to Mr. Epstein being unable to
+20
+contest liability pertains only to those plaintiffs who have
+21
+chosen as their sole remedy the federal statute. My clients,
+22
+Jane Doe 2 through 7, have elected to bring additional causes
+23
+of action, and it's for that reason we were silent when you
+24
+said does anyone here find Mr. Epstein to be in breach of the
+25
+non-prosecution agreement. That provision, as we understand
+
+
+30
+1 It, it doesn't relate to oux clients.
+2
+THE COURT: Okay. But, again, you're in agreement
+3
+with everyone else so. far that's spoken on behalf of a
+plaintiff that defending the case in the normal course of
+conducting discovery and filing motions would not be a breach?
+MR. HOROWITZ: Subject to your rulings, of course,
+5
+6
+> yes.
+8
+9
+THE COURT: Thank you.
+Anyone else have anything to say from the plaintiffs?
+if you would be so kind as to maybe
+10
+Ms.
+11
+help us out. I appreciate the fact that you're here, and I
+12
+know you're not a party to these cases and under no obligation
+13
+to respond to my inquiries. But as I indicated, it would be
+14|
+helpful for me to understand the Government's position.
+15
+Thank you, Your Honor. And we, of
+16
+17
+MS.
+course, are always happy to try to help the Court as much as
+possible. But we are not a party to any of these lawsuits, and
+18
+in some ways we are at a disadvantage because we don't have
+19
+20
+access. My access is limited to what's on Pacer. So I don't
+really know what positions Mr. Epstein may have taken either in
+21
+correspondence oi in discovery responses that aren't filed in
+22
+the case file.
+23
+But your first order was really just what do you think
+24
+about a stay, and then the second order related to this hearing
+25
+and asked a much more specific question, which is whether we
+
+
+31
+believe that Mr. Epstein's defense was a breach of the
+agreement.
+2
+3
+And I've tried to review as many of the pleadings as
+4
+5
+possible. As you know, they're extremely voluminous. And I
+haven't been through all of them. But we do believe that there
+6
+has been a breach in the filing that Mr. Josefsberg referred
+7
+8
+to, and contrary to Mr. Critton, we do understand that we have
+an obligation to provide notice, and we are providing notice to
+9
+Mr. Epstein today.
+10
+The pleading that we found to be in breach -- the
+11
+12
+13
+non-prosecution agreement, sought to do one thing, which was to
+place the victims in the same position they would have been if
+Mr. Epstein had been convicted of the federal offenses for
+14
+15
+which he was investigated.
+And that if he had been federally prosecuted and
+16
+convicted, the victims would have been entitled to restitution,
+17
+18
+regardless of how long ago the crimes were committed,
+regardless of how old they were at the time, and how old they
+19 are today, or at the time of the conviction.
+20
+And it also would have made them eligible for damages
+21
+under 2255.
+22
+And so our idea was, our hope was that we could set up
+23
+a system that would allow these victims to get that restitution
+24
+without having to go through what civil litigation will expose
+25
+them to.
+
+
+32
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+You have a number of girls who were very hesitant
+about even speaking to authorities about this because of the
+trauma that they have suffered and about the embarrassment that
+they were afraid would be brought upon themselves and upon
+their families.
+So we did through the non-prosecution agreement tried
+to protect their rights while also protecting their privacy.
+So, pursuant to the non-prosecution agreement -- on the other
+hand, we weren't trying to hand them a jackpot or a key to a
+bank. It was solely to sort of put them in that same position.
+So we developed this language that said if -- that
+provided for an attorney to represent them. Most of the
+victims, as you know from the pleadings, come from not wealthy
+circumstances, may not have known any attorneys who would be in
+a position to help them.
+So we went through the Special Master procedure that
+resulted in the appointment of MI. Josefsberg, and the goal was
+that they would be able to try to negotiate with Mr. Epstein
+19"
+for a fair amount of restitution/damages. And if Mr. Epstein
+20
+took the position, which apparently he has, which is that the
+21
+$50,000 or $150, 000 floor under 2255 also would be a cap. That
+22 if they were to proceed to file suit in Federal Court to get
+23
+fair damages under 2255, Mr. Epstein would admit liability, but
+24
+he, of course, could fight the damages portion, which means
+25
+that, of course, he would be entitled to depositions; of
+
+
+33
+1
+course, he would be entitled to take discovery, and we don't
+2
+believe that any of that violates the non-prosecution
+3
+agreement.
+4
+The issue with the pleading that he filed, the motion
+5
+to dismiss the case, I believe it's Jane Doe 101, represented
+6
+by MI. Josefsberg, is that that is a case that was filed
+7
+exclusively under 18 U.S.C., Section 2255. She met that
+8
+requirement. Mr. Epstein is moving to dismiss it, not on the
+9
+10
+11
+basis of damages, he is saying that he cannot be held liable
+under 2255 because he was not convicted of an offense.
+The reason why he was not convicted of an offense is
+12
+because he entered into the non-prosecution agreement. So that
+13
+14
+we do believe is a breach.
+The issue really that was raised in the motion to stay
+15
+and that I addressed in our response to the motion to stay is
+16
+that Mr. Epstein's -- Mr. Epstein wants to stay the litigation
+17
+in order to leave, in order to sort of attack the cases of the
+18
+victims whether they are fully within the non-prosecution or
+19 not, non-prosecution agreement or not, and leave the Government
+20-
+without a remedy if he does, in fact, breach those terms. And
+211
+that is why we opposed the stay.
+22
+THE COURT: I'm not sure what you mean by that last
+23
+24
+statement.
+Well, because this issue related to
+25
+MS.
+the motion to dismiss on Mr. Josefsberg's client came up after
+
+
+34
+we had filed that response. And what we said in the response
+2
+to the motion to stay is that the reason why he wants to stay
+3
+the litigation is so that the non-prosecution agreement
+4
+terminates based on a period of time, as he puts it. And then
+5
+afterwards he would be able to come in here and make all of
+6
+these arguments that clearly violate the non-prosecution
+8
+agreement but we would be without remedy.
+THE COURT: But you're not taking the position that
+9
+other than possibly doing something in litigation which is a
+10
+violation of an express provision of the non-prosecution
+11
+agreement, any other discovery, motion practice, investigations
+12
+13
+14
+that someone would ordinarily do in the course of defending a
+civil case would constitute a violation of the agreement?
+MS.
+No, Your Honor. I mean, civil
+15
+litigation is civil litigation, and being able to take
+16
+discovery is part of what civil litigation is about. And while
+17
+there may be, for example, if someone were to try to subpoena
+18
+19
+20
+the Government, we would obviously resist under statutory
+reasons, all that sort of stuff. But, no, Mr. Epstein 1s
+entitled to take the deposition of a plaintiff and to subpoena
+21
+records, etc.
+22
+THE COURT: And even if he seeks discovery from a
+23
+Government agency, you have the right to resist it under the
+24
+25
+rules of procedure but that would not constitute a violation,
+again unless there's a provision in the prosecution agreement
+
+
+35
+that says I can't do this?
+2
+MS.
+Correct.
+3
+THE COURT: That's your position?
+4
+MS.
+Yes.
+5
+THE COURT: Thank you.
+6
+MS. 1
+Thank you, Your Honor.
+7
+THE COURT: Mr. Critton, did you want to add anything?
+8
+MR. CRITTON: Yes, sir. Just a few responses to some
+9
+10
+of the issues that have been raised.
+The most glaring, at least from our perspective, is
+11
+12
+both Mr. Josefsberg's comments that he believes that there's a
+violation of the NPA as well as Ms.
+with regard to
+13
+Jane Doe 101.
+14
+MI. Josefsberg, while he was the attorney rep who was
+to represent a number of individuals,
+15
+selected by Judge I
+16|
+alleged victims that may have been on the list, he represents
+17
+many of them. And the type of response that was filed in 101
+18
+would probably be very similar to what we will file if he
+19| files -- and he filed 102 as well. But If he files 103, 104
+20
+and 105, or whatever number he files, we may well take that
+21
+same legal position in our motions and in our response or in
+22 reply.
+23
+And what we've been, in essence, told today is we
+24
+consider that to be a violation of the NPA under the
+25
+circumstances.
+
+
+36
+1
+2
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+102 is a perfect example that he filed is, we have
+e-mails going back and forth between the Government and my
+clients' attorneys at the time that suggested that 102 probably
+doesn't even fit within the statute of limitations.
+So under Mr. Josefsberg's argument is as well, we've
+only brought a 2255 claim. We don't care whether she's within
+or is outside the statute of limitations. Because she was on
+the list and under the circumstances, he has to admit
+liability, which we contest is under that set of circumstances
+you're stuck with it. You can fight damages if you can, but
+she's a real person and you can't raise statute of limitations.
+The other point that kind of strikes out is there's
+probably a difference. And I'm happy to provide a copy of the
+NºA or a redacted portion of the NPA which deals with the civil
+issues, which are paragraphs 7, 8, 9 and 10, and the entire
+addenda in camera for the Court to 100k at, if plaintiff's
+counsel and the Government, I guess, really, because they're
+not a party, is if they have no objection because they all have
+19
+access based on a prior court order to the non-prosecution
+20
+agreement.
+21
+So I'm happy to provide that to the Court today and
+22 ฿
+show it to counsel so that the Court can review that.
+23
+But our position with regard to the 2255 claims is
+24
+that -- there were two types of claims that could be filed, one
+25
+was consensual litigation, the second was contested litigation.
+
+
+37
+2
+And under the consensual, in essence, which Mr. Epstein did, is
+he's offered $50, 000 of the statutory minimum for that time
+3
+period to all of those individuals.
+4
+THE COURT: Can I interrupt you a second?
+5
+6
+MR. CRITTON: Yes, sir.
+THE COURT: I'm not here, and I don't believe it's my
+role to decide whether or not there is or is not a breach of
+8
+the agreement. I'm just trying to understand what the
+9
+Government's position is regarding your defending these cases.
+10
+11
+12
+Now, I'm just saying this as an example. If, for
+example, in the non-prosecution agreement there was a provision
+that said explicitly: Jeffrey Epstein shall not move to
+13
+14
+15
+dismiss any claim brought under 2255 by any victim no matter
+how long ago the allegations or the acts took place, period.
+If that was in the agreement and you filed a motion to
+16
+dismiss by someone who brought a claim, it might sound like it
+17
+18
+might be a violation.
+MR. CRITTON: I agree.
+19
+THE COURT: So you would know that when you filed your
+20 motion because it was right there for you to read.
+21
+And so to stay the case because I want to do something
+22
+23
+24
+25
+that the contract expressly prohibits me from doing, so stay
+the case until the agreement expires so then I can do something
+that the agreement said I couldn't do so you won't be in fear
+of prosecuting, I'm not sure that that is what I'm concerned
+
+
+38
+about.
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+I'm concerned about discovery, investigation, motion
+practice, that's not prohibited by a provision of the
+agreement. If there's something that's prohibited by the
+agreement that you, knowing what the agreement says, go ahead
+and do, anyway, I guess that's a risk you're going to have to
+take. If there's a legitimate dispute about it, I guess some
+arbiter is going to decide whether it's a breach or not.
+But, again, that's something you and Mr. Burman,
+Mr. Goldberger, and you are all very good lawyers, and he's got
+a whole list of lawyers representing him, and you've got the
+agreement and you're going to make legal decisions on how to
+proceed, and you're going to have to go and make your own
+decisions.
+I'm concerned about things that aren't in the
+agreement, that aren't covered, that you're going to be accused
+of violating because, again, you take depositions, you send out
+subpoenas, you file motions that are not prohibited by the
+agreement. And that's what I'm concerned about.
+MR. CRITTON: And I understand that, Your Honor.
+But at the same time, it's as if the lawyers and the
+clients, based upon our interpretation of the agreement, and,
+believe me, we would not have filed 101, the motion to dismiss,
+but for believing that there was a good faith basis to do that
+under the circumstances.
+
+
+1
+And now, in essence, we're being accused not only by
+2
+- not accused, but it's been suggested that there's a breach
+3
+of the NPA, not only by Mr. Josefsberg on behalf of 101, but as
+41
+well Ms.
+on behalf of the United States.
+5
+That's the perfect example. They're basically saying
+6
+we think you violated. We may send you notice under the
+7
+circumstances. So does that mean that on 101 we have to back
+8
+off of it because we think in good faith that it's a motion and
+9
+10
+is that something that this Court ultimately will rule?
+THE COURT: I don't know that I'm the one who is going
+11
+to make that decision. Again, that's not the kind of thing
+12
+that I was concerned about. I was more concerned about the
+13
+normal, ordinary course of conducting and defending a case that
+14
+would not otherwise expressly be covered under the agreement,
+15
+that you're going to then have someone say, ah, he's sent a
+16
+notice of deposition, he's harassing the plaintiffs. I don't
+17
+know if there's a no contact provision in the agreement or no
+18
+harassment type of provision in the agreement. Ah, this is a
+19| breach because you sent discovery, or he's issuing subpoenas to
+20
+third parties trying to find out about these victims'
+21
+22
+backgrounds, he's breaching the agreement.
+Those are the kind of things that I was worried about.
+23
+MR. CRITTON: The concern that we have is as part of
+24
+25
+doing this general civil litigation, it's not just the
+discovery process. And I understand the issues that the Court
+
+
+40
+1 has raised.
+2
+But part of it is that often cases are disposed of
+3
+either on a summary basis or certainly legal issues that come
+4
+before the Court during the course of the case, just like in a
+5
+criminal case. That's clearly part of the, I'd say the defense
+6
+of the case under the circumstances; and if, in fact, an
+individual can't legally bring a cause of action for certain
+8
+easons, such as has been suggested in 101, and may be
+9
+suggested in 102 when that pleading is filed, that certainly is
+10
+a position that puts my client at risk.
+11
+As another example that I use with l
+• that they
+12
+filed this 30-count complaint. Now, they have the state court
+13
+14
+claims as well. But they, In essence, have said they filed
+another pleading with the Court that says depending on what the
+15
+16
+17
+Court rules, in essence, on whether we can file multiple claims
+or one cause of action with multiple violations, we may dump
+the state court claims and, therefore, we'll just ride along on
+18| that. That's a very different --
+19
+Mr. Epstein would never have entered into, nor would
+20
+his attorneys have allowed him to enter into that agreement
+21
+under those circumstances where he had this unlimited
+22
+liability. That clearly was never envisioned by any of the
+23
+defendants -- by the defendant or any of his lawyers under the
+24
+circumstances.
+25
+And if that's claimed to be a violation, either by the
+
+
+1 attorneys; i.e., he's not recapitulating on liability under the
+2
+3
+2255, and that's all we have now. That's our exclusive remedy.
+And the Government says, yeah, that's right, that's a
+4
+violation of the NPA. It again chills us from moving forward,
+5
+filing the necessary motion papers and taking legal positions
+6
+that may put my client at risk for violating the NPA and then
+7
+creating the irreparable harm of, after having been in jail,
+8
+9
+10
+after having
+pled guilty to the state court counts, after
+registering on release as a sex offender, he's complied and
+done everything, taken extraordinary efforts to comply with the
+11
+NPA, puts him at substantial risk. And that's what our worry
+12
+is moving forward.
+13
+MR. JOSEFSBERG: Your Honor, may I be heard. May I
+14|
+make three comments? It will take less than a minute.
+15
+16
+THE COURT:
+Yes, sit.
+MR. JOSEFSBERG: Mr. Critton refers to the alleged
+17
+victims. I want you to know that our position is that pursuant
+18
+to the NPA they're not alleged victims. They are actual, real
+19
+20
+victims, admitted victims.
+Secondly, he argues about the statute of limitations
+21
+on 102. I know that you don't want to hear about that, and I'm
+22
+not going to comment about it. But please don't take our lack
+23
+24
+Of argument about this as being we agree with anything.
+Last and most important, we totally agree with
+25
+Mr. Critton in his suggestion that he hand you a copy of the
+
+
+42
+2
+3
+4
+5
+6
+NPA. I think that many of the questions you asked will be
+answered when you read the NPA, and I think it's very unfair of
+everyone who is sitting in front of you who have the NPA to be
+discussing with you whether it's being breached, whether there
+should be a stay when you're not that familiar with it.
+If we would give you a copy of it, I think it would be
+much more helpful in making your ruling.
+THE COURT: Maybe Judge Colvat will resolve this issue
+8
+9
+for me.
+10
+MR. JOSEFSBERG: Even if he doesn't, Your Honor, I
+11
+12
+believe we are allowed to show it to you.
+THE COURT: I'll tell you what: I'll wait for Judge
+13
+Colvat to rule, and then if he rules that it should remain
+14
+sealed, then I'll consider whether or not I want to have it
+15] submitted to me in camera.
+16
+Anything else, Mr. Josefsberg?
+17
+MR. JOSEFSBERG: No. I thank you on behalf of myself
+18
+and the other counsel on the phone for permitting us to appear
+19 by phone.
+20
+THE COURT: All right. Anyone else have anything they
+21
+want to add?
+22
+23
+MR. EDWARDS: Brad Edwards on behalf of Jane Doe.
+I only had one issue here, and when I read your motion
+24
+that you wanted to hear on the narrow issue of just defense in
+25
+the civil actions filed against him violates the
+
+
+non-prosecution agreement, I was expecting that we were going
+2
+to hear something from the Government similar to the affidavit
+3
+that was filed by Mr. Epstein's attorneys wherein he indicates
+4
+as of the day of this affidavit attached to the motion to stay,
+5
+the U.S. Attorney's Office has taken the position that Epstein
+has breached the non-prosecution agreement and it names
+specifically investigation by Epstein of this plaintiff and
+8
+9
+10
+11
+other plaintiffs, Epstein's contesting damages in this action.
+Epstein, or his legal representatives,
+making statements to the
+press. And we didn't hear any of those things.
+So that's what I was expecting that the U.S.
+12
+13
+Attorney's Office was going to expound on and say, yes, we've
+made some communications to Epstein. He's violating.
+14
+What we're hearing right now, today, just so that I'm
+15
+clear, and I think the Court is clear now, is that the
+161
+non-prosecution agreement is what it is. There have been no
+17
+violations, but for maybe what Mr. Josefsberg brought up.
+18
+But there are very few restrictions on Mr. Epstein.
+19| He went into this eyes wide open. And whether or not I agree
+20
+21
+with the agreement, how it came to be in the first place, is
+neither here nor there.
+22
+But there have been no violations or breaches up to
+23
+24
+25
+this point. And his affidavit that was filed, I'm just
+troubled by where it even came from. I mean, it's making
+specific allegations that the U.S. Attorney's Office is
+
+
+44
+1
+threatening a breach, and this is part of the motion to stay,
+2
+3
+4
+5
+6
+which we're all battling here.
+So I just wanted to indicate to the Court or remind
+the Court that there have been specific allegations made, the
+United States Attorney's Office is making these allegations of
+breach, which we haven't heard any of the evidence of.
+7
+Thank you.
+THE COURT: All right.
+9
+Ms.
+, did you want to respond to that
+10
+suggestion that there were other allegations of breach besides
+11
+the one that you've just mentioned today?
+12
+MS.
+: No, Your Honor.
+13
+THE COURT: Thank you. I appreciate your giving me
+14฿
+the information, which I think has been very helpful today, and
+15
+I'll try and get an order out as soon as possible.
+16
+[Court adjourned at 11:10 a.m.].
+17
+CERTIFICAI E
+18
+I hereby certify that the foregoing is an accurate
+19| transcription of proceedings in the above-entitled matter.
+20
+s/
+21
+DATE
+22
+h, RPR-CM-RMR-FCRSC
+Official United States Court Reporter
+400 N. Miami Avenue
+Miami, FL 33128 -
+(Fax)
+23
+24
+25
+email:
+Quality Assurance by Proximity Linguibase Technologies
+
+
+abide 27:15
+ability 18:8 19:1
+able 20:14 27:9
+about 4:24 5:25 6:10
+13:22 20:25 21:13
+23:13 25:23 27:2
+27:11,23 28:16
+30:24 32:2,2,3
+34:16 38:1,2,7,15
+38:19 39:12,12,20
+39:22 41:20,21,22
+above-entitled 44:19
+Absolutely 29:11
+access 30:19,19
+according 19:21
+accused 22:23 38:16
+action 7:13 8:5 9:8
+10:3,4,9,21 11:18
+15:4 17:24 18:17
+20:2 21:22 27:10
+29:23 40:7,16 43:8
+14:3 16:11 19:5,17
+22:16 25:4 42:25
+acts 9:11,12 37:14
+actually 5:21 17:9
+Adam 1:13 3:4
+29:13
+add 29:5 35:7 42:21
+addenda 36:16
+Adderly 3:17
+additional 29:22
+address 29:15
+addressed 33:15
+adjourned 44:16
+Adler 1:17
+admit 20:3,18 25:11
+32:23 36:8
+admits 23:20
+admitted 23:17 24:9
+41:19
+ado 23:13
+advantage 20:24
+adverse 18:18
+advice 12:7
+affidavit 43:2,4,23
+afraid 32:4
+after 33:25 41:7,8,8
+afterwards 34:5
+again 9:10,18,22
+10:19,20 18:5,9
+23:18 26:1 30:2
+34:25 38:9,17
+39:11 41:4
+against 4:23,25 6:24
+22:15 26:4 29:1
+agency 34:23
+ago 31:17 37:14
+agree 13:13 17:23
+25:25 26:7 27:9
+37:18 41:23,24
+agreed 17:9 20:2
+agreement 5:2,2,11
+S:15 6:2,23 7:16
+7:19 8:5,6 12:9
+15:20 16:20 18:18
+18:24 19:6,11,13
+19:18,24 20:1,10
+20:18 21:7,16,23
+22:8,11,17,19,20
+22:23 23:18,19,20
+24:1,9,23 27:25
+28:2,5,19,25 29:6
+29:7,25 30:2 31:2
+31:11 32:6,8 33:3
+33:12,19 34:3,7,11
+34:13,25 36:20
+37:8,11,15,23,24
+38:4,5,5,12,16,19
+38:22 39:14,17,18
+39:21 40:20 43:1,6
+allegation 5:1 15:19
+allegations 4:25 16:6
+37:14 43:25 44:4,5
+alleged 17:17,25
+allowed 40:20 42:11
+always 30:16
+Amendment 6:24
+amount 17:3,20
+23:25 24:3,9,16,24
+another 9:514:14
+18:11 40:11,14
+answer 8:7 13:10
+anybody 11:14
+anyone 14:16,19
+17:5 22:13 24:17
+24:24 29:12,24
+anything 8:22 11:15
+13:22 14:2,7,20,25
+16:10 18:11 21:12
+30:9 35:7 41:23
+apparently 32:20
+appear 3:1925:6
+appearances 1:12
+applicable 6:13 18:3
+apply 20:6 28:9
+appointed 21:2
+appointment 25:15
+appreciate 30:11
+appropriate 19:21
+argue 18:1 22:1
+argument 36:5
+articulated 29:16
+asked 5:4,4 8:2 14:5
+asking 21:12 25:10
+aspects 9:1,2 16:5
+assertion 4:24 15:19
+associate 10:17
+associated 18:12
+assurances 12:5
+attention 15:1,22
+Atterbury 2:12
+attorney 2:15 7:1
+19:4 27:17,18,19
+attorneys 5:9 10:10
+11:8 32:14 36:3
+40:20 41:1 43:3
+Attorney's 4:8,10
+26:19 27:4 43:5,12
+Australlan 2:12
+authorities 32:2
+Avenue 1:21,23 2:12
+aware 6:6 13:14 15:4
+B
+.. -
+back 12:18 36:2 39:7
+backgrounds 39:21
+balance 12:15
+bank 32:10
+based 6:12 10:7 12:6
+13:11 17:4 34:4
+36:19 38:22
+basically 7:16 13:10
+39:5
+basis 33:9 38:24
+40:3
+battling 44:2
+Beach 1:2,4,21 2:10
+2:13
+before 1:11 6:5
+15:13,18 24:10,11
+24:13 40:4
+behalf 3:14 4:2,6 6:7
+14:16 22:10 26:10
+26:15 30:3 39:3,4
+42:17,22
+being 9:17 10:6,21
+23:19 26:4 28:19
+29:19 34:15 39:1
+belleve 3:18 5:10,10
+5:14,16 6:17,17,21
+7:13,19 8:11 14:18
+21:11 31:1,5 33:2
+33:5,13 37:6 38:23
+believing 38:24
+beneficiaries 19:12
+beneficiary 20:1
+between 8:6 9:23
+beyond 13:16
+Biscayne 1:14
+Boehringer 1:20
+both 10:10 16:25
+Boulevard 1:14,17
+Brad 3:7 42:22
+BRADLEY 1:16
+breach 6:1,23 15:11
+16:3 18:24 19:6,13
+23:1625:9,9 28:2
+29:24 30:531:1,6
+31:10 33:13,20
+37:7 38:8 39:2,19
+breached 7:19 12:24
+15:20 22:11 42:4
+Page 45
+43:6
+breaches 7:15,17
+19:11 21:11 22:16
+43:22
+breaching 22:19,20
+22:23 39:21
+brief 15:18,23
+briefing 5:4
+briefly 27:22
+bring 29:22 40:7
+brond 29:17
+brought 15:1 20:2
+24:17,20 28:6 32:4
+36:6 37:13,16
+43:17
+Broward 2:15
+brush 29:17
+buffer 12:25
+Burman 2:8,9 4:3
+38:9
+business 13:25
+C
+C 2:1 44:17,17
+came 6:5 12:18 17:6
+18:22 33:25 43:20
+camera 36:16 42:15
+capped 23:25
+care 13:20,25 25:20
+5:22 6:4,78:12
+9:11 10:24,24.11:4
+11:15,18 13:18,20
+14:18,22 15:1,18
+16:2 19:17 22:17
+22:25 23:4,8,8
+24:17,20 26:3,4
+28:10 29:4,6,9
+30:4,22 33:5,6
+34:13 37:21,23
+39:13 40:4,5,6
+eases 3:26:9 7:3,11
+8:13,22 9:3,5,5,15
+10:3,11 12:1,2
+21:10 24:8,11 26:2
+29:18 30:12 33:17
+catastrophic 7:21
+catch 7:21.10:2
+cause 17:24 18:17
+caused 15:21
+cavalierly 12:13
+certain 8:22 11:18
+17:2,6 21:17 25:16
+certainly 8:169:1
+
+
+chills 10:9 18:25
+circumstance 7:21
+circumstances 9:25
+10:1,11 12:11,20
+12:21 13:8,13 16:8
+16:17 17:3,8,13,18
+18:19 32:14 35:25
+36:8,9 38:25 39:7
+civil 4:23,25 5:25 7:3
+7:3,11 8:5,22 9:4,7
+9;11 10:3,23,23
+13:23 14:3,9 15:7
+22:14 26:25 27:10
+31:24 34:13,14,15
+34:16 36:14 39:24
+clalm 6:1 18:19
+23:21,23 25:8 36:6
+claimed 40:25
+claiming 25:9
+claims 22:15 23:22
+23:22 24:1,4,6
+clear 10:7 18:18
+19:19 29:16 43:15
+clearly 9:24 11:20
+client 10:21 13:5
+23:2 24:3 26:15
+28:3 33:25 40:10
+clients 11:9 21:24
+22:10,24 23:3
+25:16 29:21 30:1
+come 8:8,13 13:11
+21:1 23:6 32:13
+commitment 17:2
+committed 31:17
+communications
+complainants 17:9
+complaining 25:11
+complaint 28:4
+compliance 12:14
+comply 41:10
+concern 4:24 5:10,24
+9:20 16:1 22:8
+25:24 26:1 39:23
+concerned 13:22
+23:10 27:11 37:25
+38:2,15,19 39:12
+conducting 22:13
+confident 19:10
+consider 6:14 18:1
+23:16 35:24 42:14
+constitute 13:18
+16:2 19:6 34:13,24
+construed 14:18
+contact 10:17 39:17
+contention 4:24
+contentions 28:8
+contest 17:12 18:7,8
+24:18,21,23,25
+contested 9:13 16:18
+16:25 36:25
+contesting 20:6 25:2
+context 13:18,19
+contract 7:16 37:22
+contracting 9:23
+contrary 25:631:7
+convicted 20:14
+31:13,16 33:10,11
+conviction 20:8,15
+copy 28:4 36:13
+correct 5:12 23:1
+correspondence
+counsel 3:3,4,7 12:7
+16:5 23:13 26:8,25
+27:22 28:11,20
+29:13 36:17,22
+counts 17:17 41:8
+course 7:5 24:25
+26:21 27:12 30:4,6
+30:16 32:24,25
+33:1 34:12 39:13
+court 1:1 2:22 3:1,6
+3:9,12,15,20,22,24
+5:11,14,18,19,21
+5:24 6:6,11,13,14
+6:18,20,21,22 7:6
+8:1 9:6 11:3,10,25
+12:19 13:1,10,16
+14:5,11 15:5,13,15
+16:10,13,22 19:2,9
+21:12,25 23:18
+25:23 26:1,8,13,17
+26:18,23 27:9,14
+27:16,18,20 28:1,4
+28:4,11,13,14,16
+29:4,8,12 30:2,8
+30:16 32:22 33:22
+34:8,22 35:3,5,7
+36:16,19,21,22
+37:4,6,19 39:9,10
+39:25 40:4,12,14
+40:15,17 41:8,15
+42:8,12,20 43:15
+44:3,4,8,13,16,22
+court's 7:15 8:25
+covered 38:16 39:14
+criminal 8:21 20:15
+26:6 28:22 40:5
+Critton 2:8,9 4:2,2
+4:13 5:13 6:3,3
+14:4 15:3,14 16:4
+16:12,15 31:7 35:7
+35:8 37:5,18 38:20
+39:23 41:16,25
+crystal 29:16
+cure 8:14,179:21
+17:16 24:11 26:10
+26:15 40:11
+damages 17:3 23:23
+23:25 24:3,10,24
+25:2 31:20 32:23
+32:24 33:9 36:10
+date 13:12,14 44:21
+Datura 1:21
+deal 9:23 14:13,14
+15:15 16:24,24
+deals 36:14
+dealt 6:19 16:25,25
+decide 10:11 22:5
+decision 39:11
+decisions 38:12,14
+deemed 10:4
+defend 5:25 10:11
+11:18 12:1,2 22:17
+22:18,22,25 24:2
+defendant 1:8 2:8
+6:23 11:13 16:16
+22:15,18 27:10
+defendants 25:5
+defendant's 16:23
+defending 4:25 7:24
+9:4 10:2,23 13:18
+13:20,23 14:3,9,18
+25:18 29:9 30:4
+34:12 37:9 39:13
+defends 26:3
+defense 4:1,14 8:4,12
+9:3,12,14 10:9
+12:3 19:5,17 24:6
+24:18 27:22 28:11
+28:20 31:1 40:5
+deny 22:4,7
+depending 18:2
+depose 23:2
+deposition 11:11,12
+14:23 22:24 34:20
+depositions 10:13
+14:22 19:20 22:12
+22:20 23:15 32:25
+desired 20:12
+developed 32:11
+different 6:5 12:21
+16:19 23:7 40:18
+direction 10:20
+disadvantage 30:18
+disagree 20:5,21
+discovery 7:2,10,11
+10:16,25 22:12
+29:4 30:5,21 33:1
+34:11,16,22 38:2
+Page 46
+39:19,25
+discretionary 6:19
+6:2l
+discuss 9:22 23:6
+discussing 42:4
+discussion 16:22
+disingentious 19:15
+dismiss 7:22 8:18
+10:14 20:4 27:24
+33:5,8,25 37:13,16
+38:23
+disposed 40:2
+dispute 38:7
+distinet 7:9
+DISTRICT 1:1,1,11
+DIVISION 1:2
+docket 6:17 8:25
+12:14
+documents 11:7
+14:24
+Doe 1:4,15,18,22 2:3
+2:73:1,5,8,115:17
+6:8,9,16 11:12
+21:5 29:14,22 33:5
+35:13 42:22
+doing 8:9 29:9 34:9
+37:22 39:24
+done 12:3,4 13:17,19
+13:24 14:2,7,17,20
+14:25 15:6 17:14
+20:16 25:4 29:4
+41:10
+doubt 9:14
+dramatic 7:25
+dramatically 7:8
+dump 40:16
+during 40:4
+E
+E 44:17,17
+each 17:24 18:16
+East 1:17 2:15
+Edwards 1:163:7,7
+5:16,20,23 42:22
+42:22
+effect 9:7 17:5
+efforts 41:10
+either 9:3 10:5 30:20
+40:3,25
+elected 29:22
+eligible 31:20
+Elkins 1:20
+email 44:24
+embarrassment 32:3
+enforce 21:17 25:17
+enforcement 7:2
+enforcing 25:10
+enter 40:20
+entered 33:12 40:19
+entire 5:15 20:25
+36:15
+entitle 11:23
+entitled 24:2 31:16
+32:25 33:1 34:20
+
+
+entry 6:17 8:25
+12:14
+enumerated 18:8,9
+envisioned 40:22
+Epstein 1:7 3:1 4:3,6
+4:22 6:77:13,15
+7:19 8:6,20 9:15
+9:18,24 10:1,6,10
+12:5,15 13:17,21
+14:8 17:9 19:5,14
+19:16 20:11,13
+21:8 23:13 24:21
+28:22 29:19,24
+32:18,19,23 33:8
+33:16 34:19 37:1
+37:12 40:19 43:5,7
+Epstein's 4:24 5:9,24
+8:4 9:1 22:7 31:1
+error 27:7,7
+ESQ 1:13,16,20,23
+2.1,5,8,8,11,14,17
+essence 7:9,12 8:3
+10:2 12:3 35:23
+37:1 39:1 40:13,15
+essentially 28:22
+even 11:5,6,9 14:1
+extraordinary 9:13
+41:10
+extremely 31:4
+eyes 26:24 43:19
+Ezell 2:5 3:16,17
+e-mails 36:2
+fact 7:1 8:11 11:19
+14:20 28:4 30:11
+fair 27:6 32:19,23
+faith 38:24 39:8
+far 14:25 21:17
+23: 10 24:24 30:3
+everyone 30:3 42:3
+everything 15:7
+evidence 25:1 44:6
+exact 21:18,22 28:20
+example 14:20 16:21
+17:16 34:17 36:1
+except 8:20 11:25
+exclusively 28:6 33:7
+expecting 43:1,11
+explicitly 37:12
+expose 5:1,25 31:24
+exposure 22:7
+expound 43:12
+express 34:10
+expressly 37:22
+extensive 29:4
+extent 28:10
+federally 2:22 31:15
+fees 21:8,10 25:10
+32:22 35:18 38:18
+filled 5:11,16,21,23
+6:7,10 10:8 11:9
+15:18,23,24 20:20
+28:330:21 33:4,6
+34:135:17,19 36:1
+36:24 37:15,19
+38:23 40:9,12,13
+files 35:19,19,20
+filing 30:5 31:6 41:5
+financial 23:12
+find 5:6 6:13 19:15
+19:25 23:11 29:24
+first 5:9 16:14 19:3
+26:18 30:23 43:20
+FL 1:15,18,21,24 2:3
+2:6,10,13,16,23
+Flagler 2:2,6,9
+FLORIDA 1:1,4
+foregoing 44:18
+forgot 27:23
+Fort 1:18 2:16
+forward 9:8 13:11
+22:17 23:5 26:2
+frankly 5:6
+from 3:174:7 5:9 7:9
+10:20,24 13:9
+14:13 15:9 16:23
+17:10 19:2 30:9
+32:13,13 34:22
+35:10 37:22 41:4
+front 9:5 12:19
+future 9:12 10:5
+Garcia 1:20,20 3:10
+28:15,18 29:11
+general 39:24
+generally 10:22
+getting 24:11 25:19
+girls 20:7 23:5 25:20
+give 12:5 14:1 42:6
+glaring 18:21 35:10
+go 12:10 15:13 22:17
+24:24 26:2 28:8
+29:7 31:24 38:5,13
+going 3:18 5:25 12:4
+12:10 13:23,25
+14:11,13 15:18
+16:2 19:522:4,6,9
+22:18,23 23:10,14
+23:2426:528:8,11
+29:836:238:6,8
+38:12,13,16 39:10
+39:15 41:22 43:1
+Goldberger 2:11,12
+good 3:6,9,10,12,13
+3:15,16,22,23 4:4
+4:5,9,11,16,18,20
+17:16 38:10,24
+Government 7:7,9
+Page 47
+7:188:1,2,79:21
+35:6 38:20 41:13
+10:8 11:19 12:6
+42:10 44:12
+13:1,2,2,9,11,13
+HONORABLE 1:11
+14:1,5 15:23 16:19
+hope 31:22
+17:11 18:4,12,17
+hopefully 13:3
+20:11,11 21:13,14
+Horowitz 1:13,14
+23:10,11 25:11
+3:4,4 29:13,13
+29:9 33:1934:18
+30:6
+34:23 36:2,17 41:3
+horrible 21:23
+humiliated 20:25
+Government's 5:6,8
+hypocritical 19:25
+7:25 9:10 12:20,23
+15:16 18:22 25:13
+granted 22:2
+great 7:23 8:20 9:19
+10:22 12:17 15:15
+guess 36:17 38:6,7
+guilty 17:11 41:8
+hand 32:9,941:25
+hanging 11:19
+happen 14:13 22:6
+happy 30:16 36:13
+harassing 39:16
+harassment 39:18
+harm 10:1 41:7
+having 27:2,11
+hear 5:9 26:12 41:21
+heard 19:2 41:13
+hearing 1:10 4:21
+30:24 43:14
+help 30:11,16 32:15
+helpful 5:7 25:12
+30:14 42:7 44:14
+Herr 2:21 44:20,21
+idea 17:1 31:22
+Il 1:22 3:11
+impact 16:18
+important 41:24
+| impose 27:4
+incident 24:14
+incidents 17:25
+incredible 7:21
+incredulous 19:15
+indicate 44:3
+Indicated 30:13
+Indicates 43:3
+indict 7:20,20,22
+8:13,16,17 12:10
+12:24 15:10 18:23
+indicted 9:17 10:6
+indictment 8:19 10:7
+individual 18:16
+Individuals 10:18
+17:1 35:15 37:3
+information 22:21
+initial 12:19 15:21
+initially 15:24
+injury 10:23 23:22
+inquiries 30:13
+inquiry 7:15 15:16
+instance 7:18,24
+9:18 10:10 11:3,17
+him 4:23 7:20,20,22
+8:13,16,17 9:15,20
+11:23 12:521:14
+21:15 25:10,11
+26:4,5,13 28:24
+38:11 40:2041:11
+himself 5:1,3
+Honor 3:10,13,16,21
+4:2,5,9,13,17,19
+25:22,25 26:7,12
+27:21 30:15 34:14
+intended 28:21
+intention 9:19 26:19
+26:20,20 27:16
+Interested 13:17
+interpretation 16:20
+Interrogatories
+14:24 19:20
+interrupt 37:4
+introduced 20:16
+intrusive 29:5
+invasive 19:22
+investigated 31:14
+
+
+investigation 10:18
+38:2 43:7
+investigations 22:13
+invited 27:6
+involvement 6:6
+irreparable 9:16
+ISIDRO 1:20
+issue 4:23 6:5,11,19
+7:4 11:25 12:18,22
+14:14 15:25 16:2
+16:13,22 18:12,22
+21:18 28:10,16
+33:4,14,24 42:8,23
+issued 14:25
+Issues 4:21 24:10,13
+25:21,23 35:9
+36:15 39:25 40:3
+issuing 22:20 39:19
+J
+J 1:16
+Jack 2:11 4:5
+jackpot 32:9
+jail 41:7
+Jane 1:4,15,18,22
+2:3,7 3:5,5,7,11
+5:17 6:8,9,16
+11:12 21:4 29:14
+29:22 33:5 35:13
+42:22
+Jay 2:20 4:18
+Jeffrey 1:7 37:12
+jeopardize 9:15
+jeopardy 15:17
+join 26:11,15
+Josefsberg 2:1,2,5
+3:18,20,21,23 19:7
+19:7,10 21:25 23:1
+24:5 25:25 26:7,11
+26:12,16 27:13
+31:632:1733:5
+35:14 39:3 41:13
+41:16 42:10,16,17
+43:17
+Josefsberg's 33:25
+35:11 36:5
+JR 2:8
+Judge 1:11 15:12
+21:2 29:13 35:15
+42:8,12
+judgment 22:16
+June 1:5 13:12
+Jurisdiction 28:1,6
+just 18:23 20:15,16
+22:3,6 24:20 26:1
+29:15,16 30:23
+35:8 37:8,10 39:24
+40:4,17 42:24
+43:14,23 44:3,11
+Katherine 2:5 3:16
+KENNETH 1:11
+kind 30:10 36:12
+know 4:22 6:17 8:21
+11:14 12:2 13:9,17
+14:21 15:5,7 16:22
+19:23 22:6 23:12
+25:9 27:1 30:12,20
+31:4 32:13 37:19
+39:10,17 41:17,21
+knowing 26:25 38:5
+knowledge 5:13
+known 21:4 32:14
+lack 41:22
+Ladies 20:23 21:3,20
+Lake 1:24
+language 18:14
+32:11
+LARRY 2:21 44:21
+Las 1:17
+last 33:22 41:24
+Lauderdale 1:18
+2:16
+law 7:1 21:24 28:9
+lawsuit 25:18,19
+lawsuits 30:17
+lawyers 8:21 9:4,7
+10:23,23 17:22
+27:1 38:10,11,21
+40:23
+lay 8:10
+least 35:10
+leave 33:17,19
+Lefkowitz 2:20 4:18
+legal 10:13 24:10,13
+35:21 38:12 40:3
+legally 40:7
+legitimate 38:7
+let 5:9 13:10 19:19
+letter 17:10 21:19
+liability 17:12 18:7,7
+20:3,6,16,19 23:16
+23:17,20 24:8,18
+24:22,23 25:6,11
+29:20 32:23 36:9
+like 7:16 13:9 25:21
+limit 23:23 24:2
+limitation 25:2
+lImitations 36:4,7,11
+limited 4:21 8:3 14:5
+17:12 20:19 23:25
+Lindsay1 65(gaol.C...
+list 17:1,2,6 35:16
+litigation 7:4,5 9:13
+15:8 16:18,25
+21:18 22:14 23:12
+31:24 33:16 34:3,9
+34:15,15,16 36:25
+long 31:17 37:14
+look 12:14 18:6
+M 1:20
+MA 2:18
+made 15:10,17 16:6
+20:12 31:20 43:13
+major 11:25
+make 8:21 13:4
+27:24 29:1,16 34:5
+38:12,13 39:11
+making 42:7 43:9,24
+many 20:23 31:3
+Martin 2:174:16
+Master 21:2 32:16
+matter 20:15 37:13
+matters 21:11
+may 3:35:17:2,10
+11:19 13:17,18
+14:18 15:12 16:18
+16:19 17:12 19:8
+19:16 20:4 21:11
+27:22 30:20 32:14
+34:17 35:16,20
+39:640:8,16 41:6
+maybe 12:17 13:10
+17:20 30:10 42:8
+mean 18:10 33:22
+34:14 39:7 43:24
+memo 7:14 28:9
+memorandum 27:23
+mentioned 44:11
+Mermelstein 1:14
+Miami 1:15 2:3,6,23
+Michael 2:8 4:3
+microphone 26:13
+might 14:2,12 22:14
+minimum 17:3 25:3
+minimums 24:25
+minute 18:13 41:14
+mistakes 13:4
+23:25 30:25 39:12
+morning 3:6,9,10,12
+3:13,15,16,22,23
+4:4,5,9,11,16,18
+most 7:7 13:3 15:24
+18:21 32:12 35:10
+motion 1:10 4:22 6:7
+12:22 15:24 20:4
+22:6 27:24 33:4,14
+33:15,25 34:2,11
+37:15,20 38:2,23
+39:8 41:542:23
+motions 10:14 17:15
+21:5 30:5 35:21
+more 7:22 8:18 19:1
+19:20 21:17,21
+moving 9:7 33:8
+much 23:13 30:16
+multiple 18:1540:15
+multitude 8:12
+myself 16:5 42:17
+names 11:9 23:5
+necessary 22:22 41:5
+Page 48
+need 24:22 25:23
+negotiate 32:18
+negotiated 27:3,3
+neither 43:21
+never 11:9 26:20
+40:19,22
+newspapers 23:5
+nobody 11:14
+none 13:25
+non-contesting 28:5
+non-position 9:10
+non-prosecution 5:2
+5:11 6:2 8:6 13:24
+14:19 15:20 19:6
+22:8 24:1 27:25
+28:2,5,19,25 29:25
+31:11 32:6,8 33:2
+33:12,18,19 34:3,6
+34:10 36:19 37:11
+43:1,6,16
+поп-2255 24:4,6
+normal 30:4 39:13
+North 1:23 2:9,23
+nothing 13:15 24:12
+notice 8:13,16 9:21
+13:6 14:23 22:24
+31:8,8 39:6,16
+notification 15:3,4
+NPA 8:5,11,15,24
+10:4,19,22 11:20
+12:8,15,24 13:7,15
+14:10 16:8 18:14
+20:22 21:19,19
+23:924:12,15,16
+24:18,20 25:2,7
+35:12,24 36:14,14
+39:3 41:4,6,11,18
+number 15:9 16:21
+17:7,9,14,21,24
+numerous 23:21
+object 7:2,10,10
+objection 36:18
+objections 11:5,6
+obligation 21:9
+30:12 31:8
+obtain 11:7
+obviously 10:20
+34:18
+occurred 17:25
+occurs 26:21
+off 39:8
+offender 41:9
+offense 18:8,10,15
+33:10,11
+offenses 18:16 31:13
+offered 37:2
+
+
+office 4:8,10 26:20
+27:4 43:5,12,25
+Official 2:22 44:22
+okay 3:25 5:19,21
+old 31:18,18
+one 4:23 7:17 11:25
+17:24 18:5,16,20
+18:21 20:1,8 22:24
+31:11 36:24 39:10
+40:16 42:23 44:11
+only 13:22 14:3
+17:24 23:20 25:4
+29:20 36:6 39:1,3
+open 26:24 43:19
+opportunity 8:14,17
+opposed 33:21
+opposite 20:22 21:18
+21:22 28:20
+opposition 27:24
+option 7:23
+order 6:16 12:14
+22:21 30:23,24
+33:17,17 36:19
+44:15
+ordinarily 26:3
+34:12
+ordinary 27:10
+originally 6:5
+Orseck 2:2,5 3:17
+other 7:1,17 16:4,5
+17:22 22:13,18
+23:6,21,22 24:1
+25:21 26:8 32:8
+34:9,11 36:12
+42:18 43:844:10
+otherwise 39:14
+out 8:8 10:16 22:24
+26:16,23 28:22
+30:11 36:12 38:17
+outside 13:18,19
+24:17 36:7
+over 11:19 24:24
+own 12:21 38:13
+P
+Pacer 30:19
+pages 7:14 27:23
+28:9
+paint 29:17
+Palm 1:2,4,21 2:10
+2:13
+paper 10:16 13:7
+papers 8:10,16 9:25
+10:8 11:21 12:20
+15:6,10 41:5
+paragraphs 36:15
+paraphrasing 6:20
+part 10:18 18:9
+20:23 21:7 23:9,20
+34:16 39:23 40:2,5
+particular 6:15,18
+7:24 8:22 9:18
+parties 9:23 11;6
+16:21 22:21 39:20
+partner 3:184:3
+parts 19:2521:17
+party 11:11 14:25
+30:12,17 36:18
+past 9:11 10:5 12:3,4
+pay 17:3 21:8,10
+pending 6:15 9:5
+17:1521:6
+people 23:6
+per 24:14,14,14,14
+perception 28:21
+perfect 36:1 39:5
+perhaps 20:24 27:22
+perlod 9:21 34:4
+37:3,14
+permitted 24:6,18
+permitting 42:18
+person 36:11
+personal 10:23
+23:21
+perspective 16:23
+35:10
+pertains 29:20
+phone 4:12,14,15
+42:18,19
+pieking 12:13
+place 31:12 37:14
+43:20
+plaintiff 3:7,14
+24:15 30:4 34:20
+43:7
+plaintiffs 1:5,13 3:4
+3:24 11:8 17:8,14
+17:22 19:3 22:14
+23:7,24 27:5 29:1
+29:12,14,20 30:9
+39:16 43:8
+plaintill's 19:4 26:8
+36:16
+playing 7:8
+plead 17:11 18:10,11
+pleading 7:14 31:10
+33:4 40:9,14
+pleadings 23:4 31:3
+please 41:22
+pled 17:8,16 20:14
+Podhurst 2:2,5 3:17
+point 6:18 14:12
+26:16,23 28:14
+29:15 36:12 43:23
+pointed 14:20
+portion 32:24 36:14
+portions 5:15
+posed 11:25
+posing 8:4
+position 5:5,86:47:7
+7:25 9:16,20 10:12
+10:13 11:21,22
+12:12,17,23 14:8,8
+14:15 15:16 16:16
+16:17 17:4,7 18:13
+18:17 19:19 20:13
+22:1,11 25:8 30:14
+31:12 32:10,15,20
+34:8 35:3,21 36:23
+37:9 40:1041:17
+positions 30:20 41:5
+possible 30:17 31:4
+44:15
+possibly 34:9
+posting 25:22
+potential 5:3 15:2
+28:2
+potentially 10:18
+15:19
+power 13:2
+practical 10:25 15:9
+practice 34:11 38:3
+predicate 20:8,15
+prepared 20:5 27:15
+present 5:5 11:15
+presents 9:7
+press 43:10
+pressure 21:15
+presume 23:24
+pretty 8:1
+prior 6:6 8:25 12:14
+36:19
+privacy 19:22 32:7
+probably 35:18 36:3
+36:13
+problem 14:12 22:22
+23:2,3 28:18
+procedure 32:16
+34:24
+proceed 12:10 18:23
+32:22 38:13
+proceeding 6:15,15
+proceedings 4:23,25
+44:19
+process 39:25
+production 14:24
+prohibited 38:3,4,18
+prohibits 37:22
+proof 20:16
+proper 25:1 27:14
+prosecuted 20:13
+26:4 27:11 29:10
+prosecuting 37:25
+prosecution 26:6
+28:23 29:6,7 34:25
+prospect 16:15
+protecting 32:7
+provide 31:8 36:13
+provided 16:9 32:12
+provides 9:22
+providing 31:8
+provision 6:12 8:11
+29:19,25 34:10,25
+37:11 38:3 39:17
+provisions 13:6,7
+psychologically
+purpose 21:19,23
+28:20
+pursuant 25:15 32:8
+41:17
+pursue 23:12
+pursuing 22:12;15
+put 9:1518:21 32:10
+41:6
+puts 18:25 34:4
+40:10 41:11
+Q
+question 8:3,7 9:2
+12:1 30:25
+questions 42:1
+quite 19:10
+R
+R 44:17
+raise 16:2 36:11
+raised 15:25 16:13
+18:5,21 19:13
+28:10 33:14 35:9
+40:1
+read 37:20 42:2,23
+reading 18:18 23:19
+ready 29:7
+real 9:6 10:8 36:11
+41:18
+really 12:2 18:11
+30:20,23 33:14
+36:17
+Realtime 2:22
+reason 6:14 7:3
+29:23 33:11 34:2
+reasons 18:5,20
+34:19 40:8
+recapitulating 41:1
+received 5:5 15:3,4
+20:4
+recent 7:7 15:24
+records 34:21
+redacted 36:14
+Page 49
+reference 27:25
+referred 31:6
+refusing 25:5
+regard 9:11,12,13
+1O:12,13,14,14
+11:412:19 14:9
+16:18 18:23 35:12
+regarding 6:24
+regardless 31:17,18
+registering 41:9
+relate 9:3 30:1
+related 30:24 33:24
+relating 29:19
+release 41:9
+relevant 19:22
+remain 42:13
+remedy 7:20 8:17
+29:21 33:20 34:7
+remember 23:19
+remind 44:3
+remote 10:8
+гер 35:14
+replies 10:15
+reply 35:22
+REPORTED 2:21
+Reporter 2:22,22
+14:22
+*095. ent 21:3 32-12
+representation
+26:18
+representatives 4:7
+43:9
+represented 21:7
+26:24 33:5
+representing 38:11
+represents 18:16
+35:16
+requests 14:23
+required 17:3
+requirement 33:8
+resist 34:18,23
+resolve 42:8
+resolved 7:4 19:12
+24:16
+respect 22:14
+respectfully 7:6 14:4
+respond 20:5 30:13
+44:9
+response 5:67:14
+8:211:20 15:16,23
+18:22 33:15 34:1,1
+35:17,21
+responses 10:14
+30:21 35:8
+restitution 29:2
+31:16,23
+
+
+restitution/damages
+32:19
+restrictions 43:18
+result 10:21 15:19
+18:20
+resulted 32:17
+review 31:3 36:22
+Richard 1:23 3:13
+26:10
+ride 40:17
+right 3:24 6:24
+12:25 13:325:8,14
+34:23 37:20 41:3
+42:20 43:14 44:8
+rights 13:5 25:16
+32:7
+risk 9:6 10:6,7 18:25
+38:6 40:10 41:5,11
+risks 21:5
+Robert 2:1,8 4:2 6:3
+role 25:13 37:7
+Room 2:23
+Rosenfeldt 1:17
+rose-colored 11:16
+Rothstein 1:17
+RPR-CM-RMR-F...
+44:21
+RPR-RMR-FCRR...
+2:21
+rule 39:9 42:13
+rules 22:3 25:1 34:24
+40:15 42:13
+ruling 8:25 42:7
+rulings 19:21 23:8
+25:2 27:13,15 30:6
+run 22:18
+running 21:13 23:14
+27:16
+same 6:10,16 8:3
+20:13 27:12 31:12
+32:10 35:21 38:21
+satisfied 20:9
+saying 7:10 8:1
+17:17 19:12,16
+20:6,7,8 21:14
+25:5 33:9 37:10
+says 8:15 13:7 17:11
+18:13 35:1 38:5
+40:14 41:3
+scheduled 4:21
+seal 5:18,23
+sealed 42:14
+second 20:23 27:2,5
+30:24 36:25 37:4
+Secondly 41:20
+secret 17:1
+Section 33:7
+see 4:7 15:11 20:12
+seek 23:25
+seeking 6:7 24:3
+seeks 34:22
+seen 5:14,15
+selected 35:15
+self-fulfilling 24:23
+self-incrimination
+6:25
+send 10:16 38:17
+39:6
+sends 22:23
+sent 14:22,23,24
+16:6 17:10 39:15
+39:19
+separate 5:20 17:17
+serve 11:5,5
+set 12:21 13:13 18:4
+31:22 36:9
+settle 21:8
+settling 21:10 25:5
+severely 21:21
+sex 41:9
+sexual 23:6
+shape 11:4
+shield 29:1
+show 36:22 42:11
+Sid 3:10
+side 7:17,17
+silent 29:23
+similar 35:18 43:2
+simply 11:17
+since 20:20
+sir 19:9 35:8 37:5
+41:15
+sit 8:9
+sitting 42:3
+situation 12:6 20:25
+25:12 26:24
+sole 29:21
+solely 12:15 32:10
+some 4:7 5:4 7:2,10
+7:11,12 9:1,8,9
+10:16 15:12 16:1,8
+17:22.20:25 21:3
+30:18 35:8 38:7
+43:13
+someone 10:17 19:22
+24:20 26:3 34:12
+34:17 37:16 39:15
+something 13:19,24
+14:17 15:24 20:19
+26:1728:13 34:9
+37:21,23 38:4,9
+39:9 43:2
+Sometimes 13:4
+somewhat 6:5
+soon 44:15
+sorry 15:14 27:19
+sort 32:10 33:17
+34:19
+sought 31:11
+sound 37:16
+South 2:12
+SOUTHERN 1:1
+speak 12:16 19:8
+speaking 26:14 32:2
+Special 21:2 32:16
+specific 8:2 11:1
+16:24 17:13 30:25
+specifically 43:7
+spector 11:18
+speculative 10:9
+standpolnt 10:25
+state 3:3 9:6 28:4
+29:440:12,17 41:8
+statement 33:23
+statements 43:9
+States 1:1,11 2:22
+4:8 5:1,5,17 6:1
+9:24 10:6 13:21
+14:8,17 16:7 19:14
+22:10,19 29:939:4
+statute 17:4 18:3
+20:6 24:14 28:7
+29:21 36:4,7,11
+statutory 6:12 24:25
+25:3 34:18 37:2
+stay 4:23 6:8,19,21
+7:3 11:24 12:16,19
+12:23 15:25 19:16
+21:22 22:2,4,4,5,7
+24:22 25:21 30:24
+33:14,15,16,21
+34:2,2 37:21,22
+42:5 43:4 44:1
+stayed 25:19
+staying 21:18
+stuck 18:14 36:10
+subject 5:3 26:5,21
+submitted 42:15
+subpoena 11:9 34:17
+subpoenaes 11:5
+subpoenas 14:25
+22:21 38:18 39:19
+subsequently 6:9
+substantial 9:6
+suggest 8:10,23
+suggested 12:13,21
+14:16 15:5,6 36:3
+39:2 40:8,9
+suggesting 16:7
+suggestion 15:17
+suit 20:21 21:4 32:22
+summary 40:3
+supporting 15:16
+supposed 20:18
+22:25 23:17 24:9
+sure 5:7 14:11 26:2
+29:16 33:22 37:25
+system 31:23
+take 7:12 9:12 10:3,3
+10:12,13,21 11:12
+11:18,21,22 14:7
+14:21 16:16,16
+18:2 19:20 22:10
+27:9,10 29:3 33:1
+34:15,20 35:20
+38:7,17 41:14,22
+taken 7:7 9:11,21
+14:9 15:5 30:20
+taking 9:8 14:23
+19:17 22:12,20
+23:15 25:20 34:8
+talk 6:18 25:23
+team 4:14 12:3
+telephone 2:4,19,20
+tell 11:13,14 42:12
+telling 21:13 22:9
+temporary I!:
+terminates 34:4
+terms 9:3 22:7 33:20
+thank 19:1,2 27:8,21
+30:8,15 35:5,6
+their 3:3,25 7:14,14
+8:10,169:25 11:8
+11:20 12:21 13:7
+14:21 15:6,10
+21:21 23:627:5
+29:21 32:5,7,7
+themselves 32:4
+thing 25:4 27:12
+28:21 31:11 39:11
+things 11:3 38:15
+think 6:8,14 8:15 9:4
+9:22 10:19 11:22
+12:24,25 13:6,6
+17:16 18:18,23
+19:14 25:13 27:6,6
+27:22 28:18 29:15
+30:23 39:6,8 42:1
+42:2,6 43:15 44:14
+third 11:6,11 14:25
+third-party 19;11
+21:16 25:14
+thoughts 27:2,5
+threatening 44:1
+through 3:56:9 11:7
+11:16 29:14,22
+31:5,24 32:6,16
+time 6:10,11,12,15
+6:19,20 13:3 17:5
+21:12 31:18,19
+times 17:19 18:2
+today 8:4 13:11 14:3
+14:6.6 15:5 28:17
+today's 13:12,14
+told 23:20 35:23
+tort 10:24 23:22
+totally 20:5,21 23:1
+TRANSCRIPT 1:10
+transcription 44:19
+traumatized 21:21
+tried 31:3 32:6
+troubled 43:24
+try 23:11 30:16
+32:18 34:17 44:15
+trying 10:11 22:3
+28:25 32:9 37:8
+two 4:13 9:23 19:25
+type 12:15 22:13
+35:17 39:18
+types 22:16 36:24
+typical 11:2,4 22:15
+ultimately 39:9
+uncertainty 9:14
+uncomfortable
+under 5:17,17,23
+7:20 8:18 9:25
+
+
+....
+10:1,11,22 12:6,10
+12:20 13:7,8 16:8
+16:17,23 17:2,4,8
+17:12,18 18:4,8,19
+20:9,18,19,21 21:9
+22:7 24:8,11,18,20
+24:20 25:1,6 28:6
+30:12 31:21 32:21
+34:18,23 35:24
+36:58,9 37:1,13
+38:25 39:6,14 40:6
+understand 5:7
+14:15 21:25 22:3
+23:24 29:25 30:14
+31:7 37:8 38:20
+understanding
+unilateral 12:22
+unilaterally 7:13
+United 1:1,11 2:22
+4:8 5:1,5,17 6:1
+9:24 10:6 13:21
+14:8,17 16:7 19:14
+22:10,19 29:839:4
+44:5,22
+unless 11:7 34:25
+unlimited 40:21
+until 37:23
+urge 22:9
+use 10:25 11:8 20:24
+23:11 28:25 40:11
+used 28:19
+U.S 2:15 4:10 7:1,9
+8:6 12:8,12 16:16
+26:19 27:4,18,19
+various 3:l 10:25
+very 4:21 5:7 11:1,2
+11:20 12:21 16:19
+23:11 29:4 32:1
+35:18 38:10 40:18
+42:2 43:18 44:14
+victims 20:12 21:20
+28:23 31:12,16,23
+32:13 33:18 35:16
+39:20 41:17,18,19
+NeY /6:12
+4:10 17:10 30:10
+30:15 33:24 34:14
+35:2,4,6,12 39:4
+44:9,12
+violate 19:18 34:6
+violated 5:214:2
+39:6
+violates 8:5,11 33:2
+42:25
+violating 9:16,19
+38:17 41:6 43:13
+violation 8:23 9:9
+10:4,19 11:20 12:7
+12:9 13:15,19,20
+13:23 14:10,19
+15:216:718:19
+24:19 25:19,20
+29:10 34:10,13,24
+35:12,24 37:17
+40:25 41:4
+violations 17:17,18
+17:24 18:1,16
+19:23 40:16 43:17
+43:22
+voluminous 31:4
+vs 1:6 3:1 5:17
+W
+₩ 2:5
+wait 8:10 18:03
+42:12
+waive 25:14
+waiving 18:7
+want 8:9,10 11:15
+12:216:22 17:20
+21:4,4,5,14 22:1,6
+25:1726:2,8,16,18
+26:23 27:4 29:16
+35:7 37:21 41:17
+41:21 42:14,21
+wanted 11:11 14:21
+17:5 20:12 29:15
+wants 11:1413:3
+19:2,16,20 23:4
+24:24 33:16 34:2
+warranted 6:22
+way 8:239:9 10:5,16
+10:19 11:4 13:16
+14:10 19:23 25:1
+25:18 27:3,4 28:22
+ways 30:18
+Weinberg 2:17 4:16
+well 7:10 8:20 10:22
+11:12,12,13,13
+12:17 13:16 14:11
+15:7 16:18 17:15
+17:23 18:10,11
+33:24 35:12,19,20
+36:5 39:4 40:13
+went 6:18,22 26:23
+32:16 43:19
+were 6:10 14:6 15:10
+18:7 19:11 21:2
+29:23 31:17,18
+32:1,4,22 34:17
+36:24 43:1 44:10
+West 1:2,4,21 2:2,6
+we'll 7:19,22 8:16
+17:23 26:13 40:17
+we're 9:8 10:2 12:10
+13:14 19:10,12
+20:5 27:15 28:17
+39:1 43:14 44:2
+we've 15:4 35:23
+whatsoever 27:7
+while 32:7 34:16
+whole 20:12 38:11
+wide 26:24 43:19
+willful 8:23 12:7
+Willits 1:23 3:13,14
+26:10,10,14,15
+withdraw 28:8,11
+wonderful 28:23,24
+written 5:6 21:9 23:4
+yesterday 21:9
+young 20:23 21:3,20
+$150,000 32:21
+S50,000 17:5 32:21
+08-80119-CIV-M...
+101 2:3,7 33:5 35:13
+35:17 38:23 39:3,7
+102 6:8 35:19 36:1,3
+40:9 41:21
+103 21:5 35:19
+104 35:19
+105 35:20
+11:10 44:16
+12 1:5 9:4
+12th 13:12
+13 7:14 9:4
+150 17:19,20 18:2
+17 27:23 28:9
+18205 1:14
+19 27:23 28:9
+2
+23:55:17 6:9,16
+29:14,22
+20 2:18 17:25 18:2
+2009 1:5 13:12
+227:21 10:2
+224 1:21
+2255 16:23 17:4,17
+17:18 18:8,12,14
+20:2,9,19,21 23:21
+23:22,23 24:8,17
+24:21 25:6 31:21
+32:21,23 33:7,10
+36:6,23 37:13 41:2
+2290 1:23
+252:2,6
+2502:12
+2620:4
+3
+31:18
+30 17:16,19,19
+30-count 40:12
+305.358.2800 2:3,7
+2:23
+1:15
+44:23
+305/523-5639 44:23
+336:179:1
+33128 2:23 44:23
+33130 2:3,6
+33160 1:15
+33301 1:18
+33394 2:16
+33401 1:21 2:10,13
+33461 1:24
+3421:20
+4.
+4 1:18 11:12
+400 2:23 44:22
+4011:17
+5
+51:186:9
+5th 12:18
+Page 51
+50 18:2 24:12
+500 2:15
+5152:9
+551.582-7600 1223
+551.532-8038 1:22
+2:10
+6
+6H8
+2:19
+71:18 3:5 29:14,22
+36:15
+8
+836:15
+8N09 2:23
+9
+936:15
+2:16
+1:19
+
+
+CASE NO: 4D09-2554
+L.T. No. 2008 CF 9381
+JEFFREY EPSTEIN,
+Petitioner,
+STATE OF FLORIDA,
+, THE PALM BEACH POST,
+Respondents.
+•'S SEALED REQUEST TO DISMISS THE PETITION FOR
+LACK OF JURISDICTION
+Respondent, W
+., would show the Court as follows:
+1. This Court lacks jurisdiction to hear this petition.
+The order under review is a non-final order for which no appeal is
+provided by Rule 9.130. A non-final order for which no appeal is provided
+by Rule 9.130 is reviewable by petition for certiorari only in limited
+circumstances. The order must depart from the essential requirements of law
+and thus cause material injury to the petitioner throughout the remainder of
+the proceedings below, effectively leaving no adequate remedy on appeal.
+Allstate Ins. Co. |. Langston, 655 So.2d 91, 94 (Fla. 1995); Barad & Co. I.
+
+
+McGuire, 670 So.2d 153 (Fla. 4" DCA 1996); see, Menke | Broward
+School Bd, 916 So.2d 8 (Fla. 4"' DCA 2005).
+The requirement of irreparable harm is jurisdictional. Allstate; Barad
+& Co. A petitioner's failure to demonstrate the satisfaction of this
+jurisdictional element should result in dismissal of a petition for writ of
+certiorari. Barad & Co.
+As shown below, petitioner fails to meet this jurisdictional threshold.
+2. Disclosure of the NPA will not cause petitioner irreparable
+harm.
+a. There is nothing in the NPA that is confidential and disclosure
+will not cause petitioner irreparable harm ("there's no cat in the bag").
+Petitioner does not cite a single term, provision, sentence or word in
+the NPA' that is confidential. There are no "confidentiality provisions" in
+the NPA, contrary to petitioner's misleading assertions (i.e., petition at page
+10). There is not a single detail about this sex offender's plea deal with the
+U.S. Attorney or the state attorney that should be hidden from the public.
+A page-by-page review of the NPA demonstrates this. The first page
+discusses that local law enforcement have conducted investigations of
+1 The undersigned attorneys were given a copy of the NPA through the
+tederal proceedings before Judge Marra (see
+filed herewith), but, inexplicably, undersigned was not provided a copy of
+the Addendum.
+We have never seen it and do not know its contents.
+2
+
+
+petitioner; that he was charged by indictment with solicitation of
+prostitution; that the U.S. Attorney and FBI have conducted their own
+investigation of his crimes against the United States from 2001-2007
+including crimes for inducing minor females to engage in prostitution;
+conspiring to use interstate commerce to engage in illicit sexual conduct;
+using interstate commerce to induce minor females to engage in prostitution;
+traveling in interstate commerce to engage in illicit sexual conduct with
+minor females; recruiting minors to engage in a commercial sexual act.
+The second page provides that petitioner wishes to resolve globally
+his state and federal charges; that the interests of the state, the United States
+and petitioner would be served by so doing; that prosecution by the U.S.
+Attorney shall be deferred in favor of prosecution by the state provided
+petitioner abides by the agreement; that should petitioner violate any
+conditions of the agreement he may be prosecuted for any offense; that if
+petitioner fulfills the terms of the agreement, the U.S. Attorney will not
+prosecute him for any offense.
+The third page discusses that he will plead guilty to state charges of
+solicitation of prostitution and solicitation of minors to engage in
+prostitution and be registered as a sex offender; he will agree to a county jail
+sentence of 18 months for the two charges followed by 12 months
+3
+
+
+community control; the state judge must approve the sentence; the
+agreement does not preclude petitioner and the state attorney from agreeing
+to recommend additional charges or additional terms of probation or
+incarceration; petitioner waives his rights; petitioner shall provide the U.S.
+Attorney with copies of his agreements with the state attorney.
+Page four provides that the United States shall provide petitioner with
+a list of victims; the United States shall select an attorney to represent the
+victims; if any victims files suit based on federal claims petitioner will not
+contest them; he is not admitting liability by signing this agreement; that he
+will use his best efforts to plead guilty by a certain date.
+Page five provides that he will not be treated differently than any
+other offender as to county jail gain time; that the parties anticipate this
+agreement will not be made part of any public record but if there is a
+Freedom of information Act Request or compulsory process on the United
+States for this agreement, the U.S. will give petitioner notice before
+disclosing the agreement; that the U.S. Attorney cannot guarantee what the
+state attorney does; that the United States will not prosecute potential coconspirators; that ongoing grand jury proceedings will be halted.
+4
+
+
+Page six provides there is consideration for the NPA and a breach
+allows the United States to elect to terminate it; that petitioner waives certain
+rights.
+Finally, page seven provides that petitioner has read the agreement
+and understands it.
+Where is there a single confidential term, provision, sentence or word
+in the NPA the disclosure of which will cause petitioner irreparable harm?
+The answer is there is none.
+Will it cause petitioner irreparable harm for the public to learn that he
+and the U.S. Attorney agreed he will be sentenced in state court to a mere 18
+months county jail time (in his home county, not a prison, with all the usual
+gain time and work release benefits not available in the state prison system,
+so he serves about 60% of the sentence) plus 12 months non-sexual offender
+community control, for solicitation of a minor to engage in prostitution, a
+second degree felony punishable by up to 15 years in prison, and felony
+solicitation of prostitution, a third degree felony punishable by up to 5 years
+in prison?
+Will it cause petitioner irreparable harm for the public to learn that if
+petitioner fulfills the terms of the agreement, the U.S. Attorney will not
+5
+
+
+prosecute him for a single federal crime he committed against multiple
+minor female victims?
+Will it cause petitioner irreparable harm for the public to learn the
+state attorney will only prosecute him for just two of his crimes involving
+only just two of his minor female victims and that he does not face any
+further state prosecution for all his other crimes against the many more
+minor female victims identified by the U.S. Attorney?
+Will it cause petitioner irreparable harm for the public to know that
+the other participants in his criminal enterprise for procuring minor females
+to engage in prostitution, co-conspirators
+Groff and
+Lesley
+will not be prosecuted at all?
+Will it cause petitioner irreparable harm for the public to learn that an
+attorney will be appointed to represent his other minor female victims in
+civil lawsuits; that, if they bring only a single specified federal cause of
+action, he will not contest, but not admit, liability, but if they bring other
+causes of action such as battery or intentional infliction of emotional
+distress, he can defend in any manner he choices?
+Will it cause petitioner irreparable harm for the public to know that
+the U.S. Attorney and the state attorney have utterly compromised their roles
+6
+
+
+as prosecutors and protectors of the public safety by entering into this
+sweetheart deal with petitioner?
+As in the old Wendy's commercial, "Where's the beef?"
+b. The parties to the NPA did not agree it would be confidential;
+in fact, the United States agreed the NPA would be publicly disclosed if
+a Freedom of Information Act Request or compulsory process were
+made to disclose it.
+There is nothing in the record to support petitioner's assertion that the
+parties agreed to confidentiality. Petitioner has not proven by any evidence
+extrinsic to the NPA that it was intended to be confidential.
+The wording of the NPA, moreover, does not show it was intended by
+both parties to be confidential. The NPA on its face does not state anywhere
+that it is confidential. The word "confidential" does not appear in it. There
+is not a single term, provision, sentence or word in it where both parties
+affirmatively agree to keep it confidential. The term "confidential"
+essentially means that something is "meant to be kept secret." Black's law
+dictionary (8'h ed. 2004). The NPA does not contain an expression of this
+intent. In fact, the parties to it expressly agree to the contrary: that the
+United States will disclose the NPA if a Freedom of Information Act
+Request or compulsory process is made to disclose it:
+7
+
+
+The parties anticipate that this agreement will not be made part
+of any public record. If the United States receives a Freedom of
+Information Act request or any compulsory process commanding the
+disclosure of the agreement, it will provide notice to Epstein before
+making that disclosure.
+(NPA, paragraph 13(emphasis added.)
+The first sentence of the above quote does no more than state an
+expectation by both sides that they do not anticipate the document being
+made part of a public record, i.e., not filed in federal court. At most it states
+merely an intent that neither side will take affirmative steps to make place it
+in a public record. But that is not a provision that the document is
+confidential or that it will be kept confidential. In the same paragraph, the
+United States agrees to disclose the NPA if a Freedom of Information Act
+Request or compulsory process for the document is made.
+In fact, with all the hearings held in state court to the present on this
+issue, the United States, which was always noticed, has not once intervened
+in state court to request that the document remain sealed. A representative
+of the U.S. Attorney's office has not even appeared at any of the hearings
+before the trial judge below on this issue. Moreover, at the plea colloquy,
+representatives of the United States were present and did not object to the
+8
+
+
+terms of the agreement being discussed on the record or being placed in the
+state court file (see below)?
+Also, the text of the NPA quote above (par. 13) shows that petitioner's
+arguments based on the supremacy clause and the doctrine of secrecy of
+grand jury proceedings are wholly without merit. Can these arguments have
+any conceivable validity if the U.S. Attorney agreed to publicly disclose the
+NPA if there were a Freedom of Information Act Request or compulsory
+service of process? There should be no serious consideration given to
+petitioner's contention that the U.S. Attorney intended to look to petitioner
+to protect the rights of the United States under the supremacy clause or to
+protect the sanctity of the doctrine of federal grand jury secrecy. This is but
+another smoke-screen.
+c. Petitioner himself and the state prosecutor already publicly
+disclosed the contents of the NPA ("the cat's already out of the bag").
+At the plea colloquy (A-8), with representatives of the U.S. Attorney
+present, petitioner's attorney and the prosecutor disclosed on the record, in
+public, the essential terms of the NPA. After the trial judge cautioned
+2 It was noted on the record that representatives of the U.S. Attorney were
+present in court. A-8, page 39, lines 22-23.
+9
+
+
+counsel that any sidebar conversation would be on the record, the following
+exchange occurred:
+MR. GOLDBERGER [petitioner's counsel]: The reason why I
+asked to come sidebar is there is a nonprosecution agreement with
+the United States Attorney's office that triggers as a result of the
+plea agreement. In other words, they have signed off and said
+they will not prosecute Mr. Epstein in the Southern District of
+Florida for any offense upon his successful [sic] taking of this plea
+today. That is a confidential document that the parties have agreed to.
+I wanted to tell the court.
+THE COURT: I understand, that would also be invalidated
+should he violate community control?
+MR. GOLDBERGER: Absolutely. That nonprosecution
+agreement -
+MS.
+[the state prosecutor]: They spell all that
+out.
+THE COURT: Mr. Epstein needs to come closer.
+Mr. Epstein, your attorney has told me that in addition to
+everything, we talked about another inducement, shall we say, to
+your taking this plea is that the U.S. Attorney for the Southern
+District of the State of Florida, federal prosecutor, has agreed to a
+nonprosecution
+agreement with you, meaning that if you
+successfully
+• complete probation and do everything you're
+supposed to, they have, have agreed not to prosecute you
+federally, did you understand that?
+THE PETITIONER: Yes, ma'am.
+(A-8, pages 38-39) (emphasis added).
+We can see from the page-by-page review of the NPA (section 2a.
+above) that the other provisions of the NPA are incidental to the highlighted
+quotations. The substance of the NPA is the publicly disclosed provision
+that the U.S. Attorney will not prosecute petitioner for any federal offense
+
+
+upon his pleading guilty to the two state crimes and agreeing to the sentence
+discussed in the plea colloquy.
+CONLUSION
+For the reasons stated above, it is respectfully requested that the
+petition for certiorari be dismissed for lack of jurisdiction.
+I HEREBY CERTIFY that a copy of the foregoing has been served by
+mail on the paris listed below this 13 day of July, 2009.
+I HEREBY CERTIFY that the foregoing is submitted in Times New
+Roman 14-point font and complies with the font requirement of Rule 9.100.
+ROTHSTEIN ROSENFELDT ADLER
+Attorneys for
+401 East Las Olas Blvd., Suite 1650
+Fort Lauderdale. Florida 33301
+Telephone
+Telecopier
+By:
+SERVICE LIST
+Kreusler-Walsh, Compiani & Vargas, P.A.
+West Palm Beach, Fl 33401-5913
+11
+
+
+Robert D. Critton
+Burman, Critton, Luttier & Coleman
+West Palm Beach, FI 33401
+Jack A. Goldberger
+Atterbury, Goldberger, & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, Fl 33401
+U.S. Attorney's Office-Southern District
+500 South Australian Avenue, Suite 400
+West Palm Beach, F1 33401
+Honorable Jeffrey Colbath
+Palm Beach County Courthouse
+205 North Dixie Highway
+12
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/cfb28c42a9e568c2360c68fa254a37f97eed887edc0db60f191ddea2d4a286a5.receipt.json b/vision-fixhub/ds9-unparsed-05/cfb28c42a9e568c2360c68fa254a37f97eed887edc0db60f191ddea2d4a286a5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e4c9b06a151e5fcfc9af3e8137dd7d8b076ee7d0
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cfb28c42a9e568c2360c68fa254a37f97eed887edc0db60f191ddea2d4a286a5.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -10819,
+  "dataset": "marble-joined",
+  "doc_id": "cfb28c42a9e568c2360c68fa254a37f97eed887edc0db60f191ddea2d4a286a5",
+  "engine": "marble-apple-vision",
+  "event_count": 201,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "164a07648e093085b11403d35224bc8fa58018ced46939ebe28a8af04f67d031",
+  "output_sha256": "549820751a8859bb7fa028a79125f9c375798382562c675dc7ca79ccb172dc17",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/cfb723383497878f9d4837a113b7bdb706b078e04d804a5c18c1ae9dfc68b2a9.md b/vision-fixhub/ds9-unparsed-05/cfb723383497878f9d4837a113b7bdb706b078e04d804a5c18c1ae9dfc68b2a9.md
new file mode 100644
index 0000000000000000000000000000000000000000..439141e36d25768eceb90e0f7af4fc9d153f8648
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cfb723383497878f9d4837a113b7bdb706b078e04d804a5c18c1ae9dfc68b2a9.md
@@ -0,0 +1,5543 @@
+Statements
+
+
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+STEARNS
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary......
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity..........
+Trades Not Yet Settled
+Your Messages
+3
+5
+7
+7
+Hollandlold
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 29, 2002
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+18,116,298
+738,561
+674,926
+S19,529,785
+•••••••/••••••••••••
+20,844,363
+-1,314,578
+ere are no "Stop Loss' orders or other pending bu
+r sell open orders on file for your accoun
+Market Value of Your Portfolio
+$1.413.487
+$1,369.211
+Cash & Equivalent
+Equities
+| $18,116,298
+$19,475,152
+Important Message
+If any information regarding
+2002interest, dividends,
+miscellaneous income,
+gross proceeds or original
+issue discount is required
+to be reported to the IRS for
+Current market value
+Last statement's market value
+12425 31.200 17, 2003.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp..
+_ Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal purpose red de Set revere date for portant iformation.
+
+
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+STEARNS
+3 or 7
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance,
+THIS PERICO
+5695.112.61
+828.12
+43,448.42
+$44,276.54
+........
+-828.12
+-828.12
+.. . .
+43,448.42
+738.561.03
+Income Summary
+Dividends
+Credit Balance Int.
+THIS PERIOD
+44,203.12
+73.42
+544.276.54
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+695,112.61
+$695,112.61
+CLOSING
+738,561.03
+........
+5738.561.03
+027
+YEAR TO DATE
+287,026.95
+2,529.16
+$289,556.11
+1,413,487
+18,116,298
+$19,529,785
+01/01/03:09:30 001
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 29, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+7%
+Equities
+93%
+Unshaded portions denole debi balance and'or short
+
+
+STEARNS
+4 of 7
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+......
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+AOL TIME WARNER INC
+AMERICAN INTERNATIONAL GROUP
+BANK OF AMER CORP
+CITIGROUP INC
+GOLDMAN SACHS GROUP INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+.................
+JOHNSON& JOHNSON
+.. . .
+MBNA CORF
+PFIZER INC
+PROCTER & GAMBLE CO
+TYCO INTERNATIONAL LTD
+....
+SYMBOLCUSIP
+BSMXX
+QUANTITY
+674,926.45
+PRICE
+1.0000
+SIMBCLCUSIP
+AOL
+AIG
+BAC
+GS
+IBM
+JNU
+......
+KRB
+PFE
+...
+PG
+TYC
+CASH
+CASH
+CASH
+........
+CASH
+CASH
+.......
+CASH
+CASH
+......
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+50,000
+25,000
+30,000
+... ..
+27,375
+12,000
+...
+20,000
+50,000
+90.000
+75.000
+25,000
+50.000
+MARKET
+VALUE
+738,561
+674,926
+$1,413,487
+PRICE
+13.1000
+57.8500
+69.5700
+.. . .
+35.1900
+68.1000
+....
+77.5000
+53.7100
+9.0200
+30.5700
+85.9400
+.. . .
+17.0800
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 29,2002
+ESTIMATED
+ANNUAL INCOME
+8,774 1.3000
+$8,774
+MARKET
+VALUE
+655,000
+1,446,250
+2,087,100
+963,326
+..............
+817,200
+...
+1,550,000
+2,685,500
+1,711,800
+2,292,750
+2,148,500
+.. . .
+854,000
+027
+ESTIMATED
+ANNUAL INCOME
+4,700
+76,800
+....
+19,710
+1.000
+41,000
+.. . .
+25,200
+.....
+15,00
+...
+11,000
+2,500
+SURREN
+0.3250
+3.6791
+..046
+0.7048
+0.7742
+1.5267
+1.472
+1.9627
+... ..
+1.9083
+... . .
+0.2927
+.......
+
+
+STEARNS
+5 of 7
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+VIACOM INC-CL B
+Total Equities& Options
+TOTAL EQUITIES
+SIMBOUCUSIP
+VIAB
+CASH
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+TRANSACTION
+11/30/02
+12/02/02 DIVIDEND
+12/02/02 REINVEST
+SCRIPTA
+OPENINGBALANCE
+MAKE FOOLE ME, MONE
+RECORD 11/29/02 PAY 11/29/02
+MAKE TOLE ME, MONEY
+REINVEST PRICE $ 1.00
+CLOSINGBALANCE
+12/31/02
+TOTAL
+QUANTITY
+22,200
+PRICE
+40.7600
+MARKET
+VALLE
+904,872
+$18,116,298
+$18,116,298
+$282,444
+$19,529,785
+SYMBOUCUSIP
+BMXX
+QUANTITY
+674,098.33
+828.12
+674,926.45
+027
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 29,2002
+ESTIMATED
+ANNUAL INCOME
+$273,670
+$273,670
+CURRENT
+YIELD IS
+PRICE
+DEBIT AMOUNT
+828.12
+$-828.12
+828.12
+$828.12
+
+
+STEARNS
+6 of 7
+Transaction Detail (continued)
+DIVIDENDS
+DATE
+12/05/02
+DESCRIPTION
+PFIZER INC
+REC 11/15/02 PAY 12/05/02
+12/10/02 INTERNATIONAL BUSINESS™
+MACHINES CORP
+REC 11/08/02 PAY 12/10/02
+12/10/02
+*''JOHNSON& JOHNSON'''
+REC 11/19/02 PAY 12/10/02
+(2720702'''AMERICAN INTENATIONAL "CASUP
+INC
+REC 12/06/02 PAY 12/20/02
+12127/02 BANK OF AMER CORP.
+REC 12/06/02 PAY 12/27/02
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+12/23/02 INTEREST ONCREDIT BALANCE
+T 0 1/8% 11/21 THRU 12/20
+TOTAL
+SYMBOUCUSIP
+PFE
+"BM
+"BAC
+QUANTITY
+RATE (S)
+75,000
+0.1300
+20000•
+0.1500
+50,000
+25,000*
+0.2050
+0.0470
+'30,000'"
+0.6400
+SYMBOLCUSIP
+QUANTITY
+RATE (%)
+0.1250
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+01/01/03:09:30 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securites Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+November 29,2002
+9,750.00
+*3,000.00
+10,250.00
+7,175.00
+19,200.00
+$43,375.00
+CAEDIT AMOUNT
+73.42
+$73.42
+V639
+
+
+STEARNS
+7 of 7
+Trades Executed Pending Settlement
+SETLEMENT TREE
+TRANSACTION
+01/06/03 12/31/02 SOLD
+01/06/03
+12/31/02 SOLD
+TOTAL
+DESCRIPTION
+TYCO INTERNATIONAL LTD
+AVG PRICE SHOWN-DETAILS ON REQ
+ACTUAL CONFIRM TO YOUR AGENT
+DISCRETIONARY ORDER
+TYCO INTERNATIONAL LTD
+AVG PRICE SHOWN-DETAILS ON REQ
+ACTUAL CONFIRM TO YOUR AGENT
+DISCRETIONARY ORDER
+The above trades do not appear in any other section of this statement.
+Your messages
+As part of the National Association of Securities Dealers (NASD)
+Investor Education Program, you may obtain information on the
+NASD's Public Disclosure Program by contacting the NASD at
+telephone number (800) 289-9999 or via the internet address which is
+ww.nasdr.com, In addition, a brochure explaining the Publ
+sclosure Program is available from the NASD upon reques
+STOP
+****** End of Statement******
+SYMBOLGUSIP
+TYC
+QUANTITY
+-12,500.00
+PRICE
+17.0165
+TYC
+-12,500.00
+17.1509
+027
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Car
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD November 30,2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+November 29,2002
+DEBIT AMOUNT
+211,449.84
+213,129.79
+$0.00
+$424,579.63
+V639
+
+
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+STEARNS
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .......................
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25,2002
+3
+4
+5
+Hollandlold
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+19,475,152
+695,113
+674,098
+$20,844,363
+nonsensens
+20.244.221
+600,141
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$1,369.211
+$1,350.585
+Cash & Equivalent
+Equities
+$19.475,152
+$18,893,636
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+do Client Servicos at 800-634-1428; or write to Cient Servicos at Bear, Stoama Securitios
+Corp..
+_ Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal purposes rear die Set revere date for portant iformation.
+11/30/02;14:25 001
+
+
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+11/30/02;14:25 001|
+
+
+STEARNS
+3 ore
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Dabited.
+Net Cash Activity
+Closing Balance
+THIS PERIOD
+5677.773-36
+1,286.51
+17,339.25
+18,625.7
+•........
+-1,286.51
+....
+5-1,286.51
+.........
+17,339.25
+6695.112.61
+Income Summary
+Dividends
+Credit Balance Int.
+THIS PERIOD
+18,529.01
+96.75
+$18.625.76
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+677,773.36
+$677,773.36
+CLOSING
+695,112.61
+$695,112.61
+027
+YEAR TO DATE
+242,823.83
+2,455.74
+$245,279.57
+1,369,211
+19,475,152
+520844.365
+11/30/02;14:25 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAI
+Bear Steams Securites o
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+6%
+Equities
+94%
+Unshaded portions denote debe balance andor short
+V638
+
+
+STEARNS
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+........
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+AOL TIME WARNER INC
+AMERICAN INTERNATIONAL GROUP
+BANK OF AMER CORP
+CITIGROUP INC
+GOLDMAN SACHS GROUP INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+.................
+JOHNSON& JOHNSON
+.. . .
+MBNA CORF
+PFIZER INC
+PROCTER & GAMBLE CO
+TYCO INTERNATIONAL LTD
+....
+SYMBOLCUSIP
+BSMXX
+QUANTITY
+674,098.33
+PRICE
+1.0000
+SIMBCLCUSIP
+AOL
+AIG
+BAC
+GS
+IBM
+JNU
+......
+KRB
+PFE
+...
+PG
+TYC
+CASH
+CASH
+CASH
+........
+CASH
+CASH
+.......
+CASH
+CASH
+......
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+50,000
+25,000
+30,000
+.....
+27,375
+12,000
+...
+20,000
+50,000
+90.000
+75.000
+25,000
+50.000
+MARKET
+VALUE
+695,113
+674,098
+$1,369,211
+PRICE
+16.3700
+65.1500
+70.0800
+... ...
+38.8800
+78.8700
+.. . .
+87.1000
+57.0200
+21.3400
+31.5400
+84.0000
+17.8400
+"HOLLY OWNED SUBSIDIARY
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25,2002
+ANIVUAL INCOME
+.........
+9,437 1.3999
+$9,437
+MARKET
+VALLE
+818,500
+1,628,750
+2,102,400
+.......
+1,064,340
+946,440
+...
+1,742,000
+2,851,000
+1,920,600
+2,365,500
+2,100,000
+.. ..
+892,000
+027
+ESTIMATED
+ANNUAL INCOME
+4,700
+76,800
+.......
+9,710
+5,760
+...
+12,000
+41,000
+.. .
+25,200
+...
+9,000
+...
+1,00
+1,500
+11/30/02;14:25 001
+SURREN
+0.2886
+3.6530
+........
+1.8519
+0.6086
+1.688
+1.4381
+......
+1.312
+1.6487
+1.9524
+0.2803
+
+
+STEARNS
+5 org
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+VIACOM INC-CLB
+Total Equities& Options
+TOTAL EQUITIES
+SIMBOLCUSIP
+VIAB
+CASH
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+TRANSACTION
+10/26/02
+17701702 DIVIDEND
+17701/02 REINVEST
+DESCRIPTION
+OPENINGBALANCE
+MAKE FOOLE ME, MONE
+RECORD 10/31/02 PAY 10/31/02
+MAKE TOLE ME, MONEY
+REINVEST PRICE $ 1.00
+CLOSINGBALANCE
+11/29/02
+TOTAL
+QLANTITY
+22,200
+PRICE
+47.0100
+SYMBOUCUSIP
+BMXX
+BMXX
+MARKET
+_VALLE
+1,043,622
+$19,475,152
+$19,475,152
+$277,107
+$20,844,363
+QUANTITY
+672,811.82
+1,286.51
+674,098.33
+027
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25,2002
+SURREN
+$267,670
+$267,670
+PRICE
+DEBIT AMOUNT
+1,286.51
+$-1,286.51
+1,286.51
+$1,286.51
+11/30/02;14:25 001
+
+
+STEARNS
+6 of 8
+Transaction Detail (continued)
+DIVIDENDS
+DATE
+DESCRIPTION
+11/04/02
+TYCO INTERNATIONAL LTD
+REC 10/01/02 PAY 11/01/0:
+11502' ROCTER 8 GAMBLE 00"
+REC 10/18/02 PAY 11/15/02
+11/22/02
+REC 11/04/02 PAY 11/22/02
+112502 REC 102802 PAN 11250 NC
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+11/21/02
+INTEREST ON CREDIT BALANCE
+AT O 1/8% 11/06 THRU 11/20
+11/21/02 INTEREST ON CREDIT BALAN
+AT 0145. 1021 THRU 110GE
+TOTAL
+SYMBOL/CUSIP
+TYC
+PG
+GS
+SYMBOUCUSIP
+STOP
+****** End of Statement******
+QUANTITY
+RATE (S)
+50,000
+0.0125
+25,000 0.4100
+27,375
+0.1800
+12,000
+0.1200
+QUANTITY
+RATE (%)
+0.1250
+.. . .
+0.2500
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+11/30/02;14:25 001
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear Steams Securites o
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+October 25,2002
+625.00
+10,250.00
+4,927.50
+.........
+1,440.00
+$17,242.50
+35.55
+....
+51.20
+$96.75
+V638
+
+
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+STEARNS
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .......................
+3
+4
+6
+Hollandlold
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27, 2002
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+18,893.636
+677,773
+672.812
+NET EQUITY THIS PERIOD
+$20,244,221
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+18,475,552
+1,768,670
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$1.350.585
+$1,886.429
+Cash & Equivalent
+Equities
+$18.893,636
+$16,589,123
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+do Client Servicos at 800-634-1428; or write to Cient Servicos at Bear, Stoama Securitios
+Corp..
+_ Brooklyn, N.Y. 11201-3859.
+SP The surren s four or ratanal purposes red de Set revere date for portant iformation.
+V637
+
+
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+OFFICE SERVICING YOUR ACOOUNT
+STEARNS
+3 or 7
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Amount Credited
+Securities Bought
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERICO
+589.122.74
+677,690.50
+1,129,505.61
+6,309.55
+5.813.505-66
+-1,222,349.43
+-2,505.61
+$-1.224.855.04
+588,650.62
+....
+677.773.34
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+8,805.61
+9.55
+$8.815.16
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+89,122.74
+$89,122.74
+CLOSING
+677,773.36
+....
+$677,773.36
+027
+YEAR TO DATE
+224,294.82
+2,358.99
+$226,653.81
+1,350,585
+18,893,636
+$20,244,221
+"HOLLY OWNED SUBSIDIARY
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+6%
+Equities
+94%
+Unshaded portions denote debe balance andor short
+
+
+STEARNS
+4 of 7
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+......
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+AOL TIME WARNER INC
+AMERICAN INTERNATIONAL GROUP
+BANK OF AMER CORP
+CITIGROUP INC
+GOLDMAN SACHS GROUP INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+.................
+JOHNSON& JOHNSON
+....
+MBNA CORF
+PFIZER INC
+PROCTER & GAMBLE CO
+TYCO INTERNATIONAL LTD
+....
+SYMBOLCUSIP
+BSMXX
+QUANTITY
+672,811.82
+PRICE
+1.0000
+SIMBCLCUSIP
+AOL
+AIG
+BAC
+GS
+IBM
+JNU
+......
+KRB
+PFE
+...
+PG
+TYC
+CASH
+CASH
+CASH
+........
+CASH
+CASH
+.......
+CASH
+CASH
+......
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+50,000
+25,000
+30,000
+......
+27,375
+12,000
+...
+20,000
+50,000
+90.000
+75.000
+25,000
+50.000
+MARKET
+VALUE
+677,773
+672,812
+$1,350,585
+PRICE
+14.7000
+65.4100
+69.8200
+.. . .
+35.7000
+73.9900
+......
+74.5600
+57.7600
+9.8900
+31.9000
+88.7000
+15.4000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+ANNUAL INCOME
+ESTIMATE CURRENT
+11,371
+1.6901
+$11,371
+MARKET
+VALUE
+735,000
+1,635,250
+2,094,600
+977,288
+887,880
+1,491,200
+2,888,000
+1,790,100
+2,392,500
+2,217,500
+.. . .
+770,000
+027
+ESTIMATED
+ANNUAL INCOME
+4,700
+76,800
+....
+19,710
+5,760
+... .
+12,000
+41,000
+.. .
+25,200
+...
+9,00
+.....
+41,000
+2,500
+SURREN
+0.2874
+3.6666
+... ..
+2.0168
+............
+0.6487
+•......
+).804
+1.4197
+....
+407
+...
+1.630
+... ..
+1.8489
+----.....
+0.3247
+.........
+VE37
+
+
+STEARNS
+5 of 7
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+VIACOM INC-CL B
+Total Equities& Options
+TOTAL EQUITIES
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+SIMBOLCUSIP
+VIAB
+CASH
+QUANTITY
+22,200
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT TRADE
+DATE
+TRANSACTION
+10/07/02
+10/02/02
+BOUGHT
+10107/02 70/02/02"BOUGHT
+DESCRIPTION
+AMERICAN INTERNATIONAL GROUP
+DISCRETIONARY ORDER
+BANK OF AMER CORP
+DISCRETIONARY ORDER
+INTEANATONAL BUSINESS
+MACHINES CORP
+DISCRETIONARY ORDER
+PRICE
+45.6900
+MARKET
+1.014.318
+$18,893,636
+$18,893,636
+$279,041
+$20,244,221
+CURRENT
+YIELD IS
+$267,670
+$267,670
+SYMBOLICUS.P
+AIG
+"BAC
+QUANTITY
+5,000
+5,000
+10,000
+PRICE
+57.35000
+64.36000
+60.66000
+027
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+DEBIT AMOUNT
+288,519.93
+323,729.97
+870,099.55
+VE37
+
+
+STEARNS
+6 of 7
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SATEMENT TRIE
+TRANSACTION
+T0/24/02 10/21/02
+SOLD
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+09/28/02
+10/01:02
+"DIVIDEND
+10/01/02
+"REINVEST
+10/07/02 SOLD
+10/25/02
+TOTAL
+SYMBOLICUSIP
+VIAB
+QUANTITY
+-14,800
+PRICE
+46.06840
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Cam
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27, 2002
+DEBIT AMOUNT
+677,690.50
+$-1,222,349.43
+$677,690.50
+DESCAIPTION
+OPENINGBALANCE
+MARTINE, MONEY
+RECORD 09/30/02 PAY 09/30/02
+ARE TORE CE, MONEY
+CLOSINGBALANCE
+SYMBOUCUSIP
+BMXX
+BMXX
+QUANTITY
+1,797,306.21
+2,505.61
+=1,127,000
+672,811.82
+PRICE
+DEBIT AMOUNT
+2.505.61
+2,505.6
+1.00001,127,000.00
+$-2,505.61
+$1,129,505.61
+027
+
+
+STEARNS
+7 of 7
+Transaction Detail (continued)
+DIVIDENDS
+DESCRIPTION
+1001102 MENACORP
+REC 09/16/02 PAY 10/01/02
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+10/21/02
+INTEREST ON CREDIT BALANCE
+4T 0 1/4% 09/21 THRU 10/20
+TOTAL
+SYMBOUCUSIP
+KRB
+SYMBOL/CUSIP
+STOP
+****** End of Statement******
+QUANTITY
+90,000
+QUANTITY
+RATE (S)
+0.0700
+RATE INI
+0.2500
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27, 2002
+6,300.00
+$6,300.00
+9.55
+$9.55
+
+
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear. Steams Securities C
+STEARNS
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ........................................
+Your Messages
+3
+5
+7
+Hollandlold
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+Market Value of Your Portfolio
+$1,886.429
+$1,846,149
+16,589,123
+89,123
+1,797,306
+$18,475,552
+......
+19,585,730
+-1,110,179
+Cash & Equivalent
+Equities
+| $16,589,123
+$17,739,581
+Current market value
+Last statement's market value
+Important Message
+Confirmation: Unless we
+hear from you to the
+contrary, it is our
+understanding that any free
+credit balances in your
+account are being
+maintained to facilitate
+sour intentions things us.
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp..
+Brooklyn, N.Y. 11201-3859.
+SIP The suremen is four or ratanal purger red de Set revere date for portant iformation.
+V636
+
+
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+STEARNS
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Dabited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+$51,671.45
+... ..
+2,828.67
+37,451.29
+$40,279.96
+......
+-2,828.67
+......
+5-2,828.67
+.. . .
+37,451.29
+689,122.74
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+40,268.67
+11.29
+540.279.96
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+total.
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+51,671.45
+$51,671.45
+CLOSING
+89,122.74
+.....
+$89,122.74
+027
+YEAR TO DATE
+215,489.21
+2,349.44
+.....
+5217,838.65
+1,886,429
+16,589,123
+518,475,552
+EARED THROUGH F
+HOLLY OWNED SUBSIDIAR
+Bear Steams Securites o
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+10%
+Equities
+90%
+Unshaded portions denote debe balance andor short
+
+
+STEARNS
+4 of a
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+... . .
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+AOL TIME WARNER INC
+AMERICAN INTERNATIONAL GROUP
+BANK OF AMER CORP
+CITIGROUP INC
+GOLDMAN SACHS GROUP INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+.................---------
+JOHNSON& JOHNSON
+....
+MBNA CORF
+PFIZER INC
+PROCTER & GAMBLE CO
+TYCO INTERNATIONAL LTD
+....
+SYMBOLCUSIP
+BSMXX
+QUANTITY
+1,797,306.21
+PRICE
+1.0000
+SIMBCLCUSIP
+AOL
+AIG
+BAC
+GS
+IBM
+JNU
+......
+KRB
+PFE
+...
+PG
+TYC
+CASH
+CASH
+CASH
+........
+CASH
+CASH
+.......
+CASH
+CASH
+......
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+50,000
+20,000
+25,000
+....
+27,375
+.............
+12,000
+.. ..
+10,000
+50,000
+90.000
+75,000
+25,000
+50.000
+MARKET
+VALUE
+89,123
+1,797,306
+$1,886,429
+PRICE
+12.1200
+55.2300
+64.0800
+.. . .
+29.0200
+66.1300
+......
+60.3600
+55.1000
+18,7400
+28.5800
+88.1300
+14.4300
+"HOLLY OWNED SUBSIDIARY
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+ESTIMATED
+ANVUAL INCOME
+.. . . .
+30,015 1.6700
+$30,015
+MARKET
+VALUE
+606,000
+1,104,600
+1,602,000
+.....
+794,423
+..............
+793,560
+.......
+603,600
+2,755,000
+1,686,600
+.. . .
+2,143,500
+2,203,250
+.. . .
+721,500
+027
+ESTIMATED
+ANNUAL INCOME
+3,760
+60,000
+....
+19,710
+.............
+41,000
+.. . .
+25,200
+...
+19,000
+... .
+41,000
+2,50
+SURREN
+0.3404
+3.7453
+2.4810
+0.7258
+......
+0.9940
+1.4882
+1.4941
+•.........
+1.8195
+......
+1.8609
+0.3465
+
+
+STEARNS
+5 org
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+VIACOM INC-CL B
+Total Equities& Options
+TOTAL EQUITIES
+SIMBOLCUSIP
+VIAB
+CASH
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+TRANSACTION
+08/31/02
+09/03/02 DIVIDEND
+09/03/02 REINVEST
+SCRIPTA
+OPENINGBALANCE
+ARE TORTOLE ME, MONE
+RECORD 08/30/02 PAY 08/30/02
+MAKE TOLE ME, MONEY
+REINVEST PRICE $ 1.00
+CLOSINGBALANCE
+09/27/02
+TOTAL
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+ESTIMATEL
+ANNUAL INCOME
+$243,930
+$243,930
+URREN
+QUANTITY
+37,000
+PRICE
+42.5700
+SYMBOU/CUSIP
+BMXX
+BMXX
+MARKET
+VALLE
+1,575,090
+$16,589,123
+$16,589,123
+$273,945
+$18,475,552
+QUANTITY
+1,794,477.54
+2,828.67
+1,797,306.21
+027
+PRICE
+DEBIT AMOUNT
+2.828.67
+$-2.828.67
+*2,828.67
+$2.828.67
+
+
+BEARR
+STEARNS
+6 ofa
+Transaction Detail (continued)
+DIVIDENDS
+DATE
+DESCRIPTION
+09/05/02
+PFIZER INC
+REC 08/16/02 PAY 09/05/02
+09/10/02 INTERNATIONAL" BUSINESS™
+MACHINES CORP
+REC 08/09/02 PAY 09/10/02
+09/10/02
+*''JOHNSON& JOHNS®N"***
+REC 08/20/02 PAY 09/10/02
+09120702''AMERICAN "INTEANATONAL "CASUP"
+INC
+REC 09/06/02 PAY 09/20/02
+09/27/02 BANK OF AMER CORP.
+REC 09/06/02 PAY 09/27/02
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+19/23/02 INTEREST ONCREDIT BALANCI
+T 0 1./4% 08/21 THRU 09/2
+TOTAL
+SYMBOUCUSIP
+PFE
+"BM"
+"BAC
+QUANTITY
+RATE (S)
+75,000
+0.1300
+10,000
+0.1500
+50,000
+20,000*
+0.2050
+'0.0470
+'25,000•T
+0.6000
+SYMBOLCUSIP
+QUANTITY
+RATE (S)
+0.2500
+027
+LEARED THROUGH I7
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Secuiles Co
+DEBIT AMOUNT
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+9,750.00
+1,500.00
+10,250.00
+*940.00
+15,000.00
+$37,440.00
+DEBIT AMOUNT
+11.29
+$11.29
+
+
+STEARNS
+7 of a
+Your messages
+Bear, Stearns Securities Corp, Net Capital and Net Capital
+Requirements:
+A complete copy of the Bear, Stearns Securities Corp, Statement
+of Financial Condition is available on the web site
+www.bearstearns.com, Alternatively, to request a free printed copy
+please call -toll free 1-866-299-9331.
+Bear, Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+August 30, 2002
+Securities and other assets in your account are the firm's collateral
+for any margin loan made to you. If the securities and other assets in
+your account decline in value, so does the value of the collateral
+supporting your loan, and, as a result, the firm can take action, such
+the following:
+> You can lose more funds than you deposit in the margin account.
+> The firm can force the sale of securities or other assets in your
+accounts).
+> The firm can sell your securities or other assets without contacting
+> You are not entitled to choose which securities or other assets in
+your accounts) are liquidated or sold to meet a margin call.
+> The firm can increase its "house" maintenance margin requirements
+at any time and is not required to provide you advance written notice.
+> You are not entitled to an extension of time on a margin call.
+027
+
+
+STEARNS
+8 of 8
+13P
+This statement is provided to explain Bear, Steams & Co. Inc.'s
+(BSC*) payment for order flow practices.
+STOP
+****** End of Statement******
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+Pursuant to SEC Rule 11Ac1-6, please note the following:
+Bear, Stearns & Co, Inc, will post its quarterly routing statistics at the
+following web link:
+htp:/igpraeacesams.combeasteams/ndhvidualivestorequitesord
+Customers of Bear, Stearns & Co. Inc, may request information on
+any order executed within the prior six months from the time of the
+request, Specifically, you may request the identity of the venue to
+which the identified orders were routed for execution, whether the order
+was directed by you to that venue, and the time of the executions, i
+any, that resulted from such orders.
+027
+V636
+
+
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+STEARNS
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ....
+Your Portfolio Holdings
+Transaction Detail
+«aaaaaaaaaaaaaaas aaaaaaaaaaasan
+Fund Activity
+3
+4
+5
+7
+Hollandlold
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+17,739,581
+51,671
+1,794,478
+$19,585,730
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+17,673,826
+1,911,904
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$1.846,149
+$3.037.258
+Cash & Equivalent
+Equities
+$17,739,581
+$14,636,568
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp..
+_ Brooklyn, N.Y. 11201-3859.
+SP The suren s four or ratanal purposes rear die Set revere date for portant iformation.
+
+
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+STEARNS
+3 ora
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERIOD
+51.05,294.02
+65,545.86
+213,549.14
+16,826.29
+27.90
+$295,949.19
+.. . .
+-1,276,540.62
+-3,031.14
+$-1,279,571.76
+.....
+-983,622.57
+561.671.45
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+19,648.64
+208.79
+.$19.857.43
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OFENING
+1,035,294.02
+$1,035,294.02
+CLOSING
+51,671.45
+$51,671.45
+....
+027
+YEAR TO DATE
+175,220.54
+2,338.15
+.....
+$177.558.69
+1,846,149
+17,739,581
+....
+$19,585,730
+.....
+"HOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+Equities
+91%
+Unshaded portions denote debe balance andor short
+
+
+OFFICE SERVICING YOUR ACOOUNT
+STEARNS
+4 of a
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+....... .
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+AOL TIME WARNER INC
+•••••••••••••••••••••••••••••••••
+MERICAN INTERNATIONAL GROU
+INC
+... . .
+ANK OF AMER COR
+... . . .
+CITIGROUP INC
+GOLDMAN SACHS GROUP INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JOHNSON& JOHNSON
+MENA CORP
+PFiZER INC
+PROCTER & GAMBLE CO
+TYCO INTERNATIONAL LTD
+SYMBOLCUSIP
+BSMXX
+QUANTITY
+1,794,477.54
+PRICE
+1.0000
+SYMBCUCUSIP
+AOL
+AIG
+BAC
+GS
+IBM
+JNJ
+KRB
+PFE
+PG
+"TYC
+CASH
+•••••••••••
+CASH
+CASH
+.....
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+50,000
+••••••••••••
+20,000
+25,000
+•..........
+27,375
+12,000
+....
+10,000
+50,000
+90,000
+75,000
+25,000
+.....
+50,000
+MARKET
+VALUE
+51,671
+1,794,478
+$1,846,149
+PRICE
+12.6500
+62.8000
+70.0800
+32.7500
+77.3000
+75.3800
+54.3100
+20.2000
+33.0800
+88.6500
+15.6900
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+ESTIMATED
+ANNUAL INCOME
+30,506
+1.7000
+$30,506
+MARKET
+VALUE
+632,500
+1,256,000
+1,752,000
+....
+896,531
+927,600
+753,800
+2.715,500
+1.818,000
+2.481,000
+2216,250
+... .
+784.50
+027
+ESTIMATE
+NNUAL INCON
+CURRENT
+YIELD IN
+3,760 02994
+0.2994
+60,000
+19,710
+5,760
+41,000*
+25.200
+39,000
+41.000
+2500
+3.4247
+........
+2.1985
+....
+0.6210
+... ...
+0.7960
+5099
+3861
+5719
+1.8500
+0.3187
+
+
+STEARNS
+5 or 8
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+VIACOM INC-CL B
+Total Equities& Options
+TOTAL EQUITIES
+SYMBCUCUSIP
+VIAB
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+ACCT
+CASH
+QUANTITY
+37,000
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TRE
+DATE
+TRANSACTION
+08/20/02 08/15/02
+BOUGHT
+68/20/02 08/15/02 "BOUGHT
+08/2002 08/20/02
+•''SOLD
+DESCRPTION
+AOL TIME WARNER ING
+DISCRETIONARY ORDER
+"TYCO INTERNATIONAL " LTD"
+DISCRETIONARY ORDER
+"TRAVELERS PROPERTY CASUALTY
+CORP CLASS B
+WHEN, AS & IF ISSUED
+DISCRETIONARY ORDER
+PRICE
+40.7000
+MARKET
+VALUE
+1,505,900
+$17,739,581
+$17,739,581
+$274,436
+$19,585,730
+ESTIMATED
+ANNUAL INCOME
+$243,930
+$243,930
+CURRENT
+YIELD (%)
+SYMBOLCUSIP
+AOL
+TYC
+QUANTITY
+50,000
+50,000
+2,429
+PRICE
+12.00000
+• 13.30000
+18.74000
+027
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26,2002
+DEBIT AMOUNT
+605,621.90
+870,918.72
+
+
+STEARNS
+6 of a
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SETTLEMENT TRADE
+DATE
+TRANSACTION
+08/21/02
+08/20/02
+68/21/02 08/20/02*"SOLD
+08/23/02
+''*08/20/02
+''''SOLD
+08/26/02 08/21/02 BOUGHT
+08/26/02
+08/24/02
+"BOUGHT
+08/26/02
+TOTAL
+08/20/02
+'SOLD
+DESCRIPTION
+TRAVELERS PROPERTY CASUALTY
+CORP CLASS B
+WHEN-ISSUE RESCINDED
+DISCRETIONARY ORDER
+TO CAL PREVIOUS SELL
+THAVELERS" PHOPERTY CASUALYY
+DORP CLASS E
+WHEN, AS & IF ISSUED
+AS OF 0802002 ORDER
+"TRAVELERS PROPERTY CASUALTY
+DOSE TONARY ORDER
+TRAVELERS PROPERTY CASUALTY
+SPINOFF ON 27375 SHS
+SPINOR FROM SEC # CO07878
+REC 08/09/02 PAY 08/20/02
+"TRAVELERS PROPERTY CASUALTY
+SPINOFF ON 27375 SHS
+CITIGROUP INC
+SEC 080802 PE 820107779
+"TRAVELERS PROPERTY CASUALTY
+OAP CLASS B
+NHEN-ISSUE EXTENDE
+DISCRETIONARY ORDE
+S OF 08/20/0:
+SYMBOLICUSIP
+TAPB
+TAPB
+TAPB
+027
+QUANTITY
+2,429
+2,429
+1,182
+1,182
+PRICE
+18.74000
+"17:25000"
+2,429
+-2,429
+18.74000
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+DEBIT AMOUNT
+CRECIT AMOUNT
+20,270.68
+45,275.18
+$-1,276,540.62
+$65,545.86
+
+
+STEARNS
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+07/27/02
+08/0102 DIVIDEND
+08/01/02 REINVEST
+08/22/02 SOLD"
+08/30102
+TOTAL
+DESCRIPTION
+OPENINGBALANCE
+RARE FEARS TOME, MONEY
+RECORD 07/31/02 PAY 07731102
+MAKE ENSE ME, MONEY
+REINVEST PRICE $1.00
+"AKE PORTILE ME, MONEY
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+DESCRIPTION
+08/15/02
+PROCTER & GAMBLE CO
+REC 07/19/02 PAY 08/15/02
+08/23/02 CMGROUP INC..
+REC 08/05/02 PAY 08/23/02
+0829/02
+. . . .
+OLDMAN SACHS GROUP I
+REC 07/30/02 PAY 08/29/02
+TOTAL
+GS
+SYMBOUCUSIP
+BMXX
+QUANTITY
+25,000
+27,375
+12,000
+QUANTITY
+2,001,964.40
+3,031.14
+210,518
+1,794,477.54
+RATE (S)
+0.4100
+0.1800
+0.1200
+027
+1.0000
+DEBIT AMOUNT
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Secuties
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+DEBIT AMOUNT
+3,031.14
+3,031.14
+210,518.00
+$-3,031.14
+$213,549.14
+10,250.00
+4,927.50
+1,440.00
+$16,617.50
+
+
+STEARNS
+8 of a
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+08/21/02
+INTEREST ON CREDIT BALANCE
+AT 0 1/4% 07/21 THRU 08/20
+TOTAL
+MISCELLANEOUS
+DATE
+MODAY
+08/30/02
+TRANSACTION
+CASH-LIEU
+SYMBOL/CUSIP
+0830/02
+'CASH LIEU
+DESCRIPTION
+TRAVELERS PROPERTY CASUALTY
+CORP CL A
+GEROUP IN 71767
+SENOF FROM SEC # 2007878
+CORP CLASS PROPERTY CASUALTY
+CASH IN LIEU OF .95811
+CITIGROUP INC
+REC 08/08/02 PAY 08/20/02
+SPINOFF FROM SEC # C007878
+TOTAL
+STOP
+****** End of Statement******
+QUANTITY
+RATE (%)
+0.2500
+DEBIT AMOUNT
+027
+DEBIT AMOUNT
+11 44
+16.46
+$27.90
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+208.79
+$208.79
+
+
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+STEARNS
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary .............................
+Your Portfolio Holdings
+Transaction Detail ..................…..............
+Fund Activity ........••••.••••••••••I•IIIIIIIIIII
+3
+4
+5
+6
+Hollandlold
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+14,636.568
+1,035,294
+2,001,964
+$17,673,826
+...
+20.316.814
+-2,642,988
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$3.037,258
+$2,207,043
+Cash & Equivalent
+Equities
+$14,636,568
+# $18,109,771
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+do Client Services at 800-634-1428; or write to Cient Servicos at Bear, Stoama Securitios
+Corp..
+_ Brooklyn, N.Y. 11201-3859.
+SP The suremen is foul ratanal purger red de Set revere dae for portant iformation.
+07/27/02;17:22 001
+
+
+Bear. Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+07/27/02;17:22 001
+
+
+STEARNS
+3 ore
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+mount Debite
+Net Cash Activity
+Closing Balance
+THIS PERICO
+5207.043.26
+822,177.88
+1,964.40
+6,072.88
+$830,215.16
+.....
+-1,964.40
+.. 1964.40
+828,250.76
+S.035.294.02
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+207,043.26
+$207,043.26
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+7,964.40
+72.88
+$8.037.28
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+CLOSING
+1,035,294.02
+$1.035,294.02
+YEAR TO DATE
+155,571.90
+2,129.36
+.....
+$5157.701.28
+3,037,258
+14,636,568
+.......
+$17,673.826
+.............
+07/27/02;17:22 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+Your Portfolio
+Allocation
+fash & Equivalent-
+Equities
+82%
+Unshaded portions denote debe balance andor short
+
+
+STEARNS
+4 org
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+..........
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+AMERICAN INTERNATIONAL GROUP
+BANK OF AMER CORP*
+GOLDMAN SACHS GROUP INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JOHNSON& JOHNSON
+MBNA CORPI*
+PFIZER INC
+PROCTER & GAMBLE CO
+VIACOM INC-CLB
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+BSMXX
+QUANTITY
+2,001,964.40
+1.0000
+SYMBOUCUSIP
+AIG
+BAC
+GS
+•a•a
+IBM
+JNJ
+CRE
+PFE
+VIAB
+Дост
+CASH
+CASH
+.. . .
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+20,000
+25,000
+......
+27,375
+...
+12,000
+10,000
+50,000
+-...
+0,00
+75,000
+25,000
+37,000
+"HOLLY OWNED SUBSIDIARY
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+MARKET
+VALUE
+1,035,294
+2,001,964
+$3,037,258
+ESTIMATED
+INNUAL INCOME
+•••••••••••••••••••••••••••••••
+35,435
+1.7700
+$35,435
+PRICE
+56.8200
+61.6500
+30.7400
+69.5800
+.. . .
+66.4000
+49.6100
+
+29.4600
+84.2000
+34.3500
+MARKET
+VALUE
+1,136,400
+1,541,250
+841,508
+... .
+334,960
+664,000
+2,480,500
+1552,500
+2.209,500
+105.00
+1,270,950
+$14,636,568
+$14,636,568
+027
+ESTIMATEC
+ANNUAL INCOME
+3,760
+60,000
+... ...
+19,710
+......
+41,000
+25,200
+39.000
+41.000
+$241,430
+$241,430
+07127102;17:22 001
+SURREN
+YIELD IS
+0.3309
+3.8929
+2.3422
+........
+0.6899
+....
+0.9036
+6529
+L6232
+7651
+1.9477
+
+
+STEARNS
+5 or 8
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+TRANSACTION
+07/12/02 07/09/02
+SOLD
+07/19/02
+''07/16/02
+"BOUGHT"
+07/24/02
+07/19/02
+SOLD
+TOTAL
+DESCRIPTION
+WYETH
+ANG PRICE SHOWN DETAILS ON REO
+CTUAL CONFIRM TO YOUR AGEN
+ISCRETIONARY ORDE
+MENAC. --
+K SPLIT ON 60000 SH
+© 07/01/02 PAY 07/15/0
+WETH
+COM
+AVG PRICE SHOWN-DETAILS ON REC
+ACTUAL CONFIRM TO YOUR AGENT
+$276,865
+$17,673,826
+SYMBOLCUSP
+WYE
+QUANTITY
+-12,000
+PRICE
+39.72150
+"KAB
+WYE
+30,000
+12,000
+29.24540
+027
+07127102;17:22 001
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+DEBIT AMOUNT
+CRECAT AMOUNT
+474,243.65
+347,934.23
+$822,177.88
+
+
+STEARNS
+6 of 8
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+06/29/02
+07/01/02 DIVIDEND
+07/01/02
+REINVEST
+DESCRIPTION
+OPENINGBALANCE
+RARE TORPET ME, MONEY
+RECORD 06/28102 PAY 06/28102
+MAKE PORT LOVE, MONEY
+REINVEST PRICE $ 1.00
+CLOSINGBALANCE
+07/26/02
+TOTAL
+DIVIDENDS
+DATE
+DESCRUPTION
+07/01/02
+MBNA CORP
+REC 06/14/02 PAY 07/01/02
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+07/22/02 INTEREST ON CREDIT BALANCE
+AT 0 1/4% 06/21 THRU 07/20
+TOTAL
+SYMBOUGUSIP
+BMXX
+BMXX
+SYMBOUCUSIP
+KAB
+QUANTITY
+60,000
+SYMBOUCUSIP
+QUANTITY
+QUANTITY
+2,000,000
+1,964.40
+2,001,964.40
+RATE (S)
+0.1000
+RATE (%)
+0.2500
+027
+PRICE
+DEBIT AMOUNT
+DEBIT AMOUNT
+07127102;17:22 001
+LEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear. Steams Secuties
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28,2002
+DEBIT AMOUNT
+1,964.40
+1,964.40
+$-1,964.40
+$1,964.40
+6,000.00
+$6.000.00
+72.88
+$72.88
+
+
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+STEARNS
+ACCOUNT EXECUTIVE
+GREENBERG,ALAN C.
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ....
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ....
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+3
+6
+Hollandiml
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+Market Value of Your Portfolio
+$2,207,043
+$1,446.139
+18,109,771
+207,043
+2,000,000
+$20,316,814
+.....
+21,568,112
+-1,251,298
+Cash & Equivalent
+Equities
+$18,109,771
+# $20,121,973
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+do Client Services at 800-634-1428; or write to Cient Servicos at Bear, Stoama Securitios
+Corp..
+_ Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal purposes reard Set revere date for portant iformation.
+
+
+Bear. Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+06/29/02;10:49 001|
+
+
+STEARNS
+3 or 7
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+51.446.139.08
+717,799.46
+43,104.72
+$760,904.18
+......
+-2,000,000.00
+.....
+5-2,000,000.00
+..._.......
+-1,239,095.82
+207.043.28
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+42,860.00
+244.72
+$43,104.72.
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+1,446,139.08
+$1,446,139.08
+CLOSING
+207,043.26
+.........
+$207,043.26
+027
+YEAR TO DATE
+147,607.50
+2,056.48
+----.
+.5149.663.98
+2,207,043
+18,109,771
+....
+$20,316,814
+06/29/02;10:49001
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+10%
+Equities
+90%
+Unshaded portions denote debe balance andor short
+
+
+STEARNS
+4 of 7
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+........... ..
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRPTION
+AMERICAN INTERNATIONAL GROUP
+BANK OF AMER CORP
+..... .
+CITIGROUP INC
+GOLDMAN SACHS GROUP INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JOHNSON& JOHNSON'
+MENA CORP.*.
+PFIZER INC
+PROCTER & GAMBLE CO
+VIACOM INC.CLE
+SYMBOLCUSIP
+BSMXX
+QUANTITY
+2,000,000
+1.0000
+SYMBCUCUSIP
+AIG
+BAC
+GS
+•a•a
+IBM
+JNU
+KRE
+PFE
+"PG
+VIAB
+CASH
+CASH
+.....
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+20,000
+25,000
+27,375
+.....
+12,000
+...........
+10,000
+50,000
+.......
+60,000
+75,000
+25,000
+37,000
+MARKET
+JALUE
+207,043
+2,000,000
+$2,207,043
+PRICE
+68.2300
+70.3600
+38.7500
+73.3500
+.........
+72.0000
+52.2600
+.....
+33.0700
+35.0000
+89.3000
+4.370
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+MAN INCONS
+35,600
+$35,600
+....
+1.7800
+MARKET
+VALUE
+1,364,600
+1,759,000
+.....
+1,060,781
+880,200
+.......
+720,000
+2,613,000
+.........
+1.984.20(
+2.625,000
+.....
+2,232,500
+641.69
+ESTIMATED
+ANNUAL INCOME
+3,760
+.......
+60,000
+......
+19.710
+5,760
+6000
+41,000
+.....
+24,00đ
+39,000
+......
+8,00
+CURRENT
+YIELD I%
+0.2755
+3.4110
+1.8581
+0.6544
+.....
+0.8333
+.5691
+1.2096
+4851
+1.702
+027
+
+
+STEARNS
+5 of 7
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+WYETH
+COM
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+WYE
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+ACCT
+CASH
+QUANTITY
+24,000
+Transaction Detail
+INVESTMENT ACTIVITY
+TRANSACTION
+06/06/02 06/03/02
+BOUGHT
+06/06/02 86/03/02"SOLD
+••••••••••••••••••••••
+DESCRIPTION
+SMUCKER JM COMPANY
+NEW
+PINOFF ON 25000 SH
+ROCTER & GAMBLE C
+SEC 052902 PAY 0603102
+SMUCKER JM COMPANY*
+NEW
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+..............
+PRICE
+51.2000
+MARKET
+VALUE
+1,228,800
+$18,109,771
+$18,109,771
+$294,910
+$20,316,814
+ESTIMATED
+ANNUAL INCOME
+22,080
+$259,310
+$259,310
+CURRENT
+YIELD (%)
+1.7969
+SYMBOLCUSP
+SUM
+QUANTITY
+500
+500
+PRICE
+'35.07340
+027
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+DEBIT AMOUNT
+-77,273.14
+
+
+STEARNS
+6 of 7
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SATEMENT TREE
+DATE
+TRANSACTION
+06/07/02 06/04/02
+SOLD
+DESCRIPTION
+BRISTOL MYERS SQUIBB CO
+WITH RIGHTS TO PURCHASE PREFRD
+TK UNDER CERTAIN CIRCUMSTANC
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+TRANSACTION
+06/01/02
+06/11702 BOUGHT
+DESCRIPTION
+OPENINGBALANCE
+MAKES PORTED ME MONEY.
+06/28/02
+TOTAL
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+DESCRIPTION
+06/03/02
+WYETH
+COM
+REC 05/13/02 PAY 06/01/02
+06/06/02'P#I2ER'IN'C'''
+REC 05/17102 PAY 06/06/02
+SYMBOUCUSIP
+WYE
+SYMBOL/GUSP
+BMY
+QUANTITY
+-25,000
+PRICE
+28.21220
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Car
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+DEBIT AMOUNT
+700,526.32
+$717,799.46
+SYMBOUCUSIP
+"ESMXX"
+QUANTITY
+0.00
+2,000,000
+2,000,000
+PRICE
+1:0000"
+QUANTITY
+24,000
+RATE (SI
+0.2300
+75,000 01300
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+2.088,000.00
+$-2,000,000.00
+5,520.00
+9,750.00
+
+
+STEARNS
+7 of 7
+Transaction Detail (continued)
+DIVIDENDS (continued)
+06/10102
+DESCRIPTION
+INTERNATIONAL BUSINESS
+MACHINES CORP
+REC 05/10/02 PAY 06/10/02
+06/11/02
+REC 05/21/02 PAY 06/11/02
+06/74/02*
+'''MERICAN INTERNATIONAL GROUP
+LEG 0607102 PAY 061402
+06/28/02
+TOTAL
+BANK OF AMER CORP
+REC 06/07/02 PAY 06/28/02
+INTEREST
+DATE
+DESCRIPTION
+06/21/02 INTEREST ON CREDIT BALANCE
+AT 0 1/4% 05/21 THRU 06/20
+TOTAL
+SYMBOUCUSIP
+IBM
+UNJ
+AIG
+BAC
+SYMBOUCUSIP
+STOP
+****** End of Statement******
+QUANTITY
+10,000
+50,000*
+0,00
+25,000
+QUANTITY
+RATE (S)
+0.1500
+0.2050
+0.0420
+0.6000
+RATE (%)
+0.2500
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+1,500.00
+*10,250.00
+840.00
+5,000.0
+$42,860.00
+244.72
+$244.72
+
+
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Co
+STEARNS
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary.............................
+Your Portfolio Holdings
+Transaction Detail
+3
+3
+5
+Hollandlold
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26, 2002
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+20,121,973
+1,446,139
+$21,568,112
+21,847,728
+-279,616
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$1,446.139
+$1,422,974
+Cash & Equivalent
+Equities
+$20,121.973
+$20.424,754
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as delivered to you.
+to Client Services at 800 634-1428; or writa to Cient Services at Bear, Steams Securities
+Corp.,
+Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal fryer red de Set revere ate for portant iformation.
+
+
+2 of 5
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+STEARNS
+3 of5
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+1,422,973.76
+$1,422,973.76
+THIS PERIOD
+51.422,973.76
+23,165.32
+$23,165.32
+23,165.32
+$1.446.139.08
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+22,867.50
+297.82
+$23,165.32
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total.
+YEAR TO DATE
+104,747.50
+1,811.76
+••*********••--.
+5106,559.26
+1,446,139
+20,121,973
+....
+$21,568,112
+CLOSING
+1,446,139.08
+...........
+$1,446,139.08
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBCLCUSIP
+QUANTITY
+PRICE
+MARKET
+VALUE
+1.446,139
+$1,446,139
+STIMAT
+NUAL INCON
+027
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securites o
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+6%
+Equities
+94%
+Unshaded portions denote debit balance and or shart
+
+
+STEARNS
+4 of 5
+Your Portfolio Holdings (continued)
+EQUITIES
+Equities & Options
+DESCRIPTION
+AMERICAN INTERNATIONAL GROUP
+.. . . .
+INK OF AMER CO
+...... .
+RISTOL MYERS SQUIBB CO
+CITIGROUP IN ...
+GOLDMAN SACHS GROUP INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JOHNSON& JOHNSON
+MIBNA CORP
+PFIZER INC
+PROCTER & GAMBLE CO
+VIACOMING CLB
+WETH
+COM
+Total Equities& Options
+TOTAL EQUITIES
+SYMBCLCUSIP
+AIG
+BAC
+BMY
+IBM
+JNU
+PFE
+PG
+VIAB
+WYE
+CASH
+CASH
+......
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+20,000
+25,000
+**.....
+25,000
+...---•-.
+27,375
+2,000
+--..
+10,000
+50,000
+0,00
+75,000
+15,000
+37,000
+24,000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+PRICE
+66.9700
+75.8100
+31.1200
+--.•
+3.1800
+75.4500
+..--..
+80.4500
+61.3500
+36.2100
+4.600C
+89.5500
+48.9600
+55.5000
+MARKET
+VALUE
+1,339,400
+.895,250
+778,000
+.. . .
+182,053
+905,400
+804,500
+3,067,500
+2.172,600
+2,595,000
+238,75
+1,811,520
+1,332,000
+$20,121,973
+$20,121,973
+$287,310
+$21,568,112
+027
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26, 2002
+ESTIMATE
+NNUAL INCOM
+3,760
+CURRENT
+YIELD (S
+0.2807
+60.000 3.165
+3.1658
+.....
+28,000
+****•
+3.5990
+9,71
+.....
+1.6674
+,760
+.6362
+6.000
+......
+.745
+41.000
+24,000
+39.000
+8,00
+3366
+1.1047
+.....
+1.502
+L6974
+22,080
+$287,310
+$287,310
+1.6577
+
+
+STEARNS
+5 of 5
+Transaction Detail
+DIVIDENDS
+D5501102
+DESCRIPTION
+BRISTOL MYERS SQUIBB C
+IEC 04/05/02 PAY 05/01/0
+05/15/02 PROCTER & GAMBLE 00**
+REC 04/19/02 PAY 05/15/02
+05/24/02
+'CITIGROUP INC...
+REC 05/06/02 PAY 05/24/02
+062002 0 0M3052CAN BOUNC
+TOTAL
+INTEREST
+DATE
+DESCRPTION
+05/21/02
+INTEREST ON CREDIT BALANCE
+AT 0 1/4% 04/21 THRU 05/20
+TOTAL
+SYMBOL/CUSIP
+BMY
+"PG**
+GS
+SYMBOL/GUSIP
+STOP
+****** End of Statement******
+QUANTITY
+RATE (S)
+25,000
+0.2800
+25,000 0.3800
+27,375
+0.1800
+12,000
+0.1200
+QUANTITY
+RATE (%)
+0.2500
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+April 26, 2002
+7,000.00
+9,500.00
+4,927.50
+.........
+1,440.00
+$22,867.50
+297.82
+$297.82
+
+
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities C
+STEARNS
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary.............................
+Your Portfolio Holdings
+Transaction Detail
+3
+4
+5
+Hollandlold
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2002
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+20,424,754
+1,422,974
+21.847.72
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+23,210,702
+-1,362,974
+Cash & Equivalent
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Equities
+Market Value of Your Portfolio
+$1.422.974
+$1,255,202
+$20,424,754
+$21,955,500
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as delivered to you.
+do Client Services at 800 634-1428; or writa to Cient Services at Bear, Steams Securities
+Corp.,
+Brooklyn, N.Y. 11201-3859.
+SP This suremen s four for ratanal furyce red de Set revere date for portant iformation.
+04/27/02;12:01001
+
+
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+04/27/02;12:01 001
+
+
+STEARNS
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+$1,255,201.69
+....
+161,450.01
+6,322.06
+5167,772.07
+•........
+167,772.07
+1.422,973-1
+Income Summary
+Dividends
+Credit Balance Int.
+Total L
+THIS PERIOD
+6,000.00
+322.06
+$6.322.06
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+1,255,201.69
+$1, 255,201.69
+CLOSING
+1,422,973.76
+......
+51.422.973.76
+027
+YEAR TO DATE
+81,880.00
+1,513.94
+---.
+$83,393.94
+.....
+1,422,974
+20,424,754
+21.847.728
+04/27/02;12:01001
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+6%
+Equities
+94%
+Unshaded portions denote debe balance andor short
+
+
+STEARNS
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+AMERICAN INTERNATIONAL GROUP
+....
+BANK OF AMER CORP
+BRISTOL MYERS SQUIBB CO
+CITIGROUP INC
+GOLDMAN SACHS GROUP INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JOHNSON& JOHNSON
+MIBNA CORF
+.. . .
+PFIZER INC
+PROCTER & GAMBLE CO
+....
+VIACOM INC-CL B
+WYETH
+COM
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+QUANTITY
+PRICE
+SIMBCLICUSIP
+AIG
+BAC
+BMY
+GS
+KRB
+PFE
+PG
+FIAL
+WYE
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+.......
+ASH
+CASH
+CASH
+CASH
+QUANTITY
+20,000
+25,000
+25,000
+....
+27,375
+12,000
+10,000
+50,000
+60,000
+.. . .
+75,000
+25,000
+.......
+37,000
+24,000
+"HOLLY OWNED SUBSIDIARY
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2002
+MARKET
+VALUE
+1.422,974
+$1,422,974
+ESTIMATED
+NUAL INCOM
+CURREN
+(ELD (:
+PRICE
+68.7100
+71.7800
+29.3200
+43.0500
+79.1500
+34.7100
+63.6100
+35.2600
+....
+36.7600
+89.8000
+.......
+48.2000
+.........•...
+61.0900
+MARKET
+VALUE
+1,374,200
+1,794,500
+733,000
+1,178,494
+949,800
+847,100
+3,180,500
+2,115,600
+... .
+2,757,000
+2,245,000
+....
+1,783,400
+1,466,160
+$20,424,754
+$20,424,754
+STIMATE
+INNUAL INCOM
+3,360
+60,000
+28,000
+19,710
+5,760
+5,600
+41,000
+38,000
+22,080
+$286,510
+$286,510
+CURRENT
+YIELD IN
+0.2445
+3.3435
+....
+3.8199
+...
+1.6725
+0.6064
+...........
+0.6611
+1.2891
+1.1344
+.. . .
+1.4146
+1.6927
+1.5060
+027
+04/27102;12:01 001
+
+
+STEARNS
+5 or 8
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+TRANSACTION
+04/01/02 03/26/02
+SOLD
+TOTAL
+DIVIDENDS
+DATE
+DESCRIPTION
+04/01/02 MBNA CORP
+REC 03/15/02 PAY 04/01.02
+TOTAL
+DESCRIPTION
+TYCO INTERNATIONAL LTD
+AVG PRICE SHOWN-DETAILS ON REC
+ACTUAL CONFIRM TO YOUR AGENT
+UNSOLICITED
+SYMBOUCUSIP
+KAB
+$286,510
+$21,847,727
+SYMBOLGUSIP
+TYC
+QUANTITY
+-5,000
+PRICE
+32.44049
+QUANTITY
+60,000
+RATE (S)
+0.1000
+DEBIT AMOUNT
+027
+04/27/02;12:01 001
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2002
+DEBIT AMOUNT
+161,450.01
+$161,450.01
+6,000.00
+$6,000.00
+
+
+"HOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+STEARNS
+6 of 8
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+04/22/02
+INTEREST ON CREDIT BALANCE
+AT O 1/4% 03/21 THRU 04/20
+TOTAL
+SYMBOL/CUSIP
+QUANTITY
+RATE (%)
+0.2500
+DEBIT AMOUNT
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2002
+322.06
+$322.06
+STOP
+****** End of Statement******
+027
+04/27/02;12:01 001
+
+
+STEARNS
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ......
+Your Portfolio Holdings
+Transaction Detail
+Trades Not Yet Settled
+Your Messages
+3
+Hollandlold
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+WHOLLY OWNED SUBSIDIARY
+Best Scene Seats Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+February 22, 2002
+8
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+21,955,500
+1,255,202
+$23,210,702
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+21,704,531
+1,506,171
+Cash & Equivalent
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Equities
+Market Value of Your Portfolio
+$1.255,202
+$2.081.411
+$21,955,500
+$19,623,120
+Current market value
+Last statement's market value
+Flease raport any dierence or non-receipt of chacks or stocks, indicated as delivered to you.
+to Client Services at 800-634-1428; or writa to Cient Services at Bear, Steams Securities
+Corp.,
+Brooklyn, N.Y. 11201-3859.
+SP The suremen is four or ratanal furyce red de Set revere date for portant iformation.
+
+
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+03/29/02;20:33 001|
+
+
+STEARNS
+3 ora
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+Securities Bought
+Amount Debited
+Net Cash Activity
+Closing Balance,
+THIS PERICD
+32,081.411.08
+164,615.23
+41,917.10
+$206,532.33
+-1,032,741.72
+$-1,032,741.72
+.........
+-826,209.39
+51.255.201.69
+Income Summary
+Dividends
+Credit Balance Int.
+THIS PERIOD
+41,510.00
+407.10
+*•***--.
+$41.917.10
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+OPENING
+2,081,411.08
+Net Cash Balance
+$2,081,411.08
+CLOSING
+1,255,201.69
+$1,255,201.69
+027
+YEAR TO DATE
+75,880.00
+1,191.88
+$7.07i.38
+1,255,202
+21,955,500
+$23,210,702
+LEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+February 22, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+5%
+Equities
+95%
+Unshaded portions denote debe balance andor short
+
+
+STEARNS
+4 of a
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+AMERICAN INTERNATIONAL GROUP
+...
+BANK OF AMER CORP
+BRISTOL MYERS SQUIBB CO
+CITIGROUP INC
+GOLDMAN SACHS GROUP INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JOHNSON& JOHNSON
+MBNA CORP
+.....
+PFIZER INC
+PROCTER & GAMBLE CO
+.. . .
+TYCO INTERNATIONAL LTE
+.....
+VIACOM INC-CL B
+SYMBOLCUSIP
+QUANTITY
+PRICE
+SIMBCLCUSIP
+AIG
+BAC
+BMY
+GS
+IBM
+JNJ
+•......
+KRB
+PFE
+PG
+.......
+TYC
+VIAB
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+•..........
+CASH
+... ..
+CASH
+CASH
+CASH
+......
+CASH
+QUANTITY
+20,000
+25,000
+25,000
+27,375
+12,000
+10,000
+50,000
+60,000
+.. . .
+75,000
+25,000
+5,000
+....-----••
+37,000
+MARKE
+VALUE
+1,255,202
+$1,255,202
+PRICE
+72.1400
+68.0200
+40.4900
+49.5200
+90.2500
+104.0000
+64.9500
+38.5700
+....
+39.7400
+90.0900
+...
+32.3200
+... ..
+48.3700
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+ANAL INTE
+CURRE
+ELD I
+MARKET
+VALLE
+1,442,800
+1,700,500
+1,012,250
+1,355,610
+1,083,000
+1,040,000
+3,247,500
+2,314,200
+2,980,500
+2,252,250
+161,600
+...
+1,789,690
+TIMATE
+INUAL INCON
+3,360
+60,000
+28,000
+17,520
+5,760
+5,600
+36,000
+24,000
+39,000
+3000
+CURRENT
+YIELD IN
+0.2329
+3.5284
+2.7661
+1.2924
+0.5319
+.....
+0.5385
+-1085
+_0371
+....
+.308
+1.6872
+...
+.154
+027
+
+
+STEARNS
+5 ora
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+WYETH
+COM
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+WYE
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+ACCT
+CASH
+QUANTITY
+24,000
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TRE
+03/11/02
+TRANSACTION
+NAME CHG
+03/11/02
+"NAME CHG"
+03/21702 03/18/02"SOLD"
+DESCRPTION
+AMERICAN HOME PRODUCTS CORP
+A397519 TO W003167
+N/C WYETH
+COM
+W003167 FROM A397519
+N/C WYETH
+TYCO INTERNATIONAL LTD*
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+AS OF 03/18/02
+......
+PRICE
+65.6500
+MARKE
+FALLE
+1,575,600
+$21,955,500
+$21,955,500
+$279,570
+$23,210,701
+ESTIMATED
+ANNUAL INCOM
+22,080
+$279,570
+$279,570
+CURRENT
+YIELD (%)
+1.4014
+SIMBOLCUSP
+
+"WE
+TYC
+QUANTITY
+-24,000
+24,000
+5,000
+PRICE
+33.16710
+027
+03/29/02:20:33 001
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Car
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+164,615.23
+VSSS
+
+
+STEARNS
+6 of a
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SATEMENT TRIE
+TRANSACTION
+03/25/02 03/20/02 BOUGHT
+DESCRIPTION
+BRISTOL MYERS SQUIBB CO
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+TOTAL
+DIVIDENDS
+DATE
+DESCRIPTION
+03/01/02
+AMERICAN HOME PRODUCTS CORP
+REC 02/13/02 PAY 03/01/02
+03/07/02
+REC 02/15/02 PAY 03/07/02
+03/11/02 INTERNATIONAL BUSINESS
+MACHINES CORP
+REC 02/08/02 PAY 03/09/02
+83/12/02 BANSON& JOHNSON"***
+REC 02/19/02 PAY 03/12/02
+03/15/02
+''"'AMERICAN INTERNATIONAL " GROUP
+REC 03/01/02 PAY 03/15/02
+13/22/02
+TOTAL
+BANK OF AMER CORP
+REC 03/01/02 PAY 03/22/02
+SVMBOUCUSIP
+
+PFE
+BAC
+SYMBOL/GUSP
+BMY
+QUANTITY
+RATE (S)
+24,000
+0.2300
+75,000
+0.1300
+10000*0:1400
+50,000••01800
+20,000 0.0420
+25,000
+0.6000
+027
+QUANTITY
+25,000
+PRICE
+41.06070
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Cam
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+DEBIT AMOUNT
+1,032,741.72
+$-1,032,741.72
+$164,615.23
+DEBIT AMOUNT
+5,520.00
+9,750.00
+*••••••:•••1.400.00
+•9:000:00
+840.00
+15,000.00
+$41.510.00
+03/29/02:20:33 001
+
+
+STEARNS
+7 of a
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+03/21/02
+INTEREST ON CREDIT BALANCE
+AT O 1/4% 02/21 THRU 03/20
+TOTAL
+SYMBOL/CUSIP
+Trades Executed Pending Settlement
+BATLEMENT
+04/01/02
+03/26/02
+TOTAL
+TRANSACTON
+SOLD
+DESCRIPTION
+TYCO INTERNATIONAL LTD
+The above trades do not appear in any other section of this statement.
+QUANTITY
+RATE (%)
+0.2500
+SYMBOLICUSIP
+TYC
+027
+DEBIT AMOUNT
+QUANTITY
+-5,000.00
+PRICE
+32.4404
+LEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+407.10
+$407.10
+DEBIT AMOUNT
+$0.00
+161,450.01
+$161,450.01
+
+
+STEARNS
+8 of 8
+Your messages
+1 Pursuant to SEC Rule 11Ac1-6, Bear, Stearns & Co, Inc will
+publicly post its quarterly routing statistics at the following web link:
+http://www.bearstearns.com/corporate/business/equities/orp.htm
+STOP
+****** End of Statement******
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+Bear, Stearns Securities Corp, Net Capital and Net Capital
+Requirements:
+At November 30, 2001 and January 31, 2002, the Company's net
+capital of approximately $2,6 billion and $2,6 billion was
+approximately 9% and 8% of aggregate debit items and exceeded
+the minimum regulatory net capital requirement of approximately
+$604.1 million and $648.0 million by approximately $2.0 billion and
+$2.0 billion, all respectively.
+A complete copy of the Bear, Stearns Securities Corp. Statement
+of Financial Condition is available on the web site
+www.bearstearns.com,
+Alternatively, to request a free printed copy
+please call -toll free 1-866-299-9331,
+027
+
+
+STEARNS
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ••••••••••••••IIIIII•
+Your Portfolio Holdings
+Transaction Detail
+.....
+4
+5
+Hollandlold
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear seams Seems co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+January 25, 2002
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+19,623,120
+2,081,411
+$21,704,531
+22,141,283
+-436,752
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$2,081.411
+$2,402,195
+Cash & Equivalent
+Equities
+$19,623,120
+$19,739,088
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as delivered to you.
+do Client Services at 800 634-1428; or writa to Cient Services at Bear, Steams Securities
+Comp.,
+Brooklyn, N.Y. 11201-3859
+SP The suren s four or ratanal purposes red die Set revere date for portant iformation.
+
+
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+STEARNS
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Securities Bought
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERICO
+$2,402,194.72
+....
+28,530.47
+28,530.47
+-349,314.11
+$:349,314.111
+....
+-320,783.64
+$2.081.411.08
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+28,070.00
+460.47
+.$28,530.47.
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+let Cash Balanc
+.......
+OFENING
+2,402,194.72
+$2,402,194.72
+CLOSING
+2,081,411.08
+52.08-41.08
+027
+YEAR TO DATE
+34,370.00
+784.78
+$35,154.78
+2,081,411
+19,623,120
+521.704.531
+WHOLLY OWNED SUBSIDIARY
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+January 25, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+Equities
+91%
+Unshaded portions denote debe balance andor short
+
+
+STEARNS
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+AMERICAN HOME PRODUCTS CORP
+.....
+AMERICAN INTERNATIONAL GROUP
+INC
+BANK OF AMER CORP
+CITIGROUP INC
+GOLDMAN SACHS GROUP INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JOHNSON& JOHNSON
+MBNA CORP
+.. . .
+PFIZER INC
+PROCTER & GAMBLE CO
+.. . .
+TYCO INTERNATIONAL LTD
+..........
+VIACOM INC-CLB
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+QUANTITY
+PRICE
+SYMBOLICUSIP
+AHP
+AIG
+BAC
+C
+GS
+KRB
+PFE
+PG
+.......
+TYC
+VIAB
+CASH
+CASH
+CASH
+CASH
+ASI
+CASH
+CASH
+......
+ASH
+CASH
+CASH
+CASH
+QUANTITY
+24,000
+.......
+20,000
+25,000
+27,375
+12,000
+10,000
+50,000
+60,000
+.. . .
+75,000
+25,000
+......
+10,000
+37,000
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securites Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 25, 2002
+MARKET
+VALUE
+2.081.411
+$2,081,411
+MALAS INCOME CRON
+(ELD (:
+PRICE
+63.9800
+70.3300
+61.3200
+42.4000
+79.0000
+98.4500
+59.4000
+32.5500
+....
+41.1100
+85.6000
+......
+27.5000
+44.1500
+MARKET
+VALTE
+1,535,520
+1,406,600
+1,533,000
+1,160,700
+948,000
+984,500
+2,970.000
+1,953,000
+3,083,250
+2,140,000
+275,000
+1,633,550
+$19,623,120
+$19,623,120
+ESTIMATED
+ANNUAL INCOME
+22,080
+3,360
+60,000
+17,520
+5,760
+5,600
+36,000
+38,000
+500
+$251,820
+$251,820
+CURRENT
+YIELD IN
+1.4379
+0.2389
+3.9139
+1.5094
+0.6076
+......
+0.5688
+1.2121
+1.2289
+... .
+1.2649
+1.7757
+0.1818
+027
+
+
+STEARNS
+5 or 8
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SEEMENT TRE
+TRANSACTION
+02/01/02 01/29/02
+BOUGHT
+TOTAL
+DIVIDENDS
+DATE
+DESCRIPTION
+01/31/02
+JP MORGAN CHASE & CO
+REC 01/04/02 PAY 01/31/02
+0245/02 ''PROCTER 8 GAMBLE CO*''
+REC 01/18/02 PAY 02/15/02
+02721702*GOLDMAN SACHS GROUP INC
+REC 01/22/02 PAY 02/21/02
+DESCRIPTION
+TYCO INTERNATIONAL LTD
+DISCRETIONARY ORDER
+SINCE CUBIP
+'''PC
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear seams Seems co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+January 25, 2002
+$251,820
+$21,704,531
+SYMBOLGUSIP
+TYC
+QUANTITY
+10,000
+PRICE
+34.70000
+DEBIT AMOUNT
+349,314.11
+$-349,314.11
+QUANTITY
+RATE (S)
+37,500
+0.3400
+25,0000.3800
+12,000
+0.1200
+027
+DEBIT AMOUNT
+REDIT AMOUN
+2,750.00
+9,500.00
+1,440.00
+......
+
+
+STEARNS
+6 of 8
+Transaction Detail (continued)
+DIVIDENDS (continued)
+DATE
+DESCRIPTION
+02/22/02
+CITIGROUP INC
+REC 02/04/02 PAY 02/22/02
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+02/21/02
+INTEREST ONCREDIT BALANCI
+T 0 1/4% 01/21 THRU 02/2
+TOTAL
+SYMBOUCUSIP
+SYMBOL/CUSIP
+STOP
+****** End of Statement******
+QUANTITY
+27,375
+QUANTITY
+RATE (S)
+0.1600
+RATE INJ
+0.2500
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear. Steams Securities Ca
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 25, 2002
+4,380.00
+$28,070.00
+460.47
+$460.47
+
+
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities C
+STEARNS
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary.............................
+Your Portfolio Holdings
+Transaction Detail
+Your Messages
+3
+4
+5
+6
+Hollandlold
+INSTITUTIONAL INTERESTS A/C #2
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+19,739,088
+2,402,195
+522,141,283
+22,405,902
+-264,620
+The apen step onese for your other ponding buy
+Market Value of Your Portfolio
+$2,402,195
+$1,309.037
+Cash & Equivalent
+Equities
+/ $19,739,088
+m $21,096,865
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as delivered to you.
+to Client Services at 800 634-1428; or writa to Cient Services at Bear, Steams Securities
+Corp.,
+Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal furyce red die Set revere date for portant iformation.
+01/26/02;09:29 001
+
+
+Bear. Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+01/26/02:09:29 001
+
+
+STEARNS
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+Securities Bought
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+51.309,03.42
+1,707,729.70
+6,624.31
+$1,714,354.01
+.........
+-621,196.71
+$-621,196.71
+1,093,157.30
+2.402.194.72
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+6,300.00
+324.31
+$6.624.31
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+1,309,037.42
+$1,309,037.42
+CLOSING
+2,402,194.72
+$2,402,194.72
+027
+YEAR TO DATE
+6,300.00
+324.31
+****--.
+$6.624.31
+2,402,195
+19,739,088
+$22,141,283
+.....
+01/26/02;09:29 001
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear. Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+10%
+Equities
+90%
+Unshaded portions denote debe balance andor short
+
+
+STEARNS
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+AMERICAN HOME PRODUCTS CORP
+....
+AMERICAN INTERNATIONAL GROUP
+BANK OF AMER CORP
+CITIGROUP INC
+GOLDMAN SACHS GROUP INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JOHNSON& JOHNSON
+MBNA CORP
+.. . .
+PFIZER INC
+PROCTER & GAMBLE CO
+VIACOM INC-CL B
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+QUANTITY
+PRICE
+SYMBOLCUSIP
+AHP
+AIG
+BAC
+C
+GS
+JNJ
+KRB
+PFE
+PG
+VIAB
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+......
+CASH
+CASH***
+CASH
+QUANTITY
+24,000
+........
+20,000
+25,000
+27,375
+12,000
+10,000
+50,000
+60,000
+.......
+75,000
+25,000
+37,000
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+MARKET
+VALUE
+2,402,195
+$2,402,195
+NAME NOTE ORDEN
+PRICE
+63.0100
+1.010
+63.3500
+49.6200
+87.3000
+109.2800
+57.6500
+35.6000
+....
+41.7000
+79.1400
+39.4500
+MARKET
+VALUE
+1,512,240
+1,560,200
+1,583,750
+1,358,348
+1,047,600
+1,092,800
+2,882,500
+2,136,000
+... .
+3,127,500
+1,978,500
+1,459,650
+$19,739,088
+$19,739,088
+027
+ESTIMATED
+ANNUAL INCOME
+22,080
+3,360
+60,000
+17,520
+5,760
+5,600
+36.000
+38.00*
+$251,320
+$251,320
+CURRENT
+YIELD (%)
+1.4601
+......
+0.2154
+3.7885
+1.2898
+0.5498
+......
+0.5124
+1.2489
+1.1236
+... ..
+1.2470
+1.9206
+01/26/02:09:29 001
+
+
+STEARNS
+5 or 8
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SETILEMENT TRADE
+TRANSACTION
+01/04/02 01/03/02
+SOLD
+01723/02 01717/02 SOLD
+01724/02 01/18/02 "BOUGHT
+01/24/02
+01718/02
+SOLD
+TOTAL
+SCRIPTION
+ENA COF
+ACTUAL ON AN TO TOUR T
+JP MORGAN CHASE & CO....
+ACTUAL CORN TO TOUR ONE O
+SEE NOTE 'S' ON BACK
+JP MORGAN CHASE & CO
+AVG PRICE SHOWN-DETAILS ON REQ
+ACTUAL CONFIRM TO YOUR AGENT
+$251,320
+$22,141,282
+SYMBOLCUSP
+KAB
+*IPM
+JPM
+QUANTITY
+-10,000
+18,750
+12,375
+- 18,750
+PRICE
+36.15000
+36.67440
+• 49.90000
+35.71260
+027
+01/26/02;09:29 001
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities C
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+DEBIT AMOUNT
+359,114.25
+683,283.17
+'621,196.71
+$-621,196.71
+665,332.28
+$1,707,729.70
+
+
+STEARNS
+6 of 8
+Transaction Detail (continued)
+DIVIDENDS
+DATE
+DESCRIPTION
+01/02/02 MBNA CORP
+REC 12/14/01 PAY 01/01/02
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+01/22/02
+INTEREST ON CREDIT BALANCE
+AT 0 1/4% 12/21 THRU 12/30
+012202 A TA 19T PRAL INGE
+TOTAL
+SYMBOUCUSIP
+KRB
+SYMBOL/CUSIP
+Your messages
+hoi was, any on the no aurican ting ember 30.
+The interest, if any, charged to your account during January 2002
+is computed from December 31, 2001.
+STOP
+****** End of Statement******
+QUANTITY
+70,000
+QUANTITY
+RATE (S)
+0.0900
+RATE (%)
+0.2500
+0.2500
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+01/26/02;09:29 001
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Co
+INSTITUTIONAL INTERESTS A/C #2
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+6,300.00
+$6,300.00
+CREDIT AND 18
+234.13
+$324.31
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/cfb723383497878f9d4837a113b7bdb706b078e04d804a5c18c1ae9dfc68b2a9.receipt.json b/vision-fixhub/ds9-unparsed-05/cfb723383497878f9d4837a113b7bdb706b078e04d804a5c18c1ae9dfc68b2a9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..674b9d4c3d39454004ec43c1331aea3fb1325280
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/cfb723383497878f9d4837a113b7bdb706b078e04d804a5c18c1ae9dfc68b2a9.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -9444,
+  "dataset": "marble-joined",
+  "doc_id": "cfb723383497878f9d4837a113b7bdb706b078e04d804a5c18c1ae9dfc68b2a9",
+  "engine": "marble-apple-vision",
+  "event_count": 85,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "c6c3b446a949d24137933e207365e87341bff1136142a33f991cc0344357af26",
+  "output_sha256": "98485f3476492c2715783559a4553f7094d62400fd734c4d5c477e48eca592a8",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/d08547ba00a7e7d3cb973320fc72bd121a93310f980a38de633cba6b1a4f6e38.md b/vision-fixhub/ds9-unparsed-05/d08547ba00a7e7d3cb973320fc72bd121a93310f980a38de633cba6b1a4f6e38.md
new file mode 100644
index 0000000000000000000000000000000000000000..2a43de4d7512ce9b0b60a7ced56529c2fb4b4217
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d08547ba00a7e7d3cb973320fc72bd121a93310f980a38de633cba6b1a4f6e38.md
@@ -0,0 +1,517 @@
+CM/ECF - Live P-tabase - flsd
+
+LRJ
+Jane Doe No. 6 v. Epstein
+Assigned to: Judge Kenneth A. Marra
+Cause: 28:1331 Federal Question
+Plaintiff
+Jane Doe No. 6
+U.S. District Court
+Southern District of Florida (West Palm Beach)
+CIVIL DOCKET FOR CASE #: 9:08-cv-80994-KAM
+Date Filed: 09/10/2008
+ury Demand: Plaintifi
+Vature of Suit: 710 Labor: Fai
+Standards
+Jurisdiction: Federal Question
+represented by Adam D. Horowitz
+Herman & Mermelstein, P.A.
+18205 Biscayne Blvd.
+Miami , FL 33160
+Fax:
+Email:
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+leffrey Mare Herman
+lerman & Mermelsteir
+18205 Biscayne Boulevard
+Suite 2218
+Miami , FL 33160
+Fax: 931-0877
+Email:_
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Stuart S. Mermelstein
+Herman & Mermelstein
+18205 Biscayne Boulevard
+Miami, EL 33160
+Fax: 931-0877
+Email: D
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?617389682623668-L_801_0-1
+10/8/2008
+
+
+CM/ECF - Live P-tabase - flsd
+
+Defendant
+Jeffrey Epstein
+represented by Robert Deweese Critton, Jr.
+Burman Critton Luttier & Coleman
+515 N Flagler Drive
+Suite 400
+West Palm Beach, FL 33401-2918
+Fax:
+Email:
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Date Filed
+09/10/2008
+09/10/2008
+09/15/2008
+10/03/2008
+10/06/2008
+10/08/2008
+#Docket Text
+1
+COMPLAINT against Jeffrey Epstein Filing fee $ 350.00. Receipt#: 544159,
+filed by Jane Doe No. 6.(mg) (Entered: 09/11/2008)
+2
+Summons Issued as to Jeffrey Epstein. (mg) (Entered: 09/11/2008)
+3
+NOTICE of Attorney Appearance by Robert Deweese Critton, Jr on behalt of
+Jeffrey Epstein (Critton, Robert) (Entered: 09/15/2008)
+4
+| SUMMONS (Affidavit) Returned Executed by Jane Doe No. 6. Jeffrey Epstein
+served on 9/23/2008, answer due 10/14/2008. (Herman, Jeffrey) (Entered:
+10/03/2008)
+5
+ORDER OF TRANSFER. Case reassigned to Judge Kenneth A. Marra for all
+Signer by dude Daniel . a Hurry on to-ey no (on Ernasred.: 10107/20c
+. (gp) (Entered: 10/07/2008)
+6
+CERTIFICATION AND ORDER OF TRANSFER TO MAGISTRATE JUDGE.
+Magistrate Judge James M. Hopkins no longer assigned as referral judge in case
+Case transferred to Judge Marra's paired Magistrate Judge Linnea R. Johnson
+Signed by Magistrate Judge James M. Hopkins on 10/8/08. (Iw1) (Entered:
+10/08/2008)
+PACER Service Center
+Transaction Receipt
+10/08/2008 17:41:02
+PACER Login: du4480
+Client Code:
+9:08-cv-80994-
+Description: Docket Report Search Criteria:
+KAM
+Billable Pages: |L
+Cost:
+10.08
+https://ecf.fsd.uscourts.gov/cgi-bin/DktRpt.p|?617389682623668-L_801_0-1
+10/8/2008
+
+
+Case 9:08-Cv-tuJ94-KAM Docume... 1
+Entered.. FLSD Docket 09/11.08 Page i op/mal
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.:
+08-CV-80994-Hurley-Hopkins
+/ELECTRONE VT D.C.
+SEPT. 10, 2008
+5.0. OF
+COMPLAINT
+Plaintiff, Jane Doe No. 6 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey
+Epstein, as follows:
+Parties, Jurisdiction and Venue
+Jane Doe No. 6 is a citizen and resident of the State of Florida, and is sui juris.
+2.
+This Complaint is brought under a fictitious name to protect the identity of the
+Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a
+minor.
+3.
+Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
+4.
+This is an action for damages in excess of $50 million.
+5.
+This Court has jurisdiction of this action and the claims set forth herein pursuant to 28
+U.S.C. §1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs;
+and (ii) is between citizens of different states.
+6.
+Additionally, this Court has jurisdiction pursuant to 28 U.S.C. §1331 because
+Plaintiff alleges a claim under the laws of the United States. This Court has supplemental
+HERMAN & MERMELSTEIN, P. A.
+- 1-
+1017
+
+
+08-C/8099A Mrley-Hopki..
+Entered i.. FLSD Docket 09/11._.08 Page 2 of 7
+jurisdiction pursuant to 28 U.S.C. §1367(a) over all other claims set forth herein which form part of
+the same case or controversy.
+This Court has venue of this action pursuant to 28 U.S.C. §§1391(a) and 1391(b) as a
+substantial part of the events or omissions giving rise to the claim occurred in this District.
+Factual Allegations
+At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male,
+approximately 52 years old. Epstein is a financier and money manager with a secret clientele limited
+exclusively to billionaires. He is himself a man of tremendous wealth, power and influence. He
+maintains his principal home in New York and also owns residences in New Mexico, St. Thomas
+and Palm Beach, FL. The allegations herein concern Epstein's conduct while at his lavish estate in
+Palm Beach.
+Upon information and belief, Epstein has a sexual preference and obsession for
+underage minor girls. He engaged in a plan and scheme in which he gained access to primarily
+economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave
+them money. In or about 2004, Jane Doe, then approximately 13 years old, fell into Epstein's trap
+and became one of his victims.
+10.
+Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted
+girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas.
+11.
+Epstein's scheme involved the use of young girls to recruit underage girls. These
+underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation
+in his Palm Beach mansion. Epstein, upon information and belief, generally sought out economically
+disadvantaged underage girls from western Palm Beach County who would be enticed by the money
+HERMAN & MErMELstEIN, P. A.
+- 2-
+2of7
+
+
+08-CMe80994.-sankey-Hopkia... Entered... FLSD Docket 09/11..JO8 Page 3 of 7
+being offered - generally $200 to $300 per "massage" session - and who were perceived as less likely
+to complain to authorities or have credibility if allegations of improper conduct were made. This
+was an important element of Epstein's plan.
+12.
+Epstein's plan and scheme reflected a particular pattern and method. The underage
+victim would be brought or directed to Epstein's mansion, where she would be led up a flight of
+stairs to a bedroom that contained a massage table in addition to other furnishings. The girl would
+then find herself alone in the room with Epstein, who would be wearing only a towel. He would then
+remove his towel and lie naked on the massage table, and direct the girl to remove her clothes.
+Epstein would then perform one or more lewd, lascivious and sexual acts, including masturbation.
+13.
+Consistent with the foregoing plan and scheme, when Jane Doe was only 13 years old,
+she was recruited by another girl to give Epstein a massage for monetary compensation. Jane was
+brought to Epstein's mansion in Palm Beach. Once there, she was led up the flight of stairs to the
+room with the massage table. Epstein came into the room and directed Jane to remove her clothes
+and give him a massage. As directed by Epstein, Jane stripped to her underwear. Epstein then
+sexually assaulted Jane during the massage. In addition, Epstein masturbated during the massage.
+Epstein then paid Jane money.
+14.
+As a result of this encounter with Epstein, Jane experienced confusion, shame,
+humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
+COUNT I
+Sexual Assault and Battery
+15.
+Plaintiff Jane Doe repeats and realleges paragraphs I through 14 above.
+16. Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane
+Doe, creating a reasonable fear of imminent peril and sexual assault.
+HERMAN & MERMELSTEIN, P. A.
+- 3-
+3017
+
+
+Case 9:08-CV-duJ94-KAM Docume... 1
+Entered u.. FLSD Docket 09/11 .UO8 Page 4 of 7
+17.
+Jane Doe.
+Epstein intentionally inflicted harmful or offensive sexual contact on the person of
+18.
+Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein's acts
+were intentional, unlawful, offensive and harmful.
+19. Epstein's plan and scheme in which he committed such acts upon Jane Doe were done
+willfully and maliciously.
+20.
+As a direct and proximate result of Epstein's assault on Jane, she has suffered and will
+continue to suffer severe and permanent traumatic injuries, including mental, psychological and
+emotional damages.
+WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this
+Court deems just and proper.
+COUNT II
+Intentional Infliction of Emotional Distress
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+Epstein's conduct was intentional or reckless.
+Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds
+21.
+22.
+23.
+of decency.
+24.
+Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted
+in mental or sexual injury that caused or were likely to cause Jane Doe's mental or emotional health
+to be significantly impaired.
+25.
+Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had
+reason to know that his intentional and outrageous conduct would cause emotional distress and
+HERMAN & MERMELSTEIN, P. A.
+- 4-
+
+
+Case 9:08-cv-buJ94-KAM Docume... 1
+Entered u.. FLSD Docket 09/11...U08 Page 5 of 7
+damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing
+severe emotional distress to Jane Doe.
+26.
+As a direct and proximate result of Epstein's intentional or reckless conduct, Jane
+Doe, has suffered and will continue to suffer severe mental anguish and pain.
+WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this
+Court deems just and proper.
+COUNT III
+Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422
+27. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+28. Epstein used a facility or means of interstate commerce to knowingly persuade,
+induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or
+sexual activity for which any person can be charged with a criminal offense.
+29.
+Epstein's acts and conduct are in violation of 18 U.S.C. §2422.
+30.
+As a result of Epstein's violation of 18 U.S.C. §2422, Plaintiff has suffered personal
+injury, including mental, psychological and emotional damages.
+31.
+Plaintiff hired Herman & Mermelstein, P.A., in this matter and agreed to pay them a
+reasonable attorneys' fee.
+WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey
+Epstein for all damages available under 18 U.S.C. §2255(a), including without limitation, actual and
+compensatory damages, costs of suit, and attorneys' fees, and such other and further relief as this
+Court deems just and proper.
+HERMAN & MERMELSTEIN, P. A.
+- 5-
+
+
+.. Case 9:08-CV-ouJ94-KAM Docume... 1
+Entered u.. FLSD Docket 09/11,.J08
+
+JURY TRIAL DEMAND
+Plaintiff demands a jury trial in this action on all claims so triable.
+Dated: September 10
+_ 2008
+Respectfully submitted,
+By:
+Jeffrey M. Herman (FL Bar No. 521647)
+Stuart S. Mermelstein (FL Bar No. 947245)
+Adam D. Horowitz (FL Bar No. 376980)
+HERMAN & MERMELSTEIN, P.A.
+Attorneys for Plaintiff
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel:
+Fax:
+HERMAN & MerMelsteIN, P. A.
+- 6-
+
+
+Uriginal
+xcept as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk o
+he Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)
+|(a) PLAINTIFFS
+DEFENDANTS
+JANE DOE NO. 6,
+JEFFREY EPSTEIN
+(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF
+COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT NEW YORK
+(IN U.S. PLAINTIFF CASES ONLY)
+PALM BEACH COUNTY
+(EXCEPT IN U.S. PLAINTIFF CASES)
+(c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER)
+Herman & Mermalstein. P.A., 18205 Biscayne Blvd., Suite 2218, Miami,
+FL 33160,
+ATTORNEYS (IF KNOWN)
+(d) CIRCLE COUNTY WHERE ACTION AROSE: PALM BEACH
+II. BASIS OF JURISDICTION
+(PLACE AN X ONE BOX ONLY)
+• 1. U.S. Government
+X 3. Federal Question
+Plaintiff
+(U.S. Govemment Not a Party)
+• 2. U.S. Government
+• 4. Diversity
+Defendant
+(Indicate Citizenship of Parties in Item
+9108CV 80994- Harley-Hopkins
+III. CITIZENSHIP OF PRINCIPAL PARTIES
+(For Diversity Case Only)
+Citizen of This State
+Citizen of Another State
+02 02
+Cilizen or Subject of a Foreign Country • 3 • 3
+Incorporated of Principal Place of
+Business in This State
+Incorporated and Principal Place of 0 5 0 5
+Business in Another State
+Foreign Nation
+• 6 0 6
+lil)
+IV. CAUSE OF ACTION
+(CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE.
+DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY.)
+ACTION FOR SEXUAL ASSAULT UNDER 18 U.S.C. §2422 AND STATE LAW
+IVa. 5 days estimated (for both sides) to try entire case
+I NATURE OF SUIT
+(PLACE AN XIN ONE BOX ONLY)
+A CONTRACT
+A TORTS
+000D0
+110Ingurance
+120 Marne
+130 MI ACI
+140 Negetable Insisners
+150 Recavery of Overpayment
+& Enfoicement of
+Judgmen
+151 Medicare Act
+8 192 Recovery of Delete
+Salon Loans (Excl
+Veterara) B
+• 153 Recovery of Overpayment
+of Veisran's Benels B
+• 180 Sockholder's Suite
+• 185 Contract Product Libity
+PERSONAL INJURY
+• 310 Arplane
+© 362 Personal Injury Aled Malpractice
+• 315 Airplane Product Liabily
+D 300
+Personal Injury Product Libity
+• 320 Assault, Libel & Slander
+• 30d Asbestos Personnel
+© 330 Federal Empleyers' Liablty
+Injury Product Liabilty
+© 345 Marine Product Liablty
+PERSONAL PROPERTY
+• 350 Mesar Vehicle
+© 355 Mosor Vehicle Product Labilly O370 Oever Fraud
+* 350 Other Porsonal Wjury
+0 371
+Truth in Landeg B
+• 380 Other Personnel
+Property Damage
+• 305 Property Damage
+Product Labity
+B FORFEITURE
+PENALTY
+• 610 Agriculture
+• 620 Other Food & Drug
+D 625 Drug Related Serie
+of Property 21 USC 801
+O 830 Liguer Lans
+• 540 R.R. & Truck
+C 550 Airline Rega
+0 600 Occupadonal
+SafetyHealth
+• 800 Овог
+A BANKRUPTCY
+A OTHER STATUS
+• 422 Appeal 28 USC 15B
+• 423 Wahdrawal 28 USC 157
+A REAL PROPERTY
+• 210 Land Condemnation
+• 220 Forecosure B
+240 Torta to Land
+245 Ten Product Labity
+O 200 All Oner Meal Property
+A CIVIL RIGHTS
+• 441 Voting
+© 442Empioyment
+443 Housing/Accommodations
+440 Cher CM Rights
+B PRISONER PETITIONS
+A PROPERTY RIGHTS
+O820 Copyrights
+Oi30 Palent
+D 840 Trademark
+B SOCIAL SECURITY
+• 801 HIA (1305M)
+• 002 Black Lung (923)
+©B03 DIWC/DWW(405(gll
+© 384 SSID THe XVI
+• 105 RSI (405(gl)
+• 510Matona to Vacate Sentence
+Habess Corpus
+• 530 General*
+• 535 Dwath Penaly
+D 540 Mandamus & Other"
+• 550CM RICHs
+*A orB
+A LABOR
+X710 Far Labor Standards
+Act
+• 72O Laber Managerient
+Relakint B
+C 730 Labor Management
+Reperting & Disclosure
+• 740 Ratway Labor Act
+C] 700 Other Labor Ligation
+Securty Ac B
+A FEDERAL TAX SUITS
+Sutus Reappointment
+• 41D Antinast
+• 430
+Banks and Manking
+• 450
+Commerce/CO Rates/ic B
+© 470 Racketeer Influenced and
+Corrupe Orpanizatione
+Soloctive Service
+Securlies/ Contmodies/
+D 875
+Customer Challenge
+I2USC3410
+D 891
+Agricutural Acts
+0 882
+Economic Stablizaton Act
+0 803
+Enormertal Marters
+Energy Allocation Art
+• 800
+Freedom of Information Act
+000
+Appeal of Fee Detamination
+Under Equal Access *
+Jusace
+• 050
+Consibusonality of Sule
+0 800
+Other Sunsory Actions"
+"AorB
+Dediaralary eelief and slade law claims
+or delamation
+• 870 Taxes (U.S. Plainull or Defendant)
+D 871 IRS Third Party 20 USC 7509
+/I. ORIGIN
+: 1. Origina
+Proceeding
+VII. REQUESTED
+IN COMPLAINT
+02. Removedfrom 3. Remanded from 84; Relied
+• 6. Multidistrict Litigation
+Appeal to District Judge from
+State Court
+Appellate Court O 5. Transferred from another distric
+Specify
+Magistrate Judgment
+CHECK IF THIS IS A
+• UNDER F.R.C.P. 2:
+• CLASS ACTION
+DEMAND $
+Check YES only if demanded in X YES
+complaint:
+JURY DEMAND:
+• NO
+(See Instructions):
+Jane Doe 2J. Jeffrey Epstel
+Jane Doe 3LL. Jeffrey Epstein
+DATE Sept lo
+- 2608
+UNITED STATES DISTRICT COURT
+REV. 9/94
+(SEE ATTACHED)
+JUDGE KENNETH A. MARRA
+JUDGE KENNETH A. MARRA
+JUDGE KENNETH A MARRA
+DOCKET NUMBER 08-CV-B0119-MARRA-JOHNSON
+DOCKET NUMBER 0B-CV-80232-MARRA-JOHNSON
+DOCKET NUMBER 0B-CV-80380-MARRA/JOHNSON
+JUDGE KENNETH A MARRA
+SIGNATURE OF ATTORNEY OF RECORD AL
+FOR OFFICE USE ONLY: Receipt No.
+Amount:
+300
+Date Paid:
+
+• Mifp:
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/d08547ba00a7e7d3cb973320fc72bd121a93310f980a38de633cba6b1a4f6e38.receipt.json b/vision-fixhub/ds9-unparsed-05/d08547ba00a7e7d3cb973320fc72bd121a93310f980a38de633cba6b1a4f6e38.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..73fd260ee5a2de52a0959a057b51fb4a35f75d7e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d08547ba00a7e7d3cb973320fc72bd121a93310f980a38de633cba6b1a4f6e38.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -256,
+  "dataset": "marble-joined",
+  "doc_id": "d08547ba00a7e7d3cb973320fc72bd121a93310f980a38de633cba6b1a4f6e38",
+  "engine": "marble-apple-vision",
+  "event_count": 14,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "d34d0d67562b5d8b9e49d312441901eefbb6816ee815bf5091e6dc7e254e572b",
+  "output_sha256": "a6d436cbde95bc135d881b3bf3b384254ec0d99cb4dcb80515bc316773281e04",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/d0f91e5cd6116a14731aea3129454b0868fefacb614c8763386a8ec3dc188596.md b/vision-fixhub/ds9-unparsed-05/d0f91e5cd6116a14731aea3129454b0868fefacb614c8763386a8ec3dc188596.md
new file mode 100644
index 0000000000000000000000000000000000000000..8a481944a283646cefc0f7e895065cb3b89a3b93
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d0f91e5cd6116a14731aea3129454b0868fefacb614c8763386a8ec3dc188596.md
@@ -0,0 +1,6565 @@
+Statements
+
+
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ........../../............................
+Your Messages
+Bear, Stearns & Co. Inc.
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 29, 2002
+3
+6
+7
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+6,046,710
+2,419
+80,376
+3,417,795
+$9,547,300
+NET EQUITY LAST STATEMENT
+9,810,083
+CHANGE SINCE LAST STATEMENT
+-262,783
+This portfolio indudes one or mare unpriced securties that are no
+ollected in tho Total Value of Securtie
+and the Not Equity This Porkd
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+Equities
+Fixed
+Income
+$3.498,171
+$3,479,960
+$4,046,710
+$4,328,256
+Important Message
+f any information regarding
+2002 interest, dividends
+niscellaneous incom
+gross proceeds or origina
+$2,000,000
+$2,000,000
+Current market value
+Last statement's market value
+12425 31.200 17, 2003.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+1o Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+• This summary is for informational purposes only. It is not intended as a tax document
+SPC This statement should be retained for your records. See reverse side for important information
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance,
+Bear, Stears & Co. Inc.
+New York, New York 10179
+THIS PERICO
+34,926.0
+....
+2,760.53
+15,450.28
+$18,210.81
+-2,760.53
+...
+$-2,760.53
+...........
+15,450.28
+$80,376.36
+Income Summary
+Dividends
+Other Dividends
+Muni Bond Int.
+Credit Balance Int.
+Total
+Bond Purchase Int.
+Margin Int. Paid
+THIS PERIOD
+12,911.50
+2,760.53
+2,494.52
+44.26
+18,210.8
+0.00
+0.00
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Fixed Income
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+64,926.08
+$64,926.08
+CLOSING
+80,376.36
+.....
+$80,376.36
+027
+YEAR TO DATE
+89,213.30
+42,794.94
+5,352.05
+1,849.01
+... .
+$139.209.30
+-1,375.34
+-6,516.67
+3.498,171
+4,046,710
+2,000,000
+$9,544,881
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 29,2002
+Your Portfolio
+Allocation
+Cash & Equivalent
+37%
+Equities
+43%
+and income
+Unshaded portions denote debit balance and or shart
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+... . .
+DREYFUS TAX EXEMPT CASH
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+CENTER TR INC
+CANHORN CHEMICAL CORP
+CROWN AMERICAN REALTY TRUST
+.. . .
+FELCOR LODGING TRUST INC
+•••••••••••••••••••••.
+GLENBOROUGH REALTY TRUST INC
+GLIMCHER REALTY TRUST-SBI
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+SBI
+...
+JOHNSON& JOHNSON
+nanaaaaiinanaaaaaaaaaaaaaaaaaaaaaaaa
+KRAMONT REALTY TRUST
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+.......
+SIRIUS SATELLITE RADIO INC
+....
+Bear, Stears & Co. Inc.
+New York, New York 10179
+SYMBOLCUSIP
+DEIXX
+QUANTITY
+aaaaaaaaaaaaaaaaaaaaaa.
+3,417,794.94
+PRICE
+1.0000
+SYMBOL/CUSIP
+CTA
+CNCP.
+CWN
+FCH
+GLB
+GRT
+HRP
+HPT
+KRT
+RPT
+SIR
+ACCT
+CASH
+CASH
+CASH
+..........
+CASH
+CASH
+CASH
+....
+CASH
+CASH
+CASH
+.....
+CASH
+CASH
+QUANTITY
+2,000
+19
+5,000
+2,000
+2,000
+2,000
+10,000
+....
+2,000
+57,800
+.......
+2,000
+.......
+12,000
+1,000
+MARKET
+VALUE
+80,376
+3,417,795
+$3,498,171
+PRICE
+7.8000
+Unpriced
+9.2000
+11.4400
+17.8200
+17.7500
+1.2400
+....
+35.2000
+53.7100
+.....
+14.6500
+......
+19.7500
+0.6400
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 29, 2002
+NNUAL INCOM
+ESTATE CURENT
+******************..
+44,431
+1.3000
+$44,431
+MARKET
+VALLE
+15,600
+46,000
+22,880
+35,640
+35,500
+82,400
+... ..
+70,400
+3,104,438
+.. ..
+29,300
+.....
+237,000
+640
+027
+ESTIMATED
+ANNUAL INCOME
+480
+4,250
+1,200
+3.440
+........
+3,846
+..........
+8,000
+....
+5,760
+47,396
+......
+2,600
+.. . .
+20,160
+SURREN
+3.0769
+9.2391
+.244
+••••••••••••
+9.6521
+.....
+10.8338
+......
+9.7081
+....
+8.1818
+1.5267
+8.8737
+........
+8.5063
+01/01/03;09:30 001
+
+
+Your Portfolio Holdings (continued)
+Bear, Stears & Co. Inc.
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD November 30,2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+November 29, 2002
+Equities & Options (continued)
+DESCRIPTION
+TOO INC
+Total Equities& Options
+TOTAL EQUITIES
+FIXED INCOME
+Municipal Bonds
+DESCRIPTION
+METROPOLITAN TRANSN AUTH NY
+DEVEN DATE 053002
+DO CALL 01030/200
+SA INSURE
+Total MunicipalBonds
+TOTAL FIXED INCOME
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+SYMBOUCUSIP
+TOO
+CASH
+QUANTITY
+15,600
+PRICE
+23.5200
+MARKET
+VALLE
+366,912
+$4,046,710
+$4,046,710
+ESTIMATED
+ANNUAL INCOME
+$97,132
+$97,132
+CURRENT
+YELD IN
+SWMBOLCUSP
+CASH
+QUANTITY
+2,000,000
+PRICE
+100.0000
+MARKET VALUE
+2,000,000
+CRUE
+TERE
+2,419
+ESTIMATE
+AAL INCOM
+30,000
+CURRENT
+YIELD (%)
+1.5000
+$2,000,000
+$2,000,000
+$2,419
+$2,419
+$30,000
+$30,000
+$2,419
+$171,563
+$9,544,881
+027
+
+
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+TRANSACTION
+11/30/02
+12/02/02"DIVDEND
+12/02/02
+"REINVEST
+.....
+12/31/02
+TOTAL
+DIVIDENDS
+DATE
+DESCRIPTION
+12/10/02
+PC 1/102 PAN 1210002
+i2220102
+*CROWN AMERICAN REALTY TRUST
+REC 12/09/02 PAY 12/20/02
+TOTAL
+INTEREST
+DATE
+12/02/02
+ESCRIPTIL
+METROPOLITAN TRANSN AUTH N
+Bear, Stears & Co. Inc.
+New York, New York 10179
+DESCRIPTION
+OPENINGBALANCE
+PAGE REME CASH
+MONTHLY DIVIDEND
+ONDEND RENNESTED
+EXEMPT CASH
+CLOSINGBALANCE
+SYMBOUCUSIP
+BEIXX
+DEIXX
+SYMBOUGUSIP
+JNJ
+QUANTITY
+57,800
+5,000
+SYMBOUCUSIP
+QUANTITY
+2,000,000
+QUANTITY
+3,415,034.41
+2,760.53
+3,417,794.94
+RATE (S)
+0.2050
+0.2125
+RATE (SI
+027
+PRICE
+01/01/03;09:30 001
+CLEARED THROUGH ITS
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 29, 2002
+2,760.53
+2,760.53
+$-2,760.53
+$2,760.53
+11,849.00
+1,062.50
+$12,911.50
+2,494.52
+
+
+Bear, Stears & Co. Inc.
+New York, New York 10179
+Transaction Detail (continued)
+INTEREST (continued)
+DATE
+DESCRIPTION
+12/23/02
+INTEREST ON CREDIT BALANCE
+AT O 3/4% 11/21 THRU 12/20
+TOTAL
+SYMBOL/CUSIP
+Your messages
+I Florida residents who own, manage, or control stocks, bonds, money
+market or mutual funds having a value of $20,000 or more for
+ndividuals or $40,000 for married couples filing jointly must pay a tax
+on these items, called "Intangible Tax", by June 30 to avoid increased
+penalties. For Tax Returns and information, call the Department of
+Revenue at 1-800-352-3671,
+STOP
+****** End of Statement******
+QUANTITY
+RATE (%)
+0.7500
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+November 29, 2002
+44.26
+$2,538.78
+As part of the National Association of Securities Dealers (NASD)
+Investor Education Program, you may obtain information on the
+NASD's Public Disclosure Program by contacting the NASD at
+telephone number (800) 289-9999 or via the internet address which is
+www.nasdr.com, In addition, a brochure explaining the Public
+Disclosure Program is available from the NASD upon request,
+027
+01/01/03;09:30 001
+V639
+
+
+Bear, Stearns & Co. Inc.
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .....................
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25,2002
+3
+4
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+6,328,256
+1,867
+64,926
+3,415,034
+$9,810,083
+NET EQUITY LAST STATEMENT
+8,330,733
+CHANGE SINCE LAST STATEMENT
+1,479,350
+*is portfolio indudes one or more unpriced socurties that are E
+acted in the Total Value of Securti
+and the Not Equity This Period.
+Market Value of Your Portfolio
+$2,040,519
+Cash & Equivalent
+Equities
+Fixed
+Income
+$3,479,960
+$4,328,256
+$4.287,827
+$2,000,000
+$2,000,000
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or writo to Cient Services at Bear, Stoams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3669.
+This summary is for informational purposes only. It is not intended as a tax document.
+SIP This statement should be retained for your recards. See reverse side for important information.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+V638
+
+
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Funds Deposited
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited.
+Net Cash Activity
+Closing Balance
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+29,973.64
+$29,973.64
+Bear, Stears & Co. Inc.
+New York, New York 10179
+THIS PERICO
+29,973.6
+.. . .
+4,488.99
+1,428,297.00
+6,655.44
+51.439,441.43
+......
+-1,404,488.99
+... 1.404.488.99
+34,952.44
+64.926.08
+Income Summary
+THIS PERIOD
+Dividends
+3,740.00
+Other Dividends
+4,488.99
+Muni Bond Int.
+2,857.53
+Credit Balance Int.
+57.91
+Total
+511,144.43
+Bond Purchase Int.
+0.00
+Margin Int. Paid
+0.00
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Fixed Income
+Total
+CLOSING
+64,926.08
+564,926.08
+027
+YEAR TO DATE
+76,301.80
+40,034.41
+2,857.53
+1,804.75
+... ..
+$120,998.49
+-1,375.34
+-6,516.67
+3,479,960
+4,328,256
+2,000,000
+$9.808.216
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+36%
+Equities
+44%
+Fixed Income-
+20%
+Unshaded portions denote debit balance and or shart
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+... . .
+DREYFUS TAX EXEMPT CASH
+MA SO DATE 1140%
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+CENTER TR INC
+CANHORN CHEMICAL CORP
+CROWN AMERICAN REALTY TRUST
+.. . .
+FELCOR LODGING TRUST INC
+•••••••••••••••••••••.
+GLENBOROUGH REALTY TRUST INC
+GLIMCHER REALTY TRUST-SBI
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+SBI
+...
+JOHNSON& JOHNSON
+nanaaaaiinanaaaaaaaaaaaaaaaaaaaaaaaa
+KRAMONT REALTY TRUST
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+.......
+SIRIUS SATELLITE RADIO INC
+....
+Bear, Stears & Co. Inc.
+New York, New York 10179
+SYMBOLCUSIP
+DEIXX
+QUANTITY
+aaaaaaaaaaaaaaaaaaaaar
+3,415,034.41
+PRICE
+1.0000
+SYMBOL/CUSIP
+CTA
+CNCP.
+CWN
+FCH
+GLB
+GRT
+HRP
+HPT
+KRT
+RPT
+SIR
+ACCT
+CASH
+CASH
+CASH
+..........
+CASH
+CASH
+CASH
+....
+CASH
+CASH
+CASH
+.....
+CASH
+CASH
+QUANTITY
+2,000
+19
+5,000
+2,000
+••••••
+2,000
+2,000
+10,000
+....
+2,000
+57,800
+... .
+2,000
+.......
+12,000
+1,000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25, 2002
+MARKET
+VALUE
+64,926
+3,415,034
+$3,479,960
+ESTIMATED
+NUAL INCON
+51,226
+$51,226
+1.5000
+PRICE
+7.6900
+Unpriced
+9.4400
+11.8900
+17.2500
+16.5000
+1.370
+....
+34.1000
+57.0200
+....
+14.8500
+19.8600
+0.8600
+MARKET
+VALLE
+15,380
+47,200
+23,780
+34,500
+33,000
+83,700
+.. ..
+68,200
+3,295,756
+...
+29,700
+238.320
+860
+027
+ESTIMATED
+ANNUAL INCOME
+480
+4,250
+1,200
+••••••••••••
+3.440
+...........
+3,846
+..........
+8,000
+....
+5,760
+47,396
+2,600
+....
+20,160
+CURREN
+VELD :
+3.1209
+9.0042
+.........
+5.0463
+9.9710
+.........
+11.6545
+.........
+9.557
+... ..
+8.4457
+1.4381
+8.7542
+8.4592
+
+
+Your Portfolio Holdings (continued)
+Bear, Stears & Co. Inc.
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD October 26, 2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25,2002
+Equities & Options (continued)
+DESCRIPTION
+TOO INC
+Total Equities& Options
+TOTAL EQUITIES
+FIXED INCOME
+Municipal Bonds
+DESCRIPTION
+METROPOLITAN TRANSN AUTH NY
+EV REDG-SER D
+TED DATE 05/30/0
+OOK ENTRY ONL
+AR CALL 12/25/200
+FSA INSURED
+Total Municipal Bonds
+TOTAL FIXED INCOME
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+SYMBOUCUSIP
+TOO
+CASH
+QUANTITY
+15,600
+PRICE
+29.3500
+MARKET
+VALLE
+457,860
+$4,328,256
+$4,328,256
+ESTIMATEC
+ANNUAL INCOME
+$97,132
+$97,132
+CURRENT
+YELD IN
+SWMBOLCUSP
+CASH
+QUANTITY
+2,000,000
+PRICE
+100.0000
+MARKET VALUE
+2,000,000
+1,867
+ESTIMATED
+ANNUAL INCOM
+24,000
+CURRENT
+YIELD (%)
+1.2000
+$2,000,000
+$2,000,000
+$1,867
+$1,867
+$24,000
+$24,000
+$1,867
+$172,358
+$9,808,216
+120
+V638
+
+
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+11/19/02
+TRANSACTION
+FUNDS REC
+DESCRIPTION
+NDS WIRED TO CITIBANK FRO
+ORGAN STANLE
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MODAY
+10/26/02
+17701/02
+TRANSACTION
+DIVIDEND
+11/01702
+REINVESI
+11/20/02 BOUGHT
+DESCRIPTION
+OPENINGBALANCE
+MANAGENT ISENSE CASHT
+MONTHLY DIVIDEND
+MANAGEMENT ISE CASH
+DIVIDEND REINVESTED
+MANAGEMENT NEE BECASH
+CLOSINGBALANCE
+11/29/02
+TOTAL
+DIVIDENDS
+DATE
+10/31/02
+DESCRIPTION
+FELCOR LODGING TRUST ING
+REC 10/11/02 PAY 10/31/02
+Bear, Stears & Co. Inc.
+New York, New York 10179
+SYMBOUCUSIP
+FCH
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD October 26, 2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25,2002
+1,428,297.00
+$1,428.297.00
+SYMBOUGUSIP
+"BEIXX
+DEIXX
+QUANTITY
+2,010,545.42
+4,488.99
+1,400,000
+3,415,034.41
+PRICE
+1.0000
+QUANTITY
+2,000
+4.488.99
+1,400,000.00
+$-1,404.488.99
+300.00
+.....
+*4,488.99
+$4,488.99
+RATE (S)
+0.1500
+027
+
+
+Transaction Detail (continued)
+DIVIDENDS (continued)
+DATE
+DESCRIPTION
+11/21/02
+HOSPITALITY PROPERTIES TRUST
+REC 10/25/02 PAY 11/21/02
+11/22/02 HAPT PROPERTIES TR-SBI
+REC 10/22/02 PAY 11/22/02
+TOTAL
+INTEREST
+DATE
+11/01/02
+DESCRIPTION
+METROPOLITAN TRANSN AUTH NY
+EV RFDG-SER D-:
+RE 100102 PA 9090
+11/21/02
+"INTEREST ON CREDIT BALANCE
+AT 1 1/4% 10/21 THRU 11/05
+/21/02 INTEREST ONCREDIT BALANC
+0 3/4% 11/06 THRU 11:
+TOTAL
+Bear, Stears & Co. Inc.
+New York, New York 10179
+SYMBOUCUSIP
+HPT
+"HAP
+QUANTITY
+2,000
+RATE (S)
+0.7200
+10,000
+• 0.2000
+SYMBOL/CUSIP
+QUANTITY
+2,000,000
+RATE INJ
+2500
+0.7500
+STOP
+****** End of Statement******
+L20
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25,2002
+1,440.00
+2,000.00
+$3,740.00
+2,857.53
+1721
+40.70
+$2,915.44
+
+
+Bear, Stearns & Co. Inc.
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .....................
+.....
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+3
+4
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+6,287,827
+2,387
+29,974
+2,010,545
+$8,330,733
+.....
+NET EQUITY LAST STATEMENT
+10,167,939
+CHANGE SINCE LAST STATEMENT
+-1,837,206
+"This portfolio indudes one or mare unpriced securties that are not
+reflected in tho Total Value of Securties and the Not Equity This Period
+Market Value of Your Portfolio
+$2.040.519
+Cash & Equivalent
+Equities
+Fixed
+Income
+$6.027,597
+$4,287,827
+$4,140,342
+$0
+$2,000,000
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen is four for ratanal purger red de Set revere date for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Securities Bought
+Money Fund
+Funds Withdrawn
+Dividends/Interest Charged
+Amount Debited
+Net Cash Activity
+Closing Balance,
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+23,693.89
+$23,693.89
+Bear, Stears & Co. Inc.
+New York, New York 10179
+THIS PERICO
+23,693.85
+... .
+4,006,642.84
+7,657.59
+$4,014,300.43
+...
+-2,000,002.50
+-6,642.84
+-2,000,000.00
+-1,375.34
+54.008.020.68
+6,279.75
+$29.973.64
+Income Summary
+THIS PERIOD
+Dividends
+7,631.60
+Other Dividends
+6,642.84
+Credit Balance Int.
+25.99
+......
+Total
+$14,300.43
+Bond Purchase Int.
+-1,375.34
+Margin Int. Paid
+0.00
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Fixed Income
+CLOSING
+29,973.64
+.........
+$29,973.64
+....
+027
+YEAR TO DATE
+72,561.80
+35,545.42
+1,746.84
+.....
+.$109.854.06
+-1,375.34
+-6,516.67
+2,040,519
+4,287,827
+2,000,000
+$8,328,346
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+25%
+Equities
+51%
+Fixed Income
+24%
+Unshaded portions denole debi balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+... . .
+DREYFUS TAX EXEMPT CASH
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+CENTER TR INC
+CANHORN CHEMICAL CORP
+CROWN AMERICAN REALTY TRUST
+.. . .
+FELCOR LODGING TRUST INC
+•••••••••••••••••••••.
+GLENBOROUGH REALTY TRUST INC
+GLIMCHER REALTY TRUST-SBI
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+SBI
+...
+JOHNSON& JOHNSON
+nanaaaaiinanaaaaaaaaaaaaaaaaaaaaaaaa
+KRAMONT REALTY TRUST
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+.......
+SIRIUS SATELLITE RADIO INC
+....
+Bear, Stears & Co. Inc.
+New York, New York 10179
+SYMBOLCUSIP
+DEIXX
+QUANTITY
+arisaaaaaaaaaaaaaaaaar
+2,010,545.42
+1.0000
+SYMBOL/CUSIP
+CTA
+CNCP.
+CWN
+FCH
+GLB
+GRT
+HRP
+HPT
+KRT
+RPT
+SIR
+ACCT
+CASH
+ASH
+CASH
+.......
+CASH
+CASH
+CASH
+....
+CASH
+CASH
+CASH
+.....
+CASH
+CASH
+QUANTITY
+2,000
+19
+5,000
+2,000
+2,000
+2,000
+10,000
+....
+2,000
+57,800
+.......
+2,000
+.......
+12,000
+1,000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+MARKET
+VALUE
+29,974
+2,010,545
+$2,040,519
+ESTIMATED
+ANNUAL INCOME
+26,137
+$26,137
+1.3000
+PRICE
+6.0500
+Unpriced
+8.9500
+11.0700
+19.5400
+17.2200
+8.0500
+....
+32.0000
+57.7600
+....
+14.2200
+......
+19.1000
+0.7490
+MARKET
+VALLE
+12,100
+44,750
+22,140
+••••••••••:
+39,080
+34,440
+80,500
+....
+64,000
+3,338,528
+...
+28,440
+229,200
+749
+027
+ESTIMATED
+ANNUAL INCOME
+480
+4,250
+1,200
+3.440
+...........
+3,846
+..........
+8,000
+....
+5,760
+47,396
+......
+2,600
+....
+20,160
+SURREN
+3.9669
+9.4972
+.........
+5.420
+•••••••••••••
+8.8025
+......
+1.1672
+3.9379
+... . .
+9.0000
+1.4197
+.......
+9.1421
+8.7958
+VE37
+
+
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+TOO INC
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOUCUSIP
+TOO
+FIXED INCOME
+Municipal Bonds
+DESCRIPTION
+METROPOLITAN TRANSN AUTH NY
+EV REDG-SER D
+TED DATE 05/30/0
+BAR CALL 1121/2002
+FSA INSURED
+SWMBOLCUSP
+Total MunicipalBonds
+TOTAL FIXED INCOME
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stears & Co. Inc.
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 28,2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+September 27,2002
+CASH
+QUANTITY
+15,600
+PRICE
+25.2500
+MARKET
+VALLE
+393,900
+$4,287,827
+$4,287,827
+ESTIMATED
+ANNUAL INCOME
+$97,132
+$97,132
+CURRENT
+YELD IN
+CASH
+QUANTITY
+2,000,000
+PRICE
+100.0000
+MARKET VALUE
+2,000,000
+2,387
+ESTIMATE
+NNUAL INCOM
+37,000
+CURRENT
+YIELD (%)
+1.8500
+$2,000,000
+$2,000,000
+$2,387
+$2,387
+$37,000
+$37,000
+$2,387
+$160,269
+$8,328,346
+120
+VB37
+
+
+Bear. Stearns & Co. Inc.
+New York, New York 10179
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTEMENT TREE
+TRANSACTION
+T0/17/02 10/17/02
+BOUGHT
+DESCRIPTION
+METROPOLITAN TRANS AUTH NY
+REV REDG-SER D-2
+UE 11/01/2032 01.7509
+UBJ TO EXTRA ORD CAL
+THIS SECURITY HAS PUT FEATURES
+TOTAL
+DEPOSITS AND WITHDRAWALS
+DATE
+10/11/02
+TRANSACTION
+FND WIRED
+DESCRIPTION
+SO SENANAL RESHIBED TO
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+TRANSACTION
+09/28/02
+DESCAIPTON
+OPENINGBALANCE
+0/D1/0
+DIVIDEND
+10101/02
+REINVEST
+18/11702 SOLD
+RAFTER ERY REMET
+• CASH
+MONTHLY DIVIDEND
+REXERE RENE CASH
+DIVIDEND REINVESTED
+MANAGEMENT SENSE CASH"
+SYMBOLCUSIP
+QUANTITY
+2,000,000
+ACCR. INT.
+PRICE
+100.00000
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 28,2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27, 2002
+2,000,002.50
+1,375.34
+$-2,001,377.84
+DEBIT AMOLNT
+2,000,000.00
+$2,000,000.00
+SYMBOUCUSIP
+*DEIXX
+QUANTITY
+6,003,902.58
+6,642.84
+2,000,000
+027
+PRICE
+6,642.84
+16,642.84
+2,000,000.00
+1.0000
+VE37
+
+
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+TRANSACTION
+10/17/02
+SOLD
+...
+10/25/02
+TOTAL
+DESCRIPTION
+PRAHAGHMERY SENSA CASH
+CLOSINGBALANCER
+DIVIDENDS
+DATE
+DESCRIPTION
+10/15/02
+GLENBOROUGH REALTY TRUST INC
+REC 10/01/02 PAY 10/15/02
+10/15/02
+'"LIMCHER REALTY TRUST SBI
+REC 09/30/02 PAY 10/15/02
+10/15/02 "RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+REC 09/30/02 PAY 10/15/02
+10/18/02 KRAMONT REALTY TAUST*
+REC 09/27/02 PAY 10/18/02
+10/21/02
+'CENTER TR INC
+REC 09/30/02 PAY 10/21/02
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+10/21/02 INTEREST ON CREDIT BALANCE
+AT 1 1/4% 09/21 THRU 10/20
+TOTAL
+Bear, Stears & Co. Inc.
+New York, New York 10179
+SYMBOUCUSIP
+DEIXX
+QUANTITY
+2,000,000
+2,010,545.42
+SYMBOL/CUSIP
+GLB
+'APT
+"CTA
+QUANTITY
+2,000
+2,000
+12,000
+RATE (S)
+0.4300
+0.4808
+*0.4200
+*2,000*•*0.3250
+2,000
+0.0600
+SYMBOL/CUSIP
+QUANTITY
+RATE (%)
+1.2500
+027
+PRICE
+1.0000
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 28,2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27, 2002
+2,000,000.00
+.....
+$-6,642.84
+$4.006,642.84
+860.00
+961.60
+5,040.00
+= 650.00
+120.00
+$7,631.60
+25.99
+$25.99
+VB37
+
+
+Bear, Stearns & Co. Inc.
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ........../../............................
+Your Messages
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+3
+5
+7
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+4,140,342
+23,694
+6,003,903
+S10,167,939
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+10,110,577
+57,362
+*This portfolio indudes one or more unpriced securties that are not
+reflected in the Total Value of Securties and the Net Equity This Period.
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+Equities
+$6,027,597
+$6,007,003
+$4,140,342
+$4,103,574
+Current market value
+Last statement's market value
+Important Message
+Confirmation: Unless we
+hear from
+you to the
+contrary, it is our
+understanding that any free
+redit balances in you
+ccount are bein
+maintained to facilitate
+your intention to invest
+such amounts through us
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal purpose red de Set revere date for portant iformation.
+
+
+2 of 9
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or 9
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance
+Bear, Stears & Co. Inc.
+New York, New York 10179
+THIS PERIOD
+$10.766.17
+7,665.09
+12,927.72
+$20,592.81
+-7,665.09
+....
+$-7,665.09
+12,927.72
+523.693,.89
+Income Summary
+Dividends
+Other Dividends
+Credit Balance Int.
+Total
+Margin Int. Paid
+THIS PERIOD
+12,911.50
+7,665.09
+16.22
+$20,592.81
+0.00
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+10,766.17
+$10,766.17
+CLOSING
+23,693.89
+$23,693.89
+027
+YEAR TO DATE
+64,930.20
+28,902.58
+1,720.85
+$95.553.63
+-6,516.67
+6,027,597
+4,140,342
+10,167,93
+09/29/02;13:15 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+Your Portfolio
+Allocation
+Equities
+40%
+Cash & Equivalent
+60%
+Unshaded portions denole debi balance and'or short
+
+
+4 of g
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+... .
+DREYFUS TAX EXEMPT CASH
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+CENTER TR INC
+CANHORN CHEMICAL CORP
+CROWN AMERICAN REALTY TRUST
+.. . .
+FELCOR LODGING TRUST INC
+•••••••••••••••••••••.
+GLENBOROUGH REALTY TRUST INC
+GLIMCHER REALTY TRUST-SBI
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+SBI
+...
+JOHNSON& JOHNSON
+nanaaaaiinanaaaaaaaaaaaaaaaaaaaaaaaa
+KRAMONT REALTY TRUST
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+.......
+SIRIUS SATELLITE RADIO INC
+....
+OFFICE SERVICING YOUR ACOOUNT
+Bear, Stears & Co. Inc.
+New York, New York 10179
+SYMBOLCUSIP
+DEIXX
+QUANTITY
+.....
+6,003,902.58
+1.0000
+SYMBOL/CUSIP
+CTA
+CNCP.
+CWN
+FCH
+GLB
+GRT
+HRP
+HPT
+KRT
+RPT
+SIR
+ACCT
+CASH
+CASH
+CASH
+..........
+CASH
+CASH
+CASH
+....
+CASH
+CASH
+CASH
+.....
+CASH
+CASH
+QUANTITY
+2,000
+19
+5,000
+2,000
+2,000
+2,000
+10,000
+....
+2,000
+57,800
+.......
+2,000
+.......
+12,000
+1,000
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+MARKET
+JALUE
+23,694
+6,003,903
+$6,027,597
+STIMATE
+NUAL INCON
+78,051
+$78,051
+....•
+1.3000
+PRICE
+5.9000
+Unpriced
+9.3000
+13.1400
+20.2000
+18.5100
+1.200
+... .
+33.4100
+55.1000
+....
+14.9500
+19.3300
+1.1500
+MARKET
+VALLE
+11,800
+46,500
+26,280
+40,400
+37,020
+82,000
+.. ..
+66,820
+3,184,780
+.. . .
+29,900
+.....•.
+231,960
+1,150
+027
+ESTIMATED
+ANNUAL INCOME
+480
+4,250
+1,200
+••••••••••••
+3.440
+...........
+3,846
+..........
+8,000
+....
+5,760
+47,396
+2,600
+....
+20,160
+CURRENT
+YIELD (S)
+4.0678
+9.1398
+4.5662
+••••••••
+3.514
+-*---.....
+10.3890
+....
+9.756
+.....
+8.6202
+1.4882
+8.6957
+.......
+8.6912
+
+
+5 org
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+TOO INC
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+TOO
+CASH
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+TRANSACTION
+08/31/02
+09/03/02 DIVIDEND
+08/03/02 REINVEST
+DESCAIPTION
+OPENINGBALANCE
+MMANAGEMEN TESTS CASH"
+MONTHLY DIVIDEND
+REYFUS TAX EXEMPT CASI
+ANAGEMENT INSTL S
+DIVIDEND REINVESTED
+CLOSINGBALANCE
+09/27/02
+TOTAL
+Bear, Stears & Co. Inc.
+New York, New York 10179
+QUANTITY
+15,600
+PRICE
+24.4700
+SYMBOUCUSIP
+"DEIXX"
+DEIXX
+MARKET
+VALLE
+381,732
+$4,140,342
+$4,140,342
+$175,183
+$10,167,939
+QUANTITY
+5,996,237.49
+7,665.09
+6,003,902.58
+027
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+ESTIMATED
+ANNUAL INCOME
+$97,132
+$97,132
+CURRENT
+YELD IN
+PRICE
+7,665.09
+$-7,665.09
+7,665.09
+$7.665.09
+
+
+6 of g
+Bear, Stears & Co. Inc.
+New York, New York 10179
+Transaction Detail (continued)
+DIVIDENDS
+09710/02
+DESCRIPTION
+JOHNSON& JOHNSON
+REC 08/20/02 PAY 09/10/02
+09/13/02 CROWN AMERICAN REALTY TRUST
+REC 08/30/02 PAY 09/13/02
+TOTAL
+INTEREST
+SYMBOUCUSIP
+JNJ
+CWN
+QUANTITY
+RATE (S)
+57,800
+0.2050
+*5,000 0.212
+0.2125
+DATE
+09/23/02
+TOTAL
+DESCRIPTION
+INTEREST ONCREDIT BALANCE
+AT 1 1/4% 08/21 THRU 09/20
+SYMBOLICUSIP
+QUANTITY
+RATE (%)
+1.2500
+027
+09/29/02;13:15 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30,2002
+11,849.00
+......
+,062.5
+$12,911.50
+CAEDIT AMOUNT
+16.22
+$16.22
+
+
+7 of g
+Bear, Steams & Co. Inc.
+New York, New York 10179
+Your messages
+Bear, Stearns Securities Corp, Net Capital and Net Capital
+Requirements:
+A complete copy of the Bear, Stearns Securities Corp, Statement
+of Financial Condition is available on the web site
+www.bearstearns.com, Alternatively, to request a free printed copy
+please call -toll free 1-866-299-9331.
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+August 30, 2002
+Securities and other assets in your account are the firm's collateral
+for any margin loan made to you, If the securities and other assets in
+your account decline in value, so does the value of the collateral
+supporting your loan, and, as a result, the firm can take action, such
+as issue a margin call and/or sell securities or other assets in any of
+Equiry in the scount, It's mportant that you tuly understand required
+the following:
+> You can lose more funds than you deposit in the margin account.
+> The firm can force the sale of securities or other assets in your
+accounts).
+> The firm can sell your securities or other assets without contacting
+> You are not entitled to choose which securities or other assets in
+your accounts) are liquidated or sold to meet a margin call.
+> The firm can increase its "house" maintenance margin requirements
+at any time and is not required to provide you advance written notice.
+> You are not entitled to an extension of time on a margin call.
+027
+
+
+8 of 9
+Bear, Stearns & Co. Inc.
+New York, New York 10179
+13P
+This statement is provided to explain Bear, Stearns & Co. Inc.'s
+(BSC*) payment for order flow practices.
+BSC routes a majority of orders for customer securities transactions
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+Pursuant to SEC Rule 11Ac1-6, please note the following:
+Bear, Stearns & Co, Inc, will post its quarterly routing statistics at the
+following web link:
+Customers of Bear, Stearns & Co. Inc, may request information on
+any order executed within the prior six months from the time of the
+request, Specifically, you may request the identity of the venue to
+which the identified orders were routed for execution, whether the order
+was directed by you to that venue, and the time of the executions, i
+any, that resulted from such orders.
+027
+09/29/02;13:15 001
+
+
+9 of 9
+Bear, Stearns & Co. Inc.
+New York, New York 10179
+13P
+The following account service fees will be charged to applicable
+accounts as of November 1, 2002:
+The service charge per transaction will be $5,00, Accounts
+transferred from Bear Stearns will be charged a $75.00 account
+transfer fee. There will be a $50.00 fee for each stock certificate
+hat is sent out in registered form at the customer's request, W
+trongly recommend against holding stock certificates in physic
+form due to the possibility of theft, loss or damage.
+13P
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+August 30, 2002
+NOTICE OF CHANGE PURSUANT TO THE TRUTH IN LENDING
+SEC RULE 10b-16
+Effective as of November 15, 2002, the annual rate of interest charged
+on any credit extended to you by Bear Steams Securities for the
+purpose of purchasing, carrying or trading in any security or other
+property shall be based on either the Bear Stearns Margin Basis Rate,
+the Bear Stearns Securities Fed Funds Rate or the London Interbank
+Offering Rate (LIBOR"). The Bear Stearns Margin Basis Rate will be
+quoted daily by Bear Stearns at our main office in New York, Factors
+affecting the determination of the Bear Stearns Margin Basis Rate
+will include the short-term market interest rates quoted by money
+center banks and the Federal Reserve and the rate that Bear Stearns
+is charged for borrowing money, The Bear Stearns Securities Fed
+Funds Rate is the rate for U.S. dollar funds, as quoted by an
+independent broker of such funds selected by Bear Stearns Securities
+for the last transaction completed prior to 9:30 a,m, (Eastern Time)
+on the business day on which such rate is determined. The annual
+rate of interest will be no more than 3% above the Bear Stearns
+Margin Basis Rate or 4% above either the Bear Stearns Securities
+Fed Funds Rate or LIBOR and will appear on your monthly statements.
+Since the rate of interest charged is related to the Bear Stearns
+Margin Basis Rate, the Bear Stearns Securities Fed Funds Rate or
+LIBOR, any changes in these rates will cause corresponding changes
+in the rate charged to your account, which changes will be made
+without prior notice to you. If for any other reason Bear Stearns
+Securities changes the rate of interest it charges you, we will give you
+at least 30 days prior notice.
+The "Statement of Interest Charges Pursuant to the "Truth-in-Lending"
+SEC Rule 10b-16" previously provided to you remains in effect
+except to the extent specifically amended by this notice.
+027
+VB36
+
+
+Bear, Stearns & Co. Inc.
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN, IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ....
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity....
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+3
+6
+Hollandlold
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+4,103.574
+10,766
+5,996,237
+NET EQUITY THIS PERIOD
+S10,110,577
+••••••••/••••••••••••
+NET EQUITY LAST STATEMENT
+11,841,586
+CHANGE SINCE LAST STATEMENT
+-1,731,009
+*This portfolio indudes one or more unpriced securties that are not
+relected in the Total Value of Securities and the Net Equity This Period.
+Market Value of Your Portfolio
+Cash & Equivalent
+Equities
+86.007.008 57.994,518
+$4,103,574
+$3,847,068
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four or ratanal purposes rear die Set revere date for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Funds Withdrawn
+Amount Debited
+Net Cash Activity
+Closing Balance
+OFFICE SERVICING YOUR ACOOUNT
+Bear, Stears & Co. Inc.
+New York, New York 10179
+THIS PERICO
+$7,018.42
+......
+2,008,737.92
+3.747.75
+$2,012,485.67
+....
+-8,737.92
+-2,000,000.00
+$-2,008.737.92
+3,747.75
+$510.766.17
+Income Summary
+Dividends
+Other Dividends
+Credit Balance Int.
+Total
+.. . . .
+Margin Int. Paid
+THIS PERIOD
+3,740.00
+8,737.92
+7.75
+$12,485.67
+0.00
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+7,018.42
+$7,018.42
+CLOSING
+10,766.17
+$10,766.17
+....
+027
+YEAR TO DATE
+52,018.70
+21,237.49
+1,704.63
+......
+$74,960.82
+-6,516.67
+6,007,003
+4,103,574
+$10.110.577
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+Your Portfolio
+Allocation
+Equities
+40%
+Cash & Equivalent
+60%
+Unshaded portions denole debi balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+.... . .
+DREYFUS TAX EXEMPT CASH
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+CENTER TR INC
+••••• •••!•••••••••••••••••
+CANHORN CHEMICAL CORP
+........
+CROWN AMERICAN REALTY TRUST
+ana i iga8aggggagg i gaganaaaagaaaaaa
+FELCOR LODGING TRUST INC
+.. . .
+GLENBOROUGH REALTY TRUST INC
+GLIMCHER REALTY TRUST-SB**
+. . .
+HRPT PROPERTIES TR-SBI
+. . . .
+HOSPITALITY PROPERTIES TRUST
+SBI
+JOHNSON& JOHNSON
+KRAMONT REALTY TRUST
+..........
+RAMCO GERSHENSON PROPERTIE:
+TRUST-MD SBI
+SIRIUS SATELLITE RADIO INC
+Bear, Stears & Co. Inc.
+New York, New York 10179
+SYMBOLCUSIP
+DEIXX
+SYMBOUCUSIP
+СТА
+CNCPF
+CWN
+.. .
+FCH
+......
+GLB
+GRT
+HRP
+HPT
+JNJ
+KRT
+RPT
+SIRI
+QUANTITY
+5,996,237.49
+Дост
+CASH
+ASH
+CASH
+...
+CASH
+......
+CASH
+'''' S
+CASH
+CASH
+CASH
+SASH
+CASH
+1.0000
+QUANTITY
+2,000
+19
+5,000
+•.........
+2,000
+...
+2,000
+2,000
+.....
+10,000
+2,000
+57,800
+2,000
+12,000
+1,000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocktyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+MARKET
+VALUE
+10,766
+5,996,237
+$6,007,003
+PRICE
+5.7000
+•••••••!!!
+Unpriced
+9.5500
+.. .
+14.8000
+21.0500
+18:0700
+8.4200
+. . .
+34.6800
+54.3100
+5.000
+20.3400
+1.5100
+ESTIMATE
+NUAL INCON
+77,951
+1.3000
+$77,951
+MARKET
+VALUE
+11,400
+ESTIMATED
+ANNUAL INCOME
+480
+CURRENT
+YIELD (N)
+4.2105
+47,750
+. ..
+29,600
+....
+42,100
+36,140
+•.........
+4,20
+69,360
+3,139,118
+30.000
+••••••••
+244,080
+1,510
+4,250
+8.9005
+......
+1,200
+.. . .
+4.0541
+....
+3.440
+8.1710
+384610.6419
+....
+8,000
+.......
+9.5012
+5,760
+8.3045
+47,396
+1.5099
+2,00
+8.6667
+200*
+•••••••
+8.2596
+027
+
+
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+TOO INC
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLOUSIP
+TOO
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stears & Co. Inc.
+New York, New York 10179
+ACCT
+CASH
+QUANTITY
+15,600
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+08/08/02
+TRANSACTION
+FND WIRED
+08/30/02
+FND WIRE
+TOTAL
+DESCRIPTION
+NDS WIRED TO
+3K & TR O
+LA SEARE ENDS WIRED TO
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+Juty 26,2002
+PRICE
+23.6100
+MARKET
+VALUE
+368,316
+$4,103,574
+$4,103,574
+$175,083
+$10,110,577
+ESTIMATED
+ANNUAL INCOME
+$97,132
+$97,132
+CURRENT
+YIELD (%)
+1,000,000.00
+1,000,000.00
+$-2,000,000.00
+027
+
+
+Bear, Stears & Co. Inc.
+New York, New York 10179
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTKN
+07/27/02
+08/0102 DIVIDEND
+08i01/02
+*"REINVEST
+08/08/02 SOLD
+08/30/02 SOLD
+DESCRIPTION
+OPENINGBALANCE
+PAGE ME CASH
+MONTHLY DIVIDEND
+RAME REBECASH
+CLOSINGBALANCE
+08/30102
+TOTAL
+DIVIDENDS
+DATE
+DESCRIPTION
+07/31/02
+FELCOR LODGING TRUST INC
+REC 07/15/02 PAY 07/31/02
+08/22/02
+' HOSPITALITY PROPERTIES TRUST
+REC 07/24/02 PAY 08/22/02
+08/23/02 HAPT PROPERTIES TR-SBI
+REC 07/25/02 PAY 08/23/02
+TOTAL
+SYMBOUCUSIP
+FCH
+HPT
+HAP
+SYMBOUCUSIP
+BEIXX
+DEIXX
+"DEIXX
+"DEIXX"
+QUANTITY
+7,987,499.57
+8,737.92
+1,000,000
+1,000,000
+5.996.237.49
+QUANTITY
+2,000
+2,000
+RATE (S)
+0.1500
+0.7200
+10,000 |
+0.2000
+027
+PRICE
+1.0000
+1.0000
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26,2002
+8,737.92
+8,737.92
+1,000,000.00
+1,000,000.00
+$2,008,737.92
+$-8.737.92
+300.00
+1,440.00
+2,000.00
+$3,740.00
+
+
+Bear, Stears & Co. Inc.
+New York, New York 10179
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+08/21/02
+INTEREST ON CREDIT BALANCE
+AT 1 1/4% 07/21 THRU 08/20
+TOTAL
+SYMBOUCUSIP
+QUANTITY
+RATE 1%
+1.2500
+STOP
+*** End of Statement******
+027
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+7.75
+$7.75
+
+
+Bear, Stearns & Co. Inc.
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary .............................
+Your Portfolio Holdings
+Transaction Detail .................................
+Fund Activity ........•••••••••••••IIIIII.
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+4
+5
+6
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+3,847,068
+7,018
+7,987,500
+NET EQUITY THIS PERIOD
+$11,841,586
+nonsenses
+NET EQUITY LAST STATEMENT
+13,100,511
+CHANGE SINCE LAST STATEMENT
+-1,258,924
+*This portfolio indudes one or more unpriced securties that are not
+relected in the Total Value of Securites and the Net Equity This Period.
+Market Value of Your Portfolio
+Cash & Equivalent
+Equities
+$7.994,518
+$8,978,134
+$3,847,068
+$4,122,377
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+do Client Services at 800-634-1428; or write to Cient Servicos at Bear, Stoama Securitios
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four or ratanal purpose rebr de Set revere dae for portant iformation.
+07/27102:17:22 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Stears & Co. Inc.
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Funds Withdrawn
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+5698.754.87
+1,008,120.29
+8,263.55
+$1,016,383.84
+-708,120.29
+-1,000,000.00
+.....s.1.708.120.29
+-691,736.45
+27.018.4
+Income Summary
+THIS PERIOD
+Dividends
+7,631.60
+Other Dividends
+8,120.29
+Credit Balance Int.
+631.95
+... .
+Total
+$16.383.84
+Margin Int. Paid
+0.00
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+698,754.87
+$698,754.87
+CLOSING
+7,018.42
+8.....
+$7,018.42
+027
+YEAR TO DATE
+48,278.70
+12,499.57
+1,696.88
+......
+$62.475.15
+-6,516.67
+7,994,518
+3,847,068
+511.841.586
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+Your Portfolio
+Allocation
+Equities
+32%
+Cash & Equivalent
+68%
+Unshaded portions denole debt balance and'or short
+from the absolute market value of your portfolio.
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+.... . .
+DREYFUS TAX EXEMPT CASH
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+CENTER TR INC
+••••• •••!•••••••••••••••••
+CANHORN CHEMICAL CORP
+........
+CROWN AMERICAN REALTY TRUST
+ana i iga8aggggagg i gaganaaaagaaaaaa
+FELCOR LODGING TRUST INC
+.. . .
+GLENBOROUGH REALTY TRUST INC
+GLIMCHER REALTY TRUST-SB**
+. . .
+HRPT PROPERTIES TR-SBI
+. . . .
+HOSPITALITY PROPERTIES TRUST
+SBI
+JOHNSON& JOHNSON
+KRAMONT REALTY TRUST
+..........
+RAMCO GERSHENSON PROPERTIE:
+TRUST-MD SBI
+SIRIUS SATELLITE RADIO INC
+Bear, Stears & Co. Inc.
+New York, New York 10179
+SYMBOLCUSIP
+DEIXX
+QUANTITY
+ailaaaaaaaaaaaaaa.
+7,987,499.57
+PRICE
+1.0000
+SYMBOUCUSIP
+СТА
+CNCPF
+CWN
+.. .
+FCH
+......
+GLB
+GRT
+HRP
+HPT
+JNJ
+KRT
+RPT
+SIRI
+Дост
+CASH
+ASH
+CASH
+...
+CASH
+......
+CASH
+'''' S
+CASH
+CASH
+CASH
+SASH
+CASH
+QUANTITY
+2,000
+19
+5,000
+•.........
+2,000
+.....
+2,000
+2,000
+.. . .
+10,000
+2,000
+57,800
+2,000
+12,000
+1,000
+MARKET
+VALUE
+7,018
+7,987,500
+$7,994,518
+PRICE
+6.0000
+.. !!!
+Unpriced
+8.3500
+.........
+14.9000
+......
+0.000
+17.3000
+7.8000
+31.6200
+49.6100
+
+20.3800
+1.6000
+LEARED THAOUGH IT:
+HOLLY OWNED SUBSIDIAR'
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocktyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+UNNUAL INCOME
+ES TATE CURER
+103,837
+$103,837
+1.3000
+MARKET
+VALUE
+12,000
+•••••• !
+41,750
+. ..
+29,800
+... .
+40,000
+34,600
+...
+78,000
+63,240
+2,867,458
+26,900
+*244,560
+1,600
+027
+ESTIMATED
+CURRENT
+ANNUAL INCOME
+480
+YIELD (%
+4.0000
+.•••••.•••••••••••••
+4,250
+10.1796
+.. . .
+1,200
+4.0268
+3,440
+8.6000
+3,84011.1156
+...... -
+3,000
+10.2564
+5,760
+9.1082
+47,396
+1.6529
+2,00*
+9.6654
+••••••••••
+8.2434
+07/27102;17:22 001
+
+
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+TOO INC
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLOUSIP
+TOO
+Bear, Stears & Co. Inc.
+New York, New York 10179
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+ACCT
+CASH
+QUANTITY
+15,600
+PRICE
+26.1000
+MARKET
+VALUE
+407,160
+$3,847,068
+$3,847,068
+ESTIMATED
+ANNUAL INCOME
+$97,132
+$97,132
+CURRENT
+YIELD (%)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+$200,969
+$11,841,586
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+07/23/02
+TRANSACTION
+END WIRED
+DESCRIPTION
+TOTAL
+1,000,000.00
+$-1,000,000.00
+027
+
+
+Bear, Stears & Co. Inc.
+New York, New York 10179
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+06/29/02
+07/01/02 DIVIDEND
+07/01/02
+*REINVEST
+87717/02 BOUGHT
+07723/02
+DESCRIPTION
+OPENINGBALANCE
+PAGE REME CASH
+MONTHLY DIVIDEND
+MANAGEMENT INSTENS CASH
+CLOSINGBALANCE
+07/26102
+TOTAL
+DIVIDENDS
+DATE
+DESCRIPTION
+07/15/02
+GLENBOROUGH REALTY TRUST INC
+REC 07/01/02 PAY 07/15/02
+07715/02
+*CLIMCHER REALTY TRUST-SBI
+REC 06/28/02 PAY 07/15/02
+07716/02 " RAMCO GERSHENSON PROPERTIES
+RUST-MD SE
+EC 06/30/02 PAY 07/16/0
+07/19/02
+'''KRAMONT REALTY TRUST
+REC 06/26/02 PAY 07/19/02
+07/22/02
+REC 06/28/02 PAY 07/22/02
+TOTAL
+SYMBOUGUSIP
+GLB
+GAT
+APT
+KAT
+"CTA
+SYMBOUCUSIP
+"BEIXX
+BEIxX
+"DEIXX"
+"DEIXX
+QUANTITY
+8,279,379.28
+8,120.29
+700,000
+1000,000
+7,987,499.57
+QUANTITY
+RATE (S)
+2,000
+0.4300
+2,000"
+0.4808
+12,0000.4200
+2,000
+2,000
+*0.3250
+0.0600
+027
+PRICE
+1.0000
+1.0000
+CLEARED THROUGH ITS
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+8,120.29
+8,120.29
+700,000.00
+1,000,000.00
+$-708,120.29
+$1,008,120.29
+860.00
+961.60
+5,040.00
+650.00
+120.00
+$7,631.60
+07127102;17:22 001
+
+
+Bear, Stears & Co. Inc.
+New York, New York 10179
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+07/22/02
+INTEREST ON CREDIT BALANCE
+AT 1 1/4% 06/21 THRU 07/20
+TOTAL
+SYMBOUCUSIP
+QUANTITY
+RATE 1%
+1.2500
+STOP
+****** End of Statement******
+027
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+631.95
+$631.95
+
+
+Bear, Stearns & Co. Inc.
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ....
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ....
+...............
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+4
+6
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+NET CREDIT BALANCE
+4,122,377
+MONEY MARKET FUND BALANCE
+698,755
+8.279.379
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+$13,100,511
+••••••••/••••••••••••
+11.805.819
+CHANGE SINCE LAST STATEMENT
+1,294,691
+*This portfolio indudes one or more unpriced securties that are not
+relected in the Total Value of Securities and the Net Equity This Period.
+Cash & Equivalent
+Equities
+Market Value of Your Portfolio
+$6,612,663
+$4.122,377
+$5,193,156
+$8.978.134
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The surren s four or ratanal furyce reard Set revere date for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+06/29/02;10:49001
+
+
+Bear, Stears & Co. Inc.
+New York, New York 10179
+Cash Flow Analysis
+THIS PERICO
+Opening Balance
+5137.663.44
+Securities Sold
+567,830.73
+Money Fund
+4,379.28
+Dividends/Interest
+13,493.27
+Miscellaneous
+1,779,767.43
+Amount Credited
+$2,365,470.71
+Money Fund
+-1,804,379.28
+Amount Debited
+5-1.804,379.28
+Net Cash Activity
+561,091.43
+.......
+Closing Balance
+........... 5698.754.87
+Same day transfers of cash between account types are not included in this
+section; such transfers, as wall as detals for all other transactions this period,
+appear in Transaction Detal.
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+131,409.18
+6,254.26
+$137,663.44
+Income Summary
+THIS PERIOD
+Dividends
+12,911.50
+Other Dividends
+4,379.28
+Credit Balance Int.
+581.77
+••••••••••••••••••••••••••••••••••••••••••••••••••••••••••
+Total
+$17,872.55
+Margin Int. Paid
+0.00
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+.....
+Total
+027
+CLOSING
+698,754.87
+0.00
+........
+$698,754.87
+YEAR TO DATE
+40,647.10
+4,379.28
+1,064.93
+*•////•••••••••••••
+$46.091.31
+-6,516.67
+8,978,134
+4,122,377
+513,100.511
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+Your Portfolio
+Allocation
+Equities
+31%
+Cash & Equivalent-
+69%
+Unshaded portions denole debit balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+... .. .
+DREYFUS TAX EXEMPT CASH
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+CENTER TR INC
+••••• •••!•••••••••••••••••
+CANHORN CHEMICAL CORP
+........
+CROWN AMERICAN REALTY TRUST
+ana i iga8aggggagg i gaganaaaagaaaaaa
+FELCOR LODGING TRUST INC
+.. . .
+GLENBOROUGH REALTY TRUST INC
+GLIMCHER REALTY TRUST-SB**
+. . .
+HRPT PROPERTIES TR-SBI
+. . . .
+HOSPITALITY PROPERTIES TRUST
+SBI
+JOHNSON& JOHNSON
+KRAMONT REALTY TRUST
+..........
+RAMCO GERSHENSON PROPERTIE:
+TRUST-MD SBI
+SIRIUS SATELLITE RADIO INC
+OFFICE SERVICING YOUR ACOOUNT
+Bear, Stears & Co. Inc.
+New York, New York 10179
+SYMBOLCUSIP
+QUANTITY
+8,279,379.28
+PRICE
+1.0000
+SYMBOUCUSIP
+СТА
+CNCPF
+CWN
+.. .
+FCH
+......
+GLB
+GRT
+HRP
+HPT
+JNJ
+KRT
+RPT
+SIRI
+Дост
+CASH
+ASH
+CASH
+...
+CASH
+......
+CASH
+''' AS
+CASH
+CASH
+CASH
+SASH
+CASH
+QUANTITY
+2,000
+19
+5,000
+..... .
+2,000
+....
+2,000
+*2,000
+.. . .
+10,000
+2,000
+57,800
+2,000
+••••••••••
+12,000
+1,000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocktyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIDO June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+MARKET
+VALUE
+698,755
+8,279,379
+$8,978,134
+PRICE
+7.0600
+••••••!!!
+Unpriced
+9.4000
+.....
+18.3500
+.....
+3.700
+18:5000
+.....
+850
+... .
+36.5000
+52.2600
+15.9900
+.. ••••••
+20.1500
+3.7690
+ANNUAL INCOME
+ES MATES CURAT
+124,191
+1.5000
+$124,191
+MARKET
+VALUE
+14,120
+47,000
+... ..
+36,700
+****•**••••••
+47,400
+37,000
+....
+88,500
+73,000
+3,020,628
+31.980
+241,800
+3,769
+027
+ESTIMATED
+ANNUAL INCOM
+480
+4,250
+1,200
+.. . .
+3,440
+....
+8,000
+5,680
+47,396
+2,600
+CURRENT
+YIELD (%)
+3.3994
+9.0426
+.. . .
+3.2698
+7.2574
+0.394
+9.0395
+7.7808
+.5691
+8.1301
+8.3375
+
+
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+TOO INC
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLOUSIP
+TOO
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stears & Co. Inc.
+New York, New York 10179
+ACCT
+CASH
+QUANTITY
+15,600
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT
+TRADE
+DATE
+06/17/02
+06/12/02
+TRANSACTION
+SOLD
+06/17/02 06/12/02 SOLD*
+0871770206/12/02 SOLD
+DESCRIPTION
+ALLIED WASTE INDUSTRIES ING
+UNSOLICITED
+"ALLIED WASTE INDUSTRIES INC
+NEW
+ACTUAL CONFIRM TO YOUR CENT
+FIVE STAR QUALITY CARE INC
+UNSOLICITED
+PRICE
+30.8000
+MARKET
+VALUE
+480,480
+$4,122,377
+$4,122,377
+$221,243
+$13,100,510
+ESTIMATED
+ANNUAL INCOME
+$97,052
+$97,052
+CURRENT
+YIELD (%)
+SYMBOL/CUSP
+AW
+AW*
+"EVE
+QUANTITY
+-2,500
+23,700
+-100
+PRICE
+11.42000
+• 71.51230
+6.52000
+220
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+28,399.14
+264,537.62
+599.48
+
+
+Bear. Stearns & Co. Inc.
+New York, New York 10179
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SETILEMENT TRADE
+DATE
+DATE
+06/18/02
+06/13/02
+TRANSACTION
+SOLD
+DESCRIPTION
+ALLIED WASTE INDUSTRIES ING
+NEW
+06/19/02 06/14/02 SOLD
+TOTAL
+UNSOLICITED
+ALLIED WASTE INDUSTRIES INC
+NEW
+AVG PRICE SHOWN-DETAILS ON REO
+UNSOL GENERM TO YOUR AGENT
+MONEY FUND ACTIVITY
+TRANSACTION
+06/01/02
+06/03/02 DIVIDEND
+08/03/02 REINVEST
+DESCAIPTION
+OPENINGBALANCE
+08/12/028808A7
+MONTHLY DIVIDEND
+"RANGER RESH CASHI"
+DIVIDEND REINVESTED
+"MANAGEMENT TENSE CASH
+CLOSINGBALANCE
+06/28/02
+TOTAL
+SYMBOLCUSP
+AW
+AW
+QUANTITY
+-13,200
+11,200
+PRICE
+11.50790
+
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+May 31, 2002
+151,105.20
+123,189.29
+$567,830.73
+SYMBOUCUSIP
+QUANTITY
+6,475,000
+4,379.28
+
+8.279,379.28
+PRICE
+1:0000
+4,379.28
+1.800,000.00
+$-1,804,379.28
+CAEDIT AMOUNT
+*4.379.28
+$4,379.28
+027
+
+
+Transaction Detail (continued)
+DIVIDENDS
+0671/02
+DESCRIPTION
+JOHNSON& JOHNSON
+REC 05/21/02 PAY 06/11/02
+06/14/02 CROWN AMERICAN REALTY TRUST
+REC 06/03/02 PAY 06/14/02
+TOTAL
+INTEREST
+DATE
+06/21/02
+TOTAL
+DESCRIPTION
+INTEREST ON CREDIT BALANCE
+AT 1 1/4% 05/21 THRU 06/20
+MISCELLANEOUS
+DATE
+MO/DAY
+TRANSACTION
+06/06/02
+JOURNAL
+08/12702
+"JOURNAL
+06/12/02
+JOURNAL
+TOTAL
+Bear, Stears & Co. Inc.
+New York, New York 10179
+SYMBOUCUSIP
+JNJ
+CWN
+SYMBOUGUSIP
+DESCRIPTION
+COL REC LOA FROM 35301417
+JOURNAL FROM TYPE 2101"
+JOURNAL FROM TYPE 2T011
+STOP
+* End of Statement****
+QUANTITY
+RATE (S)
+57,800
+0.2050
+*5,000 0.212
+0.2125
+QUANTITY
+RATE (%)
+1.2500
+6,254.26
+$-6,254.26
+027
+1,779.767.43
+•.,254.26
+$1.786,021.69
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+11,849.00
+....
+1,062.50
+$12.911.50
+581.77
+$581.77
+
+
+Bear, Stearns & Co. Inc.
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .....................
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26, 2002
+3
+4
+6
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+5,193,156
+137,663
+6,475,000
+NET EQUITY THIS PERIOD
+S11,805,819
+•••••••••••••••••••
+NET EQUITY LAST STATEMENT
+5,888,067
+CHANGE SINCE LAST STATEMENT
+5,917,753
+*This portfolio indudes one or more unpriced securies that are not
+reflected in the Total Value of Securities and the Net Equity This Period.
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$101,774
+Cash & Equivalent
+Equities
+$6.612,663
+$5,193,156
+$5,786.293
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four or ratanal fur yes red de Set revere date for portant formation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Stears & Co. Inc.
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Money Fund
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERIOD
+$101,773.57
+.. . .
+631,511.40
+25,000.00
+4,162.16
+6,000,000.00
+56. 60.67356
+-90,000.00
+-6,500,000.00
+-34,783.69
+........
+-6,624,783.6
+35,889.87
+...
+5137.663144
+Income Summary
+Dividends
+Credit Balance Int.
+......
+Total
+Margin Int. Paid
+THIS PERIOD
+3,720.00
+442.16
+$4,162.16
+....
+0.00
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+95,519.31
+6,254.26
+$101,773.57
+CLOSING
+131,409.18
+6,254.26
+137,663.44
+.........
+027
+YEAR TO DATE
+27,735.60
+483.16
+.....
+$28,218.76
+.....
+-6,516.67
+6,612,663
+5,193,156
+511.805.819
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26, 2002
+Your Portfolio
+Allocation
+Equities
+43%
+Cash & Equivalent
+57%
+Unshaded portions denole debi balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+... . .
+DREYFUS TAX EXEMPT CASH
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+ALLIED WASTE INDUSTRIES INC
+NEW
+...
+CENTER TR INC
+... ...
+CANHORN CHEMICAL CORP
+.. . . .
+CROWN AMERICAN REALTY TRUST
+.........
+ELCOR LODGING TRUST IN
+FIVE STAR QUALITY CARE INC
+ENBOROUGH REALTY TRUST IN
+GLIMCHER REALTY TRUST-SB
+HRPT PROPERTIES TR-SBI
+.......
+HOSPITALITY PROPERTIES TRUST
+SBI
+JOHNSON& JOHNSON
+KRAMONT REALTY TRUST
+OFFICE SERVICING YOUR ACOOUNT
+Bear, Stears & Co. Inc.
+New York, New York 10179
+SYMBOLCUSIP
+QUANTITY
+6,475,000
+1.0000
+SYMBCUCUSIP
+AW
+CTA
+CNCPF
+......
+CWN
+........
+FCH
+FVE
+GLB
+GRT
+HRP
+HPT
+JNU
+KRT
+CASH
+CASH
+.......
+CASH
+...
+CASH
+CASH
+CASH
+•••••••
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+50,000
+...
+2,000
+19
+5,000
+2,000
+.........
+100
+2,000
+.....
+2,000
+10,000
+2,000
+57,800
+2,000
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26,2002
+MARKET
+VALUE
+137,663
+6,475,000
+$6,612,663
+STIMATE
+ANUAL INCON
+90,650
+**•*•••••••••-•
+1.4000
+$90,650
+PRICE
+11.2000
+6.7900
+....
+Unpriced
+... ..
+9.0100
+1.75
+7.0600
+22.5000
+19.8000
+8.8200
+35.3300
+61.3500
+14.8500
+MARKET
+VALUE
+560,000
+13,580
+45,050
+37,500
+....
+706
+45,000
+39,600
+88.200
+70,660
+3,546,030
+29,700
+027
+ESTIMATE
+NNUAL INCON
+480
+...
+4,250
+.. ...
+1,200
+......
+3440*
+3,846
+8000
+47,396
+2,600
+CUARENT
+YELD (%)
+3.5346
+9.4340
+.....
+3.2000
+.....
+7.6444
+9.7121
+9.0703
+8.0385
+1.3366
+8.7542
+
+
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+...
+SIRIUS SATELLITE RADIO INC
+.. ...
+TOO INC
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLICUSIP
+RPT
+SIRI
+TOO
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stears & Co. Inc.
+New York, New York 10179
+CASH
+CASH
+CASH
+QUANTITY
+12,000
+1,000
+15,600
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TREE
+DATE
+05/07/02 05/02/02
+TRANSACTION
+SOLD
+05/21/02 05/15/02 BOUGHT"
+DESCRIPTION
+TOO INC
+UNSOLICITED
+AEROPOSTALE
+UNSOLICITED
+PROSPECTUS UNDER SEPARATE MAIL
+AS OF 05/15/02
+PRICE
+19.6500
+3.9700
+30.6000
+MARKET
+VALLE
+235,800
+3,970
+477,360
+$5,193,156
+$5,193,156
+$187,702
+$11,805,819
+ESTIMATED
+CURRENT
+ANNUAL INCOME
+YELD (S)
+20,160
+8.5496
+....
+.............
+$97,052
+$97,052
+SYMBOLCUSP
+TOO
+ARO
+QUANTITY
+-16,300
+000's.
+PRICE
+31.00380
+18.00000"
+027
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26,2002
+90,000.00
+504,366.22
+
+
+Bear, Stears & Co. Inc.
+New York, New York 10179
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+DETLEMENT TATE
+DATE
+TRANSACTION
+05/21/02 05/16/02
+SOLD
+DESCRIPTION
+AEROPOSTALE
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MODAY
+04/27/02
+TRANSACTION
+05/15/02
+'BOUGHT
+05/1702
+SOLD
+DESCRIPTION
+OPENINGBALANCE
+RAGE ISE CASH"
+PRESEN RENE CASH"
+05/31/02
+TOTAL
+CLOSINGBALANCE
+DIVIDENDS
+DESCRIPTION
+04130102 REC 011202 PAY DUST G
+05/23/02 HOSPITALIY PROPERTES TRUST
+REC 01/24/02 PAY 05/23/02
+SYMBOLGUSP
+ARO
+QUANTITY
+-5,000
+PRICE
+25.59750
+CLEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26,2002
+127,145.18
+$-90,000.00
+$631,511.40
+SYMBOUGUSIP
+QUANTITY
+0.00
+6.500,000
+*25,000
+6,475,000
+PRICE
+1.0000
+1.0000
+QUANTITY
+RATE (5)
+2,000
+0.1500
+2,000**
+0.7100
+027
+6.500,000.00"
+$-6,500,000.00
+300.00
+1.420.00
+25,000.00
+$25,000.00
+
+
+Transaction Detail (continued)
+DIVIDENDS (continued)
+DATE
+DESCRIPTION
+05/24/02
+HAPT PROPERTIES TR-SBI
+REC 04/22/02 PAY 05/24/02
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+05/21/02 INTEREST ON CREDIT BALANCE
+AT 1 1/4% 04/21 THRU 05/20
+TOTAL
+MISCELLANEOUS
+DATE
+MO/DAY
+05/07/02
+05/1402
+TOTAL
+TRANSACTION
+JOURNAL
+DURNA
+DESCRIPTION
+FROM
+PER LOA
+STOP
+****** End of Statement******
+Bear, Stears & Co. Inc.
+New York, New York 10179
+SYMBOUCUSIP
+HRP
+SYMBOL/CUSIP
+QUANTITY
+10,000
+RATE (S)
+0.2000
+QUANTITY
+RATE (SI
+1.2500
+34,783.69
+$-34,783.69
+027
+6,000,000.00
+$6,000,000.00
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26,2002
+2,000.00
+$3,720.00
+442.16
+$442.16
+
+
+Bear, Stearns & Co. Inc.
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summar...........................
+Your Portfolio Holdings
+Transaction Detail
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2002
+4
+5
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+5,786.293
+NET CREDIT BALANCE
+101,774
+NET EQUITY THIS PERIOD
+65,888,067
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+4,953,140
+934,927
+"This portfolio indudes one or more unpriced securtles that are not
+refected in the Total Value of Securtes and the Net Equity This Period.
+Market Value of Your Portfolio
+$101.274
+$-978,513
+Cash & Equivalent
+Equities -
+$5,786,293
+$5,931,653
+Current market value
+Last statement's market value
+Short market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four or ratanal purposes red die Set revere date for portant iformation.
+04/27/02;12:01 001
+
+
+2 of 8
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+04/27/02;12:01001
+
+
+3 ora
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Dividends/Interest Charged
+Miscellaneous
+THIS PERIOD
+978,512.9
+.......
+7,672.60
+1,100,000.00
+$1,107,672.60
+.........
+-1,298.34
+-26,087.76
+mount Debite
+Net Cash Activity
+Closing Balance
+.....27.386.10
+1,080,286.50
+5101,77357
+ne day transfers of cash between account types are not included in t
+tion: such transfers, as well as details for all other transactione this peri
+appear in Transaction Detail.
+Bear, Stears & Co. Inc.
+New York, New York 10179
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+0.00
+-978,512.93
+$-978,512.93
+Income Summary
+Dividends
+Credit Balance Int.
+Total.
+Margin Int. Paid
+THIS PERIOD
+7,631.60
+41.00
+$7,672.60
+-1,298.34
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+CLOSING
+95,519.31
+6,254.26
+...
+$101,773.57
+YEAR TO DATE
+24,015.60
+41.00
+4,056.
+...
+-6,516.67
+101,774
+5,786,293
+$5.888.067
+04/27102;12:01 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+1%
+- Equities
+99%
+Unshaded portions denote debit balance and'or short
+from the absolute market value of your portlolio.
+
+
+Bear, Stears & Co. Inc.
+New York, New York 10179
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+ALLIED WASTE INDUSTRIES INC
+NEW
+CENTER TR INC
+....
+CANHORN CHEMICAL CORP
+CROWN AMERICAN REALTY TRUST
+FELCOR LODGING TRUST INC
+FIVE STAR QUALITY CARE INC
+GLENBOROUGH REALTY TRUST INC
+GLIMCHER REALTY TRUST-SBI
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+SBI
+.. . .
+JOHNSON& JOHNSON
+...........
+KRAMONT REALTY TRUST
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+........
+SIRIUS SATELLITE RADIO ING
+SYMBCLCUSIP
+QUANTITY
+PRICE
+SYMBOLCUSIP
+AW
+CTA
+CNCPF
+CWN
+FCH
+FVE
+GLB
+GRT
+HRP
+HPT
+JNJ
+aaaaaa
+KRT
+RPT
+SIRI
+ACCT
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+...
+CASH
+CASH
+QUANTITY
+50,000
+2,000
+19
+5,000
+2,000
+100
+2,000
+2,000
+10,000
+......
+2,000
+57,800
+........
+2,000
+...
+12,000
+1,000
+MARKET
+VALUE
+101.774
+$101,774
+PRICE
+11.7900
+5.6000
+Unpriced
+9.4700
+21.0000
+7.3500
+21.8000
+19.0700
+8.5900
+33.9300
+63.6100
+...
+13.8600
+...
+18.0200
+4.7200
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28, 2002
+ESTIMATED
+NUAL INCON
+CURREN
+ELD E
+MARKET
+VALUE
+589,500
+11,200
+47,350
+42,000
+735
+43,600
+38,140
+85,900
+67,860
+3.676,658
+....
+27,720
+....
+216,240
+4,720
+027
+ESTIMATED
+ANNUAL INCOME
+480
+4,250
+1,200
+3,440
+3,846
+8,000
+47,396
+2,600
+... .
+20,160
+CURRENT
+YIELD IN
+4.2857
+8.9757
+2.8571
+7.8899
+10.0839
+....
+9.3132
+8.3702
+1.2891
+.....
+9.3795
+... ..
+9.3230
+04/27102;12:01 001
+
+
+5 org
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+TOO INC
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLOUSIP
+TOO
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stears & Co. Inc.
+New York, New York 10179
+ACCT
+CASH
+QUANTITY
+31,900
+Transaction Detail
+INVESTMENT ACTIVITY
+SETEEMENT DATE
+TRANSACTION
+JOURNAL
+84/10/02
+
+"JOURNAL
+JOUANAL"
+JOURNAL
+"JÖÜRNAL"
+DESCRIPTION
+ALLIED WASTE INDUSTRIES ING
+NEW
+JOURNAL FROM TYPE 2 TO 1
+CROWN AMERICAN REALTY TRUST
+JOURNAL FROM TYPE 2 TO 1
+"FELCOR LODGING TAUSTINE"
+JOURNAL FROM TYPE 2 TO 1
+"FIVE STAR QUALITY CARE INC
+JOURNAL FROM TYPE 2 TO 1
+PRICE
+29.3000
+MARKET
+VALUE
+934,670
+$5,786,293
+$5,786,293
+$97,052
+$5,888,066
+ESTIMATED
+ANNUAL INCOME
+$97,052
+$97,052
+CURRENT
+YIELD (%)
+SYMBOLCUSP
+AW
+FCH
+"FVE
+"GLE
+QUANTITY
+50,000
+5,000
+2,000
+100
+2,000
+PRICE
+027
+04/27/02;12:01 001
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2002
+
+
+6 of a
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SEEMENT TR
+RANSACTION
+JOURNAL
+JÖURNAL
+JÖURNAL'
+
+"JOUANAL"
+JOURNAL
+JOURNAL
+"JOURNAL'
+JOURNAL
+04/10/02'
+04/10/02.
+••••••••
+JOURNAL'
+"JOURNAL
+JOURNAL
+JOURNAL
+JÖURNAL
+"JOURNAL"
+Bear, Stears & Co. Inc.
+New York, New York 10179
+DESCRIPTION
+GLIMCHER REALTY TRUST-SBI
+JOURNAL FROM TYPE 2 TO 1
+HAPT PROPERTIES TA-SBI**
+JOURNAL FROM TYPE 2 TO 1
+HOSPITALITY PROPERTIES TRUST
+JOURNAL FROM TYPE 2 TO 1
+"OHNSONS JOHNSON"
+JOURNAL FROM TYPE 2 TO 1
+KRAMONT REALTY TRUST
+JOURNAL FROM TYPE 2 TO 1
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+JOURNAL FROM TYPE 2 TO 1
+"SIRIUS SATELLITE RADIO INC"
+JOURNAL FROM TYPE 2 TO 1
+ALLIED WASTE INDUSTRIES INC
+JOURNAL FROM TYPE 2 TO 1
+CROWN AMERICAN REALTY TRUST
+JOURNAL FROM TYPE 2 TO 1
+ELCOR LODGING TRUST INC
+OURNAL FROM TYPE 2 TO
+VE STAR QUALITY CARE IN
+URNAL FROM TYPE 2 TO
+GLENBOROUGH REALTY TRUST INC
+JOURNAL FROM TYPE 2 TO 1
+LIMCHER REALTY TRUST-S
+URNAL FROM TYPE 2 TO
+SYMBOLGUSP
+GRT
+'HAP"
+HPT
+APT
+CWN
+"FVE
+"GLE
+GAT
+"HAP
+027
+QUANTITY
+2,000
+10,000
+2,000
+57,800
+2,000
+12,000
+1,000
+50,000
+5,000
+2,000
+100
+2,000
+2,000
+10,000
+PRICE
+04/27102;12:01 001
+CLEARED THROUGH ITS
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28, 2002
+
+
+Bear, Stears & Co. Inc.
+New York, New York 10179
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SETTLEMENT TRADE
+TRANSACTION
+JOURNAL
+64/10/02
+64/10/02
+"OUANAL"
+JOURNAL
+JOUANAL"
+TOTAL
+JOURNAL
+DIVIDENDS
+DATE
+04/15/02
+DESCRIPTION
+GLENBOROUGH REALTY TRUST INC
+REC 04/01/02 PAY 04/15/02
+84/75/02 LINCHER REALTY TAUST SET
+REC 03/29/02 PAY 04/15/02
+04/16/02
+"RANCO GERSHENSON PROPERTIES
+RUST-MD SB
+IEC 03/31/02 PAY 04/16/0:
+04/22/02
+''''"CENTER TRINC****''*******
+REC 03/2902 PAY 04/22/02
+04/22/02
+KRAMONT REALTY TRUST
+REC 03/29/02 PAY 04/20/02
+TOTAL
+DESCRIPTION
+HOSPITALITY PROPERTIES TRUST
+JOURNAL FROM TYPE 2 TO 1
+JOHNSON& JOHNSON'
+JOURNAL FROM TYPE 2 TO 1
+KRAMONT REALTY TAUST"
+JOURNAL FROM TYPE 2 TO 1
+RAMCO GERSHENSON PROPERTIES'
+TRUST-MD SBI
+JOURNAL FROM TYPE 2 TO 1
+"SIRIUS SATELLITE RADIO INC
+JOURNAL FROM TYPE 2 TO 1
+SYMBOUCUSIP
+GLB
+"CTA"
+KRT
+SYMBOLGUSP
+HPT
+KAT
+"APT
+STAI
+QUANTITY
+RATE ($)
+2,000
+0.4300
+*2,0000****••0:4808
+12,000
+*0.4200
+2,000
+2,000
+*0.0600
+0.3250
+027
+QUANTITY
+-2,000
+*57,800
+2,000
+:12,000
+1,000
+PRICE
+04/27102;12:01 001
+CLEARED THROUGH ITS
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+March 28,2002
+B60.00
+100961:60
+5,040.00
+120.00
+650.00
+$7,631.60
+
+
+8 ora
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+04/22/02
+FROM 03/21 THRU 04/20 @21/2%
+BAL 6,861-AVBAL 719,080
+02202 NES. ONCE PA SANCE"
+Bear, Stears & Co. Inc.
+New York, New York 10179
+SYMBOL/CUSIP
+QUANTITY
+RATE (%)
+2.5000
+1.2500
+MISCELLANEOUS
+DATE
+MO/DAY
+04/05/02
+84/09/02
+TOTAL
+TRANSACTION
+JOURNAL
+JOURNAL
+JOURNAL
+JOURNAL
+DESCRIPTION
+TO
+JOURNAL FROM TYPE 1702
+JOURNAL FROM TYPE 1 TO 2
+26,087.76
+,004,600.69
+$-1,030,688.45
+STOP
+****** End of Statement******
+027
+1,298.34
+$-1,298.34
+1, 100,000.00
+1.004,600.69
+$2.104,600.69
+04/27/02;12:01 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2002
+.....
+41.00
+$41.00
+
+
+Bear, Stearns & Co. Inc.
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+Your Messages
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+3
+4
+6
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+5,931,653
+NET DEBIT BALANCE
+-978.513
+NET EQUITY THIS PERIOD
+1.953.14
+NET EQUITY LAST STATEMENT
+4,494,480
+CHANGE SINCE LAST STATEMENT
+458.660
+"This portfolio indudes one or more unpriced securtles that are not
+refected in the Total Value of Secures and the Net Equity This Period.
+Market Value of Your Portfolio
+$-978,513
+$-958,140
+Cash & Equivalent
+Equities -
+$5,931,653
+$5,452,620
+Current market value
+Last statement's market value
+Short market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The surren s four or ratanal furyce rearde Set revere date for portant iformation.
+
+
+2 of 6
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Stears & Co. Inc.
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+5-958,140.16
+11,454.00
+$11,454.00
+-1,877.05
+-29,949.72
+$-31,826.77
+.. . .
+-20,372.77
+$978.512.93
+Income Summary
+Dividends
+Total
+Margin Int. Paid
+THIS PERIOD
+11,454.00
+$11.454.00
+-1,877.05
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+SHOAT
+978,513
+$978,513
+Cash Balance Summary
+Margin
+....
+Net Cash Balance
+OPENING
+CLOSING
+-958,140.16
+-978,512.93
+.......
+$-958,140.16
+$-978,512.93
+027
+YEAR TO DATE
+16,384.00
+•...••••
+$16.384.00
+-5,218.33
+LONG
+5,931,653
+$5.931.653
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+Your Portfolio
+Allocation
+Short Cash & Equivalent.
+Equities
+86%
+Unshaded portions denote debe balance andor short
+
+
+4 ofB
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITES
+Equities & Options
+DESCRIPTION
+ALLIED WASTE INDUSTRIES INC
+NEW
+CENTER TR INC
+•.....
+CANHORN CHEMICAL CORP
+CROWN AMERICAN REALTY TRUST
+FELCOR LODING TRUST INC
+....
+FIVE STAR QUALITY CARE INC
+GLENBOROUGH REALTY TRUST ING
+GLIMCHER REALTY TRUST-SB|
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+SBI
+JOHNSON& JOHNSON
+..............
+KRAMONT REALTY TRUST
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+.............
+SIRIUS SATELLITE RADIO INC
+Bear, Stears & Co. Inc.
+New York, New York 10179
+SYMBCLCUSIP
+QUANTITY
+PRICE
+SYMBOLCUSIP
+AW
+CTA
+CNCPF
+CWN
+FCH
+FVE
+GLB
+GRT
+HRP
+HPT
+JNJ
+aanaaa
+KRT
+RPT
+SIRI
+MRGN
+CASH
+CASH
+MRGN
+MRGN
+MRGN
+MAGN
+MAGN"
+MRGN
+MAGN"
+MRGN"
+.........
+MRGN
+.. . .
+MRGN
+MRGN
+QUANTITY
+50,000
+2,000
+19
+5,000
+2,000
+100
+2,000
+2,000
+10,000
+...-....
+2,000
+57,800
+.. . .
+2,000
+.. . .
+12,000
+1,000
+MARKET
+VALUE
+-978,513
+$-978,513
+PRICE
+13.0000
+5.2900
+Unpriced
+9.7400
+21.2500
+7.3200
+21.5000
+18.5500
+9.0000
+34.3300
+64.9500
+.....
+13.5500
+.. .
+17.7600
+5.3200
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+MINE MACED
+CURRE
+ELD I
+MARKET
+VALLE
+650,000
+10,580
+48,700
+42,500
+732
+43.000
+37,100
+90,000
+68,660
+3,754,110
+*...--.-........
+27,100
+... .
+213,120
+5,320
+ESTIMATED
+ANNUAL INCOME
+480
+4.200*
+400
+3,440
+3,846
+8,000
+5,680
+1,61
+2,600
+.. .
+20,160
+CURRENT
+YELD IN
+4.5369
+8.6242
+0.9412
+8.0000
+10.3666
+8.8889
+8.272€
+1.1085
+9.5941
+.......
+9.4595
+027
+
+
+5 or 8
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+TOO INC
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLOUSIP
+TOO
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stears & Co. Inc.
+New York, New York 10179
+ACCT
+CASH
+QUANTITY
+31,900
+Transaction Detail
+DIVIDENDS
+DATE
+DESCRIPTION
+03/12/02
+JOHNSON& JOHNSON
+REC 02/19/02 PAY 03/12/02
+03/15/02
+CROWN AMERICAN REALTY TRUST
+REC 03/04/02 PAY 03/15/02
+TOTAL
+SYMBOL/CUSIP
+JNJ
+PRICE
+29.4900
+MARKET
+VALUE
+940,731
+$5,931,653
+$5,931,653
+$90,422
+$4,953,140
+QUANTITY
+57,800
+5,000
+RATE (S)
+0.1800
+0.2100
+027
+CLEARED THRESH SONARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+ESTIMATED
+ANNUAL INCOME
+$90,422
+$90,422
+CURRENT
+YIELD (%)
+10,404.00
+1,050.00
+$11,454.00
+
+
+6 of 8
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+03/21/02
+FROM 0/ 0THRU 0/0@21/2%
+BAL 976,635 AVBAL 965,338
+TOTAL
+MISCELLANEOUS
+MADDAY
+03/11/02
+TOTAL
+TRANSACTION
+JOURNAL
+DESCRIPTION
+TO
+Bear, Stears & Co. Inc.
+New York, New York 10179
+SYMBOL/CUSIP
+QUANTITY
+RATE (SI
+2.5000
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+1,877.05
+$-1,877.05
+29,949.72
+$-29,949.72
+Your messages
+11 Pursuant to SEC Rule 11Ac1-6, Bear, Steams & Co. Inc will
+Bear, Stearns Securities Corp. Net Capital and Net Capital
+Requirements:
+At November 30, 2001 and January 31, 2002, the Company's net
+capital of approximately $2,6 billion and $2,6 billion was
+approximately 9% and 8% of aggregate debit items and exceeded
+the minimum regulatory net capital requirement of approximately
+$604.1 million and $648,0 million by approximately $2,0 billion and
+$2,0 billion, all respectively.
+ww.bearstearns.com. Alternatively, to request a free printed cop
+lease call -toll free 1-866-299-9331
+027
+
+
+Bear, Stearns & Co. Inc.
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary •••••••••••//•I/IIIIIIIII HI
+Your Portfolio Holdings
+Transaction Detail
+.....
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 25,2002
+4
+5
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+5,452,620
+NET DEBIT BALANCE
+-958,140
+NET EQUITY THIS PERIOD
+$4,494,480
+NET EQUITY LAST STATEMENT
+4,370,641
+CHANGE SINCE LAST STATEMENT
+123.839
+"This portfolio indudes one or more unpriced securtles that are not
+relected in the Total Value of Securites and the Net Equity This Period
+Market Value of Your Portfolio
+$-958,140
+S-924,169
+Cash & Equivalent
+Equities -
+$5,452,620
+$5,294,810
+Current market value
+Last statement's market value
+Short market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal furyce rearde Set revere date for portant iformation.
+
+
+2 of 6
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Stears & Co. Inc.
+New York, New York 10179
+Cash Flow Analysis
+THIS PERICO
+Opening Balance
+$-924.169.49
+Dividends/Interest
+3,520.00
+Amount Credited
+$3,520.00
+Dividends/Interest Charged
+-2,013.78
+Miscellaneous
+-35,476.89
+Amount Debited.
+-37,490.6
+.........
+Net Cash Activity
+-33,970.67
+Closing Balance
+$-958.140-16
+Same or rana do a tea at an at one are a irated a paid.,
+appoar in Transaction Detal.
+Cash Balance Summary
+Cash
+Margin
+OPENING
+80.00
+-924,249.49
+Net Cash Balance
+$-924,169.49
+CLOSING
+0.00
+-958,140.16
+$-958,140.16
+188.....
+Income Summary
+Dividends
+Total
+Margin Int. Paid
+THIS PERIOD
+3,420.00
+$3.420.00
+-2,013.78
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+SHORT
+958,140
+$958,140
+027
+YEAR TO DATE
+4,930.00
+*....•••...•
+34.930.00
+-3,341.28
+LONG
+5,452,620
+$5.452.620
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 25, 2002
+Your Portfolio
+Allocation
+Shot Cash & Equivalent.
+Equities
+86%
+Unshaded portions denote debe balance andor short
+market values.
+The allocation percentage is derived
+
+
+4 ofB
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITES
+Equities & Options
+DESCRIPTION
+ALLIED WASTE INDUSTRIES INC
+NEW
+CENTER TR INC
+....
+CANHORN CHEMICAL CORP
+CROWN AMERICAN REALTY TRUST
+FELCOR LODING TRUST INC
+....
+FIVE STAR QUALITY CARE INC
+GLENBOROUGH REALTY TRUST ING
+GLIMCHER REALTY TRUST-SB|
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+SBI
+JOHNSON& JOHNSON
+..............
+KRAMONT REALTY TRUST
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+.............
+SIRIUS SATELLITE RADIO INC
+Bear, Stears & Co. Inc.
+New York, New York 10179
+SYMBCLCUSIP
+QUANTITY
+PRICE
+SYMBOLCUSIP
+AW
+CTA
+CNCPF
+CWN
+FCH
+FVE
+GLB
+GRT
+HRP
+HPT
+JNJ
+aanaaa
+KRT
+RPT
+SIRI
+MRGN
+CASH
+CASH
+MRGN
+MRGN
+MRGN
+MAGN
+MAGN"
+MRGN
+MAGN"
+MRGN"
+.........
+MRGN
+.. . .
+MRGN
+MRGN
+QUANTITY
+50,000
+2,000
+19
+5,000
+2,000
+100
+2,000
+2,000
+10,000
+.........
+2,000
+57,800
+... .
+2,000
+. . . .
+12,000
+1,000
+MARKET
+VALUE
+-958,140
+$-958,140
+PRICE
+11.3300
+4.0800
+Unpriced
+8.9500
+19.0900
+8.4000
+20.6300
+17.8000
+8.7400
+31.4800
+59.4000
+......
+13.5000
+.. .
+17.6900
+4.3600
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocktyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 25, 2002
+NAWAL NATNE
+CURRE
+ELD I
+MARKET
+VALLE
+566,500
+8,160
+44,750
+38,180
+840
+41,260
+35,600
+87,400
+62,960
+3,433,320
+27,000
+****•*••
+280
+4,360
+ESTIMATEC
+ANNUAL INCOM
+320
+4,200
+400
+3,440
+3,846
+8,000
+5,680
+1,61
+2,600
+.. .
+20,160
+CURRENT
+YIELD (%)
+3.9216
+9.3855
+1.0477
+8.3374
+10.8034
+9.1533
+9.021€
+1.212
+9.6296
+.....
+9.4969
+027
+
+
+5 or 8
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+TOO INC
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLOUSIP
+TOO
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stears & Co. Inc.
+New York, New York 10179
+ACCT
+CASH
+QUANTITY
+31,900
+Transaction Detail
+DIVIDENDS
+DATE
+01/31/02
+DESCRIPTION
+FELCOR LODGING TRUST INC
+CASH DIV ON
+2000 SHS
+EC 12/31/01 PAY 01/31/02
+MOUNT INCLUDED ON 2001-109
+ö2/19/02
+"HOSPITALITY PROPERTIES TAUST"
+REC 01/18/02 PAY 02/19/02
+02222/02
+TOTAL
+APT PROPERTIES TR-SE
+REC 01/18/02 PAY 02/22/02
+SYMBOUCUSIP
+FCH
+•HPT
+"HAP
+PRICE
+27.9000
+MARKE
+FALLE
+890,010
+$5,452,620
+$5,452,620
+$90,262
+$4,494,479
+QUANTITY
+000z
+10,000
+RATE (S)
+0.7100
+0.2000
+027
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 25,2002
+ESTIMATED
+ANNUAL INCOME
+$90,262
+$90,262
+CURRENT
+YIELD (%)
+100.00
+1,420.00
+,000.0
+$3,520.00
+
+
+6 of 8
+Bear, Stears & Co. Inc.
+New York, New York 10179
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+02/21/02
+FROM 01/21 THRU 02/20 @21/2%
+BAL 958,126 AVAL 935,435
+TOTAL
+MISCELLANEOUS
+DATE
+MODAY
+TRANSACTION
+02/11/02
+JOURNAL
+02/12/02
+IÖURNAL"
+02/12/02
+JOURNAL
+TOTAL
+DESCRIPTION
+TOL
+JOURNAL FROM TYPE 2 TO 1
+JOURNAL FROM TYPE 2 TO 1
+SYMBOL/CUSIP
+STOP
+****** End of Statement******
+QUANTITY
+RATE (%)
+2.5000
+35,476.89
+35,396.89
+$-70,873.78
+027
+CLEARED THRESH SONARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 25, 2002
+2,013.78
+$-2,013.78
+35,396.89
+$35,396.89
+
+
+Bear, Stears & Co. Inc.
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+.....
+Transaction Detail
+Your Messages
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+4
+5
+7
+JEFFREY EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH FL 33480-4730
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+NET DEBIT BALANCE
+5,294,810
+-924,169
+NET EQUITY THIS PERIOD
+$4,370,641
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+3,759,682
+610.959
+"This portfolio indudes one or more unpriced securtles that are not
+refected in the Total Value of Securtes and the Net Equity This Period.
+Market Value of Your Portfolio
+$-924,169
+S-895,708
+Cash & Equivalent
+Equities -
+$5,294,810
+$4,655,390
+Current market value
+Last statement's market value
+Short market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal furyce red de Set revere date for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Stears & Co. Inc.
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited.
+Net Cash Activity
+Closing Balance,
+THIS PERICO
+$-895.708.49
+7,591.60
+....
+$7,591.60
+-1,327.50
+-34,725.10
+$-36,052.60
+........
+-28,461.00
+5.924.169.49
+Income Summary
+Dividends
+Total
+Margin Int. Paid
+THIS PERIOD
+1,510.00
+$1.510.00
+-1,327.50
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+SHORT
+924,169
+$924,169
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+0.00
+-895,708.49
+$-895,708.49
+CLOSING
+80.00
+-924,249.49
+.......
+$-924,169.49
+027
+YEAR TO DATE
+1,510.00
+...........
+.$1.510.00
+-1,327.50
+LONG
+5,294,810
+$5.294,810
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+Your Portfolio
+Allocation
+Short Cash & Equivalent.
+Equities
+86%
+Unshaded portions denote debe balance andor short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITES
+Equities & Options
+DESCRIPTION
+ALLIED WASTE INDUSTRIES INC
+NEW
+CENTER TR INC
+•.....
+CANHORN CHEMICAL CORP
+CROWN AMERICAN REALTY TRUST
+FELCOR LODING TRUST INC
+....
+FIVE STAR QUALITY CARE INC
+GLENBOROUGH REALTY TRUST ING
+GLIMCHER REALTY TRUST-SB|
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+SBI
+JOHNSON& JOHNSON
+..............
+KRAMONT REALTY TRUST
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+.............
+SIRIUS SATELLITE RADIO INC
+Bear, Stears & Co. Inc.
+New York, New York 10179
+SYMBCLCUSIP
+QUANTITY
+PRICE
+SYMBOLCUSIP
+AW
+CTA
+CNCPF
+CWN
+FCH
+FVE
+GLB
+GRT
+HRP
+HPT
+JNJ
+aanaaa
+KRT
+RPT
+SIRI
+MRGN
+CASH
+CASH
+MRGN
+MRGN
+MRGN
+MAGN
+MAGN"
+MRGN
+MAGN"
+MRGN"
+.........
+MRGN
+.. . .
+MRGN
+MRGN
+QUANTITY
+50,000
+2,000
+19
+5,000
+2,000
+100
+2,000
+2,000
+10,000
+2,000
+57,800
+.. . .
+2,000
+...
+12,000
+1,000
+MARKET
+VALUE
+-924,169
+$-924,169
+PRICE
+11.6000
+4.1600
+Unpriced
+8.0400
+17.3500
+8.0500
+20.1500
+17.5900
+8.7100
+29.2000
+57.6500
+.. . .
+12.9400
+......
+17.5500
+6.9700
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocktyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIO January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+NAWAL NOTE
+CURRE
+ELD I
+MARKET
+VALLE
+580,000
+8,320
+40,200
+34,700
+805
+40,300
+35,180
+87,100
+58,400
+3.332,170
+25,880
+....
+210,600
+6,970
+ESTIMATEL
+ANNUAL INCOM
+320
+4.200
+400
+3,440
+3,846
+8,000
+5,680
+1,616
+2,600
+.. .
+20,160
+CURRENT
+YIELD (%)
+3.8462
+10.4478
+1.1527
+8.5360
+10.9323
+9.1848
+........
+9.7260
+1.2489
+10.0464
+... ...
+9.5726
+027
+
+
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+DESCRIPTION
+TOO INC
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLOUSIP
+TOO
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stears & Co. Inc.
+New York, New York 10179
+ACCT
+CASH
+QUANTITY
+31,900
+Transaction Detail
+INVESTMENT ACTIVITY
+BETLEMENT TE
+DATE
+TRANSACTION
+01/07/02
+01/02/02
+BOUGHT
+01/25/02
+TOTAL
+"RECEIVED
+DESCRIPTION
+FIVE STAR QUALITY CARE INC
+SPINOFF
+ON 10000 SH
+HRPT PROPERTIES TR-SB
+SEC 1270 HAT 1231101
+TOO INC
+201!
+PRICE
+26.1500
+MARKET
+VALLE
+834,185
+$5,294,810
+$5,294,810
+$90,262
+$4,370,640
+ESTIMATED
+ANNUAL INCOME
+$90,262
+$90,262
+CURRENT
+YIELD (%)
+SYMBOL/CUSP
+FVE
+"TOO
+QUANTITY
+100
+*31,900
+PRICE
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+
+
+Transaction Detail (continued)
+DIVIDENDS
+DATE
+DESCRIPTION
+01/15/02
+GLENBOROUGH REALTY TRUST INC
+REC 01/01/02 PAY 01/15/02
+O17502'LIMCHER REALTY TRUST SBI"
+LAN UN NEUSE ON 301-000
+6171502"KAM0O GERSHENSON PROPERTES
+TRUST-MD SBI
+CASH DIV ON 12000 SHS
+REC 12/31/01 PAY 01/15/02
+AMOUNT INCLUDED ON 2001-1099
+01/22/02
+'''KRAMONT REALTY TAUST
+REC 01/04/02 PAY 01/19/02
+01/22/02
+CENTER TR INC
+CASH DIV ON
+2000 SHS
+REC 12/31/01 PAY 01/21/02
+AMOUNT INCLUDED ON 2001-1099
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+01/22/02
+FROM 12/31 THRU 01/20 @21/2%
+BAL 923,571 AVBAL 910,283
+TOTAL
+Bear, Stears & Co. Inc.
+New York, New York 10179
+SYMBOL/CUSIP
+GLB
+'''GRT
+QUANTITY
+2,000
+RATE (S)
+0.4300
+2,000 0.3250
+"CA"
+SYMBOUCUSIP
+QUANTITY
+RATE (%)
+2.5000
+027
+1,327.50
+$-1,327.50
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIO January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+860.00
+-961.60
+"5,040.00
+• 650.00
+80.00
+$7,591.60
+
+
+Bear, Stears & Co. Inc.
+New York, New York 10179
+Transaction Detail (continued)
+MISCELLANEOUS
+DATE
+MO/DAY
+01/11/02
+TRANSACTION
+JOURNAL
+TOTAL
+DESCRIPTION
+TO
+Your messages
+* Choi was fare can ted no your a cland throug one
+STOP
+****** End of Statement******
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+34,725.10
+$-34,725.10
+CRECIT AMOUNT
+027
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/d0f91e5cd6116a14731aea3129454b0868fefacb614c8763386a8ec3dc188596.receipt.json b/vision-fixhub/ds9-unparsed-05/d0f91e5cd6116a14731aea3129454b0868fefacb614c8763386a8ec3dc188596.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d58921deefa83f9afa7a0f9002573ca317e189fe
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d0f91e5cd6116a14731aea3129454b0868fefacb614c8763386a8ec3dc188596.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -9324,
+  "dataset": "marble-joined",
+  "doc_id": "d0f91e5cd6116a14731aea3129454b0868fefacb614c8763386a8ec3dc188596",
+  "engine": "marble-apple-vision",
+  "event_count": 92,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "481136e4ba7ca199bebf6a58a36e1111e125fd25578d3d56612dc6343ac86faf",
+  "output_sha256": "e40a5d1095ea575d05e425aaef5eea2222d5ba0bb3493abe59dd57ee2cf794b0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/d17767461c15a76b2fb7bcf455296f07738c0f58c5cce9ea7bd83c2069552ec8.md b/vision-fixhub/ds9-unparsed-05/d17767461c15a76b2fb7bcf455296f07738c0f58c5cce9ea7bd83c2069552ec8.md
new file mode 100644
index 0000000000000000000000000000000000000000..3eb39b287a38198044aa6ebd515f2f7a73f44086
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d17767461c15a76b2fb7bcf455296f07738c0f58c5cce9ea7bd83c2069552ec8.md
@@ -0,0 +1,54 @@
+OLY-26
+
+
+TO: Gerald Lefcourt
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-26
+SUBPOENA FOR:
+X PERSON
+X
+DOCUMENTS OR OBJECTIS
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+February 13, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+All retainer agreements, representation agreements, and all documents referring or relating to payments
+for representation and the scope of your representation of Jeffrey Epstein and/or any current or former
+employee or associate of Jeffrey Epstein.
+A list of all current or former employees or associates of Jeffrey Epstein whom you claim to represent and the
+identity of the person(s) paying for that representation.
+All joint defense agreements, whether formal or informal, and all documents referring or relating to joint defense
+agreements and/or the sharing of information related to the investigation of Jeffrey Epstein and/or any current
+or former employees or associates of Jeffrey Epstein.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+DATE:
+February 1, 2007
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the United States of America
+*If not applicable, enter "none."
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+Tel:
+Fax:
+To be used in lieu of AOTIO
+FORM ORD-227
+JAN.86
diff --git a/vision-fixhub/ds9-unparsed-05/d17767461c15a76b2fb7bcf455296f07738c0f58c5cce9ea7bd83c2069552ec8.receipt.json b/vision-fixhub/ds9-unparsed-05/d17767461c15a76b2fb7bcf455296f07738c0f58c5cce9ea7bd83c2069552ec8.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f340ebf7321692608a73b2184c8888ddb7bfd540
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d17767461c15a76b2fb7bcf455296f07738c0f58c5cce9ea7bd83c2069552ec8.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "d17767461c15a76b2fb7bcf455296f07738c0f58c5cce9ea7bd83c2069552ec8",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "4a57ecdccccd99aeddd9116d6c1cd12b436c53e551f64994b20226638f53f5cc",
+  "output_sha256": "86ec131a1251da6e97da1706f3d274985cf64bfb8bb76a0c5e23f4bff30f5612",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/d26e397452d08d1c25945f4e479de967272639cdd72c6c31e22297070509ab55.md b/vision-fixhub/ds9-unparsed-05/d26e397452d08d1c25945f4e479de967272639cdd72c6c31e22297070509ab55.md
new file mode 100644
index 0000000000000000000000000000000000000000..520b1db36b099136c7ea8a2c7e78f468b6e72a8c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d26e397452d08d1c25945f4e479de967272639cdd72c6c31e22297070509ab55.md
@@ -0,0 +1,4667 @@
+CM/ECF - Live Database • 1
+
+LRJ
+U.S. District Court
+Southern District of Florida (West Palm Beach)
+CIVIL DOCKET FOR CASE #: 9:08-cv-80736-KÅM
+Doe I. United States of America
+Assigned to: Judge Kenneth A. Marra
+Cause: no cause specified
+Date Filed: 07/07/2008
+ury Demand: Non
+lature of Suit: 440 Civil Rights: Othe
+Jurisdiction: U.S. Government Defendant
+Date Filed
+07/07/2008
+07/07/2008
+07/07/2008
+07/09/2008
+07/09/2008
+07/09/2008
+07/09/2008
+07/09/2008
+07/09/2008
+07/09/2008
+07/10/2008
+07/11/2008
+#
+Docket Text
+1 | EMERGENCY PETITION for Victim's Enforcement of Crime Victim's Rights Act 18 USC
+3771 against United States of America Filing fee $ 350. Receipt#: 724403, filed by Jane Doe.
+(rb) (Entered: 07/07/2008)
+2
+3
+CERTIFICATE OF EMERGENCY by Jane Doe re 1 Complaint (rb) (Entered: 07/07/2008)
+ORDER requiring U.S. Attorney to respond to 1 Complaint filed by Jane Doe by 5:00 p.m. on
+719/08. Signed by Judge Kenneth A. Marra on 7/7/08. (ir) (Entered: 07/07/2008)
+4
+NOTICE of Attorney Appearance by Dexter Lee on behalf of United States of America (Lee,
+Dexter) (Entered: 07/09/2008)
+6
+Sealed Document. (rb) UNSEALED see DE 12 . Modified on 7/15/2008 (bs). (Entered:
+07/10/2008)
+7
+Sealed Document. (rb) UNSEALED see DE 13 . Modified on 7/15/2008 (bs). (Entered:
+07/10/2008)
+8
+Sealed Document. (rb) UNSEALED see DE 14 . Modified on 7/15/2008 (bs). (Entered:
+07/10/2008)
+12
+UNSEALED MOTION to Seal Response to Victim's Emergency Petition by United States of
+America. (previously filed as 6 sealed document) (bs) (Entered: 07/15/2008)
+13
+| UNSEALED RESPONSE to 1 Emergency Petition for Enforcement of Crime Victim Rights
+Act filed by United States of America. (previously filed as 7 sealed document) (bs) (Entered:
+07/15/2008)
+14 | UNSEALED DECLARATION signed by : A. Marie Villafana. re 13 Response to Victim's
+Emergency Petition by United States of America. (previously filed as 8 sealed document) (bs)
+(Entered: 07/15/2008)
+ORDER SETTING HEARING: Petitioner's Emergency Petition for Enforcement of Crime
+Victim's Rights Act set for 7/11/2008 10:15 AM in West Palm Beach Division before Judge
+Kenneth A. Marra. Signed by Judge Kenneth A. Marra on 7/10/08. (ir) (Entered: 07/10/2008)
+REPLY to Response (under seal) re 1 Complaint/Emergency Petition, and Objection to
+Government's Motion for Sealing of Pleadings filed by Jane Doe. (Is) (Entered: 07/11/2008)
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?657771929017239-L_801_0-1
+10/17/200
+
+
+CM/ECF - Live Database
+4
+
+/07/11/2008
+10 Minute Entry for proceedings held before Judge Kenneth A. Marra: Miscellaneous Hearing held
+on 7/11/2008. Court will issue order to unseal pleadings. Court Reporter: Official Reporting
+Service- phone number 305-523-5635 (ir) (Entered: 07/11/2008)
+07/11/2008
+11
+ORDER Denying Motion to Seal re 7 Sealed Document, 6 Sealed Document, & Sealed
+addument. Signed by Judge Kenneth A. Marra on 7/11/2008. (ls) (Additional attachments)
+on 7/15/2008: # 1 docket sheet) (bs). (Entered: 07/14/2008)
+07/17/2008
+15
+TRANSCRIPT of Hearing held on 7/11/2008 before Judge Kenneth A. Marra. Court Reporter:
+Victoria Aiello- phone number 954-467-8204 32 pages. (abd) (Entered: 07/18/2008)
+07/28/2008
+16
+MOTION for Limited Appearance, Consent to Designation and Request to Electronically
+Receive Notices of Electronic Filing for Paul G. Cassell, Filing Fee $75, Receipt #724532. (cw)
+(Entered: 07/28/2008)
+07/29/2008
+17
+NOTICE by United States of America To Court Regarding Absence of Need for Evidentiary
+Hearing (Lee, Dexter) (Entered: 07/29/2008)
+07/30/2008
+18
+ENDORSED ORDER granting Paul G. Cassell 16 Motion for Limited Appearance, Consent to
+Designation and Request to Electronically Receive Notices of Electronic Filings. Signed by
+Judge Kenneth A. Marra on 7/29/08. (ir) (Entered: 07/30/2008)
+08/01/2008
+19
+RESPONSE/REPLY to Goverment's Notice to Court Regarding Absence of Need for
+Evidentiary Hearing and Motion for Production of Non-Prosecution Agreement and of Report
+of Interview filed by Jane Doe. (Attachments: # 1 Exhibit Proposed Stipulation, # 2 Exhibit July
+17, 2008 Letter, # 3 Exhibit July 3, 2008 Letter)(Edwards, Bradley) (Entered: 08/01/2008)
+08/08/2008
+20
+MOTION for Limited Appearance, Consent to Designation and Request to Electronically
+Receive Notices of Electronic Filing for Jay C. Howell, Filing Fee $75, Receipt #724591. (cw)
+(Entered: 08/12/2008)
+08/13/2008
+21
+ENDORSED ORDER granting Jay C. Howell 20 Motion for Limited Appearance, Consent to
+Designation and Request to Electronically Receive Notices of Electronic Filings. Signed by
+Judge Kenneth A. Marra on 8/12/08. (ir) (Entered: 08/13/2008)
+08/13/2008
+22
+NOTICE by United States of America re 19 Response/Reply (Other), Response/Reply (Other)
+Government's Response to Petitioners' Request for Non-Prosecution Agreement and Report of
+Interview (Lee, Dexter) (Entered: 08/13/2008)
+08/13/2008
+23
+ORDER Setting Status Conference: Status Conference set for 8/14/2008 03:30 PM in West
+Palm Beach Division before Judge Kenneth A. Marra. Parties may contact the courtroom deputy
+at 561-514-3765 to make arrangements to appear telephonically. Signed by Judge Kenneth A.
+Marra on 8/13/08. (ir) (Entered: 08/13/2008)
+08/14/2008
+25
+S 4208. Cour Reporter Steple Frane inde Kne num 361-514-378 CrEecheld on
+08/20/2008
+08/21/2008
+08/22/2008
+24
+NOTICE of Instruction to Filer: re 22 Notice (Other) filed by United States of America Error:
+Vrong Event Selected; Instruction to filer - In the future please select the proper event. (Is
+Entered: 08/20/2008
+26
+ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER. Signed by Judge
+Kenneth A. Marra on 8/21/08. (ir) (Entered: 08/21/2008)
+27
+RANSCRIPT of Hearing held on 8/14/2008 before Judge Kenneth A. Marra. Court Reporte
+ephen Franklin - phone number 561-514-3768 25 pages. (abd) (Entered: 08/25/200
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?657771929017239-L_801_0-1
+10/17/200
+
+
+CM/ECF - Live Database - r «
+
+/ 09/25/2008
+10/08/2008
+10/16/2008
+28
+29
+30
+MOTION to Unseal Document Non-Prosecution Agreement by Jane Doe. Responses due by
+10/14/2008 (Attachments: # 1 Text of Proposed Order)(Edwards, Bradley) (Entered:
+09/25/2008)
+RESPONSE in Opposition re 28 MOTION to Unseal Document Non-Prosecution Agreement
+filed by United States of America. (Villafana, Ann Marie) (Entered: 10/08/2008)
+RESPONSE/REPLY to 29 Response in Opposition to Motion to Unseal Non-Prosecution
+Agreement filed by Jane Doe. (Attachments: # 1 Exhibit October 9, 2008 letter from Brad
+Edwards, Esquire to AUSA Dexter Lee, # 2 Exhibit October 15, 2008 Letter from Brad
+Edwards, Esquire to AUSA Dexter Lee)(Edwards, Bradley) (Entered: 10/16/2008)
+PACER Service Center
+Transaction Receipt
+10/17/2008 10:41:21
+PACER Login: du4480
+Description:
+Billable Pages:
+] Client Code:
+Docket Report Search Criteria:
+KAN9-80736-
+2
+Cost:
+0.16
+https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?657771929017239-L_801_0-1
+10/17/2001
+
+
+Case 9:08-CV-8. 36-KAM Document su
+Entered uri FLSD Docket 10/16/2 ud Page 1 of 6
+CASE NO.: 08-80736-CTV-MARRA/JOHNSON
+JANE DOE #1 AND JANE DOE #2,
+Petitioners,
+UNITED STATES OF AMERICA,
+Respondent.
+VICTIMS' REPLY TO RESPONDENT'S OPPOSITION TO
+VICTIMS' MOTION TO UNSEAL NON-PROSECUTION AGREEMENT
+COME NOW the Petitioners, Jane Doe #1 and Jane Doe #2 ("the victims"), by and
+through undersigned counsel, and reply to the Government's Opposition to Victims' Motion to
+Unseal Non-Prosecution Agreement.
+The victims have moved for a lifting of the protective order barring them from publiely
+disclosing or discussing the terms of the non-prosecution agreement between Jeffrey Epstein and
+the United States Government.
+Jeffrey Epstein has made no response to this motion. The
+Government, however, contends that the victims' motion should be denied because the victims
+cannot show any injury from the protective order. The Government's position is wrong for three
+reasons. First, the Government bears the burden of showing some good cause for a protective
+order. It has utterly failed to even offer any such cause - much less show that it is good cause.
+Second, the Government - with the apparent contrivance of Jeffrey Epstein's attorneys - has
+made inaccurate representations about the nature of the non-prosecution agreement in its notices
+to the victims and in its filing before the Court. To set the record straight, therefore, the victims
+
+
+Document Su
+Entered ..l FLSD Docket 10/16/2uud Page 2 of 6
+should be allowed to publicly discuss the agreement. Finally, the victims are burdened by
+provisions in the protective order. For all these reasons, the protective order should be lifted.
+No Good Cause Has been Shown for Sealing the Agreement.
+In their motion to unseal the agreement, the victims argued that there was no good reason
+for the protective order requiring them not to further disseminate the agreement. Curiously, the
+Government's response does not offer any substantive reason for the agreement to remain under
+seal or under a protective order.! Instead, the Government contends that victims have "no legal
+right to disclose the Agreement to third parties, or standing to challenge the confidentiality
+provision." Gov't Response at 2. But this argument has things backwards. It is not the victims"
+task to show some reason for not entering a protective order; rather, it is the Government's task
+to show some affirmative reason for entering the order in the first place. See Fed. R. Civ. P.
+26(c) (allowing for entry of a protective order upon motion for a party "for good cause shown");
+see also In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (11" Cir. 1987) ("good
+cause" for a protective order "generally signifies a sound basis or legitimate need to take judicial
+action"). Having been given the opportunity to explain why the document has to remain
+confidential, the Government chose not to do so. And Jeffrey Epstein was served with the
+victims' motion, but chose not to respond. Presumably this was because Jeffrey Epstein had no
+real interest at stake in the confidentiality of the agreement. Therefore, the protective order
+should be lifted because it lacks any articulated justification - much less any justification that
+constitutes good cause.
+"The Government prefers to view the issues in this case as involving not the sealing of a document but rather the
+preced on the ivere preventing the iclesure of a document. To simplity the dispute in this case, we will
+
+
+Case 9:08-cv-8.. 36-KAM
+Document '3-
+Entere ... FLSD Docket 10/16/2v.J Page 3 of 6
+2.
+The Government, With the Apparent Aid of Epstein, Has Provided Inaccurate
+Information to the Victims (and to the Court).
+The victims also asked that the protective order be lifted to help clarify the record in this
+case. The Government has made public representations in its pleadings in this case about the
+civil remedy provision in the non-prosecution agreement. It also specifically sent notices to Jane
+Doe #1 and other victims of Jeffrey Epstein's crimes describing this provision in the agreement.
+Those representations were inaccurate - as the Government now seemingly admits. See Gov't
+Response at 6 (referring to "erroneous disclosure" that was "inadvertently made" to Jane Doe
+#1). Indeed, the Government now takes the position that the responsibility for those inaccurate
+representations to the victim - as well as to the Court - lies with Jeffrey Epstein's attorneys'.
+See Gov't Response at 5 ("the [inaccurate] victim notification letter was provided to Epstein's
+attorneys prior to being sent, who approved the language of which the petitioners now
+complain.").
+The apparent approval by Jeffrey Epstein's attorneys of inaccurate information being sent
+to crime victims (and possibly their approval of inaccurate information being provided, as a
+result, to the Court) raises very significant issues under the Crime Victim's Rights Act. The
+victims have, therefore, sent a letter to the U.S. Attorney's Office requesting clarification of
+exactly how Jeffrey Epstein's attorneys participated in misleading the victims. See Attachment 1
+(Oct. 9, 2008, Letter from Brad Edwards, Esq. to AUSA Dexter Lee). Indeed, it appears that the
+Government may have provided an inaccurate description of another feature of the nonprosecution agreement to the vietims. See Attachment 2 (Oct. 15, 2008 Letter from Brad
+Edwards, Esq. to AUSA Dexter Lee (noting Government's representation to vietims of a right to
+recover at least $150,000 in damages from Jeffrey Epstein while Jeffrey Epstein's lawyers take
+the position that the agreement allows automatic recovery of only $50,000). In light of all these
+
+
+Document 3u
+Entered ..! FLSD Docket 10/16/2l.ú Page 4 of 6
+apparent misrepresentations about precisely what the non-prosecution agreement entails, the
+victims should not be bound by a protective order barring their public disclosure of the
+agreement.
+3.
+The Protective Order Unfairly Burdens the Victims.
+In their motion, the victims also explained how the protective order burdened their efforts
+to confer with other victims' rights attorneys regarding how best to proceed in light of the nonprosecution agreement. The Government does not seriously contest the victims' representations
+about the burdens imposed by the protective order. Instead, it takes the truly remarkable position
+that "the Protective Order does not prevent [the victims] from consulting with anyone; it only
+prevents them from disclosing the Agreement." Gov't Response at 4. But the whole point of the
+victims' motion was that the protective order places burdens on the victims in consulting with
+other attorneys about the agreement. Obviously, it is of no help to the victims to be able to
+consult with other attorneys on that issue if the agreement itself cannot be disclosed.
+CONCLUSION
+The provision in the protective order barring the victims and their attorneys from publicly
+disclosing the non-prosecution agreement should be lifted.
+DATED this 16th day of October, 2008.
+By:
+Respectfully Submitted,
+THE LAW OFFICE OF BRAD EDWARDS &
+ASSOCIATES, LLC
+_ s/ Brad Edwards
+2028 Harrison Street - Suite 202
+Hollywood, Florida 33020
+Telephone: 954-414-8033/Fax: 954-924-1530
+be@bradedwardslaw.com
+
+
+Case 9:08-cv-8v. 36-KAМ
+Document 3u
+Entered ..l FLSD Docket 10/16/2vud Page 5 of 6
+Paul G. Cassell
+Attorney for Petitioners
+Pro Hac Vice
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+801-585-6833
+cassellp@law.utah.edu
+Jay C. Howell, Esquire
+Attorney for Petitioners
+Pro Hac Vice
+644 Cesery Boulevard - Suite 250
+Telephone: F04-80-1234
+904-680-1238
+jay@jayhowell.com
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on October 16, 2008, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF.
+SERVICE LIST
+Jane Doe 1 and Jane Doe 2
+Case No.: 08-80736-CIV-MARRA/JOHNSON
+United States District Court, Southern District of Florida
+Dexter A. Lee,
+Assistant U.S. Attorney
+Falsihone: 305-50-7330
+305-530-7139
+Ann Marie C. Villafana, AUSA
+500 South Australian Averue
+Suite 400
+West Palm Beach, Florida 33401
+s/ Brad Edwards
+
+
+Document 3
+Entered ... FLSD Docket 10/16/24. Page 6 of 6
+I HEREBY FURTHER CERTIFY that on October 16, 2008, a true and correct copy of
+the above and foregoing document is being provided by United States mail to:
+Jack Alan Goldberger, Esquire
+Atterburty, Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, Florida 33401
+jagesq@bellsouth.net
+Michael R. Tein, Esquire
+Lewis Tein, P.L.
+3059 Grand Avenue
+Suite 340
+Coconut Grove, Florida 33133
+tein@lewistein.com
+Robert D. Critton, Jr., Esquire
+Michael J. Pike, Esquire
+Burman, Critton, Luttier & Coleman, LLI
+515 North Flagler Drive
+Suite 400
+West Palm Beach, Florida 33401
+rcrit@bclclaw.com
+mpike@bclclaw.com
+s/ Brad Edwards
+
+
+Case 9:08-cv-80, vo-KAM
+Document 3U: I A w Enterer 1 FLSD Docket 10/16/<vu8
+AND ASSOCIATES.....
+October 9, 2008
+
+Re:
+Jane Doe # and Jane Doe #2 |. United States of America
+Case No.:
+08-80736-CIV-MARRA/JOHNSON
+Dear Mr. Lee:
+I am writing to call to your attention two potentially false statements that the Government
+made, albeit inadvertently, in a sworn declaration submitted to the Court in connection with the
+above-captioned case. I request that your office file a corrected declaration and accompanying
+explanation.
+The first statement is found at page 3 to 4 of the July 9'h
+, 2008 declaration of Marie
+Villafaña. There a provision in a plea agreement with Mr. Jeffrey Epstein is recounted. As we
+understand the Government's current position in this case, it is that this provision is not in fact
+part of the plea agreement in this case. If our understanding is correct, then Ms. Villafaña has
+filed a false affidavit with the court, albeit inadvertently. We respectfully request that she file a
+new affidavit that corrects this false information, along with all other information relevant to
+understanding how the false information came to be provided to the court - and to the victims in
+this case. This correction should, in my view, include more details about how Epstein and his
+attorneys approved a submission of false information to the victims as you stated on Page 5, n.2
+in your October 8, 2008 filing "Respondent's Opposition to Victims' Motion to Unseal Non-
+Prosecution Agreement" - presumably knowing that litigation surrounding the victims' rights
+issues was on-going and that such false information might be ultimately presented to the court.
+Such information is highly relevant to what remedy the victims might ultimately choose to seek
+for violations of their rights in this case.
+The second statement may or may not be false, but may need some clarification. At page
+4 of Ms. Villafaña declaration, she states that "[i]n October 2007, shortly after the agreement was
+signed, four victims [including C.W.] were contacted and these provisions were discussed"
+(emphasis added). Similarly at page 5, the declaration states: "After C.W. had been notified of
+the terms of the agreement ....." (emphasis added). I write to inquire whether, in view of the fact
+that the provision noted above is not in fact (according to the Government's current view) part of
+the plea agreement, whether this was the provision that the government (inaccurately) discussed
+with the victims. Put another way, I am wondering whether the Government will now stipulate
+that it, at most, discussed with the victims a provision in the plea agreement that never was
+actually part of the plea agreement.
+2028 HARRISON STREET, SUITE 202, HOLLYWOOD, FLORIDA 33020
+
+
+Case 9:08-cv-80. uô-KAM
+Document 36 -
+Entere un FLSD Docket 10/16/<.u8 Page 2 of 2
+October 9, 2008
+Page Two
+I continue to be interested in working out a joint stipulation of proposed facts in this case
+with the Government. If you would like to proceed in that direction, please give me a call. If,
+however, the Government is not willing to work out a joint stipulation of facts, then I need to
+have the record be as clear as possible, and at a minimum would request that the Government
+correct the inaccurate information it has provided to the court and clarify precisely how such
+inaccurate information came to be made a part of the record and the extent to which Mr. Epstein,
+through his attorneys, was culpable.
+Sincerely,
+• BE/sg
+Brad Edwards
+2028 HARRISON STREET, SUITE 202, HOLLYWOOD, FLORIDA 33020
+
+
+Case 9:08-cv-80. -ỏ-KAM
+Document 3U LAw Entererof FLSD Docket 10/16/2. v8
+AND ASSOCIATES
+
+October 15, 2008
+Re: Jane Doe # and Jane Doe #2 | United States of America
+Case No.:
+08-80736-CIV-MARRA/JOHNSON
+Dear Mr. Lee:
+1 am writing to inquire about whether Mr. Epstein has violated his Non-Prosecution
+Agreement with the Government.
+As you know, the Government has repeatedly described the Non-Prosecution Agreement
+as guaranteeing to the victims of Epstein's sexual abuse at least $150,000 in civil damages. The
+Government has made these representations in reliance on a current provision in the U.S. Code -
+18 U.S.C. § 2255(a) - which provides for an automatic amount of damages of at least $150,000.
+At the time that the Non-Prosecution Agreement was drafted and signed, that was the law that
+was in effect.
+In Epstein's latest filing in federal court, however, he takes the position that the pre-2006
+Amendments version of the law applies. See Defendant Epstein's Motion to Dismiss, for More
+Detinite Statement and To Strike Directed to Plaintiff Jane Doe's Complaint at 9, Jane Doe 1
+Jeffrey Epstein, No. 08-CIV-80893-Marra/Johnson (discussing § 2255 and stating that the
+"applicable version of the statute" is "pre-2006 Amendments"). The 2006 Amendments altered
+§ 2255(a), by increasing the presumed minimum damages from $50,000 to $150,000. See Pub.
+L. 109-248, Title VIl, § 707(b), (c), July 27, 2006, 120 Stat. 650.
+In light of Epstein's latest filing, I write to ask several questions:
+(1) Would you stipulate that you told me several times that Epstein had agreed to pay at
+least $150,000 to the identified victims of his abuse?
+(2) Did Epstein in fact agree to pay damages to the identified victims of his abuse at least
+$150,000?
+(3) Did the Government tell victims, either directly or through counsel, that Epstein had
+agreed to pay his victims at least $150,000?
+2028 HARRISON STREET, SUITE 202, HOLLYWOOD, FLORIDA 33020
+
+
+Case 9:08-cv-84. 6-KAM
+Document 36-
+Entere, un FLSD Docket 10/16/<vv8
+
+October 15, 2008
+Page Two
+(4) Is Epstein in compliance with his Non-Prosecution Agreement with the Government
+when he is now taking the legal position, through his attorneys, that he only has to
+pay the victims $50,000 damages under § 2255?
+Thank you for any clarification you can provide on these questions.
+Sincerely,
+BE/sg
+cc:
+Brad Edwards
+Ann Marie C. Villafaña, AUSA
+500 South Australian Avenue
+West Palm Beach, Florida 33401
+2028 HARRISON STREET, SUITE 202, HOLLYWOOD, FLORIDA 33020
+OFFICE: 954-414-8053/305-935-2011
+
+
+29
+
+
+Case 9:08-Cv-
+3-KAM Document 29
+Entered on FLSD Docket 10/
+08 Page 1 of 7
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOES #1 and #2
+Petitioners,
+UNITED STATES OF AMERICA,
+Respondent.
+RESPONDENT'S OPPOSITION TO VICTIMS' MOTION
+TO UNSEAL NON-PROSECUTION AGREEMENT
+Respondent, by and through its undersigned counsel, files its Opposition to
+Victims' Motion to Unseal Non-Prosecution Agreement, and states:
+I.
+THE MOTION TO UNSEAL SHOULD BE DENIED
+BECAUSE THE NON-PROSECUTION AGREEMENT HAS
+NEVER BEEN FILED UNDER SEAL IN THIS COURT.
+Petitioners have filed their motion to unseal the non-prosecution agreement,
+claiming that no good cause exists for sealing it. As an initial matter, the motion should
+be denied because the non-prosecution agreement entered into between the United States
+Attorney's Office and Jeffrey Epstein was never filed in the instant case by the United
+States, either under seal or otherwise. On August 14, 2008, this Court held a telephonic
+hearing to discuss petitioners' request for a copy of the non-prosecution agreement. The
+United States advised the Court that the Agreement had a confidentiality provision,
+
+
+Entered on FLSD Docket 10/t
+08 Page 2 of 7
+which the United States was obligated to honor. The United States requested that, if the
+Agreement was to be produced to petitioners, it should be done pursuant to a protective
+order, to ensure that further dissemination of the Agreement would not occur. At that
+time, petitioners had no objection to such a procedure.
+On August 21, 2008, this Court entered its Order to Compel Production and
+Protective Order (DE 26). Subpart (b) of the Order provides that, "Petitioners and their
+attorneys shall not disclose the Agreement or its terms to any third party absent further
+court order, following notice to and an opportunity for Epstein's counsel to be heard."
+(DE 26 at 1.) Presumably, petitioners' motion to unseal is an effort to modify the terms
+of the Protective Order, to enable them to disclose the Agreement to third parties.
+Since the Agreement has not been filed under seal with this Court, the legal
+authority cited by petitioners regarding sealing of documents, United States | Ochoa-
+Vasque, 428 F.3d 1015 (11" Cir. 2005), is inapposite. The parties who negotiated the
+Agreement, the United States Attorney's Office and Jeffrey Epstein, determined that the
+Agreement should remain confidential. They were free to do so, and violated no law in
+making such an agreement. Since the Agreement has become relevant to the instant
+lawsuit, petitioners have been given access to it, upon the condition that it not be
+disclosed further.' Petitioners have no legal right to disclose the Agreement to third
+parties, or standing to challenge the confidentiality provision.
+'It is unclear whether the Petitioners themselves (as opposed to their attorneys) have
+actually reviewed the Non-Prosecution Agreement. The Court's Order to Compel Production
+required petitioners' counsel to review and agree to the Protective Order and to do the same with
+2
+
+
+-KAM Document 29 Entered on FLSD Docket 10/0
+38 Page 3 of 7
+In order to have standing, petitioners must show: (1) an injury in fact, meaning an
+injury that is concrete and particularized, and actual or imminent; (2) a causal connection
+between the injury and the causal conduct; and (3) a likelihood that the injury will be
+redressed by a favorable decision. Granite State Outdoor Advertising, Inc. |. City of
+Clearwater, Fla., 351 F.3d 1112, 1116 (11" Cir. 2003). Petitioners already have obtained
+access to the agreement, so they cannot claim a denial of access as an injury in fact.
+Their motion to unseal refers to their stated desire to confer with other victims of Epstein
+and their attorneys "to determine whether they were likewise provided with inaccurate
+information about the nature of the plea agreement." (DE 28 at 5.)
+This asserted reason for needing to unseal the Agreement is baseless given that the
+Protective Order, at the Court's direction, specifically provides for a very simple
+procedure to allow other victims and their lawyers to see the Agreement. (See DE 26 at
+1-2, subpart (d).) All that is required is for any victims and/or their attorneys to review
+and agree to the terms of the Protective Order, and to provide the signed acknowledgment
+of that agreement to the United States.
+Petitioners' claim that they wish to discuss with others the "possible legal
+responses" to the Government, including the National Alliance of Victims' Rights
+Attorneys, also provides no basis for vacatur of the Protective Order. Petitioners contend
+that the "sealing order would apparently block these forms of consultation ..." (DE 28 at
+their clients. Copies of those signed acknowledgements to abide by the Protective Order were
+then to be provided "promptly" to the United States. To date, only Attorney Brad Edwards has
+provided a signed acknowledgement.
+3
+
+
+Case 9:08-cv-f
+I-KAM Document 29
+Entered on FLSD Docket 10/1
+08 Page 4 of 7
+5.) First, there is no sealing order. Second, the Protective Order does not prevent
+petitioners from consulting with anyone; it only prevents them from disclosing the
+Agreement. Petitioners fail to mention why it is necessary for the National Alliance of
+Victims' Rights Attorneys to have the Agreement in hand, in order to meaningfully
+consult with them.
+Petitioners also assert that they would like to be able to reference the Agreement
+"in a parallel civil suit that is pending before this Court." (DE 28 at 5.) Given that the
+suit names Jeffrey Epstein as a defendant and is pending before the same district judge, it
+seems that litigation regarding the production and use of the Agreement should occur in
+that case, where the true party in interest, Jeffrey Epstein, is present and represented by
+counsel, rather than in a suit that was originally filed in July as an "Emergency Petition"
+under the various victims' rights laws.
+Il.
+THE GOVERNMENT ACCURATELY DESCRIBED THE
+PROVISIONS OF THE AGREEMENT, AT THE TIME THE
+RESPONSES WERE FILED WITH THE COURT.
+Petitioners castigate the Government for inaccurately describing the nonprosecution agreement. (DE 28 at 2-5.) They contend a particular provision cited by the
+Government does not appear in the copy of the Agreement produced to them.
+During the telephonic hearing on August 14, 2008, Government counsel advised
+the Court and petitioners' counsel that there was an ongoing dispute between the
+Government and Epstein's attorneys over what constituted the Agreement. Government
+counsel advised that, in its opinion, the Agreement had three parts. The first part was
+4
+
+
+Case 9:08-cv-f
+08
+
+executed in September 2007, the second part, an addendum, was executed in October
+2007, and the third part was a December 2007 letter from the United States Attorney to
+Epstein's attorneys, suggesting a further modification of the Agreement. The
+Government advised the Court that it believed that all three parts comprised the
+Agreement, while it appeared that Epstein's attorneys were contending the Agreement
+was comprised only of parts one and two.
+At the commencement of the instant litigation, in July 2008, the Government
+believed the Agreement was comprised of all three parts mentioned above. This belief
+was expressed in victim notification letters, including one sent to Jane Doe #1, the
+Government's July 9, 2008 response to the Emergency Petition for Enforcement of
+Victims Rights Act, as well as the Declaration of A. Marie Villafaña, Assistant U.S.
+Attorney, which accompanied the Government's response. This belief continued until
+August 2008, when the Government advised Epstein's attorneys that the victims had
+2The victim notification letter was provided to Epstein's attorneys prior to being sent,
+who approved the language of which the petitioners now complain. Thus, petitioners' repeated
+assertions that the Government made these errors intentionally and/or negligently are meritless.
+(See, e.g. DE 28 at 4-5 ("The Government apparently feels free to disclose to the victims one
+provision in the non-prosecution agreement that it believes it is to its advantage to disclose, but
+not others. The Government should not be permitted to pick and choose, particularly where it
+has inaccurately described the provision that it has chosen to disclose.") The Government seeks
+no "advantage" in this suit brought by the two victims. Furthermore, the petitioners' original
+emergency petition focused on their concern about the amount of jail time that Epstein would
+serve. The provision that they complain of now has no relation to jail time. Furthermore,
+petitioners aver that the October 2007 disclosure to Jane Doe #1 contained inaccurate
+information, but that disclosure was made before the December 2007 letter and, therefore, did
+not include anything related to the U.S. Attorney's now-defunct proposed amendment to the
+Agreement.
+5
+
+
+08 Page 6 of 7
+demanded disclosure of the Agreement to them, and discussions ensued about what
+constituted the Agreement. Epstein's attorneys then told the Government that Epstein
+believed the Agreement consisted only of the first and second parts. These were the parts
+disclosed to petitioners pursuant to the Protective Order in compliance with the Court's
+order to compel production. The fact that an erroneous disclosure was inadvertently
+made to one petitioner after Epstein had already entered his guilty plea, was sentenced,
+and surrendered to begin serving his sentence does not create an injury where one did not
+exist before.
+CONCLUSION
+For the foregoing reasons, the United States respectfully requests that the Court
+deny Petitioners' Motion to Unseal the Non-Prosecution Agreement.
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+Fla. Bar No. 0936693
+(305) 961-9320
+Fax: (305) 530-7139
+E-mail: dexter.lee@usdoj.gov
+6
+
+
+08 Page 7 of 7
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on October 8, 2008, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF.
+s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+SERVICE LIST
+Jane Does 1 and 2 I. United States
+Case No. 08-80736-CIV-MARRA/JOHNSON
+United States District Court, Southern District of Florida
+Brad Edwards, Esq.,
+The Law Offices of Brad Edwards & Associates, LLC
+2028 Harrison Street, Suite 202
+Hollywood, Florida 33020
+7
+
+
+HI CED FOR
+B0000 SERIES
+
+
+Case 9:08-CV-{
+-KAM Document 28 Entered on FLSD Docket 09/:
+38 Page 1 of 8
+CASE NO.: 08-80736-CIV-MARRA/JOHNSON
+JANE DOE #1 AND JANE DOE #2,
+Petitioners,
+UNITED STATES OF AMERICA,
+Respondent.
+VICTIM'S MOTION TO UNSEAL NON-PROSECUTION AGREEMENT
+COMES NOW the Petitioners, Jane Doe #1 and Jane Doe #2, by and through their
+undersigned attorneys, pursuant to the Crime Victim's Rights Act, 18 U.S.C. Section 3771
+("CVRA"), and file this motion to unseal the non-prosecution agreement that has been provided
+to their attorneys under seal in this case. The agreement should be unsealed because no good
+cause exists for sealing it. Moreover, the Government has inaccurately described the agreement
+in its publicly-filed pleadings, creating a false impression that the agreement protects the victims.
+Finally, the agreement should be unsealed to facilitate consultation by victims' counsel with
+others involved who have information related to the case.
+BACKGROUND
+As the court is aware, this action was brought by two crime victims (hereinafter referred
+to as "the victims") seeking protection of their rights under the Crime Victim's Rights Act, 18
+U.S.C. § 3771. At the center of this action is an agreement between the United States and Jeffrey
+Epstein that (as described in earlier court pleadings publicly filed by the Government) involved
+1
+
+
+6-KAM Document 28
+Entered on FLSD Docket 09.
+108 Page 2 of 8
+Epstein's entry of guilty pleas to various state charges and an 18-month jail sentence, in
+exchange for which the U.S. Government apparently agreed to defer all federal prosecution -
+including any federal prosecution for the federal crimes committed against the victims.
+At a hearing held on August 14, 2008, the court ordered the Government to produce to
+counsel for the victims the non-prosecution agreement. That production, however, was to be
+done under protective order in the first instance. The agreement has now been produced. At the
+earlier hearing, the court recognized that the victims' counsel might at a later date seek to have
+the sealing lifted. That date has now arrived.
+ARGUMENT
+As the court envisioned might well happen, counsel for the victims now believe that
+sealing of the agreement is no longer appropriate. The non-prosecution agreement should now
+be unsealed for three reasons.
+No Good Cause Has Been Shown for Sealing the Agreement.
+Having now reviewed the agreement, counsel for the victims can find no
+legitimate basis for the document to be sealed. Because it stands at the center of this litigation
+(as well as several related civil suits), the burden should fall on those who would keep the
+document sealed to show cause for doing so. No good cause has yet been shown. Cf. United
+States |. Ochoa-Vasque, 428 F.3d 1015 (11" Cir. 2005) (to justify sealing of court records "a
+court must articulate the overriding interest along with findings specific enough that a reviewing
+court can determine whether the closure order was properly entered").
+2.
+The Government Has Inaccurately Described the Agreement.
+In its publicly-filed pleadings in this case, the Government has inaccurately
+2
+
+
+i-KAM Document 28
+Entered on FLSD Docket 09/:
+18 Page 3 of 8
+described the non-prosecution agreement, creating the false impression that it is more favorable
+to the victims than it actually is. Accordingly, the non-prosecution agreement should be unsealed
+so that the true state of affairs is reflected in the court's file.
+In its response to the victims' petition, the Government states that the nonprosecution agreement contains the following provision:
+Any person, who while a minor, was a victim of a violation of an
+offense enumerated in Title 18, United states Code, Section 2255,
+any a plaintiff must meet, shall consider that it is the intent of the
+parties to place these identified victims in the same position as they
+would have been had Mr. Epstein been convicted at trial. No
+more; no less.
+Govt's Resp. to Victim's Emergency Petition for Enforcement of Crime Victim's Right at 4. The
+sworn declaration of the Assistant U.S. Attorney handling this matter also recounts the same
+language.
+See Declaration of A. Marie Villafaña in Support of United States' Response to
+Victims' Emergency Petition at 3-4. The sworn declaration also states that victims were told
+about this language in October 2007. See Declaration of A. Marie Villafaña at 4 ("In October
+2007, shortly after the agreement was signed, four victims were contacted and these provisions
+were discussed"). On July 9, 2008, the victims received notice from the Government that the
+above-described provision was negotiated on behalf of the victims for their protection and was
+3
+
+
+З-KAМ Document 28
+Entered on FLSD Docket 09/
+08 Page 4 of 8
+thus contained in the non-prosecution agreement. 1
+Having now reviewed the non-prosecution agreement, the Government's response
+to the victims' motion and the accompanying sworn declaration are simply untrue. The abovequoted provision simply does not appear in the agreement anywhere. It is true that the nonprosecution agreement contains a provision bearing on the same subject. However, this
+provision has a number of qualifying provisos that make it far less favorable to the victims than
+the above-described provision. (To avoid filing a separate, sealed pleading laying out the
+differences, counsel for the victims have simply described the differences in general terms. We
+trust that the Government, in its response, will agree that it has erroneously described the
+agreement to the court and the victims.)
+The Government should be required to correct its previously-filed pleadings to
+accurately recount the non-prosecution agreement that it reached with Epstein. Moreover, the
+Government should also be required to state forthrightly whether through the last nine months, it
+gave the victims (like the court) inaccurate information about what the non-prosecution
+agreement entailed. But most important, because the current sealing of the non-prosecution
+agreement creates a false and deceptive appearance about the agreement that the Government has
+actually reached with Epstein, the agreement should be unsealed.
+Indeed, it should be noted that sealing of materials in this case appears to operate
+in a rather peculiar fashion. The Government apparently feels free to disclose to the victims one
+provision in the non-prosecution agreement that it believes it is to its advantage to disclose, but
+not others. The Government should not be permitted to pick and choose, particularly where it
+1 The Government has recently provided a new notice to the victims, containing different language.
+4
+
+
+6-KAM Document 28
+Entered on FLSD Docket 09,
+108 Page 5 of 8
+has inaccurately described the provision that it has chosen to disclose.
+The Non-Prosecution Agreement Should be Unsealed To Facilitate Effective
+Representation of the Victims in this Action and Related Civil Actions.
+The sealing order bars the victims' counsel from "disclosing] the Agreement or
+its terms to any third party absent further court order, following notice to and an opportunity for
+Epstein's counsel to be heard." Order to Compel Production and Protective Order at 1. Victims'
+counsel have scrupulously abided by that restriction. Victims' counsel would, however, now like
+to discuss the terms of the non-prosecution agreement with third parties in making a
+determination about how best to proceed in this action, including what remedies to seek for the
+violations of victims' rights that have occurred. Counsel, therefore, respectfully seek the "further
+court order" that the sealing order envisions.
+In particular, victims' counsel would like to discuss the agreement with other
+victims of Epstein and their attorneys to determine whether they were likewise provided with
+inaccurate information about the nature of the plea agreement. Victims' counsel would also like
+to discuss possible legal responses to the Government with other victims' rights attorneys,
+including in particular the National Alliance of Victims' Rights Attorneys for possible legal
+approaches. See http://www.ncvli.org/navra.html. The sealing order would apparently block
+these forms of consultation, or perhaps require such burdensome non-disclosure obligations as to
+make the consultation difficult or impractical. Finally, victims' counsel would like to refer to the
+non-prosecution agreement in a parallel civil suit that is pending before this court. See Jane Doe
+1. Jeffrey Epstein, United States District Court, Southern District of Florida, Case No.: 08-CIV-
+80893-MARRA-JOHNSON. To facilitate all these discussions, the non-prosecution agreement
+5
+
+
+-KAM Document 28
+Entered on FLSD Docket 09/2
+18 Page 6 of 8
+should be unsealed.
+NOTICE TO EPSTEIN
+It is possible that Jeffrey Epstein will object to the unsealing of the agreement.
+Accordingly, the court should provide notice of this motion to Jeffrey Epstein, through counsel.
+Jeffrey Epstein's counsel has entered an appearance in several related civil suits, including Jane
+. Doe | Jeffrey Epstein, United States District Court, Southern District of Florida, Case No.: 08-
+CIV-80893-MARRA-JOHNSON. Although Epstein's counsel has not entered an appearance in
+this matter, as a courtesy to them, counsel for the victims' will provide a copy of this pleading at
+the address indicated in the related civil suit.
+CONCLUSION
+The non-prosecution agreement should be unsealed.
+DATED this 25th day of September, 2008.
+Respectfully Submitted,
+THE LAW OFFICE OF BRAD EDWARDS &
+ASSOCIATES, LIC
+By:
+_ s/ Brad Edwards
+Attorney for Petitioners
+2028 Harrison Street
+Hollywood, Florida 33020
+Telephone: 954-414-8033
+E-Mail:
+be@bradedwardslaw.com
+6
+
+
+Document 28
+Entered on FLSD Docket 09/:
+18 Page 7 of 8
+Paul G. Cassell
+Attorney for Petitioners
+Pro Hac Vice
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone:
+801-585-5202
+801-585-6833
+E-Mail:
+cassellp@law.utah.edu
+Jay C. Howell, Esquire
+Attorney for Petitioners
+Pro Hac Vice
+644 Cesery Boulevard
+Suite 250
+Jacksonville, Florida 32211
+Telephone:
+904-680-1234
+904-680-1238
+E-Mail:
+jay@jayhowell.com
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on September 25, 2008, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF.
+SERVICE LIST
+Jane Doe 1 and Jane Doe 2
+Case No.: 08-80736-CIV-MARRA/JOHNSON
+United States District Court, Southern District of Florida
+Dexter A. Lee,
+Assistant U.S. Attorney
+Telephone:
+305-961-9320
+305-530-7139
+7
+
+
+Case 9:08-CV-i
+İ-KAM Document 28
+Entered on FLSD Docket 09/:
+08 Page 8 of 8
+Ann Marie C. Villafana, AUSA
+500 South Australian Avenue
+Suite 400
+West Palm Beach, Florida 33401
+s/ Brad Edwards
+I HEREBY FURTHER CERTIFY that on September 25, 2008, a true and correct copy of
+the above and foregoing document is being provided by United States mail to:
+Jack Alan Goldberger, Esquire
+Atterburty, Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, Florida 33401
+jagesq@bellsouth.net
+Michael R. Tein, Esquire
+Lewis Tein, P.L.
+3059 Grand Avenue
+Suite 340
+Coconut Grove, Florida 33133
+tein@lewistein.com
+Robert D. Critton, Ji., Esquire
+Michael J. Pike, Esquire
+Burman, Critton, Luttier & Coleman, LLP
+515 North Flagler Drive
+Suite 400
+West Palm Beach, Florida 33401
+rcrit@bclclaw.com
+mpike@bclclaw.com
+s/ Brad Edwards_
+8
+
+
+Case 9:08-CV-8(
+KAM Document 28-2
+Entered on FLSD Docket 09.
+108 Page 1 of 1
+CASE NO.: 08-80736-CIV-MARRAJJOHNSON
+JANE DOE #1 AND JANE DOE #2,
+Petitioners,
+UNITED STATES OF AMERICA,
+Respondent.
+ORDER TO UNSEAL NON-PROSECUTION AGREEMENT
+THIS CAUSE comes before the Court on the Petitioners' Motion to Unseal Non-
+Prosecution Agreement between the United States Attorney's Office for the Southern District of
+Florida and Jeffrey Epstein. After consideration of the Motion and the record, it is
+ORDERED AND ADJUDGED that the Petitioners' Motion is GRANTED and the Non-
+Prosecution Agreement between the United States Attorney's Office for the Southern District of
+Florida and Jeffrey Epstein is hereby ordered to be unsealed.
+DONE AND ORDERED in Chambers, in West Palm Beach, Palm Beach County,
+Florida, this
+_ day of
+_ 2008.
+KENNETH A. MARRA
+
+
+RECYCLED O
+B000O SERIES
+
+
+-KAM Document 27
+Entered on FLSD Docket 08/2
+18 Page 1 of 2
+ATTACHMENT(S) NOT SCANNED
+PLEASE REFER TO COURT FILE
+MAINTAINED IN THE OFFICE WHERE THE
+JUDGE IS CHAMBERED
+CASE NO. 08-80736-CV KAM
+DE#
+• DUE TO POOR QUALITY, THE ATTACHED
+DOCUMENT IS NOT SCANNED
+• VOLUMINOUS (exceeds 999 pages = 4 inches)
+consisting of (boxes, notebooks, etc.)
+• BOUND EXTRADITION PAPERS
+• ADMINISTRATIVE RECORD (Social Security)
+• ORIGINAL BANKRUPTCY TRANSCRIPT
+• STATE COURT RECORD (Habeas Cases)
+X SOUTHERN DISTRICT TRANSCRIPTS
+• LEGAL SIZE
+• DOUBLE SIDED
+• PHOTOGRAPHS
+• POOR QUALITY (e.g. light print, dark print, etc.)
+• SURETY BOND (original or letter of undertaking)
+• CD's, DVD's, VHS Tapes, Cassette Tapes
+• OTHER =
+
+
+3
+4
+5
+6
+:
+13
+15
+16
+17
+18
+"1
+23
+2.4
+6-KAM Document 27
+Entered on LSD Docket 08,
+108 Page 2 of2
+Page 1
+JANE DOE,
+Case No.
+08-80736-CIV-MARRA
+Petitioner,
+AUG 2 5 2008
+STERRUNS DIST CFE
+S. D. Of FLA. - MIAMI
+UNITED STATES OF AMERICA, I
+Respondent.
+West Palm Beach, Florida
+August 11, 2008
+TRANSCRIPT OF HEARING
+BEFORE "THE HONORABLE KENNETH A. MARRA
+U.S. DISTRICT JUDGE
+Appearances:
+FOR THE PETITIONER
+FOR THE RESPONDENT
+Reporter
+(561) 514-3768
+Bradley J. Edwards, ESQ., and
+Paul G. Cassell, ESQ.
+Dexter Lee, AUSA, ano
+Ann Marie C. Villafana, AUSP
+Stephen W. Franklin, RMR, CRR, CP!
+tricial Court Reporter
+701 Clematis Street, Suite 437
+West Palm Beach, Florida 33401
+(FILED by
+- D.C.
+AUG 2 2 2008
+
+
+
+
+-KAM Document 26 Entered on FLSD Docket 08/2
+18
+
+NO. 08-80736-CIV-MARRA/JOHNSON
+IN RE: JANE DOES 1 AND 2,
+Petitioners.
+ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER
+THIS CAUSE comes before the Court on the Petitioners' ore tenus motion seeking the
+production of the Non-Prosecution Agreement between the United States Attorney's Office for the
+Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"'). After consideration of the
+Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
+Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
+including any modifications and addenda thereto, in accordance with the following procedures:
+(a)
+The USAO shall produce a copy of the Non-Prosecution Agreement,
+including any modifications and addenda thereto (collectively referred to as the "Agreement"), to
+the attorneys for Petitioners.
+(b)
+Petitioners and their attorneys shall not disclose the Agreement or its terms
+to any third party absent further court order, following notice to and an opportunity for Epstein's
+counsel to be heard.
+(c)
+Before counsel for petitioners show the Agreement to their clients or discuss
+the specific terms with them, they must provide a copy of this Order to petitioners, who must review
+and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
+petitioners must promptly provide a copy of that acknowledgment to the USAO.
+(d)
+If any individuals who have been identified by the USAO as victims of
+
+
+Case 9:08-cv-:
+j-KAM Document 26 Entered on FLSD Docket 08/:
+08 Page 2 of 2
+Epstein and/or any attorney(s) for those individuals request the opportunity to review the
+Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
+individuals also agree that they shall not disclose the Agreement or its terms to any third party
+absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
+(e) Prior to producing the documents to any other individuals who have been
+identified by the USAO as victims of Epstein and/or any attorney(s) for those individuals, a copy
+of this Order must be provided to said individuals, who must review and acknowledge their receipt
+of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
+provide a copy of that acknowledgment to the USAO.
+DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
+this 21" day of August, 2008.
+KENNETH A. MARRA
+UNITED STATES DISTRICT JUDGE
+Copies furnished to: all counsel of record
+By signing below, I certify that I have reviewed and agree to be bound by the terms of this
+Order.
+Dated:
+Signed by:
+Printed Name:
+2
+
+
+50000 SERIES
+
+
+Case 9:08-Cv.
+3-KAM Document 23
+Entered on FLSD Docket 08/
+108 Page 1 of 1
+NO. 08-80736-CIV-MARRA/JOHNSON
+IN RE: JANE DOES 1 & 2,
+Petitioner
+ORDER
+PLEASE TAKE NOTICE that this cause has been set for a status conference on
+Thursday, August 14, 2008, at 3:30 p.m. before United States District Judge Kenneth A. Marra.
+The hearing shall be held in Courtroom 4 at the United States Courthouse, 701 Clematis Street,
+West Palm Beach, Florida. The parties may appear by telephone!'
+DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County,
+Florida, this 13" day of August, 2008.
+KENNETH A. MARRA
+United States District Judge
+'Any party wishing to appear by telephone must contact Chambers at 561-514-3765 by
+12:00 noon on August 14, 2008, to make the appropriate arrangements.
+
+
+
+
+-KAM Document 22 Entered on FLSD Docket 08/
+18 Page 1 of 3
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOES #1 and #2
+Petitioners,
+UNITED STATES
+Respondent.
+GOVERNMENT'S RESPONSE TO PETITIONERS' REQUEST
+FOR NON-PROSECUTION AGREEMENT AND REPORT OF INTERVIEW
+Respondent United States, by and through its undersigned counsel, files its Response to
+Petitioners' Request for Non-Prosecution Agreement and Report of Interview, and states:
+In their Response to Government's Notice to Court Regarding Absence of Need for
+Evidentiary Hearing and Motion for Production of Non-Prosecution Agreement and Report of
+Interview (D.E. 19), petitioners seek an order compelling the Government to produce the Non-
+Prosecution Agreement with Jeffrey Epstein (D.E. 19 at 11-13), and the Report of Interview with
+Jane Doe # 1 (D.E. 19 at 13-14).
+The Government is unable to voluntarily produce the Non-Prosecution Agreement
+because the Agreement contains a clause where the parties expressed their anticipation that the
+Agreement would not be made part of any public record.
+The Government believes this clause
+in the Agreement precludes it from voluntarily producing the Agreement, as requested by
+petitioners.
+
+
+Document 22 Entered on FLSD Docket 08,
+108 Page 2 of 3
+As to petitioners' request for the Report of Interview with Jane Doe # 1, counsel for the
+Government has spoken with FBI Special Agents Nesbitt Kurykendall and Jason Richards, who
+have advised that no Report of Interview was prepared subsequent to their meeting with Jane
+Doe # 1 in October 2007, to discuss the Non-Prosecution Agreement entered into with Jeffrey
+Epstein.
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+Fla. Bar No. 0936693
+99 N.E. 4" Street
+(305) 961-9320
+Fax: (305) 530-7139
+E-mail: dexter.Ice@usdoj.gov
+2
+
+
+-KAM Document 22 Entered on FLSD Docket 08/1
+18 Page 3 of 3
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on August 13, 2008, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF.
+_ s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+SERVICE LIST
+Jane Does 1 and 2 l. United States,
+Case No. 08-80736-CIV-MARRA/JOHNSON
+United States District Court, Southern District of Florida
+Brad Edwards, Esq.,
+202 arisin Sire, Sadie vards & Associates, LLC
+Hollywood, Florida
+33020
+3
+
+
+HUGER FOR
+RECYCLEDE
+
+
+•
+. Case 9:08-cv-5
+AKAM
+Document 20 Entered on FLSD Docket 08/1
+59L
+Clerk
+PAiD
+In Forma
+Fauperis steven M
+Case No.: 08-80736-CIV-Marra/Johnson
+In re: Jane Doe #1, and Jane Doe #2,
+Petitioners.
+18 Page 1 of 7
+FILED by —
+—. D.C.
+AUG 0 8 200B
+1D. OF FLA. - W.P
+MOTION FOR LIMITED APPEARANCE, CONSENT TO
+DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE
+NOTICES OF ELECTRONIC FILING
+In accordance with Local Rules 4.B of the Special Rules Governing the Admission and
+Practice of Attorneys of the United States District Court for the Southern District of Florida, the
+undersigned respectfully moves for the admission of Jay C. Howell for purposes of limited
+appearance as co-counsel on behalf of Jane Does #1 and #2, herein, in the above-styled case only,
+and pursuant to Rule 2B, Southern District of Florida, CM/ECF Administrative Procedures, to permit
+Jay C. Howell to receive electronic filings in this case, and in support thereof states as follows:
+1.
+While Jay C. Howell, is not admitted to practice in the Southern District of Florida,
+he is a member in good standing of the Florida Bar and the bar of the U.S. District Court for the
+Middle District of Florida.
+Movant, Brad Edwards, of the law firm of The Law Offices of Brad Edwards &
+Associates, is a member in good standing of The Florida Bar and the United States District Court
+for the Southern District of Florida, maintains an office in this State for the practice of law, and will
+shortly be filing the appropriate application to be authorized to file through the Court's electronic
+filing system. Movant consents to be designated as a member of the Bar of this Court with whom
+the Court and opposing counsel may readily communicate regarding the conduct of the case, upon
+
+
+Document 20 Entered on FLSD Docket 08/
+08 Page 2 of 7
+whom filings shall be served, who shall be required to electronically file all documents and things
+that may be filed electronically, and who shall be responsible for filing documents in compliance
+with the CM/ECF Administrative Procedures. See Section 2B of the CM/ECF Administrative
+Procedures.
+3.
+In accordance with the local rules of this Court, Jay C. Howell, has made payment
+(enclosed) of this Court's $75 admission fee. A certification in accordance with Rule 4B is attached
+hereto.
+Jay C. Howell, by and through designated counsel and pursuant to Section 2B,
+Southern District of Florida, CM/ECF Administrative Procedures, hereby requests the Court 1o
+provide Notice of Electronic Filings to Jay C. Howell, at email address: jay@jayhowell.com.
+WHEREFORE, Brad Edwards, Esquire, moves this Court to enter an Order permitting Jay
+C. Howell to appear before this Court on behalf of Jane Doe, for all purposes relating to the
+proceedings in the above-styled matter and directing the Clerk to provide notice of electronic filings
+to Jay C. Howell.
+Date: August 6, 2008
+Respectfully submitted,
+Florida Bar #542075
+be@bradedwardslaw.com
+2028 Harrison Street
+Suite 202
+Hollywood, Florida 33020
+Telephone:
+954-414-8033
+
+
+• Case 9:08-cv-{
+Document 20 Entered on FLSD Docket 08/1
+18 Page 3 of 7
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing Motion for Limited
+Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic
+Filings was served by mail, on August 6, 200B_, on all counsel or parties of record on the service
+list.
+
+
+-KAM Document 20
+Entered on FLSD Docket 08/1
+18 Page 4 of 7
+Case No.: 08-80736
+SERVICE LIST
+Ann Marie C. Villafana
+Assistant U.S. Attorney
+500 South Australian Avenue
+Suite 400
+West Palm Beach, FL 33401
+Dexter Lee
+Assistant U.S. Attorney
+
+
+6-KAM Document 20
+Entered on FLSD Docket 08/
+08 Page 5 of 7
+Case No.: 08-80736
+In re: Jane Doe, et al.
+Petitioners.
+CERTIFICATION OF JAY C. HOWELL
+Jay C. Howell, pursuant to Rule 4B of the Special Rules Governing the Admission and
+Practice of Attorneys, hereby certifies that (1) I have studied the Local Rules of the United States
+District Court for the Southern District of Florida; and (2) I am a member in good standing of the
+Florida Bar and the bar for the U.S. District Court for the Middle District of Florida.
+
+
+• Gase 9:08-cv-
+Document 20 Entered on FLSD Docket 08/
+08 Page 6 of 7
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing Motion for Limited
+Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic
+Filings was served by mail, on _August 6, 2008, on all counsel or parties of record on the service
+list.
+Florida Bar #542075
+be@bradedwardslaw.com
+2028 Harrison Street
+Suite 202
+Hollywood, Florida 33020
+Telephone:
+954-414-8033
+Attorney for Jane Doe # 1 and #2
+
+
+Case 9:08-Cv-E
+Document 20
+Entered on FLSD Docket 08/1
+18 Page 7 of 7
+Case No.: 08-80736
+SERVICE LIST
+Ann Marie C. Villafana
+Assistant U.S. Attorney
+500 South Australian Avenue
+Suite 400
+West Palm Beach, FL 33401
+Dexter Lee
+Assistant U.S. Attorney
+
+
+
+
+Case 9:08-Cv-8
+18 Page 1 of 16
+CASE NO.: 08-80736-CIV-MARRA/JOHNSON
+JANE DOE #1 AND JANE DOE #2,
+Petitioners,
+UNITED STATES OF AMERICA,
+Respondent.
+VICTIMS' RESPONSE TO GOVERNMENT'S "NOTICE TO COURT REGARDING
+ABSENCE OF NEED FOR EVIDENTIARY HEARING" AND MOTION FOR
+PRODUCTION OF NON-PROSECUTION AGREEMENT AND OF REPORT OF
+INTERVIEW
+COME NOW the Petitioners, Jane Doe #1 and Jane Doe #2 (the "victims"), by and
+through their undersigned attorneys to file this Response to the Government's document styled as
+"Notice to Court Regarding Absence of Need for Evidentiary Hearing" as follows:
+INTRODUCTION
+At the conclusion of the oral argument on the victims' petition, victims Jane Doe #1 and
+Jane Doe #2 joined the Government in expressing to the Court a desire to work out a set of
+stipulated facts regarding this case. Towards that end, the Government sent a proposed set of
+stipulated facts to the victims' counsel (Exhibit 1 to this pleading) and, in turn, the victims' sent
+a responsive letter raising concerns about some of the Government's proposed stipulated facts
+and suggesting some additions and modifications (Exhibit 2 to this pleading). The victims also
+requested copies of two relevant documents from the Government: (1) the Non-Prosecution
+1
+
+
+18 Page 2 of 16
+Agreement with defendant Epstein that is at the center of this litigation and (2) the FBI's report
+of interview concerning a meeting with Jane Doe #1. These requests were also made in several
+telephone conversations with the attorney for the Government. Remarkably, rather than respond
+to the victims' suggestions, the Government has now suddenly reversed course and filed a terse
+document claiming an "absence of a need" for an evidentiary hearing. If' anything, however, the
+victims' discussions with the Government have made clear that the Court should not enter
+judgment for the Government but rather should enter immediate judgment for the victims that the
+Government violated their rights under the CVRA. The Court should then schedule a hearing to
+determine the proper remedy for the violation of the victims' rights.
+In particular, the Government now apparently admits that the Non-Prosecution
+Agreement it struck with Epstein in September 2007 contained an "express confidentiality
+provision." See Exhibit 1 to this pleading, Government's Proposed Stipulated Facts, at page 3,
+paragraph 6. Assuming that the Government honored its agreement with the defendant (a fact
+that the victims have proposed to stipulate to), the Government could not have "conferred" with
+the victims about the proposed arrangement over the next nine months because doing so would
+have violated its confidentiality obligations with the defendant. As a result, the Government
+plainly has not afforded the victims' their right to "confer" about the proposed arrangement under
+the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771(a)(5). In addition, the Government
+effectively misled the victims that it had reached a Non-Prosecution Agreement with Epstein,
+plainly violating the victims' rights to be treated with "fairness" under the CVRA, 18 U.S.C.
+§3771(a)(8). The Court should therefore find that the victims' rights have been violated.
+The Court should also order the Government to produce the Non-Prosecution Agreement
+2
+
+
+18 Page 3 of 16
+to the victims. The victims are entitled to know what disposition has been made in their case.
+Moreover, that Agreement purportedly contains provisions pertaining to the civil liability of
+Epstein for crimes he has committed against Jane Doe #1 and Jane Doe #2. Epstein obviously
+knows what those provisions are. The victims are entitled to see those provisions and the
+surrounding document as well.
+The Court should also order the Government to produce a report of interview with Jane
+Doe #1 from about October 26, 2007, during which the Government apparently claims that it
+discussed the plea arrangement with the victims.
+Finally, after these documents are produced to the victims and the Court enters judgment
+that the victims' rights have been violated, the Court should schedule a hearing to determine the
+appropriate remedy for the violations of the victims' rights.
+THE VICTIMS' PROFFERED FACTS
+The Government's latest submission takes the position that "after consideration" it is now
+unnecessary to hold an evidentiary hearing. The Government apparently believes that the Court
+could rule in its favor based on just two submitted undisputed facts. In taking this position, the
+Government apparently believes that there are no set of facts that could sustain judgment for the
+victims. To the contrary, however, the available facts require judgment for the victims that their
+rights under the CVRA have been violated.
+Having attempted to confer with the Government about the facts in this case, counsel for
+the victims respectfully submit the following - and more complete -- set of facts that, on
+information and belief, they could establish if given the opportunity to do so:
+In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of
+3
+
+
+18
+
+Investigation opened an investigation into allegations that Jeffrey Epstein had used facilities of
+interstate commerce to induce young girls between the ages of thirteen and seventeen to engage
+in prostitution (among other offenses). The case was presented to the United States Attorney's
+Office for the Southern District of Florida, which accepted the case for investigation. Jane Doe
+#1 and Jane Doe #2 were victims of sex crimes committed by Epstein while they were minors.
+The U.S. Attorney's Office's investigation soon revealed that Epstein had committed
+federal sex crimes against Jane Doe #1 and Jane Doe #2. This made Jane Doe #1 and Jane Doe
+#2 "victims" protected by the Crime Victim's Rights Act, 18 U.S.C. § 3771. Accordingly, the
+U.S. Attorney's Office arranged to have victim notification letters sent to Jane Doe #1 and Jane
+Doe #2. For example, on about June 7, 2007, Assistant U.S. Attorney A. Marie Villafaña sent a
+letter to Jane Doe #1 that began: "Pursuant to the [CVRA], as a victim and/or witness of a federal
+offense, you have a number of rights." The letter then listed the various rights of victims under
+the CVRA. The U.S. Attorney's Office would not have sent such a letter to Jane Doe #1 if it did
+not believe that she was a victim and was protected by the CVRA.
+By mid-2007, the U.S. Attorney's Office had ample information to file an indictment
+against Epstein charging multiple federal sex offenses. It elected not to file an indictment but
+instead to engage in pre-indictment plea discussions with Epstein.
+In September 2007, Epstein and the U.S. Attorney's Office reached an agreement
+blocking any federal prosecution of the federal offenses he had committed. This Non-
+Prosecution Agreement barred federal charges for Epstein's sex offenses in favor of prosecution
+by Florida, so long as several preconditions were met. Those included a conviction on a state
+sex offense that reflected that the victims were minors at the time the crimes occurred and that
+4
+
+
+Document 19 Entered on FLSD Docket 08/C
+18
+
+would require sex offender registration. While the Agreement barred federal criminal
+prosecution, it envisioned that the victims would pursue a civil rights action against Epstein for
+his sexual offenses against them. Most important for present purposes, the Agreement contained
+an express confidentiality provision, which prevented the Government from disclosing the terms
+of the Agreement to the victims or others before it was consummated. The Agreement was
+subsequently modified in October and December 2007. The Agreement has several addenda that
+are relevant to the Agreement. (To date, although requested to do so, the Government has
+refused to provide to the victims the final Non-Prosecution Agreement or any of its earlier
+versions.) Through his attorneys, Epstein was aware of the confidentiality provision and of the
+fact that it would block the Government from conferring with the victims about the plea
+arrangement.
+On about October 26, 2007, FBI Special Agents E. Nesbitt Kuyrkendall and Jason
+Richards met in person with Jane Doe #1 at a restaurant. The Special Agents explained that there
+had been discussions with Epstein about a possible resolution of the charges against him.
+Consistent with the express confidentiality provision in the Non-Prosecution Agreement, the
+Special Agents did not disclose that the arrangement would bar any federal prosecution of
+Epstein. Nor did the Agents disclose that the Non-Prosecution Agreement had been finalized.
+Jane Doe #1's reasonable perception of the meeting was that only the State part of the Epstein
+investigation had been resolved, and that the federal investigation would continue, possibly
+leading to a federal prosecution. (While the Government has a report of interview regarding this
+meeting with the victim that could confirm the victims' understanding of the facts, the
+Government has refused Jane Doe #1's request to see the report.)
+5
+
+
+18 Page 6 of 16
+Following the signing of the Non-Prosecution Agreement and the modifications thereto
+by the U.S. Attorney's Office for the Southern District of Florida, Epstein received an unusual
+benefit that the Government does not ordinarily provide to other criminal defendants: his
+performance was delayed while he was given an opportunity to seek higher level review within
+the Department of Justice in Washington, D.C.
+On around January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI
+advising them that ")his case is currently under investigation. This can be a lengthy process
+and we request you continued patience while we conduct a thorough investigation." The FBI
+sent these letters, under the direction of the U.S. Attorney's Office, because it believed that the
+CVRA applied to Jane Doe #1 and Jane Doe #2. The FBI did not notify Jane Doe #1 or Jane
+Doe #2 that the Non-Prosecution Agreement had been concluded four months earlier. Jane Doe
+#1 and Jane Doe #2 reasonably understood that a federal criminal investigation of Epstein was
+on-going and that federal criminal charges were possibility. At the time, Jane Doe #1 and Jane
+Doe #2 believed that criminal prosecution of Epstein was extremely important. They also
+desired to be consulted by the FBI and/or other representatives of the federal government about
+the prosecution of Epstein. In light of the letters that they had received around January 10
+(among other things), they reasonably believed that they would be contacted before the federal
+government reached any final resolution of that investigation.
+In the spring 2008, Jane Doe #1 contacted the FBI because Epstein's counsel was
+attempting to take her deposition and private investigators were harassing her. Assistant U.S.
+Attorney A. Marie Villafaña secured pro bono counsel to represent Jane Doe #1 and several other
+identified victims in connection with the criminal investigation. Pro bono counsel was able to
+6
+
+
+18 Page 7 of 16
+assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafaña secured pro bono
+counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in
+Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms.
+Garvin was not advised about the Non-Prosecution Agreement.
+In mid-June 2008, Mr. Edwards contacted Assistant U.S. Attorney Villafaña to inform her
+that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to provide
+information about the federal crimes committed by Epstein, hoping to secure a significant federal
+indictment against Epstein. AUSA Villafaña and Mr. Edwards discussed the possibility of federal
+charges being filed. At the end of the call, AUSA Villafaña asked Mr. Edwards to send any
+information that he wanted considered by the U.S. Attorney's Office in determining whether to
+file federal charges. Because of the confidentiality provision in the Non-Prosecution Agreement,
+Mr. Edwards was not informed of the Agreement's existence. Mr. Edwards was also not
+informed that any resolution of the criminal matter was imminent.
+On July 3, 2008, Mr. Edwards sent to AUSA Villafaña a letter, a true and correct copy of
+which is attached as Exhibit 3. In the letter, Mr. Edwards indicated his desire that federal
+charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients: "We
+urge the Attorney General and our United States Attorney to consider the fundamental import of
+the vigorous enforcement of our Federal laws. We urge you to move forward with the traditional
+indictments and criminal prosecution commensurate with the crimes Mr. Epstein has committed,
+and we further urge you to take the steps necessary to protect our children from this very
+dangerous sexual predator." When Mr. Edwards wrote this letter, he still had not been made
+aware that a Non-Prosecution Agreement had been reached with Epstein.
+7
+
+
+18 Page 8 of 16
+On about July 3, 2008, Jane Doe #1 and Jane Doe #2 learned, through telephones
+conversations had between Mr. Edwards and AUSA Villafaña, that the U.S. Attorney's Office
+and Epstein might be in the process of finalizing some sort of plea arrangement. Accordingly,
+they filed an emergency motion seeking to protect their rights under the CVRA, including in
+particular their right to confer about the proposed plea arrangement.
+Mr. Edwards - and thus his clients -- first learned of the Non-Prosecution Agreement on
+or after July 9, 2008, when the Government filed its responsive pleading to Jane Doe's
+emergency petition. That pleading was the first public mention of the non-prosecution agreement
+and the first disclosure to Mr. Edwards and his clients. Epstein, through his attorneys, knew that
+the victims had not been informed about the plea arrangement.
+On July 9, 2008, AUSA Villafaña sent a victim notification to Jane Doe #l via her
+attorney, Mr. Edwards, which is attached as Exhibit 6 to the Villafaña Declaration. That
+notification contains a written explanation of some of the terms of the Non-Prosecution
+Agreement between Epstein and the U.S. Attorney's Office. A full copy of the terms was not
+provided. This was the first time that Jane Doe #1 was told that the arrangement blocked any
+possibility of federal criminal charges being filed against Epstein. A notification was not
+provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the
+United States was prepared to name in an indictment.
+On July 11, 2008, the Court held a hearing on the victims' emergency motion. During the
+hearing, the Government discussed in open court various provisions of the Non-Prosecution
+Agreement.
+, At the conclusion of the hearing, victims' counsel and the Government agreed to
+8
+
+
+Case 9:08-cv-8:
+Entered on FLSD Docket 08/0
+8 Page 9 of 16
+confer in an effort to determine the undisputed facts of the fact. The Court took the motion under
+advisement.
+On July 16, 2008, the Government sent to Mr. Edwards a proposed set of undisputed
+facts, which is attached to this pleading as Exhibit 1.
+On July 17, 2008, Mr. Edwards sent a response to the Government, which is attached to
+this pleading as Exhibit 2. The response made various suggestions to the proposed undisputed
+facts. The response also requested a copy of the Non-Prosecution Agreement and the Report of
+Interview with Jane Doe #1.
+On July 29, 2008, rather than attempt to work with victims' counsel to draft a set of
+undisputed facts, the Government filed its "Notice to Court Regarding Absence of Need for
+Evidentiary Hearing."
+At all times material to this statement of facts, it would have been easily practical and
+feasible for the Federal Government to inform Jane Doe #1 and Jane Doe #2 of the details of any
+proposed plea agreement with Epstein, including in particular the details of the Non-Prosecution
+Agreement. The reason that AUSA Villafaña and the FBI agents acting with her did not provide
+this information to Jane Doe #1 and Jane Doe #2 was because of the express confidentiality
+provision that had been entered into by the Federal Government and Epstein. This provision
+was requested by Epstein.
+The Government was under no obligation to enter into such an
+arrangement and would have been statutorily forbidden from entering into such an arrangement
+by the CVRA's requirement that it "confer" with the victims about any disposition of their cases.
+9
+
+
+Entered on FLSD Docket 08/01
+3 Page 10 of 16
+THE GOVERNMENT SHOULD BE DIRECTED TO CONFER WITH THE VICTIMS
+REGARDING THE UNDISPUTED FACTS OF THE CASE
+The Government should be directed to confer with the victims about the facts in this case,
+rather than allowed to obscure the facts with its proposed "notice" that an evidentiary hearing is
+unnecessary. The reason that the Government abruptly terminated discussions about the facts
+with the victims seem obvious: The facts, if revealed, would plainly demonstrate that the victims
+did not receive their right under the CVRA to confer with the Government and to be treated
+fairly. The victims will not repeat all of their arguments from their earlier pleadings but would
+simply highlight for the Court the point that this case already reeks of favored treatment for a
+billionaire sex offender who has substantial influence. Regardless of how the Court proceeds, it
+should at least do so on the basis of fully developed factual record so that the victims and the
+public can be assured that justice has been done.
+If anything, the facts in this case now call for immediate judgment in favor of the victims.
+Based on the Government's proposed stipulated facts (Exhibit 1 to this pleading), it is now
+obvious that the Government could not have fulfilled its statutory obligations to confer with the
+victims. As now admitted by the Government, in September 2007, it had entered into a Non-
+Prosecution Agreement with Epstein containing what it describes as "an express confidentiality
+provision." While the Government has refused to disclose the text of this provision (or, indeed,
+the Non-Prosecution Agreement itself, it is apparent that the Government could not have
+conferred with the victims about the Agreement while abiding by the confidentiality provision.
+Likewise it is now apparent that the Government has not fulfilled its statutory obligation
+to treat the victims with fairness. The Government reached the Non-Prosecution Agreement with
+10
+
+
+Entered on FLSD Docket 08/01|
+3 Page 11 of 16
+Epstein in September 2007, yet affirmatively concealed that Agreement from the victims through
+a series of misleading statements and representations over the next nine months. For example,
+on around January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advising
+them that "[t]his case is currently under investigation. This can be a lengthy process and we
+request your continued patience while we conduct a thorough investigation." As the Government
+well knew, however, a Non-Prosecution Agreement had already been reached with Epstein at that
+time - a fact not disclosed in the letter.
+The victims therefore request judgment in their favor that their rights under the CVRA
+have been violated. In the alternative, the victims request that the Court direct that the
+Government confer in good faith with the victims to attempt to reach a set of stipulated facts that
+might form the basis for a final ruling in this case. As part of this conference, the victims request
+that the Government indicate which (if any) of the proposed facts set forth above it disputes.
+THE GOVERNMENT SHOULD BE REQUIRED TO PRODUCE
+THE NON-PROSECUTION AGREEMENT
+Remarkably, the Government has yet to disclose to the victims the very Non-Prosecution
+Agreement that lies at the heart of this case. This failure becomes even more curious when
+assessed against the Government's proposed stipulation of facts, which included the proposed
+fact that the victims had been told about the "full terms" of the Agreement. The proposed
+stipulated facts that the Government sent to the victims included this proposed stipulation:
+On July 9, 2008, AUSA Villafafia sent a victim notification to Jane Doe #1 via her
+attorney, Bradley Edwards, which is attached as Exhibit 6 to the Villafaña
+Declaration. That notification contains a written explanation of the full terms of
+the agreement between Epstein and the U.S. Attorney's Office.
+Contrary to its own proposed stipulation, the Government has never disclosed to the victims the
+11
+
+
+Case 9:08-CV-8(
+Entered on FLSD Docket 08/0*
+3 Page 12 of 16
+"full terms" of its Non-Prosecution Agreement with Epstein. To protect the victims' right to be
+treated with fairness, 18 U.S.C. § 3771(a)(8), it should be required to do so now.
+Congress' main concern in passing the CVRA was that crime victims were "treated as
+non-participants in a critical event in their lives. They were kept in the dark by prosecutors too
+busy to care enough ... and by a court system that simply did not have a place for them." 150
+CoNG. REc. S4262 (Apr. 22, 2004) (statement of Sen. Feinstein). To remedy this problem,
+Congress gave victims "the simple right to know what is going on, to participate in the process
+where the information that victims and their families can provide may be material and relevant...
+•" Id. To date, Jane Doe #1 and Jane Doe #2 do not know what has happened to their case,
+because they have not been told how it has been resolved. Of course, no possible harm to the
+Government can come from the release of the Agreement, as this criminal matter is now
+concluded - at least from the Government's perspective.
+Production of the Non-Prosecution Agreement is also warranted because it has provisions
+in it that are designed to benefit Jane Doe #1 and Jane Doe #2. As described by the Government,
+the Agreement contains provisions in it that preclude Epstein from contesting civil liability for
+the sex offenses committed against a number of the victims, including Jane Doe #1. Obviously,
+Jane Doe #1 cannot take advantage of this provision if her attorneys are not able to review it.
+Jane Doe #1 and Jane Doe #2 intend to file civil suits against Epstein within the next few days.
+Epstein knows what is in the Non-Prosecution Agreement that may be helpful to him. Jane Doe
+#1 and Jane Doe 2 are entitled to see the Agreement for items that may be helpful to them.
+Finally, Epstein is apparently taking advantage of provisions in the Non-Prosecution
+Agreement to stall civil suits against him. For example, in Jane Doe I. Epstein et al., No. 08-
+12
+
+
+Case 9:08-cv-8:
+Entered on FLSD Docket 08/0
+8 Page 13 of 16
+80804-MARRA/JOHNSON (S.D. Fla. 2008), on July 25, 2008, Epstein filed a motion for a stay.
+That motion claims that the civil action is "a counterpart to a pending federal criminal action."
+The basis for that claim, so far as Jane Doe #1 and Jane Doe #2 can tell, is the federal Non-
+Prosecution Agreement. Epstein should not be permitted to use provisions in the Agreement to
+his advantage in private litigation without disclosing those provisions to the parties he is
+opposing. Indeed, as a simple matter of fairness to the victims, see 18 U.S.C. § 3771(a)(5)
+(victims right to "fairness"), the provisions should be disclosed.
+In sum, the Court should direct the Government to reveal to the victims what it has done
+to resolve the case by ordering production of the full Non-Prosecution Agreement and any
+accompanying addenda to the agreement.
+THE GOVERNMENT SHOULD BE REQUIRED TO PRODUCE THE REPORT OF
+INTERVIEW WITH JANE DOE #1
+The Government apparently has a report of interview indicating that two named FBI
+agents met with Jane Doe #1 on about October 26, 2007. The Government, however, has
+declined to produce it.
+The Government should be directed to produce this information to Jane Doe #1. Of
+course, a criminal defendant would be entitled to such a report. See Fed. R. Crim. P. 16(a)(1)(A)
+& (B). As an innocent victim in this matter, Jane Doe #1 should be treated with at least the same
+consideration. See 18 U.S.C. § 3771(a)(8) (victim's right to "be treated with fairness"). Jane
+Doe #1 requested this report in her letter regarding the proposed stipulated facts (see Exhibit 2 to
+this filing), a request that the Government has simply ignored.
+13
+
+
+‹AM Document 19
+Entered on FLSD Docket 08/01
+3 Page 14 of 16
+AFTER ENTERING JUDGMENT FOR THE VICTIMS' ON THE VIOLATION OF THEIR
+RIGHTS, THE COURT SHOULD SCHEDULE A HEARING ON THE APPROPRIATE
+REMEDY
+For the reasons just explained, the Court should enter judgment for Jane Doe #1 and Jane
+Doe #2 on the violations of their rights under the CVRA and order the Government to produce
+the Non-Prosecution Agreement and the report of interview with Jane Doe #1. After doing that,
+the question then arises as to what is the proper remedy for the violations of victims' rights.
+To be clear, at this time, the victims seek two things: (1) a judicial declaration that the
+Government violated their rights under the CVRA and an apology from the Government; and (2)
+a hearing to discuss the appropriate remedy under the circumstances. At the same time, the
+victims are not asking to have any provision in the Non-Prosecution Agreement establishing
+liability in a civil suit to be vacated or declared invalid. Because the possible connection
+between these two things raises complex legal issues, the victims respectfully request that the
+Court order a hearing at which the appropriate remedy can be discussed. The victims also need
+to review the full text of the Non-Prosecution Agreement and any accompanying addenda to
+make an appropriate determination about the remedy that they wish to pursue.
+CONCLUSION
+The Court should find that the Government violated Jane Doe #1 and Jane Doe #2's
+rights under the CVRA to confer and to be treated with fairness during the negotiation and
+consummation of the Non-Prosecution Agreement. In the alternative, the Court should direct the
+Government to confer with the victims regarding what facts are undisputed in this matter and,
+should material facts actually be disputed, hold an evidentiary hearing regarding those facts. So
+that the victims can discuss these matters with the Government, the Court should order the
+14
+
+
+(AM
+Entered on FLSD Docket 08/01.
+
+Government to provide to the victims the full Non-Prosecution Agreement (and accompanying
+addenda) that is central to this litigation as well as a report of interview with Jane Doe #1 from
+about October 26, 2007. The Court should then hold a hearing on the proper remedy for the
+violations of the victims' rights.
+DATED this Ist day of August, 2008.
+Respectfully Submitted,
+THE LAW OFFICE OF BRAD EDWARDS &
+ASSOCIATES, LLC
+By:
+Attorney for Petitioners
+2028 Harrison Street
+Suite 202
+Hollywood, Florida 33020
+Telephone:
+954-414-8033
+E-Mail:
+be@bradedwardslaw.com
+Paul G. Cassell
+Attorney for Petitioners
+Pro Hac Vice
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone:
+801-585-5202
+801-585-6833
+E-Mail:
+cassellp@law.utah.edu
+
+
+Case 9:08-CV-81
+Entered on FLSD Docket 08/0:
+3
+
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on August 1, 2008, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF.
+s/ Brad Edwards_
+SERVICE LIST
+Jane Doe 1 and Jane Doe 2
+Case No.: 08-80736-CIV-MARRA/JOHNSON
+United States District Court, Southern District of Florida
+Dexter A. Lee,
+Assistant U.S. Attorney
+Telephone: 305-961-9320
+305-530-7139
+16
+
+
+Case 9:08-CV-8
+KAM Document 19-2 Entered on FLSD Docket 08.
+J08 Page 1 of 6
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOES #1 and #2
+UNITED STATES
+STIPULATION
+The parties to this action, petitioners Jane Doe #1, Jane Doe #2, and the
+respondent United States of America, by and through their undersigned counsel, do
+hereby stipulate and agree that the following facts are true and correct and that no further
+evidentiary hearing is required with respect to the pending "Victim's Emergency Petition
+for Enforcement of Crime Victim Right Act, 18 U.S.C. § 3771.
+In 2006, at the request of the Palm Beach Police Department, the Federal
+Bureau of Investigation ("FBI") opened an investigation into allegations that Jeffrey
+Epstein ("Epstein") and his personal assistants had used facilities of interstate commerce
+to induce young girls between the ages of thirteen and seventeen to engage in
+prostitution, amongst other offenses. The case was presented to the United States
+Attorney's Office for the Southern District of Florida, which accepted the case for
+investigation.
+
+
+Case 9:08-CV-80
+{AM Document 19-2 Entered on FLSD Docket 08/1
+08 Page 2 of 6
+At the time that the investigation was opened, the Palm Beach County State
+Attorney's Office had presented evidence to a state grand jury, which had returned an
+indictment charging solicitation of prostitution. That charge made no reference to the
+ages of the minor victims and, upon conviction, would not require sex offender
+registration.
+Jane Doe #1 is a woman with initials C.W., and Jane Doe #2 is a woman
+with initials T.M. Both were victims of Epstein's while they were minors beginning when they
+were fifteen years old. Both Jane Does were identified through the Palm Beach Police
+Department's investigation of Epstein.
+4.
+Attached as Exhibits 1, 2, 3, and 4 to the Declaration of A. Marie Villafaña
+are true and correct copies of victim notification letters sent to Jane Does 1 and 2 from
+the United States Attorney's Office and the FBI.
+5.
+Throughout the investigation, the FBI agents and the Assistant U.S.
+Attorney had several meetings with Jane Doe #1. During those meetings, Jane Doe #1
+never expressed a desire to be consulted prior to the resolution of the investigation. Jane
+Doe #2 was represented by counsel and, accordingly, all contact was made through that
+attorney. That attorney never expressed that Jane Doe #2 wanted to be consulted prior to
+the resolution of the investigation.
+In September 2007, Epstein and the U.S. Attorney's Office reached an
+agreement whereby the United States would defer federal prosecution in favor of
+
+
+(AM Document 19-2 Entered on FLSD Docket 08/
+08 Page 3 of 6
+prosecution by the State of Florida, so long as certain basic preconditions were met.
+Those included a conviction on a state sex offense that reflected that the victims were
+minors at the time the crimes occurred and that would require sex offender registration.
+Another key objective for the United States Attorney's Office was to preserve a federal
+remedy for the young girls whom Epstein had sexually exploited. The Agreement
+contained an express
+confidentiality provision. The Agreement was subsequently
+modified in October and December 2007.
+Although individual victims were not consulted regarding the agreement,
+several had expressed concerns regarding the exposure of their identities at trial and they
+desired a prompt resolution of the matter. At the time the agreement and the
+modifications were signed in September, October, and December 2007, Jane Doe #2 was
+openly hostile to the prosecution of Epstein.
+In October 2007, shortly after the initial agreement was signed, Jane Doe
+#1 was contacted to be advised regarding the resolution of the investigation. On October
+26, 2007, Special Agents E. Nesbitt Kuyrkendall and Jason Richards met in person with
+Jane Doe #1. The Special Agents explained that the investigation had been resolved, that
+Epstein would plead guilty to state charges, he would be required to register as a sex
+offender for life, and he had made certain concessions related to the payment of damages
+to the victims, including Jane Doe #1. During this meeting, Jane Doe #1 did not raise any
+objections to the resolution of the matter,
+
+
+<AM Document 19-2 Entered on FLSD Docket 08/
+08 Page 4 of 6
+9.
+Jane Doe #I's perception of the explanation provided by the Special Agents
+was that only the State part of the Epstein investigation had been resolved, and that the
+federal investigation would continue, possibly leading to a federal prosecution.
+10.
+When Epstein's attorneys learned that some of the victims had been
+notified, they complained that the victims were receiving an incentive to overstate their
+involvement with Epstein in order to increase their damages claims. Following the
+signing of the Agreement and the modifications thereto, Epstein's performance was
+delayed while he sought higher level review within the Department of Justice.
+Throughout that period, the FBI and the U.S. Attorney's Office maintained contact with
+the victims, to be prepared if Epstein were to renege on the agreement.
+11.
+After Jane Doe #1 had been notified of the terms of the agreement, but
+before Epstein performed his obligations, Jane Doe #1 contacted the FBI because
+Epstein's counsel was attempting to take her deposition and private investigators were
+harassing her. Assistant U.S. Attorney A. Marie Villafaña secured pro bono counsel to
+represent Jane Doe #1 and several other identified victims in connection with the criminal
+investigation. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper
+deposition.
+12.
+In mid-June 2008, Attorney Edwards contacted AUSA Villafaña to inform
+her that he represented Jane Doe #1 and, later, Jane Doe #2. Attorney Edwards asked to
+
+
+KAM Document 19-2 Entered on FLSD Docket 08/
+108 Page 5 of 6
+meet to provide information regarding Epstein. Attorney Edwards was asked to send any
+information that he wanted considered, but did not send anything.
+13.
+On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA Villafaña
+received a copy of Epstein's proposed state plea agreement and learned that the plea was
+scheduled for 8:30 a.m., Monday, June 30, 2008. AUSA Villafaña and the Palm Beach
+Police Department attempted to provide notification to victims in the short time that
+Epstein's counsel had provided. Attorney Edwards was called to provide notice to his
+clients regarding the hearing
+14.
+On July 9, 2008, AUSA Villafaña sent a victim notification to Jane Doe #1
+via her attorney, Bradley Edwards, which is attached as Exhibit 6 to the Villafaña
+Declaration. That notification contains a written explanation of the full terms of the
+agreement between Epstein and the U.S. Attorney's Office. A notification was not
+provided to Jane Doe #2 because the agreement limited Epstein's liability to victims
+whom the United States was prepared to name in an indictment.
+SO STIPULATED AND AGREED.
+Dated:
+2
+BRADLEY EDWARDS, ESQ.
+Attorney for Petitioners Jane Does #1 &
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+
+
+Case 9:08-cv-8l
+KAM Document 19-2
+Entered on FLSD Docket 08.
+108 Page 6 of 6
+Dated:
+LEE
+By:
+ASSISTANT U.S. ATTORNEY DEXTER
+Attorney for Respondent United States
+
+
+Document 19-3 A wEared 88 FLSD Docket 08,
+(Brad Ecuaints
+AND ASSOCIATES
+108 Page 1 of 7
+July 17, 2008
+Ann Marie C. Villafaña, AUSA
+500 South Australian Avenue
+West Palm Beach, Florida 33401
+Re: Proposed Stipulated Facts for In Re Jane Doe
+Dear Ms. Villafafia:
+Thank you for your recent proposed stipulation of facts in this case. I believe that we
+have considerable common ground. At the same time, however, it appears to me that a few areas
+of potential disagreement are arising. In view of that, and to avoid any misunderstandings, I
+thought it might be useful to send a short letter outlining several requests and issues for
+resolution before I send you back my proposed stipulated facts.
+I am working with two other attorneys on this case - Jay Howell in Jacksonville,
+Florida, and Professor Paul Cassell in Salt Lake City, Utah. Because they were not in court for
+the hearing last Friday, they will need to review a transcript of the hearing before our legal team
+can agree to any stipulated facts. I have requested a transcript, but the preparation of it will
+apparently take several weeks. Do you have any way of expediting the preparation of the
+Government's responsibility to use its "best efforts to see that crime victims are ... accorded]
+the rights" in the CVRA, 18 U.S.C. § 3771(c)(1), I was wondering whether the Government
+would' be willing to pay for the transcript.
+Your proposed stipulation indicates that in September 2007 the U.S. Attorney's
+Office reached an agreement with Epstein to resolve the case, which was then modified in
+October and December of that year, While this seems plausible, to stipulate to the facts, I would
+obviously need to see copies of those three agreements. Moreover, because the circumstances
+surrounding the initial agreement and its later modification are now the subject of litigation, my
+client is entitled to see them. See 18 U.S.C. § 3771(a)(8) (victim's right to "be treated with
+fairness"). In addition, your proposed stipulation states that: "On July 9, 2008, AUSA Villafaña
+sent a victim notification to Jane Doe #1 via her attorney, Bradley Edwards, which is attached as
+Exhibit 6 to the Villafaña Declaration. That notification contains a written explanation of the full
+terms of the agreement between Epstein and the U.S. Attorney's Office." I am puzzled by this
+proposed stipulation, as your July 9 letter explicitly noted that it was covering only some of the
+provisions in the agreement. Perhaps the fact that I have not yet received the agreement is all
+just an oversight on your part, and you had intended to give me the "full terms" of the plea
+agreement that was ultimately reached. In any event, the simplest way to proceed at this point is
+for the plea agreement - and the earlier versions - to be provided to me so that I can review
+2028 HARRISON STREET, SUITE 202, HOLLYWOOD, FLORIDA 33020
+BE@BRADEDWARDSLAW COM
+
+
+Entered on FLSD Docket OE
+008 Page 2 of 7
+Ann Marie C. Villafaña, AUSA
+Page 2
+them with my clients. Of course, no possible harm to the Government can come from the release
+of the documents, as this criminal matter is now concluded - at least from the Government's
+perspective.
+I am wondering about your position on the confidentiality provision in the
+agreement. As I understand things from your proposed stipulation, in September 2007 you
+"reached" an agreement with Epstein's attorneys that "contained an express confidentiality
+provision." Are you taking the position that this "express" provision barred disclosure of the
+substance of the agreement to my clients? And, if so, would you stipulate that the FBI agents
+and your office complied with the provision up through June 30 when, I assume, the confidential
+provision expired as Epstein entered his guilty plea in open court?
+4. Your proposed stipulation indicates:
+On October 26, 2007, Special Agents E. Nesbitt Kuyrkendall and Jason Richards
+met in person with Jane Doe #1. The Special Agents explained that the
+investigation had been resolved, that Epstein would plead guilty to state charges,
+he would be required to register as a sex offender for life, and he had made certain
+concessions related to the payment of damages to the victims, including Jane Doe
+#1. During this meeting, Jane Doe #1 did not raise any objections to the
+resolution of the matter.
+From the drafting of this proposed stipulation, it appears that you may be working from a Report
+of Interview with my client (i.e., an FBI 302). My client has a differing recollection of some
+aspects of that meeting. Of course, she did not take notes of the meeting. Therefore, I ask that
+you provide me (the relevant parts of) any report of this meeting as well as reports of any other
+meetings relevant to the matters at hand.
+I believe that my client is entitled to a copy of (the relevant parts of) the reports of
+treated with fairness").
+I am hoping that the Special Agents' and my client's recollections about one point
+if the October 26"
+rederal prosecution for thing mes at end. is a in on are reare biked al
+2028 HARRISON STREET, SUITE 202, HOLLYWOOD, FLORIDA 33020
+BE@BRADEDWARDBLAW.COM
+
+
+KAM Document 19-3
+108 Page 3 of 7
+Ann Marie C. Villafaña, AUSA
+You mention your assistance in securing pro bono counsel for Jane Doe #1 to help
+revent harassment. I trust that you would be willing to stipulate that you did not mention th
+ederal non-prosecution agreement to this counsel and that you did not mention that a ple
+agreement had already been reached. Professor Cassell has spoken to Meg Garvin, Esq., at the
+National Crime Victims' Law Institute, and that is her recollection of the events.
+I think that your proposed stipulation regarding my contact with the office is
+somewhat abbreviated. I wonder what you would think about the following:
+In mid-June 2008, Mr. Edwards contacted AUSA Villafaña to inform her
+that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to
+meet to provide information about the federal crimes committed by Epstein,
+hoping to secure a significant federal indictment against Epstein. AUSA
+Villafaña and Mr. Edwards discussed the possibility of federal charges being
+filed. At the end of the call, AUSA Villafaña asked Mr. Edwards to send any
+information that he wanted
+considered by the U.S. Attorney's Office in
+determining whether to file federal charges. Because of the confidentiality
+provision that existed in the plea agreement, Mr. Edwards was not informed that,
+in September 2007, the U.S. Attorney's Office had reached an agreement not to
+file federal charges. Mr. Edwards was also not informed that any resolution of the
+criminal matter was imminent.
+On July 3, 2008, Mr. Edwards sent to AUSA Villafaña a letter, a true and
+correct copy of which is attached. In the letter, Mr. Edwards indicated his desire
+that federal charges be filed against defendant Epstein. In particular, he wrote on
+behalf of his clients: "We urge the Attorney General and our United States
+Attorney to consider the fundamental import of the vigorous enforcement of our
+Federal laws. We urge you to move forward with the traditional indictments and
+criminal prosecution commensurate with the crimes Mr. Epstein has committed,
+and we further urge you to take the steps necessary to protect our children from
+this very dangerous sexual predator." When Mr. Edwards wrote this letter, he
+was still unaware that a non-prosecution agreement had been reached with
+Epstein. Mr. Edwards first learned of this fact on or after July 9, 2008, when the
+Government filed its responsive pleading to Jane Doe's emergency petition. That
+pleading was the first public mention of the non-prosecution agreement and the
+first disclosure to Mr. Edwards and his clients.
+I trust that you will agree that the Government had probable cause to file a
+multiple count federal indictment against Epstein, including an indictment charging crimes
+2028 HARRISON STREET, SUITE 202, HOLLYWOOD, FLORIDA 33020
+
+
+Case 9:08-cv-8(
+KAM Document 19-3
+Entered on FLSD Docket 08,
+108 Page 4 of 7
+Ann Marie C. Villafaña, AUSA
+Page 4
+against Jane Doe #1 and Jane Doe 2. In asking for this stipulation, I realize that you have taken
+2227
+Finally, in light of the fact that you have been sending letters to Jane Doe #2,
+which was obviously done because you believed her to be a "victim" in this case, and since she
+has been added in this matter as a victim, we would like some assurances that she will be
+protected, as the other victims have been, in your agreement with Mr. Epstein.
+Thank you very much for considering these issues and concerns. I look forward to
+vorking with you to reach a stipulation that covers as much common ground as possible in thi
+ase. If you think that further discussions might be helpful, I would like to try and set up
+conference call with you and my co-counsel to discuss these issues further.
+Sincerely,
+BaRe
+Brad Edwards
+BE/sg
+Enclosure
+cc:
+
+
+•KAM
+LAW OFFICE
+008 Page 5 of 7
+AND ASSOCIATES
+July 3, 2008
+Ann Marie C. Villafana, AUSA
+500 South Australian Avenue
+West Palm Beach, Florida 33401
+Dear Ms. Villafana:
+VIA CERTIFIED MAIL
+RETURN RECEIPT REQUESTED
+7007 2680 0002 5519 8503
+As you are aware, we represent several of the young girls that were victimized
+and abused by Jeffrey Epstein. While we are aware of his recent guilty plea and
+conviction in his State Court case, the sentence imposed in that case is grossly inadequate
+for a sexual predator of this magnitude. The information and evidence that has come to
+our attention in this matter leads to a grave concern that justice will not be served in this
+cause if Mr. Epstein is not aggressively prosecuted and appropriately punished. Based on
+our investigation and knowledge of this case, it is apparent that he has sexually abused
+more than 100 underage girls, and the evidence against him is overwhelmingly strong.
+As former Assistant State Attorneys with seven years' prosecution experience, we
+believe that the evidence against Mr. Epstein is both credible and deep and that he may
+be the most dangerous sexual predator of children that our country has ever seen. The
+evidence suggests that for at least 4 years he was sexually abusing as many as three to
+four girls a day. It is inevitable that if he is not confined to prison, he will continue to
+manipulate and sexually abuse children and destroy more lives. He is a sexual addict that
+focused all of his free time on sexually abusing children, and he uses his extraordinary
+wealth and power to lure in poor, underprivileged little girls and then also uses his wealth
+to shield himself from prosecution and liability. We are very concerned for the health
+and welfare of the girls he has already victimized, and concerned that if justice is not
+properly served now and he is not imprisoned for a very long time, he will get a free pass
+to sexually abuse children in the future. Future abuse and victimization is obvious to
+anyone who really reviews the evidence in this case, and future sexual abuse of minors is
+inevitable unless he is prosecuted, tried and appropriately sentenced. Money and power
+should not allow a man to make his own laws, and he has clearly received preferential
+treatment at every step up to this point. If he were a man of average wealth or the abused
+girls were from middle or upper class families, then this man would spend the rest of his
+life in prison. In a country of true, blind justice, those distinctions are irrelevant, and we
+really hope he does not prove the point that a man can commit heinous crimes against
+children and buy his way out of it.
+If the Department of Justice's recent commitment to the protection of our children
+from child molesters is to be more than rhetoric, then this is the time and the case where
+the Department must step forward. We urge the Attorney General and our United States
+2028 HARRISON STREET, SUITE 202, HOLLYWOOD, FLORIDA 33020
+
+
+Case 9:08-cv-8(
+Entered on FLSD Docket 08.
+J08 Page 6 of 7
+Ann Marie C. Villafana, AUSA
+Page Two
+Attorney to consider the fundamental import of the vigorous enforcement of our Federal
+sexual perpetrator. We will help you to do this in any way possible to ensure that true
+Justice is served in this case.
+Sincerely,
+Jay Howell, Esquire
+2028 HARRISON STREET, SUITE 202, HOLLYWOOD, FLORIDA 33020
+OFFIGI: 954-414-8033/305-935-2011
+
+
+Case 9:08-cv-81
+Entered on FLSD Docket 08.
+108 Page 7 of 7
+SENDER: COMPLETE THIS SECTION
+• Complete Items 1,2, and 3. Also complate
+Item 4 if Restricted Dellvery Is desired.
+• Print your name and address on the reverse
+so that we can-return the card to you.
+• Attach this card to the back of the mallplece,
+or on the front if space permits.
+1. Article Addressed to:
+COMPLETE THIS SECTION ON DELIVERY
+A-SI
+X(
+TO Agent
+i mur #D Addreasee
+C. Baterof Delivery
+77/08
+D. Is delvery address different from tam 17
+I/YES, enter delivery address below:
+• No
+Ann Marie C. Villafana, AUSA
+500 South Australian Avenue
+West Palm Beach, Florida. 33401
+2, Article Number : :
+(Tansfer from service label)
+PS Form 3811, February 2004
+• Beguise Typ
+Certified M
+• Express Mall
+• Retum Recalpt for Merchandise
+• Insured Mail
+=O C.O.D.
+4. Restricted Delivery? (Extra Fes)
+• Yes 3
+7007 2680 0002 5519 8503
+Domestic Retum Recept
+102595-02-M-1540
+2000
+0992
+2002
+U.S. Postal Service.
+CERTIFIED MAIL RECEIPT
+(Domestic Mail Only; No Insurance Coverage Provided)
+For delivery information visit our website at www.usps.com
+OFFICIAL USE
+Postage
+$
+Certifled Foo
+Total Postage & Faes
+Sent To
+3a. 22N6:"
+or PU Box No.
+Chy Stato, 2947
+PS Form 3000, August 200G
+So Roverso for Instructions
+
+
+'Case 9:08-cv-8l
+KAM Document 19-4
+Entered on FLSD Docket 08,
+- LAW OFFICE•
+108 Page 1 of 2
+AND ASSOCIATES
+July 3, 2008
+Ann Marie C. Villafana, AUSA
+500 South Australian Avenue
+West Palm Beach, Florida 33401
+Dear Ms. Villafana:
+VIA CERTIFIED MAIL
+RETURN RECEIPT REQUESTED
+7007 2680 0002 5519 8503
+As you are aware, we represent several of the young girls that were victimized
+and abused by Jeffrey Epstein. While we are aware of his recent guilty plea and
+conviction in his State Court case, the sentence imposed in that case is grossly inadequate
+for a sexual predator of this magnitude. The information and evidence that has come to.
+our attention in this matter leads to a grave concern that justice will not be served in this
+cause if Mr. Epstein is not aggressively prosecuted and appropriately punished. Based on
+our investigation and knowledge of this case, it is apparent that he has sexually abused
+more than 100 underage girls, and the evidence against him is overwhelmingly strong.
+As former Assistant State Attorneys with seven years' prosecution experience, we
+believe that the evidence against Mr. Epstein is both credible and deep and that he may
+be the most dangerous sexual predator of children that our country has ever seen. The
+evidence suggests, that for at least 4 years he was sexually abusing as many as three to
+four girls a day. It is inevitable that if he is not confined to prison, he will continue to
+manipulate and sexually abuse children and destroy more lives. He is a sexual addict that
+focused all of his free time on sexually abusing children, and he uses his extraordinary
+wealth and power to lure in poor, underprivileged little girls and then also uses his wealth
+to shield himself from prosecution and liability. We are very concerned for the health
+and welfare of the girls he has already victimized, and concerned that if justice is not
+properly served now and he is not imprisoned for a very long time, he will get a free pass
+to sexually abuse children in the future. Future abuse and victimization is obvious to
+treatment at every step up to this point. If he were a man of average wealth or the abused
+girls were from middle or upper class families, then this man would spend the rest of his
+life in prison. In a country of true, blind justice, those distinctions are irrelevant, and we
+really hope he does not prove the point that a man can commit heinous crimes against
+children and buy his way out of it.
+If the Department of Justice's recent commitment to the protection of our children
+from child molesters is to be more than rhetoric, then this is the time and the case where
+the Department must step forward. We urge the Attorney General and our United States
+2028 HARRISON STREET, SUITE 202, HOLLYWOOD, FLORIDA 33020
+BEBRADEDWARDSLAW dOM
+
+
+-KAM Document 19-4
+308
+
+Ann Marie C. Villafana, AUSA
+United States Attorney's Office.
+Page Two
+Attorney to consider the fundamental import of the vigorous enforcement of our Federal
+laws, We urge you to move forward with the traditional indictments and criminal
+prosecution commensurate with the crimes Mr, Epstein has committed, and we further
+urge you to take the steps necessary to protect our children from this very dangerous
+sexual perpetrator. We will help you to do this in any way possible to ensure that true
+Justice is served in this case.
+Sincerely,
+Jay Howell, Esquire
+2028 HARRISON STREET, SUITE 202, HOLLYWOOD, FLORIDA 33020
+OFFIGE: 954-414-8033/30-935-2011
+FAX:
+954-924-1530/305-935-4227
+BEФBRADEDWARDBLAW.GOM
+
+
+TENDER
+
+
+-KAM Document 17
+Entered on FLSD Docket 07/2
+18 Page 1 of 3
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOES #1 and #2
+Petitioners,
+I.
+UNITED STATES
+Respondent.
+GOVERNMENT'S NOTICE TO COURT REGARDING
+ABSENCE OF NEED FOR EVIDENTIARY HEARING
+Respondent United States, by and through its undersigned counsel, files its Notice to
+Court Regarding Absence of Need for Evidentiary Hearing, and states:
+1. At the conclusion of the hearing held on July 11, 2008, the Court asked the parties
+whether an evidentiary hearing would be necessary.
+The Government suggested that the parties
+confer, and determine whether such a hearing should be held.
+2. After consideration, the Government believes that an evidentiary hearing is not
+necessary. The precise issue before the Court is whether the Government was obligated, under
+18 U.S.C. § 3771(a)(5), to confer with petitioners prior to entering into an agreement with
+Jeffrey Epstein, which permitted the pending State of Florida prosecution to go forward, so long
+as Epstein agreed to certain conditions.
+3. The Government believes there are two relevant facts which will permit the Court to
+resolve the legal issue: (1) there are no criminal charges in the United States District Court,
+Southern District of Florida, filed against Jeffrey Epstein; and (2) Epstein entered pleas of guilty
+
+
+i-KAM Document 17 Entered on FLSD Docket 07/:
+08 Page 2 of 3
+in Florida State Court on June 30, 2008, was sentenced, and is now imprisoned in Palm Beach
+County. The Government believes the absence of any charges in the Southern District of
+Florida can be judicially noticed pursuant to Fed.R.Evid. 201(b), because such information is
+either generally known within the territorial jurisdiction of the trial court, or, is capable of
+accurate and ready determination by resort to sources whose accuracy cannot reasonably be
+questioned. Cash Inn of Dade, Inc. | . Metropolitan Dade County, 938 F.2d 1239, 1243 (11"
+Cir. 1991)("A district court may take judicial notice of public records within its files relating to
+the particular case before it or related cases.") (citation omitted).
+Under the same rationale, the
+absence of such files can also be judicially noticed
+Epstein's convictions in State court can be
+established by public record documents, which the Government will file with this Court.
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+Fla. Bar No. 0936693
+99 N.E. 4" Street
+(305) 961-9320
+Fax: (305) 530-7139
+E-mail: dexter.lee@usdoj.gov
+2
+
+
+Case 9:08-Cv-E
+-KAM Document 17
+Entered on FLSD Docket 07/:
+38 Page 3 of 3
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on July 29, 2008, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF.
+_ s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+SERVICE LIST
+Jane Does 1 and 2 . United States,
+Case No. 08-80736-CIV-MARRA/JOHNSON
+United States District Court, Southern District of Florida
+Brad Edwards, Esq.,
+The lario seEs sule vards & Associates, LIC
+Hollywood, Florida 33020
+3
+
+
+
+
+Document 16 Entered on FLSD Docket 071.
+08 Page 1 of 7
+L
+FILING FEE
+"95.00
+-orma
+
+soris leven M. Larimare, Clerk
+In re: Jane Doe, et al.
+Petitioners.
+Case No.: 08-80736-Civ-MARRA/JOHNSON
+FILED by 1123 D.c.
+JUL 2 8 2008
+TENDS ARMO
+D. OF FLA. - W.P
+MOTION FOR LIMITED APPEARANCE, CONSENT TO
+DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE
+NOTICES OF ELECTRONIC FILING
+In accordance with Local Rules 4.B of the Special Rules Governing the Admission and
+Practice of Attorneys of the United States District Court for the Southern District of Florida, the
+undersigned respectfully moves for the admission of Paul G. Cassell, Esquire, for purposes of limited
+appearance as co-counsel on behalf of Jane Does #1 and #2, herein, in the above-styled case only,
+and pursuant to Rule 2B, Southern District of Florida, CM/ECF Administrative Procedures, to permit
+Paul G. Cassell to receive electronic filings in this case, and in support thereof states as follows:
+While Paul G. Cassell Esquire, is not admitted to practice in the Southern District
+of Florida, he is a member in good standing of the Utah State Bar and the bar of the U.S. District
+Court for the District of Utah.
+2.
+Movant, Brad Edwards, Esquire, of the law firm of The Law Offices of Brad Edwards
+& Associates, is a member in good standing of the The Florida Bar and the United States District
+Court for the Southern District of Florida, maintains an office in this State for the practice of law,
+and will shortly be filing the appropriate application to be authorized to file through the Court's
+electronic filing system. Movant consents to be designated as a member of the Bar of this Court with
+whom the Court and opposing counsel may readily communicate regarding the conduct of the case,
+
+
+Document 16 Entered on FLSD Docket 071:
+08 Page 2 of 7
+upon whom filings shall be served, who shall be required to electronically file all documents and
+things that may be filed electronically, and who shall be responsible for filing documents in
+compliance with the CM/ECF Administrative Procedures. See Section 2B of the CM/ECF
+Administrative Procedures.
+3.
+In accordance with the local rules of this Court, Paul G. Cassell, Esquire, has made
+payment (enclosed) of this Court's $75 admission fee. A certification in accordance with Rule 4B
+is attached hereto.
+4.
+Paul G. Cassell, Esquire, by and through designated counsel and pursuant to Section
+2B, Southern District of Florida, CM/ECF Administrative Procedures, hereby requests the Court to
+provide Notice of Electronic Filings to Paul G. Cassell, Esquire, at email address:
+cassellp/@law.utah.edu.
+WHEREFORE, Brad Edwards, Esquire, moves this Court to enter an Order permitting Paul
+G. Cassell to appear before this Court on behalf of Jane Doe, for all purposes relating to the
+proceedings in the above-styled matter and directing the Clerk to provide notice of electronic filings
+to Paul G. Cassell.
+Date: July 24, 2008.
+Respectfully submitted,
+Florida Bar #542075
+be@bradedwardslaw.com
+2028 Harrison Street
+Suite 202
+Hollywood, Florida 33020
+Telephone:
+954-414-8033
+
+
+18 Page 3 of 7
+CERTIFICATE OF SERVICE
+1 HEREBY CERTIFY that a true and correct copy of the foregoing Motion for Limited
+Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic
+Filings was served by mail, on _July 24, 2008, on all counsel or parties of record on the service
+list
+
+
+Entered on FLSD Docket 07,
+108
+
+Case No.: 08-80736
+SERVICE LIST
+Ann Marie C. Villafana
+Assistant U.S. Attorney
+500 South Australian Avenue
+West Palm Beach, FL 33401
+Dexter Lee
+Assistant U.S. Attorney
+
+
+• Case 9:08-CV-E
+18
+
+Case No.: 08-80736
+In re: Jane Doe, et al.
+Petitioners.
+CERTIFICATION OF PAUL G. CASSEL, ESQ.
+Paul G. Cassell, Esquire, pursuant to Rule 4B of the Special Rules Governing the Admission
+and Practice of Attorneys, hereby certifies that (1) I have studied the Local Rules of the United States
+District Court for the Southern District of Florida; and (2) I am a member in good standing of the
+Utah Bar and the bar for the U.S. District Court for the District of Utah.
+assell, Esquire
+
+
+Document 16 Entered on FLSD Docket 07,
+J08 Page 6 of 7
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing Motion for Limited
+Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic
+Filings was served by mail, on July 24, 2008
+_ on all counsel or parties of record on the service
+list.
+sas
+Florida Bar #542075
+be@bradedwardslaw.com
+2028 Harrison Street
+Suite 202
+Hollywood, Florida
+33020
+Telephone:
+954-414-8033
+
+
+Case 9:08-Cv-
+Entered on FLSD Docket 071.
+J08 Page 7 of 7
+Case No.: 08-80736
+SERVICE LIST
+Ann Marie C. Villafana
+Assistant U.S. Attorney
+500 South Australian Avenue
+Suite 400
+West Palm Beach, FL 33401
+Dexter Lee
+Assistant U.S. Attorney
+
+
+HITE-FIN
+
+
+-KAM Document 15
+Entered on FLSD Docket 0714
+tePage 10t2
+IN RE: JANE DOE,
+Plaintiff,
+vS.
+UNITED STATES OF AMERICA,
+Defendant.
+1
+THE UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA FILED.by
+CASE NO.
+08-80736-CIV-MARRA
+- D.C.
+JUL 17 2008
+STEVEN M. LARIMORE
+CLERK US DIST CT
+S. D. of FLA: - MIAMI
+ORIGINAL
+JUL 18/2008
+STEVEN M. LARIMOR
+CLERK U.S. DIST. C
+S. D. Of FLA - MIAMI
+Federal Courthouse
+west Palm Beach, Florida
+July 11, 2008
+10:15 a.m.
+The above entitled matter came on for
+Emergency Petitioner for Enforcement of Crime Victim
+Rights before the Honorable Kenneth A. Marra,
+pursuant to Notice, taken before Victoria Aiello,
+Court Reporter, pages 1-32.
+For the Plaintiff: Bradley Edwards, Esquire
+For the Defendant: Dexter Lee, AUSA
+Maria Villafana, AUSA
+OFFICIAL REPO
+NG SERVICES, LLC (954) -8204
+
+
+i-KAM Document 15
+UNITED STATES DISTRICT CUURT
+18
+
+ATTACHMENT(S) NOT SCANNED
+PLEASE REFER TO COURT FILE
+MAINTAINED IN THE OFFICE WHERE THE
+JUDGE IS CHAMBERED
+CASE NO. 08-80736-CV KAM
+DE#
+• DUE TO POOR QUALITY, THE ATTACHED
+DOCUMENT IS NOT SCANNED
+• VOLUMINOUS (exceeds 999 pages = 4 inches)
+consisting of (boxes, notebooks, etc.)
+• BOUND EXTRADITION PAPERS
+• ADMINISTRATIVE RECORD (Social Security)
+• ORIGINAL BANKRUPTCY TRANSCRIPT
+• STATE COURT RECORD (Habeas Cases)
+X SOUTHERN DISTRICT TRANSCRIPTS
+O LEGAL SIZE
+• DOUBLE SIDED
+• PHOTOGRAPHS
+O POOR QUALITY (e.g. light print, dark print, etc.)
+• SURETY BOND (original or letter of undertaking)
+• CD's, DVD's, VHS Tapes, Cassette Tapes
+• OTHER =
+
+
+DUCER TO
+
+
+-KAM Document 14
+8 Page 1 of 21
+Case No. 08-80736-Civ-Marra/Johnson
+[FILED by 113
+- D.C.
+JUL 0 9 2008
+IN RE: JANE DOE,
+Petitioner.
+DECLARATION OF A. MARIE VILLAFAÑA
+IN SUPPORT OF UNITED STATES' RESPONSE
+TO VICTIM'S EMERGENCY PETITION FOR ENFORCEMENT
+OF CRIME VICTIM RIGHTS ACT, 18 U.S.C. § 3771
+1, A. Marie Villafaña, do hereby declare that 1 am a member in good standing
+of the Bar of the State of Florida. I graduated from the University of California at Berkeley
+School of Law (Boalt Hall) in 1993. After serving as a judicial clerk to the Hon. David F.
+Levi in Sacramento, California, I was admitted to practice in California in 1995. I also am
+admitted to practice in all courts of the states of Minnesota and Florida, the Eighth, Eleventh,
+and Federal Circuit Courts of Appeals, and the U.S. District Courts for the Southern District
+of Florida, the District of Minnesota, and the Northern District of California. My bar
+admission status in California and Minnesota is currently inactive. I am currently employed
+as an Assistant United States Attorney in the Southern District of Florida and was so
+employed during all of the events described herein.
+
+
+18 Page 2 of 21
+2.
+I am the Assistant United States Attorney assigned to the investigation of
+Jeffrey Epstein. The case was investigated by the Federal Bureau of Investigation ("FBI").
+The federal investigation was initiated in 2006 at the request of the Palm Beach Police
+Department ("PBPD"') into allegations that Jeffrey Epstein and his personal assistants had
+used facilities of interstate commerce to induce young girls between the ages of thirteen and
+seventeen to engage in prostitution, amongst other offenses.
+Throughout the investigation, when a victim was identified, victim notification
+letters were provided to her both from your Affiant and from the FBI's Victim-Witness
+Specialist. Attached hereto are copies of the letters provided to Bradley Edwards' three
+clients, T.M., C. W., and S.R.' Your Affiant's letter to C. W. was provided by the FBI. (Ex.
+1). Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she
+was interviewed (Ex. 2).? Both C. W. and T.M. also received letters from the FBI's Victim-
+Witness Specialist, which were sent on January 10, 2008 (Exs. 3 & 4). S.R. was identified
+via the FBl's investigation in 2007, but she initially refused to speak with investigators.
+S.R.'s status as a victim of a federal offense was confirmed when she was interviewed by
+'Attorney Edwards filed his Motion on behalf of "Jane Doe," without identifying which of
+his clients is the purported vietim. Accordingly, I will address facts related to C.W., T.M., and S.R.
+All three of those clients were victims of Jeffrey Epstein's while they were minors beginning when
+they were fifteen years old
+¿Please note that the dates on the U.S. Attorney's Office letters to C. W. and T.M. are not the
+dates that the letters were actually delivered. Letters to all known victims were prepared early in the
+investigation and delivered as each victim was contacted.
+-2-
+
+
+8 Page 3 of 21
+federal agents on May 28, 2008. The FBI's Victim-Witness Specialist sent a letter to S.R.
+on May 30, 2008 (Ex. 5).
+Throughout the investigation, the FBI agents, the FBI's Victim-Witness
+Specialist, and your Affiant had contact with C. W. and S.R. Attorney Edwards' other client,
+T.M., was represented by counsel and, accordingly, all contact with T.M. was made through
+that attorney. That attorney was James Eisenberg, and his fees were paid by Jeffrey Epstein,
+the target of the investigation.?
+In the summer of 2007, Mr. Epstein and the U.S. Attorney's Office for the
+Southern District of Florida ("the Office") entered into negotiations to resolve the
+investigation. At that time, Mr. Epstein had been charged by the State of Florida with
+solicitation of prostitution, in violation of Florida Statutes § 796.07. Mr. Epstein's attorneys
+sought a global resolution of the matter. The United States subsequently agreed to defer
+federal prosecution in favor of prosecution by the State of Florida, so long as certain basic
+preconditions were met. One of the key objectives for the Government was to preserve a
+federal remedy for the young girls whom Epstein had sexually exploited. Thus, one
+condition of that agreement, notice of which was provided to the victims on July 9, 2008. is
+the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+'The undersigned does not know when Mr. Edwards began representing T.M. or whether
+T.M. ever formally terminated Mr. Eisenberg's representation.
+- 3-
+
+
+Entered on FLSD Docket 07/:
+08 Page 4 of 21
+had been tried federally and convicted of an enumerated offense. For purposes
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+thority interpreting this provision, including any authority determinir
+hich evidentiary burdens if any a plaintiff must meet, shall consider that it
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+6.
+An agreement was reached in September 2007. The Agreement contained an
+express confidentiality provision.
+Although individual victims were not consulted regarding the agreement,
+several had expressed concerns regarding the exposure of their identities at trial and they
+desired a prompt resolution of the matter. At the time the agreement was signed in
+September 2007, T.M. was openly hostile to the prosecution of Epstein. The FBI attempted
+to interview S.R. in October 2007, at which time she refused to provide any information
+regarding Jeffrey Epstein. None of Attorney Edwards' clients had expressed a desire to be
+consulted prior to the resolution of the federal investigation.
+As explained above, one of the terms of the agreement deferring prosecution
+1o the State of Florida was securing a federal remedy for the victims. In October 2007,
+shortly after the agreement was signed, four victims were contacted and these provisions
+were discussed. One of those victims was C. W. who at the time was not represented, and she
+was given notice of the agreement. Notice was also provided of an expected change of plea
+in October 2007. When Epstein's attorneys learned that some of the victims had been
+-4-
+
+
+18 Page 5 of 21
+notified, they complained that the victims were receiving an incentive to overstate their
+involvement with Mr. Epstein in order to increase their damages claims. While your Affiant
+knew that the victims' statements had been taken and corroborated with independent
+evidence well before they were informed of the potential for damages, the agents and I
+concluded that informing additional victims could compromise the witnesses' credibility at
+trial if Epstein reneged on the agreement.
+9.
+After C. W. had been notified of the terms of the agreement, but before Epstein
+performed his obligations, C. W. contacted the FBI because Epstein's counsel was attempting
+to take her deposition and private investigators were harassing her. Your Affiant secured pro
+bono counsel to represent C.W. and several other identified victims. Pro bono counsel was
+able to assist C.W. in avoiding the improper deposition. That pro bono counsel did not
+express to your Affiant that C.W. was dissatisfied with the resolution of the matter.
+10.
+In mid-June 2008, Attorney Edwards contacted your Affiant to inform me that
+he represented C. W. and S.R. and asked to meet to provide me with information regarding
+Epstein. I invited Attorney Edwards to send to me any information that he wanted me to
+consider. Nothing was provided. I also advised Attorney Edwards that he should consider
+contacting the State Attorney's Office, if he so wished. I understand that no contact with that
+office was made. Attorney Edwards had alluded to T.M., so 1 advised him that, to iny
+knowledge, T.M. was still represented by Attorney James Eisenberg.
+-5.
+
+
+Document 14 Entered on FLSD Docket 07/1 18 Page 6 of 21
+11. On Friday, June 27, 2008, at approximate 4:15 p.m., your Affiant received a
+copy of the proposed state plea agreement and learned that the plea was scheduled for 8:30
+a.m., Monday, June 30, 2008. Your Affiant and the Palm Beach Police Department
+attempted to provide notification to victims in the short time that Epstein's counsel had given
+us. Although all known victims were not notified, your Affiant specifically called attorney
+Edwards to provide notice to his clients regarding the hearing. Your Affiant believes that
+it was during this conversation that Attorney Edwards notified me that he represented T.M..,
+and I assumed that he would pass on the notice to her, as well. Attorney Edwards informed
+your Affiant that he could not attend but that someone would be present at the hearing. Your
+Affiant attended the hearing, but none of Attorney Edwards' clients was present.
+12. On today's date, your Affiant provided the attached victim notifications to
+C. W. and S.R. via their attorney, Bradley Edwards (Exs. 6 & 7). A notification was not
+provided to T.M. because the U.S. Attorney's modification limited Epstein's liability to
+victims whom the United States was prepared to name in an indictment. In light of T.M.'s
+prior statements to law enforcement, your Affiant could not in good faith include T.M. as a
+victim in an indictment and, accordingly, could not include her in the list provided to
+Epstein's counsel.
+13.
+Furthermore, with respect to the Certification of Emergency, Attorney Edwards
+did not ever contact me prior to the filing of that Certification to demand the relief that he
+requests in his Emergency Petition. On the afternoon of July 7, 2008, after your Affiant had
+-6-
+
+
+Document 14 Entered on FLSD Docket 07/1
+18 Page 7 of 21
+already received the Certification of Emergency and Emergency Petition, I received a letter
+from Attorney Edwards that had been sent, via Certified Mail, on July 3, 2008. While that
+letter urges the Attorney General and the United States Attorney to consider "vigorous
+enforcement" of federal laws with respect to Jeffrey Epstein, it contains no demand for the
+relief requested in the Emergency Petition.
+14.
+1 declare under penalty of perjury, pursuant to 28 U.S.C. § 1746 that the
+foregoing is true and correct to the best of my knowledge and belief.
+Executed this 9th
+_day of July, 2008.
+QUillalane
+-7-
+
+
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 South Australian Ave, Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+June 7, 2007
+DELIVERY BY HAND
+Miss Cl
+Re:
+Crime Victims' and Witnesses' Rights
+Dear Miss W
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a foderal offense,
+you have a number of rights. Those nghts are:
+(1)
+The right to be reasonably protected from the accused.
+(2)
+The right to reasonable, accurate, and timely notice of any public court proceeding
+involving the crime or of any release or escape of the accused.
+(3)
+The right not to be excluded from any public court proceeding, unless the cour
+determines that your testimony may be materially altered if you are present for other
+portions of a proceeding.
+(4)
+The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, or sentencing.
+(S)
+(6)
+(7)
+(8)
+The reasonable right to confer with the attorney for the United States in the case.
+The right to full and timely restitution as provided in law.
+The right to proceedings free from unreasonable delay.
+The right to be treated with fairness and with respect for the victim's dignity and
+privacy.
+Members of the U.S. Department of Justice and other federal investigative agencies,
+including the Federal Bureau of Investigation, must use their best efforts to make sure that these
+rights are protected. If you have any concerns in this regard, please feel free to contact me at 56l
+209-1047, or Special Agent Nesbitt Kuyrkendall from the Federal Bureau of Investigation at 561
+822-5946. You also can contact the Justice Department's Office for Victims of Crime in
+Washington, D.C. at 202-307-5983. That Office has a website at www.ovc.gov.
+You can seck the advice of an attomey with respect to the righis listed above and, if you
+believe that the rights set forth above are being violated, you have the right to petition the Court for
+relief.
+
+
+Entered on FLSD Docket 07/1 8 Page 9 of 21
+•
+MISS CU
+JUNE 7, 2007
+PAGE 2
+In addition to these rights, you are entitled to counseling and medical services, and protection
+from intimidation and harassment. If the Court determines that you are a victim, you also may be
+entitled to restitution from the perpetrator. A list of counseling and medical service providers can
+be provided to you, if you so desire. If you or your family is subjected to any intimidation or
+harassment, please contact Special Agent Kuyrkendall or myself immediately. It is possible that
+someone working on behalf of the targets of the investigation may contact you. Such contact does
+not violatesthe lawe" However, if you are contacted, you have the choice of speaking to that person
+or refusing 1o"do so. If you refuse and feel that you are being threatened or harassed, then please
+contact Special Agent Kuykendall or myself.
+You also are entitled to notification of upcoming case events. At this time, your case is under
+investigation! If anyone is charged in connection with the investigation, you will be notified.
+Sincerely,
+R. Alexander Acosta
+United States Altorney
+By:
+A. Marie Villafaña
+Assistant United States Attomey
+CE:
+Special Agent Nesbitt Kuyrkendall, F.B.I.
+!
+
+
+Case 9:08-cv-81
+Entered on FLSD Docket 07/15
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+August 11, 2006
+DELIVERY BY HAND
+Miss T
+Re:
+Crime Victims" and Witnesses' Rights
+Dear Miss MI
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense,
+you have a number of rights. Those rights are:
+(1)
+(2)
+The right to be reasonably protected from the accused.
+The right to reasonable, accurate, and timely notice of any public court proceeding
+involving the crime or of any release or escape of the accused
+(3)
+The right not to be excluded from any public court proceeding, unless the court
+determines that your testimony may be materially altered if you are present for other
+portions of a proceeding.
+(4)
+The right 1o be reasonably heard at any public proceeding in the district court
+involving release, plea, or sentencing.
+(5)
+(0)
+(7)
+(8)
+The reisonable right to confer with the attorney for the United States in the case.
+The right to full and timely restitution as provided in law.
+The right to proceedings free from unreasonable delay.
+The right to be treated with fairness and with respect for the victim's dignity and
+privacy.
+Members of the U.S. Department of Justice and other federal investigative agencies,
+including the Federal Bureau of Investigation, must use their best efforts to make sure that these
+rights are protected. If you have any concers in this regard, please feel free to contact me at 561
+209-1047, or Special Agent Nesbitt Kuyrkendall from the Federal Burcau of Investigation at 56l
+822-5946. You also can contact the Justice Department's Office for Victims of Crime in
+Washington, D.C. at 202-307-5983. That Office has a website at www.ovc.gov.
+You can seek the advice of an attorney with respect to the rights listed above and, if you
+believe that the rights set forth above are being violated, you have the right to petition the Court for
+relief.
+
+
+Entered on FLSD Docket 07/15 3 Page 11 of 21
+MISS TE
+AUGUST 11, 2006
+PAGE 2
+• ME
+In addition to these rights, you are entitled to counseling and medical services, and !..
+from intimidation and harassment. If the Court determines that you are a victim, you .....
+not violate the law. However, if you are contacted, you have the choice of speaking to ih
+or refusing to do so. If you refuse and feel that you are being threatened or harassed, I'
+contact Special Agent Kuyrkendall or myself.
+You also are entitled to notification of upcoming case events. At this time, your es :
+investigation. If anyone is charged in connection with the investigation, you will bon
+Sincerely,
+R. Alexander Acosta
+United States Altomey
+By:
+A. Marie Villalaña
+Assistant United States Attorney
+cc:
+Special Agent Nesbitt Kuyrkendall, F.B.I.
+".".
+
+
+Case 9:08-Cy-8
+Entered on FLSD Docket OZL1:
+U.S. Department of Justice
+Bus Pagev12 of 21
+January 10, 2008
+Re: Case Number:
+Dear Q
+This case is currently under Investigation. This can be a lengthy process and we request your
+continued patience while we conduct a thorough investigation.
+As a crime victim, you have the following rights under 18 United States Code 5 3771: (1) The right to
+be reasonably protected from the accused; (2) The right to reasonable, accurate, and tirely notice of any
+public court proceeding, or any parole proceeding, Involving the crime or of any release or escape of the
+accused; (3) The right not to be excluded from any such public court proceeding, unless the court, after
+receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if
+the victin heard other testimony at that proceeding; (4) The right to be reasonably heard at any public
+proceeding in the district court involving release, plea, sentencing, or any parole proceeding: (5) The
+reasonable right to confer with the attomey for the Government in the case; (6) The right to full and timely
+restitution as provided In law; (7) The right to proceedings free from unreasonable delay; (8) The right to be
+treated with faimess and with respect for the victim's dignity and privacy.
+We will make our best efforts to ensure you are accorded the rights desorbed. Most of these rights
+pertain to events occurring after the arrest or indictment of an individual for the crime, and it will become the
+responsibility of the prosecuting United States Attomey's Office to ensure you are accorded those rights. You
+may also seek the advice of a private attomey with respect to these rights.
+The Victim Notification System (VNS) is designed to provide you with direct information regarding the
+case as it proceeds through the criminal justice system. You may obtain current information about this matter
+on the Internet at WWW.Notify. USDOJ.GOV or from the VNS Call Center at 1-866-DOJ-4YOU (1-866-365-
+496B) (TDD/TTY: 1-866-228-4619) (International: 1-502-213-2767). In addition, you may use the Call
+Center or Internet to update your contact information and/or change your decision about participation in the
+notification program. If you update your information to include a current emall address, VNS will send
+information to that address. You will need the following Victim Identification Number (VIN) "1941737 and
+Personal Identification Number (PIN) '5502' anytime you contact the Call Center and the first time you log on to
+/NS on the Internet. In addition, the first time you access the VS Intemet site, you will be prompted to enter
+rour last name (or business name) as currently contained in VNS. The name you should enter Is
+CABE
+NO. 08-80736-CV-MAR)
+
+
+-KAM Document 14
+If you have additional questions which involve this matter, please contact the office listed above. When
+you call, please provide the file number located at the top of this letter. Please remember, your participation
+in the notification part of this program is voluntary. In order to continue to receive notifications, it is your
+responsibility to keep your contact information current.
+Sincerely.
+18 Page 13 8f 21
+
+
+•KAM
+Entered on FLSD Docket 07/4
+1.S. Department of Justic
+*ederal Bureau of investigatio
+BI - West Palm Beact
+Suite 500
+05 South Flagler Driv
+Vest Palm Beach, FL 3340
+hone: (581) 833-751
+ax: (561) 833-797
+801 Page 44of 21
+January 10, 2008
+James Elsenberg
+One Clearlake Center Ste 704 Australian South
+West Palm Beach, FL. 33401
+Dear James Elsanberg:
+You have requested to receive notifications for T
+This case is currently under Investigation. This can be a lengthy process and we request your
+continued patlence while we conduct a thorough investigation.
+As a crime victim, you have the following rights under 18 United States Code § 3771: (1) The right to
+be reasonably protected from the accused; (Z) The right to reasonable, accurate, and timely notice of any
+public court proceeding, or any parole proceeding, involving the crime or of any release or escape of the
+accused: (3) The right not to be axcluded from any such public court proceeding, unless the court, after •
+receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if
+the victim heard other testimony at that proceeding: (4) The right to be reasonably heard at any public
+proceeding in the district court involving release, plea, santencing, or any parole proceeding; (5) The
+reasonable right to confer with the attomey for the Government in the case; (5) The right to full and timely
+restitution as provided in law; (7) The right to proceedings free from unreasonable delay: (8) The right to be
+We will make our best efforts to ensure you are accorded the rights described. Most of these rights
+pertain to events occurring after the arrest or indictment of an individual for the crime, and it will become the
+responsiblity of the prosecuting United States Attorney's Office to ensure you are accorded those rights. You
+may also seek the advice of a private attorey with respect to these rights.
+The Victim Notification System (VNS) is designed to provide you with direct information regarding the
+case as it proceeds through the criminal justice system.
+You may obtain current information about this matter
+on the internet at WWW.Notify. USDOJ.GOV or from the VNS Call Center at 1-886-DOJ-4YOU (1-866-365-
+4969) (TDD/TTY: 1-866-228-4618) (Intemational: 1-502-213-2767). In addition, you may use the Call
+Center or Intemet to update your contact information and/or change your decision about participation in the
+notification program. If you update your information to Include a current emall address, VNS will send
+information to that address. You will need the following Victim Identification Number (VIN) *1941741' and
+Personal Identification Number (PIN) 7760" anytime you contact the Call Center and the first time you log on to
+VNS on the Interet. In addition, the first time you access the VNS Internet site, you will be prompted to enter
+your last name (or business name) as currently contained in VNS. The name you should enter is Eisenberg.
+CASE
+NO: 08-80136-CV MARK
+
+
+Case 9:08-Gv-8(
+Entered on FLSD Docket 07*4L
+If you have addtional questions which involve this matter, please contact the office listed above. When
+ou call, please provide the file number located at the top of this letter. Please remember, your participatio
+the nolffication part of this program is voluntary. In order to continue to receive nolifications, it is you
+responsibility to keep your contact Information current.
+Sincerely.
+Quikes smitt
+3201 Page 45 of 21
+
+
+Entered on FLSD Docket 0711
+U.S. Department of Justice
+Federal Bureau of Investigation
+FBI - West Palm Beach
+Suite 500
+505 South Flagler Drive
+West Paim Beach, FL 33401
+Phone: (561) 833-7517
+Fax: (561) 833-7970
+GOVERN
+EXH
+May 30, 2008
+Re:
+Dear S
+Your name was referred to the FBI's Victim Assistance Program as being a possible victim of a federal
+crime. We appreciate your assistance and cooperation while we are investigating this case. We would like to
+make you aware of the victim services that may be available to you and to answer any questions you may have
+regarding the criminal justice process throughout the investigation. Our program is part of the FBi's effort to
+ensure the victims are treated with respect and are provided information about their nights under federal law.
+These rights include notification of the status of the case. The enclosed brochures provide information about
+the FBI's Victim Assistance Program, resources and instructions for accessing the Victim Notification System
+(VNS). VNS is designed to provide you with information regarding the status of your case.
+This case Is currently under Investigation. This can be a lengthy process and we request your
+continued patience while we conduct a thorough investigation.
+As a crime victim, you have the following rights under 18 United States Code § 3771: (1) The right to
+be reasonably protected from the accused; (2) The right to reasonable, accurate, and timely notice of any
+public court proceeding, or any parole proceeding, involving the crime or of any release or escape of the
+accused: (3) The right not to be excluded from any such public court proceeding, unless the court, after
+receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if
+the victim heard other testimony at that proceeding: (4) The right to be reasonably heard at any public
+proceeding in the district court involving release, ples, sentencing, or any parole proceeding; (5) The
+reasonable right to confer with the attorney for the Govemment in the case; (6) The right to full and timely
+restitution as provided in law; (7) The right to proceedings free from unreasonable delay: (8) The right to be
+treated with fairess and with respect for the victim's dignity and privacy.
+We will make our best efforts to ensure you are accorded the rights described. Most of these rights
+pertain to events occurring after the arrest or indictment of an individual for the crime, and it will become the
+responsibility of the prosecuting United States Attorney's Office to ensure you are accorded those rights. You
+may also seek the advice of a private attorney with respect to these rights.
+The Victim Notification System (VNS) Is designed to provide you with direct information regarding the
+case as it proceeds through the criminal justice system. You may obtain current information about this matter
+on the Internet at WWW. Notify. USDOJ. GOV or from the VNS Call Center at 1-866-DOJ-4YOU (1-866-355-
+4968) (TDD/TTY: 1-866-228-4619) (International: 1-502-213-2767). In addition, you may use the Call
+Center or Internet to update your contact information and/or change your decision about participation in the
+notification program. if you update your Information to Include a current email address, VNS will send
+information to that address. You will need the following Victim Identification Number (VIN) 2074381' and
+Personal Identification Number (PIN) '1816' anytime you contact the Call Center and the first time you log on to
+VNS on the Internet. In addition, the first time you access the VNS Internet site, you will be prompted to enter
+your last name (or business name) as currently contained in VNS. The name you should enter is R
+
+
+Case, 9:08-EV-8l
+Entered on FLSD Docket 07/4€
+11 you have additional questions which involve this matter, please contact the office listed above. When
+you call, please provide the file number located at the top of this letter. Please remember, your participation
+in the notification part of this program is voluntary. In order to continue to receive notifications, it is your
+responsibility to keep your contact information current.
+Sincerely,
+3out Page 47 of 21
+TOTAL P.07
+
+
+18
+U.S. Department of Justice
+
+GOVERNMENT
+
+CASE 8036-CY-MARRA
+
+6
+United States Attorney
+Southern District of Florida
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 9, 2008
+VIA FACSIMILE
+Brad Edwards, Esq
+The Law Offices of Brad Edwards & Associates, LLC
+2028 Harrison Street, Suite 202
+Hollywood, Florida
+33020.
+•
+Re: Jeffrey Epstein/Can W
+• NOTIFICATION OF
+IDENTIFIED VICTIM
+Dear Mr. Edwards:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following notice to your client, GI
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+
+
+8 Page 19 of 21
+BRAD EDWARDS, ESQ
+NOTIFICATION OF IDeNTIFIED VICTIM G
+JULY 9, 2008
+
+had been tried federally and convicted of an enumerated offense. For purposes
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that your client, Out
+is an individual whom the United States was prepared to name as a victim of an enumerated
+offense.
+Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an
+enumerated offense, please provide notice of that denial to the undersigned.
+Please thank your client for all of her assistance during the course of this examination
+and express the heartfelt regards of myself'and Special Agents Kuyrkendall and Richards for
+the health and well-being of Ms. We
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Plan ellatara
+A. MARIE VILLAFAÑA
+ASSISTANT U.S. ATTORNEY
+ce: Jack Goldberger, Esq.
+
+
+II.S. Department of Justice
+18
+
+¡OVERNMEN
+CODE 80736-CY. MARRA
+
+United States Attorney
+Southern District of Florida
+500 South Australian Ave., Suire 400
+Yest Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 9, 2008
+VIA FACSIMILE
+Brad Edwards, Esq.
+The Law Offices of Brad Edwards & Associates, LLC
+2028 Harrison Street, Suite 202
+Hollywood, Florida 33020.
+Re:
+Jeffrey Epstein/S
+IDENTIFIED VICTIM
+• NOTIFICATION OF
+Dear Mr. Edwards:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following notice to your client, Se
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nas. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+in light of the entry of the guilty plea and sentence, the United States has agreed tr
+Jefer federal prosecution in favor of this state plea and sentence, subject to certair
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+
+
+KAM Document 14 Entered on FLSD Docket 07/1.
+8 Page 21 of 21
+BRAD EDWARDS, ESQ.
+NOTIFICATION OF IDENTIFIED VICTIM SERIE
+JULY 9,2008
+
+had been tried federally and convicted of an enumerated offense. For purposes
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in ar
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+uthority interpreting this provision, including any authority determinin
+vhich evidentiary burdens if' any a plaintiff must meet, shall consider that it i
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that your client, Si
+• is an individual whom the United States was prepared to name as a victim of an
+enumerated offense.
+Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an
+enumerated offense, please provide notice of that denial to the undersigned.
+Please thank your client for all of her assistance during the course of this examination
+and express the heartfelt regards of myself and Special Agents Kuyrkendall and Richards for
+the health and well-being of Ms. R
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Alan Vellafor
+A. MARIE VILLAFAÑA
+ASSISTANT U.S. ATTORNEY
+cc:
+Jack Goldberger, Esq.
+
+
+Case 9:08-c
+36-KAM Document 5
+Entered on FLSD Docket 07,
+108 Page 1 of 1
+CASE NO. 08-80736-CTV-MARRA/JOHNSON
+IN RE: JANE DOE,
+Petitioner.
+/
+ORDER
+TAKE NOTICE that the above-styled cause has been set for a hearing on Petitioner's
+Emergency Petition for Enforcement of Crime Victim's Rights Act on Friday, July 11, 2008 at
+10:15 A.M. before United States District Judge Kenneth A. Marra, 701 Clematis Street,
+Courtroom 4, West Palm Beach, Florida.
+DONE and ORDERED in Chambers at West Palm Beach, Palm Beach County, Florida
+this 10 day of July, 2008.
+KENNETH A. MARRA
+United States District Judge
+copies to:
+
+
+RETAIN
+
+
+SKAM Document 13 Entered on FLSD Docket 071 08 Page 1 of 8
+CASE NO. 08-80736-CIV-MARRA/JOHNSON
+IN RE: JANE DOE,
+FILED by ISS D.C.
+JUL 0 9 2008
+Petitioner.
+GOVERNMENT'S RESPONSE TO VICTIM'S EMERGENCY PETITION
+FOR ENFORCEMENT OF CRIME VICTIM RIGHTS ACT, 18 U.S.C. § 3771
+The United States of America, by and through its undersigned counsel, files its Response
+to Victim's Emergency Petition for Enforcement of Victim Rights Act, 18 U.S.C. § 3771, and
+states:
+THERE IS NO "COURT PROCEEDING" UNDER 18 U.S.C. § 3771(b)
+Petitioner complains that she has been denied her rights under the Crime Victims Rights
+Act, 18 U.S.C. § 3771. In the emergency petition filed by the victim, she alleges the Government
+has denied her rights since she has received no consultation with the attorney for the government
+regarding possible disposition of the charges (18 U.S.C. § 3771(a)(5)); no notice of any public
+court proceedings (18 U.S.C. § 377l(a)(2)); no information regarding her right to restitution (18
+U.S.C. § 3771(a)(6)); and no notice of rights under the Crime Victim Rights Act (CVRA).
+Emergency Petition, 1 5.
+The instant case is unique in several respects. First, in 2006, Jeffrey Epstein was charged
+with felony solicitation of prostitution in the Circuit Court of the Fifteenth Judicial Circuit, Palm
+Beach County, Florida. This charge was based upon the offenses alleged in paragraph 1 of the
+petition. Second, while Epstein has been under federal investigation, he has not been charged in
+
+
+Document 13 Entered on FLSD Docket 07/
+108 Page 2 of 8
+the Southern District of Florida.
+Title 18, U.S.C., Section 3771(b)(1) provides in pertinent part that, "li]n any court
+proceeding involving an offense against a crime victim, the court shall ensure that the crime
+victim is afforded the rights described in subsection (a)." There is no "court proceeding" in the
+instant case since Epstein has not been charged with violation of any federal statute. No federal
+grand jury indictment has been returned, nor has any criminal information been filed. There can
+thus be no failure of a right to notice of a public court proceeding or the right to restitution.
+In her memorandum, petitioner relies upon In Re Dean, 527 F.3d 391 (5th Cir. 2008),
+where the Fifth Circuit held that the CVRA required the government to "confer in some
+reasonable way with the victims before ultimately exercising its broad discretion." Id. at 395. In
+Dean, the government sought and obtained an ex parte order permitting it to negotiate a plea
+agreement with BP Products North America, without first consulting with the victims,
+individuals injured and survivors of those killed in a refinery explosion. A plea agreement was
+ultimately negotiated and the victims objected. The appellate court found that the CVRA granted
+a right to confer. However, the court declined to grant mandamus relief for prudential reasons,
+finding that the district court had the benefit of the views of the victims who chose to participate
+at the hearing held on whether the plea agreement should be accepted. Id. at 396.
+Dean is legally distinguishable in several respects. For one thing, the court's discussion
+of the scope of the right to confer was unnecessary because the court ultimately declined to issue
+mandamus relief. Dean, 527 F.3d at 395. Also, in offering its view that this right applies precharge, it is noteworthy that the court, in purporting to quote the statute, omitted the last three
+words of section 3771(a)(5)(*in the case"), words that arguably point in the opposite direction by
+- 2-
+
+
+Document 13 Entered on FLSD Docket 07.
+108 Page 3 of 8
+suggesting that the right applies post-charge. Further, the court went to great lengths to
+emphasize that its holding was limited to the particular circumstances presented in that case (i.c.,
+the simultaneous filing of a plea agreement and formal charges), which of course, is not the case
+here. No federal charges have been filed in the instant case, and this case, unlike Dean, involves
+an agreement to defer federal prosecution in favor of prosecution by the State of Florida and not a
+guilty plea. Id. at 394. Finally, the Dean court expressly declined to "speculate on the [right to
+confer's] applicability to other situations." Id. Nothing in § 3771(a)(5) supports the petitioner's
+claim that she had a right to be consulted before the Government could enter into a nonprosecution agreement which defers federal prosecution in exchange for state court resolution of
+criminal liability, and a significant concession on an element of a claim for compensation under
+18 U.S.C. § 2255.
+Il.
+THE GOVERNMENT HAS USED ITS BEST EFFORTS TO COMPLY WITH
+18 U.S.C. § 3771(a)
+The Epstein case was investigated initially by the Palm Beach Police Department in 2006.
+Exhibit A, Declaration of Assistant United States Attorney A. Marie Villafaña, 9 2.
+Subsequently, the Palm Beach Police Department sought the assistance of the Federal Bureau of
+Investigation (FBI). Id. Throughout the investigation, when a victim was identified, victim
+notification letters were provided to the victim by both the FBI Victim-Witness Specialist and
+AUSA Villafaña. Id., 1| 3. Petitioner's counsel, Brad Edwards, Esq., currently represents C. W.,
+T.M., and S.R. The U.S. Attorney's Office victim notification letter to C. W. was provided by the
+FBI, and the letter 1o T.M. was hand-delivered by AUSA Villafaña to her when she was
+interviewed in April 2007. FBI victim notification letters were mailed to C.W. and T.M. on
+- 3-
+
+
+6-KAМ
+Document 13 Entered on FLSD Docket 07.
+108 Page 4 of 8
+January 10, 2008, and to S.R. on May 30, 2008. Villafaña Decl., 1 3.
+Throughout the investigation, AUSA Villafaña and the FBI's Victim-Witness Specialist
+had contact with C.W. Villafaña Decl., 9 4. Earlier in the investigation, T.M. was represented by
+James Eisenberg, Esq. Consequently, all contact with T.M. was made through Mr. Eisenberg.
+In mid-2007, Epstein's attorneys approached the U.S. Attorney's Office in an effort to
+resolve the federal investigation. Id., 11 5. At that time, Mr. Epstein had been charged by the
+State of Florida with solicitation of prostitution, in violation of Florida Statutes § 796.07. Mr.
+Epstein's attorneys sought a global resolution of this matter. The United States subsequently
+agreed to defer federal prosecution in favor of prosecution by the State of Florida, so long as
+certain basic preconditions were met. One of the key objectives for the Government was to
+preserve a federal remedy for the young girls whom Epstein had sexually exploited. Thus, one
+condition of that agreement, notice of which was provided to the victims on July 9, 2008, is the
+following:
+"Any person, who while a minor, was a victim of a violation of an
+offense enumerated in Title 18, United States Code, Section 2255,
+will have the same rights to proceed under Section 2255 as she
+would have had, if Mr. Epstein had been tried federally and
+convicted of an enumerated offense. For purposes of
+implementing this paragraph, the United States shall provide Mr.
+Epstein's attorneys with a list of individuals whom it was prepared
+parties to place these identified victims in the same position as they
+more; no less."
+The Attorney General Guidelines for Victim and Witness Assistance (May 2005). Article
+- 4-
+
+
+i6-KAM
+Document 13 Entered on FLSD Docket 07
+008 Page 5 of 8
+IV, Services to Victims and Witnesses, provides the following guidance for proposed plea
+agreements:
+(3) Proposed Plea Agreements. Responsible officials should make reasonable
+efforts to notify identified victims of, and consider victims' views about,
+prospective plea negotiations. In determining what is reasonable, the responsible
+official should consider factors relevant to the wisdom and practicality of givin
+lotice and considering views in the context of the particular case, including, bu
+not limited to, the following factors:
+(a) The impact on public safety and risks to personal safety.
+(b) The number of victims.
+(c) Whether time is of the essence in negotiating or entering a proposed plea.
+(d) Whether the proposed plea involves confidential information or conditions.
+(e) Whether there is another need for confidentiality.
+(f) Whether the victim is a possible witness in the case and the effect that relaying any
+information may have on the defendant's right to a fair trial.
+Throughout negotiations, Epstein's attorneys claimed that one reason victims came
+forward and pressed their claims was their desire for money. They argued that victims might
+have an inducement to fabricate or enhance their testimony, in order to maximize their
+opportunities to obtain financial recompense. Villafaña Decl., 9. 8. The Government was
+extremely concerned that disclosure of the proposed terms would compromise the investigation
+by providing Epstein the means of impeaching the victim witnesses, should the parties fail to
+reach an agreement. In light of the fact (i) that the United States agreed to defer prosecution to a
+previously filed state criminal case; (ii) that as a result sentencing would take place in state court
+before a state judge; (iii) that if the state resolution failed to meet minimum standards such that a
+federal prosecution was warranted, the victims would be witnesses and thus potential
+- 5-
+
+
+Case 9:08-Cv
+36-KAМ
+Document 13 Entered on FLSD Docket 07
+008 Page 6 of 8
+impeachment issues were of concern; and (iv) the United States was already making efforts to
+secure for victims the right to proceed federally under 18 U.S.C. § 2255 even if prosecution took
+place in state court, the Government determined that its actions in proceeding with this
+agreement best balanced the dual position of the Jane Does as both victims and potential
+witnesses in a criminal proceeding.
+On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA Villafaña received a copy
+of the proposed state plea agreement, and learned that Epstein's state plea hearing was scheduled
+for Monday, June 30, 2008, at 8:30 a.m. Villafaña Decl., 9 10. AUSA Villafaña and the Palm
+Beach Police Department attempted to provide notification to victims in the short time that they
+had. Id. Although all known victims were not notified, AUSA Villafaña did call attorney
+Edwards to provide notice to his clients regarding the hearing. AUSA Villafaña did this, even
+though she had no obligation to provide notice of a state court hearing. Mr. Edwards advised that
+he could not attend but that someone would be present at the hearing. Id.
+The Government has complied with 18 U.S.C. § 3771(c)(1) by using its best efforts to
+"see that crime victims are notified of, and accorded, the rights described in subsection (a)."
+Specifically, petitioner was afforded the reasonable right to confer with the attorney for the
+Government under 18 U.S.C. § 3771(a)(5). Disclosure of the specific terms of the negotiation
+were not disclosed prior to a final agreement being reached because the Government believed
+doing so would jeopardize and prejudice the prosecution in the event an agreement could not be
+made. Further, although 18 U.S.C. § 3771(a)(2) does not apply to state court proceedings, the
+government nonetheless notified petitioner's counsel on June 27, 2008, of the plea hearing in
+state court on June 30, 2008.
+- 6-
+
+
+Document 13 Entered on FLSD Docket 07/:
+18 Page 7 of 8
+Section 3771(d)(6) provides, in relevant part, that "[n]othing in this chapter shall be
+construed to impair the prosecutorial discretion of the Attorney General or any officer under his
+direction." The Government exercised its judgment and discretion in determining that there was
+a need for confidentiality in the negotiations with Epstein. The significant benefit of obtaining
+Epstein's concession that victims suing him under 18 U.S.C. § 2255(a) were "victims" of the
+numerated offenses, despite the fact he has not been convicted in federal court, was of sufficient
+importance to justify confidentiality of the negotiations.
+III. THE GOVERNMENT'S DISCUSSIONS WITH T.M., C.W., AND S.R.
+Attorney Brad Edwards has advised the Government that he represents T.M., C.W., and
+S.R. Vietim letters were provided to all three individuals. The letters to C.W. and T.M. were
+forwarded on January 10, 2008. Villafaña Decl., 9 3. On May 28, 2008, S.R.'s status as a victim
+was confirmed when she was interviewed by federal agents. Id. The FBI Victim Witness
+specialist sent her a letter on May 30, 2008. Id.
+When the agreement was signed in September 2007, T.M. was openly hostile to a
+prosecution of Epstein, and S.R. had refused to speak with federal investigators. Id., 117. While
+individual vietims were not consulted regarding the agreement, none of Mr. Edwards' clients
+had expressed a desire to be consulted prior to the resolution of the federal investigation. Id.
+In October 2007, C. W. was not represented by counsel. Id.. 118. She was given
+telephonic notice of the agreement, as were three other victims. Id. These four individuals were
+also given notice or an expected change of plea, in state court, in October 2007.
+In mid-June 2008, Mr. Edwards contacted AUSA Villafaña to advise that he represented
+C. W. and S.R., and requested a meeting. Id., 119. AUSA Villafaña asked Mr. Edwards to send
+- 7-
+
+
+Document 13
+Entered on FLSD Docket 07/:
+18 Page 8 of 8
+to her any information that he wished her to consider. Nothing was provided. Id. AUSA
+Villafaña also told Mr. Edwards he could contact the State Attorney's Office, if he wished. To
+her knowledge, Mr. Edwards did not make the contact.
+The Government has acted reasonably in keeping T.M, C.W., and S.R. informed.
+Petitioner's rights under the CVRA have not been violated. Therefore, her emergency petition
+should be denied.
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+Assistant U.S. Attorney
+Fla. Bar No. 0936693
+99 N.E. 4" Street
+(305) 961-9320
+Fax: (305) 530-7139
+E-mail: dexter.lee@usdoj.gov
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via facsimile
+transmission and U.S. Mail, this? day of July, 2008, to: Brad Edwards, Esq. The Law
+Offices of Brad Edwards & Associates, LIC, (954) 924-1530, 2028 Harrison Street, Suite 202,
+Hollywood, Florida 33020.
+DEXTER A. LEE
+Assistant U.S. Attorney
+- 8-
+
+
+8000D SERIES
+
+
+Document 12 Entered on FLSD Docket 07,
+108 Page 1 of 3
+CASE NO. 08-80736-CIV-MARRA/JOHNSON
+IN RE: JANE DOE,
+FILED by MRS D.C.
+JUL. 0 9 2008
+Petitioner.
+UNITED STATES' MOTION TO FILE RESPONSE TO VICTIM'S EMERGENCY
+PETITION FOR ENFORCEMENT OF VICTIM RIGHTS ACT
+AND DECLARATION OF A. MARIE VILLAFAÑA UNDER SEAL
+The United States of America, by and through its undersigned counsel, files its Motion to File
+Response to Victim's Emergency Petition for Enforcement of Victim Rights Act and Declaration
+of A. Marie Villafaña Under Seal, pursuant to S.D. Fla. L.R. 5.4 and 18 U.S.C. § 3509(d)(2), and
+states:
+On July 7, 2008, petitioner filed her Emergency Victim's Petition for Enforcement of Crime
+Victim Rights Act, 18 U.S.C. § 3771. Petitioner did not disclose her name, and alleges that she was
+a minor child when she was the victim of federal crimes committed by Jeffrey Epstein. Petition, 9 1.
+On July 7, 2008, the Court directed the Government to file a response to the Petition by July
+9,2008, at 5:00 p.m.
+The Government has prepared its Response, which is attached as Exhibit A, and the
+Declaration of Assistant United States Attorney A. Marie Villafaña, as well as correspondence with
+several individuals who were minors when the relevant events occurred. Additionally, the
+Government's Response also refers to actions taken by the United States Attorney's Office with an
+interested party which was done in confidence. The Government believes that its Response should
+
+
+Document 12
+Entered on FLSD Docket O7/
+08 Page 2 of 3
+be filed under seal, in order to protect the minor victims' privacy, as well as to maintain the
+confidentiality of the agreement reached with an interested party.
+The Government requests that its Response and the Declaration be sealed until the
+termination of the instant litigation, or five years from the date of filing, whichever occurs first.
+Upon the expiration of the time period for sealing, the Government requests the documents be
+returned to the United States Attorney's Office.
+WHEREFORE, the government respectfully requests that its Response to Victim's
+Emergency Petition for Enforcement of Crime Victim Rights Act, 18 U.S.C. § 3771, and the
+Declaration of A. Marie Villafaña be filed under seal.
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+scillafare for
+DEXTER A. LEE
+Assistant U.S. Attorney
+Fla. Bar No. 0936693
+99 N.E. 4* Street
+(305) 961-9320
+Fax: (305) 530-7139
+E-mail:
+:dexter.lee@usdoj.gov
+2
+
+
+Document 12 Entered on FLSD Docket 07,
+108 Page 3 of 3
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via facsimile
+transmission and U.S. Mail, this A day or July, 2008, to: Brad Edwards, Esq. The Law Offices
+of Brad Edwards & Associates, L.L.C, (954) 924-1530, 2028 Harrison Street, Suite 202, Hollywood,
+Florida 33020.
+DEXTER A. LEE
+Assistant U.S. Attorney
+3
+
+
+
+
+Case 9:08-Cv-i
+İ-KAM Document 11
+18 Page 1 of 1
+NO. 08-80736-CIV-MARRA/JOHNSON
+IN RE: JANE DOE,
+Petitioner.
+ORDER DENYING MOTION TO SEAL
+THIS CAUSE comes before the Court on the United States of America's Motion to Seal
+its Response to Victim's Emergency Petition for Enforcement of Crime Victim Rights Act, filed
+July 9, 2008. The Court has carefully considered the motion and is otherwise fully advised in the
+premises. For the reasons explained at the hearing held on July 11, 2008, it is hereby
+ORDERED AND ADJUDGED that the Motion to Seal is DENIED. The Clerk shall make
+available for public viewing all documents placed under seal on July 9, 2008.
+DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County,
+Florida, this/ day of July, 2008.
+KENNETH A MARRA
+United States District Judge
+
+
+708 Page 1 of 2
+LRJ
+U.S. District Court
+Southern District of Florida (West Palm Beach)
+CIVIL DOCKET FOR CASE #: 9:08-cv-80736-KAM
+Internal Use Only
+Doe. United States of America
+ssigned to: Judge Kenneth A. Marr
+ause: no cause specifie
+Petitioner
+Jane Doe
+Jurisdiction: U.S. Government Defendan
+represented by Bradley James Edwards
+2028 Harrison Street
+Suite 202
+354-410-8. 54. 3020
+Fax: 924-1530
+Email: BE@kubickidraper.com
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+I.
+Respondent
+United States of America
+represented by Ann Marie C. Villafana
+500 So sin Australian nice
+LEAD ATTORNE. illafana@usdo.gov
+Dexter Lee
+99 NE 4 Street
+Miami, FL 33132
+305-961-9320
+Fax: 530-7139
+Email: dexter.lee@usdoj.gov
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Date Filed
+07/07/2008
+#
+07/07/2008
+07/07/2008
+07/09/2008
+Docket Text
+EMERGENCY PETITION for Victim's Enforcement of Crime Victim's Rights
+Act 18 USC 3771 against United States of America Filing fee $ 350. Receipti:
+724403, filed by Jane Doe.(rb) (Entered: 07/07/2008)
+CERTIGATE OF EMERGENCY by Jane Doc re Complaine (1b) (Entered:
+ORDER requiring U.S. Attorney to respond to 1 Complaint filed by Jane Doe by
+51007/20080 7/9/08. Signed by Judge Kenneth A. Marra on 7/7108. (it) (Entered
+4 NOTICE of Attorney Appearance by Dexter Lee on behalf of United States of
+America (Lee, Dexter) (Entered: 07/09/2008
+
+
+Case 9:08-cv-8r
+07/09/2008
+07/09/2008
+07/09/2008
+07/10/2008
+07/11/2008
+07/11/2008
+07/11/2008
+KAND8-ДeB0ñaent 1As2of: ŒEntér20Q8 FLSWA«BIT07
+0D8 Page 2 of 2
+6 Scaled Document. (rb) (Entered: 07/10/2008)
+7
+Sealed Document. (rb) (Entered: 07/10/2008)
+8
+Sealed Document. (rb) (Entered: 07/10/2008)
+ORDER SETTING HEARING: Petitioner's Emergency Petition for Enforcement
+of Crime Victim's Rights Act set for 7/11/2008 10:15 AM in West Palm Beach
+Division before Judge Kenneth A. Marra. Signed by Judge Kenneth A. Marra on
+7/10/08. (ir) (Entered: 07/10/2008)
+2
+REPLY to Response (under seal) re_1 Complaint/Emergency Petition, an
+3) (Eritered: 07/11200t) Motion for Scaling of Pleadings filed by Jane Doc
+10 Miscel aners Hearing ding on / 2008. Cour elsA Mario unscal
+303-523 C3 (Rontered: 07/ 1 Roosting Service- phone number
+ORDER Denying Motion to Seal re 7 Sealed Document, 6 Sealed Document, &
+Sealed Document. Signed by Judge Kenneth A. Marra on 7/11/2008. (Is)
+(Entered: 07/14/2008)
+
+
+
+
+----
+18 Page 1 of 17
+CASE NO.: 08-80736-CIV-MARRAVJOHNSON
+[FILED by D.C.
+JUL 1 1 2038
+5.D. OF FLA. - W. 1L
+IN RE: JANE DOE,
+Petitioner.
+VICTIM'S REPLY TO GOVERNMENT'S RESPONSE TO EMERGENCY PETITION
+FOR ENFORCEMENT OF CRIME VICTIM'S RIGHTS ACT, 18 U.S.C. § 3771
+AND OBJECTION TO GOVERNMENT'S MOTION FOR SEALING OF PLEADINGS
+COMES NOW the Petitioner, JANE DOE, by and through her undersigned attorney,
+pu suant to the Crime Victim's Rights Act, 18 U.S.C. Section 3771 ("CVRA"), and files this
+Reply to the Government's Response to her Emergency Petition for Enforcement and Objection
+to the Sealing of the Pleadings in this matter as follows:
+INTRODUCTION
+Four days ago (July 7), Petitioner filed in this Court a motion seeking enforcement of
+(among other rights) her right to "confer" with the prosecution before a plea arrangement is
+reached disposing of the criminal charges involving her - a right promised to her in the Crime
+Victims' Rights Act (CVRA). See 18 U.S.C. § 3771(d)(5) (victims of crime have the "reasonable
+right to confer with the attorney for the Government in the case"). Two days later (July 9'"), the
+Covernment sent her a notice that, in light of defendant, Jeffrey Epstein's entry of guilty pleas to
+various state charges and 18-month jail sentence, the Government had agreed to defer all federal
+prosecution - including any federal prosecution for the federal crimes committed against her.
+This deferred prosecution agreement was reached without conferral with Petitioner - or, indeed,
+with the many other young victims of the defendant's crimes. And the agreement remarkably
+1
+
+
+6-KAМ Document 9
+18 Page 2 of 17
+alowed the defendant - a billionaire with extraordinary political connections -- to escape all
+federal prosecution for dozens of serious federal sex offenses against minors.
+On July 9", the Government also filed with this Court a response to the Petitioner's
+petition for enforcement of her CVRA rights. In its response, the Government argues that it did
+not need to confer with Petitioner because there was no formal "court proceeding" pending at the
+time the Government negotiated this non-prosecution agreement. This position ignores the plain
+language of the CVRA - which extends the right to confer to any "case," not any "court
+proceeding" - and flies in the face of the Fifth Circuit's recent decision that is squarely on point -
+In re Dean, 527 F.3d 391 (5" Cir. 2008). Perhaps in recognition of the weakness of its position,
+the Government goes on to argue that it used its "best efforts" to comply the CVRA. But the
+Government never conferred with Petitioner about the agreement - so the Government's efforts
+fall well short of affording Petitioner her right to confer. Finally, the Government clains that it
+disclosed some of its activities to Petitioner in this case (identified as "C.W." in the Government's
+papers). But neither Petitioner nor undersigned counsel were ever notified of the proposed nonprosecution agreement. To the contrary, undersigned counsel was advised that a federal
+indictment was in the works. For all these reasons, the Government's response lacks merit. The
+Court should therefore declare the proposed non-prosecution agreement an illegal one, since it
+was reached in violation of the CVRA, and order the Government to confer with Petitioner and
+the other victims in this matter before reaching any disposition in this case.
+The Government also apparently proposes to keep its activities in this case secret, by filing
+documents under seal. It bears emphasizing that none of the pleadings in this matter discloses,
+either directly or indirectly, the identity of a minor victim. In light of this fact, the Government
+2
+
+
+18 Page 3 of 17
+bears a heavy burden in deviating from the ordinary rules, a burden it has not carried. There is no
+sound basis for keeping the pleadings in this matter sealed. Moreover, the matter is one of
+exceptional public interest - involving what appears to Petitioner to be a "sweetheart" nonprosecution agreement for multiple sex crimes against children committed by a well connected
+billionaire. Accordingly, the papers in this case should be lodged in the Court's public file.
+THE GOVERNMENT HAS VIOLATED PETITIONER'S RIGHT TO "CONFER"
+BEFORE REACHING THE NON-PROSECUTION AGREEMENT.
+The Crime Victims' Rights Act promises Petitioner that she will have "'the reasonable
+right to confer with the attorney for the Government in the case." 18 U.S.C. § 3771(d)(5)
+(emphasis added). To justify its failure to confer here, the Government's lead argument in its
+response is that there was no "court proceeding" in this case that triggered Petitioner's right to
+confer. Gov't Response at 1-2. The Government's position flouts the plain language of the
+CVRA. The CVRA guarantees to Petitioner the right to confer with prosecutors "in the case" -
+not in a "court proceeding." Indeed, the fact that (as the Government notes) the drafters of the
+CVRA used the term "court proceeding" elsewhere in the statute makes it obvious that they
+intended to give victims a right to confer that extended beyond simple court proceedings - that is,
+the right to confer about "the case."
+Obviously there was "a case" going on in this matter for some time. Indeed, the
+Government sent notice to Petitioner more than a year ago that "your case is under investigatior."
+See Letter from A. Marie Villafaña to C.W. at 2 (June 7, 2007) (attached to Government's
+Response) (emphasis added). The notice went on to tell Petitioner that "as a victim and/or
+witness of a federal offense, you have a number of rights." Id. at 1. Of course, she would not
+have had those rights if she was not covered by the CVRA. Interestingly, the letter also advised
+3
+
+
+i6-KAМ Document 9
+Entered on FLSD Docket 07/:
+18 Page 4 of 17
+Petitioner that "if you believe that the rights set forth above (e.g., the right to confer and other
+CVRA rights] are being violated, you have the right to petition the Court for relief." Id. at 1.
+If there were any doubt that the drafters of the CVRA intended for its rights to extend to
+pre-indictment situations, they disappear in light of the CVRA's instruction that a crime victim
+w10 secks to assert rights in pre-indictment situations should proceed in the court where the
+crime was committed: "The rights described in subsection (a) [of the CVRA] shall be asserted in
+the district in which a defendant is being prosecuted for the crime or, if no prosecution is
+underway, in the district court in the district in which the crime occurred." 18 U.S.C. §
+3:71 (d)(3) (emphasis added). Petitioner noted the importance of this language in her opening
+Petition, see Emergency Victim's 5, but the Government chose not to discuss it in its reply.
+In a case remarkably similar to this one, the Fifth Circuit has recently held that victims
+have a right to confer with federal prosecutors even before any charges are filed. In In re Dean,
+527 F.3d 391, 394 (5"' Cir. 2008), a wealthy corporate defendant reached a generous plea deal
+with the Government - a deal that the Government concluded and filed for approval with the
+district court without conferring with the victims. When challenged on a mandamus petition by
+the victims, the Fifth Circuit held:
+The district court acknowledged that "[t]here are clearly rights
+under the CVRA that apply before any prosecution is underway."
+BP Prods., 2008 WL 501321 at *11, 2008 U.S. Dist. LEXIS
+12893, at *36. Logically, this includes the CVRA's establishment
+of victims' "reasonable right to confer with the attorney for the
+ascertain the victims' views on the possible details of a plea bargain.
+Id. at 394.
+4
+
+
+3-KAM Document 9
+8 Page 5 of 17
+As we understand the Government's response, it asks this Court to decline to follow the
+Fifth Circuit's holding and create a split of authority on this important issue. See Gov't Resporse
+at 2-3. Notably, the Government does not cite any cases supporting its position. Instead, the
+Government would have this Court deviate from the Fifth Circuit's well-reasoned opinion because
+the Circuit's "discussion of the scope of the right to confer was unnecessary because the court
+ultimately declined to issue mandamus relief." Gov't Response at 2 (citing Dean, 527 F.3d at
+395). This is simply untrue. The Fifth Circuit faced a petition for mandamus relief from the
+victims in that case, asking that a proposed "binding" plea agreement negotiated under Fed. R.
+Crim. P. 1(c)(1)(C) (i.e., a plea agreement obligating the judge to impose a specific sentence) be
+rejected. The victims asked for that relief because of the Government's failure to confer with
+them before the charges and accompanying plea agreement were filed. The Fifth Circuit held fat
+the victims' rights had been violated in the passages quoted above. It then went on to remand he
+matter to the district court for further consideration of the effect of the violations of the victins"
+rights:
+We are confident, however, that the conscientious district court will fully consider
+the victims' objections and concerns in deciding whether the plea agreement should
+be accepted.
+The decision whether to grant mandamus is largely prudential. We conclude that
+he better course is to deny relief, confident that the district court will take hee
+hat the victims have not been accorded their full rights under the CVRA and wi
+carefully consider their objections and briefs as this matter proceeds.
+527 F.3d at 396. Obviously, the Fifth Circuit could not have instructed the District Court to "take
+heed" of the violations of victims' rights unless it has specifically held, as a matter of law, that tre
+victims' rights had been violated.
+The Government's next effort to deflect the force of the Fifth Circuit's decision is that the
+5
+
+
+18 Page 6 of 17
+Circuit did not directly quote three words found in the CVRA's right to confer - the words "in
+the case." See Gov't Response at 2. But the Fifth Circuit had received briefs totaling close to
+100 pages in that case and was obviously well aware of the statute at hand. Indeed, in the very
+paragraph the Government claims is troublesome, the Fifth Circuit cited to the district court
+opinion under review, which had quoted all the words in the statute. See United States |. BP
+Producis, 2008 WL 501321 at *7 (noting victims right to confer "in the case"), cited in In re
+Dean, 527 F.3d at 394.
+The Government finally notes that the Fifth Circuit properly stated that its ruling about the
+Government violating the right to confer applied "in the posture of this case." 527 F.3d at 394.
+But the posture of this case - at least in its relevant aspects -- is virtually identical to the posture
+there. The Fifth Circuit held that the Government had an obligation to confer with the victims
+before charges were filed and before a final plea arrangement was reached. Without giving the
+victims a chance to confer before hand, the plea agreement might be fatally flawed because it did
+not consider the concerns of the victims. Thus, the Fifth Circuit emphasized the need to confer
+with victims before any disposition was finally decided: "The victims do have reason to believe
+that their impact on the eventual sentence is substantially less where, as here, their input is
+received after the parties have reached a tentative deal. As we have explained, that is why we
+conclude that these victims should have been heard at an earlier stage." Id. at 395. The posture
+in this case is exactly the same - the Government should have conferred before the parties
+"reached a tentative deal." The fact that the deal reached here is slightly different than the deal
+reached in the Dean case (a non-prosecution agreement versus a plea agreement) is truly a
+distinction without a difference. If anything, the facts here cry out for conferral even more than in
+6
+
+
+18 Page 7 of 17
+that case. At least the defendant there agreed to plead guilty to a federal felony. Here, the
+wealthy defendant has escaped all federal punishment - a plea deal that Petitioner would have
+strenuously objected to ... if the Government had given her the chance.
+The Fifth Circuit's decision in Dean has been cited in one very recent District Court
+decision, which provides further support for Petitioner's position here. In United States | Rubin,
+20(18 WI. 2358591 (E.D.N.Y. 2008), the victims argued for extremely broad rights under the
+CVRA. After citing Dean, the District Court agreed that the rights were expansive and could
+apply before indictment, but subject to the outer limit that the Government be at least
+"contemplating" charges:
+Quite understandably, movants perceive their victimization as having begun long
+before the government got around to filing the superseding indictment. They also
+believe their rights under the CVRA ripened at the moment of actual victimization,
+or at least at the point when they first contacted the government. Movants rely on
+a decision from the Southern District of Texas for the notion that CVRA rights
+apply prior to any prosecution. In United States |. BP Products North America,
+Inc., the district court reasoned that because § 3771(d)(3) provided for the
+assertion of CVRA rights "in the district court in which a defendant is being
+prosecuted for the crime or, if no prosecution is underway, in the district court in
+the district in which the crime occurred," the CVRA clearly provided for "rights...
+that apply before any prosecution is underway." (United States. BP Products
+North America, Inc., Criminal No. H-07-434, 2008 WL 501321 at *11 (S.D.Tex.
+Feb.21, 2008) (emphasis in original), mandamus denied in part, In re Dean, No.
+corresponding investigation is at a nascent or theoretical stage.
+Id. ilt *6. Here, of course, the criminal investigation went far beyond the "nascent or theoretical
+7
+
+
+18 Page 8 of 17
+stage" - to a point where the Government determined that crimes had been committed and that
+the defendant should plead guilty to either a state or federal offense.
+For all these reasons, the Court should follow the Fifth Circuit and hold that Petitioner and
+the other victims in this case had the right to confer with the Government before it reached its
+nor-prosecution agreement.
+II.
+THE GOVERNMENT HAS NOT USED ITS "BEST EFFORTS" TO COMPLY
+WITH THE CRIME VICTIM'S RIGHTS ACT.
+The Government next argues that it has somehow used its "best efforts" to comply with
+the CVRA in this case. Gov't Response at 3. The bulk of the Government's arguments concern
+varous notices that it sent to victims. Buried in the middle of these arguments is the
+Government's stark concession that proves Petitioner's claim: "(T)he specific terms of the
+negotiation were not disclosed prior to a final agreement being reached because the Government
+believed doing so would jeopardize and prejudice the prosecution in the event an agreement
+could not be made." Gov't Response at 6 (emphasis added). In other words, Petitioner - and the
+mary other victims of the defendant's federal sex offenses - was deliberately kept in the darl
+about the fact that the Government was planning to reach a deal that would permit the defendant
+to escape all federal punishment in favor of an 18-month county jail sentence. This bald decision
+to conceal from the victims what was happening violated the basic premise of the Crime Victim's
+Rights Act: that victims deserve to know what is happening in their cases. Congress was
+concerned that in the federal system crime victims were "treated as non-participants in a critical
+event in their lives. They were kept in the dark by prosecutors too busy to care enough ... and by
+a court system that simply did not have a place for them." 150 CONG. REC. S4262 (Apr. 22.
+2004) (statement of Sen. Feinstein). To remedy this problem, Congress gave victims "the simple:
+8
+
+
+18 Page 9 of 17
+right to know what is going on, to participate in the process where the information that victiras
+and their families can provide may be material and relevant...." Id.
+The CVRA required the Government to confer with Petitioner and consider her viev/s
+about the proposed arrangement in this case. Indeed, the Government's own regulations require
+prosecutors to "consider victims' views about prospective plea negotiations." U.S.DEP'T OF
+JUSTICE OFFICE FOR VICTIMS OF CRIME, ATTORNEY GENERAL GUIDELINES FOR VICTIMS AND
+WITNESS ASSISTANCE 30 (2005). Congress obviously intended for victims to have a meaningfal
+role in the criminal justice process.
+The Fifth Circuit recently confronted - and rejected - a very similar claim from the
+Government that it did not need to meaningfully confer with crime victims.
+There, the
+Government's purported justification for failing to confer was the risk of pre-trial publicity to the
+defendant.
+• The Fifth Circuit summarily dismissed that argument, holding: "Congress made the
+policy decision -- which we are bound to enforce -- that the victims have a right to inform the plea
+negotiation process by conferring with prosecutors before a plea agreement is reached." Id. it
+395. In this case, too, this Court is "bound to enforce" Congress' decision that prosecutors
+confer with victims before reaching a plea agreement.
+The Government is not entitled to pick and choose which particular cases it will give
+victims the right to confer. In support of its remarkable position, the Government cites il
+provision in the CVRA that provides that "InJothing in this chapter shall be construed to impair
+the prosecutorial discretion of the Attorney General or any officer under his direction." 18 U.S.C.
+§ 3771(d)(6). But the Government made the same argument in the Dean case - and lost. The
+Fifth Circuit reversed the District Court decision that enforcing the right to confer might impair
+9
+
+
+3-КАМ Document 9
+8 Page 10 of 17
+prosecutorial discretion with the following statement: "[Giving the right to confer to victims] is
+not an infringement, as the district court believed, on the government's independent prosecutor. al
+discretion, ... instead, it is only a requirement that the government confer in some reasonable
+way with the victims before ultimately exercising its broad discretion." 574
+Moreover, the Government's asserted justification for failing to confer is transparently
+flinsy. It asserts that, if the vietims had been told that the plea agreement gave them advantages
+in civil litigation against the defendant, then that would have "provided] Epstein the means of
+impeaching the victim witnesses ...." Gov't Response at 5. But obviously the victirns were
+already subject to impeachment on that ground - even if no plea agreement was ever reached.
+The defense attorneys presumably would have asked all of the victims at any criminal trial about
+the possibility that they could pursue civil litigation against the defendant if he was convicted.
+The plea agreement did not change the obvious fact that a criminal conviction - whether by plea
+agreement or by jury trial - would facilitate civil claims by the victims of the defendant's crimes.
+In light of all this, this Court should reach the obvious conclusion: The Government did
+not use its "best efforts" to protect the rights of Petitioner (and the other victims) in this case
+when it failed to confer with her about the non-prosecution agreement.
+III. THE GOVERNMENT DID NOT CONFER WITH PETITIONER.
+The Government finally makes a factual argument about the state of negotiations in this
+case. The brief discussion (see Gov'ts Response at 7-8) is somewhat vague. One short passage
+in the response, however, seems to assert that Petitioner was given some sort of notice about the
+plea agrcement about nine months ago. Gov't Response at 7 ("In October 2007, C. W. was not
+represented by counsel.... She was given telephonic notice of the agreement, as were three other
+10
+
+
+Case 9:08-cv-l
+Document 9
+Entered on FLSD Docket 07/1:
+3 Page 11 of 17
+victims.").
+If the Government is asserting that Petitioner was told that a non-prosecution agreement
+had been reached with the defendant as early as October 2007, Petitioner strongly disputes this
+alleged "fact." To the contrary, undersigned counsel was told by federal prosecutors within the
+last 60 days that a federal "indictment" was under consideration.
+Petitioner does not believe that the Government is truly asserting that she was told about a
+nol-prosecution agreement because, elsewhere in its brief, the Government makes the opposite
+assertion: "[T)he specific terms of the negotiation were not disclosed prior to a final agreement
+being reached because the Government believed doing so would jeopardize and prejudice the
+presecution in the event an agreement could not be made." Gov't Response at 6 (emphasis
+addled).
+Because of the confusion about what the Government is truly asserting, Petitioner
+requests an opportunity to address the facts directly with the Court at the hearing. If necessary,
+Petitioner also requests leave of Court after the hearing to provide whatever supplemental
+information (by way of affidavit or otherwise) that would be needed to prove that she was never
+toll that the Government was considering a federal non-prosecution agreement with the
+defendant, much less given a chance to confer with the Government on this extraordinarily lenient
+disposition.
+IV. THE COURT SHOULD ENTER AN ORDER DIRECTING THE GOVERNMENT
+TO CONFER WITH THE PETITIONER BEFORE ANY NON-PROSECUTION
+AGREEMENT BECOMES FINALIZED.
+For all these reasons, it is obvious that Petitioner's right to confer was violated in this
+case. The question then arises as to the appropriate remedy. The obvious remedy is to declare
+
+
+3-КАМ Document 9
+8 Page 12 of 17
+the non-prosecution agreement illegal and direct that the Government proceed to negotiate a new
+agreement - in a process that respects Petitioner's (and the other victims') rights.
+The non-prosecution agreement here violates federal law. As described by the
+Government (the victims have not been even given the courtesy of a copy of the agreement), tre
+agreement prevents federal prosecution of the defendant for numerous sex offenses. Yet the
+agreement was reached without giving Petitioner her right to confer - a violation of 18 U.S.C. §
+3771(a)(5).
+When other plea arrangements have been negotiated in violation of federal law, they have
+been stricken by the courts. For example, United States | Walker, 98 F.3d 944 (7th Cir. 1996),
+held that where a sentence on a new crime could not run concurrently with a probation revocation
+the defendant was then serving - contrary to the assumption of the parties to the plea agreement -
+the defendant was not entitled to specific performance of the plea agreement. The Court
+explained that the case was one "in which the bargain is vitiated by illegality...." Here, of
+course, exactly the same is true: the non-prosecution agreement is vitiated by illegally - namely,
+the fact that it was negotiated in violation of the victims" rights. Other cases reach similar
+conclusions. See, e.g., United States | Cooper, 70 F.3d 563 (10" Cir. 1995) (prosecutor agreed
+to recommend probation, but it now appears that would be an illegal sentence in this case, and
+thus the only adequate remedy is to allow defendant to withdraw the plea); Craig I People, 986
+P.2d 951 (Colo. 1999) (because "neither the prosecutor nor the trial court have authority to
+modify or waive the mandatory parole period," such "is not a permissible subject of plea
+negotiations," and thus, even if "the trial court erroneously approves of such an illegal bargain"
+such plea is "invalid" and thus will not be specifically enforced). Nor can the defendant clairn
+12
+
+
+i-KAM Document 9
+3 Page 13 of 17
+soine right to specific performance of an illegal non-prosecution agreement. See State. Garcia,
+58.2 N. W.2d 879 (Minn. 1998) (plea agreement for 81 months sentence, but court added 10-year
+conditional release term because, under facts of case, a sentence without such release term was
+"plainly illegal," and thus the remedy of specific performance not available); State fy. Wall, 348
+N.C. 671, 502 S.E.2d 585 (1998) (plea agreement was for sentence to be concurrent with one not
+yet completed, but state statute mandates consecutive sentence on facts of this case; "defendant is
+not entitled to specific performance in this case because such action would violate the laws of this
+state"); Ex parte Rich, 194 S. W.3d 508 (Tex. Crim. App. 2006); (where "the plea bargain seemed
+fair on its face when executed, it has become unenforceable due to circumstances beyond the
+cortrol of [the parties], namely the fact that one of the enhancement paragraphs was
+mischaracterized in the indictment, resulting in an illegal sentence far outside the statutory range,"
+proper remedy is plea withdrawal, as "there is no way of knowing whether the State would have
+offired a plea bargain within the proper range of punishment that he deemed acceptable"); State
+Marzone:| W.Va. 368, 572 S.E.2d 891 (2002) (where plea agreement was that defendart
+would plead guilty to 2 felony counts of felon in possession of firearm and prosecutor would
+dismiss the remaining 6 counts re other offenses with prejudice, and all parties erroneously
+believed these 2 crimes were felonies, lower court "correctly resolved this unfortunat?
+predicament by holding that a plea agreement which cannot be fulfilled based upon legal
+impossibility must be vacated in its entirety, and the parties must be placed, as nearly as possible,
+in the positions they occupied prior to the entry of the plea agreement").
+This Court is obligated to take steps to protect Petitioner's rights. Under the CVRA, "li)n
+any court proceeding involving an offense against a crime victim, the court shall ensure that the
+13
+
+
+Entered on FLSD Docket 07/11 ; Page 14 of 17
+crime victim is afforded the rights described in [the CVRA]." 18 U.S.C. § 3771(b)(I). The
+CVRA also confers on crime victims the right to "assert the rights described in [the CVRA]." 18
+U.S.C. § 3771(d)(1). Obviously there is now a court proceeding before this Court in which
+Petitioner is asserting rights under the CVRA. This Court must therefore protect her rights py
+declaring the non-prosecution agreement invalid.
+I.
+THE PUBLIC IS ENTITLED TO SEE THE GOVERNMENT'S EXPLANATIONS
+FOR
+ITS
+EXTRAORDINARILY LENIENT
+NON-PROSECUTION
+AGREEMENT.
+The Government has also filed its pleadings in this matter under seal. There is no sound
+reason for concealing from the public the Government's explanations in this matter. Accordingly,
+the Government's pleadings should be unsealed.
+The Government offers two explanations for sealing its pleadings. First, the Government
+claims that the pleading would reveal correspondence with minors. Gov't Motion at 1. But the
+Government has redacted the names of the minors involved (including Petitioner's name), so there
+is no good basis for sealing. (Counsel does respectfully request that the Government doublecheck its redactions to make sure that no name has been overlooked.) Indeed, the very statute
+that the Government cites (18 U.S.C. § 3509(d)(2)) envisions that minors' names will be redacted
+and then the remaining pleadings made available to the public. See 18 U.S.C. § 3509(d)(2) (The
+perion who makes a filing [involving a minor] shall submit to the clerk of the court ... the paper
+with the portions of it that disclose the name of or other information concerning a child redacted,
+to be placed in the public record"') (emphasis added).
+Second, the Government asserts that its pleading should be kept under seal "to maintain
+the confidentiality of the agreement reached with an interested party." Gov't Motion at 2.
+14
+
+
+Entered on FLSD Docket 07/11
+} Page 15 of 17
+Petitioner believes exactly the opposite is true - confidentiality will undermine public confidence
+in the federal criminal justice system.
+This case involves a non-prosecution agreement with a politically-connected billionaire
+that has drawn considerable public attention. See, e.g., Palm Beach Post.Com, Banker Epstein
+Pleads in Prostitution Case, Gets 18 Months (June 30, 2008) ("He lives in a Palm Beach
+waterfront mansion and has kept company with the likes of President Bill Clinton, Prince Andrew
+and Donald Trump, but investment banker Jeffrey Epstein will call the Palm Beach County jail
+ho me for the next 18 months"). The public is entitled to know all of the circumstances
+surrounding this federal (non) prosecution. The public may well wonder - as Petitioner does in
+this case - why a defendant who committed multiple sex crimes over an extended period of time
+aguinst numerous minor victims is receiving only an 18-month jail sentence and a "free pass" fron
+the federal government. If the Government had conferred with Petitioner, she would have
+explained why this proposed disposition did not begin to reflect "the seriousness of the offense "
+18 U.S.C. § 3553(a)(2)(A).
+The Eleventh Circuit has instructed that the district courts must make substantial findings
+before scaling records in cases before it. For instance, in United States | Ochoa-Vasque, 428
+F.3d 1015 (11" Cir. 2005), it reversed an order from this Court that had sealed pleadings in a
+criminal case, emphasizing the importance of the public's historic First Amendment right of access
+to the curts. To justify sealing, "a court must articulate the overriding interest along with
+finclings specific enough that a reviewing court can determine whether the closure order was
+properly entered." Id. at 1030. The Government has not discussed the controlling court
+authority on sealing orders, much less attempted to prove that there is an "overriding interest"
+15
+
+
+Case 9:08-CV-8
+Entered on FLSD Docket 07/11.
+
+justifying sealing. For this reason, the Government's attempts to keep secret what has been done
+in this case should be rejected and its motion for sealing of its response denied.
+CONCLUSION
+The Petitioner requests the intervention of this Court to ensure that her rights are
+respected and accorded, as promised in the Crime Victims' Rights Act. The Court should enter
+an order finding the non-prosecution agreement in this case was negotiated in violation of the
+CVRA and therefore is illegal and invalid. The Court should also deny the Government's motion
+to seal its pleadings in this case.
+DATED this Ith day of July, 2008.
+Respectfully Submitted,
+THE LAW OFFICE OF BRAD EDWARDS &
+ASSOCIATES, LLC
+BRaL
+Florida Bar #542075
+2028 Harrison Street
+Suite 202
+Hollywood, Florida 33020
+Telephone:
+954-414-8033
+
+
+Entered on FLSD Docket 07/11
+¡ Page 17 of 17
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
+provided by hand delivery in open court to the Attorney appearing on behalf of the United States
+Attorney's Office, this 11h day of July, 2008.
+17
+
+
+30% P.C. W.
+
+
+i6-KAM Document 4
+Entered on FLSD Docket 07/l
+38 Page 1 of 2
+CASE NO. 08-80736-CIV-MARRA/JOHNSON
+IN RE: JANE DOE,
+Petitioner.
+!
+NOTICE OF ENTRY OF APPEARANCE FOR RESPONDENT
+UNITED STATES OF AMERICA
+Assistant United States Attorney Dexter A. Lee enters his appearance on behalf of the
+respondent, United States of America.
+The undersigned respectfully requests that notices,
+orders, and other documents be sent to the undersigned at:
+99 N.E. 4" Street, Suite 300
+Miami, Florida
+(305) 961-9320
+Fax: (305) 530-7139
+E-mail: dexter.lee@usdoj.gov
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+Fla. Bar No. 0936693
+99 N.E. 4" Street
+(305) 961-9320
+Fax: (305) 530-7139
+E-mail: dexter.lee@)usdoj.gov
+
+
+i6-KAM Document 4
+18 Page 2 of 2
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on July 9, 2008, I electronically filed the foregoing document
+with the Clerk of the Court using CM/ECF.
+s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+SERVICE LIST
+In Re Jane Doe
+Case No. 08-80736-CIV-MARRA/JOHNSON
+United States District Court, Southern District of Florida
+Brad Edwards, Esq.
+The Law Office of Brad Edwards & Associates, LEC
+2028 Harrison Street, Suite 202
+Hollywood, Florida 33020
+Attorney for Jane Doe
+2
+
+
+RECYCLED•
+
+
+Case 9:08-Cv:
+6-KAM Document 3
+38
+
+NO. 08-80736-CIV-MARRA/JOHNSON
+IN RE: JANE DOE,
+Petitioner
+/
+ORDER
+THIS CAUSE comes before the Court on Plaintiff's Emergency Petition for Enforcement
+of Crime Victim's Rights Act (DE 1), filed July 7, 2008. It is hereby ORDERED that the United
+States' Attorney shall file a response to this petition by 5:00 P.M. on Wednesday, July 9, 2008.
+DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County,
+Florida, this 7" day of July, 2008.
+KENNETH A. MARRA
+United States District Judge
+R. Alexander Acosta, United States' Attorney
+
+
+RECYCLED •
+
+
+i6-KAM Document 2
+Entered on FLSD Docket 07/C
+CASE NO.
+08-80736-Civ-MARRA/JOHNSON
+8 ECT 1 EXA D.C.
+JULY 7, 2008
+Inre:
+Jane
+poe
+V.
+United States
+of America
+Plaintif
+Defendant
+CERTIFICATION OF EMERGENCY
+I hereby certify that, as a member of the Bar of this Court, I have carefully examined this matter and it is a true
+emergency.
+I further certify that the necessity for this emergency hearing has not been caused by a lack of due diligence
+in my part, but has been brought about only by the circumstances of this case. The issues presented by this matter hav
+ot been submitted to the Judge assigned to this case or any other Judge or Magistrate Judge of the Southern Distric
+of Flerida prior hereto.
+I further certify that I have made a bona fide effort to resolve this matter without the necessity of emergency
+action.
+Dated this
+day of July
+Signature:
+-
+Print Name:
+Brad
+Florida Bar Number:
+Telephone Number:
+
+954-414-8033
+************************************************
+...=
+*****
+I hereby certify that the Judge assigned to this case is unavailable for this emergency (a copy of his/her
+notification to the Clerk is on file). In accordance with Local Rule 3.7, the Honorable
+was randomly drawn from the Emergency Wheel.
+Dated:
+STEVEN M. LARIMORE
+Court Administrator • Clerk of Court
+By:_
+Deputy Clerk
+1 of 1
+
+
+RECTCLED O
+
+
+Entered on FLSD Docket 07/07
+JULY 7, 2008
+08-80736-Civ-MARRA/JOHNSON
+CASE NO.:_
+IN RE: JANE DOE,
+Petitioner.
+Emergency VICTIM'S PETITION FOR ENFORCEMENT OF
+CRIME VICTIM'S RIGHTS ACT, 18 U.S.C. SECTION 3771
+COMES NOW the Petitioner, JANE DOE (hereinafter "Petitioner"), by and through her
+undersigned attorneys, pursuant to the Crime Victim's Rights Act, 18 U.S.C. Section 3771
+("CVRA"), and files this Petition for Enforcement in the above styled action as follows:
+1.
+Petitioner, an adult, as a minor child was a victim of federal crimes committed by
+JEFFREY EPSTEIN (hereinafter "Defendant"). These crimes included sex trafficking of
+children by fraud, in violation of 18 U.S.C. § 1591, use of a means of interstate commerce to
+entice a minor to commit prostitution, in violation of 18 U.S.C. § 2422, as well as wire fraud, in
+violation of 18 U.S.C. § 1343. The Defendant committed these crimes within the jurisdiction of
+the Southern District of Florida in Palm Beach County, Florida.
+2.
+Upon information and belief, the Defendant is the subject of a federal criminal
+investigation conducted by the United States of America in the Southern District of Florida. The
+Defendant has recently been prosecuted and pleaded guilty, on June 30, 2008, in the Circuit
+Court for Palm Beach County to various similar state offenses including solicitation of minors
+for prostitution.
+Upon information and belief, the Defendant is engaged in plea negotiations with
+the Office of the United States Attorney for the Southern District of Florida concerning federal
+1 ot 10
+
+
+i-KAM Document 1
+Entered on FLSD Docket 07/0'
+8 Page 2 of 10
+crimes which he is alleged to have committed against minor children, including the Petitioner.
+Such negotiations may likely result in a disposition of the charges in the next several days.
+4.
+Under the CVRA, before any charges are filed against the Defendant, the
+Petitioner has the rights (among others) to notice of her rights under the CVRA, to confer with
+the prosecutors, and to be treated with fairness. As soon as charges are filed, the Petitioner has
+the rights (among others) to timely notice of court proceedings, the right not to be excluded from
+such proceedings, the right to be heard at such public proceedings regarding conditions of
+release, any plea, and any sentence, the right to confer with the attorney for the government, the
+right to restitution, and the right to be treated with fairness and with respect for her dignity and
+privacy.
+5.
+The Petitioner has been denied her rights in that she has received no consultation
+with the attorney for the government regarding the possible disposition of the charges, no notice
+of any public court proceedings, no information regarding her right to restitution, and no notice
+of rights under the CVRA, as required under law.
+6.
+The Petitioner is in jeopardy of losing her rights, as described above, if the
+government is able to negotiate a plea or agreement with the Defendant without her participation
+and knowledge.
+WHEREFORE, for the reasons outlined above, the Petitioner respectfully requests this
+Court to grant her Petition, and to order the United States Attorney to comply with the provisions
+of the CVRA prior to and including any plea or other agreement with the Defendant and any
+attendant proceedings.
+2
+2o110
+
+
+i-KAM Document 1
+Entered on FLSD Docket 07/0;
+3 Page 3 of 10
+MEMORANDUM
+1.
+THE CRIME VICTIMS' RIGHTS ACT MAKES CRIME VICTIMS
+INDEPENDENT
+PARTICIPANTS
+THROUGHOUT
+THE
+CRIMINAL JUSTICE PROCESS.
+In October 2004, Congress passed and the President signed into law the Crime Victims'
+Rights Act, Pub. L. No. 108-405, 118 Stat. 2251 (codified at 18 U.S.C. § 3771). Because this
+appears to be the first case involving the Act to come before this Court, a bit of background may
+be in order.
+The CVRA Gives Crime Victims Rights to Participate in the Criminal Justice
+Process.
+Congress passed the CVRA "to give crime victims enforceable rights to participate in
+federal criminal proceedings." Opinion at 14. Congress was concerned that in the federal system
+crime victims were "treated as non-participants in a critical event in their lives. They were kept
+in the dark by prosecutors too busy to care enough ... and by a court system that simply did not
+have a place for them." 150 CoNG. REC. S4262 (Apr. 22, 2004) (statement of Sen. Feinstein).
+To remedy this problem, Congress gave victims the simple right to know what is going on, to
+participate in the process where the information that victims and their families can provide may
+be material and relevant ..." Id.
+The CVRA gives victims of federal crimes a series of rights, including the right to notice
+of court proceedings, to be heard at plea and sentencing hearings, and to reasonably "confer with
+the attorney for the Government in the case." 18 U.S.C. § 3771(a). Vietims also have a "right
+of access to the terms of a plea agreement ...." In re Interested Party I, 530 F.Supp. 2d 136,
+2008 WL 134233 at *7 (D.D.C. 2008). The CVRA also assures victims broadly that they will
+"be treated with fairness." 18 U.S.C. § 3771(a)(8).
+3
+3 of 10
+
+
+Entered on FLSD Docket 07/0:
+3 Page 4 of 10
+Of course, these rights would be of little use to most crime victims unless they were told
+about them. To ensure that victims are notified of their rights, the CVRA directs employees of
+the Justice Department "and other departments and agencies of the United States engaged in the
+detection, investigation, or prosecution of crime" to use their "best efforts to see that crime
+victims are notified of ... the rights described [in the CVRA]." 18 U.S.C. § 3771(c)(1) (emphasis
+added).1
+B.
+The CVRA Gives Vietims Rights During the Investigation of a Crime.
+The CVRA gives victims rights during the investigation of a crime. The Fifth Circuit
+recently reached this conclusion, holding:
+In re Dean, 527 F.3d 391, 394 (5'" Cir. 2008).
+The position that CVRA rights apply before charges have been filed is consistent with the
+Justice Department regulations under the CVRA, which explain that government officials "must
+advise a victim [about their rights under the CVRA] ... at the earliest opportunity at which it may
+be done without interfering with an investigation." A.G. GUIDELINES FOR VICTIM AND WITNESS
+suspected offender."
+4
+4 of 10
+
+
+Entered on FLSD Docket 07/0:
+3 Page 5 of 10
+ASSISTANCE 23 (May 2005). And the plain language of the CVRA undergirds this conclusion, as
+it applies not simply to prosecutors but to government agencies "engaged in the detection [and]
+investigation... of crime …. " 18 U.S.C. § 3771(c)(1). Indeed, if there were any doubt, the plain
+language of the CVRA extends victims" right to situations "in which no prosecution is
+underway." 18 U.S.C. § 3771(d)(3).
+II. PETITIONER IS A "VICTIM PROTECTED BY THE CVRA.
+Under the CVRA the crime victim is defined as "a person directly and proximately
+harmed as a result of the commission of a Federal offense ..." 18 U.S.C. Section 3771(e). In
+particular, Defendant called Petitioner when she was a minor over a telephone (a means of
+interstate communication) requesting that she perform a massage in exchange for payment. As
+Defendant well knew, that request was fraudulent, as he not only intended to receive a massage,
+but also intended to have her perform sexual acts in exchange for a cash payment to Petitioner.
+Only when Petitioner arrived at a Defendant's mansion as directed by Defendant, did Defendant
+reveal his true purpose of obtaining sexual favors in exchange for payment. This conduct
+violated 18 U.S.C. § 2422, which forbids using a means of interstate commerce to knowingly
+"induce" or "entice" a minor "to engage in prostitution." In addition, this conduct was both a use
+of "fraud" to obtain a commercial sex act, in violation of 18 U.S.C § 1591, and use of wire
+communications to perpetrate a "scheme and artifice to defraud," in violation of 18 U.S.C. §
+1343.
+It appears obvious that Petitioner was "directly and proximately" harmed by these crimes,
+thereby making her a victim under the CVRA. It should be emphasized that the CVRA "was
+designed to be a 'broad and encompassing' statutory victims' bill of rights." United States l
+5
+5 of 10
+
+
+Entered on FLSD Docket 07/0
+8
+
+Degenhardt, 405 F.Supp.2d 1341, 1342 (D. Utah 2005) (quoting 150 Cong. Rec. S4261 (daily
+ed. Apr. 22, 2004) (statement of Sen. Feinstein)). Congress intended the CVRA to dramatically
+rework the federal criminal justice system. In the course of construing the CVRA generously, the
+Ninth Circuit observed: "The criminal justice system has long functioned on the assumption that
+crime victims should behave like good Victorian children -- seen but not heard. The Crime
+Victims' Rights Act sought to change this by making victims independent participants in the
+criminal justice process." Kenna . U.S. Dist. Court for C.D. Cal., 435 F.3d 1011, 1013 (9th Cir.
+2006). Accordingly, because the CVRA is remedial legislation, courts should interpret it
+"liberally to
+facilitate and accomplish its purposes and intent." Elliott Industries Lid.
+Partnership |. BP America Production Co., 407 F.3d 1091, 1118 (10th Cir. 2005) (noting
+remedial legislation should be "interpreted liberally to facilitate and accomplish its purposes and
+intent"). The CVRA itself suggests this conclusion by requiring that courts must treat crime
+victims with "fairness." United States |. Patkar, 2008 WL 233062 at *3 (D. Haw. 2008) (citing
+United States 1. Turner, 367 F.Supp.2d 319, 335 (E.D.N.Y. 2005)).
+Not only must the CVRA as a whole be interpreted liberally, but its definition of "crime
+victim" requires a generous construction. After reciting the direct-and-proximate-harm language
+at issue here, one of the Act's two co-sponsors -- Senator Kyl -- explained that "[t]his is an
+intentionally broad definition because all victims of crime deserve to have their rights protected
+...:" 150 Cong. Rec. S10912 (Oct. 9, 2004) (emphasis added). The description of the victim
+definition as "intentionally broad" was in the course of floor colloquy with the other primary
+sponsor of the CVRA and therefore deserves significant weight. See Kenna, 435 F.3d at 1015-16
+(discussing significance of CVRA sponsors= floor statements).
+6
+6 of 10
+
+
+Entered on FLSD Docket 07/0
+8 Page 7 of 10
+The definition of "crime victims" must thus be construed broadly in favor of Petitioner.
+She obviously qualifies as a "victim" under the CVRA.
+III. PETITIONER IS ENTITLED TO NOTICE OF HER RIGHTS, AN
+OPPORTUNITY TO CONFER WITH THE PROSECUTORS AND
+TO BE TREATED WITH FAIRNESS.
+Because Petitioner is a "victim" under the CVRA, she has certain protected rights under
+the Act. Most important, the Act promises that she will have an opportunity to "confer with the
+attorney for the Government in the case." To date, Petitioner has not been given that right. This
+raises that very real possibility that the Government may negotiate and conclude a plea agreement
+with the Defendant without giving Petitioner her protected rights.?
+Petitioner is entitled to have this conference with prosecutors before any final plea
+agreement is reached. The Fifth Circuit reached exactly this conclusion in a very recent case. In
+In re Dean, 527 F.3d 391 (5" Cir. 2008), the Government negotiated a plea agreement with the
+well-heeled corporate defendant without conferring with the victims. When the Government's
+failure was challenged in the Fifth Circuit, the Fifth Circuit concluded that the Government had
+indeed violated the CVRA. The Fifth Circuit observed: "In passing the [CVRA], Congress
+made the policy decision-which we are bound to enforce-that the victims have a right to inform
+the plea negotiation process by conferring with prosecutors before a plea agreement is reached."
+Id. at 394.
+This Court is obligated to protect the rights of Petitioner. The CVRA directs that "i)n
+any court proceeding involving an offense against a crime victim, the court shall ensure that the
+2 in or are and ete retreate one er their saint several other young females. These
+7
+7 of 10
+
+
+Entered on FLSD Docket 07/0
+18
+
+crime victim is afforded the rights described in [the CVRA]." 18 U.S.C. § 3771(b)(1). The
+CVRA also confers on crime victims the right to "assert the rights described in [the CVRA]." 18
+U.S.C. § 3771(d)(1). Therefore, this Court has its own independent obligation to intercede and
+ensure that the Government respects the rights of Petitioner under the CVRA.
+CONCLUSION
+The Petitioner requests the intervention of this Court to ensure that her rights are
+respected and accorded, as promised in the Crime Victims' Rights Act.
+DATED this 7th day of July, 2008.
+Respectfully Submitted,
+THE LAW OFFICE OF BRAD EDWARDS &
+ASSOCIATES, LLC
+Florida Bar #542075
+2028 Harrison Street
+Suite 202
+Hollywood, Florida 33020
+Telephone:
+954-414-8033
+8
+B of 10
+
+
+Entered on FLSD Docket 07/C
+18 Page 9 of 10
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
+provided by United States mail and via facsimile to: ANN MARIE C. VILLAFANA, AUSA,
+United States Attorney's Office, 500 South Australian Avenue, Suite 400, West Palm Beach,
+Florida 33401, this 7th day of July, 2008.
+9 of 10
+
+
+08-807360CiX
+ABRA JOHNSONEntered on FLSD Docket 07/0:
+8
+CIVIL COVER SHEET
+"he JS 44 civ I cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as
+ly local rules of court. This form, approved by the Judicial Conference of the United States in September | 974, is required for the use of the Clerk
+the civil cocket sheet, (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)
+NOTICE: Attorneys MUST Indicate All Re-filed
+1. (a) PLAINTIFFS
+DEFENDANTS
+In re: Jane Dol
+United Slates of
+ELECTRONIC
+JULY 7, 2008
+STEVEN M. LARIMORE
+CLERK
+U.S.
+DIST.
+CT.
+S. D.
+OF FLA. + MIAMI
+(b) County of Residence of First Listed Plaintiff
+Palm Bch,
+County of Residence of First Listed Defendant
+¡EXCEPT IN US. PLAINTIFF CASESI
+(IN L' S. PLAINTIFF C'ASES ONLY)
+(c) Altomey's Firm dame. Address, and Telephune Numberi
+NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT
+Lin office of Brad Edwards tAssoliates
+LAND INVOLVED.
+2028 Harrison Street
+Attomeys (1f Known)
+Svite 202
+Ann
+marie C. Villataña, VS. attys
+Hollywood
+33020
+office
+* Check County Where Action Arose:
+] MIAMI. DADE
+3 MONROES BROWARD X PALM BEACH > MARTIN J STLUCIE> INDIANRIVER > OKEECHOBEE
+HIGHLANDS
+I. BASIS OF JURISDICTION
+1 Place an "'*" in Une Box Only)
+HI. CITIZENSHIP OF PRINCIPAL PARTIES Plate an "X- in One Bas for PlaniT
+(For Diversity Cases Daly)
+and One Ins for Defendans)
+] 3 Federal Question
+PTF
+DEF
+PTF
+Plantif
+(US Governmens Yor a Party)
+Calven of This State
+] •
+Incorpuraied or Principal Place
++
+DEF
+al Business In This 5 ate
+X"s tramme
+Diversity
+Cilizen of Another Staie
+Incorporaled wed Pricipal Place
+Cele: dan:
+of Busidess Ie Another Stale
+(Indicale Calizenship of Parties in lies Il)
+08€
+80736 MARRA JOHNSON
+Cilizen or Subject of a
+1 Foreign Nation
+3 6
+Foreign Cuuntry
+JY. NATURE OF SUIT (Place in "X° in One Bas Ufly)
+CONTRACT
+TORTS
+PERSONAL INJURY
+PERSONAL INJURY
+130 Marine
+J 310 A rplane
+362 Personal lajury -
+iJ0 Miller Act
+J 315 A rplane Produet
+Med. Malpractice
+140 Negonable Instrunseei
+Liabiliy
+365 Personal Injury •
+150 Rec nery of Orerpayment
+> 320 Assault, Libel &
+Pradeet Liabilly
+& Er forcemeal of Judgment
+Slander
+36N Asbestos Personal
+• 151 Medicar Act
+3 330 Federal Employers'
+Injury Product
+152 Recovery of Defan led
+Liabilmy
+Libility
+Studins I mans
+3340 Marine
+PERSONAL PROPERTY
+(Es. Veterans)
+J J45 Marine Produce
+370 Other Fraud
+: 193 Reensery el Orerpayment
+Liability
+371 Truth in Lending
+of Veteran + Benerls
+7 350 Molor Vehrie
+3ND Other Personal
+* 160 Stockhelders" Sums
+J 355 Motor Vehicle
+Property Damage
+Product Liability
+J8S Property Damage
+* 105 Consue Product Liahity
+] 160 O-her Personal
+Product Liahility
+196 Fraccher
+REAL PROPERTY
+CIVIL RIGHTS
+PRISONER PETITIONS
+210 LanI Credemnaics
+3 441 Vating
+510 Motions la Vacale
+220 Forrelo-ure
+J 442 Einploymer
+Sentence
+230 Rent leise & Ejectment
+3 443 Hausing
+Habear Corpes:
+FORFEITURE PENALTY
+610 Agricelture
+120 Other Food & Drug
+625 Drug Relaied Seizure
+of Property 21 USC KKI
+A30 Liquor Laws
+040 R.R. & Truck
+450 Airline Rep.
+s60 Occupational
+HANKRUPTCY
+] +22 Appeal 2N USC 15M
+J 423 Withdraw al
+28 USC 157
+PROPERTY RIGHTS
+7 K20 Copyrights
+> X30 Patent
+> K4D Trademark
+Safeiy Healch
+590 Other
+LABOR
+SOCIAL SECURITY
+710 Fair Laber Standards
+3 КóI HIA (139500
+Act
+] 862 Black Lung (923)
+720 Labor/Mgml. Reiations
+J 86J DIW DIWW (405(g))
+730 Lubor/Mgmt.Reporling
+3 N64 SSID Tale XVI
+& Disclosure Act
+3 865 R51 gl
+740 Railway Labor Act
+FEDERAL TAX SUITS
+740 Ciher Labor Laigation
+3 N3Q Taves (L'.S. Plainhlf
+791 Empi. Ret. Inc. Securil:
+or Defendant)
+7 N7I IRS
+Third Party
+OTHER STATUTES
+u u
+400 Stare Reapporlionment
+410 Antairest
+430 Barks and Banking
+450 Commerce
+460 Deperiation
+470 Rackeseer Influenced and
+Corrupt Organizations
+48D C'onsemer Credi
+490 Calile Sat TV
+BID Selective Senice
+850 Sec alics Commoditits
+Exchange
+875 Curtamer Challenge
+12 L SC 3410
+890 Other Statulory Achions
+891 Agriculural Acts
+892 Eccsomic Stabilization Aci
+893 Environmental Mallers
+Ku Energs Allocation Act
+- -0 Tons 1o Land
+SECRETAI
+$95 Fresdom of lafarmation Act
+245 Tor Produce Liability
+J 444 Welfare
+535 Deash Penaly
+IM SUCRATION
+900 Appeal of Fee Deserminalio
+* 290 All 23cr Real Property
+445 Amer. * Disabilises
+Employment
+340 Mandamus & Other
+462 Naturalization
+Under I qual Access in Justice
+Application
+44h Amer. • Disabilies
+Other
+550 Cixil Rights
+463 Habeas Corpus-Alien
+Delainee
+Xan Other Cisit Rights
+→ 195 Prison Condition
+465 Oiher Immigration
+Netions
+950 Constilutionality of State
+Stat: Irs
+ORIGIN
+Original
+Prosecuing
+VI. RELATED/RE-FILED
+CASE(5).
+VII. CAUSE OF ACTION
+(Place an "X" in One Box Only)
+32 Removed from
+State Court
+Appeal to Distric
+Re-filed-
+(see Vi below) → 4 Reopened or D 3
+Transferred from J 6 Multidistrict
+Reopened
+another distriet
+0 7
+Judge from
+(specity)
+Litigation
+Magistrate
+Judament
+a) Re-filed Case DYES O NO
+b) Related Cases JYES J NO
+(See insiructions
+tacund page!:
+JUDGE
+DOCKET NUMBER
+Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless
+crime Victims Rights ACT
+18 USC 33771
+behalf of victim of sex offenses
+6e
+the CVRM
+TIlI. REQUESTED IN
+• CHECK IF THIS IS A CLASS ACTION
+COMPLAINT:
+UNDER F.R.C.P. 23
+A. BOVE INFORMATION IS TRUE & CORRECT TO
+THE BEST OF MY KNOWLEDGE
+CHECK YES only if demanded in complaint:
+J Yes J No
+SENATORGORATERNEY OF RECORD
+DATE
+7-7-08
+FOR OFFICE USE ONLY
+AMOUNT 350 0
+10 of 10
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
diff --git a/vision-fixhub/ds9-unparsed-05/d26e397452d08d1c25945f4e479de967272639cdd72c6c31e22297070509ab55.receipt.json b/vision-fixhub/ds9-unparsed-05/d26e397452d08d1c25945f4e479de967272639cdd72c6c31e22297070509ab55.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..dc6eb960bce69fe54f79ed89c31f5052a9dad950
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d26e397452d08d1c25945f4e479de967272639cdd72c6c31e22297070509ab55.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12571,
+  "dataset": "marble-joined",
+  "doc_id": "d26e397452d08d1c25945f4e479de967272639cdd72c6c31e22297070509ab55",
+  "engine": "marble-apple-vision",
+  "event_count": 245,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "7711b9140067792309cb1b9f48e2476daab6796e86c6448a81e59d3f5c475e9f",
+  "output_sha256": "f4de0a77bf22e8edd01cec7eb5ee4bf31f5b0257510230e827a21c8de8b66952",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/d3a6c06194a02118c8a37cb2b27f6ae543541197224639b76fdca8d57958d0b6.md b/vision-fixhub/ds9-unparsed-05/d3a6c06194a02118c8a37cb2b27f6ae543541197224639b76fdca8d57958d0b6.md
new file mode 100644
index 0000000000000000000000000000000000000000..ed34baa6eef97e0af78809f749b990b0a36c954b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d3a6c06194a02118c8a37cb2b27f6ae543541197224639b76fdca8d57958d0b6.md
@@ -0,0 +1,694 @@
+U.S. Department of lustice
+United States Anorney
+Sonuhern Districh of Florida
+R ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+vil: 150e
+Are, FL II13.
+(107 16/ 210 Глор
+December 19,2007
+DELIVERY BY FACSIMILE
+Lilly Ann Sanchez
+Fowler While Burnell, PA
+1395 Brickell Ave, 14" Floor -
+Miami, F. 33131
+Re: Jeffrey Epstein
+Dear Ms. Sanchez:
+I write to follow up on the December 14" meeting between defense counsel and the Epstein
+prosecutors, as well as our First Assistant, the Miami FBI Special Agent in Charge and mysell.' I
+write to you because lam not certain who among the defense team is the appropriate recipient of this
+Icter. I address issucs raised by several members of the defense team, and would thus ask that you
+please provide a copy of this lenter to all appropriate defense Icam members.
+First, I would like to address the Section 2255 issue." As / stated in my December 4' letter.
+my understanding is that the Non-Prosccution Agreement entered into between this Office and Mr.
+Epsicin responds to Mr. Epstein's desire to reach a global resolution of his state and federal criminal
+liability. Under this Agreement, this District has agreed to defer prosecution for chumerated sections
+'Over the past awe wecks, we have received several hundred pages of arguments and exhibus from defense counsel.
+This is not the fonum to respond to the several items raiscd, and our silence should not be interpret as agreement. I
+would, however, like to address one issue. Your December 11" letter states that as a result of defense counsel
+objections to the appointment process; the USAO proposed an addendum to the Agreement to provide for the esc ol
+an independent third party sclector. As I recall this matter, before I had any knowledge of defense counsel
+objections. I sua sponte proposed the Addendum to Mr. I elkowitz at an Oclober meeting in Palm Beach. I did thes
+in an anempt to avoid what 1 foresaw would likely be a litigious sclection process. It was oniy after 1 proposed this
+change that Mr. Lekowitz raised with me his enumerated concerns.
+* Section 2255 provides that: "fafny person who, while a minor, was a victims of a violation of (enumerated sections
+of Tale I8] and who suffers personal injury as a result of such violation.
+inity suc in any appropriate United States
+District Court and shall recover the acmal damages such person sustains and the cost of the suit, schung a
+reasonable antomcy's fcc."
+
+
+CABLULAVE UFFILE
+of Tille 18 in favor of prosecution by the State of Florida, provided that the Mr. Epstein sarisfies
+three gencral foderal interests: (1) Char Mir. Epstein plead guilty to a "registerable" stille oficuse. 2)
+that this state plea include a binding recommendation for a sufficient term of imprisonment and ill
+thal the Agreement not harm the interests of his victims
+With this in mind, I have considered defense counsel arguments regarding the Section 1225
+portions of the Agrement. As 1 previously observed, our intent has been to place the victims in the
+same position as they would have been had Mr. Epstein been convicted at trial No more: no less.
+From our mecting, it appears that the defense agrees that thes was the intent During the course of
+negotiations that intent was reduced to writing in Paragraphs 7 and X, which as / wrote previously.
+appear far from simple to understand. I would thus propose that we solve our disagreements over
+interpretations by saying precisely what we mean, in a simple fashion. I would replace l'aragraphs /
+and 8 with the following language:
+"Any person, who while a minor, was a victim of a violation of an offense chumerated in
+Title 18, United States Code, Section 2255, will have the same rights to proceed under
+Section 2255 as she would have had, if Mr. Epslein been tried federally and convicted of an
+enumerated oflense. For purposes of implementing this paragraph. the United States shalt
+provide Mr. Lpsiein's attorneys with a list of individuals whon it was prepared to name in an
+Indictment as victims of an cruncrated offense by Mr. Epsicin Any judicial authority
+interpreting this provision, including any authority determining which evidentiary burdens if
+any i plaintiff must meet, shall consider that it is the intent of the parties to place these
+identified victims in the same position as they would have been had Mr. Epstein been
+convicted at trial. No more; no less."
+Second, I would like to address the issuc of victim's rights pursuant to Section 3771 1
+understand that the defense objects to the victims being given notice of time and place of Mr
+Epstein's state court sentencing hearing. I have reviewed the proposed victim notification letic and
+the statute. I would note that the United States provided the draft lotter to defense as a courlesy. In
+addition, First Assistant United States Attorney Sloman already incorporated in the letter several
+edits that had been requested by defense counsel. I agree that Section 3771 applies lo notice of
+proceedings and results of investigations of federal crimes as opposed to the state crime. We intend
+to provide victims with notice of the federal resolution, as required by law. We will defer to the
+discretion of the State Allorney regarding whether he wishes to provide victims with notice of the
+state proceedings, although we will provide him with the information necessary to do so if he wishes.
+Third, I would like to address the issue raised regarding Florida Statute Section 796.03. Al
+our meeting, Professor Dershowitz look the position that. Mr. Epstein believes that his conduer does
+not satisfy the clements of this offense. His assertion raises for me substantial concerns. This Office
+will nol, and cannol, be a party to an apreement in which Mr. Epstein pleads guilty to an offense that
+he believes he did not commit: We are considering how best to proceed
+2
+
+
+Finally. I would like to address a more general point. Our Agrcement was first signed on
+September 2q"
+. 2007. Pursuant to paragraph 11, Mr. Epstein was to use hes best efforts to enter lus
+guilty plea and be sentenced no later than October 26. 2007. As outlined in correspondence between
+nur proseculors and defense counsel. dus deadline came and went. Our prosecutors reiterated to
+defense counsel several times their concerns regarding delays, and in fact, asked me several weeks
+ago to declare the Agreement in breach because of those delays. I resisted that invitation. I share
+this fact becausc it is background to my frustration with what appears 10 be an 11" hour appeal,
+weeks belore the now scheduled January 4" plea dale.
+This said, the issues raised are important and must he fully velled irrespective of timeliness
+concerns. We hope to preserve the January 4" date. I understand that defense counsel shares our
+desire not to move that appearance and will work with our office to expedito this process over the
+next several days. With this in mind, and in the event that defense counsel may wish to seck review
+of our determinations in Washinglon D.C.., I spoke this past Monday with the Assistant Altorncy
+General Fisher, to inform her ofa possible appeal, lo ask her to grant the potential request for review,
+and to in fact review this case in an expedited manner lo attempt to preserve the January 4"' plea date.
+I want to again reiterate that it is not the intention of this Office ever to force the hand of a
+defendant to enter into an agreement against his wishes. Your cliem has the right to proceed to trial.
+-and he should do so if he believes that he did not commit the clements of the charged offense.
+I will respond to the pending issues shortly. In the interim, I wouki ask that you
+communicale your position with respect to the sections 2255 and 3371 issues as quickly as possible.
+Sincerely.
+P. MA
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+CC:
+Alice Fisher, Assistant Attorney General
+, First Assistant U.S. Attomey
+
+
+Unired States Attorney
+Somhern Districe of Florida
+A ALEXAVDEN ACOSTA
+UNITED STATES ATTORNEY
+9wf45
+(105) 9619100. Telephoonr
+December 19,2007
+DELIVERY BY FACSIMILE
+Lilly Ann Sanchez.
+Fowler White Bumett, PA
+1395 Brickell Ave, 14" Floor
+Miami, F1. 33131
+Re:
+tellrey Epstein
+Dear Ms. Sanchez:
+I write to follow up on the December 14# meeting between defense counsel and the Epstein
+prosecurors, as well as our First Assistant, the Miami I:BI Special Agent in Charge and myselt.' I
+write to you because lam not certain who among the defense team is the appropriate recipient of this
+Ictier. I address issues raised by several members of the defense team, and would thus ask that you
+please provide a copy of this ferter to all appropriate defense Icam members
+First, I would like to address the Section 2255 issue: As I stated in my December *" Iener,
+my understanding is that the Non-Prosocution Agreement entered into between this Office and Mr.
+Epstein responds to Mr. Epstein's desire to reach a global resolution of his state and federal criminal
+liability. Under this Agreement, this District has agreed to defer prosecution for chunerated sections
+"Over the past evo wecks, wc have received several hundred pages of argoments and exhibus from defense counsel.
+This is not the forum to respond to the sevcral items raised, and our silence should not be interpret as agreement. !
+would, however, like to address one issuc. Your December 11" letter states that as a result of defense counșel
+objections to the appointment process, the USAO proposed an addendum lo the Agrecment to provide for the ose of
+an independent third party sclector. As I recall dis matter, before I had any knowledge of defense counsel
+objections, I sas sponte pruposed the Addendum to Mr. Lelkowitz at an October mecting in Palm Beach. I did dus
+in an ancmpt to avoid what 1 foresaw would likcly be a litigious selection process. It was only after 1 proposed this
+change that Mr. Lelkowitz raiscd with me his cnumerated concerns.
+"Section 225$ proviles that: "alny person who, while a minor, was a victim of a violation of (enumerated sections
+of Tale 1KJ and who suffers personal injury as a result of such violation. may suc in any appropriate United States
+District Court and shall recover the achial damages such person sustams and the cost of the suit. mcluing a
+reasonable antorney's fee."
+
+
+DAGLUALTE UFFALO
+/ 003
+of Title 18 in favor of prosecution by the State of Florida, provided that the Mr. Epstein satisfies
+three general federal interests: (1) that Mr. Epstein plead guilty to a "registcrable" state offense. 2)
+that this state plea include a binding recommendation for a sufficient term of imprisonment: and ( 9)
+that the Agreement not harm the interests of us victims
+With this in mind, I have considered defense counsel arguments regarding the Section ???3
+portions of the Agrecment. As 1 previously observed, our intent has been to place the victims in the
+same position as they would have been had Mr. Epstein been convicted at trial. No more: no less.
+From our mceting, it appears that the defense agrees that this was the iment During the course of
+negotiations that intent was reduced to writing in Paragraphs 7 and X, which as I wrote previously.
+appear far from simple to understand. I would thus propose that we solve our disagreements over
+interpretations by saying precisely what we mean, in a simple fashion. I would replace l'aragraphs 7
+and 8 with the following language:
+"Any person, who while a minor, was a victim of a violation of an offense numerated in
+Tille 18, United States Code, Section 2255, will have the same rights to proceed under
+Section 2255 as she would have had, if Mr. Epslein been tried federally and convicted of an
+enumerated offense: For purposes of implementing this paragraph. the Inited Stales shall
+provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an cnumerated offerise by Mr. Epstein Any judicial authority
+interpreting this provision, including any authority determining which evidentiary burdens if
+any it plaintiff must meet, shall consider that it is the intent of the parties to place these
+identified victims in the same position as they would have been had Mr. Epstein heen
+convicted al frial. No more; no less."
+Sccond, I would like to address the issue of victim's rights pursuant to Section 3771 1
+understand that the defense objects to the victims being given notice of time and place of Mr
+Epstein's state court sentencing hearing. I have reviewed the proposed victin notilication Ictier and
+the statute. I would note that the United States provided the draft letter to defense as a couriesy. In
+addition, First Assistant United States Attorney Sloman already incorporated in the letter several
+edits that had been requested by defense counsel. I agree that Section 3771 applies lo notice of
+proceedings and results of investigatioris of federal crimes as opposed to the state crime. We intend
+to provide victims with notice of the federal resolution, as required by law. We will defer to tie
+discretion of the State Attorney regarding whether he wishes to provide victims with notice of the
+state proceedings, although we will provide him with the information necessary to do so ifhe wishes.
+Third, I would like to address the issue raised regarding Florida Statute Section 796.03. Al
+our meeting, Professor Dershowitz took the position that Mr. Epstein believes that his conduer docs
+not satisfy the clements of this offense. His assertion raises for me substantial concerns. This Office
+will nol, and cannot, be a party to an agrcement in which Mr. Epstein pleads quilly to an offense that
+he believes he did not commit. We are considering how best to proceed.
+2
+
+
+VELIVE
+Finally. I would like to address a more general point. Our Agroement was first signed on
+September 29. 2007. Porsuant to paragraph 11, Mr. Epstein was to use his best efforts to enter his
+guilty plea and be sentenced no later than October 26. 2007. As onlined in correspondence berseen
+our prosecutors and defense counsel, Is deadline came and went. Our proseculors reiterated to
+defense counsel several times their concers regarding delays, and in fact. asked me several weeks
+ago to declare the Agrecment in breach because of those delays. I resisted that invitation. I share
+this fact because it is background to my frustration with what appears to be an 11" hour appeal,
+weeks belore the now scheduled January 4' plea dare.
+This said, the issues raised are important and must he fully vetted irrespective of timeliness
+concerns. We hope to preserve the January 4" date. I understand that defense counsel shares our
+desire not to move thar appearance and will work with our office to expedite this process over the
+next several days. With this in mind, and in the event that defense counsel may wish to scek review
+of our determinations in Washington D.C., I spoke this past Monday with the Assistant Altorney
+General Fisher, to inform her ofa possible appeal, lo ask her to grant the potential request for review,
+and to in fact review this case in an expedited manner to attempt to preserve the lamery 4*' plea date.
+I want to again reiterate that it is not the intention of this Office ever to force the hand of a
+defendant to enter into an agreement against his wishes. Your client has the right to proceed to trial.
+and he should do so if he believes that he did not commit the clements of the charged offense.
+I will respond to the pending issues shortly
+In the interim, I wouk ask that you
+communicale your position with respect to the sections 2255 and 3371 issues as quickly as possible.
+Sincerely.
+P. MA
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+CC:
+Alice Fisher, Assistant Attorney Gencral
+First Assistant U.S. Altomey
+
+
+United States Artorney
+Sohern District of Florida
+R ALEKANDER ACOSTA
+UNITED STATES ATTORNEY
+Home, FL INS:
+(106) 9619109. Telephone
+December 19,2007
+DELIVERY BY FACSIMILE
+Lilly Ann Sancher.
+Fowler White Burncti, PA
+1595 Brickell Ave, 14" Floor -
+Miami, A. 33131
+Re:
+Jeffrey Epsicin
+Dear Ms. Sanchez:
+I write to follow up on the December 14* meeting berween defense counsel and the Fipstein
+prosecutors, is well as our First Assistant, the Miami FBI Special Agent in Charge and mysell.' 1
+write to you because 1 am not certain who among the defense team is the appropriate recipient of this
+Ietter. I address issucs raised by several members of the defense team, and would thus ask that you
+please provide a copy of this lenter to all appropriate defense (cam members.
+First, I would like to address the Section 2255 issue:" As / stated in my December 4" Iener,
+my understanding is that the Non-Prosccution Agreement entered into between this Office and Mr.
+Epstein responds to Mr. Epstein's desire to reach a global resolution of his state and federal criminal
+liability. Under this Agrcement, this District has agreed to defer prosecution for numerated sections
+'Over the past two wecks, we have received several hundred pages of arguments and exhibus from defense counsel
+This is not the foram to respond to the sevcral items raised, and our silence should not be interpret as agreement. 1
+would, however, like to address one issuc. Your December 11* letter states that as a result of defense counsel
+objections to the appointment process, the USAO proposed an addendum to the Agrement to provide for the ase of
+an independent thirl party selector. As I recall this matter, before I had any knowledge of defense counsel
+objections. I sea sponte proposed the Addendan to Mr. Leikowitz at an October mecting in Palm Beach. I did thes
+in an aftompt to avoid what I foresaw would likely be a litigious selection process. It was only after ! proposed this
+change that Mr. Leßkowitz raised with me his coumcrated concerns.
+" Section 2255 provides dar: "Talny person who, while a minor, was a victim of a violation of fenumerated sections
+of Tale 18f and who suffers personal injury as a result of such violation. may sue in any appropriate United States
+District Count and shall recover the actual damages such person sustams and the cost of the suit, isclong i
+reasonalile allomey's fce."
+
+
+CABLULATE VETILE
+of Tille 18 in favor of prosecution by the State of Florida, provided that the Mr. Epstein satisfies
+three general loderal interests: (1) that Mr. Epsiein plead guilty to a "registerable" state offense. (2)
+that this state plea include a binding recommendation for a sufficient term of imprisonment: and i %)
+that the Agreement not harm the interests of his victims
+With this in mund, I have considered defense counsel arguments regarding the Section ?2y5
+portions of the Agrecment. As I previously observed, our intent has been to place the victims in the
+same position as they wouki have been had Mr. Epstein been convicted at trial No more: no less.
+From our meeting, it appears that the defense agrees that this was the intent During the course of
+negotiations that intent was reduced to writing in Paragraphs 7 and 8, which as I wrote previonsly.
+appear far from simple to understand. I would thus propose that we solve our disagreements over
+interpretations by saying precisely what we mean, in a simple fashion. I would replace Paragraphs 7
+and 8 with the following language:
+"Any person, who while a minor, was a victim of a violation of an offense chumerated in
+Title 18, United Stares Code, Section 2255, will have the same rights to proceed under
+Section 2255 as she would have had, if Mr. Epstein been tried federally and convicted of an
+cnumerated offense. For purposes of implementing this paragraph the United States shall
+provide Mr. Epstein's attorneys with a list of individuals whons it was prepared to name in an
+Indictment as victims of an cuumerated offense by Mr. Epstin Any judicial authority
+interpreting this provision, including any authority determining which cvidentiary burdens if
+any it plaintiff must meet, shall consider that it is the intent of the parties to place these
+identified victims in the same position as they would have been had Mr. Epstein been
+convicted at trial. No more; no less."
+Sccond, I would like to address the issue of victim's rights pursuant to Section 377l 1
+understand that the defense objects to the victims being given notice of time and place of Mr
+Epstein's state court sentencing hearing. I have reviewed the proposed victim notification letic and
+the statute. I would note that the United States provided the draft letter to defense as a courlesy. In
+addition, First Assistant United States Attorney Sloman already incorporated in the letter several
+edits that had been requested by defense counsel. I agree that Section 3771 applies to notice of
+proceedings and results of investigations of federal crimes as opposed to the state crime. We intend
+to provide victims with notice of the federal resolution, as required by law. We will defer to die
+discretion of the State Allorney regarding whether he wishes to provide victims with notice of the
+state proceedings, although we will provide him with the information necessary to do so if he wishes.
+Third, I would like to address the issne raised regarding Florida Statule Section 796.03. Al
+our meeling, Professor Dershowitz look the position that Mr. Epstein believes that his conduct does
+not satisfy the clements of this offense. His assertion raises for me substantial concerns. This Office
+will nol, and cannot, be a party to an agreement in which Mr. Epstein pleads guilty to an offense that
+he believes he did not commit. We are considering how best to proced
+2
+
+
+Finally. I would like to address a more general point. Our Agrcement was first signed on
+September 24". 2007, Porsuant to paragraph 11, Mr. Epstein was to use has best efforts to enter his
+guilty plea and be sentenced no later than October 26. 2007. As outlined in correspondence between
+our prosecutors and defense counsel, this dcadline came and went. Our prosecutors reiterated to
+defense counsel several times their concerns regarding delays, and in fact. asked ine several wecks
+ago to declare the Agrecment in breach because of those delays. I resisted that invitation. I share
+this fact because it is background to my frustration with what appears to be an 11" hour appeal,
+weeks before the now scheduled January 4'' plea date.
+This said, the issues raised are important and must be fully vetted irrespective of timcliness
+concerns. We hope to preserve the January 4" dale. I understand that defense counsel shares our
+desire not to move that appearance and will work with our office to expedite this process over the
+next several days. With this in mind, and in the event that defense counsel may wish to scek review
+of our determinations in Washington D.C., I spoke this past Monday with the Assistant Altorney
+General Fisher, lo inform her of a possible appcal, lo ask her to grant the potential request for review,
+and to in fact review this case in an expedited manner to attempi lo preserve the lamary 4* plea dare.
+I want to again reiterate that it is not the intention of this Office ever to force the hand of a
+defendant to enter into an agreement aganst his wishes. Your client has the right to proceed lo trial.
+and he should do so if he believes that he did not commit the clements of the charged offense.
+I will respond to the pending issues shortly.
+In the interim, I would ask that you
+communicate your position with respect to the sections 2255 and 3371 issues as quickly as possible.
+Sincerely.
+P. MAZ
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+CC:
+Alice Fisher, Assistan Attorney General
+. First Assistant U.S. Attorney
+
+
+ALLAN VEEILD
+4002
+UJ.S. Department of Justice
+United Stores Artorney
+Souhern Districh of Flarida
+RAL FLANDERACOSTA
+UNITED STATES ATTORNEY
+December 19,2007
+DELIVERY BY FACSIMILE
+Lilly Ann Sanchez.
+Fowler White Burneti, PA
+1395 Brickell Ave, 14" Floor •
+Miami, F. 33131
+Re: Jelley Epsicin
+Dear Ms. Sanchez:
+I write to follow up on the December 14 meeting berween defense counsel and the Fipstein
+prosecufors, as well as our First Assistant, the Miami FBI Special Agent in Charge and mysell.' I
+write in you because l am not certain who among the defense team is the appropriate recipient of this
+Icter. 1 address issues raised by several members of the defense Ieam, and would thus ask that you
+please provide a copy of this lenter to all appropriale defense team members.
+First, I would like to address the Section 2255 issue.' As! stated in my December 4" letter,
+my understanding is that the Non-Prosccution Agreement entered into berween this Office and Mr.
+Epstein responds to Mr. Epstein's desire to reach a global resolution of his statc and federal criminal
+liability. Under this Agreement, this District has agreed to defer prosecution for chumerated sections
+' Over the past two wecks, we have received several hundred pages of arguments and exhibus from defense counsel.
+This is not the fonam to respond to the sevcral items raiscd, and our silence should not be imerpret as agreement. I
+would, however, like to address one issue. Your December 11* tenter states thar as a result of'defense counsel
+objections to the appointment process, the USAO proposed an addendum to the Agreement to provide for the ase of
+an independent thirl party sclector. As I recall this matter, before I had any knowledge of defense counsel
+objections. I sua sponte proposed the Addendum to Mr. Lelkowitz at an Oclober meeting in Palm Beach. I did thes
+in an attempt lo avoid what 1 foresaw would likely be a litigious selection process. It was only after 1 proposed this
+change that Mr. Lekowitz raised with me his enumerated concerns.
+' Section 2255 provides that: "Taloy person who, while a minor, was a victim of a violation of Jenumerated sections
+- of Title 18) and who suffers personal injury as a result of suche violation. may sue in any appropriate Oned States
+District Court and shall recover the actual damages such person sustams and the cost of the suit, including a
+reasonable anorney's fce."
+
+
+BADLUAIYE UFFILE
+of Tille 18 in favor of prosecution by the State of Florida, provided that the Mr. Epstein satisfies
+threc general fouleral interests: (1) that Mr. Epstein plead guilty to a "registerable" state offense. (2)
+that this state plea include a binding recommendation for a sufficient term of imprisonment: and is
+thal thc Agreement not harm the interests of his victims
+With this in mind, I have considered defense counsel arguments regarding the Section 22vs
+portions of the Agreement. As 1 previously observed, our intent has been to place the victims in the
+same position as they would have been had Mr. Epstein been convicted at trial No more; no less.
+From our meeting, it appears that the defense agrees that thes was the intent During the course of
+negotiations that intent was reduced to writing in Paragraphs 7 and 8, which as I wrole previously.
+appear far from simple to understand. I would thus propose that we solve our disagrcements over
+interpretations by saying precisely what we mean, in a simple fashion. I would replace l'aragraphs /
+and 8 with the following language:
+"Any person, who while a minor, was a victim of a violation of an offense numerated in
+Title 18, Uniled States Code, Section 2255, will have the same rights to proceed under
+Section 2255 as she would have had, if Mr. Epstein been tried federally and convicted of'an
+enumerated offense. For purposes of implementing this paragraph. the United States shall
+provide Mr. Epsicin's attorneys with a list of individuals whom it was prepared to namo in an
+Indictment as victims of an coumerated offense by Mr. Epstein Any judicial auchority
+interpreting this provision, including any authority determining which evidentiary burdens if
+any i plaintiff must meet, shall consider that it is the intent of the parties to place these
+my a em a move no lain as they would are ben find Me. Fein been
+convicted at trial. No more; no less."
+Second, I would like to address the issue of victim's rights pursuant to Section 3771 1
+understand that the defense objects to the victims being given notice of time and place of Mr
+Epstein's state court sentencing hearing. I have reviewed the proposed victin notification letict and
+the statute. I would note that the United States provided the draft Ictter to defense as a couriesy. In
+addition, First Assistant United States Attorney Sloman already incorporated in the letter several
+edits that had been requested by defense counsel. I agree that Section 3771 applies to notice of
+proceedings and results of investigations of federal crimes as opposed to the state crime. We intend
+to provide victims with notice of the federal resolution, as required by law. We will defer to the
+discretion of the State Attorney regarding whether he wishes to provide victims with notice of the
+state proceedings, although we will provide him with the information necessary to do so if he wishes.
+Third, I would like to address the issue raised regarding Florida Statute Section 796.03. Al
+our meeting, Professor Dershowitz look the position that Mr. Epstein believes that his conduer does
+not satisfy the clements of this offense. His assertion raises for me substantial concerns. This Office
+will nol, and cannot, be a party to an agreement in which Mr. Epstein pleads guilty to an offense that
+he believes he did not commit. We are considering how best to proceed.
+2
+
+
+Finally. I would like to address a more general point. Our Agrcement was first signed on
+Seplember 24"
+. 2007. Pursuant to paragraph 11, Mr. Epstein was to use his best efforts to enter his
+quilty plea and be sentenced no later than October 26. 2007. As outlined in correspondence berween
+nur proseculors and defense counsel, this deadline came and went. Our prosecutors reiterated to
+defense counsel several times their concerns regarding delays, and in face, asked me several weeks
+ago to declare the Agreement in breach because of those delays. I resisted that invitation. I share
+this fact because it is background to my frustration with what appears to be an 11" hour appeal,
+weeks before the now scheduled January 4"' plea date.
+This sard, the issues raised are important and must he fully vetted irrespective of timcliness
+concerns. We hope to preserve the January 4" date. I understand that defensc counsel shares our
+desire not to move that appearance and will work with our office lo expedite this process over the
+next several days. With this in mind, and in the event that defense counsel may wish to scek review
+of our determinations in Washinglon D.C., 1 spoke this past Monday with the Assistant Allorney
+General Fisher, to inform her of a possible appeal, to ask her to grant the potential request for review,
+and to in fact review this casc in an expedited manner to attempt to preserve the January 4" plea date.
+I want to again reiterate that it is not the intention of this Office ever to force the hand of a
+defendant to enter into an agreement against his wishes. Your client has the right to proceed to trial.
+and he should do so if he believes that he did not commit the clements of the charged offense.
+I will respond to the pending issues shorly. In the interim, I would ask that you
+communicale your position with respect to the sections 2255 and 3371 issues as quickly as possible.
+Sincerely.
+P. AMA
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+CC:
+Alice Fisher, Assistant Attorney Gencral
+- First Assistant U.S. Altorcy
+AUSA I
+
+
+LANUULATE UFFIVE
+United Stares Arorner
+Somhern District of Florida
+R ALEXANDER ACOSTA
+CIVICED STATES ATTORNEY
+if 4.50€
+fear. FL. 1115.
+(30i) 96/ 9100 - Telephon
+10j/ 510-6114 Finemal
+December 19, 2007
+DELIVERY BY FACSIMILE
+Lilly Ann Sancher.
+Fowler White Bumell, PA
+1395 Brickell Ave, 14" Floor
+Miami, FI. 33131
+Re: Jeffrey Epsicin
+Dear Ms. Sanchez:
+I ivrite to follow up on the December 14" meeting between defense counsel and the Epstein
+prosecufors, as well as nur First Assistant, the Miami FBI Special Agent in Charge and mysell.' I
+write to you because I am not certain who among the defense team is the appropriate recipient of this
+Icter. 1 address issues raised by several members of the defense Icam, and would thus ask that you
+please provide a copy of this lenter to all appropriate defense team members.
+First, I would like to address the Section 2255 issue. As / stated in my December 4" letter,
+my understanding is that the Non-Prosccution Agreement entered into between this Office and Mr.
+Epsicin responds to Mr. Epsiein's desire to reach a global resolution of his state and federal criminal
+liabifity. Under this Agreement, this District has agreed to defer prosecution for chumerated sections
+'Over the past two wecks, we have received several hundred pages of arguments and exhibus from defense counse!
+This is not the lonum to respond to the several items raiscd, and our silence should not be interpret as agrement. I
+wnuld, however, like lo address one issue.
+Your December 11" tenter states that as a result of defense counsel
+objections to the appointment process, the USAO proposed an addendum to the Agrement to provide for the ase of
+an independent third party sclector. As I recall this matter, before I had any knowledge of defense comsel
+objections. I sea sponte proposed the Addendum to Mr. Lelkowitz at an October mecting in Pain Beach. I did ius
+in an antempt lo avoid what I foresa would likcly be a litigious selection process. It was only after | proposed this
+change that Mr. Lelkowitz raised with me his enumcrated concerns.
+"Section 2255 provides that: "fafny person who, while a minor, was a victim of a violation of enumerated sections
+of Tale 18) and who suffers personal injury as a result of such violation.
+may sue in any appropriate Unded States
+District Court and shall recover the actual damages such person sustams and the cost of the suit, incloding a
+reasonable attorney's fce."
+
+
+GABLULITE UFFILD
+of Title 18 in favor of prosecution by the State of Florida, provided that the Mr. Epstein sarisfics
+three general federal interests: (1) that Mr. Epstein plead guilty to a "registerable" state offense. 2)
+that this state plea include a binding recommendation for a sufficient term of imprisonment: and i %,
+that thc Agreement not harm the interests of his victims
+With this in mind, I have considered defense counsel arguments regarding the Section ???s
+portions of the Agrecment. As 1 previously observed, our intent has been to place the victims in the
+same position as they would have been had Mr. Epstein been convicted at trial No more: no less.
+From our mecting, it appears that the defense agrees that thes was the intent During the course of
+negotiations that intent was reduced to writing in Paragraphs 7 and 8, which as I wrote previously.
+appear far from simple to understand. I would thus propose that we solve our disagreements over
+interpretations by saying precisely what we mean, in a simple fashion. I would replace l'aragraphs 7
+and 8 with the following language:
+"Any person, who while a minor, was a victim of a violation of an offense chumerated in
+Tille 18, United States Code, Section 2255, will have the same rights to proced under
+Section 2255 as she would have bad, if Mr. Epstein been iried federally and convicted of'an
+enumerated offense. For purposes of implementing this paragraph. the MInited States shalt
+provide Mr. Lpsiein's attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein Any judicial authority
+interpreting this provision, including any authority determining which evidentiary burdens if
+any i plaintiff must meet, shall consider that it is the intent of the parties to place ihese
+identified victims in the same position as they would have been had Mr. Epstein heen
+convicted at trial. No more; no less."
+Second, I would like to address the issue of victim's rights pursuant to Section 3771
+understand that the defense objects to the victims being given notice of time and place of Mr
+Epstein's state court sentencing hearing. I have reviewed the proposcd victin notification letter and
+the statute. I would note that the Uniled States provided the drafi letter to defense as a courlesy. In
+addition, First Assistant United States Attorney Sloman already incorporated in the letter several
+edits that had been requested by defense counsel. I agree that Section 3771 applies to notice of
+proceedings and results of investigations of federal crimes as opposed to the state crime. We intend
+to provide victims with notice of the federal resolution, as required by law. We will defer to the
+discretion of the State Allorney regarding whether he wishes lo provide victims with notice of the
+state proceedings, although we will provide him with the information necessary to do so if he wishes.
+Third, I would like to address the issue raised regarding Florida Statute Section 796.03. Al
+our meeting, Professor Dershowitz took the position that Mr. Epstein believes that his conduer does
+not satisfy the clements of this offense. His assertion raises for me substantial concers. This Office
+will not, and cannot, be a party to an aprcement in which Mr. Epstein pleads guilty to an offense that
+he believes he did not commit. We are considering how best to proced.
+2
+
+
+DALUVALD VITALE
+Finally. I would like to address a more general point. Our Agroement was first signed on
+September 24"
+, 2007. Pursuant to paragraph 11, Mr. Epstein was to use hes best efforts to enter his
+guilty plea and be sentenced no later than October 26. 2007. As onlined in correspondence bercen
+nur prosecutors and defense counsel. dus deadline came and went. Our proseculors reiterated 1o
+delense counsel several times their concerns regarding delays, and in fact, asked me several weeks
+ago to declare the Agrecment in breach because of those delays. I resisted that invitation. I share
+this fact because it is background to my frustration with what appears to be an 11" hour appeal,
+weeks belore the now scheduled January 4" plea dale.
+This said, the issues raised are important and must he fully velled irrespective of timeliness
+concerns. We hope to preserve the January 4" date. I understand that defense counsel shares our
+desire not to move that appearance and will work with our office to expedite this process over the
+next several days. With this in mind, and in the event that defense counsel may wish to seck review
+of our determinations in Washington D:C., I spoke this past Monday with the Assistant Altorney
+General Fisher, lo inform her of a possible appeal, lo ask her to grant the potential request for review,
+and to in fact review this case in an expedited manner to attempt to preserve the Jarry 4*
+plea date.
+I want to again reiterate that it is not the intention of this Office ever to force the hand of a
+defendant to enter into an agreement against his wishes. Your client has the right to proceed to trial.
+and he should do so if he believes that he did not commir the clements of the charged offense.
+I will respond to the pending issues shortly. In the interim, I woukd ask that you
+communicate your position with respect to the sections 2255 and 3371 issues as quickly as possible.
+Sincerely.
+P. MA
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+CC:
+Alice Fisher, Assistant Attorney General
+First Assistant U.S. Attorney
+
+
+06/30/08
+MON 10:18 FAX|
+@002
+United States Anorney
+Southern District of Florida
+A 11. FRANDEN ACOSTA
+UNITED STATES ATTORNEY
+YUNE: 15022
+(105) 9619180 Selephane
+103510-6924 Facsmi
+December 19, 2007
+DELIVERY BY FACSIMILE
+Lilly Ann Sanchez.
+Fowler White Burnett, PA
+1395 Brickell Ave, 14'" Floor
+Miami, H. 33131
+Re: Jeffrey Epsicin
+Dear Ms. Sanchez:
+I write to follow up on the December 14 meeting berween defense counsel and the Fipslein
+prosecutors, is well as our first Assistant, the Miami FBI Special Agent in Charge and mysell.' I
+write to you because I am not certain who among the defense team is the appropriate recipient of this
+letter. I address issues raised by several members of the defense leam, and would thus ask that you
+plcase provide a copy of this lenter to all appropriale defense leam members.
+First, I would likc to address the Section 2255 issue! As 1 stated in my December 4" ieter,
+my understanding is thai the Non-Prosccution Agreement entered into berween this Office and Mr.
+Epslein responds to Mr. Epstein's desire to reach a global resolution of his state and federal criminal
+liability. Under this Agreement, this District has agreed to defer prosecution for numerated sections
+' Over the past two wecks, we have received several hundred pages of arguments and exhibus from defense counsel.
+This is not the forum to respond to the several items raised, and our silence should not be interpret as agreement. I
+would, however, like to address one issue. Your December 11* letter states that as a result of defense counsel
+objections to the appointment process, the USAO proposed an addendum to the Agreement to provide for the use of
+an independent third party sclector. As 1 recall this matter, before I had any knowledge of defense counsel
+objections, I sua sponte proposed the Addendum to Mr. I elkowitz at an October mecting in Palm Beach. I did thes
+in an attempt lo avoid what 1 foresaw would likely be a litigious selection process. It was only after 1 proposed this
+change that Mr. Lelkowitz raised with me his enumerated concerns.
+' Section 2255 provides that: "Talny person who, while a minor, was a victim of a violation of enumerated sections
+of Title 18j and who suflers personal injury as a result of such violation. may sue in any appropriate Uniled States
+District Court and shall recover the actual damages such person sustams and the cost of the suit, includug a
+reasonable antorney's fee."
+
+
+06/30/08 MON 10:19 FAX
+2003
+of Title 18 in favor of prosecution by the Statc of Florida, provided that the Mr. Epstein satisfies
+three general federal interests: (1) that Mr. Epsiein plead guilty to a "registerable" state offensc. 2)
+that this state plea include a binding, recommendation for a sufficient lerm of imprisonment and is
+that the Agreement not harm the interests of us victims
+With this in mind, I have considered defense counsel arguments regarding the Section ?299
+portions of the Agreement. As 1 previously observed, our intent has been to place the victims in the
+same position as they would have been had Mr. Epstein been convicted at trial No more: no less.
+From our mecting, it appears that the defense agrees that thes was the intent During the course of
+negotiations that intent was reduced to writing in Paragraphs 7 and 8, which as I wrole previously.
+appear far from simple to understand. I would thus propose that we solve our disagreements over
+interpretations by saying precisely what we mean, in a simple fashion. I would replace Paragraphs 7
+and 8 with the following language:
+"Any person, who while a minor, was a victim of a violation of an offense enumerated in
+Title 18, United States Code, Section 2255, will have the same rights to proceed under
+Section 2255 as she would have had, if Mr. Epsiein been tried federally and convicted of an
+numerated offense. For purposes of implementing this paragraph. the United States shalt
+provide Mr. Lpsicin's attorneys with a list of individuals whons it was prepared to name in an
+Indictment as victims of an chumerated offense by Mr. Epstein Any judicial authority
+interpreting this provision, including any authority delcrmining which evidentiary burdens if
+any a plaintiff must meet, shall consider that it is the intent of the parties to place these
+identified victims in the same position as they would have been had Mr. Epstein been
+convicted al trial. No more; no less."
+Second, I would like lo address the issue of victim's rights pursuant to Section 3771 1
+understand that the defense objects to the victims being given notice of time and place of Mr
+Epstein's state court sentencing hearing. I have reviewed the proposed vietin notification letter and
+the statute. I would note that the Uniled States provided the draft fetter to defense as a courlesy. In
+addition, First Assistant United States Attorney Sloman already incorporated in the letter several
+edits that had been requested by defense counsel. I agrec that Section 3771 applies to notice of
+proceedings and results of investigations of federal crimes as opposed to the state crime. We intend
+to provide victims with notice of the federal resolution, as required by law. We will defer to the
+discretion of the State Attorney regarding whether he wishes to provide victims with notice of the
+state proceedings, although we will provide him with the information necessary to do so if he wishes.
+Third, I would like to address the issue raised regarding Florida Statute Section 796.03. Al
+our mecting, Professor Dershowitz took the position that Mr. Epstein believes that his conduct docs
+not satisfy the clements of this offense. His assertion raises for me substantial concerns. This Office
+will not, and cannot, be a party to an agreement in which Mr. Epstein pleads guilty to an offense that
+he believes he did not commit. We are considering how best to proceed
+2
+
+
+06/30/08 MON 10:19 FAX J
+42004
+Finally. I would like to address a more general point. Our Agreement was first signed on
+September 24".
+. 2007. Pursuant to paragraph 11, Mr. Epstein was to use hes best efforts to enter his
+guilty plea and he sentenced no later han October 26. 2007. As outlined in correspondence berween
+ago to declare the Agrecment in breach bocause of those delays. I resisted that invitation. I share
+this fact because it is background to my frustration with what appears to be an 11" hour appeal,
+weeks before the now scheduled January 4'' plea date.
+This said, the issues raised are important and must be fully vetted irrespective of timeliness
+concerns. We hope to preserve the January 4" date. I understand that defense counsel shares our
+desire not to move that appearance and will work with our office to expedite this process over the
+next several days. With this in mind, and in the event that defense counsel may wish to seck review
+of our determinations in Washinglon D.C., I spoke this past Monday with the Assistant Attorney
+General Fisher, lo inform her ofa possible appal, lo ask her to grant the potential request for review,
+and to in fact review this case in an expedited manner to attempt to preserve the Jamunry *" plea date.
+I want to again reiterate that it is not the intention of this Office ever to force the hand of a
+defendant to enter into an agreement against his wishes. Your client has the right to proceed to trial.
+and he should do so if he believes that he did not commit the clements of the charged offense.
+I will respond to the pending issues shorlly. In the interim, I would ask that you
+communicate your position with respect to the sections 2255 and 3371 issues as quickly as possible.
+Sincerely.
+P. MA
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+cc:
+Alice Fisher, Assistant Attorney General
+, First Assistant U.S. Attomey
+-
+
+
+06/30/08 MON 10:18 FAX
+United States Altorney
+Southern District of Florida
+@001
+UNITED STATES ATTORNEY'S OFFICE
+SOUTHERN DISTRICT OF FLORIDA
+99 NE 4'" STREET
+MIAMI, FLORIDA 33132-2111
+Jeffrey H. Sloman
+First Assistant U.S. Attorney
+Cyndee Campos
+Staff Assistant
+fax
+FACSIMILE TRANSMISSION
+COVER SHEET
+DATE:
+June 30, 2008
+TO:
+FAX NUMBER:
+SUBJECT: Epstein
+NUMBER OF PAGES, INCLUDING THIS PAGE: 4
+Message/Comments:
+This facsimile contains PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the
+original facsimile to us at the above address via the U.S. Postal Servicc. Thank you.
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/d3a6c06194a02118c8a37cb2b27f6ae543541197224639b76fdca8d57958d0b6.receipt.json b/vision-fixhub/ds9-unparsed-05/d3a6c06194a02118c8a37cb2b27f6ae543541197224639b76fdca8d57958d0b6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..97ad3e60b6c456061d0389fd503136a82292f3ef
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d3a6c06194a02118c8a37cb2b27f6ae543541197224639b76fdca8d57958d0b6.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -452,
+  "dataset": "marble-joined",
+  "doc_id": "d3a6c06194a02118c8a37cb2b27f6ae543541197224639b76fdca8d57958d0b6",
+  "engine": "marble-apple-vision",
+  "event_count": 20,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "5965347b4c7d718c9b820e207a3d08fa84588a3f9893b8720d636c8dca2b7b0f",
+  "output_sha256": "8034ceffc2a930cef1dc1848f24a597466a8965da323b7344bcacc706fd7f3b4",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/d4f25fe9fe06771e1bf483d4681f54d8acf97c216f0d4d604f19d0de578506ce.md b/vision-fixhub/ds9-unparsed-05/d4f25fe9fe06771e1bf483d4681f54d8acf97c216f0d4d604f19d0de578506ce.md
new file mode 100644
index 0000000000000000000000000000000000000000..f5be6739e889bcf4715dab344846435651c20ee8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d4f25fe9fe06771e1bf483d4681f54d8acf97c216f0d4d604f19d0de578506ce.md
@@ -0,0 +1,1941 @@
+Extra Copy
+
+
+2
+4
+Epstein in town
+3 First call:
+5 Date
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+26
+27
+28
+29
+30
+31
+32
+7/4/2004
+7/5/2004
+77/2004
+71/2004
+7/8/2004
+7/8/2004
+7/8/2004
+7/8/2004
+7/8/2004
+7/8/2004
+7/10/2004
+7/10/2004
+7/10/2004
+7/11/2004
+7/16/2004
+7/16/2004
+7/16/2004
+7/16/2004
+7/16/2004
+7/16/2004
+7/16/2004
+7/16/2004
+7/16/2004
+7/19/2004
+Time
+Event
+Epstein's Flight arrives at
+PBIA (Gulfstream G-
+10:20:00 PM 1159B)
+7:04:00 PM Call
+8:47:00 PM Call
+8:50:00 PM Call
+7:20:00 PM Call
+7:52:00 PM Call
+8.36:00 PM Call
+8.50:00 PM Call
+8:59:00 PM Call
+9:07:00 PM Call
+5:44:00 PM Call
+6:04:00 PM Call
+6:04:00 PM Call
+Epstein's Flight departs
+from PBIA (Gulfstream G-
+10:47:00 AM 1159B)
+1:55:00 AM Call
+10:35:00 AM Call
+11:10:00 AM Call
+1:44:00 PM Call
+1:45:00 PM Call
+2:14:00 PM Call
+4:47:00 PM Call
+7:29:00 PM Call
+Epstein's Flight arrives at
+PBIA (Gulfstream G-
+10:02:00 PM 1159B)
+1:48:00 PM Call
+D
+DOB
+From
+cel
+E
+F
+To
+Call length/message
+info/Passengers
+Jeffrey Epstein.
+celi
+cell
+cell
+cell
+cell
+0:03:00
+0:03:00
+0:05:00
+0:05:00
+cell
+cell
+cel
+cel
+cell
+0:03:00
+0.01:00
+Jeffrey Epstein
+
+
+2
+Epstein in town
+3 First call e
+4
+italics-
+5 Date
+33
+34
+35
+36
+37
+38
+39
+40
+41
+42
+43
+44
+45
+46
+47
+48
+49
+50
+51
+52
+53
+54
+55
+58
+59
+7/19/2004
+7/19/2004
+7/19/2004
+7/19/2004
+7/19/2004
+7/22/2004
+7/22/2004
+7/22/2004
+7/22/2004
+7/23/2004
+7/23/2004
+7/23/2004
+7/23/2004
+7/24/2004
+7/24/2004
+7/24/2004
+7/24/2004
+7/24/2004
+7/24/2004
+7/24/2004
+7/25/2004
+7/25/2004
+8/6/2004
+8/9/2004
+D
+DOB
+From
+Time
+Event
+Epstein's Flight departs
+5:35:00 PM from PBIA (Boeing 727)
+5:42:00 PM Call
+8:36:00 PM Call
+9:51:00 PM Call
+11:58:00 PM Call
+10:56:00 AM Call
+6:48:00 PM Call
+6:50:00 PM Call
+Epstein's Flight arrives at
+9:50:00 PM PBIA (Boeing 727)
+11:31:00 AM Call
+11:32:00 AM Call
+4:38:00 PM Call
+4:41:00 PM Call
+10:15:00 AM Call
+2:24:00 PM Call
+3:01:00 PM Call
+5:00:00 PM Call
+6:10:00 PM Call
+8:31:00 PM Call
+9:07:00 PM Call
+11:33:00 AM Call
+Epstein's Flight departs
+4:35:00 PM from PBIA (Boeing 727)
+Epstein's Flight arrives af
+10:25:00 PM PBIA (Boeing 727)
+10:33:00 AM Call
+cel
+917-855-3363
+Sarah Kellen cell
+cell
+cell
+cell
+cell
+cell
+cell
+cell
+cell
+E
+To
+cell
+cel
+cell
+cell
+cell
+cell
+cel
+cel
+cell
+cell
+cel
+cel
+cell
+cell
+F
+Call length/message
+info/Passengers
+Jeffrey Epstei
+1 female, 1 female, 1 female
+Jeffrey Epstein
+Jeffrey Epstein,
+1 female
+Jeffrey Epstein,
+0:03:00
+
+
+1
+2 Epstein in town
+3 First calls
+4 Italics
+5 Date
+60
+61
+62
+63
+64
+65
+66
+67
+68
+69
+70
+71
+72
+73
+74
+75
+76
+77
+78
+79
+80
+81
+82
+83
+84
+85
+86
+87
+88
+Time
+8/9/2004
+8/10/2004
+8/17/2004
+8/19/2004
+8/20/2004
+8/21/2004
+8/22/2004
+8/24/2004
+8/25/2004
+8/25/2004
+8/26/2004
+8/30/2004
+8/31/2004
+8/31/2004
+8/31/2004
+8/31/2004
+9/1/2004
+9/7/2004
+9/16/2004
+9/16/2004
+9/16/2004
+9/16/2004
+9/17/2004
+9/17/2004
+Event
+11:13:00 AM Call
+Epstein's Flight departs
+10:23:00 AM from PBIA (Boeing 727)
+5:31:00 PM Call
+Epstein's Flight arrives at
+4:50:00 PM PBIA (Boeing 727)
+1:34:00 PM Call
+7:03:00 PM Call
+10:36:00 AM Call
+Epstein's Flight departs
+10:51:00 AM from PBIA (Boeing 727)
+Epstein's Flight arrives at
+5:31:00 PM PBIA (Boeing 727)
+7:12:00 PM Call
+6:52:00 PM Call
+10:17:00 PM Call
+12:31:00 PM Call
+3:36:00 PM Call
+3:45:00 PM Call
+4:41:00 PM Call
+Epstein's Flight departs
+5:56:00 PM from PBIA (Boeing 727)
+8:08:00 PM Call
+1:51:00 PM Call
+6:04:00 PM Call
+6:09:00 PM Call
+Epstein's Flight arrives at
+10:16:00 PM PBIA (Boeing 727)
+10:24:00 AM Call
+12:15:00 PM Call
+D
+DOB
+From
+561-655-2779
+Jeffrey Epstein
+cell
+cell
+cell
+cell
+cell
+561-655-0995
+Jeffrey Epstein
+561-655-2779
+Jeffrey Epstein
+celi
+561-655-2779
+Jeffrey Epstein
+cell
+[cell
+cell
+cel
+E
+To
+cell
+celi
+561-655-2779
+Jeffrey Epstein
+cell
+561-655-2779
+Jeffrey Epstein
+cell
+cel
+cell
+cell
+561-655-2779
+Jeffrey Epstein
+cell
+cel
+cell
+cel
+cell
+cell
+Call length/message
+info/Passengers
+Jeffrey Epstein.
+Jeffrey Epstein,
+Jeffrey Epstein, Ghislaine
+Maxwell,
+Jeffrey Epstein,
+Glislaine
+Maxwell,
+0:03:00
+Jeffrey Epstein,
+0:03:00
+0:03:00
+0:03:00
+Jeffrey Epstein,
+
+
+2
+Epstein in town
+3 First call e
+4 italics-
+5 Date
+Event
+89
+90
+91
+92
+93
+94'
+95
+96
+97
+98
+99
+100
+101
+102
+103
+104
+[105
+106
+107
+108
+109
+1101
+112
+113
+Time
+9/17/2004
+9/17/2004
+9/18/2004
+9/18/2004
+9/19/2004
+9/20/2004
+10/2/2004
+10/3/2004
+10/5/2004
+10/8/2004
+10/9/2004
+10/9/2004
+10/10/2004
+10/16/2004
+10/17/2004
+10/26/2004
+10/26/2004
+1:02:00 PM Call
+2.31:00 PM Call
+1:08:00 PM Call
+3:33:00 PM Call
+stein's Flight departs
+:36:00 AM from PBIA (Boeing 727
+6:21:00 PM Call
+Epstein's Flight arrives at
+9:49:00 PM PBIA (Boeing 727)
+11:21:00 AM Call
+Epstein's Flight departs
+8:02:00 AM
+from PBIA (Boeing 727)
+Epstein's Flight arrives at
+8:05:00 PM PBIA (Boeing 727)
+3:35:00 PM Call
+3:40:00 PM Message Pad
+Epstein's Flight departs
+6:00:00 PM from PBIA (Boeing 727)
+Epstein's Flight arrives at
+8:08:00 PM PBIA (Boeing 727)
+Epstein's Flight departs
+8:04:00 AM from PBIA (Boeing 727)
+9:05:00 AM Call
+10/29/2004
+10/30/2004
+9:05:00 AM Call
+Epstein's Flight arrives at
+PBIA (Gulfstream G-
+12:36:00 AM 1159B)
+9:58:00 AM Call
+D
+DOB
+From
+|561-655-2779
+Jeffrey Epstein
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+cell
+cell
+cell
+cell
+cell
+E
+To
+cel
+cell
+561-655-0995
+Jeffrey Epstein
+Mr. J.E. or
+cell
+cell
+Call length/message
+info/Passengers
+Jeffrey Epstein,
+Jeffrey Epstein
+Jeffrey Epstein, E
+Jeffrey Epstein
+1 pax
+Pls. call her (AR)
+Jeffrey Epstein,
+Jeffrey Epstein, s
+Jeffrey Epstein, Ghislaine
+Maxwell
+Jeffrey Epstein.
+0:04:00
+
+
+2
+Epstein in town
+3
+First call
+4 italics-
+5 Date
+Time
+Event
+114
+10/31/2004
+115
+116
+11/1/2004
+117
+118
+11/4/2004
+119
+11/5/2004
+120
+121
+11/9/2004
+122
+11/18/2004
+123
+11/20/2004
+124
+125
+11/23/2004
+126 * 12/3/2004
+127
+12/4/2004
+128
+12/6/2004
+129
+130
+131
+12/7/2004
+132
+12/7/2004
+12/8/2004
+12/8/2004
+133
+12/13/2004
+134
+135
+12/14/2004
+136
+137
+12/16/2004
+12/16/2004
+8:29:00 AM Call
+Epstein's Flight departs
+from PBIA (Gulfstream G-
+7:50:00 PM 1159B)
+2:40:00 PM Message Pad
+Epstein's Flight arrives at
+PBIA (Gulfstream G-
+10:46:00 PM 11598)
+Epstein's Flight departs
+from PBIA (Gulfstream G-
+5:32:00 PM 1159B)
+Epstein's Flight arrives at
+PB/A (Gulfstream G-
+12:10:00 AM 1159B)
+2:50:00 PM Message Pad
+Epstein's Flight departs
+2:35:00 PM from PBIA (Boeing 727)
+Epstein's Flight arrives at
+7:34:00 PM PBIA (Boeing 727)
+2:55:00 PM Message Pad
+1:00:00 PM Message Pad
+3:32:00 PM Call
+3:33:00 PM Call
+6:43:00 PM Call
+6:51:00 PM Call
+Epstein's Flight arrives at
+PBIA (Gulfstream G-
+6:11:00 PM 1159B)
+Epstein's Flight departs
+from PBIA (Gulfstream G-
+10:12:00 PM 1159B)
+11:14:00 AM Call
+5:15:00 PM Call
+D
+DOB
+From
+E
+F
+To
+cell
+cell
+Jeffrey
+cell
+cell
+cell
+cell
+home
+cell
+cell
+home
+cell
+cell
+home
+cell
+Call length/message
+info/Passengers
+Jeffrey Epstein,
+Return /
+signature)
+Call (no
+Jeffrey Epstein E
+1 female,
+male-
+Jeffrey Epstein,
+Jeffrey Epstein,
+Returning your call (AR)
+Jeffrey Epstein
+Jeffrey Epstein,
+1 female.
+would like to work
+@4:00 PM if possible /
+scheduled for 5:00 today] the
+movie is @ 7:30 (no signature)
+Please call her (AR)
+Jeffrey Epstein,
+1 female pax
+Jeffrey Epstein,
+1 SS Secret Service, 1 SS
+Secret Service, 1 Female, 1
+Female
+
+
+2
+Epstein in town
+First call
+4 Italics-
+5 Date
+Time
+138
+139
+12/16/2004
+12/17/2004
+140
+141
+12/17/2004
+142
+143
+144
+145
+146
+147
+148
+149
+150
+151
+152
+153
+154
+155
+156
+157
+158
+159
+160
+161
+162
+163
+164]
+12/17/2004
+12/18/2004
+12/20/2004
+12/20/2004
+12/21/2004
+12/31/2004
+1/1/2005
+1/1/2005
+1/1/2005
+1/1/2005
+1/1/2005
+1/3/2005
+1/6/2005
+1/10/2005
+1/11/2005
+1/14/2005
+1/14/2005
+1/14/2005
+Event
+9:16:35 PM Call
+7:21:50 PM Call
+7:23:59 PM Call
+Epstein's Flight arrives at
+PB/A (Gulfstream G-
+10:35:00 PM 1159B)
+10:49:37 AM Call
+6:54:53 PM Call
+8:07:43 PM Call
+Epstein's Flight departs
+from PBIA (Gulfstream G-
+8:44:00 AM 1159B)
+8:05:00 PM Text Message
+Epstein's Flight arrives at
+PBIA (Gulfstream G-
+4:09:00 PM
+(1159B)
+1:54:00 PM Call
+5:36:32 PM Call
+9:31:45 PM Call
+10:12:05 PM Call
+Epstein's Flight departs
+from PBIA (Gulfstream G-
+4:04:00 PM 11598)
+Epstein's Flight arrives at
+PBIA (Gulfstream G
+11:50:00 PM 1159B)
+11:19:41 AM Call
+Epstein's Flight departs
+8:03:00 PM from PBIA (Boeing 727)
+5:04:00 PM Call
+Epstein's Flight arrives at
+6:18:00 PM PBIA (Boeing 727)
+6:27:00 PM Call
+D
+DOB
+From
+cell
+cell
+cell
+561-655-0995
+Jeffrey Epstein
+cel
+561-665-2779
+Jeffrey Epstein
+cell
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+561-655-0995
+Jeffrey Epstein
+E
+To
+cell
+cell
+cell
+cel
+cell
+cell
+cell
+cell
+cell
+cell
+cell
+cell
+F
+Call length/message
+info/Passengers
+Jeffrey Epstein
+0:00:43
+0:01:05
+0:00:38
+0:00:27
+0:00:02
+0:01:13
+Jeffrey Epstein, Ghislaine
+Maxwell,
+Jeffrey Epstein,
+Jeffrey Epstein,
+Maxwell,
+Jeffrey Epstein,
+Jeffrey Epstein,
+Female
+Jeffrey Epstein,
+cell
+0:03:00
+0:00:21
+0:00:16
+0:00:19
+Ghislaine
+0:00:21
+1 Female, 1
+0:00:41
+
+
+2
+Epstein in town
+3 First call st
+4 Italics-
+5 Date
+Time
+Event
+165
+166
+167
+168
+169
+170
+171
+172
+173
+174
+175
+176
+177
+178
+179
+180
+181
+182
+183
+184
+185
+186
+187
+188
+189
+190
+1/15/2005
+1/15/2005
+1/15/2005
+1/15/2005
+1/17/2005
+1/19/2005
+1/20/2005
+1/24/2005
+1/27/2005
+1/27/2005
+1/28/2005
+1/31/2005
+1/31/2005
+2/1/2005
+2/1/2005
+2/1/2005
+212/2005
+212/2005
+212/2005
+213/2005
+2/3/2005
+216/20051
+9:36:47 AM Call
+9:51:21 AM Call
+10:37:25 AM Call
+10:44:06 AM Call
+Epstein's Flight departs
+5:10:00 PM from PBIA (Boeing 727)
+Epstein's Flight arrives at
+11:52:00 PM PBIA (Boeing 727)
+5:37:31 PM Call
+3:05:00 PM Call
+1:25:00 PM Call
+Epstein's Flight departs
+7:46:00 PM from PBIA (Boeing 727)
+7:39:00 PM Call
+11:15:45 AM Call
+7:33:57 PM Call
+11:16:00 AM Call
+11:51:00 AM Text Message
+3:36:00 PM Call
+11:56:00 AM Text Message
+8:27:17 PM Call
+9:19:00 PM Call
+Epstein's Flight arrives at
+12:40:00 AM PBIA (Boeing 727)
+3:28:00 PM Call
+4:44:45 PM/Call
+D
+DOB
+From
+561-655-0995
+Jeffrey Epstein
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+E
+To
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+561-655-0995
+Jeffrey Epstein
+561-655-7626
+Jeffray Epstein
+cell
+cell
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+cel
+cel
+cell
+561-655-0995
+cell
+Jeffrey Epstein
+turns 18
+cell
+cell
+cell
+cell
+cell
+cell
+cell
+cell
+cell
+cell
+cell
+F
+Call length/message
+info/Passengers
+Jeffrey Epstein
+Jeffrey Epstein
+Jeffrey Epstein
+Jeffrey Epstein
+Female, Female
+0:00:22
+0:00:04
+0:02:16
+1 pax, 1 pax
+0:01:14
+0:04:00
+0:00:47
+0:03:00
+0:00:02
+1:00
+Female,
+0:04:00
+0:00:271
+
+
+2
+Epstein in town
+3 First call
+4
+italics-
+5 Date
+Time
+Event
+191
+192
+193
+194
+195
+196
+197
+198
+199
+200
+201
+202
+203
+204
+205
+206
+207
+208
+2209
+213
+214
+215
+216
+217
+27/2005
+2/10/2005
+2/10/2005
+2/11/2005
+2/14/2005
+2/14/2005
+2/14/2005
+2/15/2005
+2/24/2005
+2/24/2005
+2/24/2005
+2/24/2005
+2/24/2005
+2/24/2005
+3/1/2005
+3/4/2005
+3/4/2005
+3/5/2005
+3/5/2005
+3/5/2005
+3/5/2005|
+Epstein's Flight departs
+5:39:00 AM from PBIA (Boeing 727)
+4:51:00 PM Call
+Epstein's Flight arrives at
+11:54:00 PM PBIA (Boeing 727)
+3:33:00 PM Call
+9:36:43 AM Call
+3:43:00 PM Call
+4:15:30 PM Call
+Epstein's Flight departs
+5:42:00 PM from PBIA (Boeing 727)
+9:28:00 AM Call
+Epstein's Flight arrives at
+PBIA (Gulfstream G-
+3:40:00 PM 1159B)
+5:26:29 PM Call
+7:26:59 PM Call
+7:46:21 PM|Call
+9:20:45 PM Call
+Epstein's Flight departs
+10:50:00 AM from PBIA (Boeing 727)
+9:17:00 PM Call
+Epstein's Flight arrives at
+11:45:00 PM PBIA (Boeing 727)
+6:24:21 PM Call
+6:28:00 PM Call
+7:49:00 PM Call
+7:52:15 PM Call
+D
+DOB
+From
+cell
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+cell
+561-655-2779
+Jeffrey Epstein
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+cell
+cell
+cell
+E
+To
+cell
+cell
+cell
+cell
+cell
+561-655-2779
+Jeffrey Epstein
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+cell
+cel
+cel
+917-855-3363
+cell
+F
+Call length/message
+info/Passengers
+Jeffrey Epstein
+Jeffrey Epstein
+(illegible).
+Jeffrey Epstein, Ghislaine
+Maxwell
+Jeffrey Epstein.
+Jeffrey Epstein
+Jeffrey Epstein, Ghislaine
+Maxwell,
+0:03:00
+0:00:26
+D:01:00
+0:01:36
+0:00:32
+0:01:32
+0:01:43
+0:00:11
+0:01:44
+0:00:26
+
+
+2
+Epstein in town
+3
+First call
+4 Italics-
+5 Date
+218
+219
+220
+221
+222
+223
+224
+225
+226
+227
+228
+229
+230
+231
+232
+233
+234|
+235
+238
+239
+240
+241
+242
+243
+3/8/2005
+Time
+Event
+Epstein's Flight departs
+11:42:00 AM from PBIA (Boeing 727)
+3/18/2005
+3/18/2005
+3/18/2005
+3/18/2005
+3/22/2005
+3/29/2005
+3/30/2005
+3/31/2005
+3/31/2005
+4/1/2005
+4/6/2005
+4/13/2005
+4/15/2005
+4/27/2005
+4/29/2005
+4/29/2005
+4/29/2005
+4/29/2005
+4/29/2005
+11:56:00 AM Call
+Epstein's Flight arrives at
+12:48:00 PM PBIA (Boeing 727)
+1:27:04 PM Call
+1:36:27 PM Call
+Epstein's Flight departs
+1:07:00 PM from PBIA (Boeing 727)
+9:15:35 PM Call
+5:18:26 PM Call
+9:52:00 AM Call
+Epstein's Flight arrives at
+11:10:00 AM PBIA (Boeing 727)
+Trash Pull (Jeffrey
+Epstein Stationary)
+Epstein's Flight departs
+10:54:00 AM from PBIA (Boeing 727)
+Trash Pull (Jeffrey
+Epstein Stationary)
+rash Pull (72
+ationar
+Epstein's Flight arrives at
+PBIA (Gulfstream G-
+11:58:00 AM 1159B)
+11:22:03 AM Call
+1:01:14 PM Call
+1:01:16 PM/Call
+1:01:33 PM Call
+1:01:52 PM Call
+D
+DOB
+From
+cel
+cel
+cell
+cell
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+E
+To
+561-655-0995
+Jeffrey Epstein
+561-655-0995
+Jeffrey Epstein
+cell
+cell
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+561-655-0995
+Jeffrey Epstein
+561-655-0995
+Jeffrey Epstein
+F
+Call length/message
+info/Passengers
+Jeffrey Epstein,
+Jeffrey Epstein, Ghislaine
+Maxwell,
+Jeffrey Epstein
+1 female.
+Jeffrey Epstein, Ghislaine
+Maxwell,
+10:30
+around 2'Oclock
+Jeffrey Epstein,
+Body
+(legible)
+0:00:25
+0:00:58
+1 female
+0:00:18
+on Fri
+any
+Jeffrey Epstein, Ghislaine
+Maxwell,
+1 male, 1 male, 1 female
+0:01:33
+0:00:31
+0:00:43
+
+
+2
+Epstein in town
+3 First call
+4 italics-
+5 Date
+/Time
+Event
+244
+245
+246
+247
+248
+249
+250
+251
+252
+253
+254
+255
+256
+257
+258
+259
+260
+261
+262
+263
+264
+265
+266
+267
+268
+269
+4/29/2005
+4/29/2005
+4/29/2005
+4/29/2005
+4/29/2005
+4/29/2005
+4/29/2005
+4/29/2005
+5/4/2005
+5/6/2005
+5/6/2005
+5/6/2005
+5/7/2005
+5/7/2005
+5/9/2005
+5/9/2005
+5/9/2005
+5/9/2005
+5/9/2005
+5/9/2005
+5/10/2005
+5/10/2005
+5/10/2005
+1:51:50 PM Call
+1:52:08 PM Call
+1:52:16 PM Call
+1:52:47 PM Call
+1:53:10 PM Call
+1:54:33 PM Call
+1:59:00 PM Call
+Epstein's Flight departs
+from PBIA (Gulfstream G-
+8:22:00 PM 1159B)
+4:45:34 PM Call
+7:12:46 PM Call
+9:44:08 PM Call
+Epstein's Flight arrives at
+PBIA (Gulfstream G-
+11:27:00 PM 1159B)
+12:48:08 PM Call
+J.B. Petty Cash
+12:06:09 PM Call
+7:44:27 PM Call
+7:45:14 PM Call
+7:45:40 PM Call
+8:10:28 PM Call
+8:12:43 PM Call
+9:06:55 AM Call
+9:09:59 AM Call
+Epstein's Flight departs
+from PBIA (Gulfstream G-
+4:34:00 PM 1159B)
+270
+271
+5/18/2005
+11:49:00 AM Call
+D
+DOB
+From
+cell
+cell
+cell
+cell
+cell
+cell
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+cell
+cell
+561-655-2779
+Jeffrey Epstein
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+E
+To
+561-655-0995
+Jeffrey Epstein
+561-655-0995
+Jeffrey Epstein
+cell
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+cell
+cell
+cell
+Cash
+cell
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+561-655-2779
+Jeffrey Epstein
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+F
+Call length/message
+info/Passengers
+Jeffrey Epstein,
+Jeffrey Epstein.
+1 female,
+Jeffrey Epstein,
+0:03:30
+1:00
+0:00:05
+0:01:45
+0:00:26
+0:00:43
+$200.00
+0:00:31
+0:00:11
+0:00:03
+0:00:57
+0:00:53
+0:00:36
+0:00:21
+0:00:27
+0:00:18
+
+
+1
+2
+Epstein in town
+3
+First callE
+4
+Italics
+5 Date
+272
+5/19/2005
+273
+274
+5/24/2005
+Time
+Event
+Epstein's Flight arrives at
+PBIA (Gulfstream G
+10:12:00 PM 1159B)
+Epstein's Flight departs
+from PBIA (Gulfstream G-
+11:14:00 AM 1159B)
+275
+276
+5/27/2005
+5/28/2005
+277
+5/28/2005
+278
+5/28/2005
+279
+5/28/2005
+280
+5/28/2005
+281
+282
+5/29/2005
+283
+5/29/2005
+284
+6/1/2005
+285
+286
+6/1/2005
+287 * 6/8/2005
+288
+6/10/2005
+289
+6/17/2005
+290
+6/18/2005
+291
+6/20/2005
+292
+293
+294
+295
+6/20/2005
+6/20/2005
+296
+297
+6/30/2005
+712/2005
+4:39:00 PM Call
+5:51:00 PM Call
+10:45:00 PM Call
+10:52:59 PM Call
+10:53:20 PM Call
+10:55:05 PM Call
+11:52:15 AM Call
+Epstein's Flight arrives at
+PBIA (Gulfstream G-
+6:07:00 PM 1159B)
+11:29:00 AM Western Union
+Epstein's Flight departs
+from PBIA (Gulfstream G-
+4:31:00 PM 1159B)
+Epstein's Flight arrives at
+10:33:00 PM PBIA (Boeing 727)
+6:55:04 PM Call
+7:15:00 PM Call
+Epstein's Flight arrives at
+PBIA (Gulfstream G-
+10:35:00 AM 1159B)
+9:19:22 AM Call
+Epstein's Flight departs
+from PBIA (Gulfstream G-
+4:39:00 PM 1159B)
+J.B. Petty Cash
+Epstein's Flight arrives at
+PBIA (Gulfstream G
+10:01:00 PM 1159B)
+6:54:38 PM Call
+D
+DOB
+From
+cell
+cell
+cell
+cell
+Jeffrey Epstein
+(New York, NY)
+561-655-0995
+Jeffrey Epstein
+cell
+561-655-0995
+Jeffrey Epstein
+E
+To
+cell
+cell
+cell
+cell
+(Cancun, MX)
+cell
+cell
+Cash
+F
+Call length/message
+info/Passengers
+Jeffrey Epstein
+Jeffrey Epstein.
+0:00:03
+0:00:28
+0:00:02
+0:00:08
+0:00:28
+0:01:13
+$350.00
+Jeffrey Epstein,
+Ghislaine Maxwell
+Jeffrey Epstei
+Jeffrey Epstein
+Jeffrey Epstein,
+Jeffrey Epstein,
+1 female
+Jeffrey Epstein,
+Female
+0:01:36
+0:04:00
+0:00:36
+$100.00
+0:00:03
+
+
+2
+Epstein in town
+3
+First call
+4 Italics-
+5 Date
+Event
+298
+299
+300
+301
+302
+303
+304
+305
+306
+307
+308
+309
+310
+311
+312
+313
+314
+315
+316
+317
+318
+319
+320)
+321
+322
+323
+324
+325
+Time
+7/2/2005
+7/5/2005
+7/12/2005
+7/12/2005
+7/12/2005
+7/12/2005
+7/12/2005
+7/12/2005
+7/12/2005
+7/12/2005
+7/12/2005
+7/13/2005
+7/13/2005
+7/15/2005
+7/15/2005
+7/16/2005
+7/16/2005
+7/16/2005
+7/16/2005
+7/18/2005
+7/18/2005
+7122/2005
+7122/2005
+8:53:00 PM Call
+Epstein's Flight departs
+from PBIA (Gulfstream G-
+11:29:00 AM 1159B)
+12:21:50 PM Call
+12:22:18 PM Call
+12:25:43 PM Call
+12:26:38 PM Call
+1:52:43 PM Call
+2:15:20 PM Call
+2:38:57 PM Call
+9:01:00 PM Call
+10:47:00 PM Text Message
+12:27:00 PM Western Union
+2:19:00 PM Text Message
+Epstein's Flight arrives at
+PBIA (Gulfstream G-
+12:19:00 AM 1159B)
+9:35:00 PM Call
+11:26:18 AM Call
+12:00:33 PM Call
+1:41:38 PM Call
+11:10:40 PM Call
+9:13:28 AM Call
+Epstein's Flight departs
+trom PBIA (Gullstream G-
+1:49:00 PM 1159B)
+6:41:00 PM Call
+7:45:47 PM Call
+7/22/2005
+Epstein's Flight arrives at
+PBIA (Gulfstream G-
+11:26:00 PM 1159B)
+D
+DOB
+From
+561-655-0995
+Jeffrey Epstein
+cell
+cell
+cell
+cell
+Jeffrey Epstein
+(New York, NY)
+cell
+cell
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+561-655-0995
+Jeffrey Epstein
+561-655-0995
+Jeffrey Epstein
+cell
+cell
+E
+To
+cell
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+cell
+cell
+cell
+561-655-0995
+Jeffrey Epstein
+cel
+cell
+(San
+Diego, CA)
+cell
+cell
+cell
+561-655-0995
+Jeffrey Epstein
+cell
+Call length/message
+info/Passengers
+0:02:03
+Jeffrey Enstein
+emate, 1
+male
+0:00:05
+0:00:21
+0:00:03
+0:00:01
+$200.00
+Jeffrey Enstein.
+Jeffrey Epstein.
+0:04:06
+0:00:13
+0:01:32
+0:01:49
+0:00:30
+Jeffrey Epstein,
+
+
+1
+2
+Epstein in town
+3
+First call
+4 Italics-
+5 Date
+Time
+326
+327
+328
+329
+330
+331
+332
+333
+334
+335
+336
+337
+338
+339
+340
+343
+344
+345
+346
+347
+Event
+7/23/2005
+7/23/2005
+7/24/2005
+7/25/2005
+8/8/2005
+8/18/2005
+8/19/2005
+8/20/2005
+8/20/2005
+8/21/2005|
+8/21/2005
+8/22/2005
+9/3/2005
+9/3/2005
+9/4/2005
+9/5/2005
+9/6/2005
+9:58:35 AM Call
+Trash Pull (Ghislaine
+Maxwell Stationary)
+5:49:02 PM Call
+Epstein's Flight departs
+from PBIA (Gulfstream G-
+5:09:00 PM 1159B)
+11:28:00 AM Call
+Epstein's Flight arrives at
+PBIA (Gulfstream G-
+3:19:00 PM 1159B)
+5:14:57 PM Call
+8:41:00 PM Call
+8:50:00 PM Message Pad
+11:38:00 AM Call
+11:39:00 AM Message Pad
+Epstein's Flight departs
+from PBIA (Gulfstream G-
+3:57:00 PM 1159B)
+1:55:00 PM Call
+Epstein's Flight arrives at
+PBIA (Gulfstream G-
+2:12:00 PM 1159B)
+12:55:00 PM Message Pad
+Epstein's Flight departs
+from PBIA (Gulfstream G.
+3:59:00 PM 1159B)
+4:56:00 PM/Call
+D
+DOB
+From
+561-655-0995
+Jeffrey Epstein
+561-655-0995
+Jeffrey Epstein
+cell
+561-655-7626
+Jeffrey Epstein
+E
+To
+cell
+cell
+cel
+J.E.
+Mr. J. Epstein
+cell
+J.E
+F
+Call length/message
+info/Passengers
+0:00:23
+class Him 2:15 back at 5:30
+pm tues /
+- work till 4:30 -
+5:30 /
+- Tues @ 8:00
+pm /
+off at 5 pm /
+Tomorrow - 12 lunch
+0:00:24
+Jeffrey Epste
+Jeffrey Epstein
+Sister
+0:00:30
+- confirmed at 4 PM Who
+is scheduled for Morning? I
+believe
+wants to work (L)
+cannot work today and
+will be here at 4:00 PM
+(L)
+Jeffrey Epstein,
+Jeffrey Epstein.
+1
+she would like to reschedule
+her time (J)
+Jeffrey Epstein, Ghislane Maxwell,
+Female
+
+
+2 Epstein in town
+3 First call
+4 Italics-
+5 Date
+Event
+348
+349
+350
+351
+352
+353
+354
+355
+356
+357
+358
+359
+360
+361
+362
+363
+364
+365
+366
+367
+Time
+9/6/2005
+9/10/2005
+9/10/2005
+9/11/2005
+9/18/2005
+9/18/2005
+9/19/2005
+9/19/2005
+9/20/2005
+9/20/2005
+9/23/2005
+9/29/2005
+10/2/2005
+10/2/2005
+10/4/2005
+368
+369
+10/28/2005
+11/2/2005
+11/2/2005
+4:57:00 PM Call
+8:57:00 PM Call
+10:10:00 PM Message Pad
+10:24:00 AM Call
+10:04:00 AM Call
+Epstein's Flight arrives at
+PBIA (Gulfstream G-
+9:36:00 PM 1159B)
+10:31:52 AM Call
+11:03:56 AM Call
+9:42:04 AM Call
+Epstein's Flight departs
+from PBIA (Gulfstream G-
+8:16:00 PM 1159B)
+Trash Pull (Ghislaine
+Maxwell stationary)
+Epstein's Flight arrives at
+PBIA (Gulfstream G
+11:12:00 PM 1159B)
+9:37:00 PM Call
+9:48:21 PM Call
+Epstein's Flight departs
+from PBIA (Gulfstream G-
+11:41:00 AM 1159B)
+8:37:23 PM Call
+7:15:49 PM Call
+7:16:18 PM Call
+D
+DOB!
+From
+cell
+561-655-2779
+Jeffrey Epstein
+561-655-0995
+Jeffrey Epstein
+561-655-0995
+Jeffrey Epstein
+cell
+cell
+cel
+cell
+E
+F
+To
+Call length/message
+info/Passengers
+J.E.
+0:03:00
+will be at 11AM Do you
+want me to cange
+| (no
+signature)
+cel
+cell
+cel
+cel
+Jeffrey Epstein
+cell
+cell
+cell
+cell
+cell
+0:00:45
+0:00:15
+0:00:13
+Jeffrey Epstein,
+1pm
+4:30 pm / Tues
+@ 9pm /
+12
+|(on front) Definate answer
+tomorrow unpromisin (on back)
+Jeffrey Epstein,
+1 female,
+0:01:28
+Jeffrey Epstein
+0:00:15
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/d4f25fe9fe06771e1bf483d4681f54d8acf97c216f0d4d604f19d0de578506ce.receipt.json b/vision-fixhub/ds9-unparsed-05/d4f25fe9fe06771e1bf483d4681f54d8acf97c216f0d4d604f19d0de578506ce.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..cc4b29e92c62749dea06cfb349fd40b238efa1c6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d4f25fe9fe06771e1bf483d4681f54d8acf97c216f0d4d604f19d0de578506ce.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1083,
+  "dataset": "marble-joined",
+  "doc_id": "d4f25fe9fe06771e1bf483d4681f54d8acf97c216f0d4d604f19d0de578506ce",
+  "engine": "marble-apple-vision",
+  "event_count": 16,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "c67e67e8129f116c55f88a18ef24450ddbf15304e06c1f55015a2e9426e7c421",
+  "output_sha256": "62bf5cccd8cf56a1b5bfe1da6e4514b790a38f9678e4557663cc9934465530cb",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/d52d437f2882503d77363ede756cdd8ea1190d9981b9d50d2ce8d12e048a68c8.md b/vision-fixhub/ds9-unparsed-05/d52d437f2882503d77363ede756cdd8ea1190d9981b9d50d2ce8d12e048a68c8.md
new file mode 100644
index 0000000000000000000000000000000000000000..9542d4d1b1d98c2bd9970abefef7c427c6567c01
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d52d437f2882503d77363ede756cdd8ea1190d9981b9d50d2ce8d12e048a68c8.md
@@ -0,0 +1,115 @@
+IN RE:
+INVESTIGATION OF
+JEFFREY EPSTEIN
+ADDENDUM TO THE NON-PROSECUTION AGREEMENT
+IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7
+otto Non-Prosecution Agreement (hereinafter "paragraph 7), that agreement is modied as
+7A.
+The United States has the right to assign to an independent third-party the responsibility
+for consulting with and, subject to the good faith approval of Epstein's counsel, selecting
+the attorney representative for the individuals identified under the Agreement. If the
+United States elects to assign this responsibility to an independent third-party, both the
+United States and Epstein retain the right to make good faith objections to the attorney
+representative suggested by the independent third-party prior to the final designation of
+the attorney representative.
+7B.
+The parties will jointly prepare a short written submission to the independent third-party
+regarding the role of the attorney representative and regarding Epstein's Agreement to
+pay such attorney representative his or her regular customary hourly rate for representing
+such victims subject to the provisions of paragraph C, infra.
+7C.
+Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision, however, shall not
+obligate Epstein to pay the foes and costs of contested litigation filed against him. Thus,
+if after consideration of potential settlements, an attorney representative elects to file a
+contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested
+remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay reasonable
+attorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney
+representative, shall cease.
+
+
+:
+By signing this Addendum, Epstein asserts and certifies that the above has been read and
+explained to him. Epstein hereby, states that he understands the clarifications to the Non-
+Prosecution Agreement and agrees to comply with them
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+Dated:
+Das /12r/7
+ASSISTANT U.S. ATTORNEY
+Dated:
+OUNSEL TODDIN
+To STEIN
+Dated:
+
+
+By signing this Addendum, Epstein asserts and certifies that the above has been read and
+explained to him. Epstein hereby states that he understands the clarifications to the Non-
+Prosecution Agreement and agrees to comply with them.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Dated:
+By:
+À. MARIE VILLAFAÑA
+ASSISTANT U.S. ATTORNEY
+Dated:
+Das 10/29/07
+JEFFREY EPSTEIN
+COUNSEL TO JEFFREY EPSTEIN
+Dated:
+LILLY ANN SANCHEZ, ESQ.
+
+
+By signing this Addendum, Epstein asserts and certifies that the above has been read an
+plained to him. Epstein hereby states that he understands the clarifications to the Nor
+Prosecution Agreement and agrees to comply with them.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Dated:
+By:
+À. MARIE VILLAFAÑA
+ASSISTANT U.S. ATTORNEY
+Dated:
+JEFFREY EPSTEIN
+Dated: _
+GERALD LEFCOURT, ESQ.
+COUNSEL TO JEFFREY EPSTEIN
+Dated: 10-29-07
+ILLY ANN SANCHEZ, ESQ
+
+
+LAW OFFICE
+(Band Edends
+*. AND ASSOCIATES
+•
+January 16, 2009
+FILE COPY
+Ann Marie C. Villafana, AUSA
+United States Attorney's Office
+500 South Australian Avenue
+West Palm Beach, Florida 33401
+Re: Jane Does 1 and 2
+Case Number: 08-80736-CIV-MARRA/JONSON
+Dear Ms. Villafana:
+By this letter I am requesting a duplicate of the taped statement made by my
+client,
+and would request that you forward same to me at your earliest
+convenience. I will, of course, reimburse you for any out-of-pocket costs incurred
+Should you, for whatever reason, not be able to provide me with a copy of this
+statement, please contact me immediately.
+BE/sg
+Sincerely,
+3000
+Brad Edwards, Esquire
+Please treat as a FOIA
+request.
+This relates to U.S. v. Jeffrey
+pateen operation eap par
+which is a pending investato
+2028 HARRISON STREET, SUITE 202, HOLLYWOOD, FLORIDA 33020
+OFFICE: 954-414-8033/305-935-2011
+FAX:
+954-924-1530/305-935-4227
+BE@BRADEDWARDSLAW.COM
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/d52d437f2882503d77363ede756cdd8ea1190d9981b9d50d2ce8d12e048a68c8.receipt.json b/vision-fixhub/ds9-unparsed-05/d52d437f2882503d77363ede756cdd8ea1190d9981b9d50d2ce8d12e048a68c8.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1acc307fe9b33e4946205ca8e8c2f79e90630456
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d52d437f2882503d77363ede756cdd8ea1190d9981b9d50d2ce8d12e048a68c8.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -148,
+  "dataset": "marble-joined",
+  "doc_id": "d52d437f2882503d77363ede756cdd8ea1190d9981b9d50d2ce8d12e048a68c8",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "aedccc28e86833cdbecce22b207d0de9657e4054854bb7c2bd832c5e262fda7e",
+  "output_sha256": "a687fadb7da53efebf384605d35aba2ea6d3bfde7beb9c2baff58eaaedf58118",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/d5482e57bf309c6530af6a80a15c7119c112fa4d7bbe8bbaa1d55a7eba4e8372.md b/vision-fixhub/ds9-unparsed-05/d5482e57bf309c6530af6a80a15c7119c112fa4d7bbe8bbaa1d55a7eba4e8372.md
new file mode 100644
index 0000000000000000000000000000000000000000..be90f57ddffbbdc985ecfb4dd2a4fa410b474fbb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d5482e57bf309c6530af6a80a15c7119c112fa4d7bbe8bbaa1d55a7eba4e8372.md
@@ -0,0 +1,54 @@
+OLY-22
+
+
+TO: Larry Visoski
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-22
+SUBPOENA FOR:
+PERSON
+X
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+December 1, 2006
+9:30 am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+Any and all information and records related to Jeffrey Epstein, Gulfstream Aircraft N909JE, and Boeing
+Aireraft N908JE, including but not limited to flight records, maintenance records, and passenger manifest
+records. Any and all records related to your employment, including but not limited to paystubs, W-2
+forms, correspondence, employment applications, and employment reviews. Any and all information
+regarding methods to contact Jeffrey Epstein directly or via any secretaries/assistants from 1/1/2004 to
+the present, including but not limited to, telephone numbers, cellular telephone numbers, Blackberry
+addresses, e-mail addresses, and mailing addresses.
+Please coordinate your compliance with this subpoena and confirm the date and time of your appearance
+with Special Agent
+, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+n behalf of the court
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+November 13, 2006
+This subpoena is issued upon application
+of the United States of America
+*If not applicable, enter "none."
+DON DISTRICT OF TA
+Name, Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+300 So. Australian Avenue, Suite 400
+West Palm Beach. FL 33401-6235
+Tel:
+Fax:
+To be used in lieu of A0110
+FORM ORD-227
+JAN.86
diff --git a/vision-fixhub/ds9-unparsed-05/d5482e57bf309c6530af6a80a15c7119c112fa4d7bbe8bbaa1d55a7eba4e8372.receipt.json b/vision-fixhub/ds9-unparsed-05/d5482e57bf309c6530af6a80a15c7119c112fa4d7bbe8bbaa1d55a7eba4e8372.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2156e6e4393adb27b78c80a2c02e40582c1d09ee
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d5482e57bf309c6530af6a80a15c7119c112fa4d7bbe8bbaa1d55a7eba4e8372.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "d5482e57bf309c6530af6a80a15c7119c112fa4d7bbe8bbaa1d55a7eba4e8372",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "4ef3f463941f424a50b82e830f67b63355190325d0174677810ac92b69fd509f",
+  "output_sha256": "c843e669e7e82d464cd3c69b919968ef38db681f76148e3145b2336db1f6efd4",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/d554b07a2817653cea033a4880e885c4843310826e7353256ab6aacc9fdd1b1f.md b/vision-fixhub/ds9-unparsed-05/d554b07a2817653cea033a4880e885c4843310826e7353256ab6aacc9fdd1b1f.md
new file mode 100644
index 0000000000000000000000000000000000000000..f1380ee00c93c9b2141f92b981dd19adcd6a0073
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d554b07a2817653cea033a4880e885c4843310826e7353256ab6aacc9fdd1b1f.md
@@ -0,0 +1,2477 @@
+Nov 12, 2004
+7:37 Am
+917-855-3363
+NV
+17, 2004
+10:42 am
+L+
+Nor 13, 2004
+7:01 pm
+L+
+wu l, 2004
+4:31 pm
+Incompkete
+Steve C. Locutel
+additional contacts le
+neels to load into Acs.
+
+
+1
+2
+Epstein in town
+3
+arat cate
+4 Italic:
+5 Date
+6
+7
+8
+9
+10
+11/5/2004
+11/5/2004
+11/5/2004
+11/5/2004
+11
+11/5/2004
+12
+11/5/2004
+13
+14
+11/5/2004
+C
+E
+F
+/Time
+Event
+6/18/2004 ..
+From
+Call length/message
+info/Passengers
+To
+J 17 years old
+5:28:00 PM Call
+8:44:00 PM Call
+9:11:00 PM Call
+9:37:00 PM Call
+9:48:00 PM Call
+9:55:00 PM Call
+10:00:00 PM Call
+0:03:00
+0:03:00
+Jeffrey Epstein,
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+26
+28
+11/5/2004
+11/6/2004
+11/6/2004
+11/6/2004
+11/6/2004
+11/6/2004
+11/7/2004
+11/7/2004
+11/8/2004
+11/9/2004
+11/9/2004
+11/9/2004
+11/9/2004
+11/9/2004
+Epstein's Flight
+arrives at PBIA
+10:46:00 PM (Gulfstream G-1159B)
+2:28:00 AM Call
+2:51:00 AM Call
+9:38:00 AM Call
+4:41:00 PM Call
+8:31:00 PM Call
+2:22:00 AM Call
+1:57:00 PM Call
+7:12:00 PM Call
+12:08:00 PM Call
+4:40:00 PM Call
+5:26:00 PM Call
+5:26:00 PM Call
+5:32:00 PM Call
+0:04:00
+0:05:00
+
+
+2
+Epstein in town
+3
+4 Italics-l
+5 Date
+C
+E
+Time
+Event
+29
+30
+11/9/2004
+31
+11/10/2004
+32
+11/11/2004
+33
+11/11/2004
+34
+11/11/2004
+35
+11/11/2004
+36
+11/11/2004
+37
+11/13/2004
+38
+11/13/2004
+39
+11/13/2004
+40
+11/13/2004
+41
+11/13/2004
+Epstein's Flight
+departs from PBIA
+5.32:00 PM (Gulfstream G-1159B)
+Epstein's Flight
+arrives at PBIA
+12:21:00 AM (Gulfstream G-1159B)
+9:37:00 AM Call
+9:57:00 AM Call
+9:15:00 PM Call
+9:33:00 PM Call
+10:12:00 PM Call
+11:11:00 AM Call
+12:00:00 PM Call
+9:25:00 PM Call
+9:33:00 PM Call
+10:01:00 PM Call
+42
+11/13/2004
+43 11/13/2004
+44
+11/13/2004
+10:14:00 PM Call
+10:25:00 PM Call
+10:54:00 PM Call
+45 | 11/13/2004
+46
+11/13/2004
+10:54:00 PM Call
+11:05:00 PM Call
+47
+11/13/2004
+48|11/13/2004
+49 11/13/2004
+50
+11/14/2004
+11:09:00 PM Call
+11:13:00 PM Call
+11:46:00 PM Call
+12:34:00 AM Call
+51
+11/14/2004
+12:36:00 AM Call
+From
+To
+[Call length/message
+info/Passengers
+Jeffrey Epstein,
+Jeffrey Epstein,
+0:04:00
+
+
+3
+4 italics
+5 Date
+C
+E
+F
+52
+53
+11/14/2004
+Time
+Event
+Epstein's Flight
+departs from PBIA
+12:13:00 PM (Gulfstream G-1159B)
+5411/14/2004
+55
+11/17/2004
+7:14:00 PM Call
+1:36:00 AM Call
+56
+11/17/2004
+57
+11/17/2004
+58
+9:36:00 AM Call
+10:55:00 AM Call
+59
+11/18/2004
+Epstein's Flight
+arrives at PBIA
+12:10:00 AM (Gulfstream G-1159B)
+60
+61
+62
+11/19/2004
+11/19/2004
+11/20/2004
+12:18:00 PM Call
+9:42:00 PM Call
+12:31:00 AM Call
+63| 11/20/2004
+11:56:00 AM Call
+64
+11/20/2004
+12:30:00 PM Call
+65
+11/20/2004
+1:00:00 PM Call
+66
+11/20/2004
+8:13:00 PM Call
+67
+11/20/2004
+11:44:00 PM Call
+68
+11/20/2004
+11:47:00 PM Call
+69
+11/21/2004
+2:14:00 AM Call
+70
+11/21/2004
+2:30:00 AM Call
+71
+11/21/2004
+2:53:00 AM Call
+72
+11/21/2004
+8:04:00 PM Call
+Epstein's Flight
+departs from PBIA
+73
+11/23/2004
+2:35:00 PM (Boeing 727)
+From
+To
+[Call length/message
+info/Passengers
+Jeffrey Epstein,
+Jeffrey Epstein,
+0:13:00
+0:03:00
+Jeffrey Epstein,
+
+
+E
+F
+1
+3
+4 Italics-
+5 Date
+74
+75
+11/27/2004
+76
+11/27/2004
+77
+11/27/2004
+78 11/28/2004
+79
+11/30/2004
+80
+81
+11/30/2004
+11/30/2004
+82
+12/1/2004
+12/1/2004
+83
+84
+12/1/2004
+85
+12/1/2004
+86
+87
+88
+89
+12/1/2004
+12/1/2004
+12/1/2004
+90 * 12/3/2004
+91
+12/4/2004
+92.
+12/5/2004
+93
+12/5/2004
+94
+12/5/2004
+95
+96
+98
+12/5/2004
+12/5/2004
+12/5/2004
+12/5/2004
+-
+Time
+Event
+2:43:31 PM Call
+10:57:00 PM Call
+10:57:28 PM Call
+10:08:14 AM Call
+6:11:48 PM Call
+6:13:07 PM Call
+6:15:01 PM Call
+1:03:00 AM Call
+1:04:01 AM Call
+2:01:00 AM Call
+2:02:06 AM Call
+10:17:25 AM Call
+12:23:31 PM Call
+6:07:51 PM Call
+Epstein's Flight
+arrives at PBIA
+7.34:00 PM (Boing 727)
+9:35:21 AM Call
+1:33:11 AM Call
+10:22:21 AM Call
+4:16:27 PM Call
+5:31:00 PM Call
+6:06:00 PM Call
+6:06:03 PM Call
+6:06:33 PM Call
+From
+To
+[Call length/message
+info/Passengers
+0:01:47
+0:01:47
+0:00:13
+0:00:41
+0:00:06
+0:00:13
+0:05:53
+Jeffrey Epstein,
+Jeffrey Epstein
+0:00:13
+0:00:03
+0:01:44
+0:01:12
+0:00:16
+0:01:47
+
+
+1
+3
+4 Italic
+5 Date
+- 99 12/6/2004
+100
+101
+102
+12/6/2004
+12/6/2004
+12/6/2004
+Time
+Event
+12:27:11 PM Call
+5:36:50 PM Call
+6:31:39 PM Call
+7:25:37 PM Call
+103
+12/6/2004
+7:53:05 PM Call
+104
+12/7/2004
+9:09:39 AM Call
+105
+12/7/2004
+5:16:11 PM Call
+106
+12/7/2004
+5:17:08 PM Call
+107
+12/7/2004
+7:57:35 PM Call
+108
+12/7/2004
+8:11:00 PM Call
+109
+12/7/2004
+8:11:58 PM Call
+110
+12/7/2004
+8:27:00 PM Call
+111
+12/7/2004
+8:27:43 PM Call
+112
+12/7/2004
+9:31:53 PM Call
+113
+12/7/2004
+10:27:29 PM Call
+114
+12//2004
+10:58:27 PM Call
+115
+12/7/2004|
+11:37:00 PM Call
+116
+12//2004
+11:37:40 PM Call
+117
+12/7/2004
+11:38:09 PM Call
+118
+12/8/2004
+1:12:27 AM Call
+119
+12/8/2004
+2:09:21 AM Call
+120
+12/8/2004
+9:09:47 AM Call
+121
+12/8/2004
+10:24:53 AM Call
+122
+12/8/2004
+10:40:57 AM Call
+123
+12/8/2004
+10:41:41 AM Call
+From
+Jeffrey Epstein
+Jetirey Epstein
+Jeffrey Epstein
+Jeffrey Epstein
+E
+F
+To
+Jeffrey Epstein
+Jeffrey Epstein
+cell
+Call length/message
+info/Passengers
+0:01:13
+0:00:17
+0:01:10
+0:01:33
+0:07:51
+0:00:48
+0:00:25
+0:00:48
+0:00:28
+0:03:00
+0:01:51
+0:00:19
+0:00:37
+0:15:00
+0:14:27
+0:00:28
+0:01:45
+
+
+1
+3
+First c
+4 Italics
+5 Date
+124 12/8/2004
+125
+12/9/2004
+126 12/13/2004
+127 12/13/2004
+128
+12/13/2004
+129
+12/13/2004
+13012/13/2004
+131
+12/13/2004
+132
+12/13/2004
+C
+E
+F
+133 12/13/2004
+134 12/13/2004
+135 12/14/2004
+136
+12/14/2004
+137 12/14/2004
+138 12/14/2004
+139 12/14/2004
+14012/14/2004
+141
+12/14/2004
+142 12/14/2004
+143
+12/14/2004
+144| 12/14/2004
+Time
+Event
+10:43:05 AM Call
+11:55:06 AM Call
+12:37:43 PM Call
+3:49:35 PM Call
+3:52:20 PM Call
+4:03:00 PM Call
+4:04:20 PM Call
+4:10:54 PM Call
+4:52:26 PM Call
+Epstein's Flight
+arrives at PBIA
+6:11:00 PM (Gulfstream G-11598)
+6:29:19 PM Call
+7:21:23 AM Call
+7:56:06 AM Call
+8:01:08 AM Call
+8:28:00 AM Call
+8:28:36 AM Call
+8:35:35 AM Call
+8:36:00 AM Call
+8:36:37 AM Call
+9:03:00 AM Call
+9:03:19 AM Call
+From
+Jeffrey Epstein
+To
+Call length/message
+info/Passengers
+0:00:12
+0:00:31
+0:00:49
+0:02:09
+0:00:16
+0:00:21
+0:00:17
+Jeffrey Enstein
+0:00:34
+0:00:22
+0:00:03
+0:01:26
+0:00:11
+0:00:11
+0:00:19
+0:00:10
+
+
+A |
+1
+3
+4 Italic
+5 Date
+145| 12/14/2004
+146 12/14/2004
+C
+Time
+Event
+11:42:14 AM Call
+11:42:14 AM Call
+Epstein's Flight
+departs from PBIA
+14712/14/2004
+10:12:00 PM (Gulfstream G-1159B)
+149
+12/17/2004
+Epstein's Flight
+arrives at PBIA
+10:35:00 PM (Gulfstream G-1159B)
+150
+12/18/2004
+11:40:53 AM Call
+151
+12/18/2004
+7:10:26 PM Call
+152
+12/20/2004
+2:36:42 PM Call
+153
+12/20/2004
+9:20:38 PM Call
+154
+155
+12/21/2004
+Epstein's Flight
+departs from PBIA
+8:44:00 AM
+(Gulfstream G-1159B)
+156 12/22/2004
+4:51:16 PM Call
+157 12/22/2004
+4:59:42 PM Call
+158 12/22/2004
+5:14:05 PM Call
+15912/22/2004
+5:59:00 PM Call
+160| 12/22/2004
+6:13:00 PM Call
+16112/23/2004
+12:05:00 PM Western Union
+162 12/25/2004
+1:28:13 PM Call
+163 12/25/2004
+8:19:52 PM Call
+16412/25/2004
+9:19:00 PM Call
+From
+Jenrey Bostem
+E
+F
+To
+[Call length/message
+info/Passengers
+0:00:26
+0:00:26
+Jeffrey Epstein,
+Jaffrey Ensteina
+0:00:25
+0:00:42
+0:00:22
+0:02:25
+Jeffrey Epstein, Ghislaine
+Maxwell,
+0:00:28
+$200.00
+0:00:21
+0:01:35
+
+
+1
+Epstein in town
+3
+4 Italics
+5 Date
+165
+166
+1/1/2005
+167
+168
+169
+170
+171
+172
+173
+174
+175
+176
+177
+178
+179
+180
+181
+182
+183
+1/1/2005
+1/1/2005
+1/1/2005
+1/1/2005
+1/2/2005
+1/2/2005
+1/2/2005
+1/2/2005
+1/3/2005
+1/6/2005
+1/8/2005
+1/8/2005
+1/9/2005
+1/9/2005
+1/10/2005
+1/10/2005
+C
+E
+F
+Time
+Event
+2:04:00 PM Call
+Epstein's Flight
+arrives at PBIA
+4:09:00 PM (Gulfstream G-1159B)
+4:09:55 PM
+Call
+5:20:25 PM
+Call
+5:41:57 PM Call
+8:58:43 AM Call
+3:18:00 PM Call
+3:19:04 PM Call
+3:50:06 PM Call
+Epstein's Flight
+deperts from PBIA
+4:04:00 PM (Gulfstream G-1159B)|
+Epstein's Flight
+arrives at PIA
+11:50:00 PM (Gulfstream G-1159B)|
+12:41:00 PM Call
+12:42:27 PM Call
+9:52:00 PM Call
+9:52:58 PM Call
+10:39:00 AM Call
+10:39:54 AM Call
+From
+To
+Call length/message
+info/Passengers
+0:01:20|
+0:03:22
+0:00:27
+0:00:25
+0:00:24
+0:01:00|
+
+
+1
+2
+Epstein in town
+3
+4 italics/
+5 Date
+184
+185
+1/11/2005
+186
+187
+1/14/2005
+1/15/2005
+C
+E
+F
+188
+189
+1/17/2005
+190
+191
+192
+193
+1/19/2005
+1/20/2005
+1/20/2005
+1/21/2005
+194
+1/22/2005
+195
+1/22/2005
+196
+1/22/2005
+197
+1/22/2005
+1/22/2005
+199
+1/22/2005
+200|
+1/22/2005
+201
+1/22/2005
+202
+1/23/2005
+203
+1/23/2005
+204
+1/23/2005
+205
+1/23/2005
+206
+1/24/2005
+Time
+Event
+Epstein's Flight
+departs from PBIA
+8:03:00 PM (Boeing 727)
+Epstein's Flight
+arrives at PBIA
+6:18:00 PM (Boeing 727)
+10:57:31 PM Call
+Epstein's Flight
+departs from PBIA
+5:10:00 PM (Boeing 727)
+Epstein's Flight
+arrives at PBIA
+11:52:00 PM (Boeing 727)
+2:51:25 PM Call
+9:28:58 PM Call
+5:58:10 PM Call
+1:48:00 PM Call
+1:48:13 PM Call
+7:47:49 PM Call
+7:48:00 PM Call
+7:48:15 PM Call
+9:31:30 PM Call
+10:21:00 PM Call
+10:22:07 PM Call
+12:17:00 AM Call
+12:17:11 AM Call
+12:17:33 AM Call
+7:23:56 PM Call
+9:37:13 AM Call
+From
+To
+Call length/message
+info/Passengers
+0:01:40
+0:00:18
+0:00:55
+0:00:21
+0:00:54
+0:00:08
+0:00:46
+0:00:21
+0:00:42
+0:01:39
+0:01:14
+0:00:20
+
+
+C
+E
+F
+1
+3
+4 Italics-fuman
+5 Date
+207
+1/24/2005
+208
+1/24/2005
+209
+1/24/2005
+210
+211
+1/24/2005
+1/25/2005
+1/25/2005
+213
+1/26/2005
+214
+1/26/2005
+215
+1/26/2005
+216
+1/26/2005
+217
+1/26/2005
+218
+1/26/2005
+219
+1/26/2005
+220
+1/26/2005
+221
+222
+1/27/2005
+223
+2/1/2005
+224
+2/1/2005
+225
+2/1/2005
+Time
+Event
+3:10:00 PM Call
+3:20:43 PM Call
+3:21:00 PM Call
+3:21:08 PM Call
+1:46:51 PM Call
+2:38:02 PM Call
+1:30:00 PM Message Pad
+3:19:44 PM Call
+4:02:00 PM Call
+4:03:32 PM Call
+4:10:00 PM Call
+4:11:11 PM Call
+4:26:00 PM Call
+4:26:53 PM Call
+Epstein's Flight
+departs from PBIA
+7:46:00 PM (Boeing 727)
+From
+To
+| Call length/message
+info/Passengers
+0:00:16
+0:01:43
+0:00:07
+She is confirming for 5:30
+PM
+0:00:21
+0:00:41
+0:00:12
+4:30:00 PM Call
+4:31:42 PM Call
+5:26:00 PM Call
+0:00:50
+
+
+3
+4 Italic
+5 Date
+226
+2/1/2005
+227
+2/1/2005
+228
+229
+230
+231
+232
+233
+234
+235
+236
+237
+238
+239
+240
+2/1/2005
+2/1/2005
+2/1/2005
+2/1/2005
+2/1/2005
+2/1/2005
+2/3/2005
+2/3/2005
+2/3/2005
+2/4/2005
+2/5/2005
+2/6/2005
+241
+242
+2/2005
+243
+2/10/2005
+244L
+2/10/2005
+฿
+C
+E
+F
+Time
+Event
+5:26:41 PM Call
+5:29:00 PM Call
+5:29:43 PM Call
+5:33:00 PM Call
+5:33:29 PM Call
+5:34:17 PM Call
+6:17:27 PM Call
+6:18:36 PM Call
+Epstein's Flight
+arrives at PBIA
+12:40:00 AM (Boeing 727)
+1:23:00 PM Call
+1:23:48 PM Call
+12:03:32 PM Call
+10:04:41 PM Call
+12:14:06 PM Call
+Epstein's Flight
+departs from PBIA
+5.39:00 AM (Boeing 727)
+5:58:00 PM Call
+6:39:00 PM Call
+From
+To
+[Call length/message
+info/Passengers
+0:00:03
+0:00:02
+0:00:52
+0:00:08
+0:01:01
+0:04:51
+0:01:17
+
+
+1
+3
+4 Italics-
+5 Date
+245
+2/10/2005
+246
+247
+2/10/2005
+248
+2/10/2005
+249
+2/11/2005
+250
+2/12/2005
+251
+2/12/2005
+252
+2/13/2005
+253
+2/14/2005
+254
+2/14/2005
+255
+256
+2/15/2005
+257
+258
+259
+2/21/2005
+2/21/2005
+260
+261
+262
+2/21/2005
+2/21/2005
+2/21/2005
+263
+264
+2/22/2005
+265
+2/22/2005
+C
+Time
+Event
+6:40:09 PM Call
+9:25:00 PM Call
+Epstein's Flight
+arrives at PBIA
+11:54:00 PM (Boeing 727)
+4:06:00 PM Call
+4:11:00 PM Call
+4:11:39 PM Call
+11:32:48 AM Call
+9:35:44 AM Call
+1:44:56 PM Call
+Epstein's Flight
+departs from PBIA
+5:42:00 PM (Boeing 727)
+12:33:17 PM Call
+2:02:07 PM Call
+Epstein's Flight
+arrives at PBIA
+8:05:00 PM (Boeing 727)
+8:53:00 PM Call
+8:53:40 PM Call
+Epstein's Flight
+departs from PBIA
+10:37:00 AM (Gulfstream G-1159B)
+3:05:26 PM Call
+From
+561-644-9656
+[Felicia E
+561-644-9656
+Felicia E
+E
+F
+To
+[Call length/message
+info/Passengers
+0:00:05
+0:00:22
+0:00:27
+0:00:46
+Jeffrey Epstein, Ghislaine
+Maxwell,
+0:00:27
+0:00:04
+0:05:00
+0:04:16
+
+
+1
+3
+DISECE
+4 Italics-
+5 Date
+266 2/22/2005
+267
+2/22/2005
+268
+2/22/2005
+269
+270
+2/24/2005
+271
+272
+273
+274
+275
+2/24/2005
+2/24/2005
+2/25/2005
+2/25/2005
+2/25/2005
+276
+277
+3/1/2005
+278
+3/1/2005
+279
+3/1/2005
+280
+3/1/2005
+281
+282
+3/1/2005
+283
+284
+3/4/2005
+3/5/2005
+285
+286
+287
+3/8/2005
+3/13/2005
+E
+F
+Time
+Event
+5:53:11 PM Call
+7:56:19 PM Call
+8:08:04 PM Call
+2:49:03 PM Call
+Epstein's Flight
+arrives at PBIA
+3:40:00 PM (Gulfstream G-1159B)
+5:49:25 PM Call
+12:22:15 PM Call
+12:27:55 PM Call
+12:29:48 PM Call
+Epstein's Flight
+departs from PBIA
+10:50:00 AM (Boeing 727)
+From
+[Call length/message
+info/Passengers
+0:00:49
+0:00:24
+0:00:18
+0:01:30
+0:01:51
+0:01:09
+0:00:13
+2:04:00 PM Call
+2:04:28 PM Call
+2:13:00 PM Call
+2:13:58 PM Call
+Epstein's Flight
+arrives at PBIA
+11:45:00 PM (Boeing 727)
+5:40:56 PM Call
+Epstein's Flight
+departs from PBIA
+11:42:00 AM (Boeing 727)
+6:05:11 PM Call
+0:00:59
+0:00:18
+
+
+C
+1
+2. Epstein in town
+3
+4 ME
+5 Date
+Time
+Event
+288
+3/16/2005
+9:15:00 AM Call
+289
+3/16/2005
+9:16:04 AM Call
+290
+3/16/2005
+2:59:00 PM Call
+291
+292
+3/16/2005
+293
+3/18/2005
+6:36:40 PM Call
+Epstein's Flight
+arrives at PBIA
+12:48:00 PM (Boning 727)
+294
+3/21/2005
+3:45:00 PM Call
+295
+3/21/2005
+3:45:19 PM Call
+296
+3/21/2005
+297
+298
+3/22/2005
+3:45:44 PM Call
+Epstein's Flight
+departs from PBIA
+1:07:00 PM (Boeing 727)
+299
+300
+3/29/2005
+301
+3/31/2005
+302
+303
+4/6/2005
+304
+4/8/2005
+3:13:00 PM Call
+Epstein's Flight
+arrives at PBIA
+11:10:00 AM (Boeing 727)
+Epstein's Flight
+departs from PBIA
+10:54:00 AM (Boeing 727)
+Trash Pull (Jeffrey
+E. Epstein
+Stationary)
+305
+4/8/2005
+Trash Pull (Jeffrey
+E. Epstein
+Stationary)
+E
+F
+From
+To
+[Call length/message
+info/Passengers
+0:00:25
+0:00:22
+
+
+1
+3
+4 lita
+5 Date
+E
+F
+Time
+Event
+From
+To
+Call length/message
+info/Passengers
+306
+4/15/2005
+Trash Pull (727
+Stationary)
+
+
+1
+3
+CONCENS
+4 Italic
+5 Date
+6
+7
+8
+9
+10
+11
+12
+13
+14
+11/5/2004
+11/5/2004
+11/5/2004
+11/5/2004
+11/5/2004
+11/5/2004
+11/5/2004
+E
+F
+Time
+5:28:00 PM Call
+8:44:00 PM Call
+9:11:00 PM Call
+9:37:00 PM Call
+9:48:00 PM Call
+9:55:00 PM Call
+10:00:00 PM Call
+Event
+6/18/2004
+From
+[Call length/message
+info/Passengers
+0:03:00
+0:03:00
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+26
+27
+28
+11/5/2004
+11/6/2004
+11/6/2004
+11/6/2004
+11/6/2004
+11/6/2004
+11/7/2004
+11/7/2004
+11/8/2004
+11/9/2004
+11/9/2004
+11/9/2004
+11/9/2004
+11/9/2004
+Epstein's Flight
+arrives at PBIA
+10:46:00 PM (Gulfstream G-1159B)
+2:28:00 AM Call
+2:51:00 AM Call
+9:38:00 AM Call
+4:41:00 PM Call
+8:31:00 PM Call
+2:22:00 AM Call
+1:57:00 PM Call
+7:12:00 PM Call
+12:08:00 PM Call
+4:40:00 PM Call
+5:26:00 PM Call
+5:26:00 PM Call
+5:32:00 PM Call
+0:04:00
+0:05:00
+
+
+2
+3
+4
+italics-
+Epstein in town
+5 Date
+C
+E
+F
+Time
+Event
+29
+30
+11/9/2004
+Epstein's Flight
+departs from PBIA
+5:32:00 PM (Gulfstream G-1159B)
+31
+11/10/2004
+Epstein's Flight
+arrives at PBIA
+12:21:00 AM (Gulfstream G-1159B)
+32
+11/11/2004
+9:37:00 AM Call
+33
+11/11/2004
+9:57:00 AM Call
+34
+11/11/2004
+9:15:00 PM Call
+35
+11/11/2004
+9:33:00 PM Call
+36
+11/11/2004
+10:12:00 PM Call
+37
+11/13/2004
+11:11:00 AM Call
+38
+11/13/2004
+12:00:00 PM Call
+39
+11/13/2004
+9:25:00 PM Call
+40
+11/13/2004
+9:33:00 PM Call
+41
+11/13/2004
+10:01:00 PM Call
+42
+11/13/2004
+10:14:00 PM Call
+43 11/13/2004
+10:25:00 PM Call
+44 11/13/2004
+10:54:00 PM Call
+45| 11/13/2004
+10:54:00 PM Call
+4611/13/2004
+47
+11/13/2004
+11:05:00 PM Call
+11:09:00 PM Call
+11:13:00 PM Call
+48 11/13/2004
+4911/13/2004
+11:46:00 PM Call
+50|
+11/14/2004
+12:34:00 AM Call
+5111/14/2004
+12:36:00 AM Call
+From
+To
+[Call length/message
+info/Passengers
+Jeffrey Epstein,
+0:04:00
+
+
+1
+3
+4 Italic
+5 Date
+E
+F
+Time
+Event
+Epstein's Flight
+departs from PBIA
+12:13:00 PM (Gulfstream G-1159B)
+From
+To
+Call length/message
+info/Passengers
+52 11/14/2004
+53
+54 11/14/2004
+55 | 11/17/2004
+56
+57
+58
+11/17/2004
+11/17/2004
+59
+11/18/2004
+60
+11/19/2004
+61
+11/19/2004
+62
+11/20/2004
+63
+11/20/2004
+6411/20/2004
+65
+11/20/2004
+66
+67
+11/20/2004
+11/20/2004
+68
+11/20/2004
+69
+11/21/2004
+70
+11/21/2004
+71
+11/21/2004
+72
+11/21/2004
+73 11/23/2004
+7:14:00 PM Call
+1:36:00 AM Call
+9:36:00 AM Call
+10:55:00 AM Call
+Epstein's Flight
+arrives at PBIA
+12:10:00 AM (Gulfstream G-1159B)
+12:18:00 PM Call
+9:42:00 PM Call
+12:31:00 AM Call
+11:56:00 AM Call
+12:30:00 PM Call
+1:00:00 PM Call
+8:13:00 PM Call
+11:44:00 PM Call
+11:47:00 PM Call
+2:14:00 AM Call
+2:30:00 AM Call
+2:53:00 AM Call
+8:04:00 PM Call
+Epstein's Flight
+departs from PBIA
+2:35:00 PM (Boeing 727)
+0:13:00
+0:03:00
+
+
+1
+3
+4 Italics
+5 Date
+74
+75 11/27/2004
+76
+11/27/2004
+77
+11/27/2004
+78
+11/28/2004
+79
+11/30/2004
+80
+11/30/2004
+81
+11/30/2004
+82
+12/1/2004
+83
+12/1/2004
+84
+12/1/2004
+85
+12/1/2004
+86
+12/1/2004
+87
+12/1/2004
+88
+89
+12/1/2004
+90 12/3/2004
+91
+12/4/2004
+92
+12/5/2004
+93
+12/5/2004
+94
+12/5/2004
+95
+96
+97
+98
+12/5/2004
+12/5/2004
+12/5/2004
+12/5/2004
+E
+F
+Time
+Event
+From
+To
+Call length/message
+info/Passengers
+2:43:31 PM Call
+10:57:00 PM Call
+10:57:28 PM Call
+10:08:14 AM Call
+6:11:48 PM Call
+6:13:07 PM Call
+6:15:01 PM Call
+1:03:00 AM Call
+1:04:01 AM Call
+2:01:00 AM Call
+2:02:06 AM Call
+10:17:25 AM Call
+12:23:31 PM Call
+6:07:51 PM Call
+Epstein's Flight
+arrives at PBIA
+7:34:00 PM (Boeing 727)
+9:35:21 AM Call
+1:33:11 AM Call
+10:22:21 AM Call
+4:16:27 PM Call
+5:31:00 PM Call
+6:06:00 PM Call
+6:06:03 PM Call
+6:06:33 PM Call
+0:01:47
+0:01:47
+0:00:13
+0:00:41
+0:00:06
+0:00:13
+0:05:53
+0:00:13
+0:00:03
+0:01:44
+0:01:12
+0:00:16
+0:01:47
+
+
+E
+F
+1
+4 Italics
+5 Date
+Time
+Event
+99
+12/6/2004
+12:27:11 PM Call
+100
+12/6/2004
+5:36:50 PM Call
+101
+12/6/2004
+6:31:39 PM Call
+102 12/6/2004
+7:25:37 PM Call
+103
+12/6/2004
+7:53:05 PM Call
+104
+9:09:39 AM Call
+105
+106
+12//2004
+121/2004
+12/7/2004
+107
+12/7/2004
+5:16:11 PM Call
+5:17:08 PM Call
+7:57:35 PM Call
+8:11:00 PM Call
+108
+12//2004
+109
+12/7/2004
+110
+12/7/2004
+8:11:58 PM Call
+8:27:00 PM Call
+111
+12Л/2004
+8:27:43 PM Call
+112
+113
+12//2004
+9:31:53 PM Call
+12/7/2004
+10:27:29 PM Call
+114
+127/2004
+10:58:27 PM Call
+115
+127/2004
+11:37:00 PM Call
+116
+12/7/2004
+11:37:40 PM Call
+117
+12Л/2004
+11:38:09 PM Call
+118
+12/8/2004
+1:12:27 AM Call
+119
+12/8/2004
+2:09:21 AM Call
+120
+12/8/2004
+9:09:47 AM Call
+121
+12/8/2004
+10:24:53 AM Call
+122
+12/8/2004
+10:40:57 AM Call
+123
+12/8/2004|
+10:41:41 AM Call
+From
+To
+Call length/message
+info/Passengers
+0:01:13
+0:00:17
+0:01:10
+0:01:33
+0:07:51
+0:00:48
+0:00:25
+0:00:48
+0:00:28
+0:03:00
+0:01:51
+0:00:19
+0:00:37
+0:15:00
+0:14:27
+0:00:28
+0:01:45
+
+
+1
+3
+4 Italic:
+5 Date
+124 12/8/2004
+125
+12/9/2004
+126 12/13/2004
+127 12/13/2004
+128
+12/13/2004
+129
+12/13/2004
+130 12/13/2004
+131 12/13/2004
+|132 12/13/2004
+E
+F
+Call length/message
+info/Passengers
+133 12/13/2004
+134 12/13/2004
+13512/14/2004
+136 12/14/2004
+137 12/14/2004
+138 12/14/2004
+139 12/14/2004
+140 12/14/2004
+141| 12/14/2004
+142| 12/14/2004
+143| 12/14/2004
+144
+12/14/2004
+Time
+Event
+10:43:05 AM Call
+11:55:06 AM Call
+12:37:43 PM Call
+3:49:35 PM Call
+3:52:20 PM Call
+4:03:00 PM Call
+4:04:20 PM Call
+4:10:54 PM Call
+4:52:26 PM Call
+Epstein's Flight
+arrives at PBIA
+6:11:00 PM (Gulfstream G-1159B
+6:29:19 PM Call
+7:21:23 AM Call
+7:56:06 AM Call
+8:01:08 AM Call
+8:28:00 AM Call
+8:28:36 AM Call
+8:35:35 AM Call
+8:36:00 AM Call
+8:36:37 AM Call
+9:03:00 AM Call
+9:03:19 AM Call
+From
+ITo
+all
+all
+ell
+ell
+0:00:12
+0:00:31
+0:00:49
+0:02:09
+0:00:16
+0:00:21
+0:00:17
+sell
+0:00:34
+0:00:22
+0:00:03
+0:01:26
+0:00:11
+0:00:11
+0:00:19
+0:00:10|
+
+
+1
+3
+4
+5 Date
+145 12/14/2004
+146| 12/14/2004
+E
+F
+Time
+Event
+11:42:14 AM Call
+11:42:14 AM Call
+Epstein's Flight
+departs from PBIA
+10:12:00 PM (Guifstream G-1159B)
+From
+To
+IE&K7E 6720
+Call length/message
+info/Passengers
+0:00:26
+0:00:26
+147 12/14/2004
+148
+149
+150
+151
+152
+153
+12/17/2004
+12/18/2004
+12/18/2004
+12/20/2004
+12/20/2004
+Epstein's Flight
+arrives at PBIA
+10:35:00 PM (Gulfstream G-1159B)
+11:40:53 AM Call
+7:10:26 PM Call
+2:36:42 PM Call
+9:20:38 PM Call
+Epstein's Flight
+departs from PBIA
+8:44:00 AM (Gulfstream G-1159B)
+4:51:16 PM Call
+0:00:25
+0:00:42
+0:00:22
+0:02:25
+154 12/21/2004
+155
+156
+12/22/2004
+157 12/22/2004
+4:59:42 PM Call
+15812/22/2004
+5:14:05 PM Call
+159 12/22/2004
+5:59:00 PM Call
+160| 12/22/2004
+6:13:00 PM Call
+161| 12/23/2004 12:05:00 PM Western Union
+162 12/25/2004
+1:28:13 PM Call
+163 12/25/2004
+8:19:52 PM Call
+164|12/25/2004
+9:19:00 PM Call
+0:00:28
+$200.00
+0:00:21
+0:01:35
+
+
+1
+3
+4 Italics-
+5 Date
+Time
+Event
+165
+166
+167
+168
+169
+170
+171
+172
+173
+174
+175
+176
+177
+178
+179
+180
+181
+182
+1/1/2005
+2:04:00 PM Call
+1/1/2005
+1/1/2005
+Epstein's Flight
+arrives at PBIA
+4:09:00 PM (Gulfstream G-1159B)
+4:09:55 PM Call
+1/1/2005
+5:20:25 PM Call
+1/1/2005
+5:41:57 PM Call
+1/2/2005
+8:58:43 AM Call
+1/2/2005
+3:18:00 PM Call
+1/2/2005
+1/2/2005
+3:19:04 PM Call
+3:50:06 PM Call
+1/3/2005
+Epstein's Flight
+departs from PBIA
+4:04:00 PM (Gulfstream G-1159B)
+Epstein's Flight
+arrives at PBIA
+1/6/2005 11:50:00 PM (Gulfstream G-1159B)
+1/8/2005
+12:41:00 PM Call
+1/8/2005
+12:42:27 PM Call
+1/9/2005
+9:52:00 PM Call
+1/9/2005
+9:52:58 PM Call
+1/10/2005
+10:39:00 AM Call
+183L
+1/10/2005
+10:39:54 AM Call
+E
+F
+From
+To
+Call length/message
+info/Passengers
+0:01:20
+0:03:22
+0:00:27
+0:00:25
+0:00:24
+
+
+1
+3
+4 Italic
+5 Date
+184
+185
+1/11/2005
+186
+1/14/2005
+187
+1/15/2005
+188
+189
+1/17/2005
+190
+191
+192
+193
+1/19/2005
+1/20/2005
+1/20/2005
+1/21/2005
+194
+1/22/2005
+195
+1/22/2005
+196
+1/22/2005
+197
+1/22/2005
+198
+1/22/2005
+199
+1/22/2005
+200
+1/22/2005
+201
+1/22/2005
+202
+1/23/2005
+203
+1/23/2005
+204
+1/23/2005
+205
+1/23/2005
+206
+1/24/2005
+E
+F
+Time
+Event
+Epstein's Flight
+departs from PBIA
+8:03:00 PM (Boeing 727)
+Epstein's Flight
+arrives at PB/A
+6:18:00 PM (Boeing 727)
+10:57:31 PM Call
+Epstein's Flight
+departs from PBIA
+5:10:00 PM (Boeing 72T)
+Epstein's Flight
+arrives at BIA
+11:52:00 PM (Boeing 727)
+2:51:25 PM Call
+9:28:58 PM Call
+5:58:10 PM Call
+1:48:00 PM Call
+1:48:13 PM Call
+7:47:49 PM Call
+7:48:00 PM Call
+7:48:15 PM Call
+9:31:30 PM Call
+10:21:00 PM Call
+10:22:07 PM Call
+12:17:00 AM Call
+12:17:11 AM Call
+12:17:33 AM Call
+7:23:56 PM Call
+9:37:13 AM Call
+From
+To
+Call length/message
+info/Passengers
+0:01:40
+0:00:18
+0:00:55
+0:00:21
+0:00:54
+0:00:08
+0:00:46
+0:00:21
+0:00:42
+0:01:39
+0:01:14
+0:00:20|
+
+
+1
+3
+4 italics
+5 Date
+207
+1/24/2005
+208
+1/24/2005
+2091/24/2005
+210
+1/24/2005
+211
+1/25/2005
+1/25/2005
+213
+1/26/2005
+214|
+1/26/2005
+215
+1/26/2005
+216
+1/26/2005
+217
+1/26/2005
+218
+1/26/2005
+219
+1/26/2005
+220
+1/26/2005
+221
+1/27/2005
+222
+223
+2/1/2005
+224
+2/1/2005
+225
+2/1/2005
+C
+F
+Time
+Event
+3:10:00 PM Call
+3:20:43 PM Call
+3:21:00 PM Call
+3:21:08 PM Call
+1:46:51 PM Call
+2:38:02 PM Call
+1:30:00 PM Message Pad
+3:19:44 PM Call
+4:02:00 PM Call
+4:03:32 PM Call
+4:10:00 PM Call
+4:11:11 PM Call
+4:26:00 PM Call
+4:26:53 PM Call
+Epstein's Flight
+departs from PBIA
+7:46:00 PM (Boeing 727)
+From
+To
+Call length/message
+info/Passengers
+0:00:16
+0:01:43
+0:00:07
+Sheis confirming for 5:30
+0:00:21
+0:00:41
+0:00:12
+4:30:00 PM Call
+4:31:42 PM Call
+5:26:00 PM Call
+0:00:50
+
+
+1
+3
+4 Italic
+5 Date
+Event
+226
+227
+228
+229
+230
+231
+232
+233
+234
+Time
+2/1/2005
+2/1/2005
+2/1/2005
+2/1/2005
+2/1/2005
+2/1/2005
+2/1/2005
+2/1/2005
+5:26:41 PM Call
+5:29:00 PM Call
+5:29:43 PM Call
+5:33:00 PM Call
+5:33:29 PM Call
+5:34:17 PM Call
+6:17:27 PM Call
+6:18:36 PM Call
+E
+F
+From
+To
+Call length/message
+info/Passengers
+0:00:03
+0:00:02
+0:00:52
+0:00:08
+235
+2/3/2005
+236
+237
+238
+239
+240
+241
+242
+243
+2/3/2005
+2/3/2005
+2/4/2005
+2/5/2005
+2/6/2005
+27/2005
+2/10/2005
+244
+2/10/2005
+Epstein's Flight
+arrives at PBIA
+12:40:00 AM (Boeing 727)
+1:23:00 PM Call
+1:23:48 PM Call
+12:03:32 PM Call
+10:04:41 PM Call
+12:14:06 PM Call
+Epstein's Flight
+departs from PBIA
+5:39:00 AM (Boeing 727)
+0:01:01
+0:04:51
+0:01:17
+•
+5:58:00 PM Call
+6:39:00 PM Call
+
+
+1
+3
+4 Italics-
+5 Date
+245
+2/10/2005
+246 240/2005.
+248
+2/10/2005
+249
+2/11/2005
+250
+2/12/2005
+251
+252
+253
+254
+2/12/2005
+2/13/2005
+2/14/2005
+2/14/2005
+255
+256
+257
+258
+259
+2/15/2005
+2/21/2005
+2/21/2005
+E
+F
+260 2/21/2005
+261
+2/21/2005
+262
+2/21/2005
+263
+2/22/2005
+264
+265
+2/22/2005
+Time
+Event
+6:40:09 PM Call
+9:25:00 PM Call
+Epstein's Flight
+arrives at PBIA
+11:54:00 PM (Boeing 727)
+4:06:00 PM Call
+4:11:00 PM Call
+4:11:39 PM Call
+11:32:48 AM Call
+9:35:44 AM Call
+1:44:56 PM Call
+Epstein's Flight
+departs from PBIA
+5:42:00 PM (Boeing 727)
+12:33:17 PM Call
+2:02:07 PM Call
+Epstein's Flight
+arrives at PBIA
+8:05:00 PM (Boeing 727)
+8:53:00 PM Call
+8:53:40 PM Call
+Epstein's Flight
+departs from PBIA
+10:37:00 AM (Gulfstream G-1159B)
+3:05:26 PM Call
+From
+To
+Call length/message
+info/Passengers
+0:00:05
+0:00:22
+0:00:27
+0:00:46
+0:00:27
+0:00:04
+0:05:00
+0:04:16
+
+
+1
+3
+4 Italics-
+5 Date
+265 2/22/2005
+267
+2/22/2005
+268 2/22/2005
+269
+270
+2/24/2005
+-
+E
+F
+271
+272
+273
+274
+275
+276
+277
+278
+279
+280
+281
+282]
+2/24/2005
+2/24/2005
+2/25/2005
+2/25/2005
+2/25/2005
+3/1/2005
+Time
+Event
+5:53:11 PM Call
+7:56:19 PM Call
+8:08:04 PM Call
+2:49:03 PM Call
+Epstein's Flight
+arrives at PBIA
+3:40:00 PM (Gulfstream G-1159B)
+5:49:25 PM Call
+12:22:15 PM Call
+12:27:55 PM Call
+12:29:48 PM Call
+Epstein's Flight
+departs from PBIA
+10:50:00 AM (Boeing 727)
+From
+To
+Call length/message
+info/Passengers
+0:00:49
+0:00:24
+0:00:18
+0:01:30
+0:01:51
+0:01:09
+0:00:13
+3/1/2005
+3/1/2005
+3/1/2005
+3/1/2005
+283
+284
+285
+286
+287
+3/4/2005
+3/5/2005
+3/8/2005
+3/13/2005
+2:04:00 PM Call
+2:04:28 PM Call
+2:13:00 PM Call
+2:13:58 PM Call
+Epstein's Flight
+arrives at PBIA
+11:45:00 PM (Boeing 727)
+5:40:56 PM Call
+Epstein's Flight
+departs from PBIA
+11:42:00 AM (Boeing 727)
+6:05:11 PM Call
+0:00:59
+0:00:18
+
+
+3
+4 Ita
+5 Date
+288
+3/16/2005
+289
+3/16/2005
+290
+3/16/2005
+291
+292
+3/16/2005
+293
+3/18/2005
+294
+3/21/2005
+295
+3/21/2005
+296
+3/21/2005
+297
+298
+3/22/2005
+299
+300]
+3/29/2005
+301
+3/31/2005
+C
+Time
+Event
+9:15:00 AM Call
+9:16:04 AM Call
+2:59:00 PM Call
+6:36:40 PM Call
+Epstein's Flight
+arrives at PBIA
+12:48:00 PM (Boeing 727)
+3:45:00 PM Call
+3:45:19 PM Call
+3:45:44 PM Call
+Epstein's Flight
+departs from PBIA
+1:07:00 PM (Boeing 727)
+302
+303
+304
+305
+4/6/2005
+4/8/2005
+4/8/2005
+306
+4/8/2005
+3:13:00 PM Call
+Epstein's Flight
+arrives at PBIA
+11:10:00 AM (Boeing 727)
+Epstein's Flight
+departs from PBIA
+10:54:00 AM (Boeing 727)
+8:20:00 PM Message Pad
+Trash Pull (Jeffrey
+E. Epstein
+Stationary)
+Trash Pull (Jeffrey
+E. Epstein
+Stationary)
+From
+To
+Felicia
+J.E.
+F
+Call length/message
+info/Passengers
+0:00:25
+0:00:22
+((J)
+
+
+1
+3
+4 Itali
+5 Date
+E
+F
+Time
+Event
+From
+To
+Call length/message
+info/Passengers
+307
+4/15/2005
+Trash Pull (727
+Stationary)
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/d554b07a2817653cea033a4880e885c4843310826e7353256ab6aacc9fdd1b1f.receipt.json b/vision-fixhub/ds9-unparsed-05/d554b07a2817653cea033a4880e885c4843310826e7353256ab6aacc9fdd1b1f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b66f4ea7308cd2ab0ad5f1bac58dbd9361aa7a7b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d554b07a2817653cea033a4880e885c4843310826e7353256ab6aacc9fdd1b1f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -2935,
+  "dataset": "marble-joined",
+  "doc_id": "d554b07a2817653cea033a4880e885c4843310826e7353256ab6aacc9fdd1b1f",
+  "engine": "marble-apple-vision",
+  "event_count": 32,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "a9838ee64e7fdfe83b732e00f35d991521859f7d94ce522b8e5c5e206a842fde",
+  "output_sha256": "cc9f3aafc4a3195045af253249afc5b099cca7bcc25a4903a20cab22a7e695a6",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/d5eab062a9e0f71b4e202a8fd5ea6d568e6ff62c316ff9da1e80719e4b7bbc50.md b/vision-fixhub/ds9-unparsed-05/d5eab062a9e0f71b4e202a8fd5ea6d568e6ff62c316ff9da1e80719e4b7bbc50.md
new file mode 100644
index 0000000000000000000000000000000000000000..c380866af79bf0e09ac91a30b966a20050e1244c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d5eab062a9e0f71b4e202a8fd5ea6d568e6ff62c316ff9da1e80719e4b7bbc50.md
@@ -0,0 +1,269 @@
+1
+3
+2 Epstein in town
+Lust call
+4 Italics-
+B
+E
+F
+5 Date
+6
+7
+Time
+Event
+From
+To
+Call
+length/message
+info/Passengers
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+2/3/2005
+2/5/2005
+2/5/2005
+2/6/2005
+2/6/2005
+2/6/2005
+216/2005
+2/6/2005
+2/6/2005
+216/2005
+216/2005
+19
+20
+2Л/2005
+Epstein's Flight
+arrives at PBIA
+12:40:00 AM (Boeing 727)
+8:46:00 PM Call
+10:00:00 PM Call
+12:49:00 PM Call
+12:50:00 PM Call
+12:52:00 PM Call
+1:01:00 PM Call
+1:02:00 PM Call
+1:02:00 PM Call
+2:01:00 PM Call
+10:25:00 PM Call
+Epstein's Flight
+departs from PBIA
+5.39:00 AM (Boeing 727)
+0:02:00
+22
+23
+2/7/2005
+217/2005
+11:59:00 AM Call
+4:30:00 PM Call
+
+
+1
+2
+Epstein in town
+3
+Erst cal
+4 Italics-t
+B
+D
+E
+F
+5 Date
+24
+25
+26
+2/10/2005
+2/11/2005
+2/11/2005
+27
+28
+29
+30
+2/15/2005
+2/20/2005
+Time
+Event
+Epstein's Flight
+arrives at PBIA
+11:54:00 PM (Boeing 727)
+9:37:00 PM Call
+9:39:00 PM Call
+Epstein's Flight
+departs from PBIA
+5:42:00 PM (Boeing 727)
+1:10:00 PM Message Pad
+From
+To
+length/message
+info/Passengers
+Left her cell #
+31
+2/21/2005
+Epstein's Flight
+arrives at PBIA
+8:05:00 PM (Boeing 727)
+32
+33
+34
+35
+36
+37
+38
+2/22/2005
+Epstein's Flight
+departs from PBIA
+(Gulfstream G.
+10:37:00 AM 1159B)
+3/16/2005
+3/18/2005
+3/18/3005
+3/18/3005
+6:36:00 PM Call
+Epstein's Flight
+arrives at PBIA
+12:48:00 PM (Boeing 727)
+12:50:00 PM Call
+12:51:00 PM Call
+
+
+1
+2 Epstein in town
+3
+4 Italics-
+B
+C
+D
+E
+F
+5 Date
+39
+40
+3/18/2005
+3/20/2005
+3/22/2005
+Time
+Event
+4:16:00 PM Call
+3:07:00 PM Call
+Epstein's Flight
+departs from PBIA
+1:07:00 PM (Boeing 727)
+From
+To
+Call
+length/message
+info/Passengers
+0:03:00
+42
+43
+44
+45
+46
+47
+48
+49
+50
+51
+52
+53
+54
+55
+3/29/2005
+3/30/2005
+3/30/2005
+3/30/2005
+3/30/2005
+3/30/2005
+3/30/2005
+3/30/2005
+3/31/2005
+3/31/2005
+3/31/2005
+3/31/2005
+2:51:00 PM Call
+10:49:00 AM Call
+2:17:00 PM Call
+3:34:00 PM Call
+3:35:00 PM Call
+3:40:00 PM Call
+4:09:00 PM Call
+4:35:00 PM Call
+9:55:00 AM Call
+Epstein's Flight
+arrives at PBIA
+11:10:00 AM (Boeing 727)
+4:25:00 PM Call
+5:09:00 PM Call
+0:02:00
+0:04:00
+0:02:00
+0:02:00
+0:02:00
+0:02:00
+0:02:00
+
+
+1
+2 Epstein in town
+3
+4 Italics
+B
+D
+E
+L
+F
+5 Date
+56
+57
+58
+59
+60
+61
+62
+4/1/2005
+4/1/2005
+4/1/2005
+4/1/2005
+4/1/2005
+4/1/2005
+4/1/2005
+Time
+Event
+63
+64
+65
+66
+4/6/2005
+4/8/2005
+4/8/2005
+3:20:00 PM Call
+3:21:00 PM Call
+3:27:00 PM Call
+3:59:00 PM Call
+4:00:00 PM Call
+7:21:00 PM Call
+7:25:00 PM Call
+Epstein's Flight
+departs from PB/A
+10:54:00 AM (Boeing 727)
+Trash Pull
+(Jeffrey E.
+Epstein
+Stationary)
+Trash Pull
+(Jeffrey E.
+Epstein
+Stationary)
+From
+ITo
+length/message
+info/Passengers
+0:02:00
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/d5eab062a9e0f71b4e202a8fd5ea6d568e6ff62c316ff9da1e80719e4b7bbc50.receipt.json b/vision-fixhub/ds9-unparsed-05/d5eab062a9e0f71b4e202a8fd5ea6d568e6ff62c316ff9da1e80719e4b7bbc50.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0482963afde95e4dd7ef9e7c72e9d70f4fb8a69c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d5eab062a9e0f71b4e202a8fd5ea6d568e6ff62c316ff9da1e80719e4b7bbc50.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -273,
+  "dataset": "marble-joined",
+  "doc_id": "d5eab062a9e0f71b4e202a8fd5ea6d568e6ff62c316ff9da1e80719e4b7bbc50",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "b0b6f274da7def634659c103ccd6b63ff05d28e92e9adaed260179190edd4c14",
+  "output_sha256": "76ca3867efcf59b01adeaf1ab2af008d17768fc3f520d06cef31680c86d6d9fc",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/d6288943fc4293dca6c5fac204bd7dc65d3583f15bc79cc58c52248cf563407e.md b/vision-fixhub/ds9-unparsed-05/d6288943fc4293dca6c5fac204bd7dc65d3583f15bc79cc58c52248cf563407e.md
new file mode 100644
index 0000000000000000000000000000000000000000..ea2f21c8c0148878aa62a42b7d46fe1bbf362ab2
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d6288943fc4293dca6c5fac204bd7dc65d3583f15bc79cc58c52248cf563407e.md
@@ -0,0 +1,1291 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No:
+18 U.S.C. $ 371
+18 U.S.C. § 1591(a)(1)
+18 U.S.C. § 1591(a)(2)
+18 U.S.C. § 2422(b)
+18 U.S.C. § 2423(e)
+18 U.S.C. § 2423(d)
+18 U.S.C. § 2423(b)
+UNITED STATES OF AMERICA
+JEFFREY EPSTEIN,
+, a/k/a «l
+and
+Defendants.
+3.
+INDICTMENT
+The Grand Jury charges that:
+BACKGROUND
+At all times relevant to this Indictment:
+Defendant JEFFREY EPSTEIN employed defendants
+, a/k/a "
+' and |
+to perform, among other things,
+services as personal assistants.
+Defendants JEFFREY EPSTEIN and
+paid T.M., H.R., and A.F. to
+perform, among other things, recruiting services.
+Defendant JEFFREY EPSTEIN owned a property located at 358 El Brillo Way, Palm
+Beach, Florida, in the Southern District of Florida (hereinafter referred to as "358 El Brillo Way").
+Defendant JEFFREY EPSTEIN was the principal owner of JEGE, INC., a Delaware
+corporation. JEGE, INC.'s sole business activities related to the operation and ownership of a Boeing
+727-31 aircraft bearing tail number N908JE.
+Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder
+of JEGE, INC., and had the power to direct all of its operations.
+Defendant JEFFREY EPSTEIN was the principal owner of Hyperion Air, Inc., a
+Delaware corporation.
+Hyperion Air, Inc.'s sole business activities related to the operation and
+ownership of a Gulfstream G-1159B aircraft bearing tail number N909JE.
+
+
+7.
+9.
+10.
+11.
+Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder
+of Hyperion Air, Inc., and had the power to direct all of its operations.
+Pursuant to Florida Statutes Section 794.05, a "person 24 years of age or older who
+engages in sexual activity with a person 16 or 17 years of age commits a felony of the second
+degree." For purposes of "this section, "sexual activity' means oral, anal, or vaginal penetration by,
+or union with, the sexual organ of another; however, sexual activity does not include an act done for a
+bona fide medical purpose." Florida Statutes Section 794.021 states that "ignorance of the age [of
+the victim] is no defense," and that neither "misrepresentation of age by [the victim] nor a bona fide
+belief that such person is over the specified age [shall] be a defense."
+Pursuant to Florida Statutes Sections 800.04(5)(a) and 800.04(5)(c)(2), an adult "who
+intentionally touches in a lewd or lascivious manner the breasts, genitals, genital area, or buttocks, or
+the clothing covering them, of a person less than 16 years of age, or forces or entices a person under
+16 years of age to so touch the perpetrator, commits lewd or lascivious molestation," which is a
+felony of the second degree if the victim is 12 years of age or older but less than 16 years of age.
+Pursuant to Florida Statutes Sections 800.04(6)(a) and 800.04(6)(b), an adult "who
+[i]ntentionally touches a person under 16 years of age in a lewd or lascivious manner or [solicits a
+person under 16 years of age to commit a lewd or lascivious act commits lewd or lascivious
+conduct," which is a felony of the second degree.
+Pursuant to Florida Statutes Sections 800.04(7)(a) and 800.04(7)(c), an adult "who: (1)
+[i]ntentionally masturbates; (2) [i]ntentionally exposes the genitals in a lewd or lascivious manner; or
+(3) [i]ntentionally commits any other sexual act that does not involve actual physical or sexual
+contact with the victim, including, but not limited to ... the simulation of any act involving sexual
+activity in the presence of a victim who is less than 16 years of age, commits lewd or lascivious
+exhibition," which is a felony of the second degree.
+Pursuant to Florida Statutes Section 800.04(2), "[neither the victim's lack of chastity
+nor the victim's consent is a defense to the crimes proscribed by [Section 800.04]."
+Pursuant to Florida Statutes Section 800.04(3), "[t]he perpetrator's ignorance of the
+victim's age, the victim's misrepresentation of his or her age, or the perpetrator's bona fide belief of
+the victim's age cannot be raised as a defense in a prosecution under [Section 800.04]."
+
+
+Pursuant to Florida Statutes Section 800.02, a "person who commits any unnatural and
+lascivious act with another person commits a misdemeanor of the second degree."
+Defendant JEFFREY EPSTEIN was over the age of 24 and did not have any medical
+license.
+15.
+16.
+17.
+18.
+19.
+20.
+21.
+22.
+During the period of her involvement with the Defendants, Jane Doe #4 attended
+Wellington High School and Palm Beach Central High School in Palm Beach County.
+During the period of her involvement with the Defendants, Jane Doe #5 attended
+Wellington High School in Palm Beach County.
+During the period of their involvement with the Defendants, Jane Does # 6, 8, and 12
+attended Palm Beach Central High School in Palm Beach County.
+During the period of her involvement with the Defendants, Jane Doe #7 attended
+William T. Dwyer High School in Palm Beach County.
+During the periods of their involvement with the Defendants, Jane Does #9, 14, 15, 16,
+17, 18, and 19 attended Royal Palm Beach High School in Palm Beach County.
+During the period of her involvement with the Defendants, Jane Doe #10 attended Lake
+Worth High School in Palm Beach County.
+During the period of her involvement with the Defendants, Jane Doe #11 attended
+Jeaga Middle School in Palm Beach County.
+During the period of her involvement with the Defendants, Jane Doe #13 attended John
+1. Leonard High School in Palm Beach County.
+COUNT 1
+(Conspiracy: 18 U.S.C. § 371)
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference
+as though fully set forth herein.
+From at least as early as 2001, the exact date being unknown to the Grand Jury, through
+in or around October 2005, in Palm Beach County, in the Southern District of Florida, and elsewhere,
+the Defendants,
+JEFFREY EPSTEIN,
+1, a/k/a"l
+and
+
+
+did knowingly and willfully combine, conspire, confederate, and agree with each other and with others
+known and unknown to commit an offense against the United States, that is, to use a facility or means of
+interstate or foreign commerce to knowingly persuade, induce, and entice individuals who had not
+attained the age of 18 years to engage in prostitution, in violation of Title 18, United States Code,
+Section 2422(b).
+Purpose and Object of the Conspiracy
+It was the purpose and object of the conspiracy to procure females under the age of 18
+to travel to 358 El Brillo Way so that JEFFREY EPSTEIN could, in exchange for money, engage in
+lewd conduct with those minor females in order to satisfy JEFFREY EPSTEIN's prurient interests.
+Manner and Means
+The manner and means by which the Defendants and other participants sought to
+accomplish the purpose and object of the conspiracy included the following:
+(a) It was part of the conspiracy that Defendants
+a/k/a "
+19
+and other participants would contact minor
+females via the use of cellular and other telephones to arrange appointments for minor females to travel
+to 358 El Brillo Way to allow Defendant JEFFREY EPSTEIN to engage in lewd conduct with them.
+(b) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN,
+a/k/a
+and other
+participants would make payments to, or cause payments to be made to, minor females in exchange for
+engaging in lewd conduct.
+(c) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, I
+a/k/a "
+" and other participants would ask females to
+recruit other minor females to engage in lewd conduct with Defendant JEFFREY EPSTEIN.
+(d) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, L
+, a/k/a "
+" and other participants would make payments
+to, or cause payments to be made to, the recruiters for bringing additional minor females to 358 El Brillo
+Way to engage in lewd conduct with Defendant JEFFREY EPSTEIN.
+(e) It was further a part of the conspiracy that Defendant JEFFREY EPSTEIN would pay
+minor females to engage in lewd conduct with Defendant
+to satisfy Defendant
+JEFFREY EPSTEIN's prurient interests.
+
+
+Overt Acts
+In furtherance of this conspiracy and to effect the objects thereof, there was committed,
+by at least one of the co-conspirators herein, at least one of the following overt acts, among others, in
+the Southern District of Florida, and elsewhere:
+Jane Does #1 and #2
+In or around the beginning of 2001, Defendant JEFFREY EPSTEIN engaged
+in sexual activity with Jane Doe #1, who was then a seventeen-year-old girl, in the presence
+of Jane Doe #2, who was then a fourteen-year-old girl.
+In or around 2001, Defendant
+led Jane Doe #2 from the kitchen of
+358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way.
+In or around 2001, Defendant JEFFREY EPSTEIN masturbated in the
+presence of Jane Doe #2, who was then a fourteen-year-old girl.
+In or around 2001, Defendant JEFFREY EPSTEIN asked Jane Doe #2, who
+was then a fourteen-years-old girl, to pinch his nipples while he masturbated.
+In or around 2001, Defendant JEFFREY EPSTEIN made a payment of $300 to
+Jane Doe #2.
+In or around 2001, Defendant
+placed a telephone call to a
+telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel to 358 El
+Brillo Way.
+9.
+10.
+In or around 2001, JEFFREY EPSTEIN engaged in sexual intercourse with an
+unidentified female in the presence of Jane Doe #2, who was then a fourteen-year-old girl.
+In or around 2001, Defendant JEFFREY EPSTEIN paid $300 to Jane Doe #2,
+who was then a fourteen-year-old girl, for allowing an unidentified female to perform oral
+sex on Jane Doe #2 in EPSTEIN's presence.
+On or about March 11, 2003, Defendant JEFFREY EPSTEIN reviewed a
+written telephone message prepared by one of his employees regarding a telephone call
+received from Jane Doe #2.
+In or around 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #2 if she
+had any younger friends who would be interested in engaging in similar sexual activities
+with him.
+
+
+11.
+In or around 2003, Defendant
+took nude photographs of
+Jane Doe #2, who was then a sixteen-year-old girl.
+In or around 2003, Defendant
+made a payment of $500 to
+Jane Doe #2 in exchange for posing for nude photographs.
+In or around 2003, Defendant
+told Jane Doe #2 that
+Defendant JEFFREY EPSTEIN had asked KELLEN to take nude photographs of Jane Doe
+#2.
+15.
+16.
+In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the
+presence of Jane Doe #2, who was then a sixteen-year-old girl.
+In or around 2003, Defendant JEFFREY EPSTEIN made a payment of $200 to
+Jane Doe #2, who was then a sixteen-year-old girl.
+In or around 2003, Defendant
+placed a telephone call to a
+telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel to 358 EI
+Brillo Way.
+17.
+18.
+On or about April 23, 2004, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #2.
+On or about May 2, 2004, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #2.
+Jane Doe #3
+In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the
+presence of Jane Doe #3, who was then a fifteen-year-old girl.
+In or around 2003, Defendant JEFFREY EPSTEIN made a payment of $200 to
+Jane Doe #3.
+On or about October 26, 2004, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #3.
+On or about October 30, 2004, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #3.
+In or around 2004, Defendant JEFFREY EPSTEIN directed Jane Doe #3, who
+was then a sixteen- or seventeen-year-old girl, to straddle an adult female and to touch the
+adult female's breasts.
+
+
+In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging device
+on the vagina of an adult female in the presence of Jane Doe #3, who was then a sixteen- or
+seventeen-year-old girl.
+7.
+In or around 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to
+Jane Doe #3.
+9.
+10.
+11.
+In or around 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #3 to
+rub his nipples.
+In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging device
+on the vagina of Jane Doe #3, who was then a sixteen- or seventeen-year-old girl.
+In or around 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #3 to
+recruit additional females to come to 358 El Brillo Way.
+On or about November 8, 2004, Defendant JEFFREY EPSTEIN reviewed a
+written telephone message prepared by one of his employees regarding a telephone call
+received from Jane Doe #3 that read: "I have a female for him."
+On or about January 14, 2005, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #3.
+On or about January 29, 2005, Defendant JEFFREY EPSTEIN reviewed a
+written telephone message prepared by one of his employees regarding a telephone call
+received from Jane Doe #3 that read: "I have a female for him."
+Jane Does #4, #5, and #6
+In or around the first half of 2004, Defendant
+led Jane Doe
+#4 and Jane Doe #5 to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way.
+In or around the first half of 2004, Defendant JEFFREY EPSTEIN learned that
+Jane Doe #4 was seventeen years old when he asked Jane Doe #4 about her age, and Jane
+Doe #4 responded with her true age.
+In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+masturbated in the presence of Jane Doe #4, who was then a seventeen-year-old-girl, and
+Jane Doe #5, who was then a seventeen-year-old girl.
+In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed
+Jane Doe #4, who was then a seventeen-year-old girl, to play with his nipples.
+
+
+9.
+10.
+11.
+3.
+In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed
+Jane Doe H4, who was then a seventeen-year-old girl, to remove her clothing.
+In or around the first half of 2004, Defendant JEFFREY EPSTEIN stroked the
+vagina of Jane Doe #4, who was then a seventeen-year-old girl.
+In or around the first half of 2004, Defendant JEFFREY EPSTEIN paid $200
+to Jane Doe #4.
+In or around the first half of 2004, Defendant JEFFREY EPSTEIN paid $200
+to Jane Doe #5.
+In or around the first half of 2004, Defendant JEFFREY EPSTEIN asked Jane
+Doe #6 what high school she attended.
+In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed
+Jane Doe #4 to leave so that Jane Doe #6 could massage him alone.
+In or around the first half of 2004, Defendant JEFFREY EPSTEIN
+masturbated in the presence of Jane Doe #6, who was then a sixteen-year-old girl.
+In or around the first half of 2004, Defendant JEFFREY EPSTEIN digitally
+penetrated Jane Doe #6, who was then a sixteen-year-old girl.
+In or around the first half of 2004, Defendant JEFFREY EPSTEIN placed a
+large vibrating massager on the vagina of Jane Doe #6, who was then a sixteen-year-old girl.
+In or around the first half of 2004, Defendant JEFFREY EPSTEIN caused a
+payment of $200 to be made to Jane Doe #6.
+Jane Does #7 and #8
+In or around July 2004, Defendant JEFFREY EPSTEIN led T.M., who was
+then a fifteen-year-old girl, and Jane Doe #7, who was then a sixteen-year-old girl, from the
+kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom.
+On or about July 4, 2004, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #7.
+On or about July 5, 2004, Defendant
+placed a telephone
+call to a telephone used by T.M.
+In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the
+presence of Jane Doe #8, who was then a seventeen-year-old girl.
+
+
+9.
+10.
+11.
+3.
+In or around July 2004, Defendant JEFFREY EPSTEIN stroked the vagina of
+Jane Doe #8, who was then a seventeen-year-old girl.
+In or around July 2004, Defendant JEFFREY EPSTEIN paid approximately
+$200 to Jane Doe #8.
+In or around July 2004, Defendant JEFFREY EPSTEIN paid $200 to T.M. for
+recruiting Jane Doe #8 to travel to 358 El Brillo Way.
+In or around July 2004, Defendant
+Defendant JEFFREY EPSTEIN would pay Jane Doe #8 if she returned with a friend.
+On or about July 15, 2004, Defendant
+told Jane Doe #8 that
+placed a telephone
+call to a telephone used by Jane Doe #7.
+On or about July 15, 2004, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #8.
+On or about July 15, 2004, Defendant
+placed a telephone
+call to a telephone used by T.M.
+On or about July 16, 2004, Defendant
+placed one or more
+telephone calls to a telephone used by Jane Doe #7.
+On or about July 16, 2004, Defendant
+placed a telephone
+call to a telephone used by T.M.
+On or about July 17, 2004, Defendant JEFFREY EPSTEIN reviewed a written
+telephone message prepared by one of his employees regarding a telephone call received
+from T.M. that read: "Me & [Jane Doe #7] can come tomorrow any time or [T.M.] alone".
+In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the
+presence of Jane Doe #7, who was then a sixteen-year-old girl.
+In or around July 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe
+#7, who was then a sixteen-year-old girl, to rub his nipples.
+In or around July 2004, Defendant JEFFREY EPSTEIN stroked the vagina of
+Jane Doe #7, who was then a sixteen-year-old girl.
+In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of
+$200 to Jane Doe #7.
+
+
+7.
+10.
+11.
+In or around July 2004, Defendant JEFFREY EPSTEIN told Jane Doe #7 that
+if she reported to anyone what had occurred at Defendant JEFFREY EPSTEIN's home, bad
+things could happen to her.
+On or about July 24, 2004, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #8.
+Jane Does #9 and #10
+On or about July 15, 2004, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #9.
+On or about July 16, 2004, Defendant
+caused Jane Doe #9
+to make a telephone call to a telephone used by Jane Doe #10.
+On or about July 17, 2004, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #9.
+On or about July 18, 2004, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #9.
+On or about July 22, 2004, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #9.
+In or around July 2004, Defendant JEFFREY EPSTEIN fondled the breasts of
+Jane Doe #9, who was then a seventeen-year-old girl.
+In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the
+presence of Jane Doe #9, who was then a seventeen-year-old girl.
+In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of
+$200 to Jane Doe #9.
+On or about July 22, 2004, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #10.
+In or around the last half of 2004, Defendants JEFFREY EPSTEIN and
+engaged in oral sex and sexual intercourse in the presence of Jane
+Doe #9, who was then a seventeen-year-old girl.
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN forcibly
+inserted his penis into the vagina of Jane Doe #9, who was then a seventeen-year-old girl.
+
+
+15.
+16.
+17.
+18.
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a
+payment of $300 to Jane Doe #9.
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN rubbed the
+vagina of Jane Doe #10, who was then a seventeen-year-old girl.
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a
+payment of $200 to Jane Doe #10.
+On or about November 28, 2004, Defendant JEFFREY EPSTEIN arranged for
+one of his employees to provide an envelope filled with cash to Jane Doe #9.
+On or about December 4, 2004, Defendant
+provided a
+written message to Defendant JEFFREY EPSTEIN regarding Jane Does # 9 and 10, stating:
+"[Jane Doe #10] would like to work @ 4:00 pm if possible. [[Jane Doe #9] is scheduled for
+5:00 today.] the movie is @ 7:30".
+On or about December 29, 2004, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #9.
+On or about December 30, 2004, Defendants JEFFREY EPSTEIN and
+caused the purchase of Broadway tickets as an eighteenth birthday gift
+for Jane Doe #9.
+19.
+In or around the last half of 2004 or January 2005, Defendant JEFFREY
+EPSTEIN masturbated in the presence of Jane Doe #10, who was then a seventeen-year-old
+girl.
+20.
+21.
+22.
+23.
+24.
+In or around the last half of 2004 or January 2005, Defendant JEFFREY
+EPSTEIN fondled the breasts of Jane Doe #10, who was then a seventeen-year-old girl.
+On or about January 14, 2005, Defendant
+placed one or
+more telephone calls to a telephone used by Jane Doe #10.
+On or about January 27, 2005, Defendant
+" placed one or more telephone calls to a telephone used by Jane Doe #10.
+On or about January 28, 2005, Defendant
+,, a/k/a "L
+placed one or
+more telephone calls to a telephone used by Jane Doe #10.
+On or about February 1, 2005, Defendant
+placed one
+or more telephone calls to a telephone used by Jane Doe #10.
+
+
+25.
+In or around February 2005, Defendant JEFFREY EPSTEIN caused a payment
+of $200 to be made to Jane Doe #9 for recruiting Jane Doe #16 to travel to 358 El Brillo
+Way.
+3.
+Jane Doe #11
+In or around the summer of 2004, Defendant
+led Jane Doe
+#11 and T.M. from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY
+EPSTEIN's master bedroom suite.
+In or around the summer of 2004, Defendant JEFFREY EPSTEIN paid $200 to
+T.M. for bringing Jane Doe #11 to 358 El Brillo Way.
+In or around the summer of 2004, Defendant JEFFREY EPSTEIN masturbated
+in the presence of Jane Doe #11, who was then a fifteen- or sixteen-year-old girl.
+In or around the summer of 2004, Defendant JEFFREY EPSTEIN instructed
+Jane Doe #11 to rub his chest and pinch his nipples while he masturbated.
+In or around the summer of 2004, Defendant JEFFREY EPSTEIN instructed
+Jane Doe #11 to write her telephone number on a notepad in his master bedroom suite.
+In or around the summer of 2004, Defendant JEFFREY EPSTEIN learned Jane
+Doe #lI's true age when he asked Jane Doe #11 how old she was and she responded
+truthfully.
+In or around the summer of 2004, Defendant JEFFREY EPSTEIN told Jane
+Doe #11 that he did not care how old she was and that he did not like girls older than
+eighteen.
+9.
+10.
+11.
+In or around the second half of 2004, Defendant JEFFREY EPSTEIN placed a
+vibrating massager on the vagina of Jane Doe #11, who was then a sixteen-year-old girl.
+In or around the second half of 2004, Defendant JEFFREY EPSTEIN digitally
+penetrated the vagina of Jane Doe #11, who was then a sixteen-year-old girl.
+On or about August 6, 2004, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #11.
+On or about August 18, 2004, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #11.
+
+
+15.
+16.
+17.
+18.
+On or about October 29, 2004, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #11.
+On or about November 5, 2004, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #11.
+On or about February 14, 2005, Defendant JEFFREY EPSTEIN reviewed a
+written telephone message prepared by one of his employees regarding a telephone call
+received from Jane Doe #11 that read: "Please! Call her back".
+On or about February 14, 2005, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #11.
+On
+or
+about February 21, 2005, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #11.
+On or about March 29, 2005, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #11.
+In or around the second half of 2005 or the first quarter of 2006, Defendant
+JEFFREY EPSTEIN offered to pay $400 to Jane Doe #11, who was then a sixteen-year-old
+girl, if she would engage in oral sex, or $500 or more if she would engage in sexual
+intercourse.
+19.
+3.
+In or around the second half of 2005, Defendant JEFFREY EPSTEIN offered
+to pay $100 to Jane Doe #11 if she would bring other girls to 358 El Brillo Way.
+Jane Does #12 and #13
+On or about August 2, 2004, Defendant JEFFREY EPSTEIN reviewed a
+written telephone message prepared by one of his employees regarding a telephone call
+received from T.M. and Jane Doe #12 that stated: "They are available all weekend and
+maybe [Jane Doe #13] too".
+On or about August 21, 2004, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #13.
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated
+in the presence of Jane Doe #12, who was then a seventeen-year-old girl.
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN digitally
+penetrated Jane Doe #12, who was then a seventeen-year-old girl.
+
+
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN attempted to
+place a massaging device on the vagina of Jane Doe #12, who was then a seventeen-year-old
+girl.
+7.
+9.
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a
+payment of $200 to Jane Doe #12.
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane
+Doe #12, who was then a seventeen-year-old girl, about her age.
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN told Jane
+Doe #12 that he would take her to Los Angeles when she turned eighteen.
+In or around the last half of 2004, Defendants JEFFREY EPSTEIN and
+caused Jane Doe #12 to recruit Jane Doe #13 to travel to 358 El Brillo
+Way.
+10.
+11.
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated
+in the presence of Jane Doe #13, who was then a seventeen-year-old girl.
+In or around the end of 2004, Defendant JEFFREY EPSTEIN placed a
+massaging device on the vagina of Jane Doe #13, who was then a seventeen-year-old girl.
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a
+payment of $200 to Jane Doe #13.
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN digitally
+penetrated Jane Doe #13, who was then a seventeen-year-old girl.
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane
+Doe #13, who was then a seventeen-year-old girl, about her age.
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN told Jane
+Doe #13 that he wanted to take her to Paris but he could not because Jane Doe #13 was not
+yet eighteen years old.
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane
+Doe #13 to bring her friends to his home, especially "girls who looked like [Jane Doe #13]."
+Jane Doe #14
+In or around the last half of 2004, Defendant
+led Jane Doe
+#14 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's
+
+
+9.
+10.
+11.
+15.
+bedroom at 358 El Brillo Way.
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane
+Doe #14 to provide her telephone number.
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN instructed
+Jane Doe #14, who was then a seventeen-year-old girl, to pinch his nipples.
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated
+in the presence of Jane Doe #14, who was then a seventeen-year old girl.
+In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a
+payment of $300 to Jane Doe #14.
+In or around the end of 2004 and the beginning of 2005, Defendant JEFFREY
+EPSTEIN digitally penetrated Jane Doe #14, who was then a seventeen-year-old girl.
+In or around the end of 2004 and the beginning of 2005, Defendant JEFFREY
+EPSTEIN asked Jane Doe #14, who was then a seventeen-year-old girl, whether she had any
+plans for her eighteenth birthday and acknowledged that she had not yet turned eighteen.
+On or about December 23, 2004, Defendant JEFFREY EPSTEIN caused a
+Western Union wire transfer order to be sent to Jane Doe #14.
+In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN placed a
+massaging device on the vagina of Jane Doe #14, who was then a seventeen-year-old girl.
+In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN engaged
+in sexual intercourse with Jane Doe #14, who was then a seventeen-year-old girl.
+In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+performed oral sex on Jane Doe #14, who was then a seventeen-year-old girl.
+In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN made a
+payment of $600 to Jane Doe #14.
+On or about January 8, 2005, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #14.
+On or about January 9, 2005, Defendant
+a/k/a"L
+'" placed a telephone call to a telephone used by Jane Doe #14.
+On or about January 26, 2005, Defendant
+a/k/a "l
+" reviewed a written telephone message prepared by one of Defendant JEFFREY
+
+
+16.
+17.
+18.
+19.
+20.
+3.
+EPSTEIN's employees regarding a call received from Jane Doe #14 that read: "She is
+confirming for 5:30".
+On or about January 26, 2005, Defendant
+, a/k/a "•
+'" placed a telephone call to a telephone used by Jane Doe #14.
+On or about February 1, 2005, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #14.
+On or about March 1, 2005, Defendant
+a/k/a "I
+'" placed a telephone call to a telephone used by Jane Doe #14.
+On or about March 21, 2005, Defendant
+a/k/a "l
+'" placed a telephone call to a telephone used by Jane Doe #14.
+On or about March 29, 2005, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #14.
+Jane Doe #15
+On or about December 6, 2004, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #15.
+On or about December 14, 2004, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #15.
+In or around the first half of 2005, Defendant
+led Jane Doe
+#15 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's
+bedroom at 358 El Brillo Way.
+In or around the first half of 2005, Defendant JEFFREY EPSTEIN instructed
+Jane Doe #15, who was then a seventeen-year-old girl, to pinch his nipples while he
+masturbated.
+In or around the first half of 2005, Defendant JEFFREY EPSTEIN fondled the
+breasts of Jane Doe #15.
+In or around the first half of 2005, Defendant JEFFREY EPSTEIN made a
+payment of $200 to Jane Doe #15.
+On or about January 7, 2005, Defendant
+a/k/a "C
+" placed a telephone call to a telephone used by Jane Doe #15.
+
+
+9.
+10.
+11.
+15.
+16.
+17.
+3.
+On or about February 4, 2005, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #15.
+On or about February 10, 2005, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #15.
+On or about February 21, 2005, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #15.
+On or about February 24, 2005, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #15.
+On or about March 17, 2005, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #15.
+On or about March 30, 2005, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #15.
+On or about March 31, 2005, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #15.
+On or about March 31, 2005, Defendant
+a/k/a "L
+" placed a telephone call to a telephone used by Jane Doe #15.
+On or about April 1, 2005, Defendant JEFFREY EPSTEIN reviewed a note
+prepared by one of his employees that read: "10:30 [Jane Doe #15]/[Jane Doe #10] on Fri
+around 2'Oclock".
+In or around June 2005, Defendant JEFFREY EPSTEIN provided Jane Doe
+#15 with a gift of Victoria's Secret lingerie for her eighteenth birthday.
+Jane Does #16 & #17
+In or around February 2005, Defendant JEFFREY EPSTEIN masturbated in
+the presence of Jane Doe #16, who was then a seventeen-year-old girl.
+In or around the first quarter of 2005, Defendants JEFFREY EPSTEIN and
+caused Jane Doe #16 to place a telephone call to Jane Doe #17 to ask her
+to travel to 358 El Brillo Way.
+In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN caused a
+payment to be made to Jane Doe #16 for recruiting Jane Doe #17 to travel to 358 El Brillo
+Way.
+
+
+In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+masturbated in the presence of Jane Doe #17, who was then a sixteen-year-old girl.
+In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
+instructed Jane Doe #17, who was then a sixteen-year-old girl, to remove all of her clothing.
+In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN placed a
+massaging device on the vagina of Jane Doe #17, who was then a sixteen-year-old girl.
+In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN made a
+payment of $200 to Jane Doe #17, who was then a sixteen-year-old girl.
+In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN
+placed a massaging device on the vagina of Jane Doe #16, who was then a seventeen-yearold girl.
+10.
+11.
+In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN
+asked Jane Doe #16, who was then a seventeen-year-old girl, how old she was, and she
+responded that she was seventeen years old.
+In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN
+engaged in sexual activity with Defendant
+in the presence of Jane
+Doe #16, who was then a seventeen-year-old girl.
+In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN
+asked Jane Doe #16, who was then a seventeen-year-old girl, to touch the breast of
+Defendant
+15.
+16.
+On or about April 11, 2005, Defendant
+a/k/a "C
+'" placed a telephone call to a telephone used by Jane Doe #16.
+On or about April 11, 2005, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #16.
+On or about April 11, 2005, Defendant
+Defendant JEFFREY EPSTEIN stating: "[Jane Doe #16] can work tomorrow at 4pm."
+On or about May 19, 2005, Defendant
+left a message for
+placed a telephone
+call to a telephone used by Jane Doe #16.
+On or about June 30, 2005, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #16.
+
+
+17.
+18.
+19.
+20.
+21.
+22.
+23.
+24.
+25.
+26.
+27.
+28.
+29.
+30.
+On or about July 2, 2005, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #16.
+On or about July 22, 2005, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #16.
+On or about August 18, 2005, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #16.
+On or about August 19, 2005, Defendant
+a/k/a "
+'" placed a telephone call to a telephone used by Jane Doe #16.
+On or about August 21, 2005, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #16.
+On or about September 3, 2005, Defendant
+a/k/a"l
+!" placed a telephone call to a telephone used by Jane Doe #16.
+On or about September 18, 2005, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #16.
+On or about September 19, 2005, Defendant
+sent a text
+message to a telephone used by Jane Doe #16.
+On or about September 29, 2005, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #16.
+On or about September 30, 2005, Defendant
+a/k/a "l
+" placed a telephone call to a telephone used by Jane Doe #16.
+On or about October 1, 2005, Defendant
+left a telephone
+message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #15] confirmed at 11 AM
+and [Jane Doe #16]- 4PM".
+On or about October 2, 2005, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #16.
+On or about October 3, 2005, Defendant
+placed a telephone
+call to a telephone used by Jane Doe #16.
+On or about October 3, 2005, Defendant
+left a telephone
+message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #16] will be ½ hour late".
+
+
+31.
+32.
+33.
+7.
+9.
+In or around the first week of October, 2005, Defendant JEFFREY EPSTEIN
+engaged in sexual intercourse with Jane Doe #16, who was then a seventeen-year-old girl.
+In or around the first week of October, 2005, Defendant JEFFREY EPSTEIN
+made a payment of $350.00 to Jane Doe #16, who was then a seventeen-year-old girl.
+In or around the first week of October, 2005, Defendant JEFFREY EPSTEIN
+provided a gift of Victoria's Secret lingerie to Jane Doe #16 for her eighteenth birthday.
+Jane Does #18 and #19
+In or around the last half of 2003, Jane Doe #18 was approached by A.F. and
+was asked whether she would be willing to provide a massage to Defendant JEFFREY
+EPSTEIN in exchange for $200.
+In or around the last half of 2003, Defendant JEFFREY EPSTEIN asked Jane
+Doe #18 to provide her telephone number.
+On or around August 27, 2003, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #18.
+In or around the last half of 2003, Defendant JEFFREY EPSTEIN masturbated
+in the presence of Jane Doe #18, who was then a seventeen-year-old-girl.
+On or around November 16, 2003, Defendant
+placed a
+telephone call to a telephone used by Jane Doe #18.
+In or around the last half of 2003, Defendant JEFFREY EPSTEIN digitally
+penetrated Jane Doe #18, who was then a seventeen-year-old-girl.
+In or around the last half of 2003, Defendant JEFFREY EPSTEIN asked Jane
+Doe #18 to recruit other females to travel to 358 El Brillo Way.
+On or about March 5, 2004, Defendant JEFFREY EPSTEIN asked Jane Doe
+#19, who was then a seventeen-year-old girl, to leave when she refused to remove her shirt.
+On or about March 5, 2004, Defendant JEFFREY EPSTEIN verbally
+reprimanded Jane Doe #18 for bringing Jane Doe #19 to 358 El Brillo Way when she was
+not willing to undress for him.
+, and
+The Defendants' Travel
+On or about July 16, 2004, Defendants JEFFREY EPSTEIN,
+traveled from Teterboro, New Jersey to Palm Beach
+
+
+County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.
+On or about August 6, 2004, Defendants JEFFREY EPSTEIN and
+traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the
+Boeing 727 aircraft owned by JEGE, INC.
+3.
+On or about August 19, 2004, Defendants JEFFREY EPSTEIN and
+traveled from Van Nuys, California to Palm Beach County, Florida aboard
+the Boeing 727 aircraft owned by JEGE, INC.
+On or about October 29, 2004, Defendants JEFFREY EPSTEIN and
+traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard
+the Gulfstream aircraft owned by Hyperion Air, Inc.
+On or about February 21, 2005, Defendants JEFFREY EPSTEIN,
+and
+traveled from the U.S. Virgin Islands to Palm
+Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC.
+On or about March 31, 2005, Defendant JEFFREY EPSTEIN traveled from
+New York, New York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned
+by JEGE, INC.
+7.
+On or about September 18, 2005, Defendants JEFFREY EPSTEIN,
+and
+• a/k/a "
+" traveled from Westchester
+County, New York to Palm Beach County, Florida aboard the Gulfstream aircraft owned by
+Hyperion Air, Inc.
+On or about September 29, 2005, Defendants JEFFREY EPSTEIN,
+a/k/a "
+1." and
+traveled from Teterboro,
+New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by
+Hyperion Air, Inc.
+All in violation of Title 18, United States Code, Section 371.
+COUNTS 2 THROUGH 11
+(Sex Trafficking: 18 U.S.C. § 1591(a)(1))
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference
+as though fully set forth herein.
+On or about the dates enumerated as to each count listed below, the exact dates being
+unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and
+
+
+elsewhere, the Defendants listed below did knowingly, in and affecting interstate and foreign
+commerce, recruit, entice, provide, and obtain by any means a person, that is, the person in each
+count listed below, knowing that the person had not attained the age of 18 years and would be caused
+to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1):
+Count
+Dates
+Minor Involved
+Defendants
+2
+2001 - 2004
+Jane Doe #2
+3
+4
+5
+6
+8
+9
+January 2004
+through
+July 2004
+July 2004
+through
+December 29, 2004
+July 2004
+through
+January 31, 2005
+Mid-2004
+through
+March 2005
+Mid-2004
+through
+April 22, 2005
+August 2004
+through
+May 27, 2005
+November 2004
+through
+March 2005
+Jane Doe #4
+Jane Doe #9
+Jane Doe #10
+Jane Doe #11
+Jane Doe #12
+Jane Doe #13
+Jane Doe #14
+10
+December 2004
+through
+June 5, 2005
+Jane Doe #15
+February 2005
+through
+first week of October
+2005
+Jane Doe #16
+a/k/a "l
+a/k/a "|
+a/k/a"
+All in violation of Title 18, United States Code, Sections 1591(a)(1) and 2.
+COUNT 12
+(Sex Trafficking: 18 U.S.C. § 1591(a)(2))
+
+
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference
+as though fully set forth herein.
+From at least as early as in or about 2001 through in or about October 2005, the exact
+dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida,
+and elsewhere, the defendants,
+1, a/k/a "l
+and
+did knowingly benefit, financially or by receiving anything of value, from participation in a venture, as
+defined in 18 U.S.C. § 1591(c)(3), which had engaged in an act described in violation of 18 U.S.C. §
+1591(a)(1), that is, the recruiting, enticing, providing, and obtaining by any means a person, in or
+affecting interstate commerce, knowing that the person or persons had not attained the age of 18 years
+and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in
+violation of Title 18, United States Code, Sections 1591(a)(2), 1591(b)(2), and 2.
+COUNT 13
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference
+as though fully set forth herein.
+From in or around the spring of 2003 through on or about October 2, 2005, the exact
+dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida,
+and elsewhere, the defendants,
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce
+and entice Jane Doe #3, who was a person who had not attained the age of 18 years, to engage in
+prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is
+violations of Florida Statutes Sections 800.04(5)(a), 800.04(6)(a), and 800.04(7)(a); in violation of Title
+18, United States Code, Sections 2422(b) and 2.
+COUNT 14
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference
+as though fully set forth herein.
+
+
+In or around July 2004, the exact dates being unknown to the Grand Jury, in Palm
+Beach County, in the Southern District of Florida, and elsewhere, the defendants,
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce
+and entice Jane Doe #7, who was a person who had not attained the age of 18 years, to engage in
+prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2.
+COUNT 15
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference
+as though fully set forth herein.
+From in or around July 2004 through in or around October 2004, the exact dates being
+unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and
+elsewhere, the defendants,
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce
+and entice Jane Doe #8, who was a person who had not attained the age of 18 years, to engage in
+prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2.
+COUNT 16
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference
+as though fully set forth herein.
+From in or around July 2004 through on or around December 29, 2004, the exact dates
+being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and
+elsewhere, the defendants,
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce
+and entice Jane Doe #9, who was a person who had not attained the age of 18 years, to engage in
+prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is a
+
+
+violation of Florida Statutes Section 794.05; in violation of Title 18, United States Code, Sections
+2422(b) and 2.
+COUNT 17
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference
+as though fully set forth herein.
+From in or around July 2004 through on or about January 31, 2005, the exact dates
+being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and
+elsewhere, the defendants,
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce
+and entice Jane Doe #10, who was a person who had not attained the age of 18 years, to engage in
+prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2.
+COUNT 18
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference
+as though fully set forth herein.
+From in or around the middle of 2004 through in or about March 2005, the exact dates
+being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and
+elsewhere, the defendants,
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce
+and entice Jane Doe #11, who was a person who had not attained the age of 18 years, to engage in
+prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2.
+COUNT 19
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference
+as though fully set forth herein.
+From in or around the middle of 2004 through on or about April 22, 2005, the exact
+dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida,
+and elsewhere, the defendants,
+
+
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce
+and entice Jane Doe #12, who was a person who had not attained the age of 18 years, to engage in
+prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2.
+COUNT 20
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference
+as though fully set forth herein.
+From in or around August 2004 through on or about May 27, 2005, the exact dates
+being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and
+elsewhere, the defendants,
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce
+and entice Jane Doe #13, who was a person who had not attained the age of 18 years, to engage in
+prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2.
+COUNT 21
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference
+as though fully set forth herein.
+From in or around November 2004 through in or around March 2005, the exact dates
+being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and
+elsewhere, the defendants,
+JEFFREY EPSTEIN,
+and
+, a/k/a"
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce
+and entice Jane Doe #14, who was a person who had not attained the age of 18 years, to engage in
+prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is a
+violation of Florida Statutes Section 794.05 ; in violation of Title 18, United States Code, Sections
+2422(b) and 2.
+COUNT 22
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+
+
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference
+as though fully set forth herein.
+From in or around December 2004 through on or about June 5, 2005, the exact dates
+being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and
+elsewhere, the defendants,
+JEFFREY EPSTEIN,
+_ and
+,, a/k/a "
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce
+and entice Jane Doe #15, who was a person who had not attained the age of 18 years, to engage in
+prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2.
+COUNT 23
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference
+as though fully set forth herein.
+From in or around February 2005 through in or around the first week of October 2005,
+the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of
+Florida, and elsewhere, the defendants,
+JEFFREY EPSTEIN,
+, a/k/a "
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce
+or entice Jane Doe #16, who was a person who had not attained the age of 18 years, to engage in
+prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is a
+violation of Florida Statutes Section 794.05 ; in violation of Title 18, United States Code, Sections
+2422(b) and 2.
+COUNT 24
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference
+as though fully set forth herein.
+From in or around February 2005 through in or around April 2005, the exact dates
+being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and
+elsewhere, the defendants,
+JEFFREY EPSTEIN,
+
+
+1, and
+• a/k/a "
+"9
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce
+and entice Jane Doe #17, who was a person who had not attained the age of 18 years, to engage in
+prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2.
+COUNT 25
+(Enticement of a Minor: 18 U.S.C. § 2422(b))
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference
+as though fully set forth herein.
+From in or around August 2003 through in or around February 2004, the exact dates
+being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and
+elsewhere, the defendants,
+JEFFREY EPSTEIN,
+and
+did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce
+and entice Jane Doe #18, who was a person who had not attained the age of 18 years, to engage in
+prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2.
+COUNT 26
+(Conspiracy to Travel: 18 U.S.C. § 2423(e))
+Paragraphs 1 through 23 of this indictment are re-alleged and incorporated by reference
+as fully set for the herein.
+unknown to the Grand Jury, the Defendants,
+From at least as early as 2001 through in or around October 2005, the exact dates being
+JEFFREY EPSTEIN,
+1, a/k/a "l
+and
+did knowingly and willfully conspire with each other and with others known and unknown to travel in
+interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. §
+2423(f), with another person, in violation of Title 18, United States Code, Section 2423(b); all in
+violation of Title 18, United States Code, Section 2423(e).
+COUNT 27
+(Facilitation of Unlawful Travel of Another: 18 U.S.C. § 2423(d))
+
+
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference
+as though fully set forth herein.
+From at least as early as in or about 2001 through in or around October 2005, the exact
+dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida,
+and elsewhere, the Defendant,
+did, for the purpose of commercial advantage or private financial gain, arrange and facilitate the travel
+of a person, that is Defendant Jeffrey Epstein, knowing that such person was traveling in interstate
+commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f); in
+violation of Title 18, United States Code, Section 2423(d).
+COUNTS 28 THROUGH 35
+(Travel to Engage in Illicit Sexual Conduct: 18 U.S.C. § 2423(b))
+Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference
+as though fully set forth herein.
+On or about the dates enumerated as to each count listed below, from a place outside
+the Southern District of Florida to a place inside the Southern District of Florida, the Defendants
+listed below traveled in interstate commerce for the purpose of engaging in illicit sexual conduct as
+defined in 18 U.S.C. § 2423(f), with a person under 18 years of age, that is, the person(s) listed in
+each count below:
+Count
+Date
+28
+7/16/2004
+Defendants
+29
+8/6/04
+30
+8/19/04
+10/29/04
+32
+2/21/05
+Minor(s) Involved
+Jane Doe #7
+Jane Doe #8
+Jane Doe #9
+Jane Doe #10
+Jane Doe #9
+Jane Doe #11
+Jane Doe #9
+Jane Doe #10
+Jane Doe #11
+Jane Doe #10
+Jane Doe #11
+Jane Doe #13
+Jane Doe #11
+Jane Doe #14
+Jane Doe #15
+a/k/a "l
+
+
+33
+3/31/2005
+34
+9/18/2005
+Jane Doe #11
+Jane Doe #14
+Jane Doe #15
+Jane Doe #16
+Jane Doe #16
+a/k/a"l
+a/k/a"
+35
+9/29/05
+Jane Doe #16
+a/k/a
+All in violation of Title 18, United States Code, Sections 2423(b) and 2.
+FORFEITURE 1
+Upon conviction of the violation alleged in Count 1 of this indictment, the defendants, JEFFREY
+EPSTEIN,
+a/k/a
+" and L
+shall forfeit to the United States any property, real or personal, which constitutes or is
+derived from proceeds traceable to the violation.
+Pursuant to Title 28, United States Code, Section 2461; Title 18, United States Code, Section
+981(a)(1)(C); and Title 21, United States Code, Section 853.
+If the property described above as being subject to forfeiture, as a result of any act or
+omission of the defendants, JEFFREY EPSTEIN,
+a/k/a "l
+'and
+(1) cannot be located upon the exercise of due diligence;
+(2) has been transferred or sold to, or deposited with a third person;
+(3) has been placed beyond the jurisdiction of the Court;
+(4) has been substantially diminished in value; or
+(5) has been commingled with other property which cannot be subdivided without difficulty;
+it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to seek
+forfeiture of any other property of the defendants up to the value of the above forfeitable property.
+All pursuant to Title 28 United States Code, Section 2461; Title 18, United States Code, Section
+981(a)(1)(C); and Title 21 United States Code, Section 853.
+FORFEITURE 2
+
+
+Upon conviction of any of the violations alleged in Counts 13-35 of this indictment, the
+defendants, JEFFREY EPSTEIN,
+a/k/a"
+," and
+shall forfeit to the United States any property, real or personal, constituting or
+traceable to gross profits or other proceeds obtained from such offense; and any property, real or
+personal, used or intended to be used to commit or to promote the commission of such offense,
+including but not limited to the following:
+a. A parcel of land located at 358 El Brillo Way, Palm Beach, Florida 33480, including all
+buildings, improvements, fixtures, attachments, and easements found therein or thereon, and more
+particularly described as:
+Being all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as recorded in Plat
+Book 9, Page 9, in the records of Palm Beach County, Florida and
+BEING that portion lying West of Lot 40, El Bravo Park, in Section 27, Township 43
+South, Range 43 East, as recorded in Plat Book 9, Page 9, Public Records of Palm Beach
+County, Florida, being bounded on the West by the West side of an existing concrete
+seawall and the northerly extension thereof as shown on the Adair & Brady, Inc., drawing
+IS-1298, dated March 25, 1981, and bounded on the East by the shoreline as shown on the
+plat of El Bravo Park, and bounded on the North and South by the Westerly extensions of
+the North and South lines respectively of Lot 40, containing 0.07 acres, more or less.
+Pursuant to Title 18, United States Code, Section 2253.
+If any of the forfeitable property described in the forfeiture section of this indictment, as a result
+of any act or omission of the defendants JEFFREY EPSTEIN,
+a/k/a"
+' and
+(a) cannot be located upon the exercise of due diligence;
+(b) has been transferred or sold to, or deposited with, a third person;
+(c) has been placed beyond the jurisdiction of the Court;
+(d) has been substantially diminished in value; or
+(e) has been commingled with other property which cannot be divided without difficulty;
+it is the intent of the United States, pursuant to Title 18, United States Code, Section 2253(o), to seek
+forfeiture of any other property of said defendant up to the value of the above forfeitable property.
+Pursuant to Title 18, United States Code, Section 2253.
+FORFEITURE 3
+Upon conviction of any of the violations alleged in Counts 2-12 of this indictment, the
+defendants, JEFFREY EPSTEIN,
+, a/k/a "
+" and
+shall forfeit to the United States any property, real or personal, that was used
+
+
+or intended to be used to commit or to facilitate the commission of such violation; and any property, real
+or personal, constituting or derived from any proceeds that such person obtained, directly or indirectly,
+as a result of such violation, including but not limited to the following:
+a. A parcel of land located at 358 El Brillo Way, Palm Beach, Florida 33480, including all
+buildings, improvements, fixtures, attachments, and easements found therein or thereon, and more
+particularly described as:
+Being all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as recorded in Plat
+Book 9, Page 9, in the records of Palm Beach County, Florida and
+BEING that portion lying West of Lot 40, El Bravo Park, in Section 27, Township 43
+South, Range 43 East, as recorded in Plat Book 9, Page 9, Public Records of Palm Beach
+County, Florida, being bounded on the West by the West side of an existing concrete
+seawall and the northerly extension thereof as shown on the Adair & Brady, Inc., drawing
+S-1298, dated March 25, 1981, and bounded on the East by the shoreline as shown on th
+lat of El Bravo Park, and bounded on the North and South by the Westerly extensions of
+the North and South lines respectively of Lot 40, containing 0.07 acres, more or less.
+Pursuant to Title 18, United States Code, Section 1594(b).
+A TRUE BILL.
+FOREPERSON
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+-
+ASSISTANT UNITED STATES ATTORNEY
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/d6288943fc4293dca6c5fac204bd7dc65d3583f15bc79cc58c52248cf563407e.receipt.json b/vision-fixhub/ds9-unparsed-05/d6288943fc4293dca6c5fac204bd7dc65d3583f15bc79cc58c52248cf563407e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f0de5a046bddbe1cf77d38e6a4c8dd654b73d94d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d6288943fc4293dca6c5fac204bd7dc65d3583f15bc79cc58c52248cf563407e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1199,
+  "dataset": "marble-joined",
+  "doc_id": "d6288943fc4293dca6c5fac204bd7dc65d3583f15bc79cc58c52248cf563407e",
+  "engine": "marble-apple-vision",
+  "event_count": 34,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "c88eb7fc07963cd35c85de1f9bdd4beba997a0d6af30d82b6ca6cf55317ff4a5",
+  "output_sha256": "2432d2f9a7394463f7ca4956025a3858e91a1b810501c6f5af76bda004ef06c2",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/d63a6881c05e8d9cbd07df89c4007ef4de513beaa7518ae1a4a8e0cf56291714.md b/vision-fixhub/ds9-unparsed-05/d63a6881c05e8d9cbd07df89c4007ef4de513beaa7518ae1a4a8e0cf56291714.md
new file mode 100644
index 0000000000000000000000000000000000000000..1c3181032703ac940e36a1bcaeb464ce887735c3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d63a6881c05e8d9cbd07df89c4007ef4de513beaa7518ae1a4a8e0cf56291714.md
@@ -0,0 +1,95 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+West Palm Beach, FL 33401
+500 S. Australian Ave, Ste 400
+Facsimile:
+November 24, 2008
+DELIVERY BY ELECTRONIC MAIL
+Roy Black, Esq.
+Black Srebnick Kornspan & Stumpf P.A.
+201 S. Biscayne Blvd, Suite 1300
+Miami, FL 33131
+Re: Jeffrey Epstein
+Dear Roy:
+On Thursday I learned that Mr. Epstein applied for and was admitted to the Palm Beach
+County Sheriff's Office's work release program and that he has been on work release for the past
+few weeks. For the following reasons, the Office believes that Mr. Epstein's application to and
+participation in the work release program is a material breach of the Non-Prosecution Agreement.
+Accordingly, the United States demands that Mr. Epstein withdraw his application to participate
+in the program and complete his eighteen-month term of imprisonment in accordance with the
+Non-Prosecution Agreement.
+The Non-Prosecution Agreement provides that Epstein "shall be sentenced to consecutive
+terms of twelve (12) months and six (6) months in county jail for all charges, without any
+opportunity for withholding adjudication or sentencing, and probation or community control in
+lieu of imprisonment." I have more than a dozen e-mails between myself and Jay Lefkowitz
+discussing the U.S. Attorney's insistence on eighteen months of incarceration. You will recall
+that at one meeting you and Ms. Sanchez raised the idea of Mr. Epstein hiring Sheriff's Deputies
+to guard him as equivalent to imprisonment. Mr. Acosta specifically rejected that suggestion. It
+is our understanding from the Sheriff's Office that Mr. Epstein is paying off-duty Sheriff's
+Deputies to guard him while he "works" at Mr. Goldberger's office building each day.
+As you remember, shortly before Mr. Epstein's change of plea, Mr. Goldberger sent me a
+copy of the proposed plea agreement with the state. On June 27, 2008, I sent a letter containing
+the following language to you and Mr. Goldberger:
+The U.S. Attorney's Office hereby provides Notice that the proposed sentencing
+provision does not comply with the terms of the Non-Prosecution Agreement.
+The second sentencing paragraph of the proposed plea agreement reads:
+On 08CF009381AMB, the Defendant is sentenced to 18 months Community Control 1
+(one). As a special condition of this Community Control, the Defendant must serve the
+first 6 months in the Palm Beach County Detention Facility ...
+The Non-Prosecution Agreement specifically provides:
+Epstein shall be sentenced to consecutive terms of twelve (12) months and six (6) months
+in county jail for all charges, ... without probation or community control in lieu of
+imprisonment.
+Thus, the proposed plea agreement with the State Attorney's Office does not comply with
+the terms of the Non-Prosecution Agreement. To comply with the Agreement, Mr. Epstein
+nust make a binding recommendation of eighteen months imprisonment , which mean
+confinement twenty-four hours a day at the County Jail, and the judge must accept tha
+recommendation. Community control must follow that term of incarceration.
+(Emphasis in original.)
+
+
+As I specified in that letter, the Non-Prosecution Agreement calls for "confinement
+twenty-four hours a day." In response to that letter, Mr. Goldberger agreed that he would revise
+the state plea agreement to include the word "imprisonment" to make clear that Mr. Epstein
+would be incarcerated for the full eighteen months and would change the language of the state
+agreement to match the language of the federal agreement. Mr. Goldberger and I also discussed
+the situation and he made clear that Mr. Epstein would not be asking for or receiving work
+release and would remain in jail "around the clock."
+In early August, Karen Atkinson and I raised the same issue with you when we heard that
+Mr. Epstein was considering applying for work release. On August 6, 2008, Ms. Atkinson and I
+had a conference call with you wherein you again stated that Mr. Epstein would not apply for or
+receive work release and would spend his eighteen months incarcerated twenty-four hours a day
+at the Palm Beach County Stockade.
+In preparation for this letter, I obtained a certified copy of Mr. Epstein's state court file.
+On June 30, 2008, on the procurement of minors charge, Judge Pucillo entered the following
+sentence:
+The defendant is hereby committed to the custody of the Sheriff of Palm Beach
+County, Florida for a term of 6 mos. It is further ordered that the Defendant shall
+be allowed a total of 1 days [ sic ] as credit for time incarcerated prior to imposition
+of this sentence. It is further ordered that the composite term of all sentences
+imposed for the counts specified in the order shall run consecutive to the following:
+Specific sentences: 2006CF9454AXX.
+... the following provisions apply to the sentence imposed: ... Followed by a
+period of 12 mos on community control 1 under the supervision of the Department
+of Corrections....
+As I learned on Friday when I received the state court file, you neglected to inform our
+Office that, on July 21, 2008, Judge McSorley modified the judgment nune pro tune to an "Order
+of Community Control I." This same language was the basis for the objection in my letter of
+June 26, 2008 and directly contradicts the language of the Non-Prosecution Agreement. I also
+note that, on the state plea agreement, Mr. Goldberger did not insert the word "imprisonment" as
+agreed prior to the change of plea, instead the words "jail sentence" are included.
+The Office's Agreement not to prosecute Mr. Epstein was based upon its determination
+that eighteen months' incarceration (i.e., confinement twenty-four hours a day) was sufficient to
+satisfy the federal interest in Mr. Epstein's crimes. Accordingly, the U.S. Attorney's Office
+hereby gives notice that Mr. Epstein has violated the Non-Prosecution Agreement by failing to
+remain incarcerated twenty-four hours a day for the eighteen-month
+term of imprisonment. The United States will exercise any and all rights it has under the Non-
+Prosecution Agreement unless Mr. Epstein immediately ceases and desists from his breach of this
+Sincerely,
+R. Alexander Acosta
+United States Attorney
+By:
+Assistant United States Attorney
+cc:
+Chief, Northern Division
diff --git a/vision-fixhub/ds9-unparsed-05/d63a6881c05e8d9cbd07df89c4007ef4de513beaa7518ae1a4a8e0cf56291714.receipt.json b/vision-fixhub/ds9-unparsed-05/d63a6881c05e8d9cbd07df89c4007ef4de513beaa7518ae1a4a8e0cf56291714.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a4cab035e844abd4bad8c9e641d5a912dcac8af6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d63a6881c05e8d9cbd07df89c4007ef4de513beaa7518ae1a4a8e0cf56291714.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "d63a6881c05e8d9cbd07df89c4007ef4de513beaa7518ae1a4a8e0cf56291714",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "8ccbbd029dfec02ba419064a1557f43eb3059636886618be78bd8121ef2ebec1",
+  "output_sha256": "64f041e286996df24f0957d0b0438932a8cd10d6b7c8753ee411855ad028857c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/d63eb53e2fcbef4909defac0a2ba11cdc2400ca776e154e6bde78a177b5b9a8c.md b/vision-fixhub/ds9-unparsed-05/d63eb53e2fcbef4909defac0a2ba11cdc2400ca776e154e6bde78a177b5b9a8c.md
new file mode 100644
index 0000000000000000000000000000000000000000..ed07b86bfc95efff1f679a6afa6c7f9b1896ea9c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d63eb53e2fcbef4909defac0a2ba11cdc2400ca776e154e6bde78a177b5b9a8c.md
@@ -0,0 +1,3537 @@
+Statements
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary •••••••••••••••••••••••I/I/
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ............../....../....................
+Your Messages .....................................
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 29, 2002
+3
+3
+4
+5
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+113,829
+9,346,503
+9,460,332
+9,449,358
+10,974
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+$9.460,332
+$9.449,358
+Current market value
+Last statement's market value
+Important Message
+If any information regarding
+2002interest, dividends,
+niscellaneous income
+ross proceeds or origina
+sue discount is require
+be reported to the IRS fo
+his acated Form 109
+ill be mailed to you b
+1a4250 M20 17, 2003.
+Flease raport any dierence or nonreceipt of chocks or stocks, indicated as delivered to you,
+to Client Services at 800-34.1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3669.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+: This statement should be retained for your records. See reverse side for important informati
+01/01/03;09:30 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+01/01/03:09:30 001
+V639
+
+
+3 of 5
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited.
+Net Cash Activity
+Closing Balance
+THIS PERICO
+$113,757.87
+.. . .
+10,902.75
+71.10
+$10,973.85
+-10,902.75
+-10,902.75
+.. ..
+71.10
+$113.828.97
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+113,757.87
+$113,757.87
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+10,902.75
+71.10
+$10,973.85
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+CLOSING
+113,828.97
+$113,828.97
+YEAR TO DATE
+46,502.81
+3,361.85
+......
+549.864.66
+9,460,332
+59.-460,332
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+SYMBOUCUSIP
+QUANTITY
+FRICE
+MARKET
+VALUE
+113,829
+027
+ESTIMATED
+ANNUAL INCOME
+CURRENT
+YIELD (%)
+....
+01/01/03;09:30 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 29, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+4 or5
+Your Portfolio Holdings (continued)
+CASH & CASH EQUIVALENTS (continued)
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+NSTITUTIONAL SHARES
+ST, 30 DAY AVG YIELD 1,22009
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+DICXX
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 29,2002
+QUANTITY
+9,346,502.81
+PRICE
+1.0000
+MARKET
+VALUE
+9,346,503
+$9,460,332
+ESTIMATED CURRENT
+ANNUAL INCOME
+YELD (%)
+130,851
+1.4000
+$130,851
+$130,851
+$9,460,332
+Transaction Detail
+MONEY FUND ACTIVITY
+TRANSACTION
+11/30/02
+12/02/02 DIVIDEND"
+1202/02 REINVEST
+12/31/02
+TOTAL
+ESCAIPTICY
+OPENINGBALANCE
+PETE HAS MANACEMENFCLA
+MONTHLY DIVIDEND
+DIVIDEND REINVESTED
+CLOSINGBALANCE
+SYMBOUCUSIP
+"DiCXX
+'DICXX"
+QUANTITY
+9,335,600.06
+10,902.75
+9,346,502.81
+027
+PRICE
+DEBIT AMOUNT
+10,902.75
+10.902.75
+$-10,902.75
+$10,902.75
+01/01/03;09:30 001
+
+
+5 of5
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+12/23/02
+INTEREST ON CREDIT BALANCE
+AT 0 3/4% 11/21 THRU 12/20
+TOTAL
+SYMBOL/CUSIP
+Your messages
+As part of the National Association of Securities Dealers (NASD)
+Investor Education Program, you may obtain information on the
+STOP
+****** End of Statement******
+QUANTITY
+RATE (%)
+0.7500
+027
+DEBIT AMOUNT
+01/01/03;09:30 001
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 29,2002
+71.10
+$71.10
+VB39
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail ..................................
+Fund Activity ............../....../....................
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25,2002
+3
+4
+4
+Hollandiml
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+...
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+113,758
+9,335,600
+$9.449,358
+9,436,156
+13,202
+here are no "Stop Loss" orders or other pending bu
+r sell open orders on file for your account
+Market Value of Your Portfolio
+Cash & Equivalent
+$9.449,358
+$9.436,156
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as delivered to you,
+to Client Services at 800 634-1428; or writa to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3669.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 of 5
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+113,658.70
+.....
+13,102.87
+99.17
+$13,202.04
+-13,102.87
+$-13,102.87
+....
+99.17
+5113.757.87
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+113,658.70
+$113,658.70
+Income Summary
+THIS PERIOD
+Dividends
+13,102.87
+Credit Balance Int.
+99.17
+Total
+$13.202.04
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+CLOSING
+113,757.87
+5113.757.87
+YEAR TO DATE
+35,600.06
+3,290.75
+$38.890.81
+9,449,358
+$9,449,358
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+SYMBOUCUSIP
+QUANTITY
+FRICE
+MARKET
+VALUE
+113,758
+027
+ESTIMATED
+ANNUAL INCOME
+CURRENT
+YIELD (%)
+....
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25,2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+VE38
+
+
+4 or5
+Your Portfolio Holdings (continued)
+CASH & CASH EQUIVALENTS (continued)
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+NSTITUTIONAL SHARES
+ST, 30 DAY AVG YIELD 1,39009
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+DICXX
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25, 2002
+QUANTITY
+9,335,600.06
+PRICE
+1.0000
+MARKET
+VALUE
+9,335,600
+$9,449,358
+ESTIMATED
+CURRENT
+ANNUAL INCOME
+YELD (%)
+158,705
+1.7000
+$158,705
+$158,705
+$9,449,358
+Transaction Detail
+MONEY FUND ACTIVITY
+RATELY
+TRANSACTION
+10/26/02
+17701/02 DIVIDEND"
+17701702 REINVEST
+11/29/02
+TOTAL
+ESCAIPTICY
+OPENINGBALANCE
+PRETE ONES MANAGEMENECTA
+MONTHLY DIVIDEND
+DIVIDEND REINVESTED
+CLOSINGBALANCER
+SYMBOUCUSIP
+QUANTITY
+9,322,497.19
+13,102.87
+9,335,600.06
+027
+PRICE
+DEBIT AMOUNT
+13,102.87
+13,.102.87
+$-13,102.87
+$13,102.87
+VE38
+
+
+5 or 5
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+INTEREST
+DATE
+11/21/02
+DESCRIPTION
+INTEREST ON CREDIT BALANCE
+AT 0 3/4% 11/06 THRU 11/20
+SYMBOL/CUSIP
+TOTAL
+STOP
+****** End of Statement******
+QUANTITY
+RATE (%)
+0.7500
+1.2500
+027
+DEBIT AMOUNT
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD October 26, 2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25, 2002
+35.52
+...
+63.65
+$99.17
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail .................................
+Fund Activity …....••••••••••••••••••••IIIII
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+3
+Hollandlold
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+113,659
+9,322,497
+$9,436,156
+9,542,114
+- 105,958
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+Equities -
+$9.436,156
+$9.480,006
+$0
+$62,108
+Current market value
+Last statement's market value
+Flease raport any dierence or non-receipt of chacks or stocks, indicated as delivered to you.
+to Client Services at 800-634.1428; or writa to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859
+SP The suremen s four ratanal purger rebr de Set revere date for portant iformation.
+
+
+2 of 6
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+V637
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Money Fund
+Funds Withdrawn
+Amount Debited.
+Net Cash Activity
+Closing Balance,
+THIS PERICO
+5469.941.16
+63,172.01
+12,432.16
+241.98
+3,325.55
+$79,171.70
+-312,432.16
+-123,022.00
+5 435 454.16
+-356,282.46
+$113.658.70
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+12,432.16
+241.98
+$12,674.14
+Portfolio Composition
+Cash/Cash Equivalent
+Tota
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+469,941.16
+$469,941.16
+CLOSING
+113,658.70
+......
+$113,658.70
+027
+YEAR TO DATE
+22,497.19
+3,191.58
+____.
+$25,688.77
+......
+9,436,156
+9,436,15
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+VB37
+
+
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+... . . .
+DREYFUS CASH MANAGEMENT-CLA
+TOTAL CASH & CASH EQUIVALENTS
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+SYMBOLCUSIP
+DICXX
+QUANTITY
+9,322,497.19
+Transaction Detail
+INVESTMENT ACTIVITY
+DATE EMENT TRIE
+TRANSACTION
+10/07/02
+10/02/02
+SOLD
+10/08/02
+RECEIVED
+1025/02
+10/22/02
+"SOLD
+TOTAL
+DESCRIPTION
+UNITED RETAIL GROUP INC
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+AVG PRICE: DETAILS ON REQUEST
+AS OF 10/02/02
+"CANDIES INC
+CANDIES INC
+PRICE
+1.0000
+MARKET
+VALUE
+113,659
+9,322,497
+$9,436,156
+ESTIMATED
+ANNUAL INCOME
+*******•//--.
+158,482 1.7000
+$158,482
+$158,482
+$9,436,156
+SYMBOLCUSP
+URGI
+CAND
+CAND
+QUANTITY
+- 13,650
+502
+-502
+PRICE
+4.65060
+1.13000
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+DEBIT AMOUNT
+62,657.27
+514.74
+$63,172.01
+VE37
+
+
+5 of 8
+Transaction Detail (continued)
+DEPOSITS AND WITHDRAWALS
+1001/02
+TRANSACTION
+FND WIRED
+10/24/02 CHECK
+TOTAL
+DESCRIPTION
+GEORGE MADASON
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+09/28/02
+10/01/0Z
+"DIVIDEND'
+10/01/02
+"REINVEST
+10/02/02 BOUGHT
+10/25/02
+TOTAL
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27, 2002
+DEBIT AMOUNT
+117,430.00
+5.592.00
+$-123,022.00
+DESCRIPTION
+OPENINGBALANCE
+RYHASSMALGEMENFCLA
+MONTHLY DIVIDEND
+IVIDEND REINVESTEL
+REHEA MANAGEMENTCLA
+CLOSINGBALANCE
+SYMBOLCUSIP
+DICXX
+DICXX
+"DiCXX
+QUANTITY
+9,010,065.03
+12,432.16
+300,000
+9.322,497.19
+PRICE
+DEBIT AMOUNT
+1.0000
+12,432.16
+300,000.00
+$-312,432.16
+$12.432.16
+027
+VE37
+
+
+6 of 8
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+10/21/02
+INTEREST ON CREDIT BALANCE
+AT 1 1/4% 09/21 THRU 10/20
+TOTAL
+MISCELLANEOUS
+DATE
+MODAY
+10/08/02
+TRANSACTION
+10/11/02
+DESCRIPTION
+FROM: SJZ
+* JRL *
+FROM: SJZ/
+TOTAL
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUCUSIP
+L1-USD
+STOP
+****** End of Statement******
+QUANTITY
+RATE 1%
+1.2500
+DEBIT AMOUNT
+027
+DEBIT AMOUNT
+3,225.55
+100.00
+$3.325.55
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+241.98
+$241.98
+VB37
+
+
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary •••••••••••••••••••••••I/I/
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ............../....../....................
+Your Messages .....................................
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30,2002
+3
+6
+7
+Hollandlold
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+62,108
+469,941
+9,010,065
+$9,542,114
+••••••••/••••••••••••
+9,556,270
+-14,156
+here are no "Stop Loss" orders or other pending bu
+r sell open orders on file for your accoun
+Cash & Equivalent
+Equities
+Market Value of Your Portfolio
+$62,108
+$270,853
+Current market value
+Last statement's market value
+$9.480,006
+$9.285.417
+Important Message
+Confirmation: Unless we
+hear from you to the
+contrary, it is our
+understanding that any free
+redit balances in your
+account are being
+maintained to facilitate
+sour intentions things us.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal furyce rear die Set revere date for portant iformation.
+
+
+2 of 9
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 org
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+mount Debite
+Net Cash Activity
+Closing Balance
+THIS PERIOD
+3285.116.31
+184,153.54
+10,065.03
+370.81
+.. . .
+$194,589.38
+-10,065.03
+.$-10.065.03
+184,524.35
+5469-941.16
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+285,416.81
+$285,416.81
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+10,065.03
+370.81
+$10,435.84
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+CLOSING
+469,941.16
+$469,941.16
+YEAR TO DATE
+10,065.03
+2,949.60
+naaaaaaaaaan
+$13.014.63
+9,480,006
+62,108
+59.542.114
+09/29/02;13:15 001
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30,2002
+Your Portfolio
+Allocation
+Equities
+41%
+Cash & Equivalent-
+99%
+Unshaded portions denole debi balance and'or short
+from the absolute market value of your portolio.
+
+
+4 of g
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+... . . .
+DREYFUS CASH MANAGEMENT-CLA
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+UNITED RETAIL GROUP ING
+Total Equities& Options
+TOTAL EQUITIES
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+DICXX
+QUANTITY
+9,010,065.03
+PRICE
+1.0000
+SYMECUCUSIP
+URGI
+CASH
+QUANTITY
+13,650
+MARKET
+VALUE
+469,941
+9,010,065
+$9,480,006
+NUAL INCOM
+153,171
+$153,171
+1.7000
+PRICE
+4.5500
+URREN
+ELD C
+62,108
+$62,108
+$62,108
+$153,171
+$9,542,114
+$0
+$0
+120
+09/29/02;13:15 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+
+
+5 org
+Transaction Detail
+INVESTMENT ACTIVITY
+SETLEMENT TRIE
+DATE
+TRANSACTION
+09/04/02
+08/29/02
+SOLD
+9764/0208/29/02*SOLB
+09/05/02 08/30/02"SOLB"
+09/05/02
+08/30102
+09/05/02
+08/30/02
+SOLD
+SOLD
+09/05/02
+108/30/02
+"SOLD"
+0970970209/0402
+
+09706/02
+•......
+19/20/02
+09/17/02
+TOTAL
+"SOLD
+SOLD
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+CACHE ING NEW
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+UNSOLICITED
+AVG PRICE: DETAILS ON REQUEST
+"C-M'ASPAREL"CASUP 1'8***•
+UNSOLICITED
+"CACHE INC NEW"
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+UNSOLICITED
+AVG PRICE: DETAILS ON REQUEST
+""-I APPAREL GROUP LT**'*
+UNSOLICITED
+"NOVEL DENIM HOLDINGS LTD"
+AVG PRICE SHOWN-DETAILS ON REC
+ACTUAL CONFIRM TO YOUR AGENT
+UNSOLICITED
+AVG PRICE: DETAILS ON REQUEST
+"UNITED RETAIL GROUP INC**
+VG PRICE SHOWN-DETAILS ON RE
+CTUAL CONFIRM TO YOUR AGEN
+UNSOLICITED
+AVG PRICE: DETAILS ON REQUEST
+"NOVEL DENIM HOLDINGS LTD"
+UNSOLICITED
+"G- APPAREL GROUP LTD"
+UNSOLICITED
+ACHE INC NEV
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+UNSOLICITED
+AVG PRICE: DETAILS ON REQUEST
+SYMBOLGUSIP
+CACH
+"CACH"
+"VLD
+"URGI
+NILD
+"Gill"
+CACH
+027
+QUANTITY
+-1,100
+200°
+-1,000
+PRICE
+10.65000
+- 6:80000
+•7:0Ф00Ö
+100°
+2,200
+'6.75000
+5.19000
+- 1,500%
+5.00000
+*950
+20,550
+-1,350
+'5.12000
+- 6.00000
+10.46570
+CLEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+August 30, 2002
+DEBIT AMOUNT
+11,646.14
+1,327.45
+10,937.16
+642.47
+11,283.15
+7,407.27
+*4,804.35
+22,060.78
+14,044.77
+$184,153.54
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of g
+Transaction Detail (continued)
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+TRANSACTION
+08/31/02
+05/03/02 DIVIDEND
+DESCRIPTION
+OPENINGBALANCE
+PREYFUS CASH MANAGEMENT-CLA
+MONTHLY DIVIDEND
+08/03/02
+""REINVEST
+09/27/02
+TOTAL
+CLOSINGBALANCE
+INTEREST
+DATE
+TOTAL
+DESCRIPTION
+9/23/02 INTEREST ON CREDIT BALANC
+/ 1 1/4% 08/21 THRU 09/2
+SYMBOL/CUSIP
+SYMBOUCUSIP
+BICXX
+DICXX
+QUANTITY
+QUANTITY
+9,000,000
+10,065.03
+9,010,065.03
+RATE (NA
+1.2500
+027
+PRICE
+DEBIT AMOUNT
+09/29/02;13:15 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+DEBIT AMOUNT
+10,065.03
+10.065.03
+$-10,065.03
+$10,065.03
+370.81
+$370.81
+
+
+7 of g
+ear, Steams & Co. In
+83 Madison Avenu
+New York, New York 10179
+Your messages
+138
+Bear, Stearns Securities Corp, Net Capital and Net Capital
+Requirements:
+A complete copy of the Bear, Stearns Securities Corp, Statement
+of Financial Condition is available on the web site
+www.bearstearns.com, Alternatively, to request a free printed copy
+please call -toll free 1-866-299-9331.
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+August 30, 2002
+Securities and other assets in your account are the firm's collateral
+for any margin loan made to you. If the securities and other assets in
+your account decline in value, so does the value of the collateral
+supporting your loan, and, as a result, the firm can take action, such
+as issue a margin call and/or sell securities or other assets in any of
+your accounts held with the member, in order to maintain the required
+equity in the account, It is important that you fully understand the
+risks involved in trading securities on margin. These risks include
+the following:
+> You can lose more funds than you deposit in the margin account.
+> The firm can force the sale of securities or other assets in your
+accounts).
+> The firm can sell your securities or other assets without contacting
+> You are not entitled to choose which securities or other assets in
+your accounts) are liquidated or sold to meet a margin call.
+> The firm can increase its "house" maintenance margin requirements
+at any time and is not required to provide you advance written notice.
+> You are not entitled to an extension of time on a margin call.
+027
+
+
+8 of 9
+Bear, Stears & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+13P
+This statement is provided to explain Bear, Stearns & Co. Inc.'s
+(BSC") payment for order flow practices.
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+Pursuant to SEC Rule 11Ac1-6, please note the following:
+Bear, Stearns & Co, Inc, will post its quarterly routing statistics at the
+following web link:
+Customers of Bear, Stearns & Co. Inc, may request information on
+any order executed within the prior six months from the time of the
+request, Specifically, you may request the identity of the venue to
+which the identified orders were routed for execution, whether the order
+was directed by you to that venue, and the time of the executions, i
+any, that resulted from such orders.
+027
+09/29/02;13:15 001
+
+
+9 of 9
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+13P
+The following account service fees will be charged to applicable
+accounts as of November 1, 2002:
+The service charge per transaction will be $5,00, Accounts
+transferred from Bear Stearns will be charged a $75.00 account
+transter fee. There will be a $50,00 fee for each stock certificate
+hat is sent out in registered form at the customer's request, W
+strongly recommend against holding stock certificates in physica
+form due to the possibility of theft, loss or damage.
+13P
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+August 30, 2002
+NOTICE OF CHANGE PURSUANT TO THE TRUTH IN LENDING
+SEC RULE 10b-16
+Effective as of November 15, 2002, the annual rate of interest charged
+on any credit extended to you by Bear Steams Securities for the
+purpose of purchasing, carrying or trading in any security or other
+property shall be based on either the Bear Stearns Margin Basis Rate,
+the Bear Stearns Securities Fed Funds Rate or the London Interbank
+Offering Rate (LIBOR"). The Bear Stearns Margin Basis Rate will be
+quoted daily by Bear Stearns at our main office in New York, Factors
+affecting the determination of the Bear Stearns Margin Basis Rate
+will include the short-term market interest rates quoted by money
+center banks and the Federal Reserve and the rate that Bear Stearns
+is charged for borrowing money, The Bear Stearns Securities Fed
+Funds Rate is the rate for U.S. dollar funds, as quoted by an
+independent broker of such funds selected by Bear Stearns Securities
+for the last transaction completed prior to 9:30 a,m, (Eastern Time)
+on the business day on which such rate is determined. The annual
+rate of interest will be no more than 3% above the Bear Stearns
+Margin Basis Rate or 4% above either the Bear Stearns Securities
+Fed Funds Rate or LIBOR and will appear on your monthly statements.
+Since the rate of interest charged is related to the Bear Stearns
+Margin Basis Rate, the Bear Stearns Securities Fed Funds Rate or
+LIBOR, any changes in these rates will cause corresponding changes
+in the rate charged to your account, which changes will be made
+at least 30 days prior notice.
+The "Statement of Interest Charges Pursuant to the "Truth-in-Lending"
+SEC Rule 10b-16" previously provided to you remains in effect
+except to the extent specifically amended by this notice.
+027
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ....
+Your Portfolio Holdings
+Transaction Detail
+«aaaaaaaaaaaaaaas aaaaaaaaaaasan
+Fund Activity ........
+Trades Not Yet Settled
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+3
+4
+9
+Hollandlold
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+270,853
+285,417
+9,000,000
+$9,556,270
+••••••••••••
+82,178
+9,474,092
+ere are no "Stop Loss" orders or other pending bu
+r sell open orders on file for your accoun
+Market Value of Your Portfolio
+Cash & Equivalent -
+$82,178
+Equities— $270,853
+$0
+Current market value
+Last statement's market value
+$9.285.417
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal furyce rear die Set revere date for portant iformation.
+
+
+2 of 9
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or 9
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Funds Deposited
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERIOD
+$82,178.07
+.. . .
+385,566.14
+13,032.60
+2,014.15
+8,802,625.85
+$9,203,238.74
+-9,000,000.00
+$ 9.000.000.00
+203,238.74
+.....
+$285.416.81
+Income Summary
+Credit Balance Int.
+Total
+THIS PERIOD
+2,014.15
+$2.014.15
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OFENING
+82,178.07
+$82,178.07
+CLOSING
+285,416.81
+$285,416.81
+027
+YEAR TO DATE
+2,578.79
+$2.578.79
+9,285,417
+270,853
+$9,556,270
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26,2002
+Your Portfolio
+Allocation
+Equities
+2%
+Cash & Equivalent-
+98%
+Unshaded portions denole debit balance andor short
+
+
+4 of g
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+... ..
+DREYFUS CASH MANAGEMENT-CLA
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+NOVEL DENIM HOLDINGS LTD
+... . . .
+UNITED RETAIL GROUP INC
+Total Equities& Options
+TOTAL EQUITIES
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+DICXX
+QUANTITY
+9,000,000
+1.0000
+SYMBCUCUSIP
+CACH
+GIll
+NVLD
+URGI
+CASH
+CASH....*
+CASH
+........
+CASH
+QUANTITY
+3,450
+....•.!..
+20,850
+.. . .
+3,150
+... ..
+15,150
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+MARKET
+VALUE
+285,417
+9,000,000
+$9,285,417
+ESTIMATEL
+NUAL INCOM
+153,000
+$153,000
+1.7000
+PRICE
+11.0100
+6.7500
+... ...
+5.2000
+5.0000
+MARKET
+VALUE
+37,985
+140,738
+16,380
+75,750
+$270,853
+$270,853
+$153,000
+$9,556,269
+ESTIMATED
+ANNUAL INCOME
+$0
+$0
+CURRENT
+YIELD (%)
+027
+
+
+5 org
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTEMENT TREE
+07/31/02
+TRANSACTION
+
+JOUANAL'
+6775102******
+JOUANAL"
+07731/02
+07731/02
+07731/02
+JÖURNAL
+
+
+87751/02
+07731/02
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+CANDIES INC
+FROM: SJZ
+•1-USD
+"CANDIES INC'
+FROM: SJZ
+* JRL *
+-2-USD
+"CACHE"INC NEW''
+FROM: SJZ/
+-1-USD
+* JAL •
+FINLAY ENTERPRIS
+INC
+FROM: SJZ
+-1-USD
+* JRL *
+"ll APPAREL GROUP LTD
+FROM: SJZ
+1-USD
+* JAL
+HEARUSA INC
+NEW
+FROM: Suz/
+• 1-USD
+*JAL •
+MANNING"
+ROM: SJI
+•1-USD
+*JAL •
+NY REGISTRY
+FROM: SJZ
+- 1-USD
+• JAL *
+MAXWELL SHOECO NG-CLA
+FROM: Suz/
+-1-USD
+* JAL
+NOVEL DENIM HOLDINGS LTD
+FROM: SJZ
+-1-USD
+• JRL •
+'UNITED RETAIL GROUP INC
+FROM: SJZ|
+-1-USD
+• JRL •
+SYMBOLICUSIP
+CAND
+"CAND
+FNLY
+Gill
+EAR
+"HED
+"MAXS
+URGI
+027
+QUANTITY
+27,300
+PRICE
+7,750
+10,300
+20,850
+10,300
+1,500
+5,000*
+1,200
+12,250
+15,150
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD July 27, 2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+DEBIT AMOUNT
+
+
+6 of g
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SETTLEMENT TRADE
+DATE
+TRANSACTION
+08/07/02
+08/02/02
+SOLD
+08/07/02 08/02/02 SOLD
+686762**08/02/02"S0LB
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+08/08/02
+08/05/02
+08/08/02
+08405/02
+08/09/02
+08/06/02
+08/09/02 08/06/02
+08/12702
+08/07/02
+08/12/02
+
+20/21/89
+
+08713/02
+•008/02
+*SOLD
+SOLD
+"SOLD
+*SOL
+SOLD
+"SOLD
+"SOLD
+"SOLD
+DESCRIPTION
+FINLAY ENTERPRISES INC
+UNSOLICITED
+VG PRICE: DETAILS ON REQUES
+NY REGISTRY
+UNSOLICITED
+"MAXWELL" SHOECO INCELA
+UNSOLICITED
+WE MAKE A MKT IN THIS SECURITY
+REPORTED PRICE
+12,000000
+DIFFERENCE
+0.060000
+FINLAY ENTERPRISES INC
+INSOLICITE
+VG PRICE: DETAILS ON REQUES
+"-MANY INC
+ANG PRICE DETAILS ON REQUEST
+"CANDIES INC**
+UNSOLICITED
+AVG PRICE: DETAILS ON REQUEST
+"NOVEL DENIM HOLDINGS LD**
+UNSOLICITED
+AVG PRICE: DETAILS ON REQUEST
+"CANDIES INC
+JNSOLICITED
+VG PRICE: DETAILS ON REQUES
+"HEARUSA INC"***
+NEW
+VG PRICE SHOWN-DETAILS ON R
+TUAL CONFIRM TO YOUR AGEI
+NOVEL DENIM HOLDINGS LED
+UNSOLICITED
+"NOVEL DENIM HOLDINGS LTD
+SYMBOLGUSIP
+FNLY
+"HED
+"MAXS
+FNLY
+IMNY
+"CAND
+"CAND
+EAR
+"VLD
+027
+QUANTITY
+-134
+5,000
+:1,200
+10,166
+1,500
+:15,000
+5,600
+-13,720
+10,300
+1,000
+100°
+PRICE
+16.72180
+- 2.75000
+*T:94000***
+16.73160
+2.50660
+'2.70220
+= 6.10430
+
+0.62290
+6.00000
+6.00000
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+DEBIT AMOUNT
+2,231.45
+13,497.08
+14,325.06
+169,475.87
+*3,667.28
+33,844.55
+36.243.25
+6,283.17
+5,937.31
+547.48
+
+
+7 of g
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SETILEMENT TRADE
+DATE
+DATE
+TRANSACTION
+08/16/02
+08/13/02
+SOLD
+08/22/02 08/19/02 SOLD
+08/28/02
+''08/23/02
+08/28/02
+08/23/02
+SOLD
+DESCRIPTION
+NOVEL DENIM HOLDINGS LTD
+UNSOLICITED
+CACHE ING NEW...
+UNSOLICITED
+AVG PRICE: DETAILS ON REQUEST
+CACHE ING NEW**'
+ANG PRICE: DETAILS ON REQUEST
+NOVEL DENIM HOLDINGS LTD
+UNSOLICITED
+AVG PRICE: DETAILS ON REQUEST
+TOTAL
+DEPOSITS AND WITHDRAWALS
+DATE
+08/02/02
+TOTAL
+TRANSACTION
+DEPOSIT
+DESCRIPTION
+ALYSSEE FIN OO INTL CHARI
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+TRANSACTION
+07/27/02
+08/08/02 BOUGHT
+DESCRIPTION
+OPENINGBALANCE
+PRETTINA SHAGEMENT CLA
+SYMBOLCUSIP
+NVLD
+"CACH
+NVLD
+QUANTITY
+-800
+3,000
+*700
+- 1,600
+PRICE
+6.10000
+12.20000
+13.11000"
+5.90950
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+DEBIT AMOUNT
+4,829.35
+36,416.39
+9,132.22
+9,356.41
+$385,566.14
+DEBIT AMOLNT
+SYMBOU/CUSIP
+DICXX
+13,032.60
+$13,032.60
+QUANTITY
+0.00
+9,000,000
+027
+PRICE
+1.0000
+DEBIT AMOUNT
+9,000,000.00
+
+
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+8 of 9
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MODAY
+08/30/02
+TOTAL
+TRANSACTKN
+DESCRIPTION
+CLOSINGBALANCE
+INTEREST
+DATE
+DESCRIPTION
+08/21/02
+INTEREST ON CREDIT BALANCE
+AT 1 1/4% 07/21 THRU 08/20
+TOTAL
+MISCELLANEOUS
+SYMBOUCUSIP
+DATE
+MO/DAN
+07/31/02
+08/02/02
+TOTAL
+TRANSACTION
+DESCRIPTION
+FROM: SuZ
+FROM: SuZ
+• JAL
+-1-USD
+2-USD
+SYMBOUCUSIP
+QUANTITY
+9,000,000
+PRICE
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+DEBIT AMOUNT
+$-9,000,000.00
+QUANTITY
+RATE (%)
+1.2500
+DEBIT AMOUNT
+2,014.15
+$2.014.15
+DEBIT AMOUNT
+480,339.48
+8,322,286.37
+$8,802,625.85
+027
+
+
+9 or g
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Trades Executed Pending Settlement
+SETLEMENT TREE
+TRANSACTION
+DESCRIPTION
+09104/02 08/29/02
+SOLD
+CACHE ING NEW
+VG PRICE SHOWN-DETAILS ON REC
+CTUAL CONFIRM TO YOUR AGEN
+AVG PRICE: DETAILS ON REQUEST
+09/04/02
+* 08/29/02 SOLD
+09/05/02
+08/30/02
+UNSOLICITED
+SOLD
+ACHE ING NEW
+VG PRICE SHOWN-DETAILS ON RE
+CTUAL CONFIRM TO YOUR AGEN
+UNSOLICITED
+AVG PRICE: DETAILS ON REQUEST
+09/05/02
+08/30/02
+SOLD
+"iI APPAREL GROUP LTD
+UNSOLICITED
+09/05/02
+08/30/02
+SOLD
+NOVEL DENIM HOLDINGS LTD
+AVG PRICE SHOWN-DETAILS ON REQ
+ACTUAL CONFIRM TO YOUR AGENT
+UNSOLICITED
+AVG PRICE: DETAILS ON REQUEST
+09/05/02
+.. . ..
+08/30/02
+SOLD
+INITED RETAIL GROUP IN
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+UNSOLICITED
+AVG PRICE: DETAILS ON REQUEST
+TOTAL
+The above trades do not appear in any other section of this statement.
+SYMBOLGUSIP
+CACH
+CACH
+GIII
+NVLD
+URGI
+027
+QUANTITY
+-1,100.00
+-200.00
+1,000.00
+- 100.00
+2,200.00
+PRICE
+10.6500
+• 6.8000
+11
+6.7500
+5.1900
+-1,500.00
+5
+LEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+DEBIT AMOUNT
+11,646.14
+327.4
+
+642.47
+11, 283.15
+7,40727
+$0.00
+$43,243.64
+VB66
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+..................
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28,2002
+4
+4
+Hollandlold
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+82,178
+$82,178
+77,589
+4,589
+There are no "Stop Loss' orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+$82,178
+# $77,589
+Current market value
+Last statement's market value
+Please report any diference or non-receipt of chacks or stocks, indicated as delivered to you
+o Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3669.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Funds Deposited
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+577.589.16
+4,508.09
+80.82
+$4,588.91
+4,588.91
+$82,178.07
+Income Summary
+THIS PERIOD
+Credit Balance Int.
+80.82
+Total
+$80.82
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+77,589.16
+$77,589.16
+CLOSING
+82,178.07
+$82,178.07
+027
+YEAR TO DATE
+564.64
+.........
+.5564.64
+82,178
+582,178
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+SIMBOUCUSIP
+QUANTITY
+PRICE
+MARKE
+VALU
+82,178
+$82,178
+ESTIMATED
+ANUAL INCON
+CURREN
+(ELD (:
+YOUR PRICEDPORTFOLIOHOLDINGS
+$82,178
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+07/25/02
+TOTAL
+TRANSACTION
+DEPOSIT
+DESCRIPTION
+INTEREST
+DATE
+DESCRIPTION
+07/22/02
+INTEREST ON CREDIT BALANCE
+AT 1 1/4% 06/21 THRU 07/20
+TOTAL
+DEBIT AMOUNT
+4,508.09
+$4.508.09
+SYMBOUCUSIP
+QUANTITY
+RATE (St
+1.2500
+DEBIT AMOUNT
+80.82
+$80.82
+027
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary .....
+Your Portfolio Holdings
+Transaction Detail
+........
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+3
+4
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+77,589
+$77,589
+77,506
+83
+There are no "Stop Loss' orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+$77,589
+37:560
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800 634-1428; or Write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+06/29/02;10:49 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+06/29/02;10:49001
+
+
+3 or a
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+Cash Balance Summary
+Cash
+Net Cash Balance
+OFENING
+77,505.73
+$77,505.73
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERIOD
+377.505.73
+83.43
+$83.43
+83.43
+$77,589-16
+Income Summary
+THIS PERIOD
+Credit Balance Int.
+Total
+83.43
+$83.43
+Portfolio Composition
+Cash/Cash Equivalent
+Total.
+YEAR TO DATE
+483.82
+--...
+$483.82
+77,589
+577.589
+CLOSING
+77,589.16
+577,589.16
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOL/CUSIP
+QUANTITY
+PRICE
+MARKET
+VALUE
+77,589
+$77,589
+MANUAL MONE
+027
+06/29/02;10:49 001
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+Your Portfolio Holdings (continued)
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+INTEREST
+DATE
+DESCRIPTION
+06/21/02 INTEREST ON CREDIT BALANCE
+AT 1 1/4% 05/21 THRU 06/20
+TOTAL
+SYMBOLICUSIP
+STOP
+****** End of Statement******
+QUANTITY
+$77,589
+RATE (%)
+1.2500
+027
+DEBIT AMOUNT
+06/29/02;10:49 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+CAEDIT AMOUNT
+83.43
+$83.43
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+....
+Transaction Detail
+CLEARED THROUGH ITE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26, 2002
+3
+3
+4
+Hollandlold
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+77,506
+$77,506
+77,425
+81
+There are no "Stop Loss' orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+$77,506
+# $77,425
+Current market value
+Last statement's market value
+Flease report any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or Writa to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+06/01/02;15:46 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+06/01/02;15:46 001
+
+
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+77,425.08
+$77,425.08
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+577.125.08
+80.65
+$80.65
+80.65
+577.605.73
+Income Summary
+THIS PERIOD
+Credit Balance Int.
+80.65
+Total
+$80.65
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+YEAR TO DATE
+400.39
+.5400.39
+77,506
+$77,506
+......
+CLOSING
+77,505.73
+....
+77,505.7
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBCLCUSIP
+QUANTITY
+PRICE
+MARKET
+VALUE
+77.506
+$77,506
+МАИН NCOE
+CURREN
+027
+06/01/02;15:46 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+Your Portfolio Holdings (continued)
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+INTEREST
+DATE
+DESCRIPTION
+05/21/02 INTEREST ON CREDIT BALANCE
+AT 1 1/4% 04/21 THRU 05/20
+TOTAL
+SYMBOLICUSIP
+STOP
+****** End of Statement******
+QUANTITY
+$77,505
+RATE (%)
+1.2500
+027
+DEBIT AMOUNT
+06/01/02;15:46 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26,2002
+CAEDIT AMOUNT
+80.65
+$80.65
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+....
+Transaction Detail
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28, 2002
+3
+3
+4
+Hollandlold
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+77,425
+$77,425
+77,342
+83
+There are no "Stop Loss' orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+$77,425
+- 577322
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800 634-1428; or writa to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+04/27/02;12:01 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+04/27/02;12:01001
+
+
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance.
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICD
+$77,341.83
+....
+83.25
+$83.25
+83.25
+577.-425.08
+Income Summary
+THIS PERIOD
+Credit Balance Int.
+83.25
+Total
+583.25
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+Cash Balance Summary
+Cash
+OPENING
+77,341.83
+Net Cash Balance
+$77,341.83
+CLOSING
+77,425.08
+$77,425.08
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+QUANTITY
+PRICE
+MARKET
+VALUE
+77.425
+$77,425
+027
+YEAR TO DATE
+319.74
+..........
+$319.74
+77,425
+$77,425
+04/27/02;12:01 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+Your Portfolio Holdings (continued)
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+INTEREST
+DATE
+DESCRIPTION
+04/22/02 INTEREST ON CREDIT BALANCE
+AT 1 1/4% 03/21 THRU 04/20
+TOTAL
+SYMBOLICUSIP
+STOP
+****** End of Statement******
+QUANTITY
+$77,425
+RATE (%)
+1.2500
+027
+DEBIT AMOUNT
+04/27/02;12:01 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28, 2002
+CAEDIT AMOUNT
+83.25
+$83.25
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+Your Messages
+.........
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+3
+Hollandlold
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+77,342
+$77,342
+77,267
+75
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+$77,342
+$77,267
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800 6341428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four or ratanal purposes red de Set revere date for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 ofs
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance.
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+77,266.71
+$77,266.71
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+577.266.71
+75.12
+:75.12
+75.12
+677.341.83
+Income Summary
+THIS PERIOD
+Credit Balance Int.
+75.12
+Total
+$75.12
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+YEAR TO DATE
+236.49
+--...
+.$236.49
+77,342
+$77,342
+........
+CLOSING
+77,341.83
+.......
+$77,341.83
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+QUANTITY
+PRICE
+MARKET
+VALUE
+77.342
+$77,342
+МАИН NONE
+CURREN
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+4 of 5
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+INTEREST
+DATE
+DESCRIPTION
+03/21/02 INTEREST ONCREDIT BALANCI
+T 1 1/4% 02/21 THRU 03/20
+TOTAL
+SYMBOLICUSIP
+QUANTITY
+$77,341
+RATE (%)
+1.2500
+027
+DEBIT AMOUNT
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+75.12
+$75.12
+
+
+5 or 5
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+Your messages
+138
+Pursuant to SEC Rule 11Ac1-6, Bear, Stearns & Co, Inc will
+publicly post its quarterly routing statistics at the following web link
+ttp://www.bearstearns.com/corporate/business/equities/orp.htr
+STOP
+****** End of Statement******
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22,2002
+Bear, Stearns Securities Corp, Net Capital and Net Capital
+Requirements:
+At November 30, 2001 and January 31, 2002, the Company's net
+capital of approximately $2,6 billion and $2,6 billion was
+approximately 9% and 8% of aggregate debit items and exceeded
+the minimum regulatory net capital requirement of approximately
+$604.1 million and $648,0 million by approximately $2.0 billion and
+$2.0 billion, all respectively.
+A complete copy of the Bear, Stearns Securities Corp. Statement
+of Financial Condition is available on the web site
+www.bearstearns.com,
+Alternatively, to request a free printed copy
+please call -toll free 1-866-299-9331,
+027
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+..................
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 25,2002
+4
+4
+Hollandlold
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+77,267
+$77,267
+74,300
+2,967
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+$77,267
+$74,300
+Current market value
+Last statement's market value
+Flease report any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800 634-1428; or Writa to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Funds Deposited
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+$74,300.13
+... ..
+2,885.10
+81.48
+$2,966.58
+2,966.58
+577.266.71
+Income Summary
+THIS PERIOD
+Credit Balance Int.
+81.48
+Total
+$81.48
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+74,300.13
+$74,300.13
+CLOSING
+77,266.71
+$77,266.71
+027
+YEAR TO DATE
+161.37
+..........
+.$161.37
+77,267
+$77.267
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 25,2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SIMBOUCUSIP
+QUANTITY
+PRICE
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+02/06/02
+TRANSACTION
+DEPOSIT
+DESCRIPTION
+INDIE'S INC OO INTERNATIOI
+LARITABLE INTERESTS
+STERLING NAT BK
+TOTAL
+INTEREST
+DATE
+02/21/02
+TOTAL
+DESCRIPTION
+INTEREST ONCREDIT BALANCE
+AT 1 1/4% 01/21 THRU 02/20
+SYMBOUCUSIP
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 25, 2002
+MARKET
+VALUE
+77,267
+$77,267
+MALINATED GRI
+(ELD (:
+$77,266
+DEBIT AMOUNT
+2,885.10
+$2,885.10
+QUANTITY
+RATE (%)
+1.2500
+DEBIT AMOUNT
+81.48
+$81.48
+027
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .•••••••••••••••••••I/I/
+Your Portfolio Holdings
+Transaction Detail
+Your Messages
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+3
+4
+4
+Hollandlold
+INTERNATIONAL CHARITABLE
+INTERESTS II DTD 08/30/94
+FINCL TR CO INC TTEE
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+74,300
+$74,300
+74,220
+80
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+$74,300
+| $74,220
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four ratanal purger red de Set revere date for portant iformation.
+01/26/02;08:54 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+01/26/02;08:54 001
+
+
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance.
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+74,220.24
+$74,220.24
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+5574.220.24
+79.89
+$79.89
+79.89
+574,300.13
+Income Summary
+THIS PERIOD
+Credit Balance Int.
+79.89
+Total
+$79.89
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+YEAR TO DATE
+79.89
+_ 579.89
+74,300
+$74,300
+CLOSING
+74,300.13
+....
+554.300.137
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+QUANTITY
+PRICE
+MARKET
+VALUE
+74,300
+$74,300
+ESTIMATE
+NNUAL INCOM
+CURREN
+027
+01/26/02;08:54 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+INTEREST
+DATE
+DESCRIPTION
+01/22/02
+INTEREST ONCREDIT BALANCE
+AT 1 1/4% 12/21 THRU 12/30
+Ö1122/02 INTEREST ONCREDIT BALANCE
+AT 1 1/4% 12/31 THRU 01/20
+TOTAL
+SYMBOLICUSIP
+Your messages
+computed from December to 1, uralount during January 200
+QUANTITY
+$74,300
+RATE (%)
+1.2500
+1.2500
+027
+DEBIT AMOUNT
+01/26/02;08:54 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INTERNATIONAL CHARITABLE
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+25.77
+54.12
+$79.89
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/d63eb53e2fcbef4909defac0a2ba11cdc2400ca776e154e6bde78a177b5b9a8c.receipt.json b/vision-fixhub/ds9-unparsed-05/d63eb53e2fcbef4909defac0a2ba11cdc2400ca776e154e6bde78a177b5b9a8c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9f01134201747bd896faca51f63a68f0f6d16c43
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d63eb53e2fcbef4909defac0a2ba11cdc2400ca776e154e6bde78a177b5b9a8c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -6507,
+  "dataset": "marble-joined",
+  "doc_id": "d63eb53e2fcbef4909defac0a2ba11cdc2400ca776e154e6bde78a177b5b9a8c",
+  "engine": "marble-apple-vision",
+  "event_count": 74,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "ae0dd89b9aa79578f04ea5bb92cde9f6bd8dd0d003a52e8f0b2a3fc9695a6a74",
+  "output_sha256": "1adbd79f35abf46ba1631dca371403528610c49508979af7a1c647477e5f4035",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/d746186c2cafd7d567162c4cfeb0fa7530388dc6453b2e61ff7ae4e14fc9b1be.md b/vision-fixhub/ds9-unparsed-05/d746186c2cafd7d567162c4cfeb0fa7530388dc6453b2e61ff7ae4e14fc9b1be.md
new file mode 100644
index 0000000000000000000000000000000000000000..ca1b264c150e67a2cd80619095ae36f5180198cb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d746186c2cafd7d567162c4cfeb0fa7530388dc6453b2e61ff7ae4e14fc9b1be.md
@@ -0,0 +1,2241 @@
+Statements
+
+
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+INVESTMENT PROFESSIONAL
+ZICHERMAN,IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .........
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ......•...///I//•/////II//I//II///
+Your Messages
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 30, 2007
+THROUGH
+July 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2007
+3
+5
+6
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+349,500
+271,118
+$620,618
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+This portfolio indudes one or more unpriced secures that are no
+fected in the Total Value of Securtes and the Net Equity This Perio
+634,873
+-14.255
+Market Value of Your Portfolio
+$271,118
+$269,973
+Cash & Equivalent
+Equities
+S4500
+$364.900
+BOSSES
+.....
+Current market value
+Last statement's market value
+The are rep one fores or a her pending buy
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivered to you,
+to Client Services at 800-634-1428; Or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+027
+SPC This statement shouid be retaine for yous rodrs. See renerse sde for try portant info.
+See reverse side for important information.
+08/01/07.07:19 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+08/01/07 07:19 001|
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+1,144.87
+$1,144.87
+-1,144.87
+5-1.144.87
+$0.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+1,144.87
+51.144.87
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+08/01/07 07:19 001|
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 30, 2007
+THROUGH
+July 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2007
+YEAR TO DATE
+8,807.60
+....
+$8,807.60
+271,118
+349,500
+$620,618
+Your Portfolio
+Allocation
+Cash &Equivalent
+44%
+Equities
+56%
+Unshaded portions denole debi balance and'or short
+markot values.
+The alocation percentago is derived
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 30, 2007
+THROUGH
+July 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2007
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST, 30 DAY AVG YIELD 5,2100%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+QUANTITY
+271,117.87
+FRICE
+1.0000
+MARKET
+VALUE
+271,118
+$271,118
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department. The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform, The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers use different ratings systems and have normalized them as follows: B = Buy; H = Hold; S = Sell (this may not always
+DESCRIPTION
+ABERCROMBIE & FITCH CO-CLA
+BSC RATING: STOCK O/SECTOR MW
+BUCKINGHAM RESEARCH RATING: B
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBCUCUSIP
+ANF
+BPIBY
+CASH
+CASH
+QUANTITY
+5,000
+20,000
+PRICE
+69.9000
+Unpriced
+349,500
+3,500
+ESTIMATE
+ELD (S
+1.0014
+$349,500
+$349,500
+$3,500
+$3,500
+027
+08/01/07.07:19 001
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+MONEY FUND ACTIVITY
+06/30/07
+07/02/07
+07/02/07
+TRANSACTION
+DIVIDEND
+REINVEST
+07/31/07
+TOTAL
+DESCRIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT-CLA
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+DIVIDEND REINVEST
+CLOSINGBALANCE
+SYMBOL/CUSIP
+DICXX
+DICXX
+027
+$3,500
+$620,618
+QUANTITY
+269,973
+1,144.87
+271,117.87
+08/01/07:07:19 001
+PRICE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 30, 2007
+THROUGH
+July 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2007
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,144.87
+1,144.87
+$-1,144.87
+$1,144.87
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your messages
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 30, 2007
+THROUGH
+July 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2007
+You are advised to promptly report any inaccuracy or discrepancy in your
+STOP
+****** End of Statement******
+027
+08/01/07 07:19 001
+
+
+Bear, Stears & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+INVESTMENT PROFESSIONAL
+ZICHERMAN,IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .........
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .....•••I//////•///////////III//III//
+Your Messages
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 1,2007
+THROUGH
+June 29, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2007
+3
+5
+6
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+364,900
+269,973
+$634,873
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+681,173
+-46.300
+This portfolio indudes one or more unpriced securties that are no
+ected in the Total Value of Secures and the Net Equity This Perior
+Market Value of Your Portfolio
+$269,973
+$267,923
+Cash & Equivalent
+Equities
+$364,900
+$413.250
+BOSSES
+.....
+Current market value
+Last statement's market value
+here are no "Stop Loss" orders or other pending bu
+r sell open orders on file for your accoun
+Flease report any disrence or non-receipt of chacks or stocks, indicated as dalivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+027
+SPC This statement shouid be retainel por out records. See reverse side for important intormation.
+06/30/07:07:43 001
+
+
+2 of 7
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+06/30/07 07:43 001|
+
+
+3 or 7
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+1,175.49
+875.00
+$2,050.49
+-2,050.49
+$ 2,050.49
+.......
+50.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+2,050.49
+$2.050.49
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+06/30/07 07:43 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 1,2007
+THROUGH
+June 29, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31,2007
+YEAR TO DATE
+7,662.73
+57,662.73
+269,973
+364,900
+$634,873
+Your Portfolio
+Allocation
+Cash &Equivalent
+43%
+Equities
+57%
+Unshaded portions denole debi balance and'or short
+from the absolute market value of your portfolio.
+
+
+4 of 7
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 1,2007
+THROUGH
+June 29, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2007
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST, 30 DAY AVG YIELD 5,2200%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBCUCUSIP
+DICXX
+QUANTITY
+269,973
+FRICE
+1.0000
+MARKET
+VALUE
+269,973
+$269,973
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department. The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform, The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers use different ratings systems and have normalized them as follows: B = Buy; H = Hold; S = Sell (this may not always
+DESCRIPTION
+ABERCROMBIE & FITCH CO-CLA
+BSC RATING: STOCK O/SECTOR MW
+BUCKINGHAM RESEARCH RATING: B
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBCUCUSIP
+ANF
+BPIBY
+CASH
+QUANTITY
+5,000
+PRICE
+72.9800
+MARKET
+VALUE
+364,900
+3,500
+ESTIMATED
+YIELD I%
+0.9592
+CASH
+20,000
+Unpriced
+$364,900
+$364,900
+$3,500
+$3,500
+027
+06/30/07:07:43 001
+VD11
+
+
+5 or7
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+06/01/07
+6/01/0
+06/01/07
+06/26/07
+06/29/07
+TOTAL
+TRANSACTON
+"DIVIDEND
+REINVEST
+BOUGHT
+DESCRIPTION
+OPENINGBALANCE
+SYMBOL/CUSIP
+DREYFUS CASH MANAGEMENT. CLA
+NSTITUTIONAL SHARE:
+DIVIDEND REINVES
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTICNAL SHARES
+CLOSINGBALANCE
+DICXX
+DICXX
+027
+$3,500
+$634,873
+QUANTITY
+267,922.51
+PRICE
+1,175.49
+875
+269,973
+1.0000
+06/30/07:07:43 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 1,2007
+THROUGH
+June 29, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2007
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,175.49
+1,175.49
+875.00
+$-2,050.49
+$1,175.49
+VO11
+
+
+6 of 7
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+DIVIDENDS
+
+DESCRIPTION
+ABERCROMBIE & FITCH CO-CLA
+REC 06/05/07 PAY 06/26/07
+TOTAL
+SYMBOUCUSIP
+ANF
+QUANTITY
+5,000
+RATE (S)
+0.1750
+DEBIT AMOUNT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 1,2007
+THROUGH
+June 29, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2007
+CREDIT AMOUNT
+875.00
+$875.00
+Your messages
+Confirmation: Unless we hear from you to the contrary, it is our understanding
+that any free credit balances in your account are being maintained to facilitate
+your intention to invest such amounts through us,
+LEPT SPECIAL NOTICE FOR MARGIN CUSTOMERS
+If you are a customer with a margin account, you consent to Bear Steams's
+right to use, lend or pledge any securities held by Bear Stearns in your margin
+account, In certain circumstances, such loans or other use may limit, in whole
+or in part, your ability to receive dividends directly from the issuing company
+and/or your right to exercise voting and other attendant rights of ownership
+dates for dividend distributions. If you do not receive dividends directly from
+the issuing company, you may receive payments-in-lieu of dividends which
+could cause you to lose the benefit of the preferential tax treatment accorded
+to dividends.
+027
+06/30/07-07:43 001
+VD11
+
+
+7 of 7
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+You are advised to promptly report any inaccuracy or discrepancy in your
+account to your broker and Bear, Stearns Securities Corp. ('BSS") at the
+(SIPA"), any such communications should be reconfirmed in writing to your
+broker and BSSC at the addresses which appear on the front of this
+STOP
+****** End of Statement******
+027
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD
+June 1, 2007
+THROUGH
+June 29, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+May 31, 2007
+In an effort to maximize execution quality, Bear Stearns may route your equity
+orders to its Smart Order Router (SOR). The SOR accepts limit and market
+orders and automates their routing across several sources of liquidity in an
+attempt to maximize price and minimize market impact with respect to your
+order, The SOR routes orders using proprietary algorithms that scan
+exchanges, ECN's and other liquidity venues before it decides a strategy
+designed to achieve an optimal execution for clients. The SOR may in the
+course of executing an instruction change the entered order type from market
+to limit or may change the entered limit price in an attempt to obtain the best
+price, Although the Firm believes that the regular use of this technology
+benefits clients by achieving overall better execution quality, we cannot
+guarantee an optimal execution on any individual order.
+06/30/07-07:43 001
+
+
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+INVESTMENT PROFESSIONAL
+ZICHERMAN,IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .........
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .....••I//////•////////////II//III//.
+Your Messages
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD May 1, 2007
+THROUGH
+May 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 30, 2007
+3
+5
+6
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARKL
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+413,250
+267,923
+$681,173
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+his portfolio indudes one or more unpriced securties that are m
+lected in the Total Value of Secures and the Net Equity This Perio
+675,093
+6,080
+Market Value of Your Portfolio
+$267,923
+$266,793
+Cash & Equivalent
+Equities
+$413.250
+$408,300
+BOSSES
+.....
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+027
+SPC This statement shouid be retainel por out records. See reverse side for important intormation.
+06/01/07:05:44 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+06/01/07 05:44 001|
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+1,129.27
+$1,129.27
+-1,129.27
+$-1,129.27
+$0.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+1,129.27
+$1,129.27
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+06/01/07 05:44 001|
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD May 1, 2007
+THROUGH
+May 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 30,2007
+YEAR TO DATE
+5,612.24
+5.612.24
+267,923
+413,250
+$681,173
+Your Portfolio
+Allocation
+Cash &Equivalent
+40%
+-Equities
+60%
+Unshaded portions denole debi balance and'or short
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD May 1, 2007
+THROUGH
+May 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 30, 2007
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST, 30 DAY AVG YIELD 5,1900%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBCUCUSIP
+DICXX
+QUANTITY
+267,922.51
+FRICE
+1.0000
+MARKET
+VALUE
+267,923
+$267,923
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department. The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform, The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers use different ratings systems and have normalized them as follows: B = Buy; H = Hold; S = Sell (this may not always
+DESCRIPTION
+ABERCROMBIE & FITCH CO-CLA
+BSC RATING: STOCK O/SECTOR MW
+BUCKINGHAM RESEARCH RATING: B
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBCUCUSIP
+ANF
+BPIBY
+CASH
+CASH
+QUANTITY
+5,000
+20,000
+PRICE
+82.6500
+Unpriced
+413,250
+3,500
+ESTIMATED
+YIELD I%
+0.8469
+$413,250
+$413,250
+$3,500
+$3,500
+027
+06/01/07.05:44 001
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+MONEY FUND ACTIVITY
+05/01/07
+05101/07
+05/01/07
+TRANSACTION
+DIVIDEND
+REINVEST
+DESCRIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT-CLA
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+DIVIDEND REINVEST
+CLOSINGBALANCE
+SYMBOL/CUSIP
+DICXX
+DICXX
+05/31/07
+TOTAL
+027
+$3,500
+$681,173
+QUANTITY
+266,793.24
+1,129.27
+267,922.51
+06/01/0705:44 001
+PRICE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD May 1, 2007
+THROUGH
+May 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 30, 2007
+DEBIT AMOUNT
+CREDIT AMOUNT
+,129.2
+1,129.27
+$-1,129.27
+$1,129.27
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your messages
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD May 1, 2007
+THROUGH
+May 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 30, 2007
+You are advised to promptly report any inaccuracy or discrepancy in your
+STOP
+****** End of Statement******
+027
+06/01/07 05:44 001
+
+
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+INVESTMENT PROFESSIONAL
+ZICHERMAN,IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .........
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ......•...///I//•/////II//I//II///
+Your Messages
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 31, 2007
+THROUGH
+April 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30,2007
+3
+5
+6
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+408.300
+266,793
+S675,093
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+643,985
+31,108
+This portfolio indudes one or more unpriced securties that are no
+ected in the Total Value of Secures and the Net Equity This Perior
+Market Value of Your Portfolio
+$266,793
+$265,585
+Cash & Equivalent
+Equities
+$408.300
+$378,400
+BOSSES
+.....
+Current market value
+Last statement's market value
+The are rep one fores or a her pending buy
+Flease report any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; Or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+027
+SPC This statement shouid be retainel por out records. See reverse side for important intormation.
+05/01/07:07:14 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+05/01/07 07:14 001|
+4009
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+1,208.24
+$1,208.24
+-1,208.24
+$-1,208.24
+$0.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+1,208.24
+$1.208.24
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+05/01/07 07:14 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 31, 2007
+THROUGH
+April 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30,2007
+YEAR TO DATE
+4,482.97
+•........
+54,482.97
+266,793
+408,300
+••••••••••••••••••••••
+675,093
+Your Portfolio
+Allocation
+Cash &Equivalent
+40%
+-Equities
+60%
+Unshaded portions denole debi balance and'or short
+V00S
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 31, 2007
+THROUGH
+April 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30, 2007
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST, 30 DAY AVG YIELD 5,1600%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBCUCUSIP
+DICXX
+QUANTITY
+266,793.24
+FRICE
+1.0000
+MARKET
+VALUE
+266,793
+$266,793
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department. The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers use different ratings systems and have normalized them as follows: B = Buy; H = Hold; S = Sell (this may not always
+DESCRIPTION
+ABERCROMBIE & FITCH CO-CLA
+BSC RATING: STOCK O/SECTOR MW
+BUCKINGHAM RESEARCH RATING: B
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBCUCUSIP
+ANF
+BPIBY
+CASH
+CASH
+QUANTITY
+5,000
+20,000
+PRICE
+81.6600
+Unpriced
+MARKET
+VALLE
+408,300
+3,500
+ESTIMATED
+YIELD I%
+0.8572
+$408,300
+$408,300
+$3,500
+$3,500
+027
+05/01/07:07:14 001
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+MONEY FUND ACTIVITY
+03/31/07
+04/02/07
+04/02/07
+TRANSACTION
+DIVIDEND
+REINVEST
+DESCRIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT-CLA
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+DIVIDEND REINVEST
+CLOSINGBALANCE
+SYMBOL/CUSIP
+DICXX
+DICXX
+04/30/07
+TOTAL
+027
+$3,500
+$675,093
+QUANTITY
+265,585
+1,208.24
+266,793.24
+05/01/07:07:14 001
+PRICE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 31, 2007
+THROUGH
+April 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30, 2007
+DEBIT AMOUNT
+CREDIT AMOUNT
+1.208.24
+1,208.24
+$-1,208.24
+$1,208.24
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your messages
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 31, 2007
+THROUGH
+April 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30, 2007
+You are advised to promptly report any inaccuracy or discrepancy in your
+STOP
+****** End of Statement******
+027
+05/01/07 07:14 001
+
+
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+INVESTMENT PROFESSIONAL
+ZICHERMAN,IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .........
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ......•...///I//•/////I//I//II///
+Your Messages
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 1, 2007
+THROUGH
+March 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+February 28,2007
+3
+5
+7
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+MONEY MARKET FUND BALANCE
+378,400
+265,585
+NET EQUITY THIS PERIOD
+$643,985
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+This portfolio indudes one or more unpriced secures that are no
+fected in the Total Value of Securtes and the Net Equity This Perio
+679,418
+-35,433
+Market Value of Your Portfolio
+$265,585
+$288,568
+Cash & Equivalent
+BOSSES
+.....
+Equities
+$378,400
+$390.850
+Current market value
+Last statement's market value
+The are orts one fores or a her pending buy
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+027
+SPC This statement shouid be retainel por out records. See reverse side for important intormation.
+VOOB
+
+
+2 of 9
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+03/31/07 06:43 001|
+
+
+3 or 9
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Funds Withdrawn
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+26,141.88
+875.00
+$27,016.88
+-2,016.88
+-25,000.00
+1-227.01......
+$0.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+2,016.88
+$2.016.88
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+03/31/07 06:43 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 1,2007
+THROUGH
+March 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28,2007
+YEAR TO DATE
+3,274.73
+53,274.73
+265,585
+378,400
+$643.985.
+Your Portfolio
+Allocation
+Cash &Equivalent
+42%
+Equities
+58%
+Unshaded portions denole debi balance and'or short
+VOOB
+
+
+4 of g
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 1, 2007
+THROUGH
+March 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+February 28,2007
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST, 30 DAY AVG YIELD 5,1700%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBCUCUSIP
+DICXX
+265,585
+1.0000
+MARKET
+VALUE
+265,585
+$265,585
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department. The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform, The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers use different ratings systems and have normalized them as follows: B = Buy; H = Hold; S = Sell (this may not always
+DESCRIPTION
+ABERCROMBIE & FITCH CO-CLA
+BSC RATING: STOCK O/SECTOR MW
+BUCKINGHAM RESEARCH RATING: B
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBCUCUSIP
+ANF
+BPIBY
+CASH
+CASH
+QUANTITY
+5,000
+20,000
+PRICE
+75.6800
+Unpriced
+MARKET
+VALLE
+378,400
+3,500
+ESTIMATED
+YIELD I%
+0.9249
+$378,400
+$378,400
+$3,500
+$3,500
+027
+V0OB
+
+
+5 org
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+03/15/07
+TRANSACTION
+FND WIRED
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+03/01/07
+DESCRIPTION
+MDA
+WIRED TO
+EMBRAN CHASE BANK, NA
+EM004094
+DESCAIPTION
+OPENINGBALANCE
+0310107 DIDEND
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+MONTHLY DIVIDEND
+....
+DEBIT AMOLNT
+25,000.00
+$-25,000.00
+SYMBOLCUSIP
+DiCX
+027
+$3,500
+$643,985
+CREDIT AMOUNT
+QUANTITY
+288,568.12
+PRICE
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 1, 2007
+THROUGH
+March 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+February 28,2007
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,141.88
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of g
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MODAY
+03/01/07
+TRANSACTION
+REINVEST
+03/15/07
+SOLD
+03/27/07
+BOUGHT
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CL A
+NSTITUTIONAL SHARES
+DIVIDEND
+REINVEST
+03/30/07
+TOTAL
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+DESCRIPTION
+03/27107
+ABERCROMBIE & FITCH CO-CLA
+TOTAL
+REC 03/06/07 PAY 03/27/07
+SYMBOUCUSIP
+ANF
+SYMBOUCUSIP
+DICXX
+DICX
+DICXX
+QUANTITY
+5,000
+027
+QUANTITY
+1,141.88
+-25,000
+875
+265,585
+PRICE
+1.0000
+1.0000
+RATE (S)
+0.1750
+DEBIT AMOUNT
+03/31/07 06:43 001
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 1,2007
+THROUGH
+March 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 28,2007
+DEBIT AMOUNT
+1,141.88
+CREDIT AMOUNT
+25,000.00
+875.00
+$-2,016.88
+$26,141.88
+CREDIT AMOUNT
+875.00
+$875.00
+
+
+7 of g
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your messages
+Bear, Stearns Securities Corp. Net Capital and Net Capital Requirements:
+A complete copy of the Bear, Stearns Securities Corp, Statement of Financial
+Condition is available on the web site www.bearstearns.com, Alternatively, to
+request a free printed copy please call - toll free 1-866-299-9331,
+DeP You are advised to promptly report any inaccuracy or discrepancy in your
+account to your broker and Bear, Stearns Securities Corp, ('BSS") at the
+telephone numbers listed on the front of this statement, In order to protect
+broker and BSSC at the addresses which appear on the front of this
+statement,
+027
+18P
+lear, Steams Securities Corp
+ne Metrotech Center Nort
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 1, 2007
+THROUGH
+March 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+February 28, 2007
+SPECIAL NOTICE FOR MARGIN CUSTOMERS
+or in part, your ability to receive dividends directly from the issuing company
+nd/or your right to exercise voting and other attendant rights of ownershi
+ith respect to the loaned, sold or pledged securities. Such circumstance
+include, but are not limited to, loans of securities that you own in your margin
+account that continue over record dates for voting purposes and ex-dividend
+dates for dividend distributions. If you do not receive dividends directly from
+the issuing company, you may receive payments-in-lieu of dividends which
+could cause you to lose the benefit of the preferential tax treatment accorded
+to dividends.
+NOTICE OF CHANGE PURSUANT TO TRUTH-IN-LENDING SEC RULE 10b-16
+hort-term market interest rates quoted by money center banks and t
+deral Reserve and the rate that BSSC is charged for borrowing mone
+
+
+8 of g
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Effective no earlier than thirty (30) days from your receipt of this statement:
+1. The annual rate of interest charged to you on U.S. dollar-denominated
+redit will not exceed the specified percentage over the applicable rate, a
+ndicated in the following chart
+Debit Size Range
+Up to $499,999
+$500,000 - $999,999
+$1,000,000 - $2,499,999
+$2,500,000 - $4,999,999
+5,000,000 - $9,999,99:
+$10,000,000 and abov
+Index
+Margin Basis
+Margin Basis
+Margin Basis
+LIBOR
+LIBOR
+LIBOR
+Spread to Index
++ 3,000%
++ 2,000%
++ 1,500%
++ 3.000%
++ 2,250%
++ 1,750%
+Debits in currencies other than U,S, dollars will not be taken into account in
+computing the debit size for purposes of determining the applicable interest
+rate. The rate corresponding to the debit size range in which your U.S. dolla
+lenominated debit falls will apply to the entire amount of your U.S. dolla
+lenominated debit. The actual rate charged to you at any given time will b
+notified to you on request, and the amount charged to you will appear on your
+monthly statements.
+027
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD
+March 1, 2007
+THROUGH
+March 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+February 28,2007
+2. Interest may be charged to your account at varying rates during the month
+to reflect any changes in such interest rates that have occurred during the
+month surel as ayahanges in the applicable rate caused by a change in the
+3. The rate of interest charged to you on any credit extended to you in a
+currency other than U.S. dollars shall continue to be based on either (i) a
+LIBOR, as such rate is compiled by the British Bankers Association and
+published on Bloomberg or Reuters, or (ii) any other rate quoted by Reuters
+that is applicable to the currency in which the obligation is denominated or, if a
+rate for such currency is not quoted by Reuters, the rate provided by Bear
+Stearns Securities' local bank, In either case, the annual rate of interest on
+such non-U,S, dollar denominated debit will continue to not exceed 5% above
+either a LIBOR, any rate quoted by Reuters or the rate provided by Bear
+Stearns Securities' local bank, and will appear on your monthly statements,
+The actual rate charged to you at any given time will be notified to you on
+request and the amount charged to you will appear on your monthly
+4, Unless otherwise agreed, the BSSC Fed Funds Rate will no longer be an
+available option for computing interest.
+03/31/07:06:43 001
+V00B
+
+
+9 of 9
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 1, 2007
+THROUGH
+March 30, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+February 28,2007
+If BSSC makes changes in any of the credit terms and conditions described
+herein or if a change is required by law, we will notify you of such change within
+• reasonable period of time, unless such change results in the same or
+ligher rate to you, in which case we will provide you at least 30 days' pric
+written notice, The annual rate of interest you are charged may fluctuate with
+changes in the BSSC Margin Basis Rate, a LIBOR, any of the rates quoted by
+Reuters or the rate provided by BSSC's local bank, The changes in rates
+resulting from this fluctuation will be made without prior notice to you (as
+contrasted with changes in the credit terms and conditions, notice of which will
+be provided as described above).
+The Truth-in-Lending disclosure previously provided to you shall continue to
+apply except as specifically noted above.
+STOP
+****** End of Statement******
+027
+03/31/07-06:43 001
+WOOR
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+INVESTMENT PROFESSIONAL
+ZICHERMAN.IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .......
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity
+....
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD February 1, 2007
+THROUGH
+February 28, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31, 2007
+3
+4
+5
+5
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+390.850
+MONEY MARKET FUND BALANCE
+288.568
+NET EQUITY THIS PERIOD
+$679,418
+......
+........
+NET EQUITY LAST STATEMENT
+685,010
+CHANGE SINCE LAST STATEMENT
+-5.592
+This portfolio indudes one or more unpriced securties that are no
+elected in the Total Value of Securtes and the Net Equity This Perio
+Market Value of Your Portfolio
+$288,568
+$287,310
+Cash & Equivalent
+Equities
+$390,850
+$397,700
+Current market value
+Last statement's market value
+ere are no "Stop Loss" orders or other pending b
+sell open orders on file for your accoun
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivered to you,
+to Client Services at 800-634-1428; Or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+027
+SP The suremen is four or ratanal purger red de Set revere date for portant iformation.
+03/01/07:05:17 001
+V0O6
+
+
+2 of 5
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+03/01/07 05:17 001
+
+
+3 ofs
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERIOD
+50.00
+1,257.85
+$1,257.85
+-1,257.85
+$-1,257.85
+$0.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+1,257.85
+$1.257.85
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+03/01/07 05:17 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD February 1, 2007
+THROUGH
+February 28, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31, 2007
+YEAR TO DATE
+1,257.85
+$1.257.85....
+288,568
+390,850
+......
+$679,418
+.....
+Your Portfolio
+Allocation
+Cash & Equivalent
+43%
+Equities
+57%
+Unshaded portions denole debit balance andor short
+from the absolute market value of your portfolio.
+
+
+4 of 5
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD February 1, 2007
+THROUGH
+February 28, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31, 2007
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST. 30 DAY AVG YIELD 5.1700%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+QUANTITY
+288,568.12
+PRICE
+1.0000
+MARKET
+VALUE
+288,568
+$288,568
+ESTIMATED ESTIMATED
+ANNUAL INCOME
+YELD IS
+15,294 5.3000
+$15,294
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department. The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers use different ratings systems and have normalized them as follows: B = Buy; H = Hold; S = Sell (this may not always
+DESCRIPTION
+ABERCROMBIE & FITCH CO-CLA
+BSC RATING: STOCK O/SECTOR W
+BUCKINGHAM RESEARCH RATING: B
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOUCUSIP
+ANF
+BPIBY
+CASH
+QUANTITY
+5,000
+PRICE
+78.1700
+MARKET
+VALLE
+390,850
+3,500
+ESTIMATED
+YIELD (%)
+0.8955
+CASH
+20,000
+Unpriced
+$390,850
+$390,850
+$3,500
+$3,500
+027
+03/01/07:05:17 001
+
+
+5 ors
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+MONEY FUND ACTIVITY
+02/01/07
+02/01/07
+02/01/07
+TRANSACTION
+DIVIDEND
+REINVEST
+DESCAIPTION
+OPENINGBALANCE
+SYMBOL/CUSIP
+DICXX
+*DICXX
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+DIVIDEND REINVEST
+CLOSINGBALANCE
+02/28/07
+TOTAL
+027
+$18,794
+$679,418
+QUANTITY
+287,310.27
+1,257.85
+288,568.12
+03/01/07:05:17 001
+PRICE
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD February 1, 2007
+THROUGH
+February 28, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 31, 2007
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,257.85
+1,257.85
+$-1,257.85
+$1,257.85
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+INVESTMENT PROFESSIONAL
+ZICHERMAN.IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .......
+....•
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD December 30, 2006
+THROUGH
+January 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 29, 2006
+3
+4
+5
+5
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+397,700
+287,310
+$685,010
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+634,208
+50.802
+This portfolio indudes one or more unpriced securties that are no
+elected in the Total Value of Securtes and the Net Equity This Perio
+Cash & Equivalent
+Equities
+Market Value of Your Portfolio
+$287,310
+$286,058
+$397,700
+$348,150
+......
+...
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending bu
+or sell open orders on file for your account
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+027
+SP The suremen s four or ratanal purposes rear die Set revere date for portant iformation.
+02/01/07:06:16 001
+
+
+2 of 5
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+02/01/07 06:16 001
+
+
+3 ofs
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD December 30, 2006
+THROUGH
+January 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+December 29,2006
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERIOD
+50.00
+1,252.28
+$1,252.28
+-1,252.28
+
+$0.00
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+287,310
+397,700
+36800
+Your Portfolio
+Allocation
+Cash & Equivalent
+42%
+Equities
+58%
+Unshaded portions denole debi balance and'or short
+tram the absolute market value of your portfollo.
+027
+02/01/07 06:16 001
+
+
+4 of 5
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD December 30, 2006
+THROUGH
+January 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 29,2006
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST, 30 DAY AVG YIELD 5,1600%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+QUANTITY
+287,310.27
+FRICE
+1.0000
+MARKET
+VALUE
+287,310
+$287,310
+ESTIMATED ESTIMATED
+ANNUAL INCOME
+YELD IS
+15,227 5.2999
+$15,227
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department. The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers use different ratings systems and have normalized them as follows: B = Buy; H = Hold; S = Sell (this may not always
+DESCRIPTION
+ABERCROMBIE & FITCH CO-CLA
+BSC RATING: STOCK O/SECTOR W
+BUCKINGHAM RESEARCH RATING: B
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOUCUSIP
+ANF
+BPIBY
+CASH
+QUANTITY
+5,000
+PRICE
+79.5400
+MARKET
+VALLE
+397,700
+3,500
+ESTIMATED
+YIELD (%)
+0.8801
+CASH
+20,000
+Unpriced
+$397,700
+$397,700
+$3,500
+$3,500
+027
+02/01/07:06:16 001
+
+
+5 ors
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+MONEY FUND ACTIVITY
+TRANSACTION
+12/30/06
+01/02/07
+REINVEST
+01/02/07
+*"DIVIDEND
+DESCAIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT-CLA
+SYMBOL/CUSIP
+DICXX
+DICXX
+01/31/07
+TOTAL
+CLOSINGBALANCE
+027
+$18,727
+$685,010
+QUANTITY
+286,057.99
+,252.28
+287,310.27
+02/01/07:06:16 001
+PRICE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD December 30, 2006
+THROUGH
+January 31, 2007
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+December 29, 2006
+DEBIT AMOUNT
+252.28
+CREDIT AMOUNT
+,252.2
+$-1,252.28
+$1,252.28
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/d746186c2cafd7d567162c4cfeb0fa7530388dc6453b2e61ff7ae4e14fc9b1be.receipt.json b/vision-fixhub/ds9-unparsed-05/d746186c2cafd7d567162c4cfeb0fa7530388dc6453b2e61ff7ae4e14fc9b1be.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2c5a4bc1097bf481a0c5f17b287ffb562b7ae1d1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d746186c2cafd7d567162c4cfeb0fa7530388dc6453b2e61ff7ae4e14fc9b1be.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -3307,
+  "dataset": "marble-joined",
+  "doc_id": "d746186c2cafd7d567162c4cfeb0fa7530388dc6453b2e61ff7ae4e14fc9b1be",
+  "engine": "marble-apple-vision",
+  "event_count": 48,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "c4e657f175392ec6eadad121121020673b899f0e730529aa78e4b07274395b4b",
+  "output_sha256": "6cf06dca899baccba04f927713e0b0ab50c542d6d445b9895e99f43d4497c741",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/d75a05dc8a484b4fbea4194ba903d33ad72ffbddc970733ac2e83a0ccff8f4d2.md b/vision-fixhub/ds9-unparsed-05/d75a05dc8a484b4fbea4194ba903d33ad72ffbddc970733ac2e83a0ccff8f4d2.md
new file mode 100644
index 0000000000000000000000000000000000000000..b85b978acacee148facd3a768f399f83b55b1024
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d75a05dc8a484b4fbea4194ba903d33ad72ffbddc970733ac2e83a0ccff8f4d2.md
@@ -0,0 +1,9747 @@
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+114
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 270
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+Vs.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO: 08-CV-80119
+CASE NO: 08-CV-80232
+CONDENSED
+Vs.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+Vs.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+/
+CASE NO: 08-CV-80380
+CASE NO: 08-CV-80381
+Vs
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Page 271
+CASE NO: 0B-CV-B0994
+Plaintiff,
+3 Vs.
+Defendant.
+8
+9
+10
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+11
+12
+13
+Plaintiff,
+14
+15
+Vs.
+JEFFREY EPSTEIN,
+16
+Defendant.
+17
+JANE DOE,
+18
+Plaintift,
+Vs.
+20
+JEFFREY EPSTEIN,
+21
+Defendant.
+22
+23
+24
+25
+CASE NO: 08-CV-80993
+CASE NO: 08-CV-B0811
+CASE NO: 08-CV-80893
+CASE NO: 08-CV-80469
+Plaintiff,
+3
+Vs.
+4
+JEFFREY EPSTEIN,
+5
+Defendant.
+6
+JANE DOE NO. 101
+7
+Plaintift,
+8
+Vs.
+9
+JEFFREY EPSTEIN,
+10
+Defendant.
+12 JANE DOE NO. 102,
+13
+Plaintiff,
+14 Vs.
+15 JEFFREY EPSTEIN,
+16
+Defendant.
+17
+18
+19
+20
+21
+22
+23
+24
+25
+CASE NO: 08-CV-80591
+CASE NO: 08-CV-80656
+Page 272
+1
+4
+5
+Plaintiff,
+6
+7
+8
+Vs.
+JEFFREY EPSTEIN.
+Defendant.
+9
+10
+11
+12
+1031 Ives Dairy Road
+Suite 228
+13
+North Miami, Florida
+ugust 7, 200
+14
+:15 р.m. to 5:30 p.r
+15
+16
+CONTINUED
+17
+VIDEOTAPEC
+18
+DEPOSITION
+19
+of
+20
+ALFREDO RODRIGUEZ
+21
+22
+taken on behalf of the Plaintiffs pursuant
+23
+to a Re-Notice of Taking Continued Videotaped
+24
+25
+Deposition (Duces Tecum)
+¿ APPEARANCES:
+MERMELSTEIN & HOROWITZ, P.A.
+4
+5
+Miami, Florida 33160
+6,tone toney for Jane Doe 2, 3, 4,5,
+ROTHSTEIN ROSENFELDT ADLER
+BY: BRAD 1. EDWARDS, ESQ., and
+9
+10
+11
+15
+16
+01 East Las Olas Boulevar
+ort Lauderdale, Florida 3331
+Attorney for Jane Doe and
+And
+PODHURST ORSECK
+BY: KATHERINE W. EZELL, ESQ.
+25 West Flagler Street
+Suite 800
+Miami, Florida 33130
+Attorney for Jane Doe 101 and 102.
+19
+20
+LEOPOLD-KUVIN
+BY: ADAM J. LANGINO, ESQ.
+2925 PGA Boulevard
+Suite 200
+Raim nestor Sadies, Fonde 3410
+Page 273
+IN THE CIRCUIT COURT OF THE 15TH
+JUDICIAL CIRCUIT IN AND FOR
+PALM BEACH COUNTY, FLORIDA
+CASE NO. 502008CA037319X00XMB AB
+Page 274
+2 (Pages 271 to 274)
+
+
+3 PERNICE .
+RICHARD WILLITS, ESQ.
+2290 10th AVenue North
+Suite 404
+Lake Worth, Florida 33461
+5
+Attorney for
+Appeared via telephone.
+URMAN, CRITTON, LUTTIER I
+8
+COLEMAN, LL
+BY: ROBERT CRITTON, ESQ
+615 North Flagler Drive
+Suite 400
+10
+West Palm Beach, Florida 33401
+Attorney for Jeffrey Epstein.
+11
+12
+13 ALSO PRESENT:
+14
+JOE LANGSAM, VIDEOGRAPHER
+...
+17
+18
+19
+25
+3
+4
+5
+6
+7
+8
+CONTINUED INDEX OF EXAMINATION
+WITNESS
+DIRECT CROSS REDIRECT RECROSS
+ALFREDO RODRIGUEZ
+(By Ms. Ezell) 278
+(By Mr. Willits) 334
+441, 467
+453, 469
+(By Mr. Critton)
+338
+(By Mr. Edwards)
+(By Mr. Langino)
+464
+419, 454, 468
+452
+CONTINUED INDEX OF EXHIBITS
+PAGE
+315
+327
+331
+331
+331
+331
+21 Ezehills 4, 5, 6, 7, and 8 were retained by Ms.
+23
+24
+25
+Page 275
+1
+2
+3
+4
+5
+6
+7
+Page 277
+Deposition taken before MICHELLE PAYNE, Court
+Reporter and Notary Public in and for the State of
+Florida at Large, in the above cause.
+THE VIDEOGRAPHER: This is a continuation
+of the deposition of Alfredo Rodriguez.
+Today is Friday, August the 7th, the year
+9
+2009, starting time approximately 1:15 p.m.
+Will the court reporter please swear in
+10
+the witness?
+11
+Thereupon,
+12
+ALFREDO RODRIGUEZ,
+13
+having been first duly sworn or affirmed, was
+14
+examined and testified as follows:
+15
+16
+MR. CRITTON: Before we get started just
+with regard to Ms. Ezell represents Jane Doe
+17
+101 and 102, the alleged time of her
+18
+incidents as of least have been plead in the
+19
+complaint for 101 is '99 -- I'm sorry, '98
+20
+through 2002, with Jane Doe 102 the Spring
+21
+22
+of - Spring/Summer of 2003. Mr. Rodriguez
+never even began employment until '04 and
+23
+'05. I think her questioning I think -- I
+24
+can't say she doesn't have standing based on
+25
+the court order, but I would say it's
+Page 276
+Page 278
+completely irrelevant and immaterial and has
+• YOUDUN
+no probative value with regard to this
+particular witness based upon the two
+clients at least that are in suit at this
+point in time.
+MS. EZELL: As Mr. Critton well knows I
+represent a number of other clients whose
+cases have not been filed and I believe we
+10
+do have standing to ask questions, and I do
+intend to do that today.
+11
+EXAMINATION
+12 BY MS. EZELL:
+13
+Q. Mr. Rodriguez, you stated last time that
+there were guests at the house, frequent guests,
+15 friends from Harvard.
+16
+17
+Do you remember that testimony?
+A. Yes, ma'am.
+18
+Q. And was there a lawyer from Harvard named
+19 Alan Dershowitz?
+20
+21
+A. Yes, ma'am.
+Q. And are you familiar with the fact that
+22 he's a famous author and famous lawyer?
+23
+A. Yes, ma'am.
+24
+Q. How often during the six months or 50
+25 that you were there was Mr. Dershowitz there?
+3 (Pages 275 to 278)
+
+
+Page 279
+Page 281
+NH
+A. Two or three times.
+3
+Q. And did you have any knowledge of why he
+was visiting there?
+4
+A. No, ma'am.
+5
+Q. You don't know whether or not he was a
+6
+7
+lawyer -- acting as a lawyer or whether he was
+there as a friend?
+8
+A. I believe as a friend.
+9
+Q. Were there also young ladies in the house
+10 at the time he was there?
+11
+MR. CRITTON: Form.
+12
+THE WITNESS: Yes, ma'am.
+13
+BY MS. EZELL:
+14
+Q. And would those have included, for
+15 instance,
+and
+?
+16
+A. Yes, maam.
+17
+Q. Were there other young ladies there when
+18 Mr. Dershowitz was there?
+19
+MR. CRITTON: Form.
+20
+THE WITNESS: Yes, ma'am.
+21
+BY MS. EZELL:
+22
+Q. Do you have any idea who those young
+23
+women were?
+24
+A. No, ma'am.
+25
+Q. Were any of those the young women that
+Q. Can you tell me where those were?
+A. One in the kitchen, and the one in the
+4
+formal -- the main entrance. And there was one
+more added later on, but there is two when I was
+5
+working there.
+6
+7
+Q. Could you just give me a rough sketch of
+the house of where the main entrance was and where
+8
+the kitchen was?
+9
+A. I'm not an architect but it's something
+10 like this. This is the kitchen, this is the main
+11 entrance.
+12
+13
+Q. Will you mark the kitchen with a K,
+please, and the main entrance with ME?
+14
+A. This is the pool.
+15
+16
+Q. The pool?
+A. Yes, ma'am.
+17
+Q. And in the upper left?
+18
+A. In the terrace, yeah, there was a balcony
+19
+here.
+20
+Q. And where were the staircases?
+21 A. This is one, the kitchen, one in the
+22 foyer, and the pool.
+23
+Q. Okay. And would you just put an F where
+24 the foyer staircase began? And KS where the
+25
+kitchen staircase began.
+Page 280
+Page 282
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+23
+24
+25
+you have said came to give massages?
+A. Yes, ma'am.
+Q. And do you have any idea whether or not
+Mr. Dershowitz was also receiving massages?
+A. I don't know, Ma'am.
+Q. I want to ask you to take this piece of
+paper, please, and a pencil --
+MR. WILLITS: Can anybody hear me?
+MS. EZELL: Yes. Can you hear me?
+MR. WILLITS: I've heard nothing for
+about a minute or so.
+MR. CRITTON: Can you hear me now?
+MR. WILLITS: Yes.
+MS. EZELL: I'm asking questions, I'm
+SOMR. CRITTON: Why don't we go off the
+record for a second.
+(Thereupon, a discussion was held off the
+record.)
+THE VIDEOGRAPHER: We're back on the
+record.
+22 BY MS. EZELL:
+Q. Mr. Rodriguez, you indicated that there
+were several staircases in the house?
+A. Yes, ma'am.
+And you said that later another staircase
+was added?
+A. Yeah, we rehabilitated this, you know,
+but you asked me how many stairs there were, to
+5
+6
+answer your question there were three.
+Q. Three. So where was the third one?
+A. The pool, this leads to the pool.
+9
+Through the outside master bedroom you could go
+downstairs to the pool.
+10
+Q. Okay. A stairway then from the outside,
+11
+from outside the master bedroom?
+12
+A. Yes, ma'am.
+13
+Q. Down to the pool?
+14
+A. Yes, ma'am.
+15
+Q. One of your duties was to answer the
+16
+17
+door. Is that correct?
+A. Yes, ma'am.
+18
+19
+Q. Which door would you answer?
+A. Mainly the kitchen.
+20
+Q. And why was that, why would people mainly
+21
+come to the kitchen?
+22
+A. I'll say it was for practicable reasons
+23 because not to go to the main -- it was shorter
+24 because the entrance was here, so this was the
+25 driveway and we used to take into the back door of
+4 (Pages 279 to 282)
+
+
+Page 283
+1
+the kitchen and they will wait there.
+2
+Q. All right. Would you just put BD where
+3
+the back door of the kitchen was, please?
+4
+Now, these young women that came to give
+5
+Mr. Epstein massages, would they usually come to
+6
+the kitchen door?
+7
+8
+A. Yes, ma'am.
+MR. CRITTON: Form.
+9
+BY MS. EZELL:
+10
+Did any ever come to the front door?
+11
+Very rarely.
+12
+Q.
+And you would let them in the kitchen?
+13
+A. Yes, ma'am.
+14
+0. And then how did you then turn them over
+15
+to
+16
+17
+MR. CRITTON: Form.
+THE WITNESS: I will call her.
+18 BY MS. EZELL:
+19
+Q. How would you call her?
+20
+21
+On her cell phone and she will know they
+were waiting in the kitchen.
+22
+23
+Q. And would you bring them in the kitchen
+and then just leave?
+24
+A. Yes, ma'am.
+25
+Q. And where would you go?
+Page 284
+1
+A. To my -- to the staff house that was
+2
+here.
+3
+4
+Q. Good, I was going to ask you to show me
+5
+where the staff house is. Just put SH.
+A. It was just maybe five feet, I used to
+6
+stay here.
+7
+8
+Q. Okay. So what you're saying, it's about
+five feet from the kitchen?
+9
+A. More or less, yes.
+10
+Q. Was it connected to the house?
+11
+A.
+No, it's detached but it's very close
+12
+13
+proximity.
+Q. Okay. So to get to the staff house would
+14
+you come out the kitchen door?
+15
+A. Yes, ma'am. And I came through my --
+16
+17
+there was two entrances, one through the laundry
+here and one to the main entrance to the staff
+18
+house.
+19
+Q. All right. And what was your usual
+20
+21
+pathway if you left the kitchen to enter the staff
+house, how would you generally do it?
+22
+23
+A. Normally I will came to the laundry, the
+24
+laundry was here and my office was next to the
+laundry.
+25
+Q. Okay. Thank you.
+Page 285
+A. You're welcome.
+Q. Could you see the pool from the staff
+house?
+4
+5
+A. No, ma'am.
+Q. How would you know, or would you know
+when the young women were brought downstairs after
+7
+8
+giving the massages?
+MR. CRITTON: Form.
+9
+THE WITNESS: I will hear the commotion,
+10
+some voices, but I was not told they were
+11
+leaving.
+12
+BY MS. EZELL:
+13
+Q. And so did you have any duties that had
+14
+anything to do with their leaving?
+15
+A. Check the security and see if the gate
+16
+was closed, that the cars were locked because the
+17
+garage were here.
+18
+Q. Would you put a G where the garage was?
+19
+I believe you testified that you were
+20
+required to have on your person $2,000 everyday?
+21
+A. More or less, Ma'am.
+22
+Q. And if you open the door and a young
+23
+woman was there to give a massage you would call
+24
+and go back to the staff house?
+25
+A. Yes, ma'am.
+Page 286
+1
+Q. And then you believe
+would
+come in and lead the young woman upstairs.
+Correct?
+5
+MR. CRITTON: Form.
+THE WITNESS: I'm sorry, can you repeat
+6
+your question?
+7 BY MS. EZELL:
+8
+Q. Ill try to, yes.
+9
+When you would answer the door and there
+10
+would be a young lady there to give a massage.
+11
+A. Yes, ma'am.
+12
+Q. I believe you testified you would let her
+13 in the kitchen.
+14
+A. Yes, ma'am.
+15
+Q. And you called
+16
+A. Yes, ma'am.
+17
+Q. And you then left her in the kitchen
+18
+alone?
+19
+A. Yes.
+20
+Q. And went to the staff house?
+21
+A. Yes, ma'am.
+22
+Q. And sometimes you heard the commotion
+23
+when the young woman was leaving -
+24
+A. Yes, ma'am.
+25
+Q. - but you didn't necessarily see them
+5 (Pages 283 to 286)
+
+
+Page 287
+Page 289
+3
+4
+5
+leave. Is that correct?
+A. Exactly, yes, maam.
+Q. How did you transmit the money that you
+were keeping to
+to pay those young
+women?
+1
+A. Yes. The whole south face of the house,
+2
+but this was
+3
+4
+Q. All right. And so did she usually work
+with her laptop on the dining room table?
+5
+would tell me who to pay and how
+6
+A. She will have all over the house but she
+will sit down here to work on the desk.
+7
+much, that's the way we work.
+7
+Q. Do you know whether she kept any lists of
+8
+Q. And when would she tell you that?
+8
+names of girls to come and give massages?
+9
+A.
+She will call me by phone and say I'H
+9
+10
+give so much to so on and so forth.
+10
+A. She did, Ma'am.
+MR. CRITTON: Form.
+11
+Q. Okay. Was that at the conclusion of the
+11
+BY MS. EZELL:
+12
+massage?
+12
+13
+Q. And do you know in what form she kept
+MR. CRITTON: Form.
+13
+those?
+14
+THE WITNESS: Yes, ma'am.
+14
+A. She had notes, you know, she always have
+15
+BY MS. EZELL:
+15
+16
+papers, but I don't know.
+17
+Q. Okay. Then I'm a little confused because
+16
+Q. Do you recall seeing the papers with
+I thought you said that you didn't see them when
+17
+telephone numbers on them?
+18 they left from giving the massage.
+18
+A. A couple of times.
+19
+20
+A. She will call me and she will say pay X,
+19
+Q. Do you know whether she also kept records
+Y, or Z, and that's the way I knew how much and to
+20 on the computer relating to the girls?
+21
+whom. But sometimes they would leave and I didn't 21
+MR. CRITTON: Form.
+22
+23
+pay those, I don't know who paid them.
+22
+Q. Okay. So if she calls you and told you
+23
+THE WITNESS: Yes, ma'am.
+BY MS. EZELL:
+24
+25
+to pay X, Y, and Z $200, would you then go back
+24
+Q. And how do you know that?
+into the kitchen and give X, Y, and Z $200 each?
+25
+A. Everything was recorded in -- everything
+Page 288
+1
+A. Sometimes in the kitchen, sometimes in
+the driveway I will pay them in an envelope, you
+know.
+4
+Q. Okay. And she would tell you how much to
+5
+pay them?
+6
+7
+A. Yes, ma'am.
+Q. Where was Ms.
+when you would call
+8
+her to tell her that there was someone at the
+9
+kitchen door to give a massage?
+10
+11
+A. She was inside the house so I call her on
+her cell and say, Alfredo, leave them in the
+12 kitchen, but I don't know where she was.
+Q. Okay. Did she have an office?
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+• No, ma'am.
+Q. Did she have a computer in the house?
+A.
+• Yes.
+Q. Where was her computer?
+A.
+She had a laptop but she usually work in
+the dining room.
+Q. And where was the dining room?
+A. All this area facing the garden facing
+north -- I'm sorry, facing south, and
+was at her desk here.
+Q. So did the dining room have large
+windows?
+Page 290
+1
+2
+3
+4
+we did as employees we used to record and kept in
+the internal circuit we used to have among the
+employees.
+Q. And so would it be, if I understand you
+correctly then, was there some sort of a program
+so that you could access information that
+7
+Ms.
+was putting into that program and she
+8
+could access information you put in?
+9
+10
+A. Yes, ma'am.
+Q. And did you also send each other e-mails
+11 that way or did you use a different program for
+12 e-mails?
+13
+A.
+didn't send direct e-mails to me
+but she will call me on her cell. But I was
+15 supposed to send through Citrix to other
+employees.
+17
+Q. E-mail them through Citrix?
+18
+A. Yes, ma'am.
+19
+Q. Okay. And who would those other
+20
+employees be, have been, I mean, while you were
+21
+22
+there?
+A. Mrs. Maxwell, Bella in New York, mostly
+23 the main people, you know, Bella and --
+24
+Q. Lesley was --
+25
+A. Lesley, yes, the secretary, and somebody
+6 (Pages 287 to 290)
+
+
+Page 291
+Page 293
+1
+2
+else, I don't recall.
+Q. Was there anyone else that you could
+e-mail?
+4
+A. We could e-mail anybody in the
+5
+organization.
+6
+Q. On that particular program?
+7
+A. Yes, ma'am.
+8
+Q. And so who else would be in that
+9
+organization?
+10
+A. Other household managers from Paris or
+11
+the Island, Manhattan.
+12
+Q. Do you know whether Ms.
+kept any
+13
+pictures of the young women who would come to give
+14
+massages on her laptop?
+15
+16
+A. Yes, ma'am.
+Q. You saw those pictures?
+17
+A. Yes.
+18
+Q. Were the pictures uniform? And by that I
+19
+20
+mean, were they all taken, for instance, there at
+the house so that they would all be fairly
+21
+standard?
+22
+MR. CRITTON: Form.
+23
+THE WITNESS: They will be all over, you
+24
+know, sometimes out of the country and
+25
+sometimes in the house.
+1
+A. I don't remember, ma'am.
+2
+3
+Q. Did you ever see
+using that
+small compact camera to take a picture of the
+4 girls?
+A. Yes, ma'am.
+MR. CRITTON: Form.
+BY MS. EZELL:
+8
+9
+Q. When you saw her doing that where were
+they, the girls?
+10
+A. The dining room, the library, the first
+11 floor of the house.
+12
+Q. Did you ever see Ms. Maxwell taking
+13
+pictures of the girls?
+14
+A. No, ma'am.
+15
+Q. Did you ever see Mr. Epstein taking
+16 pictures of the girls?
+17
+A. No, ma'am.
+18
+Q. Were you ever told by anyone that Mr.
+19 Epstein sometimes took pictures of the girls?
+20•
+MR. CRITTON: Form.
+21
+THE WITNESS: Yes, ma'am.
+22 BY MS. EZELL:
+23
+Q. And do you recall who told you that?
+24
+A. I think it was
+25
+Q. Do you recall what she said about that?
+Page 292
+Page 294
+BY MS. EZELL:
+2
+Q. Were these pictures that were taken by
+1
+2
+A. He likes photography and he likes -- like
+a hobby.
+3
+someone for the purpose of keeping them in that
+4
+program?
+Q. Do you know which camera or what kind of
+5
+A. I don't know.
+6
+MR. CRITTON: Form.
+4
+5
+camera he used to take those pictures?
+A. No, ma'am.
+Q. And you said I think you never saw him
+7
+BY MS. EZELL:
+8
+7
+taking them?
+Q. Or opposed to, for instance, one of the
+8
+A. Yes.
+9 young ladies bringing a picture to give to
+9
+Q. So-
+10 Ms.
+10
+MR. CRITTON: Yeah meaning correct?
+11
+12
+13
+nomi
+A. I don't know.
+11
+THE WITNESS: Yes.
+Q. You don't know where the pictures came
+from?
+12 BY MS. EZELL:
+13
+Q. Was it your understanding that he took
+14
+A. No, ma'am.
+15
+Q. Do you know was there anyone staying in
+14
+those pictures upstairs?
+15
+MR. CRITTON: Form.
+16
+the house who often took pictures of young women? 16
+THE WITNESS: Yes, ma'am.
+17
+MR. CRITTON: Form.
+17 BY MS. EZELL:
+18
+THE WITNESS: There was several cameras
+19
+in the house and they were used often, but I
+18
+Q. And when you had occasion to go upstairs
+19 do you recall seeing camera equipment?
+20
+21
+don't know who used them.
+20
+A. No, ma'am
+BY MS. EZELL:
+22
+Q. Okay. Do you remember what kind of
+21
+Q. Were you ever told that he took picture
+22 of the girls nude?
+23
+cameras they were?
+24
+A. The small compact camera.
+23
+A. No, ma'am.
+25
+Q. Any other kind?
+24
+Q. Were you ever told that he liked to have
+25 pictures taken of the girls nude?
+7 (Pages 291 to 294)
+
+
+Page 295
+Page 297
+1
+MR. CRITTON: Form.
+2
+THE WITNESS: No, ma'am.
+3
+BY MS. EZELL:
+4
+Q. I believe you were asked before in the
+5
+6
+deposition about the stairway leading from the
+kitchen upstairs and whether or not there were
+7
+pictures on that stairway.
+8
+9
+Yes, there were pictures.
+10
+Q. Were those pictures some of them of nude
+young women?
+11
+MR. CRITTON: Form.
+12
+THE WITNESS: Not on the stairway, they
+13
+were in the foyer in the second -- on the
+14
+foyer and the foyer leading to the master
+15
+bedroom.
+16
+BY MS. EZELL:
+17
+Q. I see. Were those -- what size generally
+18
+were those pictures?
+19
+A. They were, you know, I'll say three by
+20
+21
+five.
+Q. So very large --
+22
+A. Yes, ma'am.
+23
+Q. - pictures? Were there lots of
+24
+photographs just around the house on top of
+25
+furniture in the various rooms?
+1
+BY MS. EZELL:
+Q. And was that already installed when you
+3
+4
+5
+came there?
+A. Yes, ma'am.
+Q. Where is it you - first of all, did they
+tell you where the equipment was installed?
+A. No.
+8
+Q. Did you have any understanding of where
+9
+10
+the equipment was installed?
+A. No.
+11
+12
+Q. Do you know whether or not there was
+surveillance photography equipment upstairs and
+13
+downstairs?
+14
+15
+MR. CRITTON: Form.
+THE WITNESS: Yes, ma'am.
+16
+BY MS. EZELL:
+17
+Q. And how do you know that?
+18
+A. I read it through the FBI report after
+19 the fact that I -- after I left the job.
+20
+Q. Before reading through the FBI report did
+21 you have any knowledge of the fact that there was
+22
+surveillance equipment both upstairs and
+23
+24
+downstairs?
+A. No, ma'am.
+25
+Q. While you were there was there ever an
+Page 296
+1
+A. Yes, ma'am.
+Q. And were any of those photographs of
+4
+young women in the nude?
+A. Yes, ma'am.
+Q. Did you recognize any of those young
+women?
+A. Yes, a couple.
+8
+Q. And who was it that you recognized?
+9
+10
+A.
+and some other girl from Brazil
+that was in the house but I don't remember her
+11
+name.
+12 Q. Was this a girl that would come and stay
+13
+in the house or one of the girls that would come
+14
+and give massages?
+15
+A. They will stay at the house.
+16
+17
+Q. Stay at the house. Do you recall a
+picture of the girl, of a young women nude in a
+18
+hammock?
+19
+20
+MR. CRITTON: Form.
+THE WITNESS: No, I don't remember.
+21
+BY MS. EZELL:
+22
+Q. Was there surveillance equipment
+23
+24
+installed in the house?
+A. Yes, ma'am.
+25
+MR. CRITTON: Form.
+Page 298
+1
+2
+occasion when someone came to do any maintenance
+or repair on the surveillance equipment?
+A. Yes, ma'am.
+4
+MR. CRITTON: Object to the form of the
+5
+6
+last question.
+MS. EZELL: Pardon?
+7
+MR. CRITTON: Form of the last question.
+8 BY MS. EZELL:
+9
+Q. Did that happen more than one time?
+10
+A. I believe so, yes, ma'am.
+11
+Q. Do you have any recollection of who came
+12 there, either the name of the company or the name
+13 of the person who would come to repair or do
+14 maintenance on the video equipment?
+15
+A. We used to have a young technician from
+16 Ohio who used to maintain all the computers and he
+17 would be the only one dealing with those things.
+Q. So he maintained the computers and the
+19 video equipment.
+20
+A. Yes.
+21
+Q. Is that correct?
+22
+MR. CRITTON: Form.
+23 BY MS. EZELL:
+24
+Q. Do you have any recollection of what his
+25 name was?
+8 (Pages 295 to 298)
+7115 Rue Notre Dame, Miami Beach, FL 35141
+
+
+1
+2
+3
+4
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 299
+Page 301 g
+A.
+I don't remember, Ma'am. He came from
+New Albany, Ohio.
+Q. From New -
+A. New Albany, Ohio.
+Q. New Albany, Ohio. Did he have his own
+business?
+A. No, he worked for Mr. Epstein. He will
+maintain all the computers.
+Q. Was he there everyday?
+A.
+No, ma'am.
+Q.
+Do you know whether at that time Mr.
+Epstein had an office in Palm Beach?
+A. Not outside the house, no.
+Do you have any knowledge of whether or
+not the video equipment was -- and I don't know
+the technical term, forgive me, but was it the
+kind of equipment that would record for a certain
+amount of time and then record over that film?
+A. I don't know.
+MR. CRITTON: Form.
+BY MS. EZELL:
+Q. You don't know?
+A. No, ma'am.
+MR. CRITTON: Just for clarification, I
+may have misunderstood, but I thought he
+1
+2
+3
+video, even phones.
+Q. Would he also repair the televisions if
+they needed work?
+A. No.
+5
+Q. No. Did you have any kind of intercom
+6
+7
+system in the house?
+A. Yes, ma'am.
+8
+9
+Q. And what kind of system was that?
+A. It was standard office equipment, Lucid
+10 Technologies maybe, but it was an intercom like we
+using right now.
+12
+13
+MS. EZELL: Just let the record reflect
+that the witness pointed to the telephone on
+14
+15
+the table that has a speaker phone.
+THE WITNESS: Yes, ma'am.
+16
+BY MS. EZELL:
+17
+Q. And did you use that in your work?
+18
+A. Yes, ma'am.
+19
+Q. And what did you use it for?
+20
+A. Mr. Epstein used to page me when he
+21
+needed me.
+22
+Q. Did you have one of those phones in the
+23 kitchen?
+24
+25
+A. Yes, ma'am.
+Q. And was there one out in the staff house
+Page 300
+said he didn't even know the video equipment
+existed until he read the FBI report.
+MS. EZELL: He said he didn't know that
+it was upstairs and downstairs, I believe.
+MR. CRITTON: I thought he said he didn't
+know that it even existed.
+MS. EZELL: I may be wrong.
+BY MS. EZELL:
+Q. Did you know it existed before you read
+the FBI report?
+A. No, ma'am.
+Q. I'm sorry, then I was wrong.
+How did you know then that the young
+technician from Ohio maintained the computers and
+the video equipment?
+A. Because we used to request -- there were
+always problems with the computers so he came to
+the house and he was the programmer. It was very 18
+sophisticated.
+MR. CRITTON: Form to the last question,
+move to strike the answer as nonresponsive.
+BY MS. EZELL:
+Q. How did you know then that he maintained
+the video equipment as well?
+A. Because he was in charge of computers,
+Page 302
+1
+as well?
+2
+A. Yes, ma'am.
+3
+Q. Do you know where others were in the
+4 house?
+5
+6
+A. Probably have like 15 phones. We used to
+have three in the staff house, one in the cabana,
+7 two in the master bedroom, one in each room,
+8 kitchen, dining room, Mrs. Maxwell's office, the
+9 garage.
+10
+Q. Where was Mrs. Maxwell's office?
+11
+A. Under the stairs next to the kitchen.
+12
+Q. Can you give me some idea of what size
+13
+space that was?
+14
+A. It was probably - we change the floor.
+15 Twelve by five, something like that.
+16
+17
+Q. And was the computer equipment in that
+space?
+19
+A. Yes, ma'am.
+Q. Do you know whether Ms. Maxwell kept the
+20
+names and telephone numbers of the girls who came
+21 to do massages?
+22
+A. Yes, ma'am.
+23
+MR. CRITTON: Form.
+24 BY MS. EZELL:
+25
+Q. Do you know that because you saw the
+9 (Pages 299 to 302)
+
+
+Page 303
+Page 305 h
+1
+names and phone numbers?
+2
+MR. CRITTON: Form.
+3
+THE WITNESS: Yes, maam.
+4
+BY MS. EZELL:
+6
+Q.
+Do you know if she kept pictures of the
+7
+girls on the computer?
+8
+A. Yes, she did.
+Q. And you know that as well because you
+9
+happen to see them?
+10
+A. Yes, ma'am.
+11
+MR. CRITTON: Form to the last two
+12
+questions.
+13
+• BY MS. EZELL:
+14
+15
+Q
+Were they similar to the pictures that
+Ms. |
+had on her computer?
+16
+MR. CRITTON: Form.
+17
+THE WITNESS: Yes, ma'am.
+18 BY MS. EZELL:
+19
+Q. Did the pictures that they kept there
+20
+21
+look like pictures that were posed?
+A. They were more casual.
+22
+Q. Did they look as though the person being
+23
+photographed knew that they were being
+24
+photographed?
+25
+MR. CRITTON: Form.
+1
+2
+THE WITNESS: No, ma'am.
+BY MS. EZELL:
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+Q. And what can you tell me about that, what
+lead you to draw that conclusion?
+A. They were probably taken in parties in
+big reception or banquet.
+MR. CRITTON: Let me offer as a
+suggestion, not that you have to accept or
+that you would, you're using the term young
+girls generically, he has probably seen
+many, many young girls, there was no -
+you've used it interchangeably with just
+young girls versus young girls who may have
+come to -- purported to give a massage and,
+therefore, that may be a different answer,
+so that's part of my form objection.
+MS. EZELL: Okay, thank you.
+BY MS. EZELL:
+Q. When I asked you about Ms.
+whether
+she had a list of the girls and telephone numbers,
+I think I asked about those girls that came to
+give massages, but let me go back and just ask it
+that way.
+Did you notice that Ms.
+had a list
+25 of the girls that came to give massages on her
+1
+2
+computer?
+MR. CRITTON: Form.
+4
+THE WITNESS: Yes, ma'am.
+BY MS. EZELL:
+5
+Q. And did she generally have phone numbers
+for those girls?
+8
+A. Yes, ma'am.
+Q. And were they generally pictures of the
+9
+girls?
+10
+MR. CRITTON: Form.
+11
+THE WITNESS: No, ma'am.
+12 BY MS. EZELL:
+13
+Q. And did Ms. Maxwell have a list of the
+14 girls who came to give massages?
+MR. CRITTON: Form.
+16
+THE WITNESS: Yes, ma'am.
+17 BY MS. EZELL:
+18
+Q. Did she have telephone numbers generally?
+A. Yes, maam.
+20
+MR. CRITTON: Form.
+21
+BY MS. EZELL:
+22
+Q. Were there pictures on her computer of
+23
+the girls who came to give massages?
+24
+MR. CRITTON: Form.
+25
+BY MS. EZELL:
+Page 304
+Page 306
+1
+Q. Ms. Maxwell I'm talking about.
+A. Yes, ma'am.
+3
+Q. And were those pictures the more casual
+4
+ones that you described when I asked whether or
+5
+not the subject looked as though she knew she was
+6
+being photographed?
+7
+MR. CRITTON: Form.
+8
+THE WITNESS: I'm sorry, can you repeat?
+9
+BY MS. EZELL:
+10
+11
+Q. Yeah. The pictures of the young girls
+who came to the house to give massages that were
+12 on Ms. Maxwell's computer, did they appear to have
+13 been taken when the girls knew they were being
+14 photographed?
+15
+MR. CRITTON: Form.
+16
+THE WITNESS: I don't think they knew
+17
+they were being photographed.
+18 BY MS. EZELL:
+19
+Q. I believe you said they were more casual
+20 pictures.
+21
+A. Yes, ma'am.
+22
+Q. Did you notice any nude photographs in
+23 those pictures?
+24
+A. Yes, ma'am.
+25
+MR. CRITTON: Form for the last question.
+10 (Pages 303 to 306)
+
+
+Page 307
+1
+2
+3
+4
+BY MS. EZELL:
+Q. Among those pictures in Ms. Maxwell's
+computer of the young women who came there to give
+massages, were the nude photographs in that group
+taken, did they appear to be taken in the house?
+MR. CRITTON: Form.
+THE WITNESS: No, maam.
+8
+BY MS. EZELL:
+9
+Q. You said before they appeared to be taken
+10
+at receptions or banquets?
+11
+A. Yes, ma'am.
+12
+13
+Q. And I'm a little confused about how they
+were casual and taken while the girls were nude at
+14
+receptions and banquets?
+15
+A. What I saw there were parties in Russia,
+16
+Eastern Europe, I don't know which country, but
+17
+there were also pictures of nude girls in a
+18 shower, for instance, in a shower stall.
+Q. You said for instance, so were there
+20 other places other than the shower?
+21
+A. Yes, ma'am.
+22
+Q. Like what?
+23
+A. Gatherings, you know, in a party. You
+24
+could tell everybody is smiling so I believe it
+25
+was a place where they re having fun.
+1
+Q. Were any of those pictures, if you
+recall, taken in the cabana?
+3
+4
+5
+6
+7
+A. I don't remember.
+Q. Do you recall there being parties and
+gatherings in the cabana at the house?
+A. I don't remember.
+MR. CRITTON: Form.
+8 BY MS. EZELL:
+Q. When Mr. Epstein entertained did you have
+10 anything to do with seeing that the bars were
+11
+stocked and that there was food that was needed
+12 and so forth?
+13
+MR. CRITTON: Form.
+14
+THE WITNESS: There was no alcohol in the
+15
+house, only for guests. But, yeah, he will
+16
+ask sometimes for food.
+17 BY MS. EZELL:
+18
+Q. And do you ever recall him asking for
+19
+food for parties in the cabana?
+20
+A. No, ma'am.
+21
+Q. Was there a chef at the house on El
+22
+Brillo Way when you were there?
+23
+A. I'm sorry?
+24
+Q. A chef.
+25
+A. Yes, there was.
+1
+Page 309
+Q. And was there more than one during the
+2 time you were there?
+3
+A. Yes.
+4
+Q. Do you remember their names?
+5
+A. One was David, I don't remember the other
+6
+one name.
+7
+8
+Q. Did they appear to be American?
+A. Yes, ma'am.
+9
+Q. Do you know the name
+?
+10
+A. Could be, ma'am, but I'm not sure of his
+last name.
+12
+13
+Q. Do you have any idea where those chefs
+had gotten their training?
+14
+A.
+was working in San Francisco when
+15
+he was hired.
+16
+Q. Was he still there when you left Mr.
+17 Epstein's employ?
+A. Yes, to my knowledge, ma'am.
+19
+Q. Did the chef interact with the girls who
+20
+came to give massages?
+21
+A. In the kitchen, yes.
+22
+Q. And did he often offer them some food
+23
+while they were there?
+24
+A. Yes, ma'am.
+25
+Q. Were there occasions where a girl came to
+Page 308
+Page 310
+1
+2
+give a massage accompanied by another girl, or
+another person, let me say?
+3
+A. Yes, ma'am.
+4
+5
+Q. And sometimes was that other person a
+woman and sometimes a man?
+6
+A. No, ma'am, always a woman.
+7
+8
+Q. Always a woman. Usually would it have
+been a woman about the same age as the young woman
+9
+coming to give the massage?
+10
+11
+MR. CRITTON: Form.
+THE WITNESS: Yes, ma'am.
+12 BY MS. EZELL:
+13
+Q. Were you ever told by Ms.
+to pay
+14 the person who came who didn't give a massage?
+15
+A. Yes, ma'am.
+16
+Q. Do you recall how much you paid that
+17
+person?
+18
+A. Yes, ma'am.
+19
+MR. CRITTON: Form.
+20 BY MS. EZELL:
+21
+Q. How much?
+22
+23
+A. 300 to 500 dollars.
+Q. Were some of those young women who
+24 brought other young women for massages regulars, I
+25 mean, did they regularly bring other young women?
+11 (Pages 307 to 310)
+
+
+MR. CRITTON: Form.
+3
+THE WITNESS: Yes, ma'am.
+BY MS. EZELL:
+4
+Q. And were there some who maybe came just
+5
+once or twice with other young women?
+6
+A. That's correct, ma'am.
+7
+Q. Now, where would the young woman who was
+8
+bringing another young woman go during the time
+9
+10
+the person that she brought was upstairs giving
+the massage?
+11
+MR. CRITTON: Form.
+12
+THE WITNESS: I will take them to the
+13
+kitchen and
+would take them from
+14
+there.
+15
+BY MS. EZELL:
+16
+17
+Q. Do you know where she took them?
+A. No, ma'am.
+18
+Q. Were they ever taken to just sit in the
+19
+living room and wait?
+20
+MR. CRITTON: Form.
+21
+22
+THE WITNESS: I don't know, ma'am.
+BY MS. EZELL:
+23
+Q. These pictures of nude young women taken
+24
+25
+in gatherings where they were smiling, did they
+appear to you to be taking part in an orgy?
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 312
+MR. CRITTON: Form.
+THE WITNESS: I don't know, ma'am.
+BY MS. EZELL:
+Q. Do you know the word cavorting?
+A. No, ma'am, I don't know.
+Q. I need my Thesaurus. You said they were
+smiling, did they appear to be having a good time?
+A. Yes, ma'am.
+Q.
+Did they appear to be doing anything
+sexual?
+A. Yes, ma'am.
+Q. And in these instances were there girls
+doing sexual things with other girls?
+Yes, ma'am.
+Q. And I'm still talking about the pictures
+on Ms. Maxwell's computer.
+A. Yes, ma'am.
+MR. CRITTON: You're talking about the
+group shots that he's mentioned from Russia
+and Eastern Europe?
+MS. EZELL: And girls in the shower.
+MR. CRITTON: Let me object to the form
+then the way you just now described that.
+MS. EZELL: He said for instance.
+MR. CRITTON: He had said a girl in the
+Page 311
+Page 313
+1
+shower, I don't know whether he ever used
+3
+plural.
+BY MS. EZELL:
+4
+Q. Was there more than one picture of a girl
+5
+in the shower?
+6
+A. There were two girls in the shower.
+7
+Q. Two girls in the shower together?
+8
+A. Yes, ma'am.
+9
+Q. And were those two girls engaged in
+10
+something sexual?
+11
+A. Yes, ma'am.
+12
+Q. And I may have asked you this question,
+13
+forgive me if I did, did you know those two girls?
+14
+A. No, ma'am.
+15
+O. Did Ms. Maxwell have nude pictures of
+16
+on her computer?
+17
+MR. CRITTON: Form.
+18
+THE WITNESS: I don't know, ma'am.
+19
+BY MS. EZELL:
+20
+0.
+21
+, Did you ever meet a young woman named
+who had an association with Ms. Maxwell?
+22
+23
+MR. CRITTON:
+MS. EZELL:
+24
+THE WITNESS: I don't remember, ma'am.
+25
+BY MS. EZELL:
+Page 314
+Q. Did you ever have any conversations with
+2
+Ms. Maxwell about any of the women in those
+pictures?
+A. No, ma'am.
+5
+0. And did you ever have a conversation with
+7
+about any of the pictures of the
+girls in her computer?
+8
+A. No, ma'am.
+9
+10
+Q. You were asked last time about the creams
+and lotions that Mr. Epstein typically had
+11
+available to him and you said you thought there
+12
+was a favorite one but you couldn't remember it.
+13
+A. Spa.
+14
+Q. Spa, you did say Spa.
+15
+A. Yeah.
+16
+Q. Thank you.
+17
+Where did the stairway from the kitchen
+18 lead -- to where did it lead?
+19
+A. To the second floor between the first and
+20 second bedrooms.
+21
+Q. Were either of those bedrooms the master
+22 bedroom?
+23
+A. No, ma'am.
+24
+Q. Could one go up that staircase through --
+25 could one go up that staircase and reach the
+12 (Pages 311 to 314)
+
+
+Page 315
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+master bedroom?
+A. Yes, ma'am.
+Q. And how would you do that? If you want
+to turn the page over for the upstairs you could
+do that.
+A. Okay.
+MR. CRITTON: Are you going to mark this
+as an exhibit?
+MS. EZELL: Uh-huh.
+MR. CRITTON: Would that be Exhibit 3?
+MR. EDWARDS: I think so.
+(Exhibit No. 3 was marked for
+Identification.)
+THE WITNESS: This is the master bedroom,
+master bath, and there were one, two -- the
+rest of the bedrooms were here and the
+master bedroom was here. This is master
+bath one and master bath two.
+So the staircase came to the second floor
+like this and it was between the first and
+second bedroom. And you could go through
+here and you enter a foyer with double doors
+here, double doors here, and you enter the
+master bedroom.
+BY MS. EZELL:
+1
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 316
+Q. All right. How would you get to the
+master bathroom on that end?
+A. You go through these double doors, go
+around the bed and you gain access to the master
+bedroom -- master bathroom, sorry.
+Q. And then there was another master
+bathroom on the other side of the room?
+A. Yes, ma'am.
+Q. Where generally did the massages take
+place?
+A. Right here, ma'am.
+Q. And is that in the master bathroom?
+A. Master bathroom, yes.
+Q. Do you recall what color the tile was in
+that bathroom?
+A. There was carpet.
+Q. Was there tile on the walls or marble
+A. There was a sauna here with marble but
+outside the sauna everything was carpet, and the
+walls, they didn't have any tile. Oh yes, I will
+say four feet off the floor they will have marble.
+Q. And do you remember what color marble it
+was?
+A. White.
+1
+Page 317
+Q. White. By the way, I have some more
+2
+water, would you like some?
+3
+A. Thank you, ma'am.
+4
+Q. I figure if I'm a little dry you may be
+5
+too.
+6
+I believe one of the items that you
+7 mentioned that sometimes had to be picked up after
+girls were there giving massages was a back
+9
+massager.
+10
+A. Yes, ma'am.
+11
+Q. Could you describe that for me, please?
+12
+A. It was a piece about this big.
+13
+Q. Would you say that's about 18 inches?
+14
+A. Yes, ma'am. And two prongs with the
+15
+rubber tips and a cord.
+16
+Q. Okay.
+17
+A. Or it could be detached too.
+18
+Q. Do you have any recollection of what make
+19 that was?
+20
+A. No, ma'am.
+21
+22
+Q. Were there any other massagers that you
+23
+recall seeing there regularly?
+A. Those are the ones I remember. I think
+24
+25
+they are from Sharper Image, but I don't -
+Q. Okay. Were there often girls around the
+Page 318
+pool at the house?
+2
+A. Yes, ma'am.
+3
+Q. And were these sometimes the same girls
+4 that came to give massages?
+5
+6
+A. Yes, ma'am.
+7
+Q. Were there girls in addition to those who
+came to give massages who hung around the pool?
+8
+A. The girls who were staying at the house.
+9
+Q. Okay. And so they weren't girls who just
+10
+11
+regularly came to hangout around the pool?
+A. No, ma'am.
+12
+MS. EZELL: Excuse me. Can we go off the
+13
+record for a minute?
+14
+(Thereupon, a recess was had.)
+15
+THE VIDEOGRAPHER: We're back on the
+16
+17
+record with tape number two.
+BY MS. EZELL:
+18
+Q. Mr. Rodriguez, did you receive a subpoena
+19 that asked you to bring documents with you to the
+deposition?
+21
+A. Yes, ma'am.
+22
+Q. And did you bring any with you?
+23 A. I couldn't find anything at my house.
+24
+Q. Okay. I believe we talked about a
+25 journal that you kept, and you looked for that?
+13 (Pages 315 to 318)
+
+
+A. Yes, ma'am.
+3
+Q. And you couldn't find it?
+4
+A. I give it to Detective
+5
+Q.
+A.
+Yes, ma'am.
+6
+7
+Q.
+You mentioned that you called Mr.
+Jean-Luc Bernell about a recommendation when you
+8
+were looking for a job.
+9
+A. Yes, ma'am.
+10
+Q. And did you know him from his visits in
+11
+the home?
+12
+A. Yes, ma'am.
+13
+Q. Did you say that his wife's name was Eva?
+14
+MR. CRITTON: Form.
+15
+THE WITNESS: No, ma'am.
+16 BY MS. EZELL:
+17
+Q. Do you know what his wife's name was?
+18
+A. Eva was a model, a former model from
+19
+years past who was friend of Mr. Epstein.
+20
+Q. Do you know if she was married to Glenn
+21
+22
+Dubin? Do you know Mr. Dubin?
+23
+MR. CRITTON: Form.
+THE WITNESS: I believe, yeah, I'm not
+24
+25
+sure, maam.
+BY MS. EZELL:
+Page 320
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+Q. Is she now a doctor?
+A. No, she was a model, her husband could be
+a doctor but I don't think she is.
+Q. Okay. So is Jean-Luc Bernell married; to
+your knowledge?
+A. I don't know, ma'am.
+Q. I think I must have gotten confused
+because we were talking about the picture in the
+house of the little girl who is lifting up her
+skirt or her underpants, I'd forgotten what it
+was.
+A. Yes, ma'am.
+MR. CRITTON: Form.
+BY MS EZEL•
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A. Yes, maam.
+Q. Do you know where she and her mother
+live?
+A. They live in Manhattan.
+MR. CRITTON: Form.
+Page 319
+Page 321
+1 BY MS. EZELL:
+2
+Q. Did they ever visit Mr. Epstein at the
+home when you were there?
+4
+A. Yes, ma'am.
+5
+Q. How old was the little girl at that time?
+6
+7
+A. Eight years old.
+Q. Did the girl's father come to visit as
+8
+well?
+9
+A. Yes, ma'am.
+10
+Q. And do you remember his name?
+11
+A. No, ma'am.
+12
+Q. Do you remember hearing anything about
+13
+what he does for a living?
+14
+A. No, ma'am.
+15
+Q. Can you describe him?
+16
+A. Tall, American born, I will say 50 years
+17 old.
+18
+Q. What color hair did he have?
+19
+A. At that time it was black with a few
+20 white hairs.
+21
+22
+Q. Were there drawings of nude women in the
+house?
+23
+A. No, ma'am.
+24
+Q. Were there paintings of nude women in the
+25 house?
+Page 322
+A. Yes, ma'am.
+Q. Did any of those appear to be
+Ms. Maxwell?
+A. Yes, ma'am.
+5
+Q. You mentioned that
+who was still
+working there when you left -
+A. Yes, ma'am.
+Q. - was a very religious woman -
+9
+10
+A. Yes, ma'am.
+Q. -and would sometimes be upset about
+11
+seeing pictures of nude girls or having to pick up
+12 sex toys, et cetera.
+13
+MR. CRITTON: Form.
+14
+THE WITNESS: Yes, ma'am.
+15
+16
+BY MS. EZELL:
+Q. And you said that you remembered her
+17
+crying because there was a picture of the Pope
+•next to a picture of a naked girl.
+19
+20
+MR. CRITTON: Form.
+THE WITNESS: Yes, ma'am.
+21
+BY MS. EZELL:
+22
+Q. Do you know who that naked girl was?
+23
+A. I don't remember, ma'am.
+Q. I believe David Copperfield's name came
+25 up in the last deposition as someone who would
+14 (Pages 319 to 322)
+
+
+Page 323
+1 call or visit.
+2
+A. Yes, ma'am.
+3
+Q. Were you ever there when he visited?
+A. Yes, ma'am.
+5
+Q. And do you remember did he spend the
+6
+night?
+7
+A. No, ma'am.
+8
+Q. Did he come for dinner?
+9
+A. Yes, ma'am.
+10
+Q. Did that happen more than one time when
+11 you were there?
+12
+A. Yes, ma'am.
+13
+Q. Do you remember whether or not any of the
+14 young ladies who came to perform massages also
+15 stayed for dinner?
+16
+A. No, ma'am.
+17
+MR. CRITTON: Just so it's clear, no, you
+18
+don't remember?
+19
+THE WITNESS: No, they were not there.
+20
+BY MS. EZELL:
+21
+Q. Did any of them ever stay for dinner?
+22
+Just any dinner, not the dinner with David
+23
+Copperfield.
+24
+A. You said they, the girls?
+25
+Q. The girls who came to give massages.
+Page 324
+1
+2
+A. No, ma'am.
+Q. In the earlier part of the deposition you
+3
+4
+stated that you didn't drive the girls but then
+later you remembered that you did sometimes have
+5
+to drive them.
+6
+A. Yes, ma'am.
+7
+Q. Do you remember a young woman named
+8
+who came there?
+9
+A. Yes, I do remember.
+10
+MS. EZELL: And again, we're going to
+11
+have the same agreement, if we use a girl's
+12
+name it will be shown on the transcript as
+13
+the initials only.
+14
+MR. EDWARDS: Agreed.
+15
+MR. CRITTON: Why don't you give him the
+16
+initials? Because in reading the transcript
+17
+we could end up with 25 's or is ors,
+18
+19
+in looking at it by just using the first, I
+am just offering a suggestion because none
+20
+of us will remember who in the heck these
+21
+people are.
+22
+23
+MS. EZELL: So you're asking me to give
+both names so we would have two initials?
+24
+MR. CRITTON: He may not recognize either
+25
+the first or the second name but as long as
+HN
+Page 325
+6
+we are start with it and then you can use
+the initials after that for all I care.
+BY MS. EZELL:
+Q. Do you remember a girl named
+A. I heard that name.
+Q. So I will refer to her as
+from now
+on.
+I'm going to show you a document, we can
+9
+mark it but I'm not going to leave it. I'm going
+10
+to take the exhibit.
+11
+MR. CRITTON: Wait a minute. Are you
+12
+13
+going to make a copy of it?
+MS. EZELL: No, I'm not going to leave a
+14
+15
+copy.
+MR. CRITTON:, All right. Then I object
+16
+to you showing him a document that is not
+17
+part of this record
+18
+MS. EZELL: Then object and the Judge can
+19
+rule, but I'm going to ask him to look at
+20
+this document. We can mark it as Exhibit 4.
+21
+THE WITNESS: Oh yeah.
+22 BY MS. EZELL:
+23
+Q. Do you remember this young woman?
+24
+A. Yes.
+25
+MR. CRITTON: Let's see.
+Page 326
+1
+2
+3
+4
+5
+BY MS. EZELL:
+Q. And was she one of the ones who came to
+the house to give massages?
+A. Yes, ma'am.
+Q. Do you remember her name?
+A. No, ma'am.
+7
+8
+Q. Is it possible she was
+MR. CRITTON: Form.
+10
+THE WITNESS: I hear that name but I
+cannot say for sure.
+11
+BY MS. EZELL:
+12
+Q. Okay. Did she come often to the house?
+13
+A. Yes, ma'am.
+14
+Q. Were you ever aware of her being
+15
+photographed?
+16
+A. No, ma'am.
+17
+Q. Iasked you about David Copperfield
+18 before and let me ask you again. In thinking
+19 about it is it possible that you remember that she
+was there for dinner with David Copperfield?
+21
+MR. CRITTON: Form, asked and answered.
+22
+THE WITNESS: Possible, yes, ma'am.
+23
+BY MS. EZELL:
+24
+Q. Did you ever meet her parents?
+25
+A. No, ma'am.
+15 (Pages 323 to 326)
+
+
+Page 327
+Page 329
+Q. Ill take the pictures back.
+2
+3
+MR. CRITTON: Just put on the record that
+my client obviously could be here at the
+deposition, or anyone's clients could be
+here at the deposition and have full access
+to the information that's being provided, by
+taking the photograph back I'm not going to
+be able to provide to that client, nor will
+I have possession of it so I could discuss
+10
+11
+12
+13
+14
+15
+16
+17
+18
+20
+21
+22
+23
+24
+25
+that photograph, it's now been explored with
+this witness.
+(Exhibit No. 4 was marked for
+Identification.)
+BY MS. EZELL:
+Q. Do you recall that on occasion you drove
+this young woman to or from Mr. Epstein's house?
+MR. CRITTON: Form.
+THE WITNESS: I don't remember, ma'am.
+19 BY MS. EZELL:
+Q. Do you ever recall driving her by the
+airport and showing her Jeffrey Epstein's plane?
+MR. CRITTON: Form.
+THE WITNESS: Yes, ma'am.
+BY MS. EZELL:
+Q. Do you ever recall one time perhaps by
+Page 328
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+accident seeing her naked?
+MR. CRITTON: Form.
+THE WITNESS: Yes, ma'am.
+BY MS. EZELL:
+Q. How did that happen?
+A.
+I told
+to go upstairs because I
+saw Mr. Epstein leave, so we rushed upstairs to
+clean and this girl was sleeping naked in the
+sauna, she fall asleep there, there was nobody
+else there.
+MR. CRITTON: Can I ask just for
+clarification, is he talking now about the
+person he thought was but he wasn't sure
+or the person that's in photo four?
+MS. EZELL: The person that's in
+photo four.
+THE WITNESS: Yes.
+MR. CRITTON: Okay, thank you.
+BY MS. EZELL:
+And just so we're clear, do you think
+this is
+• but you're not sure?
+MR. CRITTON: Form.
+THE WITNESS: I heard the name so many
+times but I know I took her, you know, in
+the Suburban, so it was her.
+1
+BY MS. EZELL:
+2
+Q. You mentioned last time that Mr. Epstein
+3
+asked you to go and rent a car for one of the
+4 girls who gave him massages.
+5
+A. Right.
+6
+Q. Do you know if that was
+A. I'm not hundred percent sure, ma'am.
+8
+Q. Do you know how long that girl kept the
+9
+car?
+10
+A. A couple of months.
+11
+Q. Did she bring it back to you or did she
+12
+turn it in at the agency?
+13
+A. She brought it back to me.
+14
+Q. Did you ever have any knowledge of Mr.
+15
+Epstein helping this girl with her college
+16
+applications?
+17
+MR. CRITTON: Form.
+18
+THE WITNESS: I believe Mr. Epstein was
+19
+giving her money for good grades, that's
+20
+what I -- she told me, I understood that.
+21
+BY MS. EZELL:
+22
+Q. Was this the girl that you were
+23
+instructed by Mr. Epstein to take roses to at the
+24
+completion of her graduation?
+25
+A. I don't remember exactly, ma'am, but
+Page 330
+1
+2
+3
+4
+5
+there were so many faces, you know, but I cannot
+say a hundred percent.
+Q. But it's possible that this is the same
+girl?
+A. Yes, ma'am.
+MR. CRITTON: Form.
+7
+BY MS. EZELL:
+8
+Q. And thinking about it carefully you still
+9
+believe she kept that car for two months?
+10
+A. Yes, ma'am.
+Q. Do you recall an encounter with this same
+12 girl when you saw a strange vehicle in the
+driveway one day?
+14
+MR. CRITTON: Form.
+15
+THE WITNESS: Yes, ma'am.
+16
+17
+BY MS. EZELL:
+Q. And what happened then?
+18
+A. I saw, you know, an old car that didn't
+19 belong to the house so I went to the police
+20 department, so the police department follow me and
+21
+they with flashlight they went into the driver and
+22 ask her because she was -- I forgot I was suppose
+23 to pay her but it was late at night, 8:00 p.m.,
+something like that, 8:30, so I recognize her and
+25 I said to the police department I know this girl,
+16 (Pages 327 to 330)
+
+
+Page 331
+1
+2
+3
+4
+5
+so I paid her and she went off.
+Q. Do you recall how much you paid her?
+A. Between two and 300 dollars, I believe.
+Q. How often was Mr. Epstein in Palm Beach
+during the period you were there?
+A. He will stay two months -- I mean, two
+weeks out of the month.
+MS. EZELL: If I could please have these
+10
+marked as Exhibits 5 through 8.
+(Exhibit No's. 5, 6, 7, and 8 were
+11 marked for Identification.)
+12
+MR. CRITTON: Do you want them in the
+13
+order you gave them?
+14
+MS. EZELL: It doesn't matter.
+15
+BY MS. EZELL:
+16
+Q. Would you look, please, at the exhibit
+17 that has been marked as number -- what is it;
+18 five?
+19
+20
+A.
+Five.
+Q. Five. Do you recall seeing this young
+21
+woman at the house when you were there?
+22
+23
+A. Yes, ma'am.
+Q. And do you recall her name?
+24
+25
+A.
+No, ma'am.
+MR. CRITTON: Let the record reflect it's
+Page 332
+1
+written on the photographs is a name, so
+it's already being suggested to him, I think
+3
+that's inappropriate.
+4
+MS. EZELL: It shouldn't be there, I'm
+5
+sorry. If I can erase it I will, I didn't
+6
+realize it was on there.
+7
+MR. CRITTON: It's on all of them, Cathy.
+8
+MS. EZELL: You're right, sorry.
+9
+BY MS. EZELL:
+10
+Q. Looking at the girl in number five, if I
+11
+told you that her name was
+L would that
+12
+refresh your recollection as to who she was?
+13
+A.
+No, ma'am.
+14
+Q. Would you look, please, at the girl in
+15
+the picture that's been marked as Exhibit 6?
+16
+17
+Do you ever recall seeing that girl come
+to the house to give massages?
+18
+A.
+I cannot guarantee that, Ma'am.
+19
+20
+Q. I understand, it's not the best picture
+in the world either, you can't see.
+21
+MR. EDWARDS: I don't know that I
+22
+understood the answer. You can't guarantee
+23
+it?
+24
+THE WITNESS: I cannot guarantee it, sir.
+25 BY MS. EZELL:
+Page 333
+1
+Q. Possibly but you're not sure?
+A. Yes, ma'am.
+3
+4
+Q. Okay. Would you look, please, at the two
+photographs that have been marked as Composite
+5
+Exhibit 7?
+6
+Do you recall seeing this girl come to
+7 the house to give massages?
+8
+A. I don't remember, ma'am.
+9
+Q. Okay. That's perfectly all right.
+10
+MR. CRITTON: Who does that purport to
+11
+be; number seven?
+12
+MS. EZELL:
+13
+BY MS. EZELL:
+14
+Q. The last one is exhibit what?
+15
+A. Eight.
+16
+Q. Eight. Do you recall seeing this girl
+17
+come to the house to give massages?
+18
+A. No, ma'am.
+19
+Q. Okay.
+20
+MS. EZELL: I don't have any other
+21
+22
+questions right now. If anybody else wants
+to go, if I could just reserve that if I
+23
+find something.
+24
+MR. WILLITS: I don't know who's next,
+25
+this is Richard Willits, I have a couple of
+Page 334
+questions.
+MR. CRITTON: All right, you're up.
+MR. EDWARDS: Hold on one second,
+Richard, they're going to put a microphone
+by the phone.
+MR. WILLITS: I only have a couple of
+questions.
+9
+(Thereupon, an interruption was had.)
+10
+THE VIDEOGRAPHER: We're back on the
+11
+record.
+EXAMINATION
+12 BY MR. WILLITS:
+13
+Q. Back on the record. Sir, my name is
+14 Richard Willits and I just have a couple of
+15 questions for you.
+17
+the house by the name your girl coming to
+18
+A. I hear that name, sir.
+19
+Q. You know the name, does that ring a bell
+20
+at all?
+21
+A. I hear the name in the house.
+22
+Q. Can you associate that name with a girl?
+23
+A. Yes, sir.
+24
+Q. I'm sorry?
+25
+A. Yes, sir, yes, I do.
+17 (Pages 331 to 334)
+
+
+Page 335
+1
+Q. Do you remember whether she came to the
+2
+house on more than one occasion?
+3
+A. I heard her name several times from
+4
+sir, but beyond that I cannot say anything
+5
+else.
+6
+Q. Okay. Who have you talked to about your
+7
+knowledge of Mr. Epstein in the last year?
+8
+A. My wife.
+9
+Q. Anyone else?
+10
+A.
+No, sir.
+11
+Q. Well, you talked to Mr. Critton.
+12
+A.
+We have a conversation in West Palm
+13
+Beach.
+14
+Q. Yes. So you talked to your wife, you
+15 talked to Mr. Critton?
+16
+A. Yes.
+17
+Q. Had you talked to anyone else in the last
+18 year about Epstein?
+19
+A. No.
+20
+Q. Did you talk to Mr. Goldberger?
+21
+A.
+Yeah, I called Mr. Goldberger first
+22 before I talked to Mr. Critton.
+23
+Q. Okay. So we have your wife, we have Mr.
+24
+Critton, and we have Mr. Goldberger.
+25
+Do we have anyone else that you talked to
+Page 336
+1
+2
+in the last year?
+A.
+No, sir.
+3
+Q. How about Mr. Epstein of course?
+4
+A.
+No.
+5
+Q. Where did you usually keep the journal
+6
+7
+with the names of the girls, in what part of the
+house?
+8
+A. In the staff house.
+9
+Q. Sorry?
+10
+11
+. The staff house, the guest house.
+Q. Right. But you said you had a journal at
+your own residence with the names of the girls.
+13
+A. I give the whole journal and all the
+14
+information regarding this case, sir, to Detective
+15
+sir.
+16
+Q.
+17
+Okay. And the materials that you gave to
+the Detective, were they kept -- were any of them
+18
+kept at your own personal residence?
+19
+20
+A. Yes, they were with me, sir.
+Q. Okay. When you gave the materials to the
+21
+Detective, did all of the materials you gave to
+22
+23
+him come from your residence?
+A.
+Yes.
+24
+Q. Do you remember exactly what you gave to
+25
+him?
+Page 337
+A. I give him a list of notes that I used to
+2
+take from frequent people -- I mean, people who
+used to frequent the house and -- I'm sorry, it's
+4
+been a few years, I don't remember, but it was
+5
+6
+those years, like it was a file with my personal
+notes because he told me it was very important and
+7
+he kind of said can I borrow this from you, and he
+8
+still has those documents, sir.
+9
+Q. So even though they pertain to Mr.
+10
+Epstein you kept those notes at your residence?
+11
+A. Yes, sir.
+12
+13
+Q. Okay. Where in your residence did you
+keep those notes before you gave them to the
+14
+Detective?
+15
+A. In my bedroom.
+16
+17
+Q. Did you have a file cabinet or --
+A. No.
+18
+Q. - chester drawers or something?
+19
+A. No, they were laying next to some other
+20
+papers that I have.
+21
+22
+Q. Did the other papers pertain to Mr.
+Epstein?
+23
+A. No, no, nothing else related to Mr.
+24 Epstein.
+25
+Q. I'm just confused as to why you told us
+Page 338
+1
+before that you had a journal at home and today
+2
+you say that you gave everything to the Detective.
+MR. CRITTON: Form. You also may have
+missed a portion of his earlier testimony if
+you couldn't hear something, but go ahead.
+MR. WILLITS: Most likely.
+THE WITNESS: What I said was I thought I
+9
+had some information, and then I look with
+my daughter and we couldn't find anything,
+10
+and I remember now that I put everything in
+11
+the file that I give to Detective
+12 BY MR. WILLITS:
+13
+Q. Did anyone help you assemble those papers
+14 to give to the Detective?
+15
+A. No, sir.
+16
+MR. WILLITS: I don't have any other
+17
+questions.
+18
+CROSS EXAMINATION
+19
+20
+BY MR. CRITTON:
+Q. Mr. Rodriguez, my name is Bob Critton and
+21 I represent Mr. Epstein as you're aware, I have a
+few questions for you.
+23
+What I would like to remind you at the
+24
+start of this is if you know something, tell us,
+25 if you don't know something tell us that.
+18 (Pages 335 to 338)
+
+
+Page 339
+1
+2
+3
+You're not required to speculate, you're
+not required to guess, you're not required to
+assume because some lawyers ask you a leading
+question or suggested in a report or like the
+5
+police report like Mr. Mermelstein and Mr. Edwards
+6
+did, that did you tell the police officers X, Y,
+7
+or Z without showing you the statement. You're
+8
+9
+not required to guess, I want personal knowledge,
+not speculation. Do you understand?
+10
+A. Yes, I do.
+11
+Q. All right. Now, when Mr. Edwards and -
+12
+Mr. Horowitz is here today for Mr. Mermelstein,
+13
+but you remember a lawyer asked you some questions
+14
+last time you were here?
+15
+A. Yes.
+16
+Q. That is he started and he went on for a
+17
+few hours. Do you recall that?
+18
+A. Yes, I remember.
+19
+20
+Q. He asked you do you remember telling the
+police officer Y, X, or Z.
+21
+Do you remember that? Do you remember
+22 that's how he phrased his question?
+23
+A. Yes, yes.
+24
+Q. He never showed you a statement that you
+25
+made to the police department; did he?
+Page 340
+1
+2
+3
+4
+5
+6
+7
+8
+A. I'm sorry?
+Q. He didn't show you a document that said,
+question, you know, what is your name; answer, my
+name is Alfredo Rodriguez -
+MR. WILLITS: Object to the form of the
+question.
+MR. CRITTON: You need to let me finish
+9
+10
+MR. WILLITS: I'm sorry, I thought you
+were.
+11 BY MR. CRITTON:
+12
+Q. He never showed you a statement of what
+13 the question was and the answer that you gave.
+14
+True?
+15
+MR. WILLITS: Object to the form of the
+16
+question.
+17
+THE WITNESS: I don't exactly understand
+18
+your question.
+19 BY MR. CRITTON:
+20
+Q. Do you know what a deposition is?
+21
+A. Yes, I am.
+22
+Q. That's what you're doing here.
+23
+MR. CRITTON: Could I borrow your
+24
+deposition for just a minute?
+25
+MR. HOROWITZ: The transcript? It's
+Page 341
+1
+marked up, no, you can't.
+MR. CRITTON: I just want to show him.
+Thank you, Cathy.
+BY MR. CRITTON:
+Q. This is the first what Ms. Ezell was kind
+enough to provide is the first part of your
+deposition, it was transcribed by the court
+8
+reporter and provided by all counsel.
+9
+10
+Do you understand that?
+A. Yes, I understand that.
+11
+Q. And no one has provided that to you yet
+12
+today; have they?
+13
+A. No.
+14
+Q. Now, I think you told us that with the
+15
+police officers you gave a taped statement.
+16
+Did I understand you correctly?
+17
+A. Yes.
+18
+Q. And the only conversation that you had
+19
+with the police officers, and it may have been a
+20
+state attorney, it was somebody named Ms. Weiss
+21
+who I think was referenced in the questions, the
+22
+23
+only time that you talked with at least Officer
+and the State Attorney's Office from Palm
+24
+25
+Beach County was in a taped statement.
+Is that correct?
+Page 342
+A. No.
+2
+Q. Did you talk with them separate and apart
+3
+from that?
+4
+A. Yes, I did.
+5
+Q. Okay. Did they tape that statement?
+6
+7
+A. No.
+Q. You told us you also spoke with
+8
+representatives of the FBI?
+9
+A. Yes.
+10
+Q. Okay. And you distinguished between the
+11
+FBI and between Officer
+12
+A. Yes.
+13
+Q. So how many times did Officer
+•, or
+14
+Detective
+L I think he's from the Palm
+15
+16
+Beach Police Department speak with you?
+A. Like three or four times.
+17
+Q. But he only took one statement?
+18
+A. One taped.
+19
+Q. I'm sorry, one taped statement?
+20
+A. Yes.
+21
+Q. All right. So as to whether or not if
+22
+you said something to Officer
+or not that
+23
+you would be able to confirm, that would only have
+been in a taped statement, one taped statement out
+25 of the three, approximately three times he spoke
+19 (Pages 339 to 342)
+
+
+Page 343
+1
+2
+3
+4
+5
+with you.
+MR. EDWARDS: Form.
+MR. HOROWITZ: Form.
+BY MR. CRITTON:
+Q.
+Is that correct?
+A. Yes, correct.
+MR. WILLITS: Object to the form.
+MR. HOROWITZ: Join.
+9
+BY MR. CRITTON:
+10
+Q. And when we were here, I think it was
+11
+last week or the last ten days anyway -- I could
+12
+13
+tell you. On July 29th of this year, and Mr.
+Mermeistein started with your deposition and then
+14
+others asked questions, when Mr. Mermelstein and I
+15
+16
+think Mr. Edwards asked questions about did you
+tell Officer
+/X, Y, or Z, they didn't show
+17
+you a statement, they didn't give you like a
+18
+transcript like this and say see what the question
+19
+and see what the answer is?
+20
+21
+A. No.
+MR. EDWARDS: Form.
+22
+23
+MR. WILLITS: Object to the form of the
+question.
+24 BY MR. CRITTON:
+25
+Q. And you haven't had an opportunity to see
+Page 344
+1
+your taped statement since you gave it many years
+2
+3
+ago?
+No, sir.
+Q. Would you agree that your taped statement
+6
+would probably be a little more accurate than your
+7
+testimony today because of the time period that
+8
+has transpired?
+A. That's correct.
+9
+MR. HOROWITZ: Object to the form.
+10
+MR. WILLITS: Object to the form of the
+11
+question.
+12 BY MR. CRITTON:
+Q. When you spoke with the FBI over at
+14
+Greens -- I think it was Greens Pharmacy?
+15
+A. Yes.
+16
+Q. Did they take a statement from you, that
+17
+is, did they have a tape recorder or did they just
+18
+make notes?
+19
+A. They took notes.
+20
+Q. All right. Did you sign anything?
+21
+A. No, sir.
+22
+23
+Q. That is like did they take notes of what
+you said and then you signed it to say yep, that
+24
+accurately reflects what I said?
+25
+A. No, I didn't sign anything.
+Page 345
+Q. When Officer
+y took - spoke with
+2
+3
+you on those approximately two times when he did
+not take a taped statement, did he ever present
+4
+anything for you, anything in writing that he had
+5
+written to say, Mr. Rodriguez, I would like you to
+6
+review this to make certain that I took down
+7
+correctly what you said?
+8
+A. No, sir.
+9
+10
+Q. If he had offered to do that would you
+have read what he wrote down to determine whether
+11
+or not he took down that which you had said or
+12 told him?
+13
+MR. EDWARDS: Object to the form.
+14
+15
+THE WITNESS: Probably I will read it
+first.
+16
+BY MR. CRITTON:
+17
+Q. All right. And if in fact he had
+18
+recorded something incorrectly or recorded in a
+19
+particular way that he wanted it phrased and it
+20 was not accurate, would you have told him that?
+21
+MR. EDWARDS: Object to the form.
+22
+THE WITNESS: No, I never told him that.
+23 BY MR. CRITTON:
+24
+Q. Listen to my question.
+25
+If he, Officer
+i, had taken down
+Page 346
+1
+2
+3
+4
+5
+6
+what you said and it was not accurate, that is, he
+put his interpretation of what you said, would you
+have told him that's not accurate, Officer
+MR. HOROWITZ: Form.
+MR. EDWARDS: Object to the form.
+THE WITNESS: I will tell him.
+9
+MR. CRITTON: Go ahead and change. We're
+10
+going to change the tape. We do have time.
+Cathy, could I borrow back the
+11
+photographs, please?
+12
+While you're giving me those back, would
+13
+it be correct that you're going to keep --
+14
+you took as you did with photograph
+15
+16
+number four you took back five, six, seven
+17
+and eight, and you're going to keep those
+and not allow me or anyone else to have a
+18
+copy of them?
+19
+MS. EZELL: Yes.
+20
+MR. CRITTON: You're going to be equally
+21
+restrictive; right?
+22
+MS. EZELL: Right.
+23
+MR. CRITTON: All right. Thank you.
+24 BY MR. CRITTON:
+25
+Q. You were shown photograph five of a lady,
+20 (Pages 343 to 346)
+
+
+Page 347
+Page 349
+1
+, and I think you told us that you had seen
+Q. I'm sorry?
+3
+4
+her, you recognized her photograph.
+A. Yes, I did.
+3
+A. Yes, I did, I told the police.
+Q. And at the time that you spoke with the
+Q. On how many occasions did you ever see
+4
+police and gave them a statement, isn't it true,
+• her at the Epstein home?
+5
+Mr. Rodriguez, that you were no longer employed by
+6
+A. More than three times.
+6
+7
+Q. More than three?
+7
+A. Yes.
+8
+A. Yes, sir.
+8
+9
+Q. And you understood that you were required
+Q. That's as accurate as you can be?
+9 to tell the police officers the truth at that
+10
+A.
+Yes.
+10 time?
+11
+Q. More than three?
+11
+A. Yes.
+12
+A.
+More than three.
+12
+Q. And if I understood your testimony I
+13
+Q. Whether it was four or five you don't
+13 believe from July 29th through today, you at no
+14 know, but more than three?
+14 time asked any of these girls how old they were.
+15
+A.
+More than three, sir.
+15
+16
+Q. In terms of
+'s age, did you ever ask
+16
+A. No.
+17 her what her age was?
+18
+17
+Q. And as to whether the girls were under 18
+A. No, sir.
+18
+or 18 or over 18, you really didn't know one way
+19
+Q. Did she appear to you to be someone at
+19
+or the other at the time. Would that be a fair
+20
+least from seeing her and recalling her that she
+20
+statement?
+21
+appeared at least to you to be while a young woman
+22
+21
+A. Yes.
+appeared to be someone who was 18 or older?
+22
+23
+A. No, sir.
+23
+MR. WILLITS: Object to the form of the
+24
+25
+Q. Okay. Well, did you ever say anything to
+question.
+24 BY MR. CRITTON:
+the police or did you ever - were you ever
+25
+Q. On Exhibit 6 there is a person who's
+Page 348
+Page 350
+1
+concerned about that such that you told someone?
+A. No, sir.
+1
+2
+covered, the lady that Ms. Ezell asked you about I
+believe was on the right-hand side of the
+3
+Q. Haven't you told the police, sir - let
+photograph. There is a young lady on the
+me strike that, let me ask it this way.
+left-hand side with a black hat on.
+5
+In your taped statement that you gave to
+7
+the police did you not tell them that all of the
+6
+Do you recognize her at all?
+A. No, I don't recognize her.
+girls appeared to you to be 18 or above?
+Q. Okay. Thank you. With regard to the
+8
+A. Sir, as far as when all these actions
+9
+photograph four that you saw that you think
+that were taking place I was under an environment
+9
+possibly might be
+10
+that I thought I was going to be -- in other
+10
+-, I think you told us that
+you recall seeing that woman in the sauna at Mr.
+11
+words, I was afraid of any reprisal Mr. Epstein
+11
+Epstein's house on one occasion and she was naked.
+12
+and Mrs. Maxwell if I say something that is any
+12
+A. Yes.
+13
+idea of me because I have this confidentiality
+14
+agreement. What I saw that they were very young,
+13
+Q. Was that near the end of your employment
+15
+but I cannot say that they were 18 and old.
+14
+or the middle or the front end?
+15
+A. I saw her on January 2005, sir, and I was
+16
+Q. Right. Let me just take you back to my
+17
+16
+terminated in March, so that was two months prior.
+question again and see if you can answer my
+17
+18
+Q. And did you ever tell anyone that you had
+18
+question.
+seen her naked in the sauna?
+19
+20
+MR. CRITTON: Could you please read it
+19
+back?
+A. I told
+20
+Q. Okay. And what did
+21
+(Thereupon, a portion of the record was
+say?
+A. She was surprised.
+22 read by the reporter.)
+22
+Q. Okay. Did you wake the young lady up in
+23
+THE WITNESS: I think I told the police
+23 the sauna?
+24
+that.
+24
+A. No.
+25 BY MR. CRITTON:
+25
+Q. And do you know how old the young lady
+21 (Pages 347 to 350)
+
+
+Page 351
+Page 353
+1
+was at that time?
+2
+3
+A. No, I didn't know.
+Q. If I was to tell you she was born in
+4 December of '86 which would have made her 18 at
+5
+6
+the time, and you would say, not surprised?
+MS. EZELL: Objection, form.
+7
+MR. WILLITS: Object to the form of the
+8
+9
+question.
+MR. HOROWITZ: Join.
+10
+THE WITNESS: I would say I wouldn't
+11
+know.
+12
+BY MR. CRITTON:
+13
+Q. Other than telling
+did you say
+14
+anything to anyone else when you saw
+., the
+15
+lady you believe was
+•. naked in the sauna?
+16
+17
+A. I believe I mentioned that to my wife.
+Q. All right. Anyone else?
+18
+A. No.
+19
+Q. And did
+20
+continue -- assuming it was
+r, did she continue to sleep in the sauna, that
+21
+is, she didn't know you were there?
+22
+A. She never knew that I was there.
+23
+Q. She didn't at least acknowledge that she
+24
+knew. Correct?
+25
+A. Yes, correct.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 352
+Q. You were asked by Ms. Ezell -- I'm just
+going to cover a couple of things as long as I'm
+staying with Cathy here -- whether
+had told us something about the picture of the
+Pope near a picture of a naked person, naked
+woman. That's what
+told you, you never
+saw those photos. Correct?
+A. I did saw the pictures.
+Q. You did see the pictures?
+A.
+• Yes.
+Q. And the photos that you saw of the naked
+woman that was near the Pope's photograph, was
+that someone that you knew or just a picture of a
+naked woman?
+A. It was somebody - somebody that was a
+visitor in the house, but I don't know her name.
+Q. And the visitors, that would have been
+one of the plane women, you described the women
+who came in on planes, or that they came with Mr.
+Epstein from time to time?
+A. They came with Mr. Epstein from time to
+time.
+Q. All right. And those are women that I
+think you testified at your last deposition all
+appeared to be in their 20's or older. Is that
+correct?
+A. I think so, sir.
+Q. All right. I assume that in over the
+course of your life separate and apart from your
+wife you've seen a naked woman before.
+A. Yes.
+7 Q. And I assume that in your 50 some odd
+• years -- how old are you, sir?
+9
+10
+A. 55.
+Q. In your 55 years you've seen pictures of
+11
+naked women both photographs, paintings, statutes.
+12
+Would that be a fair statement?
+13
+A. Yes.
+14
+Q. And in terms of at least in this
+15
+particular case there is all sorts of -- as you
+16
+know there is testimony, and you've been asked a
+17
+number of questions about sex related issues, that
+18 is whether you saw in photographs or whether you
+19 saw anyone engaged in any type of sexual activity.
+20 Correct?
+21
+A. Correct.
+22
+Q. And I assume that you understand that men
+23 and women -- we'll start there first, that men and
+24 women actually do have sex in this world?
+A. Yes.
+Page 354
+1
+2
+Q. That comes as no grand surprise to you?
+A. No.
+Q. And you understand that people actually
+4
+enjoy sex from time to time?
+A. Yes.
+6
+Q. Are you familiar with that concept at
+7 least?
+8
+A. Yes.
+9 Q. All right. And what may be typical
+10
+sexual activity for one man and woman, or whatever
+the permutation might be, another couple, or
+12 another man and woman, or another man or woman may
+13 consider to be unusual or overly aggressive.
+14
+MS. EZELL: Objection to form.
+15 BY MR. CRITTON:
+16
+17
+Q. True?
+A. It depends on your point of view.
+18
+Q. That's what I mean. Everyone has a
+19 different point of view about sex and what may be
+20
+considered typical sexual activity for someone,
+21
+someone else may consider that's a bit
+22
+adventurous?
+23
+24
+MR. EDWARDS: Object to the form.
+THE WITNESS: Yes.
+25 BY MR. CRITTON:
+22 (Pages 351 to 354)
+
+
+Page 355
+Q. I'm not trying to make you a sex expert.
+2
+Also, I assume that when you've been in
+CVS or Walgreens, for that matter Publix or Winn
+Dixie I assume that you've -- I don't want to
+assume anything.
+Have you ever been in an aisle where
+7
+you've actually seen condoms being sold?
+8
+A. Yes.
+9
+10
+Q. And where lubricants are being sold?
+A. Yes.
+11
+Q. And as well as massage oils and other
+12
+types of oils actually are sold in those kinds of
+13
+stores?
+14
+A. Yes.
+15
+16
+Q. And they're available so that someone
+walking through Walgreens or Publix or CVS could
+17
+actually take it off the shelf, put it in their
+18
+cart, go up and pay for it and take it home?
+19
+A. Yes.
+20
+Q. All right. In the photographs that you
+21
+22
+talked about, and if I understood you correctly,
+at least during the time that you were there, Mr.
+23
+Rodriguez, in '04 and '05 there were -- you said
+24
+that there were -- I think you said downstairs --
+25
+and I'm talking about really from the kitchen area
+Page 356
+1
+up the back stairway, or what would be the kitchen
+2
+3
+stairway to the upper floor, there was I think you
+4
+said, but correct me if I'm wrong, please, that
+you don't recall seeing there being any pictures
+5
+6
+or photographs of any nude women. Is that
+correct?
+7
+A. They were not nude women in the
+8
+staircase.
+9
+10
+Q. That's all I'm talking about right now.
+In that area you never saw any pictures, or
+11
+photographs, paintings, any type of depiction of a
+12
+nude woman on that staircase going upstairs.
+13
+Correct?
+14
+A. Correct.
+15
+16
+Q. All right. And I think you said
+17
+downstairs you saw a picture of -- the only
+picture that you saw of I'd say of a younger child
+18
+19
+that displayed some form of - I don't want to say
+20
+nudity because it's probably not that, but of some
+portion of their body that was exposed, and I
+21
+think you described it as her cheek.
+22
+A. Yes, that's upstairs.
+23
+Q. That's upstairs?
+24
+A. Upstairs.
+25
+Q. And that was --
+Page 357
+1
+you say her name?
+2
+A. Yes,
+3
+Q. Okay. It's
+- there was a
+picture where someone it looked like was pulling
+on their swimsuit?
+6
+A. Yes.
+7
+Q. Do you recall ever seeing the old
+8
+Coppertone -
+9
+10
+A. Yes.
+Q. Let me ask the question. I know you know
+11
+what this is.
+12
+13
+Have you ever seen the old Coppertone
+14
+commercials and billboards that used to be
+plastered all over certainly Florida and other
+15 places where there is a cute little girl who
+16 appears to be two, three, four years old and
+7 someone is pulling down at least a portion of he
+18 swimsuit so she's exposing a small portion of he
+19 cheek is exposed?
+20
+A. Yes.
+21
+Q. Okay. Is that what the picture of the
+22
+young girl looked like that is Mr. Epstein's God
+23 daughter?
+24
+A. More or less, yes.
+25
+Q. All right. And downstairs in the kitchen
+Page 358
+1
+were there any pictures of women in any stage of
+is that how
+undress?
+3
+A. No.
+4
+Q. And then I think you said as you walk
+5
+upstairs, or as you walked up the stairway from
+6
+the kitchen at the top of the landing, I think you
+described - did you describe it as the foyer?
+8
+A. Yes.
+9
+Q. Okay. But it's really the landing, the
+10 upstairs landing?
+11
+A. Yes.
+12
+Q. I think you said there were -- there was
+13
+- were or was a three by five picture or
+14
+15
+pictures?
+A. Yes.
+16
+Q. Of women in some stage of undress?
+17
+A. Yes.
+18
+Q. Okay. And when you say three by five, I
+19 assume you meant three feet?
+20
+A. Three feet.
+21
+Q. By five feet?
+22
+23
+A. Yes.
+Q. Were they photographs?
+24
+A. Yes, they were photographs.
+25
+Q. And I think you also told us that you
+23 (Pages 355 to 358)
+
+
+Page 359
+Page 361
+1
+2
+3
+4
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+didn't recognize who those people were. Is that
+correct?
+MR. EDWARDS: Object to the form.
+THE WITNESS: I knew this particular girl
+because it was
+BY MR. CRITTON:
+Q. Okay. And is that the picture you're
+talking about?
+A. This is the picture I'm talking about.
+Q. Okay. And that was a three by five?
+A.
+Yes.
+Q. All right. And the only thing that you
+could see was a portion, that is of her other than
+say her waist or her shoulders or her arms or
+something, that's one where you could see kind of
+like the Coppertone commercial, a picture of her
+cheek?
+A. Yes. Part of her buttocks.
+MR. LANGINO: Object to the form.
+BY MR. CRITTON:
+Q. Okay. And was there another picture at
+the top of the foyer, large one, or is that the
+only one that you can recall?
+A. There were two of the same girl in
+different poses.
+H N
+A. Inside his closet, the walk-in closet.
+3
+Q. And those pictures, I think you called it
+a mosaic?
+A. Yes.
+6
+Q. And of the mosaic, approximately how many
+7
+pictures were in the mosaic?
+A. 16 or 20.
+8
+Q. Okay. And of those pictures how many did
+9
+you recognize?
+10
+A. About three or four.
+11
+12
+Q. All right. Were they - as to who those
+people were, you don't know, you just recognized
+13
+three or four of them?
+14
+A. Mr. Epstein when he was younger, and then
+15 different girlfriends, but I didn't recognize
+16
+except the ones --
+17
+Q. Okay. You said three or four of those
+18 were pictures of the girls who came over to give a
+19
+20
+21
+22
+23
+24
+25
+A. Yes.
+Q. Okay. But as to who those girls were you
+don't know as you sit here today?
+A. No, sir.
+Q. And as to what their ages were you don't
+know?
+Page 360
+Page 362
+Q. But showed the same thing?
+A. No, sir.
+2
+A. Yes.
+3
+Q. Okay. As you walked through into -- then
+4
+2
+3
+Q. That's correct?
+A. That's correct.
+if I understood it correctly, you go to the pretty
+Q. And as to what they depicted in the
+5
+much to the end of the hallway, then you go
+photographs of the girls were they in different
+6
+7
+through another small vestibule, double doors, two
+stages of undress?
+sets of double doors, and as you go straight ahead
+A. Yes.
+8
+9
+then you make a left around the bed and then you
+Q. Was everyone undressed to some degree,
+10
+end up in the bathroom.
+9 that is, they were described as nude, or at least
+A. Yes.
+10 the questions asked were these people nude? Were
+11
+Q. In the bathroom -- in the bathroom or in
+11 they actually nude or someone may have had their
+12 that location were there any pictures of any women
+12 top off?
+13 in any stage of undress?
+13
+A. There were two girls completely naked in
+14
+A. Yes.
+15
+Q. All right. And were any of those
+14
+a shower in a sexual act.
+15
+16 pictures, did they involve -- or were they of any
+16
+Q. Is that the one when Ms. Ezell asked you
+questions, that's one of the photographs that you
+17 of the girls that have been described as women who
+17
+18
+came over to give Mr. - purportedly to give Mr.
+A. No, sir.
+19
+18
+were talking about?
+Epstein a massage?
+20
+19
+A. Yes.
+20
+Q. That was a different --
+A. Different one.
+21
+Q. And do you remember who any of the names 21
+Q. Okay. And the mosaic that you saw where
+22
+of any of those people were?
+22 you saw two girls involved in a sexual act, do you
+23
+A. No.
+23 know where that photograph was taken?
+24
+Q. And the pictures you saw, where were they
+A. I think it was taken in one of the rooms
+25 located?
+25 in the house because there is an oval bathtub, but
+24 (Pages 359 to 362)
+
+
+Page 363
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+I don't know which room, sir.
+Okay. Did you recognize both the girls
+or just one of the girls?
+A. The two girls.
+Q. Then there were -- there was one or two
+other photographs of girls that you recognized?
+Yes.
+Q. Okay. And were they fully unclothed or
+did they have some degree of clothes on and/or
+11
+A. They were naked.
+12
+Q. All right. And all of the remaining
+13
+pictures at least within that mosaic were of
+14
+individuals that you did not know?
+15
+A. No, sir.
+16
+Q. And that you did not recognize as having
+17
+been at the house. Is that correct?
+18
+A. Yes, that's correct.
+19
+Q. You were also asked about some -- let me
+20
+switch for just a minute.
+21
+You were asked about a vibrator that you
+22
+23
+saw, and I think you described it as a back
+massager that was approximately 18 inches long
+24
+25
+that had a couple of rotating heads on it.
+A. Yes.
+Page 364
+1
+Q. And I think you ultimately came up with
+2
+3
+the idea as it was something you had seen at like
+a Sharper Image store.
+4
+A. Yes, sir.
+5
+6
+Q. Have you ever seen one of those types of
+devices, that is a back massager with the rotating
+7
+heads also sold - well, let me ask you this.
+8
+Strike that last question.
+9
+Have you ever been to Brookstone?
+10
+A.
+Yes.
+11
+Q. Okay. Have you ever seen a massager like
+12
+that at Brookstone?
+13
+A. Yes.
+14
+Q. Okay. You were asked whether Ms. Maxwell
+15
+kept the names of any of the girls who came to
+16
+give massages on -- let me ask it this way.
+17
+I think you were asked whether
+18
+Ms. Maxwell ever kept the names of any of the
+19
+girls who came to give massages and I think your
+20
+response was yes.
+21
+A. Yes.
+22
+Q. Okay. Did she keep them on a pad of
+23
+paper, did she keep them in a notebook, did she
+24
+keep them in a computer?
+25
+A. We used to have internal books for
+Page 365
+1
+pilots, masseuses, chefs, so she have a copy of
+2 the black book with herself and as well as the
+3
+computer.
+4
+Q. Did you ever go on Ms. Maxwell's computer
+5 to see what she had in it?
+6
+A. Yes.
+7
+Q. And was that something you were allowed
+8
+to do?
+9
+A. No.
+10
+Q. Okay. You actually went in her office?
+11
+A. Yes.
+12
+Q. And was her computer on so that you
+13
+didn't need to access the password?
+14
+A. It was off.
+15
+Q. Okay. So you just turned it on?
+16
+A. Yes, sir.
+17
+Q. And then you were able to access her
+18
+computer?
+19
+A. Exactly.
+20
+Q. And what possessed you to go in and to
+21
+access her personal computer?
+22
+A. I needed to send some documents to the
+23 New York office and it was the only computer
+24 working in the house.
+25
+Q. Okay. And how many occasions did you use
+Page 366
+1
+2
+her computer?
+A. Several times.
+Q. Was she ever aware that you used her
+4
+computer?
+6
+MR. LANGINO: Form.
+THE WITNESS: I don't think so.
+7 BY MR. CRITTON:
+8 Q. Did you ever ask Ms. Maxwell for
+9
+permission to use her computer?
+10
+A. I was the house manager, I believe I was
+11 supposed to use everything in the house to
+12
+accomplish my duties, in that case sending
+13
+financial reports or e-mails.
+Q. So would you have been -- did you ever
+15 use Mr. Epstein's computer?
+17
+A. No.
+Q. Okay. But you used Ms. Maxwell's
+18 computer?
+19
+20
+A. Yes.
+Q. Did you ever use Ms.
+computer?
+21
+A. Yes.
+22
+Q. In looking at Ms. Maxwell still, you went
+23 into Ms. Maxwell's computer with at least the idea
+24 of sending some documents?
+25
+A. Yes.
+25 (Pages 363 to 366)
+
+
+1
+3
+4
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 367
+Page 369
+Q. Up to New York?
+record with tape number three.
+A.
+Yes.
+2
+BY MR. CRITTON:
+Q. Were you going to pdf them?
+3
+Q. Mr. Rodriguez, I was asking you about
+A.
+Yes.
+4
+Q. And did she have a fax machine -- not a
+5
+Ms. Maxwell's computer and you told me how you
+fax machine, a copy machine in her office as well?
+6
+went on the computer.
+A. Yes.
+computer with her?
+Q. Okay. So how would you generally do
+7
+If she was out of town would she take her
+8
+that? Would you do that through a Microsoft
+9
+A. No.
+Q. It was something she left there?
+program?
+10
+A. Yes.
+A. Through Citrix.
+11
+Q. All right. And when you went on to pdf,
+Q. Through Citrix. All right. With Citrix,
+12
+I think you said it was really one time that you
+and that is, if you said you saw some names of
+13
+saw the names of some of these girls?
+individuals on her computer if you were just going
+14
+A. Yes.
+to pdf some documents up to New York why would you
+15
+Q. And if I understand it correctly, it was
+of - what would of caused you to have seen any
+16 -- did it have the name and then a phone number?
+names on her computer?
+MS. EZELL: Objection to form.
+17
+A. Yes.
+18
+Q. And was that something that was
+THE WITNESS: All the calls that came to
+19 automatically downloaded from the system?
+358 El Brillo, they came through the
+20
+A. Yeah, from the phone system to the
+telephone, they have a transcript somehow
+21
+that they connect to the computer, so you
+22
+computer so we have a transcript.
+Q. When you say a transcript, the fact that
+can pull it and you register the time, who
+23
+Sally Jones, phone number 561, whatever it was,
+called, who didn't call, and you can pull
+24
+this at your request.
+So I used to use that
+25
+called.
+A. It was a transcript of the phone calls of
+Page 368
+Page 370
+1
+2
+3
+to go back to some calls that they were
+requesting, especially when the hurricane
+season happened.
+BY MR. CRITTON:
+Q. Okay. So if I understand, even the
+computer you used would have had that same
+feature?
+8
+9
+A. No, no, it was totally different. Mine
+was slower and all the time was breaking down
+10
+that's why we have the guy from Ohio came and
+11
+fixed the computers.
+12
+13
+Q. Okay. Were there other computers that
+you used that had that feature, that is that --
+14
+A. Only
+1, Mrs. Maxwell, and the staff
+15
+house.
+16
+Q. Staff house being yours?
+17
+A. The guest house, yes, my office.
+18
+19
+Q. So you could go out to your guest house
+then and look for the same information?
+20
+21
+A. No.
+22
+Q. All right. I don't understand but why
+don't we take a break because we're almost out of
+23
+24
+tape.
+25
+(Thereupon, a recess was had.)
+THE VIDEOGRAPHER: We're back on the
+1
+the house, we can get it from the computer.
+2
+3
+Q. Okay. And I'm distinguishing,
+transcript, it would tell you the name and phone
+4
+5
+number, it wouldn't tell you what was said?
+6
+A. It was the message also.
+Q. Okay. Now I understand. And so
+7 Ms. Maxwell when you said she had the names of
+8 some of these girls who may have given massages,
+9
+or at least were what you called earlier girls
+10
+that gave massages, or females that gave massages,
+11
+she would have had it because that was information
+12 that was downloaded from the Citrix system into
+13 her computer?
+14
+A. Yes.
+15
+MS. EZELL: Objection, form.
+16 BY MR. CRITTON:
+Q. Okay, I understand. Now, you said she
+18 also had some pictures. Is that that one time you
+19 also saw pictures?
+A. Yes.
+21Q. And were you going through her computer
+22 at that time?
+23
+24
+Q. The question is, if all you were going to
+25 do was try to pdf some financial information to
+26 (Pages 367 to 370)
+
+
+Page 371
+1
+New York what were you doing getting to names and
+2 phone numbers and then pictures of girls?
+3
+4
+I was trying to get some information. I
+was working the computer and I just happen -- they
+5
+have the icon of the file and I open and it was
+6
+right there, so I was not looking but, you know,
+7
+it was already accessible to me.
+8
+Q. And how many photographs did you then
+9
+scroll through to look at?
+10
+A. Probably 30.
+11
+Q. Okay. And why?
+12
+A.
+Just curiosity, sir.
+13
+Q. So again, you never told anyone other
+14
+than your wife?
+15
+A.
+No.
+16
+Q. Correct?
+17
+A.
+• Yes, correct.
+18
+Q. Of the pictures that you saw, if I
+19
+20
+understood it correctly, some of those were
+pictures of - well, I think you said some of them
+21
+reflected parties or banquets?
+22
+23
+A. Yes.
+Q. I think you described some of the
+24
+pictures gatherings that appeared to be either in
+25
+Russia or Eastern Europe?
+Page 373
+1
+Q. Okay. Were any of the photographs that
+2 were in -- again, I'm talking about Ms. Maxwell's
+3
+4
+computer now, were those photographs of
+individuals who were any of the girls or ladies
+5 that came over to give massages?
+6
+7
+A. No. They stay at the house.
+Q. Okay. So the photographs that you saw on
+8
+• Ms. Maxwell's computer of females in any state of
+9
+undress or at parties or at banquets, those were
+10
+all of individuals who would fly in with Mr.
+11 Epstein at various periods of time that had
+12
+traveled with him?
+13
+A. That's correct.
+14 Q. Okay. Those are the girls that you told
+15 us I think at your last deposition and reaffirmed
+16
+here today, those girls all appeared to be in
+17 their 20's?
+18
+A. Yes, sir.
+19 Q. All right. Now, you were also asked some
+20 questions, a lot of questions about surveillance.
+21
+22
+And if I understood your testimony, and this is
+23
+where it goes back to what do you know, what don't
+you know, what were you speculating on, what did
+24
+you know at the time, what do you know now, at
+25
+least I need you to distinguish that for me so
+Page 372
+Page 374
+1
+A. Yes.
+2
+Q. All right. And then you talked about a
+3
+4
+picture of two girls in the shower that you didn't
+know the girls. Correct?
+5
+A. Yes.
+6
+Q. That's correct?
+7
+A. That's correct.
+8
+Q. All right. And that in all of the
+9
+photographs that you saw the individuals seemed to
+10
+be having a good time?
+11
+• Yes.
+12
+Q. All right. Would it be a correct
+13
+statement that in none of the photographs did
+14
+anyone seem to be distressed or disturbed or show
+15
+any type of negative emotion, at least from what
+16
+you observed?
+17
+A. That's correct.
+18
+MS. EZELL: Objection, form.
+19
+BY MR. CRITTON:
+20
+Q. And in terms of the photographs that you
+21
+did see, were any of the photographs that you saw,
+22
+23
+did they appear -- did they appear to have been of
+women that you had seen fly in with Mr. Epstein on
+24
+his plane?
+25
+A. Yes.
+1
+that I know what you knew at the time, and as
+2
+distinct from what you may have read in the
+3
+newspaper or been told by some lawyer or someone
+4
+else that may not be accurate. Okay?
+5
+A. Yes, sir.
+6
+7
+Q. With regard to the - with regard to
+surveillance equipment, if I understood your
+8
+testimony today is you were completely unaware of
+9
+the existence of any surveillance equipment in the
+10
+house during the 2004/2005 time period that you
+11
+worked there. Is that correct?
+12
+A. Yes.
+13
+Q. And therefore, where it was, what may
+14 have existed, whether it in fact actually did
+exist, whether anyone maintained it, you have no
+16 personal knowledge whatsoever. Is that true?
+17
+A. That's true.
+18
+MR. WILLITS: Object to the form.
+19 BY MR. CRITTON:
+20
+21
+Q. You talked about pictures of two women
+who you saw in the house who were nude, one was
+22
+?
+23
+24
+A. Yes.
+Q. And you knew
+was someone who was in
+25 her 20's?
+27 (Pages 371 to 374)
+
+
+Page 375
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A. Yes.
+Q. All right. And then you saw another
+picture of a Brazilian woman who had traveled or
+flown on the plane before?
+Q. All right. And she also appeared to be a
+woman to you not only in the photograph but from
+your having seen her who appeared to be in her
+A. Yes.
+0. Excuse me. Thank you. You talked about
+computer. Was she hooked into your
+main system?
+A.
+Not to my office in the staff house but
+15. she was hooked into the main house.
+Q. Okay. The same Citrix system?
+A.
+• Yes.
+Q. And you said that
+had pictures of
+women on her computer that you saw. Is that
+correct?
+A.
+Yes.
+Q. Okay. And were those the same types of
+pictures that Ms. Maxwell had, that is, females,
+pictures of females who had traveled in with Mr.
+Epstein from his plane?
+Page 376
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A. This were different pictures.
+Q. Okay. Were any of hers of any of the
+girls who came in on the plane, or the ladies or
+women?
+A. No.
+Q. What were her pictures of?
+A. They were young women modeling, you know.
+I don't remember seeing nudity on
+computer.
+Q. All right. Hers, when I say hers, the
+photographs that
+had on her computer
+were all of individuals who appeared -- or not
+appeared, but were dressed and appeared to be
+modeling?
+A. Yes.
+Q. Would it be a correct statement that none
+of the women that you saw, that is the pictures of
+the women that you saw on
+computer were
+any of the girls, women, whoever came to give
+massages? Is that correct?
+MR. EDWARDS: Object to the form.
+MS. EZELL: Form.
+THE WITNESS: That's correct.
+BY MR. CRITTON:
+Q. You said that
+you thought also had
+Page 377
+1
+2
+3
+4
+5
+names and addresses of - let me start over.
+Strike that.
+If I understood your testimony, you said
+that
+had pictures - start again.
+You said that
+had the names and
+phone numbers of some of the massage girls.
+A. Yes.
+9
+Q. Or at least of the people that you
+thought may have been called to give massages.
+10
+A. Yes.
+11
+MS. EZELL: Form.
+12
+13
+MR. EDWARDS: Form.
+BY MR. CRITTON:
+14
+Q. And was that in the same format that you
+15
+saw on Ms. Maxwell's computer?
+16
+A. No.
+17
+Q. Okay. What occasion would you have been
+18 -- have had to use
+$ computer?
+19
+A. She will instruct me to get some
+20 information from her desk or telephone numbers, so
+21 I will.
+22
+Q. And that's where you would have seen it?
+23 A. Yes.
+24
+Q. I think you testified at your last
+25 deposition, or the start of your deposition that
+Page 378
+1
+the number of women that you remember came over to
+2
+give massages was something eight to ten, twelve,
+3
+4
+I don't remember, what's your best recollection?
+A. Can you repeat that, please?
+5
+Q. Or the women, of different women that you
+7
+knew came over to give massages during the time
+that you worked for Mr. Epstein, '04 to '05,
+during that time period, approximately how many
+9
+women were there?
+10
+MR. EDWARDS: Object to the form.
+THE WITNESS: To give massages?
+12 BY MR. CRITTON:
+13
+Q. Yes, sir.
+14
+A. Fifteen, yeah.
+15
+Q. So something between one and fifteen of
+5 the names you would have seen on M
+7 computer along with a phone numbe
+18
+MR. EDWARDS: Form.
+19
+THE WITNESS: Yes.
+20 BY MR. CRITTON:
+21
+Q. Do you remember how many you would have
+22 seen?
+23
+A. Fifteen.
+24
+Q. Okay. You also told us earlier today
+25 that you saw
+from time to time taking
+28 (Pages 375 to 378)
+
+
+Page 379
+1
+2
+3
+pictures in the dining room and the library.
+A. Yes.
+Q. Photographs.
+A. Yes.
+Q. Okay. Was she taking -- the pictures she
+took were people who were clothed?
+A. Yes.
+8
+Q. And were any of the pictures that she
+9
+took of any of the girls that you ever -- let me
+10
+strike that.
+11
+12
+If I understood your original testimony
+-- I don't want to say original. If I understood
+13
+your testimony from July 29th to what you told us
+14
+15
+today as to the women who did come to give
+16
+massages they'd knock or somehow you would be
+aware that they were at the back door, you would
+17
+punch the security code and lead them into the
+18
+kitchen.
+19
+A. Yes.
+20
+Q. Okay. When you brought them into the
+21
+22
+kitchen you would say, hi, they would say hi back
+to you, or something to that, short greeting,
+23
+you'd offer them water, there was never any
+24
+25
+alcohol in the whole house other than I think you
+said for one person at one time. Is that a fair
+Page 380
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+statement?
+A. Yes.
+Q. All right. You left the kitchen, you
+understood
+came down, and what
+happened thereafter you don't have any personal
+knowledge whatsoever?
+A. That's correct.
+MR. EDWARDS: Form.
+BY MR. CRITTON:
+Q. At some point in time Ms.
+might
+contact you and say pay such and such X amount of
+dollars, she is now getting ready to leave.
+A. Yes.
+Q. That maybe one. Another set of
+circumstances might be you use the word commotion,
+you might hear a commotion, I assume you don't
+mean -- well, let me ask you, when you say
+commotion, do you mean a disturbance, something
+that was seriously like raised voices or merely
+you just heard some people talking?
+A. Conversation of people leaving.
+Q. Okay. Not a commotion in the form of a
+disturbance but a commotion in the sense that you
+heard people talking?
+A. Yes.
+Page 381
+1
+Q. Regular conversation?
+A. Yes.
+3
+Q. And, therefore, you might interject
+4
+yourself back in because you've been asked to pay
+5
+6
+someone or to let them out?
+MR. LANGINO: Form.
+7
+THE WITNESS: Yes, I was called to pay
+8
+them.
+9
+BY MR. CRITTON:
+10
+Q. All right. And when you hear that
+11 conversation that would be another way that you
+12
+would know that the women were leaving?
+113
+A. Yes.
+14
+Q. And sometimes they'd leave without you
+15
+16
+even being involved, if I understood it correctly?
+17
+A. That's correct.
+Q. So, the only places that you ever saw the
+18
+women who came to give massages would be -- of the
+19
+some fifteen women during the time you were there
+20
+would be either when you let them into the house
+21
+22
+and escorted them into the kitchen or as they were
+23
+leaving?
+A. Yes.
+24
+Q. And I think you described one instance
+25
+earlier today is that you may have had
+- in the
+Page 382
+1
+car, in the Suburban?
+A. Yes.
+Q. And that's the only person that you can
+remember having driven any place, that is, of the
+5
+6
+women who were described as having given massages?
+MR. EDWARDS: Objection.
+MS. EZELL: Objection, form.
+THE WITNESS: Sir, I have to clarify
+10
+that. I drove a lot of girls, but I don't
+remember the names associated with the
+11
+faces. But this particular girl r
+12
+others, whatever, I remember driving in
+13
+the Suburban, but I cannot say this was --
+14
+BY MR. CRITTON:
+15
+Q. Let me clarify because what I want to be
+16 clear is, is I do remember you testifying that
+17
+when some of the 20 plus year old models or
+18 females would fly in with Mr. Epstein they might
+19 want to go shopping, they might want to go to the
+20
+store, they may want to go to the drug store, they
+21
+may want to go to the beach, wherever they wanted
+22
+to go and you would drive them.
+23
+A. Yes.
+24
+Q. All right. And then I remember in
+25 response to Ms. Ezell's questions today she asked
+29 (Pages 379 to 382)
+
+
+Page 383
+1
+you about having driven
+h. and you recalled
+2
+having had her in the Suburban specifically.
+3
+A. Yes.
+4
+Q. Do you remember any of the other girls,
+5
+women who came to give massages ever having driven
+6
+them, or is
+. the only one that you remember?
+7
+MR. EDWARDS: Form.
+8
+THE WITNESS: I only remember
+. right
+9
+now for the fact that I was driving by the
+10
+airport and I showed her Mr. Epstein's
+11
+plane.
+12
+BY MR. CRITTON:
+13
+Q. All right. Which really takes me back to
+14
+really where I started with this series of
+15
+questions.
+16
+You saw the girls, the women who came in
+17
+to give the massages, when they came in if you
+18
+were advised or if you heard conversation and you
+saw them you would see them when they left?
+20
+21
+22
+23
+24
+A. Yes.
+Q. And you saw
+,. because she was in the
+Suburban on at least one occasion?
+A. Yes.
+Q. And, therefore, you never saw these
+25 girls, these women who gave the massages in the
+Page 384
+1
+2
+dining room or the library. Would that be a fair
+statement?
+3
+A. That's correct.
+4
+MR. EDWARDS: Form.
+5
+BY MR. CRITTON:
+6
+Q. All right. So, therefore, the pictures
+7
+that you saw
+taking of girls, women,
+8
+either in the dining room or library, those were
+9 other individuals other than those who may have
+10
+given or who came for massages. Is that correct?
+11
+MS. EZELL: Form.
+12
+MR. EDWARDS: Form.
+13
+THE WITNESS: It's confusing, sir,
+14
+because there were a bunch of girls. I
+15
+don't know which one they were but I saw her
+16
+taking pictures of the groups.
+17
+BY MR. CRITTON:
+18
+Q. As to whether they were people who came
+19
+in on the planes or there may have been a massage
+20
+girl or more than one woman who gave a massage,
+21
+you just don't know as you sit here, you'd just be
+22
+23
+speculating. Is that correct?
+MR. EDWARDS: Form.
+24
+THE WITNESS: I don't know.
+25
+BY MR. CRITTON:
+Page 385
+Q. All right. Ms. Ezell asked you about Mr.
+2
+Dershowitz being present in Mr. Epstein's home,
+3
+4
+and I think she asked -- and I think that you said
+Mr. Epstein was a -- and he and Mr. Dershowitz
+5
+were friends?
+6
+A. Yes.
+7
+Q. She also I think asked was Mr. Dershowitz
+8
+ever there when one of the women who gave a
+9
+massage was present in the home?
+10
+11
+A. I don't remember that.
+Q. That's what I want to clear up. Is it
+12
+13
+your testimony that Mr. Dershowitz was there when
+any of the women came to Mr. Epstein's home to
+14
+give a massage?
+15
+A. Yes.
+16
+17
+MR. EDWARDS: Form.
+BY MR. CRITTON:
+18
+Q. As to whether any of those women were
+19
+ever associated with Mr. Dershowitz would it be a
+20
+correct statement that you have absolutely no
+21
+knowledge?
+22
+A. I don't know, sir.
+23
+Q. You don't know?
+24
+A. I don't know, sir.
+25
+MS. EZELL: Form.
+Page 386
+1
+2
+BY MR. CRITTON:
+Q. Okay. Were you in any way attempting in
+• I D A
+10 00
+your response to Ms. Ezell to imply that Mr.
+Dershowitz had a massage by one of these young
+ladies?
+A. I don't know, sir.
+Q. You have no knowledge?
+A. No, sir.
+Q. And you certainly weren't implying that
+10
+that occurred, you just have no knowledge.
+11
+Correct?
+12
+MR. EDWARDS: Form.
+13
+14
+THE WITNESS: I don't know.
+BY MR. CRITTON:
+15
+Q. Sorry?
+16
+A. I don't know.
+17
+Q. I think in response to one of Ms. Ezell's
+18 questions you responded that - let me ask it this
+19 way.
+20
+You never saw Mr. Epstein ever take
+21
+photographs of anyone. Would that be a correct
+22 statement?
+23
+A. Yes
+24
+Q. Would it be a correct statement you never
+25 saw Mr. Epstein initiate a phone call to anyone?
+30 (Pages 383 to 386)
+
+
+Page 387
+1
+2
+A. To place a phone call?
+Q. Yeah. Did you ever see him place a phone
+3
+4
+A. Yes.
+5
+6
+Q. If in fact, maybe it was this way, is
+7
+that you never saw him call someone to schedule a
+massage appointment. Correct?
+8
+A. That's correct.
+9
+Q. I think you said that Ms.
+i told you
+10 that Mr. Epstein would take photographs. Did I
+11
+understand you correctly?
+12
+A. I'm sorry, can you repeat that?
+13
+Q. Did Ms.
+ever tell you that Mr.
+14
+Epstein took a photograph of anyone?
+15
+16
+A. No, she said to me Mr. Epstein is like
+he's an amateur photographer.
+17
+Q. Okay. I may have misunderstood you then.
+18 Let me clarify that testimony.
+19
+It's your testimony that Ms.
+i told
+20
+you that Mr. Epstein is an amateur photographer?
+21
+A. Yes.
+22
+23
+Q. She never told you that - or let me
+strike that.
+24
+Is it correct that she never told you
+25
+that Mr. Epstein took photographs of any of the
+Page 388
+1
+girls, women, who came over to give him a massage?
+2
+A. That's correct.
+3
+4
+Q. All right. Mr. Rodriguez, other than Mr.
+Epstein I think you told us you had worked for a
+5
+lady named Ms. Hammond?
+6
+A. Yes.
+7
+Q. And you had worked for a gentleman --
+8
+A. Sidney Bowman.
+9
+10
+Q. Is he the gentleman from Fisher Island?
+A. No, Arturo Torres.
+11
+Q. All right. In addition to Ms. Hammond up
+12
+in Palm Beach you worked for other individuals as
+13
+well?
+14
+A. I did it part-time but I don't have her
+15
+name right now, sir.
+16
+Q. During your career as a -- let me strike
+17
+that.
+18
+19
+Had you worked other than those places,
+Mr. Arturo --
+20
+A. Arturo Torres, yes.
+21
+Q. Arturo Torres, Ms. Hammond, the other
+22
+individual you can't remember, and Mr. Epstein,
+23
+have you worked for other individuals as an estate
+24
+manager or general house manager?
+25
+A. No, sir.
+Page 389
+1
+Q. Of the time that you've done that
+approximately how many years does that include in
+your working life?
+5
+A. Eight years, ten years.
+6
+Q. All right. And have you worked for --
+have you been in other circumstances where you
+7 have worked around - well, let me step back.
+8
+With all of the individuals that you
+9 mentioned, estate manager, house manager, has this
+10 been for individuals who have or at least appear
+11 to have substantial wealth?
+12
+A. Yes.
+13
+Q. And as part of your duties, or not duties
+14 but as part of being a house manager or general
+15
+16
+manager for an estate do you interact with other
+estate managers?
+17
+A. Yes.
+18
+19
+Q. And do you assist each other from time to
+time if someone needs help?
+20
+A. That's correct.
+21
+22
+Q. And I assume that you've been in other
+estates in Palm Beach and probably in Fort
+23
+Lauderdale and other locations?
+24
+A. Yes.
+25
+Q. As part of during your working career did
+Page 390
+1
+you ever work in restaurant or a personal services
+2 type business where you would provide like
+3
+catering or something like that to other wealthy
+4
+individuals?
+5 A. I did.
+6
+Q. Give us a little of your background if
+7 you could then, Mr. Rodriguez.
+8
+A. I work in Long Island, Montauk Lake Club
+9 and Marina, a very exclusive country club where
+10 Mr. Nixon used to spend his summers, Richard
+Nixon. I worked for Leona Helmsley in New York.
+12 Very demanding lady. And then Mr. Torres in Texas
+13 in his ranch and as well as Fisher Island. And I
+14
+was a general manager of one of his restaurants in
+15
+San Antonio, Texas. This is the most high profile
+16
+people that I worked for.
+17
+Q. Okay. When you worked for Ms. Helmsley,
+18
+• Leona Helmsley, she used to have the Helmsley
+19
+Palace and she with her husband, Harry Helmsley, I
+20
+think they owned a number of real estate in
+21 addition to hotel properties.
+22
+A. That's correct.
+23
+Q. When you would -- I think you described
+24 her as a demanding person?
+A. Yes.
+31 (Pages 387 to 390)
+
+
+Page 391
+Q. All right. In terms of these wealthy
+people that you've worked for, these individuals,
+do they all have, that is at least in terms of Mr.
+Epstein, the way that his household was managed,
+was it similar to other set of circumstances that
+you've been involved with?
+7
+MR. HOROWITZ: Object to form.
+8
+9
+THE WITNESS: They have a common ground,
+10
+yes.
+BY MR. CRITTON:
+11
+Q. All right. And in terms of you talked
+12
+about Mr. Epstein that there was some sort of a
+13
+manual or a procedure book with regard to his
+14
+house.
+15
+A.
+House manual, yes.
+16
+Q. A house manual. Did other houses have
+17
+house manuals as well? Is that reasonably - I
+18
+19
+mean not common but it's something that you've
+seen before?
+20
+21
+MR. EDWARDS: Form.
+THE WITNESS: I know a lot of houses do
+22
+23
+but that was the only estate that we have a
+house manual.
+24
+BY MR. CRITTON:
+25
+Q. And other individuals like where you've
+Page 392
+1
+worked similar to Mr. Epstein -- now, Mr. Epstein
+2
+was single?
+3
+A. Yes.
+4
+Q. All right. And him having a lot of -- or
+5
+bringing a lot of attractive women and other
+6
+people to his house, I assume that didn't offend
+7
+you in any way?
+8
+MR. EDWARDS: Object to the form.
+9
+THE WITNESS: No, sir.
+10 BY MR. CRITTON:
+11
+Q. At least based upon your experience in
+12 dealing with other individuals either of some
+13
+notoriety like Ms. Helmsley or when you said the
+14
+club that you worked up is in Montauk -
+15
+A. Montauk Lake Club and Marina.
+16
+17
+Q. Right. You ran into separate and apart
+from Richard Nixon were there a lot of people,
+18
+corporate people, business people?
+19
+A. Yes.
+20
+Q. People of substantial resources and
+21
+22
+wealth?
+A. Yes.
+23
+Q. Have you found at least in your
+24
+experience that most of those people are pretty
+25
+discreet about -- when I say discreet, private
+Page 393
+1
+2
+about what they do?
+MR. HOROWITZ: Object to the form.
+4
+THE WITNESS: Yes.
+BY MR. CRITTON:
+Q. And have you worked at other locations,
+6
+7
+that is, in the other houses that you've worked
+where they have massage tables?
+8
+A. Yes.
+9
+10
+Q. And in those other locations where they
+had a massage table, were they similar to the
+11
+12
+massage table that was in Mr. Epstein's home?
+A. Yes, sir.
+13
+Q. All right. Almost same make and model?
+14
+A. Same type, yes.
+15
+16
+Q. And did other individuals in houses that
+you worked at and other places where you helped
+17
+out other estate managers, would those individuals
+18 have massages from time to time?
+19
+A. Yes.
+20
+Q. So having a massage or a massage table in
+21
+someone's house that you might - that lives in
+22
+Palm Beach or Montauk or New York or something,
+23 would you consider that unusual?
+MR. HOROWITZ: Form.
+25
+THE WITNESS: No.
+Page 394
+1
+BY MR. CRITTON:
+2
+3
+Q. I think you told me at least in Mr.
+Epstein's home other than for one guest he didn't
+4
+have any type of alcohol in the house. Is that
+5 correct?
+A. That's correct.
+7
+Q. Was that basically you understood that
+8 that was one of the policies and procedure, no
+9 alcohol in the house?
+10
+A. Yes.
+11
+Q. And did you ever see any type of illegal
+12 or inappropriate drugs?
+13
+A. No, sir.
+14
+Q. And was that another policy or procedure,
+15 absolutely no drugs of any kind?
+16
+17
+A. No smoking in the house.
+Q. All right. So no drugs, no smoking, no
+18 alcohol?
+19
+A. Yes.
+20
+Q. Was that pretty typical for other Palm
+21 Beach places that you were familiar with?
+22 A. No.
+23
+Q. All right. And other places you'd always
+24 find alcohol?
+25
+A. Yes.
+32 (Pages 391 to 394)
+
+
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+Page 395
+Q. All right. And you might find drugs?
+A.
+Yes.
+Q. And some pretty wild parties?
+A. Yes.
+Q. Now, with regard to the women who came to
+give massages, of those women, of those
+approximately fifteen that you described, how many
+of them came more than one -- more than one
+occasion?
+MR. HOROWITZ: Form.
+THE WITNESS: I'd say more than half.
+BY MR. CRITTON:
+Q. So maybe seven, eight, nine, ten?
+A. Yes.
+Q. Of those people that came on -- of those
+seven to ten that came on more than one occasion,
+did those individuals come on many occasions?
+A. Yes.
+Q. And as to the women who were -- who you
+understood were coming to give the massages --
+MR. EDWARDS: Form.
+MR. CRITTON: I'm not done yet.
+THE VIDEOGRAPHER: I need to go off the
+record for a second.
+(Thereupon, an interruption was had.)
+Page 396
+THE VIDEOGRAPHER: We're back on the
+record.
+BY MR. CRITTON:
+Q. Mr. Rodriguez, I want to turn to the --.
+stay with the women who came to give or at least
+were called to give the massages.
+7
+You were shown a number of message pads,
+8
+I think Mr. Mermelstein who represents a number of
+9
+-- or at least certainly Jane Doe 2 and some
+10
+others, you were identified or shown a bunch of
+11
+message pads that had I think in most instances
+12 your initials,
+.. Do you recall that?
+13
+A.
+• Yes, I do.
+14
+Q. I think one of the individuals that you
+15
+identified that called often was
+?
+16
+A. Yes.
+17
+Q. Which is one of Mr. Edwards' clients.
+18
+19
+This lady called on a regular basis, or
+20
+at least from looking at your pad she would call
+on a pretty regular basis. Is that true?
+21
+A. Yes.
+22
+23
+Q. And she and others who are reflected on
+those message pads, they were calling to come to
+24
+give massages. Correct?
+25
+A. Yes.
+Page 397
+MR. EDWARDS: Object to the form.
+BY MR. CRITTON:
+Q. And I don't know whether he asked, do you
+4
+remember a person named
+.?
+5
+A. Yes.
+6
+Q. And would she call from time to time
+7
+asking if she could come to give a massage just
+8
+like?
+9
+MR. EDWARDS: Object to the form.
+10
+THE WITNESS: Yes.
+11 BY MR. CRITTON:
+12
+13
+Q. So at least those two individuals, they
+were overtly, that is, they were asking whether
+14 they could come to give Mr. Epstein a massage.
+15
+Correct?
+16
+A. They will call and they will say I need
+17 to talk to
+• and
+fifteen minutes later
+18 will tell, Alfredo, we're going to have a massage
+with so and so.
+20
+Q. So either
+, ОГ
+would call to ask
+21 if they could come and then a massage would be set
+then they would show up?
+23
+A. That's correct, sir.
+24 Q. Okay. And from time to time they would
+25 bring other people as well?
+Page 398
+1
+A. That's correct.
+Q. Both
+• and ?
+3
+A. Yes.
+4
+Q. Of the females that - the women that
+5
+came to the house, did you ever see anyone force
+6
+7
+any of these women onto the property?
+A. No, sir.
+8
+Q. Did you ever see anyone force them into
+9 the house?
+10
+A. No.
+11
+Q. Did you ever see anyone force them into
+12 the kitchen?
+13
+14
+Q. Did you ever use any force, any type of
+15 intimidation or coercion to bring them into the
+16 house and get them into the kitchen?
+17
+A. No, sir.
+18
+Q. Did you ever observe
+using any
+19 force or intimidation or coercion --
+20
+A. No, I did not.
+21
+Q. - with any of these individuals?
+22
+A. I did not.
+23
+MR. EDWARDS: Object to the form.
+24 BY MR. EDWARDS:
+25
+Q. Did - let me use the initials
+33 (Pages 395 to 398)
+
+
+Page 399
+1
+2
+3
+4
+5
+that way it will show up correctly.
+Did
+ever use from what you saw, did
+she ever use any force or coercion or intimidation
+with any of the women that she brought to the
+house?
+6
+MR. HOROWITZ: Form.
+7
+MR. EDWARDS: Object to the form.
+8
+9
+THE WITNESS: No, sir.
+BY MR. CRITTON:
+10
+Q. Okay. I'm just talking about what you
+11
+observed during the time. And you know what I
+12 mean by force?
+13
+A. Yes.
+14
+Q. You know what I mean by intimidation?
+15
+A. Yes.
+16
+17
+Q. Could to be verbal intimidation or
+coercion, either verbally or using some form of
+18 her body, or their bodies.
+19
+A. Yeah, I understand that.
+20
+MR. EDWARDS: Form.
+21
+MR. HOROWITZ: Form.
+22
+23
+MS. EZELL: Objection, form.
+BY MR. CRITTON:
+24
+Q. When
+• brought individuals to the
+25
+house, did you ever see her use any force or
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 400
+intimidation or coercion from what you could
+observe with those women who had come to give a
+massage?
+A. No.
+MR. EDWARDS: Form.
+MR. HOROWITZ: Form.
+MS. EZELL: Form.
+BY MR. CRITTON:
+Q. With any of the fifteen women that you
+observed who came to the home to give massages
+during the time period '04 through I think you
+said February of '05, the time period I think was
+it August, Mr. Rodriguez --
+A. August.
+Q. - August of '04 through February of '05?
+• March of '05.
+Q. Through the beginning of March '05?
+A. Yes.
+Q. Okay. That's the time period I'm
+focussing on.
+Of the approximately fifteen women that
+you came to see to give massages that you let in
+the back door after punching the security code,
+did any of them ever appear to be scared?
+A. No.
+Page 401
+Q. Did any of them ever appear to be
+frightened?
+3
+MR. HOROWITZ: Form.
+4
+THE WITNESS: No.
+5
+6
+BY MR. CRITTON:
+Q. Did any of the women appear to be
+7 fearful?
+8
+A. No.
+9
+Q. Did any of them appear to be
+10
+11
+uncomfortable in coming into the house?
+MR. EDWARDS: Form.
+12
+13
+THE WITNESS: No.
+BY MR. CRITTON:
+14
+Q. At any time did any of them express to
+15 you verbally that they were in fear when they came
+16
+into the house?
+17
+A. No, sir.
+18
+Q. Did any one of the fifteen girls that
+came to the back door, then into the kitchen, and
+20 prior to your leaving them in the kitchen say, Mr.
+21 Rodriguez, or Alfredo, or sir, could you get me
+22 out of here?
+23
+A. No, sir.
+24
+Q. Did any of them tell you verbally that
+25
+they were uncomfortable?
+Page 402
+A. No.
+Q. Did anyone say help me or I'm scared?
+A. No.
+Q. Did all of them appear to be at least
+when they came to the back door in a reasonably
+good mood?
+A. Yes.
+8
+Q. They all appeared to be happy?
+9
+10
+A. Yes.
+Q. Smile, I'd say interact with you verbally
+11
+in your greetings?
+12
+A. That's correct.
+13
+Q. Did any one of the fifteen girls that you
+14
+observed during the August '04 through March 2005
+15
+16
+time period from your personal observation appear
+to be there -- appear to be at the Epstein home
+17
+not voluntarily?
+18
+MR. EDWARDS: Object to the form.
+19
+20
+MR. HOROWITZ: Object to the form.
+THE WITNESS: No.
+21 BY MR. CRITTON:
+22
+Q. Did any one of the fifteen women who came
+23 to give the massage ever tell you that they had
+24 been forced to come to the house or coerced into
+25 coming to the house?
+34 (Pages 399 to 402)
+
+
+Page 403
+Page 405
+1
+A. No.
+1
+them stop and have anything to eat or did you
+MR. EDWARDS: Form.
+2
+always see them at the end, that is they're ready
+3
+BY MR. CRITTON:
+3
+to go?
+Q. For those women -- I think I need - let
+4
+A. I didn't know, they came from downstairs,
+me strike that.
+5
+they went to the kitchen, but I didn't know they
+On some occasions you'd see the women
+6
+were there because I was in the guest house.
+come down from upstairs because you would either
+Q. Okay, that's my question. You only
+8
+9
+let them out of the house or you might give them
+10
+an envelope that had money in it. Is that
+9
+observed them either if you heard conversation or
+had called you and said would you pay such
+correct?
+10
+and such?
+11
+A. Yes.
+11
+A. Yes.
+12
+13
+Q. Did any of those -- Mr. Edwards asked you
+12
+some questions -- I think it was Mr. Edwards,
+13
+Q. At which time you would give them the
+envelope with money?
+14
+15
+whether they had sat down and had anything to eat,
+14
+A. Yes.
+16
+whether they had cereal or anything like that.
+15
+A. Yes.
+16
+Q. In that set of circumstances they were on
+their way basically to leave?
+17
+Q. Did you ever observe any of those women
+18 before they went upstairs eating anything at the
+17
+A. Yes.
+18
+Q. When you saw them leave did any of them
+19 house?
+20
+A. Sometimes.
+21
+Q. And I think he used -- he meaning Mr.
+22 Edwards, used cereal and ice cream.
+A. Yes.
+24
+Q. And he said, if I recall from the last
+25 deposition, kids like ice cream.
+to be scared?
+22
+A. No, sir.
+23
+Q. Did any girls, women ever appear to have
+24 been injured in any way?
+25
+MR. EDWARDS: Form.
+Page 404
+Page 406
+1
+A. Yes.
+THE WITNESS: No, sir.
+2
+Q. Do you remember him asking you that?
+2
+3
+BY MR. CRITTON:
+A. Yes.
+Q. Did anyone appear to be in shock?
+4
+Q. Are you familiar that teenagers like ice
+A. No, sir.
+5
+cream?
+Q. Was anyone ever crying?
+6
+A. Yes.
+A. No, sir.
+7
+Q. Are you familiar that people who are 20
+Q. Was anyone disheveled or appeared to be
+8
+and 30 years old like ice cream?
+8
+unhappy?
+9
+A. Yes.
+9
+A. No, sir.
+10
+11
+2. Are you tamiliar that older people, eve
+10
+Q. Did all of them appear, that is the ones
+ur age, Mr. Rodriguez, like ice cream too
+11 that you saw leave the house that you had an
+12
+A. Yes.
+12 opportunity to observe during that time period,
+13
+Q. Okay. And when the individuals would sit
+13 did they appear to be approximately the same
+14
+there, and that is these women who would come over 14 personality, same demeanor that they had had when
+15
+16
+to give a massage and they would -- you would
+15 they came into the house?
+observe them eating, did they appear to be
+16
+MR. HOROWITZ: Form.
+17
+comfortable?
+17
+THE WITNESS: Yes.
+18
+A. Yes.
+19
+18
+• BY MR. CRITTON:
+MR. HOROWITZ: Form.
+19
+Q. Did anyone ever tell you when they came
+20
+BY MR. CRITTON:
+21
+Q. Did they appear to be interacting with
+20
+down the stairs that they had been injured?
+21
+A. No.
+22
+23
+either you or the chef?
+22
+Q. I'm talking about the young lady, the
+A. Yes.
+23
+women who had given the massages that you saw
+24
+Q. When any of those women would come over
+24
+actually leave the house, that is you had some
+25 to give massage came downstairs, did you ever see
+25 interaction with, either some interaction as they
+35 (Pages 403 to 406)
+
+
+Page 407
+1
+were leaving the house, did anyone ever tell you
+2
+that they had been injured?
+3
+A. No, sir.
+4
+Q. Did they ever tell you that they had been
+5
+forced to do something against their will?
+6
+A. No.
+7
+Q. Did they ever tell you that they had been
+8
+forced to do something inappropriate?
+9
+A. No.
+10
+Q. Did they ever tell you that they had been
+11 assaulted in any way?
+12
+A. No.
+13
+14
+Q. Did they ever tell you that they had been
+inappropriately touched?
+15
+A. No.
+16
+MR. HOROWITZ: Form. This is a
+17
+cumulative. He's already told you the
+18
+limited contact he had. This is totally
+19
+20
+inappropriate line of questions.
+MR. CRITTON: Is that a form objection?
+21
+MR. HOROWITZ: You're exceeding the scope
+22
+of the direct because nobody asked him --
+23
+MR. CRITTON: Form, you get form in
+24
+federal court, that's what you get. Give me
+25
+your form.
+Page 408
+1
+MR. HOROWITZ: Form, cumulative.
+MR. CRITTON: Great. Why don't you let
+me finish the question and then you can
+4
+object to it.
+Could you give me back what my last
+7
+question was, please?
+(Thereupon, a portion of the record was
+8
+read by the reporter.)
+9
+THE WITNESS: No.
+10
+BY MR. CRITTON:
+11
+Q. Did they ever tell you that they had been
+12
+sexually assaulted in any way?
+13
+14
+MR. EDWARDS: Form.
+MR. HOROWITZ: Form.
+15
+THE WITNESS: No.
+16
+BY MR. CRITTON:
+17
+Q. I'm sorry?
+18
+A. No.
+19
+Q. At any time did you hear anyone -- strike
+20 that.
+21
+22
+23
+24
+25
+As to the women who came to give a
+massage, did you ever hear anyone scream?
+A. No, sir.
+Q. Did you ever hear anyone cry out what
+sounded like to you help?
+Page 409
+1
+2
+3
+MR. EDWARDS: Form.
+THE WITNESS: No.
+BY MR. CRITTON:
+Q. Did you ever hear anyone yell rape or
+assault or battery?
+MR. HOROWITZ: Form.
+7
+8
+THE WITNESS: No.
+BY MR. CRITTON:
+9
+Q. Did you ever hear anyone yell out in
+10
+anger?
+A. No.
+12
+Q. You've gone online, Mr. Rodriguez, and
+13
+looked at various articles or postings that have
+14 been made regarding these cases. Is that a fair
+15 statement?
+16
+A. I'm sorry?
+17
+Q. If I understood your testimony from July
+18 29th and a little bit today, is that you've gone
+19 online and read some articles and/or what the
+20 police report may have said, that is, you've read
+21 information that you've -- about these lawsuits
+22
+after the time that you left Mr. Epstein's
+23
+employment.
+24
+A. Yes.
+25
+Q. Correct?
+Page 410
+1
+2
+A. Yes.
+Q. And, therefore, you have at least seen
+certain allegations and what people say occurred,
+or at least their recitation of what may have
+5
+occurred at Mr. Epstein's home.
+A. Yes.
+7
+Q. You have no personal knowledge one way or
+• the other.
+9
+10
+MR. HOROWITZ: Object to the form.
+11
+MR. EDWARDS: Form.
+BY MR. CRITTON:
+12
+Q. Correct?
+13
+A. That's correct.
+Q. Are you also aware that the individuals
+15 who have filed lawsuits want in some instance
+millions of dollars?
+17
+A. Yes.
+18
+Q. Okay. Are you aware that some of them
+19 are now claiming that they were sexually
+20
+assaulted?
+21
+A. Yes.
+22
+Q. And battered?
+23
+A. Yes.
+24
+Q. And you have no information, no personal
+25 knowledge in that regard. Is that true?
+36 (Pages 407 to 410)
+
+
+A. Yes.
+MR. EDWARDS: Form.
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+20
+21
+22
+23
+24
+25
+MR. HOROWITZ: Form.
+BY MR. CRITTON:
+Q. All right. Were you aware of the
+backgrounds of any of these women who came over to
+give massages?
+MR. HOROWITZ: Form.
+THE WITNESS: No, sir.
+BY MR. CRITTON:
+Q. Well, have you -- did any one of the
+females who ever came to give massages, did they
+ever tell you that they were prostitutes?
+A. No, sir.
+Q. Did they ever tell you that they had been
+lead into a life of prostitution?
+MR. HOROWITZ: Form.
+THE WITNESS: No.
+19 BY MR. CRITTON:
+Q. Did they ever tell you about their family
+life, whether it involved prostitution, abuse,
+prior posttraumatic stress syndrome, drugs,
+alcohol, abuse by individuals, physical abuse as
+well as verbal abuse?
+A. No, they didn't tell me.
+Page 412
+1
+2
+3
+Q. And, obviously, you have no personal
+knowledge one way or the other -
+A. No, sir.
+Q. - with regard to what their backgrounds
+5
+6
+were before they ever met or came in contact with
+Mr. Epstein?
+A. No, sir.
+8
+Q. Did any person, female, who came to give
+9
+a massage at the Epstein home, did anyone ever
+10
+come downstairs and say, Mr. Rodriguez, or sir,
+11
+call the police?
+12
+MR. EDWARDS: Form.
+13
+MR. HOROWITZ: Form.
+14
+THE WITNESS: No, sir.
+15
+BY MR. CRITTON:
+16
+17
+Q. I think you said on one occasion you saw
+someone parked in a vehicle inside the gate that
+18
+19
+you didn't recognize.
+A. Exactly.
+20
+Q. You called the police?
+21
+A. Yes, I did.
+22
+Q. Did you go to the police or you called
+23
+24
+the police and they came?
+A. I went to the police department.
+25
+Q. So how did you -- did you actually leave
+Page 411
+Page 413
+1 the property in your car?
+2
+3
+A. I was pulling over from Publix so I
+4
+turned around and I went to the police and say-
+Q. Okay. You were coming back to the home
+5
+when you saw that car there?
+6
+A. Exactly.
+7
+Q. And they sent -- they, the police, sent a
+8
+police car with you to come there?
+9
+10
+A. Yes.
+Q. Did you and the police officer walk up to
+11 the car?
+12
+A. The police went first.
+13
+Q. All right. And if I understand that,
+14 that was in January of '05?
+15
+A. Yes.
+16
+Q. And when you did that then did you follow
+17 behind the police officer to see who was in the
+18 car?
+19
+A. Yes.
+20
+Q. And then you recognized that as?
+21
+A. Yes.
+22
+23
+Q. And
+.. said she had come back or was
+there to get some money?
+24
+A. Yes.
+25
+Q. And did you in fact give her money?
+Page 414
+2
+4
+6
+7
+8
+9
+10
+11
+A. Yes, I did.
+Q. And I think you said you told the police
+officer you recognized her?
+A. Yes.
+Q. Did you have to get permission to pay her
+or did you just pay her?
+A. No, because
+told me already but I
+forgot she was going to be that late, so that was
+my concern in calling the police.
+Q. Okay. And that person who came, do you
+have any idea what her age was at that time?
+12
+13
+Q. Right, January of '08.
+14
+A. No, no.
+15
+16
+Q. I'm sorry, January of '05.
+A. No.
+17
+Q. You mentioned some conversations that you
+18 had had with
+who was I think she was one
+• of the house -- the main housekeeper.
+20
+A. Yes.
+21 Q. And
+told you a number of thoughts
+22 that sheead. Is that correct?
+A. Yes.
+Q. And as to
+what she told you about
+25 -- let me strike that.
+37 (Pages 411 to 414)
+
+
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 415
+Page 417
+I think you told us, you were asked
+A. To bring the pictures from my computer?
+questions about sex toys, I think you certainly
+Q. Let me rephrase the question. I thought
+described the back massagers. Correct?
+what you said last time was that as to the
+A. Yes.
+pictures that you did see of naked women - of a
+Q. I think you said the only sex toys that
+5
+naked woman or naked women on the computer, that
+you ever saw were in the armoire at the end of Mr.
+6 you've looked at those photographs through your
+Epstein's bed.
+7 computer.
+A. Yes.
+8
+A. No.
+Q. Okay. And whatever other sex toys that
+9
+Q. Okay. Then I may have misunderstood you.
+to which there was a reference, that's something
+10 Was your reference to Ms. Maxwell's computer that
+that
+• told you. Is that correct?
+11 you made at the last deposition?
+A.
+That's correct.
+12
+A. Yes.
+Q. You were asked at the last deposition, I
+13 Q. Okay. Your computer that you had either
+don't remember who asked the question, but whether
+14 in the staff house or that you --
+you had ever seen pornography on any computer. I
+15
+A. Didn't access.
+think one of your responses was you saw some
+16
+Q. You couldn't access those files?
+photos of a naked woman who appeared to you to be 17
+A. That's correct.
+a model.
+18
+Q. All right, now I'm with you. So the
+A. Yes.
+19
+photographs you've talked of the nude individuals,
+Q. Okay. Do you consider every photograph,
+20
+or the naked women, were the photographs that
+picture, painting of a naked nude woman to be
+21
+we've already talked about with both, l.e., in
+pornography?
+22
+Ms. Maxwell's computer?
+MR. HOROWITZ: Form.
+MS. EZELL: Objection, form.
+23
+A. Yes.
+THE WITNESS: I consider -- well, if it's
+24
+Q. Thank you for clearing that up.
+25
+I'm going to ask you to assume that/
+Page 416
+Page 418
+a frontal picture it's pornography, I will
+1
+who you've described as having come to Mr.
+look at my way.
+2
+Epstein's house on three or four times a week for
+BY MR. CRITTON:
+3
+a period of time, one of her claims in this case
+Q. In your view?
+4
+A.
+Yes.
+5
+is that she has been emotionally traumatized by
+Q. So if you looked at -- I don't remember
+6
+her contact with Mr. Epstein. Just assume that to
+be true for purposes of this question.
+whether Playboy still has -- say a Playboy that
+7
+Did you ever observe any what you would
+has a frontal nudity shot of a woman, you would in
+8
+have seen as emotional trauma or any type of
+essence say that Playboy is selling pornography?
+9
+A. Yes.
+10
+disturbance with
+• on the many times she came
+to your house?
+Q. Therefore, every person who buys a
+11
+MR. EDWARDS: Form.
+Playboy that has over the last umpteen tens of
+12
+THE WITNESS: I didn't see any.
+years that has a frontal picture of a woman in the
+nude would be purchasing pornography whether it's
+13
+BY MR. CRITTON:
+from CVS, or Walgreens, or Eckerd as they existed,
+14
+Q. Does it make sense to you that a person
+15 who claims emotional trauma would continue to come
+or any grocery store that sells them?
+16 back to the house, does that make sense to you,
+A.
+Yes.
+17 sir?
+MS. EZELL: Objection, form.
+18
+MR. EDWARDS: Form.
+MR. EDWARDS: Form.
+19
+MR. HOROWITZ: Form.
+20
+MR. HOROWITZ: Form.
+MR. WILLITS: Object to the form of the
+BY MR. CRITTON:
+21
+question.
+Q. The photographs -- I'm sorry, the
+22
+THE WITNESS: I'm not a psychologist.
+pictures that you saw in the computer, I think you
+were able to draw those up or bring those up from
+23
+MR. EDWARDS: Can you state your answer,
+24
+I didn't hear it?
+your own computer.
+25
+THE WITNESS: Yeah, I'm not a
+38 (Pages 415 to 418)
+
+
+Page 419
+Page 421
+1
+2
+psychologist, I don't know.
+MR. CRITTON: I have no further
+questions.
+REDIRECT EXAMINATION
+BY MR. EDWARDS:
+6
+7
+Q. Mr. Rodriguez, I don't know if we covered
+this last time, I think that we did not, but can
+8
+9
+you tell us during the period of time when you
+10
+worked at that house at El Brillo, Mr. Epstein's,
+what cars did he own or were in the driveway?
+11
+We have two Suburbans, two Mercedes 600,
+12 and a Cobra, and a motorcycle.
+13
+Q. And which, if any, did he drive?
+14
+• He preferred the Mercedes or any of the
+15
+Suburbans.
+16
+Q. All right. Do you know where he owns
+17 homes?
+18
+A. Yes.
+19
+Q. Where?
+20
+21
+MR. CRITTON: Form.
+22
+THE WITNESS: Paris, New York City, El
+Brillo, Saint James Island -- I'm sorry, an
+23
+Island in the Caribbean, and a ranch in New
+24
+Mexico.
+25
+BY MR. EDWARDS:
+Q. What's the address?
+3
+A. 22 Foch Avenue, Paris. F-O-C-H.
+Q. Okay. Do you know a telephone number for
+Balsone?
+5
+6
+A. No, I don't remember, sir.
+7
+Q. All right. How did it come up that you
+talked to him about whether or not Mr. Epstein had
+8
+massages at that house?
+9
+A. He came on two occasions and stay with me
+10
+for a week because Mr. Epstein wanted me to get
+11
+12
+into his style of running the house, and he was
+13
+good enough to give me some inside information,
+what he likes and doesn't like, so he told me the
+14
+same thing was in Paris.
+15
+16
+Q. And I think that you described Mr.
+Epstein usually had about two massages a day, or
+17 at least we were calling them massages.
+18
+A. Yes, sir.
+MR. CRITTON: Form.
+20 BY MR. EDWARDS:
+21
+Q. And did Mr. Balsone describe it in a
+22
+similar fashion --
+23
+A. Yes.
+24
+Q. - in Paris?
+25
+And did he also tell you that the girls
+Page 420
+Page 422
+1
+2
+3
+Q. Have you been to any of the other
+properties?
+A. No.
+Q. Do you know the house managers at any of
+5
+the other properties?
+A.
+7
+• Yes.
+Q. And who are they?
+8
+A. Balsone in Paris, good friend of mine
+9
+from Brazil. And the people in New York give me
+10
+the briefing when I came aboard. There is a
+11
+couple from the Philippines. And I talked to the
+12
+couple that used to own the Island -- I mean who
+13
+used to manage the Island, a couple from South
+14
+African. Balsone was closer to me.
+15
+Q. Have you talked to Balsone about whether
+16
+or not Mr. Epstein has massages when he is at that
+17
+place?
+18
+A. Yes, I did.
+19
+Q. And what did he say about that?
+20
+A. That he had a lot of massages over there
+21
+22
+too.
+23
+24
+25
+MR. CRITTON: Mr. Balsone was which one?
+THE WITNESS: Baslone was the house
+manager of Paris, 22 Foch Avenue.
+BY MR. EDWARDS:
+1
+were very young in age that he was receiving these
+2
+massages from?
+3
+MR. CRITTON: Form.
+THE WITNESS: Yes.
+5
+6
+BY MR. EDWARDS:
+Q. Did he indicate whether or not -- or how
+7
+old these girls were?
+A. No, he didn't told me.
+9
+Q. Just that the age group was similar to
+10
+the age group that he was interested in in Palm
+11
+Beach?
+12
+13
+MR. EDWARDS: Form.
+THE WITNESS: Yes.
+14
+BY MR. EDWARDS:
+15
+Q. And did you talk to any of the house
+16
+managers in New York?
+17
+A. No.
+18
+Q. Who was the house manager in New York at
+19 the time when you were the house manager at El
+Brillo?
+21
+A. His nickname was Jo-Jo, but I don't
+22 remember. Jo-Jo and his wife, but I don't
+23 remember his name, sir.
+24
+Q. Do you know whether Mr. Epstein would
+25 have massages when he was in New York at his New
+39 (Pages 419 to 422)
+
+
+Page 423
+York house?
+3
+4
+A. He will have massages.
+MR. CRITTON: Form.
+BY MR. EDWARDS:
+Q. And are we still talking about a habit of
+two a day?
+7
+MR. CRITTON: Form.
+8
+THE WITNESS: I don't know that.
+9
+BY MR. EDWARDS:
+10
+Q. Okay. So for the time period when you
+11
+have been familiar with Mr. Epstein and known his
+12
+13
+habits, is it fair to say that he would have
+roughly two girls a day in that same age group
+14
+wherever he was?
+15
+A. Yes.
+16
+MR. CRITTON: Form.
+17
+BY MR. EDWARDS:
+18
+Q. All right. And have you talked to
+19
+anybody that has given you similar information
+20
+from his Island home?
+21
+A. No.
+22
+23
+Q. Do you know any of the girls that have
+been over to his Island?
+24
+A. Yes.
+25
+Q. And who are they?
+Page 425
+Q. And is your understanding that Mr.
+2
+Epstein was intimate with any of those girls?
+4
+MR. CRITTON: Form.
+THE WITNESS: Yes.
+BY MR. EDWARDS:
+Q. With all of them?
+MR. CRITTON: Form.
+8
+THE WITNESS: Yes.
+9 BY MR. EDWARDS:
+10
+Q. With
+as well?
+11
+A. Yes.
+12
+MR. CRITTON: Form.
+13 BY MR. EDWARDS:
+Q. With!
+15
+A. Yes.
+16
+MR. CRITTON: Form.
+17 BY MR. EDWARDS:
+18
+Q. And the girls who would come over on the
+19 airplane?
+20
+MR. CRITTON: Form.
+21
+THE WITNESS: Yes.
+22 BY MR. EDWARDS:
+23 Q. Did you ever have occasion to go into the
+24 bedroom and find the vibrators or back massagers
+25 out after Mr. Epstein was in the room with any of
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 424
+A.
+the girls who used to stay at the
+home in El Brillo used to go over there to the
+Island.
+Q. When he would have these girls -- I guess
+we've kind of categorized them as the girls who
+would come over with him on an airplane and stay
+at the house.
+A. Yes.
+Q. When they would be staying at the house
+would he also have the local Palm Beach girls
+coming over that you were told to call masseuses?
+A. Yes.
+Q. So these girls that came on the airplane
+with him, were they also -- did they also have
+knowledge that these young girls were coming over
+to give massages?
+MR. CRITTON: Form.
+THE WITNESS: Yes, sir.
+BY MR. EDWARDS:
+Q. Okay. Who are the girls from the
+airplane other than
+A.
+that you remember?
+recall right now. But
+There were so many, sir 1 del
+is for sure,
+was one of the main girlfriends, but I don't
+remember that.
+Page 426
+1
+the girls that came over on the plane?
+2
+MR. CRITTON: Form.
+3
+THE WITNESS: Yes.
+4
+BY MR. EDWARDS:
+5
+6
+Q. So that's something that would be out
+after the girls that came over on the plane or the
+7 girls that came over for the massages?
+8
+A. Yes.
+9
+10
+MR. CRITTON: Form.
+11
+BY MR. EDWARDS:
+Q. And at the time when you were house
+12
+manager you had a 15-year old daughter?
+A. Yes.
+14
+15
+16
+17
+Q. Did she live down here?
+A. In New Jersey.
+Q. Okay. When Alan Dershowitz was at the
+house I understood you to say that these local
+Palm Beach girls would come over to the house
+19
+20
+while he was there but you're not sure if he had a
+massage from any of those girls.
+21
+A. Exactly.
+22
+Q. And what would he do while those girls
+23
+were at the house?
+24
+MR. CRITTON: Form.
+25
+THE WITNESS: He will read a book with a
+40 (Pages 423 to 426)
+
+
+Page 427
+glass of wine by the pool, stay inside.
+BY MR. EDWARDS:
+3
+Q. Did he ever talk to any of the girls?
+A. I don't know, sir.
+5
+6
+Q. Certainly he knew that they were there?
+MR. CRITTON: Form.
+THE WITNESS: I don't know, sir.
+8
+BY MR. EDWARDS:
+9
+Q.
+Do you know how
+knows Mr.
+10 Epstein?
+11
+A.
+No, sir.
+12
+Q. Or how long she's known him?
+13
+MR. CRITTON: Form.
+14
+THE WITNESS: She was on board two years
+15
+or a year and a half before I came on board.
+16
+BY MR. EDWARDS:
+17
+Q. Okay.
+18
+A. So it's probably 2003 or 2.
+19
+20
+Q. All right. You mentioned this Citrix
+21
+system.
+Yes.
+22
+23
+Q. Is that a system that was used to operate
+the phones and the computers?
+24
+A.
+The computers mainly.
+25
+Q. All right. But you then also described
+Page 429
+1
+usually it's Yahoo dot com or at Bellsouth dot
+2
+3
+net.
+A. It was very uncommon. I don't remember,
+4 sir.
+5
+Q. Did everybody in the -- I think you
+6 called it the organization, did everybody have
+7 e-mails?
+8
+A. Yes.
+9
+Q. Okay. Would that include
+10
+A. Yes.
+11
+Q. All right. And did Mr. Epstein have an
+12
+e-mail?
+13
+14
+A. Yes.
+Q. Did you ever correspond with Mr. Epstein
+15
+by e-mail?
+16
+A. Yes.
+17
+MR. EDWARDS: You can go ahead.
+18
+THE WITNESS: That's the only one that I
+19
+remember.
+20
+THE VIDEOGRAPHER: Okay, we're off the
+21
+record.
+22
+(Thereupon, a recess was had.)
+23
+THE VIDEOGRAPHER: We're back on the
+24
+record with tape number four.
+25
+BY MR. EDWARDS:
+Page 428
+Page 430
+1
+2
+3
+4
+5
+some system where someone would call on the
+Q. Mr. Rodriguez, what was Mr. Epstein's
+telephone and that would be automatically
+2
+e-mail?
+downloaded to the computer?
+3
+A. Jeep project at something -- Jeep
+A. Yeah, you can retrieve who called in a
+transcript written who called, what's the message,
+4
+project -- I can't remember it right now.
+5
+the time so you have it on a piece of paper, you
+6
+Q. Okay. In the course of this next 10 or
+15 minutes -
+7
+can print it out.
+7
+A. I can recall.
+8
+Q. Is it your understanding that is also
+Q. - if it comes to you just tell me. So
+9
+part of the Citrix system?
+8
+9
+it was Jeep project -
+10
+A. Yes.
+11
+10
+A. Like Jeep, the brand name Jeep, Jeep
+Q. All right. Did you have an e-mail?
+11
+project at - I can't remember.
+12
+A. Right now, yes.
+12
+Q. Okay. Was that his only e-mail to your
+13
+Q. No, when you were working at --
+13 knowledge?
+14
+A. Yes, I did.
+14
+A. No.
+15
+Q. -. Mr. Epstein?
+16
+And did
+15
+Q. He had other e-mail addresses?
+have an e-mail?
+16
+A. Yes.
+17
+A. Yes.
+17
+Q. Do you know what any of his other e-mail
+18
+Q. And did all of the e-mails end the same
+18 addresses were?
+19
+way such as Epstein's house dot com or something?
+19
+A. No, I don't remember.
+20
+A. Yes.
+20
+Q. Do you know who the carriers were for the
+21
+Q. Okay. What was
+e-mail?
+21 other e-mail addresses owned by Jeffrey Epstein?
+22
+A. I don't remember.
+A. No, sir.
+23
+Q. What was your e-mail?
+23
+Q. Whether it was Yahoo or hot mail or --
+24
+A. Staff house -- I don't remember, sir.
+24
+A. No, none of those.
+25
+Q. Do you recall how it ended? I mean
+25
+Q. Okay. Was this Jeep project e-mail run
+41 (Pages 427 to 430)
+
+
+Page 431
+through the Citrix system?
+A. Yes.
+3
+Q. Okay. And was there a certain company
+• that came out and fixed the actual Citrix system?
+5
+A. Yes.
+6
+7
+Q. And who was that?
+A. We used to have our own in-house
+8
+technician from Ohio.
+9
+Q. The same guy you were telling us about
+10 before?
+11
+A. Yes.
+12
+Q. All right. He would fix the video
+13
+equipment or the --
+14
+A. Computers mainly.
+15
+Q. And if the Citrix system broke down too
+16
+then he would be in charge of it?
+17
+A. He was the only one dealing with this, we
+18
+19
+couldn't hire anybody else.
+Q. Do you know why that is?
+20
+A. No. It was too many lines into the house
+21
+from many properties.
+22
+Q. And do you know who that person is,
+23
+remember his name now?
+24
+A. I don't remember, sir.
+25
+Q. I understood you to say at some point in
+Page 432
+1
+time that you saw photographs of some of the girls
+2
+that were at the house to give massages on
+3
+4
+Ms. Maxwell's computer.
+A. Yes.
+5
+Q. And -
+6
+MR. CRITTON: Form to the last question.
+7
+BY MR. EDWARDS:
+8
+Q. And do you know which of the girls?
+9
+No, sir.
+10
+Q. Was
+. one of them?
+11
+MR. CRITTON: Form.
+12
+THE WITNESS: I cannot guarantee that, I
+13
+14
+cannot say hundred percent, sir.
+BY MR. EDWARDS:
+15
+Q. Was
+one of them?
+16
+A. Could be, sir.
+17
+Q. How about
+18
+.?
+19
+A. It's the same thing, I cannot say a
+20
+hundred percent, sir.
+Q. I think that you used the phrase there
+21
+were so many girls.
+22
+A. Yes, sir.
+23
+Q. That you're not sure which ones you saw?
+24
+• No, sir, so many names.
+25
+Q. Okay. While David Copperfield was ever
+Page 433
+H N
+at the house did any of these girls, these local
+Palm Beach girls come over to the house as well?
+A. They were earlier, sometimes they will
+leave and he will stay for dinner.
+5
+Q. All right. And you remember there was
+6
+one time where maybe
+1. stayed for dinner with
+7
+David Copperfield?
+8
+A. That's correct.
+9
+Q. Was there ever a time where
+10
+David Copperfield were in a bedroom together?
+11
+A. I don't think Mr. Copperfield went
+12
+upstairs.
+13
+Q. When the police came to the driveway with
+14
+. in the car, what did you tell the police, if
+15
+16
+anything, that you were paying
+. for?
+A. They asked me whose this people, and I
+17 said they're a masseuse.
+18
+Q. Okay. Why would you tell them that
+they're a masseuse, that's the name you were
+20
+supposed to call them?
+21
+MR. CRITTON: Form.
+22
+THE WITNESS: Yes.
+23
+BY MR. EDWARDS:
+24
+Q. And for these massages you were paying
+25
+between 300 and 500 dollars each time?
+Page 434
+1
+A. Yes, sir.
+Q. And that's usually for an hour up in the
+3
+bedroom with Mr. Epstein?
+A. More or less, yes.
+5
+6
+Q. You never told your 15-year old daughter
+at the time that she could come over to Mr.
+7 Epstein's for $500 an hour?
+8
+A. No, sir.
+9
+10
+MR. CRITTON: Form.
+BY MR. EDWARDS:
+11
+Q. Why is it that you never asked your
+12
+daughter to come over if it's just a massage?
+13
+MR. CRITTON: Form.
+14
+THE WITNESS: My daughters are too clean
+15
+for that, sir.
+16
+17
+BY MR. EDWARDS:
+Q. Too clean to give a massage?
+18
+MR. CRITTON: Form.
+19
+THE WITNESS: They are good students,
+20
+they are in another type of environment,
+21
+sir, we are poor but you know, they're good
+22
+students.
+23 BY MR. EDWARDS:
+24
+Q. It's because you knew there was more than
+25 a massage going on in the bedroom?
+42 (Pages 431 to 434)
+
+
+Page 435
+MR. CRITTON: Form.
+3
+THE WITNESS: Yes, sir.
+BY MR. EDWARDS:
+4
+Q. What are some of Mr. Epstein's companies,
+5
+if you know the names?
+6
+A. Well, he was the Price -- Price Com, it
+7
+was one of his companies, he had a phone company
+8
+9
+in Palm Beach. A lot of offshore companies that
+I don't recall, sir.
+10
+Q. When you say Price Com --
+11
+A.
+12
+Price dot Com, he owned that for awhile.
+And the local phone company in Palm Beach was his
+13
+but then he sold it again. But there is too many.
+14
+Q. As house manager you're obviously at his
+15
+16
+house every single day, did you inquire as to what
+he did in terms of making money?
+17
+A. No, sir, I only got through the internet
+18
+because I put his name on Google and then I find
+19
+out the rest of his companies.
+20
+Q. So during the day when he would go to the
+21
+cabana I think that you described last time that
+22
+he would work there?
+23
+A. He would work there.
+24
+Q. Do you know what he would do in terms of
+25
+working?
+1
+2
+3
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+Page 436
+A. No, that was very private. I would put
+his coffee there and I would shut the door.
+Q. And
+had a work station or
+work computer within the house?
+A. Yes.
+Q. What did she do in terms of work?
+A. She will set appointments for comedy
+shops, movies. I will get the tickets but, you
+know, she was appointments for the masseuse, or
+travel arrangements with the pilots, that type of
+thing.
+Q. And would she keep track of all of the
+girls who were coming to his house in Palm Beach
+or at the other houses as well?
+MR. CRITTON: Form.
+THE WITNESS: All of the houses.
+BY MR. EDWARDS:
+Q. All right. So if he was going to be in
+Paris and he wanted girls over in that house she
+would keep track of that as well?
+MR. CRITTON: Form.
+THE WITNESS: Exactly.
+BY MR. EDWARDS:
+0.
+And when you talked about seeing
+computer and seeing the names and
+Page 437
+telephone numbers of various girls that were
+referred to as masseuses, did that also give you
+access to the girls that were coming over to Mr.
+Epstein's house in Paris and New York and New
+Mexico?
+MR. CRITTON: Form.
+THE WITNESS: We used to have a book in
+8
+every car, in every plane, in every boat
+10
+that Mr. Epstein with all the names of all
+these people so it was not necessarily a
+11
+secret.
+12
+13
+BY MR. EDWARDS:
+Q. When we're talking all these people, are
+14 we talking about -
+15
+16
+A. Masseuses and, you know, chefs, the
+important people in the life of Mr. Epstein, you
+17
+18
+know, used to have a black book with all the
+19
+names.
+Q. So there were many black books?
+20
+A. Yes.
+21
+Q. And do you know where those black books
+22
+are now?
+23
+A. There were tons of those in the house
+24 but, you know, I don't know.
+25
+Q. Okay. And did each one of them have
+Page 438
+1
+handwritten names and numbers or were these
+2
+• computer printouts so they were the same?
+3
+A. They were very organized. Once in awhile
+• they used to be updated, so we used to have these
+5
+books with obsolete dates, you know, so we discard
+6
+them and have the new ones.
+7
+Q. By obsolete dates are you saying that
+8 there were girls that came over and then they no
+9
+longer came over anymore?
+10
+A. That's correct.
+MR. CRITTON: Form.
+12 BY MR. EDWARDS:
+Q. Okay. So if a girl that was coming over
+14
+for a period of time got too old and was no longer
+15 able to come over and somebody else took her place
+16 then her page would disappear from that book?
+18
+MR. CRITTON: Form.
+THE WITNESS: I believe so, sir.
+19 BY MR. EDWARDS:
+20
+Q. You were asked about other homes that you
+21 worked at for other wealthy people and asked if
+22 these other homes had a massage table.
+23
+A. Yes.
+24
+Q. And you said that they did?
+25
+A. Yes.
+43 (Pages 435 to 438)
+
+
+Page 439
+Page 441
+1
+2
+3
+4
+5
+6
+7
+Q. And you said that that was -- the massage
+MR. EDWARDS: I don't have anything else.
+table was similar in kind to that used by Mr.
+Epstein?
+3
+MS. EZELL: I have a few.
+EXAMINATION
+A. That's correct.
+4 BY MS. EZELL:
+Q. And others had massage oils and that was
+5
+Q. Mr. Rodriguez, I may have missed
+similar in kind to Mr. Epstein's as well?
+6
+something. Did you say that there weren't any
+A. Yes.
+7
+wild parties ever at El Brillo Way?
+Q. And you didn't think that the massage
+8
+A. I never saw what was going on inside the
+table at a home was unusual?
+9
+house, Ma'am.
+10
+A.
+• No.
+10
+Q. So you don't know wether there were or
+11
+12
+Q. All right. Did any of the other houses
+11
+were not?
+13
+where you worked have masseuses that were 14, 15, 12
+A. No, ma'am.
+and 16 years old?
+13
+Q. There wasn't just one massage table
+14
+MR. CRITTON: Form.
+15
+14 there; was there?
+THE WITNESS: No, sir.
+15
+16 BY MR. EDWARDS:
+16
+A. We used to have two and we have an extra
+reserve, I think there were three in the house.
+17
+Q. And did any of the other homes where you
+17 Excuse me, I'll take that back. All the bedrooms
+18 worked have different girls of that age coming
+18 used to have one.
+19
+every single day?
+19
+Q. Okay. Thank you. Did you ever hear
+20
+A. Yes.
+20 about a girl named
+21
+MR. CRITTON: Form.
+21
+.?
+A. No, no, ma'am.
+22
+BY MR. EDWARDS:
+22
+Q. And those pictures on Ms. Maxwell's
+23
+Q. They had different girls?
+23 computer, did you ever see one of a girl naked in
+24
+25
+A.
+• Yes.
+24 a hammock?
+Q. Okay. And how old were the girls that
+25
+MR. CRITTON: Form. Asked and answered.
+Page 440
+Page 442
+1
+2
+3
+4
+would come to these other homes?
+A. They seem older.
+Q. Older than the ones that would come to
+Mr. Epstein's home?
+A. Yes.
+6
+Q. And did you ever work at a place where
+7
+there would be girls calling up on the phone to
+8
+say I have girls to bring him and --
+9
+A.
+• No, sir.
+10
+Q. - coming over in teams -
+11
+12
+A.
+No.
+Q. - or pairs?
+13
+14
+15
+16
+17
+18
+19
+THE WITNESS: I saw on a book not on a
+2
+3
+computer.
+BY MS. EZELL:
+4
+Q. You saw a picture of a girl naked in a
+5
+book or on a book?
+6
+A. The book was done for
+and she was
+7 on the hammock, that's the only one I saw.
+8
+Q. I'm sorry, the book was done for
+9
+A. She was on the cover.
+10
+Q. Then there were other people inside the
+11
+book?
+12
+A. Yes, ma'am.
+13
+Q. And in that book there was a picture of a
+Q. So there were a lot of things about Mr.
+14
+girl naked in a hammock?
+Epstein's house and his arrangement that were very
+15
+A. Yes.
+unusual compared to the other places where you
+16
+Q. Where did
+keep that book?
+worked?
+17
+A. There were a few of those examples but I
+MR. CRITTON: Form.
+18
+don't know where she kept it.
+THE WITNESS: Yes.
+19
+Q. Was it laying around the house somewhere?
+BY MR. EDWARDS:
+21
+22
+23
+24
+25
+20
+A. Yes.
+Q. And there were no drugs and alcohol or no
+21
+Q. Downstairs?
+wild parties at Mr. Epstein's house, that is
+22
+A. Downstairs, yes, ma'am.
+somewhat different from some of the other places
+23
+Q. Did
+keep scrapbooks or photograph
+where you worked?
+24 books --
+A. Yes.
+25
+A. Yes.
+44 (Pages 439 to 442)
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 443
+Q. - of friends, girls?
+1
+Page 445
+A.
+was like
+, she was between
+A. Yes, ma'am.
+and me, I guess. She was to help |
+MR. CRITTON: Form.
+3
+in
+BY MS. EZELL:
+4
+her duties.
+Q. And is that what your understanding was
+Q. Do you remember there being a young man
+5
+as to what
+did?
+who would bring girls to the house named Tony
+6
+A. I'm sorry?
+Figueroa?
+7
+Q. Was it your understanding that
+was
+A.
+No, ma'am. The only person that I saw
+8
+there to help
+with her duties?
+that night
+was at the house, she was driving
+9
+the car, but I didn't see any males.
+10
+A. No
+vas.
+MR. CRITTON: You said he, he being whom?
+11
+Q.
+was. Okay.
+Have you spoken to any lawyers or
+BY MS. EZELL:
+12 investigators about this case since you were
+Q. I didn't quite understand that either.
+13
+deposed last?
+Tony Figueroa was driving.
+14
+A. No, ma'am.
+A.
+She was with this girl that night,
+I
+15
+think that's the only time I saw a male at the
+16
+Q. I believe Mr. Critton was asking you
+questions relating to the incident when
+•. was
+house, ma'am.
+17 in a car in the driveway and you went and got the
+Q. And you're talking about the night when
+18
+police and he was speaking of that time as being
+you came and found the old car in the driveway?
+19
+in January of '05. Do you remember when it was?
+A. Exactly, yes, with the police, yes.
+20
+A. I will put that in that month, ma'am, but
+Q. How did you remember that it was Tony
+21 I cannot guarantee.
+Figueroa?
+22
+Q. Let me just show you something that we
+A. It's the only person, male that I
+23
+can mark as the next exhibit.
+remember.
+24
+Q. But you don't know his name?
+25
+I would just ask that if -- yes, the name
+is in here that we redact it to show just the
+Page 444
+Page 446
+A. No, no, no, Ma'am.
+Q. Got you. Thank you.
+MR. CRITTON: Can I ask one quick?
+There was a man with
+» you don't know
+who it was?
+THE WITNESS: That's the only male that's
+been to the house, so when she asked me the
+question I assume, you know.
+MR. CRITTON: Do you know who Tony
+Figueroa is?
+THE WITNESS: No, sir.
+MR. CRITTON: Okay. Now I think I
+understand. Thank you. Sorry, Cathy.
+MS. EZELL: That's okay.
+BY MS. EZELL:
+Q. I asked you earlier if the chef's name
+could have been
+and I was wrong, I
+wanted to ask you a different name.
+Could it have been
+A. I don't remember his last name.
+Q. Do you remember an assistant of some sort
+who worked there for awhile when you were there
+named
+A.
+Yes.
+Q. What did she do?
+1
+2
+3
+initials.
+MR. EDWARDS: We're going to attach this;
+right?
+MS. EZELL: Yes.
+MR. CRITTON: You're going to let us have
+this one?
+7
+MS. EZELL: Yes. With initials.
+8
+(Exhibit No. 9 was marked for
+9
+Identification.)
+10
+11
+BY MS. EZELL:
+Q. Have you ever seen this report?
+12
+A. I saw it typed, not handwritten like
+13
+this.
+14
+Q. Did the police bring you one that was
+15 typed?
+16
+A. No, the only time I saw my own report was
+17 on the internet because my daughter told me do you
+18
+know that you're in Palm Beach and this and that,
+19 so I was in New York on vacation and that's why I
+20 read it but this is the first time I'm looking at
+21 this.
+22
+Q. Okay.
+23
+MR. HOROWITZ: Do you have extra copies?
+24
+MS. EZELL: I do, I don't want to give
+25
+them out, I'd rather -- I don't mind them
+45 (Pages 443 to 446)
+
+
+Page 447
+attaching it to the deposition as long as it
+2
+has just the initials.
+THE WITNESS: This is the report when I
+called to the police to the house?
+5
+BY MS. EZELL:
+6
+Q. Let me let you look at it, I'd rather you
+7
+tell us if it is.
+8
+A.
+This is why I was fired. This is the
+9
+reason I was let go.
+10
+MR. CRITTON: There is no question right
+11
+now. I'm sure there will be.
+12
+MR. EDWARDS: I'll ask it if you want.
+13
+THE WITNESS: I'm thinking out loud.
+14
+BY MS. EZELL:
+15
+Q. Did you notice the date on this report?
+16
+A.
+17
+November 28th, yes, ma'am.
+Q. And do you have any reason to belleve
+18 that that's not accurate?
+19
+20
+A. No, that's it, yeah.
+Q. And as you look at other information on
+21
+the report do you see anything else that's not
+22
+accurate?
+23
+A. Let me finish reading this, please.
+24
+Q. Sure.
+25
+MR. CRITTON: Let me just object to the
+Page 448
+1
+form. Can I look at your copy, please?
+THE WITNESS: This is the first time I
+saw this.
+4
+5
+BY MS. EZELL:
+Q. Have you had a chance now to read it?
+A. Yes, ma'am.
+8
+Q. Okay. Does this report accurately
+describe what occurred that evening?
+9
+A. Yes, ma'am.
+10
+11
+MR. CRITTON: Form.
+12
+BY MS. EZELL:
+Q. Did you overhear the conversation between
+13
+and the policeman?
+14
+A. Yes, ma'am.
+15
+Q. And is that part accurate as well?
+16
+A. Yes.
+17
+Q. And then your conversation with Mr. --
+18 with Officer
+19
+A. Yes, maam.
+20
+Q. -- is that accurately reported here as
+21 well?
+22
+A. Yes, ma'am.
+23
+Q. Now you stated that this is why you got
+24
+fired.
+25
+A. Yes, ma'am.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 449
+Q. Can you tell me what you mean by that?
+A. Mr. Epstein used to give a lot of gifts
+to the police department, so we used to have
+certain leeway in terms of speeding or some other
+things. So he used to put a baseball cap Palm
+Beach Police Department on the dashboard.
+So when he saw I called the police for my
+own safety because I was carrying cash, I
+explained that to him, and he say why you called
+the police, and I said because I saw a clunker in
+the driveway and it's dark. In Palm Beach there
+is no nights. So I called for my own safety. I
+was coming from Publix buying my groceries and I
+had cash in my pocket. And I said I called the
+police because I was concerned about my own
+safety.
+And I recognized the girl and I figured
+because I remember
+told me earlier that day
+-- it was a hectic day, he just left Palm Beach
+and I was catching up with my breath, you know, I
+went to buy my groceries, and I explained that.
+So he was upset that this will spill, you know, to
+the public or the street. But I didn't realize
+this was written or something, you know.
+Q. You were not fired though until sometime
+Page 450
+1
+in March?
+2
+A. Exactly, yes. But he gave me-- Mr.
+3
+Epstein used the word I'm going to give you -- he
+4
+make fun of my Spanish and he said (speaking in
+Spanish).
+And I said, yes, Mr. Epstein. Okay, I'll
+give you one more chance. And I said what's going
+8
+on. But, you know, it meant a few words, I
+9
+10
+couldn't talk to him too much, but this was it.
+Because, you know, I have to say this for
+11
+myself, you know, I never did something illegal, I
+12
+13
+was working hard to please him and sometimes more
+than I was supposed to, many hours beyond my
+14
+duties, and so -- but he was concerned about this.
+15
+16
+And I say, Mr. Epstein, you told me
+safety is the paramount of this house, in this
+17
+case it was me, but obviously he didn't care about
+18
+19
+me, it was his safety.
+20
+MR. CRITTON: Form. Move to strike.
+BY MS. EZELL:
+21
+Q. Can you translate for me what you said a
+22 moment ago in -- I don't know --
+23
+A. In Spanish he said "conose" amnesty, but
+24 he used the word "conose amnistia"
+, Ill give you
+25 amnesty so you have a chance to continue working
+46 (Pages 447 to 450)
+7115 Rue Notre Dame, Miami Beach, FL. 33141
+
+
+1
+2
+4
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+Page 451
+Page 453
+with me.
+1
+her do you believe under the influence of drugs?
+But I didn't ask him why. He just came
+A. No.
+fast. You're always in the run, you have to be on
+Q. Did you ever see steroids in the house?
+your toes, and the next thing he said I took the
+A. No.
+wrong Suburban and they let me go.
+MR. LANGINO: Thank you.
+But I never find out what happened
+MR. EDWARDS: Do you have anything,
+because I have to say this. Being so many people
+Richard?
+in the house I didn't know if I displease one of
+the girls, or something I said or I did, I don't
+9
+MR. WILLITS: Yes.
+MR. EDWARDS: Okay, shoot.
+think so. So they let me go very mysteriously.
+10
+But this is it.
+11
+EXAMINATION
+BY MR. WILLITS:
+Q. I understood you to say that Mr. Epstein
+12
+gave lots of gifts to the police department.
+13
+Q. Mr. Critton asked you several questions
+about the females who you were told to refer to as
+A. Yes, ma'am.
+14
+masseuses. And when he asked you those questions
+Q. And you said something about a baseball
+15
+he referred to them often as women.
+cap.
+16
+Did you think of those masseuses as
+A. Well, the police department used to give
+17 women?
+us in retribution dozens of baseball caps with the
+18
+MR. CRITTON: Form.
+Palm Beach Police Department, you put one of those
+19
+THE WITNESS: Yes.
+on the dashboard you don't get a ticket.
+20 BY MR. WILLITS:
+Q. On.
+21
+Q. Why?
+A. Stutt like that. Key rings and so on and
+22
+A. Because I saw them, they were females.
+so forth. There is - everybody knows this, I
+23
+Q. What is your definition of a woman?
+don't think it's a secret. Mr. Epstein give
+24
+A. Person of the opposite sex, I'm a male.
+$85,000 simulator for the police to shoot, you
+25
+Q. Is a three-year old a woman?
+Page 452
+Page 454
+know, and it was returned after the scandal broke
+out.
+MR. CRITTON: Move as nonresponsive to
+any question. Move to strike.
+MS. EZELL: I don't have any other
+6
+questions.
+7
+EXAMINATION
+8
+BY MR. LANGINO:
+9
+Q. m
+10
+Mr. Rodriguez, do you know where the main
+server, the main computer server was located
+11
+inside the house?
+12
+A. In the garage.
+Q. Do you know the names of any of the
+14
+programs - computer programs --
+15
+MR. WILLITS: I am missing something.
+16
+Whose questioning now?
+17
+MR. LANGINO: Adam Langino.
+18 BY MR. LANGINO:
+19
+Q. Do you know the names of some of the main
+20
+computer programs that are used as part of your
+21
+routine as the house manager of the house?
+22
+A. The main computers?
+23
+Q. Programs.
+24
+A. Besides Citrix, no, sir.
+25
+Q. Regarding
+did you ever see
+A. Yes.
+Q. Okay.
+MR. WILLITS: I don't have any other
+questions.
+INDA
+MR. EDWARDS: I do but only just to
+follow-up with this police report that we've
+just been provided which I'm not sure if it
+8
+9
+has a designation.
+MR. CRITTON: Exhibit 9.
+10
+MR. EDWARDS: Okay.
+11
+EXAMINATION
+12 BY MR. EDWARDS:
+Q. You were asked by Mr. Critton about
+14
+who we were referring to as
+1. in this
+15
+deposition, and her date of birth is
+16
+And Mr. Critton was indicating to you earlier that
+17
+18
+at the time that you had this dealing with her in
+19
+the driveway that she was 18 years old. It
+appears that this occurred November 28, 2004,
+20
+which would indicate that she is 17 years old.
+21
+22
+I think the question that was asked of
+you is, are you surprised by that, so I'll ask you
+23
+the same question?
+24
+A. No, Sir.
+25
+Q. All right. This report that you have
+47 (Pages 451 to 454)
+
+
+Page 455
+1
+2
+3
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+indicated is accurate or accurately reflects the
+events of that night, I want to make sure that Mr.
+Willits hears and that we go through it and you
+can elaborate on any part of it. Okay.
+On Sunday, 11/28/2004, at approximately
+19:00 hours, so we're talking about 7:00 at night,
+the property manager of 358 El Brillo Way, Alfredo
+Rodriguez, came to the station to complain there
+was a strange vehicle parked in the driveway.
+A. Yes.
+Q. That's true?
+A. Yes.
+Q. When Officer
+nd 1, this is
+Officer
+talking, arrived at 358 El Brillo,
+we located a white female later identified as
++, date of birth
+waiting in the
+driveway.
+A. That's correct.
+Q. Okay.
+MR. CRITTON: Form. Are you asking him
+whether the statement is correct or that
+you're reading it correctly?
+BY MR. EDWARDS:
+Q. No, the statement is correct.
+A. Yes.
+Page 456
+1
+Q. That's what you understood me to ask you?
+2
+A.
+, Yes.
+3
+Q. Okay.
+arrived at that time and
+stated he did remember. was there to pick up -
+5
+was coming there to pickup an envelope the
+6
+homeowner, Jeffrey Epstein, left for her.
+7
+And that's correct as well. Right?
+8
+A. Yes.
+9
+MR. CRITTON: Form.
+10 BY MR. EDWARDS:
+11
+This document right here, is it
+12 refreshing your recollection as to that night?
+A. Yes.
+14
+MR. CRITTON: Form.
+15 BY MR. EDWARDS:
+16
+Q.
+quickly entered the house then
+17 returned with a sealed envelope with 's first
+18 name on it.
+19
+A. Yes.
+20
+Q. Do you remember who wrote her first name
+21 on that envelope?
+22
+A. I did.
+Q. Okay. The envelope appeared to have
+24 money in it, in my opinion. . was very nervous
+25 with us standing there.
+Page 457
+Did you get that impression that was
+2
+very nervous in her car when the police showed up?
+A. Yes.
+Q. Was that an indication to you that she
+5
+realized that there were police there and that
+there was some form of illegal activity that she
+7
+was involved in at Jeffrey Epstein's house?
+MR. CRITTON: Form.
+9
+10
+THE WITNESS: Yes.
+BY MR. EDWARDS:
+11
+Q. 's cell phone rang, she answered it
+12
+13
+quickly, said, in quotes, "I can't talk, I can't
+talk, I'm at school, I got to go."
+14
+Did you hear that part of it?
+15
+A. Yeah.
+16
+Q. Okay. That's obviously a lie. Right?
+17
+MR. CRITTON: Form.
+18 BY MR. EDWARDS:
+19
+Q. She's saying she's at school when really
+20 she's right in front of Jeffrey Epstein's house?
+A. Yes.
+22
+23
+24
+25
+Q. And again, another indication that she's
+doing something she shouldn't be doing. Right?
+MR. CRITTON: Form.
+MS. EZELL: Object to the form.
+Page 458
+1
+BY MR. EDWARDS:
+2
+Q. If she was a masseuse and was at
+3
+someone's house in relation to pick up money from
+a massage she had given, that's not the typical
+answer that you would expect. Right?
+MR. CRITTON: Form.
+THE WITNESS: That's right.
+8
+BY MR. EDWARDS:
+Q. Okay. It didn't shock you or surprise
+10 you as Mr. Critton asked you earlier that she
+11
+would make up a tale or a lie about her
+12
+13
+whereabouts considering what she was doing.
+Right?
+14
+A. No.
+15
+MR. CRITTON: Form.
+16
+17
+BY MR. EDWARDS:
+Q. Then hung up, talking about Ms. I
+18
+asked her who it was on the phone, she stated it
+19
+was her mom. I asked her how she knows Epstein,
+20
+21
+- stated the following. She works at Abercrombie
+& Fitch in the Wellington Greens Mall, she met
+22 Epstein through a female friend at work, Epstein
+allows them to come over any time and use the
+24
+house and pool. Then she quickly left.
+25
+Did you hear that conversation?
+48 (Pages 455 to 458)
+
+
+Page 459
+A. Yes, they were next to me.
+3
+Q. Okay. Is that the entire substance of
+that conversation between Ms.. and the police
+4
+• officer?
+5
+A. Yes.
+6
+Q. She didn't mention that she comes over to
+7 his house and goes into a bedroom with Mr.
+8
+Epstein. Right?
+9
+MR. CRITTON: Form.
+10
+THE WITNESS: No.
+11 BY MR. EDWARDS:
+12
+Q. And she didn't tell the police officer
+13
+that she is a masseuse; did she?
+14
+A. No.
+15
+Q. And that didn't surprise you either; did
+16
+it?
+17
+A. No.
+18
+MR. CRITTON: Form.
+19 BY MR. EDWARDS:
+20
+Q. I then asked Rodriguez what was in the
+21
+22
+envelope, Rodriguez was hesitant but -- what is
+that word?
+23
+A. But then.
+24
+Q. But then I said it was drugs and he
+25
+quickly said it was money. Is that accurate?
+Page 460
+1
+2
+3
+4
+5
+A. That's correct.
+Q. When he first asked you what was in the
+envelope were you nervous?
+A. No, because I was trying to -- I didn't
+want to disclose these private things with the
+7
+8
+9
+10
+11
+police so that's why I was concerned about that.
+Q. When you're talking about private things,
+the fact that there are young girls coming over?
+MR. CRITTON: Form.
+THE WITNESS: It was late, you know,
+exactly.
+12 BY MR. EDWARDS:
+Q. I'll let you answer. What are the
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+private things that you were nervous to tell the
+police?
+A. This was inside the compound, the
+property itself, so you have to keep
+confidentiality, and the police was there, that's
+why. Not that I was doing something wrong but I
+was trying to keep them --
+Q. I'm not suggesting that you were doing
+something wrong.
+A. Exactly. So he asked me is there any
+drugs there, and I said, no, it's just money.
+That's all I said.
+Page 461
+1
+Q. I asked what kind of job performs
+2
+odriguez smiled and says she is a massag
+3
+therapist.
+A. Yeah.
+Q. Why did you tell him that?
+MR. CRITTON: Form.
+THE WITNESS: Because I understood she
+8
+came to give massage.
+9 BY MR. EDWARDS:
+10
+Q. Well, that's what somebody had told you?
+11
+A. Yes.
+12
+13
+Q. At this point in time though you knew
+that more was going on than a massage?
+14
+MR. CRITTON: Form.
+15 BY MR. EDWARDS:
+16
+Q. Right?
+17
+MR. CRITTON: Form.
+18
+THE WITNESS: That's right.
+19 BY MR. EDWARDS:
+20
+Q. I asked -- this is the police officer
+21 talking, I asked which muscle she rubbed.
+22
+Do you remember the police officer asking
+23 that?
+24
+A. Yes.
+25
+Q. And you knew what he was implying.
+Page 462
+1
+2
+3
+Right?
+MR. CRITTON: Form.
+THE WITNESS: Yeah.
+BY MR. EDWARDS:
+Q. That it was obvious to him that she was
+over there to sexually please Mr. Epstein. Right?
+7
+MR. CRITTON: Form.
+8
+THE WITNESS: That's correct.
+9 BY MR. EDWARDS:
+10
+Q. And that's coming from a police officer
+who's not the house manager. Right?
+12
+MR. CRITTON: Form.
+13
+THE WITNESS: That's right.
+14
+BY MR. EDWARDS:
+15
+Q. You knew right away what he was asking
+16
+and you say, Rodriguez laughed said, in quotes,
+"off the record, he, Epstein, has many young girls
+18 come over for that," end quote.
+19
+20
+Do you remember telling him that?
+MR. CRITTON: Form.
+21
+THE WITNESS: Yes.
+22 BY MR. EDWARDS:
+23 Q. And when you were saying come over for
+24 that, it was --
+25
+A. Massage or something.
+49 (Pages 459 to 462)
+
+
+Page 463
+Page 465
+2 Right?
+• -- to sexually please Mr. Epstein.
+3
+MR. CRITTON: Form.
+4
+THE WITNESS: Yes.
+5
+BY MR. EDWARDS:
+6
+Q. I mean, that's what you were telling the
+7
+police officer.
+8
+MR. CRITTON: Form.
+9
+THE WITNESS: Yes.
+10 BY MR. EDWARDS:
+11
+12
+Q. Okay. There's always a different girl at
+the pool or inside with him when he's here.
+13
+MR. CRITTON: Form.
+14
+THE WITNESS: Yes.
+15
+16
+MS. EZELL: You left out a word, young.
+BY MR. EDWARDS:
+Q. Sorry, I'll read the last sentence again.
+18
+19
+There's always a different young girl at
+the pool or inside with him when he's here.
+20
+Do you remember telling the police
+21
+officer that?
+22
+23
+A. Yes.
+MR. CRITTON: Form.
+24
+BY MR. EDWARDS:
+25
+Q. And that's true. Right?
+Q. And as to -- it was read to you by Mr.
+2
+3
+4
+5
+Edwards and he then asked you a number of
+questions whether you remembered something.
+Correct?
+A. Yes.
+Q. Okay. Just so I'm clear, he's asking you
+7
+to speculate on what may or may not have occurred
+8
+• upstairs in the bedroom. I want to be very clear.
+9
+Mr. Rodriguez, were you ever up in the
+10 bedroom to observe whatever went on between a
+11 masseuse and Mr. Epstein or anyone else for that
+12
+matter at any time?
+13
+MR. HOROWITZ: Form.
+14
+15
+THE WITNESS: No, sir.
+16
+BY MR. CRITTON:
+Q. And so when Mr. Edwards asked you, you
+17 were aware that sexual activity or may have been
+18
+sexual activity occurring upstairs, you have no
+19
+personal knowledge, you're just speculating;
+20
+aren't you, sir?
+21
+MR. HOROWITZ: Form.
+22
+MR. EDWARDS: Object to the form.
+23
+24
+THE WITNESS: I never saw them.
+BY MR. WILLITS:
+25
+Q. And therefore you can only speculate --
+Page 464
+Page 466
+1
+A. Yes.
+2
+3
+Q. When he's at the house there is always a
+young girl inside with him.
+4
+MR. CRITTON: Form.
+5
+BY MR. EDWARDS:
+6
+7
+Q. Right?
+A.
+That's right.
+8
+9
+Q. Okay. And whether the company line is to
+10
+call them a masseuse, you knew that these girls
+were young and were up in the bedroom with Mr.
+11
+Epstein to sexually please Mr. Epstein.
+12
+13
+MR. CRITTON: Form.
+THE WITNESS: That's right.
+14
+MR. EDWARDS: I don't have anything else.
+15
+We've already attached this; right? Here is
+16
+the one that can be attached
+17
+MR. WILLITS: Who is next?
+18
+19
+MR. CRITTON: Me.
+RECROSS EXAMINATION
+20
+BY MR. CRITTON:
+21
+Q. Mr. Rodriguez, looking at Exhibit 9 which
+22 is the police report that was prepared on November
+23
+28, 2004, this is the first time you've seen it.
+24
+Correct?
+25
+A. That's correct.
+5
+6
+7
+8
+9
+10
+MR. WILLITS: Object to the form.
+MR. CRITTON: I need to ask the question
+first.
+MR. WILLITS: It was the earlier
+question.
+BY MR. CRITTON:
+Q. All right. If you did not see what was
+going on you can have no personal knowledge.
+True?
+MR. HOROWITZ: Object to the form.
+11
+MR. EDWARDS: Object to the form.
+12
+THE WITNESS: Yes.
+13
+BY MR. CRITTON:
+14
+15
+speculating or refore what are dave glen
+16
+occurring. True?
+17
+MR. HOROWITZ: Form.
+18
+MR. EDWARDS: Form.
+19
+MR. WILLITS: Form.
+20
+THE WITNESS: I use my age together.
+21
+BY MR. CRITTON:
+22
+Q. I'm not saying that you don't, but
+23 without having personal knowledge you're best
+24 guessing what may have occurred up there betweer
+25 Mr. Epstein and one of the massage women, or for
+50 (Pages 463 to 466)
+
+
+Page 467
+Page 469
+1 that matter anyone else who was upstairs?
+2
+A. Yes.
+3
+MR. HOROWITZ: Form.
+MR. EDWARDS: Form.
+MR. WILLITS: Object to the form.
+MR. CRITTON: Thank you.
+MS. EZELL: I just have a couple of
+questions.
+1
+A. Yes.
+3
+MR. EDWARDS: Nothing else.
+MR. WILLITS: Is it my turn?
+4
+MR. EDWARDS: Yes.
+0 Un
+5
+EXAMINATION
+7
+8
+9
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+6
+BY MR. WILLITS:
+7
+Q. Mr. Rodriguez, you mentioned the last
+8 time about a lady who was an obvious professional
+EXAMINATION
+masseuse by the name of
+_ Do you remember
+10 BY MS. EZELL:
+10 that?
+Q. Following up on that, you did however see
+11
+A. Yes, I do remember.
+this same young woman asleep naked in the sauna?
+12
+Q. Did you ever pay her?
+A. Yes, ma'am.
+13
+A. Yes, sir.
+Q. And you did along with
+find and
+14
+Q. Okay. How much did you pay her?
+- and you did also find sex toys and massagers of
+15
+A. It was between 200 and 500, sir, but
+various kinds and creams scattered around on
+16
+somewhere in that - between those two amounts.
+several occasions after these young women had been 17
+Q. For
+upstairs with Mr. Epstein?
+18
+A. Yes, sir.
+MR. CRITTON: Object to form, asked and
+19
+MR. WILLITS: Okay. I don't have any
+answered about six times.
+20
+other questions.
+THE WITNESS: Yes.
+21
+MR. CRITTON: You have a right to read
+MS. EZELL: No other questions.
+22
+this deposition when the other part is typed
+MR. EDWARDS: Sorry, last one. It has
+nothing to do with this report.
+23
+and make any changes that you want. Would
+24
+EXAMINATION
+you like to do that? It's your right a
+25
+hundred percent. The court reporter can
+Page 468
+Page 470
+1
+2
+3
+4
+BY MR. EDWARDS:
+Q. During Mr. Critton's questioning he asked
+you about whether or not we had ever shown you a
+previous taped statement that you had given to a
+police officer, and we did not do that; did we?
+A. No.
+7
+Q. We can represent to you that we don't
+8
+have it to show it to you otherwise we would like
+9
+to do that.
+10
+However, he asked you did you tell the
+11
+police officers at that time that the girls
+12 appeared to be 18 years or older, and 1 believe
+13 that you said when you gave the statement to the
+14
+police that you did; right, say that?
+15
+A. Yes.
+16
+Q. And I wrote, I put it in quotes, you said
+17
+that because you were fearful of reprise from
+18
+Ms. Maxwell and Mr. Epstein.
+19
+A. That's correct.
+20
+MR. CRITTON: Form.
+21
+BY MR. EDWARDS:
+22
+Q. Okay. Is everything that you've said
+23
+today and told us today, is it true?
+24
+A.
+Yes.
+25
+Q. To the best of your knowledge?
+provide you or whoever set your
+deposition -
+3
+THE WITNESS: I tried to be truthful.
+MR. CRITTON: All you have to do is tell
+her you would like to waive. Do you waive
+the reading and signing?
+MR. EDWARDS: You can either read or you
+can waive reading?
+9
+THE WITNESS: I don't understand what I
+10
+have to do.
+11
+MR. CRITTON: Why don't we go off the
+12
+record and you can explain it to him.
+13
+MR. EDWARDS: We can go off the record.
+14
+THE VIDEOGRAPHER: Off the record.
+15
+(Thereupon, a discussion was held off the
+16
+record.)
+17
+THE WITNESS: Waive.
+18
+(Thereupon, the deposition was concluded
+19
+20
+at 5:30 p.m.)
+21
+--
+22
+23
+24
+25
+51 (Pages 467 to 470)
+
+
+Page 471
+1 THE STATE OF FLORIDA,
+COUNTY OF DADE.
+3
+5
+I, the undersigned authority, certify
+that ALFREDO RODRIGUEZ personally appeared before
+7 me on the 7th day of August, 2009 and was duly
+8
+9
+sworn.
+10
+11
+WITNESS my hand and official seal this
+18th day of August, 2009.
+12
+13
+14
+15
+16
+MICHELLE PAYNE, Court Reporter
+Notary Public - State of Florida
+17
+18
+19
+20
+21
+22
+23
+24
+25
+CERTIFICATE
+County Of Dade.
+I, MICHELLE PAYNE, Court Reporter and
+Notary Public in and for the State of Florida at
+large, do hereby certify that I was authorized to
+and did stenographically report the deposition of
+ALFREDO RODRIGUEZ; that a review of the transcript
+was not requested; and that the foregoing pages,
+numbered from 270 to 472, inclusive, are a true
+and correct transcription of my stenographic notes
+10
+of said deposition.
+I further certify that said deposition was
+taken at the time and place hereinabove set forth
+11
+and that the taking of said deposition was
+commenced and completed as hereinabove set out.
+12
+I further certify that I am not an
+13 attorney or counsel of any of the parties, nor am
+I a relative or employee of any attorney or
+14
+counsel of party connected with the action, nor am
+I financially interested in the action.
+15
+The foregoing certification of this
+16 transcript does not apply to any reproduction of
+the same by any means unless under the direct
+17 control and/or direction of the certifying
+reporter.
+18
+19
+20
+DATED this 18th day of August, 2009.
+21
+22
+23
+24
+25
+MICHELLE PAYNE, Court Reporter
+Page 472
+52 (Pages 471 to 472)
+215 us Coute Dame, ani Beach, F 33141
+
+
+Page 1
+
+
+Page 2
+EE
+
+
+Page 3
+
+
+Page 4
+JL
+
+
+Page 5
+' ]
+
+
+Page 6
+FT-r
+
+
+Page 7
+
+
+Page 8
+
+
+Page 9
+
+
+Page 10
+J.IL
+
+
+Page 11
+
+
+Page 12
+Nl Lr l
+
+
+Page 13
+
+
+Page 14
+
+
+Page 15
+
+
+Page 16
+
+
+Page 17
+
+
+Page 18
+•+Tu
+
+
+Page 19
+
+
+PENSAD 800-631-6989
+EXHIBI
+#3
+ROnPIGuEZ
+0-2°8
+EL BPILLO
+lis
+G
+D.
+1 5 9 5|
+
+
+
+
+PALM
+BEACH POLICE DEPARTMENT
+INTELLIGENCE REPORT
+FILE
+CASE
+#
+#:
+DATE:_i|•28-0Y
+CONFIDENTIAL (CYN) :
+YES
+OFFICER NAM
+SUBJECT NAME: (LAST) Epstein
+DATE OF BIRTH: 01-20•53
+I.D.
+"(FIRST) Jeff me
+RACE: white
+SEX:
+18443
+(M.I:) N
+Male
+SOURCE NAME: (LAST)
+CONTACT INFORMATION
+. (TELEYHONE)
+-
+EVALUATION OF SOURCE: RELIABLE
+SOURCE
+IDENTIFICATION: PRIVATE CITIZEN •X
+CRIMINAL SOURCE
+• (FIRST)
+(M.I.).
+-
+UNRELIABLE
+UNEVALUATED.
+LAW OFFICER
+GOVT: AGENCY
+OTHER
+INFORMATION ACQUIRED BY: PERSONAL KNOWLEDGE
+HEARSAY/RUMOR"*
+NEWS MEDIA
+DOCUMENTS
+INFORMATION:
+On sun, 11-28-c4, st appies iacchis, the property sismuger of 35B Et Bills way.
+Alfredo Rodiguez can to the statien to corphin there was a strange vehicle putted in to deacony.
+at 358 El Brilla. When ofe
+and I aprived at 358 EL Brillo, we located a white funcle later
+idatlid as
+wiling in the driviny.
+arrived a
+at so that time cond
+stated lic did remanks t was coming this to pick up an endope the hate war Iffery Epstein
+Left for her
+sickly entred the bour they returned with a sculed covetee with
+cait: the enclope apprased to basis meneg in it, in syapinion.
+was very outine with we standing
+call phere may i she ameredit guickly, scid "I sit all, I can't tall, let sched, Egottage"
+Theu lung ye 7 seked her who it wasthe stated it was he men. Fasked bow she Kan Fpitene
+baded the fallings the wok at Abeabie & Fitch" in the Willinger Gue cue all. Sheret Epstein the
+a fatale front at want. Epstein allans them to cascue anytime sad use the kevi cind pale Then sens
+Let. I tico aiked
+want was in the eavelies
+digi, be gukly said it was mney. Earked wist Kind of Joh
+performiss
+guiled and
+Adde la cerage therapite I ink wich musth she rubbede
+Laughed sind sold
+"aft the scord, bc (plin has many you jids came over for that". there's slut,
+a different young
+INFORMATION Et at the pool orinside weth him when he's here."
+UNVERIFIED
+EXPLAIN
+PARTIALLY VERIFIED
+SIMILAR INFO FILED
+EVALUATED BY SUPERVISOR (INITIALS ¿
+RECOMMENDED: FOLLOW-UP BY SUPERVISOR:
+SOURCE TO VERIFY
+ANALYZE: AND
+EVALUATE
+DETECTIVE TO VERIFY
+FILE 0
+EXHIB
+#9
+Entries do
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/d75a05dc8a484b4fbea4194ba903d33ad72ffbddc970733ac2e83a0ccff8f4d2.receipt.json b/vision-fixhub/ds9-unparsed-05/d75a05dc8a484b4fbea4194ba903d33ad72ffbddc970733ac2e83a0ccff8f4d2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1dbc56098ddba4bcdf6643fee4fdbfeb42b9275a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d75a05dc8a484b4fbea4194ba903d33ad72ffbddc970733ac2e83a0ccff8f4d2.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -5702,
+  "dataset": "marble-joined",
+  "doc_id": "d75a05dc8a484b4fbea4194ba903d33ad72ffbddc970733ac2e83a0ccff8f4d2",
+  "engine": "marble-apple-vision",
+  "event_count": 75,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "6be6917203223a8f11e5fd7288adb88e96e105e7ed927667342b933b0f97c36f",
+  "output_sha256": "cb0b40e853933e8482d741796bc45d1e70d56c325b1f046f91b6f3ff4948f763",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/d8cd9ee8448dee16412e89c06fc81c03278ffe2ce91996fccc2010f2f769768a.md b/vision-fixhub/ds9-unparsed-05/d8cd9ee8448dee16412e89c06fc81c03278ffe2ce91996fccc2010f2f769768a.md
new file mode 100644
index 0000000000000000000000000000000000000000..bcf20db0a1b8cb5c38b1e4996951d949d5f85fe0
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d8cd9ee8448dee16412e89c06fc81c03278ffe2ce91996fccc2010f2f769768a.md
@@ -0,0 +1,82 @@
+ROY BLACK
+HOWARD M. SREBNICK
+SCOTT A. KORNSPAN
+LARRY A. STUMPF
+MARIA NEVRA
+JACKIE PERCZEK
+MARK A.J. SHAPIRO
+JARED LOPEZ
+=
+BLACK
+SREBNICK
+KORNSPAN
+& STUMPF
+=PA.=
+JESSICA FONSECA-NADER
+KATHLEEN P. PHILLIPS
+MARCOS BEATON, JR.
+MATTHEW P. O BRIEN
+JENIFER J. SOULIKIAS
+NOAH FOX
+E-Mail: RBlack@RoyBlack.com
+February 18, 2010
+Esq.
+Assistant United States Attorney
+99 N.E. 4th Street
+Miami, FL 33132
+RE: Jeffrey Epstein
+Dear
+Thank you for your letter of February 11, 2010. We write to update you
+about ongoing eiforts to reach an agreement with Robert Josetsberg regarding the
+amount of fees and costs properly owed to him by Mr. Epstein pursuant to the
+NPA.
+On February 16, 2010 Mr. Epstein's principal civil counsel Bob Critton
+advised Mr. Josefsberg in writing that he and Mr. Epstein would meet with Mr.
+Josefsberg on two occasions between now and March 1, 2010 to review Mr.
+Josefsberg's outstanding bills on a line-by-line basis and attempt to reach a nonadversarial resolution of all outstanding fee issues. Mr. Critton also transmitted
+to Mr. Josefsberg an Agreement for Special Master to Determine Amount of
+Attorneys' Fees and Costs ("Special Master Agreement"), signed by Mr. Epstein,
+containing terms and conditions previously agreed to by Mr. Josefsberg, which
+would mandate binding mediation before a neutral third party in the event the
+proposed settlement discussions did not resolve all outstanding issues in an
+expeditious manner.
+We want to assure you that Mr. Epstein fully intends to fulfill his obligations
+under the NPA. We regret that issues remain unresolved regarding whether all of
+the fees and costs being sought by the attorney representative - which now total
+$1,947,000 exclusive of the $526,466 already paid by Mr. Epstein - meet the
+criteria set forth by the NPA. We assure you that both Mr. Epstein's prior civil
+counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the NPA
+language, and Mr. Critton, each strongly believe that significant amounts of the
+fees and costs billed by Mr. Josefsberg are outside the scope of Mr. Epstein's fee-
+201 S. Biscayne Boulevard, Suite 1300 • Miami, Florida 33131 • Phone: 305-371-6421 • Fax: 305-358-2006 • www.RoyBlack.com
+
+
+Marie Villafana, Esq.
+February 18, 2010
+Page 2
+related payment obligations under the NPA. We hope that the fee-related issues
+can be resolved by further settlement discussions or by relying on the Special
+Master Agreement signed Tuesday February 16, 2010 by Mr. Epstein. Mr. Epstein
+and his counsel believe that these options are consistent with the NPA, are good
+faith alternatives to contested litigation, and are reasonable given the unexpected
+magnitude of the bills and their inclusion of charges for legal work that was
+clearly related to the preparation of litigation and thus outside Par 7C of the
+Addendum as well as for extensive work performed by attorneys from outside Mr.
+Josefsberg's law firm.
+Mr. Josefsberg previously advocated for settling outstanding issues through
+a Special Master Agreement nearly identical to the one executed Tuesday by Mr.
+Epstein. In fact, Mr. Josefsberg and Mr. Epstein had each agreed in the past to
+a specific Master as a third-party neutral to conduct proceedings to resolve the fee
+issues. However, the selected Master withdrew.
+We hope that the Special Master Agreement will provide a basis for a prompt
+resolution of any issue not resolved by the parties through further discussions.
+Respectfully submitted,
+MARTIN WEINBERG, ESQ.
+ROY
+LACK, ESQ.
+in Tah.
+/ wg
+Cc:
+Jeffrey Sloman, Esq.
+, Esq.
+Black, Srebnick, Kornspan & Stumpf, P.A.
diff --git a/vision-fixhub/ds9-unparsed-05/d8cd9ee8448dee16412e89c06fc81c03278ffe2ce91996fccc2010f2f769768a.receipt.json b/vision-fixhub/ds9-unparsed-05/d8cd9ee8448dee16412e89c06fc81c03278ffe2ce91996fccc2010f2f769768a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2d1fbb4dfb039e37ebf82f4e511656efbf29da39
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d8cd9ee8448dee16412e89c06fc81c03278ffe2ce91996fccc2010f2f769768a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -26,
+  "dataset": "marble-joined",
+  "doc_id": "d8cd9ee8448dee16412e89c06fc81c03278ffe2ce91996fccc2010f2f769768a",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "d547af56e2f31ca571cef84805a138aca5cb461e8f1dc3f5cafeb70a43242a95",
+  "output_sha256": "5047fed919d6f0fc5d81270df38c1543fd929361a9d5bd9c9902e1774e23201f",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/d98d6ded484cdb24a067d172c2d63aac0e35714bed9ab1d17f366c66078aab40.md b/vision-fixhub/ds9-unparsed-05/d98d6ded484cdb24a067d172c2d63aac0e35714bed9ab1d17f366c66078aab40.md
new file mode 100644
index 0000000000000000000000000000000000000000..6ba32b49035767cd9d2188b85a77ec964fda44bb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d98d6ded484cdb24a067d172c2d63aac0e35714bed9ab1d17f366c66078aab40.md
@@ -0,0 +1,199 @@
+U.S. Department of Justice
+Southern District of Florida
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+December 5, 2008
+VIA ELECTRONIC MAIL
+Brad Edwards, Esq.
+2028 Harrison Street, Suite 202
+Hollywood, Florida
+33020
+Re:
+Jeffrey Epstein/
+Notification of Work Release
+, and
+Dear Mr. Edwards:
+By virtue of this letter, the United States Attorney's Office for the Southern District of
+Florida asks that you provide the following notice to your clients,
+1, and
+The U.S. Attorney's Office has learned that Jeffrey Epstein has applied to
+participate in the Palm Beach County Sheriff's Office's ("PBSO") work release program, and PBSO
+has granted that application. Mr. Epstein is reportedly working for The Florida Science Foundation
+at 250 South Australian Avenue, Suite 1404, West Palm Beach, FL 33401. After work each day,
+Mr. Epstein returns to the Palm Beach County Stockade. While outside the Stockade, Mr. Epstein
+is electronically monitored via a GPS system and an ankle bracelet. Pursuant to the work release
+rules, Mr. Epstein is to go directly from the Stockade to his office, remain at the office throughout
+the work day, and then return directly to the Stockade.
+We regret that we were unable to inform your client of these developments prior to Mr.
+leatin s cisase but or orin si was seried of participatin the piration and dyly
+or your client have any questions regarding the work release program, please direct your inquiries
+to Captain David Sleeth, Palm Beach Sheriff's Office,
+Sincerely,
+R. Alexander Acosta
+By:
+Assistant U.S. Attorney
+
+
+U.S. Department of Justice
+Southern District of Florida
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+December 11, 2008
+VIA HAND DELIVERY
+Captain David Sleeth
+Palm Beach Sheriff's Office
+Corrections Division
+3228 Gun Club Road
+West Palm Beach, FL 33406
+Re:
+Work Release Application of Jeffrey Epstein
+Dear Captain Sleeth:
+The U.S. Attorney's Office recently learned that Inmate Jeffrey Epstein applied for
+and was approved for participation in the Palm Beach Sheriff's Office's ("PBSO") work
+release program. Through a request for public records, 1 have received a copy of Mr.
+Epstein's work release file. After doing some internet research of public records and making
+a few telephone calls, I discovered some inaccuracies and omissions in Mr. Epstein's file that
+I wanted to bring to your attention. During a recent meeting, Roy Black, one of Mr.
+Epstein's attorneys, invited us to share our concerns with PBSO.
+Eligibility for Participation
+I understand that Mr. Epstein would be ineligible for participation in the work release
+program if he committed three violations of F.S.S. 796 within the past five years. Mr.
+Epstein has been charged with and convicted of a felony violation of F.S.S. 796.07. In order
+to be convicted of a felony violation of that statute, one must commit "a third or subsequent
+violation." In other words, Mr. Epstein has committed at least three violations of Section
+796.07, and in his "Alternative Custody Program Placement Synopsis," Mr. Epstein's charges
+are described as "Recommit: Prostitution."
+In addition to those three violations, Mr. Epstein also has been convicted of violating
+F.S.S. 796.03, procuring a person under the age of 18 for prostitution. Throughout his
+
+
+PAGE 2
+paperwork, this violation is referred to simply as "prostitution." The charge is not a
+solicitation of prostitution charge, it is a procurement of a minor to engage in prostitution.
+Florida courts have defined the offense as "inducing a victim to engage in sexual activity"
+for money and "persuading, inducing, or prevailing upon a person to do something sexual"
+for financial gain. In other words, the statute addresses the recruiting of minors who have
+not previously been involved in prostitution to engage in sexual activity for commercial gain
+to a recruiter or "pimp"/"madame." The Florida Legislature has acknowledged the
+significant difference between solicitation under F.S.S. 796.07 and procurement of minors
+under F.S.S. 796.03 by requiring persons convicted of violating F.S.S. 796.03 to register as
+sex offenders. The distinction may be meaningful to the victims of Mr. Epstein's offenses,
+who could feel that they are being stigmatized as "prostitutes."
+Inaccuracies and Omission in Work Release Application and Related Documents
+Throughout the records related to Mr. Epstein's work release placement, he is
+alternatively referred to as working for "The Florida Science Foundation" or "selfemployed," and Mr. Epstein lists his salary as $250,000. Mr. Epstein describes himself as
+"returning to work" and "eligible for re-employment" at The Florida Science Foundation.
+Please be advised that the only W-2 that Mr. Epstein provided is from Financial Trust
+Company, Inc., which shows that Mr. Epstein was employed in the U.S. Virgin Islands at a
+salary of $180,785.62, not $250,000.
+Mr. Epstein provided to you no documentation regarding his pre-incarceration
+employment with "The Florida Science Foundation" or its corporate alter-ego, "The
+C.O.U.Q. Foundation, Inc." As you will see, the Foundation, its offices, and Mr. Epstein's
+purported job schedule were all created on the eve of Mr. Epstein's incarceration in order to
+provide him with a basis for seeking work release.
+The Florida Science Foundation was not registered with the State of Florida and had
+no office space or telephone number until after Mr. Epstein was already incarcerated. The
+application filed with the State of Florida and signed under penalty of perjury by Richard
+Kahn lists Mr. Kahn's and the Foundation's telephone number as "561-659-8300." That is
+the telephone number of Atterbury, Goldberger and Weiss-one of the law firms representing
+Mr. Epstein. Richard Kahn is a partner at the law firm of Sullivan and Cromwell in New
+York and has no association with the Atterbury firm.
+Checking public records available on the internet, I located the IRS returns of "The
+C.O.U.Q. Foundation, Inc." for fiscal years 1999 through 2006 (which covers the period
+
+
+DECEMBER 11,2008
+PAGE 3
+through 2/28/07).' These sworn filings show that Mr. Epstein worked for the Foundation for
+only one hour per week and earned no compensation. (See page 6 of each return.) All of
+these returns were signed under penalty of perjury by either Mr. Epstein or Darren Indyke,
+who is listed in Mr. Epstein's work release file as Mr. Epstein's "supervisor." Mr. Epstein's
+representations concerning his prior work duties and salary may violate the salary and
+employment verification requirements of C.O.P. #926.01(V)(C)(7) and (8).
+In response to your requirement of "a detailed work schedule," Mr. Indyke has
+provided the following two sentences:
+[Mr. Epstein's] duties will require him to work six days a week, Monday
+through Saturday, at the Foundation's office located at 250 S. Australian
+Avenue, Suite 1404, West Palm Beach, Florida from the hours of 8:00 A.M.
+to 8:00 P.M.
+As President of the Foundation, Mr. Epstein will be responsible for the general
+oversight and management of the Foundation, and particularly, to seek out,
+evaluate and determine worthy charitable causes to which the Foundation may
+make contributions.
+Mr. Indyke did not disclose that Mr. Epstein only worked one hour per week prior to his
+incarceration and has provided no explanation of why Mr. Epstein could perform these duties
+in one hour per week before he was incarcerated but now needs to spend 72 hours each week
+to do the same job. Again, this appears to be inconsistent with C.O.P. #926.01(V)(C)(7).
+Mr. Indyke has signed the "Alternative Custody Unit Program Agreement" as Mr.
+Epstein's "employer." In that Agreement, Mr. Indyke promises to "notify the Alternative
+'The returns are available online at the following public websites:
+FY2006: http://www.guidestar.org/FinDocuments/2007/133/996/2007-133996471-0391c8db-F.pdf
+FY2005: http://www.guidestar.org/FinDocuments/2006/133/996/2006-133996471-02c9625e-F.pdf
+FY2004: http://www.guidestar.org/FinDocuments/2005/133/996/2005-133996471-02056acf-F.pdf
+FY2003: http://www.guidestar.org/FinDocuments/2004/133/996/2004-133996471-1-F.pdf
+FY 2002: http://www.guidestar.org/FinDocuments/2003/133/996/2003-133996471-1-F.pdf
+FY2001: http://www.guidestar.org/FinDocuments/2002/133/996/2002-133996471-1-F.pdf
+FY2000: http://www.guidestar.org/FinDocuments/2001/133/996/2001-133996471-1-F.pdf
+FY1999: http://www.guidestar.org/FinDocuments/2000/133/996/2000-133996471-1-F.pdf
+FY1998: http://www.guidestar.org/FinDocuments/1999/133/996/1999-133996471-1-F.pdf
+
+
+PAGE 4
+Custody Unit immediately if the Participant: (1) Fails to appear for work at the scheduled
+time; and (2) Leaves the place of employment prior to the scheduled time." Both in this form
+and in Mr. Indyke's letter in support of Mr. Epstein's application, Mr. Indyke neglects to
+inform the Sheriff's Office of two significant facts. First, Mr. Indyke lives and works in the
+New York metropolitan area. He likely will not be present at Mr. Epstein's workplace, so
+he may not know if Mr. Epstein "fails to appear for work" or "leaves the place of
+employment." In that event, Mr. Indyke also will not be able to supervise Mr. Epstein's
+actual work to determine whether he is truly doing the work of The Florida Science
+Foundation.? Second, Mr. Indyke does not "employ" Mr. Epstein. Instead, Mr. Epstein
+"employs" Mr. Indyke. Mr. Epstein is the President and founder of The Florida Science
+Foundation and Mr. Indyke is its Vice President. More importantly, Mr. Epstein is also the
+founder and President of the Financial Trust Company, his for-profit corporation. Mr.
+Indyke is Mr. Epstein's subordinate at that entity as well.
+One of Mr. Epstein's attorneys has suggested that Mr. Epstein is using his time on
+work release to manage investments resulting in investment income of millions of dollars.
+If that is true, then Mr. Epstein is acting outside of the scope of his employment with The
+Florida Science Foundation. Instead, that would be in keeping with Mr. Epstein's work for
+his for-profit corporation, which would inure to the benefit of Mr. Indyke. Because that work
+would result in a financial benefit to him, and because he is Mr. Epstein's subordinate at that
+corporation, Mr. Indyke may be reluctant to inform the Sheriff's Office of this violation of
+the terms of Mr. Epstein's Work Release contract.
+The "references" listed by Mr. Epstein all appear to have the same conflict of interest.
+Mr. Epstein did not list any past or present co-workers, supervisors, or clients. Instead, he
+has listed four attorneys who are currently retained-and paid-by Mr. Epstein. Their attorneyclient privilege obligations might further restrain them from notifying the Sheriff's Office
+if Mr. Epstein was not abiding by the work release rules.
+As I previously mentioned to Colonel Gauger, the decision regarding work release is
+ompletely within the discretion of the Sheriff's Office. The purpose of this letter is simpl
+) provide you with information concerning Mr. Epstein's offenses and his work situatiot
+Judge Pucillo, who conducted the change of plea and sentencing, heard the factual proffer
+and imposed Mr. Epstein's sentence. She has not been consulted regarding Mr. Epstein's
+"On the application for registration of the Florida Science Foundation with Florida's
+Department of State, Mr. Indyke lists his true address in Livingston, New Jersey.
+
+
+PAGE 5
+application for work release. I understand that Judge McSorley's standing order states that
+she "takes no position with respect to the eligibility of any inmate sentenced in this Division
+unless specifically stated at time of sentencing." Because of her absence, Judge McSorley
+did not conduct the sentencing and, therefore, did not have the opportunity to weigh any
+objections to work release at that hearing. It is unclear whether Judge Pucillo was aware of
+Judge McSorley's standing order when she imposed sentence. In utilizing your discretion,
+you may or may not choose to consult with the appropriate judge on this matter.
+Request for Notification
+As I had previously asked of Colonel Gauger, I would appreciate if you would keep
+me informed of any changes to Mr. Epstein's release status so that I may fulfill my
+obligations to keep the victims identified through the federal investigation informed of Mr.
+Epstein's status. I have informed all of the known victims of Mr. Epstein of the change in
+his incarceration status and that you are the contact person if they have any questions. Some
+may ask that their locations be amongst the "Exclusionary Zones" programmed into Mr.
+Epstein's GPS unit. If you need their addresses, please let me know.
+Please feel free to contact me with any questions or concerns.
+Sincerely,
+R. Alexander Acosta
+By:
+Assistant United States Attorney
+CC:
+Colonel Michael Gauger
+Karen Atkinson, Chief, Northern Division I
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/d98d6ded484cdb24a067d172c2d63aac0e35714bed9ab1d17f366c66078aab40.receipt.json b/vision-fixhub/ds9-unparsed-05/d98d6ded484cdb24a067d172c2d63aac0e35714bed9ab1d17f366c66078aab40.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c2c347c3c6369650c647c5b4ef6d62d9b2a3fb45
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d98d6ded484cdb24a067d172c2d63aac0e35714bed9ab1d17f366c66078aab40.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -307,
+  "dataset": "marble-joined",
+  "doc_id": "d98d6ded484cdb24a067d172c2d63aac0e35714bed9ab1d17f366c66078aab40",
+  "engine": "marble-apple-vision",
+  "event_count": 9,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "93607cf7b09fc3fffd290d2cd06929fbd21a278eb3bc7242f5e483bc1cc03d5e",
+  "output_sha256": "6e739869a0d6233be1999e3006a7ea0e05b30f7cdf7b77f1c2851ecacc19a8cc",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/d9fc82277bad8cd7d9a4dd9e0956d0df7d80815d3797ccc9153e88ec9f5e61b0.md b/vision-fixhub/ds9-unparsed-05/d9fc82277bad8cd7d9a4dd9e0956d0df7d80815d3797ccc9153e88ec9f5e61b0.md
new file mode 100644
index 0000000000000000000000000000000000000000..76ae1159b8c55b6ea9ce166a272c7fcf8e8bdd31
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d9fc82277bad8cd7d9a4dd9e0956d0df7d80815d3797ccc9153e88ec9f5e61b0.md
@@ -0,0 +1,1997 @@
+COMPACT FLASH SW
+
+
+AO 93 (Rev. 5/85) Search Warrant.
+SOUTHERN
+FLORIDA
+In the Matter of the Search of
+(Name, address or brief description of property or premises to be searched)
+One Ritz Big Print Digital Film
+128 Megabyte CompactFlash memory card,
+marked 3608128AW4801CF53
+in the custody of the Federal Bureau of Investigation
+SEARCH WARRANT
+CASE NUMBER 08-8067-LRJ
+FEDERAL BUREAU OF INVESTIGATION, and any Authorized Officer of the United
+States:
+Affidavit(s) having been made before me by
+who has reason to
+Affiant
+believe that [Jon the person of or [X] on the premises known as (name, description andor location)
+One Ritz Big Print Digital Film 128 Megabyte CompactFlash memory card
+marked 3608128AW4801CF53
+in the custody of the Federal Bureau of Investigation,
+505 S. Flagler Drive, Suite 500, West Palm Beach, Florida
+FLORIDA
+SOUTHERN
+District of
+concealed a certain person or property, namely (describe the person or property)
+there is now
+the electronic information contained in that CompactFlash memory card,
+which is property that constitutes evidence of the commission of a criminal offense, instrumentalities of such
+violations; and any fruits of those crimes, that is, violations of 18 U.S.C. 55 371, 1591, 2252, 2252A, 2422, and
+2423.
+1 am satisfied that the affidavits) and any recorded testimony establish probable cause to believe that the person
+or property so described is now concealed on the person or premises above-described and establish grounds for the
+issuance of this warrant.
+YOU ARE HEREBY COMMANDED to search on or before
+3-27-08
+(Date)
+(not to exceed 10 days) the person or place named above for the person or property specified, serving this warrant
+and making the search (in the daytime - 6:00 A.M. to 10:00 P.M.)(at any time in the day or night as I find
+reasonable cause has been established)) and if the person or property be found there to seize same, leaving a copy
+of this warrant and receipt for the person or property taken, and prepare a written inventory of the person or
+property seized and promptly return this warrant to the duty Magistrate Judge as required by law.
+3-17-08
+Date and Time Issued
+United States Magistrate Judge
+1:40 pm at WEST PALM BEACH, FLORIDA
+City and State
+Certified to be a true and
+Steven Mage document on file
+armore, Cork.
+"' Distra
+Shudea
+Florida
+
+
+IN RE:
+SEARCH WARRANT APPLICATION
+ORDER GRANTING UNITED STATES' MOTION TO SEAL
+This matter comes before the Court upon the United States' Motion to Seal the
+documents related to its Search Warrant Application. The Court being fully apprised in the
+premises, orders that the motion is hereby GRANTED.
+DONE AND ORDERED in chambers, in West Palm Beach, Florida, this L 7 day of
+March, 2008.
+Im
+LINNEA R. JOHNSO
+cc:
+,, AUSA
+Certified to be * Irue and
+correct copy of the document on he
+Steven M
+armore
+Blerk,
+Deteriorita
+n Districh
+By
+Candier
+
+
+Number: 08-8067-LRJ
+In Re
+SEARCH WARRANT APPLICATION
+Party Filing Matter Under Seal
+SEALED DOCUMENT TRACKING FORM
+Name:
+I. U.S. Attorney's Office
+Address: 500 S. Australian Ave, Suite 400, West Palm Beach, FL 33401
+• Plaintiff
+• Defendant
+On behalf of (select one):
+Date sealed document filed: 3/17/2008
+If sealed pursuant to statute, cite statute: Fed. R. Crim. P. 6(e) (Grand Jury Material)
+If sealed pursuant to previously entered protective order, date of order and docket entry number:
+The matter should remain sealed until:
+• Conclusion of Trial
+• Case Closing
+• Arrest of First Defendant
+• Conclusion of Direct Appeal
+• Other: _
+• Permanently. Specify the authorizing law, rule, court order:
+The moving party requests that when the sealing period expires, the filed matter should be (select one):
+• Unsealed and placed in the public portion of the court file
+] Destroyed
+• Returned to the party or counsel for the party, as identified above
+
+
+IN RE:
+SEARCH WARRANT APPLICATION
+!
+MOTION TO FILE DOCUMENTS UNDER SEAL
+The United States of America, by and through the undersigned Assistant United States
+Attorney, hereby moves to seal its Application for Search Warrant for the following reasons:
+The attached documents contain information relating to an ongoing grand jury
+investigation; thus, pursuant to Fed. R. Crim. P. 6(e)(6), all records and orders related to the grandjury proceedings must be kept under seal to the extent and as long as necessary to prevent the
+unauthorized disclosure of a matter occurring before the grand jury.
+Public disclosure of this matter would jeopardize the criminal investigation, notify
+potential subjects and/or targets and undermine the public interest and the function of the grand jury.
+WHEREFORE, the United States respectfully requests that the aforementioned documents
+be sealed.
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+Assistant United States Allorney
+
+
+SOUTHERN
+FLORIDA
+Mant, the Master of the Search of kariet)
+One Ritz Big Print Digital Film
+128 Megabyte CompactFlash memory card
+APPLICATION AND AFFIDAVIT
+FOR SEARCH WARRANT
+marked 3608128AW4801CF53
+in the custody of the Federal Bureau of Investigation
+CASE NUMBER: 08-8067-LRJ
+I,
+— being duly sworn, depose and say:
+, and have reason to believe
+that
+I am a Special Agent, Federal Bureau of Investigation
+on the person of or
+_ on the premises known as (name, description and/or location):
+One Ritz Big Print Digital Film 128 Megabyte CompactFlash memory card,
+marked 3608128AW4801CF53,
+in the custody of the Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500, West Palm Beach, Florida
+District of
+Florida
+in the
+Southern
+there is now concealed a certain person or property, namely (describe the person or property):
+the electronic information contained in that CompactFlash memory card,
+which is (give alleged grounds for search and seizure under Rule 41(b) of the Federal Rules of Criminal Procedure)
+evidence, instrumentalities, and fruits of a crime, concerning violations of Title 18, United States Code,
+Sections 371, 1591, 2252, 2252A, 2422, and 2423.
+The facts to support the issuance of a Search Warrant are as follows:
+see Attached Affidavit of E.
+Continued on the attached sheet and made a part heroof
+Y Ves
+E.
+Federal Bureau of Investigation
+Special Agent
+Sworn to before me, and subscribed in my presence:
+3-17-05
+Certified to be a trua
+and
+WEST PALM BEACH, FLORIDA
+City and State
+Date
+Oate.
+U.S
+Southed Distri
+
+
+I, B
+I am a Special Agent with the Federal Bureau of Investigation ("FBI") and have been
+so employed for the past ten (10) years. I am currently assigned to PB-2, the Violent Crimes and
+Major Offenses Squad of the Palm Beach County Resident Agency, Miami Division. Among my
+responsibilities as a Special Agent are investigating crimes against children, particularly offenses
+involving child pornography and the exploitation of children.
+2.
+I make this affidavit in support of an application by the United States of America for
+issuance of a warrant to search and seize evidence of violations of Title 18, United States Code,
+Sections 371, 1591, 2252, 2252A, 2422, and 2423; instrumentalities of such violations; and any
+fruits of those crimes located within electronic media, specifically two 128MB CompactFlash
+memory cards, seized in October 2005 by The Town of Palm Beach Police Department ("PBPD")
+during the execution of a State of Florida search warrant at the premises located at 358 El Brillo
+Way, Palm Beach, Florida 33480, owned by Jeffrey Epstein (hereinafter, "Epstein's residence").
+Those CompactFlash memory cards are more fully described as follows: (a) one Ritz Big Print
+Digital Film 128 Megabyte CompactFlash memory card, marked 3608128AW4801CF53, and (b)
+one PNY Technologies 128 Megabyte CompactFlash memory card, marked
+THNCF128MMA(T00CB) 999223 TAIWAN 0247 (hereinafter jointly referred to as "CompactFlash
+memory cards").
+The facts set forth in this affidavit are based on my personal knowledge, information
+obtained in this investigation from others, including other law enforcement officers, my review of
+documents and records related to this investigation, and information gained through my training and
+
+
+experience. Since this affidavit is being submitted for the limited purpose of securing a search
+warrant, I have not included each and every fact known to me concerning this investigation, but have
+set forth only those facts necessary to establish probable cause to believe that evidence,
+instrumentalities, and fruits of crimes, that is violations of Title 18, United States Code, Sections
+371, 1591, 2252, 2252A, 2422, and 2423 will be found within the CompactFlash memory cards,
+specifically the electronic information contained therein.
+The Statutes Involved
+4.
+The investigation involves possible violations of Title 18, United States Code,
+Sections 371, 1591, 2252, 2252A, 2422, and 2423, which provide as follows:
+a.
+18 U.S.C. § 371 makes it an offense for two or more persons to conspire to
+commit an offense against the United States;
+b.
+18 U.S.C. § 1591(a) makes it an offense for anyone to knowingly, in or
+affecting interstate commerce, recruit, entice, provide, or obtain by any means a person, knowing
+that the person has not attained the age of eighteen and will be caused to engage in a commercial sex
+act;
+c.
+18 U.S.C. §§ 2252 and 2252A prohibit the manufacture, possession,
+distribution, and receipt of child pornography;
+d.
+18 U.S.C. § 2422(b) prohibits the use of a facility of interstate commerce,
+including the telephone, to persuade, induce, or entice a minor to engage in prostitution or any sexual
+activity for which any person can be charged with a criminal offense; and
+e.
+18 U.S.C. § 2423(b) makes it an offense for anyone to travel in interstate
+commerce for the purpose of engaging in any illicit sexual conduct with another person. "Illicit
+
+
+sexual conduct" includes a commercial sex act with a person under eighteen or other sexual conduct
+Section 2422(b) refers to activity "for which any person can be charged with a
+criminal offense." Pursuant to:
+a.
+Florida Statutes Section 794.05, a "person 24 years of age or older who
+engages in sexual activity with a person 16 or 17 years of age commits a felony of the second
+degree;"
+Florida Statutes Section 794.021, "ignorance of the age [of the victim]
+is no defense," and that neither "misrepresentation of age by [the victim] nor a bona fide
+belief that such person is over the specified age [shall] be a defense;"
+Florida Statutes Sections 800.04(5)(a) and 800.04(5)(c)(2), an adult
+"who intentionally touches in a lewd or lascivious manner the breasts, genitals, genital area,
+or buttocks, or the clothing covering them, of a person less than 16 years of age, or forces or
+entices a person under 16 years of age to so touch the perpetrator, commits lewd or lascivious
+molestation," which is a felony of the second degree if the victim is 12 years of age or older
+but less than 16 years of age;
+Florida Statutes Sections 800.04(6)(a) and 800.04(6)(b), an adult "who
+[i]ntentionally touches a person under 16 years of age in a lewd or lascivious manner or
+[solicits a person under 16 years of age to commit a lewd or lascivious act commits lewd or
+
+
+e.
+Florida Statutes Sections 800.04(7)(a) and 800.04(7)(c), an adult "who:
+(1) [i]ntentionally masturbates; (2) [i]ntentionally exposes the genitals in a lewd or lascivious
+manner; or (3) [i]ntentionally commits any other sexual act that does not involve actual
+physical or sexual contact with the victim, including, but not limited to ... the simulation of
+any act involving sexual activity in the presence of a victim who is less than 16 years of age,
+commits lewd or lascivious exhibition," which is a felony of the second degree.
+f.
+Florida Statutes Section 800.04(2), "[n]either the victim's lack of
+chastity nor the victim's consent is a defense to the crimes proscribed by [Section 800.04]."
+Florida Statutes Section 800.04(3), "It]he perpetrator's ignorance of the
+victim's age, the victim's misrepresentation of his or her age, or the perpetrator's bona fide
+belief of the victim's age cannot be raised as a defense in a prosecution under [Section
+800.04]."
+h.
+Florida Statutes Section 800.02, a "person who commits any unnatural
+and lascivious act with another person commits a misdemeanor of the second degree."
+The Epstein Investigation
+6.
+In the Spring of 2006, Detective
+with the Townof Palm Beach Police
+Department contacted me about the investigation of Jeffrey Epstein's solicitation of minors to
+engage in prostitution and his lewd and lascivious conduct with minors. The FBI opened a case file
+in July 2006, and your Affiant is the case agent assigned to the investigation.
+At around the same time that the FBI opened its investigation, the U.S. Attorney's
+Office began a grand jury investigation. Your Affiant is one of the agents on the Federal Rule of
+
+
+Criminal Procedure 6(e) list, that is, someone who is authorized to have access to the facts of the
+As part of the Federal Grand Jury investigation, a subpoena was issued for all of the
+physical evidence obtained by PBPD during the course of its investigation, including the evidence
+seized when PBPD executed the search warrant at Epstein's residence in October 2005. Included
+in the evidence seized during the search of the Premises were the two CompactFlash memory cards.
+I have reviewed that evidence, which included a number of photographs of topless and nude young
+women taken at Epstein's residence. The evidence, including the two CompactFlash memory cards
+that are the subject of this application, have been in the custody of the Federal Bureau of
+Investigation since August 2006 and have not been tampered with or altered. Prior to that, they were
+in the custody of the Evidence Custodian of the Palm Beach Police Department, and I understand
+that the evidence was not tampered with or altered while in PBPD's custody.
+9.
+I note that I am aware that Epstein's attorneys have alleged that Detective
+made misstatements in his application for the state search warrant, but they have not moved to
+suppress any of that evidence in connection with the prosecution of Epstein by the State Attorney's
+Office for felony solicitation of prostitution. No federal agency was involved in the application for
+or execution of the search warrant, and this application is based upon evidence obtained through the
+FBI's independent investigation.
+10.
+During the course of the federal investigation, federal agents have interviewed more
+than two dozen young women who have reported engaging in sexual activity with Jeffrey Epstein
+while they were under eighteen. All of those girls have reported essentially the same information.
+While they were under the age of eighteen (between the ages of fourteen and seventeen), they were
+
+
+approached by a colleague - either an acquaintance at school, a co-worker, a "friend of a friend," or
+the like - who told them that they could make a lot of money performing a "massage" for a wealthy
+older man who lived on Palm Beach island. In some cases the girls were told that they would have
+to remove some clothing during the massage, other girls were not told about this. The girls traveled
+to Epstein's residence and entered through a side door into the kitchen of the residence. There they
+were met by Epstein and/or one of his personal assistants, usually
+The girls would be
+led up to the master bathroom area of Epstein's bedroom. The bathroom had a separate room similar
+to a dressing area where a massage table would be set up. The girls described the presence of nude
+and topless photographs of young women throughout the house. Epstein would lie face down on the
+massage table and the girl would begin by massaging his back and legs. Epstein would then turn
+over and begin to masturbate while instructing the girl to pinch his nipples or to straddle him. In
+some cases, Epstein would place a large back massager/vibrator on the victim's vagina. With some
+girls, he would digitally penetrate her vagina while he masturbated. The sexual activity with some
+minors progressed to oral sex, sexual intercourse, and the introduction of an adult female into the
+activity. With some girls, the sexual activity began with the first massage; with others, there was no
+sexual activity at first but sexual activity occurred in later massages; and in many cases, Epstein
+pushed the girls to engage in more and more sexual activity with each visit.
+11.
+Almost all of the sexual massages ended the same way, when Epstein ejaculated.
+Epstein or one of his assistants would pay the girl $200 or more, depending on how much sexual
+activity occurred. A fee of $200 also would be paid to the "recruiter" who brought the girl for the
+visit. If Epstein liked the girl, he or his assistant would ask for the girl's telephone number. Later,
+one of Epstein's assistants would call the girl directly to arrange for the girl to return. In some
+
+
+instances of scheduling a girl for "work," which was a euphemism for performing a sexual massage,
+Epstein's assistants would make the atrangement for the next time that Epstein was in Florida.
+During those calls, the assistant would invite the girl to return to Epstein's home to "work." None
+of the girls ever spontaneously went to Epstein's home to provide a sexual massage. The
+appointments were set up over the telephone.
+12.
+The victims interviewed by the federal agents were asked about Epstein's knowledge
+that they were minors. Many of the victims specifically discussed their ages with Epstein, and he
+provided them with birthday gifts, made statements about trips that he wanted to take them on when
+they were eighteen, and discussed high school events and college plans with them. Forother victims,
+the subject of age was never discussed, and for others, their "recruiter" instructed them to lie and say
+they were eighteen.
+13.
+One of the young women interviewed during the course of the FBI's investigation was
+who stated that she first met Epstein at the age of fourteen. Epstein paid $200 - $400 to
+provide him with massages. According to during the three years that she saw Epstein, all but
+three of the over one hundred massages she provided were sexual in nature. The sexual activity
+ranged from self masturbation on Epstein's part to Epstein touching||
+vagina. On a separate
+occasion, Epstein introduce an unidentified female during a massage, who performed oral sex on
+while Epstein had sexual intercourse with the unidentified female.
+14.
+When was approximately sixteen years old,
+, Epstein's assistant,
+contacted| and told her that Epstein wanted
+to take some photographs of her.
+utilizing a digital camera, took nude photographs of
+in several different locations in and around
+
+
+victims interviewed have repeatedly pointed to the existence of the pictures of nude and semi-nude
+Efforts have been made to corroborate the statements of||
+and the other young
+women who have described their sexual relationships with Epstein. With respect to , there are
+telephone records showing
+phone calls to|| during the time period that she was seeing
+Epstein.|L also described receiving gifts from Epstein via Federal Express. A grand jury subpoena
+issued to Federal Express contained records of a number of packages sent by Epstein or his assistants
+to| Likewise, the statements of other victims have been corroborated through telephone records,
+Western Union records, travel records, credit card receipts, sales records of theaters, and rental car
+records.
+16.
+Also, during the FBI's investigation, I interviewed a young woman,
+who had
+known Epstein several years ago, when she was in her late teens/early twenties. The woman was a
+struggling artist in New York who was specializing in painting nude portraits. Prior to preparing a
+portrait,
+would take several photographic studies. Epstein was very interested in her work and
+her photographs, and also expressed an interest in the artist's younger sister,
+who was sixteen
+years old at the time.
+17.
+Epstein and an associate/companion, Ghislaine Maxwell, made arrangements and paid
+for to travel to one of his homes, located in New Mexico. One morning during that visit, Epstein
+got into bed with
+Mr. Epstein told that he felt like "cuddling."
+described Epstein's actions
+as "spooning" and constantly hugging her.
+18.
+Epstein and Maxwell also made arrangements and paid for to fly hometo
+for the primary purpose of taking artistic photographs of her family members in the nude. This
+
+
+included the artist's younger siblings, two sisters, and al
+Due to the sensitive nature of the photographs,
+image and the order it was taken. Later, learned that seven photographs, two of and five of the
+were missing.| who was very upset, contacted Epstein's office and asked for one
+of Epstein's assistants to look for the missing photographs. L
+also confronted Epstein and Maxwell
+about the missing photographs which they claimed they did not possess. A few weeks later L
+received a telephone call from an unidentified caller who stated that the missing photographs were
+in Epstein's briefcase. The missing photographs were not recovered and believes that Epstein is
+in possession of them. Although those photo graphs were artistic, rather than pornographic in nature,
+this further shows Epstein's interest in taking and maintaining nude and semi-nude photographs of
+minors.
+19.
+Thave interviewed and about their experiences with Epstein. Bothand are
+reluctant to divulge their experiences publically. During the interview with
+she was visibly
+disturbed when recalling an incident with Epstein at his ranch in New Mexico when she was sixteen
+years old. stated that one evening Epstein had come into her bedroom and sat on the bed. Epstein
+stroked her hair and told her she was beautiful. was unable to recall the remainder of any events
+that evening.| has also expressed her concern of speaking publicly against Epstein for fear of
+reprisals against her or her family.
+The Items to Be Searched and the Information Sought
+20.
+This application seeks permission to forensically examine two CompactFlash memory
+cards. Your Affiant knows that electronic media,
+important to a criminal investigation because the objects may be used as storage devices that contain
+
+
+contraband, evidence, instrumentalities, or fruits of a crime in the form of electronic data. Rule 41
+of the Federal Rules of Criminal Procedure permit the government to search for and seize computer
+hardware, software, and electronic files that are evidence of crime, contraband, instrumentalities of
+crime and/or fruits of crime. I know that CompactFlash memory cards are most often used in digital
+cameras to store photographs taken with the cameras. However, memory cards can be used to store
+any type of digital data, including computer files.
+21.
+The nature of electronic media, i.e., CompactFlash memory cards, requires forensic
+analysis to employ a variety of different search techniques. These techniques include, but are not
+limited to, opening files, reviewing directories of files, and searching for and analyzing deleted
+and/or hidden information. While conducting the analysis, data will be continuously evaluated as
+to whether or not it is within the scope of the issued search warrant. Only information within the
+scope of the search warrant will be acknowledged, shared with, or provided to, the investigators
+involved in this matter. All other information will be closed and maintained within the analytical
+unit. Forensic analysis will be conducted in close consultation with the United States Attorney's
+office for specific legal guidance throughout the analytical and reporting process.
+22.
+I understand that reviewing the contents of the CompactFlash memory cards was
+within the scope of the State search warrant that gave rise to the seizure of the cards from Epstein's
+residence, and that PBPD reviewed the contents of the cards. I also understand that an FBI agent
+conducted a similar review when all of the items were taken into federal custody pursuant to the
+federal grand jury subpoena. Those reviews did not involve a forensic examination to determine if
+there were any deleted or corrupted files, which could be recovered only via such a forensic analysis.
+I understand that the cursory reviews performed by the other law enforcement officers did not delete
+
+
+or add any files to the CompactFlash memory cards and, therefore, they contain the same information
+that they had at the time they were removed from the Epstein residence. While the cursory review
+performed by the FBI agent did not exceed the scope of the PBPD's review, and therefore did not
+require the issuance of a warrant, the forensic review that is requested by this application would
+expand that review and, accordingly, your Affiant requests the issuance of a search warrant in
+accordance with United States v. Jacobsen, 466 U.S. 109, 115-21 (1984).
+23.
+As explained above, Epstein instructed one of his assistants to photograph using
+a digital camera; reported Epstein's unusual interest in, and probable theft of, nude photographs
+of the minor members of her family; and Epstein engaged in inappropriate sexual activity with
+numerous minor females. In light of Epstein's display of photographs of nude and semi-nude young
+women throughout his residence, your Affiant avers that there is probable cause to believe that
+photographs or other evidence of the victims' visits to Epstein's residence may be found on the
+CompactFlash memory cards. Accordingly, your Affiant seeks permission to forensically examine
+the CompactFlash memory cards for evidence, instrumentalities, and fruits of the crimes listed
+above, that is, the electronic information contained within the memory cards, including electronic
+files containing photographs, owner identification information, date and time information, names,
+addresses, and information regarding the source of any photographs or the persons depicted in any
+photographs.
+24.
+Although the cursory reviews did not reveal any of the items sought, your Affiant
+avers that there is probable cause to believe that a thorough forensic examination, which would
+include the recovery of any deleted or corrupted files, would result in the discovery of the data listed
+above, which is evidence, instrumentalities, and fruits of the crimes under investigation.
+
+
+WHEREFORE, your Affiant requests that this court issue a search warrant for the
+CompactFlash memory cards described in the Application for Search Warrant and for the seizure of
+FURTHER YOUR AFFIANT SAYETH NAUGHT.
+11 Special Agent
+Federal Bureau of Investigation
+Subscribed and sworn to before me
+this
+- 17 day of March, 2008
+I m
+Lemm
+
+
+IN RE
+APPLICATION FOR SEARCH WARRANT
+FOR ONE RITZ BIG PRINT DIGITAL FILM
+128 MEGABYTE COMPACT FLASH MEMORY CARD
+MARKED 3608128AW4801CF53 IN THE CUSTODY
+OF THE FEDERAL BUREAU OF INVESTIGATION
+2.
+3.
+4.
+CRIMINAL COVER SHEET
+Did this matter originate from a matter pending in the United States Attorney's Office prior
+to April 1, 1999?
+Yes
+If yes, was it pending in the Central Region?
+Yes
+No
+Did this matter originate from a matter pending in the United States Attorney's Office prior
+to April 1, 2003.
+X No
+Did this matter originate from a matter pending in the Narcotics Section (Miami) of the
+United States Attorney's Office prior to May 18, 2003?
+Yes X No
+Did this matter originate from a matter pending in the Northern Region of the United States
+Attorney's Office prior to October 14, 2003?
+_Yes
+X No
+Did this matter originate from a matter pending in the Central Region of the United States
+Attorney's Office prior to September 1, 2007?
+_Yes
+X No
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+ASSISTANT UNITED STATES ATTORNEY
+Florida Bar No. L
+West Palm Beach, FL 33401
+
+
+IN RE:
+SEARCH WARRANT APPLICATION
+ORDER GRANTING UNITED STATES' MOTION TO SEAL
+This matter comes before the Court upon the United States' Motion to Seal the
+documents related to its Search Warrant Application. The Court being fully apprised in the
+premises, orders that the motion is hereby GRANTED.
+DONE AND ORDERED in chambers, in West Palm Beach, Florida, this / Z day of
+March, 2008.
+LINNEA R. JOHNSO
+cc:
+AUSA
+Cortified to be
+* true and
+correct copy of the document on file
+Dale
+3-17-0 gry clerk
+
+
+(Rev. 06/2005)Scaled Document Tracking Form
+Number: 08-8067-LRJ
+In Re
+SEARCH WARRANT APPLICATION
+Party Filing Matter Under Seal
+SEALED DOCUMENT TRACKING FORM
+Name:
+I. U.S. Attorne's Office
+Address: 500 S. Australian Ave, Suite 400, West Palm Beach, FL. 33401
+• Plaintiff
+• Defendant
+On behalf of (select one):
+Date sealed document filed: 3/17/2008
+If sealed pursuant to statute, cite statute: Fed. R. Crim. P. 6(e) (Grand Jury Material)
+If sealed pursuant to previously entered protective order, date of order and docket entry number:
+The matter should remain sealed until:
+• Conclusion of Trial
+Z Case Closing
+• Arrest of First Defendant
+• Conclusion of Direct Appeal
+• Other:
+• Permanently. Specify the authorizing law, rule, court order:
+The moving party requests that when the sealing period expires, the filed matter should be (select one):
+Unsealed and placed in the public portion of the court file
+• Returned to the party or counsel for the party, as identified above
+
+
+IN RE:
+SEARCH WARRANT APPLICATION
+MOTION TO FILE DOCUMENTS UNDER SEAL
+The United States of America, by and through the undersigned Assistant United States
+Attorney, hereby moves to seal its Application for Search Warrant for the following reasons:
+1.
+The attached documents contain information relating to an ongoing grand jury
+investigation; thus, pursuant to Fed. R. Crim. P. 6(e)(6), all records and orders related to the grand-
+• jury proceedings must be kept under seal to the extent and as long as necessary to prevent the
+unauthorized disclosure of a matter occurring before the grand jury.
+Public disclosure of this matter would jeopardize the criminal investigation, notify
+potential subjects and/or targets and undermine the public interest and the function of the grand jury.
+WHEREFORE, the United States respectfully requests that the aforementioned documents
+be sealed.
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+RI
+sistant inter States Attemay
+V
+
+
+_ DISTRICT OF _
+SOUTHERN
+FLORIDA
+Nant, the Matter of the Stares of earthe
+One Ritz Big Print Digital Film
+APPLICATION AND AFFIDAVIT
+128 Megabyte CompactFlash memory card
+FOR SEARCH WARRANT
+marked 3608128AW4801CF53
+in the custody of the Federal Bureau of Investigation
+CASE NUMBER: 08-8067-LRJ
+I,
+_ being duly sworn, depose and say:
+I am a Special Agent, Federal Bureau of Investigation
+, and have reason to believe
+that
+_ on the person of or X
+_ on the premises known as (name, description and/or location):
+One Ritz Big Print Digital Film 128 Megabyte CompactFlash memory card,
+marked 3608128AW4801CF53,
+in the custody of the Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500, West Palm Beach, Florida
+in the
+Southern
+District of
+Florida
+there is now concealed a certain person or property, namely (describe the person or property):
+the electronic information contained in that CompactFlash memory card,
+which is (give alleged grounds for search and seizure under Rule 41(b) of the Federal Rules of Criminal Procedure)
+evidence, instrumentalities, and fruits of a crime, concerning violations of Title 18, United States Code,
+Sections 371, 1591, 2252, 2252A, 2422, and 2423.
+The facts to support the issuance of a Search Warrant are as follows:
+see Attached Affidavit of
+Continued on the attached sheet and made a part hereof. X Yes Na n
+Sworn to before me, and subscribed in my presence: on ite
+3-17-08
+Steven N..
+Latinor:
+Clerk,
+at
+Distrid
+Lour
+Southern Distr
+Date
+UNTIED STATES MAGISTRATE JUDGE
+ву Манам.
+3-17 yeier
+WEST PALM BEACH, FLORIDA
+Cly and Slate
+
+
+I, E.
+1.
+I am a Special Agent with the Federal Bureau of Investigation ("FBI") and have been
+so employed for the past ten (10) years. I am currently assigned to PB-2, the Violent Crimes and
+Major Offenses Squad of the Palm Beach County Resident Agency, Miami Division. Among my
+responsibilities as a Special Agent are investigating crimes against children, particularly offenses
+involving child pornography and the exploitation of children.
+2.
+I make this affidavit in support of an application by the United States of America for
+issuance of a warrant to search and seize evidence of violations of Title 18, United States Code,
+Sections 371, 1591, 2252, 2252A, 2422, and 2423; instrumentalities of such violations; and any
+fruits of those crimes located within electronic media, specifically two 128MB CompactFlash
+memory cards, seized in October 2005 by The Town of Palm Beach Police Department"PBPD")
+during the execution of a State of Florida search warrant at the premises located at 358 El Brillo
+Way, Palm Beach, Florida 33480, owned by Jeffrey Epstein (hereinafter, "Epstein's residence").
+Those CompactFlash memory cards are more fully described as follows: (a) one Ritz Big Print
+Digital Film 128 Megabyte CompactFlash memory card, marked 3608128AW4801CF53, and (b)
+one PNY Technologies 128 Megabyte CompactFlash memory card, marked
+THNCF128MMA(T00CB) 999223 TAIWAN AN (hereinafter jointly referred to as "CompactFlash
+memory cards").
+3.
+The facts set forth in this affidavit are based on my personal knowledge, information
+obtained in this investigation from others, including other law enforcement officers, my review of
+documents and records related to this investigation, and information gained through my training and
+
+
+experience. Since this affidavit is being submitted for the limited purpose of securing a search
+warrant, I have not included each and every fact known to me concerning this investigation, but have
+set forth only those facts necessary to establish probable cause to believe that evidence,
+instrumentalities, and fruits of crimes, that is violations of Title 18, United States Code, Sections
+371, 1591, 2252, 2252A, 2422, and 2423 will be found within the CompactFlash memory cards,
+specifically the electronic information contained therein.
+The Statutes Involved
+4.
+The investigation involves possible violations of Title 18, United States Code,
+Sections 371, 1591, 2252, 2252A, 2422, and 2423, which provide as follows:
+a.
+18 U.S.C. § 371 makes it an offense for two or more persons to conspire to
+commit an offense against the United States;
+b.
+18 U.S.C. § 1591(a) makes it an offense for anyone to knowingly, in or
+affecting interstate commerce, recruit, entice, provide, or obtain by any means a person, knowing
+that the person has not attained the age of eighteen and will be caused to engage in a commercial sex
+act;
+c.
+18 U.S.C. §§ 2252 and 2252A prohibit the manufacture, possession,
+distribution, and receipt of child pornography;
+d.
+18 U.S.C. § 2422(b) prohibits the use of a facility of interstate commerce,
+including the telephone, to persuade, induce, or entice a minor to engage in prostitution or any sexual
+activity for which any person can be charged with a criminal offense; and
+e.
+18 U.S.C. § 2423(b) makes it an offense for anyone to travel in interstate
+commerce for the purpose of engaging in any illicit sexual conduct with another person. "Illicit
+
+
+sexual conduct" includes a commercial sex act with a person under eighteen or other sexual conduct
+Section 2422(b) refers to activity "for which any person can be charged with a
+criminal offense." Pursuant to:
+a.
+Florida Statutes Section 794.05, a "person 24 years of age or older who
+engages in sexual activity with a person 16 or 17 years of age commits a felony of the second
+degree;"
+b.
+Florida Statutes Section 794.021, "ignorance of the age [of the victim]
+is no defense," and that neither "misrepresentation of age by [the victim] nor a bona fide
+belief that such person is over the specified age [shall] be a defense;"
+Florida Statutes Sections 800.04(5)(a) and 800.04(5)(c)(2), an adult
+"who intentionally touches in a lewd or lascivious manner the breasts, genitals, genital area,
+or buttocks, or the clothing covering them, of a person less than 16 years of age, or forces or
+entices a person under 16 years of age to so touch the perpetrator, commits lewd or lascivious
+molestation," which is a felony of the second degree if the victim is 12 years of age or older
+but less than 16 years of age;
+d.
+Florida Statutes Sections 800.04(6)(a) and 800.04(6)(b), an adult "who
+[i]ntentionally touches a person under 16 years of age in a lewd or lascivious manner or
+[solicits a person under 16 years of age to commit a lewd or lascivious act commits lewd or
+
+
+Florida Statutes Sections 800.04(7)(a) and 800.04(7)(c), an adult "who:
+(1) [i]ntentionally masturbates; (2) [i]ntentionally exposes the genitals in a lewd or lascivious
+manner; or (3) [i]ntentionally commits any other sexual act that does not involve actual
+physical or sexual contact with the victim, including, but not limited to ... the simulation of
+any act involving sexual activity in the presence of a victim who is less than 16 years of age,
+commits lewd or lascivious exhibition," which is a felony of the second degree.
+Florida Statutes Section 800.04(2), "InJeither the victim's lack of
+chastity nor the victim's consent is a defense to the crimes proscribed by [Section 800.04]."
+g.
+Florida Statutes Section 800.04(3), "It]he perpetrator's ignorance of the
+victim's age, the victim's misrepresentation of his or her age, or the perpetrator's bona fide
+belief of the victim's age cannot be raised as a defense in a prosecution under [Section
+800.04]."
+h.
+Florida Statutes Section 800.02, a "person who commits any unnatural
+and lascivious act with another person commits a misdemeanor of the second degree."
+The Epstein Investigation
+6.
+In the Spring of 2006, Detectivel
+with the Town of Palm Beach Police
+Department contacted me about the investigation of Jeffrey Epstein's solicitation of minors to
+engage in prostitution and his lewd and lascivious conduct with minors. The FBI opened a case file
+in July 2006, and your Affiant is the case agent assigned to the investigation.
+At around the same time that the FBI opened its investigation, the U.S. Attorney's
+Office began a grand jury investigation. Your Affiant is one of the agents on the Federal Rule of
+
+
+Criminal Procedure 6(e) list, that is, someone who is authorized to have access to the facts of the
+As part of the Federal Grand Jury investigation, a subpoena was issued for all of the
+physical evidence obtained by PBPD during the course of its investigation, including the evidence
+seized when PBPD executed the search warrant at Epstein's residence in October 2005. Included
+in the evidence seized during the search of the Premises were the two CompactFlash memory cards.
+I have reviewed that evidence, which included a number of photographs of topless and nude young
+women taken at Epstein's residence. The evidence, including the two CompactFlash memory cards
+that are the subject of this application, have been in the custody of the Federal Bureau of
+Investigation since August 2006 and have not been tampered with or altered. Prior to that, they were
+in the custody of the Evidence Custodian of the Palm Beach Police Department, and I understand
+that the evidence was not tampered with or altered while in PBPD's custody.
+9.
+I note that I am aware that Epstein's attorneys have alleged that Detective
+made misstatements in his application for the state search warrant, but they have not moved to
+suppress any of that evidence in connection with the prosecution of Epstein by the State Attorney's
+Office for felony solicitation of prostitution. No federal agency was involved in the application for
+or execution of the search warrant, and this application is based upon evidence obtained through the
+FBI's independent investigation.
+10.
+During the course of the federal investigation, federal agents have interviewed more
+than two dozen young women who have reported engaging in sexual activity with Jeffrey Epstein
+while they were under eighteen. All of those girls have reported essentially the same information.
+While they were under the age of eighteen (between the ages of fourteen and seventeen), they were
+
+
+approached by a colleague - either an acquaintance at school, a co-worker, a "friend of a friend," or
+the like - who told them that they could make a lot of money performing a "massage" for a wealthy
+older man who lived on Palm Beach island. In some cases the girls were told that they would have
+to remove some clothing during the massage, other girls were not told about this. The girls traveled
+to Epstein's residence and entered through a side door into the kitchen of the residence. There they
+were met by Epstein and/or one of his personal assistants, usually
+The girls would be
+led up to the master bathroom area of Epstein's bedroom. The bathroom had a separate room similar
+to a dressing area where a massage table would be set up. The girls described the presence of nude
+and topless photographs of young women throughout the house. Epstein would lie face down on the
+massage table and the girl would begin by massaging his back and legs. Epstein would then turn
+over and begin to masturbate while instructing the girl to pinch his nipples or to straddle him. In
+some cases, Epstein would place a large back massager/vibrator on the victim's vagina. With some
+girls, he would digitally penetrate her vagina while he masturbated. The sexual activity with some
+minors progressed to oral sex, sexual intercourse, and the introduction of an adult female into the
+activity. With some girls, the sexual activity began with the first massage; with others, there was no
+sexual activity at first but sexual activity occurred in later massages; and in many cases, Epstein
+pushed the girls to engage in more and more sexual activity with each visit.
+11.
+Almost all of the sexual massages ended the same way, when Epstein ejaculated.
+Epstein or one of his assistants would pay the girl $200 or more, depending on how much sexual
+activity occurred. A fee of $200 also would be paid to the "recruiter" who brought the girl for the
+visit. If Epstein liked the girl, he or his assistant would ask for the girl's telephone number. Later,
+one of Epstein's assistants would call the girl directly to arrange for the girl to return. In some
+
+
+instances of scheduling a girl for "work," which was a euphemism for performing a sexual massage,
+Epstein's assistants would make the arrangement for the next time that Epstein was in Florida.
+During those calls, the assistant would invite the girl to return to Epstein's home to "work." None
+of the girls ever spontaneously went to Epstein's home to provide a sexual massage. The
+appointments were set up over the telephone.
+12.
+The victims interviewed by the federal agents were asked about Epstein's knowledge
+that they were minors. Many of the victims specifically discussed their ages with Epstein, and he
+provided them with birthday gifts, made statements about trips that he wanted to take them on when
+they were eighteen, and discussed high school events and college plans with them. For other victims,
+the subject of age was never discussed, and for others, their "recruiter" instructed them to lie and say
+they were eighteen.
+13.
+One of the young women interviewed during the course of the FBI's investigation was
+who stated that she first met Epstein at the age of fourteen. Epstein paid $200 - $400 to
+provide him with massages.
+. According to during the three years that she saw Epstein, all but
+three of the over one hundred massages she provided were sexual in nature. The sexual activity
+ranged from self masturbation on Epstein's part to Epstein touching|
+› vagina. On a separate
+occasion, Epstein introduce an unidentified female during a massage, who performed oral sex on
+while Epstein had sexual intercourse with the unidentified female.
+14.
+When was approximately sixteen years old,
+Epstein's assistant,
+contacted and told her that Epstein wanted
+to take some photographs of her.
+utilizing a digital camera, took nude photographs of in several different locations in and around
+
+
+victims interviewed have repeatedly pointed to the existence of the pictures of nude and semi-nude
+Efforts have been made to corroborate the statements offli and the other young
+women who have described their sexual relationships with Epstein. With respect to ill there are
+telephone records showing 1
+phone calls to i during the time period that she was seeing
+Epstein. Kalso described receiving gifts from Epstein via Federal Express. A grand jury subpoena
+issued to Federal Express contained records of a number of packages sent by Epstein or his assistants
+to Likewise, the statements of other victims have been corroborated through telephone records,
+Western Union records, travel records, credit card receipts, sales records of theaters, and rental car
+records.
+16.
+Also, during the FBI's investigation, I interviewed a young woman,
+who had
+known Epstein several years ago, when she was in her late teens/early twenties. The woman was a
+struggling artist in New York who was specializing in painting nude portraits. Prior to preparing a
+portrait,
+would take several photographic studies. Epstein was very interested in her work and
+her photographs, and also expressed an interest in the artist's younger sister,
+who was sixteen
+years old at the time.
+17.
+Epstein and an associate/companion, Ghislaine Maxwell, made arrangements and paid
+for to travel to one of his homes, located in New Mexico. One morning during that visit, Epstein
+got into bed with
+Mr. Epstein told that he felt like "cuddling. "I described Epstein's actions
+as "spooning" and constantly hugging her.
+18.
+Epstein and Maxwell also made arrangements and paid for to fly home to LI
+for the primary purpose of taking artistic photographs of her family members in the nude. This
+
+
+Due to the sensitive nature of the photographs.
+image and the order it was taken. Later.
+learned that seven photographs, two off
+and five of the
+, were missing./L
+who was very upset, contacted Epstein's office and asked for one
+of Epstein's assistants to look for the missing photographs l
+also confronted Epstein and Maxwell
+about the missing photographs which they claimed they did not possess. A few weeks later
+received a telephone call from an unidentified caller who stated that the missing photographs were
+in Epstein's briefcase. The missing photographs were not recovered and believes that Epstein is
+in possession of them. Although those photographs were artistic, rather than pornographic in nature,
+this further shows Epstein's interest in taking and maintaining nude and semi-nude photographs of
+minors.
+19
+Thave interviewed an
+about their experiences with Epstein. Both
+land
+are
+reluctant to divulge their experiences publically. During the interview with, she was visibly
+disturbed when recalling an incident with Epstein at his ranch in New Mexico when she was sixteen
+years old. stated that one evening Epstein had come into her bedroom and sat on the bed. Epstein
+stroked her hair and told her she was beautiful.| was unable to recall the remainder of any events
+that evening.| as also expressed her concern of speaking publicly against Epstein for fear of
+reprisals against her or her family.
+The Items to Be Searched and the Information Sought
+20.
+This application seeks permission to forensically examine two CompactFlash memory
+cards. Your Affiant knows that electronic media,
+important to a criminal investigation because the objects may be used as storage devices that contain
+
+
+contraband, evidence, instrumentalities, or fruits of a crime in the form of electronic data. Rule 41
+of the Federal Rules of Criminal Procedure permit the government to search for and seize computer
+hardware, software, and electronic files that are evidence of crime, contraband, instrumentalities of
+crime and/or fruits of crime. I know that CompactFlash memory cards are most often used in digital
+cameras to store photographs taken with the cameras. However, memory cards can be used to store
+any type of digital data, including computer files.
+21.
+The nature of electronic media, i.e., CompactFlash memory cards, requires forensic
+analysis to employ a variety of different search techniques. These techniques include, but are not
+limited to, opening files, reviewing directories of files, and searching for and analyzing deleted
+and/or hidden information. While conducting the analysis, data will be continuously evaluated as
+to whether or not it is within the scope of the issued search warrant. Only information within the
+scope of the search warrant will be acknowledged, shared with, or provided to, the investigators
+involved in this matter. All other information will be closed and maintained within the analytical
+unit. Forensic analysis will be conducted in close consultation with the United States Attorney's
+office for specific legal guidance throughout the analytical and reporting process.
+22.
+I understand that reviewing the contents of the CompactFlash memory cards was
+within the scope of the State search warrant that gave rise to the seizure of the cards from Epstein's
+residence, and that PBPD reviewed the contents of the cards. I also understand that an FBI agent
+conducted a similar review when all of the items were taken into federal custody pursuant to the
+federal grand jury subpoena. Those reviews did not involve a forensic examination to determine if
+there were any deleted or corrupted files, which could be recovered only via such a forensic analysis.
+I understand that the cursory reviews performed by the other law enforcement officers did not delete
+
+
+or add any files to the CompactFlash memory cards and, therefore, they contain the same information
+that they had at the time they were removed from the Epstein residence. While the cursory review
+performed by the FBI agent did not exceed the scope of the PBPD's review, and therefore did not
+require the issuance of a warrant, the forensic review that is requested by this application would
+expand that review and, accordingly, your Affiant requests the issuance of a search warrant in
+accordance with United States v. Jacobsen, 466 U.S. 109, 115-21 (1984).
+23.
+As explained above, Epstein instructed one of his assistants to photograph
+using
+a digital camera;
+reported Epstein's unusual interest in, and probable theft of, nude photographs
+of the minor members of her family; and Epstein engaged in inappropriate sexual activity with
+numerous minor females. In light of Epstein's display of photographs of nude and semi-nude young
+women throughout his residence, your Affiant avers that there is probable cause to believe that
+photographs or other evidence of the victims' visits to Epstein's residence may be found on the
+CompactFlash memory cards. Accordingly, your Affiant seeks permission to forensically examine
+the CompactFlash memory cards for evidence, instrumentalities, and fruits of the crimes listed
+above, that is, the electronic information contained within the memory cards, including electronic
+files containing photographs, owner identification information, date and time information, names,
+addresses, and information regarding the source of any photographs or the persons depicted in any
+photographs.
+24.
+Although the cursory reviews did not reveal any of the items sought, your Affiant
+avers that there is probable cause to believe that a thorough forensic examination, which would
+include the recovery of any deleted or corrupted files, would result in the discovery of the data listed
+above, which is evidence, instrumentalities, and fruits of the crimes under investigation.
+
+
+WHEREFORE, your Affiant requests that this court issue a search warrant for the
+CompactFlash memory cards described in the Application for Search Warrant and for the seizure of
+FURTHER YOUR AFFIANT SAYETH NAUGHT.
+Special Agent
+Federal Bureau of Investigation
+Subscribed and sworn to before me
+this — / 7 day of March, 2008
+Lemo
+
+
+IN RE
+APPLICATION FOR SEARCH WARRANT
+FOR ONE RITZ BIG PRINT DIGITAL FILM
+128 MEGABYTE COMPACT FLASH MEMORY CARD
+MARKED 3608128AW4801CF53 IN THE CUSTODY
+OF THE FEDERAL BUREAU OF INVESTIGATION
+CRIMINAL COVER SHEET
+Did this matter originate from a matter pending in the United States Atlomey's Office prior
+to April 1, 1999?
+If yes, was it pending in the Central Region?
+Yes
+No
+2.
+3.
+Did this matter originate from a matter pending in the United States Attorney's Office prior
+to April 1, 2003?
+Yes
+X No
+Did this matter originate from a matter pending in the Narcotics Section (Miami) of the
+United States Attorney's Office prior to May 18, 2003?
+Yes
+X No
+4. Did this matter originate from a matter pending in the Northern Region of the United States
+Attorney's Office prior to October 14, 2003?
+X No
+Did this matter originate from a matter pending in the Central Region of the United States
+Attorney's Office prior to September 1, 2007?
+_Yes
+X No
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNTIED STATES ATTARNEY
+BY:
+A
+ASSISTANT UNITED STATES ATTORNEY
+Florida Bar No.
+West Palm Beach, FL. 33401
+
+
+IN RE
+APPLICATION FOR SEARCH WARRANT
+FOR ONE RITZ BIG PRINT DIGITAL FILM
+128 MEGABYTE COMPACT FLASH MEMORY CARD
+MARKED 3608128AW4801CF53 IN THE CUSTODY
+OF THE FEDERAL BUREAU OF INVESTIGATION
+1.
+CRIMINAL COVER SHEET
+Did this matter originate from a matter pending in the United States Attorney's Office prior
+to April 1, 1999?
+Yes
+No
+If yes, was it pending in the Central Region?
+Yes
+No
+2.
+4.
+Did this matter originate from a matter pending in the United States Attorney's Office prior
+to April 1, 2003?
+-X No
+Did this matter originate from a matter pending in the Narcotics Section (Miami) of the
+United States Attorney's Office prior to May 18, 2003?
+Did this matter originate from a matter pending in the Northern Region of the United States
+Attorney's Office prior to October 14, 2003?
+X No
+Did this matter originate from a matter pending in the Central Region of the United States
+Attorney's Office prior to September 1, 2007?
+_ Yes
+_X No
+Respectfully submitted,
+R. ÁLEXANDER ACOSTA
+JINITED STATES ATTORNEY
+ASSISTANT UNITED STATES ATTORNEY
+Florida Bar No.
+
+
+IN RE:
+SEARCH WARRANT APPLICATION
+MOTION TO FILE DOCUMENTS UNDER SEAL
+The United States of America, by and through the undersigned Assistant United States
+Attorney, hereby moves to seal its Application for Search Warrant for the following reasons:
+The attached documents contain information relating to an ongoing grand jury
+investigation; thus, pursuant to Fed. R. Crim. P. 6(e)(6), all records and orders related to the grandjury proceedings must be kept under seal to the extent and as long as necessary to prevent the
+unauthorized disclosure of a matter occurring before the grand jury.
+Public disclosure of this matter would jeopardize the criminal investigation, notify
+potential subjects and/or targets and undermine the public interest and the function of the grand jury.
+WHEREFORE, the United States respectfully requests that the aforementioned documents
+be sealed.
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+V
+Assistant DeS as ANOT
+Florida Bar No.
+West Palm Beach. EL. 33401
+
+
+IN RE:
+SEARCH WARRANT APPLICATION
+ORDER GRANTING UNITED STATES' MOTION TO SEAL
+This matter comes before the Court upon the United States' Motion to Seal the
+documents related to its Search Warrant Application. The Court being fully apprised in the
+premises, orders that the motion is hereby GRANTED.
+DONE AND ORDERED in chambers, in West Palm Beach, Florida, this
+day of
+March, 2008.
+cc:
+I, AUSA
+
+
+Number: 08-8067-LRJ
+In Re
+SEARCH WARRANT APPLICATION
+Party Filing Matter Under Seal
+SEALED DOCUMENT TRACKING FORM
+Name:_
+J.S. Attorney's Office
+Address: 500 S. Australian Ave, Suite 400, West Palm Beach, FL 33401
+• Plaintiff
+• Defendant
+On behalf of (select one):
+Date sealed document filed: 3/17/2008
+If sealed pursuant to statute, cite statute: Fed. R. Crim. P. 6(e) (Grand Jury Material)
+If sealed pursuant to previously entered protective order, date of order and docket entry number:
+The matter should remain sealed until:
+• Conclusion of Trial
+• Case Closing
+• Arrest of First Defendant
+• Conclusion of Direct Appeal
+• Other: _
+• Permanently. Specify the authorizing law, rule, court order:
+The moving party requests that when the sealing period expires, the filed matter should be (select one):
+• Unsealed and placed in the public portion of the court file
+• Returned to the party or counsel for the party, as identified above
+
+
+ÀO 106 (Rev. 5/85) Affidavit for Search Warrant
+SOUTHERN
+Name, the Mate of the Start of cartet
+One Ritz Big Print Digital Film
+128 Megabyte CompactFlash memory card
+marked 3608128AW4801CF53
+in the custody of the Federal Bureau of Investigation
+FLORIDA
+APPLICATION AND AFFIDAVIT
+FOR SEARCH WARRANT
+that
+CASE NUMBER: 08-8067-LRJ
+I,.
+_ being duly sworn, depose and say:
+I am a Special Agent, Federal Bureau of Investigation
+, and have reason to believe
+on the person of or X_. on the premises known as (name, description and/or location):
+One Ritz Big Print Digital Film 128 Megabyte CompactFlash memory card,
+marked 3608128AW4801CF53,
+in the custody of the Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500, West Palm Beach, Florida
+District of
+Florida
+in the
+Southern
+there is now concealed a certain person or property, namely (describe the person or property):
+the electronic information contained in that CompactFlash memory card,
+which is (give alleged grounds for search and seizure under Rule 41(b) of the Federal Rules of Criminal Procedure)
+evidence, instrumentalities, and fruits of a crime, concerning violations of Title 18, United States Code,
+Sections 371, 1591, 2252, 2252A, 2422, and 2423.
+The facts to support the issuance of a Search Warrant are as follows:
+see Attached Affidavit of
+Continued on the attached sheet and made a part hereof._X Yes
+_No
+Sworn to before me, and subscribed in my presence:
+at
+Date
+UNTTED STATES MAGISTRATE JUDGE
+7 Special Agent
+Federal Bureau of Investigation
+WEST PALM BEACH, FLORIDA
+City and State
+
+
+I, E
+I am a Special Agent with the Federal Bureau of Investigation ("FBI) and have been
+so employed for the past ten (10) years. I am currently assigned to PB-2, the Violent Crimes and
+Major Offenses Squad of the Palm Beach County Resident Agency, Miami Division. Among my
+responsibilities as a Special Agent are investigating crimes against children, particularly offenses
+involving child pornography and the exploitation of children.
+I make this affidavit in support of an application by the United States of America for
+issuance of a warrant to search and seize evidence of violations of Title 18, United States Code,
+Sections 371, 1591, 2252, 2252A, 2422, and 2423; instrumentalities of such violations; and any
+fruits of those crimes located within electronic media, specifically two 128MB CompactFlash
+memory cards, seized in October 2005 by The Town of Palm Beach Police Department ("PBPD")
+during the execution of a State of Florida search warrant at the premises located at 358 El Brillo
+Way, Palm Beach, Florida 33480, owned by Jeffrey Epstein (hereinafter, "Epstein's residence").
+Those CompactFlash memory cards are more fully described as follows: (a) one Ritz Big Print
+Digital Film 128 Megabyte CompactFlash memory card, marked 3608128AW4801CF53, and (b)
+one PNY Technologies
+128 Megabyte CompactFlash memory card, marked
+THNCF128MMA(T00CB) 999223 TAIWAN 0247 (hereinafter jointly referred to as "CompactFlash
+memory cards").
+The facts set forth in this affidavit are based on my personal knowledge, information
+obtained in this investigation from others, including other law enforcement officers, my review of
+documents and records related to this investigation, and information gained through my training and
+
+
+experience. Since this affidavit is being submitted for the limited purpose of securing a search
+warrant, I have not included each and every fact known to me concerning this investigation, but have
+set forth only those facts necessary to establish probable cause to believe that evidence,
+instrumentalities, and fruits of crimes, that is violations of Title 18, United States Code, Sections
+371, 1591, 2252, 2252A, 2422, and 2423 will be found within the CompactFlash memory cards,
+specifically the electronic information contained therein.
+The Statutes Involved
+4.
+The investigation involves possible violations of Title 18, United States Code,
+Sections 371, 1591, 2252, 2252A, 2422, and 2423, which provide as follows:
+a.
+18 U.S.C. § 371 makes it an offense for two or more persons to conspire to
+commit an offense against the United States;
+b.
+18 U.S.C. § 1591(a) makes it an offense for anyone to knowingly, in or
+affecting interstate commerce, recruit, entice, provide, or obtain by any means a person, knowing
+that the person has not attained the age of eighteen and will be caused to engage in a commercial sex
+act;
+18 U.S.C. §§ 2252 and 2252A prohibit the manufacture, possession,
+distribution, and receipt of child pornography;
+d.
+18 U.S.C. § 2422(b) prohibits the use of a facility of interstate commerce,
+including the telephone, to persuade, induce, or entice a minor to engage in prostitution or any sexual
+activity for which any person can be charged with a criminal offense; and
+e.
+18 U.S.C. § 2423(b) makes it an offense for anyone to travel in interstate
+commerce for the purpose of engaging in any illicit sexual conduct with another person. "Illicit
+
+
+sexual conduct" includes a commercial sex act with a person under eighteen or other sexual conduct
+Section 2422(b) refers to activity "for which any person can be charged with a
+criminal offense." Pursuant to:
+a.
+Florida Statutes Section 794.05, a "person 24 years of age or older who
+engages in sexual activity with a person 16 or 17 years of age commits a felony of the second
+degree;"
+b. Florida Statutes Section 794.021, "ignorance of the age [of the victim]
+is no defense," and that neither "misrepresentation of age by [the victim] nor a bona fide
+belief that such person is over the specified age [shall] be a defense;"
+c.
+Florida Statutes Sections 800.04(5)(a) and 800.04(5)(c)(2), an adult
+"who intentionally touches in a lewd or lascivious manner the breasts, genitals, genital area,
+or buttocks, or the clothing covering them, of a person less than 16 years of age, or forces or
+entices a person under 16 years of age to so touch the perpetrator, commits lewd or lascivious
+molestation," which is a felony of the second degree if the victim is 12 years of age or older
+but less than 16 years of age;
+d.
+Florida Statutes Sections 800.04(6)(a) and 800.04(6)(b), an adult "who
+[i]ntentionally touches a person under 16 years of age in a lewd or lascivious manner or
+[solicits a person under 16 years of age to commit a lewd or lascivious act commits lewd or
+
+
+Florida Statutes Sections 800.04(7)(a) and 800.04(7)(c), an adult "who:
+(1) [i]ntentionally masturbates; (2) [i]ntentionally exposes the genitals in a lewd or lascivious
+manner; or (3) [i]ntentionally commits any other sexual act that does not involve actual
+physical or sexual contact with the victim, including, but not limited to ... the simulation of
+any act involving sexual activity in the presence of a victim who is less than 16 years of age,
+commits lewd or lascivious exhibition," which is a felony of the second degree.
+f.
+Florida Statutes Section 800.04(2), "[n]either the victim's lack of
+chastity nor the victim's consent is a defense to the crimes proscribed by [Section 800.04]."
+Florida Statutes Section 800.04(3), "It]he perpetrator's ignorance of the
+victim's age, the victim's misrepresentation of his or her age, or the perpetrator's bona fide
+belief of the victim's age cannot be raised as a defense in a prosecution under [Section
+800.041."
+h.
+Florida Statutes Section 800.02, a "person who commits any unnatural
+and lascivious act with another person commits a misdemeanor of the second degree."
+6.
+The Epstein Investigation
+In the Spring of 2006, Detective
+with the Town of Palm Beach Police
+Department contacted me about the investigation of Jeffrey Epstein's solicitation of minors to
+engage in prostitution and his lewd and lascivious conduct with minors. The FBI opened a case file
+in July 2006, and your Affiant is the case agent assigned to the investigation.
+7.
+At around the same time that the FBI opened its investigation, the U.S. Attorney's
+Office began a grand jury investigation. Your Affiant is one of the agents on the Federal Rule of
+
+
+Criminal Procedure 6(e) list, that is, someone who is authorized to have access to the facts of the
+As part of the Federal Grand Jury investigation, a subpoena was issued for all of the
+physical evidence obtained by PBPD during the course of its investigation, including the evidence
+seized when PBPD executed the search warrant at Epstein's residence in October 2005. Included
+in the evidence seized during the search of the Premises were the two CompactFlash memory cards.
+I have reviewed that evidence, which included a number of photographs of topless and nude young
+women taken at Epstein's residence. The evidence, including the two CompactFlash memory cards
+that are the subject of this application, have been in the custody of the Federal Bureau of
+Investigation since August 2006 and have not been tampered with or altered. Prior to that, they were
+in the custody of the Evidence Custodian of the Palm Beach Police Department, and I understand
+that the evidence was not tampered with or altered while in PBPD's custody.
+9.
+I note that I am aware that Epstein's attorneys have alleged that Detective
+made misstatements in his application for the state search warrant, but they have not moved to
+suppress any of that evidence in connection with the prosecution of Epstein by the State Attorney's
+Office for felony solicitation of prostitution. No federal agency was involved in the application for
+or execution of the search warrant, and this application is based upon evidence obtained through the
+FBI's independent investigation.
+10.
+During the course of the federal investigation, federal agents have interviewed more
+than two dozen young women who have reported engaging in sexual activity with Jeffrey Epstein
+while they were under eighteen. All of those girls have reported essentially the same information.
+While they were under the age of eighteen (between the ages of fourteen and seventeen), they were
+
+
+approached by a colleague - either an acquaintance at school, a co-worker, a "friend of a friend," or
+the like - who told them that they could make a lot of money performing a "massage" for a wealthy
+older man who lived on Palm Beach island. In some cases the girls were told that they would have
+to remove some clothing during the massage, other girls were not told about this. The girls traveled
+to Epstein's residence and entered through a side door into the kitchen of the residence. There they
+were met by Epstein and/or one of his personal assistants, usually
+The girls would be
+led up to the master bathroom area of Epstein's bedroom. The bathroom had a separate room similar
+to a dressing area where a massage table would be set up. The girls described the presence of nude
+and topless photographs of young women throughout the house. Epstein would lie face down on the
+massage table and the girl would begin by massaging his back and legs. Epstein would then turn
+over and begin to masturbate while instructing the girl to pinch his nipples or to straddle him. In
+some cases, Epstein would place a large back massager/vibrator on the victim's vagina. With some
+girls, he would digitally penetrate her vagina while he masturbated. The sexual activity with some
+minors progressed to oral sex, sexual intercourse, and the introduction of an adult female into the
+activity. With some girls, the sexual activity began with the first massage; with others, there was no
+sexual activity at first but sexual activity occurred in later massages; and in many cases, Epstein
+pushed the girls to engage in more and more sexual activity with each visit.
+11.
+Almost all of the sexual massages ended the same way, when Epstein ejaculated.
+Epstein or one of his assistants would pay the girl $200 or more, depending on how much sexual
+activity occurred. A fee of $200 also would be paid to the "recruiter" who brought the girl for the
+visit. If Epstein liked the girl, he or his assistant would ask for the girl's telephone number. Later,
+one of Epstein's assistants would call the girl directly to arrange for the girl to return. In some
+-0-
+
+
+instances of scheduling a girl for "work," which was a euphemism for performing a sexual massage,
+Epstein's assistants would make the arrangement for the next time that Epstein was in Florida.
+During those calls, the assistant would invite the girl to return to Epstein's home to "work." None
+of the girls ever spontaneously went to Epstein's home to provide a sexual massage. The
+appointments were set up over the telephone.
+12.
+The victims interviewed by the federal agents were asked about Epstein's knowledge
+that they were minors. Many of the victims specifically discussed their ages with Epstein, and he
+provided them with birthday gifts, made statements about trips that he wanted to take them on when
+they were eighteen, and discussed high school events and college plans with them. For other victims,
+the subject of age was never discussed, and for others, their "recruiter" instructed them to lie and say
+they were eighteen.
+13.
+One of the young women interviewed during the course of the FBI's investigation was
+who stated that she first met Epstein at the age of fourteen. Epstein paid $200 - $400 to
+provide him with massages. According toll, during the three years that she saw Epstein, all but
+three of the over one hundred massages she provided were sexual in nature. The sexual activity
+ranged from self masturbation on Epstein's part to Epstein touching i
+vagina. On a separate
+occasion, Epstein introduce an unidentified female during a massage, who performed oral sex on
+while Epstein had sexual intercourse with the unidentified female.
+14.
+When was approximately sixteen years old,
+contacted|| land told her that Epstein wanted
+Epstein's assistant,
+to take some photographs of her.
+utilizing a digital camera, took nude photographs of in several different locations in and around
+| paid 1$500 for posing for the nude photographs. Other
+
+
+victims interviewed have repeatedly pointed to the existence of the pictures of nude and semi-nude
+Efforts have been made to corroborate the statements of and the other young
+women who have described their sexual relationships with Epstein. With respect to there are
+telephone records showing
+phone calls to during the time period that she was seeing
+Epstein. |_ also described receiving gifts from Epstein via Federal Express. A grand jury subpoena
+issued to Federal Express contained records of a number of packages sent by Epstein or his assistants
+to | Likewise, the statements of other victims have been corroborated through telephone records,
+Western Union records, travel records, credit card receipts, sales records of theaters, and rental car
+records.
+16.
+Also, during the FBI's investigation, I interviewed a young woman,
+who had
+known Epstein several years ago, when she was in her late teens/early twenties. The woman was a
+struggling artist in New York who was specializing in painting nude portraits. Prior to preparing a
+portrait,
+would take several photographic studies. Epstein was very interested in her work and
+her photographs, and also expressed an interest in the artist's younger sister
+who was sixteen
+years old at the time.
+17.
+Epstein and an associate/companion, Ghislaine Maxwell, made arrangements and paid
+for to travel to one of his homes, located in New Mexico. One morning during that visit, Epstein
+got into bed with Mr. Epstein told
+that he felt like "cuddling: "I described Epstein's actions
+as "spooning" and constantly hugging her.
+18.
+Epstein and Maxwell also made arrangements and paid forl
+ko fly home to
+for the primary purpose of taking artistic photographs of her family members in the nude. This
+
+
+. Due to the sensitive nature of the photographs, created a photo log to document each
+image and the order it was taken. Later, learned that seven photographs, two of and five of the
+were missing.|I who was very upset, contacted Epstein's office and asked for one
+of Epstein's assistants to look for the missing photographs. also confronted Epstein and Maxwell
+about the missing photographs which they claimed they did not possess. A few weeks later|
+received a telephone call from an unidentified caller who stated that the missing photographs were
+in Epstein's briefcase. The missing photographs were not recovered and
+believes that Epstein is
+in possession of them. Although those photographs were artistic, rather than pornographic in nature,
+this further shows Epstein's interest in taking and maintaining nude and semi-nude photographs of
+minors.
+19.
+I have interviewed
+and
+about their experiences with Epstein. Both and
+are
+reluctant to divulge their experiences publically. During the interview with
+she was visibly
+disturbed when recalling an incident with Epstein at his ranch in New Mexico when she was sixteen
+years old.| stated that one evening Epstein had come into her bedroom and sat on the bed. Epstein
+stroked her hair and told her she was beautiful. was unable to recall the remainder of any events
+that evening.| has also expressed her concern of speaking publicly against Epstein for fear of
+reprisals against her or her family.
+The Items to Be Searched and the Information Sought
+20.
+This application seeks permission to forensically examine two CompactFlash memory
+cards. Your Affiant knows that electronic media,
+important to a criminal investigation because the objects may be used as storage devices that contain
+
+
+contraband, evidence, instrumentalities, or fruits of a crime in the form of electronic data. Rule 41
+of the Federal Rules of Criminal Procedure permit the government to search for and seize computer
+hardware, software, and electronic files that are evidence of crime, contraband, instrumentalities of
+crime and/or fruits of crime. I know that CompactFlash memory cards are most often used in digital
+cameras to store photographs taken with the cameras. However, memory cards can be used to store
+any type of digital data, including computer files.
+21.
+The nature of electronic media, i.e., CompactFlash memory cards, requires forensic
+analysis to employ a variety of different search techniques. These techniques include, but are not
+limited to, opening files, reviewing directories of files, and searching for and analyzing deleted
+and/or hidden information. While conducting the analysis, data will be continuously evaluated as
+to whether or not it is within the scope of the issued search warrant. Only information within the
+scope of the search warrant will be acknowledged, shared with, or provided to, the investigators
+involved in this matter. All other information will be closed and maintained within the analytical
+unit. Forensic analysis will be conducted in close consultation with the United States Attorney's
+office for specific legal guidance throughout the analytical and reporting process.
+22.
+I understand that reviewing the contents of the CompactFlash memory cards was
+within the scope of the State search warrant that gave rise to the seizure of the cards from Epstein's
+residence, and that PBPD reviewed the contents of the cards. I also understand that an FBI agent
+conducted a similar review when all of the items were taken into federal custody pursuant to the
+federal grand jury subpoena. Those reviews did not involve a forensic examination to determine if
+there were any deleted or corrupted files, which could be recovered only via such a forensic analysis.
+I understand that the cursory reviews performed by the other law enforcement officers did not delete
+
+
+or add any files to the CompactFlash memory cards and, therefore, they contain the same information
+that they had at the time they were removed from the Epstein residence. While the cursory review
+performed by the FBI agent did not exceed the scope of the PBPD's review, and therefore did not
+require the issuance of a warrant, the forensic review that is requested by this application would
+expand that review and, accordingly, your Affiant requests the issuance of a search warrant in
+accordance with United States v. Jacobsen, 466 U.S. 109, 115-21 (1984).
+23.
+As explained above, Epstein instructed one of his assistants to photograph using
+a digital camera reported Epstein's unusual interest in, and probable theft of, nude photographs
+of the minor members of her family; and Epstein engaged in inappropriate sexual activity with
+numerous minor females. In light of Epstein's display of photographs of nude and semi-nude young
+women throughout his residence, your Affiant avers that there is probable cause to believe that
+photographs or other evidence of the victims' visits to Epstein's residence may be found on the
+CompactFlash memory cards. Accordingly, your Affiant seeks permission to forensically examine
+the CompactFlash memory cards for evidence, instrumentalities, and fruits of the crimes listed
+above, that is, the electronic information contained within the memory cards, including electronic
+files containing photographs, owner identification information, date and time information, names,
+addresses, and information regarding the source of any photographs or the persons depicted in any
+photographs.
+24.
+Although the cursory reviews did not reveal any of the items sought, your Affiant
+avers that there is probable cause to believe that a thorough forensic examination, which would
+include the recovery of any deleted or corrupted files, would result in the discovery of the data listed
+above, which is evidence, instrumentalities, and fruits of the crimes under investigation.
+-11- l
+
+
+WHEREFORE, your Affiant requests that this court issue a search warrant for the
+CompactFlash memory cards described in the Application for Scarch Warrant and for the seizure of
+FURTHER YOUR AFFIANT SAYETH NAUGHT.
+1 Special Agent
+Federal Bureau of Investigation
+Subscribed and sworn to before me
+this
+day of March, 2008
+
+
+AO 93 (Rev. 5/85) Search Warrant
+SOUTHERN
+In the Matter of the Search of
+(Name, address or brief description of property or premises to be searched)
+One Ritz Big Print Digital Film
+128 Megabyte CompactFlash memory card,
+marked 3608128AW4801CF53
+in the custody of the Federal Bureau of Investigation
+FLORIDA
+SEARCH WARRANT
+CASE NUMBER 08-8067-LRJ
+FEDERAL BUREAU OF INVESTIGATION, and any Authorized Officer of the United
+who has reason to
+TO: E.
+States:
+Affidavit(s) having been made before me by
+Attant
+believe that
+Lon the person of or [X]on the premises known as (name, description and/or location)
+One Ritz Big Print Digital Film 128 Megabyte CompactFlash memory card,
+marked 3608128AW4801CF53
+in the custody of the Federal Bureau of Investigation,
+505 S. Flagler Drive, Suite 500, West Palm Beach, Florida
+FLORIDA
+in the
+SOUTHERN
+District of
+concealed a certain person or property, namely (describe the person or property)
+the electronic information contained in that CompactFlash memory card,
+there is now
+which is property that constitutes evidence of the commission of a criminal offense, instrumentalities of such
+violations; and any fruits of those crimes, that is, violations of 18 U.S.C. 55 371, 1591, 2252, 2252A, 2422, and
+I am satisfied that the affidavit(s) and any recorded testimony establish probable cause to believe that the person
+or property so described is now concealed on the person or premises above-described and establish grounds for the
+issuance of this warrant.
+YOU ARE HEREBY COMMANDED to search on or before
+(not to exceed 10 days) the person or place named above for the person or property specified, serving this warrant
+and making the search (in the daytime - 6:00 A.M. to 10:00 P.M.)(at any time in the day or night as I find
+_ at WEST PALM BEACH, FLORIDA
+City and State
+Date and Time Issued
+United States Magistrate Judge
+
+
+No. 08-8067-LRJ
+APPLICATION FOR SEARCH WARRANT
+FOR ONE RITZ BIG PRINT DIGITAL FILM
+128 MEGABYTE COMPACT FLASH MEMORY CARD
+MARKED 3608128AW4801CF53 IN THE CUSTODY
+OF THE FEDERAL BUREAU OF INVESTIGATION
+1.
+CRIMINAL COVER SHEET
+Did this matter originate from a matter pending in the United States Attorney's Office prior
+to April 1, 1999?
+Yes
+If yes, was it pending in the Central Region?
+Yes
+2.
+3.
+4.
+Did this matter originate from a matter pending in the United States Attorney's Office prior
+to April 1, 2003?
+X No
+Did this matter originate from a matter pending in the Narcotics Section (Miami) of the
+United States Attorney's Office prior to May 18, 2003?
+Yes_X No
+Did this matter originate from a matter pending in the Northern Region of the United States
+Attorney's Office prior to October 14, 2003?
+Did this matter originate from a matter pending in the Central Region of the United States
+Attorney's Office prior to September 1, 2007?
+_Yes
+X. No
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+BY:
+ASSISTANT UNITED STATES ATTORNEY
+Florida Bar No. MILLI
+West Palm Beach, FL 33401
+
+
+IN RE:
+SEARCH WARRANT APPLICATION
+MOTION TO FILE DOCUMENTS UNDER SEAL
+The United States of America, by and through the undersigned Assistant United States
+Attorney, hereby moves to seal its Application for Search Warrant for the following reasons:
+The attached documents contain information relating to an ongoing grand jury
+investigation; thus, pursuant to Fed. R. Crim. P. 6(e)(6), all records and orders related to the grandjury proceedings must be kept under seal to the extent and as long as necessary to prevent the
+unauthorized disclosure of a matter occurring before the grand jury.
+2.
+Public disclosure of this matter would jeopardize the criminal investigation, notify
+potential subjects and/or targets and undermine the public interest and the function of the grand jury.
+WHEREFORE, the United States respectfully requests that the aforementioned documents
+be sealed.
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+V
+Assistant Uned States Attorney
+Florida Bar No.
+West Palm Beach. FL. 33401
+
+
+IN RE:
+SEARCH WARRANT APPLICATION
+ORDER GRANTING UNITED STATES' MOTION TO SEAL
+This matter comes before the Court upon the United States' Motion to Seal the
+documents related to its Search Warrant Application. The Court being fully apprised in the
+premises, orders that the motion is hereby GRANTED.
+DONE AND ORDERED in chambers, in West Palm Beach, Florida, this
+_ day of
+March, 2008.
+cc:
+, AUSA
+
+
+Number: 08-8067-LRJ
+In Re
+SEARCH WARRANT APPLICATION
+Party Filing Matter Under Seal
+SEALED DOCUMENT TRACKING FORM
+Name:
+U.S. Attorney's Office
+Address: 500 S. Australian Ave, Suite 400. West Palm Beach, FL. 33401
+• Plaintiff
+• Defendant
+On behalf of (select one):
+Date sealed document filed: 3/17/2008
+If sealed pursuant to statute, cite statute: Fed. R. Crim. P. 6(e) (Grand Jury Material)
+If scaled pursuant to previously entered protective order, date of order and docket entry number:
+The matter should remain sealed until:
+• Conclusion of Trial
+7 Case Closing
+• Arrest of First Defendant
+• Conclusion of Direct Appeal
+• Other:
+• Permanently. Specify the authorizing law, rule, court order:
+The moving party requests that when the sealing period expires, the filed matter should be (select one):
+• Unsealed and placed in the public portion of the court file
+• Returned to the party or counsel for the party, as identified above
+
+
+SOUTHERN
+In the Matter of the Search of
+(Name, address or brief description of person to be searched)
+One Ritz Big Print Digital Film
+128 Megabyte CompactFlash memory card
+marked 3608128AW4801CF53
+in the custody of the Federal Bureau of Investigation
+FLORIDA
+APPLICATION AND AFFIDAVIT
+FOR SEARCH WARRANT
+CASE NUMBER: 08-8067-LRJ
+_, being duly sworn, depose and say:
+I am a Special Agent, Federal Bureau of Investigation
+_ and have reason to believe
+that
+on the person of or X
+_ on the premises known as (name, description and/or location):
+One Ritz Big Print Digital Film 128 Megabyte CompactFlash memory card,
+marked 3608128AW4801CF53,
+in the custody of the Federal Bureau of Investigation
+505 S. Flagler Drive, Suite 500, West Palm Beach, Florida
+in the
+Southern
+District of
+Florida
+there is now concealed a certain person or property, namely (describe the person or property):
+the electronic information contained in that CompactFlash memory card,
+which is (give alleged grounds for search and seizure under Rule 41(b) of the Federal Rules of Criminal Procedure)
+evidence, instrumentalities, and fruits of a crime, concerning violations of Title 18, United States Code,
+Sections 371, 1591, 2252, 2252A, 2422, and 2423.
+The facts to support the issuance of a Search Warrant are as follows:
+see Attached Affidavit of
+Continued on the attached sheet and made a part hereof. X Yes _No
+- M Special Agent
+Federal Bureau of Investigation
+Sworn to before me, and subscribed in my presence:
+at
+WEST PALM BEACH, FLORIDA
+City and State
+Date
+
+
+I,
+1.
+Iam a Special Agent with the Federal Bureau of Investigation ("FBI") and have been
+so employed for the past ten (10) years. I am currently assigned to PB-2, the Violent Crimes and
+Major Offenses Squad of the Palm Beach County Resident Agency, Miami Division. Among my
+responsibilities as a Special Agent are investigating crimes against children, particularly offenses
+involving child pornography and the exploitation of children.
+I make this affidavit in support of an application by the United States of America for
+issuance of a warrant to search and seize evidence of violations of Title 18, United States Code,
+Sections 371, 1591, 2252, 2252A, 2422, and 2423; instrumentalities of such violations; and any
+fruits of those crimes located within electronic media, specifically two 128MB CompactFlash
+memory cards, seized in October 2005 by The Town of Palm Beach Police Department ("PBPD")
+during the execution of a State of Florida search warrant at the premises located at 358 El Brillo
+Way, Palm Beach, Florida 33480, owned by Jeffrey Epstein (hereinafter, "Epstein's residence").
+Those CompactFlash memory cards are more fully described as follows: (a) one Ritz Big Print
+Digital Film 128 Megabyte CompactFlash memory card, marked 3608128AW4801CF53, and (b)
+one PNY Technologies 128 Megabyte CompactFlash memory card, marked
+THNCF128MMA(T0OCB) 999223 TAIWAN 0247 (hercinafter jointly referred to as "CompactFlash
+memory cards").
+3.
+The facts set forth in this affidavit are based on my personal knowledge, information
+obtained in this investigation from others, including other law enforcement officers, my review of
+documents and records related to this investigation, and information gained through my training and
+- 1-
+
+
+experience. Since this affidavit is being submitted for the limited purpose of securing a search
+warrant, I have not included each and every fact known to me concerning this investigation, but have
+set forth only those facts necessary to establish probable cause to believe that evidence,
+instrumentalities, and fruits of crimes, that is violations of Title 18, United States Code, Sections
+371, 1591, 2252, 2252A, 2422, and 2423 will be found within the CompactFlash memory cards,
+specifically the electronic information contained therein.
+The Statutes Involved
+4.
+The investigation involves possible violations of Title 18, United States Code,
+Sections 371, 1591, 2252, 2252A, 2422, and 2423, which provide as follows:
+a.
+18 U.S.C. § 371 makes it an offense for two or more persons to conspire to
+commit an offense against the United States;
+b.
+18 U.S.C. § 1591(a) makes it an offense for anyone to knowingly, in or
+affecting interstate commerce, recruit, entice, provide, or obtain by any means a person, knowing
+that the person has not attained the age of eighteen and will be caused to engage in a commercial sex
+act;
+C.
+18 U.S.C. §§ 2252 and 2252A prohibit the manufacture, possession,
+distribution, and receipt of child pornography;
+d.
+18 U.S.C. § 2422(b) prohibits the use of a facility of interstate commerce,
+including the telephone, to persuade, induce, or entice a minor to engage in prostitution or any sexual
+activity for which any person can be charged with a criminal offense; and
+e.
+18 U.S.C. § 2423(b) makes it an offense for anyone to travel in interstate
+commerce for the purpose of engaging in any illicit sexual conduct with another person. "Illicit
+- 2-.
+
+
+sexual conduct" includes a commercial sex act with a person under eighteen or other sexual conduct
+criminal offense." Pursuant to:
+Section 2422(b) refers to activity "for which any person can be charged with a
+a.
+Florida Statutes Section 794.05, a "person 24 years of age or older who
+engages in sexual activity with a person 16 or 17 years of age commits a felony of the second
+degree;"
+b.
+Florida Statutes Section 794.021, ignorance of the age [of the victim]
+is no defense," and that neither "misrepresentation of age by [the victim] nor a bona fide
+belief that such person is over the specified age [shall] be a defense;"
+C.
+Florida Statutes Sections 800.04(5)(a) and 800.04(5)(c)(2), an adult
+"who intentionally touches in a lewd or lascivious manner the breasts, genitals, genital area,
+or buttocks, or the clothing covering them, of a person less than 16 years of age, or forces or
+entices a person under 16 years of age to so touch the perpetrator, commits lewd or lascivious
+molestation," which is a felony of the second degree if the victim is 12 years of age or older
+but less than 16 years of age;
+d.
+Florida Statutes Sections 800.04(6)(a) and 800.04(6)(b), an adult "who
+[i]ntentionally touches a person under 16 years of age in a lewd or lascivious manner or
+[solicits a person under 16 years of age to commit a lewd or lascivious act commits lewd or
+
+
+Florida Statutes Sections 800.04(7)(a) and 800.04(7)(c), an adult "who:
+(1) [i]ntentionally masturbates; (2) [i]ntentionally exposes the genitals in a lewd or lascivious
+manner; or (3) [i]ntentionally commits any other sexual act that does not involve actual
+physical or sexual contact with the victim, including, but not limited to ... the simulation of
+any act involving sexual activity in the presence of a victim who is less than 16 years of age,
+commits lewd or lascivious exhibition," which is a felony of the second degree.
+f.
+Florida Statutes Section 800.04(2), "InJeither the victim's lack of
+chastity nor the victim's consent is a defense to the crimes proscribed by [Section 800.04]."
+g•
+Florida Statutes Section 800.04(3), "It]he perpetrator's ignorance of the
+victim's age, the victim's misrepresentation of his or her age, or the perpetrator's bona fide
+belief of the victim's age cannot be raised as a defense in a prosecution under [Section
+800.04]."
+h.
+Florida Statutes Section 800.02, a "person who commits any unnatural
+and lascivious act with another person commits a misdemeanor of the second degree."
+The Epstein Investigation
+6.
+In the Spring of 2006, Detective
+with the Town of Palm Beach Police
+Department contacted me about the investigation of Jeffrey Epstein's solicitation of minors to
+engage in prostitution and his lewd and lascivious conduct with minors. The FBI opened a case file
+in July 2006, and your Affiant is the case agent assigned to the investigation.
+7.
+At around the same time that the FBI opened its investigation, the U.S. Attorney's
+Office began a grand jury investigation. Your Affiant is one of the agents on the Federal Rule of
+
+
+Criminal Procedure 6(e) list, that is, someone who is authorized to have access to the facts of the
+As part of the Federal Grand Jury investigation, a subpoena was issued for all of the
+physical evidence obtained by PBPD during the course of its investigation, including the evidence
+seized when PBPD executed the search warrant at Epstein's residence in October 2005. Included
+in the evidence seized during the search of the Premises were the two CompactFlash memory cards.
+I have reviewed that evidence, which included a number of photographs of topless and nude young
+women taken at Epstein's residence. The evidence, including the two CompactFlash memory cards
+that are the subject of this application, have been in the custody of the Federal Bureau of
+Investigation since August 2006 and have not been tampered with or altered. Prior to that, they were
+in the custody of the Evidence Custodian of the Palm Beach Police Department, and I understand
+that the evidence was not tampered with or altered while in PBPD's custody.
+9.
+I note that I am aware that Epstein's attorneys have alleged that Detective
+made misstatements in his application for the state search warrant, but they have not moved to
+suppress any of that evidence in connection with the prosecution of Epstein by the State Attorney's
+Office for felony solicitation of prostitution. No federal agency was involved in the application for
+or execution of the search warrant, and this application is based upon evidence obtained through the
+FBI's independent investigation.
+10.
+During the course of the federal investigation, federal agents have interviewed more
+than two dozen young women who have reported engaging in sexual activity with Jeffrey Epstein
+while they were under eighteen. All of those girls have reported essentially the same information.
+While they were under the age of eighteen (between the ages of fourteen and seventeen), they were
+
+
+approached by a colleague - either an acquaintance at school, a co-worker, a "friend of a friend," or
+the like - who told them that they could make a lot of money performing a "massage" for a wealthy
+older man who lived on Palm Beach island. In some cases the girls were told that they would have
+to remove some clothing during the massage, other girls were not told about this. The girls traveled
+to Epstein's residence and entered through a side door into the kitchen of the residence. There they
+were met by Epstein and/or one of his personal assistants, usually
+The girls would be
+led up to the master bathroom area of Epstein's bedroom. The bathroom had a separate room similar
+to a dressing area where a massage table would be set up. The girls described the presence of nude
+and topless photographs of young women throughout the house. Epstein would lie face down on the
+massage table and the girl would begin by massaging his back and legs. Epstein would then turn
+over and begin to masturbate while instructing the girl to pinch his nipples or to straddle him. In
+some cases, Epstein would place a large back massager/vibrator on the victim's vagina. With some
+girls, he would digitally penetrate her vagina while he masturbated. The sexual activity with some
+minors progressed to oral sex, sexual intercourse, and the introduction of an adult female into the
+activity. With some girls, the sexual activity began with the first massage; with others, there was no
+sexual activity at first but sexual activity occurred in later massages; and in many cases, Epstein
+pushed the girls to engage in more and more sexual activity with each visit.
+11.
+Almost all of the sexual massages ended the same way, when Epstein ejaculated.
+Epstein or one of his assistants would pay the girl $200 or more, depending on how much sexual
+activity occurred. A fee of $200 also would be paid to the "recruiter" who brought the girl for the
+visit. If Epstein liked the girl, he or his assistant would ask for the girl's telephone number. Later,
+one of Epstein's assistants would call the girl directly to arrange for the girl to return. In some
+
+
+instances of scheduling a girl for "work," which was a euphemism for performing a sexual massage,
+Epstein's assistants would make the arrangement for the next time that Epstein was in Florida.
+During those calls, the assistant would invite the girl to return to Epstein's home to "work." None
+of the girls ever spontaneously went to Epstein's home to provide a sexual massage. The
+appointments were set up over the telephone.
+12.
+The victims interviewed by the federal agents were asked about Epstein's knowledge
+that they were minors. Many of the victims specifically discussed their ages with Epstein, and he
+provided them with birthday gifts, made statements about trips that he wanted to take them on when
+they were eighteen, and discussed high school events and college plans with them. For other victims,
+the subject of age was never discussed, and for others, their "recruiter" instructed them to lie and say
+they were eighteen.
+13.
+One of the young women interviewed during the course of the FBI's investigation was
+who stated that she first met Epstein at the age of fourteen. Epstein paid
+$200 - $400 to
+provide him with massages.
+According to during the three years that she saw Epstein, all but
+three of the over one hundred massages she provided were sexual in nature. The sexual activity
+ranged from self masturbation on Epstein's part to Epstein touching
+vagina. On a separate
+occasion, Epstein introduce an unidentified female during a massage, who performed oral sex on
+while Epstein had sexual intercourse with the unidentified female.
+14.
+When was approximately sixteen years old,
+Epstein's assistant,
+contacted and told her that Epstein wanted
+to take some photographs of her.
+utilizing a digital camera, took nude photographs of in several different locations in and around
+
+
+victims interviewed have repeatedly pointed to the existence of the pictures of nude and semi-nude
+Efforts have been made to corroborate the statements of
+and the other young
+women who have described their sexual relationships with Epstein. With respect to, there are
+telephone records showing
+phone calls to during the time period that she was seeing
+Epstein.
+also described receiving gifts from Epstein via Federal Express. A grand jury subpoena
+issued to Federal Express contained records of a number of packages sent by Epstein or his assistants
+to. Likewise, the statements of other victims have been corroborated through telephone records,
+Western Union records, travel records, credit card receipts, sales records of theaters, and rental car
+records.
+16.
+Also, during the FBI's investigation, I interviewed a young woman,
+who had
+known Epstein several years ago, when she was in her late teens/early twenties. The woman was a
+struggling artist in New York who was specializing in painting nude portraits. Prior to preparing a
+portrait,
+would take several photographic studies. Epstein was very interested in her work and
+her photographs, and also expressed an interest in the artist's younger sister,
+" who was sixteen
+years old at the time.
+17.
+Epstein and an associate/companion, Ghislaine Maxwell, made arrangements and paid
+for to travel to one of his homes, located in New Mexico. One morning during that visit, Epstein
+got into bed with. Mr. Epstein told that he felt like "cuddling."
+described Epstein's actions
+as "spooning" and constantly hugging her.
+18.
+Epstein and Maxwell also made arrangements and paid for to fly home tol
+for the primary purpose of taking artistic photographs of her family members in the nude. This
+
+
+Due to the sensitive nature of the photographs
+image and the order it was taken. Later, Icared that seven photographs, two of and five of the
+were missing.
+who was very upset, contacted Epstein's office and asked for one
+of Epstein's assistants to look for the missing photographs.
+also confronted Epstein and Maxwell
+about the missing photographs which they claimed they did not possess. A few weeks later
+received a telephone call from an unidentified caller who stated that the missing photographs were
+in Epstein's briefcase. The missing photographs were not recovered and
+belleves that Epstein 1s
+in possession of them. Although those photographs were artistic, rather than pornographic in nature,
+this further shows Epstein's interest in taking and maintaining nude and semi-nude photographs of
+minors.
+19.
+I have interviewed
+and
+about their experiences with Epstein. Both
+and are
+reluctant to divulge their experiences publically. During the interview with
+, she was visibly
+disturbed when recalling an incident with Epstein at his ranch in New Mexico when she was sixteen
+years old. stated that one evening Epstein had come into her bedroom and sat on the bed. Epstein
+stroked her hair and told her she was beautiful.
+was unable to recall the remainder of any events
+that evening.
+has also expressed her concern of speaking publicly against Epstein for fear of
+reprisals against her or her family.
+The Items to Be Searched and the Information Sought
+20.
+This application seeks permission to forensically examine two CompactFlash memory
+cards. Your Affiant knows that electronic media,
+important to a criminal investigation because the objects may be used as storage devices that contain
+
+
+contraband, evidence, instrumentalities, or fruits of a crime in the form of electronic data. Rule 41
+of the Federal Rules of Criminal Procedure permit the government to search for and seize computer
+hardware, software, and electronic files that are evidence of crime, contraband, instrumentalities of
+crime and/or fruits of crime. I know that CompactFlash memory cards are most often used in digital
+cameras to store photographs taken with the cameras. However, memory cards can be used to store
+any type of digital data, including computer files.
+21.
+The nature of electronic media, i.e., CompactFlash memory cards, requires forensic
+analysis to employ a variety of different search techniques. These techniques include, but are not
+limited to, opening files, reviewing directories of files, and searching for and analyzing deleted
+and/or hidden information. While conducting the analysis, data will be continuously evaluated as
+to whether or not it is within the scope of the issued search warrant. Only information within the
+scope of the search warrant will be acknowledged, shared with, or provided to, the investigators
+involved in this matter. All other information will be closed and maintained within the analytical
+unit. Forensic analysis will be conducted in close consultation with the United States Attorney's
+office for specific legal guidance throughout the analytical and reporting process.
+22.
+I understand that reviewing the contents of the CompactFlash memory cards was
+within the scope of the State search warrant that gave rise to the seizure of the cards from Epstein's
+residence, and that PBPD reviewed the contents of the cards. I also understand that an FBI agent
+conducted a similar review when all of the items were taken into federal custody pursuant to the
+federal grand jury subpoena. Those reviews did not involve a forensic examination to determine if
+there were any deleted or corrupted files, which could be recovered only via such a forensic analysis.
+I understand that the cursory reviews performed by the other law enforcement officers did not delete
+
+
+or add any files to the CompactFlash memory cards and, therefore, they contain the same information
+that they had at the time they were removed from the Epstein residence. While the cursory review
+performed by the FBI agent did not exceed the scope of the PPD's review, and therefore did not
+require the issuance of a warrant, the forensic review that is requested by this application would
+expand that review and, accordingly, your Affiant requests the issuance of a search warrant in
+accordance with United States v. Jacobsen, 466 U.S. 109, 115-21 (1984).
+23.
+As explained above, Epstein instructed one of his assistants to photograph using
+a digital camera;
+reported Epstein's unusual interest in, and probable theft of, nude photographs
+of the minor members of her family; and Epstein engaged in inappropriate sexual activity with
+numerous minor females. In light of Epstein's display of photographs of nude and semi-nude young
+women throughout his residence, your Affiant avers that there is probable cause to believe that
+photographs or other evidence of the victims' visits to Epstein's residence may be found on the
+CompactFlash memory cards. Accordingly, your Affiant seeks permission to forensically examine
+the CompactFlash memory cards for evidence, instrumentalities, and fruits of the crimes listed
+above, that is, the electronic information contained within the memory cards, including clectronic
+files containing photographs, owner identification information, date and time information, names,
+addresses, and information regarding the source of any photographs or the persons depicted in any
+photographs.
+24.
+Although the cursory reviews did not reveal any of the items sought, your Affiant
+avers that there is probable cause to believe that a thorough forensic examination, which would
+include the recovery of any deleted or corrupted files, would result in the discovery of the data listed
+above, which is evidence, instrumentalities, and fruits of the crimes under investigation.
+
+
+WHEREFORE, your Affiant requests that this court issue a search warrant for the
+CompactFlash memory cards described in the Application for Scarch Warrant and for the seizure of
+FURTHER YOUR AFFIANT SAYETH NAUGHT.
+I Special Agent
+Federal Bureau of Investigation
+Subscribed and sworn to before me
+this
+day of March, 2008
+
+
+AO 93 (Rev. 5/85) Search Warrant,
+SOUTHERN
+FLORIDA
+In the Matter of the Search of
+(Name, address or brief description of property or premises to be searched)
+One Ritz Big Print Digital Film
+128 Megabyte CompactFlash memory card,
+marked 3608128AW4801CF53
+in the custody of the Federal Bureau of Investigation
+SEARCH WARRANT
+CASE NUMBER 08-8067-LRJ
+FEDERAL BUREAU OF INVESTIGATION, and any Authorized Officer of the United
+States:
+Affidavit(s) having been made before me by
+who has reason to
+Affiant
+believe that on the person of or [X]on the premises known as (name, description and/or location)
+One Ritz Big Print Digital Film 128 Megabyte CompactFlash memory card,
+marked 3608128AW4801CF53
+in the custody of the Federal Bureau of Investigation,
+505 S. Flagler Drive, Suite 500, West Palm Beach, Florida
+in the
+SOUTHERN
+District of
+concealed a certain person or property, namely (describe the person or property)
+FLORIDA
+there is now
+the electronic information contained in that CompactFlash memory card,
+which is property that constitutes evidence of the commission of a criminal offense, instrumentalities of such
+violations; and any fruits of those crimes, that is, violations of 18 U.S.C. 59 371, 1591, 2252, 2252A, 2422, and
+I am satisfied that the affidavit(s) and any recorded testimony establish probable cause to believe that the person
+or property so described is now concealed on the person or premises above-described and establish grounds for the
+issuance of this warrant.
+YOU ARE HEREBY COMMANDED to search on or before
+(Date)
+(not to exceed 10 days) the person or place named above for the person or property specified, serving this warrant
+and making the search (in the daytime - 6:00 A.M. to 10:00 P.M.)(at any time in the day or night as 1 find
+reasonable cause has been established)) and if the person or property be found there to seize same, leaving a copy
+of this warrant and receipt for the person or property taken, and prepare a written inventory of the person or
+property seized and promptly return this warrant to the duty Magistrate Judge as required by law.
+at WEST PALM BEACH, FLORIDA
+City and State
+Date and Time Issued
+United States Magistrate Judge
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/d9fc82277bad8cd7d9a4dd9e0956d0df7d80815d3797ccc9153e88ec9f5e61b0.receipt.json b/vision-fixhub/ds9-unparsed-05/d9fc82277bad8cd7d9a4dd9e0956d0df7d80815d3797ccc9153e88ec9f5e61b0.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d053056cb6d38649b800e0d56a432d7822421ea9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/d9fc82277bad8cd7d9a4dd9e0956d0df7d80815d3797ccc9153e88ec9f5e61b0.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -6078,
+  "dataset": "marble-joined",
+  "doc_id": "d9fc82277bad8cd7d9a4dd9e0956d0df7d80815d3797ccc9153e88ec9f5e61b0",
+  "engine": "marble-apple-vision",
+  "event_count": 76,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "20769696d5260e388e38e5d858b6e911c9fabe91222f05ba1d5100559e031af5",
+  "output_sha256": "2d99d714b4b54fd7162e0b87fb55f00e4e81f351ec33b63aea2f42eaa7fdae44",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/dae7447835a7cf43ea215ac4d0f1fff885ccf0a78517cf9e2225b0db970c1e88.md b/vision-fixhub/ds9-unparsed-05/dae7447835a7cf43ea215ac4d0f1fff885ccf0a78517cf9e2225b0db970c1e88.md
new file mode 100644
index 0000000000000000000000000000000000000000..c3a110638992d21c87d3a6a28a707f523871cf0a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/dae7447835a7cf43ea215ac4d0f1fff885ccf0a78517cf9e2225b0db970c1e88.md
@@ -0,0 +1,2 @@
+Native Placeholder
+No Images Produced
diff --git a/vision-fixhub/ds9-unparsed-05/dae7447835a7cf43ea215ac4d0f1fff885ccf0a78517cf9e2225b0db970c1e88.receipt.json b/vision-fixhub/ds9-unparsed-05/dae7447835a7cf43ea215ac4d0f1fff885ccf0a78517cf9e2225b0db970c1e88.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..740c88c4f9646e69445ddfb60dd87fdc7e86bf0e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/dae7447835a7cf43ea215ac4d0f1fff885ccf0a78517cf9e2225b0db970c1e88.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "dae7447835a7cf43ea215ac4d0f1fff885ccf0a78517cf9e2225b0db970c1e88",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "409337fe3d98e988eb785409fadcbcf5f937d62a3b3396b973831d883fe73a96",
+  "output_sha256": "846cc48c4d9439d88bbfa81198172eb50ef898abf3a9ac9c30fcf62adcd7ff8c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/db8f2a700bc3fcac287a6aff83673753ebf771171c3e810e1de4b34469b0ef47.md b/vision-fixhub/ds9-unparsed-05/db8f2a700bc3fcac287a6aff83673753ebf771171c3e810e1de4b34469b0ef47.md
new file mode 100644
index 0000000000000000000000000000000000000000..063529e7b3384605a3e9a74b79e39324c57a2cb7
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/db8f2a700bc3fcac287a6aff83673753ebf771171c3e810e1de4b34469b0ef47.md
@@ -0,0 +1,57 @@
+U.S. ATTORNEY'S OFFICE
+SOUTHERN DISTRICT OF FLORIDA
+INDICTMENT/INFORMATION/RULE 20 APPROVAL COVER SHEET
+UNITED STATES OF AMERICA LIONS USAO NO..
+| AUSA
+JEFFREY EPSTEIN
+AUSA Delivered to Supervisor 6/8/09
+Date
+Time
+CHECK ALL OF THE FOLLOWING WHICH APPLY TO AND CASES
+X Indictment (Superseding) _ Information (Indictment Waiver Attached)
+SEALED
+RULE 20
+. OCDETF - FC/FLS/
+Operation
+- FIRREA Case
+- CORRUPTION Case (Federal/State/Local Official)
+PSN Case _ PSN Defendant
+(Name(s))
+X PSC (Project Safe Childhood) Case
+VIOLENT CRIME Case
+- OTHER (Credit card fraud, money laundering, illegal re-entry)
+10:00 p.m.
+VICTIM/WITNESS CASE: NO
+ESTIMATED NUMBER OF WITNESSES: _40_ (Persons subpoenaed)
+AUSA KING participated in this case/had supervisory authority over this case
+Reactive Case
+Prosecution Memorandum Attached: X Yes
+Asset Forfeiture Count: X_ Yes
+Arrest Warrants) Attached X
+sached Pa Not Require Chief, Asset Porture Division)
+Not Required
+Press Release Attached: _ Yes _ Not Required
+_ Yes - But SEALED-DO NOT RELEASE UNTIL AUTHORIZED
+Date and Time of Presentation: Tuesday. June 16, 2009
+We have reviewed the attached indictment/information with regard to legal sufficiency and find it will
+withstand a motion to dismiss for failure to state a crime.
+Final Approval Rtn'd for Revisions
+Section Deputy Chief
+Date/Time
+Section Chief
+Date/Time
+Chief, Criminal
+Date/Time
+Deputy Chief, Criminal Division
+First Assistant U.S. Attorney if Required)
+United States Attorney if Required)
+Date/Time
+Date/Time
+Date/Time
+Date/Time
+Date/Time
+Date/Time
+Date/Time
+Date/Time
+Date/Time
+(Rev. 3/1/06)
diff --git a/vision-fixhub/ds9-unparsed-05/db8f2a700bc3fcac287a6aff83673753ebf771171c3e810e1de4b34469b0ef47.receipt.json b/vision-fixhub/ds9-unparsed-05/db8f2a700bc3fcac287a6aff83673753ebf771171c3e810e1de4b34469b0ef47.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a6ee202a85d065c10d1fb9873637030eb906fc0d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/db8f2a700bc3fcac287a6aff83673753ebf771171c3e810e1de4b34469b0ef47.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "db8f2a700bc3fcac287a6aff83673753ebf771171c3e810e1de4b34469b0ef47",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "6a6ac164c474aaec29daef9184d8d2c95110d06d5669e36096677ff343d46393",
+  "output_sha256": "8c2c9daa7a7efae520a78df9ef4e69c50502d9871c4c11378ffe0d88f8596b70",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/dbb3c9dbc4d939568daed7501d2ac78d48067ad7568938e15b5e1deb964a95f4.md b/vision-fixhub/ds9-unparsed-05/dbb3c9dbc4d939568daed7501d2ac78d48067ad7568938e15b5e1deb964a95f4.md
new file mode 100644
index 0000000000000000000000000000000000000000..2a2c54ba2b083bf37bac126c3b7229a9a4c3c9bf
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/dbb3c9dbc4d939568daed7501d2ac78d48067ad7568938e15b5e1deb964a95f4.md
@@ -0,0 +1,3623 @@
+Statements
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ...................../.................
+Your Messages .....................................
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 29, 2002
+3
+3
+5
+5
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+23.408
+912,370
+$935,778
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+934,645
+1,134
+"This portfolio indudes one or more unpriced securties that are not
+relected in the Total Value of Securites and the Net Equity This Period
+Market Value of Your Portfolio
+Cash & Equivalent
+$935.778
+$934,645
+Current market value
+Last statement's market value
+Important Message
+If any information regarding
+2002interest, dividends,
+miscellaneous income
+gross proceeds or original
+issue discount is required
+to be reported to the IRS for
+his acated Form 109
+ill be mailed to you b
+1a4250 M.20 17, 2003.
+There are no "Stop Loss" orders or other pending bu
+or sell open orders on file for your account
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+: This statement should be retained for your records. See reverse side for important informati
+01/01/03;09:30 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+01/01/03:09:30 001
+VE39
+
+
+3 of5
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited.
+Net Cash Activity
+Closing Balance.
+THIS PERICO
+523.393.66
+1,119.47
+14.62
+$1,134.09
+......
+-1,119.47
+....
+$-1,119.47
+.....
+14.62
+$23.408.28
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+23,393.66
+$23,393.66
+CLOSING
+23,408.28
+$23,408.28
+.....
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+1,119.47
+14.62
+$1,134.09
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+YEAR TO DATE
+12,370.20
+6,845.77
+$19.215.97
+935,778
+5935.778
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+SYMBOUCUSIP
+QUANTITY
+FRICE
+MARKET
+VALUE
+23,408
+ESTIMATED
+ANNUAL INCOME
+027
+CURRENT
+YIELD (%)
+....
+01/01/03;09:30 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 29, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+VE39
+
+
+Your Portfolio Holdings (continued)
+CASH & CASH EQUIVALENTS (continued)
+DESCRIPTION
+BEAR STEARNS PRIME MONEY
+ARKET PORTFOLIO CL
+VIDEND REINVESTE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBCLCUSIP
+BSMXX
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+QUANTITY
+912,370.20
+PRICE
+1.0000
+EQUITIES
+Equities & Options
+DESCRIPTION
+BANPAIS SA-SPONSOREDADR
+REPSTO 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SIMBCUCUSIP
+BPIBY
+CASH
+QUANTITY
+20,000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD November 30,2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 29, 2002
+MARKET
+VALUE
+912,370
+$935,778
+ESTIMATED
+CURRENT
+ANNUAL INCOME
+YELD IN
+11,861
+1.3000
+$11,861
+PRICE
+Unpriced
+MARKE
+VALLI
+$0
+$0
+$11,861
+$935,778
+ANNUAL INCOME
+$0
+$0
+CURRENT
+YIELD IN
+027
+01/01/03:09:30 001
+
+
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+TRANSACTION
+11/30/02
+12ö202ÖMDEND
+12/02/02
+REINVEST
+........a
+12/31/02
+TOTAL
+INTEREST
+DESCAPTION
+12223102 AT 034% NI21 THRU ALANCE
+TOTAL
+Your messages
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+OPENINGBALANCE
+RARE FORST ME, MONEY
+RECORD 11/29/02 PAY 11/29/02
+MAKE PORT LOVE, MONEY
+REINVEST PRICE $ 1.00
+CLOSINGBALANCE
+SYMBOL/CUSIP
+As part of the National Association of Securities Dealer's (NASD)
+Investor Education Program, you may obtain information on the
+SYMBOUCUSIP
+BMXX
+BMXX
+QUANTITY
+QUANTITY
+911,250.73
+1,119.47
+912,370.20
+RATE (NI
+0.7500
+027
+DEBIT AMOUNT
+01/01/03;09:30 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 29, 2002
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,119.47
+1,119.47
+$-1,119.47
+$1,119.47
+CREDIT AMOUNT
+14.62
+$14.62
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .......••••••••••••••••••/•IIIIIIII/I
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25, 2002
+3
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+23.394
+911.251
+$934,645
+NET EQUITY LAST STATEMENT
+933.311
+CHANGE SINCE LAST STATEMENT
+1,333
+"This portfolio indudes one or more unpriced securtles that are not
+relected in the Total Value of Securites and the Net Equity This Period
+Market Value of Your Portfolio
+Cash & Equivalent
+S934.645
+$933,311
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited.
+Net Cash Activity
+Closing Balance.
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+23,373.37
+.....
+1,312.59
+20.29
+$1,332.88
+-1,312.59
+.....
+5-1,312.59
+....
+20.29
+23.393.66
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+23,373.37
+$23,373.37
+CLOSING
+23,393.66
+$23,393.66
+......
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+1,312.59
+20.29
+$1,332.88
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+YEAR TO DATE
+11,250.73
+6,831.15
+$18,081.88
+934,645
+$934,645
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+SYMBOUCUSIP
+QUANTITY
+FRICE
+MARKET
+VALUE
+23,394
+027
+ESTIMATED
+ANNUAL INCOME
+CURRENT
+YIELD (%)
+....
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings (continued)
+CASH & CASH EQUIVALENTS (continued)
+DESCRIPTION
+BEAR STEARNS PRIME MONEY
+ARKET PORTFOLIO CL
+VIDEND REINVESTE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBCLCUSIP
+BSMXX
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+QUANTITY
+911,250.73
+PRICE
+1.0000
+EQUITIES
+Equities & Options
+DESCRIPTION
+BANPAIS SA-SPONSOREDADR
+REPSTO 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SIMBCUCUSIP
+BPIBY
+CASH
+QUANTITY
+20,000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25,2002
+MARKET
+VALUE
+911,251
+$934,645
+ESTIMATED
+CURRENT
+ANNUAL INCOME
+YIELD IN
+12,758
+1.4001
+$12,758
+PRICE
+Unpriced
+MARKE
+VALLI
+$0
+$0
+$12,758
+$934,645
+CURRENT
+YIELD IN
+$0
+$0
+027
+
+
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+TRANSACTION
+10/26/02
+11701702 BIMDEND
+17/01/02
+REINVEST
+.....
+11/29/02
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+11/21/02
+11721/02 INTEREST ON CREDIT BALANCE"
+AT 1 1/4% 10/21 THRU 11/05
+TOTAL
+STOP
+* End of Statement****
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+OPENINGBALANCE
+RARE TORPET ME, MONEY
+RECORD 10/31/02 PAY 10/31/02
+MAKE PORT LOVE, MONEY
+REINVEST PRICES S1.00
+CLOSINGBALANCE
+SYMBOUCUSIP
+BMXX
+BMXX
+SYMBOL/CUSIP
+QUANTITY
+QUANTITY
+909,938.14
+1,312.59
+911,250.73
+RATE (%)
+0.7500
+1.2500
+027
+PRICE
+DEBIT AMOUNT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 25, 2002
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,312.59
+1,312.59
+$-1,312.59
+$1,312.59
+CREDIT AMOUNT
+7.30
+12.99
+$20.29
+VE38
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail .................................
+Fund Activity .......•••••••••••••••••IIIIIIIIII/I
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+3
+4
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+23.373
+909,938
+$933.311
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+1,131,752
+-198.441
+"This portfolio indudes one or more unpriced securtles that are not
+refected in the Total Value of Securtes and the Net Equity This Period.
+Market Value of Your Portfolio
+Cash & Equivalent
+8933.31 51.131,752
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+
+
+2 of 6
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 ore
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Funds Withdrawn
+Amount Debited
+Net Cash Activity
+Closing Balance
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+$23,349.05
+201,554.85
+24.32
+$201,579.17
+......
+-1,554.85
+-200,000.00
+........S.201.554.85
+24.32
+23.373.37
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+23,349.05
+$23,349.05
+Income Summary
+THIS PERIOD
+Dividends
+1,535.61
+Credit Balance Int.
+24.32
+Total
+$1,559.93
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+027
+CLOSING
+23,373.37
+$23,373.37
+......
+YEAR TO DATE
+9,938.14
+6,810.86
+... .
+$16,749.00
+933,311
+naaaaaan.
+$933,311
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+........
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+BSMXX
+QUANTITY
+909,938.14
+1.0000
+SYMECUCUSIP
+BPIBY
+CASH
+QUANTITY
+20,000
+MARKET
+VALUE
+23,373
+909,938
+$933,311
+PRICE
+Unpriced
+STIMATE
+NUAL INCON
+15,378
+$15,378
+1.6900
+MARKEE
+$0
+$0
+$15,378
+$933,311
+ANNUAL NOME
+$0
+$0
+URREN
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD September 28,2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+
+
+5 of 8
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+09/30/02
+TRANSACTION
+FND WIRED
+DESCRIPTION
+MDA#
+ENDS WIRED TO
+IPMORSAKRSFASE BANK
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+TRANSACTION
+09/28/02
+09/30/02
+SOLD
+їö01702
+"DIMBEND
+10/01/02
+REINVEST
+''DIVIDEND
+DESCRIPTION
+OPENINGBALANCE
+MAKE PORT OLD ME, MONEY
+RARES PAVE, MONEY
+RECORD 09/30/02 PAY 09/30/02
+RARE TASTINE, MONEY
+REINVEST PRICE $ 1,00
+ARE TEASE ME, MONEY
+10/08/02"FUND"
+MAKE FORNICE, MONEY
+ADJUST DIVIDEND FROM 9/30
+REDEMPTION
+11025/02
+TOTAL
+CLOSINGBALANCE
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DEBIT AMOUNT
+200,000.00
+$-200,000.00
+CREDIT AMOUNT
+SYMBOUCUSIP
+BMXX
+BSMIX
+BMXX
+QUANTITY
+1,108,402.53
+200,000
+1,545.23
+9.62
+909,938.14
+PRICE
+1.0000
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+DEBIT AMOUNT
+CREDIT AMOUNT
+200,000.00
+1,545.23
+1,545.23
+*9.62
+$-1,554.85
+9.62
+$201,554.85
+VE37
+
+
+6 of 8
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+10/21/02
+INTEREST ON CREDIT BALANCE
+AT 1 1/4% 09/21 THRU 10/20
+TOTAL
+SYMBOUCUSIP
+QUANTITY
+RATE (%)
+1.2500
+STOP
+*** End of Statement******
+027
+DEBIT AMOUNT
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 27,2002
+CREDIT AMOUNT
+24.32
+$24.32
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ...................../..................
+Your Messages .....................................
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+3
+3
+5
+6
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+23,349
+1,108,403
+NET EQUITY THIS PERIOD
+$1, 131,752
+......
+NET EQUITY LAST STATEMENT
+1,130,110
+CHANGE SINCE LAST STATEMENT
+1,642
+"This portfolio indudes one or more unpriced securtles that are not
+relected in the Total Value of Securites and the Net Equity This Period
+Market Value of Your Portfolio
+Cash & Equivalent
+$1,131,752
+$1,130,110
+Current market value
+Last statement's market value
+Important Message
+Confirmation: Unless we
+hear from you to the
+contrary, it is our
+understanding that any free
+redit balances in your
+ccount are bein
+maintained to facilitate
+such amount thirugh us.
+There are no "Stop Loss" orders or other pending bu
+or sell open orders on file for your account
+Flease report any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+
+
+2 of 8
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited.
+Net Cash Activity
+Closing Balance.
+THIS PERICO
+523,323.94
+1,616.06
+25.11
+$1,641.17
+•........
+-1,616.06
+.. . .
+$-1,616.06
+25.11
+$23.349.05
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+23,323.94
+$23,323.94
+CLOSING
+23,349.05
+$23,349.05
+............
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+1,616.06
+25.11
+$1,641.17
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+YEAR TO DATE
+8,402.53
+6,786.54
+$15,189.07
+1,131,752
+51. 131.752
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+SYMBOUCUSIP
+QUANTITY
+FRICE
+MARKET
+VALUE
+23,349
+ESTIMATED
+ANNUAL INCOME
+027
+CURRENT
+YIELD (%)
+....
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30,2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+4 of a
+Your Portfolio Holdings (continued)
+CASH & CASH EQUIVALENTS (continued)
+DESCRIPTION
+BEAR STEARNS PRIME MONEY
+LARKET PORTFOLIO CL
+VIDEND REINVESTE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+BSMXX
+EQUITIES
+Equities & Options
+DESCRIPTION
+BANPAIS SA-SPONSOREDADR
+REPSTO 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SIMBCUCUSIP
+BPIBY
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+QUANTITY
+1,108,402.53
+PRICE
+1.0000
+CASH
+QUANTITY
+20,000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+MARKET
+VALUE
+1,108,403
+$1,131,752
+ESTIMATED
+CURREN
+ANNUAL INCOME
+YIELD IS
+18,510
+1.6700
+$18,510
+PRICE
+Unpriced
+MARKET
+VALUE
+$0
+$0
+$18,510
+$1,131,752
+CURRENT
+YIELD IN
+$0
+$0
+027
+09/29/02;13:15 001
+
+
+5 or 8
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+08/31/02
+05/03/02 DIVIDEND
+08/03/02
+""REINVEST
+09/27/02
+TOTAL
+INTEREST
+DATE
+TOTAL
+DESCRIPTION
+9/23/02 INTEREST ON CREDIT BALANC
+/ 1 1/4% 08/21 THRU 09/2
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+OPENINGBALANCE
+BRARE FERNS ME, MONEY
+RECORD 08/30/02 PAY 08/30/02
+REINVEST PRICE $ 1.00
+CLOSINGBALANCE
+SYMBOUCUSIP
+BMXX
+BSMXX
+SYMBOL/CUSIP
+QUANTITY
+QUANTITY
+1,106,786.47
+1,616.06
+1,108,402.53
+RATE (NA
+1.2500
+027
+DEBIT AMOUNT
+09/29/02;13:15 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,616.06
+1,616.06
+$-1,616.06
+$1.616.06
+CREDIT AMOUNT
+25.11
+$25.11
+
+
+6 of 8
+OFFICE SERVICING YOUR ACCOUNT
+lear, Steams & Co. Inc
+83 Madison Avenue
+New York, New York 10179
+Your messages
+13F
+Bear, Stearns Securities Corp, Net Capital and Net Capital
+Requirements:
+A complete copy of the Bear, Stearns Securities Corp, Statement
+of Financial Condition is available on the web site
+www.bearstearns.com, Alternatively, to request a free printed copy
+please call -toll free 1-866-299-9331.
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+August 30, 2002
+Securities and other assets in your account are the firm's collateral
+for any margin loan made to you. If the securities and other assets in
+your account decline in value, so does the value of the collateral
+supporting your loan, and, as a result, the firm can take action, such
+as issue a margin call and/or sell securities or other assets in any of
+our accounts held with the member, in order to maintain the require
+quity in the account, It is important that you fully understand th
+the following:
+> You can lose more funds than you deposit in the margin account.
+> The firm can force the sale of securities or other assets in your
+accounts).
+> The firm can sell your securities or other assets without contacting
+> You are not entitled to choose which securities or other assets in
+your accounts) are liquidated or sold to meet a margin call.
+> The firm can increase its "house" maintenance margin requirements
+at any time and is not required to provide you advance written notice.
+> You are not entitled to an extension of time on a margin call.
+027
+
+
+7 of 8
+OFFICE SERVICING YOUR ACCOUNT
+Sear, Stears & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+13P
+This statement is provided to explain Bear, Stearns & Co. Inc.'s
+(BSC") payment for order flow practices.
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 30, 2002
+Pursuant to SEC Rule 11Ac1-6, please note the following:
+Bear, Stearns & Co, Inc, will post its quarterly routing statistics at the
+following web link:
+Customers of Bear, Stearns & Co. Inc, may request information on
+any order executed within the prior six months from the time of the
+request, Specifically, you may request the identity of the venue to
+which the identified orders were routed for execution, whether the order
+was directed by you to that venue, and the time of the executions, i
+any, that resulted from such orders.
+027
+09/29/02;13:15 001
+
+
+8 of 8
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+The following account service fees will be charged to applicable
+accounts as of November 1, 2002:
+The service charge per transaction will be $5,00, Accounts
+transferred from Bear Stearns will be charged a $75.00 account
+transter fee. There will be a $50,00 fee for each stock certificate
+hat is sent out in registered form at the customer's request, W
+strongly recommend against holding stock certificates in physica
+form due to the possibility of theft, loss or damage.
+13P
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+August 30, 2002
+NOTICE OF CHANGE PURSUANT TO THE TRUTH IN LENDING
+SEC RULE 10b-16
+Effective as of November 15, 2002, the annual rate of interest charged
+purpose of purchasing, carrying or trading in any security or other
+property shall be based on either the Bear Stearns Margin Basis Rate,
+the Bear Stearns Securities Fed Funds Rate or the London Interbank
+Offering Rate (LIBOR"). The Bear Stearns Margin Basis Rate will be
+quoted daily by Bear Stearns at our main office in New York, Factors
+affecting the determination of the Bear Stearns Margin Basis Rate
+will include the short-term market interest rates quoted by money
+center banks and the Federal Reserve and the rate that Bear Stearns
+is charged for borrowing money, The Bear Stearns Securities Fed
+Funds Rate is the rate for U.S. dollar funds, as quoted by an
+independent broker of such funds selected by Bear Stearns Securities
+for the last transaction completed prior to 9:30 a,m, (Eastern Time)
+on the business day on which such rate is determined. The annual
+rate of interest will be no more than 3% above the Bear Stearns
+Margin Basis Rate or 4% above either the Bear Stearns Securities
+Fed Funds Rate or LIBOR and will appear on your monthly statements.
+Since the rate of interest charged is related to the Bear Stearns
+Margin Basis Rate, the Bear Stearns Securities Fed Funds Rate or
+LIBOR, any changes in these rates will cause corresponding changes
+in the rate charged to your account, which changes will be made
+at least 30 days prior notice.
+The "Statement of Interest Charges Pursuant to the "Truth-in-Lending"
+SEC Rule 10b-16" previously provided to you remains in effect
+except to the extent specifically amended by this notice.
+027
+VB36
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ....
+Your Portfolio Holdings
+Transaction Detail .................................
+Fund Activity....
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+3
+3
+5
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+23.324
+1,106,786
+$1, 130,110
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+1,128,412
+1,698
+"This portfolio indudes one or more unpriced securtles that are not
+relected in the Total Value of Securites and the Net Equity This Period
+Market Value of Your Portfolio
+Cash & Equivalent
+$1,130,110
+$1,128,412
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending bu
+or sell open orders on file for your account
+Flease report any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or5
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+523.298.86
+1,673.25
+25.08
+$1,698.33
+-1,673.25
+$-1.673.25
+25.08
+$23,323.94
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+23,298.86
+$23,298.86
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+1,673.25
+25.08
+$1,698.33
+Portfolio Composition
+Cash/Cash Equivalent
+Total.
+CLOSING
+23,323.94
+623,323.94
+-.....
+YEAR TO DATE
+6,786.47
+6,761.43
+$13,547.90
+1,130,110
+1,130,1
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+SYMBOLCUSIP
+QUANTITY
+PRICE
+MARKET
+VALUE
+23,324
+ESTIMATEL
+ANNUAL INCOME
+027
+....
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings (continued)
+CASH & CASH EQUIVALENTS (continued)
+DESCRIPTION
+BEAR STEARNS PRIME MONEY
+SYMBCLCUSIP
+BMXX
+MARKET PORTFOLIO CLY
+DIVIDEND REINVESTED
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBCUCUSIP
+BPIBY
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+QUANTITY
+1,106,786.47
+PRICE
+1.0000
+CASH
+QUANTITY
+20,000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+MARKET
+VALUE
+1,106,786
+$1,130,110
+ESTIMATED CURREN
+UNNUAL INCOM
+18,815 1.7000
+$18,815
+PRICE
+Unpriced
+ESTIMATED
+ANNUAL INCOME
+CURRENT
+YIELD (%)
+$0
+$0
+$18,815
+$1,130,109
+027
+
+
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+07/27/02
+08/0102 DIVIDEND
+08/01/02
+"REINVEST
+...••
+08/30/02
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+08121/02 A 1% 721 THRU OBANCE
+TOTAL
+STOP
+****** End of Statement******
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+OPENINGBALANCE
+RARE TORPET ME, MONEY
+RECORD 07/31/02 PAY 07/31,02
+MAKE PORT LOVE, MONEY
+REINVEST PRICE S 1.00
+CLOSINGBALANCER
+SYMBOUCUSIP
+BMXX
+BMXX
+SYMBOL/CUSIP
+QUANTITY
+QUANTITY
+1,105,113.22
+1,673.25
+1,106,786.47
+RATE (S)
+1.2500
+027
+PRICE
+DEBIT AMOUNT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 26, 2002
+DEBIT AMOUNT
+CREDIT AMOUNT
+1.673.25
+1,673.25
+$-1,673.25
+$1,673.25
+CREDIT AMOUNT
+25.08
+$25.08
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail .................................
+Fund Activity .......••••••••••••••••••IIIIIIIIII/I
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+3
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+23.299
+1,105,113
+$1,128,412
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+1,126,682
+1,730
+"This portfolio indudes one or more unpriced securtles that are not
+relected in the Total Value of Securites and the Net Equity This Period
+Market Value of Your Portfolio
+Cash & Equivalent
+$1,128,412
+$1,126,682
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending bu
+or sell open orders on file for your account
+Flease report any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited.
+Net Cash Activity
+Closing Balance
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+$23,274.62
+... ..
+1,706.21
+24.24
+$1,730.45
+...
+-1,706.21
+$-1,706.21
+.......
+24.24
+$23.298.86
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+23,274.62
+$23,274.62
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+1,706.21
+24.24
+$1,730.45
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+CLOSING
+23,298.86
+$23,298.86
+......
+YEAR TO DATE
+5,113.22
+6,736.35
+$11.849.57
+1,128,412
+51.128.412
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRPTION
+CASH BALANCE
+SYMBOUCUSIP
+QUANTITY
+PRICE
+MAKE
+TALU
+23,299
+ANNUAL MONE
+027
+...
+07127102;17:22 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings (continued)
+CASH & CASH EQUIVALENTS (continued)
+DESCRIPTION
+BEAR STEARNS PRIME MONEY
+SYMBOLCUSIP
+BMXX
+MARKET PORTFOLIO CL Y
+DIVIDEND REINVESTED
+TOTAL CASH & CASH EQUIVALENTS
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+QUANTITY
+1,105,113.22
+PRICE
+1.0000
+EQUITIES
+Equities & Options
+DESCRIPTION
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBCUCUSIP
+BPIBY
+CASH
+QLANTITY
+20,000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28,2002
+MARKET
+VALUE
+1,105,113
+$1,128,412
+ESTIMATED
+CURRENT
+NNUAL INCOM
+YIELD (%)
+19,561 1.7700
+$19,561
+PRICE
+Unpriced
+MARKEE
+$0
+$0
+$19,561
+$1,128,411
+ESTIMATED
+ANNUAL INCOME
+CURRENT
+YIELD (%)
+027
+
+
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+06/29/02
+07/01702 DIVIDEND
+07/01/02
+"REINVEST
+.....
+07/26/02
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+07722102 A 11% 0621 THRU OVANCE
+TOTAL
+STOP
+****** End of Statement******
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+OPENINGBALANCE
+HARP TORPET ME, MONEY
+RECORD 06/28102 PAY 06/28/02
+MAKE PORT LOVE, MONEY
+REINVEST PRICE S 1.00
+CLOSINGBALANCE
+SYMBOUCUSIP
+BMXX
+BMXX
+SYMBOL/CUSIP
+QUANTITY
+QUANTITY
+1,103,407.01
+1,706.21
+1,105,113.22
+RATE (NI
+1.2500
+027
+PRICE
+DEBIT AMOUNT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 28,2002
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,706.217
+1,706.21
+$-1,706.21
+$1,706.21
+CREDIT AMOUNT
+24.24
+$24.24
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ....
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity
+..........
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+3
+4
+5
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+23,275
+1,103,407
+$1,126,682
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+1,224,779
+-98.097
+"This portfolio indudes one or more unpriced securtles that are not
+relected in the Total Value of Securites and the Net Equity This Period
+Market Value of Your Portfolio
+Cash & Equivalent
+l.125.22
+$1.224,779
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or5
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Funds Withdrawn
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+323.249.59
+101,877.63
+25.03
+$101,902.66
+-1,877.63
+-100,000.00
+$-101,877.63
+25.03
+323.274.62
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+23,249.59
+$23,249.59
+Income Summary
+Dividends
+Credit Balance Int.
+Total.
+THIS PERIOD
+1,877.63
+25.03
+$1,902.66
+Portfolio Composition
+Cash/Cash Equivalent
+Total.
+027
+CLOSING
+23,274.62
+$23,274.62
+.........
+YEAR TO DATE
+3,407.01
+6,712.11
+$10,119.12
+1,126,682
+$1.126.682
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+.............
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+BSMXX
+QUANTITY
+1,103,407.01
+PRICE
+1.0000
+SYMBCUCUSIP
+BPIBY
+CASH
+QUANTITY
+20,000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+MARKET
+VALUE
+23,275
+1,103,407
+$1,126,682
+ESTIMATED
+NNUAL INCOM
+*•*•••••••••••••••••••-•
+19,641
+1.7800
+$19,641
+PRICE
+Unpriced
+MARKET
+VALUE
+$0
+$0
+$19,641
+$1,126,681
+ESTIMATED
+ANNUAL INCOME
+$0
+$0
+CURRENT
+YIELD (%)
+120
+
+
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+06/17/02
+TRANSACTION
+FND WIRED
+DESCRIPTION
+MDA#
+MANANA BARS WIRED TO
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MODAY
+06/01/02
+06/03/02
+TRANSACTION
+"DIVIDEND"
+06/03/02
+"REINVEST
+06/17/02 SOLD
+DESCRIPTION
+OPENINGBALANCE
+MAKE FORTLE E, MONEY
+RECORD 05/31/02 PAY 05/31/02
+MAKE POTLE, MONEY
+REINVEST PRICE $ 1,00
+MAKE PORTOLD DIE, MONEY
+CLOSINGBALANCER
+06/28/02
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+06/21/02 INTEREST ON CREDIT BALANCE
+AT 1 1/4% 05/21 THRU 06/20
+TOTAL
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2002
+DEBIT AMOUNT
+100,000.00
+$-100,000.00
+SYMBOUCUSIP
+CREDIT AMOUNT
+QUANTITY
+1,201,529.38
+1,877.63
+-100,000
+1,103,407.01
+PRICE
+1.0000*
+SYMBOUGUSIP
+QUANTITY
+RATE (%)
+1.2500
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+1.877.63
+$-1,877.63
+CREDIT AMOUNT
+25.03
+$25.03
+CREDIT AMOUNT
+1.877.63
+100,000.00
+$101,877.63
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail .................................
+Fund Activity .......•••••••••••••••••IIIIIIIIII/I
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26, 2002
+3
+4
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+23.250
+1,201,529
+$1,224,779
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+1,473,210
+-248.431
+"This portfolio indudes one or more unpriced securtles that are not
+relected in the Total Value of Securites and the Net Equity This Period
+Market Value of Your Portfolio
+Cash & Equivalent
+$1.224,778
+$1,473,210
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending bu
+or sell open orders on file for your account
+Flease report any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Funds Withdrawn
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+73,209.8
+... ..
+201,529.38
+39.76
+$201,569.14
+-1,529.38
+-250,000.00
+П. 5-251.529 38
+-49,960.24
+$23-249.59
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+73,209.83
+$73,209.83
+Income Summary
+THIS PERIOD
+Dividends
+1,529.38
+Credit Balance Int.
+39.76
+Total
+$1.569.14
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+027
+CLOSING
+23,249.59
+$23,249.59
+......
+YEAR TO DATE
+1,529.38
+6,687.08
+.....
+$8.216.46
+1,224,779
+51.224,779
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26,2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+.............
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+BSMXX
+QUANTITY
+1,201,529.38
+PRICE
+1.0000
+SYMECUCUSIP
+BPIBY
+CASH
+QUANTITY
+20,000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26,2002
+MARKET
+VALUE
+23,250
+1,201,529
+$1,224,779
+ESTIMATEL
+NUAL INCOM
+22,228
+$22,228
+1.8500
+PRICE
+Unpriced
+MARKET
+VALUE
+$0
+$0
+$22,228
+$1,224,778
+ESTIMATED
+ANNUAL INCOME
+$0
+$0
+CURRENT
+YIELD (%)
+120
+
+
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+04/30/02
+TRANSACTION
+FND WIRED
+DESCRIPTION
+MDA#
+SWIRED TO
+CHASE MaRRaMAN BANK NA
+F#
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+TRANSACTION
+04/27/02
+04/30/02
+"SOLD
+05/01702
+'''DIVIDEND'
+DESCAIPTION
+OPENINGBALANCE
+ARETTES PIME, MONEY
+05/01/02
+•REINVEST
+RECORD 04/30/02 PAY 04/30/02
+ARE PORNES DE, MONEY
+REINVEST PRICE $ 1,00
+05/31/02
+TOTAL
+CLOSINGBALANCE
+INTEREST
+DATE
+DESCRUPTION
+05/21/02
+INTEREST ON CREDIT BALANCE
+AT 1 1.4% 04/21 THRU 05/20
+TOTAL
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 26, 2002
+DEBIT AMOUNT
+250,000.00
+$-250,000.00
+SYMBOUCUSIP
+BMXX
+CREDIT AMOUNT
+SYMBOUCUSIP
+QUANTITY
+QUANTITY
+1,400,000
+200,000
+1,529.38
+1,201,529.38
+RATE (%)
+1.2500
+027
+PRICE
+1.0000
+DEBIT AMOUNT
+DEBIT AMOUNT
+1,529.38
+$-1,529.38
+CREDIT AMOUNT
+39.76
+$39.76
+CREDIT AMOUNT
+60,000.00
+1,529.38
+$201,529.38
+V5S9
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail .................................
+Fund Activity .......•••••••••••••••••IIIIIIIIII/I
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28, 2002
+3
+4
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+73.210
+1,400,000
+$1,473,210
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+1,472,118
+1,092
+"This portfolio indudes one or more unpriced securtles that are not
+relected in the Total Value of Securites and the Net Equity This Period
+Market Value of Your Portfolio
+Cash & Equivalent
+$1,473,210
+$1,472,118
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending bu
+or sell open orders on file for your account
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+04/27/02;12:01001
+
+
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERICO
+51.472,118.31
+1,091.52
+$1,091.52
+-1,400,000.00
+$:.400.000.00
+-1,398,908.48
+$73.209.83
+Income Summary
+Credit Balance Int.
+Total
+THIS PERIOD
+1,091.52
+$1,091.52
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+Cash Balance Summary
+Cash
+let Cash Balanc
+-........
+OFENING
+1,472,118.31
+$1,472,118.31
+CLOSING
+73,209.83
+$73,209.83
+•••••••••••'I
+027
+YEAR TO DATE
+6,647.32
+.....
+$6.647.32
+1,473,210
+51.473.210
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+.............
+BEAR STEARNS PRIME MONEY
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+BSMXX
+QUANTITY
+1,400,000
+1.0000
+SYMECUCUSIP
+BPIBY
+CASH
+QUANTITY
+20,000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28, 2002
+MARKET
+VALUE
+73,210
+1,400,000
+$1,473,210
+STIMATE
+NUAL INCOR
+26,460
+$26,460
+1.8900
+PRICE
+Unpriced
+MARKET
+VALUE
+$0
+$0
+$26,460
+$1,473,209
+ESTIMATED
+ANNUAL INCOME
+$0
+$0
+CURRENT
+YIELD (%)
+120
+
+
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+03/29/02
+84/10/02 BOUGHT
+04/26/02
+TOTAL
+INTEREST
+DATE
+DESCRIPTION
+04/22/02
+INTEREST ON CREDIT BALANCE
+AT 1 1/4% 03/21 THRU 04/20
+TOTAL
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+OPENINGBALANCE
+RARE FORST ME, MONEY
+CLOSINGBALANCE
+SYMBOUGUSIP
+BMXX
+SYMBOUCUSIP
+QUANTITY
+STOP
+****** End of Statement******
+QUANTITY
+0.00
+1,400,000
+1,400,000
+RATE (%)
+1.2500
+027
+PRICE
+1.0000*
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 28,2002
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,400,000.00
+... . .
+$-1,400,000.00
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,091.52
+$1,091.52
+VS57
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Your Messages
+.........
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+February 22, 2002
+3
+4
+6
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+1.472.118
+Cash & Equivalent
+$1,472,118
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+1,670,494
+-198.376
+is portfolio includes one or mare unpriced securtes that are n
+lected in tho Total Value of Securties and the Not Equity This Paro
+Market Value of Your Portfolio
+31.472,118
+$1,670,494
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+lease report any dierence or non-receipt of chacks or stocks, indicated as delivered to you
+o Client Services at 800-634-1428; or write to Clent Services at Bear, Stoams Securities
+Corp.. One Metrolech Center North, Brooklyn, N.Y. 11201-3659.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+
+
+2 of 6
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Funds Withdrawn
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERIOD
+51.670-49422
+1,624.09
+$1,624.09
+-200,000.00
+- 200.000.00
+- 198,375.91
+$1.472,118.31
+Income Summary
+Credit Balance Int.
+Total
+THIS PERIOD
+1,624.09
+$1.624.09
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+Cash Balance Summary
+OFENING
+Cash
+1,670,494.22
+let Cash Balanc
+$1,670,494.22
+•••••••••••••••••••••••••••••••••••••••••••••••••••••••••••
+CLOSING
+1,472,118.31
+•••••••••••••••••••••
+$1,472,118.31
+••••••••••••••••••••••'I
+027
+YEAR TO DATE
+5,555.80
+$5.555.80
+1,472,118
+$1,472,118
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+100%
+Unshaded portions denole debt balance and'or short
+
+
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SIMBOUCUSIP
+QUANTITY
+PRICE
+EQUITIES
+Equities & Options
+DESCRIPTION
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLCUSIP
+BPIBY
+CASH
+QUANTITY
+20,000
+YOUR PRICEDPORTFOLIOHOLDINGS
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+MARKET
+VALUE
+1.472,118
+$1,472,118
+NAME NOTE ORDEN
+PRICE
+Unpriced
+CURRENT
+YELD IN
+$0
+$0
+$0
+$0
+$1,472,118
+027
+
+
+5 of 8
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+03/27/02
+TRANSACTION
+FND WIRED
+DESCRIPTION
+ARAS NAME BANKIRE
+NDSWIRED T
+F#]
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DEBIT AMOUNT
+200,000.00
+TOTAL
+INTEREST
+$-200,000.00
+DATE
+03/21/02
+TOTAL
+DESCRIPTION
+INTEREST ON CREDIT BALANCE
+AT 1 1/4% 02/21 THRU 03/20
+SYMBOUCUSIP
+QUANTITY
+RATE (%)
+1.2500
+027
+CREDIT AMOUNT
+DEBIT AMOUNT
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22, 2002
+CREDIT AMOUNT
+1,624.09
+$1,624.09
+
+
+6 of 6
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+Your messages
+138
+Pursuant to SEC Rule 11Ac1-6, Bear, Stearns & Co, Inc will
+publicly post its quarterly routing statistics at the following web link
+ttp://www.bearstearns.com/corporate/business/equities/orp.htr
+STOP
+****** End of Statement******
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+February 22,2002
+Bear, Stearns Securities Corp, Net Capital and Net Capital
+Requirements:
+At November 30, 2001 and January 31, 2002, the Company's net
+capital of approximately $2,6 billion and $2,6 billion was
+approximately 9% and 8% of aggregate debit items and exceeded
+the minimum regulatory net capital requirement of approximately
+$604.1 million and $648,0 million by approximately $2.0 billion and
+$2.0 billion, all respectively.
+A complete copy of the Bear, Stearns Securities Corp. Statement
+of Financial Condition is available on the web site
+www.bearstearns.com,
+Alternatively, to request a free printed copy
+please call -toll free 1-866-299-9331,
+027
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summ............................
+Your Portfolio Holdings
+•••••••••••
+Transaction Detail
+..................
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 25, 2002
+4
+5
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+1.670.494
+Cash & Equivalent
+$1,670,494
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+1,868,542
+-198,048
+his portfolio indudes one or mare unpriced securties that are n
+fected in tho Total Value of Securties and the Not Equity This Panic
+Market Value of Your Portfolio
+81.67S1,8
+$1.868,542
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Please report any diference or non-receipt of chacks or stocks, indicated as delivered to you
+o Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or 5
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Funds Withdrawn
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERICO
+551.868.542.04
+1,952.18
+$1,952.18
+-200,000.00
+- 2000000.00
+-198,047.82
+$1.670.494.22
+Income Summary
+Credit Balance Int.
+Total
+THIS PERIOD
+1,952.18
+$1.952.18
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+Cash Balance Summary
+Cash
+OFENING
+1,868,542.04
+et Cash Balanc
+$1,868,542.04
+•...•••••••!•••••••••••••••••••••••••••.•••••••••••••.......
+CLOSING
+1,670,494.22
+$1,670,494.22
+••••••••••••••••••
+027
+YEAR TO DATE
+3,931.71
+*•••••••••••••
+$3.931.71
+1,670,494
+$1.670,494
+......
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 25, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SIMBOUCUSIP
+QUANTITY
+PRICE
+SYMBOLCUSIP
+BPIBY
+CASH
+QUANTITY
+20,000
+YOUR PRICEDPORTFOLIOHOLDINGS
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 25, 2002
+MARKE
+ALU
+1.670.494
+$1,670,494
+ANUAL NATE
+CURRE
+ELD I
+PRICE
+Unpriced
+CURRENT
+YELD IN
+$0
+$0
+$0
+$0
+$1,670,494
+027
+
+
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+
+TRANSACTION
+FND WIRED
+DESCRIPTION
+MRAS ENHAN BANKRES
+WIRED TO
+F#
+TOTAL
+INTEREST
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DEBIT AMOUNT
+200,000.00
+$-200,000.00
+DATE
+DESCRIPTION
+02/21/02
+INTEREST ON CREDIT BALANCE
+AT 1 1/4% 01/21 THRU 02/20
+TOTAL
+SYMBOUCUSIP
+QUANTITY
+RATE (%)
+1.2500
+STOP
+****** End of Statement******
+027
+CREDIT AMOUNT
+DEBIT AMOUNT
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 25, 2002
+CREDIT AMOUNT
+1,952.18
+$1,952.18
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Your Messages
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+3
+4
+5
+5
+EPSTEIN INTERESTS
+DTD 12/26/91
+JEFFERY E EPSTEIN & MARK L *
+EPSTEIN & WILLIAM ELKUS TTEES
+457 MADISON AVENUE 4TH FLR
+NEW YORK NY 10022-6843
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+1.868.542
+Cash & Equivalent
+$1,868,542
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+1,916,563
+-48,020
+is portfolio indudes one or more unpriced securtes that are i
+lected in tho Total Value of Securies and the Not Equity This Pari
+Market Value of Your Portfolio
+$1.868.542
+$1.916,563
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+lease report any difference or non-receipt of chacks or stocks, indicated as delivered to you
+o Client Services at 800-634-1428; or write to Cient Services at Bear, Stoama Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3659.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Funds Withdrawn
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERICO
+51,916,562.51
+1,979.53
+$1,979.53
+-50,000.00
+$.50.000.00
+-48,020.47
+$1.868.542.04
+Income Summary
+Credit Balance Int.
+Total
+THIS PERIOD
+1,979.53
+$1.979.53
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+Cash Balance Summary
+Cash
+let Cash Balanc
+.......
+OFENING
+1,916,562.51
+$1,916,562.51
+CLOSING
+1,868,542.04
+51.368.542-00
+027
+YEAR TO DATE
+1,979.53
+......
+$1.979.53
+1,868,542
+$1,868,542
+......
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+BANPAIS SA-SPONSOREDADR
+REPSTG 6 SER L SHS
+Total Equities& Options
+TOTAL EQUITIES
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SIMBOUCUSIP
+QUANTITY
+PRICE
+SYMBOLCUSIP
+BPIBY
+CASH
+QUANTITY
+20,000
+YOUR PRICEDPORTFOLIOHOLDINGS
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+MARKE
+ALU
+1,868,542
+$1,868,542
+ANAL INTE
+CURRE
+ELD I
+PRICE
+Unpriced
+CURRENT
+YELD IN
+$0
+$0
+$0
+$0
+$1,868,542
+027
+
+
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+01/23/02
+TRANSACTION
+FND WIRED
+TOTAL
+DESCRIPTION
+MDA
+DSWIRED TO
+CHASEAMARRAMAN BANK NA
+FD
+INTEREST
+DATE
+01/22/02
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+INTEREST ONCREDIT BALANCE
+AT 1 1/4% 12/21 THRU 12/30
+2 INTEREST ON CREDIT BALANCE
+AT 1 1/4% 12/31 THRU 01/20
+SYMBOL/CUISIP
+TOTAL
+Your messages
+The interest, if any, charged to your account during December
+STOP
+****** End of Statement******
+DEBIT AMOUNT
+50,000.00
+$-50,000.00
+QUANTITY
+RATE (%)
+1.2500
+1.2500
+027
+CREDIT AMOUNT
+DEBIT AMOUNT
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+EPSTEIN INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2001
+CREDIT AMOUNT
+582.04
+.....
+•1,397.49
+$1.979.53
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/dbb3c9dbc4d939568daed7501d2ac78d48067ad7568938e15b5e1deb964a95f4.receipt.json b/vision-fixhub/ds9-unparsed-05/dbb3c9dbc4d939568daed7501d2ac78d48067ad7568938e15b5e1deb964a95f4.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..20c5767a1dd269578fc3a1983c348e0683863cc1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/dbb3c9dbc4d939568daed7501d2ac78d48067ad7568938e15b5e1deb964a95f4.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -5405,
+  "dataset": "marble-joined",
+  "doc_id": "dbb3c9dbc4d939568daed7501d2ac78d48067ad7568938e15b5e1deb964a95f4",
+  "engine": "marble-apple-vision",
+  "event_count": 68,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "ec547a5175d305bdd6b8185304dcfb20651d0018efca90da27521e6cf62d6d77",
+  "output_sha256": "aecf7586cd411e4deb733ca2cdec2610937925f1725e0186b6e489aafd9858ef",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/dbcdaa1c35dc377be6c432166c7f0aff98a681366555c5fcc421d9ef0e2149fb.md b/vision-fixhub/ds9-unparsed-05/dbcdaa1c35dc377be6c432166c7f0aff98a681366555c5fcc421d9ef0e2149fb.md
new file mode 100644
index 0000000000000000000000000000000000000000..2dabfe50e4f4acddb1d19c68e7953f28562962c4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/dbcdaa1c35dc377be6c432166c7f0aff98a681366555c5fcc421d9ef0e2149fb.md
@@ -0,0 +1,3732 @@
+- CONFIDENTIAL-
+
+
+Importent e-meal (addresses
+# JoffeyE. Epstoin: jalfreye@mindspring.comPB)
+jeeproject@yehoo.com
+(N.X)
+zorrovanch@aol.com
+apstein@wanzdoo.fr
+* * * Shislaine Hexwall:
+(Peris)
+(NY)
+- In House-
+-Tim Newcombe (Citrix Systems Programmer)
+Call.
+#.
+- Cherlay Pelmer (Chef- Auroolo Rastarant) NrC
+- Joo Pegeno (Chof-Aspon, Co,)
+Importent-Christopho Franch Driver) P.B
+→ Jet Aviation)
+→ Sacrot Servico Porsomnal escorting
+Mr. Berck, Ehud Formor P.Mof Israal on
+J. Epstein plevos..
+#**→ Jean-luc
+Brunel "Scout" for youy fomeles-
+Karin Modes
+- Dirid Cook Blm Bozch (2004-2001) Witnass,
+interacted and chat daily ul undorage girls.-
+
+
+- CONFIDENTIAL-
+
+
+Visiters Massega (P.B)
+
+
+
+
+P.B., 2004-2005
+Adam, Nicl
+Agag Aleiandro
+Agnew, Marie Claire &
+Alai Azzedine
+Albermarle, Rufus &
+Sally
+Aldridge Saffron
+Alexander Pam
+Algranti Giacomo
+Allan Paul
+Allan, Nick & Sarah
+Althorp, Charlie
+Althorn
+
+
+Carella
++
+Alun-Jones, Jeremy &
+Deborah
+Ivarez, Senc
+incent
+Amon, Mr Philippe
+Amon, Roberta &
+Maurice
+Anastos, Lisa
+Anderson
+Appleby, Robert & Alex
+ranao. Maite
+
+
+Arellano, Victor
+Arion Joaquin
+Fernandez de
+Arion, Fernando
+Armstrong, Arthur &
+Cathy
+ron. Herve & Marine
+Ash. Lorinda
+081
+& Allegra Hicks
+Nick & Ari
+DUT
+ssaf, Charlotte
+Itori
+Aznar Jose
+Astaire, Mr Simon
+Baddeley, Jean
+Astor Viscount William
+Atkin Helene
+Bahrke Peter
+Atkin, Mike & Ami
+Baker Danny
+Bakhtiar, Shariar
+hurch Palm Cottag
+oats Cirencester Glos
+
+
+Balazs, Andre
+Bad Lady Sir Anthony
+Bands, Doug
+Baldwin Alec
+Balliol College, Oxford
+Is.gov
+ara Latham
+Denise Diorio
+Joe Cashion asst.
+Bamford
+oucestersh
+58 0Y
+e/alice
+Laura Sinheris
+Bannister, Clive
+& Rank nig
+Banon, Javier
+FB international Finance Bank
+Barham, Nicholas &
+Gretal
+put!
+Barnes. Pete
+Barnett, Craig
+88 CL
+(P)
+Bastone. Hillary
+Batstone Hillary
+
+
+DUt
+(Asst Erin Eagan)
+Berkman, Bill
+Boia Von, Debbie &
+Batstone. Tim Natasha
+Benson. Stever
+Bentinck, Baron
+Baumer, Lorenzo
+Beaumont, Lord & Lady
+Bernard, Tara
+Birchall, Martyn
+Bismark Vanessa Von
+vestment Managemen
+Beckwith. Tamara
+Belzbera. Lisa
+Birley, Robin
+Bisson, lean Marc
+Bjorlin, Jean Paul
+
+
+Blaine David
+Polin hiss asst.)
+Slack, Conrad & Barbar
+Minger internation.
+Blair Tony
+sec Katie Kas
+(Co
+Bloomberg Mike
+Boardman Samantha
+Blacker (Blogs & Jill, Mr Boardman Serena
+Boden, Johnie & Sophie
+-
+Dut
+Bodini, Daniel
+American Propertie:
+Bookis Nicholas
+Booth Mark & 1
+Netlets
+Boisgelin, Edward de
+London SWE
+Boisguilbert, Pierre de
+Boothe, Christina A.
+Bond Anabelle
+Bornese Paulo.
+Bonomi. Andrea & Giola
+Milano 201211
+Borrico, Michael
+Certified Contracting ine.
+(w)
+
+
+• D4 +
+raghetti Peretti
+Penelon, Hon Bruce and ferdinando
+Bram. Ben
+Brand Tony
+Branson, Richard
+Brandolini d'Adda
+Briatore, Flavio
+Boucherie Sylvianne
+Brachetti. Huao
+Bourke, Rick
+6831
+Braine, Caroline
+Braine, Ms Katie &
+Municolini Nuno &
+Broadhurst, Julia
+Bowles, Hamish
+
+
+roalie
+Bronfman, Jr., Edgar
+Brooks Christoper &
+Brooks. Miranda
+Jean-luc Brunel
+Karin Models
+Alison
+i.com
+")
+Druce,
+Lucinda
+Marine i
+Brunel, Jean-Luc
+elimina
+2 hour
+voll
+Bryer Tania
+Buck Joan Juliet
+Buffet, Jimmy & Jane
+Bull, Bartle
+Bullough, Hamish and
+Emma
+en f
+Burckle, Ron
+Burney, Mr Jules
+Burtril, Martin
+Bushnell Candice
+
+
+Busson. Arki
+Butter. Charlie
+Button Terri
+Ro
+Cadenet de Alain
+30 Queensgate Pirne Mark
+Caledon , Nicky
+calvo-Platero
+Mario/Ariadne
+ambell Roddy
+Cambell, Alistar
+Camerana, Giancarlo
+Cammy
+Campbell, Naomi
+•DUt
+sutim
+Çampo del Brooke &
+Emilio
+tandole. Andrew d
+andy, Nicholas A (
+andiyen Candy Ll
+
+
+Castaneda Debbie
+Cator, Alby and
+Cecil, Dr. Mark
+•V
+rello Sara Massimo
+um & Carina
+carvalho, Michel &
+Charlen
+Gecil Mark & Mini
+Cerina, Fabrizio
+Casagrande, Guido
+Caribom Camil;
+ecil Mark & Mini
+Aurel Stephenson,
+eorae & Pauline
+Cerutti Gian Carlo
+
+
+butim
+Chatwal, Vikram
+Cicogna, Gianfranco
+Ginriani Guiseppi
+Clive, Lucy
+Cisneros, Gustavo and
+Patty
+Chinevix-Trench, John
+Hicoana Marina
+Cicogna Gianluca
+Gionani, Pietro
+Claverino, Amadeo
+Claverino, Isabel
+one pital Partner
+Cleese John Alice Fay
+Cochrane, Ms Mandy
+Cicoana. Gener
+lempson, Graham
+mm
+Cohen Dalit
+
+
+Colle leffrey
+Cooke, Clive
+Cohen Peter
+Collins Phil & Orianor
+Cordle, Ms Rachel
+Conrad, Henrietta
+Coleman. Jo
+Conlle, Rupert 8
+Coleridge, Nicholas 8
+Seorgia
+Sien Batine, Susannah
+ordova Hohenlohe
+ernando di
+iterell HarO
+Courcel Martine De
+Cowdray. Marina
+Cowie, Colin
+
+
+Crabbe, Sophie
+Bo
+Dabbaah. Amr A.
+Davies, David & Linda
+Mrs Jennifer
+Dahl. Sophie
+Davis Michael
+sie Carman
+d'Arenberg, Prince Pi-
+erre
+Darrin, Drake
+ay, Nick and Heathe
+at Company
+Dartmouth William
+de Andrade. Marcelo
+Davies Jeff
+d'Uzes Jacques de
+crussol
+
+
+55 21 2524 5682 (wf)
+de Baecque.
+De Soto, Fernando
+Dickenson, Debbie
+Maidity
+edieu, Jean d
+auletti
+de Cabrol. Milly
+Tartas
+Derby Earl /Cntess Cas:
+& Tec
+Jef p
+De Cadenet. Alen
+el Bono, Luc
+intessentin.
+London, United Kingdom WiW
+le Clermont-Tonnern
+termini
+New York, NY 10004
+Dic
+nice
+hris Royer
+Dietrich Marc Antoine
+and Cath
+Paris 75008
+Dietrich, Paul & Laura
+torean Emerging Markets, Ltd
+Derby, Ros & Jonathan
+Dell. Adam
+(9)
+Deluca Dina & Fouard
+Chartuuni
+Dimbelby Johnathan
+Di Vita, Charlotte
+
+
+Email: 0171-243 1643(f)
+Diniz, Pedro
+PPD Sports
+San Paulo, Brazil
+Dierassi. Dale
+Dolbey, Alex & Suzie
+Short Hoo
+DUT
+Douglas, Diandra
+Driver. Minnie
+Dubb, Anthony I
+YC.N
+Donne, Aleara
+London SWEL
+Dubbens, Peter
+Dubin a Clea
+Glen
+1010 Gith Ave - Ant 110(h)
+Dor Ell Wiesel,
+Drax, Jeremy
+SWEE
+Dori
+Dorrit
+Doss, David & Christy
+Prunier
+New York, NY 10024
+Dreesmann, Bernard
+Dubin, Louis & Tiffany
+
+
+HTH Duchess of York
+lagrou
+Duchess of York
+unninghill Par
+scot Berkshia Sa 7T
+bads
+lenean f
+Ducrey-Giordano,
+Duesing, Paul
+Ventures
+Duke of York
+Buckingham Palace
+c)
+12 Ruad 2
+Dunpar Johnson
+Miranda & Steph
+Has
+Dunne. Griffin
+001-
+unne, Philip ‹
+London, W12
+Duong, Anh,
+Durso Luigi
+Ines de la Fressange
+cynth)
+parlotte
+Dzhabrailou, Umar
+Ecclestone, Bernie
+Eckon, Paul
+Edsel, Lucinda
+
+
+Edwards, Andrew &
+Tracy
+Elinaworth, Charlie &
+80 Oxford Garde
+Radon, United Kingdom WIW
+Erba Noona
+(tall blonde armanai
+Elian. Iohnathan
+Elliot. Gail & loe Coffey
+Espirito Santo, Manuel
+and Ros
+Elias, Brian
+Elizabeth
+Ellenbogen Eric
+y Park
+Estlin, Jean-Marc
+res
+Ellison, Mandy & Ralph
+Sliasch Johan &
+I Cheste
+Ellingworth, Mr & Mrs
+The Old House
+Launhton mila
+Elliot, Ben
+Elwas. Anabel
+London, sWit
+Epstein, Ed
+Entrada Juffali, Chris-
+250H
+
+
+Evans Chris
+Evehart Angie
+Faber David
+Faber Sally & Brook
+Johnson
+Gloucestershire Gil: STZ
+Faibairn, Charlotte
+Fairfax, The Hon Rupert
+The Coach House
+Falletans, Olivier de
+90o
+Fakhre, Danny & Chrisine
+• D4t
+'nt!
+Im
+A'Vi
+Faniul. Pepe
+Fairweather Natasha
+Moscar
+Fairweather, Ms
+Catherine
+Fall, Meredith
+Paris, France
+Fallah, Mrs
+Ennismore Gardens
+London SW7.
+Faulkner, Terence &
+Cornelia
+Feeley. Fiona
+Fairweather, Ambassa.
+dude many
+London SISONE
+Fakhre, Armado & Jasmine
+Fallah. Ms
+*Jon Robe
+V14 ORI
+
+
+Ferragamo, Leonard
+Beatrice
+Lavamuzzo, Italy 50029
+lalon Dir.
+Brandon (appt.s)
+LAin Paige
+Fiennes, Martin
+Ferranti. Hugo
+Fiennes, Ralph
+Feldman. Andrew
+881
+Ferry Brian
+Studio One
+Fiennes, Suzzana
+lennes, Marti
+oughton Cast
+Fell, David & Anne
+881
+1(8)
+Fifer. Chuck
+881
+Chai Christopher &
+Finch Charles
+Finklestein, Howard
+Firyal Princess
+Fisher, Dan
+(n)
+
+
+Flick Mook
+IRONINE
+Forbes, Steve & Sabine
+Bedminster, N.J. 07921
+-ord, Katie
+Ford Mortal
+Foman, Bobby 8
+Jeanette
+Home
+Forbes Zandy
+0011
+Forbes, Chris (Kip) Astrid
+cate - Parents
+Catie direc
+i Done on rice
+Andre's private
+KATIE'S FAX
+Fuck, eym & Richard
+Forman John
+001 ||
+IF (W)
+801 H
+1(7)
+Forman Johnathan
+Formby, Nicola
+07831 127575 (P)
+Forte, Rocco & Aliai
+Fox Andrew
+cinda
+• DU†
+Fraiser, Violet
+Francesco de la Garda,
+Fraysse, Isabel
+Freud Mathew
+
+
+Frost, Mr David & Lady
+Carina
+London Sue Asy
+Frostrup, Mariella
+Fry. Cosmo &
+Fulhurst Teresa
+Furstenberg, Heinrich &
+Ailan:
+Furstenburg Buravelli,
+Nina
+Ganoza, Esteban Juan
+Garson Jeremy
+Gaspar, Nacho
+matricisen 2в4n9
+Evson. Edwina
+Gaetani. Gelasio
+Garcia, Ludmila
+Gaetani. Rufreido
+001
+Gallman, Kuki
+Gardner Adam
+Garland Michael
+Gelardin lack
+Ganero, Mario Jr.
+German-Ribon Catriona
+
+
+Gibson, Caroline
+Gertler, Eric
+Privin
+15th floor
+r NY 10010
+@privista.com
+Gillfilan, Andrew
+Box 65014
+Seamane
+Getty, Mark
+Gillford, Lord & Lady
+12 Ashcombe Street
+Getty, Pia and Chris
+
+Gibbs, Emma
+Landon, SWiG SAU UK
+Gillmour, Andrew 8
+Emma
+001:1
+Ginsberg Gary
+ittis, Howar
+cinema
+New York, NY 10021
+Giussani Luca
+Goldsmith, Isabel
+Beverly Ells, CA 90210
+Glanville Mary
+58a Radnor Walk
+ondon SW3
+Glass, Charlie
+Glentworth, Edmund &
+Emily
+Golinkin, Sandy
+W)
+Goess. Pilar
+Gomez, Thomas
+Goldberg, F
+Ellen
+Santa Fu last
+
+
+Gonme Willam & Emma Grat, François
+72J Madison Ave.
+Condon lacobo i
+128002 Madrid
+Granby, David
+51 Sevmour Walk
+Gore, Juliet
+Gottlieb. Steve
+Grange, Jacques
+Goulandris Dimitri
+Grabau. Loren
+Gran wame
+reece rancess Oiga
+'"t!
+m
+Greece, mo
+, MC & Pavlos
+hrh Princa
+001
+Gregg Geordie &Katherine
+Grenfell, Natasha
+Green, Deborah
+Griffen. Ted
+Green, Jeremy
+(qu(h)
+Capetown:
+apetown, South Africa
+Green, Judy
+New York, NY 10021
+Gimmy Pinkelat
+
+
+Pamela p
+James p
+car
+James w
+Pamela w
+wf)
+Grossman Lloyd
+Gubelmann, Marjorie
+Guccioni. Tony
+881
+33
+Gudefin, Christian
+Deutahe
+8)
+Guedroitz, Solina &
+Nicolas
+Sally & Rufus' bestfriends
+TW SLJ
+lome
+ame Fax
+Barbara Home
+work
+urt NY home
+ard Pouse
+васп
+Guttfreund Susan
+&John
+ohn work
+Sec Diana
+Hahn, Dr & Mrs
+Guerini Maraldi
+Alessandro
+Longer sura
+Guiness.
+Guerrand-Hermes,
+Valesca
+1014
+New Y
+(P)
+Guest Cornelia
+•
+Guinness, Mr Hugo
+Pippa
+Halpern Jen
+andon :
+Guissaini, Luca
+uggenheim, Barba
+Bert F
+Iton. George
+• D4†
+'"!!
+
+
+Hanson, Brook
+65
+Square
+Hanson, Lord & Lady
+Hammond, Dana
+117 Fartza
+001
+Handler, Sharon
+Hanson, The Hon Robert
+The Garden House
+Westonbirt
+Hanover Ernst & chantal
+Hapsburg, Marie
+Harvey Victoria
+Harvie-Watt, Isabelle
+Haslam, Nick
+9287-7300898(
+Hatkoff, Craig & Jane
+fistor Capital Group
+NY. 12T
+car
+siest Line
+Hauteville, Marc de
+Hay. Henry & Patricia
+MY V210028
+layworth Reggie
+radwel grove
+Burford
+Oran
+letford
+(am)
+Hearn Barry & Susan
+Matchroom
+
+
+Hefner Ill. Bob
+Heiden Lisa
+ster Leslie (P)
+Fredie
+Helen and Tim Shifter
+NY NY 10027
+telvin Maris
+Herbert Jaso
+2 & Olaf
+Hesalinet MAnnabel
+London, arenawa ARP
+Himmelstein, Howard
+Hirsch, Jef
+001
+Herrero, Juan & Helen
+Heseltine, Rupert
+9811
+ott (i
+ott (
+Hissom, Robert &
+Andrea
+Hersov Robert & Kim
+London SW7
+Hicks India
+David Flintwoed
+Harbour Island
+Bahr
+Heseltine, Mr & Mrs
+Mentord
+Hill, Anthony
+London Wid.
+Heseltine, Mr & Mrs
+coffman Rustin
+Hoffman, Hetty
+
+
+Hoffman, Jessica
+Holland-Martin, Ben
+Landon SWR
+Hollond, Mr & Mrs James
+Hovenian. Nina
+001
+Hovnanian, Shaunt
+Howard J.
+Kapla
+• Tierney
+Hunter, Carlyn & Laurie
+owegego Luc
+Johnnsor
+Kaytsman, Jon & Mary
+Hey Peter
+Hunt, Laura
+nt 3C 10021
+Hurd, Nick & Kim
+urley, LI
+Hunter Gordon, Kit 8
+Georgina
+London W2
+
+
+Hurst. Anne
+Hutley, Lulu & Edward
+Ind.
+Charlie
+Hurst, Robert J.
+GoldmanEans & Co.
+T/0004
+Isamel Abdullah
+Inzerillo, Gerard J.
+Hyssain, Ayla
+Do Var NIX 10012
+Hutley, Mr & Mrs
+Isham. Chris
+001฿
+Jackson, Michael
+Samuel Gen (Attorney)
+Hutton.
+w-direct)
+w-main
+Asts.
+Carolie.
+Hussey Simon
+Hymes lyan
+Ireland, George
+K1 Top Albany Piccadily
+Jacobson, Julian
+lagger Mick
+Hutley, Henn
+rvine. Eddie
+
+
+Jagger, Hatti
+iake
+Jameel, Mohammed
+Jankiew, Linda
+Now vermark 10023
+991
+Jarecki, Nancy & An-
+drew
+hit the ground runnias films
+Jeffries, Tim
+09 Nancy
+Andrew
+Johnson Richard &
+Nadine
+Jarecki, Nick
+01
+mail.com
+cell
+Jason (canada)
+Johnson, Lucy
+London SWASHeB
+Javier
+Joans And & Mick
+Josephson, Barry 8
+Jackie
+(Bany w))
+ountry
+Barry email
+(w unal Jan 2004
+Karella, Kalliope
+Kastner, Ron
+001
+Catz, Anton & Robir
+dani
+New York, NY 10021
+
+
+Kennedy Jr, Ted
+Wardedy, Senator Ed-
+robin pl
+anton pi
+anton w
+Katzenellenbogen, Mark
+Capetown, South Africa
+Keller Georgie
+Gennedy, Bobby & Mary Kersner, Sol
+Kellet Fraysse, Caromanmare FRaysse
+Keeling. Sarah
+Kegan, Rory
+17. Reditte Place
+Kelmenson, Leo-Arthur
+and Gay!
+ayann & Eckh
+Khavat, Antoine, Jana &
+nad Street
+Kidd Jemma
+Keid
+you Third Avenue
+5ih ROOF, NX 10017
+Kennedy, Ethel
+Hickory Hill
+Lennedy Cuomo, An
+ern
+King, Abby
+meSmeaton Road
+Keidan, Jon
+
+
+-
+Kirwin Taylor, Charlie 8
+lelen
+21 Redcitte Square
+Koch. David
+881
+Kohl Astrid
+Kirwin Taylor, Peter
+001
+Dr Henry A
+Kotic Boby
+MaChinen
+Mon
+dee, Rupert & Charlotte
+9 Kensington Palace Garden
+ondon W
+ravetz, Anna
+Krooth Carvi
+Klesch Johnathan.
+Kudrow, Alistar
+al Dalamal
+ol.com
+w) direct line
+• p)
+Lalaunis, Demetra
+Lambert. Christopher
+'ut
+ambert. David
+Thi
+Lambert, Edward
+Partners
+Lambos Duff & John
+281
+Lang, Caroline
+Lange Dieter
+
+
+Lawton Paul
+Larsen Janet
+10 Ruthad cnts
+Lazar, Christophe &
+marie
+L'orongeria
+Laurie, Jonathan
+Indioo STEI
+Laviada, Laura D.B. de
+Le Bon, Simon & Jasmine
+Le Fur Jean-YVeS
+Zeme
+Lawford Christopher &
+Jean
+Le Marq,
+Willie
+Lea, Piers
+Leeds, Jeffrey
+NY, INCZETITE
+001
+Lefcourt, Jerry
+Lester, Dominick
+681
+evine, Philip
+an Cornaratio
+Liman, Doug.
+_indeman-Barnet, Sloar
+* Roger
+001
+Joen
+The Adela
+(sloane direct)
+
+
+ss of York
+8536
+unba
+S58955
+952
+Darr
+Lesley,
+Helen
+старов
+stricone-45
+Al Castricone (P)
+Epstein, Jeffrey
+Chigan Home
+Epstein, Mark
+5, Inc.
+12200013-1214
+Rome)
+made do not try
+1 35 1ST FL King Ad-
+Mark's assis-
+Mark's direct work
+FAX
+Epstein, Mark
+55 - 49 Stone Cr
+Epstein, Paula
+vase mach, FL 33411
+Joyce Michayluk
+(p)
+Farkas, Andrew
+(w)
+Farkas
+Live Oak /
+ax Hotel
+utomatic Pick-up
+nternational
+ocal Office
+Problems/package
+1o2meth
+Gell-man Murray
+ilman, Kenneti
+ce Charman/cr
+• DU
++
+
+
+hh
+P'n
+Secretary
+Glick, Howard
+Georgetown, Washington DC
+Home
+Gold, Bob
+WeStONGTH S80 (M)
+@aol.com
+ax at Home
+ellular
+Goodman, Bob
+(h1)
+W)
+emergency
+(2)
+Guadenheim Fileen
+x302
+Parent's Home
+(1)
+Harold Mollin
+Hashemi, Jalila
+Montrose Mous
+1 X70
+Hedberg, Gregory &
+Mariat Aller Art Gallery
+New York, NY 10021*
+By 2m Lig
+Heil, Paula
+130 West 56th Stree
+New York, New York 10019
+"tIm
+: Vineyare
+iana Home
+rivate Line
+ome
+Hunter, Joey
+Dwaga
+w)
+10012
+Indyke, Darren K.
+Livingston, New Jersey
+sidect 19 comp.
+tayivania
+New House
+DKI Graphics
+
+
+Insurance Office of Central Oh
+Hech Walaun
+Brecki, Henry Dr.
+a/conwood Corporatio
+565 Fifth Avenue (w)
+ird Floor
+er hours)
+a Can
+nice Lichtensteir
+Isaacson, Walter
+work
+(W)
+James, Randy
+www.ran
+37/384
+49)
+| Guyana
+We
+estchester
+wfl
+860 Plane
+Westchester f
+Emergency
+Emergency
+Other
+Johananoff. Pamela
+Jarecki, Gloria
+Johnson, Elizabeti
+Libit
+Trumg international Hotel & To
+Sonary, Sen. John
+John Kerry for President
+ahead
+lessler, Jack
+New Albany Compan
+Kosslyn, Steve
+
+
+Labang, Marc
+(wf)
+mergency contact
+hfi
+Nick La Penna
+Leese.
+Nick
+House of Orient PTE Ltd.
+169 Mount Slopanat PR
+Kravis, Hen
+Lang, Adam Perry
+Mact Industries
+Mast Industries - Milan
+Vilan, taly 20121
+McMillen, C. Thomas
+Chairman
+MID 20785
+McMillen, Thomas C.
+
+
+Meister, Robert
+rade
+V10048-0090
+Work
+Fax
+West Palm Beach
+Car
+Kelly
+Work Fax - Palm
+- Palm
+Merrit. Jerr
+ol.com
+ther
+ashington office
+Minsky, Marvin
+MIT
+Street
+U945
+Gloria
+ney onl
+Gloria Minsky pri
+Marvin-office
+Mitchell, David
+MY 10010
+m)18. S0th he 10th 0
+street, 10th fl
+home
+(p)
+Car phone
+•
+Mitc
+Gec
+282
+Emai
+Hm
+Aot 196
+papt:18951005
+1q2495
+: Dyt
+ut!m
+10023
+Florida
+Ea
+state
+Home
+DC Fax
+Morrison, Larry
+mite 105
+(office address)
+ch, FL 33406
+# 1158004
+Myhrvold, Nathan
+ntellectual Ventures
+N.A. Property, Inc.
+v. A. Propert
+925 West Campus Ovadress)
+OH 43054
+5906 buse Gran Fed Ex Ad-
+dress
+table
+andberg
+
+
+XHH)
+prod ass
+randmos
+@har-
+cosmoy mil
+(assistant)
+614-939-8525 (f)
+Newcombe, Timothy W.
+(Tim)
+lewcombe Electronic Systems
+2320 A is: A 403221 (h)
+Voice Mail
+(hf)
+ea rastoclates, ne.
+600 Fal
+Suite mount Avenue
+1286
+w)
+ted Parkway
+132
+el-Col
+er - Skypage
+8-MB°r
+59.
+me Westerville
+Newman, Larry Esq.
+Merry Castle's Di-
+SE MOO
+anice Oatman
+Florida
+Fonda
+Ovitz, Michae
+die Thannament Group
+mistle Dne-
+CA 90212
+Portable in NY
+TY Apt.
+vitz s pager
+ime
+A cell
+pach
+boat pr
+2-347 boat ph
+JY answer.
+Bl as of 1-13-03
+Packer, Mark
+Canastel's
+Je # 14E
+iami
+Pagano, Joe
+lome amy
+Office
+IL p
+Joe temporary # @
+Sance Monica
+lizhak
+w York 10023
+NY Apartmer
+Private Line
+Pete
+Menaveve (Lisand)
+Lisa in New Mexico
+ILOT INFORMATION
+ypenon Air or JE
+Washinton-Signa-
+Washinton-Signa-
+X:V1
+
+
+XHH!
+"e an
+temational Avia-
+(P)
+spen Base Operantum Lakes Drive
+A Garrett Aviation
+1 Jet.
+Aviation
+3 Jet Aviation
+aston Signature
+oston Signature
+anta Fe Capital
+Quinn. Thor
+blumbus Pilot Off.
+30 Lane Aviation Washincin P.C. 20005
+hike Internalantic Avia-
+Ilion air
+Narrett
+anta Monica -
+n Nuys - Million
+t West (Van
+w TOIk AvenUe, NW
+PC 20005
+Riempor Rhode Is-
+h-Washington
+(direct)
+Signature
+nite Plains
+General Avia-
+Ranieri, Lewis S.
+Po Charles Undberg Blvd. #500
+Cape Home
+Asst. Maureen Mc-
+imited.com
+arkwav
+43230
+World Cell
+VY office
+Rockefeller, Davide
+202 (0112
+lateral Com
+Home
+Rodgers, Dave
+Ike Warh FL 33467
+eeper #
+฿...
+Ross, David
+San
+Emn Museum of Modern Art
+:94103-3159
+sfmoma.org
+seper watch #
+Ivid's (P
+aphne
+race (sec
+Roxton Sporting
+Daniel Reynolds
+fax)
+fax)
+Canta All.u nu
+
+
+Doug
+home)
+tant
+га
+ottage
+) Bahama
+Shadow. Monty
+alibero.it
+ork fax
+rivate fax
+rivate line at
+Shaeffer David
+S81 BAHA
+Snyder, Richard & Laur
+forke
+Golden Books Family Entertainm
+888 Seventh Avenue (w)
+MY 100211
+Mom
+Car
+portable
+Spector, Warren
+Preside times cal
+ouse A
+Vork MY 10011
+1) Massachusetts
+hi Palm Beach
+Staley, Jes
+Cork, NY 10036
+(im 930 Park Avenue
+MY 10028
+ortable
+lamptons (hat)
+Stark, Caroline
+Krista's friend
+Lino set Auenue Thi
+FL 35939
+Steel, Kim
+ax number
+Stein, Andrew
+Work
+Stock, Ann
+Secretar
+iS Governmen
+The White House 20500
+senianton B
+Stroll, Lawrence S.
+Quebec
+anada
+
+
+(cell)
+(wl) Montrea
+Montreal
+NY
+(h) London
+(h) Moustique
+h) Claire Ann
+394 John-Stroll's chauf
+Silas's fax#
+Strollis fax
+ew country house
+Trump, Donald
+Trump Organization
+10022
+Tuckerman, Steve
+Tuckerman Optical Coi haw)
+Visoski, Larry
+Wachner, Linda
+Warnaco, Intih st
+afoya, Crai
+iser Yach
+rgency
+Ugland, Peg
+19th Street h
+Trust, Marty.
+W) direct
+Emergency
+- dam fel
+Mishi Francis
+
+
+Woner - Abigail Planta-
+Verang Backer Vera
+
+showroom (SEND ALL
+25 West 39th Street
+th Floor
+ork MY 10018
+9468 Home
+ome ra
+Y Brid
+South Hampton
+South Hampton
+Portable
+3789 Paris - Concierge
+a196 Paris - Apt
+howroom
+showroom fax
+Wexner - Flight Dept.
+4387 International29gteway
+im Steh!
+n Stehly (p)
+Wexner, Les
+78 Mount Street
+London, United Kingdom W1K
+| Home
+Home - fax
+Range Rover-
+David
+1-944|
+Home
+Home - fax
+Range Roverfercedes
+merc)
+Mercedes
+Range Rover
+Bently Mobile
+Wexner, Les
+rt Ufkes - Perurt Ufkes - Perurt Ufkes
+urt Uikes Page
+ain Line
+ain Fax
+eep Cherokee
+зер Wrangler
+MC Pick-Up 1994 --.
+Unite Range
+Fax
+eep Grand Cherourt Ufke
+Curt Uike S
+Wexner, Les
+Wexner.
+Les
+he Limited inc.
+White House
+Main Line (Information)
+1600 Pennsylvenia sonue, N.W.
+Whitehead, Jim
+Nolman, Herb
+urance Office Central Ohio
+
+
+parpiy
+tricla Hughs
+Zuckerman, Mort
+Teston Propertia
+@bostonproperti
+roperties
+reet
+Ihl
+on (h)
+mpton (f
+Epstein, Jeffrey
+2 Ea 781298021
+124 East 63rd Si
+EP02
+JEFFREY 71ST.
+Barnett, Richard
+EE extra line
+Mer('
+TNG CM
+See Lne 2
+Jojo (hk
+lerc.
+tano Sarage
+¡¡uęą or e
+apiuquas14x
+-wuju
+'"t!
+A'Vl
+Fo
+(n)
+JoJo Skytel pin#
+Lynn Skytel pin#
+(8 bpn
+Gaston Steve
+Graces Marketplace
+Acct # 5002
+Tom
+Sawyo
+(Tolophones)
+
+
+KENYA (K)
+Muthaiga Club
+KINNERTON
+Airport Transfers
+Charlie
+Chelsea Police Station
+oles, Ala
+gistered Osteopa
+al Centre
+Earls Court SW5 UNL
+Drivers
+welcomeminihus(®, hotmail com
+Entwistle Isi
+Hair Assocs
+Harrods Limited
+971-730 1234
+lon SW1X7XL
+Harvey Nichols
+Holland & Holland
+(NY)
+-
+Jackson Stops
+Jatyn & Benson
+John Hobbs Ltd.
+London.:
+jax)
+La Famiglia
+Martin Tim/Debbie Stewart
+Grosvenor Estate
+Martine
+Massage - UK (a)
+adge Rover
+tande
+Maxwell, Ghislaine
+Minicabs
+Nass Hiend
+Kevir
+O'Neil Nessa
+Oping
+Outred, Anthony
+SW10 OTZ
+Hedly's Humpers
+Police 24 hours
+Range Rover
+Ray John
+001 l
+((w)
+• Dy†
+'nt!m
+architat
+
+
+Sticho
+Tobias, Maxine
+roga -UK
+Unlisted London
+Fantact: Debbie Nichois
+Yara
+MEDICAL
+Birnbaum, Dr
+John Scotell
+Burman, Dr
+et for Ma:
+сувинь Sir
+Chiropractor
+Chiropractor
+2067 Broadway between
+Chiropractor
+Calaos, Br. Dear
+between 71th 8 9sn stret)
+Go Bent race
+Dr. Bruno
+535 Park AVEF40021
+Dr. Dean Calakos
+370 Columbus Avenue
+
+Dr. Farkus
+0 East 60th Street
+Or Ray. Dr. Kashel
+Dr. Schimoni
+Ear Conning
+30 West 2nd Breat
+Gaynor, Dr JR
+no dadonan Place
+Hirshfield. Dr.
+Ishmail
+177 Prince Street
+race & Thompson)
+Kent, Susan DVM
+Park East Animal Hospital
+2 ask
+4th Stree
+Krumholtz, Dr. Michael
+anth Simet
+fax
+Lister Hospital
+Magnani, Dr.
+waive Suite 2101
+(bown 52лC:4410022
+fax
+Medical
+dard ID Bum:
+rudential ID num-
+MedLink Emergency
+Meltzer, J. Dr.
+903 Pook Avenue
+Moskowitz, Dr. Bruce
+1411 North Flagler Drive
+Suite 9909-101
+tot
+
+
+direct to Moskowitz
+Oxford Health Plans
+lember number
+Prudential
+Steinburg Prath si
+NY Hotell
+Sternberg, Esther Dr.
+Washington B9kM
+Wyntik, Wayne
+PB
+Baba
+Bard, Dr. Perry
+chobes Blyd (w)
+Tom, Maggie
+Victor, Steve Dr.
+305784 8: (PSM) 69
+42029, 201 324
+Breakers. The
+Chiropractor
+Or Bar
+Cleaners
+usband
+Witness
+Creative Custom Swimwear
+Lupe. Tada denner Plaza
+Devito, Dawn
+- forida 33480
+m)44 Pleasant St.
+Watertown
+Palm Beach Hon
+Boston:
+Rhode Island
+(P)
+Driver - PB
+Ray
+Epstein, Jeffrey
+358 El Brillo WaY 3480
+Palm Beach, H
+P2Mespring.com
+ne 1
+пе 3
+Line 4
+in house kitchery
+in house kitchen
+mored Merc
+rmored Merc
+suest Merc S600
+Guest Mere S600
+GM Merc SL55
+: DU+
+rome Pierre-garwitness
+Idman, Francis
+Goldsmith, Gerald
+54S*3L33480
+Palm Beach
+nal Bank
+Architont
+
+
+9 emerg.
+matunet, Bill
+Phones
+Massage • Florida
+Pompan
+Stopek,
+Maxwell, Ghislaine
+38 El Billo Way.
+chact & Sally AR. BANC
+Alan Stopok
+landscape
+architact
+
+
+spstein
+a Sa delivery y
+o Dan and Nancy Sowle
+stanley, Neon Store
+pstein, Jeffre
+iro Ranc
+49Ziare Ransh Road
+Eins 2 (office
+Shop Wood Shob
+modem
+line
+(f)
+moder
+Brice & Karen (h)
+Flano lo (Nextel)
+ate (Nexte
+xtra 1 (o
+Exercedes. front
+Mercedes - back
+Mercedes G500
+: Suburb
+• Suburh
+ahoe
+Hummer
+Bradbury Stamm
+im Pay Stamm
+Stables
+Kelly Son
+(erney Natio
+Gar
+w)
+h Street NW
+IM 87103-2168
+Maryland 20774
+:
+55552))
+Home
+Santa Fe Institute
+- 17501
+ling. Rhond
+honiHKing Realt
+mament of Staaley
+LON COU
+• Mexico 87056
+Work
+lome
+Portable
+Massage - New Mexico
+Singleton Dr. & Mrs.
+RM
+Aboff Shelley
+Cowley, Dick
+Domb, Sam
+
+
+home
+Ellis Freedman
+881
+191 (w)
+Grumbridge, Malcolm
+She tomach Groun
+one board
+th)
+work
+Miranda. Bob
+Moss Brian /Carolin
+Coleman
+Nesson. Mauri
+881-
+Aspen
+Oliver, Ke
+Keith
+emaine. Pierre
+/ 5184
+
+Murden Scott and Sarah
+.891L
+Murden Scott and Sarah
+Onakewe, Rodolph
+47 Rue de Chaellot
+891
+Marden, Scott & Sarah
+Ord, Robert
+001
+(w)
+Shaw Derek
+Shelly Aboff
+Paul Cox
+7592206—
+Peters & Peters
+Keith Oliver/Helen Mcdowell
+ndon Wil
+Pisar. Samuel
+Tony Busby
+Travis. Paul
+Tutle.
+Caroline
+Caroline
+White. Justin
+Mine.
+_eah Pisar (w)
+Lean Pisar
+RUGS
+Pierre, Jerome
+Posen, Felix
+SECURITY (S
+Scotland Yard
+Gard nor
+
+
+South Ken
+The Home Office
+SWITZERLAND
+(SW)
+Bristol Hotel
+10 rue du Mart Bland 1201
+Paris
+The Corveglia Club
+The Steffan
+TRAVEL (T)
+Aero Leasing
+Zurich
+Geneva)
+Air France
+Juent flier (GM)
+juent filer numbe
+Air Hansen
+American Airlines
+Leona
+Gatwick
+I AA Frequent
+St T Brenda Boone
+Susan Michado Mi-
+American Express
+British Airways
+Roz home (emerenelope Foy
+ernette Berry - l
+Citicar
+DHI Courier
+Flight Options
+guyangga Sount Furport
+y. NY 10021
+Ellen/Tackie
+all-Free Numbe
+hen ph system is
+-oncord Tickete
+lavid Gladwin
+her) Susie Si-
+(Wilpon) Michael
+Continental Airlines
+(GM)
+1470oz trequent llier number
+Delta Airlines
+Elvawa
+Frequent Flyer Clubs
+#2 TUZ 105435 Trequent flier number
+carnero. .T. Mario B.
+38a Pans
+Helicopters
+Nice Help oner
+ar Aeroport Nice Cote d'Azur
+Terminal1
+06281
+Nice Cadar 2
+Delta Dast
+
+
+Hickery, Eileen
+Special Si
+rvices, NY
+Northwest Airlines
+Immunisation
+Omar
+Anto Travert
+827 Ridgew
+ent. Geoffre'
+bercrombie & Kent
+8701 Nodh AA
+suite
+More Ba
+Phone
+1800414 0808(8Y2c1
+ondon Airway
+Lonsdale
+Pisa Brothers
+Net Jets
+Richard Santulli asst. Carol
+York. New York 10111
+Peggy Culver
+W) asst Erin
+ortuga
+Plane Charter
+Chauffair
+Nite & Day
+• Moonacha Rol
+lodBrides MJ 070
+(f)
+Platinum Travel
+Steppes East
+Marc Bullough
+last (GN
+avtheon Travel Air
+Kocher
+Mie Sosperang Office Park
+Souther
+Book fight
+en Jenki
+en Jenkins F
+light Options
+Red Carpet Limousine
+Company
+Saphire Travel
+Shopper's Travel
+03 Fith Avenue, Suite 100
+al York M
+Sprint
+rence call
+SR Reservations
+Travel Consolidator Eu-
+rope
+as Tauni Coalad
+ap concorde
+Succes Voy-
+Travel Consolidators
+as numbers
+EAP
+Laker Airlines
+100
+ry Cheap
+ery Cheap
+p Seat
+seat
+nsdale)
+03 Paris
+cellini
+Saphire/charters
+Bling Trav.
+Bet Planet ext
+hu cel
+eapflights.co.uk
+incediscount
+ap concorde
+Time Travel -
+
+
+vigan
+vex. Centunar
+mex Plat.
+latinum/Heather
+US Air
+Frequent Traveler Center
+Pla ta alam NG 27102-0005
+1 4 Busi./Charlie
+Travels and
+omestic only mi.
+irgin specialist
+TWA
+USA International
+18 West 47th Street (B'Way)
+lew York, N°
+Virgin Atlantic Airways
+flier
+ler
+#
+# J.E.
+
+
+Lindemann, Adam & Eliz- Lindsley, Blake
+abeth
+730 Park Avenue, 2pt 10A
+6024 Bonsall Drive
+raol.com
+(W)
+indomann,
+((Sr.)&Freida
+Balmossom Way
+1480
+Lindsay Alax & Jaclyn
+Abbey Street
+Lindsex t
+Linley David
+Lignos
+001
+W)
+Lister
+Livanos
+Arriette
+des Cascio Robert
+mail: robertr@liveperson.com
+• DU+
+Loeb, Alex
+Horatio
+NY
+8810
+Lonsdale Richard
+Lorenzoti, Eva Vivre
+125 Fast 72
+Love, Courtney
+ornia 90210
+Dana
+5) Dana
+Lorimer, John & Lottie
+-owell Ivana
+265 East 66th St
+NY
+001
+Loyd Mark
+London SWZ 12B
+Lucas, Colin
+Mack, Carol & Earl
+than Guy J.
+10017
+private
+KY Home
+
+
+Macmilan, Dave & Bella
+5 Stanley Crescent
+London W11
+Mailer, Michael
+Magaziner. Ira C.
+90023
+New York, NY 10013
+Mailman Josh
+001
+Malek, Harry & Didi
+(P)
+rect line)
+sa Hurley)
+Mahler, Giovanni
+Mahoney, Sean
+001
+Macinga (Mandela)
+Malina, Mariorie
+Malkin Shelly & Tony
+107 Double 5088830
+Crepar
+Mallinckrodt, Mr Philip
+Manfredini Alessandro
+AndersWaB England
+Manconi, John
+8 Albermonaire Street
+ce fax
+me fax
+Geneva office
+Geneva office
+steria Cottage
+Mandelson. Peter
+Manners, Eddie
+able Peter
+1 ADAA
+aldo
+Peter's direct
+Manners, Miss Lucy
+
+
+rssa
+rainne Jones (as-
+Marks, Stephen & Alisa
+Massimo Parisi
+London. SWe Ne
+Manzano, Jose Luis &
+Aleiandra.
+Mannin
+John
+Lone park, cross
+onde
+lo & Pia
+Marterler Astrid
+от ''')
+Martins Peter
+Mavroleon Caitlin
+Margolis, Eric
+Jamieson Laboratories
+Toronto, Canada MATTE
+Marzotto, Matteo
+Valentine
+Mars are Grades Ra wra
+iwaites
+dyde Lane
+Ecchins Well
+Newbury Berks
+Mason,
+Christopher
+Mavroleon, Carlos
+
+
+Mavroleon, Manoli
+mal
+Maxwell, Isabel
+Mavroleon, Mr Bluey
+wwitzerland
+Mavroleon, Nicholas &
+Barbara
+esworld
+Global track-
+Guy and Anne
+ome fa
+avier p)
+(rodger p)
+Maxwell Dolbie
+Anne
+Maxwell & Laurens, Ms
+Maxwell la
+Tal 5
+98900H
+ara
+Philipell, Dr & Mrs
+Maxwell, Kevin and
+Pandora
+Telemonde Inc.
+Moulstord, near Wallingford
+WIH 6LT.
+Maxwell Malin= Cl
+rance, 13590 Merel
+tine, Maxwell, E.
+"tIm
+
+
+MC & Alienor
+Lime close
+Drayton Abingdon
+Oxfordshire
+lilly p)
+well, Marcella
+an Road
+Mayhew, Mr John
+Leesdaie 50571
+VcAlpine Alistair 8
+lomillv
+go The porters
+Venice 20124
+Mazandi, Yassi
+47 Cheyne Walk
+one Donald on
+McFarland. Anthony
+Mazzoti, Mateo
+McKenzie. Raymond
+10021
+Mclancy, Cas
+WPB
+Todd Work DI
+Mendoza. Neil
+York. NY 10014-7221
+clane, Shannon
+Mcleod Jock & Pru
+Lansdowne Cre
+don Wi
+Menzies, Kate
+Mews
+Meister, Todd
+Merison. Guy & Caroline
+Merivale-Austen, Bruce
+Ch. PLUSHE
+lob w
+Katrina
+Cami Neiss
+Regency
+
+
+Mermagon, Mr Jonathan
+Justin p)
+Milford Haven George
+and Clare
+Mills, Cheryl
+Metz Robin
+Nomi
+Metcalf Jus
+Minot, Carie & Bell,
+George
+Mever. Ton
+Metcalf Melanie & Julian
+Micklethwait, Fev &
+John
+Vetcalfe Julian &
+Melanie
+UK
+land home tax)
+Milford Haven, Sarah
+Road
+coateve
+00 35 9
+iller, Nicole & Kir
+aipal
+Minot, Susan
+Mischer. Kevin
+Modafferi, Daniela
+Via S.Marta 11
+Milan. Italy
+ombe Whi
+m)525 7lh AVE, 201110
+Milani. Gianluca
+Metcalfe, Justin & Joane
+20154 Milan ital
+Cico
+
+
+Monckton, Rosa
+frungon, east Sussex TN21
+Money Kryle, Mr Charlie
+effrey
+Moore, Julliet &Chris
+136 East 79th Stri
+gL#7B
+Moore, Mr Geoffrey
+POUN SSOHW SDE
+S France)
+Morris Stephen
+ілс
+Montemavor, Cesar
+88A
+• Paris (h)
+Monti Riccardo
+(w)
+Morris, Nick & Lucy
+• Dyt
+Mortimer, Gigi & Averell
+ement, Inc.
+Munro, Donald
+..''
+10
+Mind luort
+rav Philipson Kate
+X'Y1
+Morton
+Morton, Robert
+Murray Philipson, Mr &
+Thes Coltage
+L Martot Li
+h Leics
+Tertious raipland
+ip Pierre .
+St Trop)
+
+
+Nadler Emanuel
+001
+Nagel Adam
+891
+Nagel William
+Nardi, Dott M Jacope
+0225 802 1295
+Neil Andrew
+Neil, Andrew
+(W)
+, Hetty
+5 Pely Place
+England
+Nastasse Ille & Alex
+, Mr & Mrs
+compton Park
+Compton Chamberlayne
+Negrete, Jelitza
+Ng, Clive
+MIX 10012
+Fetis Sakham Loice stershire
+• D4†
+Niarchos, Constantine
+Nickerson, William &
+Jayne
+Nishio. Yoshi
+Noha, Cecilia
+001
+Noonan. Tim
+001|
+Nuttall, Harry
+Shantation
+Noel Alix
+Thomas
+
+
+O'Donnell, Mr Carletto
+Place
+Camille
+(0p8z)
+Oppenheim, Ms Marella
+Arabell Willam &
+.raven Arm:
+fordshire, UK SY7 OJU
+"t!m
+Mik
+Omar, Ralph
+Hm
+Oates, Simon
+Oates.
+Tom
+alumni.or
+Darda Vaughn-Ed.
+Witshre England SP4 90A
+Ong BS & Chritina
+coma Holdings Find floor
+Otto, Beo & Edvige
+Ong
+Orlando, Fabrice
+Katen Edmunds, Tom &
+Ojora, Yinka
+Laurie
+Osbourne Rachel
+London,
+
+
+Oxenberg
+marc Yang
+Palumbo Pater
+Paini, Nicole
+aHiend South
+London Sitz
+Panah-Izadi, Nader &
+Briaitte
+Palau, Marcia
+IGTTSDESTTER
+Pank, Ms
+Alby Carte
+&
+Palmer Tomkinson Tara
+Parker Jackie
+Palumbo, Mr James
+Parsons Carolina
+Paschen. Elise
+881L
+ashcow, Joel
+Thala Rantn Tans
+'ashcow, Stace
+married name Gard
+portable
+car phone
+Pastrana, Andres
+imhia South Amer-
+Patricof. Alan & Susan
+21J0021
+(W)
+Paulson. John
+Pavoncelli, Cosima &
+Riccardo
+: D4t
+"t!m
+
+
+Peltz. Haran
+Pearson. Hon Charles
+Pennell, Mark
+Pease, Simon & Clem
+Pedrini Lorenzo
+Perelman, Ronald
+10021
+Petangi, Helsius
+Peter
+Pekele
+: Dy†
+Peterson. Holly
+Pet
+JUT
+Pham Linh-Dan + An-
+drew
+ickering, Jane & Wil
+am (Ni
+Pignatelli, Frederico
+(P)
+so. Olivier & Alice
+Pigozzi Jean
+NY 8167022
+(h))
+Picciotto Michael
+
+
+Denny's cell
+Polu, Clary
+Podolsky, Jeffrey
+B20021
+mail
+aronique h)
+Porrin Ivanisevic
+Pittman, Sandy
+Polk.
+001 1
+Porter,
+,Pliny
+reworke Pictur
+Plenler. Ricl
+Diane & Denis
+Porthault Emmanuele
+Polu Emmanuelle
+00 331 4326 4092(01
+Polu Isabelle
+Porthault, Pascal
+LEntroux
+Porthaut, Rami & Isabel
+Poster, Mery
+IY 10028
+Potter. Muffie
+81
+Prestin, Electra
+001
+Prevost, Catherine
+ntim
+
+
+Price, Charles H.IL
+Price, Judy
+Avenue
+7341 9465
+Princess Firyal
+Pritzker
+Nick
+yatt Fevelopment
+Aster Street
+Mary Ryan)
+Pritzker, Thomas
+Vumero Uno
+200 W. Madison
+Suite 3800
+Lakeview #7N
+vf)
+mergency conmain Office Num-
+TOPP Rodney
+Premier Christy & David Ruanala Sonia
+Pucci Laudomia
+sandro Castellano
+5100 Florence. r
+Puttnam. David
+Vitshire sanis su n
+Florence
+lorence
+Rome
+lorence
+Pymont, Chris
+Crane Cor
+ondon
+Puig Marc
+Fashion Di
+Barcelona 08021
+Quartucci Alan
+(DOr
+Corniya
+londe
+(p)
+Puia Taria,
+Barcelona 08017
+Spain
+Quina
+889
+: D4t
+"tIm
+
+
+Raynes. Patty
+Rachline, Nicholas
+k cell
+Radziwill Carole
+Reardan, Kate
+win
+Reynal Michael
+w)
+mum
+uel
+Reza, Ali
+Rattazzi Isabel
+ingdom
+PAli
+Bat, Nick Rebecca
+IORGONLAICE BRIN
+Ritson Thomas Rupert
+Robilant, Mr Edmonde
+li Maya
+(m)0499-21122(mp)
+Robin
+Rivers. Joan
+Robinski Kasia/Pod
+Robert, Joseph & Jill
+202160X1900г.
+Robinson, Jo & Lisa
+Shields
+parents)
+ksavage David
+
+
+001
+Jo (W)
+loedy, Bil
+Mam or Y
+Rolfe, Gail
+(K)
+Rosen. Andrew
+8811
+Rosen. Denis & Sylvia
+Ronson Lisa
+Sa's work
+Ronson, Mr & Mrs Gerald
+Rosenerantz, Ms
+Hampstess London
+N2 OTY
+ondon WER
+(b oat)
+Rose Wendy 8, so
+Rosenfeld Donald
+Rothchild Jessica
+Rosenstein. Rob
+881|
+Rothchild. Hannah
+vate fax)
+Rothenburg. Rich
+Roth, Peter Thomas &
+Noreen
+10021
+Rotherwick, Tania &
+Robin
+Orc Software Ltd
+imPeter Thomas RounCe
+Country
+
+
+Rothschild, Edouard de
+buinin
+001]
+Rudnick, Della
+00.
+Russel Minhelle
+Rothschild, Evelyn de
+a Lane
+Roumugere Caroline
+0011
+Royle, Hon Lucinda
+1 Place
+Rucellai Natalie
+Cathmine.
+Rust Marina & lan
+*Yok NY 10021
+Or
+neers Blaza
+lan (p)
+an work
+Rustow, Tim
+: Dy +
+Rutalnd Duke and Duch- 001]
+ess
+Belvoir Castle
+Ruttenbore
+(w)
+Saffra, Edmund
+081-
+Safro Wayne
+Q01
+nird Ave,
+nic & Perri
+(Perri)
+ht)
+Ew)
+holas
+Said, Wafic
+00 33 1 4502401
+Sainsbury. Mr Jamie
+Salama. Eric
+Sacco Am
+Sachs, Jeffrey
+001
+
+
+Saltzman. Elizabeth
+Shad, Brenda
+Santo Domingo, Julio
+Schifter, Helen & Tim
+Samuels, Mia
+anto, Mr & Mrs A
+spirit
+Rua Inalaterra 31
+Shearer Andre & Angie
+Tim Schifter P
+Helen P
+881 MH
+2nd home
+§ Sant Montefire Simon
+Shore Chris and Maura
+Shriver, Bobby
+Sandelmar Jon & Corrie Saud Prince Solman
+Sangster, Guy & Fi
+Scerbo, Randall
+Sangster, Mr Ben
+Schiatti, Gianmarco
+Seilern Christine
+881
+Sejournet, Isabel de
+London salen
+Shabtai, Benny
+Shriver, Maria
+
+
+Shuster Sust
+Siegal, Peggy
+125 East 74th(h)
+im 401 alayelle st
+Ms Enta
+Siegel, William (Bill)
+Chris Craft Industries
+767 5th Avenue 4153 1.
+540 Park Av
+N 19021
+3498(0
+Sieghart, William
+London With
+Silver Ron
+801:
+001
+001)
+Silverman, Nancy &
+phon
+if phon
+Simon, Bren
+BS Associates, LLC
+armel
+: Dy+
+Smith, James
+cats Trist
+Newark ove
+Sophion (Caruth),
+Email:
+Snyder, Maria
+Sindi, Rena & Sami
+ew Yor
+New York
+100
+Slayton Bobb
+Smith Osborne
+19 Sitwell Gans
+London WA
+Smith Peterson, Noona
+1000 15
+Soymes, Rupert & Milly
+Tin endon bury Backs
+
+
+S obrino Eeporanza
+881
+Soto, Fernando de
+h)
+(W)
+Solomon, Andrew
+The Now Yorh Timan
+Soto, Jaime & Marina de
+34 Cadogan, Sa
+South. Hamilton
+(n)
+(regan)
+Soros Pal
+Souza, Carlos
+Valentino
+Sharon
+pacey, Kevir
+ICCM
+at Pranuc
+Soros, Peter
+Squire, Hugo
+Stanburry Caroline
+Stark, Koo
+Starzewski Thomas
+steenkamp, Chris
+vork
+Office Fax
+Steiner Jeffrey
+001
+((w)
+Steinkampf, Chris &
+Nina
+ape Province. BRI
+: D4+
+A'Yl
+ch house
+Stengel. Andrew
+•Man
+131EL024
+Nayn
+
+
+Stern, Allison & Leonard Stracher Kate
+MY 1222
+CHEA boat
+(hF)
+Leonard (WE)
+eonard i
+ramptons
+amptons fax 2
+ampions t
+5 (boat)
+Stevens Michael
+Sundlun, Stuart
+SunlOY Mr James &
+15 Bury
+andan SWi
+Sutherland Harry
+Stepford-Sackville, Char
+Shann M-Kinnay
+Svenlinson, Peter
+Swire Sophie
+Swire, Hugo
+Read
+Taaffe, Paul
+Eman
+Tabet, Karim and
+Cristina
+65th Street Neighbars
+Swire, Jenny
+Swire, Mark
+SWAY COE
+Carim (W)
+Taki
+Indon sKI
+Talbot Williams, Simon
+Sykes, Lucy Ewen
+Tand, Mr David, & Lucy
+ent Lid
+% Place, London, SWI
+
+
+Taubman, Bobby
+Tavoulareas, Mr Billy &
+Nicket
+Samarlese
+¡venue
+N6 4LP
+Tate. Runert
+Tavoulareas, Peter
+London NW1
+(1)
+Taubman, Alfred
+an Avenue
+(W)
+ichigan 48304
+: D4†
+Taylor. Felicia
+John
+rivate line
+c phon
+K ce
+Taylor, Pamela
+0011
+Taylor, Sebastian
+- Mast Mollis GL
+bondon SWiN
+6207-243-6816 Fax
+Trymor, Julie Eliot
+Tennenbaum, Harry
+010 1
+Teodorani-Fabbri, Eduardo
+CNH Global
+[heilmann, Baroness
+Francesca
+Elliot portable
+Assistant Jules
+Jules fax
+Julie portable
+
+
+Theodoli Catherine
+Tholstrup, Moegens
+5. Trop.)
+erbier
+Thompson, Barnaby
+001
+(w)
+Tisch. David
+eh. Merryl and Jimmy
+NY NY 10021
+Tish, Anne & Andrew
+Begency Hotel
+001
+Bor
+Titapupola Sonia
+odhunter, Emil
+Olypitu:
+200on 2248
+Toledo Ignacio, Alvarez
+: DUT
+Tollman. Bea
+Tollman, Brett
+22
+country)
+Tollman, Mr. & Mrs.
+Treacy Philip
+Tollman, Syrie & Gavin
+Stefan)
+Trump Blaine & Robert
+EW TOIR, NY 10021
+Trump. Ivana
+Tollman. Wyne
+(w)
+Trump, Ivanka
+Toub, Veronica (Busson)
+
+
+Trump, Robert & Blaine Turner, Jenny
+7A Burstock Road
+(ap)
+HElsieux
+Van, William
+Straubenzer
+Turner, Miles Creswell
+28 Edgeley Road
+(Madrid)
+Veronis, Jane
+I K
+Tucker. Chris
+h)
+Pylyn-her home
+offic Rylyn (his as-
+Rylyn's Portable)
+Turlington, Christy
+Varsavsky Martin
+Lyssen, (Chessy)
+Francesca
+Velasquez Patricia
+(1)
+Villani, Carmine S.
+Urbiola -Jorge
+Verdin. Julia
+5 ANUBST
+Tharbull, Governor
+Vahabzadeh, Iraj and
+Linda
+0011
+an Hauen Sophie
+harlotte Morar
+illeneuve, Jacques
+Viltadini. Emanuele A.
+Verdin-Mulot, Annie &
+
+
+p world
+Vittorelli, Dott. Marco
+Млат 20154
+• Trol
+C)
+pierre
+Vivian Smith, Charles
+Von Habsburg,
+Francesca
+Vittoz Martine
+in Hase, Bettina
+Limited
+Direct line
+Vittoz,
+Wachtmeister, Eric
+Vittoz, Vonnic
+Wagner David
+001
+Vainright. Ruper
+Waksal, Sam
+Wallace.
+Mike
+Walters, Barbara
+Ward. Kevin
+Varner. Ozzi
+Warnford-
+Mandy
+, Ms
+Wasserman, Casey &
+Laura
+1210
+Laura
+Wassong David
+Partne
+oros Private Equity Pa
+Mrs. Lisa
+'"t!
+m
+
+
+Isa's cell
+Landon SWa
+Wastnage, Lucy
+magazine Gap Road
+fong Kong
+Weimberg, Jason
+Waterman, Felicity
+1982 N. Navyandier
+Watson,
+265a New Kings Road
+_andon SH
+Webb. Veronica
+(P)
+Weidenfeld. Lorr
+Weinstein Rob
+001
+(o)
+Weintraub, Harriet
+920 5th Avenu 0021
+W)
+office fax
+Wastheimer. Ruth Dr.
+Weymouth. Mrs Lally
+881L
+White Somers
+ext. 201
+White
+White, Michael
+White, O'Gara,
+Whitworth, Alan &
+Wendy
+Wial, Jim
+Wienberg Anouska and
+Mark
+Wiesel Dr Eli and
+Marion
+0011
+Wigram Lionel anc
+Lydia
+Wigram, Lionel
+329 N. Palm
+Beve
+Williams Alexandra &
+Nick
+
+
+Williams-Ellis, David &
+Serena
+Mindsor-Taylor, Tim 8
+Helen
+Landers
+ondon
+*obecca
+Winn, Steve
+Winston, Elizabeth
+Wilmot-Sitwell, Alex & Fi Travis Ranch, Kenney
+Wilson. Carter
+Wipple, George
+Joumilist-For
+001:
+Wolper Carol
+Vindisch Grazol
+Manfrec
+Wong, Andy
+(P)
+Wong, Theodore
+land
+Woodall, Trinny
+Woods Emily & Carrie
+801
+001
+Woodward, Alexa
+991T
+Noodward, Shaun &
+Camilla
+aun p)
+Worcester, Marq & Marc
+London SWS 2BT
+ge
+Wyatt Jim
+Wyatt, Steve & Cate
+Yamani, Mai
+72
+lerrace
+33 (h)
+
+
+Yariv Zghoul
+Yates Andrew (piggy)
+goslavia, Princ
+Chel (
+national Advisors
+Ave
+(X)
+Voicemail
+Yugoslavia, Serge de
+Yogger, Tracy & Lee,
+Yugoslavia Dimitri
+Lacks Gordon
+Zales, Ale
+8810
+Zanar
+e & Bob
+Zawauri, Waleed
+Must l Oman P.O. Box 879.
+Zecher Bibi and Adrian
+Julia Walter:
+xecutive Assista
+Zilkha, Bettina
+Zeiler, John
+Zipp, Brian
+160
+·3A. 10021(h)
+aptial.com
+0101
+B907
+neme Fax
+65TH STREET
+Dionne, Ryan
++ NY<(0021
+(w)
+Zevi, Dino & Rosi
+London SId
+Geffert, Scott
+
+
+Brunel
+sdols
+Personel Secroony
+Kelly. Brian
+Pozne Xaley
+Maxwell. Ghislaine
+scemati (Pass-
+SE Line 3
+Guest Modem
+sale Number
+·ET
+i World
+asech (p
+orina íDl
+worid connect
+ott cal
+M Line 2
+BE Line 7
+Guest
+Staff
+Line 1
+N) Line 2
+1552 GSMH
+anoe Garage
+Mailbox#
+ich's Securit
+Celiemmp
+Josoph iFlorimfrodz
+Police
+Sere RO
+Domestic G. Maxwdl
+lanaging Couple)
+an !
+Arizona
+58th Street
+Between Madison & Park
+Runda losenh & Florena
+Avis International
+Joseph.
+-lorine
+Bel Air Hotel
+Prank Bowilnger
+791 Sone CaryiRo2d
+Tahoe, Kinney Garage
+2l1 Fot alh
+AMERICA(A)
+Aetiques - Resale Num-
+Beverly Hills Hotel
+341 Sunset BNV
+everly Hills, CA 9021
+: Dy t
+
+
+Beverly Wilshire
+Bice
+Bilboquet
+0101|
+Bond Street
+f Bond St
+Carlyle
+38576h5
+Christies- New York
+Cooney
+James
+: D4t
+(P)Franka Mercat
+niFranka.
+arol Magill
+laria Loss - Clien
+arno
+Cipriani Downtown
+376 West Bro 10072
+Coffee Shop
+82 Union Wes
+Inion Wer
+Cohen Gibby
+navat Haute Cuisine of Ess Cax alpases
+60 Central Park Sout
+mw York New York 1001
+210 East 58th Stree
+Nev
+0101
+Delmonico's
+Rosa/account under NYS
+1209A210022
+Doyle's
+Estia
+128 9101
+exercise New York
+thouse
+001
+Elaine
+B77 Second Avenue t61
+Four Seasons
+Electrolysis
+Four Seasons Hotel
+17F738 570, Street
+Elio's Restaurent
+Restauren in and 8s Fant Seasons Restau-
+99E 52nd (P91602x)
+
+
+Isso York
+164
+Brenal
+LA
+Hatsuhana (Japanese)
+7 E
+Helmsley Palace
+0101
+Il Cantinori
+32 East 10 (at Broadway)
+Il Tre Merli
+louston Street
+Vest Broadway
+Isabelle's
+Klinger. Georgette
+T002
+2 Norma Jean
+Le Club
+88th (2-3)
+Le Comptoir
+27E0S G70 5002
+Lowell Hotel
+Fuad Chartounian-contact
+28 East 63rd St.
+fork, NY
+Madison Gourmet
+Jour et Nuit
+Karen Pets
+1195 Lexinaton Ave.
+nd Sts
+Madison Towers
+(ra Moore Madison & 38th)
+Vew
+101
+Madr
+Massago-Celiforne
+168 WI
+New
+001 21
+Mark
+Massage - California
+an!
+Mayfair Regent
+McMullan
+holographer
+12 Filth Avenue, 0011
+Mercer Kitchen
+99 F
+001
+Mr Chow
+TITT!
+
+
+SIX7PA
+My Pres Dt Westwick
+934 Hudson Street
+Nicolas
+001|
+Opia
+Peninsula Hotel
+Bea prit Sanl Monica Brd
+CA 90212
+Peninsulia Hotel
+700 Fith AVeR48019
+Plerre Hotel
+3 Ea9 81515798021
+Plazil
+Plaza Athenee Hotel
+12 00 39882
+Provin co Restaurant
+Riz Calten
+Royalton
+44 Wes 441h 8 Stn)
+Sette Mezzo
+Rea exington
+0101L
+Soes-rep
+Shoe Service F
+Shutters on the Beach
+1 Pico Bind.
+CA 90405
+Sotheby'S
+Condan-35 New Band Street
+Sulteby's
+Magurre
+St Regis Hotel
+Staphong Hotel
+Sunset Margupe
+Tao Restaurant
+Taylor The
+The Great American
+Health Bar
+35 West 57th Street
+Troi Lamalie
+The Westhury
+01011
+
+Tickets
+EstanE and games
+agron Londre Tickets,
+Tribesa Gill)
+Two Bunch Palm
+Wal dort Astoria
+Westbury hotel
+BRAZIL
+Cecilia Szajman
+sanero, Mario Sr.
+trasilinvest
+iccard
+lo play
+ENTERTAIN-
+MENT (E)
+Annabels
+Aspinals
+Bibendum
+Clermont Club
+Daphne
+Foxtrot Oscar
+Harys Bar
+Marks Club
+Nam long
+Nikitas
+Patisserie Valerie
+San Lorezo
+Scalinis
+Tramp
+FINANCE (F)
+Centurion
+
+
+164
+Colonial Bank
+Cristina Bello
+D-Im
+Nat West
+Rob Bowran (Sharon Mulvany)
+Personal Accts.
+Executive Dept
+121
+High
+France 75004
+ATT Acess
+Bristol Hotel
+450 De Bats Faubourg St. Honore
+France
+Natwest Bank
+B Nationa
+FRANCE (FR)
+Alaia, Azzedine
+Cab Blue
+Cabare ignalib
+Car rental
+Chateau de la
+Messardier
+Chez Denise
+Chez L'Ami Louis
+32, Rug du Vert-BRis
+Ferme Lundi & Mardi
+Epstein, Jeffrey
+inch Apartment
+22 Avenue F0
+partment 2DD
+Erance 75116
+Hm)1 Rue Chalgrine/Staff En-
+Ambasador Car
+ean Marie (w)
+ean Marie (h)
+ean Marie (p)
+aldson (
+otrin
+aldson Cotrin
+Mr. Com
+Comu/garage
+ar phone
+velyn
+Coulaux(p)
+Experton
+Guerin
+Ms. Peres(conc.)
+Peres
+Peres (p)
+Sir. Stephane
+Ar Santos
+Epstein, Jeffrey (G)
+rench Apartment
+22 Avenue F
+•partment 208
+Paris, France 75116
+Ambasador Car
+Jean Marie @
+ean Marie @
+9322 Jean Man
+3 61 30 14 377 (p) Valdson
+33 148 27 85 33 (h) Valdsonk
+tatt line
+Cornu/garage
+2 phone
+s. Peres (o)
+502 M. Pascalicable
+Mr Pascal ceil(ca-
+, Mr Karim or
+: DUT
+
+
+esso York
+Vou
+Mr. Karin or
+пОле
+ir. Tourtea,
+Mr.
+tr. Belstan cell
+93 Mr.
+Sier Domenichini
+D Mr.Lafond(a/c,
+Mr. Lafond
+M. Pasquer
+Mir Santos
+Berlioz & Co.
+AVenue Louise 11a
+anton, Marie Joseph
+Hotel Crillon
+10 Place de la Co
+Jogorde
+Hotel Raffael
+Junot, Philippe
+509 Madisor
+ark. Nv
+Paris
+Paris
+Sain fax)
+428
+New Yorkble
+Gerard
+L'Amijean
+Ree de Varen
+Rue de Varene
+L'Arc
+Rue PIN
+L'Arpege
+La Merlot
+Rue de la cherche midi
+La Poste
+Lagardere, Betty
+34 Rue FaIl
+Lawyers
+Stephane Coulaux
+Stephane Coulate
+Geraldine Talavera
+Le Telegrashe
+Massego - Paris
+rance
+Massage - Paris
+: Dy+
+
+
+ss o York
+lou
+Mr. Karin or
+Mr.
+Tourteau
+Mr.
+Mr. Belstan cell
+Mr.Lafond(a/c,
+Mr. Lafond
+Mr. Pasquer
+Mr Santos
+xperton, Marie Josep
+erioz & C
+Gerard
+Hotel Crillon
+A Place de la Concorde
+Hotel Raffael
+Junot, Philippe
+509 Madison Avenue
+Mau Work
+Matignon
+pain)
+en rable
+L'Amijean
+Rue de Varene
+Teme
+Rue de Varene
+L'Arc
+Rue Pulsit
+"Arme
+Massego - Pans
+•cier
+La Merlot
+Rue de la cherche midi
+La Poste
+Lagardere, Betty
+cell
+France
+Massage - Paris
+Lawyers
+Stephane Coulaux
+Stephane Coulat
+Geraldine Talavera
+Le Telegraphe
+
+
+iss of Yorl
+Aborto Pinte
+Arg. Paris
+l (p)
+(speak little
+speaks NO
+USE
+Miele, Mr & Mrs
+(b)
+ix)
+Ott Cyntf
+nd Claude
+2DD
+claude
+Pinto, Alberto
+(h) Linda
+assau
+assau
+Serge
+(p)Serge
+Enda gir.
+ves
+Chantal
+Irtopinto
+Pinto in
+Morrocco
+rect
+Nisberopinto
+Plaza Athenee - Paris
+25 Avenue Montai
+Berek
+Taxi BI-
+Valdson Cotrin
+Poñs
+01 49 36
+Taxis
+98 3311
+531
+n0 21
+4
+Taxis I
+(Houso Manager)
+0149 36
+Vaia Cota Valion n
+Restaurant-takeouts
+Sust
+Restaurants
+Entrecote
+5 que Marbeauf
+Ritz - Paris
+Paris He Vee 9 9047
+Cedex 01
+• r3nce 7
+Direct Fax Reser-
+River Cafe
+146 quai de Stalin grad
+Tante Louise
+glais
+HOTELS (HT)
+Berkeley Hotel
+: D4+
+''!!
+
+
+• (
+Blakes
+Carlton Tower
+Claridges
+Brook Street
+W1A 2JQ
+(f)
+Cliveden House
+Connauaht
+Dorchester
+Lanesborough Hotel
+Senen Mangal
+Rt comer, LONDON
+Private fax. 8/2
+Savoy
+The Barcley Hotel
+Waterside Inn
+ISLAND(I)
+Air Center Helicopter
+Nicholas & Tina
+nome
+1 cell
+Christopher Taxi
+(home)
+Bekak
+stigu c
+Cox. Madison
+Madison Cox Design, Inc.
+3 TUUT1
+Soae (husec)
+Suite B-3
+JSVI 00802
+Epstein, Jeffrey
+3100 Red Hogkvi 0oa8rs B-3
+Staff 1
+Air Center Helicop-
+Leon agorabie
+Paul Hoffman, P.C.
+нота, Рач!
+shen
+Thomas
+, USVI
+Hales p.5
+ell Backu 2
+Mane ae las n
+loston h
+
+
+Massage A - Island
+Moselev. Brian
+Roberts, Theresa
+Romualdez, Daniel
+architect
+MessagG-Irland
+S direct
+Sanchez, Carlos
+Tropical Shipping
+Point Pleasant
+Water Taxi
+-
+-
+ISRAEL
+Eshed, Elisa
+Evani Duud Efrat
+Gil Avi
+Em
+Gutman, Arik
+Gutman, Arik
+Jerusalem Hyatt
+, Berek
+ster of
+Neima, Yakhof
+(p)
+Olmert, Ehud
+ITALY (1)
+Torne di Pisa
+/ia Mercato 26
+Train Info
+JEFFREY (J)
+301 East 66th St.
+Rie Vet, RP 80821
+Apt.forModids
+: DU+
+'nt!m
+
+
+And.pgr
+west cell
+ager Yokosta Caba
+) Yokosta Caba
+(Morrison)
+tax)
+(Anina
+(Guest)
+used)
+(ans/fax)
+Ques
+128 (guest)
+Natty
+Adler, Frederick (Fred) &
+Cath
+Fulbrisht
+Evz Anderson
+former model
+400 (W)
+Andersson, Eva
+Him NE. Anderson's
+Black
+4548 (caGienn
+Archer, Bill
+Westerville, OH 43031
+Three
+imited P13230y
+Mobile
+Home Fax
+Sherry Castle
+emergency
+(wf)
+Aslanian, Linda
+1002Z
+4920 asons Hotel(w)
+work(1-9-03)
+Bandar Prince
+sec. Cas Elio
+Ehud, Barek
+Former Prima Ministe- of
+Isracl
+ST
+Barak, Ehud
+Charmal no
+jates, L.L.C.
+ates.com
+Barrack, Tom
+Colony Capital Inc.
+1999 A
+nue of the Stars
+Suite 1200
+.. CA 90067
+: DU+
+
+
+European poroffice
+aific.net.sc
+rect fax to Tom's
+3 Euro C
+talian port
+75 Tra
+11 Davi
+avid Monahan (Ha-
+Barrett, Anthony
+Ossa Propertion
+eet
+or MY 10022
+erson
+wf)
+Seck
+Benamou. Albert
+Paris. France 2tnt
+Leon Bleck
+Partner
+60 Park Avenue
+Entrance on
+10021
+Beeford
+(ht)
+as (w
+com
+Br
+461
+Michello, Cameo
+Firad Secratery
+ountry
+Ruskinnham Racearch
+
+
+ass of York
+Caymes digmy
+agaol.com,
+10022e Apt 6A
+Home
+Suzette Direct
+(p)
+Ind Home Fax
+suzette's fax
+at Cayne
+Chou, Silas
+madan Anto
+ANG URITO
+clon
+other
+(wf)
+emergency -
+Daniel
+Davison, Dayle
+Cithank
+k 10022
+eoff VonKuhn
+le son.
+359 St
+
+8700252h)
+cár)
+332 E
+#1
+1G
+lershowit
+17 661 1965 *7
+Alan
+Edelman, Gerald Dr.
+Neurosciences Research
+Neurosciences Research Foun
+Alan
+Deersdaowits
+81
+EASTEN PORTA
+Suisream
+Sultstream
+9359 satelite -
+54123 satellite -
+Guest cell
+pstein, Jeffre
+stein interes
+10022 - 4th Floor
+'nt!
+
+
+isso York
+-
+aimindspring.com
+E-Fax iDin
+eșley
+Helen
+it Des
+57 Mad. Switch
+Dictaphone
+A Castricone-45|
+Al Castricone (p)
+Epstein, Jeffrey
+dichigan Home
+End line
+Ens taily or Companies, Inc.
+10010-1214
+me)
+ekion
+Work do not try
+ding Graphi
+331STFL King Ad-
+I Mark's assis-
+• Mark's direct work
+I FAX
+Enstein Mark
+in, GA 30087
+Cellular
+Epstein, Paula
+Golden Lakes
+Joyce Michayluk
+Joyce Michayluk
+(p)
+Farkas, Andrew
+Island Capital
+laX
+Farkas
+Live Oak I
+52 Е. 72г
+772
+hug and
+-ohmeth
+Gell-man Murray
+santo Fe institute a
+Federal Exoress
+I :264220070 EC
+c 2506
+22-4 Max Hotel
+Automatic Pick-up
+International
+_ocal Office
+Problems/package
+aris local
+channesburg
+pept)
+(w direct
+Ny divia)
+Gilman, Kenneth
+P3230
+: DUT
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/dbcdaa1c35dc377be6c432166c7f0aff98a681366555c5fcc421d9ef0e2149fb.receipt.json b/vision-fixhub/ds9-unparsed-05/dbcdaa1c35dc377be6c432166c7f0aff98a681366555c5fcc421d9ef0e2149fb.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1b942f1bcd9499db5c1614fb46fd49d2ccdcc51d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/dbcdaa1c35dc377be6c432166c7f0aff98a681366555c5fcc421d9ef0e2149fb.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1744,
+  "dataset": "marble-joined",
+  "doc_id": "dbcdaa1c35dc377be6c432166c7f0aff98a681366555c5fcc421d9ef0e2149fb",
+  "engine": "marble-apple-vision",
+  "event_count": 126,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "5e0510a5b1ea9561b6c19b1c1e3e2ae43c520f0832c447a580de8a2a1cfb1c23",
+  "output_sha256": "91d2ac62ae0b8eb8d1ec5753fbda1b5c958d13efeee8141dc69e0ba5d7a0d55e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/dbd070e3445fc9879ece64b0e8be1ad882f8977992594ca05bccb376a19174cc.md b/vision-fixhub/ds9-unparsed-05/dbd070e3445fc9879ece64b0e8be1ad882f8977992594ca05bccb376a19174cc.md
new file mode 100644
index 0000000000000000000000000000000000000000..c62c43d8610df283dda96b6bafc9950037b64fa3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/dbd070e3445fc9879ece64b0e8be1ad882f8977992594ca05bccb376a19174cc.md
@@ -0,0 +1,48 @@
+18
+Sep 2005
+Sep. 18
+Epstein Trip 9/18/2005 - 9/20/2005
+Sep. 19
+Sep. 20
+9/18/2005
+(9:59 AM)
+(9,59 AM)
+(10:05 AM)
+(11:48 AM)
+1(5:17 PM)
+Epstein Arrives in Palm Beach (9:36 PM)
+calls
+Residence
+Sep. 21
+22
+ext message
+(8:46 AM)
+(10:31 AM)
+0:51 AM)
+| (11:03 AM)
+(11:15 PM)
+11:45 AM)
+(12:30 PM)
+calls
+(9:24 AM)
+Epstein Residence cal
+(9.42 AM)
+_calls |
+(12:10 AM)
+Epstein Departs Palm Beach (B:16 PM)
+9/20/2005
+Trash Pull
+Trash Pull 3247996 for a good time call
+Sep 2005
+18
+Legend
+Sep. 18
+19
+Sep. 19
+carmot come at 7pm tomorrow b/c of
+20
+Sep. 20
+21
+Flight
+Trash Pull
+Sep. 21
diff --git a/vision-fixhub/ds9-unparsed-05/dbd070e3445fc9879ece64b0e8be1ad882f8977992594ca05bccb376a19174cc.receipt.json b/vision-fixhub/ds9-unparsed-05/dbd070e3445fc9879ece64b0e8be1ad882f8977992594ca05bccb376a19174cc.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0fc350dcd3cecc942ecbc5ab6cce6fa778b5d656
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/dbd070e3445fc9879ece64b0e8be1ad882f8977992594ca05bccb376a19174cc.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "dbd070e3445fc9879ece64b0e8be1ad882f8977992594ca05bccb376a19174cc",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "9804d3e2d47fd28d67cbe06024b2db1e4f43c88600603ee9e372e3f467b91274",
+  "output_sha256": "77034f7c4f530f71a875b8f66538a8f0b378b006be7b1157b9de974960c9cefd",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/dbd89a288b183d42f70f5ba04aacc66008220ddab27c3549d708a3d4ff040c21.md b/vision-fixhub/ds9-unparsed-05/dbd89a288b183d42f70f5ba04aacc66008220ddab27c3549d708a3d4ff040c21.md
new file mode 100644
index 0000000000000000000000000000000000000000..1c104285ffbe37c036f878c081056d4a60d24027
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/dbd89a288b183d42f70f5ba04aacc66008220ddab27c3549d708a3d4ff040c21.md
@@ -0,0 +1,16068 @@
+Statements
+
+
+What's In This Statement
+Financial Summary.....••/I///////...I...
+Transaction Detail
+LEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 30, 2002
+INSTITUTIONAL INTERESTS
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENNAN
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Miscellaneous
+Amount Credited
+Miscellaneous
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+944,625.34
+$944,625.34
+_______...
+-944,625.34
+$.944.625.34
+$0.00
+Income Summary
+THIS PERIOD
+Dividends
+0.00
+Credit Balance Int.
+0.00
+*•*********.
+Total
+$0.00
+Foreign Tax Withheld
+0.00
+Margin Int. Paid
+0.00
+YEAR TO DATE
+49,811.92
+6,925.68
+_-..
+$56,737.60
+-124.31
+-14.94
+SP The surren s four or ratanal purposes rear die Set revere date for portant iformation.
+09/28/02;15:02 001
+
+
+2 org
+Transaction Detail
+MISCELLANEOUS
+DATE
+MO/DAY
+09/03/02
+V03/0
+TOTAL
+OURNA
+New York. New York 10179
+TO CLOSE LINE
+CASH
+TO CLOSE LINE
+944,625.34
+$-944,625.34
+CRECIT AMOUNT
+944,625.34
+$944.625.34
+STOP
+****** End of Statement******
+027
+09/28/02;15:02 001
+LEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 30, 2002
+V636
+
+
+3 of 3
+Bear, Steams Securities Corp
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+09/28/02;15:02 001
+VE36
+
+
+What's In This Statement
+Financial Summ........................
+Transaction Detail
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 26, 2002
+3
+4
+INSTITUTIONAL INTERESTS
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENNAN
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+Market Value of Your Portfolio
+Cash & Equivalent - 80,
+$1,180
+1,180
+-1,180
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+This summary is for informational purposes only. It is not intended as a tax document
+SPC This statements four beratined purposes cer lt ne feede date ata dota intomation
+08/31/02;14:56 001
+
+
+2 of 4
+Bear, Steams Securities Corp
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+08/31/02;14:56 001
+
+
+3 of 4
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+$1,179.77
+*....
+3,149.00
+5,580.54
+$B,729.54
+........
+-9,909.31
+59.909.31
+-1,179.77
+350.00
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+493.88
+685.89
+$1,179.77
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+Foreign Tax Withheld
+Margin Int. Paid
+THIS PERIOD
+3,149.00
+0.00
+$3.149.00
+0.00
+0.00
+027
+CLOSING
+0.00
+0.00
+****•--.
+$0.00
+YEAR TO DATE
+49,811.92
+6,925.68
+$56.737.60
+-124.31
+-14.94
+08/31/02;14:56 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 26, 2002
+
+
+4 of 4
+Transaction Detail
+DIVIDENDS
+DATE
+07/30/02
+DOW CHEMICAL CO
+REC 06/28/02 PAY 07/30/02
+TOTAL
+MISCELLANEOUS
+DATE
+MODAY
+08/01/02
+0B/01/02
+JOUANAL"
+08/01/02
+"JOUANAL'
+0802/02 JOURNAL**
+08/02/02
+"JOUANAL"
+08/02/02*
+JOURNAL'
+08/05/02
+"JOUANAL"
+08/05/02
+......
+18/05/0
+TOTAL
+SURN
+SYMBOUCUSIP
+DOW
+FROM:
+* JRL
+TO:
+TO:
+JAL
+'******TO.
+07/02 CLA CHE]
+FROM I
+* JRL •
+"TO:
+CLR
+• JAL *
+TO CLOSE LINE
+CASH
+TO CLOSE LINE
+QUANTITY
+9,400
+RATE (S)
+0.3350
+685.8%
+4,328.77
+72.00
+493.88
+$-9,909.31
+027
+CRECIT AMOUNT
+685.89
+.....
+72:00
+4,328.77
+493.88
+$5,580.54
+08/31/02;14:56 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 26, 2002
+3,149.00
+$3,149.00
+
+
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 28,2002
+What's In This Statement
+Financial Summar.......•...••••••••I'
+Your Portfolio Holdings
+..........
+Transaction Detail ........................
+Fund Act................................
+3
+4
+4
+17
+INSTITUTIONAL INTERESTS
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENNAN
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+1,180
+$1,180
+16,204,798
+-16,203,618
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Cash & Equivalent
+Equities
+Market Value of Your Portfolio
+$1.180
+90
+$5,050,518
+$11,154,280
+Current market value
+SP This satement stori for atanal for oes recorde, Set revere das a a doctant intomation.
+07/27/02;19:19 001
+
+
+2 of 20
+Bear, Steams Securities Corp
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+07/27/02;19:19 001|
+
+
+3 or 20
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Money Fund
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+58,505.17
+6,224.85
+S64.730.02
+THIS PERICO
+564.730.02
+1,757,067.20
+5,478,268.35
+3,421.83
+5,843,311.04
+$13,082,068.42
+-296,181.73
+-489,000.00
+-14.94
+-12,360,422.00
+$-13.145.618.67
+-63,550.25
+51,179.77
+Income Summary
+Dividends
+Credit Balance Int.
+.......
+Total
+.......
+Foreign Tax Withheld
+Margin Int. Paid
+THIS PERIOD
+6,236.58
+700.83
+$6,937.41
+0.00
+-14.94
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+CLOSING
+493.88
+685.89
+....
+$1,179.77
+....
+027
+YEAR TO DATE
+46,662.92
+6,925.68
+... ..
+$53,588.60
+......
+-124.31
+-14.94
+1,180
+$1,180
+07/27/02;19:19 001
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 28, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+100%
+Unshaded portions denole debt balance and'or short
+market values. The alocation percentage is derived
+from the absolute market value of your portlolio.
+
+
+4 of 20
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+New York. New York 10179
+SIMBOUCUSIP
+QUANTITY
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT THE
+07/01/02
+TRANSACTON
+0701702 06/26/02"S0L5
+COSTCO WHOLESALE CORP-NEW
+5000301102 25003-053302
+DOMMISSION
+AS OF 06/26/02
+"CIMIZENS COMMUNICATIONS CO
+TS 100050201. 6200 06-130
+COMMISSION
+372,00
+SEC FEE
+1.56
+AS OF 06/26/02
+......
+ANAL NEE
+CURREN
+(ELD (:
+1,180
+$1,180
+$1,179
+SYMBOLCUSP
+COST
+QUANTITY
+-2,400
+36.95540
+*CZNI
+6,200
+= 832330
+027
+07127/02;19:19 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 28, 2002
+88,555.29
+*51,215.50
+
+
+5 or 20
+SETTLEMENT TRADE
+DATE
+07/01/02
+
+0770170206/26/02'S0LD
+CABOT CORP
+WITH RIGHTS TO PURCHASE PREFRO
+STECUTION BENEED CIRCUMSTANCE
+SEC FEE
+199.00
+MC STRATEX NETWORKS INC
+XECUTION BY SLK
+S 750 10-17-01, 4900 04-18-0
+COMMISSION
+169,50
+SEC FEE
+.38
+AS OF 06/26/02
+EDISON INTERNATIONAL
+EXECUTION BY RSSF
+VS 2600 04-16-02
+SEC RESION
+1.32.00
+AS OF 06/26/02
+EXPEDITORS INTERNATIONAL OF
+WASHINGTON INC
+EXECUTION BY SBSH
+00MM 0307-02
+105,00
+SEC FEE
+1.98
+AS OF 06/26/02
+"FOX ENTERTAINMENT GROUP INC
+DOMMISSION
+SEC FEI
+AS OF 06/26/02
+1,16.00
+SYMBOLGUSIP
+CBT
+EIX
+EXPD
+220
+QUANTITY
+-1,400
+27.03870
+5,650
+-2,600
+= 2.18480
+17.15570
+2,100
+
+-1,800
+• 20.86810
+07/2702;19:19 001
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 28, 2002
+37,740.04
+"12,159.24
+44.406.47
+- 65, 631.33
+#*37,420.44
+
+
+6 of 20
+SETTLEMENT TRADE
+DATE
+07/01/02
+
+*SOLD
+
+'0726/02
+0770170206/26/02'S0LD
+07/02702
+
+= ''BOUGHT
+HICA INC
+(FRM HCA-HEALTHCARE COMPANY)
+ECUTION BY RS
+:1000 10-24-01, 1800 01-11
+SE FESTON
+4196.00
+KOHLS CORP
+ES 10003-0-02. 700 11-06-01
+COMMISSION
+48,00
+SEC FEE
+1.61
+AS OF 06/26/02
+LIBERTY MEDIA CORP
+SER A NEW
+EXECUTION BY MSCO
+yS 2500 09-29-00, 1000 01-040
+SE MISSION
+LIZ CLAIBORNE ING
+910,00
+EXECUTION BY BUCK
+VS 2700 04-08-02
+COMMISSION
+SEC FEE
+162,00
+2.51
+AS OF 06/26/02
+EXECUTION BY JPHO
+VS 600 04-23-02
+COMMISSION
+SEC FEE
+AS OF 06/26/02
+ABBOTT LABORATORIES
+EE NOTE 'S' ON BA
+ECUTION BY LEF
+S 2700 06-27-0
+OMMISSIO
+62.00
+189,00
+SYMBOLGUSIP
+HCA
+KSS
+L
+TLB
+*ABT
+027
+QUANTITY
+-2,800
+-800
+3,500
+47.40300
+66.71530
+8.67500
+2,700
+30.79900
+600*
+34.21550
+00Lz
+•'38.80720
+07127/02;19:19 001
+EARED THROUGH I
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 28, 2002
+132,513.40
+53,307.63
+0,136.5
+82,977.79
+20,471.68
+104,983.44
+
+
+7 of 20
+SETTLEMENT TRADE
+DATE
+07/02/02
+06/27102
+BOUGhT
+07/02/02 06/27/02 SOLD
+
+
+Z0/201L0
+06/27/02
+07/02/02
+06/27/02
+07/02/02
+•'072702
+20/20140
+*06/27702
+"SOLD"
+CYTYC CORP
+XECUTION BY ADA
+SMISS0027-0.
+340.00
+CALPINE CORP'***
+ES SU00 O-2402, 1500 04-24-0
+SO MISSION
+321,00
+"CENDANT CORP
+EXECUTION BY MSCO
+VS 2000 05-17-02, 1650 11-13-0
+, 3050 11-12-0
+OMMISSIO
+SEC FEB
+3.05.,00
+"CITIZENS COMMUNICATIONS CO
+EXECUTION BY MONT
+VS 4200 06-13-01
+OMMISSIO
+EC FE
+1.68.00
+CONTINENTAL AIRLINES INC-CL'B
+XECUTION BY MLC
+'S 1700 03-25-02, 250 12-26-0
+, 550 12-24-01
+175.00
+"EMMIS COMMUNICATIONS CORP-CLA
+EXECUTION BY FCAR
+/S 1100 12-26-0
+COMMISSION
+SEC FEE
+-65.00
+"FOX ENTERTAINMENT GROUP INC
+EXECUTION BY MICO
+VS 1000 11-13-01, 900 11-07-01
+COMMISSIOI
+SEC FE
+11133.00
+SYMBOL/GUSP
+CYTC
+'''CPN
+"CZ*
+CAL
+"EMMS
+FOX
+027
+QUANTITY
+6,800
+5,400
+7.23780
+= 5.62500
+6,700%
+15.10370
+4,200
+2,500
+- 8.35360
+14.68460
+1,100
+1,900
+'17.86000
+19.71470
+07/27/02;19:19 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 28, 2002
+49,572.04
+30,035.08
+100,707.74
+*34,817.06
+36,520.39
+19,575.40
+37,308.80
+
+
+8 of 20
+SETTLEMENT TRADE
+DATE
+67/02/02
+06/27102
+07/02/02 06/27/02 "BOUGHT
+07/02/02
+•*06/27102
+''''SOLD
+0770270206/2702
+07/05/02
+007701/02
+07705/02
+
+.........
+LIBERTY MEDIA CORF
+SER A NEW
+XECUTION BY TWP
+S 2600 01-04-01, 700 02-23-0
+SEC FESSION
+198,00
+.80
+"OMINICARE INC**
+COMMISSION
+385,00
+"SINCLAIR BROADCAST GROUP INC
+EXECUTION BY SBSH
+6000,08.02 200002
+160,00
+1.26
+"YOUNG BROADCASTING ING-CLA
+EXECUTION BY JPHO
+VS 1600 05-14-02, 1000 05-31-0
+130,00
+1,38
+COPER INDUSTRIES LTD
+EXECUTION BY TWPT
+2. 110005-2202. 1200 05220
+COMMISSION
+231,00
+SEC FEE
+3.87
+CISCO SYSTEMS INC
+EXECUTION BY MONT
+YSMMIS50328-02
+135,00
+AS OF 07/0102
+1.13
+SYABOUCUSP
+*OCA
+"CBE
+(SCO
+027
+QUANTITY
+-3,300
+5,500
+3.200%
+2,600
+3,300
+2,700
+8.01120
+25.67750
+13.03450
+' 17.56900
+38.92560
+13.88920
+07127102;19:19 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 28, 2002
+26,223.16
+'141,626.25
+41,534.14
+45,533.02
+128,207.61
+37,352.71
+
+
+9 of 20
+SETTLEMENT TRADE
+DATE
+07/05/02
+07/01/02
+07708/02 07/02/02 SOLD*
+07708/02
+07/02/02
+07708/02
+07/02/02
+07708/02
+07/02/02
+*SOLD
+8778702 07785/02''S0LB
+2600 03-06-02, 300 03-041
+IMMISSIO
+203.00
+EC FEL
+1.03
+"ABBOTT LABORATORIES
+COMMISSION
+SEC FEE
+98,00
+1,58
+AS OF 07/02/02
+"CISCO SYSTEMS INC
+AVG PRICE: DETAILS ON REQUEST
+MYKROLS CORP**'*
+TS 130003-04027
+COMMISSION
+AS OF 07102102
+115.00
+VISHAY INTERTECHI
+VOLOGY INC
+SEE NOTE "S* ON BACK
+EXECUTION BY OPCO
+VS 400 11-27-01, 1600 12-04-01
+700 12-21-0
+OMMISSION
+189,00
+SEC FEE
+1.64
+"FOX ENTERTAINMENT GROUP INC
+BEEN BY 400
+COMMISSION
+AS OF 07105102
+32.00
+SYMBOL/GUSP
+MYK
+*ABT
+"SCO
+MYK
+VSH
+*FOX
+027
+QUANTITY
+-2,900
+1,400
+11.72000
+37.37400
+2,500
+1,300
+- 12.71500
+11.65000
+2,700
+20.07460
+600
+21:79390
+07/27/02;19:19 001
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 28, 2002
+33,771.97
+52,212.02
+31.661.54
+15,041.54
+53,998.78
+12,667.95
+
+
+10 of 20
+SETTLEMENT TRADE
+DATE
+67/10/02
+07/05/02
+07710/02 07/05/02 SOLD
+07/10/02
+07/10/02
+07/002
+'BURNAL
+JOUANAL
+"JOURNAL
+ESCRIPTION
+BERTY MEDIA COR
+SER A NEW
+EXECUTION BY MSCO
+VS 1800 02-23-01
+COMMISSION
+SEC FEE
+.508.00
+AS OF 07/05/02
+"SINCLAIR BROADCAST GROUP INC
+EXECUTION BY PHO
+VS 400 01-04-02, 3600 12-26-01
+COMMISSION
+200,00
+ESS OF 07105102
+1.60
+• JRL
+AMERICAN EAGLE OUTFITTERS INC
+NEW
+TORE
+ABBOTT LABORATORIES
+TO:
+JAL
+ANALOG DEVICES ING
+JRL
+"BEA SYSTEMSING
+TO:
+JRL
+BEVERLY ENTERPRISES ING NEW
+JAL
+CR BARDING "
+TO:
+SYABOUCUSP
+SBGI
+ANF
+"AEOS
+"ADi
+"BEAS
+BEV
+"BCR
+027
+QUANTITY
+-1,800
+9.15000
+4,000
+13.27330
+3,200
+4,500
+1,300
+-1,300
+4,300
+41,700
+7,700
+07/2702;19:19 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 28, 2002
+16,349.50
+52,879.60
+
+
+11 of 20
+07/10/02
+67/10/02
+JOUANAL"
+6710/02***
+'''ÖUANAL"
+07/10/02
+07/10/02
+"JÖURNAL
+
+JOUANAL
+07710102"
+
+"JOURNAL"
+CYTYG CORP
+TO:
+* JAL
+"CALPINE CORP**
+TO:
+* JAL
+"COSTCO WHOLESALE CORP NEW
+* JAL
+CITIZENS COMMUNICATIONS CO
+JAL
+CSX CORP
+TO:
+JAL
+CABOT CORP
+TO:
+* JRL
+KENNETH COLE PRODUCTIONS ING
+SYMBOL/CUSP
+СУТС
+CPN
+''COST
+*CZN
+CSX
+CSCO
+CAL
+QUANTITY
+-14,100
+16,000
+7,950
+20,600
+2,700
+4,000
+7,500
+2,400%
+5,350
+9:400
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+June 28, 2002
+'EBISONINTANATONAL*•••••••••••••*•••••••••••''****••**••••••••••••••••****•••••••••••••/•••••••••••••••••/•••••••••••••••••/••••••••••••••••
+TO:
+• JAL
+027
+0712702;19:19 001
+
+
+12 or 20
+SETLEMENT TRIES
+07/10/02
+67/0/02
+"JOURNAL'"
+JÖURNAL
+07/10/02
+......
+7/10/0
+JOUANAL
+EMMIS COMMUNICATIONS CORP-CL A
+* JAL
+"EXPEDITORS INTEANATIONAL OF
+WASHINGTON ING
+TO:
+* JAL
+"FOX ENTERTAINMENT GROUP INC
+* JRL
+FEDEX CORP
+TO:
+FOOT
+LOCKER INC
+TO:
+FEDERATED DEPARTMENT STORES
+INC-DEL
+TO:
+• JAL
+EXTRONICS INTERNATIONEL
+TONA TECHNOLOGIES PLE
+SPONSORED ADR
+TO:
+HONEY
+TO:
+TO:
+SYMBOLCUSIP
+EMMS
+FOX
+FDX
+FLEX
+DONA
+HON
+027
+QUANTITY
+4,750
+3,900
+10,300
+3,900
+17,650
+6,200
+11,800
+:4,150
+52,750
+07/2702;19:19 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York: 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+June 28, 2002
+
+
+13 of 20
+BATLEMENT DATE
+07/10/02
+07/10/02
+07/10/02
+07/10/02
+JOURNALI
+"JÖURNAL
+"JOURNAL
+07/10/02
+Bear, Stearns & Co. Inc.
+HCA INC
+(FRM HCA-HEALTHCARE COMPANY)
+* JAL
+JONES APPAREL GROUP INC
+* JAL
+KOHLS CORP
+TO:
+"LIBERTY MEDIA CORP
+SER A NEW
+TO:
+* JRL
+"LIZ CLABORNE INC
+LIRI
+MILLENNIUM CHEMICALS INC
+• RI
+MYKROUS CORP"
+TO:
+JA
+"NOVACHEMICALS CORP
+NORTHWEST AIRLINES CORP
+SYMBOLGUSIP
+HCA
+KSS
+LIZ
+"MCH"
+MYK
+"NEX
+NWAC
+027
+QUANTITY
+-8,200
+:11,200
+2,400
+:16,600
+7,700
+8,600
+-5,100
+4.500
+2,500
+8,450
+6,407
+07/27102;19:19 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 28, 2002
+
+
+14 of 20
+07/10/02
+67/0/02
+JOUANAL"
+6710/02***
+''JOURNAL'
+07/10/02
+"JOURNAL
+87/10/02
+'JOURNAL
+07/10/02
+'JOURNAL
+07/10/02
+07/10/02
+JÖURNAL"
+OLIN CORP NEW
+TO:
+* JAL
+"OMNICARE ING**
+TO:
+* JAL •
+"PACIFIC SUNWEAR OF CALIFOANIA
+TO:
+JAL
+QUIKSIAVER INC"
+TO:
+JAL
+"ROYAL CARIBBEAN CRUISES LID
+JAL
+aaaaaaaaaaaaaaa
+ICOB IN
+TO:
+"STAGE STORES INC
+NEW
+TO:
+SYMBOLGUSP
+OLN
+"SCA
+'''PSUN
+*ZOK
+"ACL
+SCRI
+SEGI
+027
+QUANTITY
+4,100
+-77,800
+:10,950
+18,650
+-10,250
+10,800
+9,000
+7,800
+10,900
+14,400
+07/2702;19:19 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+June 28, 2002
+
+
+15 of 20
+07/10/02
+87/18/02
+6710/02***
+67/10/02'
+
+JOUANAL"
+'JOUANAL"
+JÖURNAL"
+"JOURNAL
+• JAL
+SYMBOL TEGHNOLOGIES ING
+TO:
+* JAL
+"TICO SOFIWARE INC
+TO:
+* JRL
+"TALBOYS INC''*"
+TO:
+* JAL
+"TIMBERLAND CO-CLA
+TO:
+JAL
+TOMMY HILFIGER CORP-ORD"
+JAL
+TRIGUINT SEMICONDUCTOR INC
+* JAL
+UNITED PARCEL "SVE INC
+CL B
+TO:
+JAL
+
+...........••••••
+SYMBOLGUSIP
+SBL
+""BX
+"TOM
+TONT
+UPS
+URGI
+027
+QUANTIT
+-10,000
+17,400
+3,650
+6,100
+13,900
+9,800
+5,350
+16,700*
+-14,700*
+*346
+07/2702;19:19 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+June 28, 2002
+
+
+16 of 20
+DATE
+07/11/02
+07/08/02
+07/12/02 07/09/02 SOLD
+07712/02
+07709/02
+07/92/02 *07/0902*SOLD
+07/12/02
+107/09/02
+'''SOLD
+07712/02 07/09/02 SOLD
+STAGE STORES INC
+NEW
+ECUTION BY NI
+: 1000 12-26-1
+COMMISSION
+AS OF 07/08102
+BEA SYSTEMS INC
+1,00.00
+COMMISSION
+SEC FEE
+,95.00
+CENDANT CORP***
+EXECUTION BY TWPT
+VS 250 11-12-01, 6500 10-03-01
+COMMISSION
+472,50
+SEC FEE
+3,06
+CONTINENTAL AIRLINES ING-CLB*
+EXECUTION BY MLCO
+VS 1550 12-24-01, 150 12-18-01
+COMMISSION
+SEC FEE
+719.00
+EMMIS COMMUNICATIONS CORP CLA
+EXECUTION BY MONT
+VS 1300 12-26-01, 500 12-18-01
+DOMMISSION
+SEC FER
+1.92.00
+"FLEXTRONICS INTERNATIONAL
+EXECUTION BY COWN
+VS 800 03-05-02
+COMMISSION
+SEC FEE
+119.00
+SYMBOLCUSIP
+STGS
+BEAS
+"CAL
+EMMS
+"FLEX
+027
+QUANTITY
+-1,000
+33.50440
+3,900
+6,750
+*1,700
+-1,800
+*800
+8.11000
+15.02530
+'14:57480
+20.57740
+
+07127102;19:19 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 28, 2002
+33,441.39
+31,421.04
+100,933.22
+24:64541
+36,936.20
+6,038.05
+
+
+17 of 20
+SETTLEMENT TRADE
+DATE
+07/12/02
+07/09/02
+07/12/02 07/09/02 SOLD
+07/12/02
+*07/09/02
+07/25/02
+TOTAL
+MONEY FUND ACTIVITY
+06/29/02
+07/01702 SOLD
+07/02/02 BOUGHT
+IONA TECHNOLOGIES PLE
+SPONSORED ADR
+ES CUTION BY 5-02, 1700 02-07-0
+SE FESSION
+20.00
+T-MANY INC
+5 400120000
+COMMISSION
+SEC FEE
+1347.00
+SYMBOL TECHNOLOGIES INC
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+UNSOLICITED
+........
+WTS AMERICAN BANK NOTE
+HOLOGRAPHICS
+DUE 06/18/03
+EXP 06/18/2003
+FORE
+OPENINGBALANCE
+EARED THROUGH I
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 28, 2002
+8,702.73
+SYMBOL/GUSP
+IONA
+IMNY
+
+QUANTITY
+-3,000
+4,900
+5,400
+2,151
+2.93500
+= 2.41570
+
+17,677.57
+40,343.79
+$-296,181.73
+SYMBOUCUSIP
+QUANTITY
+4,985,787.77
+- 10,000
+215,000
+027
+1.0000*
+...0000L.
+07/2702;19:19 001
+
+$1,757,067.20
+10,000.00
+
+
+18 or 20
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+07/03/02
+67/08/02
+07/09/02
+67/10/02
+07/11/02
+07/11/02
+"BOUGH
+BOUGH
+DIVIDEND
+07/11/02
+"FUND
+07744702 "FUND"
+0772/02
+"DIVIDEND
+Ö772/02
+"FUND
+07/26102
+TOTAL
+SYMBOUCUSIP
+GIDXX
+"DOMEST PRIME PORTFOLIO
+"DOMEST PRIMES PORTFOLIO
+DIVIDEND CLOSEOUT
+ONE PREM PORTFOLIO
+FROM TYPE 2
+DOMEST ME A PORTE
+TO TYPE 1
+DIVIDEND CLOSEOUT
+ONE MAKE MAN PORTFOLIO
+ADJUST POSITION
+CLOSINGBALANCER
+GTXX
+"GTOXX
+GTXX
+*GTDXX
+"GTOXX
+QUANTI
+[75.00đ
+60,000
+39,000
+5,425,787.77
+39,000
+6,336.96
+6,336.96
+0.00
+027
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 28, 2002
+175,000.00
+60,000.00
+"39,000.00
+1.0000*
+0000*
+.0000
+1.0000"
+5,425,787.77
+38,965.00
+3,021.70
+493.88
+$-489,000.00
+$5,478,268.35
+07/27/02;19:19 001
+
+
+OFFICE SERVICING YOUR ACOUNT
+19 of 20
+DIVIDENDS
+097/01/02
+REC 051502 PAY 070102
+07/01702-MC GLOBAL INC......
+07/01/02
+REG 081202 AT 05020M
+07/0802 ME 061902 PAY 070802
+TOTAL
+INTEREST
+DATE
+07/22/02
+INT CR
+07722/02
+-
+TOTAL
+JUL 02
+JUL 02
+MISCELLANEOUS
+DATE
+MO/DAY
+07/10/02
+
+"JOURNAL'
+07/12/02 JOURNAL"
+TO:
+* JRL
+''TO
+• JAL
+• JRL
+SYMBOUCUSIP
+MCH
+*FDX
+QUANTITY
+RATE (S)
+3,500
+0.3500
+7,000••
+0.0200
+8,600
+0.1350
+3,900
+0.0500
+SYMBOUGUSIP
+QUANTITY
+RATE (%)
+667,081.19
+6,224.85
+- 5,843,804.92
+027
+14.94
+$-14.94
+CRECIT AMOUNT
+07/2702;19:19 001
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 28,2002
+1,225.00
+-140.00
+1,161.00
+.. . .
+195.00
+$2,721.00
+700.83
+$700.83
+
+
+20 of 20
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+07/15/02
+TOMATON
+07/15/02 JOURNAL
+TOTAL
+To:
+• JRI
+FROM
+* JAL*
+5,843,311.04
+$-12,360,422.00
+CRECIT AMOUNT
+5,843,311.04
+$5,843,311.04
+STOP
+****** End of Statement******
+027
+07/27/02;19:19 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 28,2002
+
+
+lear, Steams & Co. Inc
+83 Madison AvenL
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31,2002
+What's In This Statement
+Financial Summary.....
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity.....
+Trades Not Yet Settled
+3
+4
+8
+18
+21
+INSTITUTIONAL INTERESTS
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENNAN
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+11,154,280
+64,730
+4,985,788
+NET EQUITY THIS PERIOD
+$16.204.798
+••••••••
+NET EQUITY LAST STATEMENT
+17,278,908
+CHANGE SINCE LAST STATEMENT
+-1,074,110
+*This portfolio indudes one or more unpriced securies that are not
+reflected in the Total Value of Secures and the Net Equity This Period.
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$5,050.518
+$4,184,719
+Cash & Equivalent
+Equities
+$11.154,280
+# $13.094.189
+Current market value
+SP This satement stori for ratanal for our red de. Spot revere did or dotan itormation.
+
+
+2 of 22
+Bear, Steams Securities Corp
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+06/29/02;12:40 001|
+
+
+3 or 22
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Amount Credited
+Securities Bought
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERIOD
+3915.551.23
+1,582,617.93
+357,919.83
+7,479.94
+$1.948,017.70
+-728,219.08
+-2,100,619.83
+52828.838.91
+-880,821.21
+...
+$64,730.02
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+940,365.44
+5,185.79
+$945,551.23
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+Foreign Tax Withheld
+THIS PERIOD
+10,360.71
+1,039.06
+$11.399.77.
+0.00
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Totall
+027
+CLOSING
+58,505.17
+6,224.85
+$64,730.02
+YEAR TO DATE
+40,426.34
+6,224.85
+•*••••••••••
+$46,651.19
+-124.31
+5,050,518
+11,154,280
+516.204,798
+LEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+32%
+Equities
+68%
+Unshaded portions denote debe balance andor short
+
+
+4 of 22
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+THE TREASURERS FUNDING
+DOMESTIC PRIME MAM PORTFOLIO.
+THE TREASURERS FUNDING
+DOMESTIC PRIME MIM PORTFOLIO
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+ABERCROMBIE & FITCH CO-CLA
+AMERICAN EAGLE OUTFITTERS ING
+NEW
+WTS AMERICAN BANK NOTE
+HOLOGRAPHICS
+EXP 06/18/2003
+ANALOG DEVICES INC
+BEA SYSTEMS INC
+BEVERLY ENTERPRISES INC NEW
+CA BARD INC
+VIYC CORI
+CALPINE CORP
+CENDANT CORP
+COSTCO WHOLESALE CORP NEW
+SYMBOLCUSIP
+GTOXX
+GTDXX
+QUANTITY
+4979,450.81
+6,336.96
+1.0000
+1.0000
+SYMBOUCUSIP
+ANF
+AEOS
+
+ADI
+BEAS
+BEV
+BCR
+CYTC
+CPN
+COST
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+3,200
+4,500
+2,151
+1,300
+3,20
+1,70
+1,700
+7,300
+21,400
+.....
+13,450
+4,350
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+MARKET
+VALUE
+64,730
+....
+1,979,45
+6,337
+$5,050,518
+24.1200
+1.140
+Unpriced
+29.7000
+9.4100
+7.6100
+56.5800
+T.0300
+5.880
+8.620
+ESTIMATED
+ANNUAL INCOME
+74,194
+94
+$74,288
+MARKET
+VALUE
+77,184
+5,13
+38,610
+77,162
+317,337
+96,186
+55,626
+150,442
+13,58
+167,997
+027
+1.4900
+......
+1.4834
+ESTIMATEC
+ANNUAL INCOME
+CURRENT
+YIELD (%)
+1,428
+1.4846
+
+
+5 of 22
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+CITIZENS COMMUNICATIONS CO
+... ..
+CSX CORP
+COOPER INDUSTRIES LTD
+CLA
+CABOT CORP
+CANDIES ING
+... ..
+KENNETH COLE PRODUCTIONS INC
+CL A
+CISCO SYSTEMS INC
+.. . .
+CONTINENTAL AIRLINES INC-CL B
+... ..
+DMC STRATEX NETWORKS INC
+DOW CHEMICAL CO
+EDISON INTERNATIONAL
+EMMIS COMMUNICATIONS CORP-CL A
+EXPEDITORS INTERNATIONAL OF
+WASHINGTON INC
+B.......•........................•--••-----
+FOX ENTERTAINMENT GROUP ING
+CLA
+FEDEX CORP
+FOOT LOCKER INC
+FEDERATED DEPARTMENT STORES
+INC-DEL
+.............
+FLEXTRONICS INTERNATIONAL
+LTD
+SYMBOLCUSIP
+CZN
+CSX
+CBE
+CBT
+CAND
+....
+KCP
+CSCO
+CAI
+DOW
+EIX
+EMMS
+EXPD
+FOX
+FDX
+FLEX
+ONA TECHNOLOGIES PLO
+SPONSORE ........
+IONA
+CASH
+.....
+CASH
+.....
+CASH
+CASH
+MRGN
+CASH
+CASH
+CASH
+.......
+CASH
+CASH
+CASH
+.............
+CASH
+CASH
+CASH
+CASH
+CASH
+......
+CASH
+CASH
+CASH
+QUANTITY
+31,000
+2,700
+3,300
+5,400
+346
+7,500
+7,600
+7,550
+5,650
+9,400
+17,250
+.. ...
+7,650
+.. . .
+6,000
+14,600
+3,900
+11,650
+6,200
+7,100
+14,800
+8.3600
+...
+35.0500
+39.3000
+28.6500
+.0500
+...........
+28.3500
+3.9500
+5.7800
+2.0100
+34.3800
+17.0000
+21.1900
+33.1600
+21.7500
+53.4000
+14.4500
+39.7000
+7.1300
+5.2990
+259,160
+94,635
+129,690
+154,710
+,401
+212,625
+106.020
+19,13
+11,357
+323,172
+293.250
+162,104
+198,960
+317,550
+208,260
+168,343
+246,140
+50,623
+8,42
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+CURRENT
+YELD IN
+1,080 1.1412
+......
+4,620
+3.5623
+2,808
+1.8150
+....
+12,596
+720
+3.8976
+0.3619
+80**0374
+0.374
+06/2902;12:40 001
+
+
+6 of 22
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+HONEYWELL INTL INC
+. . . .
+I-MANY INC
+HCA ING
+RM HCA-HEALTHCARE COMPAN
+KOHLS CORP
+....
+LIBERTY MEDIA CORP
+SER A NEW
+LIZ CLAIBOR
+INC
+MILLENNIUM CHEMICALS INC
+MYKROLIS CORP
+NOVA CHEMICALS CORP
+NOR
+EST
+AIRL
+INES CORP
+NORFOLK SOUTHERN CORP
+POLO RALPH LAUREN CORP-CL A
+OLIN CORP NEW
+... ..
+OMNICARE INC
+... . .
+PACIFIC SUNWEAR OF CALIFORNIA
+QUIKSILVER INC
+ROYAL CARIBBEAN CRUISES LID"
+SICOR ING
+SKECHERS USA INC
+CLA
+SIMBOLCUSIP
+HON
+IMNY
+HCA
+JNY
+KSS
+LIZ
+CH
+NCX
+NIAC
+NSC
+OCR
+....
+PSUN
+ZQK
+RCL
+SCRI
+SKX
+CASH
+.....
+CASH
+.....
+CASH
+CASH
+....
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+.....
+ASI
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+4,150
+57,650
+11,000
+11,200
+1,200
+25,200
+0,400
+8,600
+9,300
+4,500
+2,500
+8,450
+6,407
+4,100
+6,300
+10,950
+18,650
+10,250
+10,800
+9,000
+35.2300
+2.7490
+47.5000
+37.5000
+70.0800
+10.0000
+31.8000
+14.0500
+11.8100
+22.5400
+12.0600
+23.3800
+22.4000
+22.1500
+26.2600
+.. . .
+22.1700
+24.8000
+19.5000
+18.5400
+21.6100
+146,205
+158,480
+522,500
+420,000
+224,256
+252,000
+330,720
+120,830
+109,833
+101,430
+30,150
+197,561
+143,517
+90,815
+165,438
+242,762
+462,520
+99.87
+200,232
+194,490
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+ANNUAL INCOME
+3,113
+880
+CURRENT
+YELD (S)
+2.1292
+0.1684
+...
+2,340
+4,644
+763
+2,028
+3,280
+567
+5,330
+0.7075
+.843
+0.7522
+1.0265
+3.6117
+0.3427
+26667
+
+
+7 of 22
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+STAGE STORES ING
+NEW
+SANMINA-SCI CORP
+SYMBOL TECHNOLOGIES INC
+TIBCO SOFTWARE INC
+TALBOTS INC
+TIMBERLAND CO-CLA
+TOMMY HILFIGER CORP.ORD
+TRIQUINT SEMICONDUCTOR INO
+UNITED PARCEL SVC INC
+CL B
+UNITED RETAIL GROUP INC
+... . . .
+ISHAY INTERTECHNOLOGY IN
+YOUNG BROADCASTING INC-CLA
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLICUSIP
+STGS
+SANM
+SBGI
+SBL
+TIBX
+TLB
+TBL
+TOM
+TONT
+UPS
+URGI
+YBTVA
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH**
+CASH
+CASH
+CASH
+......
+CASH
+CASH
+QUANTITY
+8,800
+10,900
+21,600
+15,400
+17,400
+4,250
+6,100
+3,90
+9,800
+...
+5,350
+16,700
+......
+2,700
+17,300
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+34.7400
+6.3100
+4.4390
+8.5000
+5.5600
+35.0000
+35.8200
+14.3200
+6.4100
+61.7500
+10.5000
+22.0000
+17.7800
+MARKET
+VALUE
+305,712
+68.775
+311,882
+130,900
+96.744
+148,750
+218,502
+199,048
+62,818
+330,363
+175,350
+59,400
+307,594
+$11,154,280
+$11,154,280
+$127,169
+$16,204,798
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+URREN
+..........
+.. . .
+308
+).2353
+....
+1,530
+.0286
+4,066
+1.2308
+$52,881
+$52,881
+
+
+8 of 22
+Transaction Detail
+INVESTMENT ACTIVITY
+DATE
+TRANSAGTION
+06/03/02
+05/29/02
+06/03/02 05/29/02 "BOUGHT
+08/03/02
+•05/29/02
+ö6/04/02
+05/30/02
+06/0402 05/3002 BOUGHT
+06/04/02
+05/30/02
+06/05/02
+05/31/02
+IMC GLOBAL INC
+SEE NOTE "S' ON BACK
+XECUTO BYS
+'S 1000 10-05-0
+COMMISSION
+SEC FEE
+72.00
+"QUIKSILVER INC
+EXECUTION BY ADAM
+VS 1200 05-29-02
+COMMISSION
+84,00
+"TALBOTS INC
+XECUTION BY BUO
+S 1200 04-29-0
+COMMISSION
+72.00
+SEC FEE
+"COSTCO WHOLESALE CORP NEW
+EXECUTION BY JPHO
+VS 800 02-26-02
+COMMISSION
+SEC FEE
+-35.00
+A SUWER OF CALFON
+EXECUTION BY JPHO
+VS 600 05-30-02
+COMMISSION
+30,00
+"TIMBERLAND CO-CLA"
+EXECUTION BY BUCK
+VS 1700 05-30-02
+COMMISSION
+102.00
+DEPI COMNUNIEATIONS CORP
+SEC FEE
+SYMBOLCUSIP
+IGL
+*ZOK
+COST
+"ADELO
+027
+QUANTITY
+-1,000
+13.62420
+1,200
+-1,200
+800°
+500*
+1,700
+26,300
+22.20790
+37.42250
+39.28000
+
+•''38.90000
+- 078220"
+LEARED THROUGH I
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+13,538.78
+*'26,748.48
+44,818.64
+31,368.05
+66,247.00
+86-986'0.....
+19,767.24
+
+
+9 of 22
+SETTLEMENT TRADE
+DATE
+06/05/02
+05/31/02
+06/05/02 05/31/02 BOÜGHT
+06/05/02 05/31/02
+• BOUGHT
+06/05/02
+05/31/02
+06/06/02
+06/03/02
+06/06/02
+06/03702
+*SOLD
+06/06/0206/03/02 SOLD
+CALPINE CORP
+EXECUTION BY ADAM
+S 2800 05-31-0
+OMMISSIO
+168.00
+MILLENNIUM CHEMICALS INC
+EXECUTION BY LEHN
+IS 2400 05-31-02
+COMMISSION
+168,00
+OLIN CORP NEW™
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY MLCO
+S 4100 05-31-0
+OMMISSION
+287,00
+YOUNG BROADCASTING INC-CLA
+EXECUTION BY FBCO
+VS MIS 0531-02
+160,00
+*DELPHIA COMMUNICATIONS COF
+EXECUTION BY SBSH
+VS 10300 05-23-0
+COMMISSION
+SEC FER
+326,00
+ROYAL CARIBBEAN CRUISES LTD
+SEE NOTE 'S' ON BACK
+EXECUTION BY JPHO
+VS 1100 12-18-01
+SEC FESSION
+77.00
+"TYCO INTERNATIONAL" LTD
+EXECUTION BY INET
+VS 2550 10-03-01
+COMMISSION
+SEC FEE
+1.55:00
+SYMBOLCUSIP
+CPN
+MCH
+OLN
+ADELÖ
+ACL
+TYC
+027
+QUANTITY
+2,800
+2,400
+4,100
+9.38000
+14.01500
+19.76740
+3,200
+10,300
+-7,700
+19.94230
+0.70540
+22-64880
+2,550
+- 18.05330
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+26,447.00
+33,819.00
+81,348.34
+63,990.36
+7,044.40
+24,820.93
+''45,968.53
+
+
+10 of 22
+DATE
+06/07/02
+06/04/02
+06/07702 06/04/02 SOLD"
+06/07/02
+06/04/02
+08/07702
+
+06/10/02
+06/05/02
+08/10/02
+:*06/05/02BOUGHT
+06710702 06/05/02"BOUGHT
+ANALOG DEVICES INC
+WITH RIGHTS TO PURCHASE COMMON
+TK UNDER CERTAIN CIRCUMSTANO
+ECUTION BY BUC
+00S 0004-02
+72,00
+BEA SYSTEMS NG
+S00011- 7-01T
+COMMISSION
+23.00
+TETRONE EATINAL.
+EXECUTION BY FBCO
+CSMMISSON 1-02
+75.00
+"TALBOTS INC***
+EXECUTION BY BUCK
+VS 1000 04-29-02, 200 04-30-02
+DOMMISSIO
+SEC FEI
+127.00
+AMERICAN BANK NOTE
+HOLOGRAPHICS INC
+EXECUTION BY NITE
+VS 2000 05-13-02
+SEC FEE
+REVERCAN EAGLE OUTFITERS ING
+5 34000605-02
+"PACIFIC SUNWEAR OF CALIFORNIA"
+50.00
+SYMBOLCUSP
+ADI
+BEAS
+FLEX
+ABHH
+"AEOS
+'"PSUN"
+027
+QUANTITY
+1,200
+-900
+1,500
+-1,200
+2,000
+*3,400
+1,000
+35.29860
+1022940"
+10.02500
+••'35.12540
+67000
+22.58250
+- 1951000
+06/2902;12:40 001
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+42,445.32
+*9,164.18
+15,127.50
+42,062.21
+3,324.89
+76,795.50
+19,575.00
+
+
+11 of 22
+SETILEMENT TRADE
+DATE
+DATE
+06/10/02
+06/05/02
+68/10/02 06/05/02"*SOLD"
+VS 200 04-30-02
+COMMISSION
+SEC FEE
+06/11/02
+06/06/02
+06/11702
+06/08/02
+
+06/06/02
+06/12/02
+06/0702
+BOUGH
+88772702 06707702'BOUGA
+23.00
+98,00
+2.09
+EXECUTION BY NITE
+SEC BES 05-13-02
+.09
+"CYTY CORP''
+EXECUTION BY TWPT
+- 0 08080602)
+170,00
+YOUNG BROADCASTING INC-CLA
+EXECUTION BY FECO
+65,00
+"ADELPHIA COMMUNICATIONS CORP"
+EXECUTION BY NET
+S 15000 05-23-0
+150,00
+"HYE" CORP
+EXECUTION BY TWPT
+VS 3900 06-07-02
+COMMISSION
+195.00
+SYMBOLCUSIP
+TLB
+'''UHS
+HHEY.
+"ABELO
+027
+QUANTITY
+-200
+1,400
+1,635
+3,400
+1,300
+15,000
+3,500
+36.58811
+• 4939000"
+67000
+• 12.01880
+'19.76270
+- 0.27910
+06/2902;12:40 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+7,290.39
+09030-51
+2,715.36
+41,048.92
+25,771.51
+3,721.37
+46,550.97
+
+
+12 of 22
+SETLEMENT THE
+DATE
+06/12/02
+06/07/02
+06/12/02 06/07/02 SOLD
+06/13/02
+''*06/10/02
+06/14,02
+06/1702
+06/14/02
+06/11/02
+"SOLD"
+88777702 86772702'SOB
+CALPINE CORP
+EXECUTION BY COWN
+162,00
+COX COMMUNICATIONS ING NEW
+1,98:00
+"ADELPHIA COMMUNICATIONS CORP
+371,08
+"COX COMMUNICATIONS ING NEW
+EXECUTION BY LEHM
+VS 1300 05-17-02
+COMMISSION
+SEC FEE
+1,7.00
+PEACE STORES INC
+EXECUTION BY FBCO
+COMMISS04-09-02, 70050-22-02
+85,00
+SEC FEE
+"STAGE STORES INC
+1.73
+NEW
+XECUTION BY FBO
+S 300 03-22-02, 700 01-03-0
+900 01-02-02, 900 12-26-01
+SEC FESSION
+2.19,00
+SYMBOLGUSIP
+CPN
+COX
+"ADELO
+SPIS.
+SEIS
+027
+QUANTITY
+2,700
+1,300
+:18,554
+8.45000
+29.97000
+0.18470
+-1,300
+29.81040
+-1,700
+33.69650
+2,800
+*32.81040
+06/29/02:12:40 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+22,992.00
+38,853.82
+3,040.73
+*38,646.35
+57,182.32
+*91,711:35
+
+
+13 of 22
+SETTLEMENT TRADE
+DATE
+06/17/02
+06/12/02
+66/18/02 06/13/02**"BOUGAT
+06/19/02
+06774/02
+06/1902*06/14/02**SOLB
+06/19/02
+2 06/14/02
+88779702'
+06714/02
+08719/02
+08/142
+TOMMY HILFIGER CORP-ORD
+EXECUTION BY BUCK
+VS 1700 05-23-02
+COMMISSION
+SEC FEE
+1702.00
+V5140006-1-02
+DOMMISSION
+98,00
+ANALOG DEVICES INC
+EXECUTION BY MDLD
+VS 1400 05-17-02
+COMMISSION
+SEC FEE
+1.39.00
+CENDANT CORP
+EXECUTION BY TWPT
+VS 2100 05-17-02
+COMMISSION
+SEC FEE
+137.00
+CELESTICA INC
+SUBORD VTG SHS
+EXECUTION BY MSCO
+VS 900 03-28-02
+SOMMISSION
+63,00
+SEC FEE
+•COST WHOLESALE CAP NEW
+EXECUTION BY MONT
+VS 300 02-26-02, 1100 12-13-01
+SEC FEE
+1.66
+"LIBERTY MEDIA CORP™
+SER A NEW
+EXECUTION BY RHCO
+VS 700 09-28-00, 1700 09-29-00
+OMMISSION
+- 721.00
+SYMBOLCUSIP
+TOM
+"ADI
+"COST"
+027
+QUANTITY
+-1,700
+1,400
+-1,400
+*2,100
+900*
+14.84100
+' 41:44300"
+32.28620
+•*15:22600
+23.80000
+1,400
+2,400
+"39.26460"
+9.90000
+06/2902;12:40 001
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+25,111.94
+'58,733.20
+45,086.31
+31,811.63
+21,341.35
+'54,353.78
+23,600.28
+
+
+14 of 22
+SETILEMENT TRADE
+DATE
+DATE
+06/19/02
+06/14/02
+68/19/02 06/14/02"*SOLD"
+06/19/02
+•05/74002
+06/19/02
+06/14/02
+06/19/02 06/14/02
+"SOLD"
+06/20/02
+3/17/
+06/24/02
+08/19/02
+REMEC INC
+EXECUTION BY OPCO
+/S 4350 04-18-01
+DOMMISSION
+SEC FEE
+1317,50
+SANMINA SCH CORP
+EXECUTION BY MSOO
+S 1000 03-12-0
+OMMISSIO
+SEC FEE
+50.00
+"TALBOTS INC
+EXECUTION BY BUCK
+VS 700 04-30-02, 350 04-23-02
+COMMISSION
+SEC FEE
+157,00
+TOMMY HILFIGER CORP-ORD
+EXECUTION BY BUCK
+VS 1400 05-23-02
+-64.00
+"TAIQUINT SEMICONDUCTOR INC
+EXECUTION BY NITE
+SEC FEE 0328-02, 20004-1602
+AMERICAN EAGLE OUTFITERS INC
+COMMISSION
+55,00
+EROON BY BEER OF
+SE FS 03302)
+52.00
+SYMBOLCUSP
+REMC
+TOM
+*TONT
+*TOM
+027
+QUANTITY
+-4,350
+-1,000
+-1,050
+-1,400
+'1,700*
+1,100
+1,200
+5.92720
+- 777310"
+37.97730
+14.99530
+-6.698709
+T:2250300
+15.45470
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+25,550.04
+7,047.88
+39,796.96
+20,893.78
+11,372.44
+23,723.30
+18,458.08
+
+
+15 of 22
+SETTLEMENT TRADE
+DATE
+06/25/02
+DATE
+06/20/02
+66/25 02 06/20/02**SOLD"
+06/2502
+*06/20/02
+''''SOLD
+06/25/02*06/20/02*S0LB
+06/26/02 06/24702 SOLD
+88/2770206724702''S0B
+......
+CALPINE CORP
+EXECUTION BY BUCK
+S 10600 04-24-0
+OMMISSION
+530,00
+SEC FEE
+2.43
+"EMIS COMMUNICATIONS CORP-CLA
+EXECUTION BY DBAB
+VS 1400 12-26-01
+COMMISSION
+SEC FEE
+1.05:00
+"MC GLOBAL INC"
+SEE NOTE 'S' ON BACK
+EXECUTION BY MLCO
+VS 500 10-05-01, 500 10-11-01,
+100 10-03-01
+COMMISSION
+SEC FEE
+17.00
+UBERTY MEDIA CORP***
+SER A NEW
+EXECUTION BY MLCO
+VS 2300 09-29-00
+COMMISSION
+SEC FEE
+661.00
+TOMMY HILFIGER CORP-ORD
+EXECUTION BY BUCK
+S 400 05-23-0
+IMMISSIO
+SEC FEE
+128.00
+TS 140008-13402, 1300 05-220
+OMMISSIO
+EC FE
+2,05.00
+SYMBOLICUSIP
+CPN
+''EMMS
+"TOM
+"EBE
+027
+QUANTITY
+-10,600
+1,400
+1,100
+2,300
+:400
+2,700
+7.61250
+'''24:90070"
+13.46890
+- 14.59020
+"37.41800
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+80,145.07
+''34,774.93
+14,723.34
+021:0333
+5,796.90
+100,821.55
+
+
+16 or 22
+SETTLEMENT TRADE
+DATE
+06/27/02
+06/24/02
+0627702 06/24/02 "BOUGHT
+06/28/02
+•*0625/02
+06/28/02*06/25/02*S0LB
+06/2802 06/25/02
+"SOLD"
+06/28/02 06/25/02 SOLD
+06/28/02 06/25/02
+IMC GLOBAL INC
+SEE NOTE "S' ON BACK
+XECUTION BY MLO
+'S 5900 10-03-0
+SEC FISSION
+228.00
+*TOMMY HILFIGER CORP ORD
+84,00
+ANALOG DEVICES INC***
+EXECUTION BY MONT
+VS 900 05-17-02
+COMMISSION
+SEC FEE
+EXECUTION BY INET
+,73.00
+SEC FEE
+168.00
+SEC MISSION
+1196,00
+"CELESTICA INC''
+SUBORD VTG SHS
+EXECUTION BY SSH
+VS 1200 04-08-02
+COMMISSION
+SEC FEE
+81.00
+"CITIZENS COMMUNICATIONS "CO
+EXECUTION BY MONT
+VS 6200 05-02-01
+SEC FESSION
+1.67.00
+SYMBOLGUSP
+IGL
+"TOM
+"ADI
+'''CZN
+027
+QUANTITY
+-5,900
+1,400
+*900
+12.71760
+''14:47610*
+28.55020
+2,600
+2,800
+-1,200%
+* 8.40830
+15.69300
+22.33200
+6,200%
+- 8.60100
+06/2902;12:40 001
+LEARED THROUGH I
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+74,603.58
+' 20,365.54
+25,616.40
+21:767:92
+43,728.07
+26,698.59
+'''52,875.59
+
+
+17 of 22
+SETTLEMENT TRADE
+DATE
+06/28/02
+06/25/02
+66/28/02* 06/25/02**S0LB
+06/28/02
+20625(02
+06/28/02
+06/25/02
+06/28/02
+06/25/02
+BOUGH
+06/28/02
+*06/25/02
+'SOLD"
+06228/02 06725/02 BOUGHT
+CISCO SYSTEMS INC
+EXECUTION BY COWN
+2600 03-28-
+IMMISSIO
+SEC FEE
+109.00
+"CONTINENTAL" AIRLINES "ING 8L8"
+EXECUTION BY NEED
+SE 032602 00232802
+133,00
+MC STRATEX NETWORKS INC
+EXECUTION BY VKCO
+VS 1350 06-28-01, 3200 12-05-0
+0. M0 1017-01
+SEC FEB
+290,00
+"EDISON INTERNATIONAL"
+EXECUTION BY MSCO
+VS 1900 04-16-02
+OMMISSIO
+EC FE
+1133,00
+EXPEDITORS INTERNATIONAL OF
+LIBERTY MEDIA CORP"
+SECUTION BY LEMM
+/S 4500 09-29-0
+OMMISSIO
+SEC FEE
+223.00
+"TOMMY HILAGER "COAP BAD"
+EXECUTION BY BUCK
+VS 1800 06-25-02
+COMMISSION
+108,00
+SYMBOLCUSIP
+CSCO
+"CAL
+027
+QUANTITY
+-2,600
+1,900
+5,800
+1,900
+3,000
+4,500
+13.58000
+• 1601790"
+2.27410
+• 17.77160
+- 9.19200
+1,800
+*''14:48120
+06/2902;12:40 001
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+35,161.93
+*30,285.09
+2,884.30
+33,617.02
+47,077.75
+*26,153.16
+
+
+18 of 22
+DATE
+06/28/02 06/25/02
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+06/01/02
+OPENINGBALANCE
+06/03/02* *SOLD
+06/04/02
+06/06/02
+06/07/02
+66/10/02
+08/12/02
+06/13/02
+*BOUGH
+BOUGHI
+06/14/02
+06/17/02
+06/18/02
+BOUGHI
+Bear, Stearns & Co. Inc.
+VISHAY INTERTECHNOLOGY INC
+SEE NOTE 'S' ON BACK
+EXECUTION BY SBSH
+VS 2200 11-27-01
+COMMISSION
+SEC FEE
+154,00
+1.43
+SYMBOLCUSIP
+VSH
+QUANTITY
+-2,200
+21.46000
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+47,041.57
+$-728,219.08
+$1,582,617.93
+SYMBOU/CUSIP
+"GTXX
+GTXX.
+*GTXX
+QUANTITY
+3,239,167.94
+150,000
+126,000
+10,00
+75,000
+30,000
+11,700
+121,000
+53,000
+285,000
+36,000
+027
+1.0000
+0000
+0000
+.0000
+0000
+.0000
+.0000
+0000
+.0000
+0000
+126,000.00
+171,700.00
+121,000.00
+285,000.00
+150,000.06
+10,800:00
+75,000.00
+30,000.00
+53,000.00
+36,000.00
+
+
+19 or 22
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+06/20/02
+06/21/02
+'''BOUGHT
+06/21/02*
+''DIVIDEND
+MONTHLY DIVIDEND
+06/21102 DIVIDEND"
+MONTHLY DIVIDEND
+06/21/02
+'''*REINVEST
+06/21702
+''''EINVESY
+MONTHLY DIVIDEND REINVESTED
+HE TREASURERS" FUND INC"
+OMESTIC PRIME MIM PORTFOLI
+MONTHLY DIVIDEND REINVESTED
+68/2402"
+'''BOUGHT
+ONE PREM ORFOL
+06/25/02
+06/26/02"
+'BOUGHT
+06/27102 BOUGHT
+DOMEST PRIME MORTALIO
+06/28/02
+06/28/02
+TOTAL
+CLOSINGBALANCER
+SYMBOUCUSIP
+GIDXX
+"GTOXX"
+QUANTITY
+25,000
+163.000
+*3,126.04
+793.79
+15,000
+160,000
+360,000
+660,000
+70,000
+4,985,787.77
+027
+1.0000
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+25,000.00
+163,000.00
+3,126.04
+793.79
+1:000*
+1.0000
+7.0000"
+1.0000
+3,126.04
+793.79
+15:000.00
+160,000.00
+360,000000
+660,000.00
+70,000.00
+$-2,100,619.83
+$357,919.83
+
+
+OFFICE SERVICING YOUR ACOUNT
+20 of 22
+DIVIDENDS
+
+THCA INC
+RM HOA-HEALTHCARE COMPAN
+EC 05/01/02 PAY 06/01/0
+06787702 UNITEB PAACEL SVCINC
+REC 05/28/02 PAY 06/07/02
+6670102RE 0659202 PAY 061002
+06/10/02
+''LIZ CLAIBORNE INC..
+REC 05/20/02 PAY 06/10/02
+66/18/02 NORFOLK SOUTHERN COAP"
+REC 05/03/02 PAY 06/10/02
+06/12/02
+''OMINICARE INC
+REC 05/31/02 PAY 06/120
+06/14/02
+A 002 PA 061402
+REC 05/31/02 PAY 06/14/02
+06/17/02 EXPEDITORS INTERNATIONAL OF
+WASHINGTON INC
+REC 06/03/02 PAY 06/17/02
+06/1702TALBOTS INC.*
+REC 06/03/02 PAY 06/17/02
+......
+06/27/02
+ROYAL CARIBBEAN CRUISES LTD
+REC 06/05/02 PAY 06/27/02
+TOTAL
+SYMBOUCUSIP
+HCA
+'UPS
+'HON
+OCA
+CSX
+CBT
+"EXPD
+ACL
+QUANTITY
+12,400
+RATE (S)
+0.0200
+'5,350*
+''0:1900
+*4,150 0.1875
+10,400
+0.0562
+*4,350*•*0.0600
+6,300
+0.0225
+*2,700
+'0.1000
+5,400
+0.1300
+3,000
+''0.1200
+6,700*0.0900
+11,350
+0.1300
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+248.00
+1,016.50
+778.13
+585.00
+261:00
+141.75
+270.00
+702.00
+360.00
+- 603.00
+1,475.50
+$6,440.88
+
+
+Bear, Stearns & Co. Inc.
+21 or 22
+INTEREST
+DATE
+06/21/02
+INT CR
+TOTAL
+SYMBOUCUSIP
+JUN 02
+Trades Executed Pending Settlement
+SETTLEMENT
+DATE
+TRADE
+DATE
+07/01/02
+07/01/02
+.. . ..
+07/01/02
+07/01/02
+......... . .
+07/01/02
+07/01/02
+2 SOLD
+COSTCO WHOLESALE CORP-NEW
+ITIZENS COMMUNICATIONS CO
+CABOT CORP
+WITH RIGHTS TO PURCHASE PREFRO
+DM STRATEX NETWORKS INC
+DISON INTERNATIONAL
+"EXPEDITORS INTERNATIONAL OF
+WASHINGTON INC
+FOX ENTERTAINMENT GROUP INC
+07/01/02
+07/01/02
+07/01/02 06/26/02 SOLD***
+57/01/02*06
+07/01/02
+........
+07/01/02
+CA INC
+RM HCA-HEALTHCARE COMPAN
+...........................
+KOHLS CORP
+"UBERTY MEDIA CORP
+SER A NEW
+... ..
+LIZ CLAIBORNE INC
+TALBOTS INC
+QUANTITY
+RATE (SL
+SYMBOLICUSIP
+COST
+CZN
+*CBT
+STXN
+•****•••••
+EIX
+"EXPD"
+FOX
+"HCA
+LIZ
+027
+LEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+1,039.06
+$1,039.06
+QUANTITY
+-2,400.00
+3,200.0
+-1,400.00
+5,650.00
+...
+-2,600.00
+2,100.00
+-1,800.00
+800.0
+'00.00
+3,500.00
+2,700.00
+-600.00
+36.9554
+8.3233
+.. .
+27.0387
+2.1848
+.....
+7.155
+-31.31
+20.8681
+47.4030
+30.7990
+............
+34.2155
+06/2902;12:40 001
+88,555.29
+.. . .
+51,215.90
+37,740.04
+2,159.2
+......
+4,406.4
+65,631.33
+7.420.4
+132,513.40
+:: 13,307.63
+30, 136.58
+82,977.79
+.........•....
+20,471.66
+
+
+22 or 22
+Trades Executed Pending Settlement
+(continued)
+SETLEMENT TREE
+07/02/02
+06/27/02
+07/02/02
+06/27/02
+07/02/02
+06/27/02
+07/02/02 06/27/02
+07/02/02 06/27/02
+07/02/02 06
+07/02/02
+06/27/02
+... . .
+07/02/02
+06/27/02
+07/02/02
+06/27/02
+17/02/02
+07/02/02
+07/02/02
+TOTAL
+06/27/02
+06/27/02
+BOUGH
+06/27/02
+ABBOTT LABORATORIES
+CYTYC CORP
+CALPINE CORP
+"CENDANT CORP**
+CiTizENS COMMUNICATIONS CO
+CONTINENTAL AIRLINES INC-CLB
+EMMIS COMMUNICATIONS CORP-CL A
+FOX ENTERTAINMENT GROUP INC
+LIBERTY MEDIA CORP
+SER A NEW
+IMNICARE IN
+SINCLAIR BROADCAST GROUP INC
+CLA
+YOUNG BROADCASTING ING-CLA
+The above trades do not appear in any other section of this statemant.
+STOP
+****** End of Statement******
+SYMBOLICUSIP
+ABT
+СУТС
+CPN
+"CD
+CZN®
+"CAL
+EMMS
+FOX
+OCR
+SBGI
+YBTVA
+120
+QUANTITY
+2,700.00
+6,800.00
+-5,400.00
+5,700.00
+4,200.00
+2,500.00
+-1,100.00
+-1,900.00
+-3,300.00
+5,500.00
+-3,200.00
+-2,600.00
+38.8072
+7.2378
+5.6250
+5.101
+8.3536
+14.6846
+17.8600
+... . .
+19.7147
+8.0112
+25.6773
+13.0345
+- 17.5690
+06/29/02:12:40 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD June 1,2002
+THROUGH
+June 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+May 31, 2002
+104,983.44
+49.572.04
+30,035.08
+100,707.74
+34,817.06
+36,520.39
+19,575.40
+. . . .
+37,308.80
+6.223.1)
+141,626.25
+$296,181.73
+41,534.14
+45.533.02
+$1,028,790.58
+
+
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+What's In This Statement
+Financial Summary.............................
+Your Portfolio Holdings
+Transaction Detail ..............................
+FudA...........................
+Trades Not Yet Settle...................
+3
+8
+21
+23
+ImllmInklumll
+INSTITUTIONAL INTERESTS
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENNAN
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+13,094,189
+945,551
+3,239,168
+S17.278.908
+NET EQUITY LAST STATEMENT
+17,627,084
+CHANGE SINCE LAST STATEMENT
+-348,176
+*This portfolio indudes one or more unpriced securies that are not
+relected in the Total Value of Securties and the Net Equity This Period
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$4.184,719
+$4,378,949
+Cash & Equivalent
+Equities
+$13,094,189
+: $13,248,135
+Current market value
+SP This satement stori for atanal for our red de, not revere did ora dotan itormation.
+
+
+2 of 24
+Bear, Steams Securities Corp
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or 24
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Amount Credited
+Securities Bought
+Money Fund
+Funds Withdrawn
+Miscellaneous
+Amount Debited.
+Net Cash Activity
+Closing Balance
+THIS PERICO
+$843,946.28
+2,156,104.20
+904,164.60
+2,611.77
+$3,062,880.57
+... . .
+-2,334,459.07
+-604, 164.60
+-22,608.67
+-43.28
+5-2.961.275.62
+101,604.95
+....
+5945.551.23
+Income Summary
+Dividends
+Credit Balance Int.
+........
+Total
+Foreign Tax Withheld
+THIS PERIOD
+5,873.40
+902.97
+$6,776.37
+......
+-43.28
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+839,663.46
+4,282.82
+$843,946.28
+CLOSING
+940,365.44
+5,185.79
+*......
+$945,551.23
+........
+027
+YEAR TO DATE
+30,065.63
+5,185.79
+... . .
+$35,251.42
+........
+-124.31
+4,184,719
+13,094,189
+517.278.908
+EARED THROUGH I
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+25%
+Equities
+75%
+Unshaded portions denole debi balance and'or short
+
+
+4 of 24
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+THE TREASURERS FUNDING
+DOMESTIC PRIME MAM PORTFOLIO.
+THE TREASURERS FUNDING
+DOMESTIC PRIME MIM PORTFOLIO
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+ABERCROMBIE & FITCH CO-CLA
+AMERICAN BANK NOTE
+HOLOGRAPHICS INC
+WTS AMERICAN BANK NOTE
+HOLOGRAPHIC:
+EXP 05/18/200
+ADELPHIA COMMUNICATIONS CORP
+CLA
+ANALOG DEVICES INC
+BEA SYSTEMSING
+BEVERLY ENTER
+RISES ING NEW
+CR BARD INC
+YIYC COF
+CALPINE CORP
+SYMBOLCUSIP
+GTOXX
+GTDXX
+QUANTITY
+3.233.624.77
+5,543.17
+1.0000
+1.0000
+SYMBOUCUSIP
+ANF
+ABHH
+
+ADLAE
+ADI
+BEAS
+BEV
+CPN
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+3,200
+3,635
+2,151
+70,154
+2,400
+.....
+9,101
+1,70
+1,700
+....
+2,600
+*.....
+6.50
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+MARKET
+VALUE
+945,551
+.. ..
+3,233,625
+5,543
+$4,184,719
+29.0000
+1.8300
+Unpriced
+0.7000
+36.6200
+10.7600
+7.8100
+55.1000
+....
+6.290
+9.6400
+ESTIMATED
+ANNUAL INCOME
+48,504
+.500
+......
+83
+1.4974
+$48,587
+MARKET
+VALUE
+92,800
+6,652
+49,108
+87,888
+........
+7.91
+325.677
+93,670
+-42,354
+255,460
+027
+ESTIMATEC
+ANNUAL INCOME
+CURRENT
+YIELD (%)
+1,428
+1.5245
+
+
+5 of 24
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+CENDANT CORP
+CELESTICA INC
+.......
+SUBORD VTG SHS
+COSTCO WHOLESALE CORP NEW
+CITIZENS COMMUNICATIONS CO
+ESX CORP
+... ...
+COOPER INDUSTRIES LTD
+CL A
+CABOT CORP
+... .
+CANDIES INC
+..............
+KENNETH COLE PRODUCTIONS INC
+CLA
+......
+CISCO SYSTEMS INC
+.....
+CONTINENTAL AIRLINES INC-CL B
+... .. .
+COX COMMUNICATIONS IN NEW
+ĐNC STRATE: NETWORKS NC
+DOW CHEMICAL CO
+EDISON INTERNATIONA
+EMMIS COMMUNICATIONS CORP-CL A
+EXPEDITORS INTERATIONAL OF
+WASHINGTON INC
+...............
+FOX ENTERTAINMENT GROUP ING
+CLA
+FEDEX CORP
+SYMBOLICUSIP
+CD
+CLS
+COST
+CZN
+CSX
+CBE
+CBT
+CAND
+KCP
+Csco
+CAL
+COX
+STXN
+DOW
+EIX
+EMMS
+EXPD
+FOX
+FDX
+CASH
+.. . .
+CASH
+CASH
+.......
+CASH
+ASH
+•.....
+CASH
+CASH
+MRGN
+.........
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+AS
+CASH
+CASH
+QUANTITY
+18,350
+2,100
+6,550
+37,200
+2,700
+4,600
+5,400
+346
+7,500
+10,200
+........
+9,450
+.. ..
+2,600
+11,450
+9,400
+19,150
+....i
+9,050
+3,000
+14,600
+3,900
+18.2800
+29.5200
+39.2700
+.....
+9.400฿
+34.4000
+43.3700
+24.6300
+4.6600
+26.4200
+15.7800
+22.2700
+33.6400
+3.4900
+33.3400
+18.6600
+29.6000
+59.1000
+25.0400
+53.9500
+MARKE
+VALLI
+335,438
+61,992
+257,219
+... ..
+349.680
+92,880
+199,502
+133,002
+1,612
+198,150
+160,956
+210,452
+87,464
+39,961
+313,396
+357,339
+267,880
+177,300
+365,584
+210.405
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+ANNUAL INCOME
+CURRENT
+YIELD (S
+1,080
+6,440
+2,808
+1.1628
+....
+3.2280
+2.1112
+12,596
+720
+4.0192
+0.4061
+
+
+6 of 24
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+FOOT LOCKER INC
+FEDERATED DEPARTMENT STORES
+INC-DEL
+FLEXTRONICS INTERNATIONAL
+LTD
+"ONA TECHNOLOGIES PLC
+SPONSORED ADR
+HONEYWELL INTL INC
+I-MANY INC
+HICA INC
+(FRM HCA-HEALTHCARE COMPANY)
+.....
+IMC GLOBAL INC
+JONES APPAREL
+GROUP INC
+KOHLS CORP
+...
+LIBERTY MEDIA CORP
+SER A NEW
+LIZ CLAIBORNE INC
+MILLENNIUM CHEMICALS INC
+MYKROLIS CORP
+NOVA CHEMICALS CORP
+NORTHWEST AIRLINES CORP
+NORFOLK SOUTHERN CORP
+POLO RALPH LAUREN CORP-CL A
+OMANICARE INC
+SYMBOLCUSIP
+FD
+FLEX
+IONA
+HON
+MN
+HCA
+IGL
+JNY
+KSS
+LIZ
+MCH
+MYK
+NCX
+NWAG
+NSC
+RL
+OCR
+CASH
+.....
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+AS
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+11,650
+....
+6,200
+5,600
+14,800
+4,150
+57,650
+11,000
+8,000
+11,200
+3,200
+34,400
+10,400
+6,200
+9,300
+4,500
+2,500
+8,450
+6,407
+6,300
+15.3000
+...............
+41.4100
+13.2300
+9.9800
+39.2000
+4.3200
+49.1300
+14.0200
+39.8600
+75.0000
+12.0500
+30.6300
+14.2500
+13.5000
+25.3400
+16.7200
+21.1700
+25.8900
+28.0800
+MARKET
+178.245
+......
+256,742
+74,088
+147,704
+162,680
+249,048
+540,430
+112,160
+446,432
+240,000
+414,520
+318,552
+88,350
+125,550
+114,030
+41,800
+178,887
+165,877
+176,904
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+STIMATE
+INNUAL INCON
+CURRENT
+YIELD (S
+3,113
+880
+640
+1.9136
+0.1628
+0.5706
+2,340
+3,348
+757
+2,028
+567
+0.7346
+3.7895
+0.6639
+1.1337
+0.3205
+
+
+7 of 24
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+PACIFIC SUNWEAR OF CALIFORNIA
+INC
+... ..
+JIKSILVER I
+REME INCU
+ROYAL CARIBBEAN CRUISES LTD
+SICOR INC
+... ...
+SKECHERS USA INC
+CL A
+.....•
+STAGE STORES INC
+NEW
+SANMINA-SCI CORP
+nananaisaaaaaaaaaaaaaaaan
+SINCLAIR BROADCAST GROUP INC
+CLA
+SYMBOL TECHNOLOGIES INC
+.. . . .
+TYCO INTERNATIONAL LTD
+TIBCO SOFTWARE INC
+TALBOTS INC
+TIMBERLAND CO-CLA
+TOMMY HILFIGER CORP-ORD
+............
+TRIGUINT SEMICONDUCTOR ING
+UNITED PARCEL SVC INC
+CL B
+.......
+UNITED RETAIL GROUP INC
+... . . .
+UNIVERSAL HEALTH SERVICES INC
+CL B
+SYMBOLCUSIP
+PSUN
+ZOK®
+REMC
+RCL
+SCRI
+SKX
+STGS
+SANM
+SBGI
+SBL
+TYC
+TIBX
+TLB
+TBL
+TOM
+TONT
+UPS
+URGI
+UHS
+CASH
+CASH
+.......
+CASH
+••••••••
+ASH
+CASH
+........
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+9,350
+17,450
+4,350
+11,350
+10,800
+9,000
+13,300
+11,900
+21,600
+15,400
+......
+2,550
+..........
+17,400
+7,900
+4,400
+15,400
+11,500
+5,350
+16,700
+..........
+1,400
+19.4000
+23.0500
+7.3800
+22.5100
+16.3700
+... ..
+21.7100
+35.6200
+11.5000
+14.8200
+8.5700
+21.9500
+5.9500
+37.2000
+38.7800
+15.2200
+9.0000
+60.3800
+9.0460
+..........
+49.6200
+MARKET
+VALUE
+181,390
+402,223
+32,103
+255,489
+176,796
+...
+195,390
+473,746
+136,850
+320,112
+131,978
+55,973
+103,530
+293,880
+170,632
+234,388
+103,500
+323,033
+151,068
+69,468
+220
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+ESTIMATE
+NNUAL INCON
+CURRENT
+YELD IN
+.....
+5,902
+...-
+2.3101
+.....
+308
+...
+128
+2,844
+4,066
+0.2334
+0.2287
+0.9677
+1.2587
+06/01/02:17:25 001
+
+
+8 of 24
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+VISHAY INTERTECHNOLOGY INC
+YOUNG BROADCASTING INC-CLA
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOL/CUSIP
+VSH
+YBTVA
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+CASH
+.....
+CASH
+QUANTITY
+4,900
+12,800
+Transaction Detail
+INVESTMENT ACTIVITY
+BATEMENT TREE
+04/29/02
+04/24/02
+0429/02 04/24/02 SOLD
+CALPINE CORP
+EXECUTION BY MSCO
+MMISSI
+CELESTICA INC:
+SUBORD VTG SHS
+EXECUTION BY SIMM
+VS 2100 03-28-02
+COMMISSION
+SEC FEE
+1,015.00
+147.00
+1,85
+24.5600
+20.2000
+MARKET
+VALUE
+120,344
+258,560
+$13,094,189
+$13,094,189
+$100,580
+$17,278,908
+ESTIMATE
+NNUAL INCOM
+$51,993
+$51,993
+CURRENT
+YELD IN
+SYMBOLGUSP
+CPN
+QUANTITY
+14,500
+2,100
+12.13460
+*29.13140
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+176,981.70
+61,012.09
+
+
+9 of 24
+SETTLEMENT TRADE
+DATE
+04/29/02
+DATE
+04/24/02
+64/29/02 04/24/02**SOLB"
+04/29/02
+04/24/02
+04/30/02
+04/25/02
+04/30/02 04/25/02"BOUGHT
+0430/02
+' 04/25/02 BOUGHT
+05/01/02 04/26/02 BOUGHT
+CONTINENTAL AIRLINES INC-CL B
+EXECUTION BY SBSH
+/S 100 03-28-02, 2600 04-18-02
+DOMMISSION
+SEC FEE
+189,00
+2,28
+"TERRORES WENATIONA
+COMMISSION
+280,00
+VISHAY INTERTECHNOLOGY INC
+SEE NOTE 'S' ON BACK
+EXECUTION BY RHCO
+500010902, 001.23701
+OMMISSION
+PERICAN EAGLE OUTFITERS NG
+EXECUTION BY RSSF
+SEC FEE 04-23-02
+1,26
+"CALPINE CORP'***
+EXECUTION BY FBCO
+AS 04012502
+-ANYING
+
+"AMERICAN EAGLE OUTFITERS INC
+NEW
+EXECUTION BY JPHO
+VS 1200 04-26-02
+SYMBOLCUSIP
+CAL
+"FLEX
+HSA.
+"CPN
+"AEOS
+027
+QUANTITY
+-2,700
+5,600
+-1,300
+1,600
+6,200
+1,600
+1,200
+28.02700
+= 1435290
+20.25000
+26.09630
+1.50000
+4.60000
+26.14750
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+75,466.62
+*80,078.82
+26,218.20
+41,737.82
+71,315.00
+7,375.00
+31,392.00
+
+
+10 of 24
+SETTLEMENT TRADE
+DATE
+05/01/02
+04/26/02
+65/02/02 04/29/02**S0LВ"
+05/02/02
+04/29/02
+05/02/02
+*'04/29/02
+05/02/02 04/29/02
+05/02702
+04/29/02
+ö5/03/02
+04/30/02
+EXECUTION BY RHCO
+VS 1750 03-06-02
+COMMISSION
+122,50
+SEC FEE
+3,45
+CH BAD
+WITH RIGHTS TO PURCHASE COMMON
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY COWN
+VS 1400 04-12-02
+COMMISSION
+98.00
+SEC FEE
+2,29
+'ENZON INC
+EXECUTION BY COWN
+SEC S0 09-17-01, 650.21-31-02
+SEC FEB
+JONES APPAREL GROUP INC"
+EXECUTION BY OPCO
+VS 1500 04-29-02
+COMMISSION
+105.00
+TYCO INTERNATIONAL LD.....
+AVG PRICE SHOWN-DETAILS ON REO
+TUAL CONFIRM TO YOUR AGE
+ISOLICIT
+"TALBOTS INC
+EXECUTION BY BUCK
+VS 3200 04-29-02
+COMMISSION
+192,00
+EMMIS COMMUNICATIONS CORP-CLA
+ECUTION BY FB
+3000 01-08-02, 1500 12-26
+1
+COMMISSION
+225,00
+SEC FEE
+3.78
+SYMBOLGUSIP
+AGN
+"BCA
+ENZN
+*SNY
+"INC
+EMMS
+027
+QUANTITY
+-1,750
+-1,400°
+-1,200
+1,500
+2,350
+3,200
+4,500
+65.47880
+
+34.32000
+' 3894730"
+**11.160090
+*34.72340
+27.89110
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+114,446.95
+'75,807.27
+41,167.76
+58,540.95
+43,546.30
+11,321.0
+125,266.17
+
+
+11 of 24
+DATE
+05/03/02
+04/30/02
+OFFICE SERVICING YOUR ACOUNT
+05/03/02 04/30/02"BOUGHT
+05/03/02"
+04/30/02
+05/03/02
+04/30/02
+05/06/02
+15/01/0
+05/06/02
+05/01702
+IMC GLOBAL INC
+SEE NOTE "S' ON BACK
+ESZTION BY 02, 2100 01-22-0
+SE FESSION
+1,38.00
+JONES APPAREL GROUP INC
+ECUTION BY BU
+: 2200 04-30-
+COMMISSION
+132,00
+"MASCO CORP
+VS 100 12-06-01, 3200 12-05-01
+COMMISSION
+SEC FEE
+2278.00
+"TALBOTS INC
+EXECUTION BY LEHM
+/S 1100 04-30-0
+OMMISSION
+77,00
+AMERICAN EAGLE OUTFITERS INC
+EXECUTION BY JPHO
+$ 1000 04-23-02, 1200 04-26
+1400 04-18-
+COMMISSION
+180,00
+SEC FEE
+2.67
+BOISE CASCADE CORP****
+WITH RIGHTS TO PURCHASE COMMON
+STK UNDER CERTAIN CIRCUMSTANCE
+SEE NOTE "S' ON BACK
+VS 9000305-02. 700 03-12.02.
+1100 03-26-02
+SYMBOLCUSP
+IGL
+JNY
+MAS
+"AEOS
+BCC
+027
+QUANTITY
+-5,300
+2,200
+3,300
+12.41110
+39.25210
+27.95390
+1,700
+-3,600*
+*34.48150
+24.59820
+2,700
+33.12220
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+65,390.85
+86,501.62
+91,999.09
+38,024.65
+88,355.85
+89,22324
+
+
+12 or 24
+SETTLEMENT TRADE
+DATE
+05/06/02
+05/01/02
+6506/02 05/01702S0LВ
+05/06/02 05/01/02 SOLD
+20/90/50
+05/01/02
+05/07/02
+05/02/02
+05/07/02
+•05/02/02
+05767702 85/02/02 SOLD
+KENNETH COLE PRODUCTIONS ING
+COMMISSION
+96,00
+"EXPRESSUET HOLDINGS INC'*
+S 4800 04-17-6
+IMMISSIO
+336,00
+GLOBAL ...
+SEE NOTE 'S' ON BACK
+EXECUTION BY MLCO
+VS 400 01-22-02, 1100 10-05-01
+COMMISSION
+SEC FEE
+105.00
+JC PENNEY CO INC
+SEE NOTE 'S' ON BACK
+EXECUTION BY GSCO
+VS 500 04-15-02, 1650 04-08-02
+OMMISSIO
+150,50
+EC FE
+1,39
+AMERICAN EAGLE OUTFITERS INC
+NEW
+EXECUTION BY JPHO
+/S 2600 04-18-0
+SO MISSION
+1190.00
+"CALPINE CORP***
+EXECUTION BY MLOO
+VS 3200 05-02-02
+COMMISSION
+224,00
+IME" CLOBAL INC"
+SEE NOTE 'S' ON BACK
+TS 1300 10-05010
+COMMISSION
+SEC FEE
+-31.00
+SYMBOLGUSIP
+KCP
+JCP
+AEOS
+CPN
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+46,740.28
+QUANTITY
+1,600
+4,800
+29.14330
+• 1451000"
+1,500
+-12.41420...
+*69,297.00
+- 18,500.73
+2,150
+2,600
+3,200%
+1,300*
+21.47590
+24.37820
+10.21600
+•''°3:03180"
+46,006.30
+63,236.41
+*32,930.20
+16,834.83
+
+
+13 or 24
+DATE
+05/07/02
+05/02/02
+05/08/02 05/03/02 SOLD*
+05/08/02
+05/03/02
+05/08/02
+05/03/02
+65/08/02
+05/03/02
+*SOLD
+85788702 05/03702'SO
+05/09/02 05/06/02
+VISHAY INTERTECHNOLOGY ING
+SEE NOTE 'S' ON BACK
+EXECUTION BY MLOO
+VS 1300 11-27-01
+SEC FESSION
+91.00
+57000 0882C
+COMMISSION
+SEC FEE
+-35.00
+JC PENNEY CO INC
+SEE NOTE "S' ON BACK
+EXECUTION BY BUCK
+VS 1050 04-08-02, 150 04-04-02
+COMMISSION
+SEC FEE
+78.00
+"ROYAL CARIBBEAN CRUISES LTD
+SEE NOTE "S' ON BACK
+EXECUTION BY JPHO
+VS 2500 12-18-01
+DOMMISSION
+SEC FEE
+175.00
+SYMBOL TECHNOLOGIES INC
+VG PRICE SHOWN-DETAILS ON RE
+CTUAL CONFIRM TO YOUR AGEN
+UNSOLICITED
+TOMMY HILFIGER" COAP BAB"
+SEC FEE
+114.00
+"ENZON ING"***'
+EXECUTION BY COWN
+VS 650 01-31-02, 650 01-16-02
+SEC FEE
+1,19
+SYMBOLGUSIP
+VSH
+"PSUN"
+RCL
+*SBL
+"TOM
+''ENZN
+027
+QUANTITY
+-1,300
+700
+22.92750
+* 24.73640
+-1,200
+21.40270
+2,500
+0226E EZ.
+-5,100
+1,900
+-1,300
+8.14960
+15:46678
+30.20000
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+29,698.85
+*17,264.95
+25,595.46
+EZ: LOE BS
+41,255.70
+29,256.84
+39,243.81
+
+
+14 of 24
+DATE
+05/09/02
+05/06/02
+BOUGhT"
+05/09/02 05/06/02SÖLD
+FOOT LOCKER INC
+EXECUTION BY BUCK
+00130005-06-02
+78,00
+TOMMY HILFIGER CORP-ORD
+05/10/02 05/07/02 "BOUGHT
+05/10/02
+*05/07/02
+05/10/02
+*05/07/02 BOUGHT
+05/10/02 95/07/02 BOUGHT
+05/10/02 85/07/02"BOUGHT
+85713702*85/08/02
+EXECUTION BY COWN
+VS 2600 05-07-02
+FEDEX CORP****
+ECUTION BY ML
+: 1300 05-07-
+COMMISSION
+91,00
+FOOT LOCKER INC
+EXECUTION BY MLO
+VS 1300 05-07-02
+COMMISSION
+91,00
+"NORFOLK SOUTHERN CORP
+EXECUTION BY MLOO
+VS 1500 05-07-02
+COMMISSION
+105,00
+OBED PARCEL SC
+AVG PRICE SHOWN-DETAILS ON REC
+ACTUAL CONFIRM TO YOUR AGEN
+H.........
+(FRM HCA-HEALTHCARE COMPANY)
+EXECUTION BY OPCO
+
+1,98.00
+SYMBOUCUSP
+TOM
+"CYTC
+"FDX
+NSC
+UPS
+"HEA
+027
+QUANTITY
+1,300
+2,100
+14.90060
+15.22590
+2,600
+* 14.92800
+1,300
+1,300
+1,500
+1,200
+50.84770
+15.18050
+''*20.88240
+''3971080"
+-1,400
+• 45:70000
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+19,463.78
+39,811.42
+38,827.80
+66,208.01
+19,840.65
+31,443.80
+71,736.96
+83,865.07
+
+
+15 of 24
+SETTLEMENT TRADE
+DATE
+05/13/02
+05/08/02
+05/13/02 05/08/02 SOLD*
+05/14/02
+05/09/02
+0571470205/09/02
+05/14/02
+05/09/02
+05714/02
+' 05/09/02
+05/15/02
+*05/10/02
+IC PENNEY CO INC
+SEE NOTE "S' ON BACK
+EXECUTION BY GSCO
+VS 900 04-04-02
+SEC FISSION
+63.00
+*TOMMY HILFIGER CORP ORD
+EXECUTION BY BUCK
+VS 1800 04-10-02
+COMMISSION
+00'801
+"FEDERATED DEPARTMENT STORES
+INC-DEL
+EXECUTION BY BUCK
+VS 2300 05-09-02
+COMMISSION
+138,00
+"JC PENNEY CO ING
+SEE NOTE "S' ON BACK
+EXECUTION BY OPCO
+VS 400 04-04-02
+COMMISSION
+SEC FEE
+22,00
+BOTS I
+EXECUTION BY BUCK
+VS 700 04-29-02
+SO ASSION
+- 12.00
+"TOMMY HILFIGER CORP-ORD
+EXECUTION BY BUCH
+/S 300 04-10-02, 500 01-30-0
+COMMISSION
+SEC FEE
+38.00
+"FOOT LOCKER ING
+EXECUTION BY OPCO
+VS 400 05-10-02
+COMMISSION
+28,00
+SYMBOLCUSIP
+JCP
+"TOM
+*FD
+TLB
+"TOM"
+027
+QUANTITY
+-900
+1,800
+2,300
+400°
+-700
+800
+*400
+22.59440
+'15.36320
+41.54240
+''22.07380
+37.31000
+14.92180
+13.81090
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+20,256.34
+*27,529.92
+95,700.52
+8,786.25
+26,059.21
+11,874.08
+5,567.36
+
+
+16 or 2%
+SETTLEMENT TRADE
+DATE
+05/15/02
+05/10/02
+65/15/02 05/18/02**"SOLD"
+05/16/02 05/13/02 BOUGHT*
+05/1770205/14/02 BOUGHT
+05/17/02
+*05/14/02 BOUGHT
+05/2002
+05/20/02
+05/15/02
+05/21/02
+05/16/02
+JC PENNEY CO INC
+AVG PRICE SHOWN-DETAILS ON REQ
+ACTUAL CONFIRM TO YOUR AGENT
+UNSOLICITED
+SEE NOTE "S" ON BACK
+"YOUNG BROADCASTING INE CLA"
+SEC FEE 01-04-02, 720112-2601
+SEC FEE
+"PACIFIC SUNWEAR OF CALIFORNIA"
+XECUTION BY RSS
+S 600 05-13-02
+"NORFOLK SOUTHERN CORP
+EXECUTION BY FBCO
+VS 2200 05-14-02
+COMMISSION
+154,00
+"YOUNG BROADCASTING INC-CLA
+XECUTION BY INE
+1S MMISS05-140
+48.00
+BEA SYSTEMSING"
+EXECUTION BY TWPT
+SEC FE 1-0901, 70011-07-01
+"BEVERLY ENTERPRISES ING NEW
+EXECUTION BY ADAM
+VS 3100 04-30-01
+COMMISSION
+SEC FEE
+176,00
+"ENZONING"*''
+EXECUTION BY COWN
+VS 1350 01-16-02, 700 01-15-02
+, 1400 03-01-02
+SEC FEE
+3.13
+SYMBOLCUSIP
+JCP
+"VEIVA
+"PSUN*****'''''
+"NSC
+"VBIVA
+"BEAS
+BEV
+'ENZN
+027
+QUANTITY
+-650
+3,200
+600
+2,200
+1,600
+-7,400
+3,100
+3,450
+22.70890
+19.4080(
+'''22.47920
+21.13700
+1.78500
+7.74000
+*'''30.05830
+LEARED THROUGH I
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+14,714.84
+*70,824.46
+11,659.80
+*47,423.24
+33,882.20
+16,483.50
+23.792.27
+103,683.01
+
+
+17 of 24
+SETTLEMENT TRADE
+DATE
+05/22/02
+05/17/02
+05/22/02 05/17/02 "BOUGHT
+05/22/02
+•05/17702
+'''BOUGHT
+05/22/02
+05/17/02
+05/22/02 05/17/02
+'''BOUGHT
+05/22/02
+05/1702
+*BÖUGHT
+05/22/02
+05/1702
+*BÖUGHT
+05/22702
+• 5/17/02"BOUGHT
+ANALOG DEVICES INC
+WITH RIGHTS TO PURCHASE COMMON
+TK UNDER CERTAIN CIRCUMSTANC
+ECUTION BY RHO
+OSAMS 5-17-02
+168,00
+"CALPINE CORP.
+UNSOLICITED
+CENDANT CORP***
+S 6900 05-17-027
+COMMISSION
+483.00
+"CABOT CORP''
+TH RIGHTS TO PURCHASE PREFF
+K UNDER CERTAIN CIRCUMSTAN
+EXECUTION BY VKCO
+VS 4000 05-17-02
+COMMISSION
+280,00
+"COX COMMUNICAONS ING NEW
+CLA
+EXECUTION BY C
+SMISS 17-0.
+182,00
+"DOW CHEMICAL CO
+ES 60005-7-MSCO
+COMMISSION
+42,00
+OIS5017-02
+56.00
+NORFOLK SOUTHERN CORP**
+EURO BEC
+/S 400 05-17-02
+COMMISSION
+28.00
+SYMBOLGUSIP
+ADI
+CPN
+CD
+*CBT
+"DOW
+NSC
+027
+QUANTITY
+2,400
+40.10570
+2,600
+6,900
+4,000
+- 8.83600
+18.83500
+09994.92.
+2,600
+600°
+800*
+400
+•*3386630
+33.91200
+13.65000
+
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+96,436.68
+' 23,129.60
+*130,459.50
+107,321.00
+88,249.38
+20,404.20
+10,991.00
+8,766.44
+
+
+18 of 24
+SETTLEMENT TRADE
+DATE
+05/22/02
+05/17/02
+65/22/02* 05/1702*"S0LВ"
+05/22/02
+NAME CHG
+05/22/02
+NAME CHE
+'SOLD
+05/20/02
+05/24/02
+05/21702
+85/2402
+05/21/02
+65124702"
+'''05/21702"
+'''BOUGAT
+STAGE STORES INC
+NEW
+EXECUTION BY NITE
+VS 1000 04-09-02
+SEC FEE
+1.06
+"TALBOYS' INC
+EXECUTION BY BUCK
+/S 300 04-29-02
+DOMMISSION
+SEC FEE
+39,00
+COOPER INDUSTRIES LTD
+NOCOPE ANDUSTRIES LO
+COOPER INDUSTRIES INC
+WOCOOPERINDUSTRIES LTD
+JONES APPAREL GROUP INC
+66.00
+KOHLS CORP'
+EXECUTION BY FCAP
+VS 100 01-10-02, 200 03-06-02
+COMMISSION
+21.00
+SEC FEE
+POLO RALPH LAUREN CORP CL'A*
+SEE NOTE "S' ON BACK
+SEC FEE
+"CUIKSILVER "INC"
+EXECUTION BY BUCK
+/S 2850 05-21-02
+DOMMISSION
+AS OF 05I21102
+90,00
+1,29
+171.00
+SYMBOL/CUSP
+STGS
+"CBE
+SNY
+*2OK
+027
+QUANTITY
+-1,000
+300
+3,500%
+3,500
+7,700
+*300
+34.90000
+• 3874510"
+41.02970
+76.00180
+2,350
+'''22.65318
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+34,883.94
+
+45,213.67
+22,763.85
+42,44451
+64,747:34
+
+
+19 of 24
+DATE
+05/24/02
+05/21/02
+05/2402 05/21/02 BOUGHT
+0528/02
+05/22/02
+05/28/02 05/22/02
+05/28/02
+05/22/02
+05/28/02 05/22/02 SOLD
+05/28/02 *85/22/02SOLB
+TOMMY HILFIGER CORP-ORD
+EXECUTION BY BUCK
+VS 600 01-30-02, 1900 02-20-02
+M0-90-010051
+SEC MISSION
+1240,00
+"UNIVERSAL HEALTH SERVICES INC
+COMMISSION
+98.00
+COOPER INDUSTRIES LT*
+"CABOT CORP"*'**
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+98,00
+EXECUTION ET BUC
+VS 3200 05-22-02
+COMMISSION
+192,00
+MYKROLS CORP**
+EXECUTION BY MONT
+IS 1400 03-06-02
+OMMISSION
+SEC FEE
+88000
+"POLO RALPH LAUREN CORP:CLA
+SEE NOTE "S' ON BACK
+EXECUTION BY MONT
+VS 800 01-31-02, 200 01-30-02
+COMMISSION
+70,00
+SEC FEE
+.82
+SYMBOLICUSIP
+TOM
+"UHS
+CBE
+"CBT
+"MYK
+027
+QUANTITY
+4,000
+14.57260
+1,400
+1,100
+1,400
+45.19400
+41.42930
+'25.73250
+3,200
+-1,400
+-1,000
+13.32890
+16.00000
+27.15780
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+58,033.64
+''63,384.60"
+45,649.23
+*36,138.50
+42,859.48
+22,286.32
+27,071.38
+
+
+20 or 21
+SETTLEMENT TRADE
+DATE
+05/28/02
+05/22/02
+05/29/02 05/23/02 BOUGHT
+05/29/02 05/23/02
+05/29/02
+n'º052302
+05/29/02
+*05/23/02 BOUGHT
+05/30/02 05/24/02 SOLD
+05/30/02
+05/24/02
+'SOLD"
+85380285/24702BO0SRT
+QUIKSILVER INC
+EXECUTION BY LEHM
+COM 0522-02
+91,00
+ADELPHIA COMMUNICATIONS CORP
+EXECUTION BY SASH
+VS 61800 05-23-02
+FOOT LOCKER INC
+AVG PRICE SHOWN-DETAILS ON REO
+ANSOLCTENFIRM TO YOUR AGENT
+JONES APPAREL GROUPING"
+EXECUTION BY BUCK
+VS 1200 05-23-02
+COMMISSION
+72.00
+"TOMMY HILFIGER "CORP.ORD"
+EXECUTION BY BUCK
+VS 6300 05-23-02
+COMMISSION
+378,00
+ACTVINC..
+SEC FESION
+"IMC GLOBAL INC
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+INSOLICITEL
+SEE NOTE "S' ON BAC
+XECUTION BY JPH
+S 2900 05-24-0
+COMMISSION
+145,00
+SYMBOLGUSIP
+ZOK
+ADLAE
+TOM
+"PSUN"
+027
+QUANTITY
+1,300
+61,800
+2,000
+1,200
+6,300
+:17,300
+1,100
+2,900
+21.54350
+- 2.41000
+14.19650
+'''39.99450
+
+
+*'13.71350
+'15:50500"
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+28,112.55
+148,953.00
+28,533.00
+48,080.40
+96,665.19
+28,312.88
+15,007.39
+'56,724.56
+
+
+21 or 24
+SETTLEMENT TRADE
+DATE
+05/30/02
+05/24/02
+05/30/02
+65/30/02*****
+RECEIVED"
+"RECEIVED"
+05/31/02
+05/28/02
+TOTAL
+DEPOSITS AND WITHDRAWALS
+DATE
+04/29/02
+CHECK
+K #MH72538
+EES FR 4/1/02-6/30/0
+BUCKINGHAM CAPITAL
+TOTAL
+MONEY FUND ACTIVITY
+04/27/02
+..............-.....
+DESCAIPTION
+OPENINGBALANCE
+TIMBERLAND CO-CLA
+EXECUTION BY BUCK
+: 500 05-24-0
+IMMISSIO
+30,00
+AMERICAN "BANK NOTE
+HOLOGRAPHICS INC
+DUE 05/18/02
+EXP 05/18/2002
+PACIFIC SUNWEAR OF CALIFORNIA
+EXECUTION BY JPHO
+VS 1100 05-28-02
+COMMISSION
+55.00
+SYMBOLCUSIP
+TBL
+*ABHH
+' 024377971
+PSUN
+QUANTITY
+500
+3,635
+2,751
+1,100
+39.74630
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+19,918.15
+18.88860
+20,847.46
+$-2,334,459.07
+$2,156.104.20
+22,608.67
+$-22,608.67
+SYMBOUCUSIP
+QUANTITY
+3,535,003.34
+027
+
+
+22 0124
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+05/02/02
+05/06/02
+'BOUGHT
+05/20/02
+65/21/02 DIVIDEND
+05/24/02
+''''DIVIDEND
+05/24702 REINVEST
+05/24/02
+"REINVEST'
+05/24/02 SOLD
+05/31/02
+TOTAL
+DIVIDENDS
+05001/02 CENEY CO ING
+REC 04/10/02 PAY 05/01/02
+REC 04/01/02 PAY 05/01/02
+SYMBOUCUSIP
+GIDXX
+*GTOXX
+MONTHLY DIVIDEND
+DONETS PRE ORTFOLIO
+MONTHLY DIVIDEND
+DOMEST PRIME MA PORTE
+MONTHLY DIVIDEND REINVESTED
+DOES PREM PORTFOLIO
+MONTHLY DIVIDEND REINVESTED
+"DOMEST PRIME MA PORTFOLIO
+CLOSINGBALANCER
+"GTOXX
+SACCUSI
+QUANTITY
+2,100
+QUANTI
+100.00
+200,000
+400,000
+3,453.75
+710.85
+-500,000
+3,239,167.94
+RATE (S)
+0.1250
+027
+1.0000
+0000*
+1.0000
+LEARED THROUGH I
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+400,000.00
+200,000.00
+400,000.00
+3,453.75
+710.85
+1.0000
+3.453.75
+710.85
+••••••••••••••••••••••••••••:
+$-604,164.60
+500,000.00
+$904,164.60
+262.50
+
+
+23 or 2%
+DIVIDENDS (continued)
+
+MASCO CORP
+REC 04/05/02 PAY 05/07/02
+REC 01/29/02 PAY 05/10/02
+05/15/02
+"NOVA CHEMICALS CORP
+REC 04/30/02 PAY 05/15/02
+FOREIGN TAX WITHHELD
+SYMBOUGUSIP
+MAS
+''''CR
+TOTAL
+INTEREST
+DATE
+05/21/02
+INT CR
+TOTAL
+SYMBOUCUSIP
+MAY 02
+Trades Executed Pending Settlement
+SATE MENT
+06/03/02
+05/29/02
+06/03/02
+*05/29/02
+06/03/02
+#05/29/02
+06/04/02
+.. 5/30/02
+06/04/02
+05/30/02
+IMC GLOBAL INC
+DUKSILVER INC
+TALBOTS INC
+"COSTCO WHOLESALE CORP NEW
+PACIFIC SUNWEAR OF CALIFORNIA
+QUANTITY
+RATE (S)
+3,300
+0.1350
+3,100 0.2100
+4,500
+HM
+0.0641
+QUANTITY
+RATE (%)
+SYMBOLGUSP
+IGL
+*ZOK
+ILB
+COS
+PSUN
+027
+43.28
+$-43.28
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+445.50
+651.00
+288.55
+$1,708.80
+902.97
+$902.97
+QUANTITY
+1,000.00
+,200.00
+200.00
+-900.00
+600.00
+13.6242
+22.2079
+37.4225
+39.2800
+18.1533
+26,748.48
+10.936.98
+CRECIT AMOUNT
+13,538.78
+44,818.64
+31,368.05
+
+
+24 or 24
+Trades Executed Pending Settlement
+(continued)
+BATEMENT TREE
+06/04/02
+05/30/02
+
+05/31/02
+06/05/02
+05/31/02
+BOUGH
+06/05/02
+05/31/02
+06/05/02
+05/31/02
+06/05/02
+05/31/02
+TOTAL
+TIMBERLAND CO-CLA
+ADELPHIA COMMUNICATIONS CORP
+CLA
+CALPINE CORP
+MILLENNIUM CHEMICALS INC
+OLIN CORP NEW"
+WITH RIGHTS TO PURCHASE PREFRD
+YOUNG BROADCASTING INC-CLA
+The above trades do not appear in any other section of this statement
+STOP
+*** Endof Statement**
+SYMBOLCUSP
+TBL
+ADLAE
+CPN
+MCH
+OLN
+BIVA
+027
+QUANTITY
+1,700.00
+26,300.00
+2,800.00
+2.400.00
+4,100.00
+3.200.00
+38.9000
+7822
+9.3800
+4.015
+.....
+19.7674
+19.9423
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD April 27,2002
+THROUGH
+May 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+April 26, 2002
+66,247.00
+26,447.00
+33,819.00
+81,348.34
+63.990.36
+$309.537.16
+19,767.24
+$109,492.71
+
+
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28, 2002
+What's In This Statement
+Financial Summary.........................
+Your Portfolio Holdings
+Transaction Detail ..............................
+FundA..............................
+Trades Not Yet Settle...................
+3
+8
+22
+24
+ImllmInklumll
+INSTITUTIONAL INTERESTS
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENNAN
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+13,248,135
+843,946
+3,535,003
+517.627.084
+•••••••••
+18,082,026
+-454,942
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account
+Market Value of Your Portfolio
+$4,378,949
+$4,561,906
+Cash & Equivalent
+Equities
+$13,248,135
+$13,520,120
+Current market value
+SP This satement stori for atanal por oes recorde Set reverse das a a doctant intomation.
+
+
+2 of 25
+Bear, Steams Securities Corp
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 of 25
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Money Fund
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+51.031.509.02
+2,680,526.61
+1,104,606.35
+5,664.68
+35.00
+$3,790,832.64
+-2,873,754.03
+-1,104,606.35
+-35.00
+..................•••..
+-3,978,395.38
+-187,562.74
+...
+5843.946.28
+Income Summary
+Dividends
+Credit Balance Int.
+Foreign Tax Withheld
+THIS PERIOD
+9,223.85
+1,047.18
+.....
+$10,271.03
+....
+0.00
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+1,028,273.38
+3,235.64
+$1,031,509.02
+CLOSING
+839,663.46
+4,282.82
+$843,946.28
+........
+027
+YEAR TO DATE
+24,192.23
+4,282.82
+.....
+$28,475.05
+.......
+-81.03
+4,378,949
+13,248,135
+S17.627.084
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent-
+25%
+Equities
+75%
+Unshaded portions denole debi balance and'or short
+
+
+4 of 25
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+THE TREASURERS FUND INC
+DOMESTIC PRIME MAM PORTFOLO.
+THE TREASURERS FUNDING
+DOMESTIC PRIME MIM PORTFOLIO
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+ABERCROMBIE & FITCH CO-CL A
+ACTV INC
+AMERICAN AGLE OUTFITTERS ING
+NEW
+-.-.-...............
+ADELPHIA COMMUNICATIONS CORP
+CL A
+ALLERGAN INC
+_... ..
+BEA SYSTEMS INC
+BEVERLY ENTERPRISES INC NEW
+..... . . . .
+CR BARD INC
+......
+BOISE CASCADE CORP
+.HH../•••••••••••••••••••••/•••••••••••••
+ENDANT COR
+.......--.
+CELESTICA INC
+SUBORD VTG SHS
+.. . . .
+SYMBOLCUSIP
+GTDXX
+GTDXX
+QUANTITY
+3,530,171.02
+4,832.32
+1.0000
+1.0000
+SYMBOUCUSIP
+ANF
+IATV
+AEOS
+ADLAE
+AGN
+........
+BEAS
+BEV
+....
+BCR
+BCC
+CD
+aLS
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+.. . .
+CASH
+......
+HASH
+''CAH*
+CASH
+QUANTITY
+3,200
+17,300
+......
+6,600
+8,354
+1,750
+........
+10,500
+.....
+44,800
+... . .
+3,100
+2,700
+11,450
+4,200
+LEARED THROUGH IT:
+HOLLY OWNED SUBSIDIAR'
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocktyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIO March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAPAYER NUMBER
+March 28,2002
+MARKET
+VALUE
+843,946
+__....
+3,530,171
+4,832
+$4,378,949
+30.3600
+1.2500
+25.7300
+6.0000
+65.7300
+10.1600
+.........
+8.7000
+.. ..
+55.0800
+33.1400
+••..
+18.4000
+28.3500
+ESTIMATED
+ANNUAL INCOME
+51,894
+1.470
+......
+71 1.4694
+99619$
+MARKET
+VALLE
+97,152
+21,625
+169,818
+ESTIMATED
+ANNUAL INCOME
+50,124
+115,028
+......
+106,680
+...
+389,760
+... ..
+170,748
+... .
+89,478
+210,680
+119,070
+630
+CURRENT
+YELD (N)
+0.5477
+2,604
+1.5251
+1,620
+1.8105
+ananassanınııasaaanasaaaanann
+027
+
+
+5 of 25
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+COSTCO WHOLESALE CORP-NEW
+.. . .
+CITIZENS COMMUNICATIONS CO
+CSX CORP
+CANDIES INC
+... .
+KENNETH COLE PRODUCTIONS ING
+CL A
+.......
+CISCO SYSTEMS INC
+CONTINENTAL AIRLINES INC-CL B
+.....•
+COOPER INDUSTRIES INC
+DMC STRATEX NETWORKS INC
+DOW CHEMICAL CO
+CsCo
+CAL
+CBE
+STXN
+DOW
+FIX
+.......
+EXPRESSJET HOLDINGS INC
+XJT
+.. . . .
+EMMIS COMMUNICATIONS CORP-CLA
+EMMS
+ENZON INC
+.....
+ENZN
+.........
+EXPEDITORS INTERNATIONAL OF
+EXPD
+WASHINGTON INC
+....
+FOX ENTERTAINMENT GROUP INC
+CLA
+FOX
+FEDEX CORP
+FDX
+FOOT LOCKER IN
+FEDERATED DEPARTMENT STORES
+FD
+INC-DEL
+.....
+FLEXTRONICS INTERNATIONAL
+LTD
+FLEX
+....
+SYMBOLCUSIP
+COST
+CZN
+CSX
+CAND
+KCP
+CASH
+.....
+CASH
+•***---
+CASH
+....
+CASH
+CASH
+CASH
+CASH
+.......
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+6,550
+37,200
+2,700
+346
+5,900
+10,200
+12,150
+3,500
+11,450
+8,800
+19,150
+4,800
+......
+13,550
+1-....
+5,950
+......
+3,000
+14,600
+2,600
+2,650
+3,900
+11,200
+39.9200
+9.7500
+36.6400
+... .
+3.2500
+7.000
+13.9100
+27.1800
+3.300
+4.3000
+31.2000
+18.2100
+14.3300
+30.1500
+3.77
+57.4600
+24.0600
+54.3400
+5.600
+39.9100
+13.4600
+MARKE
+VALLI
+261,476
+362,700
+98,928
+1,125
+159,300
+141,882
+330,237
+151,550
+49,235
+274,560
+348,722
+68,784
+408,533
+218,782
+172,380
+351,276
+141,284
+41,340
+155,649
+150,752
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28,2002
+ANNUAL NOME
+CURRENT
+YIELD (S
+.. . .
+1,080
+1.0917
+....
+.. . .
+4,900
+11,792
+3.2333
+4.2949
+600
+0.3481
+
+
+6 of 25
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+IONA TECHNOLOGIES PLC
+SPONSORED ADR
+HONEYWELL INTL INC
+-MANY ING
+HCA ING
+(FRM HOA-HEALTHCARE COMPANY)
+JONES APPAREL
+GROUP INC
+KOHLS CORP
+LIBERTY MEDIA CORP
+SER A NEW
+LIZ CLAIBORNE INC
+MILLENNIUM CHEMICALS INC
+MYKROLIS CORP
+MASCO CORP
+NOVA CHEMICALS CORP
+NORTHWEST AIRLINES CORP
+NORFOLK SOUTHERN CORP
+POLO RALPH LAUREN CORP-CLA
+PACIFIC SUNDEAR OF CALIFORNIA
+JC PENNEY COINC
+QUIKSILVER INC
+REMEC INC
+SYMBCLCUSIP
+IONA
+HON
+.....
+IMNY
+HCA
+IGL
+JNY
+KSS
+LIZ
+MCH
+MYK
+MAS
+NCX
+NWAC
+NSC
+RL
+OCR
+PSUN
+ZOK
+REMO
+OFFICE SERVICING YOUR ACOUNT
+CASH
+CASH
+.......
+CASH
+CASH
+CASH
+CASH
+CASH**
+CASH
+CASH
+CASH
+CASH
+...
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+14,800
+4,150
+56,050
+12,400
+17,200
+5,200
+3,500
+34,400
+10,400
+6.200
+10,700
+.....
+3,300
+4,500
+........
+2,500
+4,350
+8,907
+6,300
+5,450
+5,300
+13,300
+4,350
+12.0500
+36.9200
+5.0500
+•••••••••••
+47.9000
+2.
+5800
+38.
+72.7500
+10.6100
+13.
+5.
+28.0000
+23.0800
+19.3800
+21.6000
+28.4700
+27.7900
+25000
+21.4600
+24.1400
+8.0000
+MARKET
+VALLE
+178,340
+153,218
+283,053
+593,960
+216,376
+201,656
+254,625
+364,984
+330.096
+84.320
+162,212
+92,400
+103,860
+•••••••••••
+48,450
+93,960
+253,582
+175,077
+138,975
+113,738
+321,062
+34,800
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28, 2002
+ESTIMATEC
+ANNUAL INCOME
+CURRENT
+YELD IN
+3,113 2.0317
+992
+1,376
+....
+0.1670
+0.6359
+2,340
+3,348
+1,782
+729
+1,044
+567
+0.7089
+3.970
+1.9286
+0.7019
+1.1111
+0.3239
+2,650***2.3299
+
+
+7 of 25
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+ROYAL CARIBBEAN CRUISES LTD
+COR IN
+ECHERS USA IN
+STAGE STORES ING
+NEW
+SANIMINA-SCI CORP
+SINCLAIR BROADCAST GROUP INC
+CL A
+SYMBOL TECHNOLOGIES INC
+TYCO INTERNATIONAL LTD*
+.. ...
+TIBCO SOFTWARE INC
+TALBOTS INC
+TIMBERLAND CO-CLA
+... . .
+TOMMY HILFIGER CORP-ORD
+SYMBOLCUSIP
+RCL
+SCRI
+SKX
+STGS
+SANM
+SBGI
+SBL
+TYC
+TIBX
+TLB
+TBL
+TOM
+TONT
+UPS
+UNITED RETAIL GROUP INC
+ISHAY INTERTECHNOLOGY IN
+YOUNG BROADCASTING ING-CLA
+Total Equities& Options
+TOTAL EQUITIES
+URGI
+VSH
+YBIVA
+OFFICE SERVICING YOUR ACOUNT
+CASH
+.....
+CASH
+.....
+CASH
+CASH
+CASH
+CASHI*
+CASH
+CASH
+CASH
+CASH
+CASH
+.........
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+13,850
+•.........
+10,800
+9,000
+14,300
+11,900
+21,600
+20,500
+4,900
+17,400
+4,600
+3,900
+......
+19,700
+...
+11,500
+4,150
+16,700
+7,500
+14,400
+22.9000
+17.5500
+23.0000
+32.1600
+10.5700
+12.7400
+8.4100
+19.9000
+8.8000
+34.6400
+1.360
+....
+16.1200
+10.0000
+...
+60.4100
+9.0000
+19.8800
+22.2100
+MARKE
+317,165
+189,540
+207,000
+459,888
+125,783
+275,184
+172,405
+97,510
+153,120
+159,344
+161,304
+......
+317,564
+-...
+115,000
+50,70
+150,300
+149,100
+319,824
+$13,248,135
+$13,248,135
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28, 2002
+ANNUAL INCOME
+7,202
+CURRENT
+YIELD (%
+2.2707
+.....
+410
+245
+1,472
+3,154
+0.2378
+251
+0.9238
+1.2581
+$53,650
+$53,650
+
+
+8 of 25
+OFFICE SERVICING YOUR ACOUNT
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT TRADE
+04/01/02 03/26/02
+04/01/02
+03/26/02
+04/01/02
+03/26/02
+AMERICAN EAGLE OUTFITTERS INC
+NEW
+EXECUTION BY RSSF
+VS 1400 12-14-01
+SEC FEE
+"BUALINGTON NORTHEAN SANTA FE
+CORP
+SEE NOTE 'S' ON BACK
+EXECUTION BY FECO
+COMMS 032-02
+119,00
+BOISE CASCADE CORP"
+TH RIGHTS TO PURCHASE COMM
+K UNDER CERTAIN CIRCUMSTAN
+SEE NOTE 'S' ON BACK
+EXECUTION BY JPHO
+IS 1100 03-26-02
+OMMISSION
+77,00
+$105,615
+$17,627,084
+SYMBOLGUSIP
+AEOS
+QUANTITY
+-1,400
+25.12900
+BNI
+"BCC
+1,700
+29.98880
+1,100
+- 35.40000
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28,2002
+35,165.07
+51,71496
+39,032.00
+
+
+9 of 25
+DATE
+04/01/02
+03/26/02
+04101702 03/26/02 BOUGHT
+04/01/02
+*03/26/02"
+"BÖUGHT
+84/01702
+03/26/02 BOUGHT
+04101/02 03/26/02
+ö4/01/02"
+03726/02
+
+03/26/02
+'SOLD"
+CHILDRENS PLACE RETAIL STORES
+EXECUTION BY SLKG
+VS 600 01-03-02, 900 01-14-02,
+310012-31-01
+1.72
+WITH RIGHTS TO PURCHASE PREFRO
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY FBCO
+VS 1000 03-26-02
+COMMISSION
+70,00
+"CONTINENTAL AIRLINES INC-CLB
+EXECUTION BY BUCH
+78.00
+"FLEXTRONICS INTERNATIONAL
+XECUTION BY FLT
+S 1400 03-26-0
+MASCO CORP*****
+WITH RIGHTS TO PURCHASE PREFRD
+TK UNDER CERTAIN CIRCUMSTANO
+ECUTION BY RYA
+VS 1000 12-06-01
+NOSINIO
+SEC FEE
+70.00
+NOVA CHEMICALS CORP
+ECUTION BY ML
+, 2200 05-04-
+COMMISSION
+SEC FEB
+1751.00
+"SANIMINA SCICORP
+EXECUTION BY FLIT
+VS 1400 03-26-02
+SYMBOLCUSP
+PLCE
+*ESX
+'CAL
+"FLEX
+MAS
+NEX
+SANM
+027
+QUANTITY
+-3,600
+31.78000
+1,000
+*'''37.19550
+1,300
+1,400
+1000*
+27.27050
+• 17.77000
+- 27:21000
+2,200
+1,400
+23.72040
+11.97000
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28, 2002
+114,391.28
+'37,280.50
+35,544.65
+24,893.00
+27:124:59
+52,015.09
+16,773.00
+V5S7
+
+
+10 of 25
+DATE
+04/02/02
+03/27102
+04/02/02 03/27/02 SOLD
+04/02/02
+
+04/02/02*
+'''03/27/02
+04/03/02
+/*03/28/02
+04/03/02
+
+'''BOUGHT
+ADELPHIA COMMUNICATIONS CORP
+CLA
+ES 180001-1602, 1700 09-29-0
+SEC FEE
+S OF 03/27/02
+.98
+"EASTMAN CHEMICAL CO
+T8 300 01-31-02. 600 01-2402
+COMMISSION
+77,00
+SEC FEE
+.81
+AS OF 03/27/02
+MASCO CORP'*
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY MLOC
+VS 1000 12-06-01
+-70.00
+"TEXTRON ING"
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY GSCO
+VS 1400 11-15-01
+COMMISSION
+SEC FEE
+1,08.00
+CELESTICA INC**
+SUBORD VTG SHS
+EXECUTION BY MON
+210,00
+"CiSCO SYSTEMS INC
+XECUTION BY JPH
+S 13600 03-28-0
+SYMBOL/CUSP
+ADLAE
+EMN
+MAS
+TXT
+CS00
+027
+QUANTITY
+-3,500
+18.50000
+-1,100
+-1,000
+48.96410
+'27.22900
+1,400
+3,000
+13,800
+50.31600
+36.56400
+*'16.96740
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28, 2002
+64,734.02
+53,767.70
+27, 143.59
+70,328.34
+109,917.00
+230,771.64
+
+
+11 of 25
+DATE
+04/03/02
+03/28/02
+04/03/02 03/28/02 SOLD
+04/03/02
+'''03/28/02*BÖUGHT
+04/03/02 03/28/02 "BOUGHT
+04/04/02
+''º24/01/02'SOLD*
+04/04/02284/01/02S0LB
+04/05/02
+04/02/02
+BEGUN BEARS NOB
+0S MMS 03-28-02
+84,00
+"EASTMAN CHEMICAL CO
+3700
+FLEXTRONICS INTERNATIONAL'
+ECUTION BY JPI
+: 1000 03-28-1
+"TRIGUINT SEMICONDUCTOR INC
+XECUTION BY VKC
+S 1500 03-28-0
+ADELPHIA COMMUNICATIONS CORP
+0 0 0 2 0 0 2200
+COMS5127-01
+SEC FEE
+105,00
+EXECUTION BY BUCK
+/S 3900 01-15-02
+DOMMISSION
+SEC FEE
+388.00
+ADELPHIA COMMUNICATIONS CORP
+SEC FEE
+SYMBOLCUSIP
+CAL
+"FLEX
+"TONT
+ADLAE"
+ADLAE*
+027
+QUANTITY
+1,200
+28.33010
+1,100
+•48.78250
+1,000
+* 18.53440
+1,500
+*12.18800
+3,500
+13.45980
+• 3,900
+* 29.61830"•
+3,600
+12.67700
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28,2002
+34,095.12
+53,567.94
+18,549.40
+18,297.00
+46,987.88
+**•*•*••••****195.258.89
+45,620.82
+
+
+12 of 25
+DATE
+04/05/02
+04/02/02
+04/05/02 04/02/02 SOLD
+04/05/02
+04/02/02
+84/05/02
+04/02/02
+04/05/02
+04/02/02
+BURLINGTON NORTHERN SANTA FE
+CORP
+BEECUTON BY COCK
+:1000 03-06-
+MMISSI
+SEC FEE
+188.00
+BOISE CASCADE CORP
+WITH RIGHTS TO PURCHASE COMMON
+STK UNDER CERTAIN CIRCUMSTANCE
+SEE NOTE 'S' ON BACK
+EXECUTION BY JPHQ
+63.00
+EX CORP
+WITH RIGHTS TO PURCHASE PREFRO
+STE UTION BE FEN CRCUMSTANCE
+S0 0 0 02 0 02302
+"CUMMINS INC
+EXECUTION BY JPHO
+VS 700 03-12-02, 1800 03-05-02
+COMMISSION
+175,00
+SEC FEE
+EXECUTION BY DEMATIONS CORE CL A
+1,16
+AS OF 04/02/02
+SYMBOLGUSP
+BNI
+*BCC
+CUM
+"EMMS
+027
+QUANTITY
+-1,000
+-900
+1,100
+29.15000
+35.02070
+37.09580
+2,500
+46.32360
+400
+'27.37000
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28, 2002
+29,064.12
+31,439.68
+40,712.15
+115,615.51
+38,301.84
+
+
+13 of 25
+DATE
+04/05/02
+04/02/02
+04105/02 04/02/02 SOLD"
+04/05/02
+14/02/0
+*SOLD
+04705/02
+004/02702
+84/05/02 04/02/02SOLD
+04/05/02 84/02/02"S0LБ
+04/05/02 04/02/02 SOLD
+HONEYWELL INTL INC
+SEE NOTE 'S' ON BACK
+EXECUTION BY JPHQ
+VS 700 01-03-02
+-80.000
+"MASCO CORP
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY MSCO
+VS 1300 12-06-01
+COMMISSION
+SEC FEE
+1.06.00
+NOVA CHEMICALS CORP
+EXECUTION BY ADAN
+VS 1300 05-04-01, 600 04-17-0
+OMMISSION
+1.38.00
+NORFOLK SOUTHERN CORP"
+EXECUTION BY FBCO
+VS 1100 10-11-01
+COMMISSION
+77,00
+PPG INDUSTRIES INC
+EXECUTION BY ADAM
+VS 500 01-31-02
+COMMISSION
+35.00
+SEC FEE
+.82
+"SINCLAIR" BADABCAST CASUP'INE"
+SEC FEE
+1.42
+"YOUNG BROADCASTING INC-CLA"
+EXECUTION BY SSH
+VS 1600 01-08-02, 1000 01-04-0
+SEC FEE
+1.89
+SYMBOLGUSIP
+HON
+MAS
+NSC
+"PPG
+027
+QUANTITY
+-700
+1,300
+-1,900
+1,700
+500
+3,600*
+2,600
+37.90300
+'26 89040"
+23.7076฿
+22.90000
+• 54.00670
+13.07100
+24.14800
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28,2002
+26,467.30
+34,850.46
+8096B tr
+1246092.
+26,952.53
+*47,039.78
+62,767.91
+
+
+14 of 25
+SETTLEMENT TRADE
+DATE
+04/08/02
+04/03/02
+64/08/02 04/03/02**"BOUGAT
+04/08/02
+•'04/03/02
+04/09 02 04/04/02
+04/09/02
+04/04/02
+*SOLD
+8469702"
+'"°4/04702"BÖÜGHT
+04/17/02 04/08/02
+• BOUGHT
+ALLERGAN INC
+EXECUTION BY COWN
+VS 1000 03-06-02
+COMMISSION
+SEC FEE
+
+T-MANYING
+EXECUTION BY RSSF
+VS 7000 04-03-02
+COMMISSION
+350,00
+AS OF 04/03/02
+VITRIA TECHNOLOGY INC
+EXECUTION BY FLITT
+VS 1500 02-23-01, 10700 01-11-
+01, 5450 03-23-01
+1.24
+"ADELPHIA COMMUNICATIONS CORP"
+CLA
+EXECUTION BY SBSH
+VS 1900 11-20-01
+.65
+LIBERTY MEDIA CORP
+SER A NEW
+EXECUTION BY JPHO
+IS 1200 09-14-00, 2900 09-18-
+), 2700 09-28-0
+OMMISSIO
+SEC FEE
+279,00
+"JEPENNEY CO INC*
+SEE NOTE "S' ON BACK
+147,00
+"CELESTICA INC**
+SUBORD VTG SHS
+EXECUTION BY MONT
+US MSS008-02
+84.00
+SYMBOLCUSP
+AGN
+*IMNY
+VITR
+"ADLAE
+"CiS
+027
+QUANTITY
+-1,000
+7,000
+:15,650
+-1,900
+6,800
+2,100°
+1,200
+62.97600
+•'4:55000"
+2.62620
+• 11.22000
+11.75000
+19.4795ö
+
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28, 2002
+62,889.10
+**'*32,215.00
+*41,083.79
+21,302.35
+79,406.59
+"41,068.95
+*36,373.32
+
+
+15 of 25
+ELEMENT THE
+04/11/02
+DATE
+04/08/02
+04/11702 84/08/02 BOUGHT
+04/17/02 04/08/02
+20/1L/t0
+/'04/08/02
+Аналов.
+04/11/02
+'''34/08/02"BÖUGHT
+047127020409/02 BOUGHT
+6471502"
+04/10/02
+
+'BOUGHT
+8477502**84718/02*B008H1
+IONA TECHNOLOGIES PLE
+SPONSORED ADR
+51400-06-02
+LIZ CLAIBORNE INC
+210.00
+PACIFIC SUNWEAR OF CALIFORNIA*
+15 50 0 0 025
+JC PENNEY CO INC
+SEE NOTE "S" ON BACK
+EXECUTION BY FLOR
+VS 2700 04-08-02
+COMMISSION
+189,00
+"TIBCO SOFTWARE INC
+IS 1300 04-08-02
+"STAGE STORES INC
+NEW
+EXECUTION BY CLYN
+SAMS MMSS2-09-02
+50.00
+JONES APPAREL GROUP INC
+XECUTION BY MON
+S 2500 04-10-0
+COMMISSION
+175,00
+53400 01-1002
+EXECUTION BY MLOO
+VS 4000 04-10-02
+COMMISSION
+280,00
+SYMBOLCUSIP
+IONA
+"SUN
+*TIBX
+*STGS
+SNY
+'''P8M
+027
+QUANTITY
+1,400
+3,000
+1,500
+2,700%
+1,300
+2,000
+14.11000
+29.32090
+- 24.98250
+'20.35130
+10.29170
+''28.74600
+2,500
+*3,400
+'4,000***
+37.09570
+10:59000"
+•*15:57168
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28,2002
+19,769.00
+88,187.70
+*37,488.75
+55,152.51
+13.394.27
+'57,557.00
+92,929.25
+'36,024.80
+
+
+16 of 25
+SETTLEMENT TRADE
+DATE
+04/16/02
+04/11/02
+64/16/02 04/11702**SOLB"
+04/17/02
+
+''BOUGHT
+04717702"
+*04/12/02 BÖUGHT
+04/17/02 04/12/02: BOUGHT
+04/17702
+4/12/0
+*SOLD
+04/17/02
+04/12/02
+REMEC INC
+EXECUTION BY CLYN
+VS 900 04-18-01
+COMMISSION
+22,50
+SEC FEE
+.26
+SYMBOL TECHNOLOGIES INC"
+S0 0 2, 201
+1.10.00
+"CR BARD INC
+TH RIGHTS TO PURCHASE COMMO
+K UNDER CERTAIN CIRCUMSTAN
+EXECUTION BY ADAM
+COMMISSION 12-02
+217.00
+"CONTINENTAL AIRLINES INC-CLE"
+EXECUTION BY SSH
+VS 1500 04-12-02
+COMMISSION
+105.00
+"DOW CHEMICAL CO
+EXECUTION BY NEED
+COMMS 12-02
+294,00
+ENZON INC
+EXECUTION BY COWN
+SEC FE 09.01, 760 091701
+FOOT LOCKER INC
+ECUTION BY BU
+1150 10-11-01, 3900 01-03-
+2, 900 01-04-02, 2250 01-15-0:
+DOMMISSION
+492,00
+SEC FEE
+4.00
+SYMBOLGUSIP
+REMC
+1AS.
+"BCR
+"CAL"
+DOW
+"ENZN
+027
+QUANTITY
+-900
+4,000
+3,700%
+9.33650
+•2.25000
+57.04770
+1,500
+4,200
+-800
+8,200
+• 29.25160
+**32:97380
+40.08000
+16.18790
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28,2002
+8,365.09
+36,743.88
+'177,079.87
+43,997.40
+138,798.96
+2,048.0
+132,229.78
+
+
+17 of 25
+SETTLEMENT TRADE
+DATE
+04/17/02
+04/12/02
+04/1702 84/12/02 BOUGHT
+04/17/02 04/12/02
+• BOUGHT
+04/18/02
+04/15/02
+*SOLD
+04/18/02
+04715/02
+"SOLD"
+04/18/02"
+04/15/02
+04/19/02 04716/02
+'SOLD
+8477970284716/02'BO0BRT
+I-MANY INC
+EXECUTION BY RSSF
+5 2500 04-12-0
+OMMISSIO
+125.00
+JONES APPAREL "GROUP INC"
+EXECUTION BY DAIN
+VS 600 04-12-02
+COMMISSION
+42,00
+TIBCO SOFTWARE INC**
+ECUTION BY TW
+$ 3800 04-12-
+CONTINENTAL AIRLINES INC-OLB
+EXECUTION BY SBSH
+IS 1500 04-12-02, 1100 03-28-1
+COMMISSION
+182,00
+SEC FEE
+2.27
+FOOT LOCKER INC
+SEC FEE
+32.00
+JC PENNEY CO INC
+SEE NOTE "S'
+EXECUTION Y BUCACK
+OMISSION 15-02
+60.00
+"ADELPHIA COMMUNICATIONS CORP
+XECUTION BY MON
+/S 1700 11-20-01, 600 11-16-0
+SEC FEE
+COMS A 16-02
+343,00
+SYMBOL/GUSP
+IMNY
+*TIBX
+"ADLAE"
+"EIX"
+027
+QUANTITY
+2,500
+600
+*3,800
+2,600
+4.50000
+37.01170
+- 9.71070
+
+-700
+1,000
+-2,300
+4,900
+16.15030
+21.59010
+- 7.15000
+*16:85950
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28, 2002
+11,390.00
+22,264.02
+36,915.66
+4,892.11
+984241.
+21,665.10
+16,429.50
+82989.55
+
+
+18 of 25
+DATE
+04/19/02
+04/16/02
+04/19/02 84/18/02 SOLD
+04/19/02
+''*04/16/02***BOUGHT
+04719/02 04/18/02"BOUGHT
+04/19/02
+''*34716/02"BÖUGHT
+FEDEX CORP
+182,00
+FOOT LOCKER INC
+$5.00
+TON TECHNOLOGIES..
+SPONSORED ADR
+EXECUTION BY COWI
+/S 3500 04-16-02
+EXECUTION BY RSS
+'S 3500 04-16-0
+COMMISSION
+JC PENNEY CO INC
+175.00
+04/19/02
+*04/16/02"
+04/19/02
+04/16/02
+04/19/02
+*04/16/02
+*SOLD
+"TICO SOFTWARE INC
+5510001-1802
+"TENET HEALTHCARE CORP
+ES 4900 12 2-9. 350 1220-99
+COMMISSION
+367,50
+SEC FEE
+11,08
+"TRIGUINT SEMICONDUCTOR INC
+EXECUTION BY RSSF
+VS 1500 04-16-02
+SYMBOLGUSIP
+FDX
+IONA
+IMNY
+JCP
+*TIX
+TONT
+027
+QUANTITY
+2,600
+900
+54.96750
+• 15.77840
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28,2002
+143,112.50
+14,131.13
+*3,500
+14.99330.....
+*3.500
+2,000
+1,000
+5,250
+5.05000
+21.78480
+10.44200
+70.10520
+52,491.55
+"17,865.00
+43,704.60
+10,457.00
+367,658.72
+1,500
+11.89800
+17,862.00"
+
+
+19 of 25
+DATE
+04/22/02
+04/17702
+04/22/02 04/17/02 BOUGHT
+04/22/02
+*04/17/02
+04/23/02
+04/18/02
+BÖUGHT
+04/23/02
+04/18/02
+'BOUGHT
+04723/0284/17/02BOUGHT
+04/23/02
+'' 84/18/02
+# BOUGHT
+04/23/02
+04/18/02
+'SOLD"
+IONA TECHNOLOGIES PLE
+SPONSORED ADR
+ES 120001Y 402, 1400 01-23-0
+SO PESSON
+1,04.00
+JONES APPAREL GROUP INC
+1552100 01-1-02
+COMMISSION
+126.00
+MILLENNIUM CHEMICALS INC
+EXECUTION BY MLOO
+VS 6200 04-17-02
+COMMISSION
+434,00
+"AMERICAN EAGLE OUTFITERS INC
+ECUTION BE PRO
+VS 4000 04-18-02
+"CONTINENTAL AILINES INC-CLIB
+EXECUTION BY SBSH
+0-81-20 0092 S
+COMMISSION
+182,00
+"EXPRESSUET HOLDINGS T
+EXECUTION BY SBSH
+AS OF 04/17/02
+I-MANYNN.......
+VS 3900 0 8 028
+COMMISSION
+195,00
+"JC PENNEY CO ING
+SEE NOTE "S' ON BACK
+EXECUTION BY FCAP
+VS 700 04-16-02
+COMMISSION
+SEC FEE
+-19.00
+SYMBOL/GUSP
+IONA
+JNY
+MCH
+AEOS
+CAL
+'MINY
+027
+QUANTITY
+-2,600
+13.27700
+2,100
+6,200
+4,000
+2,600
+'4,800***
+3,900
+700
+38.61650
+14.68840
+25.76500
+27.81200
+* 16.00000******
+* 4.88330
+21075700"
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28,2002
+34,426.16
+81,235.65
+91,517.08
+103,075.00
+72,508.20
+' 76815:00
+19,25487
+15,165.44
+
+
+20 of 25
+SETTLEMENT TRADE
+DATE
+04/23/02
+04/18/02
+64/24/02 04/19/02'"SOLD
+04/24/02
+' 84/19/02
+''''SOLD
+04724/02 04/19/02
+04/25/02
+104/22/02
+04725/02
+04/22/02
+SYMBOL TECHNOLOGIES INC
+EXECUTION BY FLCR
+OSMMISSION2-01, 205075.30-01
+COMMISSION
+SEC FEE
+.83
+"FOOT LOCKER" INC
+EXECUTION BY BUCK
+S00 80501 20 92 3002
+SEC FEE
+"IC PENNEY CO INC
+SEE NOTE "S' ON BACK
+EXECUTION BY BUCK
+OOMISON 16-02. 50004-15-02
+SEC FEE
+1.08.00
+"SYMBOL TECHNOLOGIES INC
+EXECUTION BY SBSH
+VS 2400 07-30-01, 1100 10-04-0
+1, 2500 03-21-02, 100 10-03-0
+COMMISSION
+SEC FEE
+1375.00
+"BRUINGTON NORTHERN SANAFE
+SEE NOTE "S' ON BACK
+XECUTION BY UBS
+S 700 03-06-02, 1000 03-12-0
+1700 03-26-02
+OMMISSION
+238,00
+VITH RIGHTS TO PURCHASE PREFRO
+TK UNDER CERTAIN CIRCUMSTANC
+EXECUTION BY UBSW
+270002-28-
+IMMISSI
+SEC FEE
+189,00
+2,82
+SYMBOLGUSIP
+SBL
+BNI
+"SX"
+027
+QUANTITY
+-2,500
+-1,200*
+-1,800
+10.99990
+20.90240
+6,100
+
+3,400
+28.29210
+-2,700
+34.61320
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28,2002
+27,308.92
+19,448.41
+'37,500.18
+58,181.50
+*95,937.24
+93,248.82
+
+
+21 of 25
+SETTLEMENT TRADE
+DATE
+04/25/02
+04/22/02
+64/25 02 04/22/02**SOLB"
+04/2502
+''04/22/02 SOLD*
+04/26/02 04/23/02 "BOUGHT
+04/26/02 04/2302 BOUGHT
+0426/02 04/2302 BOUGHT
+04726/02 04/23/02 "SOLD*
+CISCO SYSTEMS INC
+EXECUTION BY FBCO
+S 3400 03-28-0
+OMMISSION
+SEC FEE
+1132.00
+NORFOLK SOUTHERN CORP*
+EXECUTION BY UBSW
+COMMS 1011-01, 15010024-01
+SEC FEE
+1,18
+"SINCLAIR BROADCAST GROUP INC
+EXECUTION BY SUKO
+30-0-1000250
+COMMISSION
+120.00
+"AMERICAN EAGLE OUTFITERS INC
+NEW
+EXECUTION BY ASSF
+VS 2600 04-23-02
+"COSTCO WHOLESALE COAP NEW**
+EXECUTION BY MONT
+VS 1250 04-23-02
+"DOW CHEMICAL****
+EXECUTION BY DRKW
+: 4600 04-23-1
+IMMISSI
+322,00
+"PPG INDUSTRIES INC
+EXECUTION BY DRKW
+VS 1000 01-31-02
+COMMISSION
+SEC FEE
+159.00
+SYMBOLCUSIP
+CSCO
+"NSC
+"AEOS
+*•**••••••*•••••••••••••••'*BOW
+"PPG
+027
+QUANTITY
+-3,400
+1,700
+0otz
+14.83150
+'22:87640"
+12.53580
+2,600
+*'26.72670
+1,250
+09/490t.
+'4,600
+0*****••***32.06530********•
+1,000
+*''52.71510
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28, 2002
+50,240.58
+''38,754:70
+29,950.01
+69,504.42
+* 10,824.38
+*147,837.38**
+52,628.51
+
+
+22 or 25
+SATE EMENT TATE
+DATE
+04/26/02
+04/23/02 BOUGHT
+TOTAL
+TALBOTS ING
+EXECUTION BY BUCK
+DO AS 00-23-02
+MONEY FUND ACTIVITY
+DATE
+MODAY
+03/29/02
+04/03/02
+04/05/02
+BOUGHI
+04/09/02
+04/11/02
+04/15/02
+04/18/02
+04/22/02
+04/23/02
+04/23/02
+DIVIDEND
+DESCAIPTION
+OPENINGBALANCE
+BONEST PREM PORTOO
+DOES PRE PORTFOLI
+DOMEST PRICE PORTFOLIO
+04/23/02
+DIVIDEND
+MONTHLY DIVIDEND
+DOES ARE BALO
+MONTHLY DIVIDEND
+Bear, Stearns & Co. Inc.
+SYMBOLCUSIP
+TLB
+QUANTITY
+4,600
+32.89380
+276,00
+SYMBOUCUSIP
+GIDXX
+GTЫXX
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28, 2002
+151,602.48
+$-2,873,754.03
+$2.680,526.61
+*700,000.00
+100,000.00
+GTЫXX
+GTOXX
+"GTOXX
+QUANTITY
+3,530,396.99
+700,000
+100,000
+200,000
+250,000
+200,000
+50,000
+100,000
+300.000
+1.0000
+1.0000
+1.0000
+1.0000*
+1.0000
+0000*
+1.0000
+1.0000
+300,000.00
+200,000.00
+250,000.00
+200,000.00
+50,000.00
+100,000.00
+3,778.40
+827.95
+027
+
+
+23 or 25
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+04/23/02
+REINVEST
+MONTHLY DIVIDEND REINVESTED
+04/23/02 REINVEST
+MONTHLY DIVIDEND REINVESTED
+64/2502 30LB
+04/26/02
+TOTAL
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+04/01/02
+BURLINGTON NORTHERN SANTA FE
+CORP
+REC 03/11/02 PAY 04/01/02
+
+''EASTMAN CHEMICAL 80*
+REC 03/15/02 PAY 04/01/02
+04/01/02
+"M GLOBAL INC.
+REC 03/15/02 PAY 03/31/02
+04/01/02
+ROYAL CARIBBEAN CRUISES LTD
+REC 03/18/02 PAY 03/29/02
+04/01/02
+''"TEXTRON INC
+REC 03/15/02 PAY 04/01/02
+04/05/02
+"SYMBOL TECHNOLÖGIES INC
+REC 03/11/02 PAY 04/05/02
+04/15/02
+BOISE CASCADE CORP
+REC 04/01/02 PAY 04/15/02
+TOTAL
+SYMBOLCUSIP
+BNI
+IGL
+BCC
+SYMBOUGUSIP
+GIDXX
+QUANTITY
+1,700
+2,200*
+17,200
+13,850
+1,400
+30,600
+3,600
+QUANTITY
+3,778.40
+827.95
+*300,000
+3,535,003.34
+RATE (5)
+0.1200
+0.4400
+'0.0200
+0.1300
+0.3250
+•0.0100
+0.1500
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28,2002
+3,778.40
+827.95
+''300,000.00
+$-1,104,606.35
+$1,104,606.35
+CAEDIT AMOUNT
+204.00
+968.00
+*344.00
+1,800.50
+455.00
+*306.00
+540.00
+$4,617.50
+
+
+24 of 25
+INTEREST
+DATE
+04/22/02
+INT CR
+TOTAL
+SYMBOUCUSIP
+APR 02
+MISCELLANEOUS
+DATE
+MODAY
+04/05/02
+4/10/02** JOURNAL
+OURNA
+TOTAL
+03/02 CLR CHG
+••••••••••/••••••••
+REVERSE 0302MUTUAL FUND CARES
+Trades Executed Pending Settlement
+SETTLEMENT
+TRADE
+DATE
+DATE
+04/29/02
+04/24/02
+
+04/24/02
+04/29/02
+04/24/02
+04/29/02
+.. . .
+04/24/02
+FOLL
+04/29/02
+04/24/02
+04/30/02 04/25/02 SOLD
+04/30/02
+04/25/02
+DESCAPTION
+CALPINE CORP
+CELESTICA INC
+SUBORD VTG SHS
+CONTINENTAL AIRLINES INC-CLB
+FLEXTRONICS INTERNATIONAL
+VISHAY INTERTECHNOLOGY INC
+"AMERICAN EAGLE OUTFITTERS INC
+NEW
+CALPINE CORP
+QUANTITY
+RATE (SI
+35.00
+$-35.00
+SIMBOLICUSP
+CPN
+CLS
+CAL
+"FLEX
+AEOS
+CPN
+027
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29, 2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28,2002
+1,047.18
+$1,047.18
+CRECIT AMOUNT
+35.00
+$35.00
+QUANTITY
+14,500.00
+2,100.00
+-2,700.00
+....
+,600.
+-1,300.00
+-1,600.00*
+6,200.00
+12.1346
+29.1314
+28.0270
+14.3529
+20.2500
+- 26.0963
+11.5000
+176,981.70
+61.012.09
+75,466.62
+30,078.82
+26,218.20
+41,737.82
+71,315.00
+
+
+25 of 25
+Bear, Stearns & Co. Inc.
+Trades Executed Pending Settlement
+(continued)
+BETLEMENT TREE
+0430102 04/25102
+05101/02
+•04/26/02
+
+04/26/02
+TOTAL
+The above trades do not appear in any other section of this statement.
+I-MANY INC
+AMERICAN EAGLE OUTFITERS INC
+NEW
+LLERGAN IN
+SIMBOLCUSP
+IMNY
+AEOS
+AGN
+QUANTITY
+,600.00
+1,200.00
+-1,750.00
+4.6000
+26.1475
+65.4788
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD March 29,2002
+THROUGH
+April 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+March 28,2002
+7,375.00
+1,392.0
+$287,063.70
+114.446.95
+$398,960.50
+STOP
+****** End of Statement******
+027
+VS57
+
+
+LEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+What's In This Statement
+Financial Summary .............................
+Your Portfolio Holdings
+Transaction Detail ..............................
+FundA..............................
+Trades Not Yet Settle................
+3
+4
+8
+24
+26
+INSTITUTIONAL INTERESTS
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENNAN
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+Market Value of Your Portfolio
+$4,561,906
+$3,325,224
+13,520,120
+1,031,509
+3,530,397
+$18,082,026
+17,055,947
+1,026,079
+Cash & Equivalent
+Equities
+$13,520,120
+| $13,730,723
+Current market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account
+SP This satement stori for retanal for you recorde Set revere das a a doctant intration.
+
+
+2 of 28
+Bear, Steams Securities Corp
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+03/29/02;22:30 001|
+
+
+3 or 28
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Amount Credited
+Securities Bought
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+5707.761.76
+4,117,158.62
+552,934.28
+4,911.29
+....
+$4.675,004.19
+... .
+-2,888,322.65
+-1,462,934.28
+54.351.256.33
+323,747.26
+.......
+51,031,509.02
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+705,457.53
+2,304.23
+$707,761.76
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+Foreign Tax Withheld
+THIS PERIOD
+6,914.16
+931.41
+37.845.57.
+0.00
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+CLOSING
+1,028.273.38
+3,235.64
+$1,031,509.02
+YEAR TO DATE
+14,968.38
+3,235.64
+.......
+$18.204.02
+-81.03
+4,561,906
+13,520,120
+18.082,02
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent
+26%
+Equities
+74%
+Unshaded portions denole debi balance and'or short
+
+
+4 of 28
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+THE TREASURERS FUNDING
+DOMESTIC PRIME MAM PORTFOLIO.
+THE TREASURERS FUNDING
+DOMESTIC PRIME MIM PORTFOLIO
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+ABERCROMBIE & FITCH CO-CLA
+ACTV INC
+AMERICAN EAGLE OUTFITTERS INC
+NEW
+___....
+ADELPHIA COMMUNICATIONS CORP
+CLA
+ALLERGAN INC
+.......
+BURLINGTON NORTHERN SANTA FE
+CORP
+...
+BEA SYSTEMS ING
+.. . .
+BEVERLY ENTERPRISES ING NEW
+BOISE CASCADE CORP
+........ .
+HILDRENS PLACE RETAIL STORI
+INC
+SYMBOLCUSIP
+GTOXX
+GTDXX
+QUANTITY
+3.526,392.62
+4,004.37
+1.0000
+1.0000
+SYMBOUCUSIP
+ANF
+IATV
+AEOS
+ADLAC
+AGN
+BNI
+BEAS
+BEV
+BCC
+PLCE
+CASH
+CASH
+CASH
+ASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+3,200
+17,300
+1,400
+23,154
+2,750
+..........
+2,700
+10,500
+44,800
+2,500
+.....
+3,600
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+MARKET
+VALUE
+1,031,509
+.. ..
+3,526,393
+4,004
+$4,561,906
+ESTIMATED
+ANNUAL INCOME
+50,427
+1.4300
+57
+......
+1.4236
+$50,484
+30.8000
+1.5090
+..........
+24.7700
+14.9000
+64.6500
+.............
+30.1800
+13.7100
+....
+7.2000
+36.2400
+.....
+33.0000
+MARKET
+VALUE
+98,560
+26,106
+34,678
+344,995
+177,788
+81.486
+143,955
+.. ...
+322,560
+....
+0,60
+*****..
+18,80
+ESTIMATED
+ANNUAL INCOME
+CURRENT
+YIELD (%)
+990
+1,296
+1,500
+0.5568
+5905
+1.6556
+027
+
+
+5 or 28
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+CENDANT CORP
+COSTCO WHOLESALE CORP NEW
+CITIZENS COMMUNICATIONS CO
+CANDIES INC
+.........
+NNETH COLE PRODUCTIONS IN
+CLA
+CONTINENTAL AIRLINES INC-CL B
+COOPER INDUSTRIES INC
+CUMMINS INC
+MC STRATEX NETWORKS INC
+......•...
+EDISON INTERNATIONAL
+....
+EASTMAN CHEMICAL CO
+....
+EMMIS COMMUNICATIONS CORP-CL A
+ENZON INC
+........
+EXPEDITORS INTERNATIONAL OF
+WASHINGTON INC
+FOOTSTAR INC
+FOX ENTERTAINMENT GROUP INC
+POO LOCKE NC
+FEDERATED DEPARTMENT STORES
+INC-DEL
+......
+FLEXTRONICS INTERNATIONAL
+LTD
+......
+SIMBOUCUSIP
+CD
+COST
+•......
+CZN
+*...
+CSX
+CAND
+KCP
+CAL
+CBE
+CUM
+STXN
+FIX
+EMN
+EMMS
+ENZN
+EXPD
+FTS
+FOX
+FD
+FLEX
+CASH
+.....
+CASH
+•***---
+CASH
+CASH
+MRGN
+CASH
+CASH
+...
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+''CASH"
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+11,450
+...
+5,300
+37,200
+...*.--..
+5,500
+346
+5,900
+8,150
+3,500
+2,500
+11,450
+14,250
+2,200
+.. . ..
+14,950
+....
+6,750
+.........
+3,000
+3,900
+14,600
+13,650
+3,900
+8,800
+19.2000
+....
+39.8200
+10.7500
+.....
+38.1100
+2.2000
+20.0700
+28.3200
+41.9500
+47.2300
+5.4400
+16.7500
+48.7900
+26.7400
+44.2900
+61.0000
+30.4900
+23.6500
+16.1800
+40.8500
+18.2500
+MARKET
+VALUE
+219,840
+211,046
+399,900
+209,605
+761
+118,413
+230,808
+146,825
+118.075
+62,288
+238,688
+107,338
+399,763
+298,958
+183,000
+118,911
+345,290
+220,857
+59,31
+160,600
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+ANNUAL INCOME
+CURRENT
+YELD IN
+... . .
+....
+2,200
+1.0498
+.....
+4,900
+3,000
+3,872
+600
+3.3373
+2.5408
+3.6073
+0.3279
+
+
+6 of 28
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+IONA TECHNOLOGIES PLC
+SPONSORED ADR
+HONEYWELL INTL INC
+-MANY ING
+HCA ING
+(FRM HOA-HEALTHCARE COMPANY)
+IMC GLOBAL INC
+KOHLS CORP
+LIBERTY MEDIA CORP
+SER A NEW
+LIZ CLAIBORNE INC
+nananas
+MYKROLIS CORP
+MASCO CORP
+NOVA CHEMICALS CORP
+.. ...
+NORTHWEST AIRLINES CORP
+VORFOLK SOUTHERN CORI
+•••••••••••••••••••••••••••••••••••••
+POLO RALPH LAUREN CORP-CL A
+OMNICARE INC
+PACIFIC SUNWEAR OF CALIFORNIA
+INC
+PPG INDUSTRIES INC
+QUIKSILVER INC
+EMEC IN(
+ROYAL CARIBBEAN CRUISES LTD
+.......
+SICOR INC
+SYMBCLCUSIP
+IONA
+HON
+.....
+IMNY
+HCA
+GL
+KSS
+LIZ
+MYK
+MAS
+NCX
+•......
+NWAC
+NSC
+...
+RL
+OCR
+PSUN
+PPG
+ZOK
+REMO
+RCL
+SCRI
+CASH
+CASH
+.......
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+...
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+12,500
+4,850
+39,150
+... ...
+12,400
+17,200
+3,500
+41,200
+7,400
+......•*...
+10,700
+6.600
+8,600
+....
+2,500
+7,150
+8,907
+6,300
+3,950
+1,500
+13,300
+5,250
+13,850
+10,800
+16.9300
+38.2700
+4.9600
+4.080
+14.7500
+71.
+.1500
+12.6400
+28.3600
+15.2900
+27.4500
+25.0100
+19.0700
+23.9400
+29.1800
+25.8900
+24.6000
+54.9100
+21.8800
+9.2500
+22.5500
+17.0800
+MARKET
+VALUE
+211,625
+185,610
+194,184
+546,592
+253,700
+249.025
+520,768
+209,864
+163.603
+181,170
+215,086
+.....
+47,675
+171,171
+.......•..
+259,906
+•....
+163,107
+97,170
+82,365
+291,004
+48,563
+312,318
+184,464
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+STIMATE
+NNUAL INCON
+CURRENT
+YELD IN
+3.638 1.9600
+1.9600
+992
+1,376
+1,665
+3,564
+1,365
+1,716
+567
+2,520
+7,202
+......
+0.1815
+0.5424
+0.7934
+1.9672
+0.6346
+1.0025
+0.3476
+3.0596
+2.3060
+
+
+7 of 28
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+SKECHERS USA INC
+CLA
+STAGE STORES INC
+NEW
+SANMINA-SCI CORP
+SINCLAIR BROADCAST GROUP INC
+SYMBOL TECHNOLOGIES INC
+TYCO INTERNATIONAL LTD
+TIBCO SOFTWARE INC
+TENET HEALTHCARE CORP
+......
+TEXTRON INC
+TIMBERLAND CO-CLA
+TOMMY HILFIGER CORP-ORD
+.... . .
+TRIQUINT SEMICONDUCTOR INO
+UNITED PARCEL SVC INC
+SYMBOLICUSIP
+SKX
+STGS
+SANM
+SBGI
+SBL
+TYC
+TIBX
+THC
+TXT
+TBI
+TOM
+TON
+UPS
+UNITED RETAIL GROUP INC
+VITRIA TECHNOLOGY INC
+COM
+VISHAY INTERTECHNOLOGY INC
+YOUNG BROADCASTING INC-CL A
+Total Equities& Options
+TOTAL EQUITIES
+URGI
+VITR
+VSH
+YBTVA
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+............
+CASH
+CASH
+CASH
+...
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+GLANTITY
+9,000
+2,300
+0,500
+27,600
+33,100
+----
+4,900
+7,900
+5,250
+1,400
+3,900
+....
+15,700
+.......
+8,500
+4,150
+16,700
+5,65
+7,500
+17,000
+18.9100
+26.6000
+11.7500
+13.5500
+11.2400
+32.3200
+11.7600
+67.0200
+51.1000
+42.2500
+14.3500
+
+60.8000
+6.9600
+3.9500
+20.3400
+24.9900
+MARKET
+VALUE
+170,190
+327,180
+372,044
+158,368
+92,904
+351,855
+71,540
+164,775
+25,29
+102,085
+252,320
+116,232
+31,818
+152,550
+424,830
+$13,520,120
+$13,520,120
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+CURRENT
+YELD IN
+662
+245
+1,820
+0.1779
+0.1547
+2.5440
+3,154
+1.2500
+$48,844
+$48,844
+
+
+8 of 28
+OFFICE SERVICING YOUR ACOUNT
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT TRADE
+02/25/02 02/20/02
+02/25/02 02/20/02 SOLD
+02/28/02 02/21/02 SOLD
+ECUTION BY BUC
+$ 1900 02-20-
+COMMISSION
+114,00
+AS OF 02/20/02
+"VORK INTERNATIONAL CORP NEW
+052601820. 101-140
+COMMISSION
+SEC FEE
+1.16,00
+AS OF 02/20102
+"BEA SYSTEMS INC
+EXECUTION BY INET
+SMS 50123-02, 90071009-01
+COMMISSION
+SEC FEE
+$99,328
+$18,082,026
+SYMBOLCUSIP
+TOM
+VRK
+QUANTITY
+1,900
+11.52490
+3,600
+'3208780
+BEAS
+2,600
+'''15.15900
+027
+LEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+22.026.31
+115,28334
+- 39,319.80
+
+
+9 of 28
+SETTLEMENT TRADE
+DATE
+02/26/02
+02/21/02
+62/26/02 02/2102*"SOLD
+KENNETH COLE PRODUCTIONS ING
+COMMISSION
+252,00
+INTERSIL COAPORATION CLA''
+20/9220
+
+02727/02
+02722/02
+02/27/02
+02/22/02
+02727/02
+02722/02 SOLD"
+"SOLECTRON CORP
+EXECUTION BY MONT
+VS 4300 01-04-02, 2600 01-03-0
+30M/S 12-26-01
+SEC FEB
+1518,00
+ANDRY GROUP*
+NEW
+EXECUTION BY INET
+VS 2000 01-31-02
+COMMISSION
+SEC FEE
+1,00.00
+"CAPSTONE TURBINE CORP
+EXECUTION BY SBSH
+VS 8600 01-08-02, 2200 01-10-0
+353F00 01-24-02
+.63
+"MC CORP NEW**
+SEE NOTE "S' ON BACK
+EXECUTION BY DBAB
+VS 300 11-13-01, 600 11-16-01
+COMMISSION
+63.00
+SEC FEE
+SYMBOLGUSIP
+KCP
+SLA
+"ABAX
+ISdo
+"FMC
+027
+QUANTITY
+4,200
+1,700
+*8,600
+2,000
+18.65120
+12772000*
+9.10830
+'33.06710
+-14,600
+*900
+2.86070
+36.05000
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+78,602.04
+''47,108.29
+77,799.20
+66,058.20
+41,750.59
+32,36651
+
+
+10 of 28
+SETTLEMENT TRADE
+DATE
+02/27/02
+02/22/02
+Bear, Stearns & Co. Inc.
+02/27/02 02/22/02 SOLD"
+20/L220
+02/22/02
+20/22/20
+02/22/02
+02/28/02
+02/25/02
+03761702"
+'''82728702*S0LB
+03/01/02 02/26/02
+PRAXAIR INC
+SEE NOTE *S' ON BACK
+EXECUTION BY MLOO
+VS 2000 01-17-02
+SEC FISSION
+1.70.00
+"SOLUTIA INC
+e 20 010 02 210001070
+COMMISSION
+SEC FEE
+1528,00
+SOLECTRON CORP
+EXECUTION BY SBSH
+VS 4550 12-26-01, 7000 12-21-0
+1, 10600 12-21-01
+SEC PASSION
+2820.00
+VITESSE SEMICONDUCTOR CORP
+EXECUTION BY JPHO
+VS 1250 07-19-01, 1800 07-17-4
+1, 1700 01-23-02, 2500 10-03-0
+SEC FEE
+.81
+TX COMPANIES INC NEW
+Vs 1300 022802
+OMMISSION
+90,00
+TELEMENS PLACE RETAIL STORES
+
+SEC FEE
+"COSTCO WHOLESALE CORP NEW
+EXECUTION BY INET
+VS 1100 02-26-02
+COMMISSION
+33,00
+SYMBOLCUSP
+PX
+SLA
+VISS
+"PLČE"
+027
+QUANTITY
+-2,000
+8,800
+22,150
+7,250
+57.34320
+
+8.57260
+7.38330
+1,500
+800"
+1,100
+34.33000
+*34-85800
+• 43.81000
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+114,529.67
+65,520.24
+188,536.24
+53,513.12
+'51,600.00
+*27,230.59
+48,239.00
+
+
+11 of 28
+SETTLEMENT TRADE
+DATE
+03/01/02
+02/26/02
+63/01/02 02/26/02**SOLB"
+03/01/02
+*02/26/02
+ö3/04/02
+02/27/02
+03/04/02 02/27/02 BOUGHT
+03/04/02
+02/27/02
+'''SOLD"
+03765/02 02/28/02 SOLD
+KENNETH COLE PRODUCTIONS ING
+CLA
+EXECUTION BY BUCK
+VS 1700 02-26-02
+COMMISSION
+102,00
+"MILLENNIUM "CHEMICALS INE"
+EXECUTION BY SIMM
+: 7900 10-03-
+IMMISSIO
+SEC FEE
+1553.00
+VIACOM INC-CL B
+EXECUTION BY JPHO
+VS 800 12-18-01, 1200 11-07-01
+COMMISSION
+140,00
+SEC FEE
+1.40
+"AMERICAN EAGLE OUTFITERS INC
+NEW
+EXECUTION BY INET
+VS 1500 02-27-02
+COMMISSION
+45.00
+"ONA TECHNOLOGIES PL
+SPONSORED ADR
+EXECUTION BY INET
+0S MISS0227-02
+78,00
+"HCA ING"
+EXECUTION BY REGARE COMPAN
+VS 2600 10-24-01
+COMMISSION
+SEC FEE
+1.52.00
+"AVNETINC
+EXECUTION BY COWN
+VS 4500 01-03-02
+COMMISSION
+SEC FEE
+1,35.00
+SYMBOLGUSIP
+KCP
+"VIAB
+AEOS
+'ONA
+"HCA
+027
+QUANTIT
+1,700
+7,900
+2,000
+1,500
+2,500
+2,600
+4,500
+18.69210
+46.51570
+24.75000
+*11:76180
+41:72800
+''26 39950"
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+31,893.57
+
+''95,621.74
+9120...
+'37,185.00
+106,864.19
+T18,465.96
+
+
+12 of 28
+SETTLEMENT TRADE
+DATE
+03/05/02
+02/28/02
+03/05/02 02/28/02 SOLD"
+03/05/02
+02728/02
+'BOUGHT
+03/05/02
+02/28/02
+03/05/02
+02/28/02
+03/05/02
+*02/28/02 BOUGHT"
+03/06/02
+/'03/01/02
+83786702 03781702'BOUBRT
+CSX CORP
+WITH RIGHTS TO PURCHASE PREFRD
+TK UNDER CERTAIN CIRCUMSTANC
+ECUTION BY FC
+0S 4200 0228-02
+294.00
+DIM STRATEX NETWORKS INC
+0 1 0 00 02801
+TONA TECHNOLOGIES PLO
+SPONSORED ADR
+EXECUTION BY SLKC
+VS 2500 02-28-02
+"NORFOLK SOUTHERN CORP
+EXECUTION BY FCAP
+VS 2600 02-28-02
+COMMISSION
+182,00
+PEED PARCEL SONG
+5500275-020
+COMMISSION
+108.50
+NEW
+EXECUTION BY INET
+COMMISSION
+SMISSION -02, 12009207-02
+SEC FEE
+1.09
+"03188 WHOLESALE CORP NEW
+EXECUTION BY RSSF
+VS 500 03-01-02
+SYMBOLCUSIP
+CSX
+ONA
+NSC
+*TIBX
+"UPS
+"08ST
+027
+QUANTITY
+4,200
+2,000
+2,500%
+2,600
+5,100
+1,550
+- 1,900*
+38.98850
+' 461630"
+
+24.02300
+10.76470
+59.05320
+'*338400
+500
+•''39.72000"
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+164,060.70
+*9,217.46
+*35,988.75
+62,656.80
+54,914.97
+91,655.96
+72,476.51
+19,875.00
+
+
+13 of 28
+SETTLEMENT TRADE
+DATE
+03/06/02
+03/01/02
+03766/02 03701702 BOUGHT
+63/6602*03761702"S0LВ"
+03/07/02
+03/04/02
+03/07/02
+*03/04/02 BOUGHT
+03/07/02"
+*03/04/02
+03/07/02
+' 03/04/02BOUGHT
+ENZON INC
+EXECUTION BY MON
+VS 1400 03-01-02
+SCORN....
+ECUTION BY SB:
+4600 03-01-
+.....
+EXECUTION BY BUCK
+VS 300 01-04-02, 1500 01-03-02
+COMMISSION
+108,00
+SEC FEE
+1.10
+IN LORENS PLACE FREIAL STORES
+EXECUTION BY JPHQ
+SEC FE 01-29-02, 50001-03-02
+SEC FEE
+COOPER INDUSTRI
+COMMS 03-04-02
+161,00
+"FOX ENTERTAINMENT GROUP INC
+ECUTION BY DRK
+224.00
+"MYKROLS CORP"
+XECUTION BY SBSI
+COMMISSION 01-0
+469,00
+SYMBOLICUSIP
+ENZN
+"PLCE
+"CBE
+"FOX
+MYK
+027
+QUANTITY
+1,400
+*4,600
+:7,800
+200
+2,300
+3.200
+6,700
+43.36670
+- 1606250"
+40.71510***
+34.62080
+37.83720
+22.90920
+1312780"
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+60,728.38
+*73.502.50
+*73,183.08
+41,529.33
+87,201.56
+*73,548.44
+88,440.26
+
+
+14 of 28
+03/07/02
+
+03/07/02 03/04/02"BOUGHT
+20140/50
+03/04/02
+03/07702"
+''*03/04/02
+03/07/02
+03/04/02
+03708702"
+ROYAL CARIBBEAN CRUISES LTD
+SEE NOTE 'S' ON BACK
+EELUTON BY ROT, 2200 1221-0
+SE FESION
+1228.00
+TIBCO SOFTWARE INC
+JOMMISSION
+45.00
+CURE PARCEL SVENG
+EXECUTION BY MSOC
+182,00
+"UNIVERSAL HEALTH SERVICES INC
+EXECUTION BY OPCO
+VS 400 10-17-01, 5100 01-19-01
+COMMISSION
+385,00
+SEC FEE
+SECUTON BY ORNAL CORP NEW
+/S 1250 11-14-01, 800 11-13-0
+O002301
+255,50
+SEC FEE
+1,95
+"AMERICAN EAGLE OUTFITTERS INC
+NEW
+EXECUTION BY JPHO
+VS 1400 01-30-02, 100 01-29-02
+SEC FEE
+.57
+SYMBOLCUSIP
+RCL
+TIBX
+UPS
+"UHS
+VRK
+027
+QUANTITY
+4,200
+20.24990
+1,500
+2,600
+5,500
+*T1.35900"
+59.50000
+' 37.64470
+-3,650
+35.47910
+1,500
+25.21780
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+84,739.30
+17,098.50
+154,897.00
+206.642.74
+129,226.27
+37,877:33
+
+
+15 of 28
+
+03/08/02 03/05/02BOÜGHT
+20/80/E0
+03/05/02
+201B0/E0
+03/05/02
+03/05/02
+BOUGH
+20/80/80
+*03/05/02
+''''SOLD*
+03/08/02 03/05/02
+'BOUGHT
+BOISE CASCADE CORP
+WITH RIGHTS TO PURCHASE COMMON
+SEE NOTE SON BA CARCUMSTANCE
+IMMISSION
+CALPINE CORP*'
+0 64000-0502
+OMMISSION
+126,00
+384.00
+27.00
+COOPER INDUSTRIES INC...
+STE UNDER ENTAN CHARANCE
+EXECUTION BY JPHO
+84,00
+"CUMMINS INC
+126,00
+"FEDERATED DEPARTMENT STORES
+,35.00
+"FLEXTRONICS INTERNATIONAL"
+LTD
+EXECUTION BY TWPT
+VS 4100 03-05-02
+SYMBOLCUSP
+BCC
+*CPN
+COST
+'CBE
+"CUM
+"FLEX
+027
+QUANTITY
+1,800
+37.37970
+6,400
+900°
+1,200
+1,800
+500
+4,100
+=*9.17450
+38.94960
+40.00000
+14.6284
+42.94000
+' 1795330"
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+67,424.46
+59,115.80
+35,096.64
+48,099.00
+80,472.12
+21,419.67
+73,623.53
+
+
+16 of 28
+SETLEMENT TATE
+
+03/08/02 03/05/02 SOLD
+20180/50
+03/05/02
+03/05/02
+03708/02
+03/05/02
+03705/02
+
+03/6602
+*SOLD
+IONA TECHNOLOGIES PLE
+SPONSORED ADR
+ES 170003-0502
+MASCO CORP
+NITH RIGHTS TO PURCHASE PREFRI
+STK UNDER CERTAIN CIRCUMSTANCI
+SE CUTO 12Y O1. 1100 01160
+"REMEC INC
+189.00
+.37
+SANMINA SCI CORI
+EXECUTION BY TWPT
+VS 4100 03-05-02
+AS OF 03/05/02
+*X COMPANIES ING NEW
+EXECUTION BY FCAP
+VS 1500 02-25-02
+OMMISSIO
+EC. FE
+805.00
+"TALBOTS INC"
+EXECUTION BY DAN
+VS 900 01-16-02
+COMMISSION
+SEC FEE
+-53.00
+'ALLERGAN INC
+EXECUTION BY COWN
+S 2750 03-06-0
+OMMISSION
+192,50
+SYMBOL/GUSP
+IONA
+MAS
+SANM
+NOV.
+027
+QUANTIT
+1,700
+2,700
+15.94000
+28.51520
+3,000
+4,100
+1,500
+900°
+OSLZ
+8.05400
+12.84830
+36.98660
+'39.47230
+
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+27,113.00
+76,785.88
+24,146.63
+52,693.03
+55,359.06
+35,446.53
+"179,482.75
+
+
+17 of 28
+
+03/11702 03/06/02 "BOUGHT"
+03/06/02
+
+*03/06/02
+03/11002 03/06/02
+'''BOUGHT
+13/06/0
+03/06/02
+83/11702 03/06/02B008A1
+BURLINGION NORTHERN SANTA FE
+CORP
+EE NOTE 'S' ON BAC
+ECUTION BY FB
+0S 1700 03.06-02
+119.00
+'CSX CORP
+SIK UNDER GERAN CHANTANCE
+EXECUTION BY FBCO
+VS 300 03-06-02
+COMMISSION
+21.00
+EXPEDITORS INTERNATIONAL OF
+WASHINGTON INC
+EXECUTION BY FECO
+VS 1500 03-06-02
+"FLEXTRONICS INTERNATIONAL
+EXECUTION BY TWPT
+IS 1600 03-06-02
+KOHLS CORP...
+EXECUTION BY BUCK
+COMMISSIONG-02
+18.00
+"MYKROLIS CORP"
+EXECUTION BY MONT
+0S MIS 03-0-02
+280,00
+NORFOLK SOUTHERN CORP"
+EXECUTION BY FBCO
+VS 2600 02-28-02, 2800 12-18-0
+1, 1000 11-13-01, 650 10-11-01
+COMMISSION
+493,50
+SEC FEE
+2,77
+"SANMINA SCICORP
+EXECUTION BY TWPT
+VS 1600 03-06-02
+SYMBOLGUSIP
+BNI
+*ESX
+*EXPD"
+"FLEX
+KISS
+MYK
+NSC
+'SANM
+027
+QUANTITY
+1,700
+300
+1,500
+1,600
+''300*
+4,000
+7,050
+31.06000
+*'''40.18470*
+59.77200
+• 18.84000
+'13.44120
+26.15410
+1,600
+• 13:48000
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+52,936.00
+12,085.41
+*89,673.00
+*30,159.00
+19,823.70
+4,059.8
+183,875.14
+'''24583.00
+
+
+18 of 28
+
+03/11/02 03/06/02 SOLD
+03/12/02 "03/07/02"BOUGHT
+03/12/02 03/07/02 "BOUGHT
+03/12/02
+:*03/07/02S0L0
+03/0/02
+03/13/02
+13/08/0
+03/13/02
+03108/02
+SYMBOL TECHNOLOGIES INC
+EXECUTION BY SBSH
+VO 0002.06-02
+238,00
+VIACOM INC-CLE*
+ECUTION BY DA
+800 11-07-01, 2200 10-03-
+MOSSINANO
+210.00
+SEC FE
+WASHINGTON INC
+EXECUTION BY SUKG
+VS 1500 03-07-02
+"LIBERTY MEDIA CORP
+SER A NEV
+JNSOLICITEI
+"PEREGRINE SYSTEMS INC
+EXECUTION BY SBSH
+VS 700 12-21-01,
+1800 01-09-02
+SEC FE 01-03-02, 3600 01-24-02
+"CALPINE CORP'*'
+EXECUTION BY MDLD
+VS 6400 03-05-02
+COMMISSION
+448,00
+SEC FEE
+1,24
+EMZENS COMMUNICATIONS CC
+EXECUTION BY CAN
+COMMISS 3-08-02
+264,00
+"FOOT LOCKER INC"
+EXECUTION BY BUCI
+VS 2100 12-31-0
+COMMISSION
+SEC FEE
+156,00
+SYMBOLCUSIP
+SBL
+"VIAB
+"EXPD
+"PRGN"
+CPN
+"CZN
+027
+QUANTITY
+3,400
+10.89300
+3,000
+-51.04000
+1,500
+* 59.85130
+*3,400
+= 13.80000
+9,100
+= 9.30310
+6,400
+12.84850
+4,400
+'10:47780
+2,100
+' 17.66630
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+37,289.20
+152,892.70
+89,791.95
+47;158.00
+*84,641.94
+81,766.16
+46,381.32
+36,957.67
+
+
+19 of 28
+SETTLEMENT TRADE
+DATE
+03/13/02
+03/13/02 03/08/02$ÖLD
+Bear, Stearns & Co. Inc.
+03/14/02: *03/11/02*S0LD
+03715/02 03/12/02"BOUGHT
+03715/02
+"03/12/02"
+"*BöUGHT
+REMEC INC
+EXECUTION BY VKCO
+SE 500 1 18-01
+ROYAL CARIBBEAN CRUISES LTD
+SEE NOTE "S* ON BACK
+EXECUTION BY RYAN
+357,00
+STAGE STORES ING
+EXECUTION BY INET
+VS 800 01-03-02
+OMMISSION
+SEC FEI
+21.00
+TALBOTS INC".
+EXECUTION BY GSCO
+VS 200 01-16-02, 1200 02-04-02
+231,00
+SE E 0802. 05130
+ORINGTON NORTHERN SANTA FE
+SHE UTON BY BOOK
+S 1000 03-12-0
+OMMISSION
+70.00
+"BOISE CASCADE CORP"
+SEE NOTE "S' ON BACK
+EXECUTION BY JPHO
+IS 700 03-12-02
+COMMISSION
+49,00
+SYMBOLCUSP
+REMC
+RCL
+STGS
+"BNI
+BCC
+027
+QUANTITY
+-6,500
+5,100
+-800
+3,300
+9.66250
+21.72600
+29.61260
+''34:43430
+1,000
+30.67670
+700
+37.03600
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+62,790.30
+110,428.93
+23,650.72
+3,385.
+30,761.70"
+25,989.20
+
+
+20 of 28
+SATE EMENT TATE
+DATE
+03/15/02
+03/12/02
+03/15/02 03/12/02 "BOUGHT
+03715/02
+03/12/02
+03/15/02: *03/12/02*S0LD
+03/15/02
+*03/12/02
+03/1502
+202460.
+03/18/02
+*03/13/02
+'SOLD"
+CSX CORP
+WITH RIGHTS TO PURCHASE PREFRD
+STE UNION BE FERN CIRCUMSTANCE
+00 MIS 0312-02
+70.00
+CUMMINS INC.
+WITH RIGHTS TO PURCHASE COMMON
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY JPHO
+VS 700 03-12-02
+COMMISSION
+49.00
+"FLEXTRONICS INTERNATIONAL
+LTD
+EXECUTION BY INET
+VS 1400 03-12-02
+COMMISSION
+42,00
+MAS00 CORP'•**
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY OPCO
+VS 700 01-16-02, 1400 12-28-01
+DOMMISSION
+147,00
+SEC FEE
+SANMINA SCICORP
+XECUTION BY FBO
+S 1400 03-12-0
+TALBOTS INCI
+EXECUTION BY BUCK
+VS 1200 12-05-01
+COMMISSION
+SEC FER
+-62.00
+"ACTV INC
+EXECUTION BY SBSH
+VS 3900 04-19-00, 1100 11-02-4
+SEC FEE
+.11
+SYMBOLCUSIP
+CSX
+"CUM
+"FLEX
+MAS
+*SANM
+027
+QUANTITY
+1,000
+38.93200
+700
+1,400
+*2,100
+*''46.50180
+18.19210
+•***28:54400
+1,400
+-1,200
+5,000
+13.63000
+35.05790
+35000*
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+39,017.00
+' 32,615.26
+25525.94
+59,779.50
+19,097.00
+10981.84
+6,734.89
+
+
+21 of 28
+DATE
+03/19/02
+03/14/02
+03/19/02 03/14/02 SOLD
+03/20/02
+53715/02
+20/12/60
+03/18/022
+03/22/02
+03/19/02
+03/2502
+*03/20/02
+"SOLD"
+*SOLD
+MASCO CORP
+WITH RIGHTS TO PURCHASE PREFRD
+STE UNION BERTAIN CIRCUMSTANCE
+1500 12-28
+MMISSI
+SEC FEE
+605.00
+"STAGE STORES INC
+NEW
+EXECUTION BY INET
+0 50 01 09-02
+65.00
+FOOT LOCKER INC
+359.00
+PERICAN EAGLE OUTFITERS INC
+EXECUTION BY JPHO
+VS 1200 01-29-02, 1500 02-01-0
+SEC FEE
+1.13
+"OMINICARE INC
+EXECUTION BY GSC
+VS 1800 06-15-0
+COMMISSION
+SEC FEE
+126.00
+AMERICAN EAGLE OUTFITERS INC
+NEW
+EXECUTION BY JPHO
+VS 500 02-01-02, 1500 02-27-02
+SEC F2-04-02
+1,08
+SYMBOLGUSIP
+MAS
+SIGS
+"AEOS
+OCA
+027
+QUANTITY
+-1,500
+-1,500
+27.80000
+' 27.79840
+3,700
+2,700
+':16:72310
+
+1,800
+2,500
+24.78010
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+41,579.37
+41,636.97
+31,600.5
+75,158.08
+44,462.51
+71,582.17
+
+
+22 of 28
+SETTLEMENT TRADE
+DATE
+03/26/02
+03/21/02
+63/26/02 03/21702 BOUGHT
+03/26/02 03/21/02 SOLD
+03/26/02
+03/21/02
+ö3/26/02
+03/21/02
+03/26/02 03/21/02OUGHT
+03/26/02
+/''03/21/02
+03/26/02
+•'*ö3/21/02
+AMERICAN EAGLE OUTFITERS ING
+NEW
+EXECUTION BY JPHO
+VS 4000 02-04-02
+SEC FEE
+1.69
+"EDISON INTENATIONAL"
+EXECUTION BY ADAM
+AS IS 0 21-02
+259,00
+FOOT LOCKER INC...
+EXECUTION BY MLCO
+COMMISSION -01, 140012.01-01
+COMMISSION
+SEC FEE
+TETRONICE WFENATIONAL
+S 14005321024
+QUIKSILVER INC
+EXECUTION BY OPCO
+; 700 02-11-0
+SEC FEE
+49.00
+.26
+EXECUTION BY SBSH
+VS 1700 03-21-02
+"SYMBOL TECHNOLOGIES INC
+EXECUTION BY GKMO
+VS 2500 03-21-02
+COMMISSION
+175,00
+"TIBCO SOFTWARE INC
+XECUTION BY TW
+3 1300 03-21-6
+SYMBOL/CUSP
+AEOS
+"FLEX
+ZOK
+***•''**SANM
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+112,278.51
+*****62,230.87
+QUANTITY
+4,000
+28.07380
+3,700
+' 1674510''
+1,600
+1663850.•
+1,700
+16.89600
+-700°
+24.41590
+'1,700
+**********11.42000******
+2,500*
+•:1.61870
+1,300
+11.86000
+* 26,494.20
+28,738.20
+17,026.87
+' 19;429:00
+29,236.75
+15,433.00
+
+
+23 of 28
+SETTLEMENT TRADE
+DATE
+03/26/02
+03/21702
+63/27/02 03/22/02*"SOLD
+20/22/60
+03/22/02
+03/27/02
+03/22/02
+03/27/02
+03/22/02
+BOUGH
+03/2802
+03/25/02
+03728/02 0372502 BOUGHT
+TALBOTS ING
+VS 300 12-05-01, 600 12-04-01
+COMMISSION
+SEC FEE
+EXECUTION BY JPHO
+2, 200 02.20002, 1000 02-150
+SEC FEE
+1.04
+NEE STORES NE
+EXECUTION BY INET
+VS 1MIS03-22-02
+30.00
+"TALBOTS INC
+EXECUTION BY BUCK
+VS 500 12-04-01
+OMMISSIO
+EC FE
+20.00
+TIMBERLAND CO-CLA
+EXECUTION BY BUCK
+VOMNIS502-02
+48,00
+AMERICAN EAGLE OUTFITTERS INC
+EE CATION BY PH
+VS 1100 02-08-02, 800 02-07-02
+2000 12-18-01, 600 12-14-01
+SEC FER
+1.75
+CONTNENTAL AIRLINES INC:CLE"
+EXECUTION BY SBSH
+VS 2300 03-25-02
+COMMISSION
+161,00
+SYMBOLCUSIP
+TLB
+"AEOS
+SPIS
+CAL
+220
+QUANTITY
+-900
+2,600
+35.71830
+' 26.52620
+1,000
+500
+800
+4,500
+27.39260
+35.92020
+39.02620
+2583890"
+2,300
+
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+32,076.98
+*68,952.08
+27,437.60
+17,914.83
+*31,283.96
+116,258.30
+"61,630.16
+
+
+24 of 28
+SETTLEMENT TRADE
+DATE
+03/28/02
+03/25/02
+03/28/02 03/25/02 BOUGHT
+03/28/02 03/25/02 SOLD
+03728/02
+03/25/02
+NORTHWEST AIRLINES CORP
+EXECUTION BY SLKC
+SEE FEE 01-08-02
+SANMINA-SCICORP
+.69
+517003-25020
+"ALBOTS INC''''
+EXECUTION BY BUCK
+VS 1200 12-04-01, 800 12-19-01
+800 11-05-01
+COMMISSION
+SEC FEE
+1.48.00
+"TENET HEALTHCARE CORP
+EXECUTION BY MOKE
+VS 2100 12-29-99
+COMMISSION
+147.00
+SEC FEE
+2.06
+TOTAL
+MONEY FUND ACTIVITY
+02/23/02
+02/25/02
+02/28/02 BOUGHT
+03/01702 SOLD
+03/07/02 SOLD"
+OPENINGBALANCE
+DOMEST PREM PORT OLO
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+45,586.81
+20,248.40
+SYMBOLGUSIP
+NWAG
+WINKS.
+TLB
+THC
+QUANTITY
+-2,500
+1,700
+2,800
+2,100
+18.24100
+•i1.90200
+35.05930
+65.25760
+SYMBOUCUSIP
+"GTDXX
+GTXX
+QUANTITY
+2.617,462.71
+500,000
+60,00d
+-150,000
+-200,000
+$-2,888.322.65
+500,000.00
+60,000.00
+027
+1.0000
+0000
+1.0000
+0000
+97,981.56
+136,876.90
+$4.117,158.62
+150,000.00
+200,000.00
+
+
+New York. New York 10179
+25 of 28
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+03/07/02
+03/19/02
+63/21/02
+ö3/21/02
+BOUGH
+BOUGHI
+BOUGH
+DIVIDEND
+DOMEST PRIME MADATOLID
+RESEE MANGLIO
+"DOMEST PRIMES PORTFOLIO
+MONTHLY DIVIDEND
+03/24102
+DIVIDEND
+MONTHLY DIVIDEND
+03/21702
+''''REINVEST
+03/21102
+'''REINVEST'
+03/2602
+MONTHLY DIVIDEND REINVESTED
+**••••••••••••••••••••••••••••••
+MONTHLY DIVIDEND REINVESTED
+03/28102
+TOTAL
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+03/01/02
+DESCRUPTION
+SYMBOL/CUSIP
+HCA INC
+HCA
+(FRM HA-HEALTHCARE COMPANY)
+REC 02/01/02 PAY 03/01/02
+SYMBOUCUSIP
+GIDXX
+QUANTITY
+15,000
+QUANTITY
+200,000
+100,000
+*300,000
+100,000
+2,243.14
+691.14
+400,000
+3,530,396.99
+RATE (S)
+0.0200
+027
+1.0000*
+0000
+.0000
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+200,000.00
+100,000.00
+300,000.00
+100,000.00
+2,243.14
+691.14
+10000•
+2,243.74
+691.14
+:400,000.00
+$-1,462,934.28
+CAEDIT AMOUNT
+300.00
+$552,934.28
+
+
+lear, Steams & Co. Inc
+83 Madison Avenu
+26 of 28
+DIVIDENDS (continued)
+DATE
+HONEYWELL INTL INC
+REC 02/20/02 PAY 03/08/02
+03/11/02 LI2 CLAIBORNE INC
+REC 02/19/02 PAY 03/11/02
+03/11702" NORFOLK SOUTHERN CORP"
+REC 02/01/02 PAY 03/11/02
+03/12/02 PPG INDUSTRIES INC
+REC 02/19/02 PAY 03/12/02
+03/14/02
+''OMNICARE INC
+REC 02/28/02 PAY 03/14/02
+v25/0
+. . . .
+TALBOTS INC
+TOTAL
+REC 03/11/02 PAY 03/25/02
+SYMBOL/CUSIP
+HON
+Liz'
+"NSC
+"OCR
+TLE
+INTEREST
+DATE
+03/21/02
+INT CR
+TOTAL
+SYMBOUCUSIP
+MAR 02
+Trades Executed Pending Settlement
+SETILEMENT TRADE
+DATE
+04/01/02
+03/26/02
+AMERICAN EAGLE OUTFITTERS ING
+NEW
+////////.............
+QUANTITY
+RATE (S)
+4,850
+0.1875
+7.400•• 0.0562
+14,100*
+"0.0600
+1,500 0.4200
+8, 100*
+0.0225
+8,700
+0.0800
+QUANTITY
+RATE (%)
+SYMBOLCUSP
+AEOS
+027
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+909.38
+- 416.25
+846.00
+630.00
+182.25
+....
+696.00
+$3,979.88
+CAEDIT AMOUNT
+931.41
+$931.41
+QUANTITY
+-1,400.00
+DREDIT AMOUNT
+25.1290
+35,165.07
+........!.!!..........
+
+
+Bear, Stearns & Co. Inc.
+27 of 28
+Trades Executed Pending Settlement
+(continued)
+SEE MENT TRIE
+04/01/02
+03/26/02
+04/01/02
+03/26/02
+04/01/02
+03/26/02
+04/01/02
+03/26/02
+04/01/02
+03/26/02
+.. . .
+04/01/02
+03/26/02
+04/01/02
+03/26/02
+04/01/02
+…............a.
+04/01/02
+04/02/02
+03/26/02
+03/26/02
+03/27/02
+04/02/02
+03/27/02
+.. . . .
+04/02/02
+03/27/02
+04/02/02
+03/27/02
+04/03/02
+3/28/0
+BOUGH
+04/03/02
+04/03/02
+04/03/02
+03/28/02
+03/28/02
+03/28/02
+BOUGH
+BURLINGTON NORTHERN SANTA FE
+CORP
+DISE CASCADE COR
+ITH RIGHTS TO PURCHASE COMMO
+MILDREN PLACE REAL STORES
+CSX CORP
+WITH RIGHTS TO PURCHASE PREFRD
+CONTINENTAL AIRLINES INC-CL B
+FLEXTRONICS INTERNATIONA
+MASCO CORP
+WITH RIGHTS TO PURCHASE PREFRO
+NOVA CHEMICALS CORP
+SANMINA-SCI CORP
+ADELPHIA COMMUNICATIONS CORP
+CLA
+EASTMAN CHEMICAL CO
+MASCO CORP
+WITH RIGHTS TO PURCHASE PREFRD
+WITH RIGHTS TO PURCHASE PREFRD
+CELESTICA INC***
+SUBORD VTG SHS
+CISCO SYSTEMS INC
+CONTINENTAL AIRLINES INC-CL B
+EASTMAN CHEMICAL CO
+SYMBOLCUSP
+BNI
+BCC
+CSX
+CAL
+FLEX
+MAS
+NCX
+SANM
+...........
+ADLAC
+EMN
+......
+MAS
+TXT
+"CLS
+CSCO
+CAL
+EMN
+027
+QUANTITY
+1,700.00
+1,100.00
+-3,600.00
+1,000.00
+1,300.00
+1,400.00
+-1,000.00
+-2,200.00
+1,400.00
+......
+3,500.00
+-1,100.00
+1,000.01
+- 1,400.00
+33000.00
+13,600.00
+1,200.00
+1,100.00
+29.9888
+35.4000
+31.7800
+37.1955
+27.2705
+17.7700
+*27.2100
+23.7204
+1.970
+....
+18.5000
+48.9641
+......
+27.2290
+50.3160
+36.5640
+16.9674
+28.3301
+.. . .
+48.7825
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22, 2002
+51,114.96
+39,032.00
+114,391.28
+37,280.50
+35,544.65
+...........
+4,893.0
+16,773.00
+27,124.59
+2,015.0
+64.734.02
+53,767.70
+......
+27,143.59
+70,328.34
+109,917.00
+230,771.64
+34,095.12
+53,567.94
+
+
+28 of 28
+Trades Executed Pending Settlement
+(continued)
+SETLEMENT TREE
+04/03/02
+03/28/02
+BOUGhT
+04/03/02 03/28/02 BOUGHT
+TOTAL
+FLEXTRONICS INTERNATIONAL
+"TRIOUNT SEMICONDUCTOR INC
+The above trades do not appear in ary other section of this statement.
+SYMBOLCUSP
+FLEX
+TONT
+QUANTITY
+1,000.00
+1,500.00
+18.5344
+12.1880
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD February 23,2002
+THROUGH
+March 28, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+February 22,2002
+18,549.40
+18.297.00
+$616,268.27
+$498,237.62
+STOP
+***** End of Statement******
+027
+
+
+lear, Steams & Co. Inc
+83 Madison AvenL
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+What's In This Statement
+Financial Summar........................
+Your Portfolio Holdings
+Transaction Detail ..............................
+Fund Activity.......
+Trades Not Yet Settled
+4
+8
+20
+22
+INSTITUTIONAL INTERESTS
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENNAN
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+13,730,723
+707,762
+2,617,462
+S17,055,947
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+18,159,806
+-1,103,859
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account
+Market Value of Your Portfolio
+S3,325.224
+$2,829.738
+Cash & Equivalent
+Equities
+$13,730,723
+1 $15,330,068
+Current market value
+SP This satement stori for retanal for our record, Set reverse das a a portant intormation.
+
+
+2 of 23
+Bear, Steams Securities Corp
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+02/23/02;11:32 001|
+
+
+3 or 23
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Amount Credited
+Securities Bought
+Money Fund
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERICO
+1,114,248.2
+.....
+2,590,579.61
+351,973.29
+3,121.96
+2,945,674.86
+... .
+-2,100,072.01
+-1,251,973.29
+-116.03
+$-3.352.161.33
+406,486.47
+$707.761.76
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+1,112,885.98
+1,362.25
+$1,114,248.23
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+Foreign Tax Withheld
+THIS PERIOD
+4,153.27
+941.98
+85.095.25
+-81.03
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+CLOSING
+705,457.53
+2,304.23
+*******•-*.
+$707,761.76
+YEAR TO DATE
+8.054.22
+2,304.23
+10,358.4
+-81.03
+3,325,224
+13,730,723
+17,055,94
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent
+20%
+Equities
+80%
+Unshaded portions denote debit balance and or shart
+
+
+4 of 23
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+THE TREASURERS FUNDING
+DOMESTIC PRIME MAM PORTFOLIO.
+THE TREASURERS FUNDING
+DOMESTIC PRIME MIM PORTFOLIO
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+ABERCROMBIE & FITCH CO-CLA
+ACTV INC
+AMERICAN EAGLE OUTFITTERS INC
+NEW
+ANDAX GROUF
+NEW
+ELEPHA COMMUNICAIONS CORP
+AVNET INC
+BEA SYSTEMS INC
+BEVERLY ENTERPRISES INC NEW
+CHILDRENS PLACE RETAIL STORE
+ING
+CENDANT CORP
+SYMBOLCUSIP
+GTOXX
+GTDXX
+QUANTITY
+614,149.4
+3,313.23
+1.0000
+1.0000
+SYMBOL CUSIP
+ANF
+IATV
+AEOS
+ADRX
+"ADLAC
+AVT
+BEAS
+....
+BEV
+PLCE
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+3,200
+22,300
+17,700
+3,900
+23,154
+4,500
+13,100
+.. ..
+44,800
+5,600
+11,450
+MARKET
+VALUE
+707,762
+2,614,149
+3,313
+$3.325,224
+25.2900
+1.4600
+24.9000
+34.9590
+21.3000
+25.8600
+....
+14.8600
+6.3200
+32.3800
+15.6800
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+ESTIMATED
+ANNUAL INCOME
+39,212
+.500
+.......
+1.5092
+50
+$39,262
+MARKET
+VALU
+80,928
+32,558
+440,730
+136,340
+493,180
+116,370
+179,536
+ESTIMATED
+ANNUAL INCOME
+CURRENT
+YIELD (%)
+1,350
+1.1601
+027
+02/23/02:11:32 001
+
+
+5 or 23
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+COSTCO WHOLESALE CORP-NEW
+CITIZENS COMMUNICATIONS CO*
+CAPSTONE TURBINE CORP
+CANDIES INC
+CONTINENTAL AIRLINES INC-CLB
+STRATE NETWORKIN
+EDISON INTERNATIONAL
+EASTMAN CHEMICAL CO
+EMMIS COMMUNICATIONS CORP-CLA
+ENZON INC
+FOOTSTAR INC
+FOX ENTERTAIMENT GROUP INC
+CL A
+....
+FMC CORP NEW
+FOOT LOCKER INC
+.....
+FEDERATED DEPARTMENT STORES
+INC-DEL
+. . ..
+IONA TECHNOLOGIES PLC
+SPONSORED ADR
+HONEYWELL INTL INC
+INTERSIL CORPORATION CLA
+(FRM INTERSIL HLG CORP CL-A)
+I-MANY INC
+HCA INC
+(FRM HOA-HEALTHCARE COMPANY)
+......
+SYMBOLCUSIP
+COST
+CZN
+CPST
+CAND
+CAL
+STXN
+EIX
+EMN
+EMMS
+ENZN
+FTS
+FOX
+FMC
+IONA
+HON
+IMNY
+HCA
+CASH
+.....
+CASH
+CASH
+....
+RGN
+•......
+CASH
+CASH
+CASH
+•****•
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+2,800
+...
+32,800
+......
+14,600
+346
+5,850
+•••••••••••
+13,450
+10,550
+2,200
+14,950
+5,350
+3,900
+11,400
+900
+21,050
+4,400
+5,700
+4,850
+1,700
+39,150
+15,000
+45.2300
+9.2800
+2.8500
+.....
+1.300
+30.9000
+5.3700
+15.5800
+40.5000
+24.5600
+43.9900
+26.3300
+20.6500
+36.1500
+1.250
+38.3600
+15.9900
+35.0900
+28.1300
+5.9900
+43.6500
+MARKE
+JALUE
+126,644
+304,384
+41,610
+796
+180,765
+2,22
+164,369
+89,100
+367,172
+235.347
+102,687
+235,410
+32,535
+342,063
+168,784
+91,143
+170,187
+47,821
+234,509
+654,750
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+ESTIMATEC
+ANNUAL INCOME
+CURRENT
+YELD IN
+... . .
+... . .
+•••••••/
+3.872
+4.3457
+3,638
+1,200
+2.1376
+••••••
+0.1833
+
+
+6 of 23
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+IMC GLOBAL INC
+JHLS COF
+... . . .
+LIBERTY MEDIA CORP
+SER A NEW
+LIZ CLAIBORNE INC
+MILLENNIUM CHEMICALS INC
+MASCO CORP
+NOVA CHEMICALS CORP
+NORTHWEST AIRLINES CORP
+NORFOLK SOUTHERN CORP
+PEREGRINE SYSTEMS INC
+POLO RALPH LAUREN CORP-CL A
+......
+OMNICARE INC
+.. . . .
+.....
+PACIFIC SUNWEAR OF CALIFORNIA
+INC
+...
+PPG INDUSTRIES INC
+PRAXAIR INC
+QUIKSILVER INC
+REMEC ING
+ROYAL CARIBBEAN CRUISES LTD
+SOLUTIA INC
+SICOR INC
+.......
+SKECHERS USA INC
+CLA
+SYMBOLICUSIP
+IGL
+LIZ
+MCH
+MAS
+NCX
+NIAC
+NSC
+PRGN
+RL
+OCR
+PSUN
+PPG
+REMO
+RCL
+OFFICE SERVICING YOUR ACOUNT
+CASH
+.....
+CASH
+.....
+CASH
+CASH
+....
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+.......
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+..........
+CASH
+QUANTITY
+17,200
+3,200
+....
+37,800
+12.
+проводеров
+1,500
+......
+2,000
+14,000
+14,750
+23,150
+8,800
+6,200
+9,000
+13.0300
+.. ..
+65.8300
+...
+12.2000
+28.8900
+12.2800
+26.
+15.
+22.
+27.
+22.1500
+21.4400
+50.4000
+57.5500
+. . . .
+18.7400
+8.0400
+16.8000
+5.8000
+....
+15.9000
+13.6000
+224,116
+210,65€
+461,160
+213,786
+27,012
+339.
+175,526
+76,500
+255.432
+59,878
+246.724
+179,415
+84,688
+75,600
+115,100
+262,360
+118,590
+388,920
+51,040
+98,580
+122,400
+027
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+ESTIMATE
+NNUAL INCOM
+1,376
+CURRENT
+YIELD (S
+0.6140
+... . .
+1.665
+4,266
+....
+6,966
+1,353
+.....
+0.7788
+.........
+2.0509
+1770
+2,784
+1.0899
+729
+0.4063
+2,520
+230 1320
+3.3333
+1.3206
+12,038
+352
+3.0952
+0.6897
+
+
+7 of 23
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+STAGE STORES INC
+NEW
+SINCLAIR BROADCAST GROUP INC
+CLA
+SOLECTRON CORP
+SYMBOL TECHNOLOGIES INC
+TYCO INTERNATIONAL LTD
+TALBOTS INC
+TENET HEALTHCARE CORP
+TEXTRON INC
+......
+TIMBERLAND CO-CLA
+...
+TOMMY HILFIGER CORP-ORD
+TRIQUINT SEMICONDUCTOR INC
+aaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaa
+UNITED RETAIL GROUP ING
+UNIVERSAL HEALTH SERVICES INC
+.CL...
+VITRIA TECHNOLOGY INC
+COM
+VITESSE SEMICONDUCTOR CORP
+VIACOM INC-CL B
+VISHAY INTERTECHNOLOGY INC
+YORK INTERNATIONAL CORP NEW
+YOUNG BROADCASTING INC-CL A
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLICUSIP
+STGS
+SBG
+SLR
+SBL
+TYC
+TLB
+THC
+TXT
+'BL
+TOM
+TQNT
+URGI
+UHS
+VITR
+VTSS
+VIAB
+VSH
+YRK
+YBTVA
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH**
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+13,600
+27,600
+30,750
+17,200
+4,900
+11,400
+7,350
+1,400
+3,100
+13,800
+8,500
+.. ...
+16,700
+........
+5,500
+15,650
+7.250
+5,000
+7,500
+7,250
+17,000
+26.9500
+11.3600
+8.8700
+27.5000
+6.580
+61.7600
+46.4000
+34.7600
+12.5000
+9.3400
+8.1200
+41.1300
+43700
+7.4200
+44.1500
+17.5500
+31.8600
+24.7500
+MARKET
+VALUE
+366,520
+313,536
+272,753
+......
+01,28
+134,750
+417,012
+453,936
+64,960
+107,756
+...
+72,50
+79,390
+| 35,604
+226,215
+68,391
+53,795
+20,750
+131,625
+230,985
+420,750
+$13,730,723
+$13,730,723
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+CURRENT
+YELD IN
+544
+245
+3.648
+1,820
+.. ...
+0.2703
+0.1818
+0.8748
+2.8017
+4,350
+$56,236
+$56,236
+
+
+
+8 of 23
+OFFICE SERVICING YOUR ACOUNT
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TATE
+01/28/02 01/23/02 BOUGHT
+0128/020/2302000A0
+0172810201/23/02
+"BÖUGHT
+01728/02 01723/02
+"BOUGHT"
+AMERICAN EAGLE OUTFITTERS INC
+NEW
+EXECUTION BY ASSF
+VS 1000 01-23-02
+"BEA SYSTEMSINC
+EXECUTION BY INET
+VS 1700 01-23-02
+COMMISSION
+51.00
+"TONA TECHNOLOGIES PLC"
+SPONSORED ADR
+EXECUTION BY FECO
+VS 2700 01-23-02
+AS OF 01/23/02
+"ING GLOBAL INC
+SEE NOTE 'S" ON BACK
+EZ1000E
+COMMISSION
+224,00
+$95,498
+$17,055,946
+SYMBOLCUSP
+AEOS
+"BEAS
+DONA
+QUANTITY
+1,000
+1,780
+27.86500
+'•19:67728
+2,700
+*3,200
+22.03750
+'12.38690
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+27,880.00
+33.517:24
+59,516.25
+*39,877.08
+
+
+9 of 29
+SETTLEMENT TRADE
+01/28/02 01/23/02
+61/28/02 01/23/02**"BOUGAT
+01/29102 01/24/02 BOUGHT
+
+01724/02
+20162/10
+01/24/02
+01729/02 01724/02 BOUGHT
+
+01724/02
+01729/02 01/24/02 SOLD
+01729/02 01/24/02 "BOUGHT
+SKECHERS USA INC
+CLA
+EXECUTION BY BUCK
+VS 1000 01-23-02
+COMMISSION
+60,00
+"VITESSE SEMICONDUCIOR CORP"
+EXECUTION BY COWN
+VS 1700 01-23-02
+CAPSTONE TURBINE CORP'**
+EXECUTION BY SBSH
+VS 3800 01-24-02
+"EASTMAN CHEMICAL CO
+EXECUTION BY MSCO
+COMMISSION 21-02
+119,00
+ONA TECHNOLOGIES PLO
+SPONSORED ADR
+
+PEREGRINE SYSTEMSINC
+15 360001-2402
+SE NOTE 1S' ON BACK
+EXECUTION BY MSCO
+VS 700 01-24-02
+COMMISSION
+49.00
+"ROSS STORES INC
+EXECUTION BY MONT
+SEC FEE 1-08-02
+.21
+"SKECHERS USA INC
+EXECUTION BY BUCK
+COMMS 0124-02
+108,00
+SYMBOLGUSIP
+SKX
+viss
+CAST
+EMN
+TONA
+"PRGN
+"PX
+'"'ROST
+*SKX
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+16,008.80
+19;741.80
+18,661.60
+862
+9'898 L
+31,489.44
+37,181.29
+13,799.47
+28,707.00
+027
+QUANTITY
+1,000
+1,700
+3,800
+1,700
+1,200
+3,500
+700
+-400
+1,800
+15.93380
+• 4.90700
+7969 2
+09+6L22
+
+53.02470
+34.53670
+1588000"
+
+
+10 of 23
+SETTLEMENT TRADE
+DATE
+01/29/02
+01/24/02
+61/29/02 01/24/02**"BOUGAT
+01730102 01/25/02 SOLD
+01730/02 01/25/02 SOLD
+01731102 01/28/02
+02701/02
+01/29/02
+02/01/02
+01729(02
+
+•''BOUGHT
+TOMMY HILFIGER CORP-ORD
+EXECUTION BY BUCK
+19 MISS1013-01, 50010-26-01
+126,00
+SEC FEE
+"TAIGUINT SEMICONDUCTOR"ING"
+EXECUTION BY SBSH
+VS 8500 01-24-02
+ADELPHIA COMMUNICATIONS CORP
+CLA
+XECUTION BY SBSI
+S 3100 01-16-0
+SEC FEE
+1.26
+"GEORGIA PACIFIC CORP
+EXECUTION BY BUCK
+VOMMISS1008-02, 900 04.00-02
+COMMISSION
+SEC FEE
+*TOMMY HILFIGER CORP ORD
+EXECUTION BY BUCK
+У 0 102501, 140 32 050-
+DOMMISSION
+SEC FEE
+"AMERICAN EAGLE OUTFITERS INC
+NEW
+EXECUTION BY JPHO
+VS 1300 01-29-02
+CHLORENS PLACE RETAIL STORES"
+1S 50001-29-02
+"FOOT LOCKER ING
+ECUTION BY BUC
+S 1900 01-29-
+COMMISSION
+114,00
+SYMBOLGUSIP
+TOM
+"TONY
+"ADLAC
+"TOM"
+"PLE
+027
+QUANTITY
+-2,100
+8,500
+3,100
+-1,400
+14.90840
+'27:03600"
+''22. 50000
+-2,200
+1,300
+1,500
+1,900
+•11:52510
+26.28500
+"32.67000
+13.63600
+02/23/02:11:32 001
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+31,166.17
+'''93,217.50
+83,795.34
+31.400.52
+34,007.70
+*34,185.50
+49,020.00
+26,037.40
+
+
+11 of 23
+DATE
+02/01/02
+01/29/02
+02/01/02 01/29/02 SOLD*
+02/01/02
+01/29/02
+
+01730/02
+ö2/04/02
+01730/02
+02/04/0201/30/02S0LB
+02/04/0201/30/02
+FEDERATED DEPARTMENT STORES
+ING-DEL
+EXECUTION BY BUCK
+VS 700 12-10-01, 300 12-06-01
+SOMMISSION
+60000
+"PACIFIC SUNWEAR OF CALIFORNIA
+.17
+USA NETWORKS ING
+EXECUTION BY JPHO
+8201-07-01. 10011-1301
+SEC FEE
+"AMERICAN EAGLE OUTFITERS INC
+NEW
+EXECUTION BY JPHO
+VS 2000 01-30-02
+FOOT LOCKER INC
+5 10001-30-02
+COMMISSION
+60.00
+IMPERIAL CHEMICAL INDS PL.**
+ADR NEW
+EXECUTION BY GSCO
+VS 1400 10-11-01
+COMMISSION
+SEC FEE
+OHLS COR
+-08.00
+XECUTION BY RHC
+VS 400 01-10-02
+COMMISSION
+SEC FEE
+28,00
+.39
+SIABOUCUSP
+"PSUN"
+USAİ
+AEOS
+KSS
+027
+QUANTITY
+-1,000
+500
+3,000
+2,000
+1,000
+40.80710
+22.50000
+29.71400
+26.50250
+14.85000
+1, 400
+1***********37gH*******
+:400
+''63.83050
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+40,731.48
+11,234.83
+89,125.66
+53.020.00
+4,925.00
+•****29.776.41
+25,488.81
+
+
+12 or 23
+DATE
+02/04/02
+01/30/02
+02/04/02 01730/02 BOUGHT"
+02/04/02
+01730/02
+02704/02
+•'01730/02
+02104/02*01/30/02 BOUGHT
+02/05/02
+01/31/02
+02/05/02
+01731/02
+BOUGH
+ö26502 *01731702•B008AТ
+OM GROUP INC
+SEE NOTE 'S' ON BACK
+EXECUTION BY COWN
+VS 2600 01-17-02
+SEC FESSION
+2.88,00
+"POLO RALPH LAUREN CORP-CLA
+SEE NOTE 'S" ON BAC
+114,00
+"PACIFIC SUNWEAR OF CALIFORNIA"
+EXECUTION BY RHCO
+SEC FE 01-07-02, 70001-02-02
+SEC FEE
+@UIKSILVER INC"
+EXECUTION BY BUCK
+VS 2900 01-30-02
+COMMISSION
+174.00
+TOMMY HILFIGER CORPOR
+EXECUTION BY MSCO
+203,00
+ANDAX GROUP'***
+52083F050
+EASTMAN CHEMICAL CO"
+EXECUTION BY BUCK
+VS 500 01-31-02
+COMMISSION
+"ENZON IN**'
+XECUTION BY COW
+S 1300 01-31-0
+30,00
+SYMBOL/GUSP
+OMG
+'AL
+PSUN
+*ZOK
+"TOM"
+"ABRX
+'EMN
+027
+QUANTITY
+-2,600
+1,900
+1,000
+2,900
+2,900**
+2,000
+500
+1,300"*
+65.45460
+
+22.86000
+• 18.02950
+*12.25710
+59.65330
+40.10000
+''53.08500"
+02/23/02:11:32 001
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+169,982.40
+' 51,220.00"
+22,844.65
+52,474.55
+* 35,763.59
+119,321.60
+20,095.00
+69,025.50
+......
+
+
+13 of 23
+SETTLEMENT TRADE
+DATE
+02/05/02
+01/31/02
+62/65/02 01731702**BOUGAT
+02/06/02 02/01/02 BOUGHT*
+02706/02
+:*02/01/02BÖÜGHT
+02/08/02
+•02201702
+02/06/02*02/01/02SOLB
+
+'BoUGHT
+
+'"ö2/04/02•"BOUGAT
+POLO RALPH LAUREN CORP-CLA
+SEE NOTE 'S' ON BACK
+ECUTION BY BU
+2300 01-31-
+COMMISSION
+138,00
+PEE INDUSTAIES INE"
+EXECUTION BY BUCK
+/S 1500 01-31-02
+OMMISSION
+XECUTION BY RSS
+S 2000 02-01-0
+"ANDR GROUP'***
+S700001020
+"FEDERATED DEPARTMENT STORES
+EXECUTION BY BUCK
+0S MISS12-0-01
+SEC FEE
+72,00
+.74
+SOLUTIA INC......
+EXECUTION BY MLCO
+VS 6950 01-02-02, 1900 01-09-0
+OMMISSION
+SEC FE
+1,21.00
+SIGOR INC
+EXECUTION BY SBSH
+20-10-200090SA
+"AMERICAN EAGLE OUTFITTERS"INE"
+NEW
+EXECUTION BY JPHO
+/S 5900 02-04-0
+AS OF 02/04/02
+.. . .
+SYMBOLCUSP
+AEOS
+"BAX
+QUANTITY
+2,300
+27.29270
+1,500
+48:2047**
+• 2,000 25.89700...
+*700
+**58.42500
+-1,200
+40.77130
+• 8,850
+•9.06490•*
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+62,926.21
+''''72,412.05
+'51,809.00**'
+40,912.50
+SCRI
+"AEOS"
+5,300
+00st
+1577930"
+''''24:67540
+48,837.82
+1***•••*79,677.16
+71,021.85
+145,245:88
+027
+
+
+14 of 23
+DATE
+02/07/02
+02/04/02
+02/07/02 02/04/02 SOLD"
+02707/02
+'02/04/02"*
+02/07/021
+''''02/04/02S0LB
+ö2/08/02
+0205/02
+'SOLD
+02/08/02
+02/05/02
+"BOUGHT"
+JONES APPAREL GROUP ING
+: 1500 01-02-0
+IMMISSIO
+SS OF 020402
+170.00
+
+"61
+72.00
+"USA NETWORKS INC
+S280011-1-01
+1,21
+BACON STANDARD COMPANIES"
+VS 2700 11-14-01, 1400 11-20-0
+COMMISSION
+287,00
+SEC FEE
+3.69
+SKECHERS USA INC
+EXECUTION BY BUCK
+VS 700 02-05-02
+COMMISSION
+42.00
+SYMBOLCUSP
+JNY
+'USAI
+ASD
+SKX
+027
+QUANTITY
+-1,500
+32.41300
+1,800
+''22.34700"
+1,200
+*2,800
+4,100
+' 35.27280
+'28:80200
+
+700
+14.68500
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+48,513.77
+40,208.99
+42,414.36
+80.629.39
+245,677.91
+10,336.50
+
+
+Bear, Stearns & Co. Inc.
+15 of 23
+STENT TATE
+DATE
+02/11/02
+02711702 02/06/02 SOLD"
+SEE NOTE "S' ON BACK
+EXECUTION BY BUCK
+VS 800 01-03-02, 200 01-17-02
+COISON
+60.00
+"JONES APPAREL GROUP ING
+EXECUTION BY BUCK
+VS 1300 01-02-02
+COMMISSION
+SEC FEE
+20/61/20
+
+COMMISSION
+SEC FEE
+"PRAXAIR INC
+SEE NOTE "S" ON BACK
+EXECUTION BY SBSH
+VS 700 01-24-02, 700 01-16-02
+COMMISSION
+SEC FEE
+02/11/02
+102706/02
+
+'02/06/02 BOUGHT
+02/11/02
+DOMMISSION
+178.50
+1.37
+"SKECHERS USAINC
+EXECUTION BY BUCK
+S 2700 02-06-0
+OMMISSIO
+162,00
+TALBOTS INC
+EXECUTION BY BUCK
+VS 1300 02-06-02
+COMMISSION
+78,00
+SYMBOL/CUSIP
+FMC
+NSC
+ROH
+*SKX
+TLB
+027
+QUANTITY
+-1,000
+32.54970
+1,300
+2,500
+-1,400
+*''*31.62630
+
+
+2,550
+2,700
+1,300
+35.70000
+13.74980
+34.11800
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+32,474.21
+*41,020.57
+53,228.69
+78,640.57
+90,840.13
+*37,301.46
+*44,446.40
+
+
+16 of 23
+DATE
+02/11/02
+02/12/02 02/07/02 BOUGHT
+
+
+02/12/02
+20121/20
+20/21/20
+02/12702
+02/07/02
+02/07/02
+02/07/02
+20/40/20
+20/20/20.
+BOUGH
+"SOLD"
+WITH RIGHTS TO PURCHASE PREFRD
+STE UNION BE MILI CIRCUMSTANCE
+900 11-15-0
+MMISSI
+SEC FEE
+-60.00
+"AMERICAN EAGLE OUTFITERS INC
+NEW
+VS 800 02 07 020
+ECUTION BY SB$
+: 1200 02-07-
+"ANNTAYLOR STORES CORP
+SEE NOTE 'S' ON BACK
+EXECUTION BY TWPT
+VS 1800 12-17-01, 900 12-11-01
+SEC MISSION
+189,00
+1.66
+TONA TECHNOLÖGIES PLE
+SPONSORED ADR
+XECUTION BY FB
+S 1800 02-07-0
+"PACIFIC SUNWEAR OF CALIFORNIA"
+EXECUTION BY RHCO
+VS 2000 02-07-02
+ROSS STORES ING
+EXECUTION BY MONT
+SEC FEE 01-08-02
+.54
+"SICOR INCI
+ECUTION BY COV
+S 1700 02-07-
+SMIROUCUS
+AEOS
+ADRX
+ANN
+TONA
+*PSUN
+ROST
+"SCRI
+027
+QUANTITY
+-900
+800°
+1,200
+2,700
+1,800
+2,000
+1,000
+1,700
+43.89550
+24.11000
+52.02670
+40.83740
+16.34500
+21.46200
+'35.93570
+n14:08830
+02/23/02:11:32 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+39,427.35
+19,303.00
+62,447.04
+"110,055.32
+29,436.00
+42,939.00
+35,920.16
+23.965.11
+
+
+17 of 23
+DATE
+02/12/02
+02/07/02
+Bear, Stearns & Co. Inc.
+02/13/02 02/08/02 "BOUGHT
+02/13/02
+
+02713/02 *02/08/02*SOLD
+0271370202/08/02 SOLD
+02713/02
+02/08/02
+TIMBERLAND CO-CLA
+EXECUTION BY FCAP
+S 800 01-08-02, 500 01-11-0
+0-01-10 008
+SO ASSION
+1227,00
+"AMERICAN EAGLE OUTFITERS INC
+NEW
+s 130002-0800
+FMC CORP NEW"
+SEE NOTE 'S' ON BACK
+EXECUTION BY DRKW
+VS 500 01-17-02, 500 12-06-01,
+1000 11-13-01
+SEC FISSION
+1.00.00
+HONEYWELL' INTL' INC
+SEE NOTE 'S' ON BACK
+EXECUTION BY BUCK
+VS 1300 01-03-02
+COMMISSION
+SEC FEE
+79,00
+"PRAXAIR INC'*
+SEE NOTE "S' ON BACK
+ECUTION BY DRK
+S 1000 01-16-
+COMMISSION
+SEC FEE
+70.00
+"TEXTRON INC
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY ORKW
+S 1000 11-15-6
+OMMISSIO
+SEC FEE
+-60.00
+SYMBOLCUSIP
+TBL
+"AEOS
+"FMC
+HON
+"PX"
+027
+QUANTITY
+-2,600
+32.39850
+1,300
+2,000
+24.24200
+33.12980
+*1,300
+'32:50000
+-1,000
+1,000
+55.92500
+43.68140
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+84,037.83
+31,529.60
+
+55,839.16
+43,595.74
+
+
+18 of 23
+DATE
+02/14/02
+02/11/02
+Bear, Stearns & Co. Inc.
+0271402 02/11/02 "BOUGHT
+02/14/02
+
+"BÖUGHT
+
+02/12/02
+ö2/19/02
+02/13/02
+02/19/02*02/13/02S0LB
+20/61/20
+02/13/02
+PRAXAIR INC
+SEE NOTE "S' ON BACK
+EXECUTION BY NEED
+VS 300 01-16-02, 700 01-18-02
+SEC FISSION
+70.00
+"DUIKSILVER INC
+EXECUTION BY BUF
+112,00
+SKECHERS USA INC
+VS 2800021-024
+COMMISSION
+168,00
+"TIMBERLAND CO-CLA"
+AS OF 027202
+DO ENTERTAINMENT GROUP INC
+ECUTION BY BU
+2800 02-13-
+COMMISSION
+168,00
+NAUTICA ENTERPRISES IN.....
+EXECUTION BY RSSF
+VS 2800 01-04-02, 2600 11-13-0
+SEC FEE
+1,11
+"PEREGRINE SYSTEMSINC
+EXECUTION BY SBSH
+3300 11-07-01, 1300 11-1:
+1300 11-13-01, 1100 12-2
+AS OF 0213102
+.79
+SABOUCUSP
+*ZOK
+SKX®
+TBL
+"FOX
+027
+QUANTITY
+-1,000
+57.49240
+1,600
+2,800
+1,600
+2,800
+'18.42480
+14.35510
+31.68160
+21.50000
+7,000
+*7.45550
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+57,406.53
+8Z LLE OF
+''29,606.68
+50,577.79
+'60,383.00
+*•••••*•••••••••••••••••••**73.849.41
+52,172.71
+
+
+19 of 23
+SETE EMENT TATE
+02/19/02
+
+LEARED THROUGH (
+HOLLY OWNED SUBSIDIAI
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocktyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+147,824.77
+02/19/02 02/13/02BOÜGH*
+ö2/20/02
+02/14/02
+SOLO
+02/20/02 *02/14/02**S0L0
+......
+2/20/0
+RECEIVED
+02/21/02*02/15/02OUGH**
+02727/02
+''02/15/02|
+'SÖLD"
+
+''"°2/15/02"BÖÜGHT
+ESCRIPTION
+TYCO INTERNATIONAL LTE
+SYMBOLICUSIP
+TYC
+EXECUTION BY SBSH
+VS 2550 01-18-01, 2450 10-03-0
+COMMISSION
+SEC FEE
+AS OF 02/13/02
+2350.00
+"TOMMY HILFGER CORP-ORD"
+TOM
+BS SUO ON BY BUCK
+COMMISSION
+18.00
+AMERICAN EAGLE OUTFITTERS ING
+AEOS
+NEW
+EXECUTION BY JPHO
+VS 1000 01-23-02, 1200 01-14-0
+2, 1400 01-11-02, 600 01-30-02
+SEC FEE
+1.58
+VIACOM INC-CLB*
+VIAB
+EXECUTION BY BUCK
+VS 1200 12-18-01
+COMMISSION
+SEC FEE
+,32.00
+CANDIES INC
+CAND
+'"'AMERICAN EAGLE OUTFITTEAS INC• "EOS***
+NEW
+S5 00 021605)
+"ADELPHIA COMMUNICATIONS CORP"
+"ADLAC
+XECUTION BY SBS
+S 5100 01-16-0
+SEC FEE
+1.47
+"SYMB8L TECHNOLOGIES INC"
+SBL
+UNSOLICITED
+QUANTITY
+-5,000
+*300
+4,200
+-1,200
+29.63840
+
+25.03650
+•• 43.99050
+3,818.37
+105,136.72
+*52,700.80
+--024:522202457--.
+5,100
+000'9t.
+*'19.16450
+97,722.48
+'*8.54000
+"128,858.00"
+027
+
+
+20 of 23
+DATE
+02/22/02 02/19/02
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+01/26/02
+OPENINGBALANCE
+ö1/28/0250В
+02/01/02
+62/06/02 BOUGHT
+02/08/02
+62/11702
+''''BOUGAY
+02/14/02
+02/15/02
+BOUGHI
+02/21/02
+'''DIVIDEND
+02/21/02"DIVIDEND
+Bear, Stearns & Co. Inc.
+DESCRPTION
+ANNTAYLOR STORES CORP
+SEE NOTE 'S' ON BACK
+ECUTION BY BUO
+$ 1300 12-11-0
+COMMISSION
+SEC FEE
+78,00
+.80
+SYMBOLCUSIP
+ANN
+QUANTITY
+-1,300
+40.80310
+LEARED THROUGH I
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+52,950.23
+$-2,100,072.01
+$2,590,579.61
+SYMBOL/CUSIP
+"ТЫXX
+"GTOXX
+"ТЬXX
+"GTDXX"
+QUANTITY
+1,715,489.42
+150,000
+200,000
+200,000
+300,000
+188,000
+250,000
+150,000
+1.0000
+0000
+1:0000*
+0000
+18000"
+0000
+0000
+50,000.00
+200,000.00
+*200,000.00
+300,000.00"
+188,600.08
+250.000.00
+150,000.00
+MONTHLY DIVIDEND
+"DOMEST PRIME MAM PORTFOLIO
+MONTHLY DIVIDEND
+1,251.74
+721.55
+027
+
+
+21 or 23
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+02/21/02
+REINVEST
+02/2102 REINVEST
+62/22/02*B60GAT*
+MONTHLY DIVIDEND REINVESTED
+DOES HAS BAGUO
+MONTHLY DIVIDEND REINVESTED
+02/22/02
+TOTAL
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+02/01/02
+02/11/02
+02/15/02
+TYCO INTERNATIONAL LTD
+REC 01/02/02 PAY 02/01/02
+"MASCO CORP***
+REC 01/11/02 PAY 02/11/02
+VOVA CHEMICALS CORI
+REC 01/31/02 PAY 02/15/02
+FOREIGN TAX WITHHELD
+SYMBOUCUSIP
+TYC
+"MAS
+NCX
+TOTAL
+INTEREST
+DATE
+02/21/02
+INT CR
+TOTAL
+SYMBOUCUSIP
+FEB 02
+SYMBOUGUSIP
+GIDXX
+QUANTITY
+11,300
+11,100
+8,600
+WH
+QUANTITY
+QUANTITY
+1,251.74
+721.55
+"250,000
+2,617,462.71
+RATE ($)
+0.0125
+0.1350
+0.0628
+RATE (NA
+027
+81.03
+$-81.03
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+1,251.74
+721.55
+*250,000.00**
+$-1,251,973.29
+$351.973.29
+141.25
+1,498.50
+540.23
+$2,179.98
+941.98
+$941.98
+VS27
+
+
+22 or 23
+MISCELLANEOUS
+DATE
+MODAY
+02/01/02
+TOTAL
+01/02 CLR CHG
+Trades Executed Pending Settlement
+SETTLEMENT
+DATE
+TRADE
+DATE
+02/25/02
+02/20/02
+02/25/02
+02/20/02
+... .
+02/26/02
+02/21/02
+....
+02/26/02
+02/21/02
+02/26/02
+02/21/02
+02/26/02
+02/21/02
+... . . .
+02/27/02
+02/22/02
+02/27/02
+... . .
+02/27/02
+02/27/02
+......
+02/27/02
+02/27/02
+....
+02/22/02
+02/22/02
+02/22/02
+02/22/02
+02/22/02
+TOMMY HILFIGER CORP-ORD
+YORK INTERNATIONAL CORP NEW
+BEA SYSTEMS ING
+KENNETH COLE PRODUCTIONS ING
+CLA
+INTERSIL CORPORATION CL A
+(FRM INTERSIL HLG CORP CL-A)
+SOLECTRON CORP...
+ANDRX GROUP
+NEW
+CAPSTONE TURBINE CORP
+MC CORP NE
+PRAXAIR INC
+SOLUTIA INC
+SOLECTRON CORP
+35.00
+$-35.00
+SYMBOLICUSIP
+TOM
+YRK
+BEAS
+KCP
+SIR
+....
+ADRX
+CPST
+FMC
+PX*
+SOI
+SLR
+027
+CRECIT AMOUNT
+QUANTITY
+1,900.00
+-3,600.00
+.............
+2,600.00
+4,200.00
+1,700.00
+-8,600.00
+.. . .
+2,000.00
+:14,600.00
+*900.00
+2,000.00
+..........
+8,800.01
+22,150.0
+11.5249
+....
+32.0878
+.. . .
+15.1590
+18.6512
+27.7200
+9.1083
+........
+33.0671
+2.860%
+36.0500
+57.3432
+.507
+8.5726
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22,2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+22,026.31
+78,602.04
+115,283.34
+39,319.80
+47,108.29
+77,799.20
+.........
+36,058.20
+41,750.59
+*32,366.51
+174529.57
+........
+5.520.2
+188,536.24
+
+
+23 of 23
+Trades Executed Pending Settlement
+(continued)
+SETLEMENT TRIE
+02/27/02
+02/22/02
+TOTAL
+The above trades do not appear in arry other section of this statement.
+VITESSE SEMICONDUCTOR CORP
+SIMBOLCUSP
+VISS
+QUANTITY
+-7,250.00
+7.3833
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 26, 2002
+THROUGH
+February 22, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+January 25, 2002
+$100,628.35
+53,513.12
+$841,785.20
+STOP
+****** End of Statement******
+027
+
+
+lear, Steams & Co. Inc
+83 Madison AvenL
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+What's In This Statement
+Financial Summary ••••••••••...•..................
+Your Portfolio Holdings
+Transaction Detail ..........
+Fund Activity.......
+Trades Not Yet Settled
+8
+25
+28
+INSTITUTIONAL INTERESTS
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE D
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+Market Value of Your Portfolio
+$2,829.738
+$4,076,376
+15,330,068
+1,114,248
+1,715,490
+$18, 159,806
+•••••••••
+18,376,734
+-216,928
+Cash & Equivalent
+Equities
+$15,330,068
+• $14,300,358
+Current market value
+here are no "Stop Loss" orders or other pending bu
+r sell open orders on file for your accoun
+SP This satement stori for retanal for our recorde, Set revere das a a doctant intomation.
+
+
+2 of 28
+Bear, Steams Securities Corp
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+01/26/02;10:42 001|
+
+
+3 or 28
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Funds Deposited
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Money Fund
+Funds Withdrawn
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+914,140.42
+0.00
+$914,140.42
+THIS PERICO
+5914.140.42
+2,832,752.33
+2,503,253.70
+22,962.72
+3,892.25
+5,880,995.94
+11.243.856.9
+.. . . .
+-4,063,544.45
+-1,053,253.70
+45,925.44
+-5,881,025.54
+$-11.043.749.13
+200,107.81
+... .
+51.114.248.25
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+3,900.95
+1,362.25
+55.263.20
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total.
+CLOSING
+1,112,885.98
+1,362.25
+•..•.•
+$1,114,248.23
+027
+YEAR TO DATE
+3,900.95
+1,362.25
+....
+$5,263.20
+.......
+2,829,738
+15,330,068
+$18.159,806
+LEARED THROUGH I
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+16%
+- Equities
+84%
+Unshaded portions denole debit balance andor short
+market values. The alocation percentage is derived
+from the absolute market value of your portlolio.
+
+
+4 of 28
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+THE TREASURERS FUNDING
+DOMESTIC PRIME MAM PORTFOLIO.
+THE TREASURERS FUNDING
+DOMESTIC PRIME MIM PORTFOLIO
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+ABERCROMBIE & FITCH CO-CLA
+ACTV INC
+AMERICAN EAGLE OUTFITTERS ING
+NEW
+...............
+ADELPHIA COMMUNICATIONS CORP
+CLA
+.......
+ANNTAYLOR STORES CORP
+*.._.-_-_____________________..
+AMERICAN STANDARD COMPANIES
+INC-DEL
+......
+AVNET INC
+... . . .
+BEA SYSTEMS INC
+BEVERLY ENTERPRISES INC NEW
+.................. .
+HILDRENS PLACE RETAIL STORE
+INC
+SYMBOLCUSIP
+GTOXX
+GTDXX
+QUANTITY
+1,712, 897.74
+2,591.68
+1.0000
+1.0000
+SYMBOUCUSIP
+ANF
+IATV
+AEOS
+ADLAC
+ANN
+ASD
+AVT
+.........
+BEAS
+...
+BEV
+.....
+PLCE
+CASH
+CASH
+CASH
+ASH
+CASH
+CASH
+......
+CASH
+CASH
+QUANTITY
+3,200
+22,300
+6,600
+31,354
+4,000
+.......
+4,100
+4,500
+....
+11,400
+......
+44,800
+......
+4,100
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+MARKET
+VALUE
+1,114,248
+....
+1.712,898
+2,592
+$2,829,738
+ESTIMATED
+ANNUAL INCOME
+30,832
+1,8000
+......
+47
+1.8133
+$30,879
+26.0000
+1.5700
+28.0200
+27.7500
+36.5300
+...--........
+63.1500
+25.0100
+....
+20.2600
+... . .
+6.8500
+........
+32.0000
+MARKET
+VALUE
+83,200
+35,011
+184.932
+70,07
+146,120
+..........
+258.915
+112,545
+......
+230,964
+....
+306,880
+....
+131,200
+ESTIMATED
+ANNUAL INCOME
+CURRENT
+YIELD (%)
+1,350
+1.1995
+027
+
+
+5 of 28
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+CENDANT CORP
+COSTCO WHOLESALE CORP-NEW
+CITIZENS COMMUNICATIONS CO
+CARSTONE TURBINE CORP****
+CONTINENTAL AIRLINES INC-CL B
+A STRE NEW
+assaaaaaaaaaaaaaaaaaaaaaaaaaaaaaas
+EDISON INTERNATIONAL
+EMMIS COMMUNICATIONS CORP-CLA
+ENZON INC
+POSTAR ING
+FOX ENTERTAINMENT GROUP ING
+CL A
+......
+FMC CORP NEW
+......
+FOOT LOCKER INC
+FEDERATED DEPARTMENT STORES
+INC-DEL
+...
+GEORGIA PACIFIC COAP
+(GEORGIA PACIFIC GROUP)
+HONEYWELL INTL INC
+INTERSIL CORPORATION CL A
+FRM INTERSIL HLG CORP CL-A)
+I-MANY INC
+CA IN
+(FRM HOA-HEALTHCARE COMPANY)
+IMC GLOBAL INC
+....
+SYMBOLCUSIP
+CD
+COST
+....
+CZN
+..-...
+CPST
+CAL
+STXN
+EIX
+EMMS
+ENZN
+FTS
+FOX
+FMC
+FD
+GP
+HON
+ISIL
+IMNY
+"HCA
+IGL
+CASH
+.....
+CASH
+CASH
+••••**
+CASH
+...
+CASH
+CASH
+•....•.
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+11,450
+2,800
+32,800
+10,800
+5,850
+13,450
+10,550
+14,950
+4,050
+3,900
+8,600
+3,900
+.. . .
+18,150
+6,600
+....
+1,400
+6,150
+1,700
+39,150
+15000*
+14,000
+18.4500
+44.2000
+9.8900
+840
+30.2900
+7.5800
+15.5900
+23.1100
+52.9200
+23.2000
+21.6800
+34.5500
+14.1100
+40.4000
+24.7000
+32.7000
+27.9800
+8.6000
+41.6400
+12.9000
+211,253
+123,760
+324,392
+........
+52,272
+177,197
+101,951
+164,475
+345,495
+214,326
+90,480
+186,448
+134,745
+256,097
+266,640
+34,580
+201,105
+47,566
+336,690
+624.500
+180,600
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIO January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+ESTIMATE
+NNUAL INCON
+CURRENT
+YELD IN
+.....
+.....
+700
+4,613
+2.0243
+2.2938
+1,200 01921
+1.120
+0.6202
+
+
+6 of 28
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+IMPERIAL CHEMICAL INDS PLC
+ADR NEW
+JONES APPAREL GROUP INC
+KOHLS CORP
+İBERTY MEDIA CORD
+ER A NEW
+LIZ CLAIBORNE INC
+MILLENNIUM CHEMICALS INC
+MASCO CORP
+NOVA CHEMICALS CORP
+NAUTICA ENTERPRISES INC
+NORTHWEST AIRLINES CORP
+NORFOLK SOUTHERN CORP
+OM GROUP INC
+PEREGRINE SYSTEMS INC
+POLO RALPH LAUREN CORP-CLA
+.....
+OMNICARE INC
+PACIFIC SUNWEAR OF CALIFORNIA
+INC
+PRAXAIR INC
+QUIKSILVER INC
+REMEC INC
+ROYAL CARIBBEAN CRUISES LTD
+ROHM & HAAS CO
+SYMBOLICUSIP
+ICI
+JNY
+KSS
+LIZ
+MCH
+MAS
+NCX
+NAUT
+NWAC
+NSC
+OMG
+PRGN
+OCR
+PSUN
+PX
+REMC
+RCL
+ROH
+CASH
+CASH
+....
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+1,400
+2,800
+3,600
+37,800
+7,400
+7,900
+2,900
+8,600
+5,400
+5,000
+14,100
+2,600
+2,500
+4,707
+.......
+8,100
+5,250
+4,700
+9,500
+14,750
+23,150
+2,550
+23.6300
+32.9800
+66.3400
+14.2500
+26.
+12.
+26.
+19.
+2000
+3.
+66.0000
+7.9500
+27.7100
+23.2000
+23.0000
+55.8800
+8.210
+9.9900
+18.0200
+35.0600
+MARKET
+33,082
+92,344
+238,824
+538,650
+194,620
+96,143
+346.
+365
+165.
+120
+74.736
+78,950
+174
+171,600
+99,375
+130,431
+187,920
+120,750
+262,636
+172,99.
+147,353
+417,163
+89,403
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+ESTIMATE
+NNUAL INCON
+2,061
+CURRENT
+YIELD (%)
+6.2300
+....
+..........
+1.6650.8555
+4,740
+1.930
+6,966
+2.0112
+1,345
+0.8146
+3,384
+1,352
+1.0840
+0.7879
+729
+0.3879
+3,572
+1.3601
+12,038
+2,040
+2.8857
+.....
+2.281฿
+
+
+7 of 28
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+ROSS STORES ING
+OLUTIA IN
+STAGE STORES INC
+NEW
+SINCLAIR BROADCAST GROUP INC
+CLA
+SOLECTRON CORP
+SYMBOL TECHNOLOGIES INC
+TYCO INTERNATIONAL LTD
+TALBOTS INC
+TENET HEALTHCARE
+•••.
+CORP
+TEXTRON INC
+TIMBERLAND CO-CLA
+TOMMY HILFIGER CORP-ORD
+USA NETWORKS INC
+UNITED RETAIL GROUP ING
+UNIVERSAL HEALTH SERVICES INC
+CL B
+....
+VITRIA TECHNOLOGY INC
+COM
+VITESSE SEMICONDUCTOR CORP
+VIACOM INC-CL B
+VISHAY INTERTECHNOLOGY INC
+VORK INTERNATIONAL CORP NEW
+SYMBOLCUSIP
+ROST
+SOI
+STGS
+SBGI
+SLR
+SBL
+TYC
+TLB
+THC
+TXT
+TBL
+TOM
+USAI
+URGI
+UHS
+VITR
+VTSS
+VIAB
+VSH
+YAK
+CASH
+.....
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+....
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH**
+CASH
+QUANTITY
+1,400
+17,650
+13,600
+27,600
+30,750
+12,200
+9,900
+8,900
+7,350
+3,300
+7,300
+14,900
+5,800
+16,700
+.......
+5,500
+15,650
+5,550
+6,200
+7,500
+7,250
+34.9700
+9.8000
+25.3500
+9.9500
+3300
+15.8800
+45.0000
+37.4200
+62.7700
+41.3800
+38.6500
+15.2000
+25.7000
+6.9500
+41.7500
+7.4500
+12.4700
+39.4500
+19-0500
+38.0000
+MARKET
+FALLE
+48,958
+172,970
+344,760
+274,620
+348,398
+193.736
+445,500
+333,038
+461,360
+136,554
+282,145
+226,480
+149,060
+116.065
+229,625
+116,593
+69,209
+244,590
+275,500
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+ESTIMATEC
+ANNUAL INCOME
+238
+706
+244
+495
+2,848
+4,290
+SURRENT
+YIELD (%
+0.4861
+0.4082
+....
+.....
+0.1259
+0.1111
+0.8552
+3.1416
+4,350
+1.5789
+
+
+8 of 28
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+YOUNG BROADCASTING ING-CLA
+Total Equities& Options
+TOTAL EQUITIES
+SIMBCUCUSIP
+YBTVA
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+ACCT
+CASH
+QUANTITY
+17,000
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT TRADE
+01/03/02
+12/28/01
+61/63/02* 12/28/01**BOUGHT
+ADELPHIA COMMUNICATIONS CORP
+CLA
+V5 580081 1007
+SEC FEE
+2,56
+MAS00 CORP...
+SMS 12-28-01
+174,00
+18.4050
+MARKET
+VALUE
+312,885
+$15,330,068
+$15,330,068
+$92,925
+$18,159,806
+ESTIMATED
+ANNUAL INCOME
+$62,046
+$62,046
+CURRENT
+YIELD (%)
+SYMBOLGUSIP
+ADLAC
+"MAS"
+QUANTITY
+-5,600
+2,900*
+30.45000
+2458480*
+027
+LEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+170,502.44
+*1,484.92
+
+
+9 of 28
+SETTLEMENT TRADE
+01/04/02
+
+61/64/02*12/31701BOUGAT
+81764/02 "12/31701"S0C0
+01767/02
+01/02/02
+'BOUGHT
+01/07/02
+01/02/02
+"BOUGHi
+ö1/07702
+10202
+01/07/02
+'' 01/02/02
+01/07/02
+01/02/02
+''BOUGHT
+CHILDRENS PLACE RETAIL STORES
+521001231-010
+DOT LOCKER IN
+EXECUTION BY INET
+"EMC TECHNOLOGIES ING
+SPINOFF ON 2400 SHS
+FMC CORP NEW
+SPIN-OFF F/R F006362
+REC 12/12/01 PAY 12/31/01
+JONES APPAREL GROUP INC
+EXECUTION BY BUCK
+0SS50-02-02
+168,00
+"PACIFIC SUNWEAR OF CALIFORNIA"
+EXECUTION BY RSSF
+VS 2650 01-02-02
+SOLUTIA NC•****
+486.50
+"STAGE STORES INC
+NEW
+ECUTION BY IN
+900 01-02-03
+COMMISSION
+27.00
+SYMBOLCUSIP
+PLCE
+SNY
+PSUN
+SOI
+STGS
+027
+QUANTITY
+2,100
+6,000
+8,100*
+4,127
+2,800
+2,650
+6,950
+900
+27.32350
+-15.83890
+= 452230
+32.99150
+19.82000
+*13:27300
+' 23.25000
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+57,394.35
+95,453.40
+*36.372.08
+92,559.20
+52,538.00
+92,331.85
+20,967.00
+
+
+10 of 28
+SETTLEMENT TRADE
+DATE
+01/07/02
+01/02/02
+01708/02 01/03/02 BOUGHT
+01708/02 01/03/02 BOUGHT
+01708/02
+0201/0302
+Ö1/08/02
+01/03/02 BOUGHT
+01708/02 01/03/02 "BOUGHT
+Ö1708/02 81/03/02"BÖUGHT
+01708/02
+''*01703/02 BOUGHT
+01708/0201/03/02
+TIMBERLAND CO-CLA
+EXECUTION BY BUCK
+CONSO 2-02
+150,00
+AMERICAN EAGLE OUTFITERS INC
+NEW
+EXECUTION BY JPHO
+VS 1300 01-03-02
+XECUTION BY NEED
+CSAMISSO 03-0.
+315.00
+"SHIRENS PLACE REAL STORES'
+ECUTION BY JP
+$ 1100 01-03-
+"FMC CORP NEW**
+SEE NOTE 'S' ON BACH
+EXECUTION BY MSCO
+56.00
+FOOT LOCKER INC
+UNSOLICITED
+"HONEYWELL INTL INC
+SEE NOTE "S' ON BACH
+EXECUTION BY MIDR
+S 2850 01-03-0
+OMMISSIO
+199,50
+"PEREGRINE SYSTEMS INC
+30001-03024
+"ROHM & HAAS CO"
+EXECUTION BY GKMO
+VS 2150 01-03-02
+OMMISSIO
+150.50
+S OF 01/03/0
+SYMBOLCUSIP
+TBL
+"AEOS
+AVT
+"PLCE
+"FMC
+"HON
+027
+QUANTITY
+2,500
+1,300
+4,500
+7,700
+800
+3,900
+2850**
+3,000
+2,150
+37.07050
+• 27.12250
+• 26.62270
+
+33.90000
+15.69160
+*''*34.17460
+9.11250
+''35.66380
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+92,841.25
+35,274.25
+120,132.15
+31,286.13
+27,191.00
+61,470.24
+97,612.11
+27,352.50
+76,842.67
+
+
+11 of 28
+SETTLEMENT TRADE
+DATE
+01/08/02
+01/03/02
+01708/02 01/03/02 BOUGHT
+20/80/L0
+n*01/03/02
+"BÖUGHT
+ö1/08/02
+*01/03/02 SOLD
+01708/02
+01703/02 SOLD
+01709/02
+01704/02
+01/09/02
+01/04/02
+STAGE STORES INC
+NEW
+5 00 01-03-20
+SOLECTRON CORP
+EXECUTION BY MSCO
+20-010 009251
+COMMISSION
+182,00
+TALBOTS INC
+EXECUTION BY BUCK
+COMMIS 0-03-02
+90,00
+TIMBERLAND CO-CLA
+EXECUTION BY BUCH
+VS 1900 01-03-02
+COMMISSION
+114,00
+"VERITAS SOFTWARE CORP
+EXECUTION BY FBCO
+VS 1000 11-20-01, 700 11-08-01
+, 50 11-07-01
+SEC FEE
+1.23
+VERITAS SOFTWARE CORP
+EXECUTION BY INET
+VS 550 11-07-01, 600 11-09-01,
+650 11-12-01
+DOMMISSION
+SEC FE
+1,50.00
+"FOOT LOCKER ING"
+EXECUTION BY BUCK
+OOMMISSION-02
+54,00
+MODATA CORP'***
+EXECUTION BY CEUT
+SEC FEE
+.51
+AS OF 01/04/02
+SYMBOL/GUSP
+SIGS
+TLB
+"VATS"
+"VATS
+"MCDTA"
+027
+QUANTITY
+3,000
+2,600
+1,500
+1,900
+1,750
+-1,800
+23.57930
+11.90340
+37.60590
+*''37.91060
+''46.81830
+47.41430
+900
+-1,050
+* 15.49600
+'3209500
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+70,752.90
+*31,145.84
+98ELS 99.
+'81,915.80
+85,275.45
+14015.40
+33,684.24
+
+
+12 of 28
+SETTLEMENT TRADE
+DATE
+01/09/02
+01/04/02
+01709/02 01/64/02"BÖUGHT
+01709102 01704/02 BOUGHT
+01709/02
+0104/02
+ö1/09/02
+01704/02 BOUGHT
+01709/02 01/04/02 "BOUGHT"
+01709/02 81/04/02"BOUGHT
+01710/02 01/07/02 BOUGHT
+01710/02 0107/02 "BOUGHT
+NAUTICA ENTERPRISES INC
+EXECUTION BY MONT
+AS OF 01040202
+ROHM & HAAS CO
+ECUTION BY SBS
+S 400 01-04-02
+COMMISSION
+28,00
+SOLUTIA INC
+ECUTION BY MSO
+162,00
+"SINCLAIR BROADCAST GROUP ING
+SEND ON I SECH
+SOLECTRON CORP
+ECUTION BY MO
+S 4300 01-04-0
+COMMISSION
+301,00
+"TALBOTS INC*
+XECUTION BY BUO
+S 300 01-04-02
+COMMISSION
+18.00
+"YOUNG BROADCASTING INC-CLA
+EXECUTION BY SBSH
+VS 3500 01-04-02
+"AMERICAN EAGLE OUTFITTERS INC
+"PACIFIC SUNWEAR OF CALIFORNIA"
+XECUTION BY OPO
+S 800 01-07-02
+SYMBOLCUSP
+NAUT
+ROH
+SOi
+'SLA
+"AEOS
+*PSUN
+027
+QUANTITY
+2,800
+400
+2,700
+600*
+4,300
+300
+*3,500
+*900
+800°
+13.77880
+• 36.69750
+- 966910
+9.99330
+•''12.07130
+39.15000
+1858000"
+29.81000
+''21:40000
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+38,595.64
+14,722.00
+26,283.57
+6,010.98
+52,222.59
+14,778:00
+65,045.00
+26,844.00
+17,135.00
+
+
+13 of 28
+SETTLEMENT TRADE
+DATE
+01/10/02
+01/07/02
+ö1711702 01/09/02"BÖUGHT
+01711/02
+01708/02
+
+01708/02
+01711/02"
+01708/02
+*SOLD
+8977302 81708/02'BOUGA
+0171770201708/02
+SOLUTIA INC
+147,00
+ADELPHIA BUSINESS SOLUTIONS
+NC CL A
+SPINOFF ON 23054 SH$
+ADELPHIA COMMUNICATIONS CORP
+SPINOFF FROM SEC # A059849
+AS OF 010224Y 01/1/02
+ADELPHIA BUSINESS SOLUTIONS
+INC CL A
+EXECUTION BY INET
+VS 1227 04-07-98, 950 09-28-00
+, 1000 09-29-00, 3250 11-16-01
+2300 11-20-01, 2800 11-27-01
+345,8
+"CAPSTONE TURBINE CORP
+S 800001-08-02
+NITH RIGHTS TO PURCHASE PREFRO
+STK UNDER CERTAIN CIRCUMSTANCI
+EXECUTION BY BUCK
+VS 2000 11-15-01, 1950 11-13-0
+COMMISSION
+237,00
+"EMMIS COMMUNICATIONS CORP-CLA
+ECUTO BYIN
+132,00
+"GEORGIA PACIFIC CORP.....
+ITH RIGHTS TO PURCHASE PREFF
+TK UNDER CERTAIN CIRCUMSTAN
+EXECUTION BY BUCK
+IS MMISS01-08-02
+132,00
+SYMBOLGUSP
+SOI
+ABIZ
+ABIZ
+"EMMS
+"GP
+027
+QUANTITY
+2,100
+11,483
+-11,527
+10.60000
+0.26980
+8,600
+3,950
+5.75810
+37.66080
+*4,400
+2,200
+25.14620
+25.67530
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+22,422.00
+CRECIT AMOUNT
+2,749.12
+49,534.66
+148,505.92
+110,790.28
+56.632.66
+
+
+14 of 28
+SETTLEMENT TRADE
+DATE
+01/11/02
+01/08/02
+09777782 *87768702฿00GRN
+61/11/02*01708/02 "BOUGHT
+
+01708/021
+*BÖUGHT
+01711/02
+11/08/0
+"BÖUGHT
+01/11/02
+01/08/02
+0171170201708/02 BOUGHT
+
+NORTHWEST AIRLINES CORP
+EXECUTION BY FBCO
+VS 5000 01-08-02
+"ROSS STORES INC"
+S0001027
+"SINCLAIR BAOADCAST GAOUP'ING"
+4S 9000 01-0.02
+*X COMPANIES ING NEW
+138,00
+TIMBERLAND CO-CLA
+XECUTION BY BUCH
+/S 800 01-08-02
+COMMISSION
+48,00
+COMA TECHNOLOGY
+INC
+"WILLAMETTE INDUSTRIES INC
+WITH RIGHTS TO PURCHASE PREFRI
+STK UNDER CERTAIN CIRCUMSTANCE
+152000 0-0602
+OMMISSIO
+203,00
+POUNG BAOADCASTING INCOL
+IMMISSIO
+32.00
+SYMBOLGUSIP
+NWAG
+027
+QUANTITY
+5,000
+2,800
+9,000
+2,300
+800
+-4,500
+2,900
+17.88330
+- 3357050
+*10.17250
+40.38700
+39.88120
+7.10720
+• 45.15710
+1,600
+• 1061880
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+89,431.50
+94,012.40
+***91,567.50
+93,043.10
+31967.96
+31,966.92
+131, 156.19
+"29,837.08"
+
+
+15 of 28
+SETTLEMENT TRADE
+01/14/02
+01/08/02 CANCEL SELL
+01714/02 01/08/02 SOLD
+01714702"
+01/09/02
+BOUGH
+01714,02
+01714/02 01/09/02 "BOUGHT
+01714/02
+''*01/09/02
+*'''BOUGHT"
+ADELPHIA BUSINESS SOLUTIONS
+INC CL A
+EXECUTION BY INET
+VS 1227 04-07-98, 950 09-28-00
+, 2800 11-27-01
+100 Me 90 12701
+ADELPHIA BUSINESS SOLUTIONS'
+INC CL A
+EXECUTION BY INET
+VS 1183 04-07-98, 950 09-28-00
+, 1000 09-29-00, 3250 11-16-01
+300 11-20-01, 2800 11-27-0
+RIGINAL S/D 01/11/
+GEORGIA PACIFIC CORF
+WITH RIGHTS TO PURCHASE PREFRO
+EXECUTION BY BUCK CIRCUMSTANCE
+DO 0501-0-02
+150,00
+KOHLS CORP.**
+0 1 3 01 10 20801
+COMMISSION
+SEC FEB
+1.98,00
+"PEREGRINE"SYSTEMS INC****
+(ECUTION BY MOI
+S 1800 01-09-0
+SOLUTIA INC.....
+EXECUTION BY BUCH
+VS 5900 01-09-02
+COMMISSION
+354,00
+SYMBOLCUSP
+ABIZ
+ABIZ
+KSS
+"PRGN
+*Soi
+027
+QUANTITY
+11,527
+0.26980
+- 11,483
+2,500
+1,800
+= 0.26980
+26.38750
+70.27010
+1,800
+5,900
+10.12000
+10.64200
+LEARED THROUGH I
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+2,749.12
+2,738.57
+66,133.75
+26,361.28
+18,231.00
+63,756.80
+
+
+16 of 28
+SETTLEMENT TRADE
+01/14/02
+D7T0902
+0171402 01709/02 "BOUGHT
+01715/02"
+01/10/02
+01715/02
+01710/02
+ö1/15/02
+01710/02
+01715/02 01710/02 SOLD"
+01/15/02
+01710/02
+VITRIA TECHNOLOGY INC
+COM
+EXECUTION BY HRZO
+/S 1200 01-17-01, 500 02-23-01
+SEC FISSION
+135.00
+"VISHAY INTERTECHNOLOGY INC
+112,00
+AMERICAN EAGLE OUTFITTERS INC
+EXECUTION BY RSSF
+VS 900 01-07-02,
+1300 01-03-02
+"CAPSTONE TURBINE CORP
+VS 200 01-10-024
+EASTMAN CHEMICAL CO
+EXECUTION BY MSCO
+/S 1500 12-07-0
+DOMMISSION
+SEC FEE
+95.00
+"MC GLOBAL INC"
+SEE NOTE 'S' ON BACK
+(ECUTION BY BUO
+3400 11-16-01, 400 10-05-0
+DOMMISSION
+SEC FEE
+'KOHLS CORP
+.228,00
+EXECUTION BY BUCK
+VS 500 01-10-02
+COMMISSION
+30,00
+SYMBOLGUSIP
+VITR
+AEOS
+EMN
+"KSS
+027
+QUANTITY
+-1,700
+8.12000
+1,600
+5,600
+21.34810
+28.29130
+2,200
+1,500
+3,800
+500°
+5.48500
+42.95500
+
+68.95000
+LEARED THROUGH I
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+13,703.79
+' 34,283.96
+158,413.90
+12,082.00
+64,311.53
+48,491.64
+34,520.00
+
+
+17 of 28
+SETTLEMENT TRADE
+DATE
+DATE
+01/15/02
+01/10/02
+01715/02 01/10/02 "BOUGHT
+01716/02 01711/02
+• BOUGHT
+01716/02
+'*1714702
+''''SOLD
+01/16/02
+01/11/02
+01/16/02
+
+*SOLD
+81716702 81711702"SOLD
+TIX COMPANIES INC NEW
+EXECUTION BY BUCK
+S 300 01-10-02
+OMMISSIO
+18,00
+TIMBERLAND CO-CLA
+XECUTION BY MLO
+'S 1600 01-10-0
+NOSING
+0021
+SERIAN EAGLE OUTFIES NG
+5 40 0 1 1.02
+FEDERATED DEPARTMENT STORES
+EXECUTION BY BUCK
+VS 200 12-10-01
+OMMISSIO
+C FE
+113.00
+GEORGIA PACIFIC CORP
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY MSCO
+CSMS011-02
+63.00
+"IME GLOBAL INC
+SEE NOTE 'S' ON BACK
+EXECUTION BY MLOO
+VS 2500 10-05-01
+SEC FESSION
+175.00
+ROSS STORES INC
+5540001-08-04
+SEC FEE
+.20
+SYMBOLCUSIP
+TJX
+TBL
+"AEOS
+FD
+"GP
+"ROST
+027
+QUANTITY
+300
+1,600
+1,400
+•200
+900°
+-2,500
+*400
+39.98000
+39.10510
+27.10900
+42.10000
+24.13900
+'12.82200
+- 32.73330
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+12,027.00
+62,695.16
+37,967.60
+8,392.87
+21,803.10
+31,864.5
+'13,078.12
+
+
+18 of 28
+SETTLEMENT TRADE
+DATE
+DATE
+01/16/02
+01711/02
+61/16/02 01711702**BO0GAT
+61/1702 "01/14/02"BOUGHT*•
+01717/02 01/14/02"SOLD
+01717/02
+01/14/02
+01/17/02
+01/14/02
+01718/02 01715/02 "BOUGHT
+01718/02
+
+''BOUGHT
+TUX COMPANIES INC NEW
+EXECUTION BY BUCK
+'S 300 01-08-02
+OMMISSION
+SEC FEE
+118.00
+TIMBERLAND " C8 CLA"
+: 500 01-11-0
+MMISSIO
+55120001-1402
+"ADELPHIA COMMUNICATIONS CORP
+EXECUTION BY JPHO
+SS FEE 11-27-01
+.73
+NO RENS PLACE RETAIL STORES
+45 900 01. 74 н
+EASTMAN CHEMICAL CO
+EXECUTION BY MSOO
+VS 1000 12-07-01
+OMMISSION
+-60.00
+DIMC STRATEX NETWORKS INC
+EXECUTION BY OPOO
+VS 1500 01-15-02
+EXECUTION BY COWN
+VS 700 01-15-02
+LEARED THROUGH I
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+11,796.12
+'19,715.80
+*32,567.04'''
+SYMBOLGUSIP
+QUANTITY
+TJX
+-300
+39.43100
+*500
+0*3334160
+''EOS. 1,20027.12670...
+"ADLAC
+-1,700
+
+"PLCE
+900°
+27.95000
+EMN
+1,000
+41.94660
+1,500
+' 8.35000
+"ENZN
+700
+51.28000
+48,374.77
+25,170.00
+41,860.97
+12,540.00
+35,911.00
+027
+
+
+19 of 28
+SETTLEMENT TRADE
+DATE
+DATE
+01/18/02
+01/15/02
+01718/02 01/15/02 "BOUGHT
+01718/02 01715/02 SOLD"
+01718/02 01/15/02 SOLD
+01/2202
+*01/16/02
+01/22/0207/18/02BOUGH
+01/22/02 01/16/02
+* SOLD
+FOOTSTAR INC
+EXECUTION BY BUCK
+COMMISSON 15-02
+FOOT LOCKER INC
+234,00
+XECUTION BY BUCI
+'S 2600 01-15-0
+COMMISSION
+156,00
+TYCO INTERNATIONAL LED*
+EXECUTION BY INET
+VS 800 03-09-01, 600 04-18-01
+COMMISSION
+28,00
+1.04
+"VISHAY INTERTECHNOLOGY INC
+SEE NOTE "S* ON BACK
+EXECUTION BY FBCO
+VS 1300 01-09-02
+COMMISSION
+SEC FEE
+131.00
+ABELPHIA COMMUNICATIONS CORP
+CLA
+EXECUTION BY SBSH
+VS 10000 01-16-02
+ENON....
+XECUTION BY COW
+S 2000 01-16-0
+"MC TECHNOLOGIES INC
+SEE NOTE "S' ON BACK
+EXECUTION BY BUCK
+VS 860 12-06-01, 2235 11-13-01
+, 1032 11-16-01
+COMMISSION
+SEC FEE
+.317.62
+SYMBOLCUSIP
+FTS
+TYC
+ADLAC
+''''ENZN
+027
+QUANTITY
+3,900
+2,600
+-1,400
+-1,300
+24.04600
+- 15.03680
+- 49.18350
+'19.35000
+10,000
+25.50000
+'2,000
+*********51:54200******
+'4,727**
+=5.02060
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+94,028.40
+39,266.68
+68,812.86
+25,048.62
+255,015.00
+##103,299.00
+61,726.47
+
+
+20 of 28
+SETTLEMENT TRADE
+DATE
+01/22/02
+01/16/02
+61/2202 01716/02***BO0GAT
+
+''0775702*S016
+01722/02 01/16/02
+01122/02
+01716/02
+01722/02
+0176/02
+'SOLD"
+01722702"
+*01716/02
+HONEYWELL INTL INC
+SEE NOTE 'S' ON BACK
+XECUTION BY DBA
+S 1300 01-16-0
+COMMISSION
+91,00
+INTEASIL COAPORATION CL'A"
+(FRM INTERSIL HLG CORP CL-A)
+EXECUTION BY COWN
+VS 3400 01-16-02
+"HARRAHS ENTERTAINMENT INC
+NITH RIGHTS TO PURCHASE PREFRI
+STK UNDER CERTAIN CIRCUMSTANC
+EXECUTION BY DRKW
+VS 1600 11-13-01
+COMMISSION
+SEC FEE
+92.00
+"IMPERIAL CHEMICAL INDS PLC
+ADR NEW
+EXECUTION BY BUCK
+VS 500 10-11-01
+COMMISSION
+SEC FEE
+- 20.00
+.. ...
+1GM MIRAGI
+EXECUTION BY DRKW
+VS 1950 11-13-01
+OMMISSION
+EC. FE
+-336.50
+MANDALAY RESORT GROUP
+EXECUTION BY DRKW
+VS 1950 11-13-01
+COMMISSION
+SEC FEE
+,706.50
+MASCO CORP
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY BUCH
+US MISSIO- 1-02
+108,00
+SYMBOLCUSIP
+HON
+"SIL
+"HET
+MGG
+"MBG
+MAS
+027
+QUANTITY
+1,300
+29.40000
+3,400
+1,600
+600 40.96420
+500
+''23.28230
+-1,950
+-1,950
+1,800
+29.03960
+23.70520
+24-64720
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+38,326.00
+CRECIT AMOUNT
+'104,027:00
+** 65.414.73
+11,595.97
+56.474.87
+46,072.54
+44,487.96
+
+
+21 of 28
+SETTLEMENT TRADE
+DATE
+01/22/02
+01/16/02
+61/2202**01716/02S0LВ
+01/22/02
+'01716/02 "BOUGHT
+Ö1/22/02
+01/16/02
+"SÖLD"
+01/23/02
+01717/02
+*SOLD
+01723/02 07717702 BOUGHT
+ö1723/02 8171702 BOUGHT
+PRAXAIR ING
+SEE NOTE "S' ON BACK
+ECUTION BY MDL
+S 2000 01-16-0
+COMMISSION
+140,00
+"IX COMPANIES INE"NEW**
+S 800 01-08-02
+OMMISSION
+SEC FEE
+119,00
+"TALBOTS ING
+EXECUTION BY BUCK
+/S 1100 01-16-0
+COMMISSION
+66.00
+"TEXTRON INC
+ITH RIGHTS TO PURCHASE PREFF
+TK UNDER CERTAIN CIRCUMSTAN
+EXECUTION BY MLCO
+VS 1100 11-15-01
+SEC MISSION
+-67:00
+BEVERLY ENTERPRISES INC NEW
+EXECUTION BY OPCO
+VS 5000 04-30-01
+COMMISSION
+SEC FEE
+80,000
+FMC CORP NEW"
+SEE NOTE "S' ON BACH
+TS 00017 BUCK
+COMMISSION
+42,00
+HONEYWELL' INT'INC"
+SEE NOTE "S' ON BACK
+EXECUTION BY MLOO
+VS 2000 01-17-02
+COMMISSION
+140,00
+SYMBOLCUSIP
+PX
+TXT
+BEV
+"FMC
+"HON"
+027
+QUANTITY
+2,000
+800
+1,100
+-1,100
+5,000
+700
+2,000
+50.44130
+• 3866430
+35.62831
+39.79140
+7.42500
+31.74240
+2903050"
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+101,037.60
+CRECIT AMOUNT
+30,867.97
+*39,272.14
+43,677.88
+6,809.4
+22,276.68
+58,218:00
+
+
+22 of 28
+SETTLEMENT TRADE
+DATE
+01/23/02
+01717/02
+01723/02 01717/02 "BOUGHT
+61723/02 "01/17/02 SOLD..'
+01723/02
+01/17/02
+01/23/02
+01/1702
+01724/02 01/18/02"SOLD
+01724702"
+01717/02
+IMPERIAL CHEMICAL INDSPLC
+ADR NEW
+EXECUTION BY BUCK
+VS 600 10-11-01
+SOMMNSSION
+36.00
+"LIZ'CLAIBORNE ING
+STK SPLIT ON
+3700 SH$
+REC 12/31/01 PAY 01/16/0
+IS AUTO BY POT, 550 06-15-01
+COMMISSION
+350,00
+SEC FEE
+1,71
+PRAXAIR INC
+SEE NOTES* ON BAC
+EXECUTION BY FBCO
+VS 2000 01-17-02
+OOMMISSION
+140,00
+"SABRE HOLDINGS CORP CLA
+IS TUTO 1 82001, 1600 11-160
+1. 350 17.150
+SEC FEB
+3,50.50
+"CABLEVISION SYSTEMS CORP CLA"
+CABLEVISION NY GROUP CON
+UNSOLICITEC
+ACTUAL ON RN TO TA DE
+EE NOTE 'S' ON BAC
+S OF 01/18/0
+"OM GROUP INC
+SEE NOTE 'S" ON BAC
+XECUTION BY MDL
+AS OF 01/17/02
+SABOUCUSP
+''OCR*****
+TSG
+OMG
+027
+QUANTITY
+-600
+23.27160
+*3,700
+5,000 22.75640
+2,000
+48.67320
+-8,450
+40.27270
+2,800
+''43.15700"
+2,600
+• 59.00000
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+13,911.75
+*773,415.29
+97,501.40
+259,288.52
+"120,641.78
+153,415.00
+
+
+23 of 28
+SETTLEMENT TRADE
+DATE
+01/24/02
+01/18/02
+0172402 01718/02 SOLD"
+PRAXAIR INC
+SEE NOTE 'S' ON BACK
+ECUTION BY BUC
+: 700 01-18-0
+42,00
+*T COMPANIES ING NEW"
+01724002"
+01718/02
+01/25/02 01/22/02 SOLD
+01725/02 01722/02
+0172502 01/22/02
+AS OF 01/18/02
+TOMMY HILFIGER CORP-ORD
+ES 13000B2801, 700 08-17-01
+. 500 11-13-01
+SEC RESONE
+350.00
+AS OF 01/18102
+CABLEVISION SYSTEMS CORP-CLA
+CABLEVISION NY GROUP COM
+UNSOLICITED
+AVG PRICE SHOWN-DETAILS ON RE
+ACTUAL CONFIRM TO YOUR AGEN
+SEE NOTE "S" ON BACK
+GEORGIA PACIFIC CORP*.....
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY BUCK
+VS 2500 01-09-02, 1700 01-08-0
+SOMMISSION
+252,00
+INTERSIL CORPORATION CLA
+SEC 70 01 - 16-02
+SABOUCUSP
+"TIX
+TOM
+"CVC
+027
+QUANTITY
+700
+-1,500
+2,500
+2,200
+49.10000
+39.00000
+14.97300
+43.79550
+4,200
+*21.40290
+1,700
+
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+34,427.00
+58,394 12
+37,266.93
+96,194.65
+
+47,227.29
+
+
+24 of 28
+SETTLEMENT TRADE
+DATE
+01/25/02
+01/22/02
+6172502 01/22/02**"SOLD
+01/2502
+*01/22/02
+''''SOLD
+IMC GLOBAL INC
+SEE NOTE "S' ON BACK
+EXECUTION BY FBCO
+VS 2500 01-22-02
+NOISSIWINOO
+175,00
+"HOSS STORES INC
+XECUTION BY MON
+S 1000 01-08-02
+SEC FEE
+.50
+AS OF 01/22/02
+UNIVERSAL HEALTH SERVICES INC
+EXECUTION BY PHO
+VS 5000 10-17-01
+COMMISSION
+350,00
+SEC FEE
+2.97
+WILLAMETTE INDUSTRIES ING
+WITH RIGHTS TO PURCHASE PREFRD
+STK UNDER CERTAIN CIRCUMSTANCE
+EXECUTION BY BUCK
+VS 2900 01-08-02
+COMMISSION
+SEC FEE
+174,00
+2,40
+01/25/0:
+01/22/02
+TOTAL
+DEPOSITS AND WITHDRAWALS
+DATE
+01/14/02
+CHECK
+ö1/23/02
+"'CHECK*
+FEEST 0110110203/31.02
+BUCKINGHAM CAPITAL MGMT
+PES 1010102-03/31.02
+BUCKINGHAM CAPITAL
+SYMBOLCUSIP
+IGL
+"HOST
+"UHS
+WLL
+QUANTITY
+2,500
+1,000
+-5,000
+2,900
+12.34440
+39.53660
+55.11250
+22,962.72
+"22.962.72
+027
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+31,051.00
+CRECIT AMOUNT
+"32,976.50
+197,315.03
+59,634.85
+$-4,063.544.45
+$2,832,752.33
+
+
+25 of 28
+DEPOSITS AND WITHDRAWALS (continued)
+DATE
+01/23/02
+FUNDS REG
+PEES TAURUIN 033002
+BUCKINGHAM CAPITAL
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+01/01/02
+01/02/02
+REINVEST
+ö1/02/02
+DIMDEND
+OPENINGBALANCE
+DOES PREM PORNOLD
+MONTHLY DIVIDEND REINVESTED
+DOMEST PIE PORTOLO
+AMT INCLUDED IN 2001 - 1099
+01/02/02
+''REINVEST
+MONTHLY DIVIDEND REINVESTED
+01/02/02
+01/03/02
+*SOLD
+ö1/6702*581B
+ö1/0702
+"SOLD"
+Ö1709/02
+'SOLD"
+01/15/02
+AMT INCLUDED IN 2001 - 1099
+DOMEST PRIME MA PORTFOL
+DOES PRIME A PORTFOL
+DOMESTIC PRIME MAM PORTFOLIO
+$-45,925.44
+22,962.72
+$22.962.72
+SYMBOU/CUSIP
+XXа1о.
+*ТЫXX
+"GTXX
+"GIDXX
+QUANTITY
+3,162,235.72
+514.90
+1,367.85
+400,000
+200,000
+-600,000
+700,000
+150,000
+027
+1.0000
+T:0000"
+1.0000
+1.0000
+1.0000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+514.90
+1,367.85
+514.90
+1,367.85
+400,000.00
+200,000.00
+600,000.00
+700,000.00
+150,000.00
+
+
+26 or 28
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+01/17/02
+01/23/02
+'BOUGHT
+01/23/02 DVDEND
+DOES SHREES PRANSLO
+MONTHLY DIVIDEND
+07/23/02 DIVIDEND***
+MONTHLY DIVIDEND
+ö123/02 "REINVEST
+ö1723702 REINVEST
+MONTHLY DIVIDEND REINVESTED
+MONTHLY DIVIDEND REINVESTED
+89/2402***S8LB
+01/25102
+TOTAL
+CLOSINGBALANCE
+DIVIDENDS
+DESCRUPTION
+370202 TEE AT 16002
+1/02/02 TEXTRON...
+TEC 12N401 PAY 010110:
+TOTAL
+SYMBOUCUSIP
+EMN
+SYMBOUCUSIP
+GIDXX
+GHЫXХ
+QUANTITY
+2,500
+4,400
+QUANTITY
+-500,000
+900,000
+147.12
+1,223.83
+- 180,000
+1,715,489.42
+RATE (S)
+0.4400
+0.3250
+027
+1.0000
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+500,000.00
+....
+900,000.00
+147.12
+1,223.83
+147.12
+1,223.83
+1:0000*
+180,800.06
+$2,503,253.70
+$-1,053,253.70
+1,100.00
+1,430.00
+$2,530.00
+
+
+27 of 28
+INTEREST
+DATE
+01/22/02
+INT CR
+TOTAL
+JAN 02
+MISCELLANEOUS
+RADEAN
+01/03/02
+01707702*
+"JOURNAL*"
+01/09/02
+CASH-LIEU
+1/18/0
+CASH-LIEUT
+OFFICE SERVICING YOUR ACOUNT
+SYMBOUCUSIP
+QUANTITY
+RATE (SI
+OFFSET FROM BKD P&L
+*'CASH******•••••••••••••••••**
+MOVE BKD P&L TO BOOKKEEPING
+'*12701 CLA CHE 1
+EMC TECHNOLOGIES INC
+CASH IN LIEU OF .33040
+EM CORP NEW
+© 12/12/01 PAY 12/31/0
+IN-OFF F/R F0063
+ADELPHIA BUSINESS SOLUTIONS
+ING CL A
+ADELPHA OMMUANEATIONS CORE
+5.880.990.54
+•• 35.00
+TOTAL
+$-5,881,025.54
+027
+CRECIT AMOUNT
+5,880,990.54
+5.38
+0.02
+$5,880,995.94
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1, 2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+December 31, 2001
+1,362.25
+$1,362.25
+
+
+28 of 28
+Trades Executed Pending Settlement
+SETLE MENT
+TRTDE
+01/28/02 01/23/02
+BOUGhT"
+01/28/02 01/23/02
+0128/02
+01/23/02
+01/28/02"
+01/23/02
+"BÖUGHT
+01/28/02 01/23/02
+01/28/02
+01/23/02
+......
+01/29/02
+01/24/02
+a.................
+01/29/02
+01/24/02
+anananaananaaıiıınaaaananaaaanaaaaaaagııııaaaan
+01/29/02
+01/24/02
+01/29/02
+01/29/02
+01/29/02
+01/29/02
+...
+01/29/02
+......
+1/29/0
+01/30/02
+01/30/02
+TOTAL
+01/24/02
+01/24/02
+01/24/02
+01/24/02
+01/24/02
+01/24/02
+01/25/02
+01/25/02
+AMERICAN EAGLE OUTFITTERS ING
+NEW
+BEA SYSTEMS INC
+SONERD AORES PIC
+IMC GLOBAL ING"
+SKECHEAS USA INC
+CLA
+VITESSE SEMICONDUCTOR CORP
+CAPSTONE TURBINE CORP**™
+EASTMAN CHEMICAL CO
+IONA TECHNOLOGIES PLC
+SPONSORED ADR
+PEREGRINE SYSTEMS ING
+PRAXAIR INC
+ROSS STORES INC
+ORECHERS USA NC
+TOMMY HILFIGER CORP-ORD
+TRIQUINT SEMICONDUCTOR INC
+ADELPHIA COMMUNICATIONS CORP
+CLA
+GEORGIA PACIFIC CORP
+WITH RIGHTS TO PURCHASE PREFRD
+The above trades do not appear in any other section of this statement.
+SYMBOLCUSIP
+AEOS
+BEAS
+IONA
+*SKX
+VTSS
+CPST
+EMN
+IONA
+PRGN
+PX
+ROS
+SKX
+TOM"
+TONT
+ADLAC
+GP
+027
+QUANTITY
+1,000.00
+1,700.00
+...... .....
+2,700.00
+3,200.00
+1,000.00
+1,700.00
+3,800.00
+.............
+1,700.00
+1,200.00
+3,600.00
+.............
+700.00
+......•
+-400.00
+1,800.00
+2,100.00
+8,500.00
+100.0
+-1,400.00
+27.8650
+19.6772
+22.0375
+12.3869
+- 15.9338
+11.6040
+....
+4.9070
+. . . .
+38.6264
+22.7946
+8.7429
+53.0247
+34.5367
+15.8800
+14.9084
+10.9650
+27.0360
+22.5000
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 1,2002
+THROUGH
+January 25, 2002
+ACCOUNT NUMBER
+TAPAYER NUMBER
+December 31, 2001
+27,880.00
+33,517.24
+......
+59,516.25
+39,877.08
+16,008.80
+19,741.80
+18,661.60
+. . . .
+65,798.88
+.......
+27,368.52
+31,489.4
+37,181.29
+13,799.47
+28,707.00
+31,166.17
+93,217.50
+83,795.34
+31,400.52
+$160,161.50
+$498,965.40
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/dbd89a288b183d42f70f5ba04aacc66008220ddab27c3549d708a3d4ff040c21.receipt.json b/vision-fixhub/ds9-unparsed-05/dbd89a288b183d42f70f5ba04aacc66008220ddab27c3549d708a3d4ff040c21.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6a4ff85c832b24ed2cb1d87701e241de4cf0fc38
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/dbd89a288b183d42f70f5ba04aacc66008220ddab27c3549d708a3d4ff040c21.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -47824,
+  "dataset": "marble-joined",
+  "doc_id": "dbd89a288b183d42f70f5ba04aacc66008220ddab27c3549d708a3d4ff040c21",
+  "engine": "marble-apple-vision",
+  "event_count": 277,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "cd11b99473aef1f7ae4dd9667f28d260a56a8e7ebf5ac63de6bfcf4359770f12",
+  "output_sha256": "054c12b4a41adf5b0e4358eb063296221202374b217aac5199ed18e887582428",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/dbefbe55a282489e8b6a168151cb5af245ea9d4c0b906c02654d8c40e9fd273e.md b/vision-fixhub/ds9-unparsed-05/dbefbe55a282489e8b6a168151cb5af245ea9d4c0b906c02654d8c40e9fd273e.md
new file mode 100644
index 0000000000000000000000000000000000000000..67147eeaff107469eb878ac0412f1f00331dd6c2
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/dbefbe55a282489e8b6a168151cb5af245ea9d4c0b906c02654d8c40e9fd273e.md
@@ -0,0 +1,670 @@
+United States Attorney's Office
+Southern District of Florida
+NEWS BRIEFING
+To:
+, Acting United States Attorney
+Vacant, First Assistant
+Executive Assistant
+_ Special Counsel
+, Chief, Criminal Division
+, Deputy Chief, Criminal Division
+Chief, Appellate Division
+Chief, Asset Forfeiture Division
+1. Chief, Civil Division
+, Chief, PINS
+1. Chief, Narcotics
+. Chief, Economic and Environmental Crimes Section
+, Chief, Major Crimes Section
+, Chief, Special Prosecutions
+, Deputy Chief, Ft. Lauderdale
+Deputy Chief, West Palm Beach
+, Deputy Chief, Ft. Pierce
+From:
+Executive Division
+June 11, 2009
+
+
+Southern District of Florida - Press Release
+The United States Attorney's Office
+Southern District of Florida
+
+Press Release
+MIAMI RETURN PREPARER PLEADS GUILTY TO TAX PREPARATION FRAUD
+SCHEME
+June 10, 2009
+FOR IMMEDIATE RELEASE
+Jeffrey H. Sloman, Acting United States Attorney for the Southern District of Florida, and Daniel W. Auer, Special
+Agent in Charge, Internal Revenue Service, Criminal Investigation Division, announced that defendant
+Beaudelaire Telfort, 37, of Miami, pled guilty today to one count of aiding and assisting in the filing of a false
+tax return, in violation of Title 26, United States Code 7206(2). Telfort remains on bond pending sentencing.
+Sentencing is scheduled for August 19, 2009 at 9:30 AM, before U.S. District Court Judge Cecilia Altonaga. At
+sentencing, Telfort faces up to three years' imprisonment and mandatory restitution.
+According to court documents, Telfort managed his own business, Nation Tax 1, in Miami, where he prepared tax
+returns for other individuals and filed them electronically with the IRS. Telfort received fees in connection with
+the preparation and filing of those returns. On April 24, 2009, a twenty-six count indictment was unsealed
+against the defendant charging him with tax fraud charges. As set forth in the Indictment, Telfort was charged
+with assisting in the preparation of false U.S. Individual Income Tax Returns (Forms 1040) for numerous
+individuals during calendar tax years 2002 and 2003. The tax returns contained false information regarding
+wages, income and withholding amounts. In total, the fraudulent tax filings sought more than $80,061 in
+fraudulent tax refunds.
+During the plea hearing, Telfort admitted to preparing and filing a tax return for a client in which he
+misrepresented the client's wages and income, and the amount of federal taxes withheld. Telfort also admitted to
+filing a fictitious W-2 form with said return, which suggested that the client had worked for a second employer
+and earned a salary working for that employer. The material misrepresentations resulted in a claimed tax refund
+that was significantly greater than what the client was legitimately entitled to receive.
+Mr. Sloman commended the investigative efforts of the Internal Revenue Service, Criminal Investigation Division.
+This case is being prosecuted by Assistant United States Attorney Joseph B. Shumofsky.
+A copy of this press release may be found on the website of the United States Attorney's Office for the Southern
+District of Florida at http://www.usdoj.gov/usao/fls. Related court documents and information may be found on
+the website of the District Court for the Southern District of Florida at http://www.flsd.uscourts.gov or on
+http://pacer.flsd.uscourts.gov.
+Technical comments about this website can be e-mailed to the Webmaster. PLEASE NOTE: The United States
+Attorney's Office does not respond to non-technical inquiries made to this website. If you wish to make a request
+for information, you may contact our office at 305-961-9001, or you may send a written inquiry to the United
+States Attorney's Office, Southern District of Florida, 99 NE 4th Street, Miami, Fl. 33132.
+http://www.usdoj.gov/usao/fls/PressReleases/090610-01.html
+
+
+Campos, Cyndee (USAFLS)
+Subject:
+FW: Article - South Florida Business Journal
+Wednesday, June 10, 2009, 3:31pm EDT | Modified: Wednesday. June 10, 2009. 3:38pm
+Tax preparer pleads guilty to fraud
+South Florida Business Journal
+The ser a a la reparation busten pleaded my ladnesday lo one count tax fraud, coring o a news.
+In April, Beaudelaire Telfort, 37, was hit with a 26-count indictment in which he was charged with assisting in the
+preparation of fake tax returns for clients in 2002 and 2003 totaling $80,061.
+Telfort, who owned Nation Tax 1, admitted to misrepresenting a client's wages and income and to filing a fictitious W-2
+Telfort face up to three years in prison and restitution. Sentencing is set for Aug. 19.
+Jennifer Wroblewski
+Special Agent / Alternate Public Information Officer
+Internal Revenue Service, Criminal Investigation
+Office: 954-423-7897
+Cell: 305-986-9485
+Fax: 954-423-7888
+
+
+Campos, Cyndee (USAFLS)
+Subject:
+FW: NEWS RELEASE: TWO JAMAICAN NATIONALS, INCLUDING JAMAICAN FUGITIVE,
+CAPTURED AND CHARGED ON IMMIGRATION CHARGES
+June 10, 2009
+NEWS RELEASE:
+TWO JAMAICAN NATIONALS, INCLUDING JAMAICAN FUGITIVE,
+CAPTURED AND CHARGED ON IMMIGRATION CHARGES
+Jeffrey H. Sloman, Acting United States Attorney for the Southern District of Florida, and
+Anthony _. Mangione, Special Agent in Charge, U.S. Immigration and Customs Enforcement, Office
+of Investigations, announced the arrest of defendant Omar Oneal Lewis, 33, a Jamaican national
+wanted by the Jamaican government as one of their 10 "most wanted" fugitives in connection with a
+Lewis was arrested on June 8, 2009, by ICE special agents in Miami, working with the
+Lauderhill Police Department. Lewis was considered the 6th most wanted fugitive in Jamaica. ICE
+agents also arrested Michael Montaque, 25, also a Jamaican national. Both men were residing in
+the South Florida area and both were charged with having illegally re-entered the U.S. after having
+been deported. If convicted, Lewis faces up to two years in prison and Montaque faces up to 10
+years in prison.
+Acting U.S. Attorney Sloman stated, "Foreign fugitives cannot run and hide on our soil for long.
+Thanks to the outstanding work of ICE and the Lauderhill Police Department, one such fugitive will be
+brought to justice."
+"I'm proud of the hard work and diligence of our special agents for tracking down and
+apprehending these criminals," said Anthony Mangione, Special Agent in Charge of the ICE Office of
+Investigations in Miami. "Apprehending dangerous foreign fugitives hiding in the United States is a
+top priority of ICE and now, not only has this illegal alien been removed from the streets of South
+Florida, but he will eventually be removed from the United States to face justice in Jamaica."
+Mr. Sloman commended the investigative efforts of ICE's Office of Investigations in Miami and
+the Lauderhill Police Department.
+. This case is being prosecuted by Special Assistant United States
+Attorney Lorraine Tashman.
+A copy of this press release may be found on the website of the United States Attorney's Office
+for the Southern District of Florida at http://www.usdoj.gov/usao/fls. Related court documents and
+information may be found on the website of the District Court for the Southern District of Florida at
+http://www.flsd.uscourts.gov.or on http://pacer.flsd.uscourts.gov.
+1
+
+
+Jamaican fugitive faces immigration charges - 06/10/2009 - MiamiHerald.com
+
+The THiami Herald I
+Posted on Wed, Jun. 10, 2009
+Jamaican fugitive faces immigration charges
+The Associated Press
+Authorities in South Florida say they've captured a Jamaican fugitive connected to a 2008 homicide.
+The U.S. Attorney's Office reports that Immigration and Customs Enforcement agents arrested 33-year-old
+Jmar Uneal Lewis Monday in Miami. Officials say Lewis is considered the sixth most wanted fugitive ir
+Jamaica. At the same time. ICE agents also arrested 25-vear-old Michael Montaque
+Both men have been charged with illegally re-entering the U.S. after being deported. Under U.S. law, Lewis
+faces up to two years in prison and Montaque, a convicted felon, faces up to 10.
+Besides the charges they face in the U.S., ICE officials say they will eventually be deported and will likely face
+additional charges in Jamaica.
+© 2009 Miami Herald Media Company. All Rights Reserved.
+http://www.miamiherald.com
+http://www.
+html
+
+
+Suspected killer wanted in Jamaica arrested in Lauderhill -- South Florida Sun-Sentinel.com
+sun-sentinel.com/news/local/breakingnews/sfl-lauderhill-fugitive-arrest-b061009,0,4655364.story
+
+South Florida Sun-Sentinel.com
+Suspected killer wanted in Jamaica arrested in Lauderhill
+By Joel Marino
+SunSentinel.com
+7:01 PM EDT, June 10, 2009
+LAUDERHILL
+One of Jamaica's most wanted criminals - an accused killer who
+goes by the street name "King of Evil" - was arrested in Lauderhill
+on Monday by police and U.S. Immigration and Customs
+Enforcement agents.
+i The page cannot be displayer
+There is a problem with the page you are trying to rea
+be displayed.
+Omar Oneal Lewis, 33, was charged with illegally re-entering the
+country after having been deported. Lewis was deported to Jamaica
+in 2006 and should not have been living in Florida, according to
+court records.
+Please try the following:
+Jamaican authorities have been looking for Lewis since 2008, when
+they say he killed a man named Richard Reid that June, according to
+the Jamaica Constabulary Force. He was placed on a top 10 most
+wanted list by Jamaica's law enforcement agencies. Details of that
+case were not immediately available.
+• Open the view.atdmt.com home page, and the
+to the information you want.
+• Click the Refresh button, or try again later.
+• Click Search to look for information on the
+• You can also see a list of related sites.
+Copyright © 2009, South Florida Sun-Sentinel
+http://www.sun-sentinel.com/news/local/breakingnews/sfl-lauderhill-fugitive-arrest-b061009,0,18476...
+
+
+Jamaican fugitive faces immigration charges
+PalmBeachPost.com / Search
+One-Stop Hurricane Shopping
+
+EXPORM
+Register Now | Log In
+Jobs
+Autos
+Real Estate
+Classifieds
+Home
+News
+Weather
+Sports
+Health
+Business
+Place An Ad
+Obituaries Opinion
+Living
+Entertainment
+Photos
+Video
+Blogs
+Services
+Jamaican fugitive faces immigration charges
+MIAMI — Authorities in South Florida say they've captured a Jamaican fugitive connected to a 2008 homicide.
+The U.S. Attorney's Office reports that Immigration and Customs Enforcement agents arrested 33-year-old Omar
+Oneal Lewis Monday in Miami. Officials say Lewis is considered the sixth most wanted fugitive in Jamaica. At the
+same time, ICE agents also arrested 25-year-old Michael Montaque.
+Both men have been charged with illegally re-entering the U.S. after being deported. Under U.S. law, Lewis faces
+up to two years in prison and Montaque, a convicted felon, faces up to 10.
+Besides the charges they face in the U.S., ICE officials say they will eventually be deported and will likely face
+additional charges in Jamaica.
+June 10, 2009 - 6:37 p.m. EDT
+Copyright 2009, The Associated Press. The information contained in the AP Online news report may not be
+published, broadcast or redistributed without the prior written authority of The Associated Press.
+ONE-STOP
+Hurricane Shopping
+Shutters • Generators • Supplies • More
+Win a Free Generator - Find Out How!
+stormexpo2009.com
+XPL
+Featured Motorcycles
+Honda Shadow
+Aero 750cc '06. Kept indoors. Exc., Lik...
+Harley Davidson
+http://www.palmbeachpost.com/search/content/gen/ap/FL_Jamaican_Fugitive.html
+
+
+JUN.11.2009
+10:03AM
+USAO WPB FL
+NO.797
+P.1
+THE PALM BEACH POST
+THURSDAY, JUNE 11, 2009
+Judge delays ruling on request
+to unseal plea deal in sex case
+Past Staff Writer
+wraing Subat to un at lead treated like
+WEST PALM BEACH - A seal the deal that Epstein
+Epstein, 56, a reporter
+circuit judge on Wednes- brokered with
+federal money manager of billion
+day, did not unseal the
+prosecutors. A lawyer for
+aires, is currently serving
+deal that money manager
+The Palm Beach Post also
+an 18-month sentence in
+Jeffrey Epstein of Palm
+has joined in the request.
+the Palm Beach County
+Beach struck with fed-
+"Its a secret agree-
+Stockade after pleading
+eral prosecutors to avoid
+ment. A secret, sweetheart
+guilty nearly a year ago
+charges,
+opting instead
+agreement." said former
+1n
+state court to felony
+to give Epsteins lawyers
+Circuit Judge Bill Berger,
+solicitation of prostitution
+a chance to
+who now represents sotne
+and procuring teenagers
+demonstrate
+of the women.
+for prostitution
+why it should
+"Everybody
+WES
+in
+The saga began year
+remain
+den
+hidon this deal except the
+ago when the Palm Beach
+from
+victims and the public,"
+Police Department began
+public view.
+Berger sald. "The public
+investigating
+whether
+Circuit
+should be outraged it has
+young worrien were be-
+Judge Jeff
+Epstein
+gone as far as it has."
+brought to Epstein's
+Colbath
+a0-
+A
+second attorney
+mansion on El Brillo Way
+knowledged at a hearing
+representing the women,
+to massage him and have
+that Epstein's deal was not
+Brad Edwards, has seen
+sex with him in exchange
+sealed in state court in acthe sealed document A
+for money.
+cordance with the rules.
+federal judge allowed him
+Epstein's
+attorneys,
+"I don't see where any
+and his clients to view it,
+in federal filings,
+of the procedures were
+but not to discuss its conhave
+referred to sealed docuever followed," he said.
+tents.
+ments as a deferred pros-
+Colbath
+has
+given
+Edwards
+Epstein's defense attorney,
+vomen were "outraged" at federal prosecutors an
+Jack Goldberger, an op
+what had been negotiated have called it
+sealed and asked lawyers
+to submit briefs to him by
+full tories for bune 25.
+"Are you kidding? It's @ susan_spencer.
+Attorneys
+young transparent. Certainly no wendel@pbpost.con
+
+
+Miami skipper in lobster poaching case can't fish for two years
+
+GE PRINTTHIS
+PalmBeachPost.com
+Miami skipper in lobster poaching case can't fish for two
+years
+By BRITTANY LEVINE
+The Miami Herald
+Thursday, June 11, 2009
+Two more of the six defendants in one of the largest lobster-poaching cases in the Florida Keys
+were sentenced Wednesday.
+Robert Hammer, a well-known Miami charter boat captain and
+Post your principal figure in the case, was sentenced to two months in prison, six months of house
+POSt comments arrest and placed on two years of probation. During his probation, the 45-year-old is
+banned from fishing commercially or for pleasure near South Florida waters.
+story below
+More Florida news
+Latest state headlines
+P.B. County, TCoast
+news
+Special reports
+Weather | Traffic |
+Obituaries
+Sean Reyngoudt of Summerland Key, an aspiring professional kite surfer with a
+prosthetic leg who played a minor role in the poaching, got four years of probation. He,
+too, was banned from fishing.
+The two were charged in a federal grand jury indictment last year with the illegal harvest
+of about 6,000 lobsters from man-made habitats called casitas placed in the Florida Keys
+National Marine Sanctuary. The lobsters were stored in a freezer at the million-dollar
+home of the scheme's kingfish, David Dreifort, 41.
+Dreifort, a commercial fisherman — who Hammer called the "largest lobster poacher in the Keys" in court
+documents — and his wife, Denise, are scheduled for sentencing July 17. Both could face a maximum of five years
+in jail and a $250,000 fine.
+Using casitas to harvest lobsters dirties the ocean and could have a negative effect on lobster migration and
+reproduction, wildlife experts said.
+Hammer said he plans never to fish again. He has sold his boat and will work for his wife's company, Humane
+Animal Removal, after serving his time. He will most likely serve the prison time at a South Florida facility close to
+his wife and children.
+Reyngoudt, 25, said getting involved with Dreifort was "the worst choice I've ever made in my life" and plans to
+continue kite surfing.
+The first of five to plead guilty, John Niles, 50, of LaBelle, was spared jail time in return for his cooperation. In
+April, Michael Delph, 39, of Key West - son of legendary charter boat captain Ralph Delph and the only one to
+http://palmbeachpost.printthis.clickability.com/pt/cpt?action=cpt&title=Miami+skippertin+lobster+p... 6/11/2009
+
+
+Miami skipper in lobster poaching case can't fish for two years
+
+plead not guilty — was sentenced to 10 months in prison.
+The six were arrested in August on opening day of lobster season after federal agents caught all, minus Reyngoudt,
+returning to Dreifort's Cudjoe Key home with 922 lobsters. Agents called the case Operation Freezer Burn.
+Find this article at:
+http://www.palmbeachpost.com/localnews/content/state/epaper/2009/06/11/0611_lobster.html
+• Check the box to include the list of links referenced in the article.
+http://palmbeachpost.printthis.clickability.com/pt/cpt?action=cpt&title=Miami+skipper+in+lobster+p...
+
+
+Miami skipper in lobster poaching case can't fish for two years - 06/11/2009 - MiamiHerald.com
+
+The THiami Herald H
+Posted on Thu, Jun. 11, 2009
+Miami skipper in lobster poaching case can't fish for two years
+BY BRITTANY LEVINE
+blevine@MiamiHerald.com
+Two more of the six defendants in one of the largest lobster-poaching cases in the Florida Keys were sentenced
+Wednesday.
+Robert Hammer, a well-known Miami charter boat captain and principal figure in the case, was sentenced to
+two months in prison, six months of house arrest and two years of probation. During his probation, the 45-yearold is banned from fishing commercially or for pleasure near South Florida waters.
+Sean Reyngoudt of Summerland Key, an aspiring professional kite surfer with a prosthetic leg who played a
+minor role in the poaching, got four years of probation. He, too, was banned from fishing.
+The two were charged in a federal grand jury indictment last year with the illegal harvest of about 6,000 lobsters
+from man-made habitats called casitas placed in the Florida Keys National Marine Sanctuary. The lobsters were
+stored in a freezer at the million-dollar home of the scheme's kingfish, David Dreifort, 41.
+Dreifort, a commercial fisherman -- who Hammer called the "largest lobster poacher in the Keys" in court
+documents -- and his wife, Denise, are scheduled for sentencing July 17. Both could face a maximum of five
+years in jail and a $250,000 fine.
+Using casitas to harvest lobsters dirties the ocean and could have a negative effect on lobster migration and
+reproduction, wildlife experts said.
+Hammer said he plans never to fish again. He has sold his boat and will work for his wife's company, Humane
+Animal Removal, after serving his time. He will most likely serve the prison time at a South Florida facility
+close to his wife and children.
+Reyngoudt, 25, said getting involved with Dreifort was "the worst choice I've ever made in my life" and plans to
+continue kite surfing.
+The first of five to plead guilty, John Niles, 50, of LaBelle, was spared jail time in return for his cooperation. In
+April, Michael Delph, 39, of Key West -- son of legendary charter boat captain Ralph Delph and the only one to
+plead not guilty -- was sentenced to 10 months in prison.
+Thynix were rested in Argue on Coperi day or bite 2a0 alter eat and a a al ration
+© 2009 Miami Herald Media Company. All Rights Reserved.
+http://www.miamiherald.com
+
+
+Feds get tough on mortgage fraud - 06/11/2009 - MiamiHerald.com
+
+Che THiami Herald H
+Posted on Thu, Jun. 11, 2009
+Feds get tough on mortgage fraud
+By MONICA HATCHER
+McClatchy Newspapers
+To neighboring residents, the string of rapid-fire sales at a Coral Gables home was emblematic of the cause and
+consequences of South Florida's housing bust. The four-bedroom house, now vacant and deteriorating, was sold,
+bought and foreclosed on three times in less than three years.
+Neighbors always suspected "something wasn't right with the milk" at 330 Alesio Avenue as the value of the
+home more than doubled to $1.2 million in the short time span. It turns out they were on to something.
+Last week a federal judge sentenced Jose G. Martin, who had once posed as a renter in the home, to 65 months
+in prison for orchestrating a $6.6 million mortgage fraud scheme involving the Alesio property and six other
+homes in Miami-Dade County.
+In all, prosecutors say he pocketed S1 million - $450,000 alone from his machinations at 330 Alesio. He used
+the money to pay off co-conspirators and enrich himself.
+Martin's sentence, which came on Wednesday, is a sign the federal government is taking a tougher stance
+against people who commit mortgage fraud - a crime once so pervasive that it played a role in bringing about
+the current economic crisis.
+Average sentences for mortgage fraud convictions have increased from 24 months since 2004 to between 50 and
+55 months currently, according to Rachel Dollar, a California-based attorney who specializes in fraud recovery
+litigation.
+And, they're expected to soon get harsher. Last month, Congress passed new legislation strengthening
+prosecutors' ability to fight fraud and promised new funding for more agents, analysts and investigators.
+TASK FORCE
+It also created a nationwide mortgage fraud task force modeled after a task force in Miami-Dade County, where
+mortgage scammers such as Martin ran amok during the housing boom.
+Despite his stiff sentence, the Alesio neighbors said it wasn't long enough - considering the harm mortgage
+fraud has done to South Florida's housing market and the national economy.
+"I'm happy someone got punished for it, but maybe they didn't go up high enough. It's criminal what the banks
+and mortgage companies were allowed to get away with," said Fred Hermes, who lives across the street.
+Yolanda Feanny, a few doors down, also blamed the banks for allowing Martin to so easily rip them off.
+But now lenders are subjecting loans to rigorous underwriting in an effort to fight fraud and avoid future losses.
+The message currently telegraphed is that people who committed mortgage fraud during the boom should be
+expecting a knock on their doors, said Michael Sichenzia, president of Deerfield Beach-based Dynamic
+Consulting, a loss mitigation and real estate analytics firm.
+
+
+Feds get tough on mortgage fraud - 06/11/2009 - MiamiHerald.com
+'CLEAR MANDATE'
+
+"Law enforcement has been given a clear mandate to go after mortgage fraud and prosecute people to the fullest
+extent of the law," Sichenzia said. "This is going to be like the war on drugs 20 years ago because the
+government has to send a message that this will not be tolerated."
+Eric Bustillo, who heads the economic crimes section for the U.S. attorney's office in Miami, said the office
+began attacking the problem early. In 2007, it joined forces with state law enforcement to step up investigations
+and prosecutions. Then, last year, it formed a separate strike force of teams from other federal agencies to
+enhance efforts.
+In two years, the office has charged 176 people with mortgage fraud, convicting 120 of them. But with new,
+labor-intensive cases pouring in almost daily, Bustillo said the office is asking for more resources to tackle
+pending investigations, which have exploded by 600 percent.
+As for the house at 330 Alesio Avenue, neighbors said they suspected wrongdoing for a long time. "It just kept
+changing hands," said Linda Marquis, who lives across the street with her husband, Fred Hermes.
+Martin, prosecutors said, was running a classic straw borrower scheme, in which he recruited and paid
+thousands of dollars to three stand-in buyers to purchase 330 Alesio and other homes in Miami using fraudulent
+papers. Few, if any, payments were ever made on the loans that totaled $6.6 million, and $2.6 million for the
+Alesio home.
+As soon as the properties entered foreclosure, Martin would arrange the next bogus sale. At each closing, he
+collected on phony invoices for construction work that was never done by his company, Old Martin
+Construction.
+Raphael Piedra and Jose D. Martinez, two of the alleged straw borrowers, also have been charged, but remain
+fugitives. A third straw borrower, Samuel Morejon pleaded guilty and was sentenced to 27 months in jail.
+"Fraud was everywhere you turned," said Sichenzia, who himself served three years in federal prison for
+mortgage securities fraud between 2003 and 2005, but now helps law firms and lenders ferret out malfeasance.
+"If I look at 100 transactions month, 90 percent of them have one aspect or more of a misrepresentation in the
+documents," he said.
+The house at 330 Alesio doesn't appear to be worth anywhere near its last sale price of S1.2 millon. The lawn is
+overrun with weeds. Thieves long ago stripped the place of its appliances and fixtures.
+"My handyman was here and he said he wouldn't give them more than $200,000 for it, it's going to need so
+much work," Marquis said.
+© 2009 Miami Herald Media Company. All Rights Reserved.
+http://www.miamiherald.com
+
+
+2 in St. Lucie County arrested in counterfeiting scheme : TCPalm.com
+TCPALM
+FLORIDAS TREASURE COAST AND PALM BEACHES
+PRINTER FRIENDLY ST-IRY
+READ MORE AT WWW.TCPALM.COM
+2 in St. Lucie County arrested in counterfeiting
+scheme
+By The Palm Beach Post
+Wednesday. June 10. 2009
+FORT PIERCE — It wasn't burnt breakfast St. Lucie County Sheriff's Office detectives
+smelled Tuesday morning when they knocked on the apartment door in the 6500 block
+of Yedra Avenue.
+Instead, it was burnt counterfeit money, and Brenda Hopkins, 46, and Ronald Jensen,
+51, are facing charges of counterfeiting money and possessing the tools for
+counterfeiting money, a news release from the Sheriff's Office states. Jensen faces an
+additional charge for destroying evidence.
+About 7:44 a.m. Tuesday, Sheriff's Office detectives and U.S. Marshals were serving a
+felony petit theft arrest warrant for Hopkins, when she ran out of the back sliding door
+and was caught by law enforcement officers, the arrest affidavit states.
+After entering the apartment, a detective smelled an odor and heard Jensen making
+noises in the bathroom. The detective found burnt $20 bills inside the toilet bowl and a
+stack of folded $20 bills on the back of the toilet, the news release states. Detectives
+found at total of $1,680 in counterfeit $20 bills, $43 in bleached $1 bills, and one
+bleached $5 bill, the release states.
+Jensen and Hopkins have requested an attorney, the release states. As of Wednesday
+afternoon, Hopkins was in St. Lucie County Jail in lieu of $41,000 bail, jail records
+show. Jensen was released on $15,000 bail on Tuesday evening, jail records show.
+Click here to read the full article »
+
+© 2009 Scripps Treasure Coast Newspapers
+http://www.tcpalm.com/news/2009/jun/10/2-st-lucie-county-arrested-counterfeiting-scheme/?printer=1/ 6/11/2009
+
+
+
+ShareThis Reprints & Permissions Print
+Federal Vacancies
+Women, minorities apply in record numbers, spurred by the Obama factor
+June 11, 2009
+By: John Pacenti
+he sea change in the White House seemed to signal to women and minority lawyers in South
+in the Obama administration.
+Hispanic and black candidates populate both lists, and women make up half
+Web Extra:
+List of applicants
+of the 20 applicants vying for the seat vacated when U.S. District Judge
+Daniel T. K. Hurley in West Palm Beach took senior status in February.
+Gregory Samms, a black attorney who runs a Coral Gables law firm, said Obama's victory in
+November encouraged qualified minority candidates to believe they would be evaluated fairly.
+"Before, we couldn't even get on the field. Now, we feel at least we can get on the field," Samms said.
+"I think the fact Obama was successful is encouraging more minorities to apply for these positions."
+The diversity of applicants comes after criticism of the makeup of the Federal Judicial Nominating
+Commission for a lack of women and minorities.
+Attorney Marva Wiley, president of the Gwen S. Cherry Black Women's Bar Association, said she is
+happy to see the attention paid to the commission's makeup didn't discourage women or minorities
+from applying
+RELATED STORIES -
+I leseralbeney and
+federal bench
+applicants
+"It's a good sign people feel the process is going to merit their participation," Wiley said. "Sometimes
+people take themselves out of the game early because of what they perceive issues to be. It is encouraging to see that they put their
+names in the hat to see what the outcome will be."
+The JNC will cut the list of applicants for individual public interviews set for mid-July. Three names for each position will be forwarded
+to Democratic U.S. Sen. Bill Nelson, who will recommend a nominee to Obama after another round of interviews.
+"We are talking about a district which has never had an African-American U.S. attorney, a district - with an exception of a temporary
+appointment — that has never had a woman as a U.S. attorney," said Guy Lewis, a former U.S. attorney who is now a partner with
+Lewis Tein in Miami. "You look at the minority candidates, and they are strong candidates — former and current partners and judges."
+Among the minority applicants to succeed U.S. Attorney Alex Acosta are three black judges: Broward Circuit Judge Ilona Holmes, head
+of the criminal division; Miami-Dade Circuit Judge Daryl Trawick; and Palm Beach County Court Judge Reginald Corlew. Hispanics
+Wilfredo Ferrer, an assistant Miami-Dade County attorney, and Lilly Ann Sanchez, a criminal litigator with Fowler White Burnett in Miami,
+also have put their names in the hopper.
+"It's great there is such diversity in the applications we are seeing this year," said Charles Lichtman, an attorney with Berger Singerman
+and legal counsel for the Florida Democratic Party. "There are certainly terrific minority candidates and female candidates and to be sure
+male candidates. I see it extremely difficult to pare the list down."
+Roland Sanchez-Medina, president of the Cuban American Bar Association, agreed the Obama factor appears to be encouraging
+minorities to apply. "Listen, there's an African-American man in the White House now," he said.
+Obama has made diversity a priority in his appointments. He most recently selected federal judge Sonia Sotomayor for the U.S.
+Supreme Court. If confirmed by the Senate, she will become the first Hispanic on the high court.
+Earlier this month, Acosta accepted the dean position at Florida International University's law school in Miami. The Republican
+appointee knew his time was limited when Obama was elected. New presidents normally pick their own U.S. attorneys, especially when
+the party in office changes.
+Federal prosecutor Jeffrey Sloman, Acosta's top assistant, has stepped in as interim U.S. attorney to run the 284-attomey district
+stretching from Key West to Fort Pierce. Sloman applied to become Acosta's permanent replacement along with 15 others
+*There is no more important district in the United States in terms of the types of cases, the number of cases," Lewis said of the Southern
+District. "L.A. and New York may try to steal the thunder nationally, but the truth is Miami is absolutely the World Series."
+Attorney Lisa Lehner, a board member of the Miami-Dade chapter of the Florida Association for Women Lawyers, said she was
+impressed three women applied for the U.S. attorney position.
+*This is probably the first I've seen this number of women apply for the U.S. attorney's office," she said. "Women feel they actually have
+a shot at that one. There never has been a women in that position, and from what I understand, from what I hear, what I feel, that spot
+has opened for women."
+The 20-candidate list to replace Hurley is made up mostly of minorities and women.
+Federal Public Defender Kathleen Williams, U.S. Magistrate Robin Rosenbaum and Miami-Dade Circuit Judges Mary Barzee Flores are
+among the female contenders.
+http://www.dailybusinessreview.com/news.html?news_id=55550&stripTemplate=/
+
+
+
+Some of the minority applicants vying for the bench include U.S. Magistrate Patrick A. White and Miami-Dade Circuit Court Judges
+Darrin Gayles and Jerald Bagley, who are black; Miami-Dade Circuit Judges Maria D. Ortiz and Peter R. Lopez; and Assistant U.S.
+Attorney Ana Maria Martinez.
+President Bush appointed the last federal judge to the South Florida bench in 2004. Marcia Cooke, a former federal magistrate in Detroit
+with strong ties to Jeb Bush, became the first black woman appointed a federal judge in the state.
+Even though it's important to get minority and women candidates in the mix, Lehner said qualifications matter most.
+These are two very important positions. The selection should be on merit. Nobody is saying the senator or the president should mak
+he ultimate selection based on what group somebody fits in. That is not what this is all about. This is about the best person for the job,
+Wiley said she remains "cautiously optimistic" as the selection process begins.
+"Folks don't want to get too confident before giving the process a chance to work itself and prove its validity," she said
+John Pacenti can be reached at (305) 347-6638.
+Former U.S. Attorney's for The Southern District of Florida:
+William Allison McArea - May 1828 - April 1829
+John G. Stower - April 1829 - April 1830
+John K. Campbell - April 1830 - May 1830
+Edward Chandler - May 1830 - Oct. 1834
+Adam Gordon - Oct. 1834 - Dec. 1834
+Wylie P. Clark - Dec. 1834 - June 1835
+William Marvin - June 1835 - March 1839
+Charles Walker - March 1839 - July 1840
+L. Windsor Smith - July 1840 - Aug. 1842
+W. Macrae - Aug. 1842 - March 1847
+L. Windsor Smith - March 1847 - Aug. 1850
+William R. Hackley - Aug. 1850 - March 1858
+John L. Tatum - March 1, 1858 - April 1861
+Thomas Jefferson Boynton - April 5, 1861 - Oct. 1863
+Homer G. Plantz - Oct. 1863 - Dec. 1869
+Claiborn R. Mobley - Dec. 1869 - Aug. 1876
+John Tyler - Aug. 1876 - Nov. 1877
+B. Patterson - Nov. 1877 - March 1886
+Livingstone W. Bethel - March 1886 - April 1890
+G. Browne Patterson - April 1890 - July 1894
+Owen J.H. Summers - July 1894 - Aug. 1894
+Frank Clark - Nov. 1894 - July 1897
+Joseph N. Stripling - July 1897 - Dec. 1905
+http://www.dailybusinessreview.com/news.html?news_id=55550&stripTemplate=l
+
+
+
+John M. Cheney - Dec. 1905 - Oct. 1912
+Richard P. Marks - Oct. 1912 - June 1913
+Herbert S. Phillips - June 1913 - Oct. 1921, June 1936 - Aug. 1953
+William M. Gober - Nov. 1921 - April 1929
+Wilburn P. Hughes - April 1929 - July 1933
+John W. Holland - July 1933 - June 1936
+James I. Guilmartin - Aug. 1953 - Dec. 1959
+E. Coleman Madsen - Dec. 1959 - April 1961
+Edward G. Boardman - April 1961 - Oct. 1962
+Edith House - Nov. 1962 - June 1963
+William A. Meadows Jr. - June 1963 - Dec. 1969
+Michael J. Osman - Dec. 1969
+Robert W. Rust - Dec. 1969 - June 1977
+Vincent K. Antle - June 1977 - Sept. 1977
+Jacob | Eskenazi - Sept. 1977 - March 1980
+Atlee W. Wampler III - March 1980 - March 1982
+Stanley I. Marcus - April 1982 - Aug. 1985
+Leon B. Kellner - Aug. 1985 - June 1988
+Dexter W. Lehtinen - June 1988 - Jan. 1992
+James G. McAdams - Jan. 1992 - May 1992
+Roberto Martinez - May 1992 - Sept. 1993
+Kendall B. Coffey - Oct. 1993 - May 1996
+William A. Keefer - June 1996 - Aug. 1997
+Thomas E. Scott - Aug. 1997 - May 2000
+Guy A. Lewis - June 2000 - Aug. 2002
+Marcos D. Jimenez - Aug. 2002 - June 2005
+R. Alexander Acosta - June 2005 - June 2009
+Your Name:
+Comments:
+Type your comment here.
+Submit This Form
+Search the archive for more stories.
+Clear Form
+http://www.dailybusinessreview.com/news.html?news_id=55550&stripTemplate=l
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/dbefbe55a282489e8b6a168151cb5af245ea9d4c0b906c02654d8c40e9fd273e.receipt.json b/vision-fixhub/ds9-unparsed-05/dbefbe55a282489e8b6a168151cb5af245ea9d4c0b906c02654d8c40e9fd273e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e805a0ad8bf261d0967bd94b344b1d20101c106e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/dbefbe55a282489e8b6a168151cb5af245ea9d4c0b906c02654d8c40e9fd273e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -468,
+  "dataset": "marble-joined",
+  "doc_id": "dbefbe55a282489e8b6a168151cb5af245ea9d4c0b906c02654d8c40e9fd273e",
+  "engine": "marble-apple-vision",
+  "event_count": 36,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "aa4cc79a40759766d87fa7f93db1eddea50b49be36f9c0f89d4cd8c9ec3fe06d",
+  "output_sha256": "5ae408d953c558c68e682b84e30b27023c2a8d004c2fd4296d0c500a335c0870",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/dbf461940624d2b096ad4308d9fe420387fec180b21d3765447e85caaff03ed4.md b/vision-fixhub/ds9-unparsed-05/dbf461940624d2b096ad4308d9fe420387fec180b21d3765447e85caaff03ed4.md
new file mode 100644
index 0000000000000000000000000000000000000000..3f542efe10b47ddebb6fe473f704e908a0d50c79
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/dbf461940624d2b096ad4308d9fe420387fec180b21d3765447e85caaff03ed4.md
@@ -0,0 +1,299 @@
+
+Ir. Karin or
+Pourteau
+Mr. Beislan cell
+r: bimenichini
+Mr. Lafond(a/c,
+Let Pasquer
+Mr Santos
+Exporton, Marle Joseph
+Hotel Crillon
+Hotel Raffael
+Junot, Philipne
+Gerard
+Belgian Cet
+French Cet-
+Berfioz
+L'Amijean
+Berlioz France
+Lua co vaoe
+L'Are
+Rut Pulsite
+Now Porktle
+бете
+Le Voltaire
+Madame Lemercier
+La Merlot
+Rue de la cherche midi
+a Poste
+Massage - Parls
+Claudia Hadida
+Stephane Couladx
+Stephane Coulande
+Geraldine Talavera
+TIn ENR3HI
+massarn
+
+Massage A - Island
+Grapevine Salon
+Moseley, Brian
+Roberts, Theresa
+Shomar, STORYTE
+Romualdez, Daniel
+architect
+ISRAEL
+Eshed, Elisa
+direct
+Jennifer
+Sanchez, Carlos
+Evani Duud Efrat
+GIl Avi
+Gutman, Arik
+Tropical Shipping
+Gutman, Arik
+Water Taxi
+Jerusalem Hyatt
+Neima, Yakhof
+Tantalam, Isarl
+Olmert, Ehud
+ITALY (1)
+Torne di Pisa
+Train Info
+JEFFREY (J)
+New York. NY 10021
+Apt for Modes
+
+
+KENYA (K)
+Muthalna Ciub
+KINNERTON
+Airport Transfers
+Charlle
+Chelsea Pollce Station
+coles
+Logistered Alingarl
+(Gim) Courtfeld Marical Centre
+Drivers
+1. holmail.com
+Is Wallaci
+es
+aller (o
+alter (o
+Entwistle Isl
+Hair Assocs
+Banta
+Harrods Limited
+inanemast, London SW1X7XL
+Harvey Nichols
+Holland & Holland
+Jackson Stops
+In & Bens
+John Hobbs Ltd.
+La Famiglia
+Martin Tlm/Debble Stew-
+2nd Line
+lange Rover
+Martine
+Massage - UK (a)
+Minicabs
+Jags Head
+REALI
+Maxwell, Ghislaine
+4 Kinnerton Stree
+endeg ERen SWIX BE
+tind guex paolagorossimon Ed.
+adasltama Floha Mishela
+onden, BIDEITC bnd
+O'Neil Noss
+Oping
+Outred, Anthony
+ond oni thrland SW100TZ
+tome
+Hedly's Humpers
+(Movers
+Police 24 hours
+Range Rover
+Ray John
+w)
+
+
+Maronet, BIll
+Thones
+Massage - Florida (a)
+p)
+Had
+ed)
+Mogens, Larry
+Police PB,
+Kennifer Bruno (cop hireVPa
+amorager
+de Reca
+or Meinc
+Sigt Trilych
+Pompano Helicopter
+Stopek, Alank
+Maxwell, Ghislaine
+220 8 У 33480
+Yos.
+Michast e salyA.R. RANCH (RH)
+Pal hoiree r
+Bode setta
+
+
+Epstein, Jeffrey
+Jeffrey
+19 Zorro
+stanley. NEED
+Security
+noden
+khouse LF
+lunk 5
+Shop Wood Shop
+ag cabin
+Sues longe main
+odem
+stell
+ercedos - fror
+Mercedes - back
+Mercedes G500
+; suburbal
+uburbar
+lahoe
+dummer
+Bradbury Slamm
+Bum Bad Sam 11)
+Sables
+(aren (Cell)
+ice Fax
+Sant: Fo NM 7:08
+Kelly En
+• HM 87103-2168
+erney, Ga
+mimard Naba
+Ince ethno Maryland 20774
+Sary home
+4778
+elular
+mergency
+King: Brucer
+Home
+King King Preda
+Thon
+Sanky New Mexic
+37056
+tome
+ortable
+Massage - New Mexico
+Richardson, Bill
+nice direct
+Sec agent wiGow
+(Tony)
+Santa Fe Institute
+Singleton, Dr. & Mrs.
+BM
+Aboff Shelley
+Cowley, Dick
+30mb. Sam Somor
+lew York, Ni
+
+
+Hatsuhana (Japanese)
+17 East 481h Şlre1)
+Helmal
+Il Cantinorl
+#l Tre Merll
+ouston Stre:
+aiBmaac
+Isabelle's
+349 Columhus Avanue
+Jour et Nutt
+Karen Pets
+Klinger, Georgette
+:012:5410021
+ionid.
+01402 Norma Jee
+Le Club
+88th (2-3)
+Le Comptoir
+A el Hote onter
+der YozNy
+Madison Gourmet
+Madison Towers
+3. aia Medion 8 300)
+lew York M
+Madre, Le
+168 West 18th
+New Vouk M
+Mark Hotel
+Nar Yat NY
+Massage - Californla
+Mayfair Regent
+65th bat BarkMad
+MoMullan, Patrick
+Mercer Kitchen
+Morgan Hotel
+Mr Chow
+Kem ,57'
+1002
+Hitni TT Knighesbridge
+
+
+cosmay mil
+News Albany Country
+1 Club Lane
+Albany. Columbus CH
+harark fax
+oreen (assistant)
+Datman. Bol
+, Inc.
+
+95 Parkway
+otel-Col
+per - Skypage
+Newcombe, Timothy W.
+leweimhn Einatenaic Systems
+105 An
+3221 (h)
+Berce Mail
+Larry Esq.
+21-272 MY 10021
+1 Creek Farms Road
+· 1105
+Flond
+da
+me.Ce
+Shery Catties Di-
+trice MD
+anice Oatman
+euragentsy
+Pice
+Beverly Hills, CA 90212
+Sanco Monica
+(h)
+Periman, Itzhak
+assina/Ovitz as
+Rewar 1127 York 10023
+table in NY
+MY Apart-
+Ritz's pager
+mer
+rivate Line
+A coll
+ach
+Fell as of 1-13-03
+acker, Marl
+anastel:
+/o Motorcyce Equities Ir
+4th Flo
+1OZE * 14E
+Canastel's Miami
+(R)
+agano, Joe
+my (w)
+Pete
+New Voti
+isa in New Mexico
+POT A FORMATION
+3514 Poster Road
+Veri Sim Beach, EL 23406
+on Home amy
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/dbf461940624d2b096ad4308d9fe420387fec180b21d3765447e85caaff03ed4.receipt.json b/vision-fixhub/ds9-unparsed-05/dbf461940624d2b096ad4308d9fe420387fec180b21d3765447e85caaff03ed4.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7af98d4ec2e6c17550bffaf36b05adf796af42b3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/dbf461940624d2b096ad4308d9fe420387fec180b21d3765447e85caaff03ed4.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -114,
+  "dataset": "marble-joined",
+  "doc_id": "dbf461940624d2b096ad4308d9fe420387fec180b21d3765447e85caaff03ed4",
+  "engine": "marble-apple-vision",
+  "event_count": 10,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "1a26a92bb5efc6eac7a8d3853b13e4e70a1193c8294b83721aa7999df1626861",
+  "output_sha256": "8c38206d6e5a04f42e211bb09bd0e11adb8b2a5a607ff131db9f45e68b664ffa",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/dcc75d224fc083d66e3e965b915e8223c55c1d4ed2aae933462430dea173501e.md b/vision-fixhub/ds9-unparsed-05/dcc75d224fc083d66e3e965b915e8223c55c1d4ed2aae933462430dea173501e.md
new file mode 100644
index 0000000000000000000000000000000000000000..280dd8f941b7353612a866dd2d38b5e316a0e934
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/dcc75d224fc083d66e3e965b915e8223c55c1d4ed2aae933462430dea173501e.md
@@ -0,0 +1,44 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 S. Australian Ave, Ste 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+June 12, 2009
+DELIVERY BY HAND
+Jack A. Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+One Clearlake Centre, Suite 1400
+250 Australian Ave S.
+West Palm Beach, FL 33401-5015
+Re:
+Jeffrey Epstein
+Dear Mr. Goldberger:
+Pursuant to the terms of the Non-Prosecution Agreement, the United States Attorney's
+Office for the Southern District of Florida hereby provides you with notice that the United
+States Attorney has determined, based on reliable evidence, that Jeffrey Epstein has willfully
+violated one of the conditions of the Non-Prosecution Agreement. Specifically, on May 26,
+2009, Jeffrey Epstein, through his counsel, filed a "Motion to Dismiss the First Amended
+Complaint or, in the Alternative, for a More Definite Statement," in the matter of Jane Doe
+No. 101 v. Jeffrey Epstein, Court File No. 09-CV-80591-KAM. "Jane Doe No. 101" was on
+the list provided to Mr. Epstein's attorneys of individuals whom the United States had
+identified as victims, as defined in 18 U.S.C. § 2255, and "Jane Doe No. 101" has elected to
+proceed exclusively under 18 U.S.C. § 2255. By filing the Motion to Dismiss, Mr. Epstein
+is contesting liability and, therefore, has violated Term 8 of the Non-Prosecution Agreement.
+Based upon Mr. Epstein's breach of that term, the U.S. Attorney's Office will pursue
+its remedies. The U.S. Attorney's Office also is continuing its review of Mr. Epstein's
+filings in the civil suits to determine whether additional breaches have occurred. If' any are
+
+
+JACK GOLDBERGER, Esp.
+JUNE 12, 2009
+
+identified, they will be communicated to you in accordance with the terms of the Non-
+Prosecution Agreement.
+Sincerely,
+Jeffrey H. Sloman
+Acting United States Attorney
+By:
+cc:
+Roy Black, Esq.
diff --git a/vision-fixhub/ds9-unparsed-05/dcc75d224fc083d66e3e965b915e8223c55c1d4ed2aae933462430dea173501e.receipt.json b/vision-fixhub/ds9-unparsed-05/dcc75d224fc083d66e3e965b915e8223c55c1d4ed2aae933462430dea173501e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1b25b83adadaedf1f11e1390d1a62ec87078b57a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/dcc75d224fc083d66e3e965b915e8223c55c1d4ed2aae933462430dea173501e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -35,
+  "dataset": "marble-joined",
+  "doc_id": "dcc75d224fc083d66e3e965b915e8223c55c1d4ed2aae933462430dea173501e",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "ed0b16fdbb83b02a8048c8b386f2db8a04642f9a6d5dca111b97df677cdf9597",
+  "output_sha256": "87a7d2ebd5fedff6a370750e4c1c019e38ed3a0adf08cd9418117813d89b9eed",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ddbc27a2fd10b1a97c42344590828780feea333e9fc6851f995c69cf98736859.md b/vision-fixhub/ds9-unparsed-05/ddbc27a2fd10b1a97c42344590828780feea333e9fc6851f995c69cf98736859.md
new file mode 100644
index 0000000000000000000000000000000000000000..2bbac4d1ecc689b004eeb9dad801fecb376ee845
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ddbc27a2fd10b1a97c42344590828780feea333e9fc6851f995c69cf98736859.md
@@ -0,0 +1,271 @@
+Sent
+To:
+Subject:
+- (USAFLS)
+(USAFLS)
+Wednesday. March 05, 2008 5:58 PM
+RE: Epstein update
+I don't think we have an issue with staleness because the memory cards are fixed
+(they haven't changed since the original search warrant) .
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach.
+FL 33401
+Phone
+-----Original Message-..--
+Madnesdav
+2008 5:55 PM
+Subject: Re: Epstein update
+(USAFLS)
+I like your style! Unsure what communication btw
+we have staleness issues with SW?
+Oniminal Maccano
+is about?? Also do
+Robert #ISAl
+Cc:
+Sent: Wed Mar 05 16:54:35 2008
+Subject: Epstein update
+Hi all - I wanted to update you on a couple of new developments in the Epstein
+case.
+First, Jeff Herman is supposed to give a press conference today announcing
+the filing of a third lawsuit against Epstein. That case also involves a victim
+whom we are no longer referring to in the indictment [Drew -
+do not tell
+that to the defense.] Herman seems to have latched onto the
+group
+which, as discussed in my third addendum to the pros memo, we have already
+decided to forego for the most part.
+Drew - Since I am not certain of the scope of your meeting, I do not know how
+critical it is for you to see the new facts developed in the supplemental pros
+memos (you reviewed the initial pros memo from May of last year). If you would
+like the supplements, please let me know. The legal theories have remained the
+same.
+1455
+P-014656
+
+
+I also wanted to call to everyone's attention the three-year statute of
+limitations in Florida for the state solicitation offenses. The statute will run
+for all the victims this summer.
+Once it runs we cannot insist on a state court
+plea to a new charge. It also means that the state cannot charge the crimes
+related to the victims discovered after the initial investigation. We have asked
+the Palm Beach Police Department to forego presenting those charges for state
+prosecution in deference to our prosecution. If we do not intend to go forward,
+it is imperative that we communicate that to the Police Department as soon as
+possible so they can present those victims for state prosecution.
+• have reserved time with the grand jury on the 18th. I had hoped to present the
+indictment at that time, but in light of LAN, communication with I will
+push it off until the 25th. I would still like to start the presentation on the
+18th so we aren't accused of rushing the grand jury. So, I hope that the final
+indictment packet will be approved by that date.
+Thank you.
+1456
+P-014657
+
+
+- (USAFLS)
+Sent
+To:
+Subject:
+Wednesday. March 05, 2008 5:55 PM
+1 200515 M
+Re: Epstein update
+I like your style! Unsure what communication btw
+we have staleness issues with Sw?
+----- Animinal Mace
+is about?? Also do
+Sent: Wed Mar 05 16:54:35 2008
+Subject: Epstein update
+Hi all - I wanted to update you on a couple of new developments in the Epstein
+case. First, Jeff Herman is supposed to give a press conference today announcing
+the filing of a third lawsuit against Epstein. That case also involves a victim
+whom we are no longer referring to in the indictment [Drew -
+once do not tell
+that to the defense.] Herman seems to have latched onto the
+group
+which, as discussed in my third addendum to the pros memo, we have already
+decided to forego for the most part.
+Drew - Since I am not certain of the scope of your meeting, I do not know how
+critical it is for you to see the new facts developed in the supplemental pros
+memos (you reviewed the initial pros memo from May of last year). If you would
+like the supplements, please let me know. The legal theories have remained the
+same.
+I also wanted to call to everyone's attention the three-year statute of
+limitations in Florida for the state solicitation offenses.
+The statute will run
+for all the victims this summer. Once it runs we cannot insist on a state court
+plea to a new charge. It also means that the state cannot charge the crimes
+related to the victims discovered after the initial investigation. We have asked
+the Palm Beach Police Department to forego presenting those charges for state
+prosecution in deference to our prosecution. If we do not intend to go forward,
+it is imperative that we communicate that to the Police Department as soon as
+possible so they can present those victims for state prosecution.
+I have reserved time with the grand jury on the 18th. I had hoped to present the
+ndictment at that time.
+18th so we aren't accused of rushing the grand jury. So, I hope that the final
+indictment packet will be approved by that date.
+Thank you.
+1457
+P-014658
+
+
+1458
+P-014659
+
+
+(USAFLS)
+From
+ent
+To:
+Subject:
+- (USAFLS)
+Wednesdav. March 05, 2008 10:39 AM
+RE: Epstein
+Sounds good. I think it is worth doing the search warrant. Can Jason get the cards out of evidence when he is
+down there?
+Do you have a copy of your affidavits that we submitted on the computer issue? I think those are a good start
+for the search warrant affidavit. Thanks.
+lite 400
+01
+Sent: Wednesday. March 05, 2008 10:35 AM
+To:
+(USAFLS)
+Subject: RE: Epstein
+Marie,
+Still no word from Mr. Herman. Just to clarify about the memory cards - Joe and Jason have both reviewed the evidence
+some time ago. There is no significant photographs on the cards. However, a forensic analysis was not done which
+would show any deleted photos. Jason has to go tomorrow to Miami. I have asked him to pick up the copies of
+documents, obtain the copyright date for the "Massage for Dummies" book and get a description of the memory cards -
+should we decide to go ahead with a search warrant. We're still working on obtaining some of the girls' phone records.
+I have put Hauge on standby to put together the travel/phone charts once we have
+and Jennifers' records. I'll
+give you a call once I have spoken with Herman.
+(USAFLS) [
+Sent: Tuesday, March 04, 2008 12:15 PM
+Subject: RE: Epstein
+Thank you for the update. On the statute of limitations, it doesn't matter for the pending charges because they
+were indicted in time, it just matters to adding new charges.
+Can you call Mr. Herman and see if he will give us the following items without a subpoena?
+1. Copy of
+deposition transcript
+2. Copy of any video and/or audiorecording of that deposition
+3. Transcripts) of any other depositions taken in that suit
+4. Copies of any e-mails and correspondence sent to or received from Epstein or his lawyers
+Copies of any agreements - formal or informal - entered into between Epstein/his lawyers and
+dad/their lawyers.
+1463
+P-014660
+
+
+And maybe you can ask him why there will be a press conference?
+Thank you.
+Sent Tuesday. March 04, (USAL524 AM
+(USAFLS)
+Subject: Epstein
+Hey
+I just heard from Joe that Mr. Herman is holding another press conference tomorrow at Palm Beach Town at
+1:00pm. He called the Town of Palm Beach to see if he could hold it at EPSTEIN's residence. They told him "NO".
+Also FYI, there is a three year statute of limitations on the State charges of Solicitation. Joe feels like that State or
+Epstein's Counsel may be waiting for those dates to pass. September/October 2005 is when most of the other victims
+reported so that means in Sept/Oct 2008 the statute of limitations applies.
+1464
+P-014661
+
+
+Sent:
+To:
+Subject:
+Wednesday. March 05, 2008 10:35 AM
+- (USAFLS)
+RE: Epstein
+Marie,
+Still no word from Mr. Herman. Just to clarify about the memory cards - Joe and Jason have both reviewed the evidence
+some time ago. There is no significant photographs on the cards. However, a forensic analysis was not done which
+would show any deleted photos. Jason has to go tomorrow to Miami. I have asked him to pick up the copies of
+documents, obtain the copyright date for the "Massage for Dummies" book and get a description of the memory cards -
+should we decide to go ahead with a search warrant. We're still working on obtaining some of the girls' phone records.
+I have put Hauge on standby to put together the travel/phone charts once we have
+give you a call once I have spoken with Herman.
+(USAFLS)
+Sent: Tuesday, March 04, 2008 12:15 PM
+To:
+Subject: RE: Epstein
+Thank you for the update. On the statute of limitations, it doesn't matter for the pending charges because they
+were indicted in time, it just matters to adding new charges.
+Can you call Mr. Herman and see if he will give us the following items without a subpoena?
+1. Copy of
+deposition transcript
+2. Copy of any video and/or audiorecording of that deposition
+3. Transcripts) of any other depositions taken in that suit
+4. Copies of any e-mails and correspondence sent to or received from Epstein or his lawyers
+5. Copies of any agreements - formal or informal - entered into between Epstein/his lawyers and
+dad/their lawyers.
+And maybe you can ask him why there will be a press conference?
+Thank you.
+Sent: Tuesdav. March 04. 2008 11:24 AM
+To:
+(USAFLS)
+Subject: Epstein
+Hey
+1465
+P-014662
+
+
+I just heard from Joe that Mr. Herman is holding another press conference tomorrow at Palm Beach Town
+1:00pm. He called the Town of Palm Beach to see if he could hold it at EPSTEIN's residence. They told him "NO".
+Also FYI, there is a three year statute of limitations on the State charges of Solicitation. Joe feels like that State or
+Epstein's Counsel may be waiting for those dates to pass. September/October 2005 is when most of the other victims
+reported so that means in Sept/Oct 2008 the statute of limitations applies.
+1466
+P-014663
+
+
+• (USAFLS)
+Sent:
+To:
+Subject:
+- (USAFLS)
+Tuesdav. March 04, 2008 12:16 PM
+RE: Epstein
+Thank you for the update. On the statute of limitations. it doesn't matter for the pending charges because they
+were indicted in time, it just matters to adding new charges.
+Can you call Mr. Herman and see if he will give us the following items without a subpoena?
+1. Copy or
+deposition transcript
+copy of any video and/or audiorecording of that deposition
+›. Iranscripts) of an other depositions taken in that suit
+4. Copies of any e-mails and correspondence sent to or received from Epstein or his lawyers
+5. Copies of' any agreements - formal or informal - entered into between Epstein/his lawyers and
+dad/their lawyers.
+And maybe you can ask him why there will be a press conference?
+Thank you.
+Sent: Tuesday, March 04, 2008 11:24 AM
+To:
+(USAFLS)
+Subject: Epstein
+Hey Marie,
+Just heard from Joe that Mr. Herman is holding another press conference tomorrow at Palm Beach Town at
+1:00pm. He called the Town of Palm Beach to see if he could hold it at EPSTEIN's residence. They told him "NO".
+Also FYI, there is a three year statute of limitations on the State charges of Solicitation. Joe feels like that State or
+Epstein's Counsel may be waiting for those dates to pass. September/October 2005 is when most of the other victims
+reported so that means in Sept/Oct 2008 the statute of limitations applies.
+1469
+P-014664
+
+
+From
+sent:
+Subject:
+Tuesday, March 04. 2008 11:24 AM
+| (USAFLS)
+Epstein
+Hey Marie,
+I just heard from Joe that Mr. Herman is holding another press conference tomorrow at Palm Beach Town at
+1:00pm. He called the Town of Palm Beach to see if he could hold it at EPSTEIN's residence. They told him "NO".
+Also FYI, there is a three year statute of limitations on the State charges of Solicitation. Joe feels like that State or
+Epstein's Counsel may be waiting for those dates to pass.
+September/October 2005 is when most of the other victims
+reported so that means in Sept/Oct 2008 the statute of limitations applies.
+1470
+P-014665
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/ddbc27a2fd10b1a97c42344590828780feea333e9fc6851f995c69cf98736859.receipt.json b/vision-fixhub/ds9-unparsed-05/ddbc27a2fd10b1a97c42344590828780feea333e9fc6851f995c69cf98736859.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..405a67f4a9e59728fa54ac1cbbf3d26acb2a6772
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ddbc27a2fd10b1a97c42344590828780feea333e9fc6851f995c69cf98736859.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -361,
+  "dataset": "marble-joined",
+  "doc_id": "ddbc27a2fd10b1a97c42344590828780feea333e9fc6851f995c69cf98736859",
+  "engine": "marble-apple-vision",
+  "event_count": 11,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "6dba62c29f6cf65519c17cbee8bd9f7bd09ea1b1f090c7fda3137978aea4542e",
+  "output_sha256": "5ace485064837e59cdfe0718e6e49a56208dd7dd11ec147ecf1f29d0cd2cb9f0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/de24775b5ad224f1bb09ea0ec18467cf363d75034975e539cefcf8ae3e85cd95.md b/vision-fixhub/ds9-unparsed-05/de24775b5ad224f1bb09ea0ec18467cf363d75034975e539cefcf8ae3e85cd95.md
new file mode 100644
index 0000000000000000000000000000000000000000..b0fecaf6e2b67e77bb567d5718fa9785f20cf498
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/de24775b5ad224f1bb09ea0ec18467cf363d75034975e539cefcf8ae3e85cd95.md
@@ -0,0 +1,35 @@
+
+
+
+(USAFLS)
+From: Lilly Ann Sanchez [
+Sent:
+Friday, January 05, 2007 4:05 PM
+To:
+| (USAFLS)
+Cc:
+Gerald Lefcourt
+Subject: Jeffrey Epstein
+[you had a great holiday season. Gerald Lefcourt and I would like to speak with you early next week on the Epstein
+matter. if you provide me with some convenient dates and times for us to call you, i will coordinate with Gerry and confirm
+same.
+regards
+Lilly Ann Sanchez, Esq.
+FOWLER WHITE BURNETT P.A
+**TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance
+with requirements imposed by the IRS, we inform you that any tax
+advice contained in this communication (including attachments) was
+not intended or written to be used, and cannot be used, for the
+purpose of (i) avoiding penalties under the Internal Revenue Code
+or (ii) promoting, marketing or recommending to another party any
+transaction or matter addressed herein. If you would like such advice,
+please contact us.***
+***Attention: The information contained in this E-mail message
+is attorney privileged and confidential information intended only
+for the use of the individual (s) named above. If the reader of this
+message is not the intended recipient, you are hereby notified that any
+dissemination, distribution or copy of this communication is strictly
+prohibited. If you have received this communication in error, please
+contact the sender by reply E-mail and destroy all copies of the original
+message. Thank you.
+1/11/2007
diff --git a/vision-fixhub/ds9-unparsed-05/de24775b5ad224f1bb09ea0ec18467cf363d75034975e539cefcf8ae3e85cd95.receipt.json b/vision-fixhub/ds9-unparsed-05/de24775b5ad224f1bb09ea0ec18467cf363d75034975e539cefcf8ae3e85cd95.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..520321b65568beae556174a58dcdaa22b75697a9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/de24775b5ad224f1bb09ea0ec18467cf363d75034975e539cefcf8ae3e85cd95.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -35,
+  "dataset": "marble-joined",
+  "doc_id": "de24775b5ad224f1bb09ea0ec18467cf363d75034975e539cefcf8ae3e85cd95",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "fcd09b26fa51f5b971b581edcd292f50615e13e43fb03c06a51f26a48dff5138",
+  "output_sha256": "3232687e3be0193c9836fbbed7661e4eb9ec0a7e7563ab99ff7d41e471b37889",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/df6cff9b8f36af21cd8ecccd7fb06e4ec9e869571e67b38579270b65b6bd03b4.md b/vision-fixhub/ds9-unparsed-05/df6cff9b8f36af21cd8ecccd7fb06e4ec9e869571e67b38579270b65b6bd03b4.md
new file mode 100644
index 0000000000000000000000000000000000000000..51a1d0b1d11380f9fad9bc2d6ab50e80c995dac5
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/df6cff9b8f36af21cd8ecccd7fb06e4ec9e869571e67b38579270b65b6bd03b4.md
@@ -0,0 +1,115 @@
+August 2,2007 Sanchez t
+
+
+Fre
+FOWLERWHITE
+ATTORNEYS A1
+BURNETT
+MIAMI • FORT LAUDERDALE • WEST PALM BEACH • ST. PETERSBURG
+TELEPHONE
+FACSIMILE (305) 789-9201
+WWW.FOWLER-WHITE.COM
+LILLY ANN SANCHEZ
+DIRECT PHONE No.:
+DIRECT FACSIMILE No.:
+August 2, 2007
+Mr.
+Chief, Criminal Division
+United States Attorney's Office
+Southern District of Florida
+Re: Jeffrey Epstein
+Dear
+As we discussed at Tuesday's meeting, and consistent with our view that no
+federal prosecution should lie in this matter, Mr. Epstein is prepared to resolve this
+matter via a state forum. We are in receipt of your memo regarding same and as the
+dynamics of the meeting did not allow for us to fully detail our proposal, we do so
+now. We believe that our respective positions are not very far apart and that a
+mutually agreeable resolution can be reached that will accomplish the interests of the
+United States Attorney's Office as well as those of the community.
+We welcomed your recognition that a state prison sentence is neither
+appropriate for, nor acceptable to, Mr. Epstein, as the dangers of the state prison
+system pose risks that are clearly untenable. We acknowledge that your suggestion
+of a plea to two federal misdemeanors was an attempt to resolve this dilemma. Our
+proposal is significantly punitive, and if implemented, would, we believe, leave little
+doubt that the federal interest was demonstrably vindicated.
+The Florida state judicial system, unlike the federal system, provides for
+numerous types of onerous sanctions after a defendant is remanded to the custody of
+the state. The sentence is tailored to the needs of the local community and the risk
+posed by a specific defendant. After a great deal of thought, our proposal consists
+of both a severe supervised custody, with an assurance that any violation would result
+in the immediate implementation of the two year period of incarceration. We must
+keep in mind that Jeffrey Epstein is a 54-year old man who has never been arrested
+before. He has lived an otherwise exemplary life, characterized by both many
+charitable contributions and philanthropic acts. His reputation has suffered
+significantly as a result of his poor judgment in these matters. He is well aware of the
+ramifications of his past behavior and, accordingly, there is no concern, whatsoever,
+FowLeR WHITE Burnett P.A.
+
+
+Page 2
+The following proposal is offered as an assurance to the community that the
+goals of appropriate punishment and rehabilitation are attained.
+We will agree to a sentence of two years in state prison pursuant to Florida
+Statute 948.012(2) which permits a split sentence whereby Mr. Epstein will be
+sentenced to a term of supervised custody, followed by a period of incarceration.
+Supervised custody in the state system includes potential daily surveillance,
+administered by officers with restricted case loads. Supervised custody is an
+individualized program in which the freedom of Mr. Epstein is limited to the
+confines of his residence with specific sanctions imposed and enforced. See Florida
+Statute 948.001(2). Should Mr. Epstein successfully complete the terms and
+conditions of his custody, the Judge will eliminate the incarcerative portion of the
+sentence. If Mr. Epstein, however, fails to comply with the conditions of his
+supervised custody. The period of incarceration will be immediately implemented.
+We, therefore, propose the following:
+Two years supervised custody with the following mandatory and special
+conditions:
+• Confinement to home
+• Report to a community control officer at least once a week or more
+often as directed by the officer
+• Permit a community control officer to visit him unannounced at home
+at any time, day or night
+• Obtain psychological counseling
+• No unsupervised contact with all the victims in the instant case
+• Perform community service
+• Payment of Restitution
+• Application of 18 U.S.C. § 2255'
+• Payment of a contribution of a defined amount to a charitable
+organization benefitting victims of sexual assault
+• Payment of Court and probationary costs
+• Payment of law enforcement investigative costs
+• Submit to random drug testing
+• Refrain from associating with persons engaged in criminal activities
+• Refrain from committing any new law offenses
+• Any other specific conditions that the Office may deem necessary
+Two additional years of reporting probation:
+' 18 U.S.C. 2255 provides that any minor who suffers injury as a result of the commission of certain offenses
+shall recover actual damages and the cost of any suit. It is important to note that Mr. Epstein is prepared to fully
+fund the identified group of victims which are the focus of the Office - that is, the 12 individuals noted at the
+meeting on July 31, 2007. This would allow the victims to be able to promptly put this behind them and go
+forward with their lives. If given the opportunity to opine as to the appropriateness of Mr. Epstein's proposal,
+in my extensive experience in these types of cases, the victims prefer a quick resolution with compensation for
+damages and will always support any disposition that climinates the need for trial.
+FOWLER WHITE BURNETT P.A.
+
+
+Page 3
+• Mandatory conditions as provided in Florida Statute § 948.03
+• Special conditions as stated above
+If the terms of supervised custody and probation are successfully completed,
+then the two years of state prison is eliminated.
+This proposal provides for the two year imposition of the state prison sentence
+if any violation of the supervised custody or probation occurs. Accordingly, the
+Office's position that Mr. Epstein agree to a resolution that includes jail time is
+satisfied by this proposal. It would immediately bring closure to a matter that has
+been pending for over two years, allows Mr. Epstein to commence with his sentence,
+and, most significantly, allow the victims to move forward with their lives. We are
+in process of scheduling a meeting with R. Alexander Acosta, United States
+Attorney, to further discuss this matter.
+Sincerely,
+8835
+Lilly Ann Sanchez
+cc.
+R. Alexander Acosta
+Gerald Lefcourt
+Roy Black
+FowLer WHite BurneTT P.A.
diff --git a/vision-fixhub/ds9-unparsed-05/df6cff9b8f36af21cd8ecccd7fb06e4ec9e869571e67b38579270b65b6bd03b4.receipt.json b/vision-fixhub/ds9-unparsed-05/df6cff9b8f36af21cd8ecccd7fb06e4ec9e869571e67b38579270b65b6bd03b4.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e5483e54821f09262e32bc6a99a91af9c9650c90
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/df6cff9b8f36af21cd8ecccd7fb06e4ec9e869571e67b38579270b65b6bd03b4.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -48,
+  "dataset": "marble-joined",
+  "doc_id": "df6cff9b8f36af21cd8ecccd7fb06e4ec9e869571e67b38579270b65b6bd03b4",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "917818557586363672d6a86fb9e77429cbfc3cb81b66080f4c13c177e869f47a",
+  "output_sha256": "939b10f64ac04cf49d1eddc4c5a6c1c8cb82c1a71b7c9b6d7ebd57f4e8922413",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/dfcee56529fff5bc28931544528f0fc43b3613f0693a4805cb54014299b73a3c.md b/vision-fixhub/ds9-unparsed-05/dfcee56529fff5bc28931544528f0fc43b3613f0693a4805cb54014299b73a3c.md
new file mode 100644
index 0000000000000000000000000000000000000000..ba628d5b29a161bd98eee47669a7456fee0ce7a3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/dfcee56529fff5bc28931544528f0fc43b3613f0693a4805cb54014299b73a3c.md
@@ -0,0 +1,3297 @@
+NOU-27-2007 13:26
+ATTN:
+PALM BEACH CI
+SHERIFF'S OFFICE
+RIC L. BRADSHAW, SHERIFF
+P.01/05
+
+RESPECT
+ALTERNATIVE CUSTODY LINIT
+FAX TRANSMITTAL
+COVER SHEET
+To:
+From:
+Department:
+CC:
+Fax#:
+Date:
+Pages:
+11/26/07
+• Urgent
+• For Review
+• Please Comment
+• Please Reply
+As per your request, these are the copies of PBSO post orders for the Work Release Program
+3228 Gun Club Road - P.O. Box 24881 - West Palm Beach, Florida 33416-4681 *
+
+
+NOU-27-2007 13:26
+I PALM BEACH COUNTY
+SHERIFF'S OFFICE
+RIC L. BRADSHAW, SHERIFF
+P.02/05
+Work Release Post Orders
+I. INTRODUCTION
+The information included in this packet is to be used as a guide for training in the Work
+Release Program. It is a list of the basic tasks, functions and procedures for operating the
+equipment identified. The Field Training Officer will have the trainee read all material as well as
+the Corrections Operating Procedures that are relevant to this post Additionally, the F.T.O. will
+explain and demonstrate to the trainee the operation of all equipment, to include tasks and
+proper procedures. The trainee will then demonstrate their proficiency of the assigned tasks.
+To ensure maximum training in this area, a total of five (5) days is to be scheduled. A Daily
+Observation Report will be completed by the F.T.O: and reviewed with the trainee on daily
+basis. Furthermore, a Post Evaluation sheet will be completed by the F.T.O. at the conclusion
+of training in this area. All forms will be reviewed and signed off by the shift Lieutenant,
+Sergeant, F.T.O. and trainee.
+This information is not all encompassing; therefore, when unlisted situations arise the F.T.O
+should demonstrate or explain to the trainee the proper procedure for handling the situation. It
+is unrealistic to expect that one could possibly prepare for all unusual situations that may
+occur. To enhance any portion of the training, additional resource material may be utilized
+providing it falls within the description of the job.
+PERFORMANCE EVALUATIONS:
+The performance level of a trainee may be evaluated utilizing on-the-spot testing of their
+knowledge concerning specific pieces of equipment and/or procedures to be taken during
+critical incidents. All areas indicated on the Daily and Post evaluation forms must include
+performance evaluations.
+The following orders will give the deputy a basic operational knowledge of this post. The
+information contained herein will attempt to cover the normal or routine functions. These orders
+are neither designed nor intended to cover all situations and are subject to change. These
+orders are not to be seen or shown to any inmate.
+The following tasks are completed Monday thru Friday by the Work Release Officer:
+1) Check with Booking Deputy for inmates that were place on hold for breach of contract.
+2.) Pick up work release sign out sheet from Booking Desk.
+3.) Notify G & H Deputy for any inmate on hold, to be sent to program office.
+-1.
+anacher Endea forma fund Ordere Carpiated dos
+
+
+NOV-27-2007
+P.03/05
+4.) Deputy will discuss with inmate and determine weather to give a corrective counsel or
+remove the inmate from The Work Release program; Documentation will be placed in
+inmate file.
+5.) Review request from inmate Records of inmates requesting work release and answer
+them in writing
+6.) Check files from inmate Records of inmates requesting to be placed on work release.
+7.) Request Palms, NCIC-FCIC inquiry from Inmate Booking Tech.
+Work Release Backgrounds Check: The following preliminary procedures will be completed
+when an inmate request work release.
+1.) Review file of inmate requesting work release. The following charges are not eligible:
+a. Bombs/Deadly Missiles/Throwing deadly missiles causing bodily harm (F.S.S.
+790)
+b. Burglary with Assault or Battery (F.S.S. 810.02(2)(a)
+c. Child Abuse/Child Neglect (F.S.S.827)
+d. Homicide/Vehicular Homicide/Murder (F.S.S. 782)
+e. Kidnapping/False Imprisonment (F.S.S.787)
+f. Sexual Battery (F.S.S. 794)
+g. Any history of violation of federal, state, or local work release or in house
+arrest/community control programs.
+h. Arson (F.S.S.806) one (1) guilty during the past fifteen (15) years.
+i. Drug Trafficking (F.S.S. 893.135) one (1) guilty during the past fifteen- (15)
+years.
+j. 'D.U.I. Manslaughter (F.S.S. 316.193) one (1) guilty during the past fifteen (15)
+years.
+k. Escape (F.S.S. 944.40) one (1) guilty during the past fifteen- (15) years.
+I. Robbery (F.S.S. 812) (1) guilty during the past five (5) years.
+m. D.W.I. / U.B.A. (F.S.S. 316.93) three guilt's within the past fifteen (15) years.
+n. Prostitution (F.S.S. 796) three guilt's within the past five (5) years.
+o. Aggravated Battery (F.S.S. 784) two guilt's within the past ten (10) years.
+p. Domestic Violence (F.S.S. 741.28) one guilty within the past five (5) years.
+q. Stalking (F.S.S. 784) one guilty within the past ten (10) years.
+r. Armed Robbery (F.S.S. 812.13) one guilty in past ten (10) years.
+s. Aggravated Assault (F.S.S. 784.021) one guilty in past five (5) years.
+t. An extensive or violent criminal history or facility behavior as determined by the
+supervisor of the Alternative Custody Section
+u. Inmates with active detainees for other agencies are ineligible, except when their
+sentences are running concurrent/consecutive with local sentences and they are
+authorized for Work Release by the other jurisdiction.
+• Inmates who are known to belong to, or associate with individuals involved with
+organized crime, subversive groups that advocate violence, or street gangs are
+ineligible, as determined by PALMS, criminal history or law enforcement
+intelligence.
+2.) Work Release Deputy will call G & H dor to send inmate for personal interview and
+explain what paperwork is needed from inmate.
+3.) If preliminary requirements are met, give inmate copy of Program Agreement, personal
+history forms, and emergency form to be completed by inmate and returned.
+4.) After NCIC, Criminal History check, Palms check, and Personal history form are
+received, the Programs Supervisor will review the complete package at this time, and
+inmate file signifying to continue or suspend process.
+- 2-
+
+
+NOV-27-2007
+P.04/05
+5.) If the Program Supervisor decides, upon review of documents, that the inmate does not
+meet the criteria of the program, a note will be returned to the effected Deputy, so
+stating. That Deputy will so notify the effected inmate.
+Placement on Work Release:
+1. If approved the officer will complete the following forms
+a. Work Release Program Agreement
+b. Case Files Review Sheet Work Release
+Key Agreement
+d. Locator Card Contacts
+e. Equipment Inspection Check Out Sheet (ProTech Equipment)
+. Work Release Synopsis
+g. Work Release Folder Stamp Revised
+h. Medical clearance for for work release inmates
+i.
+Booking card
+j. Court record (Court Orders / Commitments)
+k. FCIC/NCIC (Criminal History)
+1. Employed Verification Letter
+m. Program entry fees (copy of money order )
+n. Employee wage verification
+0. Drivers License, Vehicle Registration and Auto Insurance card
+p. Victim notification (if Application)
+q. Application
+r. Monitoring initializing printout /GPS offender report
+s. Finance sheet
+t. Inmate photograph (Front and Side Face)
+• Computer generated reading/signed by assigned case deputy
+• ID Card for Inmate
+w. Blue "T" Card
+2. After all form are completed the package will be read and signed by inmate;
+The Deputy will review orally the contents with inmate to assure the inmate understands
+the rules and regulations.
+3. The signed complete package is then given to Work Release Supervisor or designee,
+for approval.
+4. If approved, inmate is given his clothes, and personal items from property are signed for
+by inmate. Witch is placed in the inmate assigned locker.
+5. Inmate information is placed on work release sheet, finance sheet, and face sheet is
+placed in active file, and "T" card changed in Work Release.
+6. Inmate is taken to Job and work release rules are explained to his supervisor and a
+signature obtained.
+7. A random monitoring of inmate will be conducted, at the inmate's place of employment,
+at Deputy and/or supervisors discretion.
+Global Tracking System (MTD) Miniature Tracking Device
+1. Inmate or assigned Equipment
+a. Monitor
+b. Bracelet
+c. Base Unit (place in Building)
+2. Enrolling inmate into Pro-Tech
+-3.
+
+
+NOU-27-2007
+FBI -
+P.05/05
+a. demographic screen
+b. Personal Information
+c. Education
+d. Employment
+e. Sentencing
+f. Picture
+g. Rules
+h. Hardware (Add Monitor, Bracelet and Base Unit)
+Removal of inmate for violation of rules: When it becomes necessary to remove an inmate
+from work release, the following procedures will be followed.
+1. Remove name from work release log.
+2. Remove from inmate locator file folder.
+3. Remove active file and place in completed files.
+4. Give inmate change of trustee clothes.
+5. Notify Classification and G & H Deputy of inmate removal from program.
+6. Work Release Deputy will remove inmate property from locker and return it back to
+property.
+7. Remove inmate from work release Job assignment.
+8. Type a report stating the reason why inmate was removing from program. The original
+to be filed in inmate file, a copy given to unit supervisor.
+Escape: (Signal 6): The following procedures will be followed if an inmate fails to retum to the
+Stockade within the schedule time.
+1. BOLO Issue (Commo)
+2. Place inmate in PALMS (intake Booking Main Jail)
+3. Remove name from work release list.
+4. Notify G & H Deputy of inmate removal from program.
+5. Clear inmate Work Release locker.
+6. Remove inmate from work release Job assignment.
+7. Type a report the original to be filed in inmate file, a copy given to unit supervisor.
+8: Signal 6 Filling Packet with state Attomey Office.
+Completion of Work Release Program: The following procedures will be followed when an
+inmate is time served from this program.
+1. Get inmates name from Classification officer
+3. Pui file and Tocator cargiroat bosse list
+Pull file and locator card from card box.
+-4-
+S1D/2057
+Elor Pires Pa Dries Comple ess
+TOTAL P.05
+
+
+Appendix 5 - 1998 through 2003 Agency Strategic Plan, Florida Department of Corrections Page 1 of 5
+ту"
+PuDic
+Safety
+Florida Department of
+ORRECTIONS
+Hopeda
+Rarene Bitte
+Duanaraswer a Some Contes
+ESTATISTICS & PUBEICATIONS
+top | previous | 24 of 26 | next
+Agency Strategic Plan
+1998 - 2003
+Appendix 5:
+Statutory Authorities and Bibliography
+The following Florida Statutes, Administrative Regulations, Rules and
+Contracts govern operations of the Florida Department of Corrections:
+FLORIDA STATUTES
+20.315
+Created a Department of Corrections
+110.105
+Employment Policy of the State
+110.205
+Career Service Exemptions - Exempt position
+186.022
+State Agency Functional Plans: Consistency with State Comprehensive Plan
+187.201
+State Comprehensive Plan 229.565(3) Educational Evaluation Procedure
+Education Evaluation
+252
+253.025
+273.02
+. 284.50
+Emergency Management
+Acquisition of State Lands
+Record and Inventory of Certain Property
+Loss Prevention Program; Safety Coordinators; Interagency Advisory Council
+on Loss Prevention; Employee Recognition Program
+364.510
+Distance Learning Network
+397.305
+Provide Substance Abuse Treatment
+403
+Environmental Control
+440.56
+Safety Rules and Provisions; Penalty
+442
+Occupational Health and Safety
+447.203 (2)
+Definitions of "Public Employees"
+633.085
+Inspections of State Buildings and Premises: Tests of Fire Satety Equipment;
+Building Plans to be Approved
+775.084
+775.089
+784.07
+874.03
+794.011
+Violent Career criminals
+Court Order to Collect and Dispense Restitution
+Assaults by Prisoners
+Criminal Street Gang member
+Sexual Battery
+
+
+Appendix 5 - 1998 through 2003 Agency Strategic Plan, Florida Department of Corrections
+
+921
+943.03
+944.012
+944.023
+944.26
+944.33
+944.053
+944.08
+944.09
+944.10
+944.105
+Sentence
+Department of Law Enforcement
+Legislative Intent
+944.012(5) Authority to Coordinate with Various Agencies
+Comprehensive Correctional Master Plan
+Community-Based Facilities and Programs
+Community Correctional Centers
+Public Works Projects
+Commitment to Custody of Department: Venue of Institutions
+Rules of the Department: Offenders, Probationers and Parolees
+Department of Corrections to Provide Buildings
+Contractual Arrangements with Private Entities for Operation and
+Maintenance of Correctional Facilities and Supervision of Inmates
+944.11
+944.1905
+944.291
+Department to adopt Rules as to Admission of Books
+Initial Inmate Classification: Inmate Reclassification
+Prisoner released by reason of gain-time allowances or attainment of
+provisional release date
+944.704
+944.705
+944.707
+944.801
+945.04
+945.091
+945.092
+945.12
+945.41
+945.49
+945.71-73
+946
+947.146
+948
+948.01
+948.03
+948.50
+949.07
+949.09
+Transition Programs
+Release Orientation Program
+Post Release Support Services
+Education for State Prisoners
+Maximize Use of Inmate Labor
+Extension of the Limits of Confinement: Restitution by Employed Inmates
+Limits on Work Release
+Transfers for Rehabilitative Treatment
+Legislative Intent of Section 945.40945.49 Corrections Mental Health Act
+Operation and Administration
+Boot Camps - Training
+Inmate Labor and Correctional Work Programs
+Control Release Authority
+Probation and Community Control
+When Court May Place Defendant on Probation or into Community Control
+Terms and Conditions of Probation or Community Control
+Community Corrections Partnership Act
+Compacts with Other States
+Short Title: Section 949.07-949.08 Uniform Law for Out-of-State Probation
+and Parole Supervision
+
+
+Appendix 5 - 1998 through 2003 Agency Strategic Plan, Florida Department of Corrections Page 3 of 5
+957.03
+957.04
+957.07
+958.04
+Correctional Privatization Commission
+Contract Requirements
+Cost Saving Requirements
+Judicial Disposition of Youthful Offenders
+DEPARTMENT OF CORRECTIONS ADMINISTRATIVE RULES
+33-1 Definitions, Responsibilities, Organization and Public Information
+33-2
+Inspections and Investigations
+33-3
+Operation of Institutions
+33-4
+Personnel
+33-5
+Visitors
+33-6
+Reception, Classification, Transfer and Records
+33-7
+Local Transfer, Temporary Release and Discharge Procedures
+33-8 County and Municipal Detention Facilities
+33-9 Extension of the Limits of Confinement
+33-11 Modification of Sentences
+33-12 Notice of Proceedings and Proposed Rules
+33-14 Procedures for Contracting for Professional Services
+33-15 News Media Access Following Issuance of Death Warrants
+33-19 Health Services
+33-20 Miscellaneous Provisions
+33-21 Interstate Cooperation
+33-22 Inmate Discipline
+33-23 Corrections Mental Health Facilities
+33-24 Probation and Parole Services
+33-25 Staff Development
+33-26 Staff Housing
+33-27
+Basic Training Program for Youthful Offenders
+33-29 Inmate Grievance Procedure
+33-30 Food Services
+33-31
+Utilization of Minority Business Enterprises
+33-32 Construction and Operation of Private Correctional Facilities
+33-35 Community Corrections Partnership
+33-36 Indexing of Final Agency Orders
+33-37 Substance Abuse Programs
+DEPARTMENT OF CORRECTIONS POLICY AND PROCEDURES
+
+
+Appendix 5 - 1998 through 2003 Agency Strategic Plan, Florida Department of Corrections Page 4 of 5
+DIRECTIVES
+1.01.02 Inter and Intra Governmental Cooperation
+2.02.34 Industrial/Fire Safety, Loss, Control and Prevention
+3.01.01
+The Processing of Inmates' Impounded Personal Property
+2.01.01 Inmate Personal Property
+3.04.07 Contraband
+3.04.11 Inmate Package Permits
+4.07.32 Probation and Restitution Centers
+CONTRACTS
+Department of Corrections/Department of Labor Employment Security
+Contractual Agreement for Services, 1985 for Services Under Item 316 of the
+1981-89 State of Florida Appropriations Act.
+OTHER AGENCY ADMINISTRATIVE RULES
+DER Rules 17-2 and 17-712 FAC Biohazardous Waste Disposal
+DHRS Rule 10D-104 FAC
+OTHER SOURCES REFERRED TO IN THE STRATEGIC PLAN
+Americans with Disabilities Act
+Criminal Justice Estimating Conference (CJEC) Reports
+Department of Community Affairs Directives
+Department of Corrections Annual Report 1996-97
+Department of Corrections Strategic Information Systems Plan 1990
+(Anderson Report)
+Department of Corrections Environmental Health Services Manual July 1980
+Governor's Commission For Government By The People December 1991
+Health Services Bulletin 15.13.01
+Health Services Bulletin 15.03.13
+Health Services Bulletin 15.03.05
+Health Services Bulletin 15.03.24
+National Council on Crime & Delinquency: Evaluation of the Florida
+Community Control Program 1987
+National Probation and Parole Association and The President's Commission
+on Law Enforcement and the Administration of Justice
+Parole & Probation Staff Safety Task Force Report
+Personnel Procedures Manual, Vol. 3, Chapters 3 & 5
+State of Florida, Department of Corrections Strategic Information Systems
+Plan
+State Strategic Plan for Information Resource Management: Fiscal Years
+1995-1999
+BIBLIOGRAPHY
+1. Annual Report 1996-1997, Florida Department of Corrections.
+"Community Work Squads Earnings and Value Added/Cost Savings
+Report," Dated June 30, 1997, Program Services, Department of
+
+
+Appendix 5 - 1998 through 2003 Agency Strategic Plan, Florida Department of Corrections Page 5 of 5
+Corrections.
+3. Correctional Education School; Authority Annual Report FY 1993-94
+and Paradox Special Education Database, Department of Corrections.
+4. Correctional Education School Authority, Based On Pre and Post
+Testing Sample Taken During the Period of July - December 1994.
+5. Correctional Education Status Report, July 1, 1994 - June 1, 1995.
+6. Corrections Yearbook 1994, Criminal Justice Institute, Inc., New York.
+7. Department of Corrections Affirmative Action Plan, FY 1994-95.
+8. Evelyn Gort Career Criminal Act, Chapter 98-152, Laws of Florida.
+9. Florida Administrative Code, Section 33-25.
+10. "Florida's Community Supervision Population Trends," Bureau of
+Research and Data Analysis, Department of Corrections, 1997.
+11. Governor's Sterling Award Application Manual.
+12. Governor's Sterling Award Manual, 1994
+13. Inmate Escape Report, FY 1996-1997, Bureau of Research and Data
+Analysis, Department of Corrections.
+14. "Minority Business Enterprise Program Final Report, FY 1993-94,",
+Pinky Douglas-Moore, Bureau of General Services, Department of
+Corrections.
+Recidivism Rates of Inmates Released from Florida's Prisons, June 30,
+1997, Department of Corrections.
+16. State Strategic Plan for Information Resource Management: FY 1995-
+99, Information Resource Commission, State of Florida, January 1994.
+17. "Strategic Planning at the Florida Department of Corrections: An
+Assessment Four Years into the Program," C. James Juang & Frances
+S. Berry, PhD, The Florida State University, July 1995.
+18. "Tier Program Outcome Evaluation: A Recommitment Study," Bureau
+of Planning, Research and Statistics, Department of Corrections.
+19. USA and Florida Department of Corrections Agreement, 5/19/92.
+top | previous | 24 of 26 | next
+Agency Strategic Plan
+1998 - 2003
+Home | Highlights | Reports | Facilities | Offender Search | FAQs | Search | Contact
+Privacy Policy
+
+
+RULES
+OF THE
+DEPARTMENT OF CORRECTIONS
+SENTENCE STRUCTURE AND TRANSPORTATION
+33-603.101
+33-603.201
+33-603.401
+33-603.402
+33-603.409
+33-603.410
+33-603.411
+33-603.412
+Use of Committed Name.
+(12-12-06)
+Transfer of Inmates. (8-28-01)
+Gain Time
+Definitions. (4-
+21-96)
+Hasic Gain Time. (3-24-96)
+Cancellation of Administrative
+Gain Time and Provisional
+Credita. (4-17-94)
+Credit for Time Served
+Following Apprehension in
+Another Juriadiction.
+(3-30-95)
+Warrants for Retaking
+Offenders. (1-06-94)
+Actual Release Date.
+(2-26-80)
+Use of Conmitted Name.
+(1) (a) In order to avoid conflicts in
+mailing and visiting privileges, as well as
+to assist inmates in making bank and canteen
+transactions and ensure timely delivery of
+legal documents, and to provide staff with a
+consistent meane of inmate identification for
+security and daily institutional operation
+purposes, each inmate shall be recognized by
+the department under the name on the initial
+commitment under which the inmate was
+received. The committed name shall be
+obtained from the information or indictment
+page of the cormitment package, not from the
+uniform commitment to custody cover sheet.
+For multiple cases imposed on separate dates,
+the committed name ls the name on the
+information page of the commitment of the
+earlieat imposed case.
+For multiple cases
+imposed on the same date, commitments are
+arranged according to service of the
+sentences or sequential order as directed by
+the sentencing court and the committed name
+is the name on the information page of the
+first imposed case as so designated. For
+multiple cases imposed on the same date where
+the order of sentencing cannot be determined,
+the cases are arranged numerically and the
+comnitted name is the name on the information
+page of the commitment with the lowest case
+number. This name shall be the inmate's
+official identification throughout the
+continuous incarceration of the inmate on
+that sentence or combined sentences and must
+be included on any official document sent or
+received by the inmate except as provided in
+(3) below.
+(b)
+The department shall register
+any known aliases on the inmate's record and
+shall also designate on the record which name
+is the Inmate's true or legal name if this
+information 1s available. If an inmate's true
+or legal name is not the committed name, the
+inmate shall be permitted to use the true or
+legal name on documents and mail so long as
+the committed name and DC number appear
+firat, followed by the true or legal name.
+(c) Legal Religious Names.
+1.
+Upon request of an inmate to
+include a legal religious name to the inmate
+Identification card, the warden or facility
+head shall forward the request and supporting
+documentation to the Office of the General
+Counsel for verification that the inmate's
+name has been legally changed for religious
+reasons through court order, birth
+certificate or other legally acceptable
+documentation.
+When verification is
+complete, the Office of the General Counsel
+shall notify the warden or facility head in
+writing.
+_ 2.
+The institution or facility
+shall affix a label to the reverse side of
+the inmate identification card which bears
+the following:
+This is to certify that the legal
+religious name of inmate DC# ——__ 18
+[INSERT LEGAL RELIGIOUS NAME]
+(Signature] Warden or Facility Head, Name
+of Facility
+A legal religious name change
+does not require that the department alter
+official records; the inmate's committed name
+shall be used for all department business.
+(d) Nothing in thin rule prohibite
+lesuance of an educational or vocational
+certificate in the Inmate's true or legal
+name providing that the office issuing such
+certificate provides a photocopy of the
+certificate to be placed in the inmate's
+institutional file and such copy alao
+reflects the inmate's committed name and
+identification number.
+(2) Incoming and outgoing mail
+shall be processed in accordance with rule
+33-210.101 and 33-210.102.
+603-1
+
+
+CHAPTER 33-503
+(3)
+An inmate who has litigation
+pending which was filed under a name other
+than the official name shall be responsible
+for notifying the institution or facility
+mailroom in writing of the name under which
+litigation ia pending.
+Incoming legal mail
+addressed to an inmate under a name other
+than the official committed name shall be
+forwarded to the inmate if the inmate has
+notified the mailroom of pending legal
+actions under this name.
+record of such notification by the inmate,
+the
+mailroom shall request that
+the
+appropriate institutional office check the
+offender
+information ayatem
+for
+identification of the addressee.
+If such
+effort fails to reveal proper identification,
+the mail shall be returned to the sender with
+appropriate
+notations
+that
+the addressee
+could not be identified.
+(4)
+An inmate who desires to have
+a document or documents
+notarized under a
+name other than the official committed name
+shall advise
+notarizing
+officer
+writing at least three working daye prior to
+requesting
+Buch
+notarization.
+notice
+shall specify the name
+under which the inmate
+plane to sign.
+The notary shall review the
+inmate's record to confirm that the name is a
+true or legal name or a known
+alias.
+there
+is
+no record of the name in the
+institutional
+flle,
+inmate
+cannot
+provide identification or documentation that
+the name is either his or her true or legal
+name, or that there is a legal action pending
+involving
+the inmate
+under such name, the
+officer
+shall
+ПОС
+notarize
+the signature.
+Following
+production of such identification
+or documentation,
+the
+notary shall notarize
+the document and indicate the manner by which
+the inmate was identified. If the inmate has
+obtained a legal religious name change and
+wishes to have documents notarized under this
+name, the legal religious name affixed to an
+inmate identification card shall be
+sufficient for purposes of provision of
+notary services unless there is a reason to
+believe that the information has been forged
+or altered.
+Specific Authority 944.09 FS.
+Law
+Implemented 944.09 FS. History--New 9-30-93,
+Formerly 33-6.012, Amended 4-29-02, 5-20-03,
+7-7-05, 12-12-06.
+33-603.201
+Transfer of Inmates.
+For the purposes of this rule
+"tranefer" shall mean the reassignment and
+SENTENCE STRUCTURE AND TANSPORTATION
+movement of inmates from one institutional
+facility to another.
+"Transfer" does not
+include such movement as may be required for
+the normal operations of the Department such
+outside tripe sponsored by religious,
+Jaycee and Alcoholics Anonymous groups and
+trips by work and maintenance crews.
+The
+institutional inmate record and all sub-files
+must accompany any inmate being routinely
+transferred between department facilities,
+except in emergency situations. In emergency
+situations
+medical
+records
+will
+be
+transferred with the inmate except that in
+emergencies such as the evacuation of a
+facility, the medical records will be boxed
+together with all records going to one
+location and forwarded to the receiving
+institution(s) with the inmates or as soon as
+possible.
+In such emergencies, individual
+packaging of medical records is waived.
+The
+institutional
+inmate
+record
+shall
+aleo
+accompany
+the
+inmate unless the
+inmate's
+health and welfare would be Jeopardized
+the transfer were delayed for the amount.
+of
+time required to obtain the record.
+Local
+procedures shall be established to ensure
+that appropriate facility staff have access
+to
+the
+institutional inmate
+record during
+weekende, holidays, and after normal business
+hours.
+Such procedures shall ensure that the
+security of the record is not compromised and
+that
+accountability
+for
+the
+record
+maintained in
+the event that
+ассевв
+is
+required other than during normal working
+hours.
+Following an emergency transfer, all
+other sub-files, such as the visiting record,
+educational record, property record,
+ete..
+shall be forwarded by the sending facility
+within 72 hours following the transfer.
+(2)
+In
+order
+to
+ensure
+coordination in the operation of the transfer
+system, ensure the safety of the public,
+employees and inmates and to maintain proper
+security practices, a qualified officer muat
+be in charge of each transfer. This rule
+shall also apply to work release centere
+except when inmate drivers are involved.
+(3)
+All Department
+employees
+transferring inmates shall be certified as
+Correctional officers.
+Transfer officers
+must also comply with the specific
+requirements outlined in Chapter 316, Florida
+Statutes.
+(4) The transfer officer shall be'
+responsible for
+maintaining schedules
+approved by the Bureau of Sentence Structure
+and
+Transportation,
+supervising
+and
+603-2
+
+
+inatructing additional personnel assigned,
+guarding inmates,
+maintaining order and
+discipline and ensuring the secure and safe
+custody of inmates being transferred.
+The transfer vehicle must be
+maintained in accordance with the guidelines
+set forth in Chapter 316, Florida Statutes,
+and be properly fueled,
+serviced and
+determined to be mechanically safe to
+transfer inmates. The vehicle shall be
+equipped with radio communication.
+thoroughly searched and all security features
+inspected prior to boarding any inmates.
+Continuing checks shall be made periodically
+by the tranafer officer while en route.
+Vehicle inspection shall be conducted during
+the time the transfer vehicle is
+prior to departing on or continuing a trip.
+transfer orders, commitment
+are in order prior to the boarding
+Each inmate must be properly
+identified by the transfer officer prior to
+assuming
+relinquishing
+supervision
+and
+control of the inmate.
+The transfer officer
+shall verify the identity of law enforcement
+agencies and their representatives prior to
+releasing an inmate into their custody.
+transfer
+officer
+shall
+ensure that all inmates are searched prior to
+the transfer vehicle.
+shall be conducted by or under the direct
+supervision
+transfer
+assistance is obtained from the inatitution.
+The Chief Health Officer may
+that an inmate who is mentally or
+physically 1l1 be transferred separately from
+the general population inmates. In addition,
+if there is any indication that an inmate who
+is to be transferred is not in good physical
+mental condition, the transfer officer
+shall secure the advice of the institution
+physician before beginning the trip. Transfer
+of an inmate who is il1 or injured shall be
+undertaken based on the advice of the Chief
+Health Officer on duty. The Chief Health
+Officer shall determine if medical staff are
+to accompany the inmate while being
+transferred. If he does decide that medical
+staff need to accompany the inmate, he must
+assign this staff.
+In transferring any death row,
+close management, or disciplinary confinement
+Inmate, or any inmate determined by the Chief
+of Security to be a high-risk inmate, the
+SENTENCE STRUCTURE AND TANSPORTATION
+following shall be required:
+(a)
+The inmate shall be restrained
+with handcuffs, waist chains with a C and 5
+handcuff cover (black box), and leg irons and
+transferred in a secure caged vehicle. The
+driver shall be unarmed in order to handle
+inmates en route if necessary.
+(b) The transfer vehicle shall be
+accompanied by a trailing escort vehicle
+driven by a well-armed officer. "Well-armed"
+shall mean possession of a semiautomatie
+If several inmates are being
+transferred, the transfer vehicle shall have
+a second armed officer in attendance.
+(d) Communication between the two
+vehicles ie essential and is required between
+both vehicles and the home station.
+The Chief of Security or shift
+supervisor is authorized to make individual
+exceptione to the assignment of a trailing
+escort vehicle for close management III and
+disciplinary confinement inmates.
+(f)
+The reception centers shall be
+authorized to transport close management I,
+II, and III inmates in the secure caged area
+within a specially designed secure transter
+bus without the neceasity of a trailing
+escort vehicle.
+(g)
+Protective management inmates
+shall not be routinely transported on
+reception center transfer buses. |
+(h)
+Specific written instructions
+will be provided from the transportation
+section of the Bureau of Sentence Structure
+and Transportation.
+(11)
+The transfer officer shall
+conduct a head count of inmates prior to
+departure and maintain continuing checke
+while en route and upon arrival at the
+receiving institution.
+(12)
+If more than one officer la
+assigned to the transfer trip, at least one
+officer shall remain with the vehicle to
+provide supervision during stops. When there
+1s only one officer, the vehicle must be
+parked in such a way that supervision can be
+provided for the vehicle and all inmates
+departing the vehicle. If stops occur within
+the secure confines of an institution and
+inmates remain on board the vehicle, the
+vehicle
+shall be parked so that the
+institution can provide proper supervision
+before the transfer officer leaves the
+vehicle.
+(13) Manpower requiremento shall
+vary depending upon the mode of transter, the
+603-3
+
+
+distance to be traveled and the type and
+number of inmates. Each situation must be
+thoroughly evaluated by Chief of Security or
+shift supervisor prior to departure and
+appropriate personnel assigned. A minimum of
+one armed correctional officer shall be
+assigned when there are close custody inmates
+to transfer except when special approval is
+received from the Director of Institutions.
+At all times, there must be at least one
+officer of the same sex as that of the inmate
+present during the transferring of medium,
+close, or maximum custody inmates. There
+shall be no gender restrictions regarding the
+transfer of community or minimum custody
+inmates. Community or minimum custody inmates
+do not require restrainte unless they are
+being transferred with close custody inmates
+or pose a security risk; however, there shall
+be an adequate number of officer escorts to
+provide appropriate supervision.
+Standard restraint equipment
+for the normal situation will be handcuffs
+and a restraint chain.
+specifically outlined below, additional
+restraints, such as waist chains with a C and
+5 handcuff cover (black box) and leg irons,
+shall be necessary when transferring death
+row and close custody inmates, Inmates who
+are extreme escape risko, inmates with
+serious assaultive tendencies, or any innate
+determined by the Chief of Security to be a
+high security rink.
+responsible for the custody of inmates, the
+transfer officer in charge has the authority
+to apply restraints to community custody
+inmates and additional restrainte to medium
+or minimum custody inmates when he or she
+determines that such is necessary to ensure
+When inmates are transferred
+within the state from one secure perimeter to
+another secure perimeter and a specially
+designed secure transfer bus 1a used, inmates
+may be restrained with leg irone only. Death
+row, close management, and high-risk inmates
+will require restraints as noted in (10)
+above during any transport.
+Each medium custody inmate who
+is not being transferred from one secure
+perimeter to another secure perimeter in a
+specially designed secure transfer bus shall
+be restrained with a minimum of handeuffs.
+Close custody inmates will require a waist
+chain with a C and S handeuft cover (black
+box) and leg irons under these circumstances.
+SENTENCE STRUCTURE AND TANSPORTATION
+leaving the secure perimeter. The restraints
+shall not be removed until the inmate is
+returned to a secure perimeter unless
+circumstances require their removal, that is,
+federal appearances or medical visits.
+(c)
+Use of restraint equipment,
+except for death row inmates, will not be
+required
+at
+Reception Centers
+for
+any
+transport on state property provided that a
+specially designed secure transfer bus is
+used; 1.e., from a Reception Center Main Unit
+to a Reception Center annex that is not
+separated by property not belonging to the
+Department of Corrections.
+(d)
+During any transport,
+level of restraints applied will
+the
+be
+commensurate with the highest custody grade
+being transported.
+(e)
+During prenatal and postpartum
+periods,
+female
+inmates
+will
+not
+be
+restrained with their hands behind the back
+nor will leg
+irone be utilized due to the
+poesibility of a fall. Waist chains with the
+C&S handcuff cover (black box) will not be
+worn when there is any danger of causing harm
+to the inmate or fetus.
+(E)
+Female
+Inmates,
+when being
+transferred on the same vehicle as
+male
+inmates, shall be phyaically separated from
+the male inmates by security screens and
+other security measures.
+(g)
+All restraint equipment shall
+be double locked.
+(h)
+An
+inmate
+shall
+handcuffed behind
+his
+or her
+not
+back
+be
+handcuffed to a stationary object in a moving
+vehicle.
+(i)
+A reasonable number of stope
+shall be made in order for inmates to utilize
+toilet facilities. Proper security shall be
+provided inmates when utilizing toilet
+lacilities on or off the transfer vehicle.
+(15) An Electronic Restraint Belt
+may be used in cases involving high profile
+transports outside the secure perimeter of an
+Institution where in the judgment of the
+security staff the use of the belt is
+warranted. Prior to usage of the Electronic
+Restraint Belt, written, signed approval must
+be obtained from the Office of Institutions,
+Bureau Chief of Security Operations.
+firearms in the transferring of inmates is
+extremely hazardous, in those instances where
+it 18 advisable for firearms to be carried,
+such equipment must be kept in a secure place
+or on the person of an officer who will not
+603-4
+
+
+come in direct contact with an inmate during
+entire trip. Firearms
+carried by any of the escorting officers
+while in a car, plane or train unless the
+inmate is securely restrained and positive
+precautionary measures have been taken that
+will preclude contact between inmates and the
+Use of firearms shall be in
+accordance with Rule 33-602.210, F.A.C./
+If an inmate escapes while
+being transferred, the transfer officer shall
+exhaust all resources Immediately available
+to him in apprehending the inmate and then
+take immediate action to contact the nearest
+law enforcement agency. As soon as possible,
+supervisor of the escape and give an oral
+report of the incident.. When the local law
+enforcement agency
+transfer officer
+circumatances shall supervision of other
+inmates be relaxed in order to pursue an
+escaping inmate.
+(18)
+Transfer
+by Commercial
+Airlines.
+Transfers via airlines shall be
+coordinated by
+the Bureau of Sentence
+Structure and Transportation.
+The Bureau of
+Sentence Structure and Transportation shall
+maintain liaison with the airlines and
+formulate standard operating procedures in
+accordance with Federal Aviation Agency and
+airline regulations.
+(19)
+Private Transport Companies.
+The Department is authorized to contract with
+private transport companies for the transfer
+prisoners both within and beyond
+The transport company shall
+take the prisoner into custody for the
+purpose of transferring the prisoner to the
+proper law enforcement official within or
+beyond the limits of this state.
+(b) The Department shall include,
+but not be limited to, the following
+requirements in any contract with a private
+transport company:
+Any private transport company
+transferring an inmate shall be considered an
+independent contractor and shall be solely
+liable for the inmate while he is in the
+custody of that company.
+The transport company shall
+maintain adequate liability coverage with
+respect to the transferring of inmates.
+Personnel employed with the
+transport company who are based in Florida
+SENTENCE STRUCTURE AND TANSPORTATION
+shall meet the minimum standards of a
+correctional or law enforcement officer in
+accordance with Chapter 943.13, Florida
+Statutes. Personnel who are based outside
+Florida shall meet the minimum standards of a
+correctional officer or law enforcement
+officer in the state where the employee is
+Transfer officers who
+based in Florida shall comply with the
+epecific requirements contained in Chapter
+316, Florida Statutes. Transfer officers who
+are based outside of Florida shall comply
+with the legal driving requirements of the
+state in which they are based.
+Bach transfer vehicle operated
+by the transport company must be maintained
+in a condition meeting the
+of Chapter 316, Florida
+and be mechanically safe to
+Transfer vehicles used
+maintained in a condition
+specific requirements of that state.
+The transport company shall
+adhere to standards which provide for humane
+treatment of inmates while in the custody of
+that company.
+7.
+The transport company shall
+submit reports to the Department regarding
+Incidents of escape, use of force, abuse, and
+accidents involving inmates in the custody of
+the transport company within 24 hours of the
+incident.
+Failure to report incidents,
+taleification of reports,
+coercing
+attempting to coerce others not to report or
+to faleify reports may result in appropriate
+criminal penalties and cancellation of the
+contract.
+The transport company shall
+hold a Class "B" license pursuant to Chapter
+493, Florida Statutes, and any employee of
+the company shall hold a Class "D" and Class
+"G" licenao pursuant to Chapter 493, Florida
+Statutes.
+9. Correctional
+administrators
+will refuse to release death row, close
+ustody, or other high-risk inmates to a
+private transport company or other law
+enforcement agencies that do not have an
+armed officer assigned or who do not provide
+a secure vehicle for transport. In these
+situations, the institution will:
+a. Refuse to release the inmate
+and advise the tranaport company or law
+enforcement officer to stand by.
+603-5
+
+
+b.
+Contact
+the
+Population
+Management section of the Bureau of Sentence
+Structure and Transportation during normal
+working hours.
+after normal working hours, contact the
+Emergency Action Center which will notify
+appropriate central office staff.
+Population Management staff
+will contact the on duty supervisor for the
+private transport agency or law enforcement
+agency involved and advise him or her of the
+specific concern. Thia will be documented
+and the results of thie contact relayed to
+the involved institutional staff providing
+specific directione regarding release.
+Specific Authority
+Implemented 944.09 FS. History--New 7-12-86,
+Amended 5-21-92, 1-06-94, 2-12-97, 11-8-98,
+Formerly 33-7.009, Amended B-2B-01.
+33-603.401
+Definitions.
+Gain
+Time
+SENTENCE STRUCTURE AND TANSPORTATION
+comnitted on or after October 1, 1995 shall
+be eligible to receive up to 10 days of
+incentive gain time per month, except as
+provided in 33-601,101 (1).
+(d)
+Inmates sentenced as violent
+career criminals for offenses committed on or
+after October 1, 1995 shall be eligible to
+receive up to 5 days of incentive gain time
+per
+month,
+except as provided in 33-
+Enhanced Incentive Gain Time--
+Gain time that is considered on a monthly
+basis for all inmates who are eligible and
+have worked diligently, participated in
+used time constructively or
+otherwise engaged in positive activities.
+Inmates convicted of offenses occurring on or
+after January 1, 1994 which fall within level
+through 7 of the sentencing guldelines
+offense severity chart (921.0012 P.S.) are
+eligible to receive up to 25 days of enhanced
+incentive gain time per month, pursuant to
+33-601.101(3), except as provided in 33-
+inmate who performs an outstanding deed, such
+an saving a life or assisting in recapturing
+an escaped inmate,
+or who in some manner
+performs an outstanding service that would
+merit the granting of additional deductions
+from his sentence length, may be awarded
+Incentive Gain Time--Gain time
+that 1e considered on a monthly basis for all
+diligently, participated in training, used
+time conatructively or otherwise engaged in
+positive activities. |
+Inmates convicted of offenses
+occurring prior to January 1, 1994 shall be
+eligible to receive up to 20 days of
+incentive gain time per month, pursuant to
+33-601.101(3), except a provided in 33-
+601.101 (1).
+Inmates convicted of offenses
+occurring on or after January 1, 1994 which
+tall within level from B through 10 of the
+sentencing guidelines offense severity chart
+(921.0012 F.S.) shall be eligible to receive
+up to 20 days of incentive gain time per
+month, pursuant to 33-601.101(3), except as
+provided in 33-601.101 (1).
+Inmates convicted of offenses
+Incentive Gain Time.
+The following ratings
+are based. on behavioral objectives as set
+forth in rule 33-601.101(3) (a)1. and 2.
+(a)
+"Unsatisfactory" --The inmate
+failed to meet a behavioral objective during
+"Satisfactory"--The inmate met
+all behavioral objectives during the month.
+"Above satisfactory".. The
+inmate met all behavioral objectives during
+the month and exceeded what is reguired to
+comply with one or more of the behavioral
+objectives.
+Specific Authority 944.09, 944.275 FS. Law
+Implemented 944.09, 944.275 PS. History"-New
+2-26-80, Amended 1-12-83, 1-31-85, Formerly
+33-11.035, Amended 4-17-94, 1-4-95, 3-24-96,
+4-21-96, Formerly 33-11.0035-
+33-603.402
+Basic Gain Time. The
+Department
+of Corrections will award
+deductions from a sentence in the form of
+basic gain time to encourage satisfactory
+inmate behavior.
+603-6
+
+
+(a) No inmate shall be eligible to
+receive or accumulate basic gain time:
+For the mandatory minimum
+portion of a sentence imposed pursuant to s.
+775.087(2), F.S. for an offende committed on
+or after October 1, 1976 involving use or
+possession of a firearm, machine gun, or
+destructive device as defined in s. 775.087,
+2-
+For the minimum portion of a
+sentence imposed pursuant to s. 893.13 (1) (e),
+F.S. (1989) for a specified drug-related
+offense committed on or after June 27, 1989
+but prior to January 1, 1994, in, on, or
+within 1,000 feet of a school;
+If sentenced as a habitual
+felony offender or a habitual violent felony
+offender under s. 775.084 (4), F.S. for an
+offense which occurred on or after October 1,
+1988; or
+893.13(1) (1) 1, F.S. (1991) for a specified
+January 1, 1994 in, on, or within 200 feet of
+real properties described in s. 893.13, F.S.;
+If serving a sentence
+definite term; that is, a life sentence or
+death sentence.
+For the period of time
+remaining in any treatment program placement
+term Imposed under s. 953.11 F.S.
+7.
+If sentenced for any degree of
+sexual battery specified under 8. 794.011 PS
+for a crime conmitted on or after October 1,
+If serving a sentence for
+SENTENCE STRUCTURE AND TANSPORTATION
+law enforcement duties in those instances
+where the offense was committed prior to
+January 1, 1994.
+eligible for basic gain time in an amount
+which would cause a sentence to expire prior
+to such inmate having served the period of
+for which the court has retained
+jurisdiction pursuant to s. 947.16(4) F.9.
+sentences of life or death, or sentences
+imposed for offenses committed on or after
+January 1, 1994, basic gain time credit will
+awarded to all other cases unless
+specifically prohibited by applicable law.
+How credited. Basic gain time
+shall be calculated at the rate specified by
+law according to the date of offense
+shall be based on the length of the sentence
+prorated on the basis of a 30-day month.
+Portions of any sentences
+concurrently shall be treated as a single
+sentence when determining basic gain time.
+For offenses committed prior
+to July 1, 1978, basic gain time shall be
+awarded in the amount of 5 daya per month for
+the first and second years of the sentence,
+10 days per month for the third and fourth
+years of the sentence and 15 days per month
+for all succeeding years of the sentence,
+pursuant to 5 944.27 (1977), F.S.
+after July 1, 1978, but before January 1,
+1994, basic gain time shall be awarded in the
+amount of 10 days for each month
+sentence imposed, pursuant to
+to such inmate having served the minimum or
+mandatory minimum portion of a sentence
+imposed pursuant to:
+1.
+s. 775.0823,
+F.S.
+for
+specified crimes committed prior to January
+1, 1994 against a law enforcement or
+in B. 943.10 (1), (2), (3), (6), (7), (8), or
+(9), or any state attorney, or assistant
+state attorney on or after January 1, 1990,
+or against a judge or justice of a court
+described in Article | of the State
+Constitution on or after October 1, 1990;
+2.
+S. 775. 0875(1) B.S. for taking
+a firearm from a law enforcement officer
+while such officer was lawfully engaged in
+initial tentative release date, basic gain
+time awards are made in a lump sum upon entry
+into the department's custody.
+For inmates
+serving a sentence with a minimum term as
+described in subparagraph (1) (a) 1. and 2.,
+the lump sum award of basic gain time is
+limited to that portion of the sentence or
+sentences which exceeds the minimum term.
+Specific Authority 794.011(7),/
+944.09,
+944.275 FS.
+Law Implemented 794.011(7),
+944.09, 944.275 FS. History -- Nèw 2-26-80,
+Formerly 33-11.045, Amended 1-12-83, 1-31-85,
+4-28-87, 12-18-BB, 10-14-91, 3-23-93, 4-17-
+94, 3-24-96, Formerly 33-11.0045.
+33-603.409
+Cancellation
+of
+Administrative Gain Time and Provisional
+Credita. Effective June 17, 1993, any inmate
+603-7
+
+
+serving a sentence or combined sentences where
+one or more days of administrative gain time
+or provisional credita have been applied,
+shall have all such awards cancelled, and
+release dates of such offenders shall be
+extended accordingly. Other conditions under
+which previously awarded administrative gain
+time or provisional credita shall be cancelled
+when a release date is reestablished are as
+follows:
+Upon revocation of any postrelease supervision program;
+(2)
+Upon recapture following
+escape;
+(3)
+Upon return from release on
+bond;
+Upon determination that an
+inmate'a release date was not calculated in
+accordance with case law or statute.
+Specific Authority 944.278 FS.
+Implemented 944.278 FS. History - New 4-17-
+94, Formerly 33-11.019.
+Credit for Time Served
+Following
+Apprehension in Another
+Juriadiction. An escapee or an absconder from
+supervised community release or provisional
+release supervision shall be eligible for
+credit for time served following apprehension
+in another jurisdiction as followe:
+If the offender is being held
+solely on the Department of Corrections'
+warrant, credit will be appiled from the date
+of arrest. However, If the offender refuses
+to waive extradition, credit will be stopped
+on the date of such refusal and will not
+resume until the offender 1e taken into
+custody by agente of the department, or the
+offender subsequently signe a waiver of
+extradition.
+(2)
+An offender who is arrested
+and charged with crimes committed in an outof-state jurisdiction shall not be eligible
+for credit for time served on the Florida
+sentence until such additional charges are
+disposed of and the offender is being held
+solely on the department'e warrant. In such
+instances, credit shall be allowed from the
+date of dispoaition of local charges.
+(3)
+If the offender is bondable on
+the out-of-state charges, credit may be
+applied from the date of arrest upon receipt
+of appropriate documentation that
+such
+offenses were bondable.
+Specific Authority 944.09, 944.275 FS. Law
+Implemented 944.09, 944.275 FS. History--New
+SENTENCE STRUCTURE AND TANSPORTATION
+3-30-95, Formerly 33-3.0106.
+33-603.411
+Warrants for Retaking
+Offenders.
+(1)
+When an offender escapes from
+custody or absconds from a rehabilitative
+community reentry program prior to
+satisfaction of the sentence or combined
+sentences, or if it is determined that an
+offender was released in error, or If it is
+subsequently determined that the offender was
+statutorily ineligible for
+release,
+Secretary of the Department or the secretary's
+designated representative shall issue a
+warrant for retaking such offender into
+custody to serve the remainder of such
+sentence or corbined sentences. The warrant
+issued shall:
+(a)
+Be in writing and in the name
+of the Department of Corrections;
+(b)
+Command that law enforcement
+officials take the offender against whom the
+warrant is issued into custody and hold him
+until such time as proper arrangements can be
+made for the return of the offender to the
+department;
+(c)
+Specify the
+name of
+the
+offender to be apprehended,
+the
+date of
+cacape, date of abaconding from supervision,
+or the date on which the offender was released
+in error, the date the offender was sentenced
+to incarceration in the department, the county
+of sentence, the term of sentence; and
+(d)
+Bear
+the
+Beal
+of
+the
+Department of Corrections.
+(2)
+An offender who is arrested as
+provided in subsection (1) above in ineligible
+for
+bond,
+bail, or release on
+his
+oWn
+recognizance.
+pursuant to this rule does not negate or
+interfere with the right to issuance of a
+warrant under any other provision of law, nor
+will it interfere with any charges or court
+proceeding pending against the Individual in
+any other jurisdiction.
+(4)
+A warrant issued by the
+Department shall be in effect until the inmate
+has been returned to the custody of the
+Department, or until the sentence being served
+by the inmate is deemed satisfied, whichever
+occura first.
+(5)
+The following procedures shall
+be followed in cases of offenders who were
+released in error or were aubeequently
+determined to be statutorily ineligible for
+release:
+603-8
+
+
+" . .
+SENTENCE STRUCTURE AND TANSPORTATION
+{a)
+within three days of receiving
+notification that the offender has been taken
+into custody, exeluding the day of notice,
+weekends
+and holidays,
+a correctional
+probation officer, classification supervisor,
+or other person designated by the Bureau Chief
+of Miniseion and Release for that purpose
+shall provide the offender with a copy of the
+affidavit upon which the warrant was issued, a
+copy of the warrant, a written statement
+advising the offender that he or she may
+challenge his return to custody through use of
+the inmate grievance procedure, and a copy of
+Form DC1-303, Request for Administrative
+Remedy or Appeal. In those cases in which the
+offender is out of state, the time frame for
+delivery of the warrant package to the
+offender shall be extended to seven days,
+excluding the day of notice, holidays and
+weekende.
+offender
+who wishes to
+challenge his or her return to Department of
+Corrections custody shall file an emergency
+grievance directly with the Office of the
+Secretary using the Request for Administrative
+Remedy or Appeal, Form DC1-303, in accordance
+with rule 33-103.007 (5).
+filed with the
+office of the Secretary regarding retaking of
+an offender into custody shall be responded to
+in accordance with the time frames set forth
+in rule 33-103.007 and 33-103.011.
+(d)
+Nothing in this section shall
+be deemed to conatitute a waiver by the
+Department of Corrections of its authority or
+Jurisdiction to retake offenders into custody
+under the
+circumstances set
+forth
+in
+subeection (1) of this rule, nor shall any
+procedure had under this section which resulta
+in or fails to result in retaking be deemed a
+waiver by the department of its authority or
+jurisdiction to retake offenders.
+specifie Authority 944.405 FS.
+Law
+Implemented 944.405 FS. History--New 2-29-88,
+1-06-94, Formerly 33-3.0105.
+33-603.412
+Actual Release Date.
+A sentence expires at midnight, but release
+may be granted at any hour on such release
+date.
+Specific Authority 944.09 FS. Law Implemented
+944.09, 944.275 FS. History--New 2-26-80,
+Formerly 33-11.12, Formerly 33-11.012.|
+603-9
+
+
+Completing the Scoresheet
+1. Date of Sentence
+• Record the date the sentence was imposed
+2. Scoresheet Preparer
+* Indicate the first and last name of the state
+attorney who prepared the scoresheet.
+3. County
+• Record the name of the county where the
+sentence is imposed. In instances of a change
+of venue, record the county that received the
+case.
+4. Senteneing Judge
+• Record the full name of the judge imposing
+sentence.
+5. Name
+• Record the offender's legal name used at the
+time of senteneing. Record the name using the
+following format: last name, first name,
+middle initial. Do not record aliases.
+6. Date of Birth
+• Record the offender's date of birth.
+7. DC Number
+• Record the six digit number assigned by the
+Department of Corrections if available.
+8. Race
+• Check the appropriate box to note the race of
+the offender. Use the following criteria:
+B) Black - a person having origins in any of the
+black racial groups of Africa.
+* (Other) - a person having origins in any of the
+original peoples of the Far East, southeast
+Asia, Indian subcontinent, Pacific Islands, or
+any of the original people of the Americas,
+including Native Americans or Alaskan
+natives.
+9. Gender
+• Check the appropriate box to indicate the
+gender of the offender.
+10. Primary Offense Date
+• The date of the "primary offense" pending
+before the court for sentencing. If the
+primary offense involves dates of continuing
+enterprise, record the date the criminal
+activity commenced.
+11. Primary Docket Number
+• The felony court case number of the primary
+sentencing shall be classified as the primary
+offense.
+8
+
+
+12. Plea or Trial
+• Check whether the adjudication of the offenses
+at conviction was obtained by plea or trial. If
+convictions were obtained by both plea and
+trial, enter a check mark in the trial field.
+13. Primary Offense
+"Primary offense" means the offense at
+conviction pending before the court for sentencing
+for which the total sentence points recommend a
+sanction that is as severe as, or more severe than,
+the sanction recommended for any other offense
+committed by the offender and pending before the
+court at sentencing. Only one count of one offense
+before the court for sentencing shall be classified
+as the primary offense.
+All other offenses,
+including multiple counts of the same offense
+scored as the primary offense, are to be listed as
+additional offenses.
+The primary may be an
+offense ranked at a lower severity level than other
+offenses before the court for sentencing due to the
+operation of multipliers for drug tratficking›
+grand theft motor vehicle (with the requisite prior
+record) violations of the Law Enforcement
+Protection Act, Street Gang
+and Domestic
+Violence. The Felony Degree,
+Florida Statute,
+Description and Offense Level shall be recorded
+in the appropriate field of Section I. The points
+assigned to the severity level of the offense are
+entered in the space indicated on the scoresheet.
+An offense before the court as a result of a finding
+of violation of a community sanction is the
+primary offense if the original charge total
+sentence points recommend a sanction that is as
+severe as, or more severe than, the sanction
+recommended for any other offense committed by
+the offender and pending before the court at
+sentencing under any single version of the
+guidelines, revision of the guidelines or
+punishment code. This is in accordance with
+sections 775.082 (8), 921.0021(1), 921.0021(4) and
+921.0024(3), Florida Statutes.
+Prior Capital Felony Points/Primary Offense
+If the offender has one or more prior
+capital felonies in the offender's criminal record,
+points shall be added to the subtotal sentence
+points of the offender equal to twice the number of
+points the offender receives for the primary
+offense. This is recorded by checking the box in
+Section I and multiplying the Section I subtotal by
+3 (three).
+A prior capital felony in the offender's
+criminal record is a previous capital felony offense
+for which the offender has entered a plea of nolo
+contendre or guilty or has been found guilty, or a
+felony in another jurisdiction which is a capital
+felony in that jurisdiction, or would be a capital
+felony if the offense were committed in this state.
+14. Additional Offenses
+Additional offense means any offense other
+than the primary offense for which an offender is
+convicted and which is pending before the court
+for sentencing at the time of the primary offense.
+The severity level of each additional offense must
+be known in order to score it. Multiple counts of
+the same offense can be listed on a single line with
+the points indicated for that severity level
+multiplied by the number of counts. The resulting
+points are recorded in the fields in the right hand
+column. Misdemeanors are scored at the level
+"M" regardless of degree. A supplemental page is
+available for additional offenses if the available
+lines are not sufficient for all additional offenses.
+An offense before the court as a result of a
+finding of violation of a community sanction is an
+additional offense if the original charge total
+sentence points do not recommend a sanction that
+is as severe as, or more severe than, the sanction
+recommended for any other offense committed by
+the offender and pending before the court at
+9
+
+
+sentencing under any single version of the
+guidelines, revision of the guidelines or
+punishment code. This is in accordance with
+sections 775.082 (8), 921.0021(I), 921.0021(4) and
+921.0024(3), Florida Statutes.
+Prior Capital Felony Points /
+Additional Offense
+If the offender has one or more prior
+capital felonies in the offender's criminal record,
+points shall be added to the subtotal sentence
+points of the offender equal to twice the number of
+points the offender receives for the additional
+offense(s). This is calculated by checking the box
+in Section II and multiplying the Section I|
+subtotal by 3 (three).
+A prior capital felony in the offender's
+criminal record is a previous capital felony offense
+for which the offender has entered a plea of nolo
+contendre or guilty or has been found guilty; or a
+felony in another jurisdiction which is a capital
+felony in that jurisdiction, or would be a capital
+felony if the offense were committed in this state.
+Prior capital felonies shall not be seored in the
+prior record section.
+15. Attempts, Conspiracies, Solicitations and
+Reclassifications
+Criminal attempts, criminal solicitations
+and criminal conspiracies are generally scored one
+level below the severity level of the completed
+offense. Where a criminal attempt, solicitation or
+conspiracy is separately ranked in section
+921.0022, Florida Statutes, the severity level at
+which the inchoate offense is placed is the basis
+for scoring. Where the inchoate version of an
+offense is required to be punished as if the
+offender had committed the prohibited act, score
+it at the same level as the completed crime.
+Conspiracy to commit drug trafficking under
+section 893.135(5), Florida Statutes, or conspiring
+to commit bookmaking under section 849.25(4),
+Florida Statutes, or attempting, soliciting or
+conspiring to kill or commit aggravated abuse
+upon registered horses or cattle 828.125(2),
+Florida Statutes, are examples of legislative intent
+to punish the inchoate versions of an offense the
+same as the completed offense. Unless specifically
+provided otherwise by statute, attempts,
+conspiracies, and solicitations must be indicated in
+the space provided on the Criminal Punishment
+Code scoresheet and must be scored at one
+severity level below the completed offense.
+Attempts, solicitations, and conspiracies of
+third-degree felonies located in offense severity
+levels 1 and 2 must be scored as misdemeanors.
+Attempts, solicitations, and conspiracies of thirddegree felonies located in offense severity levels 3,
+4, 5, 6, 7, 8, 9, and 10 must be scored as felonies
+one offense level
+beneath the incomplete or
+inchoate offense.
+16. Vietim Injury
+"Victim injury" is scored for physical
+injury or death suffered by a person as a direct
+result of any offense pending before the court for
+sentencing. Except as otherwise provided by law
+(section 921.0021(7) (c) (d), Florida Statutes) the
+sexual penetration and sexual contact points will
+be scored as follows. Sexual penetration points
+(80) are scored if an offense pending before the
+court for sentencing involves sexual penetration.
+Sexual contact points (40) are scored if an offense
+pending before the court for sentencing involves
+sexual contact, but no penetration. If the victim of
+an offense involving sexual penetration or sexual
+contact without penetration suffers any physical
+injury as a direct result of an offense pending
+before the court for sentencing, that physical
+injury must be scored separately and in addition
+to any points scored for the sexual contact or
+sexual penetration.
+Vietim injury must be scored for each
+10
+
+
+victim physically injured and for each offense
+resulting in physical injury whether there are one
+or more victims. Multiple assessments of the same
+level of victim injury may be scored by
+multiplying the appropriate level of injury by the
+number of counts scoreable. However, victim
+injury must not be scored for an offense for which
+the offender has not been convicted.
+If the offense at conviction is a second
+degree murder, 240 points are to be scored for the
+death. All other deaths are to receive 120 points as
+victim injury.
+Victim injury resulting from one or more
+capital offenses before the court for sentencing
+must not be included upon any scoresheet
+prepared for non-capital offenses also pending
+before the court for sentencing. This does not
+prohibit the scoring of victim injury as a result of
+the non-capital offense or offenses before the
+court for sentencing.
+17. Prior Record
+"Prior record" refers to any conviction for
+an offense committed by the offender prior to the
+commission of the primary offense. "Conviction"
+means a determination of guilt that is the result of
+a plea or trial, regardless of whether adjudication
+is withheld.
+Prior record includes convictions for
+offenses committed by the offender as an adult or
+juvenile, convictions by federal, out of state,
+military, or foreign courts and convictions for
+violations of county or municipal ordinances that
+incorporate by reference a penalty under state
+law. Federal, out of state, military or foreign
+convictions are scored at the severity level at
+which the analogous or parallel Florida crime is
+located. The elements of an out-of-state offense
+are to be the sole consideration for determining an
+analogous crime
+Convictions for offenses committed more than 10
+years before the date of the commission of the
+primary offense must not be scored as prior
+record if the offender has not been convicted of
+any other crime for a period of 10 consecutive
+years from the most recent date of release from
+confinement, supervision, or other sanction,
+whichever is later, to the date of the commission of
+the primary offense.
+Juvenile dispositions of offenses committed by the
+offender within 5 years before the date of the
+commission of the primary offense must be scored
+as prior record if the offense would have been a
+crime if committed by an adult.
+Juvenile
+dispositions of sexual offenses committed by the
+offender more than 5 years before the date of the
+primary offense must be scored as prior record if
+the offender has not maintained a conviction-free
+record, either as an adult or as a juvenile, for a
+period of 5 consecutive years from the most recent
+date of release from confinement, supervision, or
+sanction, whichever is later, to the date of
+commission of the primary offense.
+Entries in criminal histories that show no
+disposition, disposition unknown, arrest only, or a
+disposition other than conviction must not be
+scored. Criminal history records expunged or
+sealed under section 943.058, Florida Statutes, or
+other provisions of law, including former sections
+893.14 and 901.33, Florida Statutes, must be
+scored as prior record where the offender whose
+record has been expunged or sealed is before the
+court for sentencing.
+Any uncertainty in the scoring of the offender's
+prior record must be resolved in favor of the
+offender and disagreement as to the propriety of
+scoring specific entries in the prior record must be
+resolved by the sentencing judge.
+When unable to determine whether the conviction
+to be scored as prior record is a felony or a
+misdemeanor, the conviction must be scored as a
+11
+
+
+misdemeanor. When the degree of felony is
+ambiguous or the severity level cannot be
+determined, the conviction must be scored at
+severity level 1.
+18. Legal Status Violations
+"Legal status points" are assessed when an
+offender:
+Escapes from incarceration; flees to avoid
+prosecution; fails to appear for a criminal
+proceeding;
+violates any condition of a
+supersedeas bond; is incarcerated; is under any
+form of a pretrial intervention or diversion
+program; or is under any form of court-imposed
+or post-prison release community supervision and
+commits an offense that results in conviction.
+Legal status violations receive a score of 4
+sentence points and are scored when the offense
+committed while under legal status is before the
+court for sentencing.
+Points for a legal status
+violation must only be assessed once regardless of
+the existence of more than one form of legal status
+at the time an offense is committed or the number
+of offenses committed while under any form of
+legal status.
+19. Violating the Conditions of a Community
+Sanction
+Community sanction violation points occur
+when the offender is found to have violated one or
+more conditions of a community sanction.
+Community sanctions include probation,
+community control or pretrial intervention or
+diversion.
+Community sanction violation points are
+assessed when a community sanction violation is
+before the court for sentencing as a primary or
+additional offense. Six community sanction
+violation points must be assessed for each
+violation or if the violation results from a new
+12
+felony conviction, 12 community sanction
+violation points must be assessed. Where there
+are multiple violations, points may be assessed
+only for each successive violation that follows a
+continuation of supervision, or modification or
+revocation of the community sanction before the
+court for sentencing and are not to be assessed for
+violation of several conditions of a single
+community sanction.
+Multiple counts of
+community sanction violations before the
+sentencing court may not be the basis for
+multiplying the assessment of community sanction
+violation points.
+20. Prior Serious Felony Points
+A single assessment of thirty prior serious
+felony points is added if the offender has a
+primary offense or any additional offense ranked
+in level 8, 9, or 10 (under sections 921.0022 or
+921.0023, Florida Statutes) and one or more prior
+serious felonies. A "prior serious felony" is an
+offense in the _offender's prior record ranked in
+level 8, 9, or 10 and for which the offender is
+serving a sentence of confinement, supervision or
+other sanction or for which the offender's date of
+release from confinement, supervision, or other
+sanction, whichever is later, is within 3 years
+before the date the primary offense or any
+additional offenses were committed. Out of state
+convictions wherein the analogous or parallel
+Florida offenses are located in offense severity
+level 8, 9, or 10 must be considered prior serious
+felonies.
+Possession of a Firearm, Semiautomatic Weapon
+or Machine Gun
+Possession of a firearm, semiautomatic firearm, or
+a machine gun during the commission or attempt
+to commit a crime will result in additional
+sentence points. Eighteen sentence points are
+assessed if the offender is convicted of committing
+or attempting to commit any felony other than
+those enumerated in subsection 775.087(2),
+
+
+Florida Statutes, while having in his or her
+possession a firearm as defined in subsection
+790.001(б), Florida Statutes. Twenty-five sentence
+points are assessed if the offender is convicted of
+committing or attempting to commit any felony
+other than those enumerated in subsection
+775.087(3), Florida Statutes, while having in his or
+her possession a semiautomatic firearm as defined
+in subsection 775.087(3), Florida Statutes, or a
+machine gun as defined in subsection 790.001(9),
+Florida Statutes. Only one assessment of either 18
+or 25 points can be made.
+Firearm points may not be assessed where the
+possession of the firearm is necessary in order for
+the underlying felony to exist. In other words, if
+the offense is possession of a firearm by a
+convicted felon or carrying a concealed firearm,
+the additional points should not be assessed. Also,
+if the offense is one of those enumerated in section
+775.087 (2) or (3), Florida Statutes, firearm points
+may not be assessed.
+21. Subtotal Sentence Points
+"Subtotal sentence points" are the sum of
+the primary offense points, the total additional
+offense points, the total victim injury points, the
+total prior record points, any legal status points,
+community sanction points, prior serious felony
+points, prior capital felony points and points for
+possession of a firearm or semiautomatic weapon.
+22. Sentencing Enhancements
+If the primary offense is drug trafficking
+under section 893.135, Florida Statutes, ranked in
+offense severity level 7 or 8, the subtotal sentence
+points may be multiplied, at the discretion of the
+sentencing court, by a factor of 1.5.
+If the primary offense is a violation of the Law
+Enforcement Protection Act under subsections
+775.0823(2), Florida Statutes, the subtotal
+sentence points are multiplied by 2.5. If the
+primary offense is a violation of subsection
+775.0823(3), (4), (5), (б), (7), or (8), Florida
+Statutes,
+the subtotal sentence points are
+multiplied by 2.0. If the primary offense is a
+violation of the Law Enforcement Protection Act
+under subsection 775.0823(9) or (10), Florida
+Statutes, or section 784.07(3), Florida Statutes, or
+section 775.0875(1), Florida Statutes, the subtotal
+sentence points are multiplied by 1.5.
+If the primary offense is grand theft of the third
+degree of a motor vehicle and the offender's prior
+record includes three or more grand thefts of the
+third degree of a motor vehicle, the subtotal
+sentence points are multiplied by 1.5.
+If the Offender is convicted of the primary offense
+and committed the offense for the purpose of
+benefiting, promoting, or furthering the interests
+of a criminal street gang under section 874.04,
+Florida Statutes, of the commission of the primary
+offense, the subtotal sentence points are multiplied
+by 1.5.
+If the primary offense is a crime of domestic
+violence as defined in section 741.28, Florida
+Statutes, which was committed in the presence of
+a child under 16 years of age who is a family
+household member as defined in section 741.28(2),
+Florida Statutes, with the victim or perpetrator,
+the subtotal sentence points are multiplied, at the
+discretion of the court, by 1.5.
+23. Total Sentence Points
+"Total sentence points" are the subtotal
+points. Do not add the subtotal sentence points
+and the enhanced subtotal points to arrive at total
+minimum sentence that may be imposed by the
+trial court, absent a valid reason for departure
+The lowest permissible sentence is any nonstate
+
+
+prison sanction in which the total sentence points
+equals or is less than 44 points, unless the court
+determines within its discretion that a prison
+sentence, which may be up to the statutory
+maximums for the offenses committed, is
+appropriate.
+When the total sentence points
+exceed 44 points, the lowest permissible sentence
+in prison months must
+be calculated by
+subtracting 28 points from the total sentence
+points and decreasing the remaining total by 25
+percent. The total sentence points must be
+calculated only as a means of determining the
+lowest permissible sentence. The permissible
+range for sentencing must be the lowest
+permissible sentence up to and including the
+statutory maximum, as defined in section 775.082,
+Florida Statutes, for the primary offense and any
+additional offenses before the court for
+sentencing. The sentencing court may impose
+such
+sentences concurrently or consecutively.
+However, any sentence to state prison must exceed
+1 year. If the lowest permissible sentence under
+the Code exceeds the statutory maximum sentence
+as provided in section 775.082, Florida Statutes,
+the sentence required by the Code must be
+imposed. If the total sentence points are greater
+than or equal to 363, the court may sentence the
+offender to life imprisonment.
+The sentence
+imposed must be entered on the scoresheet.
+24. Mandatory Minimum Sentence
+For those offenses having a mandatory minimum
+sentence, a scoresheet must be completed and the
+lowest permissible sentence under the code
+calculated. If the lowest permissible sentence is
+less than the mandatory minimum sentence, the
+mandatory minimum sentence takes precedence.
+If the lowest permissible sentence exceeds the
+mandatory sentence, the requirements of the
+Criminal Punishment Code and any mandatory
+minimum penalties will apply. Mandatory
+minimum sentences must be recorded on the
+scoresheet.
+14
+25. Split Sentence
+If a split sentence is imposed, the total sanction
+(incarceration and community control
+or
+probation) must not exceed the term provided by
+general law or the maximum sentence under the
+Criminal Punishment Code.
+26. Revocation of Supervision
+Sentences imposed after revocation of probation
+to the sentering have applicable at pose tine roane
+commission of the original offense.
+27. Departures
+Any downward departure from the lowest
+permissible sentence, as calculated according to
+the total sentence points pursuant to section
+921.0024, Florida Statutes, is prohibited unless
+there are circumstances or factors that reasonably
+justify the downward departure. Mitigating
+circumstances or factors that can be considered
+include, but are not limited to, those listed in
+subsection 921.0026(2), Florida Statutes, and
+attached in Appendix D.
+If a sentencing judge imposes a sentence that is
+below the lowest permissible sentence, it is a
+departure sentence and must be accompanied by a
+written statement by the sentencing court
+delineating the reasons for the departure, filed
+within 7 days after the date of sentencing. A
+written transcription of orally stated reasons for
+departure articulated at the time sentence was
+imposed is sufficient if it is filed by the court
+within 7 days after the date of sentencing. The
+sentencing judge may also list the written reasons
+for departure in the space provided on the
+Criminal Punishment Code scoresheet.
+
+
+The written statement delineating the reasons for
+departure must be made a part of the record. The
+written statement, if it is a separate document,
+must accompany the scoresheet required to be
+provided to the Department of Corrections
+pursuant to section 921.0024(6), Florida Statutes.
+The imposition of a sentence below the lowest
+permissible sentence is subject to appellate review
+under Chapter 924, but the extent of the
+downward departure is not subject to appellate
+review.
+15
+
+
+APPENDIX A
+Rule 3.704. The Criminal Punishment Code
+(a) Use. This rule is to be used in conjunction with the forms located at rule 3.992. This rule
+amples ens tense 20 mimid o Purier Oute 1, in 6a, or anot wrih hequire by Morida Statures. This rule
+(b)
+Purpose and Construction. The purpose of the 1998 Criminal Punishment Code and the
+principles it embodies are set out in subsection 921.002(1), Florida Statutes. Existing case law construing the
+application of sentencing guidelines will continue as precedent unless in conflict with the provisions of this rule or
+the 1998 Criminal Punishment Code.
+(c)
+Offense Severity Ranking.
+()
+Felony offenses subject to the 1998 Criminal Punishment Code are listed in a single offense
+severity ranking chart located in section 921.0022, Florida Statutes. The offense severity ranking chart employs 10
+offense levels, ranked from least severe to most severe. Each felony offense is assigned to a level according to the
+severity of the offense, commensurate with the harm or potential for harm to the community that is caused by the
+offense, as determined by statute. The numerical statutory reference in the left column of the chart and the felony
+degree designations in the middle column of the chart determine whether felony offenses are specifically listed in
+the offense severity ranking chart and the appropriate severity level. The language in the right column is merely
+descriptive.
+(2) Felony offenses not listed in section 921.0022, Florida Statutes, are assigned a severity level in
+accordance with section 921.0023, Florida Statutes, as follows:
+(A) A felony of the third degree within offense level 1.
+(B) A felony of the second degree within offense level 4.
+(C) A felony of the first degree within offense level 7.
+(D) A felony of the first degree punishable by life within offense level 9.
+(E) A life felony within offense level 10.
+An offense does not become unlisted and subject to the provisions of section 921.0023, Florida Statutes, because
+of a reclassification of the degree of felony under section 775.0845, section 775.087, section 775.0875 or section
+794.023, Florida Statutes, or any other law that provides an enhanced penalty for a felony offense.
+(d)
+(1)
+General Rules and Definitions.
+One or more Criminal Punishment Code scoresheets must be prepared for each offender covering
+16
+
+
+all offenses pending before the court for sentencing, including offenses for which the offender may qualify as an
+habitual felony offender, an habitual violent felony offender, a violent career criminal or a prison releasee
+reoffender. The office of the state attorney must prepare the scoresheets and present them to defense counsel for
+review for accuracy. If sentences are imposed under section 775.084 or section 775.082(9), Florida Statutes, and
+the Criminal Punishment Code, a scoresheet listing only those offenses sentenced under the Criminal Punishment
+Code must be filed in addition to any sentencing documents filed under sections 775.084, or 775.082(9), Florida
+(2) One scoresheet must be prepared for all offenses committed under any single version or revision of
+the guidelines or Criminal Punishment Code pending before the court for sentencing.
+(3) If an offender is before the court for sentencing for more than one felony and the felonies were
+committed under more than one version or revision of the guidelines or Criminal Punishment Code, separate
+scoresheets must be prepared and used at sentencing. The sentencing court may impose such sentence
+concurrently or consecutively.
+(4) The sentencing judge must review the scoresheet for accuracy and sign it.
+(5) Felonies, except capital felonies, with continuing dates of enterprise are to be sentenced under the
+guidelines or Criminal Punishment Code in effect on the beginning date of the criminal activity.
+"Conviction" means a determination of guilt that is the result of a plea or trial, regardless of
+whether adjudication is withheld.
+"Primary offense" means the offense at conviction pending before the court for sentencing for
+which the total sentence points recommend a sanction that is as severe as, or more severe than, the sanction
+recommended for any other offense committed by the offender and pending before the court at sentencing. Only
+one count of one offense before the court for sentencing shall be classified as the primary offense.
+(8)
+"Additional offense" means any offense other than the primary offense for which an offender is
+convicted and which is pending before the court for sentencing at the time of the primary offense.
+(9) "Victim injury" is scored for physical injury or death suffered by a person as a direct result of any
+offense pending before the court for sentencing. Except as otherwise provided by law, the sexual penetration and
+sexual contact points will be scored as follows. Sexual penetration points are scored if an offense pending before
+the court for sentencing involves sexual penetration. Sexual contact points are scored if an offense pending before
+the court for sentencing involves sexual contact, but no penetration. If the victim of an offense involving sexual
+penetration or sexual contact without penetration suffers any physical injury as a direct result of an offense
+pending before the court for sentencing, that physical injury must be scored in addition to any points scored for the
+sexual contact or sexual penetration.
+Victim injury must be scored for each victim physically injured and for each offense resulting in physical
+injury whether there are one or more victims. However, victim injury must not be scored for an offense for which
+the offender has not been convicted.
+Victim injury resulting from one or more capital offenses before the court for sentencing must not be
+included upon any scoresheet prepared for non-capital offenses also pending before the court for sentencing. This
+17
+
+
+does not prohibit the scoring of victim injury as a result of the non-capital offense or offenses before the court for
+sentencing.
+(10) Unless specifically provided otherwise by statute, attempts, conspiracies, and solicitations must be
+indicated in the space provided on the Criminal Punishment Code scoresheet and must be scored at one severity
+level below the completed offense.
+Attempts, solicitations, and conspiracies of third-degree felonies located in offense severity levels 1 and 2
+must be scored as misdemeanors. Attempts, solicitations, and conspiracies of third-degree felonies located in
+offense severity levels 3, 4, 5, 6, 7, 8, 9, and 10 must be scored as felonies one offense level beneath the
+incomplete or inchoate offense.
+(11) An increase in offense severity level may result from a reclassification of felony degrees under
+sections 775.0845, 775.087, 775.0875, or 794.023, Florida Statutes. Any such increase must be indicated in the
+space provided on the Criminal Punishment Code scoresheet.
+(12)
+A single assessment of thirty prior serious felony points is added if the offender has a primary
+offense or any additional offense ranked in level 8, 9, or 10 and one or more prior serious felonies. A "prior
+serious felony" is an offense in the offender's prior record ranked in level 8, 9, or 10 and for which the offender is
+serving a sentence of confinement, supervision or other sanction or for which the offender's date of release from
+confinement, supervision, or other sanction, whichever is later, is within 3 years before the date the primary
+offense or any additional offenses were committed. Out of state convictions wherein the analogous or parallel
+Florida offenses are located in offense severity level 8, 9, or 10 must be considered prior serious felonies.
+(13)
+If the offender has one or more prior capital felonies, points must be added to the subtotal sentence
+points of the offender equal to twice the number of points the offender receives for the primary offense and any
+additional offense. Out-of-state convictions wherein the analogous or parallel Florida offenses are capital offenses
+and must be considered capital offenses for purposes of operation of this section.
+"Prior record" refers to any conviction for an offense committed by the offender prior to the
+commission of the primary offense. Prior record includes convictions for offenses committed by the offender as
+an adult or as a juvenile, convictions by federal, out of state, military, or foreign courts and convictions for
+violations of county or municipal ordinances that incorporate by reference a penalty under state law. Federal, out
+of state, military or foreign convictions are scored at the severity level at which the analogous or parallel Florida
+crime is located.
+(A) Convictions for offenses committed more than 10 years before the date of the commission of the
+primary offense must not be scored as prior record if the offender has not been convicted of any other
+crime for a period of 10 consecutive years from the most recent date of release from confinement,
+supervision, or other sanction, whichever is later, to the date of the commission of the primary offense.
+(B) Juvenile dispositions of offenses committed by the offender within 5 years before the date of the
+commission of the primary offense must be scored as prior record if the offense would have been a crime if
+committed by an adult. Juvenile dispositions of sexual offenses committed by the offender more than 5
+years before the date of the primary offense must be scored as prior record if the offender has not
+maintained a conviction-free record, either as an adult or as a juvenile, for a period of 5 consecutive years
+18
+
+
+from the most recent date of release from confinement, supervision, or sanction, whichever is later, to the
+date of commission of the primary offense.
+(C) Entries in criminal histories that show no disposition, disposition unknown, arrest only, or a
+disposition other than conviction must not be scored. Criminal history records expunged or sealed under
+section 943.058, Florida Statutes, or other provisions of law, including former sections 893.14 and 901.33,
+Florida Statutes, must be scored as prior record where the offender whose record has been expunged or
+sealed is before the court for sentencing.
+Any uncertainty in the scoring of the offender's prior record must be resolved in favor of the
+offender and disagreement as to the propriety of scoring specific entries in the prior record must be
+resolved by the sentencing judge.
+(E) When unable to determine whether the conviction to be scored as prior record is a felony or a
+misdemeanor, the conviction must be scored as a misdemeanor. When the degree of felony is ambiguous
+or the severity level cannot be determined, the conviction must be scored at severity level 1.
+(15)
+"Legal status points"
+are assessed when an offender:
+(A) Escapes from incarceration;
+(B)
+Flees to avoid prosecution;
+(C) Fails to appear for a criminal proceeding;
+(D) Violates any condition of a supersedeas bond;
+(E)
+Is incarcerated;
+(F)
+Is under any form of a pretrial intervention or diversion program; or
+(G)
+Is under any form of court-imposed or post-prison release community supervision and
+commits an offense that results in conviction. Legal status violations receive a score of 4 sentence
+(16)
+offenses committed while under any form of legal status.
+Community sanction violation points occur when the offender is found to have violated a condition
+(A)
+(B)
+(C)
+Probation;
+Community Control; or
+Pretrial intervention or diversion.
+19
+
+
+Community sanction violation points are assessed when a community sanction violation is before the court
+for sentencing. Six community sanction violation points must be assessed for each violation or if the violation
+results from a new felony conviction, 12 community sanction violation points must be assessed. Where there are
+multiple violations, points may be assessed only for each successive violation that follows a continuation of
+supervision, or modification or revocation of the community sanction before the court for sentencing and are not to
+be assessed for violation of several conditions of a single community sanction. Multiple counts of community
+sanction violations before the sentencing court may not be the basis for multiplying the assessment of community
+sanction violation points.
+(17) Possession of a firearm, semiautomatic firearm, or a machine gun during the commission or attempt
+to commit a crime will result in additional sentence points. Eighteen sentence points are assessed if the offender is
+convicted of committing or attempting to commit any felony other than those enumerated in subsection
+775.087(2), Florida Statutes, while having in his or her possession a firearm as defined in subsection 790.001(6),
+Florida Statutes. Twenty-five sentence points are assessed if the offender is convicted of committing or attempting
+to commit any felony other than those enumerated in subsection 775.087(3), Florida Statutes, while having in his
+or her possession a semiautomatic firearm as defined in subsection 775.087(3), Florida Statutes, or a machine gun
+as defined in subsection 790.001(9), Florida Statutes. Only one assessment of either 18 or 25 points can be made.
+(18) "Subtotal sentence points" are the sum of the primary offense points, the total additional offense
+points, the total victim injury points, the total prior record points, any legal status points, community sanction
+points, prior serious felony points, prior capital felony points and points for possession of a firearm or
+semiautomatic weapon.
+If the primary offense is drug trafficking under section 893.135, Florida Statutes, ranked in offense
+severity level 7 or 8, the subtotal sentence points may be multiplied, at the discretion of the sentencing court, by a
+factor of 1.5.
+(20) If the primary offense is a violation of the Law Enforcement Protection Act under subsections
+775.0823(2), Florida Statutes, the subtotal sentence points are multiplied by a factor of 2.5. If the primary offense
+is a violation of subsection 775.0823(3), (4), (5), (6), (7), or (8), Florida Statutes, the subtotal sentence points are
+multiplied by a factor of 2.0. If the primary offense is a violation of the Law Enforcement Protection Act under
+subsection 775.0823(9) or (10) or section 784.07(3), Florida Statutes, or section 775.0875(1), Florida Statutes, the
+subtotal sentence points are multiplied by a factor of 1.5.
+(21) If the primary offense is grand theft of the third degree of a motor vehicle and the offender's prior
+record includes three or more grand thefts of the third degree of a motor vehicle, the subtotal sentence points are
+multiplied by 1.5.
+(22) If the offender is found to have committed the offense for the purpose of benefiting, promoting, or
+furthering the interests of a criminal street gang under section 874.04, Florida Statutes, at the time of the
+commission of the primary offense, the subtotal sentence points are multiplied by 1.5.
+(23) If the primary offense is a crime of domestic violence as defined in section 741.28, Florida Statutes,
+which was committed in the presence of a child under 16 years of age who is a family household member as
+defined in section 741.28(2), Florida Statutes, with the victim or perpetrator, the subtotal sentence points are
+multiplied, at the discretion of the court, by 1.5.
+20
+
+
+(24) "Total sentence points" are the subtotal sentence points or the enhanced subtotal sentence points.
+(25) The lowest permissible sentence is the minimum sentence that may be imposed by the trial court,
+absent a valid reason for departure. The lowest permissible sentence is any nonstate prison sanction in which the
+total sentence points equals or is less than 44 points, unless the court determines within its discretion that a prison
+sentence, which may be up to the statutory maximums for the offenses committed, is appropriate. When the total
+sentence points exceeds 44 points, the lowest permissible sentence in prison months must be calculated by
+subtracting 28 points from the total sentence points and decreasing the remaining total by 25 percent. The total
+sentence points must be calculated only as a means of determining the lowest permissible sentence. The
+permissible range for sentencing must be the lowest
+permissible sentence up to and including the statutory
+maximum, as defined in section 775.082, Florida Statutes, for the primary offense and any additional offenses
+before the court for sentencing. The sentencing court may impose such sentences concurrently or consecutively.
+However, any sentence to state prison must exceed 1 year. If the lowest permissible sentence under the Code
+exceeds the statutory maximum sentence as provided in section 775.082, Florida Statutes, the sentence required by
+the Code must be imposed. If the total sentence points are greater than or equal to 363, the court may sentence the
+offender to life imprisonment. The sentence imposed must be entered on the scoresheet.
+(26)
+For those offenses having a mandatory minimum sentence, a scoresheet must be completed and the
+lowest permissible sentence under the Code calculated. If the lowest permissible sentence is less than the
+mandatory minimum sentence, the mandatory minimum sentence takes precedence. If the lowest permissible
+sentence exceeds the mandatory sentence, the requirements of the Criminal Punishment Code and any mandatory
+minimum penalties apply. Mandatory minimum sentences must be recorded on the scoresheet.
+(27) Any downward departure from the lowest permissible sentence, as calculated according to the total
+sentence points under section 921.0024, Florida Statutes, is prohibited unless there are circumstances or factors
+that reasonably justify the downward departure. Circumstances or factors that can be considered include, but are
+not limited to, those listed in subsection 921.0026(2), Florida Statutes.
+(A) If a sentencing judge imposes a sentence that is below the lowest permissible sentence, it is a
+departure sentence and must be accompanied by a written statement by the sentencing court delineating the
+reasons for the departure, filed within 7 days after the date of sentencing. A written transcription of orally
+stated reasons for departure articulated at the time sentence was imposed is sufficient if it is filed by the
+court within 7 days after the date of sentencing. The sentencing judge may also list the written reasons for
+departure in the space provided on the Criminal Punishment Code scoresheet.
+(B) The written statement delineating the reasons for departure must be made a part of the record. The
+written statement, if it is a separate document, must accompany the scoresheet required to be provided to
+the Department of Corrections under subsection 921.0024(6), Florida Statutes.
+If a split sentence is imposed, the total sanction (incarceration and community control or probation) must
+not exceed the term provided by general law or the maximum sentence under the Criminal Punishment Code.
+(28) Sentences imposed after revocation of probation or community control must be imposed according
+to the sentencing law applicable at the time of the commission of the original offense.
+21
+
+
+APPENDIX B - For Offenses committed under the Criminal Punishment Code (on or after 10-1-98)
+RULE 3.992(a) CRIMINAL PUNISHMENT CODE SCORESHEET
+1. DATE OF SENTENCE
+2. PREPARER'S NAME ODC OSAO
+3. COUNTY
+4. SENTENCING JUDGE
+5. NAME (LAST, FIRST, MI..)
+16. DOB
+7. DCP
+8. RACE
+Ов Ow OTHER
+9. GENDER
+Ом Ог
+10. PRIMARY OFF. DATE
+11. PRIMARY DOCKET *
+12.
+PLEA O
+TRIAL. O
+PRIMARY OFFENSE: If Qualifier, please check
+F.S.#
+DESCRIPTION
+_A
+FELONY
+DEGREE
+$ _c
+_R (A=Allempl, S-Solicitation, C=Conspiracy, R=Reclassification)
+OFFENSE
+LEVEL
+POINTS
+[Level - Polints: 1=4, 2=10, 3=16, 4=22, 5=28, 6*36, 7=56, 8=74, 9=92, 10=116)
+Prior capital falony triples Primary Offense points L
+1I.
+ADDITIONAL OFFENSE(S): Supplemental page attached L
+DOCKET#
+FEL/MM
+F.S.#
+OFFENSE
+DEGREE
+LEVEL
+QUALIFY COUNTS
+A SCR
+0000
+POINTS
+1.
+TOTAL
+DESCRIPTION
+000O
+x
+=
+DESCRIPTION
+0000
+DESCRIPTION
+(Lovel - Points: M=0.2, 1=0.7, 2-1.2, 3-2.4, 4=3.6, 5=8.4, 6=18, 7=28, 8=37, 9-46, 10=58)
+Prior capital felony triples Additional Offense points O
+IlI. VICTIM INJURY:
+Number
+2nd Degree Murder
+Total
+Death
+Severe
+Moderate
+Supplemental page points.
+Il.
+240 x
+120 x
+40x
+Slight
+Sex Penetration
+Sex Contact
+4x
+80x
+40 x
+18x
+IV. PRIOR RECORD:
+Supplemental page attached
+FEL/MM
+F.S.#
+OFFENSE QUALIFY:
+DEGREE
+LEVEL
+A SCR
+DESCRIPTION
+0000
+0000
+0000
+0000
+0000
+0000
+0000
+(Lovel = Points: M=0.2, 1-0.5, 2=0.8, 3=1.8, 4=2.4, 5=3.6, 6-9, 7=14, 8=19, 9=23, 10=29)
+Number
+=
+Total
+HI.
+NUMBER
+POINTS TOTAL
+X
+=
+Supplemental page points
+IV.
+Page 1 Subtotal:
+23
+
+
+Page 1 Subtotal:
+Legal Status violation = 4 Points
+VI. Community Sanction violation before the court for sentencing
+6 points x each successive violation OR
+New felony conviction = 12 points x each successive violation
+VIl. Firearm/Semi-Automatic or Machine Gun = 18 or 25 Points
+VIlI. Prior Serious Felony - 30 Points
+VI.
+VIl.
+VIII.
+Subtotal Sentence Points
+IX. Enhancements (only if the primary offense qualifies for enhancement)
+Law Enforcement Protection
+Grand Theft Motor Vehicle
+Steet Gang
+- x.1.5
+- * 1.5
+-X 1.5
+Enhanced Subtotal Sentence Points
+Domestic Violance
+(offerses commited on or after 10-1-37)
+- * 1.5
+IX.
+TOTAL SENTENCE POINTS
+SENTENCE COMPUTATION
+If total sentence points are less than or equal to 44, the lowest permissible sentence is any nan-state prison sanction.
+If total sentence points are greater than 44:
+total sentence points
+minus 28 =
+_x.75 =
+lowest permissible prison
+sentence in months
+TOTAL SENTENCE IMPOSED
+Years Months
+maximum sentence
+in years
+Days
+• State Prison
+• County Jail
+•
+Life
+Time Served
+• Community Control
+• Probation
+Please check If sentenced as O habitual offender, habitual violent offender, • violent career criminal, • prison releasee reoffender,
+or a O mandatory minimum applies.
+• Mitigated Departure
+• Plea Bargain
+Other Reason
+JUDGE'S SIGNATURE
+24
+
+
+NAME (LAST, FIRST, ME.I)
+RULE 3.992(b) SUPPLEMENTAL CRIMINAL PUNISHMENT CODE SCORESHEET
+DOCKET #
+DATE OF SENTENCE
+II. ADDITIONAL OFFENSES(S):
+DOCKET#
+FEL/MM
+DEGREE
+F.S#
+OFFENSE
+LEVEL
+QUALIFY COUNTS
+A S CR
+0000
+POINTS POINTS
+DESCRIPTION
+0000
+DESCRIPTION
+0000
+DESCRIPTION
+•000
+DESCRIPTION
+0000
+(Level - Points: M=0.2, 1=0.7, 2=1,2, 3=2.4, 4=3.6, 5=5.4, 6=18, 7=28, 8-37, 9=46, 10=58)
+IV. PRIOR RECORD
+FEL/MM
+DEGREE
+F.S.#
+OFFENSE
+QUALIFY:
+LEVEL
+A SC R
+• i
+DESCRIPTION
+x
+=
+II.
+NUMBER POINTS
+TOTAL
+=
+=
+=
+=
+=
+•
+•
+(Lovel = Points: M=0.2, 1=0.5, 2=0.9, 3=1.6, 4=2.4, 5=3.6, 6=9, 7=14, 8=19, 9=23, 10=29)
+REASONS FOR DEPARTURE - MITIGATING CIRCUMSTANCES
+(reasons may be checked here or written on the scoresheet)
+• Legitimate, uncoerced plea bargain.
+The defendant was an accomplice to the offense and was a relatively minor participant in the criminal conduct.
+The capacity of the defendant to appreciate the criminal nature of the conduct or to conform that conduct to the requirements of law was substantially impared.
+The defendant requires specialized treatment for a mental disorder that is unrelated to substance abuse or addetion, or for a physical disabilly, and the defendant is
+amenable to treatment.
+The need for payment of restitution to the victim outweighs the need for a prison sentence.
+•
+The victim was an initiator, willing participant, aggressor, or provoker of the incident.
+The defendant acted under extreme duress or under the domination of another person.
+•
+Before the identity of the defendant was determined, the victim was substantially compensated.
+The defendant cooperated with the State to resolve the current offense or any other offense.
+• The offense was committed in an unsophisticated manner and was an isolated incident for which the defendant has shown remorse.
+• At the time of the offense the defendant was too young to appreciate the consequences of the offense.
+• The defendant is to be sentenced as a youthful offender.
+Pursuant to 921.0026(3) the defendant's substance abuse or addiction does not justify a downward departure from the lowest permissible sentence.
+25
+
+
+APPENDIX C
+Offense Severity Ranking Chart
+Florida Criminal Punishment Code
+Section 921.0022, Florida Statutes
+Felony offenses subject to the 1998 Criminal Punishment Code are listed in a single offense
+severity ranking chart located at section 921.0022, Florida Statutes. . The offense severity
+ranking chart employs 10 offense levels, ranked from least severe to most severe. Each felony
+offense is assigned to a level according to the severity of the offense, commensurate with the
+harm or potential for harm to the community that is caused by the offense, as determined by
+statute. The numerical statutory reference in the left column of the chart and the felony degree
+designations in the middle column of the chart determine whether felony offenses are
+specifically listed in the offense severity ranking chart and the appropriate severity level. The
+language in the right column is merely descriptive.
+Felony offenses not listed in section 921.0022, Florida Statutes, are assigned a severity level in
+accordance with section 921.0023, Florida Statutes, as follows:
+(A) A felony of the third degree within offense level 1.
+(I) A felony of the second degree within offense level 4.
+(C) A felony of the first degree within offense level 7.
+(D) A felony of the first degree punishable by life within offense level 9.
+(E) A life felony within offense level 10.
+An offense does not become unlisted and subject to the provisions of section 921.0023, Florida Statutes,
+because of a reclassification of the degree of felony pursuant to section 775.0845, section 775.087, section
+775.0875 or section 794.023, Florida Statutes, or any other law that provides an enhanced penalty for a
+felony offense.
+26
+
+
+784.021(1)(a)
+784.021(1)(b)
+784.041
+784.048(3)
+784.048(5)
+784.07(2)(c)
+784.074(1)(b)
+784.08(2) (b)
+784.081(2)
+784.082(2)
+784.083(2)
+787.02(2)
+790.115(2)(d)
+790.161(2)
+790.164(1)
+790.19
+794.011(8)(a)
+794.05(1)
+800.04(5)(d)
+800.04(6)(b)
+806.031(2)
+810.02(3)(c)
+812.014(2)(b)1.
+812.015(9)
+OFFENSE SEVERITY RANKING CHART
+AS OF JULY 1, 2006
+Felony
+Degree
+3rd
+3rd
+3rd
+3rd
+3rd
+2nd
+2nd
+2nd
+2nd
+2nd
+2nd
+3rd
+2nd
+2nd
+2nd
+2nd
+3rd
+2nd
+3rd
+2nd
+2nd
+2nd
+2nd
+2nd
+Description
+Aggravated assault; deadly weapon without intent to kill.
+Aggravated assault; intent to commit felony.
+Felony battery.
+Aggravated stalking; credible threat.
+Aggravated stalking of person under 16.
+Aggravated assault on law enforcement officer.
+Aggravated assault on sexually violent predators facility staff.
+Aggravated assault on a person 65 years of age or older.
+Aggravated assault on specified official or employee.
+Aggravated assault by detained person on visitor or other detainee.
+Aggravated assault on code inspector.
+False imprisonment; restraining with purpose other than those in s. 787.01,
+Discharging firearm or weapon on school property.
+Make, possess, or throw destructive device with intent to do bodily harm or damage
+property.
+False report of deadly explosive, weapon of mass destruction, or act of arson or
+violence to state property:
+Shooting or throwing deadly missiles into dwellings, vessels, or vehicles.
+Solicitation of minor to participate in sexual activity by custodial adult.
+Unlawful sexual activity with specified minor.
+Lewd or lascivious molestation; victim 12 years of age or older but less than 16 years;
+offender less than 18 years.
+Lewd or lascivious conduct; offender 18 years of age or older.
+Arson resulting in great bodily harm to firefighter or any other person.
+Burglary of occupied structure; unarmed; no assault or battery.
+Property stolen $20,000 or more, but less than $100,000, grand theft in 2nd degree.
+Retail theft; property stolen $300 or more; second or subsequent conviction.
+37
+
+
+812.13(2)(c)
+817.034(4)(a)1.
+817.4821(5)
+825.102(1)
+825.102(3)(c)
+825.1025(3)
+825.103(2)(c)
+827.03(1)
+827.03(3)(c)
+827.071(2) & (3)
+836.05
+836.10
+843.12
+847.0135(2)
+914.23
+244.35(3)(a)2.
+944.40
+944.46
+944.47(1)(a)5.
+951.22(1)
+316.027(1)(b)
+316.193(3)(c)2.
+OFFENSE SEVERITY RANKING CHART
+AS OF JULY 1, 2006
+Felony
+Degree
+2nd
+Ist
+2nd
+3rd
+3rd
+3rd
+3rd
+3rd
+3rd
+2nd
+2nd
+2nd
+3rd
+3rd
+2nd
+3rd
+2nd
+3rd
+2nd
+3rd
+Ist
+Description
+Robbery, no firearm or other weapon (strong-arm robbery).
+Communications fraud, value greater than $50,000.
+Possess cloning paraphernalia with intent to create cloned cellular telephones.
+Abuse of an elderly person or disabled adult.
+Neglect of an elderly person or disabled adult.
+Lewd or lascivious molestation of an elderly person or disabled adult.
+Exploiting an elderly person or disabled adult and property is valued at less than
+$20,000.
+Abuse of a child.
+Neglect of a child.
+Use or induce a child in a sexual performance, or promote or direct such
+Pares cortion.
+Written threats to kill or do bodily injury.
+Aids or assists person to escape.
+Facilitates sexual conduct of or with a minor or the visual depiction of such conduct.
+Retaliation against a witness, victim, or informant, with bodily injury.
+ommitting malicious battery upon or inflicting cruel or inhuman treatment on E
+mate or offender on community supervision, resulting in great bodily harn
+Escapes.
+Harboring, concealing, aiding escaped prisoners.
+Introduction of contraband (firearm, weapon, or explosive) into correctional facility.
+Intoxicating drug, firearm, or weapon introduced into county facility.
+(g) LEVEL 7
+Accident involving death, failure to stop; leaving scene.
+DUI resulting in serious bodily injury.
+38
+
+
+316.1935(3)(b)
+327.35(3)(c)2.
+402.319(2)
+409.920(2)
+456.065(2)
+456.065(2)
+458.327(1)
+459.013(1)
+460.411(1)
+461.012(1)
+462.17
+463.015(1)
+464.016(1)
+465.015(2)
+466.026(1)
+467.201
+468.366
+483.828(1)
+483.901(9)
+484.013(1)(c)
+484.053
+494.0018(2)
+560.123(8)b) 1.
+OFFENSE SEVERITY RANKING CHART
+AS OF JULY 1, 2006
+Felony
+Degree
+Ist
+3rd
+2nd
+3rd
+3rd
+2nd
+3rd
+3rd
+3rd
+3rd
+3rd
+3rd
+3rd
+3тd
+3rd
+3rd
+3rd
+3rd
+3rd
+3rd
+3rd
+Ist
+3rd
+Description
+using serious bodily injury or death to another person; driving at high speed
+th wanton disregard for safety while fleeing or attempting to elude law enforceme
+officer who is in a patrol vehicle with siren and lights activate
+/essel BUI resulting in serious bodily injury.
+Misrepresentation and negligence or intentional act resulting in great bodily harm,
+ermanent disfiguration, permanent disability, or deatl
+fedicaid provider frauc
+Practicing a health care profession without a license.
+Practicing a health care profession without a license which results in serious bodily
+injury.
+Practicing medicine without a license.
+Practicing osteopathic medicine without a license.
+Practicing chiropractic medicine without a license.
+Practicing podiatric medicine without a license.
+Practicing naturopathy without a license.
+Practicing optometry without a license.
+Practicing nursing without a license.
+Practicing pharmacy without a license.
+Practicing dentistry or dental hygiene without a license.
+Practicing midwifery without a license.
+Delivering respiratory care services without a license.
+Practicing as clinical laboratory personnel without a license.
+Practicing medical physics without a license.
+Preparing or dispensing optical devices without a prescription.
+Dispensing hearing aids without a license.
+Conviction of any violation of ss. 494.001-494.0072 in which the total money and
+property unlawfully obtained exceeded $50,000 and there were five or more victims.
+520,0 money angrop men instruments exceling 5300 bur los han
+39
+
+
+560.125(5)(a)
+655.50(10)(b)1.
+775.21(10)(a)
+775.21(10)(b)
+175.21(10)(g)
+782.051(3)
+782.07(1)
+782.071
+182.072
+784,045(1)(a)l.
+784.045(1)(a)2.
+784.045(1)(b)
+784.048(4)
+784.048(7)
+784.07(2)(d)
+784.074(1)(a)
+784.08(2)(a)
+784.081(1)
+784.082(1)
+784.083(1)
+790.07(4)
+790.16(1)
+790.165(2)
+790.165(3)
+OFFENSE SEVERITY RANKING CHART
+AS OF JULY 1, 2006
+Felony
+Degree
+3rd
+3rd
+3rd
+3rd
+3rd
+2nd
+2nd
+2nd
+2nd
+2nd
+2nd
+2nd
+3rd
+3rd
+Ist
+Ist
+Ist
+Ist
+Ist
+Ist
+Ist
+Ist
+2nd
+2nd
+Description
+Money transmitter business by unauthorized person, currency or payment instruments
+exceeding $300 but less than $20,000.
+Failure to report financial transactions exceeding $300 but less than $20,000 by
+financial institution.
+Sexual predator; failure to register; failure to renew driver's license or identification
+card; other registration violations.
+Sexual predator working where children regularly congregate.
+Failure to report or providing false information about a sexual predator; harbor or
+conceal a sexual predator.
+Attempted felony murder of a person by a person other than the perpetrator or the
+perpetrator of an attempted felony.
+Killing of a human being by the act, procurement, or culpable negligence of another
+(manslaughter).
+Killing of human being or viable fetus by the operation of a motor vehicle in a
+reckless manner (vehicular homicide).
+Killing of a human being by the opcration of' a vessel in a reckless manner (vessel
+homicide).
+Aggravated battery; intentionally causing great bodily harm or disfigurement.
+Aggravated battery; using deadly weapon.
+Aggravated battery; perpetrator aware victim pregnant.
+Aggravated stalking; violation of injunction or court order.
+Aggravated stalking; violation of court order.
+Aggravated battery on law enforcement officer.
+Aggravated battery on sexually violent predators facility staff.
+Aggravated battery on a person 65 years of age or older.
+Aggravated battery on specified official or employee.
+Aggravated battery by detained person on visitor or other detainee.
+Aggravated battery on code inspector.
+Specified weapons violation subsequent to previous conviction of s. 790.07(1) or (2).
+Discharge of a machine gun under specified circumstances.
+Manufacture, sell, possess, or deliver hoax bomb.
+Possessing, displaying, or threatening to use any hoax bomb while committing or
+attempting to commit a felony.
+40
+
+
+790.166(3)
+790.166(4)
+796.03
+800.04(5)(c)l.
+800.04(5)(c)2.
+806.01(2)
+810.02(3)(a)
+810.02(3)(b)
+810.02(3)(d)
+812.014(2)(a)L.
+812.014(2)(b)2.
+812.014(2)(b)3.
+812.0145(2)(a)
+812.012(2)
+812.131(2)(a)
+812J33(2)(b)
+817.234(8)(a)
+817.234(9)
+817.234(11)(c)
+817.2341(2)(b) & (3)(b)
+825.102(3)(b)
+825. 103(2)(b)
+827.03(3)(b)
+OFFENSE SEVERITY RANKING CHART
+AS OF JULY 1, 2006
+Felony
+Degree
+2nd
+2nd
+2nd
+2nd
+2nd
+2nd
+2nd
+2nd
+2nd
+Ist
+2nd
+2nd
+Ist
+Ist
+2nd
+Ist
+2nd
+2nd
+Ist
+Ist
+2nd
+2nd
+2nd
+Description
+Possessing, selling, using, or attempting to use a hoax weapon of mass destruction.
+Possessing, displaying, or threatening to use a hoax weapon of mass destruction while
+committing or attempting to commit a felony.
+Procuring any person under 16 years for prostitution.
+Lewd or lascivious molestation; victim less than 12 years of age; offender less than
+18 years.
+Lewd or lascivious molestation; victim 12 years of age or older but less than 16 years;
+offender 18 years or older.
+Maliciously damage structure by fire or explosive.
+Burglary of occupied dwelling; unarmed; no assault or battery.
+Burglary of unoccupied dwelling; unarmed; no assault or battery.
+Burglary of occupied conveyance; unarmed; no assault or battery.
+Property stolen, valued at $100,000 or more or a semitrailer deployed by a law
+enforcement officer; property stolen while causing other property damage; 1st degree
+Property stolen, cargo valued at les than 50,00, grand thef in 2nd degre
+Property stolen, emergency medical equipment; 2nd degree grand theft.
+Theft from person 65 years of age or older; $50,000 or more.
+Stolen property; initiates, organizes, plans, etc., the theft of property and traffics in
+stolen property.
+Robbery by sudden snatching-
+Carjacking; no firearm, deadly weapon, or other weapon.
+Solicitation of motor vehicle accident victims with intent to defraud.
+Organizing, planning, or participating in an intentional motor vehicle collision.
+Insurance fraud; property value $100,000 or more.
+41
+
+
+STATUTE
+443.071
+812.13
+782.04
+316.1935
+$00.04
+$93.13
+800.04
+316.1935
+796.07
+784.08
+784.048
+784.07
+316.193
+893.135
+810.02
+[914.22
+$00.04
+825.103
+893.13
+794,011
+784.048
+800,04
+539.001
+893.13
+893.135
+893.13
+800.04
+893.13
+893.13
+[316.193
+794.05
+316.1935
+777,03
+SECTION
+(D)
+((2)(B)
+(5KB)
+(4XA)
+(4X(A)
+(4)(C)
+(2)(C)
+(3KC)
+(1XA OR F)
+(5XCX2)
+(2XC)
+(2XA)2
+(6(B)
+(8)(B)8A
+(6(A)
+(XA)]
+(2)(B-C)
+CODE
+2615
+1213
+0914
+4921
+3622
+9430
+3640
+4926
+4008
+1334
+1342
+1328
+5404
+9571
+2210
+8501
+3624
+3832
+9524
+1129
+1341
+3626
+6252
+9532
+9513
+9447
+9510
+1137
+7396
+OFFENSE TYPE
+FRAUD: BUSINESS
+ROBBERY
+HOMICIDE
+OBSTRUCTING
+SEXUAL BATTERY
+DRUG DEALING
+SEXUAL BATTERY
+OBSTRUCTING
+PROSTITUTION
+BATTERY
+ASSAULT
+ASSAULT
+DRUNK DRIVING: VEHICLE
+DRUG TRAFFICKING
+BURGLARY
+COURT PROCESS
+SEXUAL BATTERY
+ABUSE: ELDER
+DRUG PURCHASE
+MAYHEM
+ASSAULT
+LEWDNESS
+FRAUD: BUSINESS
+DRUG POSSESSION
+DRUG TRAFFICKING
+DRUG DEALING
+LEWDNESS
+DRUG POSSESSION
+DRUG DEALING
+DRUNK DRIVING: VEHICLE
+LEWDNESS
+OBSTRUCTING
+ACCESSORY
+ASI DESCRIPTION
+FRAUD-TO INCREASE BENEFITS
+ROBB. WPN - NOT DEADLY
+2ND DEG MURD, DANGEROUS ACT
+FLEE LEO/HISPEED,NO REGARD
+LL MOLEST <12 OFF 18+
+(SM/D METH
+L. BATT. SEX W/L-12-15
+AGG. FLEE/ELUDE LEO
+[PROSTITUTION -3 RD CONV.
+[BATTERY UPON PERSON 65/OLDER
+AGG.STALK - VIOL. COURT ORDER.
+AGG.ASSLT/LEO/FIREFGT/EMS/ETC.
+DUI,CAUSE SERIOUS BODILY INIRY
+TRAFF HER,ETC.4-U/14 GR
+BURG/N/ASSLT/OCC STRUCT.
+INTIMIDATE WITNESS
+LA. MOLEST | 12-15 OFF 18+
+EXPL ELDER/DISABLD LT S20K
+MARIJUANA-PUR/POSS WANT PUR
+SEX BAT/INJURY NOT LIKELY
+AGG. STALK-CREDIBLE THREAT
+LI CONDUCT <16 OFF 18+
+FALS.INF. TO PWNBRKR<$300
+OPIUM-POSS LESS/10 GRAMS
+TRAFF. MDMA, PHEN 10-U/200 GR
+OTH DRUG-SALE/MANUF/DELIV
+LIL, INDEC. ASLT CHILD U/16
+POSSESS MDMA
+HEROIN-SALE, MANUF/DELIVER
+DUI MANSLAUGHTER
+ADLT SEX W/16-17 YR OLD
+AGG.FLEE/ELUDE LEO
+ACCESSORY AFT. FACT-OTHER
+GUIDELINE
+LEVEL
+-
+-
+LEVEL
+EFFECTIVE
+(YYYYMM)
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+FELONY
+DEGREE
+N
+N
+IN N
+51
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/dfcee56529fff5bc28931544528f0fc43b3613f0693a4805cb54014299b73a3c.receipt.json b/vision-fixhub/ds9-unparsed-05/dfcee56529fff5bc28931544528f0fc43b3613f0693a4805cb54014299b73a3c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..144a58263019cfbcd87ec2c6c923fd8a629133f5
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/dfcee56529fff5bc28931544528f0fc43b3613f0693a4805cb54014299b73a3c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1251,
+  "dataset": "marble-joined",
+  "doc_id": "dfcee56529fff5bc28931544528f0fc43b3613f0693a4805cb54014299b73a3c",
+  "engine": "marble-apple-vision",
+  "event_count": 81,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "2e1b492e9f8319a38294e725f832ed942f604211aee32182a74c835c73613d25",
+  "output_sha256": "eae32c1c203717d47a7bf9015a828d308aac39b2be6b00a45979620dff8a5bbd",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e0276efa4a51c53d78d0ad14538f50f7038672ee1a35c2d93561c1506e853eb5.md b/vision-fixhub/ds9-unparsed-05/e0276efa4a51c53d78d0ad14538f50f7038672ee1a35c2d93561c1506e853eb5.md
new file mode 100644
index 0000000000000000000000000000000000000000..74056543b9da2da08d7868110e8c5fcd841e66c3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e0276efa4a51c53d78d0ad14538f50f7038672ee1a35c2d93561c1506e853eb5.md
@@ -0,0 +1,111 @@
+OLY-69
+
+
+TO:
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-69
+SUBPOENA FOR:
+x PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+•
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+ugust 21, 200
+:00pm
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+ANY AND ALL NOTES, LETTERS, CARDS, GIFTS, PAYMENTS, AND PHOTOGRAPHS YOU HAVE RECEIVED
+FROM JEFFREY EPSTEIN,
+I AND/OR L
+ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIGITAL, OF JEFFREY EPSTEIN,
+ALLI
+L AND/OR
+ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS, OR TELEPHONE
+MESSAGES THAT YOU HAVE SENT TO AND/OR RECEIVED FROM JEFFREY EPSTEIN, J
+_ AND/OR
+*Please coordinate your compliance with this subnoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+August 6, 2007
+This subpoena is issued upon application
+of the United States of America
+a
+*If not applicable, enter "none."
+Name, Address and Phone Number of Assistant U.S. Attorney
+1 Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+Tels
+Fax:
+To be used in lieu of AO110
+FORM ORD-227
+JAN.8G
+
+
+United States District Court
+• SOUTHERN DISTRICT OF FLORIDA
+TO:
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-69
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+Grand Jury Room
+•
+DATE AND TIME:
+lugust 21, 200
+1:00pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+ANY AND ALL NOTES, LETTERS, CARDS, GIFTS, PAYMENTS, AND PHOTOGRAPHS YOU HAVE RECEIVED
+FROM JEFFREY EPSTEIN, T
+ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIGITAL, OF JEFFREY EPSTEIN, I
+.!:
+HI, AND/OR
+ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS, OR TELEPHONE
+MESSAGES THAT YOU HAVE SENT TO AND/OR RECEIVED FROM JEFFREY EPSTEIN, 1 :
+,, AND/OR
+*Please coordinate your compliance with this subnoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+August 6, 2007
+This subpoena is issued upon application
+of the
+V
+a
+*If not applicable, enter "none."
+Name, Address and Phone Number of Assistant U.S. Attorney
+h, Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, EL 33401-6235
+x3047
+Fas
+To be used in lieu of AD110
+FORM ORD-227
+JAN.86
diff --git a/vision-fixhub/ds9-unparsed-05/e0276efa4a51c53d78d0ad14538f50f7038672ee1a35c2d93561c1506e853eb5.receipt.json b/vision-fixhub/ds9-unparsed-05/e0276efa4a51c53d78d0ad14538f50f7038672ee1a35c2d93561c1506e853eb5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9500e686cff225655e6308a82f148e0b403fea6e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e0276efa4a51c53d78d0ad14538f50f7038672ee1a35c2d93561c1506e853eb5.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "e0276efa4a51c53d78d0ad14538f50f7038672ee1a35c2d93561c1506e853eb5",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "46cd5a3e77e4576a791ce87ed6b1d70443e8c29530921083431fb732fe45c6c8",
+  "output_sha256": "44aacc17e995cd364e60d4162f031f9e7bbaa9a90e5d63f215fc47e2e43849ec",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e084e03325bbefba39aa1eae9101153ff264a52bd6e337a6008824b770463374.md b/vision-fixhub/ds9-unparsed-05/e084e03325bbefba39aa1eae9101153ff264a52bd6e337a6008824b770463374.md
new file mode 100644
index 0000000000000000000000000000000000000000..7552480170145972fb3374051136f6f0311828d0
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e084e03325bbefba39aa1eae9101153ff264a52bd6e337a6008824b770463374.md
@@ -0,0 +1,1861 @@
+
+To be argued by
+DEBORAH L.. MORSE
+New Dork Supreme Court
+Appellate Division - First Department
+THE PEOPLE OF THE STATE OF NEW YORK,
+Respondent,
+- against -
+JEFFREY E. EPSTEIN
+Defendant-Appellant.
+BRIEF FOR RESPONDENT
+CYRUS R. VANCE, JR.
+New York County
+Attorney for Respondent
+One Hogan Place
+New York, New York 10013
+danyappeals@dany.nyc.gov
+GINA MIGNOLA
+DEBORAH L. MORSE
+ASSISTANT DISTRICT ATTORNEYS
+Of Counsel
+
+
+TABLE OF CONTENTS
+TABLE OF AUTHORITIES
+INTRODUCTION
+POINT
+Page
+.....ii
+1
+THE SORA COURT'S DESIGNATION OF
+DEFENDANT AS A LEVEL-THREE OFFENDER
+WAS SUPPORTED OVERWHELMINGLY BY THE
+RECORD. THE PROCESS BY WHICH THE COURT
+REACHED AND DELIVERED THAT
+DETERMINATION WAS ENTIRELY FAIR AND
+PROPER
+CONCLUSION ..
+..33
+. 63
+
+
+TABLE OF AUTHORITIES
+CASES
+Conttast People v. Ferguson, 53 A.D.3d 571 (2d Dept. 2008) ..
+People v. Belter, 84 A.D.3d 905 (2d Dept. 2011) ...
+People v. Brensic, 70 N. Y.2d 9 (1987........
+People v. Conway, 47 A.D.3d 492 (1st Dept. 2008)
+People v. Guaman, 8 A.D.3d 545 (2d Dept. 2004)
+People v. Johnson, 77 A.D.3d 548 (1st Dept. 2010).
+People v. Kello, 96 N.Y.2d 740 (2001)..
+People v. Knox, 12 N.Y.3d 60 (2009)
+People v. Mendez, 45 A.D.3d 429 (1st Dept. 2007).
+People v. Mingo, 12 N.Y.3d 563 (2009)..
+People v. O'Neal, 35 A.D.3d 302 (1st Dept. 2006)
+People v. Pettigrew, 14 N.Y.3d 406 (2010)...
+People v. Roland, 292 A.D.2d 271 (1st Dept. 2002)
+People v. Smith, 75 A.D.3d 1112 (4th Dept. 2010)
+People v. Vasquez, 20 Misc.3d 37 (App. Term 1st Dept. 2008)
+People v. Windham, 10 N. Y.3d 801 (2008) ..
+STATUTES
+Corrections Law § 168-1
+Correction Law § 168-n(3)
+Correction Law § 169-8(3)
+Fla. Stat. 796.03.
+-i-
+.57
+43
+.36
+.35
+38,49
+.39
+.36
+36
+36-37,40
+36
+36
+38
+58
+.37
+. 36,38
+29,35
+36,58
+36
+..1
+
+
+Fla. Stat. 796.07..
+.............1
+-ili-
+
+
+SUPREME COURT OF THE STATE OF NEW YORK
+APPELLATE DIVISION: FIRST DEPARTMENT
+THE PEOPLE OF THE STATE OF NEW YORK,
+Respondent,
+-against-
+JEFFREY EPSTEIN,
+Defendant-Appellant.
+BRIEF FOR RESPONDENT
+INTRODUCTION
+Defendant, Jeffrey Epstein, appeals from an order of the Supreme Court, New
+York County (Ruth Pickholz, J.), entered on January 18, 2011, adjudicating him a
+level-three sex offender pursuant to the Sex Offender Registration Act ("SORA").
+By the underlying judgment, defendant was convicted in Palm Beach County, Florida,
+by his plea of guilty, of Procuring a Person Under 18 for Prostitution (Fla. Stat.
+796.03) and Felony Solicitation of Prostitution (Fla. Stat. 796.07). On June 30, 2008,
+defendant was sentenced to serve consecutive jail terms of 12 months and 6 months,
+to be followed by a 12-month term of Community Control. Defendant has
+completed his sentence.
+
+
+Apart from various other residential properties, defendant maintains homes
+both in Palm Beach, Florida, and on the Upper East Side of Manhattan. The SORA
+risk-level designation that defendant received in New York is the subject of this
+appeal.
+The criminal conduct underlying the SORA designation occurred in
+defendant's Palm Beach home.
+On March 15, 2005, a 14-year-old girl and her family made a report to the Palm
+Beach Police Department about sexual misconduct committed against her by then 51-
+year-old defendant. For almost a yeat—from March 2005 to February 2006-the
+Palm Beach Police Department conducted an extensive investigation of defendant
+and two accomplices who had helped him lure young girls to the seclusion of his
+home. On May 1, 2006, a Palm Beach detective swore out a 22-page probable-cause
+affidavit detailing the results of dozens of police interviews as well as the first-hand
+observations of Palm Beach detectives.
+Among other things, the investigation revealed that defendant had been paying
+young girls—-many from Royal Palm Beach High School who were 16 years of age of
+less—to come to his home and give him a massage as he lay naked, masturbated, and
+engaged in sexual contact with them. The sexual contact during these "massages"
+included vaginal intercourse, mouth to vagina sodomy, touching of the girl's breasts
+and vagina, placing his fingers inside the girl's vagina, and using a vibrator on the girl's
+vaginal area
+-always as he masturbated to climax. During certain time periods,
+defendant was receiving these "massages" two or three times a day. The girls were
+-2-
+
+
+paid anywhere from $200 to $1,000 per massage, depending upon the nature of the
+sexual contact that they permitted.
+In July of 2006, five months after the investigation had concluded, the Palm
+Beach County State's Attorney's Office obtained an indictment charging defendant
+with one count of Felony Solicitation of Prostitution: Defendant was taken into
+custody. Almost two years later, on June 26, 2008, the State's Attorney's Office filed
+an information charging defendant with an additional crime-namely, Procuring a
+Person Under 18 For Prostitution. Four days later, on June 30, 2008, defendant
+pleaded guilty to both accusatory instruments—namely, one count each of Procuring
+a Person Under 18 for Prostitution and Felony Solicitation of Prostitution. That same
+day, defendant was sentenced to serve consecutive jail terms of 12 months and 6
+months, to be followed by a 12-month term of Community Control.
+Because one of the crimes required that defendant register in Florida as a sexoffender, the fact that he also maintained a residence in Manhattan meant that he had
+to register in New York State as a sex offender as well. Following an investigation,
+the State of New York Board of Examiners of Sex Offenders ("The Board")
+recommended that, on the three-tier SORA classification scale, defendant be classified
+as a level-three sex offender. The Board reached that conclusion after having
+calculated defendant's risk assessment score at 130
+—solidly above the 110 qualifying
+number for level three.
+-3-
+
+
+On Januaty 18, 2011, after having received the appropriate notice months
+earlier, two attorneys—the ones who are representing defendant on appealappeared before Justice Ruth Pickholz on defendant's behalf for a hearing to
+determine defendant's risk level; defendant chose not to attend the proceedings. At
+the hearing, defendant urged that a proper application of the SORA guidelines to his
+conduct warranted a level-one classification.
+Apparently misapprehending the
+governing legal standards, the People expressed concern about assessing points
+against defendant on the basis of the victim-accounts detailed in the probable-cause
+affidavit; the People seem to have based that position largely on the mistaken notion
+that only sexual conduct for which defendant had been formally charged could be
+considered when calculating his risk-assessment score. After hearing argument from
+both parties, and reviewing all the materials that had been submitted, the court
+adopted the recommendation made by the SORA Board and found defendant to be a
+level-three sex offender.
+On appeal, defendant contends that he was incorrectly classified a level-three
+offender and should have been classified a level-one offender instead.
+More
+particularly, defendant contends that the level-three designation lacked the support of
+clear and convincing evidence, and was based instead on impropet considerations.
+Defendant further complains that the court rendered its ruling without affording the
+parties an opportunity to present evidence on disputed issues, and issued an order that
+-4
+
+
+lacked the requisite findings and conclusions.
+THE MATERIALS PROVIDED TO THE SORA COURT
+The Florida Probable-Cause Affidavit
+Among the materials provided to the SORA court was the probable-cause
+affidavit prepared by detectives of the Palm Beach Police Department (AG-27). This
+22-page document, sworn to by a detective, outlined the findings of a "sexual battery"
+investigation beginning on March 15, 2005, and extending through February of 2006
+(A6).' The numerous interviews conducted by the Palm Beach Police produced
+sworn, tape-recorded statements from what the police denominated as five victims
+and seventeen witnesses.
+The statements concerned "massages" provided to
+defendant by high school girls in exchange for money, and "other unlawful sexual
+activity" by defendant involving those young girls, in defendant's Palm Beach home
+(A6). Defendant was 51 years of age at the time of four of the specified criminal
+incidents, and 52 years of age at the time of the fifth (A2T).
+The affidavit revealed that defendant had set up, and maintained, a highly
+organized operation to satisfy his compulsive need for young girls. Most of the
+victims were students at Royal Palm Beach High School (A6). And, defendant had
+1 Parenthetical numerical references preceded by "A" are to the pages of Defendant's
+Appendix.
+-5-
+
+
+maintained a steady and orderly stream of these girls with the aid of various
+employees. For the equivalent of a finder's fee,
+a student at Royal
+Palm Beach High School, recruited classmates to perform these so-called "massages."
+defendant's adult assistant, regularly was present at defendant's house at
+the time of the massages, recorded the girls' names and contact information for future
+reference, and set up appointments for the girls to come to the house at regular
+intervals on each day that defendant was in town (A6).
+The affidavit further revealed that most of the "massage" sessions themselves
+followed a regulat routine. Upon arrival at defendant's house, the victim was escorted
+to defendant's bedroom, where defendant entered the room wearing nothing but a
+towel and instructed the girl to remove her clothes as well (A6). As the girl provided
+the massage in some state of undress, which usually consisted of only panties,
+defendant subjected her to some sort of sexual contact-including rubbing her vagina
+with his fingers of a vibratos, or inserting his penis of fingers into her vagina (AG). At
+the conclusion of the massage, the girls were given cash in sums ranging from $200 to
+$1,000, depending upon the extent of the sexual contact (A6). More particularly, the
+affidavit related the following specific accounts:
+The Statements By Girls Who Had Provided "Massages"
+During an interview that was sworn and tape-recorded, 14-yeat-old S.G., a
+student at Royal Palm Beach High School, reported to detectives that
+had
+-6-
+
+
+offered het an opportunity to make money, and then had picked her up at home and
+driven her to defendant's house (A6-7). The two entered the house through the
+kitchen door, and were met shortly afterwards by defendant and
+(A7). 1
+escorted S.G. up a flight of stairs, past walls lined with photographs, to a room
+containing a massage table and a "hot-pink and green" sofa (A7). There was a mural
+of a naked woman in the foom, and on a shelf there were several photographs of
+naked women (A7).
+commanded
+Defendant entered the room wearing only a towel, and, speaking "stern[ly]," he
+to remove her clothes as well (A7). Not knowing "what to do,"
+since she "was the only one there,"
+removed her shirt (A7). Defendant, who had
+removed the towel and was naked, directed
+to take off everything, and she
+complied—leaving on only her thong panties (A7). Pointing to a particular container
+of lotion, defendant instructed
+to massage his back (A7). Defendant then
+directed
+to sit on his back, and as
+straddled defendant's back, her exposed
+buttocks were touching his (A7).
+After a while, defendant turned over on his back and instructed
+massage his chest (A7). As
+complied, defendant held the small of
+to
+back
+with one hand and masturbated with the other (A7). Retrieving a purple vibrator,
+defendant held the vibrator on her vaginal area, on top of her underwear (A6-7).
+Defendant ejaculated, used the towel to wipe himself, and left the room (A8).
+Downstairs, defendant gave S.G. $300 and told her to leave her telephone number
+-7-
+
+
+(A8). As they left the house,
+said that she had received $200 for having
+brought
+to defendant's house that day (A8).
+In a statement that was sworn and tape-recorded
+reported that she was
+16 years of age when
+asked if she wanted to "make money for Christmas"; she
+to defendant's house, where a white woman with long
+agreed (A23).
+blond hair led her up a spiral staircase to a bedroom containing a massage table; there
+was a steam room and shower in the bathroom next door (A23). The woman said
+that massage oils would be there, and that defendant would select the one he wanted
+(A23). Defendant was wearing only a towel, and he selected the oils that he wanted
+to use (A23-24).
+began by rubbing defendant's feet, legs, and back (A24). At defendant's
+direction, l
+removed her clothes and continued massaging while wearing only
+underwear (A24). Turning onto his back, defendant told
+to tub his chest and
+pinch his nipples (A24).
+A
+complied, defendant reached up, unsnapped her bra
+(which opened in the front), and began rubbing her breasts (A24). Defendant asked if
+liked that, and she said she did not (A24). Removing the towel and lying naked,
+defendant then masturbated while continuing to touch
+breasts (A24).
+Next, defendant rubbed
+vaginal area over her panties (A24). When
+tensed up, defendant said, "Relax, I'm not going inside" (A24). But then, defendant
+moved her panties aside, stroked her clitoris, and inserted two fingers into
+vagina and began stroking (A24).
+pulled back, trying to free herself, and finally
+-8-
+
+
+defendant removed his fingers and apologized (A24). Keeping his hand on her
+vagina, defendant rubbed her "very hard" while masturbating until he climaxed into
+the towel (A24). Defendant left $200 on the dresser for
+and $100 to be given to
+for having brough
+here (A24).
+knew that what had happened to her
+was "wrong," and they did not contact her again (A24).
+During a statement that was sworn and tape-tecorded,
+reported that, at 16
+years of age, in September of 2004,l
+!! had offered her a chance to make money
+(A13). From conversations with friends at Royal Palm Beach High School,
+"what
+did for [defendant]," and
+greed (A13).
+drove
+knew
+to
+defendant's house, where they entered through the kitchen and met defendant (A13).
+escotted
+upstairs—past many photographs of naked girls—to a
+bedroom, where
+set up a massage table and oils (A13). Entering the room
+wearing only a towel, defendant selected an oil and instructed
+to rub his legs, the
+area under his buttocks, his back, and chest (A13).
+Defendant removed the towel and lay naked (A13). Defendant told
+to
+"get comfortable," but she did not undress (A13). As
+rubbed defendant's chest,
+he tried to reach down her pants and touch her buttocks, but he did not succeed
+because her clothing was too tight (A13). Defendant began to mastutbate and tried to
+reach up her shirt and touch her breasts, butl
+pulled back (A13-14). Defendant
+continued masturbating to climax, cleaning himself with the towel (A14).
+-2-
+
+
+received $200 in cash, and gave her telephone number to l
+on the way out of the
+house (A14).
+did not provide a massage for defendant on any other occasion, but she
+accompanied
+to defendant's house on two occasions when HI!
+brought
+other girls there (A14). One of those girls was
+s friend,
+who was sixteen
+years of age (A14). The time they too!
+the three entered the house through the
+kitchen, where they were met by
+|!!! (A14).
+and
+both escorted
+o the upstaits bedroom, and later
+gave
+6100 for having brought
+to defendant's house (A14).
+During a statement that was sworn and tape-recorded,
+reported that, at
+the suggestion of a classmate at Royal Palm Beach High School, she had given
+defendant massages at his house when she was 16 years of age (A16). On the first
+visit, the classmate took her to defendant's house, where they entered through the
+kitchen and were met by I
+11 (A16). As
+led her upstairs
+saw that, on
+the wall and on tables, there were photographs of naked women (A16). Once in the
+bedroom,
+set up a massage table and oils, and shortly afterwards defendant
+emerged from a steam room and shower area wearing only a towel (A16). Defendant
+removed all but her panties (A16). After
+lay on the table, and at his suggestion
+nad rubbed defendant's legs and feet, he turned onto his back, touched her
+breasts, and masturbated until he cjaculated (A16). The massage ended at that point
+-10-
+
+
+(A16). L
+was given $200 that day, and defendant asked her to leave her cell phone
+number so he could contact her "when [he] was in town" (A16).
+returned to defendant's home "hundreds of times" over the course of the
+next two years to provide these massages; she became defendant's "number one gir!"
+(A16). Every time defendant was in Palm Beach,
+calledl
+and scheduled
+appointments for
+to "work" for defendant (A17). A "routine" was established
+-ntered the house and "glo]t naked" in the bedroom; she began by massaging
+defendant's back, after which he rolled over and she rubbed his chest; defendant
+masturbated, and with the other hand inserted his fingers into her vagina; defendant
+continued this process until he ejaculated, and then used a vibrator on her vagina until
+she climaxed (A16). During her visits, defendant asked
+now old she was, and
+she said she was 16; defendant told her not to tell anyone her real age (A16).
+At some point, "things escalated" during the massage sessions: at defendant's
+instruction,
+had intercourse with defendant's female friend
+the intercourse included using "strap-on dildos," "large rubber penises," and "other
+devices" that defendant had in his home (A16).
+Defendant watched and
+'masturbated; occasionally, he joined in by providing oral sex to
+and
+(A17). These episodes took place during the time when
+was 16 years of age
+(A17). Defendant sometimes photographed the naked sex sessions between!
+ind
+nd he displayed the photographs in his home (A17).
+-11-
+
+
+Things "continued to escalate," and
+received additional money whenever
+something new was introduced into the routine (A17).
+had an "understanding"
+with defendant, however, that he would not penetrate her vagina with his penis (A17).
+Defendant's penis was "deformed".
+-when erect, it was "thick" toward the base, but
+"thin and small" toward the head; it was shaped like an "egg" or an "oval" (A17).
+During one massage,
+and
+kissed and fondled each other's breasts as
+defendant watched (A17). Later, as the massage continued, defendant "grabbed"
+turned her over on her stomach, and held her head down "forcibly" as he
+inserted his penis into her vagina and repeatedly "pumpled|" his penis into her (A17).
+"screamed," "No!" and defendant stopped (A17). Defendant apologized and
+gave her $1,000 that day (A17)?
+During a statement that was sworn and tape-recorded,
+related that, at 15
+years of age, she was approached by
+a classmate at Royal Palm Beach
+High School and asked about modeling lingerie at the home of a wealthy Palm Beach
+man (A24-25). When they arrived at defendant's home
+nd
+were served
+dinner by defendant's personal chef (A25). After dinner, defendant and
+took
+to an upstairs bedroom, where there was a massage table (A25). When defendant
+had been arrested by the Palm Beach Police Department on September 11,
+2005, for misdemeanor possession of marijuana; during that arrest, she had told the atresting
+officer that she had information about sexual activity at defendant's house (A15-16). As
+noted on pages 26-27, infra, the police subsequently found
+name and cell phone
+number on discarded papers that were retrieved from defendant's trash (A16), and recovered
+a copy of her high school transcript from defendant's bedroom desk (A23).
+-12-
+
+
+entered wearing only a towel,
+said she and
+were going to give defendant a
+massage (A25).
+asked why they were doing that instead of modeling, and
+said it was defendant's "routine" (A25).
+undressed at defendant's direction, until
+she was wearing only panties (A25). At fitst,
+rubbed defendant's legs and feet;
+then, when he turned onto his back, defendant instructed her to rub his chest and
+nipples, and she complied (A25). Defendant masturbated, while alternately touching
+breasts and stroking her vagina, until he ejaculated into the towel (A25).
+Defendant paid
+$200 (A25). He said that "bad things could happen if
+she told anyone what had taken place in his house (A25). Defendant's "houseman"
+drove
+and
+home, any
+vas afraid about the fact that defendant knew
+where she lived (A25). When
+called her several days later to set up another
+appointment for "work,"l
+agreed (A25). Once at defendant's house,
+escorted
+to the bedroom and prepared the room for the massage (A25).
+Defendant entered the room wearing only a towel and directed
+to perform the
+massage naked, which she did (A25).
+began by rubbing defendant's feet and legs,
+and defendant later turned onto his back and masturbated with one hand and with the
+other rubbed her vagina with his fingers (A25). Once defendant had ejaculated into
+the towel, the massage was over (A25)
+vas paid $200, and defendant threatened
+her again— saying that "bad things would happen" if she talked about what had
+happened (A25).
+wanted to notify the authorities but was afraid of what might
+happen to her or her family (A25).
+-
+-13-
+
+
+In a statement that was sworn and tape-recorded,
+related that she was 16
+years of age when a fellow student at Royal Palm Beach High School said
+could
+make $200 by providing massages to defendant while topless (A21-22). Entering the
+house through the kitchen,
+was escorted upstairs to a bedroom that had a
+massage table and a large pink couch (A22). Defendant entered the room wearing
+only a towel, lay face-down on the table, and selected the oils to be used (A22).
+Wearing only thong panties,
+rubbed defendant's legs, back, and feet for 40
+minutes (A22). Defendant turned onto his back and
+rubbed his chest while he
+masturbated to climax, ejaculating into the towel (A22).
+was given $200 for
+that massage (A22).
+During a return visit,
+again was led to the upstairs bedroom, and
+defendant entered wearing only a towel (A22). At defendant's direction,
+performed this massage naked (A22). She rubbed his back first; when defendant
+rolled over and began masturbating, she rubbed his chest (A22). After a while,
+defendant retrieved a large gray vibrator with a large head, and he rubbed her vagina
+with it for about two or three minutes (A22).
+continued rubbing defendant's
+chest until he climaxed, cjaculating into the towel (A22). The massage was over at
+that point, and
+received $200 that day (A22).
+did not provide any more
+massages (A22).
+Duting a tape-recorded statement
+related that, when she was sixteen years
+of age, her classmate
+took her to defendant's house on two occasions (A11).
+-14-
+
+
+The first time,
+drove, they entered through the kitchen door, and they were
+met there by defendant and
+(A11-12).
+escorted her to a bedroom,
+where
+set up a massage table and oils, and entered the room wearing only a
+towel (A12). Defendant lay on the table, selected an oil for
+o use, and she began
+the massage (A12). When defendant tried to remove
+shirt, she became upset
+and discontinued the massage (A12).
+left the house and did not receive any
+money (A12).
+defendant would "stop" (A12).
+had told her to tell defendant if she was "uncomfortable" and
+also knew that "the more you do, the more you
+get paid" (A12).
+Several weeks later,
+agreed to return to defendant's house with
+(A12). Again they entered through the kitchen,
+was escorted upstairs by
+and
+set up the massage table and oils (A12). During the massage, defendant
+tried to reach into
+pants and touch her buttocks, but her clothing was too tight
+and he was unable to do so (A12). Rolling over on his back, defendant tried to touch
+breasts, but she became upset, said she did not want to be touched, and
+discontinued the massage (A12). Defendant gave her $200 that day, and
+did not
+return (A12).
+During a statement that was sworn and tape-recorded, a student whose
+birthdate was 2/08/1987 reported having been approached by
+and offered
+money to provide a "massage" to "a wealthy man in Palm Beach" (A12).
+drove the girl to defendant's housc, where they entered through the kitchen and met
+-15-
+
+
+defendant and
+(A12).
+took the girl upstairs to a bedtoom, where ]
+set up a massage table and oils, and defendant entered the room shortly afterwards
+wearing only a towel (A12). Removing the towel and lying on the table naked,
+defendant chose a lotion for the girl to rub on his thighs and back (A12).
+At defendant's request, the girl undressed and continued the massage wearing
+only thong underpants (A12). The girl straddled defendant's back, her bare buttocks
+touching his, and later he turned onto his back and masturbated as she rubbed his
+chest (A13). The girl, who had "just turned seventeen," "did not want to look at
+[defendant's] penis area" because she "was uncomfortable" (A13). Retrieving a
+"large, white vibrator," defendant rubbed the vibrator on her vaginal area over her
+underwear until he ejaculated (A13). Defendant got up from the table, took a shower,
+and paid the girl either $350 or $400 (13). The girl did not return to defendant's
+house (13).
+During a statement that was sworn and tape-recorded, a girl whose birthdate
+was
+related that she had been told she could make some "quick money"
+by providing a massage while dressed only in underwear (A18). The girl was driven to
+defendant's home, where she and the other girl entered through the kitchen door and
+went to an upstairs bedroom, where there was a massage table neat a sauna/shower
+area and photographs of naked women throughout the room (A18). Defendant
+entered wearing only a towel, and at defendant's direction the two girls undressed as
+well (A18). Wearing only panties, the girls rubbed defendant's legs and feet (A18).
+-16-
+
+
+At defendant's instruction, the recruiter left the room and the new girl finished the
+massage alone (A18).
+At that point, defendant turned onto his back, removed the towel, and
+masturbated as the girl rubbed his chest (A18). Defendant then pulled down the
+girl's panties, retrieved a "large, white" vibrator from a nearby drawer, and rubbed it
+over the girl's outer vaginal area (A18).
+The girl was "very uncomfortable" but
+"knew it was almost over" at that point (A18). Once defendant had ejaculated, he
+wiped himself with the towel and went into the shower area (A18). The girl was given
+$200 for the massage, and the recruiter girl was given $200 for having brought the girl
+to defendant (A18).
+subsequently called and asked the girl to return for some
+additional "work," as
+called it; the girl said she was not comfortable providing
+"that type of work" (A18).
+During a statement that was sworn and tape-recorded, a Royal Palm Beach
+High School student whose birthdate was
+reported having been
+approached by
+to provide a massage for defendant in exchange for $200 in
+cash (A19).
+made the arrangements but was unable to take the girl, so
+someone else drove the girl there (A19). Entering the house through the kitchen
+door, the girl met with
+as well as another "assistant,"
+(A19). As
+escorted her upstairs, the girl noticed a number of photographs of naked girls
+throughout the house (A19).
+-17-
+
+
+Defendant entered the room wearing only a towel, lay down on the massage
+table, and selected oils for her to use (A19). Defendant asked the girl to remove her
+clothes, but that time she refused (A19). The girl returned and provided massages on
+several other occasions, and each time "it was more than a massage" (A19-20). The
+girl did not look below defendant's waist, but she knew he always masturbated under
+the towel (A19). Eventually, defendant convinced the girl to remove her clothes and
+perform the massage dressed only in her thong panties (A19). On occasion,
+defendant tubbed a white vibrator with a large head on her vaginal area as he
+masturbated (A19). On two occasions, the girl brought a classmate to defendant's
+home to perform a massage, and the gitl received $200 for each one she brought
+(A20).
+In a statement that was sworn and tape-fecorded, a girl whose birthdate was
+related having been approached byl
+Tand asked about making money
+for providing massages to defendant (A20). The girl agreed, and
+drove her to
+defendant's home, where they were met by defendant and
+(A20).
+|took
+the girl upstairs and then left the room (A20). Defendant entered wearing only a
+towel, and lay on his stomach as the girl, wearing only panties, rubbed his back (A20).
+Defendant masturbated until he ejaculated (A20). The girl "felt the whole situation
+was weird"; but she was paid $200, so she returned (A20).
+was paid $200 for
+having brought the girl to defendant's house (A20).
+-18-
+
+
+During subsequent massages, defendant grabbed the girl's breasts and fondled
+them (A20). On one occasion, when she was 17 years of age, defendant paid her
+extra to have vaginal intercourse, and she agreed (A20). As the girl lay on the massage
+table, defendant penetrated her vagina with his penis, withdrawing to ejaculate onto
+the table (A20). Defendant gave the girl $350 for that massage (A20). On a different
+occasion, defendant had his girlfriend "l
+and the girl kiss and fondle each
+other's breasts and buttocks as he watched and masturbated (A20). On yet other
+occasions, defendant used a large, white vibrator on the girl's vagina as she massaged
+him (A20). Defendant masturbated during every massage (A20).
+During a statement that was sworn and tape-recorded, a Royal Palm Beach
+High School student whose birthdate was
+related that, at 17 years of age, she
+went with
+to defendant's house (A10-11). Entering the house through the
+kitchen, the girl was escorted upstairs by
+(A10-11). Defendant entered the
+bedroom wearing only a towel, but she remain clothed (A11). At one point during
+the massage, defendant grabbed her buttocks and pulled her close to him (A11). The
+girl received money but did not remember how much (A11). She was "uncomfortable
+with the whole experience" and did not return (A11).
+During a statement that was sworn and tape-tecorded, a Royal Palm Beach
+student whose birthdate was
+related that she was 16 years of age when she
+went to defendant's house for the first time at the suggestion of a classmate (A20-21).
+escorted the girl upstairs to a bedroom, and defendant lay naked on a massage
+-19-
+
+
+table as he handed her some oils (A21). Fully clothed, the girl rubbed defendant's legs
+and back (A21). Defendant paid her $300 for the massage (A21). Subsequently,
+| called the girl and said that defendant was "in town" and wanted her to
+"work" (A21). The girl went to defendant's house and provided a massage, again
+while fully-clothed (A21). The following time, defendant asked the girl to remove
+her clothes, and she complied (A21). Wearing only thong panties, the girl continued
+the massage as defendant turned on his back and masturbated while she rubbed his
+chest (A21). Once he had climaxed, defendant got up and told her to get dressed
+(A21). The girl received $300 that day (A21).
+By the time
+called and asked her to work again, in about January of
+2005, the girl had a boyfriend and did not feel comfortable about going, but she
+decided to go one last time (A21). Defendant entered the bedroom wearing only a
+towel and lay down on the massage table (A21). During the massage, defendant
+caught the girl looking at the clock a few times, and he asked if she was "in a hurry"
+(A21). When the girl said that her boyfriend was waiting for her outside, and that she
+would not be back again, defendant told her to leave because she was ruining his
+Even after that falling out, defendant still wired her money by
+massage (A21).
+Western Union as a "Christmas bonus" (A21).
+During a statement that was sworn and tape-recorded, a girl whose date of
+birth was
+reported having provided massages to defendant for two years,
+beginning when she was 16 years of age (A14). Over the course of that time,
+-20-
+
+
+defendant "kept pushing to go further and further" (A14). "Recently" she had begun
+removing her clothes and providing the massage dressed only in a thong panty, and he
+had begun to masturbate as she rubbed his chest (A14-15). Defendant rubbed her
+buttocks, but she pulled back when he tried to touch her breasts (A15). She also
+refused to let defendant use a "large white" vibrator, with a "huge head on the tip,"
+on her; defendant kept the vibrator in a closet near the massage table (A14-15).
+Defendant "tried] to get away with more and more on each massage," and she
+considered him to be a "pervert" (A14-15).
+The most recent massage had been on October 1, 2005 (A15). On that date,
+the girl asked to borrow one of defendant's cars, and he said he would rent a car for
+called and said that defendant had
+her (A15). Two days later, on October 3rd, L
+rented a new Nissan Sentra for her, and that the car would be hers fot a month (A15).
+The girl related that, at the time of the interview, the car was parked next to the Lynn
+University Gym field (A15).
+In a statement that was sworn and tape-recorded, a Royal Palm Beach High
+School student whose birthdate was 6/01/1986 reported having been approached by
+a classmate who asked if the girl wanted to "work" (A17). As the girl explained it,
+atrangements were made with defendant's "assistant," L
+and then the girl went
+to defendant's home in March of 2005 and gave him a massage, fully-clothed, in
+exchange for $200 (A17). Since the girl's answers seemed "almost scripted," and she
+appeared to be "nervous," the detective asked if she had been contacted by anyone
+-21-
+
+
+from defendant's "organizations" or "house" (A17). The girl said she had been
+"interviewed" by a "private investigator" named "Paul," who had been hired by
+defendant (A17). The investigator had asked her about the police investigation, and
+he had given her his telephone number, which she related to the detectives (A17).
+The Evidence Corroborating The "Massage" Statements
+The probable-cause affidavit also outlined a variety of other evidence
+uncovered during the investigation, including the following:
+gave a statement that was sworn and taped-recorded (A8-10).
+said that she was 17 years of age when she was approached by a friend about
+providing a massage for defendant in exchange for $200 (A8).
+friend drove
+her to defendant's home, where defendant and
+greeted her in the kitchen, and
+then
+led
+to the upstairs bedroom, arranged the massage table and oils,
+and left the room (A9). Defendant entered the room wearing only a towel, lay facedown on the table nude, and selected an oil for her to use (A9).
+was naked
+while performing the massage, and defendant grabbed
+buttocks;
+"felt uncomfortable" and said that she did not want to be "touched" (A9).
+Defendant paid
+$200 for the massage (A9). Defendant offered to pay
+for simply bringing girls to him—"the younger the better," defendant said
+(A9). One time,
+brought a 23-year-old, and defendant said she was "too old"
+(A9).
+remembered having brought six different girls to defendant, including
+-22-
+
+
+all between the ages of 14 and 16 (A9)L
+was the youngestshe was 14 yeats of age at the time of the massage (A9). Defendant did not contact
+1 directly to make arrangements; defendant informed Billa that he was going
+to travel to Palm Beach, and
+a contacted
+1, who in turn arranged for girls
+to "work" for defendant during that time period (A9-10).
+called for
+at home and drove her to defendant's house;l
+was driving a red pick-up truck at that time (A9). Entering through the kitchen door,
+and
+net with defendant's house chef and
+1, after which
+escortedl
+to the upstairs bedroom (A9).
+said she had been paid $300 for the
+massage, and
+received $200 for having brought
+was the
+last girl
+took to defendant, because
+parents found out about her
+"visits" to defendant and she stopped (A10).
+1 changed her cellular number in
+order to avoid
+but
+continued to call
+house and leave
+messages fot her there (A9-10).
+gave the police cellular numbers and possible addresses for the girls
+whom she had mentioned (A10). Once the interview had concluded, a sergeant
+informed
+that, by admitting that she had taken underage girls to defendant's
+house, she had implicated herself in a crime (A10). During the ride home,
+told the police, "I'm like a Heidi Fleiss" (A10). That statement was recorded by a
+device in the car (A10).
+-23-
+
+
+During a statement that was sworn and tape-recorded, a Royal Palm Beach
+High School student whose birthdate was
+reported that
+approached girls at school and asked if they wanted to "work" for defendant by giving
+him massages (A19). The girl declined to provide any massages herself, but she went
+along on four of five occasions when _
+defendant's home (A19). The girl waited in the kitchen with
+took other girls, including to
+during the
+was given
+massage, and defendant's cook provided food for them (A19).
+$200 for each girl she delivered (A19). The girl noticed that there were many
+photographs of naked girls in the house (A19).
+During an interview, Jose Alessi stated that, from about 1993 through 2004,
+he had been employed by defendant as house manager, driver, and maintenance
+person at the Palm Beach house (A26). Defendant's cooks and assistants travelled
+with him on his private plane (A26). Defendant received three massages each day in
+the house (A26). Each masseuse was different, and toward the end of Alessi's period
+of employment, the masseuses were "younger and younger"——sixteen of seventeen
+years of age "at the most" (A26). The massages took place in defendant's bedroom;
+Alessi set up the massage table there (A26). There were times toward the end of
+Alessi's employment that he found a vibrator and long rubber penis in the sink after
+the massage; Alessi had to wash off those items (A26). "[Allmost always" after a
+massage Alessi had to make defendant's bed (A26).
+-24-
+
+
+During a statement that was sworn and tape-recorded, Alfredo Rodriguez
+related that, from November 2004 through May of 2005, he had been employed by
+defendant as "house manager" of the Palm Beach home (A26). In this capacity,
+Rodriguez acted as butler, chauffeur, chef, and houseman; he also tan errands for
+defendant, and provided for defendant's guests (A26). During the time defendant
+was "in residence," he had two massages a day—one in the morning, and one in the
+afternoon (A26). Rodriguez was told to expect someone and to make them
+comfortable until either defendant or
+arrived; Rodriguez admitted the girls into
+the kitchen, where either defendant or
+met them and escorted them upstairs
+(A26).
+The girls appeared to be too young to be masseuses; Rodriguez knew that the
+girls were still in high school and were of high school age (A26). On one occasion, at
+defendant's direction, Rodriguez delivered a dozen roses to Royal Palm Beach High
+School for one of the girls who had come to the house to provide a massage (A26).
+On another occasion, also at defendant's direction, Rodriguez rented a car from
+Dollar Rent-A-Cat and delivered it to the same girl-so she could drive to
+defendant's home without incident, whereas otherwise she often needed rides to and
+from the house (A27).
+Rodriguez produced a folder containing documentation: there was a note on
+defendant's stationery directing the delivery of roses to Royal Palm Beach High
+School after
+school play, and on the same stationery a direction to rent a car
+-25-
+
+
+for
+and to extend the contract (A27). Rodriguez believed that there was "a lot
+more going on than just massages" (A26). Rodriguez often cleaned defendant's
+bedroom after the massages, and found vibrators and "sex toys" scattered on the
+floor; he "wiped down" those items and put them away in an armoite neat
+defendant's bed (A26-27).
+While executing a search warrant at defendant's home, the case detective saw a
+pink-and-green couch in the master bedroom, photographs of naked young girls
+lining a wall of the stairway leading from the kitchen to the bedroom, and numerous
+photographs of naked young girls throughout the houses; some of the subjects of the
+photographs seemed to be girls whom the detective had interviewed (A23). Inside a
+bedroom desk containing stationery in defendant's name, the detective found a high
+school transcript for
+(A23). In an armoire next to the bed, the detective found
+a bottle of massage oil (A23). 'There was a massage table in the master bedroom, and
+other tables throughout that floor of the house (A23).
+On the first floor, the detective found two covert cameras hidden within
+clocks—one in the garage, and the other on a shelf behind a desk (A23). A computer
+found in the house appeared to display images from the two covert cameras, and the
+hard drive of that computer contained several images of
+and other girls
+whom the police had interviewed (A23). Telephone message books recovered from
+the house contained carbon copies of various messages, some of which listed the
+names and telephone numbers of girls whom the detective recognized from the
+-26-
+
+
+investigation (A23). In the text of some of those messages, there were notations
+indicating that the caller was confirming a "work" appointment (A23). Other
+messages listed the caller's message as, "I have girls for him," and, "I have 2 girls for
+him";
+name appeared at the bottom of those messages, in the space provided
+for the name of the person who had taken the message (A23).
+Subpoenaed cellular telephone records showed that !
+I had called
+"during the exact times and dates" of the incidents that|
+had described, and that
+also had called
+"during the time frame" of the incidents related
+by those girls (A27). A comparison of data from subpoenaed aviation records
+indicating artival and departure times for defendant's private plane at Palm Beach
+International Airpott, and subpoenaed cellular telephone records showed that ?
+had made telephone calls to
+Land the victims either "in the days just prior to"
+defendant's arrival in Palm Beach, or during the time he was already there (A27).
+After the interview of the girl whose birthdate was
+detectives found
+a silver Nissan Sentra parked near the gym of Lynn University—the car was registered
+to Dollar Rent-A-Car; had been rented by Janusz Banasiack, who was employed as
+defendant's houseman at the time; and had been charged to a credit card in
+defendant's name (A15). Subpoenaed records of Western Union revealed that, on
+December 23, 2004, defendant had sent money to the girl with birthdate
+(A21).
+-27-
+
+
+father told police that
+• had come to their home to get
+on
+February 6, 2005, and that
+was driving a pick-up truck at the time (A7).
+During a controlled, tape-recorded telephone call to
+cellular telephone.
+asked what she "needled] to do to make more money," and
+replied, "The
+more you do, the more you get paid" (A8). I
+subsequently called
+[cellular
+telephone and left a voicemail message indicating that she had set up an appointment
+for
+o go to defendant's house at 11:00 a.m. on April 5, 2005; the police recorded
+that message from
+voicemail (A8). A trash, pull from defendant's house on
+April 5, 2005, revealed a telephone message for defendant which listed the names of
+and
+and the time 11:00 a.m. (A8).
+During the course of the investigation, detectives learned that several people
+whom the police had identified as possible victims were in fact 18 years of age or
+older, and therefore were consenting adults (A25). During interviews, these adults
+described what the police found to be "the same massage routine" as the one
+pottrayed by the victims:
+contacted them and set up appointments for them to
+"work"; they entered defendant's house through the kitchen, and
+escorted
+them to an upstairs bedroom; defendant entered the room wearing only a towel and
+asked them to get comfortable; as they performed the massage naked, defendant
+either touched their vaginas with his fingers of rubbed their vaginal areas with a
+vibrator; defendant masturbated to climax, and at that point the massage ended (A25-
+26).
+-28-
+
+
+The Recommendations Of The Board
+Pursuant to the mandate of Corrections Law Section 168-1, the Board issued a
+"Case Summary" and a completed "Risk Assessment Instrument" with respect to
+defendant. These documents were based upon the Florida probable-cause affidavit,
+as well as defendant's "inmate file," which included defendant's pre-sentence report,
+prior criminal history, and post-offense behavior (A65).
+The Case Summary
+The Case Summary included a detailed account of the operation that defendant
+had established and maintained for the purpose of satisfying his obsessive sexual
+desire for young girls. The Summaty stated that, during 2005, defendant had sexually
+assaulted "numerous" girls between the approximate ages of 14 and 17 (A65).
+"Most" of the victims had been "recruited" from a local high school by a 17-year-old
+who herself had begun as one of defendant's massage victims (A65).
+The Summary noted police repotts
+containing references to police
+conversations with "numerous" girls (A65). According to the police reports, "most"
+of the girls were "embarrassed to speak with police regarding what had happened to
+them while they were in [defendant]'s home" (A65).
+Nonetheless, "Is|worn
+statements" had been taken from "at least five victims and seventeen witnesses"
+about "massages and unlawful sexual activity" that had taken place at defendant's
+home (A65).
+-29-
+
+
+The Summary recounted how, one after another, school girls had been lured to
+defendant's home with the promise of money in exchange for performing a
+"massage" (A65). Once the girl had been led through his home and to his bedroom,
+past photo displays of naked young girls, defendant entered the bedroom wearing
+only a towel and lay down on a massage table that had been set up there (A65). On
+most occasions, defendant immediately removed the towel and asked the girl to
+remove her clothing as well (A65).
+Most girls undressed down to their bra and
+panties, and some removed even those items (A65). During the massage, defendant
+either touched the gitl's breasts, inserted his fingers into her vagina, or used a vibrator
+on the girl's vaginal area—-sometimes doing a combination of those things (A65).
+Defendant masturbated to climax during the encounter, often ejaculating into the
+towel that he had been wearing (A65). The girls were paid a minimum of $200 at the
+end of each encounter (A65).
+Pointing to a number of victims as examples, the Summary stated that, with a
+14-yeat-old, for example, defendant had touched the girl's vaginal area with a vibrator
+while she performed the massage (A65). Yet a different girl, 16 yeats of age, had gone
+to defendant's home at least 100 times over the course of a two-year period (A65).
+When receiving a massage from this girl, defendant had masturbated while either
+touching the young girl's breasts, inserting his fingers into her vagina, or using a
+vibrator on her vaginal area (A65). On some occasions, defendant paid this young girl
+to engage in sexual activity with an adult female friend of his while he watched;
+-30-
+
+
+defendant sometimes participated by performing oral sex on the young girl (A65). On
+one occasion, the encounter escalated to the point where defendant forcibly raped the
+girl—-turning the teenager over on the massage table and, against her will, forcibly
+inserting his penis into her vagina (A65).
+The Summary stated that defendant's conduct while on Community Control
+had been assessed as "satisfactory"; that he lacked a history of substance abuse; and
+that, because defendant had pleaded guilty, he was being "credited" with having
+accepted responsibility for his actions (A65). Regarding defendant's criminal history,
+the Case Summary stated that, in 1973, in England, defendant had been convicted of
+the misdemeanor Unlawful Possession of an Offensive Weapon-—namely, a cane that
+incorporated a concealed blade (A65). Defendant had been assessed for: "sexual and
+deviate intercourse,
+forcible compulsion,
+numerous victims and theit ages, a
+continued course of sexual misconduct, à prior misdemeanot conviction in England
+absent specific information, his stranger relationship to most victims, and establishing
+a relationship with these underage girls for the purpose of victimization" (A65).
+The Board calculated that defendant "score[d] as a Level III Sex Offender with
+absolutely no basis for downward departure" (A66). As the Board assessed the
+circumstances, defendant had "used his wealth and power in such a way so that he
+could take advantage of many teenage girls to satisfy his own sexual perversions"
+(A65-66).
+-31-
+
+
+The Risk Assessment Instrument
+Of the fifteen factors included in the Risk Assessment Instrument, the Board
+recommended that defendant receive points for seven of them, as follows: for the
+"Use of Violence" factor, 10 points, based on the fact that defendant had used
+forcible compulsion; for the "Sexual Contact with Victim" factor, 25 points, based on
+the fact that defendant had committed either sexual intercourse, oral of anal sexual
+conduct, or aggravated sexual abuse; for the "Number of Victims" factor, 30 points,
+based on the fact that there were three or more victims; for the "Duration of Offense
+Conduct with Victim" factor, 20 points, based on the fact that defendant had
+committed a continuing course of sexual misconduct; for the "Age of Victim" factor,
+20 points, based on the fact that there was a victim between the ages of 11 and 16
+years; for the "Relationship with Victim" factor, 20 points, based on the fact that a
+victim either was a stranger, someone with whom defendant had established a
+relationship for the purpose of victimizing, or someone with whom he had a
+professional relationship; and, for the "Number and Nature of Prior Crimes" factor, 5
+points, since the Board concluded that defendant had no prior history of sex crimes
+or felonies. By the Board's calculations, defendant had a total risk assessment score
+of 130 points (A64).
+-32-
+
+
+POINT
+THE SORA COURT'S
+DESIGNATION
+OF
+DEFENDANT AS A LEVEL-THREE OFFENDER
+WAS SUPPORTED OVERWHELMINGLY BY THE
+RECORD. THE PROCESS BY WHICH THE COURT
+REACHED
+AND
+DELIVERED
+THAT
+DETERMINATION WAS ENTIRELY FAIR AND
+PROPER (Answering Defendant's Brief).
+As noted, the Board assessed defendant's risk level according to the various
+factors set out in the Risk Assessment Instrument, and they calculated defendant's
+score at 130, making him a presumptive level-three offender. The Board also
+considered all of the facts and circumstances to see if there was any legitimate basis
+for a downward departure, and they concluded that there was none. For those
+reasons, the Board recommended that defendant be designated a level-three sex
+offender.
+At the SORA hearing before Justice Pickholz, defendant essentially took the
+position that the level-three designation could not be supported by the crimes with
+which he had actually been charged. Minimizing the seriousness of the crimes and
+claiming he was present in New York only for limited periods of time, defendant
+urged additionally that strict level-three reporting requirements would be unfair in this
+particular case. The People, in turn, voiced their own concerns about assessing points
+for criminal conduct beyond that for which defendant had been charged; in reaching
+that conclusion, the People apparently relied on a combination of a mistaken
+interpretation of the governing legal standards and certain secondhand information
+-33-
+
+
+about the Florida case. After a full SORA hearing, including an extended inquiry
+revealing the unreliable nature of the prosecutor's information, Justice Pickholz
+adopted the recommendation made by the SORA Board and designated defendant a
+level-three offender.
+On appeal, defendant claims that the SORA court erred in a number of ways.
+Defendant contends that the level-three finding was not supported by the record and
+instead was attributable to the court's "personal disdain" for defendant. Defendant
+further complains that the court denied the parties an opportunity to present evidence
+on disputed issues. In addition, defendant argues that the SORA order itself lacked
+the requisite findings and conclusions.
+First, defendant's appellate complaints are almost entirely unpreserved. During
+the proceedings below, defendant mentioned only one of his current complaints—
+namely, the one about the purported lack of record support. Furthermore, none of
+defendant's current complaints has even a shred of merit. Thus, there is no reason to
+disturb the decision of the SORA court.
+A.
+As the Sex Offender Registration Act itself explains, "the threat posed by a sex
+offender depends upon two factors: (i) the offender's likelihood of reoffense, and (i)
+the harm that would be inflicted if he did reoffend." Sex Offender Guidelines and
+Commentary ("Guidelines") at 2. "I]n determining an offender's risk level," the
+-34-
+
+
+Guidelines "seek to capture both these elements." Id. The Guidelines recognize that
+certain conduct, in particular, carries a strong likelihood of re-offense. "Offenders
+who target young children as their victims are more likely to reoffend," the Guidelines
+state. Guidelines at 11 (internal citations omitted).
+"Such offenders also pose a
+heightened risk to public safety," the Guidelines add, because young children both
+"lack the physical strength to resist" and "can be more easily lured into dangerous
+situations than adults." Id. For those reasons; the Guidelines provide a special
+category for an offender whose victims are between the ages of 11 through 16.
+Likewise, the Guidelines explain that "the existence of multiple victims is indicative
+of compulsive behavior and is, therefore, a significant factor in assessing the
+offender's risk of re-offense and dangerousness." Guidelines at 10 (internal citations
+omitted).
+In an effort to predict the likelihood of re-offense and the extent of the harm
+inflicted as a result, a Risk Assessment Instrument assigns points to an offender for an
+extended series of risk factors—-including those just mentioned-and the offender's
+total score using that calculation becomes his "presumptive risk level." Guidelines at
+3. Although a court is empowered to exercise its discretion and depart from the
+presumptive risk level, "t)he expectation is that the [risk assessment] instrument will
+result in the proper classification in most cases, so that departures will be the
+exception -- not the rule." Commentary at 4; see also People v. Guaman, 8 A.D.3d
+545 (2d Dept. 2004) (citation omitted).
+LA SORA court may adopt the presumptive
+-35-
+
+
+risk level as long as the court finds that the risk factors giving rise to the offender's
+score were supported by "clear and convincing evidence." See Correction Law $168-
+n(3); People v. Pettigrew, 14 N.Y.3d 406, 408 (2010); People v. O'Neal, 35 A.D.3d
+302 (1st Dept. 2006).
+That SORA employs this relatively-relaxed standard, as opposed to proof
+beyond a reasonable doubt, reflects the fact that a SORA risk-level assessment is
+made not for the purpose of punishing the offender but rather for the sole purpose of
+protecting the public from the risk the offender poses. See People v. Knox, 12
+N.Y.3d 60 (2009)("governmental interest advanced by SORA is, of course, the
+protection of the community against people who have shown themselves capable of
+committing sex crimes"); People v. Windham, 10 N.Y.3d 801, 802 (2008)(SORA risklevel determination "is a collateral consequence of a conviction for a sex offense
+designed not to punish, but rather to protect the public").
+In determining
+whether a risk factor has been supported by "cleat and
+convincing evidence," the SORA court may consider information from any source
+that is "reliable." Correction Law §168-n(3); Guidelines at 7. Plainly, that includes
+hearsay. Correction Law $169-8(3)(SORA court "may consider reliable hearsay
+evidence submitted by either party"); see also People v. Conway, 47 A.D.3d 492, 492-
+493 (1st Dept. 2008); People v. Mendez, 45 A.D.3d 429 (1st Dept. 2007). Indeed,
+case summaries prepared by the SORA Board and submitted to court "certainly meet
+the 'reliable hearsay' standard for admissibility at SORA proceedings," People v.
+-36-
+
+
+Mingo, 12 N.Y.3d 563, 573 (2009), and those materials "often [are] replete with
+hearsay culled from a variety of secondary sources." People v. Vasquez, 20 Misc.3d 37
+(App. Term 1st Dept. 2008). Hearsay is "reliable for SORA purposes" if, "based on
+the circumstances surrounding the development of the proof, a reasonable person
+would deem it trustworthy." People v. Mingo, 12 N.Y.3d at 575.
+Victim statements, in particular, are among the class of materials treated as
+presumptively reliable for purposes of a SORA hearing, and that is true even when
+the statement was not made under oath, People v. Mingo, 12 N.Y.3d at 576. The
+SORA court should disregard a victim statement only when that statement is
+"equivocal, inconsistent with other evidence, or seems dubious in light of other
+information in the record." 12 N.Y.3d at 577.
+Equally cleatly, the mere fact that conduct has not been the subject of formal
+charges does not bat its consideration for SORA purposes. The SORA Guidelines
+explicitly provide that, when determining an offender's risk level, "the Board is not
+limited to the crime of conviction." Guidelines at 5. The Guidelines state that "the
+fact that an offender was not indicted fot an offense may be strong evidence that the
+offense did not occur." Guidelines at 5 (emphasis in original). Howevet, by phrasing
+that principle in the permissive way—-that the absence of indictment "may" be strong
+evidence (emphasis supplied)
+-the Legislature conveyed nothing more than the
+simple fact that there were circumstances under which the absence of formal charges
+would, in fact, cast doubt on the offender's commission of the conduct at issue.
+-37-
+
+
+Indeed, this Coutt recently recognized as much in People v. Johnson, 77
+A.D.3d 548 (1st Dept. 2010). In Johnson, the defendant had pleaded guilty to the
+sole count of a superiot court information charging statutory tape, and this Court
+upheld a SORA assessment against him fot having used forcible compulsion in the
+commission of that crime. The SORA court had based the forcible-compulsion
+assessment on the victim's hearsay statement, as contained in the felony complaint,
+describing the manner in which the crime had been committed. In doing so, Johnson
+implicitly acknowledged the likely scenario that the defendant had been permitted "to
+plead to a crime less serious than the one that could be proven." People v. Johnson,
+77 A.D.3d at 550 (McGuite, J. concurring).
+Finally, it is clear that the ordinary rules of preservation apply to an appeal from
+a SORA determination. See People v. Windham, 10 N.Y.3d at 802; People v. Roland,
+292 A.D.2d 271 (1st Dept. 2002).
+Here, for the reasons set out fully below, the SORA coutt properly recognized
+that the Board's assessment of points for repeated and serious sex offenses was based
+on information that was entirely reliable. The victim-accounts themselves carried
+strong indicia of reliability, and there was an abundance of reliable information
+corroborating the events described in the victim-accounts. Furthermore, the manner
+in which that information was conveyed had its own inherent assurances of reliability.
+Based upon the totality of extensive and compelling information before it, the SORA
+court had more than ample basis to conclude that the victim-accounts were reliable,
+-38-
+
+
+and that neither the formal charges that had brought against defendant nor his guilty
+plea accurately conveyed the nature and extent of his criminal conduct in this case.
+B.
+Defendant claims that the risk-assessment determination was not supported by
+the requisite "clear and convincing evidence." As he did below, defendant attempts
+to limit the Florida conduct considered for risk-assessment purposes to only those
+actions that can be said to have given rise to the two formal charges brought against
+him. Defendant claims that all of the detailed information about his additional and
+sordid sexual misconduct was unsuitable for consideration for SORA purposes. And,
+in advancing that argument, defendant points largely to statements to that effect made
+by the People at the SORA hearing. For the reasons set out more fully below, this
+Court should uphold the SORA court's decision to accept the well-supported
+recommendations made by the SORA Board, notwithstanding arguments by both
+defendant and the People to the contrary.
+3 On appeal, defendant urges that the supposed absence of the requisite "clear and
+convincing evidence" constituted a violation of his federal constitutional right to due process
+(Brief for Defendant at 32-33). That notion was never mentioned below, so it has not been
+preserved for appellate review. People v. Kello, 96 N.Y.2d 740, 744 (2001)(constitutional
+complaints must be raised with specificity). In any event, the short answer is that, as set out
+herein, the requisite supporting information was, in fact, before the SORA court, and
+therefore no violation of defendant's rights, constitutional ot otherwise, occurred.
+-39-
+
+
+As noted, when determining whether a risk factor has been supported by "clear
+and convincing evidence," the Board and a SORA court may consider information
+from any source that is "reliable." So too, as a practical matter, the information at a
+SORA hearing very often is in the form of reliable hearsay. Here, the SORA court
+correctly recognized that the information submitted by the Board, including the
+victim-statements, was entirely reliable and therefore appropriately considered for the
+purpose of making a SORA risk-level determination.
+To begin, the evidence of defendant's extended course of sex crimes was
+before the court not only in the Board's Case Summary of those activities—which, as
+noted, was presumptively admissible at the hearing-but also in the underlying 22-
+page probable-cause affidavit itself. The court saw that the affidavit systematically
+identified all the sources of the information it recounted— either by full name of, in
+the case of a minor, by initials and date of birth. The court also saw that the affidavit
+had been signed and sworn to by the Palm Beach detective who had prepared it. See
+People v. Mingo, 12 N.Y.3d 563, 573 (2009) (fact that statement made under oath is "a
+significant, though not indispensable, indication of reliability"). This combination of
+circumstances gave the document an unmistakable cast of reliability.*
+^ Of course, defendant's suggestions notwithstanding (Brief for Defendant at 21, 28),
+it was of no meaningful signiticance for SORA assessment purposes that the SORA
+materials provided to the court happened to contain a copy of the probable-cause affidavit
+listing defendant's accomplice,
+,, as the subject, rather than the one that listed
+detendant. As detendant himselt knew, and therefore did not make a complaint along this
+(Continued...)
+-40-
+
+
+More particulatly, though, the court knew that the affidavit's contents, and
+especially the victim-statements themselves, carried nothing short of hallmark indicia
+of reliability. Notably, the affidavit stated that all the victim-statements, and many of
+the witness-statements as well, had been sworn and tape-recorded. The affidavit also
+stated that these sworn statements by the victims had been preserved in the form of
+tape-recordings (A6). Significantly, too, virtually all of those accounts were highly
+detailed-—itself an indicator of reliability.
+Even more telling was the fact that the victims' detailed accounts of the sexual
+encounters were virtually identical. As noted, all of the girls reported having been
+ushered through the kitchen entrance of defendant's house and then escorted to an
+upstairs bedroom containing a massage table, and then defendant, wearing only a
+towel, entered, made a selection from among an array of massage oils, and lay nude
+on the table while requesting that the girl undress as well. While some "massages"
+included supplemental sexual activities and even an additional participant, the average
+massage followed a strikingly similar pattern: defendant began by lying face-down and
+selecting a massage oil, after which, at his instruction, the girls first rubbed his feet,
+legs, and back; once defendant had rolled over onto his back, the girls followed his
+(...Continued)
+line at the hearing, it was simply the content of the affidavit's sworn allegations themselves
+hat was at issue at the hearing.
+and
+criminal conduct as an accomplice of defendant in that process.
+-41-
+
+
+instruction to rub his chest, at which point defendant began masturbating with one
+hand while using the other to make some form of contact with their bodies-either
+with his hands alone or with the aid of a vibrator; and the massages all ended as soon
+as defendant ejaculated onto the towel that he had brought with him.
+In fact, many of the victim-accounts included references to the same distinctive
+details about the "massage" locale—a hot-pink-and-green couch in the bedroom, for
+example, as well as an adjacent bathroom containing not just a shower but also a
+sauna/steam room, and a stairway-wall lined with photographs of naked young girls.
+Put simply, the similatity of all the massage accounts provided a valuable assurance of
+reliability to all those various accounts.
+While the victim-accounts, in themselves, thereby carried strong indicia of
+reliability, the court saw that those accounts also were heavily corroborated by a
+wealth of independent and inherently reliable information. Again, this corroborative
+information as well was set out in detail in the sworn probable-cause affidavit.
+For example,
+herself made a sworn, tape-recorded statement to police
+acknowledging her own particular tole in defendant's enterprise and confirming the
+cole of what the victims had said. Just as many of girls described having been
+recruited by
+for the equivalent of a finder's fee, l
+confirmed that she
+had, in fact, done so. Echoing the routine portrayed by the victims,
+described
+how she herself had begun by providing a massage for defendant at age 17—entering
+the house through the kitchen, and being escorted by
+Ill! to an upstairs bedroom,
+-42-
+
+
+where she removed her clothes and performed a massage naked at defendant's request
+after he had selected oils while lying naked on the massage table. But, as
+explained, she soon "graduated" to bringing other girls to defendant for that purpose,
+in exchange for which she was given money.
+In this regard, as noted, 14-year-old
+had given one of the detailed victimaccounts, and
+also acknowledged having brough
+to defendant when
+was 14 years of age, and having received $200 for that service.
+eceived
+$300 for the massage,
+confirmed. All of those details mirrored the account
+that
+herself had given.
+also confirmed another important fact common
+to the victim-accounts—namely, the vital importance of the young age of the girls
+supplied to defendant. All girls whom |
+had brought to defendant were
+between the ages of 14 and 16,
+stated.
+words to her on the subject— "The younger, the better," he had emphasized.
+related defendant's clear
+remembered well defendant's rejection as "too old" a 23-year-old whom
+had
+once brought to him.
+Significantly, when evaluating the trustworthiness of |
+account, the
+remarks constituted admissions on her part, and therefore
+court knew that
+were imbued with a high degree of inherent reliability. See generally People v.
+Brensic, 70 N. Y.2d 9, 14 (1987). Notably, too, there was no doubt that
+was
+aware of the incriminatory nature of the remarks, since the police informed her of
+that circumstance explicitly. When a sergeant pointed out that
+had implicated
+-43-
+
+
+herself in criminal activity—by admitting that she had been paid for delivering minors
+for the purpose of sexual activity
+• bragged that she was "like Heidi Fleiss."
+Another compelling piece of cotroborative evidence before the court came in
+the form of a controlled telephone call made by
+to
+Detectives heard
+ask what exactly she had to "do" in order to "make more money," and, without
+missing a beat,
+replied by explaining, "The more you do, the more you get
+paid." In that same connection, there was the voicemail message that
+had
+subsequently left fo
+informing
+f her appointment at defendant's house at
+11:00 a.m. on April 5, 2005; relatedly, the court also saw that, as a result of a trash
+pull, detectives had the remnants of a telephone message left for defendant listing the
+names of both
+and
+along with that very same date and time.
+For yet additional confirmation, the court also had read the accounts of two
+people who had worked as housemen for defendant—for a combined period of about
+eleven and a half years. Both housemen had seen a steady flow of different girls come
+to defendant's house at regular intervals—-cither two ot three times a day— on every
+day that defendant was in residence at his Palm Beach home. And, both housemen
+noticed that these supposed masseuses seemed to be very young —16 or 17 years of
+age, at most. The men further reported that, after so-called massage sessions, they
+routinely found various "sex toys"—-such as a vibrator and a long rubber penis—-
+strewn around the bedroom and adjacent bathroom, and it became the responsibility
+of the housemen to wash the sex toys and put them away.
+-44
+
+
+Next, the affidavit pointed to various subpoenaed records that yielded
+additional corroboration of the victim-accounts. For example, cell phone records
+revealed calls made by
+to certain victims at times consistent with ones
+reported by the victims. Indeed, cell phone records revealed calls made by
+both to
+and various victims, and, with aviation-record data of arrival and
+departure times for defendant's private plane at Palm Beach International Airport, it
+was clear that all of those calls had been made during periods either immediately
+before, or during, defendant's stays in Palm Beach. That information, thus,
+confirmed the accounts-by
+and the victims alike-that once defendant
+informed
+of his impending stays in Palm Beach,
+reached out both to
+and to certain girls directly, in order to ensure that, whenever defendant was
+in town, the requisite number of teen sex-providers showed up steadily, and in timely
+fashion, at his door.
+Finally, the record also established that among the list of yet additional
+powerful corroboration were important observations made by the detectives
+themselves inside defendant's houșe during the execution of the search warrant. The
+affidavit recounted that the detectives had found the distinctive pink-and-green
+bedroom sofa, as well as the staircase-wall lined with photographs of naked young
+girls—-some of whom, in fact, the detectives recognized from having interviewed
+them during the investigation. In a desk in defendant's bedroom, the detectives had
+found the high school transcript of
+the teenaged victim who had dubbed herself
+-45-
+
+
+defendant's "number one girl"-having reportedly gone to his home regularly for
+sexual activity over the course of two full years, since the age of sixteen.
+The detectives also recovered carbon copies of telephone messages left for
+defendant saying, "I have girls for him," and, "I have 2 girls for him"; |
+, who
+had been named by virtually all the interviewed girls as defendant's assistant in the
+massage-mill operation, was listed on cach of these particular messages as the person
+who had recorded it. Yet other messages listed names and numbers that the
+detectives recognized from the investigation.
+Put simply, the information in the probable-cause affidavit certainly constituted
+the kind of "reliable" information upon which SORA findings are based. Given the
+detailed, sworn accounts of the victims, and the extraordinary amount of compelling
+evidence corroborating that dovetailing proof, the SORA court had every reason to
+rely on the victim-accounts when determining defendant's risk-level designation.
+Again, the sole purpose of the SORA registration and reporting requirements is the
+protection of the public from unlawful sexual conduct by an offender, and points may
+propetly be assessed against an offender for any factor of which there is "clear and
+convincing evidence." With those governing principles in mind, the SORA court had
+ample basis to conclude that, as a general proposition, the victim-accounts set out in
+the probable cause affidavit provided reliable information about the level of risk that
+defendant posed.
+-46-
+
+
+C.
+Defendant's assertions notwithstanding, the People's remarks at the SORA
+hearing did nothing to diminish the propriety of the level-three risk designation.
+Again, the Boatd itself had recommended precisely that risk level. And, the court saw
+not only the Case Summaty and resulting Risk Assessment Instrument calculations,
+but also the huge array of reliable information that had formed the basis of each
+individual point assessment. While the People expressed reservations about the
+suitability of certain portions of information for SORA purposes, the court correctly
+recognized that the People's arguments in that regard were based largely upon a
+simple misunderstanding of the governing legal standatd, and otherwise on a
+combination of certain unreliable hearsay information and unfounded speculation
+which itself had roots in that same legal misunderstanding. Therefore, for the reasons
+set forth more particularly below, the SORA court acted well within its discretion
+when it chose to reject the arguments put forward by the People, and to adopt the
+well-supported recommendation of the SORA Board instead.
+At the SORA hearing, the prosecutor informed the court, "[Wle don't believe
+that we can rely on the entire probable cause affidavit" (H: 2).
+When the court
+responded, "I don't know why you cannot rely on it," the prosecutor stated her
+reasons—-namely, that, unlike in a "plea bargain" situation, the Florida prosecutor
+here "went forward" only on "one case," there was "an indictment for one victim,"
+and "that is what the defendant pled to" (H2). The prosecutor stated her belief that,
+-47-
+
+
+"under the Board guidelines," the lack of indictment for an offense "is strong
+evidence that the offense did not occur" (H2-3)(emphasis supplied).
+Clearly, the prosecutor had simply misread the Guideline provision about the
+significance of the lack of indictment. As noted, the Guideline language on the
+subject is couched not in the absolute terms that the prosecutor used but rather in
+permissive ones. The rule to which the prosecutor referred provides that the lack of
+indictment fot an offense "may be strong evidence that the offense did not occur."
+Guidelines at 5 (emphasis supplied). The prosecutor, in contrast, characterized the
+text as reading "is strong evidence." Certainly, the actual statutory phrasing "may be
+strong evidence" contemplates that there will, in fact, be circumstances where the lack
+of indictment does not carry any such negative connotation about the occurrence of
+the offense.
+One obvious circumstance where the absence of indictment lacks probative
+value on the question of guilt is that of a plea bargain. The prosecutor believed that
+this case was unlike a situation where a plea bargain had taken place, because
+additional charges had not been indicted here before the plea. However, the
+experienced trial judge in this case knew that in some situations—and particularly
+ones where zealous private counsel are involved—negotiated plea compromises may
+sometimes be reached well before an indictment has been handed down, and
+sometimes may even stave off prosecution entirely.
+-48-
+
+
+In Johnson, as noted, this Court made the point about plea bargains very
+clearly. The Court upheld a SORA assessment on the forcible-compulsion factor
+despite the fact that the defendant had pleaded guilty to a single-count accusatory
+instrument charging him with statutory rape. The force assessment had been made
+on the basis of the victim's hearsay statement, as contained in the felony complaint,
+that force had been used in the commission of the crime. Clearly, in Johnson, this
+Court upheld the point-assessment on the theory that the defendant had likely been
+given the benefit of a plea bargain, and thus the conviction did not accurately
+represent the extent of his conduct in the case. The SORA court here, in turn, knew
+that the same scenario was likely in this case. Indeed, alluding to this commonsense
+idea, the court even asked the prosecutor straightforwardly, "Do you find that if
+somebody is not indicted it is strong evidence that it did not occur?" (H3).
+Apart from her stated concern stemming from the mistake about the statute,
+the prosecutot also expressed a reluctance based upon what she believed had been a
+lack of "cooperation" on the part of the victims. As the below-quoted exchange
+shows, though, when the prosecutor first mentioned that additional reservation, the
+court was still grappling with the prosecutor's first stated concern.
+From the court's perspective, since nothing was suspect about the victimaccounts, and there was so much other information as well—what the court called
+"everything here"— the court pressed the prosecutor on her position. The prosecutot
+went on to elaborate about what she believed to be a lack of "cooperation" on the
+-49-
+
+
+part of the victims, and the court questioned the prosecutor pointedly, establishing
+that the prosecutor simply lacked a reliable basis to conclude that there had been any
+such lack of cooperation. The prosecutor admitted that, since the Florida prosecutor
+who had handled the case had since "left the office," she had merely spoken to the
+Florida prosecutor who "took over the case" (H5).
+The court characterized the
+prosecutor's information as "hearsay," and repeatedly urged the prosecutor to contact
+the Florida prosecutor who had actually handled the case (H5). Remarking that it had
+never seen the prosecutor's office recommend what it termed a "downward
+argument" such as this, the court expressed its belief that the People had "done more
+in other cases looking into it," and had not done "much of an investigation here"
+(H5-6).
+Indeed, after its exchange with the prosecutor, the court correctly concluded
+that there was no reliable information indicating that the victims had failed to
+cooperate with the authorities. Again, the prosecutor had acknowledged that she had
+never even spoken to anyone with first-hand knowledge of the Florida case: she had
+not spoken to the Florida prosecutor who had handled the case, and there is no
+indication that she had spoken to any of the detectives who had dealt with the victims
+so extensively during the Palm Beach Police Department's year-long investigation of
+these events. Instead, as the court pointed out, the prosecutor had relied on mere
+"hearsay" fot the notion that the victims had not cooperated—-unreliable hearsay, the
+court clearly meant, since it emphasized that the sole soutce of the prosecutor's
+-50-
+
+
+information was one Florida prosecutor who had "taken over the case" after it had
+been resolved, and there was no logical reason to conclude that this take-over person
+was in a position to contribute anything whatsoever of value. Simply put, the court
+saw that, in contrast to the vast array of concrete reasons to credit the victimaccounts, the prosecutor's hesitation was based on mere supposition and unfounded
+speculation.
+Lastly, it is worth pointing out that, as the court also well knew from the
+record, even a reluctance on the victims' part to cooperate with authorities would not
+necessarily have cast doubt on the truth of their accounts. Victims of sex crimes, and
+particularly child victims, commonly display an understandable reluctance to relive the
+traumatic ordeal of the crime, and sometimes they choose not to pursue the matter
+with the authorities. Indeed, the desire to protect a child sex-crimes victim from the
+ordeal of a public trial can lead a prosecutor to offer a favorable plea bargain even
+when the defendant's guilt is entirely clear.
+Thus, whether of not these particular
+child sex-crime victims would have cooperated fully in an extended prosecution, their
+detailed, mutually-cortoborative accounts—corroborated yet additionally by an
+extensive array of independent, reliable evidence--were properly considered for
+SORA purposes.
+In short, while defendant has cast this as a situation where the People
+undertook their own independent "investigation" of the victim-accounts and
+determined that the accounts were unreliable, the record resoundingly defeats that
+-51-
+
+
+proposition.
+In reality, the prosecutor thought that the victim-accounts were
+automatically excluded from consideration by a legal rule, but it turns out that the
+legal interpretation was simply mistaken. The prosecutor also seems to have made
+some unwarranted factual leaps based upon information from an unreliable source.
+The SORA court understood that the combination of information provided by the
+Board provided more than the requisite "clear and convincing" reason to believe that
+defendant had preyed on the numerous victims in this case and thus posed a
+significant risk to the community. The court acted correctly, and certainly well within
+its discretion, when it concluded that the People's stated concerns did not cast any
+meaningful doubt on the propriety of the Board's recommendation.
+D.
+Nor is defendant persuasive when he contends that the court hatbored a
+"personal distaste" for him, and allowed these "personal feelings" about him to
+influence the SORA determination (Brief for Defendant at 38-44). First of all, as
+noted, SORA appellate claims, like any others, must be preserved, and this one is not.
+At the hearing, defendant made no complaint whatsoever about a supposed lack of
+objectivity. And, defendant failed to advance a protest on this score because there
+simply was no meaningful complaint to be made on the subject. Indeed, defendant's
+current baseless attack is simply a necessary part of his attempt to forum-shop, to
+enhance his chance of success if he succeeds in obtaining a remand. See infra at 55-
+-52-
+
+
+62. In the end, however, there is no merit whatsoever to defendant's attack on the
+SORA court, and his belated attempts in this regard must fail.
+Significantly, defendant points to nothing that suggests there had been any
+personal contact or dealings between the court and him. In fact, since defendant
+chose not to attend the SORA hearing, the court may not have even met him.
+Rather, to support the current claim of supposed bias against him personally,
+defendant points merely to remarks made by the court during two isolated sections of
+the SORA hearing. Defendant's belated claims notwithstanding, though, there was
+nothing improper in those remarks, or any othets for that matter.
+For example, as noted, in one set of remarks that defendant now challenges
+(Brief for Defendant at 41-42), the court referred to a SORA determination that it had
+made in a different case--one involving a marine—-to underscore its confusion about
+what seemed to be unexplained leniency on the part of the People here (H3-4).
+Since, in the court's view, the evidence of defendant's guilt was straightforward and
+compelling, and the crimes involved were numerous and serious, the court struggled
+with the fact that, in this particular case, the prosecutor was urging rejection of the
+Board's level-three finding. In a case. where a marine had engaged in a consensual
+sexual relationship with a 17-year-old who had approached him in a bat, the court
+pointed out, the People vehemently insisted on a level three finding. The court noted
+the sharp contrast between the People's position in that case and their position here.
+-53-
+
+
+As the above-discussed record shows, any "personal" disdain displayed by the
+court was directed at the prosecutor, not at defendant. The court's decision to
+designate defendant a level-three offender was the product of its reasoned evaluation
+of the severity of the conduct that he had committed, and not any personal animus
+toward him.
+Defendant's other example of supposed personal bias against him is no more
+persuasive. At one point during the hearing, one of defendant's attorneys tried to
+persuade the court that it would be unfair to impose level-three reporting
+requirements on defendant when all of the other states where defendant had homes
+had classified him in a less-severe fashion. Strict reporting requirements would be
+particularly inappropriate, counsel urged, since defendant spent so little time in New
+York in the first place. Defendant's "primary residence is the U.S. Virgin Islands,"
+counsel urged; and, in addition to his home in New York, he maintained "vacation"
+homes in Florida and New Mexico as well (H6-7). For these reasons, counsel
+suggested, defendant "never comes to New York for more than seven days or at least
+he has not since he has been registered," and "has no intention to ever be here for
+longer than a period of ten days" (H7-8). Defense counsel went so far as to protest
+that level-three registration requirements "actually would require him to come to New
+York more than he does normally" (H8). It was in response to that defense argument
+that the court remarked, "I am sorry that he may have to come here every 90 days.
+He can give up his home if he does want to come every 90 days" (H12). Plainly,
+-54-
+
+
+viewed in context, the now-challenged remarks by the court were not improper in any
+way, and they constituted a direct and appropriate response on the merits to an
+argument that had been made by defense counsel.
+In short, defendant's attempts to discredit the objectivity of the SORA court
+have failed. If this Court were to determine that remand is appropriate to clarify
+some aspect of the SORA ruling, see infra at 55-62, the case should be heard by the
+judge who actually issued the ruling.
+E.
+Defendant's remaining complaints can be answered more quickly. As noted,
+defendant complains that the court rendered its ruling without affording the parties an
+opportunity to present evidence on disputed issues, and issued an order that lacked
+the requisite findings and conclusions. He also takes some passing swipes at the basis
+for a few of the individual point assessments.
+All of these complaints are
+unpreserved. More fundamentally, though, defendant's failure to protest along these
+lines yields an answer on the merits, as well, for the bulk of these current claims.
+At the hearing, defendant primarily urged that, when assessing his risk-level, the
+court could properly consider only the criminal conduct that had resulted in the
+formal charges against him. Defendant also made some equitable pitches for leniency:
+he quoted the opinion of an individual Florida assistant state's attorney, cited his more
+modest reporting obligations in other states where he maintained similar "vacation"
+-55-
+
+
+homes,
+and portrayed his presence in New York as a decidedly minimal one.
+Defendant did not, however, take the position that, even if all the information before
+the SORA court were available for assessment, the risk-level calculation made by the
+Board would be unsustainable nonetheless. Likewise, defendant certainly did not
+tackle any of the individual point assessments that the Board had made on the basis of
+the full record before them. Instead, defendant's remarks about the risk level as
+calculated by the Board were limited to stating that he "joined in the prosecutor's
+application" (H8), that the Florida prosecutor had been able to present only one
+"case" to the grand jury (H9), and that "the evidence simply did] not support the
+foundation of the state's determination" (H15).
+In keeping with his overarching legal position with respect to all of the
+conduct that was "uncharged," defendant most assuredly did not seek an opportunity
+to present any additional facts. Indeed, while defendant now protests the so-called
+lack of opportunity to "present evidence," it may be that there simply was no
+additional favorable evidence to be presented on his behalf. Whatever the reason,
+though, the result was plain: as a tactical matter, defendant chose to accept the factual
+universe as presented, and he used what was largely a legal approach to try to exclude
+the majority of that factual universe from consideration. Since the issues had been
+litigated in that manner, the SORA court cannot reasonably have been responsible for
+a lack of additional evidence on "contested" factual issues (Brief for Defendant at 30).
+-56-
+
+
+Again, there were no such contested factual issues, and that is undoubtedly why there
+was no request for an opportunity to introduce any additional proof.
+For much the same reasons, the SORA court's order cannot reasonably be
+viewed as deficient. Defendant now claims that the order lacked the requisite findings
+and legal conclusions (Brief for Defendant at 45-48). At the time the order was
+issued, though, defendant understandably saw no need to make that kind of protest.
+After all, as noted, none of the individual point assessments had been called into
+question. The court had rejected the notion—-advanced by both defendant and the
+People--that the assessment had to be limited to the conduct formally charged. And
+there was no suggestion whatsoever, at any juncture of the hearing, that the totality of
+defendant's conduct, as set forth in the SORA materials, failed to support the point
+assessments as set forth in the Board's Risk Assessment Instrument.
+5 In a related argument advanced in a footnote, defendant complains that he was
+denied his right to written notice of the People's intention to make a recommendation that
+differed from that of the Board; once the People had made their position known at the
+hearing, he further urges, the court should have "adjourned the matter to receive and review
+a written statement of the People's determination and supporting reasons" (Brief for
+Defendant at 39). Of course, had defendant voiced a need for additional time, the court
+certainly could have granted that request—-thereby curing the purported problem about
+which defendant now complains. Defendant certainly should not be permitted to obtain
+relief on a basis that so easily could have been eliminated if he had only protested at the
+time.
+It makes perfect sense, though, that defendant saw no need to cry surprise about the
+position taken by the People--both because his statements at the hearing indicated he was
+aware of that position in advance (H8-9), and more fundamentally because he simply did not
+need to prepate for arguments that were entirely favorable to him. Contrast People v.
+Ferguson, 53 A.D.3d 571 (2d Dept. 2008)(at the hearing, defendant objected to lack of
+notice of amendment to Risk Assessment Instrument).
+-57-
+
+
+Under these particular circumstances, the court's dictated order-
+-recounting
+the Board's assessments one by one and endorsing them—-more than amply explained
+the basis for its determination and thereby permit full appellate review. See People v.
+Smith, 75 A.D.3d 1112, 1112 (4th Dept. 2010) (SORA court's oral findings of fact and
+conclusions of law were sufficient where thay were "clear, supported by the record,
+and sufficiently detailed to permit intelligent appellate review"); People v. Belter, 84
+A.D.3d 905, 906 (2d Dept. 2011) ("While a SORA determination should be supported
+by findings of fact, there is no need for a court to make gratuitous findings of fact
+with respect to issues that are entirely academic"); see generally Correction Law §168-
+n(3).
+Indeed, defendant implicitly acknowledged as much at the hearing. After the
+court announced its determination to "rely on the board," one of defendant's
+attorneys declared that defendant "reserve[d] the right" to appeal; counsel then
+prompted the court, "For the purposes of appeal, I believe that Your Honor - "
+(H12-13). At that point, the court delivered its full decision (H13-14), and afterwards
+defendant did not complain that the form of the decision was deficient in any way.
+Instead, implicitly acknowledging that the order was entirely clear, defendant's other
+attorney took the opportunity to make some additional remarks, essentially attempting
+to re-argue the merits of the court's clear determination (H14-15).
+Moreover, aside from the complete absence of preservation, there is no metit
+to any of defendant's other complaints about the proceedings, including the
+-58-
+
+
+correctness of certain individual point assessments recommended by the Board and
+adopted by the court. For example, in a footnote, defendant refers to an "agreement"
+by "the parties" that defendant had not used forcible compulsion (Brief for
+Defendant at 42), but his record citation for that assertion reveals nothing more than
+the court's assessment of points on the subject of force (H113). In fact, as noted, the
+materials set out in excruciating detail how, with one teenage victim, defendant
+responded to her stated refusal of vaginal penetration by "grabbling]" her, turning her
+over on her stomach, and holding her head down "forcibly" as he inserted his penis
+into her vagina and repeatedly "pump[ed]" his penis into her (A17). That defendant
+later apologized, and gave her $1,000 in cash (A17) did not erase his use of forcible
+compulsion, and did not make that conduct other than a forcible rape-—which, of
+course, was a crime no matter what her age, and no matter what her geographical
+location within the United States at the time. The Board recognized that obvious fact
+when it labeled the conduct as such on the first page of its Case Summary.®
+• At one point, when trying to minimize the nature of the conduct at issue, defense
+counsel urged that "[a]ll of the alleged conduct" that was "cited in the board's write up" was
+"commercial conduct" (H9). 'As counsel explained, "All of the alleged conduct the women
+went voluntarily, there are no allegations of force certainly none" (H9). Plainly, that
+particulat reference to the absence of force did not preserve his current claim on the subject.
+After all, these references to the girls having made the trip to defendant's home voluntarily,
+in return for payment, cannot reasonably have alerted the SORA court to his current
+suggestion that the point assessment for forcible compulsion was unwarranted because none
+of the particular sex acts alleged to have been committed by defendant once in that house
+had been inflicted on a victim in a forcible manner. Certainly, these hearing remarks about
+the mere "commercial" and "voluntary" nature of the overall arrangement were not directed
+(Continued...)
+-59-
+
+
+In a different footnote, defendant complains that the Board assessed five
+points against him in the category of Criminal History despite its notation in the Case
+Summary that it had done so "absent specific information" (Brief for Defendant at 8).
+In fact, on the same page of the Case Summary, the Board also states that defendant
+had been convicted of Unlawful Possession of an Offensive Weapon, a misdemeanot,
+in England, stemming from his possession of a cane that contained a concealed blade
+(A65). Read in the context that the Risk Assessment Instrument itself provides, the
+notation "absent specific information" plainly was meant to explain why the Board
+had chosen to award the lowest point assessment permissible for that criminal
+conduct, rather than one of the higher ones mandated in the presence of certain listed
+aggravating factors. In other words, "absent specific information" about defendant's
+weapons-possession conviction, the Board gave him the benefit of the doubt and did
+not award yet additional points.
+As to the age-of-victim factor, in turn, defendant's belated suggestions
+notwithstanding (Brief for Defendant at 36-38), the SORA court was well aware that
+defendant sometimes received "massages" from girls who were 18 years or older. The
+probable cause affidavit explicitly stated that certain people initially viewed as
+"victims" turned out to be 18 years of age or older and therefore were "consenting
+(...Continued)
+specifically at the point assessment that had been made in the category of "forcible
+compulsion."
+-60-
+
+
+adults" under the law (A25-26).
+The affidavit further clarified, though, that these
+"adults" had recounted the "same massage routine" as had the underage girls (A25),
+and therefore the court, like the detectives who had conducted the investigation,
+recognized that the "adult" accounts provided valuable corroboration of the accounts
+given by the underage victims. Of course, more to the point for risk-assessment
+purposes, the court also knew from the record that the occasional adult "masseuse"
+did nothing to minimize the compelling evidence of demonstrated preference for
+young high school girls-"the younger the better," as defendant himself instructed
+one of his high school recruiter-pimps.
+One final note on the subject of point assessments. As defendant concedes
+(Brief for Defendant at 10), he was given credit for having accepted responsibility for
+his actions by pleading guilty. If the Board had taken the view that defendant now
+espouses-
+-that his guilty plea reflected nothing more than his conduct with one 17-
+year-old victim—-the point-assessment total would be even higher than the one
+defendant has now.
+Plainly, then, defendant has provided no legitimate reason for this Court to
+doubt the propriety of the determination made by the SORA court. Therefore,
+defendant's request fot a recalculation of his risk level must be denied. Nevertheless,
+it bears mention that this Court would not be proper venue for any such recalculation
+in any event. As noted, defendant seeks recalculation on the basis of a myriad of
+arguments that are being made for the first time on appeal. The SORA court, thus,
+-61-
+
+
+was not given an opportunity to consider these arguments when fashioning its
+determination. The People, too, were not given an opportunity to present additional
+evidence on these newly-minted theories, if they so chose. If this Court were inclined
+to grant defendant's request for recalculation, the Court should remand the case for
+that purpose to the SORA court, where the People will have an opportunity to
+introduce additional evidence as well.'
+*
+*
+*
+7 If this Court chooses to remand the case for additional proceedings—-either for the
+"re-calculation" of points that defendant seeks, of the opportunity that he seeks for "the
+parties to present evidence"—the People will have an opportunity to correct any
+misimpressions left by defendant, and to provide instead a complete and accurate picture of
+the circumstances that gave rise to the two single-count accusatory instruments dated fully
+two years apart.
+The People's evidence on remand would include proof that defendant had engaged in
+aggressive negotiations with the Palm Beach State's Attorney's Office even before
+indictment; that, after the State's Attorney's Office obtained a single-count indictment,
+Florida federal authorities convened their own grand jury investigation; and that defendant
+entered into a federal non-prosecution agreement with the United States Attorney of the
+Southern District of Florida, under which he agreed to plead guilty to an additional state
+felony charge that carried a consecutive jail sentence and required tegistration as a sex
+offender.
+While a defendant hardly could have a legitimate objection to an accurate portrayal of
+the facts and circumstances relevant to the SORA determination that he has challenged,
+defendant here would be particularly hard-pressed to complain on that score since his
+unpreserved entreaties for recalculation, as well as remand, call upon this Court to reach out
+in the interest of justice.
+-62-
+
+
+In sum, the decision of the SORA coutt is absolutely correct. There is no
+legitimate basis for complaint about either the form or content of that determination.
+CONCLUSION
+The judgment of conviction should be affirmed.
+Respectfully submitted,
+District Attorney
+New York County
+Assistant District Attorneys
+Of Counsel
+August 2011
+-63-
+
+
+-64-
+
+
+PRINTING SPECIFICATIONS STATEMENT
+The word count for this brief is 16,045, excluding the Table of Contents and
+Table of Authorities. The word processing system used to prepare this brief and to
+calculate the word count was Microsoft Word 2007. The brief is printed in
+Garamond, a serifed, proportionally-spaced typeface. The type size is 14 points in the
+text and headings, and 13 points in the footnotes.
+
+
diff --git a/vision-fixhub/ds9-unparsed-05/e084e03325bbefba39aa1eae9101153ff264a52bd6e337a6008824b770463374.receipt.json b/vision-fixhub/ds9-unparsed-05/e084e03325bbefba39aa1eae9101153ff264a52bd6e337a6008824b770463374.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..22b14fde1ea2389d1a66b076dbe5e533f1395854
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e084e03325bbefba39aa1eae9101153ff264a52bd6e337a6008824b770463374.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -868,
+  "dataset": "marble-joined",
+  "doc_id": "e084e03325bbefba39aa1eae9101153ff264a52bd6e337a6008824b770463374",
+  "engine": "marble-apple-vision",
+  "event_count": 79,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "909bed5aa207e3258ce32618cc42c04076b646240759d36afcd6441a204a57d1",
+  "output_sha256": "59b6f5a29db442adb286292725caf78e9de0605121f02c7f2ca5d916af0d0126",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e0a7a1c1d83c090db4ba7967d5c5bd945d70c4ea13d82e8e5b5f9e0cfbd30193.md b/vision-fixhub/ds9-unparsed-05/e0a7a1c1d83c090db4ba7967d5c5bd945d70c4ea13d82e8e5b5f9e0cfbd30193.md
new file mode 100644
index 0000000000000000000000000000000000000000..d7af626a7e2eca9769ff45f889550eff383a73c5
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e0a7a1c1d83c090db4ba7967d5c5bd945d70c4ea13d82e8e5b5f9e0cfbd30193.md
@@ -0,0 +1,2264 @@
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+DOB
+B
+Jane Doe #1
+15
+AGE AT FIRST
+CONTACT
+HIGH SCHOOL
+BROUGHT BY
+Ghislaine Maxwell
+DATES OF
+Approx: 1999
+CONTACT/SOURCE Testimony
+GIRLS RECRUITED
+NUMBER OF
+MASSAGES
+ENTICEMENT
+Title 18 USC 2422(b)
+Interstate Commerce
+Connection
+Under 18 at time of
+sexual activity
+Advised if asked to
+state they were over
+18/Advised by
+whom?
+YES - 17
+Knowledge or
+Discussion of Age
+with JE?
+12
+13
+14
+Payment for
+services?/Amount
+Payment for
+recruitment
+Jane Doe #2
+14
+2001 - 7/2004
+Testimony/Message
+Pad
+D
+Jane Doe #3
+15
+Palm Beach Central HS
+Kpossibly
+04/23/2004 - 10/01/2005
+Telephone
+Multiple
+"'maybe 30
+girls"
+Unknown, multiple times
+YES - 14
+was
+advised to say she.
+was 17 byl
+Telephone Records
+YES - 15
+YES/
+Epstein askedi
+JE asked her age.
+• her age and she
+stated that she
+uttered "four" and then insisted that she was 18.
+said 17. Epstein
+responded by saying,
+"so you are fourteen."
+JE also told l
+they would not tell
+anyone.
+YES/$200.00-500.00
+YES/$200.00
+$100.00 per girl
+
+
+1
+15
+16
+17
+18
+19
+20
+21
+B
+D
+DOB
+Payments made by
+Taken upstairs by
+Clothing worn during
+massage
+Sexual activity
+Jane Doe #1
+Jane Doe #2
+Epstein
+Jane Doe #3
+Epstein/
+possibly
+Topless, one time Nude.
+•
+Bra and underwear,
+topless and nude.
+Sexual intercourse at
+•observed JE
+age 17 (observed by
+engage in sexual
+intercourse with
+1. a 17 year
+old female. JE
+introduced an
+unidentified female
+who performed oral
+sex on while JE
+had sexual intercourse
+with the unidentified
+female. JE touched
+vagina (no
+penetration).
+7 would rub his ches
+• stated that JE neve
+touched her.
+Masturbation
+Ejaculation
+Sexual activity with
+
+
+1
+22
+23
+24
+25
+26
+27
+28
+DOB
+Statements made by
+Epstein
+Asked to bring
+others/By whom?
+Gifts
+Physical Evidence
+(i.e. Message Pads,
+Trash Pulls, Search
+Warrant, Payment
+Documentation, etc.)
+TRAVEL
+Title 18 USC 2423(b)
+Dates of
+Travel/Aircraft
+B
+D
+Jane Doe #1
+Jane Doe #2
+Jane Doe #3
+comfortable? Why are
+you going to keep your
+panties on? So you
+are 14.
+Yes/Epstein
+Yes/Epstein (JE upset
+when I
+brought a black
+girl, JE - no heavy girls)
+YES - Apartment rent YES - Victoria's Secret Bikini from Brazill
+paid by Epstein.
+bras and underwear,
+massage oils, book
+titled "Massage for
+Dummies." Concert
+tickets to see the band
+Incubus at the Sound
+Advice Amphitheater.
+MP / Massage for
+Dummies Book
+Telephone Records //
+Petty Cash Report
+Baby gifts
+
+
+1
+29
+30
+DOB
+Who Scheduled
+Appointments?
+Miscellaneous
+B
+Jane Doe #1
+Jane Doe #2
+D
+Jane Doe #3
+SK
+SK
+• told the PBPD that
+photographs taken by she is in love with JE and
+Tat JE's
+request. was paid about him positively or
+friends at
+house
+31
+Interviewed by PBPD No
+32
+33 Interviewed by FBI
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+=
+12
+13
+14
+E
+F
+G
+DOB
+AGE AT FIRST
+CONTACT
+HIGH SCHOOL
+Jane Doe #4
+Jane Doe #5
+15
+17
+9th Grade - Lake Worth HS Royal Palm Beach HS
+and John I. Leonard HS
+Jane Doe #6
+16
+Royal Palm Beach HS
+BROUGHT BY
+DATES OF
+2003-10/02/2005
+CONTACT/ SOURCE Testimony/ Telephone
+03/12/2004 - 07/24/2005
+| Telephone
+4/25/2004 - 10/06/2005
+Telephone
+GIRLS RECRUITED
+| and unidentified
+females ages 15 - 25.
+NUMBER OF
+Approx. 10-15
+MASSAGES
+ENTICEMENT
+Title 18 USC 2422(b)
+Interstate Commerce Telephone Records
+Connection
+Under 18 at time of
+YES - 15
+sexual activity
+Advised if asked to
+state they were over
+18/Advised by
+whom?
+Knowledge or
+Discussion of Age
+with JE?
+told JE she
+was 18.
+Payment for
+services?/Amount
+YES/$200.00
+Payment for
+recruitment
+Epstein offered I
+$300.00 to bring]
+1
+Land
+(20-21yoa) Paid $200.00
+each by
+Less than 10 times but
+more than five.
+Telephone Records
+Telephone Records
+YES - 17
+YES - 16
+YES -
+YES -
+advised FP
+that she would make
+$200.00, to dress cute, JE
+might touch her, and to
+tell JE if she was
+uncomfortable and JE
+would stop.
+told JE she was 18 but FP told JE she was a
+she said that she thought Junior at Royal Palm
+he knew better.
+Beach High School. •
+told JE that she and
+were good friends and
+went to same school and
+in same class. and JE
+discussed
+•ble of girls
+frdshp. (said was
+worried b/c she had
+mentioned prom to JE.)
+YES/$200.00
+YES/$200.00
+
+
+1
+15
+16
+17
+18
+19
+20
+21
+DOB
+E
+F
+G
+Jane Doe #4
+Jane Doe #5
+Payments made by
+Taken upstairs by
+Epstein
+Epstein
+Jane Doe #6
+Epstein and
+Clothing worn during Topless and Nude.
+massage
+Sexual activity
+Nude
+Bra and Underwear, and
+topless.
+JE requested
+Performed massages in JE pulled bra down
+to rub his chest and nipples. the nude. would not
+JE used a back massager allow him to touch her. JE He grabbed her butt.
+onl
+vagina. JE grabbed 5 butt and
+touched
+•vagina asked her to rub his
+and clitoris. JE instructed nipples
+Ito straddle an
+unidentified female (UF)
+and fondled the breasts of
+the UF as he used a
+massaged him. During
+topless massages, JE
+fondled
+bare breasts.
+JE touched
+vagina
+over her panties.
+nassaging device on th
+JF's vagina
+Masturbation
+Ejaculation
+Sexual activity with
+YES, made moaning
+noises while touching
+himself.
+She believed he
+ejaculated.
+
+
+1
+22
+23
+24
+25
+26
+27
+28
+DOB
+Statements made by
+Epstein
+E
+Jane Doe #4
+Asked to bring
+others/By whom?
+Gifts
+Yes/Epstein stated JE YES/ Epstein
+said no black girls or girls
+with tattoos.)
+YES - $600.00-700.00 to
+apply toward the purchase
+of a vehicle. Book -
+Massage for Dummies.
+F
+G
+Jane Doe #5
+Jane Doe #6
+I'll pay you $200.00 for
+Asked her to take her
+every girl you bring to me. clothes off. Told her she
+Make sure they know
+could make more money
+what is expected. The
+if she would do more
+younger the better.
+Told her she could make
+more money if she
+brought her pretty friends
+You should know what to
+expect when you come
+here. Do you have sex
+with your boyfriend?
+When told JE she was
+a virgin, JE asked "You
+don't like sex?" Come
+closer. Rub my chest.
+Take your clothes off.
+YES/L
+Jand Epstein
+Physical Evidence
+i.e. Message Pads
+Trash Pulls, Searct
+Warrant, Payment
+Documentation, etc.)
+Telephone Records
+- 9
+Confession
+TRAVEL
+Title 18 USC 2423(b)
+Dates of
+Travel/Aircraft
+03/31/2005 -
+
+
+1
+29
+30
+DOB
+Who Scheduled
+Appointments?
+Miscellaneous
+E
+F
+G
+Jane Doe #4
+and
+(phonetic)
+Jane Doe #5
+Jane Doe #6
+recently spoke
+with
+(Fall 2007).
+_talked of her twin
+boys and mentioned she
+was living in Manhattan.
+described
+as a storyteller
+and a bad liar.
+told that JE
+oesn't do that (referrin
+o sex) he plays arounc
+with them.
+liked
+Land SG the
+most.
+•believed told her
+about the vibrator
+provided to prior to
+Spring 2005. knew of
+JE's offer to take and
+to New York or hi
+sland. knew of gift
+JE provided to • ie. •
+lingerie, birthday flowers,
+vibrator and rental car.
+31
+Interviewed by PBPD No
+32
+33 Interviewed by FBI
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+DOB
+AGE AT FIRST
+CONTACT
+HIGH SCHOOL
+BROUGHT BY
+DATES OF
+CONTACT/ SOURCE
+H
+Jane Doe #7
+16
+WT Dwyer HS
+07/04/2004 - 07/16/2004
+• Telephone
+GIRLS RECRUITED
+N/A
+Jane Doe #8
+17
+Royal Palm Beach HS
+J
+Jane Doe #9
+17
+Lake Worth HS
+07/15/2004 - 09/01/2005
+07/22/2004 - 11/02/2005
+Telephone
+Telephone
+N/A
+(18)
+multiple times ( stated Approx. 15
+hundreds of times
+NUMBER OF
+3 - 4 times
+MASSAGES
+ENTICEMENT
+Title 18 USC 2422(b)
+Interstate Commerce Telephone Records
+Connection
+Under 18 at time of
+Yes - 16
+sexual activity
+Advised if asked to
+state they were over
+18/Advised by
+whom?
+Knowledge or
+Discussion of Age
+with JE?
+Telephone Records
+YES - 17 stated 16
+and 16/17)
+Telephone Records
+Payment for
+services? Amount
+Payment for
+recruitment
+YES/$200.00
+Yes/$200.00
+YES/$200.00 - 1st time, YES/$200.00
+$300.00 - $600.00 and
+$1000.00 paid after penile
+penetration.
+YES - AD stated AH
+recvd $200.00
+
+
+1
+15
+16
+17
+18
+19
+20
+21
+DOB
+H
+Jane Doe #7
+Payments made by
+Taken upstairs by
+Epstein
+Epstein and
+Clothing worn during Underwear and Nude
+massage
+Sexual activity
+Jane Doe #8
+Epstein
+Underwear - first
+massage/ Nude
+JE instructed to rub
+is chest and nipples. JE I JE would rub h
+uched breast and penis on her breast. .
+J
+Jane Doe #9
+1st time - Shorts and Bra,
+3rd visit - Nude
+JE touched
+breast
+as he masturbated.
+Masturbation
+Ejaculation
+Sexual activity with
+Yes, JE appeared to
+climax and then the
+massage would end
+performed oral sex on times JE placed a larg
+n one occasion, JE vibrating back massage
+vaginal penetrated
+witnessed the
+while he masturbated. On
+penetration. JE
+at least two occasions,
+requested
+to perform
+JE's girlfriend/assistant
+oral sex on
+when she
+accompanied
+refused he offered her an
+with providing massages.
+extra $200.00 for five
+got naked and
+minutes. All but once, but performed sexual acts
+less than five times, JE
+with JE, including the use
+requested
+land
+of the massager and oral
+engage in sexual activity.
+sex.
+touched
+i.e. kissing, touching, and
+vagina.
+pulled
+oral sex, in front of him
+hand away. On more
+and with him. Additional
+than one occasion,
+sex toys were introduced
+placed the massager
+and used on
+by JE
+directly on
+vagina.
+and
+during the i
+massages.
+Yes, kissing, touching and Yes,
+touched
+oral sex. I
+vaginally
+vagina,
+pulled
+penetrated with
+hand away. On more
+vibrator/sex toys.
+than one occasion,
+placed the massager
+directly on
+i vagina.
+
+
+22
+23
+24
+25
+26
+27
+28
+DOB
+H
+1
+J
+Jane Doe #7
+Statements made by JE told to get
+Epstein
+Jane Doe #8
+Jane Doe #9
+On more than one
+JE asked lo touch his
+occasion, JE asked 1
+Ito penis, she declined. JE
+anyone what happened at perform oral sex on him. attending college in the
+he house or bad things
+could happen. On the
+advice on [
+Is bad credit,
+dealing with her parents
+to remove her bra and
+and school.
+panties and JE told her
+that she was here for that
+reason.
+Asked to bring
+others/By whom?
+Gifts
+Physical Evidence
+(i.e. Message Pads,
+Trash Pulls, Search
+Warrant, Payment
+Documentation, etc.)
+Testimony/Telephone
+Records
+Message pads
+07/16/2004-
+YES - Multiple Victoria's YES - Brazilian bathing
+Secret underwear sets.
+suit, Western Union -
+Bathing suit and Louis
+Cancun $350.00 Rec.
+Vuitton purse. Movie
+06/02/2005 Western
+tickets/show tickets i.e.
+Union - San Diego
+_(FL)
+$200.00
+Rec
+and Phantom of the
+07/13/2005
+Opera (NY). Plane ticket
+Tickets
+to NY. $2000.00
+Christmas bonus. 2005
+Dodge Neon. L
+believed JE would pay for
+her to attend NYU.
+- 10
+.. H.S. Transcri
+- 09/21/2005
+Photo Lineupnoto Line Cash Receipt
+Petty Cash Receipt
+Brazilian bathing suit,
+Palm Beach PD report-
+Western Union - Cancun
+taken whenwent to
+$350.00 Recd
+pick up Christmas bonus. 06/02/2005
+Western
+2005 Dodge Neon rental
+Union - San Diego
+car.
+$200.00 Recvd
+07/13/2005
+07/16/2004 -
+07/16/2004-
+TRAVEL
+Title 18 USC 2423(b)
+Dates of
+Travel/Aircraft
+
+
+1
+29
+30
+DOB
+Who Scheduled
+Appointments?
+Miscellaneous
+H
+J
+Jane Doe #7
+Jane Doe #8
+Jane Doe #9
+JE instructed his house
+I wrote her cellular
+nanager to driv
+Land
+telephone number for JE
+home after
+first
+on a notepad described
+massage. called
+as having JE's name o
+after first massage and
+he bottom of the pac
+told her that she wanted
+to contact the police. L
+discouraged from
+reporting. took Xanax
+prior to each visit.
+31
+Interviewed by PBPD Yes
+32
+33
+Interviewed by FBI
+No/Contact made
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+K
+AGE AT FIRST
+CONTACT
+HIGH SCHOOL
+Jane Doe #10
+Jane Doe #11
+17
+17
+Palm Beach Central HS
+[John I. Leonard HS
+BROUGHT BY
+DATES OF
+CONTACT/ SOURCE
+Unknown
+08/19/2004 - 02/14/2005
+Telephone
+GIRLS RECRUITED
+NUMBER OF
+MASSAGES
+ENTICEMENT
+Title 18 USC 2422(b)
+Interstate Commerce
+Telephone Records
+Connection
+Under 18 at time of
+sexual activity
+YES - 16 or 17
+Junior Year of H.S.
+Advised if asked to
+state they were over
+18/Advised by
+whom?
+4
+Approx 10 times
+Second visit she brought
+DN
+Telephone Records
+YES - 17
+Knowledge or
+Discussion of Age
+with JE?
+M
+Jane Doe #12
+16
+Royal Palm Beach HS
+08/21/2004 - 08/18/2005 09/2004 - Testimony -
+•Telephone
+Start date only.
+1 massage
+2 more residence visits
+Telephone Records
+YES - 17
+told JE she was in
+told JE multiple times None
+High School. JE asked
+that she was 17. JE
+her how old she was and stated to her he couldn't
+she told him her actual
+wait for her to turn 18 so
+age at the time which was she could be his personal
+16 or 17. JE told when masseuse. He also
+she turned 18 he would
+couldn't wait for her to
+ler a place to stay wher
+she was 18 and that he
+would take her
+everywhere.
+YES/$200.00
+YES/$200.00
+12
+13
+Payment for
+services?/Amount
+Payment for
+14 recruitment
+YESI$200.00
+YES/$200.00 for DN
+YES/$200.00 per girl
+YES/$100.00
+
+
+1
+15
+16
+18
+19
+20
+21
+DOB
+K
+L
+M
+Jane Doe #10
+Jane Doe #11
+Jane Doe #12
+Payments made by
+Taken upstairs by
+Epstein
+Epstein
+Epstein
+Clothing worn during Bra and Underwear, and Nude
+massage
+Sexual activity
+Cropped tank top that
+JE rolled over on his side
+JE masturbated each time JE rubbed]
+legs and
+and masturbated while
+massaged him. JE
+buttocks and reached for
+provided the
+used a massager/vibrator her breasts under her
+massage. He ejaculated
+on
+vagina. JE
+shirt. She told him she
+in his hand. Later
+touched
+breasts and was not comfortable with
+massages JE placed back buttocks. On one
+that. JE also attempted to
+massager on vagina occasion, JE penetrated
+reach into pants but
+over her underwear. JE
+• (age 17) with his
+her belt was too tight. JE
+digitally penetrated RS.
+finger.
+rubbed his nipples and
+started to masturbate unti
+he ejaculated.
+Masturbation
+Ejaculation
+Sexual activity with
+
+
+1
+22
+23
+24
+25
+26
+27
+28
+DOB
+K
+L
+Jane Doe #10
+Statements made by
+According to
+JE
+Epstein
+refers to the girls that
+massage him as
+"clientele".
+• JE told
+that he had a girl he paid
+$600.00 to for anal sex.
+Epstein referred to
+and heavy. He told he talk dirty to him. JE
+wanted cute girls like her. asked l
+When other girls at JE's
+residence asked for wine, that he'd give her more
+JE replied "I don't drink or money (she declined). JE
+do drugs." JE asked
+told
+he could not wait
+"do you have any friends for her to turn 18 so she
+that would do this?"
+could be his personal
+masseuse.
+YES/ Epstein and |
+M
+Jane Doe #11
+Jane Doe #12
+JE asked and
+to
+Get a little bit more
+take their shirts and bras comfortable. Take of your
+off (they did) and RS
+shirt and pull down your
+would show DN what to
+pants. Let me touch you
+do. JE told to leave
+like | like to be touched.
+Asked to bring
+others/By whom?
+Gifts
+None
+None
+Physical Evidence
+(i.e. Message Pads,
+Trash Pulls, Search
+Warrant, Payment
+Documentation, etc.)
+MP
+Testimony
+Massage oils
+Testimony
+TRAVEL
+Title 18 USC 2423(b)
+Dates of
+Travel/Aircraft
+
+
+K
+L
+1
+29
+30
+DOB
+Who Scheduled
+Appointments?
+Miscellaneous
+M
+Jane Doe #10
+Jane Doe #11
+-
+Jane Doe #12
+•via
+31
+Interviewed by PBPD Yes
+32
+33 Interviewed by FBI
+First visit,
+met with
+During
+first visit,
+at trailer park and
+and
+observed JE's penis
+initially massaged and described it as
+traveled to JE's by cab
+JE together while they
+circumcised.
+with
+Land
+were both topless.
+Unknown female. told gave JE her school
+her to get into her bra and picture and she wrote on
+underwear.
+called the the back of the picture
+cab for |
+the first time
+she couldn't wait until she
+went to JE's.
+identified JE in a photo
+spread. was aware
+(note:
+that
+and
+Thad
+reports).
+visited JE's residence.
+circumstance to the
+Following the massage
+PBPD because she read
+_ provided to JE, the
+that JE had passed a
+chet at the residence told |
+her she looked scared.
+od noa phonica remales
+(Based on
+vere minors. She knev
+description ofand
+that that was untrue as h
+message pad notes, it is
+was well aware of her
+believed
+IS
+being 17
+believed JE
+knew
+juvenile,
+was 17. As a
+was arrested
+for marijuana possession
+and shoplifting.
+last
+contact with
+was
+approx. 05/2005.
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+N
+AGE AT FIRST
+CONTACT
+HIGH SCHOOL
+Jane Doe #13
+17
+Royal Palm Beach HS
+Jane Doe #14
+16
+Royal Palm Beach HS
+BROUGHT BY
+DATES OF
+11/12/2004 - 03/29/2005
+12/06/04 - 10/27/2005
+CONTACT/ SOURCE
+Telephone
+Telephone. Spring 04/L
+telephone contact.
+GIRLS RECRUITED
+N/A
+1(18)
+NUMBER OF
+More than 10
+MASSAGES
+ENTICEMENT
+Title 18 USC 2422(b)
+Interstate Commerce Telephone Records
+Connection
+Under 18 at time of
+YES - 17
+sexual activity
+Advised if asked to
+YES -I
+Advised YES
+state they were over
+she would make $200.00,
+18/Advised by
+wear something sexy and
+whom?
+18 yoa if asked
+Unknown/Multiple
+Telephone records
+YES - 16/17
+Knowledge or
+Discussion of Age
+with JE?
+Payment for
+services?/Amount
+During first massage JE
+Never told JE her age.
+asked how old she
+Discussed Soccer and would
+was, said 18. A
+be attending Lynn Univ. L
+couple massages later,
+stated that JE didn't care,
+JE and were
+discus for her birthday. she had meaned pre bo
+discussing if • had any
+said So you're going to be JE.) - and good
+eighteen? said yes
+riends and they went to sam
+chool and in same class
+continued on with
+and JE discussed •b/c of
+massage.
+girls frashp. told JE she
+was a Jr.)
+YES/$300.00
+YES/$200.00
+13
+Payment for
+14
+recruitment
+P
+Jane Doe #15
+16
+Royal Palm Beach HS
+12/2004/Testimony
+N/A
+1
+Telephone Records
+between
+1&
+YES - 16
+YES - 1
+never told JE her age.
+stated that JE knew
+she was in High School
+YES/$200.00 (Epstein
+gave • $100.00 to give
+to for bringing her.)
+YES/$100.00 to
+
+
+1
+15
+16
+18
+19
+20
+21
+DOB
+N
+P
+Jane Doe #13
+Jane Doe #14
+Jane Doe #15
+Payments made by
+Taken upstairs by
+Epstein
+Epstein
+and Jeffrey
+Epstein
+Clothing worn during Bra and Underwear
+Underwear/Nude
+massage
+also nude
+Sexual activity
+Epstein
+White female, long blonde
+hair identified
+&
+Underwear (pulled to the
+side by JE)
+JE grabbed
+buttocks. On more than one occasion. JE instructed her to rub
+JE asked to rub and
+JE digitally penetrated
+JE his chest and pinch his
+pinch his nipples.
+used Back Massager/Vibrator nipples. JE rubbed
+massaged JE's chest and on vagina. • straddled JE
+breasts. JE masturbated
+JE masturbated under a
+and he would attempt to rub
+in front of completely
+towel. JE used a vibrator
+penis on vagina, no
+exposing his penis. JE
+onand digitally
+penetration. JE fondled
+moved thong panties
+penetrated
+i vagina.
+breasts. JE asked to have his to one side and stroked
+JE performed oral sex on
+nipples pinched
+ner vagina. IE digitally
+• JE and had
+penetrated
+vagina.
+intercourse on JE's bed.
+JE masturbated until he
+ejaculated onto a towel.
+Masturbation
+Ejaculation
+Sexual activity with
+Uncertain, but guessing
+by his breathing, she
+believed he did.
+
+
+1
+DOB
+N
+Jane Doe #13
+Statements made by
+Why don't you take that
+Epstein
+stated He would
+try to talk you into it. He
+did not force her.
+22
+23
+Asked to bring
+others/By whom?
+Gifts
+N/A
+YES - Western Union -
+12/23/2004
+$200.00 Christmas
+present. JE gave a
+book on poetry and
+lingerie bra and panty
+sets.
+24
+Physical Evidence
+1-3
+(i.e. Message Pads,
+Western Union -
+Trash Pulls, Search
+12/23/2004
+Warrant, Payment
+$200.00 Christmas
+Documentation, etc.) present. Book of Poetry
+and a set of lingerie.
+25
+26
+27
+28
+TRAVEL
+Title 18 USC 2423(b)
+Dates of
+Travel/Aircraft
+03/31/2005 -
+Jane Doe #14
+YES - VS Bra & Panty sets,
+Vibrator, and Rental Car
+09/21/2005, -
+10/04/2005, -10/07/2005.
+- 1
+03/31/2005 - 1
+P
+Jane Doe #15
+JE instructed to go
+down to her bra and
+underwear. JE toldas
+he unfastened her bra,
+"We're gonna take this
+off'. As JE stroked
+vagina he told her to relax
+to go inside her.
+stated the JE told her tha
+sexually active and what
+Testimony
+
+
+N
+1
+29
+30
+DOB
+Who Scheduled
+Appointments?
+Miscellaneous
+P
+Jane Doe #13
+Jane Doe #14
+Jane Doe #15
+Third time,
+started
+JE offered to fly and to
+•stated that during
+massaging JE in her bra
+his island around and for their the massage she was
+and underwear. JE asked June birthdays. knew
+thinking to herself "How
+"Why do you keep
+about JE providing with
+am I going to get out of
+looking at the clock?"
+lingerie for birthday.
+here" and "please hurry
+eplied, "Because m
+vibrator and rental car.
+up".
+stated that she
+boyfriend is going to com
+told that JE fingered
+pick me up." JE said,
+her after message was
+"Well your supposed to be
+over.
+asked by JE to
+making me enjoy my
+leave her phone number.
+massage right now,
+please do not keep
+looking at the clock." JE
+stated, "If you don't want
+to do this then you don't
+have to do it."
+31
+32
+33
+Interviewed by PBPD Yes
+Interviewed by FBI
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+=
+12
+13
+14
+DOB
+Q
+AGE AT FIRST
+CONTACT
+HIGH SCHOOL
+Jane Doe #16
+14
+Royal Palm Beach HS
+BROUGHT BY
+DATES OF
+02/06/2005 - 04/2005
+CONTACT/ SOURCE Telephone
+GIRLS RECRUITED
+N/A
+NUMBER OF
+1
+MASSAGES
+ENTICEMENT
+Title 18 USC 2422(b)
+Interstate Commerce Telephone records
+Connection
+between
+Under 18 at time of
+YES - 14
+sexual activity
+Advised if asked to
+state they were over
+18/Advised by
+YES - Haley R. advised
+to say 18 and Sr. @
+Wellington HS.
+whom?
+Knowledge or
+Discussion of Age
+with JE?
+• told she was 18
+and a Senior at
+Wellington High School.
+Payment for
+services?/Amount
+Payment for
+recruitment
+YES/$300.00
+R
+Jane Doe #17
+17
+Royal Palm Beach HS
+S
+Jane Doe #18
+16
+Royal Palm Beach HS
+02/25/2005 - 10/03/2005
+Telephone
+Approx. 15
+02/2005 vial
+Telephone/Testimony -
+Start date only.
+|(20) N/A
+2 times
+Telephone Records
+YES - 17
+Telephone Records
+between
+YES - 16 and possible
+turned 17 by the second
+visit
+•I told JE she was 17
+age and she stated he
+was well aware of her
+age.
+stated that JE asked
+them questions like "What
+do you do?" or "Where do
+you go to School?" I
+stated she believed she
+told him she went to
+RPBHS.
+YES/$200.00 for
+massages, $350.00 for
+intercourse.
+YES/$200.00 each time
+
+
+1
+15
+16
+17
+18
+19
+20
+21
+Q
+DOB
+Jane Doe #16
+Payments made by
+Taken upstairs by
+Epstein
+Unknown female
+assistant - SK or NM
+Clothing worn during Nude
+massage
+Sexual activity
+JE used vibrator on
+vagina. JE digitally
+penetrated
+Masturbation
+Ejaculation
+Sexual activity with
+R
+S
+Jane Doe #17
+Jane Doe #18
+Epstein
+1st time -
+time-??
+2nd
+Underwear only and
+1st time - Underwear
+approx. two times nude. Only. 2nd time - Nude
+'JE masturbated each time JE touched
+breasts.
+provided a massage. JE rubbed
+vagina
+JE began touching on with a massager/vibrator.
+her buttocks and grabbed
+her closer to him as he
+nasturbated. JE also
+grabbed breasts an
+fondled her breast with his
+hands as she massaged
+him. JE frequently placed
+a large massager/vibrator
+on
+} vagina. JE
+introduced during a
+massage session with
+land JE had
+sexual intercourse while
+watched. touched
+JE while
+and her
+kissed.
+and also
+touched each others
+breasts and buttocks. JE
+wad sexual intercourse
+with
+on one occasion
+prior to
+18th
+birthday.
+YES, made moaning
+noises while touching
+himself.
+JE wiped penis with towel, YES
+SG believed he
+ejaculated.
+Yes, kissed • •
+touched
+breast.
+
+
+1
+DOB
+Q
+Jane Doe #16
+Statements made by Asked to use vibrator on
+Epstein
+her. I gave you an extra
+$100 because I fingered
+you and used a vibrator
+on you.
+22
+23
+Asked to bring
+others/By whom?
+Gifts
+NO (Controlled call to
+Twin Sister)
+24
+Physical Evidence
+(i.e. Message Pads,
+Trash Pulls, Search
+Warrant, Payment
+Documentation, etc.)
+Controlled call to
+-- 0
+- 2 items 04/08/2005.
+25
+26
+27
+28
+TRAVEL
+Title 18 USC 2423(b)
+Dates of
+Travel/Aircraft
+Title 18 USC 1591(a).
+03/31/2005 -
+R
+Jane Doe #17
+N/A
+YES - Victoria's Secret
+Bra and Panties sets,
+Digital camera and
+photography book
+03/31/2005
+09/18/2005 -
+09/29/2005 - |
+Jane Doe #18
+andperformed
+first massage together.
+to leave the
+room. JE asked
+to
+get naked. JE asked
+if he could use the
+massager on her vagina.
+Testimony/Telephone
+Records
+
+
+1
+29
+30
+DOB
+Who Scheduled
+Appointments?
+Miscellaneous
+R
+S
+Jane Doe #16
+via l
+Jane Doe #17
+(MessPd -4),
+(MessPd - 1)
+via
+Jane Doe #18
+and
+told that JE had
+put his fingers inside her
+and had brought out the
+massager.
+_statedreceived
+$200.00 for bringing to
+JE.
+of
+knows W because
+boyfriend,
+brother is
+the father
+Is child
+31
+32
+33
+Interviewed by PBPD Yes
+Interviewed by FBI
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+DOB
+AGE AT FIRST
+CONTACT
+HIGH SCHOOL
+BROUGHT BY
+DATES OF
+CONTACT/ SOURCE
+GIRLS RECRUITED
+T
+Jane Doe #19
+16
+Royal Palm Beach HS
+U
+V
+17
+Royal Palm Beach HS
+Early 2005 - Testimony
+N/A
+2
+Sometime between
+04/2004 - 07/2004 via
+&M Telephones -Start
+Date only.
+NUMBER OF
+MASSAGES
+ENTICEMENT
+Title 18 USC 2422(b)
+Interstate Commerce
+Connection
+Under 18 at time of
+YES -16
+sexual activity
+Advised if asked to YES-
+state they were over
+18/Advised by
+whom?
+3-4 times
+YES - 17
+11
+Knowledge or
+Discussion of Age
+with JE?
+After a while, somebody
+told him.
+12
+13
+14
+Payment for
+services?/Amount
+Payment for
+recruitment
+YES/$200.00 or $300.00
+YES/$300.00 max
+YESIFE stated $200.00
+
+
+1
+15
+16
+17
+18
+19
+20
+21
+DOB
+Jane Doe #19
+Payments made by
+Taken upstairs by
+Epstein
+Clothing worn during JE asked to • to remove
+massage
+clothing. refused.
+Sexual activity
+Epstein pulled at
+clothing and touched
+butt and breasts.
+U
+V
+Epstein
+3rd time-Bra/Underwear
+4th time-Underwear
+JE touched
+bare
+breasts and buttocks. JE
+touched
+•vagina over
+her underwear. JE pulled
+•close to him as he
+masturbated.
+Masturbation
+Ejaculation
+Sexual activity with
+Unsure
+
+
+1
+22
+23
+24
+25
+26
+27
+28
+DOB
+Statements made by
+Epstein
+T
+Jane Doe #19
+U
+V
+JE offered SV $100.00
+Asked to bring
+others/By whom?
+Gifts
+Unknown
+NO (knew was
+offered more money and
+•received a blue
+Dodge.)
+Physical Evidence
+(i.e. Message Pads,
+Trash Pulls, Search
+Warrant, Payment
+Documentation, etc.)
+Testimony
+•-1
+TRAVEL
+Title 18 USC 2423(b)
+Dates of
+Travel/Aircraft
+
+
+1
+29
+30
+DOB
+Who Scheduled
+Appointments?
+Miscellaneous
+T
+U
+V
+Jane Doe #19
+called and
+said she did not want to
+do it anymore.
+observed pictures of
+naked people while going
+up the stairs at JE's
+residence. JE asked
+for
+telephone
+number.
+stopped
+going because she was
+scared JE was going to
+do something. We told
+to say she was 18 if
+asked.
+31
+32
+33
+Interviewed by PBPD Yes
+Interviewed by FBI
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+DOB
+W
+AGE AT FIRST
+CONTACT
+HIGH SCHOOL
+17
+RPBHS/Survivors BB
+BROUGHT BY
+DATES OF
+On or about 11/2004 -
+CONTACT/ SOURCE Testimony
+GIRLS RECRUITED
+N/A
+NUMBER OF
+MASSAGES
+ENTICEMENT
+Title 18 USC 2422(b)
+Interstate Commerce
+Connection
+Under 18 at time of
+sexual activity
+Advised if asked to
+state they were over
+18/Advised by
+whom?
+1
+YES - 17
+Knowledge or
+Discussion of Age
+with JE?
+•told JE she was 18.
+Payment for
+services?/Amount
+Payment for
+recruitment
+YES/$350.00 or $400.00
+(she was supposed to
+give money to l
+but didnt)
+X
+17
+John I. Leonard HS
+Y
+17
+Home School
+After 08/2004 - via
+Telephone
+N/A
+1
+After 08/2004 - vial
+Telephone
+N/A
+1
+YES - 16 or 17
+Sophomore Year of H.S.
+YES - 17
+During small talk with JE, No age related discussion
+mentioned she was in with JE.
+school but did not say
+what level of school.
+YES/$200.00
+|YES/$200.00
+
+
+1
+15
+16
+17
+18
+19
+20
+21
+DOB
+W
+X
+Y
+Payments made by
+Taken upstairs by
+Epstein
+Unknown blonde female
+Unable to recall
+Unknown blonde female
+Clothing worn during Bra and Underwear
+massage
+Sexual activity
+Nude
+Bra, underwear and skirt.
+JE rubbed a white vibrator JE masturbated in full
+JE masturbated while
+over thong
+view whileprovided
+provided the massage.
+underwear on her vaginal the massage. JE touch
+JE reached under
+area. JE masturbated,
+• stomach, arms, legs skirt and touched her
+ejaculated and removed and bare breasts.
+vagina on top of her
+himself from the massage
+underwear.
+table.
+Masturbation
+Ejaculation
+Sexual activity with
+Unknown
+Unknown
+
+
+1
+DOB
+X
+Y
+Statements made by JE asked to take her
+JE asked, "Are you going Take off your clothes.
+Epstein
+shirt and pants off. JE
+to take your clothes off?"
+That's part of this.
+askedto straddle him
+and massage his back.
+22
+23
+Asked to bring
+others/By whom?
+Gifts
+N/A
+None
+None
+24
+Physical Evidence
+(i.e. Message Pads,
+Trash Pulls, Search
+Warrant, Payment
+Documentation, etc.)
+Testimony
+Testimony
+Testimony
+25
+TRAVEL
+26
+_Title 18 USC 2423(b)
+Dates of
+Travel/Aircraft
+27
+28
+
+
+1
+29
+30
+DOB
+Who Scheduled
+Appointments?
+Miscellaneous
+W
+was ashamed and
+uncomfortable with the
+ituation. The massag
+asted approx 45-60 mir
+31
+32
+33
+Interviewed by PBPD Yes
+Interviewed by FBI
+X
+believed paid
+•observed numerous
+$200.00 for bringing
+photos and sculptures of
+identified JE in a
+naked people at the
+photo spread. and
+residence.
+•identified
+started massaging JE JE in a photo spread.
+together initially then JE
+was aware
+asked to go to the
+and
+balcony.
+was not
+went to JE's.
+had
+expecting the events that
+drank beer and took
+occurred at JE's
+residence. did not tell JE's residence.and
+that she might have to started massaging JE
+together initially then JE
+masturbate. JE later told told
+to leave. He
+that he did not like AC disrobed and began
+because she was so
+masturbating after left
+nervous.
+was aware
+the room.
+that
+and
+had been to
+residence. She stated
+had brought girls to
+frequently
+
+
+1
+2
+3
+4
+5
+DOB
+Z
+AA
+AB
+AC AD
+AGE AT FIRST
+CONTACT
+HIGH SCHOOL
+BROUGHT BY
+DATES OF
+CONTACT/ SOURCE
+GIRLS RECRUITED
+6
+7
+8
+9
+10
+NUMBER OF
+MASSAGES
+ENTICEMENT
+Title 18 USC 2422(b)
+Interstate Commerce
+Connection
+Under 18 at time of
+sexual activity
+Advised if asked to
+state they were over
+18/Advised by
+whom?
+=
+Knowledge or
+Discussion of Age
+with JE?
+12
+13
+Payment for
+services?/Amount
+Payment for
+14
+recruitment
+
+
+1
+15
+16
+17
+18
+19
+20
+21
+DOB
+Payments made by
+Taken upstairs by
+Clothing worn during
+massage
+Sexual activity
+Z
+AA
+AB
+AC AD AE L
+_AF AG
+Masturbation
+Ejaculation
+Sexual activity with
+
+
+1
+DOB
+Statements made by
+Epstein
+Z
+AA
+AB
+AC AD AE AF AG
+22
+23
+Asked to bring
+others/By whom?
+Gifts
+24
+Physical Evidence
+(i.e. Message Pads,
+Trash Pulls, Search
+Warrant, Payment
+Documentation, etc.)
+25
+TRAVEL
+26
+_Title 18 USC 2423(b)
+Dates of
+Travel/Aircraft
+27
+28
+
+
+1
+29
+30
+DOB
+Who Scheduled
+Appointments?
+Miscellaneous
+Z
+AA
+_AE AF
+AG
+31
+32
+33
+Interviewed by PBPD
+Interviewed by FBI
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+12
+13
+14
+AH
+Al
+DOB
+AGE AT FIRST
+CONTACT
+HIGH SCHOOL
+BROUGHT BY
+DATES OF
+CONTACT/ SOURCE
+GIRLS RECRUITED
+NUMBER OF
+MASSAGES
+ENTICEMENT
+Title 18 USC 2422(b)
+Interstate Commerce
+Connection
+Under 18 at time of
+sexual activity
+Advised if asked to
+state they were over
+18/Advised by
+whom?
+Knowledge or
+Discussion of Age
+with JE?
+Payment for
+services?/Amount
+Payment for
+recruitment
+
+
+1
+15
+16
+18
+19
+20
+21
+DOB
+Payments made by
+Taken upstairs by
+Clothing worn during
+massage
+Sexual activity
+AH
+AI
+Masturbation
+Ejaculation
+Sexual activity with
+
+
+1
+22
+23
+24
+25
+26
+27
+28
+DOB
+Statements made by
+Epstein
+AH
+Al
+Asked to bring
+others/By whom?
+Gifts
+Physical Evidence
+(i.e. Message Pads,
+Trash Pulls, Search
+Warrant, Payment
+Documentation, etc.)
+TRAVEL
+Title 18 USC 2423(b)
+Dates of
+Travel/Aircraft
+
+
+1
+DOB
+Who Scheduled
+Appointments?
+29
+30
+Miscellaneous
+AH
+Al
+31
+32
+33
+Interviewed by PBPD
+Interviewed by FBI
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/e0a7a1c1d83c090db4ba7967d5c5bd945d70c4ea13d82e8e5b5f9e0cfbd30193.receipt.json b/vision-fixhub/ds9-unparsed-05/e0a7a1c1d83c090db4ba7967d5c5bd945d70c4ea13d82e8e5b5f9e0cfbd30193.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7348d8541d31804c295997e77c896ee13a11f099
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e0a7a1c1d83c090db4ba7967d5c5bd945d70c4ea13d82e8e5b5f9e0cfbd30193.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1981,
+  "dataset": "marble-joined",
+  "doc_id": "e0a7a1c1d83c090db4ba7967d5c5bd945d70c4ea13d82e8e5b5f9e0cfbd30193",
+  "engine": "marble-apple-vision",
+  "event_count": 42,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "eba799b4a18a73f94a86879d6f0e2f0060555ac28881aa7c509c0736cb3e71ca",
+  "output_sha256": "87d94aa6b9b98023a715ba377314a3245b015adf43e070bc7ac2962c0596f355",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e0ac260e46c55988afdf03bf4a4156478d2a418c7ce722a0dacbb0ab052c47f9.md b/vision-fixhub/ds9-unparsed-05/e0ac260e46c55988afdf03bf4a4156478d2a418c7ce722a0dacbb0ab052c47f9.md
new file mode 100644
index 0000000000000000000000000000000000000000..718afa7c6c97b35a657f5ab923674d93eed04c1b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e0ac260e46c55988afdf03bf4a4156478d2a418c7ce722a0dacbb0ab052c47f9.md
@@ -0,0 +1,49 @@
+OLY-36
+
+
+TO:
+West Palm Beach, FL
+United States District c'ourt
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-36
+SUBPOENA FOR:
+•
+PERSON
+X
+DOCUMENTS OR OBJECTIS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+March 13, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following document(s) or objects):
+See attachments
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+-
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+• on behalf of the court.
+CLERK
+DATE:
+March 2, 2007
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the United States of America
+*If not applicable, enter "none."
+Name, Address and Phone Number of Assistant U.S. Attorney
+S00 So. Australian Avenue, Suite 400
+West Palm Beach, FL. 33401-6235
+Tel:
+Fax:
+To be used in lieu of AO110
+FORM ORD-227
+JAN.86
diff --git a/vision-fixhub/ds9-unparsed-05/e0ac260e46c55988afdf03bf4a4156478d2a418c7ce722a0dacbb0ab052c47f9.receipt.json b/vision-fixhub/ds9-unparsed-05/e0ac260e46c55988afdf03bf4a4156478d2a418c7ce722a0dacbb0ab052c47f9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..bcb42e0a08e52d4a66d5f168d5536a065329bb8f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e0ac260e46c55988afdf03bf4a4156478d2a418c7ce722a0dacbb0ab052c47f9.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "e0ac260e46c55988afdf03bf4a4156478d2a418c7ce722a0dacbb0ab052c47f9",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "5caf15c59c5a0fc3241211c31b91e20ed2f7261c593336fae3851ca2ba75045c",
+  "output_sha256": "edc99a651c9be5960b20928fc3b9e4c845e96f88c9953813260380745a7e455e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e0df6ad7e8047731a2674837fd779526d793ba28c2f39d2467193c0c8fcce6ff.md b/vision-fixhub/ds9-unparsed-05/e0df6ad7e8047731a2674837fd779526d793ba28c2f39d2467193c0c8fcce6ff.md
new file mode 100644
index 0000000000000000000000000000000000000000..3845af646ec289bedf8781592f62a648c9072349
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e0df6ad7e8047731a2674837fd779526d793ba28c2f39d2467193c0c8fcce6ff.md
@@ -0,0 +1,224 @@
+5/15/08 OUSTERBAAN-
+LEFAOWITE LIR
+
+
+15/16/2008 11:16 HAA
+15/13/08
+FRI 11:08 FAX
+UNITED STATES DEPARTMENT OF JUSTICE
+Criminal Division
+Child Exploitation and Obscenity Section
+1400 New York Avenue, NW
+Suite 600
+Washington, DC 20530-0001
+20005
+CEOS: (202) 514-5780
+FAX: (202) 514-1793
+2001
+TO:
+'R. Alexander Acosta, Esq.
+Jay Lefkowitz, Esq.
+OFFICE NUMBER:
+FAX NUMBER:
+305/530-7087
+FROM:
+Alexandra Gelber.
+DATE/TIME:
+May 16, 2008
+OFFICE NUMBER: (202) 514-5780
+NUMBER OF PAGES, EXCLUDING THIS SHEET: 5
+SPECIAL INSTRUCTIONS:
+
+
+UD/1D/ZUU 11:10 PAA
+05/16/08
+FRI 11:08 FAX
+0002
+Child Exploirion and Obsceniry Rection
+U.S. Department of Justice
+Criminal Division
+Andrew G. Oosterbaan, Chief
+100 New York Avanna, NIP
+inite d00
+Leu25, D0 208: (202 514-1793
+May 15, 2008
+Jay Lofkowitz, Esq.
+Kirkland & Ellis LLP
+Citigroup Center
+153 E. 53° St.
+New York, NY 10022-4611
+Re: Investigation of Jeffery Epstein
+Dear Mr. Lefkowitz:
+Pursuant to your request and the request of U.S. Attorney R. Alexander Acosta, we have
+independently evaluated certain issues raised in the investigation of Jeffrey Epstein to determine
+whether a decision to prosecute Mr. Epstein for federal criminal violations would contradict
+criminal enforcement policy interests, As part of our evaluation, we have reviewed letters
+written on behalf of Mr. Epstein on February 1, 2007, June 25, 2007, July 6, 2007, March 28,
+2008, April 8, 2008, April 28, 2008, and May 14, 2008, with their attachments. We have also
+reviewed memos prepared by the U.S. Attorney's Office. As you will recall, we met with you
+and other representatives of Mr. Epstein to further discuss your views on the propriety of a
+federal prosecution. We have discussed the factual and legal issues you raise with the Criminal
+Division's Appellate Section, and we consulted with the Office of Enforcement Operations
+concerning the petite policy.
+We are examining the narrow question as to whether there is a legitimato basis for the
+U.S. Attorney's Office to proceed with a federal prosecution of Mr. Epstein. Ultimately, the
+prosecutorial decision making authority within a U.S. Attorney's Office lies with the U.S.
+Attorey. Therefore, to borrow a phrase from the case law, the question we sought to answer
+was whether U.S. Attorey Acosta would abuse his discretion if he authorized prosecution in this
+case.
+As you know, our review of this case is limited, both factually and legally. We have not
+looked at the entire universe of facts in this case. It is not the role of the Criminal Division to reconduct a complete factual inquiry from scratch. Furthermore, we did not analyze any issues
+concerning prosccution under federal statutes that do not pertain to child exploitation, such as the
+money laundering statutes.
+
+
+05/16/2008 11:16 FAX
+05/18/08 FRI 11:08 FAX
+2003
+As was made clear at the outset, we did not review the facts, circumstances, or terms
+included in the plea offer, not any allegations that individuals involved in the investigation
+engaged in misconduct. Despite that agreement, wo note that your letters of April 8, April 28,
+and May 14 focus in large part on accusations of investigative or prosecutorial misconduct. Not
+only do allegations of prosecutorial misconduct fall outside the boundary of our agreed review,
+they also fall outside the authority of the Criminal Division in the first instance. Simply, the
+Criminal Division does not investigate or resolve allegations of professional misconduct by
+federal prosecutors. For these reasons, we do not respond to the portion of those letters that
+discuss alleged misconduct.
+Based on our review of all of these materials, and after careful consideration of the issues,
+we conclude that UJ.S. Attomey Acosta could properly use his discretion to authorize prosecution
+in this case. We will briefly address each of the issues that you have raised.
+Knowledge of age. Federal child exploitation statutes differ as to whether there must be
+proof that the defendant was aware that the children were under the age of 18. However, even
+for those statutes where knowledge of age is an element of the offense, it is possible to satisfy
+that element with proof that the defendant was deliberately ignorant of facts which would suggest
+that the person was a minor. For that reason, the fact that some of the individuals allegedly lied
+1o Mr. Epstein about their age is not dispositive of the issue. While there may be an open factual
+issue as to Mr. Epstein's knowlodge, we cannot say that it would be impossible to prove
+knowledge of age for any such charges which require it. Thereforo, Mr. Acosta could rightfully
+conclude that this factual issue is best resolved by a jury.
+Travel for the purpose. In the materials you prepared, you suggest that Mr. Epstein
+should not be charged with violating 18 U.S.C. § 2423(b) because his dominant purpose in going
+to Florida was not to engage in illegal sexual activity, but rather to return to one of his residences.
+While we fully understand your argument, we also find that the U.S. Attorney's office has a good
+faith basis fully to develop the facts on this issue and brief the law to permit a court to decide
+whether the law properly reaches such conduct. Mr. Acosta would not be abusing his discretion
+it he decided to pursue such a course of action.
+Intent to engage in the conduct at the time of travel. Based on our review of the facts of
+this case, we respectfully disagree that there is no evidence concerning Mr. Epstein's intent when
+he traveled, and when that intent was formed. Should Mr. Acosta elect to let the case proceed so
+that a jury can resolve this factual issue, be would be within his discretion to do so.
+Use of a facility or means of interstate or foreign commerce. Much of the materials you
+have prepared and much of the inceting we had focused on 18 U.S.C. § 2422(b), specifically your
+contention that Mr. Epstein did not use the phone to coerce anyone to engage in illegal sexual
+activity. We understand the issue you raise concerning the statutory interpretation. As before,
+however, we cannot agree that there is no evidence that would support a charge under Section
+2422(b), nor can we agree that there is no argument in support of the application of that statute to
+this case. Finally, our assessment is that the application of that statute to these facts would not be
+2
+
+
+05/16/2008 11:10 FAA
+05/16708 FRI 11:09 FAX
+12004
+so novel as to implicate the so-called "clear statement rulc," the Ex Post Facto clause, or the Due
+Process clause. As with the other legal issues, Mr. Acosta may elect to proceed with the case.
+Absence of coercion. With respect to 18 U.S.C. § 1591, the alleged absence of the use of
+force, fraud, or coercion is of no moment. The statute does not require the use of force, fraud,
+and coercion against minors. Because of their age, a degrec of coercion is presumed. In your
+materials, you note that the statute requires that the minors must be "caused" to engage in a
+commercial sex act, further arguing that the word "cause" suggests that a certain amount of
+undue influence was used. We reject that interpretation, as it would read back into the offense an
+element-coercion-that Congress has expressly excluded. We have successfully prosecuted
+defendants for the commercial sexual exploitation of minors, even when the minors testified that
+not only did they voluntarily engage in the commercial sex acts, it was their idea to do so. As
+such, Mr. Acosta could properly decide to pursue charges under Scetion 1591 oven if there is no
+evidence of coercion.
+More broadly, a defendant's criminal liability does not hinge on his victim identifying as
+having suffered at his hands. hercfore, a prosecution could procced, should Mr. Acosta decide
+to do so, even though some of the young women allegedly have said that they do not view
+themselves as victims.
+Witness credibility. As all prosecutors know, there are no perfect witnesses. Particularly
+in cases involving exploited children, as one member of your defense team, Ms. Thacker, surely
+knows from her work at CEOS, it is not uncommon for victim-witnesses to give conflicting
+statements. The prosecutors are in the best position to assess the witness's credibility. Often, the
+prosecutor may decide that the best approach is to present the witness, let defense counsel
+explore the credibility problems on cross-cxamination, and let the jury resolve the issue. Mr.
+Acosta would be within his authority to select that approach, especially when here there are
+multiple, mutually-corroborating witnesses.
+Contradictions and omissions in the search warrant application. We have carefully
+reviewed the factual issues you raise concerning the search warrant application. For a search
+warrant to be suppressed, however, the factual errors must be material, and the officers must not
+have proceeded in good faith. Despite the numerous factual errors you describe, the U.S.
+Attorney's Office could still plausibly argue that the mistakes-whether inadvertent or
+intentional-were not material to the determination that probable cause existed for a search, and
+that the search was in good faith in any event. As such, Mr. Acosta could properly elect to
+defend the scarch warrant in court rather than forego prosecution.
+Petite Policy: After reviewing the petite policy and consulting with the Office of
+Enforcement Operations ("ORO"), we conclude that the petite policy does not prohibit federal
+proseculion in this case, According to the U.S. Attorney's Manual, the petite policy "applies
+whenever there has been a prior state or federal prosecution resulting in an acquittal, a
+conviction, including one resulting from a plea agreenent, or a dismissal or other termination of
+3
+
+
+05/16/2008 11:17 FAX
+05/16/08 FRI 11:09 FAX
+40005/006
+40005
+the case on the merits after jeopardy has attached." USAM 9-2.031(C). Our understanding is
+that the state case is still pending. As such, the procedural posture of the state case does not
+implicate the petite policy.
+We recognize that the petite policy could be triggered if the state case concluded after a
+federal indictment was issued but prior to the conmencement of any federal trial. Id. However,
+the policy "does not apply... where the [state] prosecution involved only a minor part of the
+contemplated federal charges." USAM 9-2.031(B). Based on our understanding of the possible
+federal charges and existing state charges, we do not think the petite policy would be an issue
+should federal proceedings take place.
+Federalism and Prosecutorial Discretion. All of the above issues essentially ask whether
+a foderal prosecution can proceed. We understand, however, that you also ask whether a federal
+prosecution should proceed, even in the event that all of the elements of a foderal offense could
+be proven. On this issue, you raised two arguments: that the conduct at issue here is traditionally
+a state concern because the activity is entirely local, and that the typical prosecution under federal
+child exploitation statutes have different facts than the ones implicated here. You have
+essentially asked us to look into whether a prosecution would so violate federal prosecutorial
+policy that a United States Attorney's Office should not pursue a prosecution. We do not think
+that is the case here for the following reasons.
+Simply, the commercial sexual exploitation of children is a foderal concern, even when
+the conduct is local, and regardless of whether the defendant provided the child (the "pimp") or
+paid for the child (the "john"). In your materials, you refer to a letter sent by the Department of
+Justice to Congress in which the Department expresses concern over the expansion of federal
+laws to reach almost all instances of prostitution. In that portion of the letter, the Department
+was expressly referring to a proposed federal law that reach adult prostitution where no force,
+frand, or coercion was used. Indeed, the point being made in that letter is that the Department's
+efforts are properly focused on the commercial sexual exploitation of children and the
+exploitation of adults through the use of force, fraud, or coercion. As such, there is no
+inconsistency between the position taken in that letter and the federal prosecution of wholly local
+instances of the conmercial sexual exploitation of children.
+If Congress wanted to limit the reach of federal statutes only to those who profit from the
+commercial sexual exploitation of children, or only to those who actually traffic children across
+state lines, it could have done so. It did not. Finally, that a prosecution of Mr. Epstein might not
+look precisely like the cases that came before it is not dispositive. We can say with confidence
+that this case is consistent in principle with other federal prosecutions nationwide. As such, Mr.
+Acosta can soundly exercise his authority to decide to pursue a prosecution even though it might
+involve a novel application of' a federal statute,
+Conclusion. After carefully considering all the factual and legal issues raised, as well as
+the arguments concerning the general propriety of'a federal case against Mr. Epstein on these
+4
+
+
+05/16/2008 11:17 FAX
+05/16/08
+FRI 11:10 FAX
+40006/006
+0006
+facts, we conclude that federal prosecution in this case would not be improper or inappropriate.
+While you raise many compelling arguments, we do not see anything that says to us categorically
+that a federal case should not be brought. Mr. Acosta would not be abusing his prosecutorial
+discretion should he authorize federal prosecution of Mr. Epstein
+Sincerely yoke's,
+NG.
+• Oosterbaan
+co:
+AAG Alice S. Fisher
+DAAG Sigal P. Mandelker
+U.S. Attorney R. Alexander Acosta (
diff --git a/vision-fixhub/ds9-unparsed-05/e0df6ad7e8047731a2674837fd779526d793ba28c2f39d2467193c0c8fcce6ff.receipt.json b/vision-fixhub/ds9-unparsed-05/e0df6ad7e8047731a2674837fd779526d793ba28c2f39d2467193c0c8fcce6ff.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..916baefa0f718da45436ee67a8634029f7c1584b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e0df6ad7e8047731a2674837fd779526d793ba28c2f39d2467193c0c8fcce6ff.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -86,
+  "dataset": "marble-joined",
+  "doc_id": "e0df6ad7e8047731a2674837fd779526d793ba28c2f39d2467193c0c8fcce6ff",
+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "7b2a2bea9981b5971513b19f98d24d9ad8d095a654c238e9fefd544c4ce2c9d8",
+  "output_sha256": "a410a835a683429498f906201c14cd2b87fcfca07c85f22d2e04c0cf736425c1",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e247354075c01034f39ec18fb180a3f86c25b5ce77655c3b14b4f0c24a4ed419.md b/vision-fixhub/ds9-unparsed-05/e247354075c01034f39ec18fb180a3f86c25b5ce77655c3b14b4f0c24a4ed419.md
new file mode 100644
index 0000000000000000000000000000000000000000..bd12b103358acd413d5ed2a9025bbfcfce58b9f0
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e247354075c01034f39ec18fb180a3f86c25b5ce77655c3b14b4f0c24a4ed419.md
@@ -0,0 +1,56 @@
+(USAFLS)
+From:
+Sent:
+To:
+Subject:
+(FBI) <
+Tuesday, July 22, 2008 3:05 PM
+1. (USAFLS)
+Re:
+Bogota- ALATI
+--- Original Message -
+From:
+To:
+Sent: Tue Jul 22 15:01:29 2008
+Subject: RE:
+(USAFLS) <
+Actually, do you have the names of the LegAtts?
+Sydney - ALAT
+Assistant U.S. Attorney
+---Original Message-----
+From:
+(FBI)
+Sent: Tuesday, July 22. 2008 2:58 PM
+To:
+(USAFLS)
+Subject: Re:
+--- Original Message
+(USAFLS) <
+Sent: Tue Jul 22 14:57:45 2008
+Subject: RE:
+Hey What addresses should I put on
+and
+letters?
+Assistant U.S. Attorney
+From:
+I. (FBI)
+08-80736-CV-MARRA
+265
+P-015091
+
+
+Sent: Tuesday. July 22, 2008 12:28 PM
+(USAFLS)
+Subject:
+Hey take a deep breath!!!!! I had not read your latest email or Tein's letter. I'm speechless but we must deal with only one issue at a
+time. We need to, as u say, digest and disect. As I write this, the pain in my gut intensifies. I hope it is only something I ate and not
+an ulcer from Epstein. Anyways, take a deep breath!!!!!
+Our legat has located what we believe to be a good address for
+included with the lead to Bogata.
+I need to come by and get her letter from you so it can be
+address is:
+Let me know what time to come by and also dont hesitate to call if you need something done. Hang in there( THIS IS
+CRAZY)!!!!!!!!!!!!!!!!
+08-80736-CV-MARRA
+266
+P-015092
diff --git a/vision-fixhub/ds9-unparsed-05/e247354075c01034f39ec18fb180a3f86c25b5ce77655c3b14b4f0c24a4ed419.receipt.json b/vision-fixhub/ds9-unparsed-05/e247354075c01034f39ec18fb180a3f86c25b5ce77655c3b14b4f0c24a4ed419.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f6e1f1590468337c71b6a6d66553ecff2188575f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e247354075c01034f39ec18fb180a3f86c25b5ce77655c3b14b4f0c24a4ed419.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "e247354075c01034f39ec18fb180a3f86c25b5ce77655c3b14b4f0c24a4ed419",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "9ddd701b36836f44459deab8dbf5e77ea75cbf9968ced003ab4d9b0c0ae8aec6",
+  "output_sha256": "1326adfc246a9170c24d28b2aecc5623b806614b53f8581776b96c162f2a1338",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e282c87b721c40339c0a864bff6a326b7a2c8e0237eb9b62befbb08dc9ba96ac.md b/vision-fixhub/ds9-unparsed-05/e282c87b721c40339c0a864bff6a326b7a2c8e0237eb9b62befbb08dc9ba96ac.md
new file mode 100644
index 0000000000000000000000000000000000000000..1dc8db3b0bfe189d19b77425512fa3cad3b660b1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e282c87b721c40339c0a864bff6a326b7a2c8e0237eb9b62befbb08dc9ba96ac.md
@@ -0,0 +1,883 @@
+CASE NO:_10-80015-CR-Marra/Hopkins
+UNITED STATES OF AMERICA,
+Plaintiff,
+VS.
+ALFREDO RODRIGUEZ,
+Defendant.
+/
+ORDER RE: STATUS CONFERENCE, SPEEDY TRIAL, AND
+PRETRIAL MATTERS
+IT IS HEREBY ORDERED that counsel for the Government and the Defense
+appear before N/A for STATUS CONFERENCE to resolve pre-trial motions and discovery
+problems.
+All counsel are directed to read carefully the Standing Discovery Order which
+clearly delineates the parties' discovery obligations, including the materials sought by the vast
+majority of the standard pre-trial motions. Routine filing of "Boilerplate" motions covered by the
+Standing Discovery Order, as well as repeated failure to timely provide discovery has
+substantially contributed to the backlog of criminal cases in this District. Accordingly, all
+counsel are hereby advised that this Court will recommend the imposition of sanctions against
+attorneys who persist in these practices.
+Where the parties are able to resolve pretrial matters prior to the date of the above
+scheduled status conference, they should so notify the Court, in writing, and will be excused from
+attendance at the conference.
+2.
+Under Rule 88.5 of the Local Rules of the United States District Court for the
+Southern District of Florida it is the duty of counsel to provide the Court with written reports
+setting forth the speedy Trial status of each case pending before the Court. Such report shall be
+submitted to the United States Attorney pursuant to that Rule. Such report shall set forth:
+
+
+A.
+All excusable time on which there is agreement, including the applicable statutes;
+B.
+All excusable time as recorded on the docket on which there is a conflict, including
+the applicable statutes;
+C.i.
+ii.
+iii.
+iv.
+Computation of the gross time;
+Excusable time;
+Net time remaining;
+The final date upon which the defendants) may be tried in compliance
+with the speedy trial plan of this Court; and
+D.
+Any agreement by the parties as to excusable time which exceeds the amount
+recorded on the docket shall have no effect unless approved by the Court. Failure
+to timely file such reports may result in sanctions being imposed.
+3. The United States Attorney shall provide discovery to the defendant(s) within the
+time provide under the Standing Discovery Order. Failure to timely provide such discovery
+absent prior approval of the Court for an extension of time, may result in the imposition of
+sanctions by the Court.
+The defendant(s) shall file all motions on a timely basis within the period provided
+in the Standing Discovery Order. Failure to timely provide such discovery absent prior approval
+of the Court for an extension of time, may result in the imposition of sanctions by the Court.
+A.
+Any extension of time for filing defensive motions must be requested at
+the time of arraignment.
+Any motion untimely filed will be denied unless good cause is shown for
+the delay, except as justice requires or as otherwise provided by the
+Federal Rules of Criminal Procedure.
+Counsel shall abide by Local Rule 88.9 which states:
+Motions in criminal cases shall be accompanied by a written statement certifying
+that counsel for moving party, or the moving party if not represented by counsel,
+has conferred with opposing counsel or party as the case may be, in an effort in
+good faith to resolve by agreement the subject matter of any motion, but has not
+been able to do so. In addition, the written statement shall specify the information
+
+
+that has been made available to opposing counsel or parties in lieu of filing
+motion.
+Pursuant to Amendment to General Local Rule 7, Local Rules of the United States
+District Court for the Southern District of Florida entered July 17, 1984, counsel must attach a
+copy of each pleading, motion, and/or other papers tendered for filing with the original
+document. Both the original and the copy will be filed together with the Clerk of Court. Please
+attach your envelopes to the copy not the original.
+Motions to travel must set forth:
+A.
+The date the defendant desires to leave the area permitted under the bond;
+B.
+C.
+The date of his/her return;
+The address where the defendant will be staying;
+The telephone number at the place where the defendant will be staying;
+E.
+"he method of travel to be used by the defendan
+F.
+hether the United States Attorney has no objection to such travel; an
+G.
+The name of the Magistrate Judge who originally set the conditions of
+release.
+DONE AND ORDERED at West Palm Beach, Florida, this 1st day of February, 2010.
+/S| ANN E. VITUNAC
+ANN E. VITUNAC
+UNITED STATES MAGISTRATE JUDGE
+c: All Counsel of Record
+
+
+JAMUTIV 3ИИА
+
+
+CASE NO.: 10-80015-CR-Marra/Hopkins
+UNITED STATES OF AMERICA,
+Plaintiff,
+VS.
+ALFREDO RODRIGUEZ,
+Defendant,
+STANDING DISCOVERY ORDER
+The above-named defendants) having been arraigned this date in open Court, it is
+thereupon
+ORDERED and ADJUDGED that on or before fourteen (14) days from the date of this
+Order, the parties shall confer and the following shall be accomplished:
+A.
+The Government shall permit the defendants) to inspect and copy the following items or
+copies thereof, or supply copies thereof, which are within the possession, custody or
+control of the Government, the existence of which is known or by the exercise of due
+diligence may become known to the Government:
+Written or recorded statements made by the defendants).
+2.
+The substance of any oral statement made by the defendants) before or after
+his/her/their arrest (s) in response to interrogation by a then known-to-be
+Government agent which the Government intends to offer in evidence at trial.
+3.
+Recorded grand jury testimony of the defendants) relating to the offenses
+charged.
+The defendant's(s') arrests) and conviction record(s).
+5.
+Books, papers, documents, photographs, tangible objects, buildings or places, or
+copies or portions thereof, which are material to the preparation of the defendant's
+defense, or which the Government intends to use as evidence at trial to prove its
+case in chief, or were obtained from or belonging to the defendants).
+6.
+Results or reports of physical or mental examinations, and of scientific tests or
+experiments, made in connection with this case.
+
+
+B.
+D.
+F.
+G.
+H.
+The defendants) shall permit the Government to inspect and copy the following items, or
+copies thereof, or supply copies thereof, which are within the possession, custody or
+control of the defendants), the existence of which is known or by the exercise of due
+diligence may become known to the defendants).
+1.
+Books, papers, documents, photographs or tangible objects which the defendants)
+intend(s) to introduce as evidence in chief at trial.
+2.
+Any results or reports of physical or mental examinations and of scientific tests or
+experiments made in connection with this case which the defendants) intend(s) to
+introduce as evidence in chief at trial, or which were prepared by a defense
+witness who will testify concerning the contents thereof.
+If a defendant intends to rely upon the defense of insanity at the time of the
+alleged crime, or intends to introduce expert testimony relating to a mental
+disease, defect or other condition bearing upon the issue of whether he had the
+mental state required for the offense charged, he shall give written notice thereof
+to the government.
+The Government shall reveal to the defendants) and permit inspection and copying of all
+information and material known to the Government which may be favorable to the
+defendant on the issues of guilt or punishment within the scope of Brady. Maryland,
+373 U.S. 83 (1963), and United States |. Agurs, 427 U.S. 97 (1976).
+The Government shall disclose to the defendants) the existence and substance of any
+payments, promises of immunity, leniency, preferential treatment, or other inducements
+made to prospective Government witnesses, within the scope of Giglio vs. United States,
+405 U.S. 150 (1972), and Napue vs. Illinois, 360 U.S. 264 (1959).
+The Government shall supply the defendant(s) with a record of prior convictions of any
+alleged informant who will testify for the Government at trial.
+The Government shall state whether defendants) was/were identified in any lineup, show
+up, photo spread or similar identification proceeding, and produce any pictures utilized or
+resulting therefrom.
+The Government shall advise its agents and officers involved in this case to preserve all
+rough notes.
+The Government shall advise the defendants) of its intention to introduce extrinsic act
+evidence pursuant to Rule 404(b), Federal Rules of Evidence. The Government shall
+
+
+I.
+K.
+L.
+M.
+N.
+provide notice regardless of how it intends to use the extrinsic act evidence at trial, i.e.
+during its case-in-chief, for impeachment, or for possible rebuttal. Furthermore, the
+Government shall apprise the defense of the general nature of the evidence of the
+extrinsic acts.
+The Government shall state whether the defendants) was/were an aggrieved person(s), as
+defined in Title 18 United States Code Section 2510(11), of any electronic surveillance,
+and if so, shall set forth in detail the circumstances thereof.
+The Government shall have transcribed the grand jury testimony of all witnesses who will
+testify for the Government at the trial of this cause, preparatory to a timely motion for
+discovery.
+The Government shall, upon request, deliver to any chemist selected by the defense, who
+is presently registered with the Attorney General in compliance with 21 U.S.C. Section
+822 and Section 823, and 21 C.F.R. Section 101.22(8), a sufficient representative sample
+of any alleged contraband which is the subject of this indictment, to allow independent
+chemical analysis of such sample.
+The Government shall permit the defendants), his/her/their counsel and any experts
+selected by the defense to inspect any vehicle, vessel, or aircraft allegedly utilized in the
+commission of any offenses charged. Government counsel shall, if necessary, assist
+defense counsel in arranging
+custody of the thing to be inspected that such inspection has been ordered by the Court.
+The Government shall provide the defense, for independent expert examination, copies of
+all latent fingerprints or palm prints which have been identified by a Government expert
+as those of the defendants).
+The Government shall, upon request of the defendant, disclose to the defendant a written
+summary of testimony the Government reasonably expects to offer at trial under Rules
+702, 703, or 705 of the Federal Rules of Evidence. This summary must describe the
+witnesses' opinions, the bases and the reasons therefor, and the witnesses' qualifications.
+If the defendant seeks and obtains discovery under this paragraph, the defendant shall,
+upon request by the government, disclose to the Government a written summary of
+testimony the defendant reasonably expects to offer at trial under Rules 702, 703, or 705
+of the Federal Rules of Evidence, describing the witnesses' opinions, the bases and the
+reasons therefor, and the witnesses' qualifications.
+
+
+The parties shall make every possible effort in good faith to stipulate to all facts or points
+of law the truth and existence of which is not contested and the early resolution of which
+will expedite the trial.
+P.
+The parties shall collaborate in preparation of a written statement to be signed by counsel
+for each side, generally describing all discovery material exchanged, and setting forth all
+stipulations entered into at the conference. No stipulations made by defense counsel at
+the conference shall be used against the defendants) unless the stipulations are reduced to
+writing and signed by the defendants) and his/her/their counsel. This statement,
+including any stipulations signed by the defendants) and his/her/their counsel, shall be
+filed with the Court within five (5) days following the conference.
+Q.
+Timing of all discovery shall be governed by the provisions set forth in Paragraph Q of
+Local Rule 88.10.
+It shall be the continuing duty of counsel for both sides to immediately reveal to opposing
+counsel all newly discovered information or other material within the scope of this Standing
+Order.
+Upon a sufficient showing, the Court may at any time, upon motion properly filed, order
+that the discovery or inspection provided for by this Standing Order be denied, restricted or
+deferred, or make such other order as is appropriate. It is expected by the Court, however, that
+counsel for both sides shall make every good faith effort to comply with the letter and spirit of
+this Standing Order.
+All motions concerning matters not covered by this Standing Order must be filed pursuant
+to Local Rule 88.9 within twenty-eight (28) days of this Order.
+DONE and ORDERED at West Palm Beach, FL this 1" day of February, 2010.
+(S/ ANN E. VITUNAC
+ANN E. VITUNAC
+U.S. MAGISTRATE JUDGE
+
+
+DAMUTIV 3ИИА
+
+
+Case 9:10-cr-80015-KAM Document 15 Entered on FLSD Docket 01/29/2010 Page 1 of 4
+Case No. 10- 80015-CK-MARRA / HoPKiNS
+18 U.S.C. § 1512(c)
+UNITED STATES OF AMERICA
+v.
+ALFREDO RODRIGUEZ,
+Defendant.
+JAN 2 9 2010
+ID OF FLA. - W.I
+INFORMATION
+The United States Attorney charges that:
+From at least as early as January 18, 2007, through on or about November 3, 2009, in Palm
+Beach County, in the Southern District of Florida, and elsewhere, the defendant,
+ALFREDO RODRIGUEZ,
+did corruptly conceal a record, document, or other object, with the intent to impair the object's
+availability for use in an official proceeding, that is proceedings before a federal grand jury, and
+otherwise corruptly obstructed and impeded said official proceeding; in violation of Title 18, United
+States Code, Section 1512(c),
+JEFPREY H. SLOMAN
+UNITED STATES ATTORNEY
+ASSISTANT UNITED STATES ATTORNEY
+
+
+• Case 9:10-cr-80015-KAM Document 15 Entered on FLSD Docket 01/29/2010 Page 2 of 4
+UNITED STATES OF AMERICA
+VS.
+CASE NO. 10-80015 -CR- MARRA/HOPKiNS
+CERTIFICATE OF TRIAL ATTORNEY•
+ALFREDO RODRIGUEZ,
+Defendant. /
+Court Division: (Select One)
+=
+Miami
+FTL
+_ FTP
+I do hereby certily that:
+Superseding Case Information:
+New Defendant(s)
+Yes —
+Number of New Defendants
+Total number of counts
+No -
+Lot procare wily ses and the negatomplete of the nice tortion antacted here or
+2.
+3.
+4.
+5.
+=-
+IV
+V
+6.
+If yes:
+Judge:
+Interpreter:
+(Yes or No) _ No
+List language and/or dialect
+This case will take _
+4 days for the parties to try.
+Please check appropriate category and type of offense listed below:
+(Check only one)
+(Check anly one)
+0 to 5 days
+Petty
+6 to 10 days
+Minor
+11 to 20 days
+Misdem.
+21 to 60 days
+Felony
+61 days and over
+Has this case been previously filed in this District Court? (Yes or No)
+- Case No.
+No
+(Attach copy of dispositive order)
+Has a complaint been filed in this matter?
+If yes:
+Magistrate Case No.
+(Yes or No) _
+Yes
+09-8308-1B.
+Related Miscellaneous numbers:
+Defendants) in federal custody as of
+Defendant(s) in state custody as of
+Rule 20 from the
+District of
+Is this a potential death penalty case? (Yes or No) _
+No
+Does remate ending in the in the .. tormey's ofice
+8.
+ree matter ding in a Rein of the U.S. Atoney's office
+*Penalty Sheets) attached
+REV. 4/8/08
+
+
+Case 9:10-cr-80015-KAM Document 15 Entered on FLSD Docket 01/29/2010 Page 3 of 4
+PENALTY SHEET
+Defendant's Name: ALFREDO RODRIGUEZ
+Caso No.: 10 - 80015-CR -MARRA/ HOPKiNS
+Count 1:
+•
+18 U.S.C. § 1512(c)
+Obstruction of Justice
+"Max. Penalty: 20 years Imprisonment: 3 years Supervised Release: $250.000 Fine
+Count :
+"Max. Penalty:
+Count :
+"Max. Penalty:
+'Refers only to possible term of incarceration, does not include possible fines, restitution, specia
+issessments, parole terms or forfeitures that may be applicable
+KEV. 12/1270
+
+
+Case 9:10-cr-80015-KAM Document 15 Entered on FLSD Docket 01/29/2010 Page 4 of 4
+AO 455 (Rev. 01:09) Waiver of an Indictmens
+for the
+Southern District of Florida
+United States of America
+1.
+Alfredo Rodriguez
+Deferelur
+CAss No. 10-80015-CR-MARRA/
+HOPKiNS
+WAIVER OF AN INDICTMENT
+year. Vanderan that have acred on or lie ofter posita ble by again men for more than one
+After receiving this advice, I waive my right to prosecution by indictment and consent to prosecution by
+information.
+Date:
+Defendant's signature
+Signature uf defendani's attorney
+DAVE LEE BRANNON, AFPO
+Printed name of defendant's attorney
+Judge's signarure
+Judge's printed nume und title
+
+
+Case 9:10-cr-80015-KAM Document 15 Entered on FLSD Docket 01/29/2010 Page 1 of 4
+Case No. 10-80015-CR-MARRA / HOPKiNS
+18 U.S.C. § 1512(c)
+UNITED STATES OF AMERICA
+ALFREDO RODRIGUEZ,
+Defendant.
+JAN 2 9 2010
+INFORMATION
+The United States Attorney charges that:
+From at least as early as January 18, 2007, through on or about November 3, 2009, in Palm
+Beach County, in the Southern District of Florida, and elsewhere, the defendant,
+ALFREDO RODRIGUEZ,
+did corruptly. conceal a record, document, or other object, with the intent to impair the object's
+availability for use in an official proceeding, that is proceedings before a federal grand jury, and
+otherwise corruptly obstructed and impeded said official proceeding; in violation of Title 18, United
+States Code, Section 1512(c).
+JEFFREY H. SLOMAN
+UNITED STATES ATTORNEY
+ASSISTANT UNITED STATES ATTORNEY
+
+
+Case 9:10-cr-80015-KAM Document 15 Entered on FLSD Docket 01/29/2010 Page 2 of 4
+UNITED STATES OF AMERICA
+VS.
+CASE NO. 10-80015 -CR-MARRA/HOPKiNS
+CERTIFICATE OF TRIAL ATTORNEY•
+ALFREDO RODRIGUEZ,
+Defendant. /
+Court Division: (Select One)
+=
+Miami
+FTL
+Ker West
+Superseding Case Information:
+New Defendant(s)
+Number of New Defendants
+Total number of counts
+Yes
+No -
+FTP
+I do hereby certify that:
+1.
+of probate winese and the legal competites or te it mentiona on aracted here or
+2.
+Contin are that he near any pee in ta rate the man e rese are
+vot, Title 28 U.S.C. Section 3161
+3.
+Interpreter:
+(Yes or No) - No
+List language and/or dialect
+4.
+5.
+This case will take 4 days for the parties to try.
+(Chack only ona)
+Plea on check appropriate category and type of offense listed below:
+0 to 5 days
+Petty
+6 to 10 days
+Minor
+11 to 20 days
+Misdem.
+21 to 60 days
+51 days and over
+Felony
+8.
+Has this case been previously filed in this District Court? (Yes or No)
+No
+If yes:
+Judge:
+- Case No.
+(Attach copy of dispositive order)
+Has a complaint been filed in this matter?
+If yes:
+Magistrate Case No.
+Related Miscellaneous numbers:
+(Yes or No) - Yes
+09-8308-LR.J
+Defendants) in federal custody as of
+Defendants) in state custody as of
+Rule 20 from the
+District of
+Is this a potential death penalty case? (Yes or No) _
+No
+7.
+Do to 142e rom a matter pending in the Norhen Region of the U.S. Atomey's Ofice
+Dresser frater pending in the Central Region of the U. Attorney's Office
+*Penalty Sheets) attached
+REV. 4/8/08
+
+
+Case 9:10-cr-80015-KAM Document 15 Entered on FLSD Docket 01/29/2010 Page 3 of 4
+PENALTY SHEET
+Defendant's Name: ALFREDO RODRIGUEZ
+Case No.:_
+10 - 80015-CR-MARRA/ HOPKiNS
+Count 1:
+18 U.S.C. § 1512(c)
+Obstruction of Justice
+"Max. Penalty: 20 years Imprisonment: 3 years Supervised Release; $250.000 Fine
+Count :
+*Max. Penalty:
+Count:
+*Max. Penalty:
+•Refers only to possible term of incarceration, does not include possible fines, restitution, specia
+assessments, parole terms or forfeitures that may be applicable
+KEV. 12/1216
+
+
+Case 9:10-cr-80015-KAM Document 15 Entered on FLSD Docket 01/29/2010 Page 4 of 4
+AO 455 (Rer. 01:09) Waiver of an Indictment
+for the
+Southern District of Florida
+United States of America
+1.
+Alfredo Rodriguez
+Defendur
+CAsE No. 10-80015-CR-MARRA/
+HOPKiNS
+WAIVER OF AN INDICTMENT
+understand that I have been accused of one or more offenses punishable by imprisonment for more than of
+car. I was advised in open court of my rights and the nature of the proposed charges against me
+After receiving this advice, I waive my right to prosecution by indictment and consent to prosecution by
+information.
+Date:
+Defendant's signature
+Signature of defendami"s attorney
+DAVE LEE BRANNON, AFPD
+Printed nure of defendam's attorney
+Judge's signarure
+Judge's printed nume and title
+
+
+AO 455 (Rev. 01/09) Waiver of an Indictment
+for the
+Southern District of Florida
+United States of America
+V.
+Alfredo Rodriguez
+Defendant
+Case No. 10-80015-CR-MARRA/HOPKINS
+WAIVER OF AN INDICTMENT
+I understand that I have been accused of one or more offenses punishable by imprisonment for more than one
+vear. I was advised in open court of my rights and the nature of the proposed charges against me
+After receiving this advice, I waive my right to prosecution by indictment and consent to prosecution by
+information.
+Date:
+Defendant's signature
+Signature of defendant's attorney
+DAVE LEE BRANNON, AFPD
+Printed name of defendant's attorney
+Judge 's signature
+Judge's printed name and title
+
+
+Memorandum
+Subject
+Prosecution Memorandum
+In re Operation Stolen Globe: Request to Issue
+Subpoena to Cooperating Attorney
+Jeffrey Sloman
+Acting U.S. Attorney
+Date
+October 28, 2009
+From
+Assistant U.S. Alicytey
+Acting First Assistant U.S. Attorney
+Acting Chie
+Criminal Division
+Deputy Chief
+Criminal Division
+Chief
+Northern Division
+This memorandum seeks permission to issue a subpoena to attorney Brad Edwards
+("Edwards") for records relating to the investigation Operation Stolen Globe. Edwards is
+willing to produce all of these items voluntarily. For liability reasons, his firm prefers that
+we issue a subpoena. Likewise, I would prefer to proceed by subpoena to maintain the
+formality and secrecy of the grand jury procedures.
+Background of the Investigation
+As 1 have previously discussed with some of you, this investigation arises from
+obstruction of the Operation Leap Year investigation. Alfredo Rodriguez ("Rodriguez") was
+considered a significant witness in that investigation. Rodriguez had been employed by the
+target of the Operation Leap Year investigation and had worked in the home in Palm Beach
+where the criminal sexual activity had taken place. Rodriguez admitted seeing underage girls
+in the home, paying money to them, and delivering flowers to girls at one of the local high
+schools. Rodriguez was interviewed by the Palm Beach Police Department and was asked
+to produce documents. Rodriguez turned over some documents. When the case was adopted
+for federal investigation, he was interviewed again by the FBI in January 2007. He was
+cooperative with the agents and was not, therefore, subpoenaed to the grand jury.
+
+
+As you all know, the Operation Leap Year investigation ended with the Non-
+Prosecution Agreement between Jeffrey Epstein and the U.S. Attorney's Office for the
+Southern District of Florida. No federal charges were filed against Epstein or any of his coconspirators. While there were a multitude of reasons for that decision, one sentiment was
+that federal nexus was not as strong as it normally is because there was no evidence of e-mail
+contact or interstate travel by victims.
+Moving forward more than two years to the present day, Brad Edwards is currently
+representing a few of the victims who were identified by the U.S. Attorney's Office and the
+FBI during Operation Leap Year.' Edwards has filed individual lawsuits against Epstein -
+some in state court and some in federal court. Other identified victims have also filed suit,
+and a number of those lawsuits are consolidated in front of Judge Marra in the U.S. District
+Court. In connection with those federal civil suits, a subpoena was issued to Alfredo
+Rodriguez to appear for a deposition and to produce documents.? Rodriguez appeared for
+deposition and produced documents as an unrepresented party on July 29 and August 7,
+2009. Edwards was one of the attorneys present who questioned Rodriguez. Edwards
+reports that Rodriguez was very forthcoming about the criminal sexual activity that was
+occurring at Epstein's home.? After the deposition, Rodriguez sent an email to Brad Edwards
+asking to speak with him. Rodriguez then called Edwards and told him that he had the "holy
+grail" of information regarding all of the sexual activity that Epstein had been engaging in.
+Rodriguez claimed to have a list of more than 500 names of young girls who had been to
+Epstein's houses in Palm Beach, New York, Paris, New Mexico, and the Virgin Islands.
+Rodriguez also claimed to have emails and evidence that the girls had been transported
+interstate by Epstein. If Rodriguez does have this evidence, it would have been relevant and
+highly material to the Operation Leap Year grand jury investigation.
+Edwards asked Rodriguez for the evidence. Rodriguez said that he would give the
+'It should be noted that Edwards filed suit against the United States on behalf of these victims
+asserting claims that the Office violated their statutory victims' rights by not providing them with
+notice and an opportunity to be heard before entering into the Non-Prosecution Agreement. That
+case remains open but dormant.
+"This subpoena, the deposition transcript, and the documents Rodriguez produced are
+the bulk of what is sought by the proposed subpoena to Attorney Edwards.
+'From the description, it appears that he disclosed far more during the deposition than
+he did to the Palm Beach Police and the FBI, but I cannot make that determination without
+reviewing the actual deposition.
+-2-
+
+
+evidence to Edwards, but only if Edwards would pay him $50,000 cash. Edwards refused.
+This was in approximately mid-August 2009. At that time, Edwards called me and presented
+this to me as a "hypothetical" scenario without disclosing who the witness was. I told him
+that, if the witness really had withheld that information, it was obstruction of justice and we
+would want to do an undercover operation to obtain the evidence and prosecute him for
+obstruction. Edwards said that he would think about it and get back to me, but I never heard
+any more.
+On October 22nd, I heard again from Edwards. He disclosed that the witness was
+Rodriguez, and that he had received several more calls from him. During those calls, which
+were witnessed by one of the law firm's private investigators, Rodriguez again offered to
+provide the evidence to Edwards in exchange for $50,000. Edwards repeatedly advised
+Rodriguez that it was illegal to buy evidence and tried to convince Rodriguez to turn it over
+without payment in accordance with the subpoena. Rodriguez reportedly referred to the
+information as his "insurance policy" and said, "I didn't turn it over to the police when they
+asked, or to the FBI, but I will give it to you because you touched my heart during the
+deposition." Edwards asked him why Rodriguez hadn't turned the information over to law
+enforcement and Rodriguez said that he had worked to compile the information and it was
+his "property" and he wasn't going to give it away for nothing.
+Edwards reported that, during the last conversation, when he told Rodriguez again that
+he wouldn't buy the evidence because it was illegal, Rodriguez said that he understood that
+Edwards wouldn't pay for it, so he was willing to deal with any "third party" that Edwards
+wanted him to. Edwards said that he realized that he would never be able to convince
+Rodriguez to turn the evidence over in accordance with the subpoena, and re-approached law
+enforcement.
+FBI agents who were not involved in Operation Leap Year and I met with Edwards,
+his investigator, and another attorney from their firm and did a debriefing. Today, Edwards
+made a controlled call to the target and introduced the undercover agent. It is not expected
+that Edwards will be further involved in the investigation, except to turn over the items that
+I am seeking in the subpoena.
+ITEMS CALLED FOR BY THE SUBPOENA
+The subpoena seeks three items:
+The subpoena duces tecum that was issued to Rodriguez for his deposition.
+The videotape of the deposition, transcript, and documents produced in
+-3-
+
+
+response to the subpoena.
+3.
+The email correspondence between Edwards and Rodriguez.
+The first two items are necessary to determine what was asked for and received and
+to see whether Rodriguez made statements contrary to what he told federal agents. The email
+correspondence is needed to see the beginning of the contact between Edwards and
+Rodriguez and to defeat any claim of "entrapment."
+None of the items contain any privileged information. The first item is a subpoena
+issued on behalf of the U.S. District Court and served by an attorney upon a non-party
+witness. The second items are a deposition that was attended by a number of attorneys
+representing parties and our target, who was the witness. There was no attorney-client
+relationship between any of the persons present at the deposition and no private privileged
+conversation. The documents produced by Rodriguez also are not privileged because he
+produced them to attorneys for a number of different parties in response to a lawfully issued
+subpoena. The third item also is not privileged because it involves correspondence between
+an attorney and a third party.
+Edwards has expressed his willingness to produce all of these items and is not
+asserting any claim of privilege or confidentiality.
+Conclusion
+For the foregoing reasons, I recommend the issuance of the attached subpoena.
+-4-
+EFT A00179468
+
+Resource Manual No. 264 Form -- Request for Authorization To Issue A Subpoena To An
+Attorney for Information Relating To Representation of a Client
+To:
+From:
+Southern District of Florida
+Criminal Division
+1301 New York Ave, N.W.
+Washington, D.C. 20005
+PHONE No. (202)
+TELEFAX No.
+PHONE No.
+FAX No.
+1) Name of Attorney Witness: _Brad. Edwards, Esq.. Law Firm of Rothstein Rosenfeldt Adler
+PLEASE NOTE: THE ATTORNEY IS COOPERATING WITH THE AUTHORITIES
+IN INVESTIGATING A CRIME THAT DOES NOT INVOLVE A CLIENT AND HE
+IS WILLING TO PRODUCE THE REQUESTED ITEMS. HIS FIRM HAS
+REQUESTED THAT WE PROCEED VIA SUBPOENA.
+2) District:
+Southern District of Florida
+3) Date by which subpoena needed: October 30, 2009
+4) Nature of Subpoena: ( ) Trial
+(X) Grand Jury
+5) Name of Case or Investigation:
+Operation Stolen Globe
+6) Nature of Case: False Statements to Federal Agent, Obstruction of Justice: Misprision of a Felony
+(X) Criminal
+() Civil
+_ Tax _ Forfeiture
+- Other
+7) (a) Name of Client:
+(b) Status of Client:
+n/a
+() Defendant in Criminal Case
+() Defendant in Civil Case
+() Subject
+() Target of Grand Jury Investigation
+(X) Other Identified Victim of a Closed Federal Grand Jury Investigation
+
+
+8)
+9)
+10)
+11)
+Relationship of attorney witness to subjects or defendants or targets (specifically
+indicate whether the witness currently represents any defendants or subjects in the
+matter in which the subpoena is to be issued):
+None. Attorney approached the government because a witness who had been interviewed
+by the FBI in connection with the federal grand jury investigation (which is currently closed)
+had approached the attorney to "sell" him information related to civil suits that have arisen
+from the criminal activity underlying the grand jury investigation.
+The attorney's client was an identified victim in the underlying criminal investigation. The
+attorney represents the victim in a civil suit seeking damages for sexual exploitation. She
+is not a subject, defendant, or target or any open investigation. And the subpoena does not
+seek any privileged information.
+Information sought by the subpoena (if subpoena calls for testimony, indicate the
+nature of the anticipated testimony):
+At this time, the subpoena seeks only:
+1.
+A copy of the deposition of the target of the investigation, Alfredo Rodriguez, and
+any materials that Rodriguez produced pursuant to the civil subpoena.
+2.
+A copy of the civil subpoena duces tecum.
+3.
+Copies of any emails between the attorney and the target.
+Summary of case or proceeding (include a citation to the charges pending or under
+investigation in a criminal case:
+The investigation arose from the tip received from the attorney. We are arranging to make
+controlled calls with the target and plan to do a meeting to do an undercover "purchase" of
+this evidence. The target was interviewed by state law enforcement who asked him to turn
+over relevant documents and then was interviewed by FBI who also asked for all relevant
+information. The target never produced this information to law enforcement. The
+information also was called for by the federal civil subpoena duces tecum and was not
+produced. Crimes under investigation are 18 U.S.C. §§ 4, 402, 1001, 1501, and 1512.
+Relevancy of the information sought to the case or proceeding:
+The civil subpoena duces tecum, deposition transcript, and materials produced in response
+to the subpoena are necessary to determine whether they contain evidence of obstruction of
+the federal grand jury investigation separate and apart from the evidence that he intends to
+2
+
+
+"sell." They also are necessary to show that the target was served with a legitimate legal
+command to produce the materials that he is now attempting to "sell."
+The e-mail between the attorney and the target are necessary to establish the initial contact
+and overture to "sell" the evidence to the attorney.
+12)
+Factual statement of the need for the information to the successful completion of the
+case or proceeding:
+The requested e-mail information is necessary to show a jury how the crime first came to
+light, and how the target began making overtures to sell what he knew was information
+relevant to the criminal investigation to the person he thought could be the highest bidder.
+The requested deposition, documents, and subpoena are evidence of prior false statements
+of the target and the target's response to legal process.
+13) Are there alternative sources for the information?
+(X) Yes (X) No
+There are no other sources for the emails. There are other sources for the civil subpoena,
+deposition, and documents produced pursuant to subpoena.
+14)
+If there are alternative sources for the information, have attempts been made to obtain
+information from them:
+() Yes, but with no success.
+( ) Yes, with success. Explain below why the subpoena is necessary.
+(X) No. Explain below why the alternative sources have not been pursued.
+The other sources for the information would be other attorneys in the same set of civil
+lawsuits, all of which raise the same issues raised herein. Also, disclosure to them could
+compromise the undercover operation. It is possible that a court reporter would have a copy
+of the deposition transcript, but not the documents produced in response to the subpoena.
+It is possible that the target was provided with a copy of his deposition transcript, but
+providing him with a subpoena would inform him that he is the subject of an investigation
+and disclose the undercover operation.
+3
+
+
+15)
+Statement as to adverse impact on attorney client relationship:
+(a)
+Has the witness been asked to supply the requested information voluntarily?
+(X) Yes () No Explain:
+The attorney's firm is concerned about liability issues and feels that
+the most prudent approach is to produce the documents in response
+to a subpoena.
+(b)
+Will witness be disqualified from representation of the client as a result of the
+subpoena being issued and enforced?
+() Yes (X) No Explain: Not applicable. The target is not the attorney's client
+(c)
+Is witness a target or subject of any investigation or is there a basis to believe
+that witness will become one:
+() Yes (X) No If yes, Explain:
+16)
+Basis for belief that information is not privileged:
+The items sought do not contain any attorney-client communications. They all involve
+communications between the attorney and a third party (our target).
+17) Requestor has considered applicable rules of professional conduct (X) Yes () No
+18)
+Attach copy of subpoena.
+ignature of Requestol
+Signature of United States Attorney
+Revised September 2007
+4
+
+
+GAO110 (Rev. 04/07) Subpoena to Testify Before Grand Jury
+TO:
+Bradley Edwards, Esq.
+Rothstein Rosenfeldt Adler
+401 E Las Olas Blvd Ste 1650
+Fort Lauderdale, Florida 33301
+SUBPOENA TO TESTIFY
+BEFORE GROND8-II03 (WPB) HOSG-001
+SUBPOENA FOR:
+• PERSON
+• DOCUMENTS) OR OBJECTS)
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date, and time specified below.
+PLACE
+COURTROOM
+Grand Jury Room
+United States District Court
+701 Clematis Street
+West Palm Beach, Florida 33401
+DATE AND TIME
+11/5/2009 10:30 am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):*
+. All subpoenas duces tecum issued by any party to Alfredo Rodriguez in connection with any civil suit pendin
+gainst Jeffrey Epstein in the United States District Court for the Southern District of Florid
+.. All recordings of the deposition(s) of Alfredo Rodriguez in connection with any civil suit pending against Jeffre
+ipstein in the United States District Court for the Southern District of Florida, including transcripts, videorecordings
+3. All documents produced by Alfredo Rodriguez in response to all subpoenas duces tecum or other verbal or written
+requests in connection with any civil suit pending against Jeffrey Epstein in the United States District Court for the
+Southern District of Florida.
+4. All e-mail or other correspondence between Brad Edwards and Alfredo Rodriguez.
+N.S. COURTS
+• Please see additional information on revers
+This subpoena shall remain in friet unil yet.
+behalf of the court
+leavello depart by the court or by an officer acting on
+10/22/2009
+(By) Deputy Clerk
+This subpoena is issued on application
+NAME, ADDRESS AND PHONE NUMBER OF ASSISTANT U.S. ATTORNEY
+• Assistant U.S. Attorney
+500 South Australlan Avenue, Suite 400
+West Palm Beach, Florida 33401-6235
+* If not applicable, enter "none".
+
+
+NOU-05-2009 14:24
+CRM DIV KEENEY
+202 307 0877
+P.02
+U.S. Department of Justice
+Criminal Division
+Assistant Attorney General
+Washington, D.C. 20530
+NOV - 5 2009
+Jeffrey H. Sloman
+Acting United States Attorney
+Southern District of Florida
+Miami, Florida 33132
+Attention:
+Re:
+Assistant United States Attorney
+Subpoena to Brad Edwards, Esq., Law Firm of Rothstein, Rosenifeldt,
+Adler
+Dear Mr. Sloman:
+I received your request to issue the above-referenced subpoena related to Operation
+Stolen Globe. After review, I authorize you to issue the subpoena as set out in your request in
+this matter and in any further proceedings resulting therefrom or ancillary thereto as outlined in
+U.S.A.M. 9-13-410.
+Sincerely,
+Lanny A. Breuer
+Assistant Attorney Gerieral
+Deputy Assistant Attorney General
+Criminal Division
+TOTAL P.02
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/e282c87b721c40339c0a864bff6a326b7a2c8e0237eb9b62befbb08dc9ba96ac.receipt.json b/vision-fixhub/ds9-unparsed-05/e282c87b721c40339c0a864bff6a326b7a2c8e0237eb9b62befbb08dc9ba96ac.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4ac26521331d63eeccc2677c46b4948bfc23f976
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e282c87b721c40339c0a864bff6a326b7a2c8e0237eb9b62befbb08dc9ba96ac.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -937,
+  "dataset": "marble-joined",
+  "doc_id": "e282c87b721c40339c0a864bff6a326b7a2c8e0237eb9b62befbb08dc9ba96ac",
+  "engine": "marble-apple-vision",
+  "event_count": 29,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "cd3533d370728eab29370b31e535647993114514c2fa53ce3236f755ab8511dd",
+  "output_sha256": "a00ecc8c04eb76539051145a287d8460ad1cf2791dec930a1006c5ffac0744c8",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e34bf7467832267d7d03b84cdec7833c43c759b22311b8179729d75b4f21c73a.md b/vision-fixhub/ds9-unparsed-05/e34bf7467832267d7d03b84cdec7833c43c759b22311b8179729d75b4f21c73a.md
new file mode 100644
index 0000000000000000000000000000000000000000..a1efdb44efece28ec290b2ffab774d6403c0b563
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e34bf7467832267d7d03b84cdec7833c43c759b22311b8179729d75b4f21c73a.md
@@ -0,0 +1,150 @@
+(USAFLS)
+To:
+Cc:
+Subject:
+Spencer Kuvin < HI
+Friday, December 12, 2008 8:48 AM
+| (USAFLS)
+Mitch Kitroser
+Re: Follow-up re work release
+Thank you I will check with my clients asap and get back to you. Thank you.
+Spencer T. Kuvin
+Leopold~Kuvin, P.A.
+B-99
+On Dec 11, 2008, at 6:43 PM, "L
+wrote:
+KUSAFLSI)" <
+Gentlemen:
+I wanted to provide you with another piece of information regarding Mr. Epstein's work
+release. I understand that Mr. Epstein must wear a GPS unit that monitors his location. That
+GPS unit can be programmed with "Exclusionary Zones," which activates some sort of alarm if
+Mr. Epstein tries to enter that "zone." The addresses of victims' homes, workplaces, and schools
+can be added to that list of "Exclusionary Zones." Obviously that would require you to disclose
+those addresses to the Sheriff's Office. I do not know if that would also result in the disclosure
+of the information to Mr. Epstein or his attorneys. If, after consulting with your clients, they
+lecide that they would like to have their addresses programmed into the GPS unit, please Contac
+Captain
+• As 1 mentioned in my letter, Captain SI
+can be reached at
+I sent a letter to Captain I today reminding him of my earlier request to be kept up-to-date
+on any changes in Mr. Epstein's custody status so that I may inform all of you in a timely
+manner.
+Thank you.
+MILI BI
+36
+
+
+(USAFLS)
+To:
+(USAFLS) <
+Tuesday, December 30, 2008 10:42 AM
+ROBERT C. JOSEFSBERG: KATHERINE W. EZELL: E
+Cc:
+Subject:
+(USAFLS)
+RE: Jeffrey Epstein
+Not exactly. Mr. Epstein is only supposed to go directly from jail to work and back. If he deviates from that
+route, right now no alarms will go off unless, during that deviation, he enters an exclusionary zone. If, for
+example, his driver breaks the rules and takes him for a tour of Royal Palm Beach while en route to Mr.
+Goldberger's office, and that tour takes him near one of the programmed addresses, the alarm will go off. I
+don't know what the radius is for the exclusionary zone, but, if the alarm were to go off, Mr. Epstein would
+know that he is near one of the prohibited places, but wouldn't know whose address it was and whether the
+address was their home, place of work, or place of study.
+If you need more detail, I will need to reach out to Captain I
+| and I am happy to do so.
+Thank you.
+From: ROBERT C. JOSEFSBERG D
+Sent: Monday, December 29, 2008 5:32 PM
+To:
+(USAFLS): KATHERINE W. EZELLA
+Cc:
+(USAFLS)
+Subject: Re: Jeffrey Epstein
+If I understand you, Epstein will know "the exclusionary zone" - he has to know it in order to stay away from it - but he won't know
+whose home, office, or hangout it is. Am I correct?
+-- Original Message -..-
+Cc:
+(USAFLS) 4
+Sent: Mon Deo 29 17:16:03 2008
+Subject: Jeffrey Epstein
+Dear Messrs, Josefsberg, Edwards, Scarola, Herman, Kuvin, Dutko, and Willits and Ms. Ezell:
+1
+
+
+Ms. Ezell contacted me to inquire whether Mr. Epstein will be told of the names or addresses of any victims who ask to be added to
+Mr. Epstein's "exclusionary zones" on his GPS system. Captain
+from the Palm Beach Sheriff's Office informs me that the
+information will remain confidential and will not be provided to Mr. Epstein.
+Captain
+has asked that all such requests go through me rather than directly to him. If any of your clients would like to have
+their work, school, or home addresses added to the list of exclusionary zones, please let me know.
+Thank you.
+2
+
+
+L (USAFLS)
+To:
+Subject:
+KATHERINE W. EZELL 4
+Monday, December 29, 2008 6:11 PM
+I. (USAFLS)
+RE:
+Thanks, Marie.
+From: [
+.. (USAFLS) [mallto
+Sent: Monday, December 29, 2008 5:05 PM
+To: KATHERINE W. EZELL
+Cc: Amy Ederi
+Subject: RE:
+right now.
+Hi Kathy and Amy - I hope all is well with you. I see from the paper that you are in a firestorm of your own
+I just spoke with Captain|
+. He said that if you provide the address info, it will not be disclosed to Epstein
+or his people. Epstein is accompanied only by his private driver when he goes to and from the jail, although
+PBSO has his travel routes programmed in to his GPS monitor so, if he deviates from that route, they will know
+if they check the monitor when he returns.
+Captain
+has asked that all requests go through me so he knows who is legit and who isn't, so if anyone
+wants their addres(es) added, please let me know. I am going to send an e-mail to all of the plaintiffs' attorneys
+with this info.
+From: KATHERINE W. EZELL [mailto
+Sent: Monday, December 29, 2008 1:44 PM
+To:
+1. (USAFLS)
+Cc: Amy Ederi
+Subject:
+Dear Marie, This is a message I tried to send on the 20th. I got a notification back that it did not go through, so I'm trying
+this different address.
+In your notification letter about JE's work release that you wrote to the victims you mentioned the possibility of their
+notifying you if they wanted any of their addresses made off limits on his mechanical device that restricts him. First, if he
+is only going to and from that office address, why does he need to be mechanically otherwise restricted? Second, should
+one of the victims want to designate an address where she lives or works to be programmed as off limits, is it possible for
+him to then have access to the name of the victim and the specific location from which he is being restricted?
+Wishing you a peaceful and happy holiday! Kathy
+3
+
+
+- (USAFLS)
+To:
+ROBERT C. JOSEFSBERG 4
+Monday, December 29, 2008 5:32 PM
+L. (USAFLS); KATHERINE W. EZELL;
+(USAFLS)
+CC:
+Subject:
+Re: Jeffrey Epstein
+'I understand you, Epstein will know "the exclusionary zone" - he has to know it in order to stay away from it - but he won't kno
+hose home, office, or hangout it is. Am I correct
+--- Original Message **.
+I (USAFLS) <
+Cc:
+(USAFLS) 4
+Sent: Mon Dec 29 17:16:03 2008
+Subject: Jeffrey Epstein
+Dear Messrs. Josefsberg, Edwards, Scarola, Herman, Kuvin, Dutko, and Willits and Ms. Ezell:
+s. Ezell contacted me to inquire whether Mr. Epstenn w
+Mr. Epstein's "exclusionary zones" on his GPS system. Captain
+information will remain confidential and will not be provided to Mr. Epstein.
+has asked that all such requests go through me rather than directly to him. If any of your clients would like to have
+their work, school, or home addresses added to the list of exclusionary zones, please let me know.
+Thank you.
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/e34bf7467832267d7d03b84cdec7833c43c759b22311b8179729d75b4f21c73a.receipt.json b/vision-fixhub/ds9-unparsed-05/e34bf7467832267d7d03b84cdec7833c43c759b22311b8179729d75b4f21c73a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..121f8a73c8d0999b7762e6336cddc72f2d472e4b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e34bf7467832267d7d03b84cdec7833c43c759b22311b8179729d75b4f21c73a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -235,
+  "dataset": "marble-joined",
+  "doc_id": "e34bf7467832267d7d03b84cdec7833c43c759b22311b8179729d75b4f21c73a",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "45c0e2248baba0368243ff9625940d18733e14b4dfe66443484743c9ec8c804e",
+  "output_sha256": "e2082d6e8e878072fb96015b13d0c1923be3c6d56002a24e6439a636aaab9c64",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e477480839e07ff5864bb53d9ec4e3c802c24527f30d59e6b60cc626009a8a38.md b/vision-fixhub/ds9-unparsed-05/e477480839e07ff5864bb53d9ec4e3c802c24527f30d59e6b60cc626009a8a38.md
new file mode 100644
index 0000000000000000000000000000000000000000..fb3c846fd826c75b0cb7f12532bb1c2b44ce27cb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e477480839e07ff5864bb53d9ec4e3c802c24527f30d59e6b60cc626009a8a38.md
@@ -0,0 +1,153 @@
+Sent
+Subject:
+Friday, February 01, 2008 8:25 AM
+w. epstem
+Everyone, keep your fingers crossed.
+Maybe we will get some movement today.
+(See below)
+Assistant U.S. Attorney
+500 S. Australian Ave,
+Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+-Original Message-
+Sent:
+Subjec
+2008 9:07 PM
+epstein
+Thanks
+I reached out today tol
+Sent from my BlackBerry Wireless Handheld
+•
+to do just that. Let's chat tomorrow.
+Original Message
+AFLS)
+(USAFLS); Acosta, Alex (USAFLS)
+Sent: Thu Jan 31 19:33:12 2008
+Subject: Epstein
+Hi Jeff and Alex - We just finished interviewing three of the girls. I wish you
+could have been there to see how much this has affected them.
+one girt broke down sobbing so that we had to stop the interview twice within a
+20 minute span. She regained her composure enough to continue a short time, but
+she said that she was having nightmares about Epstein coming after her and she
+started to break down again, so we stopped the interview.
+The second girl, who has a baby girl of her own, told us that she was very upset
+about the 18 month deal she had read about in the paper. She said that 18 months
+was nothing and that she had heard that the girls could get restitution, but she
+would rather not get any money and have Epstein spend a significant time in jail.
+The FBI's victim-witness coordinator attended and she has arranged for counseling
+for several of the girls.
+1771
+P-014569
+
+
+Please reach out to Alice to make her decision. These girls deserve so much
+better than they have received so far, and I hate feeling that there is nothing I
+We have four more girls coming in tomorrow. Can I persuade you to attend?
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+1772
+P-014570
+
+
+Sent
+Subject:
+Thursday, January 31, 2008 9:07 PM
+S)
+Thanks Marie. I reached out today to Drew to do just that. Let's chat tomorrow.
+Sent from my BlackBerry Wireless Handheld
+Original Message
+; Acosta,
+Alex (USAFLS)
+Sent: Thu Jan 31 19:33:12 2008
+Subject: Epstein
+Hi and Alex - We just finished interviewing three of the girls. I wish you
+could have been there to see how much this has affected them.
+One girl broke down sobbing so that we had to stop the interview twice within a
+20 minute span. She regained her composure enough to continue a short time, but
+she said that she was having nightmares about Epstein coming after her and she
+started to break down again, so we stopped the interview.
+The second girl, who has a baby girl of her own, told us that she was very upset
+about the 18 month deal she had read about in the paper. She said that 18 months
+was nothing and that she had heard that the girls could get restitution, but she
+would rather not get any money and have Epstein spend a significant time in jail.
+The FBI's victim-witness coordinator attended and she has arranged for counseling
+for several of the girls.
+Please reach out to Alice to make her decision. These girls deserve so much
+better than they have received so far, and I hate feeling that there is nothing I
+can do to help them.
+We have four more girls coming in tomorrow. Can I persuade you to attend?
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+1773
+P-014571
+
+
+Sent:
+Subject:
+Thunder anar 31205307 M
+Thanks Marie. I reached out today to Drew to do just that. Let's chat tomorrow.
+Sent from my BlackBerry Wireless Handheld
+Original Message
+(USAFLS)
+(USAFLS); Acosta, Alex (USAFLS)
+Sent: Thu Jan 31 19:33:12 2008
+Subject: Epstein
+Hi Jeff and Alex - We just finished interviewing three of the girls. I wish you
+could have been there to see how much this has affected them.
+One girl broke down sobbing so that we had to stop the interview twice within a
+20 minute span. She regained her composure enough to continue a short time, but
+she said that she was having nightmares about Epstein coming after her and she
+started to break down again, so we stopped the interview.
+The second girl, who has a baby girl of her own, told us that she was very upset
+about the 18 month deal she had read about in the paper. She said that 18 months
+was nothing and that she had heard that the girls could get restitution, but she
+would rather not get any money and have Epstein spend a significant time in jail.
+The FBI's victim-witness coordinator attended and she has arranged for counseling
+for several of the girls.
+'lease reach out to Alice to make her decision. These girls deserve so mucl
+etter than they have received so far, and I hate feeling that there is nothing :
+can do to help them.
+We have four more girls coming in tomorrow. Can I persuade you to attend?
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+1774
+P-014572
+
+
+Sent:
+Subject:
+(USAFLS)
+Thursday, January 31. 2008 7:33 PM
+D: Acosta, Alex (USAFLS)
+Epstein
+Hi L and Alex - We just finished interviewing three of the girls. I wish you could have been there to see how
+much this has affected them.
+One girl broke down sobbing so that we had to stop the interview twice within a 20 minute span. She regained
+her composure enough to continue a short time, but she said that she was having nightmares about Epstein
+coming after her and she started to break down again, so we stopped the interview.
+The second girl, who has a baby girl of her own, told us that she was very upset about the 18 month deal she
+had read about in the paper. She said that 18 months was nothing and that she had heard that the girls could get
+restitution, but she would rather not get any money and have Epstein spend a significant time in jail.
+The FBI's vietim-witness coordinator attended and she has arranged for counseling for several of the girls.
+Please reach out to Alice to make her decision. These girls deserve so much better than they have received so
+far, and I hate feeling that there is nothing 1 can do to help them.
+We have four more girls coming in tomorrow. Can 1 persuade you to attend?'
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 56l 209-1047
+Fax 561 820-8777
+Tracking:
+1779
+P-014573
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/e477480839e07ff5864bb53d9ec4e3c802c24527f30d59e6b60cc626009a8a38.receipt.json b/vision-fixhub/ds9-unparsed-05/e477480839e07ff5864bb53d9ec4e3c802c24527f30d59e6b60cc626009a8a38.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3a9fc8a05e71b034e650083497b59f7a894791dd
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e477480839e07ff5864bb53d9ec4e3c802c24527f30d59e6b60cc626009a8a38.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -231,
+  "dataset": "marble-joined",
+  "doc_id": "e477480839e07ff5864bb53d9ec4e3c802c24527f30d59e6b60cc626009a8a38",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "f55df3fdda24adbb1264947c04ee3cf744446e91300a785ade90273631982295",
+  "output_sha256": "50c2fc065ff77c8e2ecb92e0930b15c681ae8cbbaea767bc47c6eb76935fc4db",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e49e9c1beec4752e5b5266425a4c2f41b00afb34330f69d8e0f2bcbdcf1a9d8c.md b/vision-fixhub/ds9-unparsed-05/e49e9c1beec4752e5b5266425a4c2f41b00afb34330f69d8e0f2bcbdcf1a9d8c.md
new file mode 100644
index 0000000000000000000000000000000000000000..d9677d6546e717ee4301982e2cb3b7e8b9894c1f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e49e9c1beec4752e5b5266425a4c2f41b00afb34330f69d8e0f2bcbdcf1a9d8c.md
@@ -0,0 +1,56 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+West Palm Beach, FL 33401
+500 South Australian Ave., Suite 400
+Facsimile:
+July 22, 2008
+VIA FACSIMILE
+Michael R. Tein, Esq.
+Lewis Tein, P.L.
+3059 Grand Avenue, Suite 340
+Coconut Grove, FL 33133
+Re: Jeffrey Epstein
+Dear Mr. Tein:
+In response to your letter of July 21, 2008, the United States hereby provides notice that
+the United States Attorney has determined, based upon reliable evidence, that, during the period
+of the Non-Prosecution Agreement, Jeffrey Epstein has willfully violated the conditions of the
+Agreement.
+In particular, Epstein has repeatedly denied that the victims named by the United States
+are not victims of an enumerated offense contained in Title 18, United States Code, Section 2255,
+and has attempted to stop those victims from pursuing their claims under that statute. For
+example, just yesterday, Epstein's publicist, speaking of behalf of Epstein, made the following
+statement regarding the suit brought against the United States by
+and
+The lawsuit has absolutely no merit. They're just looking for money. These women
+have lied repeatedly, and in no way shape or form were they victims. They were
+at his place freely and voluntarily. And one of them showed Epstein a fake ID.
+(July 21, 2008 New York Post article, entitled "Bid to Burn Epstein Plea," found at
+www.nypost.com/seven/07212008/gossip/pagesix/bid_to_burn_epstein_plea_120770.htm.)
+and
+• are both listed in the United States' July 10, 2008 "Final
+Notification of Identified Victims." Mr. Epstein was given more than a week to object to the
+names on the list and chose not to make any objections. Accordingly, pursuant to the terms of the
+Non-Prosecution Agreement as modified, Mr. Epstein and all of his representatives are required
+to treat
+and
+| as "victims of an enumerated offense."
+Furthermore, Mr. Epstein is frustrating the purpose of the Agreement with respect to the
+victims' ability to obtain damages. Epstein's waiver of liability regarding civil suits brought
+pursuant to 18 U.S.C. § 2255 was a key piece of consideration for the United States' willingness
+to defer its prosecution to the State of Florida. To complete his performance of his contractual
+obligations, Mr. Epstein must submit to suit under 18 U.S.C. § 2255 and admit that the Identified
+Victims are victims of an offense enumerated in that section. By seeking to stay all civil
+litigation, during what you assert is the term of the Non-Prosecution Agreement, Mr. Epstein is
+avoiding that essential contractual term.
+Accordingly, the United States Attorney's Office hereby provides notice of Mr. Epstein's
+breach of the Non-Prosecution Agreement.
+Sincerely,
+R. Alexander Acosta
+United States Attorney
+By:
+
+
+Assistant United States Attorney
+cc:|
+Esq.
diff --git a/vision-fixhub/ds9-unparsed-05/e49e9c1beec4752e5b5266425a4c2f41b00afb34330f69d8e0f2bcbdcf1a9d8c.receipt.json b/vision-fixhub/ds9-unparsed-05/e49e9c1beec4752e5b5266425a4c2f41b00afb34330f69d8e0f2bcbdcf1a9d8c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f33e3d18b70cf2067fe5a5a3c8498eea6d218455
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e49e9c1beec4752e5b5266425a4c2f41b00afb34330f69d8e0f2bcbdcf1a9d8c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "e49e9c1beec4752e5b5266425a4c2f41b00afb34330f69d8e0f2bcbdcf1a9d8c",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "2cae065cf819b1e2b391e45291f5eb35460e1bf1657bd1267d7b8a2007ad09d2",
+  "output_sha256": "a70605e1d13d50f2d07ed9dd598c6effd5ff5461f62a813c585ecf99970708fa",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e511f23b8f21f86582170fc2988c7690f066fb0c6d2929f2fd0ec29bd823a88a.md b/vision-fixhub/ds9-unparsed-05/e511f23b8f21f86582170fc2988c7690f066fb0c6d2929f2fd0ec29bd823a88a.md
new file mode 100644
index 0000000000000000000000000000000000000000..a41d85799295117a33e8addea477d74b248f80d7
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e511f23b8f21f86582170fc2988c7690f066fb0c6d2929f2fd0ec29bd823a88a.md
@@ -0,0 +1,51 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 S. Australian Ave, Ste 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+June 8, 2009
+DELIVERY BY ELECTRONIC MAIL
+Jay P. Lefkowitz, Esq.
+Kirkland & Ellis LLP
+Citigroup Center
+New York, New York 10022-4675
+Roy Black, Esq.
+Black Srebnick Kornspan & Stumpf P.A.
+Miami, FL 33131
+Jack A. Goldberger, Esq.
+Atterbury, Goldberger & Weiss. P.A.
+West Palm Beach, FL 33401-5015
+Re: Jeffrey Epstein
+Dear Jay, Roy, and Jack:
+I am writing to inform you that I have been provided with a copy of a motion filed by
+the Palm Beach Post in the Circuit Court for the Fifteen Judicial Circuit in and for Palm
+Beach County seeking to have the Non-Prosecution Agreement unsealed. The information
+that I have received is that a hearing will occur before Judge Jeffrey Colbath at 10:40 a.m.
+on June 10, 2009, at the Palm Beach County Courthouse. In accordance with the terms of
+that Agreement, I am notifying you of this development. The motion was filed in the matter
+of State of Florida |. Jeffrey Epstein. Since Mr. Epstein is a party to that criminal case, he
+has standing to contest any unsealing, while we do not. Accordingly, 1 ask that you confer
+with the State Attorney's Office regarding how you would like to proceed with the matter.
+
+
+JAY P. LEFKOWITZ, ESQ.
+Roy BLaCK, EsQ.
+Jack GolDBERGEr, ESQ.
+JUNE 8, 2009
+
+Although I have been provided with notice of the hearing, there has been no indication that
+the judge would like someone from the U.S. Attorney's Office to appear. Accordingly, no
+one from our Office plans to attend that hearing.
+I also understand that some of the plaintitts in civil suits pending against Mr. Epstein
+in state and federal court have made similar motions. Again, since Mr. Epstein is a party to
+those suits and our Office is not, he has standing to contest those motions, and, unless the
+Court asks us otherwise, we will not be involved in the litigation of those motions.
+Sincerely,
+Jeffrey H. Sloman
+Acting United States Attorney
+By:
+Assistant United States Attorney
+cc:
+Chief, Northern Division
diff --git a/vision-fixhub/ds9-unparsed-05/e511f23b8f21f86582170fc2988c7690f066fb0c6d2929f2fd0ec29bd823a88a.receipt.json b/vision-fixhub/ds9-unparsed-05/e511f23b8f21f86582170fc2988c7690f066fb0c6d2929f2fd0ec29bd823a88a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..41faf3f3e767898c5f75c4ba24d0acf22beafc62
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e511f23b8f21f86582170fc2988c7690f066fb0c6d2929f2fd0ec29bd823a88a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -35,
+  "dataset": "marble-joined",
+  "doc_id": "e511f23b8f21f86582170fc2988c7690f066fb0c6d2929f2fd0ec29bd823a88a",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "443dfd557756bce092db8f6c2196a0efef34ff81a5eb56e15f8ca038cdfd8275",
+  "output_sha256": "dff6db1334011f66a0b230b589ba8bedd053de649848600538e4ef361308fcec",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e58891ce74d137e5b1cadfff03534fb4b39a5363a5923455a587f9e309d9781d.md b/vision-fixhub/ds9-unparsed-05/e58891ce74d137e5b1cadfff03534fb4b39a5363a5923455a587f9e309d9781d.md
new file mode 100644
index 0000000000000000000000000000000000000000..7799d8816d691acd2da8a339cec58d25f19e62db
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e58891ce74d137e5b1cadfff03534fb4b39a5363a5923455a587f9e309d9781d.md
@@ -0,0 +1,207 @@
+Department of Justice
+EXECUTIVE SECRETARIAT
+CONTROL SHEET
+:
+DATE OF DOCUMENT: 7/10/2019
+DATE RECEIVED:
+7/19/2019
+FROM:
+WORKFLOW ID: 4298374
+DUE DATE: 8/5/2019
+TO:
+MAIL TYPE:
+SUBJECT:
+The Honorable Elijah E. Cummings*
+J.S. House of Representative
+Vashington. DC 2051
+DATE ASSIGNED
+07/19/2019
+OPR
+Congressional Priority
+(Rec'd from OLA via email) Ltr from Chmn Cummings, Oversight and
+Government Reform Comte and CHMN Raskin, Subcomte on Civil Rights and
+Civil Liberties, stating in light of the recently unsealed criminal indictment
+against Jeffrey Epstein for alleged acts of child abuse and sex trafficking,
+requesting the Comte be provided with an update on the status of the
+investigation of alleged misconduct by Secretary of Labor Alexander Acosta
+during his tenure as USA for the S.D. of Florida. Advising there are significant
+concerns with Secretary Acosta's actions in approving an extremely favorable
+deal for an alleged sexual predator while concealing the deal from the victims of
+Mr. Epstein's crimes, which a judge found violated the Crime Victims' Right
+Act. Mentions earlier this year, the House of Representatives passed H.R. 202,
+the Inspector General Act, on a bipartisan basis to provide the Inspector General
+with the authority to investigate allegations of misconduct by DOJ attorneys and
+the bill is currently pending in the Senate. Further, until the bill is enacted into
+law, the ability to hold a DOJ attorney accountable rests with OPR, making it
+even more important that OPR provide transparency into its findings. The Comte
+requests a briefing from OPR on its review of the Epstein matter by 07/17/2019,
+including answers to the enclosed questions. Ltr also signed by MCs Speier,
+Wasserman-Schultz and Frankel. See related corres in ECMS.
+ACTION COMPONENT & ACTION REQUESTED
+OLA
+For appropriate handling. Advise ES of any action taken.
+OAG, ODAG, CRM, EOUSA, FBI, OPR
+INFO COMPONENT:
+COMMENTS:
+FILE CODE:
+EXECSEC POC:
+BODGER Pricillia: 1
+
+
+Congress of the United States
+Washington, BC 20515
+July 10, 2019
+Director and Chief Counsel
+Office of Professional Responsibilit
+U.S. Department of Justice
+950 Pennsylvania Avenue, N. W.
+Washington, D.C. 20530
+Dear Mr. L
+In light of the recently unsealed criminal indictment against Jeffrey Epstein for alleged
+acts of child abuse and sex trafficking, we request that you provide the Committee with an
+update on the status of your investigation of alleged misconduct by Secretary of Labor Alexander
+Acosta during his tenure as United States Attorney for the Southern District of Florida.
+There are significant concerns with Secretary Acosta's actions in approving an extremely
+favorable deal for an alleged sexual predator while concealing the deal from the victims of Mr.
+Epstein's crimes, which a judge found violated the Crime Victims' Rights Act.
+In March 2005, "the parents of a 14-year old girl told Palm Beach police that she had
+been molested by Epstein at his mansion." Investigators soon discovered dozens of other girls
+in Florida who claimed to be victims of sexual abuse by Mr. Epstein between 2002 and 2005.
+By May of 2007, federal prosecutors in the Southern District of Florida had drafted a 53-page
+indictment outlining numerous federal sexual offenses committed by Mr. Epstein.?
+On September 24, 2007, Mr. Epstein reached an agreement with the United States
+Attorney's Office to "defer federal prosecution in favor of prosecution by the State of Florida."3
+Under the terms of the 2007 agreement, Mr. Epstein pleaded guilty to two charges of prostitution
+in Florida state court and served just 13 months in county jail in exchange for federal prosecutors
+' How A Future Trump Cabinet Member Gave a Serial Sex Abuser the Deal of a Lifetime, Miami Herald
+(Nov. 28, 2018) (online at miamiherald.com/news/local/article220097825.html).
+3 Jane Doe v. United States, No. 08-80736-CIV, 3-7(S.D. Fla. Feb. 21, 2019) Corder for summary
+judgment) (online at
+oversight.house.gov/sites/democrats.oversight.house.gov/files/Court%27s%20Summary%20Judgment%20Opinion
+%202-21-2019.pdf).
+" Id.
+PRINTED ON RECYCLED PAPER
+
+
+Mr.
+Page 2
+dropping, their case against him. Mr. Epstein received generous "work release privileges, which
+enabled him to leave the jail six days a week, for 12 hours a day, to go to a comfortable office
+that Epstein had set up in West Palm Beach."**
+On February 6, 2019, the Department of Justice (DOJ) announced that your office
+"opened an investigation into allegations that Department attorneys may have committed
+professional misconduct in the mannier in which the Epstein criminal matter was resolved."
+Your office committed to share its findings with Members of Congress "as appropriate."
+On February 21, 2019, United States District Judge Kenneth Marra ruled that federal
+prosecutors in the Southern District of Florida violated the Crime Victims' Rights Act by failing
+to appropriately notify Mr. Epstein's victims of the non-prosecution agreement (NPA) in 2007
+and 2008. The judge found that prosecutors worked to "conceal the existence of the NPA and
+mislead the victims to believe that federal prosecution was still a possibility."6
+The court's decision prompted several Members of Congress, including on this
+Committee, to "request that the results of the Office of Professional Responsibility's (OPR)
+review:of Secretary of Labor Alexander Acosta's decision to grant Epstein a non-prosecution
+agreement be made publicly available and provided to Congress."7
+On July 8, 2019, federal prosecutors in the Southern District of New York unsealed a
+new indictment outlining a host of additional charges against Mr. Epstein. According to the
+indictment, from 2002 to 2005, Mr. Epstein lured dozens of teenage girls to his homes in New
+York City and Palm Beach, Florida, and paid them to engage in sexual activity with him.®
+Unlike other federal employees, misconduct by DOJ attorneys acting in their capacity to
+investigate, litigate, or provide legal advice, is not subject to the independent oversight of an
+Inspector General.? Under current law, the authority to investigate attorneys is restricted to OPR.
+* How A Future Trump Cabinet Member Gave a Serial Sex Abuser the Deal of a Lifetime, Miami Herald
+(Now. 28, 2018) (online at miamiherald.com/news/local/article220097825.html).
+_, Assistant Attorney General, Department of Justice, to Senator Ben Sasse
+(Feb. 6, 2019) (online at www.sasse.senate.gov/public/_cache/files/le5c07ee-0138-4441-9e61-b6ec7037c4d5/-
+untitled-.pdf).
+6. Jane Doe v. United States, No. 08-80736-CIV, 27-28 (S.D. Fla. Feb. 21, 2019) (order for summary
+judgment) (online at
+oversight.house.gov/sites/democrats.oversight.house.gov/files/Court%27s%20Summary%20Judgment%20Opinion
+%202-21-2019.pdf).
+" Letter from Reps. Debbie Wasserman Schultz, Jackie Speier, Jamie Raskin, et al., to Attorney General
+William Barr, Department of Justice (Mar. 1, 2019) (online at
+raskin.house.gov/sites/raskin.house.gov/files/2019.03.01%20DWS%20Frankel%20Speier%20Letter%20to%20DOJ.
+® Indictment, 1-2 (July 8, 2019), United States v. Jeffrey Epstein, S.D.N.Y. (No. 19-CR-490) (online at
+int.nyt.com/data/documenthelper/1362-epstein-indictment/01e39b8c091cbeae3797/optiinized/full.pdf).
+• Inspector General Act of 1978 (5 U.S.C App.).
+
+
+Mr.
+Page 3
+Earlier this year, the House of Representatives passed H.R. 202, the Inspector General
+making it even more important that OPR provide transparency into its findings.
+For these reasons, the Committee requests a briefing from OPR on its review of the
+Epstein matter by July 17, 2019, including the following questions:
+What is the status of your investigation? If it is not complete, when does OPR
+estimate that the investigation will conclude?
+2.
+Did prosecutors in the Southern District of Florida comply with the DOJ's
+Sandinin at professional responsibility for prosecutors in their management of the
+Did your review come to any findings or conclusions about the prosecutors? Did
+your review find any evidence of misconduct by the prosecutors?
+4.
+What did your review reveal about why federal prosecutors did not inform victims
+about the resolution of the Epstein matter? Was this conduct intentional?
+What, if any, changes should be made to the Department's, policies to protect the
+rights of victims under the Crime Victims' Rights Act?
+The Committee on Oversight and Reform is the principal oversight committee of the
+House of Representatives and has broad authority to investigate "any matter" at "any time" under
+If you have any questions about this request, please contact Committee staff at
+Egil E. Cump
+Elijah E. Cummings
+Chairman
+Committee on Oversight and Reform
+Sincerely,
+Jamie/Raskin
+time Rest.
+Chairman
+Subcommittee on Civil Rights and
+Civil Liberties
+
+
+Page 4
+jaci speier
+Member of Congress
+Los Frankel
+Lois Frankel
+Member of Congress
+cc:
+The Honorable Jim Jordan, Ranking Member
+Committee on Oversight and Reform
+The Honorable Chip Roy, Ranking Member
+Subcommittee on Civil Rights and Civil Liberties
+Abilise Sat
+Debbie Wasserman-Schultz
+Member of Congress
+
+
+From:
+Sent:
+To:
+Cc:
+Subject:
+Attachments:
+Friday, July 19, 2019 10:48 AM
+Importance:
+FW: Letter attached
+2019-07-10.EEC JR. Speier Schultz Frankel to
+High
+-DOJ re Acosta Investigation.pdf
+Good morning,
+have one last request for an expedited log into IQ as l am preparing the response for OLA AAG (
+signature. Can
+he attached incoming pls be entered as soon as possible? My apologies if this is already in the process of bein
+controlled. Many thanks!
+Best,
+From:
+Sent: Friday, July 19, 2019 10:07 AM
+To:
+Subject: FW: Letter attached
+My apologies...
+From:
+To:
+Sent: Thursday, July 18, 2019 4:37 PM
+Subject: Letter attached
+Hi
+Would you please review and ready the attached letter for signature in a folder? Looking to get this to
+tomorrow morning if possible.
+Thanks!
diff --git a/vision-fixhub/ds9-unparsed-05/e58891ce74d137e5b1cadfff03534fb4b39a5363a5923455a587f9e309d9781d.receipt.json b/vision-fixhub/ds9-unparsed-05/e58891ce74d137e5b1cadfff03534fb4b39a5363a5923455a587f9e309d9781d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4ae249ab0c5236486145cd91d7148bad9d88c912
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e58891ce74d137e5b1cadfff03534fb4b39a5363a5923455a587f9e309d9781d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -72,
+  "dataset": "marble-joined",
+  "doc_id": "e58891ce74d137e5b1cadfff03534fb4b39a5363a5923455a587f9e309d9781d",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "7dba1f39ef2889b433f44744e6de826430716bffe8b6a56db9ab6f195b58dc2d",
+  "output_sha256": "4b46262170e77b36b7f5c1b97f5cd2449ec65c99b0175df334309459503492ce",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e5a72027aed7bce26eafd5564334519b9c3b1d7737a0d5bbc4f695db8984aab5.md b/vision-fixhub/ds9-unparsed-05/e5a72027aed7bce26eafd5564334519b9c3b1d7737a0d5bbc4f695db8984aab5.md
new file mode 100644
index 0000000000000000000000000000000000000000..d5415fc726cd3523151b1b9f6d78ccbcb76ec1b8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e5a72027aed7bce26eafd5564334519b9c3b1d7737a0d5bbc4f695db8984aab5.md
@@ -0,0 +1,351 @@
+United States Attorney's Office
+NEWS BRIEFING
+To:
+Acting United States Attorney
+Acting First Assistant
+Executive Assistant
+1, Special Counsel
+Acting Chief, Criminal Division
+Deputy Chief, Criminal Division
+Chief, Appellate Division
+Chief, Asset Forfeiture Division
+Chief, Civil Division
+. Acting Chief, PINS
+, Chief, Narcotics
+, Chief, Economic and Environmental Crimes Section
+1, Chief, Major Crimes Section
+, Chief, Special Prosecutions
+Acting Deputy Chief, Ft. Lauderdale
+, Deputy Chief, West Palm Beach
+Deputy Chief, Ft. Pierce
+From:
+September 22, 2009
+
+
+Southern District of Florida - Press Release
+
+The United States Attorney's Office
+Press Release
+SEBASTIAN WOMAN SENTENCED ON FRAUD CHARGES
+September 21, 2009
+FOR IMMEDIATE RELEASE
+Jeffrey H. Sloman, Acting United States Attorney for the Southern District of Florida, Guy P. Fallen,
+Special Agent in Charge, Social Security Administration, Office of Inspector General, and Amie R
+Tanchak, Resident Special Agent in Charge, U.S. Department of Defense, Defense Criminal
+Investigative Service (DCIS), announced that defendant Penelope Sharon Jordan, 61, of
+Sebastian, FL, was sentenced today on charges of theft of government funds, in violation of 18
+U.S.C. § 641. Jordan had pled guilty to this charge on June 22, 2009. U.S. District Judge Donald
+Graham sentenced Jordan to one year and one day in prison, followed by three years of supervised
+release. In addition, the Judge ordered that Jordan repay to the Government $237,876 in
+restitution for Social Security payments and military pension payments she had unlawfully received
+According to an affidavit filed by a Sebastian Police Department detective in support of an
+application for a state court search warrant, Penelope Jordan lived in a Sebastian home owned by
+her mother. In late March 2009, the Sebastian Police Department obtained the defendant's
+consent to look inside the home, where they found the dead body of her mother in a spare
+bedroom. The defendant told Sebastian Police that her mother had been dead for at least six
+years. Evidence presented during sentencing indicated that, in December 2001, Penelope Jordan
+had told her visiting sister that their mother had already died before that earlier date.
+According to in-court statements during the plea, the defendant concealed the death of her mother
+and withheld reporting her death in order to continue receiving both her mother's Social Security
+survivor's benefit payments and her mother's military pension survivor's benefit payments. From
+January 2003 through March 2009, the defendant received approximately $61,415 in Social
+Security payments, plus $176,461 of military pension benefits, to which she was not entitled.
+Mr. Sloman commended the investigative efforts of the Social Security Administration-Office of
+Inspector General, the Defense Criminal Investigative Service (DCIS), the efforts of City of
+Sebastian animal control and building code officers, and the Sebastian Police Department. The
+case was prosecuted by Assistant U.S. Attorney Theodore Cooperstein.
+A copy of this press release may be found on the website of the United States Attorney's Office for
+the Southern District of Florida at http://www.usdoj.gov/usao/fls. Related court documents and
+information may be found on the website of the District Court for the Southern District of Florida at
+Technical comments about this website can be e-mailed to the Webmaster. PLEASE NOTE: The
+United States Attorney's Office does not respond to non-technical inquiries made to this website. If
+you wish to make a request for information, you may contact our office at 305-961-9001, or you
+may send a written inquiry to the United States Attorney's Office, Southern District of Florida, 99
+NE 4th Street, Miami, Fl. 33132.
+http://www.usdoj.gov/usao/fls/PressReleases/090921-01.html
+
+
+Sebastian woman sentenced to prison for taking dead mother's military pension checks : T... Page 1 of 2
+TCPALM
+FLORIDAS TREASURE COAST AND PALM BEACHES
+PRINTIR-FUENDLY STUFY
+READ MORE AT WWW.TCPALM.COM
+Sebastian woman sentenced to prison for
+taking dead mother's military pension checks
+By Melissa E. Holsman
+Monday, September 21, 2009
+FORT PIERCE — A Sebastian woman who pleaded guilty to a criminal charge related
+to collecting her dead mother's federal benefits for six years was ordered Monday to
+serve one year and one day in prison.
+Penelope Jordan, 61, was arrested in late March by Sebastian police after they found
+the decaying body of her mother, Timmie Jordan, in a barricaded bedroom of their
+Wimbrow Drive home. Jordan told officials she kept the corpse there since her
+mother's death in early 2003.
+Jordan, who in June pleaded guilty to theft of public money or property, was also
+ordered by U.S. District Judge Donald Graham to pay $237,876 in restitution and serve
+three years of supervised release.
+She had faced up to two years in prison on the charge.
+The theft of public money charge refers to Jordan collecting military pension benefits
+being sent to her mother for Col. Ashford Travis "A. T." Jordan, her mother's late
+husband, after her mother's death. Ashford Jordan was a World War Il veteran and city
+clerk for Sebastian, records show.
+Standing before Graham on Monday dressed in a long black skirt and a print top
+covered by an oversized blue windbreaker, Jordan apologized to the court and talked
+about the financial struggles she'd been facing prior to her arrest in March.
+"I was trying to ... keep a roof over my head and I take responsibility for what I did. It
+was wrong," Jordan said in a low soft voice. "I've never had a whole lot but I do have
+faith in God and people.
+Added Jordan: "I am asking for a second chance to do right."
+Her attorney, Assistant Federal Public Defender Panayotta Augustin-Birch, who
+characterized the unemployed Jordan as "very remorseful," recommended she be
+punished with a term of home detention, followed by supervised release.
+As part of a plea bargain, federal prosecutors dropped a charge of failure to disclose
+http://www.tcpalm.com/news/2009/sep/21/sebastian-sebastian-woman-sentenced-to-prison... 9/22/2009
+
+
+Sebastian woman sentenced to prison for taking dead mother's military pension checks : T... Page 2 of 2
+an occurrence that would alter distribution of Social Security benefits, which could have
+added an additional five years in prison.
+In announcing Jordan's sentence, Graham noted the "conduct in this matter has some
+interesting and unusual facts surrounding the fraud that was perpetrated."
+"It's apparent to the court," he continued, "that the defendant has some issues, some
+social issues in this case."
+The court, Graham said, "does not believe the public will have a problem with future
+crimes from the defendant and a variance is warranted, but not what has been
+recommended by the defense."
+An animal control complaint about stray cats led police to Jordan's home in late March,
+which is when they asked about the whereabouts of her mother. The city also cited
+Jordan for faulty wiring and large amounts of debris and animal waste at the home.
+© 2009 Scripps Treasure Coast Newspapers
+http://www.tcpalm.com/news/2009/sep/21/sebastian-sebastian-woman-sentenced-to-prison. 9/22/2009
+
+
+Southern District of Florida - Press Release
+
+The United States Attorney's Office
+Press Release
+DEFENDANTS SENTENCED IN DRIVER'S LICENSE SCAM
+September 21, 2009
+FOR IMMEDIATE RELEASE
+Jeffrey H. Sloman, Acting United States Attorney for the Southern District of Florida, Rick Walker,
+Special Agent in Charge, U.S. Department of Labor, Office of Inspector General, Office of Labor
+Wesley Philamar, 36, of Miami, was sentenced on Friday, September 18, 2009 on charges of
+conspiracy to produce identification documents without lawful authority, in violation of Title 18,
+United States Code, Sections 1028(a)(1), (b)(1)(A)(ii), (c)(3)(A), and (f). Philamar pled guilty to
+this charge on March 13, 2009.
+U.S. District Judge Kenneth A. Marra sentenced Philamar to 20 months' imprisonment, to be
+followed by 2 years of supervised release. Co-defendant Yvan Bonhomme, 54, of Miramar, pled
+guilty to the same charge on April 1, 2009 and was sentenced by Judge Marra on July 31, 2009 to
+36 months' imprisonment, to be followed by 3 years of supervised release. A third defendant,
+Carmino Rossini Santos, Jr., 40, of Pompano Beach, also pled guilty to the same charge on
+March 13, 2009, and was sentenced by Judge Marra on May 26, 2009 to 3 months' imprisonment,
+3 months' home detention with electronic monitoring, to be followed by 2 years of supervised
+release, and a $1000 fine.
+These convictions were the result of "Operation Turn Signal." Operation Turn Signal is a joint effort
+between the U.S. Department of Labor--Office of Labor Racketeering and Fraud Investigations,
+ICE's Office of Investigations, and the U.S. Attorney's Office to investigate and prosecute fraud
+related to the issuance of immigration documents and Florida driver's licenses.
+According to a factual proffer filed during the pleas, the defendants used five fictitious companies
+purportedly operating in South Florida to create paperwork falsely representing that their clients
+were employees of these companies and had applied for visas. In fact, however, the clients were
+illegal aliens. Thereafter, the aliens presented the false employment documentation received from
+these companies, along with false U.S. Department of Labor certifications and U.S. work visa
+application receipts, to the Florida Division of Driver's Licenses ("DDL") to receive valid driver's
+licenses. The defendants also provided illegal aliens with false U.S. immigration forms for
+submission with their passports to the DDL. In total, the defendants caused the issuance of at
+least 500 fraudulent driver's licenses in both Broward and Palm Beach Counties.
+Mr. Sloman commended the investigative efforts of the U.S. Department of Labor and ICE's Office
+of Investigations. This case was prosecuted by Assistant U.S. Attorney Randy Katz.
+A copy of this press release may be found on the website of the United States Attorney's Office for
+the Southern District of Florida at http://www.usdoj.gov/usao/fls. Related court documents and
+information may be found on the website of the District Court for the Southern District of Florida at
+http://www.flsd.uscourts.gov or on http://pacer.fisd.uscourts.gov.
+http://www.usdoj.gov/usao/fls/PressReleases/090921-02.html
+
+
+Woman charged with buying Jackson Memorial patient records - 09/22/2009 - MiamiHer... Page 1 of 1
+The Miami Herald D
+Posted on Tue, Sep. 22, 2009
+Woman charged with buying Jackson Memorial patient
+records
+By JAY WEAVER
+jweaver@MiamiHerald.com
+A Miami cosmetician is set to appear in federal court Wednesday on charges of buying
+confidential patient records from a Jackson Memorial Hospital employee and selling them to
+a lawyer suspected of soliciting the patients to file personal-injury claims.
+Maria Victoria Suarez was added to an indictment that charges her and husband Ruben E.
+Rodriguez with paying a JMH ultrasound technician $1,000 a month for the hospital records
+of hundreds of patients treated for slip-and-fall accidents, car crash injuries, gunshot
+wounds and stabbings, federal authorities said.
+The technician, Rebecca Garcia, a 22-year JMH veteran, has been fired and pleaded guilty
+in the conspiracy case.
+The Rodriguezes brokered the stolen records of patients' names, addresses, telephone
+numbers and medical diagnoses to the lawyer over a two-year period, according to the
+indictment. The lawyer, not identified in court papers, used the information "to improperly
+solicit JMH patients with hopes of representing them in future legal proceedings."
+In Florida, lawyers are allowed to advertise on TV and billboards and in the Yellow Pages,
+but are prohibited from soliciting clients by phone or at their home or in the hospital.
+© 2009 Miami Herald Media Company. All Rights Reserved.
+http://www.miamiherald.com
+
+
+Miami woman charged with buying Jackson Memorial patient records - South Florida Su... Page 1 of 1
+sun-sentinel.com/news/florida/sfl-jackson-memorial-patient-records-bn092209,0,7145861.story
+South Florida Sun-Sentinel.com
+Miami woman charged with buying Jackson Memorial patient
+records
+She is accused of selling the records to a lawyer suspected of soliciting personal-injury
+cases
+By Jay Weaver
+The Miami Herald
+8:05 AM EDT, September 22, 2009
+MIAMI
+A Miami cosmetician is set to appear in federal court
+Wednesday on charges of buying confidential patient
+records from a Jackson Memorial Hospital employee and
+selling them to a lawyer suspected of soliciting the
+patients to file personal-injury claims.
+rethink burgers
+with StarKist Tuna Creations.
+get the bolder burger recipe, click here.
+Maria Victoria Suarez was added to an indictment that
+charges her and husband Ruben E. Rodriguez with
+paying a Jackson Memorial ultrasound technician $1,000
+a month for the hospital records of hundreds of patients
+treated for slip-and-fall accidents, car crash injuries,
+gunshot wounds and stabbings, federal authorities said.
+dick here today for
+win $500
+official rules & details
+Starkis
+Circles
+The technician, Rebecca Garcia, a 22-year Jackson
+Memorial veteran, has been fired and pleaded guilty in
+the conspiracy case.
+The Rodriguezes brokered the stolen records of patients' names, addresses, telephone numbers and
+medical diagnoses to the lawyer over a two-year period, according to the indictment.
+The lawyer, not identified in court papers, used the information "to improperly solicit JMH patients with
+hopes of representing them in future legal proceedings."
+In Florida, lawyers are allowed to advertise on TV and billboards and in the Yellow Pages, but are
+prohibited from soliciting clients by phone or at their homes or in the hospital.
+Copyright © 2009, South Florida Sun-Sentinel
+http://www.sun-sentinel.com/news/florida/sfl-jackson-memorial-patient-records-bn092209. 9/22/2009
+
+
+Miami Medicare fraud defendant gets 8 years - 09/22/2009 - MiamiHerald.com
+
+The Miami Herald D
+Posted on Tue, Sep. 22, 2009
+Miami Medicare fraud defendant gets 8 years
+BY JAY WEAVER
+jweaver@MiamiHerald.com
+A fugitive who claimed to be Mexican but
+Miami federal court on U.S. Medicare fraud
+Alcides Garcia, 44, of Pembroke Pines,
+asked the judge for "forgiveness" after his
+lawyer challenged the total amount of fraud
+-- $10.7 million in false claims, according to
+prosecutors. Garcia's Hialeah medical
+equipment business collected $2.2 million
+for supplies never provided to patients.
+U.S. District Judge Marica Cooke ordered
+Garcia to pay it all back. But if he is like
+hundreds of other Medicare fraud
+prosecutions, the taxpayer-funded program
+for the elderly won't likely recover much
+money.
+Authorities say Alcides Garcia claimed $10.7 million in
+Medicare claims and collected $2.2 million.
+Garcia, who pleaded guilty to one count of
+defrauding Medicare, listed himself and
+mug
+others as the owner of A&Y Medical Supply
+from 2002 to 2004, billing Medicare for
+power air mattresses, feeder pumps and
+other equipment.
+'This defendant figured out it was easier to hide through other people," said Assistant U.S.
+Attorney Daniel Bernstein, adding that Garcia used a local billing firm, All-Med, headed by a
+Miami Lakes couple convicted of unrelated Medicare fraud last year.
+Garcia fled South Florida before his trial a year ago. Free on $200,000 bond, he traveled to
+Mexico, then Spain, then the Canary Islands, on a false Mexican passport. Initially, the FBI
+thought he had escaped to his native Cuba.
+But Garcia made a mistake on the lam, when he went to a shipping company in the Canary
+Islands in February to have his belongings sent from Miami to the Spanish island.
+
+
+Miami Medicare fraud defendant gets 8 years - 09/22/2009 - MiamiHerald.com
+
+The business owner grew suspicious of him because he said he was Mexican, but she
+detected his heavy Cuban accent. The accent was familiar to her because people on the
+Canary Islands are known to speak Spanish like Cubans.
+The business owner Googled Garcia's name on the Internet and up popped a Miami
+Herald/El Nuevo story published in January that described Garcia as a Cuban-born fugitive
+wanted on Medicare fraud charges in South Florida. The story, which carried a mug shot of
+Garcia, confirmed his identity.
+The owner called the FBI in Miami. Special Agent Robert Cessario notified authorities in
+Madrid.
+arcia later checked into a hotel in the capital city, using his real name and the fals
+lexican passport. The Spanish National Police arrested him on an FBI warrant in Marct
+© 2009 Miami Herald Media Company. All Rights Reserved.
+http://www.miamiherald.com
+
+
+
+GE PRINTTHIS
+PalmBeachPost.com
+Palm Beach Post Editorial
+Tuesday, September 22, 2009
+On the second page of the secret deal between federal prosecutors and Jeffrey
+Epstein, we read that the agreement will serve the interests of "the United States, the
+State of Florida, and the Defendant." Wrong on the first two, right on the third.
+Until Friday, the public didn't know the terms of the deal that finalized the case of
+the Palm Beacher who arranged to have girls brought to his house for sex and
+massages. Only Epstein's platoon of lawyers, the U.S. Attorney's Office for the
+Southern District of Florida and the Palm Beach County State Attorney's Office knew the details. And
+now we know why the perpetrators of this outrage didn't want the public to know.
+story below
+The deal is an indictment of a system that did much more for a criminal than
+Post your for his victims. Jeffrey Epstein - officially a registered sex offender but in
+Instead, the federal deal allowed him to plead guilty to light charges in state
+court. He spent just 13 months - nights only - in the Palm Beach County Jail.
+Meanwhile, the government tried to help Epstein buy off the young girls
+whom Epstein had exploited.
+More from Opinion
+Editorials, letters,
+columns and more
+special features
+The Opinion Zone
+Sound off in our blog
+Several of those girls have filed civil suits against Epstein. (Their lawyers and
+lawyers for The Post sued to make the plea deal public.) In the agreement, the
+government proposes to identify all the alleged victims and steer them to a
+lawyer, whose expenses Epstein would pay. In return, however, the victims
+would withdraw all lawsuits from state court and agree to a settlement in
+federal court of no more than $150,000 each. Even then, of course, Epstein
+would not acknowledge any "liability."
+Share This Story
+The agreement thus placed the Department of Justice in a role similar to those of the four women who
+procured girls for Epstein. If there's a precedent in this or any of the other 92 United States attorney's
+offices, we'd like to hear it. Not surprisingly, R. Alexander Acosta also agreed not to prosecute those
+women.
+If the outcome is frustrating, so is the lack of accountability. Mr. Acosta's name is on the deal, but he's
+now the dean of Florida International University's law school. A call to his office for comment Monday
+http://palmbeachpost.printthis.clickability.com/pt/cpt?action=cpt&title=EDITORIAL%3A... 9/22/2009
+
+
+
+was not returned. The name of Assistant U.S. Attorney A. Marie Villafana is on the deal. She still works
+as a federal prosecutor in West Palm Beach, but Alicia Valle, the office's special counsel, said in an e-
+mail, "We cannot comment on your questions." Didn't she really mean will nor?
+This case got into the federal system because former Palm Beach Police Chief Michael Reiter believed
+that Palm Beach County State Attorney Barry Krischer wasn't moving aggressively enough. Mr.
+Krischer retired last year. The assistant state attorney who oversaw the case is no longer with the office.
+At this point, the public must hope that the civil suits suck as much money from Epstein as possible.
+Money seems to be all that he understands. Also, Jeffrey Sloman is serving as the acting U.S. attorney
+or the Southern District of Florida until President Obama nominates a permanent replacement to
+onfirmation by the Senate. It would be good to know that whoever follows Mr. Acosta is on record th
+the Jeffrey Epstein deal did not serve the interests of the United States.
+Find this article at:
+http://www.palmbeachpost.com/search/content/opinion/epaper/2009/09/22/a12a_leadedit_epstein_0922.html
+Г Check the box to include the list of links referenced in the article.
+http://palmbeachpost.printthis.clickability.com/pt/cpt?action=cpt&title=EDITORIAL%3A...
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/e5a72027aed7bce26eafd5564334519b9c3b1d7737a0d5bbc4f695db8984aab5.receipt.json b/vision-fixhub/ds9-unparsed-05/e5a72027aed7bce26eafd5564334519b9c3b1d7737a0d5bbc4f695db8984aab5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..25cd534b317905da846ef9ed3cb67107a3de6ea9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e5a72027aed7bce26eafd5564334519b9c3b1d7737a0d5bbc4f695db8984aab5.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -460,
+  "dataset": "marble-joined",
+  "doc_id": "e5a72027aed7bce26eafd5564334519b9c3b1d7737a0d5bbc4f695db8984aab5",
+  "engine": "marble-apple-vision",
+  "event_count": 18,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "dc5927304a8fc09fef4f07bd481765ae2c22e70f298e2b143523db537e4d32cf",
+  "output_sha256": "3e44b938c0cd6db1170cd8272cf9e1e3f3473f2ec3564a12ca2a68418defe37a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e5c48a21f3b1380f088a0bd0b5db5c9fcbb519dad4af3ba0c53cfec1ff26de65.md b/vision-fixhub/ds9-unparsed-05/e5c48a21f3b1380f088a0bd0b5db5c9fcbb519dad4af3ba0c53cfec1ff26de65.md
new file mode 100644
index 0000000000000000000000000000000000000000..9dd9300dedbbfb6c5f6e6ec1be2ef0061abb8043
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e5c48a21f3b1380f088a0bd0b5db5c9fcbb519dad4af3ba0c53cfec1ff26de65.md
@@ -0,0 +1,39 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+West Palm Beach, FL 33401
+500 South Australian Ave., Suite 400
+Facsimile:
+July 8, 2008
+VIA FACSIMILE AND ELECTRONIC MAIL
+Jack A. Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+West Palm Beach, FL 33401-5015
+Re: Jeffrey Epstein
+Dear Mr. Goldberger:
+In accordance with the terms of the Non-Prosecution Agreement, on June 30, 2008, the
+United States Attorney's Office provided you with a list of thirty-one individuals "whom it was
+prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein."
+Yesterday, I provided you with the identification of another victim whom I had erroneously left
+off of that list. At the time the list was provided, Special Agent
+and I impressed
+upon you the need to finalize this last piece of the agreement as quickly as possible so that we
+could fulfill our victim notification obligations. In deference to your vacation, we allowed you a
+week to provide us with any objections or requested modifications to the list and/or the
+Notification language. Yesterday, I contacted you via telephone and e-mail, but received no
+response.
+Accordingly, the United States hereby notifies you that it will distribute the victim
+notifications tomorrow, July 9, 2008, to each of the thirty-two identified victims, either directly
+or via their counsel. A carbon copy of each notification will be provided to you, and the
+notification will list you as the contact person for any civil litigation, if the victim decides to
+pursue damages. If the United States learns that a civil suit has been filed against Mr. Epstein
+and he has denied that one of these victims is entitled to proceed under 18 U.S.C. § 2255, that
+will be considered a breach of the Non-Prosecution Agreement and the United States will
+proceed accordingly.
+Sincerely,
+R. Alexander Acosta
+United States Attorney
+By:
+Assistant United States Attorney
+cc:
+n, AUSA
diff --git a/vision-fixhub/ds9-unparsed-05/e5c48a21f3b1380f088a0bd0b5db5c9fcbb519dad4af3ba0c53cfec1ff26de65.receipt.json b/vision-fixhub/ds9-unparsed-05/e5c48a21f3b1380f088a0bd0b5db5c9fcbb519dad4af3ba0c53cfec1ff26de65.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..723b6265591f61f0ea709bfe0a21fe0b76741c26
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e5c48a21f3b1380f088a0bd0b5db5c9fcbb519dad4af3ba0c53cfec1ff26de65.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "e5c48a21f3b1380f088a0bd0b5db5c9fcbb519dad4af3ba0c53cfec1ff26de65",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "6bcd2db5d5557c39b4de4f6b30446e589d77d2dbab74bf57103b0b32172d9df4",
+  "output_sha256": "80b85643f3f3d310ab16d00d3aa3c7606e2e0922effe4aad1df4b1d3ee142ccf",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e66abf44a285746785dc7d9bf28f3ed0659c7d34c421eb0c4a136a150e4c80d4.md b/vision-fixhub/ds9-unparsed-05/e66abf44a285746785dc7d9bf28f3ed0659c7d34c421eb0c4a136a150e4c80d4.md
new file mode 100644
index 0000000000000000000000000000000000000000..40995886e50cb696521b3728eb95a50488a8faa3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e66abf44a285746785dc7d9bf28f3ed0659c7d34c421eb0c4a136a150e4c80d4.md
@@ -0,0 +1,758 @@
+Cc:
+Subject:
+- (USAFLS)
+Mondav. January 14. 2008 11:35 AM
+- (USAFLS)
+IR.
+RE: Epstein
+It was a pleasure meeting you on Friday, as well as the agents. Let's plan for me to be in Florida on the 23° and 24* and
+I will get the remaining 302s at that time. As for meeting with the girls, I am available the entire week of the 28th and will
+leave it to the agents to make arrangements with the girls and let me know when to come down.
+From what I could tell during the meeting on Friday, I am guessing that you have already done everything that we need to
+do and obtained whatever evidence that we need to have. It's probably just a matter of doubling back to make sure that
+everything is still "fresh" and, in this case, making sure that things have not begun to vanish. I will be able to speak more
+definitively once I've made a bigger dent in the materials that you sent back with me.
+Take care.
+(USAFLS) [mailto:Ann.
+Sent: Monday. January 14, 2008 11:22 AM
+Cc:
+Subject: Epstein
+EN.;
+R.
+-gov]
+Hi
+- I have one more book of 302s that wouldn't fit into the bag that I gave you on Friday. Please let
+me know if you would like me to send it or if you want to wait until you return next week. Except for a
+lunchtime dental appointment on Tuesday the 22nd,
+, I will be around all week, and I will keep my schedule open
+as much as possible. During the week of the 28th,
+', i have a suppression hearing on the morning of 1/30, but i am
+otherwise around.
+I have ce'd
+and
+on this e-mail so you will have their e-mail/Blackberry addresses.
+responses to see what it missing.
+I will start working on revising the indictment taking into account your suggestions and |
+suggestions. I also want to do an application to get the tax returns for all of the defendants, since Epstein's
+corporations have refused to obey the grand jury subpoenas.
+Is there anything else that I should or should not be doing?
+Thank you, and it was so nice to meet you in person on Friday.
+A.
+1887
+P-014524
+
+
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone :
+Fax 561 820-8777
+1888
+P-014525
+
+
+- (USAFLS)
+Cc:
+Subject:
+(USAFLS)
+Monday, January 14, 2008 11:22 AM
+EN.;
+R.
+Epstein
+- I have one more book of 302s that wouldn't fit into the bag that I gave you on Friday. Please let
+me Know if you would like me to send it or if you want to wait until you return next week. Except for a
+lunchtime dental appointment on Tuesday the 22nd
+', I will be around all week, and I will keep my schedule open
+as much as possible. During the week of the 28**, I have a suppression hearing on the morning of 1/30, but 1 am
+otherwise around.
+I have ce'd
+and
+on this e-mail so you will have their e-mail/Blackberry addresses.
+responses to see what it missing.
+I will start working on revising the indictment taking into account your suggestions and
+suggestions. I also want to do an application to get the tax returns for all of the defendants, since Epstein's
+corporations have refused to obey the grand jury subpoenas.
+Is there anything else that I should or should not be doing?
+Thank you, and it was so nice to meet you in person on Friday.
+| Villataña
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone :
+Fax 561 820-8777
+1889
+P-014526
+
+
+- (USAFLS)
+Subject:
+Thursday. January 10, 2008 3:02 PM
+(USAFLS)
+RE: Tomorrow
+Since the meeting is informal, should | dress casually or is it business as usual?
+(USAFLS) [mailto:Ann
+Se:t: Insay anuary 10, 2008 3:00 PM
+Subject: RE: Tomorrow
+Great. I will see you then.
+Sent: Thursday, January 10, 2008 2:59 PM
+(USAFLS)
+Subject: RE: Tomorrow
+need between now and tomorrow. My cell number is
+US Air Flight 1223 arrives at 12:43PM. I have the pros memo and indictment. They-are pretty thick, so I think that's all l
+See you soon!
+(USAFLS) [mailto
+Sent: Thursday, January 10, 2008 2:54 PM
+Subject: RE: Tomorrow
+Absolutely. Just send me the flight info. My cell number is
+You have the pros memo, I think. Do you want me to send you anything else?
+Sent: Thursday, January 10, 2008 2:53 PM
+Subject: RE: Tomorrow
+(USAFLS)
+Let's go ahead and stick with tomorrow. Are you available at 12:45 to pick me up from the airport?
+(USAFLS) [mailto:
+Sent: Thursday, January 10, 2008 2:51 PM
+Subject: RE: Tomorrow
+Do you want to do that? Or do you want to wait? I haven't heard back from the agents yet.
+Sent: Thursday, January 10, 2008 2:50 PM
+1891
+P-014527
+
+
+Subject: Tomorrow
+(USAFLS)
+There is a flight out of DC arriving in Palm Beach tomorrow at 12:45. Therefore, I can make a 1:30 meeting.
+1892
+P-014528
+
+
+- (USAFLS)
+Subject:
+- (USAFLS)
+Thursday. January 10, 2008 3:00 PM
+RE: Tomorrow
+Great. I will see you then.
+Subject: RE: Tomorrow
+10, 2008 2:59 PM
+(USAFLS)
+US Air Flight 1223 arrives at 12:43PM. I have the pros memo and indictment. They are pretty thick, so think that s all
+need between now and tomorrow. My cell number is
+See you soon!
+(USAFLS) [mailto
+Sent: Thursday, January 10, 2008 2:54 PM
+Subject: RE: Tomorrow
+Absolutely. Just send me the flight info. My cell number is
+You have the pros memo, I think. Do you want me to send you anything else?
+Sent: Thursday, January 10, 2008 2:53 PM
+(USAFLS)
+Subject: RE: Tomorrow
+Let's go ahead and stick with tomorrow. Are you available at 12:45 to pick me up from the airport?
+(USAFLS) [mailto,
+Sent: Thursday. January 10, 2008 2:51 PM
+Subject: RE: Tomorrow
+Do you want to do that? Or do you want to wait? I haven't heard back from the agents yet.
+Sent: Thursday, January 10, 2008 2:50 PM
+, (USAFLS)
+Subject: Tomorrow
+There is a flight out of DC arriving in Palm Beach tomorrow at 12:45. Therefore, I can make a 1:30 meeting
+1895
+P-014529
+
+
+- (USAFLS)
+Subject:
+Thursday, January 10, 2008 2:59 PM
+RE: Tomorrow
+US Air Flight 1223 arrives at 12:43PM. I have the pros memo and indictment. They are pretty thick, so | think that's all I
+need between now and tomorrow. My cell number is
+See you soon!
+(USAFLS) [/
+Sent: uperstay anuary 10, 2008 2:54 PM
+Subject: RE: Tomorrow
+Absolutely. Just send me the flight info. My cell number is
+You have the pros memo, I think. Do you want me to send you anything else?
+Sent: Thursday, January 10, 2008 2:53 PM
+(USAFLS)
+Subject: RE: Tomorrow
+Let's go ahead and stick with tomorrow. Are you available at 12:45 to pick me up from the airport?
+(USAFLS) [mailto
+Sent: Thursday, January 10, 2008 2:51 PM
+Subject: RE: Tomorrow
+Do you want to do that? Or do you want to wait? I haven't heard back from the agents yet.
+Sent: Thursday, January 10, 2008 2:50 PM
+(USAFLS)
+Subject: Tomorrow
+There is a flight out of DC arriving in Palm Beach tomorrow at 12:45. Therefore, I can make a 1:30 meeting
+1897
+P-014530
+
+
+Subject:
+- (USAFLS)
+| (USAFLS)
+Thursday. January 10, 2008 2:55 PM
+(E.
+@ic.Tbi.gov)
+Forget the earlier e-mail
+Richards2
+can make the meeting tomorrow. I have to pick her up at the airport at 12:45, so I probably can't do lunch.
+1899
+P-014531
+
+
+- (USAFLS)
+Subject:
+- (USAFLS)
+Thursday, January 10, 2008 2:54 PM
+RE: Tomorrow
+Absolutely. Just send me the flight info. My cell number is
+You have the pros memo, I think. Do you want me to send you anything else?
+Sent: Thursday. January 10, 2008 2:53 PM
+(USAFLS)
+Subject: RE: Tomorrow
+Let's go ahead and stick with tomorrow. Are you available at 12:45 to pick me up from the airport?
+(USAFLS) [mailto
+Sent: Inursday, January 10, 2008 2:51 PM
+Subject: RE: Tomorrow
+Do you want to do that? Or do you want to wait? I haven't heard back from the agents yet.
+Sent: Thursday, January 10, 2008 2:50 PM
+- (USAFLS)
+Subject: Tomorrow
+There is a flight out of DC arriving in Palm Beach tomorrow at 12:45. Therefore, I can make a 1:30 meeting.
+1900
+P-014532
+
+
+- (USAFLS)
+Subject:
+Thursdav, January 10, 2008 2:53 PM
+(USAFLS)
+RE: Tomorrow
+Let's go ahead and stick with tomorrow. Are you available at 12:45 to pick me up from the airport?
+(USAFLS)
+Sent: Thursday, January 10, 2008 2:51 PM
+To: I
+Subject: RE: Tomorrow
+gov]
+Do you want to do that? Or do you want to wait? I haven't heard back from the agents yet.
+Sent: Thursday, January 10, 2008 2:50 PM
+(USAFLS)
+Subject: Tomorrow
+There is a flight out of DC arriving in Palm Beach tomorrow at 12:45. Therefore, I can make a 1:30 meeting.
+1903
+P-014533
+
+
+Subject:
+- (USAFLS)
+Thursdav, January 10, 2008 2:50 PM
+(USAFLS)
+Tomorrow
+There is a flight out of DC arriving in Palm Beach tomorrow at 12:45. Therefore, I can make a 1:30 meeting.
+1905
+P-014534
+
+
+Villafana, Ann Marie C. (USAFLS)
+Subject:
+- (USAFLS)
+Thursday, January 10, 2008 2:51 PM
+RE: Tomorrow
+Do you want to do that? Or do you want to wait? I haven't heard back from the agents yet.
+Myesha
+Sent: Thursday, January 10, 2008 2:50 PM
+, Ann Marie C. (USAFLS)
+Subject: Tomorrow
+There is a flight out of DC arriving in Palm Beach tomorrow at 12:45. Therefore, I can make a 1:30 meeting.
+1907
+P-014535
+
+
+Subject:
+- (USAFLS)
+(USAFLS)
+Thursday, January 10, 2008 2:42 PM
+(E
+@ic.tbi.gov)
+Meeting Change -- Urgent!
+Richards2
+Hi guys - The attorney from CEOS would like to attend the meeting, but getting down here from DC tomorrow would be
+difficult. Can we do Monday? I know the other agents are coming, but I was hoping maybe first thing in the morning?
+1909
+P-014536
+
+
+- (USAFLS)
+Subject:
+- (USAFLS)
+Thursday, January 10, 2008 2:30 PM
+RE: Epstein case
+Thanks, Drew. I look forward to meeting her in person.
+-----Original Message--
+Sent,
+Thuncdan
+Subject: Re: Epstein case
+Well, it sounds like
+she'll call you shortly.
+2008 2:27 PM
+(USAFLS)
+will be ideal. I've given her the assignment and
+She plans on attending the meeting tomorrow.
+If you need any other help just let me know.
+I'll talk to you soon. Best of luck.
+Drew
+From.
+(USAFLS) <
+Sent: Wed Jan 09 18:27:59 2008
+Subject: RE: Epstein case
+hat backup perp for the ctuad of ike ons repen stuff, so I can work on that
+One other strategic thing. I want the judge and jury to see that, rather than
+the big bad government vs. the poor little defense attorney, it is the big bad
+defense attorneys ganging up on the nice, polite, hard-working government.
+Thank you so much, Drew. I really appreciate it.
+A.
+500 S. Australian Ave, Suite 400
+West Palm Beach.
+EL 33401
+Phone
+Fax 561 820-8777
+-----Original Message-
+And
+Sent: Wednesday, January 09, 2008 5:51 PM
+1916
+P-014537
+
+
+(USAFLS)
+Subject: Re: Epstein case
+well,
+has those qualities - and there isn't a federal prosecutor in the
+land who knows more about dealing with teenaged victims of prostitution offenses.
+That said, this matter is unique for reasons you know better than anyone.
+Writ
+onses to complex legal claims - bogus or otherwise - is definitely
+not
+strength. On the other hand, she's!
+mely good in court. I told
+Jeff that perhaps it's best to partner you with
+and give you back up on
+motions and other legal pleadings from someone else in my section with that
+strength. How do you feel about that?
+Sent: Wed Jan 09 17:42:07 2008
+Subject: RE: Epstein case
+(USAFLS) <
+I thought she was great, but I leave it completely to your discretion. I am
+happy for all the help I can get. You kind of know the lay of the land on the
+case, and I think we will get either Judge Middlebrooks, Judge Marra, or Judge
+Hurley. Tenacity, patience, and an ability to work with troubled young women
+will be key.
+Thanks.
+A.
+allafana
+500 S. Australian Ave, Suite 400
+West Palm Beach, EL 33401
+Phone
+Fax 561 820-8777
+•
+-----Original Message-----
+bladnesday,
+January 29,
+2008 5:30 PM
+(USAFLS)
+Subject: Re: Epstein case
+Hey
+I just got off the phone with Jeff.
+I wanted to discuss my options with him a
+bit. I plan to assign it in the morning, and I will do whatever I can to get the
+TA down there for the meeting Friday. Do you have a preference for
+given
+your experience with her?
+She does know the area well. Thanks. Drew
+(USAFLS) <
+1917
+P-014538
+
+
+Sent: Wed Jan 09 15:59:06 2008
+Subject: Epstein case
+Hi Drew - I hear that you are coming into the fray. I haven't heard from
+from your office yet about a meeting.
+I just wanted to remind you that
+Braden and I talked about the case a few times and she was a great help.
+I am hoping to get all the evidence back from
+tomorrow, so I will have
+everything back up here in West Palm by Friday morning.
+I am meeting with the
+agents and group supervisor on Friday afternoon for a strategy session.
+chance my CEOS colleague can participate? At least by phone?
+Thanks.
+A.
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phor
+Fax 561 820-8777
+1918
+P-014539
+
+
+- (USAFLS)
+sent:
+Subject:
+Thursday, January 10.2008 2:27 PM
+(USAFLS)
+Re: Epstein case
+well, it sounds like
+will be ideal. I've given her the assignment and
+she'll call you shortly. She plans on attending the meeting tomorrow.
+If you need any other help just let me know.
+I'll talk to you soon. Best of luck.
+Drew
+----- Criminal Meccanorm
+(USAFLS) <
+• gov›
+Sent: Wed Jan 09 18:27:59 2008
+Subject: RE: Epstein case
+That sounds perfect. I actually like the written stuff, so I can work on that
+with backup help for the flood of motions I expect.
+One other strategic thing. I want the judge and jury to see that, rather than
+the big bad government vs. the poor little defense attorney, it is the big bad
+defense attorneys ganging up on the nice, polite, hard-working government.
+Thank you so much, Drew. I really appreciate it.
+A.
+500 S. Australian Ave, Suite 400
+West Palm Beach, EL 33401
+Phone
+Fax 561 820-8777
+-----Oniginal Message--
+Sent: badnesday
+1aauaRy 99, 2008 5:51 PM
+(USAFLS)
+Subject: Re: Epstein case
+well,
+has those qualities - and there isn't a federal prosecutor in the
+land who knows more about dealing with teenaged victims of prostitution offenses.
+hat said, this matter is unique for reasons you know better than anyone.
+Writi
+nses to complex legal claims - bogus or otherwise - is definitel
+not
+strength. On the other hand, she's extremely good in court.
+I told
+P-014540
+
+
+Jeff that perhaps it's best to partner you with
+and give you back up on
+motions and other legal pleadings from someone else in my section with that
+strength. How do you feel about that?
+Anicinal
+Mera
+Sent: Wed Jan 09 17:42:07 2008
+Subject: RE: Epstein case
+(USAFLS) <Ann./
+j. gov>
+I thought she was great, but I leave it completely to your discretion. I am
+happy for all the help I can get.
+You kind of know the lay of the land on the
+case, and I think we will get either Judge Middlebrooks, Judge Marra, or Judge
+Hurley. Tenacity, patience, and an ability to work with troubled young women
+will be key.
+Thanks.
+A.
+500 S. Australian Ave, Suite 400
+west Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+-----Original Message-
+Iladnesday
+January 99, 2008 5:30 PM
+(USAFLS)
+Subject: Re: Epstein case
+Hey
+I just got off the phone with Jeff.
+I wanted to discuss my options with him a
+bit. I plan to assign it in the morning, and I will do whatever I can to get the
+TA down there for the meeting Friday. Do you have a preference for
+given
+your experience with her? She does know the area well. Thanks. Drew
+e
+(USAFLS) <
+Sent: Wed Jan 09 15:59:06 2008
+Subject: Epstein case
+Hi Drew - I hear that you are coming into the fray. I haven't heard frommune
+from your office yet about a meeting. I just wanted to remind you that
+Braden and I talked about the case a few times and she was a great help.
+1924
+P-014541
+
+
+I am hoping to get all the evidence back from
+tomorrow, so I will have
+everything back up here in West Palm by Friday morning
+I am meeting with the
+agents and group supervisor on Friday afternoon for a strategy session.
+chance my CEOS colleague can participate? At least by phone?
+Thanks.
+A.
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+1925
+P-014542
+
+
+• (USAFLS)
+Subject:
+(USAFLS)
+Wednesday. January 09, 2008 6:28 PM
+RE: Epstein case
+That sounds perfect. I actually like the written stuff, so I can work on that
+with backup help for the flood of motions I expect.
+One other strategic thing. I want the judge and jury to 'see that, rather than
+he big bad government vs. the poor little defense attorney, it is the big ba
+lefense attorneys ganging up on the nice, polite, hard-working government
+Thank you so much, Drew. I really appreciate it.
+A.
+500 S. Australian Ave, Suite 400
+West Palm Beach. EL 33401
+Phone
+Fax 561 820-8777
+-----Original Message--
+Sent: hadnesda
+any 09, 2008 5:51 PM
+(USAFLS)
+Subject: Re: Epstein case
+Well,
+has those qualities - and there isn't a federal prosecutor in the
+land who knows more about dealing with teenaged victims of prostitution offenses.
+That said, this matter is unique for reasons you know better than anyone.
+Writ
+onses to complex legal claims - bogus or otherwise - is definitely
+not
+strength. On the other hand, she's
+Jeff that perhaps it's best to partner you with
+and give you back up on
+motions and other legal pleadings from someone else in my section with that
+strength. How do you feel about that?
+Sent: Wed Jan 09 17:42:07 2008
+Subject: RE: Epstein case
+(USAFLS) <
+• gov›
+I thought she was great, but I leave it completely to your discretion. I am
+happy for all the help I can get.
+casey and at thk he ill get ether in Mo Ker the a or tara on the
+Hurley. Tenacity, patience, and an ability to work with troubled young women
+will be key.
+1933
+P-014543
+
+
+Thanks.
+A.
+500 S. Australian Ave, Suite 400
+West Palm Beach. EL 33401
+Phone
+Fax 561 820-8777
+From: steinal Messare-
+Sent: Wadnasday
+Subject: Re: Epstein case
+2008 5:30 PM
+(USAFLS)
+Hey
+I just got off the phone with Jeff.
+I wanted to discuss my options with him a
+bit. I plan to assign it in the morning, and I will do whatever I can to get the
+TA down there for the meeting Friday. Do you have a preference for
+given
+your experience with her? She does know the area well. Thanks. Drew
+Sent: Wed Jan 09 15:59:06 2008
+Subject: Epstein case
+(USAFLS) <
+Hi Drew - I hear that you are coming into the fray. I haven't heard from arrane
+rom your office yet about a meeting. I just wanted to remind you that
+Braden and I talked about the case a
+few times and she was a great help
+I am hoping to get all the evidence back from
+so I will have
+everything back up here in West Palm by Friday morning. I am meeting with the
+agents and group supervisor on Friday afternoon for a strategy session. Any
+chance my CEOS colleague can participate? At least by phone?
+Thanks.
+A.
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone
+1934
+P-014544
+
+
+Fax 561 820-8777
+1935
+P-014545
+
+
+- (USAFLS)
+Subject:
+Wednesday. January 09, 2008 5:51 PM
+(USAFLS)
+Re: Epstein case
+well,
+has those qualities - and there isn't a federal prosecutor in the
+land who knows more about dealing with teenaged victims of prostitution offenses.
+That said, this matter is unique for reasons you know better than anyone.
+onses to complex legal claims - bogus or otherwise - is definitely
+strength. On the other hand, she'si
+wanely good in court. I told
+Jeff that perhaps it's best to partner you with
+and give you back up on
+motions and other legal pleadings from someone else in my section with that
+strength. How do you feel about that?
+Animinal Maccago
+To: Oosterbaan,
+Sent: Wed Jan 09 17:42:07 2008
+Subject: RE: Epstein case
+(USAFLS) <
+1>
+I thought she was great, but I leave it completely to your discretion. I am
+happy for all the help I can get.
+case, and alt the he pil get ether kin odder ths ade tara, or the
+Hurley. Tenacity, patience, and an ability to work with troubled young women
+will be key.
+Thanks.
+A.
+500 S. Australian Ave, Suite 400
+West Palm Beach. EL 33401
+Phor
+Fax 561 820-8777
+-----Original Message-
+Sent: Madnesday
+Subject: Re: Epstein case
+any 09, 2008
+: 5:30 PM
+(USAFLS)
+Hey
+I just got off the phone with Jeff.
+I wanted to discuss my options with him a
+bit. I plan to assign it in the morning, and I will do whatever I can to get the
+TA down there for the meeting Friday. Do you have a preference for
+given
+your experience with her? She does know the area well. Thanks.
+Drew
+1941
+P-014546
+
+
+==---
+Sent: Wed Jan 09 15:59:06 2008
+Subject: Epstein case
+(USAFLS) <
+• gov›
+Hi Drew - I hear that you are coming into the fray. I haven't heard fro
+from your office yet about a meeting. I just wanted to remind you that
+Braden and I talked about the case a few times and she was a great help.
+ne
+I am hoping to get all the evidence back from
+so I will have
+everything back up here in West Palm by Friday morning. I am meeting with the
+agents and group supervisor on Friday afternoon for a strategy session. Any
+chance my CEOS colleague can participate?
+At least by phone?
+Thanks.
+A.
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone
+Fax 561 820-8777
+1942
+P-014547
+
+
+- (USAFLS)
+Subject:
+(USAFLS)
+Wednesday. January 09, 2008 5:42 PM
+RE: Epstein case
+I thought she was great, but I leave it completely to your discretion. I am
+happy for all the help I can get. You kind of know the lay of the land on the
+case, and I think we will get either Judge Middlebrooks, Judge Marra, or Judge
+Hurley. Tenacity, patience, and an ability to work with troubled young women
+Thanks.
+ley
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone
+Fax 561 820-8777
+-----Original Message--
+Sent: hadnesday
+Subject: Re: Epstein case
+09, 2008 5:30 PM
+(USAFLS)
+Hey
+I just got off the phone with Jeff.
+I wanted to discuss my options with him a
+bit. I plan to assign it in the morning, and I will do whatever I can to get the
+TA down there for the meeting Friday. Do you have a preference for
+given
+your experience with her? She does know the area well.
+Thanks.
+Drew
+Oniminal Message
+(USAFLS) <
+• gov>
+To: Oosterbaan,
+Sent: Wed Jan 09 15:59:06 2008
+Subject: Epstein case
+Hi Drew - I hear that you are coming into the fray. I haven't heard frommane
+from your office yet about a meeting. I just wanted to remind you that
+raden and I talked about the case a few times and she was a great help.
+I am hoping to get all the evidence back from
+tomorrow, so I will have
+everything back up here in west Palm by Friday morning.
+I am meeting with the
+agents and group supervisor on Friday afternoon for a strategy session. Any
+chance my CEOS colleague can participate? At least by phone?
+1947
+P-014548
+
+
+Thanks.
+A. Marie
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phor
+Fax 561 820-8777
+1948
+P-014549
+
+
+Subject:
+Hey
+- (USAFLS)
+Wednesday, January 09, 2008 5:30 PM
+(USAFLS)
+Re: Epstein case
+I just got off the phone with Jeff.
+I wanted to discuss my options with him a
+to get the
+given
+---_-
+Animinal Maccano
+Sent: Wed Jan 09 15:59:06 2008
+Subject: Epstein case
+(USAFLS) <
+ov>
+Hi Drew - I hear that you are coming into the fray. I haven't heard from
+from your office yet about a meeting. I just wanted to remind you that
+Braden and I talked about the case a few times and she was a great help.
+one
+I am hoping to get all the evidence back from
+tomorrow, so I will have
+everything back up here in West Palm by Friday morning.
+I am meeting with the
+agents and group supervisor on Friday afternoon for a strategy session. Any
+chance my CEOS colleague can participate? At least by phone?
+Thanks.
+A.
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone
+Fax 561 820-8777
+1949
+P-014550
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/e66abf44a285746785dc7d9bf28f3ed0659c7d34c421eb0c4a136a150e4c80d4.receipt.json b/vision-fixhub/ds9-unparsed-05/e66abf44a285746785dc7d9bf28f3ed0659c7d34c421eb0c4a136a150e4c80d4.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..54490a2605da01757118e6338d441c375cc99f32
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e66abf44a285746785dc7d9bf28f3ed0659c7d34c421eb0c4a136a150e4c80d4.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1785,
+  "dataset": "marble-joined",
+  "doc_id": "e66abf44a285746785dc7d9bf28f3ed0659c7d34c421eb0c4a136a150e4c80d4",
+  "engine": "marble-apple-vision",
+  "event_count": 28,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "c56a208f45712efd95e444d288e3a8670fef3fe70a1efe1a2d61858f718b934b",
+  "output_sha256": "821ccfbe73a38fabd4d7b5412adc39ca3845533ccaccabf8229f19ea2118e48a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e68e84ad8e83f6a2cb63df340df203331f08dca9ffd2d2579e848966e535b95f.md b/vision-fixhub/ds9-unparsed-05/e68e84ad8e83f6a2cb63df340df203331f08dca9ffd2d2579e848966e535b95f.md
new file mode 100644
index 0000000000000000000000000000000000000000..4dfc88f94b9cd69bb9dbce40811dbf688cb599da
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e68e84ad8e83f6a2cb63df340df203331f08dca9ffd2d2579e848966e535b95f.md
@@ -0,0 +1,505 @@
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+D.
+= 2008
+VIA UNITED STATES MAIL
+B-98
+Re:
+Jeffrey Epstein/
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office hereby pen.
+fice
+that the U,S. Attorney's Office has learned that Jeffrey Epstein has applied to participate in m- alm
+Beach County Sheriff's Office's ("PBSO") work release program, and PBSO has granted that
+application. Mr. Epstein is reportedly working for The Florida Science Foundation at 250 South
+Australian Avenue, Suite 1404, West Palm Beach, FL 33401. After work each day, Mr. Epstein
+returns to the Palm Beach County Stockade. While outside the Stockade, Mr. Epstein is
+electronically monitored via a GPS system and an ankle bracelet. Pursuant to the work release rules,
+Mr. Epstein is to go directly from the Stockade to his office, remain at the office throughout the work
+day, and then return directly to the Stockade.
+We regret that we were unable to inform you of these developments prior to Mr. Epstein's
+release, but our Office was never notified of Mr. Epstein's application, and we only learned of his
+release more than six weeks after he began participating in the program. Should vou have any
+questions regarding the work release nragram, please direct your inquiries to
+Palm Beach Sheriff's Office,
+. You also can ask
+to add the addresses
+where you live, work, and/or attend school to the list of Mr. Epstein's "Exclusionary Zones," which
+are programmed into his GPS system.
+It is my understanding that you have not retained counsel to represent you with regard
+to any litigation against Mr. Epstein. It is important that you inform me if you do hire an
+attorney so that I may communicate with you through that attorney, or if you change your
+address or telephone number. As 1 mentioned in my earlier correspondence, Robert
+Josefsberg and his firm were selected by an independent Special Master to represent the
+identified victims of Mr. Epstein with certain limitations, which Mr. Josefsberg can explain.
+
+
+DECEMBER 9,2008
+
+Again, you have no obligation to select Mr. Josefsberg as your counsel, but if you would like
+to have Mr. Josefsberg represent you, you must contact him or his partner, Katherine Ezell,
+directly. at
+via e-mail at
+(If you contact them via e-mail please reference Mr. Epstein in your
+e-mail.) Please note that, even if you decide not to pursue a claim against Mr. Epstein, Ms.
+Ezell has put together a team of counselors who can assist you with any counseling or other
+services that you might need. You also can continue to contact the FBI's Victim Services
+Coordinator, Twiler|
+, at
+My best wishes for l peaceful holiday season.
+R. Alexander Acosta
+By:
+Assistant O.s. Atomney
+,, Esq.
+:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach. EL 33401
+December 9, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein
+Notification of Work Release
+Dear Ms
+By virtue of this letter, the United States Attorney's Office hereby provides you with notice
+that the U.S. Attorney's Office has learned that Jeffrey Epstein has applied to participate in the Palm
+Beach County Sheriff's Office's ("PBSO") work release program, and PBSO has granted that
+application. Mr. Epstein is reportedly working for The Florida Science Foundation at 250 South
+Australian Avenuc, Suite 1404, West Palm Beach, FL 33401. After work each day, Mr. Epstein
+returns to the Palm Beach County Stockade. While outside the Stockade, Mr. Epstein is
+electronically monitored via a GPS system and an ankle bracelet. Pursuant to the work release rules,
+Mr. Epstein is to go directly from the Stockade to his office, remain at the office throughout the work
+day, and then return directly to the Stockade.
+We regret that we were unable to inform you of these developments prior to Mr. Epstein's
+release, but our Office was never notified of Mr. Epstein's application, and we only learned of his
+release more than six weeks after he began participating in the program. Should you have any
+questions regarding the work release program, please direct your inquiries to Captain
+Palm Beach Sheriff's Office,
+You also can ask Captain
+Hill to add the addresses
+where you live, work, and/or attend school to the list of Mr. Epstein's "Exclusionary Zones," which
+are programmed into his GPS system.
+It is my understanding that you have not retained counsel to represent you with regard
+to any litigation against Mr. Epstein. It is important that you inform me if you do hire an
+attorney so that 1 may communicate with you through that attorney, or if you change your
+address or telephone number. As I mentioned in my earlier correspondence, Robert
+Josefsberg and his firm were selected by an independent Special Master to represent the
+identified victims of Mr. Epstein with certain limitations, which Mr. Josefsberg can explain.
+
+
+
+Again, you have no obligation to select Mr. Josefsberg as your counsel, but if you would like
+to have Mr. Josefsberg represent you, you must contact him or his partner, Katherine Ezel!,
+directly at
+or via e-mail at il
+and
+(If you contact them via e-mail please reference Mr. Epstein in your
+e-mail.) Please note that, even if you decide not to pursue a claim against Mr. Epstein, Ms.
+Ezell has put together a team of counselors who can assist you with any counseling or other
+services that you might need. You also can continue to contact the FBI's Victim Services
+Coordinator, MI
+at l
+My best wishes for a peaceful holiday season.
+R. Alexander Acosta
+By:
+Assistant U.S. Attorney
+1, Esq.
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+December 9, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+: Notification of Work Release
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office hereby provides you with notice
+that the U.S. Attorney's Office has learned that Jeffrey Epstein has applied to participate in the Palm
+Beach County Sheriff's Office's ("PBSO") work release program, and PBSO has granted that
+application. Mr. Epstein is reportedly working for The Florida Science Foundation at 250 South
+Australian Avenue, Suite 1404, West Palm Beach, FL 33401. After work each day, Mr. Epstein
+returns to the Palm Beach County Stockade. While outside the Stockade, Mr. Epstein is
+electronically monitored via _ GPS system and an ankle bracelet. Pursuant to the work release rules,
+Mr. Epstein is to go directly from the Stockade to his office, remain at the office throughout the work
+day, and then return directly to the Stockade.
+We regret that we were unable to inform you of these developments prior to Mr. Epstein's
+release, but our Office was never notified of Mr. Epstein's application, and we only learned of his
+release more than six weeks after he began participating in the program. Should you have any
+questions regarding the work release program, please direct your inquiries to Captain
+Palm Beach Sheriff's Office, |
+• You also can ask Captain
+to add the addresses
+where you live, work, and/or attend school to the list of Mr. Epstein's "Exclusionary Zones," which
+are programmed into his GPS system.
+It is my understanding that you have not retained counsel to represent you with regard
+to any litigation against Mr. Epstein. It is important that you inform me if you do hire an
+attorney so that I may communicate with you through that attorney, or if you change your
+address or telephone number. As I mentioned in my earlier correspondence, Robert
+Josefsberg and his firm were selected by an independent Special Master to represent the
+identified victims of Mr. Epstein with certain limitations, which Mr. Josefsberg can explain.
+
+
+
+represent you, you must contact him or his partner,
+directly at
+Or
+via
+e-mail at
+and
+(If you contact them via e-mail please reference Mr. Epstein in your
+e-mail.) Please note that, even if you decide not to pursue | claim against Mr. Epstein, MS.
+has put together team of counselors who can assist you with any counseling or other
+services that you might need. You also can continue to contact the FBI's Victim Services
+Coordinator, LI
+at
+My best wishes for I peaceful holiday season.
+R. Alexander Acosta
+By:
+Assistant U.S. Attorney
+L. Esq.
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL. 33401
+Facsimile:
+December 9, 2008
+VIA UNITED STATES MAIL.
+Re: Jeffrey Epstein/
+|: Notification of Work Release
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office hereby provides you with notice
+that the U.S. Attorney's Office has learned that Jeffrey Epstein has applied to participate in the Palm
+Beach County Sheriff's Office's ("PBSO") work release program, and PBSO has granted that
+application. Mr. Epstein is reportedly working for The Florida Science Foundation at 250 South
+Australian Avenue, Suite 1404, West Palm Beach, FL 33401. After work each day, Mr. Epstein
+returns to the Palm Beach County Stockade. While outside the Stockade, Mr. Epstein is
+electronically monitored via | GPS system and an ankle bracelet. Pursuant to the work release rules,
+Mr. Epstein is to go directly from the Stockade to his office, remain at the office throughout the work
+day, and then return directly to the Stockade.
+We regret that we were unable to inform you of these developments prior to Mr. Epstein's
+release, but our Office was never notified of Mr. Epstein's application, and we only learned of his
+release more than six weeks after he began participating in the program. Should you have any
+questions regarding the work release program, please direct your inquiries to Captain
+Palm Beach Sheriff's Office,
+. You also can ask Captain
+to add the addresses
+where you live, work, and/or attend school to the list of Mr. Epstein's "Exclusionary Zones," which
+are programmed into his GPS system.
+It is my understanding that you have not retained counsel to represent you with regard
+to any litigation against Mr. Epstein. It is important that you inform me if you do hire an
+attorney so that I may communicate with you through that attorney, or if you change your
+address or telephone number. As I mentioned in my earlier correspondence,
+and his firm were selected by an independent Special Master to represent the
+identified victims of Mr. Epstein with certain limitations, which Mr.
+
+
+
+as your counsel, but if you would like
+represent you, you must contact him or his partner,
+directly
+at
+or
+via e-mail at
+and
+(If you contact them via e-mail please reference Mr. Epstein in your
+e-mail.) Please note that, even if you decide not to pursue | claim against Mr. Epstein, Ms.
+I has put together team of counselors who can assist you with any counseling or other
+services that you might need. You also can continue to contact the FBI's Victim Services
+Coordinator,
+at
+My best wishes for I peaceful holiday season.
+R. Alexander Acosta
+By:
+Assistant U.S. Attorney
+_ Esq.
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, Fl, 33401
+Facsimile:
+December 9, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+1: Notification of Work Release
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office hereby provides you with notice
+that the U.S. Attorney's Office has learned that Jeffrey Epstein has applied to participate in the Palm
+Beach County Sheriff's Office's ("PBSO") work release program, and PBSO has granted that
+application. Mr. Epstein is reportedly working for The Florida Science Foundation at 250 South
+Australian Avenue, Suite 1404, West Palm Beach, FL 33401. After work each day, Mr. Epstein
+returns to the Palm Beach County Stockade. While outside the Stockade, Mr. Epstein is
+electronically monitored via GPS system and an ankle bracelet. Pursuant to the work release rules,
+Mr. Epstein is to go directly from the Stockade to his office, remain at the office throughout the work
+day, and then return directly to the Stockade.
+We regret that we were unable to inform you of these developments prior to Mr. Epstein's
+release, but our Office was never notified of Mr. Epstein's application, and we only learned of his
+release more than six weeks after he began participating in the program. Should you have any
+questions regarding the work release program, please direct your inquiries to Captain
+Palm Beach Sheriff's Office,
+1. You also can ask Captain |
+to add the addresses
+where you live, work, and/or attend school to the list of Mr. Epstein's "Exclusionary Zones," which
+are programmed into his GPS system.
+It is my understanding that you have not retained counsel to represent you with regard
+to any litigation against Mr. Epstein. It is important that you inform me if you do hire an
+attorney so that I may communicate with you through that attorney, or if you change your
+address or telephone number. As I mentioned in my earlier correspondence,
+and his firm were selected by an independent Special Master to represent the
+identified victims of Mr. Epstein with certain limitations, which Mr.
+
+
+
+½ as your counsel, but if you would like
+: represent you, you must contact him or his partner.
+directly
+at
+or
+via
+e-mail
+at
+and
+(If you contact them via e-mail please reference Mr. Epstein in your
+e-mail.) Please note that, even if you decide not to pursue claim against Mr. Epstein, Ms.
+has put togetherla team of counselors who can assist you with any counseling or other
+services that you might need. You also can continue to contact the FBI's Victim Services
+Coordinator,
+at
+My best wishes ford peaceful holiday season.
+R. Alexander Acosta
+By:
+Assistant U.S. Attorney
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL. 33401
+Facsimile:
+December 9, 2008
+VIA UNITED STATES MAIL
+Ms. (
+Re:
+Jeffrey Epstein/
+Notification of Work Release
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office hereby provides you with notice
+that the U.S. Attorney's Office has learned that Jeffrey Epstein has applied to participate in the Palm
+Beach County Sheriff's Office's ("PBSO") work release program, and PBSO has granted that
+application. Mr. Epstein is reportedly working for The Florida Science Foundation at 250 South
+Australian Avenue, Suite 1404, West Palm Beach, FL 33401. After work each day, Mr. Epstein
+returns to the Palm Beach County Stockade. While outside-the Stockade, Mr. Epstein is
+electronically monitored via L GPS system and an ankle bracelet. Pursuant to the work release rules,
+Mr. Epstein is to go directly from the Stockade to his office, remain at the office throughout the work
+day, and then return directly to the Stockade.
+We regret that we were unable to inform you of these developments prior to Mr. Epstein's
+release, but our Office was never notified of Mr. Epstein's application, and we only learned of his
+release more than six weeks after he began participating in the program. Should YOU WIL
+questions regarding the work release program, please direct your inquiries to Captain |
+Palm Beach Sheriff's Office,
+You also can ask Captain
+•to add the addresses
+where you live, work, and/or attend school to the list of Mr. Epstein's "Exclusionary Zones," which
+are programmed into his GPS system.
+It is my understanding that you have not retained counsel to represent you with regard
+to any litigation against Mr. Epstein. It is important that you inform me if you do hire an
+attorney so that I may communicate with you through that attorney, or if you change your
+address or telephone number. As I mentioned in my earlier correspondence,
+and his firm were selected by an independent Special Master to represent the
+identified victims of Mr. Epstein with certain limitations, which Mr.
+
+
+
+Mas your counsel, but if you would like
+to have
+represent you, you must contact him or his partner,
+directly
+at
+Or
+via
+e-mail at
+and
+(If you contact them via e-mail please reference Mr. Epstein in your
+e-mail.) Please note that, even if you decide not to pursue claim against Mr. Epstein, Ms.
+has put together a team of counselors who can assist you with any counseling or other
+services that you might need. You also can continue to contact the FBI's Victim Services
+Coordinator, 1
+Lat:
+My best wishes for I peaceful holiday season.
+R. Alexander Acosta
+By:
+Assistant U.S. Attorney
+_ Esq.
+
+
+FILE COPY
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+December 9, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein
+: Notification of Work Release
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office hereby provides you with notice
+that the U.S. Attorney's Office has learned that Jeffrey Epstein has applied to participate in the Palm
+Beach County Sheriff's Office's ("PBSO") work release program, and PBSO has granted that
+application. Mr. Epstein is reportedly working for The Florida Science Foundation at 250 South
+Australian Avenue, Suite 1404, West Palm Beach, FL 33401. After work each day, Mr. Epstein
+returns to the Palm Beach County Stockade.
+While outside the Stockade, Mr. Epstein is
+electronically monitored via GPS system and an ankle bracelet. Pursuant to the work release rules,
+Mr. Epstein is to go directly from the Stockade to his office, remain at the office throughout the work
+day, and then return directly to the Stockade.
+We regret that we were unable to inform you of these developments prior to Mr. Epstein's
+release, but our Office was never notified of Mr. Epstein's application, and we only learned of his
+release more than six weeks after he began participating in the program. Should you have any
+questions regarding the work release program, please direct your inquiries to Captain
+Palm Beach Sheriff's Office,
+. You also can ask Captain|
+to add the addresses
+where you live, work, and/or attend school to the list of Mr. Epstein's "Exclusionary Zones," which
+are programmed into his GPS system.
+It is my understanding that you have not retained counsel to represent you with regard
+• to any litigation against Mr. Epstein. It is important that you inform me if you do hire an
+attorney so that I may communicate with you through that attorney, or if you change your
+address or telephone number. As I mentioned in my earlier correspondence,
+and his firm were selected by an independent Special Master to represent the
+identified victims of Mr. Epstein with certain limitations, which Mr.
+
+
+
+represent you, you must contact him or his partner,
+directly at
+via
+e-mail
+and
+(If you contact them via e-mail please reference Mr. Epstein in your
+e-mail.) Please note that, even if you decide not to pursue _ claim against Mr. Epstein, Ms.
+has put together team of counselors who can assist you with any counseling or other
+services that you might need. You also can continue to contact the FBI's Victim Services
+Coordinator,
+, at
+My best wishes for I peaceful holiday season.
+R. Alexander Acosta
+By:
+Assistant U.S. Attorney
+,, Esq.
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+December 9, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein
+: Notification of Work Release
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office hereby provides you with notice
+that the U.S. Attorney's Office has learned that Jeffrey Epstein has applied to participate in the Palm
+Beach County Sheriff's Office's ("PBSO") work release program, and PBSO has granted that
+application. Mr. Epstein is reportedly working for The Florida Science Foundation at 250 South
+Australian Avenue, Suite 1404, West Palm Beach, FL 33401. After work each day, Mr. Epstein
+returns to the Palm Beach County Stockade. While outside the Stockade, Mr. Epstein is
+electronically monitored vial GPS system and an ankle bracelet. Pursuant to the work release rules,
+Mr. Epstein is to go directly from the Stockade to his office, remain at the office throughout the work
+day, and then return directly to the Stockade.
+We regret that we were unable to inform you of these developments prior to Mr. Epstein's
+release, but our Office was never notified of Mr. Epstein's application, and we only learned of his
+release more than six weeks after he began participating in the program. Should you have any
+questions regarding the work release program, please direct your inquiries to Captain
+Palm Beach Sheriff's Office,
+1. You also can ask Captain
+to add the addresses
+where you live, work, and/or attend school to the list of Mr. Epstein's "Exclusionary Zones," which
+are programmed into his GPS system.
+It is my understanding that you have not retained counsel to represent you with regard
+to any litigation against Mr. Epstein. It is important that you inform me if you do hire an
+attorney so that I may communicate with you through that attorney, or if you change your
+address or telephone number. As I mentioned in my earlier correspondence,
+Land his firm were selected by an independent Special Master to represent the
+identified victims of Mr. Epstein with certain limitations, which Mr.
+
+
+
+represent you, you must contact him or his partner.
+directly
+at
+via e-mail at
+and
+(If you contact them via e-mail please reference Mr. Epstein in your
+e-mail.) Please note that, even if you decide not to pursue claim against Mr. Epstein, Ms.
+has put together team of counselors who can assist you with any counseling or other
+services that you might need. You also can continue to contact the FBI's Victim Services
+Coordinator, 1
+at
+My best wishes for peaceful holiday season.
+R. Alexander Acosta
+By:
+Assistant U.S. Attorney
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+December 9, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+1: Notification of Work Release
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office hereby provides you with notice
+that the U.S. Attorney's Office has learned that Jeffrey Epstein has applied to participate in the Palm
+Beach County Sheriff's Office's ("PBSO") work release program, and PBSO has granted that
+application. Mr. Epstein is reportedly working for The Florida Science Foundation at 250 South
+Australian Avenue, Suite 1404, West Palm Beach, FL. 33401. After work each day, Mr. Epstein
+returns to the Palm Beach County Stockade.
+While outside the Stockade, Mr. Epstein is
+electronically monitored via [ GPS system and an ankle bracelet. Pursuant to the work release rules,
+Mr. Epstein is to go directly from the Stockade to his office, remain at the office throughout the work
+day, and then return directly to the Stockade.
+We regret that we were unable to inform you of these developments prior to Mr. Epstein's
+release, but our Office was never notified of Mr. Epstein's application, and we only learned of his
+release more than six weeks after he began participating in the program. Should you have any
+questions regarding the work release program, please direct your inquiries tol
+Palm Beach Sheriff's Office,
+. You also can ask Captain
+to add the addresses
+where you live, work, and/or attend school to the list of Mr. Epstein's "Exclusionary Zones," which
+are programmed into his GPS system.
+It is my understanding that you have not retained counsel to represent you with regard
+to any litigation against Mr. Epstein. It is important that you inform me if you do hire an
+attorney so that I may communicate with you through that attorney, or if you change your
+address or telephone number. As I mentioned in my earlier correspondence,
+and his firm were selected by an independent Special Master to represent the
+identified victims of Mr. Epstein with certain limitations, which Mr.
+
+
+MS. !
+
+½ as your counsel, but if you would like
+¿ represent you, you must contact him or his partner.
+directly
+at
+Or
+via
+e-mail at
+and
+. (If you contact them via e-mail please reference Mr. Epstein in your
+e-mail.) Please note that, even if you decide not to pursuel claim against Mr. Epstein, Ms.
+• has put together a team of counselors who can assist you with any counseling or other
+services that you might need. You also can continue to contact the FBI's Victim Services
+Coordinator,
+1, at
+My best wishes for peaceful holiday season.
+R. Alexander Acosta
+By:
+Assistant U.S. Attorney
+- I am very concerned about you.
+Please call Tom,me
+or
+just to let us know that you
+me
+are okay.
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/e68e84ad8e83f6a2cb63df340df203331f08dca9ffd2d2579e848966e535b95f.receipt.json b/vision-fixhub/ds9-unparsed-05/e68e84ad8e83f6a2cb63df340df203331f08dca9ffd2d2579e848966e535b95f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2b53c703e0acb22480f51ad9803d9124623a5a8a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e68e84ad8e83f6a2cb63df340df203331f08dca9ffd2d2579e848966e535b95f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -2359,
+  "dataset": "marble-joined",
+  "doc_id": "e68e84ad8e83f6a2cb63df340df203331f08dca9ffd2d2579e848966e535b95f",
+  "engine": "marble-apple-vision",
+  "event_count": 28,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "d0612be28fe0870b94aefdfa245b2815f7bcd085e18a19ad104472865b13bd61",
+  "output_sha256": "1656e04ccae1402c373328ae3d5f1295330954d8745f003101babf68b8d081ab",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e69f6f19f587cb5c6e8c4f7b62a73111256d28125f5f25beab42115a94b8ff09.md b/vision-fixhub/ds9-unparsed-05/e69f6f19f587cb5c6e8c4f7b62a73111256d28125f5f25beab42115a94b8ff09.md
new file mode 100644
index 0000000000000000000000000000000000000000..9a60235958bd25f820477207aeae7ef15c75e606
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e69f6f19f587cb5c6e8c4f7b62a73111256d28125f5f25beab42115a94b8ff09.md
@@ -0,0 +1,50 @@
+OLY-16
+
+
+TO: EVIDENCE CUSTODIAN
+CITY OF PALM BEACH
+POLICE DEPARTMENT
+PALM BEACH, FL
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-16
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Palm Beach County Courthouse
+Room 4-A
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+DATE AND TIME:
+September 1, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+ANY AND ALL EVIDENCE RECEIVED, SEIZED, AND/OR COLLECTED IN CONNECTION WITH
+THE INVESTIGATION OF JEFFREY EPSTEIN AND/OR ANY EMPLOYEE OR ASSOCIATE OF
+JEFFREY EPSTEIN.
+Specie Agdimate your compliance of aral buen anvestigation, date and time of your apearance with
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+August 25, 2006
+This subpoena is issued upon application
+of the
+*If not applicable, enter "none."
+Name, Address and Phone Number of Assistant UJ.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Rench, ET. 23401-6235
+Tel:
+Fax:
+To be used in lieu of AOLIO
+FORM ORD-227
diff --git a/vision-fixhub/ds9-unparsed-05/e69f6f19f587cb5c6e8c4f7b62a73111256d28125f5f25beab42115a94b8ff09.receipt.json b/vision-fixhub/ds9-unparsed-05/e69f6f19f587cb5c6e8c4f7b62a73111256d28125f5f25beab42115a94b8ff09.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..fedb9c4965fcb7e1c358dd25e990dc1691295479
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e69f6f19f587cb5c6e8c4f7b62a73111256d28125f5f25beab42115a94b8ff09.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "e69f6f19f587cb5c6e8c4f7b62a73111256d28125f5f25beab42115a94b8ff09",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "d9c0ba62898f00666c17e53115145be73e9ee9ccca1914447f5ff491f202b6ff",
+  "output_sha256": "1a0a3f663d3070a11107c2754b951eca3072e921327a858a24a46b6ce9ae1cba",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e78393f9a53595304429b251bf1a9cc9f069ce9720ae000ea1a221207b6487cb.md b/vision-fixhub/ds9-unparsed-05/e78393f9a53595304429b251bf1a9cc9f069ce9720ae000ea1a221207b6487cb.md
new file mode 100644
index 0000000000000000000000000000000000000000..634898aa28bd439d2836c53599ccee37e6f35ec6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e78393f9a53595304429b251bf1a9cc9f069ce9720ae000ea1a221207b6487cb.md
@@ -0,0 +1,15 @@
+-rom
+Sent:
+Subject:
+Monday, December 17, 2007 12:54 PM
+Hi Jeff - anything that I or the agents should be doing?
+And Nesbitt is all worked up because another agent and AUSA Nancy Quinlan are the subject of an OPR
+investigation for failing to properly confer with and notify victims. We seem to be in a Catch-22.
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Fax 561 820-8777
+Tracking:
+2243
+08-80736-CV-MARRA
+P-014444
diff --git a/vision-fixhub/ds9-unparsed-05/e78393f9a53595304429b251bf1a9cc9f069ce9720ae000ea1a221207b6487cb.receipt.json b/vision-fixhub/ds9-unparsed-05/e78393f9a53595304429b251bf1a9cc9f069ce9720ae000ea1a221207b6487cb.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a3ec197e144943f571e119c435733f9f6b02d7f1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e78393f9a53595304429b251bf1a9cc9f069ce9720ae000ea1a221207b6487cb.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "e78393f9a53595304429b251bf1a9cc9f069ce9720ae000ea1a221207b6487cb",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "91b4831e8245930ad80e861e4d3ed1fe397a8c387164623a477f23b99e3d9a29",
+  "output_sha256": "68f530c852904fde3f727786594e1a5cc5c8de965aea6c715194a0e156a43d68",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e784de37940e4417ad961fe31372ad08d7fa53bfc94cca013adaf4a65bf459d0.md b/vision-fixhub/ds9-unparsed-05/e784de37940e4417ad961fe31372ad08d7fa53bfc94cca013adaf4a65bf459d0.md
new file mode 100644
index 0000000000000000000000000000000000000000..e7c91ff1853cb079562010f5e3854e12c9b0c2ef
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e784de37940e4417ad961fe31372ad08d7fa53bfc94cca013adaf4a65bf459d0.md
@@ -0,0 +1,2019 @@
+1
+State nf Arlamare
+ECRETARY OF STAT
+VISION OF CORPORATION
+OVER, DELAWARE 10903
+
+MASTE BRIM BARCI
+33401
+
+8100H Certified - History
+1025 Incorp Delaware Sto 09-07-200
+
+8300
+Certificate in Re Short
+2
+
+Cortients tage Fee
+
+8200
+
+8200
+Certified Copy; certification fee
+
+05-17-2007
+AMOUNT
+38.00
+30.0
+1.0
+30.04
+1.00
+
+
+PAGE 2
+State of Drlamare
+
+
+WEST PALM BEACH
+ATTN:
+33401
+3284, 2C 6200 Certified Copy; A/R
+05-17-2007
+32046 2N 8200 Certified Copy: A/R
+3284, 2NC.
+Certified Copy; Certification ree
+TOTAL CHARGES
+TOTAL PAYMENTS
+CHARGED TO ACCOUNT
+AMOUNT
+1.00
+4.00
+4.00
+268.00
+340.00
+72.00CR
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+DELAWARE, DO HEREBY CERTIFY THE ATTACHED ARE TRUE AND CORRECT
+COPIES OF ALL DOCUMENTS ON FILE OF "JEGE, INC. " AS RECEIVED AND
+THE FOLLOWING DOCUMENTS HAVE BEEN CERTIFIED:
+CERTIFICATE OF INCORPORATION, FILED THE SEVENTH DAY OF
+SEPTEMBER, A.D. 2000, AT 2:15 O'CLOCK P.M.
+AND I DO HEREBY FURTHER CERTIFY THAT THE AFORESAID
+CERTIFICATES ARE THE ONLY CERTIFICATES ON RECORD OF THE
+AFORESAID CORPORATION, "JEGE, INC.".
+
+
+8100H
+OFLAWARE
+AUTHENTICATION: 5685185
+
+
+Sep-07-2000 01:50pm
+Fron-d Epstein & Company. Inc.
+2:23718042
+CERTIRICATE OF INCORPORATION
+OF
+The name of the corporation to be formed upon the filing of thi
+Certificate of Incorporation is JEGE, Inc. (the "Corporation")
+The address of the Corporation's registered office in the State of Delaware
+s Corporation Trust, 1209 Orange Street, in the City of Wilmington, County of Ner
+'astle. The name of the Corporation's registered agent at such address is Th
+The nature of the business to be conducted by the Corporation is, or the
+purposes to be promoted by the Corporation are, to engage in any lawful acts or activities
+tor which corporations may be organized under the General Corporation Law of the State
+of Delaware.
+he total number of shares of stock which the Corporation shall has
+thority to issue is One Thousand Five Hundred (1,500) shares of Common Stock, all ‹
+which shares shall be without par value.
+The name and mailing address of the sole incorporator of the Corporation
+are Darren Indyke, 457 Madison Avenue, Fourth Floor, New York, New York 10022.
+6.
+The Corporation is to have perpetual existence.
+In turtherance, and not in limitation, of the powers conferred by the
+Jeneral Corporation Law of the State of Delaware upon the board of directors of the
+Corporation, the board of directors of the Corporation is expressly authorized to make,
+alter or repeal the by-laws of the Corporation.
+Elections of the directors of the Corporation need not be by written ballot,
+unless the by-laws of the Corporation shall so provide.
+Meetings of the stockholders of the Corporarion may be held within or without
+the State of Delaware, as the by-laws may provide. The books of the Corporation may be
+kept (subject to any provision contained in the General Corporation Law of the State of
+Delaware) ourside the Stale of Delaware at such place or places as may be designate
+rom time to time by the board of directors or in the by-laws of the Corporation
+The Corporation reserves the right to amend, alter, change or repeal any
+provision contained in this Certificate of Incorporation, in the manner now or hereafter
+...
+
+
+Sep-0T-Z000 01:50pm
+Fron-J Epstein & Company, inc.
+
+prescribed by the General Corporation Law of the State of Delawaro, and all rights
+conferred in this Certificate of Incorporation upon the stockholders of the Corporation are
+granted subject to such reservation.
+10. A director of the Corporation shall not be personally liable to the
+Corporation or its stockholders for monetary damages for breach of fiduciary duty as a
+director, except for liability (a) for any breach of the director's duty of loyalty to the
+Corporation or its stockholders, (b) for acts or omissions not in good faith or which
+involve intentional misconduct or a knowing violation of law, (I under Section 174 of
+the General Corporation Law of the State of Delaware, or (d) for any transaction from
+which the director derived any improper personal benefit.
+I, THE UNDERSIGNED, being the sole incorporator hereinbefore named, for
+the purpose of forming a corporation pursuant to the General Corporation Law of the
+State of Delaware, hereby certify and declare that this is uny act and deed and that the
+facts stated herein are true, and have hereunto ser my hand this 7th day of September,
+2000.
+Darren K. Indyke
+Sole Incorporator
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "JEGE, INC. " AS FILED IN
+SECRET
+
+
+8200
+arriet Smith Windsor, Secretary of Sta
+UTHENTICATION: 568518
+
+
+I
+ANNUAL FRANCHISE TAX REPORT
+[COHPORATION HAME
+
+FEDERAL EMPLOYER IS NO.
+[RENEWAL/ REVOCATIOH DATE
+TTAXYR
+2001
+TUATE OF
+HACTIMTY
+TRIESROSS
+TPHONE HUMBER
+SCCSJLO
+FROM
+TNO. OF SHARES
+TRAR VAT DE/SHARE
+1,500
+-000000
+ASSET DATE
+ENEMERA BERRATED
+FRANCHISE TAX
+SODO PENALTY
+
+THE CORPORATICH TRUST COMPANY
+CORPORATION TRUST CENTER
+1209 ORANGE STREET
+WILMINGTON
+-00
+DE 19801
+$50.00 PENALTY I not Fiscalved on or before
+March 1. Plus 1.5% Interesiper month.
+TESS MONTHLY INTERES
+-OD
+TANTAPPROVED RESTORUAANCE
+20-00 L
+-00
+MAR 2 2 2002
+PREPAID ORTY. PAYMENTE
+48.80
+AMOUNT BUE
+1.20.
+
+DAVE RODGERS
+JEFE
+
+000000120 0
+MAKE CHECK PAYABLE TO:
+DELAWARE SECRETARY OF STATE
+CHECK NO
+1489
+,20
+3
+
+
+NATUR OF BUSINESS
+SENU INVOICE AND PAYMENT ONLY - NO ATTACHMENTS - NO ADDITIONAL PAGES
+NAME
+STREET/CITY/STATEZP
+1.
+2.
+3.
+4.
+Б.
+DO NOT WRITE IN THIS SPACE - FOR BANK USE ONLY
+:1233.
+OFFICERS
+= Vice President
+ORIGINAL SIGNATURE (OFFICER, DIRECTOR OR INCORPORATOR)
+X
+Janen Wage
+STHEET/CITY/STATEZIP
+457 NigelissAve Fourth Else, MY 'AY 10022.
+Vice Prescient
+4-1-02-
+
+
+1
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "JEGE, INC. " AS FILED IN
+SECRETA
+
+
+8200
+Varriet Smita Hindsor
+AUTHENTICATION: 5685188
+
+
+=3
+
+BOBOT
+2002 ANNUAL FRANCHISE TAX REPORT
+
+FEDERAL EMPLOYER IS NO.
+INCORPORATION DATE
+SEPTEMBER 7, 2000
+AUTHOFIZED STOCK
+TDESIGNATION
+TNO, OF SHARES
+BEGIN DATE
+ENDING DATE
+OR STOCK CLASS
+09-07-2000
+COMMON
+1,50€
+TRENEWAUHEVOCATION DATE
+DATE OF
+PAR VALUE SHARE
+TNO. SHARES
+INACTIVIT
+TORATE ROSES
+• DOODOO
+[PHONE NUMBER
+FROM
+ASSET DATE
+, то,
+[ASSETS FOR REGULATED
+INVESTMENT CORPS
+LAN 100
+FRANCHISE TAX
+850. DO PENALTY
+11.5% MONTHLY INTEREST
+$
+,00
+•00
+TANY. FILING FEE
+TPREY CREDIT OR BALANCE
+20.00
+•02
+TPREPAID ORTY. PAYMENTS
+5
+TAMOUNT BUE
+50.02
+MAKE CHECK PAYABLE TO:
+DELAWARE SECRETARY OF STATE
+CHECK NO.
+*TAMOUNT ENCLOSED
+
+THE
+CORPORATION TRUST
+CORPORATION TRUST CENTER
+1209 ORANGE STREET
+WILMINGTON, DE 19801
+2 030103
+
+000005002 0
+7
+$50.00 PENALTY I not Received on or before
+MAR 1, 2003 Plus 1.5% Intarest per month.
+
+
+SEND INVOICE AND PAYMENT OMLY - NO ATTACHMENTS - NO ADDITIONAL PAGES
+PRINCIPAL PLĂCE OF BUSINESS OUTSIDE OF DELAWARE
+1.
+2.
+NAME
+STREET/CITY/STATE/ZIP
+DO NOT WRITE IN THIS SPACE - FOR BANK USE ONLY
+STREET/CITY STATEZIE
+2.
+Vice fiesicient
+1-5-12.3
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "JEGE, INC. " AS FILED IN
+HERETARYS
+OREST
+
+
+8200
+Harriet Smita Hindson
+AUTHENTICATION: 5685189
+
+
+
+50SCT
+FILE NUMBEH
+
+FEDERAL EMPLOYER D NO.
+AUTHOHIZED STOCK
+BEGIN DATE:
+ENDING DATE
+09-67-2000
+APORATION NAME
+IJEGE: INÇ.
+TINGDAPORATION, DATE
+SEPTEMBER 7. 2000
+DESIONATION
+NO. OF SHARES
+OR STOCK CLASS
+COMMON
+1,500
+ISE TAX
+$100.00 PENALTY
+1,5% MONTALYINTERL
+S.
+#SHARE
+QOATION DATE
+NO. SHARES
+ISSUED
+A. FILING FEE
+25.00
+35.00
+PHONE NUMBER
+DATE OF
+INACTIVITY
+TTOTAL GROSS
+ASSETS.
+FROM
+ASSET DATE
+TASSETS FOR REGULATED
+INVESTMENT CORPS
+AN. te
+SEC. 318
+TPREY CREDIT OR BALANCE
+AID ORTY. PAYMENTS
+AMOUNT QUE
+60.00
+MAKE CHECK PAYABLE TO:
+DELAWARE SECRETARY OF STATE
+CHECKNO. : AMOUNT ENCLOSE
+REGİSTERED.
+AGENT.
+
+THE
+CORPORATION' TRUST
+ORPORATION TRUST CENTER
+1209
+• ORANGE STREET.*.
+WILMINGTON;: DE:
+19801
+2 0010 32848₴
+000006000 0 6
+$100.00, PENALTY It not Received On or before
+MAR 1. 2004 Plus 1,5% interest per month:
+
+
+UR
+RECTORS:
+: SEND INVOICE AND PAYMENT ONLY SING ATTACHMENTS: NO ADDITIONAL PAGES
+PANGRAL LACE OBSESSED DELAWARE
+NAMI
+STREETCILY/STATEZIP
+DO NOT WAITE iN
+THIS SPACE- FOR BANK USE ONLY
+111-20
+OFFICERS
+STREETICITY/STATEZIP
+= DATETEAM EXPIRES
+1-600
+Bee almale
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "JEGE, INC. " AS FILED IN
+
+
+8200
+Variet Smila Hindsor
+AUTHENTICATION: 5685190
+
+
+
+BOBCT
+MULA GRANOLE TAK REDORI
+
+FEDEMAL EMPLOTER TO NO.
+AUTHONIZED STOCK
+BEGIN DATE
+ENDING DATE
+09-07-2000
+CORPORATION NANE
+INCORPORATION DATE
+SEPTEMBER 7,
+2000
+DESIGNATION
+TWO. OF SHARES
+OR STOCK CLASS
+COMKON
+1,500
+RENEWAL/REVOCATION DATE
+PAR VALUE SHARE
+NO, SHARES
+ISSUED
+DATE OF
+INACTIVITY
+ITOTAL GROSS
+ASSETS
+PHONE NUMBER
+FROM
+ASSET DATE
+HANCHISE TAX
+$10d.00 PENALTY
+1.5% MONTHLY INTEREST
+35.00
+TANN. FILING FEE
+25.00
+PREV CREDIT OR BALANCE
+TO
+ASSETS FOR REGULATED
+INVESTMENT CORPE
+JAN. 1al
+DEC. 31Gt
+PREPAID ORTY. PAYHENTS
+THE CORPORATION
+
+TRUST
+CORPORATION TRUST
+CENTER
+1209 ORANGE STREET
+WILMINGTON, DE 19801
+AMOUNT DUE
+60.00
+MAKE CHECK PAYABLE TO:
+DELAWARE SECRETARY OF STATE
+CHECK NO.: AMOUNT ENCLOSED
+$100.00 PENALTY I not Recalved on or before
+MAR I, 2005 Plus 1.5% Interast per month
+
+
+000006000 0 5*
+
+
+[NATURE OF BUSINESS
+VIUL ANU FAIMÇNI UNLT • NU AI IACHMENTS - NO ADITIONAL PAGES
+PRINCIPAY PLACERSE BUSINESS OUTSIDE OF DELAWARE
+DOTTSTATERr
+5.
+DO NOT WRITE IN THIS SPACE - FOR BANK USE ONLY
+2s46
+BT 01/18/85
+OFFICERS
+483K
+12:
+NANE
+STREET/OITY/STATEZP
+ORIGINAL SIGNATURE (OFFICER, DIRECTOR OR INCORPORATOR)
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "JEGE, INC." AS FILED IN
+
+
+8200
+Variet Smits Hindson
+AUTHENTICATION: 5685191
+
+
+
+2005 ANNUAL FRANCHISE TAX REPORT
+[FICE NUMBER
+CORPORATION HAME
+
+FEDERAL EMPLOVEATE NO.
+TINCORPORATION DATE
+SEPTEMBER T, 2000
+REGIN DATE TO ENDING DATE OR STOCK CLASS
+THO. OF SHAREE
+BEGIN DATE
+09-07-2000
+COMMON
+1,500
+THENE WALREVOCATION BATE
+[FAR VALUE SHARE
+THO: SHARES
+ISSUED
+DATE OF
+INACTIVITY
+TOTAL GROSS
+ABBETS
+TPHONE NUMBER
+TRON
+TASSET DATE
+ASSETS FOR REGULA
+WIVESTENT CORPS
+FRANCHISE TAX
+$100.06 PENALTY
+[1.5% MONTHLY INTEREST
+35.00
+100.00
+2.26
+TANN. FILING FEE
+25.00
+LEGISTERED AGENT
+
+HE CORPORATION TRUST COMPANY
+CORPORATION TRUST_CENTER
+209 ORANGE STREE
+ILMINGTON, DE 1980
+PREY CREDIT. Of BALANCE
+PREPAID ORTY. PAYMENTS
+60.00 CRs
+AMSUN GUE
+102.26
+MAKE CHECK PAYABLE TO:
+DELAWARE SECRETARY OF STATE
+(CHECK NO.
+TAMOUNT ENCLOS
+00.00 PENALTY If not Received on or beft
+AR 1, 2006 Plus 1.5% Interest per mon
+2
+
+
+000030226 0
+4
+
+
+• SEND INVOICE AND PAYMENT ONLY - NO ATTACHMENTS - NO ADDITIONAL PAGES
+NAME
+STREETICITY/STATE/ZIP
+1.
+2.
+3.
+4.
+5.
+6.
+DO NOT WRITE IN THIS SPACE - FOR BANK USE ONLY
+OFFICERS
+NAME
+STREET/CITY STATEZIP
+2.
+1-11-06
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "JEGE, INC. " AS FILED IN
+COBETAH
+
+
+8200
+Variet Smila Hindson
+AUTHENTICATION: 5685192
+05-17-07
+
+
+SEND INVOICE AND PAYMENT ONLY - NO ATTACHMENTS - NO ADDITIONAL PAGES
+HAME
+STREET/CITY/STATE ZP
+DO NOT WRITE IN THIS SPACE - FOR BANK USE ONLY
+OFFICERS
+NAME
+STREET/CITY/STATE/ZIP
+SIGNAT
+CER, DIRECTOR OR INCORPORATOR)
+seen
+
+
+State of Drlamare
+WEST PALM BEACH
+ATTN:
+33401
+
+8300 Certificate in Re Short
+* ITEMS WERE PREVIOUSLY BILLED
+
+8100H Certified - History
+01025 Incorp Delaware Sto 07-18-1991
+Change of Agent
+09-19-1996
+0133 Change of Agent
+01-13-1997
+* ITEMS WERE PREVIOUSLY BILLED
+HYPERSON BROCertified Copy; A/R
+
+* ITEMS WERE PREVIOUSLY BILLED
+
+8200
+* ITEMS WERE PREVIOUSLY BILLED
+2268758N B2 C.
+
+* ITEMS WERE PREVIOUSLY BILLED
+4
+1
+1
+
+05-23-2007
+AMOUNTI
+*
+38.00
+32.00
+32.00
+*
+90.00
+12.00
+102.00
+1. 00
+32.00
+38.00
+
+
+PAGE 2
+State of Arlamare
+
+
+505 s.
+FLAGLER DRIVE
+WEST PALM BEACH
+FL
+ATTN:
+33401
+
+* ITEMS WERE PREVIOUSLY BILLED
+
+* ITEMS WERE PREVIOUSLY BILLED
+
+* ITEMS WERE PREVIOUSLY BILLED
+
+* ITEMS WERE PREVIOUSLY BILLED
+HYPERION AIR, Certified Copy; A/R
+* ITEMS WERE PREVIOUSLY BILLED
+05-23-2007
+AMOUNT
+:
+30.0
+1.0
+:
+1.00
+*
+*
+4.00
+4.00
+*
+4.00
+
+
+3
+State nf Delamare
+P.O. BOX 89E
+
+
+WEST PALM BEACH
+ATTN:
+33401
+
+* ITEMS WERE PREVIOUSLY BILLED
+HYPERION AIR,
+
+8200
+certification Fee
+05-23-2007
+:
+*
+AMOUNT
+38.00
+38.00
+* ITEMS WERE PREVIOUSIY BILLED
+
+*
+* ITEMS WERE PREVIOUSLY BILLED
+HYPERION AIR,
+INC.
+
+8200
+* ITEMS WERE PREVIOUSLY BILLED
+* ITEMS WERE PREVIOUSLY BILLED
+*
+*
+1.0
+30.01
+1.0
+38.00
+
+
+4
+State nf Arlamare
+P.O. BOX 89B
+
+
+WEST PALM BEACH
+FL
+ATTN:
+33401
+
+certified copy Cocument ago see
+* ITEMS WERE PREVIOUSLY BILLED
+
+HYPERTON 82. Certified Copy: 2/8
+* ITEMS WERE PREVIOUSLY BILLED
+FILING IOTAL
+TOTAL CHARGES
+TOTAL PAYMENTS
+CHARGED TO ACCOUNT
+05-23-2007
+:
+*
+AMOUNT
+38.00
+4.00
+640.00
+946.00
+306.00CR
+
+
+1
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+DELAWARE, DO HEREBY CERTIFY "HYPERION AIR, INC. " IS DULY
+INCORPORATED UNDER THE LAWS OF THE STATE OF DELAWARE AND IS IN
+GOOD STANDING AND HAS A LEGAL CORPORATE EXISTENCE SO FAR AS THE
+RECORDS OF THIS OFFICE SHOW, AS OF THE IWENTY-THIRD DAY OF MAY,
+A. D.
+2007.
+
+
+8300
+Variet Smila Hindson
+AUTHENTICATION: 5698210
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+DELAWARE, DO HEREBY CERTIFY THE ATTACHED ARE TRUE AND CORRECT
+COPIES OF ALL DOCUMENTS ON FILE OF "HYPERION AIR, INC. " AS
+RECEIVED AND FILED IN THIS OFFICE.
+THE FOLLOWING DOCUMENTS HAVE BEEN CERTIFIED:
+CERTIFICATE OF INCORPORATION, FILED THE EIGHTEENT DAY OF
+JULY, A.D. 1991, AT 2:30 O'CLOCK P.M.
+CERTIFICATE OF CHANGE OF REGISTERED AGENT, FILED THE
+NINETEENTH DAY OF SEPTEMBER, A.D. 1996, AT 9 O'CLOCK A.M.
+CERTIFICATE OF CHANGE OF REGISTERED AGENT, FILED THE
+THIRTEENTH DAY OF JANUARY, A.D. 1997, AT 9 O'CLOCK A.M.
+AND I DO HEREBY FURTHER CERTIFY THAT THE AFORESAID
+CERTIFICATES ARE THE ONLY CERTIFICATES ON RECORD OF THE
+AFORESAID CORPORATION, "HYPERION AIR, INC.".
+CRETARY.
+
+
+8100H
+Varriet Smies Hindson
+AUTHENTICATION: 5698211
+
+
+'ECRETARY OF STAT
+FILED 02:30 PM 07/18/1991
+751199007 - 2268758
+CERTIFICATE OF INCORPORATION
+OF
+1
+FIRST: The name of the corporation hereinafter called the "corporation")
+is HYPERION AIR, INC.
+SECOND: The address, including street, number. city, and county. of the
+registered office of the curporation in the State of Delaware is
+t; and the name of the registered agent of the
+corporation in the State of Delaware at such address is The Prentice-Hall Corporation
+System, Inc.
+THIRD: The purpose of the corporation is to engage in any lawful act ur
+activity for which corporations may be organized under the General Corporation Law of the
+FOURTH: The total number of shares uf stock which the corporation shall
+have authority to issue is one thousand five hundred. The par value of each of such shares
+is one tenth of a mill. All such shares are of one class and are shares of Common Stock.
+FIFTH: The name and the mailing address of the incorporator are as follows:
+NAME
+MAILING ADDRESS
+Athena Togias
+SIXTH: The corporation is to have perpetual existence.
+-1.
+20°d
+0294 ELE 218-01
+......
+
+
+SEP-19-96 THU 14:47
+NCR PH# 734-1450
+P. 02
+:
+ELED 09:00 AM 09/19/19
+60272031 - 22687:
+:
+-
+_ CERTIPICATE OF CHANGE OF LOCATION OF REGISTERRD OFFICE
+AND OF REGISTERED AGENT
+It is hereby certilled that:
+HYPERION AIR. Te MO Of the corporatioa fiercinafer clad the "corporation" is
+hereby changed. respited ofte fe on onto er lie tol, Sue or Dreame is
+3. The registered agent of the corportion within the State of Delaware is
+hereby changed to National Ragintered Agents, Inc., the business office of which is Identical
+with the regiatered office of the corporation as hereby changed.
+4. The corporation has authorized the changes bertiubefore set forti by
+resolution of its Board of Directors.
+Signed on August 21,1996.
+JettIey Epstein
+
+
+CERTIFICATE OF CHANGE OF LOCATION OF REGISTERED
+OFFICE AND REGISTERED AGENT
+OF
+The Board of Directors of:
+• Corporation of the state of Dalanara, on this 13#
+. day or
+January A.D. 1997, do hereby resolve and order that the
+location of the Registered Office of tnis Corporation within this
+stato ba, and the same heraby is:
+1013 Cantre Road, In the City of WIlmington, In the County
+of New Castle, Delaware, 19805.
+The name of the Registered Agent therein and in charge thereaf
+upon whom process against the Carporation may be servad, 1s:
+CORPORATION SERVICE COMPANY.
+a Corporation of the State of Delaware, does hereby certify that the
+foregoing is a true copy of a resolution adopted by the Board of
+Directors at a meeting
+held as herein stated.
+IN WITNESS WHEREOF, sald corporation has caused this
+cortericate to be signed by Jeffrey Epstein
+•
+this
+13M
+day of January
+A. D. 1997.
+crated orficer
+Jeffrey
+Epstein
+STATE OF DELANARE
+FILED
+09:00 AM 01/13/1997
+971012574 - 2268758
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "HYPERION AIR, INC. " AS
+20
+
+
+8200
+SLAWARE
+AUTHENTICATION: 5698212
+
+
+
+Franchise Tax
+State of Delauare
+SEND ORIGINAL COPY - RETURN ENTINE COPY - UU NUT SEND PHOTOCOFIEE - DU NUL WELALA ELUD
+1991 ANNUAL FRANCHISE TAX REPORT
+FORM
+MICHAEL N. CASTLE, Gavernor
+MICHAEL HARKINS, Secretary of State
+Phone (302) 735-4225
+1. AGENT 8000012
+THE PRENTICE-HALL CORPORATION SYSTEM, INC.
+32 LOOCKERMAN SQUARE
+SUITE L-100
+DOVER
+DE 19901
+BO NOT ALTEN FILE NUMBER
+2. FILE NUMBER
+
+3. INCORFORATION DATE
+07/18/1991
+4. NATURE OF BUSINEES Own and
+Operate private aireraft
+2: ATIN BATE 8 ENDING DATE
+L GESIGNATIOI
+IR STOCK CLAS
+07/18/91
+CONMON
+2
+
+MENEWAL DATE
+REVOCATION DATE
+FEDERAL EMPLOVER ID. NO.
+TYPE
+GENERAL
+E. PRINCIPAL PLACE OF BUSINESS OUTSIDE OF DELAWARE
+None
+a. s0. OF SHARES
+1,500
+.0001
+
+s. R
+8
+PHONE NUMBER
+SEG. NO.
+OR3E0E
+BT-NR
+ETEA
+DATE MON
+• ISRA GROSS
+L
+27 10
+H. ASSET DAIE
+12/31/91
+8. A. PRANCHISE TAX
+. 800.GO PENA-T
+LAPLICARLE
+. 00
+1% MONTPL"
+TA MONTRALTY TER APPLIC.
+TD. AANUAL FILING PEE E BEY CREDIT OR BALANEZ * PATREN QUARTERLY
+.CO
+20.00
+9. ASSETS FOR REGULATED INVESTMEN" CORPS
+DEDUCT PAYMENTS
+MADE AFTER
+G. QUARIERLY INTERESTICHECK CHO.
+Jan, Jat
+Dec. 31st
+11/19/81
+10. APPOINTED DATE OF NEXT ANNUAL MEETING OF STOCKHOLDERS TO ELECT DIRECTORS
+11. CIRECTORS
+VAME
+STREET/CH Y/STATE/ZIF
+JeCtrey E. Epatein
+358 R1 Rrillo Was
+Palm Beach, FL
+TOTAL PAYMENT DUE
+$
+(MM/DD/YY)
+50.00
+T
+CATE TERM EXPIRES
+12. CFFICERS
+NAME
+PRESIDENT Jef[rey E. Epstein
+VICE-PRESIDENT
+SECRETARY Jeffrey E.
+Epstein
+TREASURER Jeffrey E. Epetein
+OTHER OFFICERS
+13. ORIGINAL SIGNATURE (OFFICER, DIRECTÓR OR INCORPORATOM)
+X
+STRECT/CITY/STATE/2IP
+358 EL Brillo Way
+Palm Beach, PL
+358 EI Brillo Way Palm Beach, FL
+358 B1 Brillo Way
+Palm Beach, TL
+Dren
+4/27/7
+
+
+Delarare
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "HYPERION AIR, INC. " AS
+
+
+8200
+DELAWARE.
+Harriet Smith Windsor, Secretary of Stat
+IUTHENTICATION: 569821.
+
+
+
+1992 ANNUAL FRANCHISE TAX REPORT
+FILE NUMSER
+
+PHONE NUMBER
+AUTHORIZED STOCK
+DESIGMATION
+1891
+NO. OF SHARES
+BEGIN DATE
+ENDING DATE
+07/18/91
+OR STOCK CLASS
+CONMON
+1:500
+RENEWAL / REVOCATION DATE
+PAR VALUE / SHARE NO. SHARES
+ISSUED
+
+1,500
+FEROT FRIE ID NO.
+DATE O
+INACTIVITI
+TOTAL GROSS
+ASSET DATE
+ASSETS
+FROM
+ASSETS FOR REGULAT
+IVESTMENT COR
+FRANCHISE TAX
+55000 PENALTY
+- 0p
+
+THE PRENTICE-HALL CORPORATION SYSTEM, INC.
+32 LOCKERHAN SQUARE
+SUITE L-100
+DOVER, DE 19901
+* $50.00 PENALTY if not Received on or before
+March 1, 1993
+1.5% MONTHLY INTEREST QUARTERLY INTEREST
+ANN. FILING FEE
+PREY CREDIT OR BALANCE PREPAID QRTY. PAYMENTS
+.00
+00
+20.00
+.00
+AMOUNT DUE
+1 00
+50.00
+MAKE CHECK PAYABLE TO
+DELAWARE SECRETARY OF STATE
+CHECK NO.
+AMGUNT ENCLOSED
+1232
+550-
+2
+
+
+7
+
+
+Own and operate private aircraft
+APPOINTED DATE OF NEXT ANNUAL MEETING OF STOCKHOLDERS TO ELECT DIRECTORS
+(MM/DD/YY)
+6222: TuRn cori
+1. Jeffrey E. Epstein
+NAME
+STREETICITY/STATEZIP
+358 El Brillo Way, Palm Beach, FL Until succeeded
+2.
+3:
+4.
+OFFICERS
+1. President
+1 Secretary
+3. Ireasurer
+NAME
+Jeffrey E. Epstein
+Jeffrey E. Epstein
+Jeffrey E. Epstein
+ORIGINAY/SICNATUNE (OFFICER, DIKECTOR OR INCORFORATOR)
+STREETICITY/STATEIZIP
+358 El Brillo Way, Palm Beach, FL
+358 EL Brillo Waye Palm Beach, RI
+358 E1 Brillo Way, Palm Beach, FL
+PRESIDENT
+Until succeeded
+Until succeeded
+Until succeeded
+2-17-93
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "HYPERION AIR, INC. " AS
+SECRETARY
+
+
+8200
+Varriet Smits Hindsor
+AUTHENTICATION: 5698214
+
+
+
+1993 ANNUAL FRANCHISE TAX REPORT
+
+THONE NUMBER.
+UTHORIZED STOCI
+EGIN DAT
+ENDING DATE
+07/18/91
+CORFORATION NAME
+HYPERTON AIR. INC.
+ДИСОКРОВ 097 1671881
+DESIONATTON
+TNO. OF SHARIS
+OR STOCE CLASS
+COMMON
+1,500
+FRANCILSE TAX
+T$50.00 PENALTY
+30.00g
+T1.S% MONTHLY INTHREST QUARTERLY INTEREST
+.00 s
+Registered Agent 8000012
+THE PRENTICE-HALL CORPORATION SYSTEM, INC.
+32 LOCKERMAN SQUARE
+SUITE L-100
+DOVER, DE 19901
+FEDIRAL FARE RED NO.
+TRENERAL/ REVOCATON DATE
+PAR YALUE/SHARE
+SOUTHARES
+0.000100
+1,500
+TO
+TOTAL GROS
+ASSET DATE
+SSET
+SSETS BOR RAGULAT
+VESTMENT COR
+Jes. lat
+Dee. 31rt
+.00 s
+ANN. FILING FEE
+PREV. CREDIT OR BALANCE
+20.00 s
+TERRAID ORTY. PAYMENTS
+.00
+AMOUNT DUE
+00
+50.00
+MAKE CHECK PAYABLE TO:
+DELAWARE SECRETARY OF STATE
+CERCENO
+$50.00
+Mad 1, ALT I or Recited on or before.
+2
+
+
+
+
+NATURE OF HUSINESS
+PRINCIPAL, PLACE OF BUSINESS OUTSIDE OF DELAWARE
+OWN AND OPERATE PRIVATE AIRCRAFT
+SEND INVOICE AND PAYMENT ONLY — NO ATTACHMENTS — NO ADDITIONAL PAGES
+JEFFREY E. EPSTEIN
+NAME
+358 EL BETELY, PALM BEACH, FL
+02/24/94 0002 01426 2249752 084158 65 81 83
+1.
+2.
+OFFICERS
+NAME
+PRESIDENT
+JEFFREY E.
+EPSTEIN
+SECRETARY/ TREASURER
+JEFFREY E. EPSTEIN
+ORIGINAL SIGNATURE (OFFICER, DIRECTOR OR INCORPORATOR)
+358 EL BELO GETAW BEACH, FL.
+358 EL BRILLO MAY, PALM BEACH, FL
+fendant
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "HYPERION AIR, INC. " AS
+
+
+8200
+AUTHENTICATION: 5698215
+
+
+4
+I
+
+ALENUMHER
+
+EVERAL EMILOYER ID NO.
+AUTORMED STOCK
+ENDING DATE
+07/18/91
+1994 ANNUAL FRANCHISE TAX REPORT
+TCORPORATION MAME
+HYPERION AIR, INC
+7918/BTN DAT
+TORTOCK CASS
+NO. OPSHARES
+COMMON
+1,500
+RENEMAL/ REVOCATION DATE
+TRAR VALUE/SHART
+0.000100
+1,500
+PRANCHISE TAX
+$30.00
+SS0.00 PENALTY
+$ .00
+1.5% MONTHLY INTEREST
+15.00
+EDENE EAT ATON SESTEM, INC.
+32 LOCKERMAN SQUARE
+SUITE L-100
+DOVER
+DE 19904
+QUARTERLY INTENST
+TANN. FILING FEE
+Is 20.00
+PHONE NUMBER
+TOTAL GROSS
+ASSETS
+/ ASSET BATE
+FROM
+TO
+ASSET ON ORATED
+lan. Jes
+Dre. 31st
+FREN. CREDIT OR BALANCE
+PREPAID ORTY PAYMENTS
+15.00
+AMOUNT DUE
+350.00
+MAKE CHECK PAYABLE TO:
+DELAWARE SECKETARY OF STATE
+CHECK ND.
+1236
+50
+2
+
+
+DO00O5O00 D
+
+
+OWN_AND OPERATE PRIVATE AIRCRAFI
+1. JEFFREY E. EPSTEIN
+NAME
+STREET/CITY/STATE/ZIP
+358_EL BRILLO WAY. PALM BEACH. EL
+BANK USE ONLY - SEND INVOICE AND PAYMENT ONLY - NO ATTACHMENTS — NO ADDITIONAL PAGES
+12/14/94 0101 13469 2268758 058846 91 03 Ø1
+OFFICERS
+1 PRESIDENT
+JEFFREY EL EPSTEIN.
+2 SECRETARY/TREASURER
+JEFFREY.E, EPSTEIN
+ORIGINAL SIGNATURE (OFFICER, DIRECTOR OR INCORPORATOR)
+STREET CITY/SLATE/ZE
+.358 EL BRILLO HAY, PALM BEACH, EL
+358 EL BRILLO HAY, PALM REACH. FL
+TALE
+DALE
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "HYPERION AIR, INC. " AS
+ACRETA
+
+
+8200
+Varriet Smies Hindsor
+AUTHENTICATION: 5698216
+
+
+DO NOT ALTER FILE NUMBER ANNUAL FRANCHISE TAX REPORT
+
+-FECERAL EMPLOYER ID NO.
+NCORPORATION CAT
+- AUTHOAIZED STOCK
+07-18-91
+* BEGIN DATE
+ENDING DATE
+• TORTOCK CLASS
+THO. OF SHARES
+07-18-91
+COMMON
+1,500
+RENEWAL EVOCATION BATE
+PAN VALUBSHARE
+INS. SHARES
+ISSUED
+-000100
+(TAX YE.
+TPHONE NUNSER
+1995
+DATE DI
+INACTIT
+TASSET CATE
+E= RANCHISETAX
+$50.00 PENALTY
+.00
+
+THE PRENTICE-HALL CORPORATION SYSTEM, ING
+1013 CENTRE ROAD
+WILHINGTOH
+DE 15805
+1.5% MONTHLY INTEREST
+.00
+TANTE FILINGFEE
+TREV CREDIT OR BALANCE
+$
+20.00 #
+$50.00 PENALTY it not Received on or boldie
+March 1. Plus 1.5% Interest per month.
+
+
+
+TO
+JAN. 1
+ЖЕС. 311
+PREPAID ORTY. PAYMENTS
+.00
+50.00
+DELANE CARE OSTATE
+CHECK NO.
+TAMDUNT ENCLOSED
+$50.00
+4
+
+
+OWN AND OPERATE PRIVATE AIRCRAFT
+[PRINCIPAL PLACE OF BUSINESS OUTSIDE OF DELAWARE
+1. JEFFREY E. EPSTEIN
+SEND INVOICE AND PAYMENT ONLY • NO ATTACHMENTS - NO ADDITIONAL PAGES
+STREET/CITY'STATE/ZIP
+358 EL BRILLO KAY, PALM BEACH, EL
+2.
+3.
+4.
+5._
+FOR BANK USE ONLY
+82/23/96 0845 21674 2268753 819727 89 Ø1 aI
+1. PRESIDENT
+JEFFREY E. EPSTEIN
+2. SECRETARY/TREASURER
+JEFFREYE. EPSTEIN
+ORIGINAL SIGNATURE (OFFICER, DIRECTOR OR INCORPORATOR)
+STREET CITY STATE/ZIP
+358 EL BRILLO WAY, PALM BEACH, FL
+368 EL BRILLO HAY, PALM BEACH, FL
+1/2819
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "HYPERION AIR, INC. " AS
+CRETARYS
+
+
+8200
+Varriet Smith Hindson
+AUTHENTICATION: 5698217
+
+
+9
+0
+2
+SIAIE UF DELAWARE
+1996 ANNUAL FRANCHISE TAX REPORT
+(FICE HUMSER
+COHPOHATION HAME
+
+HYPERION AIR, INC,
+TINCOAPORATION DATE
+JULY 18, 1991
+AU.
+BEGIN DATE
+07-18-91
+(DESIGNATION
+TNO. OF SHANES
+ENDING DATE
+OR STOCK CLASS
+CONNIN
+1,500
+FRANCHISE TAX
+TESO.DO PENALTY
+TESS MONTHLY INTEREST
+THONE NUMBER
+TRENEWALREVOGATION BATE
+TPAR VALUE SHARE
+THO. SHARES
+SSUFD
+- 000100
+TANK: FILING FEE
+20.00
+LATEO
+INACTIVT
+TOTAL GROSS
+ASSETE
+TASSET DATE
+ASSETS FOR REGULATEI
+WESTMENT CORP
+TPREY CREDIT OR BALANCE
+
+NATIDNAL, REGISTERED AGENTS, INC.
+_EAST LOOCKERMAN STREE
+OVER, DE 1990
+FREPAID ORTY. PAYMENTE
+FAMOURT DUE
+50.00
+MAKE CHECK PAYABLE TO
+DELAWARE SECRETARY OF STATI
+CHECKHS,
+50 -
+$50,00 PENALTY'It, not Reesived on or before
+MAR 1; 1997 Plus 1.5% Interest per month.
+
+
+3
+
+
+OWN & OPERATE PRIVATE AIRCRAFT
+SEND INVOICE AND PAYMENT ONLY - NO ATTACHMENTS - NO ADDITIONAL PAGES
+STREET/CIT VISTATE ZIP
+1. PRESIDENT
+JEFFREY E. EPSTEIN
+358 EL BRILLO WAY, PALM BEACH FL
+UNTIL SUCEEEDED
+2 SECRETARY/TREAS.
+JEFFREY E. EPSTEIN
+358 BL BRILLO WAY, PALM BEACH FO
+FOR BANK USE ONLY
+82-25-F7 0825 00641
+22687584543 04 01
+1. JEFFREY E. EPSTEIN
+2.
+NAME
+STRGET/CITY/STATE/ZIP
+358_ EI, BRILLO WAY, PALM BEACH FL
+6.
+ORIGINAL SIGNATURE TOFFICER, DIRECTOR OR INCORPORATOR)
+X
+PRES/ SEE /TREAS.
+2/10177
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "HYPERION AIR, INC. " AS
+SECRETARY
+
+
+8200
+Varriet Smila Hindsor
+AUTHENTICATION: 5698225
+
+
+DO NOT ALTER FILE NUMBER.
+-5 FILE NUMBE
+
+FEDERAL, EMPLOYER ID NO.
+BRAIN DATED STENDAND DATE
+BROIN DATT
+07-18-81
+FRANCHISE TAX
+$30.00
+35000 PENALTY
+$.00
+Registered Agent 9000014
+CORPORATION SERVICE COMPANY
+1013 CENTRE ROAD
+WILMINGTON, DE 19805
+1997 ANNUAL FRANCHISE TAX REPORT
+THONE NUMER
+CORFORATION NAME
+IOORFORATTON DAT
+JULY 18, 199
+ESIGNATIO:
+NO. OPSHARES
+R STOCK CLA
+COMMON
+1,500
+RENEWAL/ REVOCATION DATE
+TOM
+TOSE GROSS
+ASSET DATE
+
+Jan. 1st
+Doc. 3s
+13% MONTHLY INTEREST
+5.00
+ANN. FILING PIE
+$ 20.00
+PREV. CRUDET OR BALANCE
+$.00
+FRITAID ORTY. PAYMENTS
+$ 50.00
+I LANE SEE A OF SAT
+CHECK NO.
+2952
+50
+
+
+
+
+OFFICERS
+SEND INVOICE AND PAYMENT ONLY - NO ATTACHMENTS - NO ADDITIONAL PAGES
+STREETCHYSTATE/ZIP
+1.
+01-13-98 0005 00115
+BANK USE ONLY
+2268758#381 05 01
+MAME
+STREET/CITY/STATE/ZIP
+X
+ORIGINAL SIGNATURE (OFFICER, DIRECTOR OR INCORPORATOR)
+PrEs
+1/7/98
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "HYPERION AIR, INC. " AS
+
+
+8200
+O LAWARE
+AUTHENTICATION: 5698218
+
+
+
+07-18-91
+1998 ANNUAL FRANCHISE TAX REPORT
+HYPERION ARE, 10 AT
+SIGNATI
+ESTOCK CL/
+NO. OF SHARES
+COMMON
+1,500
+SINEWAL/REVOCATION DATS
+FAR VALUE/ SHARE
+-000100
+PIAL GROSS
+SSET:
+FRANCHISE THE
+$30,00
+$50.00 FEMALTY
+$.00
+Registered Agent 9000014
+CORPORATION SERVICE COMPANY
+1013 CENTRE ROAD
+WILMINGTON, DE 19805
+15% MONTHLY INTERIST
+$.00
+ANN FILING FEE
+$ 20.00
+PREV. CREDIT OR BALANCE
+5.00
+PHONE NUMBER
+ASSET DATE
+FROM
+NEMAN CORAT
+Jan. Ist
+Doc 3lat
+PREPAID ORTY. RAYMENTS
+AMOUNT DUE
+1 50.00
+DEAR CHECK AT GOATE
+CHECE NO.
+11022
+50-
+
+
+000005000 0 1
+
+
+1
+O FRESIDENT
+2
+83-61-99 6613
+SEND INVOICE AND PAYMENT ONLY - NO ATTACHMENTS - NO ADDITIONAL PAGES
+STREET/CITY/STATE/ZIP
+JorfReE ESTErN 358 ELBRILLO WAY
+B21 BEACH, PL
+00031
+BANK USE ONLY226875U1982
+16 01
+NAME
+STREET/CETY/STATE/ZIP
+2
+ORIGINAL SIGNATURE (OFFI
+IR, DIRECTOR OR INCORPORATOR
+TILL
+PRES.
+2154/99
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "HYPERION AIR, INC. " AS
+SECRETARYS®
+GEESE
+
+
+8200
+Varriet Smith Hindson
+AUTHENTICATION: 5698219
+
+
+1999 ANNUAL FRANCHISE TAX REPORT
+E) DO NOT ALTER FILE NUMDER
+J2268758
+FEDERAL EMPLOYER IS NO.
+ATTA DATED STONDING DATE
+BEGIN DATE
+07-18-91
+NOLY 199T
+ESIGNATIO
+NO. OF SHARES
+R STOCK CLA:
+COMMON
+1,500
+RINEWAL. /REVOCATION DATE
+PAR VALUE /SHARE
+NO. SHARES
+ISSUBD
+•000100
+E
+I lo
+FRANCHISE TAX
+$ 30.00
+150.00 PENALTY
+$.00
+LIN MONTHLY INTEREST
+1.00
+ANN. FILING FEM
+$ 20.00
+5
+Registered Agent 9000014
+CORPORATION SERVICE COMPANY
+1013 CENTRE ROAD
+WILMINGTON, DE 19805
+PHONE NUMBER
+JATRO
+NACTIVIT
+TOTAL CROSS
+ASSET DATE
+ASSHIS
+PREV. CREDIT OR BALANCE
+5.00
+FROM
+SSETS FOR REGULATE
+VESTMENT CUR
+Jan. Is
+Doc. 31o
+PREPAD QRTY. PAYMENTS
+AMOUNT DUE
+L: 50.00
+MAKE CHECK PAYARLE TO
+DELAWARE SECRETARY OF STATE
+CHECK NO.
+$50.00 PENALTY If not Recelved on or before
+March 1, 2000. Plus 1.5% Interest per mo.
+2
+
+
+
+9
+
+
+2.
+SEND INVOICE AND PAYMENT ONLY - NO ATTACHMENTS - NO ADDITIONAL PAGES
+STREET/CITY/STATE/ZIP
+situat
+1 cost2
+DO NOT WRITE IN THIS SPACE - FOR BANK USE ONLY
+0031.20
+:342205
+ORIGINAL SIGNATURE (OFFICER, DIRECTOR OR INCORPORATOR)
+%%.
+Secretory
+5-iecc.
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "HYPERION AIR, INC. " AS
+
+
+8200
+CELAWARE
+AUTHENTICATION: 5698220
+05-23-07
+
+
+NEIL IT JIME AND PAYMENI UNLY - NO ATTACHMENTS - NO ADDITIONAL PAGES
+STREET/CITY/STATE/ZIP
+Jeffrey Epstein N-Amen Yoch Haver Lieu Recitteck
+Quarter * 2, St Thincas USVI fecr
+DO NOT WRITE IN THIS SPACE - FOR BANK USE ONLY
+20.i30205%
+STREET/CITY/STATEZP
+1. President JeffreyE Spite Amencontact Hote, alcohecite Quetenta, St Marr, UVI Pres
+2 Secretary
+Darren K. Inclyke 447 Mercisen Ave Ar Flocr, Neutely ico22
+Secretary
+6-14-01
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "HYPERION AIR, INC. " AS
+
+
+8200
+AUTHENTICATION: 5698221
+
+
+Evi
+
+SOSCE
+2001 ANNUAL FRANCHISE TAX REPORT
+[FLE NUMBER"
+
+FEDERAL EUFLOVER TE NO
+TINCORPORATION DATE
+JULY 18, 1991
+ALTHORIZED STOCK
+TDESIGNATION
+NO. OF SHARES
+BEGIN DATE
+ENDING DATE
+OR STOCK CLASS
+87-18-1991
+COMMON
+1,508
+[RENEWAL HEVOCATION DATE
+TPAR VALUE'SHAHE
+TNO. SHARES
+ISSUED
+- 800100
+TPHONE NUMBER
+FROM
+BATE OF
+INACTIVITY
+TOTAL GROSS
+ASSETS
+ASSET DATE
+TASSETS FOR REGULATED
+INVESTMENT CORPS
+FRANCHISE TAX
+$
+$50.00 PENALTY
+T.5% MONTHLY INTEREST
+30.00 ≤
+TANN. FILING FEE
+20.00
+TPREY CREDIT OR BALANCE
+TPREPAID ORTY. PAYMENTS
+LAMSURTBUE
+E
+50.00
+00001
+ORPORATION SERVICE COMPAN
+2711 CENTERVILLE ROAD
+SUITE
+400
+WILMINGTON, DE 19808
+[CHECK HO.
+TAMOUNT ENCLOSED
+$50.00 PENALTY If not Recelved on or before
+MAR 1, 2002 Plus 1.5% Interast per month.
+2
+
+2268758 000005000 0
+7
+
+
+1. JeltreyE Epstein.
+SENU INVUICE AND PAYMENT ONLY - NO ATTACHMENTS - NO ADDITIONAL PAGES
+DO NOT WRITE IN THIS SPACE - FOR BANK USE ONLY
+2300%
+• President Jettrey Epskin, uttest fames and hencech take ViSA
+= Secretary
+Dasionkinüylie
+ORIGINAL SIGNATURE (OFFICER, DIRECTOR OR INCORPORATOR)
+457 Madison Avenue Linflar, 14, M/ 10022
+X DeLEVLL
+Secretary
+2-502
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "HYPERION AIR, INC. " AS
+HERETAILS
+
+
+8200
+CELAW NEE
+Harriet Smith Windsor, Secretary of Stat
+AUTHENTICATION: 569822
+
+
+
+2002 ANNUAL FRANCHISE TAX REPORT
+COAPORATION NAME
+
+HYPERION AIR. INC.
+UNCORPOHATION DATE
+JULY 18, 1991
+ADTHORIZED STOCK
+BEGIN DATE
+ENDING DATE
+07-18-1991
+DESIGNATION
+INO. OF SHARES
+OR STOCK CLASS
+COMMON
+1,500
+1.5% MONTHLY INTEREST
+PRANCHISE TAX
+350:00 PENALTY
+RENEWAL REVOCATION DATE
+PAR VALUESHAHE
+TRO. SHARES
+ISSUED
+
+TARN FILING FEE
+20.00
+
+CORPORATION
+SERVICE
+2711 CENTERVILLE ROAD
+SUITE 400
+WILMINGTON, DE 19808
+2 030103
+
+PHONE NUNBER
+FROM
+DATE OF
+INACTIVITY
+[TOTAL GROSS
+ASSETS
+ASSET DATE
+ASSETS FOR REGULATED
+INVESTMENT CORPS
+HAN 11
+TPREV CREDIT OR BALANCE
+TPREPATO CHTY. PAYMENTS
+AMOUNT DUE
+50.00
+MAKE CHECK PAYABLE TO:
+DELAWARE SECRETARY OF STATE
+[CHECK NO.
+5507
+$50
+b
+$50.00 PENALTY If not Received on or belore
+MAR 1, 2003 Plus 1.5% interest per month.
+
+
+SENU INVUICE AND PAYMENT ONLY - NO ATTACHMENTS - NO ADDITIONAL PAGES
+STREETICITY/STA
+1.
+3..
+4.
+5.
+CAM EXPIRES
+DO NOT WRITE IN THIS SPACE - FOR BANK USE ONLY
+Sectary
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "HYPERION AIR, INC. " AS
+
+
+8200
+AUTHENTICATION: 5698223
+
+
+
+CORPORATION HAME
+
+FEDERAL EMPLOYER ID HO.
+INCOMPORATION DATE
+JULY 18, 1991
+NO. OF SHARES
+PAR VALUE'SHAHE
+RENEWAL/REVOCATION DATE
+N5. SHARES
+ISSUED
+AUTHORIZED STOCK
+BEGIN DATE
+ENDING DATE
+07•1B-1991
+DESTONATION
+OR STOCK CLASS
+CONHON
+1,500
+- 000100
+FRANCHISE TAX
+$100.00 PENALTY
++ 3% MONTHLY INTEREST
+35.00
+$
+100.00
+2.26
+TANN PILING FEE
+$
+25.00
+
+CORPORATION SERVICE
+2711
+CENTERVILLE ROAD
+SUITE
+400
+WILMINGTON, DE 19808
+2 030104
+2268758 000010226 0
+PRONE NUMBER
+'DATE OF
+INACTIVITY
+TOTAL GROSS
+ASSETS
+TO
+ASSET DATE
+TASSETS FOR REGULATEL
+INVESTMENT COPS
+JAN. 161
+DEC: 31a
+EDIT OR BALANCE
+60.00 CR$
+PREPAID ORTY. PAYMENTS
+AMOUNT DUE
+102.26
+MAKE CHECK PAYABLE TO:
+DELAWARE SECRETARY OF STATE
+15693
+MOUNT 520B
+3
+$100.00 PENALTY I not Recelved on or before
+MAR 1, 2004 Plus 1.5% Interest per month.
+
+
+-
+NAME
+- HUMIIAUMMENIS - NO ADDITIONAL PAGES
+[PRINCIPAL PLACE OF BUSINESS OUTSIDE OF DELAWARE
+STREET/CITY/STATE/ZIP
+DO NOT WRITE IN THIS SPACE - FOR BANK USE ONLY
+
+OFFICERS
+•3.:
+NAME
+STREET/CITYISTATEIZIP
+ORIGINAL SIGNATURE (OFFICER, DIRECTOR OR INCORPORATOR)
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECT COPY OF THE ANNUAL REPORT OF "HYPERION AIR, INC. " AS
+
+
+8200
+Varriet Smita Hindsor
+larriet Smith Windsor, Secretary of Stat
+LUTHENTICATION: 569822
+
+
+I, HARRIET SMITH WINDSOR, SECRETARY OF STATE OF THE STATE OF
+CORRECI COPY OF THE ANNUAL REPORT OF "HYPERION AIR, INC. " AS
+HERE!
+
+
+8200
+Variet Amith HIndsor
+AUTHENTICATION: 5698037
+
+
+BORGA
+DO TATER LENUMBER AROMAN FRANCHISE TAX REPORT
+(FLE NUMBER
+
+TRCORFORATION DATE
+"HENEWALMEVOCATIOW DATE
+07-18-1991
+EDIN DATE STOCKENDING DATE OF STOCK ELAS
+THO. OF SHARES
+PAR VALUE SHARE
+107-18-1991
+COMMON
+TSSUEDANIES
+1,500
+-000100
+PRANCHIDE TAX
+PENALTY
+TESS MONTHLY INTEREST
+35.00
+
+CORPORATION SERVICE COMPANY
+2711 CENTERVILLE ROAD
+SUITE 400
+WILMINGTON
+.00
+.00
+DE 19808
+TTAXY PHOME HUMBER
+2006
+BATE OF
+МАСТИТУ
+SCETSAG
+TASSET DATE
+TESTERP EBRALATED
+er. 1k
+TANA PILING FEE PREY CREDIT OR BALANCE
+25.00
+TPHEPAID ORTY. PAYMENTS
+.00
+MAKE CHECK PAYABLE TO:
+60.00
+DELAWARE SECRETARY OF STATE
+(CHECKMS,
+TAMOURT ENCLOSED
+2 - 030107
+
+000006000 0
+
+
+SEND INVOICE AND PAYMENT ONLY - NO ATTACHMENTS - NO ADDITIONAL PAGES
+[PRINCIPAL PLACE OF BUSINESS OUTSIDE OF DELAWARE
+NAME
+STREET CITY STATE ZIP
+DO NOT WRITE IN THIS SPACE - FOR BANK USE ONLY
+OFFICERS
+NAME
+STREET/CITY/STATE ZIP
+1D Visha
+DIRECTOR OR INCORPORATOR)
+Scre
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/e784de37940e4417ad961fe31372ad08d7fa53bfc94cca013adaf4a65bf459d0.receipt.json b/vision-fixhub/ds9-unparsed-05/e784de37940e4417ad961fe31372ad08d7fa53bfc94cca013adaf4a65bf459d0.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..27729977d840e1e1c983530f5bc96f748051b13a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e784de37940e4417ad961fe31372ad08d7fa53bfc94cca013adaf4a65bf459d0.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12061,
+  "dataset": "marble-joined",
+  "doc_id": "e784de37940e4417ad961fe31372ad08d7fa53bfc94cca013adaf4a65bf459d0",
+  "engine": "marble-apple-vision",
+  "event_count": 226,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.court-caption.filed-stamp\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "13e0699ae51130ba2a9bbe80c916e85a7c9591b743bf3d47380bd9fd7d4cfbe0",
+  "output_sha256": "6ac3c16a4700d5c6994da3d5dd1a15723ea234a0ce6243cec4b7bad65025f714",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e78fea0443b0c82613e653110c52ade7a09a9216acf097469c3fa990d0db54d9.md b/vision-fixhub/ds9-unparsed-05/e78fea0443b0c82613e653110c52ade7a09a9216acf097469c3fa990d0db54d9.md
new file mode 100644
index 0000000000000000000000000000000000000000..d9c65b9b3f489f440b126e17944a0ddef2df7703
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e78fea0443b0c82613e653110c52ade7a09a9216acf097469c3fa990d0db54d9.md
@@ -0,0 +1,588 @@
+CERTIFIED MAIL
+SIE
+RICCI-LEOPOLD.
+CONSUMER JUSTICE ATTORNEYS
+2925 PGA Boulevard 1 Suite 200
+Palm Beach Gardens 58 FL 33410
+049J82034925
+$05.490
+09/04/2008
+Mailed From 33410
+US POSTAGE
+7160 3901 9845 1468 3274
+RETURN RECEIPT REQUES
+Or
+Miami FBI
+SEP 0 8 2008
+16320 Northwest 2nd Avenue
+North Miami Beach, FL 33169
+3316916599 C007
+
+
+COMMITTED TO JUSTICI, TRUTH & SATETY
+E
+RICCI-LEOPOLD.
+CONSUMER JUSTICE ATTORNEYS
+September 04, 2008
+CERTIFIED MAIL #7160 3901 9845 1468 3274
+Miami FBI
+16320 Northwest 2nd Avenue
+North Miami Beach, FL 33169
+Re:
+Jeffrey Epstein - Criminal investigation
+Date of Indictment: 7/19/06
+Dear Sir or Madam:
+Pursuant to the Public Records Act, Chapter 119 of the Florida Statutes, I am writing to request a
+copy of any and all evidence, documents, etc. including but not limited to papers and things as
+listed on the attached Property Receipt attached as Exhibit "A" regarding the investigation of
+Jeffrey Epstein pertaining to the indictment by the Palm Beach County Grand Jury issued on July
+19,2006.
+This request includes copies of every document related to the above matters, regardless of the
+format in which the information was stored or whether it is currently in your possession or in
+storage.
+If you refuse to provide this information, Chapter 119 of the Florida Statutes requires you to
+advise me in writing and indicate the applicable exemption to the Public Records Act. Also
+please state with particularity the reasons for your decision, as required by Section 119.07(2). If
+he exemptions you are claiming only applies to a portion of the records, please delete tha
+portion and provide photocopies of the remainder of the records according to Section 119.07(2)
+I reserve the right to appeal your decision to withhold any information.
+2925 PGA Boulevard • Suite 200 # Palm Beach Gardens • Florida 33410 ฿
+CRASHWORTHINESS • INSURANCE BAD FAITH • MANAGED CARE ABUSE • PERSONAL INJURY • WRONGFUL DEATH
+
+
+:
+September 04, 2008
+
+I would appreciate it you would provide this information to me, as required by statute, by no
+later than September 15, 2008. If you have any questions or need additional information to
+expedite this request, please call me.
+Very truly yours,
+
+
+M BEACH POLICE DEPARTMEN
+PaR Form 852
+• PROPERTY
+M EViDENCE
+INCIDENT/CITATION NUMBER
+SEARCH WARRANT RETURN
+O FOUND
+TRIAL
+• DECEASED (Probated)
+• PERSONAL :
+• CONFISCATED
+O LABORATORY
+O STOLEN RECOVERED
+COTHER®
+DATE/TIME RECOVERED
+PROPERTY NUMBER (Leave Blank)
+10-20-2005
+ADDRESS WHERE PROPERTY IMPOUNDE
+05-1024
+5
+-L-brillo
+DISCOVERED-BY / D.O.B.
+ADDRESS
+City
+Zip
+PHONE NUMBER
+eg lot'g
+•DETECTIVE BUREAU
+' DESTROY
+BIN NUMBER (Leave Brahk) C
+OWNER / VICTIM'S NAME / D.O,B.
+ADDRESS
+Sires!
+City
+Zip
+PHONE NUMBER
+SUSPETE NAME DOB 10 EG
+Astein
+ADDT NL. SUSPECT/DIO.B.
+ADDRESS
+358
+FEL BRilto
+Zip
+PHON
+
+Zip
+PHON
+SPECIAL INSTRUCTIONS
+FOUND PROPERTY.
+CLẠM O
+NOT CLAM O
+ITEM & • QUANTITY
+•VALUE
+1.
+4
+3
+•
+Kitche
+Bain massage table.
+•*.
+99
+He Fames Ponte fride flo
+Pictures
+in frame -
+e8 trong t
+A From Yella Blue room nt Kitchen TAFar r
+Photos from nEtice off Post area
+Photos fiori
+(firtot
+aike in right:
+TOTAL PACKAGE WEIGHT
+1 hereby acknowledge that the above list represents all property taken
+from me and that I have received a copy of this receipt.
+L hereby acknowledge that the atiove list represents all property impounded
+by me in the official performance of my duty as a police ofticer.
+SIGNATURE
+DATE
+SIGN
+the officer by whom this warrant
+inventory, contains a true and
+detailedi aramint
+jaf
+the authority of this warrant.
+Swor to and subscribed before me
+this 2| day of October 2005.
+: DATE/TIME RECEIVED
+executed, do swear that: the above
+
+
+ZM BEẠCH POLICE DEPARTMEN
+PBPD Form R52
+• PROPERTY
+Ed EVIDENCE.
+SEARCH WARRANT RETURN
+O FOUND
+MA TRIAL
+• DECEASED (Probated)
+L PERSONAL
+• CONFISCATED
+• LÄBORATORY
+O STOLEN/RECOVERED
+O OTHER
+DATE/TIME RECOVERED .
+PROPERTY NUMBER (Leave Blaink)
+VITERE PROPERI
+MPOUNDED
+10.30-05
+65-1274
+358
+EL-
+rilla
+DISCOVERED BY / D.O.B:
+ADDRESS
+Streel
+•Clty
+Zp
+PHONE NUMBER
+PA6E 205 6
+DETECTIVE BUREAU
+• DESTROY
+BIN NUMBER (Leave Blank)
+itbo
+OWNER/ VICTIM'S NAME / D.O.B.
+ADDRESS
+- Street
+City
+forstrimst
+SET NE 2035 El BRANO
+Jeff
+ADDRESS
+BriNo
+Zip
+PHONE NUMBER
+Zip
+PHONE NUMBER
+Zip
+PHONE NUMBER
+.SPECIAL INSTRUCTIONS
+FOUND PROPERTY
+ITEM•#
+13
+QUANTITY
+2
+VALUE
+-90 DAYS
+CLAM |
+NOT CLAIM O
+BESCRIPTION
+*
+V.Hts tapes.
+-Rile
+. Frim (r dara By isu/
+CDi masked Hippy Biru Bsane
+T irdinza por
+sesege posk a Suti gane ae ,
+3
+Prom dest
+9.
+20
+a from desk
+infigud Photos from desk
+tems 1B19,2a 2)
+mm /st floon
+framed Phitos Fiim desk
+22
+franid Phutos fron table yn So Cornçe
+3
+2
+affire.
+Soap on Rope INE Berroini (con kroni
+WaplE
+arad Itaimed
+in Torpedo (ndele adren) ndengm
+Drtüre" (frim foyer into Maz
+TOTAL PACKAGE WEIQHT
+Bid coin.)
+1 herey acknowledge that the. above ist represonte, all property taken
+from me and that I havgyeceived a copy of thls receipt. :
+Ih
+by
+SIGNATURE
+DATE
+Sid
+
+
+POPD Fom #52
+• PROPERTY:
+TAl EVIDENCE
+O FOUND
+CA TRIAL
+M BEACH POLICE DEPARTMEN
+SEARCH
+WARRANT RET
+• DECEASED (Probated)
+• PERSONAL
+• CONFISCATED
+O LABORATORY
+• STOLEN/RECOVERED
+O OTHER
+DATE/TIME RECOVERED
+PROPERTY NUMBER (Leave Blank)
+10-20-05
+05-10211
+PAGE 30F 6
+DETECTIVE BUREAU
+• DESTROY
+BIN NUMBER (Leave Blank)
+DDRESS WHERE PROPERTY IMPOU
+358
+DISCOVERED BY / D.D.B.
+D
+ADDRESS
+Street
+City
+PHONE NUMBER
+OWNER / VICTIM'S NAME / D.O.B.
+ADDRESS
+Street
+Clty
+PHONE NUMBER
+SUSPECTS NAME/ D.O.B. 01: 20-53
+Jeff
+358
+USPECT7D.6
+EL BRillo
+PHONE NUMBER
+Zip
+PHONE NUMBER
+SPECIAL INSTRUCTIONS
+FOUND PROPERTY
+90 DAYS
+•CLAIM O
+• NOT CLAIM O
+ITEM * QUANTITY VALUE
+jitn
+SchuoltaniseRieT
+• DESCRIPTION
+PASTER BROM DESK
+3
+G
+mak
+NEV
+VIDEOTAPES%, SEXIN COY, EATIN JANINE, LOVE LESBIANS FOUR, MOTOR
+NEVE
+FRAMED PHOTOS FRID MENS BADIE IM - MALEEN BeRREM
+S
+32
+33
+THRIFTY RENTAL AGREPMENT ENEM CHLUROT SURPURBAN (COPIED.
+MOTE FREiA
+From Clinic
+from
+office.
+SURRE FAN:
+ops kitchen
+6
+26
+27
+38
+1:39
+V40
+E-F
+8 mm
+Compact flash cards from Beakase ReTuRN
+Fashtart from Camera on berk cases
+RETURNY TO OUne
+3
+30
+Z1p Cn3 fron
+Book rose
+RODIN
+CD's from
+Book cuse
+Litems 35-40 from
+TOTAL PACKAGE WEIGHT
+tuesthouse
+1 hereby acknowledge that the above list represents all property taken
+from me and that I have received a copy of this receipt.
+I hereby acknowledge that ihe above list represents all property. impourder
+by n
+SIGNATURE
+DATE
+SIG
+
+
+LM BEACH POLICE DEPARTMEN
+PBPD Fom #52
+• PROPERTY
+NO EVIDENCE
+MANENT TATIONATICA
+SEARCH MARRATIT RETURN
+• FOUND
+STRIAL
+• DECEASED (Probated)
+• PERSONAL
+• LABORATORY
+• STOLEN/RECOVERED
+DATE/TIME RECOVERED
+PROPERTY NUMBER (Leave Blank)
+10:20-05
+ADDRESS WHERE PI
+OPERTY TMPOUNDEL
+05-1024
+25
+€/ Brillo
+DISCOVERED BY / D.O.B.
+ADDRESS
+DETECTIVE BUREAU
+• CONFISCATED
+• DESTROY
+O OTHER
+BIN NUMBER (Leave Blank)
+PHONE NUMBER
+OWNER'S NAME / D.O.B.
+ADDRESS.
+Street
+Clty
+PHONE NUMBER
+PHONE NUMBER
+Epstein
+Jeff
+ADOTNL. SUSPECT/D.O.B.
+ADDRESS
+Street
+City
+Zp
+PHONE NUMBER
+SPECIAL INSTRUCTIONS
+'FOUND PROPERTY
+BO DAYS "
+CLAIM O
+NOT CLAIM O
+ITEM #
+ALE
+142
+*DESCRIPTION
+rom desk middle ShelfRerm
+*
+Power Cord for CPU From Guest kon
+cRustram Guest Bedroom
+31012
+8mm Vidio Tapes in Guest Bedroom.
+maxell CD-R in first nodinn
+REnA
+142
+4y An * Diskon in clear Box
+RETURA COPTERS
+ZIA DISKs
+from fues
+FrE DENIA!
+Hems # 35-48 From
+479
+50
+151-1
+1520
+153
+missage book fRom Burst
+aise ffice RENDEr
+niessage book
+Compact flash cards
+ReTURN #49-51QuEse
+sal
+CAn From Ghest holise
+office
+penin
+TOTAL PACKAGE WEIGHT
+1 heroby acknowledge that the above list represents all property taken
+from me and that I have recelved a copy of this recept.
+I hereby acknowledge that the above list represents all property impounded
+by me in the official performance of my duty as a police officer.
+SIGNATURE
+DATE
+REAS
+
+
+PBPD Forn #52
+• PROPERTY
+O FOUND
+EVIDENCE
+A TRIAL
+INCIDENT/CITATION NUMBERE
+DISCOVERED BY / D.O.B.
+LM BEACH POLICE DEPARTMEN
+GEARCH WARRANT LETUR
+•DECEASED (Probated)
+• PERSONAL
+• CONFISCATÉD
+•LABORATORY
+• STOLEN/RECOVERED
+O OTHER
+DATE/TIME RECOVERED
+PROPERTY NUMBER (Leave Blank).
+10-20-05
+05-1024
+El-Brill-
+Palm
+Beack
+ADDRESS
+PHONE NUMBER
+PAGE 5 or 6:
+DETECTIVE BUREAU
+• DESTROY
+Lab
+BIN NUMBER (Leave Blank)
+OWNER'S NAME / D.D.B;
+ADDRESS
+Strest
+City
+PHONE NUMBER
+SUSPECT'S NAME/D.O.B. 07-20-5 LODRESS
+Epstein
+ADDENL SUSPECT/DJO.B,
+Jeff
+350
+ADDRESS
+PHONE NUMBER
+EL BRIMO
+. Zp
+PHONE NUMBER
+SPECIAL INSTRUCTIONS,
+FOUND PROPERTY
+:90 DAYS.
+ITEM * QUANTITY
+CLAIM O
+NOT GLAIM O
+ReTim
+*
+3
+DESCRIPTION
+Power Cord t CPU.
+1#53
+CPu Prom office off Kititen
+Power cord to item #55
+CD's titu
+#55-57 from Office
+if Kitchen
+Petin
+Peach mossage table statistru
+RETUIZAT
+'RETURA
+RETURN
+RETURN.
+TOTAL PACKAGE WEIGHT
+nereby acknowledge that the above list replesents all property taker
+rom-me and that I have received a copy of this recep
+SIGNATURE
+DATE
+Return
+I hereby acknowledge that the above Ilat represents all property Impounded
+Hy me la the ollielal mariarmanes of misduty ae a hallen ciliant
+SIGN
+DATE TIME RECEIVED
+
+
+PALM BEACH POLICE DEPARTMEN
+PEPD Form, #52
+SW PEOPERUYRECEIPT
+• PROPERTY
+• FOUND
+• DECEASED (Probated)
+• PERSONAL •
+J-SVIDENCE
+PARIAL:
+* D LABORATORY
+• STOLENIRECOVERED
+INGIDENTICITATION NUMBER
+DATE/TIME RECOVERED
+05-
+10 2005
+1410
+PROPERTY NUMBER (Leave Blank)
+-05:1024
+ADRESS OR Bullo
+DISCOVERED BY / D.O.B.
+ADDRESS
+Street
+City
+PrE Gorb
+DETECTIVE BUREAU
+• CONFISCATED
+• OTHER
+• DESTROY
+lab
+• BIN NUMBER (Leave Blank)
+PHONE NUMBER
+OWNER'S NAME / D.O.B.'
+ADDRESS
+Street
+City..
+Zip
+PHONE NUMBER
+PHONE NUMBER
+ADDTNL, SUSPEOT /D.O.B,
+358 FEL
+ADDRESS
+2p:
+PHONE NUMBER
+SPECIAL, INSTRUCTIONG
+FOUND PROPERTY
+: 80 DAYS
+ITEM
+QUANTITY
+VALUE
+GREN PHoto
+NAKED GIRl.
+* DESCRIPTION
+FRAME
+CLAIM O
+NOT CLAIM O
+Петити
+Return
+ReTVrin)
+Patine
+RETULATRE
+RETURN
+PETUAN
+RENAN:
+TOTAL PACKAGE WEIGHT
+I hareby acknowledge that the above list reprisents all property taken
+from me and that have racelved a copy of this receipt.
+SIGNATURE
+DATE
+I hereby acknowledge that the above list represents all property Impounded
+by me in the official performance of my duty as a pollce officer.
+SI
+10•20-05
+1500k0
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/e78fea0443b0c82613e653110c52ade7a09a9216acf097469c3fa990d0db54d9.receipt.json b/vision-fixhub/ds9-unparsed-05/e78fea0443b0c82613e653110c52ade7a09a9216acf097469c3fa990d0db54d9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9678940dd1640e7f29bb05bf197c0b1d57614d6a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e78fea0443b0c82613e653110c52ade7a09a9216acf097469c3fa990d0db54d9.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -319,
+  "dataset": "marble-joined",
+  "doc_id": "e78fea0443b0c82613e653110c52ade7a09a9216acf097469c3fa990d0db54d9",
+  "engine": "marble-apple-vision",
+  "event_count": 12,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "5d948ff6c7dce741179f832651502ba9925c22fdb4dcbd4b3bc47c27aabdef69",
+  "output_sha256": "5a52bf426152f5fc617c240f2462398d0a344fa62dfc4400434995cae2389b65",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e7a01be1a794f85b515448f28d2bb97e88bb88418e9a8b47a5dda00247020179.md b/vision-fixhub/ds9-unparsed-05/e7a01be1a794f85b515448f28d2bb97e88bb88418e9a8b47a5dda00247020179.md
new file mode 100644
index 0000000000000000000000000000000000000000..7b6a00c238a761f5f3c82e3790041fe459b3248b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e7a01be1a794f85b515448f28d2bb97e88bb88418e9a8b47a5dda00247020179.md
@@ -0,0 +1,995 @@
+Statements
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+FIRM
+www.bearstearns.com
+What's In This Statement
+Financial Summa..........................
+Transaction Detail
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 1, 2004
+THROUGH
+September 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+August 31, 2004
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK CENTER
+SUITE 63
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+Market Value of Your Portfolio
+...Cash & Equivalent — 50
+.....
+→ $ 168,945
+-168,945
+168,945
+Last statement's market value
+Short market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+This summary is for informational purposes only. It is not intended as a tax documen
+Ce tement should be retained for vour records. Sne reveren cide for important information
+10/01/04:07:49 001
+
+
+2 of 4
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+10/01/04;07:49 001
+
+
+Cash Flow Analysis
+pening Balanc
+Securities Sold
+Miscellaneous
+Amount Credited
+Dividends/Interest Charged
+Amount Debited
+Net Cash Activity
+Closing Balance
+Transaction Detail
+INVESTMENT ACTIVITY
+SEEMENT ARE
+TRANSACTION
+09/01/04 08/30/04
+CANCEL BUY
+TOTAL
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+$-168,945.31
+168,945.31
+10.32
+$168,955.63
+-10.32
+$-10.32
+...
+168.945.31
+_$0.00
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+- 168,945.31
+$-168,945.31
+CLOSING
+0.00
+$0.00
+Income Summary
+THIS PERIOD
+Margin Int. Paid
+-10.32
+YEAR TO DATE
+-89.77
+DESCRIPTION
+AVO S/D 08/31/04
+AS OR PRENUS BUY
+SYMBOLCUSP
+
+-25,000,000
+PRICE
+0.67578
+027
+10/01/04:07:49 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 1, 2004
+THROUGH
+September 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+August 31, 2004
+DEBIT AMOUNT
+CREDIT AMOUNT
+168,945.31
+$168,945.31
+
+
+Transaction Detail (continued)
+INTEREST
+DATE
+DESCRIPTION
+09/01/04
+AVG BAL 168.945RT 2.199
+021 OFFICE INTEREST 0804
+TOTAL
+MISCELLANEOUS
+DATE
+MO/DAY
+09/02/04
+TOTAL
+TRANSACTION
+JOURNAL
+DESCRIPTION
+FITO FITM
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUGUSIP
+STOP
+****** End of Statement******
+RATE (%)
+DEBIT AMOUNT
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 1, 2004
+THROUGH
+September 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+August 31, 2004
+CREDIT AMOUNT
+DEBIT AMOUNT
+10.32
+$-10.32
+CREDIT AMOUNT
+10.32
+$10.32
+10/01/04;07:49 001
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+FIRM
+www.bearstearns.com
+What's In This Statement
+Financial Summary.........................
+Your Portfolio Holdin.......................
+Transaction Detail
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD July 31, 2004
+THROUGH
+August 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Avallable
+LAST STATEMENT
+July 30,2004
+3
+3
+4
+Hollandiml
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK CENTER
+SUITE 63
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET DEBIT BALANCE
+NET EQUITY THIS PERIOD
+-168.945
+$-168,945
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+a portfolio indudes ono or mare unpriced securties that are
+acted in the Total Value of Securtes and the Not Equity This Por
+0
+-168.945
+Market Value of Your Portfolio
+$0
+Cash & Equivalent -
+.....
+.....
+→ 5-168,945
+Last statement's market value
+Short market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+This summary is for informational purposes only. It is not intended as a tax documen
+PC tement should be retained for our records. See reveren cide for important information
+09/01/04:08:31 001
+
+
+2 of 4
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+09/01/04;08:31 001
+
+
+Cash Flow Analysis
+Opening Balance
+Securities Bought
+Amount Debited
+Net Cash Activity
+Closing Balance
+Cash Balance Summary
+Margin
+Not Cas Ban ...
+OPENING
+0.00
+$0.00
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERIOD
+$0.00
+- 168,945.31
+$-168.945.31
+-168,945.31
+5-168.945.311
+Income Summary
+Margin Int. Paid
+THIS PERIOD
+0.00
+Portfolio Composition
+Cash/Cash Equivalent
+Total.
+SHORT
+168,945
+$168,945
+YEAR TO DATE
+-79.45
+LONG
+CLOSING
+- 168,945.31
+••••/•••••••••••••••••••••••••••••
+$-168,945.31
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+FRICE
+MARKET
+VALUE
+-168,945
+$-168,945
+ESTIMATED
+ANNUAL INCOME
+CURRE
+ELD I
+027
+09/01/04:08:31001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOO July 31,2004
+THROUGH
+August 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+July 30,2004
+Your Portfolio
+Allocation
+Short Cash & Equivalent
+Unshaded portions denote debit balance and or shart
+market values. The allocation percentage is derived
+from the absolute market value of your portolio.
+
+
+Your Portfolio Holdings (continued)
+EQUITIES
+Equities & Options
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+
+MRGN
+25,000,000
+Total Equities& Options
+TOTAL EQUITIES
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SEEMENT TREE
+TRANSACTION
+08/31/04
+08/30/04
+BOUGHT
+TOTAL
+DESCRIPTION
+CALL TSY 4 3/4 08/14
+1 0 0902 018
+PRICE
+Unpriced
+MARKET
+VALLE
+$0
+$0
+$-168,945
+ANNUAL INCOME
+$0
+$0
+CURRENT
+YELD IN
+SYMBOLCUSIP
+
+25,000,000
+PRICE
+0.67578
+027
+09/01/04;08:31 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD July 31, 2004
+THROUGH
+August 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Avallable
+LAST STATEMENT
+July 30,2004
+DEBIT AMOUNT
+168,945.31
+$-168,945.31
+CREDIT AMOUNT
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+FIRM
+www.bearstearns.com
+What's In This Statement
+Financial Summ...........................
+Transaction Detail
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD July 1,2004
+THROUGH
+July 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+June 30, 2004
+1
+Hollandlol
+FINANCIAL TRUST CO INC
+VO JEFFREY EPSTEIN
+6100 RED HOOK CENTER
+SUITE 63
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Miscellaneous
+Amount Credited
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Closing Balance,
+THIS PERIOD
+$0.00
+158.90
+$158.90
+-79.45
+-79.45
+$-158.90
+$0.00
+Income Summary
+Margin Int. Paid
+THIS PERIOD
+-79.45
+VEAR TO DATE
+-79.45
+SP The surren s four or ratanal purposes rear die Set revere date for portant iformation.
+07/31/04;08:41 001
+V958
+
+
+2 org
+Transaction Detail
+INTEREST
+DATE
+DESCRIPTION
+07/01/04
+AVG BAL 355,468RT 1.60
+21 OFFICE INTEREST 060
+TOTAL
+MISCELLANEOUS
+DATE
+MO/DAY
+07/02/04
+
+TOTAL
+TRANSACTION
+JOURNAL
+JOURNAL
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOL/CUSIP
+DESCRIPTION
+FITO TO FITM
+FIT FITO
+STOP
+***** End of Statement******
+RATE (%)
+DEBIT AMOUNT
+79.45
+$-79.45
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD July 1,2004
+THROUGH
+July 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+June 30,2004
+CREDIT AMOUNT
+DEBIT AMOUNT
+79.45
+$-79.45
+CREDIT AMOUNT
+158.90
+$158.90
+07/31/04:08:41 001
+V858
+
+
+3 of 3
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+07/31/04:08:41 001
+V958
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+FIRM
+www.bearstearns.com
+What's In This Statement
+Financial Summary.......................
+Transaction Detail
+Your Messages
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 29,2004
+THROUGH
+June 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+March 31,2004
+1
+2
+3
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK CENTER
+SUITE 63
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Amount Credited
+Securities Bought
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+355,468.75
+$355,468.75
+-355,468.75
+S-355.468.75
+$0.00
+PC This summary is for informational purposes only. It is not intended as a tax docum
+This statement should he retained for your records. See revere cide for imortant intomat
+
+
+2 or a
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEEMENT TRIE
+DATE
+TRANSACTION
+06/04/04
+06/03/04
+BOUGHT
+06/09/04 06/03/04 CANCEL BUY
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+PUT TSY 3 1/8 05/07
+EXP 0B 1320049-20
+PUT TSY 3 1/8 05/07
+EUROPUT STRK 99-20
+EXP 08/13/2004
+AVO S/D 06/04/04
+AS OF 06/03/04
+TO CXL PREVIOUS BUY
+SYMBOLGUSIP
+
+
+50,000,000
+50,000,000
+PRICE
+0.71094
+-071094
+TOTAL
+027
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 29,2004
+THROUGH
+June 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+March 31, 2004
+DEBIT AMOUNT
+355,468.75
+CREDIT AMOUNT
+-355,468.75
+$-355,468.75
+$355.468.75
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your messages
+Notice Regarding a Change in The Statement of Interest Charges
+Pursuant to the "Truth-in-Lending" Rule 10 (b)-16 Regarding Short Sales
+And Marking-To-The-Market
+ffective no earlier than thirty (30) days from your receipt of this statement, w
+will compute interest regarding your short sales and marking-to-the market a
+follows:
+The credit that appears on your statement due to short sales (including short
+sales against the box) is offset by a debit of like amount because Bear Steams
+Securities has to borrow the same security in order to deliver it to the buying
+broker and has to provide its lender additional collateral of up to 105% of the
+settled short market value of the borrowed securities to secure such loan, This
+means that the debit balance on which interest is computed will be the
+difference between (i) up to 105% of the settled short market value of such
+short sales (across all currencies), which shall be calculated daily, and (ii) the
+proceeds of such short sales,
+STOP
+****** End of Statement******
+18P
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 29,2004
+THROUGH
+June 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Avallable
+LAST STATEMENT
+March 31, 2004
+Any short positions in your account will be kept "marked-to-the market", This
+means that periodically the balance maintained in the short account will be
+adjusted to equal the market value of the short securities. Securities that are
+priced below five dollars per share may be valued at five dollars per share for
+short marking-to-the market purposes. If a security has been sold short (o
+sold short against the box) and has appreciated in market price over the
+selling price, interest will be charged on the amount of appreciation; if it
+depreciates in market price, interest will be correspondingly reduced by the
+drop in value. The appreciation or depreciation of securities sold short will be
+determined by Bear Stearns Securities based upon daily closing prices or
+quotations provided by pricing services, as applicable, or upon such factors as
+Bear Stearns Securities in its sole judgement deems pertinent.
+Please note that the other sections of the "Truth-in-Lending" disclosure
+previously provided to you remain unchanged,
+027
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+FIRM
+www.bearstearns.com
+What's In This Statement
+Financial Summary.......................
+Transaction Detail
+Your Messages
+LEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD February 28,2004
+THROUGH
+March 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+February 27,2004
+1
+2
+2
+Hollandlol
+FINANCIAL TRUST CO INC
+NO JEFFREY EPSTEIN
+6100 RED HOOK CENTER
+SUITE 63
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Miscellaneous
+Amount Credited
+Net Cash Activity
+losing Balance
+THIS PERIOD
+$-0.50
+0.50
+$0.50
+0.50
+.$0.00
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+-0.50
+$-0.50
+CLOSING
+0.00
+$0.00
+This summary is for informational purposes only. it is not intended as a tax documen
+TPC This statement should be retained for your recards. See reverse side for important infarmatio
+04/01/04;12:31 001
+
+
+2 org
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TREE
+03/24/04
+TRANSACTION
+EXPIRED
+TOTAL
+MISCELLANEOUS
+03/25/04
+TOTAL
+TRANSACTION
+JOURNAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+PUT TSY 1 7/8 1/06
+UROPUT STRK 99 24/3
+XP 03/17/2004
+DESCRIPTION
+MISC ADJ TO CASH BAL
+Your messages
+LP Excess SIPC Account Protection Update
+Effective February 16, 2004, the commercial insurer through which Bear,
+steams Securities Corp, obtains excess SIPC protection changed to Custome
+isset Protection Company ("CAPCO*), a New York licensed insurance
+company. CAPCO has an A+ financial strength rating from Standard and
+SYMBOLCUSIP
+-25,000,000
+PRICE
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD February 28,2004
+THROUGH
+March 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Avallable
+LAST STATEMENT
+February 27,2004
+DEBIT AMOUNT
+CRECIT AMOUNT
+DEBIT AMOUNT
+CREDIT AMOUNT
+0.50
+$0.50
+The Firm believes it is of the utmost importance that clients who purchase or
+old mutual funds fully understand the intricacies of the pricing structures an
+ules which govern these investments, Recently, a joint Industry/NASD Tasl
+Force collaborated to create a Disclosure Statement to address these issues.
+We are providing this Disclosure Statement to you for the purpose of
+reinforcing these concepts and to initiate the opportunity for further discussion
+of these issues to the extent you have questions, You are encouraged to
+contact your financial professional with any questions you have regarding your
+iolving Ns, Do we sale, you may review this information online at the
+http://www.nasdr.com/breakpoints_statement.asp
+027
+04/01/04:12:31 001
+
+
+3 of 3
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+04/01/04;12:31 001
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+FIRM
+www.bearstearns.com
+What's In This Statement
+Financial Summary.............................
+Your Portfolio Holdings
+Transaction Detail
+Your Messages ..../•II/I/
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO January 31, 2004
+THROUGH
+February 27,2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Available
+LAST STATEMENT
+FINANCIAL TRUST CO INC
+O JEFFREY EPSTEIN
+6100 RED HOOK CENTER
+SUITE 63
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Miscellaneous
+Amount Credited
+Securities Bought
+Amount Debited
+Net Cash Activity
+Clasing Balance
+THIS PERIOD
+$0.00
+54,687.00
+$54,687.00
+-54,687.50
+.$ 54.687.50
+-0.50
+.....
+.$-0.50
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+0.00
+$0.00
+CLOSING
+-0.50
+$-0.50
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+SHORT
+1
+LONG
+SP The serema o teral pros onde e rente das a perant tomation.
+02/2804;11:22 001
+
+
+2 ora
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SIMBCLCUSIP
+PRICE
+EQUITIES
+Equities & Options
+DESCRIPTION
+PUT TSY 1 7/8 1/06
+UROPUT STRK 99 24/3
+XP 03/17/200
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOL/CUSIP
+MRGN
+25,000,000
+YOUR PRICEDPORTFOLIOHOLDINGS
+MARKUE
+-1
+$-1
+PRICE
+Unpriced
+027
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 31, 2004
+THROUGH
+February 27,2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+ESTIMATED
+ANNUAL INCOME
+URREN
+ELD I:
+MARKE
+$0
+$0
+$-1
+CURRENT
+YIELD (%)
+$0
+$0
+02/28/04;11:32 001
+V828
+
+
+3 or a
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEEMENT TATE
+DATE
+TRANSACTION
+02/06/04 02/05/04
+BOUGHT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+PUT TSY 1 7/8 1/06
+EUROPUT STRK 99 24/32
+EXP 03/17/2004
+AS OF 02/05/04
+SYMBOLCUSIP
+TOTAL
+MISCELLANEOUS
+TRANSACTION
+JOURNAL
+DEBIT AMOUNT
+02/09/04
+TOTAL
+DESCRIPTION
+FITM FITO
+Your messages
+Excess SIPC Account Protection Update
+ffective February 16, 2004, the commercial insurer through which Bea
+teams Securities Corp, obtains excess SIPC protection changed to Custom
+CAPC has an At fiancial stength ating from standard Porse company.
+STOP
+****** End of Statement******
+027
+25,000,000
+PRICE
+0.21875
+CRECIT AMOUNT
+54,687.00
+$54,687.00
+02/28/04;11:32 001
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 31, 2004
+THROUGH
+February 27,2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+DEBIT AMOUNT
+54,687.50
+CREDIT AMOUNT
+$-54,687.50
+V828
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+02/28/04:11:32 001
+V928
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/e7a01be1a794f85b515448f28d2bb97e88bb88418e9a8b47a5dda00247020179.receipt.json b/vision-fixhub/ds9-unparsed-05/e7a01be1a794f85b515448f28d2bb97e88bb88418e9a8b47a5dda00247020179.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..281c5be96d0c7829fb2741f16afe8868c2acc113
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e7a01be1a794f85b515448f28d2bb97e88bb88418e9a8b47a5dda00247020179.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1697,
+  "dataset": "marble-joined",
+  "doc_id": "e7a01be1a794f85b515448f28d2bb97e88bb88418e9a8b47a5dda00247020179",
+  "engine": "marble-apple-vision",
+  "event_count": 30,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "abb06cc27ecaa5b2585351b64cdfcdd68a03d80880b16c3df5c2d82dabbc8067",
+  "output_sha256": "19e2c22e6894cc28a4f3711a09172756f700d2589689712b2fd9baed51d82948",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e7ed87d2a6db309d85244fac82b6e5a393f9e73b56a8fcd8b50f7d43701455c0.md b/vision-fixhub/ds9-unparsed-05/e7ed87d2a6db309d85244fac82b6e5a393f9e73b56a8fcd8b50f7d43701455c0.md
new file mode 100644
index 0000000000000000000000000000000000000000..9cfad58a9140c7525fabcca8fc42611e9c77b64a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e7ed87d2a6db309d85244fac82b6e5a393f9e73b56a8fcd8b50f7d43701455c0.md
@@ -0,0 +1,27 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+West Palm Beach, FL 33401
+(561) 820-8711
+500 South Australian Ave., Suite 400
+Facsimile: (561) 820-8777
+April 2,2007
+VIA FACSIMILE AND FEDERAL EXPRESS
+Witness Immunity Unit
+Criminal Division, Room 1056
+1001 G Street N. W.
+Washington, DC 20530
+Re: Witness Immunity Requests for
+Dear Sir or Madam:
+and
+I have attached two requests for immunity for witnesses
+Please
+ote that the expected date of testimony is April 17, 2007. Both witnesses were minors at the time the
+ere involved in the criminal activity, so please treat these applications, and their names, as confidentia
+If you have any questions or concerns, please do not hesitate to contact me at l
+Sincerely,
+R. Alexander Acosta
+United States Attorney
+By:
+Assistant United States Attorney
+Enclosure
diff --git a/vision-fixhub/ds9-unparsed-05/e7ed87d2a6db309d85244fac82b6e5a393f9e73b56a8fcd8b50f7d43701455c0.receipt.json b/vision-fixhub/ds9-unparsed-05/e7ed87d2a6db309d85244fac82b6e5a393f9e73b56a8fcd8b50f7d43701455c0.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1686ea690f3d372d1cd0641b1cee79dd0c26516e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e7ed87d2a6db309d85244fac82b6e5a393f9e73b56a8fcd8b50f7d43701455c0.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "e7ed87d2a6db309d85244fac82b6e5a393f9e73b56a8fcd8b50f7d43701455c0",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "0fd70031634b95cede30129468ba364463daf173cdb1bb1ba7e4c3cfded41ff4",
+  "output_sha256": "ea4b5e333e972c058717f44ada89ef448c0befff5ec382cc0270b0afa4414ec9",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e93a5e8e29bfef7eef922f5de8a3676071852571f2ac39514133a7d15213f6db.md b/vision-fixhub/ds9-unparsed-05/e93a5e8e29bfef7eef922f5de8a3676071852571f2ac39514133a7d15213f6db.md
new file mode 100644
index 0000000000000000000000000000000000000000..98c80f83e2e4683b804e942fc45f9f12e5230b4a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e93a5e8e29bfef7eef922f5de8a3676071852571f2ac39514133a7d15213f6db.md
@@ -0,0 +1,1662 @@
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile: (MILA
+September 2, 2008
+VIA UNITED STATES MAIL
+Miss
+Re:
+Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+I AMENDED NOTIFICATION
+Dear Miss
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos.
+and
+and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+1.
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+MISS
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms.
+If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+MISS
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401,
+In addition, there has been litigation between the United States and two other victims
+to represent you, that attorney can review the Court's order in the matter of
+, S.D. FI. Court File No.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+IHL AMENDED
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos.
+and
+and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+1.
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+Ms. JH
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+•3.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+Ms.ILL
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401,
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josetsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of
+I, S.D. Fl. Court File No.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+cc: Robert Josefsberg, Esq.
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+¡ AMENDED NOTIFICATION
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos.
+and
+and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+deter federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401,
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of
+S.D. FI. Court File No.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein
+I: AMENDED
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+79607 eir alertion protein and to as Beach ony Case No are in.
+) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+1.
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+MS._
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Jrseck, P.A., i
+Obligat, use Mr. osespered and experienceday, but as explaine.
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401,
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter off
+1, S.D. Fl. Court File No.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein
+OF IDENTIFIED VICTIM
+1: AMENDED NOTIFICATION
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos.
+and
+) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+AMENDED NOTIFICATION OF IdenTIFIED VICTIM
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401,
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of
+, S.D. FI. Court File No.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+
+
+500 South Australian Ave., Suite 400
+Yet Palm Beach, FL 33101
+Facsimile: (
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+MATE STATES MAIL
+Re: Jeffrey Epstein. I
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos.
+and l
+) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+1.
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+Ms. 1
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay. the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms.
+If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+Ms. AL
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401,
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of!
+I, S.D. FI. Court File No.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+0
+ASSISTANT U.S. ATTORNEY
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL. 33401
+Facsimile:
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+•United States Attorney
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+IDENTIFIED VICTIM
+• NOTIFICATION OF
+• Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos.
+and
+and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+1.
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, LI
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Vir. Josefsberg can provide further guidance on this issue, or if you select another attorne
+to represent you, that attorney can review the Court's order in the matter of!
+, S.D. Fl. Court File No.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+
+
+500 South Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+1: AMENDED NOTIFICATION
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+›f Florida provides you with the following amended notice. Some of the informatior
+ontained in the July 21. 2008 letter to you was inaccurate, so please take note of th
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. I
+and
+) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+
+
+MS.L
+
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C, § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+ture, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberge
+ks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Wels
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, I
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of
+1, S.D. Fl. Court File No.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+CC.
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Paim Beach, FL 33401
+Facsimile:
+September 2, 2008
+VIA UNITED STATES MAIL
+Ms. I
+Re: Jeffrey Epstein/l
+IDENTIFIED VICTIM
+| NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+• of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 1 5th Judicial Circuit in
+• and for Palm Beach County (Case Nos.
+and
+and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+1.
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josetsberg, Esq. of the tirm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+Ms.1
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401,l
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of!
+1, S.D. Fl. Court File No.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+
+
+500 South Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008.
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein
+IDENTIFIED VICTIM
+L: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos.
+and
+) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+Ms. IMI
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at |
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffiey Epstein, Mr. Epstein's attorney, Jack
+
+
+Ms.I
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, L
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of
+, S.D. Fl. Court File No.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+cc.
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein/
+OF IDENTIFIED VICTIM
+• AMENDED NOTIFICATION
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. I
+and
+) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+1.
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+
+
+
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401,
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mir. Josefsberg can provide further guidance on this issue, or if you select another attornes
+to represent you, that attorney can review the Court's order in the matter of
+I, S.D. Fl. Court File No.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FiL 33401
+Facsimile:
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+IT: AMENDED
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos.
+and
+I and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+1.
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+MS. I
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at |
+
+
+MS. J
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401,
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of !
+S.D. Fl. Court File No.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+Cc:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+EXCEPT IN CONNECTION WITH
+A LEGAL
+
+
+500 South Australian Ave., Suite 400
+West Palm Reach, FL. 33401
+Facsimile:
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+Un June 30, 2008, Jetfrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos.
+and
+) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms.
+If you would like to contact Mr. Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, L
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of
+1, S.D. FI. Court File No.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+
+
+500 South Australian Ave. Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+Wet Palm Beach, FL. 33101
+Facsimile:
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+AMENDED NOTIFICATION OF
+Dear Ms. HI
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage Il
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos.
+and
+and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+1.
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+
+
+Ms.I
+
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to'state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401,
+• In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+Lo represent you, that attorney can review the Court's order in the matter of
+S.D. Fl. Court File No.
+As 1 stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By
+ASSISTANT U.S. ATTORNEY
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+PROCEEDING:
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+VIA UNITED STATES MAIL
+Re: Jeffrey Epstein
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Ms. Patrick:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos.
+) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+
+
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+Lawsui pursuen co 1, US.C. 12: 0 or you let to file contested
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at I
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+Ms. I
+NOTIFICATION OF IdentIfIeD VICTIM
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401,
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of f
+S.D. Fl. Court File No.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this investigation and please
+accept the heartfelt regards of myself and Special Agents
+and
+for your
+health and well-being.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein
+OF IDENTIFIED VICTIM
+I AMENDED NOTIFICATION
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of. Florida provides you with the following amended notice. Some of the information
+contained in the July 21, 2008 letter to you was inaccurate, so please take note of the
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos.
+and
+D and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+
+
+
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+AMEnDED NOTIFICATION OF IDENTIFIED VICTIM
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401,
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of
+, S.D. Fl. Court File No.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+CC.
+Robert Josetsberg, Esq.
+
+
+500 South Australian Ave., Suite 400
+Wet alm Beach, FL. 334101
+Facsimile:
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+VIA UNITED STATES MAIL
+Re:
+Jeffrey Epstein/
+IDENTIFIED VICTIM
+: NOTIFICATION OF
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida provides you with the following notice because you are an identified victim of a
+federal offense.
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos.
+and
+) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+deter federal prosecution in favor of this state plea and sentence, subject to certain
+1. -
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A.., a highly-respected and experienced attorney. You are not
+
+
+
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+• If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.Ş.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr: Josefsberg directly, he can be reached at
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack
+
+
+
+Goldberger, asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger
+and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, IL
+In addition, there has been litigation between the United States and two other victims
+• regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of I
+, S.D. FI. Court File No.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation.
+Thank you for all of your assistance during the course of this in vestigation and please
+accept the heartfelt regards of myself and Special Agents
+health and well-being.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+
+
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+
+
+V.S. Department of Justice
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Facsimile:
+September 2, 2008
+• VIA UNITED STATES MAIL
+Re: Jeffrey Epstein.
+AMENDED
+NOTIFICATION OFIDENINPIED VICTIM
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+f Florida provides you with the following amended notice. Some of the informatio
+ontained in the July 21. 2008 letter to you was inaccurate, so please take note of th
+following changes.
+As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter
+referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections
+796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in
+prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos.
+and
+) and was sentenced to a term of twelve
+months' imprisonment to be followed by an additional six months' imprisonment, followed
+by twelve months of Community Control 1, with conditions of community confinement
+imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+An independent Special Master was assigned the task of selecting an
+attorney representative to represent the victims, including you, in
+
+
+
+connection with civil actions between the victims and Mr. Epstein. The
+Special Master selected Robert Josefsberg, Esq. of the firm Podhurst
+Orseck, P.A., a highly-respected and experienced attorney. You are not
+obligated to use Mr. Josefsberg as your civil attorney, but, as explained
+in greater detail below, Mr. Josefsberg's services will be provided at no
+cost to you because Mr. Epstein is obligated to pay the costs and fees
+of the attorney-representative. Also, Mr. Epstein and his attorneys can
+only contact you via Mr. Josefsberg, assuming that you would like Mr.
+Josefsberg to serve as your attorney.
+If you elect to file suit against Mr. Epstein pursuant to Title 18, United
+States Code, Section 2255, Mr. Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida
+over his person and/or the subject matter, and Mr. Epstein waives his
+right to contest liability and also waives his right to contest damages up
+to an amount as agreed to between you and Mr. Epstein, so long as you
+elect to proceed exclusively under 18 U.S.C. § 2255, and you waive any
+other claim for damages, whether pursuant to state, federal, or common
+law. Notwithstanding this waiver, Epstein's agreement with the United
+States, his waivers and failure to contest liability and such damages in
+any suit are not to be construed as an admission of any criminal or civil
+liability.
+As stated above, Mr. Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision,
+however, shall not obligate Epstein to pay the fees and costs of
+contested litigation filed against him. Thus, if after consideration of
+potential settlements, you and Mr. Josefsberg elect to file a contested
+lawsuit pursuant to 18 U.S.C. § 2255 or you elect to pursue any other
+contested remedy, the obligation to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay
+reasonable attorneys fees and costs such as those contained in Section
+Mr. Josefsberg will be contacting you within the next two weeks to explain these
+terms. If you would like to contact Mr. Josefsberg directly, he can be reached at
+
+
+
+If you have already selected other counsel to represent you, or if you do so in the
+future, and you decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger,
+asks that you have your attorney contact Mr. Goldberger at Atterbury Goldberger and Weiss,
+250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401,
+In addition, there has been litigation between the United States and two other victims
+regarding the disclosure of the entire agreement between the United States and Mr. Epstein.
+Mr. Josefsberg can provide further guidance on this issue, or if you select another attorney
+to represent you, that attorney can review the Court's order in the matter of
+1, S.D. Fl. Court File No.
+As I stated in my earlier notification, please understand that neither the U.S.
+Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist
+in civil litigation, but we again thank you for all of your assistance during the course of this
+investigation.
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+cc: Robert Josefsberg, Esq.
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/e93a5e8e29bfef7eef922f5de8a3676071852571f2ac39514133a7d15213f6db.receipt.json b/vision-fixhub/ds9-unparsed-05/e93a5e8e29bfef7eef922f5de8a3676071852571f2ac39514133a7d15213f6db.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b1efebb0bb579ce2030aa928e1c8146eea33bf79
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e93a5e8e29bfef7eef922f5de8a3676071852571f2ac39514133a7d15213f6db.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -9148,
+  "dataset": "marble-joined",
+  "doc_id": "e93a5e8e29bfef7eef922f5de8a3676071852571f2ac39514133a7d15213f6db",
+  "engine": "marble-apple-vision",
+  "event_count": 104,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "aacaaf0e86f3b41be4e1c092464a6ebba251ea2c9f024f4fbf5ab81fac04f6fa",
+  "output_sha256": "4646de63802c5006ef8cd32a3f1b123411b738a95440c93cbabe1d52eca3e086",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e9589f3e6e395e19581fe95ef620e1706435091cfcfd2be58e6d01269eb5ac4d.md b/vision-fixhub/ds9-unparsed-05/e9589f3e6e395e19581fe95ef620e1706435091cfcfd2be58e6d01269eb5ac4d.md
new file mode 100644
index 0000000000000000000000000000000000000000..bc047db0d389d12a6d733d122a71368d111afad8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e9589f3e6e395e19581fe95ef620e1706435091cfcfd2be58e6d01269eb5ac4d.md
@@ -0,0 +1,26 @@
+AO 190 (Rev. 01/09) Record of the Number of Grand Jurors Concurring in an Indictment
+UNITED STATES DISTRICT COURT
+for the
+Southern District of Florida
+) Indictment No.
+Case No.
+United States of America
+JEFFREY EPSTEIN,
+Talka"
+and
+Defendant
+RECORD OF THE NUMBER OF GRAND JURORS CONCURRING IN AN INDICTMENT
+As the foreperson of the grand jury of this court at a session held at
+West Palm Beach, Florida
+on
+06/16/2009
+, I certify that (specify number)
+grand jurors concurred in the indictment in this case.
+Under Fed. R. Crim. P. 6(c), this record is being filed with the court clerk and will not be made public unless the court
+orders otherwise.
+Date:
+Foreperson's signature
+FGJ No:
+Print
+Save As...
+Reset
diff --git a/vision-fixhub/ds9-unparsed-05/e9589f3e6e395e19581fe95ef620e1706435091cfcfd2be58e6d01269eb5ac4d.receipt.json b/vision-fixhub/ds9-unparsed-05/e9589f3e6e395e19581fe95ef620e1706435091cfcfd2be58e6d01269eb5ac4d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ddf701af45f1743ef47cf8e0d58c27a1978edd54
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e9589f3e6e395e19581fe95ef620e1706435091cfcfd2be58e6d01269eb5ac4d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "e9589f3e6e395e19581fe95ef620e1706435091cfcfd2be58e6d01269eb5ac4d",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "23f4dfda4d7d7d7b159caf8ec905d821e9e0506da9b94c2db29c1d79886f0153",
+  "output_sha256": "049f7c6a8b9ccdc43140a1435f89c3b6142a2f00cf0dfb8972534a4a359655e5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/e9cda2249073ae380edd2808ea569d92efcf2db751d64e7c5d58a9adc18a2a0e.md b/vision-fixhub/ds9-unparsed-05/e9cda2249073ae380edd2808ea569d92efcf2db751d64e7c5d58a9adc18a2a0e.md
new file mode 100644
index 0000000000000000000000000000000000000000..1864270ff37c79382fb42fadc8a65c3d17d397e1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e9cda2249073ae380edd2808ea569d92efcf2db751d64e7c5d58a9adc18a2a0e.md
@@ -0,0 +1,113 @@
+
+GEPRINTTHIS
+PalmBeachPost.com
+By Larry Keller
+UPDATED
+WEEKLY
+Palm Beach Post Staff Writer
+Monday, August 14, 2006
+In the case of Palm Beach financier Jeffrey Epstein, it seems, at times, as if two men
+are accused of wrongdoing: Epstein and Palm Beach Police Chief
+Browse
+Specials
+& Deals
+From Local
+Dealerships
+Epstein, 53, was indicted last month on a charge of felony solicitation of
+Autos
+PalmBeachPost.com
+prostitution solely because of
+"craziness," one of Epstein's lawyers said. His
+department disseminated "a distorted view of the case" and behaved in a "childish" manner when the
+grand jury didn't indict Epstein on the charges it sought, another Epstein lawyer complained
+Jeffrey Epstein
+Billionaire
+financier
+Jeffrey
+Epstein has
+been indicted
+for felony solicitation of
+prostitution by a grand
+jury following
+accusations by teen girls.
+• Past headlines
+To hear the Epstein camp tell it,
+1. 48,
+is a loose cannon better suited to be the
+sheriff of Mayberry. They whisper that he's
+embroiled in a messy divorce.
+did in fact file for divorce from his
+wife, Jill, last year, after 24 years of
+marriage. They have a son, 18, and a
+daughter, 14. The couple is scheduled to go
+to mediation next week, Aug. 16. Nothing
+in the court file suggests their split is
+particularly ugly.
+More local news
+Latest breaking news, photos and all of today's Post stories.
+Share This Story
+incurred the wrath of the Epstein
+camp as well as the state attorney's office
+for two reasons. First, he pressed for
+Epstein to be charged with the more serious crimes of sexual activity with minors. Second, he slammed
+State Attorney
+in blunt language seldom used by one law-enforcement official
+concerning another because of what he perceived as that office's mishandling of the case.
+In a letter to
+written May 1,
+called his actions in the Epstein case "highly unusual." He
+added, "I must urge you to... consider if good and sufficient reason exists to require your disqualification
+from the prosecution of these cases."
+
+
+
+In short,
+said of
+told the county's top prosecutor for the past 13 years that he ought to get off the case. "It
+looks like a departure from professionalism," Miami-Dade State Attorney
+letter.
+Following Epstein's indictment,
+referred the case to the FBI to determine whether the super-rich,
+super-connected defendant had violated any federal laws.
+won't discuss the case or the broadsides aimed at him. But others almost uniformly use one word
+to describe the chief: professional.
+"I have always been impressed by Mike's professionalism and his leadership," said
+of the Lantana Police Department and a Palm Beach County cop for 32 years.
+, chief
+"The town of Palm Beach has a very professional police department. We all consider Mike to be our
+peer and a man of integrity."
+Juno Beach Police Chief
+agreed. Although he doesn't know
+well, he has met with
+him on countywide law enforcement issues. "I've never seen him lose his cool. I've never seen anything
+but a professional demeanor from him."
+joined the Palm Beach Police Department in 1981, leaving a $20,000-a-year patrol job at the
+University of Pittsburgh. His personnel jacket shows consistently excellent job evaluations.
+Posh Palm Beach is no hotbed of crime, and in his first year on the job, a resident confined to his home
+with a sick child thanked
+for delivering a few Cokes to the house.
+refused payment for the
+beverages. Another resident thanked
+for shutting off his car's headlights in his driveway, saying a
+valet must have been at fault.
+worked everything from road patrol to organized crime, vice and narcotics. And he's no novice at
+investigations involving the island's rich and famous. He was the lead detective probing the drug
+overdose death of David Kennedy in 1984. He also was one of the officers who worked the investigation
+of William Kennedy Smith, who was charged in 1991 — and later acquitted — with raping a woman at
+the Kennedy family compound in Palm Beach.
+who has a master's degree in human resource development from Palm Beach Atlantic University,
+also has attended the FBI National Academy in Quantico, Va., and management courses at Harvard.
+He's been active in countywide interagency law enforcement organizations and has a "top secret"
+national security clearance.
+"He has a perspective that's broader than just addressing the needs of the town," said Town Manager
+, who promoted
+from assistant chief to chief in March 2001.
+makes more than
+$144,000 as the town's top cop. Elwell thinks he's worth it.
+"He's very businesslike, very straightforward. He's not easily agitated or flamboyant. He's about the
+work," Elwell said. "I think that his service as chief has been outstanding in five-plus years."
+Find this article at:
+
+
+
+• Check the box to include the list of links referenced in the article.
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/e9cda2249073ae380edd2808ea569d92efcf2db751d64e7c5d58a9adc18a2a0e.receipt.json b/vision-fixhub/ds9-unparsed-05/e9cda2249073ae380edd2808ea569d92efcf2db751d64e7c5d58a9adc18a2a0e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b500b4f32382471bda0989e3c99934657de4cbfd
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/e9cda2249073ae380edd2808ea569d92efcf2db751d64e7c5d58a9adc18a2a0e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -297,
+  "dataset": "marble-joined",
+  "doc_id": "e9cda2249073ae380edd2808ea569d92efcf2db751d64e7c5d58a9adc18a2a0e",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "c46f35e083acfc574dd4460e87fb7eda214993f5f38a90608de6118326745870",
+  "output_sha256": "91a789c126d386f4ddd3d48137af2b66b9ab4e4a78319265ef27ded34c9f5b0d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ea41360245c2260441fe9a8d8ce2adde8596ec64953555bd72716e1e0b427b09.md b/vision-fixhub/ds9-unparsed-05/ea41360245c2260441fe9a8d8ce2adde8596ec64953555bd72716e1e0b427b09.md
new file mode 100644
index 0000000000000000000000000000000000000000..a3aa39275184ce0b5353de9ca2f91ecafc5532ba
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ea41360245c2260441fe9a8d8ce2adde8596ec64953555bd72716e1e0b427b09.md
@@ -0,0 +1,3244 @@
+Subject:
+Well, our victim notification letter has been filed in court
+(preicim notification letter has been filed in court in connection with one of the federal civil suits against
+About 10 letters have gone out so far. The FBI's victim coordinator is updating the addresses on the rest and
+they will go out on Monday.
+445
+
+
+Kuyrkendall, E N. (FBI)
+Richards, Jason R. (FBI)
+Atkinson. Karen (USAFLS)
+Read: 7/18/2008 4:53 PM
+Read: 7/18/2008 4:51 PM
+446
+
+
+To:
+Cc:
+Subject:
+/illafana, Ann Marie C. (USAFLS
+Thursday, July 17, 2008 6:22 PN
+Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS); Atkinson, Karen (USAFLS)
+Richards, Jason (BOP); Nesbitt Kuyrkendall (E.Kuyrkendall@ic.fbi.gov)
+Tein Ltr 080717.pdf
+Hi all - I just faxed out the letter, here is the electronic version with the fax confirmation sheets.
+Tein Ltr
+080717.pdf
+447
+
+
+To:
+Subject:
+Thursday, July 17, 2008 3:11 PM
+RE: Emailing: 080717 Tein Ltr.wpc
+Okey dokey.
+-----Original Message-----
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Thursday, July 17, 2008 3:02 PM
+To: Sloman, Jeff (USAFLS)
+Subject: Re: Emailing: 080717 Tein Ltr.wpd
+Hi jeff. I am still being held hostage at the county courthouse but I will revise
+and send tonight.
+Thanks.
+•---- Original Message -....
+From: Sloman, Jeff (USAFLS)
+To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Atkinson, Karen
+(USAFLS) ; Lee, Dexter (USAFLS)
+Sent: Thu Jul 17 14:51:28 2008
+Subject: RE: Emailing: 080717 Tein Ltr.wpd
+Marie,
+Tein may be trying to bait us into declaring the matter closed when it's
+technically deferred/suspended. As a result, I've revised your draft which you
+may be able to color in a bit. Let me know what you think. Thanks,
+Jeff
+-----Original Message---
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Thursday, July 17, 2008 11:38 AM
+To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS); Lee,
+Dexter (USAFLS)
+Subject: Emailing: 080717 Tein Ltr.wpd
+-----Original Message-----
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Thursday, July 17, 2008 11:38 AM
+To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS); Lee,
+Dexter (USAFLS)
+Subject: Emailing: 080717 Tein Ltr. wpd
+448
+
+
+Here it is. Feel free to revise. I have listed myself as the author, but it
+may be more powerful coming from someone else.
+The message is ready to be sent with the following file or link attachments:
+080717 Tein Ltr.wpd
+Note: To protect against computer viruses, e-mail programs may prevent sending or
+receiving certain types of file attachments. Check your e-mail security settings
+449
+
+
+To:
+Subject:
+Soman. Jet (U34715 302 PM
+Re: Emailing: 080717 Tein Ltr.wpd
+Hi jeff. I am still being held hostage at the county courthouse but I will revise
+and send tonight.
+hanks.
+----- Original Message -...-
+From: Sloman, Jeff (USAFLS)
+To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Atkinson, Karen
+(USAFLS); Lee, Dexter (USAFLS)
+Sent: Thu Jul 17 14:51:28 2008
+Subject: RE: Emailing: 080717 Tein Ltr.wpd
+Marie,
+Tein may be trying to bait us into declaring the matter closed when it's
+technically deferred/suspended. As a result, I've revised your draft which you
+may be able to color in a bit. Let me know what you think. Thanks,
+Jeff
+-----Original Message-----
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Thursday, July 17, 2008 11:38 AM
+To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS); Lee,
+Dexter (USAFLS)
+Subject: Emailing: 080717 Tein Ltr.wpd
+-----Original Message-...--
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Thursday, July 17, 2008 11:38 AM
+To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS); Lee,
+Dexter (USAFLS)
+Subject: Emailing: 080717 Tein Ltr. wpd
+Here it is. Feel free to revise. I have listed myself as the author, but it
+may be more powerful coming from someone else.
+The message is ready to be sent with the following file or link attachments:
+080717 Tein Ltr.wpd
+450
+
+
+Note: To protect against computer viruses, e-mail programs may prevent sending or
+receiving certain types of file attachments. Check your e-mail security settings
+451
+
+
+To:
+Subject:
+Thursday, July 17, 2008 1:31 PM
+Funny epstein story
+Well, jeff, epstein's pricey lawyers may have cost him $200 million. I reviewed
+the docket sheets for the 4 pending federal suits (they are all jeff herman
+suits) and judge marra has issued orders to show cause why default judgments
+shouldn't be entered for all 4. Herman asked for $50 million in each one.
+Apparently epstein tried to avoid service and ignored the deadline when the
+complaints were mailed to him (thinking that was ineffective service). All I can
+say is, so much money, so little skill.
+452
+
+
+To:
+Subject:
+Attachments:
+Thursday, July 17, 2008 11:38 AN
+Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS); Lee, Dexter
+(USAFLS)
+Emailing: 080717 Tein Ltr.wpd
+080717 Tein Ltr.wpd
+Here it is. Feel free to revise. I have listed myself as the author, but it
+may be more powerful coming from someone else.
+The message is ready to be sent with the following file or link attachments:
+080717 Tein Ltr. wpd
+Note: To protect against computer viruses,
+e-mail programs may prevent sending or
+receiving certain types of file attachments.
+453
+
+
+To:
+Subject:
+RE: Epstein's Court Filings
+Do you want to call me or should I call you?
+500 S. Australian Ave, Suite 400
+-----Original Message-----
+From: Acosta, Alex (USAFLS)
+Sent: Thursday, July 17, 2008 9:49 AM
+To: Villafana, Ann Marie C. (USAFLS); Lee, Dexter (USAFLS); Sloman, Jeff
+(USAFLS); Castillo, Annette (USAFLS)
+Cc: Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+Subject: Re: Epstein's Court Filings
+Let's talk at 10 15.
+----- Original Message
+=----
+From: Villafana, Ann Marie C. (USAFLS)
+To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+Sent: Thu Jul 17 09:44:08 2008
+Subject: Epstein's Court Filings
+Hi all - Here are the documents that Mike Tein filed in connection with one of
+the civil suits pending against Epstein in the District Court. Note that Judge
+Marra is assigned to all of the federal civil suits, and also is the judge on the
+suit filing against the United States.
+Tein filed these ex parte and under seal and claims that all of the civil
+litigation has to be stayed because "the federal criminal action" is still
+pending. He discloses that a federal indictment had been prepared and that grand
+jury proceedings had occurred. I am concerned that this contradicts what Dexter
+told the Court, namely that a federal prosecution was never contemplated.
+<<DE24_080717_Notice of Pendency of Federal Case. pdf>> ‹DE23_088717_Motn to
+File Ex Parte and Under Seal.pdf>>
+500 S. Australian Ave, Suite 408
+454
+
+
+455
+
+
+Read: 7/17/2008 10:21 AM
+456
+
+
+To:
+Subject:
+Thursday, July 17, 2008 10:01 AN
+RE: Epstein's Court Filings
+Hey Dexter. I told Irene about Mr. Edwards' vacation, so all is well on that front.
+500 S. Australian Ave, Suite 400
+From: Lee, Dexter (USAFLS)
+Sent: Thursday, July 17, 2008 9:54 AM
+To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+Subject: RE: Epstein's Court Filings
+My recollection is that I told the court no federal prosecution was contemplated by either party, in the event an
+British Petroleum were negotiating a plea agreement, but it was clear there was going to be a federal prosecution,
+whether by a plea agreement or a litigated trial.
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Thursday, July 17, 2008 9:44 AM
+To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+Subject: Epstein's Court Filings
+Hi all - Here are the documents that Mike Tein filed in connection with one of the civil suits pending against
+Epstein in the District Court. Note that Judge Marra is assigned to all of the federal civil suits, and also is the
+judge on the suit filing against the United States.
+Tein filed these ex parte and under seal and claims that all of the civil litigation has to be stayed because "the
+federal criminal action" is still pending. He discloses that a federal indictment had been prepared and that grand
+jury proceedings had occurred. I am concerned that this contradicts what Dexter told the Court, namely that a
+federal prosecution was never contemplated.
+<< File: DE24_080717_Notice of Pendency of Federal Case.pdf >> << File: DE23_
+_080717_Motn to File Ex
+Parte and Under Seal.pdf>>
+457
+
+
+500 S. Australian Ave, Suite 400
+458
+
+
+Lee. Dexter (USAFLS)
+Read: 7/17/2008 10:03 AM
+459
+
+
+To:
+Cc:
+Subject:
+Thursday, July 17, 2008 9:54 AM
+Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+RE: Epstein's Court Filings
+My recollection is that I told the court no federal prosecution was contemplated by either party, in the event an
+agreement could be reached. We acknowledged at the hearing that the case had been referred to our office, and the
+FBI had conducted an investigation. I was attempting to distinguish Dean, where both the U.S. Attorney's Office and
+British Petroleum were negotiating a plea agreement, but it was clear there was going to be a federal prosecution,
+whether by a plea agreement or a litigated trial.
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Thursday, July 17, 2008 9:44 AM
+To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+Subject: Epstein's Court Filings
+Hi all - Here are the documents that Mike Tein filed in connection with one of the civil suits pending against
+Epstein in the District Court. Note that Judge Marra is assigned to all of the federal civil suits, and also is the
+judge on the suit filing against the United States.
+Tein filed these ex parte and under seal and claims that all of the civil litigation has to be stayed because "the
+federal criminal action" is still pending. He discloses that a federal indictment had been prepared and that grand
+jury proceedings had occurred. I am concerned that this contradicts what Dexter told the Court, namely that a
+federal prosecution was never contemplated.
+< File: DE24_080717_Notice of Pendency of Federal Case.pdf>> << File: DE23_080717_Motn to File Ex
+Parte and Under Seal.pdf>>
+500 S. Australian Ave, Suite 400
+460
+
+
+To:
+Cc:
+Subject:
+Thursday, July 17, 2008 9:49 AM
+Villafana, Ann Marie C. (USAFLS); Lee, Dexter (USAFLS); Sloman, Jeff (USAFLS); Castillo,
+Annette (USAFLS)
+Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+Re: Epstein's Court Filings
+Let's talk at 10 15.
+----- Original Message
+From: Villafana, Ann Marie C. (USAFLS)
+To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FB-)
+Sent: Thu Jul 17 09:44:08 2008
+Subject: Epstein's Court Filings
+Hi all - Here are the documents that Mike Tein filed in connection with one of
+the civil suits pending against Epstein in the District Court. Note that Judge
+Marra is assigned to all of the federal civil suits, and also is the judge on the
+suit filing against the United States.
+Tein filed these ex parte and under seal and claims that all of the civil
+litigation has to be stayed because "the federal criminal action" is still
+pending. He discloses that a federal indictment had been prepared and that grand
+jury proceedings had occurred. I am concerned that this contradicts what Dexter
+told the Court, namely that a
+federal prosecution was never contemplated.
+<<DE24_080717_Notice of Pendency of Federal Case.pdf>> ‹<DE23_080717_Motn to
+File Ex Parte and Under Seal. pdf>>
+A. Marie Villafana
+500 S. Australian Ave, Suite 400
+461
+
+
+To:
+Cc:
+Subject:
+Thursday, July 17, 2008 9:44 AM
+Lee, Dexter (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+Epstein's Court Filings
+Hi all - Here are the documents that Mike Tein filed in connection with one of the civil suits pending against
+Epstein in the District Court. Note that Judge Marra is assigned to all of the federal civil suits, and also is the
+judge on the suit filing against the United States.
+Tein filed these ex parte and under seal and claims that all of the civil litigation has to be stayed because "the
+federal criminal action" is still pending. He discloses that a federal indictment had been prepared and that grand
+jury proceedings had occurred. I am concerned that this contradicts what Dexter told the Court, namely that a
+DE24_080717_NDE23_080717_M
+tice of Pendencystn to File Ex Pa..
+500 S. Australian Ave, Suite 400
+462
+
+
+Kuyrkendall, E N. (FBI)
+Richards, Jason R. (FBI)
+Yera, E.J. (USAFLS)
+Read: 7/17/2008 9:45 AM
+Read: 7/17/2008 9:45 AM
+Read: 7/17/20089:44 AM
+Read: 7/17/2008 10:00 AM
+463
+
+
+To:
+Subject:
+Tuesday, July 15, 2008 6:53 PM
+Sloman, Jeff (USAFLS); Valle, Alicia (USAFLS); Acosta, Alex (USAFLS); Lee, Dexter
+Emaken: alemkepsteino 5., mason R. (FB); kinson, Karen (USAF LS)
+Wow - these guys work fast. Here is the Palm Beach Daily News report re Epstein.
+webmmkepstein
+0715.htm
+474
+
+
+To:
+Subject:
+Tuesday, July 15, 2008 6:33 PM
+Stipulation in Word Perfect Format
+Hi Dexter - I have been called up for jury duty tomorrow (can you believe it?). So here is the stipulation in
+Word Perfect format. Nesbitt is going to contact you directly tomorrow with any changes and with the two
+missing dates. I will call Brad Edwards and let him know that you will be in touch tomorrow.
+I will bring my Blackberry with me, but don't know how much I will be able to check it.
+Thank you.
+Stipulation.wpd
+500 S. Australian Ave, Suite 400
+Fax 56l 820-8777
+475
+
+
+476
+Read: 7/15/2008 6:36 PM
+
+
+To:
+Subject:
+Tuesday, July 15, 2008 6:31 PM
+Kuyrkendall, E N. (FBI)
+RE: Stipulation in Jane Doe Case
+That is fine. Hope all is okay.
+I have jury duty tomorrow so can you e-mail Dexter directly?
+500 S. Australian Ave, Suite 400
+-----Original Message-...-
+From: Kuyrkendall, E N. (FBI)
+Sent: Tuesday, July 15, 2008 6:20 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Re: Stipulation in Jane Doe Case
+Marie, I've been out on another matter. I will get that info to u first thing in
+the morn if that is ok.
+•---- Original Message
+From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov>
+To: Lee, Dexter (USAFLS); Kuyrkendall, E N.; Richards, Jason R.
+Sent: Tue Jul 15 18:16:49 2008
+Subject: Stipulation in Jane Doe Case
+Hi Nesbitt and Jason - Can you double check the facts and give me the two missing
+dates?
+Dexter - This is my draft. I will wait to hear back from you before I send it to
+Edwards. Thanks.
+<<Stipulation.pdf>>
+500 S. Australian Ave, Suite 400
+477
+
+
+478
+
+
+To:
+Subject:
+Tuesday, July 15, 2008 6:17 PM
+Lee, Dexter (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+Stipulation in Jane Doe Case
+Hi Nesbitt and Jason - Can you double check the facts and give me the two missing dates?
+Dexter - This is my draft. I will wait to hear back from you before I send it to Edwards. Thanks.
+Stipulation.pdf
+500 S. Australian Ave, Suite 400
+479
+
+
+Kuyrkendall, E N. (FBI)
+Richards, Jason R. (FBI)
+Read: 7/15/2008 6:17 PM
+480
+
+
+To:
+Subject:
+Tuesday, July 15, 2008 4:35 PM
+Richards, Jason R. (FBI): Kuyrkendall, E N. (FBI)
+Date you met with
+Hi Jason and Nesbitt - Did you ever find your notes? Do you know what date you met with ( li
+city was the meeting in?
+500 S. Australian Ave, Suite 400
+? and what
+481
+
+
+To:
+Subject:
+RE: In Re Jane Doe - Call from Palm Beach Daily News
+We moved to have them sealed but the Judge denied the motion, so they are all publicly available.
+500 S. Australian Ave, Suite 400
+From: Valle, Alicia (USAFLS)
+Sent: Tuesday, July 15, 2008 4:27 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News
+None sealed, correct??
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Tuesday, July 15, 2008 4:24 PM
+To: Valle, Alicia (USAFLS); Lee, Dexter (USAFLS)
+Cc: Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS) :
+Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News
+Here is the scanned file-stamped copies of our filings. Along with the filings of the Jane Does from PACER.
+« File: DE2_080707 _Cert of Emergency.pdf »> «< File: DE1_080707_Petition.pdf »> « File: DE9_080711_Reply
+Brief.pdf >> «< File: In Re Jane Doe001.pdf >>
+A. Marie Villataña
+500 S. Australian Ave, Suite 400
+From: Valle, Alicia (USAFLS)
+Sent: Tuesday, July 15, 2008 4:22 PM
+To: Lee, Dexter (USAFLS)
+Cc: Villaana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS)
+Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News
+
+
+Ok - just got off the phone with her.
+Can you send me copies of the does, which I will forward to her? thanks, aov
+From: Lee, Dexter (USAFLS)
+Sent: Tuesday, July 15, 2008 2:15 PM
+To: Valle, Alicia (USAFLS)
+Cc: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS)
+Subject: In Re Jane Doe - Call from Palm Beach Daily News
+Alicia,
+I just received a phone call from Maggie Kacoha of the Palm Beach Daily News, (561) 820-3850, asking about the Jane
+Doe case. She told me they were tied up on Friday and unable to attend the hearing before Judge Marra. She said
+she had read the Sun Sentinel article and wanted to confirm that : (1) the government argued the court had no
+jurisdiction; and (2) the district court agreed.
+I gave her your name and said someone would be calling her back. I told her that the filings had all been unsealed and
+she could access them through PACER. I did confirm that the government argued the court did not have jurisdiction,
+but said the case was not over. I declined to make any other comments.
+When the hearing concluded last Friday, Judge Marra left it up to the parties to advise the court whether an evidentiary
+hearing was needed. If the answer is yes, then the court will schedule a hearing. If the answer is no, then I assume
+the court will go ahead and rule on the papers filed.
+If you need copies of what the government filed, please let me know. Thanks.
+483
+
+
+Read: 7/15/2008 4:40 PM
+484
+
+
+To:
+Subject:
+Tuesday, July 15, 2008 4:31 PM
+Valle, Alicia (USAFLS); Lee, Dexter (USAFLS)
+RE: In Re Jane Doe - Call from Palm Beach Daily News
+The motion has been taken under advisement. The parties are conferring to determine if an evidentiary hearing
+is necessary.
+500 S. Australian Ave, Suite 400
+From: Valle, Alicia (USAFLS)
+Sent: Tuesday, July 15, 2008 4:25 PM
+To: Villafana, Ann Marie C. (USAFLS); Lee, Dexter (USAFLS)
+Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News
+Perfect - I will forward to her.
+So, in a nutshell, what was the result of the hearing on Friday?
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Tuesday, July 15, 2008 4:24 PM
+To: Valle, Alicia (USAFLS); Lee, Dexter (USAFLS)
+Cc: Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS)
+Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News
+Here is the scanned file-stamped copies of our filings. Along with the filings of the Jane Does from PACER.
+« File: DE2_080707 _Cert of Emergency.pdf » « File: DE1_080707_Petition.pdf >> «< File: DE9_080711_Reply
+Brief.pdf >> «< File: In Re Jane Doe001. pdf >>
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL. 33401
+From: Valle, Alicia (USAFLS)
+Sent: Tuesday, July 15, 2008 4:22 PM
+485
+
+
+To: Lee, Dexter (USAFLS)
+Cc: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS)
+Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News
+Ok - just got off the phone with her.
+Can you send me copies of the docs, which I will forward to her? thanks, aov
+From: Lee, Dexter (USAFLS)
+Sent: Tuesday, July 15, 2008 2:15 PM
+To: Valle, Alicia (USAFLS)
+Cc: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS)
+Subject: In Re Jane Doe - Call from Palm Beach Daily News
+Alicia,
+I just received a phone call from Maggie Kacoha of the Palm Beach Daily News, (561) 820-3850; asking about the Jane
+Doe case. She told me they were tied up on Friday and unable to attend the hearing before Judge Marra.
+she had read the Sun Sentinel article and wanted to confirm that : (1) the government argued the court had no
+jurisdiction; and (2) the district court agreed.
+I gave her your name and said someone would be calling her back. I told her that the filings had all been unsealed and
+she could access them through PACER. I did confirm that the government argued the court did not have jurisdiction,
+but said the case was not over. I declined to make any other comments.
+When the hearing concluded last Friday, Judge Marra left it up to the parties to advise the court whether an evidentiary
+hearing was needed. If the answer is yes, then the court will schedule a hearing. If the answer is no, then I assume
+the court will go ahead and rule on the papers filed.
+If you need copies of what the government filed, please let me know. Thanks.
+486
+
+
+487
+Read: 7/15/2008 4:40 PM
+Read: 7/15/2008 4:38 PM
+
+
+To:
+Cc:
+Subject:
+Tuesday, July 15, 2008 4:24 PM
+Valle, Alicia (USAFLS); Lee, Dexter (USAFLS)
+Sloman, Jeff (USAFLS): Acosta, Alex (USAFLS)
+RE: In Re Jane Doe - Call from Palm Beach Daily News
+Here is the scanned file-stamped copies of our filings. Along with the filings of the Jane Does from PACER.
+DE2_080707_CeDE1_080707_PetDE9_080711_Re In Re Jane
+of Emergency.p.
+ition.pdf
+ply Brief.pdf
+Doe001.pdf
+A. Marie Villataña
+500 S. Australian Ave, Suite 400
+From: Valle, Alicia (USAFLS)
+Sent: Tuesday, July 15, 2008 4:22 PM
+To: Lee, Dexter (USAFLS)
+Cc: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS)
+Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News
+Ok - just got off the phone with her.
+Can you send me copies of the does, which I will forward to her? thanks, aov
+From: Lee, Dexter (USAFLS)
+Sent: Tuesday, July 15, 2008 2:15 PM
+To: Valle, Alicia (USAFLS)
+Cc: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS)
+Subject: In Re Jane Doe - Call from Palm Beach Daily News
+Alicia,
+I just received a phone call from Maggie Kacoha of the Palm Beach Daily News, (561) 820-3850, asking about the Jane
+Doe case. She told me they were tied up on Friday and unable to attend the hearing before Judge Marra. She said
+she had read the Sun Sentinel article and wanted to confirm that : (1) the government argued the court had no
+jurisdiction; and (2) the district court agreed.
+I gave her your name and said someone would be calling her back. I told her that the filings had all been unsealed and
+she could access them through PACER. I did confirm that the government argued the court did not have jurisdiction,
+but said the case was not over. I declined to make any other comments.
+488
+
+
+When the hearing concluded last Friday, Judge Marra left it up to the parties to advise the court whether an evidentiary
+hearing was needed. If the answer is yes, then the court will schedule a hearing. If the answer is no, then I assume
+the court will go ahead and rule on the papers filed.
+If you need copies of what the government filed, please let me know. Thanks.
+489
+
+
+Read: 7/15/2008 4:25 PM
+Read: 7/15/2008 4:36 PM
+Read: 7/15/2008 4:25 PM
+490
+
+
+To:
+Subject:
+Tuesday, July 15, 2008 4:21 PM
+RE: In Re Jane Doe - Call from Palm Beach Daily News
+Hi Dexter - Just got a voicemail from Brad. I will draft something up and will forward it to you before I send it
+over to him.
+Thanks.
+500 S. Australian Ave, Suite 400
+Phone 56l 209-1047
+From: Lee, Dexter (USAFLS)
+Sent: Tuesday, July 15, 2008 3:44 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News
+Marie,
+I have heard nothing from Edwards. My recollection is that you told him you would prepare a document for joint filing,
+once we agreed after the hearing that an evidentiary hearing was not necessary for either side.
+We were going to
+detail what occurred at the meeting between Nesbitt and Jason at Publix with !., and Edwards was going to provide
+perception of what she was told by Nesbitt and Jason.
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Tuesday, July 15, 2008 3:09 PM
+To: Lee, Dexter (USAFLS)
+Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News
+Hi Dexter - Have you heard any more from Mr. Edwards? I don't like to keep Judge Marra waiting. He is our
+nicest judge, so I like to be as responsive as possible.
+500 S. Australian Ave, Suite 400
+Fax 56l 820-8777
+491
+
+
+From: Lee, Dexter (USAFLS)
+Sent: Tuesday, July 15, 2008 2:15 PM
+To: Valle, Alicia (USAFLS)
+Cc: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS)
+Subject: In Re Jane Doe - Call from Palm Beach Daily News
+Alicia,
+I just received a phone call from Maggie Kacoha of the Palm Beach Daily News, (561) 820-3850, asking about the Jane
+Doe case. She told me they were tied up on Friday and unable to attend the hearing before Judge Marra. She said
+she had read the Sun Sentinel article and wanted to confirm that: (1) the government argued the court had no
+jurisdiction; and (2) the district court agreed.
+I gave her your name and said someone would be calling her back. I told her that the filings had all been unsealed and
+she could access them through PACER. I did confirm that the government argued the court did not have jurisdiction,
+but said the case was not over. I declined to make any other comments.
+When the hearing concluded last Friday, Judge Marra left it up to the parties to advise the court whether an evidentiary
+hearing was needed. If the answer is yes, then the court will schedule a hearing. If the answer is no, then I assume
+the court will go ahead and rule on the papers filed.
+If you need copies of what the government filed, please let me know. Thanks.
+492
+
+
+Read: 7/15/2008 4:36 PM
+493
+
+
+To:
+Subject:
+Tuesday, July 15, 2008 3:44 PM
+RE: In Re Jane Doe - Call from Palm Beach Daily News
+Marie,
+I have heard nothing from Edwards. My recollection is that you told him you would prepare a document for joint filing,
+once we agreed after the hearing that an evidentiary hearing was not necessary for either side.
+We were going to
+detail what occurred at the meeting between Nesbitt and Jason at Publix with i! and Edwards was going to provide
+1 perception of what she was told by Nesbitt and Jason.
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Tuesday, July 15, 2008 3:09 PM
+To: Lee, Dexter (USAFLS)
+Subject: RE: In Re Jane Doe - Call from Palm Beach Daily News
+Hi Dexter - Have you heard any more from Mr. Edwards? I don't like to keep Judge Marra waiting. He is our
+nicest judge, so I like to be as responsive as possible.
+500 S. Australian Ave, Suite 400
+From: Lee, Dexter (USAFLS)
+Sent: Tuesday, July 15, 2008 2:15 PM
+To: Valle, Alicia (USAFLS)
+Cc: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS)
+Subject: In Re Jane Doe - Call from Palm Beach Daily News
+Alicia,
+! just received a phone call from Maggie Kacoha of the Palm Beach Daily News, (561) 820-3850, asking about the Jane
+Doe case. She told me they were tied up on Friday and unable to attend the hearing before Judge Marra. She said
+she had read the Sun Sentinel article and wanted to confirm that : (1) the government argued the court had no
+jurisdiction; and (2) the district court agreed.
+I gave her your name and said someone would be calling her back. I told her that the filings had all been unsealed and
+she could access them through PACER. I did confirm that the government argued the court did not have jurisdiction,
+but said the case was not over. I declined to make any other comments.
+494
+
+
+When the hearing concluded last Friday, Judge Marra left it up to the parties to advise the court whether an evidentiary
+hearing was needed. If the answer is yes, then the court will schedule a hearing. If the answer is no, then I assume
+the court will go ahead and rule on the papers filed.
+If you need copies of what the government filed, please let me know. Thanks.
+495
+
+
+To:
+Subject:
+RE: In Re Jane Doe - Call from Palm Beach Daily News
+Hi Dexter - Have you heard any more from Mr. Edwards? I don't like to keep Judge Marra waiting. He is our
+nicest judge, so 1 like to be as responsive as possible.
+500 S. Australian Ave, Suite 400
+From: Lee, Dexter (USAFLS)
+Sent: Tuesday, July 15, 2008 2:15 PM
+To: Valle, Alicia (USAFLS)
+Cc: Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS)
+Subject: In Re Jane Doe - Call from Palm Beach Daily News
+Alicia,
+I just received a phone call from Maggie Kacoha of the Palm Beach Daily News, (561) 820-3850, asking about the Jane
+Doe case. She told me they were tied up on Friday and unable to attend the hearing before Judge Marra. She said
+she had read the Sun Sentinel article and wanted to confirm that : (1) the government argued the court had no
+jurisdiction; and (2) the district court agreed.
+I gave her your name and said someone would be calling her back. I told her that the filings had all been unsealed and
+she could access them through PACER. I did confirm that the government argued the court did not have jurisdiction,
+but said the case was not over. I declined to make any other comments.
+When the hearing concluded last Friday, Judge Marra left it up to the parties to advise the court whether an evidentiary
+hearing was needed. If the answer is yes, then the court will schedule a hearing. If the answer is no, then I assume
+the court will go ahead and rule on the papers filed.
+If you need copies of what the government filed, please let me know. Thanks.
+496
+
+
+Read: 7/15/2008 3:41 PM
+497
+
+
+To:
+Cc:
+Subject:
+Tuesday, July 15, 2008 2:15 PM
+Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Acosta, Alex (USAFLS)
+In Re Jane Doe - Call from Palm Beach Daily News
+Alicia,
+I just received a phone call from Maggie Kacoha of the Palm Beach Daily News, (561) 820-3850, asking about the Jane
+Doe case. She told me they were tied up on Friday and unable to attend the hearing before Judge Marra. She said
+she had read the Sun Sentinel article and wanted to confirm that : (1) the government argued the court had no
+jurisdiction; and (2) the district court agreed.
+I gave her your name and said someone would be calling her back. I told her that the filings had all been unsealed and
+she could access them through PACER. I did confirm that the government argued the court did not have jurisdiction,
+but said the case was not over. I declined to make any other comments.
+When the hearing concluded last Friday, Judge Marra left it up to the parties to advise the court whether an evidentiary
+hearing was needed. If the answer is yes, then the court will schedule a hearing.
+If the answer is no, then I assume
+the court will go ahead and rule on the papers filed.
+If you need copies of what the government filed, please let me know. Thanks.
+498
+
+
+To:
+Subject:
+Tuesday, July 15, 2008 1:26 PM
+Richards, Jason R. (FBI)
+Hi Jason -- Yes, that is fine, unless I am selected for jury duty, which seems
+unlikely.
+500 S. Australian Ave, Suite 400
+-----Original Message-----
+From: Richards, Jason R. (FBI)
+Sent: Tuesday, July 15, 2008 1:02 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Re: Calls
+Are you available to meet with Aris and her mom on Thur. at 3:30. Julia was very
+uncooperative with Twila today.
+----- Original Message -----
+From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov>
+To: Richards, Jason R.
+Sent: Tue Jul 15 12:00:40 2008
+Subject: Re: Calls
+Hi jason. I am out of the office right now. It is jason at south carolina
+victim's action network (www.scvan.org) and pauline mandel at maryland crime
+victims' services (www.mdcrimevictims.org)
+----- Original Message -----
+From: Richards, Jason R. (FBI)
+To: Villafana, Ann Marie C. (USAFLS)
+Sent: Tue Jul 15 11:32:17 2008
+Subject: Re: Calls
+Call me when you get a chance. Twila on hold re: notifications. Any word from
+Marra?
+499
+
+
+----- Original Message -----
+From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov>
+To: Kuyrkendall, E N.; Richards, Jason R.; Smith, Twiler V.
+Sent: Mon Jul 14 16:16:08 2008
+Subject: FW: Calls
+Hi all -- Wasn't sure this went through last time.
+On another note, do you guys have an office in Ft Pierce?
+500 S. Australian Ave, Suite 400
+-----Original Message-----
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Monday, July 14, 2008 2:14 PM
+To: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+Subject: Calls
+Hi guys. I am stuck in the rain. If you want to start calling here are my
+thoughts.
+We are calling to inform you about the resolution of the Epstein investigation
+and to thank you for your help.
+Mr Epstein pled guilty to one child sex offense that will require him to register
+as a sex offender for life and received a sentence of 18 months imprisonment
+followed by one year of home confinement. Mr Epstein also made a concession
+regarding the payment of restitution.
+All of these terms are set out in a letter that AUSA Villafana is going to send
+out. Do you have a lawyer? Get name and address. If not where do you want letter
+sent? If you have questions when you receive the letter, please understand that
+we cannot provide legal advice but the lawyers at the following victims rights
+organizations are able to help you at no cost to you. (Provide the names and
+phone numbers) Also ask about counseling and let them know that counseling is
+500
+
+
+To:
+Subject:
+Richards, Jason R. (FBI)
+Tuesday, July 15, 2008 1:02 PM
+Re: Calls
+Are you available to meet with Aris and her mom on Thur. at 3:30. Julia was very
+uncooperative with Twila today.
+----- Original Message -..-.
+From: Villafana, Ann Marie C. (USAFLS) <Ann. Marie. C.Villafana@usdoj.gov>
+To: Richards, Jason R.
+Sent: Tue Jul 15 12:00:40 2008
+Subject: Re: Calls
+Hi jason. I am out of the office right now. It is jason at south carolina
+victim's action network (www.scvan.org) and pauline mandel at maryland crime
+victims' services (www.mdcrimevictims.org)
+- Original Message
+From: Richards, Jason R. (FBI)
+To: Villafana, Ann Marie C. (USAFLS)
+Sent: Tue Jul 15 11:32:17 2008
+Subject: Re: Calls
+Call me when you get a chance. Twila on hold re: notifications. Any word from
+Marra?
+----- Original Message --.--
+From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov>
+To: Kuyrkendall, E N.; Richards, Jason R.; Smith, Twiler V.
+Sent: Mon Jul 14 16:16:08 2008
+Subject: FW: Calls
+Hi all -- Wasn't sure this went through last time.
+On another note, do you guys have an office in Ft Pierce?
+500 S. Australian Ave, Suite 400
+501
+
+
+-----Original Message-----
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Monday, July 14, 2008 2:14 PM
+To: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+Subject: Calls
+Hi guys. I am stuck in the rain. If you want to start calling here are my
+thoughts.
+We are calling to inform you about the resolution of the Epstein investigation
+and to thank you for your help.
+Mr Epstein pled guilty to one child sex offense that will require him to register
+as a sex offender for life and received a sentence of 18 months imprisonment
+followed by one year of home confinement. Mr Epstein also made a concession
+regarding the payment of restitution.
+All of these terms are set out in a letter that AUSA Villafana is going to send
+out. Do you have a lawyer? Get name and address. If not where do you want letter
+sent? If you have questions when you receive the letter, please understand that
+we cannot provide legal advice but the lawyers at the following victims rights
+organizations are able to help you at no cost to you. (Provide the names and
+phone numbers) Also ask about counseling and let them know that counseling is
+502
+
+
+To:
+Subject:
+Tuesday, July 15, 2008 12:01 PM
+Richards, Jason R. (FBI)
+Re: Calls
+Hi jason. I am out of the office right now. It is jason at south carolina
+victim's action network (www.scvan.org) and pauline mandel at maryland crime
+victims' services (www.mdcrimevictims.org)
+----- Original Message
+From: Richards, Jason R. (FBI)
+To: Villafana, Ann Marie C. (USAFLS)
+Sent: Tue Jul 15 11:32:17 2008
+Subject: Re: Calls
+Call me when you get a chance. Twila on hold re: notifications. Any word from
+Marra?
+----- Original Message
+From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov›
+To: Kuyrkendall, E N.; Richards, Jason R.; Smith, Twiler V.
+Sent: Mon Jul 14 16:16:08 2008
+Subject: FW: Calls
+Hi all -- Wasn't sure this went through last time.
+On another note, do you guys have an office in Ft Pierce?
+500 S. Australian Ave, Suite 400
+-----Original Message-..--
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Monday, July 14, 2008 2:14 PM
+To: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+Subject: Calls
+Hi guys. I am stuck in the rain. If you want to start calling here are my
+thoughts.
+503
+
+
+We are calling to inform you about the resolution of the Epstein investigation
+and to thank you for your help.
+Mr Epstein pled guilty to one child sex offense that will require him to register
+as a sex offender for life and received a sentence of 18 months imprisonment
+followed by one year of home confinement. Mr Epstein also made a concession
+regarding the payment of restitution.
+All of these terms are set out in a letter that AUSA Villafana is going to send
+out. Do you have a lawyer? Get name and address. If not where do you want letter
+sent? If you have questions when you receive the letter, please understand that
+we cannot provide legal advice but the lawyers at the following victims rights
+organizations are able to help you at no cost to you. (Provide the names and
+phone numbers) Also ask about counseling and let them know that counseling is
+504
+
+
+To:
+Subject:
+Richards, Jason R. (FBI)
+Tuesday, July 15, 2008 11:32 AM
+Re: Calls
+Call me when you get a chance. Twila on hold re: notifications. Any word from
+Marra?
+----- Original Message -----
+From: Villafana, Ann Marie C. (USAFLS) ‹Ann.Marie.C.Villafana@usdoj .gov>
+To: Kuyrkendall, E N.; Richards, Jason R.; Smith, Twiler V.
+Sent: Mon Jul 14 16:16:08 2008
+Subject: FW: Calls
+Hi all -- Wasn't sure this went through last time.
+On another note, do you guys have an office in Ft Pierce?
+A. Marie Villafana
+500 S. Australian Ave, Suite 400
+-----Original Message-----
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Monday, July 14, 2008 2:14 PM
+To: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+Subject: Calls
+Hi guys. I am stuck in the rain. If you want to start calling here are my
+thoughts.
+We are calling to inform you about the resolution of the Epstein investigation
+and to thank you for your help.
+Mr Epstein pled guilty to one child sex offense that will require him to register
+as a sex offender for life and received a sentence of 18 months imprisonment
+followed by one year of home confinement. Mr Epstein also made a concession
+regarding the payment of restitution.
+All of these terms are set out in a letter that AUSA Villafana is going to send
+out. Do you have a lawyer? Get name and address. If not where do you want letter
+sent? If you have questions when you receive the letter, please understand that
+we cannot provide legal advice but the lawyers at the following victims rights
+organizations are able to help you at no cost to you. (Provide the names and
+505
+
+
+phone numbers) Also ask about counseling and let them know that counseling is
+506
+
+
+To:
+Subject:
+Richards, Jason R. (FBI)
+Tuesday, July 15, 2008 11:12 AM
+Re: Calls
+Hi Marie, do you have the names and numbers of the pro bono attorneys available
+for the victims?
+----- Original Message -----
+From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov>
+To: Kuyrkendall, E N.; Richards, Jason R.; Smith, Twiler V.
+Sent: Mon Jul 14 16:16:08 2008
+Subject: FW: Calls
+Hi all -- Wasn't sure this went through last time.
+On another note, do you guys have an office in Ft Pierce?
+500 S. Australian Ave, Suite 400
+-----Original Message-----
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Monday, July 14, 2008
+2:14 PM
+To: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+Subject: Calls
+Hi guys. I am stuck in the rain. If you want to start calling here are my
+thoughts.
+We are calling to inform you about the resolution of the Epstein investigation
+and to thank you for your help.
+Mr Epstein pled guilty to one child sex offense that will require him to register
+as a sex offender for life and received a sentence of 18 months imprisonment
+followed by one year of home confinement. Mr Epstein also made a concession
+regarding the payment of restitution.
+All of these terms are set out in a letter that AUSA Villafana is going to send
+out. Do you have a lawyer? Get name and address. If not where do you want letter
+sent? If you have questions when you receive the letter, please understand that
+we cannot provide legal advice but the lawyers at the following victims rights
+organizations are able to help you at no cost to you. (Provide the names and
+507
+
+
+phone numbers) Also ask about counseling and let them know that counseling is
+still
+available even though the investigation is closed.
+508
+
+
+To:
+Cc:
+Subject:
+Thank you, Dexter.
+500 S. Australian Ave, Suite 400
+RE: Conversation with Mike Tein
+From: Lee, Dexter (USAFLS)
+Sent: Monday, July 14, 2008 4:53 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Conversation with Mike Tein
+Marie,
+Mike Tein called this afternoon, wanting to confirm details he had read in the newspaper. I told him that Judge Marra
+had not dismissed the victims' petition, and explained the parties were determining whether an evidentiary hearing was
+necessary. He asked if both Jane Doe No. 1 and No. 2 were present in court, and I told him yes.
+He also asked if the government's response would be available on PACER. I told him that, since the court had denied
+our motion to seal, the government's response would be unsealed and placed on the docket.
+509
+
+
+510
+Read: 7/14/2008 5:02 PM
+
+
+To:
+Subject:
+Monday, July 14, 2008 4:53 PM
+Conversation with Mike Tein
+Marie,
+Mike Tein called this afternoon, wanting to confirm details he had read in the newspaper. I told him that Judge Marra
+had not dismissed the victims' petition, and explained the parties were determining whether an evidentiary hearing was
+necessary. He asked if both Jane Doe No. 1 and No. 2 were present in court, and I told him yes.
+He also asked if the government's response would be available on PACER. I told him that, since the court had denied
+our motion to seal, the government's response would be unsealed and placed on the docket.
+511
+
+
+Subject:
+Monday, July 14, 2008 4:16 PM
+Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI); Smith, Twiler V. (FBi)
+Hi all -- Wasn't sure this went through last time.
+On another note, do you guys have an office in Ft Pierce?
+500 S. Australian Ave, Suite 400
+-----Original Message--..-
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Monday, July 14, 2008 2:14 PM
+To: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+Subject: Calls
+Hi guys. I am stuck in the rain. If you want to start calling here are my
+thoughts.
+We are calling to inform you about the resolution of the Epstein investigation
+and to thank you for your help.
+Mr Epstein pled guilty to one child sex offense that will require him to register
+as a sex offender for life and received a sentence of 18 months imprisonment
+followed by one year of home confinement. Mr Epstein also made a concession
+regarding the payment of restitution.
+All of these terms are set out in a letter that AUSA Villafana is going to send
+out. Do you have a lawyer?
+and address. If not where do you want letter
+sent? If you have questions when you receive the letter, please understand that
+we cannot provide legal advice but the lawyers at the following victims rights
+organizations are able to help you at no cost to you. (Provide the names and
+phone numbers) Also ask about counseling and let them know that counseling is
+512
+
+
+To:
+Subject:
+Monday, July 14, 2008 2:14 PM
+Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+Calls
+Ho uys, I am stuck in the rain. If you want to start calling here are my
+We are calling to inform you about the resolution of the Epstein investigation
+and to thank you for your help.
+Mr Epstein pled guilty to one child sex offense that will require him to register
+as a sex offender for life and received a sentence of 18 months imprisonment
+followed by one year of home confinement. Mr Epstein also made a concession
+regarding the payment of restitution.
+All of these terms are set out in a letter that AUSA Villafana is going to send
+out. Do you have a lawyer? Get name and address. If not where do you want letter
+sent? If you have questions when you receive the letter, please understand that
+we cannot provide legal advice but the lawyers at the following victims rights
+organizations are able to help you at no cost to you. (Provide the names and
+phone numbers) Also ask about counseling and let them know that counseling is
+513
+
+
+To:
+Cc:
+Subject:
+Monday, July 14, 2008 12:17 PM
+RE: Jane Doe Hearing
+Hi Dexter - I haven't heard any more from Jack and I haven't received any faxes, so perhaps the storm has
+passed. If you would like to call him, his phone number is 561.659.8300.
+A. Marie Villataña
+500 S. Australian Ave, Suite 400
+From: Lee, Dexter (USAFLS)
+Sent: Monday, July 14, 2008 10:20 AM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: RE: Jane Doe Hearing
+Marie,
+I left early on Friday since I had to take care of some matters before my Air Force reserve duty at Homestead AFB this
+weekend. If you want me to participate in a conference with Mr. Goldberger, I will be happy to do so.
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Friday, July 11, 2008 3:04 PM
+To: Lee, Dexter (USAFLS)
+Subject: RE: Jane Doe Hearing
+Hi Dexter - I really think you should be on this call with Jack Goldberger, if you feel a response is required.
+From: Lee, Dexter (USAFLS)
+Sent: Friday, July 11, 2008 2:33 PM
+To: Herd, Kim (USAEO); Neal, Kristina (USAEO); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Villafana, Ann Marie C. (USAFLS); Jacobus, Wendy (USAFLS)
+Subject: Jane Doe Hearing
+514
+
+
+Colleagues,
+The hearing this morning lasted 45 minutes. Judge Marra first heard argument from Brad Edwards, who harangued the
+government for permitting Epstein to get off with a light sentence in state court. He argued that the victims were
+entitled to be consulted before this agreement was reached, and the court should set the agreement aside. Edwards
+again argued that the rights in section 3771(a) accrue prior to the filing of any charges.
+In my portion of the argument, I advised the court of the status of Epstein's state case: (1) he entered pleas of guilty to
+two state charges on June 30, 2008; (2) he was sentenced to 18 months' incarceration and 1 year of community control;
+and (3) he was serving his sentence of incarceration. The court queried me on the Dean case and the government's
+position on when the rights in section 3371(a) applied. I distinguished Dean and argued that rights under 3771(a) does
+not accrue until a charge is filing in district court. I noted that the A/G's guidelines are applied with common sense,
+such that a victim claiming they were being threatened by a perpetrator would not be turned away since an indictment
+had not been returned. I also argued that 18 U.S.C. 3771 did not grant authority to the court to set aside the
+agreement in the instant case, since it was not a plea agreement filed with court, which it had the discretion to accept or
+reject.
+The court had questions regarding the completion of the agreement in September 2007, but the plea was not
+entered until June 30, 2008. 1 advised the court that Epstein's attorneys sought higher review of the agreement within
+the DOJ.
+As to the motion to seal the government's response, the court asked if that was necessary any more, since a public
+hearing had been held and much of what was filed had been discussed. I argued that the government had two bases
+for sealing: (1) protection of the privacy of the minor victims; and (2) confidentiality of negotiations with Epstein's
+attorneys and the confidentiality clause in the Agreement.
+Edwards waived any protection for his clients, two of
+whom were present in court (| and
+1) As to the confidentiality, the court found that the discussions regarding
+the potential impeachment of the victims because of the availability of relief under 18 U.S.C. 2255 had already been
+discussed at the hearing. I argued that the exact clause in the agreement pertaining to section 2255 had been cited in
+the notification letters to and
+, which were filed, and the government had agreed to notify Epstein before
+making any disclosure.
+The court stated that the disclosure was being done pursuant to its order, not by the
+government's action.
+I told the court the government wanted to register its objection.
+The court ordered the government's response, Marie's declaration, and the attachments, unsealed. Also, Edwards filed
+a reply, which is also a public record document.
+The court noted that, since Epstein had entered his plea and was sentenced, this was no longer an emergency. Both
+parties agreed. The court wanted to know if any evidentiary hearing need to be held. Since there is a dispute over
+what the FBI agents told
+in September 2007, I asked the court to permit the parties to speak to determine if there
+are any factual disputes which require a hearing. The court agreed.
+There was a reporter from the Sun Sentinel present in the audience.
+515
+
+
+Read: 7/14/2008 12:17 PM
+Read: 7/14/2008 12:48 PM
+516
+
+
+To:
+Subject:
+Monday, July 14, 2008 10:20 AM
+Villafana, Ann Marie C. (USAFLS,
+RE: Jane Doe Hearing
+Marie,
+I left early on Friday since I had to take care of some matters before my Air Force reserve duty at Homestead AFB this
+weekend. If you want me to participate in a conference with Mr. Goldberger, I will be happy to do so.
+From: Villafana, Ann Marie C. (USAFLS)
+ent: Friday, July 11, 2008 3:04 PM
+o: Le
+, Dexter (USAFLS)
+Subject: RE: Jane Doe Hearing
+Hi Dexter - I really think you should be on this call with Jack Goldberger, if you feel a response is required.
+A. Marie Villajaña
+From: Lee, Dexter (USAFLS)
+Sent: Friday, July 11, 2008 2:33 PM
+To: Herd, Kim (USAEO); Neal, Kristina (USAEO); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Villafana, Ann Marie C. (USAFLS); Jacobus, Wendy (USAFLS)
+Subject: Jane Doe Hearing
+Colleagues,
+The hearing this morning lasted 45 minutes. Judge Marra first heard argument from Brad Edwards, who harangued the
+government for permitting Epstein to get off with a light sentence in state court. He argued that the victims were
+entitled to be consulted before this agreement was reached, and the court should set the agreement aside. Edwards
+again argued that the rights in section 3771(a) accrue prior to the filing of any charges.
+In my portion of the argument, I advised the court of the status of Epstein's state case: (1) he entered pleas of guilty to
+two state charges on June 30, 2008; (2) he was sentenced to 18 months' incarceration and 1 year of community control;
+and (3) he was serving his sentence of incarceration. The court queried me on the Dean case and the government's
+position on when the rights in section 3371(a) applied. I distinguished Dean and argued that rights under 3771(a) does
+not accrue until a charge is filing in district court. I noted that the A/G's guidelines are applied with common sense,
+such that a victim claiming they were being threatened by a perpetrator would not be turned away since an indictment
+had not been returned. I also argued that 18 U.S.C. 3771 did not grant authority to the court to set aside the
+agreement in the instant case, since it was not a plea agreement filed with court, which it had the discretion to accept or
+reject. The court had questions regarding the completion of the agreement in September 2007, but the plea was not
+517
+
+
+entered until June 30, 2008. I advised the court that Epstein's attorneys sought higher review of the agreement within
+the DOJ.
+As to the motion to seal the government's response, the court asked if that was necessary any more, since a public
+hearing had been held and much of what was filed had been discussed. I argued that the government had two bases
+for sealing: (1) protection of the privacy of the minor victims; and (2) confidentiality of negotiations with Epstein's
+attorneys and the confidentiality clause in the Agreement. Edwards waived any protection for his clients, two of
+whom were present in court (C.W. and T.M.) As to the confidentiality, the court found that the discussions regarding
+the potential impeachment of the victims because of the availability of relief under 18 U.S.C. 2255 had already been
+discussed at the hearing. I argued that the exact clause in the agreement pertaining to section 2255 had been cited in
+the notification letters to. and ., which were filed, and the government had agreed to notify Epstein before
+making any disclosure. The court stated that the disclosure was being done pursuant to its order, not by the
+government's action. I told the court the government wanted to register its objection.
+The court ordered the government's response, Marie's declaration, and the attachments, unsealed. Also, Edwards filed
+a reply, which is also a public record document.
+The court noted that, since Epstein had entered his plea and was sentenced, this was no longer an emergency. Both
+parties agreed.
+The court wanted to know if any evidentiary hearing need to be held. Since there is a dispute over
+what the FBI agents told . in September 2007, 1 asked the court to permit the parties to speak to determine if there
+are any factual disputes which require a hearing.
+There was a reporter from the Sun Sentinel present in the audience.
+518
+
+
+To:
+Subject:
+RE: Jane Doe Hearing
+Hi Dexter - I really think you should be on this call with Jack Goldberger, if you feel a response is required.
+561209-1047
+From: Lee, Dexter (USAFLS)
+Sent: Friday, July 11, 2008 2:33 PM
+To: Herd, Kim (USAEO); Neal, Kristina (USAEO); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Villafana, Ann Marie C. (USAFLS); Jacobus, Wendy (USAFLS)
+Subject: Jane Doe Hearing
+Colleagues,
+The hearing this morning lasted 45 minutes. Judge Marra first heard argument from Brad Edwards, who harangued the
+government for permitting Epstein to get off with a light sentence in state court. He argued that the victims were
+entitled to be consulted before this agreement was reached, and the court should set the agreement aside. Edwards
+again argued that the rights in section 3771(a) accrue prior to the filing of any charges.
+In my portion of the argument, I advised the court of the status of Epstein's state case: (1) he entered pleas of guilty to
+two state charges on June 30, 2008; (2) he was sentenced to 18 months' incarceration and 1 year of community control;
+and (3) he was serving his sentence of incarceration. The court queried me on the Dean case and the government's
+position on when the rights in section 3371(a) applied. I distinguished Dean and argued that rights under 3771(a) does
+not accrue until a charge is filing in district court.
+I noted that the A/G's guidelines are applied with common sense,
+such that a victim claiming they were being threatened by a perpetrator would not be turned away since an indictment
+had not been returned. I also argued that 18 U.S.C. 3771 did not grant authority to the court to set aside the
+agreement in the instant case, since it was not a plea agreement filed with court, which it had the discretion to accept or
+reject. The court had questions regarding the completion of the agreement in September 2007, but the plea was not
+entered until June 30, 2008. I advised the court that Epstein's attorneys sought higher review of the agreement within
+the DOJ.
+As to the motion to seal the government's response, the court asked if that was necessary any more, since a public
+hearing had been held and much of what was filed had been discussed. I argued that the government had two bases
+for sealing: (1) protection of the privacy of the minor victims; and (2) confidentiality of negotiations with Epstein's
+attorneys and the confidentiality clause in the Agreement. Edwards waived any protection for his clients, two of
+whom were present in court (.. and | .) As to the confidentiality, the court found that the discussions regarding
+the potential impeachment of the victims because of the availability of relief under 18 U.S.C. 2255 had already been
+discussed at the hearing. I argued that the exact clause in the agreement pertaining to section 2255 had been cited in
+the notification letters to . and , which were filed, and the government had agreed to notify Epstein before
+making any disclosure.
+The court stated that the disclosure was being done pursuant to its order, not by the
+government's action. I told the court the government wanted to register its objection.
+520
+
+
+The court ordered the government's response, Marie's declaration, and the attachments, unsealed. Also, Edwards filed
+a reply, which is also a public record document.
+The court noted that, since Epstein had entered his plea and was sentenced, this was no longer an emergency. Both
+parties agreed. The court wanted to know if any evidentiary hearing need to be held. Since there is a dispute over
+what the FBI agents told | in September 2007, l asked the court to permit the parties to speak to determine if there
+are any factual disputes which require a hearing. The court agreed.
+There was a reporter from the Sun Sentinel present in the audience.
+521
+
+
+Read: 7/14/2008 8:52 AM
+522
+
+
+To:
+Friday, July 11, 2008 2:33 PM
+Herd, Kim (USAEO); Neal, Kristina (USAEO); Acosta, Alex (USAFLS); Sloman, Jeff
+(USAFLS)
+Cc:
+Subject:
+Villafana, Ann Marie C. (USAFLS); Jacobus, Wendy (USAFLS)
+Jane Doe Hearing
+Colleagues,
+The hearing this morning lasted 45 minutes.
+Judge Marra first heard argument from Brad Edwards, who harangued the
+government for permitting Epstein to get off with a light sentence in state court. He argued that the victims were
+entitled to be consulted before this agreement was reached, and the court should set the agreement aside. Edwards
+again argued that the rights in section 3771(a) accrue prior to the filing of any charges.
+In my portion of the argument, I advised the court of the status of Epstein's state case: (1) he entered pleas of guilty to
+two state charges on June 30, 2008; (2) he was sentenced to 18 months' incarceration and 1 year of community control;
+and (3) he was serving his sentence of incarceration. The court queried me on the Dean case and the government's
+position on when the rights in section 3371(a) applied. I distinguished Dean and argued that rights under 3771(a) does
+not accrue until a charge is filing in district court. I noted that the A/G's guidelines are applied with common sense,
+such that a victim claiming they were being threatened by a perpetrator would not be turned away since an indictment
+had not been returned. I also argued that 18 U.S.C. 3771 did not grant authority to the court to set aside the
+agreement in the instant case, since it was not a plea agreement filed with court, which it had the discretion to accept or
+reject. The court had questions regarding the completion of the agreement in September 2007, but the plea was not
+entered until June 30, 2008. I advised the court that Epstein's attorneys sought higher review of the agreement within
+the DOJ.
+As to the motion to seal the government's response, the court asked if that was necessary any more, since a public
+hearing had been held and much of what was filed had been discussed. I argued that the government had two bases
+for sealing: (1) protection of the privacy of the minor victims; and (2) confidentiality of negotiations with Epstein's
+attorneys and the confidentiality clause in the Agreement.
+Edwards waived any protection for his clients, two of
+whom were present in court (
+and
+As to the confidentiality, the court found that the discussions regarding
+the potential impeachment of the victims because of the availability of relief under 18 U.S.C. 2255 had already been
+discussed at the hearing.
+I argued that the exact clause in the agreement pertaining to section 2255 had been cited in
+the notification letters to
+_ and
+which were filed, and the government had agreed to notify Epstein before
+making any disclosure.
+The court stated that the disclosure was being done pursuant to its order, not by the
+government's action. I told the court the government wanted to register its objection.
+The court ordered the government's response, Marie's declaration, and the attachments, unsealed. Also, Edwards filed
+a reply, which is also a public record document.
+The court noted that, since Epstein had entered his plea and was sentenced, this was no longer an emergency. Both
+parties agreed. The court wanted to know if any evidentiary hearing need to be held. Since there is a dispute over
+what the FBI agents told _ in September 2007, I asked the court to permit the parties to speak to determine if there
+are any factual disputes which require a hearing. The court agreed.
+There was a reporter from the Sun Sentinel present in the audience.
+523
+
+
+To:
+Subject:
+fillafana, Ann Marie C. (USAFLS
+riday, July 11, 2008 2:18 PN
+Kuyrkendall, E N. (FBI)
+RE: Notice of Disclosure
+I am at 209-1021
+-----Original Message-....
+From: Kuyrkendall, E N. (FBI)
+Sent: Friday, July 11, 2008 2:17 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Re: Notice of Disclosure
+We are calling your office.
+----- Original Message -----
+From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov>
+To: Kuyrkendall, E N.; Richards, Jason
+Sent: Fri Jul 11 14:15:19 2008
+Subject: FW: Notice of Disclosure
+Are you sure you are still with me?
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Friday, July 11, 2008 1:42 PM
+To: Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS)
+Subject: FW: Notice of Disclosure
+I'm not going to call him by myself, so who wants to join me?
+524
+
+
+From: Jack Goldberger [mailto:jgoldberger@agwpa.com]
+Sent: Friday, July 11, 2008 1:18 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: RE: Notice of Disclosure
+Please call me in regard to this
+Jack goldberger
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.gov]
+Sent: Friday, July 11, 2008 12:01 PM
+To: Jack Goldberger
+Cc: Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS)
+Subject: Notice of Disclosure
+Dear Mr. Goldberger:
+Today, Dexter Lee and I appeared before Judge Marra in connection with a suit
+filed by . and . asserting that their rights as victims were breached by
+our failure to consult with them before entering into the Non-Prosecution
+Agreement.
+In response to their petition, I filed a Declaration under seal that
+included the victim notification letters provided to their attorney, Brad
+Edwards. At today's hearing, and over our objection, Judge Marra denied our
+motion to seal and unsealed the declaration.
+Accordingly, one piece of the Non-
+Prosecution Agreement, specifically the paragraph that is quoted in the victim
+notification letters,
+has been disclosed.
+525
+
+
+sent
+Subject:
+Villafana, Ann Marie C. (USAFLS
+Friday, July 11, 2008 2:15 PN
+Suyrkendali, E N. (FBI); Richards, Jason R. (FBI
+W: Notice of Disclosure
+Are you sure you are still with me?
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Friday, July 11, 2008 1:42 PM
+To: Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS)
+Subject: FW: Notice of Disclosure
+I'm not going to call him by myself, so who wants to join me?
+From: Jack Goldberger [mallto: jgoldberger@agwpa.com/
+Sent: Friday, July 11, 2008 1:18 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: RE: Notice of Disclosure
+Please call me in regard to this
+Jack goldberger
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie. C. Villafana@usdoj.gov]
+Sent: Friday, July 11, 2008 12:01 PM
+To: Jack Goldberger
+Cc: Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS)
+Subject: Notice of Disclosure
+Dear Mr. Goldberger:
+Today, Dexter Lee and I appeared before Judge Marra in connection with a suit filed by i and 1
+asserting that their rights as victims were breached by our failure to consult with them before entering into the
+Non-Prosecution Agreement. In response to their petition, I filed a Declaration under seal that included the
+victim notification letters provided to their attorney, Brad Edwards. At today's hearing, and over our objection,
+Judge Marra denied our motion to seal and unsealed the declaration. Accordingly, one piece of the Non-
+Prosecution Agreement, specifically the paragraph that is quoted in the victim notification letters, has been
+disclosed.
+526
+
+
+527
+
+
+ent
+To:
+Subject:
+Friday, July 11, 2008 1:42 PM
+Atkinson, Karen (USAFLS); Lee, Dexter (USAFLS)
+FW: Notice of Disclosure
+I'm not going to call him by myself, so who wants to join me?
+1. Marie Villafaña
+561209-1047
+From: Jack Goldberger [mailto:jgoldberger@agwpa.com]
+Sent: Friday, July 11, 2008 1:18 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: RE: Notice of Disclosure
+Please call me in regard to this
+Jack goldberger
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie. C. Villafana@usdoj.gov]
+Sent: Friday, July 11, 2008 12:01 PM
+To: Jack Goldberger
+Cc: Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS)
+Subject: Notice of Disclosure
+Dear Mr. Goldberger:
+Today, Dexter Lee and I appeared before Judge Marra in connection with a suit filed by
+. and
+asserting that their rights as victims were breached by our failure to consult with them before entering into the
+Non-Prosecution Agreement. In response to their petition, I filed a Declaration under seal that included the
+victim notification letters provided to their attorney, Brad Edwards. At today's hearing, and over our objection,
+Judge Marra denied our motion to seal and unsealed the declaration. Accordingly, one piece of the Non-
+Prosecution Agreement, specifically the paragraph that is quoted in the victim notification letters, has been
+disclosed.
+528
+
+
+529
+Read: 7/11/2008 2:55 PM
+Read: 7/11/2008 2:05 PM
+
+
+To:
+Subject:
+Kuyrkendall, E N. (FBI)
+Friday, July 11, 2008 12:25 PM
+Re: Notice of Disclosure
+No, but I'll be sure to look in tomorrows Sun Sent for the much deserve praise
+for our hard work. Hey for the record we can't break up the team now so we will
+be here for any tar and feathering:)
+----- Original Message -----
+From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov>
+To: Kuyrkendall, E N.
+Sent: Fri Jul 11 12:17:02 2008
+Subject: RE: Notice of Disclosure
+No, thanks, I want to spend the next year investigating Matt and Lilly. Did
+Jason show you the press release that I found?
+500 S. Australian Ave, Suite 400
+-----Original Message-----
+From: Kuyrkendall, E N. (FBI)
+Sent: Friday, July 11, 2008 12:03 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Re:
+Notice of Disclosure
+All Jason and I can say is unbelievable. This is going to be a big mess. Jason
+and I r taking the next year off want to join us in Cabo?
+----- Original Message -----
+From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov>
+To: Jack Goldberger <jgoldberger@agwpa.com>
+Cc: Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS)
+Sent: Fri Jul 11 11:55:14 2008
+Subject: Notice of Disclosure
+Dear Mr. Goldberger:
+Today, Dexter Lee and I appeared before Judge Marra in connection with a suit
+filed by
+• and
+1. asserting that their rights as victims were breached by
+our failure to consult with them before entering into the Non-Prosecution
+Agreement. In response to their petition, I filed a Declaration under seal that
+531
+
+
+included the victim notification letters provided to their attorney, Brad
+Edwards. At today's hearing, and over our objection, Judge Marra denied our
+motion to seal and unsealed the declaration.
+Accordingly, one piece of the Non-
+Prosecution Agreement, specifically the paragraph that is quoted in the victim
+notification letters, has been disclosed.
+532
+
+
+sent:
+Subject:
+Friday, July 11, 2008 12:17 PM
+Kuyrkendall, E N. (FBI)
+RE: Notice of Disclosure
+No, thanks, I want to spend the next year investigating Matt and Lilly. Did
+Jason show you the press release that I found?
+500 S. Australian Ave, Suite 400
+-----Original Message-----
+From: Kuyrkendall, E N. (FBI)
+Sent: Friday, July 11, 2008 12:03 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Re: Notice of Disclosure
+All Jason and I can say is unbelievable. This is going to be a big mess. Jason
+and I r taking the next year off want to join us in Cabo?
+Original Message
+From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov>
+To: Jack Goldberger <jgoldberger@agwpa.com>
+Cc: Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS)
+Sent: Fri Jul 11 11:55:14 2008
+Subject: Notice of Disclosure
+Dear Mr. Goldberger:
+Agreement. In response to their petition, I filed a Declaration under seal that
+included the victim notification letters provided to their attorney, Brad
+Edwards. At today's hearing, and over our objection, Judge Marra denied our
+motion to seal and unsealed the declaration. Accordingly, one piece of the Non-
+Prosecution Agreement, specifically the paragraph that is quoted in the victim
+notification letters, has been disclosed.
+A. Marie Villafana
+533
+
+
+561
+209-1047
+534
+
+
+To:
+Subject:
+Sloman, Jeff (USAFLS
+Friday, July 11, 2008 11:58 AN
+RE: Notice of Disclosure
+Marie,
+I have another question about today's hearing. Please call me at my desk. Thanks,
+Jeff
+305-961-9299
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Friday, July 11, 2008 11:55 AM
+To: Jack Goldberger
+Cc: Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS)
+Subject: Notice of Disclosure
+Dear Mr. Goldberger:
+Today, Dexter Lee and I appeared before Judge Marra in connection with a suit filed by i
+asserting that
+their rights as victims were breached by our failure to consult with them before entering into the Non-Prosecution
+Agreement. In response to their petition, I filed a Declaration under seal that included the victim notification letters
+provided to their attorney, Brad Edwards. At today's hearing, and over our objection, Judge Marra denied our motion to
+seal and unsealed the declaration. Accordingly, one piece of the Non-Prosecution Agreement, specifically the paragraph
+that is quoted in the victim notification letters, has been disclosed.
+535
+
+
+'Jack Goldberger'
+Lee. Dexter (USAFLS)
+Kuyrkendall, E N. (FBI)
+Richards, Jason R. (FBI)
+Read: 7/11/2008 2:05 PM
+Read: 7/11/2008 11:58 AM
+Read: 7/11/2008 11:56 AM
+537
+
+
+To:
+Cc:
+Subject:
+Friday, July 11, 2008 11:55 AM
+'Jack Goldberger
+Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS)
+Notice of Disclosure
+Dear Mr. Goldberger:
+Today, Dexter Lee and I appeared before Judge Marra in connection with a suit filed byl
+. asserting that
+their rights as victims were breached by our failure to consult with them before entering into the Non-Prosecution
+Agreement. In response to their petition, 1 filed a Declaration under seal that included the victim notification letters
+provided to their attorney, Brad Edwards. At today's hearing, and over our objection, Judge Marra denied our motion to
+seal and unsealed the declaration. Accordingly, one piece of the Non-Prosecution Agreement, specifically the paragraph
+that is quoted in the vietim notification letters, has been disclosed.
+538
+
+
+'Jack Goldberger
+Kuyrkendall, E N. (FBI)
+Richards, Jason R. (FBI)
+Read: 7/11/20082:05 PM
+Read: 7/11/2008 11:56 AM
+539
+
+
+To:
+Subject:
+Importance:
+Friday, July 11, 2008 11:25 AM
+Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS
+Just got back from Epstein hearing
+High
+We need to talk. Dexter, Karen and 1 are at 561 209-1021
+540
+
+
+Read: 7/11/2008 11:51 AM
+541
+
+
+To:
+Subject:
+Kuyrkendall, E N. (FBI)
+Thursday, July 10, 2008 5:34 PM
+Re: Proposed response to Goldberger's letter
+Looks great! He will try to push u for more but I agree with your stance to
+provide him with only the info we have agreed to in the NPAgreemt (no more no
+less) as our position is not to be involved in the civil process. Hey and thanks
+for understdng the position of notification(Jason and I had some extentive debate
+on the matter). See u tomorrow.
+----- Original Message -----
+From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov>
+To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS)
+Cc: Kuyrkendall, E N.; Richards,
+Jason R.
+Sent: Thu Jul 10 17:12:26 2008
+Subject: Proposed response to Goldberger's letter
+‹<080710 Response to Goldberger Itr re notification. wpd›> Please let me know if
+this is alright to fax out today. I can see no reason for us to disclose any of
+the additional information that they have requested.
+The message is ready to be sent with the following file or link
+attachments:
+080710 Response to Goldberger Itr re notification. wpd
+Note: To protect against computer viruses, e-mail programs may prevent sending or
+receiving certain types of file attachments. Check your e-mail security settings
+542
+
+
+To:
+Cc:
+Subject:
+Thursday, July 10, 2008 5:15 PM
+Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Atkinson, Karen (USAFLS)
+cuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+Re: Proposed response to Goldberger's letter
+Fine
+----- Original Message
+From: Villafana,
+Ann Marie C. (USAFLS)
+To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS)
+Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+Sent: Thu Jul 10 17:12:26 2008
+Subject: Proposed response to Goldberger's letter
+Please let me know if this is alright to fax out today. I can see no reason for
+us to disclose any of the additional information that they have requested.
+The message is ready to be sent with the following file or link attachments:
+080710 Response to Goldberger Itr re notification.wpd
+Note: To protect against computer viruses, e-mail programs may prevent sending or
+receiving certain types of file attachments.
+543
+
+
+To:
+Cc:
+Subject:
+Attachments:
+Please let me know if this is alright to fax out today. I can see no reason for
+us to disclose any of the additional information that they have requested.
+The message is ready to be sent with the following file or link attachments:
+080710 Response to Goldberger Itr re notification.wpd
+Note: To protect against computer viruses, e-mail programs may prevent sending or
+receiving certain types of file attachments.
+544
+
+
+To:
+Cc:
+Subject:
+Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS)
+Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+080710 Goldberger Ltr to A Marie C Villafana Esquire.pdf
+Hi all -- This letter just arrived from Jack Goldberger. I will prepare a response.
+
+berger Ltr to A t
+Here is the final victim list that is going out to Goldberger via certified mail this afternoon.
+080710 Final
+Victim List for G..
+P.S. This is the final version of the letter that I sent to Jack yesterday:
+080709 Ltr to
+ioldberger re No.
+545
+
+
+To:
+Subject:
+Thursday, July 10, 2008 9:47 AN
+KE Hearing on Jane Doe Petition
+Yes please. We should try to get as many notifications out as possible today. I
+am preparing a 1og.
+-----Original Message-----
+From: Kuyrkendall, E N. (FBI)
+Sent: Thursday, July 10, 2008 9:36 AM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Re: Hearing on Jane Doe Petition
+Do u still want us to come over this morning.
+----- Original Message -----
+From: Villafana, Ann Marie C. (USAFLS) <Ann.Marie.C.Villafana@usdoj.gov>
+To: Lee, Dexter (USAFLS)
+Cc: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Richards, Jason R.;
+Kuyrkendall, E N.
+Sent: Thu Jul 10 09:26:40 2008
+Subject: Hearing on Jane Doe Petition
+Hi Dexter:
+I just received a message from Judge Marra's CRD. He would like to set a hearing
+for 10:15 tomorrow. Are you available?
+A. Marie Villafana
+547
+
+
+To:
+Subject:
+Thursday, July 10, 2008 9:34 AM
+illafana, Ann Marie C. (USAFLE
+E: Hearing on Jane Doe Petitio
+Marie,
+Can you call me at (305) 961-9320? | tried your number but I think you are working in another office. Thanks.
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Thursday, July 10, 2008 9:32 AM
+To: Lee, Dexter (USAFLS)
+Subject: RE: Hearing on Jane Doe Petition
+Thanks, Dexter. I will ask both Nesbitt and Jason to attend. What documents should I bring with me? And how much
+information is the office willing to share with the ludge if he asks, what I think will be the big question, namely:
+If this deal was signed in September, why didn't the victims receive notification until yesterday?
+From: Lee, Dexter (USAFLS)
+Sent: Thursday, July 10, 2008 9:28 AM
+To: Villafana, Ann Marie C. (USAFLS)
+Cc: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Richards, Jason R. (FBI); Kuyrkendall, E N. (FBI)
+Subject: RE: Hearing on Jane Doe Petition
+Marie,
+I received the same call. I'll be there.
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Thursday, July 10, 2008 9:27 AM
+To: Lee, Dexter (USAFLS)
+Cc: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Richards, Jason R. (FBI); Kuyrkendall, E N. (FBI)
+Subject: Hearing on Jane Doe Petition
+Importance: High
+Hi Dexter:
+548
+
+
+I just received a message from Judge Marra's CRD. He would like to set a hearing for 10:15 tomorrow. Are you
+available?
+549
+
+
+To:
+Subject:
+Thursday, July 10, 2008 9:32 AM
+RE: Hearing on Jane Doe Petition
+Thanks. Dexter. I will ask both Nesbitt and Jason to attend. What documents should I bring with me? And how much
+information is the office willing to share with the Judge if he asks, what I think will be the big question. namely:
+If this deal was signed in September, why didn't the victims receive notification until yesterday?
+A. Marie Villataña
+From: Lee, Dexter (USAFLS)
+Sent: Thursday, July 10, 2008 9:28 AM
+To: Villafana, Ann Marie C. (USAFLS)
+Cc: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Richards, Jason R. (FBI); Kuyrkendall, E N. (FBI)
+Subject: RE: Hearing on Jane Doe Petition
+Marie,
+I received the same call. I'li be there.
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Thursday, July 10, 2008 9:27 AM
+To: Lee, Dexter (USAFLS)
+Cc: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Richards, Jason R. (FBI); Kuyrkendall, E N. (FBI)
+Subject: Hearing on Jane Doe Petition
+Importance: High
+Hi Dexter:
+available?
+I just received a message from Judge Marra's CRD. He would like to set a hearing for 10:15 tomorrow. Are you
+A. Marie Villajaña
+550
+
+
+551
+Read: 7/10/2008 9:32 AM
+
+
+To:
+Thursday, July 10, 2008 9:28 AM
+Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS); Villafana, Ann
+Marie C. (USAFLS)
+Cc:
+Subject:
+Herd, Kim (USAEO); Neal, Kristina (USAEO)
+In Re Jane Doe - Hearing on July 11, 2008 at 10:15 a.m.
+Alex,
+I just received a call from Judge Marra's Chambers. He has scheduled a hearing on the victim's petition for Friday, July
+11, 2008, at 10:15 a.m.
+. Can we have the FBI case agent present at the hearing?
+552
+
+
+Thursday, July 10, 2008 9:27 AM
+Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Richards, Jason R. (FBI); Kuyrkendall, E N
+(FBI)
+Hearing on Jane Doe Petition
+High
+Subject:
+Importance:
+Hi Dexter:
+I just received a message from Judge Marra's CRD. He would like to set a hearing for 10:15 tomorrow. Are you
+available?
+553
+
+
+Richards, Jason R. (FBI)
+Kuyrkendall, E N. (FBI)
+Read: 7/10/2008 9:28 AM
+Read: 7/10/2008 9:46 AM
+Read: 7/10/2008 9:33 AM
+554
+
+
+To:
+Subject:
+Wednesday, July 09, 2008 9:21 PM
+Re: Conversation with Chambers
+Hi dexter. I don't know what happened. I left at 4:00 and everything had already
+gone to the courthouse. Our clerk's office is the worst so I should have sent a
+courtesy copy directly to Judge Marra. I am sorry for the trouble.
+----- Original Message -•*--
+From: Lee, Dexter (USAFLS)
+To: Villafana, Ann Marie C. (USAFLS)
+Sent: Wed Jul 09 18:02:00 2008
+Subject: Conversation with Chambers
+Marie,
+I really appreciate you faxing a copy of what we filed to me.
+At 4:45 p.m., I
+e-filed my entry of appearance.
+At approximately 5:15, I received a call from
+Robert Glass, Judge Marra's law clerk.
+He told me the Judge had received my
+notice of appearance, but was wondering what happened to the government's
+At that point, I told him that we had earlier hand-filed a motion
+to seal, the government's response, and your declaration.
+He told me he would
+go down to the Clerk's Office and retrieve it.
+At 5:25, Mr. Glass called again to tell me everyone at the Clerk's Office had
+gone home.
+Judge Marra was anxious to get the government's response, given
+the time constraints.
+I just completed faxing everything to Chambers.
+It never ceases to amaze me how one small glitch can render meaningless all the
+work done on a project.
+556
+
+
+To:
+Subject:
+Wednesday, July 09, 2008 6:02 PM
+Conversation with Chambers
+Marie,
+I really appreciate you faxing a copy of what we filed to me. At 4:45 p.m., I e-filed my entry of appearance. At
+approximately 5:15, I received a call from Robert Glass, Judge Marra's law clerk. He told me the Judge had received
+my notice of appearance, but was wondering what happened to the government's response. At that point, I told him
+that we had earlier hand-filed a motion to seal, the government's response, and your declaration. He told me he would
+go down to the Clerk's Office and retrieve it.
+At 5:25, Mr. Glass called again to tell me everyone at the Clerk's Office had gone home. Judge Marra was anxious to
+get the government's response, given the time constraints.
+I just completed faxing everything to Chambers.
+It never ceases to amaze me how one small glitch can render meaningless all the work done on a project.
+557
+
+
+To:
+Subject:
+Wednesday, July 09, 2008 3:52 PM
+RE: Government's Motion to Seal
+Everything is out. Copies will be sent to you via inter-office. Thank you, Dexter, as usual, you came to the rescue!
+Can I ask one more favor? Will you e-file a notice of' appearance? That way notices of hearings will come to both of us.
+I have to run to an appointment, but you can get me on the cell phone.
+Thanks.
+561209-1047
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 2:13 PM
+To: Villafana, Ann Marie C. (USAFLS)|
+Subject: RE: Government's Motion to Seal
+Marie,
+To Lay DoC US 5, 2062052
+Subject: RE: Government's Motion to Seal
+Yes, both the response, your declaration, and the attachments to your declaration, are to be sealed.
+Hi Dexter - You want to seal my declaration as well, right? Please let me know and I will change accordingly.
+Thanks.
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 1:47 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Government's Motion to Seal
+560
+
+
+Marie,
+In preparation for this afternoon's filing, I have prepared a motion to seal, which is attached. I did not include
+Epstein's name and made general assertions regarding the confidentiality of the negotiations. Please have someone
+sign both the motion to seal, and the government's response, for me. We then need to prepare a sealed document
+tracking sheet, to accompany the motion.
+An original and one copy of the sealed document should be placed in two separate envelopes, with the case number
+written on the outside. An original and one copy of the motion to seal should be filed with the Clerk.
+Thanks.
+« File: victim_Mot_seal.wpd >>
+561
+
+
+562
+Read: 7/9/2008 3:54 PM
+
+
+To:
+Subject:
+Kuyrkendall, E N. (FBI)
+Wednesday, July 09, 2008 3:41 PM
+RE: Emailing: Final Victim Notification -
+Looks good except for upper lefthand corner of 2nd page "Page 2 of 4". Is that
+correct? Other than that it looks fine.
+Re the Declaration : Hopefully u r referring to the three clients/victims of Mr.
+Edwards when you state that "
+•..notice of which was provided to the victims on
+July 09, 2008, is …..."
+(We have not notified all victims on this date)
+Hey everything else looks great!!!!!!!!!!!! See you in the morning let us know a
+time to be at your office.
+We will talk about notification process then.
+Jason and Nesbitt
+From: Villafana, Ann Marie C. (USAFLS) [Ann.Marie.C.Villafana@usdoj.gov]
+Sent: Wednesday, July 09, 2008 3:18 PM
+To: Richards, Jason R.; Kuyrkendall, E N.
+Subject: FW: Emailing: Final Victim Notification --
+‹Final Victim Notification --
+earlier. Does it look alright?
+> Hi guys -- I sent this
+-----Original Message-----
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Wednesday, July 09, 2008 1:24 PM
+To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson,
+Karen (USAFLS)
+Cc: Richards, Jason R. (FBI); Kuyrkendall, E N. (FBI)
+Subject: Emailing: Final Victim Notification
+Attached please find my proposed final victim notification letter. This is
+addressed to Edwards' client,
+1. (Please note that all of the
+victims but one is now an adult and all of Mr. Edwards' clients are adults.)
+Please let me know if you would like any changes made. Also, Dexter, please let
+me know when it is safe to send to Mr. Edwards. The letter for ||. will be
+identical.
+The message is ready to be sent with the following file or link attachments:
+563
+
+
+Final Victim Notification --
+Note: To protect against computer viruses, e-mail programs may prevent sending or
+receiving certain types of file attachments.
+564
+
+
+Tubject:
+Wednesday, July 09, 2008 3:24 PM
+RE: Revised Draft with DOJ Edits
+1 added 18 usc 3509(d)(2). It says we don't even need to file a motion, but better safe than sorry.
+A. Marie Villatana
+561209-1047
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 3:10 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: RE: Revised Draft with DOJ Edits
+Marie,
+Yes, we are ready to file. As far as statutory authority, we can cite the Privacy Act, 5 U.S.C. 552a, et. Seq. Also, are
+there any special victim-witness provisions regarding restrictions on disclosure of victims' names and personal
+identifying information?
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Wednesday, July 09, 2008 3:06 PM
+To: Lee, Dexter (USAFLS)
+Subject: RE: Revised Draft with DOJ Edits
+i Dexter - Does this mean your response is good to go? On the sealed document tracking form, is there a particular
+statute or rule that you think gives us the right to file under seal? Thank you
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 3:04 PM
+To: Herd, Kim (USAEO); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Jacobus, Wendy (USAFLS); Rothenberg, Laurence E (SMO); Wood, Seth M (SMO); Neal, Kristina (USAEO); Manning,
+Katharine (USAEO)
+Subject: RE: Revised Draft with DOJ Edits
+Kim,
+565
+
+
+Thanks to you, Kristina and Katherine for all your help. We'll let you know what happens.
+From: Herd, Kim (USAEO)
+Sent: Wednesday, July 09, 2008 3:02 PM
+To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Jacobus, Wendy (USAFLS); Rothenberg, Laurence E (SMO); Wood, Seth M (SMO); Neal, Kristina (USAEO); Manning,
+Katharine (USAEO)
+Subject: RE: Revised Draft with DOJ Edits
+All -
+We have checked with OLP and they have cleared the language in your latest revision (per your e-mail below).
+Please let us know if you have additional questions.
+Thank you for your patience on this -
+Kim
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 2:26 PM
+To: Herd, Kim (USAEO); Neal, Kristina (USAEO); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff
+(USAFLS)
+Cc: Jacobus, Wendy (USAFLS)
+Subject: Revised Draft with DOJ Edits
+Colleagues,
+Attached please find the latest revision, which includes the edits suggested by EOUSA. I have also incorporated the
+word "place", per Jeff's suggestion. For our DOJ colleagues, there is a new Section III, which goes into detail regarding
+the contact Marie had with the three victims.
+Also, as to whether Edwards raises the right to fairness being violated, I was referring to paragraph five of the
+emergency petition, which only alleges violations of the right to consultation, notice of public court proceedings,
+information regarding right to restitution, and notice of rights under the CVRA.
+A motion to seal has been prepared, seeking leave of the Court to seal the government's response, Marie's declaration,
+and the attachments to the declaration.
+« File: victim_resp_USArev corrected_DOJedits.wpd »>
+566
+
+
+567
+Read: 7/9/2008 3:24 PM
+
+
+Viliafana, Ann Marie C. (USAFLS)
+Wednesday, July 09, 2008 3:19 PM
+Richards, Jason R. (FBI); Kuyrkendall, E N. (FBI)
+Subject:
+Attachments:
+FW: Emailing: Final Victim Notification -- (
+Final Victim Notification -- (
+Hi guys -- I sent this earlier. Does it look alright?
+-----Original Message-----
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Wednesday, July 09, 2008 1:24 PM
+To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson,
+Karen (USAFLS)
+Cc: Richards, Jason R. (FBI); Kuyrkendal1, E N. (FBI)
+Subject: Emailing: Final Victim Notification
+Attached please find my proposed final victim notification letter. This is
+addressed to Edwards' client,
+(Please note that all of the
+victims but one is now an adult and all
+of Mr. Edwards' clients are adults.)
+Please let me know if you would like any changes made. Also, Dexter, please let
+me know when it is safe to send to Mr. Edwards, The letter for n
+7. will be
+identical.
+The message is ready to be sent with the following file or link attachments:
+Final Victim Notification --
+Note: To protect against computer viruses, e-mail programs may prevent sending or
+receiving certain types of file attachments.
+568
+
+
+To:
+Cc:
+Subject:
+Wednesday. July 09, 2008 3:13 PM
+Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS)
+Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+Proposed Response to Jack Goldberger
+When you have a chance, please review. I don't think this has to go out today. I will not be sending Jack the "cc's" of the
+notification letters until they have all been sent.
+
+Iberger It re not
+569
+
+
+Kuyrkendall, E N. (FBI)
+Richards, Jason R. (FBI)
+Read: 7/10/2008 9:47 AM
+Read: 7/10/2008 11:16 AM
+570
+
+
+To:
+Subject:
+Wednesday, July 09, 2008 3:10 PM
+RE: Revised Draft with DOJ Edits
+Marie,
+Yes, we are ready to file. As far as statutory authority, we can cite the Privacy Act, 5 U.S.C. 552a, et. Seq. Also, are
+there any special victim-witness provisions regarding restrictions on disclosure of victims' names and personal
+From: Villafana, Ann Marle C. (USAFLS)
+Sent: Wednesday, July 09, 2008 3:06 PM
+To: Lee, Dexter (USAFLS)
+Subject: RE: Revised Draft with DOJ Edits
+Hi Dexter - Does this mean your response is good to go? On the sealed document tracking form, is there a particular
+statute or rule that you think gives us the right to file under seal? Thank you.
+A. Marie Villufaña
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 3:04 PM
+To: Herd, Kim (USAEO); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Jacobus, Wendy (USAFLS); Rothenberg, Laurence E (SMO); Wood, Seth M (SMO); Neal, Kristina (USAEO); Manning,
+Katharine (USAEO)
+Subject: RE: Revised Draft with DOJ Edits
+Thanks to you, Kristina and Katherine for all your help. We'll let you know what happens.
+Kim,
+From: Herd, Kim (USAEO)
+To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Jacobus, Wendy (USAFLS); Rothenberg, Laurence E (SMO); Wood, Seth M (SMO); Neal, Kristina (USAEO); Manning,
+Subject: RE: Revised Draft with DOJ Edits
+571
+
+
+All -
+We have checked with OLP and they have cleared the language in your latest revision (per your e-mail below).
+Please let us know if you have additional questions.
+Thank you for your patience on this -
+Kim
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 2:26 PM
+To: Herd, Kim (USAEO); Neal, Kristina (USAEO); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff
+(USAFLS)
+Cc: Jacobus, Wendy (USAFLS)
+Subject: Revised Draft with DOJ Edits
+Colleagues,
+Attached please find the latest revision, which includes the edits suggested by EOUSA. I have also incorporated the
+word "place", per Jeff's suggestion. For our DOJ colleagues, there is a new Section III, which goes into detail regarding
+the contact Marie had with the three victims.
+Also, as to whether Edwards raises the right to fairness being violated, I was referring to paragraph five of the
+emergency petition, which only alleges violations of the right to consultation, notice of public court proceedings,
+information regarding right to restitution, and notice of rights under the CVRA.
+A motion to seal has been prepared, seeking leave of the Court to seal the government's response, Marie's declaration,
+and the attachments to the declaration.
+« File: victim_resp_USArev corrected_DOJedits. wpd»>
+572
+
+
+To:
+Cc:
+Subject:
+Wednesday, July 09, 2008 3:07 PM
+Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Victim Notification Letter
+Importance:
+High
+Hi all - We need to get everything ready to go to court by 4:00. It looks like the response and my declaration are ready to
+go, but I need to send the notification letters to Edwards before everything can be filed. Can you please review and give
+me your comments? Thank you.
+Final Victim
+Votification -- C...
+573
+
+
+Sioman, Jeff (USAFLS)
+574
+Read: 7/10/2008 10:35 AM
+Read: 7/9/2008 3:10 PM
+
+
+To:
+Subject:
+Wednesday, July 09, 2008 3:06 PM
+RE: Revised Draft with DOJ Edits
+Hi Dexter — Does this mean your response is good to go? On the sealed document tracking form, is there a particular
+statute or rule that you think gives us the right to file under seal? Thank you.
+A. Marie Villațaña
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 3:04 PM
+To: Herd, Kim (USAEO); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Jacobus, Wendy (USAFLS); Rothenberg, Laurence E (SMO); Wood, Seth M (SMO); Neal, Kristina (USAEO); Manning,
+Katharine (USAEO)
+Subject: RE: Revised Draft with DOJ Edits
+Kim,
+Thanks to you, Kristina and Katherine for all your help. We'll let you know what happens.
+From: Herd, Kim (USAEO)
+Sent: Wednesday, July 09, 2008 3:02 PM
+To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Jacobus, Wendy (USAFLS); Rothenberg, Laurence E (SMO); Wood, Seth M (SMO); Neal, Kristina (USAEO); Manning,
+Katharine (USAEO)
+Subject: RE: Revised Draft with DOJ Edits
+All -
+We have checked with OLP and they have cleared the language in your latest revision (per your e-mail below).
+Please let us know if you have additional questions.
+Thank you for your patience on this -
+Kim
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 2:26 PM
+To: Herd, Kim (USAEO); Neal, Kristina (USAEO); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff
+(USAFLS)
+575
+
+
+Cc: Jacobus, Wendy (USAFLS)
+Subject: Revised Draft with DOJ Edits
+Colleagues,
+Attached please find the latest revision, which includes the edits suggested by EOUSA. I have also incorporated the
+word "place", per Jeff's suggestion. For our DOJ colleagues, there is a new Section III, which goes into detail regarding
+the contact Marie had with the three victims.
+Also, as to whether Edwards raises the right to fairness being violated, I was referring to paragraph five of the
+emergency petition, which only alleges violations of the right to consultation, notice of public court proceedings,
+information regarding right to restitution, and notice of rights under the CVRA.
+A motion to seal has been prepared, seeking leave of the Court to seal the government's response, Marie's declaration,
+and the attachments to the declaration.
+«< File: victim_resp_USArev corrected.
+_DOJedits.wpd >>
+576
+
+
+577
+Read: 7/9/2008 3:06 PM
+
+
+To:
+Cc:
+Subject:
+Vednesday, July 09, 2008 3:04 PN
+erd, Kim (USAEO); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Slomar
+Jeff (USAFLS)
+Jacobus, Wendy (USAFLS); Rothenberg, Laurence E (SMO); Wood, Seth M (SMO); Neal,
+Kristina (USAEO); Manning, Katharine (USAEO)
+RE: Revised Draft with DOJ Edits
+Kim,
+Thanks to you, Kristina and Katherine for all your help. We'll let you know what happens.
+From: Herd, Kim (USAEO)
+Sent: Wednesday, July 09, 2008 3:02 PM
+To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Jacobus, Wendy (USAFLS); Rothenberg, Laurence E (SMO); Wood, Seth M (SMO); Neal, Kristina (USAEO); Manning,
+Katharine (USAEO)
+Subject: RE: Revised Draft with DOJ Edits
+All -
+We have checked with OLP and they have cleared the language in your latest revision (per your e-mail below).
+Please let us know if you have additional questions.
+Thank you for your patience on this -
+Kim
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 2:26 PM
+To: Herd, Kim (USAEO); Neal, Kristina (USAEO); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff
+Cc: Jacobus, Wendy (USAFLS)
+Subject: Revised Draft with DOJ Edits
+Colleagues,
+Attached please find the latest revision, which includes the edits suggested by EOUSA. I have also incorporated the
+word "place", per Jeff's suggestion. For our DOJ colleagues, there is a new Section III, which goes into detail regarding
+the contact Marie had with the three victims.
+Also, as to whether Edwards raises the right to fairness being violated, 1 was referring to paragraph five of the
+emergency petition, which only alleges violations of the right to consultation, notice of public court proceedings,
+information regarding right to restitution, and notice of rights under the CVRA.
+578
+
+
+A motion to seal has been prepared, seeking leave of the Court to seal the government's response, Marie's declaration,
+and the attachments to the declaration.
+«< File: victim_resp_USArev corrected_DOJedits.wpd >>
+579
+
+
+To:
+Subject:
+Wednesday, July 09, 2008 2:52 PM
+RE: Latest Version
+Do you anticipate any more changes?
+A. Marie Villataña
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 2:48 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Latest Version
+Marie,
+We're getting close to game time. Here is my corrected version, which takes out deferred prosecution.
+this version as the one you will be filing. Make the latest changes to this document. Thanks.
+«< File: victim_resp_USArev corrected_DOJedits(1445).wpd >>
+580
+
+
+581
+Read: 7/9/2008 3:00 PM
+
+
+To:
+Subiect:
+Wednesday, July 09, 2008 2:48 PM
+Latest Version
+Marie,
+We're getting close to game time. Here is my corrected version, which takes out deferred prosecution.
+this version as the one you will be filing. Make the latest changes to this document.
+• Thanks.
+Please use
+ev corrected_D..
+582
+
+
+To:
+Subject:
+Attachments:
+Wednesday, July 09, 2008 2:46 PM
+Kuyrkendall, E N. (FBI)
+RE: Declaration Looks Great!!!!!!!
+Villafana Declaration-v2 final.wpd
+Thanks. Here it is with your changes. Can you read through once more. Thank you!
+.1. Marie Villafaña
+From: Kuyrkendall, E N. (FBI)
+Sent: Wednesday, July 09, 2008 2:44 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Declaration Looks Great!!!!!!!!!!!
+Jason and I have finished and it looks great!!!!!!!!!!!!!
+583
+
+
+To:
+Subject:
+Attachments:
+Wednesday, July 09, 2008 2:42 PM
+Lee, Dexter (USAFLS); Acosta, Alex (USAFLS)
+Emailing: victim_resp_USArev corrected_DOJedits.wpd
+victim_resp_USArev corrected_DOJedits.wpd
+Alex and Dexter -- I caught a couple of typos and made one substantive change.
+Nesbitt says she can't remember whether she handed i
+I letter to her or if
+made the change that Alex wanted on page 3, but please take a look.
+Thanks.
+The message is ready to be sent with the following file or link attachments:
+victim_resp_USArev corrected_DOJedits. wpd
+Note: To protect against computer viruses, e-mail programs may prevent sending or
+receiving certain types of file attachments.
+584
+
+
+Read: 7/9/2008 2:45 PM
+585
+
+
+To:
+Subject:
+Kuyrkendall, E N. (FBI)
+Wednesday, July 09, 2008 2:38 PM
+RE: Emailing: Villafana Declaration-v2 final. wpd
+Marie,
+Paragraph 7: Should be changed to something similar to this:
+•....opening hostile to the prosecution of Epstein. The FBI attempted to
+interview I. in October 2007, at which time she refused to provide any
+information regarding Jeffrey Epstein......
+(302 of refusal Oct 2, 2007)
+Paragraph 8:
+.....agreement was signed, four victims were contacted and these
+provision......•
+(we spoke to all four of them in person)
+Still reading .....but looks good thus far
+From: Villafana, Ann Marie C. (USAFLS) [Ann.Marie.C.Villafana@usdoj.gov]
+Sent: Wednesday, July 09, 2008 2:17 PM
+To: Kuyrkendall, E N.; Richards, Jason R.
+Subject: Emailing: Villafana Declaration-v2 final. wpd
+‹Villafana Declaration-v2 final. wpd»> Sorry if I seem cranky, I am just getting
+changes from 12 people at once.
+The message is ready to be sent with the following file or link
+attachments:
+Villafana Declaration-v2 final. wpd
+Note: To protect against computer viruses, e-mail programs may prevent sending or
+receiving certain types of file attachments.
+586
+
+
+To:
+Wednesday, July 09, 2008 2:37 PM
+Lee, Dexter (USAFLS); Herd, Kim (USAEO); Neal, Kristina (USAEO); Villafana, Ann Marie C.
+(USAFLS); Sloman, Jeff (USAFLS)
+Cc:
+Subject:
+Jacobus, Wendy (USAFLS)
+RE: Revised Draft with DOJ Edits
+I am just reading this.
+I am very concerned, because I have repeatedly edited the phrase "deferred prosecution" and replaced it with an
+"agreement to defer federal prosecution in favor of prosecution by the State of Florida." The phrase is now back on
+I send the email only to make clear that there is a difference. This is not a deferred federal prosecution. There was a
+state case, that case was prosecuted, and in light of state guilty plea federal government has agreed not to pursue a
+state prosecution as well. This matters, because the victims have the opportunity to have their rights vindicated in state
+court as well.
+Not a big deal, but just want to make sure the distinction remains clear in any subsequent drafts.
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 2:26 PM
+To: Herd, Kim (USAEO); Neal, Kristina (USAEO); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff
+(USAFLS)
+Cc: Jacobus, Wendy (USAFLS)
+Subject: Revised Draft with DOJ Edits
+Colleagues,
+Attached please find the latest revision, which includes the edits suggested by EOUSA. I have also incorporated the
+word "place", per Jeff's suggestion. For our DOJ colleagues, there is a new Section IlI, which goes into detail regarding
+the contact Marie had with the three victims.
+Also, as to whether Edwards raises the right to fairness being violated, I was referring to paragraph five of the
+emergency petition, which only alleges violations of the right to consultation, notice of public court proceedings,
+information regarding right to restitution, and notice of rights under the CVRA.
+A motion to seal has been prepared, seeking leave of the Court to seal the government's response, Marie's declaration,
+and the attachments to the declaration.
+<< File: victim_resp_USArev corrected_DOJedits.wpd >>
+587
+
+
+To:
+Wednesday, July 09, 2008 2:26 PM
+Herd, Kim (USAEO); Neal, Kristina (USAEO); Villafana, Ann Marie C. (USAFLS); Acosta,
+Alex (USAFLS); Sloman, Jeff (USAFLS)
+Cc:
+Subject:
+Jacobus, Wendy (USAFLS)
+Revised Draft with DOJ Edits
+Colleagues,
+Attached please find the latest revision, which includes the edits suggested by EOUSA. I have also incorporated the
+word "place", per Jeff's suggestion. For our DOJ colleagues, there is a new Section III, which goes into detail regarding
+the contact Marie had with the three victims.
+Also, as to whether Edwards raises the right to fairness being violated, I was referring to paragraph five of the
+emergency petition, which only alleges violations of the right to consultation, notice of public court proceedings,
+information regarding right to restitution, and notice of rights under the CVRA.
+A motion to seal has been prepared, seeking leave of the Court to seal the government's response, Marie's declaration,
+and the attachments to the declaration.
+ev corrected_D..
+588
+
+
+Subject:
+Attachments:
+lednesday, July 09, 2008 2:17 P
+ayrkendall, E N. (FBI); Richards, Jason R. (FE
+Emailing: Villafana Declaration-v2 final. wpd
+Villafana Declaration-v2 final. wpd
+Sorry if I seem cranky, I am just getting changes from 12 people at once.
+The message is ready to be sent with the following file or link attachments:
+Villafana Declaration-v2 final. wpd
+Note: To protect against computer viruses, e-mail programs may prevent sending or
+receiving certain types of file attachments.
+589
+
+
+Wednesday, July 09, 2008 2:13 PM
+RE: Government's Motion to Seal
+Subject
+Marie,
+Yes, both the response, your declaration, and the attachments to your declaration, are to be sealed.
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Wednesday, July 09, 2008 2:06 PM
+To: Lee, Dexter (USAFLS) |
+Subject: RE: Government's Motion to Seal
+Hi Dexter - You want to seal my declaration as well, right? Please let me know and 1 will change accordingly.
+Thanks.
+561209-1047
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 1:47 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Government's Motion to Seal
+Marie,
+In preparation for this afternoon's filing, I have prepared a motion to seal, which is attached.
+I did not include
+Epstein's name and made general assertions regarding the confidentiality of the negotiations, Please have someone
+sign both the motion to seal, and the government's response, for me. We then need to prepare a sealed document
+tracking sheet, to accompany the motion.
+An original and one copy of the sealed document should be placed in two separate envelopes, with the case number
+written on the outside. An original and one copy of the motion to seal should be filed with the Clerk.
+Thanks.
+•
+«< File: victim_Mot_seal.wpd »>
+590
+
+
+To:
+Subject:
+Wednesday, July 09, 2008 2:06 PM
+RE: Government's Motion to Seal
+Hi Dexter - You want to seal my declaration as well, right? Please let me know and I will change accordingly.
+Thanks.
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 1:47 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Government's Motion to Seal
+Marie,
+In preparation for this afternoon's filing, I have prepared a motion to seal, which is attached. I did not include
+Epstein's name and made general assertions regarding the confidentiality of the negotiations. Please have someone
+sign both the motion to seal, and the government's response, for me. We then need to prepare a sealed document
+tracking sheet, to accompany the motion.
+An original and one copy of the sealed document should be placed in two separate envelopes, with the case number
+written on the outside. An original and one copy of the motion to seal should be filed with the Clerk.
+Thanks.
+« File: victim_Mot_seal.wpd »>
+591
+
+
+Read: 7/9/2008 2:13 PM
+592
+
+
+To:
+Cc:
+Subject:
+Wednesday, July 09, 20081:49 PM
+Acosta, Alex (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS)
+Jacobus, Wendy (USAFLS)
+RE: Latest Version
+That was a typographical error, which Marie caught. It has been corrected.
+From: Acosta, Alex (USAFLS)
+Sent: Wednesday, July 09, 2008 1:48 PM
+To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Jacobus, Wendy (USAFLS)
+Subject: RE: Latest Version
+This version states that Edwards "did make the contact." I thought he had NOT made the contact to provide the state
+with information? (2d to last paragraph)
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 12:08 PM
+To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Jacobus, Wendy (USAFLS)
+Subject: Latest Version
+Colleagues,
+Attached please find the latest version of the government's response. I have added a new Section III, which details the
+efforts made by Marie in maintaining contact with |
+<< File: victim_resp_USArev corrected (3).wpd >>
+593
+
+
+To:
+Cc:
+Subject:
+Wednesday, July 09, 2008 1:48 PM
+Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS)
+Jacobus, Wendy (USAFLS)
+This version states that Edwards "did make the contact." I thought he had NOT made the contact to provide the state
+with information? (2d to last paragraph)
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 12:08 PM
+To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Jacobus, Wendy (USAFLS)
+Subject: Latest Version
+Colleagues,
+Attached please find the latest version of the government's response. I have added a new Section IlI, which details the
+efforts made by Marie in maintaining contact with
+, and
+« File: victim_resp_USArev corrected (3).wpd >>
+594
+
+
+To:
+Subject:
+Wednesday, July 09, 2008 1:47 PM
+Government's Motion to Seal
+Marie,
+In preparation for this afternoon's filing, I have prepared a motion to seal, which is attached. I did not include
+Epstein's name and made general assertions regarding the confidentiality of the negotiations. Please have someone
+sign both the motion to seal, and the government's response, for me. We then need to prepare a sealed document
+tracking sheet, to accompany the motion.
+An original and one copy of the sealed document should be placed in two separate envelopes, with the case number
+written on the outside. An original and one copy of the motion to seal should be filed with the Clerk.
+Thanks.
+victim_Mot_seal.
+wpd
+596
+
+
+To:
+Wednesday, July 09, 2008 1:24 PM
+Acosta, Alex (UŚAFLS); Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen
+(USAFLS)
+Cc:
+Subject:
+Attachments:
+Final Victim Notification -L
+Attached please find my proposed final victim notification letter. This 15
+addressed to Edwards' client,
+(Please note that all of the
+victims but one is now an adult and all of Mr. Edwards' clients are adults.)
+lease let me know if vou would like any changes made. Also, Dexter, please le
+le know when it is safe to send to Mr. Edwards. The letter for . will b
+identical.
+The message is ready to be sent with the following file or link attachments:
+Final Victim Notification --
+Note: To protect against computer viruses, e-mail programs may prevent sending or
+receiving certain types of file attachments. Check your e-mail security settings
+597
+
+
+Richards, Jason R. (FBI)
+Kuyrkendall, E N. (FBI)
+Read: 7/9/2008 1:27 PM
+Read: 7/9/2008 1:35 PM
+Read: 7/9/2008 1:35 PM
+Read: 7/10/2008 11:18 AM
+598
+
+
+To:
+Cc:
+Subject:
+Wednesday, July 09, 2008 1:19 PM
+Lee, Dexter (USAFLS); Herd, Kim (USAEO); Neal, Kristina (USAEO)
+Manning, Katharine (USAEO)
+RE: Victim Notification
+The Notification specifically provided that each victim would receive a copy with the names of all other victims redacted.
+We also have provided the list only by hand delivery to counsel for Mr. Epstein with a cover sheet advising them that
+disclosing the names to anyone could violate federal and/or state law. That cover sheet will accompany the victim
+notification even when it is sent to the victims themselves.
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 1:17 PM
+To: Herd, Kim (USAEO); Neal, Kristina (USAEO)
+Cc: Manning, Katharine (USAEO); Villafana, Ann Marie C. (USAFLS,
+Subject: RE: Victim Notificatior
+Kim,
+The consensus is that there's nothing to talk to Edwards about because the agreement has been signed and the federal
+case is over. We will not be reaching out to Edwards to get an extension.
+As to the draft notice, Epstein's lawyers raised a similar concern.
+From: Herd, Kim (USAEO)
+Sent: Wednesday, July 09, 2008 1:07 PM
+To: Lee, Dexter (USAFLS); Neal, Kristina (USAEO)
+Cc: Manning, Katharine (USAEO)
+Subject: RE: Victim Notification
+Our concern is that the list of individuals contains the names of minors. Have you thought about just listing initials? Or
+not providing the entire list to each victim?
+Also - any word from victim counsel on an extension?
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 12:29 PM
+To: Herd, Kim (USAEO); Neal, Kristina (USAEO)
+Subject: FW: Victim Notification
+599
+
+
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Tuesday, July 08, 2008 5:37 PM
+To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS)
+Subject: Victim Notification
+Hi Alex and Dexter - Here is the proposed notification that was provided to Epstein's counsel last week.
+<< File: Victim Identification and Notification Final with Goldberger sig revised.wpd >>
+Assuming that they don't sign it tomorrow, I would remove the bottom portion that calls for Epstein's signature
+and incorporate some instructional language along with notice that Jack Goldberger is the contact person for
+any civil litigation.
+500 S. Australian Ave, Suite 400
+600
+
+
+Herd, Kim (USAEO)
+Neal, Kristina (USAEO)
+Manning, Katharine (USAEO)
+Read: 7/9/2008 1:19 PM
+Read: 7/9/2008 1:19 PM
+Read: 7/9/2008 1:32 PM
+Read: 7/9/2008 1:40 PM
+601
+
+
+To:
+Cc:
+Subject:
+Wednesday, July 09, 2008 1:04 PM
+Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS)
+Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI)
+Response to Goldberger Letter
+Here are my thoughts:
+1. Notification only by mail: For those girls who are currently not represented (or for whom we do not know of
+any representation), we intend to contact the victims by telephone to tell them of the resolution and to get mailing
+addresses to send the written notification or to determine if they have secured counsel to send it to them. For the
+girls who are represented, contact will be made by telephone followed by the mailing of the notification. I think a
+"live" thank you is the least that is required at this point and a "check in" to make sure that girls who need
+counseling are getting it. (FBI has already arranged counseling for several girls.) In any written response to Mr.
+Goldberger, I would simply ignore this request.
+2. Separate mailings: I have no objection to this change. The notice was drafted the way it was so that Epstein
+would only have to sign one document rather than 33. Since he isn't going to sign any, that change is fine with
+me.
+3.
+Notification limited to the information on the first page of the draft notification: In light of Epstein's refusal
+to sign the acknowledgement, I think some additional explanation is required. I will prepare that revision and
+send to you shortly.
+4. Eliminate the Acknowledgement portion: I have no objection to this.
+S.
+Supplement the notification with our previous statement that we are not vouching for the veracity of any
+claim: I would reject this request and, in our response to Goldberger, state that we have limited our list to those
+whom we were prepared to name in an indictment and, accordingly, we believe that there is proof beyond a
+reasonable doubt that each was a victim of Epstein's,
+6. Explain why the acknowledgement is required: In our response to Goldberger, I think we should explain that
+the acknowledgement language was meant to create a means for proving the existence of the agreement without
+having to provide copies of the Non-Prosecution Agreement, which contains a confidentiality clause. While I
+have no objection to revising the language, I think that Epstein's position will lead to litigation regarding the need
+to disclose the full agreement, which is contrary to the parties' interest in confidentiality. I agree that we cannot
+force him to sign the acknowledgement, but he must accept the consequences of that decision.
+7. Names of pro bono lawyers and information regarding their communications: I have already advised Mr.
+Goldberger that I will provide him with the names and contact information of attorneys who represent the victims,
+so I have no objection to that. I also have no objection to telling him that they were recommended by the Crime
+Victims Rights Advocacy Group based upon a referral from the Justice Department. Other than that, I have no
+intention of disclosing any "communications" that I had with them.
+I will take a crack at revising the victim notifications and drafting a response to Goldberger. Any other thoughts I should
+incorporate?
+604
+
+
+Kuyrkendall, E N. (FBI)
+Richards, Jason R. (FBI)
+Read: 7/9/2008 1:26 PM
+Read: 7/9/2008 1:05 PM
+605
+
+
+To:
+Cc:
+Subject:
+Attachments:
+Wednesday, July 09, 2008 12:42 PM
+Lee, Dexter (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Emailing: Villafana Declaration-v2 final. wpd
+Villafana Declaration-v2 final.wpd
+Hi all -- I think this includes everyone's thoughts. If any changes are needed,
+please let me know.
+The message is ready to be sent with the following file or link attachments:
+Villafana Declaration-v2 final. wpd
+Note: To protect against computer viruses, e-mail programs may prevent sending or
+receiving certain types of file attachments.
+606
+
+
+To:
+Cc:
+Subject:
+Wednesday, July 09, 2008 12:34 PM
+RE: Victim Notification
+Hi Dexter - Jack Goldberger's response just arrived - I am sending it in a separate e-mail. I need to revise the letter and
+make sure Alex and Jeff' approve before it goes out, so it won't be ready until later this afternoon. I just need to make sure
+that it goes out before I file my Declaration, since 1 swear that it has gone out to Attorney Edwards.
+Thanks.
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 12:28 PM
+To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS)
+Subject: RE: Victim Notification
+Marie,
+DOJ wanted us to hold off sending this out until we get clearance to file our document this afternoon. Will that pose
+any problems?
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Tuesday, July 08, 2008 5:37 PM
+o: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS)
+Subject: Victim Notificatior
+Hi Alex and Dexter - Here is the proposed notification that was provided to Epstein's counsel last week.
+< File: Victim Identification and Notification Final with Goldberger sig revised.wpd >>
+Assuming that they don't sign it tomorrow, I would remove the bottom portion that calls for Epstein's signature
+and incorporate some instructional language along with notice that Jack Goldberger is the contact person for
+any civil litigation.
+A. Marie Villajaña
+500 S. Australian Ave, Suite 400
+607
+
+
+608
+
+
+Read: 7/9/2008 12:35 PM
+Read: 7/9/2008 1:25 PM
+609
+
+
+To:
+Cc:
+Subject:
+Attachments:
+Wednesday, July 09, 2008 12:35 PM
+Acosta, Alex (UŚAFLS); Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS)
+Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI); Lee, Dexter (USAFLS)
+FW: Jeffrey Epstein - Response from Jack Goldberger
+Letter to A. Marie Villafana dated 070908.pdf
+Attached please find Jack Goldberger's response to my letter.
+-----Original Message-----
+From: Nira Alanis [mailto:nalanis@agwpa.com]
+Sent: Wednesday, July 09, 2008 12:28 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Jeffrey Epstein
+This attachment has been sent to you on behalf of Jack A. Goldberger, Esquire.
+Regards,
+Nayanira Alanis,
+Legal Assistant
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+T#561-659-8300
+F#561-835-8691
+610
+
+
+Kuyrkendall, E N. (FBI)
+Richards, Jason R. (FBI)
+Read: 7/9/2008 1:26 PM
+Read: 7/9/200B 1:32 PM
+Read: 7/10/2008 11:14 AM
+Read: 7/9/2008 12:35 PM
+611
+
+
+To:
+Subject:
+Wednesday, July 09, 2008 12:28 PM
+Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS)
+RE: Victim Notification
+Marie,
+DOJ wanted us to hold off sending this out until we get clearance to file our document this afternoon. Will that pose
+any problems?
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Tuesday, July 08, 2008 5:37 PM
+To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS)
+Subject: Victim Notification
+Hi Alex and Dexter - Here is the proposed notification that was provided to Epstein's counsel last week.
+<< File: Victim Identification and Notification Final with Goldberger sig revised.wpd>>
+Assuming that they don't sign it tomorrow, I would remove the bottom portion that calls for Epstein's signature
+and incorporate some instructional language along with notice that Jack Goldberger is the contact person for
+any civil litigation.
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL. 33401
+613
+
+
+To:
+Cc:
+Subject:
+Wednesday, July 09, 2008 12:22 PM
+Acosta, Alex (USAFLS); Lee, Dexter (USAFLS)
+Sloman, Jeff (USAFLS); Atkinson, Karen (USAFLS)
+Revised Declaration
+I removed the sentence about why the Palm Beach Police contacted FBI for assistance. I notice that the language
+regarding my securing pro bono counsel for IT
+I was removed. I think it shows how far we went out of our way to
+protect the victims, especially Mr. Edwards' clients. Is it alright to put it back in?
+A. Marie Villataña
+614
+
+
+Read: 7/9/2008 1:25 PM
+Read: 7/9/2008 12:22 PM
+Read: 7/9/2008 2:05 PM
+615
+
+
+To:
+Subject:
+Attachments:
+Wednesday, July 09, 2008 12:15 PM
+Emailing: victim_resp_USArev corrected (3).wpd
+victim_resp_USArev corrected (3).wpd
+Hi Dexter -- I caught one date error and an important "not" in the last section -
+- as far as I know, Edwards did NOT make contact with the State Attorney's
+Office.
+The message is ready to be sent with the following file or link attachments:
+victim_resp_USArev corrected (3). wpd
+Note: To protect against computer viruses, e-mail programs may prevent sending or
+receiving certain types of file attachments.
+616
+
+
+To:
+Cc:
+Subject:
+Wednesday, July 09, 2008 12:08 PM
+Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Jacobus, Wendy (USAFLS)
+Latest Version
+Colleagues,
+Attached please find the latest version of the government's response. I have added a new Section I!!, which details the
+efforts made by Marie in maintaining contact with fl, and
+D
+rev corrected (...
+617
+
+
+To:
+Cc:
+Subject:
+Wednesday, July 09, 2008 12:00 PM
+Acosta, Alex (USAFLS); Lee, Dexter (USAFLS); Sloman, Jeff (USAFLS)
+Jacobus, Wendy (USAFLS)
+RE: Brad Edwards' End Game
+I have talked to Brad and his heart seems to be in the right place, he just has
+gotten himself a bit too worked up over this. The agents and I (and Karen, I
+think) would be happy to meet with him and his clients. The problem is that
+there is nothing to discuss -- the agreement has already been signed and our
+investigation is closed. In light of that, I don't think a meeting would satisfy
+him because he seems to believe that his petition can undo what has been done.
+500 S. Australian Ave, Suite 400
+-----Original Message-----
+From: Acosta, Alex (USAFLS)
+Sent: Wednesday, July 09, 2008 11:56 AM
+To: Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS)
+Cc: Jacobus, Wendy (USAFLS)
+Subject: Re: Brad Edwards' End Game
+Not at all.
+We need to file today.
+----- Original Message
+From: Lee, Dexter (USAFLS)
+To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff
+(USAFLS)
+Cc: Jacobus, Wendy (USAFLS)
+Sent: Wed Jul 09 11:52:46 2008
+Subject: Brad Edwards' End Game
+Marie, Alex and Jeff,
+I have just spoken with Kim Herd at EOUSA regarding clearance to argue that no
+rights to consultation accrue until after charges have been filed. The argument
+is being considered by Criminal Division and OLP.
+Kim wanted to know what
+Edwards' objective in this case is, and whether he would agree to meet and try to
+resolve this.
+I told Kim that the only way to avoid our filing at 5:00 p.m.
+today is if Edwards' agree to a joint enlargement of time.
+618
+
+
+HOW
+reasonable do you think Edwards is?
+619
+
+
+Jacobus, Wendy (USAFLS)
+Read: 7/9/2008 12:01 PM
+Read: 7/9/2008 12:01 PM
+Read: 7/9/2008 12:00 PM
+Read: 7/9/2008 12:12 PM
+620
+
+
+To:
+Subject:
+Re: Brad Edwards' End Game
+Not at all.
+We need to file today.
+----- Original Message -----
+From: Lee, Dexter (USAFLS)
+To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff
+Cc: Jacobus, Wendy (USAFLS)
+Sent: Wed Jul 09 11:52:46 2008
+Subject: Brad Edwards' End Game
+Marie, Alex and Jeff,
+I have just spoken with Kim Herd at EOUSA regarding clearance to argue that no
+rights to consultation accrue until after charges have been filed. The argument
+is being considered by Criminal Division and OLP.
+Kim wanted to know what
+Edwards' objective in this case is, and whether he would agree to meet and try to
+resolve this.
+I told Kim that the only way to avoid our filing at 5:00 p.m.
+today is if Edwards' agree to a joint enlargement of time.
+How reasonable do you think Edwards is?
+621
+
+
+To:
+Cc:
+Subject:
+Wednesday, July 09, 2008 11:53 AM
+Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS)
+Jacobus, Wendy (USAFLS)
+Brad Edwards' End Game
+Marie, Alex and Jeff,
+I have just spoken with Kim Herd at EOUSA regarding clearance to argue that no rights to consultation accrue until after
+charges have been filed. The argument is being considered by Criminal Division and OLP. Kim wanted to know what
+Edwards' objective in this case is, and whether he would agree to meet and try to resolve this.
+I told Kim that the only
+way to avoid our filing at 5:00 p.m. today is if Edwards' agree to a joint enlargement of time.
+How reasonable do you think Edwards is?
+622
+
+
+To:
+Cc:
+Subject:
+Attachments:
+Wednesday, July 09, 2008 11:49 AM
+Sloman, Jeff (USAFLS); Lee, Dexter (USAFLS); Acosta, Alex (USAFLS)
+Atkinson, Karen (USAFLS); Jacobus, Wendy (USAFLS)
+RE: Emailing: victim_resp_USArev corrected.wpd
+image001.png
+Here is the language from the Agreement. I will leave it to you to interpret whether disclosing part of the substance of the
+Agreement requires sealing or otherwise.
+The parties anticipate that this agreement will not be made p
+public record. If the United States receives a Freedom of In
+Act request or any compulsory process commanding the dis
+the agreement, it will provide notice to Epstein before mi
+disclosure.
+-----Original Message-..--
+From: Sloman, Jeff (USAFLS)
+Sent: Wednesday, July 09, 2008 9:57 AM
+To: Lee, Dexter (USÁFLS); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS)
+Ce: Atkinson, Karen (USAFLS); Jacobus, Wendy (USAFLS)
+Subject: RE: Emailing: victim_resp_USArev corrected. wpd
+Doesn't the confidentiality provision obligate us to file it under seal?
+-----Original Message-...
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 9:53 AM
+To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS)
+Ce: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS)
+Subject: RE: Emailing: victim_resp_USArev corrected. wpd
+Alex and Jeff,
+Do you have any preference for filing under seal or a public filing? If we can protect the identities of the minor victims in a
+public filing, that is one less reason to file it under seal. The other considerations are the government's confirmation that
+Epstein was under federal investigation, and the confidentiality provision in the deferral of prosecution agreement with Epstein.
+It's actually easier to file it electronically, and the general policy is that documents filed in court are public.
+-----Original Message-...
+623
+
+
+From: Villafiana, Ann Marie C. (USAFLS)
+Sent: Wednesday, July 09, 2008 9:23 AM
+To: Lee, Dexter (USAFL.S); Acosta, Alex (USAFLS)
+Ce: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS)
+Subject: RE: Emailing: victim_resp_USArey corrected. wpd
+I was planning to redact all of that information prior to scanning it and attaching Exhibit Stickers. I think we should do so even
+if this is filed under seal.
+-----Original Message-...-
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 9:22 AM
+To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS)
+Ce: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS)
+Subject: RE: Emailing: victim_resp_USArev corrected.wpd
+Marie,
+I will sign the response. Since this case involves girls who were minors when the crimes were committed, and there is a
+confidentiality provision in the deferral of prosecution agreement with Epstein, I believe this should be filed under seal.
+Otherwise, we'll have to go through each letter and excise the names, addresses, and other identifying information on the three
+girls.
+-----Original Message-----
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Wednesday, July 09, 2008 9:11 AM
+To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS)
+Ce: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS)
+Subject: Emailing: victim_resp_USArev corrected.wpd
+Dexter and Alex -- I fixed a couple of typos and entered the correct information about the dates when the letters were sent. I
+also included the information about all three of Edwards' clients,
+1, and |
+At the end, 1 also corrected the information regarding the notifications of the victims about the change of plea. I called Edwards
+in Friday, but I'm not sure whether we spoke that day or if he called me over the weekend. And the agents and I didn't star
+naking calls together until Monday after the hearing. So I notified Edwards to inform his three clients, and PBPD tried te
+notify six victims, I think. I didn't want the court to think that we tried to notify all 33 girls.
+I will make similar changes to my declaration and send that to you shortly.
+Also, I notice there is no signature block. Do you want me to sign and file? Or will you do that, Dexter? Thanks.
+The message is ready to be sent with the following file or link attachments:
+victim_resp_USArey corrected.wpd
+Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments.
+Check your e-mail security settings to determine how attachments are handled.
+624
+
+
+Jacobus, Wendy (USAFLS)
+Read: 7/9/2008 11:49 AM
+Read: 7/9/2008 11:49 AM
+Read: 7/9/2008 11:55 AM
+Read: 7/9/2008 12:29 PM
+625
+
+
+To:
+Cc:
+Subject:
+Wednesday, July 09, 2008 10:38 AM
+A few thoughts:
+1. bottom of page 5/ top of page 6 - - were we talk about the "Throughout the
+negotiations, ... recompense. " Should we cite to Decl para 8?
+•. Next para -- cite to para 8 should be cite to para 10.
+3. Right before the next para starting with On Friday, should we discuss the
+but have nad, knowteage of theing
+. In fact, maybe this should be a separate argument III -- he, or his clients,
+ad prior knowledge and didn't complain until now. Thoughts?
+Attorney?
+-----Original Message-----
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Wednesday, July 09, 2008 9:22 AM
+To: Acosta, Alex (USAFLS); Lee, Dexter (USAFLS)
+Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS)
+Subject: Emailing: Villafana Declaration-v2 final. wpd
+Attached is the revised declaration.
+Please let me know if any other changes are
+required. I am off to Court but should be back by 11:30.
+Thank you.
+The message is ready to be sent with the following file or link attachments:
+Villafana Declaration-v2 final. wpd
+Note: To protect against computer viruses, e-mail programs may prevent sending or
+receiving certain types of file attachments. Check your e-mail security settings
+626
+
+
+To:
+Cc:
+Subject:
+Wednesday, July 09, 2008 9:57 AM
+Lee, Dexter (USAFLS); Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS)
+Atkinson, Karen (USAFLS); Jacobus, Wendy (USAFLS)
+RE: Emailing: victim_resp_USArev corrected.wpd
+Doesn't the confidentiality provision obligate us to file it under seal?
+-----Original Message----
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 9:53 AM
+To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS)
+Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS)
+Subject: RE: Emailing: victim_resp_USArev corrected.wpd
+Alex and Jeff,
+Do you have any preference for filing under seal or a public filing?
+If we can
+protect the identities of the minor victims in a public filing, that is one less
+reason to file it under seal.
+The other considerations are the government's
+confirmation that Epstein was under federal investigation, and the
+confidentiality provision in the deferral of prosecution agreement with Epstein.
+It's actually easier to file it electronically, and the general policy is that
+documents filed in court are public.
+-----Original Message-----
+From: Villafana, Ann Marie C. (USAFLS)
+To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS)
+Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS)
+Subject: RE: Emailing: victim_resp_USArev corrected.wpd
+I was planning to redact all of that information prior to scanning it and
+attaching Exhibit Stickers. I think we should do so even if this is filed under
+•----Original Message----
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 9:22 AM
+To: Villafana,
+Ann Marie C. (USAFLS); Acosta, Alex (USAFLS)
+627
+
+
+Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS)
+Subject: RE: Emailing: victim_resp_USArev corrected. wpd
+Marie,
+I will sign the response. Since this case involves girls who were minors when
+the crimes were committed, and there is a confidentiality provision in the
+deterral of prosecution agreement with Epstein, I believe this should be filed
+under seal. Otherwise, we'll have to go through each letter and excise the
+names, addresses, and other identifying information on the three girls.
+-----Original Message-----
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Wednesday, July 09, 2008 9:11 AM
+To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS)
+Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS)
+Subject: Emailing: victim_resp_USArev corrected.wpd
+Dexter and Alex -- I fixed a couple of typos and entered the correct information
+about the dates when the letters were sent. I also included the information
+about all three of Edwards' clients, I
+1•, and li
+At the end, I also corrected the information regarding the notifications of the
+victims about the change of plea. I called Edwards on Friday, but I'm not sure
+whether we spoke that day or if he called me over the weekend. And the agents
+and I didn't start making calls together until Monday after the hearing.
+SO I
+notified Edwards to inform his three clients, and PBPD tried to notify six
+victims, I think. I didn't want the court to think that we tried to notify all
+33 girls.
+I will make similar changes to my declaration and send that to you shortly.
+Also, I notice there is no signature block. Do you want me to sign and file? Or
+will you do that, Dexter? Thanks.
+The message is ready to be sent with the following file or link attachments:
+victim_resp_USArev corrected. wpd
+Note: To protect against computer viruses, e-mail programs may prevent sending or
+receiving certain types of file attachments.
+628
+
+
+To:
+Subject:
+Wednesday, July 09, 2008 9:23 AM
+Lee, Dexter (USAFLS); Acosta, Alex (USAFLS)
+Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS)
+RE: Emailing: victim_resp_USArev corrected.wpd
+I was planning to redact all of that information prior to scanning it and
+attaching Exhibit Stickers.
+I think we should do so even if this is filed under
+seal.
+-----Original Message-----
+From: Lee, Dexter (USAFLS)
+Sent: Wednesday, July 09, 2008 9:22 AM
+To: Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS)
+Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS)
+Subject: RE: Emailing: victim_resp_USArev corrected. wpd
+Marie,
+I will sign the response. Since this case involves girls who were minors when
+the crimes were committed, and there is a confidentiality provision in the
+deferral of prosecution agreement with Epstein, I believe this should be filed
+under seal.
+Otherwise, we'll have to go through each letter and excise the
+names, addresses, and other identifying information on the three girls.
+-----Original Message-----
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Wednesday, July 09, 2008 9:11 AM
+To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS)
+Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS)
+Subject: Emailing: victim_resp_USArev corrected. wpd
+Dexter and Alex -- I fixed a couple of typos and entered the correct information
+about the dates when the letters were sent. I also included the information
+about all three of Edwards' clients,
+.., and l.
+and I didn't start making calls together until Monday after the hearing. So I
+notified Edwards to inform his three clients, and PBPD tried to notify six
+629
+
+
+victims, I think. I didn't want the court to think that we tried to notify all
+33 girls.
+I will make similar changes to my declaration and send that to you shortly.
+Also, I notice there is no signature block. Do you want me to sign and file? Or
+will you do that, Dexter? Thanks.
+The message is ready to be sent with the following file or link attachments:
+victim_resp_USArev corrected.wpd
+Note: To protect against computer viruses, e-mail programs may prevent sending or
+receiving certain types of file attachments. Check your e-mail security settings
+630
+
+
+Jacobus, Wendy (USAFLS)
+Read: 7/9/2008 9:30 AM
+Read: 7/9/2008 9:30 AM
+Read: 7/9/2008 9:25 AM
+Read: 7/9/2008 9:53 AM
+631
+
+
+From.
+To:
+Cc:
+Subject:
+Attachments:
+Wednesday, July 09, 2008 9:22 AM
+costa, Alex (USAFLS); Lee, Dexter (USAFLS
+kinson, Karen (USAFLS); Sloman, Jeff (USAFL:
+Emailing: Villafana Declaration-v2 final.wpd
+Villafana Declaration-v2 final. wpd
+Attached is the revised declaration. Please let me know if any other changes are
+required.
+I am off to Court but should be back by 11:30.
+Thank you.
+The message is ready to be sent with the following file or link attachments:
+Villafana Declaration-v2 final. wpd
+Note: To protect against computer viruses, e-mail programs may prevent sending or
+receiving certain types of file attachments.
+632
+
+
+To:
+Cc:
+Subject:
+Wednesday, July 09, 2008 9:22 AM
+Villafana, Ann Marie C. (USAFLS); Acosta, Alex (USAFLS)
+Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS); Jacobus, Wendy (USAFLS)
+RE: Emailing: victim_resp_USArev corrected.wpd
+Marie,
+I will sign the response.
+Since this case involves girls who were minors when
+che crimes were committed, and there is a confidentiality provision in the
+deferral of prosecution agreement with Epstein, I believe this should be filed
+under seal.
+Otherwise, we'll have to go through each letter and excise the
+names, addresses, and other identifying information on the three girls.
+-----Original Message-..--
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Wednesday, July 09, 2008 9:11 AM
+To: Lee, Dexter (USAFLS); Acosta, Alex (USAFLS)
+Cc: Atkinson, Karen (USAFLS); Sloman, Jeff (USAFLS)
+Subject: Emailing: victim_resp_USArev corrected. wpd
+Dexter and Alex -- I fixed a couple of typos and entered the correct information
+about the dates when the letters were sent..
+I also included the information
+about all three of Edwards' clients,
+1, and
+At the end, I also corrected the information regarding the notifications of the
+victims about the change of plea. I called Edwards on Friday, but I'm not sure
+whether we spoke that day or if he called me over the weekend. And the agents
+and I didn't start making calls together until Monday after the hearing.
+So I
+notified Edwards to inform his three clients, and PBPD tried to notify six
+victims, I think. I didn't want the court to think that we tried to notify all
+33 girls.
+I will make similar changes to my declaration and send that to you shortly.
+Also, I notice there is no signature block. Do you want me to sign and file? Or
+will you do that, Dexter? Thanks.
+The message is ready to be sent with the following file or link attachments:
+victim_resp_USArev corrected.wpd
+Note: To protect against computer viruses, e-mail programs may prevent sending or
+receiving certain types of file attachments. Check your e-mail security settings
+633
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/ea41360245c2260441fe9a8d8ce2adde8596ec64953555bd72716e1e0b427b09.receipt.json b/vision-fixhub/ds9-unparsed-05/ea41360245c2260441fe9a8d8ce2adde8596ec64953555bd72716e1e0b427b09.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e0ceb6cde5e03417f3861d75ac148498e32ff0e9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ea41360245c2260441fe9a8d8ce2adde8596ec64953555bd72716e1e0b427b09.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -20203,
+  "dataset": "marble-joined",
+  "doc_id": "ea41360245c2260441fe9a8d8ce2adde8596ec64953555bd72716e1e0b427b09",
+  "engine": "marble-apple-vision",
+  "event_count": 171,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "319db3b4fe5d27e5c4d483054291b700d20c443dd368e5e16920951765217988",
+  "output_sha256": "20e9bf982043ac2d75b3b83806b111c2d4f721615eea024f469dc5bd3631d2b5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ea526c886e83dd394c15882cddf1e540f2a5780266a26efd8763b33c43452460.md b/vision-fixhub/ds9-unparsed-05/ea526c886e83dd394c15882cddf1e540f2a5780266a26efd8763b33c43452460.md
new file mode 100644
index 0000000000000000000000000000000000000000..c3c5547e17a5d83c3435487c00efab6776a64a3d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ea526c886e83dd394c15882cddf1e540f2a5780266a26efd8763b33c43452460.md
@@ -0,0 +1,16 @@
+U.S. Department of Justice
+nited States Attorney
+outhern District of Florid
+TO:_
+DATE: July 16, 2007
+FAX NO.
+PHONE NO.
+FROM: |
+PHONE NO.
+COMMENTS:
+Esq.
+Facsimile
+FACSIMILE COVER SHEET
+# OF PAGES: 3
+RE: William Riley-
+Assistant U.S. Attorney
diff --git a/vision-fixhub/ds9-unparsed-05/ea526c886e83dd394c15882cddf1e540f2a5780266a26efd8763b33c43452460.receipt.json b/vision-fixhub/ds9-unparsed-05/ea526c886e83dd394c15882cddf1e540f2a5780266a26efd8763b33c43452460.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e92bcfbbd8b3824c4c18dd5da9b8174fd73233d1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ea526c886e83dd394c15882cddf1e540f2a5780266a26efd8763b33c43452460.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "ea526c886e83dd394c15882cddf1e540f2a5780266a26efd8763b33c43452460",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "d496cc1ecf3369be986d22018ff989b3975055a1dd5142d0c80af806b82653e8",
+  "output_sha256": "cf4d6207d3a66dbb43508013431ce9acbed7de17041950b2c02dbbbb1ad4815e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/eb3d2dd4ef72063a7ca692c2de4e934512bb73ff95dd9044a186f54ba643f0bb.md b/vision-fixhub/ds9-unparsed-05/eb3d2dd4ef72063a7ca692c2de4e934512bb73ff95dd9044a186f54ba643f0bb.md
new file mode 100644
index 0000000000000000000000000000000000000000..f9f95d638be5f84f441e9ddae061f48d5fe2fc1f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/eb3d2dd4ef72063a7ca692c2de4e934512bb73ff95dd9044a186f54ba643f0bb.md
@@ -0,0 +1,38 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.
+IN RE SEALED INDICTMENT
+MOTION TO SEAL
+NOW COMES the United States of America, by and through its undersigned attorney, and respectfully
+requests that the indictment, arrest warrants, this motion, and any resulting Order be SEALED until the arrest of
+the defendants or until further order of this Court, excepting the United States Attorney's Office and federal law
+enforcement agencies, which may obtain copies of any indictment, arrest warrant, or other sealed document for
+purposes of arrest, extradition, or any other necessary cause, for the reason that the named defendants may flee,
+evidence may be destroyed, the integrity of the ongoing investigation might be compromised, and the safety of
+certain witnesses could be compromised should knowledge of this indictment become public.
+Respectfully submitted,
+JEFFREY H. SLOMAN
+ACTING UNITED STATES ATTORNEY
+By:
+ASSISTANT UNITED STATES ATTORNEY
+Florida Bar No. L
+500 East Broward Boulevard, 7th Floor
+Ft Lauderdale, FL 33394
+Telephone: 9
+Facsimile:
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.
+IN RE SEALED INDICTMENT
+SEALED ORDER
+The United States of America, having applied to this Court for an Order sealing the
+indictment, arrest warrants, its motion to seal, and this Order and the Court finding good cause:
+IT IS HEREBY ORDERED that the indictment, arrest warrants, and this Order shall be filed under seal
+until the arrest of the defendants or until further order of this Court, however, the United States Attorney's Office
+and any federal law enforcement agency may obtain copies of any indictment, arrest warrant, or other sealed
+document for purposes of arrest, extradition, or any other necessary cause.
+DONE AND ORDERED in chambers at West Palm Beach, Florida, this _
+_ day of June, 2009.
+UNITED STATES MAGISTRATE JUDGE
+cc:
+AUSA
diff --git a/vision-fixhub/ds9-unparsed-05/eb3d2dd4ef72063a7ca692c2de4e934512bb73ff95dd9044a186f54ba643f0bb.receipt.json b/vision-fixhub/ds9-unparsed-05/eb3d2dd4ef72063a7ca692c2de4e934512bb73ff95dd9044a186f54ba643f0bb.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..93bd85e28f9f157030435b929cc2546784f0cd9b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/eb3d2dd4ef72063a7ca692c2de4e934512bb73ff95dd9044a186f54ba643f0bb.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "eb3d2dd4ef72063a7ca692c2de4e934512bb73ff95dd9044a186f54ba643f0bb",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "b38c0a701517d4a1f38d93589d404e87dc7df0daade03037656a66506f44f27d",
+  "output_sha256": "ba9022d10639b297c5012470ba11c1d67bf3d2bb74419fd7ae316dd54e651771",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ebb5c386fbf582c5eef85c28a3b432015309986d4e6982b4e519738c46e824b8.md b/vision-fixhub/ds9-unparsed-05/ebb5c386fbf582c5eef85c28a3b432015309986d4e6982b4e519738c46e824b8.md
new file mode 100644
index 0000000000000000000000000000000000000000..c0550a28272c7760b81aefd01ac7aea55baca39a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ebb5c386fbf582c5eef85c28a3b432015309986d4e6982b4e519738c46e824b8.md
@@ -0,0 +1,887 @@
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND FOR
+PALM BEACH COUNTY, FLORIDA
+JEFFREY EPSTEIN,
+Plaintiff,
+Complex Litigation, Fla. R. Civ. Pro. 1.201
+CASE NO.
+50 2009 CAO / 0 3 0 0 XXX MB
+SCOTT ROTHSTEIN, individually,
+BRADLEY J. EDWARDS, individually, and
+L.M., individually,
+Defendants.
+COPY
+RECEIVED FOR FILING
+DEC Đ / 2009
+ShAnON 1. BOCK
+COMPLAINT
+Plaintiff, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his
+undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN,
+individually, BRADLEY J. EDWARDS, individually, and L.M., individually. Accordingly,
+EPSTEIN states:
+SUMMARY OF ACTION
+Attorney Scott Rothstein aided by other lawyers and employees at the firm
+of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal
+of the ethical, legal and fiduciary duties to their own clients and professional obligations
+to the administration of justice, deliberately engaged in a patter of racketeering that
+involved a staggering series of gravely serious obstructions of justice, actionable frauds,
+and the orchestration and conducting of egregious civil litigation abuses that resulted in
+profoundly serious injury to Jeffrey Epstein one of several targets of their misconduct
+
+
+Page 2
+and others. Rothstein and RRA's fraud had no boundary; Rothstein and his coconspirators forged Federal court orders and opinions. Amongst the violations of law
+that are the subject of this lawsuit are the marketing of non-existent Epstein settlements
+and the sanctioning of a series of depositions that were unrelated to any principled
+litigation purpose but instead designed to discover extraneous private information about
+Epstein or his personal and business associates (including well-known public figures) in
+order to defraud investors and support extortionate demands for payment from Epstein.
+The misconduct featured the filing of legal motions and the pursuit of a civil litigation
+strategy that was unrelated to the merits or value of their clients' cases and, instead,
+had as its improper purpose the furthering of Rothstein's misrepresentations and deceit
+to third party investors. As a result, Epstein was subject to abusive investigatory tactics,
+unprincipled media attacks, and unsupportable legal filings. This lawsuit is filed and will
+be vigorously pursued against all these defendants. The Rothstein racketeering
+enterprise endeavored to compromise the core values of both state and federal justice
+systems in South Florida and to vindicate the hardworking and honest lawyers and their
+clients who were adversely affected by the misconduct that is the subject of this
+Complaint.
+Plaintiff reserves the right to add additional defendants - co-conspirators as the
+facts and evidence is developed.
+GENERAL ALLEGATONS
+1. This is an action for damages in excess of $15,000.00, exclusive costs, interest,
+and attorneys' fees.
+
+
+Page 3
+2. Plaintiff, EPSTEIN, is an adult and currently is residing and works in Palm Beach
+County, Florida.
+3. Defendant, SCOTT ROTHSTEIN ("ROTHSTEIN"), is an individual residing in
+Broward County, Florida, and was licensed to practice law in the State of Florida. In
+November 2009, ROTHSTEIN voluntarily relinquished his law license in the midst of the
+implosion of Rothstein, Rosenfeldt and Adler, P.A. ("RRA"). He was disbarred by the
+Florida Supreme Court on November 20, 2009. On December 1, 2009, ROTHSTEIN
+was arrested and arraigned in Federal Court in Broward County, Florida.
+4. At all times relevant hereto, ROTHSTEIN was the managing partner and CEO of
+RRA.
+5. Defendant, ROTHSTEIN and Stuart Rosenfeldt, are and were the principal
+owners of equity in RRA and each co-founded RRA.
+6. Defendant, BRADLEY J. EDWARDS ("EDWARDS"), is an individual residing in
+Broward County, Florida and is licensed to practice law in the State of Florida. At all
+times relevant hereto, EDWARDS was an employee, agent, associate, partner,
+shareholder, and/or other representative of RRA.
+7. Defendant, L.M. ("L.M.'), is an individual residing in Palm Beach County, Florida.
+At all times relevant hereto, L.M. was represented by RRA, ROTHSTEIN and
+EDWARDS in a civil lawsuit against Epstein and was an essential participant in the
+scheme referenced infra by, among other things, substantially changing prior sworn
+testimony, so as to assist the Defendants in promoting their fraudulent scheme for the
+
+
+Epstein [| RRA, et al.
+Page 4
+promise of a multi-million dollar recovery relative to the Civil Actions (defined below)
+involving Epstein, which was completely out of proportion to her alleged damages.
+8. Non-party, RRA is a Florida Professional Service Corporation, with a principal
+address of 401 East Las Olas Blvd., Suite 1650, Fort Lauderdale, FL 33401. In addition
+to its principal office, RRA also maintained seven offices in Florida, New York, and
+Venezuela, and employed over 70 attorneys and 200 support staff. RRA also maintains
+an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through
+its attorneys, including those named as Defendants herein, conducted business
+throughout Florida, and relevant to this action, conducted business and filed lawsuits on
+behalf of clients in Palm Beach County, Florida. (RRA is currently a debtor in
+bankruptcy. RRA is not named as a Defendant).
+FACTUAL ALLEGATIONS
+9. The United States in United States of America I. Scott W. Rothstein, Case No.
+09-60331CR-Cohn, United States District Court, Southern District of Florida, has
+brought an action for Racketeering Conspiracy, 18 U.S.C. § 1962(d) against Scott W.
+Rothstein who was the chief executive officer and chairman of RRA. Within the
+information which was filed, the United States of America has identified the enterprise
+as being the law firm, RRA, through which Rothstein in conjunction with "his coconspirators" (not yet identified by the USA) engaged in the pattern of racketeering
+through its base of operation at the offices of RRA from sometime in 2005 up through
+and continuing into November of 2009. Through various criminal activities, including
+mail fraud, wire fraud and money laundering, the United States of America asserts that
+
+
+Page 5
+Rothstein and his co-conspirators unlawfully obtained approximately $1.2 billion from
+investors by fraud in connection with a Ponzi scheme. The USA further alleges that
+"Rothstein and co-conspirators initiated the criminal conduct alleged in the instant
+Information in order to personally enrich themselves and to supplement the income and
+sustain the daily operation of RRA." In essence, in the absence of Rothstein and his coconspirators conducting the Ponzi scheme, the daily operation of RRA, which included
+payroll (compensation to lawyers, staff, investigators, etc.), accounts payable including
+unlimited improper, harassing and potential illegal investigation on cases, including
+Epstein-related matters, would in all likelihood would not have been sustainable. A copy
+of the information is attached as Exhibit 1 to this action.
+10. As more fully set forth herein, RRA held itself out as legitimately and properly
+engaging in the practice of law. In reality, ROTHSTEIN and others in RRA were using
+RRA to market investments, as described below, so as to bilk investors out of hundreds
+of millions of dollars. ROTHSTEIN and others in RRA devised an elaborate plan
+through which were sold purported confidential assignments of a structured pay-out
+settlements, supposedly reached on behalf of RRA for clients, in exchange for
+immediate payments to these clients of a discounted lump sum amount. Investors were
+being promised in excess of a 30% return on their investment which was to be paid out
+to the investors over time. While some of the cases relied upon to induce investor
+funding were existing filed cases, it is believed that the confidential, structured pay-out
+settlements were all fabricated.
+
+
+Page 6
+11. Based on media reports, Federal Bureau of Investigation (FBI) press
+conferences and releases and the Information the massive Ponzi scheme and pattern of
+criminal activity meant to lure investors began sometime in 2005 and continued through
+the fall of 2009, when the scheme was uncovered by some of the investors and the FBI.
+As of November of 2009, civil lawsuits were and continue to be filed against various
+Defendants as result of their massive fraudulent and criminal scheme.
+12. This fraudulent and illegal investment scheme is also evidenced by the filing of
+Amended Complaint For Dissolution And For Emergency Transfer of Corporate Powers
+to Stuart A. Rosenfeldt, Or, In The Alternative, For the Appointment of A Custodian or
+Receiver by ROSENFELDT, and RRA, against ROTHSTEIN, individually. (Case No. 09
+059301, In the Circuit Court of the Seventeenth Judicial Circuit, Broward County,
+Florida, Complex Business Div.), (hereinafter "RRA dissolution action, and attached
+hereto as Exhibit 2).
+13. Plaintiff references the RRA dissolution action for the sole purpose that it
+acknowledges that RRA and ROTHSTEIN were in fact conducting an illegal and
+improper investment or Ponzi scheme based on promises of financial retums from
+settlements or outcomes of supposed legal actions, including the actions brought
+against Plaintiff EPSTEIN.
+The RRA dissolution action alleges in part that -
+"ROTHSTEIN, the managing partner and CEO of the firm (RRA), has, according to
+assertions of certain investors, allegedly orchestrated a substantial misappropriation of
+funds from investor trust accounts that made use of the law firm's name (RRA). The
+investment business created and operated by ROTHSTEIN centered around the sale of
+
+
+Page 7
+interests in structured settlements." See Preliminary Statement of RRA dissolution
+action, Exhibit 2 hereto.
+14. In furtherance of the scheme, RRA's letterhead was used in communications
+regarding investment opportunities in purported structured settlements. RRA's trust
+account was used to deposit hundreds of millions of dollars or wire transfer of monies
+from duped investors and other victims. RRA personally guaranteed payments.
+15. Rothstein's scheme went so far as to manufacture false and fraudulent Court
+opinions/orders including forging the signatures of U.S. District Judge, Kenneth A.
+Marra and U.S. Circuit Court Judge, Susan H. Black, 11" Circuit in other cases. It is not
+yet known if he forged similar documents in Esptein related matters. See Composite
+
+16. The details of this fraudulent scheme are being revealed on a daily basis through
+various media reports and court documents. The most recent estimate of the financial
+scope of the scheme is that it exceeds $1.2 billion dollars.
+17. Relevant to this action, EPSTEIN is currently named as a defendant in three civil
+actions alleging, inter alia, sexual assault and battery that were handled by RRA and its
+attorneys including EDWARDS prior to its implosion - one of which is filed in federal
+court (Jane Doe |. Epstein, Case No. 08-CIV-80893, U.S.D.C. S.D. Fla.)(Jane Doe is a
+named Defendant herein), and two of which have been filed in state court in the 15"h
+Judicial Circuit Court, Palm Beach County, State of Florida, (L.M. |. Epstein, Case No.
+502008CA028051XXXXMB AB; E.W. |. Epstein, Case No. 502008CA028058XXXXMB
+
+
+Page 8
+AB), (hereinafter collectively referred to as the "Civil Actions," and L.M is a named
+Defendant herein). The Civil Actions were all filed in August and September of 2008.
+18. What is clear is that a fraudulent and improper investment or Ponzi scheme was
+in fact conducted and operated by RRA and certain of the named Defendants, which
+scheme directly impacted EPSTEIN as a named defendant in the Civil Actions.
+19. Miami attorney and developer, Alan Sakowitz, was quoted in a November 2009
+article as saying that he had met with ROTHSTEIN as a potential investor in August of
+2009, but became suspicious. He stated "I was convinced it was all a Ponzi scheme
+and 1 notified the FBI in detail how Scotty ROTHSTEIN was hiding behind a legitimate
+law firm to peddle fake investments." Attorney Sakowitz was also quoted as saying
+ROTHSTEIN had sophisticated eavesdropping equipment and former law enforcement
+officers who would sift through a potential defendants' garbage looking for damaging
+evidence to use with investors to show how potential defendants could be in essence
+blackmailed into paying settlement that far exceeded the value of any legitimate
+damage claim.
+20. Ft. Lauderdale attorney William Scherer represents multiple Rothstein related
+investors. He indicated in an article that RRA/Rothstein had used the "Epstein Ploy ...
+as a showpiece as bait. That's the way he raised all the money. He would use. cases
+as bait for luring investors into fictional cases. All the cases he allegedly structured
+were fictional. I don't believe there was a real one in there." In fact, on November 20,
+2009, William Scherer, on behalf of certain clients, filed a 147 page Complaint against
+ROTHSTEIN, David Boden, Debra Villegas, Andrew Barnett, TD Bank, N.A., Frank
+
+
+Page 9
+Spinosa, Jennifer Kerstetter, Rosanne Caretsky and Frank Preve asserting various
+allegations that further prove the massive Ponzi scheme behind the RRA façade; and
+as of November 25, 2009, a 249 page Amended Complaint naming additional
+Defendants was filed.
+21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie
+Villegas, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA)
+through brokers or middlemen would stage regular meetings during which false
+statements were made about the number of cases/clients that existed or RRA had
+against EPSTEIN and the value thereof. They would show and share actual case files
+from the EPSTEIN actions with hedge fund managers. Thus, the attorneys and clients
+have waived any attorney-client or work- product privileges that otherwise may have
+existed.
+22. Because potential investors were given access to some of the actual Civil Action
+files, investor-third parties may have became aware of a name of an existing Plaintiff
+who had filed anonymously against Epstein and had opposed disclosure of her legal
+name.
+23. In all other instances, by RRA, ROTHSTEIN and EDWARDS claiming the need
+for anonymity with regard to existing or fabricated clients, they were able to effectively
+use initials, Jane Doe or other anonymous designations which was a key element in the
+fraudulent scheme. Fictitious names could be created to make the investors believe
+many other cases existed against Epstein.
+
+
+Page 10
+24. In each of RRA's Civil Actions, the Plaintiffs are or were represented by RRA and
+its attorneys, including ROTHSTEIN and EDWARDS.
+25. In addition, investors were told that in addition to the Civil Actions another fifty
+(50) plus anonymous females were represented by RRA, with the potential for hundreds
+of millions of dollars in settlements, and that RRA and its attomeys would sue Epstein
+unless he paid exorbitant-settlement amounts to protect his high-profile friends.
+26. Upon information and belief, EDWARDS knew or should have known that
+ROTHSTEIN was utilizing RRA as a front for the massive Ponzi scheme and/or were
+selling an alleged interest or investment in the Civil Actions (and other claims) involving
+Epstein.
+27. Further evidencing that EDWARDS (and possibly other attorneys of RRA) knew
+or should have known and participated in the continuation of the massive Ponzi
+scheme, a front-page Palm Beach Post article, dated November 24, 2009, reported on
+the recent filing of an amended forfeiture complaint by prosecutors against "dozens of
+ROTHSTEIN's real estate properties, foreign cars, restaurants and other assets -
+including $12 million in the lawyer's bank account in Morocco, along with millions more
+donated to political campaigns and charitable funds." The article further reported that-
+Attorney Scott ROTHSTEIN tapped into millions of dollars from his massive
+investment scam to cover payroll costs at his expanding Fort Lauderdale
+law firm, federal authorities said in court records released Monday.
+ROTHSTEIN's law firm (RRA) generated revenue of $8 million in one
+recent year, yet his 70-lawyer law firm had a payroll of $18 million,
+
+
+Page 11
+prosecutors said. ROTHSTEIN, who owned half of RRA used investors'
+money from his Ponzi scheme to make up the shortfall, they said.
+Subsequent articles and court filings have reflected ROTHSTEIN received
+compensation in excess of $35.7 million in 2008 and $10.5 million in 2009, while
+his partner Rosenfeldt received greater than $6 million in 2008.
+28. ROTHSTEIN attempted to lure the entity known as D3 Capital Club, LLC, ("D3").
+by offering D3 "the opportunity" to invest in a pre-suit $30,000,000.00 court settlement
+against EPSTEIN; yet this supposed settlement never existed and was entirely
+fabricated. To augment his concocted story, ROTHSTEIN, upon information and belief,
+invited D3 to his office to view thirteen (13) banker's boxes of case files in Jane Doe
+(one of the Civil Actions)' in an attempt to substantiate that the claims against EPSTEIN
+were legitimate and that the evidence obtained against him by RRA, ROTHSTEIN, and
+EDWARDS (the "Litigation Team") was real.
+29. Upon information and belief, ROTHSTEIN and others offered other investors like
+the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN.
+Fisten (a former Dade County police officer with a questionable police record and RRA
+investigator) and Jenne (a former attorney, Broward County Sheriff and felon) assisted
+ROTHSTEIN in making these offers by providing confidential, privileged and workproduct information to prospective third-party investors.
+'It appears that 13 out of the 40 boxes seized by the FBI as part of its investigation at RRA
+consisted of files relating to the Civil Actions involving EPSTEIN, as reported by counsel for the
+Bankruptcy Trustee. Until those boxes can be reviewed, as well as other discovery, Epstein will
+not know the depth of the fraud and those involved.
+
+
+Page 12
+30. By using the Civil Actions against EPSTEIN as "bait" and fabricating settlements
+regarding same, ROTHSTEIN and others were able to lure investors into
+ROTHSTEIN'S lair and bilked them of millions of dollars which, in turm, was used to fund
+the litigation against EPSTEIN for the sole purpose of continuing the massive Ponzi
+scheme.
+31. As part of this scheme, ROTHSTEIN and the Litigation Team, individually and in
+a concerted effort, may have unethically and illegally:
+a. Sold, allowed to be sold and/or assisted with the sale of an interest in nonsettled personal injury lawsuits (which are non-assignable and nontransferable) or sold non-existent structured settlements (including those
+cases involving Epstein);
+b. Reached agreements to share attorneys fees with non-lawyers;
+c. Used investor money to pay plaintiffs (i.e., L.M., E.W. and Jane Doe) "up
+front" money such that plaintiffs would refuse to settle the Civil Actions;
+d. Conducted searches, wiretaps or intercepted conversations in violation of
+state or federal laws and Bar rules; and
+e. Utilized the judicial process including, but not limited to, unreasonable and
+unnecessary discovery, for the sole purpose of furthering the Ponzi
+scheme.
+32. Any such actions by ROTHSTEIN, and other attorneys, including the Litigation
+Team, directly or indirectly, would potentially be a violation of various Florida Bar Rules,
+
+
+Page 13
+including prohibiting the improper sharing of fees or costs and various conflicts of issues
+rules.
+33. Evidencing that the Litigation Team knew or should have known of the improper
+purpose that ROTHSTEIN was pursuing in the continuation of the scheme,
+ROTHSTEIN used RRA's Litigation Team in the EPSTEIN cases to pursue issues and
+evidence unrelated to and unnecessary to the claims pled in the Civil Actions, but
+significantly beneficial to lure investors into the Ponzi scheme orchestrated by
+ROTHSTEIN and other co-conspirators.
+34. Upon information and belief, ROTHSTEIN and others claimed their investigators
+discovered that there were high-profile individuals onboard Epstein's private jet where
+sexual assaults took place and showed D3 (and possibly others) copies of a flight log
+purportedly containing names of celebrities, dignitaries, and international figures.
+35. For instance, the Litigation Team relentlessly and knowingly pursued flight data
+and passenger manifests regarding flights EPSTEIN took with these famous individuals
+knowing full well that no underage women were onboard and no illicit activities took
+place. ROTHSTEIN and the Litigation Team also inappropriately attempted to take the
+depositions of these celebrities in a calculated effort to bolster the marketing scam that
+was taking place.
+36. One of Plaintiffs' counsel, EDWARDS, deposed three of EPSTEIN'S pilots, and
+sought the deposition of a fourth pilot (currently serving in Iraq). The pilots were
+deposed by EDWARDS for over twelve (12) hours, and EDWARDS never asked one
+question relating to or about E.W., L.M., and Jane Doe (RRA clients) as it related to
+
+
+Page 14
+transportation on flights of RRA clients on any of EPSTEIN'S planes. But EDWARDS
+asked many inflammatory and leading irrelevant questions about the pilots' thoughts
+and beliefs (which will never be admissible at trial) which could only have been asked
+for the purposes of "pumping" the cases and thus by using the depositions to sell the
+cases (or a part of them) to third parties.
+37. Because of these facts, ROTHSTEIN claimed that Epstein wanted to make
+certain none of these individuals would be deposed and therefore he had offered
+$200,000,000.00 to settle the claims of RRA female clients various potential plaintiffs in
+actions against EPSTEIN. The offer of a $200 million dollar settlement by EPSTEIN
+was completely fabricated; no such offer had ever been made.
+38. EDWARDS' office also notified Defendant that he intended to take the
+depositions of and was subpoenaing:
+(i) Donald Trump (real-estate magnate and business mogul);
+(ii) Alan Dershowitz (noted Harvard Law professor, constitutional attorney
+and one of EPSTEIN'S criminal defense attomeys);
+(ili)Bill Clinton (Former President of the United States);
+(iv) Tommy Mottola (former President of Sony Record); and
+( David Copperfield (illusionist).
+39. The above-named individuals were friends and acquaintances of EPSTEIN with
+whom he knew through business or philanthropic work over the years. None of the
+above-named individuals had any connection whatsoever with any of the Litigation
+Team's clients, E.W., L.M. or Jane Doe.
+
+
+Epstein _. RRA, et al.
+Page 15
+40. EDWARDS filed amended answers to interrogatories in the state court matters,
+E.W. and L.M., and listed additional high profile witnesses that would allegedly be called
+at trial, including, but not limited to:
+(i) Bill Richardson (Governor of New Mexico, formerly U.S.
+Representative and Ambassador to the United Nations); and
+(ii) Any and all persons having knowledge of EPSTEIN'S charitable,
+political or other donations;?
+41. The sole purpose of the scheduling of these depositions or listing high profile
+friends/acquaintances as potential witnesses was, again, to "pump" the cases to
+investors. There is no evidence to date that any of these individuals had or have any
+knowledge regarding RRA's Civil Actions.
+42. In furtherance of their illegal and fraudulent scheme against EPSTEIN,
+ROTHSTEIN, EDWARDS (who either know or should have known) and, at times, L.M.
+in her Civil Action against EPSTEIN:
+a) Included claims for damages in Jane Doe's federal action in
+excess of $50,000,000.00 rather than simply alleging the
+jurisdictional limits.
+b) Organized a Jane Doe TV media interview without any legitimate
+legal purpose other than to "pump" the federal case for potential
+" These high-profile celebrity "purported" witnesses have no personal knowledge regarding the facts or
+these "Three Cases", but were being contacted, subpoenaed or listed to harass and intmidate them and
+Epstein, and to add "star" appeal to the marketing effort of the Ponzi scheme.
+
+
+Page 16
+investors or to prejudice Epstein's right to a fair trial in Palm
+Beach County.
+c) EDWARDS, Berger and Russeil Adler (another named partner in
+RRA) all
+attended EPSTEIN's deposition. At that time,
+outrageous questions were asked of EPSTEIN which had no
+bearing on the case, but so that the video and questions could be
+shown to investors.
+d) Conducted and attempted to conduct completely irrelevant
+discovery unrelated to the claims in or subject matter of the Civil
+Actions for the purpose of harassing and embarrassing witnesses
+and EPSTEIN and causing EPSTEIN to spend tens of thousands
+of dollars in unnecessary attorneys' fees and costs defending
+what appeared to be discovery related to the Civil Actions but was
+entirely related to the furtherance of the Ponzi scheme.
+e) After EDWARDS was recruited and joined RRA in the spring of
+2009, the tone and tenor of rhetoric directed to cases against
+EPSTEIN used by Attorney EDWARDS and Berger changed
+dramatically in addressing the court on various motions from
+being substantive on the facts pled to ridiculously inflammatory
+and sound-bite rich such as the July 31, 2009, transcript when
+EDWARDS stated to the Court in E.W./L.M.: "What the evidence
+is really going to show is that Mr. Epstein - at least dating back as
+
+
+Page 17
+far as our investigation and resources have permitted, back to
+1997 or '98 - has every single day of his life, made an attempt to
+sexually abuse children. We're not talking about five, we're not
+talking about 20, we're not talking about 100, we're not talking
+about 400, which, I believe, is the number known to law
+enforcement, we are talking about thousands of children... and it
+is through a very intricate and complicated system that he devised
+where he has as many as 20 people working underneath him that
+he is paying well to schedule these appointments, to locate these
+girls."
+f) As an example, EDWARDS filed an unsupportable and legally
+deficient Motion for Injunction Restraining Fraudulent Transfer of
+Assets, Appointment of a Receiver to Take Charge of Property of
+Epstein, and to Post a $15 million Bond to Secure Potential
+Judgment, in Jane Doe |. Epstein, Case No. 08-CV-80893-
+Marra/Johnson. The motion was reported in the press as was the
+ultimate goal (i.e., to "pump" the cases for investor following).
+However, the Court found "Plaintiff's motion entirely devoid of
+evidence...", and denied the motion in toto.
+g) ROTHSTEIN told investors he had another 52 females that he
+represented, and that Epstein had offered $200 million to resolve,
+
+
+Page 18
+but that he could settle, confidently, these cases for $500 million,
+separate and apart from his legal fees.
+h) ROTHSTEIN and the Litigation Team knew or should have known
+that their three (3) filed cases were weak and had minimal value
+for the following reasons:
+(i)
+L.M. - testified she never had any type of sex with
+(ii)
+(iii)
+Epstein; worked at numerous strip clubs; is an
+admitted prostitute and call girl; has a history of
+illegal drug use (pot, painkillers, Xanax, Ecstasy);
+and continually asserted the 5* Amendment
+during her depositions in order to avoid answering
+relevant but problem questions for her;
+E.W. - testified she worked at eleven (11)
+separate strip clubs, including Cheetah which
+RRA represented and in which ROTHSTEIN may
+have owned an interest; and E.W. also worked at
+Platinum Showgirls in Boynton Beach, which was
+the subject of a recent police raid where dancers
+were allegedly selling prescription painkillers and
+drugs to customers and prostituting themselves.
+Jane Doe (federal case) seeks $50 million from
+Epstein. She and her attomeys claim severe
+
+
+Page 19
+emotional distress as a
+i result of her having
+voluntarily gone to Epstein's home. She testified
+that there was never oral, and or sexual
+intercourse; nor did she ever touch his genitalia.
+Yet, Jane Doe suffered extreme emotional distress
+well prior to meeting Epstein as a result of having
+witnessed her father murder his girlfriend's son.
+She was required to give sworn testimony in that
+matter and has admitted that she has lied in sworn
+testimony. Jane Doe worked at two different strip
+clubs, including Platinum Showgirls in Boynton
+Beach.
+i) Conducted ridiculous and irrelevant discovery such as
+subpoenaing records from an alleged sex therapist, Dr. Leonard
+Bard in Massachusetts, when the alleged police report reflected
+that EPSTEIN had only seen a chiropractor in Palm Beach named
+Dr. Bard. No records relating to EPSTEIN existed for this alleged
+sex therapist, Dr. Bard, and the alleged subpoena for records was
+just another mechanism to "pump" the cases for investor appeal;
+j) Allowed a Second Amended Complaint to be filed on behalf of
+L.M. alleging that EPSTEIN forced the minor into "oral sex," yet
+L.M. testified that she never engaged in oral, anal, or vaginal
+
+
+Page 20
+intercourse with EPSTEIN and she had never touched his
+genitalia.
+k) Told investors, as reported in an Associated Press article, that
+celebrities and other famous people had flown on EPSTEIN'S
+plane when assaults took place. Therefore, even though none
+(zero) of RRA's clients claim they flew of EPSTEIN'S planes, the
+Litigation Team sought pilot and plane logs. Why? Again, to
+prime the investment "pump" with new money without any
+relevance to the existing claims made by the RRA clients.
+1) After EDWARDS joined RRA, EDWARDS and former Circuit
+Judge William Berger filed and argued motion to make the Non-
+Prosecution Agreement (NPA) between Epstein and USAO
+public. But, RRA, EDWARDS and Berger, and their three clients,
+already had a copy of the NPA. They knew what it said and they
+knew the civil provisions in the agreement had no impact
+whatsoever on the three pending Civil Actions.
+The concept behind certain civil provisions in the NPA was
+to allow an alleged victim to resolve a civil claim with Epstein,
+maintain her complete privacy and anonymity and move on with
+her life.
+As an assistant United States Attorney stated at a
+hearing in federal court, the NPA was not designed "to hand them
+a jackpot or a key to a bank."
+
+
+*.
+Page 21
+43. ROTHSTEIN, with the intent and improper motive to magnify his financial gain
+so continue to fund the fraudulent and illegal investment and/or Ponzi scheme, had
+EDWARDS demand excessive money from EPSTEIN in the Civil Actions.
+44. The actions described in paragraph 42 above herein had no legitimate purpose in
+pursuing the Civil Actions against EPSTEIN, but rather were meant to further the
+fraudulent scheme and criminal activity of ROTHSTEIN so that he and others could
+fraudulently overvalue the settlement value of the existing and non-existent claims
+against EPSTEIN to potential investors.
+45. As a result of the fraudulent investment or (Ponzi) scheme, RRA and its
+attomeys in the Civil Actions against EPSTEIN may have compromised their clients'
+interests. ROTHSTEIN and the Litigation Team would have been unable to give
+unbiased legal counsel because outside investors) had been promised a financial
+interest in the outcome of the actions. Additionally, if a plaintiff received payments from
+investment monies while her action is pending, this clearly could impact the plaintiff's
+decision of whether or not to settle the current litigation or shade their testimony (i.e..
+commit perjury) to gain the greatest return on the investment and to further promote the
+Ponzi Scheme.
+46.
+The truthfulness of L.M.'s allegations and testimony in L.M.'s state civil
+action have been severely compromised by the need to seek a multi-million dollar
+payout to help maintain RRA's massive fraud. Because fictitious settlements of tens of
+millions of dollars in cases relating to EPSTEIN were represented to "investors" in this
+Ponzi scheme, RRA and the attorneys in the Civil Actions needed to create a fiction that
+
+
+Page 22
+included extraordinary damages. However, the actual facts behind her action would
+never support such extraordinary damages. Therefore, extraordinary measures were
+undertaken to create an entirely inflated value of her claims against EPSTEIN.
+a. Though she held herself out as a "victim" of Epstein, she admitted to having
+returned over and over again to him despite her current claim of abuse. She
+has now admitted, under oath, to being a call girl/escort since the age of 15.
+(in her deposition September 24, 2009 Transcript "DT" 280:16-19). She
+testified "Well, I lived life as a prostitute," (see DT 156:7) and "I am a
+prostitute when I make money" (see DT 156:12-13). L.M. admitted her
+activity with men other than Epstein to making $1,000 a day from prostitution
+on maybe more than 20 occasions in one year alone (DT 157:11-158:21).
+L.M. admitted under oath to keeping a list of amounts she collected from
+"Johns" in "two or three" lined books including a book of "Psalms" that she
+obtained from a religious store (DT 152:1-14). Under the circumstances, her
+claim for damages against EPSTEIN, one of L.M.'s many "Johns" during that
+same period, would be so incredible and certainly not likely to produce the
+extraordinary settlements promised to "RRA's investors."
+47.
+In April 2007, before she was represented by EDWARDS, and RRA, L.M.
+gave swor taped recorded testimony to the agents of the FBI. She was represented
+by a lawyer other than EDWARDS at that statement. She spoke of EPSTEIN in a very
+positive and friendly terms and directly contradicted the central allegations on which
+L.M.'s civil action against Epstein is now based. However, once in the hands of
+
+
+Page 23
+EDWARDS and RRA, L.M.'s story changed dramatically. All of a sudden she wanted to
+sue EPSTEIN and like other RRA clients, sought tens of millions of dollars.
+a. For example, in her sworn statement to the FBI, L.M. was insistent that
+"Jeffrey is an awesome man." (p. 21 - FBI); At the conclusion of she
+stated: "I hope Jeffrey, nothing happens to Jeffrey because he's an
+awesome man and it really would be a shame. It's a shame that he has to
+go through this because he's an awesome guy and he didn't do nothing
+wrong, nothing." (pp. 57-58 - FBI). In fact, L.M. spoke so highly of
+EPSTEIN and her interactions with him that the US Attorney's office
+informed a federal court in July 2008 that the US Attomey could not
+consider L.M. a victim.
+Yet, by September 24, 2009, the date on which L.M. began her
+deposition in her civil action and now represented by RRA and
+EDWARDS, L.M.'s new and very different tale about purported sexual
+misconduct under the supposed influence of EPSTEIN had been
+thoroughly rehearsed and her role into the ROTHSTEIN scam was
+complete. In her deposition in her civil action, L.M. declared that:
+"', I don't really care about money." (DT 206:8)
+"He needs time in jail. He doesn't want to be - this is not right for
+him to be on the streets living daily..." (DT 219:21-23)
+
+
+Page 24
+"You don't think my whole life I have lived that shitty life because of
+Jeffrey Epstein?" (DT 222:7-8)
+In her sworn FBI testimony (pre-EDWARDS and RRA), L.M. was
+emphatic that her interactions with Epstein involved no inappropriate
+sexual touching in any way. In fact, it was exactly the opposite:
+Q: Did he at any point kiss you, touch you, show any kind of
+affection towards you?
+A: Never, never. (p. 21 - FBI) ...
+Q: So he never pulled you closer to him in a sexual way?
+A: I wish. ' No, no, never, ever, ever, no, never. Jeffrey is an
+awesome man, no. (p. 21 - FBI)
+Yet, L.M. filed her second amended complaint in April 2009,
+after EDWARDS joined RRA, the allegations against EPSTEIN in
+L.M.'s complaint became even more salacious. In paragraph 12 of
+L.M:'s Second Amended Complaint, L.M. alleges among other
+things, that:
+"Jeffrey Epstein coerced, induced, or enticed ...the then minor
+Plaintiff to commit various acts of sexual misconduct. These acts
+included, but were not limited to, fondling and inappropriate and
+illegal sexual touching of the then minor Plaintiff, forcing or inducing
+the then minor plaintiff into oral sex or other sexual misconduct..."
+
+
+Page 25
+c. In her sworn FBI statement (pre-EDWARDS and RRA), L.M. testified that
+Carolyn Andriano, the individual who first brought L.M. to EPSTEIN's
+home, told L.M. "make sure you're 18 because Jeffrey doesn't want any
+underage girls." (p. 8 - FBI).
+Yet at her September, 2009 deposition now represented by
+EDWARDS and RRA, L.M. told a very different story:
+Q: My question was what did Carolyn tell you to tell Mr. Epstein
+about your age?
+A: She said it didn't matter.
+Q: That's your recollection about what she said?
+A: Yes, she said - I remember her saying it doesn't matter. Don't
+worry about it.
+(DT 199:20-25)
+d.
+Pre-EDWARDS and RRA, L.M. testified to the FBI: "I always made
+sure - I had a fake ID, anyways saying that I was 18." (p. 8 - FBI).
+Yet, when questioned about her fake ID at her September 2009 depo, she
+stated:
+Q: And did you have a fake ID?
+A: No.
+Q: Have you ever had a fake ID?
+
+
+Page 26
+A: No.
+(DT 300:5-8)
+e.
+In her FBI statement (pre-EDWARDS and RRA), L.M. testified
+about others L.M. brought to the Epstein home. L.M. testified that women she
+brought to EPSTEIN's home were eager for the opportunity and content with their
+experiences:
+A: None of my girls ever had a problem and they'd call me. They'd
+beg me, you know, for us to go to Jeffrey's house because they
+love Jeffrey. Jeffrey is a respectful man. He really is. I mean, and
+he all thought we were of age always. This is what's so sad about
+it. (p 30 - FBI).
+...
+Q: Did any of the girls complain about what happened after they left
+there?
+A: No. You asked me that question. No, everybody loved Jeffrey.
+(p. 44 - FBI)
+A: Every girl that I brought to Jeffrey, they said they were fine with
+it. and like for example [E.W. - another of RRA's clients in the
+Civil Actions], a lot of girls begged me to bring them back for the
+money. And as far as | know, we all had fun there. (p. 45 - FBI)
+
+
+Page 27
+Yet, with EDWARDS and RRA as her attorneys, L.M. did a "180" at her
+September, 2009 deposition in saying:
+A:... Once they were there, they were scared out of their mind.
+They did it anyways and some of them walked out and said L.M.
+don't ever do this to me again. That was the worst thing that ever
+happened to me. (DT 170:6-11)
+...A: And then, a lot of girls weren't comfortable. (DT 171:13)
+f.
+The above represent only a few of the dramatic changes L.M. made
+in her testimony prior to her representation by EDWARDS/RRA and after she
+hired ROTHSTEIN, EDWARDS and RRA.
+48. As a result of the fraudulent investment or (Ponzi) scheme, L.M. may knowingly
+have compromised her alleged interests in her Civil Action, or committed a fraud on the
+court.
+49. RRA and the Litigation Team took an emotionally driven set of facts involving
+alleged innocent, unsuspecting, underage females and a Palm Beach Billionaire and
+sought to turn it into a gold mine. Rather than evaluating and resolving the cases based
+on the merits (i.e. facts) which included knowledgeable, voluntary and consensual
+actions by each of the claimants and substantial pre-Epstein psychological and
+emotional conditions of each of the claimants and substantial sexual experiences pre-
+Epstein, RRA and the Litigation Team sought through protective orders and objections
+to block relevant discovery regarding their claimants. They instead forged ahead with
+discovery the main purpose of which was to pressure Epstein into settling the cases.
+
+
+Page 28
+Fortunately, their tactics have not been successful. As Magistrate Judge Linnea
+Johnson wrote in a discovery order dated September 15, 2009 (DE 299 in Federal Case
+#08-80119) in denying Plaintiffs' Motion for Protective Order:
+"This is his [Epstein's] right. The Record in this case is clear that the childhood of
+many of the Plaintiffs was marred by instances of abuse and neglect, which in
+turn may have resulted, in whole or in part, in the damages claimed by the
+Plaintiffs."
+In addition, in an Omnibus Order dated October 28, 2009 (DE 377 in Federal
+Case #08-80119) Magistrate Judge Linnea Johnson wrote:
+"Here the request at issue goes to the very heart of the Plaintiff's damage claims,
+requesting not only general information relating to Plaintiff's sexual history, but
+inquiring as to specific instances wherein Plaintiff received compensation or
+consideration for sex acts, claim other males sexually assaulted, battered, or
+abuses her, and/or claim other males committed lewd or lascivious acts on her.
+As a global matter, Plaintiffs clearly and unequivocally place their sexual history
+in issue by their allegations that Epstein's actions in this case has negatively
+affected their relationships by, among other things, "distrust in men," "sexual
+intimacy problems," "diminished trust," "social problems," " problems in personal
+relationships," " feeling of stress around men," "premature teenage pregnancy,"
+"antisocial behaviors," and "hyper-sexuality and promiscuity." Considering these
+allegation, there simply can be no question that Epstein is entitled to know
+whether Plaintiffs were molested or the subject of other "sexual activity" or "lewd
+
+
+Page 29
+and lascivious conduct" in order to determine whether there is an alternative
+basis for the psychological disorders Plaintiffs claim to have sustained, whether
+Plaintiffs engaged in prostitution or other similar type acts and how certain acts
+alleged in the Complaint materially affected Plaintiffs' relationships with others or
+how those acts did not have such an affect on those relationships and/or whether
+Plaintiffs suffered from the alleged emotional and psychological disorders as a
+result of other sexual acts prior to the acts alleged in the Complaint. To deny
+Epstein thus discovery, would be tantamount to barring him from mounting a
+defense."
+50. ROTHSTEIN, EDWARDS and L.M.'s actions constitute a fraud upon EPSTEIN
+as RRA, ROTHSTEIN and the Litigation Team represented themselves to be acting in
+good faith and with the bests interests of their clients in mind at all times when in reality,
+they were acting in furtherance of the investment or Ponzi scheme described herein.
+EPSTEIN justifiably relied to his detriment on the representations of RRA, and
+Defendants, ROTHSTEIN, EDWARDS and L.M. as to how he conducted and defended
+the Civil Actions brought against him.
+51. As a direct and proximate result of the fraudulent and illegal investment or Ponzi
+scheme orchestrated by ROTHSTEIN and as yet other unknown co-conspirators and as
+a result of the litigation tactics undertaken by the Litigation Team and L.M. as set forth
+herein, Plaintiff EPSTEIN has incurred and continues to incur the monetary damages
+including, but not limited to, having to pay an amount in excess of the Civil Actions' true
+value as a result of them refusing to settle in that a percentage of any payment by
+
+
+Page 30
+EPSTEIN may have been promised to third party investors; incurring significant
+additional legal fees and costs as result of Defendants refusal to conduct settlement
+negotiations in a forthright and good faith manner because any monies paid by
+EPSTEIN is in reality a promised return on an investment; and incurred significant
+attorneys' fees and costs in defending the discovery that was not relevant, material
+and/or calculated to lead to the admissibility of evidence, but which was done for the
+sole purpose of "pumping" the cases to investors.
+52. EPSTEIN has also been injured in that the scope of the fraudulent and criminal
+or racketeering activity so permeated the RRA law firm that EPSTEIN has been
+prevented from fully and fairly defending the civil actions brought against him. In
+essence, the very existence of RRA was based on the continuation of the massive
+Ponzi scheme orchestrated by ROTHSTEIN and other co-conspirators. In order to
+continue to bring in monies from investors, ROTHSTEIN and other co-conspirators used
+the Civil Actions against EPSTEIN, along with other manufactured lawsuits, as a means
+of obtaining massive amounts of money.
+53. ROTHSTEIN, EDWARDS and L.M. are liable for damages caused to EPSTEIN -
+individually, and jointly and severally.
+Count I - Violation of 5$772.101, et seg., Fla. Stat. -
+Florida Civil Remedies for Criminal Practices Act -
+54. Plaintiff realleges and incorporates paragraphs 1 through 53 as if fully set forth
+herein.
+
+
+Page 31
+55. RRA, ROTHSTEIN, EDWARDS and L.M. each and collectively constitute an
+enterprise pursuant to §772.102(3), Fla. Stat. (2009).
+56. ROTHSTEIN, EDWARDS and L.M. engaged in a pattern of criminal activity as
+defined in §772.102(3) and (4), Fla. Stat. (2009).
+57. As alleged herein, ROTHSTEIN and EDWARDS committed multiple predicate
+acts in violation of §772.103(1), (2), (3) and (4), Fla. Stat., including violations of Florida
+Statutes - Chapter 517, relating to securities transactions; Chapter 817, relating to
+fraudulent practices, false pretenses, and fraud generally (which includes L.M.); Chapter
+831, relating to forgery; §836.05, relating to extortion (which includes L.M.); and Chapter
+837, relating to perjury (which includes L.M.). Substantially more than two predicate
+acts (i.e., the selling of or participation of the sale of fabricated settlements outlined
+herein, including the Civil Actions involving Epstein as well as the improper litigation
+tactics outlined above) occurred within a five-year time period.
+58. As a direct and proximate result of ROTHSTEIN, EDWARDS and L.M.'s
+violations of §772:103, Fla. Stat., EPSTEIN has been injured.
+59. Pursuant to §772.104(1), Fla. Stat., Plaintiff EPSTEIN is entitled to threefold of
+his actual damages sustained, reasonable attorney's fees and court costs, and such
+other damages as allowed by law.
+WHEREFORE, Plaintiff EPSTEIN respectfully demands the entry of a judgment for
+damages against all the named Defendants.
+Count Il - Florida RICO-
+"Racketeer Influenced and Corrupt Organization Act"
+Pursuant to §6895.01, et seq., Fla. Stat. (2009),
+
+
+Page 32
+60. Plaintiff realleges and incorporates paragraphs 1 through 53 as if fully set forth
+herein.
+61. RRA, along with ROTHSTEIN, EDWARDS and L.M., each and collectively,
+constitute an enterprise pursuant to §895.02(3), Fla. Stat. (2009).
+62. During all times relevant hereto, ROTHSTEIN, EDWARDS and L.M. were and
+are associated with the enterprise, RRA, and each other.
+63. Defendants, ROTHSTEIN, EDWARDS and L.M., as persons associated with the
+enterprise, RRA and each other (as an enterprise), unlawfully conducted or participated,
+directly or indirectly, in such an enterprise through a pattern of racketeering. §
+895.03(3), Fla. Stat., as alleged above herein.
+64. The breadth and scope of ROTHSTEIN, EDWARDS and, potentially, L.M.'s
+racketeering activity continues to be investigated by the FBI, as numerous civil lawsuits
+against some of the Defendants and others continue to be filed by persons who have
+been damaged. As of the filing of this Complaint, criminal charges have only been
+brought against ROTHSTEIN.
+65. Substantially more than two predicate acts (i.e., the selling of fabricated
+settlements outlined herein, including the Civil Actions involving Epstein as well as the
+improper litigation tactics outlined above) occurred within a five year time period.
+66. Pursuant to §895.02, Fla. Stat., ROTHSTEIN and EDWARDS engaged in a
+pattern of "racketeering activity" through the commission of crimes as defined in §
+895.02(1)(a)-(b), Fla. Stat., including Chapter 517, relating to securities; Chapter 817,
+relating to fraudulent practices, false pretenses, and fraud (including L.M.) generally;
+
+
+Epstein I. RRA, et al.
+Page 33
+Chapter 813, relating to forgery; §836.05, relating to extortion (including L.M.); Chapter
+837, relating to perjury (including L.M.).
+67. Pursuant to §895.05, Fla. Stat., Plaintiff seeks the foliowing relief against
+Defendants, ROTHSTEIN, EDWARDS and L.M.:
+a) Ordering ROTHSTEIN and EDWARDS to divest themselves of
+any interest in the enterprise, RRA;
+b) Enjoin all Defendants from engaging in the same type of conduct
+and activities as described herein; and
+c) Temporarily enjoining ROTHSTEIN, EDWARDS and L.M., from
+the continuation of the Civil Actions brought against EPSTEIN
+until criminal charges have been formally brought against RRA
+and/or any of the Defendants, such that EPSTEIN may be
+allowed to evaluate whether a stay or dismissal of all Civil Actions
+against him is merited.
+68. EPSTEIN further seeks an award of his reasonable attorney's fees and costs,
+and such other relief that this Court deems appropriate.
+WHEREFORE, Plaintiff EPSTEIN respectfully demands the entry of a judgment for
+the relief sought and damages against the named Defendants.
+Count III - Abuse of Process -
+69. Plaintiff realleges and incorporates paragraphs 1 through 53 as if fully set forth
+herein.
+
+
+Page 34
+70. After instituting the Civil Actions against EPSTEIN, the actions of Defendants,
+ROTHSTEIN, EDWARDS and L.M. as alleged in paragraphs 9 through 53 herein,
+constitute an illegal, improper or perverted use of process.
+71. ROTHSTEIN, EDWARDS and L.M. possessed ulterior motives or purposes in
+exercising such illegal, improper, or perverted use of process.
+72. As a result of ROTHSTEIN, EDWARDS and L.M.'s actions, EPSTEIN suffered
+damages.
+WHEREFORE, Plaintiff EPSTEIN respectfully demands the entry of a judgment for
+damages against all the named Defendants.
+Count IV - Fraud
+73. Plaintiff realleges and incorporates paragraphs 1 through 53 as if fully set forth
+herein.
+74. ROTHSTEIN, by and through Defendant EDWARDS and L.M. made false
+statements of fact to EPSTEIN and his attorneys and agents, known to be false at the
+time made, and/or intentionally concealed material information from EPSTEIN and his
+attomeys and agents, for the purpose of inducing EPSTEIN to act in reliance thereon.
+75. EPSTEIN did so act on the misrepresentation and/or concealment by incurring
+additional attomey's fees,
+costs, and expenses in aggressively defending the civil
+actions whereas in reality, because the Civil Actions against Plaintiff were being
+exploited and over-valued so as to lure additional investors and to attempt to extort as
+much money as possible from EPSTEIN so as to continue the massive fraud.
+
+
+Page 35
+WHEREFORE Plaintiff EPSTEIN demands judgment against Defendants for
+damages incurred and for any other relief to which he is entitled under the law.
+Conspiracy to Commit Fraud
+76. Plaintiff realleges and incorporates paragraphs 1 through 53, and 74 and 75 as if
+fully set forth herein.
+77. ROTHSTEIN, EDWARDS and L.M. conspired to commit a fraud upon EPSTEIN.
+78. ROTHSTEIN, EDWARDS and L.M. combined by and through concerted action
+as detailed herein to accomplish an unlawful purpose or accomplish some purpose by
+unlawful means. The unlawful purpose was, among other things, the orchestrating and
+continuation of the massive fraudulent Ponzi scheme and receipt of monies for the
+continuation of the scheme. The unlawful means includes, but is not limited to, the use
+of the Civil Actions against EPSTEIN in an unlawful, improper, and fraudulent manner.
+79. As a direct and proximate result of ROTHSTEIN, EDWARDS and L.M.'s
+conspiracy to defraud EPSTEIN, EPSTEIN suffered damages.
+WHEREFORE Plaintiff EPSTEIN demands judgment against Defendants for
+damages incurred and for any other relief to which he is entitled under the law.
+Jury Trial
+Plaintiff demands Jury Trial on all issues so triable.
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+
+
+Page 36
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+303 Banyan Blvd., Suite 400
+West Palm Beach, FL 33401
+561-842-2820
+Fax: 561-253-0154
+(Attorneys for Plaintiff)
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/ebb5c386fbf582c5eef85c28a3b432015309986d4e6982b4e519738c46e824b8.receipt.json b/vision-fixhub/ds9-unparsed-05/ebb5c386fbf582c5eef85c28a3b432015309986d4e6982b4e519738c46e824b8.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e407bbaa1460d4726a3addd173a9af1b08ee497d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ebb5c386fbf582c5eef85c28a3b432015309986d4e6982b4e519738c46e824b8.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1324,
+  "dataset": "marble-joined",
+  "doc_id": "ebb5c386fbf582c5eef85c28a3b432015309986d4e6982b4e519738c46e824b8",
+  "engine": "marble-apple-vision",
+  "event_count": 44,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "cae12bbfc11d262b71017927a9c963308650d0fe0e830c1c4836319971edaf08",
+  "output_sha256": "afa81bdb63a82bad245e8b50f2cef0ee55d9ae2f299999919a08b45b529739a4",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ec22cf40d7ffd15e3e139516fb854d95a25abbf58bb6f2ad34438cab14af54d9.md b/vision-fixhub/ds9-unparsed-05/ec22cf40d7ffd15e3e139516fb854d95a25abbf58bb6f2ad34438cab14af54d9.md
new file mode 100644
index 0000000000000000000000000000000000000000..4624cfe668bd10952094ba9ae8f1e3605bf04e5e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ec22cf40d7ffd15e3e139516fb854d95a25abbf58bb6f2ad34438cab14af54d9.md
@@ -0,0 +1,5037 @@
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOES #1 and #2
+UNITED STATES
+JOINT STATEMENT OF UNDISPUTED FACTS
+The parties hereby stipulate and agree that the following facts are not in dispute and may
+be accepted as true:
+1. Between about 2001 and 2006, defendant Jeffrey Epstein (a billionaire with significant
+political connections) sexually abused more than 40 enticed into prostitution minor girls at his
+mansion in West Palm Beach, Florida, and elsewhere. Among the girls he sexually abused so
+enticed were Jane Doe #1 and Jane Doe #2. Because Epstein, through others, used a means of
+interstate commerce and knowingly traveled in interstate commerce to engage in this conduct,
+to abuse Jane Doe #1 and Jane Doe #2 (and the other victims), he committed violations of federal
+law, specifically repeated violations of 18 U.S.C. § 2422.
+2. In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of
+Investigation ("FBI") opened an investigation into allegations that Jeffrey Epstein ("Epstein")
+and his personal assistants had used facilities of interstate commerce to induce young girls
+between the ages of thirteen and seventeen to engage in prostitution, among other offenses. The
+case was presented to the United States Attorney's Office for the Southern District of Florida,
+which accepted the case for investigation. The Palm Beach County State Attorney's Office was
+
+
+also investigating the case Epstein. See Declaration of Bradley J. Edwards, Esq. at 99 1-2
+(hereinafter "Edwards Declaration").
+3. The FBI determined that beth Jane Doe #1 and Jane Doe #2 were victims of sexual assaults
+by Epstein while they were minors beginning when they were approximately fourteen years of
+age and approximately thirteen years of age respectively. Edwards Deelaration at 11 2.
+4. On about June 7, 2007, FBI agents hand-delivered to Jane Doe #1 a standard CVRA-victim
+notification letter.
+See Edwards Declaration, Exhibit "A." The notification promises that the
+Justice Department would makes its "best efforts" to protect Jane Doe #1's rights, including
+"[t]he reasonable right to confer with the attorney for the United States in the case" and "to be
+reasonably heard at any public proceeding in the district court involving ... plea ...." The
+notification further explained that "[a]t this time, your case is under investigation." That
+notification meant that the FBI had identified Jane Doe #1 as a potential victim of a federal
+offense. and as someone protected by the CVRA.
+5. On about August 11, 2007, Jane Doe #2 received a standard CVRA victim notification letter.
+See Edwards Declaration, Exhibit "B." The notification promised that the Justice Department
+would makes its "best efforts" to protect Jane Doe #2's rights, including "[t]he reasonable right
+to confer with the attorney for the United States in the case" and "to be reasonably heard at any
+public proceeding in the district court involving ... plea...." The notification further explained
+that "[a]t this time, your case is under investigation." That notification meant that the FBI had
+identified Jane Doe #2 as a potential victim of a federal offense. and as someone protected by
+the CVRA.
+6. Early in During the investigation, the FBI agents and the Assistant U.S. Attorney had several
+meetings met with Jane Doe #1. Jane Doe #2 was represented by counsel that was paid for by
+
+
+the criminal target Epstein and, accordingly, all contact was made through that attorney. Jane
+Doe #2 was openly hostile to the investigation, and told investigators that she was not a
+victim of any offense, that Epstein was an "awesome man," and that she would consider
+marrying Epstein. Jane Doe #2 actively avoided law enforcement's attempts to secure her
+cooperation with the investigation and contacted other potential witnesses and victims to
+advise them against cooperating with the authorities. Edwards Declaration at 91 5.
+In and around September 2007, plea discussions took place between Jeffrey Epstein,
+represented by numerous attorneys (including lead criminal defense counsel Jay Lefkowitz), and
+the U.S. Attorney's office for the Southern District of Florida [.] represented primarily by
+Assistant U.S. Attorney A. Marie Villafaña. The plea discussions generally began from the
+premise that Epstein would plead guilty at least one federal felony offense surrounding his sexual
+assaults of more than 40 miner girls. From there, the numerous defense attorneys progressively
+negotiated more favorable plea terms so that Epstein would ultimately plead These plea
+negotiations eventually resulted in Epstein pleading guilty to enly two state court felony
+offenses with a recommendation of 18 months' imprisonment. and would serve only county
+jail time. Many of the negotiations are reflected in e-mails between Lefkowitz and Villafaña.
+Copies Parts of the correspondence are attached as Exhibit J to the Edwards Declaration accompanying
+this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates number
+stamp).' Because Epstein has moved to keep these documents from the public, they are at this
+time filed under seal with the Court.
+• Through diligent efforts, e- Counsel for Jane Doe #1 and Jane Doe #2 received copies of half of the e
+mail correspondence (the half reflecting Villafaña's communications to defense counsel) via discovery
+requests served upon counsel for Epstein in connection with Jane Doe #1 and Jane Doe #2's civil
+suits against Epstein on about June 30, 2010. See Edwards Declaration at 91920-22.
+
+
+8. At the time of plea discussions, AUSA Villafana had drafted the U.S. Attorney's Office had
+an 82-page prosecution memorandum outlining numerous federal sexual offenses committed by
+Epstein, and had prepared drafted a 53-page indictment. for numerous federal offenses. U.S.
+Attorney's Correspondence at 4.
+In September 2007, Assistant U.S. Attorney (AUSA) A. Marie Villafaña, in an effort to
+avoid prosecuting Epstein for his numerous
+-sexual offenses against children, propesed to
+Epstein's attorneys that rather than plea to any charges relating to him molesting children,
+Epstein should instead plead to a single assault charge involving a telephone call made by
+Epstein while he was on his private jet. During the telephone call, Epstein warned his personal
+assistant, Lesley Groff, against turning over doeuments and electronie evidence responsive to a
+subpoena issued by a federal grand jury in the Southern Distriet of Florida investigating
+Epstein's sex offenses. U.S. Attorney's Correspondence at 49, 58.
+10. The correspondence also shows that AUSA Villafaña was interested in finding a place to
+conelude a plea bargain that would effectively keep the vietims from learning what was
+happening through the press. She wrote in an e-mail to defense counsel: "On an 'avoid the
+press' note, I believe that Mr. Epstein's airplane was in Miami on the day of the Ms. Groff
+telephone call. If he was in Mimi-Dade County at the time, then I can file the charge in the
+District Court in Miami, which will hopefully cut the press coverage significantly."
+-U.S.
+Attorney's Cerrespendence at 29.
+-Ms. Villafaña was aware that most of the vietims of Epstein,
+ineluding Jane Doe fl and Jane Doe #2, resided outside the Miami area.
+H1.
+On about September 24, 2007, Assistant U.S. Attorney A. Marie Villafaña sent an e-mail
+to Jay Lefkowitz, criminal defense counsel for Epstein, regarding the agreement, a copy of
+which is attached hereto as Exhibit
+_ Due to the confidentiality clause in the Agreement,
+
+
+the e-mail stated: that the Government and Epstein's counsel would negetiate between
+themselves about what information would be disclosed to the vietims about the agreement:
+Thank you, Jay. | have forwarded your message only to Alex [Acesta], Andy,
+and Roland. I don't anticipate it going any further than that. When I receive the
+originals, I will sign and return one copy to you. The other will be placed in the
+case file, which will be kept confidential since it also contains identifying
+information about the girls.
+When we reach an agreement about the attorney representative for the girls, we
+can diseuss what I can tell him and the girls about the agreement. I know that
+Andy promised Chief Reiter an update when a resolution was achieved. ..
+Kolando is calling, but Kelando knows not to tell Chief Reiter about the money
+issue, just about what erimes Mr. Epstein is pleading guilty to and the amount of
+time that has been agreed to. Rolando also is telling Chief Reiter not to disclose
+the outeome to anyone.
+U.S. Attorney's Correspondenee at 153 (emphases added).
+12. On about September 25, 2007, AUSA Villafaña sent an e-mail to Lefkowitz, a copy of
+which is attached hereto as Exhibit _ stating: "And can we have a conference call to diseuss
+what I may diselose to ... the girls regarding the agreement." U.S. Attorney's Correspondence
+at 156.
+13. On about September 26, 2007, AUSA. Villafaña sent an e-mail to Lefkowitz, a copy of
+which is attached hereto as Exhibit
+-. in which she stated: "Hi Jay Can you give me a call
+at 561 209 [xxxx] this morning? I am meeting with the agents and want to give them their
+marehing orders regarding what they can tell the girls." U.S. Attorney's Correspondence at 359.
+The reasonable inference is that the "marching orders" agreed to between the Government and
+Epstein's defense counsel was that no mention would be made of the non prosecution agreement
+between the U.S. Attorney's Office and Epstein, as no subsequent mention was made to the
+vietims of the non-prosecution agreement.
+
+
+14.
+On about September 27, 2007, Assistant U.S. Attorney A. Marie Villafaña sent an e-mail
+to Lefkowitz regarding an attorney who was under discussion to be a representative of
+victims of Epstein civil litigation, a copy of which is attached hereto as Exhibit _ revealed
+to an attorney (Bert Ocariz), who was under diseussion to be a representative of vietims of
+Epstein's sexual abuse in civil litigation, that the government was in the process of reaching a
+non prosecution agreement with Epstein. An e-mail confirming these diselosures stated: "Bert's
+firm has raised a number of good questions about how they are going to get paid." U.S.
+Attorney's Correspondence at 161. The e-mail went on to state: "I told Bert that as part of our
+agreement we (the federal government) are not going to indiet Mr. Epstein, but give him an idea
+of the charges that we had planned to bring as related to 18 USC 2255." Id. The e-mail also
+asked permission from Epstein's counsel to send to Ocariz a copy of parts of the plea agreement:
+"With respeet to question 2 [a question from Oeariz regarding "[when will it be possible to see
+the plea agreement so that we understand exaetly what Epstein concedes to in the civil case?], de
+I have your permission to send Bert just that section of the plea agreement that applies to the
+damages elaims (1 would recommend sending paragraphs 7 through 10, or at least 7 and 8)?" Id.
+75. On about September 25, 2007, ASUA AUSA Villafaña sent a letter to Jay Jefkowitz that
+stated: in which she suggested that the vietims should be represented by someone who was not
+an experienced personal injury attorney: "They [the other lawyers under consideration] are all
+very good personal injury lawyers, but I have concerns about whether there would be an inherent
+tension becaue they may feel that they might make more money... if they proceed outside the
+terms of the pela agreement. (Sorry
+-I just have a bias against plaintiffs' attorneys.)" U.S.
+Attorney's Correspondence at 157. Villafaña continued to push Ocariz as the best choice, in part
+
+
+beeause it would reduce publieity: "One nice thing about Bert [Ocariz) is that he is in Miami
+where teher has been almost no coverage of the ease." Id.
+16. In a letter later sent by Jay Lefkowitz to the U.S. Attorney for the Southern Distriet of
+Florida, Lefkowitz stated that ASUA Villafaña had "assiduously" hidden from him the faet that
+Bert Ocariz was a friend of Villafaña's boyfriend. U.S. Attorney's Correspondence at 267.
+Lefkowitz also stated that Villafaña had misleadingly used the term "friend" rather than the more
+accurate term "boyfriend" to deseribe who had recommended Ocariz. Id. at 268. Lefkowitz
+further stated the Villafaña's boyfriend had a business relationship with Ocariz and that the
+boyfriend would have financially benefitted from the presumably luerative referral of sexual
+assault cases against Epstein to Deariz. On December 13, 2007, Villafaña wrote a letter te
+Lefkowitz to deny these accusations. In the letter, Villafaña stated: "... I am surprised by your
+allegations regarding my role because I thought that we had worked very well together in
+resolving this dispute. I also am surprised because I feel that I bent over backwards to keep in
+mind the effeet that the agreement would have on Mr. Epstein and to make sure that you (and he)
+understoed the repercussions of the agreement." Id.
+17. On about September 24, 2007, Epstein and the U.S. Attorney's Office reached an
+agreement whereby the United States would defer federal prosecution in favor of prosecution by
+the State of Florida. Epstein and the U.S. Attorney's Office accordingly entered into a "Non-
+Prosecution Agreement" (NPA) reflecting their agreement. Most signifieantly, + The NPA gave
+Epstein a promise that he would not be prosecuted for a series of federal felony offenses
+involving the enticement into prostitution of a large number of minor girls. involving his
+sexual abuse-of more than 30 minor girls. The NPA instead allowed Epstein to plead guilty to
+two state felony offenses for solicitation of prostitution and procurement of minors for
+
+
+prostitution. The NPA also set up a procedure whereby a victim of Epstein's sexual abuse could
+obtain an attorney representative to proceed with a civil claim against Epstein, provided that the
+victim agreed to proceed exclusively under 18 U.S.C. § 2255 (i.e., which provided that the each
+victim would recover agreed to seek no more less than $150,000 in damages against Epstein -
+an amount that Epstein argued later was limited to no more than $50,000). See Edwards
+Declaration, Exhibit "C" (copy of the non-prosecution agreement). The agreement was signed
+by Epstein and his legal counsel, as well as the U.S. Attorney's Office, on about September 24,
+2007.
+18. A provision in the non-prosecution agreement made the agreement confidential seeret. In
+particular, the agreement stated: "The parties anticipate that this agreement will not be made part
+of any public record. If the United States receives a Freedom of Information Act request or any
+compulsory process commanding the disclosure of the agreement, it will provide notice to
+Epstein before making the disclosure." By entering into such a confidentiality agreement, the
+U.S. Attorney's Office put itself in a position that netifying the erime vietims (including Jane
+Doe #l and Jane Doe #2) of the non-prosecution agreement would violate terms of the
+agreement
+specifically the confidentiality provision. Accordingly, from September 24, 2007
+through at least June 2008 a period of more than nine months -- the U.S Attorney's Office did
+not notify any of the vietims of the existence of the nen prosecution agreement.
+19.
+A reasonable inference from the evidence is that the U.S. Attorney's Office wanted the
+non-prosecution agreement kept from publie view because of the intense public criticism that
+would have resulted from allowing a politically connected billionaire who had sexually abused
+more than 40 minor girls to escape from federal prosecution with only a county court jail
+
+
+sentence and because of the possibility that the vietims could have objected to the agreement in
+court and prevented its consummation.
+20. The Non-Prosecution Agreement that had been entered into between the U.S. Attorney's
+Office and Epstein was subsequently modified by an October 2007 Addendum and a December
+19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez. See Supplemental
+Declaration of A. Marie Villafaña, doc. #35, at 1; U.S. Attorney's Correspondence at 234-37.
+The U.S. Attorney's Office did not notify any of the vietims of the existence of these
+modifications of the agreement through at least June 2008—a period of more than six months.
+On about August 14, 2008, Epstein's defense counsel told the U.S. Attorney's Office that they
+did not consider the December 19, 2007, letter to be operative. Id.
+21.
+In October 2007, shortly after the initial plea agreement was signed, Jane Doe #1 was
+contacted to be advised regarding the resolution of the investigation. On October 26, 2007,
+Special Agents E. Nesbitt Kuyrkendall and Jason Richards met in person with Jane Doe #1. The
+Special Agents explained that Epstein would plead guilty to state charges, he would be required
+to register as a sex offender for life, and he had made certain concessions related to the payment
+of damages to the victims, including Jane Doe #1. During this meeting, the agents explained
+that this would end the federal investigation of the case and no federal charges would be
+filed. the Special Agents did not explain that an agreement had already been signed that
+precluded any prosecution of Epstein for federal charges. The agents could not have revealed
+this part of the non-prosecution agreement without violating the terms of the non-prosecution
+agreement. Whether the agents themselves had been informed of the existence of the nonprosecution agreement by the U.S. Attorney's Office is not certain. Beeause the plea agreement
+
+
+had already been reached with Epstein, the agents made no attempt to secure Jane Dee #l's view
+on the proposed resolution of the case. Edwards Declaration at 9l 7
+22. Jane Doe #1's perception of the explanation provided by the Special Agents was that only
+the State part of the Epstein investigation had been resolved, and that the federal investigation
+would continue, possibly leading to a federal prosecution. Edwards Declaration at 9l 8.
+23.
+On about November 27, 2007, Assistant U.S. Attorney Jeff Sloman sent an e-mail to Jay
+Lefkowitz, defense counsel for Epstein, a copy of which is attached hereto as Exhibit_ The
+e-mail stated: that the U.S. Attorney's Office had an obligation to notify the vietims about the
+plea agreement:
+The United States has a statutory obligation (Justice for All Aet of 2004) to notify
+the vietims of the anticipated upeoming events and their rights associated with the
+agreement entered into by the United States and Mr. Epstein in a limely fashion.
+Tomorrow will make one full week since you were formally notified of the
+seleetion. I must insist that the vetting process come to an end. Therefore, unless
+you provide me with a good faith objection to Judge-
+-seleetion [as speciał
+master for selecting legal counsel for vietim pursuing claims against Epstein] by
+COB tomorrow, November 28, 2007, I will authorize the notification of the
+vietims. Should you give me the go-head on Podhurst and Jesephsberg selection
+by COB tomorrow, 1 will simultaneously send you a draft of the letter. I intend to
+notify the vietims by letter after COB Thursday, November 29'*
+U.S. Attorney's Correspondence at 255 (emphasis rearranged).
+24. On about November 29, 2007, Assistant U.S. Attorney A. Marie Villafaña sent a draft of a
+crime victim notification letter to Jay Lefkowitz, defense counsel for Jeffrey Epstein. The
+notification letter explained: "I am writing to inform you that the federal investigation of Jeffiey
+Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an
+agreement containing the following terms ...." The letter then went on to explain that Epstein
+would plead guilty to two state offenses and receive an 18 month sentence. The letter did not
+explain that, as part of the agreement with Epstein, the Justice Department had previously agreed
+
+
+not to prosecute Epstein for any of the numerous federal offenses that had been committed. U.S.
+Attorney's Correspondence at 256-59.
+25. Apparently because of concerns from Epstein's attorneys, Because Epstein's attorneys
+sought higher review of the enforceability of the Non-Prosecution Agreement, the U.S.
+Attorney's Office never sent the proposed victim notification letter discussed in the previous
+paragraph to the victims.
+Instead, a misleading letter stating that the case was "currently under
+investigation" (described below) was sent in January 2008 and May 2008. At no time before
+reaching non-prosecution agreement did the Justice Department contact any vietims, including
+for example Jane Doe #1, about their views on the nen prosecution.
+26. On about December 6, 2007, Jeffrey H. Sloman, First Assistant U.S. Attorney sent a letter to
+Jay Lefkowitz,, a copy of which is attached hereto as Exhibit _ noting the U.S. Attorney's
+Office's legal obligations to keep vietims informed of the status of plea negotiations with
+Epstein. The letter stated:
+Finally, let me address your objections to the draft Vietim Notification Letter:
+You write that you don't understand the basis for the Office's belief that it is
+appropriate to notify the victims. Pursuant to the "Justice for All Aet of 2004,"
+fanother name from the CVRA] erime victims are entitled to: "The right to
+reasonable, accurate, and timely notice of any public court proceeding ...
+involving the crime' and the 'right not to be exeluded from any such publie court
+proceeding ....' 18 U.S.C. § 377|(a)(2) & (3). Section 3771 also commands
+that 'employees of the Department of Justice.. engaged in the detection,
+investigation, or prosecution of erime shall make their best efforts to see that
+erime vietims are notified of, and accorded, the rights deseribed in subeetion (a).'
+18 U.S.C. § 3771(c)(1)....
+Our Non-Prosecution Agreement resolves the federal investigation by allowing
+Mr. Epstein to plead to a state offense. The vietims identified through the federal
+investigation should be appropriately informed, and our Non Prosecution
+Agreement does not require the U.S. Attorney's Office to forego its legal
+obligation.
+U.S. Attorney's Correspondence at 191-92 (emphasis added).
+
+
+27. Despite this recognition of its obligation to keep vietims "appropriately informed" about the
+non-prosecution agreement, the U.S. Attorney's Office did not follow through and inform the
+vietims of the non prosecution agreement. To the contrary, as diseussed below, it continued to
+tell the vietims that the case was "under investigation." Edwards Deelaration at 1| 4 and 9 12.
+28.
+On December 13, 2007, A. Marie Villafaña sent a letter to Jay Lefkowitz, defense
+counsel for Epstein,, a copy of which is attached hereto as Exhibit_
+_.rebutling charges that
+had apparently been made against her by the Epstein defense. The letter stated that a federal
+indictment against Epstein "was postponed for more than five months to allow you and Mr.
+Epstein's other attorneys to make presentations to the Office to convince the Office not to
+prosecute." The letter also recounted that "You and I spent hours negotiating the terms [of the
+non prosecution agreement], including when to use 'a' versus 'the' and other minutiae. When
+you and I could not reach agreement, you repeatedly went over my head, involving Messrs.
+Lourie, Menchel, Sloman, and Acosta in the negotiations at various times." U.S. Attorney's
+Correspondence at 269.
+29. The December 13, 2007, letter also reveals that the Justice Department stopped making
+vietim notifications because of objeetions from Epstein's criminal defense counsel: "Three
+vietims were notified shortly after the signing of the Non-Prosecution Agreement of the general
+terms of the Agreement.
+-You raised objections to any victim notification. and no further
+notifications were done." U.S. Attorney's Correspondence at 270 (emphasis added).
+30.
+Following the signing of the Agreement and the modifications thereto, Epstein's
+performance was delayed while he sought higher level review within the Department of Justice.
+See U.S. Attorney's Correspondence passim.
+
+
+31. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advising
+them that "[t]his case is currently under investigation. This can be a lengthy process and we
+request you[r] continued patience while we conduct a thorough investigation." See Doc. #14
+(attachments 3 and 4 to declaration of A. Marie Villafaña) (emphasis added). The statement in
+the notification letter was false.
+The case was not currently "under investigation." To the
+contrary, the case had been resolved by the non prosecution agreement entered into by Epstein
+and the U.S. Attorney's Office diseussed previously. Moreover, the FBI did not notify Jane Doe
+#l of Jane Doe t2 that a plea agreement had been reached previously, and that part of the
+agreement was a non prosecution agreement with the U.S. Attorney's Office for the Southern
+Distriet of Florida. Edwards Deelaration at 9 9.
+32.
+In early 2008, Jane Doe #1 and Jane Doe 12 came to believe that eriminal prosecution of
+Epstein was extremely important. They also desired to be consulted by the FBI and/or other
+representatives of the federal government about the prosecution of Epstein. In light of the letters
+that they had received around January 10, they believed that a criminal investigation of Epstein
+was on-going and that they would be contacted before the federal government reached any final
+resolution of that investigation. Edwards Deelaration at 110.
+33. On about February 25, 2008, Assistant U.S. Attorney Sloman sent an e-mail to Jay
+Lefkowitz,, a copy of which is attached hereto as Exhibit Epstein's criminal defense
+counsel, explaining that the Justice Department's Child Exploitation Obscenity Section (CEOS)
+had agreed to review Epstein's objections to the propesed plea agreement that had been reached
+with the U.S. Attorney's Office for the Southern District of Florida. The letter indicated that,
+should CEOS reject Epstein's objections to the agreement, then "Mr. Epstein shall have one
+week to abide by the terms and conditions of the September 24, 2007 Agreement as amended by
+
+
+teller from United States Attorney Acosta to Jay Lefkowitz." U.S. Attorneys Correspondence at
+290-91.
+34.
+In about April 2008, Jane Doe #1 contacted the FBI because Epstein's counsel was
+attempting to take her deposition and private investigators were harassing her. Assistant U.S.
+Attorney A. Marie Villafaña secured pro bono counsel to represent Jane Doe #1. Pro bono
+counsel was able to assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafaña
+secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims'
+Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During
+the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached.
+35. On May 30, 2008, another of Mr. Edwards's clients who was recognized as an a
+potential victim of Epstein victim by the U.S. Attorney's Office, received a letter from the FBI
+advising her that "[t]his case is currently under investigation. This can be a lengthy process and
+we request your continued patience while we conduct a thorough investigation." The statement
+in the notification letter was false. The case was not currently "under investigation." To the
+contrary, the case had been resolved by the non prosecution agreement entered into by Epstein
+and the U.S. Attorney's Office diseussed previously. Edwards Declaration at 1l 12.
+36.
+In mid-June 2008, Mr. Edwards contacted AUSA Villafaña to inform her that he
+represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to provide
+information about the federal crimes committed by Epstein, hoping to secure a significant federal
+indictment against Epstein. AUSA Villafaña and Mr. Edwards discussed the possibility of
+federal charges being filed. At the end of the call, AUSA Villafaña asked Mr. Edwards to send
+any information that he wanted considered by the U.S. Attorney's Office in determining whether
+to file federal charges. Because of the confidentiality provision that existed in the plea
+
+
+agreement, Mr. Edwards was not informed that previously, in September 2007, the U.S.
+Attorney's Office had reached an agreement not to file federal charges. Mr. Edwards was also
+not informed that resolution of the criminal matter was imminent. Edwards Declaration at fl 13.
+37.
+On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA Villafaña received a copy
+of Epstein's proposed state plea agreement and learned that the plea was scheduled for 8:30 a.m.,
+Monday, June 30, 2008. AUSA Villafaña and the Palm Beach Police Department attempted to
+provide notification to victims in the short time that Epstein's counsel had provided. Attorney
+Edwards was called to provide notice to his clients regarding the hearing. AUSA Villafaña did
+not tell Attorney Edwards that the guilty pleas in state court would bring an end to the possibility
+of federal prosecution pursuant to the plea agreement. Edwards Deelaration at 9/ 14. AUSA
+Villafaña strongly encouraged Attorney Edwards and his client to attend and address the
+Court at sentencing if they so desired.
+38.
+On June 30, 2008, AUSA Villafaña sent an e-mail to Jack Goldberger, criminal defense
+counsel for Epstein, a copy of which is attached hereto as Exhibit
+_that stated: "Jack: The
+FBI has received several ealls regarding the Non-Prosecution Agreement. I do not know
+whether the title of the document was diselosed when the Agreement was filed under seal, but
+the FBI and our office are declining comment if asked." U.S. Attorney's Correspondence at 321.
+39.
+On July 3, 2008, Mr. Edwards sent to AUSA Villafaña a letter. See Affidavit of Bradley
+J. Edwards, Esq., at 15 (attachment 2). In the letter, Mr. Edwards indicated his client's desire
+that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his
+clients: "We urge the Attorney General and our United States Attorney to consider the
+fundamental import of the vigorous enforcement of our Federal laws. We urge you to move
+forward with the traditional indictments and criminal prosecution commensurate with the crimes
+
+
+Mr. Epstein has committed, and we further urge you to take the steps necessary to protect our
+children from this very dangerous sexual predator." When Mr. Edwards wrote this letter, he was
+still unaware that a non-prosecution agreement had been reached with Epstein|.J - a faet that
+continued to be concealed from him (and the victims) by the U.S. Attorney's Office. Mr.
+Edwards first saw a reference to the NPA on or after July 9, 2008, when the Government filed its
+responsive pleading to Jane Doe's emergency petition. That pleading was the first publie
+mention of the non prosecution agreement and the first disclosure to Mr. Edwards (and thus to
+Jane Doe #1 and Jane Doe #2) of the possible existence of a non prosecution agreement:
+Edwards Declaration at 9 15.
+40.
+On July 9, 2008, AUSA Villafaña sent a victim notification to Jane Doe #1 via her
+attorney, Bradley Edwards. Edwards Declaration, Exhibit "H." That notification contains a
+written explanation of some of the terms of the agreement between Epstein and the U.S.
+Attorney's Office. A full copy of the terms was not provided. A notification was not provided
+to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the United
+States was prepared to name in an indictment. As a result, Jane Doe #2 never received a
+notification a letter about the agreement. The notification did not mention the nen prosecution
+agreement with the U.S. Attorney's Office. Edwards Declaration at 9l 16.
+41. On July 9, 2008, AUSA Villafaña filed a sworn declaration with the Court in connection
+with the case (doc. #14). The declaration purported to recount limit parts of the non-prosecution
+agreement and stated that "these provisions were discussed" with several victims, including Jane
+Doe #1. Id. at 4.
+42.
+On July 11, 2008, the Court held a hearing on Jane Doe #1 and Jane Doe #2's Emergency
+Petition for Enforcement of Rights. During the hearing, the Government conceded that Jane Doe
+
+
+#1 and Jane Doe #2 were "victims" within the meaning of the Crime Victim's Rights Act. Tr. at
+14-15.
+43. During the July I hearing, the Court and the parties diseussed the fact that the petition
+should not be treated as an "emergency" petition because there was not any particular rush to
+ruling on it. Tr. at 24-25. The Court further diseussed a need to "hav [e] a complete record, and
+this is going to be an issue that's ... going to go to the Eleventh Circuit, [s] it] may be better to
+have a complete record as to what your position is and the government's is as to what actions
+were taken. And I den't know if I have enough information, based on Ms. Villafana's affidavit
+or I need additional information. And beeause it is not an emergeney, I don't have to do
+something quickly, we can play it b[y] ear and make this into a more complete recerd for the
+court of appeals." Tr. at 25-26. Counsel for Jane Doe #1 and Jane Doe H2 explained: " ....
+Your Honor is correct in stating that it is not an emergeney and it doesn't need to happen today.
+And, I will confer with the government on this and if evidence needs to be taken, it [ean] be
+taken at a later date. It doesn't seem like there will be any prejudice to any party [from delay)."
+Tr. at 26. The hearing coneluded: "So I'II let beth of you confer about whether there is a need
+for any additional evidence to be presented. Let me know one way or the other. If there is, we'll
+schedule a hearing. If there isn't and you want to submit some additional stipulated information,
+de that, and then I'll take care of this in due course." Tr. at 32. The Court then adjourned, taking
+the victims' petition under advisement.
+44. The U.S. Attorney's Office and the fictims then attempted to reach a stipulated set of faets
+underlying the case. The U.S. Attorney's Office set a proposed set of faets, and the vietims sent
+a counter-proposal.
+Rather than respond to the vietims' counter proposal, however, the U.S.
+Attorney's Office suddenly reversed course. (Doc. #19 at 2). On July 29, 2008, it filed a Notice
+
+
+to Court Regarding Absence of Need for Evidentiary Hearing (doc. #17). The Government teek
+the position that, because no federal criminal charges had been filed in the Southern Distriet of
+Florida, no additional evidence was required to decide the petition before the Court.
+45. On August 1, 2008, Jane Doe I/land Jane Doe #2 filed (doe. #19) a response to the
+Government's "Notice."
+- In the response, Jane Doe #1 and Jane Doe #2 gave a proposed
+statement of facts surrounding the case. The proposed statement of fact was based on the
+information available to the vietims at that time. The proposed statement of faets highlighted the
+faet that the Government had signed a non-prosecution agreement containing an express
+confidentiality provision, which prevented the Government from disclosing the agreement to
+them and other vietims. Id. at 5. The response also noted that the Court had taken the victims"
+petition under advisement. The response further noted that the Government had not attempted to
+work with the vietims to draft a full set of undisputed faets and had refused the victims' efforts to
+obtain documents relevant to the case. Id. at 9.. The vietims response also requested that the
+Court direct the Government to confer with the vietims regarding the undisputed faets of the
+ease, produce the nen-prosecution agreement at issue in the case, and produce an FBI Repert of
+Interview with Jane Doe #l. The response also requested that the Court enter judgment for the
+vietims' finding a violation of rights and schedule a hearing on the appropriate remedy. Id. at 14.
+46. On August 14, 2008, the Court held a hearing on the case. During that hearing, the U.S.
+Attorney's Office conceded "we do feel bound by the confidentiality provision such that we
+could not voluntarily disclose this non prosecution agreement without court order compelling us
+to do so." Tr. at 8. The Office went on to further concede that it could not justify depriving the
+vietims of the opportunity to see the agreement. Id. at 14. The hearing concluded without any
+sehedule or deadlines being put in place.
+
+
+47. On October 9, 2008, Bradley J. Edwards, counsel for Jane Doe #1 and Jane Doe H2, sent a
+letter to counsel for the U.S. Attorney's Office in this case advising that two possibly false
+statements had been made to the Court in the July 9*' sworn declaration of AUSA Villafaña. See
+Oct. 9, 2008, Letter from Bradley J. Edwards to Marie Villafaña at 1, Edwards Declaration,
+Attachment "I." First, while Ms. Villafaña had deseribed a term as being part of the plea
+agreement with Epstein, that term later became defunet, at least in the view of Epstein's
+attorneys (and apparently acceded to by the U.S. Attorney's Office). Second, Ms. Villafaña had
+said that "four victims [including Jane Doe #I] were contacted and these provisions were
+diseussed," it was not elear what provisions had in fact been discussed.
+48. On December 22, 2008, AUSA Marie Villafaña filed a supplemental affidavit, "correeting"
+the statement made in her July 8, 2008, declaration about the terms of the plea agreement (doe.
+#35). The supplemental affidavit stated that "part 3" of the agreement with defendant Epstein
+was, in the view Epstein' legal counsel, no longer operative. The supplemental affidavit,
+however, did not clarify what terms of the agreement had been discussed.
+49. On April 9, 2009, counsel for Jane Doe #1 and Jane Doe #2 sent to the Court in this case
+(via the PACER system) a notice of a change of law firm affiliation. Doc. #37.
+50.
+In approximately May 2009, counsel for Jane Doe #l and Jane Doe H2 propounded
+discovery requests in both state and federal civil cases against Epstein, seeking to obtain
+correspondence between Epstein and prosecuters regarding his plea agreement information that
+the U.S. Attorney's Office was unwilling to provide to Jane Doe #1 and Jane Doe #2. Epstein
+refused to produce that information, and extended litigation to obtain the materials followed.
+Edwards Declaration at fl 20.
+
+
+51. Beeause of this extended litigation, Jane Dee #1 and Jane Doe #2 did not have access to
+important correspondence demonstrating a violation of their rights until June 30, 2010. On that
+day, counsel for Epstein sent to Bradley J. Edwards, Esq., legal counsel for Jane Doe #1 and Jane
+Doe 12, approximately 358 pages of e-mail correspondence between his legal counsel and the
+U.S. Attorney's Office for the Southern District of Florida regarding the plea agreement that had
+been negotiated between them.
+-See Edwards Deelaration, Attachment "J." These e-mails
+disclosed for the first time the extreme and unusual steps that had been taken by the U.S.
+Attorney's Office to avoid prosecuting Epstein and to avoid having the vietims in the case learn
+about the non-prosecution agreement that had been reached between Epstein and the
+Government. Litigation continues to this day to obtain the correspondence regarding the state
+prosecution and regarding what Epstein's attorneys said in the correspondence with the
+prosecutors. Edwards Declaration at Tl 22
+52. In mid July 2010, Jane Doe #1 and Jane Dee H2 settled their civil lawsuits against Mr.
+Epstein. Notice of this faet was promptly provided to the Court. Edwards Deelaration at xxx.
+53. On September 8, 2010, the Court entered an order stating that "[a]n examination of the
+docket reveals that no activity has taken place in this case since April of 2009. In light of the
+underlying settlements between the vietims and Mr. Epstein, it is hereby ordered and adjudged
+that this case is closed." Doe. #38.
+54. Promptly on the heels of this administrative order, on September 13, 2010, Jane Doe #1 and
+Jane Doe #2 filed a notice that they "intend to make subsequent filing in the case shortly. They
+accordingly request administrative reopening of the case and, if the Court deems it advisable, a
+scheduling conference with the U.S. Attorney's Office regarding the case." Doc. #39 at I. They
+further advised the Court that their settlements with Jeffrey Epstein in no way affected "their
+
+
+determination to move forward with the above-captioned CVRA action against a different entity
+- the U.S. Attorney's Office for the Southern District of Florida." Id. at 2. The pleading further
+advised that "TiJf the Court wishes to proceed to an expeditious conclusion to this Case, Jane Doe
+#1 and Jane Doe #2 have no objection to the Court setting up an expedited schedule for
+proceeding on the case." Id. The pleading further advised that the reason the vietims had not
+filed for summary judgment in the case was that they had been attempting to secure
+correspondence between the U.S. Attorney's Office and Epstein to corroborate their argument
+that the Office had violated their rights. They noted that they had just secured half of that
+correspondence two months earlier.
+Id. at 2. The vietim asked that, "if the Court deems it
+advisable, that a scheduling conference be set for this ease."
+55. At all times material to this statement of faets, it would have been practical and feasible for
+federal government to inform Jane Doe #1 and Jane Doe #2 of the details of the proposed nonprosecution agreement with Epstein, including in particular the fact that the agreement barred
+any federal eriminal prosecution. Edwards Deelaration at 1l 26.
+SO AGREED AND STIPULATED TO, THIS
+DAY OF DECEMBER, 2010.
+BRADLEY J. EDWARDS
+COUNSEL FOR PLAINTIFFS
+WIFREDO A. FERRER
+UNITED STATES ATTORNEY
+By:
+DEXTER LEE
+ASSISTANT U.S. ATTORNEY
+
+
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOES #1 and #2
+UNITED STATES
+STIPULATION
+The parties to this action, that is, Jane Doe #1, Jane Doe #2, and the United States of
+America, by and through their undersigned counsel, do hereby stipulate and agree that the
+following facts are true and correct and that no further evidentiary hearing is required with
+respect to the pending "Victim's Emergency Petition for Enforcement of Crime Victim
+Right Act, 18 U.S.C. § 3771.
+In 2006, at the request of the Palm Beach Police Department, the Federal
+Bureau of Investigation ("FBI") opened an investigation into allegations that Jeffrey
+Epstein ("Epstein") and his personal assistants had used facilities of interstate commerce to
+induce young girls between the ages of thirteen and seventeen to engage in prostitution,
+amongst other offenses. The case was presented to the United States Attorney's Office for
+the Southern District of Florida, which accepted the case for investigation.
+2.
+At the time that the investigation was opened, the Palm Beach County State
+Attorney's Office had presented evidence to a state grand jury, which had returned an
+
+
+indictment charging solicitation of prostitution. That charge made no reference to the
+ages of the minor victims and, upon conviction, did not require sex offender registration.
+Jane Doe #1 is a woman with initials C. W., and Jane Doe H2 is a woman with
+initials T.M. Both were victims of Epstein's while they were minors beginning when they
+were fifteen years old. Both Jane Does were identified through the Palm Beach Police
+Department's investigation of Epstein.
+4.
+Attached as Exhibits 1, 2, 3, and 4 to the Declaration of A. Marie Villafaña
+are true and correct copies of victim notification letters sent to Jane Does 1 and 2 from the
+United States Attorney's Office and the FBI.
+Throughout the investigation, the FBI agents and the Assistant U.S. Attorney
+had several meetings with Jane Doe #1. During those meetings, Jane Doe #1 never
+expressed a desire to be consulted prior to the resolution of the investigation. Jane Doe #2
+was represented by counsel and, accordingly, all contact was made through that attorney.
+That attorney never expressed that Jane Doe #2 wanted to be consulted prior to the
+resolution of the investigation.
+6.
+In September 2007, Epstein and the U.S. Attorney's Office reached an
+agreement whereby the United States would defer federal prosecution in favor of
+prosecution by the State of Florida, so long as certain basic preconditions were met, those
+included a conviction on a state sex offense that reflected that the victims were minors at
+the time the crimes occurred and that would require sex offender registration. Another
+key objective for the United States Attorney's Office was to preserve a federal remedy for
+"z°
+
+
+the young girls whom Epstein had sexually exploited. The Agreement contained an
+express confidentiality provision. The Agreement was subsequently modified in October
+and December 2007.
+Although individual victims were not consulted regarding the agreement,
+several had expressed concerns regarding the exposure of their identities at trial and they
+desired a prompt resolution of the matter. At the time the agreement and the
+modifications were signed in September, October, and December 2007, Jane Doe #2 was
+openly hostile to the prosecution of Epstein.
+8.
+In October 2007, shortly after the initial agreement was signed, Jane Doe #1
+was contacted to be advised regarding the resolution of the investigation. On October _
+2007, Special Agents E. Nesbitt Kuyrkendall and Jason Richards met in person with Jane
+Doe #1. The Special Agents explained that the investigation had been resolved, that
+Epstein would plead guilty to two state offenses, he would be required to register as a sex
+offender for life, and he had made certain concessions related to the payment of damages to
+the victims, including Jane Doe #1. Jane Doe #1 also was advised that Epstein would be
+entering a guilty plea in state court on October _
+_ 2007, although the October change of
+plea did not take place. During this meeting, Jane Doe #1 did not raise any objections to
+the resolution of the matter.
+Jane Doe #1 misunderstood the explanation provided by the Special Agents,
+believing that only the State part of the Epstein investigation had been resolved, and that
+the federal investigation would continue, possibly leading to a federal prosecution.
+"3°
+
+
+10.
+When Epstein's attorneys learned that some of the victims had been notified,
+they complained that the victims were receiving an incentive to overstate their involvement
+with Epstein in order to increase their damages claims. Following the signing of the
+Agreement and the modifications thereto, Epstein's performance was delayed while he
+sought to rescind the Agreement. Throughout that period, the FBI and the U.S. Attorney's
+Office maintained contact with the victims, to be prepared if Epstein were to renege on the
+agreement.
+11. After Jane Doe #1 had been notified of the terms of the agreement, but before
+Epstein performed his obligations, Jane Doe #1 contacted the FBI because Epstein's
+counsel was attempting to take her deposition and private investigators were harassing her.
+Assistant U.S. Attorney A. Marie Villafaña secured pro bono counsel to represent Jane
+Doe #1 and several other identified victims in connection with the criminal investigation.
+Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition.
+12. In mid-June 2008, Attorney Edwards contacted AUSA Villafaña to inform
+her that he represented Jane Doe #1 and, later, Jane Doe #2. Attorney Edwards asked to
+meet to provide information regarding Epstein. Attorney Edwards was asked to send any
+information that he wanted considered, but did not send anything.
+13. On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA Villafaña
+received a copy of Epstein's proposed state plea agreement and learned that the plea was
+scheduled for 8:30 a.m., Monday, June 30, 2008. AUSA Villafaña and the Palm Beach
+Police Department attempted to provide notification to victims in the short time that
+"4°
+
+
+Epstein's counsel had provided. Attorney Edwards was called to provide notice to his
+clients regarding the hearing.
+14. On July 9, 2008, AUSA Villafaña sent a victim notification to Jane Doe #1
+via her attorney, Bradley Edwards, which is attached as Exhibit 6 to the Villafaña
+Declaration. That notification contains a written explanation of the full terms of the
+agreement between Epstein and the U.S. Attorney's Office. A notification was not
+provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom
+the United States was prepared to name in an indictment.
+SO STIPULATED AND AGREED.
+Dated:
+BRADLEY EDWARDS, ESQ.
+Attorney for Plaintiffs Jane Does #1 & 2
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Dated:
+DEXTER LEE
+By:
+ASSISTANT
+U.S.
+ATTORNEY
+Attorney for Defendant United States
+'5°
+
+
+Case 9:08-CV-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 1 of 13
+CASE NO. 08-80736-CIV-MARRA/JOHNSON
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs,
+UNITED STATES OF AMERICA,
+Defendant,
+ROY BLACK, et al.,
+Intervenors.
+INTERVENORS' MoTIoN For A PROTECTIVe ConfIDenTIalITy
+ORDER AND INCORPORATED MEMORANDUM OF LAW
+Intervenors Roy Black, Martin Weinberg, and Jeffrey Epstein, pursuant to Rule 26(c)
+of the Federal Rules of Civil Procedure and Local Rule 26.1, respectfully move this Court
+for the entry a Protective Confidentially Order which (1) limits the dissemination of certain
+Confidential Discovery Material ("CDM") described below, to a designated list of the
+Plaintiffs' counsel and support staff, and (2) prohibits any party from filing pleadings, briefs,
+memorandums or exhibits purporting to reproduce, quote, paraphrase or summarize any
+CDM or portions thereof, absent leave of the Court to file the document or portion thereof
+under seal in accordance with Local Rules of the United States District Court for the
+Southern District of Florida. See Exhibit 1, Proposed Protective Confidentiality Order.
+
+
+Case 9:08-CV-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 2 of 13
+In support of this motion, the Intervenors submit the following Memorandum. Part I
+sets forth the background of this matter. Part Il demonstrates why the Court can and should
+issue the requested protective order.
+MEMORANDUM
+1. BACKGROUND
+Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with
+the government in September, 2007. Under that agreement, Mr. Epstein pled guilty to two
+state felony offenses and served a prison sentence and a term of community control
+probation. The agreement, with which he has fully complied, also required that he pay the
+legal fees of the attorney-representative of identified victims and that he not contest liability
+in any cases brought against him solely under 18 U.S.C. § 2255. Plaintiffs sued under § 2255
+and received settlements as the direct result of Mr. Epstein's agreement not to contest
+liability in those cases. Plaintiffs, such as the Jane Does in this case, "relied on the [NPA]
+when seeking civil relief against Epstein ... and affirmatively advanced the terms of the
+[NPA] as a basis for relief from Epstein." United States' Reply in Support of its Motion to
+Dismiss for Lack of Subject Matter Jurisdiction, Doc. 205-6 at 12-13.
+After reaping the benefits of the NPA, the plaintiffs seek herein, among other
+remedies, the rescission of that agreement. During the course of civil litigation against Mr.
+Epstein, Mr. Epstein was ordered, over his strenuous objection, to produce documents given
+to him by the government during the course of his settlement/plea negotiations with it. See
+-2-
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 3 of 13
+Jane Doe #2 |. Epstein, No. 08-80119-MARRA, Doc. 462. Once the CVRA action was
+reactivated - after plaintiffs had successfully pursued their civil monetary remedies against
+Mr. Epstein to completion - plaintiffs sought to use that correspondence in the CVRA case
+and thereafter also sought disclosure from the government of correspondence authored and
+sent to the government by Mr. Epstein's attorneys in the course of their efforts on behalf of
+their client to resolve the ongoing criminal investigation of him. Both Mr. Epstein and his
+criminal defense attorneys - Intervenors Roy Black and Martin Weinberg - filed motions to
+intervene for the limited purpose of challenging the use and disclosure of the settlement/plea
+negotiation correspondence (Doc. 56, 93), followed by supplemental briefing and motions
+contending, among other things, that the correspondence fell within the bounds of privilege
+under Fed. R. Evid. 501. Doc. 94, 160,161, 162.
+This Court granted the motions to intervene (Doc. 158, 159), but ultimately ruled that
+the correspondence - the CDM at issue in the instant motion - was subject to disclosure.
+Doc. 188. Among other things, the Court rejected Intervenors' argument based on Rule 501
+on the ground that Congress has already addressed the issue in Fed. R. Crim. P. 11(f) and
+Fed. R. Evid. 410 and likewise rejected the Intervenors' request that the Court recognize a
+privilege for plea negotiation communications. Id. at 8-9. The Intervenors appealed the
+Court's ruling to the Eleventh Circuit. However, on April 14, 2014, the Eleventh Circuit
+affirmed the Court's rulings using the same rationales.
+- 3-
+
+
+Case 9:08-CV-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 4 of 13
+ARGUMENT
+Although the Court ruled that the Plaintiffs could discover the CDM, the Court
+reserved ruling on how the Plaintiffs could use the material thereafter, expressly cautioning
+that "this order is not intended to operate as a ruling on the relevance or admissibility of any
+particular piece of correspondence, a matter expressly reserved for determination at the time
+of final disposition." Doc 188, p. 10. Unless and until the Court determines those reserved
+issues, the Court should bar the Plaintiffs from disseminating and/or publicly disclosing the
+substance of the CDM absent further order of the Court.
+A.
+Discovery Should Not Be Routinely Made Available to the Public
+"The Eleventh Circuit has repeatedly acknowledged the private nature of discovery"
+Looney |. Moore, No. 2:13-CV-00733-KOB (N.D. Ala. April 7, 2014), 2014 U.S. Dist.
+LEXIS 48349, at *3, citing Chicago Tribune Co. | Bridgestone/Firestone, Inc.., 263 F.3d
+1304, 1316 (11" Cir. 2001) ("Discovery, whether civil or criminal, is essentially a private
+process because the litigants and the courts assume that the sole purpose of discovery is to
+assist trial preparation.") (quoting United States | Anderson, 799 F.2d 1438, 1441 (11" Cir.
+1986; emphasis in original). See also Anderson, 799 F.2d at 1441 ("Historically, discovery
+materials were not available to the public or press.") (citation omitted); In re: Denture
+Cream Products Liability Litigation, No. 09-2051-MD-Altonaga/Simonton (S.D. Fla. Jan.
+18, 2013), 2013 U.S. Dist. LEXIS 8114, at *37 ("the common law right of access to judicial
+proceedings does not apply to discovery materials, 'as these materials are neither public
+-4-
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 5 of 13
+documents nor judicial records'") (quoting Chicago Tribune, 263 F.3d at 13l1; citation
+omitted). Thus, "[a] court may restrict distribution of discovery material even if there
+'certainly is a public interest in knowing more' about its contents." Tillman |. C.R. Bard,
+Inc., Case No. 3:13-cv-222-J-34JBT (M.D. Fla. March 13, 2014), 2014 U.S. Dist. LEXIS
+41406, at *6, quoting Seattle Times Co. |. Rhinehart, 467 U.S. 20, 31 (1984)
+Placing limitations on the dissemination and use of pretrial discovery is particularly
+important since "[tJhe overwhelming majority of documents disclosed during discovery are
+likely irrelevant to the underlying issues..." Federal Trade Commission | Abbvie Products
+LLC, 713 F.3d 54, 63 (11" Cir. 2013). Therefore, "[s]uch documents, prior to admission into
+the record in support of a motion or as evidence at trial, "play no role in the performance of
+Article Ill functions' of a federal judge." Travelers Indemnity Co. | Excalibur Reinsurance
+Corp., No. 3:11-CV-1209 (CSH) (D. Conn. Aug. 5, 2013), 2013 U.S. Dist. LEXIS 110400,
+at *37, quoting United States | Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995).
+These principles are vitally important here where counsels' private communications
+with prosecutors "if publicly released could be damaging to reputation and privacy" and
+would likely constitute an "abuse of [a court's] processes." Seattle Times, 467 U.S. at 35
+While courts have recognized that settlement agreement materials may sometimes be
+discoverable, see, e.g., In re MSTG, Inc., 675 F.3d 1337, 1348 (Fed. Cir. 2012),' they are
+' But see Wagner |, Wastiffs, Case No. 2:08-cv-431 (S.D. Ohio May 14, 2013), 2013 U.S. Dist.
+LEXIS 68349 (denying motion to compel discovery of settlement agreement on relevancy grounds);
+Duncan | Phoenix Supported Living, Inc., No. 2:05cv1 (W.D. N.C. Sept. 12, 2006), 2006 U.S. Dist.
+(continued..)
+-5-
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 6 of 13
+rarely admissible as evidence at trial, see, e.g, LaserDynamics, Inc. |. Quanta Computer,
+Inc., 694 F.3d 51, 78 (Fed. Cir. 2012) (reversing district court for admitting settlement
+agreement at trial); Apple, Inc. | Samsung Electronics Co., Ltd., Case No. 11-CV-01846-
+LHK (N.D. Cal. Nov. 7, 2013), 2013 U.S. Dist. LEXIS 160337, at **51-54 (barring parties
+from relying on settlement agreement at trial under Fed. R. Evid. 403).
+For this reasons alone, it is appropriate to limit the dissemination and use of discovery
+concerning settlement discussions, even if not privileged. See Charles E. Hill & Associates,
+Inc. | ABT Electronics, Inc., 854 F. Supp. 2d 427, 430 (E.D. Tex. 2012) (designating
+discovery material including settlement communications as "Outside Counsel Eyes Only
+Confidential Information" and cautioning parties that while it is allowing the discovery it
+intends to later weigh relevance carefully and noting that settlement negotiations are "always
+suspect to some degree and are often littered with unreal assertions and unfounded
+expectations .. And are not always grounded in facts or reason."). Indeed, unless and until
+the Plaintiffs demonstrate a bona fide need to use the discovery at trial or in pleadings, the
+Intervenors need not even demonstrate "good cause" in order to obtain relief. As the Hon.
+Karon Owen Bowdre, Chief Judge of the U.S. District Court for the Northern District of
+Alabama recently held:
+(...continued)
+LEX/S 66742, at **9-11 (finding settlement communications non-discoverable as "not... Likely to
+lead to the disclosure of admissible evidence" and would tend to chill settlement efforts) (citations
+omitted).
+-6-
+
+
+Case 9:08-CV-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 7 of 13
+Based on this standard of practice, the court finds that restricting
+the use of discovery materials to case-related purposes only,
+even over Plaintiffs' objection, is within this court's discretion
+and authority even without the application of the Rule 26(c)
+good cause standard. By its text, Rule 26(c) applies to situations
+26(c). The disputed limitation in this case does not fall into
+either of these categories....
+Looney | Moore, No. 2:13-CV-00733-KOB (N.D. Ala. April 7, 2014), 2014 U.S. Dist.
+LEXIS 48349, at ** 4-5 (emphasis in original).
+B.
+Good Cause Exists For the Protective Order In Any Event
+Even if the Intervenors would be required to demonstrate "good cause" for the
+requested protective order at this point, that standard is met where restrictions are appropriate
+under Rule 26(c) to protect the Intervenors from "annoyance, embarrassment, oppression,
+or undue burden or expense." See Looney, 2014 U.S. Dist. LEXIS 48349, at *5; Irizarry-
+Santiago | Essilor Industries, 293 F.R.D. 100, 104 (D. P.R. 2013). The Intervenors include
+not only the third-party client whose non-prosecution agreement is the one Plaintiffs are
+trying to undo but also the client's attorneys, who are even further removed from the actual
+litigants. Counsels' lengthy arguments may or may not have had any influence on the
+government's decision-making and, therefore, their relevance is particularly remote. Cf.
+United States | Byrd, Crim. No. 13-0266-WS (S.D. Ala. April 7, 2014), 2014 U.S. Dist.
+LEXIS 48035, at **14-18 (denying newspaper's motion to obtain copies of unsolicited
+sentencing letters mailed to the judge prior to sentencing, despite "no formal promises of
+-7-
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 8 of 13
+secrecy or confidentiality," because "the privacy interests of the letter writers and the
+interests of the judicial system in obtaining hones, uncensored input" outweighed public's
+interest in disclosure, especially where the sentencing letters "neither drove no significantly
+impacted the sentencing decision" which was based on a plea agreement).
+Like the situation at issue in Looney, the instant case is a "high profile" one and
+should not be "tried in the media, rather [than] in the courtroom." Looney, 2014 U.S. Dist.
+LEXIS 48349, at *5. Moreover, there is a well documented history in this case of the media
+reporting inflammatory statements made by Plaintiffs' counsel, either directly to the press or
+in pleadings, and these statements have frequently been based on discovery materials. See,
+e.g., Attorneys Say Miami Prosecutors Violated Crime Victims' Rights Act, Main Justice,
+March 22, 2011 (quoting Plaintiffs' motion asserting that the U.S. Attorney's Office
+"deliberately misled' them and claiming that the "only reason" the U.S. Attorney's Office
+"concealed the existence of the non-prosecution agreement from them was "to avoid a
+firestorm of public controversy that would have erupted if the sweetheart plea dal with a
+politically connected billionaire had been revealed"); Attorneys want Jeffrey Epstein
+agreement thrown out, PalmBeachDailyNews.com,
+March 21, 2011 (repeating
+aforementioned accusations from Plaintiffs' motion attacking the U.S. Attorney's Office,
+adding that the Office had allegedly engaged in a "pattern of deception" and noting that
+Plaintiffs' motion had made references to "e-mails and letters from the federal office to
+Epstein's lawyers"); News Reports about Billionaire Pedophile Jeffrey Epstein Highlight the
+-8-
+
+
+Case 9:08-CV-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 9 of 13
+Importance of Victims Rights, BriefingWire.com, March 8, 2011 (quoting Plaintiffs' counsel
+saying "we took on powerful people and sought to level the playing field to protect victims"
+and that he "hopes that the media attention" will "inspire victims" to "hold predators
+accountable"); Judge Receives Epstein Tape Ruling Pending, Palm Beach Daily News, May
+5, 2010 (quoting plaintiffs' counsel as arguing that a 22-minute tape recording of Mr. Epstein
+was ""critical"" in showing his alleged "" lack of remorse"" and that he was a "pitiless" sexual
+abuser); Lawyer: Epstein Made Admissions On Tape, Palm Beach Daily News (FL), April
+29, 2010 (quoting Plaintiffs' motion concerning the same tape recording); Attorney For
+Epstein Victims: 'I have Never Seen A Stranger Case', Palm Beach Daily News, September
+20, 2009, p. A.1 (quoting Plaintiffs' counsel as opining that Mr. Epstein "could have gone
+to prison for life," that he had "never seen a stranger case" and that the U.S. Attorney's
+Office was effectively "saying we'll do everything in our power to see he doesn't get
+punished"); Palm Beach sex offender's secret plea deal: Possible co-conspirators not
+charged, presses victims to settle civil suits, The Palm Beach Post, September 18, 2009
+(quoting Plaintiffs' counsel as saying that non-prosecution agreement "taught [the victims]
+that someone with money can buy his way out of anything.
+It's outrageous and
+embarrassing...."); Judge to Rule on Sealed Plea-Deal Papers Today, Palm Beach Daily
+News, June 25, 2009, p. A.1 (reporting Plaintiffs' counsel saying that he wanted to use the
+settlement documents in depositions); Hearing Set to Consider Secrecy of Plea Bargain,
+Sun-Sentinel (Ft. Lauderdale, Florida), Palm Beach Edition, June 15, 2009, p. 3B (in
+-9-
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 10 of 13
+response to reporter's question about whether he thought Mr. Epstein had received special
+treatment, Plaintiffs' counsel quoted as saying: "Are you kidding? It's transparent.
+Certainly, no one else gets treated like that"). See Composite Exhibit 2.
+The publicity-generating comments by Plaintiffs' counsel have continued since the
+Eleventh Circuit's ruling. The wave began on April 21, 2014. That day, the Washington
+Post published a lengthy letter written by one of Plaintiffs' lead counsel containing his
+editorialized history of the case criticizing the Intervenors' arguments and concluding with
+his opinion that "the federal prosecutors deliberately concealed the sweetheart plea deal."
+See Composite Exhibit 3. The same attorney was also quoted by the Sun-Sentinel as making
+the unsupported accusation that somehow Mr. Epstein "used his political connections and
+great wealth" to secure a plea bargain that, in counsel's opinion "was unheard of, frankly, if
+you look at these charges." Id. Also that same day, the Plaintiffs' other lead counsel was
+quoted by the Palm Beach Daily News as referring to Mr. Epstein as "[a] well-connected
+billionaire" who "got away with molesting many girls." Appeals court rules against sex
+offender; Attorneys for underage victims seek to overturn 'sweetheart plea,
+PalmBeachDailyNews.com, April 21, 2014. Id.
+On April 22, 2014, the same attorney issued a "press release" likewise trumpeting the
+appellate victory, identifying Mr. Epstein's counsel by name and containing a personal
+statement from counsel. See Composite Exhibit 4. In a parallel article published in the
+Daily Business Review, Plaintiffs' counsel was quoted as follows: "Edwards said the
+-10-
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 11 of 13
+documents at this point will be disclosed only to the plaintiffs and will not become part of
+the public record." Id. (emphasis added). The implication of the "at his point" qualifier
+suggests that Plaintiffs' counsel plan to inject the private discovery into "the public record"
+at a later date.
+The next day, April 23, 2014, the Facebook page for the Farmer Jaffe Weissing law
+firm began posting multiple photographs of Mr. Epstein with links to numerous newspaper
+articles about the case, along with snippets of prejudicial quotations from Plaintiffs' counsel.
+See Composite Exhibit 5. The same comments were then posted on the law firm's blog
+"www.pathtojustice.com with yet another large photograph of Mr. Epstein, resembling a mug
+shot. Id. The blog includes such personalized opinions, such as: "We have a very strong
+case that, prodded by Epstein, the federal prosecutors deliberately concealed the sweetheart
+plea deal." Id.
+In light of the prominence of this case in the media, the repeated use of the media by
+Plaintiffs counsel to drum up support for their case (and to prejudice the community against
+Mr. Epstein and his counsel), and the Plaintiffs' suggestion that they could make the CDM
+available to the public in the future (just not "at this point"), the requested protective order
+is more than justified. As Chief Judge Bowdre likewise concluded in a similar, but less
+egregious, situation:
+The court has already expressed to the parties its concern that
+this potentially high profile case will be tried in the media, rather
+in the courtroom. Significant media coverage of the case has
+already occurred. In the interest of justice, this court is
+-11-
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 12 of 13
+committed to giving both parties a fair trial, which includes
+protecting the Defendants from the "annoyance, embarrassment,
+[and] oppression" that could occur from allowing their names to
+be dragged through the metaphorical mud before a jury has even
+made any determination of wrongdoing. At least one other court
+has cited the risk of excessive publicity preventing the selection
+of an impartial jury as legitimate support for a finding of good
+cause under Rule 26(c). See Anderson |. Cryovac, Inc., 805 F.2d
+1, 4 (Ist Cir. 1986) (overturning the district court's decision on
+other grounds). As such, the court finds that good cause exists
+to support the Protective Order as written....
+Looney | Moore, 2014 U.S. Dist. LEXIS 48349, at **5-6.
+LOCAL RULE 7.1(a)(3) CERTIFICATION
+Counsel hereby certify that they have conferred with all parties who may be affected
+by the relief sought in this motion in a good faith effort to resolve the issues raised in the
+motion and have been unable to do so. Plaintiffs oppose this motion.
+CONCLUSION
+For all of the foregoing reasons, the Court should GRANT this motion and enter the
+requested Protective Order.
+Respectfully submitted,
+Is/Roy Black
+oy Blac
+ackie Percze
+BLACK, SREBNICK, KORNSPAN
+& STUMPF, P.A.
+201 So. Biscayne Blvd., Suite 1300
+Miami, Florida 33131
+Tele: (305) 371-6421
+-12-
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 13 of 13
+Fax: (305) 358-2006
+rblack@royblack.com
+jperczek@royblack.com
+Attorneys for Intervenors
+Is/Martin G. Weinberg
+Martin G. Weinberg
+20 Park Plaza, Suite 1000
+Boston, Massachusetts 02116
+Tele: (617) 227-3700
+Fax: (617) 338-9538
+owlmgw@att.net
+Attorney for Intervenors
+CERTIFICATE OF SERVICE
+THERE CERTIFY that a true copy of the foregoing was filed via CM/ECF, this
+2nd day of May, 2014.
+Is/Roy Black
+Roy Black
+- 13-
+
+
+Case 9:08-cv-80736-KAM Document 247-4 Entered on FLSD Docket 05/02/2014 Page 1 of 6
+COMPOSITE EXHIBIT 4
+
+
+2201Ease 9:08-807:400n24744/stecheer5D684P05/02120104wPage 2 of 6
+NOT FOR REPRINT
+eller® DAILY BUSINESS REVIEW
+_Click to Print or Select 'Print' in your browser menu to print this document.
+Page printed from: Daily Business Review
+Prosecutors Must Turn Over Docs In
+Billionaire Sex Offender Jeffrey Epstein
+Case
+John Pacenti, Daily Business Review
+April 22, 2014
+Roy Black
+Partner
+Black, Srebnick, Kornspan & Stumpf
+Attorneys for two alleged sexual assault victims trying to negate a federal nonprosecution
+agreement with billionaire pedophile Jeffrey Epstein applauded a decision by a federal appellate
+court as a triumph for victims' rights.
+But Epstein's celebrity defense attorney Roy Black said the decision by the U.S. Courts of Appeals
+for the Eleventh Circuit in Atlanta undercuts the plea negotiation process and attorney-client
+privilege.
+The U.S. Court of Appeals for the Eleventh Circuit affirmed an order requiring prosecutors to turn
+over documents about plea discussions with Epstein. The decision also lifted an appellate stay on
+the ruling by U.S. District Judge Kenneth Marra in West Palm Beach to allow the release of
+documents to the women, identified in court papers only as Jane Doe No. 1 and Jane Doe No. 2.
+The women say they were sexually molested as minors by Epstein and claim federal prosecutors
+violated the Crime Victims' Rights Act when they negotiated the nonprosecution agreement in
+2007.
+Both sides agreed the opinion sets a precedent unrivaled in other federal circuits.
+"So much of the legal area of victims' rights is breaking new ground and new territory," said Jay
+Howell, a Jacksonville appellate lawyer who represented the women. "The court decision here
+expands the rights of the victims and the victims' ability to discover information about the criminal
+case."
+http//www.dailybusinessreview.com/cs/Satellite7c=Article_C8childpagename=DBR%2FArticle_C%2FArticle%2FLayouls2FPrinterFriendly&pagename=ALM.
+1/3
+
+
+He said the women have stuck with the case out of "a fundamental sense of injustice" for the
+underage victims of Epstein.
+Black, a partner at Black, Srebnick, Korspan & Stumpf in Miami, said the 23-page opinion issued
+Friday has wider implications in plea bargains. No longer can defense attorneys be candid with
+prosecutors when trying to negotiate a plea, he said.
+"This is now the leading precedent holding that plea bargain discussions are not confidential, and
+now criminal defense lawyers must censor their communications with prosecutors," Black said.
+"The Eleventh Circuit has ruled there is no privilege, there is no confidentiality."
+Miami attorney Joseph DeMaria, a partner at Fox Rothschild and former federal prosecutor, said
+while the opinion is legally correct, it could have a significant impact on the 90 percent of federal
+cases resolved by pleas. He said it now is up to Congress to amend the Crime Victims' Rights Act
+to carve out a safeguard for defendants.
+He foresees "a chilling effect on plea negotiations where victims are aggressively seeking
+information."
+"If these type of plea discussions are now discoverable by victims, then it's going to cause
+significant problems for the government and defendants in trying to resolve criminal cases,"
+DeMaria said.
+Epstein was accused of luring underage women to his Palm Beach mansion for sex. The television
+show "Law & Order SVU" had a "ripped from the headlines" episode based on Epstein, who is
+also known for his celebrity connections Flight logs show former President Bill Clinton flew on
+Epstein's private plane 10 times from 2002 to 2005.
+Plea bargain
+The appellate case stems from a decision by federal prosecutors not to charge Epstein if he
+pleaded guilty to state charges in Palm Beach Circuit Court for soliciting an underage girl for
+prostitution. He was sentenced to 18 months in jail and house arrest.
+Epstein moved back to New York City from Palm Beach after he finished his sentence.
+The women contend they could have argued against the nonprosecution agreement if they were
+informed before the agreement was reached.
+"Our clients want to see Mr. Epstein held accountable for the numerous sex offenses he committed
+against many children," said Bradley Edwards, the women's trial counsel and a partner at Farmer,
+Jaffe, Weissing, Edwards, Fistos & Lehrman in Fort Lauderdale.
+Edwards said the documents at this point will be disclosed only to the plaintiffs and will not become
+part of the public record.
+Andrew Levi, a partner at Lehr Levi & Mendez in Miami and former federal prosecutor, said once
+documents are in the hands of civil attorneys they can easily be passed on to news media or put in
+other court records.
+http://www.dailybusinessreview.com/cs/Saleililo7c=Arlicle_C&childpagename=DBR%2FArticle_C%2F Article%2FLayouts%2FPrinterFriendly&pagename=ALM. 2/3
+
+
+"I's not as if they are given to the attorney with any type of limitation attached," he said. "We are
+going to have to see how this plays out in the future to determine if this decision has a chilling effect
+on the candor and possibly the effectiveness of communications by defense counsel when
+negotiating a plea."
+Unanimous opinion
+Epstein's criminal defense attorneys, Black and Martin G. Weinberg of Boston, intervened in the
+appeal as third parties. The appellate ruling was written by one of the more conservative members
+of the Eleventh Circuit.
+Judge William H. Pryor said the federal rule of evidence cited by Epstein in the interlocutory appeal
+did not protect him against discoverability of plea negotiations.
+"And even if they did, Epstein clearly falls outside its protection because he entered a guilty plea
+and the victims intend to use the correspondence against the United States, not against Epstein,"
+Pryor wrote.
+He was joined in the unanimous decision by Judge Beverly Martin and U.S. District Judge
+Charlene Edwards Honeywell of Orlando, sitting by designation.
+The U.S. attorney's office in Miami argued before Marra that the victims did not need to be notified
+of the agreement because the women's liberty was not at stake. It also took the position that the
+Crime Victims Right Act did not apply unless federal charges were filed against Epstein.
+Victims' Rights
+Howell said the decision indicates how courts have come around to the victim's point of view. He
+said as a state prosecutor in 1978, victims' rights were nearly non-existent.
+"There has been a fundamental change in the courts," he said. "I's only been in the last 30 years
+that courts examines things from the view point of the victim."
+He said plaintiffs attorneys have asked the Justice Department in Washington why Epstein was
+florid the no prosecution agreement but were told all decisions on the billonaire were made in
+"Why was such a lenient deal offered?" Howell asked. "Washington is supposed to be tough on
+crimes against children, but the decision in this case certainly disputes that policy."
+Copyright 2014. ALM Media Properties, LLC. All rights reserved.
+http/www.dailybusinessreview.com/cs/Satelite7c=Article_C&childpagename=DBR%2FArticle_C%2FArlice%2FLayouls%2FPrinlerFriendlySpagename=ALM 33
+
+
+5220 Case 9:08-CV-80786 KAM R 0cEmen 247ams Entered oF BD Decker 05/02/201LoPage 5 of 6
+PRLOG
+Pross Releaso Distribution
+• Subm 1 Press Releas:
+PR Homic
+Search
+Appeals Court Rules in Favor of Crime Victims'
+Rights in Registered Pedophile Jeffrey Epstein Case
+Country News
+Valled Stips
+Cuntala
+ladlia
+Hong Kong
+United Kingdom
+Abre Coulees
+FOR IMMEDIATE RELEASE
+Industry New;
+All News
+Exclusive News
+PRiog (Press Releaso) - Apr. 22, 2014 - FORT LAUDERDALE, Fla. - Contact
+Brad Edwards, Farmer, Jafle. Weissing, Edwards.
+Fistos & Lohman. P.L
+Custom Tote Bag
+(800) 400-1098
+Kim Sailer, BARD Marketing/PR
+Vistaprint
+ksailer@gbardmarketing.com
+Like what you see? Get up to 25% off
+$8.49
+May 2014
+it Th We Tu Mo Su Sa
+2 1
+April 2014
+Appeals Court Rules in Favor of Crime Victims'
+Rights in Regislored Podophile Joltey Epstein
+Case
+20 22 28 2Z 26
+In a landmark decision, the US Court of Appeals
+for the Eleventh Circut Court on April 16, 2014
+ruled in favor of two crime victims represented by
+Famer, Jafe Weissing. Edwards. Fistos &
+Lehrman Partner Brad Edwards and his co-counsel. Paul Cassell, Ronald N. Boyce Presidential
+Professor of Caminal Law-S.J. Qunnoy Cologe of Law at the University of Utah. The ruling upheld the
+District Court which ordered the United States Altomey's Office lo provide the victims and their
+advocates the large volume of correspondence exchanged between Jeffrey Epstein and the Govemment
+that resulted in the goverment electing not to Federally prosecule Epstein for his many sexual crimes
+against children. Altomeys Edwards and Cassell argued the case before the Eleventh Circuit in
+February, against altomeys Roy Black and Martin Weinberg
+The case involves a federal criminal investigation that resulted in the Federal Goverment leaming that
+Jeffrey Epslen and certain co-conspirators sexually abused dozens and dozens of minor girls in West
+Palm Beach. Florida. Epstein ultimalely reached a plea deal under which he plead gulty only to a slale
+charge of procuring a minor for
+prostitution in exchange for the Federal Govemment agree ng not to
+pursue federal sex crimes on behalf of more than 40 ctims. Represented by Alfomey Brad Edwards
+and Paul Cassell. Iwo of the gris sought to have the plea deal thrown out because prosecutors had nol
+informed them of whal was happen ng and had laken steps to conceal the peculiar plea arrangements.
+The vict ms moved to have access to the correspondence between prosecutors and defense allomeys
+to provo their case.
+The Eleventh Circuit rulod hat that the victims were entitled lo have access lo the matenals Agreeing
+wth Attomeys Edwards and Cassell, the Eleventh Circuit ruled that the communications were not
+pruleged or otherwise barred from distribution The Elevenih Circuit explaned that the victims should
+"er oy an evidentiary benefit from the disclosure of plea negotialions to prove where the United States
+violated their righis under the [Crime Victims" Rights) Act."
+Upon leaming of the ruling Attomay Brad Edwards stated: "The viclims have fought hard for almos! 6
+years now to leam why the person who molesled them and many other children was ultimately allowed
+lo live above the law and avoid being held accounlable for his crimes. I'm pleased that the Eleventh
+Crcuit has made this ruling which will bring the wct ms one step closer to knowing the truth. Wealth and
+power should not immunize anyone from punishment for harmful sexual acts against children, in the
+circumstances when it does. the victims should at leasi have access lo the explanation why. These
+documents should begin to explain."
+Farmer, Jalle. Weissing, Edwards, Fistos & Lehman. P. L., a Fort Lauderdale Liligalion fim, locuses on
+Consumer Class Aclions. Personal Injury, Wrongful Death. and Whistleblower Suils (qui tam), The firm
+is headquartered at 425 N. Andrews Avenue. Suile 2 and may be reached al (B00) 400-1098 or (954)
+524-2820. Additional informalion aboul Brad Edwards, or Famer, Jaffe. Weissing, Edwards & Lehman.
+P.L. may be oblained from the imm's website at http://www.potblojustice.com/attornexs.brad.ss/wac/s/
+he /www.abusesodassaul.com or bitp. 2www.pathtojustice.com
+http:/www.prlog.org/12313086-appeals-courl-rules-in-favor-of-crime-wclims-rights-in-registered-pedophile-jeffrey-epstein-case.hlml
+Daily News
+IG Assets, Ins. Announs
+Balon Rouge,Hotel
+Mas. Mata troduces B
+Square Silk Collecton
+Popular Journalisblis s
+Putilic sulunches Few
+OW Sumoson Giabol
+Bess neol Never Auga
+Bopies Managog Paine!
+Winnecs Apngopse lor
+Casta Rising Star Bles
+Fust Soundback Contest'
+Weekly News
+Equesiean Teams par
+Music Stars Unge at Super
+Bade Xilo Furter Canger
+Suppor and Aware 055 -
+6964 views
+Shown Chicage at Gorila
+Lange burlezaus
+575-
+news
+Maches Island Leas
+1256 wews
+SECHERS_A Suspense
+Now or Young Adults - 826
+MOWS
+Brooner Bros. & Lisa Nicoie
+Collecton Runway Monel
+Mwon Alepson to bach
+focal nodels - 734 news
+enr 22.2014 News
+1/2
+
+
+Contact
+BARD Markoling
+@basmarketing com
+- End -
+Follow Erall
+Embed
+PDF / Print
+Pakis
+Avenue
+Contact Email
+: Contact Author *''@bardmarkeling com W
+Source
+: BARD Marketing
+Cily/Town
+For Li. derdale - Flonda - United Stales
+Industry
+: Legol
+Tngs
+: Brad Edwards, Joffrey Epsiein, Crime Vicums Rights, fanner jallo weis sing
+Shortcut
+: priog-org/12313086
+Jiselalmer: Issuers ofthe press reloaces are solely responsible for the content of their press releases
+RLo; cant be held tablo for fee content poslud byotters
+Begon. Arusa
+Latest Press Releases By "BAROMacketing"
+• Attorney Matt Weissing Forms Team Fumor Jate Wolssina: Padiciale in 7th Annual 4KJD5 But Cardig
+• (sorney Alien Honey Joins Eonor Jolle We aging
+• Sepollato Beeney Rotm Prosty Spoke alby 19th Casuit Booch Bar Conloonce
+• Munar Guan 2 Sooner Jusile Cabelos Hessarch Fousagon & Casing MinbLand Suction
+• Agorgy Gabned Zainbro Co-Chamed the AALs Eloda Ree peal Student Trol Advocasy Compchloo
+Hore...
+Trending News...
+• Dr.McConnellot Filled Barness Discuzaga Glutens Ansten Memory Ansies. ARHO
+• a Rozallies tom New Pelo Saeger Bonk to bo Donated to Hudson River Sloop Clearwate:
+• Yasatoo Walkshop In.Hawaii: Using Goodle SuRed. Creale Ta Super Stales of Amensa
+• Sisters Networhor inc padeers but FORCE 6. Unicol Sovih Flonda cessarchera
+• Soundmates Anpauses We Nays Go on Sale Snle for Award Winning for HEF Bluetom Tray
+INTRODUCING
+FREE SHIPPING
+EVERY DAY, EVERY ORDER
+SHOP & SEE CODE •
+LIke PRLog?
+9K 2K 1K
+http://www.prlog.org/12313086-appeals-court-rules-in-favor-of-crime-viclims-rights-in-registered-pedophile-jeffrey-epslein-case htmi
+22
+
+
+Case 9:08-cv-80736-KAM
+Document 247-5
+Entered on FLSD Docket 05/02/2014 Page 1 of 12
+COMPOSITE EXHIBIT 5
+
+
+Case 9:08-cv-80736-KAM Document 247-5 Entered on FLSD Docket 05/02/2014 Page 2 of 12
+52/2014
+Farmer Jaffe Veissing
+1
+295 kes 44 talking about thes - 9 were here
+Lice
+Follow Message
+Law Pracike
+425 tL. Andrews Ave., Ste. 2, Fort Lauderdale, Florkla
+(800) 400-1098
+About - Suggest an Eci
+295 =/
+Photos
+Contact us
+Ukes
+Post
+Photo / Video
+1E Pennes yette Welsing
+Farmer Jaffe Weissing Gabe Zambrano has been selected as a
+2014 Top Rated Lawyer In Mass Torts by ALM & Martindale-
+Hubbell.
+https://plus.google.com/103809421573266262708/posts/DwVXCV
++ZP4t - with Gabriel F Zambrana.
+Irate Your frends to Lie This Page
+Type a friend's namte...
+f7.
+Manchette
+- Randy Senneway
+la Marco Raguzzino
+G 7
+See Al
+Invite
+[Invite
+Invite
+-
+Reviews
+####+
+Recent Posts by Others on Farmer Jaffe Weissing
+See 28
+https://www.facebook.com/FarmerJaffeWelssing
+1/29
+
+
+Case 9:08-cv-80736-KAM Document 247-5 Entered on FLSD Docket 05/02/2014 Page 3 of 12
+LEGAL LEADERS
+*ALM
+2014 TOP RATEO LAWYERS
+MASS TORTS
+Hey Jaff, bels Me a good groupil Very professional phot....
+Manch 26 at 6:26pm
+- Premier Process Serving
+* Cal Jacksonne's most relable process servers. Premier Pro.
+February 25 at 12:02pm
+Bonnie Manls
+"Gabe Zambrano, of Farmer Jaffe Weissing, I a Co-Chal
+Fabruary 25 at 10:4bam
+Ritch
+T-minus B hours unil game thel Let's go Canes!
+1 Noverber 2, 2013 at 12 00pm
+Race Point Legal
+Race Paint Legal has delvered technology, matined and c
+Septenber 12, 2013 at 10.J5am
+More Posts
+Lkes
+See All
+S Minena Lawsults | Injurles | Lawyers | Attorney,
+Local Business
+Line
+Like • Comment • Share
+15 people lhe this.
+Marlanne Carlisle Salem Way to go, Gabe.
+19 hours ago Uke
+/ Me as eaten for walke
+Broward County Courts Broward County:
+Courthouses;
+Geverent Orpantation Professional Services: Courthouse
+eErin Brockovich
+Puble Figure
+Like
+Like
+Farmer Jaffe Weissing shared a Ink.
+Filing a Lawsuit for Sexually Assault by a Massage Therap st
+http://hub.am/1kq|Fap
+Filing a Lawsult for Sexually
+Assault by a Massage Therapist
+http://www.pathtojustice.com/blog/bkd/3
+44253/fing-a-lawsut-for-sexualy-
+Activity
+Recent
+PARE
+armer Jaffe Weissing created 7th Annual 4KID
+g Cardie 5K Faness.Spon
+l Pennes zette Welsing shared a tik.
+Sexual Assault by Massage Therapists http://hub.am/1kscg4D
+Lie Comment - Share
+Stacey Farter kes this.
+Jaln us in wishing Farmer Jaffe Wuissing - Gary Farmer a Happy
+Birthday!
+Sexual Assault by Massage Therapists
+http://www.palhtajustice.com/blog/bkd/344185/scxualassault-bymessage-therapists
+Sexual assaults of cents by mussage therapists at the spa are occuring
+at high rates and lawsuits can be fled.
+Lie - Connent ' share
+htps://www.facebook.com/Farmer.JaffeVieissing
+2/29
+
+
+Case 9:08-cv-80736-KAM Document 247-5 Entered on FLSD Docket 05/02/2014 Page 4 of 12
+Farmer Jaffe Welssing created an event.
+Apr$ 29
+7W ANNUAL
+O4KIDS
+BIGCARDIO:
+SK. FITNESS. SPORTS.
+7th Annual 4KID5 Big Cardio 5K,
+Aitness.Sports
+Tomorrow
+Central Broward Regional Park, Fort Lauderdale,
+Florida in Lauderhi, Florida
+Be the fest person to join
+Lk Coerrent - Share
+31 Apat 29-Esited
+Farmer Jaffe Welssing shared a link.
+Joln attorney #MattWelssing on May 3 and run the 7th Annual
+#kids Big Cardio 5K Help make a difference in the lives of
+Florida's foster children,
+Click Ink below to sign-up or make a donation.
+Like • Comment - Share
+27 people lke this.
+View 3 more contents
+Tammy Stockdale Happy Birthday Garythi
+Aprf 29 at 6:04pm• Like
+Annstasia Bithos Zambrano Happy Birthday
+Apri 29 at 8:41pm • Lke
+Event Sobedule:
+peptition: An Achies intend SK, Meness, Sports 5/2/014
+Starting Ceremony At Bell Tower
+6:00 am - g
+630 am-7
+/Walk Parts At Bell Tower
+ade At Main Siage
+i Classes And Sports Tournys
+Towney Amardi Al Muin Scape
+ine, Food, Acthttley, And Events
+5/3/2014
+5/3/2014
+5/1/2014
+800 am-s
+5/1/2014 830 am-32
+5/1/2014 11-45 am-12
+5/1/2014
+7:00mm-12
+4KIDS BIG Cardiol Mave. Swest. Give. - Home
+www.ihtera.org
+IG Cardle 5k. Fitness. Sports. Benefiting 4KJDS of South Florida - Join u
+May 3, 2014 for an amazing day of finess, sports, actitles, food an
+fun in the park, while supporting its in ortis,
+Uke ' Conrrent • Share
+Anastasta Bitos Zamiyano Res this.
+Farmer Jaffe Weissing shared a lnk,
+Aprl 29
+*Colleges and #un versities need to face the facts about
+#sexualassault,* #VicePresidentBiden sald in a statement as a 20-
+page report was released, "No more turning a blind eye or
+pretending it doesn't exist.
+topp
+White House releases report on sex
+assaulte at colleges
+www.weshingtonpost.com
+Like: Corrent Share
+Golans Mustafa Mes this.
+canpuses and also plan to chalenge coleges to survey their students
+next year about sexual misconduct and other safety issue.
+Aprl 29 at 9:49am • Lie
+E Aper Jatte Welsing
+Jain us in wishing Kristen Wagner a Happy Birthday!
+https://www.facebook.com/Farmer.JaffeWeissing
+PAper arre Welssing shared a bik.
+Farmer Jaffe Wess ng continues to evaluate legal claims against
+329
+
+
+Case 9:08-cv-80736-KAM Document 247-5 Entered on FLSD Docket 05/02/2014 Page 5 of 12
+52/2014
+Styker Corporation over their 'recalled' # Rejuvenate & #ABGII
+hip implants. Any questions welcome.
+http://www.pethtajustce.com/stryker-lawsults
+& ABO IT
+minis
+STRYKER HIP RECALL LAWSUITS
+www.painto unice.com
+Nationwide Case Evaluations Involving lawsuts against STRYKER HIP
+REPLACEMENTS following a recall of the REJUVENATE & ABG I. STRYKER
+REJUVENATE and ABG Il modular-neck femoral hip systers recalled in July
+2013.
+Uke " Comment ' Share
+Uke ' Coment ' Share
+1D people lke this.
+Christina Fitch Happy Bethday! i
+Aprl 2B at 3:50pm - Lke
+Anastasia Bithos Zambrano Happy Brthday
+Aprl 2B at 8.50pm • Like
+69
+Aprt 25
+Farmer Jaffe Welssing shared a lnk.
+Newsweek examines Mirena TUD lawsuits and growing number of allegadons and claims involving use the contraceptive. Do the benefits
+outweigh the risks? Are they as safe and effective as clalmed? Those questions remain at the heart of ongoing lawsuits and ligation. Farmer
+Jalfe Weissing Gabe Zambrano remains an original thought leader on the controversy and we are investigating clalms, as well as accepting
+new cases. Contact us with questions, http://www.newsweek.com/2014/05/02/courtroom-controversy-bet:nd-popular-contraceptive-mirena•
+248443.html
+The Courtroom Controversy Behled Popular Contraceptive Mirena
+Uhe Corment - Share
+Bonnie Manis Mes this.
+7 Farmer Jaffe Welss
+Daily Mall reviews 11th Circult decision and Sun Sentinel article reagarding Jeffrey Epste n. Rolated links appear below.
+https://ww.facebook.com/Farmer.JaffeWeissing
+4/29
+
+
+Case 9:08-cv-80736-KAM Document 247-5 Entered on FLSD Docket 05/02/2014 Page 6 of 12
+101
+Beach County Sheriff'& Ullice
+Sox offendar: Jeffrey Epotein served 13 months in
+prison in 2007 for relations with teen girts
+Like - Comment • Share
+Made Une likes this.
+Farmer Jaffe Weissing http://www.dalynad.co.uk/_/B8onawes-sex-vclrm.
+Billionaire's victims to see negotiations that led to lenient sentence
+www.dadymot.co.uk
+The Florida financier had counted numerous celebrities, poiticians and socialt.. See More
+Apl 23 at 5:49pm - Uke •
+Farmer Jaffe Welssing http://www.sun-senunel.cony./f-jefirey-epsten.
+Victims win right to see negotiations that led to 'lenient' plea agreement for billionaire sex..
+www.sun-sentmel.com
+Ded a Palm Beach blionaire being Investigated for having sex with young girls ... See Mo'e
+Aprt 23 at 5:49pm • Uke • 1
+Farmer Jaffe Welssing shared a ink.
+April 23
+Appeals Court Rules in Favor of Crime Victims' Rights in
+Registered Pedophile Jeffrey Epstein Case http://hub.am/1ig9303
+FREE CASE
+Appeals Court Rules In Favor of
+Crime Victims' Rights in Registered
+EVALUATION
+Pedophile Jeffrey Epstein Case
+http://www.pathtolustice.com/bbog/bwt/3
+CAD MORE:
+Uhe - Comment - Share
+Made Line likes this.
+an are wear shared a he.
+https://www.facebook.com/Farmer.JaffeWeissing
+5/29
+
+
+'Case 9:08-cv-80736-KAM Document 247-5 Entered on FLSD Docket 05/02/2014 Page 7 of 12
+Join us in welcoming attorney #AdamHorowitz to the Farmer Jaffe Weissing Team. Adam Joins attorney Brad Edwards to further expand the
+firm's nationwide #CrimeVictimsR ghts and #SexualAbuse Practice Group.
+http://www.pathtojusbce.com/adam-horowitz/
+Adam Horowitz
+Lie - Comment - Share
+7 people like this.
+Sandra K, Simpson Johnson Welcome aboard Mr. Horowitz.
+Aprl 23 at 10 36am" Uke
+Rebeca Misdraji Flelscher Hazal tovi
+Aprf 24 at 7:57am Ike
+fArmer afre Wetsing shared a ink.
+"Dur dients want to see Mr. #Epstein held accountable for the numerous ifsexoffenses he committed against many children," said
+#BradleyEdwards, the women's tral counsel and a partner at Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman in Fort Lauderdale.
+Prosecutors Must Turn Over Docs In Billonalre Sex Offender Jeffrey Epstein Case
+le: Comrent • Stare
+2 people lice this.
+1 Armer batte weissing shared a hik.
+Apri 12
+The front page of today's Sun-Sentinel - Victims w n right to see
+negotiations that led to lenient" plea agreement for bill onaire sex
+offender JeffreyEpsten.
+Armer Jaffe Weissing shared a lik.
+Aprl 22
+Additional news coverage on attorney #BradEdwards case against
+#JeffreyEpstein, Th sis a big victory for his clients and for
+#crimevictims.
+Victims win right to see negotiations that
+led to 'lenlent plea agreement for
+billionaire sexwww.sun-sentine!.com
+Act case
+www.washingtonpost.com
+Lke • Corment • Share
+8 people ike this.
+Uke: Coment Share
+§ people Me this,
+( pazer affe Welssing shared a bk.
+In recent years, the number of #cyclists and pedestrians killed
+and # njured in #crashes in #Broward and #PalmBeach counties
+has spiked.
+https://ww.facebook.com/FarmerJaffeWWeissing
+629
+
+
+• Case 9:08-CV-80736-KAM Document 247-5 Entered on FLSD Docket 05/02/2014 Page 8 of 12
+Farmer Jaffe Welssing
+i Farmer Jaffe Wetssing Tineline
+Recent
+Poolse
+Like
+Sunrise pushes pedestrian, bike safety
+www.sun-sentinel.com
+Pokce are targeting two Dalland Park Boulevard intersections with a high
+number of bicycle and pedestrian crashes, alming to educate everyone
+about the rules of the road.
+Ike ' Comment • Share
+Armer alte Weissing shared a int.
+This is one more step in the fight by victims' attorneys Brad Edwards and Paul Cassell to overturn the secret deal, which saved Epstein from
+facing serious federal charges and serving 5 grificant prison time.
+not rag
+/ Recent
+2014
+2013
+2012
+2011
+2010
+Founded
+Sponsored
+LogoSportswear - !
+logosoftwear.com
+LO
+SPORTSWIAD
+Si
+SI
+Ja
+Pl
+Up to 30% off
+vstaprint.com
+Appeals court rules against sex offender
+Like • Comment • Share
+6 people live this.
+} Made Line It's a very good day. I1th dircut got it right. Congratulations
+Apri 21 at 11:33am• Lie
+VI
+Her Carry On Wipe :
+lafreshgroup.com
+YI
+51
+Farmer Jaffe Weissing shared a ink,
+Aprt 18
+A #TampaDaySchoo' principal has been arrested afer am:lesting
+a student he befriended after the death of his father. The K-8
+school specializes assisting students who have m Id to moderate
+#learningdisabilices, dyslexia, anety, and ADHD.
+Farmer Jaffe Weissing shared a ink,
+Aprf 17 • Edted
+Local #teacher rearrested and accused of #sexuallyassaulting a
+#student after being warned by school officials not to spend any
+time alone with the #victim.
+Citizen ECO-DRIVE
+amazon.com
+Cha: (Off
+Tampa Day School principal arrested after authorities say he
+molested a student
+www.tampabay.com
+A Tampa Day School prindpal was arrested Thursday after authortles
+sall he inapproprately touched a 14-year-old male student he had
+befriended, according to an arrest report.
+Like Comment • Sha r
+Bonnie Manis ikes this.
+https:/www.facebook.com/Farmer.Juffe/Veissing
+Broward teacher accused of sey with teen had been warned to
+stay away
+articles.sun-sentinel.com
+A regious school biology teacher accused of having sex with one of tits
+14-year-old students in a car parked behind a strip mull is now facing
+federal charges. Eric Richard Beasley, 24, of...
+Lie ' Corrent " Shore
+7129
+
+
+• 5220Base 9:08-CV-80736AM uda/ment 45 tell one goblet 8702/20924e Page 9 of 12
+Farmer, Jaffe, Weissing,
+Edwards, Fistos & Lehrman, P.L.
+• 1-B55-700-PATI
+Proven Result
+• Medi
+Blo
+search
+Search
+Surrent Articles IE BSS Feed
+Appeals Court Rules In Favor of Crime Victims' Rights in Registered Pedophile Jeffrey E Epsteln Case
+Posted on Wed, Apr 23, 2014
+Case 11292 1vali Hide 84)18/2014 Fago. 1 of 23
+[PUBLISH)
+IN THE UNITED STATES COURT OF APPEALS
+FUR THE ELEVENTH CIRCUIT
+No 13-13923
+D.C Docker No. 9.06-cv-80736-KAM
+JANE DOE NO. I.
+JANE DOE NO. 3.
+versus
+UNITED STATES OF AMERICA.
+Defendant.
+ROT BLACK.
+MARTING WEINBERG.
+JEFFREY EPSTEIN.
+Intervenors-Appellants
+spents from the Uwiied Sintes District Cour
+or see Soulera Dacric of Florid
+(April 16. 2014)
+Befue PRYOR nud MARTIN. Cucuit Jaipes and HONENWELL." Dovici
+"Hanenble Charlese Ederade Honcywell. Unted States Easinci Juipe fos die Middle Drainct
+of Flarala, rituse by desipatien
+http://www.pathtojustice.com/blog/bid/343584/Appeals-Court-Rules-In-Favor-of-Crime-Victims-Rights-in-Regislered-Pedophile-Jeffrey-E-Epslein-Ceselt.U20n. 1/4
+
+
+On Friday, April 18, 2014, the Eleventh Circuit ruled that discovery can move forward in an important Crime Victims' Rights Act case
+that my co-consel Paul Cassell and I (Brad Edwards) have been litigating for nearly six years. The namow issue before the Circuit was
+whether proseculors and defense altoreys share an absolule privilege, lo the exclusion of even the viclims of the crime, so as to
+prevent anyone (including the victims) from knowing anything about the plea discussions. The District Court ruled that no such privilege
+exists and the 11th Circuit has now agreed. In this case, the ruling means that the victims will have a chance to review the
+correspondence exchanged between Epslein and prosecutors to leam how exactly the secretive deal was reached while the victims
+were lead to believe a prosecution was underway. The ruling will also get the victims one step closer to returning to the district court and
+seeking to invalidate the plea agreement that was consummated in violation of their rights. We hope that the case will ultimately set an
+important precedent establishing the timing for when victim's rights are triggered and ultimately prevent prosecutors from keeping
+victims in the dark about the plea deals reached with perpetrators.
+Ilerida Department of Law Enforcement _Sexual CHender /Preditor Olver
+Ock Hack to Track thin QUandar
+Deslenation: Seaul Oitender
+Hanse: AFFREY E EPSTEN
+Status:
+Baltand - Recuaced to
+Barisler
+Department of W35715
+Conectivon #:
+Search the Dest of
+Comecklem Website
+Date ef Bletra
+01/23/1953
+Rae 1
+White
+Sex:
+Male
+Hair:
+Gray
+Eyes
+Blum
+Haight: | 600
+Waight:
+109 bs
+JET FREY E EPSTERI
+Date Of Photo: 07/25/2013
+IPSTEIN is decistered as a Stapal Cifender,
+Podsive identification cannot be estatushed unless •
+fingerprint compartson E. mude.
+Here are the important facts, taken from the Eleventh Circuit's opinion: In 2006 the FBl began investigaling allegations that Jeffrey E.
+Enstein had sexually abused dozens and dozens of minor giris. The United States Altomey's Office for the Southem District of Florida
+accepted Epstein's case for prosecution, and the FBl issued victim notification letters lo my two clients, minors Jane Doe No. 1 and
+Jane Doe No. 2, In June and August 2007. Extensive plea negotations ensued between the United States and Epstein. Despite the
+investigation revealing that Epstein had molested more than 40 minor girls, in late 2007, the United States entered into a nonprosecution agreement (NPA) with Epstein - essentially agreeing lo Immunize Epstein for all of the Federal Sex crimes he committed in
+exchange for his offer to plead guilty to minor Florida state offenses (e.g., solicitation of prostitulion), for which he served the majority of
+his "Ume" in a lush private office, as opposed to a cell.
+During the Federal Plea negoliations, not only did the United States neglect to "meaningfully confer" with the victims before it entered
+into the agreement with Epslein, it also concealed its existence of the agreement for at least 9 months. For example, the United States
+sent post-agreement letters to the victims reporting that the "case is currenty under Invesligation" and explaining that "Ighis can be a
+lengthy process and we request your continued patience while we conduct a thorough investigation." Some of those letters were
+delivered to victims as lale as May, 2008 - many months after the NPA was signed and just before Epstein's state court plea that served
+to permanently extinguish the rights of victims.
+http://www.pathtojusilce.com/blog/bld/343564/Appeals-Court-Rules-in-Favor-of-Crime-Victims-Righis-In-Registered-Pedophile-Jetfrey-E-Epstein-CaselfU20n.. 24
+
+
+On June 27, 2008, the United Stales Informed me that Epslein planned to plead guilty to the Florida state charges three days later. But
+the United States failed to disclose that Epstein's pleas to those state charges arose from his federal non-prosecution agreement and
+that the pleas would bar a federal prosecution. As a result, the victims did not attend the state court proceedings. Ih fact, Federal
+prosecutors asked that I express my concerns about Mr. Epstein in a letter addressed to them. I sent that letter on July 3, 2008 detailing
+the reasons why federal prosecution of Mr. Epstein were extremely important for the safety of children. This exercise was obviously
+futile, especially in light of the fact that the plea to which Epstein had already entered brought an end to any chance of federal
+prosecution.
+On July 7, 2008, while under the mistaken belief (along with my clients) that a federal plea deal was imminent and should be stopped - at
+least to give my clients a chance to first confer with the prosecutor as to the terms of the plea deal - I filed a pettion alleging that Jane
+Doe No. 1 was a viclim of federal sex crimes committed by Epstein and that the United States was wrongfully excluding her from plea
+negotlations. We also alleged that the prosecutors had violated her rights under the Crime Victims' Rights Act CVRA) - specifically
+her rights to confer with faderal prosecutors, to be treated with faimess, lo receive timely notice of relevant court proceedings, and to
+receive information about restitution. The Uniled States response was the first time we realized that there was no imminent federal plea
+to stop - the deal had already been done. By telling my clients to be patient, and by having me spend lime writing letters about the need
+to prosecute Mr. Epstein, the United States had effectively run out the clock on my clients' rights. Remarkably, the United States, in its
+pleadings, defended the allegations that it had violated the victims" rights by claiming the Act did not apply to pre-Indictment
+negolations with potential federal defendants; therefore, the victims' "rights" had never been triggered and thus could not have been
+violated. The defense was that the victims had no rights...despite the CVRA.
+After Jane Doe No. 2 joined the initial petition, the district court (Marra. J.) found that both women qualified as "crime victims" under the
+Act. The disirict court later rejected the Govemment's argument that the CVRA only applies after a federal criminal indictment has been
+filed.
+Among other relief, we sought rescission of the non-prosecution agreement as a remedy for the violation of the victims' rights. To make
+the case for such a remedy, we moved for discovery of the correspondence between the United States and Epstein's attomeys during
+the plea negotiations. Epstein's attorneys intervened, arguing thal Federal Rule of Evidence 410 and Federal Rule of Criminal
+Procedure 11 create a privilege for plea negotiations blocking release of the correspondence. They also argued that the court should
+find that the materials were protected under the work product doctrine or, altematively, should be prolected under a new *common law
+privilege for plea negoliations." Yes, Epstein's defense attorneys argued al the District level and appellate level that absolute
+confidentiality should exist between defendanis and prosecutors to the exclusion of everyone - including the victims of the crime.
+The district court first puled that rescission of the plea agreement was a possible remedy under the Act. The court then ruled that we
+were entitled to review the correspondence, rejecting all of Epstein's arguments.
+On Friday, the Eleventh Circuit affirmed the district court's decision. At pp. 18-22, the Circuit concluded that there was no basis for
+restricting access lo the correspondence when the victims had a legitimate need to review. The Circuit rejected, for example, the work
+product argument:
+Disclosure of work-product materials to an adversary waives the work-product privilege. See, e.g., In re Chrysler Motors Corp, Overnight
+Evaluation Program Litig., 860 F.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir, 1981). Even if it shared the
+common goal of reaching a quick settlement, the United States was undoubtedly adverse to Epstein during its investigation of him for
+The Circuit also declined to recognize a new privilege for "plea bargaining":
+As a last-ditch effort, the intervenors contend that "Ti)f more is needed in addition to the plain language of Rule 410 to preclude
+disclosure of the correspondence to plaintiffs, it can be found in the conjunction of Rule 410, the wark-product privilege, and the Sixth
+Amendment right to the effective assistance of counsel in the plea bargaining process," but this novel argument fails too. As explained
+above, Rule 410 does not create a privlege and the intervenors waived any work-product privilege. The intervenors concede too that
+the right to counsel under the Sixth Amendment had not yet attached when the correspondence was exchanged. Lumley - City of Dade
+City. Fla., 327 F.3d 1186, 1195 (11th Cir. 2003) ('/The Sixth Amendment right to counsel ordinarily does not arise until there is a formal
+commitment by the government to prosecute," such as a "formal charge, preliminary hearing, indictment, information, or arraignment.").
+The "conjunctive" power of three false claims of privilege does not rescue the correspondence from disclosure....
+The Supreme Court has identified several considerations relevant to whether a court should recognize an evidentiary privilege—-the
+needs of the public, whether the privilege is rooted in the imperative for confidence and trust, the evidentiary benefit of the denial of the
+privilege, and any consensus among the states, Jaffee | Redmond, 518 U.S. 1, 10-15, 116 S. Cl. 1923, 1928-31 (1996)—but none of
+these considerations weighs in favor of recognizing a now privilege to provent discovery of the plea negotiations. Although plea
+negotiations are vital to the functioning of the criminal justice system, a prosecutor and target of a criminal investigation do not enjoy a
+relationship of confidence and trust when they negotiate. Their adversarial relationship, unlike the confidential relationship of a doctor
+and patient or atlomey and client, warrants no privilege beyond the terms of Rule 410. See Jaffee, 518 U.S. at 10, 116 S. Cl. at 1928.
+But the victims would enjoy an evidentiary benefit from the disclosure of plea negotiations to prove whether the United States violated
+Their nights under the Act.
+The bigger issue Is whether the Crime Victims' Rights Act is going to be taken seriously by proseculors and the courts. We have a very
+strong case that, prodded by Epstein, the federal prosecutors deliberately concealed the sweetheart plea deal they had cooked up with
+him to avoid public criticism of the deal. But the CVRA was the law of the land and required the prosecufors to confer with the victims
+about the deal - before it was made. Iam hopeful that this case substantates and advances the rights of crime victims in the criminal
+http://www.pathtojustice.com/blog/bld/343584/Appeals-Courl-Rules-in-Favor-of-Cr|me-Victims-Rights-In-Registered-Pedophile-Jelfrey-E-Epslein-Case#U20n. 3/4
+
+
+•serpase 9:08-cv-80736p/Aldar Dacumento 475/cuntared-@gFt&De@ocket:05/0242014 Page 12 of
+process at an early stage, and that ulmately the violation of our cliffs rights in this case can be resurected through the invalidation of
+this agreement that was reached in violation of their rights.
+Tags: Crime Victims Bights.Act, CVRA, Jeffrey E Epstein, Elorida Registered Sexual Ofender
+Post Comment
+Name
+Email
+•
+Website (optional)
+Comment
+Allowed tags: <a> link, <b> bold, <i» italics
+• Receive email when someone replies.
+O Subscribe to this blog by email.
+[Post Comment
+© 2014 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.
+All rights reserved. Sitemap Legal Disclaimer
+Your Path
+to Justice
+Begins
+and Ends
+With Us!
+About u
+Practice Areas
+• Atterney:
+Proven Result
+: Bagurces
+© 2013 - Path To Justice
+FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L.,
+425 North Andrews Avenue, Suite 2, Fort Lauderdale, FL 33301
+http://www.pathlojustice.com/blog/bid/343584/Appeals-Court-Rules-in-Favor-of-Crime-Victims-Rights-in-Registered-Pedophile-Jeffrey-E-Epstein-Case#.U20n. 4/4
+
+
+Case 9:08-cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 1 of 9
+
+
+
+Case 9:08-Cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 2 of 9
+CASE NO. 08-80736-CIV-MARRA/JOHNSON
+JANE DOE #1 and JANE DOE #2,
+Plantiffs,
+UNITED STATES OF AMERICA,
+Defendant,
+ROY BLACK, et al.,
+Intervenors
+PROPOSED
+ORDER OF CONFIDENTIALITY ("PROTECTIVE ORDER")
+THIS CAUSE came before the Court upon the Intervenors' Motion For a Protective
+Confidentiality Order and Incorporated Memorandum of Law. For the reasons that the Court
+will set forth in a separate forthcoming Order, the motion is hereby GRANTED.
+Now, therefore, it is ORDERED that:
+This Protective Order applies to all correspondence between the United States
+Attorney's Office and the Intervenors, including any attachments thereto, that was the subject
+of the Court's Order of June 18, 2013 (Doc. 188), hereinafter referred to as the "Confidential
+Discovery Material" or "CDM."
+The parties shall designate the CDM by marking them on the face of the
+writing:
+
+
+Case 9:08-CV-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 3 of 9
+CONFIDENTIAL - SUBJECT TO STIPULATION AND ORDER OF
+CONFIDENTIALITY.
+The marking shall be affixed in such a manner as not to obliterate or obscure any written
+matter. With respect to discovery materials produced electronically, the designation of
+Confidential may be made on the outside of the disk or cd.
+3.
+In the event that the Producing Party inadvertently fails to designate any CDM
+as confidential in this Action, it may make such designation subsequently by notifying all
+parties to whom such discovery material was produced, in writing as soon as practicable.
+After receipt of such notification, the parties to whom production has been made will treat
+the discovery material and all copies as having been designated as CDM.
+The parties agree that the CDM, or any summary thereof, shall be used solely
+for the purpose of this Action and for no other purpose without prior written approval from
+the Court or the prior written consent of the Producing Party and the Intervenors. All persons
+receiving or given access to CDM in accordance with the terms of this Protective Order
+consent to the continuing jurisdiction of this Court for the purposes of enforcing this
+Protective Order and remedying any violations thereof.
+5. a. CDM shall not be disclosed to anyone other than the following categories of
+persons:
+(i) The Court (and any appellate court), including court personnel.
+-2-
+
+
+Case 9:08-Cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 4 of 9
+(i) Court reporters (including persons operating video recording equipment at
+depositions) and person preparing transcripts of testimony to the extent necessary to prepare
+such transcripts, with the consent of counsel.
+(ii) Plaintiffs' attorneys who appear as counsel of record in this case, including the
+attached list of paralegals, clerical, secretarial and other staff employed or retained by such
+counsel, provided that such staff and employees also comply with the provisions of
+Paragraph 6 hereof.
+(iv) Retained consulting or testifying experts, advisors and consultants, including
+persons directly employed by such experts, advisors and consultants (collectively "experts")
+but only to the extent necessary to perform their work in connection with this Action.
+( Any additional persons as counsel for the parties and Intervenors shall consent to
+in writing before the proposed disclosures.
+All parties and their respective counsel, paralegals and employees and
+assistants of all counsel receiving the CDM shall take all steps reasonably necessary to
+prevent disclosure of the CDM other than in accordance with the terms of this Protective
+Order.
+C.
+Disclosure of the CDM other than in accordance with the terms of this
+Protective Order may subject the disclosing person to such sanctions and remedies as this
+Court may deem appropriate, including without limitation, contempt, injunctive relief and
+damages.
+-3-
+
+
+Case 9:08-cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 5 of 9
+No copies of any CDM shall be made or delivered to any person other than
+those categories of persons referred to in paragraph 5 above, and even then only in
+accordance with paragraphs 7 and 8 herein.
+7.
+CDM may only be disclosed to persons who are not included in those
+categories referred to in paragraph 5.a. above, upon prior written consent of the Producing
+Party's and Intervenors' counsel. If either the Producing Party's counsel or the Intervenors'
+counsel refuses to give consent, the CDM shall not be disclosed. The Receiving Parties may
+apply to the Court for an order of relief, on notice to the Producing Party and Intervenors.
+8.
+Any person referred to in paragraphs S.a.ili through 5.
+above who is
+furnished a copy of any CDM shall first be given a copy of this Protective Order and required
+to read it and be bound by its terms.
+9.
+At any time during this Action, the Receiving Parties may challenge the
+designation of CDM as confidential by written notice to the Producing Party's counsel and
+counsel for the Intervenors specifying by exact bates number the materials in dispute and the
+precise nature of the dispute with regard to each document or portion thereof. The parties
+and Intervenors shall have twenty (20) days from receipt of the written notice to determine
+if the dispute can be resolved without judicial intervention and, if not, the Receiving Parties
+any move for an Order removing the confidential designation. The Receiving Parties shall
+have the burden of proof on such a motion to establish good cause for removing the
+confidential designation and treatment.
+-4-
+
+
+Case 9:08-cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 6 of 9
+10. No party shall be obligated to challenge the propriety of any designation, and
+a failure to do so shall not preclude a subsequent challenge on the propriety of such
+designation and shall not constitute an admission that any information is, in fact, confidential.
+11. In the event a party seeks to file any pleading, brief or memorandum or other
+document purporting to reproduce, paraphrase or summarize any CDM or portions thereof,
+that party shall take appropriate action to insure that the documents receive proper protection
+from public disclosure and shall seek leave of Court to file the document under seal in
+accordance with Local Rules of the United States District Court for the Southern District of
+Florida.
+12. a.
+In the event that a party intends to file CDM with the Court in support
+of, or in opposition to, a non-discovery motion (e.g. motion for summary judgment or any
+other dispositive or substantive motion), the filing party shall take appropriate action to
+insure that the documents receive proper protection from public disclosure and shall seek
+leave of Court to file the document under seal in accordance with the local rules.
+The non-discovery motion filing and briefing schedule shall be adjusted
+and tolled to provide sufficient time for the Court to consider and rule on the motion seeking
+permission to file the documents) under seal.
+c.
+Once the matter has been resolved, the filing party may file the
+documents) in accordance with the parties' and Intervenors' agreement and/or the Court's
+instructions, as applicable.
+-5.
+
+
+Case 9:08-cV-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 7 of 9
+13. The CDM and/or other papers which are filed under seal shall be kept under
+seal until further order of the Court; however, said CDM and other papers filed under seal
+shall be available to the Court and counsel of record, and to all other persons entitled to
+receive the confidential information contained therein under the terms of this Protective
+Order.
+14. This Protective Order is intended to provide a mechanism for the handling of
+the CDM and is not intended to imply that any CDM is relevant or admissible in this Action
+or any other litigation. Any party may move for relief from, or general or particular
+modification of, the mechanism for maintaining confidentiality herein set forth, or the
+application of this Protective Order in any particular circumstance, and each party
+specifically reserves all rights to object to the relevance or admissibility of any information
+produced in accordance with this Protective Order on any grounds it may deem appropriate.
+15.
+If a party receiving CDM in accordance with the terms of this Protective Order
+is served with a subpoena or other process by any court, administrative or legislative body,
+or any other person or organization which calls for the production of any CDM, the party to
+whom the subpoena or other process is directed shall, within two business days of its service,
+notify the opposing party or parties and the Intervenors of the pendency of such subpoena or
+order and provide them with a copy of the subpoena or process and the date by which
+compliance is requested. Any party or the Intervenors opposing the production of the
+-6.
+
+
+Case 9:08-CV-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 8 of 9
+information demanded in the subpoena or process shall notify the party served of its
+objections as early as possible prior to the requested compliance date.
+16. This Protective Order may be amended with leave of Court, by the agreement
+of counsel for the parties and Intervenors in the form of a stipulation submitted to the Court
+for approval, or by the Court sua sponte after affording the parties and Intervenors the
+opportunity to be heard. If the parties and Intervenors cannot agree to an amendment, then
+a formal motion to amend must be filed with the Court. This Protective Order is intended
+to regulate the handling of CDM and documents during this litigation, but shall remain in full
+force and effect until modified, superseded or terminated on the record by agreement of the
+parties thereto or by order of the Court.
+17. All counsel of record in this Action shall make a good faith effort to comply
+with the provisions of this Protective Order and to ensure that their agents, employees and
+clients do so as well. In the event of a change of counsel, retiring counsel shall notify new
+counsel of their responsibilities under this Order.
+18. This Protective Order does not restrict or limit the use of CDM at any hearing
+or trial, which may be the subject of a further protective order and/or appropriate court
+orders. Prior to any hearing or trial at which the use of CDM is anticipated, the parties and
+Intervenors shall meet and confer regarding the use of the CDM. If the parties and
+Intervenors cannot agree, the parties and Intervenors shall request the Court to rule on such
+procedures. Notwithstanding, this Protective Order shall remain in full force and effect until
+-7-
+
+
+Case 9:08-cv-80736-KAM Document 247-1 Entered on FLSD Docket 05/02/2014 Page 9 of 9
+modified, superseded, terminated on the record by agreement of the parties and Intervenors
+or by order of the Court.
+19. Within sixty (60) days after the conclusion of this Action, whether by
+judgment, settlement or otherwise, including conclusion of any appeal, all CDM including
+but not limited to materials furnished to consultants and/or experts shall be returned to the
+Producing Party unless the parties stipulate to destruction in lieu of return; provided,
+however, that counsel of record in this case may retain for their files, copies of any of their
+work product, pleadings, court filings, brief, and exhibits, which incorporate or contain
+documents, information or material designated as "CONFIDENTIAL".
+20. Upon final termination of this Action, whether by judgment, settlement or
+otherwise, including all appeals, the Clerk of the Court shall return to counsel for the parties,
+or destroy, any materials filed under seal. Before destroying any document filed under seal,
+the Clerk of Court shall advise all parties of their option to accept return or destruction and
+shall allow no less than thirty (30) days from issuance of the notice for counsel to respond.
+In the absence of a response, the Clerk of Court may destroy documents filed under seal.
+DONE AND ORDERED in Chambers at West Palm Beach, Florida, this day of
+May, 2014.
+Kenneth Marra
+United States District Judge
+cc:
+All counsel
+-8-
+
+
+Entered on FLSD Docket 05/02/2014 Page 1 of 22
+COMPOSITE EXHIBIT 2
+
+
+'Case 9:08-CV-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 2 of 22
+Altorneys Say Miami Prosecutors Violated Crime Victims' Rights Act | Main Justice
+JEGOTIATING WITH THE DOJ:
+STRATEGIES FOR OPTIMAL RESULTS
+FREE Webinar - Wed., April 13
+MAN JUSTICE
+BRACEWELL
+&GIULIANI
+Nusul Got Tipa7 I ogiss or egister
+Search
+MAIN JUSTICE
+ITICS, POLICY AND THE LAW
+T ANTI-CORRUPTION
+orneys Say Miami Prosecutors Violated Crime Victims' Rights Act
+tephanie Woodrow ] March 22, 2011 11:52 am
+= Printable Version
+:. Rights/Raprinis
+in attorneys for two girla who conlend they were assaulted by billionaire and
+dad sox offander Jeffrey Epstain fied court papers on Monday Claiming the
+IU.S. Attorney's office violaled the Crime Victims' Rights Act by signing a nonprosecution agreement with Epstein
+ut notifying them, the Palm Beach Daily News reported
+Epsiain served 13 menthe in jall from June 2000 to July 2009 for one atole count of soliciting
+an underago girl for prostitution As a rosul, he is required to register as a sex offender Whille
+he wasnt proseculed for additional charges, more than 40 girts under the age of 18 say they
+came to his home and gave him massages. During the massages, they say, he masturbated
+and sexualy assaulled them
+y Epsiein (gavI
+Brad Edwards and Paul Cassell, attomeys representing two of his allaged victims, say in
+the filing that the U.S. Allomey's office for the Southern District of Flord of dailberalaty
+misled the victims by tetling them there was an ongoing investigation Into their clalms.
+However, they say, the office was concealing the fact that they already had signad a
+osocution deal with Epstein.
+ding to the moton, the US. Attorey's office in January 2009 and May 2000 sent "Talse notfication" afters in to
+ahis alleged victims saying "ighis case is cumonity under invaslgation." However, the office had signod the agreement
+ipatain In September 2007.
+Marmays want a court hearing during which they will ask that the agreement be invalidated because it violated the
+is' rights. In the motion. the storays claim the agreement is legal because the govemment did not protect the
+fressionally mandated rights of victims before it entered this agreament."
+dge grants the request, Epstein could be charged by the U.S Altomuy's office. i ho were charged and convicted on
+al charges, he could be sentenced to 10 years to life for esch charge.
+ding ta the motion, "The only reason that the (US. Allomey's office) concasied the axistence of the non-prosucution
+ment from the victims was not to comply with some legal restriction, but rather to avold a firestorm of public
+aversy that would have erupted if the sweetheart ples deal with a pollically connected billonaire had been revealed.*
+1 Valle, special counsel for the US. Altomey's Office Southem District of Florida, in an email to the newspaper that the
+Altomney's office will respond in court flings.
+ever, as we stated more ihan two yuars ago in July 2008 In our response to the plaintitle then-emergency pestion for
+cement of the Crime Victim Rights Act, the CVRA was not violated because no federal chargos wore avar flod in the
+em District of Floride," Volle said. "Because the matter remains pending in court, lt would be inappropriate at the time
+ivido addisional comment on the merits of the current mation."
+Wanted
+Lawyers with
+DOJ Experience
+4/7/11 1 38 PM
+obs
+sernate
+JUSTJOBS
+US. ATTORNEYS CHART (Interactivo)
+track madership congas in Do 438 > Atomey
+afices, with Bush holdevds and Otama
+tomlidsics
+MILLER
+CHEVALIER
+Providing cllents with proven
+experience and innovative solutions
+to complex compliance and
+enforcement issues inside the
+Beltway and around the globe,
+Miller & Cheralias Chartered
+milleschenaier com
+COVINGTON
+COVINGTON & BURLINO LLP
+Recognized for its Leading
+White Collar Crime and
+Anti-Corruption Practices by
+Chambers and Legal 500
+Decisions about ache, urder and Posa
+to prosecute have always been -and
+cretley branch." - Attorney General
+Eric Holler discussing pressure froma
+members of Congress to prosecute
+Khalid She ill Mohammed befure a
+militory commissint rather thora in
+http://www.mainjustice.com/2011/03/22/attorneys-say-mlaml-prosecutors-violated-crime-victims'-rights-act/
+
+
+
+Case 9:08-CV-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 3 of 22
+Attorneys Say Miami Prosecutors Violated Crime Victims' Rights Act | Main Justice
+4/7/11 1:38 PM
+feleral eurt.
+uma To Tap Non-Proft Hood For DOJ Crime Victims Post
+wmakers Bompan Lack of Funding For Victims' Righis
+seculor Who Wielated Rights of Islamic Graupa by Accidont is Now U 5 Allornay
+mocratic Donor Victated Spirit of Elect on Laws, LA Prosecutors Say
+deral Proseculora Violated Laws, Elhics Rulas in 201 Casos Since 1998, Study Finds
+IDER POST
+D'OL Asks Slalas lo Help Enforce ADA Prolastians.for Encing Hiring Freeze. Карада M.S. Alотвх.Warts Moto
+nents are closed.
+JUSTICE DEPARTMENT MEWS
+KELEASES
+Assoçiala Allomey General Tom Perrelil Speake al
+the Department of Educallona00s Gender-Based
+Violance Summi:
+omverse Technology INC. Agrees to Pay S1.
+Illion Penalty lo Resolve Violationa of Bi
+Foreion Corrupl Praclices Act
+Allorney General Eric Holder Speaka al Nalional
+Açllan Network#@ fra 13th Annual Convention
+Shenandoah, Pennsylvania, Man Senteced lor
+Involvemant in the Fatal Beating of Luis Ramirez
+New Jersey Wariewator Tresment and Chemical
+Supply Company and Owner Senlanced for Thair
+Role in Fraud Conspimcy
+Alabama Doctor and Husband Charged with Tak
+Evasion
+Tillone cooters eat at Federa as Liens for
+Enforcement
+SC Corporation Resoives Foreign Corru
+ractices Act Investigalion and Agrees to Pay
+$218.8 Million Criminal Penalty
+Iomey General Erfe Holder Speaks at Nationi
+arum on Youth Violence Prevention Summi
+Gose inmard Slins
+Department of Justice
+House Judiciary Committes
+Office of Gavemment Ethica
+Office of Lagal Counsel
+Office of Profeasional Responsibilty
+Senale Judiciary Commities
+na | About | Advertie | Jobe / Privacy Palier | Torma at Uar
+Copyright © 2011 WDC Modia LLC
+http://www.malnjustice.com/2011/03/22/attorneys-say-mlam/-prosecutors-vlotated-crlme-victims"-rights-act/
+
+
+
+Case 9:08-CV-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 4 of 22
+Altorneys want Jeffrey Epsten agreement thrown out
+4/7/11 1:37 PM
+Prim Besch, FL
+82°
+Toman de Laston To Lar M
+JUST A CLICK AWAY!
+Diningi Direelore
+PalmBeachDailyNews.com
+Home > Palm Beach Nows
+Attomeys want Jeffrey Epstein agreement thrown out
+LATEST NEWS
+Today Thursday Apni 7.
+2011
+Talk at Soa Gull Cottago lo
+focus on genomica
+Palm Beach Women's
+Interollonal Film Festival
+detouts Thursray in support of
+women flimmakers
+Day Academy pupils revisit
+notable characters in Palm
+Beach listory
+Gov Scoff at Midtown
+Beach Give mo the list,' In
+lolls officials about beach
+conceins
+By MICHELE DARGAN
+DAILY NEWS STAFF WRITER
+Updated: 9:41 a.m Wednesday March 23, 2011
+Posiod: 7.21 p.m. Monday. March 21, 2011
+Email |
+Print |
+Sham 1
+Larger Type
+Court papers filed Monday say the U.S. Attorney's Office vlolaled
+the Crime Victims' Rights Act by signing a nonprosecution
+agreement with sex offender Jeffrey Epstein without notilying his
+victims
+Attorneys Brad Edwards and Paul Cassell, represonting Jane Doe
+#1 and Jane Doe #2, want a court hearing, where they will ask that
+the agreement be invalidated because, they say, the victims' rights
+were violated if that happens, it could open up the 58-year-ald
+Palm Beach billonaire to a slew of federal charges involving sex
+crimes with minors that were set aside by the agreement.
+The motion, filed Monday in federal court in West Palm Beach.
+accuses the U.S Allomey's Office of deliberalely misleading the
+victims by teling lhem the investigation was ongoing, while
+concealing they had already signed a deal with Epstein
+According to the motion, the U.S Altomey's Office sent 'false
+notification letlers in January 2008 and May 2008 to the victims
+saying "(this case is currenty under investigation" after the
+goverment had signed the agreement with Epstein in September
+2007.
+The only reeson that the (US. Altomey's Office) concealed lhe
+existence of the non-prosecution agreoment from the victims was
+not to comply with some legal restriction, but rather to avoid a
+firestorm of public controversy that would have erupted If the
+sweetheart plea deal with a pollically connected bitionaire had been
+revealed," the motion says.
+If Epstein were found gullty on federal charges, statutory penaltles
+ranged from 10 years lo life
+Inslead, the sealed pact was part and parcel of Epslein's
+acceplance of a stale plea deal, where he received an 18-month
+sentence for so iciling a minor for prostitution and soliciling
+prostitution. He served 13 months segregatod in a vacant wing of
+the counly slockade and was let out on work release six days a
+week for up to 16 hours a day.
+Edwards and other allorneys fought in court for a year before
+successfully getting the agreement unsealed in September 2009
+More than 30 minor giris were Identified as Epstain's victims in the
+nadi
+8 Site O Web
+(SEARCH
+Web Search by YAHOO!
+PALM BEACH ESTATE
+241 La Puerta Way, Palin Beach
+Enquisitely designed Meditertancan Palm Beach
+walled estate, a More Details
+COrCOTaR.COm
+1.2; Click here for the latest events! 2
+Find us on Facebook
+Palm Beach Daily News
+Like
+2,413 people like Palm Beach Dally News.
+Jackie
+Coharlans
+James
+Karen
+LEl faceboul social plugin
+MOST RECENT AlAUMS
+The Palm Beach
+Oners
+The Gonety of tha
+Four Are bena
+Pamela Roland
+http //www.palmbeachdallynews.com/news/attorneys-want-Jeffrey-epstein-agreement-thrown-out-1338111.html
+
+
+
+Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 5 of 22
+Attorneys want Jeffrey Epstein agreement thrown out
+4/7/11 1:37 PM
+More el
+Doe 1 and 2, who were 14 and 13, respectively, at the time of the
+Incidents, received monetary setllements in civil cases. They are
+among more than two-dozen underage girls who filed lawsuits or
+settled claims against Epstein, alleging they wore lurod to his Pair
+Beach mansion to give him sexually charged massages and/or sex
+in exchange for money.
+The motion fled Monday says the agreement Is illegal because the
+government did not protect the "Congressionally mandated rights of
+viclims before it entered this agreement."
+la Valle, special counsel for the U.S. Allorney's Office South
+trict of Florida, sald in an e-mail that the U.5. Attomey's Off
+will respond in court flings.
+*However, as we staled more than two years ago in July 2008 in our
+esponse to the plaintifis' then-emergency petilion for enforcemen!
+of the Crime Victim Rights Act, the CVRA was not violated because
+no federal charges were ever filed in the Southern District of
+larida." Valle said. "Because the matter remains pending in court, I
+vould be inappropriate at this time lo provide additional comment or
+the merits of the current motion."
+The attorneys reference e-malls and letlers from the federal office lo
+Epstein's lawyers acknowledging the government's legal obligation
+to inform victims about the pact. Tho e-mails are redacted in the
+motion because they are under seal. The attorneys filed a separate
+molion Monday to unseal the correspondence.
+*The reasonable inference from the evidence is that the U.S
+Allorney's Office wanted to keep the agreement a secral to avoid
+inlense criticism that would surely ensued had the victims and tho
+public leamed that a billionaire sex offender with polltical
+connections had arranged to avoid federal prosecution for numerous
+alony sex offenses against minor girls," the motion says "As part o
+his pattern of deception, the U.S. Allomey's Office discussed victim
+notificalion with the defendant sex offender and, afler he raised
+objections, stopped making notifications."
+Epstein sought "a higher level of review" within the Department of
+Justice, the motion says. "A reasonable inference from the evidence
+That Epstein usad his significant political and social conneclions t
+obby the Juslice Department to avoid significant federa
+prosecution," the motion states.
+Share thie articia:
+COMMENTS
+Commenta are closed
+HEWS
+SOCITY
+be a Calendar
+VEATHER
+ARTS
+Arte Calendar
+OBIUARIES
+LFESTYLES
+ADVERTISE
+SPECULL SECTIONA
+me 3 tem
+BUSHESS
+BLOGS
+COLUNHISTS
+Flash D
+REAL ESTATE
+http://www.palmbeachdallynews.com/news/attorneys-want-jeffrey-epsteln-agreement-thrown-out-1338111.html
+
+
+
+• •Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 6 of 22
+Attorneys want Jeffrey Epstein agreement thrawn out
+4/7/11 1 37 PM
+Copyible The Apr 7 13 33 34 ET 2011 AM Cose Paid seDit oks a Play Pacey A at up the terms of our wils ogreement Ponse road ll
+ECAPIETLARED
+COXEDIA
+http //www.palmbeachdallynews.com/news/attorneys-want-Jeffrey-epsteln-agreement-thrown-out-1338111.html
+
+
+
+. Case 9:08-CV-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 7 of 22
+News Reports ubout Billionaire Pedophile Jeffrey Epstein Highlight the Importance of Vi... Page 1 of 3
+BRIEFINGWIRE
+A Free Press Release: Websito
+Briefing Search
+Keyward:
+Calegury
+[Clear | / Search |
+Submit Your Press Rglonge
+Biz Pirectory
+RSS Feed O
+SEO TiDE
+Questions?
+Join | Login
+Author Details
+naby Google
+nd a Lawyer - Fre
+ree, Confidentia
+Lama - Descre Your
+News Reports about
+Billionaire Pedophile Jeffrey
+Epstein Highlight the
+Importance of Victims Rights
+45k a Lawyer Online Nov
+12 Lawyers Are Online
+Current Wait Time: 14
+Nieby Google
+BnafingWiro.com, 3/08/2011 - Contact
+& erman, P. Weising. Edwards, Fistlos
+(954) 524-2820
+Kim Sale, BARD Markefing/PR
+(561) 637-2575
+art Lauderdale, FL -- In the last we
+indreds of news artic es have report
+Aska Layer Onling.
+27 Lawyers Online
+Now Answer Your
+Ause On In Minutes.
+Sexual Abuse
+Allegations
+We wrote the book on!
+defending false
+molestation
+allegations
+www.rolvcAbuse.com
+Local 1-Dax
+Coupons
+Up to 90% Off the
+Best Stuff To Dol
+Restaurants, Spas,
+Events and More
+www.LivwigSocial.com
+Ihe Diana Screen
+Employment screening
+tool. Help prevent
+hild molestatio
+lnnascrenn.ro
+
+3
+http://www.briefingwire.com/viewBriefing.aspx7id=24907
+
+
+Case 9:08-CV-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 8 of 22
+News Reports about Billionaire Pedophile Jeffrey Epstein Highlight the Importance of Vi.. Page 2 of 3
+at Epstein's Palm Beach Mansion, private
+Carlbbean Island and his jet. But
+Epstein's heinous sexual abuse of these
+victims is no fiction.
+Edwards successfully represented these
+women, oblaining justice for each of
+them, by proving that Epstein and his
+Internallonal sex trafficking criminal
+enterprise exploited them and hundreds
+of other underage giris.
+Highligene importance orle vigilms
+rights work that Attorney Edwards does
+on behalf of victims of sexual molestation
+and other sexual abuse. Edwards
+conducts extensive Investigetions and
+pursues civil lawsults against sexual
+predators to protect the rights of his
+victim clients and to hold sexual
+predators, like Epstein, accountable.
+Many sexual predators, like Epstein, are
+wealthy and powerful and able to focus
+their victims. Speaking of his work on the
+Epstein cases, Edwards says "we took on
+powerful people and sought to level the
+playing field to prolect victims."
+Representing these women has made
+Edwards aware that child sexual abuse is
+higher because it is believed that sexua
+abuse, especially amongst chlidren, l:
+Edwards hopes that the media altention
+Farmer, Jatfe, Weissing, Edwards, Fistos
+& Lehrman, P.L, a Fort Lauderdale
+Litigation flrm, focuses on Consumer
+Class Actions, Sexual Abuse Cases as
+qui tam). The firm is headquartered al
+125 N. Andraws Avenue, Suite 2, For
+http://www.briefingwire.com/viewBrieting.aspx7id=24907
+5/2/2011
+
+
+. Case 9:08-CV-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 9 of 22
+News Reports about Billionaire Pedophile Jeffrey Epstein Highlight the Importance of Vi... Page 3 0f3
+suderdale, Florida 33301 and may b
+eached at (800) 400-1098 or (954) 52
+EAGs| Sentect Us l Terma & Conditiona /
+Privacy Policy
+© 2000 BrieTingMa LLO
+http://www.briefingwire.com/viewBriefing.aspx7id=24907
+5/2/2011
+
+
+Case 9:08-cV-80736-KAM Document 247-2
+Entered on FLSD Docket 05/02/2014 Page 10 of
+Palm Beach Daily News: Archives
+PalmBeachDalyNews.com
+4/7/11 1 35 PM
+Storte
+Subiet
+PATIN
+Search lor Palm
+Beach Dolly News
+Follow @ShinySheot
+on Twittert
+OPEN FIrE
+SHErY SElter-
+Electronic Edition Now Available!
+Click Here To Subscribe
+NEWS
+Religon | Archives
+@ E-mail this pago
+Classifleds
+Advertise
+Real Estate
+Automotive
+E Prin tris page Ar Most popular
+New Search
+Relurn to results
+Prinler Friendly
+About your archives purchase:
+Your purchase of 20 arlicies expires on 04/07/2011 4:22 PM.
+You have viewed 3 articles and have 17 articles rumalning.
+Palm Beach Dally News (FL)
+JUDGE RECEIVES EPSTEIN TAPE
+RULING PENDING
+MICHELE DARGAN, Dally News Staff Writer
+Published: May 5, 2010
+NEW YORK - A Manhattan federal juda:
+tuesday look into custody a tape-recorded conversation
+between veleran newspaner munarter
+Rush and convicled sex offender Jaffrey Epstein.
+But U S. District Judge
+achenha reserved ruling on whelher the recording will be released to
+allamays representing young wamen who were sexuaily ebused by Epstaln as minors. McKenna didnt
+llsten to the recording during the hearng. Fort Lauderdale ettomey Brad Edwards and Utah atlomey and
+law professor Paul Cassell are fighting to oblain the 22-minute tape on behalf of Epstein victim Jane Doe.
+She has filed one of a dozen pending civil cases In federal court in West Palm Beech aguinst Epstein.
+A status check is set for Thursday in those cases before U.S. District Judge Kenneth Marra.
+Doe could have sellied the lawsult for $50,000 but Is asking for $50 million In damages, Cassell said
+Tuesday, "Jane Doe wus repeledly sexually asseutted over.a langthy perlod of time by this wealthy and
+powarful man," Cassell sald.
+Epstein, 57, is curently under house arrest in his Palm Beach home after serving 13 months of an 18-
+month state sentence for soliciting a minor for prostitulian and solleiting prostitulion. Nearly twa dozen
+young women have filed lawsuils against the billionalre money manager -- some already settled - ait
+alleging Epstein sexually abused tham as minors at his El Brillo Way home.
+Cites reporter's protected privilege
+Rush, of the New York Dally News, was present in the courtroom, bul did nol have to testity Tuesday.
+Nellher did Fort Lauderdale privale investigator Michael Fisten, afso in lhe courtroom. Working on behail
+of Epstaln victims, Fisien discovered the existence of the lape and had a conversation with Rush about Its
+contents.
+Representing Rush and the newspaper, Washingion aflorney Laura Handman and New York Daly News
+atomey Anne Carroll argued the tape should not be released under any circumstances, ciling reportar's
+prolected privege. Rush told Epstein the conversation was "off the record" end has never published any
+portion of that conversation. But aven if portions had been prinled, the unpublished portions would still be
+prolected, Handman said.
+Handman ciled cases where interlows wero conducted In the presence of other people and priviinge was
+not walved.
+In addition, Handman argued that Rush should not have to lestify In court.
+Te abllty for reporter's privilege to be protected is crucial in culling sources and gethering information fo
+ows slorlas, Handman sald. Reporing Is all ebout give and take between the reporter and the source
+thal's what roporters have to do, Handman said.
+"Thia ls so crivcal to news gethering," Handman sakd, "Mr. Rush could Ind himself tastlying in [many]
+cases lust because he hed the temerity to do some reporting on a very important story!
+There ls nothing helpful to Doe's case on the lape and "Jane Doe is not refered to once in that lape,"
+Handman sald.
+Cassell argued that the tape is "critical in showing Epslain's lack of remorse."
+esseli described Epstein as a pilless sexual abuser io Jane Doe and at least 30 other minor giris. Ever
+rough Jane Doe ls not referred to by namo on tha lapo, Epstein refers to his victims as "the glis" anc
+makes disparaging remarks about them on the lape, Cassell sald.
+Tape played for others
+issell sald prilege does not apply because it was walved when Rush pluyed the tape for three peop
+d verbally divulged lts contents to two others, including Fisten and Edwards, who also represents tw
+ather victima. Bul even if there is "quallfied privege," Cassell days, Il is outwoghed by Doe's Inabillty to
+obtain the Informalion anywhere alse and the Jury's need to hear Epstein's own words about his lack of
+remorse.
+EISIDER
+DIOG
+Shannon Donnelly
+Sirce Epslein has exercised his Fith Amendment right during questioning by viciims' aftorneys, tha Jury
+http://nl.newsbank.com/nl-search/we/Archives?p_action-doc&p_doct._ername-dkiesqds_accountid-AC01110406202210122618s_upgradeable=no
+
+
+
+Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 11 of
+Palm Beach Dally News: Archives
+wilt have no other way to hear Epslain's words in his own voice, Cassell sulc
+Deadine for discovery in the Doe case Is May 31, with the trial set for July 14
+-- mdargan@pbdallynews.com
+Copyright (c) 2010 Palm Beach Dally News
+refinance Hales at 2.659
+160,000 Mortgage for $659/ma. No SSN re
+LendGo.com/Mortpage
+Do NOT BAV Car Inauranse
+Ve found out how drivers can get
+www.News7@reaking/iews.com
+tan "Cheata" Credit Scors
+le Added 126 Points To His Credit Scor
+www.CreditRepairFramti:mc.com
+$79/Hr Job - 262 OpenInRE
+Make $79/hr Working From Home, As seen on
+www.workfromhomeguide net/jobs
+4/7/11 1.35 PM
+ACAP (EMANEE)
+COMEDIA!
+http://nl.newsbank.com/nl-search/we/Archives7p_action=doc&p_docl..ername=dklesqds_accountid-AC0111040620221012261&s_upgradeable=no
+
+
+
+Palm Beach Daily News Archives
+Entered on FLSD Docket 05/02/2014 Page 12 of
+4/7/11 1:32 PM
+Palm BeachDaily News. com
+0: TeNEE
+Soarch for Palm
+Beach Daly News
+Follow @)ShinySheot
+on Twitler!
+JUST A CLICK AWAY!
+Diving Direelury
+PalmBeachDailyNews.com
+NEWS
+Religion | Archives
+E2 E-nol this poge
+Classifiods
+Advertise
+Real Estate
+Automotive
+B Prins ihs pago
+Ir Most popular
+New Search
+Return to results
+Panter Friendly
+About your archives purchase:
+Your purchase of 20 articles expires on 04/07/2011 4:22 PM.
+You have viewed 2 aricies and have 18 articies remaining.
+updates in your e-mail
+Palm Beach Dally Nows (FL)
+Sign up to receive
+our e-mail
+newsletters here.
+LAWYER: EPSTEIN MADE ADMISSIONS ON TAPE
+MICHELE DARGAN, Dally News Stalf Writer
+Published: April 29, 2010
+A tape recorded interview batween a reporter and convicled sex offender Jeffrey Epstein contains
+"damning admissions by Epstein," which Includas Epstein saying he had come "close to crossing a lins"
+conceiing sax with underage giris.
+Those and other ravelalions about the 22-minute interview by New York Dally News reporter
+Rush
+with Epstein are contained in a 24-page court fing by altomeys Brad Edwards and Paul Cassel on behalt
+of Jane Doe. Edwards representa Doe and two other Epstein vietims. Edwards and Cassell are fighting to
+oblain the tape to further their case of sexual abuse by Epstein when Doe was a minor.
+Epstein, 57, was released from jall in July after serving 13 monthe of an 18-month state santence for
+sollciting a minor for prostitution and solicting prostitution. Nearly two dozen young women have fled
+lawsults agalnst Epstein - some already settled -- all alleging Epstein sexually abused them as minors at
+his El Brillo Way home, where he Is now serving house arrest.
+The New York Dally News Is seeking to keep the tape confidentiel, cling reporter's protected privilege.
+In response, Cassell seys the newspeper walved its protected privilege when Rush played the recording
+for three people and described its contents to two others, Including Edwards.
+In addition, Cassell writes that privege cant be app led in this situallon beause Is doesn't involve an
+Issue related to a confidentiel source. The person on the tape is Epstein.
+Even If there Is "qualified privilege," Cassell maintains it is outweighed by Doe's inablity to obtain the
+Information anywhere else and her "compeling need lo oblain Jeffrey Epstein's own words about his
+sexual abuse and lack of remorse."
+When reached by phone Wednesday, Anne Caroll, aftorney for the New York Dally News, sald she will
+anawer Cassell In a court filing. Both the New York Daily News and Doe have asked a federal court judge
+in Manhattan to Islan to the lape in chambers to help determine whether privege applies.
+Epstein and others who helped him procure minor glis for massages and sex acts have taken the Filth
+Amendmant In ther depositions, stymieing Dos and the other victims suing Epstein, the documents say.
+Michael Flaten, an Invesligator working for Doe, discovered the existence of the tape in fall 2009. An
+author who had listened to the tape told Fisten that Rush had a lape recording of Epstein "discussing the
+sexual abuse of minor giris."
+According to a swom affidavit by Fisten, he called Rush, who confirmed he intervlewed Epslein and made
+a tepe. According to Fisten, Rush told him that he complled negative Informalion from Epstaln about his
+exploits with underage girls and how he eluded the justice system. But Fisten said that Rush sold him that
+his publisher, who knows Epslein, killed it after recelving a call from Epstein.
+Fat Epel in uel he men, e lal i fior i or o reie ana i re erie ele omine or ra de
+In New York, he would have only received a 5200 fine.
+That L.M., one of Edwards' clients who sued Epstein for sexual abuse as a minor, come to him as a
+prostitute and a drug user (meaning she came to him for sex, rather than him pursuing her)
+That all the grie suing him are only trying to get a meal ticket.
+hat the only shing he m ght have done wrang was lo maybo cross tha Eno a little foo closel)
+, aswom deposilion, Edwards stales that Rush disciosed much of the information contained on the tap
+to him in a conversation.
+Edwards sald in his statement that the Rush Intervlew is "unique and not otharwise obtainable from other
+witnesses because Il can be used lo prove perjury -- a federal crime.
+Edwards said Epstein lestiled in a deposition that he did not recognize the name
+SUBSCRIBE
+Palm Beach Daily News
+NEWSLETTERS
+been tape recorded."
+-- mdargan@pbdallynews.com
+htp://nl.newsbank.com/nl-search/we/Archives7p_action=doc&p_docl. ername-dkiesqds_accountid-AC01110406202210122618s_upgradeable=no
+Page 1 of2
+
+
+Entered on FLSD Docket 05/02/2014
+22
+• Palm Beach Dally News Archives
+Hlas como close to crossing a line:
+Copyright (c) 2010 Pai Beach Delly News
+Refinance_ Rates nt.2.659
+160,000 Mortage for $659/mo. No 55N re
+LendGo.com/Martgage
+EAKER: S25 Cor Insurnn
+our Auto Insurer hates tr
+News7ÜreakingNews.com
+Ian "Choats" Creet Scec
+le Added 126 Points To His Credit Scor
+www.CreditRepalrFromiiome com
+79/Hr Job = 262 Opening
+ake $79/hr Working From Home. As seen o
+www.wo.fromhomeguide.net/jobs
+Page 13 of
+4/7/11 1 32 PM
+ACAPIEMARD
+COMEDIA»
+http://nl.newsbank.com/nl-search/we/Archives7p_action-doc&p_docl. ername-dklesq&s_accountid-ACO1110406202210122618s_upgradeable-no
+
+
+
+•Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 14 of
+22
+LexisNexis®
+6OflI DOCUMENTS
+Copyright 2009 ProQuest Information and Learning
+All Rights Reserved
+ProQuest SuperText
+Copyright 2009 Palm Beach Pos
+Palm Beach Daily News
+September 20, 2009 Sunday
+Dnl Edition
+SECTION: A SECTION; Pg. A.l
+LENGTH: 1126 words
+HEADLINE: ATTORNEY FOR EPSTEIN VICTIMS: I HAVE NEVER SEEN A STRANGER CASE'
+BYLINE: MICHELE DARGAN, MICHELE DARGAN, Daily News Staff Writer
+BODY:
+Sex offender Jeffrey Epstein could have been charged with multiple counts of five federal offenses involving sex
+acts with minors and faced a life sentence, but, instead, the government agreed not to prosecute him or his procurers if
+he spent 18 months in the county jail on two state charges.
+Those were the details unsealed Friday in a minconane federal non- prosecution agreement that lets Epstein and
+co-conspirators
+and
+off the hook for any of those past
+crimes.
+"He could have gone to prison for life and somehow he's getting immunity in exchange for nothing?" said Fort
+Lauderdale attorney Brad Edwards, who represents three Epstein victims. "I have never seen a stranger case. To me, it's
+more spectacular what's not in it. It's the U.S. Attorney's Office saying we'll do everything in our power to see he doesn't
+get punished."
+Edwards has been fighting for a year in federal and state court to unseal the agreement.
+"The non-prosecution agreement raises more questions than it answers," said Miami attorney Adam Horowitz, who
+represents seven victims. "Why did all the co-conspirators receive immunity? Why were the victims not consulted regarding the sentence? Why did he receive such a minimal sentence?
+The federal deal has remained sealed in Epstein's state court file since he pleaded guilty in June 2008 to state
+charges of procuring a minor for prostitution and soliciting prostitution.
+U.S. Attorey's Office does not comment
+The federal charges he could have faced were: conspiracy to persuade minor females to engage in prostitution,
+conspir, ra vo rag el to enge in in i i sexu co did et it mor tereas and ensuadi person ended years in ar
+in sex for money while knowing they are underage.
+The charges carry various statutory penalities ranging from 10 years to life, with a minimum mandatory of at least
+Alicia Valle, spokeswoman for the U.S. Attomey's Office in Miami, declined comment.
+Expert: Feds take few sex-assault cases
+
+
+Entered on FLSD Docket 05/02/2014 Page 15 of
+Page 2
+ATTORNEY FOR EPSTEIN VICTIMS: 'I HAVE NEVER SEEN A STRANGER CASE Palm Beach Daily News
+September 20, 2009 Sunday
+North Palm Beach criminal defense attorney Barry Maxwell said he is not surprised that federal charges weren't
+filed.
+ing wily spit race has be dise the rein es, ade i it rene in no sail case e realise
+enough for them."
+pstein, 56, served 13 months of his 18-month sentence at the Palm Beach County Stockade and received liber
+ork-release privileges while in jail. He was able to go to his West Palm Beach office six days a week for up to l
+hours a day.
+He is now serving one year of probation at his Palm Beach mansion and is registered as a lifelong sex offender.
+Epstein 'fully abided' by deal, says defense
+the identities of collateral third parties.
+"Mr. Epstein has fully abided by all of its terms and conditions. He is looking forward to putting this difficult period of his life behind him. He is continuing his longstanding history of science philanthropy both here in South Florida
+and nationwide."
+Goldberger had blocked the unseating by filing court papers asking that the documents stay sealed "to prevent a serious imminent threat to the fair, impartial and orderly administration of justice; to protect a compelling government
+interest; to avoid substantial injury to innocent third parties; and to avoid substantial injury to a party by disclosure of
+matters protected by a common law and privacy right, not generally inherent in these specific type of proceedings,
+sought to be closed."
+Circuit Judge Jeffrey Colbath ordered the agreement to be unsealed in June, but Epstein's attorneys appealed the
+ruling to the Fourth District Court of Appeals, which affirmed Colbath's ruling. Colbeth had ruled that the federal
+agreement - sealed in state court - was improperly sealed.
+I felt it was my fault'
+he would pay her.
+One victim, who is known as Jane Doe #5 in a federal court lawsuit against Epstein, said she didn't find out about
+the deal until after it was finalized. She was 15 at the time one of her schoolmates told her she could make $200 by giving a massage to a man in Palm Beach.
+She says she was "nervous and scared and wanted to leave" once she got to Epstein's spa room.
+"I thought, 1 can't call my dad or my mom because I'm stuck in this situation and didn't know what to do," she said
+"I really didn't know what this man was capable of. For a long time, I felt like it was my fault and that's exactly what he
+wanted me to feel."
+Epstein has curfew
+While he is serving the 12 months of house arrest at his Palm Beach home, Epstein must observe a 10 p.m. to 6
+a.m. curfew, have no unsupervised contact with anyone younger than 18 and not view, own or possess pornographic or
+sexual materials.
+which charged Epstein on the lesser charge of soliciting prostitution.
+Then-Palm Beach Police Chief Michael Reiter wrote Krischer a letter asking him to recuse himself from the cas
+hen that didn't happen, Reiter requested an FBI investigation to determine if any federal laws were broker
+
+
+Entered on FLSD Docket 05/02/2014 Page 16 of
+ATTORNEY FOR EPSTEIN VICTIMS: 1 HAVE NEVER SEEN A STRANGER CASE Palm Beach Daily Nas 3
+September 20, 2009 Sunday
+'Out of the ordinary'
+West Palm Beach criminal defense attorney Gregg Lerman said several aspects of the Epstein case are unusual.
+I don't understand why it would be a federal case in this circumstance, and why was there anything in writing at a
+nd why did they seal the agreement?" Lerman said. "Why did it go to the grand jury instead of through the state filin
+Prison time. That it out art ordinary, Nody get yayer as plate i coup in ate than.
+-- mdargan
+@pbdailynews.com
+GRAPHIC: Caption: Epstein Deal does not allow prosecution of co- conspirators.
+LOAD-DATE: September 1, 2010
+
+
+Entered on FLSD Docket 05/02/2014 Page 17 of
+22
+Local News West Palm Beach, Palm Beach County, Martin & 5t. Lucie Countles | The Palm Beach Post
+4/6/11 1:38 PM
+'The Palm Beach Post
+NEWS
+NEXT GENERATION PENINZOIL*
+CLEANS OUT UP TO 40% OF
+SLUDGE IN THE 1ST OIL CHANGE*
+Ted on are durier dean ip me sang lad to 1o
+Mot Jast off, Permoll"
+Gutscribe How
+BREAKING NEWS: Gov. Scott Oks last-minute ballet for courts, averting two-wcek furloughs Clot do road stor
+Local NeWS • Greater Palm Beaches and Treasure Coast
+Palm Beach sex offender's secret plea deal:
+Possible co-conspirators not charged, presses
+victims to settle civil suits
+By SUSAN SPENCER WENDEL
+Palm Boach Post Staff Writer
+Friday, September 18, 2009
+WEST PALM BEACH - Billonaire financier sex offender Jeffray Epstain's secret non-prosecution agreement he
+struck with federal prosecutors was unsoaled Friday, offering the frat publie look at the deal Epstein's high-powered
+legal counsel brokered on his behalf
+According the agreement, the Federal Bureau of Investigation and the U 5 Altomey's Office investigaled Epstein
+for various federal crimes, including prostilution, some punishable by a minimum of 10 years up to life in prison
+But federal prosecutors backed down and agreed in rucall grand jury subpooanas, if Epslein pleaded gullty to
+prostitution-related faionies in state court, which he ultimately did. He received an 18-month jall sentance, of which
+ha served 13
+A former federal prosecutor of 15 years, Mark Johnson of Stuart, sald the disparty in the polential sontances was
+unusual.
+The Unled Slaten Allemard OM
+amed notto change any of Epslain's possible co-conspirators
+The agreement was negotlated in part by New York heavyweight criminal datense aromay Gerald Lefcourt
+On Its frat draft in September 2007, I raquired that Epstein pay an altomey - tapped by the U.S. Altamey's Office
+and approved by Epsiein - to reprasent some of the victims in civil suits they had fied against Epstein. That
+attorney is prominent Miami lawyer Bob Jonatsberg
+Former proseculor Johnson said he has never seen a provision like that before.
+But an addendum to the agreement signed the following month struck Epstein's duty lo pay Josalberg it he and the
+victims did not accept a sottement and insteed pursued litigation.
+The agreoment, signed by Assistant U.5 Acomay Maria Villafan, does nct expressly stale whether any victims
+ware contacted or consulted before the deal was made.
+Allomey Brad Edwards of Fort Lauderdale, who reprosants three of the young women, bellaves that none of the
+between 30 and 40 woman identified as victims in tha faderal investigation waro lold of the deal. Edwards said his
+clonts were sull receiving letters in the mall months afterwards saying the U.S. Attorney's Office assuring them
+Epstain would be proseculed.
+"Never consulting the victime is probably the most outrageous aspect of iL." Edwards sald. *it taught them that
+someone with money can buy his way out of anything. It's outrageous and embarrassing for United Statos
+Allomey's Office and the State Attoreys Office.
+Epstein now feces many chil lawsuits tied by the women, who are represented by a variety altomays In many, the
+tacta alleged are the same that Epstein had a prediction for toenage girla, kentified poor, vulnerable ones and
+lured them to his home via other young women. The taens describe escending a stalrcase Ined with nude
+pholographs of young girls and to the spa room where Epstein would appear in a small towel
+Former Circuit Judge Bill Berger, who represents one of the victims, and The Palm Beach Post sought the
+unsealing of the agreement. Berger refers to it as a "sweetheart deal"
+Why was it so Important for the govomment to make this deal?* B
+anast oxplanation by any public oficial as to why i was made.. and wry the victime wore sold down the river
+Fanner federal prosecutor Ryon McCaba deserbed the agroement as "very unorthodox." Such agreements, he said,
+are usually reserved for corporations, not individuals
+© Site O Web
+Web Search by YAHOOI
+Obama Launches Mortgage Relief Plan
+you owe less than 5729,000 on your
+morgage, you probably quality for the
+President's Making Home Affordable
+Program With rales lower than they've ever
+been there has never been a better time to
+refinance if you are a homeowner and you
+havent looked into refinancing recently you
+may be surprised at how much you can save
+Select Your Age: 23
+Calculate Now House Payment
+COLUMNISTS AND BLOGGERS
+FRANK CERABINO
+Reed Frank's Ialest columns
+and follow him on Twitter.
+Read moro
+HOT CELEBRITY NEWS
+Get the Iatest on South Florida
+celebrites, billonaires,
+politicos, more.
+PageZLivo
+BENNETT
+Raan Post politics columnial
+Bunnett's lalest
+arices.
+Read moro
+MOST POPULAR
+DEADLINES COMMENTS
+Fatal shooting in Delay Beach draws crowd of 100
+onlookers
+Lake Worth mayor says The Cottage complainis use
+"Day carf against city mannger
+Was! Palm Boach mayer: Firaghter leotte likety
+Narcy Navack charged in 2000 Fort Lauderdale killing
+of her mothar-in-law
+Baynten Police warm of now taist on ATM Identty fraud
+FOLLOW THE POST ON TWITTER
+SIGN UP FOR MOBILE TEXT ALERTS
+The Palm Beach Post on Facept
+Like
+16,985 people like The Patm Beach Post
+http //www.palmbeachpost.com/pbcwest/content/local_news/epaper/2009/09/18/0918epsteln.html
+
+
+
+Entered on FLSD Docket 05/02/2014 Page 18 of
+22
+Local News West Pair Beach, Palm Beach County, Martin & St. Lucie Countles | The Palm Beach Post
+4/6/11 1:38 PM
+*Ira very, very rare. Ive never seen or hoard of the procedure that was set up here. " said McCabe, who has no
+Involvement in any Epslein Ngation and is now a securites Ilgation allomey.
+"He's essentially avoiding faderal prosecution because he can afford to pay that many lawyers to help those victima
+revlow their cases... If a person has no money he couldn't be able to strike a deal ilke this and avoid federal
+proseculian."
+The back-room deal with federal prosecutors all the more interesting in light of the lagal heavywelghts who have
+worked for Epstain, Including Harvard professor Alan Dershowitz and Kanneth Starr of Clinton Impeachment tame
+Lefcourt in a past president of the National Association of Criminal Delense Lawyors
+Epstein's local defense nhomey. Jack Goldberger, Issued a statement Friday saying ha had fought the release of
+the sealed agreement to protect the third parties named there. "Mr. Epalein has fully abided by all of its terms and
+condina. He is looking forward to pusing this clicult pariad in hie itte befind him He is contring tie long
+standing history of sclance philanthropy.
+Epstein ended up avolding federal charges, and pleaded guilty in mate court to felony Bollcation of prostition and
+procuring a person under the ego of 18 for prostitusion. In July 2008, he was sentenced to 18 months in jail, and
+later allowed out up to six days a wusk on work relause.
+Epstein loft the jall in into July 2009 after serving not quite 13 months of the sentence, having eamed gain time for
+good behavior
+Palm Bench Police began investigating the International monayman of mystery," as the Now York magazine
+dubbed him, attor they recelved a complaint from a relative of a 14-yoar-old girt who hed given Epstein a naked
+massage at his homa on the Intracoastal Waterway.
+Police saught and found in poor neighborhoods a variaty of tall, thin, model like young women, who tald stories of
+begin recruiting, then going to Epstein's home and massaging and stimulating him. They walked away with between
+$200 and 51,000
+The Investigation triggered tensions between police and prosecutors, with then-Chief Michael Railer saying in a
+May 2006 fatter to thon-State Altomey Barry Krischer that the chief prosecutor should disquality himself
+'I continue to find your office's trealment of these cases highly unusual," Reiter wrote He then asked for and got
+he federal investigation that ended in the soled doa
+ne Jeffrey Epstein metter was an experience of what a many-milion-dollar defenao can accomplish," Reiter lo
+Palm Beach Dally Nows upon his rotireme
+Hraly
+Vero
+Debra
+Robin
+Audity
+Jadle
+Recent Activity
+You need to be logged into Facebunt, to
+see your fr ends' activity
+Cerabino: Florida House GOP'y 'uterus"
+ban: A free-speech battle is horn
+1,518 people shared this.
+Foreclosure crisis. Fed-up Judges crack
+down disorder in the courts
+207 people shared this.
+Ki Facebook soulst plugin
+POSTPIX • Lalost nows plotos
+IMAGES OF WAR In Iraq
+and Afghanisten
+Massive earthquako and
+Isunami devastale Japan
+lan Muoic Swom in as
+Mayur
+Severe weather in Central
+South Flonde
+Do Your Foot Hun?
+SELBY SHOES
+561-960-9369
+Wol/Put WeedInto Your Windans
+IN THE SHADE INC
+772•223-1212
+Erep Heann Last!
+BELTONE®
+501-848-3049
+501-498-7018
+561-968•935
+Historic Archive
+(1897- 1988)
+http//www.palmbeachpost.com/pbcwest/content/local_news/epaper/2009/09/18/0918epsteln.html
+
+
+
+Case 9:08-cV-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 19 of
+22
+LexisNexis
+7 of 11 DOCUMENTS
+Copyright 2009 ProQuest Information and Leaming
+All Rights Reserved
+ProQuest SuperText
+opyright 2009 Palm Beach Po
+alm Beach Daily Nev
+June 25, 2009 Thursday
+Final Edition
+SECTION: A SECTION; Pg. A.l
+LENGTH: 557 words
+HEADLINE: JUDGE TO RULE ON SEALED PLEA-DEAL PAPERS TODAY
+BYLINE: MICHELE DARGAN, MICHELE DARGAN, Daily News Staff Writer
+BODY:
+A circuit judge will decide today whether the public will be privy to the federal government's non-prosecution deal
+with Jeffrey Epstein, which was sealed when the convicted sex offender pleaded guilty in June 2008 to two felony
+Epstein, of Palm Beach, will be released from the Palm Beach County Stockade July 22, after serving less than 13
+months of his 18- month sentence for procuring a minor for prostitution and solicitation of prostitution.
+Teri Barbera, spokeswoman for the Palm Beach County Sheriff's Office, confirmed his release date Tuesday.
+Epstein's projected release date had been Sepi. 24, but gain time - which includes his participation in a
+work-release program - moves the date up to July 22, Barbera said.
+Epstein, 56, has been in the work-release program since Oct. 10, in which he is allowed out of the stockade six days
+a week, from 10 a.m. to 10 p.m., to go to his West Palm Beach office, the Florida Science Foundation, monitored by an
+ankle bracelet and accompanied by a deputy.
+As part of Epstein's state plea agreement, the U.S. Attorney's Office agreed not to prosecute Epstein on federal
+charges as long as he fulfills all requirements of his sentence and probation. The federal non-prosecution agreement has
+Epstein's attorney Jack Goldberger filed court papers asking that the documents stay sealed for the following reasons: "to prevent a serious imminent threat to the fair, impartial and orderly administration of justice; to protect a compelling government interest; to avoid substantial injury to innocent third parties and to avoid substantial injury to a party
+by disclosure of matters protected by a common law and privacy right, not generally inherent in these specific type of
+proceedings, sought to be closed."
+Fort Lauderdale-based attomney Brad Edwards represents three Epstein victims and has asked Circuit Judge Jeffrey
+Colbath to unseal the federal agreement to the public. An attorey for The Palm Beach Post also has asked that the rec-
+Edwards and his clients have seen the agreement afler a federal judge ruled that they are allowed to see it. But that
+ruling bars Edwards and anyone else who sees the document from disclosing the terms lo anyone else.
+Edwards said he wants to use that document "in the deposition of various material witnesses" relative to his cases.
+
+
+Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 20 of
+JUDGE TO RULE ON SEALED PLEA-DEAL PAPERS TODAY Palm Beach Dally News June 25,2009 Thursday?
+adaronline.com has reported that Epstein has "secretly been helping the feds unravel a Ponzi scheme" related
+e June 2008 indictment of two former managers of Bear Steams Mortgage Investment Fun
+Epstein's rep, Howard Rubenstein, confirmed last year that Epstein is "Major Investor No. I" in the indictment,
+which says he lost about $57 million.
+Goldberger could not be reached for comment.
+The Manhattan money manager has been incarcerated since June 30, when he pleaded guilty to the two felony
+ounts. As part of the plea agreement, Epstein must serve one year of house arrest afler his release and register as a life.
+long sex offender.
+. in addition to the criminal case, there are more than a dozen civil lawsuits - both state and federal - pending
+against Epstein. All contain similar allegations: Epstein, through his employees and assistants, brought minor girls to his
+Palm Beach home on El Brillo Way for erotic massages and sometimes sex.
+- mdargan@pbdailynews.com
+GRAPHIC: Caption: Epstein To be released from jail July 22.
+LOAD-DATE: September 1, 2010
+
+
+Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 21 of
+22
+LexisNexis
+9 of 13 DOCUMENTS
+Copyright 2009 Sun-Sentinel Company
+All Rights Reserved
+Sun-Sentinel (Fort Lauderdale, Florida)
+June 15, 2009 Monday
+Palm Beach Edition
+SECTION: LOCAL; Pg. 3B
+LENGTH: 348 words
+HEADLINE: HEARING SET TO CONSIDER SECRECY OF PLEA BARGAIN
+BYLINE: Susan Spencer-Wendell The Palm Beach Post
+BODY:
+A Palm Beach Circuit Court judge will not immediately unseal a deal that wealthy Palm Beach money manager
+Jeffrey Epstein made with federal prosecutors to avoid charges.
+Circuit Judge Jeff Colbath acknowledged, though, at a hearing last week that Epstein's deal was not sealed in accordance with state and local court rules.
+"I don't see where any of the procedures were ever followed to begin with," Colbath said.
+Colbath also set a full hearing on the matter for June 25.
+Attorneys for young women now suing Epslein, logether with The Palm Beach Post, are asking Colbath to unscal
+the deal that Epstein made with federal prosecutors.
+'It's a secret agreement, a secret sweetheart agreement," said former Circuit Judge Bill Berger, who represent
+ome of the women. "Everybody was in on this deal except the victims and the public. The public should be outraged
+has gone as far as it has."
+Brad Edwards, a second attorney representing the women, has seen the sealed deal after a federal judge allowed
+him and his clients to view it, but would not discuss its contents.
+Edwards would say only that the women were "outraged" that it had been negotiated behind their backs.
+A reporter asked Edwards whether he thought Epstein received special treatment by federal prosecutors.
+"Are you kidding? It's transparent. Certainly, no one else gets treated like that," Edwards said.
+Epstein, 56, a reported money manager of billionaires, is serving an 18-month sentence in the Palm Beach County
+Stockade after pleading guilty almost a year ago in state court to felony solicitation of prostitution and procuring teenagers for prostitution. Epstein is allowed out, though, each day from 7 a.m. to 11 p.m., a Sheriff's Office spokesman
+Displeased with the way the State Attorney's Office handled the case, Palm Beach police forwarded information to
+INFORMATIONAL BOX:
+Young women have sued
+
+
+Case 9:08-cv-80736-KAM Document 247-2 Entered on FLSD Docket 05/02/2014 Page 22 of
+HEARING SET TO CONSIDER SECRECY OF PLEA BARGAIN Sun-Sentinel (Fort Lauderdale, Florida.) June 15.2
+Money manager Jeffrey Epstein made a deal and is serving an 18-month sentence in jail. Attomeys for youn
+vomen suing Epstein are asking a judge to unseal the deal that Epstein made with federal prosecutors
+NOTES: < Informational box at end of text. (TOPIC) Prostitution solicitation case
+LOAD-DATE: June 15, 2009
+
+
+Case 9:08-cv-80736-KAM Document 247-3
+Entered on FLSD Docket 05/02/2014 Page 1 of 13
+COMPOSITE EXHIBIT 3
+
+
+he Washington post sue
+Eleventh Circuit rules that discovery
+can move forward on my Crime
+Victims' Rights Act case
+By Paul Cassell Updated: April 21 at 9:41 am
+attoreys could assert some sort of "privilege" to prevent crime victims from
+reviewing the correspondence that lead to a plea bargain. More broadly, the ruling
+means that the victims will have a chance to return to the district court and seek to
+invalidate a plea agreement that (we alleged) was consummated in violation of their
+rights. I hope that the case will ultimately set an important precedent that federal
+prosecutors can't keep victims in the dark about the plea deals that they reach.
+Here are the important facts, taken from the 11th Circuit's opinion: The case arose in
+2006, the FBI began investigating allegations that wealthy investor Jeffrey Epstein
+had sexually abused dozens and dozens of minor girls. The U.S. Attorney's Office for
+the Southern District of Florida accepted Epstein's case for prosecution, and the FBI
+issued victim notification letters to my two clients, minors Jane Doe No. I and Jane
+Doe No. 2, in June and August 2007. Extensive plea negotiations ensued between the
+prosecutors and Epstein. On Sept. 24, 2007, the prosecutors entered into a nonprosecution agreement with Epstein in which they agreed not to file any federal
+charges against Epstein in exchange for his guilty plea to minor Florida offenses (e.g.,
+solicitation of prostitution). Not only did the prosecutors neglect to confer with the
+victims before they entered into the agreement with Epstein, they also concealed its
+existence for at least nine months. For example, the prosecutors sent post-agreement
+letters to the victims reporting that the "case is currently under investigation" and
+explaining that "[t]his can be a lengthy process and we request your continued
+patience while we conduct a thorough investigation."
+On June 27, 2008, the prosecutors informed my co-counsel, Brad Edwards, that
+Epstein planned to plead guilty to the Florida charges three days later. But the
+prosecutors tailed to disclose that Epstein's pleas to those state charges arose from hi:
+federal non-prosecution agreement and that the pleas would bar a federal prosecution.
+As a result, the victims did not attend the state court proceedings.
+On July 7, 2008, Edwards and I filed a petition alleging that Jane Doe No. I was a
+victim of federal sex crimes committed by Epstein and that the United States had
+wrongtully excluded her from plea negotiations. We also alleged that the federal
+prosecutors had violated her rights under the Crime Victims' Rights Act (CVRA) -
+http://www.washingtonpost.com/news/volokh-conspiracy/wp/2014/04/21/eleventh-circuit-r... 5/2/2014
+
+
+specifically her rights to confer with the government, to be treated with fairness, lo
+receive timely notice of relevant court proceedings, and to receive information about
+restitution. The United States responded by claiming that it used its "best efforts" to
+comply with the rights afforded to victims under the CVRA, but that the act did not
+apply to pre-indictment negotiations with potential federal defendants.
+After Jane Doe No. 2 joined the initial petition, the district court (Marra, J.) found
+that both women qualified as "crime victims" under the CVRA. The district court
+later rejected the government's argument that the act only applies after the filing of a
+federal criminal indictment. (I've written a law review article about the issue of how
+early crime victims' rights attach in the criminal process, which can be downloaded
+here.)
+Among other relief, we sought rescission of the non-prosecution agreement as a
+remedy for the violation of the victims' rights. To make the case for such a remedy,
+we moved for discovery of the correspondence between the U.S. and Epstein's
+attorneys during the plea negotiations. Epstein's attorneys intervened, arguing that
+Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a
+privilege for plea negotiations, barring release of the correspondence. They also
+argued that the court should find that the materials were protected under the work
+product doctrine or, alternatively, should be protected under a new "common-law
+privilege for plea negotiations."
+The district court first ruled that rescission of the plea agreement was a possible
+remedy under the act. The court then ruled that we were entitled to review the
+correspondence, rejecting all of Epstein's arguments.
+On Friday, the 11th Circuit affirmed the district court's ruling that we could review
+the plea correspondence. At pp. 18-22 of its published opinion, the court concluded
+that there was no basis for restricting access to such correspondence when crime
+victims have a legitimate need to review it. The court rejected, for example, the work
+product argument because plea discussions are not confidential:
+Disclosure of work-product materials to an adversary waives the work-product
+privilege. See, e.g., In re Chrysler Motors Corp. Overnight Evaluation Program
+Lilig., 860 F.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir.
+1981). Even if it shared the common goal of reaching a quick settlement, the United
+States was undoubtedly adverse to Epstein during its investigation of him for federal
+offenses, and the intervenors' disclosure of their work product waived any claim of
+privilege. ..•
+The court also declined to recognize a new privilege for plea bargaining, finding th
+elationship between prosecutors and defense attorneys did not need specia
+protection:
+As a last-ditch effort, the intervenors contend that "[i]f more is needed in addition to
+the plain language of Rule 410 to preclude disclosure of the correspondence to
+plaintiffs, it can be found in the conjunction of Rule 410, the work-product privilege,
+and the Sixth Amendment right 1o the effective assistance of counsel in the plea
+bargaining process," but this novel argument fails too. As explained above, Rule 410
+http://www.washingtonpost.com/news/volokh-conspiracy/wp/2014/04/21/eleventh-circuit-r... 5/2/2014
+
+
+does not create a privilege and the intervenors waived any work-product privilege.
+he intervenors concede too that the right to counsel under the Sixth Amendment hac
+ot yet attached when the correspondence was exchanged. Lumleye. City of Dade
+City, Fla., 327 F.3d 1186, 1195 (11th Cir. 2003) ("[T]he Sixth Amendment right to
+counsel ordinarily does not arise until there is a formal commitment by the
+government to prosecute," such as a "formal charge, preliminary hearing, indictment,
+information, or arraignment."). The "conjunctive" power of three false claims of
+privilege does not rescue the correspondence from disclosure. ...
+The Supreme Court has identified several considerations relevant to whether a court
+should recognize an evidentiary privilege—the needs of the public, whether the
+rivilege is rooted in the imperative for confidence and trust, the evidentiary benefi
+of the denial of the privilege, and any consensus among the states. Jaffee. Redmond
+518 U.S. 1, 10-15 (1996)—but none of these considerations weighs in favor of
+recognizing a new privilege to prevent discovery of the plea negotiations. Although
+plea negotiations are vital to the functioning of the criminal justice system, a
+prosecutor and target of a criminal investigation do not enjoy a relationship of
+confidence and trust when they negotiate. Their adversarial relationship, unlike the
+confidential relationship of a doctor and patient or attorney and client, warrants no
+privilege beyond the terms of Rule 410. See Jaffee, 518 U.S. at 10. But the victims
+would enjoy an evidentiary benefit from the disclosure of plea negotiations to prove
+whether the United States violated their rights under the Act.
+Moving forward, this case raises the important issue of what kinds of remedies are
+available for violations of the Crime Victims' Rights Act. Our complaint alleges that,
+prodded by Epstein, the federal prosecutors deliberately concealed the sweetheart
+plea deal they had reached with him to avoid public criticism of the deal. I am
+hopeful that in future district court proceedings, we will be able to prove that clear
+violation of the CVRA and then obtain the remedy of invalidating the illegallynegotiated plea deal.
+© The Washington Post Company
+http://www.washingtonpost.com/news/volokh-conspiracy/wp/2014/04/21/eleventh-circuit-r...
+
+
+Follow us on
+:
+Friday. May 2. 2014 | 3:56 p.m
+Subscribe | Today's paper | Customer care
+Sign In | Register
+Palm Beact Daily Hews
+the shiny sheet
+Search
+Posted: 12:00 a.m. Monday. April 21. 2014
+Appeals court rules against sex offender
+Attorneys for underage victims seek to overturn 'sweetheart plea.'
+Related
+By Michele Dargan
+Daily News Staff Writer
+Underage victims of billionaire sex offender Jeffrey Epstein are entitled to correspondence between federal prosecutors and
+Epstein's attorneys related to his sweetheart plea deal, a federal appeals court ruled Friday.
+This is one more slep in the fight by victims' attorneys Brad Edwards and Paul Cassell to overturn the secret deal. which
+saved Epstein from facing serious federal charges and serving significant prison time.
+If Epstein had been found guilty on federal charges, statutory penalties ranged from 10 years to life in prison.
+Inslead, the sealed pact was part and parcel of Epstein's acceptance of a state plea deal. Epstein pleaded guilty to
+soliciting a minor for prostitution and soliciting prostitution. He received an 18-month sentence. in a vacant wing of the Palm
+Beach County Stockade, and was let out on work release six days a week for up to 16 hours a day.
+Edwards and Cassell represent Jane Doe No. 1 and Jane Doe No. 2, who say the U.S. Attorney's Office violated the Crime
+Victims' Rights Act by signing the federal non-prosecution agreement in 2007 without notifying the victims. Their case is
+pending in U.S. District Court in West Palm Beach.
+The 24 page published opinion says U.S. District Judge Kenneth Marra did not err in his June 2013 ruling, when he ordered
+the correspondence turned over to the victims.
+"Sweetheart plea"
+"We're now going to get a complete picture of the negotiations that led to this sweetheart plea arrangement," said Cassell. a
+former federal judge. "We think it will show the part of the discussion to keep the victims in the dark about what was
+happening. If that's what the correspondence shows, we'll use that as part of our argument for throwing out the plea."
+Cassell said he anticipates that 500 pages of correspondence should be released early this week
+he opinion by the three-judge panel ruled against Epstein's arguments that the correspondence was protected by a
+torney's work-product privilege. The court says privilege was waived when attorneys voluntarily sent the correspondenc
+to federal prosecutors during negotiations.
+"Disclosure of work-product materials to an adversary waives the work-product privilege," the ruling says.
+http://www.palmbeachdailynews.com/news/news/local/appeals-court-rules-against-sex-offe.. 5/2/2014
+
+
+The ruling also dismissed Epstein's claims that a federal rule of evidence protects his plea correspondence. That rule
+applies only to defendants who withdraw a guilty plea. Because he pleaded guilty, that doesn't apply, the ruling says.
+"While respectful of the panel's decision, given issues of overriding importance to the criminal justice system regarding the
+need for continued confidentiality for communications between defense lawyers and prosecutors, we will be petitioning the
+court of appeals for further review," said Boston based atlorney Martin Weinberg, who represents Epstein.
+The U.S. Attorney's Office failed to notify victims prior to striking a non-prosecution agreement with Epstein on Sept. 24,
+2007, and didn't tell them of the agreement's existence for at least nine months, the ruling says.
+On June 27, 2008, the U.S. Attorney's Office told the victims that Epstein planned to plead guilty to state charges three
+days later. But federal prosecutors failed to disclose that his pleas to the state charges arose from his federal nonprosecution agreement and would bar federal charges.
+Jane Does No. 1 and No. 2, who were, respectively, 12 and 13 at the time they were victimized,received confidential
+monetary seltlements in civil cases.
+They are among more than two dozen underage girls who filed lawsuits or settled claims against Epstein. All alleged they
+were lured to his Palm Beach mansion to give him sexually charged massages and/or sex in exchange for money.
+"A well-connected billionaire got away with molesting many girls," Edwards said. "These girls should at least know how and
+why he was able to get away with these crimes. This ruling will allow us access to the documents that will provide insight
+into how that happened. I suspect that the answers revealed by these documents will ultimately allow us to invalidate that
+agreement and permit prosecution of Mr. Epstein."
+More News
+We Recommend
+• Appeals-court decision in Epstein case rights a
+terrible wrong (Palm Beach Daily News)
+• Memorial service set for former 'Daily News'
+reporter (Palm Beach Daily News)
+• Ernest S. Johnston Jr. (Palm Beach Daily News)
+• Choosing plants? There's always something new
+(Palm Beach Daily News)
+• Stale restripes Royal Palm inlersections (Palm
+Beach Daily News)
+• Eunice "Penny" Jacobs (Palm Beach Daily
+News)
+From Around the Web
+• Bad Neighborhoods: How to Read the Warning
+Signs Before You Move in (realtor.com)
+• The 5 Most Dangerous Cities in the U.S. (AARP)
+• Stunning Photos Of Leonardo DiCaprio's For
+Sale Home (Lonny Magazine)
+• Rosie O'Donnell Is Buying Olivia Newton-John's
+Florida Estate For $5.6 Million... See The
+Pictures (Lonny)
+• Andy Griffith's Widow to Raze His Home (AARP)
+• Supermodel Heidi Klum's Kid Is Growing Up
+Gorgeous (StyleBisiro)
+171
+Comments
+If you would like to post a comment please Sign in or Register
+Cancel Edit comment |
+2 Comments)
+Comments) 1-2 of 2
+Posted by THEPALMBEACHER1 at 3:02 p.m. Apr. 21. 2014
+Report Abuse
+Its inconceivable to see articles like this!! USUALLY, one gets charged with slatutory rape, child molestation, etc., and its
+Guaranteed that they will do prison time.. Now, If your a "BILLIONAIRE". you can BUY yourself freedom, and throw money
+to the victims and say adios!!!! Its OBVIOUS, payments, kickbacks. DONATIONS, financial promises are all part of this
+deal. Where is the JUSTICE SYSTEM? Where is the State Attorney. The JUDGES? People go to jail for petty thefts, illegal
+drugs, assault, battery, domestic violence, but this case is PROOF that the LEGAL system can be BOUGHT for the right
+price!!! Its OBVIOUS this individual has a severe mental problem, a sexual predator, who would ship young giris like human
+trafficking back and forth via his private jets... Its no different than "THE BACKPAGE" girls being exploited by their pimps
+http://www.palmbeachdailynews.com/news/news/local/appeals-court-rules-against-sex-offe.. 5/2/2014
+
+
+being housed in cheap motels along federal hwy for GUY LIKE THIS to get their sexual perversions satisfied!! Read the
+entire case and see that young girls flowed thru Palm Beach South Ocean Bivd and South County Rd ,to his El Brillo
+"MANSION OF PERVERSION" with this guy as its Master!! For people to think "Palm Beach" has the "Elite", the "Upper
+Crust of sociely, il also is home to some of the worst thieves, sexual predators, financial criminals the world has ever
+known!! Mr. Epstein has Billions of Dollars, and can afford the Best Criminal Attorneys, yet Can't or WON'T get Professional
+Mental Help with his sexual desires and fascination with young girls. And the Court syslems goes along with him!!!
+Unbelievable..
+• Posted by Adios at 3:12 p.m. Apr. 22, 2014
+• Report Abuse
+I agree with the post by the palm bleacher. This guy is a perv and needs to sit out of society. When listening to his
+depositions, he pretended to be insulted by the questions being asked of him and his lawyer shut it down quickly. What
+remains to be seen is if the soon to be released files will bear the fruit we all hope it does. My worry is that the tracks will be
+covered and he will not get his due.
+His opinion of himself allows him to think he did nothing wrong and these BABIES he molested were not of his place in
+society and were simply objects to be thrown away. What would he think if someone did that to his BABIES if he has any? !
+can bet that the full force of his money would work against whomever played with his kids.....bloody gross!
+2 Comments)
+Comments) 1-2 of 2
+p=recruemedialle&type=gif&segment= 848add=true
+, simg height="1" width="1" src="http://segments.adap.tv/data/?
+http://www.palmbeachdailynews.com/news/news/local/appeals-court-rules-against-sex-offe..
+
+
+calibratingest kennesbiatine Hables leniental en er ERebb03204.. Bass of 73
+sun-sentinel.com/news/palm-beach/fl-jeffrey-epstein-federal-court-of-appeals-
+20140421,0,6594687,story
+Sun Sentinel
+Victims win right to see negotiations that led to 'lenient' plea
+agreement for billionaire sex offender
+Latest in legal saga involving Jeffrey Epstein, 61, financier convicted of procuring
+minor for prostitution
+By Brett Clarkson, Sun Sentinel
+7:43 PM EDT, April 21, 2014
+Did a Palm Beach billionaire being investigated for having sex with young girls use his advertisement
+wealth to negotiate a lenient and secret agreement that saw him avoid federal
+prosecution?
+Appeals cour Ning aims ancieland ex oPender elzey postin, it an answer thanks to an
+The ruling, issued Friday, orders federal authorities to disclose the correspondence that took place
+between Epstein's attorneys and federal prosecutors when they were negotiating a 2007 agreement,
+which allowed him to escape federal prosecution if he pleaded guilty to state charges that carried a
+lesser penalty.
+"We're trying to figure out if Epstein used his political connections and great wealth to secure this
+kind of arrangement, that was unheard of, frankly, if you look at these charges," said Paul Cassell, an
+attorney for the women.
+pstein is a native New Yorker who according to media reports built a huge fortune as a mone
+nanager and owns several properties including a primary residence in Manhattan, a Palm Beac
+mansion and his own island in the Caribbean. At one point he counted among his friends former
+President Bill Clinton, Donald Trump and other high-powered figures.
+The appeal court decision described the background of Epstein's case, stating that in 2006, the Federal
+Bureau of Investigation "began investigating allegations that Jeffrey Epstein had sexually abused
+several minor girls."
+In September 2007, federal prosecutors struck the non-prosecution deal with Epstein, but didn't tell
+the victims, court filings say.
+"Not only did the United States neglect to confer with the victims before it entered into the agreement
+with Epstein, it also failed to notify them of its existence for at least nine months," Circuit Judge
+William H. Pryor wrote in the appeals court decision.
+http://www.sun-sentinel.com/news/palm-beach/fl-jeffrey-epstein-federal-court-of-appeals-2.. 5/2/2014
+
+
+In June 2008, Epstein pleaded guilty to a state charge of procuring a person under the age of 18 for
+prostitution and was sentenced to 18 months in prison. He spent 13 months behind bars, and is
+registered as a sex offender in Florida.
+The situation also resulted in civil suits being filed against Epstein, who according to media reports
+settled claims from about two dozen young women who alleged he paid them for sexual massages at
+his Palm Beach mansion, some as young as 14, according to media reports.
+To the attorneys who represent the Jane Does 1 and 2, the sentence was much lighter than the years,
+or possibly decades, that Epstein could've spent behind bars had he been prosecuted in the federal
+system.
+They're hoping that the correspondence, ordered released by the Eleventh Circuit Court of Appeals,
+will shed light on what they say is an unusually lenient deal.
+"I can say that I've been teaching criminal law for more than two decades and I have never seen a plea
+agreement as lenient as this one, for hands-on sex offenders," said Cassell, who is based in Salt Lake
+But one of Epstein's attorney'S, Martin Weinberg, based in Boston, disputed those characterizations.
+Weinberg said Monday that the plea agreement was "reached in good faith" and that "it's not a fair
+conclusion" to describe the agreement as either improper or tainted by Epstein's wealth.
+"It's Mr. Cassell's hope that this correspondence may support that theory, but the reality is that the
+U.S. Attorney's Office made a responsible judgment in how to implement the law," Weinberg said.
+Weinberg said he was concerned about the potential impact the ruling would have on the ability of
+criminal defense attorneys and prosecutors to communicate confidentialiy.
+He also said he and Epstein co-counsel, Miami criminal defense attorney Roy Black, will ask the
+Atlanta-based appeals court to review the decision.
+As for the Jane Does, who are now over 18, it's just the latest development in a long legal saga,
+another one of their attorneys said.
+"They're pretty numb at this point to favorable news because they've heard this before and nothing's
+happened," said Fort Lauderdale attorney Brad Edwards.
+Edwards and Cassel said their goal is to have Epstein's plea agreement deemed to be in violation of
+federal victims' rights legislation and invalidated. Edwards said Epstein should face a new
+prosecution.
+Edwards also said he was first told by the U.S. Attorney's Office that he would receive the
+correspondence documents on Monday, but was then told that they weren't ready yet. Cassell said the
+documents number 500 pages.
+In an email, Annette Castillo, spokeswoman for the U.S. Attorney's Office, Southern District of
+Florida, said the office couldn't comment.
+bsclarkson@iribune.com, 561-243-6609 or Twitter @BreClarkson.
+http://www.sun-sentinel.com/news/palm-beach/f1-jeffrey-epstein-federal-court-of-appeals-2... 5/2/2014
+
+
+13
+Copyright © 2014, South Florida Sun-Sentinel
+http://www.sun-sentinel.com/news/palm-beach/fl-jeffiey-epstein-federal-court-of-appeals-2.. 5/2/2014
+
+
+52201 Case 9:08-CV-80736-KAMla Document 247-6 redantered com ELS0D0sket:06/0212014 Page 11 of
+8:87 L.74
+my Friday, May 2, 2014
+The Palm Beach POstREAL NEWS STARTS HERE
+Sign Out
+Search Site
+Feedback
+Q
+HOME / NEWS
+inter Sorrint
+Resize text A A. A
+Appellate ruling could force feds to reconsider sex charges against Palm
+Beacher Epstein
+Posted. 9.25 v.m. Monday. April 21,2014
+BYDAPHNE DURET - PALM BEACH POST STAFF WRITER
+A federal appellate court has moved two young victims of billionaire sex offender Jeffrey Epstein a step closer
+to wiping out a plea deal that prosecutors made behind their backs.
+The lith Circuit Court of Appeals ruled Friday that the underage victims were entitled to see all
+correspondence between federal prosecutors and Epstein's lawyers regarding a secret 2007 plea deal that
+kept Epstein from federal charges in exchange for an 18-month work-release sentence in state prison.
+The plea negotiations took place as Epstein litigated a series of now-settled civil claims surrounding
+allegations that he had sex in his Palm Beach mansion with dozens of underage girls.
+The two victims who are seeking the documents are not identified in court documents. They were 12 and 13 at
+http://www.mypalmbeachposl.com/news/news/appeilale-ru/ing-could-force-feds-lo-reconsider-se/nffLw/7cid=pbp_inlernallink_mypbpinvtationbox_/eb2014_99cda
+16
+
+
+52/201 Case 9:08-0-80736-KAkaDament 847s 8 redonteered 010E Dohe 05402/2014 Page 12 of
+the time of their liaisons with Epstein, who pleaded guffly to two prostitution solicitation charges. The girls
+reached an out-of-court settlement with him.
+In ruling that the correspondence should be public, the appellate court authorized the release of more than
+500 pages of documents. The victims' lawyers would use the documents to prove that, by keeping the
+agreement secret, prosecutors violated a federal act aimed at protecting victims' rights.
+A win in that battle could invalidate Epstein's agreement with federal prosecutors, allowing them to
+reconsider criminal charges, but this time with input from the victims.
+Epstein's lawyers argued that the correspondence constituted confidential plea negotiations and therefore
+should not be shared with the victims' lawyers.
+"Although plea negotiations are vital to the functioning of the criminal justice system, a prosecutor and target
+of a criminal investigation do not enjoy a relationship of confidence and trust when they negotiate," the
+appellate justices wrote, calling the prosecutor-defense attorney relationship adversarial.
+They upheld a 2013 ruling by U.S. District Court Judge Kenneth Marra. He ordered the release of all the plea
+documents, but only federal prosecutors complied.
+The victims' attorneys, Brad Edwards and Paul Cassell, have called the ruling a victory for the rights of victims
+to be heard, even in cases like Epstein's, where federal prosecutors ultimately never filed charges. The victims
+were unaware of the plea agreement until three days before Epstein pleaded to the state charges in June 2008.
+A federal deal had been in place for nine months by then.
+Had prosecutors filed charges and negotiated a plea with Epstein in federal court, they would be barred from
+seeking any additional punishment against him. But because his plea agreement to a sex solicitation charge
+came in state court, federal prosecutors theoretically could charge him again.
+Still, Epstein's lawyers could argue that the only reason he agreed to the state sentence was because he
+believed it would free him of the federal charges for good. Edwards said Epstein's attorneys have made parts
+of those arguments in pre-trial hearings, and he expects them to appeal Friday's ruling. Epstein's Bostonbased attorney, Martin Weinberg, told the Palm Beach Daily News he would appeal.
+"While respectful of the panel's decision, given issues of overriding importance to the criminal justice system
+regarding the need for continued confidentiality for communications between defense lawyers and
+prosecutors, we will be petitioning the court of appeals for further review," Weinberg told the paper.
+Invalidating Epstein's plea would force federal prosecutors to meet with the alleged victims to hear their
+comments on whether to pursue charges against Epstein. They still could decline.
+"You can't force the federal government to prosecute anyone," Edwards said. "But we're hoping that if maybe
+http://www.mypalmbeachpost.com/news/news/appellate-ruling-could-force-feds-lo-reconsider-se/nffLw/7icid=pbp_internallink_mypbpimilationbox_feb2014_99cda
+2/6
+
+
+5/2/201 Case 9:08-CV-80736-KA# Document 247-grantered nFLSO Døeke+05/0242014 Page 13 of
+we get some new eyes on the case and the circumstance are different, things will change."
+In this Section
+Palm Beach County Sheriff's Office offers salule to 16 fallen in the line of duty over the decades
+Free movie at Boynlon's Dewey Park on Friday
+Boynton Beach officers stop lo investigate Camaro, witness theft of BMW; pursuit ends in crash
+Greenacres single-family home development moving forward
+Our Economy: Gardens complexlands 3 sizeable businesses
+Morning commute on 195, turnpike clear of crashes from Boca to Vero
+Find out how to work on the Riviera Beach marina development
+Royal Palm Beach Publix sells Fantasy 5 ticket now worth more than $111K
+Sun, rain today and mostly rain Saturday in Palm Beach County, TCoast
+3 NYPD officers arrested in separate gun incidents
+PREVIOUS:
+LOCAL
+Tequesta crash sends seven people to
+hospitals
+NEXT:
+OPINION
+Commentary: Has GM pulled a Pinto?
+Popular on MyPalmBeachPost.com
+All Comments (o)
+Post a Comment
+COMMENTS
+Post comment
+http://www.mypa/mbeachposl.com/nens/news/appellale-ruling-could-farce-feds-lo-reconsider-se/nfiLw/7icidspbp_internallink_mypbpirvitationbox_/eb2014_95cda
+3/6
+
+
+PRIVILEGE LOG
+Description
+P-000001
+thru
+P-000039
+P-000040
+thru
+P-000549
+ttorney (Villafaña) handwritten note
+Operation Leap Year Grand Jury Lo
+Box #I
+P-000550
+thru
+P-000621
+File folder entitled "Ritz Compact Flash SW"
+containing copies of a sealed search warrant
+application, warrant, and supporting documents
+Box #I
+P-000622
+thru
+P-000693
+File folder entitled "PNY Technologies Compact
+Flash SW" containing copies of a sealed search
+warrant application, warrant, and supporting
+documents
+P-000694
+thru
+P-000781
+P-000782
+thru
+P-000803
+P-000804
+thru
+P-000854
+File folder entitled "JE Corporations" containing
+attorney research on Epstein-owned corporations
+and prior litigation
+Capital One
+onsining desponded "Correspondenc
+File folder entitled "DTG Operations/Dollar
+Rent-a-Car" containing subpoena and responsive
+documents
+
+Contains documents subject
+this litigation
+Contains information subject
+to investigative privilege
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+this litigation
+Contains information subject
+to investigative privilege
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+Contains information subject
+to investigative privilege
+
+
+P-000855
+thru
+P-000937
+P-000938
+thru
+P-000947
+P-000948
+thru
+P-000982
+Description
+File folder entitled "JP Morgan Chase'
+ontaining subpoena, correspondence, and
+responsive documents
+File folder entitled "Washington Mutual"
+containing subpoena, correspondence, and
+responsive documents
+File folder entitled "Computer Search &"
+containing legal research on computer search and
+handwritten notes on indictment preparation
+P-000983
+thru
+P-001007
+File folder entitled "Attorney Notes from
+Document Review" containing typed and
+handwritten attorney (Villafaña) notes, target
+letters, correspondence re grand jury subpoena
+P-001008
+thru
+P-001056
+File folder entitled "Notes from Fed Ex Records"
+containing handwritten and typed attorney
+(Villafaña) notes and screen shots of FedEx
+subpoena response electronic file
+P-001057
+thru
+p-001959
+P-001960
+Thru
+P-002089
+File folder entitled "Colonial Bank Records"
+containing records received in response to grand
+jury subpoena
+File folder entitled "OLY Grand Jury Log Vol 2:
+OLY-51 THROUGH" containing subpoenas
+numbered OLY-51 through OLY-81 with related
+
+Contains documents and
+information subject to
+investigative privilege
+Contains documents and
+information subject to
+investigative privilege
+Attorney-Client
+Contains information subject
+to investigative privilege.
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+this litigation
+Contains information subject
+to investigative privilege
+Also contains informatior
+subject to privacy rights of
+victims who are not parties to
+this litigation
+Contains information subject
+to investigative privilege.
+Also contains information
+Contains information subject
+to investigative privilege
+
+
+P-002090
+Thru
+P-002169
+P-002170
+Thru
+P-002246
+P-002247
+Thru
+P-002265
+P-002266
+Thru
+P-002386
+File folder entitled "JEGE & Hyperion from
+Goldberger OLY-46 & OLY-47*
+documents received in response to sontaining
+Indictment preparation binder containing:
+Grand jury subpoena log, evidence/activity
+summary chart, witness/victim names and contact
+list, attorney (Villafaña) handwritten notes, 302s,
+portions of state investigative file, attorney
+(Villafaña) typed notes, of individuals listed as
+"Additional victims"
+P-002387
+Thru
+P-002769
+P-002770
+Thru
+P-003211
+exual activity summary, telephone call summar
+persons identified as Jane Does #1, 2, 3, 4, 5, 6, 7,
+
+Contains information and
+documents subject to
+investigative privilege
+Contains information and
+documents subject to
+investigative privilege
+Contains information and
+documents subject to
+investigative privilege
+Contains information and
+documents subject to
+investigative privilege. Also
+contains information and
+documents subject to privacy
+rights of victims who are not
+Contains information and
+documents subject to
+investigative privilege. Also
+contains information and
+documents subject to privacy
+rights of victims who are not
+documents subject to
+investigative privilege. Also
+
+
+P-003212
+Thru
+P-003545
+Description
+Indictment preparation binder containing metaanalysis charts of telephone/flight/grand jury
+information for a number of victim/witnesses.
+and
+P-003546
+Thru
+P-003552
+FBI Reports of March 2008 interviews of
+additional witness/victim located in New York
+P-003553
+Thru
+P-003555B
+P-003556
+Thru
+P-003562
+P-003563
+Thru
+P-003629
+P-003630
+Thru
+P-003633
+P-003634
+Thru
+P-003646
+Printout of filenames from Federal Express
+subpoena response with Attorney notations
+Document entitled "Identified Numbers" with
+accompanying handwritten attorney list compiled
+from grand jury materials and attorney analysis of
+records
+Folder entitled "Flight Manifests" containing
+manifests received pursuant to grand jury
+subpoena
+File folder entitled "Recent Attorney Notes"
+ontaining handwritten attorney (Villafaña) note
+egarding document review and case strateg
+ile folder bearing victim name containing FE
+iterview report from May 2008, telephor
+hactivity e potes, elated grand uny material
+
+'ontains information an
+locuments subject to
+Contains information subject
+to investigative privilege
+Contains information and
+documents subject to
+investigative privilege
+Delibera preprocess
+Attorney-client privilege
+
+
+P-003647
+Thru
+P-003651
+File folder entitled "Summary of Sexual Activity"
+containing chart bearing handwritten title "Sexual
+Activity - Summary" with meta-analysis of
+information, sorted by name of each
+ictim/witness, including name and identifyin
+Box #I
+P-003652
+Thru
+P-003663
+P-003664
+Thru
+P-003678
+P-003679
+Thru
+P-003680
+P-003681
+Thru
+P-003687
+P-003688
+Thru
+P-003693
+P-003694
+Thru
+P-003711
+File folder entitled "Victim Civil Suits"
+Produced to counsel for
+File folder entitled "Research re JE Websites"
+containing attorney research
+File folder entitled "Serene Cano (N.Y. AUSA)"
+containing attorney (Villafaña) handwritten notes
+File folder entitled "Dr. Anna Salter" containing
+attorney (Villafaña) memo to expert witness and
+handwritten attorney notes
+File folder entitled "I) G[) Interview" containing
+attorney handwritten notes of interview, and
+attorney handwritten notes regarding potential
+charges
+File folder entitled "Research re Travel for
+rostitution" containing attorney (Villafaña
+handwritten notes regarding grand jury
+victims who are not parties to
+this litigation
+P-003712
+
+
+
+P-003713
+Thru
+P-003746
+P-003747
+Thru
+P-003751
+P-003752
+Thru
+P-004295
+P-004296
+Thru
+P-004350
+File folder entitled "T] M[J" containing grand
+jury subpoenas, motion and order to compel
+testimony. and correspondence regarding same
+File folder entitled
+containing
+subpoena and correspondence regarding same
+File folder entitled "PBPD Investigative File"
+obtained via subpoena
+File folder bearing name of victim/witness
+containing meta-analysis chart showing telephone
+calls, travel, and grand jury materials relevant to
+possible charges
+Box #l
+P-004351
+Thru
+P-004381
+Box #I
+P-004382
+Thru
+P-004478
+P-004479
+Thru
+P-004551
+P-004552
+Thru
+P-004555
+File folder entitled L
+Documents
+53909-004" containing attorney research related
+to bias issue
+File Folder entitled "FEDEX" containing
+documents obtained via subpoena
+File Folder entitled "State of Delaware Records"
+containing documents obtained in preparation for
+indictment
+File folder entitled "Jet Blue Records" containing
+documents obtained via subpoena
+P-004556
+Thru
+P-004560
+File folder entitled "FL EMPLOYMENT
+RECO is so lie it tonds on targets
+
+Documents under seal
+pursuant to court order
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+Also contains information an‹
+rights of victims to are no
+
+
+P-004561
+Thru
+P-004565
+P-004566
+Thru
+P-004716
+Filed folder entitled "JANUSZ BANASIAK"
+containing attorney (Villafaña) handwritten notes
+of interview
+File folder entitled "JANUSZ BANASIAK
+RECORDS 23-0001 THROUGH 23-" containing
+documents obtained via subpoena
+P-004717
+Thru
+P-004722
+P-004723
+Thru
+P-004725
+P-004726
+Thru
+P-004819
+P-004820
+Thru
+P-004959
+P-004960
+Thru
+P-005059
+File folder entitled "GOR ZINOVIEV"
+containing attorney research regarding witness
+File folder entitled "BEAR STEARNS
+RESEARCH" containing attorney research
+regarding potential witness and subpoena
+File folder entitled "LAWSUITS INVOLVING
+EPSTEIN CORP'S" containing attorney research
+regarding Epstein's past personal and business
+Filed folder entitled "SEC RECORDS"
+containing attorney research regarding Epstein
+File folder entitled "Message Pads" containing
+selected items from evidence obtained via
+subpoena
+P-005060
+Thru
+P-005081
+P-005082
+Thru
+P-005083
+File folder bearing name of victim/witness
+containing correspondence with counsel for
+rictim/witness, attorney witness outline wit
+torney handwritten notes, attorney handwritter
+notes regarding witness reports and case
+preparation
+File folder entitled "New York Trip" containing
+attorney notes re witness interview
+
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+Also contains information and
+documents subject to privacy
+
+
+P-005108
+Thru
+P-005193
+P-005194
+Thru
+P-005300
+documents and have been remove
+ile folder entitled "ANNA SALTER" containin
+attorney research onsider pes, ase of expensi
+research materials on offenders and victims
+File folder entitled "Extra Copies" containing
+eta-analysis chart and 302's of victim/witnesse
+sed in preparing indictment packas
+P-005301
+Thru
+P-005331
+P-005332
+Thru
+P-005341
+P-005342
+Thru
+P-005387
+P-005388
+Thru
+P-005442
+File folder entitled "JUAN ALESSI
+STATEMENT" containing transcript obtained via
+subpoena
+File folder entitled "KEN LANNING" containing
+attorney research on select expert, including
+attorney handwritten notes
+File folder entitled "Info re Planes" containing
+correspondence regarding subpoenas and
+documents received in response to subpoenas
+and attorney handwritten notes, p
+editory hamdwrite denes, ing information
+File folder entitled "[Victim name] Transcript of
+Interview & GJ Transcript"
+P-005443
+Thru
+P-005496
+P-005497
+Thru
+P-005556
+File folder entitled "Bear Stearns Subpoena
+Resp." containing material received in response
+to subpoena
+
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+
+
+P-005557
+Thru
+P-005576
+P-005578
+Thru
+P-005583
+P-005584
+Thru
+P-005606
+S. Attorney's Office Criminal Case File Jacke
+ontaining file opening documents, expe
+witness payment documents
+U.S. Attorney's Office Asset Forfeiture Case File
+Jacket containing file opening and file closing
+documents
+File folder entitled "6001 Immunity Request"
+containing internal mendand eking wines
+P-005607
+Thru
+P-005914
+File folder entitled "MASTER PHONE
+RECORDS" containing meta-analysis of all
+phone, travel, and grand jury data for all
+victim/witnesses for indictment preparation
+P-005915
+Thru
+P-005977
+File folder bearing name of victim/witness
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+indictment preparation
+P-005978
+Thru
+P-006050
+File folder bearing name of victim/witness
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+indictment preparation
+P-006051
+Thru
+P-006065
+File folder bearing name of victim/witness
+ontaining meta-analysis of all phone, travel, an
+rand jury data related to that victim/witness fo
+
+Privileges) Asserted
+Work product and
+deliberative process (as to
+internal memoranda)
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+
+
+P-006066
+Thru
+P-006220
+File folder entitled "JANE DOE #4" containing
+meta-analysis of all phone, travel, and grand jury
+data related to that victim/witness for indictment
+preparation
+P-006221
+Thru
+P-006222
+File folder entitled " JANE DOE #12" containing
+meta-analysis of all phone, travel, and grand jury
+data related to that victim/witness for indictment
+preparation
+P-006223
+Thru
+P-006522
+File folder entitled "CORRECTED PHONE
+RECORDS 5/31/07" containing meta-analysis of
+all phone, travel, and grand jury data related to all
+victims/witnesses for indictment preparation
+P-006523
+Thru
+P-006802
+File folder entitled "[Victim Name] Phone
+Records" containing telephone records received
+in response to subpoena
+P-006803
+Thru
+P-006860
+P-006861
+Thru
+P-007785
+File folder entitled "Lists of Identified Phone
+Numbers" containing charts of information culled
+from grand jury materials, interviews, and other
+investigation, with attorney handwritten notes,
+and information to issue follow-up grand jury
+File folder entitled "EPSTEIN/KELLEN CELL
+notes and highlighting
+
+Also contains information and
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+Vork produc
+
+
+P-007786
+Thru
+P-008120
+Description
+Folder entitled "OLY GRAND JURY LOG:
+OLY-01 THROUGH OLY-50" containing
+subpoenas, correspondence regarding same, 6(e)
+letters, attorney handwritten notes regarding
+records received in response to subpoenas
+Handwritten flight logs received in response to
+subpoena
+P-008121
+Thru
+P-008139
+P-008140
+Thru
+P-008298
+P-008299
+Thru
+P-008363
+identifying information, photographs, and
+summary of activity
+File folder entitled "FINAL AGREEMENTS"
+containing subfolder entitled "Agrmts Filed ir
+State Court" (P-008300-P-008327 [not being
+withheld as privileged - have been produced to
+opposing counsel]); signed Non-Prosecution
+Agreement, Addendum, and operative portion of
+12/19/2007 Sanchez-Acosta letter (P-008328-P-
+008343 [not being withheld as privileged - have
+been produced to opposing counsel]); subfolder
+containing unredacted copies of that letter (P-
+P-008364
+Thru
+P-008382
+P-008383
+Thru
+P-008516
+Circuit)
+Immunity Request"
+containing internal memoranda, Justice
+Department documentation, and subpoen
+
+Also contains information and
+documents subject to privacy
+rights of victims who are no
+Also contains information and
+locuments subject to privac
+ights of victims who are no
+Deliberative Process
+
+
+P-008517
+Thru
+P-008535
+P-008536
+Thru
+P-008542
+P-008543
+Thru
+P-008549
+P-008550
+Thru
+P-008615
+Description
+6/25/2007 Letter from Gerald Lefcourt to Jeffrey
+Sloman and Andrew Lourie
+[pursuant to Court's Order, not being withheld as
+privileged - will be produced to opposing counsel
+Handwritten attorney notes to prepare for
+Handwriton grand yuy pearing May 8,
+File folder entitled "Most Recent Indictment &
+Good Cases" containing draft indictment and
+legal research
+P-008616
+Thru
+P-008686
+File folder entitled "FBI Summary Charts"
+containing chart prepared at direction of AUSA
+containing victim names, identifying information
+summary of activity, and other information
+relevant to indictment
+P-008687
+Thru
+P-008776
+victim/witness for indictment preparation
+P-008777
+Thru
+P-008808
+File folder entitled "[Victim name ]/Jane Doe #5"
+
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+who are not parties to this suit
+
+
+P-008809
+Thru
+P-008847
+P-008848
+Thru
+P-008862
+P-008863
+Thru
+P-008890
+P-008891
+Thru
+P-009103
+P-009104
+Thru
+P-009111
+P-009112
+Thru
+P-009113
+P-009114
+Thru
+P-009115
+P-009116
+Thru
+P-009125
+File folder entitled "[Victim name]/Jane Doe #6"
+ontaining meta-analysis of all phone, travel, al
+and jury data related to that victim/witness f
+File folder entitled "[Victim name]/Jane Doe #7"
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+File folder entitled "[Victim name]/Jane Doe #8"
+containiny deta reaty to thal prime traves and
+indictment preparation
+Villaz and Karen Anison rece fire patein
+(work release)
+[pursuant to Court's Order, not being withheld as
+privileged - will be produced to opposing counsel
+
+
+
+P-009126
+Thru
+P-009134
+P-009135
+Thru
+P-009141
+P-009141A
+Thru
+P-009141C
+P-009142
+Thru
+P-009152
+P-009153
+Thru
+P-009156
+P-009157
+Thru
+P-009208
+P-009209
+Thru
+P-009213
+File folder entitled "Victim name]/Jane Doe #9"
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+indictment preparation
+File folder entitled "[Victim name]/Jane Doe
+·13" containing meta-analysis of all phone
+travel, and grand jury data related to tha
+victim/witness for indictment preparation
+ile folder entitled "[Victim name]/Jane Do
+12" containing meta-analysis of all phon
+travel, and grand jury data related to that
+victim/witness for indictment preparation
+File folder entitled
+containing meta-analysis of all phone, travel, and
+grand jury data related to that individual for
+indictment preparation
+File folder entitled
+containing meta-analysis of all phone, travel, and
+grand jury data related to that individual for
+indictment preparation
+File folder entitled "[Victim name]/Jane Doe #1"
+Dhone. travel. an
+grading neta related is ofall icon witnes, an
+File folder entitled "[Victim name]/Jane Doe #2"
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Investigative privileg
+Contina cy forms on subject
+who are not parties to this sui
+
+
+P-009214
+Thru
+P-009271
+P-009272
+Thru
+P-009354
+P-009355
+Thru
+P-009403
+P-009404
+Thru
+P-009536
+P-009537
+Thru
+P-009574
+P-009575
+Thru
+P-009603
+P-009604
+Thru
+P-009711
+P-009712
+Thru
+P-009819
+P-009820
+Thru
+P-009965
+P-009966
+Thru
+P-010096
+Description
+File folder entitled "[Victim name]/Jane Doe #3"
+ontaining meta-analysis of all phone, travel, an
+rand jury data related to that victim/witness fo
+indictment preparation
+File folder entitled "Purpose of Travel Cases"
+containing attorney research and handwritten
+notes
+File folder entitled "Interstate Commerce Cases"
+containing attorney research and handwritten
+notes
+File folder entitled "Attorney Conflict Research"
+containing attorney research and handwritten
+notes
+File folder entitled "Mann Act/Travel to Have
+Sex w/Minor" containing attorney research and
+handwritten notes
+File folder entitled "Travel Act" containing
+attorney research and handwritten notes
+File folder entitled "Florida
+Prostitution/Lewdness Statutes" containing
+attorney research and handwritten notes
+Booklet entitled "Attorney General Guidelines for
+Victim and Witness Assistance" [not being
+withheld as privileged - produced to opposing
+counsel]
+File folder entitled "Corporate Liability Rsrch"
+containing attorney research and handwritten
+notes
+File folder entitled "Research re Knowledge of
+Age Unnecessary" containing attorney research
+and handwritten notes and copy of grand jury
+ontains information subje
+o privacy rights of victim
+who are not parties to this suit
+
+
+
+P-010097
+Thru
+P-010276
+P-010277
+Thru
+P-010394
+P-010395
+Thru
+P-010488
+P-010489
+Thru
+P-010509
+P-010510
+Thru
+P-010525
+P-010526
+Thru
+P-010641
+Description
+File folder entitled "Money Laundering"
+containing attorney research and handwritten
+notes
+File folder entitled "1960 & Aiding/Abetting"
+containing attorney research and handwritten
+notes
+File folder entitled "18 USC $ 2255 Cases"
+containing attorney research and handwritten
+notes
+Wines Testimony Pointing aloney es e
+and handwritten notes
+File folder entitled "Extradition" containing
+attorney research and handwritten notes
+File folder entitled "Rsrch re Crime Victims
+Rights" containing attorney research, handwritten
+notes, draft victim notification letter, and draft
+correspondence to Jay Lefkowitz
+(Also contains a November 28, 2007 letter from
+Kenneth Starr to Alice S. Fisher; and a November
+29, 2007 letter from Jay Lefkowitz to R.
+Alexander Acosta (P-010528 thru P-010530 and
+'-010556 thru P-010559). Pursuant to the
+Court's Order, these will be produced to opposin
+counsel upon lift of stay by I!" Circuit)
+iloroly entired " munity" containin
+witnesses
+Deliberative Process
+P-010642
+Thru
+P-01650
+P-010651
+Thru
+P-010659
+P-010660
+Thru
+P-010757
+File folder entitled "Research re GJ Transcript"
+containing grand jury subpoena, 6(e) letters,
+attorney research and correspondence related to
+
+
+
+P-010758
+Thru
+P-010793
+P-010794
+Thru
+P-010829
+P-010830
+Thru
+P-010853
+P-010854
+Thru
+P-010876
+P-010877
+Thru
+P-010920
+P-010921
+Thru
+P-011049
+P-011050
+Thru
+P-011212
+P-011213
+Thru
+P-011237
+P-011238
+Thru
+P-011319
+P-011320
+Thru
+P-011361
+P-011362
+Thru
+P-011374
+Description
+File folder entitled "Original Proposed Ind."
+containing draft indictment
+File folder entitled "Epstein" containing sample
+indictments and attorney research re potential
+charges with attorney notes
+File folder entitled "1591 & Money Laundering"
+containing attorney research and handwritten
+notes
+File folder entitled "18 USC 2425" containing
+attorney research and handwritten notes
+File folder entitled "Knowledge of Age"
+containing attorney research and handwritten
+notes
+File folder entitled "2423(b) Constitutionality and
+Purpose of Travel" containing attorney research
+and handwritten notes
+File folder entitled "Mistake not a
+Defense" containing attorney research and
+handwritten notes
+File folder entitled "Research re 'Pandering''
+containing attorney research and handwritten
+notes
+File folder entitled "Research re Grand Jury
+Instructions" Candivine horney research and
+File folder entitled "Def of Prostitution"
+containing attorney research and handwritten
+notes
+
+
+
+P-011375
+Thru
+P-011456
+P-011457
+Thru
+P-011626
+P-011627
+Thru
+P-011662
+P-011663
+Thru
+P-011698 and
+P-012189 thru
+P-012361
+(gap was
+scanning error)
+P-011699
+Thru
+P-011777
+P-011778
+Thru
+P-011788
+P-011789
+Thru
+P-011879
+P-011880
+Thru
+P-011922
+Descriptio
+ile folder entitled "Relevant Florida Statutes
+containing attorney research and handwritten
+notes
+File folder entitled "Unit of Prosecution
+Research" containing attorney research and
+handwritten notes
+File folder entitled "Attorney Notes" containing
+attorney handwritten and typed notes
+File folder entitled "Drafts" containing draft
+indictments with attorney handwritten notes, draft
+internal memoranda, relevant witness interview
+reports and grand jury material and attorney
+File folder entitled "6/9/09 Signed Indictment"
+containing signed indictment package dated
+6/9/2009 with corrections
+File folder entitled "6/12/09 Victim Notif, Log"
+containing chart with victim contact informatior
+and attorney notes regarding dates and type of
+contacts
+File folder entitled "Breach Memo" containing
+memorandum analyzing breach of Non-
+Prosecution Agreement with attachments
+File folder entitled "Overt Act Lists" containing
+preparation
+
+Deliberative Process
+Contains information subject
+to privacy rights of victims
+who are not parties to this
+Attorney-client privilege
+
+
+P-011923
+Thru
+P-011966
+Description
+Folder entitled "Responses to Arguments from JE
+Counsel" containing:
+7/13/2007 letter from Lilly Ann Sanchez
+to Andrew Lourie with handwritten
+attorney (Lourie) notes;
+• 6/25/2007 letter from Gerald Lefcourt to
+Jeffrey Sloman, Matt Menchal, Andrew
+Lourie, and
+Marie Villafaña with
+handwritten attorney (Villafaña) notes;
+• 6/25/2007 email from Andrew Lourie to
+P-011967
+Thru
+P-012016
+Y repacing investigoron handave stenges
+regarding i
+P-012017
+Thru
+P-012055
+P-012056
+Thru
+P-012088
+P-012089
+Thru
+P-012129
+P-012130
+Thru
+P-012150
+P-012151
+Thru
+P-012167
+Motion of Jeffrey Epstein to Intervene and to
+Quash Grand Jury Subpoenas and Incorporated
+Memorandum of Law
+Affidavit of Roy Black, Esq. in Support of
+Motion of Jeffrey Epstein to Intervene and to
+Quash Grand Jury Subpoenas
+United States' Response to Motion of Jeffrey
+pstein to Intervene and to Quash Grand Jur
+ubpoenas and Cross-Motion to Compe
+Declaration of Joseph Recarey
+Ex Parte Declaration Number One in Support of
+United States' Response to Motion to Quash
+Subpoenas
+
+
+
+P-012168
+Thru
+P-012170
+P-012171
+Thru
+P-012173
+P-012174
+Thru
+P-012176
+P-012177
+Thru
+P-012178
+P-012179
+Thru
+P-012188
+Ex Parte Declaration Number Two in Support of
+United States' Response to
+Subpoenas
+Motion to Quash
+Supplement to Ex Parte Declaration Number One
+in Suash openiad States Response to Motion
+Draft of September 2009 letter from Marie
+Undated handwritten attorney (Villafaña) notes
+regarding negotiations and allegations
+File Folder entitled "FBI G.J. Log" containing
+opy of FBI grand jury subpoena log wit
+torney (Villafaña) handwritten note
+P-012362
+Thru
+P-012451
+File folder entitled "Key Documents" containing
+correspondence between AUSA and case agent
+regarding indictment prep questions, victim
+identification information, corrections to draft
+indictment, indictment preparation timeline, key
+P-012451
+Thru
+P-012452
+File folder entitled "Victim List" containing list
+of victims with dates of birth and age information
+
+Deliberative Process
+Deliberative Process
+Also contains information
+visubie to paranor paris to
+this litigation
+Attorney-Client privilege
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+this litigation
+this litigation
+
+
+P-012453
+Thru
+P-012623
+Description
+Complete indictment package marked "Originals
+12/12/07'
+P-012624
+Thru
+P-012653
+P-012654
+Thru
+P-012864
+P-012865
+Thru
+P-013226
+P-013227
+P-013226
+Thru
+P-013230
+P-013231
+Thru
+P-013239
+Folder entitled "(Victims) Additional 302's"
+containing reports of interviews conducted in
+June 2007, October 2007, and March 2008.
+3-ring binder entitled "Child Molesters: A
+Behavioral Analysis" with attorney (Villafaña)
+handwritten notes
+witness/victim list with identifying information
+sexual activity summary, telephone call summar
+hart, attorney (Villafaña) handwritten notes
+02s, portions of state investigative file, attorne
+analysis charts, victim/witness photographs,
+DAVID records, NCICs, and related materials for
+14
+pril 23,
+A tie or Proteinal response Some sel
+Reporting April 21, 20 Ye Lete of the previously
+April 21, 2008 Letter from Jeffrey Sloman to
+Office of Professional Responsibility re Self
+Reporting
+
+Work-product
+Also contains documents
+subject to investigative
+Also contains documents
+subject to privacy rights of
+victims who are not parties to
+this litigation
+Deliberative Process
+Also contains documents
+subject to investigative
+Also contains documents
+subject to privacy rights of
+victims who are not parties to
+
+
+P-013240
+Thru
+P-013247
+P-013248
+Thru
+P-013251
+April 21, 2008 Letter from Jeffrey Sloman to
+Office of Professional Responsibility re Self
+Reporting with attachments
+P-013252
+Thru
+P-013253
+P-013254
+Thru
+P-013257
+P-013258
+Thru
+P-013259
+P-013260
+Thru
+P-013262
+Assistant U.S. And Bey Soul Cem bestrict of
+Assistant U.S. Attorney,
+August 3, and August 24, 2011
+Richard
+Sudder, Assistant
+General Counsel, Executive Office for United
+States Attorneys, and Benjamin Greenberg, First
+Assistant U.S. Attorney, Southern District of
+Florida, regarding Formal Notice of Office-wide
+Recusal of Southern District of Florida dated
+August 24 and August 29, 2011
+Emails
+between
+Richard Sudder, Assistant
+General Counsel, Executive Office for United
+States Attorneys, and Benjamin Greenberg, First
+Assistant U.S. Attorney, Southern District of
+Florida, regarding Formal Notice of Office-wide
+Recusal of Southern District of Florida dated July
+28 and August 3, 2011
+mail from Richard Sudder, Assistant Genera
+'ounsel, Executive Office for United State
+DAL, Sober MiNede
+avid Margolis (ODAG), Jay Macklin (USAEO'
+Thomas Anderson (USAEO),
+(USAEO), James Read (USAEO)
+
+
+
+P-013263
+Thru
+P-013271
+Description
+between Richard Sudder, Assistant
+Assistant U.S. Attorney,
+Assistant U.S. A orley. Southern bistrict st
+Memoradam To are attach ed
+memorandum from
+Benjamin
+P-013272
+Thru
+P-013278
+Cassell to Wifredo A. Ferrer, dated December 10,
+2010
+
+
+
+To:
+Big.imL.aw@aol.comfBig.imlaw@aol.com):
+Subject:
+RE:
+Sent:
+Tue 10/24/2006 5:51:08 PM
+From:
+Villafana, Ann Marie C. (USAFLS)
+Hi Jim - Thank you for the e-mail, and I will even forgive the football reference. I was
+just set for trial, so the earliest I will be able to reschedule the testimony will be after
+Thanksgiving. I will give you a call to discuss the immunity issue but I am concerned
+about other things we have talked about -- if Ms.
+is given immunity, will she be
+forthcoming and answer the questions? Or am I going to jump through hoops to get her
+immunity and then have to worry about filing motions to compel, motions for orders to
+show cause why she shouldn't be held in contempt, etc., etc.?
+As always, thank you for your assistance.
+Regards,
+Marie
+A. Marie Villafaña
+Assistant U.S. Attorney
+561 209-1047
+Fax 561 820-8777
+ann.marie.c.villafana@usdoj.gov
+From: BigJimLaw@aol.com [mailto:BigJimLaw@aol.com]
+Sent: Tuesday, October 24, 2006 12:00 PM
+Subject Ra, AM Marie G, (USAFLS)
+Sorry I did not get back to you sooner. I have been out of town for several weeks. As
+to Miss
+she still does not wish to testify in this case and has a Fifth Amendment
+basis for her position. She wishes not to accept the "proffer letter " cover of immunity,
+which again is her right. I think it is a waste of time to have her appear Friday to just
+ake the Fifth. I suggest that you nuddle with your people, (It is football season)..
+ou want to push the issue you will have to get formal immunity. I will accept servic
+down. Jim Eisenberg
+08-80736-CV-MARRA
+P-013875
+
+
+Memorandum
+Subject
+Date
+Re: Jeffrey Epstein Investigation
+July 26, 2011
+To
+From
+Benjamin Greenberg, First Assistant U.S. Attorney
+A. Marie Villafaña
+Introduction
+This memorandum summarizes the conflict of interest related to the investigation
+by the Federal Bureau of Investigation ("FBI") of additional crimes committed by Jeffrey
+Epstein ("Epstein"). The memo begins with a brief overview of the original investigation
+of Epstein, dubbed "Operation Leap Year"; summarizes the resolution of Operation Leap
+Year by the Southern District of Florida; and addresses the events following the
+resolution of Operation Leap Year, including the basis for the conflict. Lastly, the memo
+briefly addresses the additional crimes that the FBI wants to investigate.
+1l.
+"Operation Leap Year"
+The investigation of Jeffrey Epstein initially was undertaken by the City of Palm
+Beach Police Department in response to a complaint received from the parents of a
+14-year-old girl,
+from Royal Palm Beach. When
+and another girl began
+fighting at school because the other girl accused
+of being a prostitute, one of the
+school principals intervened. The principal searched
+purse and found $300 cash.
+The principal asked
+where the money came from.
+initially claimed that she
+earned the money working at "Chik-Fil-A," which no one believed.
+then claimed
+that she made the money selling drugs; no one believed that either.
+finally
+admitted that she had been paid $300 to give a massage to a man on Palm Beach island.
+parents approached the Palm Beach Police Department ("PBPD") about pressing
+charges.
+PBPD began investigating the recipient of the massage, Jeffrey Epstein, and two of
+his assistants
+PBPD identified 27 girls who went to
+
+
+Epstein's house to perform "massage services" (not including one licensed massage
+therapist). The girls' ages ranged from 14 years' old to 23 years' old. Some girls saw
+Epstein only once and some saw him dozens of times. The "massage services"
+performed also varied. Some girls were fully clothed while they massaged Epstein; some
+wore only their underwear; and some were fully nude. During all of these massages,
+Epstein masturbated himself and he would touch the girl performing the massage, usually
+fondling their breasts and touching their vaginas - either over their clothing or on their
+bare skin. Epstein often used a vibrator to masturbate the girls and digitally penetrated a
+number of them. For the girls who saw him more often, Epstein graduated to oral sex
+and vaginal sex. Epstein sometimes brought his assistant/girlfriend
+into the sexual activity. One of the girls described
+as Epstein's "sex slave".
+On October 18, 2005, PBPD obtained a search warrant with the assistance of the
+Palm Beach County State Attorney's Office ("PBSAO"). By this time, PBSAO had
+already been contacted by Epstein's cadre of lawyers. When PBPD arrived at Epstein's
+home two days later (10/20/05) to execute the search warrant, they found several items
+con picus sly mising or examp, crite monitor and ere bound, vert found but
+disconnected and the videotapes were gone. Nonetheless, the search did recover some
+evidence of value, including message pads showing messages from many girls over a two
+year span. The messages show girls returning phone calls to confirm appointments to
+"work." Messages were taken by three of Epstein's "personal assistants."
+Photographs taken inside the home showed that the girls' descriptions of the layout
+of the home and master bedroom/bathroom area were accurate. PBPD also found
+massage tables and oils, the high school transcript of one of the girls, and sex toys.
+'During a meeting, two of Epstein's attorneys, Gerald Lefcourt and Lilly Ann Sanchez,
+admitted that attorney Roy Black instructed Epstein to have the CPUs removed although they
+insisted that those instruction were given well in advance of the execution of the search warrant -
+not in response to a "leak."
+2
+
+
+In sum, the PBPD investigation showed that girls from Royal Palm Beach High
+School would be contacted by one of Epstein's assistants to make an appointment to
+"work." Up to three appointments each day would be made. The girls would travel to
+Epstein's home in Palm Beach where they would meet Epstein's chef and Epstein's
+assistant-usually
+-in the kitchen. The assistant would escort the girls
+upstairs to the master bedroom/bathroom area and set up the massage table and massage
+oils. The girl sometimes was instructed to remove her clothing. The assistant would
+leave and Epstein would enter the room wearing a robe. He would remove the robe and
+lie face down and nude on the massage table. Epstein would then instruct the girl on
+what to do and would ask her to remove her clothing. After some time, Epstein would
+turn over, so that he was lying face up. Epstein would masturbate himself and fondle the
+girl performing the massage. When Epstein climaxed, the massage was over, and the girl
+was instructed to get dressed and to go downstairs to the kitchen while Epstein showered.
+Epstein's assistant would be in the kitchen and the girl would be paid-usually $200-and
+if it was a "new" girl, the assistant would ask for the girl's phone number to contact her in
+the future? Girls were encouraged to find other girls to bring with them. If a girl
+brought another girl to perform a "massage," each girl would receive $200. Each time a
+girl returned to the house, Epstein would pressure the girl to go further sexually,
+advancing to oral sex and sexual intercourse. Epstein would pay more for these acts - in
+the words of one girl, "the more you do, the more you make."
+The PBPD investigation consisted primarily of sworn taped statements from the
+girls. When PBPD began having problems with PBSAO, they approached the FBI. The
+investigation was formally presented to the FBI and to the U.S. Attorney's Office after
+PBSAO "presented" the case to a state grand jury and the state grand jury returned an
+indictment charging Epstein only with one felony count of solicitation of [adult]
+prostitution.
+After the matter was presented to the U.S. Attorney's Office and there was a
+determination that federal statutes had been violated, FBI, ICE, and the U.S. Attorney's
+Office opened files. The federal investigation focused on the interstate nexus requirec
+for all of the federal violations, so a number of grand jury subpoenas were issued for
+telephone records, flight manifests, and credit card records. The federal agents also
+re-interviewed some of the girls. The agents delved into Epstein's history and interviewed
+other girls and obtained records to corroborate the girls' stories. FBI also interviewed
+'Sometimes Epstein made the payment and asked for the phone number, sometimes it
+was the assistant.
+3
+
+
+girls who came forward after the PBSAO indictment was reported in the papers and the
+additional girls identified through those interviews.
+The attempt to handle secretly the federal case was doomed from the start when
+the Chief of the Palm Beach Police Department gave a letter to each of the victims
+identified through his investigation telling them that, because of his disappointment in the
+way that the PBSAO had handled the case, the matter had been referred to the FBI.
+Almost immediately, Epstein's attorneys began calling to request a meeting with the U.S.
+Attorney's Office. When one attorney was unable to schedule a meeting, Epstein hired
+another attorney who called up the chain of command until someone agreed to a meeting.
+Between January and May 2007, an indictment package was prepared, charging
+Epstein and three of his personal assistants with a number of child exploitation offenses.
+The case agent made several appearances before the grand jury. Attorneys for Epstein
+made several presentations to the U.S. Attorney's Office to convince the Office not to
+prosecute, and made allegations of prosecutorial misconduct against the line Assistant and
+the First Assistant U.S. Attorney. Epstein also challenged the legal analysis behind the
+prosecution, both within the U.S. Attorney's Office (up to the U.S. Attorney) and to the
+Child Exploitation and Obscenity Section at the Justice Department. All of Epstein's
+challenges were considered and rejected.
+III. The Resolution of "Operation Leap Year"
+On September 24, 2007, Epstein signed a Non-Prosecution Agreement wherein the
+U.S. Attorney's Office for the Southern District of Florida promised not to prosecute
+Epstein for the crimes that were the subject of the grand jury investigation if: (1) he pled
+guilty to two crimes in state court - the state felony prostitution charge and a state charge
+of procuring minors into prostitution, which would require Epstein to register as a sex
+offender; (2) he were sentenced to at least 18 months' imprisonment, and (3) he agreed to
+pay damages to the victims of his offenses. After signing this Agreement, Epstein and
+his counsel decided that they were dissatisfied with its terms, and again complained to the
+Justice Department, seeking review to the Deputy Assistant Attorney General and the
+Deputy Attorney General.
+After those attempts also failed, on June 30, 2008, Epstein entered his guilty plea
+in state court and began serving his sentence.
+IV.
+Post-Resolution Events
+A few days before the plea and sentencing (in state court those occur on the same
+4
+
+
+day), the Assistant U.S. Attorney handling the matter contacted counsel for three of
+Epstein's identified victims and informed him of the upcoming court date, encouraging
+his clients to attend and be heard. They did not appear. On July 7, 2008, two of those
+victims filed suit against the United States in federal court claiming that their rights had
+been violated under the Crime Victims' Rights Act because they had not been consulted
+before the Office entered into the Non-Prosecution Agreement. (This will be referred to
+as the "CVRA Action.")
+After an initial flurry of activity, the Petitioners obtained a copy of the confidential
+Non-Prosecution Agreement, and the Court ordered that it be shared with all of the
+identified victims. After it was provided, the Petitioners and most of Epstein's victims
+focused on their civil suits against him.
+In 2009, the U.S. Attorney's Office in Fort Lauderdale initiated an investigation
+into a Ponzi scheme operated by Scott Rothstein through his law firm. As part of his
+Ponzi scheme, Rothstein told investors that his law firm represented several of Epstein's
+victims and that Epstein was willing to pay huge sums of money to avoid exposing his
+criminal activities. The attorney representing the victims in the CVRA Action, Brad
+Edwards ("Edwards"), worked at the Rothstein firm. Epstein sued Edwards, alleging that
+Edwards was part of the Ponzi scheme, and alleging that Edwards' attempts to subpoena
+some of Epstein's high-powered friends were done to increase the value of the Ponzi
+scheme, rather than for legitimate discovery purposes.
+In the summer of 2010, most of the civil suits against Epstein were settled,
+including the suits filed by the two victims in the CVRA Action. All of the settlements
+were confidential, so it is unknown how much each of the victims received.
+In September 2010, U.S. District Judge Kenneth Marra, who handled most of the
+civil cases and the CVRA Action, issued an Order closing the CVRA Action. Almost
+immediately thereafter, the Petitioners filed a Motion to Reopen, stating that they had
+obtained discovery through their civil suits against Epstein that showed that the U.S.
+Attorney's Office had violated their rights as victims.
+For several months, attempts were made to resolve the matter. In short, the
+victims have asked that the U.S. Attorney's Office disavow the Non-Prosecution
+Agreement, on the basis that the CVRA was violated, and bring charges against Epstein.
+Edwards has said that one of his clients repeatedly calls and asks him when Epstein is
+going to jail. One of the other attorneys on the case has suggested that emails he
+5
+
+
+considers to be embarrassing to the Office will not be disclosed if we re-open our
+investigation of Epstein and prosecute him.
+Herein lies the conflict. If the U.S. Attorney's Office for the Southern District of
+Florida re-initiates a grand jury investigation of Jeffrey Epstein, it will be perceived -
+correctly or incorrectly - as having been done at the insistence of the victims in the
+CVRA Action. And Epstein will allege that any prosecution arising therefrom will have
+been undertaken in an effort to resolve the CVRA Action, not based upon the merits of
+the investigation itself.
+The FBI's Current Investigation
+The main focus of the FBl's current investigation is a victim,
+who
+refused to speak with agents during the "Operation Leap Year" investigation. Based
+upon her debriefing, Epstein engaged in several additional crimes, in the Southern District
+of Florida and, more importantly, in several other Districts, with
+and other minor
+females. Epstein transported
+in his private airplanes to engage in sexual activity
+with him. Epstein also "pimped"
+to several of his other important friends, and
+transported her to those sexual encounters. This activity was not part of the initial
+investigation.
+also reported that, during the "Operation Leap Year" investigation, she
+was contacted by Epstein's investigators, lawyers, and Epstein himself, and offered
+payment to remain silent when contacted by the police.
+FBI agents are seeking grand jury subpoenas at this time to corroborate
+statement. They also are asking for permission to approach one of Epstein's "personal
+assistants," who was served with a target letter during the "Operation Leap Year"
+investigation, to give her a "de-target" letter and interview her.
+There are several other Districts that may have jurisdiction over the additional
+crimes under investigation. Epstein lived and still lives in the Southern District of New
+York; he engaged in sexual activity with
+in the S.D.N.Y.; and it is believed that
+he made the calls from the S.D.N.Y. to
+wherein he offered to pay her to keep her
+from speaking to law enforcement. When Epstein would fly into and out of New York,
+however, he used the airport in Teterboro, New Jersey, so the District of New Jersey also
+has jurisdiction over charges related to traveling in interstate commerce to engage in
+illicit sexual conduct and transporting minors in interstate commerce.
+reported
+6
+
+
+that Epstein engaged in sexual activity with her on his private island in the U.S. Virgin
+Islands and also had her engage in sexual activity with one of his friends on that island, so
+the District of the Virgin Islands also would have jurisdiction.
+also reported
+frequent sexual activity with Epstein in the District of New Mexico and the Central
+District of California. In both of those Districts there is evidence (from
+or other
+witnesses) of Epstein engaging in illegal sexual activity with other underage victims, as
+well.
+7
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/ec22cf40d7ffd15e3e139516fb854d95a25abbf58bb6f2ad34438cab14af54d9.receipt.json b/vision-fixhub/ds9-unparsed-05/ec22cf40d7ffd15e3e139516fb854d95a25abbf58bb6f2ad34438cab14af54d9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..df4daed620c7301da2a98b2a743eedc1e4c042d4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ec22cf40d7ffd15e3e139516fb854d95a25abbf58bb6f2ad34438cab14af54d9.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -8503,
+  "dataset": "marble-joined",
+  "doc_id": "ec22cf40d7ffd15e3e139516fb854d95a25abbf58bb6f2ad34438cab14af54d9",
+  "engine": "marble-apple-vision",
+  "event_count": 186,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "dd862a43181bd365b0771c38cf67b28793833e94526f9a273cd1025f88723dc2",
+  "output_sha256": "89dd75c5970a6565fedf98aeff7eabbe88b499eafd1523e5756fedc0ce971efa",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ec8c5a2505245bbb03b5f9385aa971dc8ec465b4107c16c3300c242bd5d7a91b.md b/vision-fixhub/ds9-unparsed-05/ec8c5a2505245bbb03b5f9385aa971dc8ec465b4107c16c3300c242bd5d7a91b.md
new file mode 100644
index 0000000000000000000000000000000000000000..429a4af8224e9bf63d92c1da29b6fd52699c3f67
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ec8c5a2505245bbb03b5f9385aa971dc8ec465b4107c16c3300c242bd5d7a91b.md
@@ -0,0 +1,255 @@
+• (USAFLS)
+To:
+Cc:
+Subject:
+(USAFLS)
+Wednesday, December 19, 2007 4:03 PM
+(USAFLS)
+(USAFLS)
+Your questions
+- I didn't see any reference to an immediate decision, but the only December 17* letter that I have is one
+signed both by Jay and by Ken Starr. If there is another letter, can you ask Annette to scan and e-mail it?
+The December 17" letter that I have does contain a repetition of their allegation that someone in our office
+referred to the State Attorney's Office as "a joke." This is something that someone from the defense group
+(probably Jack Goldberger) told Barry Krischer that we had said. During the meeting between
+had to spend several minutes convincing Barry that it had never been said. We then told the
+defense group (Goldberger, Lefcourt, and Lefkowitz) that it had never been said, and they then denied that they
+had made such a statement to Barry. Since this is going up to DOJ, you may want to reiterate that we never
+have made such a statement.
+You also may want to remind the defense that we had proposed only that the defendant agreed that the girls
+were "victims," not that they had suffered "injury," and that Mr. Lefkowitz proposed the waiver of liability and
+damages in his draft on September 21" so we are having to fix one of their invited errors (again).
+Not that I am a conspiracy theorist, but one begins to wonder whether they created these two errors (choosing
+the wrong state statute and putting in broad liability waiver language) in order to create a problematic
+agreement.
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 1
+Fax 561 820-8777
+Tracking:
+2171
+P-014448
+
+
+To:
+Cc:
+Subject:
+in blue.)
+(USAFLS)
+(USAFLS)
+Wednesday. December 19, 2007 3:30 PM
+(USAFLS)
+(USAFLS)
+RE:
+- I just made some small changes below. Also, footnote one seems to end mid-sentence. (My changes are
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach. FL 33401
+Phone
+Fax 561 820-8777
+(USAFLS)
+Sent: Wednesday, December 19, 2007 2:48 PM
+To:
+(USAFLS)
+Cc:
+(USAFLS)
+Subject:
+Running a bit late for the 2 45:
+In the interim, here's a draft for review:
+I write to follow up on the December 14" meeting between defense counsel and the Epstein prosecutors,
+as well as our First Assistant, the Miami FBI Special Agent in Charge and myself.' I write to you because 1 am
+not certain who among the defense team is the appropriate recipient of this letter. I address issues raised by
+several members of the defense team, and would thus ask that you please provide a copy of this letter to all
+appropriate defense team members.
+First, I would like to address the Section 2255 issue." As I stated in my December 4* letter, my
+understanding is that the Non-Prosecution Agreement entered into between this Office and Mr. Epstein
+responds to Mr. Epstein's desire to reach a global resolution of his state and federal criminal liability. Under
+this Agreement, this District has agreed to defer prosecution for enumerated sections of Title 18 in favor of
+prosecution by the State of Florida, provided that the Mr. Epstein satisfies three general federal interests: (1)
+that Mr. Epstein plead guilty to an offense requiring sex offender registration; (2) that this plea include a
+binding recommendation for a sufficient term of imprisonment; and (3) that the Agreement not harm the
+interests of his victims.
+With this in mind, I have considered defense counsel arguments regarding the Section2255 portions of
+the Agreement. As I previously observed, our intent has been to place the victims in the same position as they
+would have been had Mr. Epstein been convicted at trial. No more; no less. During the course of negotiations
+2183
+P-014449
+
+
+that intent was reduced to writing in Paragraphs 7 and 8, which, as I mentioned previously, appear far from
+simple to understand. I would thus propose that we say precisely what we mean, in a simple fashion. I would
+replace Paragraphs 7 and 8 with the following language:
+"Any person who, while a minor, was a victim of a violation of ap offense enumerated in Title 18,
+United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would
+have had if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes
+of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of
+individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr.
+Epstein. Any judicial authority interpreting this provision, including any authority determining which
+evidentiary burdens, if any, a plaintiff must meet, shall consider that it is the intent of the parties to place
+these identified victims in the same position as they would have been had Mr. Epstein been convicted at
+trial. No more; no less."
+Second, I would like to address the issue of victims' rights pursuant to Section 3771. I understand that
+the defense objects to the victims being given notice of time and place of Mr. Epstein's state court change of
+plea hearing. I have reviewed the proposed victim notification letter and the statute. I would note that the
+United States provided the draft letter to defense as a courtesy. In addition, Mr. Sloman already incorporated in
+the letter several edits that had been requested by defense counsel. I agree that Section 377l, strictly
+interpreted, applies to notice of proceedings and results of investigations of federal crimes, as opposed to the
+state crime. It is our intent to provide victims with notice of the federal resolution, as required by law. We will
+defer to the discretion of the State Attorney to determine if he wishes to provide victims with notice of the state
+proceedings, although we will provide him with the information necessary to do so if he wishes.
+Third, I would like to address the issue raised regarding Florida Statute Section 796.03. At our meeting.
+Professor Dershowitz took the position that Mr. Epstein believes that his conduct does not satisfy the elements
+of this offense. His assertion raises for me substantial concerns. This Office will not, and cannot, be a party to
+an agreement in which Mr. Epstein pleads guilty to an offense that he believes he did not commit. We are
+considering how best to proceed.
+Finally, I would like to address a more general point. Our Agreement was first signed on September
+24, 2007. Pursuant to paragraph 11, Mr. Epstein was to use his best efforts to enter his guilty plea and be
+sentenced no later than October 26, 2007. As outlined in correspondence between our prosecutors and defense
+counsel, this deadline came and went. Our prosecutors reiterated to defense counsel several times their
+concerns regarding delays, and in fact, asked me several weeks ago to declare the Agreement in breach because
+of those delays. I resisted that invitation.
+It is for this reason that I have expressed frustration with what appears to be an 11 hour appeal, weeks
+Important and much be uly veted. hope to Tsar saide amlary a conce ash this in mind, anded are
+event that defense counsel may wish to seek review of our determinations in Washington D.C, I conferred this
+past Monday with the Assistant Attorney
+, to inform her of a possible appeal, to asked her to
+grant the potential request for review, and to in fact review this case in an expedited manner to attempt to
+preserve the January 4* plea date. I understand that defense counsel shares our desire not to move that
+appearance and will work with our office to expedite this process over the next several days.
+I want to again reiterate that it is not the intention of this Office ever to force the hand of a defendant to
+enter into an agreement against his wishes. Your client has the right to proceed to trial, and he should do so if
+he believes that he did not commit the elements of the charged offense.
+2184
+P-014450
+
+
+I will respond to the pending issues shortly. In the interim, I would ask that you communicate your
+position with respect to the sections 2255 and 377l issues.
+Sincerely,
+UNITED STATES ATTORNEY
+Over the past two weeks, we have received several hundred letters and exhibits from defense counsel. Our failure to respond to eac
+em should not be taken to imply concurrence. I would like to note two items. First, your December 11* letter states that as a resu
+of an independent old pany so tor A real prieste. sire propod knowledge of dense const pries. proposed,
+the Addendum sua sponte to Mr. Lefkowitz at an October meeting in Palm Beach. I did this in an attempt to avoid a contusion
+selection process. It was only after I proposed this that Mr. Lefkowitz raised with me his concerns. Second,
+"Section 2255 provides that: "[a]ny person who, while a minor, was a victim of a violation of [enumerated sections of Title 18] and
+who suffers personal injury as a result of such violation... may sue in any appropriate United States District Court and shall recover
+the actual damages such person sustains and the cost of the suit, including a reasonable attorney's fee."
+Tracking:
+2185
+P-014451
+
+
+- (USAFLS)
+(USAFLS)
+Wednesday. December 19, 2007 2:48 PM
+- (USAFLS)
+(USAFLS)
+Running a bit late for the 2 45:
+In the interim, here's a draft for review:
+I write to follow up on the December 14" meeting between defense counsel and the Epstein prosecutors,
+as well as our First Assistant, the Miami FBI Special Agent in Charge and myself! I write to you because I am
+not certain who among the defense team is the appropriate recipient of this letter. I address issues raised by
+several members of the defense team, and would thus ask that you please provide a copy of this letter to all
+appropriate defense team members.
+First, I would like to address the Section 2255 issue." As I stated in my December 4' letter, my
+understanding is that the Non-Prosecution Agreement entered into between this Office and Mr. Epstein
+responds to Mr. Epstein's desire to reach a global resolution of his state and federal criminal liability. Under
+this Agreement, this District has agreed to defer prosecution for enumerated sections of Title 18 in favor of
+prosecution by the State of Florida, provided that the Mr. Epstein satisfies three general federal interests: (1)
+that Mr. Epstein plead guilty to a "registerable" offense; (2) that this plea include a binding recommendation for
+a sufficient term of imprisonment; and (3) that the Agreement not harm the interests of his victims.
+With this in mind, I have considered defense counsel arguments regarding the Section2255 portions of
+the Agreement. As I previously observed, our intent has been to place the victims in the same position as they
+would have been had Mr. Epstein been convicted at trial. No more; no less. During the course of negotiations
+that intent was reduced to writing in Paragraphs 7 and 8, which I as mentioned previously, appear far from
+simple to understand. I would thus propose that we say precisely what we mean, in a simple fashion. I would
+replace Paragraphs 7 and 8 with the following language:
+"Any person, who while a minor, was a victim of a violation of an offense enumerated in Section 2255,
+will have the same rights to proceed under 2255 as they would have had, if Mr. Epstein been tried
+federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the
+United States shall provide Epstein's attorneys with a list of individuals whom it was prepared to name
+in an Indictment as victims of an enumerated offense by Mr. Epstein. "Any judicial authority interpreting
+this provision, including any authority determining which evidentiary burdens if any a plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in the same
+position as they would have been had Mr. Epstein been convicted at trial. No more; no less."
+Second, I would like to address the issue of victim's rights pursuant to Section 377l. I understand that
+defense objects to the victims being given notice of time and place of Mr. Epstein's state court change of plea
+hearing. I have reviewed the proposed victim notification letter and the statute. I would note that the United
+States provided the draft letter to defense as a courtesy. In addition, Mr. Sloman already incorporated in the
+letter several edits, which had been requested by defense counsel. I agree that Section 377l, strictly
+interpreted, applies to notice of proceedings involving the federal crime, as opposed to the state crime. It is our
+intent to provide victims with notice of the federal resolution, as required by law. We will defer to the
+2191
+P-014452
+
+
+discretion of the State Attorney to determine if he wishes to provide victims with notice of the state
+proceedings, although we will provide him with the information necessary to do so if he wishes.
+Third, I would like to address the issue raised Florida Statute Section 796.03. At our meeting, Professor
+Dershowitz took the position that Mr. Epstein believes that his conduct does not satisfy the elements of this
+offense. His assertion raises for me substantial concerns. This Office will not, and cannot, be a party to an
+agreement in which Mr. Epstein pleads guilty to an offense that he believes he did not commit. We are
+considering how best to proceed.
+Finally, I would like to address a more general point. Our Agreement was first signed on September
+24"', 2007. Pursuant to paragraph 11, Mr. Epstein was to use his best efforts to enter his guilty plea and be
+sentenced no later than October 26, 2007. As outlined in correspondence between our prosecutors and defense
+counsel, this deadline came and went. Our prosecutors reiterated to defense counsel several times their
+concerns regarding delays, and in fact, asked me several weeks ago to declare the Agreement in breach because
+of those delays. I resisted that invitation.
+It is for this reason that I have expressed frustration with what appears to be an 11" hour appeal, weeks
+before the now scheduled January 4 plea date. That said, timeliness concerns aside, the issues raised are
+important and must be fully vetted. We hope to preserve the January 4" date. With this in mind, and in the
+event that defense counsel may wish to seek review of our determinations in Washington D.C, I conferred this
+past Monday with the Assistant Attorney
+, to inform her of a possible appeal, to asked her to
+grant the potential request for review, and to in fact review this case in an expedited manner to attempt to
+preserve the January 4* plea date. I understand that defense counsel shares our desire not to move that
+appearance and will work with our office to expedite this process over the next several days.
+I want to again reiterate that it is not the intention of this Office ever to force the hand of a defendant to
+enter into an agreement against his wishes. Your client has the right to proceed to trial, and he should do so if
+he believes that he did not commit the elements of the charged offense.
+I will respond to the pending issues shortly. In the interim, I would ask that you communicate your
+position with respect to the sections 2255 and 3371 issues
+Sincerely,
+UNITED STATES ATTORNEY
+'Over the past two weeks, we have received several hundred letters and exhibits from defense counsel. Our failure to respond to each
+item should not be taken to imply concurrence. I would like to note two items. First, your December 11' letter states that as a result
+of defense counsel objections to the appointment process, the USAO proposed an addendum to the Agreement to provide for the use
+of an independent third party selector. As I recall this matter, before we had any knowledge df defense counsel objections, 1 proposed
+the Addendum sua sponte to Mr. Lefkowitz at an October meeting in Palm Beach. I did this in an attempt to avoid a contusion
+selection process. It was only after I proposed this that Mr. Lefkowitz raised with me his concerns. Second,
+"Section 2255 provides that: "[a]ny person who, while a minor, was a victim of a violation of [enumerated sections of Title 18] and
+who suffers personal injury as a result of such violation... may sue in any appropriate United States District Court and shall recover
+the actual damages such person sustains and the cost of the suit, including a reasonable attorney's fee."
+2192
+P-014453
+
+
+To:
+Subject:
+. (USAFLS)
+(USAFLS)
+Wednesday, December 19, 2007 2:07 PM
+- (USAFLS):
+RE: Tam back from my depositions
+(USAFLS); Castillo, Annette (USAFLS)
+Wasn't there a letter in which Jay said we made a decision to proceed the same day as the WPB meeting? I'n
+rying to list various factual errors, and as I recall, we did not make an on the spot dêcision but waited for the FBI tr
+confirm certain views.
+(USAFLS)
+Sent: Wednesday. December 19. 2007 12:16 PM
+(USAFLS);
+(USAFLS);
+Subject: T am back from my depositions
+(USAFLS)
+You can reach me at
+Thank you.
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone |
+Fax 561 820-8777
+2195
+P-014454
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/ec8c5a2505245bbb03b5f9385aa971dc8ec465b4107c16c3300c242bd5d7a91b.receipt.json b/vision-fixhub/ds9-unparsed-05/ec8c5a2505245bbb03b5f9385aa971dc8ec465b4107c16c3300c242bd5d7a91b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..aaf590576595d14b5bbf68e75b8546355f0e6834
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ec8c5a2505245bbb03b5f9385aa971dc8ec465b4107c16c3300c242bd5d7a91b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -271,
+  "dataset": "marble-joined",
+  "doc_id": "ec8c5a2505245bbb03b5f9385aa971dc8ec465b4107c16c3300c242bd5d7a91b",
+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "708223fa83c8c63b471687770cd35b98b665cef743aa4b83b50cac20b1af2a1b",
+  "output_sha256": "869aa6d916e69fa1701df834a90ffdfe73107a6870a9d9cba475268ab3ed6cb1",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ed328cd2af8e339ad56b8289d87684acf09d9d6f02d30a6e9ca9a6af49c76bde.md b/vision-fixhub/ds9-unparsed-05/ed328cd2af8e339ad56b8289d87684acf09d9d6f02d30a6e9ca9a6af49c76bde.md
new file mode 100644
index 0000000000000000000000000000000000000000..adba114a589d8fccd03de2e5c29af479ee90d332
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ed328cd2af8e339ad56b8289d87684acf09d9d6f02d30a6e9ca9a6af49c76bde.md
@@ -0,0 +1,365 @@
+Case 9:08-CV-80119-KAM Document 49
+Entered on FLSD Docket 10/31/2008 Page 1 of 11
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/JOHNSON
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80232-MARRA/JOHNSON
+CASE NO.: 08-CV-80380-MARRA/JOHNSON
+/
+CASE NO.: 08-CV-80381-MARRA/JOHNSON
+
+
+Case 9:08-CV-80119-KAM Document 49
+Entered on FLSD Docket 10/31/2008 Page 2 of 11
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-80994-CIV-MARRA/JOHNSON
+CASE NO.: 08-80993-CIV-MARRA/JOHNSON
+PLAINTIFFS' MEMORANDUM OF LAW
+IN OPPOSITION TO MOTIONS TO DISMISS
+Plaintiffs, Jane Does 2-7, by and through undersigned counsel, file this Memorandum of Law
+in Opposition to Motions to Dismiss, pursuant to S.D.Fla.L.R. 7.1(C), as follows:
+I.
+Introduction and Summary
+Defendant's Motions to Dismiss and for More Definite Statement filed in each of the abovecaptioned cases pursuant to Fed.R.Civ.P. 12(b)(6) and 12(e) essentially concede that Plaintiffs have
+alleged the elements of the claims asserted in Counts I and II! of each pleading, but contend that
+more factual allegations are necessary for these claims. The pleadings at issue contain a short and
+plain statement of the claims showing that the Plaintiffs are entitled to relief in accordance with
+Fed.R.Civ.P. 8(a)(2). The specific facts sought by Defendant may properly be the subject of
+discovery, but are not necessary for purposes of pleading. Accordingly, Defendant's Motions are
+without merit and should be denied in their entirety.
+2
+
+
+Case 9:08-cv-80119-KAM
+Document 49 Entered on FLSD Docket 10/31/2008 Page 3 of 11
+II. Facts Plead
+The pleadings in these six cases are all similarly structured and assert the same claims. In the
+section entitled "Factual Allegations" each describes the plan and scheme of Defendant Epstein to
+recruit underage girls to his Palm Beach mansion for "massages". (Jane Doe No. 2 Amd. Compl. "ll
+10-11; Jane Doe No. 3 Amd. Comp. 9| 10-11; Jane Doe No. 4 Amd. Compl. 911-12; Jane Doe No. 5
+Amd. Compl. 9 10-11; Jane Doe No. 6 Amd. Compl. 9|11-12; Jane Doe No. 7 Amd. Compl. 9 11-12).
+The pleading then alleges that, consistent with this scheme, the Plaintiff was lured to Epstein's Palm
+Beach mansion to give a massage for monetary compensation. (Jane Doe No. 2 Amd. Compl. 9 12;
+(Jane Doe No. 3 Amd. Compl. { 12; Jane Doe No. 4 Amd. Compl. 9 13; Jane Doe No. 5 Amd.
+Compl. 9 12; Jane Doe No. 6 Amd. Compl. 1| 13; Jane Doe No. 7 Amd. Compl. f 13). The Plaintiff
+was directed up a flight of stairs to a room where Epstein instructed the Plaintiff to remove her
+clothes and give him a massage. Epstein then masturbated and sexually assaulted the Plaintiff"
+during this massage. (Jane Doe No. 2 Amd. Compl. 9|12; Jane Doe No. 3 Amd. Compl. 912; Jane
+Doe No. 4 Amd. Compl. 913; Jane Doe No. 5 Amd. Compl. 912; Jane Doe No. 6 Amd. Compl. 913;
+Jane Doe No. 7 Amd. Compl. 113).
+Count I of the pleading in each case alleges a claim of sexual assault and battery. Count II
+alleges a claim for intentional infliction of emotional distress, which Defendant does not seek to
+dismiss in his Motions before the Court. Count III alleges a claim for coercion and enticement to
+sexual activity in violation of 18 U.S.C. §2422. Defendant's Motions to Dismiss seek dismissal of
+Counts I and IIl for failure to state a claim under Fed.R.Civ.P. 12(b)(6), or alternatively move for a
+more definite statement under Fed.R.Civ.P. 12(e) on these Counts. As discussed below, Plaintiffs"
+claims are sufficiently plead, and Defendant's Motions should be denied in their entirety.
+3
+
+
+
+III. Argument
+A.
+THE STANDARD UNDER FED.R.CIV.P. 12(b)(6)
+DOES NOT SUPPORT DISMISSAL
+The gravamen of Defendant's Motion is that Plaintiffs' have not pled sufficient facts in
+support of their claims in Counts I and III. According to Defendant, the pleadings in this case do not
+satisfy "the standard of pleading" established in Bell Atlantic Corp. |. Twombly, 127 S.Ct. 1955
+(2007). In making this argument, Defendant would extend Iwombly well beyond its intended
+scope.
+Twombly was an antitrust conspiracy case, in which the Court abrogated the longstanding
+pronouncement first made in Conly ||. Gibson, 355 U.S. 41 (1957), that a complaint should not be
+dismissed under Fed.R.Civ.P. 12(b)(6) "unless it appears beyond doubt that the plaintiff can prove
+no set of facts in support of his claim that would entitle him to relief." 127 S.Ct. at 1969. The Court
+noted that it did "not require heightened fact pleading of specifics, but only enough facts to state a
+claim to relief that is plausible on its face." Id. at 1974 (emphasis supplied). The antitrust
+conspiracy claim before the Court was dismissed "[bjecause the plaintiffs here have not nudged their
+claims across the line from conceivable to plausible. ..." Id.
+Since Twombly, courts and commentators have grappled with the case's meaning and scope.
+Courts within the Eleventh Circuit have held that Twombly did not alter the standard for dismissal
+under Rule 12(b)(6) in the typical case. See, e.g.. CBT Flint Partners, LL.C|. Goodmail Systems,
+Inc., 529 F.Supp. 2d 1376, 1379 (N.D. Ga. 2007); Coughlin |. Wal-Mart Stores East I.P, 2008 WL
+2704381 (M.D. Fla. 2008); Capaz: Whitaker, Weinstraub & Grizzard, M.D.S, P.A., 2007 WL
+1655473 (M.D. Fla. 2007). In CBT Flint Partners, the Court warned against reading the decision in
+Trombly too broadly:
+4
+
+
+Case 9:08-CV-80119-KAM Document 49 Entered on FLSD Docket 10/31/2008 Page 5 of 11
+In my view, Trombly did not radically alter the elementary rules of
+civil procedure that have governed litigation in the federal courts for
+the past seventy years. The Court's forced retirement of Conley I
+Gibson's "no set of facts" language does not change the fundamental
+command of Rule 8 as to what a valid complaint must look like.
+Indeed, the Court made clear that it was not imposing a heightened
+pleading standard. As a general matter, 1 am loath to assume that the
+Supreme Court circumvented the normal channels for amending the
+Federal Rules. The Court's "new standard" was merely a specific
+way to articulate a solution to what it perceived to be a specific
+pleading problem, in a specific area of law that inflicted a high cost
+upon antitrust defendants. It was not a broad based new license for
+federal courts to ramp up pleading requirements.
+529 F.Supp. 2d at 1379 (citations omitted).
+The standard for pleading in the federal courts remains controlled by Fed.R.Civ.P. 8(a)(2),
+which "only requires a short and plain statement of the claim showing that the pleader is entitled to
+relief in order to give the defendant fair notice of what the claim is and the grounds upon which it
+rests." Capaz, 2007 WL 1655473 at *1. While the scope of Twombly may not be entirely clear, it
+plainly cannot be read to turn pleadings into a discovery device, as Defendant advocates here in
+seeking dismissal for failure to plead detailed factual allegations.
+In Iqbal |. Hasty, 490 F.3d 143 (2d Cir. 2007), the Court reviewed and analyzed in depth
+Twombly's "conflicting signals", and ultimately held that the Supreme Court did not impose "a
+universal standard of heightened fact pleading," but rather a "flexible "plausibility standard'". Id.
+at 157-158. This standard "obliges a pleader to amplify a claim with some factual allegations in
+those contexts where such amplification is needed to render the claim plausible." Id. (emphasis
+original). See also Sales |. All Florida Dialysis Services, Inc., 2007 WL 3231723 *2 n.2 (S.D. Fla.
+2007) (noting that Iwombly was inapplicable because the defendants did not raise the type of
+pleading deficiencies confronted in Twombly - lack of specific time, place or person involved in the
+alleged antitrust conspiracies).
+5
+
+
+Case 9:08-cv-80119-KAM Document 49 Entered on FLSD Docket 10/31/2008 Page 6 of 11
+The instant allegations and claims cannot be compared to the speculative antitrust conspiracy
+alleged in Twombly. See 127 S.Ct. at 1965. There should be no doubt that the Plaintiffs' claims are
+plausible. Accordingly, Twombley is not authority for dismissal of the pleadings in these cases.
+THE ELEMENTS OF COUNT I FOR SEXUAL ASSAULT
+AND BATTERY ARE SUFFICIENTLY ALLEGED
+In cach case, the claim in Count I is labeled "Sexual Assault and Battery." Assault and
+battery are closely related common law intentional torts that are often alleged together. See Herzfeld
+1. Herzfeld, 781 So.2d 1070 (Fla.2001) (noting that plaintiff alleged intentional tort of "assault and
+battery" based on allegations of sexual abuse); Sullivan . Atlantic Federal Savings & Loan, 454
+So.2d 52 (Fla. 4th DCA 1984) (holding that a cause of action for assault and battery cannot be based
+entirely on an omission). A common law assault occurs when a person "acts intending to cause a
+harmful or offensive contact with the person of the other, or an imminent apprehension of such
+contact, and the other is thereby put in such imminent apprehension". Restatement (Second) of
+Torts, Assault §21 (1965). "A battery consists of the infliction of a harmful or offensive contact
+upon another with the intent to cause such contact or the apprehension that such contact is
+imminent". See Paul |. Holbrook, 696 So.2d 1371 (Fla. 5th DCA 1997). See also Scelta |
+Delicatessen Support Services, Inc., 57 F.Supp. 2d 1327, 1358-59 (M.D. Fla. 1999) (allegation that
+defendant attempted to put his hands down plaintiff's dress, and that there was an actual and
+intentional touching, sufficient to state a claim for battery; Hogan ]. Tavzel, 660 So.2d 350 (Fla. 5th
+DCA 1995) (tortfeasor may be liable for battery for infecting another with a sexually transmitted
+disease).
+Defendant does not contend that the Plaintiffs failed to allege these elements of the common
+law torts of assault and battery in Count I of their pleadings. Rather, Defendant argues that the
+pleadings fail to allege the specific facts of "what was said or done to Plaintiff. Defendant thus
+6
+
+
+
+misconstrues Twombly. All of the Plaintiffs allege essentially the same plan and scheme of
+Defendant to lure underage girls to his Palm Beach mansion for "massages", leading to Defendant
+engaging in sexual activities with the Plaintiffs. The specific facts concerning what was said and
+done prior to and during the course of these "massages" is the proper subject of discovery, not the
+pleadings. Plaintiffs satisfy the pleading requirements of Fed.R.Civ.P. 8(a)(2), and Twombly does
+not require more specific fact pleading in these cases.
+HI. PLAINTIFFS SUFFICIENTLY ALLEGE A CLAIM
+IN COUNT III FOR VIOLATION OF 18 U.S.C. §2422
+The pleadings in Count III closely track the language of 18 U.S.C. §2422, and thus set forth
+the elements of a violation of this Statute, as follows:
+(i) Allegation in Complaint. Epstein used a facility or means of interstate commerce
+to knowingly persuade, induce or entice Jane Doe, when she was under the age of 18 years,
+to engage in prostitution or sexual activity for which any person can be charged with a
+criminal offense; and
+(ii) 18 U.S.C. §2422(b). Whoever, using the mail or any facility or means of
+interstate or foreign commerce, ... knowingly persuades, induces, entices, or coerces any
+individual who has not attained the age of 18 years, to engage in prostitution or any sexual
+activity for which any person can be charged with a criminal offense, or attempts to do so...
+18 U.S.C. §2455(b); Jane Doe 2 Amd. Compl. 1 29; Jane Doe 3 Amd. Compl. 11 29; Jane Doe 4
+Amd. Compl. 130; Jane Doe 5 Amd. Compl. 1|29; Jane Doe 6 Amd. Compl. 1 28; Jane Doe 7 Amd.
+Compl. 1|29. Defendant does not appear to contend that Plaintiffs have failed to allege the elements
+of a violation of 18 U.S.C. §2422 in Count III, but instead argues that further factual allegations are
+necessary. As with Count I, such specific facts are the proper subject of discovery, and need not be
+set forth in the pleadings under Rule 8(a)(2). There is no issue of plausibility concerning the
+Plaintiffs' claims under 18 U.S.C. §2422. Indeed, the Plaintiffs in these cases were notified by the
+U.S. Attorney's office that the Defendant has agreed that each Plaintiff has the same right to proceed
+on her federal statutory claim "as she would have had if Mr. Epstein had been tried federally and
+7
+
+
+Case 9:08-CV-80119-KAM Document 49 Entered on FLSD Docket 10/31/2008 Page 8 of 11
+convicted of an enumerated offense." (See July 10, 2008 letter from A. Marie Villafaña, Assistant
+U.S. Attorney, attached hereto as Exhibit "A").
+Defendant also attempts to make much of a typographical error that appears in Count Ill in
+the "Wherefore" clause demanding a judgment for damages. There, the pleading inadvertently
+makes reference to 28 U.S.C. §2255(a) instead of 18 U.S.C. §2255(a). As is clear from the
+Defendants' Motions, Defendant is well aware that this is a typographical error and that the intent is
+to reference 18 U.S.C. §2255. In any event, this reference concerns the Plaintiffs' damages, not the
+elements of Plaintiff's claim set forth in the paragraphs above it.' Count III nonetheless satisfies
+Fed.R.Civ.P. 8(a)(3), as the "Wherefore" clause states that Plaintiff seeks actual and compensatory
+damages, costs of suit, attorneys' fees and such other and further relief as this Court deems just and
+proper. If deemed necessary, the typographical error in the "Wherefore" clause of Count Ill can be
+corrected by interlineation. It does not warrant a dismissal and repleading.
+IV.
+THERE IS NO BASIS FOR DEFENDANT'S
+MOTION FOR MORE DEFINITE STATEMENT
+A motion for more definite statement under Fed.R.Civ.P. 12(e) may only be granted "if a
+pleading is so vague or ambiguous that a party cannot reasonably be required to frame a responsive
+pleading." Hernandez|. Two Brothers Farm, L.L.C, 2008 WL 4405409 *1 (S.D. Fla. 2008) (quoting
+Betancourt ]. Marine Cargo Mgmt., 930 F. Supp. 606, 608 (S.D. Fla. 1996)). Federal courts
+disfavor motions for more definite statement. Home Mgmt. Solutions, Inc. _. Prescient, Inc., 2007
+WL 2412834 (S.D. Fla. 2007). Most importantly, "Defendants may not use a motion for more
+definite statement as a means of discovery regarding those claims." Hernandez, 2008 WL 4405409
+at *1. Yet that is exactly how Defendant Epstein uses his Motions for More Definite Statement. He
+'As a result, this reference in error to 28 U.S.C. 2255(a) is not set forth in a paragraph to which
+Defendant would be expected to frame an answer.
+
+
+Entered on FLSD Docket 10/31/2008 Page 9 of 11
+seeks by these Motions specific facts which are the proper subject of discovery, not pleadings.
+Accordingly, Defendants Motions for More Definite Statement should be denied.
+I.
+Conclusion
+For the foregoing reasons, Plaintiffs respectfully request that Defendant's Motion to Dismiss
+be denied in their entirety.
+Dated: October 31, 2008.
+By: _
+Respectfully submitted,
+s/ Jeffrey M. Herman
+Jeffrey M. Herman (FL Bar No. 521647)
+jherman@hermanlaw.com
+Stuart S. Mermelstein (FL. Bar No. 947245)
+ssm@hermanlaw.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@hermanlaw.com
+HERMAN & MERMELSTEIN, P.A.
+Attorneys for Plaintiffs Jane Doe
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: 305-931-2200
+Fax: 305-931-0877
+9
+
+
+
+CERTIFICATE OF SERVICE
+I hereby certify that on October 31, 2008, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day to all parties on the attached Service List in the manner specified, either via transmission of
+Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those
+parties who are not authorized to receive electronically Notices of Electronic Filing.
+s/ Jeffrey M, Herman.
+10
+
+
+
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Michael R. Tein, Esq.
+tein@lewistein.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+Michael Pike, Esq.
+mpike@bclclaw.com
+s/ Jeffrey M. Herman_
+11
+
+
+•Case 9:08-CV-80119-KAM Document 49-2
+V.S. Department of Justice
+Entered on FLSD Docket 10/31/2008 Page 1 of 2
+United States Attorney
+Southern District of Florida
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 10, 2008
+VIA FACSIMILE AND U.S. MAIL
+Jeffrey Herman, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, Florida 33160
+Re:
+Jeffrey Epstein
+•: NOTIFICATION OF
+IDENTIFIED VICTIM
+Dear Mr. Herman:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following notice to your client,
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+
+
+Case 9:08-CV-80119-KAM
+Document 49-2
+Entered on FLSD Docket 10/31/2008 Page 2 of 2
+JEFFREY HERMAN, ESQ.
+NOTIFICATION OF IDENTIFIED VICTIM I
+JULY 10, 2008
+
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+had been tried federally and convicted of an enumerated offense. For purposes
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that your client,
+• is an individual whom the United States was prepared to name as a victim of an
+enumerated offense.
+Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an
+enumerated offense, please provide written documentation of that denial to the undersigned.
+Please thank your client for all of her assistance during the course of this investigation
+and express the heartfelt regards of myself and Special Agents Kuyrkendall and Richards for
+the health and well-being of
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Alie illagana
+A. MARIE VILLAFAÑA
+ASSISTANT U.S. ATTORNEY
+cc:
+Jack Goldberger, Esq.
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/ed328cd2af8e339ad56b8289d87684acf09d9d6f02d30a6e9ca9a6af49c76bde.receipt.json b/vision-fixhub/ds9-unparsed-05/ed328cd2af8e339ad56b8289d87684acf09d9d6f02d30a6e9ca9a6af49c76bde.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..65ab642bcb2e751b3de3f6f125f2f4c506ea3ad8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ed328cd2af8e339ad56b8289d87684acf09d9d6f02d30a6e9ca9a6af49c76bde.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -531,
+  "dataset": "marble-joined",
+  "doc_id": "ed328cd2af8e339ad56b8289d87684acf09d9d6f02d30a6e9ca9a6af49c76bde",
+  "engine": "marble-apple-vision",
+  "event_count": 20,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "f12e25b0518fc984c948c0b2ab67dc23deb19cd492fe959753281781b913966a",
+  "output_sha256": "f14c9c3eb94a7bf0e98698f8b55d5a6cd40b4d378e28994840fadeb92be05f72",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ed4e24cf15f8180b38fa5b84f39115bee8b8b494dbf6011481b4d6b63ec8b93b.md b/vision-fixhub/ds9-unparsed-05/ed4e24cf15f8180b38fa5b84f39115bee8b8b494dbf6011481b4d6b63ec8b93b.md
new file mode 100644
index 0000000000000000000000000000000000000000..c86b9b4f140bbd2f8aac06514e93f0bbc3095f0e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ed4e24cf15f8180b38fa5b84f39115bee8b8b494dbf6011481b4d6b63ec8b93b.md
@@ -0,0 +1,795 @@
+EPSTEIN BOX INVENTORY
+Box A:
+Redwell with different files for each Jane Doe I. Epstein case
+Cd's with Documents on 2"d Supplemental Privilege Log (2) and Bates #s 002111-002266
+Redwell with printout of Documents in the 2"d Supplemental Privilege Log
+6001 Orders
+6001 Immunity Request
+folder
+Jane Doe I. U.S. 6/23/15 production (redwell) with documents
+2nd Supplemental Privilege Log Box 4
+2n° Supplemental Privilege Log Letter 6-23-15 to
+Box B:
+Data Demonstratives Kirkland & Ellis LLP - 6 bound copies and 1 color copy
+Plea Negotiations (redwell) - folders: Non Prosecution Agreement - Final; Attorney Notes re Revised
+Indictment; Research re Boehm case; Research re possible misdemeanors; Notes re Plea Negotiations;
+Plea Agreement drafts; Draft Non Prosecution Agreements; Information Packet drafts
+(file folder)
+(green file folder)
+Re: Epstein Corp. Records (green file folder)
+Non Pros Agrmt & Addendum (file folder)
+Mtg w/ Ken Starr, RAA, JS, Drew (file folder)
+• Target Letter (file folder)
+Notes re Post Agreement Communications (file folder)
+(file folder)
+6/19/08
+6/3/08
+Submission to the DAG (file folder)
+5/27/08
+Submission to the DAG (file folder)
+Submission to the DAG (file folder)
+5/15/08
+Ltr (file folder)
+
+
+Draft Itr from
+Redwell - Folders: 5/22/07
+re termination (file folder)
+to
+; 11/29/07
+12/6/07
+to
+to
+: 11/30/07
+|: 12/7/07
+: 12/13/07
+to
+: 6/25/07
+&
+to
+to
+; 10/25/07
+| (was this sent?); 11/28/07
+to
+L: 8/2/07
+ltr to
+to
+:12/4/07
+to
+; 12/5/07
+; 12/7/07
+to
+I; 12/11/07
+); 12/21/07
+to
+12/26/07
+to
+Redwell - Folders: 11/15/06
+: 11/29/06
+: 11/16/06
+L: 12/1/06
+1/17/07
+: 1/18/07
+/ 1/23/07
+1: 2/1/07
+I; 1/5/07
+to
+1: 2/5/071
+; 11/21/06
+to
+; 1/22/07|
+to
+I to
+2/12/07
+to
+: 2/23/07
+to
+Box C:
+White binder with correspondence filed by Janes Does with Court - clipped section of documents with
+notes
+White binder labeled Leap Year J Marra Issue with notes and opinion and filed documents
+Redwell labeled Telephone Charts with a post it saying Duplicate
+White binder with additional documents filed in Jane Doe case
+White binder with CVRA Research
+White binder labeled Duplicate
+Box D:
+Empty|
+file folder
+Jane Does I. U.S. Standing/Ripeness Research & 6(e) & Due Process Confidentiality Research (redwell)
+Jane Does I. US Supplemental Briefing (redwell)
+Redwell with
+notes; transcript of 8/14/08 hearing in Jane Doe case (DE27); DE 99 Order;
+Westlaw research on Obstruction of Justice Charges can be based on false statements in state
+depositions, including Civil depo, if it is likely to be turned over to federal investigation; DE15-2 Exhibit A;
+"Prince's friendship with pedophile causes furor across the pond" 3/9/11 article from Palm Beach Post;
+additional
+notes; highlighted Federal Register notices; draft letter from
+to Captain
+David
+• PBSO re Epstein's Work Release Application; CVRA research with notes and Westlaw
+printouts; CVRA Research (green file folder)
+
+
+Jane Does I. U.S. Misc (green file folder)
+Florida Bar (redwell) with Self Report folder and 9/16/08 D
+ILtrto M
+Box E:
+(green file folder)
+Motion to Quash (file folder)
+Motion to Quash Riley Subpoenas (red file folder)
+Stolen Globe -
+• (red file folder)
+Cases (file folder)
+] Research (green file folder)
+Westlaw case printouts
+Box F:
+Jane Does Litigation (redwell) with 2 email printouts, Sealed Document Tracking Form with Motion to
+Seal Opposition to Petitioner's Motion Requesting an Order Directing the Government to File Redacted
+Pleadings in the Public Court File, and Red File Folder with documents filed in Jane Doe case
+Jane Does 1 & 2 |. U.S. (redwell) with CD inside mailing from |
+and original redacted
+documents from
+Clipped research with Attachment to Subpoena NES, LLC; article titled "Working for Top Bosses on Wall
+St. Has Its Perks";
+research; L
+Jeffrey Epstein
+(file folder)
+Kastigar Letters (file folder)
+2703 Motion & Order-Cingular (red file folder)
+Grand Jury Transcripts (redwell) with folders for |
+I Transcript 2/6/07;
+| Transcript
+2/27/07; L
+| Transcript 3/20/07; L
+Transcript 4/24/07; 1
+Transcript 4/24/07;
+Transcript 5/8/07;l
+| Transcript 5/8/07;
+Transcript 5/15/07;
+Transcript 5/22/07; L
+Transcript 3/18/08;
+I Transcript 4/29/08
+Pros Memo (file folder) labeled Duplicate
+Proposed Jury Instructions for Violations of 18 USC 2423(b) [Travel in Interstate or Foreign Commerce to
+Engage in Illicit Sexual Conduct]
+Pages 1-6 (of 7 pages) of Non-Prosecution Agreement with highlighted portions
+
+
+file folder with 6/23/08 letter from [
+(DAG) to
+Communication letter re Litigation Hold; clipped Non-Prosecution Agreement
+Doe (
+7) I. Epstein, 08-80893-CV-KAM (red file folder)
+and
+•: 11/2/2010 Privileged
+Box: (labeled GJ Presentation Materials)
+Federal Criminal Code and Rules 2006 Edition with multiple post-its
+File folder with
+Testimony 5/8/07;|
+5/8/07;L
+Testimony 2/6/07;1
+Testimony 4/24/07;
+Testimony 5/15/07;
+Testimony 5/22/07
+US Attorneys' Bulletin: Crafting Helpful Indictments
+| Testimony 4/24/07;1
+2/27/07 (post it says All About/
+Testimony 3/20/07;1
+Testimony
+Box H:
+12/19/07Q
+Green file folder with Grand Jury Subpoena Log - Operation Stolen Globe
+] letter with post it - to be produced after stay is lifted
+Op Stolen Globe (redwell)
+4/29/2008 Grand Jury Presentation for Operation Leap Year with Indictment
+cd
+Jane Does |. U.S. Bates Nos 000670-002110 cd
+Jane Does I. U.S. 0001-1652 cd
+Orange Composition notebook with
+notes
+Redwell with documents provided to
+on cd (000670-002110)
+Redwell with correspondence between Epstein's attorney's and USAO
+10/21/2009 letter to
+from
+12/9/2009
+ILtr re
+• Complaints (green file folder)
+Epstein redwell with correspondence
+Printout of
+s arrest
+Yellow Notepad with |
+•notes
+Enforcing Victim's Rights - April 26, 2012
+Index of Victim Notification Letters
+
+
+CD - 3 calls Alfredo Rodriguez and FBI UCE 10.29.09
+CD - Call Alfredo Rodriguez and CW
+10.28.09
+CD - Call Alfredo Rodriguez and FBI UCE 11.2.09
+CD - Call Alfredo Rodriguez and FBI UCE 11.3.09
+CD - Meet Alfredo Rodriguez and FBI UCE Audio 11.3.09
+CD - Meet Alfredo Rodriguez and FBI UCE Audio and Video 11.3.09
+Box I:
+White binder with Victim information
+Witness/Victim Names Contact List (green file folder)
+Flight Manifests (file folder)
+Recent Atty Notes (file folder)
+(file folder)
+Summary of Sexual Activity (file folder)
+White binder with Victim information -
+| (19), Past Employees -
+(15),
+• (16),/
+(17),
+(18),
+, Misc Witnesses -
+Flight Manifests
+1(2),
+White Binder with Victim Information -
+I (5), L
+• (6),
+17,1
+White binder with victim call records
+LL (1),
+• (8)
+(3)L
+1(4), M
+Box J:
+Redwell with no label - contains (front section) Email titled Fw: Epstein Letter; 5/15/2008 letter tol
+from
+handwritten list of victims; 2 copies of Privilege Log; (middle section)
+copies of privileged documents
+Jane Doe (redwell) - contains green file folder with Sealed Document Tracking Form with Government's
+Sealed Ex Parte Motion for Modification; Order and Motion to Seal Motion to Disclose Grand Jury
+Information; Sealed Document Tracking Form with Motion to Seal Motion to Dismiss for Lack of Subject
+Matter Jurisdiction; Sealed Order Granting Government's motion for Limited Disclosure of Grand Jury
+Material; Sealed Document Tracking Form with Motion to Seal Motion to Stay Discovery Pending Ruling
+Upon Respondent's Motion to Dismiss; printed stickers with "Privileged Documents Submitted Ex Parte
+By the United States for in Camera Review Pursuant to DE 190"; printed stickers with "Jane Doe #1 &
+
+
+Jane Doe #2 I. United States, 08-80736-CV-Marra/Matthewman; DE 216 and DE 219 - Notice of Filing
+Supplemental Privilege Log; Notepad with
+notes; Jane Doe No. 1 and Jane Doe No. 2's
+Appellee Brief (red cover); Florida Law Review from Daily Business Review Thursday, August 29, 2013;
+Printout of Opinion from In Re: Stake Center Locating, Inc.; DE 224; DE 225; DE 226; DE 230; email from
+to
+Tand Ed I
+I Draft Respondent's Opposition to Petitioner's Motion to Compel
+Production of Documents that are not Privileged; printout of brief regardingl
+Westlaw printouts
+Redwell with
+emails from 2007-2008
+Box K:
+FBI Palm Beach County RA, Jeffrey E. Epstein, 31E-MM White binder with PBPD Reports
+Palm Beach Police/SAO Records Redwell with post it that says "This whole stack is for opposing counsel"
+- includes file folders Req for
+1 ; Probably Cause Aff.; Req for Epstein |
+; Request for
+7; Incident Report; State Indictment
+Work Release Notification (green file folder)
+12/11/08 Ltr to PBSO re work release (
+file folder)
+6/12/09 Breach Ltr
+file folder) - post it says Epstein Defense 3 (Kelly)
+7/29/11 Letter to l
+from l
+| regarding NPA being a confidential document
+Notice of Removal (DE#1) in 08-CV-8084-KAM Jane Doe case
+Redwell with Epstein's Motion to Seal Non-Pros Agreement
+Epstein New York Case (Redwell)
+12/10/10, 3/1/11, and 9/29/11 letters from
+CD - Finished Work
+tol
+Box L:
+Redwell with
+• Notes and Jeffrey Epstein deposition documents and cds
+Redwell with Breach Memo documents and documents filed by
+Final Contact (file folder) with Non Prosecution Agreement
+•. & . Civil Complaints (green file folder)
+White binder with Westlaw cases
+CD - Epstein Files to FBI 3.8.2011 provided by [
+CD - I. Epstein Depo of Jeffrey Epstein 2.17.2010 provided by [
+(part 1)
+
+
+CD - . I. Epstein Depo of Jeffrey Epstein 2.17.2010 provided by •
+| (part 2)
+Box M:
+Redwell - Stolen Globe folder with draft indictment and documents from case; copies of phone number
+lists; copies of case law; green folder with attorney notes
+Operation Leap Year composition book with notes
+Yellow Interoffice envelope with image of 2 naked girls
+02/14/02 - 03/07/02 2"d 30 days binder with tabs for individual women
+Redwell titled Indictment Packet Prep Materials - folders for victim list, key documents, attorney notes,
+and drafts
+Binder with Child Molesters: a Behavioral Analysis
+File folder: FBI L
+. Log
+File folder no name - includes September 17, 2009 letter to CL
+from
+(handwritten notes)
+File folder: Responses to Arguments from JE counsel
+File folder: Overt Act Lists
+File folder: Breach Memo
+File folder: 6/12/09 Victim Notif Log
+File folder: 6/9/09 Signed Indictment Pkg
+Binder - Motion to Quash Riley Subpoenas
+Redwell - (victims) Additional 3025
+Redwell - originals from 12/12/07 Indictment package
+1 Plea Agreement
+CD - Epstein Address Book
+Box N:
+Epstein - Docs provided by
+(redwell)
+Certified Copy of State of Florida |. Jeffrey Epstein Plea Conference transcript
+Correspondence: 6/27/2008 letter from |
+to
+and
+regarding not receiving copy
+of proposed plea agreement; Palm Beach Post printout 9/4/2009 "Appeals court backs unsealing of
+
+
+Epstein's 07 deal with feds"; 6/27/2008 letter from •
+Itol
+agreement does not comply with the NPA; 7/17/2008 letter tol
+and regarding the plea
+from
+Grand Jury Log Vol. 2
+Redwell - State Court Criminal Pleadings; State Motion to Unseal NPA; Supplemental Appendix to Palm
+Beach Newspapers, Inc. Response to Emergency Petition for Writ of Certiorari
+Redwell with Post DC Correspondence, Epstein Attorney's Fees Correspondence
+Redwell with Correspondence with Victims
+Correspondence
+Box O:
+White Binder - Operation Leap Year Response to Motion to Quash Research
+CDs: 4/24/2007
+with
+Interview; PBPD U6-1078 Interview with
+Cassette tapes: Interview with
+; PBPD Conversation with
+#2; PBPD Voicemail from
+; PBPD Statement of
+call with
+VHS: PBPD Interview of
+Interview w/
+Private Island Helicopter
+; Interview w
+: Interview w/
+; Interview w
+: Statement of
+Box of Cassette tapes: Statement of
+; Statement of
+; Voicemail message C work; Statement of
+Box of cassette tapes: Statement of |
+1; Control call
+&
+Statement of
+case
+- drive to station; Statement of
+; Statement of
+_: Statement of
+: PBPD 061078 Interview
+c; PBPD Voicemail
+1: PBPD Follow-up phone
+&
+1; Statement of
+, Saise; Conversation of
+]; Phone call w/|
+; empty
+Box P:
+Settlement Negotiations & Settlement Statements (
+| redwell) including 5/16/2016 Settlement
+Conference Summary letter to Honorable Dave
+Brannon from
+; Confidential Memorandum
+on Behalf of Jane Doe No. 1 and Jane Doe No. 2 Regarding Mediation; printout of docket for 08-CV-
+80736; printout of Crime Victims' Services for Attorney General Pam Bondi
+Empty file folder SORNA and Victims' Services Info
+Clean Copies of Agreement without App D & E (file folder)
+
+
+Relevant Privileged Docs (] redwell) - 2 copies clipped with Bates Numbers P-003713-P-003746; P-
+008516; P-009105-P-009111; P-012624-P-012642; P-012646; P-014011-P-014025; P-014059-P-014061;
+P-014440; P-014444; P-014521-P-014522; P-014559-P-014562; P-014569-P-014573; P-014666-P-
+014693; P-014712-P-014716; P-014866-P-014883
+Privilege Logs ( redwell) - all privilege logs clipped together
+Jane Does Intervenors at Mediation (file folder) - includes notes and Westlaw printouts
+Victim List (file folder) - includes 7/10/2008 Final Notification of Identified Victims
+Victim List (file folder) - includes 7/5/2016 letter to Wells Fargo, 6/16/2016 email from |
+1, and 7/10/2008 Notification of Identified Victims to |
+to
+] Declarations (file folder) - includes 3 printouts of Declaration of A. Q
+in Suppport
+of United States' Response to Victim's Emergency Petition for Enforcement of Crime Victim Rights Act,
+18 U.S.C. 3771
+Yellow envelope from
+to
+I with Jane Doe #1 and Jane Doe #2's Supplemental
+Request for Production to the Government Regarding "Victim" Status
+Jane Doe case (Redwell) - includes Draft letters and settlement agreements, Jane Doe Mediation (file
+folder), and Jane Does Settlement Agreement and Apology Letter (file folder)
+Jane Doe Document Production (redwell) - includes 3 cds, and documents
+Order Closing Case & Timeline (file folder)
+Jane Does - Writ Ad Test (file fodler) includes Westlaw printout of U.S. I. Louis Rinchack
+Box Q:
+6/2/2017 L
+Declaration (
+]redwell)
+Second Declaration off
+• (file folder)
+Jane Doe I. U.S. Summary Judgment prep (|
+(redwell) - light green file folder with
+notes,
+bright green file folder with notes and documents, and rubber-banded exhibits
+Motion to Disclose Grand Jury Material (L
+]redwell) - with Copy of Motion, light green file folder
+with signed sealed Orders, and light green file folder with Exhibits to Motion to Unseal Grand Jury
+Materials
+White binder with Jane Doe 1 and Jane Doe 2's Consolidated Statement of Undisputed Material Facts
+and Motion for Partial Summary Judgment with Incorporated Memorandum of Law
+Box R:
+• re Subpoenas (file folder)
+
+
+File folders for individual subpoenas: -01 through •
+-81
+Ritz Compact Flash SW (file folder)
+PNY Technologies Compact Flash SW (flash drive)
+JE Corporations (green file folder)
+Capital One (green file folder)
+DTG Operations/Dollar Rent-a-Car (green file folder)
+JP Morgan Chase (green file folder)
+Washington Mutual (green file folder)
+Redwell with folders - Computer Search; Attorney Notes from Doc Review; Notes from FedEx Records
+Colonial Bank Records (redwell) with folders: JEGE, Inc.; NES, LLC
+Epstein Corporate Records
+-51,
+-SZ,
+1-53, |
+7-54 (red folder)
+Colonial Bank (green file folder)
+JEGE & Hyperion from |
+-46 & 47 (file folder)
+Box S:
+Research re JE websites (file folder)
+Victim Civil Suits (file folder)
+(NY AUSA) - (file folder)
+(file folder)
+Interview (file folder)
+Research re Travel for Prostitution (file folder)
+Transcript (empty file folder)
+I (green file folder)
+PBPD Investigative File (redwell)
+(redwell)
+FedEx (file folder) subpoena response with Certification
+Documents 53909-004 (green file folder)
+State of Delaware records (file folder)
+Jet Blue records (file folder)
+
+
+FL Employment Recs (file folder)
+(green file folder)
+Records (green file folder)
+(file folder)
+Bear Sterns Research (file folder)
+Lawsuits involving Epstein Corps (file folder)
+New York Trip (file folder)
+(green file folder)
+SEC records (green file folder)
+Message Pads (file folder)
+] (green file folder)
+Redwell with
+file folder)
+Statement (file folder),
+1 (green file folder) and Info Re Planes (green
+Police Reports & PC Affidavit (file folder)
+| Subpoena Response (file folder)
+Transcript of Interview and GJ Transcript (file folder)
+2006R01181 Operation Leap Year Criminal Complaint folder with Expert Witness Forms (green file
+folder) and asset forfeiture folder
+Extra Copies (green file folder)
+Box T: (labeled Legal Research)
+Epstein Redwell - folders titled: 1591 & Money Laundering; 18 USC 2425; Knowledge of Age; 2423(b)
+Constitutionality and Purpose of Travel; Immunity; Mistake not a defense; Research re "pandering";
+Research re Grand Jury Instructions; Telephone=Facility of Commerce; Def of Prostitution; Research re
+Crime Victims Rights; Relevant Florida Statutes; Unit of Prosecution Research
+Research re Grand Jury Transcript (file folder)
+18 USC 2255 (file folder)
+Research re Grand Jury Transcript (file folder)
+Original proposed Ind (file folder) - includes original indictment
+Research re Overt Acts and Witness Testimony (green file folder)
+
+
+Extradition (green file folder)
+Corporate Liability Research (green file folder)
+Research re Knowledge of Age Unnecessary (file folder)
+1960 & Aiding/Abetting (green file folder)
+Money Laundering (green file folder)
+Attorney General Guidelines for Victim and Witness Assistance May 2005
+Purpose of Travel Cases (green file folder)
+Redwell with folders titled: Interstate Commerce Cases; Attorney Conflict Research; Mann Act/Travel to
+Have Sex with a Minor; Travel Act; Florida Prostitution/Lewdness Statutes
+Box U:
+Folder with
+notes
+| subpoena (green file folder)
+Research re State Incarc (redwell) with Epstein's Motion to Return Property (file folder) and State
+Docket Sheets (file folder)
+Redwell with CD with nothing written on it (contains videos) and cd; Notes and Westlaw printouts
+Leap Year Filing (redwell)
+JE Work Release (file folder)
+Protective Order Samples (green file folder)
+Letter to FBI
+Research Victim and Articles
+Press Coverage re Work Release (green file folder)
+FOIA Requests (redwell) with Lewis-
+Demanding Case File folder
+Docs from Civil Suits (file folder)
+I FOIA Request to FBI folder and
+SARS (file folder)
+Signed Protective Orders (file folder)
+Re Ethics Issue (file folder)
+Signed Protective Order (green file folder)
+Notice of Withdrawal of Motion to Quash (green file folder)
+Ltr to FBI
+
+
+Epstein press coverage; Research re Florida Procurement and Sentencing Guidelines; Operation Leap
+Year Revised Indictment Summary Chart (by Victim)
+Research re FL DOC Regs (file folder)
+Research re BOP Regs (file folder)
+Supervised Release Rules (green file folder)
+GJ Transcripts redwell with
+Transcript 5/22/07; L
+Transcript 3/20/07; •
+Transcript 3/18/08
+Transcript 5/15/07; •
+Redwell with Newspaper Articles and Press Coverage
+Box: (labeled Phone Records)
+Redwell with phone records for
+#4, Jane Doe #12
+Redwell Corrected Phone Records 5/13/07
+• (victim 5),
+phone records (file folder)
+Lists of Identified Phone Numbers (file folder)
+Redwell with Master Phone Records
+Redwell with Epstein/
+Phone Records
+(Victim 14),
+(Victim 9), Jane Doe
+Box W:
+Redwell with 8/3/2015 Doc Production Jane Doe I. U.S.
+Relevant Jane Doe I. U.S. Items (Redwell) - Reinhart review (file folder), Attorney General Guidelines for
+Victim and Witness Assistance May 2005, United States of America's Response to Petitioners' Request
+for Production, Items marked as removed as non-responsive
+12-7-2007 draft Crime Victims' Rights - Notification of Resolution of Epstein Investigation with
+envelopes (redwell)
+Redwell with Items Produced to
+7/19/2013 and cd copies (1 for
+land 1 for Judge)
+Redwell with Joint Statement of Undisputed Facts, Stipulation, and Intervenors' Motion for a Protective
+Confidentiality Order and Incorporated Memorandum of Law
+binder with Doe case documents
+CDs: 2"d supplemental privilege log P-013970 thru P-014923; Epstein-•
+: Items from Supp Priv Log
+filed 7.26.13 P-013279 thru P-013969;| pictures and summaries; Lit Hold; Lit Hold PST; [
+Sealed yellow envelope to
+and A.
+from
+
+
+Redwell with Already Produced documents
+2 yellow Note pads with M
+notes
+Redwell with
+• Copies of Victim Notification Letters
+Blue folder with Intervenor documents
+CD from redwell with 8/3/15 Doc Production Jane Doe I. US labeled: Jane Doe #1 and Jane Doe #2 |. US
+08-80736-cv-Marra Items from 30 Suppl Priv Log P-014924 thru P-015267, 8.3.15
+CDs from /
+Binder with Doe Case Documents labeled: Jane Doe #1 and Jane Doe #2 I. US 08-80736-
+cv-Marra Items from Suppl Priv Log Filed 7.26.13; Jane Doe #1 and Jane Doe #2 I. USA, 08-80736-cv-
+KAM Privileged Docs 7.19.2013; Jane Doe I. Us 08-80736-cv-Marra Items from 2nd Suppl Priv Log Filed
+6.23.15
+Box X:
+West's Florida Statutes Annotated Sections 934.08 to 944.29 Book
+White binder with tax returns
+Epstein State Court File (redwell) with PBSO Inmate Rules and Work Release Regulations
+PTD Research (redwell)
+Supreme Court case The Florida Bar vs.
+Box Y:
+Box (unlabeled by #): -
+found when she was packing to leave
+6(e) application and Order Sealed in Red Interoffice envelope
+Attorney General Guidelines for Victim and Witness Assistance 2000 Book
+11 additional books re statutes and victims with notes
+Box Z: OPR Prep Box 1
+4-29-08 Grand Jury Presentation package
+5-15-08 Oosterbaan
+letter
+5-27-08|
+submission to DAG
+6-19-08
+submission to DAG
+6-24-08
+email to
+7-09-08 Victim Notification letters
+
+
+8-15-08
+Lemail re agreement
+9-17-08 Letter to
+11-24-08 Letter to
+re Breach
+Breach memo
+Doe Il. Epstein Motion Transcript
+Information
+Meeting Timeline
+Non Prosecution Agreement
+• GJ Log Volume 2
+OPR Prep Mail & Communication Volume 1
+OPR Prep Mail & Communication Volume 2
+PBSO DOC information
+Plea Agreement
+Victim letters
+Westlaw research
+re PB Daily News
+Box AA: OPR Prep Box 2
+6-25-08 Victim Notification
+6-27-08 Letter to
+and
+7-22-081
+email
+8-05-08
+Lemail re correct agreement
+9-17-09 Letter to
+Emails
+Red folder
+Redacted Three document agreement
+Timeline summary with draft responses to OPR
+Westlaw Florida Statute - Prostitution
+
+
+Box BB: OPR Prep Box 3
+OPR Response Exhibits
+1-23-07 |
+to
+2-5-07|
+to
+2-23-07
+to
+3-18-08
+letter
+letter
+|letter
+| GJ Testimony Transcript
+6-3-08|
+letter to DAG
+6-25-08 Victim Notification letters
+6-27-08 Letter to and |
+7-22-08
+email
+8-05-08
+email re correct agreement
+9-17-09 Letter to
+10-25-07|
+letter to
+11-8-07|
+letter to l
+11-13-07|
+letter to
+11-28-07|
+letter to Attorney General
+11-28-07 | letter to
+11-30-07|
+letter to
+12-4-07
+letter to
+12-5-07|
+letter to
+12-6-07
+letter to
+12-7-07
+letter to
+12-7-07
+letter to
+12-11-07
+|letter to M
+12-21-07|
+12-26-07|
+letter to L
+| letter to
+2007 FL Statute 921
+BOP Designations
+Box notes
+
+
+Crime Victim Rights
+Duplicate victim letters
+Emails re plea negotiations
+Emails
+Internal correspondence
+Key Correspondence
+Money Laundering
+Post NPA Timeline
+Red folder
+Redacted Three document agreement
+Subpoena |
+-24
+Timeline summary
+Victim Notification Index
+Westlaw FL Statute Prostitution
+Westlaw Grady I. FL
+Westlaw Kobel I. FL
+Westlaw McCann I. FL
+Westlaw Petty I. FL
+Box CC: White Box 1
+Redwell with Misc Notes (green folder), Yellow notepad with notes, Case Docket with Westlaw cases
+Redwell with Victims' Rights Suit with Suppl L
+| Decl Original folder, Filed-Stamped Response and
+Declaration folder, Possible Exhibits for
+Decl Folder, Internal
+Ire Suit folder
+Red folder Jane Does I. United States 08-80736-CIV-MARRA
+Redwell with
+re Victims' Rights Suit with
+I Signed Protective Order folder, Non Prosecution
+Argreement folder, Addendum to Non-Pros Agrmt folder, 8/1/08 D
+| Ltr to folder, 8/15/08
+e-mail to
+folder, 9/3/08
+Itr to
+folder
+Folder with Victims' Rights Action documents
+Redwell with
+with 9/3/08
+Ltr to
+| folder, CVs from
+folder,
+I folder, 9/15/08
+Signed Protective Orders folder
+Ltr to
+
+
+Box DD: White Box 2
+Redwell Final Agreements with Agrmts Filed in State Court folder, 12/19/07 •
+Ltr folder
+Loose Papers: Flight Manifest, 11/26/08 email C
+_ 7/3/08 email
+to
+, 12/6/07 Letter
+to
+• 12/6/07 Draft Victim Notification Letter, 12.6.07 two Fax
+Cover Sheets, 6/25/07 Letter
+to
+and
+1. Handwritten Notes
+Most recent Indictments & Good Cases folder
+FBI Summary Charts folder
+Folder with Revised Indictment Summary Chart, Indictment, Subpoena Response Chart, and Flight
+Manifest
+Red Folder Grand Jury Log 01 Through-50
+Redwell with Yellow Notepad, GJ Presentation Outline, Indictment Packet, and Victim List
+_ Immunity Request folder
+Redwell with
+1./Jane Doe #4 folder,
+/Jane Doe #7 folder, L
+Green folder Certified Copy of State Case File
+./Jane Doe #5 folder, L
+1./Jane Doe #8 folder
+1./Jane Doe #6 folder,
+Meeting Timeline folder
+Redwell with
+folder,
+Redwell with
+/Jane Doe #9 folder,
+folder,
+/Jane Doe #1 folder,
+/Jane Doe #13 folder,
+folder
+/Jane Doe #2 folder, I
+L/Jane Doe #12
+1./Jane Doe #3 folder
diff --git a/vision-fixhub/ds9-unparsed-05/ed4e24cf15f8180b38fa5b84f39115bee8b8b494dbf6011481b4d6b63ec8b93b.receipt.json b/vision-fixhub/ds9-unparsed-05/ed4e24cf15f8180b38fa5b84f39115bee8b8b494dbf6011481b4d6b63ec8b93b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..aca23a56c58e015046f4640917d1f3746eef251b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ed4e24cf15f8180b38fa5b84f39115bee8b8b494dbf6011481b4d6b63ec8b93b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -216,
+  "dataset": "marble-joined",
+  "doc_id": "ed4e24cf15f8180b38fa5b84f39115bee8b8b494dbf6011481b4d6b63ec8b93b",
+  "engine": "marble-apple-vision",
+  "event_count": 18,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "7bc6db5e906da2193e7243aa6abe4532f23709edd3cc260edc2b5cd1ae2f7973",
+  "output_sha256": "971208bd7ad5608fc35ae0e4e6a0a44ffeb25d8ac4718bc7cbd159bf02c74190",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/edec8509d06f27d7fd356c3b5c470d8a84c4d7e9d3cd1743c06691f13d639e5a.md b/vision-fixhub/ds9-unparsed-05/edec8509d06f27d7fd356c3b5c470d8a84c4d7e9d3cd1743c06691f13d639e5a.md
new file mode 100644
index 0000000000000000000000000000000000000000..59bfdeef0e16c9d6ef1d356b00777588894490e2
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/edec8509d06f27d7fd356c3b5c470d8a84c4d7e9d3cd1743c06691f13d639e5a.md
@@ -0,0 +1,93 @@
+
+PALM BEACH RESIDENT FACES
+SOLICITATION CHARGE
+By Chrystian Tejedor Staff WriterStaff Researcher Barbara Hijek contributed to this report
+SOUTH FLORIDA SUN-SENTINEL
+JULY 26, 2006
+A weathe ilm to inch regalent charged with soliciting prostitutin is out s jail, but police now
+want the FBI to investigate him.
+"I do not feel that justice has been sufficiently served by the indictment that has been issued," Palm
+Beach Police Chief
+wrote to the parents of one alleged victim.
+Police accused Jeffrey Epstein, a self-made man who works as a money manager and owns a fleet of
+aireraft, of fondling and -- in one case -- having sex with underage girls whom he paid for massages.
+At the end of a 13-month investigation, detectives recommended that Epstein, 53, be charged with
+four counts of committing an unlawful sex act on a minor and one count of lewd and lascivious
+molestation.
+Epstein's attorney, however, said the grand jury acted responsibly when it set aside the department's
+recommendations.
+"Those charges refer to false accusations that were not charged because the state attorney questioned
+[witness testimony]," Jack Goldberger said.
+Goldberger also said police failed to turn up corroborating evidence and Epstein passed a lie detector
+test regarding the accusations.
+The case centers on interviews with the girls who were 14 to 16 years old at the time they came to
+"work" for Epstein, according to a police report.
+Epstein, who turned himself in at the Palm Beach County Jail Sunday, allegedly paid the girls $200 to
+$1,000, depending on the type of sexual activity they performed, according to police. A recruiter -- a
+girl who is now 20 years old and would find girls from her school --would earn $200 for each girl she
+would find.
+$1 FOR 4 MONTHS
+Hurry, this sale ends 5/1
+SAVE NOW ›
+http://www.sun-sentinel.com/news/fl-xpm-2006-07-26-0607260021-storv.html
+
+4/22/2019
+
+
+
+"The more you do, the more you get paid," the recruiter told one girl during a call that was taped by
+police.
+Generally, Epstein's assistant would tell the recruiter when Epstein would be in town and the
+recruiter would drive a girl to Epstein's five-bedroom, 71/2 bath home on El Brillo Way, according to
+a police report. The home is valued at $6.9 million, property records show.
+Epstein's assistant would then escort the girl to a bedroom with a massage table and oils. Epstein
+would walk in wearing only a towel and would ask the girl to give him a back and chest massage,
+according to police.
+Epstein would touch himself during some massages and would try to fondle the girls with sex toys,
+police said
+In one case, investigators interviewed a girl who was arrested on a misdemeanor charge of marijuana
+possession and offered details of her experience at Epstein's home.
+As in the other cases, her encounter started at age 16 when the recruiter brought her to Epstein's
+home, she told police. Things escalated over time and she told authorities that she became Epstein's
+"number one girl."
+The girl told police Epstein paid her to have sex with a woman and would then perform a sex act on
+them. One time, Epstein briefly had sex with the girl although they previously agreed to not have sex,
+according to police.
+When searching Epstein's home, investigators also found nude pictures of what appeared to be some
+of the alleged victims, according to a police report. Police also scoured his garbage, finding the names
+of potential witnesses and victims on discarded messages.
+Despite witness testimony, the grand jury charged Epstein only with soliciting prostitution, which
+upset
+the Palm Beach police chief.
+While police were disappointed with that decision, the State Attorney's Office said police could have
+bypassed the grand jury by arresting Epstein based on the evidence detectives collected.
+"They elected to make a warrant request ... and the State Attorney's Office then has to meet a
+constitutional standard of proof above and beyond a reasonable doubt," said
+spokesman for the State Attorney's Office.
+$1 FOR 4 MONTHS
+SAVE NOW›
+Hurry, this sale ends 5/1
+a
+httm://www.cun_centinel com/news/fl-xnm-2006-07-26-0607260021-storv.html
+4/22/2019
+
+
+
+said information is routinely forwarded to a grand jury if there are questions about
+which charges should be filed.
+Epstein, according to a Vanity Fair magazine profile, manages money for billionaire clients. He has
+yet to file a plea, but was freed after posting $3,000 bond early Monday.
+Staff Researcher Barbara Hijek contributed to this report.
+Chrystian Tejedor can be reached at / | |
+Copyright © 2019, Sun Sentinel
+This 'attr(data-c-typename) is related to: Prostitution, Crime, FBI
+$1 FOR 4 MONTHS
+Hurry, this sale ends 5/1
+SAVE NOW›
+Lie/looner man continal com/nowe/vam_0006_07_96 0607060001-etorv html
+4/72/2019
+
+
+
+nontinal aom/nowe/f_vam_000k_07_96_0607960001-ctorv html
+4/22/2.019
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/edec8509d06f27d7fd356c3b5c470d8a84c4d7e9d3cd1743c06691f13d639e5a.receipt.json b/vision-fixhub/ds9-unparsed-05/edec8509d06f27d7fd356c3b5c470d8a84c4d7e9d3cd1743c06691f13d639e5a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..26e7def4eec24002283d19584bd36e8654f7be51
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/edec8509d06f27d7fd356c3b5c470d8a84c4d7e9d3cd1743c06691f13d639e5a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -346,
+  "dataset": "marble-joined",
+  "doc_id": "edec8509d06f27d7fd356c3b5c470d8a84c4d7e9d3cd1743c06691f13d639e5a",
+  "engine": "marble-apple-vision",
+  "event_count": 10,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "9b054eb81682022b03b68e85f8aa782c22d4a55d54f87cde8c694493654371f8",
+  "output_sha256": "c8843dd19c670f46a1a0d805211338ec111e926a6c7783c12664d0ae1674c4ec",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/edefcd5eccc7feb04c3cb07fb63264517bac691a46c18077b43802f9f4d674a2.md b/vision-fixhub/ds9-unparsed-05/edefcd5eccc7feb04c3cb07fb63264517bac691a46c18077b43802f9f4d674a2.md
new file mode 100644
index 0000000000000000000000000000000000000000..a18e47c54685b7a4aa5341e9702bc68fc1a7bf41
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/edefcd5eccc7feb04c3cb07fb63264517bac691a46c18077b43802f9f4d674a2.md
@@ -0,0 +1,1702 @@
+Statements
+
+
+Bear,Stearns International LTD
+Regulated by the Security &
+Futures Autonty
+120r sie balD England
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31,2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Avallable
+November 30, 2001
+4
+4
+Hollandlmld
+C/O AMERICAN YACHT HARBOR
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+23,375,000
+8,103
+$23,383,103
+10,479,583
+12,903,520
+Th sel arpen sles onesi for ys or other ponding buy
+Cash & Equivalent
+Equities -
+Market Value of Your Portfolio
+$8.103
+$0
+$10,479,583
+$23,375,000
+Important Message
+If any information regarding
+2001 interest, dividends,
+miscellaneous income
+gross proceeds or original
+sue discount is require
+be reported to the IRS f
+Current market value
+Last statement's market value
+Da March 15,2022 10425
+STP Thie urener s foul er ratanel ftr yer rebr de Set revere date tra postame itformatin.
+01/03/02;11:25 001
+
+
+027
+01/03/02;11:25 001|
+
+
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance,
+Bear, Stearns International LTD
+Riles Aubrite Security &
+1 Canada Square
+ondon E14 SAD England
+1207 516 661-
+THIS PERICO
+310.479.583.05
+8,102.63
+544,389.04
+$552,491.67
+......
+-11,023,972.09
+....
+t-11,023,972.09
+.. . .
+-10,471,480.42
+68.102.6
+Income Summary
+Dividends
+Credit Balance Int.
+THIS PERIOD
+0.00
+8,102.63
+$8.102.63
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total.
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+10,187,388.53
+292,194.52
+$10,479,583.05
+CLOSING
+8,102.63
+0.00
+.......
+58.10263
+027
+YEAR TO DATE
+232,000.00
+82,760.43
+$314,760.43
+8,103
+23,375,000
+3,383,10
+01/03/02;11:25 001
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Avallable
+November 30, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+<1%
+- Equities
+99%
+Unshaded portions denote debit balance and or shart
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+DESCRIPTION
+TOO INC
+Total Equities& Options
+TOTAL EQUITIES
+YOUR PRICED PORTFOLIOHOLDINGS
+Bear, Stearns International LTD
+legulated by the Security,
+utures Authorit
+1 Canada Square
+ondon E14 SAD Englan
+207 516 661
+SIMBOUCUSIP
+QUANTITY
+PRICE
+SYMBCUCUSIP
+TOO
+CASH
+QUANTITY
+850,000
+Transaction Detail
+INVESTMENT ACTIVITY
+SALEMENT TAE
+12/18/01
+TRANSACTION
+JOURNAL
+DESCRIPTION
+TOO INC
+FROM I
+SAME
+MINE ACTED
+CURREN
+ELD I
+8,103
+$8,103
+PRICE
+27.5000
+MARKET
+VALUE
+23,375,000
+$23,375,000
+$23,375,000
+$23,383,102
+ANNUAL NOME
+$0
+$0
+SYMBOLUSP
+TOO
+QUANTITY
+1,000,000
+PRICE
+027
+01/03/02;11:25 001
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31,2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+November 30,2001
+DEBIT AMOUNT
+CREDIT AMOUNT
+
+
+5 or 5
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SEEMENT TREE
+12/21/01
+12/2601
+TRANSACTION
+JOURNAL
+JOURNAL
+TOTAL
+INTEREST
+DATE
+12/20/01
+DESCRIPTION
+INTEREST ON CREDIT BALANCE
+5007.47:20 9852894219N
+TOTAL
+MISCELLANEOUS
+DATE
+MODAY
+12/04/01
+1205/01
+12/06/01
+i206/01
+12/06/01
+TOTAL
+TAANSACTION
+JOURNAL
+JOURNAL'
+¡OUANAL"
+JOURNAL"
+JOURNAL
+DESCRIPTION
+COL DEL LOA INTO
+TXPR BET TYPE TYPEZ
+**XER BET TYPETTYPEZ
+TXER BETTYPE/TYPE2
+REVERSE 12/5 JRNL
+Bear, Stearns International LTD
+gulated by the Security
+tures Authori
+1 Canada Square
+ondon E14 SAD England
+1207 516 661-
+DESCRIPTION
+TOO INC
+JAL TO 038
+.... .
+TOO ING
+JAL TO
+PER INTX'S
+SYMBOUCUSIP
+SYMBOLGUSIP
+TOO
+TOO
+QUANTITY
+RATE (SI
+DEBIT AMOUNT
+10,479,583.05
+'252,194.52
+292,194.52
+$-11,023,972.09
+027
+QUANTITY
+-100,000
+50,000
+PRICE
+DEBIT AMOUNT
+CREDIT AMOUNT
+292,194.52
+252, 194.52
+$544,389.04
+01/03/02;11:25 001
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+November 30, 2001
+DEBIT AMOUNT
+CREDIT AMOUNT
+CREDIT AMOUNT
+8,102.63
+$8,102.63
+VB19
+
+
+Bear,Stearns International LTD
+Regulated by the Security &
+Futures Authorty
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+STATEMENT PERIOD October 27,2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Avallable
+October 26,2001
+3
+4
+4
+Hollandlold
+C/O AMERICAN YACHT HARBOR
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+10,479,583
+$10,479,583
+10,503,156
+-23.572
+Cash & Equivalent
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$10,479.583
+$10,503,156
+Current market value
+Last statement's market value
+This summary is for informational purposes only. It is not intended as a tax documen
+PC This statement should be retained for poser records. See reverse side for important information
+12/01/01:13:55 001
+
+
+027
+12/01/01:13:55 001|
+
+
+Bear, Stearns International LTD
+gulated by the Security
+tures Authori
+1 Canada Square
+ondon E14 SAD Englan
+1207 516 661-
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+310.503.155.54
+19,305.04
+19,305.04
+-42,877.53
+542.877.52
+... .
+-23,572.49
+$10,479.583.05
+Income Summary
+Dividends
+Credit Balance Int.
+THIS PERIOD
+0.00
+19,305.04
+$19,305.04
+Portfolio Composition
+Cash/Cash Equivalent
+Tota
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+10,210,961.02
+292,194.52
+CLOSING
+10,187,388.53
+292,194.52
+.............
+$10,503,155.54
+$10,479,583.05
+027
+YEAR TO DATE
+232,000.00
+74,657.80
+•********-..
+5306.657.80
+10,479,583
+.$10.479.583
+12/01/01:13:55001
+STATEMENT PERIOD October 27, 2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Available
+October 26,2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+Bear, Stearns International LTD
+Reques ly he Security is
+ondon E14 SAD Englanc
+1207 516 661-
+SIMBOUCUSIP
+QUANTITY
+PRICE
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INTEREST
+DATE
+11/20/01
+TOTAL
+DESCRUPTION
+INTEREST ON CREDIT BALANCE
+500 TEY822 98208944,
+SYMBOUCUSIP
+10,479,583
+$10,479,583
+$10,479,583
+QUANTITY
+RATE (%)
+027
+STATEMENT PERIOD October 27, 2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+October 26,2001
+DEBIT AMOUNT
+CREDIT AMOUNT
+19,305.04
+$19,305.04
+12/01/01;13:55 001
+
+
+5 of5
+Bear, Stearns International LTD
+1 Canada Square
+ondon E14 SAD Englan
+207 516 661
+Transaction Detail (continued)
+MISCELLANEOUS
+DATE
+MO/DAY
+11/09/01
+TRANSACTION
+JOURNAL
+DESCRIPTION
+BSIL VSFINANCIAL TRUST CO.,T
+NY13763 EQUITY SWAP
+DUE 01/24/02
+DEBIT AMOUNT
+42,877.53
+CRECIT AMOUNT
+TOTAL
+$-42,877.53
+STOP
+****** End of Statement******
+027
+12/01/01;13:55 001
+STATEMENT PERIOD October 27,2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Avallable
+October 26,2001
+
+
+Bear,Stearns International LTD
+Regulated by the Security &
+Futures Authorty
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ................................
+Your Portfolio Holdings
+Transaction Detail
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Available
+September 28, 2001
+3
+4
+4
+Hollandlold
+C/O AMERICAN YACHT HARBOR
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+10,503,156
+$10,503,156
+10,531,649
+-28,494
+Cash & Equivalent
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$10,503.156
+$10,531,649
+Current market value
+Last statement's market value
+This summary is for informational purposes only. It Is not intended as a tax documen
+PC This statement should be retained for poser records. See reverse side for important information
+10/27/01:11:27 001
+
+
+2 of 4
+027
+10/27/01:11:27 001
+
+
+3 or a
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Dividends/Interest Charged
+Amount Debited.
+Net Cash Activity
+Closing Balance
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stearns International LTD
+gulated by the Security
+tures Authori
+1 Canada Square
+ondon E14 SAD Englan
+1207 516 661-
+THIS PERICO
+510,531.649.32
+24,382.33
+$24,382.33
+-52,876.11
+-52,876.1
+... ...
+-28,493.78
+$10.503.155.54
+Income Summary
+Dividends
+Credit Balance Int.
+THIS PERIOD
+0.00
+24,382.33
+$24.382.33
+Portfolio Composition
+Cash/Cash Equivalent
+Tota
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OFENING
+10,239,454.80
+292,194.52
+CLOSING
+10,210,961.02
+292,194.52
+......
+$10,531,649.32 $10,503,155.54
+027
+YEAR TO DATE
+232,000.00
+55,352.76
+5287.352.78
+10,503,156
+$10,503, 156
+10/27/01:11:27 001
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+September 28, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+4 of 4
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+Bear, Stearns International LTD
+Reques ly he Security is
+ondon E14 SAD Englanc
+1207 516 661-
+SIMBOUCUSIP
+QUANTITY
+PRICE
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INTEREST
+DATE
+DESCRIPTION
+10/09/01
+BSIL VSFINANCIAL TRUST CO.,T
+1002201INTEREST ON CREDIT BALAN
+TOTAL
+STOP
+*** End of Statement******
+SYMBOL/CUSIP
+•••••••• I
+10,503,156
+$10,503,156
+$10,503,155
+QUANTITY
+RATE (%)
+120
+DEBIT AMOUNT
+52,876.11
+$-52,876.11
+10/27/01:11:27 001
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Avallable
+September 28, 2001
+CAEDIT AMOUNT
+24,382.33
+$24,382.33
+
+
+Bear,Stearns International LTD
+Regulated by the Security &
+Futures Authorty
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Avallable
+August 31,2001
+3
+4
+4
+Hollandlold
+C/O AMERICAN YACHT HARBOR
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+10,531,649
+$10,531,649
+8,970,861
+1,560,789
+Cash & Equivalent
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$10,531,649
+# $8,970.861
+Current market value
+Last statement's market value
+This summary is for informational purposes only. It Is not intended as a tax documen
+PC This statement should be retained for poser records. See reverse side for important information
+
+
+027
+V50O
+
+
+3 of5
+Bear, Stearns International LTD
+gulated by the Security
+tures Authori
+1 Canada Square
+London E14 SAD England
+0207 516 6614
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+58,970.860.71
+20,983.13
+1,660,194.52
+$1,681,177.65
+-60,194.52
+-60,194.52
+... 120389.04
+1,560,788.61
+310.691.649.32
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+8,738,860.71
+232,000.00
+$8,970,860.71
+Income Summary
+Dividends
+Credit Balance Int.
+Total.
+THIS PERIOD
+0.00
+20,983.13
+$20,983.13
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+027
+CLOSING
+10,239,454.80
+292,194.52
+$10,531,649.32
+YEAR TO DATE
+232,000.00
+30,970.43
+$262,970.43
+10,531,649
+aaaaaaaaaaaaaan
+$10.531,649
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Avallable
+August 31, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+from the absolute market value of your portfolio.
+V50O
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+Bear, Stearns International LTD
+Reques ly he Security is
+ondon E14 SAD Englanc
+1207 516 661-
+SIMBOUCUSIP
+QUANTITY
+PRICE
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INTEREST
+DATE
+DESCRIPTION
+09/10/01
+BSIL VSFINANCIAL TRUST CO.,T
+DARE SUITE SWAR
+B2001 INTEREST ONCREDIT BALANCE
+200 TO 20 60 2001-09-19
+TOTAL
+SYMBOL/CUSIP
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Avallable
+August 31,2001
+MARKE
+ALU
+10,531,649
+$10,531,649
+$10,531,649
+NAME NONE FRONT
+QUANTITY
+RATE (%)
+DEBIT AMOUNT
+60,194.52
+CREDIT AMOUNT
+$-60,194.52
+"••••••••••••••••
+0,983.1
+$20.983.13
+120
+V500
+
+
+5 of 5
+Bear, Stearns International LTD
+London E14 SAD England
+Transaction Detail (continued)
+MISCELLANEOUS
+DATE
+MO/DAY
+09/10/01
+09/14/01
+ANSACTI
+URNA
+JOUANAL"
+ESCRIPTIO
+SIL VS FINANCIAL TAUST CO.
+(13763 EQUITY SWI
+DEBIT AMOUNT
+60,194.52
+05/18701 JOURNAL"
+09/19/01
+JOURNAL
+
+JOUANAL"
+V24/
+JOURNAL
+TOTAL
+SAME NAME
+"FROM
+"FROM
+FROM
+SAME
+$-60 194 52
+STOP
+****** End of Statement******
+027
+CRECIT AMOUNT
+60, 194.52
+400,000.00
+400,000.00
+500,000.00
+300,000.00
+$1,660.194.52
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Avallable
+August 31,2001
+V500
+
+
+Bear,Stearns International LTD
+Regulated by the Security &
+Futures Authorty
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+.........
+Transaction Detail
+STATEMENT PERIOD July 28,2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Avallable
+July 27, 2001
+3
+4
+4
+Hollandlold
+C/O AMERICAN YACHT HARBOR
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+8,970,861
+$8,970,861
+16,792,667
+-7,821,806
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$8,970.861
+$1,080.667
+Cash & Equivalent
+Equities
+$0
+$15,712,000
+Current market value
+Last statement's market value
+SP This satement stori for atanal for our red de, ol revere did ora dotan itormation.
+09101/01;13:20 001
+
+
+2 of 6
+027
+09.01/01:13:20 001
+
+
+3 ore
+Bear, Stearns International LTD
+1 Canada Square
+ondon E14 SAD England
+1207 516 661-
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+31.080.666.83
+235,736.13
+7,900,000.00
+$8,135,736.13
+-70,394.82
+-175,147.43
+........S:245.542.25
+7,890,193.88
+58.970,860.71
+Cash Balance Summary
+Cash
+Margin
+Net Cash Balance
+OPENING
+1,080,666.83
+0.00
+$1,080,666.83
+Income Summary
+THIS PERIOD
+Dividends
+232,000.00
+Credit Balance Int.
+3,736.13
+Total.
+$235.736.13
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+027
+CLOSING
+8,738,860.71
+232,000.00
+$8,970,860.71
+YEAR TO DATE
+232,000.00
+9,987.30
+฿241.987.30
+8,970,861
+$8,970,861
+09/01/01:13:20 001
+STATEMENT PERIOD July 28,2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Available
+July 27, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debit balance andor short
+
+
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+Bear, Stearns International LTD
+Reques ly he Security is
+ondon E14 SAD Englanc
+1207 516 661-
+STATEMENT PERIOD July 28, 2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Avallable
+July 27, 2001
+SIMBOUCUSIP
+QUANTITY
+PRICE
+MARKE
+ALU
+8,970,861
+$8,970,861
+NAME NONE FRONT
+YOUR PRICEDPORTFOLIOHOLDINGS
+$8,970,860
+Transaction Detail
+INVESTMENT ACTIVITY
+TREMENT TRE
+TRANSACTION
+08/24/01
+JOURNAL
+08/27/0JOUANAL*
+08/27/01
+JOURNAL
+TOTAL
+DESCRIPTION
+SYMBOLICUSIP
+QUANTITY
+DEBIT AMOUNT
+CREDIT AMOUNT
+BOSTON PROPERTIES INC
+PRICE
+BXP
+400,000
+JAL TO L
+PER INTX'S
+'BOSTON PROPERTIES..
+*••*40000**•••••••••••••••••••••••••••••••••••••••••••••••••/•••••••••••••••••/
+ADJ POSITION TO ZERO
+*BXP
+400,000
+027
+09101/01;13:20 001
+
+
+5 or 8
+Transaction Detail (continued)
+DIVIDENDS
+DATE
+DESCRIPTION
+07/30/01
+BOSTON PROPERTIES IN
+EC 06/29/01 PAY 07/30/0
+TOTAL
+INTEREST
+DATE
+08/09/01
+DESCRIPTION
+BSIL VSFINANCIAL TRUST CO., I
+YE3793 FRUITY SWA
+RECEIVE ON CASH ALONG
+08/10/01
+'BIL'VS FINANCIAL TRUST CO.|
+1013763 EQUITY SWAR
+EDENE ON CASH ALONG
+0B/20/01
+•'INTEREST ON CREDIT BALANCE
+
+TOTAL
+MISCELLANEOUS
+MATENY
+08/10/01
+TRANSACTION
+JOURNAL
+Bear, Stearns International LTD
+Reques ly he Security is
+1 Canada Square
+ondon E14 SAD Englan
+207 516 661
+SYMBOUCUSIP
+BXP
+QUANTITY
+400,000
+RATE (S)
+0.5800
+SYMBOL/GUSIP
+QUANTITY
+RATE (%)
+DESCRIPTION
+BSIL VSFINANCIAL TRUST CO.,I
+NY13763 EQUITY SWAP
+DUE 01/24/02
+SUN MICROSYSTEMS INC
+RECEIVE ON CASH FLOW B
+DEBIT AMOUNT
+175,147.43
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+70,085.80
+309.02
+$-70,394.82
+CRECIT AMOUNT
+09101/01;13:20 001
+STATEMENT PERIOO July 28, 2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+July 27, 2001
+CREDIT AMOUNT
+232,000.00
+$232,000.00
+CREDIT AMOUNT
+03736.13
+$3,736.13
+
+
+6 of 8
+Bear, Stearns International LTD
+gulated by the Security
+tures Author
+1 Canada Square
+London E14 SAD England
+0207 516 6614
+Transaction Detail (continued)
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+ANSACTI
+08/24/01
+URNI
+08/24/01 JOURNAL
+08/31701
+"JOURNAL"
+TOTAL
+DESCRIPTION
+FROM
+SAME
+SAME
+UNLFROM
+DEBIT AMOUNT
+$-175,147.43
+STOP
+****** End of Statement******
+027
+CREDIT AMOUNT
+1,900,000.00
+4,000,000.00
+2,000.000.00
+$7,900,000.00
+09/01/01:13:20 001
+STATEMENT PERIOD July 28,2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Avallable
+July 27, 2001
+
+
+Bear,Stearns International LTD
+Regulated by the Security &
+Futures Authorty
+120r sit all England
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+....
+Transaction Detail
+STATEMENT PERIOD June 30, 2001
+THROUGH
+July 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Avallable
+June 29, 2001
+3
+4
+5
+Hollandlold
+C/O AMERICAN YACHT HARBOR
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+15,712,000
+1,080,667
+$16,792,667
+17,502,877
+-710,211
+here are no "Stop Loss" orders or other pending bu
+r sell open orders on file for your account
+Market Value of Your Portfolio
+$1.080.667
+$1,142.877
+Cash & Equivalent
+Equities
+$15,712,000
+$16,360,000
+Current market value
+Last statement's market value
+SP This satement stori for retanal for our recorde Set reverse das a a doctant intormation.
+
+
+027
+07/28/01:12:41 001|
+
+
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Dividends/Interest Charged
+Amount obited.
+Net Cash Activity
+Closing Balance.
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stearns International LTD
+gulated by the Security
+tures Author
+1 Canada Square
+ondon E14 SAD Englan
+1207 516 661-
+THIS PERICO
+51.142,877.44
+3,373.73
+$3,373.73
+-65,584.34
+-65,584.34
+62,210.61
+$1.080.666.83
+Income Summary
+Credit Balance Int.
+Total
+THIS PERIOD
+3,373.73
+$3.373.73
+Portfolio Composition
+Cast/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+OFENING
+Cash
+1,142,877.44
+let Cash Balanc
+$1,142,877.44
+.......
+••••••••••••••••••••••••••
+CLOSING
+1,080,666.83
+$1,080,666.83
+••••••••••••••I
+027
+YEAR TO DATE
+6,251.17
+--...
+$6.251.17
+1,080,667
+15,712,000
+516.792,667
+STATEMENT PERIOO June 30, 2001
+THROUGH
+July 27,2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+June 29, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+6%
+Equities
+94%
+Unshaded portions denote debe balance andor short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Stearns International LTD
+legulated by the Security,
+utures Authorit
+1 Canada Square
+ondon E14 SAD Englan
+207 516 661
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SIMBOLCUSP
+QUANTITY
+EQUITIES
+Equities & Options
+DESCRIPTION
+BOSTON PROPERTIES INC
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOUCUSIP
+BXP
+MRGN
+QUANTITY
+400,000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+PRICE
+1.080,667
+$1,080,667
+PRICE
+39.2800
+MARKET
+VALUE
+15,712,000
+$15,712,000
+$15,712,000
+$928,000
+$16,792,666
+027
+STATEMENT PERIOD June 30, 2001
+THROUGH
+July 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Avallable
+June 29, 2001
+STIMAT
+INUAL INCO
+AHMEN MOME
+928,000
+$928,000
+$928,000
+CURREN
+YIELD IS
+5.9063
+
+
+Bear, Stearns International LTD
+Transaction Detail
+INTEREST
+DATE
+07/11/01
+
+TOTAL
+DESCRIPTION
+BSIL VSFINANCIAL TRUST CO.,T
+NV13763 EQUITY SWAP
+INTEREST ON CREDIT BALANCE
+500T.0820902089:6955
+SYMBOL/GUSIP
+QUANTITY
+STOP
+****** End of Statement******
+RATE (%)
+027
+DEBIT AMOUNT
+65,584.34
+STATEMENT PERIOD June 30, 2001
+THROUGH
+July 27,2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+June 29,2001
+CREDIT AMOUNT
+$-65,584.34
+3,373.7:
+$3.373.73
+
+
+Bear,Stearns International LTD
+Regulated by the Security &
+Futures Authorty
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+....
+Transaction Detail
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Avallable
+February 25,2000
+3
+4
+5
+Hollandlold
+C/O AMERICAN YACHT HARBOR
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+16,360,000
+1,142,877
+$17,502,877
+0
+17,502,877
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Cash & Equivalent -
+Equities -
+Market Value of Your Portfolio
+$1,142,877
+$0
+$0
+$16,360,000
+Current market value
+Last statement's market value
+SP This satement stori for atanal por oes recorde Set reverse das a a doctant intormation.
+07/01/01;03:09 001
+
+
+2 of 6
+027
+07:01/01:03:09 001
+
+
+Bear, Stearns International LTD
+Riles Alone Security i
+1 Canada Square
+ondon E14 SAD England
+1207 516 661-
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERICO
+50.00
+2,877.44
+4,660,000.00
+54.662,877.44
+.........
+-3,520,000.00
+5-3.620.00.00
+1,142,877.44
+51,142.877.44
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+0.00
+$0.00
+Income Summary
+Credit Balance Int.
+Total
+THIS PERIOD
+2,877.44
+52.877.44
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+CLOSING
+1,142,877.44
+$1,142,877.44
+YEAR TO DATE
+2,877.44
+$2.877.44
+1,142,877
+16,360,000
+617,502,871
+07:01/01:03:09001
+STATEMENT PERIOD May 26,2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Available
+February 25,2000
+Your Portfolio
+Allocation
+Cash & Equivalent-
+6%
+Equities
+94%
+Unshaded portions denote debit balance and or shart
+
+
+4 of 8
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Stearns International LTD
+legulated by the Security,
+utures Authorit
+1 Canada Square
+ondon E14 SAD Englan
+207 516 661
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SIMBOLCUSP
+QUANTITY
+EQUITIES
+Equities & Options
+DESCRIPTION
+BOSTON PROPERTIES INC
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOUCUSIP
+BXP
+MRGN
+QUANTITY
+400,000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+PRICE
+MARKE
+FALLE
+1,142,877
+$1,142,877
+PRICE
+40.9000
+MARKET
+VALUE
+16,360,000
+$16,360,000
+$16,360,000
+$928,000
+$17,502,877
+027
+STATEMENT PERIOD May 26,2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Avallable
+February 25,2000
+STIMATE
+NNUAL INCON
+ARMAL MOME
+928,000
+$928,000
+$928,000
+CURREN
+YIELD IS
+5.6724
+07:01/01:03:09 001
+V491
+
+
+5 of 8
+Transaction Detail
+INVESTMENT ACTIVITY
+SEEMENT TR
+06/11/01
+06/12/01
+RANSACTION
+OURNAL
+JOURNAL"
+TOTAL
+INTEREST
+DATE
+06/20/01
+DESCRIPTION
+INTEREST ON CREDIT BALANCE
+500 T21 902089:0618
+TOTAL
+MISCELLANEOUS
+DATE
+MO/DAY
+06/11/01
+TRANSACTION
+JOURNAL
+06/22/01 JOURNAL'
+Bear, Stearns International LTD
+gulated by the Security
+tures Authori
+1 Canada Square
+London E14 SAD England
+0207 516 6614
+DESCRIPTION
+FROSTON PAPERTES ING
+BOSTON PAOPETES INC
+FROM I
+SAME
+SYMBOUCUSIP
+CALL SUNMICROSYSTEMS INC
+MER OPTN - NY13764
+INANCIAL TRUST CO.. IN
+IP 01/18/200
+AYMENT PREMIUI
+"CALL SUN MICROSYSTEMS INC
+MER OPTN - NY13764
+INANCIAL TRUST CO., IN
+TO BSIL FOR N 13764 TEAM.
+SYMBOLCUSIP
+BXP
+BXP*
+QUANTITY
+RATE (%)
+DEBIT AMOUNT
+1,760,000.00
+027
+QUANTIT
+200,000
+200,000
+PRICE
+DEBIT AMOUNT
+CRECIT AMOUNT
+2,900,000.00
+07/01/01:03:09 001
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+February 25,2000
+DEBIT AMOUNT
+CREDIT AMOUNT
+CREDIT AMOUNT
+2,877.44
+$2,877.44
+V491
+
+
+Bear, Stearns International LTD
+6 of 8
+Transaction Detail (continued)
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+06/22/01
+TRANSACTION
+JOURNAL
+CALL SUNMICROSYSTEMS INC
+MER OPTN - NY13764
+DEBIT AMOUNT
+1,760,000.00
+06/25/01 JOURNAL
+TOTAL
+NANCIAL TRUST CO.. IN
+P 01/18/200
+EVERSE 6/22 DUPE ENTR
+$-3,520,000.00
+STOP
+***** End of Statement******
+027
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+Not Avallable
+February 25,2000
+CRECIT AMOUNT
+1,760,000.00
+$4,660,000.00
+07:01/01:03:09001
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/edefcd5eccc7feb04c3cb07fb63264517bac691a46c18077b43802f9f4d674a2.receipt.json b/vision-fixhub/ds9-unparsed-05/edefcd5eccc7feb04c3cb07fb63264517bac691a46c18077b43802f9f4d674a2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..fc375366f0c4cd8f49651da5913488b2d4926e2d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/edefcd5eccc7feb04c3cb07fb63264517bac691a46c18077b43802f9f4d674a2.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -4438,
+  "dataset": "marble-joined",
+  "doc_id": "edefcd5eccc7feb04c3cb07fb63264517bac691a46c18077b43802f9f4d674a2",
+  "engine": "marble-apple-vision",
+  "event_count": 41,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "5c8e42aa81e1ce689f19fdf1eb6580660bc7ab917544bdf1775bdd97259d01cc",
+  "output_sha256": "64660a34f80e384f503eefec7e9861874aed6712835be9e9e13d3589699968bb",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ee958d49d12f725f943a82a232ba3e384f0876b37eac9f79ebad27217bf48251.md b/vision-fixhub/ds9-unparsed-05/ee958d49d12f725f943a82a232ba3e384f0876b37eac9f79ebad27217bf48251.md
new file mode 100644
index 0000000000000000000000000000000000000000..faa6e7a4d2854d4c0334b462d7a21eeadf491295
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ee958d49d12f725f943a82a232ba3e384f0876b37eac9f79ebad27217bf48251.md
@@ -0,0 +1,54 @@
+OLY-74
+1- JANE DEE #5
+
+
+TO:
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-74
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury ofthe United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+September 4, 2007
+1:00pm*
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+Any correspondence, c-mails, text messages, or records of other communications with Jeffrey Epstein,
+1, Lesley Groff,
+1, o1
+I H the names and contact
+information of any females whom you have referred to Jeffrey Epstein, or whom Jeffrey Epstein has
+referred to you.
+All photographs in your possession that either (1) were taken at Jeffrey Epstein's Palm Beach residence,
+or (2) contain Jeffrey Epstein or any of his employees.
+*Please coordinate your compliance with this subnoenz and confirm the date and time, and location of
+your appearance with Special Agent
+l, Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+August 16, 2007
+This subpoena is issued upon application
+of the United States of America
+*If not applicable, enter "nonc."
+Name Address and Phone Number of Assistant U.S. Attorney
+Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. EL.33401-6235
+Tel:
+Fax:
+To be used in lieu of AD110
+FORM ORD-227
+JAN.8G
diff --git a/vision-fixhub/ds9-unparsed-05/ee958d49d12f725f943a82a232ba3e384f0876b37eac9f79ebad27217bf48251.receipt.json b/vision-fixhub/ds9-unparsed-05/ee958d49d12f725f943a82a232ba3e384f0876b37eac9f79ebad27217bf48251.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..045f4779c5938e0e7f9a800c971591ebb83992f1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ee958d49d12f725f943a82a232ba3e384f0876b37eac9f79ebad27217bf48251.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "ee958d49d12f725f943a82a232ba3e384f0876b37eac9f79ebad27217bf48251",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "cc3a8f83e02eb9467e5c9730a54956f055af974dc16a2279425f406f44f8cd97",
+  "output_sha256": "b00f935d35ca7b11378bb94e51368342694cd7b79ddbb991fb7baf8a89eb799d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ef73198dc4dc0d269c5ee3324f0204b9a97e82ac7b25e4059d9b433438c93e55.md b/vision-fixhub/ds9-unparsed-05/ef73198dc4dc0d269c5ee3324f0204b9a97e82ac7b25e4059d9b433438c93e55.md
new file mode 100644
index 0000000000000000000000000000000000000000..8b5d62eb3c6711be144dbb96f60e7a1326b34c90
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ef73198dc4dc0d269c5ee3324f0204b9a97e82ac7b25e4059d9b433438c93e55.md
@@ -0,0 +1,428 @@
+March 15, 2007
+DELIVERY BY HAND
+Miss Bl
+Re: Crime Victims' and Witnesses' Rights
+Dear Miss B
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense,
+you have a number of rights. Those rights are:
+(1)
+(2)
+(3)
+(4)
+(5)
+(6)
+(7)
+(8)
+The right to be reasonably protected from the accused.
+The right to reasonable, accurate, and timely notice of any public court proceeding
+involving the crime or of any release or escape of the accused.
+The right not to be excluded from any public court proceeding, unless the court
+determines that your testimony may be materially altered if you are present for other
+portions of a proceeding.
+The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, or sentencing.
+The reasonable right to confer with the attorney for the United States in the case.
+The right to full and timely restitution as provided in law.
+The right to proceedings free from unreasonable delay.
+The right to be treated with fairness and with respect for the victim's dignity and
+privacy.
+Members of the U.S. Department of Justice and other federal investigative agencies,
+including the Federal Bureau of Investigation, must use their best efforts to make sure that these
+rights are prospecd. Agou have any concerns in thim the Federal Beat of investigation at /
+, or Special Agent
+You also can contact the Justice Department's Office for Victims of Crime in
+Washington, D.C. at
+That Office has a website at www.ovc.gov.
+You can seek the advice of an attorney with respect to the rights listed above and, if you
+believe that the rights set forth above are being violated, you have the right to petition the Court for
+
+
+
+MIss B
+MARCH 15, 2007
+In addition to these rights, you are entitled to counseling and medical services, and protection
+from intimidation and harassment. If the Court determines that you are a victim, you also may be
+entitled to restitution from the perpetrator. A list of counseling and medical service providers can
+be provided to you, if you so desire. If you or your family is subjected to any intimidation or
+harassment, please contact Special Agent
+or myself immediately. It is possible that
+someone working on behalf of the targets of the investigation may contact you. Such contact does
+not violate the law. However, if you are contacted, you have the choice of speaking to that person
+or refusing to do so. If you refuse and feel that you are being threatened or harassed, then please
+contact Special Agent
+or myself.
+You also are entitled to notification of upcoming case events. At this time, your case is
+under investigation. If anyone is charged in connection with the investigation, you will be notified.
+Sincerely,
+By:
+Assistant United States Attorney
+V
+cc:
+, F.B.I.
+
+
+
+June 7, 2007
+DELIVERY BY HAND
+Miss CI
+Re: Crime Victims' and Witnesses' Rights
+Dear Miss A
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense,
+you have a number of rights. Those rights are:
+(1) The right to be reasonably protected from the accused.
+(2)
+The right to reasonable, accurate, and timely notice of any public court proceeding
+involving the crime or of any release or escape of the accused.
+(3)
+The right not to be excluded from any public court proceeding, unless the court
+determines that your testimony may be materially altered if you are present for other
+portions of a proceeding.
+(4)
+The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, or sentencing.
+(5)
+(б)
+The reasonable right to confer with the attorney for the United States in the case.
+The right to full and timely restitution as provided in law.
+(7) The right to proceedings free from unreasonable delay.
+(8)
+The right to be treated with fairness and with respect for the victim's dignity and
+privacy.
+Members of the U.S. Department of Justice and other federal investigative agencies,
+including the Federal Bureau of Investigation, must use their best efforts to make sure that these
+rights are protected. If you have any concerns in this regard, please feel free to contact me at
+, or Special Agent
+from the Federal Bureau of Investigation at
+You also can contact the Justice Department's Office for Victims of Crime in
+Washington, D.C. at
+That Office has a website at www.ovc.gov.
+You can seek the advice of an attorney with respect to the rights listed above and, if you
+believe that the rights set forth above are being violated, you have the right to petition the Court for
+
+
+
+MIss q
+In addition to these rights, you are entitled to counseling and medical services, and protection
+from intimidation and harassment. If the Court determines that you are a victim, you also may be
+entitled to restitution from the perpetrator. A list of counseling and medical service providers can
+be provided to you, if you so desire. If you or your family is subjected to any intimidation or
+harassment, please contact Special Agent
+or myself immediately. It is possible that
+someone working on behalf of the targets of the investigation may contact you. Such contact does
+not violate the law. However, if you are contacted, you have the choice of speaking to that person
+or refusing to do so. If you refuse and feel that you are being threatened or harassed, then please
+contact Special Agent
+or myself.
+You also are entitled to notification of upcoming case events. At this time, your case is under
+investigation. If anyone is charged in connection with the investigation, you will be notified.
+Sincerely,
+By:
+Assistant United States Attorney
+cc:
+_ F.B.I.
+
+
+
+Inited States Attorney
+Southern District of Florid
+June 7, 2007
+DELIVERY BY HAND
+Miss A
+Re: Crime Victims" and Witnesses' Rights
+Dear Miss CL
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense,
+you have a number of rights. Those rights are:
+(1) The right to be reasonably protected from the accused.
+(2) The right to reasonable, accurate, and timely notice of any public court proceeding
+involving the crime or of any release or escape of the accused.
+(3)
+The right not to be excluded from any public court proceeding, unless the court
+determines that your testimony may be materially altered if you are present for other
+portions of a proceeding.
+(4)
+The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, or sentencing.
+(5)
+The reasonable right to confer with the attorney for the United States in the case.
+(6)
+The right to full and timely restitution as provided in law.
+(7) The right to proceedings free from unreasonable delay.
+(8)
+The right to be treated with fairness and with respect for the victim's dignity and
+privacy.
+Members of the U.S. Department of Justice and other federal investigative agencies,
+including the Federal Bureau of Investigation, must use their best efforts to make sure that these
+rights are protected. If you have any concerns in this regard, please feel free to contact me at
+, or Special Agent
+from the Federal Bureau of Investigation at
+You also can contact the Justice Department's Office for Victims of Crime in
+Washington, D.C. at
+• That Office has a website at www.ovc.gov.
+You can seck the advice of an attorney with respect to the rights listed above and, if you
+believe that the rights set forth above are being violated, you have the right to petition the Court for
+
+
+
+MISS A
+In addition to these rights, you are entitled to counseling and medical services, and protection
+from intimidation and harassment. If the Court determines that you are a victim, you also may be
+entitled to restitution from the perpetrator. A list of counseling and medical service providers can
+be provided to you, if you so desire. If you or your family is subjected to any intimidation or
+harassment, please contact Special Agent
+Lor myself immediately. It is possible that
+someone working on behalf of the targets of the investigation may contact you. Such contact does
+not violate the law. However, if you are contacted, you have the choice of speaking to that person
+or refusing to do so. If you refuse and feel that you are being threatened or harassed, then please
+contact Special Agent
+or mysell.
+You also are entitled to notification of upcoming case events. At this time, your case is under
+investigation. If anyone is charged in connection with the investigation, you will be notified.
+Sincerely,
+By:
+Assistant United States Attorney
+cc:
+_ F.B.I.
+
+
+
+Sontes Destit on Forida
+June 7, 2007
+DELIVERY BY HAND
+Miss L
+Re: Crime Victims' and Witnesses' Rights
+Dear Miss F
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense,
+you have a number of rights. Those rights are:
+(1) The right to be reasonably protected from the accused.
+(2) The right to reasonable, accurate, and timely notice of any public court proceeding
+involving the crime or of any release or escape of the accused.
+(3) The right not to be excluded from any public court proceeding, unless the court
+determines that your testimony may be materially altered if you are present for other
+portions of a proceeding.
+(4)
+The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, or sentencing.
+(5)
+The reasonable right to confer with the attorney for the United States in the case.
+(6)
+The right to full and timely restitution as provided in law.
+(7) The right to proceedings free from unreasonable delay.
+(8)
+The right to be treated with fairness and with respect for the victim's dignity and
+privacy.
+Members of the U.S. Department of Justice and other federal investigative agencies,
+including the Federal Bureau of Investigation, must use their best efforts to make sure that these
+rights are protected. If you have any concerns in this regard, please feel free to contact me at
+, or Special Agent
+from the Federal Bureau of Investigation at
+You also can contact the Justice Department's Office for Victims of Crime in
+Washington, D.C. at
+That Office has a website at www.ovc.gov.
+You can seek the advice of an attorney with respect to the rights listed above and, if you
+believe that the rights set forth above are being violated, you have the right to petition the Court for
+
+
+
+MISS L
+In addition to these rights, you are entitled to counseling and medical services, and protection
+from intimidation and harassment. If the Court determines that you are a victim, you also may be
+entitled to restitution from the perpetrator. A list of counseling and medical service providers can
+be provided to you, if you so desire. If you or your family is subjected to any intimidation or
+harassment, please contact Special Agent
+lor myself immediately. It is possible that
+someone working on behalf of the targets of the investigation may contact you. Such contact does
+not violate the law. However, if you are contacted, you have the choice of speaking to that person
+or refusing to do so. If you refuse and feel that you are being threatened or harassed, then please
+contact Special Agent
+or myself.
+You also are entitled to notification of upcoming case events. At this time, your case is under
+investigation. If anyone is charged in connection with the investigation, you will be notified.
+Sincerely,
+By:
+Assistant United States Attorney
+cc:
+
+
+
+outhern District of Florid
+June 7, 2007
+DELIVERY BY HAND
+Miss R
+Re: Crime Victims' and Witnesses' Rights
+Dear Miss S
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense,
+you have a number of rights. Those rights are:
+(1)
+(2)
+(3)
+(4)
+(5)
+(6)
+(7)
+(8)
+The right to be reasonably protected from the accused.
+The right to reasonable, accurate, and timely notice of any public court proceeding
+involving the crime or of any release or escape of the accused.
+The right not to be excluded from any public court proceeding, unless the court
+determines that your testimony may be materially altered if you are present for other
+portions of a proceeding.
+The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, or sentencing.
+he reasonable right to conter with the attorney for the United States in the case
+The right to full and timely restitution as provided in lav
+The right to proceedings free from unreasonable delay.
+The right to be treated with fairness and with respect for the victim's dignity and
+privacy.
+Members of the U.S. Department of Justice and other federal investigative agencies,
+including the Federal Bureau of Investigation, must use their best efforts to make sure that these
+ights are protected. If you have any concerns in this regard, please feel free to contact me at
+, or Special Agent
+You also can contact the Justice Department's Office for Victims of Crime in
+Washington, D.C. at
+You can seek the advice of an attorney with respect to the rights listed above and, if you
+believe that the rights set forth above are being violated, you have the right to petition the Court for
+
+
+
+MISS R
+In addition to these rights, you are entitled to counseling and medical services, and protection
+from intimidation and harassment. If the Court determines that you are a victim, you also may be
+entitled to restitution from the perpetrator. A list of counseling and medical service providers can
+be provided to you, if you so desire. If you or your family is subjected to any intimidation or
+harassment, please contact Special Agent
+or myself immediately. It is possible that
+someone working on behalf of the targets of the investigation may contact you. Such contact does
+not violate the law. However, if you are contacted, you have the choice of speaking to that person
+or refusing to do so. If you refuse and feel that you are being threatened or harassed, then please
+contact Special Agent
+or myself.
+You also are entitled to notification of upcoming case events. At this time, your case is under
+investigation. If anyone is charged in connection with the investigation, you will be notified.
+Sincerely,
+By:
+Assistant United States Attorney
+CC:
+
+
+
+Southern District of Florid
+June 7, 2007
+DELIVERY BY HAND
+Miss MO
+Re: Crime Victims' and Witnesses' Rights
+Dear Miss S
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense,
+you have a number of rights. Those rights are:
+(1) The right to be reasonably protected from the accused.
+(2)
+The right to reasonable, accurate, and timely notice of any public court proceeding
+involving the crime or of any release or escape of the accused.
+(3)
+The right not to be excluded from any public court proceeding, unless the court
+determines that your testimony may be materially altered if you are present for other
+portions of a proceeding.
+(4)
+The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, or sentencing.
+(5)
+(6)
+(7)
+(8)
+The reasonable right to conter with the attorney for the United States in the case.
+The right to full and timely restitution as provided in law.
+The right to proceedings free from unreasonable delay.
+The right to be treated with fairness and with respect for the victim's dignity and
+privacy.
+Members of the U.S. Department of Justice and other federal investigative agencies,
+including the Federal Bureau of Investigation, must use their best efforts to make sure that these
+rights are protected. If you have any concerns in this regard, please feel free to contact me at
+, or Special Agent
+from the Federal Bureau of Investigation at
+You also can contact the Justice Department's Office for Victims of Crime in
+Washington, D.C. at
+That Office has a website at www.ovc.gov.
+You can seek the advice of an attorney with respect to the rights listed above and, if you
+believe that the rights set forth above are being violated, you have the right to petition the Court for
+
+
+
+MISS MI
+SI
+In addition to these rights, you are entitled to counseling and medical services, and protection
+from intimidation and harassment. If the Court determines that you are a victim, you also may be
+entitled to restitution from the perpetrator. A list of counseling and medical service providers can
+• be provided to you, if you so desire. If you or your family is subjected to any intimidation or
+harassment, please contact Special Agent
+or myself immediately. It is possible that
+someone working on behalf of the targets of the investigation may contact you. Such contact does
+not violate the law. However, if you are contacted, you have the choice of speaking to that person
+or refusing to do so. If you refuse and feel that you are being threatened or harassed, then please
+contact Special Agent
+or myself.
+You also are entitled to notification of upcoming case events. At this time, your case is under
+investigation. If anyone is charged in connection with the investigation, you will be notified.
+Sincerely,
+By:
+Assistant United States Attorney
+cc:
+
+
+
+June 7, 2007
+DELIVERY BY HAND
+Miss C
+Re: Crime Victims' and Witnesses' Rights
+Dear Miss W
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense,
+you have a number of rights. Those rights are:
+(1)
+(2)
+(3)
+The right to reasonable, accurate, and timely notice of any public court proceeding
+The right that time or of add flame or scape of the apeding, unless the court
+determines that your testimony may be materially altered if you are present for other
+(4)
+(5)
+(6)
+(7)
+(8)
+The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, or sentencing.
+The reasonable right to confer with the attorney for the United States in the case.
+The right to full and timely restitution as provided in law.
+The right to proceedings free from unreasonable delay.
+The right to be treated with fairness and with respect for the victim's dignity and
+privacy.
+Members of the U.S. Department of Justice and other federal investigative agencies,
+including the Federal Bureau of Investigation, must use their best efforts to make sure that these
+rights are protected. If you have any concerns in this regard, please feel free to contact me at
+, or Special Agent
+from the Federal Bureau of Investigation at
+You also can contact the Justice Department's Office for Victims of Crime in
+Washington, D.C. at
+That Office has a website at www.ovc.gov.
+You can seek the advice of an attorney with respect to the rights listed above and, if you
+believe that the rights set forth above are being violated, you have the right to petition the Court for
+
+
+
+MIsS C
+In addition to these rights, you are entitled to counseling and medical services, and protection
+from intimidation and harassment. If the Court determines that you are a victim, you also may be
+entitled to restitution from the perpetrator. A list of counseling and medical service providers can
+be provided to you, if you so desire. If you or your family is subjected to any intimidation or
+harassment, please contact Special Agent
+or myself immediately. It is possible that
+someone working on behalf of the targets of the investigation may contact you. Such contact does
+not violate the law. However, if you are contacted, you have the choice of speaking to that person
+or refusing to do so. If you refuse and feel that you are being threatened or harassed, then please
+contact Special Agent
+or myselt.
+You also are entitled to notification of upcoming case events. At this time, your case is under
+investigation. If anyone is charged in connection with the investigation, you will be notified.
+Sincerely,
+By:
+Assistant United States Attorney
+cc:
+, F.B.I.
+•
diff --git a/vision-fixhub/ds9-unparsed-05/ef73198dc4dc0d269c5ee3324f0204b9a97e82ac7b25e4059d9b433438c93e55.receipt.json b/vision-fixhub/ds9-unparsed-05/ef73198dc4dc0d269c5ee3324f0204b9a97e82ac7b25e4059d9b433438c93e55.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..92af038cc16c65dca39ba4304d5dbf80cd300ab5
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ef73198dc4dc0d269c5ee3324f0204b9a97e82ac7b25e4059d9b433438c93e55.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1373,
+  "dataset": "marble-joined",
+  "doc_id": "ef73198dc4dc0d269c5ee3324f0204b9a97e82ac7b25e4059d9b433438c93e55",
+  "engine": "marble-apple-vision",
+  "event_count": 29,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "ba567ab3e2b7abb0709999c1deeae00502887148438378c14c10c716b1770b68",
+  "output_sha256": "8e95c28edd147169c35e2f9e72fb33970c1e7f09cc8c5c33ae523db88ea0fcde",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/efc34da9a31d0123ba3dd7aa8f0be48b20ed1b98d30658026b6c4856f9dcc10f.md b/vision-fixhub/ds9-unparsed-05/efc34da9a31d0123ba3dd7aa8f0be48b20ed1b98d30658026b6c4856f9dcc10f.md
new file mode 100644
index 0000000000000000000000000000000000000000..7aa18a1d96c9137e0d698c55eec2bd9a1471aa28
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/efc34da9a31d0123ba3dd7aa8f0be48b20ed1b98d30658026b6c4856f9dcc10f.md
@@ -0,0 +1,137 @@
+Jeffrey Epstein Pedophile Billionaire and His Sex Den - The Daily Beast
+
+THE DAILY
+BEAST
+READ THIS SKIP THAT
+BLOGS & STORIES
+The Billionaire Pedophile's Sex Den
+by Conchita Sarnoff
+July 22, 2010 | 11:46pm
+The Daily Beast reveals new details about the twisted sex life of
+Jeffrey Epstein and his penchant for underage girls. Conchita
+Sarnoff on his massages, sex toys, and questionable deals. Also:
+• Nude images of young girls were scattered around the house and the
+bathroom soap was shaped like sex organs
+• Staff trolled for fresh recruits to make sure Epstein had two or three
+massage appointments each day
+• The house manager has been sentenced to a longer prison term than
+Newscom
+Epstein-for trying to sell notes regarding massage appointments
+• Epstein gave $1 million to his friend Jean Luc Brunel when he was starting the modeling agency MC2
+• According to a former bookkeeper, young girls were brought to the U.S. by MC2—often from Eastern
+Europe-then traveled on Epstein's private jets
+Jeffrey Epstein's loyal friends say that his prosecution was unduly harsh, rather than outrageously lenient. They insist
+that his sexual habits, although obsessive and unusual, were mostly legal and essentially harmless. As the police
+records attest, the girls brought to El Brillo Way were routinely told they could "say no" at any time during a massage
+as Epstein escalated contact in a step-by-step assault that was remarkably similar in every victim's statement: First
+she would be asked to remove her shirt, then her pants. He would attempt to fondle her buttocks and breasts as he
+masturbated, then bring out a large vibrator. There was sometimes digital penetration, and the more willing girls were
+lured into full-blown sexual relations with both Epstein and
+who was referred to in press accounts
+and police reports as Epstein's live-in "sex slave."
+A former bookkeeper in the Miami office, who also arranged visas for girls
+traveling to the U.S., confirmed that MC2 girls became frequent guests on
+Epstein's private jets.
+PRINT
+It's true that some underage girls may have lied about their age, and some came to the house voluntarily several
+times-although, according to Florida statutes, none of that has any bearing on the criminality of the contact,
+particularly if the girl was 16 or younger. But what is particularly disturbing about this case-judging by arrangements
+at the Palm Beach house—is that Epstein, a billionaire hedge-fund manager, organized his life around this sexual
+compulsion in an open and methodical way that suggests he felt he was beyond the law.
+• Conchita Sarnoff:
+Billionaire Pedophile Goes
+Free
+According to police who executed a search warrant, the house was
+decorated with large, framed photos of nude young girls, and similar
+images were found stashed in an armoire and on the computers seized
+at the house (although police found only bare cables where other
+computers had been). Some bathrooms were stocked with soap in the
+http://www.thedailybeast.com/blogs-and-stories/2010-07-22/jeffrey-epstein-pedophile-billi. 7/23/2010
+
+
+Jeffrey Epstein Pedophile Billionaire and His Sex Den - The Daily Beast
+
+shape of sex organs, and various sex toys, such as a "twin torpedo" vibrator and creams and lubricants available at
+erotic specialty shops, were stowed near the massage tables set up in several rooms upstairs.
+Epstein also enlisted his staff in the predatory activity, and four—
+1. Lesley Groff, and
+-figured in the FBI investigation. The Non Prosecution Agreement stipulated that they would not be
+charged. According to police reports and sworn statements in the civil suits, all four women, among their other duties,
+worked to ensure that an appointment book for twice- or thrice-daily "massages" was stocked with fresh recruits.
+Ghislaine Maxwell, daughter of the late Czechoslovakian-born press baron Robert Maxwell, who was for many years
+Epstein's live-in partner, also recruited young girls.
+Since his 13-month sentence for soliciting prostitution with a minor, Epstein has settled more than a dozen lawsuits
+brought by underage girls. Seven victims reached a last-minute deal last week, days before a scheduled trial; each
+received well over $1 million—an amount that will hardly dent Epstein's $2 billion net worth.
+The victims told police they waited in the kitchen to be called upstairs for a massage, and the house chef often gave
+them a bite to eat. House manager Alfredo Rodriguez said in his sworn statement that a maid named Lupita, who was
+a devout Catholic, wept when she complained to him about cleaning up after the massage sessions, picking up soiled
+towels and putting away the sex toys. And she was upset that a photo of Epstein with the pope hung next to one of
+him with a young girl.
+Ironically, Rodriguez, who ran the house on El Brillo Way in 2004 and 2005, ended up being sentenced to more jail
+time than his boss as a result of the complex investigation into Epstein's activities. He was fired, he says, for
+inadvertently drawing police attention to one of the girls when she arrived at the house unannounced to collect money.
+He saw an unfamiliar "beater" in the driveway one evening and called 911. When he left Epstein's employ, Rodriguez
+took away some notes and emails about massage appointments as "protection" against his own prosecution, and
+failed to produce them during the Palm Beach Police Department's initial investigation.
+Unable to get work as a house manager elsewhere in South Florida, he says, Rodriguez later tried to sell this "golden
+nugget"—his term—for $50,000, to be used in the victims' civil suits. Unfortunately, he made the offer to an
+undercover cop, and was subsequently charged with "obstruction of official proceedings" for withholding information
+that could have advanced the criminal investigation of Epstein-which by that point had been settled in a plea deal.
+Rodriguez was sentenced to 18 months in federal prison (Epstein was allowed to serve 13 months in the Palm Beach
+county jail), and now awaits an additional sentence on Aug. 24 in federal court in Miami for transporting firearms,
+another deal he says he made to pay the bills after he lost his job.
+In a deposition given for the civil suits, Rodriguez testified that he was instructed to always have $2,000 in cash on
+hand, so that he could pay both the girls who gave massages and recruiters such as
+who brought them
+to the house. He also testified that Epstein made large contributions to the Palm Beach Police Department, and in
+return was given PBPD baseball hats to put on the dashboard of his various cars to avoid being stopped or ticketed by
+local police. Retired Police Chief_
+I. in his own deposition, acknowledged that, in addition to earlier
+donations to the police department (which are fairly common in well-heeled Palm Beach), Epstein had recently given
+the department $100,000 for some sophisticated equipment. The police were still researching the purchase when
+Epstein came under suspicion, and
+told police that Epstein also gave $100,000 to the Florida Ballet for massages, because he was "very passionate"
+about massages being "therapeutically and spiritually" beneficial. Yet victims told police they had no massage
+training.)
+Perhaps most disturbing, in terms of possible sex trafficking, was Epstein's relationship with Jean Luc Brunel, owner
+of the MC2 modeling agency. According to a complaint filed in the U.S. District Court for the Southern District of
+Florida, an alleged victim said that Epstein, Maxwell, Brunel, Rodriguez, and
+"deliberately engaged in a
+pattern of racketeering that involved luring minor children through MC2, mostly girls under the age of 17, to engage in
+sexual play for money." (Which would amount to trafficking.)
+Brunel is a 50-plus French playboy who was formerly part owner of Karin, a Paris-based modeling agency. He lives in
+New York and South Beach, Florida, and owns 85 percent of MC2, which has offices in New York, Miami, and Tel
+http://www.thedailybeast.com/blogs-and-stories/2010-07-22/jeffrey-epstein-pedophile-billi.. 7/23/2010
+
+
+Jeffrey Epstein Pedophile Billionaire and His Sex Den - The Daily Beast
+
+Aviv. (The remaining 15 percent is owned by his partner, Jeff Fuller.) Brunel has been observed as a house guest at
+Epstein's Palm Beach home and may well have had contact with him also in New York, where Epstein owns a lavish
+home-the city's largest private residenceand in Paris, where Epstein keeps an apartment on elegant Ave. Foch.
+CBS reporter Craig Pyes, who investigated MC2 for a 60 Minutes broadcast several years ago, is quoted in Michael
+Gross' book about the modeling industry, Bad and Beautiful. Pyes told the author that Brunel "ranks among the
+sleaziest people in the fashion industry. We're talking about a conveyor belt, not a casting couch. Hundreds of girls
+were not only harassed but molested." Now The Daily Beast has learned that Epstein had made a $1 million wire
+transfer to Brunel's offshore bank account in September 2004, just as he was setting up MC2. Whether this was a gift
+or a loan or a backdoor investment in the new venture is unknown. A French citizen who managed to avoid giving
+evidence in the Epstein investigation, Brunel declined to comment on any of this, as does Fuller. Asked in April of
+Brunel's activities, Epstein said "I'm 100 percent convinced that he doesn't traffic children." (Brunel has never been
+charged.)
+An American fashion designer who booked her girls through MC2 says they were very young and very beautiful; many
+were from Eastern Europe and spoke little English. A former bookkeeper in the agency's Miami office, who also
+arranged visas for girls traveling to the U.S., confirmed that MC2 girls became frequent guests on Epstein's private
+jets.
+Pilot logs obtained in the civil suits show that some of the named plaintiffs were on the flight manifests. Other times,
+the pilot would just list the other passengers plus "female."
+Read Conchita Sarnoff's original report on Epstein.
+Conchita Sarnoff has developed multimedia communication programs for Fortune 500 companies and has produced
+three current events debate television programs, The Americas Forum, From Beirut to Kabul, and a segment for The
+Oppenheimer Report. She is a contributor to The Huffington Post and is writing a book about child trafficking in
+America.
+Get a head start with the Morning Scoop email. It's your Cheat Sheet with must reads from across the Web. Get it.
+For inquiries, please contact The Daily Beast at editorial@thedailybeast.com.
+URL: http://www.thedailybeast.com/blogs-and-stories/2010-07-22/jeffrey-epstein-pedophile-billionaire-and-his-sex-den/p/
+PRINT
+http://www.thedailybeast.com/blogs-and-stories/2010-07-22/jeffrey-epstein-pedophile-billi.. 7/23/2010
diff --git a/vision-fixhub/ds9-unparsed-05/efc34da9a31d0123ba3dd7aa8f0be48b20ed1b98d30658026b6c4856f9dcc10f.receipt.json b/vision-fixhub/ds9-unparsed-05/efc34da9a31d0123ba3dd7aa8f0be48b20ed1b98d30658026b6c4856f9dcc10f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1d735f55e68068c7815b892b9d5ea0f3083b40d4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/efc34da9a31d0123ba3dd7aa8f0be48b20ed1b98d30658026b6c4856f9dcc10f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -69,
+  "dataset": "marble-joined",
+  "doc_id": "efc34da9a31d0123ba3dd7aa8f0be48b20ed1b98d30658026b6c4856f9dcc10f",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "29c333d1c6da9d0bd418c061293e51a16240fbdfc1753e38a0a1c54345dce582",
+  "output_sha256": "1d17038ada5e13540f4f97ccf3dcc6af154803a6a35cf4bb9c65ad5d2152f63d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/f0c7efa7e6b8c4bf5d560a81583023da095714ade3b1ddb93c11e47c964b34a9.md b/vision-fixhub/ds9-unparsed-05/f0c7efa7e6b8c4bf5d560a81583023da095714ade3b1ddb93c11e47c964b34a9.md
new file mode 100644
index 0000000000000000000000000000000000000000..65bd481803eb833b3ba47a624bde3e8287e72ddf
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f0c7efa7e6b8c4bf5d560a81583023da095714ade3b1ddb93c11e47c964b34a9.md
@@ -0,0 +1,309 @@
+8115108 AMCV e-mail re Agnt
+
+
+Cant make arment
+If December wasn't accepted, then we are
+back to October modification
+-more victims -not limited to ones prepared to
+name in an indicment
+- waires right to challerge labelity
+- nued to pick Special Maste Vitorey
+attorney
+or Special Master it will be a
+breach
+- one week to do submission to Special
+Master, no more lolly gagging
+Tis is a "you reap what you soco" moment.
+We tried to limit Mr. Epsteins exposure.
+we tried to reduce the chance of unscrupulous
+Mornep tryng to take advantage of the
+city and unsophisticated victins
+We tried to bring guick, quiet resdutions
+pu decided that it was is your cients bes.
+interests to roll the dice and ao for
+CeR, wilt put in and sad it to
+Ur. Black is the only mambo i Eater tamanho pas not
+
+
+i har cour to acceptance
+afferming
+and his co-counsel
+Ask that you enter an are tenus motion.
+simiting Me crusade bestitution
+and co-councel
+As charly stated in the letter,
+Mr. Tein filed my
+Decl. in the civil
+suits against Mr. Epsler
+in super of their motion to
+stay the litigation.
+Names additional persons
+→be grand jury
+Mr. Cassell
+Mr. Edwards
+Mr. Lee
+Judge Marra
+Filed a case yesterday on behalf o S.R.
+
+
+•08/18/2008 17:40 FAX
+0002/003
+:
+Jay P. Litkowilz, P.C.
+AND ALIMIT PARIN SHAM
+Citigroup Conler
+163 East 53rd Street
+Now York, New York 10022-1011
+(212) 446-4800
+www.kirkland.com
+August 18, 2008
+Facsimile:
+1 446-4900
+VIA FACSIMILE: (561) 820-8777
+1. Maric Villalana
+United States Altomey's Olice
+Southern District of Florida
+500 South Australian Avenuc. Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epstein
+Dear Marie:
+I write in response to your letter dated August 15. 2008 regarding the civil restitution
+portion of the Deferred Prosecution Agreement (the "Agreement"). Thank you for conlirming
+our position that the December modification proposal is not part of the Agreement. As expressed
+by U.S. Allorney Acosta in his December 19. 2007 letter, the unorthodox use of' a civil restitution
+statute in a federal plea agreement. which resulled in stale charges against Mr. Epstein. has
+caused several miscommunications with respect to the implementation of the terms of that
+Agreement. In order to avoid any further miscommunications and to ensure that the 18 U.S.C.
+$ 2255 aspects of the Agrcement are carried out in a proper manner. it would he uscful to come
+lo an agreement as to the implementation of the civil restitution portion of' the Agreement. As
+we have previously stated. Mr. Lpstein fully intends to abide by the terms of the Agreement, and
+we hope you appreciate that our efforts to resolve any misunderstandings between Mr. Epstein
+and the government about the terms of the Agreement are intended only to ensure that it is
+carried out Jully and fairly.
+In an effort to avoid having cither party unintenbonally breach the Agreement. we
+suggest that steps be taken to clarify the meaning of paragraphs 7-10. It would he extremely
+helpful to both sides to have an independent third party consider the Agreement and offer the
+final word on how certain clauses should be interpreted and satisfied. Because the government.
+has already enlisted Judge
+to select the attorney representative under the Agreement. We
+would be amenable to his serving in this role.
+In order to come to an agreement on the exact procedure by which the identified
+individuns will obtain restitution. I am providing you with our thoughts on three issues below.
+Chicago
+Hong Kong
+London
+Los Angeles
+Munich
+San Francisco
+Washington, D.C.
+
+
+08/18/2008 17:40 FAX
+# 003/003
+A. Maric Villafona
+August 18.2008
+Page 2
+Once we come to an agreement on the following and you provide a complete and final list of
+identified individuals, it will be appropriate to notily them.
+First. I am concerned by your suggestion that you might want to increase the number of
+individuols on the government's list. I had expected the number to have become smaller,
+added to the list.
+Second. we will cooperate with the government to reach to an agrement as to substance
+of the notification to be sent to the government's list of individuals. Based on the Agreement.
+the information contained in the notification should he limited to (1) the language provided in the
+Agreement dealing with civil restitution (paragraphs 7-10) and (2) the contact information of the
+selected attorney representative. We object to the inclusion of additional intormation about the
+investigation of Mr. lipstein, the terms of the Agreement other than paragraphs 7-10. and the
+identity of'other identified individuals.
+Third, as you are aware. the Addendum requires that "the parties will joindly prepare a
+short written submission to the independent third-party regarding the role of the attorney
+representative and regarding Epstein's Agreement to pay such attorney representative his or her
+customary hourly rate for representing such victims subject to the provisions of Paragraph C.
+infra." We will certainly coopcrate with the government to drati such a joint submission and
+would he pleased to submit draft language to you for such a joint submission.
+1 look forward to working with you to resolve these matters. I believe we have a mutual
+interest in moving past all of these issues so that the civil resritution aspects of the Agreement
+can be fulfiled.
+Sincerely.
+Letkowitz.
+Cc:
+Karen Atkinson, Chief: Norhern Division
+
+
+Jay P. Leilkowitz, P.C.
+To Call Writer Directly
+lefkowilz@@kirkland.com
+AND AIRLIAL FAGINHASHEPS
+Citigrous Conter
+153 East 53rd Street
+New York, Now York 10022-4611
+(212) 436-1800
+www.kickland.com
+August 18, 2008
+• 446-4900
+VIA FACSIMILE (561) 820-8777
+A. Marie Villalana
+United States Allorney's Office
+Southern District of Florida
+500 South Austrahan Avenuc. Suite 400
+West Palm Beach, Florila 33401
+Ke: Jeffrey Epsicin
+Dear Marie:
+I write in rosponse to your leffer dated August 15. 2008 regarding the civil restitution
+portion of the Deferred Prosecution Agreement (the "Agrement). Thank you lor contirming
+our position that the December modification proposal is not part of the Agreemeni. As expressed
+by U.S. Atlomey Acosta in his December 19. 2007 letter, the unorthodox use of a civil restitition
+statiste in a federal plea agreement, which resulted in stale charges against Mr. Epstein. has
+caused several miscommunications with respect to the implementation of the terms of that
+Agreement. In order to avoid any further miscommunications and to chsure that the 18 U.S.C.
+$ 2255 aspects of the Agreement are carried out in a proper manner. it would he useful to come
+1o an agreement as to che implementation of the civil restitution poition of the Agroomept. As
+we have previously stated. Mr. Lipsrein fully intends to abide hy the terms of the Agreement and
+we hope you appreciale that our efforts to resolve any misunderstandings berwoon Mr. Epstein
+and the government about the terms of the Agreemeni are intended only to ensure that it is
+carried out folly and fairly.
+In in effort to avoid having cither party unintentionally breach the Agrecment. we
+suggest that stops be laken to clarify the meaning of paragraphs 7-10. It would he extremely
+helpful to both sides to have an independent third party consider the Agreement and offc the
+final word on how certain clauses should be interpreted and satisfied. Because thé government
+has already enlisted Judge Davis to select the attorney representative under the Agreement. we
+would be amenable to his serving in this role.
+In order io come to un agreement on the exact procedure by which the identified
+individunis will obtain restitution: I am providing you with our thoughts on three issues below;
+Chicago
+Hong Kong
+London
+Los Angeles
+Munich
+San Francisco
+Washington, D.C.
+
+
+A. Maric Villafana
+August 18. 2008
+Page 2
+Once we come to an agreement on the following and you provide a complete and final list of
+identified individuals, it will be appropriate to nottly them.
+First. I am concerned by your suggestion that you might want to increase the number of
+individuals on the government's list. I had expected the number to bave become smaller,
+because when we spoke prior to signing the agreement, you told me that the government already
+had it hist. and we were informed thereafter that the September 24. 2007 list hod been narrowed.
+('crainly: anyone who was not on the list prior: to September 24. 2007 cannot permissibly he
+added to the list.
+Second. we will cooperate with the government to reach lo an agreement as to substance
+of the notilication to be sent to the government's list of individuals: Based on the Agreement.
+the information contained in the notification should be limited to (1) the language provided in the
+Agreement dealing with civil restitution (paragraphs 7-10) and (2) the contact information of the
+selected attorney representative. We object to the inclusion of additional inlormation about the
+invesligation of Mr. lipstein, the terms of the Agreement other than paragraphs 7-10. and the
+identity of other identified individuals.
+Third, as you are aware the Addendum requires that."the parties
+jointly prepare a
+short writen submission to the independen third party regording the role of the hitorney
+representative and regarding Epstein's Agreement to pay such atomicy reprosentative his or her
+customary hourly vote for representing such victims subject to the provisions of Paragraph C.
+infra." We will certainly cooperate with the government to drati such a join submission and
+would he pleased to suhimit draft language to you for such a joint submission.
+Flook forward ro working with you to resolve those matters. I believe wo have a muttal
+interust in moving past all of these issues so that the civil restitution aspects of the Agreement
+eum be fulfilled.
+Sincerely.
+P. Lelkowitz
+cc:
+Karen Atkinson. Chief. Norihern Division
+
+
+Fax Transmittal
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4611
+Phonei
+Fax!
+Please notify us immediately if any pages are not received.
+THE INFORMATION CONTAINED IN THIS COMMUNICATION IS CONFIDENTIAL. MAY
+BE ATTORNEY-CLIENT PRIVILEGED, MAY CONSTITUTE INSIDE INFORMATION, AND
+IS INTENDED ONLY FOR THE USE OF THE ADDRESSEE. UNAUTHORIZED USE,
+DISCLOSURE OR COPYING IS STRICTLY PROHIBITED AND MAY BE UNLAWFUL.
+IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR,
+PLEASE NOTIEY US IMMEDIATELY AT:
+7) 446-4800.
+To:
+A. Marie Villafana
+CC:
+Karen Atkinson
+From:
+Jay RiLekowitz
+Message:
+Company:
+United States Attorncy's Office
+Company:
+United States Altorney's Office
+Date:
+Pages w/cover:
+August 18.2008
+Fax #;
+561-820-8777
+Fax #:
+561-8202-8777
+Fax #:
+476-6460:
+Direct #:
+561-209-1047
+Direct #:
+Direct #:
+-212 446-4970:
+
+
+Villafana, Ann Marie C. (USAFLS)
+From:
+Sent:
+To:
+Acosta, Alex (USAFLS)
+Friday, August 15, 2008 11:55 AM
+Villafana, Ann Marie C. (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee,
+Dexter (USAFLS); Atkinson, Karen (USAFLS)
+Subject:
+RE: New proposed response to Jay
+How about a slightly different version:
+Thank you for your response. Our communications with Roy Black and later with you were solely to determine
+what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. We appreciate your answering
+our question with finality, You have now made clear that Mr. Epstein did not accept the December
+modification, and accordingly, we will now consider that modification to be a nullity.
+Pursuant to our Agreement, I will prepare an Amended Notification that contains the name of additional
+identified victims. In accordance with Paragraph 7B, please provide me with a proposed written submission to
+the Special Master by Monday afternoon.
+Finally, as you are aware, yhe United States has been ordered to produce the Non-Prosecution Agreement. In
+accordance with that Order, we will produce the September Agreement with the October Addendum signed by
+your client. We understand that Mr. Goldberg may not have provided the state court with a true copy of the
+complete Agreement, and he should take steps to correct that error.
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Friday, August 15, 2008 11:42 AM
+To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Lee, Dexter (USAFLS); Atkinson, Karen
+(USAFLS)
+Subject: New proposed response to Jay
+Dear Jay:
+Thank you for your response. Our communications with Roy Black and later with you were solely to determine
+what Mr. Epstein considered to be the terms of the Non-Prosecution Agreement. You have now made clear that
+Mr. Epstein did not accept the December modification and does not intend to perform the obligations set forth
+therein. The Office is not going to continue negotiating the terms of the Agreement. We only sought finality
+and you have answered our question. Accordingly, the December proposed modification is hereby withdrawn.
+The United States has been ordered to produce the Non-Prosecution Agreement and, in accordance with that
+Order, will produce the September Agreement with the October Addendum signed by your client. Mr.
+Goldberger should be advised that we understand he has not provided the state court with a true copy of the
+complete Agreement, and he should take steps to correct that error. I will prepare an Amended Notification that
+contains the name of additional identified victims and will provide that to you promptly.
+In accordance with Paragraph 7B of the Agreement, please provide me with a proposed written submission to
+the Special Master by Monday afternoon. We will expect a showing of good faith in the selection of the
+1
+
+
+attorney representative and all other terms of the Agreement and excessive delays, like those that have occurred
+in the past, will be considered a breach of that duty of good faith.
+Sincerely,
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+2
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/f0c7efa7e6b8c4bf5d560a81583023da095714ade3b1ddb93c11e47c964b34a9.receipt.json b/vision-fixhub/ds9-unparsed-05/f0c7efa7e6b8c4bf5d560a81583023da095714ade3b1ddb93c11e47c964b34a9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..009039360a95761528df77aacf202121faadb54c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f0c7efa7e6b8c4bf5d560a81583023da095714ade3b1ddb93c11e47c964b34a9.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -226,
+  "dataset": "marble-joined",
+  "doc_id": "f0c7efa7e6b8c4bf5d560a81583023da095714ade3b1ddb93c11e47c964b34a9",
+  "engine": "marble-apple-vision",
+  "event_count": 11,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "e660c71fd918f148bad5ff9a0d817055c4ac4746f3c6e822666f958acba6804b",
+  "output_sha256": "14e8d2bcc54629260878aa1ab8937143c05680c6e8797b5880df68099d1e91d1",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/f11585e7a09025a5e21b7be4e02b9c74c81e3ed22face1eda893b9c12eba6e9f.md b/vision-fixhub/ds9-unparsed-05/f11585e7a09025a5e21b7be4e02b9c74c81e3ed22face1eda893b9c12eba6e9f.md
new file mode 100644
index 0000000000000000000000000000000000000000..7bf7aed91349714a6a42fe5964d192a039c9ea5f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f11585e7a09025a5e21b7be4e02b9c74c81e3ed22face1eda893b9c12eba6e9f.md
@@ -0,0 +1,103 @@
+
+G&PRINTTHIS
+PalmBeachPost.com
+UPDATED
+WEEKLY
+By Larry Keller
+Palm Beach Post Staff Writer
+Browse
+Specials
+Tuesday, August 08, 2006
+& Deals
+From Local
+Attorneys and publicists for Palm Beach financier Jeffrey Epstein went on the
+Dealerships
+offensive Monday, contending that teenage girls who have accused Epstein of
+sexual shenanigans at his waterfront home are liars and saying that the Palm Beach
+Police Department is "childish."
+Autos
+PalmBeachPost.com
+"There never was any sex between Jeffrey Epstein and any underage women," his lead attorney, Jack
+Goldberger, said from Idaho where he was vacationing with his family.
+• Letter from Palm Beach Chief Michael Reiter to State Attorney Barry Krischer Epstein did have young
+women come to his
+Jeffrey Epstein
+Billionaire
+financier
+Jeffrey
+Epstein has
+been indicted
+for felony solicitation of
+prostitution by a grand
+jury following
+accusations by teen girls.
+• Past headlines
+house to give him
+massages, Goldberger
+said. "Mr. Epstein
+absolutely insisted
+anybody who came to
+his house be over the
+age of 18. How he
+verified that, I don't
+know. The question is,
+did anything illegal
+occur. The law was not
+violated here."
+More local news
+Latest breaking news, photos and all of today's Post stories.
+Share This Story
+He had no explanation
+as to why Epstein
+would pay girls or
+women with no massage training — as the alleged victims said was the case — $200 to $300 for their
+visits. "The credibility of these witnesses has been seriously questioned," Goldberger said.
+Epstein, 53, was indicted by a county grand jury last month on a charge of felony solicitation of
+prostitution. After an 11-month investigation that included sifting through Epstein's trash and surveilling
+http://palmbeachpost.printthis.clickability.com/pt/cpt?action=cpt&title=Epstein+camp+calls.. 1/2/2008
+
+
+
+his home, Palm Beach police concluded there was enough evidence to charge him with sexual activity
+with minors. When the grand jury indicted Epstein on the less serious charge, Police Chief
+referred the case to the FBI to determine whether there were federal law violations.
+After a spate of stories about the case last week, New York publicist Dan Klores — whose client list has
+included Paris Hilton and Jennifer Lopez — said on Saturday that Epstein's camp was ready "to get their
+story out."
+They did that Monday via Goldberger and a Los Angeles publicist for Miami criminal defense attorney
+Roy Black, who also has represented Epstein in the case.
+"We just think there has been a distorted view of this case in the media presented by the Palm Beach
+police," Goldberger said.
+has consistently declined to comment on the case and did not respond to a request for comment
+Monday.
+The implication that State Attorney Barry Krischer was easy on Epstein by presenting the case to a
+grand jury rather than filing charges directly against him is wrong, Goldberger said
+The Palm Beach Police Department was "happy and estatic" that the panel was going to review the
+evidence. "I think what happened is they weren't happy with the result. They decided to use the press to
+embarrass Mr. Epstein."
+But records show tha
+wrote Krischer on May 1 — well before the case went to the grand jury —
+suggesting that Krischer "consider if good and suficient reason exists to require your disqualification
+from the prosecution of these cases."
+Rather than flat-out decline to charge Epstein, Krischer referred the case to the grand jury to "appease"
+the chief, Goldberger said.
+A state attorney's spokesman would say only that the office refers cases to the grand jury when there are
+issues with the viability of the evidence or witnesses' credibility.
+Both the state attorney and the grand jury concluded there was not sufficient evidence that Epstein had
+sex with minors, according to Goldberger. "It was just a childish performance by the Palm Beach Police
+Department," Goldberger said.
+The defense attorney said one of the alleged victims who claimed she was a minor was in fact over the
+age of 18. Another alleged vietim who was subpoenaed to testify to the grand jury failed to do so.
+Epstein's accusers, he added, have histories of drug abuse and thefts. "These women are liars. We've
+established that."
+But why would they all invent their stories about meeting Epstein for sexual massages?
+"I don't have an answer as to what was the motivation for these women to come forward and make these
+allegations," Goldberger said.
+http://palmbeachpost.printthis.clickability.com/pt/cpt?action=cpt&title=Epstein+camp+calls... 1/2/2008
+
+
+
+Find this article at:
+ttp://www.palmbeachpost.com/localnews/content/local_news/epaper/2006/08/08/s1b_epstein_0808.htm
+• Check the box to include the list of links referenced in the article.
+http://palmbeachpost.printthis.clickability.com/pt/cpt?action=cpt&title=Epstein+camp+calls... 1/2/2008
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/f11585e7a09025a5e21b7be4e02b9c74c81e3ed22face1eda893b9c12eba6e9f.receipt.json b/vision-fixhub/ds9-unparsed-05/f11585e7a09025a5e21b7be4e02b9c74c81e3ed22face1eda893b9c12eba6e9f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f22326f081461ef2f80bdd7d42b1d8c5b3596232
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f11585e7a09025a5e21b7be4e02b9c74c81e3ed22face1eda893b9c12eba6e9f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -234,
+  "dataset": "marble-joined",
+  "doc_id": "f11585e7a09025a5e21b7be4e02b9c74c81e3ed22face1eda893b9c12eba6e9f",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "fff19a3f97bfea2cc3272e7f7c838052e03e320822a3011aaef7d86ff2cae829",
+  "output_sha256": "ba01ab6db78c83508aff5ca26e13dff264afdbcfe79d5763dfd27d7470b6bcd3",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/f1a6d0497af1187cb3bc57d031033d336ebd76dc0e3800246b9476ab131c8b85.md b/vision-fixhub/ds9-unparsed-05/f1a6d0497af1187cb3bc57d031033d336ebd76dc0e3800246b9476ab131c8b85.md
new file mode 100644
index 0000000000000000000000000000000000000000..944f563699f1e8fb2eb32ed0b636d4a275a8cc14
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f1a6d0497af1187cb3bc57d031033d336ebd76dc0e3800246b9476ab131c8b85.md
@@ -0,0 +1,819 @@
+NON-PROSECUTION AGREEMENT
+IT APPEARING that the City of Palm Beach Police Department and the State
+Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter
+he "State Attorney's Office") have conducted an investigation into the conduct of Jeffre
+Epstein (hereinafter "Epstein");
+IT APPEARING that the State Attorney's Office has charged Epstein by indictment
+with solicitation of prostitution, in violation of Florida Statutes Section 796.07;
+IT APPEARING that the United States Attorney's Office and the Federal Bureau of
+Investigation have conducted their own investigation into Epstein's background and any
+offenses that may have been committed by Epstein against the United States from in or
+around 2001 through in or around September 2007, including:
+knowingly and willfully conspiring with others known and unknown to
+Code, Section 2422(b); all in violation of Title 18, United States Code, Section
+371;
+(2)
+knowingly and willfully conspiring with others known and unknown to travel
+(3)
+(4)
+Code, Section 2423(e);
+using a facility or means of interstate or foreign commerce to knowingly
+ersuade, induce, or entice minor females to engage in prostitution; i
+riolation of Title 18, United States Code, Sections 2422(b) and 2
+traveling in interstate commerce for the purpose of engaging in illicit sexual
+conduct, as defined in 18 U.S.C. § 2423(f), with minor females; in violation
+
+
+
+knowingly, in and affecting interstate and foreign commerce, recruiting,
+enticing, and obtaining by any means a person, knowing that the person had
+not attained the age of 18 years and would be caused to engage in a
+commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title
+18, United States Code, Sections 1591(a)(1) and 2; and
+IT APPEARING that Epstein seeks to resolve globally his state and federal criminal
+liability and Epstein understands and acknowledges that, in exchange for the benefits
+provided by this agreement, he agrees to comply with its terms, including undertaking certain
+actions with the State Attorney's Office;
+IT APPEARING, after an investigation of the offenses and Epstein's background by
+both State and Federal law enforcement agencies, and after due consultation with the State
+Attorney's Office, that the interests of the United States, the State of Florida, and the
+Defendant will be served by the following procedure;
+THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for
+the Southern District of Florida, prosecution in this District for these offenses shall be
+deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the
+following conditions and the requirements of this Agreement set forth below.
+If the United States Attorney should determine, based on reliable evidence, that,
+during the period of the Agreement, Epstein willfully violated any of the conditions of this
+Agreement, then the United States Attorney may, within ninety (90) days following the
+expiration of the term of home confinement discussed below, provide Epstein with timely
+notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its
+prosecution on any offense within sixty (60) days' of giving notice of the violation. Any
+notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the
+United States learning of facts which may provide a basis for a determination of a breach of
+the Agreement.
+After timely fulfilling all the terms and conditions of the Agreement, no prosecution
+for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have
+been the subject of the joint investigation by the Federal Bureau of Investigation and the
+United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury
+investigation will be instituted in this District, and the charges against Epstein if any, will be
+
+
+
+2.
+6.
+Epstein shall plead guilty (not nolo contendere) to the Indictment as
+currently pending against him in the 15th Judicial Circuit in and for
+Palm Beach County (Case No. 2006-cf-009495AXXXMB) charging
+one (1) count of solicitation of prostitution, in violation of FI. Stat. §
+796.07. In addition, Epstein shall plead guilty to an Information filed
+by the State Attorney's Office charging Epstein with an offense that
+'equires him to register as a sex offender, that is, the solicitation of
+ninors to engage in prostitution, in violation of Florida Statutes Sectiol
+796.03;
+Epstein shall make a binding recommendation that the Court impose a
+thirty (30) month sentence to be divided as follows:
+(a)
+Epstein shall be sentenced to consecutive terms of twelve (12)
+months and six (6) months in county jail for all charges, without
+any opportunity for withholding adjudication or sentencing, and
+vithout probation or community control in lieu o
+mprisonment; an
+(b)
+Epstein shall be sentenced to a term of twelve (12) months of
+community control consecutive to his two terms in county jail
+as described in Term 2(a), supra.
+This agreement is contingent upon a Judge of the 15th Judicial Circuit
+accepting and executing the sentence agreed upon between the State
+Attorney's Office and Epstein, the details of which are set forth in this
+agreement.
+The terms contained in paragraphs 1 and 2, supra, do not foreclose
+Epstein and the State Attorney's Office from agreeing to recommend
+any additional charge(s) or any additional term(s) of probation and/or
+incarceration.
+Epstein shall waive all challenges to the Information filed by the State
+Attorney's Office and shall waive the right to appeal his conviction an
+entence, except a sentence that exceeds what is set forth in paragrap
+Epstein shall provide to the U.S. Attorney's Office copies of all
+
+
+
+9.
+11.
+proposed agreements with the State Attorney's Office prior to entering
+into those agreements.
+The United States shall provide Epstein's attorneys with a list of
+individuals whom it has identified as victims, as defined in 18 U.S.C.
+select an attorney representative for these persons, who shall be paid for
+by Epstein. Epstein's counsel may contact the identified individuals
+through that representative.
+If any of the individuals referred to in paragraph (7), supra, elects to
+file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the
+jurisdiction of the United States District Court for the Southern District
+of Florida over his person and/or the subject matter, and Epstein waives
+his right to contest liability and also waives his right to contest damages
+up to an amount as agreed to between the identified individual and
+Epstein, so long as the identified individual elects to proceed
+exclusively under 18 U.S.C. § 2255, and agrees to waive any other
+claim for damages, whether pursuant to state, federal, or common law.
+Notwithstanding this waiver, as to those individuals whose names
+appear on the list provided by the United States, Epstein's signature on
+this agreement, his waivers and failures to contest liability and such
+damages in any suit are not to be construed as an admission of any
+criminal or civil liability.
+Epstein's signature on this agreement also is not to be construed as an
+admission of civil or criminal liability or a waiver of any jurisdictional
+or other defense as to any person whose name does not appear on the
+list provided by the United States.
+Except as to those individuals who elect to proceed exclusively under
+18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's
+ignature on this agreement, nor its terms, nor any resulting waivers o
+ettlements by Epstein are to be construed as admissions or evidence o
+civil or criminal liability or a waiver of any jurisdictional or other
+defense as to any person, whether or not her name appears on the list
+Epstein shall use his best efforts to enter his guilty plea and be
+
+
+
+sentenced not later than October 26, 2007. The United States has no
+objection to Epstein self-reporting to begin serving his sentence not
+later than January 4, 2008.
+12.
+Epstein agrees that he will not be afforded any benefits with respect to
+gain time, other than the rights, opportunities, and benefits as any other
+inmate, including but not limited to, eligibility for gain time credit
+based on standard rules and regulations that apply in the State of
+Florida. At the United States' request, Epstein agrees to provide ar
+accounting of the gain time he earned during his period of
+incarceration.
+13.
+The parties anticipate that this agreement will not be made part of any
+public record. If the United States receives a Freedom of Information
+Act request or any compulsory process commanding the disclosure of
+the agreement, it will provide notice to Epstein before making that
+disclosure.
+Epstein understands that the United States Attorney has no authority to require the
+State Attorney's Office to abide by any terms of this agreement. Epstein understands that
+it is his obligation to undertake discussions with the State Attorney's Office and to use his
+best efforts to ensure compliance with these procedures, which compliance will be necessary
+to satisfy the United States' interest. Epstein also understands that it is his obligation to use
+his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding
+recommendation regarding the sentence to be imposed, and understands that the failure to
+do so will be a breach of the agreement.
+In consideration of Epstein's agreement to plead guilty and to provide compensation
+in the manner described above, if Epstein successfully fulfills all of the terms and conditions
+of this agreement, the United States also agrees that it will not institute any criminal charges
+against any potential co-conspirators of Epstein, including but not limited to
+Further, upon execution of this
+agreement and a plea agreement with the State Attorney's Office, the federal Grand Jury
+investigation will be suspended, and all pending federal Grand Jury subpoenas will be held
+in abeyance unless and until the defendant violates any term of this agreement. The
+defendant likewise agrees to withdraw his pending motion to intervene and to quash certain
+grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence
+requested by or directly related to the grand jury subpoenas that have been issued, and
+including certain computer equipment, inviolate until all of the terms of this agreement have
+been satisfied. Upon the successful completion of the terms of this agreement, all
+outstanding grand jury subpoenas shall be deemed withdrawn.
+
+
+
+By signing this agreement, Epstein asserts and certifies that each of these terms is
+material to this agreement and is supported by independent consideration and that a breach
+of any one of these conditions allows the United States to elect to terminate the agreement
+and to investigate and prosecute Epstein and any other individual or entity for any and all
+federal offenses.
+By signing this agreement, Epstein asserts and certifies that he is aware of the fact that
+the Sixth Amendment to the Constitution of the United States provides that in all criminal
+prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further
+is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court
+may dismiss an indictment, information, or complaint for unnecessary delay in presenting
+a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein
+hereby requests that the United States Attorney for the Southern District of Florida defer such
+prosecution. Epstein agrees and consents that any delay from the date of this Agreement to
+the date of initiation of prosecution, as provided for in the terms expressed herein, shall be
+deemed to be a necessary delay at his own request, and he hereby waives any defense to such
+prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of
+the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the
+United States to a speedy trial or to bar the prosecution by reason of the running of the statute
+of limitations for a period of months equal to the period between the signing of this
+agreement and the breach of this agreement as to those offenses that were the subject of the
+grand jury's investigation. Epstein further asserts and certifies that he understands that the
+Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all
+felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees
+and consents that, if a prosecution against him is instituted for any offense that was the
+subject of the grand jury's investigation, it may be by way of an Information signed and filed
+by the United States Attorney, and hereby waives his right to be indicted by a grand jury as
+to any such offense.
+/1/
+
+
+
+By signing this agreement, Epstein asserts and certifies that the above has been read
+and explained to him. Epstein hereby states that he understands the conditions of this Non-
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+Ducat 9/2107
+_ ESQ.
+1, ESQ.
+
+
+
+By signing this agreement, Epstein asserts and certifies that the above has been read
+and explained to him. Epstein hereby states that he understands the conditions of this Non-
+UNITED STATES ATTORNEY
+Datcd:9/27/07
+By:
+ASSISTANT U.S. ATTORNEY
+Dated: 9/24/07
+ESQ.
+
+
+
+By signing this agreement, Epstein asserts and certifies that the above has been read
+and explained to him. Epstein hereby states that he understands the conditions of this Non-
+Prosecution Apreement and agrees to comply with them.
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+• ESQ.
+Dated: 9-24-07
+
+
+
+NON-PROSECUTION AGREEMENT
+IT APPEARING that the City of Palm Beach Police Department and the State
+Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter
+he "State Attorney's Office") have conducted an investigation into the conduct of Jeffre
+IT APPEARING that the State Attorney's Office has charged Epstein by indictment
+with solicitation of prostitution, in violation of Florida Statutes Section 796.07;
+IT APPEARING that the United States Attorney's Office and the Federal Bureau of
+Investigation have conducted their own investigation into Epstein's background and any
+oftenses that may have been committed by Epstein against the United States from in or
+around 2001 through in or around September 2007, including:
+(2)
+(3)
+knowingly and willfully conspiring with others known and unknown to
+commit an offense against the United States, that is, to use a facility or means
+minor females enge in prosition, in violation or i 13, United states
+Code, Section 2422(b); all in violation of Title 18, United States Code, Section
+371;
+knowingly and willfully conspiring with others known and unknown to travel
+in interstate commerce for the purpose of engaging in illicit sexual conduct, as
+defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18,
+United States Code, Section 2423(b); all in violation of Title 18, United States
+Code, Section 2423(e);
+using a facility or means of interstate or foreign commerce to knowingly
+ersuade, induce, or entice minor females to engage in prostitution; ir
+violation of Title 18. United States Code, Sections 2422(b) and 2:
+aveling in interstate commerce for the purpose of engaging in illicit sexu
+nduct, as defined in 18 U.S.C. § 2423(D, with minor females; in violatic
+
+
+
+(5)
+knowingly, in and affecting interstate and foreign commerce, recruiting,
+nticing, and obtaining by any means a person, knowing that the person ha
+ot attained the age of 18 years and would be caused to engage in
+commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title
+18, United States Code, Sections 1591(a)(1) and 2; and
+IT APPEARING that Epstein seeks to resolve globally his state and federal criminal
+liability and Epstein understands and acknowledges that, in exchange for the benefits
+provided by this agreement, he agrees to comply with its terms, including undertaking certain
+actions with the State Attorney's Office;
+IT APPEARING, after an investigation of the offenses and Epstein's background by
+both State and Federal law enforcement agencies, and after due consultation with the State
+Attorney's Office, that the interests of the United States, the State of Florida, and the
+Defendant will be served by the following procedure;
+THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for
+he Southern District of Florida, prosecution in this District for these offenses shall b
+eferred in favor of prosecution by the State of Florida, provided that Epstein abides by th
+following conditions and the requirements of this Agreement set forth below.
+If the United States Attorney should determine, based on reliable evidence, that,
+during the period of the Agreement, Epstein willfully violated any of the conditions of this
+Agreement, then the United States Attorney may, within ninety (90) days following the
+expiration of the term of home confinement discussed below, provide Epstein with timely
+notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its
+prosecution on any offense within sixty (60) days' of giving notice of the violation. Any
+notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the
+United States learning of facts which may provide a basis for a determination of a breach of
+the Agreement.
+After timely fulfilling all the terms and conditions of the Agreement, no prosecution
+for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have
+bein the sales At or mey in to mig ain by he Peara Burn or redial read re
+investigation will be instituted in this District, and the charges against Epstein if any, will be
+
+
+
+Epstein shall plead guilty (not nolo contendere) to the Indictment as
+urrently pending against him in the 15th Judicial Circuit in and fo
+'alm Beach County (Case No. 2006-cf-009495AXXXMB) chargins
+2.
+Epstein shall make a binding recommendation that the Court impose a
+thirty (30) month sentence to be divided as follows:
+Epstein shall be sentenced to consecutive terms of twelve (12)
+months and six (6) months in county jail for all charges, without
+any opportunity for withholding adjudication or sentencing, and
+without probation or community control in lieu of
+3.
+(b)
+Epstein shall be sentenced to a term of twelve (12) months of
+community control consecutive to his two terms in county jail
+as described in Term 2(a), supra.
+This agreement is contingent upon a Judge of the 15th Judicial Circuit
+ccepting and executing the sentence agreed upon between the Stat
+attorney's Office and Epstein, the details of which are set forth in thi
+agreement.
+The terms contained in paragraphs 1 and 2, supra, do not foreclose
+ipstein and the State Attorney's Office from agreeing to recommenc
+ny additional charge(s) or any additional term(s) of probation and/o
+incarceration.
+6.
+Epstein shall provide to the U.S. Attorney's Office copies of all
+
+•
+
+
+9.
+11.
+proposed agreements with the State Attorney's Office prior to enterin
+into those agreements
+BLETTE
+If any of the individuals referred to in paragraph (7), supra, elects to
+file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the
+jurisdiction of the United States District Court for the Southern District
+of Florida over his person and/or the subject matter, and Epstein waives
+his right to contest liability and also waives his right to contest damages
+up to an amount as agreed to between the identified individual an
+Epstein, so long as the identified individual elects to proceec
+exclusively under 18 U.S.C. § 2255, and agrees to waive any other
+claim for damages, whether pursuant to state, federal, or common law.
+Notwithstanding this waiver, as to those individuals whose names
+appear on the list provided by the United States, Epstein's signature on
+this agreement, his waivers and failures to contest liability and such
+damages in any suit are not to be construed as an admission of any
+criminal or civil liability.
+Epstein's signature on this agreement also is not to be construed as an
+admission of civil or criminal liability or a waiver of any jurisdictional
+or other defense as to any person whose name does not appear on the
+list provided by the United States
+Epstein shall use his best efforts to enter his guilty plea and be
+
+
+
+12.
+Later than Janupstein 0- reporting to begin serving his sentence not
+Epstein agrees that he will not be afforded any benefits with respect to
+Florida. At the United States' request, Epstein agrees to provide an
+accounting of the gain time he earned during his period of
+13.
+The parties anticipate that this agreement will not be made part of any
+public record. If the United States receives a Freedom of Information
+Act request or any compulsory process commanding the disclosure of
+the agreement, it will provide notice to Epstein before making that
+disclosure.
+Epstein understands that the United States Attorney has no authority to require the
+State Attorney's Office to abide by any terms of this agreement. Epstein understands that
+it is his obligation to undertake discussions with the State Attorney's Office and to use his
+best efforts to ensure compliance with these procedures, which compliance will be necessary
+to satisfy the United States' interest. Epstein also understands that it is his obligation to use
+his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding
+recommendation regarding the sentence to be imposed, and understands that the failure to
+do so will be a breach of the agreement.
+In consideration of Epstein's agreement to plead guilty and to provide compensation
+in the manner described above, if Epstein successfully fulfills all of the terms and conditions
+of this agreement, the United States also agrees that it will not institute any criminal charges
+against any potential co-conspirators of Enstein, including but not limited to
+or
+Further, upon execution of this
+agreement and a plea agreement with the State Attorney's Office, the federal Grand Jury
+vestigation will be suspended, and all pending federal Grand Jury subpoenas will be he
+1 abevance unless and until the defendant violates any term of this agreement. TI
+
+
+
+By signing this agreement, Epstein asserts and certifies that each of these terms is
+naterial to this agreement and is supported by independent consideration and that a breac
+fany one of these conditions allows the United States to elect to terminate the agreemer
+and to investigate and prosecute Epstein and any other individual or entity for any and all
+federal offenses.
+By signing this agreement, Epstein asserts and certifies that he is aware of the fact that
+the Sixth Amendment to the Constitution of the United States provides that in all criminal
+prosecutions the accused shall enjoy the right to a specdy and public trial. Epstein further
+is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court
+may dismiss an indictment, information, or complaint for unnecessary delay in presenting
+a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein
+hereby requests that the United States Attorney for the Southern District of Florida defer such
+prosecution. Epstein agrees and consents that any delay from the date of this Agreement to
+the date of initiation of prosecution, as provided for in the terms expressed herein, shall be
+deemed to be a necessary delay at his own request, and he hereby waives any defense to such
+prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of
+the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the
+United States to a speedy trial or to bar the prosecution by reason of the running of the statute
+of limitations for a period of months equal to the period between the signing of this
+agreement and the breach of this agreement as to those offenses that were the subject of the
+grand jury's investigation. Epstein further asserts and certifies that he understands that the
+Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all
+felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees
+and consents that, if a prosecution against him is instituted for any offense that was the
+subject of the grand jury's investigation, it may be by way of an Information signed and filed
+by the United States Attorney, and hereby waives his right to be indicted by a grand jury as
+to any such offense.
+1/1
+///
+
+
+
+By signing this agreement, Epstein asserts and certifies that the above has been read
+ad explained to him. Epstein hereby states that he understands the conditions of this Nor
+rosecution Agreement and agrees to comply with thei
+UNITED STATES ATTORNEY
+Da. 12r107
+By:
+ASSISTANT U.S. ATTORNEY
+ESQ.
+JESQ.
+ATTORNEY FOR JEFFREY EPSTEN
+
+
+
+By signing this agrecment, Epstein asserts and certifies that the above has been re
+ro explain A trement and in hereby satep that he uherstands the conditions of this Nor
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+Darod: 9/24/07
+
+
+
+By signing this agreement, Epstein asserts and certifies that the above has been read
+Prosecution Agriment and agre by comply wite understand the conditions of this Non-
+UNITED STATES ATTORNEY
+By:
+ASSISTANT U.S. ATTORNEY
+ESQ.
+Dated: 9-24-07
+!
+
+
+
+ADDENDUM TO THE NON-PROSECUTION AGREEMENT
+IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7
+of the Non-Prosecution Agreement (hereinafter "paragraph 7"'), that agreement is modified as
+7A. The United States has the right to assign to an independent third-party the responsibility
+for consulting with and, subject to the good faith approval of Epstein's counsel, selecting
+the attorney representative for the individuals identified under the Agreement. If the
+United States elects to assign this responsibility to an independent third-party, both the
+United States and Epstein retain the right to make good faith objections to the attorney
+representative suggested by the independent third-party prior to the final designation of
+the attorney representative.
+7B.
+The parties will jointly prepare a short written submission to the independent third-party
+regarding the role of the attorney representative and regarding Epstein's Agreement to
+pay such attorney representative his or her regular customary hourly rate for representing
+such victims subject to the provisions of paragraph C, infra.
+7C.
+Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision, however, shall not
+obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus,
+if after consideration of potential settlements, an attorney representative elects to file a
+contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested
+remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay reasonable
+attorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney
+representative, shall cease.
+
+
+Das 121/7
+Dated:_
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+Ã. MARJE VILLAFANA
+ASSISTANT U.S. ATTORNEY
+EFFREY EPSTEIN
+GERALD LEFCOURT, ESQ.
+
+
+By signing this Addendum, Epstein asserts and certifies that the above has been read and
+explained to him. Epstein hereby states that he understands the clarifications to the Non-
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+À. MARIE VILLAFANA
+ASSISTANT U.S. ATTORNEY
+Dia 0/89/07
+
+
+By signing this Addendum, Epstein asserts and certifies that the above has been read and
+Poleined firement acd treby sae hat he understands the clarifications to the Non-
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+À. MARIE VILLAFANA
+ASSISTANT U.S. ATTORNEY
+GERALD LEFCOURT, ESQ.
+Dated: 10-29-07
+LILLY ANN SANCHEZ, ESO:
+
+
+NON-PROSECUTION AGREEMENT
+IT APPEARING that the State Attorney's Office has charged Epstein by indictment
+with solicitation of prostitution, in violation of Florida Statutes Section 796.07;
+IT APPEARING that the United States Attorney's Office and the Federal Bureau of
+Investigation have conducted their own investigation into Epstein's background and any
+offenses that may have been committed by Epstein against the United States from in or
+around 2001 through in or around September 2007, including:
+(1) knowingly and willfully conspiring with others known and unknown to
+commit an offense against the United States, that is, to use a facility or means
+of interstate or foreign commerce to knowingly persuade, induce, or entice
+minor females to engage in prostitution, in violation of Title 18, United States
+Code, Section 2422(b); all in violation of Title 18, United States Code, Section
+371;
+(2)
+knowingly and willfully conspiring with others known and unknown to travel
+in interstate commerce for the purpose of engaging in illicit sexual conduct, as
+defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18,
+United States Code, Section 2423(b); all in violation of Title 18, United States
+Code, Section 2423(e);
+(3)
+using a facility or means of interstate or foreign commerce to knowingly
+persuade, induce, or entice minor females to engage in prostitution; in
+violation of Title 18, United States Code, Sections 2422(b) and 2;
+(4)
+traveling in interstate commerce for the purpose of engaging in illicit sexual
+'onduct, as defined in 18 U.S.C. § 2423(1), with minor females; in violation
+
+
+
+(5)
+knowingly, in and affecting interstate and foreign commerce, recruiting,
+nticing, and obtaining by any means a person, knowing that the person ha
+ot attained the age of 18 years and would be caused to engage in
+commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title
+18, United States Code, Sections 1591(a)(1) and 2; and
+IT APPEARING that Epstein seeks to resolve globally his state and federal criminal
+liability and Epstein understands and acknowledges that, in exchange for the benefits
+provided by this agreement, he agrees to comply with its terms, including undertaking certain
+actions with the State Attorney's Office;
+IT APPEARING, after an investigation of the offenses and Epstein's background by
+both State and Federal law enforcement agencies, and after due consultation with the State
+Attorney's Office, that the interests of the United States, the State of Florida, and the
+Defendant will be served by the following procedure;
+THEREFORF, on the authority of R. Alexander Acosta, United States Attorney for
+he Southern District of Florida
+etered in fa Dorot prosecution a prostate or florida provided there onese bulle
+following conditions and the requirements of this Agreement set forth below.
+If the United States Attomey should determine, based on reliable evidence, that,
+during the period of the Agreement, Epstein willfully violated any of the conditions of this
+Agreement, then the United States Attorney may, within ninety (90) days following the
+expiration of the term of home confinement discussed below, provide Epstein with timely
+notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its
+prosecution on any offense within sixty (60) days' of giving notice of the violation. Any
+notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the
+United States learning of facts which may provide a basis for a determination of a breach of
+the Agreement.
+After timely fulfilling all the terms and conditions of the Agreement, no prosecution
+Ior the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have
+been the subject of the joint investigation by the Federal Bureau of Investigation and the
+United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury
+investigation will be instituted in this District, and the charges against Epstein if any, will be
+
+
+
+Epstein shall plead guilty (not nolo contendere) to the Indictment as
+Palm Beach County (Case No. 2006-cf-009495AXXXMB) charging
+one (1) count of solicitation of prostitution, in violation of Fl. Stat. §
+796.07. In addition, Epstein shall plead guilty to an Information filec
+by the State Attorney's Office charging Epstein with an offense that
+requires him to register as a sex offender, that is, the solicitation of
+minors to engage in prostitution, in violation of Florida Statutes Sectior
+2.
+4.
+6.
+Epstein shall make a binding recommendation that the Court impose a
+thirty (30) month sentence to be divided as follows:
+Epstein shall be sentenced to consecutive terms of twelve (12)
+months and six (6) months in county jail for all charges, without
+any opportunity for withholding adjudication or sentencing, and
+without probation or community control in lieu of
+(b)
+Epstein shall be sentenced to a term of twelve (12) months of
+community control consecutive to his two terms in county jail
+as described in Term 2(a), supra.
+This agreement is contingent upon a Judge of the 15th Judicial Circuit
+Atoniy and rei pete hence ired upon recente Stic
+agreement.
+The terms contained in paragraphs 1 and 2, supra, do not foreclose
+Epstein and the State Attorney's Office from agreeing to recommenc
+any additional charge(s) or any additional term(s) of probation and/o
+incarceration.
+Epstein shall waive all challenges to the Information filed by the State
+Attorney's Office and shall waive the right to appeal his conviction anc
+sentence, except a sentence that exceeds what is set forth in paragraph
+Epstein shall provide to the U.S. Attorney's Office copies of all
+
+
+
+11.
+proposed agreements with the State Attorney's Office prior to entering
+into those agreements.
+If any of the individuals referred to in paragraph (7), supra, elects to
+file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the
+jurisdiction of the United States District Court for the Southern District
+Notwithstanding this waiver, as to those individuals whose name
+appear on the list provided by the United States, Epstein's signature or
+this agreement, his waivers and failures to contest liability and such
+damages in any suit are not to be construed as an admission of any
+criminal or civil liability.
+Epstein's signature on this agreement also is not to be construed as an
+admission of civil or criminal liability or a waiver of any jurisdictional
+er other defense as to any person whose name does not appear on th
+ist provided by the United State
+Epstein shall use his best efforts to enter his guilty plea and be
+
+
+
+sentenced not later than October 26, 2007. The United States has no
+objection to Epstein self-reporting to begin serving his sentence not
+later than January 4, 2008.
+12.
+Epstein agrees that he will not be afforded any benefits with respect to
+gain time, other than the rights, opportunities, and benefits as any other
+inmate, including but not limited to, eligibility for gain time credit
+based on standard rules and regulations that apply in the State of
+Florida. At the United States' request, Epstein agrees to provide an
+accounting of the gain time he earned during his period of
+13.
+The parties anticipate that this agreement will not be made part of any
+public record. If the United States receives a Freedom of Information
+Act request or any compulsory process commanding the disclosure of
+the agreement, it will provide notice to Epstein before making that
+disclosure.
+Epstein understands that the United States Attorney has no authority to require the
+State Attorney's Office to abide by any terms of this agreement. Epstein understands that
+it is his obligation to undertake discussions with the State Attorney's Office and to use his
+best efforts to ensure compliance with these procedures, which compliance will be necessary
+to satisfy the United States' interest. Epstein also understands that it is his obligation to use
+his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding
+recommendation regarding the sentence to be imposed, and understands that the failure to
+do so will be a breach of the agreement.
+In consideration of Epstein's agreement to plead guilty and to provide compensation
+in the manner described above, if Epstein successfully fulfills all of the terms and conditions
+of this agreement, the United States also agrees that it will not institute any criminal charges
+against any potential co-conspirators of Epstein, including but not limited to
+Further, upon execution of this
+agreement and a plea agreement with the State Altorney's Office, the federal Grand Jury
+investigation will be suspended, and all pending federal Grand Jury subpoenas will be held
+in abeyance unless and until the defendant violates any term of this agreement. The
+defendant likewise agrees to withdraw his pending motion to intervene and to quash certain
+grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence
+requested by or directly related to the grand jury subpoenas that have been issued, and
+including certain computer equipment, inviolate until all of the terms of this agreement have
+been satisfied. Upon the successful completion of the terms of this agreement, all
+outstanding grand jury subpoenas shall be deemed withdrawn.
+
+
+
+By signing this agreement, Epstein asserts and certifies that each of these terms is
+material to this agreement and is supported by independent consideration and that a breach
+of any one of these conditions allows the United States to elect to terminate the agreement
+and to investigate and prosecute Epstein and any other individual or entity for any and all
+federal offenses.
+By signing this agreement, Epstein asserts and certifies that he is aware of the fact that
+the Sixth Amendment to the Constitution of the United States provides that in all criminal
+prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein furthe
+is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Cour
+may dismiss an indictment, information, or complaint for unnecessary delay in presenting
+a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein
+hereby requests that the United States Attorney for the Southern District of Florida defer such
+prosecution. Epstein agrees and consents that any delay from the date of this Agreement to
+the date of initiation of prosecution, as provided for in the terms expressed herein, shall be
+deemed to be a necessary delay at his own request, and he hereby waives any defense to such
+prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of
+the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the
+United States to a speedy trial or to bar the prosecution by reason of the running of the statute
+of limitations for a period of months equal to the period between the signing of this
+agreement and the breach of this agreement as to those offenses that were the subject of the
+grand jury's investigation. Epstein further asserts and certifies that he understands that the
+Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all
+felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees
+and consents that, if a prosecution against him is instituted for any offense that was the
+subject of the grand jury's investigation, it may be by way of an Information signed and filed
+by the United States Attorney, and hereby waives his right to be indicted by a grand jury as
+to any such offense.
+///
+
+
+
+By signing this agreement, Epstein asserts and certifies that the above has been read
+and explained to him. Epstein hereby states that he understands the conditions of this Non-
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Deal 1er1o7
+By:
+A. MARIE VILLAFAÑA
+ASSISTANT U.S. ATTORNEY
+GERALD LEFCOURT, ESQ.
+
+
+
+Dared: 9/24/07
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+À. MARIE VILLAFANA
+ASSISTANT U.S. ATTORNEY
+Send front
+
+
+
+By signing this agreement, Epstein asserts and certifies that the above has been read
+and explained to him. Epstein hereby states that he understands the conditions of this Non-
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+À. MARIE VILLAFAÑA
+ASSISTANT U.S. ATTORNEY
+GERALD LEFCOURT, ESQ.
+Dated: 9-24-07
+ILLY ANN SAI
+Z, ESQ.
+
+
+
+ADDENDUM TO THE NON-PROSECUTION AGREEMENT
+IT APPEARING that the parties seck to clarity certain provisions of page 4, paragraph
+›f the Non-Prosecution Agreement (hereinafter "paragraph 7"'), that agreement is modified a:
+follows:
+7A. The United States has the right to assign to an independent third-party the responsibility
+for consulting with and, subject to the good faith approval of Epstein's counsel, selecting
+the attorney representative for the individuals identified under the Agreement. If the
+United States elects to assign this responsibility to an independent third-party, both the
+United States and Epstein retain the right to make good faith objections to the attorney
+representative suggested by the independent third-party prior to the final designation of
+the attorney representative.
+7B.
+The parties will jointly prepare a short written submission to the independent third-party
+regarding the role of the attorney representative and regarding Epstein's Agreement to
+pay such attorney representative his or her regular customary hourly rate for representing
+such victims subject to the provisions of paragraph C, infra.
+7C.
+Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision, however, shall not
+obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus,
+if after consideration of potential settlements, an attorney representative elects to file a
+contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested
+remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney
+representative, as opposed to any statutory or other obligations to pay reasonable
+attorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney
+representative, shall cease.
+
+
+By signing this Addendum, Epstein asserts and certifies that the above has been read anc
+xplained to him. Epstein hereby, states that he understands the clarifications to the Non
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Das: /1/21/7
+By:
+À. MARIE VILLAPAÑA
+ASSISTANT U.S. ATTORNEY
+VETEREY EPSTEIN
+Dated: _
+GERALD LEFCOURT, ESQ.
+
+
+By signing this Addendum, Epstein asserts and certifies that the above has been read an
+xplained to him. Epstein hereby states that he understands the clarifications to the Not
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+À. MARIE VILLAFAÑA
+ASSISTANT U.S. ATTORNEY
+Da 0/89/07
+Dated: _
+LILLY ANN SANCHEZ, ESO.
+
+
+By signing this Addendum, Epstein asserts and certifies that the above has been read ar
+plained to him. Epstein hereby states that he understands the clarifications to the No
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+A. MARIE VILLAFAÑA
+ASSISTANT U.S. ATTORNEY
+Dated: _
+JEFFREY EPSTE
+GERALD LEFCOURT, ESQ.
+Dated: 10-29-07
+ILLY ANN SANCHEZ, BSO
+
+
+Dac-07-07
+04:55pm
+From-Fowler-White Burnett
+
+T-REE P.003/0D4 F-Q76
+Affirmation
+I, Jery B. Epstein do hereby ro affirm the No-Proscoution Agreement and Adenduma to
+same dated October 30, 2007,
+Dato
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/f1a6d0497af1187cb3bc57d031033d336ebd76dc0e3800246b9476ab131c8b85.receipt.json b/vision-fixhub/ds9-unparsed-05/f1a6d0497af1187cb3bc57d031033d336ebd76dc0e3800246b9476ab131c8b85.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d65519f99cdc54b07d99be0ad55bcd1a4d611b98
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f1a6d0497af1187cb3bc57d031033d336ebd76dc0e3800246b9476ab131c8b85.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -3056,
+  "dataset": "marble-joined",
+  "doc_id": "f1a6d0497af1187cb3bc57d031033d336ebd76dc0e3800246b9476ab131c8b85",
+  "engine": "marble-apple-vision",
+  "event_count": 65,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "8f24e31d20a720cfd0c24162ec1b1fb76c4eba25e5fe8a9d1a4ea2091fc99171",
+  "output_sha256": "2dd5b39b5a761f383bcbe5ea5b94ba376b922c3906593c9c46d803fcdb6dc07b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/f2ff887cd5396d5f35f3c61ab7a1583413193d800f768d2b87ee8d861afe4e14.md b/vision-fixhub/ds9-unparsed-05/f2ff887cd5396d5f35f3c61ab7a1583413193d800f768d2b87ee8d861afe4e14.md
new file mode 100644
index 0000000000000000000000000000000000000000..415227ac5d5ad2dc5a0ee36ea008c5b5ffed1ba9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f2ff887cd5396d5f35f3c61ab7a1583413193d800f768d2b87ee8d861afe4e14.md
@@ -0,0 +1,5509 @@
+Statements
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+(212)272-4605
+www.bearstearns.com
+What's In This Statement
+Financial Summary ••••••••••••••••••••••I/I/
+Your Portfolio Holdings
+Transaction Detail
+Your Messages
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30, 2001
+3
+4
+7
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+21,096,865
+1,309,037
+$22,405,902
+22,315,774
+90,128
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$1.309.037
+$22,074
+Cash & Equivalent
+Equities
+$21,096,865
+$22,293,700
+Current market value
+Last statement's market value
+Important Message
+If any information regarding
+2001 interest, dividends,
+miscellaneous income,
+gross proceeds or original
+issue discount is required
+to be reported to the IRS for
+Chinsolidated Form 1099
+will be mailed to you by
+Da March 152022: 10425
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Sorvices at Bear, Steams Securities
+Corp.. One Metrolech Center North, Brooklyn, N.Y. 11201-3659.
+SP The suremen s foul ratanal purger red de Set revere dise for portant iformation.
+
+
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+
+
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+2,074.3
+... ....
+1,246,916.68
+40,046.42
+$1,286,963.10
+•........
+1,286,963.10
+51.309.037.42
+Income Summary
+Dividends
+Credit Balance Int.
+Total L
+THIS PERIOD
+40,010.00
+36.42
+$40.046.42
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+total.
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+22,074.32
+$22,074.32
+CLOSING
+1,309,037.42
+$1,309,037.42
+027
+YEAR TO DATE
+308,515.00
+8,239.66
+$316,754.66
+1,309,037
+21,096,865
+822.405.902
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+5%
+Equities
+95%
+Unshaded portions denote debe balance andor short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AMERICAN HOME PRODUCTS CORP
+....
+AMERICAN INTERNATIONAL GROUP
+INC
+•..........•
+BANK OF AMER CORP
+........
+CITIGROUP INC
+GOLDMAN SACHS GROUP INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JP MORGAN CHASE & CO
+JOHNSON& JOHNSON
+....
+MBNA CORP
+PFIZER INC
+.. . .
+PROCTER & GAMBLE CO
+........ .
+VIACOM INC-CL B
+Total Equities& Options
+TOTAL EQUITIES
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SIMBOUCUSIP
+QUANTITY
+PRICE
+SYMBOLCUSIP
+AHP
+AIG
+BAC
+GS
+JPM
+JNU
+KRB
+PFE
+PG
+VIAB
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+......
+ASH
+CASH
+CASH
+CASH
+QUANTITY
+24,000
+......
+20,000
+25,000
+15,000
+12,000
+10,000
+37,500
+50,000
+.. . .
+70,000
+75,000
+...
+25,000
+37,000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30,2001
+MARKE
+/ALUE
+1.309.037
+$1,309,037
+MAURE INE
+CURRE
+ELD I
+PRICE
+61.3600
+79.4000
+62.9500
+50.4800
+92.7500
+120.9600
+36.3500
+59.1000
+....
+35.2000
+39.8500
+.......
+9.1301
+44.1500
+MARKET
+VALTE
+1,472,640
+1,588,000
+1,573,750
+757,200
+1,113,000
+1,209,600
+1,363,125
+2,955,000
+2,464,000
+2,988,750
+1,978.250
+......
+1,633,550
+$21,096,865
+$21,096,865
+027
+ESTIMATED
+ANNUAL INCOME
+22,080
+3,360
+60,000
+9,600
+5,760
+5,600
+51,000
+36,000
+25,200
+39,000
+18,000
+$295,600
+$295,600
+CURRENT
+YIELD IN
+1.4993
+....
+0.2116
+3.8125
+1.2678
+0.5175
+.....
+0.4630
+3.7414
+1.2183
+...
+1.0221
+1.3049
+.....
+.920
+
+
+5 ol7
+OFFICE SERVICING YOUR ACOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SEEN TRE
+TRANSACTION
+12/18/01 12/13/01
+SOLD
+DIVIDENDS
+DATE
+12/03/01
+AMERICAN HOME PRODUCTS CORP
+REC 11/13/01 PAY 12/01/01
+12/06/01
+REC 11/16/01 PAY 12/06/01
+BRISTOL MYERS SQUIBB CO
+WITH RIGHTS TO PURCHASE PREFRO
+STK UNDER CERTAIN CIRCUMSTANCE
+SYMBOUCUSIP
+AHP
+*PFE
+$295,600
+$22,405,902
+SYMBOLCUSP
+BMY
+QUANTITY
+-25,000
+PRICE
+50.16890
+QUANTITY
+24,000
+75,000
+RATE (S
+0.2300
+0.1100
+DEBIT AMOUNT
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30, 2001
+DEBIT AMOUNT
+CREDIT AMOUNT
+1,246,916.68
+$1,246,916.68
+CREDIT AMOUNT
+5,520.00
+8,250.00
+
+
+OFFICE SERVICING YOUR ACOUNT
+Transaction Detail (continued)
+DIVIDENDS (continued)
+DATE
+12/11/01
+INTERNATIONAL BUSINESS
+MACHINES CORP
+12/17701
+REC 11/09/01 PAY 12/10/01
+"JÖHNSON& JÖHNSÖN"
+REC 11/20/01 PAY 12/11/01
+
+*'"AMERICAN INTERNATIONAL GROUP"
+INC 120701 PAY 1221101
+1228/01
+BANK OF AMER CORP
+REC 12/07/01 PAY 12/28/01
+INTEREST
+DATE
+12/21.01
+INTEREST ON CREDIT BALANCE
+AT O 1/2% 11/21 THRU 12/10
+122101 NOT TECT A 922CE
+SYMBOL/CUSIP
+IBM
+AIG
+BAC
+SYMBOL/CUSIP
+QUANTITY
+10,000
+50,000*
+20,000*
+25,000
+QUANTITY
+RATE (S)
+0.1400
+0:1800
+*0.0420
+0.6000
+RATE (%)
+0.5000
+0.2500
+120
+DEBIT AMOUNT
+DEBIT AMOUNT
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+November 30, 2001
+CREDIT AMOUNT
+1,400.00
+9,000.00
+840.00
+15,000.00
+$40,010.00
+CREDIT AMOUNT
+7.23
+29.19
+$36.42
+
+
+Bear, Stears & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+Your messages
+As part of the National Association of Securities Dealers (NASD)
+STOP
+****** End of Statement******
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30, 2001
+027
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+... .
+Transaction Detail
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD October 27, 2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 26,2001
+3
+4
+5
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+22,293,700
+22,074
+$22,315,774
+21,659,264
+656,510
+There are no "Stop Loss' orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$22,074
+$162.339
+Cash & Equivalent
+Equities
+$22,293,700
+# $21,496,925
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as delivered to you.
+to Client Services at 800-634-1428; or Write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3659.
+SIP The surenes four or ratanal purposes red de Set revere date for portant iformation.
+12/01/01:10:46 001
+
+
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+12/01/01:10:46 001
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Securities Bought
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERICO
+5162,339.12
+32,819.69
+$32,819.69
+-173,084.49
+-173.084.4
+.. . .
+-140,264.80
+$22.074.32
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+32,725.00
+94.69
+532.819.69
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+total.
+Cash Balance Summary
+Cash
+let Cash Balance
+•...
+OFENING
+162,339.12
+$162,339.12
+••••••••••••••••••••.
+CLOSING
+22,074.32
+!!!!
+$22,074.32
+027
+YEAR TO DATE
+268,505.00
+8,203.24
+... . .
+$276,708.24
+.....
+22,074
+22,293,700
+$22.315.774
+1201/01;10:46 001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD October 27, 2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 26,2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+<1%
+- Equities
+99%
+Unshaded portions denote debit balance and or shart
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AMERICAN HOME PRODUCTS CORP
+...
+AMERICAN INTERNATIONAL GROUP
+INC
+...
+BANK OF AMER CORP
+BRISTOL MYERS SQUIBB CO
+CITIGROUP INC
+GOLDMAN SACHS GROUP INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JP MORGAN CHASE & CO
+.. ...
+JOHNSON& JOHNSON
+MBNA CORP
+... ..
+PFIZER INC
+.................--------.
+PROCTER & GAMBLE CO
+VIACOM INC-CL B
+Total Equities& Options
+TOTAL EQUITIES
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SIMBOUCUSIP
+QUANTITY
+PRICE
+SYMBOLICUSIP
+AHP
+AIG
+BAC
+BMY
+C
+GS
+IBM
+JPM
+....
+JNJ
+KRB
+PFE
+•......
+PG
+VIAB
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+.. . .
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+24,000
+.......
+20,000
+25,000
+25,000
+15,000
+12,000
+10,000
+37,500
+.. . .
+50,000
+70,000
+......
+75,000
+... .
+25,000
+37,000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD October 27, 2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 26,2001
+MARKE
+VALUE
+22.074
+$22,074
+ANAL INTE
+CURRE
+ELD I
+PRICE
+60.1000
+82.4000
+61.3800
+53.7600
+47.9000
+88.9000
+115.5900
+37.7200
+... ..
+58.2500
+32.2400
+......
+43.3100
+....
+77.4600
+43.6500
+MARKET
+VALUE
+1,442,400
+1,648,000
+1,534,500
+1,344,000
+718,500
+1,066,800
+1,155,900
+1,414,500
+....
+2,912,500
+2,256,800
+3,248,250
+1,936,500
+1,615,050
+$22,293,700
+$22,293,700
+027
+ESTIMATED
+ANNUAL INCOM
+22,080
+3,360
+60,000
+27,500
+9,600
+5,760
+5,600
+51,000
+....
+36,000
+38,000
+$317,100
+$317,100
+1201/01:10:46 001
+CURRENT
+YIELD IN
+1.5308
+0.2039
+3.9101
+2.0461
+1.3361
+0.5399
+04845
+3.6055
+......
+1.2361
+1.1166
+......
+1.0159
+.. . ..
+1.9623
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SETILEMENT TRADE
+DATE
+11/13/01
+DATE
+TRANSACTION
+11/07/01
+BOUGHT
+DIVIDENDS
+DATE
+10/31/01
+TEC 100501 PA 1013001
+11701/01 "BRISTOL MYERS SQUiBE CO"
+REC 10/05/01 PAY 11/01/01
+GOLDMAN SACHS GROUP INO
+UNSOLICITEC
+SYMBOUCUSIP
+JPM
+''''MY
+$317,100
+$22,315,774
+SYMBOLGUSIP
+GS
+QUANTITY
+2,000
+PRICE
+86.00000
+QUANTITY
+RATE (S)
+37,500
+0.3400
+''25,000*•••0.2750
+DEBIT AMOUNT
+027
+12/01/01:10:46 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD October 27,2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 26,2001
+DEBIT AMOUNT
+173,084.49
+$-173,084.49
+CREDIT AMOUNT
+CREDIT AMOUNT
+12,750.00
+6,875.00
+
+
+6 of B
+Transaction Detail (continued)
+DIVIDENDS (continued)
+DATE
+11/15/01
+PROCTER & GAMBLE CO
+REC 10/19/01 PAY 11/15/01
+1920001'CHGROUP INC.--
+REC 11/05/01 PAY 11/21.01
+11/26/01
+"GOLDMAN SACHS GROUP INC
+REC 10/29/01 PAY 11/26/01
+INTEREST
+DATE
+11/21/01
+11/21/01
+101 INTEREST ON CREDIT BALANCE
+AT 1.000% 10/21 THRU 11/05
+SYMBOUCUSIP
+PG
+'GS
+QUANTITY
+RATE (S)
+25,000
+0.3800
+15,0000.1600
+10,000
+0.1200
+SYMBOLICUSIP
+QUANTITY
+RATE (SI
+0.5000
+1.0000
+STOP
+****** End of Statement******
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+1201/01;10:46 001
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD October 27, 2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 26,2001
+CREDIT AMOUNT
+9,500.00
+2,400.00
+1,200.00
+$32,725.00
+CREDIT AMOUNT
+19.47
+75.22
+$94.69
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary .••••••••••••••••••I/I/
+Your Portfolio Holdings
+Transaction Detail
+Your Messages
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 28, 2001
+3
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+21,496,925
+162,339
+$21,659,264
+NET EQUITY THIS PERIOD
+....
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+20,515,575
+1,143,689
+here are no Stop Loss" orders or other pending bu
+r sell open orders on file for your accoun
+Market Value of Your Portfolio
+$162.339
+$797,400
+Cash & Equivalent
+Equities
+$21,496,925
+$19,718,175
+Current market value
+Last statement's market value
+Flease raport any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four or ratanal purger red de Set revere dae for portant iformation.
+10/27/01;09:11001
+
+
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+10/27/01:09:11 001|
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Securities Bought
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERIOD
+5797.400.32
+6,806.59
+$6,806.59
+-641,867.79
+- 641,867.74
+-635,061.20
+5162,339.12
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+6,300.00
+506.59
+56.806.59
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+let Cash Balance
+OFENING
+797,400.32
+$797,400.32
+CLOSING
+162,339.12
+5162.33.12
+027
+YEAR TO DATE
+235,780.00
+8,108.55
+$243,888.55
+162,339
+21,496,925
+$21,659,264
+10/27/01:09:11001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 28, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+<1%
+- Equities
+99%
+Unshaded portions denote debe balance andor short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AMERICAN HOME PRODUCTS CORP
+...
+AMERICAN INTERNATIONAL GROUP
+INC
+...
+BANK OF AMER CORP
+BRISTOL MYERS SQUIBB CO
+CITIGROUP INC
+GOLDMAN SACHS GROUP INC
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JP MORGAN CHASE & CO
+.. ...
+JOHNSON& JOHNSON
+MBNA CORP
+... ..
+PFIZER INC
+.................--------.
+PROCTER & GAMBLE CO
+VIACOM INC-CL B
+Total Equities& Options
+TOTAL EQUITIES
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SIMBOUCUSIP
+QUANTITY
+PRICE
+SYMBOLICUSIP
+AHP
+AIG
+BAC
+BMY
+C
+GS
+IBM
+JPM
+....
+JNJ
+KRB
+PFE
+•......
+PG
+VIAB
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+.. . .
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+24,000
+......
+20,000
+25,000
+25,000
+15,000
+10,000
+10,000
+37,500
+....
+50,000
+70,000
+......
+75,000
+... .
+25,000
+37,000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 28, 2001
+MARKET
+VALUE
+162,339
+$162,339
+ANAL INTE
+CURRE
+ELD I
+PRICE
+57.9000
+83.8000
+60.6500
+55.9600
+48.5800
+83.1200
+111.1600
+37.5500
+.. . .
+58.6700
+30.0200
+.....
+42.7000
+... .
+73.3500
+36.9000
+MARKET
+VALUE
+1,389,600
+1,676,000
+1,516,250
+1,399,000
+728,700
+831,200
+1,111,600
+1,408,125
+... . .
+2,933,500
+2,101,400
+... .
+3,202,500
+......
+1,833,750
+1,365,300
+$21,496,925
+$21,496,925
+027
+ESTIMATED
+ANNUAL INCOME
+22,080
+3,360
+60,000
+27,500
+9,600
+4,800
+5,600
+51,000
+••..
+36,000
+5300.
+38,000
+$316,140
+$316,140
+10/27/01;09:11001
+CURRENT
+YIELD IN
+1.5889
+0.2005
+3.9571
+1.9657
+1.3174
+0.5775
+0.5038
+3.621
+1.2272
+1.1992
+-030
+.. . .
+2.0723
+
+
+5 ol7
+OFFICE SERVICING YOUR ACOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+$316,140
+$21,659,264
+Transaction Detail
+INVESTMENT ACTIVITY
+TRANSACTION
+70/09/01
+10/03/01
+BOUGHT
+10009010301BHT
+CITIGROUP INC
+EE NOTE 'S' ON BAC
+PART OF 15000 SHF
+CINGROUP IN...
+DISCRETIONARY ORDER
+SEE NOTE 'S' ON BACK
+PART OF 15000 SHR
+STABOLUSP
+•••••••••••••••••
+QUANTITY
+5,700
+9,300
+PRICE
+42.58000
+• 42:50000
+10127101;09:11 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 28, 2001
+DEBIT AMOUNT
+244, 193.28
+397,67451
+$-641,867.79
+CREDIT AMOUNT
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+DIVIDENDS
+DATE
+TD/D1/01
+MBNA CORP
+REC 09/15/01 PAY 10/01/01
+INTEREST
+SYMBOUCUSIP
+KRB
+DATE
+T0/22/01
+
+INTEREST ON CREDIT BALANCE
+AT O 1/2% 09/21 THRU 09/23
+•'''NTEREST ON CREDIT BALANCE
+AT 1,000% 10/02 THRU 10/20
+AT 1124, 0924 PHRU TONCE*
+SYMBOL/GUSIP
+QUANTITY
+70,000
+QUANTITY
+RATE (S)
+0.0900
+RATE (%)
+0.5000
+1.0000
+1.5000
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+10/27/01:09:11 001
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 28, 2001
+CREDIT AMOUNT
+6,300.00
+$6,300.00
+CREDIT AMOUNT
+32.64
+210.22
+263.73
+$506.59
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 28, 2001
+Your messages
+13F
+We are pleased to announce that we have moved
+ur world headquarters, previously located at
+245 Park Avenue, to:
+383 Madison Avenue
+New York, New York 10179
+While our telephone numbers and e-mail addresses
+remain the same, some fax numbers have changed,
+Please check with your Account Executive.
+STOP
+****** End of Statement******
+027
+10/27/01;09:11 001
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary .•••••••••••••••••••I/I/
+Your Portfolio Holdings
+Transaction Detail
+Your Messages
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31, 2001
+3
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+...
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+19,718,175
+797,400
+$20,515,575
+.....
+21,270,943
+-755,368
+here are no Stop Loss" orders or other pending bu
+r sell open orders on file for your accoun
+Market Value of Your Portfolio
+S797,400
+$138,743
+Cash & Equivalent
+Equities
+1 $19,718,175
+$21,132,200
+Current market value
+Last statement's market value
+Flease raport any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or Write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3669.
+SP The suremen s four or ratanal purger red de Set revere date for portant iformation.
+09/29/01;11:41 001
+
+
+2 of 8
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+09/29/01:11:41 001|
+
+
+3 ora
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+$138,743.05
+619,099.29
+39,557.98
+508-5-272
+658,657.27
+797,4003
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+39,010.00
+547.98
+539.557.98
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+138,743.05
+$138,743.05
+CLOSING
+797,400.32
+......
+$797,400.32
+027
+YEAR TO DATE
+229,480.00
+7,601.96
+5237.081.96
+797,400
+19,718,175
+$20,515,575
+09/29/01:11:41 001
+CLEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent -
+Equities
+97%
+Unshaded portions denote debe balance andor short
+
+
+4 of a
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AMERICAN HOME PRODUCTS CORP
+....
+AMERICAN INTERNATIONAL GROUP
+INC
+•..........•
+BANK OF AMER CORP
+BRISTOL MYERS SQUIBB CO
+GOLDMAN SACHS GROUP INC
+...•-----.
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JP MORGAN CHASE & CO
+JOHNSON& JOHNSON
+... . .
+MBNA CORP
+PFIZER INC
+... . .
+PROCTER & GAMBLE CO
+........
+VIACOM INC-CL B
+Total Equities& Options
+TOTAL EQUITIES
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SIMBOUCUSIP
+QUANTITY
+PRICE
+SYMBOLCUSIP
+AHP
+AIG
+BAC
+BMY
+GS
+JPM
+JNU
+KRB
+PFE
+PG
+VIAB
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+......
+ASH
+CASH
+CASH
+CASH
+QUANTITY
+24,000
+....
+20,000
+25,000
+25,000
+10,000
+10,000
+37,500
+50,000
+.. . .
+70,000
+75,000
+....
+25,000
+37,000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31, 2001
+MARKET
+VALUE
+797,400
+$797,400
+NAME MOTO CRENS
+PRICE
+58.2500
+78.0000
+58.4000
+55.5600
+71.3500
+92.3000
+34.1500
+55.4000
+... ..
+30.2900
+40.1000
+...
+72.7900
+34.5000
+MARKET
+VALUE
+1,398,000
+1,560,000
+1,460,000
+1,389,000
+713,500
+923,000
+280,625
+2,770,000
+2,120,300
+3,007,500
+......
+1,819,750
+......•...•.•.•
+1,276,500
+$19,718,175
+$19,718,175
+027
+ESTIMATED
+ANNUAL INCOME
+22,080
+3,360
+56,000
+27,500
+4,800
+5,600
+51,000
+36,000
+25,200
+33,000
+38,000*
+$302,540
+$302,540
+09/29101;11:41 001
+CURRENT
+YIELD IN
+1.5794
+......
+0.2154
+3.8356
+1.9798
+0.6727
+......
+0.6067
+3.9824
+.299
+-188
+1.0973
+2.0882
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York. New York 10167
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+DATE
+09/10/01
+09/05/01
+TRANSACTION
+SOLD
+DIVIDENDS
+D970A01
+AMERICAN HOME PRODUCTS CORP
+REC 08/13/01 PAY 09/01/01
+REC 08/17/01 PAY 09/06/01
+MORGAN STANLEY DEAN WITTER &
+SYMBOLCUSIP
+AHP
+$302,540
+$20,515,575
+SYMBOLICUSIP
+MWD
+QUANTITY
+-12,000
+PRICE
+51.90010
+QUANTITY
+24,000
+*75,000
+RATE (S)
+0.2300
+0.1100
+027
+DEBIT AMOUNT
+09/29101;11:41 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31, 2001
+DEBIT AMOUNT
+CREDIT AMOUNT
+619,099.29
+$619,099.29
+REDIT AMOUNT
+5,520.00
+8,250.00
+
+
+6 of a
+Transaction Detail (continued)
+DIVIDENDS (continued)
+DATE
+09/10/01
+INTERNATIONAL BUSINESS
+MACHINES CORP
+REC 08/10/01 PAY 09/10/01
+05/11701
+"JÖHNSON& JÖHNSÖN"
+REC 08/21/01 PAY 09/11/01
+09/1401
+*'''AMERICAN INTERNATIONAL GROUP
+HE SIO PAY 0914101
+09/28/01
+BANK OF AMER CORP
+REC 09/07/01 PAY 09/28/01
+INTEREST
+DATE
+09/21/01
+INTEREST ONCREDIT BALANCE
+AT 0 1/2% 09/19 THRU 09/20
+09/2101
+*'''INTEREST ON CREDIT BALANCE
+AT 1 1/2% 09/17 THRU 09/18
+09/21101
+.. . .
+NTEREST ONCREDIT BALANCE
+AT 2.000% 08/21 THRU 09/16
+OFFICE SERVICING YOUR ACOUNT
+245 Pal Arena Co. Inc.
+Vew York, New York 10167
+SYMBOL/CUSIP
+IBM
+AIG
+BAC
+SYMBOUCUSIP
+QUANTITY
+10,000
+50,000
+20,000*
+25,000
+QUANTITY
+RATE (S)
+0.1400
+0.1800
+*0.0420
+0.5600
+RATE (%)
+0.5000
+1.5000
+2.0000
+120
+DEBIT AMOUNT
+DEBIT AMOUNT
+09/29/01:11:41001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31, 2001
+CREDIT AMOUNT
+1,400.00
+9,000.00
+840.00
+14,000.00
+$39,010.00
+CREDIT AMOUNT
+21.75
+65.24
+460.99
+$547.98
+
+
+7 of 8
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31,2001
+Your messages
+This statement is provided to explain Bear, Steams & Co,
+Inc's ("BSC") payment for order flow practices.
+BSC routes a majority of orders for customer securities
+transactions to the primary market for such securities.
+Beginning October 31, 2001, you may request the identity
+of the venue to which any of your orders were routed for
+execution (if the order was within the six months prior t
+the request or July 2, 2001, whichever is a later date),
+whether the order was directed by you to that venue, and
+the time of the executions, if any, that resulted from such
+orders,
+(NBBO). BSC receives no cash payment or other
+consideration for such order routing other than favorable
+executions or executions of limit orders at no additional
+027
+09/29/01:11:41 001
+V50O
+
+
+8 of 8
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31, 2001
+Bear, Stearns Securities Corp. Net Capital and Net Capital
+Requirements:
+At May 25, 2001 and July 27, 2001, the Company's net
+capital of $2,7 billion and $2,7 billion was approximatel
+3.9% and 9.2% of aggregate debit items and exceeded th
+minimum regulatory net capital requirement of $605.5
+million and $585,5 million by $2,1 billion and $2,1 billion,
+all respectively.
+A complete copy of the Bear, Stearns Securities
+Corp, Statement of Financial Condition is
+available on the web site www.bearstearns.com
+Alternatively, to request a free printed copy please call
+-toll free 1-866-299-9331
+Securities and other assets in your account are the firm's
+collateral for any margin loan made to you, If the securities
+and other assets in your account decline in value, so does
+the value of the collateral supporting your loan, and, as a
+result, the firm can take action, such as issue a margin call
+and/or sell securities or other assets in any of your accounts
+held with the member, in order to maintain the required equity
+in the account, It is important that you fully understand the
+risks involved in trading securities on margin, These risks include
+the following:
+You can lose more funds than you deposited in the
+margin account,
+The firm can force the sale of securities or other assets
+in your accounts).
+The firm can sell your securities or other assets without
+contacting you.
+You are not entitled to choose which securities or
+other assets in your accounts) are liquidated or sold
+to meet a margin call,
+le firm can increase it's "house" maintenan‹
+quirements at any time and is not required to provi
+you advance written notice.
+You are not entitled to an extension of time on a margin call.
+STOP
+****** End of Statement******
+027
+09/29/01:11:41 001
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+....
+Transaction Detail
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOO July 28, 2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 27, 2001
+3
+4
+5
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+....
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+21,132,200
+138,743
+S21,270,943
+22,129,834
+-858,891
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$138.743
+$282,579
+Cash & Equivalent
+Equities
+$21.132,200
+$21,847,255
+Current market value
+Last statement's market value
+Flease raport any dierence or non-receipt of chacks or stocks, indicated as delivered to you.
+to Client Services at 800 6341428; or Write to Cient Services at Bear, Steams Securities
+Corp.. One Metrolech Center North, Brooklyn, N.Y. 11201-3659.
+SP The suren s four or ratanal purposes rear die Set revere date for portant iformation.
+09101/01;10:37 001
+
+
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+09.01/01:10:37 001
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+Securities Bought
+Amount Debited
+Net Cash Activity
+Closing Balance,
+THIS PERIOD
+282,579.49
+....
+71,060.74
+29,297.69
+$100,358.43
+.....
+-244,194.87
+5-244,194.87
+... .
+- 143,836.44
+61.38.743.05
+Income Summary
+Dividends
+Credit Balance Int.
+THIS PERIOD
+28,950.00
+347.69
+529.297.69
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+282,579.49
+$282,579.49
+CLOSING
+138,743.05
+$138,743.05
+027
+YEAR TO DATE
+190,470.00
+7,053.98
+197.523.9
+138,743
+21,132,200
+....
+$21,270,943
+09/01/01;10:37 001
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD July 28, 2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 27, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+<1%
+- Equities
+99%
+Unshaded portions denote debit balance and or shart
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AMERICAN HOME PRODUCTS CORP
+....
+AMERICAN INTERNATIONAL GROUP
+... .
+BANK OF AMER CORP
+BRISTOL MYERS SOUBB CO
+GOLDMAN SACHS GROUP INC
+.. . .
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JP MORGAN CHASE & CO
+IOHNSON& JOHNSON
+... ..
+MBNA CORP
+MORGAN STANLEY DEAN WITTER &
+co
+.. . ..
+PFIZER INC
+....
+PROCTER & GAMBLE CO
+SARRIE
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SIMBOUCUSIP
+QUANTITY
+PRICE
+SYMBOLCUSIP
+AHP
+AIG
+BAC
+BMY
+GS
+JPM
+JNJ
+....
+KRB
+MWD
+PFE
+PG
+CASH
+CASH™
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+....
+ASH
+CASH
+......
+ASH
+.....
+CASH
+QUANTITY
+24,000
+......
+20,000
+25,000
+25,000
+10,000
+10,000
+37,500
+50,000
+.. . .
+70,000
+12,000
+75,000
+... .
+25,000
+MARKET
+VALUE
+138,743
+$138,743
+PRICE
+56.0000
+78.2000
+61.5000
+56.1400
+80.1000
+100.0000
+39.4000
+52.7100
+....
+34.7600
+53.3500
+38.3100
+... .
+74.1500
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOO July 28, 2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 27,2001
+ANAL INTE
+CURRE
+ELD I
+MARKET
+VALUE
+1,344,000
+1,564,000
+1,537,500
+1,403,500
+801,000
+1,000,000
+1,477,500
+2,635,500
+....
+2,433,200
+640,200
+2,873,250
+.. . ..
+1,853,750
+ESTIMATED
+ANNUAL INCOME
+22,080
+3,360
+56,000
+27,500
+4,800
+5,600
+51.000
+356.000
+25,200
+1,04
+33,000
+....
+38,000
+CURRENT
+YIELD IN
+1.6429
+......
+0.2148
+3.6423
+1.9594
+0.5993
+....
+0.5600
+3.4518
+1.3660
+... ..
+1.0357
+1.724:
+1.1485
+.....
+2.0499
+....
+027
+09101/01:10:37 001
+
+
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+VIACOM INC-CL B
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLOUSIP
+VIAB
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCT
+CASH
+QUANTITY
+37,000
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TRE
+TRANSACTION
+08/03/01
+07/31/01
+BOUGHT
+ö8/10/0108/0701"BÖUGHT
+08/10/01
+0B/07/01
+SOLD
+AMERICAN HOME PRODUCTS CORP
+DISCRETIONARY ORDER
+"ZIMMER HOLDINGS INC**
+SPINOFF
+SPINOFF FROM SEC #
+REC 07/27/01 PAY 08/06/01
+ZIMMER HOLDINGS INC
+AVG PRICE SHOWN-DETAILS ON REQ
+ACTUAL CONFIRM TO YOUR AGENT
+PRICE
+42.4000
+MARKET
+VALUE
+1,568,800
+$21,132,200
+$21,132,200
+$313,580
+$21,270,943
+ESTIMATED
+ANNUAL INCOME
+$313,580
+$313,580
+CURRENT
+YIELD (%)
+SYMBOLICUS.P
+AHP
+*2MH"
+ZMH
+QUANTITY
+4,000
+2,500
+- 2,500
+PRICE
+60.67000
+•28.68710
+027
+09101/01:10:37 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOO July 28, 2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 27,2001
+DEBIT AMOUNT
+244,194.87
+CREDIT AMOUNT
+71,060.74
+$71,060.74
+$-244,194.87
+
+
+6 of 6
+Transaction Detail (continued)
+DIVIDENDS
+
+JP MORGAN CHASE & CO
+REC 07/06/01 PAY 07/31/01
+08/01/01 BRISTOL MYERS SQUiBE CO
+08/15/01
+REC 07/06/01 PAY 08/01/01
+"PROCTER & GAMBLE"CO"
+REC 07/20/01 PAY 08/15/01
+08:30101
+INTEREST
+DATE
+08/21/01
+INTEREST ONCREDIT BALANCE
+AT 2 1/4% 07/21 THRU 08/20
+Bear, Stears & Co. Inc
+45 Park Avenue
+New York, New York 10167
+SYMBOL/CUSIP
+JPM
+**BMY
+"PG
+SYMBOL/CUSIP
+STOP
+****** End of Statement******
+QUANTITY
+RATE (S)
+37,500
+0.3400
+20,0000.2750
+25,000
+0.3800
+10,000
+0.1200
+QUANTITY
+RATE (SI
+2.2500
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+09101/01;10:37 001
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOO July 28, 2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 27, 2001
+CREDIT AMOUNT
+12,750.00
+5500.00
+9,500.00
+.. . .
+1,200.00
+$28,950.00
+CAEDIT AMOUNT
+347.69
+$347.69
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+....
+Transaction Detail
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD June 30, 2001
+THROUGH
+July 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2001
+3
+4
+5
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+21,847,255
+282,579
+$22, 129,834
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+21,726,863
+402,971
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$282.579
+$540.053
+Cash & Equivalent
+Equities
+$21,847,255
+# $21,186,810
+Current market value
+Last statement's market value
+Flease raport any dierence or non-receipt of chacks or stocks, indicated as delivered to you.
+to Client Services at 800 6341428; or Write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3659.
+07/28/01;10:18 001
+
+
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+07/28/01:10:18 001|
+V482
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Securities Bought
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERIOD
+S540.053.06
+9,699.31
+59,699.31
+-267,172.88
+$267,72.88
+-257,473.57
+... ..
+282.579.49
+Income Summary
+Dividends
+Credit Balance Int.
+Total L
+THIS PERIOD
+9,060.00
+639.31
+$9,699.31
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+let Cash Balano
+•...
+OFENING
+540,053.06
+$540,053.06
+••••••••••••••••••••
+CLOSING
+282,579.49
+5282,579.49
+027
+YEAR TO DATE
+161,520.00
+6,706.29
+---.
+$168,226.29
+282,579
+21,847,255
+522,129,834
+07/28/01;10:18 001
+CLEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD June 30, 2001
+THROUGH
+July 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+1%
+- Equities
+99%
+Unshaded portions denote debe balance andor short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AMERICAN HOME PRODUCTS CORP
+....
+AMERICAN INTERNATIONAL GROUP
+... .
+BANK OF AMER CORP
+BRISTOL MYERS SOUBB CO
+GOLDMAN SACHS GROUP INC
+.. . .
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JP MORGAN CHASE & CO
+IOHNSON& JOHNSON
+... ..
+MBNA CORP
+MORGAN STANLEY DEAN WITTER &
+co
+.. . ..
+PFIZER INC
+....
+PROCTER & GAMBLE CO
+SARRIE
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SIMBOLCUSP
+QUANTITY
+SYMBOLCUSIP
+AHP
+AIG
+BAC
+BMY
+GS
+JPM
+JNJ
+....
+KRB
+MWD
+PFE
+PG
+CASH
+CASH™
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+....
+ASH
+CASH
+......
+ASH
+.....
+CASH
+QUANTITY
+20,000
+......
+20,000
+25,000
+25,000
+10,000
+10,000
+37,500
+50,000
+.. . .
+70,000
+12,000
+75,000
+.......
+25,000
+PRICE
+PRICE
+58.0600
+81.7200
+63.5000
+56.4300
+84.8200
+104.7000
+44.2100
+53.0100
+... ..
+35.5800
+59.5900
+39.8400
+....
+70.4700
+MARKE
+FALLE
+282,579
+$282,579
+MARKET
+VALUE
+1,161,200
+1,634,400
+1,587,500
+1,410,750
+848,200
+1,047,000
+1,657,875
+2,650,500
+......
+2,490,600
+715,080
+2,988,000
+... ..
+1,761,750
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD June 30, 2001
+THROUGH
+July 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2001
+ESTIMATE
+NNUAL INCON
+ESTIMATED
+ANNUAL INCOME
+18,400
+3,360
+56,000
+27,500
+4,800
+5,600
+51.000
+11,040
+13,000
+....
+38,000
+CURRENT
+YIELD IN
+1.5846
+....
+0.2056
+3.5276
+1.9493
+0.5659
+0.5349
+3.0762
+1.3582
+....
+1.0118
+1.5439
+1.1044
+.....
+2.1569
+..........
+07/28/01;10:18 001
+
+
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+VIACOM INC-CL B
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLOUSIP
+VIAB
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCT
+CASH
+QUANTITY
+37,000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SEEMENT TRADE
+TRANSACTION
+07/10/01 07/05/01
+BOUGHT
+BRISTOL MYERS SQUIBB CO
+WITH RIGHTS TO PURCHASE PREFRO
+STK UNDER CERTAIN CIRCUMSTANCE
+DISCRETIONARY ORDER
+PRICE
+51.2000
+MARKET
+VALUE
+1,894,400
+$21,847,255
+$21,847,255
+$309,900
+$22,129,834
+ESTIMATED
+ANNUAL INCOME
+$309,900
+$309,900
+CURRENT
+YIELD (%)
+SYMBOLICUSP
+BMY
+QUANTITY
+5,000
+PRICE
+53.10000
+027
+07/28/01:10:18 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD June 30, 2001
+THROUGH
+July 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2001
+DEBIT AMOUNT
+267,172.88
+$-267,172.88
+CRECIT AMOUNT
+
+
+6 of B
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Transaction Detail (continued)
+DIVIDENDS
+
+MBNA CORP
+REC 06/15/01 PAY 07/01/01
+07/27/01 MORGAN STANLEY DEAN WITER &
+CEC 07/06/01 PAY 07727101
+INTEREST
+DATE
+07/23/01
+INTEREST ON CREDIT BALANCE
+AT 2 1/2% 06/21 THRU 06/26
+07/23/01 INTEREST ON CREDIT BALANCE
+AT 2 1/4% 06/27 THRU 07/20
+SYMBOL/CUSIP
+KRB
+AWL
+SYMBOL/CUSIP
+STOP
+****** End of Statement******
+QUANTITY
+70,000
+12,000
+QUANTITY
+RATE (S)
+0.0900
+0.2300
+RATE (%)
+2.5000
+027
+DEBIT AMOUNT
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD June 30, 2001
+THROUGH
+July 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2001
+CREDIT AMOUNT
+6,300.00
+...
+2,760.00
+$9,060.00
+DEBIT AMOUNT
+CREDIT AMOUNT
+36.28
+........03.03
+$639.31
+07/28/01:10:18 001
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ••••••••••••••••••••••I/I/
+Your Portfolio Holdings
+Transaction Detail
+Your Messages
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 25, 2001
+3
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+21,186,810
+540,053
+S21,726,863
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+22,686,454
+-959,591
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$540.053
+$10,604
+Cash & Equivalent
+Equities
+$21,186,810
+$22,675,850
+Current market value
+Last statement's market value
+Important Message
+Please note: You may find
+more than one statement
+in this envelope. Beginning
+this month, all statements
+with the same Address and
+Social Security number /
+Taxpayer Identification
+number are being mailed in
+one envelope. For further
+details, please contact your
+account executive.
+Flease raport any dierence or non-receipt of chacks or stocks, indicated as delivered to you,
+to Client Services at 800-634.1428; or writa to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3669.
+SIP The suremen s four ratanal purger red de Set revere dise for portant iformation.
+06/30/01;23:28 001
+
+
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+06/30/01:23:28 001|
+V481
+
+
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+THIS PERICO
+510.60-25
+491,415.62
+38,033.19
+$529,448.81
+......
+529,448.81
+5540.063.06
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+37,990.00
+43.19
+$38.033.19
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+total.
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+10,604.25
+$10,604.25
+CLOSING
+540,053.06
+.....
+$540,053.06
+027
+YEAR TO DATE
+152,460.00
+6,066.98
+•-.---.
+$158,526.98
+540,053
+21,186,810
+521.726.863
+06/30/01:23:28001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 25, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+2%
+Equities
+98%
+Unshaded portions denote debe balance andor short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AMERICAN HOME PRODUCTS CORP
+....
+AMERICAN INTERNATIONAL GROUP
+... .
+BANK OF AMER CORP
+BRISTOL MYERS SOUBB CO
+GOLDMAN SACHS GROUP INC
+.. . .
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JP MORGAN CHASE & CO
+IOHNSON& JOHNSON
+... ..
+MBNA CORP
+MORGAN STANLEY DEAN WITTER &
+co
+.. . ..
+PFIZER INC
+....
+PROCTER & GAMBLE CO
+SARRIE
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SIMBOLCUSP
+QUANTITY
+SYMBOLCUSIP
+AHP
+AIG
+BAC
+BMY
+GS
+JPM
+JNJ
+....
+KRB
+MWD
+PFE
+PG
+CASH
+CASH™
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+....
+ASH
+CASH
+......
+ASH
+.....
+CASH
+QUANTITY
+20,000
+...
+20,000
+25,000
+20,000
+10,000
+10,000
+37,500
+50,000
+.. . .
+70,000
+12,000
+75,000
+... .
+25,000
+PRICE
+PRICE
+58.4400
+86.0000
+60.0300
+52.3000
+85.8000
+113.0000
+44.6000
+50.0000
+....
+32.9500
+64.2300
+40.0500
+•.........
+63.8000
+540,053
+$540,053
+MARKET
+VALLE
+1,168,800
+1,720,000
+1,500,750
+1,046,000
+858,000
+1,130,000
+1,672,500
+2,500,000
+...
+2,306,500
+770,760
+3,003,750
+... ..
+1.595,000
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 25, 2001
+ESTIMATE
+NNUAL INCON
+ESTIMATED
+ANNUAL INCOME
+18,400
+3,360
+56,000
+22,000
+4,800
+5,600
+51,000
+36,000.
+25,200
+11.040
+33,000
+.....
+35,000
+CURRENT
+YIELD (S
+1.5743
+0.1953
+3.7315
+2.1033
+0.5594
+....
+0.4956
+3.0493
+1.4400
+.. . .
+1.0928
+1.4324
+1.0986
+.......
+2.1944
+........
+06/30101:23:28 001
+
+
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+VIACOM INC-CL B
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLOUSIP
+VIAB
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCT
+CASH
+QUANTITY
+37,000
+Transaction Detail
+INVESTMENT ACTIVITY
+SEEN TA
+TRANSACTION
+06/18/01
+06/13/01
+BOUGHT
+06/26/01 06/21/01 SOLD"
+06/29/01
+06/26/01
+SOLD
+JOHNSON& JOHNSON
+TK SPLIT ON 25000 SH
+EC 05/22/01 PAY 06/12/0
+MORGAN STANLEY BEAN WITTER &
+MORGAN STANLEY DEAN WITER &
+PRICE
+51.7500
+MARKE
+FALLE
+1,914,750
+$21,186,810
+$21,186,810
+$301,400
+$21,726,863
+ESTIMATED
+ANNUAL INCOME
+$301,400
+$301,400
+CURRENT
+YIELD (%)
+SYMBOLICUS.P
+JNJ
+MWD
+MWD
+QUANTITY
+25,000
+4,000
+000't-
+- 61.54960
+62.07630
+220
+06/30101:23:28 001
+LEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 25,2001
+DEBIT AMOUNT
+CREDIT AMOUNT
+** 244,659.25
+246,756.37
+$491,415.62
+
+
+Transaction Detail (continued)
+DIVIDENDS
+DATE
+06/01/01
+AMERICAN HOME PRODUCTS CORP
+REC 05/11/01 PAY 06/01/01
+06/0701 PFIZER INC.'
+REC 05/18/01 PAY 06/07/01
+ö6/11/01
+''INTERNATIONAL BUSINESS"
+MACHINES CORP
+REC 05/10/01 PAY 06/09/01
+06/12701
+REC 05/22/01 PAY 06/12/01
+06/1501
+''"AMERICAN INTERNATIONAL GROUP
+REC 06/01/01 PAY 06/15/01
+06/22/01
+BANK OF AMER CORP
+REC 06/01/01 PAY 06/22/01
+INTEREST
+DATE
+06/21/01
+INTEREST ON CREDIT BALANCE
+AT 2 1/2% 05/21 THRU 06/20
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SYMBOUCUSIP
+AHP
+''''PFE
+INJ
+BAC
+QUANTITY
+RATE (S)
+20,000
+0.2300
+75,000 0.1100
+10,000
+0.1400
+25,000*
+20,000
+25,000
+''0:3600
+''0.0370
+0.5600
+SYMBOUCUSIP
+QUANTITY
+RATE IN)
+2.5000
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+06/30/01:23:28 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 25, 2001
+CREDIT AMOUNT
+4,600.00
+8,250.00
+1,400.00
+9,000.00
+740.00
+14,000.00
+$37,990.00
+CREDIT AMOUNT
+43.19
+$43.19
+
+
+ear, Steams & Co. In
+45 Park Avenue
+New York, New York 10167
+Your messages
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 25, 2001
+STOP
+****** End of Statement******
+027
+06/30/01:23:28 001
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+....
+Transaction Detail
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD April 28, 2001
+THROUGH
+May 25, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 27, 2001
+3
+4
+5
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+22,675,850
+10,604
+22,686.45
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+22,174,225
+512,229
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$10,604
+$949,950
+Cash & Equivalent
+Equities
+$22,675,850
+฿ $21,224,275
+Current market value
+Last statement's market value
+Important Message
+In an effort to deliver
+statements to you more
+efficiently, Bear Steams
+has enhanced the
+distribution of statements
+to household accounts.
+Salemen sen the same
+Address and Social Security
+number/ Taxpayer
+identification number will
+be mailed in a single
+envelope. For further
+details, please contact your
+account executive.
+Flease raport any diference or non-receipt of chacks or stocks, indicated as delivered to you.
+to Client Services at 800-634.1428; or writa to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3659.
+SIP The suremen s four ratanal purger red de Set revere date for portant iformation.
+05/26/01;10:08 001
+
+
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+05/26/01:10:08 001
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+Securities Bought
+Amount Debited
+Net Cash Activity
+Closing Balance,
+THIS PERIOD
+5949.949.76
+17,424.41
+28,245.21
+$45,669.62
+.........
+- 985,015.13
+-985,015.1:
+... .
+-939,345.51
+10.604.25
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+27,000.00
+1,245.21
+$28.245.21
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+total.
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+949,949.76
+$949,949.76
+CLOSING
+10,604.25
+.........
+$10,604.25
+027
+YEAR TO DATE
+114,470.00
+6,023.79
+•..*.*..-*.
+$120,493.79
+10,604
+22,675,850
+$22,686,454
+05/26/01;10:08 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD April 28, 2001
+THROUGH
+May 25, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 27, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+<1%
+- Equities
+99%
+Unshaded portions denote debe balance andor short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AMERICAN HOME PRODUCTS CORP
+....
+AMERICAN INTERNATIONAL GROUP
+... .
+BANK OF AMER CORP
+BRISTOL MYERS SOUBB CO
+GOLDMAN SACHS GROUP INC
+.. . .
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JP MORGAN CHASE & CO
+IOHNSON& JOHNSON
+... ..
+MBNA CORP
+MORGAN STANLEY DEAN WITTER &
+co
+.. . ..
+PFIZER INC
+....
+PROCTER & GAMBLE CO
+SARRIE
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SIMBOLCUSP
+QUANTITY
+SYMBOLCUSIP
+AHP
+AIG
+BAC
+BMY
+GS
+JPM
+JNJ
+....
+KRB
+MWD
+PFE
+PG
+CASH
+CASH™
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+....
+ASH
+CASH
+......
+ASH
+.....
+CASH
+QUANTITY
+20,000
+...
+20,000
+25,000
+20,000
+10,000
+10,000
+37,500
+25,000
+.. . .
+70,000
+20,000
+75,000
+... .
+25,000
+PRICE
+PRICE
+61.0000
+82.3100
+58.7100
+54.2000
+97.9600
+117.8000
+48.7000
+97.2500
+....
+36.8600
+69.4800
+41.8600
+....
+63.5000
+10.604
+$10,604
+MARKET
+VALLE
+1,220,000
+1,646,200
+1,467,750
+1,084,000
+979,600
+1,178,000
+1,826,250
+2,431,250
+......
+2,580,200
+1,389,600
+3,139,500
+.. . ..
+1,587,500
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD April 28, 2001
+THROUGH
+May 25, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 27,2001
+ESTIMATE
+NNUAL INCON
+ESTIMATED
+ANNUAL INCOME
+18,400
+3,360
+56,000
+22,000
+4,800
+5,600
+51,000
+36.00.
+25,200
+8,40
+13,000
+....
+35,000
+CURRENT
+YIELD IN
+1.5082
+0.2041
+3.8154
+2.0295
+0.4900
+......
+0.4754
+2.7926
+1.4807
+0.9767
+1.3241
+1.0511
+.....
+2.2047
+....*.......
+05/26/01:10:09 001
+
+
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+VIACOM INC-CL B
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLOUSIP
+VIAB
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCT
+CASH
+QUANTITY
+37,000
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT TRADE
+DATE
+05/08/01
+05/03/01
+TRANSACTION
+BOUGHT
+05/25/01 05/21/01 BOUGHT"
+05/25/01
+05/22/01
+SOLD
+GOLDMAN SACHS GROUP INC
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGEN
+PEABODY ENERGY CORPORATION"
+SOLICITED
+PROSPECTUS UNDER SEPARATE MAIL
+AS OF 05/21/01
+PEABODY ENERGY CORPORATION
+SOLICITED
+AS OF 05/22/01
+PRICE
+58.0000
+MARKET
+VALUE
+2,146,000
+$22,675,850
+$22,675,850
+$308,760
+$22,686,454
+ESTIMATED
+ANNUAL INCOME
+$308,760
+$308,760
+CURRENT
+YIELD (%)
+SYMBOLICUSIP
+GS
+"BTU
+BTU
+QUANTITY
+10,000
+*500
+-500
+PRICE
+96.58750
+28.00000
+35.00000
+05/26/01:10:08 001
+LEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD April 28, 2001
+THROUGH
+May 25, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 27,2001
+DEBIT AMOUNT
+971,015.13
+14,000.00
+CREDIT AMOUNT
+17,424.41
+$17,424.41
+$-985,015.13
+
+
+OFFICE SERVICING YOUR ACOOUNT
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Transaction Detail (continued)
+DIVIDENDS
+D473010T
+JP MORGAN CHASE & CO
+REC 04/06/01 PAY 04/30/01
+05/0101"BRISTOL MYERS SQUiBB CO
+05/15/01
+REC 04/06/01 PAY 05/01/01
+"PROCTER & GAMBLE CO"
+REC 04/20/01 PAY 05/15/01
+INTEREST
+SYMBOL/CUSIP
+JPM
+'''BMY
+"PG
+QUANTITY
+RATE (S)
+37,500
+0.3400
+20,0000.2750
+25,000
+0.3500
+DATE
+05/21/01
+INTEREST ON CREDIT BALANCE
+AT 2 1/2% 05/15 THRU 05/20
+
+'INTEREST ON CREDIT BALANCE
+AT 3,000% 04/21 THRU 05/14
+SYMBOL/CUSIP
+QUANTITY
+RATE (SL
+2.5000
+3.0000
+STOP
+****** End of Statement******
+027
+DEBIT AMOUNT
+DEBIT AMOUNT
+05/26/01;10:08 001
+EARED THROUGH I
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD April 28, 2001
+THROUGH
+May 25, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 27, 2001
+CREDIT AMOUNT
+12,750.00
+5,500-00
+8,750.00
+$27.000.00
+1,242.74
+$1,245.21
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+....
+Transaction Detail
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD March 31, 2001
+THROUGH
+April 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30, 2001
+3
+4
+5
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+21,224,275
+949,950
+NET EQUITY THIS PERIOD
+$22,174,225
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+20,621,077
+1,553,147
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$949,950
+$195,687
+Cash & Equivalent
+Equities
+$21,224,275
+# $20,425,390
+Current market value
+Last statement's market value
+Flease raport any dierence or nonreceipt of chocks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suremen s four ratanal purpose red die Set revere dae for portant iformation.
+
+
+027
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+5195.687.36
+740,279.60
+13,982.80
+$754,262.40
+....
+754,262.40
+$949.949.76
+Income Summary
+Dividends
+Credit Balance Int.
+Total L
+THIS PERIOD
+13,380.00
+602.80
+513,982.80
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+195,687.36
+$195,687.36
+CLOSING
+949,949.76
+......
+949,949.70
+YEAR TO DATE
+87,470.00
+4,778.58
+....
+$92,248.58
+949,950
+21,224,275
+
+027
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD March 31, 2001
+THROUGH
+April 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30,2001
+Your Portfolio
+Allocation
+Cash & Equivalent -
+Equities
+96%
+Unshaded portions denote debit balance and or shart
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AMERICAN HOME PRODUCTS CORP
+....
+AMERICAN INTERNATIONAL GROUP
+... .
+BANK OF AMER CORP
+•........
+BRISTOL MYERS SOUBB CO
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JP MORGAN CHASE & CO
+JOHNSON& JOHNSON
+MBNA CORP
+.. ..
+MORGAN STANLEY DEAN WITTER &
+PFIZER INC
+............
+PROCTER & GAMBLE CO
+.......
+VIACOM INC-CLB
+Total Equities& Options
+TOTAL EQUITIES
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SIMBOLCUSP
+QUANTITY
+SIMBOLCUSIP
+AHP
+AIG
+BAC
+BMY
+IBM
+KRB
+MWD
+PFE
+.....
+PG
+VIAB
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+.....
+CASH
+...
+CASH
+... ..
+CASH
+.......
+CASH
+QUANTITY
+20,000
+...
+20,000
+25,000
+20,000
+10,000
+37,500
+25,000
+70,000
+.. . .
+20,000
+75,000
+... ..
+25,000
+......
+37,000
+PRICE
+PRICE
+57.5200
+80.7000
+56.9200
+57.7500
+116.2000
+49.8500
+95.3800
+36.2000
+... .
+65.3000
+43.1200
+.. . ..
+59.8300
+51.2500
+MARKE
+FALLE
+949,950
+$949,950
+MARKET
+VALUE
+1,150,400
+.. . .
+1,614,000
+1.423,000
+1,155,000
+1,162,000
+869,37
+2,384,500
+2.534,000
+.. . .
+1,306,000
+3.234.000
+......
+1,495,750
+1,896,250
+$21,224,275
+$21,224,275
+ESTIMATED
+ANNUAL INCOM
+ESTIMATED
+ANNUAL INCOME
+18,400
+2,960
+56,000
+22,000
+5,600
+51,000
+25,200
+... .
+18.400
+33,000
+35,000
+$299,560
+$299,560
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD March 31, 2001
+THROUGH
+April 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30,2001
+CURRENT
+YIELD IN
+1.5994
+.....
+0.1834
+3.9353
+1.9048
+).4819
+2.7282
+1.3420
+0.9945
+1.4089
+1.0204
+2.3400
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York. New York 10167
+Your Portfolio Holdings (continued)
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SETILEMENT TRADE
+DATE
+TRANSACTION
+04/19/01
+04/18/01
+SOLD
+04/23/01 04/18/01
+1 SOLD
+DIVIDENDS
+DATE
+04/02/01
+MENA CORP
+REC 03/15/01 PAY 04/01/01
+MENA CORP
+NEXT DAY
+MORGAN STANLEY DEAN WITER &
+AS OF 04/18101
+SYMBOL/CUSIP
+KAB
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD March 31, 2001
+THROUGH
+April 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30, 2001
+$299,560
+$22,174,224
+SYMBOLCUSIP
+KRB
+QUANTITY
+-2,000
+- 10,000
+PRICE
+36.91000
+67.09150
+DEBIT AMOUNT
+CREDIT AMOUNT
+73,180.20
+667,099.40
+$740,279.60
+QUANTITY
+72,000
+RATE (S)
+0.0900
+DEBIT AMOUNT
+CAEDIT AMOUNT
+6,480.00
+....
+027
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Transaction Detail (continued)
+DIVIDENDS (continued)
+DATE
+04/27/01
+MORGAN STANLEY DEAN WITTER &
+co
+REC 04/06101 PAY 04/27101
+INTEREST
+DATE
+04/23/01
+INTEREST ONCREDIT BALANCE
+AT 3,000% 04/18 THRU 04/20
+04/23/01
+AT 5 24, 082 A 04NGE
+SYMBOUCUSIP
+MWD
+SYMBOU/CUSIP
+STOP
+****** End of Statement******
+QUANTITY
+30,000
+QUANTITY
+RATE (S)
+0.2300
+RATE (NA
+3.0000
+3.5000
+DEBIT AMOUNT
+DEBIT AMOUNT
+027
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD March 31, 2001
+THROUGH
+April 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30, 2001
+CREDIT AMOUNT
+6,900.00
+$13,380.00
+CREDIT AMOUNT
+62.74
+540.06
+$602.80
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ••••••••••••••••••••••//I/
+Your Portfolio Holdings
+Transaction Detail
+Your Messages
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD February 24,2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 31-6412006
+LAST STATEMENT
+February 23, 2001
+3
+3
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+20,425,390
+195,687
+$20,621,077
+NET EQUITY THIS PERIOD
+....
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+22,090,572
+-1,469,494
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$195.687
+$158.277
+Cash & Equivalent
+Equities
+$20,425,390
+$21,932,295
+Current market value
+Last statement's market value
+Important Notice
+Decimal Trading is Here for
+Nasdaq!
+Decimal Trading is the shift
+from fractional pricing
+(e.g. 21 1/2) to decimal
+pricing (e.g.$21.50)for
+equities and options.
+Nasdaq securities have
+been phased in during March
+and the remaining securities
+Do chis unt to be rading in.
+For details, visit our website at
+www.bearstearns.
+com.
+Flease report any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s foul ratanal purger red de Set revere date for portant iformation.
+
+
+027
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+158,276.50
+$158,276.50
+THIS PERICO
+5158,276.50
+37,410.86
+$37,410.86
+37,410.86
+5195.667.36
+Income Summary
+Dividends
+Credit Balance Int.
+Total L
+THIS PERIOD
+36,890.00
+520.86
+$37.410.86
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total.
+YEAR TO DATE
+74,090.00
+4,175.78
+----.
+$78,265.78
+195,687
+20,425,390
+•••••••••••••
+20.621,07
+...-.
+CLOSING
+195,687.36
+$195,687.36
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SIMBOLCUSP
+QUANTITY
+PRICE
+MARKET
+VALLE
+195.687
+$195,687
+AMMAL MOME
+027
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD February 24,2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 31-6412006
+LAST STATEMENT
+February 23,2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+< 1%
+03/31/01;17:01 001
+- Equities
+99%
+Unshaded portions denote debit balance andor short
+market values. The alocation percentage is derived
+
+
+Your Portfolio Holdings (continued)
+EQUITIES
+Equities & Options
+AMERICAN HOME PRODUCTS CORP
+MERICAN INTERNATIONA
+INC
+. GROUP
+BANK OF AMER CORP
+BRISTOL MYERS SQUIBB CO
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JP MORGAN CHASE & C
+JOHNSON& JOHNSON
+MBNA CORP
+MORGAN STANLEY DEAN WITTER &
+co
+PFIZER INC
+PROCTER & GAMBLE CO
+VIACOM INC-CL B
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLICUSIP
+AHP
+AIG
+BAC
+BMY
+IBM
+JPM
+KRB
+MWD
+PFE
+VIAB
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+....
+CASH
+QUANTITY
+20,000
+20,000
+25,000
+20,000
+10,000
+37,500
+25,000
+2,00
+30,000
+75,000
+......
+25,000
+37,000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+PRICE
+58.7500
+80.5000
+54.7500
+.....
+59.400
+96.1800
+44.9000
+87.4700
+33.1000
+53.5000
+40.9500
+2.6000
+43.9700
+MARKET
+VALUE
+1,175,000
+1,610,000
+1,368,750
+1,188,000
+961,300
+1,683,750
+2,186,750
+2,383,200
+1,605,000
+3,071,250
+1.565.000
+1,626,890
+$20,425,390
+$20,425,390
+$309,080
+$20,621,077
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD February 24,2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 31-6412006
+LAST STATEMENT
+February 23,2001
+CURRENT
+YELD (S)
+18,400
+1.5660
+... . . .
+2,960
+0.1839
+56,000
+....
+....
+4.0913
+•••••••••••
+1.8519
+.540
+51,000
+32,000
+25.920
+27,600
+3.0290
+463
+1.0876
+1.7196
+33,000
+1.0745
+35.000
+.. 22364
+$309,080
+$309,080
+027
+
+
+Transaction Detail
+DIVIDENDS
+DATE
+03/01/01
+AMERICAN HOME PRODUCTS CORP
+REC 02/13/01 PAY 03/01/01
+03/08/01 PFIZER INC
+REC 02/16/01 PAY 03/08/01
+03/12/01
+''INTERNATIONAL BUSINESS"
+MACHINES CORP
+REC 02/09/01 PAY 03/10/01
+63/13/01
+REC 02/20/01 PAY 03/13/01
+03/18/01
+"AMERICAN INTEANATIONAL GROUP"
+INC
+REC 03/02/01 PAY 03/16/01
+
+BANK OF AMER CORP
+REC 03/02/01 PAY 03/23/01
+INTEREST
+DATE
+03/21/01
+INTEREST ON CREDIT BALANCE
+AT 3 1/2% 03/20 THRU 03/20
+03721/01
+INTEREST ON CREDIT BALANCE
+AT 4,000% 02/21 THRU 03/19
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SYMBOUCUSIP
+AHP
+''''PFE
+INJ
+AIG
+BAC
+SYMBOUCUSIP
+QUANTITY
+RATE (S)
+20,000
+0.2300
+75,000 0.1100
+10,000
+0.1300
+25,000*
+20,000
+25,000
+'0:3200
+0.0370
+0.5600
+QUANTITY
+RATE (%)
+3.5000
+4.0000
+DEBIT AMOUNT
+DEBIT AMOUNT
+027
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD February 24,2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 31-6412006
+LAST STATEMENT
+February 23,2001
+CREDIT AMOUNT
+4,600.00
+8,250.00
+1,300.00
+8,000.00
+740.00
+14,000.00
+$36,890.00
+CREDIT AMOUNT
+17.61
+503.2
+$520.86
+
+
+ear, Stears & Co. In
+45 Park Avenue
+New York, New York 10167
+Your messages
+13F
+Bear, Stearns Securities Corp, Net Capital and
+Net Capital Requirements:
+At November 30, 2000 and January 26, 2001, the
+Company's net capital of $2,620,960,000 and
+$2,202,436,000, all respectively.
+A complete copy of the Bear, Stearns Securities
+Corp, Statement of Financial Condition is available
+on the web site www.bearstearns.com, Alternatively,
+to request a free printed copy please call -
+toll free 1-866-299-9331,
+STOP
+****** End of Statement******
+027
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD February 24,2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 31-6412006
+LAST STATEMENT
+February 23,2001
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Your Messages
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 31-6412006
+LAST STATEMENT
+January 26, 2001
+3
+7
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+21,932,295
+158,277
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+$22,090,572
+23,402,471
+-1,311,899
+Cash & Equivalent
+Equities
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$158.277
+$837,325
+$21,932.295
+$22,565,146
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+do Client Services at 800-634-142g; or write to Cient Servicos at Bear, Stoama Securitios
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen is four or ratanal purpose red de Set revere date for portant iformation.
+
+
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Securities Bought
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERIOD
+5837,324.76
+32,361.80
+$32,361.80
+-711,410.06
+$711.410.06
+679,048.26
+5158.276.50
+Income Summary
+Dividends
+Credit Balance Int.
+THIS PERIOD
+30,800.00
+1,561.80
+$32,361.80
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+Cash Balance Summary
+Cash
+Vet Cash Balance
+....
+OPENING
+837,324.76
+$837,324.76
+CLOSING
+158,276.50
+$158,276.50
+YEAR TO DATE
+37,200.00
+3,654.92
+.......
+$40,854.92
+158,277
+21,932,295
+522,090,572
+027
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 31-6412006
+LAST STATEMENT
+January 26, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+<1%
+- Equities
+99%
+Unshaded portions denote debit balance and or shart
+02/24/01;20:42 001
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AMERICAN HOME PRODUCTS CORP
+AMERICAN INTERNATIONAL GROUP
+BANK OF AMER CORP
+BRISTOL MYERS SQUIBB CO
+..........
+INTERNATIONAL BUSINESS
+MACHINES CORP
+JP MORGAN CHASE & CO
+JOHNSON& JOHNSON
+MENA CORP
+.....•....
+MORGAN STANLEY DEAN WITTER &
+co
+PFIZER INC
+PROCTER & GAMBLE CO
+SIMBOLCUSP
+QUANTITY
+SIMBCLCUSIP
+AHP
+AIG
+BAC
+BMY
+......
+IBM
+JPM
+JNJ
+KRB
+MWD
+PFE
+PG
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+QUANTITY
+20,000
+•.....•....
+20,000
+25,000
+20,000
+.......
+10,000
+37,500
+25,000
+...
+72,000
+30,000
+75,000
+25,000
+PRICE
+PRICE
+59.0000
+80.8500
+49.1400
+61.9400
+104.0000
+47.0500
+95.4900
+.. . .
+32.5500
+67.0000
+44.8200
+75.0300
+158.277
+$158,277
+MARKET
+VALLE
+1,180,000
+1,617,000
+1,228,500
+1,238,800
+....
+1.040.000
+1,764,375
+2,387,250
+2,343,600
+2,010,000
+3,361,500
+1,875,750
+ESTIMATE
+NNUAL INCON
+ESTIMATED
+ANNUAL INCOME
+18,400
+2,960
+56,000
+22,000
+..............
+5,200
+48,000
+2,00
+...
+25,920
+27,600
+33,000
+35,000
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 31-6412006
+LAST STATEMENT
+January 26,2001
+CURREN
+YELD IN
+1.5593
+0.1831
+4.5584
+1.7759
+0.5000
+2.7205
+1.3405
+1.1060
+1.3731
+0.9817
+1.8659
+027
+
+
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+VIACOM INC-CL B
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOLOUSIP
+VIAB
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCT
+CASH
+QUANTITY
+37,000
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEEMENT TREE
+DATE
+TRANSACTION
+02/02/01
+01/30/01
+BOUGHT
+02/02/01 01/30/01 BOUGHT
+PROCTER & GAMBLE CO
+DISCRETIONARY ORDER
+PART OF
+10000 SHR
+PROCTER & GAMBLE CO
+NISCRETIONARY ORDE
+ART OF 10000 SHI
+PRICE
+50.9600
+MARKET
+VALUE
+1,885,520
+$21,932,295
+$21,932,295
+$306,080
+$22,090,571
+ESTIMATED
+ANNUAL INCOME
+$306,080
+$306,080
+CURRENT
+YIELD (%)
+SYMBOLICUS.P
+PG
+PG
+QUANTITY
+1,000
+9,000
+PRICE
+70.70000
+70.75000
+027
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 31-6412006
+LAST STATEMENT
+January 26, 2001
+DEBIT AMOUNT
+71,096.00
+640,314.06
+$711,410.06
+CRECIT AMOUNT
+
+
+245 Pal Anco. no.
+New York, New York 10167
+Transaction Detail (continued)
+DIVIDENDS
+D1730101
+MORGAN STANLEY DEAN WITTER &
+REC 01/12101 PAY 01/30101
+
+•UP MÖRGAN CHASE 8'00"
+REC 01/05/01 PAY 01/31/01
+REC 00501 PAN 020050
+ö2/15/01
+"PROCTER & GAMBLE CO
+REC 01/19/01 PAY 02/15/01
+INTEREST
+DATE
+02/21/01
+INTEREST ON CREDIT BALANCE
+AT 4,000% 01/31 THRU 02/20
+02/21101 INTEREST ON CREDIT BALANCE
+AT 4 1/2% 01/21 THRU 01/30
+SYMBOUCUSIP
+MWD
+JPM
+BMY
+PG
+SYMBOUCUSIP
+QUANTITY
+35,000
+37,500
+20,000
+15,000
+QUANTITY
+RATE (S)
+0.2300
+*0.3200
+0.2750
+0.3500
+RATE (%)
+4.0000
+4.5000
+DEBIT AMOUNT
+DEBIT AMOUNT
+027
+EARED THROUGH 1
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 31-6412006
+LAST STATEMENT
+January 26,2001
+CREDIT AMOUNT
+8,050.00
+"12,000.00
+5,500.00
+5,250.00
+$30,800.00
+CREDIT AMOUNT
+514.40
+1,047.40
+$1,561.80
+
+
+lear, Steams & Co. In
+45 Park Avenue
+New York, New York 10167
+Your messages
+The interest, if any, charged to your account
+STOP
+****** End of Statement******
+027
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 31-6412006
+LAST STATEMENT
+January 26, 2001
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+GREENBERG,ALAN C.
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+....
+Transaction Detail
+LEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 30, 2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 31-6412006
+LAST STATEMENT
+December 29, 2000
+3
+4
+5
+C/O FINANCIAL TRUST COMPANY
+ATTN LARRY KEMP
+6100 RED HOOK QUARTER
+SUITE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+22,565,146
+837,325
+S23,402,471
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+23,043,134
+359,337
+There are no "Stop Loss' orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$837,325
+$388.129
+Cash & Equivalent
+Equities
+$22,565,146
+$22,655,005
+Current market value
+Last statement's market value
+Important Message
+Decimal Trading is Coming!
+Decimal Trading is the shift
+from fractional pricing
+(e.g.21 1/2) to decimal
+pricing (e.g.,$21.50)for
+equities and options.
+All trading on NYSE, AMEX,
+and regional exchanges
+will be in decimals effective
+as of 1/29/01.
+For details, visit our website
+at www.bearsteams.com.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or writo to Cient Sorvices at Bear, Stoams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3659.
+SP The suremen s four or ratanal purger rear die Set revere dae for potamt iformation.
+01/27/01;13:44 001
+
+
+Bear, Steams Securities Corp
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+027
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+Securities Bought
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+3388,128.89
+1,574,112.15
+8,493.12
+$1,582,605.27
+•........
+-1,133,409.40
+.....
+$-1,133,409.40
+449,195.87
+5837.324.76
+Income Summary
+Dividends
+Credit Balance Int.
+Total L
+THIS PERIOD
+6,400.00
+2,093.12
+$8,493.12
+YEAR TO DATE
+6,400.00
+2,093.12
+---.
+$8,493.12
+_...
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total.
+837,325
+22,565,146
+§23.402.471
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+388,128.89
+$388,128.89
+CLOSING
+837,324.76
+......
+$837,324.76
+027
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 30, 2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 31-6412006
+LAST STATEMENT
+December 29,2000
+Your Portfolio
+Allocation
+Cash & Equivalent -
+Equities
+97%
+Unshaded portions denole debe balance andor short
+01/27/01;13:44 001
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+EQUITIES
+Equities & Options
+AMERICAN HOME PRODUCTS CORP
+AMERICAN INTERNATIONAL GROUP
+BANK OF AMER CORP
+BRISTOL MYERS SQUIBB CO
+INTERNATIONAL BUSINESS
+MACHINES CORP
+....
+JP MORGAN CHASE & CO
+JOHNSON& JOHNSON
+MENA CORP
+MORGAN STANLEY DEAN WITTER &
+cO
+PFIZER INC
+PROCTER & GAMBLE CO
+SIMBOLCUSP
+QUANTITY
+SYMBOLCUSIP
+AHP
+AIG
+BAC
+BMY
+IBM
+JPM
+KRB
+MWD
+PFE
+PG
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASH
+CASE
+QUANTITY
+20,000
+20,000
+25,000
+20,000
+10,000
+37,500
+25,000
+72,000
+30,000
+75,000
+15,000
+PRICE
+PRICE
+59.0500
+87.7500
+53.1880
+64.0630
+114.1880
+54.1880
+91.9380
+38.0000
+82.5000
+44.3130
+69.2500
+837,325
+$837,325
+MARKET
+VALUE
+1,181,000
+*........
+1,755,000
+1,329,700
+1,281,260
+1,141,880
+2,032,050
+2,298,450
+2,736,000
+2,475,000
+3,323,475
+1,038,750
+ESTIMATE
+INNUAL INCOM
+ESTIMATED
+ANNUAL INCOME
+18,400
+2,960
+CURREN
+YELD IN
+1.5580
+0.1687
+56.000
+4.2115
+22,000
+1.7171
+... . .
+5,200
+0.4554
+48,000
+12,000
+25,920
+27,600
+2.3621
+1.3922
+0.9474
+1.1152
+33,000
+11,00
+0.9929
+2.0217
+027
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 30, 2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 31-6412006
+LAST STATEMENT
+December 29,2000
+
+
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+VIACOM INC-CLB
+Total Equities& Options
+TOTAL EQUITIES
+SYMBOUCUSIP
+VIAB
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+CASH
+QUANTITY
+37,000
+Transaction Detail
+INVESTMENT ACTIVITY
+SETLEMENT TORTER
+01/02/01
+TRANSACTION
+NAME CHG
+01/02/01
+NAME CHG
+01/03101
+01/02/01
+"SOLD
+CHASE MANHATTAN CORP NEW
+
+TO J001425
+NIC J P MORGAN CHASE&CO
+.........
+JP MORGAN CHASE & CO
+FROM C001559
+IBNA CORR
+DISCRETIONARY ORDER
+PRICE
+53.3130
+MARKET
+VALUE
+1,972,581
+$22,565,146
+$22,565,146
+$292,080
+$23,402,470
+ESTIMATED
+ANNUAL INCOME
+$292,080
+$292,080
+CURRENT
+YELD IN
+SYMBOLCUSIP
+16161A108
+JPM
+KRB
+QUANTITY
+-37,500
+37,500
+-8,000
+PRICE
+36.12500
+027
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 30, 2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 31-6412006
+LAST STATEMENT
+December 29,2000
+DEBIT AMOUNT
+CREDIT AMOUNT
+287,048.72
+
+
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SETTLEMENT TRADE
+DATE
+TRANSACTION
+01/09/01 01/04/01
+BOuGhT
+01/10/0101/05/01
+"BOUGHT
+01/10/01
+01/05/01
+"SOLD
+1/16/0
+01/10/01
+SOLD
+DIVIDENDS
+DATE
+01/02/01
+MBNA CORP
+REC 12/15/00 PAY 01/01/01
+INTEREST
+DATE
+DESCRUPTION
+01/22/01
+INTEREST ON CREDIT BALANCE
+AT 5.000% 12/29 THRU 01/02
+1/22/0
+INTEREST ON CREDIT BALANCE
+AT 5,000% 12/21 THRU 12/28
+///•........
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+AMERICAN HOME PRODUCTS CORP
+AVG PRICE SHOWN-DETALS ON REQ
+ACTUAL CONFIRM TO YOUR AGENT
+AMERICAN HOME PRODUCTS CORP
+AVG PRICE SHOWN-DETAILS ON REQ
+ACTUAL CONFIRM TO YOUR AGENT
+MORGAN STANLEY DEAN WITER &
+DISCRETIONARY ORDER
+MORGAN STANLEY DEAN WITTER &
+AVG PRICE SHOWN-DETAILS ON REO
+ACTUAL CONFIRM TO YOUR AGENT
+SYMBOUCUSIP
+KAB
+SYMBOUCUSIP
+SYMBOLCUSIP
+AHP
+AMP"
+MWD
+MWD
+QUANTITY
+80,000
+QUANTITY
+RATE (S)
+0.0800
+RATE (%)
+5.0000
+5.0000
+QUANTITY
+5,200
+14,800
+- 10,000
+-5,000
+PRICE
+54.47300
+56.99630
+86.81250
+85.21630
+DEBIT AMOUNT
+DEBIT AMOUNT
+027
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD December 30,2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 31-6412006
+LAST STATEMENT
+December 29, 2000
+DEBIT AMOUNT
+285,024.34
+CREDIT AMOUNT
+*848,385.06
+863,402.30
+423,661.13
+$1,574,112.15
+$-1,133,409.40
+CAEDIT AMOUNT
+6,400.00
+$6,400.00
+CAEDIT AMOUNT
+270.42
+....
+431.25
+
+
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Transaction Detail (continued)
+INTEREST (continued)
+DATE
+01/22/01
+INTEREST ON CREDIT BALANCE
+AT 4 1/2% 01/03 THRU 01/20
+SYMBOUCUSIP
+QUANTITY
+RATE INI
+4.5000
+DEBIT AMOUNT
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 30, 2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER 31-6412006
+LAST STATEMENT
+December 29,2000
+CREDIT AMOUNT
+1,391.45
+$2,093.12
+STOP
+****** End of Statement******
+027
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/f2ff887cd5396d5f35f3c61ab7a1583413193d800f768d2b87ee8d861afe4e14.receipt.json b/vision-fixhub/ds9-unparsed-05/f2ff887cd5396d5f35f3c61ab7a1583413193d800f768d2b87ee8d861afe4e14.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f4015b5c6acb29db4cb6a6be2dc47498433637fa
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f2ff887cd5396d5f35f3c61ab7a1583413193d800f768d2b87ee8d861afe4e14.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -11222,
+  "dataset": "marble-joined",
+  "doc_id": "f2ff887cd5396d5f35f3c61ab7a1583413193d800f768d2b87ee8d861afe4e14",
+  "engine": "marble-apple-vision",
+  "event_count": 90,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "49fa3ad2e706bb749820b8fde2765526a000b89380da576100f62612a27df692",
+  "output_sha256": "d21e27cd0b997f4387a6f93c0a38396ef3922cb0a4caee43c0228c5584c7cf3d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/f319e6bff744684ba0b6a55e59187d17ed08907b7165c2a8e2973959ed222a8d.md b/vision-fixhub/ds9-unparsed-05/f319e6bff744684ba0b6a55e59187d17ed08907b7165c2a8e2973959ed222a8d.md
new file mode 100644
index 0000000000000000000000000000000000000000..f4b33a38799e3a8816a9363d23b634302cc40314
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f319e6bff744684ba0b6a55e59187d17ed08907b7165c2a8e2973959ed222a8d.md
@@ -0,0 +1,107 @@
+OLY-41
+
+
+TO: Adult Video Warehouse
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-41
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTS]
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+May 1, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following document(s) or objects):
+All records and information referring or relating to invoice # 679654 dated 7/23/05, including all records
+and information referring or relating to transactions with
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+vour appearance with Special Agen
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+DATE:
+April 16, 2007
+CLERK
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the United States of America
+*If not applicable, enter "none."
+Name, Address and Phone Number of Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL. 33401-6235
+Tel!
+K3047
+Fax
+To be used in lieu of AO110
+FORM ORD-227
+JAN.86
+
+
+U.S. Departme
+of Justice
+United States Attorney
+Southern District of Florida
+500 S. Anstralian Ave, Suite 400
+West Palm Beach, FL 33401-6235
+(561) 820-8711
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+authenticity. Therefore, you may be able to avoid appearing personally at the grand
+jury/trial at the time and place specified by completely filling out the attached Certification
+and Inventory and immediately returning it with the records to Special Agent t
+, FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to May 1, 2007.
+Sincerely,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+BY:
+ASSISTANT UNITED STATES ATTORNEY
+
+
+CERTIFICATION OF BUSINESS RECORDS
+1, the undersigned,
+employed bylassociated with
+position of
+, declare that 1 am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+Date of execution:
+Place of execution:
+Signature:
+-
+
+
+APPENDIX A
+DOCUMENT INVENTORY
+The documents submitted are as follows:
+Signature of Records Custodian:
diff --git a/vision-fixhub/ds9-unparsed-05/f319e6bff744684ba0b6a55e59187d17ed08907b7165c2a8e2973959ed222a8d.receipt.json b/vision-fixhub/ds9-unparsed-05/f319e6bff744684ba0b6a55e59187d17ed08907b7165c2a8e2973959ed222a8d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0f5150c3195352ef6e6c31341f7778099b27987f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f319e6bff744684ba0b6a55e59187d17ed08907b7165c2a8e2973959ed222a8d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -60,
+  "dataset": "marble-joined",
+  "doc_id": "f319e6bff744684ba0b6a55e59187d17ed08907b7165c2a8e2973959ed222a8d",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "2430991c4e8e932dab757cf3b95afb7ef8065fb87806883b475fdeef0aea587a",
+  "output_sha256": "f81aa39131a85d07be697ed661e707b9a72ebd97f315cb853a63720c3eb394b7",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/f351dfa1d57b7dd94793bab7ea800be21d66f252de75839bf83fe1cb1fe587bb.md b/vision-fixhub/ds9-unparsed-05/f351dfa1d57b7dd94793bab7ea800be21d66f252de75839bf83fe1cb1fe587bb.md
new file mode 100644
index 0000000000000000000000000000000000000000..b7c579e32b437be4a304b24b810a27a3c87bfc85
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f351dfa1d57b7dd94793bab7ea800be21d66f252de75839bf83fe1cb1fe587bb.md
@@ -0,0 +1,92 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+West Palm Beach, FL 33401
+500 S. Australian Ave, Ste 400
+Facsimile:
+June 12, 2009
+DELIVERY BY ELECTRONIC MAIL
+Jay P. Lefkowitz, Esq.
+Kirkland & Ellis LLP
+Citigroup Center
+153 East 53rd Street
+New York, New York 10022-4675
+Re: Jeffrey Epstein
+Dear Jay:
+I write to confirm our conversation of this afternoon. As I mentioned, the U.S. Attorney's
+Office is not a party to any of the civil litigation between Mr. Epstein pending in the U.S. District
+Court or any state court and takes no position regarding those lawsuits. The U.S. Attorney's
+Office is not advising or requiring that Mr. Epstein take any action regarding those lawsuits,
+rather, Mr. Epstein should proceed as he sees fit. The U.S. Attorney's Office will continue to
+exercise its independent judgment and proceed in accordance with its rights under the Non-
+Prosecution Agreement. My statements during our conversation and during the court proceeding
+contained no promises and did not alter or modify the Non-Prosecution Agreement.
+I would like to address what appears to be a continuing pattern in this matter. There have
+been several instances of breaches of the letter and spirit of the Non-Prosecution Agreement by
+Mr. Epstein. As soon as Notice is provided by the United States, we are told that Mr. Epstein
+"was relying on his lawyers" and had not intended to willfully breach the Agreement.
+Mr.
+Epstein then undertakes a perfunctory "cure" and continues the enjoy the benefit of his bargain
+until he decides to breach yet again.
+Notifications of breach have been provided on several occasions in the past. From the
+start, Mr. Epstein did not use his "best efforts" to enter his guilty plea and be sentenced within the
+time frame set by the Agreement. After several baseless appeals were made throughout the
+Department of Justice resulting in a nine-month delay, the U.S. Attorney's Office had to remind
+Mr. Epstein of his obligation to provide a copy of the plea agreement with the State Attorney's
+Office prior to his entering into that agreement. Despite numerous requests, the proposed state
+plea agreement and notice of the state change of plea were not provided until I sent a notice of
+breach at 3:15 p.m. the last business day before the plea. Thereafter, I received a copy of the
+proposed state agreement, which contained language that directly contradicted the Non-
+Prosecution Agreement. Another notice of breach had to be prepared and sent to bring the state
+plea agreement into compliance.
+After Mr. Epstein entered his guilty plea and was sentenced, another set of problems arose.
+Mr. Epstein's counsel obstructed our ability to abide by our obligations to notify the victims of
+the outcome of the federal investigation and refused to fulfill promptly Mr. Epstein's obligation
+to secure the services of an attorney representative for the victims. At the same time, Messrs.
+Goldberger and Tein approved the dissemination of a victim notification letter that you and Mr.
+Epstein contended contained incorrect information. Mr. Epstein's counsel then informed the
+Court that a motion to quash subpoenas was still pending, despite the Non-Prosecution
+
+
+Agreement's requirement that Mr. Epstein withdraw that motion. Extensive correspondence and
+telephone conferences were required to resolve these breaches.
+In November, more issues arose when we learned - not from Mr. Epstein or his attorneys
+- that Mr. Epstein had applied for and was admitted to the Palm Beach County Sheriff's Office's
+work release program. This was done without any notification to our Office, leaving the Office
+in jeopardy of being accused again of violating our victim notification obligations. It also
+directly contradicted correspondence and discussions between Ms. Atkinson, Mr. Goldberger, Mr.
+Black, and myself that Mr. Epstein would remain in jail "twenty-four hours a day." Our
+investigation of Mr. Epstein's application for the work release program further demonstrated that
+Mr. Epstein made several false statements in his application and made threatening statements to
+the Palm Beach Sheriff's Office about legal repercussions if he was not admitted to the program.
+I also discovered - again, not from Mr. Epstein or his attorneys - that Judge McSorley had
+modified Mr. Epstein's judgment nunc pro tunc to an "Order of Community Control I," which
+directly contradicted the terms of the Non-Prosecution Agreement. This required yet another
+Notice of Breach and another claim that there was no "intended breach" followed by a
+meaningless "cure."
+During our conversation today, and during the hearing before Judge Marra, I heard again
+that Mr. Epstein had no intent to breach the Non-Prosecution Agreement but was merely relying
+on his attorneys. In light of the fact that Mr. Epstein is highly intelligent and experienced with
+the law, and is reportedly spending more than twelve hours a day at his attorney's office, working
+on nothing but the litigation pending against him, this excuse will not be accepted. Furthermore,
+while Mr. Epstein has continued to receive the benefit of his bargain by not facing federal
+prosecution, our Office has not received the benefits of finality, savings of resources, or the
+punishment and victim restitution terms envisioned by the Non-Prosecution Agreement.
+As I mentioned in our telephone call, I have asked Mr. Josefsberg to provide me with the
+correspondence that he referenced during the hearing before Judge Marra. That will be reviewed
+to determine if there has been yet another breach by Mr. Epstein. As I stated, and as mentioned
+in the Notice Letter served upon Mr. Goldberger, notice of any breaches that we discover will be
+provided as required by the Non-Prosecution Agreement. Our Office also will review the new
+pleading in the Jane Doe 101 matter that you mentioned, prior to deciding what, if any, remedies
+we will pursue for Mr. Epstein's breach. However, I note that, while the U.S. Attorney's Office is
+required to provide notice of any breach, there is no requirement that Mr. Epstein be allowed the
+opportunity to cure any breach. The pattern of behavior described above will be factored into the
+Office's decision on what remedies it will pursue in connection with this most recent breach and
+any future violations.
+Sincerely,
+Jeffrey H. Sloman
+Acting United States Attorney
+By:
+Assistant United States Attorney
+cc:
+Chief, Northern Division
diff --git a/vision-fixhub/ds9-unparsed-05/f351dfa1d57b7dd94793bab7ea800be21d66f252de75839bf83fe1cb1fe587bb.receipt.json b/vision-fixhub/ds9-unparsed-05/f351dfa1d57b7dd94793bab7ea800be21d66f252de75839bf83fe1cb1fe587bb.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..cd4bdcbcf6cb8895f89cebc7f4cfe1bd7093fb51
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f351dfa1d57b7dd94793bab7ea800be21d66f252de75839bf83fe1cb1fe587bb.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "f351dfa1d57b7dd94793bab7ea800be21d66f252de75839bf83fe1cb1fe587bb",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "5f993a836fc24e9c04ef3e065b9ebf7d4eebe3d0f5f360854e60bd69b84aeaeb",
+  "output_sha256": "b53ebd03f950777cef52e42d5d972bf4cf27d6cbf16b0ae4e1d94d2934e16234",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/f447a7f643f7f8cb1a89871d0ce0414d5ed01e12f6e2666236e06cee0aadfd4c.md b/vision-fixhub/ds9-unparsed-05/f447a7f643f7f8cb1a89871d0ce0414d5ed01e12f6e2666236e06cee0aadfd4c.md
new file mode 100644
index 0000000000000000000000000000000000000000..59e612c726c955ac170bbd1c6bb4282e79587ef8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f447a7f643f7f8cb1a89871d0ce0414d5ed01e12f6e2666236e06cee0aadfd4c.md
@@ -0,0 +1,52 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+December 12, 2008
+VIA UNITED STATES MAIL
+Miss
+B-100
+Re:
+Jeffrey Epstein/
+Notification of Work Release
+Dear Ms.
+By virtue of this letter, the United States Attorney's Office hereby provides you with notice
+that the U.S. Attorney's Office has learned that Jeffrey Epstein has applied to participate in the Palm
+Beach County Sheriff's Office's ("PBSO") work release program, and PBSO has granted that
+application. Mr. Epstein is reportedly working for The Florida Science Foundation at
+. After work each day, Mr. Epstein
+returns to the Palm Beach County Stockade. While outside the Stockade, Mr. Epstein is
+electronically monitored via a GPS system and an ankle bracelet. Pursuant to the work release rules,
+Mr. Epstein is to go directly from the Stockade to his office, remain at the office throughout the work
+day, and then return directly to the Stockade.
+We regret that we were unable to inform you of these developments prior to Mr. Epstein's
+release, but our Office was never notified of Mr. Epstein's application, and we only learned of his
+release more than six weeks after he began participating in the program. Should you have any
+questions regarding the work release program, please direct your inquiries to Captain
+Palm Beach Sheriff's Office,
+It is my understanding that you have not retained counsel to represent you with regard
+to any litigation against Mr. Epstein. It is important that you inform me if you do hire an
+attorney so that I may communicate with you through that attorney, or if you change your
+
+
+MISS :
+NOTIFICATION OF WORK RELEASE
+DECEMBER 12, 2008
+
+address or telephone number. As I mentioned in my earlier correspondence, Robert
+Josefsberg and his firm were selected by an independent Special Master to represent the
+identified victims of Mr. Epstein with certain limitations, which Mr. Josefsberg can explain.
+Again, you have no obligation to select Mr. Josefsberg as your counsel, but if you would like
+to have Mr. Josefsberg represent you, you must contact him or his partner, Katherine Ezell,
+directly at
+via e-mail at
+and
+(If you contact them via e-mail please reference Mr. Epstein in your
+e-mail.) Please note that, even if you decide not to pursue a claim against Mr. Epstein, Ms.
+Ezell has put together a team of counselors who can assist you with any counseling or other
+services that you might need. You also can continue to contact the FBI's Victim Services
+My best wishes for a peaceful holiday season.
+R. Alexander Acosta
+United States Attorney
+cc:
+Robert Josefsberg, Esq.
+Katherine Ezell, Esq.
diff --git a/vision-fixhub/ds9-unparsed-05/f447a7f643f7f8cb1a89871d0ce0414d5ed01e12f6e2666236e06cee0aadfd4c.receipt.json b/vision-fixhub/ds9-unparsed-05/f447a7f643f7f8cb1a89871d0ce0414d5ed01e12f6e2666236e06cee0aadfd4c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..cac4d89a92877927b150cbf538c6acce6ac63c3a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f447a7f643f7f8cb1a89871d0ce0414d5ed01e12f6e2666236e06cee0aadfd4c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -35,
+  "dataset": "marble-joined",
+  "doc_id": "f447a7f643f7f8cb1a89871d0ce0414d5ed01e12f6e2666236e06cee0aadfd4c",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "daaf24245da384276c4c14f1fd269a183d2d46f5e7ea18475894dd0ffdd04af6",
+  "output_sha256": "90bca63f690be5f99ed1bf48daad41a030c187c4e8c463553d36a481436cae2f",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/f4484ba3dc6f88fca8d8348c1767cd91ce0c9d1d750d1015c9ff61471141917a.md b/vision-fixhub/ds9-unparsed-05/f4484ba3dc6f88fca8d8348c1767cd91ce0c9d1d750d1015c9ff61471141917a.md
new file mode 100644
index 0000000000000000000000000000000000000000..e2f4a86249987b8cdfb4473cfc43b7220bf7d5f9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f4484ba3dc6f88fca8d8348c1767cd91ce0c9d1d750d1015c9ff61471141917a.md
@@ -0,0 +1,504 @@
+Statements
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+GNMA GOVT BOND
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocktyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 29,2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Avallable
+LAST STATEMENT
+June 27, 2003
+What's In This Statement
+Financial Summar...........................
+Transaction Detail
+Your Messages
+1
+2
+3
+Hollandlml
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN &
+6100 RED HOOK QUARTER STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+Miscellaneous
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+1,628,951.45
+24,679.06
+$1,653,630.51
+•••••••••••!!!
+-1,653,630.51
+......
+- 1.653.630.51
+$0.0
+Income Summary
+THIS PERIOD
+Corp. Bond Int.
+24,679.06
+Total.
+$24.679.06
+Bond Purchase Int.
+0.00
+YEAR TO DATE
+24,679.06
+$24.679.06
+-19,175.33
+Important Message
+any information regardir
+003interest, dividend
+iscellaneous incom
+ross proceeds or origina
+ĐeMarch 15,2004. a 10425
+STP Thie urener s foul er ratanel ptr yer rebr de Set revere date fr postamt itformation.
+
+
+2 or 4
+Transaction Detail
+INVESTMENT ACTIVITY
+SATE EMENT TATE
+DATE
+TRANSACTION
+12/04/03 12/01/03
+SOLD
+12/04/03 12/01/03 SOLD
+12/04/03
+12/01/03
+SOLD
+1204/03
+RECEIVED
+1204/03
+12204/03
+TOTAL
+RECEIVED
+RECEIVED
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ESCRIPTION
+ANNIE MAE CMO/SERIES 2002-83
+SK-VO FLTR
+BS
+... .
+FANNIE MAE CMO/SERIES 2002-82
+SK-VO FLTR
+DUE 10/25/2031 06 9318
+EF #
+BS
+S OF 12/0110
+FANNIE MAE CMO/SERIES 2002-82
+SK-VO FLTR
+
+6.931
+FANNIE MAE CO/SERIES 2002-82
+FANNIE MAE CMOVSERIES 2002-82
+SK-VO FLTR
+6.931 DUE 10/25/31
+DUE 10/25/2031
+6.931
+SYMBOLCUSP
+31392FS73
+31392FS73
+31392FS73
+31392FS73
+31392FS73
+31392FS73
+027
+QUANTITY
+-2,848,439
+3,560,549
+-7,833,209
+2,848,439
+PRICE
+11.43750
+ACCR. INT.
+•.-..
+437
+ACCR. INT.
+11.43750
+ACCR. INT.
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+June 27, 2003
+DEBIT AMOUNT
+CREDIT AMOUNT
+325,790.29
+4,935.81
+.....
+07, 237.86
+6,169.77
+895,923.30
+13,573.48
+30,726.1
+3,560,549
+7.833,209
+413,407.63
+909,496.78
+$-1,653,630.51
+$1,653,630.51
+V919
+
+
+3 of 4
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your messages
+Excess SIPC Account Protection Update
+Bear, Stearns Securities Corp, ('BSS'), a member of the Securities Investor
+Protection Corporation ("SIPC"), provides account protection for the net equity
+Coverage*). Visit www.sipc.org for more information about SIPC Coverage
+BSSC provides the additional protection ("Excess SIPC") through a commercial
+insurer. Effective February 16, 2004, the commercial insurer for Excess SIPC
+will change to Customer Asset Protection Company (CAPCO*), a licensed New
+York insurance company. Account protection applies when a SIPC member
+firm fails financially and is unable to meet its obligations to its securities
+customers, but does not apply to losses from the rise or fall in the market
+value of investments or to SIPC ineligible assets such as options, futures,
+foreign exchange transactions, or any investment contracts that are not
+registered as securities.
+STOP
+****** End of Statement******
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 29, 2003
+THROUGH
+December 31, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+June 27,2003
+
+
+4 of 4
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+GNMA GOVT BOND
+What's In This Statement
+Financial Summ........................
+Transaction Detail
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Avallable
+LAST STATEMENT
+May 30, 2003
+Hollandlol
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN &
+6100 RED HOOK QUARTER STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Amount Credited
+.................
+Securities Bought
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Closing Balance
+•••••••••••••
+THIS PERIOD
+$0.00
+....
+8,785,798.50
+19,175.34
+$8.804,973.84
+-5,397,045.76
+-19,175.33
+-3,388,752.75
+§-8.804.973.84
+50.00
+Income Summary
+Bond Purchase Int.
+THIS PERIOD
+0.01
+YEAR TO DATE
+-19,175.33
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+06/28/03;12:23 001
+7909
+
+
+2 org
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEEMENT TRIE
+TRANSACTION
+06/03/03
+04/29/03
+BOUGHT
+06/03/03
+04/29/03
+CANCEL BUY
+0/E0/90
+06/03/03
+06/12/03
+06/12/03
+TOTAL
+06/10/03
+DIK
+DELIVERED
+SOLD
+RECEIVED
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+FEDERAL NATIONAL MG ASSN
+SERIES 2003-49 CLASS SW
+DUE 01/25/2033 05 680%
+REF#
+BS
+AS OF TD 0423NUS S0 05750/03
+AS OF 04/29/03
+INTR COMPUTED TO 05/30/03
+FEDERAL NATIONAL MIG ASSN
+AS CAL PREVIOUS BUY
+"FEDERAL NATIONAL MG ASSN
+SERIES 2003-49 CLASS SI
+680 DUE 01/25K
+.. . .
+FEDERAL NATIONAL MTG ASSN
+SERIES 2003-49 CLASS SW
+5,680 DUE 01/25/3
+LE 01/25/2033
+5 680
+FEDERAL NATIONAL MIG ASSN
+STRIPS SERIES 326 CLASS 1 PO
+DUE 07/01/2032 00 0018
+BS
+AS OF UETUNUS
+.. . .
+FEDERAL NATIONAL MG ASSA
+STRIPS SERIES 326 CLASS 1 PO
+),001 DUE 07/01/3
+TIE 07001/208
+0 p01
+SYMBOLICUSIP
+027
+PRICE
+11.06250
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 31,2003
+THROUGH
+June 27, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Avallable
+LAST STATEMENT
+May 30, 2003
+DEBIT AMOUNT
+2,688,935.21
+19,175.33
+CREDIT AMOUNT
+QUANTITY
+24,306,759
+ACCR. INT.
+-24,306,759
+11.06250
+ACCR. INT.
+2.688,935.21
+19,175.34
+24,306,759
+-24,306,759
+-3,561,835
+3,561,835
+2,708,110.55
+2,708,110.54
+95.14063
+3,388,752.75
+06/28/03;12:23 001
+3.388,752.75
+$-8,804,973.84
+vace
+$8,804,973.84
+
+
+3 of 3
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+06/28/03;12:23 001
+4909
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+GNMA GOVT BOND
+What's In This Statement
+Financial Summary •••••••••••••••••...C
+Transaction Detail
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+December 31, 2002
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN &
+6100 RED HOOK QUARTER STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Amount Credited
+Securities Bought
+Dividends/Interest Charged
+Amount Debita.
+Closing Balance
+THIS PERIOD
+$0.00
+2,708,110.55
+... ..
+52,708,110.55
+-2,688,935.21
+-19,175.34
+.........
+-2,708,110.5:
+$0.00
+Income Summary
+THIS PERIOD
+Bond Purchase Int.
+-19,175.34
+VEAR TO DATE
+-19,175.34
+PC This summary is for informational purposes only. It is not intended as a tax docum
+This statement should be retained for your records. See reverse side for important informat
+05/31/03;16:24 001
+
+
+2 org
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT TRADE
+DATE
+TRANSACTION
+05/30/03
+04/29/03
+BOUGHT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+05/30/03
+DELIVERED
+DESCRIPTION
+FEDERAL NATIONAL MIG ASSN
+SERIES 2003-49 CLASS SW
+REF 01252033 05.680%
+AS OF 04/29/03
+"FEDERAL NATIONAL MIG ASSN
+SERIES 2003-49 CLASS SW
+5,680 DUE 01/25/33
+DUE 01/25/2033
+5.680
+TOTAL
+STOP
+End of Statement******
+SYMBOLGUSP
+QUANTITY
+24,306,759
+ACCR. INT.
+PRICE
+11.06250
+-24,306,759
+027
+05/31/03;16:24 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 26,2003
+THROUGH
+May 30, 2003
+ACCOUNT NUMBER
+TAXPAYER NUMBER Not Available
+LAST STATEMENT
+December 31, 2002
+DEBIT AMOUNT
+2,688,935.21
+19,175.34
+CRECIT AMOUNT
+2,708,110.55
+$-2,708,110.55
+$2,708,110.55
+
+
+3 of 3
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+05/31/03;16:24 001
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/f4484ba3dc6f88fca8d8348c1767cd91ce0c9d1d750d1015c9ff61471141917a.receipt.json b/vision-fixhub/ds9-unparsed-05/f4484ba3dc6f88fca8d8348c1767cd91ce0c9d1d750d1015c9ff61471141917a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..42244e65029396e7603a5f06427305eb7b5632dd
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f4484ba3dc6f88fca8d8348c1767cd91ce0c9d1d750d1015c9ff61471141917a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -702,
+  "dataset": "marble-joined",
+  "doc_id": "f4484ba3dc6f88fca8d8348c1767cd91ce0c9d1d750d1015c9ff61471141917a",
+  "engine": "marble-apple-vision",
+  "event_count": 13,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "de0b5925868617b0a7d975e1e24af73f7fac5a9c785c0383a819e7e5c010a511",
+  "output_sha256": "f7f54a8d6292ebc7766f421e6ef2ad1a118be12ca826d38e2f90d79b46aa2e0f",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/f45deaa9f2df4499b280370b1f61a6dfb581bb635919b9b4001804a923c38167.md b/vision-fixhub/ds9-unparsed-05/f45deaa9f2df4499b280370b1f61a6dfb581bb635919b9b4001804a923c38167.md
new file mode 100644
index 0000000000000000000000000000000000000000..fd8a8559fa28be3b07e3151f0283a19d4d7ab492
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f45deaa9f2df4499b280370b1f61a6dfb581bb635919b9b4001804a923c38167.md
@@ -0,0 +1,52 @@
+OLY-07
+
+
+TO:
+David Neville Rodgers
+Lake Worth, FL 33467
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-07
+SUBPOENA FOR:
+x PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+ROOM:
+Room 4-A
+DATE AND TIME:
+August 18, 2006
+9:00am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+Any and all information and records related to Jeffrey Epstein, Gulfstream Aircraft N909JE, and Boeing
+Aircraft N908JE, including but not limited to flight records, maintenance records, and passenger manifest
+records. Any and all records related to your employment, including but not limited to paystubs, W-2
+forms, correspondence, employment applications, and employment reviews.
+Please coordinate your compliance of this subpoena and confirm the date and time of your appearance with
+Special Agent
+, Federal Bureau of Investigation, Telephone:
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+(BY) DEPUTY CLERK
+DATE:
+August 2, 2006
+This subpoena is issued upon application
+of the United States of America
+*If not applicable, enter "none."
+Name, Address and Phone Number of Assistant U.S. Attorney
+300 S0. Australian Avenue, Suite 400
+West Palm Reach. FL. 33401-6235
+Tel
+Fax
+To be used in lieu of AQLIO
+FORM ORD-227
diff --git a/vision-fixhub/ds9-unparsed-05/f45deaa9f2df4499b280370b1f61a6dfb581bb635919b9b4001804a923c38167.receipt.json b/vision-fixhub/ds9-unparsed-05/f45deaa9f2df4499b280370b1f61a6dfb581bb635919b9b4001804a923c38167.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d2d0d6438e0158193ef11810beac8534df64a80d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f45deaa9f2df4499b280370b1f61a6dfb581bb635919b9b4001804a923c38167.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "f45deaa9f2df4499b280370b1f61a6dfb581bb635919b9b4001804a923c38167",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "7710a10440fefa91ac60f64a477f0f5b72e849ecf7068ddd70929a684a3d9659",
+  "output_sha256": "f42347962b69e126265ee2271639fcd2a9bb835f0ab9df6dc77225e38f335f15",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/f539c7603b3460ea4759c5f8645bcdb948907421bcc4492ac50f64f858388889.md b/vision-fixhub/ds9-unparsed-05/f539c7603b3460ea4759c5f8645bcdb948907421bcc4492ac50f64f858388889.md
new file mode 100644
index 0000000000000000000000000000000000000000..c3a110638992d21c87d3a6a28a707f523871cf0a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f539c7603b3460ea4759c5f8645bcdb948907421bcc4492ac50f64f858388889.md
@@ -0,0 +1,2 @@
+Native Placeholder
+No Images Produced
diff --git a/vision-fixhub/ds9-unparsed-05/f539c7603b3460ea4759c5f8645bcdb948907421bcc4492ac50f64f858388889.receipt.json b/vision-fixhub/ds9-unparsed-05/f539c7603b3460ea4759c5f8645bcdb948907421bcc4492ac50f64f858388889.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..253886605aad64f35b9f9fb98ef215361fd25d37
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f539c7603b3460ea4759c5f8645bcdb948907421bcc4492ac50f64f858388889.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "f539c7603b3460ea4759c5f8645bcdb948907421bcc4492ac50f64f858388889",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "6352c188c30a62c4b9c4b372f6ecfbdccb6c956917370d7cabe6103a8ea7ccd8",
+  "output_sha256": "846cc48c4d9439d88bbfa81198172eb50ef898abf3a9ac9c30fcf62adcd7ff8c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/f677046d8a9ac7d5b1aa9e4357f333c14bceb621c4a7bf7089512eda7f279ed3.md b/vision-fixhub/ds9-unparsed-05/f677046d8a9ac7d5b1aa9e4357f333c14bceb621c4a7bf7089512eda7f279ed3.md
new file mode 100644
index 0000000000000000000000000000000000000000..fd440bc7d64808c7ad463421c025b38b639f8fdf
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f677046d8a9ac7d5b1aa9e4357f333c14bceb621c4a7bf7089512eda7f279ed3.md
@@ -0,0 +1,10344 @@
+Condensed Transcript
+IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN
+AND FOR PALM BEACH COUNTY, FLORIDA
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Case No. 502008CA028051
+XXXXMB AD
+Defendan..
+DEPOSITION OF
+LARRY EUGENE MORRISON
+TAKEN ON BEHALF OF THE PLAINTIFF
+VOLUME I
+Pages 1 to 200
+October 6, 2009
+10:55 a.m.
+515 N. Flagler Drive
+West Palm Beach, FL 33401-4321
+, court reporter
+nder Gallo Company
+
+
+
+
+IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN
+AND FOR PALM BEACH COUNTY,
+FLORIDA
+VOLUME I
+Pages 1 to 200
+Plaintiff,
+vB.
+JEFFREY EPSTEIN,
+1 Case
+1X33x BA 502008CA028051
+Defendant.
+DEPOSITION OF
+LARRY EUGENE MORRISON
+TAKEN ON BEHALF OF THE PLAINTIFI
+October 6,
+2009
+10:55 a.m.
+- 2:20 p.m.
+lest Palm Beach, FL 33401-432:
+court reporter
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+APPEARANCES OF COUNSEL
+On behalf of the Plaintiff L.M.:
+ROTHSTEIN, ROSENFELDT & ADLER
+BY: BRADLEY J. EDWARDS, ESQ
+and MICHAEL WHEELER, ESQ.,
+401 East Las Olas Boulovard
+Suite 1650
+Fort Lauderdale, FL 33394
+On behalf of Plaintiffs Jane Doe 2 through 8:
+MERMELSTEIN & HOROWITZ, P.A.
+BY: JESSICA D. ARBOUR, ATTORNEY-AT-LAW,
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+On behalf of Plaintiffs lane Doe 101 and 102 by
+Salephone:
+PODHURST ORSECK, P.A.
+BY: KATHERINE W. EZELL, ATTORNEY-AT-LAW,
+25 W. Flagler Street
+Miami, FL 33130
+On behalf of the Plaintiff C.M.A. by balaphone:
+LAW OFFICE OF RICHARD WILLITS, P.A.
+BY: RICHARD WILLITS, ESO.,
+2290 10th Avenue N.
+Lake Worth, FL 33461
+4
+5
+10
+11
+14
+15
+16
+17
+18
+19
+20
+21
+23
+24
+25
+1
+w M
+4
+5
+6
+10
+111
+|12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+October 6, 2009
+3
+APPEARANCE OF COUNSEL
+On behalf of the Defendant:
+ATTERBURY, GOLDBERGER & WEIS
+BY: JACK ALAN GOLDBERGER, ESQ.
+250 Australian Avenue
+Suite 1400
+West Palm Reach, FL 33401
+On behalf of the Defendant by telephone:
+515 N. Flagler Drive
+Suite 400
+West Palm Roach, FL 33401
+On behalf of the witness:
+LAW OFFICE OF BRUCE E. REINHART
+BY: BRUCE E. REINHART, ESO.,
+One Clearlake Center
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+4
+INDEX OF EXAMINATION
+WITNESS:
+LARRY EUGENE MORRISON
+Page
+DIRECT EXAMINATION
+By Mr. Edwards
+#5
+CROSS-EXAMINATION
+By Ms. Ezell
+CROSS-EXAMINATION
+By Mr. Willits
+#190
+#195
+CROSS-EXAMINATION
+By Mr. Pike
+#196
+FURTHER REDIRECT EXAMINATION
+By Mr. Edwards
+#199
+INDEX TO EXHIBITS
+Plaintiff's
+
+Page
+1
+Twenty-four pages of "JEGE, Inc.,
+Passenger Manifest.*
+#138
+(Plaintiff's Composite 1 was attached to the
+original transcript and copies of the transcript.)
+
+
+10
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+5
+Deposition of LARRY EUGENE MORRISON
+October 6, 2009
+THE REPORTER: Do you swear the testimony
+you're about to give will be the truth, the
+whole truth, and nothing but the truth so help
+you God?
+THE WITNESS: So help me God.
+LARRY EUGENE MORRISON, having been first
+duly sworn, was examined and testified as
+follows:
+DIRECT EXAMINATION
+BY MR. EDWARDS:
+Q. Tell us your name.
+A. Larry Morrison.
+Q. And, Larry, where are you employed right now?
+A. For JEGE.
+Q. What's JEGE mean?
+A. It's the aviation flight department for
+Mr. Epstein, and my primary job is Dankjold Reed
+Aviation.
+MR. REINHART: Spell it.
+A. D-A-N-K-J-O-L-D, and then the second word
+is Reed, R-E-E-D, Aviation. It's a corporate flight
+6
+department.
+Q. What do you do for him?
+A. Director of Maintenance.
+Q. Okay, so you maintain his planes --
+A. Correct.
+Q. " should something go wrong?
+A.
+Correct. Yes. Yep.
+Q.
+Do you also --
+A. For maintenance.
+Q. Do you also fly on his planes?
+A. On Mr. Epstein's?
+Q. Yes.
+A. I used to. I was a flight engineer --
+Q. Okay. What --
+A. - on his 727.
+Q. When you list your company - JEGE?
+A. Yes. Yeah, it's just initials. It's an
+LLC or holding company.
+Q. How long has that holding company been around,
+if you know?
+A.
+Since -- I think it was developed when I
+came with the airplane - 2001.
+Q. Whose idea was it for that to come about - was
+it yours? Was it his?
+A.
+Oh, no, no, somewhere - It wasn't mine.
+1
+2
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+113
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alezaader Galla Company
+October 6, 2009
+7
+You know, it was a business decision made somewhere.
+Q. What does the company do?
+A. What? The company? It's just a holding
+company, I think, for the aircraft. It's not - |
+don't believe it to be a money making company or a
+real corporation.
+Q. You're saying "for the aircraft." I'm
+interpreting that to mean you're talking about one
+aircraft.
+A. Correct.
+Q. Does that mean there's one or there's more
+than one?
+A. There's more. He owns more than one, but
+just one is JEGE or --
+Q. And the aircraft that he owns, how many of
+those do you either service and/or ride on?
+A. I used to. I haven't been - Actually.!
+stepped back from being physically involved, just -
+now I just do paperwork - and it was February of
+2007. So I haven't actually physically been on the
+airplanes other than I will take the Boeing for
+maintenance.
+Q. Since it seems like we've kind of skipped
+ahead from 2001 to 2007, am I right that your first
+involvement with Jeffrey Epstein of any way, shape, or
+8
+form was 2001?
+A. That's correct, yeah.
+Q. You didn't meet him before that.
+A. I had met him. He was a - He was an
+associate of my previous boss.
+Q. Who's that?
+A. Mr. Wexner.
+Q.
+Wexner?
+A.
+Yes.
+Q. How do you know
+Wexner?
+A. I worked for Limited Stores for 12 years.
+Q. Doing what?
+A. Essentially the same thing - aircraft
+maintenance for their corporate flight department and
+flight engineering on the 727.
+Q. How many aircraft did
+Wexner have?
+A. Well, none that I know that he had
+personally, but the corporation had - the flight
+department operated - we had three Gulfstreams, two
+Hawkers, and a 727.
+Q. What was the name of his corporation that
+maintained the aircraft?
+A. For Limited Stores?
+Q.
+Yes.
+A.
+It was just - It was called Limited -
+
+
+1
+3
+4
+6
+7
+8
+10
+11
+112
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+9
+Limited Flight Department.
+Q.
+And do you know him personally then - Leslie
+Wexner?
+A. Yeah, I had met him, of course, you know.
+I met him. I used to do aircraft completions for
+him, so which would involve personal meetings.
+Q. When did you first meet Leslie Wexner?
+A. 1988 was when I hired on, so I don't
+remember the month.
+Q. How did you get that job?
+A. Through word of mouth and, you know, I
+worked - I lived in - been in aviation for years in
+Columbus.
+Q. Well, I mean, Leslie Wexner's an important
+person, right? I mean, he --
+A.
+Correct.
+MR. GOLDBERGER: Form.
+BY MR. EDWARDS:
+Q. He's somebody who owns - my understanding -
+Limited, Victoria's Secret?
+A. Well, he doesn't own them. He's Chairman,
+you know.
+Q. Chairman of --
+A. Yeah. He doesn't personally own it. It's
+a publicly held company.
+10
+Q.
+Where were you prior to any involvement with
+Wexner?
+A.
+I worked for Red Roof Inn True Sports
+Flight Department.
+Q. How did that position lead you tol
+Wexner?
+A. Well, it was always known that Limited
+Flight Department was one of the best jobs in
+Columbus and, actually, several other people that
+were already there knew me from previous jobs and
+education - we went through aircraft mechanic, or A&P
+school, together - so when the position became
+available they pointed to me and - absolutely. It
+was a fine organization.
+Q.
+So did Mr. Wexner approach you or did you
+apply to him or how did that work?
+A. Oh, no, no, no. It's -- No. He wouldn't
+be involved in that type of activity. You apply to
+H.R. and you interview with the Director of
+Operations or the Chief Pilot. You know, he
+wouldn't.
+Q. So you start with Wexner in 1988.
+A. Yes.
+Q.
+What do you do for him then?
+A.
+What did I do for him?
+2
+3
+5
+10 0 a o
+10
+11
+12
+13
+14
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+4
+6
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Galla Company
+October 6, 2009
+11
+Q. Yes.
+A. Aircraft technician.
+Q. Which entails what?
+A. Maintenance of any or all of the aircraft
+operated by the flight department and some flight
+mechanic duties.
+O. What kind of airplanes?
+A. Gulfstreams, Hawkers.
+Q. How big is the Gulfstream?
+A. Fifteen passenger - 15 to 17.
+(Mr. Goldberger exited.)
+BY MR. EDWARDS:
+Q. What did Wexner use the Gulfstream for?
+A. They were division airplanes, mostly.
+Q. And the other airplane you named - what did he
+use that for?
+A. Same, same.
+Q. Any idea why he had two planes?
+A. Well, I mean, yeah, we used them - they're
+a tool. It wasn't him. It was a large Fortune 500
+company. They use them as tools to -- You know,
+Limited has control over 60 percent of their
+manufacturing processes, plus, you know, what, 1200
+stores, or whatever, throughout all their divisions.
+I mean, when you say "Limited," it's not
+12
+just Limited, it's Victoria's Secret and it was
+Express and Leer's and Henri Bendel's and all of
+that back then, so, I mean -
+Q. So -
+A. - we moved a lot of passengers to keep
+those stores for the retail business.
+Q. And by "passengers," do you also mean clients
+of his?
+A. That I don't know. No. Mostly we just
+dealt with upper echelon, you know, people in the
+retail businesses from -
+Q. Such as whom?
+(Mr. Goldberger entered.)
+A. Can't even remember names, but it would be
+-- We would take buyers to Europe in the spring and
+fall. They would buy samples and bring them back to
+analyze for marketing. We would hire -- We would --
+Division heads, when they would do store shops and,
+Real Estate, we take Real Estate out when they were
+looking for new real estate.
+While you were working back in '88 -- Well,
+how long overall did you work with
+Wexner and/or
+his companies?
+A. Well, '88 through when I came here in
+January of '01.
+
+
+2
+3
+4
+6
+7
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+4
+6
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+13
+Q. Why the change?
+A. It offered an opportunity -- Well, one was
+I enjoyed flying - and the 727 was being replaced by
+a BBJ, which is a two-man airplane, not a three-man
+airplane - three-pilot airplane - and it gave me the
+opportunity to become a Director of Maintenance, and
+it was a challenge. You know, bringing - upstarting
+an airliner on a private ticket or a VIP ticket is
+really challenging, and I enjoy the challenge of
+working and developing the program and stuff.
+Q.
+Well, my understanding,
+Wexner is
+generally - he's in Ohio, right?
+A. No, he's got other places. I mean -- No,
+he's like anyone, he's - in his category - he's got
+multiple homes and --
+Well, when you would maintain his aircraft,
+would that be in Ohio-
+A. Yes. We were based --
+Q. - or elsewhere?
+A. We were based at Lane Aviation.
+MR. REINHART: Hold on one second. You
+have to let him finish asking the question
+before you answer.
+THE WITNESS: Okay. I'm sorry.
+BY MR. EDWARDS:
+14
+Q. I'm sorry, have you ever had your deposition
+taken before?
+A. No.
+Q. You definitely never had your deposition taken
+before while somebody else is trying to eat at the same
+time they're trying to ask the questions - that's very
+bizarre.
+A.
+Yes, yes.
+Q. I meant to do this before | got here. But,
+regardless, I'll wait until you finish your answer before
+I ask my next question; you do the same thing. "Uh-huh"
+or "uh-uh," they kind of look the same on the record, so
+try to give us a "yes" or "no" or something we
+understand.
+A. Alright.
+Q. If I ask a question that was a bad question or
+something you don't understand - I've asked bad questions
+before - say, "I don't get it." I'll ask a better
+question.
+A. Okay.
+Q. You were working with
+Wexner. You got
+the job there starting in 1988. On a day-to-day basis,
+what would you be doing?
+A. Maintenance, aircraft maintenance,
+tracking of aircraft maintenance, cleaning of
+1
+2
+3
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+10 o i
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Galle Company
+October 6, 2009
+15
+aircraft. I mean, whatever it takes to keep a
+corporate flight department operating.
+Q. Did you know back then of his relationship, if
+any, with Jeffrey Epstein?
+A. Not immediately, no.
+Q. When is the first time that you knew of a
+reputation or a relationship between Wexner and Epstein?
+A. Would have had to probably be around maybe
+98, 99.
+Q. How do you become aware that they know one
+another?
+A. Because Jeffrey, every one -- That's when
+I became a flight engineer on the Boeing, and every
+once in a while Jeffrey would ride on the Boeing,
+that's all - that's all I knew.
+Q. How did it come about that he would ride on
+Wexner's Boeing?
+A. They were business associates, I think.
+Q. As far as you know, they were business
+associates
+A. Right.
+Q. Did you understand the business relationship
+between the two?
+A. Well, I believe it's public knowledge
+that, I think, Jeffrey managed Mr. - some of Mr.
+16
+Wexner's funds.
+Q. Is that something that Mr. Wexner told you?
+A. No.
+Q. Is that something that somebody of Mr.
+Wexner's organization would have told you?
+A. No.
+Q. Is that something that Jeffrey Epstein told
+you?
+A. No.
+Q. Is that just reading articles that speculate
+as to the business relationship between the two or do you
+got something more for me?
+A. No, it's just - it's speculation and, you
+know, what I've read, you know.
+Q. I mean, like you say, to me it's common
+knowledge -
+A. Right.
+Q. But it's only because of what I've read. I
+don't have a specific person that 1 could cite to to say
+that, do you?
+A. Right. No, just - just periodicals.
+Q. What's your understanding of the personal
+relationship, if any, between Wexner and Epstein?
+MR. GOLDBERGER: Form.
+A. Don't know.
+www.esqulresolutions.com
+
+
+1
+2
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+17
+Q. Did you ever know of a time -- And I may be
+asking a question that would just be completely outside
+of your knowledge, so let me back up.
+Have you ever stayed at
+Wexner's house?
+A. No.
+Q. Do you know where his house is?
+A. Yes.
+Q.
+Do you know what the address is in Ohio?
+No, I just know the city.
+Do you know who he lives with?
+A.
+Yes.
+Q.
+Who is that?
+A.
+His wife and children.
+Q. What's his wife's name?
+A. Abigail.
+Q. Abigail Wexner, and he has three or four
+daughters, right?
+A. No. He's got a son, Harry, and two
+daughters, I think.
+Q. A son and two daughters.
+A. I don't know. See, that was back in 2001.
+I don't know what they have - if they have more kids
+noW.
+Q. Okay. Did you ever hear any information that
+he was homosexual?
+18
+1
+2
+3
+5
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A. No.
+Q. Being Mr. Wexner.
+A. No.
+Q. Any indication to you that he may be
+homosexual or bisexual?
+A. Absolutely not.
+Q. Have you heard any information that he and Mr.
+Epstein were involved sexually with one another?
+А. Oh, no, no.
+Q. Would that surprise you?
+A. Absolutely.
+Q. And that's only because you know him and you
+know Mr. Wexner and you don't see the two together.
+A. Correct.
+MR. GOLDBERGER: Form.
+A.
+Well -
+Q. He --
+A.
+Go ahead.
+MR. REINHART: If you need to answer,
+answer the question.
+A.
+Yeah. No. I saw him with Sharon, which
+was his previous girlfriend before he met Abigail.
+Q. Right.
+A. No. There was never any hint or anything
+that I would even conceive that.
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+5
+7
+8
+110
+11
+12
+|13
+14
+15
+16
+17
+11B
+19
+120
+21
+|22
+123
+124
+125
+an Alexander Galle Company
+October 6, 2009
+19
+Q. Have you spoken personally with Mr. Wexner?
+A. On business issues, yes.
+Q. Business issues related to your work on his
+airplanes?
+A. Correct.
+Q. Have you spoken to him on any other issues
+that don't involve business relationships with his
+airplanes?
+A. No.
+Q. Because you're hired basically for that
+purpose, so that's kind of how you deal with him.
+A. Yeah. It's I'm an employee and he's my
+employer and I only deal with him, you know, on
+issues that involve maintenance.
+Q. I think I probably know the answer to the next
+question, but just in case I don't, do you know any of
+his personal friends - people that he would hang out with
+on a social level - being Mr. Wexner?
+A.
+Through my business ties, yes, yes.
+Q. Who's that?
+A. I'm trying to remember - You have to
+remember it's been several years.
+Q. Right.
+A. He was friends with the Tuckermans.
+Q. What's Mr. Tuckerman or Ms. Tuckerman's names?
+20
+A. Ms. - I can't. I always addressed them
+by their proper name.
+Q. Do you know what they do?
+A. They owned an optical company - opticians.
+They were high school friends from Mr. Wexner's high
+school days.
+Q. In Ohio or New York?
+A. He went to high school in Bexley.
+Q. Bexley, Ohio.
+Has he ever discussed with you how
+longstanding the relationship is between himself and Mr.
+Epstein?
+MR. GOLDBERGER: Form.
+A. I don't understand. Can you rephrase it?
+Q. Well, you know that at some point in time -
+You started working with him in 1988. The first time,
+according to my notes, that you became aware that he was
+friends or acquaintances with Mr. Epstein was '98 -
+almost ten years later.
+A. Right.
+Q. After you became aware that there was that
+relationship, whether business or otherwise, did he ever
+speak to you about how long he had known Mr. Epstein?
+A. Oh, no, no.
+Q. So as far as you were concerned, 1998, when
+
+
+1
+2
+5
+6
+7
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+3
+5
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+21
+you found out there was a relationship with Epstein, it
+could have very well started then.
+A.
+Yes.
+Q.
+Aside from aircraft technician and taking care
+of Mr. Wexner's aircraft back in the '80s and, I guess,
+early '90s, did you have any other personal involvement
+with him?
+A. Just on aircraft completions.
+Q. And when you would speak with him, would that
+be over the telephone, at the airport, at his private --
+A. It would usually be at the corporate
+office.
+Q.
+A.
+Q.
+At the corporate office?
+At the corporate office.
+Can you tell me the address for his corporate
+office?
+A. No, I can't.
+Q.
+If I requested that from your attorney, would
+you be able to get that information?
+A.
+Well, I mean, I imagine it's public
+knowledge - wherever - it's at the Limited.
+Q. And that's where you would meet him - at the
+Limited?
+A. Yeah.
+Q. And how often was - you know, I know that
+22
+we're talking about 15, 20 years ago - how often was Mr.
+Wexner personally at that location at the Limited
+offices?
+A.
+I have no idea.
+Q.
+But any time you needed to talk to him, that's
+where he would be?
+A. Yeah, and I usually went to Charlie
+Hinson.
+Q. Who's Charlie Hinson?
+A. He was the president of the stores. He
+basically was my go-between for these aircraft
+completions for the design.
+Q. And you mentioned the Gulfstream as an
+aircraft. Did you also serve as a technician for other
+aircrafts that were owned by Mr. Wexner?
+A. Right, but not Mr. Wexner. They're owned
+or operated by Limited Stores.
+Q. Limited Stores?
+A Right. Yes.
+Q. What did you do for them?
+A Same - maintenance.
+Q. Did you ever fly in them?
+A. On the Gulfstreams in the early days we
+used flight mechanics, especially on intemational
+flights.
+1
+2
+3
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+2
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Gallo Company
+October 6, 2009
+23
+Q. Who were some of the pilots?
+A. Tim Staley, Jim Taylor. They've had some
+tumover too. I don't know who all is still there
+because retail is down.
+Q. Was Larry Visoski a pilot used by
+Wexner at any time?
+A. No.
+Q. How about David Rodgers?
+A. No.
+Q. Are those names you're familiar with?
+A. Yes.
+Q. Those are names you're familiar with how?
+A. I flew with them when I was flying for Mr.
+Epstein.
+Q. So there's no real, other than yourself --
+Well, tell me if I'm wrong: I understand that you did
+some work for Mr. Wexner related to his aircraft and you
+did some work for Mr. Epstein, which we haven't yet got
+to, but you did some work for him too. Are there any
+other people that have that type of relationship with
+both parties?
+A. No. I'm sorry, resay that.
+Q. Okay. You've already told us that you were
+the aircraft technician for Mr. Wexner.
+A. One of them. One of several, yes.
+24
+Q. One of them. Then you also have knowledge
+about Mr. Epstein and some relationship with Mr. Epstein.
+A. Correct.
+Q. Are there any other pilots, aircraft
+technicians, people like that that you know of to have a
+relationship with both Mr. Wexner and Epstein?
+A. No, no.
+Q. Do you know how Mr. Wexner met Mr. Epstein?
+A. No.
+Q. How long - if you started in 1988 - how long
+did you stay with Mr. Wexner and/or The Limited?
+A. January of '01.
+Q. Why did you stop?
+A. Because what we were talking before, you
+know, I wanted to continue flying. They bought a
+BBJ, which is a two-pilot aircraft, and I wanted to
+continue flying. Mr. Epstein bought the 727 and
+offered me a position to continue flying and, you
+know, basically set up the airplane for his flight
+department because they hadn't had any previous large
+aircraft experience.
+Q. I missed something. It wasn't your fault, it
+was mine.
+The Gulfstream that you were talking about,
+did you used to fly that as well as being a flight
+
+
+1
+2
+6
+7
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+4
+6
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+25
+technician?
+A. No, no.
+Q. Okay.
+A. You don't have to have a flight - a
+pilot's certificate to be a professional flight
+engineer. I've got a turbo - a flight engineer turbo
+jet rating, but you don't have to have a commercial
+ticket as long as you - the FAA recognizes your heavy
+aircraft maintenance experience.
+Q. So you're saying that if the FAA recognizes
+your heavy maintenance experience, I'm assuming that
+means that you understand the ins and outs of airplanes
+and you can work on them.
+A. On heavy high performance aircraft, yes.
+Q. Then you can also fly them?
+A. Sideways as a flight engineer.
+Q. Explain.
+A. On the older generation airliners there
+was three pilots - there's a captain, a first
+officer, and then the flight engineer is the
+gentleman that sits sideways and maintains all the
+systems.
+Q. When you say, "sits sideways," okay, I have
+a--
+A. Literally, you're physically sideways in
+26
+the cockpit.
+Q. So you're not looking at the people that were
+flying on the plane and you're not looking at the pilots,
+you're actually literally sitting sideways.
+A. I sit sideways at a panel, yes.
+Q. What's your job?
+A. Maintain all the aircraft systems - the
+hydraulics, fuel management, pressurization,
+environmental controls.
+Q. That's not done by the pilots.
+A. No, no.
+Q. But if you've done that long enough and FAA is
+aware of your credentials in that respect, then you also
+could be credentialed to be a pilot as well?
+A. Well, sure, yeah, yeah. If that's a
+career choice you wish to take.
+Q. And was that?
+A. No, no. I was perfectly satisfied with my
+position as a flight engineer and Director of
+Maintenance.
+Q. What year did you say Epstein bought the 727
+that was once owned by Wexner?
+A. I don't know when the actual transition
+took place, but when I came - shortly around the
+period that I came on board in '01, January of '01.
+October 6, 2009
+an Alexander Gallo Cempany
+27
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Q. Do you know why Epstein chose to buy that
+particular 727 rather than one of the other million 727s
+that are made?
+MR. GOLDBERGER: Form.
+Because it was probably the finest one out
+A.
+there -
+Q.
+Why?
+A.. - in all honesty. It's got a fully Paged
+STC interior with EFIS cockpit, and Limited's
+reputation on the way that we maintained our aircraft
+- it's the best one out there.
+Q. Describe for me the interior - I'm not talking
+about the Epstein days, we're talking about the Wener
+days - describe for me the interior of the aircraft, and
+keep in mind that I've only been on a commercial aircraft
+where you don't see the pilots, there's a door, and then
+everybody, you know, there's just a bunch of seats where
+everybody sits there.
+A. Correct. Right.
+The aircraft -- You enter the airplane,
+it's got forward air stays, which most 727's don't,
+so you enter the forward door on the left-hand side,
+the forward entryway vestibule, and there's a door on
+the left, which leads to the cockpit, and then
+there's a door on the right which leads aft to the
+28
+1
+forward salon.
+Q. What's the forward salon? Sorry.
+3 A. Forward seating area.
+4
+Q. And is it set up basically the way that I'm
+picking it - in that there are 25 or 26 rows and they're
+6
+numbered A through E?
+A. No, no, it's a corporate configuration.
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Q. Which means nothing to me, so help me.
+A. Picture a 600-mile an hour Winnebago. 1
+mean, it's got conference tables and divans and large
+first class seating.
+Q. Any various dividers throughout --
+A. Yes.
+Q. - to where there's a VIP room in the back or
+anything like that?
+A. It's compartmentized (sic), yes.
+Q. In what way? Describe it as specifically as
+you can.
+A.
+There's a forward salon, a mid galley -
+the galley's in the mid - an aft - an aft salon,
+which is - and then the aft state room.
+Q. Who designed that plane?
+A. I can't remember who the actual designer
+was. It was a Page interior, though. Page Avjet did
+the installation.
+
+
+1
+2
+3
+4
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+29
+Q. Who directed the design of that plane?
+A. It would have been Mr. Wexner. I mean, it
+was -- The layout has not changed.
+Q. "The layout has not changed," when you say
+that, you mean "from the time that I first got in it and
+I was under the guise of - 'under the employment of
+Wexner to the time I've been on it since with Epstein,
+the configuration is the same.*
+A. Essentially, yes. We removed one chair
+and one small table that was an annoyance and that's
+it, but it's identical to what The Limited used
+Q. Are there any blocked off areas to where if
+you're standing in the middle of the plane you cant see
+certain areas of the plane?
+A. There are pocket bulkheads. Yeah, there's
+dividers between the sections.
+Q. How big are these dividers and where are they?
+A. Well, there's a divider - the forward
+door, I told you, on the salon, then there's a pocket
+door on the forward side of the galley, a pocket door
+on the aft side of the galley, there's a pocket door
+between the aft salon and the office, and then
+there's another pocket door between the office and
+the state room.
+Q. Have you been on other 727s before that are
+30
+1
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+commercial airliners privately owned?
+A. Yes, yes.
+Q. Have you noticed similar configurations to
+where there are this many dividing doors or is this one
+that has more so than you've seen in the past?
+A. No, no, this is pretty atypical (sic).
+Q. It's pretty atypical?
+A.
+It's typical.
+Q. It's pretty typical?
+A. Yes, yes.
+Q. So what other airplanes - 727s, or other major
+airplanes - have you been on that have these types of
+dividers?
+A. Trump.
+Q. Trump's airplane?
+A. Yes.
+Q. Why were you on Trump's airplane?
+A.
+Well, I know the crew and, you know, this
+is a small-knit community. There's not very many of
+them out there, so everybody in this world knows one
+another to help one another out as far as -
+Q. By "there" --
+A. - information-wise and stuff
+Q. By "there aren't that many of these people out
+there," you don't mean there's not that many people -
+1
+2
+3
+4
+9
+10
+11
+|12
+13
+14
+15
+16
+17
+1B
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+aa Alexander Calle Campany
+October 6, 2009
+31
+because obviously there's a lot - there's not that
+many -
+A. Privately owned 727s, but this is -- As a
+matter of fact, The Limited's current BBJ has a very
+similar floor plan.
+Q. As Trump's?
+A. No, as the - as our 727.
+Q. Who's "our"?
+A. Mr. Epstein's. They didnt change a lot.
+It's-
+Q. Well, I thought that you had told me that the
+727 that was once owned by Wexner is the 727 that's owned
+by Epstein.
+A. It is, but what I'm saying is even their
+current airplane has the same layout - the BBJ. They
+put the same floor plane in the more modern airplane.
+Q. Well, they didn't have to put it there. It
+was already there, right?
+A. No, no, no. When you buy these aircraft -
+even a Gulfstream - when you buy them it's just a
+green hull, there's nothing in them, and you can
+customize your interior.
+Q. I'm sorry, we're miscommunicating somewhere,
+and I'm sure it's on me.
+MR. GOLDBERGER: Yes, it is.
+32
+MR. EDWARDS: And I'm taking the blame for
+it- right away.
+MR. REINHART: Take that, Ed
+MR. EDWARDS: Alright.
+BY MR. EDWARDS:
+Q. My understanding - and please correct me when
+I'm wrong, because I know I am - Wexner has this 727 and
+he designs it in a certain way.
+A. Uh-huh.
+Q. And then you come to work for Epstein -
+A. Yes.
+Q. - who buys the same 727. Your testimony, as
+I'm understanding it, is: It's basically the same floor
+plan as Wexner's floor plan. To me, it should be the
+exact same because he bought the same plane.
+A. No, he - You're misunderstanding.
+Q. I figured.
+A. What | was stating is -- You were - | was
+answering the question in regards to, "Is this
+unusual to have this many compartments and closed
+doors and bulkheads and things?"
+What I was trying to state was: No, it's
+not unusual - because The Limited even liked the
+floor plan so well in their old airplane that they
+sold to Mr. Epstein. They duplicated it in their new
+
+
+1
+2
+3
+4
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+5
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+33
+airplane - see what I'm saying? That's all I was --
+Q. So they didn't keep the floor plan. They
+actually took it out and they restructured the floor plan
+to basically match that old floor plan.
+A.
+Well, no. When you -- When you buy a
+Boeing business jet -
+A. - it comes with nothing inside. It's a
+tube. Nothing's in there. You design - have
+designers design your interior and then a fabricator
+or a facility such as Page Avjet to install this
+interior.
+Q. Right.
+A. What I was just trying to state was that
+The Limited liked their old floor plan in the old
+airplane so well - it worked so well for them - that
+they duplicated it and had that same interior
+installed in the new aircraft - same floor plan
+installed on the new plan.
+Q. So Epstein didn't buy the exact same plane.
+He bought the same type of plane.
+A. Well, more modern. He bought a 737.
+right.
+Q. Got it.
+A. Right.
+34
+MR. REINHART: Hold on.
+BY MR. EDWARDS:
+Q. Totally understand now.
+MR. REINHART: Can you clarify - Mr.
+Epstein or Mr. Wexner?
+BY MR. EDWARDS:
+Q. Mr. Epstein bought not Mr. Wexner's plane.
+A. No.
+Q. He bought the same type of plane that Mr.
+Wexner had and modeled the floor plan --
+A.
+No.
+Q. - the same way that Mr. Wexner had it.
+A. That is not correct.
+Q. He bought, actually, Mr. Epstein --
+MR. REINHART: Hold on. Distinguish -
+Use names so we're very clear when you're
+talking about Mr. Epstein and Mr. Wexner, okay?
+A. Mr. Epstein bought Mr. Wexner's 727.
+Q. Okay.
+A. The actual airplane - bought it from him.
+Q. Which has a floor plan already in it.
+A.
+That we just discussed.
+Q. Alright. The floor plan's in the plane.
+A. Right. Mr. Wexner replaced the airplane
+that Mr. Epstein bought with a new airplane and he
+1
+2
+5
+6
+7
+8
+9
+110
+11
+12
+13
+14
+115
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Gallo Compasy
+October 6, 2009
+35
+had a very identical or very like floor plan
+installed in the new airplane.
+Got it.
+A. Okay? Sorry, it's a strange business.
+It's -
+Q. Tell me if I'm right: Mr. Wexner had a plane
+that had a floor plan that apparently appealed to Mr.
+Epstein, so Mr. Epstein bought that plane.
+A. Correct.
+Q. Mr. Wexner also liked that plane that he had
+just sold to Mr. Epstein, so he built in a floor plan
+very similar to the one he just sold to Mr. Epstein.
+A. In his new aircraft.
+Q. Brand new plane.
+A. Correct.
+Q. Got it. We're on the same page now.
+A. Alright.
+Q. Took us a while to get there.
+A. Yeah, sorry.
+Q. I think it was my fault, honestly, but
+alright?
+A. It's an unusual process if you haven't
+been around corporate airplanes
+Q. I didn't realize that Mr. Wexner had a new
+plane.
+36
+A. Yes.
+Q. That's where I had a problem.
+How many times have you been on Mr. Wexner's
+airplane?
+A. The new?
+MR. REINHART: Clarity which one you're
+talking about.
+BY MR. EDWARDS:
+Q.
+Before you ever met Mr. Epstein.
+A. I can't say. I mean, over the years?
+Q.
+Numerous times?
+A. Oh, I was his flight engineer. You mean
+when I was still employed by him?
+Q.
+Yes.
+A. Yes. I was the flight engineer. I
+don't -
+Q. So as a flight engineer, every time the plane
+leaves the ground, do you leave the ground with it?
+A.
+No. We had another engineer also.
+Q. So what percentage of times do you leave the
+ground in the airplane when the plane leaves the ground?
+A. For who?
+Q. For Mr. Wexner.
+A.
+Probably one-third of the time, because |
+was also the lead technician, so I had
+
+
+: I
+5
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+4
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+37
+responsibilities in the hangar, whereas the other
+engineer was a full time engineer.
+Q.
+And given the partitions that you've described
+3
+in this airplane, are you able to see what's going on
+4
+behind the doors of the various partitions of the
+5
+airplane?
+6
+A. If the doors are open or closed?
+7
+Q. Closed.
+8
+A.
+No.
+9
+Q. Do you have any idea what's taking place in
+110
+there?
+/11
+A. No.
+12
+MR. GOLDBERGER: Form.
+113
+BY MR. EDWARDS:
+14
+Q. When you're on the plane with Mr. Wexner, was
+15
+there a time that he had - Well, let me put it this way:
+16
+When anybody is a passenger on any of these private
+17
+planes, should there be logs of the names of the
+18
+passengers on the planes?
+19
+A. Not required, no.
+120
+Q. Are you ever specifically instructed not to
+21
+record the names?
+22
+A.
+That wasn't part of my duties. That
+23
+wasn't an engineer's task, but --
+24
+Q. Do you -
+25
+38
+A. - no, not that I'm aware of.
+Q. Who is assigned the duty of reporting the
+names of the people who are going to be transported on
+the airplanes?
+MR. GOLDBERGER: Form.
+A. Captain.
+Q.
+So have you ever been privy to conversations
+where the captain is told by Mr. Wexner to record all of
+the names of the people that are going to be on the
+airplane?
+A.
+Can't say.
+Q. Sometimes?
+A. I cant - You know, I can't say. I can't
+remember what our policies were at the time.
+Q.
+I'm not asking policies. I'm asking: Have
+you ever been around when the pilot was being instructed
+by Mr. Wexner - back in the late "80s, early '90g - to
+make sure that you record who's on this aircraft?
+A. I never heard Mr. Wexner address that, no.
+Q. I mean, God forbid the airplane crashes, you
+would like to know who's the on the airplane, right?
+MR. GOLDBERGER: Form.
+A. Yes.
+Q.
+Is there any way to determine who's on each
+particular flight in case anything happens?
+1
+4
+5
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+124
+25
+an Alexander Gallo Company
+October 6, 2009
+39
+A. There is normally a passenger manifest,
+yes.
+Q. Who creates the manifest?
+A. Probably dispatch.
+Q. Dispatch?
+A. At Limited.
+Q. Do you know who that is?
+MR. REINHART: Can you give a time frame?
+thereu mean curently or back when he worked
+MR. EDWARDS: I'm talking about back when
+he worked there.
+BY MR. EDWARDS:
+Q. Do you know who that was at dispatch?
+A. That would have been Diane Williams.
+Q. Who does Diane Williams work for?
+A. Limited Flight Department.
+Q. Who does she report to?
+A. Tim Staley.
+Q. Who's Tim Staley?
+A. Director of Operations.
+Q
+For who?
+A.
+Limited Flight Department.
+Q
+What does he then do with that information?
+A. I don't know. I don't know.
+40
+Q. Have you ever talked to Tim Staley?
+A. From -- Yes, yes.
+Q. And what do you talk to him about?
+A. Oh, we're - we're friends. We worked
+together for years. I mean, I haven't talked to him
+since the holidays.
+Q. Do you know where he is now?
+A.
+To the best of my knowledge, still
+Director of Operations at Limited
+Q. Do you have a number for him?
+A. Yes.
+Q. Can I have the number, please?
+A.
+It's
+Q. Is that a work number?
+A.
+That's the Flight Department.
+Q. That's the best number to reach him at?
+A. Yes.
+Q. If I'm going to call him, that's the number I
+call?
+A. Correct.
+Q. And was he always in charge of flight
+directions?
+A. No, he was previously Chief Pilot.
+Q. He was previously Chief Pilot for Limited?
+A.
+Same, yes.
+
+
+1
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+4
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+41
+Q. And he was promoted, I suppose, to Flight
+Director?
+A.
+Director of Operations.
+It's the
+department crew. Most small departments don't have
+directors until they start to grow.
+Q.
+And when he was Chief Pilot were you
+affiliated with the Wener organization?
+Yes, I was a maintenance technician.
+Q.
+And when you say somebody keeps flight logs,
+is it always Tim - is his name Tim Staley?
+A. Yes.
+Q.
+- is it always Tim Staley who does that?
+A. No. I don't know where they go, honestly,
+and the system may have changed.
+Q.
+Okay. Are you -
+A.
+I've been gone since --
+Q.
+Are you aware of any FAA policies to where
+they need to know who's on the aircraft whenever it talks
+off?
+A. Not under Part 91 Operations, there is
+not.
+Q. Part what?
+A. Part 91.
+Q. What does Part 91 say, as far as you know?
+A. It's basically souls on board when you
+42
+file a flight plan - that's the only thing you're
+required to do. When you file your flight plan you
+file souls on board.
+Q. What does that mean,
+"souls on board"?
+A. In other words, living bodies on board.
+In other words, if you have - so if there's an
+accident and you have four and you're transporting a
+cadaver, that they go to the accident scene and don't
+find five bodies - think there were five fatalities.
+Q. So it's your understanding from what you need
+to report are, "I have five people on board."
+A. Correct, and that's for the flight plan.
+Q.
+So there's no reason to say that, "I have Joe
+Schmo on board."
+A. Not under Part 91, no.
+Q. That's doing something over and above.
+A. That's correct.
+Q. You are aware, though, that there are certain
+flight plans where they actually name individuals that
+are on the airplane?
+MR. GOLDBERGER: Form.
+A.
+Q
+No.
+I mean, you've seen that before.
+MR. GOLDBERGER: Form.
+A.
+No, not on flight plans, no - unless it's
+1
+2
+4
+5
+6
+7
+8
+9
+110
+11
+112
+13
+14
+115
+16
+17
+18
+19
+20
+21
+22
+23
+124
+125
+2
+4
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Gallo Company
+October 6, 2009
+43
+international. The only time we do international
+would be for Customs and Immigration.
+Q. So if it's an international flight --
+A. For Customs and Immigration - for coming
+and leaving the country.
+Q.
+- then they require that names of
+individuals -
+A. It would be names, passports, that kind of
+stuff - normal.
+Q. Did you ever do any international flights
+while employed by The Limited, Victoria's Secret, the
+whole Wexner group?
+A. Yes.
+Q. How many?
+A. No way of knowing. I mean, I'm - can't
+say. It's, like I say, years, but.
+Q. What years would you done it?
+A. Started flying as a flight mechanic in
+'89, and then started flying the Boeing in '99, so -
+to '01, so '89 to '01, basically.
+(Mr. Goldberger exited.)
+BY MR. EDWARDS:
+Q. So '89 to '01, if I wanted all of the flight
+logs, who would I request those from - Tim Staley?
+A. Don't know. I don't know who --
+44
+Q. What does Tim Staley do after he maintains
+these records?
+A. I don't know.
+Q. He's never told you what he does?
+A. No.
+Q. Certainly they're kept on file somewhere,
+right?
+A. I would assume.
+Q. What's the name of the company that owns the
+airplanes? I know it's affiliated with Wexner and all
+that, but what's the name of the company?
+A.
+Well, there were several companies.
+mean, the way corporate aviation flight departments
+are set up, they're under holdings companies.
+Q. I'll go with all of them.
+A. Well, I don't know. They change. They
+change sometimes by the year, sometimes - | have no
+idea what they're under now.
+Q. What were they under back in '88 -
+A. It was like -
+Q. - to the best of your memory?
+A.
+They change. I mean, every time we got a
+new aircraft, or whatever, they changed. They were
+like Northeast Holding, Southwest Holding, LLC -
+Wilmington, Delaware, companies, which is standard
+
+
+2
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+3
+5
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+45
+for these, you know.
+Q. Did
+Wexner ever tell you that he
+allowed Jeffrey Epstein to serve in some sort of
+capacity, representative capacity, for any of these
+companies?
+A. No. He would never say that to me
+anyways, no.
+Q. What's the first time you ever saw Jeffrey
+Epstein?
+Can't say. I'm not sure.
+Q. I think you saw him before you started working
+for him or with him?
+A.
+Oh, yeah, that's - Where | first saw him
+was when I flew him on The Limited 727.
+Q. What year do you think that was?
+A.
+It would have had to have been --
+Q. Talking late '80s, early '90s?
+A.
+Late '90s.
+Q.
+Late '90s?
+A.
+Yeah, probably - mid to late '90s.
+Q. Well, I mean, if you're taken over with
+Jeffrey Epstein in, what, 2001 -
+A.
+Correct.
+Q. - then you're talking late '90s is the first
+time you see him?
+46
+Well, mid - I don't know exactly. I
+can't really say, really.
+1 won't hold you to it. It is what it is.
+Mid to late '90s, if I wanted the flight logs
+that have him on it, on the airplane, who would I
+subpoena to get those records?
+A. I have no idea.
+Q.
+Are they turned into the FAA, to the best of
+your knowledge?
+A. No, the FAA doesn't require them.
+So FAA does not get the flight -- Well, what's
+the point of even keeping these?
+A.
+Sometimes I think the IRS - I mean, this
+is on assumption, I'm not even sure, but mostly for
+like IRS tracking for if you have people that have
+dual homes, dual statehoods, or whatever.
+(Mr. Goldberger entered.)
+MR. GOLDBERGER: Can we take a time out?
+(Short break.)
+(Mr. Pike appeared via telephone to
+replace Mr. Goldberger.)
+BY MR. EDWARDS:
+Q. FAA flight logs - do you know why they're
+generated, how they're generated, if they were generated
+back in the Wexner days?
+1
+2
+4
+5
+6
+8
+9
+110
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+4
+5
+6
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+as Alexander Gallo Company
+october 6, 2009
+47
+A. They were -- They were generated, but I
+don't know, you know, why - what the particular
+reasoning was for it.
+Q. Do you know if Terry (sic) Staley would have
+been the one to forward those flight logs to the FAA?
+A. No, no, no. I -- They were all just for
+business use - not forwarded to the FAA.
+Q. Okay. How -
+A. The FAA doesn't care about flight logs.
+Q. How did the FAA monitor when that plane took
+off?
+A. Flight plans.
+Q. And was it your understanding that when the
+plane took off, the FAA was unaware as to who was ever on
+it?
+A. Pretty much, yeah. They don't care about
+names. When you file flight plans with the flight
+service station or via electronically, all they care
+about is souls on board, contact information, flight
+routing, things like that.
+Q. Are there time limits as to when the plane is
+allowed to take off?
+A. Yeah, usually - From what point? What do
+you mean? Time of the day or --
+Q. Yeah, yeah, time of the day. I understand
+48
+that there's some time where if it's too late they can't
+take off, right?
+A. Only where there's a curfew on the airport
+- not all airports, no. No, airplanes can fly any
+time unless that airport has a noise curfew or
+something, yeah.
+Q. Did you ever know of Wexner's plane to take
+off after ten o'clock p.m.?
+A. Yes. Yeah.
+Q. Were you ever on that plane when it did?
+A. Probably, yeah, yeah.
+Q. Were you ever on that plane when there were
+girls on the plane?
+A. Describe -- Define "girls." On the Wexner
+airplane?
+Q. Yes.
+A. There would be ladies and his daughters
+I mean -
+Q. Other than family members.
+A. There would be business associates. If
+you're talking young women, yes, business associates
+from the divisions.
+Q. Have you ever been on the plane when there
+were girlfriends of
+Wexner?
+A. Only when Abigail - before his - became
+
+
+1
+2
+3
+4
+5
+7
+8
+9
+110
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+3
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+49
+his bride, yes.
+Q. How about after -
+A. I mean --
+Q.
+- she became his --
+A.
+- it was Abigail. She was the only
+girlfriend.
+Q. How about after Abigail?
+A. No.
+Q. Have you ever seen sex or sex-related
+instances occur on
+Wexner's airplane?
+A. Absolutely not. We didn't even have
+playing cards. He looked at the aircraft as a
+business - a flying business office.
+Q. When you say "playing cards," what do you
+mean?
+A. Playing, you know, to --
+Q. Oh, playing cards.
+A. Yes, playing cards.
+Q. So every time that you were on
+Wexner's
+airplane, it was used strictly for business?
+A. Well, I don't know if it was used strictly
+for business, but there was no, you know, it was - l
+don't know what the purpose of the actual trip was,
+but never saw, you know, anything, you know.
+Q. Was there ever a time when you were -
+50
+MR. REINHART: Hold on. Were you
+finished?
+BY MR. EDWARDS:
+Q. I thought you were finished.
+A. Yeah, I don't understand. I don't
+understand that question.
+Q. I'm going to clarify. Were there ever times
+when you were on the plane and either
+Wexner
+and/or other individuals went behind these various areas
+that you could not see into?
+A. Yes. Yeah.
+Q. Do you know what they were doing in there?
+A. Probably sleeping. He would go to bed at
+night on the long trips, okay.
+Q.
+Any time that more than one person went in one
+of these areas that you would not be able to see into?
+A. Not that I'm aware of, but my exposure to
+back there is not that, you know, is limited.
+Q. How many times did you see Jeffrey Epstein
+ride that plane with
+Wexner?
+A. Not many, but I can't say exact.
+Q. How many international flights do you remember
+that plane taking?
+A. Remember - The airplane itself taking
+international?
+october 6, 2009
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+4
+6
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Gallo Company
+51
+Q. Yes, with you on it.
+A. I can't -- I can't say.
+Q. Well, where do you remember going in it?
+A. Well, we would normally go to London,
+Milan, Paris. I mean, mostly fashion areas and
+business - business areas.
+Q. When you say "fashion areas," what do you
+mean?
+A. Well, retail. I mean, you know, design
+for clothing and stuff like that.
+Q. What was the purpose?
+A. I'm sure it was business. I have no idea
+what the actual purpose was. I don't -
+Q. Did you get off the plane?
+A. Well, of course.
+Q.
+What did you do there?
+A. Go to a hotel, eat dinner, wait to find
+out when you're going to the next place.
+Q. Were you ever on an international flight on
+one of Mr. Wexner's planes that Jeffrey Epstein was also
+on?
+A. I can't say. I can't remember.
+Maybe?
+A. Possibly.
+Q. Do you remember any specific places that
+52
+Jeffrey Epstein went while on that plane outside the
+United States?
+A. I can't remember. No, no. Like I say. I
+can't even remember if we took it for sure.
+Q. Any time that you remember Jeffrey Epstein
+being on the airplane, do you also remember there being
+girls on the airplane along with Mr. Epstein?
+A. I can't - I can't say. I can't remember.
+Q. When's the first time you remember seeing
+Jeffrey Epstein?
+A. Well, like I say, I don't even remember
+the year. I can't even pinpoint down to the year.
+It was after - some time after I started flying the
+727, because that's the only exposure.
+Q. : Okay. I'm not going to ask you at all during
+this deposition to guess. I thought at some point in
+time you told me you remember seeing Jeffrey Epstein,
+right?
+A.
+Yes.
+Q. In fact, you work for him now.
+A. Yes.
+Q. So at some point in time you saw him and you
+saw him for the first time.
+A. Correct.
+Q. When's the first time you remember seeing him?
+
+
+53
+2
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+It may not be the first time you saw him. When's the
+first time you remember seeing him?
+A. "99, somewhere in that area.
+Q. Alright. In '99 were you working for
+Wexner or were you working for Jeffrey Epstein?
+A.
+Wexner.
+Q.
+And do you remember the context in which you
+saw Jeffrey Epstein?
+A. It was a flight.
+Q. What did
+Wexner ever tell you in terms
+of who Jeffrey Epstein was?
+A. Never told me anything who Jeffrey Epstein
+was.
+Q. Did you ever ask?
+A. No.
+Q.
+Did you ever ask back in 1999 when you saw
+this guy, "I wonder what he does"?
+A. No.
+Q. Not even curious?
+A. No. It's not my place. I don't - I
+don't need to know or want to know what people's
+associations are.
+Q. Next time you saw Jeffrey Epstein was when?
+A. I can't say for sure.
+Q. Have you seen Jeffrey Epstein at
+54
+1
+2
+3
+4
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+Wexner's house?
+A. No.
+Q. Never?
+A. Never. I've never --
+Q. Have you ever -
+A. - been to Wexner's house.
+Q. You've never been there?
+A. No.
+Q.
+Have you ever known of
+Wexner or heard
+of
+Wexner having minor girls or minor boys at his
+house?
+A. Oh, no.
+Q. Have you ever heard of Jeff --
+MR. REINHART: I assume, other than his
+children.
+MR. EDWARDS: Oh, of course.
+A. Yeah. No - his children. I'm sorry.
+Thank you.
+Q. Have you ever known of Jeffrey Epstein to take
+underage giris to
+Wexner's house?
+A.
+No.
+Q.
+Do you know how it is that Jeffrey Epstein and
+Wexner met each other?
+No.
+25
+A.
+Q.
+You mentioned earlier that you believed that
+1
+2
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+117
+18
+119
+/21
+22
+23
+24
+25
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Gallo Company
+October 6, 2009
+55
+Jeffrey Epstein helped to - I think, what you said was -
+manage
+Wexner's money?
+A. Some of his accounts, yes, I guess.
+Q. Why do you think that?
+A. From what I've read in periodicals and
+magazines.
+Q. You've read in what periodicals and magazines?
+A. I think it was, what, Vanity Fair there
+was an article a couple years back, three or
+four years back, and a New York magazine as I
+mentioned.
+Q. Why did you read the article?
+A. Well, obviously it was dealing with the
+gentleman that I was working for, so out of
+curiosity, you know.
+Q. Right, because people tend to be curious --
+A. Right.
+Q. - right? But when I just asked you who
+Jeffrey Epstein was and the relationship, you said, "I
+have no idea," implying that you weren't curious. But at
+some point in time you got curious as to who this person
+is, right?
+A. Who Jeffrey Epstein is?
+Q. Yes.
+A. Well, yeah, when you're working for him
+56
+and he's in a magazine, you're going to read the
+article.
+Q. Okay, so at some point in time, did you Google
+Jeffrey Epstein?
+A. No, no.
+Q. Have you read the articles about Jeffrey
+Epstein?
+A. Lately?
+Q. Yes.
+A. Oh, of course, yes, in the newspapers.
+Q. And you're aware of why your deposition's
+being taken today.
+A. Yes, of course.
+Q. And it has something to do not with a case
+with
+Wexner, but a case involving Jeffrey Epstein.
+A.
+Correct. Yes, of course.
+Q. When you got this deposition subpoena, did you
+by any chance try to look up some information on Jeffrey
+Epstein - who this guy is?
+A. No, no. I mean --
+Q. Is there anything -
+MR. REINHART: Hold on. Were you
+finished?
+Q. Okay. Go ahead.
+A. No. I mean, other than every once in a
+
+
+1
+2
+3
+4
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+57
+while I'll get a Google alert just following the case
+- just out of interest - because he's still my
+employer, you know, and you don't want to be
+blind-sided, but other than that, no -
+Q. When you --
+A. . I never looked into his financial
+background or anything look that. I don't know if
+you can.
+Q.
+When you say a "Google alert," that's
+something that you actually go out of your way and set up
+on Google, right?
+A. Yeah.
+Q. When did you do that?
+A. A year ago or so.
+Q.
+Why did you do it?
+Because I'm not around Mr. Wexner - or Mr.
+Epstein anymore. I don't -
+Q. Well, he was in jail --
+MR. REINHART: Hold on. Were you finished
+with your answer?
+A. I haven't been a full time employee with
+Mr. Wexner since -
+MR. REINHART: Epstein.
+BY MR. EDWARDS:
+Q. Epstein or Wexner?
+58
+A.
+I'm sorry - Mr. Epstein, since February
+of 2007.
+Q.
+Well, a lot of that has to do with him being
+incarcerated --
+A. No, no.
+Q. - for a year, right?
+MR. PIKE: Form.
+A. No, it was because I wanted to make a job
+- a career change.
+Q. Why?
+A. Because I got tired of flying, being on
+the road, wanted to be home.
+Did it bother you that your boss, back in
+2007, was under investigation?
+A. Of course.
+Q. Is that part of the reason why maybe you
+wanted to make a career change?
+A.
+No, no. The reason was the amount of
+flying that I had been doing and the overnights, and
+when something's no longer fun, it's time to find
+something else to do.
+Q. Why wasn't it fun anymore?
+A. It's a very fast pace. I wanted to spend
+time at home. I wanted to get back into strictly
+maintenance.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+6
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+122
+23
+24
+25
+an Alexander Gallo Compens
+October 6, 2009
+59
+Q. When you say "fast pace," how often are you
+flying?
+A. Every week - sometimes two, three times a
+week.
+Q. And that's by the time that you're working for
+Jeffrey Epstein?
+A. Yes, yes.
+Q. Because back in the
+Wexner days you
+weren't flying every day.
+A. No, no, no, because there was another
+engineer, no.
+Q. Right.
+A. I had about one-third of the flights.
+Q.
+So from 1988, when you start working with
+Wexner, through '89 or so, you're not flying all
+the time, right?
+A. No. Oh, no, no. Actually, in '88, I was,
+you know, I was - my primary duties were in the
+hangar - maintenance.
+Q. Did you enjoy doing that?
+A. The maintenance part of it?
+Q. Yes.
+A. Oh, yeah, that's my background, that's my
+forte.
+Q. Is that something that you've gone back to?
+60
+A. Yes.
+Q. When did you go back to that?
+A. February of 07.
+Q. Who are you doing that for?
+A.
+• Dankjold Reed Aviation.
+Q.
+Say it again.
+A. Dankjold Reed Aviation.
+Q. How did you get that job?
+A. Applied for it and knew the previous
+Director of Maintenance, who was retiring.
+Q.
+Did
+Wexner and/or Mr. Epstein help you
+to get that job?
+A. No, no ties whatsoever.
+Q. So who introduces you to Jeffrey Epstein?
+A.
+Probably it would have been Larry. The
+first actual formal introduction?
+Q. Right.
+A.
+Probably would have been Larry Visoski. I
+knew Larry and Dave when they flew for Glimcher
+Corporation.
+Q.
+Tell me a little bit about that. Larry
+Visoski - how do you know him?
+A. He's the Chief Pilot for Jeffrey and hired
+me.
+Q. Well, he's the Chief Pilot now --
+
+
+5
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+AN M
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+61
+A Right.
+- for Jeffrey Epstein.
+A.
+Right.
+Q. When is the first time you met Larry Visoski?
+A. It was before he worked for Jeffrey. He
+and Dave were flying for a gentleman - Glimcher
+Corporation.
+Q. Flying for who?
+A. Glimcher Corporation.
+Q. How do you spell that?
+A. G-L-I-M-C-H-E-R, I think. They were --
+They had an airplane based at Lane Aviation in
+Columbus with us.
+Q. And David Rodgers?
+A. Yes.
+Q. How did you know David Rodgers?
+A. Same, from -- They were in the same hangar
+we were in.
+Q. Are you from here?
+A. No.
+Q. Where are you from?
+A. Columbus, Ohio.
+Q. So you're from Columbus, Ohio, and that's also
+a place where
+Wexner lives.
+A. Yes.
+62
+Q. So that was at least convenient for you?
+A.. Oh, yeah. No, it was -- Yeah.
+Q. Did you go to college in Ohio as well?
+A. Yes, Columbus State for my Aviation
+degree.
+O.
+As your first job that you had, was that with
+Wexner?
+Oh, no. I started working for Ohio State
+University -
+Q. And then where?
+A. - in their flight department.
+Went from Ohio State University to get a
+short stint, a contract maintenance for a - a
+contract for NASA at Langley - researcher, and then
+that was under the direction - that was contracted
+under OSU's umbrella for airport research. They had
+an Aviation Research Department. Then after that
+went to Red Roof Inns - maintenance technician for
+Red Roof Inns.
+Q. What was it - Gregory Finns?
+A. No, Red Roof Inns.
+Q. Red Roof Inns.
+A. True Sports Racing. It was Budweiser
+racing - Indy car team and Red Roof Inns, the motel
+chain. Then from there I went to The Limited stores.
+1
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+3
+5
+8
+110
+11
+12
+13
+114
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Galle Company
+October 6, 2009
+63
+Q. How did you learn of
+Wexner?
+A. Oh, I mean, he's very well-known in
+Columbus, because, you know, billionaires in central
+Chio, aren't, you know -
+Q. Aren't a dime a dozen, right?
+A. Exactly, and small guy that made it big,
+you know, because that's where the name Limited - so
+hearsay is - the name Limited came from he started
+with limited resources.
+Q. So did you know him before he was married to
+Abigail?
+A. Yes.
+Q. And did you know him to date exclusively women
+prior to that?
+A. The only -- I knew that he was dating
+Sharon.
+Q. Right.
+A. I never flew Sharon, but he dated Sharon
+for a long time, and then there was, you know, they
+broke up and then he started dating Abigail.
+Q. And have you heard any rumors about him dating
+men as well?
+A. No, no.
+Q. First time that you're hearing about it is me
+telling you that, right?
+64
+A. Yeah.
+Q. So back to Larry Visoski - you don't know him
+while you're employed with
+_Wexner.
+A. Yes.
+Q. You do?
+A. Yeah.
+Q. How do you meet him?
+A. Met him because their aircraft was in our
+hangar. The Glimcher aircraft was based in our
+hangar and got to know him that way.
+Q. Glimcher is a company owned by whom?
+A. I don't know if it's public or not. It
+was a mall development company not associated with
+Limited.
+So what's the conversation between you and
+Larry Visoski? Obviously you all end up working for
+Epstein, so try to lead me through that.
+A. Well, I think -- | mean, we got to know -
+I mean, you're neighbors in a hangar environment, so
+you have discussions.
+Larry was the mechanic. He was also
+pilot/mechanic on the Hawker for Glimcher, and you
+kind of form a relationship and a rapport, and then,
+I believe, Glimcher sold their airplane. I don't
+know how Dave and Larry ended up with Jeffrey, I
+
+
+1
+2
+3
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+118
+19
+20
+21
+22
+23
+24
+25
+1
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+65
+don't know how they found that job, but they started
+working for Jeffrey then, but they still --
+Q. Did you ask them?
+A. No, I don't think - I've never asked
+them, "How --
+Q. Did Jeffrey --
+A.
+- did you meet them?"
+Q.
+- have a plane in the same hangar?
+MR. REINHART: Hold on. Let him finish
+his answer.
+MR. EDWARDS: I'm sorry. I thought you
+were finished.
+MR. PIKE: This is Michael Pike. Let him
+finish his question because, keep in mind - you
+finish your question, let him finish his answer
+- keep in mind, I'm on the phone, so I'm having
+a hard time hearing his response in the
+background.
+MR. EDWARDS: You're actually on the other
+end of the table. Do you want us to try to move
+the phone closer?
+MR. PIKE: Yes, that would be good.
+MR. EDWARDS: I'll do that for you, man.
+I'm sorry, I really did forget that you were
+here.
+66
+MR. PIKE: Not a problem. I've objected
+to form a couple of times. I'm not quite sure
+if that was even heard, but that's neither here
+nor there.
+MR. EDWARDS: We'll say the last ten
+questions you objected to form. I got you.
+What was my last question, Pike? You
+don't even remember.
+MR. REINHART: You asked him conversations
+he had with Larry Visoski and Dave Rodgers about
+how they come came to work for Epstein.
+MR. EDWARDS: Good.
+A. I really never queried them on how they
+come to work for Jeffrey. I think Dave was hired
+first and he brought - this is all speculation - and,
+I think, he brought Larry on board.
+Q. So as far as you know, however you know, David
+Rodgers was the first Epstein contact and then Larry
+Visoski rode it in.
+A. The way I understand, yeah.
+Q. How did you become involved in the
+three-person train to Epstein?
+A. When it became apparent that Jeffrey, or
+Mr. Epstein, was going to buy the 727, Larry
+approached me, that if I would want to, you know,
+1
+2
+3
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+5
+6
+฿
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+er Gallo Company
+october 6, 2009
+67
+help them with the airplane, get, you know, become a
+flight engineer - Director of Maintenance - on it.
+Q. So is Larry also an Ohio person?
+A.
+• Well, he wasn't - I think he was born and
+raised in South Florida and then he was in Ohio for
+that job. He lived there for a short period, yeah,
+for Glimcher.
+Q. And then David Rodgers also?
+A.
+They both lived in Columbus, yeah. I
+mean, I don't know if it was a suburb, but they lived
+in central Ohio.
+Q. But the hangar we're talking about is in Ohio
+A. Yeah, Lane Aviation.
+Q. You would see them basically on a day-to-day
+basis because the aircraft that you were a technician
+for -
+A. Right.
+Q. -- was very close in proximity to the aircraft
+that they were piloting.
+A. Yes.
+Q. They approach you at some point in time and
+say what specifically?
+A. I can't remember the specific
+conversations, but it was like, you know, asked me if
+I would be interested in, if Jeffrey bought the 727
+68
+being, you know, the flight engineer and help them,
+you know, get the flight department going, and I told
+them I would
+Q. And why did you say "yes" considering that you
+had a boss in
+Wexner who was seemingly pretty good
+to you for the last ten years?
+A. Oh, he's excellent.
+Q. Yes.
+A. No, fine flight department and Mr. Wexner
+is a fine person.
+Q. Right.
+A. The reason being is, you know, I already
+stated this I think twice before, was that I wanted
+to be able to continue to fly and that would give me
+the opportunity to continue to fly as a flight
+engineer and the challenge of starting this airplane.
+Q. Right. I didn't ignore you. I heard you say
+that, but then I also heard you say he brought a brand
+new plane.
+A. It was only a two-man airplane -
+Q. So then he would have -
+A. - and the modern aircraft could only have
+two pilots, right.
+Q. Got you. I understand.
+So they approach you with this prospect of the
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+69
+two of them - Dave Rodgers and Larry Visoski - becoming
+the pilots for the 727 --
+A.
+Correct.
+Q.
+- that Epstein's buying and, "Hey, would you
+like to be a part of it?"
+A.
+Right.
+Q. I mean, that's the gist of it.
+A.
+Correct, that would be the gist of it.
+Q. And your response was?
+A. Yes, I would - you know, if it came to be,
+I would consider it. Obviously, you know, salary had
+to come in and everything else, but I said, "Yeah, I
+would be interested in it."
+Q. What's the next conversation that you had and
+with whom?
+A.
+I don't know. There were several
+conversations, but they were all with Dave and Larry
+both, you know, calling back and forth, but.
+Q. About what? Was it about salary, about the
+position?
+A. Salary, what the benefits were, you know,
+stuff like that. No, the position was pretty much
+defined. I mean, it's the flight engineer, Director
+of Maintenance position.
+Q. And this brings us up in our timeline to 2001,
+70
+you think?
+A. Correct, that's when I hired on and
+actually moved to Florida was January 2001.
+Q. Prior to 2001, had you heard the name
+Ghislaine Maxwell?
+A. Yes.
+Q. How would you have heard Ghislaine Maxwell?
+A. She had been a passenger on the 727 once
+or twice.
+Q. The 727, I mean?
+A. When it was under Limited.
+Q. Yeah, yeah, that's the point I'm trying to
+make. I mean, this could get confusing on the record.
+It's not confusing to me, but on the record it could be
+because the 727 was Wexner's, then it was Epstein, so
+you're talking about -
+A. When it was under Mr. Wexner's control.
+Q. What year do you think that was?
+A. It would have been in the late '90s.
+Again, like | say, when - probably some time around
+the time - you know, had to be late '90s --
+Q. Did she --
+A. -- maybe 2000.
+Q. Did she seem like a friend of
+Wexner's
+to you?
+1
+2
+3
+4
+5
+6
+8
+10
+11
+12
+13
+14
+15
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+aa Alexander Galle Company
+October 6, 2009
+71
+A. I don't know. I don't know.
+Q. I mean, how did she get on his private
+airplane? I would imagine strangers don't just walk on,
+right?
+A. Yeah, but I don't know. I don't know what
+people's associations are together when, you know.
+Q. Okay.
+A. I don't know if it's business association,
+social associations, or what.
+Q. How many times -
+MR. PIKE: Let me object to the form of
+that question.
+MR. EDWARDS: Okay. Noted.
+BY MR. EDWARDS:
+Q. How many times was she on that airplane when
+it was owned by
+Wexner?
+A. Not many, but i can't give you an exact.
+Q. Was she ever naked on the airplane?
+A. Not that I'm aware of.
+Q. I mean, that's something that you would
+probably remember, right?
+A. Well -
+MR. PIKE: Form.
+A. Yeah. I mean --
+Q. I'm not really trying to be funny, but I would
+72
+assume I would remember it.
+A. Not that I'm aware of.
+Q. Do you remember her bringing other girls on
+the airplane with her?
+A. No.
+Q. You remember her getting on the airplane
+alone?
+A. I can't say for sure.
+Q. Alright. Maybe this will jog your -
+A. I mean, she was never just alone-alone.
+Like the only passenger or.
+Q. Yes.
+A. No, no, always with - when other people
+were on board.
+Q. And you just can't remember whether she
+brought on board with her a male or a female; is what
+you're saying, right?
+A. No, I mean - Restate the question. How
+did you -
+Q. Sorry.
+A. Define "alone."
+Q. I don't mean, you know, if there's 15
+passengers and she gets on. I'm saying: Do you remember
+her getting on and being accompanied by - either they
+took the same car to the airport, they walked the runway
+
+
+1
+2
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+3
+4
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+73
+up to the airport? Do you remember her being with
+somebody else?
+A. If it would have been, would have been Mr.
+Epstein, never --
+Q. How many times do you think Mr. Epstein was on
+that airplane?
+A.
+I can't say for sure - not that many.
+Q. Less than five?
+A. That I saw him, yes, probably.
+Q. And how many times of all -
+MR. REINHART: Can I just clarify? You
+mean during the time Mr. Wexner owned the
+plane -
+MA. EDWARDS: Right, right, right.
+MR. REINHART: - since Mr. Epstein bought
+the plane
+BY MR. EDWARDS:
+Q. Alright. We're not up to the point, we're
+about to be, but we're not up to the point yet where Mr.
+Epstein takes control, so.
+A. I mean, you have to understand, Mr. -
+during this time period, Mr. Epstein had his other -
+he already owned his other airplane.
+Q. How did you know that?
+A. Well, because that's what Larry and Dave
+74
+were flying - the Gulfstream.
+Q.
+But this is something you found out
+afterwards.
+A. No, no. I knew that they had gotten a job
+with him and they were flying the Gulfstream.
+Q. Alright. Let me clarify this real quickly.
+You got the job in 1988 with Wexner.
+A. Right.
+Q. Right. Larry Visoski and David Rodgers are
+flying a plane that is presumably owned by Jeffrey
+Epstein and/or one of his corporations.
+A. Not at first.
+Q. At some point in time.
+A. Correct.
+Q. And what point in time do you become aware
+that that's happening?
+A. I can't remember exactly when they bought
+the Gulfstream. They actually had a Hawker for a
+short period. I don't know when that was.
+Q. Was that also owned by Jeffrey Epstein?
+A. For a very short period, and he traded it.
+Q. The first Epstein plane that you're aware of
+is that Visoski and Rodgers are on --
+Was a Hawker.
+Q. - was approximately what year?
+1
+2
+3
+4
+5
+6
+7
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+3
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Gallo Company
+october 6, 2009
+75
+A. Maybe mid-90, early '90.
+Q. We're talking -
+A. He didn't have that plane very long.
+Q. Between '90 and '93, you're saying.
+A. Probably, yes.
+Q. And between '90 and '93, if we use those
+years, you're familiar with the name "Jeffrey Epstein."
+A. Not until later when he bought the
+Gulfstream in - later when he was, you know, like I
+said, late '90, probably.
+Q. But you're aware that David Rodgers and
+Visoski are flying an airplane between '90 and '93 that's
+owned by somebody.
+A. Correct. Yeah.
+Q. But you don't know the name of the person --
+A.
+Correct. Right.
+Q.
+-- that is the owner. We're good. We're on
+the same page.
+'88, you start working for
+Wexner.
+A. Right.
+Q. And the first time Epstein is on
+Wexner's airplane is approximately when?
+MR. REINHART: It's asked and answered.
+BY MR. EDWARDS:
+Q. That you remember.
+76
+MR. REINHART: Asked and answered
+A. I can't - The only time I would remember
+- we've already answered this several times - was in
+the late '90s when i was actually on the airplane. I
+have no idea if he was on previous times without me
+there.
+Q. And when he is on the airplane, is he on the
+airplane with young girls?
+MR. REINHART: It's also been asked and
+answered
+A. No.
+Q. Now we're back to Ghislaine Maxwell, and I
+believe your answer - which led me back to these
+questions that I had previously asked, "Was Ghislaine
+Maxwell on the airplane that Wexner owned that you know
+of?' - and I think your answer was, "With Epstein."
+MR. PIKE: Form.
+A. I would -- I would say if she was on
+there, it would be with him. I never knew - I would
+not think that she would fly on it without him.
+Q. Do you specifically remember her on the
+airplane with him?
+A. Can't say - I can't.
+Q. On any of these flights that Jeffrey Epstein
+and/or Maxwell was on, did they fly internationally?
+
+
+2
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+3
+5
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+77
+A. I know I brought her back one time from
+England, I believe - I remember that - from London.
+Q. Brought Maxwell back from London, and was she
+alone then?
+A. I can't - I can't say. I can't remember.
+Q.
+I thought you said that if she was on the
+plane it wouldn't have been alone.
+A. More than likely she would have been with
+Jeffrey.
+Q. So do you think that you brought Maxwell and
+Jeffrey together back from London?
+A. More than likely, but I can't say for
+sure. I can't remember if he was on that flight.
+Q.
+To the best of your recollection right now, as
+we sit here, is that Maxwell was on the plane and Epstein
+may or may not have been?
+A. Correct. That's correct.
+Q. What year are we talking about and whose
+airplane are we talking about?
+A. That would have been when the 727 was
+still Limited - or Wexner.
+Q. And that would have been around what year?
+A. 2000, maybe.
+Q. 2000?
+A. "99, something like that.
+78
+Q. So this is almost into the transition --
+A. No, I'm sorry.
+Q.
+- into it.
+A. Let me think on the dates.
+Q. Okay.
+A. Yeah, I can't - I can't remember.
+Q. Late '90s or 2000?
+A. Late '90s.
+Q. Who has the flight logs from late '90s?
+A. I don't know.
+O. But that's something that the FAA would have,
+right?
+A. No.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. Flying internationally?
+A. I don't know if the FAA gets that. It
+would more - most likely be Customs and Immigration.
+MR. PIKE: Are you guys getting my form
+objections?
+MR. EDWARDS: Yes. We got you.
+MR. PIKE: Thank you. Brad, I just want
+on the record that not all of my form objections
+are coming through, so if we have an issue with
+this deposition - I am on the phone - and I want
+H N
+4
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+10
+11
+12
+113
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Gallo Company
+October 6, 2009
+79
+the Court to be well aware that not all of my
+form objections are coming through the
+telephone.
+MR. EDWARDS: Mike, how about this, of all
+of the people involved, I think that you know
+you can trust me here: If you say when we read
+this back that you wanted a form objection, I'll
+put it on the record right now you get it - how
+about that?
+MR. PIKE: Not a problem.
+BY MR. EDWARDS:
+Q. Alright. Have you ever looked at any of the
+information from Customs and Immigration related to
+flight logs?
+A. No.
+•. If Customs and immigration is the right agency
+to take control of these documents, who is it that
+generates the documents in terms of personnel riding upon
+this airplane?
+A. Captain.
+Q. Who was the captain or who were the captains
+that you are aware of - and try to give me years, if many
+of them changed, to the best of your knowledge - for
+Wexner?
+A. Primarily it would have been Tim Staley.
+80
+Jim Taylor, Rob Imlay.
+Q. Rob?
+A. Imlay, I-M-L-A-Y, Bill Hammond.
+Q. Bill Hammond?
+A. Uh-huh.
+Q. Bill Hammond later becomes affiliated with Mr.
+Epstein too, right?
+A. Correct.
+Q. We're going to get to that.
+Have you ever been a captain?
+A. No.
+Q. And when you say that it's not necessary -
+unless you're flying internationally, I know - but it's
+not necessary to maintain a passenger manifest that
+delineates the exact name, where are you getting that
+information from?
+A. I know it's not required by the FARs.
+Q. How do you know that?
+A. Because you can read the FARs, Part 91,
+FAR 91, Operations.
+Q. What's "FAR" stand for?
+A. Federal Aviation Regulations.
+Q. And what would be the reason not to put the
+whole name of the person on the airplane?
+A. I don't know. I-- I don't know.
+
+
+1
+3
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+3
+4
+6
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+81
+Q. Because later I'm going to show you some
+lists, and certain people are listed by full name and
+others are listed generically - any idea why that would
+A. Unless they just don't know who it is, you
+know, just a guess. I mean, you know, you don't want
+to query somebody and give them the third degree if
+it's just a guest of the boss that's, you know,
+riding along or something.
+Q. Well, she asked you your name before your
+deposition and you didn't consider that the third degree
+by any means, right?
+A. Right, but --
+MR. PIKE: Objection to form.
+A. But you're approaching your employer's
+guest. It would be like walking into his house and
+asking him, "Who's sitting at the dining room table?"
+- in a way. See what I'm saying? It's just - You
+have to maintain -
+Q. But --
+A. - the employee/employer relationship.
+Q. No, no, no. I guess what I'm saying is: If
+one of these people is Mohammed Atta, you would like to
+know it, probably.
+A. Well, yes.
+82
+MR. PIKE: Form.
+A. Yes, yes.
+Q. So any reason why a captain trying to secure
+the airplane and the people aboard wouldn't take that
+extra step and try to figure out who's exactly on his
+A. Well, when it's - the normal passenger
+loads are five to ten people, at the very most, and
+they're all with the owner and accompanying the owner
+and some of the regular passengers, you know; the
+likelihood that Mohammed Atta is going to sneak in
+there and board his plane and ride along is - you
+Q. He's willing to play those odds, okay.
+A. Well, I'm not saying that he's playing
+odds. I'm just stating that the only reason I can
+think - I don't know. I've never filled those out.
+The only reason I can think is he just didn't have
+the name and didn't want to intrude and ask.
+Q. If you were a captain, would you ask who was
+on your airplane?
+A. Not if the situation was that it was
+controlled by the owner and I knew who the - you
+know.
+Q.
+Okay.
+1
+2
+3
+5
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alesander Gallo Company
+October 6, 2009
+83
+A. It would be obvious that these are
+associates of some form, that they're not, you know,
+strangers trying to board the airplane.
+Q. So let's go back to that conversation that you
+have in the Ohio hangar, or whatever it is, with David
+Rodgers and Larry Visoski when they talked to you for the
+first time about possibly switching over to Mr. Epstein.
+A. Uh-huh.
+Q. How does that conversation really go about?
+MR. PIKE: Form.
+A. I don't understand. What do you mean,
+"How did it go about?"
+Q. Did you approach them and say, "Hey, are you
+going to stay here forever with this airplane?" or "Do
+you have another job for me?" or what?
+A. I think it was just, you know, I believe
+Larry approached me. I can't remember. It was that
+long ago, but -
+Q. What does Larry say to you?
+A. I can't remember the exact conversation.
+Q. I mean, was he not happy where he was?
+A. Who, Larry?
+Q. Yes.
+A. Never said he wasn't.
+Q. How did you know Larry?
+84
+A. What are you talking about? Why would he
+not be happy where he was? I don't understand.
+Q. Well, he's working for some other corporation
+that's not non-Epstein owned
+A. Oh, that previous corporation sold the
+airplane.
+Q. Oh, they did?
+A. Yeah. He had no choice. They were out of
+work.
+Q. So Larry and David were about to be out of
+work.
+A. Yes.
+Q. So they said, "Hey, we found a new job and
+it's with this guy Jeffrey Epstein and he's buying that
+plane.
+Do you want to be involved?*
+A.
+No, no. There was another airplane in
+between - two other airplanes. There was a long time
+between - and I don't know the exact dates and I
+don't know that I even do know the dates - but there
+was a time between when they left Glimcher before
+Jeffrey got involved with the 727.
+Q.
+So they leave Glimcher?
+A. Yes.
+Q. Then what happens?
+A. They somehow - I don't know how - hired on
+
+
+4
+6
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+4
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+85
+with Jeffrey.
+Q. They hired on with Jeffrey to pilot the 727?
+A. No. He had two other airplanes prior to
+that. He had a Hawker that he had for a very short
+period and then he bought - traded it or sold it. I
+don't know what he did with it, but then he got the
+Gulfstream.
+Q. So Larry Visoski and David Rodgers were pilots
+for Jeffrey Epstein when he had the Hawker also?
+A. Yes.
+Q. And what year are we talking about there?
+A. I have no idea.
+Q. Well, if you sign on with him in '91, it's
+before that year, right?
+A. No, no, I signed in '01 - January '01.
+Q. '01.
+A. I don't know how long they flew for
+Glimcher before that airplane went away and how quick
+they got on with Jeffrey. I don't know. Somewhere
+between '88 and 2001, they -
+Q. During --
+A. - left Glimcher and --
+Q. During '88 and '01, do you remain in contact
+with Larry Visoski and David Rodgers?
+A. On and off. They eventually moved, you
+86
+know, to - moved away from Columbus when they hired
+on with Jeffrey, so they weren't in the hangar every
+day.
+Q. Where did they go - do you know?
+A. I think Dave went to New York and Larry
+went back to South Florida.
+Q. Do you know why?
+A. Well, because I think Jeffrey gave them
+the choice of living where they would like, I
+believe. I mean, that's -
+Q. That's what they've said.
+A. That's what they've said.
+Q. Okay, and Larry chose South Florida, David
+Rodgers chose New York?
+A. Right.
+Q. And Epstein had a place for them both wherever
+they wanted to go?
+A. Well, they owned their own homes or
+something. I don't know what their living
+arrangements were.
+Q. Did you know Larry Rodgers or David Visoski
+before this?
+A. Before?
+MR. PIKE: Form.
+BY MR. EDWARDS:
+5
+7
+10
+13
+14
+15
+16
+17
+18
+19
+20
+|21
+22
+23
+24
+25
+1
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Gallo Company
+October 6, 2009
+87
+Q. Before your conversation with them about
+becoming involved with Jeffrey Epstein.
+A. Yes.
+Q. How?
+A. Like we discussed. We've been through
+this already. When they were at Glimcher they had an
+airplane in the hangar. We would see them
+sporadically and we would talk.
+Q. I'm sorry, bad question. I don't mean on a
+business relationship. On a social relationship, did you
+hang out with them -
+A.
+Oh, no.
+Q. - outside of this?
+A. No, no.
+Q. I apologize.
+So - and I only asked that question because
+some years later then you're in contact with them and
+they asked you to become involved with Jeff Epstein.
+A. Uh-huh.
+Q. But that is because of a business relationship
+solely that you had with them --
+A. Oh, yeah.
+Q. -- years before?
+A. I didn't know them personally.
+MR. PIKE: Form.
+88
+BY MR. EDWARDS:
+Q. Okay. Alright. So in 2001, is that the year
+that you get a telephone call from one or two of these
+people?
+MR. PIKE: Form.
+A. It would be either late 2000 or early
+2001. I don't -- These transactions don't happen
+overnight --
+Q. Yeah.
+A. - buying an airplane. So it could have
+happened in, you know, November or started talking in
+November, like, Well, you know, would you be
+interested if Jeffrey gets the airplane or buys the
+airplane?" you know, to when I actually hired on.
+Q. Did you ever talk to Ghislaine Maxwell - ever?
+A. After I had hired on, yes.
+Q. After you hired on with Epstein.
+A.
+Yes.
+Q.
+We'll go up to her.
+So when is it that you hired on with Jeffrey
+Epstein?
+A.
+I think | began in January of 01.
+Q. In January of '01, do you start getting a
+paycheck from Jeffrey Epstein?
+A.
+Yes.
+
+
+3
+5
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+5
+6
+8
+9
+10
+11
+12
+13
+/14
+17
+18
+19
+20
+21
+22
+23
+24
+25
+89
+Q. And is it paid from one of his companies or
+from Jeffrey Epstein specifically?
+A. No, no - JEGE.
+Q. JEGE. What is your understanding as to what
+that is?
+A. It's just initials. It's a name. I don't
+have any idea what it stands for, but I'd ask that a
+million times.
+Q.
+It's a company that owns something, right?
+A. I don't know --
+MR. PIKE: Form.
+A. - if it even owns anything. I don't know
+what type of company it is. I don't know if - It's
+just a Wilmington, Delaware, company.
+Q.
+on?
+What's the bank account that it was written
+A. I can't remember. I mean, I know I'd read
+- I'd see "JEGE" on it, that's all.
+Q. A New Mexico bank, New York bank, Florida
+bank?
+A. I have no idea because it's direct
+deposit. All I would do is just see if the amount's
+right. I dont - I have no idea. I would -- I have
+no idea.
+Q.
+What was your communication - direct
+90
+communication with Jeffrey Epstein that results in your
+employment with JEGE?
+MR. PIKE: Form.
+A. A conversation result in my - Essentially
+Larry hired me. I mean, it wasn't - it wasn't - |
+didn't really - I may have had one phone
+conversation with Jeffrey prior to actually being
+hired and the next time I saw Jeffrey was when I was
+in Florida with the airplane.
+Q. What did Jeffrey ask you in that one phone
+conversation?
+A. I think he asked me what my current salary
+was, or something along that line, you know.
+Q. Did he ask you what you were looking for in
+terms of salary?
+A. Yes.
+Q. What did you tell him?
+A. I told him to basically -- I forget how it
+went exactly. It ended up being like $117,000,
+something like that.
+Q. $117,000 a year?
+A. Yeah.
+Q. And what were your duties?
+A. Basically - flight engineer, obviously,
+but all line maintenance and scheduled maintenance to
+1
+2
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+3
+4
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alesaader Gallo Company
+October 6, 2009
+91
+perform.
+Q. On what planes?
+A. Just the Gulf - just the Boeing.
+Q. Just the Boeing?
+A. Uh-huh.
+Q. Over the years, did you become aware that he
+owned other aircraft?
+A. I knew that he still had that.
+MR. PIKE: Form.
+A. He still had the Gulfstream.
+Q. At the time back in 2001 - and we're going to
+walk through some of his airplanes - he owned the Boeing
+727, right?
+A. Correct.
+Q. And what other airplanes did he own at that
+time when you signed on with him in 2001?
+A. The Gulfstream.
+Q. Gulfstream is what?
+A. 2B.
+Q. Do you know who the pilot was for that plane?
+A. Dave and Larry, I mean, it's always.
+Q. Was it always Dave and Larry no matter what
+plane was being taken out?
+A. Unless somebody was on vacation or in
+school and they used contract people.
+92
+Q. What was the purpose behind having multiple
+planes - used one for the purpose, one for another - do
+you know?
+A. I never could figure that out.
+Q. Really?
+A. Yeah.
+Q. No rhyme or reason why he took one this way
+and one that way?
+A. No. He was - pretty much once the Boeing
+got on line. Now, you know, the Boeing goes down for
+heavy maintenance. It used to go annually, now it
+goes down bi-annually, but - so he would utilize that
+airplane while it was out of service, you know, for
+maintenance, which sometimes would be four, five
+weeks at a time, so.
+Q. And in those cases, then he would use the
+Gulfstream 2B7
+A. Yes.
+Q. Have you been on both planes?
+A. Yes.
+Q. We're still talking about 2001. Is that the
+first time that you're on the 727?
+A. First time I was on the 727? Wait. I
+don't know what you mean.
+Q.
+After Epstein owns it.
+Toil Free:
+
+
+1
+2
+3
+4
+7
+9
+10
+11
+12
+13
+14
+15
+116
+17
+18
+19
+20
+121
+22
+23
+124
+25
+1
+2
+5
+B
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+93
+A. Yes.
+Q. And do you remember where you went?
+A. Very first flight, no, because we didn't
+fly it immediately. We upgraded some avionics and
+did modifications.
+Q. What modifications did he want to that plane?
+A. Just changed the carpet and some fabrics,
+upgraded the radar, upgraded the navigation - the
+flight manifest systems.
+Q.
+Did he change the interior at all?
+A. No. We removed that one small table and
+chair - that's it, but we did not really change what
+you would consider the floor plan.
+Q. Now, try to give me a visual appreciation of
+the inside of the plane. If I'm looking out the cockpit
+back towards the back of the plane; what am I going to
+see?
+A. A door.
+Q. That's it?
+A. That's it, yeah.
+Q. Just an empty room with a door?
+A. No, no. The door's always closed. If the
+door's open you will see the forward salon, and in
+the forward salon there is a conference table, a
+high/low table, some divans, and some single seats.
+94
+Q. What's behind that?
+A. The galley.
+Q. The what?
+A. The kitchen - galley.
+Q. Okay.
+A. Behind that is the aft salon, which is
+just two round divans.
+Q. And?
+A. After that is the office, which is a -
+consists of a credenza and a desk, or divan and a
+desk and chairs.
+Q.
+How many of these areas can you close off or
+partition?
+MR. PIKE: Form.
+A.
+Each one. And after that there's the
+state room.
+Q. And in the state room - how big is the state
+room?
+A. Consists of a queen size bed and two
+single seats.
+Q. Have you ever been back in the state room?
+A. Oh, yes. Yeah.
+Q. When's the first time you flew on the airplane
+with Jeffrey Epstein back in 2001, after he acquired the
+727?
+1
+2
+3
+4
+6
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+124
+125
+2
+3
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Galle Company
+October 6, 2009
+95
+A. Cant remember the first flight. Like
+say, it was down for a while - probably - I think it
+was - had to take at least three to four months maybe
+to get it --
+Q.
+And did you know of him flying on the airplane
+with girls accompanying him?
+MR. PIKE: Form.
+A. I don't -
+Q. Back in 2001.
+A. With girls accompanying him?
+Q. Yes.
+A. Yes.
+Q. Where would he pick the girls up from?
+MA. PIKE: Form.
+A. I don't know. They would arrive with him,
+you know, out of Palm Beach or out of New York. I
+don't even remember where we went the first time.
+The first flight was probably New York, I think.
+Q. Is it a private airport in New York where you
+would usually pull into or a commercial airport?
+A. I think the first time we started going up
+there, I think, we were using White Plains, which is
+- actually, it's not a private airport. They all
+have some commercial service. It would have been
+White Plains, I believe, then later we started using
+96
+Kennedy, and the service was so terrible in Kennedy
+and so expensive we went to Newark.
+Q. When you would fly into White Plains or to
+Kennedy or Newark, would you always get off of the
+airplane or would you sometimes stay on and wait for
+passengers to board?
+A. I don't understand
+Q. Well, when you stop an airplane --
+Q. - sometimes you get off the airplane and you
+go either through a, you know, through the airport or you
+go somewhere else, or your option is to stay on the
+airplane and not get off and wait for other people to get
+MR. REINHART: I'm sorry, can we clarify
+the "you"? Do you mean him personally or the
+people who were passengers on the plane that he
+Q. I'm talking about you personally.
+A. Oh, no, it was rare that we ever did a
+through flight. We would normally go from Point A to
+Point B, and that was the destination.
+Q. I assume when he buys the plane initially it
+was in Ohio, right?
+
+
+1
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+97
+A. Well, yeah, but --
+Q. Then you fly to Florida.
+A. Well, we crewed it to Florida and then it
+sat at a facility in Florida during negotiations, so
+it didn't go directly from Ohio.
+Q. In 2001, when there's still negotiations,
+where in Florida is the airplane?
+A. Lake City - Timco, Lake City.
+Q. During the negotiations, does it ever take off
+or is it grounded?
+A. No, no, it's grounded, because on a Part
+91 deviation it has to be under a specific
+maintenance program, so when it left The Limited, it
+left that maintenance program, and I had to
+transition it to the new program.
+Q. This is still sometime in 2001, right?
+A. Early, yes, yes.
+Q. And then it passes all inspections, I'm
+assuming?
+A.
+Right, right.
+Q. Then you take it to what airport to where
+it --
+A. PBI.
+Q. PBI?
+A. Here in West Palm.
+98
+1
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Q. While it's at PBI airport, does it take off
+from there?
+A. No, not for - That's when we were doing
+the modifications and upgrades. We were doing the
+avionics.
+Q. How long did that take?
+A. I don't remember the exact time - maybe
+three to four months.
+Q. Who does it with you?
+A. Jet Aviation. Jet aviation did the
+avionics and soft goods.
+Q. And when you say the "soft goods," what do you
+mean by that?
+A.
+Carpet, fabrics, leather, you know,
+different things like that.
+Q. When's the first time it takes off then on a
+real flight - some time in 2001, but mid-year or
+something?
+A. Probably mid-year, maybe a little earlier
+than mid-year.
+Q. We're talking about June of 2001?
+A. Right.
+Q. And where do you go?
+A.
+Can't remember. I can't remember for
+sure.
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+118
+19
+20
+21
+22
+23
+24
+25
+an Alexander Gallo Company
+October 6, 2009
+99
+Q. Who's on the airplane?
+A. Well, obviously it would be Jeffrey.
+Q. Right.
+A. I can't remember who all went.
+Q. Who were the pilots?
+A. I can't remember that either.
+Q. Larry?
+A. No.
+MR. REINHART: Hold on.
+A. It would have been myself, for sure -
+because I was the only one with experience on the
+airplane - myself, Dave, I believe, would have been
+captain because he had been schooled, but I can't
+remember if Larry took first flight or not. I think
+he was still in training
+Q. Where did you go?
+A. I can't remember.
+MR. PIKE: Form.
+A.
+I can't remember if it was New York or --
+I would imagine it would be New York, but I can't
+remember.
+Q. When you say you would imagine New York, I'm
+getting the impression that many of the flights went to
+and from New York.
+A. Yeah, primarily.
+100
+Q. So if -
+A. And --
+Q. So any time you're having to guess where it's
+going, you're saying New York because that's the primary
+place it's going
+Correct. I would have remembered - | --
+I know I didn't get - I had heard about St. Thomas,
+but I hadn't been there right away. I didn't get to
+go to St. Thomas for a while.
+Q. That's later on in the story.
+A Yes.
+Q.
+We'll get there.
+So you go to New York. Does he tell you the
+purpose behind going to New York?
+A. No.
+Q. Prior to this trip to New York, have you had a
+personal conversation with Jeffrey Epstein?
+A.
+No.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. Never?
+A. Not personal. Everything is
+business-related.
+Q. Okay, but -
+A. I mean, it was about the interior work or
+
+
+1
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+4
+6
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+101
+the avionics going in, but never personal.
+Q. But, I mean, you've been hired by him --
+A. Right.
+- you agreed on a salary, he's going to pay
+you the salary, but other than that, and what maintenance
+may be required -
+A.
+Correct.
+Q.
+- on the airplane, nothing else?
+A.
+He's a very - His conversations are
+usually very short. He doesn't, you know, take much
+time.
+Q. When you would have conversations with him,
+would they be over the telephone or would they be in
+person?
+A. It could be in both. If he was in Florida
+and I wanted to actually show him a fabric or a
+sample for the airplane or he wanted to view how it
+was coming, but oftentimes it would be via telephone
+from New York.
+Q. When it would be in person, would you see him
+surrounded by or be accompanied by a girl or girls?
+MR. PIKE: Form.
+A. At times, yeah.
+Q. Would any of those girls be Ghislaine Maxwell?
+A. At times, yes.
+102
+Q. Would any of those girls look extremely young
+to you?
+MR. PIKE: Form.
+A.
+Not - Not that I thought.
+Q. Not back in 2001, we're talking about?
+A.
+Right, right.
+Q.
+No.
+What would Ghislaine Maxwell say to you, if
+anything?
+MR. PIKE: Form.
+A. She'd -- Mostly small talk, just -- She
+kind of did the business management part of it as far
+as, you know, arranging cell phone - I was having
+cell phone problems with the company cell phone, she
+would handle things like that, but she would have
+minor inputs on the interior work.
+Q. What was your understanding back in 2001 still
+of the relationship between Ghislaine Maxwell and Jeffrey
+Epstein?
+MR. PIKE: Form.
+A.
+I really didn't understand it. I thought
+it was personal - personal and business.
+Q. When you say "personal," did you think it was
+sexual?
+A. I thought maybe they were dating and, you
+1
+3
+8
+10
+11
+112
+13
+14
+15
+16
+117
+118
+19
+120
+21
+22
+123
+24
+25
+1
+2
+3
+4
+5
+7
+8
+9
+10
+|11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+= Alexander Galle Company
+October 6, 2009
+103
+know, business relationship too.
+Q. Did you know who Ghislaine Maxwell was?
+A. Not right away, no, no.
+Q. Not right away?
+A. Right.
+Q. At some point in time you were curious enough
+to make an attempt to find out.
+A. No, I --
+MR. PIKE: Form.
+A. - heard about her and there was a book up
+in New York in the apartment that we stayed in that
+was -- You know, you're sitting there with nothing to
+do, I read that.
+Q. Do you remember the name of the book?
+A. It was just "Maxwell."
+Q. Have anything to do with her father?
+A. Yeah, it was about him, that's what it was
+about. I mostly just flipped through looking at
+pictures, boats, and airplanes and stuff.
+Q. Back in 2001, the first time you had a real
+conversation with Ghislaine Maxwell --
+MR. PIKE: Form.
+A. Yes.
+Q. - what did that conversation consist of, if
+you remember?
+104
+A. I think it was concerning getting a cell
+phone and a pager - that's it.
+Q. Did it have anything to do with underage
+girls?
+A. Absolutely not, no, no.
+Q. That's not something she ever shared with you?
+A. No, no.
+Q. Did Jeffrey Epstein ever share with you that
+he wanted underage girls -
+A. No.
+Q. - in any way?
+A. No.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. I mean, certainy I'm not saying something to
+you that's an absolute shocker right now -
+A. Right.
+Q. - considering the newspaper articles.
+A. Right, but I know - You have to
+understand, every conversation I had was pretty much
+business, just to deal with the airplanes. You know,
+I'm an employee/employer relationship.
+Q. I just don't want you to think I'm just asking
+random off the wall questions -
+A.
+Right.
+
+
+1
+2
+3
+7
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+4
+5
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+119
+20
+21
+22
+23
+24
+25
+105
+Q. - that have nothing to do with anything.
+A. I understand.
+Q. 2001, you start working for him, and that June
+or so is the first flight, and you believe it's to New
+York.
+A. Correct.
+Q. Do you remember the purpose behind the flight?
+A. No, did not know the purpose.
+Q. Did you get off the airplane in New York?
+A. Yes, yes.
+Q. Where did you go?
+A. Probably to - into the city, into the
+city, and he has an apartment building up there that
+we would stay in in the city.
+Q. Is it paid for by Jeffrey Epstein?
+A. What?
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. The apartment.
+A. Well, he - It's - | think it's in the
+building he owns. I mean, I just - I don't know.
+Q.
+Do you remember the address?
+A. 301 East 66.
+Q. 301 East 66 Street, right?
+A. Right.
+106
+Q. Did he ever mention a brother that he may have
+to you?
+A. I met his brother, I think, once.
+Q. What's his name?
+A. I can't remember.
+Q. Mark?
+A. I remember meeting.
+Q. Mark Epstein strike --
+A. Honestly, I can't say for sure.
+Q. And how do you know that Jeffrey Epstein owns
+the apartment building at 301 East 66 Street?
+A. Larry told me. I mean, it was just kind
+of known.
+Q. Larry told you -
+A. Yeah.
+Q. - or Jeffrey told you?
+A. Oh, no, not Jeffrey, no. Larry. I
+wouldn't have asked Jeffrey.
+Q. How many of those apartments up there in New
+York is it your understanding that Jeffrey owns?
+MR. REINHART: I'm sorry, are you asking
+how many units are in the building or how many
+buildings?
+BY MR. EDWARDS:
+Q.
+No, how many units that Jeffrey owns in the
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+113
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Galle Company
+October 6, 2009
+107
+building. I've been to the building. The building is
+huge.
+A.
+I don't know. I don't know if he owns the
+building or just - or how many units he's got. Maybe
+ten, because I think some of the employees up there
+live in them.
+Q.
+Do you remember who some of the other
+employees are that live in that building?
+A.
+Well, I think Darren used to live in it,
+Darren Indyke.
+Q. Darren Indyke, right.
+What abou
+, do you remember her?
+A.
+lived in there.
+Q.
+What about
+A. I don't know if
+lived in there or
+not.
+Q. You know who that is, though.
+A.
+Right, right. Actually, she was just kind
+of coming into the picture when I was - about the
+time when I was leaving.
+Q. What about Ghislaine Maxwell?
+A. No, no, she didn't live there.
+Q. What about Jean Luc Brunel?
+A. No.
+Q. How about: Did Mark Epstein ever indicate to
+108
+you that he had any ownership in any of that?
+A. Oh, no. I only saw him one time on a
+short flight. I don't even know where we - we were
+probably taking him to and he was just - Jeffrey
+introduced him as his brother and it was very short,
+you know, just, "Oh, hi. How are you?", and he went
+in the back.
+Q. Do you know anything about the guy?
+A. Uh-uh.
+Q. Nothing?
+A. Nothing,
+Q. So in 2001, there's a flight up there at some
+appointment in time, and you get off and you stay at one
+of the apartment buildings at East 66 Street.
+A. Right, right.
+Q. And did you meet any of the neighbors of the
+apartments that are also owned by Jeffrey Epstein?
+A. No, no, because when we're there it's
+usually just for a night or something and then, you
+know, we're either airlining home or going on.
+Q. How did you know Darren Indyke?
+A. He's our - He's our business attomey for
+JEGE.
+Q.
+the apartments at
+Do you remember any of the other tenants of
+other than Darren
+www.esquiresorutions.com
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+5
+6
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+109
+Indyke and
+A. Not that I remember, no.
+How about
+A. I don't think
+lived there.
+Q.
+Do you remember that name?
+A. Yes.
+Q.
+What about
+A.
+?
+no, I don't think so.
+Q.
+Jeff Fuller?
+A. I don't know Jeff Fuller. I don't even
+know Jeff Fuller.
+Q. Do you know the name Jean Luc Brunel?
+A. Yes.
+Q. How do you know that name?
+A. He's been -- He was a passenger on a few
+of our flights.
+Q. Do you know why?
+A. I think he was -- I don't know for sure.
+He's in a modeling business with Mr. Epstein, I
+believe.
+Q. MC2? Do you know that name - MC2 Modeling
+Agency - used to be Karin Modeling Agency, now it's MC2?
+A. No.
+Q. How do you know about his and Mr. Epstein's
+modeling agency? How do you know that?
+110
+A. Just every once in a while he would say
+something about, you know, one of the model shoots or
+something. We normally had him on - we would take
+him back and forth to Paris.
+Q. Where some of their models come from?
+A. I don't know.
+Q. Did you ever bring some of the Paris models
+back?
+A. Not that I'm aware of, no.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. So he would go to Paris on the airplane, Jean
+Luc, would you drop him off there or would you pick
+people up and bring them back?
+A. If I remember, normally we were bringing
+Jean Luc from Paris to New York, if I remember.
+Q. And when you say that the modeling agency -
+obviously that, you know, between him and Mr. Epstein -
+is that something that Mr. Epstein would talk to you
+about or is that something that Jean Luc would talk to
+you about or you would just overhear the two?
+A. Overhear the two, or Jean Luc may say
+something about one of the shoots or something, just
+in general conversation.
+Q. And what would Jeffrey's comment be about some
+october 6, 2009
+1
+2
+3
+6
+9
+10
+11
+12
+(13
+14
+115
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+3
+4
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+111
+of the MC2 shoots?
+A. I never heard - There was one incident -.
+The only thing I remember about it is they were on a
+shoot - and it's not funny, but Jeff - but it is in a
+way - they were in a motor home on location at the
+shoot, and they started to drive off and one of the
+models asked to use the restroom and they told her
+which door it was and she went out the side door, so
+grabbed the wrong door, but that's actually the only
+thing that sticks in mind - was that one.
+Q. Have you ever done any research on Jean Luc
+Brunel?
+A. No.
+Q. Do you have any idea that he's known
+throughout Europe as somebody who has sex with underage
+girls?
+A. No.
+Q. You didn't know that until right now?
+A. Correct.
+Q. That's something that you're learning as a
+surprise to you.
+A. Yes.
+Q. So
+• somebody you never heard
+of?
+A. It sounds familiar. I'm trying to place
+112
+her. I don't know if she works in the office or -
+Q. Or worked in the office?
+A. Worked in the office, yeah. I very rarely
+went to the office. I mean -
+Q.
+- how do you know her?
+A.
+From the flights - being on the airplane.
+Q. How many times was she on the airplane?
+A. Quite a few. Almost every.
+Q. What's your understanding as to what she did
+for Mr. Epstein?
+A. Like a personal assistant.
+Q. Personal assistant doing what?
+A. Arrangements, meetings, handling like, /
+guess, personal affairs, you know.
+Q. Did Mr. Epstein ever once mention to you that
+he likes massages?
+MR. PIKE: Form.
+A. No, he never mentioned that to me.
+Q. That's not something that you ever heard of,
+right?
+A.
+Well, I-
+Q. I mean, outside of the articles that you've
+read.
+A.
+Right. No, but he never came up to me and
+said, "I like massages."
+an Alexander Galle Campany
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+113
+Q. And did
+- did you hear her
+organizing, scheduling, talking to people about either
+what she may call "work" or "massages" for Epstein?
+A. No, no, I don't.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. What types of conversation, if you can
+remember anything, did you ever overhear
+talking about?
+A. It would be mostly like transportation
+arrangements - car needs.
+Q. Car needs for who?
+A. Well, making sure that the driver in New
+York was meeting the airplane at the proper time,
+stuff like that, or if they had an unusual large
+amount of baggage, to make sure that another car was
+hired to come pick this up, things like thatlogistic-type stuff.
+Q. We're still talking about a time period back
+in 2001, right, in these --
+A. No.
+- I don't remember
+coming
+into the picture until later.
+Q. Later in 2000-something?
+A. No, she wasn't around at first.
+Q. Alright.
+114
+A. No. I don't remember when exactly
+but she-
+Who was making the arrangements for meetings
+and such prior
+A. Ms. Maxwell.
+Q. - that you remember?
+So Maxwell was the, for all intents and
+purposes,
+A. For all intents and purposes, yes.
+Q. And did you ever hear of Ms. Maxwell making
+arrangements for massages or for girls or anything else?
+A. No.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. Where were the conversations - whether it was
+travel or whatever else - that was occurring between
+Maxwell and/or
+? Where were they taking
+place - on the airplane, some office?
+A. Yeah. No, no, usually in the cockpit, you
+know, prior to departure, en route stating, "We've
+got this many cars and I've contacted" or "Can you
+call such and such to have this brought out?*
+Q. Did you ever see Epstein work a lot?
+MR. PIKE: Form.
+A. He always had a briefcase with him and he
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+3
+4
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alezaader Galle Company
+October 6, 2009
+115
+always sat it by his office in the back.
+Q. Always had a computer?
+A. No, no, it's just a large briefcase.
+Q. Did you ever know his e-mail?
+A. Yeah, I had it -- I can't remember what it
+was and I don't think it's even current - but when I
+would have to send him e-mails about the interior or
+maintenance issues. It was jeprojects, or something
+like that, at - I don't know if it was at Yahoo or
+gmail. I don't think it was gmail.
+Q. You think it was jeprojects?
+A. I believe so, but I can't remember what
+service.
+Q. At gmail.com or something?
+A. Or something like that or Yahoo or
+something.
+Q. How about Ms. Maxwell?
+A.
+It was
+I think.
+Q. Do you know if that's still current?
+A.
+No, I don't.
+Q. How about
+A. I had it at one time and I know she
+changed it and I don't know what it is. I can't
+remember what it was, actually.
+Q.
+Do you know
+- where she is
+116
+right now?
+A. No.
+Q.
+Do you know if she's intentionally on the lam
+to try to avoid being deposed in this case?
+A.
+No.
+MR. PIKE: Form.
+A.
+No idea. I haven't had any contact with
+since I stopped flying.
+Q.
+You say that
+was just coming in the
+picture - is the words that you used. What did you mean
+by this?
+A. Well, I mean she was just -- I'm trying to
+remember when I first started seeing her on the
+airplane. I think it was not too long before I quit
+flying. I can't remember the exact date.
+Q. When did you stop flying?
+A. In February of '07.
+Q. February '07?
+A. Yep.
+Q.
+And you don't think you saw her on the
+airplane until before that?
+A. No, I'm saying she was only coming into
+the picture like maybe six months before that or so
+or - I don't know for sure.
+Q. You don't remember seeing her on the airplane
+
+
+10
+11
+12
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+117
+in 2001, 2002, 2003?
+Oh, no, not that early.
+Q. Do you know where she came from?
+A. Just what I've read in the paper - an
+eastern country. I'm sorry, I don't remember the
+country.
+Q. Were you ever told that Mr. Epstein bought her
+from her family when she was 14 years old to come over to
+be his Yugoslavian sex slave - is that something that you
+ever heard?
+A. No. I did read something like that in the
+paper, but, no, never heard of that.
+Q. Did you ever see him and her sexually involved
+on the airplane or otherwise?
+A. No.
+Q. Did you ever see Epstein involved sexually
+with anybody on the airplane?
+A. No.
+Q. Did you ever see the airplane used for sexual
+purposes?
+A. No.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. If it had happened - considering the various
+areas that were cordoned off or blocked off - would that
+118
+have even been something that you could have seen?
+A. No, no, if it was - if the doors were
+closed, no.
+Q. So there's a back room that you've described
+that has a bed in it, and if that door's closed you don't
+know what's going on behind closed doors, right?
+A. That's correct.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. Do you remember a time Epstein was back in
+that back room with other people?
+MR. PIKE: Form.
+A. No.
+Q. Are you saying it never happened while you
+were on the airplane?
+A. I really have no idea of knowing because,
+one, we never go back there unless we're invited
+back.
+Q. Okay.
+A. And the forward door - the very forward
+salon door is closed, so we never even normally go
+into that --
+Q. So you don't really know --
+A. - without permission.
+Q. You don't really know what happens --
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ader Gallo Company
+October 6, 2009
+119
+A. No.
+Q. - in the back of the airplane.
+A. No.
+Q. So anything could go on. You would have no
+idea.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. You could sit here and testify truthfully,
+have no clue what's going on back there."
+A. That's correct. That's correct.
+Q. Darren Indyke - what's your understanding as
+to his involvement with Mr. Epstein?
+A. An attorney for the company.
+Q. Ever met Alan Dershowitz?
+A. I think - Yes.
+Q. How did you meet him?
+A. Alan Dershowitz. I don't know if it was
+Mr. Goldberger or Alan Dershowitz. We brought some
+attorneys down --
+Q.
+• Why?
+A. - to Florida one time.
+Q. Why?
+A. For Mr. Epstein. It was right before |
+finished flying. For Mr. Epstein to make an
+appearance at the courthouse or a meeting or
+120
+something, and we brought some attorneys with him.
+Q. And were you aware then of the allegations
+against Mr. Epstein?
+A. They were starting to brew, yes.
+Q. Were you still actively working on his payroll
+at the time when the investigation was going on?
+A. Yes, when it just started
+Q. And did that impact you in any way as to
+whether or not you wanted to be affiliated with this
+person?
+A. Subconsciously, it may have. And it
+wasn't because of this person, but as a business
+decision, if, you know, an airplane's not needed and
+I don't fly, I could be out of work. But, no, the
+primary reason was the fact that I did want to get
+off the road and back home.
+Q.
+Do you have children?
+A. Yes.
+Q. How old?
+A. A daughter 28, son 24, and a daughter 17 -
+all with the same bride - 31 years.
+Q. I'm assuming you're aware of the factual
+allegations in these complaints?
+A. Yes, yes.
+Q. And you are aware that there are hundreds of
+
+
+3
+5
+6
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+6
+8
+10
+11
+12
+13
+14
+15
+16
+17
+1B
+19
+20
+21
+22
+23
+24
+25
+121
+girls who are underage who claim to have had sex with Mr.
+Epstein as well as Ms. Maxwell at various times?
+MR. PIKE: Form.
+A. I was only aware of -- First time I was
+made aware of it, of the number of people, was when
+they served me the subpoena. The deputies or
+retired.
+Q. Yes.
+A. -- private eyes told me that. That was
+the first I had heard a number.
+Q. Were you completely oblivious that this was
+going on? And by "this" I mean Epstein and/or Ghislaine
+Maxwell and/or
+recruiting 12, 13, 14,
+15-year-old girls to his house for sex?
+A. Absolutely I was oblivious to it.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. If young girls were on an airplane that you
+were on - considering that we've now established how the
+airplane's set up and you're kind of cordoned off - is it
+possible that underage girls would have been on the
+airplane and you just wouldn't have known about it?
+MR. PIKE: Form.
+A. No, no. I mean, people don't board the
+airplane with - you know, and then just say, "Close
+122
+the door, we're going." You know, you see who boards
+the airplane.
+Q. So if there were flight records that show
+underage girls on the airplane, you would know about it?
+MR. PIKE: Form.
+A. Not necessarily.
+Q. Well, how not?
+MR. REINHART: I'm sorry.
+A. Well, how do you --
+Note to her you a ten do yoy
+mean he would know about the records or he would
+know about the girls allegedly on the plane?
+BY MR. EDWARDS:
+Q. You would know about the underage girls on the
+airplane if they were on there.
+MR. PIKE: Form.
+A. How do you -- How would I know that
+they're underage, though?
+Q. Well, you would only know that they look
+extremely young, right?
+A.
+But -
+MR. PIKE: Form.
+A.
+- what is the intent of them? I mean,
+are they guests or are they friends of his associates
+ОГ --
+1
+2
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+฿
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alesander Gallo Company
+October 6, 2009
+123
+Q. Okay. I ask it a different way.
+A.
+Because we have had -- You know, he's got
+a goddaughter and godson that were young, I mean.
+Q. Okay. Over the years --
+A. I mean, I don't know what the purpose --
+Q. Right. I totally understand what you're
+saying.
+Over the years, when you were on Jeffrey
+Epstein's airplane, were you aware between 2001 and
+wherever you stopped, 2007 --
+A. Seven.
+Q. - were you aware of girls that appeared very
+underage on the airplane?
+A. No.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. I'm not saying what was happening on the
+airplane. I'm just saying, were you aware of it?
+A. No, not - unless they were there, like I
+said, his goddaughter at the time. One time - a
+couple times we flew her with her mom and dad where I
+don't even know their age.
+MR. PIKE: Again, form, asked and
+answered.
+A. Six or seven. But, no, I was not aware of
+124
+anybody that was obviously, blatantly underage
+Q. Any famous people that you can tell me that
+were on the airplane?
+A. President Clinton - Ex-President Clinton.
+Q. Were you on the airplane --
+A. Yes.
+Q. - when he was on it?
+A.
+Yes.
+Q. How many times?
+A. Two trips. I mean, two extended trips.
+Q. Where did it go?
+A. The first one - or the first one was Asia.
+Q.
+What purpose?
+A. I forget what the purpose was on that one.
+Q. Was Jeffrey Epstein on the airplane as well?
+A. Yes, yes.
+Q. Who else was on the airplane then?
+A. I don't remember on that one. It was
+primarily him and his support staff.
+Q. Was
+A. Probably, yes, probably.
+Q. When's the next time President Clinton was on
+his airplane?
+A. I don't remember the date, but we did a
+Africa trip, an AIDS awareness tour. We did like ten
+
+
+1
+2
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+125
+countries in 12 days.
+Q. Is that a time Chris Tucker --
+A.
+Yes.
+Q. - and Kevin Spacey were also on it?
+A.
+Yes.
+Q. In addition to the people that we've named,
+were there females on that airplane?
+A. Yes.
+Q. And who were the females that were on the
+airplane?
+A. Can't remember. Ms. Maxwell,
+- I can
+remember, and a couple others, and there's - Mr.
+Clinton had - a couple of his support staff were
+women also.
+Q. Where were you sitting during these trips?
+A. Up front in the - my station.
+Q. Could you see what they were doing where you
+were?
+A. No, no.
+Q. Could you tell if there was any sex going on
+on the airplane while you were on it?
+A. No.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. Do you know of any underage girls being on
+126
+that airplane or would you have been able to tell?
+A. No.
+MR. REINHART: I'm sorry --
+MR. PIKE: Asked and answered.
+MR. REINHART: -- are you limiting it to
+that trip?
+BY MR. EDWARDS:
+Q. To that trip.
+A. No, I'm not aware of it.
+Q. If you had been aware of underage girls being
+transported on the airplane for the purposes of sex,
+would you have said something to somebody?
+A. Yes.
+MR. PIKE: Form.
+MR. EDWARDS: Do you mind if we take a
+five-minute break? I just have to run to the
+bathroom.
+MR. PIKE: Actually, Brad, can you hear
+me?
+MR. EDWARDS: Yes.
+MR. PIKE: How much longer do you
+anticipate going with this witness?
+MR. EDWARDS: Hour, maybe a little longer.
+MR. PIKE: Well, are you going to take a
+lunch break or what?
+1
+2
+3
+5
+7
+B
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+120
+21
+22
+23
+24
+25
+1
+2
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+a= Alexander Gallo Company
+October 6, 2009
+127
+MR. EDWARDS: No. I mean, unless
+everybody wants to take a lunch break.
+Everybody's shaking their heads, so, no, I'm
+going to take a bathroom break, and it's going
+to be a fast one.
+MA. PIKE: Okay.
+BY MR. EDWARDS:
+Q. In 2001, when you're on this flight to New
+York and then during that year we talked a little bit
+about it, is Larry Visoski and David Rodgers also on some
+of these flights?
+A. Most, yes.
+Q. If somebody's going to keep passenger logs,
+who's going to write down the names of the people? Is
+that going to be you or is that somebody else's
+responsibility?
+A. Whoever is captain.
+Q. So normally it's Visoski or David Rodgers?
+A. Correct.
+Q. Who do you turn these logs into?
+MR. PIKE: Form.
+A. I don't know. I don't know where they go.
+. You don't know the purpose behind keeping them
+or anything?
+A. No.
+128
+Q. As far as you're concerned, you don't even
+need to keep them.
+A. Correct. Yeah.
+Q. As just due diligence - going above and
+beyond?
+A. Correct.
+Q. Today you have an attomey sitting right next
+to you, right?
+A. Correct.
+Q. Is that somebody that you've known for a long
+time?
+A. No.
+Q. You're paying for an attorney to sit here with
+you?
+A. No.
+Q. Who's paying for your attorney?
+A. Mr. Epstein.
+Q. Are you worried that you're criminally
+involved here or something? Is that why you need an
+attorney?
+A. No. I don't even know anything about this
+process, that's --
+Q. Oh, okay.
+A. I'm just -- You know.
+Q. How did you know that you were --
+
+
+1
+2
+3
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+129
+MR. PIKE: Brad. Brad. Brad.
+Q.
+- going to get an attomey -
+MR. REINHART: Brad, hold on.
+MR. PIKE: Whoa. Whoa. Stop.
+MR. EDWARDS: I'm listening.
+MR. PIKE: Brad.
+MR. EDWARDS: Go.
+MR. PIKE: You are not allowing the
+witness to finish his statements throughout this
+entire depo. Please. I'm on the phone. You
+start your question before the witness is
+finished. I'm sorry for raising my voice, but
+you must allow the witness to finish his answer,
+please.
+MR. EDWARDS: You got it.
+THE WITNESS: What was your question now?
+I forgot.
+MR. EDWARDS: I'm sitting here looking at
+the witness and have a feeling we're going to be
+sitting here for 30 minutes, but I will do that
+for you, Mr. Pike.
+MR. PIKE: Alright.
+THE WITNESS: What was the question again,
+please?
+MR. EDWARDS: Can I ask the question again
+130
+2
+4
+6
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+or wait? I'll wait for you.
+MR. PIKE: If I'm ready.
+MR. EDWARDS: I already asked the
+question, so we're waiting.
+MR. REINHART: I think the witness asked
+you to repeat the question.
+MR. EDWARDS: Are you good? Alright.
+BY MR. EDWARDS:
+Q. Who hired your attomey?
+A. Mr. Epstein.
+Q. And do you have any idea why, if you're a
+witness in a case - no problems criminally - why you
+personally have an attorney paid for by Mr. Epstein to
+sit here with you?
+MR. PIKE: Form.
+A.
+No, I don't.
+Q. Do you want an attorney to sit here with you
+while I ask you questions?
+MR. PIKE: Form.
+A. I don't know what the proper protocol is.
+Q. Okay.
+A. I have very limited exposure to anything
+like this.
+Q. How did this come about to where you have an
+attorney as a witness - completely innocent witness - in
+1
+111
+12
+13
+14
+15
+16
+17
+18
+119
+20
+21
+/22
+23
+24
+25
+1
+2
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+October 6, 2009
+131
+this case against Mr. Epstein?
+MR. REINHART: Let me ask him not to
+answer that.
+MR. PIKE: Form.
+MR. REINHART: It's privileged.
+MR. EDWARDS: It's privileged between Mr.
+Epstein and you, but is it privileged between
+the two of you?
+MR. REINHART: Between Mr. Morrison and
+me.
+BY MR. EDWARDS:
+Q. Is it your understanding that he represents
+you or he represents Mr. Epstein?
+A. He represents me.
+Q. Okay. Do you think that you've done anything
+wrong criminally?
+A. No.
+Q. Do you think that you're being sued civilly?
+A. No.
+Q. And you have no reason to be sued civilly,
+right?
+A. Correct.
+Q. Did you talk to Mr. Epstein prior to taking
+your deposition today?
+A. Oh, no. I haven't talked to him in well
+132
+over a year-and-a-half, maybe two years, and that was
+just a "hello" because I'm at the airplane one day.
+Q.
+So how is it you know that Mr. Epstein paid
+for your attorney?
+MR. REINHART: It's privileged.
+MR. EDWARDS: Okay. That answers my
+question.
+BY MR. EDWARDS:
+Q. Have you ever met Donald Trump?
+• Yes.
+Q. How?
+A. He was -- He boarded the airplane one day
+when ours was on the ramp.
+Q. And did you talk to him?
+A. Just he introduced himself and I
+introduced myself.
+Q. And did he talk to Mr. Epstein?
+A. No. Mr. Epstein wasn't present. I was
+doing maintenance.
+Q. And did he fly on the plane?
+A. No.
+Q.
+Not that time?
+A.
+Never.
+Q. You think he never flew on the plane?
+A.
+On our airplane?
+an Alexander Galle Compasy
+
+
+2
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+3
+4
+5
+6
+110
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+133
+Q. Yes.
+A. No.
+Q. So if somebody has given testimony other than
+that, you would say that person is mistaken or lying?
+MR. PIKE: Form.
+A. Donald Trump was never on the airplane
+when I was on the airplane.
+Q. Is it your understanding that Donald Trump is
+friends with Mr. Epstein?
+A. From what I've read - or associates. I
+don't know how that circle works.
+Q. What's your understanding as to who Mr.
+Epstein's real friends are?
+A. I really don't know. I don't - I don't
+know. It's -- It's not like the Wexners where, you
+know, they were high school associates, you know,
+growing up.
+Q. Do you know what Mr. Epstein did prior to
+managing the money for Mr. Wexner?
+A. Just that he was a Wall Street broker or
+somebody, you know.
+Q. Also from reading?
+A. Yes, yes.
+Q. Do you know any personal knowledge as to what
+Mr. Epstein has told you about how he made money?
+134
+A. He's never -
+MA. PIKE: I'm going to move to strike any
+responses relative to what the witness has
+leamed from reading.
+BY MR. EDWARDS:
+Q. And so that is why I asked the question: Has
+Mr. Epstein told you? Which would have nothing to do
+with reading.
+A. No.
+Q. How many conversations have you personally had
+with Mr. Epstein?
+A. No personal conversations - all business.
+Q. Have you witnessed Mr. Epstein with any girls
+that look to be under the age of 187
+A. No.
+Q. Have you witnessed Mr. Epstein with
+young-looking girls that appear to be in their twenties?
+MR. PIKE: Form.
+A.
+Yes.
+Q. On how many occasions?
+A. Probably several.
+Q. And how did that come about?
+A. I mean, they show up and ride on the
+airplane, you know.
+Q. And who are they, if you know?
+an Alexander Gallo Cempany
+1
+2
+6
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+3
+4
+5
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+October 6, 2009
+135
+A. I have no idea. I don't know.
+Q. When you say that
+was just
+coming in the picture, what's your understanding as to
+who
+is relative to Mr. Epstein?
+A. I don't know. I don't understand. I
+don't know. I didn't know if maybe she was like an
+exchange - Jeffrey always appeared to be very
+involved in education and philanthropy. I didnt
+know if she was an exchange-type student or something
+or what. I don't know.
+Q. When you say he appeared to be "involved in,"
+what do you mean?
+A. Educational things, foundations, science
+foundations, and things.
+Q. Speaking of - the Florida Science Foundation
+is a place where, when he was on work release, he spent a
+lot of time there, you're aware of that?
+A. That's what I've heard, yeah.
+Q. What does that place do?
+A. I have no idea.
+Q. Does it do anything?
+A. I don't know. I don't know anything about
+it.
+Q. Certainly you've read certain newspaper
+articles about the allegations, police reports,
+136
+otherwise, the allegations that occurred or have been
+alleged to have occurred at his Palm Beach mansion,
+correct?
+A. Uh-huh.
+Q. Correct?
+A. Correct.
+Q. Given the nature of those allegations, would
+you leave your daughter of 17, 16, 15 years old with Mr.
+Epstein alone?
+MR. PIKE: Form. Move to strike.
+A.
+• Yes.
+Q. You would?
+A. (Witness nods head.)
+Q. And why?
+A. Because I don't fear that he would try
+anything with my daughter. He showed -- When I
+worked for him he showed me respect. He never - |
+never - He never showed me disrespect. He would ask
+how the family is. I mean, not on a personal level,
+but an employer/employee.
+Q. Right. Okay.
+A. He never showed me any reason not to trust
+him.
+Q. But you're not a 13-year old girl, so.
+A. No, but, like I say, he never showed me
+
+
+1
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+137
+any reason not to trust.
+Q. So maybe that's the reason why there were
+hundreds of victims, right?
+A. I don't know that there were.
+Q. So is it surprising to read the things that
+you read about what was going on at his house?
+A. Yes.
+MR. PIKE: Form. Move to strike.
+BY MR. EDWARDS:
+Q. I'm going to ask you about - I'm going to
+mark them all -- In fact, I'm going to show them to your
+attorney first because I'm going to mark them as a
+composite - just to save time.
+MR. REINHART: For the record, you've
+handed me a stack of passenger manifests?
+you want, doesn't matter to me, and we'll just
+mark them as a composite - go through each one
+MR. REINHART: If you're going to go
+through each one of them, I don't need to count
+them. You'll make a record on that.
+MR. EDWARDS: Fine. I'm going to mark
+these as Composite Exhibit 1, and we'll count
+138
+(Defendant's Composite 1 was marked for
+identification.)
+BY MR. EDWARDS:
+Q. The first one's dated 1/14/2004. Can you tell
+me what we're looking at there? Just remember, I'm about
+as familiar with that type of stuff as a three year old,
+so help me out.
+Passenger manifest just showing basically
+date, time off, time on, the trip number of the year,
+I guess it would be - that seems high for the year -
+but trip number - that must be for the total -
+destination or departure point - destination.
+Q. The trip number says, "311.' What does that
+mean?
+A.
+That must be - I don't know where they
+start that. That must have been total since he
+started the airplane. That's way too many for the
+year. Obviously it's already - it's January, so it
+must have been total flights.
+Q. Who's on that airplane?
+A. Nautical miles, statute miles, fuel
+bumed, poundage.
+and
+Q.
+A.
+Do you know
+I -- I think I know her. I think I would
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+120
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+119
+20
+21
+122
+23
+24
+25
+an Alesander Calls Company
+October 6, 2009
+139
+know her if I saw her.
+Q. What did she do?
+A. I don't know. I don't know.
+Q. Would it surprise you if she was in charge of
+scheduling for the minors to come over to the house to
+sexually gratify Mr. Epstein?
+MR. PIKE: Form.
+A. Yeah, that would surprise me, yes.
+Q. Okay. She didn't do that while you were on
+the airplane, right?
+A. No, no.
+Q. Was Mr. Epstein on the airplane?
+MR. PIKE: Form. When?
+A. Yes.
+Q. And if it happened, it happened at a portion
+of the airplane where you couldn't see it because you
+were partitioned off?
+A.
+• What happened?
+MR. REINHART: I'm sorry, can we just get
+a timeframe?
+MR. PIKE: Form.
+MR. REINHART: Are we talking about this
+flight?
+MR. EDWARDS: Yes, we're talking about
+that flight.
+140
+BY MR. EDWARDS:
+Q. If anything happened on the airplane, it would
+have been in a position where you couldn't see it anyway.
+A. That's correct.
+Q. Okay.
+A. That's correct.
+Q. So you're not saying it did happen or it
+didn't happen, you just couldn't see past a certain
+point.
+A. Correct, and I don't know what you're
+referring to as "it anyways.
+Q. "It" is whatever sexual involvement there was.
+A. Oh. Like you say, we can't see anything
+back there anyhow because the doors are closed.
+Q.
+Did Mr. Epstein instruct you as to whether or
+not to knock or just walk back there or never walk back
+there or what was the instruction?
+A. No. There was never actually a formal
+instruction. It's proper protocol for any of these
+gentlemen, or individuals that own these aircraft,
+that that's their private zone, that you don't come
+back unless you're needed, and then you can -- You
+know, but it's not forebode, it's just proper.
+Q.
+You mentioned President Clinton on the plane.
+How many girls were on the plane at the same time when
+
+
+1
+2
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+N H
+3
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+141
+President Clinton was on the plane?
+MR. REINHART: Asked and answered.
+A. Yeah, I don't remember for sure. There
+was probably maybe five, if that, and that's --
+Q. What were they -
+A. What?
+Q. Go ahead.
+A. Like I say, it was Ms. Maxwell,
+maybe two others, one other, and then I think Mr.
+Clinton had two ladies in his entourage - support
+staff.
+Q. What age group are we talking about with the
+ladies that were on the airplane?
+MR. PIKE: Form.
+A. Mid-twenties to forties, maybe. I mean, I
+don't know exactly.
+Q. I mean, you know what a 13 or 14-year-old girl
+looks like --
+A. Yes.
+Q. - right?
+A. Yes.
+Q. Most people do.
+A. Yes.
+Q. You wouldn't mistake a 13 or 14 or 15 year old
+for a 20 year old.
+142
+A. No, no.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. So you're sure that the people that were on
+the airplane - they were above the age of 18?
+A. I believe so.
+Q. Because you, in your experience, as well as
+the experience of most people your age, would know -
+A.
+Right.
+Q. - what a 14 or 15 year old looks like.
+A. Right.
+Q. I'm going to go through the next flight log.
+You tell me what we're looking at here. Who's on the
+airplane?
+A. That was a deadhead. Nobody's on it.
+Q. Why were the names crossed out?
+A. Because there was no passengers. This was
+- origin was West Palm Beach - West Palm Beach. What
+date is this? 1/20/04? It was probably a test
+flight.
+Q.
+Okay.
+A.
+It was a training flight --
+Q.
+Okay.
+A. - for Bill.
+Q.
+The next one - Well, before I ask this: Were
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alesander Gallo Company
+October 6, 2009
+143
+you familiar with a flight where Prince Andrew was on the
+airplane?
+A. I don't know if I remember him being on
+the airplane or not. I know that he has been on the
+airplane or one of the airplanes. I can't say for
+sure.
+Q. Have you met him before?
+A. I can't remember, honestly. I know.
+Q. Can't remember meeting Prince Andrew?
+A. I know. I know. I didn't even know who
+he was when I first heard the name, sorry. But, no,
+I can't remember for sure, I'm sorry.
+Q. That's like if E.T. walked on the airplane and
+I don't know.
+A. I know. Well--
+Q. Alright. I'll let you slide on that one. You
+know who Prince Andrew is now.
+A. Okay. Don't paint me as stupid. One of
+Lady Di's sons, right?
+Q. I mean, you know what he looks like now.
+A. You know, honestly, I don't know if l
+could point him out to you, I'm sorry.
+Q. Alright.
+A. It's just--
+Q. We'll forget him.
+144
+A. I'm smart in some things.
+Q. We'll forget him. We'll forget him. Don't
+worry about it.
+What's this? What are we looking at?
+MR. REINHART: For the record, you handed
+him a manifest dated January 17, 2005; is that
+correct?
+THE WITNESS: January - Yes. Correct.
+Palm Beach to Kennedy, same thing, fuel
+burns, loads, destination, time off, time on.
+Next, it was trip 312. Jeffrey is on it,
+David Mullen,
+Todd Myster (sic),
+and passenger, passenger.
+BY MR. EDWARDS:
+Q. Do you know Todd Meister?
+A. He's a friend of his, I believe.
+Q. Father's Bob Meister? Do you know the names?
+A. No, I don't know that.
+Q.
+How do you know Todd Meister?
+A. I've just heard the name.
+Q. From who?
+A. Larry Visoski.
+Q. Larry Visoski knows these people?
+A. I think Todd Meister has an airplane, or
+something like that. He's talked to their flight
+
+
+1
+2
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+5
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+145
+Q.
+For the most part, when you mention these
+people's names, you mention them as if they're just
+passengers on the airplane and this is their world -
+you're passing through, you don't know them.
+A. Right.
+Q. But Visoski - would you say that he has a
+closer relationship with Epstein to where he might know
+some of these people?
+MR. PIKE: Form.
+A. That could be an accurate - yeah. I mean,
+he's been with Jeffrey longer. I mean --
+Q.
+I mean, do you know that Visoski has a car
+that is registered in Jeffrey Epstein's name? You dont
+have anything like that, do you?
+A. No, I did not.
+Q. Were you aware of that?
+A. No.
+Q. Does Mr. Visoski tell you how far he goes back
+with Jeffrey Epstein?
+A. No, just, I mean, when he hired him,
+whenever that was after Glimcher - that's all I know.
+Q. Do you know anything about Visoski's private
+life?
+A. A little bit. He's married and -
+146
+daughters. I mean --
+Q. Then I won't go into the rest of his private
+life.
+When it says, "1 pay, 1 pay," what does that
+mean?
+A.
+It's "PAX." P-A-X is short for
+"passenger." It's a brief.
+Q. Okay. Look, this is somebody that is listing
+names of people on an airplane. They're going out of
+their way -
+A. Right.
+Q. - and then all of a sudden on No. 8 and 9
+they say, "one passenger." Is this person just getting
+lazy or is there a reason why there's no name?
+A. Like I say, just getting lazy and then
+didn't know who the passenger was.
+Q. Well, they obviously didn't know who Todd
+Meister was either - they wrote his name all wrong.
+A. They did?
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. Well, "Meister" is not spelled like that, so
+how did -
+A.
+I didn't -- I didn't know that. I don't
+know how he -- How does he spell it?
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+5
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Galle Company
+October 6, 2009
+147
+Q. Well, do you know whose handwriting that is?
+A. No, no, I don't. It may be Larry's.
+Q. Similar handwriting -
+A. Wait a minute.
+Q. - as those --
+A. Let's see the one with the training -
+because there's a different pilot on there.
+Q. Right. One where there is nobody on it,
+right?
+A. This is Bill's - I can't - This is
+Bill's writing. I think he was having him fill out
+the paperwork.
+Q. Bill Hammond?
+A. Yeah, this was his training flight.
+Q. The first one is Visoski?
+A. Maybe. I can't say for sure. I really
+can't say for sure.
+Q. And this is?
+A. I don't know if that's the same
+handwriting or not.
+Q. Well, is there any indication up here that
+would tell us whose handwriting it is? David Rodgers and
+Larry Visoski --
+A. No, because this is --
+Q. - are the pilots.
+148
+A. Yeah, but they don't indicate - they don't
+indicate who's captain that day. You know, I'm not a
+handwriting expert. I can't really - Honestly, I
+can't tell you for sure whose handwriting it was.
+Q.
+Let's keep this one out, and tell me if this
+is - I'm going to hand you January 19, 2005 --
+MR. REINHART: January 17.
+MR. EDWARDS: 2005?
+MR. REINHART: Yes.
+BY MR. EDWARDS:
+Q.
+- January 17, 2005, so two days later - where
+is this airplane going?
+A. From Kennedy to Palm Beach.
+Q. And so this is Palm Beach to Kennedy -
+A. Yep.
+Q. - in this exhibit. The next one is Kennedy
+to Palm Beach.
+Correct.
+Q. They come back. Where do they stay - do you
+know?
+A. What do you mean?
+Q.
+Well, they get off on the 17th, they stay
+somewhere until they come back on the 19th. Do you know
+where they stay?
+MR. REINHART: Can we clarify who "they"
+
+
+1
+2
+5
+7
+9
+10
+11
+12
+13
+114
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+5
+7
+8
+9
+10
+11
+12
+13
+14
+18
+19
+20
+21
+22
+23
+24
+25
+149
+is?
+BY MR. EDWARDS:
+Q. I guess it is: David Mullen,
+, Tod Myster (sic), 1 pax, another pax,
+and Jeffrey Epstein - and there's a crossed
+out "Ghislaine Maxwell," so I'm assuming she didn't go.
+A.
+Correct.
+I have no idea where they stayed.!
+assume Jeffrey would stay in his home.
+would
+stay in her apartment. As for all the others, I have
+no idea.
+Q. Have you ever been to Jeffrey Epstein's home
+in New York?
+A. Just in the lower level of the entryway.
+Q. Why did you go?
+A. To pick up bags for the trip to go to the
+airport and load them.
+Q. Was there anybody else there with him?
+A. I don't know with him. I never saw him
+him. We saw the guy that ran the house.
+Q. Who's that - Joe-Joe?
+A. Joe-Joe would be there --
+Q. What's Joe-Joe's name?
+A. Joe-Joe, that's all I know, and then
+there's the actual house manager. Joe-Joe is more of
+150
+a driver, and then there's the house manager - l
+forget his name.
+But, yeah, we would meet -- There's an
+office in the lower level that the bags would be at,
+and we would put them in the back of the van, haul
+them to the airport.
+Q. Who's David Mullen?
+A. I don't know. I heard of it. It sounds
+familiar. I can't remember who he is.
+Q. Somebody that lives in New York, Palm Beach?
+A. I dont know. I don't know.
+I'm trying to keep them in order.
+So coming back - you know, it looks like they
+take to JFK: David Mullen, Tod Myster (sic), some
+passengers unnamed - they come back with only
+Land
+- any idea why?
+MR. PIKE: Form.
+A.
+No, but, I mean, it's not unusual for
+these guys to, you know, take somebody - let somebody
+have a free ride to New York if they know them, they
+are acquaintances, need a lift, I mean, that's not
+unusual.
+Q. How's that come about - do you know?
+A. No, I don't - phone conversations,
+cocktail parties. I don't know.
+1
+2
+4
+5
+9
+10
+111
+12
+13
+14
+15
+16
+17
+118
+19
+20
+21
+22
+23
+24
+125
+1
+2
+4
+5
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Gallo Company
+October 6, 2009
+151
+Q. The next one is January 27, 2005, Palm Beach
+to where?
+A. St. Thomas.
+Q. To St. Thomas.
+A. Right.
+Q. And he has
+and
+and Jeffrey.
+A. Right.
+Q. Does he tell you what happens in St. Thomas?
+What he does there?
+A. No, no.
+Q. Ever heard that he imports underage girls from
+Brazil to his --
+MR. PIKE: Form.
+Q. - island in St. Thomas?
+MR. PIKE: Form.
+A. No, no, never heard that.
+Q. What does he tell you about his island in St.
+Thomas?
+A. Not a lot. I mean, he would sometimes
+talk about construction stuff or I would hear him -
+overhear him and Larry talk about the helicopter pad
+that they're putting in, little stuff like that - all
+construction.
+Q. Did he tell you two or three times a day, that
+he sexually abuses girls between 12 and 15 years old?
+152
+A. No.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. Not something he ever mentions.
+A. No, no.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. The next - 2/3/05 - who's on the passenger
+list?
+A. Jeffrey,
+Jean Luc, David
+Mullen, female, female, female.
+Q.
+Any idea why they would list "female, female,
+female," without listing the names?
+No, just the same as -- The only idea I
+would have would be the same reasoning for the -
+previously when they listed them as just "PAX' - that
+they didn't have any idea who they were, what their
+name was.
+Q. I mean, certainly that's --
+A. I don't know whose handwriting that is.
+Q. You're guessing, though, right?
+A. Yeah. No, I'm guessing. I have no idea.
+Q. Another guess would be they're 12 years old
+and you can't put them on it.
+MR. PIKE: Form.
+
+
+1
+5
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+3
+4
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+153
+A. I wouldn't say that. I don't know that.
+Q. Have you ever been on an airplane where you
+looked at this and you thought, "Hey, that's kind of
+strange that they wouldn't list them by name. They're
+talking about it generically: Female, female, female"?
+A. But they also --
+MR. PIKE: Form.
+A. - on another one: PAX, PAX, PAX.
+Q. You never thought that was odd either?
+A. No. I never actually even really paid
+attention to this paperwork. I don't see this.
+MS. EZELL: Brad, excuse me - this is
+Kathy Ezell - is there a date on that manifest
+you're showing?
+MR. EDWARDS: It's 2/3/05.
+MS. EZELL: Thanks.
+MR. EDWARDS: Is that your 12-year old
+client listed as No. 6?
+MR. PIKE: Form. Move to strike.
+MS. EZELL: No, but -
+MR. EDWARDS: Okay, sorry, somebody
+else's.
+MS. EZELL: Okay. Thanks.
+BY MR. EDWARDS:
+Q. 2/7/05 - who's on there?
+154
+A.
+Jeffrey.
+David Mullen,
+Jansen,
+Q. Do you know who
+is?
+A.
+No.
+Q. David Mullen travels a lot. Do you have any
+idea what his relationship is with Mr. Epstein?
+A. I don't even know who David Mullen really
+is.
+Q. Have you ever seen him?
+A. I might be able to place him if I saw a
+picture of him.
+Q. I mean, obviously you're on the airplane with
+him a lot.
+A.
+Yeah, so, I mean, obviously I would
+recognize him if I saw a picture.
+Q. Do you know if he travels with anybody else on
+this?
+A. Unless it's that one name I don't
+recognize - that Jansen, or whatever.
+Q.
+But Jansen's not somebody you know?
+A. No, no.
+Q. I can't read that date - maybe you can. I got
+a bad tax copy.
+A. Maybe 2 - 2/10.
+That's Michael Pike not wanting me to know
+1
+2
+3
+4
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Galle Company
+October 6, 2009
+155
+what it says.
+A. It's - I think it's a 2 - 2/10.
+Q. Alright. Can you tell us who's on that
+airplane?
+A.
+Jeffrey, looks like
+- is that
+Jean Luc?
+Q. Yeah.
+A.
+That's Jean Luc, I think, and
+(SiC)-
+Q.
+Jean Luc is another one who travels quite
+frequently. Why, if you know, does he travel quite
+frequently on these airplanes to and from New York with
+Jeffrey Epstein - any idea?
+A. My only assumption was business, and
+that's just an assumption.
+Q. What kind of business do you know of that they
+have in common?
+A. I was under the impression a modeling
+business.
+Q. Other than the modeling agency, what other
+business do they engage in together, if you know?
+A. I don't know.
+Q. And has Jeffrey Epstein ever talked to you -
+or loud enough to which you could hear him discussing the
+modeling agency?
+156
+MR. PIKE: Form.
+A. No, just that the only conversation he
+ever - I remember - was the one that he - the one
+about the girl opening the wrong door on the motor
+home.
+Q. Was he happy or sad about the modeling agency?
+A. No, he was happy she wasn't injured, but
+he was kind of making light of what a silly thing to
+do, you know.
+Q. Do you know if Jean Luc is the one procuring
+the models or is Jeffrey procuring the models?
+A. I don't know.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. You never investigated into how this modeling
+agency is doing or anything else?
+A. No, no interest.
+Q. You try to stay completely out of it?
+A. No interest.
+Q. Especially in light of the recent things
+you've read.
+A. I mean, I didn't have any interest in it
+before all the recent things.
+Q.
+I'm going to skip this one because it talks
+about very similar people that you've already read.
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+5
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+125
+157
+A. Okay.
+Q. No different names.
+MR. REINHART: Can we just get the date on
+the record?
+BY MR. EDWARDS:
+Q. Well, actually, we don't have to skip it.
+2/15/05 - that's the date, right?
+A. Right.
+Q. And it says: Ghislaine Maxwell --
+A. Okay.
+Q.
+and
+(Sic); is that right?
+A.
+That's what it says.
+Q. Is that a typical crew that you would see on
+the plane?
+A. What year is this? In '05?
+Q. Yes.
+A. Yes, but towards the end there, I think
+the last year, I only saw Ms. Maxwell once.
+Q. Do you know of any falling out of sorts that
+Ghislaine Maxwell and Epstein had?
+A. Well, no.
+I think they still - I think
+she still has a lot of association, or whatever.
+Q. Do you think they are still a couple?
+A. I dont know that they ever were. I never
+158
+did figure out the relationship, other than I assumed
+they were a couple and she was a business assistant -
+associate, but that was all assumption.
+Q. Did you ever know of Jeffrey Epstein to have a
+girlfriend, per se?
+A. If it would have been, it would have been
+Ms. Maxwell.
+Q. Other than Ms. Maxwell, could you identify any
+other temale that appeared to be in a intimate
+relationship with Jeffrey Epstein?
+A.
+Not really, not that I - not that I could
+say it was a relationship, no.
+Q. I'm going to show you another one. I don't
+know these people. Tell me who they are. It looks like
+you're on the airplane --
+MR. REINHART: Can we get a --
+Q. - and the date is 2/21/05
+A. Right.
+Q. Which is ten days after the previous. It's
+going --
+A. I don't know who the Stanleys are.
+Q. And it's going from the island.
+A. To --
+Q.
+Palm Beach.
+A. - Palm Beach. I don't know who the
+October 6, 2009
+1
+2
+3
+4
+5
+6
+7
+8
+9
+110
+11
+/12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alessader Gallo Company
+159
+Stanleys are.
+Q. Ever heard of them?
+A. No.
+Q. As far as you're concerned, they're some
+islanders or something, right? I mean --
+A. Well, they might be -- I mean --
+MR. PIKE: Form.
+A. - there's a lot of wealthy people down
+there. They might have been friends or associates
+that needed a lift back stateside.
+Q. Fair enough.
+What's the next one?
+A. Teterboro to PBI.
+Q. And who's on it?
+A. Jeffrey,
+_ and
+MR. REINHART: Can we get a date for the
+record?
+THE WITNESS: 2/24.
+BY MR. EDWARDS:
+Q. It seems like
+and
+travel a lot
+with Jeffrey. Is it ever your understanding that Jeffrey
+Epstein had a sexual relationship with either of them?
+A. That is not my understanding, no.
+Q. Do you know of
+having a boyfriend
+ever?
+160
+A. I heard that she has a boyfriend.
+Q. And what's his name?
+A. And this is just hearsay. I don't know.
+Q. I'm interested in hearsay.
+A. I heard that she's dating somebody -
+that's all.
+Q. Dating whom?
+A. A guy -- Somebody by the name of
+Q
+A. I don't know his last name.
+Q. How long has she been dating him?
+A. I don't know. This is just Larry, you
+know, every once in a while asks, you know, "What's
+going on?" "Who's" -- You know, I don't know.
+Q. Where does
+live?
+A. I think he's down here. I think he's one
+of Mr. Epstein's legal team or something or --
+Q. And
+is somebody who you heard of through
+Larry Visoski?
+A. Yes, yes.
+Q. And specifically what did Larry Visoski say
+about
+A.
+He thought that they were dating - he and
+- and this is all hearsay.
+Q.
+Since when?
+
+
+1
+3
+4
+5
+8
+9
+10
+11
+12
+13
+14
+15
+16
+18
+19
+20
+21
+22
+23
+24
+25
+1
+7
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+161
+A. This is all - I don't remember. Some
+time within - maybe within the year. I don't know.
+I don't know.
+Q. So it's your understanding then that if
+is in West Palm Beach or in the area, and he is dating
+somebody named
+" that it would also be a
+fair presumption that
+would be somewhere
+nearby as well.
+MR. PIKE: Form.
+A. I mean, that's not necessarily so. I
+mean, in this day and age when you can get back and
+forth to New York via airlines, or anywhere; I mean,
+at times, yes, that would be a fair assumption, but
+not continuously.
+Q. And what was the context in which the
+conversation came up where Larry Visoski says,
+- who you have very little knowledge, I mean, I
+don't want to say "very little knowledge" - you obviously
+have seen her several times -
+A.
+Yes.
+Q.
+is dating this person and his
+name is
+Obviously that's a strange name, so
+that's something you would probably remember.
+A. Right, right.
+Q. Otherwise, how would that come about?
+162
+A. I don't remember how it came about,
+actually. I think I just - several months ago |
+asked what people were doing since, you know, there's
+been a lot of changes in staff since the boss was,
+you know, detained. There's been a lot of layoffs
+and stuff. The conversation was he was updating me
+as to who's still around, who's been laid off, you
+know, who's not with the company anymore, who's not
+with, you know, at certain houses.
+Q. When you say "the boss" has been "detained,"
+the boss obviously is Jeffrey Epstein?
+Q. And you're having a conversation then with
+Larry Visoski about the changes that necessarily are
+made -
+A. Right.
+Q. - because the boss is -
+A. Well -
+Q.
+- either incarcerated or under house arrest,
+or whatever.
+A. And the economy and everything, I mean.
+Q. In the course of that he tells you something
+about, "Well,
+is dating
+A.
+Yeah, or - I think he said something about
+one of Jeffrey - the paralegal or something, the
+October 6, 2009
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+|12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Galle Company
+163
+attorney.
+Q. And what else does he tell you? I mean, there
+are other changes other than, "Hey,
+dating
+A.
+A couple of the - couple of long time
+people at the ranch were laid off.
+Q.
+Such as who?
+A. Oh, God - Mike and
+Q. Mike and
+A. Yeah.
+Q. And those are people that run the Zorro
+Ranch --
+A. They don't run it.
+Q. - in New Mexico?
+A. They work there, yeah. And other changes
+to the island. You know, I can't remember all the
+names. I believe Adam, who was the chef, at the
+island left.
+MR. PIKE: Hello?
+BY MR. EDWARDS:
+Q. Adam's the chef at the island?
+A. Yes.
+Q. And why did he leave?
+A. I don't -
+Q. Epstein's not around to cook for?
+164
+A. Yeah. It may have been a layoff kind of
+thing - and the economy too. I mean, everybody's
+affected.
+Q.
+What's your understanding about Mike and
+A.
+Just that they were laid off. I don't
+know the exact reasoning that they were laid off.
+Q.
+And before we go back to this: Have you ever
+been to that Zorro Ranch --
+A. Yes.
+Q. - in New Mexico?
+A. Yes.
+Q. How many times?
+A. Several.
+Q. Why?
+A. Because when we take them out there it was
+too far to airline home, so we'd stay - stay at the
+ranch.
+Q. And what was he there to do?
+A. I have no idea.
+Q. Well, you were at the ranch, right?
+A. Yeah, but it's a big complex. There's --
+The main house is literally probably 3 or 4 miles
+from where we stay.
+Q
+Was
+there also?
+Suite 1300
+515 East Las Olas Boulevard
+Fort Lauderdale, FL 33301
+
+
+1
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+3
+5
+7
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+165
+A.
+I'm sure at times, yes, yes.
+Q. Well, I mean, usually he goes with his --
+A. The normal -
+Q. - his
+his Ghislaine.
+A. Yeah, his normal entourage, or whatever it
+is.
+Q.
+And was somebody there to schedule his people
+to come over and see him on a daily basis?
+A. I dont know. I don't know how that
+worked.
+Q. He's --
+A. Like i say, he's up at the main house.
+Once we were at the ranch there's really no contact.
+Q. Yeah, but I'm familiar with where this ranch
+is, and it's kind of in the middle of nowhere, right?
+A. Yeah.
+Q. And, you know, so when people come to or from
+the ranch, I mean, you can't help but almost be familiar
+that somebody's coming, right?
+A. Well --
+MR. PIKE: Form.
+A. - I mean, you would see a car drive by or
+something or a truck. There's always a lot of
+activity, construction, and everything else going on.
+Where we stayed at Ranch Central, the
+166
+small, little - basically like little hotel rooms
+where we stayed, you know, it was on a busy road
+because there was always like a lot of construction
+stuff and the ranch hands and everything up and down.
+Q. Did you see girls going to visit him there?
+A. Yes.
+Q. How often would girls go to visit him there?
+A. I don't know.
+Q. Did these --
+A. Not that often.
+Q. Did these seem like girls local to New Mexico
+or had they just flown in on an airplane, landed a
+helicopter on the property?
+A.
+Oh, I don't know. I never -
+MR. PIKE: Form.
+A. I never saw them up close. I mean --
+Q.
+Did they come in taxicabs?
+MR. PIKE: Form.
+A. I can't remember that - don't think so.
+Q. You don't ever think a girl came in a taxicab
+to the New Mexico ranch?
+A. I don't ever remember seeing a taxicab on
+the ranch.
+Q. Do you remember seeing girls two or three
+times a day going to visit him while he was at the New
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+8
+110
+11
+12
+13
+14
+15
+16
+17
+118
+19
+20
+121
+22
+23
+24
+25
+an Alesander Galle Company
+October 6, 2009
+167
+Mexico ranch?
+A. Oh, no, no.
+Q. You don't remember that?
+A. No.
+Q. Could it have happened?
+A. It could have.
+But you just don't remember seeing that.
+A. No, I don't ever remember seeing that.
+Q. Have you ever met Governor Bill Richardson?
+A. I saw him. He was --
+Q. How did you see him?
+A. He was at Ranch Central. He had been
+invited for dinner, or something, at the main house
+and they were coming down to get him.
+Q. He was invited to the Zorro Ranch. I call it
+that because that's apparently what Mr. Epstein's named
+it, right?
+A. Yes.
+Q. So Bill Richardson came to the Zorro Ranch for
+what?
+A. I -- It was a dinner meeting or something,
+I don't know.
+Q. Do --
+A. I think Mr. Richardson used to own the
+property the ranch was built on, or something.!
+168
+don't know.
+Q. Did you stay for the dinner?
+A. Oh, no, no. I was down at Ranch Central
+and he was just there while they were going to escort
+him up to the main house.
+O. So Bill Richardson was where Epstein was where
+the dinner was.
+A. Yes, yes.
+Q. And you were not there.
+A. Of course not.
+Q. Who else besides Bill Richardson was there?
+A. I have no idea.
+Q. Any knowledge of Bill Richardson being
+involved with any of the girls that would have been
+brought to the house?
+A.
+Oh, no, no, not that I have.
+Q. Not that I know of.
+A. Not that I know, no.
+Q.
+Because you were in such a place that you
+never would have known anyway, right?
+A. That's correct, yeah.
+Q. What's your understanding as to Bill
+Richardson's connection to Mr. Epstein?
+A. I thought he was always just kind of
+politics. I believe - I heard at one time, I don't
+www.esqulresolutions.com
+
+
+2
+3
+4
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+4
+6
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+169
+know for a fact - I thought that part of the property
+the Zorro was built on was owned by Bill Richardson.
+He sold it to Jeffrey.
+Q.
+Ever known Bill Richardson to be on Epstein's
+airplane?
+A. No, not the Boeing.
+Q. Any plane.
+A. I don't know that.
+Q. Was he ever on a plane that you were on?
+A. No, not that I remember, not that I
+remember. I remember -- I believe the only time I
+met him was one time at Ranch Central.
+Q. Ever hear of a trust - Zorro Trust?
+A. No.
+Q. Are you familiar with some of Epstein's
+companies?
+MR. PIKE: Form.
+A. No. I mean, other than JEGE and Hyperion
+and Air Ghislaine.
+Q. What's Air Ghislaine?
+A. That's the helicopters - that's what
+they're under.
+Q. He named it after Ghislaine Maxwell?
+A. Apparently so. I would assume so.
+Q. Well, I mean, I'm not trying to be difficult
+170
+with you.
+A. No, I wouldn't --
+Q. I'm assuming you're not trying with me either.
+A. No. I would assume so. I mean, that's an
+unusual name.
+Q. Do you know Prince Andrew to be friends with
+Jeffrey Epstein?
+MR. PIKE: Form.
+A. No, I don't know that - I don't know what
+the tie is. Like I say. I didn't know even know who
+Prince Andrew is when I first heard of it. I would
+have thought it would have been more of a tie with
+Ms. Maxwell.
+Q. Right. Do you know of Ms. Maxwell bringing
+the two, that being Prince Andrew, together with Mr.
+Epstein?
+MR. PIKE: Form.
+A. That could be, yes, yep.
+Q. And at the time when Bill Richardson had this
+meeting at Epstein's house, do you remember Ghislaine
+Maxwell also being there?
+A. Can't say for sure.
+Can't say for sure.
+Q. Have you heard of Jeffrey Epstein winning the
+lottery in New Mexico?
+A.
+No.
+3
+4
+5
+10
+11
+/12
+113
+14
+15
+16
+17
+18
+19
+/20
+21
+22
+23
+24
+25
+1
+2
+3.
+4
+5
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+der Galle Compaay
+October 6, 2009
+171
+Q. You've never heard that?
+A. No, no.
+O. Have you ever been privy to any conversations
+between Bill Richardson and Jeff Epstein?
+A. No.
+Q. So you don't know what they were really
+talking about.
+A. No. No idea.
+Q. At the time when Bill Richardson was running
+for president - is that around the time when you remember
+him being at Zorro Ranch?
+A. Before, before. What year did he run for
+president?
+Q. 2007.
+A. It had to have been well before because!
+quit flying in February of '07, so.
+Q. Epstein ever tell you what his relationship is
+with Bill Richardson?
+A. No.
+Q. When you were at the ranch, did you ever
+notice underage girls at the ranch?
+A. No.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. Anybody ever told you that that ranch is used
+172
+to transport girls through Mexico to the ranch?
+A. No.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. The next exhibit that I'm going to show you -
+which is all part of Composite Exhibit 1 - is a flight
+log 2/24/05; is that right?
+A. Yes.
+O. Who's on that? Nobody. That's a test flight?
+A. That's a test flight round robin. It's
+only 17 minutes.
+Q. 3/1/05.
+A.
+3/1/05 is PBl to Kennedy with Jeffrey.
+and
+Q.
+Do you know what his relationship is with
+A.
+No.
+Q.
+Do you know what she does for him?
+A. No, only - Isn't that the one that you
+told me - you just mentioned earlier? I have no idea
+what her relationship is.
+Q.
+Has he ever told you what any of his employees
+actually do for him - why he employs so many people to do
+so many different things - has he told you that?
+MR. PIKE: Form.
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+173
+A. No, no. I mean, you know, who runs each
+house and who the driver is, stuff like that. No, he
+would never mention that.
+Q. Has he ever told you what running a house
+entails?
+A. No, no.
+Q. Has he ever told you that there's an extra
+part of running the house that ensures that underage
+girls are going to be there for him every day?
+A. No.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. That's not something you ever heard.
+A. No.
+Q. 3/4/2005 flight log - who's on it?
+A.
+Jeffrey, Ghislaine Maxwell, David Mullen,
+David Mullen - once again, we don't know who
+this guy is, do you?
+A. And I don't know. Honestly, I can't -
+Q. Do you know where he lives?
+Q. Did you ever go visit Jeffrey Epstein while he
+was in jail?
+A. No.
+174
+1
+2
+3
+4
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Q. Why not?
+A. There was no purpose to it. There was no
+need to.
+Q. He's your boss for a long time, right?
+A.
+Yeah.
+Q.
+Was he good to you?
+A.
+Yes.
+Q.
+Did you support him?
+Yes.
+Q. You supported him while he was in jail?
+A. I was -- Yes, I mean.
+Q. Did the allegations bother you?
+A.
+Yes.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q. Somebody that you still support despite the
+allegations?
+MR. PIKE: Form.
+A. Yes, yes.
+Q. You realize that he did plead guilty to the
+offenses as well, right?
+A. That's what I read.
+MR. PIKE: Form. Move to strike. That's
+not the facts.
+BY MR. EDWARDS:
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+112
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+4
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Gallo Company
+October 6, 2009
+175
+Q. And despite pleading guilty to procuring
+underage girls for the purposes of sex, you still feel
+comfortable leaving a 13, 14, 15-year-old girl around
+him?
+MR. PIKE: Form. Move to strike.
+A. Yes. I mean, with my daughter, yes. I
+don't know how he behaves around anybody else. I
+just know that the respect that he showed me, I feel
+safe with my daughter.
+Q. And have you read in detail the reports as to
+what happened at his house with the girls?
+A. Only -
+MR. PIKE: Form.
+A. - what's been in the newspapers and
+published.
+Q. If you read and hear testimony given - well, I
+can tell you now - testimony has been given in this case
+that what happens is: A 13 or 14 year old is led
+upstairs by herself, told to get naked, he lays down on
+his back, there is a brief massage before he tums over,
+exposes himself erect, masturbates while he tells this 13
+or 14 year old to pinch his nipples as hard as she can
+while he inserts his fingers into their vagina and
+ejaculates all over them before saying, "Take your money
+and leave."
+176
+MR. PIKE: Form. Move to strike.
+BY MR. EDWARDS:
+Q. Okay? Then, "You can continue to come back
+for $200 every time or every girl you bring me within
+your age group and I get to do this again, I pay you $200
+per person." If that is the testimony -
+MR. PIKE: Form.
+Q. that what happens behind closed doors with
+him, do you still feel comfortable leaving a 13 or 14
+year old in a room with Jeffrey Epstein?
+MR. PIKE: Form.
+A. If that, in fact, is what actually
+happened, no.
+Q. I'll show you the next flight log is 3/8/05.
+Here, just so these are in order, 11I - 3/8/05.
+A. Okay.
+Q. Who's on that airplane?
+A.
+- Jeffrey,
+and
+Q.
+Seem to be people that ne travels with
+frequently.
+A. Yes, normal - his normal entourage.
+Q. Have you read recently the agreement that was
+entitled the "Non-Prosecution Agreement"?
+A. No. All I read was what was in the paper.
+Q. The "Non-Prosecution Agreement' was an
+
+
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+3
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+177
+agreement between Epstein and the government where the
+government agreed, We're not going to prosecute you for
+only the sex crimes we know about," and in that they also
+agree not to prosecute Jeffrey Epstein,
+A. Okay.
+Q. - as his co-conspirators.
+Do you know any of the acts that
+ОГ
+have done in an attempt to get Jeffrey Epstein
+young girls to molest?
+Only what I've read in the paper.
+MR. PIKE: Move to strike.
+BY MR. EDWARDS:
+Q. Again, Jeffrey Epstein, Ghislaine Maxwell, and
+who's that?
+MR. REINHART: Can we get a date, please?
+BY MR. EDWARDS:
+Q. Sorry, the date is 3/18/05. On this flight
+log, who are the names?
+A.
+Ghislaine - Jeffrey. Ghislaine Maxwell,
+and
+Q.
+Do you know Ghislaine Maxwell on a social
+level or only from him?
+A. No, just professional.
+Q. Do you know whether she is straight or
+178
+bisexual? Do you know of any of her girlfriends?
+A. I do not know that.
+Q. Are you aware that Ghislaine Maxwell, in sworn
+testimony and in complaints, has been alleged to have
+used vibrators, dildos, and have sex with these underage
+girls as well?
+A. I don't -
+MR. PIKE: Form.
+A. I was not aware of that.
+Q
+Do you know who
+is?
+A.
+Q.
+A. I belive so, yeah, because
+an
+unusual name.
+Q. Do you know if
+is underage or if she is
+of age at the time that this happened - at the time they
+list her name?
+A. Oh, I don't know for sure, but, I mean,
+she - when I - If it is the
+I remember,
+she was older. I mean, I can't even guess her age,
+mid-twenties, late twenties, I mean.
+Q.
+Okay. Do you --
+A.
+If it's the
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+H
+9
+10
+/11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Gallo Company
+October 6, 2009
+179
+Q. This is the first time we've seen
+mentioned on any flight logs, right?
+A. Right.
+Q. Do you find it at all peculiar that
+is listed but certain other people who may or may not be
+of age are listed generically - one female. Why would
+they go out of their way to list
+MR. PIKE: Form.
+A. I don't know. Maybe she was already an
+employee or something. I don't know.
+Q. If she's an employee at the time, then that
+would be a good explanation, right?
+A. Right. I don't know.
+Q. If she's not an employee, then is there any
+explanation?
+MR. PIKE: Form.
+A. Unless - No. I don't know. I don't
+know. Maybe Bill asked her. That looks like Bill's
+writing there when he was captain.
+Q. We'll move to 3/22/05.
+A. Okay.
+Q. Who's listed?
+A. Actually, this wasn't even my flight
+This is: Jeffrey,
+_ female.
+female
+- PBI to Kennedy.
+180
+Q. That's not your flight?
+A. No.
+Diaz is one of the few
+engineers I used as a relief. See his name written
+in up there?
+Q. Yes, but it has your name written under it,
+right?
+A. Well, yeah, because these are pre-printed
+forms. They neglected to scratch my name out.
+Q. Any idea why now they're going to list one
+female, one female"? That doesn't seem to be protocol
+here, does it?
+A. I don't - Yeah. I have no idea. I don't
+have an answer for that, I really don't.
+Q. Certainly, if you're able to get
+to
+tell you her name, it doesn't take much effort to get two
+other people to tell you their name, right?
+A
+Like I say, the only thing I can think of
+is if
+an employee by that time, that they knew
+her. I don't know.
+Q. Did it ever at any point in time cross your
+mind that there may be something illegal going on here -
+ever?
+A.
+MS. EZELL: Form.
+MR. PIKE: Form.
+Define "here."
+
+
+1
+2
+4
+5
+6
+7
+8
+9
+110
+11
+12
+13
+14
+15
+16
+117
+18
+119
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+9
+10
+11
+112
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+181
+Q. Here when you're traveling on the airplane
+with these various girls and they're listed as "one
+female" - generically listed - anything ever cross your
+mind, "maybe something's not exactly kosher"?
+A.
+No.
+MR. PIKE: Form, asked and answered
+several times.
+BY MR. EDWARDS:
+Q. Who's that? The date is 3/31/05.
+A. Jeffrey, Ghislaine, and
+Q. Let's see, 10/15 and 10/17, both look like
+nobody's on them, so I'll show them to you together.
+A.
+There might be remarks here: "Maintenance
+test flight" out of Lake City, Florida.
+We were coming out of maintenance: "No
+passengers, maintenance, relocation for the engineer
+repair."
+Q. Okay. 4/6/05 - who's on it?
+A. Jeffrey.
+David Mullen,
+Q.
+Last one.
+A. Jeffrey - 6/8/05 -
+David
+Mullen,
+Mark Zeff -
+Q. Do you know who Mark Zeff is?
+A. No -4
+Doug Shuttle,
+182
+Q.
+Do you know who
+and
+are?
+A.
+I think
+I remember - sounds familiar.
+Q.
+How did she look?
+A.
+I can't remember. I just -
+Q.
+Overage, underage?
+MR. PIKE: Form.
+A. I never saw any that I saw that looked to
+me underage.
+Q. Have you ever been to Jeffrey Epstein's house
+- his Palm Beach house?
+A. Yes.
+Q. You stayed for an entire day?
+A. No, no.
+Q. No?
+A. It would be like an hour at the most
+waiting to talk to him for a minute. No.
+Q. Let me ask it this way: Has he ever told you
+that he's infatuated with massages?
+A. No, he's never told me that.
+MR. PIKE: Form.
+BY MR. EDWARDS:
+Q.
+Have you ever known him to get a professional
+massage anywhere you go?
+A. Yeah, I believe so.
+Q. Where?
+1
+2
+3
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+5
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Gallo Company
+October 6, 2009
+183
+A. I can't - I can't say for sure. I mean,
+we used to carry a massage table on the airplane. I
+never saw one used. I don't know for sure.
+Q. Are you being paid to be here today?
+A. No, no. I mean, I'm on salary. 1 mean -
+Q. Right.
+A. because of - for the maintenance, but,
+по.
+Q. Are you going to ask Jeffrey Epstein at some
+point in time, "Why you hired an attorney to sit here
+with me?"
+A. No.
+MR. PIKE: Form.
+A. I would never - I would not approach
+Jeffrey for that.
+Q. Do you have any idea why Jeffrey Epstein might
+want an attorney to sit here for you?
+MR. PIKE: Form.
+A. No. I mean, maybe -- | don't know.
+Q. Do you think that the attorney sitting here is
+for the purpose so that you don't say anything to
+incriminate Jeffrey Epstein?
+A. No, no. I was told strictly that he was
+here upon my behalf.
+Q. Do you know of any crimes, personally, that
+184
+you witnessed Jeffrey Epstein committing?
+A. No.
+Q. Would you -
+A. No.
+Q. - go back - considering what you've read and
+what you may or may not believe - would you go back to
+working for Jeffrey Epstein?
+MR. PIKE: Form.
+A. I can't say. I still work for him on a
+maintenance - to maintain the airplanes and stuff
+like that, so.
+Q. You're on his payroll?
+A. Salaried, yes.
+Q. Do you know who else is on his payroll?
+A. Well, Dave and Larry.
+Q. Certainly, if I want to know more about his
+private life - do you know who's at his house?
+A. No.
+Q.
+Do you know who his housekeeper is?
+A. No.
+Q.
+Do you know who his architect is?
+A.
+No, no.
+Q. Does Larry visit him at his house?
+A. I would assume so.
+Q. Why do you say you would assume so? That
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+111
+12
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+1
+7
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+185
+means he told you something, right?
+A. Well, he handles -- Jeffrey does a lot of
+- he likes high-end stereo equipment and video
+equipment, and Larry is an expert at audio and video
+installations and stuff.
+Q. How about David Rodgers - ever at his house?
+A. Probably, but more like on the grounds of
+me, you know.
+Q. Any other famous people that you met through
+Jeff Epstein?
+A. On the airplane?
+Q. Yes.
+A. Walter Cronkite.
+Q. Oh, yeah?
+A. He was very nice. Yeah. He was very
+feeble, but he was very nice. We had to carry him
+down the steps.
+Q. Where did that flight go to?
+A. New York to St. Thomas. He's an avid
+sailor. He loves to sail or loved to sail.
+Q. What's the magician's name - David
+Copperfield?
+A.
+No, I don't think I was on that. I don't
+think I flew that. I heard that we had flown him. I
+can't say for sure. I would remember that. I would
+186
+remember it. I have never met David Copperfield, but
+I heard that we had. Naomi Campbell - flew her a
+couple times.
+Q. What do you understand Naomi Campbell and
+Jeffrey Epstein's relationship to be?
+A. I don't. I assume it was modeling. I
+don't know. It was like two trips.
+Q. Jeffrey Epstein ever tell you how long he was
+in the modeling industry?
+A. Never discussed it.
+Q. So the first you know of is whatever
+involvement he's in with Jean Luc Brunel.
+A. Right.
+Q. That's the first time -
+A.
+Yes.
+Q. - you've never known him to be in modeling.
+A. Correct, that I was aware of. And,
+actually, nobody ever told me that but picking up
+bits of conversation like such as the one about the
+motor home door.
+Q. What exactly did he say about the motor home
+door that led you to know that Epstein and modeling is --
+A. They were at - on location for a modeling
+shoot and they had a motor home.
+Q.
+"They" meaning Jeffrey Epstein and somebody.
+1
+4
+5
+8
+10
+11
+12
+113
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+2
+5
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ar Gallo Company
+October 6, 2009
+187
+A. Yes, I guess. Yeah. I don't know
+exactly.
+Q.
+Have you ever heard of
+sounds familiar, but I don't
+know -
+Q.
+A.
+Q.
+A.
+Q.
+A.
+Q.
+No, I can't say that I have.
+Can't say that I have.
+Glenn Dubin?
+Glenn Dubin, yes.
+How do you know him?
+I think he's a money or finance manager of
+some form - associate of Jeffrey or Ghislaine's or
+both.
+Q. And where does he live?
+A. I think he lives in California, I believe.
+Q. What do you know about him?
+A. Well, he's - just all I just told you. I
+think he's - he's an options writer or something like
+- not an options writer, hedge funds or something
+like that. He's in money. It's -- He's got an
+airplane. I think he's got a quarter share or part
+of an airplane.
+Q. Do you know anybody that owns any property
+188
+with Epstein?
+A. No.
+Q. What other properties does Jeffrey Epstein
+own? I know we talked about the Zorro Ranch, the place
+in New York, you talked about an island, West Palm Beach.
+A. That's all that I'm aware of.
+Q. How about Paris?
+A. I don't know that he owns them. That's
+where he goes for homes.
+Q. Ever go to Paris with him?
+A. He does have an apartment in Paris. I
+don't know - however that works out, if it's a lease
+or own or what.
+Q. Who are the house managers of the various
+places that he owns?
+MR. PIKE: Form.
+A. I don't know anymore. There has been so
+much shake up, you know.
+Q. Well, who were they? Do you know the
+Freidmans out in California? Do you know Eve and
+Patrick?
+A. No.
+Q. Alfredo Rodriguez?
+A. No.
+Q. Alright.
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+189
+A. No, those are all I know.
+Q. You tell me. Who do you know?
+A. God, I can't think. It's been so long
+ago.
+Q. Other than Joe-Joe.
+A. Well, Joe-Joe doesn't - he's just a driver
+for New York - he and his wife. I could remember
+them if I saw their names. I would know which house
+they were associated with. I'm terrible with names
+anymore, unfortunately. The couple that's now at the
+ranch or was at the ranch is at the island helping
+manage as an intern.
+Q. Who's that?
+A. Honestly, I can't remember their names.
+If you were to give me a name, I could attach it to
+each house.
+Q. I wish I could.
+A. Yeah, I'm sorry, I can't. It's just --
+Q. Do you know
+A. No.
+sounds familiar. I don't
+know.
+Q. Something to do with the modeling agency?
+A. Can't say for sure - can't say.
+Q. How about Kalib Shalom?
+A. No, never heard of that one.
+190
+MR. EDWARDS: Let me look over my notes
+real fast. Anybody else going to have some
+questions so I can look over my notes and maybe
+ask a couple more?
+MR. PIKE: Brad, when I get a chance to
+cross, 1 definitely will have some questions for
+the witness.
+MR. EDWARDS: Okay. Any other plaintiff
+attorneys? Kathy? I think
+quit on us -
+must have been too boring. Anybody else?
+Hold on Mike. Give me one minute and then
+I think you can shoot.
+MS. EZELL: Brad?
+MR. EDWARDS: Yes?
+MS. EZELL: I'm sorry, it's
+didn't realize my mute was on. I do have a few
+questions.
+MR. EDWARDS: Okay. Go ahead
+CROSS-EXAMINATION
+BY MS. EZELL:
+Q.
+Mr. Morrison - forgive me, I didn't write it
+down - when did you begin working for Mr. Epstein?
+A.
+January 2001.
+Q. Do you remember a young woman named
+A. No, I'm sorry, I can't - I don't.
+A N
+3
+4
+5
+6
+7
+10
+11
+12
+13
+14
+16
+17
+118
+19
+20
+21
+22
+123
+24
+25
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+112
+13
+114
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alesander Gallo Company
+October 6, 2009
+191
+Q. Do you remember a young woman named. who
+flew frequently with Jeffrey Epstein?
+A. No, I don't recall a
+Q. You mentioned al
+A. A
+yes. I remember the name
+Q. Can you describe
+A. No, I'm sorry, I can't. I just recognize
+the name - or the sound of the name.
+Q. Do you have any recollection as to what period
+of time
+flew with Mr. Epstein?
+A. It was on one of those Passenger
+Manifests. I thought I only saw it one time.
+MR. REINHART:
+- this is Bruce - the
+passenger manifest that had that name on it was
+dated June 8, 2005.
+MS. EZELL: So all of those that Brad went
+over were '04 and '05, I believe.
+MR. REINHART: Correct.
+BY MS. EZELL:
+Q. Let's see, did you ever fly Mr. Epstein to St.
+Louis?
+A. No.
+Q. Did you ever fly him to San Francisco?
+A. No.
+Q. What about France?
+192
+A. Yes, Paris.
+Q. And Spain?
+A. No, nope.
+Q. Carmel?
+A Carmel?
+MA. RENHART: Caltonia M
+MS. EZELL: Yes.
+A. No, we wouldn't have -- Was that Monterey
+area?
+MR. REINHART: Yes.
+A. Yes.
+Q. Monterey you did, okay.
+Do you remember a woman named
+accompany Elaine (sic) Maxwell?
+A. Yes, I remember
+I believe she was
+British or -
+Q. And what was her function?
+A. To the best of my knowledge, she was Ms.
+Maxwell's assistant.
+Q. Did there come a point in time where Ms.
+Maxwell flew her own plane?
+A. No.
+Q. Did there come a time that you became aware
+that she and Jeffrey Epstein were flying separately?
+A. Yes.
+who would
+
+
+1
+3
+4
+7
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+193
+Q. And whose plane would she fly on on those
+occasions?
+A. I don't know. There was - She had a
+fractional - of a flight options. She had some
+flight options. When you said -- Can I ask --
+Q. Yes.
+A.
+- when you stated, "Did she fly her own
+plane?, did you mean as a pilot?
+Q. Yes, yes.
+A. No, no. I stand with, no.
+Q. Did you ever know her to fly a helicopter?
+A.
+Yes.
+Q. And when was that?
+A. Several times. I don't remember exactly
+when she got her initial rating. Can't remember
+exactly when she got her initial rating. It was
+before - I think before - maybe around 2000, 2001. 1
+don't know that for a fact.
+Q. Among the various pilots that you have worked
+with for Jeffrey Epstein, do you know of any who has a
+house on the Zorro Ranch property?
+A. Yes.
+Q. And who is that?
+A. Larry Visoski.
+Q. And do you know if he was given that house by
+194
+Jeffrey Epstein?
+A. I do not know.
+Q. Were you ever given any properties by Mr.
+Epstein?
+A. No.
+Q. You said that you did know Mr. Jean Luc
+Brunel?
+A.
+Yes, I knew of him - and it was as an
+acquaintance - as a passenger.
+Q. Did you fly him to and from Paris?
+A. Yes.
+Q. Do you ever remember flying three girls from
+Paris for Mr. Brunel --
+MR. PIKE: Form.
+Q. - to be guests of Mr. Epstein?
+MR. PIKE: Form.
+A. I can't say that I remember that exactly,
+no, and I didn't know who - whose guests they were
+for who.
+Q. Do you remember flying three young girls to
+Mr. Epstein's birthday party?
+MR. PIKE: Form.
+A. I dont -
+Q.
+I'm sorry, I meant from France.
+MR. PIKE: Form.
+October 6, 2009
+195
+A. I can't say that I have, no. I can't say
+1
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25.
+2 that | did.
+Q. Do you remember flying three young girls back
+to France after Mr. Epstein's birthday party?
+A.
+No, no, I can't say that I do, and I
+didn't remember what birthday - that there was a big
+birthday party.
+Q. Okay. Well, forget the party part.
+A. Okay.
+Q. Were you aware that Mr. Brunel flew in three
+12-year-old girls for Mr. Epstein's pleasure on his
+birthday?
+A. No, I was not aware of that, no.
+Q. And you have no recollection of having young
+women that young on flights that you were flying on?
+A. That's correct.
+MR. PIKE: Form.
+BY MS. EZELL:
+Q. I don't have any other questions. Thank you.
+A. Thank you.
+MR. EDWARDS: Mike, I don't really think
+anybody - I'm sorry.
+CROSS-EXAMINATION
+BY MR. WILLITS:
+Q. Richard Willits here. I just have one
+196
+5
+6
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+question, sir. I didn't catch the complete and full
+spelling of your name.
+A. My name?
+Q. Yes, sir - the witness?
+A. It's Larry - Lima, Alpha, Romeo, Romeo,
+Yankee - and last name is Morrison - Mike, Oscar,
+Romeo, Romeo, India, Sierra, Oscar, November.
+MR. WILLITS: Thank you, sir.
+MR. EDWARDS: Mike, shoot.
+MR. PIKE: Thank you. Thank you.
+CROSS-EXAMINATION
+BY MR. PIKE:
+Q. Mr. Morrison, my name is Michael Pike. I
+represent Jeffrey Epstein.
+A.
+Hi.
+Q.
+I'm going to ask you a couple of questions.
+If you do not hear me, please ask me to repeat the
+question - as I'm on a telephone - and by virtue of being
+on the telephone, I've noticed that there's some lag time
+between some answers and responses.
+MR. PIKE: So, Brad, interrupt me, if I'm
+talking over the witness as well.
+BY MR. PIKE:
+Q. Mr. Morrison, Mr. Edwards was talking to you
+about your knowledge and information regarding passengers
+an Alexander Gallo Company
+
+
+2
+3
+10
+11
+12
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+2
+4
+5
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+197
+on Mr. Epstein's plane from January 1, 2001, up until the
+time you stopped flying. Do you recall some of those
+questions?
+A. Yes.
+Q. With regard to the female passengers that Mr.
+Edwards discussed with you, do you recall if any of them
+ever left the plane in a scared manner?
+A.
+No, no.
+Q. Did any of these girls ever appear to be
+disheveled to you in any way?
+A No.
+Q. Did any of these girls that were on the plane
+ever claim to be battered or sexually assaulted?
+A. Not to me, no.
+Q. Did any of these women appear to be in shock
+to you?
+A. No.
+MR. EDWARDS: Object to the form.
+BY MR. PIKE:
+Q. Were any of these women ever crying as they
+exited the plane when you were the pilot?
+A. No, not that I saw.
+Q. Did any of these women appear to be injured as
+they exited the plane when you were a pilot?
+A. No, not that I saw.
+198
+Q. Did any of these women ever tell you, as the
+captain of the plane, that they were forced to do
+something against their will while a passenger on the
+plane?
+MR. EDWARDS: Object to the form.
+A. I was - Actually, to correct the
+question, I guess I was not captain - I was flight
+engineer - but, no.
+Q. Did they ever tell you that they had been
+forced to do anything inappropriate?
+A. No.
+Q. Did they ever tell you that they had been
+assaulted in any way?
+A. No.
+Q. Did they ever tell you that they had been
+inappropriately touched in any way?
+A.. No.
+MR. EDWARDS: Form.
+BY MR. PIKE:
+Q. Did they ever tell you or did you ever hear of
+anyone claiming that they had been sexually assaulted.
+battered, or raped while on the plane?
+MR. EDWARDS: Form.
+A. No.
+MR. REINHART: Give him a chance to object
+1
+2
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+/17
+18
+119
+20
+21
+22
+23
+24
+125
+1
+2
+4
+5
+6
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+an Alexander Gallo Company
+October 6, 2009
+199
+first.
+MR. PIKE: I have no further questions.
+MR. EDWARDS: I have a couple more - just
+follow-up - from what Kathy asked.
+REDIRECT EXAMINATION
+BY MR. EDWARDS:
+Q. Did any of the people - along Mike Pike's
+lines - did any of the girls on the airplane tell you
+that he pled guilty to two felonies in court?
+MR. PIKE: Form.
+A. No, I haven't - 1 have not spoken to Mr.
+Epstein. I don't believe -
+Q. No, no. I think the question was: Did any of
+the girls tell you that Mr. Epstein pled guilty in court?
+A. Which giris?
+Q. Any of the girls on the airplane that we're
+talking about.
+No, I don't think -- Actually, I don't
+know when he pled because I think I was - stopped
+flying by then.
+Q. So there were a lot of things that happened on
+the airplane that the girls didn't necessarily tell you
+about, right?
+MR. PIKE: Form.
+A. That I wasn't - Like | say, going back to
+200
+- there was not even an opportunity or window for
+that question, because I believe it was after
+February of 07.
+Q. That's true.
+Did any of the girts on the airplane tell you
+about things that happened on the airplane that he later
+pled guilty to?
+MR. PIKE: Form.
+A. No.
+Q. Did any of the girls on the airplane really
+talk to you?
+A. No.
+Q. Okay, so all of this is kind of silly.
+Alright. Cott
+would accompany Ms. Maxwell. When you
+say "would accompany her," what did you mean about that?
+A.
+She was like her assistant. Actually. I
+don't - I didn't see
+very many times.
+I don't
+know when she stopped working there, but she would --
+Yeah, I just - She would be on trips with her --
+Q. And did you -
+A. - and, I think, handle her logistics
+issues and stuff like that.
+(Please continue to Volume II.)
+
+
+MUKRISON, LARRY (VOLI)
+
+
+
+•
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+21:6 22:23
+38:17 45:17
+75:1 88:6
+97:17 117:2
+East
+2:4 105:23
+105:24
+106:11
+108:14,25
+eastern
+117:5
+eat
+14: 5 51:17
+echelon
+12:10
+economy
+162:21 164:2
+Ed
+32:3
+education
+10:11 135:8
+Educational
+135:13
+Edwards
+2:3 4:6,12
+5:14 9:18
+11:12 13:25
+32:1,4,5
+34: 2, 6 36:8
+37:14 39:11
+39:13 43:22
+46:22 50:3
+54:16 57:24
+65:11,19,23
+66:5,12
+71:13,14
+73:14,17
+75:24 78:15
+78: 21 79:4
+79:1186:25
+88:1 100:20
+104:14
+105:18
+106:24
+110:11
+113:6
+114:14
+117:23
+118:9 119:7
+121:17
+122:13
+123:16
+125:24
+126:7,15,20
+126:23
+127:1,7
+129:5,7,15
+129:18,25
+130:3,7,8
+131:6,11
+132:6, 8
+134: 5 137:9
+137:16,23
+138:3
+139:24
+140:1 142:3
+144:14
+146:21
+148:8,10
+149:2 152:3
+152:7
+153:15,17
+153:21,24
+156:14
+157:5
+159:19
+163:20
+171:24
+172:4
+173:12
+174:15,25
+176:2
+177:13,17
+181: 8
+182:21
+190:1,8,14
+190:18
+195:21
+196:9,24
+197:6,18
+198:5,18,23
+199:3,6
+effort
+180:15
+EFIS
+27:9
+209
+either
+7:16 50:8
+72:24 88:6
+96:11 99:6
+108:20
+113:2
+146:18
+153:9
+159:22
+162:19
+170:3
+ejaculates
+175:24
+Elaine
+192:14
+electroni...
+47:18
+Elena
+187:8
+else's
+127:15
+153:22
+192:13,15
+200:15,18
+employed
+5:17 36:13
+43:11 64:3
+employee
+19:12 57:21
+179:10,11
+179:14
+180:18
+employees
+107:5,8
+172:22
+employee/...
+81:21 104:22
+employer
+19:13 57:3
+employer's
+81:15
+employer/...
+136:20
+employment
+29:6 90:2
+employs
+172:23
+an Alexander Galle Company
+empty
+93:21
+en
+114:20
+ended
+64:25 90:19
+engage
+155:21
+engineer
+6: 13 15:13
+25:6,6,16
+25:20 26:19
+36:12,15,17
+36:19 37:2
+37:2 59:11
+67:2 68:1
+68:16 69:23
+90:24
+181:16
+198:8
+engineering
+8:15
+engineers
+180:3
+engineer's
+37:24
+England
+77:2
+enjoy
+13:9 59:20
+enjoyed
+13:3
+ensures
+173:8
+entails
+11:3 173:5
+enter
+27:20,22
+entered
+12:13 46:17
+entire
+129:10
+182:12
+entitled
+176:23
+entourage
+141:10 165:5
+October 6, 2009
+176:21
+entryway
+27:23 149:14
+environment
+64:19
+environme...
+26:9
+Epstein
+1: 8 5:21
+7:25 15:4,7
+16:7,23
+18:8 20:12
+20:18,23
+21:1 23:14
+23:18 24:2
+24:2,6,8,17
+26:21 27:1
+27:13 29:7
+31:13
+32:10
+32:25 33:20
+34:5,7,14
+34:17,18,25
+35:8,8,11
+35:12 36:9
+45:3,9,22
+50:19 51:20
+52:1,5,7,10
+52:17 53:5
+53:8,11,12
+53:23,25
+54:19,22
+55:1,19,23
+56:4,7,15
+56:19 57:17
+57:23, 25
+58:1
+59: 6
+60:11,14
+61:2
+64:17
+66:11,18,22
+66: 24 70:15
+73:4,5,15
+73:20,22
+74: 11,20,22
+75:7,21
+76:16,24
+77:15 80:7
+83:7 84:14
+85:9 86:16
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
diff --git a/vision-fixhub/ds9-unparsed-05/f677046d8a9ac7d5b1aa9e4357f333c14bceb621c4a7bf7089512eda7f279ed3.receipt.json b/vision-fixhub/ds9-unparsed-05/f677046d8a9ac7d5b1aa9e4357f333c14bceb621c4a7bf7089512eda7f279ed3.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6bdea77582d6c4ba27a3cd7054d30373864699a2
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f677046d8a9ac7d5b1aa9e4357f333c14bceb621c4a7bf7089512eda7f279ed3.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -5484,
+  "dataset": "marble-joined",
+  "doc_id": "f677046d8a9ac7d5b1aa9e4357f333c14bceb621c4a7bf7089512eda7f279ed3",
+  "engine": "marble-apple-vision",
+  "event_count": 95,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "39ccceaec939e7bfaa8dbed86c5e602add5c0bfaa6cce1e640ba2137d6143c15",
+  "output_sha256": "88ca5a3d342fe9fa27158b023ef1c0c1c8108a7cf7f49898424b46f011e6bec1",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/f6b350f9410d5a042ff2b964bc6d8e864226543489fb6ceb7fba85c92b1f0522.md b/vision-fixhub/ds9-unparsed-05/f6b350f9410d5a042ff2b964bc6d8e864226543489fb6ceb7fba85c92b1f0522.md
new file mode 100644
index 0000000000000000000000000000000000000000..7f70af8e34df025511476d85aff6171c2908dc1e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f6b350f9410d5a042ff2b964bc6d8e864226543489fb6ceb7fba85c92b1f0522.md
@@ -0,0 +1,269 @@
+All port 883-4781
+B-48
+Victim Notification.
+wpd
+6125/083:57 pr
+
+
+NOTIFICATION
+Pursuant to the Agreement between the United States Attorney's Office for the Southern
+District of Florida (hereinafter referred to as "the Office") and Jeffrey Epstein (hereinafter
+referred to as "Epstein"), the Office hereby provides Notice to the individuals listed below
+(hereinafter referred to as "identified individuals") that each of them is a person who, while a
+minor, was a victim of a violation of an offense enumerated in Title 18, United States Code,
+Section 2255, committed by Epstein, and whom the Office was prepared to name as a victim in
+an Indictment charging Epstein with an enumerated offense. The Office further provides Notice
+to the identified individuals that, pursuant to the Agreement between the Office and Epstein, a
+copy of this document may be introduced in a judicial proceeding between any such identified
+individual and Epstein, and that any judicial authority interpreting this Notification, including
+any authority determining what evidentiary burdens, if any, a plaintiff must meet, shall consider
+that it is the intent of Epstein and the Office to place the identified individuals in the same
+position as they would have been had Epstein been convicted of those federal offenses.
+Jane Doe #1
+Identified Individuals
+Jane Doe #12
+Jane Doe #23
+Jane Doe #2
+Jane Doe #13
+Jane Doe #24
+Jane Doe #3
+Jane Doe #14
+Jane Doe #25
+Jane Doe #4
+Jane Doe #15
+Jane Doe #26
+Jane Doe #5
+Jane Doe #16
+Jane Doe #27
+Jane Doe #6
+Jane Doe #17
+Jane Doe #7
+Jane Doe #18
+Jane Doe #28
+Jane Doe #29
+Jane Doe #30
+Jane Doe #8
+Jane Doe #19
+Jane Doe #9
+Jane Doe #20
+Jane Doe #10
+Jane Doe #21
+Jane Doe #11
+Jane Doe #22
+
+
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Dated:
+By:
+ASSISTANT
+UNITED
+STATES
+ATTORNEY
+ACKNOWLEDGEMENT
+I have received this Notification from my attorney, Roy Black, Esquire, have read it and
+discussed it with my attorney, and I hereby acknowledge that it accurately sets forth my
+understanding and agreement with the Office of the United States Attorney for the Southern
+District of Florida. I understand that an exact copy of this Notification will be provided to each
+identified individual, except that the names of all other identified individuals will be redacted,
+and I hereby waive any evidentiary challenges to the introduction of a copy of this
+document-even in redacted form-in any judicial proceeding between any identified individual
+and myself.
+Dated:
+
+
+U
+D
+e
+partment of Justice
+United States Attorney
+Southern District of Florida
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+
+1) 820-8777
+On June 30
+plea of guilty to y
+prostitution) and 7
+Judicial Circuit in a
+2008-
+Revised
+Victim Notsficatin 18
+•Popd
+TIFIED VICTIMS
+6125/08
+red to as "Epstein) entered a
+5:23pm
+96.07 (felony solicitation of
+in prostitution), in the 15th
+-auve evuly (Last INOs. 2006-cf-009495AXXXMB and
+followed by
+) and was sentenced to a term of eighteen months' imprisonment to be
+years of probation.
+In light of the entry of the guilty plea and sentence, and pursuant to the terms of
+the deferred prosecution agreement between Epstein and the United States Attorney's
+Office for the Southern District of Florida (hereinafter referred to as "the Office"), the
+Office hereby provides notice to Epstein that the following is a list of individuals whom
+the Office was prepared to name as victims in an Indictment charging Epstein with
+violations of federal statutes enumerated in Title 18, United States Code, Section 2255
+(hereinafter referred to as "identified individuals").
+The terms of the deferred prosecution agreement provide that the identified
+individuals shall have the same right to seek damages pursuant to Title 18, United States
+Code, Section 2255, as they would have had if Mr. Epstein had been tried and convicted
+of those enumerated offenses in a federal court. Section 2255 provides, in relevant part:
+Any person who, while a minor, was a victim of a violation of section ...
+2422, or 2423 of this title and who suffers personal injury as a result of
+such violation, regardless of whether the injury occurred while such person
+
+JULY _, 2008
+
+was a minor, may sue in any appropriate United States District Court and
+shall recover the actual damages such person sustains and the cost of the
+suit, including a reasonable attorney's fee. Any person as described in the
+preceding sentence shall be deemed to have sustained damages of no less
+than $150,000 in value.
+Thus, pursuant to the deferred prosecution Agreement between the Office and
+Epstein, the Office hereby provides Notice to the identified individuals that each of them
+is a person who, while a minor, was a victim of a violation of an offense enumerated in
+Title 18, United States Code, Section 2255, committed by Epstein. The Office further
+provides Notice to the identified individuals that, pursuant to the Agreement between the
+Office and Epstein, a copy of this document may be introduced in a judicial proceeding
+between any such identified individual and Epstein, and that any judicial authority
+interpreting this Notification, including any authority determining what evidentiary
+burdens, if any, a plaintiff must meet, shall consider that it is the intent of Epstein and the
+Office to place the identified individuals in the same position as they would have been
+had Epstein been convicted of those federal offenses.
+Identified Individuals
+Jane Doe #1
+Jane Doe #2
+Jane Doe #3
+Jane Doe #4
+Jane Doe #5
+Jane Doe #6
+Jane Doe #7
+Jane Doe #8
+Jane Doe #9
+Jane Doe #10
+Jane Doe #11
+Jane Doe #12
+Jane Doe #13
+Jane Doe #14
+Jane Doe #15
+Jane Doe #16
+Jane Doe #17
+Jane Doe #18
+Jane Doe #19
+Jane Doe #20
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Dated:
+By:
+ASSISTANT U.S. ATTORNEY
+ACKNOWLEDGEMENT
+I have received this Notification from my attorney, Roy Black, Esquire, have read
+
+
+JULY
+_ 2008
+
+it and discussed it with my attorney, and I hereby acknowledge that it accurately sets
+forth my understanding and agreement with the Office of the United States Attorney for
+the Southern District of Florida. I understand that an exact copy of this Notification will
+be provided to each identified individual, except that the names of all other identified
+individuals will be redacted, and I hereby waive any evidentiary challenges to the
+introduction of a copy of this document-even in redacted form-in any judicial proceeding
+between any identified individual and myself.
+Dated:
+
+
+e
+partment of Justice
+United States Attorney
+Southern District of Florida
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July _ 2008
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a
+plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of
+prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th
+Judicial Circuit in and for Palm Beach County
+2008-
+followed by
+) and was sentenced to a t
+years of probation.
+prisonment to be
+In light of the entry of the guilty ple
+defer federal prosecution in favor of th
+conditions.
+One such condition to which Eps'
+cop
+"Any person, who while a min‹
+enumerated in Title 18, Unite J
+tached to Ex..
+same rights to proceed under
+attach
+6/25/086:00pm
+tates has agreed to
+subiect to certain
+ng:
+on of an offense
+5, will have the
+have had, if Mr.
+Epstein had been tried federally «..
+amerated offense.
+For purposes of implementing this paragıapnited States shall
+provide Mr. Epstein's attorneys with a list of individuals whom it was
+prepared to name in an Indictment as victims of an enumerated offense by
+meet, shall consider that it is the intent of the parties to place these
+
+
+JULY _ 2008
+
+identified victims in the same position as they would have been had Mr.
+Epstein been convicted at trial. No more; no less."
+Through this letter, this Office hereby provides Notice that the individuals
+identified below are individuals whom the United Stats was prepared to name as a victim
+of an enumerated offense.
+Identified Individuals
+Jane Doe #1
+Jane Doe #2
+Jane Doe #3
+Jane Doe #4
+Jane Doe #5
+Jane Doe #6
+Jane Doe #7
+Jane Doe #8
+Jane Doe #9
+Jane Doe #10
+Jane Doe #21
+Jane Doe #22
+Jane Doe #23
+Jane Doe #24
+Jane Doe #25
+Jane Doe #26
+Jane Doe #27
+Jane Doe #28
+Jane Doe #29
+Jane Doe #30
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Dated:
+By:
+ASSISTANT U.S. ATTORNEY
+ACKNOWLEDGEMENT
+I have received this Notification from my attorney, Roy Black, Esquire, have read
+it and discussed it with my attorney, and I hereby acknowledge that it accurately sets
+forth my understanding and agreement with the Office of the United States Attorney for
+the Southern District of Florida. I understand that an exact copy of this Notification will
+be provided to cach identified individual, except that the names of all other identified
+individuals will be redacted,
+and I hereby waive any evidentiary challenges to the
+
+
+JULY_ 2008
+
+introduction of a copy of this document even in redacted form-in any judicial proceeding
+between any identified individual and myself.
+Dated:
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/f6b350f9410d5a042ff2b964bc6d8e864226543489fb6ceb7fba85c92b1f0522.receipt.json b/vision-fixhub/ds9-unparsed-05/f6b350f9410d5a042ff2b964bc6d8e864226543489fb6ceb7fba85c92b1f0522.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..516e13de2b0b44ad48032adc33694f1a18f44cf4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f6b350f9410d5a042ff2b964bc6d8e864226543489fb6ceb7fba85c92b1f0522.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -474,
+  "dataset": "marble-joined",
+  "doc_id": "f6b350f9410d5a042ff2b964bc6d8e864226543489fb6ceb7fba85c92b1f0522",
+  "engine": "marble-apple-vision",
+  "event_count": 15,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "4535f94867a6204b696dc7d9ceb1f112fa6e594415de1e93a577fa82718fe3e5",
+  "output_sha256": "2c38474a9df374452d5f6391248528ff01a412d181e21d5c5f24665f6b11e029",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/f72e5aa9c503bef0db8ce3b1eda44673888717b69cc6b4e6ddcaed687bd9e49c.md b/vision-fixhub/ds9-unparsed-05/f72e5aa9c503bef0db8ce3b1eda44673888717b69cc6b4e6ddcaed687bd9e49c.md
new file mode 100644
index 0000000000000000000000000000000000000000..241e129ca2219508b9e96ad83fd3cb7960d03779
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f72e5aa9c503bef0db8ce3b1eda44673888717b69cc6b4e6ddcaed687bd9e49c.md
@@ -0,0 +1,6426 @@
+09 - 22783
+Condensed Transcript
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CIVIL DIVISION
+L.M.,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+CASE No.
+502008CA028051XXXXMB AB
+Defendant.
+DEPOSITION OF
+LOUELLA RABUYO
+VOLUME I
+October, 20, 2009
+10:10 a.m.
+515 N. Flagler Drive
+Suite 200-P
+West Palm Beach, Florida 33401
+Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Florida
+ESQUIRE
+an Alezander Gallo Company
+Toll Free: 866.709.877
+acsimile: 561.394.262
+Suite 600
+4440 PGA Boulevaro
+
+
+
+
+1
+IN THK CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
+IN AND POR PALM BEACH COUNTY, FLORIDA
+CIVIL DIVISION
+CASE No. 502008CA028051XXXXM7 AR
+L.M..
+Plaine iff,
+-Va-
+JEFPREY EPSTEIN,
+Defendant.
+DEPOSITION DUE ELA BABUXO
+Turday. 0°9:30 p.m. 2009
+515 at Pall Be DE. 0844533002°
+Reported By:
+1
+4
+5
+10
+17
+18
+19
+23
+24
+2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE No.0B-CV-B0119-CIV-MARRA/JOHNSON
+JANE DOE NO. 2,
+-VS-
+Plaintift,
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-80380, 98-80381, 08-80994,
+08-80993, 0B-B0811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+DEPOSITION OF LOUELLA RABUYO
+VOLUME 1
+Turday aber 20. 2008
+515 N. Flagler Drive, Suite 200-P
+West Palm Beach, Florida 33401
+• Notary Public, State of Flor
+est Palm Beach Office Job #1189
+Phone: 800.330.6952
+561.659.4155
+3
+: APPEARANCES:
+On behalf of the Defendant
+ROBERT D. CRITTON, JR., ESQUIRE
+4
+BURMAN CRITTON LUTTIER & COLEMAN, LLP
+5
+303 Banyan Boulevard, Suite 400
+West Palm Beach, Florida 33401
+Phone: 561.842 2820
+= 4a
+On behalf of Plaintiff L.M.:
+BRADLEY J. EDWARDS, ESQUIRE
+CARA L. HOLMES, ESQUIRE
+ROTHSTEIN ROSENFELDT ADLER
+10
+401 E. Las Olas Boulevard, Suite 1650
+Fort Lauderdale, Florida 33394
+Phone: 954.522.3456
+11
+12
+On behalf of the Witnesse
+13
+BRUCE E. E
+14
+LAW OFFICE OF BRUCE E.
+250 S. Australian Avenue, Suite 1400
+West Palm Beach, Florida 33401
+15
+Phone: 561.202.6360
+16
+On behalf of Defendants/Jane Does 2 - 8:
+STUART S. MERMELSTEIN, ESQUIRE
+19
+MERMELSTEIN & HOROWITZ, P.A.
+18205 Biscayne Boulevard, Suite 2218
+20
+Miami, Florida 33160
+Phone: 305.931.2200
+21 On behalf of Plaintiff in related Case No. 08-80811
+22
+JACK HILL, ESQUIRE (Partially via speakerphone)
+SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY
+23
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: 561.686.6300
+4
+2
+3
+INDEX
+INES ORECT CROS HERET HECHOES
+LOUELLA RABUYO
+฿
+BY MR. EDWARDS: 5
+9
+BY MR. MERMELSTEIN:
+190
+135
+208
+10
+BY MR. HILL:
+156
+11
+BY MR. CRITTON:
+173
+12
+13
+14
+EXHIBITS
+15
+16
+17
+NUMBER
+DESCRIPTION
+PAGE
+DEFENDANTS EX. 1 COPIES, COMPOSITE PHOTOGRAPHS 103
+19 DEFENDANTS EX. 2 COMPOSITE PHONE MESSAGE BOOK 147
+DEFENDANTS EX. 3 COPY OF PHOTOGRAPH
+162
+21
+/22
+/ 23
+25
+ESQUIRE
+an Alesander Callo Company
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+1
+2
+3
+4
+5
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+5
+PROCEEDINGS
+Deposition taken before Teresa Whalen,
+Registered Professional Reporter, Florida
+Professional Reporter, and Notary Public in and for
+the State of Florida at Large, in the above cause.
+Thereupon,
+(LOUELLA RABUYO)
+having been first duly sworn or affirmed, was examined
+10
+and testified as follows:
+11
+THE WITNESS: I do.
+12
+DIRECT EXAMINATION
+113
+MR. EDWARDS: Does anyone want to put on the
+14
+record what case this is being taken in? I noticed
+15
+it in L.M. versus Epstein. I don't know if anybody
+16
+cares to say who your clients are, what the case
+17
+style is or anything else for when she types it up.
+18
+MR. MERMELSTEIN: I don't have a problem with
+19
+that. Are we doing initials?
+20
+MR. EDWARDS: Yeah. Initials.
+MR. MERMELSTEIN: Okay.
+21
+22
+BY MR. EDWARDS:
+23
+Q All right. Will you state your name for the
+24
+record.
+25
+6
+A Louella Rabuyo.
+Q And what's your current address?
+A 904 Summer Street, Lake Worth.
+Q All right. How long have you lived at 904
+Summer Street?
+A About two years.
+Q Two years. Where did you live prior to 904
+Summer Street?
+A In Palm Ridge Apartment, that's in Mango
+Drive.
+How long did you live there?
+A About a year.
+Q All right. Where did you live prior to that,
+the Palm Ridge Apartment?
+A In a townhouse in West Palm Beach.
+Q Okay. How long did you live in the townhouse
+in West Palm Beach?
+A Less than a year.
+• Have you ever lived at Jeffrey Epstein's
+location of 358 El Brillo Way?
+A No, sir.
+Q Where are you currently employed?
+A Mr. Epstein.
+And what address do you report to work?
+A 358 El Brillo Way.
+7
+1
+2
+3
+4
+5
+6
+• How long have you been employed by
+Mr. Epstein?
+A It will be five years this November 17th.
+• So you started November 17th, 2004?
+A Yes, sir.
+• And how did you get hired by Mr. Epstein?
+A Through an agency.
+• What agency?
+A It's Regal Domestics.
+• And what was your position that you were hired
+by Mr. Epstein for?
+A Housekeeper.
+• We've taken the deposition of another witness
+in this case, Alfredo Rodriguez. Are you familiar with
+that name?
+A Yes.
+• And that person, I believe he represented that
+he was also maybe a house manager. Is that correct?
+A Correct.
+• Would he have been, at some point in time,
+your boss or your superior?
+A Yes.
+• That's somebody who you answered to,
+Alfredo Rodriguez?
+A (Nodding head). Sometimes --
+8
+1
+2
+3
+4
+5
+.: You have to say yes or no, you
+can't nod your head.
+BY MR. EDWARDS:
+• Yes?
+A Yes.
+MR. CRITTON: No, no. She said sometimes.
+then you put yes in her mouth.
+5 o 0
+MR. EDWARDS: I didn't put anything in her
+mouth. I don't want the record -
+MR. CRITTON: Let me take it back. You said
+11
+12
+yes, but she started to say something before she
+was interrupted.
+13
+14
+BY MR. EDWARDS:
+• That's fine. You can answer the question,
+15
+then we'll instruct you on the deposition.
+16
+MR.
+7: Did you want to explain that
+17
+18
+further?
+THE WITNESS: Because we were supposed to work
+19
+20
+together, but he was bossy, he was bossy.
+BY MR. EDWARDS:
+21
+22
+• Okay. Have you ever had your deposition taken
+before like this?
+23
+A No.
+24
+• All right. Well, there is one court reporter,
+25
+and it's very easy in casual conversation to nod your
+ESQUIRE
+an Alesander Galla Company
+Toll Free: 866.709.877
+Facsimile: 561.394.262
+Suite 600
+
+
+1
+2
+3
+4
+5
+6
+7
+9
+10
+11
+12
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+3
+4
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+9
+head or shake your head, and she can't take that down.
+A All right.
+Q It's also very easy to say uh-huh or huh-uh,
+but it kind of looks the same on paper, so you can't do
+that either. I'm going to wait until you finish your
+answer, and you have to wait until I finish my question,
+because if we talk over one another, then the court
+reporter can't get it down.
+A Okay. Yes, sir.
+Q All right. So if you don't understand the
+question, tell me you don't understand and i'll try to
+ask a better question.
+A Yes.
+• Okay. So you were hired in November of 2004
+to be the housekeeper for Mr. Epstein?
+A Yes.
+Q And when you were hired, who exactly hired
+you, who -- let me strike that.
+When you were hired to be the housekeeper for
+Mr. Epstein, who did you interview with?
+A Ms. Maxwell.
+Q Is that Ghislaine Maxwell or just
+Laine Maxwell?
+A Ghislaine Maxwell.
+Q And where did the interview take place?
+10
+A At 358 El Brillo Way.
+Q And what did Ms. Maxwell and you speak about
+prior to your being hired as the housekeeper?
+A My duties.
+Q And what did she tell you your duties would
+A To tidy, to make beds, do laundry.
+Q
+Did she tell you what would take place in the
+house on a day-to-day basis?
+A No.
+Q So going into that position, you had no idea
+who the guests would be or who the people coming in the
+house would be, or what would generally go on?
+A Can you simplify the question?
+Q Sure. When you talked about with
+Ghislaine Maxwell at this interview, your duties being
+you would make the bed and tidy up, did she also tell
+you that there would be a lot of guests, there would be
+a few guests, did she talk to you about that at all?
+A She mentioned that if there are guests, we
+have to, like, you know, prepare the room, and, what's
+this, attend to the guests.
+• And what did you understand that to mean that
+you have to attend to the guests?
+A You have to prepare the room and see to it
+ESQUIRE
+an Alexander Gallo Company
+11
+1
+2
+3
+4
+5
+6
+7
+that it's clean and appropriately, what's this...
+• And as I understand this property, there is a
+main house and then there's also a staff house on the
+property; is that right?
+A Yes, sir.
+• And when the guests would come over, would you
+stay in the main house, or would you go to the staff
+house?
+9
+MR.
+Can we get a time frame to the
+10
+question?
+(11
+BY MR. EDWARDS:
+12
+• Over the last five years while you worked
+13
+there.
+14
+A I usually stay in the staff house and do the
+15
+laundry, then I go to the kitchen and then tidy the
+/16
+kitchen.
+17
+• You were hired in November of 2004, and what
+18
+were your hours that you worked there back in November
+19
+of 2004 when you were hired?
+20
+A Eight to five.
+21
+Q How many days a week?
+22
+A Depends.
+23
+Q How would the schedule be relayed to you?
+24
+A When Mr. Epstein is there, then I'm supposed
+25
+to report, but usually it's five days a week.
+12
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Q So am I correct in understanding that there
+was one schedule when Mr. Epstein was in town, and the
+schedule may be a little bit different if Mr. Epstein
+was out of town?
+A Yes, sir.
+Q All right. Tell me the differences when
+Mr. Epstein is in town versus when Mr. Epstein was not
+in town.
+A If he stays like three or four days, then I'm
+supposed to be there, and then the house is to be
+cleaned. And then when they do not come, then I can
+either go there, or I'm given free days off.
+Q Three days off?
+A No. A free day.
+• Oh, okay. But typically back in 2004 when you
+were hired, you worked an average of about five days a
+week; is that correct?
+A Yes.
+• All right. And I guess by the way that you're
+explaining it, if Mr. Epstein was in town for a longer
+period of time, you may work more than five days, and if
+Mr. Epstein was not in town, you may work less than five
+days?
+A Yes.
+• Okay. Did you ever talk to Mr. Epstein prior
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+13
+15
+to being hired?
+• Did she tell what you would be paid at that
+A No, sir.
+time?
+• Where did this meeting, within the house where
+3
+A Not yet.
+did the meeting with Ghislaine Maxwell take place?
+4
+Q Did you show up that Saturday? I guess that's
+A In the living room.
+November 17th of 2004?
+Q Aside from telling you that you were going to
+6
+A No, that's not.
+be required to make the beds and just generally tidy up,
+7
+• No. Was it prior to November 17th of 2004, or
+did she specify anything else that you would be required
+after?
+to do?
+9
+A After.
+A No.
+10
+• Okay. The interview that you first went to
+Q Where had you worked prior to working for
+11
+was November 17th, 2004 with Ms. Maxwell; is that the
+Mr. Epstein?
+12
+date that you gave us?
+A I work as a certified nursing assistant.
+13
+A I cannot remember.
+Q
+Where?
+14
+• The only reason I'm using that date is 1
+A At that time I was doing private duty.
+15
+believe the question I asked was when did you start
+Q How long have you been a certified nursing
+16
+assistant?
+/17
+working for Mr. Epstein, and I thought the date that you
+gave me was November 17th, 2004.
+A Since about ten years.
+18
+A Yes.
+Q And what made you change professions from
+119
+• Okay. And in the course of this whole thing,
+being a certified nursing assistant to be a housekeeper 20
+it sounds like you interviewed with Ghislaine Maxwell,
+for Mr. Epstein?
+21
+there were other interviewees, you received a call and
+A The agency called me that there is an
+22 you were asked to try out on a Saturday?
+interview; if I like, I go to, so that's how it started.
+23
+A Yes.
+• And when you went to the interview, obviously
+24
+• And where does that Saturday fall in related
+you're going to this very big house and you talked to
+25
+to November 17th, 2004?
+14
+16
+Ghislaine Maxwell, right?
+1
+A When I accepted the job offer.
+•A Yes.
+2
+• Okay. And did they tell you at that time when
+• And did you decide right then that you liked
+this and that you were going to change professions and
+4
+you accepted the job offer how much you were going to be
+paid?
+you were going to be his housekeeper?
+A Yes.
+A No.
+6
+Q What was that?
+• Okay. Then walk me through that, how did you
+7
+A It was 32,000 per annum.
+go about eventually accepting the position?
+8
+• And has your salary increased over time?
+A I didn't expect to be hired, because there
+9
+A Yes, sir.
+were other interviewers (sic), interview people that
+10
+were to be interviewed.
+11
+• And can you walk us through the increments of
+increase in your salary?
+Q Okay.
+12
+A It was promised yearly increase.
+A And then I receive a call from Ms. Maxwell if
+13
+• By whom?
+I like, I can do a try-out.
+14
+A Ms. Maxwell.
+• Okay. Did she tell you how long this try-out
+15
+• Was that at the time when you were
+period would last?
+16
+interviewed, or took the job?
+A No.
+17
+A Yes, sir.
+• And what did you tell her when she made that
+18
+offer for you to try out?
+19
+• Did she promise you what your yearly increase
+would be?
+A I told her that I am still taking care of this
+20
+A No.
+patient, so she said if you like, you can come Saturday
+21
+• And have you received a yearly increase every
+and try it.
+22 year?
+Q Okay. And what did you tell her, did you
+123
+A I did.
+accept that?
+/24
+• And what has that yearly increase been?
+A Yes, I did.
+25
+A Up to 42.
+ESQUIRE
+an Alexaader Galle Company
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+1
+2
+3
+5
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+4
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+17
+Q Today?
+A Yes.
+• So you're making $42,000 today, and that's the
+most that you've made over the five-year period you've
+worked for Mr. Epstein?
+A Yes, sir.
+Q At the time when you - when we took
+Alfredo Rodriguez's deposition, he described you as a
+very religious Catholic woman. Does that accurately
+describe you?
+MR. CRITTON: Let me just object to the form.
+MR.
+: You can answer the question if
+you understood it.
+THE WITNESS: I am a Catholic and I go to
+mass.
+BY MR. EDWARDS:
+Q Is that something you go to regularly?
+A If I have time, I go regularly.
+Q When do you normally go to mass?
+A Sunday masses and weekdays.
+How many weekdays?
+A If I can, every day.
+Q And in the five-year period that you've worked
+for Mr. Epstein, have you tried to go every day if you
+could?
+18
+A No.
+Q In a typical week would you normally go on
+Sunday to mass?
+A Yes, sir.
+Q And how many days during the week will you
+also attend mass?
+A If the schedule permits, then I go, but if
+not, then I don't go.
+Q So is there a way that you could give me an
+average of how many times a week that you go during the
+week to mass?
+A This time?
+• Right. Yeah. I guess today, these days.
+A l attend Sunday masses only.
+• And back in 2004, when you first started with
+Mr. Epstein?
+A I tried to go if i have the time, sir.
+Q Was there ever a time that you went every day?
+A No.
+Q But your testimony is that if time permitted,
+you tried to go every day?
+A Yes.
+Q Is there a reason why now these days you only
+attend on Sundays?
+A Because my time schedule has changed.
+ESQUIRE
+an Alexander Galle Company
+19
+• Okay. So let's talk about that. Back in
+2
+November of 2004, you were to working 8:00 a.m. to
+5:00 p.m. And when did that schedule change from 8:00
+4
+5
+6
+7
+5:00?
+A When? When the house was renovated.
+• When was that, do you remember the year?
+A 2006.
+• Okay.
+9
+10
+MR. CRITTON: I'm sorry. '06?
+THE WITNESS: '06.
+11
+BY MR. EDWARDS:
+12
+• So from November 2004 through '06, I'm correct
+13
+in presuming that your schedule was an average of five
+14
+days a week from 8:00 a.m. to 5:00 p.m.?
+15
+A At that time I go nine o'clock, 1 go to the
+16
+house at nine o'clock.
+17
+• Starting in 2006?
+18
+A Yes.
+19
+So when your schedule changed from 8:00 to
+20
+5:00, in 2006 you started going to the house,
+21
+Jeffrey Epstein's house, at nine o'clock?
+22
+A Yes, sir.
+23
+Q And you would stay until what time?
+24
+A Sometimes 5:00, sometimes later, 5:30.
+25
+Q Would that depend on what needed to be done?
+20
+1
+A Yes.
+2
+Q How have you received your money, has it been
+3
+by check, by cash, in terms of payment from Mr. Epstein?
+4
+A It's directly deposited to my bank.
+5
+• Do you know who directly deposits your money?
+6
+A Who?
+7
+Q Yeah. Whether it's Ghislaine Maxwell or a
+8
+corporation or Jeffrey Epstein, do you know who the
+9
+direct depositor is of your check?
+10
+MR. CRITTON: Form.
+11
+THE WITNESS: Mr. Epstein.
+12
+BY MR. EDWARDS:
+13
+Q Okay. Over the five years that you have been
+14
+working at Mr. Epstein's house, how many conversations
+15
+16
+have you had directly with Mr. Epstein?
+A What's this, what year?
+17
+• Well, in the last five years, how many
+18
+conversations have you had directly with Mr. Epstein?
+19
+MR. CRITTON: Form.
+20
+THE WITNESS: The past year it's just good
+21
+morning, how are you, you're doing a good job.
+22 BY MR. EDWARDS:
+123
+• Okay. How was it prior to that, did you talk
+24
+to him more?
+25
+A This time more.
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+1
+5
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+21
+Q Now you talk to him more?
+A Because I serve him breakfast, so...
+Q And is that an additional responsibility that
+you didn't have before?
+A Yes.
+Q In the five-year period that you've worked
+there, can you name for me all of the other employees
+who have worked at the Jeffrey Epstein house?
+A After Alfredo Rodriguez left, there was
+Jerome, the gardener, and now it's Yanusz.
+• And those are the house managers?
+A Yes.
+• And then you work there?
+A Right.
+• Aside from yourself, Jerome, and Janusz, was
+there anybody else that you can remember working at the
+house in the past five years in any position?
+A Yes.
+Q Who else?
+A
+Yes.
+• What does she do there?
+A She's the personal assistant.
+Q Personal assistant to whom?
+22
+1
+2
+3
+5
+6
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A Mr. Epstein.
+• And as his personal assistant, what have you
+observed her to do for him?
+A Can you rephrase your question?
+• I can try. You said that she's his personal
+assistant. What does that mean, what does she do?
+A Order things that I need, or, what's this.
+• So it's your testimony that
+has
+been, for the past five years that you've worked there,
+has been somebody that you have observed to order things
+that you need?
+A If I need something, then I go to ask
+• Okay. What other things have you seen
+do for Mr. Epstein?
+A I have not, that's the only thing I know.
+• Who told you that
+is
+Mr. Epstein's personal assistant?
+A Coworker.
+Q Who is that?
+A In New York.
+• What's that person's name?
+A Lyn.
+Q Lyn who?
+A Fontanilla.
+Q Is that Jojo's wife?
+2
+3
+6
+7
+8
+9
+110
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+/20
+21
+22
+123
+124
+25
+ESQUIRE
+an Alesander Gallo Company
+23
+A Yes.
+Q When did you talk to Lyn Fontanilla about
+A It was just through the conversation.
+• What would cause you to be in a conversation
+with this person in New York?
+MR. CRITTON: Form.
+THE WITNESS: She calls me, I call her.
+BY MR. EDWARDS:
+a You're friends?
+A Yes.
+• Do you still talk to her today?
+A Yes.
+• And does she work for Mr. Epstein as well, to
+your knowledge?
+A She does.
+@ And does Jojo, her husband, also work for
+Mr. Epstein as well?
+A Yes, sir.
+Q Where do they work?
+A In New York.
+Q At Mr. Epstein's house in New York?
+A Yes, sir.
+Q And have you talked with them about your
+duties and has she talked to you about her duties?
+24
+A Yes, sir.
+• And your duties are similar to Lyn's duties in
+New York?
+A No. Because that's a bigger house than...
+Q Palm Beach?
+A Yes, sir.
+Q Is it your understanding that -- you know,
+we're going to get into the past two years where
+Mr. Epstein has either been in jail or he's been on
+house arrest in Palm Beach, so I'm going to ask you
+first for the first three years that you worked there
+and Mr. Epstein was traveling, was Mr. Epstein spending
+the majority of his time in Palm Beach or in New York or
+elsewhere, if you know?
+A He comes - we don't know the schedule, we
+receive a call, then we prepare, he's coming.
+• You say we receive a call. Who receives the
+call?
+A Either Alfredo or Janusz.
+Q Depending on who the house manager is at the
+time?
+A And the cal comes from whom, from chiane
+or from Jeffrey Epstein?
+A I don't know.
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+1
+2
+4
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+25
+• Okay. What's your understanding of Lyn's role
+in Jeffrey Epstein's life up in New York?
+A She's housekeeper, too.
+Q And your understanding of Jojo's role?
+A A driver.
+Q
+Does he also serve as a house manager, similar
+to the way Alfredo Rodriguez was in Palm Beach?
+A
+No.
+When you say a driver, who does he drive, if
+you know?
+А Мг. Epstein.
+• All right. Mr. Epstein obviously hasn't been
+in New York for quite some time; isn't that your
+understanding?
+A Yes.
+• So Jojo's still employed up in New York as a
+driver for Mr. Epstein, right?
+A He also does housework, helps Lyn.
+• Have you discussed with Lyn whether or not
+young girls visit the house in New York?
+MR. CRITTON: Form.
+MR.
+: You can answer that.
+BY MR. EDWARDS:
+• He didn't like the form of my question so he's
+able to object, but you can still answer.
+26
+1
+4
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR.
+You can still answer if you
+understand the question.
+THE WITNESS: No.
+BY MR. EDWARDS:
+• You've never talked to Lyn about young girls
+being in the house in New York?
+A When the news came up, so that's how we
+talked.
+• What do you mean, when the news came up?
+A Whenever there was something on the news on
+TV, then that's how we come to talk about it.
+• Okay. When you say something came on the
+news, you're talking about in terms of a criminal
+investigation of Mr. Epstein?
+MR. CRITTON: Form.
+THE WITNESS: Criminal?
+BY MR. EDWARDS:
+• Well, you realize that Mr. Epstein went to
+jail, right?
+A Yes.
+• And that was after pleading guilty to some
+crimes. You realize that, right?
+MR. CRITTON: Form.
+BY MR. EDWARDS:
+Q I mean, that's why you go to jail.
+ESQUIRE
+as Alexander Galle Company
+3
+4
+5
+6
+7
+10
+11
+12
+15
+17
+18
+119
+20
+21
+22
+23
+24
+25
+27
+MR. CRITTON: Form.
+BY MR. EDWARDS:
+• You realize that?
+MR.
+; Do you understand his question?
+BY MR. EDWARDS:
+• Do you understand my question?
+MR.
+Do you know that is what he's
+asking you?
+THE WITNESS: Yes.
+MR. D
+: I think the question was do you
+know whether or not Mr. Epstein pled guilty to
+crimes.
+Was that the question?
+MR. EDWARDS: Sure.
+MR. CRITTON: That was not his question.
+BY MR. EDWARDS:
+• Okay. Well, do you realize that Mr. Epstein
+pled guilty to crimes?
+A Plead guilty? From the news.
+Q Okay. So when you say you saw the news, which
+is where this portion of our discussion began, are you
+referring to the news related to Mr. Epstein and the
+charges, the criminal charges or criminal investigation
+surrounding him; is that the news you're talking about?
+A Yes.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+120
+21
+22
+23
+24
+25
+28
+• Okay. So when that came out are we talking
+about 2005, 2006, something in that area?
+MR. CRITTON: Form.
+BY MR. EDWARDS:
+Q Is that the first time you remember seeing the
+news on that subject?
+MR. CRITTON: Form.
+THE WITNESS: I cannot remember.
+BY MR. EDWARDS:
+Q All right. Whenever it was, you talked to Lyn
+about that?
+A No. I don't usually talk about it. She calls
+and how are you doing, then oh, like that.
+• Okay. And what was the discussion as it
+related to girls in either the New York house or the
+Palm Beach house between yourself and Lyn?
+MR. CRITTON: Form.
+THE WITNESS: She talks to me when she read in
+the news or she saw on the computer.
+BY MR. EDWARDS:
+• Okay. And does she tell you about young girls
+being in the New York house?
+MR. CRITTON: Form.
+THE WITNESS: She did not.
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+1
+4
+7
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+29
+BY MR. EDWARDS:
+Q
+Okay. Have you talked to Jojo about that?
+2
+MR. CRITTON: Form.
+THE WITNESS: No.
+BY MR. EDWARDS:
+Q In working there for five years, at least the
+time period prior to Mr. Epstein going to jail, while
+you were there you recognized a lot of young girls in
+the house, right?
+9
+MR. CRITTON: Form, predicate.
+110
+THE WITNESS: Young girls?
+11
+BY MR. EDWARDS:
+12
+Q Are you asking -
+13
+A They are females.
+14
+• Where did the females come from, did you know?
+15
+A
+I dont know.
+16
+Q
+Do you know why they were at the house?
+17
+A For massage.
+18
+MR. CRITTON: Form.
+19
+BY MR. EDWARDS:
+20
+Q When is the first time that you heard about
+21
+females coming to Mr. Epstein's house for massages?
+22
+A Maybe two weeks after I started working.
+123
+Q All right. So if you started November 17th of
+24
+2004, then sometime around early December of 2004, you
+25
+30
+31
+• All right. And when is the first time that
+you saw these girls come to the house? And by "these
+girls," I'm talking about the girls that you were told
+were there to give massages.
+MR. CRITTON: Form.
+THE WITNESS: I cannot remember specifically
+the day and the time.
+BY MR. EDWARDS:
+Q These massages take place every day that
+Mr. Epstein's in town, right?
+MR. CRITTON: Form, leading.
+THE WITNESS: Not always.
+BY MR. EDWARDS:
+Q Okay. So if the testimony in this case by
+other witnesses has been that Mr. Epstein has these
+girls over at his house to give him a massage every day.
+then you would disagree with that testimony?
+MR. CRITTON: Form, improper question.
+THE WITNESS: Because there are times that I'm
+not there in the house.
+BY MR. EDWARDS:
+• Okay. Every day that you are there in the
+house and Mr. Epstein is also there, girls come over to
+his house to give him massages, as you understand it?
+MR. CRITTON: Form, leading.
+32
+heard about young girls or giris coming to Mr. Epstein's
+house for the purposes of giving him a massage?
+MR. CRITTON: Form.
+A Young girls? They're females, and I was told
+they come to do massages.
+1
+2
+3
+4
+5
+6
+7
+BY MR. EDWARDS:
+• Is that a fair statement?
+MR. CRITTON: Form, leading.
+MR.
+Also can we get a time frame?
+You mean now, or prior?
+BY MR. EDWARDS:
+• Between 2004 and the time that Mr. Epstein
+Q Who told you that?
+went to jail in 2008.
+A Alfredo.
+• Alfredo told you that the girls did massages?
+9
+10
+MR. CRITTON: Same objection.
+MR.
+¡ Do you understand the question?
+A He told me when I started there that there are
+THE WITNESS: No.
+massages to be done, and then that's when I heard it
+12
+BY MR. EDWARDS:
+first from him.
+13
+• Okay. Between 2004 and the time that
+Q And then did you witness the girls come over
+14
+Mr. Epstein went to jail in 2008, on occasions where you
+that you were told were there to give massages?
+15
+were in the house and Mr. Epstein was in town, is it a
+MR. CRITTON: Form. That she actually saw, is
+16
+fair statement that girls came over to give him a
+that what you're - let me just object to the form.
+117
+MR. EDWARDS: I said the word saw, so 1 mean,
+18
+massage every day?
+there's no, like, mixing words there. Yes, that
+19
+MR. CRITTON: Form.
+THE WITNESS: Between what year again?
+she actually saw.
+20
+BY MR. EDWARDS:
+MR. CRITTON: There's a distinction between
+21
+• When you started working and the time when
+seeing the girls coming and seeing the massages.
+22 Mr. Epstein went to jail.
+BY MR. EDWARDS:
+123
+MR. CRITTON: Same objection.
+• Did you see the girls come to the house?
+/24
+THE WITNESS: Yes.
+A Sometimes.
+25
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+ESQUIRE
+an Alexander Calle Company
+Suite 600
+
+
+2
+4
+7
+110
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+33
+BY MR. EDWARDS:
+Q All right. And when you were in the house and
+Mr. Epstein was also in town, would there be usually one
+massage per day, or two massages, or more?
+A Maybe three.
+Q Okay. So on a typical day when you were in
+town, you were in the house and Mr. Epstein was in town,
+it's your testimony that he would have an average of
+three massages a day?
+A Not average. I'm - I want to correct that.
+Q Correct it, please.
+A What's this, average? Can you...
+Q Okay. I think I see what you're saying.
+Some days there would be two and some days
+there would be three, and you don't want to commit to an
+average?
+A Yes. Because sometimes I'm not aware, I'm in
+the staff house.
+• Okay. All right. I understand what you're
+sayıng.
+But the days when you are in the house and
+Mr. Epstein is there, you see days when there are two
+massages per day and some days when there are three
+massages per day?
+A Yes.
+34
+Q All right. And these people that are coming
+over that you were told by Alfredo Rodriguez are there
+to give Mr. Epstein a massage, isn't it typical that
+they would arrive by taxicab?
+MR. CRITTON: Form, leading.
+THE WITNESS: I did not know about that.
+BY MR. EDWARDS:
+Q Do you know how any of these -- one more
+question before i ask the next one.
+Are they always female masseuses?
+A Yes.
+Q And are you aware of how these female
+masseuses would arrive to Mr. Epstein's house between
+the time you started working and the time he went to
+jail?
+No. Because I'm inside the house.
+• Okay. Can you describe these females for us?
+MR. CRITTON: Form.
+THE WITNESS: I don't pay attention to their,
+what's this, because I just do my job, open the
+door if I'm - what's this, I hear the doorbell
+rang.
+BY MR. EDWARDS:
+• Okay.
+A So I don't, like, really pay attention to,
+ESQUIRE
+an Alexander Galla Compaay
+1
+2
+3
+4
+5
+6
+7
+8
+10
+111
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+4
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+122
+23
+24
+25
+35
+what's this, to their appearances or to their what their
+attire is.
+• All right. Haven't you made a comment to
+Alfredo Rodriguez in the past that these girls that are
+coming over to give massages are too young?
+MR. CRITTON: Form.
+THE WITNESS: I cannot remember.
+BY MR. EDWARDS:
+• Isn't that something that you have believed?
+MR. CRITTON: Form.
+THE WITNESS: What you mean, believe?
+BY MR. EDWARDS:
+• Isn't that something that you have thought in
+your head, these girls that are coming over to the house
+that are supposedly giving Mr. Epstein massage are too
+young?
+MR. CRITTON: Form.
+THE WITNESS: At my age, these people are
+young to me, so...
+I'm past sixty, so they are young.
+BY MR. EDWARDS:
+Q Well, haven't you also made the statement to
+Mr. - we'll come back to that statement.
+When these girls would come in the house, you
+said sometimes you would answer the door, right?
+36
+MA. CRITTON: Form.
+BY MR. EDWARDS:
+Q And you would see these --
+MR. CRITTON: Wait. Can I just...
+If you use the word "female," I'm not going to
+object to most of your questions, as opposed to
+"girls," because I don't know what you mean by
+that. So I'm going to keep objecting.
+Whatever you want, | just...
+MR. EDWARDS: Yeah, I know. I'm just talking
+about the girls that would come over to give
+massages.
+MR. CRITTON: if you want to call them
+females, I have no objection. If you call them
+girls, I don't know what that means. Females, I
+do.
+MR. EDWARDS: Okay.
+MR. CRITTON: I'm not telling you how to do
+it, I'm just telling you -
+MR. EDWARDS: No, no. I appreciate it.
+BY MR. EDWARDS:
+• The females that would come over to give
+massages, often times you would answer the door when the
+door rang?
+A Sometimes.
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+1
+5
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+3
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+37
+Q Okay. And sometimes who else would answer the
+door?
+A Alfredo.
+• And what door would the females enter through?
+A The kitchen door.
+• And is that the door that other guests would
+also enter through?
+A Sometimes.
+• Why was that door chosen as the door for the
+female masseuses to enter through, do you know?
+A No, I don't.
+• What would happen, what would be the next step
+as these females would enter through the kitchen door?
+A I don't know, because I just let them and then
+go finish my work.
+Q Okay. And then would their next contact be
+with
+MR. CRITTON: Form.
+THE WITNESS: If I see
+1. then yes. But I
+just iet them stay in the kitchen and then go to
+the staff house and continue the laundry.
+BY MR. EDWARDS:
+Q Isn't it your understanding that these females
+were on a schedule as to when to come over to give
+Mr. Epstein a massage?
+39
+1
+2
+that rotated, we're talking about fifty, a hundred, two
+hundred different females that you saw?
+MR. CRITTON: Form.
+THE WITNESS: I did not count.
+5
+BY MR. EDWARDS:
+• You saw a lot of different female faces that
+were supposedly there to give him a massage, right?
+MR. CRITTON: Form, leading.
+110
+THE WITNESS: Sometimes the same female comes
+back, so..
+|11
+12
+BY MR. EDWARDS:
+• And other times it would be different females?
+113
+A Yes.
+14
+• All right. And can you approximate the age of
+115
+these females that would come over to the house?
+/16
+MR. CRITTON: Form.
+/17
+18
+THE WITNESS: I did not ask their age.
+BY MR. EDWARDS:
+19
+• You saw their face and you saw their
+20
+appearance. Would you be surprised if some of these
+/21
+females were thirteen years old?
+22
+MR. CRITTON: Form. You're asking her to
+speculate and guess.
+THE WITNESS: I did not see any thirteen years
+25
+old.
+38
+40
+MR. CRITTON: Form.
+BY MR. EDWARDS:
+THE WITNESS: No, I don't know.
+BY MR. EDWARDS:
+2
+3
+@ Okay. Would you be surprised if some of these
+girls were fourteen years old?
+Okay. Well, each time that the girls would
+MR. CRITTON: Same objection.
+come over to give Mr. Epstein a massage, he would be up
+5
+THE WITNESS: Fourteen? I don't know.
+in his master bedroom already; is that correct?
+BY MR. EDWARDS:
+MR. CRITTON: Form.
+• Could they have been fifteen years old?
+THE WITNESS: I don't know.
+BY MR. EDWARDS:
+10 0
+MR. CRITTON: Same objection.
+THE WITNESS: Maybe more than that.
+Q In the period of time between 2004 when you
+10
+BY MR. EDWARDS:
+started working and when Mr. Epstein went to jail, can
+/11
+• Maybe more than that?
+you aproximate or estimate the number of these females 13
+A Yeah.
+that would come over to Mr. Epstein's house to allegedly
+But maybe less than that?
+give him a massage?
+14
+MR. CRITTON: Form.
+A No.
+15
+THE WITNESS: I don't know.
+• Are we talking more than fifty, more than a
+16
+BY MR. EDWARDS:
+hundred?
+17
+Q The truth is, you don't know how old these
+MR. CRITTON: Form.
+18
+females were, but these females that were there to give
+THE WITNESS: I did not count.
+19
+BY MR. EDWARDS:
+20
+him a massage were young, in your mind?
+MR. CRITTON: Form.
+Q But there were many different girls, right?
+21
+THE WITNESS: Some look young, but then they.
+MR. CRITTON: Form.
+22
+what's this?
+THE WITNESS: Many females.
+123
+BY MR. EDWARDS:
+BY MR. EDWARDS:
+24
+Q It was not like there were only ten females
+• You knew that something that was going on
+/25
+there was not right, isn't that true?
+ESQUIRE
+ao Alexander Galle Company
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+2
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+41
+MR. CRITTON: Form, argumentative.
+MR. EDWARDS: Jack, we're catching some music
+coming over.
+(Brief recess in proceedings.)
+BY MR. EDWARDS:
+Q As you saw these young females coming over to
+Mr. Epstein's house to give him a massage, you knew in
+your heart of hearts that something was wrong?
+MR. CRITTON: Form, argumentative.
+THE WITNESS: I was told that they're going to
+do a massage.
+BY MR. EDWARDS:
+• I realize you were told that. Okay. Isnt it
+true that each of these girls was then led upstairs to
+Mr. Epstein's bedroom; that was the routine, right?
+MR. CRITTON: Form, predicate.
+THE WITNESS: I don't know. When I'm there,
+then I -- most of the time I just go to the, what's
+BY MR. EDWARDS:
+• When the girls would arrive - when the
+females would arrive, you would go to the staff house?
+MR. CRITTON: Form.
+THE WITNESS: First sometimes I would offer
+them drinks, and then, what's this.
+42
+1
+3
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+119
+20
+21
+22
+23
+24
+25
+BY MR. EDWARDS:
+Q All right. So did you talk to some of these
+females?
+A No. Just like you care for water or some
+drinks, soda or something.
+Q All right. Did you ever discuss religion with
+any of these females?
+A No, sir.
+• When these females would go upstairs, how long
+would each typically stay upstairs with Mr. Epstein?
+MR. CRITTON: Form, predicate.
+THE WITNESS: I don't know, but I was told by
+Alfredo that it would take one hour.
+BY MR. EDWARDS:
+Q All right. And when the females would leave,
+wasn't one of your responsibilities to clean the room
+where the massage took place?
+A Yes, sir, to tidy.
+Q To tidy?
+MR. CRITTON: Form.
+BY MR. EDWARDS:
+• And in doing so, isn't it true that many times
+after these females left, you found vibrators and sex
+toys scattered on the floor and in the room?
+MR. CRITTON: Form.
+ESQUIRE
+an Alexander Galle Company
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+119
+20
+121
+22
+23
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+122
+23
+/24
+25
+43
+THE WITNESS: I did not find any sex toys.
+BY MR. EDWARDS:
+• You never, in your employment with
+Mr. Epstein, found sex toys in the room after these
+females left from giving him a massage?
+A There was only this, like I thought it was for
+massage. That's it, that's what I saw.
+Q Okay. Have you ever - are you familiar with
+the armoire that is in Mr. Epstein's room, bedroom?
+A Yes
+• And have you ever put items away in that
+armoire?
+A No, sir.
+Q If Alfredo Rodriguez testified that you and he
+had a conversation about the sex toys in Mr. Epstein's
+bedroom and your comment being it's not right --
+A No, sir.
+Q That's not something you would agree with?
+A We did not converse about sex toys.
+• Have you talked to Mr. Epstein today about you
+having your deposition today?
+A No, sir.
+• And this is your attorney who is here next to
+you?
+A Yes, sir.
+44
+• And is that somebody that you paid to be your
+attorney?
+A No, sir.
+• That's somebody that Mr. Epstein has paid to
+be your attorney?
+A Yes.
+• When you were hired, did you sign any
+agreement of confidentiality that you wouldn't talk
+about the matters that happened within the house?
+A Yes, sir.
+• When did you sign that agreement?
+A When I received papers to sign for like my
+evaluation, all the forms needed for employment, like
+tax forms.
+Q Okay. And do you have a copy of that
+agreement?
+A Maybe in my house.
+• That's something that you think was provided
+to you, or was the only copy kept with Mr. Epstein or
+Ms. Maxwell?
+A We were given duplicate, duplicate copy.
+• Well, let me tell you that I represent three
+girls that in this case are L.M., E.W., and Jane Doe,
+who were three of the girls that you and I have been
+talking about as females that went to Mr. Epstein's
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+45
+house to give him massages. Okay. Would it surprise
+you to know that when they went to his house they were
+as young as thirteen, fourteen, and fifteen years old?
+MR. CRITTON: Form.
+THE WITNESS: I didn't know, sir.
+MR. CRITTON: Asked and answered.
+BY MR. EDWARDS:
+Q Would it surprise you to know that once inside
+his bedroom, he instructed them each to get naked?
+A I did not.
+MR. CRITTON: Let me just object to the form.
+You're asking her to speculate on something she
+knows nothing about. It serves no purpose. It's a
+great argument, but it serves no purpose.
+line of questioning, you do this every time in
+MR. CRITTON: But it serves no purpose, it's
+never going to be admissible whether she's
+surprised or not. It's like saying, you know,
+would it - well, never mind.
+You know, would it surprise you that the
+Afghan election --
+MR. EDWARDS: Are you trying to make this line
+of questioning go on longer?
+46
+1
+2
+3
+4
+5
+6
+MR. CRITTON: No. But it's just painful. Ask
+her stuff that she knows.
+MR. EDWARDS: I know it's painful.
+MR. CRITTON: I could care less one way or the
+other. It's just a waste of both our times, Brad.
+MR. EDWARDS: You're getting paid for it. No
+defense attorney ever makes this argument on the
+record.
+9
+MR. CRITTON: You know what, I get paid by a
+10
+lot of people, and I don't need to do frivolous
+11
+things in my mind, I'd rather just go home.
+12
+THE WITNESS: I don't know.
+13
+MR. EDWARDS: Okay.
+14
+MR.
+: Do you understand the question?
+15
+THE WITNESS: Yeah. I do not know anything
+16
+about that part.
+17
+MR. CRITTON: From the last time I objected,
+18
+can you just mark that, I want that two pages
+19
+marked so I can get that somehow separate and
+20
+apart.
+21
+THE COURT REPORTER: Okay.
+22
+BY MR. EDWARDS:
+23
+Q Would it come as a surprise to you that
+24
+Mr. Epstein used sexual devices such as vibrators on
+25
+each of my clients when they were fourteen or fifteen
+ESQUIRE
+an Alesander Galle Company
+47
+1
+years old?
+2
+MR. CRITTON: Form.
+3
+THE WITNESS: I do not know about that.
+4
+BY MR. EDWARDS:
+Q Okay. And after this line of questioning
+6
+related to things that happened in Mr. Epstein's bedroom
+that were actually not massages at all, does this help
+8
+to refresh your recollection as to the sexual toys or
+9
+devices that you have found in his bedroom?
+10
+MR. CRITTON: Form.
+11
+THE WITNESS: I only found one, that massage,
+12
+I thought it was a massage thing
+13
+BY MR. EDWARDS:
+• All right.
+A You know that thing, and then I thought it's
+for - that thing I only see.
+17
+MR. CRITTON: Just so the record is clear, I
+18
+think we all agree that she took her hand and
+19
+like -
+20
+MR. EDWARDS: She thought it was a back
+21
+massager.
+/22
+MR. CRITTON: Probably was a back massager.
+123
+24
+MR. EDWARDS: Give me a break.
+MR. CRITTON: No. You want to argue sex toys,
+25
+she's saying back massager. Just let her testify
+48
+as distinct from argumentative.
+MR. EDWARDS: I'm letting her testify.
+MR. CRITTON: Okay.
+BY MR. EDWARDS:
+Q The only thing that you found in his bedroom
+was in the shape of something that you believed to be a
+back massager, is that fair?
+A Yes, sir. Yes.
+• Okay. Who was the cleaning lady or
+110
+housekeeper prior to you, do you know?
+111
+A They have a cleaning crew.
+12
+• Prior to you?
+13
+A Yes.
+14
+• To your knowledge, has anybody ever left the
+15
+ouse, meaning left the employment of Mr. Epste
+16
+ecause of anything that was taking place in the houst
+117
+A No, sir.
+18
+• Have you ever thought of leaving the
+19
+employment of Mr. Epstein because of what was happening
+120
+21
+MR. CRITTON: Form.
+22
+THE WITNESS: No, sir.
+23
+BY MR. EDWARDS:
+24
+• Have you ever prayed for Mr. Epstein
+25
+because of what was happening -
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 500
+
+
+49
+1
+2
+3
+4
+5
+6
+A I pray for my co-employees and for my, what's
+this, employers.
+• Have you ever prayed for him related to these
+females that come over to the house?
+MR. CRITTON: Form.
+THE WITNESS: I just lift his name to God,
+that's it.
+8
+BY MR. EDWARDS:
+9
+• Have you ever prayed for the females that come
+10
+over to his house?
+11
+A I prayed for everyone.
+12
+Do you know what Mr. Epstein does for a
+13
+living?
+14
+A I was told that he's an investor.
+15
+Q
+16
+Who told you that?
+A Coworkers.
+17
+• Which coworkers?
+18
+A Lyn and Jojo.
+19
+Q
+Did Lyn and Jojo --
+20
+A And Alfredo.
+21
+Q
+And Alfredo.
+22
+Did Lyn and Jojo ever tell you about
+23
+Mr. Epstein getting females over to the house in
+24
+New York for massages?
+25
+MR. CRITTON: Form.
+50
+1
+THE WITNESS: They have visitors, that's what
+I was told.
+3
+BY MR. EDWARDS:
+4
+5
+• Were you ever told that he gets massages by
+females similar to the manner in West Palm Beach?
+6
+MR. CRITTON: Form.
+7
+THE WITNESS: Yes.
+8
+BY MR. EDWARDS:
+9
+Q And who told you that?
+10
+A Lyn.
+11
+Q And did she say with what frequency --
+12
+A No, sir.
+13
+Q - he has females come over?
+14
+A No, sir.
+15
+Q You didn't continue the conversation after she
+16
+told you this?
+17
+A No. I just listen, and then she talks and
+18
+then that's it. We don't really, like, oh, no.
+19
+• So is it your testimony that you don't know
+20
+what happens in the bedroom behind closed doors with
+21
+Mr. Epstein and these females?
+22
+A No, sir.
+23
+MR.
+: One second. I want to make
+24
+sure you understand the question.
+25
+MR. CRITTON: Form.
+ESQUIRE
+an Alexander Calle Company
+1
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+16
+17
+/18
+119
+21
+/22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+8
+10
+/11
+112
+13
+/14
+15
+16
+17
+118
+19
+20
+21
+22
+23
+24
+25
+51
+THE WITNESS: Yes. I do not know what's
+happening inside.
+MR.
+¡ Okay.
+BY MR. EDWARDS:
+• Okay. And have you ever asked what is going
+on inside?
+A No, sir.
+• Is that something that you have chosen just
+not to find out about?
+MR. CRITTON: Form.
+THE WITNESS: I was told that he's going to
+have a massage.
+BY MR. EDWARDS:
+Q Is that something that you believe?
+A That's what I was told, and what's this.
+• You're aware of the allegations against
+Mr. Epstein that each of these girls that was coming
+over to his house - each of these females that was
+coming over to his house was engaging in sexual activity
+with Mr. Epstein, right?
+MR. CRITTON: Form.
+THE WITNESS: Could you read the question
+back?
+(A portion of the record was read by the
+reporter.)
+52
+MR. CRITTON: Form.
+MR.
+Did you understand the
+question?
+THE WITNESS: Yes.
+MR.
+question?
+Yes, you understand the
+THE WITNESS: Yes.
+MR.
+: And i think the question was
+are you aware of the allegations.
+BY MR. EDWARDS:
+• Are you aware of the allegations?
+A Through TV news.
+Q Have you talked to anybody else about these
+allegations being made against your employer?
+A With Janusz.
+• When did you talk to Janusz about the
+allegations being made against your employer?
+A There is the scenario whenever I - what's
+this - I heard the news, it's oh, the boss is on the
+news. And that's it, to be honest.
+• And what would Janusz comment back to you, if
+anything?
+A Oh, he's in the news. So we did not really,
+like, talk about...
+• But it's one thing when your boss is on the
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+4
+5
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+4
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+53
+news and it's for accolades or for awards, it's another
+thing when your boss is on the news related to
+1
+2
+allegations that he is engaging in sexual activity with
+minor females. Wouldn't you agree with that?
+MR. CRITTON: Form, argumentative.
+THE WITNESS: Of course there's a difference,
+but...
+BY MR. EDWARDS:
+Q So did you talk to Janusz about the fact that
+there are allegations that he is engaging in sex with
+these minor females that are coming over to the house
+and you're told that they're giving massages?
+MR. CRITTON: Form, compound.
+THE WITNESS: Not really. Like we don't
+really discuss-discuss. We just oh, he's in the
+news, and then that's it, and I go to work because
+we're so busy, so...
+BY MR. EDWARDS:
+• Do you talk to your family or anybody else
+about -
+A No.
+Q Let me finish my question.
+- about the fact that many minor females have
+alleged that they have come over to Mr. Epstein's house 24
+and engaged in sexual activity with him in his bedroom
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+25
+54
+while they were under the age of eighteen?
+MR. CRITTON: Form.
+THE WITNESS: No.
+BY MR. EDWARDS:
+Q Are you aware now that your employer,
+Mr. Epstein, is a registered sex offender?
+A I heard about it.
+Q
+Does that bother you?
+A Sometimes, but I don't know if the allegations
+is true, so...
+Q Because you don't know what's going on behind
+closed doors, right, you have no idea?
+MR. CRITTON: Form, argumentative.
+BY MR. EDWARDS:
+Q I hear you.
+Have you ever asked your employer if the
+allegations being made against him are true or if they
+are not true related to his sexual activities with
+underage females?
+A No.
+Q Isn't that something that you, as a religious
+person, would want to know, whether that's true that
+that's what's going on in the bedroom every day while
+you're at work?
+A Sir, 1 go there to work, not to, what's this,
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+119
+20
+21
+|22
+23
+124
+125
+ESQUIRE
+55
+like pry on other personal activities.
+• Crimes are being committed against these girls
+on a daily basis while you're working. And
+hypothetically let's say you knew about it, would you
+report it?
+A If I knew about it, of course.
+• Sure. Like if you walked in on it, then would
+you report it?
+MR. CRITTON: Form.
+MR.
+: When you say it," do you mean
+a crime?
+BY MR. EDWARDS:
+Q Yeah. If you walked in on a crime?
+A A crime? Of course. If it's a crime, I will.
+• Okay. I'm going to ask you if you've ever
+witnessed certain acts. First I'm going to read to you
+directly from the Florida Statutes related to a crime
+called lewd and lascivious molestation. Okay.
+A All right.
+Q Florida Statute 794.021.
+MR.
+: Do you have a copy that she can
+read along with you perhaps?
+MR. EDWARDS: I don't have a copy, but I'll
+hand it to her as soon as l've read it.
+MR.
+I Thank you.
+56
+BY MR. EDWARDS:
+Q It reads as follows:
+A person who intentionally touches in a lewd
+and lascivious manner the breasts, genitals,
+genital area, or buttocks, or the clothing covering
+them of a person less than sixteen years of age, or
+forces or entices a person under sixteen years of
+age to so touch the perpetrator, commits lewd or
+lascivious molestation. An offender eighteen years
+of age or older who commits lewd or lascivious
+molestation against a victim twelve years of age or
+older but less than sixteen years of age commits a
+telony of the second degree.
+Have you ever observed - if you want to see
+the law, you can. Have you ever observed that crime
+committed in his house?
+A No, sir.
+MR. CRITTON: Form.
+What statute was that?
+MR. EDWARDS: It's 794.021, subsection five.
+MR. CRITTON: Thank you.
+BY MR. EDWARDS:
+• Subsection seven of that same statute, lewd
+and lascivious exhibition, indicates:
+A person who intentionally masturbates,
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+1
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+57
+intentionally exposes the genitals in a lewd or
+lascivious manner, or intentionally commits any
+other sexual act that does not involve actual
+physical or sexual contact with the victim in the
+presence of a victim who is less than sixteen years
+of age commits lewd or lascivious exhibition. An
+offender eighteen years of age or older who
+commits a lewd or lascivious exhibition commits a
+felony of the second degree.
+Have you seen that crime committed in
+Mr. Epstein's house?
+A No, sir.
+MR. CRITTON: Form.
+BY MR. EDWARDS:
+• Are you aware of the allegations by multiple
+female girls that allege that these are the crimes that
+were taking place behind closed doors when they were
+just minor females; are you aware of those allegations?
+MR. CRITTON: Form.
+MR.
+I Do you understand the question?
+MR. CRITTON: Asked and answered.
+MR.
+: Do you understand the question?
+MR. CRITTON: And argumentative.
+THE WITNESS: From the news, I heard that from
+the news.
+58
+BY MR. EDWARDS:
+Q And are you also aware that many of these
+girls did not know one another that were these female
+masseuses, are you aware of that?
+MR. CRITTON: Form.
+THE WITNESS: I dont know.
+BY MR. EDWARDS:
+• Okay. When these girls that would come -
+Where these females that would come over where
+you were told they were giving massages would come over,
+how many would come over at any time, meaning would they
+come over with twenty at time, or one at a time?
+MR. CRITTON: Form.
+THE WITNESS: Sometimes one at a time.
+BY MR. EDWARDS:
+• And given the number of these females that are
+making these allegations, doesn't it cause you to
+believe the allegations that there are so many of them
+and their stories are so strikingly similar as to what's
+taking place in Mr. Epstein's bedroom?
+MR. CRITTON: Form, predicate, speculation,
+argumentative.
+THE WITNESS: I don't know what's happening in
+the bedroom, I did not see anything that cause me
+alarm.
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+1B
+19
+20
+/21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+฿
+9
+110
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+ESQUIRE
+as Alexander Galle Company
+59
+BY MR. EDWARDS:
+• Have you ever worked for anyone that had this
+many young females come over to his house every day?
+A No, sir.
+• Have you ever heard anybody say that these
+girls are making this up or that this did not happen,
+these sexual acts did not happen in Mr. Epstein's
+bedroom?
+MR. CRITTON: Form, argumentative.
+BY MR. EDWARDS:
+• By that I mean Mr. Epstein, Ghislaine Maxwell?
+A No, sir. No.
+Q Did |
+ever say any of these girls
+were making this up?
+A No, sir.
+MR. CRITTON: Form.
+BY MR. EDWARDS:
+• So these girls are making these allegations,
+you work in Mr. Epstein's house?
+A Yes.
+• And you've never heard anybody deny these
+allegations, have you?
+MR. CRITTON: Form, argumentative.
+THE WITNESS: I do my job, we don't, like,
+talk.
+60
+BY MR. EDWARDS:
+• So is that a no, you've never heard anybody
+deny that?
+MR. CRITTON: Form.
+THE WITNESS: No, sir.
+BY MR. EDWARDS:
+• When was the last time you talked to
+Ghislaine Maxwell?
+A l answer the phone when she...
+• Okay. When you first started working there
+back in November of 2004, she was the person who you
+interviewed with, right?
+A Yes, sir.
+• Was she somebody who you would regularly see
+at the house during that period of time?
+A Not regular.
+Q
+How often would you see her in the house back
+in the late 2004, when you were hired, through 2005?
+A Three times.
+Q Three times a week?
+A No. During the period of that I was there.
+• Okay. During the entire five-year period you
+were there you only saw Ghislaine Maxwell three times?
+A Not five years.
+Q Okay. From the end of 2004 through 2005 you
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+3
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+61
+saw her three times?
+A Yes, sir.
+Q During --
+A Maybe more or less three times.
+• During 2006 how often did you see her?
+A 2006? He was in New York, so I saw her.
+Q You worked for Jeffrey Epstein but you worked
+in New York? I'm sorry.
+A I saw Ms. Maxwell in New York.
+Q I think I understand. Primarily, though, you
+were still working at the 358 El Brillo location?
+A Yes.
+Q However, at some point in time that year you
+took a trip to the New York house and you saw her there?
+A In her house.
+Q In Ghislaine Maxwell's house?
+A Yes.
+Q What was the occasion for you to go see her up
+there?
+A Lyn was having I think surgery.
+Q And when was that?
+A I cannot recall the month, but it's I think
+2006.
+Q So this is after the criminal investigation
+into Mr. Epstein, or before, if you remember?
+62
+MR. CRITTON: Form, predicate.
+THE WITNESS: 2006? After.
+BY MR. EDWARDS:
+• Okay. And while you were up there with
+Ghislaine Maxwell, did you talk to her about the
+criminal investigation of Mr. Epstein?
+A No. sir.
+Q At any point in time when you were up there,
+did she say to you or you overheard - let me ask you
+this way: Did she say to you that the allegations are
+false --
+MR. CRITTON: Form.
+BY MR. EDWARDS:
+• - that are being made against him?
+MR. CRITTON: Form. There's no predicate that
+a discussion ever took place about anything.
+THE WITNESS. There was no discussion about 1s
+MR. EDWARDS: Mr. Critton, if you could just
+object to the form. Obviously this witnesses just
+takes your words and she's going to recite them to
+me. If you want to say lack of predicate, okay,
+fine. But to say no discussion took place and then
+she says no discussion took place, we're leading
+the witness here, it's obvious.
+1
+3
+4
+8
+9
+10
+111
+12
+13
+14
+15
+17
+18
+19
+20
+21
+22
+/23
+24
+25
+1
+2
+3
+4
+63
+MR. CRITTON: But if you just asked her, say
+did you ever have a discussion with her about it,
+if she says yes, then we'll find out what it is.
+If she didn't have one, why ask the question?
+Go ahead.
+THE WITNESS: There was no discussion.
+MR.
+¡ There's no question pending.
+Wait for Mr. Edwards to ask his question and answer
+the question if you understand it.
+BY MR. EDWARDS:
+• How long were you at Ghislaine Maxwell's house
+this time that you visited her in 2006?
+MR. CRITTON: Form.
+THE WITNESS: I cannot remember, because I
+go..
+BY MR. EDWARDS:
+Q Back and forth?
+A Yes.
+• From West Palm Beach to New York?
+A Yes.
+• Why were you up in Ghislaine Maxwell's house
+in New York?
+A. I help over there when she has a party.
+• Okay. And then after the party you would
+return to West Palm Beach?
+64
+A Yes.
+• While you were up there, during any of the
+times that you were up there, did you have any
+conversations with Ghislaine Maxwell?
+A I think once. But it was oh, and what's this,
+it was just oh, I'm sorry about the bad news. That's
+it.
+Q You said that?
+9
+10
+11
+12
+13
+14
+115
+16
+A Because we have only, like, short
+conversation, we just don't really, like, talk-talk.
+Q When you're saying that a statement was made
+I'm sorry about the bad news, who made the statement to
+whom; she made it to you, or you made it to her?
+A She made it. But that was - I really cannot
+remember how it was how, but it was, like, I'm sorry
+about the news.
+• Okay. What news was she referring to when she
+said to you I'm sorry to hear about the bad news?
+119
+20
+A She not say anything. I just - I do not say
+anything about what the bad news is.
+21
+• Okay. I guess what I'm asking is did you have
+22 a death in the family or something happen to you
+24
+25
+personally? Or why would she say this to you, it you
+know?
+A No.
+ESQUIRE
+an Alexander Callo Company
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+2
+3
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+65
+Q You have no idea why she said that statement?
+A I think that it was about the news that was
+going on about Mr. Epstein.
+MR. CRITTON: Move to strike as speculation.
+BY MA. EDWARDS:
+Q And did she elaborate on the news about
+Mr. Epstein?
+A No, sir.
+Q During that conversation where she makes a
+statement that she's sorry about the news, did she ever
+tell you that the allegations being made against him are
+false or unfounded or untrue?
+MR. CRITTON: Form.
+THE WITNESS: Our conversation was short.
+BY MR. EDWARDS:
+Q So the answer is no?
+A No.
+Q What is your understanding of
+Ghislaine Maxwell's role in Jeffrey Epstein's life back
+in 2004 and 2005 and 2006?
+MR. CRITTON: Form.
+THE WITNESS: She told me he was his boyfriend
+(sic).
+BY MR. EDWARDS:
+Q Ghislaine Maxwell told you that
+66
+1
+4
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Jeffrey Epstein was her boyfriend?
+A When I was hired.
+• And then over the next year and a half when
+Jeffrey Epstein was in West Palm Beach, you only saw
+Ghislaine Maxwell at the house approximately three
+times?
+A Yes, sir.
+• Did you still believe that Ghislaine Maxwell
+and Jeffrey Epstein were boyfriend and girlfriend?
+MR. CRITTON: Form.
+THE WITNESS: At that time or what time?
+BY MR. EDWARDS:
+• Yeah. Back then in 2004, 2005.
+A Yes.
+Q All right. Is it your understanding that they
+are still boyfriend and girlfriend today?
+A I don't know.
+Q Ghislaine Maxwell and Jeffrey Epstein, do they
+still talk to one another today?
+A I do not know, sir.
+Q What is the last time that you talked to
+Ghislaine Maxwell?
+A She called the house and I answered the phone.
+Q How long ago?
+A About a month ago.
+ESQUIRE
+an Alexander Callo Company
+1
+2
+3
+4
+5
+7
+8
+9
+10
+(11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+122
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+67
+Q What did she say when you answered the phone?
+A Oh, she was happy. I was happy to hear her
+voice. And then she said oh, she was also happy to -
+she was so nice on the phone.
+Q What did she say?
+A Oh, nice talking to you, Louella.
+Q Then did she ask to speak to somebody else?
+A To Mr. Epstein.
+• Aside from the telephone call one month ago,
+how many times has she called the house in the last
+year?
+A That was my only, what's this, my -- the time
+that I was answer the phone and it was Ms. Maxwell.
+• Do you know why she called Mr. Epstein?
+A I do not know, sir.
+Q Have you ever seen scheduling logs, either on
+a computer or on paper, with girls' names on it and
+numbers?
+A No. No, sir.
+• Have you ever seen the names of these females
+that are alleged to have been masseuses written on
+anything?
+A Yes, sir.
+Q What have you seen them written on?
+A I just saw names, and that's it.
+68
+• Just the names, or the telephone numbers as
+well?
+MR. CRITTON: Form.
+THE WITNESS: I cannot remember.
+BY MR. EDWARDS:
+Q Where did you see this?
+A We have like butler's pantry and there's a
+telephone there.
+Q Is this in the staff house or the main house?
+A No. The main house.
+• And do you know who wrote the names?
+A No, sir.
+• How do you know that these were the names of
+the females that were alleged to have been masseuses?
+A Because there is time.
+Q What do you mean, there is time?
+A Sometimes name and then the time, that's it.
+Q What does the time indicate?
+A I cannot remember.
+Q The time to you -- you know, I'm watching what
+you're doing, but the court reporter is not able to draw
+a picture of it. So I guess what I'm asking is you're
+saying there is -- on the left-hand side there is a
+name, and on the right-hand side corresponding to that
+name there is a time written down? Is that what you
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+2
+3
+4
+5
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+69
+indicated?
+A Yes.
+Q And that time is indicative of the appointment
+time when that female was supposed to be at
+Mr. Epstein's house?
+MR. CRITTON: Form.
+THE WITNESS: I really don't know if that's
+the one that indicate who is coming, I just see
+names there and then time.
+BY MR. EDWARDS:
+Q Describe for me what this book looks like, or
+what this piece of paper looks like.
+A Someplace there are like white paper we write
+the names, if I hear - if somebody receives a call, and
+then we write the name of the person and the time.
+Q It sounds like you've answered the phone for
+when one of these females has called?
+A Sometimes.
+MR. CRITTON: Form.
+BY MR. EDWARDS:
+Q How many times in the last five years have you
+answered the telephone when one of these females has
+called?
+MR. CRITTON: Form.
+THE WITNESS: I cannot remember.
+70
+BY MR. EDWARDS:
+Q All right. I asked this question that way
+because you said sometimes we take the message.
+A Yes.
+Q And when you say we, you're including
+yourself?
+A Yes.
+Q Okay. And when the female would call to
+schedule - I mean, when the female could call, what
+exactly would she say where you would write down a name
+and a time?
+A I don't know if - I just receive a call and
+then I get the message and write the name and the time.
+Q Okay. It's just a message from whom?
+A For Mr. Epstein.
+Q And who is the call that - the calls that
+you're referring to, who are they, who is calling?
+A They are female voices.
+• And are they asking to come over to give a
+massage, to work, to -
+A To work.
+• And what is the language that the females
+would typically use when they would call --
+MR. CRITTON: Form.
+ESQUIRE
+an Alesaader Gallo Company
+1
+3
+4
+5
+6
+9
+10
+11
+12
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+125
+3
+4
+5
+7
+9
+10
+11
+12
+113
+14
+15
+16
+/17
+18
+19
+20
+21
+/22
+/23
+24
+25
+71
+BY MR. EDWARDS:
+• - and you would answer the phone?
+A Again, can you...
+Q What would they say? Hi, this is Mary, I'd
+like to come work, is there a time available for me.
+I'm making this up. What would they say?
+MR. CRITTON: Form.
+BY MR. EDWARDS:
+Q If you know.
+A They just say the, what's this. The female
+will just -- tell Mr. Epstein I called.
+• Okay. Just tell him I called?
+A Uh-huh.
+• And you would write down the name of the
+person and the time the person called?
+A Yes, sir.
+;: When you get to a convenient
+breaking point.
+MR. EDWARDS: Let's break.
+(Brief recess in proceedings.)
+MR.
+- It may be obvious to us in the
+room, but it may not be apparent in the cold record
+that English is not Ms. Rabuyo's first language.
+So that's why I've interrupted a couple of times
+and asked her if she understands the question,
+72
+because it's apparent to me sometimes that her
+English isn't as eloquent as Mr. Edwards.
+BY MR. EDWARDS:
+• What is your first language, Ms. Rabuyo?
+A Visayan and Tagalog.
+Q Do you feel comfortable with taking this
+deposition in English; meaning do you understand my
+questions and are you giving me answers that are
+truthful and accurate?
+A Sometimes I have to ask you to rephrase
+because, you know.
+Q Okay. And when you've asked me to rephrase
+and I've rephrased the question, have you understood it
+and given me an answer that you feel is accurate?
+A Yes.
+• Okay. Did you ever talk to the police?
+A No.
+• Have you ever talked to the FBI?
+A No.
+• Were you ever asked to talk to the State
+Attorney's Office?
+A No.
+• Were you ever asked to talk to the United
+States Attorney's Office?
+A No.
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+73
+1
+2
+6
+7
+8
+9
+10
+11
+12
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+4
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+• Did you ever talk to any law enforcement type
+related to the Jeffrey Epstein criminal investigation?
+A No, sir.
+• Did you remain employed from November 2004
+through today continuously with Jeffrey Epstein?
+A Yes, sir.
+• Was it discussed as to how your employment
+would be altered, if at all, while Mr. Epstein was going
+to be either - while Mr. Epstein was going to be in
+jail or away from the house?
+A No, sir.
+• Did you know, did you have any prior warning
+before Mr. Epstein pled guilty and went to jail?
+A No, sir.
+• All right. So it was just one day he's there
+and the next day he's not, as far as you knew?
+A Janusz, we discuss it with Janusz, he received
+a call, and then oh, Mr. Epstein is coming so is how I
+know.
+Q I'm sorry. Maybe we miscommunicated there.
+You're saying that Janusz received a call that
+Mr. Epstein was coming to the house?
+A Your first question was?
+Q Were you made aware of the date or time period
+that Mr. Epstein would be going to court to plead guilty
+74
+to crimes and then going to jail so that he would no
+longer be at the house, were you made aware that that
+was going to take place?
+A Not directly.
+• Okay. Indirectly then, did you know that that
+was taking place?
+A No. Janusz and I talked, so...
+Q And what did Janusz tell you about Mr. Epstein
+going to court and after court he would be in jail and
+no longer at the house?
+A We really don't know when he's going there to
+jail or is going to court. It's just a discussion like
+oh, he's going to court or something, but the date and
+the time, no.
+Q I'm not concerned with the date and the time.
+I guess what I'm getting at just is were you told that
+there was going to be a time period he was going to be
+in jail?
+A
+No.
+Q All right. There was a period of time that
+was just over a year where Mr. Epstein was not in the
+house, that being from June 30th, 2008 through sometime
+in July of 2009; correct?
+A Yes.
+Q And do you know where he was during that time?
+ESQUIRE
+an Alezaader Callo Company
+75
+1
+A Yes.
+2
+• Where?
+3
+A In jail.
+4
+• How do you know that?
+5
+A Through Janusz or, what's this, through the
+6
+news.
+7
+• So you did you work at his house during the
+8
+time period --
+9
+A Yes.
+10
+• Wait until I finish.
+|11
+A Sorry.
+12
+• Did you work at his house during time period
+13
+when Mr. Epstein was in jail?
+14
+A I did.
+15
+• Did you see Mr. Epstein during that year time
+16
+period?
+17
+A No.
+118
+• What was your schedule during that year time
+119
+period that Mr. Epstein was in jail?
+20
+A Flexible. No. Wait. The time that he was in
+21
+jail?
+22
+• Right. June 30th, 2008 through sometime in
+23
+July. 2009.
+24
+MR.
+Do you understand the question?
+|25
+THE WITNESS: Yes.
+76
+2
+3
+4
+5
+6
+7
+8
+110
+|11
+12
+13
+14
+/15
+16
+17
+118
+19
+20
+21
+22
+23
+24
+25
+MR.
+Okay. Go ahead and answer it
+then.
+THE WITNESS: I usually come nine o'clock.
+BY MR. EDWARDS:
+Q And you would leave?
+A At 5:00 or 5:30.
+• And who else would be in the house during that
+year time period from June 2008 through July 2009?
+A Only Janusz and me; and the gardener, he
+passed away.
+Q Who?
+A The gardener.
+Q Jerome?
+A
+• Jerome.
+Q
+And you said he said passed away?
+A Yes.
+• When was that?
+A I remember right we came from New York, I
+cannot remember, but I remember when we came from
+New York, we attended his -- not burial, the ceremony in
+church.
+Q Do you know how he passed away?
+A Janusz told me that he has a heart attack or
+something.
+• Okay. But it wasn't on the property while he
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+110
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+77
+was working?
+A No.
+• During that year time period that Mr. Epstein
+was in jail, what did you do on a day-to-day basis when
+you were there from 9:00 to 5:00?
+A I clean the house, I made inventory of the
+linens, and what's this, started inventorying, making an
+inventory of the silverwares.
+• Okay. Did you talk to
+during
+that time period he was in jail?
+A Yes.
+Q
+And
+went to visit him in jail numerous
+times; are you aware of that?
+MR. CRITTON: Form.
+THE WITNESS: No, sir.
+BY MR. EDWARDS:
+• And did
+stay in the house during
+the time period where Mr. Epstein was in jail?
+A Yes.
+• Permanently, or did she fly in town and fly
+back somewhere else?
+A (Nodding head.)
+MR.
+You have to say yes or no.
+THE WITNESS: Yes.
+MR.
+Yes she flew in, or yes she
+78
+stayed permanently?
+THE WITNESS: Not for a longer period.
+BY MR. EDWARDS:
+• Okay. Who would she fly into town with, it
+anyone?
+A Alone. I don't know, because she just come to
+the house and that's how she's there. I didn't know who
+she came with.
+• Did she come to the house alone, she being
+MR.
+Again, we're talking during the
+time period when Mr. Epstein is in jail?
+THE WITNESS: Yes.
+MR.
+Thank you.
+THE WITNESS: So one time she came with male
+friend.
+BY MR. EDWARDS:
+• With a male friend?
+A Yes.
+• Do you know his name?
+A I forgot it.
+Q
+Was it Igor?
+A No.
+• Was it Story?
+A No.
+4
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+9
+10
+11
+12
+/13
+14
+15
+16
+/17
+18
+19
+20
+21
+22
+23
+24
+125
+ESQUIRE
+an Alexaader Callo Company
+79
+Q Was it somebody from New York?
+A What, you mean when he was jail?
+• When he was in jail.
+A Story.
+• It was Story?
+A It was Story.
+• This is Story Cowles? Do you know the last
+name?
+A I don't know his last name.
+• And when you say she came with a person, you
+mean she came to the house with a person named Story?
+A Yes.
+flew in with
+• And do you know if that person named Story
+from elsewhere?
+A I don't know.
+• And did Story stay at the house with
+A No, sir.
+• All right. So this is during the day he came
+over, Story came over and visited with
+A Visited? I think so.
+• Okay. Do you know the purpose for Mr. Cowles,
+or Story as you referred to him, meeting with
+at the house during the year time period
+when Mr. Epstein was in jail?
+80
+A No.
+• What did you watch them do together, if
+anything?
+A Do the computer.
+• All right. How many computers were there in
+the house during the year time period Mr. Epstein was in
+jail?
+A They have their own personal computers.
+Q Who is "they"?
+A If you're asking about
+and Story?
+• Right. They brought laptops with them, you're
+saying?
+A Yes.
+• Okay. For the period of time between
+November 2004 through June of 2008, when - sorry.
+Were you working at the house when the police
+executed a search warrant on the house?
+A No.
+Q You were not working at the house?
+A I wasn't.
+• Were you aware of a search warrant being
+executed on the house?
+A No.
+• Did you know that a search warrant was ever
+executed on the house at 358 El Brillo Way?
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+2
+3
+4
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+81
+A When I came back to report, that's how I
+leamed.
+• Elaborate on that for me. What do you mean,
+when you came back to report that's how I learned?
+A I reported in the afternoon, and then that's
+how I learned that the police came.
+Q All right. And when were you - you're now
+saying you came back to report and you learned that the
+police had already come to the house, right?
+A Yes, sir.
+Q Prior to that occasion, when was the previous
+time that you were at the house?
+A The day before.
+Q Okay. And the day before you left your shift
+at roughly five o'clock?
+A I cannot remember. I usually leave 5:00 or
+5:30.
+Q But sometime late in the afternoon?
+A Yes.
+• And as of that time, the day before the search
+warrant was issued, you had seen no police officers in
+or around the house?
+A No.
+• And then the next day you reported to the job
+at what time?
+82
+A The next day?
+Q The next day.
+A I report in the afternoon.
+Q Was there a reason why you reported in the
+afternoon?
+A Ms. Maxwell called me.
+Q When did she call you?
+A During that day, she said Louella, you can
+report in the afternoon.
+• She called you early in the morning?
+A Not early.
+Q Normally you would report to the house between
+eight and nine o'clock, right?
+A Yes, sir.
+Q So in order for you not to arrive at the
+house, she had to have called you before eight or
+nine o'clock, right?
+A Yes.
+• Okay. So approximately what time does
+Ms. Maxwell call you to tell you you can report to the
+house later on that day?
+A I cannot remember really the time.
+• Okay. What time did you actually report to
+the house?
+A After lunch, about - maybe after lunch.
+ESQUIRE
+aa Alexander Gallo Compaay
+1
+2
+3
+4
+5
+6
+7
+8
+9
+110
+11
+12
+13
+14
+15
+16
+/17
+18
+19
+120
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+18
+19
+20
+21
+22
+23
+24
+25
+83
+• So are we talking about the day the police
+went to Jeffrey Epstein's house you did not go in the
+morning, but you went after lunch and the police had
+already left?
+A Oh. No. When / went there nobody was there.
+no policemen were around.
+Q Who was at the house then?
+A Janusz, and Douglas, the architect.
+Q
+• Schoettle?
+A Yes.
+• And did you have a discussion with them?
+A No.
+• How did you know the police had been to the
+house?
+A Janusz told me.
+Q When?
+A When I arrive.
+• That's what I was asking you when I said did
+you have a discussion with them, meaning Janusz and
+Douglas.
+A Okay. Being because them -- with Janusz only.
+Q What did he say?
+A He said the police came and, what's this, took
+away some stuff.
+• Did he say what they took?
+84
+A He said pictures.
+Q Did he tell you which pictures?
+A No, sir.
+• Aside from pictures, what else did the police
+take, as Janusz told you?
+A He did not elaborate.
+Q All right. Prior to the police going to the
+house and taking pictures, do you remember seeing
+pictures around Mr. Epstein's house?
+A Yes.
+Q Do you remember seeing pictures of naked or
+nude females around Mr. Epstein's house?
+A Not around, in his closet.
+• In Mr. Epstein's closet you would see --
+describe what you would see related to females in
+pictures.
+A Some have topless.
+• Is this a big closet?
+A No. Not really big, it's just this big, not
+so big.
+• Okay. Were these pictures that could be seen
+by - strike that.
+Do you know of any other pictures of females
+that were confiscated by the police that did not come
+from Mr. Epstein's closet?
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+2
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+3
+5
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+85
+MR. CRITTON: Form.
+THE WITNESS: Nude picture?
+BY MR. EDWARDS:
+Q Any other pictures that were taken by the
+police that were not taken from his closet.
+MR. CRITTON: Form.
+THE WITNESS: One.
+BY MR. EDWARDS:
+• Where was that picture?
+A The hallway leading to the master bedroom.
+Q And what was that picture of?
+A It's like advertisement, small child.
+• A small child. When you say "small child,"
+what age range are you talking about?
+A Maybe four.
+• What is that child in that picture who is
+maybe four doing?
+A I cannot really, like -- I don't know what's
+this, but I think the underwear was (indicating), like
+pulled down.
+MR. CRITTON: Just for the record, she's
+pointing to her rear-end, derriere.
+BY MR. EDWARDS:
+Q So in this picture that was taken by the
+police or confiscated by the police, it was in the
+86
+hallway and it was of a child roughly four years old
+that was pulling down her underwear and exposing her
+buttock area; is that fairly accurate?
+A Yes. Not really full, just like slightly.
+that's what I remember.
+• Okay. Are there any other photographs that
+were confiscated by the police, to your knowledge?
+A No.
+• So how many photographs had you seen prior to
+the police going into Mr. Epstein's house in
+Mr. Epstein's closet?
+MR. CRITTON: Form.
+THE WITNESS: Less than ten.
+BY MR. EDWARDS:
+• Okay. So there were less than ten photographs
+in Mr. Epstein's closet that you remember?
+A Yes.
+• And what were those photographs of, these less
+than ten?
+A Half nude women.
+Q Do you know the ages of those women?
+A No, sir.
+• Do you know the approximate ages of those
+women in those photographs?
+A No.
+ESQUIRE
+aa Alexander Galle Compasy
+1
+2
+10
+11
+12
+13
+14
+15
+16
+17
+118
+19
+20
+21
+22
+23
+124
+25
+2
+4
+10
+11
+12
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+87
+MR. CRITTON: Form.
+BY MR. EDWARDS:
+Q You were able to tell me the approximate age
+of the child in the photograph, but you're unable to
+tell me the approximate age --
+A It was just a guess for four, because I could
+hardly, like, tell the age. It was just maybe four,
+because...
+Q Okay. Was there anything else in the house
+that you were told was taken by the police?
+A No, sir.
+Q Prior to the day when the police came to the
+house, how many computers did Mr. Epstein have in his
+house?
+MR. CRITTON: Form, predicate.
+THE WITNESS: One - three.
+BY MR. EDWARDS:
+• Where were those three computers located?
+A In the cabana, in one of the desks, and one in
+the little office.
+Q And after the police came to the house do you
+remember seeing those computers any more?
+A No. I really did not focus on what was
+missing, only the picture that was big, and in the
+bedroom.
+88
+• Okay. But you're aware, as you told me, that
+there were these computers -
+A Yes.
+Q Let me finish.
+A Sorry.
+Q You where aware, as you told me, that there
+were these computers that you described as being three
+computers in Mr. Epstein's house, right?
+A Yes, sir.
+Q And do you know whether those were taken out
+of Mr. Epstein's house by Mr. Epstein or somebody
+associated with Mr. Epstein, or by the police?
+A I'm not aware.
+• So to the best of your knowledge, the police
+look less than ten photographs from Mr. Epstein's house,
+and that should be all of the evidence or objects that
+were taken by the police from Mr. Epstein's house, to
+your knowledge?
+MR. CRITTON: Form, predicate.
+THE WITNESS: I don't know.
+BY MR. EDWARDS:
+Q I'm only asking what you do know.
+To your knowledge, what you described to me
+as - 1 just want to know a list of all the things that
+you know were taken by the police. And you've described
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+89
+to me I believe one photograph of this four-year-old
+child as well as less than ten photographs that were
+previously in Mr. Epstein's closet.
+A Yes.
+MR. CRITTON: Form.
+BY MR. EDWARDS:
+• Is there anything else that you know was taken
+by the police?
+A No.
+Q Since Mr. Epstein has been out of jail, I
+guess this is since July of 2009, what has your schedule
+been?
+A My schedule has changed.
+Q To what?
+A From 6:00 to 3:30.
+Q 6:00 a.m.?
+A Yes, sir.
+• And why the schedule change?
+A Because I was chosen to give breakfast.
+Q To whom?
+A Mr. Epstein.
+Q By whom?
+A Because it was Janusz was there usually gives
+the breakfast, but there was a change, it was me.
+Q Okay. You don't know why that change
+90
+1
+2
+7
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+occurred?
+A
+No.
+• Well, do you know why that change occurred?
+A Because so that somebody - because Janusz has
+to stay later, so...
+| Every morning now you serve breakfast to
+Mr. Epstein?
+A Yes, sir.
+Q So that's why you're required to be there at
+6:00 a.m. Is that what time he eats?
+A 6:30,
+• Tell me since Mr. Epstein has been out of jail
+and back at the house, what other people have frequently
+visited and/or stayed at house?
+A Who?
+Q
+Who.
+A
+Story.
+Q
+And where does Mr. Epstein sleep in the house
+since he's been out of jail?
+A Where? In the master bedroom.
+• All right. And where does
+sleep?
+A I'm not aware if -- I did not see if they
+sleep together or...
+Q
+Well, you tidy up the house the following day,
+correct?
+ESQUIRE
+an Alessader Gallo Company
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+/11
+12
+13
+14
+15
+/16
+17
+18
+119
+120
+21
+22
+23
+|24
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+110
+11
+112
+13
+114
+15
+116
+117
+18
+19
+20
+21
+22
+23
+24
+25
+91
+A Yes.
+• So you know what bedrooms need to be tidied up
+and look like someone slept there?
+A Yes.
+• And does it appear that
+slept in the
+same bedroom as Mr. Epstein, or some other bedroom?
+A Sometimes the other bedroom is also, like,
+slept in.
+• Okay. So sometimes --
+A Sometimes one bed is the master, and sometimes
+the other, what's this, is slept in.
+• What is your understanding of the relationship
+between
+and Mr. Epstein?
+A Relationship?
+• Yeah. What is your understanding of
+role in Mr. Epstein's life?
+MR. CRITTON: Form.
+THE WITNESS: She did not tell me that. She's
+his girlfriend, so she stays there, so...
+BY MR. EDWARDS:
+• She didn't tell you, or she did?
+A She did not.
+Q She did not tell you.
+How long has
+been around Mr. Epstein, to
+the best of your memory?
+92
+A Since a few months I started working there.
+• Okay. So that's late 2005 you're talking
+about, or 2004? Sorry.
+A 2005, I think.
+MR. CRITTON: 2005?
+MR. EDWARDS: She said 2005.
+MR. CRITTON: Okay.
+BY MR. EDWARDS:
+• And what was your understanding back then why
+she was at the house with Mr. Epstein?
+A Understanding? I thought she is his
+girlfriend.
+• Ghislaine Maxwell, when she hired you or
+interviewed you, told you that she, Ghislaine, was
+Mr. Epstein's girlfriend, right?
+A Yes.
+• And then a month or two after you began
+working at Mr. Epstein's house
+is also around the
+house and you believed that she was Mr. Epstein's
+girtfriend?
+A I want to - before 1 did not know that, she
+was just a visitor.
+• Okay. When was it that you started, you were
+led to believe, or based on your observations you
+believed that
+was a girlfriend of Mr. Epstein?
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+93
+A 2006. No. Wait. When he was in jail.
+• All right. When Mr. Epstein was in jail
+between June 2008 and July of 2009 is the first time
+that you began to believe that
+was a girlfriend of
+Mr. Epstein?
+A Yes. That's just my own, but she did not tell
+me that she's the girlfriend.
+Q Did anybody tell you that?
+A No.
+Q Prior to that period of time when Mr. Epstein
+was in jail, what was your understanding as to
+relationship to Mr. Epstein or role in Mr. Epstein's
+life?
+A A friend.
+Q What did she do when she was at the house
+prior to Mr. Epstein going to jail,
+what did
+do?
+A What did she do?
+Q
+What did
+do around the house prior to
+Mr. Epstein going to jail?
+A Go shopping.
+Q Anything else?
+A That's what I know only.
+Q Do you remember a person named
+94
+1
+2
+3
+4
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A Adriana?
+Q Yes.
+A I remember a name Adriana, but the family
+name, no.
+And what did Adriana do at Mr. Epstein's
+house, if anything?
+A Alfredo told me that Adriana is a personal
+assistant.
+Q Similar to
+A Yes.
+Q Was there anything that you observed that
+would distinguish
+from Adriana in terms of
+the role that they played in Mr. Epstein's life?
+A Not really.
+• Is that somebody who you believe scheduled
+Mr. Epstein for massages with the females, Adriana?
+A I don't know.
+Q And were you ever told that by anybody that
+was also involved in sex acts with minor temales
+at Mr. Epstein's house?
+A No.
+MR. CRITTON: Form.
+BY MR. EDWARDS:
+• Am I the first person that has said that in
+your presence?
+ESQUIRE
+an Alexander Gallo Company
+1
+10
+11
+12
+(13
+14
+15
+16
+17
+18
+19
+/20
+21
+22
+/23
+24
+25
+1
+2
+3
+4
+5
+8
+10
+/11
+112
+13
+14
+15
+16
+117
+18
+19
+120
+/21
+122
+23
+24
+25
+95
+A Yes.
+• Have you ever been told that
+was
+purchased from her family by Mr. Epstein?
+A No.
+Q Have you ever been told that
+serves as a
+lesbian sex slave for Jeffrey Epstein?
+A No.
+• Since Mr. Epstein has been out of jail, you
+indicated that the frequent visitors are
+and Story; right?
+A Yes, sir.
+• And does Story stay at the house?
+A No.
+• How often is Story at the house?
+A Often. Like they come in the morning, they
+stay a few hours, then leave.
+• Who is "they"?
+and Story.
+• And is that on a daily basis?
+A Not always.
+• Do you know if
+or Story - do you know
+if
+is staying at Mr. Epstein's house now?
+A No.
+• You don't know, or she's not?
+A No, she's not.
+96
+• Do you know where she is staying?
+A Not now, no.
+• Do you know if she's staying with Story?
+A I don't know.
+• Do you know if Story is
+boyfriend?
+A Yes.
+• And is that the relationship between Story and
+. they're boyfriend and girlfriend, as you
+understand it?
+A Yes.
+• And do you know how it is that they met?
+A I don't know.
+Q Do you know how long they've been boyfriend
+and girlfriend?
+A No.
+• Do you know; have you witnessed Story talking
+with Mr. Epstein at Mr. Epstein's house?
+A Yes.
+• And where do those conversations take place?
+A In the breakfast room.
+• And when those conversations are taking place
+in the breakfast room between Story and Mr. Epstein, is
+also there?
+A There are times when she's there, there is
+times that she's not there.
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+1
+2
+3
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+5
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+97
+Q All right. So there are times that Story
+talks directly with Mr. Epstein in the breakfast room
+and it's just two of them?
+A Yes.
+Q All right. And there are times when Story
+talks with Mr. Epstein in the breakfast room and
+is also there?
+Yes.
+Q Are there times when
+is also involved in
+conversations where Story and Mr. Epstein are talking
+with one another in the breakfast room?
+A Yes.
+• Are there times when all four of them, that
+meaning
+Story, and Mr. Epstein, are all
+conversing together in the breakfast room?
+A Yes.
+• Have you overheard the conversations?
+A No.
+Q Do you know or have you been made aware of
+them talking about the allegations concerning
+Mr. Epstein and female masseuses?
+A No, sir.
+• Since Mr. Epstein has been out of jail in July
+of 2009, have you seen any females coming over to give
+Mr. Epstein a massage?
+98
+A No, sir.
+Q Do you know why that is?
+A I don't know, sir.
+Q Does
+, have you seen
+keeping a
+schedule of females or masseuses?
+A No, sir.
+Q Since July of 2009, has Jeffrey Epstein spent
+every night at the Palm Beach house, to your knowledge?
+MR. CRITTON: Form, predicate.
+THE WITNESS: 1 leave at 3:30, so...
+BY MR. EDWARDS:
+Q When you arrive every morning at 6:00 a.m.,
+has Mr. Epstein been there every day?
+A Yes, sir.
+Q Aside from
+and Story, have there
+been any other visitors that are regular visitors of
+Mr. Epstein since he's been out of jail?
+A Some female friends.
+Q Who would those people be?
+A
+Difficult names.
+Q
+who?
+A
+I don't know their...
+Q Do you know where she comes from?
+A No.
+Q And I don't mean her country of origin. I
+ESQUIRE
+as Alexander Gallo Company
+1
+2
+4
+5
+6
+7
+8
+9
+110
+11
+12
+13
+14
+15
+16
+117
+18
+19
+20
+21
+22
+23
+124
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+110
+11
+12
+113
+14
+15
+16
+17
+18
+119
+20
+21
+22
+123
+24
+25
+99
+mean do you know if she flies in from New York or flies
+in from LA, or where she lives down the street in
+Palm Beach?
+A No. She said she comes from New York.
+Q What does she do when she's in Palm Beach?
+A Go to the beach.
+• Did you know her prior to -- had you seen her
+prior to Mr. Epstein going to jail?
+A No, sir.
+Q Other than
+are there any other
+visitors that you have witnessed or observed?
+A Sultan.
+Q Who is that?
+A Sultan.
+• S-U-L-T-A-N?
+A Yes.
+• Is that a female?
+A A male.
+• Do you know what Sultan does?
+A No, sir.
+• Do you know why he's ever at the house?
+A No.
+Q How often is Sultan there?
+A I saw him two times.
+• And is that somebody that you saw prior to
+100
+Mr. Epstein going to jail?
+A No, sir.
+• So the first time you saw him was sometime
+after Mr. Epstein got out of jail?
+A Yes, sir.
+Q Any other visitors that you've seen since
+Mr. Epstein's been out of jail in July?
+A
+Q
+And who is
+A
+She's also a friend.
+Q
+A friend of whom?
+A
+Mr. Epstein.
+Q
+And where does she come from?
+A I did not ask her, I did not know.
+Q All right. Is it somebody that a driver has
+to go pick up from the airport, or she flew from
+somewhere?
+A Yes. Janusz.
+• Janusz picks these people up from the airport?
+A Yes, sir.
+MR. CRITTON: Form.
+BY MR. EDWARDS:
+• And when I say "these people," I'm talking
+about
+1. Sultan, and
+all are driven by
+Janusz to the house?
+Face: 61304-2621
+Suite 600
+
+
+101
+MR. CRITTON: Form.
+THE WITNESS: I did not see Janusz drive, but
+what's this.
+4
+5
+6
+7
+BY MR. EDWARDS:
+• But that's what you understand?
+A Yes.
+MR. CRITTON: Form, speculation.
+BY MR. EDWARDS:
+• Any other visitors?
+10
+A That's all I can remember.
+11
+• Do you know how old l
+is?
+12
+A She, what's this.
+13
+• Excuse me?
+14
+A I don't know her age, but she looks like,
+15
+what's this.
+16
+17
+• Did you say "what's this"?
+A What?
+18
+• I'm sorry. We're just I think
+19
+miscommunicating here.
+20
+A Okay.
+21
+• I was asking the age of the person that you've
+22
+described as
+23
+A I did not ask her age.
+24
+Q How do you know the names of
+_ Sultan,
+25 and
+102
+3
+5
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A What's this? Janusz.
+• Okay. Any other visitors aside from those
+three people that you have just listed, and the frequent
+visitors:
+, ап
+A That's all I can remember.
+Q Has Ghislaine Maxwell come to visit since
+Mr. Epstein's been out of jail?
+A No, sir.
+• Do you know if they frequently talk with one
+another?
+A I don't know, sir.
+Q Do you know what the relationship is or has
+been between Ghislaine Maxwell and Mr. Epstein?
+A No.
+MR. CRITTON: Form.
+BY MR. EDWARDS:
+• In the five years or so that you've worked at
+Mr. Epstein's house, what other persons besides
+Mr. Epstein have received massages from these females,
+from these female masseuses?
+MR. CRITTON: Form.
+THE WITNESS: I don't know.
+BY MR. EDWARDS:
+Q Do you know of any other visitors who have
+frequented Mr. Epstein's house that have also received a
+ESQUIRE
+an Alexander Galle Company
+103
+1
+massage from any of these females?
+2
+MR. CRITTON: Form.
+3
+THE WITNESS: I do not know.
+BY MR. EDWARDS:
+Q I'm just going to ask you if you can identify
+any of these people in this book. If you can, okay, if
+you cannot, it's fine.
+8
+MR. CRITTON: I want to mark those, please.
+9
+MR. EDWARDS: Well, if she can identify them
+10
+I'll mark them.
+11
+MR. CRITTON: No, no. I want them identified,
+12
+because if she can't identify them that's
+13
+significant to me as well. So can we mark those as
+14
+a composite?
+15
+MR. EDWARDS: I can mark them as a composite,
+16
+and we can either copy them here as black and white
+17
+or whatever.
+18
+MR. CRITTON: That's fine.
+19
+(Plaintiff's Exhibit No. 1 was marked for
+/20
+identification.)
+BY MR. EDWARDS:
+• Do you know who this is, have you ever seen
+23
+her before?
+24
+A No.
+25
+MR. CRITTON: And we'l call this Exhibit 1-A.
+104
+1
+2
+MR. EDWARDS: And then the next page will be
+"B;" "C," "D*?
+3
+MR. CRITTON: Yeah.
+4
+BY MR. EDWARDS:
+• What was your response?
+A No.
+• Never seen her before?
+A No.
+MR. CRITTON: Can you tell us who they are?
+/10
+MR. EDWARDS: Can I tell you?
+11
+MR. CRITTON: Yes.
+12
+13
+MR. EDWARDS: No.
+MR. CRITTON: Okay.
+14
+MR. EDWARDS: She may be able to tell you.
+BY MR. EDWARDS:
+• Have you ever seen her before?
+117
+MR. CRITTON: That's 1-B.
+18
+BY MR. EDWARDS:
+19
+• This is 1-B.
+20
+A No.
+21
+• That's not somebody that you recognize as
+22 anybody working on Mr. Epstein's staff, pointing at
+picture 1-B?
+124
+A No.
+125
+Q Okay. 1-C, is that somebody that you
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+1
+2
+4
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+3
+4
+5
+8
+110
+/11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+105
+recognize -
+A No.
+• - as anybody who has ever been to
+Mr. Epstein's house in the past five years?
+A No.
+• 1-D, do you know who that is?
+A No.
+Q You don't remember seeing her come to
+Mr. Epstein's house?
+A No.
+Q 1-E, do you know who that is?
+A No.
+• In the five years that you worked there, you
+never remember seeing her come to Mr. Epstein's house?
+A No.
+• Do you know who this is?
+A I remember this.
+• You remember her?
+MR. CRITTON: Are you talking 1-F?
+BY MR. EDWARDS:
+• Let's make sure we're right. 1-F.
+A Yes.
+• All right. When do you remember seeing her?
+A I cannot remember the dates, you know, but I
+remember seeing her.
+106
+Q Do you remember her name?
+A No.
+Q Does the name
+refresh your recollection
+as to who this person is?
+A
+?
+Q
+You remember a
+A
+I remember a name
+, but I don't know if
+that's
+• Okay. And where do you think that you saw
+this person?
+A In the house.
+Q Do you know why she was there?
+A No.
+• Is that one of the people that was giving a
+massage, or is that somebody else?
+A I do not know. I do not know.
+MR. CRITTON: I'm sorry.
+THE WITNESS: No, I do not see this.
+BY MR. EDWARDS:
+• 1-G, that's not somebody you remember seeing?
+A No.
+• 1-H, do you remember seeing that person?
+A No.
+Q This is a hard picture to decipher maybe, but
+do you remember seeing that face? And that's 1-l.
+ESQUIRE
+an Alexander Gallo Compasy
+107
+1
+A I cannot remember.
+2
+MR. CRITTON: This is 1-l now?
+3
+MR. EDWARDS: This is 1-l.
+4
+THE WITNESS: I cannot remember.
+5
+BY MR. EDWARDS
+6
+Q By that I mean you've been able to tell me no,
+7
+no, no, no, no. When you say I don't remember, does
+8
+that mean maybe you have?
+9
+A Maybe, because the eyes.
+10
+Q Okay. So that's somebody who may look
+11
+familiar to you but you don't know why?
+12
+A Yes.
+13
+Q Okay. Is that somebody you remember seeing at
+14
+Mr. Epstein's house; I mean, is that where the
+15
+familiarity comes from?
+16
+A Maybe.
+17
+• Okay. Do you recognize that person?
+118
+A That's
+19
+• And that's the person that you've been
+20 describing as
+throughout this deposition? When
+21 you've talked about
+, that's the person you're
+22 talking about?
+23
+A Yes.
+/24
+MR.
+:: What number are we on now?
+/25
+MR. CRITTON: "J."
+108
+1
+MR. MERMELSTEIN: "J."
+2
+MR. EDWARDS:
+is "J."
+3 BY MR. EDWARDS:
+4
+5
+• Do you know who that is, have you ever seen
+that person?
+6
+A Yes.
+• Where have you seen him?
+8
+A In the house.
+MR. CRITTON: This is "K' now?
+10
+111
+12
+13
+14
+/15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY MR. EDWARDS:
+Q This is 1-K.
+What have you seen him doing in the house?
+A He came with his family.
+• Every time that he's been in the house he's
+come with his family?
+A No, no, no. He came with his family to spend
+a week.
+• Okay. And did his family come to the house as
+well?
+A Yes. They stay there.
+• They stayed at the house?
+A This is Mr. Dershowitz?
+• Right. And how many times have you seen
+Mr. Dershowitz at the house in the time period that yo
+vere there
+Facsimile: 361. 394-3627
+Suite 600
+
+
+2
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+5
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+109
+A Two times.
+Q And one of the times he was with his family?
+A Yes.
+• And the other time is it safe to presume then
+that he was alone?
+A Yes.
+Q During the time that he was with his family.
+do you remember if Mr. Epstein received any massages
+from females?
+A No.
+Q You don't remember, or he did not?
+A Oh, he was there when Mr. Epstein was not in
+the house.
+Q Mr. Dershowitz and his family were in the
+house when Mr. Epstein was not in the house?
+A Yes. They spend a week there.
+• And Mr. Epstein was not in South Florida, you
+mean, not in Palm Beach?
+A No.
+MR. CRITTON: That's correct?
+BY MR. EDWARDS:
+Q That's correct, my statement is correct?
+A Correct.
+MR.
+So no, he was not in the house?
+THE WITNESS: He was not in the house.
+110
+1
+2
+3
+4
+8
+9
+10
+11
+12
+/13
+/14
+15
+16
+17
+18
+/19
+/20
+122
+/23
+24
+25
+BY MR. EDWARDS:
+Q So Mr. Dershowitz and his family were
+2
+occupying the house in Palm Beach, and during that
+3
+period of time Mr. Epstein was not staying at the
+4
+Palm Beach house?
+A No.
+Q That's correct?
+A I think he was in jail.
+8
+Q Oh, okay. This is a time period when
+9
+Mr. Epstein was in jail?
+110
+A (Nodding head).
+111
+Q That Mr. Dershowitz was at the house?
+12
+A Yes.
+13
+Q Okay. Other than that time period - there
+was another time period when Mr. Dershowitz was at the
+14
+/15
+house and he was not with his family?
+16
+A Yes.
+17
+• And how long ago was that?
+18
+A
+Oh. I cannot remember when.
+19
+Q All right. Was it before Mr. Epstein went to
+20
+jail?
+21
+A I think after.
+22
+• So you think again Mr. Epstein was not in the
+house. To the best of your memory, has Mr. Dershowitz
+123
+24
+been in the house at the same time Mr. Epstein has been 25
+ESQUIRE
+an Alexander Galle Company
+111
+in the house?
+A I cannot remember.
+• Do you know if Mr. Dershowitz has ever been in
+the house when the females would come to the house to
+give Mr. Epstein a massage?
+A I told you, I do not know.
+Q You don't remember that?
+A I don't remember that.
+• Okay. Do you know if Mr. Dershowitz has
+received a massage while staying at Mr. Epstein's house?
+A No.
+• You don't know?
+A I don't know.
+• Do you know who that is?
+MR. CRITTON: Let's get a letter now, or this
+is going to be a mess.
+MR. EDWARDS: Not really, they're all in
+order.
+MR. CRITTON: For the record, you're going how
+about this person, and nobody is going to know who
+you're talking about. This is "L."
+MR. EDWARDS: Yeah.
+BY MR. EDWARDS:
+• Who is 1-L?
+A 1-L?
+112
+Q Who is this?
+A Oh. That's Ms. Maxwell.
+• That's Ghislaine Maxwell?
+A Yes, sir.
+• That's somebody who you know?
+A Yes, sir.
+• And you've seen her at the house before?
+A Yes.
+• All right. And that's the same Ms. Maxwell
+that hired you into the position, correct?
+A Yes.
+• Do you remember seeing this person?
+A That's Igor.
+MR. CRITTON: "M."
+BY MR. EDWARDS:
+• This is 1-M.
+And how do you know Igor?
+A He's now in the house.
+• He's now in the house?
+A Yes.
+• But when we listed the people, I wanted you to
+list for me all of the people --
+A I forgot. I'm sorry. I forget igor.
+• Is there anybody else that you think you
+forgot?
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+113
+A I think this is the only one I forgot.
+• And what is his role in Mr. Epstein's life, if
+you know?
+A He's a driver and he is trainer.
+• Trainer?
+A (Nodding head).
+• What do you mean by that?
+A Because I saw him telling Mr. Epstein, one
+more lap.
+• One more lap where?
+A In the swimming pool. And he said he's a
+trainer.
+Q Who said he's a trainer?
+A lgor.
+• Igor told you that he's a trainer?
+A Yes.
+• Okay. Do you know who that is?
+A No.
+• Never seen her before?
+A Never.
+Q All right.
+MR. CRITTON: That's "N."
+BY MR. EDWARDS:
+Q That's "N."
+Do you ever remember a girl named
+114
+coming
+1
+2
+3
+4
+5
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+to the house?
+A
+? I heard|
+Q But you never remember seeing somebody in the
+house that somebody referred to as
+A No.
+I don't know their names if they come, I
+don't know their names.
+• But the name in this photograph, which is "N."
+you don't remember seeing her?
+A
+No, sir.
+• Do you know who that is?
+A Yes, sir.
+• Who is that?
+A My employer.
+• And that is Mr. Epstein?
+A Mr. Epstein.
+Q All right. So Mr. Epstein is "O?"
+A Correct.
+MR. CRITTON: Right.
+BY MR. EDWARDS:
+Q Do you know who that is?
+A I dont know.
+Q Do you remember Alfredo Rodriguez?
+A Oh. That's Alfredo? Oh, yes.
+• Now that you look at the photograph, does it
+look like Alfredo Rodriguez?
+ESQUIRE
+an Alesander Galle Company
+1
+2
+3
+4
+5
+6
+7
+9
+110
+11
+12
+13
+14
+15
+16
+17
+18
+19
+120
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+119
+/20
+121
+/22
+23
+/24
+25
+115
+A Because he aged.
+MR. CRITTON: He aged?
+THE WITNESS: He aged
+MR. CRITTON: Okay.
+And this is "P."
+BY MR. EDWARDS:
+Q This is "P."
+And this is, just so that you know, a fairly
+recent photograph of him, and you haven't seen him in
+how long?
+A After he left Mr. Epstein's employ.
+• So it's been numerous years since you've seen
+this person?
+A Yes.
+• So in fairness to you, that may be the reason
+why you didn't recognize this particular person?
+A Yes.
+• Okay. And if any of these previous
+photographs were taken recently and you hadn't seen the
+person for five years, then that would be a possibility
+as to why you don't recognize that person anymore?
+MR. CRITTON: Form.
+(Telephone ringing.)
+MR. EDWARDS: Jack?
+MR. CRITTON: Jack?
+116
+MR. HILL: Hey, guys. I got cut off. Sorry.
+BY MR. EDWARDS:
+• This is "P." That was Alfredo Rodriguez,
+you've seen him in the house?
+A Yes.
+Q How many months was Alfredo Rodriguez working
+there overlapping your employment?
+A I started November, December, and then --
+about three months.
+Q Okay. Do you know who that is?
+A Oh. You got that from my Facebook?
+• Do you know who that is?
+A That's me.
+• Okay. You recognize that.
+MR. CRITTON: That was "Q."
+THE WITNESS: Thank you.
+MR.U
+You made the book.
+THE WITNESS: My niece made it for me.
+MR. CRITTON: Next is "R."
+BY MR. EDWARDS:
+• Do you know who this person is who is labeled
+1-R?
+A No.
+• Never seen that person before?
+A No.
+Toll Free: 866.709.877
+Facsimile: 561.394.262:
+Suite 600
+
+
+1
+2
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+15
+16
+17
+18
+19
+20
+21
+22
+23
+25
+117
+• Has Mr. Epstein had anyone in the house that
+you remember by the name of Martin?
+A No.
+• Have you ever been on Mr. Epstein's planes?
+A
+No.
+• Do you know this person who we are labeling
+1-S?
+A
+No.
+Q
+You've never seen that person before?
+A Never.
+• Do you know the name Leslie Wexner?
+A I heard that one.
+When did you hear about Leslie Wexner?
+A In the news, it was in the news.
+Q Other than in the news, you have no idea who
+Leslie Wexner is?
+A No.
+• Have you seen that person before?
+MR. CRITTON: This is 1-T.
+BY MR. EDWARDS:
+1-T.
+A This is the Duke of, what's this?
+Q Prince Andrew. Have you ever seen
+Prince Andrew in Mr. Epstein's house?
+A No.
+118
+MR. CRITTON: Next one is "U."
+BY MR. EDWARDS:
+• 1-U, have you ever seen this person?
+A No. No, sir.
+• That's not somebody you recognize as ever
+being at Mr. Epstein's house?
+A No.
+Q Do you know who this is?
+A President Clinton.
+Q Have you ever seen President Clinton in the
+house?
+A No.
+MR. CRITTON: That was 1"?
+MR. EDWARDS: That's 1F
+' was Clinton.
+2
+9
+110
+11
+12
+(13
+14
+15
+16
+17
+18
+19
+20
+22
+23
+24
+25
+3
+5
+6
+8
+BY MR. EDWARDS:
+• Have you ever seen him at the house?
+A No.
+Q Have you ever seen him at all in person,
+Mr. Clinton?
+A No.
+• Have you ever heard that Mr. Clinton was ever
+at Mr. Epstein's house?
+A On the news.
+10
+11
+12
+113
+14
+15
+16
+17
+18
+19
+20
+21
+122
+24
+125
+ESQUIRE
+an Alexander Galle Company
+119
+• Okay. Other than on the news, anybody around
+the house ever say that?
+A President Clinton? No. Lyn and Jojo.
+Q Lyn and Jojo. What did they say?
+A Oh, not him. It's Kerry, Senator Kerry, they
+have a picture.
+Q Senator Kerry?
+A Yes. Clinton? Let me see. Oh, no.
+• So Lyn and Jojo, at some point in time, told
+you that Senator Clinton (sic) was at the New York
+house?
+MR. CRITTON: No. Senator Kerry.
+BY MR. EDWARDS:
+• Senator Kerry. Sorry.
+A I remember when I was in New York she showed
+me a picture of them with Senator Kerry or Clinton, I
+don't know, you know.
+• So either Kerry or Clinton was in a picture
+with who?
+A With Lyn and Jojo.
+• And this picture was purportedly taken at the
+New York house of Mr. Epstein?
+MA. CRITTON: Form.
+THE WITNESS: I don't know it it's in the
+house, but they showed me a picture.
+120
+BY MR. EDWARDS:
+Q Okay.
+MR.
+: This is "W."
+BY MR. EDWARDS:
+• 1-W, have you ever seen this person?
+A No.
+Q No?
+A No.
+Q Do you know anybody by the name of
+Cecelia Stein?
+A Cecelia Stein? I heard about it.
+Q How have you heard about her?
+A Cecelia Stein. I know Cecelia that works in
+the office.
+Q Works in what office?
+A New York.
+Q You think she still works in that office?
+A I don't know.
+• When was the last time you remember her
+working in that office?
+A I don't know. I just heard her name.
+Q Okay. Through whom?
+A Sometimes I think when I was in New York I
+answer a phone call, so that's...
+Q You remember a time -- did you ever hear of
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+1
+2
+3
+4
+5
+6
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+121
+her being relocated to some other location?
+A No.
+MR. CRITTON: We are at 1-X now.
+BY MR. EDWARDS:
+• So 1-X is
+A Yes, sir.
+• And you recognize
+A Yes.
+• Okay. Do you know who that is?
+A I saw him on magazines.
+• David Copperfield, do you know who that is?
+A Oh, yes.
+Q And have you seen him at Mr. Epstein's house
+ever?
+A No, sir.
+• Do you know Mr. Epstein to be friends with
+David Copperfield?
+A No.
+• If Alfredo Rodriguez remembers him performing
+magic in Mr. Epstein's living room, you weren't at the
+house at that time?
+MR. CRITTON: Form.
+THE WITNESS: No. Because I did not see him.
+BY MR. EDWARDS:
+Q Okay. Do you ever remember anyone performing
+122
+1
+3
+4
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+a magic show in Mr. Epstein's living room?
+A No.
+MR. EDWARDS: What are we at?
+MR. CRITTON: "Z"
+BY MR. EDWARDS:
+Q Do you know this?
+A Yes. What's his name.
+Q Jean Luc Brunel. Do you know who that is?
+A
+Yes.
+Q How do you know him?
+A He comes to the house.
+• He comes to the house. When you say "he comes
+to the house," you've worked since November of 2004,
+five years; when has he come to the house?
+A He came after Mr. Epstein got out of jail.
+Q And what did he do there?
+A He talked to Mr. Epstein, had breakfast.
+• How long did he stay?
+A About a day.
+Q Okay. So he stayed overnight at the house?
+A Yes.
+Q And was he accompanied by any females?
+A No.
+• Do you know what he does for a living?
+A No.
+ESQUIRE
+an Alexander Callo Company
+123
+1
+2
+3
+4
+5
+6
+7
+• Do you know if he's a business associate or
+partner of Mr. Epstein?
+A No.
+• Had you seen him prior to this time that you
+recently saw him after Mr. Epstein was out of jail?
+MR. CRITTON: Form.
+THE WITNESS: I cannot remember.
+8 BY MR. EDWARDS:
+• Okay. Do you think that the first time that
+10
+|11
+12
+13
+14
+15
+16
+you ever saw this person was recently, when Mr. Epstein
+got out of jail?
+A Yes.
+• Okay.
+MR. CRITTON: So this is AA.
+BY MR. EDWARDS:
+• Do you know who this is?
+A No.
+18
+19
+20
+21
+22
+123
+24
+125
+• Have you ever seen him before?
+A No.
+Q All right.
+A He's an actor?
+• Have you ever heard of the name Todd Meister?
+A No.
+• That's not somebody you've ever taken a
+message for that's called?
+124
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+115
+16
+117
+18
+19
+20
+21
+22
+23
+24
+25
+A No.
+• Okay. The next one is BB. Do you know who
+that is?
+A That's Story.
+• Story Cowles?
+A Yes. I don't know his family name, but Story.
+• When is the first time that you remember
+seeing Story?
+A First time? Mr. Epstein was in jail.
+• Okay. And was that as a result of him being
+at the house with
+. Story and Ms. Kellen?
+A No. I don't think so. He came without
+he came first without
+Q And did he knock on the door?
+A Yes.
+• Or does he have a key?
+A I think he knows the combination.
+• There is a combination to one of the doors to
+get access to the house?
+A Yes.
+• And Story Cowles is one of the people who has
+the combination?
+A Yes.
+• Who are the other people that have the
+combination to get in Mr. Epstein's house?
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+125
+1
+2
+3
+4
+5
+6
+8
+9
+A Me.
+• Excuse me?
+A Me.
+• Okay.
+A Janusz.
+• Okay.
+A lgor.
+• Okay.
+3
+4
+5
+6
+Q Who is that?
+11
+12
+• And when Story came to Mr. Epstein's house
+13
+14
+without
+how long ago was that, do you remember?
+MR. CRITTON: Form.
+15
+THE WITNESS: How long ago?
+16
+BY MR. EDWARDS:
+17
+• Yes. Was Mr. Epstein in jail, was it before
+18
+he went to jail?
+19
+A Oh. The other day he came without
+20
+Q But the other day is not the first time you've
+21
+seen Story, right?
+22
+A Yes.
+23
+• The other day was the first time you've seen
+24
+Story?
+25
+A No, no, no, no. I said he came without
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+126
+2
+5
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+/23
+24
+25
+Q Right. This whole back and forth started with
+me asking you when is the first time that you ever saw
+Story. And I thought you responded by telling me that
+he came to the house for the first time without
+I don't want to put words in your mouth, we'll start
+over.
+A Okay.
+Q
+When is the first time you saw Story?
+A When Mr. Epstein was in jail.
+Q Do you know why he came to the house?
+A
+No.
+there?
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+• Do you know who he talked to when he was
+12
+13
+Q
+Q
+jail?
+14
+And what did he talk to
+A I do not know.
+Did he talk to
+about?
+15
+about Jeffrey being in
+16
+17
+18
+MR. CRITTON: Form. She said she didn't know.
+19
+THE WITNESS: I did not hear anything.
+BY MR. EDWARDS:
+/20
+21
+• Where did they talk?
+122
+A In the kitchen.
+23
+Q At the time were Story and
+boyfriend and
+girlfriend, did you know?
+25
+ESQUIRE
+as Alexander Gallo Company
+...
+127
+A No.
+• They weren't boyfriend and girtfriend yet?
+A No.
+• Do you know when that evolved into a boyfriend
+and girlfriend relationship?
+A I don't know.
+MR. EDWARDS: All right.
+MR. CRITTON: Are you done?
+MR. EDWARDS: Probably.
+MR.
+: Do you need a second? Do you
+need a break?
+MA. MERMELSTEIN: Can we take a break?
+(Brief recess in proceedings.)
+MR. EDWARDS: Jack, do you have questions,
+too?
+THE WITNESS: I'm trying to get a photograph
+of somebody over there. I don't know if Esquire is
+going to be able to print it, if they've got a
+color copier, or if I've just got to run it over.
+How much longer do you-all plan on going, do
+you know?
+MR. CRITTON: About another fifteen minutes.
+I don't know. How long have you got, about
+ten?
+MR. MERMELSTEIN: About ten, fifteen.
+128
+MR. CRITTON: I may have ten minutes worth of
+questions.
+MA. EDWARDS: We'll be another thirty minutes
+at least.
+MR. HILL: I might just get in the car and
+shoot over there.
+MR. EDWARDS: I think we're taking a break
+right now anyway.
+MR. CRITTON: Well, if we're going to take a
+break, then I want to do a lunch break, I've got
+some stuff I have to do. If we're only going to be
+fifteen or twenty minutes, that's fine. But if
+we're going to go another half hour, let's take a
+MR. EDWARDS: It's going to take a while.
+MR. CRITTON: So let's take a lunch break.
+(Brief recess in proceedings.)
+(Continued to Volume II.)
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+129
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+2
+4
+5
+I, the undersigned authority, certify that
+LOUELLA RABUYO personally appeared before me on the 20th
+of October, 2009, and was duly sworn.
+Dated this 30th day of October, 2009.
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Teresa Whalen, RPR, FPR
+Notary Public - State of Florida
+My Commission Expires: 4/25/11
+My Commission No.: DD 644533
+Job # 118991
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+130
+CERTIFICATE
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+I, Teresa Whalen, Registered Professional
+Reporter and Notary Public in and for the State of
+Florida at Large, do hereby certify that the
+aforementioned witness was by me first duly sworn to
+testify the whole truth; that I was authorized to
+and did report said deposition in stenotype; and
+that the foregoing pages are a true and correct
+transcription of my shorthand notes of said
+deposition.
+I further certify that said deposition was
+taken at the time and place hereinabove set forth
+and that the taking of said deposition was commenced
+and completed as hereinabove set out.
+I further certify that 1 am not attomey or
+counsel of any of the parties, nor am I a relative or
+employee of any attomey or counsel of party connected
+with the action, nor am I financially interested in the
+action.
+The foregoing certification of this transcript
+does not apply to any reproduction of the same by any
+means unless under the direct control and/or direction
+of the certifying reporter.
+Dated this 30th day of October, 2009.
+Teresa Whalen, RPR, FPR
+Job # 118991
+ESQUIRE
+•= Alexander Galle Company
+Toll Free: 866.709.8777
+Facsimile: 561.394.2621
+Suite 600
+
+
+
+
+WORD INDEX
+RABUYO, LOUELLA
+
diff --git a/vision-fixhub/ds9-unparsed-05/f72e5aa9c503bef0db8ce3b1eda44673888717b69cc6b4e6ddcaed687bd9e49c.receipt.json b/vision-fixhub/ds9-unparsed-05/f72e5aa9c503bef0db8ce3b1eda44673888717b69cc6b4e6ddcaed687bd9e49c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2464f54cbfff56196b3e878cfc45f52fbc8eac82
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f72e5aa9c503bef0db8ce3b1eda44673888717b69cc6b4e6ddcaed687bd9e49c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -4367,
+  "dataset": "marble-joined",
+  "doc_id": "f72e5aa9c503bef0db8ce3b1eda44673888717b69cc6b4e6ddcaed687bd9e49c",
+  "engine": "marble-apple-vision",
+  "event_count": 39,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "c442e8857691c46ceb3f560e423dd5416b68f5e50921b91e0737c83f8ea33612",
+  "output_sha256": "5c0d4ba1e4bcbe3fdeb6254bafdfc91e649517d3ca7ed9cbc98df325db77ea7c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/f896a8e32bdd5938f770a40e1e0a915699a28a7b42a0aafa2f5d2e971351753b.md b/vision-fixhub/ds9-unparsed-05/f896a8e32bdd5938f770a40e1e0a915699a28a7b42a0aafa2f5d2e971351753b.md
new file mode 100644
index 0000000000000000000000000000000000000000..40986001884698a3fca9101124f4f5973b742a13
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f896a8e32bdd5938f770a40e1e0a915699a28a7b42a0aafa2f5d2e971351753b.md
@@ -0,0 +1,148 @@
+OLY-53
+
+
+TO:
+Unted States District Court
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-53
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOUARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+June 12, 2007
+1:00 pm*
+YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):
+See attachments for the production of required documents.
+*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
+your appearance with Special Agent
+Federal Bureau of Investigation, Telephone:
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
+on behalf of the court.
+CLERK
+STATES DISTAIR
+(BY) DEPUTY CLERK
+DATE:
+May 31, 2007
+This subpoena is issued upon application
+of the United States of America
+*If not applicable, enter "nonc."
+Name, Address and Phone Number of Assistant U.S. Attorney
+1, Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Bench EL 33401 6235
+Tel:
+Fax
+To be used in lieu of AO110
+FORM ORD-227
+JAN.86
+
+
+1.
+2.
+5.
+ATTACHMENT TO SUBPOENA
+For the period of January 1, 2003 to the present, all calendars, agendas, daily diaries, or
+other records of appointments, travel, meetings and the like, kept by or on behalf of
+Jeffrey Epstein,
+All, Lesley Groff, and/or
+This request includes information that is kept in physical "hard copy" and/or electronic
+form, whether stored on a personal computer, database server, cellular telephone,
+"Blackberry" unit, personal digital assistant ("PDA) or other handheld electronic device,
+or in any other electronic form, and all metadata included within the electronic/physical
+files.
+For the period of January 1, 2003 to the present, all address books, contact lists, or other
+records of names, telephone numbers, addresses, and/or e-mail addresses kept by or on
+behalf of Jeffrey Epstein,
+L. Lesley Groff, and/or
+This request includes information that is kept in physical "hard copy"
+and/or electronic form, whether stored on a personal computer, database server, cellular
+telephone, "Blackberry" unit, personal digital assistant ("PDA) or other handheld
+electronic device, or in any other electronic form, and all metadata included within the
+electronic/physical files.
+For the period of January 1, 2003 to the present, all e-mails, instant messages, text
+messages, meeting invitations, and any other electronic communication sent by Jeffrey
+Epstein,
+, Lesley Groff, and/or
+to Jeffrey
+Epstein,
+Lesley Groff, and/or
+This
+request includes information that is kept in physical "hard copy" and/or electronic form,
+whether stored on a personal computer, database server, cellular telephone, "Blackberry"
+unit, personal digital assistant ("PDA") or other handheld electronic device, or in any
+other electronic form, and all metadata included within the electronic/physical files.
+For the period of January 1, 2003 to the present, all documents and information referring
+or relating to the transfer of funds from any account owned by Epstein Interests to any
+ank account used for the maintenance of the property located at 358 El Brillo Way, Paln
+Beach, Florida, or for the payment of any person working at 358 El Brillo Way, Paln
+Beach, Florida.
+For the period of January 1, 2003 to the present, all documents and information referring
+or relating to the transfer of funds from any account owned by Epstein Interests to any
+ank account on which Janusz Banasiak and/or Alfredo Rodriguez had check-writing
+
+
+U.S. Departm : of Justice
+United States Attorney
+Southern District of Florida
+So aman er 3401-1295
+(561) 820-8711
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are providec
+sufficiently in advance of trial to allow an opportunity for any challenges to thei
+aur/trial at the time and place specified by completely pinging personald here n
+and Inventory and immediately returning it with the records to Special Agent
+, FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to June 12, 2007.
+Sincerely,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+BY:
+ASSISTANT UNITED STATES ATTORNEY
+
+
+CERTIFICATION OF BUSINESS RECORDS
+1, the undersigned,
+employed bylassociated with
+position of
+- declare that l am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+Date of execution:
+Place of execution:
+Signature:
+-
+
+
+APPENDIX A
+DOCUMENT INVENTORY
+The documents submitted are as follows:
+Signature of Records Custodian:
diff --git a/vision-fixhub/ds9-unparsed-05/f896a8e32bdd5938f770a40e1e0a915699a28a7b42a0aafa2f5d2e971351753b.receipt.json b/vision-fixhub/ds9-unparsed-05/f896a8e32bdd5938f770a40e1e0a915699a28a7b42a0aafa2f5d2e971351753b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..323501a1504481ddfa0043e4ec171d77b5a44726
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/f896a8e32bdd5938f770a40e1e0a915699a28a7b42a0aafa2f5d2e971351753b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -72,
+  "dataset": "marble-joined",
+  "doc_id": "f896a8e32bdd5938f770a40e1e0a915699a28a7b42a0aafa2f5d2e971351753b",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "a885d9c0cd818f29cedce806ac9b7c689baa715704481dc18d8315d7265c7297",
+  "output_sha256": "a50ed177dfd0b49c8b1ba5bb14f52be4efc7a03984d83c55366d55ae1a250b26",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/fa0a89d36957821579ce728537197adb3e34bb105323b41b2589046e0df121ba.md b/vision-fixhub/ds9-unparsed-05/fa0a89d36957821579ce728537197adb3e34bb105323b41b2589046e0df121ba.md
new file mode 100644
index 0000000000000000000000000000000000000000..2a71dab6df8cfa5e08f38241c76a334051b25887
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fa0a89d36957821579ce728537197adb3e34bb105323b41b2589046e0df121ba.md
@@ -0,0 +1,3389 @@
+Statements
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .•••••••••••••••••••I/I/
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity .....
+Your Messages
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30, 2001
+3
+Hollandlold
+INTERNATIONAL CHARITABLEINTS
+FINANCIAL TRUST CO TTEE
+DTD 4-28-94
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTE STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+1
+329,873
+3,442,486
+NET EQUITY THIS PERIOD
+$3,772,360
+••••••••/••••••••••••
+NET EQUITY LAST STATEMENT
+3.657.235
+CHANGE SINCE LAST STATEMENT
+115,125
+*This portfolio indudes one or more unpriced securties that are not
+relected in the Total Value of Securities and the Net Equity This Period
+Market Value of Your Portfolio
+Cash & Equivalent
+$3.772,359
+$3.657,234
+Current market value
+Last statement's market value
+Important Message
+If any information regarding
+2001 interest, dividends,
+miscellaneous income,
+gross proceeds or original
+issue discount is required
+to be reported to the IRS for
+this olicated form 1099
+will be mailed to you by
+Da March 152022: 10425
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+: This statement should be retained for your records. See reverse side for important informati
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+027
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+$221,473.88
+80,963.10
+6,725.50
+27,435.75
+5115,124.35
+....
+-6,725.50
+..56.725.50
+108,398.85
+3329-872-73
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+221,473.88
+$221,473.88
+Income Summary
+Dividends
+Govt. Agency Int.
+Credit Balance Int.
+Total
+THIS PERIOD
+6,725.50
+27,129.95
+305.80
+$34,161.25
+Portfolio Composition
+Cash/Cash Equivalent
+027
+CLOSING
+329,872.73
+5323-37273
+YEAR TO DATE
+42,485.88
+27,129.95
+9,415.99
+79,031.8
+3,772,359
+_$3772-359
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+. . . .
+DREYFUS CASH MANAGEMENT-CLA
+TOTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+UNITED MTG SECS CORP
+SERIES 93-1 CL B-2
+TED DATE 11/26/5
+OK ENTR
+PACTOR 1000000%
+Total Government& Agency Obligations
+TOTAL FIXED INCOME
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+DICCX
+QUANTITY
+3,442,485.88
+PRICE
+1.0000
+MARKET
+VALUE
+329,873
+3,442,486
+$3,772,359
+79,177 2.3000
+$79,177
+SYMBOLCUSP
+CASH
+QUANTITY
+7,506,037
+PRICE
+Unpriced
+MARKET VALUE
+$0
+$0
+VOCRUEL
+NTERES
+1
+$1
+$1
+$1
+$79,252
+$3,772,358
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30, 2001
+ESTIMATED
+ANNUAL INCOME
+75
+$75
+$75
+YIELD 1%
+
+
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TREE
+12/03/01
+PRINCIPAL
+MONEY FUND ACTIVITY
+MODAY
+12/01/01
+12/03/01 DIVIDEND
+
+"AEINVESY
+12/31/01
+INTEREST
+12/03/01
+12/21/01
+UNITED MIG SECS CORP
+ERIES 93-1 CL B-
+7558752P93Mт 0,00
+INTEREST ON CREDIT BALANCE
+AT 1 1/4% 12/11 THRU 12/20
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+UNITED MIG SECS CORP
+SERIES 93-1 CL B-2
+001 DUE 11/25/
+/25/01 PP
+SYMBOL/CUSIP
+QUANTITY
+-80,963
+PRICE
+OPENINGBALANCE
+REYBAEMANAGEMENFCLA
+MONTHLY DIVIDEND
+RETEN ACEMENTECA
+DIVIDEND REINVESTED
+CLOSINGBALANCER
+SYMBOUCUSIP
+PRICE
+5.725.50
+$-6,725.50
+CREDIT AMCUNT
+27,129.95
+114.43
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30,2001
+CREDIT AMOUNT
+80,963.10
+$80,963.10
+CREDIT AMOUNT
+725₽
+$6,725.50
+SYMBOUCUSIP
+QUANTITY
+QUANTITY
+3,435,760.38
+6.725.50
+3,442,485.88
+RATE (%)
+0.0010
+1.2500
+027
+
+
+OFFICE SERVICING YOUR ACOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+INTEREST (continued)
+12/21/01
+INTEREST ONCREDIT BALANCE
+AT 1 1/2% 11/21 THRU 12/10
+SYMBOUCUSIP
+QUANTITY
+RATE (%)
+1.5000
+Your messages
+As part of the National Association of Securities Dealers (NASD)
+Investor Education Program, you may obtain information on the
+NASD's Public Disclosure Program by contacting the NASD
+at telephone number (800) 289-9999 or via the internet address which
+is www.nasdr.com, In addition, a brochure explaining the
+Public Disclosure Program is available from the NASD upon request,
+STOP
+******
+End of Statement******
+027
+CLEARED THROUGH IT
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 1, 2001
+THROUGH
+December 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+November 30, 2001
+CREDIT AMOUNT
+191.37
+$27,435.75
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail ................................
+Fund Activity .......•••••••••••••••••IIIIIIIIII/I
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD October 27, 2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 26,2001
+3
+4
+Hollandlold
+INTERNATIONAL CHARITABLEINTS
+FINANCIAL TRUST CO TTEE
+DTD 4-28-94
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTE STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+1
+221,474
+3,435,760
+$3,657,235
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+3,497,598
+159,637
+*This portfolio indudes one or more unpriced securties that are not
+relected in the Total Value of Securites and the Net Equity This Period.
+Market Value of Your Portfolio
+Cash & Equivalent
+$3.657,234
+$3,497,598
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+12/01/01:10:46 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+027
+12/01/01:10:46 001|
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Funds Deposited
+Dividends/Interest
+Amount Credited
+Money Fund
+mount Debite
+Net Cash Activity
+Closing Balance
+THIS PERIOD
+$69.259.25
+.. ..
+7,421.33
+152,106.23
+108.40
+...
+$159,635.96
+-7,421.33
+S-7.421.33
+152,214.63
+$221,473.88
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+69,259.25
+$69,259.25
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+7,421.33
+108.40
+$7,529.73
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+027
+CLOSING
+221,473.88
+$221,473.88
+*..........
+YEAR TO DATE
+35,760.38
+9,110.19
+$44,870.57
+3,657,234
+53.657.254
+12/01/01:10:46 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD October 27, 2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 26,2001
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+. . . .
+DREYFUS CASH MANAGEMENT-CLA
+TOTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+UNITED MTG SECS CORP
+SERIES 93-1 CL B-2
+TED DATE 11/26/5
+OK ENTR
+PACTOR 1000000%
+Total Government& Agency Obligations
+TOTAL FIXED INCOME
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+OFFICE SERVICING YOUR ACOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+DICCX
+QUANTITY
+3,435,760.38
+PRICE
+1.0000
+MARKET
+VALUE
+221,474
+3,435,760
+$3,657,234
+STIMATE
+NUAL INCON
+.....
+96,201
+2.8000
+$96,201
+SYMBOLCUSP
+CASH
+QUANTITY
+7,587,000
+PRICE
+Unpriced
+MARKET VALUE
+$0
+$0
+VOCRUEL
+NTERES
+1
+$1
+$1
+$1
+$96,277
+$3,657,233
+120
+1201/01;10:46 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD October 27, 2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 26,2001
+ESTIMATED
+ANNUAL INCOME
+76
+YIELD (%)
+
+
+5 orB
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+1/19/01
+
+DEPOSIT
+FUNDS REC
+IESCRIPTIOI
+NONE CHATBLE INTS 00 B
+11/2601
+FUNDS REC
+FREER RIBANK FROM
+MONEY FUND ACTIVITY
+OPENINGBALANCE
+10/27/01
+1170101 DIVIDEND
+
+"REINVEST
+DIVIDEND REINVESTED
+CLOSINGBALANCE
+11/30/01
+OFFICE SERVICING YOUR ACOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CREDIT AMOUNT
+8,520.75
+3,296.57
+140,288.91
+$152,106.23
+SYMBOL/CUSIP
+QUANTITY
+3,428,339.05
+
+3,435,760.38
+PRICE
+027
+12/01/01:10:46 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD October 27, 2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 26,2001
+CREDIT AMOUNT
+*7,421.33
+7,421.33
+$-7,421.33
+$7,421.33
+
+
+6 of B
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+Transaction Detail (continued)
+INTEREST
+11/21/01
+INTEREST ONCREDIT BALANCE
+AT 1 1/2% 11/06 THRU 11/20
+1/21/01 INTEREST ON CREDIT BALANCE
+T 2,000% 10/21 THRU 11/05
+SYMBOL/CUSIP
+QUANTITY
+RATE (%)
+1.5000
+2.0000
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD October 27,2001
+THROUGH
+November 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+October 26,2001
+CREDIT AMOUNT
+44.13
+.. .
+64.27
+$108.40
+STOP
+****** End of Statement******
+027
+12/01/01:10:46 001
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ...................../...................
+Your Messages ................................I.....
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+September 28, 2001
+3
+5
+6
+Hollandlold
+INTERNATIONAL CHARITABLEINTS
+FINANCIAL TRUST CO TTEE
+DTD 4-28-94
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTE STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+69.259
+3,428,339
+$3,497,598
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+3,477,606
+19.992
+"This portfolio indudes one or more unpriced securties that are not
+refected in the Total Value of Securtes and the Net Equity This Period.
+Market Value of Your Portfolio
+Cash & Equivalent
+$3.497,598
+$3.477,605
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+10/27/01;09:11 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+027
+10/27/01:09:11 001|
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Funds Deposited
+Dividends/Interest
+Amount Credited
+Money Fund
+Funds Withdrawn
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERICO
+3557.257.34
+7,991.30
+161,803.99
+797.92
+$170,593.21
+-507,991.30
+-150,600.00
+5 668. 591.30
+-487,998.09
+....
+$69,259.25
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+7,991.30
+797.92
+.58.78922
+Portfolio Composition
+Cash/Cash Equivalent
+Tota
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+557,257.34
+$557,257.34
+CLOSING
+69,259.25
+......
+$69,259.25
+1.••...
+027
+YEAR TO DATE
+28,339.05
+9,001.79
+**...------.
+$37,340.84
+3,497,598
+$3,497,598
+10/27/01;09:11001
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 28, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+. . . .
+DREYFUS CASH MANAGEMENT-CLA
+TOTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+UNITED MTG SECS CORP
+SERIES 93-1 CL B-2
+TED DATE 11/26/
+OK ENTRY ONI
+PACTOR 1000000%
+Total Government& Agency Obligations
+TOTAL FIXED INCOME
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOLCUSIP
+DICCX
+QUANTITY
+3,428,339.05
+1.0000
+MARKET
+VALUE
+69,259
+3,428,339
+$3,497,598
+ESTIMATED
+INNUAL INCOME
+113,135
+3.3000
+$113,135
+SYMBOLCUSP
+CASH
+QUANTITY
+7,587,000
+PRICE
+Unpriced
+MARKET VALUE
+$0
+$0
+CCRUE
+NTERE:
+$0
+$0
+$113,211
+$3,497,598
+120
+10/27/01;09:11001
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 28, 2001
+ESTIMATED
+ANNUAL INCOME
+76
+YIELD 1%
+
+
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+5 orB
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+1070110T
+FND WIRED
+10/10/01
+FÜNDS REC
+10/25781*CHECK"
+10/26/01
+CHECK
+_ENDSWIRED TO
+ENDS WIRED TO CITIBANK FROM
+CHEN REMAN
+MONEY FUND ACTIVITY
+09/29/01
+10/01/01
+"DIVIDEND
+10/01/01 REINVEST
+18/17/01
+OPENINGBALANCE
+THOMAS MANAGEMENT CL
+MONTHLY DIVIDEND
+RATE TONS MANACEMENFCLA
+DIVIDEND REINVESTED
+HE CASE MANAGEMENT CLA
+NSTITUTIONAL
+10/26/01
+CLOSINGBALANCE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+September 28, 2001
+139,832.00
+"4,368:00
+6,400.00
+$-150,600.00
+CREDIT AMOUNT
+161,803.99
+$161,803.99
+SYMBOUCUSIP
+"DICEX"
+'''DICK
+QUANTITY
+2,920,347.75
+7.991.30
+500,000
+3,428,339.05
+PRICE
+CREDIT AMOUNT
+7,991.30
+7,991.30
+*500.000.0...
+$-507,991.30
+$7,991.30
+027
+10127101;09:11 001
+
+
+Transaction Detail (continued)
+INTEREST
+10/22/01
+NTEREST ONCREDIT BALANCI
+T 1 1/2% 09/21 THRI
+09/23
+18/22701 "NTEREST ON CREDIT BALANCE
+10/22/01
+AT 2 1/2% 09/24 THRU 10/01
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUCUSIP
+Your messages
+245 Park Avenue, to:
+383 Madison Avenue
+New York, New York 10179
+While our telephone numbers and e-mail addresses
+remain the same, some fax numbers have changed.
+Please check with your Account Executive.
+STOP
+****** End of Statement******
+QUANTITY
+RATE (%)
+1.5000
+--2.5000
+2.0000
+027
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 29, 2001
+THROUGH
+October 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+LAST STATEMENT
+September 28, 2001
+CREDIT AMOUNT
+69.66
+299.88
+428.38
+$797.92
+10/27/01:09:11001
+
+
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+ZICHERMAN, IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ...................../...................
+Your Messages ................................I.....
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31, 2001
+3
+5
+6
+Hollandlold
+INTERNATIONAL CHARITABLEINTS
+FINANCIAL TRUST CO TTEE
+DTD 4-28-94
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTE STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+1
+557,257
+2,920,348
+$3,477,606
+3.355.001
+CHANGE SINCE LAST STATEMENT
+122,606
+*This portfolio indudes one or more unpriced securties that are not
+relected in the Total Value of Securites and the Net Equity This Period
+Market Value of Your Portfolio
+Cash & Equivalent
+$3.477,605
+$3,355,000
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+
+
+2 of 7
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+027
+09/29/01:10:55 001|
+
+
+3 or 7
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Funds Deposited
+Dividends/Interest
+Amount Credited
+Money Fund
+mount Debite
+Net Cash Activity
+Closing Balance,
+THIS PERIOD
+443,648.62
+...............
+8,996.59
+112,390.00
+1,218.72
+$122.605.31
+-8,996.59
+5-8.996-59
+113,608.72
+3657-267-34
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+443,648.62
+$443,648.62
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+8,996.59
+1,218.72
+$10,215.31
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+027
+CLOSING
+557,257.34
+$557,257.34
+....
+YEAR TO DATE
+20,347.75
+8,203.87
+вааааааааааа
+$28.551.62
+3,477,605
+53.477.605
+09/29/01:10:55001
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+V50O
+
+
+4 of 7
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+....
+DREYFUS CASH MANAGEMENT-CLA
+ISTITUTIONAL SHARES
+OTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+UNITED MIG SECS COAP
+SERED DATE 112633
+BOOK ENTRY ONLY
+Told arenate any Colations
+TOTAL FIXED INCOME
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+SYMBOLCUSIP
+DICCX
+QUANTITY
+2,920,347.75
+1.0000
+MARKET
+VALUE
+557,257
+2,920,348
+$3,477,605
+MAREMATED CURE
+*******•//--.
+108,053
+3.7000
+$108,053
+SWMEOLCUSP
+ACCE
+CASH
+QUANTITY
+7,587,000
+PAICE
+Unpriced
+MARKET VALUE
+$0
+$0
+CCRUE
+TERES
+1
+$1
+$1
+51
+$108,129
+$3,477,605
+120
+09/29/01;10:55 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31, 2001
+ANNUAL TACOME
+76
+
+
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+5 of 7
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+09/05/01
+FUNDS REC
+ENDS WIRED TO CITIBANK FROM
+BK OF NYC
+FL
+MONEY FUND ACTIVITY
+MO/DAY
+09/01/01
+05/04/01
+DESCAIPTION
+OPENINGBALANCE
+DIVIDEND
+ö9/04/01
+REINVEST
+.....
+
+MONTHLY DIVIDEND
+EYFUS CASH MANAGEMENT-CL
+STITUTIONAL SHAR
+DIVIDEND REINVESTED
+CLOSINGBALANCE
+INTEREST
+09/21/01
+09/21701 INTEREST ON CREDIT BALANCE
+AT 1 1/2% 09/20 THRU 09/20
+SYMBOUCUSIP
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31, 2001
+SYMBOUCUSIP
+DICCX
+CREDIT AMOUNT
+112,390.00
+$112,390.00
+QUANTITY
+2,911,351.16
+8,996.59
+2,920,347.75
+PRICE
+QUANTITY
+RATE (SI
+0.5000
+1.5000
+027
+8,996.59
+$-8,996.59
+CREDIT AMOUNT
+7.72
+*23.17
+.....
+CREDIT AMOUNT
+8,996.59
+/....
+$8,996.59
+
+
+6 of 7
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York. New York 10167
+Transaction Detail (continued)
+INTEREST (continued)
+
+INTEREST ON CREDIT BALANCE
+AT 2 1/2% 09/17 THRU 09/18
+082101 3000-0622405165
+SYMBOL/CUSIP
+QUANTITY
+RATE (%)
+2.5000
+3.0000
+LEARED THROUGH I
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31, 2001
+CREDIT AMOUNT
+77.23
+.....
+1,110.60
+$1.218.72
+Your messages
+IS This statement is provided to explain Bear, Steams & Co.
+Inc's ('BS") payment for order flow practices,
+BSC routes a majority of orders for customer securities
+transactions to the primary market for such securities.
+Orders may also be routed to other market service vendors
+that assure executions pursuant to complex mathematical
+formulas at better than the national best bid or best offer
+(NBBO). BSC receives no cash payment or other
+consideration for such order routing other than favorable
+executions or executions of limit orders at no additional
+• Beginning October 31, 2001, you may request the identity
+of the venue to which any of your orders were routed for
+execution (if the order was within the six months prior to
+the request or July 2, 2001, whichever is a later date),
+whether the order was directed by you to that venue, and
+the time of the executions, if any, that resulted from such
+027
+09/29/01;10:55 001
+
+
+7 of 7
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stears & Co. Inc.
+45 Park Avenue
+New York, New York 10167
+LEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD September 1, 2001
+THROUGH
+September 28, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31, 2001
+Bear, Stearns Securities Corp. Net Capital and Net Capital
+Requirements:
+At May 25, 2001 and July 27, 2001, the Company's net
+capital of $2,7 billion and $2,7 billion was approximatel
+3.9% and 9.2% of aggregate debit items and exceeded th
+minimum regulatory net capital requirement of $605.5
+million and $585,5 million by $2,1 billion and $2,1 billion,
+all respectively.
+A complete copy of the Bear, Stearns Securities
+Corp, Statement of Financial Condition is
+available on the web site www.bearstearns.com
+Alternatively, to request a free printed copy please call
+-toll free 1-866-299-9331
+Securities and other assets in your account are the firm's
+collateral for any margin loan made to you, If the securities
+and other assets in your account decline in value, so does
+the value of the collateral supporting your loan, and, as a
+result, the firm can take action, such as issue a margin call
+and/or sell securities or other assets in any of your accounts
+held with the member, in order to maintain the required equity
+in the account, It is important that you fully understand the
+risks involved in trading securities on margin, These risks include
+the following:
+You can lose more funds than you deposited in the
+margin account,
+The firm can force the sale of securities or other assets
+in your accounts).
+The firm can sell your securities or other assets without
+contacting you.
+You are not entitled to choose which securities o
+other assets in your accounts) are liquidated or solo
+to meet a margin call.
+le firm can increase it's "house" maintenan‹
+quirements at any time and is not required to provi
+you advance written notice.
+You are not entitled to an extension of time on a margin call.
+STOP
+****** End of Statement******
+027
+
+
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail .................................
+Fund Activity ...................../...................
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOO July 28, 2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 27, 2001
+3
+4
+INTERNATIONAL CHARITABLEINTS
+FINANCIAL TRUST CO TTEE
+DTD 4-28-94
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTE STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+1
+443,649
+2,911,351
+$3,355,001
+3,194,575
+160,426
+CHANGE SINCE LAST STATEMENT
+*This portfolio indudes one or more unpriced securties that are not
+relected in the Total Value of Securtes and the Net Equity This Period.
+Market Value of Your Portfolio
+Cash & Equivalent
+$3,355,000
+$3,194,575
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or Write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+09/01/01:10:37 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+027
+09.01/01:10:37 001
+
+
+3 of 5
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Funds Deposited
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+5222,665.38
+9,441.74
+150,001.28
+981.46
+$160.424.48
+.......
+-9,441.74
+.$9141.74
+150,982.74
+5443.648.62
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+292,665.88
+$292,665.88
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+9,441.74
+981.46
+$10,423.20
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+027
+CLOSING
+443,648.62
+543.648.62
+YEAR TO DATE
+11,351.16
+6,985.15
+$18.336.31
+3,355,000
+$3,355,000
+09/01/01;10:37 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD July 28, 2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 27,2001
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+....
+DREYFUS CASH MANAGEMENT-CLA
+ISTITUTIONAL SHARES
+OTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+DICCX
+FIXED INCOME
+Government & Agency Obligations
+UNITED MIG SECS COAP
+SERED DATE 112633
+BOOK ENTRY ONLY
+Told arenate any Colations
+TOTAL FIXED INCOME
+SWMEOLCUSP
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+QUANTITY
+2,911,351.16
+1.0000
+MARKET
+VALUE
+443,649
+2,911,351
+$3,355,000
+113,543 3.9000
+$113,543
+ACCE
+CASH
+QUANTITY
+7,587,000
+PAICE
+Unpriced
+MARKET VALUE
+$0
+$0
+CCRUE
+TERES
+1
+$1
+$1
+51
+$113,619
+$3,354,999
+120
+09101/01;10:37 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOO July 28, 2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 27,2001
+ANNUAL TACOME
+76
+
+
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+08/09/01
+FUNDS REC
+-NDS WIRED TO CITIBANK FROM
+BK OF NYC
+MONEY FUND ACTIVITY
+MO/DAY
+07/28/01
+ö8/01701
+DESCAIPTION
+OPENINGBALANCE
+DIVIDEND
+ö8/01/01
+"REINVEST
+•.•//..
+
+MONTHLY DIVIDEND
+PRETONA CEMEN ELA
+DIVIDEND REINVESTED
+CLOSINGBALANCE
+INTEREST
+DESCAPTION
+08/21/01
+INTEREST ON CREDIT BALANCE
+AT 3 1/4% 07/21 THRU 08/20
+SYMBOUCUSIP
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOO July 28, 2001
+THROUGH
+August 31, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 27, 2001
+SYMBOUCUSIP
+"DiCCX
+QUANTITY
+CREDIT AMOUNT
+150,001.28
+$150.001.28
+QUANTITY
+2,901,909.42
+9,441.74
+2,911,351.16
+RATE (%)
+3.2500
+PRICE
+9,441.74
+/////////./....
+$-9,441.74
+CAEDIT AMOUNT
+981.46
+$981.46
+CREDIT AMOUNT
+*9,441.74
+$9,441.74
+027
+09/01/01:10:37 001
+
+
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+ZICHERMAN. IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ...................../...................
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD June 30, 2001
+THROUGH
+July 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2001
+3
+4
+Hollandlol
+INTERNATIONAL CHARITABLEINTS
+FINANCIAL TRUST CO TTEE
+DTD 4-28-94
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTE STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+292,666
+2,901,909
+$3,194,575
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+2,972,781
+221,794
+"This portfolio indudes one or more unpriced securtles that are not
+relected in the Total Value of Securites and the Net Equity This Period
+Market Value of Your Portfolio
+Cash & Equivalent
+$3.194,575
+• $2,972,781
+Current market value
+Last statement's market value
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Flease report any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+to Clent Services at 800-634-1428; or write to Clent Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+PC This summary is for informational purposes only. It is not intended as a tax docum
+* This statement should be retained for your records. See reverse side for important informat
+07/28/01:10:18 001
+V482
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+027
+07/28/01:10:18 001|
+V482
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Funds Deposited
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Money Fund
+Funds Withdrawn
+Miscellaneous
+Amount Debited.
+Net Cash Activity
+Closing Balance
+THIS PERICO
+572.781.33
+1,909.42
+2,315,486.62
+573.98
+141,124.95
+$2,459,094.97
+-1,909.42
+-139,831.00
+-2,097,470.00
+$-2.239.210.42
+219,884.55
+$292,665.88
+Income Summary
+Dividends
+Credit Balance Int.
+Total
+THIS PERIOD
+1,909.42
+573.98
+$2.483.40
+Portfolio Composition
+Cash/Cash Equivalent
+Tota
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+72,781.33
+$72,781.33
+CLOSING
+292,665.88
+$292,665.88
+027
+YEAR TO DATE
+1,909.42
+6,003.69
+.....
+7,913.1
+3,194,575
+$3,194,575
+07/28/01:10:18 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD June 30, 2001
+THROUGH
+July 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent-
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+... .
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+TOTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+UNITED MIG SECS COAP
+SERED DATE 112633
+BOOK ENTRY ONLY
+Total Government& Agency Obligations
+TOTAL FIXED INCOME
+SIMBOLCUSP
+DICCX
+QUANTITY
+2,901,909.42
+PRICE
+1.0000
+MARKET
+VALUE
+292,666
+2,901,909
+$3,194,575
+*•••••••••••••••
+118,978
+$118,978
+SYMBOLCUSP
+ACCE
+CASH
+QUANTITY
+7,587,000
+PAICE
+Unpriced
+MARKET VALUE
+$0
+$0
+$0
+$0
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+$119,054
+$3,194,574
+120
+07/28/01;10:18 001
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOO June 30, 2001
+THROUGH
+July 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2001
+AMMUNE NOTE
+76
+
+
+5 of 8
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TREE
+07/06/01
+RECEIVED
+DEPOSITS AND WITHDRAWALS
+07/02/01
+FND WIRED
+07/02/01
+FUNDS REC
+MONEY FUND ACTIVITY
+MODAY
+TRANSACTON
+06/30/01
+07/02/01 DIVIBEND
+07/02/01
+"REINVEST'
+OFFICE SERVICING YOUR ACOUNT
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+UNITED MIG SECS CORP
+SERIES 93-1 CL B-2
+D.00 1025202530.001
+SYMBOL/CUSIP
+QUANTITY
+7,587,000
+PRICE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD June 30, 2001
+THROUGH
+July 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2001
+CRECIT AMOUNT
+FNDS WIRED TO
+$ COMING FROM REPO
+CHES WIRED TO CITIBANK FROM
+139,831.00
+CREDIT AMOUNT
+2,315,486.62
+$2.315,486.62
+OPENINGBALANCE
+MONTHLY DIVIDEND
+DIVIDEND REINVESTED
+$-139,831.00
+SYMBOLCUSIP
+BICCX
+QUANTITY
+2,900,000
+1,909.42
+PRICE
+1,909.42
+CREDIT AMOUNT
+1,909.42
+027
+07/28/01;10:18 001
+
+
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+MODAY
+07/27/01
+CLOSINGBALANCE
+INTEREST
+07/23/01
+
+INTEREST ON CREDIT BALANCE
+AT 3 1/2% 06/21 THRU 06/26
+........
+INTEREST ON CREDIT BALANCE
+AT 3 1/4% 06/27 THRU 07/20
+SYMBOUCUSIP
+MISCELLANEOUS
+MODAY
+07/02/01
+
+TRANSACTICN
+RECEIVED
+TOl
+PER LOA
+BALANCE TRANSFERRED
+STOP
+****** End of Statement******
+SYMBOUCUSIP
+QUANTITY
+2,901,909.42
+PRICE
+QUANTITY
+RATE (SI
+3.5000
+3.2500
+2,097,470.00
+$-2,097,470.00
+CRECIT ANGUNT
+141,124.95
+$141,124.95
+027
+07/28/01:10:18 001
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOO June 30, 2001
+THROUGH
+July 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 29, 2001
+CREDIT AMOUNT
+$-1,909.42
+$1,909.42
+CREDIT AMOUNT
+91.07
+............
+482.91
+$573.98
+
+
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ...................../..................
+Your Messages ................................I.....
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 25, 2001
+3
+5
+6
+Hollandlol
+INTERNATIONAL CHARITABLEINTS
+FINANCIAL TRUST CO TTEE
+DTD 4-28-94
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTE STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+....
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+72,781
+2,900,000
+$2,972,781
+25,030
+2,947,751
+here are no "Stop Loss" orders or other pending bu
+sell open orders on file for your accoun
+Cash & Equivalent -
+Market Value of Your Portfolio
+$25,030
+Current market value
+Last statement's market value
+$2.972,781
+Important Message
+Please note: You may find
+more than one statement
+in this envelope. Beginning
+this month, all statements
+with the same Address and
+Social Security number /
+Taxpayer Identification
+number are being mailed in
+one envelope. For further
+details, please contact your
+account executive.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp.. One Metrolech Center North, Brooklyn, N.Y. 11201-3659.
+SP The suremen s four ratanal purger red de Set revere dise for portant iformation.
+06/30/01;23:28 001
+V481
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+027
+06/30/01:23:28 001|
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Cash Flow Analysis
+Opening Balance
+Funds Deposited
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Money Fund
+Amount Debite
+Net Cash Activity
+Closing Balance
+THIS PERICO
+$25,030.29
+.. . .
+2,800,000.00
+493.82
+147,257.22
+$2,947,751.04
+...
+-2,900,000.00
+......... 00.00
+47,751.04
+572.781.33
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+25,030.29
+$25,030.29
+CLOSING
+72,781.33
+$72,781.33
+.....
+Income Summary
+Credit Balance Int.
+Total
+THIS PERIOD
+493.82
+$493.82
+YEAR TO DATE
+5,429.71
+$5,429.71
+Portfolio Composition
+Cash/Cash Equivalent
+2,972,781
+....
+................
+027
+06/30/01:23:28 001
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 25, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debit balance andlor short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+... .
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSP
+DICCX
+QUANTITY
+2,900,000
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TATE
+
+RECEIVED
+06/05101
+UNITED MIG SECS CORP
+ERIES 93-1 CL B-
+.001 DUE 11/25/0
+ACAT REVERSAL
+PRICE
+1.0000
+MARKET
+VALUE
+72,781
+2,900,000
+$2,972,781
+$133,400
+$2,972,781
+..............
+133,400
+$133,400
+SYMBOLGUSIP
+QUANTITY
+7,587,000
+-7,587,000
+PRICE
+027
+06/30/01;23:28 001
+CLEARED THRESH SONARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 25, 2001
+CREDIT AMOUNT
+
+
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+5 of 8
+Transaction Detail (continued)
+DEPOSITS AND WITHDRAWALS
+06/25/01
+FUNDS REC
+CE SAMIRED TO CITIBANK FROM
+F0511760134701
+MONEY FUND ACTIVITY
+MO/DAY
+05/26/01
+06/25/01
+BOUGHT
+06/26/01 BOUGHT
+DESCAIPTION
+OPENINGBALANCE
+RETTO NAS SHARAGEMENTCLA
+BUY
+FD I
+REYFUS CASH MANAGEMENT-CL
+ISTITUTIONAL SHARE:
+BUY
+FD
+...
+06/29/01
+CLOSINGBALANCE
+INTEREST
+06/21/01
+INTEREST ON CREDIT BALANCE
+AT 3 1/2% 05/21 THRU 06/20
+SYMBOUCUSIP
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 25, 2001
+SYMBOUCUSIP
+QUANTITY
+CREDIT AMOUNT
+2,800,000.00
+$2,800,000.00
+QUANTITY
+0.00
+2,800,000
+100,000
+2,900,000
+RATE (%)
+3.5000
+027
+PRICE
+1.0000
+1.0000*
+2,800,000.00
+100,000.00
+$-2,900,000.00
+CREDIT AMOUNT
+493.82
+$493.82
+CAEDIT AMOUNT
+06/30101;23:28 001
+
+
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Transaction Detail (continued)
+MISCELLANEOUS
+MO/DAY
+06/04/01
+RECEIVED
+BALANCE TRANSFERRED
+Your messages
+STOP
+****** End of Statement******
+027
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD May 26, 2001
+THROUGH
+June 29, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 25, 2001
+CRECIT AMOUNT
+147,257.22
+$147,257.22
+06/30/01:23:28001
+
+
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ..............................
+Your Portfolio Holdings
+....
+Transaction Detail
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD April 28, 2001
+THROUGH
+May 25, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 27,2001
+3
+4
+4
+Hollandlold
+INTERNATIONAL CHARITABLEINTS
+FINANCIAL TRUST CO TTEE
+DTD 4-28-94
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTE STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+25,030
+$25,030
+17,630
+7,401
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Cash & Equivalent
+Market Value of Your Portfolio
+$17,630
+$25,030
+Current market value
+Last statement's market value
+Important Message
+In an effort to deliver
+statements to you more
+efficiently, Bear Steams
+has enhanced the
+distribution of statements
+to household accounts.
+number/ Taxpayer
+identification number will
+be mailed in a single
+envelope. For further
+details, please contact your
+account executive.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suren s four or ratanal purposes rear de Set revere date for portant iformation.
+05/26/01;10:09 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brocklyn, New York 11201-3859
+027
+05/26/01:10:08 001|
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Cash Flow Analysis
+Opening Balance
+Funds Deposited
+Dividends/Interest
+Amount Credited
+Funds Withdrawn
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERICO
+517.629.79
+1,803,485.76
+3,914.74
+$1,807,400.50
+-1,800,000.00
+5-1.800 000.00
+7,400.50
+25.030.29
+Cash Balance Summary
+OPENING
+Cash
+Net Cash Balance
+17,629.79
+$17,629.79
+Income Summary
+Credit Balance Int.
+Total
+THIS PERIOD
+3,914.74
+83.914.74
+Portfolio Composition
+Cash/Cash Equivalent
+1.....
+.....
+027
+CLOSING
+25,030.29
+$25,030.29
+... ...
+YEAR TO DATE
+4,935.89
+$4,935.89
+25,030
+$25,030
+05/26/01;10:08 001
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD April 28, 2001
+THROUGH
+May 25, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 27, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+BATLEMENT TRIE
+05/22/01
+
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SYMBOLCUSP
+QUANTITY
+UNITED MIG SECS CORP
+SERIES 93-1 CL B-2
+0,001 DUE 11/25/03
+0262
+UNITED MG SECS CORP
+SERIES 93-1 CL B-2
+0.001 DUE 11/25/03
+ACAT REVERSAL
+PRICE
+ESTIMATE
+NNUAL INCON
+25,030
+$25,030
+$25,030
+SYMBOLICUSIP
+QUANTITY
+7,587,000
+-7,587,000
+PRICE
+027
+05/26/01;10:09 001
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD April 28, 2001
+THROUGH
+May 25, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 27, 2001
+CREDIT AMOUNT
+
+
+5 of 5
+Transaction Detail (continued)
+DEPOSITS AND WITHDRAWALS
+0501/01
+05/22/01
+FUNDS REC
+"FND WIRED"
+ENDS WIRED TO CITIBANK FROM
+WINDS WIRED TO
+GUSING ROST COMPANY
+INTEREST
+05/21/01
+DESCREST ON CREDIT BALANCE
+AT 3 1/2% 05/15 THRU 05/20
+05/21101
+INTEREST ON CREDIT BALANCE
+AT 4,000% 04/21 THRU 05/14
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+1,800,000.00
+$-1,800,000.00
+CREDIT AMOUNT
+1,803,485.76
+$1,803,485.76
+SYMBOUCUSIP
+QUANTITY
+RATE (%)
+3.5000
+4.0000
+STOP
+****** End of Statement******
+027
+05/26/01;10:08 001
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD April 28, 2001
+THROUGH
+May 25, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 27, 2001
+CREDIT AMOUNT
+1,062.32
+*..--.....
+2,852.42
+$3,914.74
+
+
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+....
+Transaction Detail
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD March 31, 2001
+THROUGH
+April 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30, 2001
+3
+4
+4
+Hollandlold
+INTERNATIONAL CHARITABLEINTS
+FINANCIAL TRUST CO TTEE
+DTD 4-28-94
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTE STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+17,630
+$17,630
+17,562
+67
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+$17,630
+$17,562
+Current market value
+Last statement's market value
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SPC This suremenis foul be ratanad troses records, Se reverse dide a ramportant information.
+
+
+027
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Cash Flow Analysis
+Opening Balance
+Funds Deposited
+Dividends/Interest
+Amount Credited
+Funds Withdrawn
+Amount Debited
+Net Cash Activity
+Closing Balance.
+THIS PERICO
+517.562.47
+150,000.00
+67.32
+8150-067.32
+-150,000.00
+$-150,000.00
+.....
+67.32
+17.629.75
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+17,562.47
+$17,562.47
+Income Summary
+Credit Balance Int.
+Total
+THIS PERIOD
+67.32
+$67.32
+Portfolio Composition
+Cash/Cash Equivalent
+T.....
+CLOSING
+17,629.79
+$17,629.79
+..--......
+YEAR TO DATE
+1,021.15
+$1,021.15
+17,630
+$17,630
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD March 31, 2001
+THROUGH
+April 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30,2001
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debit balance andlor short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SYMBOLCUSP
+QUANTITY
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+04/02/01
+FND WIRED
+0402/01
+"'FUNDS REC
+FNDS WIRED TO
+$ COMING FROM REPO
+WIRED TO CHIBANK FROM
+PRICE
+150,000.00
+$-150,000.00
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD March 31, 2001
+THROUGH
+April 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30,2001
+ANNER NOME
+17.630
+$17,630
+$17,629
+CREDIT AMOUNT
+150,000.00
+$150,000.00
+027
+
+
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Transaction Detail (continued)
+INTEREST
+04/23/01
+INTEREST ON CREDIT BALANCE
+AT 4.000% 04/18 THRU 04/20
+072301 N412. 097 PAUSANGE
+SYMBOL/CUSIP
+QUANTITY
+RATE (%)
+4.0000
+4.5000
+STOP
+****** End of Statement******
+027
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD March 31, 2001
+THROUGH
+April 27, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 30, 2001
+CREDIT AMOUNT
+5.85
+....
+61.47
+$67.32
+
+
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail
+Your Messages
+.........
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD February 24, 2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 23, 2001
+3
+Hollandlold
+INTERNATIONAL CHARITABLEINTS
+FINANCIAL TRUST CO TTEE
+DTD 4-28-94
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTE STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+17,562
+$17,562
+17,495
+68
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+$17,562
+$17,495
+Current market value
+Last statement's market value
+Important Notice
+Decimal Trading is Here for
+Nasdaq!
+Decimal Trading is the shift
+from fractional pricing
+(e.g. 21 1/2) to decimal
+pricing (e.g.$21.50)for
+equities and options.
+Nasdaq securities have
+been phased in during March
+and the remaining securities
+re scheduled to be trading
+ecimals in Apri
+For details, visit our website at
+www.bearstearns.
+com.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP This statement should beretanad ptr ye eards, So reverse dide tramportant information.
+03/31/01;17:01 001
+
+
+027
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+
+
+3 ofs
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance.
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+THIS PERICO
+517,494.67
+67.80
+$67.80
+67.80
+617.562.47
+Income Summary
+THIS PERIOD
+Credit Balance Int.
+67.80
+Total
+$67.80
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+YEAR TO DATE
+953.83
+... .
+.$953.83
+17,562
+$17.562
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+17,494.67
+$17,494.67
+CLOSING
+17,562.47
+...
+$17,562.47
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SIMBOLCUSP
+QUANTITY
+PRICE
+MARKET
+VALLE
+17.562
+$17,562
+AHMES NONE
+027
+LEARED THROUGH
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD February 24,2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 23,2001
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denote debe balance andor short
+from the absolute market value of your portolio.
+
+
+Bear, Stearns & Co. Ine.
+245 Park Avenue
+New York, New York 10167
+Your Portfolio Holdings (continued)
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+INTEREST
+03/21/01
+INTEREST ONCREDIT BALANCE
+AT 4 1/2% 03/20 THRU 03/20
+
+'INTEREST ON CREDIT BALANCE
+AT 5.000% 02/21 THRU 03/19
+SYMBOLICUSIP
+QUANTITY
+$17,562
+RATE (%)
+4.5000
+5.0000
+027
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD February 24, 2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 23, 2001
+CREDIT AMOUNT
+2.19
+......
+65.61
+$67.80
+
+
+ear, Stears & Co. In
+45 Park Avenue
+New York, New York 10167
+Your messages
+Bear, Stearns Securities Corp, Net Capital and
+Net Capital Requirements:
+At November 30, 2000 and January 26, 2001, the
+Company's net capital of $2,620,960,000 and
+$2,202,436,000, all respectively.
+A complete copy of the Bear, Stearns Securities
+Corp, Statement of Financial Condition is available
+on the web site www.bearstearns.com, Alternatively,
+to request a free printed copy please call -
+toll free 1-866-299-9331,
+STOP
+****** End of Statement******
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD February 24, 2001
+THROUGH
+March 30, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+February 23, 2001
+027
+
+
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+ZICHERMAN, IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ••••••••••••••••••••••I/I/
+Your Portfolio Holdings
+Transaction Detail
+Your Messages
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 26, 2001
+3
+4
+4
+Hollandlold
+INTERNATIONAL CHARITABLEINTS
+FINANCIAL TRUST CO TTEE
+DTD 4-28-94
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTE STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+17,495
+$17,495
+17,417
+77
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+$17,495
+$17.417
+Current market value
+Last statement's market value
+Flease report any dierence or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800 634-1428; or Writa to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP This statement should beretamad ptr your eards See reverse dide for mportant iformation.
+
+
+2 of 4
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+027
+
+
+3 of 4
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+17,417.38
+$17,417.38
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+THIS PERICD
+$17,417.38
+.......
+77.29
+$77.29
+77.29
+517494.67
+Income Summary
+THIS PERIOD
+Credit Balance Int.
+77.29
+Total
+$77.29
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+YEAR TO DATE
+886.03
+- ....
+.5886.03
+17,495
+$17,495
+CLOSING
+17,494.67
+517.494.67
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SIMBOLCUSP
+QUANTITY
+PRICE
+MARKE
+FALLE
+17,495
+$17,495
+AHMES NONE
+027
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 26, 2001
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+4 of 4
+Bear, Steams & Co. Inc
+245 Park Avenue
+New York, New York 10167
+Your Portfolio Holdings (continued)
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+INTEREST
+02/21/01
+INTEREST ON CREDIT BALANCE
+AT 5 1/2% 01/21 THRU 01/30
+022101 INTEREST ON CREDIT BALANCE
+T 5.000% 01/31 THRU 02/20
+SYMBOLICUSIP
+Your messages
+he interest, if any, charged to your accour
+QUANTITY
+$17,494
+RATE (%)
+5.5000
+5.0000
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 26, 2001
+CREDIT AMOUNT
+26.49
+50.80
+$77.29
+027
+
+
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstearns.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+....
+Transaction Detail
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 30, 2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 29, 2000
+3
+4
+4
+Hollandlold
+INTERNATIONAL CHARITABLEINTS
+FINANCIAL TRUST CO TTEE
+DTD 4-28-94
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTE STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+17,417
+$17,417
+16,609
+809
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+$17,417
+$16,609
+Current market value
+Last statement's market value
+Important Message
+Decimal Trading is Coming!
+Decimal Trading is the shift
+from fractional pricing
+(e.g.,21 1/2) to decimal
+pricing (e.g.,$21.50)for
+equities and options.
+All trading on NYSE, AMEX,
+and regional exchanges
+will be in decimals effective
+as of 1/29/01.
+For details, visit our website
+at www.bearsteams.com.
+Flease report any diference or non-receipt of checks or stocks, indicated as delivered to you,
+to Client Services at 800-634 1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP This statements out beretanad ptr ye eards See reverse dide tramportant riformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York: 11201-3859
+027
+
+
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+Cash Flow Analysis
+Opening Balance
+Funds Deposited
+Dividends/Interest
+Amount Credited
+Funds Withdrawn
+Miscellaneous
+mount Debite
+Net Cash Activity
+Closing Balance
+THIS PERICO
+316.608.64
+2,400,000.00
+808.74
+$2,400,808.74
+-150,000.00
+-2,250,000.00
+.................0000:00
+808.74
+$17.417.38
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+16,608.64
+$16,608.64
+Income Summary
+Credit Balance Int.
+Total
+THIS PERIOD
+808.74
+$808.74
+Portfolio Composition
+Cash/Cash Equivalent
+CLOSING
+17,417.38
+$17,417.38
+YEAR TO DATE
+808.74
+5808.74
+17,417
+... 517.417
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 30, 2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 29, 2000
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+Bear, Steams & Co. Inc.
+245 Park Avenue
+New York. New York 10167
+SIMBOLCUSP
+QUANTITY
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+01/04/01
+01/04101
+FND WIRED
+FUNDS REC
+ENDS WIRED TO
+ENDS WIRED TO CITIBANK FROM
+PRICE
+150,000.00
+$-150,000.00
+MARKE
+VALLE
+17,417
+$17,417
+$17,417
+ANNE MADE
+CREDIT AMOUNT
+400,000.00
+$2,400,000.00
+027
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+STATEMENT PERIOD December 30, 2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 29, 2000
+
+
+Transaction Detail (continued)
+INTEREST
+01/22/01
+01/22/01
+
+INTEREST ONCREDIT BALANCE
+AT 6.000% 12/29 THRU 01/02
+AT 5125. 0103 THR INCE
+TEREST ON CREDIT BALANC
+• 6.000% 12/21 THRU 12/2
+MISCELLANEOUS
+01/05/01
+TO
+PER LONAS OF 01/04/01
+STOP
+****** End of Statement******
+Bear, Stears & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+SYMBOL/CUSIP
+QUANTITY
+RATE (S)
+6.0000
+5.5000
+6.0000
+2,250,000.00
+$-2,250,000.00
+CRECIT AMOUNT
+027
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+STATEMENT PERIOD December 30,2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 29, 2000
+CAEDIT AMOUNT
+13.84
+389.42
+405.48
+$808.74
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/fa0a89d36957821579ce728537197adb3e34bb105323b41b2589046e0df121ba.receipt.json b/vision-fixhub/ds9-unparsed-05/fa0a89d36957821579ce728537197adb3e34bb105323b41b2589046e0df121ba.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..00127518542e5aa6c2b420f9cd8f37f28722f25d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fa0a89d36957821579ce728537197adb3e34bb105323b41b2589046e0df121ba.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -10756,
+  "dataset": "marble-joined",
+  "doc_id": "fa0a89d36957821579ce728537197adb3e34bb105323b41b2589046e0df121ba",
+  "engine": "marble-apple-vision",
+  "event_count": 81,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "c21ddc5607c7f2f67a1ab9533aae0f141dd8028ff691f635b5ebd38218bd044f",
+  "output_sha256": "521d4d96327ef73fccd5f490f1b8ce2269d5deb333496bd82e9389cfbeda256a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/fada68ad220bdc5b180ed714f7a56be7aadcc0803fcd0bfbcc4f7c0c6c62d1fb.md b/vision-fixhub/ds9-unparsed-05/fada68ad220bdc5b180ed714f7a56be7aadcc0803fcd0bfbcc4f7c0c6c62d1fb.md
new file mode 100644
index 0000000000000000000000000000000000000000..b1b3b0049c04005c2848183ae6a53173f289dc65
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fada68ad220bdc5b180ed714f7a56be7aadcc0803fcd0bfbcc4f7c0c6c62d1fb.md
@@ -0,0 +1,149 @@
+Dec 04 08 05:13p
+p.1
+Civil Trial Lawyer
+2290 10* Avenue North, Suite 404
+Lake Worth Elorida"
+FAX TRANSMITTAL COVER SHEET
+12/4108
+DATE:
+TO:
+FROM
+RE:
+EPSZEIN
+FAX NO.
+820 - 8222
+NUMBER OF PAGES INCLUDING THIS PAGE
+5
+IF YOU DO NOT RECEIVE ANY OF THE PAGES PROPERLY, PLEASE CALL (561) 582-7600
+AND ASK FOR:
+mIKE
+DOCUMENTS INCLUDED IN THIS TRANSMISSION ARE:
+ATTAINED ARE
+ALEASE
+E MAL
+AGREEMAIN WETJETS @ 10L.COM
+HANDLING INSTRUCTIONS:
+High priority (deliver immediately)
+Cal at procained
+Other
+The information contained in this transmission is attorney privileged and confidential. It is intended
+only for the use of the individual or entity named above. If the reader of this message is not the
+intended recipient, you are hereby notified that any dissemination, distribution, o copying of this
+communication is strictly prohibited. If you receive this communication in error, please notify us
+immediately by telephone (collect) and return the original message to us at the above address via the
+U.S. Postal Service. We will reimburse you for postage and/or telephone expenses. Thank you.
+Original will follow by mail
+Original will not follow by mail
+
+
+Dec 04 08 05:13p
+Case 9:08-CV-80736-KAM Document 26
+Entered on FLSD Docket 08/21/2008
+p.2
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA.
+NO. 08-80736-CIV-MARRA/JOHNSON
+IN RE: JANE DOES I AND 2,
+Petitioners.
+ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER
+THIS CAUSE comes before the Court on the Petitioners' ore tenus motion seeking the
+production of the Non-Prosecution Agreement between the United States Attorney's Office for the
+Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the
+Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
+Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
+including any modifications and addenda thereto, in accordance with the following procedures:
+(a)
+The USAO shall produce a copy of the Non-Prosecution Agreement,
+including any modifications and addenda thereto (collectively referred to as the "Agreement"), to
+the attorneys for Petitioners.
+(b) Petitioners and their attorneys shall not disclose the Agreement or its terms
+to any third party absent further court order, following notice to and an opportunity for Epstein's
+counsel to be heard.
+(c)
+Before counsel for petitioners show the Agreement to their clients or discuss
+the specific terms with them, they must provide a copy of this Order to petitioners, who must review
+and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
+petitioners must promptly provide a copy of that acknowledgment to the USAO.
+(d)
+If any individuals who have been identified by the USAO as victims of
+
+
+p.3
+Case 9:08-CV-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 2 of 2
+Epstein and/or any attorney(s) for those individuals request the opportunity to review the
+Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
+individuals also agree that they shall not disclose the Agreement or its terms to any third party
+absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
+(e) Prior to producing the documents to any other individuals who have been
+identified by the USAO as victims of Epstein and/or any attorneys) for those individuals, a copy
+of this Order must be provided to said individuals, who must review and acknowledge their receipt
+of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
+provide a copy of that acknowledgment to the USAO.
+DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
+this 21" day of August, 2008.
+KENNETH A. MARRA
+UNITED STATES DISTRICT JUDGE
+Copies furnished to: all counsel of record
+By signing below, I certify that I have reviewed and agree to be bound by the terms of this
+Dated 9/ 20/08
+Signed by
+Printed Nam
+12/4/08
+2
+
+
+p.4
+Case 9:08-cv.80736-KAM Document 26
+Entered on FLSD Docket 08/21/2008 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80736-CIV-MARRA/JOHNSON
+IN RE: JANE DOES 1 AND 2,
+Petitioners.
+ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER
+THIS CAUSE comes before the Court on the Petitioners' ore tenus motion seeking the
+production of the Non-Prosecution Agreement between the United States Attorney's Office for the
+Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the
+Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
+Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
+including any modifications and addenda thereto, in accordance with the following procedures:
+(a) The USAO shall produce a copy of the Non-Prosecution Agreement,
+including any modifications and addenda thereto (collectively referred to as the "Agreement"), to
+the attorneys for Petitioners.
+(b) Petitioners and their attorneys shall not disclose the Agreement or its terms
+to any third party absent further court order, following notice to and an opportunity for Epstein's
+counsel to be heard.
+(c)
+Before counsel for petitioners show the Agreement to their clients or discuss
+the specific terms with them, they must provide a copy of this Order to petitioners, who must review
+and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
+petitioners must promptly provide a copy of that acknowledgment to the USAO.
+(d)
+If any individuals who have been identified by the USAO as victims of
+
+
+p.5
+Case 9:08-cv-80736-KAM bocument 26
+Entered on FLSD Docnet 08/21/2008 Page 2 of 2
+Epstein and/or any attorney(s) for those individuals request the opportunity to review the
+Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
+individuals also agree that they shall not disclose the Agreement or its terms to any third party
+absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
+(e) Prior to producing the documents to any other individuals who have been
+identified by the USAO as victims of Epstein and/or any attorney(s) for those individuals, a copy
+of this Order must be provided to said individuals, who must review and acknowledge their receipt
+of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
+provide a copy of that acknowledgment to the USAO.
+DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
+this 21" day of August, 2008.
+KENNETH A. MARRA
+UNITED STATES DISTRICT JUDGE
+Copies furnished to: all counsel of record
+Order.
+• Dated:
+By signing below, I certify that I have reviewed and agree to be bound by the terms of this
+9/11/08
+Signed by
+Printed Nar
+2
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/fada68ad220bdc5b180ed714f7a56be7aadcc0803fcd0bfbcc4f7c0c6c62d1fb.receipt.json b/vision-fixhub/ds9-unparsed-05/fada68ad220bdc5b180ed714f7a56be7aadcc0803fcd0bfbcc4f7c0c6c62d1fb.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..026fb2c04bd25d0d346bf1a0b7014234d2cb5735
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fada68ad220bdc5b180ed714f7a56be7aadcc0803fcd0bfbcc4f7c0c6c62d1fb.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -123,
+  "dataset": "marble-joined",
+  "doc_id": "fada68ad220bdc5b180ed714f7a56be7aadcc0803fcd0bfbcc4f7c0c6c62d1fb",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "794a0f78d665878d2ff28f50eb272a0cd0c37bf1478c671fda4e51d7d8c1d868",
+  "output_sha256": "c72b5be510cf25b7bc1a4026bda2b7f9fcdb0b8b885fa1b8bda65d01bf5203cf",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/fb7b354d3c25dad09bd19e4757d7f8d2383bcfa740becc02c52bb0501d1843d3.md b/vision-fixhub/ds9-unparsed-05/fb7b354d3c25dad09bd19e4757d7f8d2383bcfa740becc02c52bb0501d1843d3.md
new file mode 100644
index 0000000000000000000000000000000000000000..c3a110638992d21c87d3a6a28a707f523871cf0a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fb7b354d3c25dad09bd19e4757d7f8d2383bcfa740becc02c52bb0501d1843d3.md
@@ -0,0 +1,2 @@
+Native Placeholder
+No Images Produced
diff --git a/vision-fixhub/ds9-unparsed-05/fb7b354d3c25dad09bd19e4757d7f8d2383bcfa740becc02c52bb0501d1843d3.receipt.json b/vision-fixhub/ds9-unparsed-05/fb7b354d3c25dad09bd19e4757d7f8d2383bcfa740becc02c52bb0501d1843d3.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..576ec54f4f40de31a6862348b1317a14a457bce3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fb7b354d3c25dad09bd19e4757d7f8d2383bcfa740becc02c52bb0501d1843d3.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "fb7b354d3c25dad09bd19e4757d7f8d2383bcfa740becc02c52bb0501d1843d3",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "c3de8f40875a39a42adde7d1a469a56d7d2be27188de8632381d9de2d2cc96a3",
+  "output_sha256": "846cc48c4d9439d88bbfa81198172eb50ef898abf3a9ac9c30fcf62adcd7ff8c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/fbccb22cd7f5fde34b85973f4f1049870bdd4dbf8825600cb50a493e90af7390.md b/vision-fixhub/ds9-unparsed-05/fbccb22cd7f5fde34b85973f4f1049870bdd4dbf8825600cb50a493e90af7390.md
new file mode 100644
index 0000000000000000000000000000000000000000..2de6555dee9301f20c79766bae07fe80e055c477
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fbccb22cd7f5fde34b85973f4f1049870bdd4dbf8825600cb50a493e90af7390.md
@@ -0,0 +1,73 @@
+From:
+Sent:
+To:
+Cc:
+Subject:
+Wednesday, November 26, 2008 11:56 AM
+Re: Jellrey Epstein
+Marie since receipt of your letter I have looked into the situation and the
+following is what is happening:
+Mr. Epstein has not breached the Non-Prosecution Agreement (the "Agreement") by
+serving a portion of his 18-month sentence of imprisonment in the Palm Beach
+County Work Release Program.
+1. He is currently serving his sentence in the Palm Beach County Work Release
+Program, not in the State-Regulated Community Control Program. Thus he is not on
+community control.
+• The County Jail sentence he is presently serving is being served under the
+auspices of the Palm Beach County Sheriff's Office.
+• The Palm Beach County Sheriff's Office has a policy of allowing work release
+under certain criteria for those sentenced to the Palm Beach County Detention
+Center or Stockade. It has already been determined that Mr. Epstein qualifies
+under the Palm Beach County Sheriff's Office policy for work release.
+The
+Florida statute authorizing work release for someone imprisoned in county jail is
+at 951.24 (2)(a).
+• The statute provides that when punishment by imprisonment in the county jail is
+prescribed, the sentencing court, in its discretion, may at any time during the
+sentence consider granting the privilege to the prisoner to leave the confines of
+the jail or county facility during necessary and reasonable hours, subject to the
+rules and regulations prescribed by the court, to work at paid employment or to
+conduct his or her own business or profession. See Fla. Stat. § 951.24(2)(a).
+• In Palm Beach County, the Sheriff's Office has discretion over work release.
+The local rules state that placement into House Arrest and Work Release "is at
+the discretion of the Sheriff and the presiding Judge" and offer no defined scope
+of the type of offenders that are eligible-or that are barred-from serving their
+time in Work Release." See Palm Beach County Department of Corrections Inmate
+Rule G-16.
+2. The Non Prosecution Agreement does not prohibit work release.
+• The Agreement does not regulate what programs Mr. Epstein can participate in
+while he is serving the County Jail sentence.
+3. The Agreement expressly provides that he is to be afforded the same benefits
+that any other inmate might receive. See 9 12 of the Agreement.
+
+
+5. Under Florida Law, work release is considered part of the confinement. See
+Rule 33-601.602, Fla. Admin.
+Code. (work release "allows inmates to work at paid employment in the community
+while continuing as inmates of the facility where they are confined."). So he is
+an inmate.
+6. Alex Acosta recognized that Mr. Epstein might serve a portion of his sentence
+through the Work Release Program.
+0. On December 6, 2007, after the Agreement had been executed, counsel received a
+draft notification letter in which US Attorney Acosta expresses this intention.
+The draft document provides that the recipient is "entitled to notification when
+Mr. Epstein is released from imprisonment at the end of his prison term and/or if
+he is allowed to participate in a work release program." See December 6, 2007
+letter to J.
+Lefkowitz from A. Acosta attaching draft notification letter, p. 8.
+7. I am told that on July 3, 2008, you wrote an email to the Deputy Sherriff
+stating that the US Attorney's Office had no objection to work release as long as
+Epstein is treated as any similarly situated inmate. If anything he is being
+treated more harshly than any other inmate in the program. He can't leave the
+office. He has a guard and is wearing a GPS device. So his terms are not more
+lenientbut rather more restrictive than any other inmate in the program.
+Clearly we do not feel this is a violation of the agreement and we have no intent
+to violate it. We will meet with you and anyone in the executive office to
+resolve this matter. Certainly it would be best for us to meet and discuss.
+>>>
+11/2
+Dear Roy:
+Please review
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
diff --git a/vision-fixhub/ds9-unparsed-05/fbccb22cd7f5fde34b85973f4f1049870bdd4dbf8825600cb50a493e90af7390.receipt.json b/vision-fixhub/ds9-unparsed-05/fbccb22cd7f5fde34b85973f4f1049870bdd4dbf8825600cb50a493e90af7390.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2ecb5465cea732fabc6da36475c3a6302c348e3a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fbccb22cd7f5fde34b85973f4f1049870bdd4dbf8825600cb50a493e90af7390.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "fbccb22cd7f5fde34b85973f4f1049870bdd4dbf8825600cb50a493e90af7390",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "7aa2c84377e93192ace28ea9311697a98f4e34592fbd1ae78adbec1635d5acbc",
+  "output_sha256": "2b2d0dd2fda351c4858c67391a54579d4195e6582ec0a067cc48e0978ed09b28",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/fbef4ec719a6c8bcd7e5975ee13bd3ac7f214abb065fce00dafcc343d5e36fa2.md b/vision-fixhub/ds9-unparsed-05/fbef4ec719a6c8bcd7e5975ee13bd3ac7f214abb065fce00dafcc343d5e36fa2.md
new file mode 100644
index 0000000000000000000000000000000000000000..7fb983c0d7cc68573b18a7631dded024d9a59ef5
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fbef4ec719a6c8bcd7e5975ee13bd3ac7f214abb065fce00dafcc343d5e36fa2.md
@@ -0,0 +1,136 @@
+1117/070
+• to Sarchez
+
+
+01/17/2007 15:58 FAX 5618021787
+************#********
+TX REPORT ta
+*****#*****
+USAO WPB FL
+0001
+TRANSMISSION OK
+TX/RX NO
+CONNECTION TEL
+SUBADDRESS
+CONNECTION ID
+ST. TIME
+USAGE T
+PGS. SENT
+RESULT
+3728
+
+01/17 15:57
+01'05
+3
+OK
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+A. Marie Villafaña
+500 S. Australian Ave, 4th Floor
+West Palm Beach, Florida 33401
+Facsimile (561) 820-8777
+FACSIMILE COVER SHEET
+TO:
+DATE:
+FAX NO.
+Lilly Aun Sanchez
+January 17, 2007
+305 728-7579
+PHONE NO. 305 789-9279
+# OF PAGES: _
+RE:
+Jeffrey Epstein
+FROM:
+PHONE NO.
+COMMENTS:
+
+
+U.S. Departmel
+I Justice
+United States Attorney
+Southern District of Florida
+A. Marie Villafaña
+500 S. Australian Ave, 4th Floor
+West Palm Beach, Florida 33401
+Facsimile (561) 820-8777
+FACSIMILE COVER SHEET
+TO:
+DATE:
+FAX NO.
+PHONE NO.
+FROM:
+PHONE NO.
+COMMENTS:
+Lilly Ann Sanchez
+# OF PAGES:
+RE:
+Jeffrey Epstein
+
+
+U.S. Departme
+f Justice
+United States Attorney
+Southern District of Florida
+500 South Australian Ave., Strite 400
+West Palm Beach, FL 33401
+Facsimile: (561) 820-8777
+January 17, 2007
+VIA FACSIMILE
+Lilly Ann Sanchez, Esq.
+Fowler White Burnett
+1395 Brickell Ave Fl 14
+Miami Florida 33131-3300
+Re: Jeffrey Epstein
+Dear Lilly:
+After our telephone conversation, I had the chance to confer with
+a, the AUSA
+ssigned to the Epstein investigation. During our conversation, you stated that your client wants 1
+operate with the investigation and is willing to provide documentation, but you felt that th
+requests were overly broad. We have shortened and narrowed the list, and I hope that you will abide
+by your earlier agreement to provide documents. Please provide the documents not later than
+January 25, 2007, so that we may review them in advance of the meeting on February 1st.
+If Mr. Epstein is unwilling to provide some of the requested documents, simply tell us which
+documents he is declining to provide or which do not exist.
+If you have any other questions, please contact
+rectly at
+Sincerely,
+R. Alexander Acosta
+United States Attorney
+B
+Assistant United States Attorney
+Enclosure
+CC:
+
+
+Document Requests: In re Jeffrey Epstein
+1.
+2.
+4.
+5.
+6.
+All documents and information provided to the Palm Beach County State
+Attorney's Office in connection with its investigation of Mr. Epstein.
+Subscriber information and telephone numbers for any "land lines," cellular
+telephones, Blackberry units, e-mail addresses, webpages, or the like for Mr.
+Epstein and all of his personal assistants (including but not limited to Samb
+and
+-rom January 1, 2003 to the present.
+The computers, hard drives, CPUs, and any other computer media (including CD-
+ROMs, DVDs, floppy disks, flash drives, etc.), if any, removed from 358 El Brillo
+Way, Palm Beach, Florida prior to the execution of the search warrant at that
+premises in October 2005.
+All calendars, diaries, and address books kept by Mr. Epstein and all of his
+personal assistants from January 1, 2003 to December 31, 2005, including
+electronic calendars and address books, whether stored on computer, PDA, or
+cellular telephone.
+For the period of January 1, 2003 to December 31, 2005, the names and contact
+information of all persons who performed or arranged for "massage services" for
+Mr. Epstein at 358 El Brillo Way, Palm Beach, Florida and documentation of
+payments made to or gifts given to any such persons.
+Names, dates of employment, and contact information for any persons who
+worked at 358 El Brillo Way, Palm Beach, Florida, at any time between January
+1, 2003 and December 31, 2005.
+Information regarding bank accounts used by Mr. Epstein and/or his employees to
+pay "petty cash" expenses, including fees for "massage services," incurred in
+Palm Beach, Florida, from January 1, 2003 to the present.
diff --git a/vision-fixhub/ds9-unparsed-05/fbef4ec719a6c8bcd7e5975ee13bd3ac7f214abb065fce00dafcc343d5e36fa2.receipt.json b/vision-fixhub/ds9-unparsed-05/fbef4ec719a6c8bcd7e5975ee13bd3ac7f214abb065fce00dafcc343d5e36fa2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..15bf0fc34c228c1f48141907571ca5cb96b65b32
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fbef4ec719a6c8bcd7e5975ee13bd3ac7f214abb065fce00dafcc343d5e36fa2.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -71,
+  "dataset": "marble-joined",
+  "doc_id": "fbef4ec719a6c8bcd7e5975ee13bd3ac7f214abb065fce00dafcc343d5e36fa2",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "4f6ac362a2e67d6f80311e93fde6a433db76cb5e8ebb6b48e7a54c27c6581697",
+  "output_sha256": "cfe451d14d1e4c9642b78d5e01e084021862fbd7042ba5f1dfbc80b3619e13dc",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/fc309e3f6ec0cb28689437f7e83c77970869e77a6fdbac8d808094cc0cc3546a.md b/vision-fixhub/ds9-unparsed-05/fc309e3f6ec0cb28689437f7e83c77970869e77a6fdbac8d808094cc0cc3546a.md
new file mode 100644
index 0000000000000000000000000000000000000000..85306b6f02656fab752f5360e9b0c64c6c7dc61f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fc309e3f6ec0cb28689437f7e83c77970869e77a6fdbac8d808094cc0cc3546a.md
@@ -0,0 +1,517 @@
+Statements
+
+
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summar.........................
+Your Portfolio Holdings
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocktyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD December 1,2005
+THROUGH
+December 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30,2005
+#olholllmlll
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Closing Balance
+THIS PERIOD
+$-0.02
+$-0.02
+Income Summary
+Margin Int. Paid
+Portfolio Composition
+THIS PERIOD
+0.00
+SHORT
+YEAR TO DATE
+-0.02
+LONG
+If any information regarding
+2005interest, dividends,
+miscellaneous income, gross
+eported to the IRS for this
+account, a Consolidated Form
+1099will be mailed to you by
+January 31,2006or a 1042S
+by March 15,2006.
+Cash Balance Summary
+Margin
+Not Casi Balance
+OPENING
+-0.02
+$-0.02
+CLOSING
+-0.02
+.. . . .
+$-0.02
+•......•••••••
+STP Thie urener s foul er ratanel ptr yer rebr de Set revere date for postamt itformation.
+12/31/05:09:00 001
+V999
+
+
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD December 1, 2005
+THROUGH
+December 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30, 2005
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+QUANTITY
+PRICE
+MARKET
+VALUE
+ESTIMATE
+NNUAL INCOM
+STOP
+****** End of Statement******
+027
+12/31/05:09:00001
+v999
+
+
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+12/31/05:09:00 001
+V899
+
+
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summar •••••••••••..•..................
+Your Portfolio Holding ..........................
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+@rocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 1, 2005
+THROUGH
+September 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 30,2005
+#olholllmlll
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Closing Balance
+THIS PERIOD
+$-0.02
+$-0.02
+Income Summary
+Margin Int. Paid
+THIS PERIOD
+0.00
+VEAR TO DATE
+-0.02
+Portfolio Composition
+Cash Balance Summary
+Margin
+Net Cash Balance
+OFENING
+-0.02
+$-0.02
+SHORT
+LONG
+CLOSING
+-0.02
+.. . .
+$-0.02
+STP Thie urener s foul er ratanel ptr yer rebr de Set revere date fr postamt itformation.
+10/01/05;11:50 001
+V99G
+
+
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 1, 2005
+THROUGH
+September 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 30, 2005
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SIMBCLCUSIP
+QUANTITY
+PRICE
+MARKET
+VALUE
+ESTIMATED
+ANIVUAL INCOME
+JAREN
+ELD I
+STOP
+****** End of Statement******
+027
+10/01/05:11:50 001
+V996
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+10/01/05:11:50 001
+V996
+
+
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary.............................
+Your Portfolio Holdings
+Transaction Detail
+Your Messages
+...
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 1,2005
+THROUGH
+June 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31,2005
+1
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+... . .
+Dividends/Interest Charged
+Amount Debited
+Net Cash Activity
+... ...
+Closing Balance
+THIS PERIOD
+$0.00
+-0.02
+$-0.02
+-0.02
+$-0.02
+Income Summary
+Margin Int. Paid
+Portfolio Composition
+THIS PERIOD
+-0.02
+SHORT
+VEAR TO DATE
+-0.02
+LONG
+Confirmation: Unless we hear
+from you to the contrary, it is
+our understanding that any
+free credit balances in your
+account are being maintained
+to facilitate your intention to
+invest such amounts through
+us.
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+0.00
+$0.00
+CLOSING
+-0.02
+$-0.02
+SIP The surren s four or ratanal purposes rear de Set revere date for portant iformation.
+07/01/05;10:42 001
+
+
+
+2 ora
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SIMBCLCUSIP
+QUANTITY
+PRICE
+MARKET
+VALUE
+Transaction Detail
+INTEREST
+DATE
+DESCRIPTION
+06/01/05
+AVG BAL
+300 RT 2.400
+021 OFFICE INTEREST 0505
+TOTAL
+SYMBOUCUSIP
+QUANTITY
+RATE (%)
+027
+ESTIMATED
+ANNUAL INCOME
+JARE
+ELD I
+DEBIT AMOUNT
+0.02
+$-0.02
+07/01/05;10:42 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 1,2005
+THROUGH
+June 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 31, 2005
+CREDIT AMOUNT
+93(P
+
+
+3 of 4
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your messages
+Bear Stearns receives payments or other remuneration from the advisers,
+distributors or other affiliates of certain of the mutual funds available through
+Bear Steams, Such payments or remuneration are for administrative,
+technological or other services provided in connection with fund accounts anc
+are generally calculated based on the amount of assets held in the accounts
+Such payments or other remuneration are in addition to shareholder servicing
+and distribution fees that Bear Stearns may receive. Funds whose affiliates do
+not make payments to Bear Steams, including funds that may pay a higher or
+lower return, may be available to you,
+• If Bear Stearns makes changes in any of the credit terms and conditions
+Except as described above, the Truth in Lending disclosure previously provided
+to you remains in effect.
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 1,2005
+THROUGH
+June 30, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+May 31, 2005
+NOTICE OF CHANGE PURSUANT TO TRUTH IN LENDING SEC RULE 10b-16
+Effective no earlier than thirty (30) days from your receipt of this statement,
+the annual rate of interest charged on any credit extended to you by Bear
+Stearns for the purpose of purchasing, carrying or trading in any security or
+other property shall be based on either the Bear Stearns Margin Basis Rate,
+the Bear Stearns Fed Funds Rate or the London Interbank Offering Rate
+(LIBOR"), as notified to you upon request, The Bear Stearns Margin Basis Rate
+will be quoted daily by Bear Stearns at our main office in New York, Factors
+affecting the determination of the Bear Stearns Margin Basis Rate will include
+he short-term market interest rates quoted by money center banks and th
+ederal Reserve and the rate that Bear Stears is charged for borrowin
+money. The Bear Stearns Fed Funds Rate is the rate for U.S. dollar funds, as
+quoted by an independent broker of such funds selected by Bear Stearns for
+the last transaction completed prior to 9:30 a,m, (Eastern Time) on the
+business day on which such rate is determined, The annual rate of interest will
+be no more than 3% above the Bear Stears Margin Basis Rate or 4% above
+either the Bear Stearns Fed Funds Rate or LIBOR and will appear on your
+monthly statements.
+027
+07/01/05:10:42 001
+49931
+
+
+4 of 4
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+07/01/05;10:42 001
+
+
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summ...........................
+Transaction Detail
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocktyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 30, 2005
+THROUGH
+May 31,2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 31, 2004
+Holmallmld
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Cash Flow Analysis
+Opening Balance
+Miscellaneous
+Amount Credited
+Miscellaneous
+Amount Debited
+Closing Balance
+THIS PERICO
+$0.00
+300.00
+$300.00
+-300.00
+-300.00
+$0.00
+STP The suren s houe er ratanel ptr yer rebr die Set rere date fr potamt itomation.
+06/01/05:09:09 001
+V878
+
+
+Transaction Detail
+MISCELLANEOUS
+DATE
+MO/DAY
+05/25/05
+05/26/05
+TRANSACTIOR
+OURNAL
+JOURNAL
+TOTAL
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCRIPTION
+APR 05 SPEC CLEARING FEES
+CORRECT PRIOR ENTRY 5/25
+APR 05 SPEC CLEAR FEES
+DEBIT AMOUNT
+300.00
+$-300.00
+STOP
+End of Statement******
+027
+CRECIT AMOUNT
+300.00
+5300.00
+06/01/05:09:03 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 30, 2005
+THROUGH
+May 31, 2005
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+March 31, 2004
+V978
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+06/01/05:09:03 001|
+V979
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/fc309e3f6ec0cb28689437f7e83c77970869e77a6fdbac8d808094cc0cc3546a.receipt.json b/vision-fixhub/ds9-unparsed-05/fc309e3f6ec0cb28689437f7e83c77970869e77a6fdbac8d808094cc0cc3546a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..8fabf1cb268be84fba2ca0a126afb9ba9ca56039
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fc309e3f6ec0cb28689437f7e83c77970869e77a6fdbac8d808094cc0cc3546a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -460,
+  "dataset": "marble-joined",
+  "doc_id": "fc309e3f6ec0cb28689437f7e83c77970869e77a6fdbac8d808094cc0cc3546a",
+  "engine": "marble-apple-vision",
+  "event_count": 16,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "d4df7011d441d0f41acb22f1632f687d27fee6e1d631b70d8028e0cb50437148",
+  "output_sha256": "3b1e73a5c1726b90fc4da8fb72e7164f5c8db793a34031699a54fcc184b5aa29",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/fc4107c745223f56ea3bd5958d35e90edbdc2d3100113404029ad9171c96d4e1.md b/vision-fixhub/ds9-unparsed-05/fc4107c745223f56ea3bd5958d35e90edbdc2d3100113404029ad9171c96d4e1.md
new file mode 100644
index 0000000000000000000000000000000000000000..1bd1c5aa4a6fc95c0c7a1745f7c805dae70cb123
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fc4107c745223f56ea3bd5958d35e90edbdc2d3100113404029ad9171c96d4e1.md
@@ -0,0 +1,109 @@
+OLY-18
+
+
+TO:
+West Palm Beach, FL
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 05-02(WPB)-Fri./No. OLY-018
+SUBPOENA FOR:
+PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+ROOM:
+Room 4-A
+Palm Beach County Courthouse
+Juvenile Courts Building
+205 N. Dixie Highway
+West Palm Beach, Florida 33401
+(Temporary location for the United States District Courthouse, West Palm Beach)
+DATE AND TIME:
+September 22, 2006
+9:30am
+YOU ARE ALSO COMMANDED to bring with you the following documents) or objects):
+All documents and information referring or relating to
+including but not limited to medical records, billing records and
+information, payment records and information, and records in electronic storage.
+Please coordinate vour compliance of this subpoena and confirm the date and time of your appearance with
+Federal Bureau of Investigation, Telephone)
+Special Agent
+Please see additional information on reverse
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+HAN OBTINCT COUNTE
+(BY) DEPUTY CLERK
+DATE:
+September 13, 2006
+This subpoena is issued upon application
+of the United States of Ameriza
+*If not applicable, enter "none."
+Name, Address and Phone Number of Assistant II.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach, FL 33401-6235
+Tel:
+x3047
+Fax:
+To be used in licu of AO110
+FORM ORD-227
+JAN.86
+
+
+U.S. Departm. of Justice
+United States Attorney
+Southern District of Florida
+APPEARANCE NOTICE
+The attached subpoena requires the production of the records specified to a Federal
+Grand Jury/Trial in the Southern District of Florida.
+A new provision of the Federal Rules of Evidence provides that routine business
+records may be admitted at trial through the declaration of a custodian, if they are provided
+sufficiently in advance of trial to allow an opportunity for any challenges to their
+authenticity. Therefore, you may be able to avoid appearing personally at the grand
+jury/trial at the time and place specified by completely filling out the attached Certification
+and Inventory and immediately returning it with the records to Special Agent Wait
+FBI at the following address:
+Federal Bureau of Investigation
+505 South Flagler Drive, Ste. 500
+West Palm Beach, Florida 33401-5923
+EARLY VOLUNTARY TURNOVER
+Please note that we are requesting an early voluntary turnover of the materials
+subpoenaed. The early voluntary turnover date is prior to September 22, 2006.
+Sincerely,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+BY:
+ASSISTANT UNITED STATES ATTORNEY
+
+
+CERTIFICATION OF BUSINESS RECORDS
+I, the undersigned,
+employed bylassociated with
+position of
+, declare that l am:
+in the
+and by reason of my
+position am authorized and qualified to make this declaration.
+In my employment with the above-named bank/company I am familiar with the
+business records it maintains. The above-named bank/company maintains records of its
+business which are:
+1. made at or near the time of the occurrence of the matters set forth therein, by,
+or from information transmitted by, a person with knowledge of those matters;
+2. kept in the course of regularly conducted business activity; and
+3. made by the regularly conducted activity as a regular practice.
+Among the records so maintained are the attached records itemized in Appendix A,
+Inventory of Documents.
+I declare under penalty of perjury that the foregoing is true and correct.
+Date of execution:
+Place of execution:
+Signature:
+-
+
+
+APPENDIX A
+DOCUMENT INVENTORY
+The documents submitted are as follows:
+Signature of Records Custodian:
diff --git a/vision-fixhub/ds9-unparsed-05/fc4107c745223f56ea3bd5958d35e90edbdc2d3100113404029ad9171c96d4e1.receipt.json b/vision-fixhub/ds9-unparsed-05/fc4107c745223f56ea3bd5958d35e90edbdc2d3100113404029ad9171c96d4e1.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..eceacffc03e28625a341271fcdae42c1b19a3f1f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fc4107c745223f56ea3bd5958d35e90edbdc2d3100113404029ad9171c96d4e1.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -60,
+  "dataset": "marble-joined",
+  "doc_id": "fc4107c745223f56ea3bd5958d35e90edbdc2d3100113404029ad9171c96d4e1",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3503bc2e9c90af59464f2c8a3d4b547f09debafb0380fb266fc1791190ef2399",
+  "output_sha256": "d9d932843aebdb950096d33240510327fd95c2debf918b61b7999e88e4bee41c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/fcc86fdad4b65ff5b71d8ad725f2ffbf53469181becb7e1e9f2d1dffdb1ff611.md b/vision-fixhub/ds9-unparsed-05/fcc86fdad4b65ff5b71d8ad725f2ffbf53469181becb7e1e9f2d1dffdb1ff611.md
new file mode 100644
index 0000000000000000000000000000000000000000..53cea79cf5cd1791816bb2232750b229d8b224e7
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fcc86fdad4b65ff5b71d8ad725f2ffbf53469181becb7e1e9f2d1dffdb1ff611.md
@@ -0,0 +1,652 @@
+Statements
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 1,2004
+THROUGH
+October 29, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+September 30, 2004
+FINANCIAL TRUST CO INC
+ATT F.I. CLEARING SERVICES
+1 METROTECH CENTER N
+C/O OFFICE
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PLACHASE'
+AEPURCHASE
+PRICING
+PURCHASE PRICEL
+ACCAUED REPO
+START DATE
+DATE
+RATE
+PRINCIPAL
+INTEREST
+YOU PROVIDED
+(MARGIN)
+04/05/04 OPEN
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASE TRANSACTIONS
+*As of statement date
+0.000
+$0
+$0
+$0
+$0
+QUANTITY
+(FACE AMOUNT
+-100,000,000
+CUSP
+DESCRIPTION
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT 1.0000 03/15/32
+STOP
+****** End of Statement******
+SIP The suremen s four or ratanal furycer rear die Set revere date for portant iformation.
+10/3004;11:50 001
+V964
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+10/30/04:11:50 001
+V964
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 1, 2004
+THROUGH
+September 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+August 31, 2004
+FINANCIAL TRUST CO INC
+ATT F.I. CLEARING SERVICES
+1 METROTECH CENTER N
+C/O OFFICE
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PLACHASE
+AEPURCHASE
+PRICING
+PURCHASE PRICEL
+ACCRUED REPO
+START DATE
+DATE
+RATE
+PRINCIPAL
+INTEREST
+YOU PROVIDED
+(MARGIN)
+04/05/04 OPEN
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASE TRANSACTIONS
+*As of statement date
+0.000
+$0
+$0
+$0
+$0
+QUANTITY
+(FACE AMOUNT
+-100,000,000
+CUSP
+DESCRIPTION
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT 1.0000 03/15/32
+STOP
+****** End of Statement******
+SIP The suremen s four or ratanal furycer rear die Set revere date for portant formation.
+10/01/04:07:49 001
+V963
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+10/01/04;07:49 001
+V963
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD July 31, 2004
+THROUGH
+August 31, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+July 30, 2004
+FINANCIAL TRUST CO INC
+ATT F.I. CLEARING SERVICES
+1 METROTECH CENTER N
+C/O OFFICE
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PLACHASE
+AEPURCHASE
+PRICING
+PURCHASE PRICEL
+ACCAUED REPO
+START DATE
+DATE
+RATE
+PRINCIPAL
+INTEREST
+YOU PROVIDED
+(MARGIN)
+04/05/04 OPEN
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASE TRANSACTIONS
+*As of statement date
+0.000
+$0
+$0
+$0
+$0
+QUANTITY
+(FACE AMOUNT
+-100,000,000
+CUSP
+DESCRIPTION
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT 1.0000 03/15/32
+STOP
+****** End of Statement******
+SIP The suremen s four or ratanal furyce rear die Set revere date for portant iformation.
+09/01/04;08:31 001
+V962
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+09/01/04;08:31 001
+V962
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD July 1,2004
+THROUGH
+July 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+June 30, 2004
+FINANCIAL TRUST CO INC
+ATT F.I. CLEARING SERVICES
+1 METROTECH CENTER N
+C/O OFFICE
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PLACHASE
+AEPURCHASE
+PRICING
+PURCHASE PRICEL
+ACCAUED REPO
+START DATE
+DATE
+RATE
+PRINCIPAL
+INTEREST
+YOU PROVIDED
+(MARGIN)
+04/05/04 OPEN
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASE TRANSACTIONS
+*As of statement date
+0.000
+$0
+$0
+$0
+$0
+QUANTITY
+(FACE AMOUNT
+-100,000,000
+CUSP
+DESCRIPTION
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT 1.0000 03/15/32
+STOP
+****** End of Statement******
+SIP The suremen s four or ratanal furyce rear die Set revere date for portant iformation.
+07/31/04;08:41 001
+vese
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+07/31/04:08:41 001
+V958
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Your Messages ..............
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 29,2004
+THROUGH
+June 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+May 28, 2004
+2
+FINANCIAL TRUST CO INC
+ATT F.I. CLEARING SERVICES
+1 METROTECH CENTER N
+C/O OFFICE
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PLACHASE'
+AEPURCHASE
+PRICING
+PURCHASE PAICEY
+ACCAUED REPO
+START DATE
+DATE
+RATE
+PRINCIPAL
+INTEREST*
+YOU PROVIDED
+(MARGIN)
+04/05/04 OPEN
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASETRANSACTIONS
+"As of statement dato
+0.000
+$0
+$0
+$0
+$0
+QUANTITY
+(FACE AMOUNT
+-100,000,000
+CUSP
+DESCRIPTION
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT 1.0000 03/15/32
+SIP The suremen is four for ratanal purpose red de Set revere ase for portant iformation.
+V932
+
+
+2 org
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your messages
+Notice Regarding a Change in The Statement of Interest Charges
+Pursuant to the "Truth-in-Lending" Rule 10 (b)-16 Regarding Short Sales
+And Marking-To-The-Market
+ffective no earlier than thirty (30) days from your receipt of this statement, w
+will compute interest regarding your short sales and marking-to-the market a
+follows:
+The credit that appears on your statement due to short sales (including short
+sales against the box) is offset by a debit of like amount because Bear Steams
+Securities has to borrow the same security in order to deliver it to the buying
+broker and has to provide its lender additional collateral of up to 105% of the
+settled short market value of the borrowed securities to secure such loan, This
+means that the debit balance on which interest is computed will be the
+difference between (i) up to 105% of the settled short market value of such
+short sales (across all currencies), which shall be calculated daily, and (ii) the
+proceeds of such short sales,
+STOP
+****** End of Statement******
+18P
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 29,2004
+THROUGH
+June 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+On File
+May 28,2004
+Any short positions in your account will be kept "marked-to-the market", This
+means that periodically the balance maintained in the short account will be
+adjusted to equal the market value of the short securities. Securities that are
+priced below five dollars per share may be valued at five dollars per share for
+short marking-to-the market purposes. If a security has been sold short (o
+sold short against the box) and has appreciated in market price over the
+selling price, interest will be charged on the amount of appreciation; if it
+depreciates in market price, interest will be correspondingly reduced by the
+drop in value. The appreciation or depreciation of securities sold short will be
+determined by Bear Stearns Securities based upon daily closing prices or
+quotations provided by pricing services, as applicable, or upon such factors as
+Bear Stearns Securities in its sole judgement deems pertinent.
+Please note that the other sections of the "Truth-in-Lending" disclosure
+previously provided to you remain unchanged,
+027
+V832
+
+
+3 of 3
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+V832
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD May 1, 2004
+THROUGH
+May 28, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+April 30, 2004
+FINANCIAL TRUST CO INC
+ATT F.I. CLEARING SERVICES
+1 METROTECH CENTER N
+C/O OFFICE
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PLACHASE
+AEPURCHASE
+PRICING
+PURCHASE PRICE
+ACCAUED REPO
+START DATE
+DATE
+RATE
+PRINCIPAL
+INTEREST
+YOU PROVIDED
+(MARGIN)
+04/05/04 OPEN
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASE TRANSACTIONS
+*As of statement dabo
+0.000
+$0
+$0
+$0
+$0
+QUANTITY
+(FACE AMOUNT
+-100,000,000
+CUSP
+DESCRIPTION
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT 1.0000 03/15/32
+STOP
+****** End of Statement******
+SIP The wireman is four or ratanal furyce rear die Set revere date for portant iformation.
+05/29104;12:32 001
+V931
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+05/29/04;12:32 001
+V831
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD April 1, 2004
+THROUGH
+April 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+January 30, 2004
+FINANCIAL TRUST CO INC
+ATT F.I. CLEARING SERVICES
+1 METROTECH CENTER N
+C/O OFFICE
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearns& Co. Inc. outstanding as of date of statement
+PUACHASE
+AEPURCHASE
+PRICING
+PURCHASE PRICE
+ACCAUED REPO
+START DATE
+DATE
+RATE
+PRINCIPAL
+INTEREST
+YOU PROVIDED
+(MARGIN)
+04/05/04 OPEN
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASE TRANSACTIONS
+*As of statement date
+0.000
+$0
+$0
+$0
+$0
+QUANTITY
+(FACE AMOUNT
+-100,000,000
+CUSP
+DESCRIPTION
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT 1.0000 03/15/32
+STOP
+****** End of Statement******
+SIP The suremen s four or ratanal furyce rear die Set revere date for portant formation.
+027
+05/01/04;13:17 001
+V830
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+05/01/04:13:17 001
+V830
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Your Messages ..............
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 1, 2004
+THROUGH
+January 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2003
+2
+FINANCIAL TRUST CO INC
+ATT F.I. CLEARING SERVICES
+1 METROTECH CENTER N
+C/O OFFICE
+Repurchase and Reverse Repurchase Transactions
+with Bear, Stearnsand Co. Inc. outstanding as of date of statement
+PLACHASE/
+AEPURCHASE
+PRICING
+PUACHASE PAICES
+ACCAUED REPO
+START DATE
+DATE
+RATE
+FRINCIPAL
+INTEREST'
+YOU PROVIDED
+(MARGIN)
+10/23/03
+OPEN
+TOTAL REVERSE REPURCHASE TRANSACTIONS
+TOTAL REPURCHASE TRANSACTIONS
+"As of statement dato
+0.000
+$0
+$0
+$0
+$0
+QUANTITY
+(FACE AMOUNT
+-8,345,000
+CUSP
+31393FAF3
+DESCRIPTION
+FEDERAL HOME LOAN MIG CORP
+SERIES 2530 CLASS SE 6.3000 02/15/32
+SP The suremen s four or ratanal purpose red de Set revere date for portant iformation.
+01/31/04;09:20 001
+V924
+
+
+2 of 3
+ear, Steams & Co. In
+83 Madison AvenL
+New York, New York 10179
+Your messages
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD January 1,2004
+THROUGH
+January 30, 2004
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+LAST STATEMENT
+December 31, 2003
+STOP
+****** End of Statement******
+027
+01/31/04:09:20 001
+V824
+
+
+3 of 3
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+01/31/04:09:20 001
+V924
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/fcc86fdad4b65ff5b71d8ad725f2ffbf53469181becb7e1e9f2d1dffdb1ff611.receipt.json b/vision-fixhub/ds9-unparsed-05/fcc86fdad4b65ff5b71d8ad725f2ffbf53469181becb7e1e9f2d1dffdb1ff611.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..970a0a7ec579917c6aef68270cae1d27ff432e9e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fcc86fdad4b65ff5b71d8ad725f2ffbf53469181becb7e1e9f2d1dffdb1ff611.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1102,
+  "dataset": "marble-joined",
+  "doc_id": "fcc86fdad4b65ff5b71d8ad725f2ffbf53469181becb7e1e9f2d1dffdb1ff611",
+  "engine": "marble-apple-vision",
+  "event_count": 20,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "a50b8bd2668aeaa5c95db4eced3977f3ac70c7fdc68a1f7308de1e683aa4dd92",
+  "output_sha256": "068578c3ad1797ae784741c8e61e503340cae35fe850c7141136dc5e76ebeba0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/fd1f27d155e7ea34d1aff30a9756924cf8d2684cae61d24c178932a63e7a8990.md b/vision-fixhub/ds9-unparsed-05/fd1f27d155e7ea34d1aff30a9756924cf8d2684cae61d24c178932a63e7a8990.md
new file mode 100644
index 0000000000000000000000000000000000000000..580eefacb4f3fb6760b4451576299dd2aa0217ed
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fd1f27d155e7ea34d1aff30a9756924cf8d2684cae61d24c178932a63e7a8990.md
@@ -0,0 +1,44 @@
+OLY-72
+XH
+JANE DOE #6
+
+
+TO:
+United States District Court
+SOUTHERN DISTRICT OF FLORIDA
+SUBPOENA TO TESTIFY
+BEFORE GRAND JURY
+FGJ 07-103(WPB)-Tues./No. OLY-72
+SUBPOENA FOR:
+x PERSON
+DOCUMENTS OR OBJECTISI
+YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
+Court at the place, date and time specified below.
+PLACE:
+United States District Courthouse
+701 Clematis Street
+West Palm Beach, Florida 33401
+ROOM:
+Grand Jury Room
+DATE AND TIME:
+S. pmber 1, 2007
+YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):
+Please coordinate you special Age with this subpoem and confarm treate and tinction, telepion c
+ederal Bureau of Investigation, Telephon
+This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf
+of the court.
+CLERK
+DATE:
+August 16, 2007
+(BY) DEPUTY CLERK
+This subpoena is issued upon application
+of the United States of America
+*If not applicable, enter "none."
+Name, Address and Phone Number of Assistant U.S. Attorney
+500 So. Australian Avenue, Suite 400
+West Palm Beach. EL. 33401-6235
+Tel:
+Fax:
+To be med in lieu of ADI10
+FORM ORD-227
+JAN.86
diff --git a/vision-fixhub/ds9-unparsed-05/fd1f27d155e7ea34d1aff30a9756924cf8d2684cae61d24c178932a63e7a8990.receipt.json b/vision-fixhub/ds9-unparsed-05/fd1f27d155e7ea34d1aff30a9756924cf8d2684cae61d24c178932a63e7a8990.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4df3aded54e44924e327daed45d51344f22422f8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fd1f27d155e7ea34d1aff30a9756924cf8d2684cae61d24c178932a63e7a8990.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "fd1f27d155e7ea34d1aff30a9756924cf8d2684cae61d24c178932a63e7a8990",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "777ce74bc6e691deb1de04ddf1584182387e664bd71dbc40278be0784d94ce0a",
+  "output_sha256": "1fba875a4aed00af3a326cd0fa4a39452a13b907f1d2a61337cf9ab9bb79d06d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/fd462f01cbb39a93b6c12a686d42febc1b5866819aff9306fc892031bd0cd57a.md b/vision-fixhub/ds9-unparsed-05/fd462f01cbb39a93b6c12a686d42febc1b5866819aff9306fc892031bd0cd57a.md
new file mode 100644
index 0000000000000000000000000000000000000000..eecbe62edc8cc902e85da5425af437c8706abd45
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fd462f01cbb39a93b6c12a686d42febc1b5866819aff9306fc892031bd0cd57a.md
@@ -0,0 +1,233 @@
+00/ 24/ 200/ 03;11
+rULE FALM BEACH
+PAGE U1
+FOLE
+Florida Department of Law Enforcement
+alm Beach Field Office
+1400 Centrepark Boulevard, Suite #600
+West Palm Beach, Florida 33401
+Phone:
+SunCom:
+Fax:
+SunCom Fax #|
+To:
+From:
+Date: 5/23/07
+Information Only
+Per Your Request
+Please Call After Review
+URGENT
+# of pages (including cover page):
+I CONFIDENTIAL
+Comments:
+- Can orily query database w/ 5sN #'s-50
+Nada on Nada:
+- Also-pIs send me a case #
+- Wow on
+4th gtre of 2006 !
+Confirmațion Requested:
+Yes
+No
+
+
+05/ 24/ 200/ 09:11
+FULE MALM BEACH
+File List
+UTCR
+NEXT:
+UIMAM44
+SSN:
+UC Tax SSN Detail
+Employee Name
+EMPLOYER NAME/ADDRESS
+FASHIONS OUTLET OF AMBRICA INC
+C/O SHEAKLEY UNISERVICE INC
+PO BOX 1160
+COLUMBUS
+Acct ID
+•A R
+Qtr/YI
+4 2006
+OH 43216
+PAGE UZ
+VL: 0 05/24/0
+18: 55:5
+Wages
+815.31
+H CT
+01 HELP 03 BXIT
+S12 FIND
+UTCR
+NEXT:
+UTMAM44
+SSN:
+07 BWD
+08 FWD
+UC Tax SSN Detail
+Employee Name
+EMPLOYER NAME/ADDRESS
+JEFPREY E EPSTEIN
+Acat ID
+A
+358 EL BRILLO WAY
+PALM BEACH
+FL 33480
+S03 MENU 505 SUSP 506 RESM S11 CMEM
+IVL: 0 05/24/07
+08:56:04
+Qtx/xx
+2 2005
+3 2005
+4 2005
+1 2006
+Wages
+9,423.12
+11,038.51
+9,461.58
+7,884.65
+H CT
+' 01 HELP 03 EXIT
+07 BWD
+S12 FIND
+UTCR
+NEXT:
+UTMAM44
+SSN:
+08 FWD
+S03 MENU
+UC Tax SSN Detail
+Employee Name
+EMPLOYER NAME/ADDRESS
+WILLIAM P OWENS CPA PA
+C/O WILLIAM P OWENS
+PO BOX 610097
+NORTH MIAMI
+Acct ID
+A R
+PL 33261
+S05 SUSP
+S06 RESM $11 CMEM
+IVL: 0 05/24/07
+08:56:05
+Qtr/Yr
+4 2006
+Wages
+2,354.88
+H CT
+• CONFIDENTIAL
+- 1 -
+
+
+6o/ 24/200/ 09:11
+FULE PALM BŁALH
+PAGE UJ
+File Liat
+01 HELP 03 EXIT
+UTCR
+NEXT:
+UTMAM44
+SSN:
+07 BWD
+503 MENU S05 SUSP S06 RESM S11 CMEM $12 FIND
+VL: 0 05/24/01
+UC Tax SSN Detail
+18:56:00
+Employee Name
+EMPLOYER NAMB/ADDRESS
+WILLIAM P OWENS CPA PA
+C/O WILLIAM P OWENS
+PO BOX 610097
+NORTH MIAMI
+Acct ID
+HA R
+Qtr/Yr
+4 2006
+Wages
+2,354.88
+H CT
+FL 33261
+01 HELP
+03
+EXIT
+07 BWD
+503 MENU
+S05
+SUSP
+S06 RESM
+S11 CMFM
+S12 FIND
+• CONFIDENTIAL
+- 2 -
+
+
+65/24/200/ 09:11
+FULE MALM BEALH
+File List
+rADE 04
+UTCR
+NEXT:
+UTMAM44
+UC Tax SSN Detail
+SSN: 241 53 4676
+Employee Name
+Acct ID
+MH A
+EMPLOYER NAME/ADDRESS
+JEFFREY E EPSTEIN
+358 EL BRILIO WAY
+PALM BEACH
+FL 33480
+LVL: 0 05/24/07
+08:56:28
+H CT
+Qt=/Xx
+2 2005
+3 2005
+A 2005
+1 2006
+2 2006
+3 2006
+4 2006
+Wages
+11,538.48
+14,730.75
+22,692.28
+12, 692.26
+63,046:64
+01 HELP
+03 EXIT S03 MENU S05 SUSP S06 RESM S11 CMEM S12 FIND
+NEXT:
+HEWWIN
+UC TaX SSN Detail
+SSN: 241 53 4676
+Employee Name
+Acct ID
+A
+EMPLOYER NAME/ADDRESS
+JEFFREY E EPSTEIN
+358 EL BRILLO WAY
+PALM BEACH
+FL 33480
+Qtr/YI
+2 2005
+3 2005
+$ 2005
+1 2006
+2 2006
+3 2006
+4 2006
+Wages
+11,538.48
+14,730.75
+22,692.28
+14,807.66
+12,692.28
+16,057.68
+63,846.14
+IVL: 0 05/24/07
+08: 56:35
+H CT
+01 HELP
+03 EXIT S03 MENU S05 SUSP S06 RESM S11 CMFM S12 FIND
+CI CONFIDENTIAL
+- 1.
diff --git a/vision-fixhub/ds9-unparsed-05/fd462f01cbb39a93b6c12a686d42febc1b5866819aff9306fc892031bd0cd57a.receipt.json b/vision-fixhub/ds9-unparsed-05/fd462f01cbb39a93b6c12a686d42febc1b5866819aff9306fc892031bd0cd57a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..485f58e3260d7ce47ce1e1ce3fbdbd4d7496edab
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fd462f01cbb39a93b6c12a686d42febc1b5866819aff9306fc892031bd0cd57a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -48,
+  "dataset": "marble-joined",
+  "doc_id": "fd462f01cbb39a93b6c12a686d42febc1b5866819aff9306fc892031bd0cd57a",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "10e62095b424bdfff441e2fcbb0ea46388e1874e037d7315dac92842443e6adc",
+  "output_sha256": "ba34105f0ff9572cb746b1c570998f3af7ec07abbaa6c2014bdad0b59ea8aa37",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/fe03c2e8664c8d50268a96c2e2a0727fee69dd57efd07c2852d974a0d3507833.md b/vision-fixhub/ds9-unparsed-05/fe03c2e8664c8d50268a96c2e2a0727fee69dd57efd07c2852d974a0d3507833.md
new file mode 100644
index 0000000000000000000000000000000000000000..d47316eced53690069bd7cbe7d4cc7e57fd14071
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fe03c2e8664c8d50268a96c2e2a0727fee69dd57efd07c2852d974a0d3507833.md
@@ -0,0 +1,129 @@
+E. JANE DOE # 16 (
+) and JANE DOE # 17(
+1. Who is Jane Doe # 16? Have you testified about her previously?
+a. Is there anything that you want to clarify or add regarding your earlier testimony?
+1. Please remind the grand jury, during what period of time did Jane Doe # 16 have contact with JE?
+1. Please summarize the sexual activity that Jane Doe # 16 was involved in with JE?
+1. Did Jane Doe # 16 recruit anyone to go to JE's home?
+JANE DOE # 17 (
+1. Who is Jane Doe # 17? Have you testified about her previously?
+1. Has she been interviewed?
+1. During what period of time did Jane Doe # 17 have contact with JE?
+1. How old was she during that time frame?
+1. How did she meet JE?
+1. And what sexual activity was she involved in with JE?
+1. How much was she paid?
+1. Did she recruit anyone to go to JE's home?
+JANE DOE # 16 (
+1) and JANE DOE # 17 C
+1. Does your prior testimony and your testimony today cover the evidence supporting the allegations and
+1. Let's refer to Count 10. Is the evidence you just summarized the basis for the allegation that
+and
+procured Jane Doe # 16 to engage in commercial sex acts knowing that she was under 18?
+1. Let's refer to Count 21. Is the evidence you just summarized the basis for the allegation that
+and
+used a facility of interstate commerce to persuade, induce and entice Jane Doe # 16 to engage
+in prostitution and in sexual activity for which a person can be charged with an offense?
+a. How many telephone calls have you been able to document between Jane Doe # 16 and |
+Between Jane Doe # 16 and
+? And between Jane Doe # 16 and |
+1. What was the sexual activity that Jane Doe # 16 and JE engaged in that also violated Fl. Stat. 794.05?
+(Sexual intercourse between an adult over 24 and a minor)
+1. Does your prior testimony and your testimony today cover the evidence supporting the allegations and
+overt acts 150-155?
+1. Let's refer to Count 22. Is the evidence you just summarized the basis for the allegation that JE and
+used a facility of interstate commerce to persuade, induce and entice Jane Doe # 17 to engage in
+F. JANE DOE # 7(
+prostitution and in sexual activity for which a person can be charged with an offense?
+1. Who is Jane Doe # 7? Have you testified about her previously?
+2. Has she been interviewed?
+3. During what period of time did Jane Doe # 7 have contact with JE?
+4. How old was she during that time frame?
+5. How did she meet JE?
+6. And what sexual activity was she involved in with JE?
+7. How much was she paid?
+8. Did she recruit anyone to go to JE's home?
+9. Does your testimony cover the evidence supporting the allegations in overt acts
+46,47,54, 57, 59-64?
+10. Let's refer to Count 14. Is the evidence you just summarized the basis for the allegation that JE and
+used a facility of interstate commerce to persuade, induce and entice Jane Doe # 7 to engage in prostitution
+and in sexual activity for which a person can be charged with an offense? How many telephone calls have you
+been able to document between Jane Doe # 7 and
+G. JANE DOE # 8 (
+1. Who is Jane Doe # 8? Have you testified about her previously?
+2. Has she been interviewed?
+3. During what period of time did Jane Doe # 8 have contact with JE?
+4. How old was she during that time frame?
+5. How did she meet JE?
+?
+
+
+6. And what sexual activity was she involved in with JE?
+7. How much was she paid?
+8. Did she recruit anyone to go to JE's home?
+9. Does your testimony cover the evidence supporting the allegations in overt acts
+49-53, 55, 65?
+H. JANE DOE # 12 (
+1. Who is Jane Doe # 12? Have you testified about her previously?
+2. Has she been interviewed?
+3. During what period of time did Jane Doe # 12 have contact with JE?
+4. How old was she during that time frame?
+5. How did she meet JE?
+6. And what sexual activity was she involved in with JE?
+7. How much was she paid?
+8. Did she recruit anyone to go to JE's home?
+9. Does your testimony cover the evidence supporting the allegations in overt acts
+96, 98-104?
+10. Let's refer to Count 06. Is the evidence you just summarized the basis for the allegation that JE, and
+procured Jane Doe # 12 to engage in commercial sex acts knowing that she was under 18?
+11. Let's refer to Count 17. Is the evidence you just summarized the basis for the allegation that JE, and
+used a facility of interstate commerce to persuade, induce and entice Jane Doe # 12 to engage in prostitution
+and in sexual activity for which a person can be charged with an offense?
+a. How many telephone calls have you been able to document between Jane Doe # 12 and
+I. JANE DOE # 13 (
+1. Who is Jane Doe # 13? Have you testified about her previously?
+2. Has she been interviewed?
+3. During what period of time did Jane Doe # 13 have contact with JE?
+4. How old was she during that time frame?
+5. How did she meet JE?
+6. And what sexual activity was she involved in with JE?
+7. How much was she paid?
+8. Did she recruit anyone to go to JE's home?
+9. Does your testimony cover the evidence supporting the allegations in overt acts
+96,97, 104-111?
+10. Let's refer to Count 07. Is the evidence you just summarized the basis for the allegation that JE, and
+I procured Jane Doe # 13 to engage in commercial sex acts knowing that she was under 18?
+11. Let's refer to Count 18. Is the evidence you just summarized the basis for the allegation that JE, and
+used a facility of interstate commerce to persuade, induce and entice Jane Doe # 13 to engage in prostitution
+and in sexual activity for which a person can be charged with an offense?
+a. How many telephone calls have you been able to document between Jane Doe # 13 and
+J. JANE DOE # 18 (
+1.)
+1. Who is Jane Doe # 18? Have you testified about her previously?
+2. Has she been interviewed?
+3. During what period of time did Jane Doe # 18 have contact with JE?
+4. How old was she during that time frame?
+5. How did she meet JE?
+6. And what sexual activity was she involved in with JE?
+7. How much was she paid?
+8. Did she recruit anyone to go to JE's home?
+9. Does your testimony cover the evidence supporting the allegations in overt acts
+182-188, 190?
+10. Let's refer to Count 23. Is the evidence you just summarized the basis for the allegation that JE, and
+used a facility of interstate commerce to persuade, induce and entice Jane Doe # 18 to engage in prostitution
+and in sexual activity for which a person can be charged with an offense?
+a. How many telephone calls have you been able to document between Jane Doe # 18 and I
+
+
+K. JANE DOE #19 (
+1.)
+1. Who is Jane Doe # 19? Have you testified about her previously?
+2. Has she been interviewed?
+3. During what period of time did Jane Doe # 19 have contact with JE?
+4. How old was she during that time frame?
+5. How did she meet JE?
+6. And what sexual activity was she involved in with JE?
+7. How much was she paid?
+8. Did she recruit anyone to go to JE's home?
+9. Does your testimony cover the evidence supporting the allegations in overt acts
+189-1902
diff --git a/vision-fixhub/ds9-unparsed-05/fe03c2e8664c8d50268a96c2e2a0727fee69dd57efd07c2852d974a0d3507833.receipt.json b/vision-fixhub/ds9-unparsed-05/fe03c2e8664c8d50268a96c2e2a0727fee69dd57efd07c2852d974a0d3507833.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..5087a435bac6422e9c34ff4f036972e0357a005c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fe03c2e8664c8d50268a96c2e2a0727fee69dd57efd07c2852d974a0d3507833.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "fe03c2e8664c8d50268a96c2e2a0727fee69dd57efd07c2852d974a0d3507833",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "265cddf0618ab25fa24fe2a2c2b178fb2b3316fca4b1a62df171857dbff504ec",
+  "output_sha256": "9f7c59bef65c11d5bb8dd1f4481643fc1398b14e22b82b72d28afef1cd578014",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/fe4548f766b24747608a72076803d8f89bf05d66fbcdfd3cc38eadffb761cbe5.md b/vision-fixhub/ds9-unparsed-05/fe4548f766b24747608a72076803d8f89bf05d66fbcdfd3cc38eadffb761cbe5.md
new file mode 100644
index 0000000000000000000000000000000000000000..5db825f91ae0ce039838d8170562deddeed1c8dc
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fe4548f766b24747608a72076803d8f89bf05d66fbcdfd3cc38eadffb761cbe5.md
@@ -0,0 +1,45 @@
+From:
+Sent:
+To:
+Subject:
+Tuesday, July 15, 2008 12:01 PM
+Re: Calls
+] I am out of the office right now. It is jason at south carolina victim's action network (www.sevan.org) and pauline mandel at
+maryland crime victims' services (www.mdcrimevictims.org)
+----- Original Message -...
+From
+To:
+Sent: Tue Jul 15 11:32:17 2008
+Subject: Re: Calls
+Call me when you get a chance.
+on hold re: notifications. Any word from Marra?
+-*--- Original Message -....
+From:
+To:
+Sent: Mon Jul 14 16:16:08 2008
+Subject: FW: Calls
+Hi all - Wasn't sure this went through last time.
+On another note, do you guys have an office in Ft Pierce?
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+--=--Original Message--...
+From:
+Sent: Monday, July 14, 2008 2:14 PM
+To:
+Subject: Calls
+Hi guys. I am stuck in the rain. If you want to start calling here are my thoughts.
+We are calling to inform you about the resolution of the Epstein investigation and to thank you for your help.
+08-80736-CV-MARRA
+234
+P-015070
+
+
+All of these terms are set out in a letter that AUSA |
+Lis going to send out. Do you have a lawyer? Get name and address. If
+not where do you want letter sent? If you have questions when you receive the letter, please understand that we cannot provide legal
+advice but the lawyers at the following victims rights organizations are able to help you at no cost to you. (Provide the names and
+phone numbers)
+Also ask about counseling and let them know that counseling is still available even though the investigation is closed.
+08-80736-CV-MARRA
+P-015071
diff --git a/vision-fixhub/ds9-unparsed-05/fe4548f766b24747608a72076803d8f89bf05d66fbcdfd3cc38eadffb761cbe5.receipt.json b/vision-fixhub/ds9-unparsed-05/fe4548f766b24747608a72076803d8f89bf05d66fbcdfd3cc38eadffb761cbe5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f44c20240784c2d29ef85e4b6da4efd8121f633b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fe4548f766b24747608a72076803d8f89bf05d66fbcdfd3cc38eadffb761cbe5.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "fe4548f766b24747608a72076803d8f89bf05d66fbcdfd3cc38eadffb761cbe5",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "fb14cd46de5c2a443212766030af2b8554f7f69d745a2d6a70354af2db00e7fc",
+  "output_sha256": "c2b081afc94d0d8283d58d5e3a0a4e127abe0f1d36790deb990b925b21eb06b2",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/fed7b7d6b688b4df1f3b121f3e34d5bd0249ddf978fc19ae89812893d65311d2.md b/vision-fixhub/ds9-unparsed-05/fed7b7d6b688b4df1f3b121f3e34d5bd0249ddf978fc19ae89812893d65311d2.md
new file mode 100644
index 0000000000000000000000000000000000000000..167f650d6a9e9e838e8c32e2328f6f4bf5946595
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fed7b7d6b688b4df1f3b121f3e34d5bd0249ddf978fc19ae89812893d65311d2.md
@@ -0,0 +1,77 @@
+11/30/07 peosta trousitz
+
+
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+99 N.E. 4 Street
+Miami 500102
+November 30, 2007
+Kirkland and Ellis LLP
+Citigroup Center
+153 East 53d Street
+New York, New York 10022-4611
+Dear Mr,
+I am in receipt of your letter dated November 29, 2007. Your letter responds to a draft notice
+originally forwarded to you by Assistant United States Attorney 1
+at the request
+of our First Assistant
+Should you have concerns, I would ask that you please
+address those with them in the first instance. I will forward your letter to them.
+I am also in receipt of a November 28, 2007 letter from your co-counsel, Mr.
+This
+Office will provide a response shortly.
+In the interim, I would note that since the signing of the September 24" agreement, more than
+two months' ago, it has become clear that several attorneys on your legal team are dissatisfied with
+that roult Me Boseiola dofanso tonm Analudad taureelf I
+previously had the opportunity to review and raise objections to the terms of the
+Agreement. The defense team, however, after extensive negotiation, chose to adopt the Agreement.
+Since then counsel have objected to several steps taken by the U.S. Attorney's Office to effectuate
+the terms of the Agreement, in essence presenting collateral challenges to portions of the
+Agreement.
+It is not the intention of this Office ever to require a defendant to enter a plea against his
+wishes. Your client has the right to proceed to trial. If your client is dissatisfied with his Agreement,
+or believes that it is unlawful or unfair, we stand ready to unwind the Agreement.
+Sincerely,
+R. Alexander Acosta
+United States Attorney
+
+
+11/30/0: FRI 11:32 FAX 305 530 6440
+EXECUTIVE OFFICE
+*** TX REPORT ***
+*****
+4001
+TRANSMISSION OK
+TX/RX NO
+CONNECTION TEL
+SUBADDRESS
+CONNECTION ID
+ST. TIME
+USAGE T
+PGS.
+RESULT
+3402
+
+11/30 11:32
+00'48
+2
+OK
+U.S. Department of Justice
+United States Allorney
+Southern District of Florida
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+SOUTHERN DISTRICT OF FLORIDA
+99 NE 4' STREET
+MIAMI, FLORIDA 33132-2111
+FACSIMILE TRANSMISSION
+COVER SHEET
+November 30, 2007
+DATE:
+TO:
+FAX NUMBER:
+SUBJECT:
+Jeffrey Espstein
+NUMBER OF PAGES, INCLUDING THIS PAGE: 2
+Message/Comments:
diff --git a/vision-fixhub/ds9-unparsed-05/fed7b7d6b688b4df1f3b121f3e34d5bd0249ddf978fc19ae89812893d65311d2.receipt.json b/vision-fixhub/ds9-unparsed-05/fed7b7d6b688b4df1f3b121f3e34d5bd0249ddf978fc19ae89812893d65311d2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..34b481e1decbf7064022803f7c8ea66891df2a31
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fed7b7d6b688b4df1f3b121f3e34d5bd0249ddf978fc19ae89812893d65311d2.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -48,
+  "dataset": "marble-joined",
+  "doc_id": "fed7b7d6b688b4df1f3b121f3e34d5bd0249ddf978fc19ae89812893d65311d2",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "433499acb56a4cb368c60cc6670ccc7556bfefb16f518fd81abac2bc3266a59a",
+  "output_sha256": "836b1aaca9422fcd87fc2ee79e11a3911d9581eccaef88e2be3cfaceba198e48",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/fef6d85a5193a4bbb8edf34dcdf1cdb12ddfefaf64757f351847d45c1a879c4c.md b/vision-fixhub/ds9-unparsed-05/fef6d85a5193a4bbb8edf34dcdf1cdb12ddfefaf64757f351847d45c1a879c4c.md
new file mode 100644
index 0000000000000000000000000000000000000000..b73d578cc475b181030ebca8f0b47f05f72cdc6a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fef6d85a5193a4bbb8edf34dcdf1cdb12ddfefaf64757f351847d45c1a879c4c.md
@@ -0,0 +1,765 @@
+To:
+Wednesday, September 19, 2007 6:27 PM
+Lourie, Andrew
+RE: epstein
+Hi Andy - Can you give me a call on my cell? Jay is supposed to be calling me at around 7:00. Cell is 561 601-2301.
+I'll be in my car in 2 minutes.
+A. Marie Villataña
+Assistant U.S. Attorney
+561 209-1047
+From: Lourie, Andrew [mailto:Andrew.Lourie2@usdoj.gov]
+Sent: Wednesday, September 19, 2007 4:21 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: RE: epstein
+I will reach out to Alex to discuss.
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie. C.Villafana@usdoj.gov]
+Sent: Wednesday, September 19, 2007 4:13 PM
+To: Villafana, Ann Marie C. (USAFLS); Lourie, Andrew
+Cc: Garcia, Rolando (USAFLS)
+Subject: RE: epstein
+Oh, and they took out the appeal waiver.
+A. Marie Villataña
+Assistant U.S. Attorney
+561 209-1047
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Wednesday, September 19, 2007 4:05 PM
+To: 'Lourie, Andrew'
+Cc: Garcia, Rolando (USAFLS)
+Subject: RE: epstein
+Importance: High
+I just got their "red-lined" version. I will forward it to you. Here are the issues that Rolando and 1 specifically discussed
+with them and rejected, that they have re-inserted into the agreement.
+1.
+gree to recommend that no PSI be prepared.
+2.
+have converted it into an ABA plea - as though we wouldn't notice?
+3.
+They want us to agree to the incorrect calculation of the guidelines
+4. Instead of agreeing that the girls can sue Epstein, they cannot sue him and instead are bound to apply to a trust
+administered by the State Court (Jay and I have addressed this at least three times and it keeps appearing in his
+versions)
+5. They changed the state charge that he has to plead guilty to to a non-registrable offense and he doesn't have to
+I to that charge until after he has finished serving his federal sentence.
+5. The want us not to oppose a request for a prison camp designation.
+7. They have re-added paragraphs 17 through 19, all of which are addressed by paragraph 2.
+3035
+P-014108
+
+
+There are other problems too, but these are the highlights. This is NOT good faith negotiations.
+A. Marie Villafaña
+Assistant U.S. Attorney
+56| 209-1047
+From: Lourie, Andrew [mailto:Andrew.Lourie2@usdoj.gov]
+Sent: Wednesday, September 19, 2007 3:50 PM
+To: Villatana, Ann Marie C. (USAFLS)
+Cc: Garcia, Rolando (USAFLS)
+Subject: RE: epstein
+Good job. A few thoughts:
+I would eliminate the first sentence of para 2. Is there another way to deal with the issue in para 3 without this in the plea
+agreement ? Do we need para 10? Isn't para 11 sufficient without 10? Is it our place to include para 13 in this
+agreement? I think it belongs in the state agreement and it looks out of place here.
+I think you should include Roy or another member of the FL Bar on the plea agreement so we are not slowed down at the
+last minute by Pro Hac stuff.
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie. C. Villafana@usdoj.gov]
+Sent: Wednesday, September 19, 2007 2:36 PM
+To: Lourie, Andrew
+Subject: RE: epstein
+FYI - The Palm Beach Post reported the whole deal in today's paper and claimed to have a "federal source" and a "spy"
+in Epstein's camp.
+A. Marie Villafaña
+Assistant U.S. Attorney
+561 209-1047
+From: Lourie, Andrew [mailto:Andrew.Lourie2@usdoj.gov]
+Sent: Wednesday, September 19, 2007 2:33 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: RE: epstein
+Can you send me copy of the last thing you sent them? Thanks.
+From: Villafana, Ann Marie C. (USAFLS) [mailto: Ann.Marie. C. Villafana@usdoj.gov]
+Sent: Wednesday, September 19, 2007 2:31 PM
+To: Lourie, Andrew; Garcia, Rolando (USAFLS)
+Subject: RE: epstein
+We are still waiting for a "redline" of the agreement that they seemed happy with yesterday. Barry and Lanna and
+Epstein's attorneys are coming to our office on
+araine a monday omino They tried to drag into fuesday aer shang with the plan of geting him at least.
+A. Marie Villataña
+Assistant U.S. Attorney
+3036
+P-014109
+
+
+561 209-1047
+From: Lourie, Andrew [mailto:Andrew.Lourie2@usdoj.gov]
+Sent: Wednesday, September 19, 2007 2:25 PM
+To: Villafana, Ann Marie C. (USAFLS); Garcia, Rolando (USAFLS)
+Subject: epstein
+What is the latest?
+3037
+P-014110
+
+
+To:
+Cc:
+Wednesday. September 19, 2007 4:48 PM
+'Lourie, Andrew"
+Garcia, Rolando (USAFLS)
+RE: epstein
+Hey Andy - Thanks for your comments. Here are my thoughts: the first sentence of paragraph 2 comes from the Office's
+standard plea agreement. I can change it, but Epstein's group seems to want me to be even more detailed (as in their
+paragraphs 17, 18. and 19).
+Paragraph 3 also was added at their insistence. I don't think it hurts us.
+I think I can combine my paragraphs 10, 11, and 13 to make one overarching statement that doesn't dictate too many of
+the terms of the state plea agreement.
+I have kept your notes and will incorporate them into any future draft.
+Thanks.
+A. Marie Villafaña
+Assistant U.S. Attorney
+561 209-1047
+From: Lourie, Andrew [mailto:Andrew. Lourie2 @usdoj.gov]
+Sent: Wednesday, September 19, 2007 3:50 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Cc: Garcia, Rolando (USAFLS)
+Subject: RE: epstein
+Good job. A few thoughts:
+I would eliminate the first sentence of para 2. Is there another way to deal with the issue in para 3 without this in the plea
+agreement? Do we need para 10? Isn't para 11 sufficient without 10? Is it our place to include para 13 in this
+agreement? I think it belongs in the state agreement and it looks out of place here.
+I think you should include Roy or another member of the FL Bar on the plea agreement so we are not slowed down at the
+last minute by Pro Hac stuff.
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie. C. Villafana@usdoj.gov]
+Sent: Wednesday, September 19, 2007 2:36 PM
+FYI - The Palm Beach Post reported the whole deal in today's paper and claimed to have a "federal source" and a "spy"
+in Epstein's camp.
+A. Marie Villațaña
+Assistant U.S. Attorney
+561 209-1047
+3038
+P-014111
+
+
+From: Lourie, Andrew [mailto:Andrew.Lourie2@usdoj.gov]
+Sent: Wednesday, September 19, 2007 2:33 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: RE: epstein
+Can you send me copy of the last thing you sent them? Thanks.
+From: Villafana, Ann Marie C. (USAFLS) [mailto: Ann.Marie. C. Villafana@usdoj.gov] ×
+Sent: Wednesday, September 19, 2007 2:31 PM
+To: Lourie, Andrew; Garcia, Rolando (USAFLS)
+Subject: RE: epstein
+We are still waiting for a "redline" of the agreement that they seemed happy with yesterday. Barry and Lanna and
+Epstein's attorneys are coming to our office on Monday to finalize everything with the plan of getting him at least
+arraigned on Monday afternoon. They tried to drag it into Tuesday and I said no.
+A. Marie Villafaña
+Assistant U.S. Attorney
+561 209-1047
+From: Lourie, Andrew [mailto:Andrew.Lourie2 @usdoj.gov]
+Sent: Wednesday, September 19, 2007 2:25 PM
+To: Villafana, Ann Marie C. (USAFLS); Garcia, Rolando (USAFLS)
+Subject: epstein
+What is the latest?
+Tracking:
+3039
+P-014112
+
+
+ent
+Wednesday, September 19, 2007 2:31 PM
+Lourie, Andrew
+RE:
+I hadn't planned on it.
+A. Marie Villațaña
+Assistant U.S. Attorney
+561 209-1047
+From: Lourie, Andrew [mailto:Andrew.Lourie2 @usdoj.gov]
+Sent: Wednesday, September 19, 2007 2:26 PM
+To: Villafana, Ann Marie C. (USAFLS)
+Is CEOS going to be a party to the plea agreement?
+3061
+P-014113
+
+
+-rom:
+Wednesday, September 19, 2007 11:21 AM
+Garcia, Rolando (USAFLS)
+RE: Meeting with Epstein's attorneys
+Will you be available by phone in case of problems? I want to make sure he is
+arraigned by Monday, so that if this falls apart we can still present the
+indictment on Tuesday.
+A. Marie Villafaña
+Assistant U.S. Attorney
+561 209-1047
+-----Original Message--..-
+From: Garcia, Rolando (USAFLS)
+Sent: Wednesday, September 19, 2007 11:19 AM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Re: Meeting with Epstein's attorneys
+Thursday and Monday morning are bad.
+Sent from my BlackBerry Wireless Handheld
+-----Original Message-...-
+From: Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov>
+To: Barry Krischer <Bkrische@sa15.state.fl.us›; Lanna Belohlavek
+(Ibelohla@sa15.state.fl.us) <Ibelohla@sa15.state.fl.us›; Garcia, Rolando (USAFLS)
+<RGarcia@usa. doj .gov>
+Sent: Wed Sep 19 11:17:05 2007
+Subject: Meeting with Epstein's attorneys
+H1 all - Just received an e-mail from Jay Letkowitz agreeing that a joint meeting
+is needed to finalize all of the agreements. Are all of you available tomorrow
+(Thursday)? If not, how does very early on Monday sound?
+Thank you.
+A. Marie Villafaña
+Assistant U.S. Attorney
+561 209-1047
+Tracking:
+3083
+P-014114
+
+
+To:
+Cc:
+Tuesday, September 18, 2007 2:45 PM
+Acosta, Alex (USAFLS)
+Garcia, Rolando (USAFLS)
+RE: Tomorrow re Epstein
+Hi Alex -- Lefkowitz now seems happy with the same language we proposed last
+week. Jay agreed we should do a sit down to finalize the language but, because
+of the upcoming holiday, my guess is that it might not happen until Monday.
+Rolando and I also conferred with Barry Krisher who agrees with us regarding the
+Tracking:
+3091
+P-014115
+
+
+lasay, September 1. 2507 1-53 PN
+LE. Tomorow re Epseir
+That is fine. Rolando and I will nail everything down, we just want to get a
+final blessing. Thank you.
+Tracking:
+3093
+P-014116
+
+
+But I don't think I should be part of negotiations.
+I'd rather leave it to you
+if that's ok.
+Sent from my BlackBerry Wireless Handheld
+•--Original Message-.-
+From: Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov>
+To: Acosta, Alex (USAFLS) <AAcosta@usa.doj.gov>
+Sent: Tue Sep 18 13:34:05 2007
+Subject: Tomorrow re Epstein
+Hi Alex - Sorry to bother you when you are traveling. I would like to recommend
+to Mr. Epstein's attorneys that we all get together tomorrow to hash out the
+language. Will you be available tomorrow via fax or phone if we need final
+approval on an agreement?
+Thanks.
+3095
+P-014117
+
+
+Villafana, Ann Marie C. (USAFS)
+All day.
+Sent from my BlackBerry Wireless Handheld
+-----Original Message-...-
+From: Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov›
+To: Acosta, Alex (USAFLS) <AAcosta@usa.doj.gov›
+Sent: Tue Sep 18 13:34:05 2007
+Subject: Tomorrow re Epstein
+Hi Alex - Sorry to bother you when you are traveling. I would like to recommend
+to Mr. Epstein's attorneys that we all get together tomorrow to hash out the
+language.
+Will you be available tomorrow via fax or phone if we need final
+approval on an agreement? Thanks.
+3096
+P-014118
+
+
+Tuesday, September 18, 2007 1:34 PM
+Acosta, Alex (USAFLS)
+Tomorrow re Epstein
+Hi Alex - Sorry to bother you when you are traveling. I would like to recommend to Mr. Epstein's attorneys
+that we all get together tomorrow to hash out the language. Will you be available tomorrow via fax or phone if
+we need final approval on an agreement? Thanks.
+Tracking:
+3097
+P-014119
+
+
+To:
+Cc:
+Tuesday, September 18, 2007 12:26 PM
+Acosta, Alex (USAFLS); Lourie, Andrew (USAFLS); Garcia, Rolando (USAFLS)
+Atkinson, Karen (USAFLS); McMillan, John (USAFLS) •
+Revised Plea Agreement
+I have attached a revised plea agreement. It contains the 18/12 split that Jay and Andy agreed to. I have
+included language that addresses some of Epstein's concerns that Jay and I discussed, so it is not identical to the
+previous version. You will notice that there is some highlighted language about the state time. John and I
+talked and I think that Epstein can avoid the problem of possibly spending extra time in state prison if the state
+just puts him on probation and he will serve part of that probationary term in a federal prison. Please let me
+know how to proceed. Jay has asked for a conference call this afternoon.
+Thank you.
+070918 12.22
+1 Plea Agreement
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+Tracking:
+3106
+P-014120
+
+
+To:
+Cc:
+Tuesday, September 18, 2007 11:43 AM
+"Lourie, Andrew'; Garcia, Rolando (USAFLS)
+Atkinson, Karen (USAFLS)
+RE: Draft Agreements?
+He also removed any promise to plead to a registrable offense and the promise related to the girls' damages
+claims.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+From: Villafana, Ann Marie C. (USAFLS)
+Sent: Tuesday, September 18, 2007 11:18 AM
+To: 'Lourie, Andrew; Garcia, Rolando (USAFLS)
+Cc: Atkinson, Karen (USAFLS)
+Subject: FW: Draft Agreements?
+Importance: High
+Andy and Rolando: Please see below so you understand my frustration. This document is completely different
+from what Jay just told Andy their would agree to. He has it written as 16 months" imprisonment followed by 8
+months federal supervised release. He wants us to recommend an improper calculation of the guidelines, and he
+wants to waive the PSI so he can keep all of his information confidential. I have already told Jay that the PSI
+language and other language in this agreement was unacceptable to our office. I will send back a plea
+agreement that reads consistent with what Jay represented to Andy but I don't believe that this will be resolved
+by Tuesday unless they come down here and we have a group contract writing session with the state attorney's
+office and the decision-makers.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com]
+Sent: Tuesday, September 18, 2007 11:09 AM
+To: Villatana, Ann Marie C. (USAFLS)
+Subject: RE: Draft Agreements?
+Confidential - For Settlement purposes only.
+Marie -- Please look this over and let's see if we can identify any issues that we need to discuss in greater detail. Since
+you can't go to only one count of obstruction, but 18 would become about 15 with gain time, I have made a proposal of a
+total 24 month sentence based on two informations. This would include a period of home detention. We can then follow
+3112
+P-014121
+
+
+this with a state plea as well so he serves the additional time there. I need to see your language for proffers on the two
+charges - (taking
+out of the jurisdiction to avoid process.)
+Alternatively, at this stage, we could have just one count for 12 months and then 6 months incarceration under the state,
+followed by community control and probabtion. I am not sure which is more practicable.
+Please let me know when you are free to speak
+Thanks - Jay
+"Villafana, Ann Marie C. VUSAFLSI)"
+<Ann.Marie. C. Villafana@usdoj.gov>
+09/18/2007 09:14 AM
+To "Jay Lefkowitz" <JLefkowitz@kirkland.com>
+Subject RE: Draft Agreements?
+Hi Jay - I know that the U.S. Attorney will not go below 18 months of prison/jail time (and I would strongly
+oppose the suggestion).
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach. FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com]
+Sent: Tuesday, September 18, 2007 8:59 AM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Re: Draft Agreements?
+an alternative to what we discussed just now might be to plead to one count of 1512, serve 12 months plus supervised
+release which would be one year of home detention (if we can make that work), followed by two years of probation in the
+state on the state charges with the first 6 months being community control.
+"Villafana, Ann Marie C. WUSAFLS|)" <Ann.Marie. C.Villafana@usdoj.gov>
+09/18/2007 08:44 AM
+To "Jay Lefkowitz" <JLefkowitz@kirkland.com>
+Subject Draft Agreements?
+3113
+P-014122
+
+
+Hi Jay - I was hoping there would be things for me to read this morning, but I will try to remain patient.
+I believe there are only two types of agreements that would apply to this case: (1) a plea agreement to a federal
+charge or charges; and (2) a non-prosecution agreement (which is really a deferred prosecution agreement
+because the defendant agrees that if he violates the agreement, the U.S. can prosecute him).
+A plea agreement is part of the court file. It is not accessible on-line via PACER, but someone can go to the
+Clerk's Office to obtain a copy.
+A non-prosecution agreement would not be made public or filed with the Court, but it would remain part of our
+case file. It probably would be subject to a FOIA request, but it is not something that we would distribute
+without compulsory process.
+On the obstruction charges, many of the facts I included in that first proffer were hypothesized based upon our
+discussions and the agents' observations of Ms. Groff. We will need to interview her to confirm the accuracy of
+those facts. On a second count, we could rely on the incident where Mr. Epstein's private investigators
+followed
+father, forcing him off the road. Or, if there is something more recent related to any grand
+jury subpoenas, we could consider that.
+Hope that helps.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+Tracking:
+3114
+P-014123
+
+
+To:
+Cc:
+Attachments:
+Tuesday, September 18, 2007 11:18 AM
+'Lourie, Andrew'; Garcia, Rolando (USAFLS)
+Atkinson, Karen (USAFLS)
+FW: Draft Agreements?
+Agreement updated. doc.rtf
+Importance:
+High
+Andy and Rolando: Please see below so you understand my frustration. This document is completely different
+from what Jay just told Andy they would agree to. He has it written as 16 months' imprisonment followed by 8
+months federal supervised release. He wants us to recommend an improper calculation of the guidelines, and he
+wants to waive the PSI so he can keep all of his information confidential. I
+told Jay that the PSI
+language and other language in this agreement was unacceptable to our office. I will send back a plea
+agreement that reads consistent with what Jay represented to Andy but I don't'believe that this will be resolved
+_Tuesday unless they come down here and we have a group contract writing session with the state attorney's
+office and the decision-makers.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach. FL 33401
+Phone 561 209-1047
+Fax 56l 820-8777
+From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com]
+Sent: Tuesday, September 18, 2007 11:09 AM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: RE: Draft Agreements?
+Confidential - For Settlement purposes only.
+Marie -- Please look this over and let's see if we can identify any issues that we need to discuss in greater detail. Since
+you cant go to only one count of obstruction, but 18 would become about 15 with gain time, I have made a proposal of a
+total 24 month sentence based on two informations. This would include a period of home detention. We can then follow
+this with a state plea as well so he serves the additional time there. I need to see your language for proffers on the two
+charges - (taking)
+Alternatively, at this stage, we could have just one count for 12 months and then 6 months incarceration under the state,
+followed by community control and probabtion. I am not sure which is more practicable
+Please let me know when you are free to speak.
+Thanks - Jay
+"Villafana, Ann Marie C. YUSAFLSI)"
+«Ann.Marie.C. Villafana@usdoj.gov>
+To Jay Lohomite: «JLohowitz@kiMland.com»
+3116
+P-014124
+
+
+Subject RE: Draft Agreements?
+09/18/2007 09:14 AM
+Hi Jay - I know that the U.S. Attorney will not go below 18 months of prison/jail time (and I would strongly
+oppose the suggestion).
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL. 33401
+Phone 561 209-1047
+Fax 561 820-8777
+From: Jay Lefkowitz [mailto:JLefkowitz@kirkland.com]
+Sent: Tuesday, September 18, 2007 8:59 AM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Re: Draft Agreements?
+an alternative to what we discussed just now might be to plead to one count of 1512, serve 12 months plus supervised
+release which would be one year of home detention (if we can make that work), followed by two years of probation in the
+state on the state charges with the first 6 months being community control.
+"Villafana, Ann Marie C. \(USAFLSI)" <Ann.Marie.C.Villafana@usdoj.gov>
+09/18/2007 08:44 AM
+To "Jay Lefkowitz" <JLefkowitz@kirkland.com>
+Subject Draft Agreements?
+Hi Jay - I was hoping there would be things for me to read this morning, but I will try to remain patient.
+I believe there are only two types of agreements that would apply to this case:: (1) a plea agreement to a federal
+charge or charges; and (2) a non-prosecution agreement (which is really a deferred prosecution agreement
+because the defendant agrees that if he violates the agreement, the U.S. can prosecute him).
+A plea agreement is part of the court file. It is not accessible on-line via PACER, but someone can go to the
+Clerk's Office to obtain a copy.
+A non-prosecution agreement would not be made public or filed with the Court, but it would remain part of our
+case file. It probably would be subject to a FOIA request, but it is not something that we would distribute
+without compulsory process.
+3117
+P-014125
+
+
+On the obstruction charges, many of the facts I included in that first proffer were hypothesized based upon our
+discussions and the agents' observations of Ms. Groff. We will need to interview her to confirm the accuracy of
+those facts. On a second count, we could rely on the incident where Mr. Epstein's private investigators
+followed i
+father, forcing him off the road. Or, if there is something more recent related to any grand
+jury subpoenas, we could consider that.
+Hope that helps.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+Tracking:
+3118
+P-014126
+
+
+Tuesday, September 18, 2007 10:05 Al
+Lourie, Andrew
+RE: Epstein
+Hi Andy - Can you give me a call?
+A. Marie Villațaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+From: Lourie, Andrew [mailto:Andrew.Lourie@crm.usdoj.gov]
+Sent: Tuesday, September 18, 2007 9:54 AM
+To: Garcia, Rolando (USAFLS)
+Cc: Villafana, Ann Marie C. (USAFLS)
+Subject: RE: Epstein
+I just spoke to Jay. I agreed to two fed obstructions charges (24 month cap) with nonbinding recommendation for 18
+months. When he gets out, he has to plead to state offenses, including against minor, registerable, and then take one
+year house arrest/community confinement.
+From: Garcia, Rolando (USAFLS) [mailto:Rolando.Garcia@usdoj.gov]
+Sent: Tuesday, September 18, 2007 9:47 AM
+To: Lourie, Andrew
+Subject: Epstein
+Maybe you should talk to Epstein and close the deal.
+3122
+P-014127
+
+
+To:
+Cc:
+Importance:
+Tuesday, September 18, 2007 9:31 AM
+Acosta, Alex (USAFLS); Lourie, Andrew (USAFLS); Garcia, Rolando (USAFLS)
+Atkinson, Karen (USAFLS); McMillan, John (USAFLS)
+Epstein Negotiations
+High
+Hi all - I think that we may be near the end of our negotiations with Mr. Epstein, and not because we have
+reached a resolution. As I mentioned yesterday, I spent about 12 hours over the weekend drafting Informations,
+changing plea agreements, and writing factual proffers. I was supposed to receive a draft agreement from them
+yesterday, which never arrived. At that time, they were leaning towards pleading only to state charges and
+doing all of the time in state custody.
+Late last night I talked to Jay Lefkowitz who asked about Epstein pleading to two twelve-month federal charges
+with half of his jail time being spent in home confinement pursuant to the guidelines. I told him that I had no
+objection to that approach but, in the interest of full disclosure, I did not believe that Mr. Epstein would be
+eligible because he will not be in Zone A or B. This morning Jay called and said that I was correct but, if we
+could get Mr. Epstein down to 14 months, then he thought he would be eligible.
+My response: have him plead to two separate Informations. On the first one he gets 12 months' imprisonment
+and on the second he gets twelve months, with six served in home confinement, to run consecutively.
+I just received an e-mail asking if Mr. Epstein could just do 12 months imprisonment instead.
+As you can see, Mr. Epstein is having second thoughts about doing jail time. I would like to send Jay an e-mail
+stating that if we do not have a signed agreement by tomorrow at 5:00, negotiations will end. I have selected
+tomorrow at 5:00 because it gives them enough time to really negotiate an agreement if they are serious about it,
+and, if not, it gives me one day before the Jewish holiday to get witnesses lined up for Tuesday's grand jury
+appearance, when I plan to present the indictment, and it gives the office sufficient time to review the
+indictment package.
+Do you concur?
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+Tracking:
+3123
+P-014128
+
+
+Monday, September 17, 2007 11:44 AN
+Acosta, Alex (USAFLS)
+Absolutely. There were a lot of problems with their last attempt. They tried to
+re-open all the loopholes that I had sewn shut.
+Tracking:
+3135
+P-014129
+
+
+From
+To:
+Cc:
+Acosta, Alex (USAFLS)
+Monday, September 17, 2007 11:43 AM
+/illafana, Ann Marie C. (USAFLS); Garcia, Rolando (USAFLS); Lourie, Andrew (USAFLS
+tkinson, Karen (USAFLS); McMillan, John (USAFL$
+Re: Latest update
+PIs make sure they know its only a draft, and that we still need to approve
+final.
+The form and language may need polishing.
+Sent from my BlackBerry Wireless Handheld
+-----Original Message-...-
+From: Villafana, Ann Marie C. (USAFLS) <AVillafana@usa.doj.gov›
+To: Garcia, Rolando (USAFLS) <RGarcia@usa.doj.gov›; Acosta, Alex (USAFLS)
+<AAcosta@usa.doj.gov›; Lourie, Andrew (USAFLS) <ALourie@usa.doj.gov>
+CC: Atkinson, Karen (USAFLS) <KAtkinson@usa.doj.gov›; McMillan, John (USAFLS)
+<JMcMillan@usa.doj.gov>
+Sent: Mon Sep 17 11:33:14 2007
+Subject: Latest update
+Hi all - Just spoke with Jay Lefkowitz, he reports that, as of now, they are
+leaning back towards pleading only to state charges with a Non-Prosecution
+agreement. They are doing some legal research and talking with the state, and
+Jay thinks that they should have a proposed agreement by late tonight or early
+tomorrow morning. I am going to send him our last version of the Non-Prosecution
+Agreement so that he has a template to work from. Jay has my numbers in case I
+need to go home early and any questions come up.
+As soon as I know something, I will pass it along.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL
+33401
+Phone 561 209-1047
+Fax 561 820-8777
+3137
+P-014130
+
+
+To:
+Cc:
+Monday, September 17, 2007 11:33 AM
+Garcia, Rolando (USAFLS); Acosta, Alex (USAFLS); Lourie, Andrew (USAFLS)
+Atkinson, Karen (USAFLS); McMillan, John (USAFLS)
+Latest update
++
+Hi all - Just spoke with Jay Lefkowitz, he reports that, as of now, they are leaning back towards pleading only
+to state charges with a Non-Prosecution agreement. They are doing some legal research and talking with the
+state, and Jay thinks that they should have a proposed agreement by late tonight or early tomorrow morning. I
+am going to send him our last version of the Non-Prosecution Agreement so that he has a template to work
+from. Jay has my numbers in case I need to go home early and any questions come up.
+As soon as I know something, I will pass it along.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Phone 561 209-1047
+Fax 56l 820-8777
+Tracking:
+3138
+P-014131
+
+
+To:
+Monday, September 17, 2007 10:35 AM
+Garcia, Rolando (USAFLS); Lourie, Andrew (USAFLS)
+RE: Epstein
+Hi Rolando - Here is the last e-mail that I sent to Jay last night. Jay talked with his client about it and reports
+that they are leaning towards options I or 4. They are going to try to make that decision today (there seems to
+be some dissension in the ranks because Jack Goldberger gave some incorrect information), and draft a
+proposed either Non-Prosecution Agreement or Plea Agreement. As you can see from my list below, there are a
+number of things in their last draft that were unacceptable. All of the loopholes that I sewed up they tried to
+open. So. Jay is supposed to be consulting with Rog Black regarding the correct state information and then will
+give me a call.
+I agreed to ask the Judge to take the hearing off calendar tomorrow and to postpone the grand jury appearances
+that were scheduled from tomorrow, but I told him in no uncertain terms that I am indicting on the 25 so this
+needs to be resolved early this week. Andy and I talked about all of this as well. Long answer to a short
+question, sorry.
+Hi Jay -- This can wait until after the show, but my voice is going so I thought I would type it up. I
+talked to Andy and he still doesn't like the factual basis. In his opinion, the plea should only address
+the crimes that we were addressing, and we were not investigating Mr. Epstein abusing his girlfriend.
+So, these are the only options that he recommended:
+1. We go back to the original agreement where Mr. Epstein pleads only to state charges and serves
+his time in the state, except that we can agree to only 18 months imprisonment.
+2. Mr. Epstein pleads guilty to the state charges and also pleads to either two obstruction counts or to
+one count of violating 47 USC 223(a)(1)(B), with a joint non-binding recommendation of 18 months,
+so that Mr. Epstein can serve his time federally.
+3. (My suggestion only, not Andy's): I go back to the U.S. Attorney and ask him to agree to an ABA-
+plea to a 371 count (conspiracy to violate 2422(b)) with a binding 20-month recommendation so that
+Mr. Epstein can serve all of his time in a federal facility.
+Or 4. Mr. Epstein pleads to one obstruction count, and serves part of his time federally and part state.
+On your other proposed changes, some are fine and some are problematic.
+Re your paragraph 2: As to timing, it is my understanding that Mr. Epstein needs to be sentenced in
+the state after he is sentenced in the federal case, but not that he needs to plead guilty and be
+sentenced after serving his federal time. Andy recommended that some of the timing issues be
+addressed only in the state agreement, so that it isn't obvious to the judge that we are trying to create
+federal jurisdiction for prison purposes. My understanding is that Mr. Epstein should sign a state plea
+agreement, plead guilty to the federal offenses, plead guilty to the state offenses, be sentenced on the
+federal offenses, and then be sentenced on the state offenses, and then start serving the federal
+Re your paragraph 3: As to the reservation of Mr. Epstein's right to withdraw his state plea or to
+appeal his state plea or sentence, that is fine, but we need the caveat that, if he were to do so, the
+United States could proceed on our charges.
+Re your paragraph 6: With respect to the waiver of the right to appeal the federal sentence, given the
+way we have drafted the information, it is possible that getting to the 18 month sentence will require
+an upward departure. The version of the agreement that you were working from is a federal non-
+3140
+P-014132
+
+
+prosecution agreement, the ones I have sent you recently are plea agreements that get filed with the
+court. Please see if the appeal waiver language in those versions is alright.
+Re your paragraph 7: As I mentioned, we will not waive the presentence investigation. I know that
+this will delay Mr. Epstein's sentencing by 70 days, but that will allow him to get all of his affairs in
+order. As to bail, it will be set at the time of arraignment, and we can work out a joint recommendation
+regarding the amount and its limitations. I have no objection to making a joint recommendation that
+Mr. Epstein remain out on bond pending his sentencing, but I'm not sure that it belongs in a plea
+agreement, especially since I can't bind the court on that issue. However, I can assure you, and we
+can put it on the record during the plea colloquy, that I will join in your recommendation that he remain
+out on bond pending sentencing. The same goes for the prison camp issue. As I mentioned, I have
+opposed a designation only once in a very particular case. I can assure you, and we can put it on the
+record at the plea colloquy that I will not oppose your recommendation for Mr. Epstein's designation.
+Re your paragraph 8: As I mentioned over the telephone, I cannot bind the girls to the Trust
+Agreement, and I don't think it is appropriate that a state court would administer a trust that seeks to
+pay for federal civil claims. We both want to avoid unscrupulous attorneys and/or litigants from
+coming forward, and I know that your client wants to keep these matters outside of public court filings,
+but | just don't have the power to do what you ask. Here is my tecommendation. During the period
+between Mr. Epstein's plea and sentencing, I make a motion for appointment of the Guardian Ad
+Litem. The three of us sit down and discuss things, and I will facilitate as much as | can getting the
+girls' approval of this procedure because, as I mentioned, I think it is probably in their best interests.
+In terms of plea agreement language, let me suggest the following:
+The United States agrees to make a motion seeking the appointment of a Guardian ad Litem to
+represent the identified victims. Following the appointment of such Guardian, the parties agree to
+work together in good faith to develop a Trust Agreement, subject to the Court's approval, that would
+provide for any damages owed to the identified victims pursuant to 18 U.S.C. Section 2255. Then
+include the last two sentences of your paragraph 8.
+Re the two paragraphs following your paragraph 8: I will include our standard language regarding
+resolving all criminal liability and i will mention "co-conspirators," but I would prefer not to highlight for
+the judge all of the other crimes and all of the other persons that we could charge. Also, we do not
+have the power to bind Immigration and we make it a policy not to try to, however, I can tell you that,
+as far as I know. there is no plan to try to proceed on any immigration charges against either Ms.
+Ross or Ms.
+Also, on the grand jury subpoenas, I can prepare letters withdrawing them as of the signing of the
+plea agreement, but I would prefer to take out that language. In my eyes, once we have a plea
+agreement, the grand jury's investigation has ended and there can be no more use of the grand jury's
+subpoena power.
+I had hoped that we were far closer to resolving this than it appears that we are. Can I suggest that
+tomorrow we either meet live or via teleconference, either with your client or having him within a quick
+phone call, to hash out these items? I was hoping to work only a half day tomorrow to save my voice
+for Tuesday's hearing and grand jury, if necessary, but maybe we can set a time to meet. If you want
+o meet "off campus" somewhere, that is fine. I will make sure that I have all the necessary decisio
+makers present or "on call," as wel
+tomoran resolve some of these issues today, let's try 1o, and then save only the dificult isues for
+Sorry for the long e-mail, and for ruining your date with your daughter.
+A. Marie Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach. FL 33401
+Phone 561 209-1047
+Fax 561 820-8777
+3141
+P-014133
+
+
+From: Garcia, Rolando (USAFLS)
+Sent: Monday, September 17, 2007 10:26 AM
+To: Villafana, Ann Marie C. (USAFLS)
+Subject: Epstein
+Marie,
+Where are we at in the plea negotiations?
+Tracking:
+3142
+P-014134
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/fef6d85a5193a4bbb8edf34dcdf1cdb12ddfefaf64757f351847d45c1a879c4c.receipt.json b/vision-fixhub/ds9-unparsed-05/fef6d85a5193a4bbb8edf34dcdf1cdb12ddfefaf64757f351847d45c1a879c4c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a5228819912fb5bc0b3fd3a2e9b4d8d54f66f572
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/fef6d85a5193a4bbb8edf34dcdf1cdb12ddfefaf64757f351847d45c1a879c4c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -2158,
+  "dataset": "marble-joined",
+  "doc_id": "fef6d85a5193a4bbb8edf34dcdf1cdb12ddfefaf64757f351847d45c1a879c4c",
+  "engine": "marble-apple-vision",
+  "event_count": 28,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "e727c85072c777832a6319752033c5c4e591038a115c8be4cd36341f927888cf",
+  "output_sha256": "33726e9ff4cece83e4b84afeb5d612e0cfac5b49e13768e6b5504c9dcbcef75e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ff7fa9bd54af62f2187fdb596cec08a3cf23b2dbd31ab5e851b944e764b2cf14.md b/vision-fixhub/ds9-unparsed-05/ff7fa9bd54af62f2187fdb596cec08a3cf23b2dbd31ab5e851b944e764b2cf14.md
new file mode 100644
index 0000000000000000000000000000000000000000..9d1b2b6aabc24e826f63bad355dd5f1a61456d91
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ff7fa9bd54af62f2187fdb596cec08a3cf23b2dbd31ab5e851b944e764b2cf14.md
@@ -0,0 +1,3619 @@
+Statements
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary .............................
+Your Portfolio Holdings
+Transaction Detail ....
+Trades Not Yet Settled
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 29, 2002
+3
+4
+5
+11
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+13.715.716
+509,313
+24,520
+NET EQUITY THIS PERIOD
+$14,249,549
+NET EQUITY LAST STATEMENT
+7.885.525
+CHANGE SINCE LAST STATEMENT
+6,364,025
+*This portfolio indudes one or more unpriced securies that are not
+reflected in the Total Value of Securties and the Net Equity This Period.
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Cash & Equivalent -
+Fixed
+Income
+Market Value of Your Portfolio
+$24,520
+$13,776
+$7,421,941
+Current market value
+Last statement's market value
+$13,715.716
+Important Message
+f any information regarding
+2002interest, dividends
+niscellaneous income
+ross proceeds or origina
+sue discount is requir
+be reported to the IRS
+is socated Form 109
+Il be mailed to you t
+12425 31.200 17, 2003.
+SP The suremen is foul ratanal purger red de Set revere dise for portant iformation.
+
+
+2 of 11
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or 11
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Miscellaneous
+Amount Debited.
+Net Cash Activity
+Closing Balance.
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERICO
+13,775.7
+.......
+71,498,828.13
+964,882.99
+7,182,198.39
+$79,645,909.51
+-71,498,828.13
+-8,136,336.62
+5-79.635,164.75
+10,744.76
+..........
+24.520.47
+Income Summary
+Govt. Agency Int.
+Credit Balance Int.
+Total
+Bond Purchase Int.
+THIS PERIOD
+964,540.47
+342.52
+5964,882.99
+Portfolio Composition
+Cash/Cash Equivalent
+Fixed Income
+Total
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+13,775.71
+$13,775.71
+CLOSING
+24,520.47
+.....
+$24,520.47
+.....
+027
+YEAR TO DATE
+2,802,875.24
+1,035.54
+.....
+$2,803,910.78
+....
+-497,459.47
+24,520
+13,715,716
+-______.
+$13.740.236
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 29,2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+< 1%
+- Fixed Income
+99%
+Unshaded portions denote debit balance and or shart
+
+
+4 of 11
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+FEDERAL HOME LOAN MTG CORP
+SERIES 2530 CLASS SE
+DATED DATE 10/11/02
+BOOK ENTRY ONLY
+DUE 02/15/2032 5 980%
+FACTOR -
+FEDERAL HOME LOAN MIG CORP
+SERIES 2526 CLASS SI
+DATED DATE 10/01/02
+BOOK ENTRY ONLY
+DUE 02/15/2032 5 580%
+FACTOR -
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS VT
+DATED DATE 06/07/02
+BOOK ENTRY ONLY
+FACTOR 5202 1000%
+FEDERAL HOME LOAN MG CORP
+SERIES 2488 CLASS SO
+DATED DATE 07/08/02
+BOOK ENTRY ONLY
+DUE 03/15/2082 6.580%
+FACTOR -
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SIMBCLCUSIP
+QUANTITY
+PRICE
+SYMBOLCUSP
+MAGN
+MRGN
+MAGN
+MAGN
+QUANTITY
+58,082,010
+24,914,447
+63,667,128
+MARKET
+VALUE
+24,520
+$24,520
+PAICE
+8.6987
+8.3566
+2.9911
+Unpriced
+027
+STIMAT
+INUAL INCON
+MARKET VALUE
+5,052,380
+2,082,008
+154,367
+61,787
+1,904,354
+28,294
+133,880
+01101/03:08:59 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 29,2002
+ANNUAL INCOME
+3,473,304
+1,390,226
+68.7459
+....
+36.7733
+636,671
+3,012,352
+33.432
+66296V
+
+5 of 11
+Your Portfolio Holdings (continued)
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Government & Agency Obligations (continued)
+SHMBOLCUSIP
+FEDERAL HOME LOAN MIG CORP
+MRGN
+QUANTITY
+52,816,814
+PRICE
+8.8551
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 29,2002
+ESTIMATED
+ANNUAL INCOME
+2,947,178
+CURRENT
+YIELD (S)
+63.0146
+Total Government& Agency Obligations
+TOTAL FIXED INCOME
+MARKET VALLE
+4,676,974
+130,985
+$13,715,716 $509,313
+$13.715,716
+$509,313
+$11,459,731
+$11,459,731
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+$509,313
+$11,459,731
+$13,740,236
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TREE
+12/09/02
+TRANSACTION
+PRINCIPAL
+... . ..
+FEDERAL HOME LOAN MG CORP
+SERIES 2471 CLASS VT
+000 DUE 03/15/3
+EV INC PAN 11/15/
+SYMBOLCUSIP
+QUANTITY
+2,639,915
+PRICE
+DEBIT AMOUNT
+027
+
+
+6 of 11
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SETTEMENT TREE
+12/09/02
+TRANSACTION
+PRINCIPAL
+12/12/02*110702"BÖÜGHT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+12/12/02
+'''T174/02**"CANGEL"SEL
+12712/02
+11/07/02 CANCEL BUY
+12/42702*74794/02SOLD
+12772782"
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+PAY CORN 15/1502
+*FNMA 30YR/FNMA) GTD
+SETT. 12/02
+WE 12/01/2031 06.000%
+REF #1
+BS
+SEE 12072021 06.000%
+REF #
+BS
+S OF 11/14/08
+O CXL PREVIOUS SE
+FNMA-30YA/FNMA) GTO
+SETT. 12/02
+DUE 12/01/2031 06.000%
+TO CXL PREVIOUS BUY
+"ENMA 30YR(FNMA)GTD
+PUE 120172031,06.000%
+REF #L
+SETT, 12/02
+RUE 12/01/2032 05.500%
+TO CAL PREVIOUS SELL
+BS
+BS
+BS
+SYMBOLGUSIF
+QUANTITY
+-1,915,857
+25,000,000
+PRICE
+102.62500
+25,000,000
+- 102.79688
+25,000,000
+102.62500
+25,000,000
+10,000,000
+102.79688
+' 0052734"
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+November 29, 2002
+DEBIT AMOUNT
+•'25.656,250.00
+25.699.218.75
+25,656,250.00
+25,699,218.75
+*10,852,734.38
+
+
+7 of 11
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SETTLEMENT TRADE
+DATE
+TRANSACTION
+12/12/02
+11/07/02
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+12/1202* 12/0402*SOLD
+12/12/02
+'''11/07/02 CANCEL BUY"
+12/18/02
+12716/02
+12716/02
+12/16/02
+12716/02
+"PRINCIPAL'
+PRINCIPAL
+PRINCIPAL
+PRINCIPAL
+"PRINCIPAL
+FNMA- 30YR(FNMA) GTD
+SETT, 12/02
+PUE 1201/2032 05.500%
+REF #
+BS
+SETT. 12/02
+DUF: 1200172032 05.500%
+REF #
+BS
+ETT. 12/0
+JE 12/01/2032 05,500
+RE
+AS OF 11/0702
+TO CXL PREVIOUS BUY
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+PAINIPAL EDUCTIN 12-15-02
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+1,000 DUE 03/15/3
+PRINCIPAL REDUCTN 12-15-01
+"FEDERAL HOME LOAN MTG CORP
+SERIES 2483 CL SI
+5,580 DUE 03/15/32
+PRINCIPAL REDUCTN 12-15-02
+FEDERAL HOME LOAN MIG CORF
+SERIES 2483 CL SL
+580 DUE 03/15/
+INCIPAL REDUCTN 12-15-
+"FEDERAL HOME LOAN MIG CORP
+ERIES 2488 CLASS S
+.580 DUE 03/15/3
+PRINCIPAL REDUCTN 12-15-02
+SYMBOLGUSF
+027
+QUANTITY
+10,000,000
+10,000,000
+- 10,000,000
+PRICE
+100.90625
+'100.52734"
+*100.90625
+2,196,000
+250
+1,821,000
+967
+-1,579,000
+01/01/03:08:59 001
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+November 29, 2002
+DEBIT AMOUNT
+10,090,625.00
+10,052,734.38
+10,090,625.00
+
+
+8 of 11
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+12/16/02
+TRANSACTION
+PRINCIPAL
+12/18/02
+PRINCIPAL
+12/16/02
+PRINCIPAL
+1216/02
+PRINCIPAL
+TOTAL
+INTEREST
+DATE
+12/02/02
+AVG BAL
+58,609RT 5.658
+021 OFFICE INTEREST 1102
+12/16/02* "FEDERAL HOME LOAN MIG CORP
+NER 372 GAST 129802
+12/16/02
+'"FEDERAL HOME LOAN MIG CORP
+RER ANENT 1318002
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+FEDERAL HOME LOAN MIG CORP
+SERIES 2488 CLASS SQ
+PRINCIPAL REDUCTIN 12-15-02
+FEDERAL HOME LOAN MIG CORP
+SERIES 2530 CLASS SE
+5.980 DUE 02/15/32
+PRINCIPAL REDUCTN 12-15-02
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2530 CLASS SE
+5,980 DUE 02/15/32
+PRINCIPAL REDUCTN 12-15-0:
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2526 CLASS SI
+580 DUE 02/15/:
+INCIPAL REDUCTN 12-15-
+SYMBOUCUSIP
+QUANTITY
+RATE (%)
+1.0000
+''5.5800
+027
+QUANTITY
+-240
+1,917,000
+990
+822,727
+PRICE
+DEBIT AMOUNT
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+November 29, 2002
+DEBIT AMOUNT
+CRECIT AMOUNT
+$-71,498.828.13
+$71,498,828.13
+313.20
+:*54,886.15
+255,834.70
+
+
+9 of 11
+Transaction Detail (continued)
+INTEREST (continued)
+1216/02
+FEDERAL HOME LOAN MIG CORP
+RIES 2488 CLASS
+EnEST FAYMENT 1233-
+12/16/02
+'''FEDERAL HOME LOAN MIG CORP
+SER 452 AS 59902
+12/16/02 "FEDERAL HOME LOAN MIG CORP"
+GEES AERS GLASS $58
+TEREST PAYMENT 12-15-0
+12/31/02
+TOTAL
+AVG BAL 54,420
+54,420RT
+021 OFFICE INTEREST 1202
+MISCELLANEOUS
+DATE
+MODAY
+TAANSACTION
+12/10/02
+JOURNAL
+12/11702
+JOURNAL'
+12/11/02
+JOURNAL"
+12/12/02
+JOURNAL
+12/13/02
+12713/02
+JOUANAL'
+"JOURNAL
+NOV 02 CLEARING FEES
+"FIM TO FITG***
+ENMA 30YR(FNMA)GTD
+SETT, 12/02
+5.500 DUE 12/01/32
+MBS NET 12/11/02
+ENMA 30VR(FNMA) GTD
+SETT. 12/02
+6,000 DUE 12/01/31
+MBS NET 12/12/02
+PREMIN
+AIM PREM
+SYMBOUCUSIP
+QUANTITY
+RATE (%)
+6.5800
+5.9800
+5.5800
+DEBIT AMOUNT
+1,400.00
+*46.00
+*37,890.62
+027
+DEBIT AMOUNT
+CRECIT AMOUNT
+2,968.7
+:233.03
+34,000.00
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+November 29, 2002
+261,218.15
+278,500.00
+'''114,101.47
+9 3
+$964,882.99
+
+
+10 of 11
+Transaction Detail (continued)
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+12/17/02
+TRANSACTION
+RECEIVED
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+1271702 AECEIVED"
+"DELIVERED
+20/44/21
+DELIVERED
+12/17/02 DELIVERED
+12/18/02
+TOTAL
+JOURNAL
+ADP CD
+DUE 12/31/2049
+8,625
+3.625 0 123/49
+"АБР'СЬ"
+DUE 12/31/2049
+8,625
+8.625 DUE 12/81/448
+EITM-PR
+"ADP CD*
+DUE 12/31/2049
+8.625 DUE 22131498.625
+EITM-PRI
+*ABP CD
+DUE 12/31/2049
+8.625 DU: 12181498,625
+FITM-PR
+"ADP CD"
+DUE 12/31/2049
+B.25 DUE 1248148,625
+FITM-PR
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS VT
+1.000 DUE 03/15/32
+P&I TRER
+DEBIT AMOUNT
+3,540,000.00
+''4.557,000.00
+*473.97
+3,540,000.00
+3,540,00000
+$-8,136,336.62
+23,522.6
+$7,182,198.39
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 29, 2002
+
+
+11 of 11
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Trades Executed Pending Settlement
+SETLEMENT TREE
+TRANSACTION
+01/14/03 12/04/02 BOUGHT
+FNMA-30YR(FNMA) GID
+SETT,01/03
+DUE 01/01/2033 05.500%
+REF #
+TOTAL
+The above trades do not appear in any other section of thia statement.
+BS
+STOP
+****** End of Statement******
+SYMBOLCUSIP
+QUANTITY
+10,000,000.00
+PRICE
+100.0937
+027
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD November 30, 2002
+THROUGH
+December 31, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 29, 2002
+DEBIT AMOUNT
+10,009,375.00
+CRECIT AMOUNT
+$10,009,375.00
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary.............................
+Your Portfolio Holdings
+Transaction Detail ....
+Trades Not Yet Settled
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 26, 2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 25, 2002
+3
+4
+6
+11
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+7,421,941
+449,808
+13,776
+$7,885,525
+NET EQUITY LAST STATEMENT
+7,987,189
+CHANGE SINCE LAST STATEMENT
+- 101,664
+*This portfolio indudes one or more unpriced securies that are not
+relected in the Total Value of Securties and the Net Equity This Period
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$13,776
+Cash & Equivalent
+Fixed
+Income
+- 57.121.941
+$7,803,210
+Current market value
+Last statement's market value
+SP The suremen s four or ratanal furyce rear die Set revere date for portant formation.
+
+
+2 of 12
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 of12
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited.
+Net Cash Activity
+Closing Balance,
+Cash Balance Summary
+OPENING
+Margin
+Net Cash Balance
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERIOD
+$-L
+.....•..
+71,571,875.00
+573,407.23
+32,826,889.93
+$104,972,172.16
+-79,641,806.39
+-183,214.02
+-25,133,376.00
+5-104,958. 396.41
+13,775.75
+.......
+$13.775.71
+Income Summary
+THIS PERIOD
+Govt. Agency Int.
+573,293.59
+Credit Balance Int.
+113.64
+5573.407.23
+Bond Purchase Int.
+-183,214.02
+Portfolio Composition
+Cash/Cash Equivalent
+Fixed Income
+Totall
+CLOSING
+13,775.71
+.........
+13,775.7
+.....
+027
+YEAR TO DATE
+1,838,334.77
+693.02
+****---.
+$1,839,027.79
+... . .
+-497,459.47
+13,776
+7,421,941
+....
+$7.435.717
+LEARED THROUGH IT:
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 25, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+< 1%
+- Fixed Income
+99%
+Unshaded portions denote debit balance and or shart
+
+
+4 of 12
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SIMBCLCUSIP
+FIXED INCOME
+Government & Agency Obligations
+FEDERAL HOME LOAN MTG CORP
+SERIES 2530 CLASS SE
+INTEREST FROM DATE 11/15/02
+DATED DATE 10/11/02
+FIRST COUPON 12/15/2002
+BOOK ENTRY ONLY
+UE 02/15/2032 5,5709
+ACTOR - 1.0000000
+FEDERAL HOME LOAN MIG CORP
+SERIES 2526 CLASS SI
+INTEREST FROM DATE 11/15/02
+DATED DATE 10/01/02
+IRST COUPON 12/15/200
+BOOK ENTRY ONL
+DUE 02/15/2032 5,320%
+- 1.0000000
+EOEAL HOME LON NITE CORI
+SYMBOLCUSP
+BUT 05152032 1,000%
+FACTOR..
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+QUANTITY
+PRICE
+QUANTITY
+60,000,000
+........
+MAGN
+.......
+25,737,174
+MAGN
+65,139,320
+MARKET
+VALUE
+13,776
+$13,776
+ANNE MACED
+PRICE
+Unpriced
+MARKET VALLE
+129,966
+Unpriced
+53,248
+3.3013
+2,150,428
+25,331
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 25,2002
+ANNUAL INCOME
+3,342,000
+....
+1,369,218
+VIELD (S
+651,393
+30.2913
+VE3B
+
+
+5 or 12
+Your Portfolio Holdings (continued)
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Government & Agency Obligations (continued)
+SYMBOLCUSP
+FEDERAL HOME LOAN MIG CORP
+BOOK ENTRY ONLY
+PACT 5347193318%
+FEDERAL HOME LOAN MIG CORP
+SATED DATE 0702/02
+BOOK ENTRY ONLY
+Total Government& Agency Obligations
+TOTAL FIXED INCOME
+MAGN
+QUANTIT
+47,359,665
+MAGN
+54,638,781
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+PRICE
+Unpriced
+MARKET VALUE
+ACCRUED
+INTEREST
+121,890
+9.6479
+5,271,513
+119,373
+$7,421,941
+$7,421,941
+$449,808
+$449,808
+$449,808
+$11.566,481
+$7,435,717
+120
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 25, 2002
+ESTIMATED
+ANNUAL INCOME
+3,134,263
+CURRENT
+YIELD (S)
+3,069,607
+58.2301
+$11,566,481
+$11,566,481
+
+
+6 of 12
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEEMENT TATE
+11/14/02
+
+TRANSACTION
+17/4/02"•*T170702"CANCEL SELL"
+11714/02
+10/09/02
+"CANCEL BUY
+11/14/02
+*''T1/07/02 SOLD*
+17714/02
+11/05/02
+"BOUGHT
+T1/14/02
+11707/02
+'CANCEL SELL"
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+FNMA- 30YR(FNMA) GTD
+SETT, 11/02
+DUE 110112032 06.000%
+REF #
+SETT. 11/02
+DUE 11101/2032 06.000%
+REF #1
+AS OF 11/07:02
+TO CXL PREVIOUS SELL
+*FNMA-30YR(FNMA)GTD
+SET 11012032,06.000%
+REF #
+AS OF 10103102
+TO CXL PREVIOUS BUY
+FNMA-30YR(FNMA) GTO
+SETT. 11/02
+DUE 11072032 06,000%
+REF #1
+SETT. 11/02
+PUE 11101/2032 05.500%
+REF F
+SETT. 11/02
+DUE 11/01/2032 05.500%
+REF #
+AS OF 11/07/02
+TO CAL PREVIOUS SELL
+BS
+IBS
+BS
+BS
+Is
+BS
+SYMBOL/GUSP
+5N94582
+"5N94582
+5N94582
+5N94582
+027
+QUANTITY
+25,000,000
+'25,000,000
+PRICE
+102.65625
+:102.96875*
+25,000,000
+-25,000,000
+10,000,000
+'102.65625
+102.96875
+100.40625
+10.000,000
+101.25000
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+October 25, 2002
+DEBIT AMOUNT
+25,664,062.50
+• 25,742,187.50*
+25,664,062.50
+25,742,187.50
+10,040,625.00
+10,125,000.00
+
+
+7 of 12
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SETTLEMENT TRADE
+DATE
+TRANSACTION
+11/14/02
+11/05/02
+CANCEL BUY
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+11714/02*11/07/02 SOLD
+FNMA-30YR(FNMA)GTD
+SETT, 11/02
+RUE 110112032 05.500%
+REF #
+AS OF 11/05/02
+TO CXL PREVIOUS BUY
+FNMA-30YR(FNMAJGTD
+BS
+17715/02
+11715/02
+1715/02
+17715/02
+11715/02
+7975/02
+PRINCIPAL
+"PRINCIPAL"
+"PRINCIPAL
+PRINCIPAL
+PRINCIPAL
+"PRINCIPAL
+I BS
+"FEDERAL HOME LOAN MTG CORP
+SERIES 2471 CLASS YT
+PRINCIPAL REDUCTN 11-15-02
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+1.000 DUE 03/15/32
+PRINCIPAL REDUCTN 11-15-03
+"FEDERAL HOME LOAN MIG COR"
+SERIES 2483 CL SL
+SING PALE US 11-1502
+FEDERAL HOME LOAN MIG CORP
+SERIES 2483 CL SL
+5.618 DUE 03/15/32
+PRINCIPAL REDUCTN 11-15-0:
+FEDERAL HOME LOAN MIG CORP
+SERIES 2488 CLASS SO
+618 DUE 03/15/3
+RINCIPAL REDUCTN 11-15-0
+"FEBERAL" HOME' LOAN MIG CORP
+SERIES 2488 CLASS SQ
+6.618 DUE 03/15/32
+PRINCIPAL REDUCTN 11-15-0:
+SYMBOLGUSF
+027
+QUANTITY
+-10,000,000
+PRICE
+100.40625
+-10,000,000
+"101.25000"
+2639,000
+915
+1,589000*
+347
+1,377,000
+810
+11/3002;14:25 001
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 25, 2002
+DEBIT AMOUNT
+10,040,625.00
+10,125,000.00
+
+
+8 of 12
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SETTLEMENT TRADE
+DATE
+DATE
+TRANSACTION
+11/29/02
+11/13/02
+1972902 11713/02 "BOUGHT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+FEDERAL HOME LOAN MIG CORP
+SERIES 2530 CLASS SE
+PUE 02/15/2032.05.570%
+AS OF 11/1302
+BS
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2530 CLASS SE
+DUE 02/15/2032 05.570%
+REF #1
+BS
+AS OF 11713/02
+.......
+FEDERAL HOME LOAN MTG CORP
+SERIES 2526 CLASS SI
+DUE 0211512032 05,320%
+REF #
+BS
+AS OF 11/05/02
+1/29/02
+11/05/02
+TOTAL
+INTEREST
+1028/02
+VG BAL 157,735RT 1.08
+21 OFFICE INTEREST 100
+11715/02
+'""EDERAL HOME LOAN MIG CORP"
+R8256/32GUA 19902
+11715/02
+'"FEDERAL HOME LOAN MIG CORP
+RECI
+AMENT 15615-02
+SYMBOL/CUSIP
+SYMBOLGUSP
+QUANTITY
+RATE (%)
+1.0000
+5.6180
+027
+QUANTITY
+10,000,000
+ACCR. INT.
+50,000,000
+ACCR. INT.
+25,737,174
+ACCR. INT.
+PRICE
+9.56250
+9.56250
+9.06250
+DEBIT AMOUNT
+LEARED THROUGH IT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+October 25, 2002
+DEBIT AMOUNT
+956,250.00
+21,661.11
+CRECIT AMOUNT
+"4781,250.00
+108,305.56
+2,332,431.39
+53,247.35
+$-79.825,020.41
+$71,571,875.00
+113.64
+*77,829.12
+243.655.22
+
+
+9 of 12
+Transaction Detail (continued)
+INTEREST (continued)
+DATE
+11/15/02
+FEDERAL HOME LOAN MG CORP
+SERIES 2488 CLASS SQ
+RHEAST 13RRENT 1191.02
+TOTAL
+MISCELLANEOUS
+DATE
+MO/DAY
+10/29/02
+TRANSACTION
+RECEIVED
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUCUSIP
+10129(02
+RECEIVED
+1029/02 DELIVERED
+10/29/02
+DELIVERED
+10/29/02
+DELVERED
+ADP CD
+DUE 12/31/2049
+8.625
+8.625 DUE 1281/49
+EITM-PR
+*ADP CD
+DUE 12/31/2049
+8,625
+8,625 DUE 12/31/49
+FITM-PRI
+"ADP CD**'
+DUE 12/31/2049
+8,625
+8.625 DUE 12/31/49
+FITM-PR_I
+"ADP CD
+DUE 12/31/2049
+8.625 DU: 22131498,625
+FITM-PR 1
+DUE 12/31/2049
+8,625
+8.625 DUE 1213149
+EITM-PR
+QUANTITY
+RATE (%)
+6.6180
+DEBIT AMOUNT
+9,400,000.00
+11,400,000.00
+027
+DEBIT AMOUNT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 25,2002
+251,809.25
+$573.407.23
+CRECIT AMOUNT
+432.50
+872.78
+'22,419.00
+
+
+10 or 12
+Transaction Detail (continued)
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+10/29/02
+TRANSACTION
+DELIVERED
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+10/29702 BELIVERED"
+10/29/02
+DELIVERED
+10/29/02
+DELIVERED
+11/1202
+"QUANAL
+
+17714/02
+1118/02
+
+JOURNAL"
+"JOUANAL"
+1171902 TOURNAL
+ADP CD
+DUE 12/31/2049
+8,625
+.625 DUE 12/31/49
+ITM-PR
+"АБРСЬ"
+DUE 12/31/2049
+8,625
+8.625 DUE 12/81/448
+EITM-PR
+"ADP CD*
+DUE 12/31/2049
+8.525 DUE 12131498.625
+EITM-PRI
+"ADP CD
+DUE 12/31/2049
+8.625 DU: 12181498,625
+FITM-PR
+*OCT 2002CLEAR LES
+ENMA 30YR(FNMA)GTD
+SETT, 11/02
+.000 DUE 11/01/
+BS NET 11/14/
+*FNMA-30YR(FNMA)GTD
+SETT. 11/02
+5.500 DUE 11/01/32
+MBS NET 11/14/02
+"FEDERAL HOME LOAN MIG COAT"
+SERIES 2471 CLASS VT
+1.000 DUE 03/15/3
+P&I TRNFI
+"PREM.PAN. ADJ:
+DEBIT AMOUNT
+*250.00
+332. 126.00
+• 427,000.00
+027
+1,000,000.00
+1,000,000.00
+9,400,000.00
+9,400,000.00
+*78,125.00
+84,375.00
+2,860.45
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 26, 2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 25, 2002
+
+
+11 of 12
+Transaction Detail (continued)
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+11/19/02
+11/29/02
+TRANSACTION
+JOURNAL
+RECEIVED
+1729/02 DELIVERED
+11/29/02
+DELIVERED
+PREM.INT. ADJ
+"ADP CD"
+DUE 12/31/2049
+8.525 DUE 22431498,625
+FITM-PR
+****35CB***********
+DUE 12/31/2049 8,625
+8.625 DUE 12181/49
+FITM-PR
+ADP CD
+DUE 12/31/2049
+3.625 DU: 2213/49 8,625
+FITM-PR
+TOTAL
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Trades Executed Pending Settlement
+SATEEMENT TREE
+12/12/02
+11/07/02
+TRANSACTION
+FNMA-30YR(FNMA) GTD
+SETT.12/02
+DUE 12/01/2031 06.000%
+REF # |
+BS
+DEBIT AMOUNT
+*3.574,000.00
+,457.50
+3,347.70
+11.827,000.00
+$-25,133,376.00
+$32,826,889.93
+SYMBOLICUSIP
+QUANTITY
+25,000,000.00
+PRICE
+102.6250
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 25, 2002
+DEBIT AMOUNT
+25,656,250.00
+
+
+12 or 12
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Trades Executed Pending Settlement
+ELEMENT TRADE
+TRANSACTION
+12/12/02 11/14/02
+SOLD
+(continued)
+12/12/02 1107/02 BOUGHT
+TOTAL
+FNMA-30YR(FNMA) GTD
+SETT. 12/02
+DUE 12/01/2031 06.000%
+REF #
+SETT, 12/02
+DUE 12/01/2032 05,500%
+REF #
+The above trades do nat appear in any other section of this statemart.
+BS
+STOP
+****** End of Statement******
+SYMBOL/CUSIP
+QUANTITY
+-25,000,000.00
+PRICE
+102.7968
+10,000,000.00
+# 1009062
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD October 26,2002
+THROUGH
+November 29, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+October 25, 2002
+DEBIT AMOUNT
+CAEDIT AMOUNT
+25,699,218.75
+*10,090,625.00
+$35,746,875.00
+$25,699,218.75
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary.............................
+Your Portfolio Holdings
+Transaction Detail ....
+Trades Not Yet Settled
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 27,2002
+3
+4
+9
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+LONG ACCRUED INTEREST
+NET EQUITY THIS PERIOD
+7.803.210
+183,979
+$7,987,189
+NET EQUITY LAST STATEMENT
+8,248,273
+CHANGE SINCE LAST STATEMENT
+-261,084
+This portfolio indudes one or more unpriced securties that are no
+reflected in the Total Value of Securtes and the Net Equity This Period
+or sel apen orders onese for your acher pending buy
+Market Value of Your Portfolio
+$15,467
+Cash & Equivalent
+Fixed
+Income
+$7,803,210
+$8,000,901
+Current market value
+Last statement's market value
+SP This satement stori for atanal for our red de. not revere did ora dotan itormation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 or 9
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Funds Withdrawn
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERIOD
+_515.467.44
+25,484,375.00
+580,262.32
+1,475,379.20
+....
+$27,540,016.52
+-25,484,375.00
+-71,010.00
+-2,000,099.00
+$-27.5.484.00
+-15,467.48
+Income Summary
+Govt. Agency Int.
+Credit Balance Int.
+Bond Purchase Int.
+THIS PERIOD
+579,850.46
+411.86
+580,262.3
+Portfolio Composition
+Fixed Income
+Total
+SHOAT
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+15,467.44
+$15,467.44
+CLOSING
+027
+YEAR TO DATE
+1,265,041.18
+579.38
+----.
+$1,265,620.56
+.. . .
+-314,245.45
+LONG
+7,803,210
+$7.803.210
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 27,2002
+Your Portfolio
+Allocation
+Fixed Income-
+100%
+Unshaded portions denole debi balance and'or short
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+DATED DATE 06/07/02
+BOOK ENTRY ONLY
+RIES 2488 CLASS S
+TED DATE 07/08/C
+BOOK ENTRY ONLY
+FEDERAL HOME LOAN MIG CORP
+SERIES 2483 CL SL
+Total Government& Agency Obligations
+TOTAL FIXED INCOME
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SIMBCLCUSIP
+QUANTITY
+PRICE
+SHMBOLCUSP
+MAGN
+MAGN
+QUANTITY
+67,779,235
+48,737,273
+MAGN
+56,228,128
+MARKET
+VALUE
+PRICE
+3.3578
+Unpriced
+9.8302
+027
+ESTIMATED
+ANNUAL INCOME
+MARKET VALLE
+2,275,887
+18,830
+83,935
+5,527,323
+$7,803,210
+$7,803,210
+81,214
+$183,979
+$183,979
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 27,2002
+ESTIMATEC
+ANNUAL INCOM
+677,792
+3,021,711
+URREN
+HELD I
+29.7814
+2,923,863
+$6,623,366
+$6,623,366
+52.8984
+VE37
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+Your Portfolio Holdings (continued)
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SEEN TRADE
+RANSACTIO
+10/15/02 09/04/02
+10/15/02
+09/0402
+'CANCEL BUY
+10/15/02
+"PRİNCİPAL"
+DESCRPTION
+FNMA-30YR(FNMA) GTD
+SETT. 10/02
+PUF 120172032,06,000%
+REF #
+BS
+ENMA 30YR(FNMA) GTD
+SETT.10/02
+DUE 10/01/2032 06,000%
+REF #L
+BS
+AS OF 09/04/02
+TO CXL PREVIOUS BUY
+FEDERAL HOME LOAN MIG CORP
+1,000 DUE 031582 T
+PRINCIPAL REDUCTN 10-15-02
+$183,979
+$6,623,366
+$7,803,210
+SYMBOLCUSIP
+QUANTITY
+25,000,000
+PRICE
+101.93750
+25,000,000
+'101.93750
+1,402,000
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 27,2002
+DEBIT AMOUNT
+25,484,375.00
+25,484,375.00
+VE37
+
+
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SEEMENT TRE
+10/15/02
+TRANSACTION
+PRINCIPAL
+10/15/02
+PRINCIPAL
+10/15/02
+PRINCİPAL
+10/15/02
+JOURNAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+10/16/02
+JOURNAL
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+PRING PAL REDUCT 10-15.02
+FEDERAL HOME LOAN MIG CORF
+SERIES 2483 CL SL
+5,176 DUE 03/15/32
+PRINCIPAL REDUCTN 10-15-02
+"FEDERAL HOME LOAN MIG CORP"
+SERIES 2488 CLASS SO
+6.176 DUE 03/15/32
+PRINCIPAL REDUCTN 10-15-02
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS Y
+.000 DUE 03/15/3
+FITMARGN
+A2
+RP TERM
+TERM REPO AGREEMENT
+1,000 DUE 03458
+-ITMARGN
+LAT
+RP OPEN|
+REPO AGREEMENT
+TOTAL
+DEPOSITS AND WITHDRAWALS
+DATE
+10/03/02
+TRANSACTION
+FND WIRED
+TOTAL
+BER NATOREL BARI
+WIRED TO
+SYMBOLGUSIF
+DEBIT AMOUNT
+71,010.00
+$-71,010.00
+027
+QUANTITY
+-726
+844,507
+732,000
+3.432,534
+PRICE
+-29,048,244
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+September 27,2002
+DEBIT AMOUNT
+$-25,484,375.00
+$25,484,375.00
+
+
+7 org
+Transaction Detail (continued)
+INTEREST
+
+021 OFFICE INTEREST 09026
+10/15/02 "FEDERAL HOME LOAN MIG CORP"
+SEE REST ALAST 109502
+10/15/02 "FEDERAL HOME LOAN MIG CORP"
+SERE BAGENT 8. 7802
+10/15/02
+FEDERAL HOME LOAN MIG CORP
+ERIES 2488 CLASS 9
+TOTAL
+SYMBOUCUSIP
+QUANTITY
+RATE (%)
+1.0000
+* 5.1760
+6.1760
+MODAY
+TAANSACTION
+10/04/02
+JOURNAL
+10/07/02 RECEIVED
+10/07/02
+DELIVERED
+FITG TO FITM
+"ADP CD"*''
+DUE 12/31/2049
+8.625
+8.625 DUE 12/31/49
+FITM-PR
+ABP CB
+DUE 12/31/2049
+8,625
+8.625 DUE 1213149
+EITM-PR
+DEBIT AMOUNT
+1,000,000.00
+027
+DEBIT AMOUNT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 27,2002
+411.86
+78,998.06
+* 246,214.67
+254,637.73
+$580,262.32
+CRECIT AMOUNT
+1,527.00
+894.48
+
+
+8 org
+Transaction Detail (continued)
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+T0/07/02
+TRANSACTION
+DELIVERED
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ADP CD
+DUE 12/31/2049 8,625
+.625 DUE 1281/4
+TM-PRI
+DEBIT AMOUNT
+10/09/02 JOUANAL"
+10/10/02 JOUANAL*
+18/45702 OUANAL"
+10/16/02
+JOURNAL
+10/18/02
+RECEIVED
+'''50.00
+*... 49.00
+JOURNAL
+SETT. 10/02
+,000 DUE 10/01/32
+JIBS NET 10/15/02
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+1.000 DUE 03/15/32
+P&I TANFR
+"ABP CB
+DUE 12/31/2049
+B.625 DUE 12181/438,625
+FITM-PRI
+FIG TO FITM
+1,000,000.00
+10/21/02
+TOTAL
+$-2,000,099.00
+027
+1,190,000.00
+278,320.31
+2,903.41
+1,734.00
+$1,475,379.20
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 27,2002
+
+
+9 org
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Trades Executed Pending Settlement
+SETLEMENT TREE
+TRANSACTION
+11/14/02 10/09/02 BOUGHT
+FNMA-30YR(FNMA) GTD
+SETT, 11.02
+DUE 11/01/2032 06.000%
+REF #
+TOTAL
+The above trades do not appear in any other section of this statement
+BS
+STOP
+****** End of Statement******
+SYMBOLCUSIP
+5N94582
+QUANTITY
+25,000,000.00
+PRICE
+102.6562
+027
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD September 28, 2002
+THROUGH
+October 25, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 27, 2002
+DEBIT AMOUNT
+25,664,062.50
+CREDIT ANKUNT
+$25,664,062.50
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary.............................
+Your Portfolio Holdings
+Transaction Detail ....
+Trades Not Yet Settled
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 30,2002
+3
+4
+9
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+8,000,901
+231,905
+15,467
+$8,248,273
+NET EQUITY LAST STATEMENT
+3,531,317
+CHANGE SINCE LAST STATEMENT
+4,716,957
+*This portfolio indudes one or more unpriced securies that are not
+relected in the Total Value of Securties and the Net Equity This Period
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$15,467
+$116,153
+Cash & Equivalent
+Fixed
+Income
+$8,000,901
+$3,122,857
+Current market value
+Last statement's market value
+SP This satement stori for ratanal for our red de. pot revere did ora dotan itormation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+09/29/02;12:44 001
+
+
+3 org
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance
+THIS PERIOD
+$116,152.92
+... .
+76,139,231.57
+893,355.55
+518,584.04
+S77.551,171.16
+.....
+-76,128,187.98
+-308,618.66
+-1,215,050.00
+$-77.651.856.64
+- 100,685.48
+$15.467.44
+Income Summary
+Govt. Agency Int.
+Credit Balance Int.
+Bond Purchase Int.
+THIS PERIOD
+604,811.55
+119.34
+5604,930.89
+-20,194.00
+Portfolio Composition
+Cash/Cash Equivalent
+Fixed Income
+Total
+Cash Balance Summary
+Margin
+Net Cash Balance
+OPENING
+116,152.92
+$116,152.92
+CLOSING
+15,467.44
+.....
+515.467.44
+027
+YEAR TO DATE
+685,190.72
+167.52
+... . .
+$685,358.24
+.. ...
+-314,245.45
+15,467
+8,000,901
+58.016,368
+09/29/02;12:44 001
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 30, 2002
+Your Portfolio
+Allocation
+Cash & Equivalent -
+< 1%
+- Fixed Income
+99%
+Unshaded portions denote debit balance and or shart
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+FEDERAL HOME LOAN MTG CORP
+SERIES 2471 CLASS YT
+DATED DATE 06/07/02
+BOOK ENTRY ONLY
+DUE 03/15/2032 1000%
+FACTOR -
+FEDERAL HOME LOAN MG CORP
+ERIES 2488 CLASS S
+MATED DATE 07/08/0
+BOOK ENTRY ONLY
+DUE 03/15/2032 6 176%
+FACTOR -
+FEDERAL HOME LOAN MIG CORP
+SERIES 2483 CL SL
+Total Government& Agency Obligations
+TOTAL FIXED INCOME
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SIMBCLCUSIP
+QUANTITY
+PRICE
+SHMBOLCUSP
+MAGN
+MAGN
+QUANTITY
+94,797,671
+49,469,275
+MAGN
+57,072,635
+MARKET
+VALUE
+15,467
+$15,467
+PAICE
+2.9713
+Unpriced
+9.0835
+027
+STIMATE
+ANUAL INCON
+MARKET VALLE
+2,816,686
+CORUE
+TERE
+31,598
+101,840
+5,184,215
+$8,000,901
+$8,000,901
+98,467
+$231,905
+$231,905
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 30, 2002
+ESTIMATEC
+INNUAL INCOM
+947,977
+3,055,222
+SURREN
+33.6558
+2,954,080
+$6,957,279
+$6,957,279
+56.9822
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+Your Portfolio Holdings (continued)
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+TRANSACTION
+09/13/02 07/19/02
+09/13/02 07719/02 CANCEL BUY"
+FNMA-30YR(FNMA) GTD
+SETT.09/02
+DUE 091012032,06,000%
+REF #
+SETT.09/02
+DUE 09/01/2032 06.000%
+REF #L
+AS OF 07/19/02
+TO CXL PREVIOUS BUY
+BS
+BS
+$231,905
+$6,957,279
+$8,016,368
+SYMBOL/CUSP
+QUANTITY
+25,000,000
+PRICE
+100.29688
+25,000,000
+'100.29688"
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD August 31, 2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 30, 2002
+DEBT AMOUNT
+25,074,218.75
+25,074,218.75
+
+
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SATEEMENT TATE
+DATE
+TRANSACTION
+09/16/02
+07/19/02
+09/16/02 09/04/02 "CANCEL SELL"
+09/16/02
+07719/02
+"CANCEL BUY
+09/16/02
+209104/02
+"SOLD
+09/16/02
+PRINCIPAL
+09/18/02
+PRINCIPAL
+09/16/02
+"PRINCIPAL"
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+FNMA-30YR(FNMA) GTD
+SETT 09/02
+DUE 09101/2032 06,000%
+AS OF 0771902
+BS
+ETT 09/0:
+JE 09N01/2032 06.000
+REF #
+AS OF 0910402
+TO CXL PREVIOUS SELL
+BS
+SETT.09/02
+DUE 09101/2032 06.000%
+REF #
+BS
+AS OF 07/19/02
+TO CXL PREVIOUS BU
+MA 30YR(FNMA)GTD
+SETT, 09/02
+PIE 0910172032,06,000%
+REF #L
+BS
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+1,000 DUE 03/15/32
+PRINCIPAL REDUCTN 09-15-02
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+1,000 DUE 03/15/32
+PRINCIPAL REDUCTN 09-15-02
+"FEDERAL HOME LOAN MIG CORP
+SERIES 2483 CL SL
+5,161 DUE 03/15/32
+PRINCIPAL REDUCTN 09-15-02
+SYMBOLGUSF
+027
+QUANTITY
+25,000,000
+25,000,000
+PRICE
+100.29688
+102.34766
+25,000,000
+100.29688
+25,000,000
+1,017,000
+22
+612,297
+102.34766
+LEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+August 30,2002
+DEBIT AMOUNT
+25,074,218.75
+'25.586,914.07
+25,074,218.75
+25,586,914.07
+
+
+7 of g
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+TEMENT TREE
+09/16/02
+TRANSACTION
+PRINCIPAL
+09/25/02 09/20/02 BOUGHT
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+FEDERAL HOME LOAN MIG CORP
+SERIES 2488 CLASS SQ
+PRINCIPAL REDUCTN 09-15-02
+EDERAL HOME LOAN MIG COF
+ERIES 180 CAS6,O00-
+REF #
+ACCRUES ON 1ST, PAYS ON 15TH
+FEDERAL HOME LOAN MG CORP
+SERIES 2466 CLASS EI
+DUE 05/15/2017 06.000%
+REF #1
+BS
+ACCRUES ON 1ST, PAYS ON 15TH
+.....
+09/25/02
+09/20/02
+SOLD
+TOTAL
+INTEREST
+DATE
+09/03/02
+AVG BAL 112,761RT 1.08
+121 OFFICE INTEREST 080
+09/16/02*"FEDERAL HOME LOAN MIG CORP
+ZAVMENT 08-15-0
+05/1502
+'PEDERAL HOME LOAN MIG CORP
+SERE GENT 08:1802
+09/18/02
+"FEBERAL HOME LOAN MIG CORP
+ERIES 2488 CLASS S
+MEREST ARMENT 08150
+SYMBOUCUSIP
+QUANTITY
+RATE (%)
+1.0000
+5.1610
+6.1600
+027
+QUANTITY
+-530,725
+5,048,500
+ACCR. INT.
+-5,048,500
+PRICE
+* 7.78125
+8.00000
+ACCR. INT.
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+August 30, 2002
+DEBIT AMOUNT
+*392,836.41
+20,194.00
+$-76,148,381.98
+403,880.00
+20,194.00
+$76,159,425.57
+DEBIT AMOUNT
+119.34
+*79,845.58
+288,42466
+256,666.67
+
+
+8 of g
+Transaction Detail (continued)
+INTEREST (continued)
+
+FEDERAL HOME LOAN MIG CORP
+REAR R A 6818,25
+09/17/02
+FEDERAL HOME LOAN MIG CORP
+ERIES 2483 CL S
+TOTAL
+MISCELLANEOUS
+DATE
+MODAY
+09/05/02
+TRANSACTION
+JOURNAL
+09/11:02
+"JOURNAL"
+09/12/02
+ÖURNAL'
+08/16/02 OURAL
+08/17/02
+JOUANAL'
+09/18/02
+RECEIVED
+TOTAL
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUCUSIP
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+1.000 DUE 03/15/32
+P&I TRANSFER
+**FiT TO FITC
+"AUG 02 CLEAR FEES
+SETT,09/02
+5,000 DUE 09/01/3
+/BS NET 09/16/0
+"FEDERAL HÖME LOAN MIG CORP
+SERIES 2471 CLASS YT
+.000 DUE 03/15/3
+&I TANF
+"ADP CD"
+DUE 12/31/2049
+8,6252 DUE 12/31/498,625
+FITM-PR_ F2613178011
+QUANTITY
+RATE (%)
+5.1760
+5.1760
+DEBIT AMOUNT
+25,000.00
+'50.00
+1,190,000.00
+$-1,215,050.00
+027
+DEBIT AMOUNT
+288,424.66
+$-288,424.66
+CRECIT AMOUNT
+2,954.17
+' 512695.31
+2,934.56
+$518,584.04
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 30, 2002
+248,105.30
+$873,161.55
+
+
+9 org
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Trades Executed Pending Settlement
+TRANSACTION
+10/15/02 09/04/02 BOUGHT
+FNMA-30YR(FNMA) GTD
+SETT, 10/02
+DUE 10/01/2032 06.000%
+REF #
+TOTAL
+The above trades do not appear in any other section of this statement
+BS
+STOP
+****** End of Statement******
+SYMBOLCUSIP
+QUANTITY
+25,000,000.00
+PRICE
+101.9375
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD August 31,2002
+THROUGH
+September 27, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 30, 2002
+DEBIT AMOUNT
+25,484,375.00
+$25,484,375.00
+027
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary.....
+Your Portfolio Holdings
+Transaction Detail ......
+........
+Trades Not Yet Settled
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 26, 2002
+3
+9
+Hollandlold
+FINANCIAL TRUST CO INC
+CIO JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD*
+LONG ACCRUED INTEREST
+NET CREDIT BALANCE
+3,122,857
+292,307
+116.153
+NET EQUITY THIS PERIOD
+$3,531,317
+•••••••••••••••••••
+NET EQUITY LAST STATEMENT
+241,409
+CHANGE SINCE LAST STATEMENT
+3,289,908
+*This portfolio indudes one or more unpriced securies that are not
+reflected in tho Total Value of Securties and the Not Equity This Pariod.
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$116,153
+$241,409
+Cash & Equivalent -
+Fixed
+Income
+$3,122,857
+Current market value
+Last statement's market value
+SP The surren s four or ratanal furyce rearde Set revere date for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 0r9
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Securities Bought
+Dividends/Interest Charged
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance,
+THIS PERIOD
+5241.409.36
+80,427.35
+110,150,262.74
+$110,230,690.09
+-15,313,595.08
+-294,051.45
+-94,748,300.00
+5-110.355.946.53
+-125,256.44
+....
+.5116.152.92
+Income Summary
+Govt. Agency Int.
+Credit Balance Int.
+Total
+Bond Purchase Int.
+THIS PERIOD
+80,379.17
+48.18
+.S80.427.35
+-294,051.45
+Portfolio Composition
+Cash/Cash Equivalent
+Fixed Income
+Total
+Cash Balance Summary
+OFENING
+241,409.36
+Margin
+Net Cash Balance
+$241,409.36
+CLOSING
+116,152.92
+....
+$116,152.92
+.......
+027
+YEAR TO DATE
+80,379.17
+48.18
+.....
+. $80.427-35
+-294,051.45
+116,153
+3,122,857
+•••••••••••••••••••
+$3,239,010
+......
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 26, 2002
+Your Portfolio
+Allocation
+Gash & Equivalent -
+- Fixed Income
+97%
+Unshaded portions denote debit balance and or shart
+
+
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+FIXED INCOME
+Government & Agency Obligations
+FEDERAL HOME LOAN MG CORP
+SERIES 2471 CLASS YT
+DATED DATE 06/07/02
+BOOK ENTRY ONLY
+DUE 03/15/2032 1,000%
+FACTOR - 1,00000000
+FEDERAL HOME LOAN MG CORP
+SERIES 2483 CL SL
+INTEREST FROM DATE 08/15/02
+DATED DATE 07/02/02
+BOOK ENTRY ONLY 15/2002
+FEDERAL HOME LOAN MIG CORP
+SERIES 2488 CLASS SQ
+INTEREST FROM DATE 08/15/02
+DATED DATE 07/08/02
+FIRST COUPON 09/15/2002
+BOOK ENTRY ONLY
+Total Government& Agency Obligations
+TOTAL FIXED INCOME
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SIMBOUCUSIP
+QUANTITY
+PRICE
+SYMBOLCUSIP
+MAGN
+OLANTITY
+95,814,693
+57,684,932
+MAGN
+50,000,000
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 26,2002
+NAWA NAME
+CURRE
+ELD I
+116,153
+$116,153
+PRICE
+3.2593
+Unpriced
+MARKET VALLE
+3,122,857
+OCRUE
+NTERE!
+39,926
+ESTIMATE
+NNUAL INCOM
+958,147
+CURRENT
+YELD (S)
+30.6817
+124,046
+2,977,119
+Unpriced
+128,335
+3,080,000
+$3,122,857
+$3,122,857
+027
+$292,307
+$292,307
+$7,015,266
+$7,015,266
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your Portfolio Holdings (continued)
+YOUR TOTAL ACCRUED INTEREST
+YOUR TOTAL ESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+INVESTMENT ACTIVITY
+SETTLEMENT TREE
+DATE
+TRANSACTION
+07/30/02 07/19/02
+
+JÖURNAL'
+08/12/02
+JOURNAL
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+PUE 08/1512032 00.001%
+AS OF 07/1802
+BS
+FEDERAL HOME LOAN MIG CORP
+ERIES 2471 CLASS Y
+1.001 DUE 03/5IR2
+REPO AGREEMENT
+A1
+FEDERAL" HOME LOAN MIG CORP
+SERIES 2471 CLASS YI
+1.000 DUE 03/5I32
+FiTMARGN
+A2
+TERM REPO AGREEMENT
+$292,307
+$7,015,266
+$3,239,009
+SYMBOLCUSP
+QUANTITY
+100,000,000
+ACCR. INT.
+PRICE
+3.46875
+20,000,000
+20,000,000*
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 26, 2002
+DEBIT AMOUNT
+3,468,750.00
+41,666.67
+
+
+Transaction Detail (continued)
+INVESTMENT ACTIVITY (continued)
+SATEMENT TREE
+08/12/02
+TRANSACTION
+JOURNAL
+68/1502****
+08/30/02 08/07/02"BOUGHT'
+08:30102
+08/02/02
+TOTAL
+INTEREST
+
+8/29/02
+AVG BAL 235,581RT 1.052
+021 OFFICE INTEREST 0702
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+RHERESTS RENT 0898902
+TOTAL
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471 CLASS YT
+10 031532 A1
+REPO AGREEMENT
+"FEDERAL" HOME LOAN MIG CORP
+SERIES 2471 CLASS VT
+1,000 DUE 03/15/32
+PRINCIPAL REDUCTN 08-29-02
+FEDERAL HOME LOAN MIG CORP
+SERIES 2483 CL SI
+WE 03/512032 05.1613
+REF #
+BS
+AS OF 08/07/02
+SEE 246 A MIC CORP
+PUE 084512032 06.160%
+BS
+IS OF 08/02/02
+SYMBOUCUSIP
+SYMBOLGUSP
+QUANTITY
+PRICE
+-3,545,000
+640,307
+''57,684,932
+- 9.53125
+ACCR. INT.
+50,000,000
+ACCR. INT.
+12.69350
+QUANTITY
+RATE (%)
+1.0000
+DEBIT AMOUNT
+027
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD July 27, 2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+July 26, 2002
+DEBIT AMOUNT
+CRECIT AMOUNT
+5,498,095.08
+124,051.45
+6,346,750.00
+128,333.33
+$-15,607,646.53
+CREDIT AMCUNT
+48.18
+.......
+30,379.17
+$80.427.35
+
+
+7 of g
+Transaction Detail (continued)
+MISCELLANEOUS
+DATE
+MO/DAY
+07/30/02
+TRANSACTION
+RECEIVED
+07730102 "DELIVERED"
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+07/30/02
+DELIVERED
+08/02/02
+
+08/08/02
+JOURNAL
+"RECEIVED
+08/08/02
+RECEIVED
+08/08/02
+- DELIVERED
+ADP CD
+DUE 12/31/2049
+8,625
+.625 DUE 12/314
+ITM-PR
+DUE 12/31/2049
+8,625
+.625 DUE 12814
+ITM-PR
+*ADP CD*
+DUE 12/31/2049
+8.525 DUE 2013149 8.625
+EITM-PR_
+FITM-PRINT ADJ
+JULY 2002CLEARING FEES
+"ABP CD"
+DUE 12/31/2049
+8.625 DUE 1241/498.625
+EITM-PR E193312801D
+DUE 12/31/2049
+8,625
+8.625 DUE 12/31/49
+EITM-PR
+"ABP CB
+DUE 12/31/2049
+8,625
+8.625 DUE 12/31/49
+FITM-PR I
+DEBIT AMOUNT
+21,168,000.00
+300.00
+21,168,000.00
+*27,506,000.00
+027
+CRECIT AMOUNT
+3,832.37
+24,769,345.91
+2,932.13
+- 7,567.56
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 26, 2002
+
+
+8 of 9
+Transaction Detail (continued)
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+08/08/02
+TRANSACTION
+DELIVERED
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+öB/08'02 BELIVERED"
+20/22/80
+20/1Z/80
+RECEIVED
+DELIVERED
+08/27/02 DELIVERED
+20/0E/B0
+RECEIVED
+08/30/02 DELIVERED
+ADP CD
+DUE 12/31/2049
+8,625
+.625 DUE 12/31/49
+ITM-PR
+"АБРСЬ"
+DUE 12/31/2049
+8,625
+.625 DUE 12814
+ITM-PR
+"ADP CD*
+DUE 12/31/2049
+8.525 DUE 2013149 8.625
+EITM-PR
+ABP CD
+DUE 12/31/2049
+8.625
+8.625 DUE 12/31/49
+FITM-PR
+"ADP CD
+DUE 12/31/2049
+8.625
+8.625 DUE 12/31/49
+FITM-PR I
+DUE 12/31/2049
+8,625 DUE 12131/49 8,625
+FITM-PR
+"ABP CD''''
+DUE 12/31/2049
+8.625
+8.625 DUE 12/31/49
+FITM-PR
+DEBIT AMOUNT
+21,506,000.00
+*9,400,000.00
+027
+21,168,000.00
+'21,168,000.00
+15,956.26
+
+2,62851
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 26, 2002
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+9 or g
+Transaction Detail (continued)
+MISCELLANEOUS (continued)
+DATE
+MODAY
+08/30/02
+TRANSACTION
+DELIVERED
+ADP CD
+DUE 12/31/2049
+8.625
+8.625 DUE 12181/49
+FITM-PRI
+TOTAL
+Trades Executed Pending Settlement
+BATLEMENT
+TRADE
+DATE
+TRANSACTION
+09/13/02
+07/19/02
+09/13/02
+07/19/02
+CANCEL BUY
+0916/02
+2 07/19/02
+2 BOUGHT
+FNMA-30YR(FNMA) GTD
+SETT.09/02
+DUE 09/01/2032 06.000%
+REF #1
+NMA- 30YRIFNMA) GTL
+SETT 09/02
+DUE 09/01/2032 06.000%
+REF #
+AS OF 07/19/02
+ENMA 30YR(FNMA) GTD
+SETT.09/02
+DUE 09/01/203206.000%
+REF #
+AS OF 07/19/02
+BS
+BS
+BS
+TOTAL
+The above trades do not appear in any other section of this statemene
+DEBIT AMOUNT
+$-94,748,300.00
+21,506,000.00
+$110,150,262.74
+SYMBOL/CUSIP
+QUANTITY
+25.000,000.00
+PRICE
+100.2968
+25,000,000.00
+100.2968
+25,000,000.00
+100.2968
+027
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIO July 27,2002
+THROUGH
+August 30, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 26, 2002
+DEBIT AMOUNT
+25,074,218.75
+25,074,218.75
+25,074218.75
+$50,148,437.50
+$25,074,218.75
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+VISIT OUR WEBSITE
+GNMA GOVT BOND
+www.bearstearns.com
+What's In This Statement
+Financial Summary.............................
+Your Portfolio Holdings
+Transaction Detail ................................
+Trades Not Yet Settled
+CLEARED THROUGH ITE
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+3
+3
+5
+Hollandlold
+FINANCIAL TRUST CO INC
+C/O JEFFREY EPSTEIN
+6100 RED HOOK QUARTER
+STE B3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+241,409
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$241.409
+241,409
+Cash & Equivalent -
+$241,409
+Current market value
+Last statement's market value
+This summary is for informational purposes only. It Is not intended as a tax documen
+set tement should be retained for your records. See revere side for important information
+07/27/02;16:57 001
+
+
+2 of 5
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+07/27/02;16:57 001
+
+
+3 of 5
+Cash Flow Analysis
+Opening Balance
+Miscellaneous
+Amount Credited
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance.
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+YOUR PRICED PORTFOLIOHOLDINGS
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERIOD
+......
+74,792,101.18
+.....
+$74,792,101.18
+-74,550,691.82
+$74.550.691.82
+241,409.36
+$241,409.36
+Cash Balance Summary
+OPENING
+Margin
+Net Cash Balance
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+CLOSING
+241,409.36
+$241,409.36
+......
+241,409
+$241,409
+SYMBOLCUSIP
+QUANTITY
+PRICE
+MARKET
+VALUE
+241.409
+$241,409
+ESTIMATED
+UNNUAL INCOM
+CURRENT
+YIELD (NI
+$241,409
+027
+07/27/02;16:57 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+from the absolute market value of your portfolio.
+
+
+4 of 5
+Transaction Detail
+MISCELLANEOUS
+DATE
+MO/DAY
+RANSACTIO
+07/12/02
+SURNA
+07/16/02
+JOURNAL'
+0772202 HEREVE
+07/22/02
+DELIVERED
+07/22/02
+DELIVERED
+07/26/02
+07/26/02 RECEIVED
+07/26/02
+07/26/02
+DELIVERED
+DELIVERED
+TOTAL
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+[021-5212
+A REO FROM JEPSTEI
+"FITM PR ADJAO 7712
+"AB'****/•••••••••••••
+DUE 12/31/2049
+8,625
+8,625 DUE 12131/49
+FITM-PR
+ADP CD
+DUE 12/31/2049
+8.625 DUE 22131498,625
+EITM-PR
+DUE 12/31/2049
+8,625
+8.625 DUE 12131/49
+FITM-PR
+*PREM A/O 7/25
+"ADP CD"
+DUE 12/31/2049
+8.625
+8.625 DUF 12/31/49
+FITM-PR
+"ADP CD
+DUE 12/31/2049
+8.625 DUE 12131498,625
+FITM-PRI
+ADP CD
+DUE 12/31/2049
+8,625 DU: 2213149 8,625
+FITM-PR
+DEBIT AMOUNT
+25,000,000.00
+24,778,567.78°
+25,000,000.00
+9,777.78
+25,000,000.00
+2,778.13
+"24,769,345.91
+577.49
+24,781,345.91
+$-74,550,691.82
+$74,792,101.18
+027
+07127102;16:57 001
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+FINANCIAL TRUST CO INC
+STATEMENT PERIOD June 29,2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+
+
+5 or 5
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Trades Executed Pending Settlement
+TRANSACTION
+07/30/02 07/19/02
+BOUGhT
+09/13/02
+07/19/02
+09/13/02
+07/19/02
+"CANCEL BUY
+09/16/02 07/19/02 BOUGHT
+TOTAL
+SETT.09/02
+SETT,09/02
+The above trades do not appear in any ather section of this statement
+FEDERAL HOME LOAN MIG CORP
+SERIES 2471CLASS VT
+STOP
+****** End of Statement******
+SYMBOLCUSP
+QUANTITY
+100,000,000.00
+25,000,000.00
+25,000,000.00
+25,000,000.00
+PRICE
+3.4687
+100.2968
+100.2968
+100.2968
+027
+07/27/02;16:57 001
+CLEARED THROUGH ITS
+WHOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+FINANCIAL TRUST COINC
+STATEMENT PERIOD June 29, 2002
+THROUGH
+July 26, 2002
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+DEBIT AMOUNT
+3,510,416.67
+25,074,218.75
+25,074,218.75
+25,074,218.75
+$53,658,854.17
+$25,074,218.75
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/ff7fa9bd54af62f2187fdb596cec08a3cf23b2dbd31ab5e851b944e764b2cf14.receipt.json b/vision-fixhub/ds9-unparsed-05/ff7fa9bd54af62f2187fdb596cec08a3cf23b2dbd31ab5e851b944e764b2cf14.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..cc57dd38b90a815450e60d0b69ccbe603f0e2170
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ff7fa9bd54af62f2187fdb596cec08a3cf23b2dbd31ab5e851b944e764b2cf14.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -6971,
+  "dataset": "marble-joined",
+  "doc_id": "ff7fa9bd54af62f2187fdb596cec08a3cf23b2dbd31ab5e851b944e764b2cf14",
+  "engine": "marble-apple-vision",
+  "event_count": 66,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "fb4814f0eca5d49f3144e0df4e1bac72dc53b028ed03e0fc22796011bc3e590b",
+  "output_sha256": "8c01ce89175a2bd95db7814e8559fe23d7de31cf54aac4a161cf113974bacd0f",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ff9456435f63d6031b80caf268c9f52f99261a5060ce94eac3518e6c85348618.md b/vision-fixhub/ds9-unparsed-05/ff9456435f63d6031b80caf268c9f52f99261a5060ce94eac3518e6c85348618.md
new file mode 100644
index 0000000000000000000000000000000000000000..d4a587473c4f08e202b0004f75f2b81f88a7feb4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ff9456435f63d6031b80caf268c9f52f99261a5060ce94eac3518e6c85348618.md
@@ -0,0 +1,357 @@
+Statements
+
+
+OFFICE SERVICING YOUR ACOOUNT
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+What's In This Statement
+Financial Summary .............................
+Transaction Detail
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 26, 2001
+3
+INSTITUTIONAL INTERESTS
+BD/AC
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+2,823
+-2,823
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent - 80,
+$2.823
+Last statement's market value
+This summary is for informational purposes only. It is not intended as a tax document
+Ce tatement should be retained for our records See revere side for important information.
+
+
+2 of 4
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+027
+
+
+3 of 4
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Miscellaneous
+Amount Debited
+Net Cash Activity
+Closing Balance.
+Transaction Detail
+INTEREST
+DATE
+DESCRIPTION
+02/21/01
+INT CR
+TOTAL
+FEB 01
+MISCELLANEOUS
+DATE
+MO/DAY
+02/15/01
+TRANSACTION
+JOURNAL
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+THIS PERIOD
+52,823.35
+10.24
+....
+$10.24
+-2,833.59
+$2883.59
+-2,823.35
+$0.00
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+2,823.35
+$2,823.35
+Income Summary
+Credit Balance Int.
+Total
+THIS PERIOD
+10.24
+510.24
+CLOSING
+0.00
+$0.00
+-....
+YEAR TO DATE
+24.04
+_$24.04
+SYMBOUCUSIP
+QUANTITY
+RATE (%)
+DEBIT AMOUNT
+DESCRIPTION
+TO:
+* JAL
+DEBIT AMOUNT
+2,823.35
+CREDIT AMOUNT
+027
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 26, 2001
+CREDIT AMOUNT
+10.24
+$10.24
+
+
+4 of 4
+OFFICE SERVICING YOUR ACOUNT
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York. New York 10167
+Transaction Detail (continued)
+MISCELLANEOUS (continued)
+DATE
+MO/DAY
+02/21/01
+TOTAL
+TRANSACTION
+JOURNAL
+DESCRIPTION
+TO:
+• JAL
+DEBIT AMOUNT
+10.24
+$-2,833.59
+STOP
+****** End of Statement******
+LEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD January 27, 2001
+THROUGH
+February 23, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+January 26, 2001
+CRECIT AMOUNT
+027
+
+
+OFFICE SERVICING YOUR ACOOUNT
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York. New York 10167
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD December 30, 2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 29, 2000
+What's In This Statement
+Financial Summary....................
+Your Portfolio Holdings
+Transaction Detail
+4
+INSTITUTIONAL INTERESTS
+BD/AC
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANIE BRENNAN
+6100 RED HOOK QUARTER STE B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+NET CREDIT BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+2,823
+$2,823
+.. . ..
+2,810
+14
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+Cash & Equivalent
+$2,823
+$2,810
+Current market value
+Last statement's market value
+This summary is for informational purposes only. It Is not intended as a tax documen
+peis statement should be retained for your records. See reverue side for imortant information
+
+
+2 of 4
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+CLEARED THROUGH IT:
+WHOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+027
+
+
+3 of 4
+Cash Flow Analysis
+Opening Balance
+Dividends/Interest
+Amount Credited
+Net Cash Activity
+Closing Balance.
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Stearns & Co. Inc.
+245 Park Avenue
+New York, New York 10167
+THIS PERIOD
+52,809.55
+13.80
+$13.80
+13.80
+2.823.35
+Income Summary
+THIS PERIOD
+Credit Balance Int.
+13.80
+Total
+$13.80
+Portfolio Composition
+Cash/Cash Equivalent
+Total
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+2,809.55
+$2,809.55
+CLOSING
+2,823.35
+....
+$2,823.35
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DESCRIPTION
+CASH BALANCE
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSP
+QUANTITY
+PRICE
+VALUE
+2.823
+$2,823
+YEAR TO DATE
+13.80
+- ....
+.. $13.80
+2,823
+$2,823
+ESTIMATED
+ANNUAL INCOM
+027
+CLEARED THROUGH IT
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD December 30, 2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 29, 2000
+Your Portfolio
+Allocation
+Cash & Equivalent -
+100%
+Unshaded portions denole debt balance and'or short
+market values. The allocation percentage is derived
+from the absolute market value of your portfolio.
+
+
+4 of 4
+OFFICE SERVICING YOUR ACCOUNT
+Bear, Steams & Co. Inc
+245 Park Avenue
+New York, New York 10167
+Your Portfolio Holdings (continued)
+YOUR PRICEDPORTFOLIOHOLDINGS
+Transaction Detail
+INTEREST
+DATE
+DESCRIPTION
+01/22/01
+INT CR
+TOTAL
+SYMBOUCUSIP
+JAN 01
+STOP
+****** End of Statement******
+QUANTITY
+$2,823
+RATE (%)
+CLEARED THROUGH ITE
+"HOLLY OWNED SUBSIDIARY
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+INSTITUTIONAL INTERESTS
+STATEMENT PERIOD December 30, 2000
+THROUGH
+January 26, 2001
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+LAST STATEMENT
+December 29, 2000
+DEBIT AMOUNT
+CREDIT AMOUNT
+13.80
+$13.80
+027
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/ff9456435f63d6031b80caf268c9f52f99261a5060ce94eac3518e6c85348618.receipt.json b/vision-fixhub/ds9-unparsed-05/ff9456435f63d6031b80caf268c9f52f99261a5060ce94eac3518e6c85348618.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..77e0a2355788891cb47d74d59923123a7be23287
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ff9456435f63d6031b80caf268c9f52f99261a5060ce94eac3518e6c85348618.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -339,
+  "dataset": "marble-joined",
+  "doc_id": "ff9456435f63d6031b80caf268c9f52f99261a5060ce94eac3518e6c85348618",
+  "engine": "marble-apple-vision",
+  "event_count": 10,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "0c118160f4713e32a9fba32c8ee825cb0da88aa6e918d01c9fc7308e60cf9605",
+  "output_sha256": "824ad09b1c251e67cb35b6edd9cd1f866539a8bb76c4c1eaea3a7949e4d1e7d6",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-05/ffa7a4747c7de9178d63681b31bcf5be81325d734bce7966df91d180c89fe7bb.md b/vision-fixhub/ds9-unparsed-05/ffa7a4747c7de9178d63681b31bcf5be81325d734bce7966df91d180c89fe7bb.md
new file mode 100644
index 0000000000000000000000000000000000000000..7801ada75a1ac9fec160ff5bc05cc6c4534143de
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ffa7a4747c7de9178d63681b31bcf5be81325d734bce7966df91d180c89fe7bb.md
@@ -0,0 +1,167 @@
+Cc:
+Subject:
+Thursday, May 29, 2008 9:29 AM
+RE: Epstein
+No telling how long the DAG's office will take to decide. Tuesday is off.
+----Original Message-..
+Sem: Thursday, May 29, 2008 9-03 AM
+Cc:
+Subject: Epstein
+Hi
+I received
+le-mail stating that the DAG agreed to meet with epstein's people. Does this mean that Tuesday is
+off? 1 need to let the gi coordinator know.
+Also, I am sure that you remember
+• She was the person whom we initially classified as a victim until epstein's attorneys
+complained. Well, |
+has just interviewed a girl who was 14 or 15 when she first went to epstein's house who reports that epstein
+told her that he had sex with
+probably would have been 15 or 16 when this conversation occurred.) The girl also reports
+that she told epstein her true age and epstein told her that he doesn't care about age.
+I know that epstein's people will, no doubt, continue to tell the dag and others that epstein didn't know about the girls' ages so I
+thought you should know.
+Please let me know about tuesday so I don't needlessly spoil
+when he was in town?
+sunday. And, any chance the case was discussed with the ag
+Thanks.
+52
+P-014936
+
+
+Subject:
+Thursday, May 29, 2008 12:19 PM
+RE: Epstein
+The NY agents made contact with
+today. She met them at the door with her attorney's card. (she is connected to a target in
+another FBI investigation) I'II explain later. Anyway, she contacted the agent a few minutes ago and sounded surprised when she was
+informed it was about Epstein. She switched the conversation immediately about coming to Grand Jury on Tues. The agent left the
+ntervie her prior to putting her in the Gu. hat do You think i told the her agent down here and dr
+and I attempt to
+nterview her prior to putting her in the GJ. What de
+should reach out to her again to
+provide her with my name and information as her contact once she gets down here. I do not know if she plans on getting her attorney
+involved or not. His info is as follows: Diarmuid White of White and White, 148 E. 78th Street, NY NY 10075, telephone number
+I have a feeling she will reach out to Epstein, so it could get interesting. We have to schedule time for her in front of
+GJ. Let me know.
+Sent: Thursday, May 29, 2008 9:03 AM
+Cc:.
+Subject: Epstein
+Hi
+I received
+e-mail stating that the DAG agreed to meet with epstein's people. Does this mean that Tuesday is
+off? I need to let the gi coordinator know.
+Also, 1 am sure that you remember
+She was the person whom we initially classified as a victim until epstein's attorneys
+complained. Well,
+has just interviewed a girl who was 14 or 15 when she first went to epstein's house who reports that epsteir
+told her that he had sex with
+probably would have been 15 or 16 when this conversation occurred.) The girl also reports
+that she told epstein her true age and epstein told her that he doesn't care about age.
+I know that epstein's people will, no doubt, continue to tell the dag and others that epstein didn't know about the girls' ages so I
+thought you should know.
+Please let me know about tuesday so I don't needlessly spoil
+when he was in town?
+sunday. And, any chance the case was discussed with the ag
+Thanks.
+P-014937
+
+
+Subject:
+Thursday, May 29, 2008 3:24 PM
+Re: Epstein
+Hi
+• Very intereting. Is she coming down on her own dime? If she wants us to pay we have to set up the travel. Can you figure
+that out and if she is showing up this tuesday call
+to reserve grand jury time. Ask to put us last in case she is willing to
+do an interview and them we will not bring her to gj. We may want to video her. Since we aren't indicting on tuesday let's meet
+monday afternoon to go over everything. Thanks.
+---- Original Message -----
+Sent: Thu May 29 12:18:50 2008
+Subject: RE: Epstein
+The NY agents made contact with
+today. She met them at the door with her attorney's card. (she is connected to a target in
+another FBI investigation) TIl explain later. Anyway, she contacted the agent a few minutes ago and sounded surprised when she was
+informed it was about Epstein. She switched the conversation immediately about coming to Grand Jury on Tues. The agent left the
+door open to contact her if she decides to talk to her. I think we should let her travel down here and let
+and I attempt to
+interview her prior to putting her in the GJ. What do you think? I told the NY agent if
+should reach out to her again to
+provide her with my name and information as her contact once she gets down here. I do not know if she plans on getting her attorney
+involved or not. His info is as follows: Diarmuid White of White and White, 148 E. 78th Street, NY NY 10075, telephone number
+I have a feeling she will reach out to Epstein, so it could get interesting. We have to schedule time for her in front of
+GJ. Let me know.
+Cc:
+Subject: Epstein
+Sent: Thursday, May 29, 2008 9:03 AM
+Hi J
+. I received e-mail stating that the DAG agreed to meet with epstein's people. Does this mean that Tuesday is
+off? I need to let the gj coordinator know.
+Also, I am sure that you remember
+i. She was the person whom we initially classified as a victim until epstein's attorneys
+complained. Well,
+has just interviewed a girl who was 14 or 15 when she first went to epstein's house who reports that epstein
+told her that he had sex with
+probably would have been 15 or 16 when this conversation occurred.) The girl also reports
+that she told epstein her true age and epstein told her that he doesn't care about age
+I know that epstein's people will, no doubt, continue to tell the dag and others that epstein didn't know about the girls' ages so I
+thought you should know.
+Please let me know about tuesday so I don't needlessly spoil
+when he was in town?
+sunday. And, any chance the case was discussed with the ag
+Thanks.
+54
+P-014938
+
+
+Subject:
+Friday, May 30, 2008 2:53 PM
+RE: Epstein
+attorney, Brendan White. He informed me that he is representing
+and that she would not be able to
+make the June 3rd date and that she will invoke her 5th amendment right unless she is granted immunity. I informed him that
+was considered a victim/witness but he said that she would still invoke w/o immunity. SOUNDS like he has been well
+informed. Anyway Mr. White advised he had left you a message so I told him I would let the two of you work out the details. We can
+meet Monday afternoon and I will fill you in on the rest. I'll let !
+]know we are off for Tuesday. Have a
+great weekend.
+Sent: Thursday, May 29, 2008 3:24 PM
+To: H
+Subject: Re: Epstein
+Very intereting. Is she coming down on her own dime? If she wants us to pay we have to set up the travel. Can you figure
+that out and if she is showing up this tuesday call H
+• to reserve grand jury time. Ask to put us last in case she is willing to
+do an interview and them we will not bring her to gj. We may want to video her. Since we aren't indicting on tuesday let's meet
+monday afternoon to go over everything. Thanks.
+•---- Original Message -...
+Fron
+Sent: Thu May 29 12:18:50 2008
+Subject: RE: Epstein
+The NY agents made contact with
+today. She met them at the door with her attorney's card. (she is connected to a target in
+another FBI investigation) T'Il explain later. Anyway, she contacted the agent a few minutes ago and sounded surprised when she was
+informed it was about Epstein. She switched the conversation immediately about coming to Grand Jury on Tues. The agent left the
+Cc:
+Subject: Epstein
+Sent: Thursday, May 29, 2008 9:03 AM
+Hi
+I received
+off? I need to let the gi coordinator know.
+tor mail stating that th-80736-C-M A Kih epstein's people. Does this mean that Tuesday: 014939
+55
+
+
+Also, I am sure that you remember
+m. She was the person whom we initially classified as a victim until epstein's attorneys
+complained. Well,
+has just interviewed a girl who was 14 or 15 when she first went to epstein's house who reports that epstein
+told her that he had sex with
+I probably would have been 15 or 16 when this conversation occurred.) The girl also reports
+that she told epstein her true age and epstein told her that he doesn't care about age.
+I know that epstein's people will, no doubt, continue to tell the dag and others that epstein didn't know about the girls' ages so I
+thought you should know.
+Please let me know about tuesday so I don't needlessly spoil
+when he was in town?
+sunday. And, any chance the case was discussed with the ag
+Thanks.
+56
+P-014940
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-05/ffa7a4747c7de9178d63681b31bcf5be81325d734bce7966df91d180c89fe7bb.receipt.json b/vision-fixhub/ds9-unparsed-05/ffa7a4747c7de9178d63681b31bcf5be81325d734bce7966df91d180c89fe7bb.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..19e6726d4233d6ee224bc6a6030886046d09acaf
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-05/ffa7a4747c7de9178d63681b31bcf5be81325d734bce7966df91d180c89fe7bb.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -251,
+  "dataset": "marble-joined",
+  "doc_id": "ffa7a4747c7de9178d63681b31bcf5be81325d734bce7966df91d180c89fe7bb",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "ec6821c6f05167449d360e2f5460bf9c523812bca930ca5f97078ca33fb3c691",
+  "output_sha256": "32b458e2aaf55ed7798cb927c235782083cc65ddc7801659623871bfeb18798c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0016dbcbe61b36bf1e99fc934def8d3ec7a80fe0f768df9c0f086ebca8bee926.md b/vision-fixhub/ds9-unparsed-06/0016dbcbe61b36bf1e99fc934def8d3ec7a80fe0f768df9c0f086ebca8bee926.md
new file mode 100644
index 0000000000000000000000000000000000000000..b67c788bd141294b712c43da6953b0cbcaee291c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0016dbcbe61b36bf1e99fc934def8d3ec7a80fe0f768df9c0f086ebca8bee926.md
@@ -0,0 +1,29 @@
+Subject: RE: Question re Preservation of Electronically Stored Information re Epstein/Jane Does
+Date: Thu, 06 Jan 2011 14:36:20 +0000
+Importance: Normal
+Other people involved on the Lit. Hold you mean ?
+Subject: RE: Question re Preservation of Electronically Stored Information re Epstein/Jane Does
+Great. Do you have copies of other people's emails, too?
+SubjectaRE quesdon te Preservadon or blectronically Strea Imoradon te EpstelnJane Does
+Ann Marie:
+Damaris will be contacting you. We made copies of the documents on your N and PST. That will be what
+you need to review, not the originals.
+_S)
+Subject: RE: Question re Preservation of Electronically Stored Information re Epstein/Jane Does
+Thanks for your caution with this.
+Please have IT do this. They can capture the information. As a Lit Hold is already in place, I would suggest
+contacting J|
+las perhaps the information has already been captured. I am copying
+email so that she or another IT person can assist you.
+on this
+
+
+Subject: Question re Preservation of Electronically Stored Information re Epstein/Jane Does
+Good evening, everyone. The Justice Department has made an inquiry of
+that he has passed along to me,
+to review our records and gather some information for them to review. This is going to require me to search and
+retrieve emails and electronic documents (Word Perfect documents) to give to l
+so that he can send them
+to Washington. Obviously I will not be altering the documents or emails in any way, but I know that just
+opening the documents can change the data. Is there a way for me to do this safely?
+Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/0016dbcbe61b36bf1e99fc934def8d3ec7a80fe0f768df9c0f086ebca8bee926.receipt.json b/vision-fixhub/ds9-unparsed-06/0016dbcbe61b36bf1e99fc934def8d3ec7a80fe0f768df9c0f086ebca8bee926.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..88e9e5226445b4424b659fea5ba0e772ecf70b63
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0016dbcbe61b36bf1e99fc934def8d3ec7a80fe0f768df9c0f086ebca8bee926.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "0016dbcbe61b36bf1e99fc934def8d3ec7a80fe0f768df9c0f086ebca8bee926",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "b0d2d3fa5c4af48e31c10d97a4cf3281f3059d95be5610fea9f1d24a5c00ef79",
+  "output_sha256": "76733692672c6c32bc347a2fecfe3946df3fbe2494a73875c877d6aaef594cf5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/002d0424022d96f0dec8a6719ff8c78b3f2749b9d965a2ba094d8c567389f92a.md b/vision-fixhub/ds9-unparsed-06/002d0424022d96f0dec8a6719ff8c78b3f2749b9d965a2ba094d8c567389f92a.md
new file mode 100644
index 0000000000000000000000000000000000000000..472127317e0b3a96ace651f91580e30e44ae2971
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/002d0424022d96f0dec8a6719ff8c78b3f2749b9d965a2ba094d8c567389f92a.md
@@ -0,0 +1,45 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE No. 08-80736-CIV-MARRA/JOHNSON
+JANE DOE 1 and JANE DOE 2,
+Plaintiffs,
+I.
+UNITED STATES OF AMERICA,
+Defendant.
+/
+UNOPPOSED MOTION OF PROPOSED INTERVENORS FOR A
+ONE-WEEK ExTENSION OF TIME To FILE ADDITIONAL BRIEFING
+Following the hearing on August 12, 2011, the Court gave proposed intervenors Black,
+Weinberg, and Lefkowitz until Friday, August 26 to file supplemental briefing on the issues raised
+concerning plea negotiations with Jeffrey Epstein. Also following the hearing, the decision was
+made for Mr. Epstein to file a motion seeking limited intervention so that there are no procedural
+issues regarding whether the protections and policies relating to Federal Rules of Evidence 410 and
+408 should be fully considered by the Court in determining whether to grant or deny the plaintiffs'
+discovery requests for plea negotiation correspondence between Mr. Epstein's lawyers and the U.S.
+Attorney's Office. We intended to file Mr. Epstein's motion to intervene by the Court's deadline
+of August 26, 2011.
+We now anticipate that our office will be closed all day Thursday due to Hurricane Irene, and
+our office may be closed part of the day Wednesday as well. We won't know until after Irene arrives
+whether our office will be closed on Friday as well. With these time limitations, we will not be able
+to file our papers as well as Mr. Epstein's motion to intervene and supporting memorandum by the
+
+
+present deadline of August 26. We have spoke with counsel for Jane Doe 1 and Jane Doe 2 as well
+as counsel for the government, and all have stated that they do not object to the extension of time
+requested here.
+Accordingly, we respectfully request an extension of time until Friday, September 2, 2011,
+to file the supplemental briefing of proposed intervenors Black, Weinberg & Lefkowitz, and to file
+a motion for limited intervention to assert rights under Rules of Evidence 408 and 410.
+We certify that on August 22, 2011, the foregoing document was filed electronically with the
+Clerk of the Court using the CM/ECF system.
+Respectfully submitted,
+BLACK, SREBNICK, KORNSPAN
+& STUMPE PA
+Miami, Florida 33131
+By.
+/S/
+ROY BLACK, ESO.
+Florida Bar Nol
+JACKIE PERCZEK, ESQ.
+Florida Bar No.
+2
diff --git a/vision-fixhub/ds9-unparsed-06/002d0424022d96f0dec8a6719ff8c78b3f2749b9d965a2ba094d8c567389f92a.receipt.json b/vision-fixhub/ds9-unparsed-06/002d0424022d96f0dec8a6719ff8c78b3f2749b9d965a2ba094d8c567389f92a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..8e338ed9f6f218a98cee4c738de4f36d38d0b403
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/002d0424022d96f0dec8a6719ff8c78b3f2749b9d965a2ba094d8c567389f92a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "002d0424022d96f0dec8a6719ff8c78b3f2749b9d965a2ba094d8c567389f92a",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "9a727e01a98d9bd3d6429f386fab912d1053e7c2572bf8fd0460afa97b79b268",
+  "output_sha256": "cf1900bc6bde69eab3c3dd974d79ca02ef8ce9f06472320caa82afdc77c52074",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0037e447651d9c7d2cd0ba44b547c5a06b806366042c853106f12720c4b7fc04.md b/vision-fixhub/ds9-unparsed-06/0037e447651d9c7d2cd0ba44b547c5a06b806366042c853106f12720c4b7fc04.md
new file mode 100644
index 0000000000000000000000000000000000000000..07937be9a403455e5a25624e847acbaff3f1f31f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0037e447651d9c7d2cd0ba44b547c5a06b806366042c853106f12720c4b7fc04.md
@@ -0,0 +1,161 @@
+Calls to Destination SB
+
+08/17/2006
+From: 01/01/2006 12:00 AM
+To:
+08/01/2006 11:59 PM
+Number Called:
+MobileId
+× cingular®
+Call Date
+Call Time
+HR: MN: SC
+Call Duration
+HR: MN: SC
+1
+2
+3
+4
+5
+6
+*
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000)000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+07/24/2006
+07/24/2006
+07/24/2006
+07/25/2006
+07/25/2006
+07/25/2006
+07/26/2006
+07/26/2006
+07/27/2006
+07/27/2006
+07/31/2006
+07/31/2006
+07/31/2006
+08/01/2006
+08/01/2006
+08/01/2006
+08/01/2006
+08/01/2006
+08/01/2006
+09:51:47 AM
+09:54:40 AM
+12:27:17 PM
+09:51:52 AM
+12:04:34 PM
+12:06:51 PM
+12:44:02 PM
+01:15:39 PM
+08:45:42 AM
+11:49:50 AM
+09:22:36 AM
+12:05:31 PM
+03:50:41 PM
+08:23:18 AM
+09:00:24 AM
+09:12:09 AM
+09:23:23 AM
+09:28:35 AM
+09:33:31 AM
+00:00:58
+00:00:18
+00:00:22
+00:00:19
+00:00:14
+00:00:38
+00:00:32
+00:00:19
+00:01:16
+00:00:47
+00:00:32
+00:00:54
+00:00:14
+00:00:09
+00:00:28
+00:00:07
+00:01:01
+00:00:10
+00:00:35
+* - indicates the first time the calling number appears on the report
+All "Calls to Destination" and "subscriber Activity" reports are recorded In Local switch Time.
+This data provided may be in pre-bill format. Due to possible data losses it is not necessarily a complete record of all calls, and is not the
+oda a Corplete secord of a11 calls, and ia not the
+same as an invoice received by a subscriber.
+JJ
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless and its Affiliates
+except under written agreement.
+Page
+1
+
+
+Calls to Destination SB
+
+08/17/2006
+* cingular®
+Mobileld
+Call Date
+Call Time
+HR : MN: SC
+Call Duration
+HR: MN: SC
+20
+21
+22
+23
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000)000-0000
+08/01/2006
+08/01/2006
+08/01/2006
+08/01/2006
+10:09:50 AM
+10:30:29 AM
+01:23:14 PM
+02:04:25 PM
+00:00:16
+00: 00:01
+00:00:16
+00:00:24
+JJ
+* - indicates the first time the calling number appears on the report
+All "Calls to Destination" and "subscriber Activity" reports are recorded in Local Switch Time
+his data provided may be in pre-bill format. Due to possible data losses it 1s not necessarily a complete record of all calls, and 1s not thi
+same as an Invoice received by a subscriber.
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless and its Affiliates
+except under written agreement.
+Page 2
diff --git a/vision-fixhub/ds9-unparsed-06/0037e447651d9c7d2cd0ba44b547c5a06b806366042c853106f12720c4b7fc04.receipt.json b/vision-fixhub/ds9-unparsed-06/0037e447651d9c7d2cd0ba44b547c5a06b806366042c853106f12720c4b7fc04.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6a04f86e9d976241a5b9818c11a57aeaae46c898
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0037e447651d9c7d2cd0ba44b547c5a06b806366042c853106f12720c4b7fc04.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "0037e447651d9c7d2cd0ba44b547c5a06b806366042c853106f12720c4b7fc04",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "c861636b92bbee5c58814f86f9a3a99187b1837dd285215619dcd192d78d6814",
+  "output_sha256": "bc57b0963ef3a9c9aaaf622482a4b919fc38331cbb2888cf73159d1782a44f9e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/008b7497d16a26c12dc973286f9cc8c8a425573e26463da65f635647bad1b1e4.md b/vision-fixhub/ds9-unparsed-06/008b7497d16a26c12dc973286f9cc8c8a425573e26463da65f635647bad1b1e4.md
new file mode 100644
index 0000000000000000000000000000000000000000..7edab5d95dc1c14753b4562393019b40e8fde00d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/008b7497d16a26c12dc973286f9cc8c8a425573e26463da65f635647bad1b1e4.md
@@ -0,0 +1,219 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOE #1 and JANE DOE #2
+1.
+UNITED STATES
+JANE DOE #1 AND JANE DOE #2'S RESPONSE TO MOTION TO INTERVENE OF
+COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and
+through undersigned counsel, to oppose the motion of attorney
+to permissively
+intervene in this case under Fed. R. Civ. P. 24(b)(1)(b) (doc. #79).
+The motion to intervene should be denied.
+Ippears to be merely the cat's paw
+of a possible real party in interest - Jeffrey Epstein. It is of no concern to
+whether or
+not this Court rules that the Government violated Jane Doe #1 and Jane Doe #2's rights under the
+Crime Victims' Rights Act. Thus
+has not established that he has some kind of
+"common question of law or fact" sufficient to support his permissive intervention into this case.
+Accordingly, as with the similar motion for Epstein's defense attorneys, his motion to intervene
+in this Crime Victims' Rights Act case is without merit and should be denied. Alternatively, if
+the Court elects to permit
+to permissively intervene, legal counsel for Jane Doe #1 and
+Jane Doe #2 should be allowed to, first, depose
+about his involvement in the Epstein
+criminal investigation and, second, respond to his baseless motion for Rule 11 sanctions.
+1
+
+
+I.
+DISCUSSION
+I DOES NOT HAVE A CLAIM OR DEFENSE THAT SHARES
+SOMETHING IN COMMON WITH THIS CRIME VICTIMS RIGHTS
+ACT ENFORCEMENT ACTION.
+claims that the Court should grant him permissive intervention under Fed. R.
+Civ. P. 24(b). The rule grants discretion to the court to allow intervention by a person who has
+"a claim or defense that shares with the main action a common question of law or fact." Fed. R.
+Civ. P. 24(b); accord Mt. Hawley Ins. Co. I. Sandy Lake Properties, Inc., 425 F.3d 1308, 1311
+(11th Cir. 2005) (intervention allowed only where "a claim or defense and the main action have a
+question of law or fact in common and the intervention will not unduly prejudice or delay the
+adjudication of the rights of the original parties."). A district court's ruling on such intervention
+is reviewed only for abuse of discretion. Stone |. First Union Corp., 371 F.3d 1305 (11th Cir.
+2004) see also AT&T Corp. | Sprint Corp., 407 F.3d 560, 561-62 (2nd Cir. 2005) ("[a] denial of
+permissive intervention has virtually never been reversed" because of the considerable discretion
+afforded to district courts).
+claims he has an interest in this Crime Victims Rights Act case sufficient to
+support permissive intervention. Curiously,
+is not the first person to try and intervene
+in the victims' case. As the Court is aware, three defense attorneys have also filed a separate
+motion to intervene (doc. #56). All these putative intervenors have one thing in common: they
+have all defended Jeffrey Epstein or his associates in the sexual abuse litigation brought by girls
+Epstein sexually abused. This sudden appearance of so many intervenors aligned with Epstein -
+but not of Jeffrey Epstein himself - strongly suggests that
+and others are being used as
+2
+
+
+Epstein's cat's paw in an attempt to undercut the vietims CVRA lawsuit without Epstein himself
+becoming involved.
+Such litigation-by-surrogate is improper. While Epstein arguably has an interest in the
+CVRA case (because the victims are seeking to invalidate his non-prosecution agreement), a
+civil defense attorney who has represented Epstein employees simply does not. The "claim and
+defense" of this CVRA action is the victims' claim that the government violated their CVRA
+rights and the government's defense that it did not.
+has no interest in how that dispute
+is resolved. Any findings that the Court makes in the course of resolving the victims' CVRA
+action are not binding on
+and he has not documented that he is suffering any tangible
+harm from them.
+In considering whether to allow intervention, a district court can also consider whether
+adequate representation exists on any issues and whether a putative intervenor will significantly
+contribute to the litigation.
+Department of Fair Employment and Housing | Lucent
+Technologies, Inc., 2011 WL 1549232, at *6 (9th Cir. 2011) (citing Spangler I. Pasadena City
+Bd. of Educ., 552 F.2d 1326(9th Cir.1977). Here, there is no indication that the Justice
+Department will do anything other than vigorously defend the non-prosecution agreement that it
+negotiated. The Court need not allow another third-party to try undercut the victims as well.
+attempts to manufacture an interest by alleging that he is entitled to intervene to
+contest two factual allegations made by the victims that relate to him and seek Rule 11 sanctions
+for the allegations. But as a non-party, he lacks standing to bootstrap his way into this case via a
+Rule 11 motion. As the Second Circuit has explained:
+3
+
+
+Although the language of Rule 11 does not address the issue of who may move
+for sanctions, the language used in the Advisory Committee Notes indicates that it
+is the parties who should move for sanctions. The Advisory Committee Notes
+accompanying the 1983 amendments require that "[a] party seeking sanctions
+hould give notice to the court and the offending party" and make explicit the
+court's authority to impose sanctions on its own motion "in order to overcome the
+traditional reluctance of courts to intervene unless requested by one of the
+parties." Notes of Advisory Committee on Rules-1983 Amendment (emphasis
+added).
+New York News, Inc. |. Kheel, 972 F.2d 482, 488 (2d Cir. 1992). If _
+motion is allowed
+to succeed, then legions of bystanders will have the ability to intervene in lawsuits through the
+simple device of claiming an interest in filing a Rule 11 sanctions motion. Thus, the Second
+Circuit has explained that "we fear that permitting a non-party to move for Rule 11 sanctions
+might fulfill crities" concerns that the rule will create unwieldy " 'satellite litigation"" that will
+frustrate the rule's goal of 'more effective operation of the pleading regimen.'" Id. (citing 5A
+Wright & Miller, Federal Practice and Procedure § 1332, at 29 (1990)).
+motion is also untimely. On March 20, 2011, the victims filed their motion for
+summary judgment - the pleading to which
+objects. The government responded on
+April 7, 2011, and the victims' replied on May 2, 2011. After all the briefing was completed on
+the victims' summary judgment motion, the next day - May 3, 2011
+filed his motion
+to intervene. This timing strongly suggests that
+deliberately waited to file his motion
+until briefing on the motion was fully completed. Rule 24(b) requires a "timely" motion for
+intervention. And it further requires the Court to consider whether the parties will be prejudiced
+by intervention.
+late motion is simply not timely and will prejudice the victims by
+requiring them to brief ancillary issues.
+4
+
+
+deny
+For all these reasons, the Court should exercise its abundant discretion in this area and
+motion to permissively intervene.
+II.
+IN THE ALTERNATIVE, IF
+MOTION TO INTERVENE IS
+GRANTED, THE COURT SHOULD ALLOW THE VICTIMS TO DEPOSE
+REINHARTD.
+Alternatively, if the Court grants
+allowed to depose him.
+permissive intervention, the victims should be
+proposes to intervene as a party-in-interest in this civil case,
+Case No. 08-807346-Civ-Marra. Of course, in civil cases "liberal civil discovery rules" provide
+"broad access" to relevant information. Ross |. Buckeye Cellulose Corp., 980 F.2d 648, 661
+(11th Cir. 1993). Jane Doe #1 and Jane Doe #2 should be able to avail themselves of those rules
+to determine whether Epstein used
+to improperly obtain information about the criminal
+investigation of the victims' sexual abuse or otherwise to inappropriately influence the process.
+has also made factual representations in support of his motion, including
+representations about his lack of involvement in the Epstein case and the supposed inadequate
+basis for the victims allegations.
+motion for sanctions (attached to his motion to
+intervene) alleges, "based on information and belief," that victims' counsel "did not speak to any
+current or former personnel from the Office or the FBI who were familiar with the structure of
+the West Palm Beach Office or with Movant's [i.e.,
+role (or lack thereof) in the
+Epstein investigation." Intervenor's Motion for Sanction at 5. The motion further complained
+that victims' counsel "never contacted Movant." Id.
+Oddly for one complaining about lack of contact,
+never contacted the victims"
+counsel about whether they have spoken to current personnel in the U.S. Attorney's Office about
+5
+
+
+involvement in the Epstein case. If he had done so,
+would have learned that
+on December 10, 2010, victims counsel met in Miami with the Wilfredo Ferrer, United States
+Attorney for the Southern District of Florida; Ben Greenburg, First Assistant U.S. Attorney;
+Lee, Assistant U.S. Attorney; and A. Marie Villafaña, Assistant U.S. Attorney and line
+prosecutor on the Epstein matter.
+Without disclosing any information about the details of that
+settlement meeting, victims' counsel believe it is appropriate to report that
+involvement in the Epstein investigation was discussed.
+Moreover, in an effort to facilitate contact on these issues, the same day that
+filed his motion to intervene (May 3), victims' counsel (Cassell) sent an e-mail to
+requesting an opportunity to talk with him about his role in the Epstein case. The next day (May
+4),
+sent a letter back refusing to talk about the matter. In view of
+refusal to
+meet voluntarily with the victims' counsel regarding his factual representations, if the Court
+decides to allow
+to intervene, it should also grant the victims the right of a reasonable
+deposition regarding his involvement in the Epstein case.
+POSITION OF THE PARTIES
+The victims wish to clarify the position of the parties.
+reports in his motion
+(based on a discussion with Assistant U.S. Attorney
+Lee) that the United States "does not
+oppose the Motion to intervene." The victims wish to report (likewise based on discussion with
+AUSA Lee) that the United States does not support the motion to intervene. The United States
+believes that this issue is a fight between the victims and
+in which it is simply not
+involved, so it takes no position on the motion. The United States also believes that it can
+adequately defend against the victims' assertions without any need for
+involvement.
+6
+
+
+CONCLUSION
+For all the foregoing reasons, the Court should deny
+this Crime Victims' Rights Act case.
+DATED: May 17, 2011
+motion to intervene in
+Respectfully Submitted,
+s/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS. FISTOS & LEHRMAN. P.L.
+and
+Paul G. Cassell
+Pro Hac Vice
+Lani
+Attorneys for Jane Doe #1 and Jane Doe #2
+7
+
+
+CERTIFICATE OF SERVICE
+The foregoing document was served on May 17, 2011, on the following using the Court's
+CM/ECF system:
+Roy Black, Esq.
+Jackie Perczek, Esq.
+Martin G. Weinberg, P.C.
+20 Darl. Dlesa
+Joseph L. Ackerman, Jr.
+Fowler White Burnett PA
+8
+
+
+West Palm Beach, FL 33401
+Breinhart@BruceReinhartLaw.com
+(via U.S. mail)
+9
diff --git a/vision-fixhub/ds9-unparsed-06/008b7497d16a26c12dc973286f9cc8c8a425573e26463da65f635647bad1b1e4.receipt.json b/vision-fixhub/ds9-unparsed-06/008b7497d16a26c12dc973286f9cc8c8a425573e26463da65f635647bad1b1e4.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..82bc24061b73328d22b084908413ef570cca50f4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/008b7497d16a26c12dc973286f9cc8c8a425573e26463da65f635647bad1b1e4.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -108,
+  "dataset": "marble-joined",
+  "doc_id": "008b7497d16a26c12dc973286f9cc8c8a425573e26463da65f635647bad1b1e4",
+  "engine": "marble-apple-vision",
+  "event_count": 9,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "0a0c078301a5507dfaf8eef28376acb58d2759f17a5b149cb747ab3b8409e71f",
+  "output_sha256": "10881683ece6157004e3c43d8e3783e5202a7e340613cebf368f8e902df4a39a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/010521b739bf4a4abf23b36ea1e7aa207ebe5975a6606aa653160b2c9d2f2f99.md b/vision-fixhub/ds9-unparsed-06/010521b739bf4a4abf23b36ea1e7aa207ebe5975a6606aa653160b2c9d2f2f99.md
new file mode 100644
index 0000000000000000000000000000000000000000..8db0a52eee1f3fdd9ac7029848df17e712ba246a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/010521b739bf4a4abf23b36ea1e7aa207ebe5975a6606aa653160b2c9d2f2f99.md
@@ -0,0 +1,20936 @@
+1
+
+Your Monthly Account Statement
+Customer Care
+Please call: 1-800-639-6111
+Web site: www.nextel.com
+Account Summary
+For Your Records
+Amount Paid
+Date Paid
+Approved
+Previous balance
+Payments as of 07/11/04 - Thank You
+Outstanding balance
+New charges
+Total Amount Due
+Due Date August 04, 2004
+$2,466.56
+-2,466.56
+922.84
+$922.84
+Summary of New Charges
+Adjustments, access and other charges
+Telecommunications Services
+Unit taxes, fees and assessments
+Total Wireless Services
+Account taxes, fees and assessments
+Adjustments to new charges
+Account Level Equipment Charges
+Nextel Retail Stores - Charges
+Third Party Charges, Adjustment and Taxes
+Total New Charges
+Nextel News: Please see the next page for important updates about your Nextel service.
+698.18
+63.88
+160.78
+$922.84
+$922.84
+octel Communicati
+Box 179
+Denver, CO 80217-0990
+MANIFESTLINE-.
+DANIAL BEALE
+16857 71ST LN N
+LOXAHATCHEE, FI
+33470-3349
+F55555444422CF
+Please detect it denion esp return it our parent in the enclosed envelope.
+SUNSHINE SVCS UNLIMI
+Account number 747607414
+Statement date July 15, 2004
+Total amount due $922.84
+Due date
+August 04, 2004
+Amount paid
+$
+Make checks payable to
+Nextel Communications
+TO PAY BY CREDIT CARD FOR THIS INVOICE
+ONLY OR CHANGE BILLING ADDRESS
+Check here and complete the information on the revers@ side.
+Mail Payment To:
+NEXTEL COMMUNICATIONS
+PO BOx 4191
+Carol Stream, IL 60197-4191
+F601974191110F
+747607414 000092284 0000000000 0000922843
+
+
+2
+
+A Guide to Your Monthly Nextel Statement
+Your Monthly Account Statement
+Your Nextel Account Summary
+Your Nextel Retail Stores - Charges &
+Services
+Nextel Direct Connect® Summary
+Additional Account Information
+Detail of Access and Usage by User
+Your Monthly Nextel Account Statement is organized into the following sections:
+he first page of your bill summarizes your payments, new charges, and amount du
+extel News will give you information about products, features, and promotions. U
+e remittance slip at the bottom of the page to pay your bill. Use the reverse side
+e remittance slip to pay by credit card or to change your billing addre
+The account summary is a tool to help you quickly see monthly charges for each
+user. The summary shows the user's name (if available) and mobile telephone
+number. It also provides the user's adjustments to new charges, access charges and
+breaks out usage by product or feature, such as Telecommunications Services,
+Messaging, Nextel Online® and third party charges, Nextel Direct Connect® an
+associated Taxes, fees and assessment
+This section itemizes activities at your local Nextel Retail Stores that were charged to
+your existing Nextel account. The total from this page is reflected on your summary of
+new charges as Nextel Retail Stores Charges.
+Refer to this section for information on Nextel Direct Connecte,
+Nationwide Direct Connect(TM), and Nextel Group Connect T
+including billable Group Connect(TM) call duration and usage
+Depending on the activity in your account, this section includes summary information
+about payments, taxes, adjustments, and Nextel equipment and third party charges
+billed at the account level.
+Refer to this section for information on monthly adjustments, access and other charges
+In addition, this section includes call detail, usage and associated Taxes, fees and
+assessments. Details about charges made for third party products are also contained
+in this section.
+Please fill out this form to pay your Nextel account balance using a credit card this month,
+or to change your billing address.
+Credit Card and Bank Account Payment
+Name (as it appears on the card
+If you would like to pay by credit card or
+Type of card (check one
+automatically debit your bank account on an
+• Visa
+Discover
+• MasterCard
+• American Express
+ongoing basis, please call Customer Care at Account Number
+1-800-639-6111 or dial 611 from your Nextel
+phone, for additional information.
+Credit Card Billing Zip Code
+Expiration date
+Amount $
+Month
+Year
+Change of Billing Address
+Email (Optional):
+Nextel may contact you regarding new
+offerings or promotions.
+Signature .
+Company Name
+Contact Name -
+Street Address —
+City
+Phone (
+) -
+State
+-
+_ Zip
+
+
+
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+Nextel News
+Cross borders at the push of a button. International Direct
+Connect is now available in and between the U.S. & Mexico.
+as well as Peru, Brazil, Argentina, or Canada. You
+automatically have access now. International Direct Connect
+calls use the Direct Connect minutes in your plan and incur
+an additional charge of $0.20/minute rounded to the second.
+Or choose from one of our unlimited or reduced rate
+options. See nextel.com/international for more details. As
+with all Direct Connect services, International Direct
+Connect calls are charged to the call initiator and perminute charges are multiplied by the number of participants
+Effective with your Aug invoice, the Nextel Service Plan,
+currently $2.50 per phone per month, will increase to $2.99
+per phone per month for each phone on your account.
+Remember! With the Nextel Service Plan, if your phone is
+repairable, it's covered at no additional charge at over
+1,300 Service & Repair locations natiomvide. For additional
+information, call 1-800-724-9351 or visit Nextel.com/support
+Nextel News continued...
+after phone purchase, activation, mailing in of a complete
+and valid rebate form to receive rebate.
+One rebate per
+phone purchase. May not be available in all markets. Full
+terms and conditions on mail-in rebate form. Set up fee of
+$35 per phone, up to $70 max per account (some markets a
+max of $80/account per order) applies. Shipping charge of
+$8.50 per phone ($12.00 in some markets) on up to 10 phones
+per account may apply.
+Please send all correspondence including billing inquiries
+to the below address. Please do not enclose your payment
+with the correspondence.
+Nextel Communications
+PO Box 17990
+Denver, CO 80217-0990
+You may also contact Nextel Customer Care at 1-800-639-6111
+or by going to the following web site: www.nextel.com.
+LISTEN UP, RACE FANS! Introducing Nextel FanScan In-Car
+Audio. Listen in on all the action during Nextel Cup races
+with the ease of a phone call. Hear live in-race radio
+communications between select drivers and their pit crews
+as they discuss pit strategies, positioning, track
+conditions, car handling, and more - live, right on your
+Nextel phone. Just dial *RACE, or visit nextel.com/fanscan
+for prices and additional info. Not available at or near
+the track where the current race is running. Airtime and
+long distance charges apply - FanScan does not use a tall-
+GET THE 1530 FOR JUST $74.99!! For a limited time, get the
+compact i530 phone for just $74.99, after $25 mall-in
+rebate, when you sign a two-year service agreement. The
+GPS-enabled i530 offers a durable flip design,
+speakerphone, 600-entry contact manager, and more.
+Hurry!! Call 1-800-569-1240 today!!! $25 mail-in rebate
+expires Sept 30, 2004. While supplies last. Requires twoyear service agreement. Allow 8-12 weeks affer phone
+purchase, activation, mailing in of a complete and valid
+rebate form to receive rebate. One rebate per phone
+purchase. May not be available in all markets. Full terms
+and conditions on mail-in rebate form. Set up fee of $35
+per phone, up to $70 max per account (some markets a
+max of S8l/account per order) applies. Shipping charge of
+$8.50 per phone ($12.00 in some markets) on up to 10
+
+•..*ONE DRIVER WINS THE CUP. ONE FAN WINS $250,000.•***•
+The Race to the Chase for the NASCAR NEXTEL Cup
+Sweepstakes. Visit nextel.com/race for details.
+INTRODUCING THE FULL-FEATURED i710!! The new i710 phone
+offers advanced features like speakerphone, downloadable
+applications, games and ring tones, GPS-enabled, and call
+preview. Right now, add the new i710 to your account for
+just $99.99 with $25 Motorola mail-in rebate. Hurry! Call
+1-800-310-0165 today!! $25 Motorola mail-in rebate expires
+September 30, 2004. While supplies last. This phone does
+not have an external caller ID display. Open flip to
+preview incoming calls and press "Yes" to answer calls.
+Requires two-year service agreement. Allow 8-12 weeks
+Do you have surplus inactive Nextel phones? Visit
+nextelbuyback.com to either donate surplus inactive phones
+or get a credit on your account for all eligible phones.
+All Donations go to American Red Cross Armed Services
+Emergency Fund. Customers without Web Access may call the
+Buyback Support Line at 866-364-5680 for program
+information.
+**REFER SOMEONE TO NEXTEL AND EARN UP TO $250** With the
+Nextel Referral Rewards Program, you can get a $25 Referral
+Rewards card, redeemable anywhere VISA(R) debit cards are
+accepted (up to $250 per year), for each associate, friend
+and family member you refer to Nextel. And once they
+activate a new Nextel account, they li receive a $25
+invoice credit. Visit nextel.com/referral for full details.
+Refemal Offer ends December 31, 2004. Referral rewards
+may be applied to the first ten qualified new accounts you
+refer by December 31, 2004.
+SAVE S5 to $30" IN BOOKING FEES - While almost all
+traditional and online travel agencies charge a service fee
+to book airline tickets—-ranging from $5 to $30 —you're
+never charged a booking fee at usairways.com. It's quick
+
+Account number 747607414
+Stang pet tod
+Nextel News continued...
+and easy, plus you eam 1,000 bonus Dividend Miles for
+every ticket you book there. US Airways serves hundreds
+of destinations in the U.S., Canada, Europe, the Caribbean
+and Latin America. "For details visit usairways.com/save.
+User Name/
+Mobile Number
+581-002-3090
+801-02-00
+$0.49
+601-02-088.
+801-02-0013
+SANE SCS UNLITED
+UN 23-3440
+$698.38
+Total Wireless Services
+Account number 747607414
+Your Nextel Account Summary
+Telecommunications Messaging Nextel OnlineD
+Nestel Direct
+Services MinSec
+Messages / and Thind Party
+Charges
+Charges/Taxes
+Connects Min: Sec
+Used / Charges
+KBytes/Charges
+2323:00
+242-09
+435:31
+477:34
+4010:00
+523.80
+100:07
+$12.41
+960:85
+226:27
+$1.40
+172:01
+1463,00
+$15.49
+#75 = 00
+$2.80
+75,54
+$27:20
+3333:34
+$63.31
+2081:43
+50.00
+Acrount Level Charges.
+Miss. addtional charges
+Account Tanes, Fees and Assessmants
+Austments is new charges
+Account Level Equipment Charges
+Nevel Retal Stores - Charges
+Third Party Charges, Austments and Tares
+Total New Charges
+Unit Taxes,
+Fees and
+Assessments
+$14.15
+945.18
+$12.43
+$12.4*
+543.59
+$16.52
+$16D.78
+Total Access
+and Usage
+$91.97.
+.573:44..
+564.30.
+$30.40
+3022.14
+8932-24
+$D.DD
+$D.00
+$$22.84
+*AL: Albemate Line
+Number of units in your account:
+or units
+Rate Plan Airtime Usage Summary
+The information in this grid is provided for each unit in the "Detail of Access and Usage by User".
+Number
+Total
+*Rate Plan Other Billable
+Rate Plan
+of calls
+Min: Sec
+Min: Sec
+Min:Sec Min:Sec
+Total
+Fate Charges
+Other Usage Charges
+Cal Forwarding
+Peak
+2:00
+2:00
+0.20
+0.40
+continued...
+
+
+Account number 747607414
+Statement date July 15, 2004
+Rate Plan Airtime Usage Summary continued.
+Number
+of units
+Rate Plan
+Total
+Min: Sec
+Nextel National Shared 500
+Celwar Usage
+Peak
+Off Peak
+Nextel Direct Connecte
+Peak
+of Peak
+National Shared Value 500
+Caluar Usage
+Peak
+Off Peak
+Nextel Direst Connecte
+Peak
+Off Peak
+National Unimited NDC Plus
+Calular Usage
+Off Peak
+Nestel Direct Connecte
+Peak
+Off Peak
+Nextel National Shared UBC
+Calular Unapo
+Off Peak
+Nestel Direct Consecto
+Peak
+Off Peak
+National Free Incoming 600
+Calular Usage
+Peak Incoming
+Off Peak incoming
+Peak Outgoing
+Off Peak Outasing
+Nestel Direct Connecte
+Peak
+Off Peak
+Local instant Connect 1090
+Catular Usage
+Peak
+Off Peak
+Nestel Direst Connecte
+1
+Off Peak
+240
+120
+2192
+730
+118
+184
+170
+58
+454
+537
+"Rate Plan
+Min:Sec
+319:19
+116:12
+416:23
+61:12
+88:00
+33:00
+225-00
+74:46
+204:09
+22:18
+326.00
+343:00
+290:00
+116:00
+446:58
+80:38
+1341:00
+95:40
+Total Usage Charges
+• Car in se is fe hang rite end acanth used
+"Other
+Billable
+Min: Sec
+Min:Sec
+319:19
+116:12
+98:00
+13:00
+137:20
+34:36
+4940-00
+533:00
+134:28
+74:45
+29:21
+204:09
+22:18
+20600
+290 / 00
+116:00
+146:58
+80: 38
+580,00
+1342,00
+146-30
+35:40
+Total
+Rate Charges
+0.35
+D.39
+0.40
+Đ.40
+Đ.DD
+D.00
+0.35
+Đ.35
+Đ.DD
+Đ.40
+0.40
+0.40
+0. 00
+D.00
+D.00
+26.18
+8.88
+635.40
+contirued..
+Account number 747607414
+Sting priate Jun 11 - 04y 10, 2004
+Summary of Shared Usage Adjustments *
+Telecom Shared Usage Adj
+Total Shared Usage Adjustments
+"This GRID reflects your savings for the billing period by using Shared Usage Price Plans. The actuar
+adjustments appear with the subscriber details.
+- $22.58
+-$22.58
+
+
+Account number 747607414
+Sling perate June 5 - Sul 10, 2004
+Nextel Direct Connect® Summary
+Nextel Direct Connect@ Network Summary
+Network # 158*24
+Network # 159*26
+Network # 159*61
+Total Nextel Direct Connectio Charges
+Network # 158*24
+Usage Charges
+Nextel Direct Connect®
+Nextel Group Connect(TM)
+Total Usage Charges
+Total Charges for Network #
+158*24
+The Nextel Direct Connect® minutes: seconds included in your rate
+plan are applied as you make Nextel Direct Connecte, Nextel Group
+Connect(SM) and International Direct ConnectS) calls during the
+billing period. See Detail of Access and Usage by User for
+individual charges and minutes used.
+Nextel Direct Connecte Usage
+Mutta Reco ran
+1 Nextel National Shared 500
+1
+Of Peak
+National Shared Value 500
+Min Sec Less Min:Sec Less Other
+in Plan
+Min: See
+Billabla
+Mine See
+Rate
+416.23
+61,32
+436:23
+61.12
+137:26
+14:30
+137:2k
+D.15
+0.15
+Off Peak
+National Unlimited NDC Plus
+1
+Off Peak
+Nestel National Shared UDC
+1
+Of Peak.
+Local instant Connect 1000
+634:55
+834:55
+125:10
+204.09
+204.09
+Of Peak
+146,30
+85:4D
+D.DD
+D.DD
+TOTAL
+cordinued.
+0000
+!
+0.08
+10
+SUNSHINE SCS UNLIMITED
+Account number 747607414
+Statement date July 15, 2004
+Network # 159*26
+Usage Charges
+Nextel Direct Connecte
+Nextel Group Connect(TM)
+Total Usage Charges
+Total Charges for Network #
+159*26
+The Nextel Direct Connecte minutes: seconds included in your rate
+plan are applied as you make Nextel Direct Connect®. Nextel Group
+Connect(SM) and international Direct ConnectSM) calls during the
+billing period. See Detail of Access and Usage by User for
+individual charges and minutes used.
+Nextel Direct Connect® Usage
+Crusts Rao Plan
+National Free incoming 800
+Min: See Less Min:Sec Less Other
+Billable
+in Plan
+Mir: See
+Min: Sec
+Race
+445:58
+Off Peak
+446:58
+80: 28
+TOTAL
+Network #159*61
+Usage Charges
+Nextel Direct Connecte
+Nextel Group Connect(TM)
+Total Usage Charges
+Total Charges for Network#
+159*61
+The Nextel Direct Connect® minutes: seconds included in your rate
+plan are applied as you make Nextel Direct Connect®, Nextel Group
+ConnectSM) and international Direct ConnectS) calls during the
+biling period. See Detail of Access and Usage by User for
+individual charges and minutes used.
+Nextel Direct Connect® Usage
+in Plan
+Min: Sec
+Billable
+National Unlimited NOC Plus
+1
+66:42
+66:42
+0.80
+Usage
+
+Account number 747607414
+State petite June 1, 2-004,
+June 11 - July 10. 2004
+Network # 159*61
+Nextel Direct Connect® Usage
+Huts reco man
+Off Peak
+continued...
+MisSo Les Miser Les her
+9: 16
+9:16
+TOTAL
+11
+Rate
+D.DD
+80.00
+
+12
+Account number 747607414
+Statement date July 15, 2004
+June 11 - July 10. 2004
+Additional Account Information
+Payments to Previous Balance
+Payment
+Payment
+Total Payments to Previous Balance
+Date Received
+06/14/04
+07/02/04
+Misc. Additional Charge Summary
+Charge Units
+Total Misc. Additional Charges
+Account Taxes, Fees and Assessments
+Rate
+Total Account Taxes, Fees and Assessments
+Adjustments to New Charges Summary
+Total Adjustments to New Charges
+Account Level Equipment Charges Summary
+Total Equipment Due
+Detail of Access and Usage by User
+SUNSHINE SVCS UNLIMITED (561) 662-3098
+Adjustments, Access and Other Charges
+Local Instant Connect 1000 for 07/11-08/10
+Two-Way Messaging Premier for 07/11-08/10
+Total Adjustments, Access and Other Charges
+Telecommunications Services Charges (561) 662-3098
+Call Forwarding
+Long Distance
+Total Telecommunications Services
+Nextel Direct Connect® - Number 158*24*31584
+Nextel Direct Connecte
+Amourt
+-1,377.08
+-1,089.48
+-$2,466.56
+Amount
+Amount
+Amount
+59.99
+7.50
+$67.49
+0.40
+7.60
+$8.00
+continued
+
+
+13
+Account number 747607414
+SUNSHINE SVCS UNLIMITED (561) 662-3098 continued...
+Nextel Direct Connect® - Number 158*24*31584
+Nextel Group Connect(TM)
+Total Nextel Direct Connect®
+Unit Taxes, Fees and Assessments
+Federal-Excise Tax
+• Federal-TRS Charge
+• Federal-Univ Serv Assessment
+State-Comm Service Tax
+County-Comm Service Tax
+3.000₴
+0.0738
+1.1247
+9.170%
+5.7208
+• Federal-Programs Cost Recovery
+County-911 Taxes
+Total Unit Taxes, Fees and Assessments
+UNLIMITED
+Rate Plan Airtime Usage Detail
+or caler
+Min: Sec
+Rate Plan
+Min Sec
+Other
+Min: Sec
+Billable
+Min: Sec
+Cal Forwarding
+Peak
+2:00
+2:0D
+0.20
+Calular Usage
+1
+Off Peak
+Neel Dined Correcte
+Feak
+Off Peak
+Total Unge Charpre
+415
+537
+980:00
+1342-00
+990-00
+1341:00
+0.40
+0.40
+146:30
+$5:40
+146:30
+95:40
+2.12
+0.04
+0.80
+7.07
+4.40
+1.55
+0.50
+$16.48
+$91.97
+Total
+Charges
+D.40
+80.40
+contirued..
+14
+Account number 747607414
+(561) 662-3098 continued..
+Telecommunications Services Call Detail (561) 662-3098
+See
+Item # Date Time CallTo
+1 Jun 11 64:33 EM NATERTONN, NY
+2 Jun 15 C8:45 IM BUPPALO, NE
+3 Jun 15 10:13 IN BUPPALO, MY|
+4 Jun 16 09:55 EM GARDENCITY MY
+§ Jun 17 01:15 AM GREEN BAY, MI
+• Jun 17 01:16 AM CARDENCITY, MY
+7 Jun 18 10:45 AM DIR ABET
+8 Jun 22 06:29 EM W PALM BCH ,PL
+9 Jun 22 06:30 PM N RAIN RCH, PL
+10 Jun 26 01:04 AM BUPPALO, SY
+11 Jun 27 09:06 PM DIR ABST
+12 Jul 10 12:66 AM ATLANTA NK, GA
+13 Jul 10 61:02 AM ATLANTA NE, GA
+14 Jul 10 12:53 PM DER NAST
+TOTAL MIN:SEC FOR CHARGED CALLS
+TOTAL MIN: SEC FOR UNCHARGED CALLS
+TOTAL
+Number
+Footnote Min: Sec
+315-489-6698
+PP/PU
+3:00
+716-830-4005 PD/PU
+2:00
+716-430-4005 CP/FU
+2: 00
+516-567-3929 OP/PU
+2:00
+920-300-3113 OF/FU
+1:00
+516-567-3929
+OP /PU
+411
+FP /FU
+561-714-2541 CF
+5E1-714-2581
+716-430-4005
+CE /FU
+411
+ce /PU
+17D-4EE-221E DE/FU
+770-466-2216 00/PU
+3: 00
+1,00
+1:0D
+1:00
+2,00
+1:0D
+1:00
+411
+26:00
+2310,00
+2336:00
+Usage
+0.20
+0.20
+80.40
+30.00
+$0.40
+Long
+Distance
+0.60
+0.40
+D.40
+D.4D
+0.20
+0.80
+1.40
+D.DD
+0.20
+1.40
+D.20
+0.20
+1.40
+87.60
+e0.00
+$7.60
+Footnote
+Features
+Networks
+NN-National Network
+Services
+Time Period
+PP-Peak Period
+WD-Worldwide Discount FC-Free Call
+Tl-Tijuana Network
+Messaging Charges
+Additional Messaging Detail
+Number of
+Number of Billable
+Messages in Messages
+Messages
+Plan
+Rate
+Initial
+Messages
+Additional Additional
+Rate
+Messages
+Service Type
+Two-Way Messaging Usa
+TOTAL
+82
+82
+82
+Total Messaging Charges
+Your Rate Plans
+Rate Plan
+Unlimited Night & Wand Minutes
+Caller ID - No Charge
+Browser Wireless Web Services
+PDS Application Datapod
+Charges
+0,60
+0.40
+0,40
+0.+0
+0.20
+1,40
+0.20
+0.20
+0,20
+1.+0
+0.20
+0.20
+1.40
+$9.00
+50.00
+58.00
+Charges
+Service
+Cellular Minutes
+Caller ID
+Packet Data Service
+Packet Data Usage
+POS Application
+
+
+15
+Account number 746574VE SVCS UNLIMITED
+Sling perate June 5 - Sul 10, 2004
+SUNSHINE SVCS UNLIMITED (561) 662-3098 continued..
+Your Rate Plans
+Rate Plan
+Two-Way Messaging Premier
+NOL Web
+Local Instant Connect 1000
+Enhanced VoiceMail Service
+(561) 662-6616
+Adjustments, Access and Other Charges
+Enhanced VoiceMail Service for 07/11-08/10
+Nextel National Shared 500 for 07/11-08/10
+Nextel Service Plan $2.50 for 07/11-08/10
+Nextel Direct Connect - Number 158'24 17984
+Nextel Direct Connect®
+Nextel Group Connect(TM)
+Total Nextel Direct Connect®
+Unit Taxes, Fees and Assessments
+Federal-Excise Tax
+• Federal-TRS Charge
+• Federal-Univ Serv Assessment
+3.000%
+0.073%
+1.1248
+6.000%
+State-Comm Service Tax
+9.170₴
+County-Comm Service Tax
+5.720%
+• Federal-Programs Cost Recovery
+County-911 Taxes
+Total Unit Taxes, Fees and Assessments
+• Fees Nextel elects to collect to recover its costs of funding
+and complying with Government mandates and initiatives.
+contirued...
+Service
+PDS Application
+Two. Way Messaging Usage
+PDS Application
+Short Message Service
+Operator Assisted Messaging
+Call Detail
+Nextel Group Connect(sM)
+Nextel Direct Connecte
+Dinect Connect Cross Fleet
+Cellular Usage
+Domestic Toll
+Cellular Minutes
+1.00
+59.99
+2.50
+$63.49
+00000
+1.89
+0.04
+0.71
+0.15
+5.73
+3.58
+1.55
+0.50
+$14.15
+Account number 747607414
+Statement date July 15, 2004
+Total Nextel Charges for B
+Rate Plan Airtime Usage Detail
+Dates or Service
+Number
+of calls
+Nextel National Shared 500
+06/11404 - 07/10/04
+Cellular Usage
+1
+340
+OF Peak
+Neel Direct Corneats
+Peak
+367
+Or Pook
+Total Usage Charges
+Min: Sec
+Rate Plan
+Min:Sec
+Other
+Min: Sec
+319,19
+116/12
+319:19
+116/12
+416:23
+Telecommunications Services Call Detail (561) 662-6616
+Hem * Date Time Callio
+See
+Number
+Footnate Min:Sec
+0:00
+435.31
+435:31
+Footnote
+Features
+Networks
+Services
+Your Rate Plans
+Rate Plan
+Nextel National Shared 500
+Nextel Service Flan 52.50
+Text & Numeric Paging
+Enhanced VoiceMail Service
+16
+$77.64
+Billable
+Min: Sec
+Total
+Charges
+0.35
+0.35
+0.DD
+416:23
+61:12
+D.00
+D.DD
+80.00
+Usage
+$0.60
+80.00
+50.00
+Long
+Distance
+s0.00
+80.00
+60.00
+Charges
+80.00
+80.00
+Time Period
+pp-Peak Period
+Service
+Call Detail
+Call Forwarding
+Caller ID
+Nextel Group Connect(SM)
+Nextel Direct Connecte
+Domestic LD Rate sa
+Direct Connect Cross Fleet
+Shared Cellular Minutes
+Cellular Usage
+Domestic Toll
+Short Message Service
+Operator Assisted Messaging
+
+
+17
+Account number 747607414
+Statement date July 15, 2004
+(561) 662-6688
+Adjustments, Access and Other Charges
+National Unlimited NDC Plus for 07/11-08/10
+Total Adjustments, Access and Other Charges
+Telecommunications Services Charges (561) 662-6688
+Long Distance
+Total Telecommunications Services
+199.99
+$199.99
+23.80
+$23.80
+Nextel Direct Connect® - Number 158*24*57985
+Nextel Direct Connecte
+Nextel Group Connect(TM)
+Total Nextel Direct Connect®
+Unit Taxes, Fees and Assessments
+Federal-Excise Tax
+• Federal-TRS Charge
+• Federal-Univ Serv Assessment
+State-Comm Service Tax
+County-Comm Service Tax
+3.0008
+0.073%
+1.124₺
+9.170₺
+5.720%
+• Federal-Programs Cost Recovery
+County-911 Taxes
+Total Unit Taxes, Fees and Assessments
+6.86
+0.15
+2.57
+20.66
+12.89
+1.55
+0.50
+$45.18
+no eving dict to colet recover cos ange
+Total Nextel Charges for C
+$268.97
+Rate Plan Airtime Usage Detail
+Dates or service
+Number
+of calls
+Mational Unlimited NDC Plus
+0511/04 - 07/10/04
+Coldar Usage
+Peak
+Off Peak
+Nextel Direct Connects
+1572
+235
+Peak.
+OM Peak
+116
+Total Usage Charges
+Total
+Min: Sec
+Rate Plan
+Min: Sec
+Other
+Min: Sec
+Billable
+Min:Sec
+Total
+Charges
+3483:00
+321:00
+3689:00
+521:00
+434. 55
+125,10
+834:55
+125,10
+D.DD
+s6.00
+contirued..
+18
+Account number 747607414
+Statement date July 15, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time CallTo
+Number
+Footnate Min:Sec
+1 Jun 15 01,34 PM DIR ABET
+411
+2 Jun 16 11:26 AM DIR ABET
+411
+3 Jun 16 12:45 PM DIR ABST
+411
+2100
+4 Jun 17 01.2+ EM DIR ABET
+411
+2100
+$ Jun 21 01:43 IN DER NEST
+411
+2:00
+• Jun 29 12:40 IM DIR ABET
+411
+7 Jun 23 04:27 PM DER ABST
+8 Jun 25 11:15 AM DIR ASST
+411
+2100
+9 Jun 25 08:65 IN DIR AST
+10 Jun 29 07:54 AM DIR ABST
+11 Jun 30 07:24 AM DIR ABET
+12 Jun 30 11:01 AM DIR AST
+13 Jul 01 06:10 IM DIR ABET
+14 Jul 01 06:13 PM DER NAT
+411
+411
+411
+411
+411
+1:00
+2,00
+3: 0D
+15 Jul 01 06,30 PM DIR NET
+18 Jul 03 09:42 AM DEA NET
+17 Jul 09 82:46 IM DIR ABET
+411
+411
+TOTAL MIN: SEC FOR CHARGED CALLS
+TOTAL MIN: SEC FOR UNCHARGED CALLS
+TOTAL
+2:00
+5:0D
+1:00
+42,00
+3968:00
+4010,00
+Usage
+80.00
+80.00
+Footnote
+Features
+A Formaing
+Networks
+Services
+W-Nedel Workwide PF-Partial Free
+Tana Needsunt F-Free Call
+Your Rate Plans
+Rate Plan
+National Unlimited NDC Plus
+Long
+Distance
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+฿23.90
+$23.80
+Time Period
+Total
+Charges
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.+0
+1.40
+1.40
+1.+0
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+823.80
+50.00
+823.80
+Service
+Packet Data Service
+Call Detail
+Caller ID
+Nextel Group Connect(SM)
+Nextel Direct Connecte
+Domestic LD Rate 50
+Direct Connect Cross Fleet
+Cellular Usage
+Nationwide Direct ConnectSM)
+Packet Data Usage
+continued
+
+19
+Account number 747607414
+Statement date July 15, 2004
+June 11 - July 10. 2004
+© (561) 662-6688 continued...
+Your Rate Plans
+Rate Plan
+NOL Full Service Package
+Service
+PDS Application
+Shared Text Messaging
+Short Message Service
+Operator Assisted Messaging
+Two-Way Messaging Usage
+(561) 662-6813
+Adjustments, Access and Other Charges
+Nextel National Shared UDC for 07/11-08/10
+Total Adjustments, Access and Other Charges
+Telecommunications Services Charges (561) 662-6813
+Telecom Shared Usage Adj
+Cellular Usage
+Total Telecommunications Services
+39.99
+$39.99
+-22.58
+35.06
+$12.48
+Nextel Direct Connect - Number 158*24*37983
+Nextel Direct Connecto
+Nextel Group Connect(TM)
+Total Nextel Direct Connect®
+Unit Taxes, Fees and Assessments
+Federal-Excise Tax
+• Federal-TRS Charge
+• Federal-Univ Serv Assessment
+State-Comm Service Tax
+County-Comm Service Tax
+3.000%
+0.073%
+1.124%
+9.1708
+5.7208
+• Federal-Programs Cost Recovery
+County-911 Taxes
+Total Unit Taxes, Fees and Assessments
+* Fees Nextel elects to collect to recover its costs of funding
+and complying with Government mandates and initiatives.
+Total Nextel Charges for A
+1.66
+0.03
+0.62
+4.96
+3.10
+1.55
+0.50
+$12.42
+$64.89
+
+corticued.
+20
+Account number 747607414
+Statement cate
+A (561) 662-6813 continued...
+Rate Plan Airtime Usage Detail
+Dates or serice
+Number
+of calls
+Nextel National Shared UDC
+06/1104 - 07/10/D4
+Collar Usage
+Peak
+Of Peak
+Nextel Dinect Connects:
+Peak
+Total
+Min: Sec
+Rate Plan
+Min:Sec
+Other
+Min: Sec
+74:46
+204:09
+22:18
+Total Usage Charges
+Telecommunications Services Call Detail (561) 662-6813
+Item # Date Time CallTo
+1 Jun 11 09.32 AM W PALM BCH,PL
+2 Jun 11 11:68 A0 N RAIM RCH, PL
+3 Jun 11 12:08 IM W PALM BCH, PL
+4 Jun 11 12:30 IN N PAIN RCH,PL
+$ Jun 11 02:30 EM W PALM BCH,PL
+§ Jun 11 02:33 PM N FAIM RCH, PL
+7 Jun 11 03:12 IN N PALM BCH, PL
+• Jun 11 05:34 PM N PALM BCH, PL
+• Jun 11 10:41 EM W PALM BCH,PL
+10 Jun 12 12:39 AM W PALM BCH, PL
+11 Jun 12 01:59 AM N PALA BCH, PL
+12 Jun 12 01:49 EM W FALM BCH, PL
+13 Jun 12 05:59 PM N RAIN RCH, PL
+14 Jun 12 08:52 IM W PALM BCH, PL
+15 Jun 12 09:03 PM W PALK BCH, PL
+Number
+500
+Footnote
+Min: Sec
+561-686-4622 PP
+561- CBC-4622
+=
+2:10
+561-662-6688
+561-541-4051
+561-686-4622
+561- CBC-4622
+=
+561-666-4622
+561-502-5236
+1:00
+561-324-1491
+561-324-1491
+2:23
+561-502-5236
+561-795-0022
+561-324-1491
+3157
+1:12
+561-502-5236
+1. 00
+561-502-5236
+561-502-5236
+8:_0n3.4312
+17 Jun 11 05:02 AM N FALA RCH, PL
+18 Jun 14 09:05 AM W FALK BCH, PL
+19 Jun 14 12:54 PM W PALM BCH, PL
+20 Jun 14 01:01 IN N FALK RCH, PL
+21 Jun 14 03:17 IM W PALM ECH, PL
+22 Jun 1403:31 ALCH,PL
+Jun 14 05:64 IN W PALM BCH,PL
+24 Jun 15 11:25 AM N BALA RCH, PL
+25 Jun 15 11:46 AM W PALM ECH, PL
+28 Jun 15 11,52 AM N PATH ACH, PL
+27 Jun 15 02:29 PM N FALA NCH, PL
+28 Jun 15 04:27 IM N PALM ECH, PL
+29 Jun 16 09:45 AM N PALM ECH, PL
+561-666-4622
+561-686-4622
+5E1-124-1491
+561-666-4622
+561-66E-4622
+561-324-1491
+5E1-EED-4222
+561-795-#512|
+561-GRE-4622
+561- CBC-4622
+1,00
+1:23
+1:00
+2:33
+SE1-(BE-4633
+1.00
+Usage
+0.53
+0.7€
+0.36
+0.35
+0.39
+0.55
+0.48
+0.35
+0.39
+0.93
+0.35
+1.38
+0.35
+0.35
+0.35
+0.35
+0.35
+0.35
+0.48
+6.47
+0.35
+0.+s
+6.35
+0.69
+0.a3
+A 2E
+0.35
+Billable
+Min:Sec
+74:46
+25:21
+204:09
+22:18
+0.35
+0.35
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D. DD
+0.0D
+D.DD
+D.D0
+D.DD
+D.DD
+0.D0
+D.DD
+D.DD
+Total
+Charges
+26.18
+$35.06
+Total
+Charges
+0.53
+0.76
+0.36
+0.35
+0,39
+•.55
+0.48
+0.35
+0.39
+0.83
+0.35
+1.38
+0.42
+0.35
+0.35
+0.35
+• те
+0.35
+0.35
+0.4E
+0.47
+0.35
+0. *6
+0.35
+0,69
+0.89
+• EE
+0.35
+
+
+
+(561) 662-6813 continued.
+Telecommunications Services Call Detail (561) 662-6813
+See
+Number
+Footnote
+Item # Date Time Call To
+30 Jun 16 12:57 PM M PALK BCH, FL
+31 Jun 16 04:09 PM M PALE BCH, PL
+32 Jun 16 04:26 PN M PALE BCH, PL
+33 Jun 16 04:29 PM M BALK BCH, FL
+34 Jun 16 04:29 IN M PALE BCH, FL
+35 Ju. 17 07:45 AM N PALE BCH, PL
+35 Jun 17 D8:34 AN M BALK BCH, PL
+37 Jun 17 09,51 AN U BALK BCH, PL
+Jun 17 08:54 JC I PALE BCH, PL
+39 Jun 17 12/16 AN W PALE BCH, PL
+40 Jun 17 12,22 AM N PAL BCH, PL
+41 Jun 17 11:32 JN M BALE BCH, VL.
+42 Jun 14 08:24 AM S PALE BCH, PL
+43 Jun 1# 09:49 AN U PALE BCH, PL
+44 Jun 18 09,52 AN M PALK BCH, PL
+Jun 19 01:37 PEM PALE BCH, PL
+$
+Jun 19 04:17 PM & PALE BCH, PL
+Jun 19 08,12 PM I PALA BCH, PL
+Jun 20 02:28 AN M PALE BC, PL
+02:31 3M 5 PALK BCH, PL
+Jun 20 07:29 PM I PALE BOH, PI.
+Jun 20 07,32 PM I PALE BC,PL
+Jun 20 08:19 IN M PALE BOH, FL
+Jun. 21 11:25 AM M PALK BCH, PL
+Jun 22 12:14 PM Inconleg
+Jun 21 12,33 PM PALA BCH, PL
+Jun 21 12:34 PM M PALK BCH, PL
+Jun 2) 12,56 PM W PALE BCH, PL
+Jun 21 02,00 PM
+Toll Free Call
+59
+Tun
+03:24 IN M PALE BC, FL
+Jun 21 03:35
+IN S PALK BCH, PL
+81
+Jun 23 03:38 IN PALE BCH, FL
+Tun
+03.45 PM Inconleg
+Jun 21 04:12 IN Inceled
+Jun 21 08:58 PM S BALK BCH, PL
+09,2E PM I PALE BON,PL
+8
+JuN 22 07:54 AN M PALE BCH. PL
+Jun 22 12:54 PM G PALM BCH, PL
+IN M BALE BCH, PL
+561-686-4623
+561-68E-4622
+561-688-0288 PP
+561-689-4222 PP
+561-689-9656 PP
+561-686-4652 M
+561-68E-4622 FF
+561-964-1515 PP
+561-964-1515 FP
+561-686-4622
+561-686-4622
+561-324-1491 PP
+561-662-6688 V9
+5E1-1RE-1E55
+561-686-4622
+561-324-1491
+E1-154-1401
+561-502-5236
+561-502-5236
+8
+8
+561-204-7349
+561-502-5236
+561-686-4622
+561-686-4622
+561-667-3171
+563-CRE-4622
+866-195-5363
+561-662-EGE8
+561-478-4188
+561-478-4168
+561-478-4188
+561-E62-EGE8
+561-204-3749
+561-EBE -4622
+561-686-4622
+561-751-1440
+Min: Sec
+1152
+1:00
+1:00
+1:00
+1:47
+1:00
+1103
+1159
+1:39
+1100
+1,00
+1:00
+1:00
+1:00
+1.0]
+1:00
+1100
+1:00
+2:21
+1.00
+12:44
+1:23
+1:00
+Usage
+0.65
+0.35
+0.35
+0.35
+0.c2
+0.35
+0.37
+0.69
+0.58
+0.35
+0.35
+0.35
+0.35
+0.35
+0.24
+$.67
+0.36
+$.35
+0.35
+0.35
+0.62
+$.35
+0.35
+0.35
+0.35
+6.35
+0.35
+0.35
+0.35
+6.35
+Distance
+D.D0
+D.DD
+D.D0
+D.DD
+D.D0
+D.D0
+0.D0
+D.00
+D.0D
+D.D0
+Total
+Charges
+0.65
+0.35
+0.35
+0.35
+0.82
+0.35
+0.69
+0.38
+0.35
+0.35
+0.35
+0.35
+0.35
+0.36
+0.35
+0.35
+0.33
+0.52
+0.35
+0.35
+0.35
+0.35
+0.35
+0.35
+0.35
+0.35
+22
+Account number 747607414
+Statement cate
+(561) 662-6813 continued.
+Telecommunications Services Call Detail (561) 662-6813
+See
+Item # Date Time CallTo
+TOTAL MIN: SEC FOR CHARGED CALLS
+TOTAL MIN: SEC FOR UNCHARGED CALLS
+TOTAL
+Number
+Footnate Min:Sec
+300,07
+0:00
+100: 07
+Footnote
+Features
+Networks
+NN-National Network
+Services
+Your Rate Plans
+Rate Plan
+Caller ID - No Charge
+Nextel National Shared UDC
+Tu-Tijuana Network
+Usage
+$35.04
+80.00
+$35.04
+Long
+Distance
+80.00
+80.00
+Time Period
+PP-Peak Period
+Total
+Charges
+835.05
+B6.00
+$35.06
+UNIT 5
+Service
+Caller ID
+Call Detail
+Call Forwarding
+Nextel Group Connect(SM)
+Nextel Direct Connecte
+Domestic LD Rate 50
+Dinect Connect Cross Fleet
+Shared Cellular Minutes
+Cellular Usage
+Domestic Toll
+(561) 719-9544
+Adjustments, Access and Other Charges
+National Shared Value 500 for 07/11-08/10
+Service Fee for 07/11-08/10
+Total Adjustments, Access and Other Charges
+Tong Distancications Services Charges (861) 719-9544
+Total Telecommunications Services
+Nextel Direct Connect® - Number 158'24'20290
+Nextel Direct Connecte
+Nextel Group Connect(TM)
+Total Nextel Direct Connect®
+49.99
+1.15
+$51.14
+1.40
+$1.40
+20000
+
+
+Account number 747607414
+Statement date July 15, 2004
+UNIT 5 (561) 719-9544 continued...
+Unit Taxes, Fees and Assessments
+Federal-Excise Tax
+• Federal-TRS Charge
+• Federal-Univ Serv Assessment
+State-Comm Service Tax
+County-Comm Service Tax
+3.000*
+0.0738
+1.1248
+9.170%
+5.720%
+• Federal-Programs Cost Recovery
+County-911 Taxes
+Total Unit Taxes, Fees and Assessments
+• Fees Nextel elects to collect to recover its costs of funding
+and complying with Government mandates and initiatives.
+Total Nextel Charges for UNIT 6
+1.56
+0.04
+0.63
+4.96
+3.10
+1.55
+0.50
+$12.44
+$64.98
+Rate Plan Airtime Usage Detail
+Dates or service
+or cats
+National Shared Value 500
+06/11/04 - 07/10/04
+Celular Usage
+Peak
+Off Peak
+Nertel Dined Cornecto
+Peak
+120
+Min Sal
+Rate Plan
+Min: Sec
+Total
+Charges
+29.00
+25-00
+39.00
+0.40
+0.40
+D.DD
+137:28
+34:36
+137:28
+34:36
+0.15
+0.15
+Telecommunications Services Call Detail (561) 719-9544
+Item a Date Time CallTo
+1 Jul 01 06:22 IM DER MET
+TOTAL MIN: SEC FOR CHARGED CALLS
+TOTAL MIN-SEC FOR UNCHARGED CALLS
+TOTAL
+Number
+411
+Footnote
+1/IU
+4:00
+4.00
+123. 00
+127:00
+Usage
+Distance
+1.40
+$1.40
+89.60
+$1.40
+Total
+Charges
+1.40
+13.40
+89.60
+$1.40
+Footnote
+Features
+Car Forming
+Be Taup Be Ca
+Networks
+Services
+Time Period
+MP-Mutiple Period
+Pleased rescunt FC-Free Cal
+Your Rate Plans
+Rate Plan
+100 Cellular Bonus Minutes
+Unlimited Night & Wand Minutes
+Caller ID - No Charge
+Service
+Cellular Minutes
+Cellular Minutes
+Caller ID
+continued..
+24
+Account number 747607414
+Sting pet da Jun 15, - July 10, 2004
+UNIT 5 (561) 719-9544 continued...
+Your Rate Plans
+Rate Plan
+National Shared Value 500
+Service
+Call Detail
+Nextel Group Connect(SM)
+Nextel Direct Connecte
+Domestic LD Rate 50
+Direct Connect Cross Fleet
+Shared Cellular Minutes
+Shared DC/Group Connect Mins
+Cellular Usage
+Service Foo
+Text & Numeric Paging
+Enhanced VoiceMail Service
+Short Message Service
+(561) 723-1821
+Adjustments, Access and Other Charges
+Direct Protect Insurance for 07/11-08/10
+National Unlimited NDC Plus for 07/11-08/10
+Total Adjustments, Access and Other Charges
+Telecommunications Services Charges (561) 723-1821
+Long Distance
+Total Telecommunications Services
+Nextel Direct ConnectS - Number 159*61*18727
+Nextel Direct Connecte
+Nextel Group Connect(TM)
+Total Nextel Direct Connect®
+Unit Taxes, Fees and Assessments
+Federal-Excise Tax
+• Federal-TRS Charge
+• Federal-Univ Serv Assessment
+State-Comm Service Tax
+County-Comm Service Tax
+3.000*
+0.0738
+1.1244
+9.1707
+5.720₴
+• Federal-Programs Cost Recovery
+County 911 Taxes
+Total Unit Taxes, Fees and Assessments
+and coming sit overnet mander sand norieding
+4.95
+199.99
+$204.94
+15.40
+$15.40
+6.61
+0.15
+2.48
+19.89
+12.41
+1.55
+0.50
+$43.59
+
+25
+Account number 747607414
+Statement date July 15, 2004
+SUNSHINE SVCS UNLIMITED (561) 723-1821 continued...
+Total Nextel Charges for SUNSHINE SVCS
+UNLIMITED
+$263.93
+Rate Plan Airtime Usage Detail
+Dates of Sarvice
+Number
+of calls
+National Unlimited NDC Plus
+0811/04 - 07/10/4
+Celiar Usage
+Peak
+620
+Off Peak
+Nestel Direct ConnectE
+Peak
+OM Peak.
+Total Usage Charges
+Total
+Min: Sec
+Rate Plan
+Min: Sec
+Other
+Min: See
+Billable
+Min:Sec
+1451:00
+12:00
+66:42
+9116
+Telecommunications Services Call Detail (561) 723-1821
+See
+Footnote
+Item # Date Time
+Call To
+1 Jun 12 D8008 AN DER AGAT
+2 Jun 1# 02:39 PM DER ABST
+3 Jun 1# 02:45 IM DER MET
+* Jun 21 01,33 PM DIR A68T
+5 Jun. 22 D8121 AN DIR AGAT
+§ Jun 22 11:29 AN DER ABST
+7 Jun 30 12:44 IN DER MaT
+8 Jul 02 08:18 AM DIR A68T
+• Jul 02 10:02 AM DER MET
+10 Jul 02 04:00 IN DEN MET
+11 Jul 09 09:28 AM DER NE8T
+TOTAL MIN:SEC FOR CHARGED CALLS
+TOTAL MIN-SEC FOR UNCHARGED CALLS
+TOTAL
+Number
+411
+411
+411
+411
+411
+411
+Min: Sec
+2:00
+1:00
+12:00
+4:00
+2100
+4:00
+6:00
+4.00
+411
+411
+411
+3:00
+1:00
+42.00
+1421-80
+1463-00
+Footnote
+Features
+Networks
+NN-National Network
+Services
+Your Rate Plans
+Rate Plan
+Caller ID - No Charge
+1451:00
+12:0D
+CE :42
+9.36
+Usage
+0.0D
+0.0B
+s0.00
+Long
+Distance
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+$25.40
+89.60
+$19.40
+Time Period
+Total
+Charges
+D.DD
+D.DD
+D.0D
+86.00
+Total
+Charges
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+$25.40
+80.60
+$19.40
+Service
+Caller ID
+26
+Account number 747607414
+Sting priate Jun 11 - 04y 10, 2004
+SUNSHINE SVCS UNLIMITED (561) 723-1821 continued...
+Your Rate Plans
+Rate Plan
+National Unlimited NDC Plus
+Browser Wireless Web Services
+NOL Full Service Package
+Direct Protect Insurance
+Text & Numeric Paging
+Service
+Call Detail
+Nextel Group Connect(SM)
+Nextel Direct Connecte
+Domestic LD Rate 50
+Direct Connect Cross Fleet
+Collular Usage
+Nationwide Direct Connect(sM)
+Packet Data Service
+Packet Data Usage
+PDS Application
+Shared Text Messaging
+Two-Way Messaging Usage
+Direct Protect Insurance Prgm
+Short Message Service
+Operator Assisted Messaging
+(561) 723-3440
+atonal Free incoming 00 for 07/41-0810
+Service Fee for 07/11-08/10
+Total Adjustments, Access and Other Charges
+Tong Distancications Services Charges (661) 723-3440
+Total Telecommunications Services
+Nextel Direct Connect® - Number 159'26'4992
+Nextel Direct Connecte
+Nextel Group Connect(TM)
+Total Nextel Direct Connecte
+69.99
+1.15
+$71.14
+2.80
+$2.80
+9000
+
+Account number 747607414
+Statement date July 15, 2004
+(561) 723-3440 continued.
+Unit Taxes, Fees and Assessments
+Federal-Excise Tax
+• Federal-TRS Charge
+• Federal-Univ Serv Assessment
+State-Comm Service Tax
+County-Comm Service Tax
+3. 000₴
+0.0738
+1.1248
+9.170%
+5.720%
+• Federal-Programs Cost Recovery
+County-911 Taxes
+Total Unit Taxes, Fees and Assessments
+• Fees Nextel elects to collect to recover its costs of funding
+and complving with Government mandates and initiatives.
+Total Nextel Charges for UNIT 4
+2.30
+0.05
+0.87
+6.93
+4.32
+1.55
+0.50
+$16.52
+$90.46
+Rate Plan Airtime Usage Detail
+Dates or service
+National Free Incoming 600
+06/11/04 - 07/10/04
+Cellular Usage
+Peak Outgoing
+Off Peak Outgoing
+Peak Inooming
+Off Peak Incoming
+Nentel Direct Cornecte
+Peak
+454
+Off Peak
+Total Usage Charges
+Min Sal
+Rate Plan
+Min: Sec
+Total
+Charges
+290:00
+116:00
+326:00
+143:00
+290,00
+116-00
+265:00
+0.40
+0.40
+D.DD
+446: 59
+446:58
+80=28
+$6.00
+Telecommunications Services Call Detail (561) 723-3440
+Item # Date Time CallTo
+Number
+See
+Footnote Min:Sec
+1 Jun 26 02:13 IM DIR ABET
+411
+08/80
+2:00
+2 Jun 26 02129 EM DER A627
+411
+OP/BU
+2100
+TOTAL MIN:SEC FOR CHARGED CALLS
+4:00
+TOTAL MIN:SEC FOR UNCHARGED CALLS
+871.00
+TOTAL
+875.00
+Usage
+80.00
+Distance
+1.40
+1.40
+$2.80
+19.80
+$2.80
+Total
+Charges
+1.40
+1.40
+42.80
+80.00
+s2.a0
+Footrate
+Features
+Cal Forwarding
+Networks
+Services
+Time Period
+Ch Canadar tick AliAsimula Usage OR Or Peak Period
+Need Worldwide Pf-Partial Free
+MP-Muliple Period
+corticued.
+28
+Account number 747607414
+Bring erote June 1, - uly 10, 2004
+UNIT 4 (561) 723-3440 continued...
+Your Rate Plans
+Rate Plan
+Browser Wireless Web Services
+Two-Way Messaging Express
+Service Fee
+Text & Numeric Paging
+National Free incoming 800
+Enhanced VoiceMail Service
+Service
+Packet Data Service
+Packet Data Usage
+POS Application
+Two-Way Messaging Usage
+Short Message Service
+Operator Assisted Messaging
+Call Detail
+Caller ID
+Nextel Graup Connect(SM)
+Nextel Dinect Connecte
+Domestic LD Rate 50
+Direct Connect Cross Fleet
+Cellular Usage
+Cellular Minutes
+
+
+Cellular Airtime Usage Summary
+The minutes displayed in this grid are for neference only: Always refer to the Detail of Access and Usage by user sections for full
+unit detai. (
+User Name / DAC
+UNIT S
+Totals
+Number /
+Pooling group
+Plan Minutes /
+Additional Min Used!
+Total Plan Min
+and Additional Min
+Used
+Total Min Used /
+Billable Min Used /
+Per Min Rate
+Billable Usage Charges /
+Shared Usage Adjustments /
+Total Usage Charges
+561-662-6616
+CSG7
+500:00
+135:31
+561-723-3440
+600:00
+169:00
+฿75:00
+561-662-3098
+1000:00
+2321:00
+561-719-9544
+CDC1
+50D: 00
+127:00
+561-723-1821
+561-662-6813
+CSG7
+2600:00
+1849:00
+3758:31
+135:31
+0.35
+4010:00
+4010:00
+875:00
+0.40
+2321:00
+0.40
+127:00
+0.40
+1463:00
+1463:00
+100:07
+100:07
+0.35
+9331,38
+5573:07
+N/A
+50.00
+50.00
+50.00
+50.00
+50.00
+50.00
+50.00
+50.00
+50.00
+50.00
+50.00
+50.00
+50.00
+50.00
+50.00
+$35.06
+-$22.58
+$12.48
+$35.06
+-$22.58
+$12.48
+Account number 747607414
+Detail of Access and Usage by User
+SUNSHINE SVCS UNLIMITED (561) 662-3098
+Telecommunications Services Call Detail (561) 662-3098
+See
+item # Date Time CallTo
+1 Jun 11 01:17 AM Incoring
+2 Jun 11 10:19 AM Inconing
+3 Jun 11 11:02 AM N FALM BCH ,PL
+4 Jun 11 11:28 AM Inconing
+5 Jun 11 12:08 IM Inconing
+• Jun 11 01:36 PM Inconing
+7 Jun 11 01:27 EM Incondng
+8 Jun 11 02:68 PM Inconing
+@ Jun 11 09:15 IM N PALM BCH, PL
+10 Jun 11 03:16 PM Inconing
+11 Jun 11 03:26 EM I PALM BCH ,PL
+12 Jun 11 03:40 I Inconing
+13 Jun 11 64.04 PM Inconing
+14 Jun 11 06:50 EM W PALM BCH, PL
+15 Jun 11 07:30 PM Inconing
+16 Jun 11 07:23 IM Inconing
+17 Jun 11 07:36 PM Inconing
+18 Jun 11 07:45 EM Inconing
+19 Jun 11 08:17 M Inconing
+20 Jun 11 08:18 IM BOYTONBCH, PL
+21 Jun 11 08:24 PM Incondng
+Jun 11 09:11 IN BOTONECH, FL
+Jun 11 09:22 I Incoring
+Jun 11 10:IE PA N PALM BCH,PL
+25 Jun 11 10:42 EM Inconing
+26 Jun 11 11:31 IN N FALA C,PL
+Jun 11 11:92 IN W PALM BCH, PL
+Jun 11 11:37 PM Inconing
+Jun 11 11:43 IN PALM BCH,L
+Jun 11 11:44 IM W PALM BCH,PL
+31 Jun 11 11:45 PM Inconing
+Jun 12 12:00 A PA CL
+Jun 12 12:01 AM A RAIN NCH, PL
+34 Jun 12 01:20 AM Inconint
+Jun 12 10:31 AM W PALK BCH,PL
+36 Jun 12 10:34 AM N PALM BCH,PL
+37 Jun 12 10:35 AM Incoring
+Jun 12 10:50 AM W PALM BCH,PL
+39 Jun 12 10:55 AM N PALM BCH, PL
+Number
+Footnote Min: Sec
+3E1-37T-4709 0B/FU
+561-965-4999 PD/PU
+561-432-2936 FP/FU
+561-365-4989 FE/FU
+561-309-5958 PD/PU
+5:00
+1:00
+2:00
+2:00
+561-343-6763 FF/FU
+561-255-1391 PP/CN/FU
+5E1-109-5958 FF/FU
+561-255-1351 PD/PU
+561-255-3391 PE/FU
+561-255-1391 PP/PU
+6:00
+2:00
+1:00
++: 00
+1,00
+561-541-5183 PD/PU
+561-427-2542 FP/FU
+561-541-7519 PP/PU
+5E1-341-7519 FF/FU
+561-432-2930 PD/PU
+2: 00
+2100
+8: 0D
+1:00
+561-577-4709 FP/FU
+561-541-7519 PP/PU
+5E1-341-7519 FF/FU
+561-737-3103 00/PU
+561-329-8070 PP/PU
+561-STT-470908/FU
+5100
+2:0D
+2:00
+2,00
+1:0D
+561-436-4434 00/PU
+561-309-5954 CP/FU
+3: 00
+561-373-0740 08/PU
+561-662-3DPE OF/FU
+561-541-7519 00/PU
+2:00
+6: 00
+561-763-5999 CE/FU
+361-141-7519 CE/FU
+561-541-7519 0B/PU
+561-763-5999 CE/FU
+561-541-7519 08/PU
+1:00
+14:00
+1,00
+561-255-1391 OF/FU
+561-541-7519 00/PU
+561-255-3391 CE/PU
+561-723-8391 08/PU
+561-723-8351 00/CH/FU
+1:00
+1:00
+2100
+18:00
+561-301-0308
+Ce /FU
+561-493-3016 08/PU
+1,00
+Usage
+0.06
+Long
+Distance
+D.DD
+D.OD
+D.DD
+D.00
+D.DD
+0.0D
+0.0D
+D.DD
+0.0D
+D.DD
+0.0D
+D.DD
+0.0D
+D.DD
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.0D
+D.00
+D. DD
+D.DD
+D.D0
+Charges
+0.0D
+0.0D
+0.0D
+0,00
+0,00
+0.0D
+
+
+(561) 662-3098 continued..
+Telecommunications Services Call Detail (561) 662-3098
+See
+Number
+Footnote
+Item # Date Time Call To
+40 Jun 12 10,56 AM W PALK BCH,FL
+41 Jun 12 11:37 AM Incoming
+42 Jun 12 12,36 AN M PALK BCH, PL
+43 Jun 12 11,59 AM M BALK BCH, FL
+44 Jun 12 12:0E IN M PALAC BCH, FL
+45 Jun 12 12:44 IM M PALA BCH, PL
+45 Jun 12 12:46 PM M BALK BCH, PL
+47 Jun 12 12,52 IN M BALK BCH, PL
+48 Jun 12 D1:0E IN INcORleg
+49 Jun 17 02:19 PM Inconleg
+50 Jun 12 02,56 PM M PALA BCH,PL
+51 Jun 12 03:27 WN M BALE BCH, VL.
+52 Jun 12 03:28 PM Inconieg
+53 Jun 12 03:51 EN • BALK BCH, PL
+54 Jun 12 04:23 EM Inconing
+55 JuN 12 04:24 IN M PALAE BOTE, PL
+Jun 12 04:35 PM S PALK BCH, PL
+57 Jun 12 04:40 PM M PALA BCH, PL
+A 1205:09 JUIT,
+59 Jun 12 05:37 PM M PALA BCH, PL
+60 Jun 12 05:37 A N PALE BCH, PL
+81 Jun 12 D6/08 PM I PALA BCH, FL.
+82 JuR 12 DE:43 IN INCORLET
+63 Jut 12 07:10 PM Inconiet
+64 Jun 12 08:04 PM INCORİNG
+05 Jun 12 08155 EM N BALE BCH, PL
+05 Jun 12 09:28 PM M PALK BCH, PL
+87 Jun 12 10:20 PM BOTTONECH, PL
+85 Jun 12 10:10 IN BOYTONECH, FL
+69 Ju. 12 10:14 IN ROTTONECH, FL
+70 Jun 13 01:45 AN Ieceiet
+71 Jun 13 02:59 AM MARLE BCH, PL
+72 Jun 13 01:46 PM N PALA BCH, PL
+73 Jun 11 01:51 IN M PALE BCH, VL
+74 Jun 13 03:54 PM InconleT
+75 Jun 13 04:16 PM Inconleg
+76 Jun 11 D6:01 IN INCAleG
+TT Jun 13 D6:42 PM INCHiET
+78 Jun 13 06:43 IN MALE BON, PL
+79 Jun 13 08,08 PM Inconleg
+80 JUL 17 DEER FAE CEL
+561-541-7519
+561-432-2930
+561-255-1391 OP/FU
+561-432-2930
+561-255-1391 OF/FU
+561-665-209A
+561-301-0308
+561-301-0308
+352-281-1034
+OF/FU
+561-493-3016 OP/FU
+561-255-1391 OP/PU
+561-541-7519 OP/SU
+561-324-7931 OP/CN/PU
+5E1_221-5959 0p/80
+561-582-9982
+OP/PU
+561-541-7519
+561-541-7519
+OP/PU
+561-582-9982
+OP/PU
+561-262-8209
+561-582-9982
+561-541-7519 OP/PU
+561-541-7519
+561-309-5358
+DF /FU
+561-541-7519
+561-309-1159
+561-329-8070
+561-309-5958
+561-523-1811
+561-523-1811
+561-523-1811
+OP/PU
+OP/PU
+OF/FU
+772-834-7899
+561-541-7519
+oP/FU
+561-352-7000
+Op/FU
+561-493-1016
+772-834-7899
+561-541-7519
+561-324-7931
+DE/FU
+561-747-4118
+561-541-7519
+561-541-7519
+Min:Sec
+8:00
+1100
+1:00
+2:00
+2:00
+1:00
+1:00
+2:00
+3:00
+1:00
+2:00
+1:00
+2:00
+2:00
+5:00
+2100
+1:00
+1:00
+2:00
+1.00
+2:00
+2:00
+2:00
+3:00
+1:00
+1100
+1:00
+23:00
+5100
+J:0a
+2:00
+1:00
+1:00
+2:00
+2:00
+Usage
+4.00
+4.DD
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+8.00 |
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+0.0D
+$.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.D0
+n. .f0
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.D0|
+п nn
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+Account number 747607414
+(561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Item # Date Time CallTo
+Number
+Footnote
+Min: Sec
+81 Jun 13 09:33 EM N PALM BCH, PL
+561-541-7519
+Ge /FU
+1,00
+82 Jun 13 09:34 IM Incoring
+561-432-2930
+2:00
+43 Jun 13 10:15 PM W FALK BCH, PL
+561-541-7519 CP/FU
+84 Jun 13 10:20 EM Incondng
+561-541-7519 0P/PU
+2:00
+85 Jun 13 10:41 PM N RAIN RCH, PL
+561-324-7931 OF/FU
+80 Jun 13 11:31 IM Inconing
+561-667-9195
+2:00
+Jun 14 02:25 AM Inconing
+561-432-2930
+4: 00
+88 Jun 14 09:29 AM Incondng
+561-324-7931 PP/PU
+1,00
+89 Jun 14 09:30 A N FALM BCH ,PL
+5E1-E41-030D
+FF/FU
+1:0D
+90 Jun 14 10:23 AM Inconing
+561-255-1391 FP/FU
+91 Jun 14 10:25 AM N PALA BCH, PL
+561-255-1391 PP/PU
+2,00
+Jun 14 10:41 A SALE CHL
+5E1-341-7519 FF/FU
+1:0D
+93 Jun 14 10:45 AM W PALM BCH,PL
+561-790-3459 PD/PU
+2:00
+94 Jun 14 00:20 IM Inconing
+561-577-4709 FE/PU
+2:00
+Jun 14 02:24 EM Incondng
+561-432-2930
+PP/pu
+2,00
+Jun 14 02:28 PM Incoelng
+561-790-3459 FF/CK/FU
+1:0D
+Jun
+14
+03:09 I Incoming
+561-255-1391 0D/PU
+2:00
+03:42 EM W PALM BCH,PL
+561-432-2930
+pP/pu
+8
+Jun
+14 00:19 IN N PALM BCH, PL
+561-856-2974 OB/FU
+2:00
+Jun
+=
+09:25 IN W PALM BCH, PL
+561-662-3098 00/PU
+101 Jun 14 09:26 PM N PAIN ECH, PL
+561-662-3094 08/FU
+102 Jun 14 09,49 PM Incoring
+561-255-1391 08/PU
+2,00
+103 Jun 14 10:01 EM W FALA BCH, PL
+561-255-1391 CE/FU
+104 Jun 14 10:37 IM Inconing
+561-255-1391 00/PU
+105 Jun 14 10:55 PM N FALK BCH, PL
+561-541-7519 CP/PU
+100 Jun 14 11:31 EM N PALM BCH,PL
+561-541-7519 08/PU
+107 Jun 14 11:51 IM N PALM BCH, PL
+561-541-7519 00/PU
+3:00
+6:00
+9:00
+Jun 15 12:12 AM N PALM BCH ,PL
+561-541-7519 GE/FU
+Jun 15 12:31 AM Incondng
+561-383-4763 GP/PU
+12:41 AM Inconlag
+561-383-6763 OF/FU
+7: 00
+111 Jun 15 01:19 AM Incorint
+561-432-2930 00/PU
+2:00
+112 Jun 15 10:32 AM Inconing
+561-427-2542
+FP /FU
+113 Jun
+1510:49 AM PALM BCH,PL
+561-707-5445
+pP/PU
+2,00
+114 Jun 15 11:07 AM Inconleg
+561-641-0101
+115 Jun 15 11:20 AM Inconing
+561-585-6103 FF/FU
+118 Jun
+15 11:37 AM Incoring
+561-541-5143
+PP/PU
+117 Jun 15 11:45 AM Inconlog
+561-185-8103 FD/FU
+118 Jun 15 11:50 AM Incoring
+561-255-1351 PD/PU
+119 Jun 15 12:05 PM Inconing
+561-432-2938
+1,00
+3:0D
+5:00
+4: 00
+120 Jun 15 04.12 FM Incordng
+561-432-3930
+PP/PU
+:
+04:87 PM A FALM BCH .PL
+Fp /FU
+I: 0D
+Usage
+6.08
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+(561) 662-3098 continued..
+Telecommunications Services Call Detail (561) 662-3098
+See
+Number
+Footnote
+Item # Date Time Call To
+122 Jun 15 05:34 PM Inconing
+123 Jun 15 06:02 IN M PAL BCH, PL
+124 Jun 15 D6121 PN M PALE BCH, PL
+125 Jun 15 06115 PM M BALK BCH, FL
+120 Jun 15 06:20 Incola
+127 Jun 15 06:38 IN • PALA BCH, PL
+128 Jun 15 D6:56 PM BOTTONECH, PL
+129 Jun 15 07:05 EN Inconing
+130 Jut 15 D7:3E IN Incoeleg
+131 Jun 15 D8:08 PM INCORleg
+132 Jun 15 08:11 EN Inconing
+133 Jun 15 D8:13 W Iscoeleg
+134 Jun 15 08:21 PM Inconley
+135 Jun 15 08:24 EN Inconleg
+138 Jun 15 08:45 PM W BALK BCH, FL
+137 Jun 15 D8:50 WN Inconleg|
+138 Jun. 15 08:57 IN BOYTONECH, PL
+130 Jun 15 09/01 IN Inconing
+140 Ju 15 08:07 IN M PALE BCH, PL
+141 Jun 15 09:31 PM Inconleg
+142 Jun 15 09:32 IN Incoming
+143 Jun 15 09,35 PM Inconing
+144 Jun 15 08:35 IN M PALE BCH, FL
+145 Jut 15 09:36 PM M PALA BCH, PL
+146 Jun 15 09:36 PM Inconing
+147 Jun 15 09:46 PM M BALA BCH, PL
+148 Jun 15 10:14 IN Inconley
+149 Jun 15 10:19 IN Incoming
+150 Jun 15 10:42 PM BOYTONCH, FL
+151 Jun 15 10:48 IN ROTTONCH, FL
+Jun 15 11:31 PM 5 PALK BCH, PL
+153 Jun 15 12:32 PM M PALE BCH, PL
+154 Jun 16 12151 2M Inconing
+155 JUR 16 08:2E AN INCOAlET
+158 Jun 16 12:10 AM PALE BCH, PL
+157 Jun 16 12/12 AN M BALA BCH, FL
+158 Jun 1e 11:18 AN Incoeleg
+159 Jun 16 12:50 IN IncoRiet
+160 Jun 16 12:53 IN INIT
+181 Jun 16 03118 EN Inconleg
+182 Jun I6 03:14 IN Inconleg
+561-309-5958
+PP/FU
+561-722-6562
+561-309-5958 PP/FU
+561-310-3190
+PP/FU
+561-309-5358 PP/FU
+561-310-3190
+561-577-4709 PP/FU
+561-577-4709 PP/FU
+561-EBE-4123 PP/FU
+954-465-1894
+561-577-4709 PP/PU
+561-EBE-4123 PP/SU
+561-333-7530 P9/90
+561-686-4123 PP/FU
+561-432-2930
+PP/PU
+716-830-4005
+PP/FU
+561-577-4709
+561-309-5958
+561-707-5445
+OP/PU
+561-541-7519
+561-541-7519 OP/FU
+561-541-7519
+561-541-7519
+OP /FU
+561-541-7519
+561-951-7766
+561-329-8070
+716-830-4005
+716-830-4005
+OP/CM/FU
+OP/PU
+OF/FU
+561-577-4709
+561-577-4709
+OF/FU
+561-714-2981
+561-714-2981
+561-577-4709
+561-255-1391
+561-478-4188
+561-432-2930
+OF/FU
+Op/PU
+PP/FU
+PP/FU
+PP/FU
+561-478-4168
+561-579-4709
+561-255-1391
+p/PO
+PP/FU
+561-432-2930
+Min:Sec
+3,00
+1100
+1:00
+3:00
+11:00
+3:00
+1:00
+1:00
+1:00
+1:00
+1:00
+3:00
+2:00
+1:00
+2:00
+1:00
+3.00
+1.00
+1:00
+1:00
+1:00
+4:00
+2:00
+1:00
+1:00
+1: 00
+1:00
+2:00
+1:00
+J:0a
+3:00
+1:00
+1:00
+1:00
+1:00
+Usage
+4.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+$.5B
+$.00
+0.0D
+•.00
+9,00
+$.00
+0.0D
+$.00
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+n an
+• on
+0.00 |
+n an
+Total
+Charges
+9.00
+9.00
+a.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+corticued.
+Account number 747607414
+(561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Item # Date Time CallTo
+Number
+Footnote
+Min: Sec
+163 Jun 16 04:34 FM Incordng
+561-784-9545
+PP/FU
+5100
+164 Jun 16 04:30 IM N PALM BCH, PL
+561-309-5958
+PD/PU
+1:00
+165 Jun 16 04:31 PM W FALK BCH, PL
+561-432-2930 FF/FU
+3: 0D
+160 Jun 16 04:42 EM Incondng
+561-432-2930
+PP/PU
+3:00
+167 Jun 16 04:45 PM N RADA BCH, PL
+561-432-2930 FF/FU
+188 Jun 16 05:03 I Inconing
+561-309-5958
+PP/PU
+1:00
+160 Jun 16 05:11 PM Inconing
+561-255-3391
+1:00
+170 Jun 16 06:11 EM Incondag
+561-329-4070
+pP /PU
+171 Jun 16 06:34 IN N FALM BCH „PL
+5E1-109-5958
+1:0D
+172 Jun 16 06:40 PM Inconing
+FE /FU
+173 Jun 16 06:43 PM W PALM BCH ,PL
+561-329-8070 PP/PU
+174 Jun 16 06:52 PM Incoring
+5E1-255-1391 FF/FU
+2:00
+175 Jun 16 07:04 IM Incoring
+561-255-1391 PD/PU
+2:00
+176 Jun 16 07:15 PM Inconing
+561-255-2391 FF/FU
+2:00
+177 Jun 16 07,17 PM W PALM BCH, PL
+561-329-4070
+PP/PU
+2,00
+178 Jun 16 07:18 IN N FALM RCH, PL
+5E1-329-BD70 FD/FU
+2:00
+179
+Jun 16
+07:19 W Incoming
+561-309-5958
+PD/CH/PU
+1:00
+16 07:29 EM W FAIM BCH, PL
+561-329-8070
+pP/pu
+181
+16 07:29 IN N PALM BCH, PL
+561-129-฿D70 FF/FU
+07:40 W Incoming
+561-255-1351 PD/PU
+183 Jun 16 07:47 PM Inconing
+561-309-5954 FF/FU
+184 Jun 16 07:54 PM Incordng
+561-309-5958
+pp/pu
+185 Jun 16 08:04 PM Inconlag
+561-141-7519 FF/FU
+4: 0D
+180 Jun 16 08:15 I Incoring
+561-309-5958 PD/PU
+187
+Jun 16 09:52 PM Inconing
+561-255-3391
+188 Jun 16 08.57 EM Incondng
+561-255-1391 PP/PU
+189 Jun 16 09:04 IN N PALM BCH,PL
+561-255-1391 00/PU
+1:00
+Jun 16 09:05 PM N PALM BCH ,PL
+561-255-1391
+CE /FU
+191
+Jun 16 09:06 FM W PALM BCH,PL
+561-255-1391
+1,00
+192 Jun
+16 09:08 IN N PALA RCH, PL
+561-255-1391
+DE/FU
+193 Jun 16 09:11 IM W PALM BCH, PL
+561-255-1391
+Ge /PU
+1:00
+194 Jun 16 09:23 IM Energency
+911
+Ce/PC
+195 Jun 16 09:16 EM W FALM BCH,PL
+561-255-1391
+1,00
+196 Jun 16 09:17 PM N FALM RCH, PL.
+561-255-1391
+ce /FU
+197
+Jun 16 09:19 PM W PALM BCH, PL
+561-255-3391 CE/FU
+198
+Jun 16 09:20 PM W PALM BCH, PL.
+561-255-1391
+OP/PU
+190 Jun 16 09:21 IM N PALM BCH, PL
+561-255-1391
+OF /FU
+Jun 16 09:21 PM W PALM BCH,PL
+561-255-1391
+0P /PU
+1:00
+1,00
+1:0D
+1:00
+201 Jun 16 09:22 PM N PALM BCH, PL
+561-255-2391
+De/PU
+Jun 16 09:23 EM W PALM BCH, PL
+561-255-1391
+OP /PU
+203
+0O:24 PM N FALM BCH .PL
+op /FU
+I: 0D
+Usage
+6.08
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+(561) 662-3098 continued..
+Telecommunications Services Call Detail (561) 662-3098
+See
+Footnote
+Item # Date Time Call To
+204 Jun 16 09,39 PM I PALK BCH, FL
+205 Jun. 16 09:39 IN M PAL BCH, PL
+208 Jun 16 09:40 PN M PALK BCH, PL
+207 Jun 16 10:14 EM Inconing
+205 Jun 16 10:36 IN M PALE BCH, FL
+209 Jun. 16 10:57 IN M PALA BCH, PL
+210 Jun 16 12:31 PM M BALK BCH, PL
+211 Jun 16 12,36 PM M BALK BCH, FL
+Ju 16 11:41 IN BOTTONICE, VL.
+213 Jun 17 12:16 AN Inconleg
+214 Jun 17 12,59 AN Inconleg
+215 J. 17 01:01 AN M PALE BCH, FL
+216 Jun 17 01:08 AM Inconieg
+217 Jun 17 03,12 AN ATLCIEN, PL
+218 Jun 17 01/13 AM M BALK BCH, FL
+219 Ju 17 01:22 8 Incoeleg
+220 Jun 17 01:46 JM Incoming
+221 Jun 17 01,57 AN Inconing
+223 Jun 17 03:04 3M 5 DALK BCH, PL
+224 Jun 17 06:10 AM M PALE BCH, PL
+225 Jun 17 09,51 AM Incoming
+220 Jun 17 11:39 AM INCORLET
+227 Jun 17 04:31 PM Inconiet
+228 Jun 17 05:09 IN BOTTONECH, PL
+229 Jun 17 05:16 PM M BALA BCH, PL
+230 Jun 17 06:06 PM N PALK BCH, PL
+231 Jun 17 D6:07 IN INCOmiNg
+232 Jun 17 06:11 PM M BALA BCH, PL
+233 Jun 17 DE:12 PM INcoRleg
+234 Jun 17 06:43 PM M PALK BCH, PL
+235 Jun 17 D6:54 PM M PALE BCH, FL
+236 Jun 17 07:42 IN M BALA BCH, FL
+237 Jun 17 08:07 Incele
+238 Jun 17 08:25 PM INnİeT
+230 Jun 17 08134 EN Inconing
+240 Jun 17 D8:43 m Inconley
+241 Jun 17 08:47 PM M PALK BCH, PL
+242 Jun 17 09:08 IN BOTTONCH. FL.
+243 Jun 17 09,09 PM BOYTONCE, FL
+244 JUL 17 08:22 PM PALE BOEFL
+Number
+561-310-3190
+561-714-2981
+561-432-2930 OP/FU
+561-577-4709 OP/FU
+561-644-1472
+OF/FU
+561-201-030A
+561-101-0908
+561-541-7519
+561-577-4709
+OF/FU
+561-577-4709 OP/FU
+561-255-1391 OP/PU
+561-541-7519 OP/SU
+561-577-4709 0P/P0
+772-834-7899 OP/PU
+561-714-2981
+OP/PU
+561-577-4709
+561-309-5958
+OP/PU
+561-309-1159 OP/PU
+561-309-5958
+561-714-2981
+561-255-1391
+561-255-1391
+PP/PU
+561-324-7931
+FF /FU
+561-383-6763 P9/90
+561-577-4709 PP/FU
+561-966-7883 PP/PU
+561-309-5958 PP/P0
+561-541-7519 PP/CM/FU
+561-309-5958
+PP/FU
+561-541-7519
+PP/CN/ FU
+561-324-7931
+561-541-7519 PP/FU
+561-183-6763
+PP/PU
+561-183-6763 PP/FU
+561-383-6763 PP/PU
+561-383-6763
+PP/FU
+561-541-7519 FP/FU
+561-324-7931 P0/P0
+561-577-4709
+561-577-4709
+12T100-E0E
+Min:Sec
+1,00
+1:00
+1100
+3:00
+2:00
+1:00
+4:00
+2:00
+2:00
+4:00
+2:00
+2:00
+3:00
+3.00
+1:00
+1:00
+1,00
+3,00
+1:00
+1:00
+7:00
+2:00
+2:00
+1:00
+8:00
+30:00
+3: 00
+14:00
+4:00
+4: 00
+1:00
+3:00
+4: 00
+2:00
+1:00
+1:00
+Usage
+4.00
+4.DD
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+$.5B
+$.00
+0.0D
+•.00
+9,00
+$.00
+0.0D
+$.00
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.D0
+n. .f0
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+n an
+• on
+0.00 |
+n an
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+corticued.
+Account number 747607414
+(561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Item # Date Time CallTo
+Number
+Footnote
+Min: Sec
+245 Jun 17 09:23 PM Incordng
+561-309-5958
+2:00
+240 Jun 17 09:42 IM N PALM BCH, PL
+561-541-7519
+0P/PU
+2:00
+247 Jun 17 09:44 PM W FALA RCH, PL
+561-255-1391 CP/FU
+1: 00
+248 Jun 17 09:46 EM W PALM BCH ,PL
+561-707-5445 0P/PU
+1,00
+248 Jun 17 09:51 PM Inconleg
+561-255-1391 OF/FU
+250 Jun 17 09:55 IM N PALA BCH,PL
+561-255-1391
+1:00
+251 Jun 17 09:5€ PM Inconing
+561-476-5223
+De/FU
+1:00
+252 Jun 17 10:05 EM Incondag
+561-432-2930
+CP/PU
+2100
+253 Jun 17 10:06 IN N FALM RCH, PL
+5E1-541-7519
+DE/FU
+1:0D
+254 Jun 17 10:04 IN N FALK BCH, PL.
+S61-541-7519 CE/FU
+255 Jun 17 10:34 PM W PALM BCH,PL
+561-255-1391 CP/PU
+256 Jun 17 11:17 PM Inconing
+SE1-E83-BE12
+De /FU
+2:00
+257 Jun 18 12:45 AM Inconing
+561-541-7519
+OP/PU
+1:00
+258 Jun 18 01:22 AM N FALK BCH, PL
+561-541-7519 CB/FU
+5:00
+250 Jun 18 01:27 AM Inconing
+561-541-7519
+0P/PU
+11,00
+Jun 18 08:20 AM N PALA BOH, PL
+561-324-7931
+FF /FU
+1:0D
+Jun
+18 09:13 AM N PALM BCH ,PL
+561-541-7519
+PD /PU
+4: 00
+18 10.35 MM Inconing
+561-432-2930
+PP/pu
+263
+Jun
+18 10:47 AM N PAIN BCH, PL
+561-324-7931 FF/FU
+Jun 18 10:48 AM W PALM BCH, PL
+561-541-7519
+PD/PU
+1:0D
+1:00
+285 Jun 18 10:50 AM N PALM RCH, PL
+561-582-9542
+FF/FU
+280 Jun 18 11:39 AM W PALM BCH,PL
+561-541-7519
+pp/pu
+287 Jun 18 11:66 AM N PALM RCH, PL
+561-141-7519
+Fe /Fu
+3: 0D
+208 Jun 18 12:05 PM N PALM BCH ,PL
+561-707-5445 PD/PU
+Jun 18 12:09 PM N PALM BCH, PL
+561-541-7519 FF/PU
+1:00
+270 Jun 18 12:14 PM Inconing
+561-432-2930
+PP/PU
+2100
+271 Jun 18 01:01 PM Incoring
+561-385-4371
+PD/PU
+272
+Jun
+$1:03 PM Inconing
+561-389-7854
+FF /FU
+273
+0L:44 PM Incondng
+561-541-7519
+PP/PU
+274
+01:59 IN N PALM RCH, PL
+561-324-1931
+275
+Jun 18
+02:02 PM Incoring
+561-324-7931
+PD/PU
+1:00
+276
+Jun 18 02:09 PM N PAEN BCH,PL
+561-324-7931
+FP /FU
+277
+Jun
+18 02:09 PM W PALM BCH,PL
+561-324-7931
+pP/PU
+2,00
+278
+Jun 18 02:15 EM N FALA RCH, PL
+561-707-3445|
+279
+Jun 18 00:59 PM W PALM BCH,PL
+561-707-5445 FF/FU
+1:00
+280
+Jun
+03:26 PM Inconing
+561-577-4709
+PP/PU
+281 Jun 18 04:05 IN N FACE NCH.UL
+561-324-7931 FD/FU
+282
+Jun 18 04:09 IN W PALM BCH.PL
+561-324-7931
+PD /PU
+2:00
+1:00
+Jun 18 04:14 PM N PALM BCH, PL
+561-324-7931
+FE /FU
+284 Jun 18 04:35 EM W FALM BCH, PL
+561-324-7931
+PP/PU
+1,00
+285
+04:47 PM Incorina
+Usage
+6.08
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+0.00 |
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+(561) 662-3098 continued..
+Telecommunications Services Call Detail (561) 662-3098
+See
+Footnote
+Item # Date Time Call To
+288 Jun 14 DE138 PM Inconing
+287 Jun 14 08:42 IM Inconieg
+265 Jun 14 10:08 IN Inconleg
+250 Jun 14 10:25 EN Inconing
+200 Jun 10 10:51 Inconley
+291 Jun 1# 11:01 IN M PALA BCH, PL
+202 Jun 14 12:04 PM M BALK BCH, PL
+203 Jun 14 12,38 PM M BALK BCH, FL
+294 Jut 19 08:44 JC M BALE BCH, VL
+285 Jun 19 D9:4E AN Inconleg
+208 Jun 19 10:08 AN Inconing
+297 Jun 19 10:57 18 0 PAL BC, PL
+285 Jun 19 11:09 AM M DALK BCH, PL
+200 Jun 19 12:33 AN M PALE BCH, PL
+300 Jun 19 11:46 AM W BALK BCH, FL
+301 Jun 19 12:33 PM PALE BCH, PL
+302 Jun. 19 12:44 IN M PALA BCH, PL
+303 Jun 19 12145 EN Inconing
+304 Jun 19 12:47 W Iscoeleg
+305 Jun 19 02:15 IM Ieconieg
+305 Jun 19 02:27 PM Inconleg
+307 Jun 19 02:29 PM M BALK ECH, PL
+308 J 19 02:32 IN M PALE BCH, FL
+309 Jun 19 03:38 PM M PALA BCH, PL
+310 Jun 19 03:39 IN M BALE BCH, PL
+311 Jun 19 03:44 PM BOYTONECH, PL
+312 Jun 19 03:45 PM BOYTONECH, PL
+313 Jun 19 03:50 IN IncomiNg
+314 Jun 19 06134 EM M BALA BCH, FL
+315 JuL 13 DE:55 IN INcORleg
+316 Jut 19 06:56 IN Inconieg
+317 Jun 19 07:07 PM INCORİNT
+318 Jun 19 07:23 IN M BALA BCH, FL
+319 Jun 19 07:44 IN M PALE BCH, FL
+320 Jun 19 07:48 PM InnieT
+321 Jun 19 08:14 IN M BALA BCH, FL
+322 Jun 19 D8:42 PM M PALE BCH, FL
+323 Jun 19 09:14 PM M PALA BCH,PL
+324 Jun 19 09:15 IN InIT
+325 Jun 19 10:21 IN BALA BCH, FL
+328 JuN 17 10:29 IN M FALE BCH, PL
+Number
+561-255-1391 PP/PU
+561-324-7931
+561-707-5445 OP/FU
+561-329-8070 OP/FU
+561-383-6763 OF/FU
+561-18R-6969 0020
+561-541-7519 OP/FU
+561-541-7519
+561-324-7931
+OF/FU
+561-324-7931 OP/PU
+561-324-7931 OP/SU
+561-385-4371 0P/PU
+561-790-3459 OP/FU
+561-385-4371
+OP/PU
+561-309-5958
+561-324-7931
+OP/PU
+561-324-7931
+OP/PU
+561-662-66E8
+561-827-2542
+561-523-1811
+5E1-248-0591
+561-24E-D593
+561-309-5958
+561-662-3098
+561-577-4709
+561-577-4709
+561-577-4709
+561-309-5958
+561-109-5358
+OF/FU
+op/PU
+OP/PU
+OP/PU
+OF/FU
+OF/FU
+561-309-5958
+561-309-5958
+OF/FU
+561-255-1391
+Op/PU
+561-541-7519
+561-329-8070
+561-309-5958
+561-541-7519 OP/FU
+561-255-1391
+561-385-4371
+
+OP/CN/FU
+Min:Sec
+2:00
+1100
+1:00
+1:00
+3:00
+9:00
+4:00
+1:00
+1:00
+1:00
+1:00
+2:00
+2:00
+1:00
+1:00
+2100
+2:00
+4: 00
+2:00
+1:00
+1:00
+4:00
+1:00
+6: 00
+2:00
+1:00
+1: 00
+1:00
+9:00
+1:00
+2:00
+4:00
+1:00
+2:00
+6:00
+1,00
+2:00
+Usage
+4.00
+• DE
+0.0D
+$.00
+•.0D
+4.00
+0.0D
+8.00 |
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+$.00
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.DD
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.00 |
+п nn
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+Account number 747607414
+(561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Item # Date Time CallTo
+Number
+Footnote Min: Sec
+327 Jun 19 10:33 PM Incondng
+561-541-7519
+Ge / PU
+5100
+328 Jun 19 11:35 IM N PALM BCH, PL
+561-541-7519
+OP /PU
+2:00
+329 Jun 20 01:20 AM Inconing
+561-541-7519 CP/FU
+• : 00
+330 Jun 20 12:27 EM W PALM BCH ,PL
+561-324-7931 OP/PU
+1,00
+331 Jun 20 01:11 PM N FALA BCH, PL
+561-141-7519
+2:00
+332 Jun 20 02:15 IM N PALM BCH, PL
+561-352-7931
+1:00
+333 Jun 20 00:14 PM N FALM BCH, PL
+561-541-7519
+De /FU
+3:00
+334 Jun 20 02:44 PM Inconing
+561-662-6648
+2100
+335 Jun 20 03:23 IN N FALM BCH, PL
+5E1-109-5958
+DE/FU
+1:0D
+336 Jun 20 03:24 PM W FALA BCH, PL
+561-714-2991
+337 Jun 20 03:24 PM W PALM BCH,PL
+561-432-2930
+1,00
+338 Jun 20 03:25 PM N PALA RCH,PL
+5E1-383-ETE3
+De /FU
+1:0D
+339 Jun 20 03:27 IM W PALM BCH, PL
+561-383-6763 0D/PU
+19:00
+340 Jun 20 03:46 PM N FALM BCH, PL
+561-541-7519 C8/PU
+8: 0D
+341 Jun 20 04.01 EM W FALM BCH, PL
+561-541-7519 CP/PU
+1,00
+342
+Jun 20 04:04 PM Inconleg
+5E1-341-7519 O0/FU
+2:00
+Jun
+04:11 W Inconing
+561-383-6763 00/PU
+2:00
+344
+05.59 PM Incondng
+561-343-6763 08/PU
+1,00
+345
+Jun
+06:00 IN Inconlea
+561-383-67E3 DE/FU
+Jun
+20
+06:43 IM Inconing
+561-383-6763 00/PU
+347 Jun 20 07:53 PM N PALM RCH,PL
+561-541-7519 CB/PU
+348 Jun 20 07:55 PM Inconing
+561-324-7931 C8/PU
+348 Jun 2008:03 FALA CE,L
+561-141-7519 CE/FU
+2,00
+5: 0D
+Jun 20 08:07 PM Incoring)
+561-541-7519 00/PU
+351
+Jun 20 09:29 PM N FALM BCH,PL
+561-541-7519 CP/PU
+Jun 20 09:10 EM Incondng
+561-577-4709 08/PU
+R
+Jun 20 09:13 PM N PALM BCH, PL
+561-541-7519 00/PU
+$:00
+3,00
+5:00
+Jun
+09:14 PM Inconing
+561-541-7519 CP/FU
+09:29 PM BOYTONBCH, PL
+561-577-4709 08/PU
+356
+10:07 PM Inconlag
+561-329-8070 OF/FU
+357
+Jun 20 10:10 IM Incoring
+561-309-5958 00/PU
+Jun 20 10:32 PM Inconing
+561-541-7519 CE/FU
+Jun
+10:34 PM Inconing
+561-432-2930 0P/PU
+1:00
+2:00
+1,00
+380 Jun 20 10:61 EM N FALM RCH, PL
+561-341-7519 CF/FU
+381 Jun 20 10:54 PM N PALM BCH, PL
+561-541-7519 CE/FU
+1:00
+382
+Jun 21 12:12 AM W PALM BCH ,PL
+561-662-3094 0P/PU
+383 Jun 21 12:46 AM Inconlog
+561-141-7519 C0/FU
+304 Jun 21 12:47 AM Incoring
+561-541-7519 00/PU
+1:0D
+1:00
+385 Jun 21 12:44 AM N PALM BCH, PL
+561-541-7519
+Ge /FU
+300 Jun 21 12:44 AM W PALM BCH ,PL
+561-541-7519
+OP /PU
+11,00
+387
+10:35 AM N FALM BCH .PL
+Usage
+6.08
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+(561) 662-3098 continued..
+Telecommunications Services Call Detail (561) 662-3098
+See
+Footnote
+Item # Date Time Call To
+365 J 21 10:54 3M NBALK BCH, FL
+369 Jun. 21 11:35 AM Inconieg
+370 Jun 21 02131 IN Inconleg
+371 Jun 21 02149 EM Inconing
+372 Jun 21 03:55 Inconley
+373 Jun. 21 04:53 IN • PALA BCH, PL
+374 Jun 21 05:44 PM M BALK BCH, PL
+375 Jun 21 D6145 IN M BALK BCH, FL
+376 Jut 21 D7:05 IN M BALE BCH, FL
+377 Jun 21 07:51 PM FILAUDEADL, PL
+378 Jun 21 07,54 PM N PALK BCH, PL
+379 Jul. 21 D8:13 W M PALE BCH, VL.
+380 Jun. 21 08:16 IM M DALK BCH, PL
+381 Jun 22 08:38 EN M BALE BCH, PL
+382 Jun 21 11:33 EN Inconing
+383 Ju. 21 11:44 WN M PALK BCH, VL
+384 Jun. 22 11:53 JM Incoming
+365 Jun 22 01/04 EN Inconing
+387 Jun. 22 05:00 IN Iscoming
+365 Jun 22 07:11 PM M PALE BCH, PL
+360 Ju 22 07,37 PM I PA BCH, PL
+300 Jun 22 07:42 IN M PALE BC, PLA
+391 Jut 22 07:43 PM M PALA BCH, PL
+382 Jun 22 07:56 PM Toll Free
+303 Jun 22 07,57 PM Inconing
+384 Jun 22 08:04 PM IncoRley
+305 Jun 22
+08:09 EN InCOnLEg
+305 Jun.
+22
+397 Ju
+08:39 IN M PALE BOH, PL
+Jun 22|
+09:45 PM M PALK BCH, PL
+380 Jun 22 09:46 PM M BALE BCH, PL
+400 Jun
+401 Jun 23 10:00 J8 Incele
+402 шл 23 11,35 1М Ікспікт
+403 Jun 23 12:34 PM Inconleg
+404 Jun 23 01:42 m Inconleg
+405 Ju 29 01:44 М Інсовівт
+405 Jun 23 02:04 IN PALE BON, PL
+407 Jun 23 02:07 PM BALA BCH, FL
+408 JUL 2705:41 PALE BOL
+Number
+561-324-7931
+PP/FU
+561-324-7931
+561-492-2930
+PP/FU
+561-324-7931 PP/FU
+561-432-2930
+PP/FU
+561-432-2930
+561-492-2980
+561-324-7931
+561-324-7931
+PP/FU
+PP/FU
+PP/FU
+954-557-5500
+561-309-5958
+PP/FU
+561-324-7931 PP/SU
+561-714-2981 PP/PU
+5E1-511-2519 PP/80
+561-329-2399
+561-662-3098
+561-714-2981
+561-714-2981
+561-714-2981
+561-255-1391
+561-662-3098
+561-255-1391
+561-255-1391
+561-541-7519
+888-546-0314
+561-541-7519
+561-255-1991
+561-255-1391
+OP/PU
+PP/PU
+PP/FU
+PP/FU
+PP/PU
+PP/FU
+P/PU
+PP/PC
+P/PU
+PP/FU
+561-541-7519
+561-662-3098
+561-541-7519
+561-541-7519
+561-478-4188
+561-383-6763
+561-432-2930
+561-432-2930
+561-352-7000
+561-432-2930
+561-352-7000
+561-714-2981
+OF/FU
+Op/FU
+PR/FU
+PP/FU
+PP/FU
+p/PO
+PP/FU
+PR/U
+Min:Sec
+1,00
+1:00
+2100
+4:00
+4:00
+1:00
+2:00
+2:00
+1:00
+2:00
+1:00
+4: 00
+2100
+1:00
+2:00
+1.00
+1:00
+1:00
+2:00
+1:00
+5:00
+3,00
+4: 00
+1:00
+1:00
+2:00
+5:00
+2:00
+1:00
+3:00
+2:00
+2:00
+Usage
+4.00
+• DE
+0.0D
+$.00
+•.0D
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.DD
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+• DO
+0.D0|
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+Account number 747607414
+(561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Footnote
+Item # Date Time CallTo
+409 Jun 23 05:57 PM Incondng
+410 Jun 23 06:01 IM N PALM BCH, PL
+411 Jun 23 07:10 PM Inconing
+412 Jun 23 07:19 EM Incoring
+413 Jun 23 07:40 PM Inconlog
+414 Jun 23 09:09 IN N PALM BCH, PL
+415 Jun 23 09:39 PM N FALM BCH, PL
+418 Jun 23 09:44 EM W PALM BCH ,PL
+417 Jun 23 09:6C #N Inconing|
+418 Jun 23 10:04 PM W FALA BCH, PL
+419 Jun 23 10:13 PM W PALM BCH,PL
+420 Jun 23 10:35 PM N FALM BCH, PL
+421 Jun 29 10:35 IM W PALA BCH, PL
+422 Jun 23 10:37 PM Inconing
+Jun 23 11:17 PM Incondng
+Jun 23 11:18 PM Incondng
+Jun
+11:23 IN W PALA BCH ,PL
+12/11 AM DELRAY BCH,PL
+24 12:11 AM BOZTONDCH, PL
+Jun
+429 Jun 24 12:45 AM N PALM RCH,PL
+430 Jun 24 09.19 AM N PACM BCH, PI.
+431 Jun 24 10:12 AM N FALA RCH, PL
+432
+Jun 24 12:42 PM Inconing
+43
+Jun
+12:43 PM Inconing
+Jun 24 03.55 PM Inconing
+Jun 24 04:10 PM Inconing
+Jun
+04:11 PM Inconing
+04:24 PM N PALM BCH,PL
+438
+439
+04:41 PM Inconing
+05:09 IM W PALA BCH,PL
+Jun 24 05:34 PM Inconing
+441 Jun 24 05:31 PM Incondug
+442 Jun 24 05:36 PM Inconing
+Jun 24 05:36 PM Inconing
+Jun 24 06:16 PM W PALM BCH ,PL.
+445 Jun 24 06:18 IN Incoring
+446 Jun 24 06:27 IN W PALM BCH. PL
+Jun 24 06:32 PM Inconing
+448 Jun 24 06:53 EMPALM BCH.PL
+449
+0E:53 PM N FALM BCH .PL
+Number
+561-309-5958
+PP/PU
+561-714-2981
+PD/PU
+561-309-5954 FF/FU
+561-541-7519 PP/PU
+561-714-2981 FF/FU
+561-541-7519
+561-309-5958
+561-309-5958
+5E1-432-2930
+DE /FU
+S61-432-2930 CE/FU
+561-309-5958 CP/PU
+SE1-109-5958 DE/FU
+561-714-2981 0D/PU
+561-432-2930 CE/FU
+561-309-5954 CP/PU
+5E1-E83-B612 OF/FU
+561-714-2981 00/PU
+561-843-6472 C8/PU
+561-97T-470908/FU
+561-577-4709 00/PU
+561-541-7519 CB/PU
+561-439-6147 PP/PU
+561-478-4188 FF/FU
+561-683-8612 PD/PU
+561-683-8612 FF/PU
+561-255-1391 PP/PU
+561-255-1391 PD/PU
+561-255-1391 FP/NN/FU
+561-474-4149 PP/PU
+561-432-2930 FF/FU
+561-352-7000 PD/PU
+561-765-4949 FF/PU
+561-6B6-4123 PP/PU
+SEL-EBG-4123 FD/FU
+561-6B6-4123 FF/FU
+561-255-1391 PP/PU
+561-255-1391 FD/FU
+561-255-1351 PD/PU
+561-255-3391 FP/FU
+561-255-1391
+PP/PU
+Fp /FU
+Min: Sec
+2:00
+1:00
+1: 00
+1:00
+14,00
+1100
+3,00
+1:0D
+1:0D
+2:00
+1:0D
+2:00
+2:00
+1:00
+1:0D
+1,00
+1: 0D
+9:00
+2100
+1:00
+$: 00|
+2100
+2:00
+4:00
+1:00
+2100
+1:0D
+2:00
+2:0D
+Usage
+6.08
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+D.DD
+Charges
+D.0D
+0,00
+0,00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+(561) 662-3098 continued..
+Telecommunications Services Call Detail (561) 662-3098
+See
+Number
+Footnote
+Item # Date Time Call To
+450 Jun 24 D6154 EN Inconing
+451 Jun. 24 06:55 IN M PALA BCH, PL
+452 Jun 24 D6:56 IN IncORleg
+453 Jun 24 D6157 EN Inconing
+454 Jun. 24 07:22 # Incoeleg
+455 Jun. 24 08:27 IN Incoeleg
+456 Jun 24 08:42 EN INCOmINg
+457 Jun 24 08149 PM M BALK BCH, FL
+458 Jut 24 11:53 IN Incoeleg
+459 Jun 24 12,56 PM BOTTONSCH, PL
+450 Jun 24 11,57 PM BOYTONBCH, FL
+451 Jul. 25 12:12 AN BOYTONCH, FL.
+462 Лил. 25 12:12 АМ ВОУТОНЕСН, PL.
+483 Jun 25 12,30 AN BOYTONCH, PI.
+454 Jun 25 12,31 AM N PALK BCH, FL
+455 Ju. 25 12:52 AM INCORleT
+405 Jun. 25 11:35 AM M PALK BCH, PL
+487 Jun 25 01:23 PN M PALA BCH, FL.
+455 Ju. 25 01:36 IN BOTTONCH, FL
+459 Jun. 25 01:37 PM M DALK BCH, PL
+470 Jun 25 01:53 IN Incelag
+471 Jun 25 02,49 PM M PATE BCH, PL
+472 Jun 25 02:51 W Incoeleg
+473 Jun 25 02:52 PM Toll Free
+474 Jun 25 02:58 IN M BALE BCH, PL
+475 Jun 25 03:00 PM M BALA BCH, PL
+475 Jun 25 03:05 PM BOYTONECH, PL
+477 Jun 25 03:10 PM Toll Free
+478 Jun 25 04:02 PM M BALA BCH, PL
+479 Ju 25
+04:45 IN M PALE ECH, FL
+4B0 Jun 25 04:46 PM Inconieg
+481 Jun 25 05:00 IN M BALK BCH, PL
+452 Jun
+06:48 PM N PALA BCH, PL
+483 Jun 25 07:20 # 1 PALE BCH, FL
+454 Jun 25
+07:27 PM M BALK BCH, PL
+485 Jun.
+07:28 PM Incoming
+450 un258:21 Inconley
+487 Jun 25 08:22 PM M PALA BCH, PL
+488 Jun 25 08:25 N InconleT
+480 Jun 25 08128 EN Inconleg
+Min:Sec
+1,00
+Usage
+4.00
+561-686-4123
+PP/CW/FU
+561-255-1391
+561-255-1391
+PP/FU
+561-596-9528 PP/FU
+561-714-2981
+FF/FU
+561-129-8090
+1100
+1:00
+1:00
+1:00
+4.DD
+0.0D
+$.00
+561-714-2981 PP/FU
+561-686-4123
+PP/FU
+561-577-4709
+OF/FU
+561-577-4709 OP/FU
+561-577-4709 OP/PU
+561-577-4709 OP/SU
+561-577-4709 0P/P0
+561-599-1909 00/80
+•.5E
+3:00
+2:00
+1:00
+1:00
+1:00
+4.00
+0.0D
+1:00
+14:00
+561-714-2981
+561-577-4709
+561-324-7931
+561-227-3000
+561-436-2336
+561-714-2981
+561-714-2981
+561-124-2921
+OP/PU
+1:00
+1:00
+PP/PU
+PP/FU
+PP/FU
+PP/PU
+561-324-7931
+FF /FU
+800-421-3347 P9/90
+561-324-7991
+PP/FU
+561-309-5958
+PP/FU
+561-577-4709
+800-421-3347
+PP/FU
+561-541-7519 PP/FU
+561.714.2081
+FF/FU
+561-309-5958
+PP/CN/PU
+561-714-2981
+PP/NS/FU
+561-124-7931
+PP/PU|
+5E1_202_628g
+PP/FU
+561-432-2930
+PP/FU
+561-432-2930
+PP/FU
+561-255-1391
+561-255-1391
+P/PO
+561-309-5958
+PP/FU
+561-255-1391
+PP/FU
+Do jett
+1:00
+1:00
+4:00
+3,00
+1:00
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+2:00
+5:00
+2:00
+0.0D
+•.00
+9,00
+$.00
+0.0D
+2.00
+5:00
+1:00
+1:00
+1: 0a
+3:00
+0.0D
+•.00
+0.0D
+•.00
+- •r
+1:00
+3:00
+•.00
+$.00
+1:00
+Long
+Distance
+D.D0
+n. .f0
+D.DD
+D .00
+D.DD
+0.00|
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.D0|
+n an
+corticued.
+Total
+Charges
+9.00
+a.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+Account number 747607414
+(561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Footnote
+Min: Sec
+Item # Date Time CallTo
+491 Jun 25 08:47 PM BOYTONBCH, PL
+492 Jun 25 08:52 IM Inconing
+43 Jun 25 09:00 PM W FALA RCH,PL
+494 Jun 25 09:14 PM BOYTONBCH, PL
+495 Jun 25 09:15 BOTCH, L
+N9d Jun 25 09:16 W Inconing
+497 Jun 25 09:19 PM N FALK BCH, PL
+498 Jun 25 09:20 PM Inconing
+490 Jun 25 09:23 IN N FALM BCH, PL
+500 Jun 25 09:26 PM Inconing
+501 Jun 25 09:35 PM W PALM BCH, PL
+502 Jun 25 09:36 PM N FALM BCH, PL
+503 Jun 25 09:36 IN N PALA BCH, PL
+504 Jun 25 09:39 PM N FALK BCH, PL
+506 Jun 25 09.39 PM W PALM BCH, PL
+Jun 25 08:43 IM N PALM BOH, PL
+Jun
+09:48 IN W PALA BCH ,PL
+25 10:06 EM Incondng
+509
+Jun
+25 10:21 m Inconleg
+510
+Jun
+11:09 IN W PALM BCH ,PL
+511 Jun 25 11:30 PM Inconing
+512 Jun 25 11:52 EM W FALM BCH,PL
+513 Jun 26 12:58 AM BOZINDCH, PL
+514 Jun 26 01:00 AM N PALM BCH ,PL
+515
+Jun
+26 01:00 AM BOYTONBCH, PL
+518
+Jun 26 01:06 AM W PALM BCH,PL
+Jun 26 09:26 AM N PALM BCH ,PL
+518
+519
+12:09 PM BOYTONECH, PL
+01.04 EM W PRIM BCH ,PL
+521
+01:49 IM BOETONBCH, PL
+Jun
+26 03:37 PM N PAEN BCH,PL
+573
+Jun
+54. 0E IM Incordng
+26 04:12 PM N FALA RCH, PL
+Jun
+578
+Jun
+04:22 PM W FALK BCH,PL
+05:39 PM Incondag
+20 05:44 IN A FALA RCH, PL
+528
+Jun
+26 05:51 IM Incoring
+Jun
+07:06 PM N PALK BCH,PL
+Jun 26 08:06 EM Incondng
+531
+08:50 IN BOTONCH, PL
+Number
+561-577-4709
+PP/NN/FU
+561-662-6668
+PD/PU
+561-202-5246 CP/FU
+561-577-4709 0P/PU
+561-577-4709 0F/FU
+561-704-4978
+561-309-5958
+DE /FU
+561-309-5958 0P/PU
+5E1-432-2930
+DE /FU
+561-309-5954 DE/FU
+561-309-5958 CP/PU
+SE1-109-5958 DE/FU
+561-309-5958 0D/PU
+561-309-5958 CE/FU
+561-309-5958
+0P/PU
+5E1-309-5958 0B/FU
+561-309-5958
+0P/PU
+561-432-2930
+OP /pu
+561-202-928E OB/FU
+561-714-2981
+0P/PU
+561-432-2930 CE/FU
+561-714-2941 08/PU
+561-STT-499D
+De /Fu
+561-329-8070 00/PU
+561-577-4990
+DE/FU
+561-329-4070 08/PU
+561-324-7931 0D/PU
+561-577-499D
+CE /FU
+561-940-0632
+De /PU
+561-1T]-499D
+ce /FU
+561-737-3103 00/PU
+561-324-7931 CE/FU
+561-577-4709
+ce/pu
+561-CE2-30DE OF/FU
+561-324-7931 CE/FU
+561-309-5958
+OP /PU
+561-141-7519 00/FU
+561-963-5900
+0P /PU
+561-432-2938
+Ge /FU
+561-309-5958
+OP /PU
+5:00
+2: 00
+2:00
+1:00
+1100
+3:0D
+1,00
+1:0D
+1:00
+1:0D
+1,00
+1:0D
+2:00
+2,00
+2:00
+1:00
+2:00
+2:00
+$100
+2:00
+2,00
+3: 0D
+1:00
+3: 00
+1,00
+Usage
+6.08
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+(561) 662-3098 continued..
+Telecommunications Services Call Detail (561) 662-3098
+See
+Number
+Footnote
+Item # Date Time Call To
+532 Jun 26 08158 PM BOYTONECH. FL
+533 Jun. 26 08:58 IN BOYZONECH, PL
+534 Jun 26 09109 PN M PALK BCH, PL
+535 Jun 26 09:47 EM Inconing
+536 JuL 26 11:30 IN M PALE BCH, FL
+537 Jun. 26 11:31 IN • PALA BCH, PL
+538 Jun 26 12:35 PM M BALK BCH, PL
+530 Jun 26 11,55 PM BOYTONBCH, FL
+540 Jl 27 01:04 J M BALE BCH, VL
+541 Jun 27 03124 AN M PALK BCH, PL
+542 Jun 27 02/25 AN Inconing
+543 Jul. 27 02:42 A Incoeleg
+544 Jun. 27 03:09 AM Incoming
+545 Jun 27 10:49 AN Incoming
+546 Jun 27 01,25 PM M PALA BCH, PL
+547 Jul. 27 02:07 WN M PALE BCH, FL
+545 Jun. 27 03:28 IN I PALA BCH, PL
+549 Jun 27 03,32 IN Inconing
+550 лив 27 03:37 1nclay
+551 Jun. 27 05:17 PM Inconley
+552 Jun 27 05:40 PM M PALE BCH, PL
+553 Jun 27 O6132 PM Incoming
+554 JuR 27 D8:49 IN M PALE BCH, FL
+555 Jut 27 08:54 PM M PALA BCH, PL
+550 Jun 27 10:05 IN IncomiNg
+557 Jun 27 10:07 PM M BALA BCH, PL
+558 Jun 27 10:11 PM M PALK BCH, PL
+550 Jun 24 28:40 AN M BALS BCH, PL
+560 Jun 24 11:26 JM Inconing
+581 Jun 28 03:02 IN M PALE BCH, FL
+Jun 24 04:27 PM Inconlet
+563 Jun 24 04:49 PM BALE BCH, PL
+584 Jun 24 05/16 EN Inconing
+585 Jun 28 05:22 IN M PALE BCH, PL
+580 Jum 24 05:27 М Ініт
+587 Jun 24 06:01 EN Inconing
+568 Jun 24 D6:07 PM M PALE CH, FL
+569 Jun 24 06:22 PM M PALA BCH, PL
+570 Jun 24 06:43 PM M BALE BCH, PL
+571 Jun 24 06148 IN MANA BCH, PL
+572 JuN 24 06:54 IN M FALK BCH, PL
+561-577-4709 OP/FU
+561-577-4709
+561-541-7519 OP/FU
+561-541-7519 OP/FU
+561-255-1391 OF/FU
+561-129-8090
+561-577-4990
+561-202-5286
+OF/FU
+561-596-7295
+561-59E-7295 OP/SU
+561-718-7578
+561-214-2981 00/80
+561-662-3098
+561-324-7931
+561-324-7931
+561-963-5534
+561-255-D431
+OP/PU
+OP/PU
+OP/PU
+561-541-7519
+561-541-7519
+561-181-6961
+op/PU
+561-662-3098
+561-541-7519
+OP/PU
+561-541-7519
+561-324-7931
+OP/PU
+561-541-7519
+OP/PU
+561-352-7000
+PP/FU
+PP/FU
+561-478-4188
+561-324-7931
+561-309-5958
+561-662-6688
+561-109-5958
+561-714-2981
+561-309-5958
+561-324-7931
+561-723-8391
+561-541-7519
+561-324-7931
+PP/FU
+PP/PU
+PP/FU
+PP/PU
+PP/FU
+PP/FU
+PP/FU
+PE/FU
+P/PO
+PP/FU
+PP/FU
+PR/FU
+Min:Sec
+1,00
+3:00
+2100
+4:00
+1:00
+3:00
+1:00
+2:00
+2:00
+1:00
+1:00
+5100
+1:00
+1:00
+3.00
+7=00
+2:00
+1,00
+4.00
+3: 00
+2:00
+2:00
+1:00
+3:00
+2:00
+1: 00
+4:00
+1:00
+2:00
+1: 0a
+4:00
+1:00
+1:00
+2:00
+1:00
+Usage
+4.00
+• DE
+0.0D
+$.00
+•.0D
+4.00
+0.0D
+8.00 |
+0.0D
+0.0D
+0.0D
+$.5B
+$.00
+0.0D
+•.00
+9,00
+$.00
+0.0D
+$.00
+0.0D
+•.00
+0.0D
+•.00
+0.0B
+•.00
+$.00
+Long
+Distance
+D.D0
+D.DD
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.00 |
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+(561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Item # Date Time CallTo
+Number
+Footnote Min: Sec
+573 Jun 28 07:24 PM Incordng
+561-714-2941
+PP/PU
+2:00
+574 Jun 28 07:28 IM Incoring
+561-383-6763
+PD/CH/PU
+2:00
+575 Jun 28 07:30 PM W FADE RCH, PL
+561-714-2941 FF/FU
+• : 00
+578 Jun 28 07:34 EM W PALM BCH PL
+561-662-3098 PP/PU
+1,00
+577 Jun 28 07:39 PM N FALA BCH, PL
+561-662-309E FF/FU
+1:00
+578
+Jun 28 07:43 IM N PALM BCH, PL.
+561-705-3454
+579 Jun 28 07:55 PM Inconing
+580 Jun 28 04:03 EM Incondag
+581 Jun 28 08:18 IN N FALM BCH, PL
+582 Jun 28 04:44 PM Inconing
+583 Jun 28 04:47 PM W PALA BCH,PL
+584 Jun 28 c8:55 PM Inconleg
+385 Jun 28 09:01 IM W PALM BCH, PL
+588 Jun 28 09:06 PM N FALK BCH,PL
+Jun 28 09,06 PM W PALM BCH ,PL
+Jun 28 09:08 IM N PALA BO,PL
+Jun
+09:09 IN W PALA BCH ,PL
+28 09.10 EM W PALM BCH, PL
+Jun
+28 09:13 PM Incolng
+Jun
+Inconing
+583 Jun 28 09:22 PM Inconing
+Jun 28 09,23 PM N PALM BC,PL
+506 Jun 28 02:26 IN N PALM RCH, PL
+Jun 28 09:31 IM N PALM BCH ,PL
+597
+Jun
+:
+09:37 PM Inconing
+Jun 28 09.34 EM Incondng
+Jun 28 09:41 PM Inconing
+800
+Jun
+:
+09:42 PM N FALM BCH ,PL
+602
+603
+09:52 PM Inconlag
+10:01 IM Incoring
+Jun
+:
+10:30 PM N PAEN BCH, PL
+805
+Jun
+10:49 EM N PALM BCH, PL
+28 11:00 PM N FALA RCH, PL
+607
+Jun
+28 11:00 PM N PALM BCH,PL
+808
+Jun
+11:01 PM W PALA BCH,PL
+609
+Jun 28 11:12 PM Inconing
+610
+Jun
+2e 11:14 IM Incoring
+฿11
+Jun
+28 11:35 PM N PALM BCH,PL
+817
+Jun 28 11:22 EM W PALM BCH ,PL
+813
+11:33 PM Incorina
+561-383-6763
+561-474-5222
+pP /PU
+5E1-432-2930
+561-478-5222
+561-309-5958 PP/PU
+5E1-371-1DE4 FF/FU
+561-309-0412 0D/PU
+561-758-9139 CB/FU
+561-721-5959 CP/PU
+561-432-2930 O0/FU
+561-758-9139 00/PU
+561-255-6426
+OP /pu
+561-432-2930 OB/FU
+561-255-6826 00/PU
+561-255-6826 CE/FU
+561-309-5958 OP/pU
+561-129-8070 OF/FU
+561-329-8070 00/PU
+561-541-7519 CP/PU
+561-329-9070 08/cw/FU
+561-309-0412
+0P/PU
+561-329-8078
+DE / FU
+561-541-7519 CP/PU
+561-308-5958 CE/CN/FU
+561-309-5958
+0e /PU
+561-255-3391 CE/PU
+561-309-5958 08/PU
+561-309-5958 CF/FU
+561-309-5958 CE/FU
+561-309-5954 OP/PU
+161-109-5958 CB/FU
+561-309-5958 00/PU
+561-596-9528
+De /FU
+561-596-9528
+OP /PU
+3:00
+2100
+8: 0D
+3:0D
++:00
+2:00
+1:00
+2,00
+1:0D
+1:00
+2,00
+2:00
+1,00
+4: 0D
+1:00
+2:00
+3: 00
+1:00
+1,00
+1:00
+1,00
+2:00
+1:00
+4: 00
+Usage
+6.08
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+0. 65
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+(561) 662-3098 continued..
+Telecommunications Services Call Detail (561) 662-3098
+See
+Number
+Footnote
+Item # Date Time Call To
+814 Jun 24 11:57 PM Inconing
+015 Ju. 29 12:11 AM Inconieg
+816 Jun 29 12:23 AN M PAL BCH, PL
+817 Jun 29 12127 3M M BALK BCH, FL
+618 Jшт 29 01:43 3 M PALE BCH , FL
+019 Jun. 29 12:21 IN • PALA BCH, PL
+820 Jun 29 12:22 PM M BALK BCH, PL
+821 Jun 29 12/25 EM Inconleg
+Jun 29 01:17 IN Incoeleg
+823 Jun 29 03,30 PM M PALK BCH, PL
+824 Jun 29 02/13 PM Inconleg
+625 Jul 27 04:0D N M PALE BCH, VL.
+625 Jun. 29 08:01 PM 5 PALA BCH, PL
+827 Jun 29 08:40 IN M BALE BCH, PL
+828 Jun 29 08,49 PM M PALA BCH, PL
+829 Ju 27 08:11 W BOTTONCH, VL.
+630 Jun. 29 09:51 IN Incoming
+831 Jun 29 09,57 PM M PALA BCH, PL
+632 all 20 10:53 Inceled
+633 Jun 29 11:29 PM 5 DALK BCH, PL
+834 Jun 30 09:55 AN I BALE BCH, PL
+835 Jun 30 09,56 ЛМ И PA BCH, PL
+635 JuL 30 08:58 AN M PALE BCH, FL
+637 Jun 30 10:06 AM INcORieT
+638 Jun 30 18:43 AN M BALE BCH, PL
+830 Jun 30 10:49 AM Inconing
+640 шп. 30 10:56 М Інсовіет
+641 Jun 30 10:58 AN Incoming
+842 Jun 34 02123 PM M BALA BCH, PL
+643 Ju 30 01:14 IN M PALE BCH, FL
+644 Jun 30 01:37 PM BOYTONBCH, PL.
+645 Jun 30 02:49 М Іксіт
+846 Jun 30 02121 EN Inconing
+647 JuR 30 03:02 M PALE BCH, FL
+845 Jun 30 03:05 #N Inconley
+840 Jun 30 03/26 IN M BALA BC, FL
+50aua10 10 m Inconley
+651 Jun 30 03:37 PM M PALA BCH,PL
+524100337 MACH, PL
+853 Jun 34 03145 IN M BALK BCH, FL
+654 Jun 30 03:54 #N Inconley
+561-383-6763
+561-255-6826
+561-309-5958
+561-596-9528 OP/FU
+561-324-2512
+OF/FU
+561-665-66RA
+561-898-18
+561-478-4188
+561-478-4168
+PP/FU
+PP/FU
+FP/FU
+561-478-4188
+561-383-6763 PP/PU
+561-383-67E3 PP/SU
+561-324-7931 P/P0
+5E1-511_2519 PP/0
+561-541-7519
+561-577-4709
+561-582-9982
+561-541-7519
+561-541-7519
+561-662-3098
+561-662-3098
+5E1-478-418R
+PP/PU
+OP/PU
+PP/FU
+PP/PU
+PP/FU
+561-478-4188
+561-478-4188
+561-324-7991
+PP/FU
+561-577-4709 PP/PU
+561-324-7931
+561-324-7991
+PP/FU
+561-541-7519
+PP/PU
+561.183-6261
+PP/FU
+561-577-4709
+561-432-2930
+PP/FU
+561-183-6763
+PP/PU
+561-255-1391
+PP/FU
+561-255-1391
+PP/FU
+561-309-5958
+PP/FU
+561-383-67E3 FP/FU
+561-309-5958
+p/PO
+561-309-5958
+PP/FU
+561-309-5958
+PP/FU
+82T41530
+Min:Sec
+1,00
+1100
+1:00
+1:00
+1:00
+2:00
+2:00
+2:00
+3:00
+1:00
+2:00
+1:00
+4: 00
+30:00
+3:00
+1.00
+1.00
+1:00
+2:00
+3:00
+1:00
+1:00
+2:00
+2:00
+2:00
+2:00
+1: 0a
+2:00
+1:00
+1:00
+1:00
+1:00
+Usage
+4.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+8.50 |
+• 0[
+0.0D
+•.00
+9,00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.D0|
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+Account number 747607414
+(561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Item # Date Time CallTo
+Number
+Footnote
+Min: Sec
+955 Jun 30 04:12 EM N PALM BCH, PL
+561-432-2930
+PP /PU
+3:00
+050 Jun 30 04:56 IM Inconing
+561-541-7519
+PD/PU
+3:00
+857 Jun 30 04:21 PM N FALK BCH,PL
+561-255-1391 FF/FU
+1: 00
+058 Jun 30 09:25 EM Incoring
+561-255-1391 PP/PU
+3:00
+850 Jun 30 09:31 PM N FALA BOH, PL
+561-255-1391
+2:00
+050 Jun 30 09:38 IN N PALM BCH, PL
+561-541-7519
+1:00
+051 Jun 30 09:44 PM N FALK BCH, PL
+561-541-7519
+De /FU
+1100
+082 Jul 01 12:54 AM BOYTONBCH, PL
+561-577-4709
+3,00
+083 Jul 01 01:01 AM
+BOTONaCH , Pu
+5E1-577-4709
+DE /FU
+3: 0D
+084 Jul 01 01:03 AM N FACE BCH,PL
+S61-541-7519 CE/FU
+13:00
+085 Jul 01 01:24 AM W PALM BCH,PL
+561-541-7519 CP/PU
+1,00
+050 Jul 01 01:31 AM Incoring
+5E1-341-7519
+De /FU
+2:00
+067 Jul 01 09:30 AM Inconing
+561-963-5534 PD/PU
+4: 00
+088 Jul 01 11:03 AM Inconing
+561-202-5286 FF/FU
+3: 0D
+08Q Jul 01 12:33 EM Inconing
+561-309-5954
+Pe /PU
+2:00
+670 Jul 01 01:33 PM Incoring
+5E1-478-418E FD/FU
+1:0D
+Jul
+01:51 I Incoming
+Unavailable
+PD /PU
+1:00
+672
+Jul 01 01.54 EM W PALM BCH, PL
+561-352-7000 FP/PU
+2,00
+673
+Jul 01 01:55 IN Incondag
+unava 11 able
+2:00
+01 01=57 IM N PALM BCH ,PL
+561-352-7000 PD/PU
+2:00
+875 Jul 01 02:02 PM Inconing
+561-714-2981 FF/FU
+4: 0D
+878
+Jul 01 02154 PM Inconing
+561-432-2930 PP/PU
+2,00
+Jul 01 04:24 PM Inconing
+561-141-6131 FF/FU
+678 Jul 01 05:24 I Incoring
+561-714-2981 PD/PU
+Jul
+01 06:26 PM BOYTONBCH, PL
+561-577-4709 FF/PU
+Jul 01 09.26 EM W PALM BCH,PL
+561-541-7519 08/PU
+681 Jul 01 09:35 IN N PALM BCH,PL
+561-432-2930 00/PU
+Jul
+09:44 PM Inconing
+561-541-7519 CP/CN/FU
+11:00
+2:00
+Jul 01 10:35 EM N PACM BCH,PL
+561-541-7519 CP/PU
+684
+Jul
+10:20 IN N PALM RCH, PL
+561-114-2981 CE/FU
+685
+Jul
+12:20 AM Incoring
+561-432-2930 00/PU
+686
+Jul 02 01:01 AM N PAEN BCH,PL
+561-541-7519 CE/FU
+887
+Jul
+01:03 AM Incondug
+561-541-7519 08/PU
+1:00
+7,00
+Jul 02 08:13 AM BORTONACH, PL
+561-377-4708 FD/FU
+689
+Jul 02 04:30 AM W PALM BCH, PL
+561-541-7519 FF/FU
+1:00
+800
+Jul
+09:43 AM Incondug
+561-951-7766 PP/PU
+1,00
+561-377-4709 FD/FU
+1:0D
+Jul 02 09:13 AM BOYTONBCH, PL
+561-573-4709 PD/PU
+1:00
+Jul
+09:27 AM N PALM BCH,PL
+561-714-2541 FP/FU
+Jul 02 09,52 AM BOLTONBCH, PL
+561-577-4709
+PP/PU
+I: 0D
+Usage
+6.08
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+(561) 662-3098 continued..
+Telecommunications Services Call Detail (561) 662-3098
+See
+Number
+Footnote
+Item # Date Time Call To
+808 Jul 02 11147 3M BAL BCH, FL
+697 Jul 02 11:52 AM Inconing
+88$ Jul 02 12:54 3N M RALE BCH, PL
+800 Jel 02 11,57 AM Incoming
+700 Jul 02 12:21 It Incoeleg
+701 Jul 02 12:38 IM Inconing
+702 Jul 02 02:36 IN IncOmiNg
+703 Jul 02 02:53 PM BOYTONBCH, FL
+704 Jul 02 04:30 IN Incoeleg
+705 Jul 02 05:16 EN Incoming
+708 Jul 02 05125 PM M PALA BCH, PL
+707 Jul 02 05:35 IN Iscoeleg
+7OS Jul 02 07:26 IM M PALE BCH, PL
+709 Jul 02 07:30 IN M BALE BCH, PL
+710 Jul 02 07,52 EN Inconing
+711 Jul 02 D8:12 WN M PALE BCH, FL
+712 Jul 02 08:24 PM M PALA BCH, PL
+713 Jul 02 08,28 PM M PALA BCH, PL
+714 Jul 02 D8:30 IN BOTTONCH, FL
+715 Jul 02 08:41 PM 5 DALK BCH, PL
+716 Jul 02 08:42 PM M PALE BCH, PL
+717 Jul 02 08,52 PM M PATE BCH, PL
+718 dul 02 08:22 W Incaleg
+719 Jul 02 09:31 PM M PALA BCH, PL
+720 Jul 02 09:33 IN Incoming
+721 Jul 02 09,33 PM M BALA BCH, PL
+722 Jul 02 09:35 PM M PAL BCH, PL
+723 Jul 02 09:40 PM M PALE BCH, PL
+724 Jul 02 10:10 PM M BALA BCH, PL
+726 Jul 02 10:18 IN Inconing
+727 Jul 0210:20 PM IniT
+728 Jul 02 10:46 IN M BALA BCH, FL
+206l02 10:47 Inchelag
+730 20l 02 10:58 МІніт
+731 Jul 02 11,38 EN Inconing
+732 Jul 02 11:52 IN Incoleg
+733 Jul 62 11:58 PM M PALA BCH,PL
+734 Jul 02 13,59 М Ініт
+735 Jal 03 12:06 JM BAL BCH, FL
+738 Jul 03 12:10 AN U FALK BCH, PL
+Min:Sec
+2:00
+561-966-7883 PP/FU
+Unavailable
+561-966-7883 PP/NN/FU
+Unsva11ab1e
+PP/FU
+Unava 11 able
+PP/FU
+Unavailable
+614-283-6500 PP/PU
+561-577-4709 PP/FU
+561-714-2981
+PP/FU
+561-951-7766 PP/FU
+561-541-7519 PP/PU
+561-714-29E1 PP/SU
+561-255-1391 PP/P0
+5E1_255-1391 PP/80
+PP/PU
+PP/FU
+561-718-7578
+561-255-0431
+561-255-0431
+561-577-4990
+561-255-0431
+561-718-7578
+561-662-3098
+561-255-1391
+561-718-7578
+561-676-6963
+561-676-6963
+561-541-5183
+561-129-8070
+PP/PU
+PP/FU
+PP/FU
+PP/PU
+OP/PU
+Op/FU
+OP/PU
+OF/FU
+OF/FU
+561-255-1391
+561-255-1391
+561-676-8767
+561-676-8767
+561-E7E-#767
+561-493-3016
+561-541-5183
+561-577-4390
+561-676-8767
+
+OP/PU
+Op/PU
+DE/FU
+1100
+4:00
+1:00
+2:00
+12:00
+1:00
+3:00
+1:00
+2:00
+1:00
+2:00
+5:00
+1:00
+3:00
+1:00
+2:00
+1:00
+1:00
+1:00
+1:00
+1:00
+2:00
+1:00
+1:00
+1:00
+2:00
+1:00
+1: 0a
+OP/CN/FU
+5:00
+2:00
+4:00
+3:00
+4:00
+1:00
+Usage
+4.00
+4.DD
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.D0|
+п nn
+corticued.
+Total
+Charges
+9.00
+9.00
+a.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+Account number 747607414
+(561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Item # Date Time CallTo
+Number
+Footnote
+Min: Sec
+737 Jul 03 12:15 AM Incordng
+561-541-7519
+Ge /FU
+3:00
+738 Jul 03 12:48 AM N PALM BCH, PL
+561-541-7519
+0e /PU
+2:00
+730 Jul 03 01:11 AM Inconing
+561-541-7519 CP/FU
+9:00
+740 Jul 03 10:01 AM N PALM BCH ,PL
+561-541-7519 0P/PU
+1,00
+741 Jul 03 10:02 AM Inconlog
+561-141-7519 OF/FU
+4: 0D
+742 Jul 09 04:47 IM W PALM BCH ,PL
+561-662-6688
+CD IDI
+4, 06
+743 Jul 03 06:19 PM Inconing
+561-541-7519
+2:00
+744 Jul 03 06:59 PM Inconing
+561-541-5143
+OP /PU
+6:00
+745 Jul 03 09:01 IN N FALM BCH "PL
+5E1-ETE -#TET
+DE/FU
+1:0D
+748 Jul 03 09:14 PM Inconing
+561-676-8767
+747 Jul 03 09:28 PM A PALA BCH.PL
+561-541-7519 CP/PU
+2,00
+748 Jul 04 12:12 AM N PALM BC, PL
+5E1-341-7519 DE/FU
+1:0D
+749 Jul 04 12:13 AM N PALM BCH, PL
+561-541-7519 0D/PU
+2:00
+750 Jul 04 12:34 AM Inconing
+561-427-2542 CP/FU
+2:00
+751 Jul 04 12:39 AM Incondng
+561-541-7519 CP/CN/FU
+752 Jul D$ 12:20 AM N PALA RCH, IL
+5E1-827-2542
+De /Fu
+2:00
+Jul 04 12:23 AM W PALM BCH ,PL
+561-309-5958
+0P /PU
+1:00
+754 Jul 04 01,34 AM W PALM BCH,PL
+561-541-7519 08/pU
+755 Jul 04 11:16 AM N PALM RCH, PL
+561-255-1391
+Jul 04 11:18 AM W PALM BCH ,PL
+561-662-3098
+0P/PU
+757 Jul 04 11:20 AM N PALM RCH,PL
+561-714-2981 CE/FU
+758 Jul 04 11/33 AM N PAM BCH, ,PI.|
+561-676-4767 0P/pU
+750 Jul 04 11:37 AM N FALA RCH, PL
+561-714-2981 CE/FU
+2:00
+14:00
+$100
+5: 0D
+700 Jul 04 11:41 AM Incoring
+561-432-2930 00/CH/PU
+781 Jul 04 11:43 AM Inconing
+561-476-4767
+GF/CH/FU
+1:00|
+782 Jul 04 11:46 AM N PALM BCH,PL
+561-676-4767 08/PU
+M3 Jul 04 11:53 AM N PALM BCH,PL
+561-432-2930 00/PU
+764 Jul 04 12:04 PM Inconing
+561-714-2981 CP/FU
+1:00
+21:00
+78S Jul 04 12:41 PM N PALM BCH,PL
+561-676-9767
+0P/PU
+766 Jul 04 12:64 IN N PALA BCH, PL
+561-114-2981 CE/FU
+9: 00
+767 Jul 04 01:16 IM Incoring
+561-432-2930 00/PU
+788 Jul 04 01:23 PM Inconing
+561-255-3391 CE/PU
+78Q Jul 04 01:39 PM Incondug
+561-676-4767 08/PU
+2:00
+2,00
+770 Jul 0a 02:47 PM Inconing
+561-255-1391
+771 Jul 04 02:06 IN PALA BCH.PL
+561-255-3391 CE/FU
+1:00
+772
+Jul 04 02:40 PM Incondug
+561-676-4767 0P/PU
+773 Jul 04 03:42 IN N FALM NCH. UL
+561-062-3058 CB/FU
+774 Jul 04 09:43 IN W PALM BCH. PL
+561-662-6688 00/PU
+775 Jul 04 03:43 PM N PALM BCH, PL
+561-662-6648
+Ge /FU
+1:0D
+1:00
+3:00
+776 Jul 04 05:30 EM W PALM BCH ,PL
+561-676-4767
+777 Jul 04 05:31 PM N FALM RCH, PL
+op /FU
+I: 0D
+Usage
+6.08
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+0.00 |
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+(561) 662-3098 continued..
+Telecommunications Services Call Detail (561) 662-3098
+See
+Item # Date Time Call To
+778 Jul 04 DE106 PM M BALK BCH, FL
+779 Jul 04 06:29 PM I DALM BCH, PL
+750 Jul 04 D6131 PM M PALE BCH, PL
+781 Jul 04 06132 PM M BALK BCH, FL
+782 Jul 04 D6:3E IN M PALE BCH, FL
+763 Jul 04 06:37 IM • PAL BCH, PL
+754 Jul 04 D6:38 PM M BALK BCH, PL
+785 Jul 04 06139 PM M BALK BCH, FL
+785 Jul 04 DE:4D IN M PALAC BCH, PL
+787 Jal 04 D6141 PM M PALK BCH, PL
+788 Jul 04 D6142 PM M PALA BCH, PL
+789 Jul 04 DE:51 IN M PALE BCH, VL.
+790 Jul 04 06:56 IM M PALE BCH, PL
+791 Jul 04 D6:59 PM M PALE BCH, PL
+702 Jul 04 07,03 PM M PALA BCH, PL
+793 Jal 04 07:39 WN M PALE BCH, FL
+794 Jul 04 08:03 IN Inconieg
+705 Jul 04 08/14 IN Inconing
+795 Jul 04 D8:22 IN M PALE BCH, PL
+797 Jul 04 08:34 PM Iscoeleg
+795 Jul 04 08:45 PM M PALE BCH, PL
+700 Jul 04 08:49 PM Incoming
+BDO Jul 04 10:56 IN M PALE BCH, FL
+801 Jul 04 11:01 PM M PALA BCH, PL
+802 Jul 04 12:26 PM M PALE BCH, PL
+803 Jul 05 10,58 AM M BALA BCH, PL
+804 Jul 05 11:02 AM M PALE BCH, PL
+805 Jul 05 12:32 AM Incoming)
+606 Jul 05 12:00 PM M BALA BCH, FL
+B07 Jul 03 12:41 IN M PALE BCH,L
+Jul 05 12:43 PM 5 PALK BCH, PL
+809 Jul 0512:46 PM InnieT
+810 Jal 05 12:50 PM Inconleg
+811 Jul 03 01:01 Inteleg
+812 Jul 05 02:08 Інопіт
+813 Jul 05 02,36 PM M BALA BCH, PL
+814 Jul 0305:26 INCEL
+B15 Jul 05 06:07 PM M PALA BCH,PL
+Number
+Footnote
+Min:Sec
+Usage
+561-255-1391
+1,00
+4.00
+561-714-2981
+561-714-2981 OP/FU
+1100
+• DE
+561-790-3459 OP/FU
+2:00
+561-255-1391 OF/FU
+1:00
+0.0D
+561-696-8962
+2:00
+$.00
+561-714-2981
+1:00
+•.5E
+561-714-2981
+1:00
+4.00
+561-714-2981
+OF/FU
+1:00
+561-714-2981
+1:00
+561-352-5163 OP/PU
+1:00
+561-E7E-8767 OP/SU
+2:00
+0.0D
+561-255-1391 0P/PU
+8.00 |
+5E1_255-1391 00/80
+1:00
+0.0D
+561-324-7931
+OP/PU
+4:00
+561-676-8767
+1:00
+0.0D
+561-432-2930
+OP/PU
+1:00
+561-676-8767
+OP/PU
+2100
+561-255-1391
+1:00
+0.0D
+561-714-2981
+2:00
+561-255-1391
+1.00
+$.5B
+561-255-1391
+op/PU
+2:00
+• 0[
+561-714-2981
+2:00
+561-541-7519
+OP/PU
+561-714-2981
+1:00
+561-714-2981
+PP/PU
+3,00
+2:00
+561-541-7519
+PP/FU
+3:00
+0.0D
+•.00
+9,00
+0.0D
+561-541-7519
+PP/FU
+2:00
+0.0D
+561-714-2981
+PP/PU
+2:00
+561-714-2981
+PP/FU
+2:00
+•.00
+561-714-2981
+PP/PU
+3,00
+561-432-2930
+PP/FU
+J:0a
+0.0D
+561-714-2981
+PP/FU
+•.00
+561-714-2981
+PP/FU
+1:00
+561-827-2542
+1:00
+- •r
+561-676-8767
+P/PO
+3:00
+561-676-8767
+PP/FU
+2:00
+•.00
+817 Jel 05 06157 EM Inconleg
+561-676-8767
+$.00
+818 Jul c3
+07: 04 IN Incceled
+
+1:00
+Long
+Distance
+D.D0
+D.DD
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.D0
+D.DD
+0.00 |
+0,00
+D.D0
+• DO
+• on
+0.00 |
+n an
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+corticued.
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+(561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Footnote
+Item # Date Time CallTo
+819 Jul 05 07:32 PM N PALM BCH ,PL
+020 Jul 05 07:56 IM N PALM BCH, PL
+821 Jul 05 04:01 PM Inconing
+822 Jul 06 12:2+ AM N PALM BCH,PL
+B23 Jul DE 04:48 PM Inconlog
+B24 Jul 06 05:54 IN Incoring
+825 Jul 06 06:39 PM Inconing
+828 Jul 06 07,05 EM W PALM BCH.PL
+827 Jul DE 07:29 IN Inconing
+828 Jul 06 08:11 PM Inconing
+829 Jul 06 09:14 PM W PALM BCH,PL
+830 Jul DE 08:20 # Inconing
+831 Jul 06 09:02 IM W PALM BCH, PL
+832 Jul 06 09:26 PM N FALK BCH, PL
+833 Jul 07 07,04 AM W FALM BCH,PL
+Jul 08
+12:44 AM W PALM BCH ,PL
+Jul 08 12:53 AM W PALM BCH, PL
+837
+Jul De 11:07 AM CUREDENE CHEa
+838
+Jul
+11:98 AM Inconing
+830 Jul 08 12:03 PM Inconing
+840 Jul 08 12:07 PM Inconing
+841 Jul De 12:15 PM Incondug
+842 Jul 08 12:19 PM Incoring
+Jul
+12:21 PM Inconing
+844 Jul 08 12:49 PM Inconing
+845
+Jul 08 01:05 PM Incoring
+Jul
+00:42 PM Inconing
+847
+03.31 PM Incondng
+848
+Jul
+na
+03:19 PM Inconleg
+649
+Jul
+09:20 IN W PALM BCH, PL
+g
+Jul 08 03:24 PM Inconing
+B51
+03:30 PM Incondng
+Jul 0e 05:14 PM Inconing
+Jul
+06:25 PM Incondng
+Jul 0e 07:10 PM M FALO BCH.UL
+Jul 08 07:11 PM W PALM BCH,PL
+Jul 08 07:13 PM N PALM BCH, PL
+858 Jul 08 07:20 EM W FALM BCH, PL
+1.1 na
+07:34 PM Incorina
+Number
+561-676-4767
+PP/FU
+561-676-4767
+PD/PU
+561-676-4767 FF/FU
+561-714-2981 OP/PU
+561-6TE-#TE7 FF/FU
+561-714-2981
+PP /NN/ PU
+561-329-8070
+Fe /FU
+561-676-4767
+PP/PU
+5E1-432-2930
+FE /FU
+916-728-5878 FE/FU
+561-714-2941 PP/PU
+SEL-ETE-#TET FF/FU
+561-676-4767 0D/PU
+5EL-432-2930 CE/PU
+561-662-3054 PP/PU
+5E1-6E2-309E FD/FU
+561-714-2981 00/PU
+561-662-3098
+OP /pu
+#DD-639-6111 FE/PC
+561-577-4990
+Unavallabie
+FE /FU
+pP/pU
+561-324-7931 FF/FU
+Unavailable
+PD/PU
+Unavallable
+FE /FU
+Unavailable
+FP /PU
+Unavailable
+PD/PU
+Unava llable
+FF /FU
+561-474-4149 PP/PU
+unava 11 able
+561-478-4168 PD/PU
+561-714-2941 FF/PU
+Unavailable
+PP/CH/FU
+561-790-3459 FF/FU
+561-432-2930 FF/FU
+561-714-2941 PP/PU
+561-676-8767 FD/FU
+561-714-2581 PD/PU
+561-432-2930 FP/FU
+561-379-7624 PP/PU
+5EL-E7E-#767
+Fp /FU
+Min: Sec
+2:00
+1:00
+2: 00
+18:00
+7:00
+9: 06
+2:00
+4:00
+3:0D
+3,00
+2:00
+1:00
+1,00
+1:0D
+9:00
+1,00
+10:00
+1:00
+4: 0D
+3,00
+1:00
+1,00
+4:00
+2,00
+2:00
+2,00
+2:00
+1:0D
+1:00
+Usage
+6.08
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+(561) 662-3098 continued..
+Telecommunications Services Call Detail (561) 662-3098
+See
+Footnote
+Item # Date Time Call To
+B60 Jal 04 07:52 PM Inconing
+061 Jul 08 07:56 PM Inconieg
+882 Jul 04 07:59 PM BOYTONRCH, PL.
+883 Jul 04 08:00 PM BOTTONECH. FL
+654 Jul c8 D8:15 IN M FAL BCH, PL
+B65 Jul 04 08:36 IM Inconieg
+665 Jul 04 08:50 PM M BALK BCH, PL
+887 Jul 04 08152 PM M BALK BCH, PG|
+660 Jul 08 09:02 PM M PALE BCH, PL
+870 Jul 08 09,07 PM M PAL BCH, PL
+871 Jul 03 12:47 A M PALE BCH, VL.
+872 Jul 09 12:47 AM M DALK BCH, PL
+873 Jul 09 09:13 18 Inconleg
+874 Jul 09 10,09 3 0 PAL BCH, PL
+875 gal 03 10:36 8 Inceled
+87S Jul 09 10:47 JM Incoming
+877 Jul 09 12129 IN Inconing
+B78 dal 03 0i:37 Inclay
+879 Jul 09 02:01 PM Iscoeleg
+880 Jul 09 02:05 PM M PALE BCH, PL
+881 Jul 09 02,07 PM I PATE BCH, PL
+B82 Jul 02 02:25 IN M PALE BCH, FL
+883 Jul 09 02:27 PM M PALK BCH, PL
+884 Jul 09 02:29 PM Inconleg
+885 Jul 09 02135 PM M BAI BCH, PL
+BBS Jul 09 06:44 PM 5 PALK BCH, PL
+887 Jul 09 07:26 PM M BALS BCH, PL
+885 Jul 09 07/28 #M Inconing
+859 Jul 03 DE:32 IN PALE BCH, FL
+B90 Jul 09 09:22 PM Inconiet
+891 Jul 09 09:24 IN IncomiNg
+802 Jul 09 09/28 EN Inconing
+B93 Jul 03 08:29 IN M PALE BCH, PL
+804 Jul 09 09:44 MIlT
+805 Jul 09 09:45 EN Inconing
+89026l0310:100 Incle
+897 Jul 09 10:19 WIsconiet
+888 Jul 09 10:29 PM M BALE BCH, PL
+80Q Jal 09 10,37 PM BALA BCH,PL
+900 Jul 07 10:49 IN M PALE BCH, PL
+Number
+561-379-7824 PP/FU
+561-790-2201
+561-577-4990 PP/FU
+561-797-3103 PP/FU
+561-432-2930
+PP/FU
+561-299-2824
+561-379-7824
+PP/FU
+561-714-2981 PP/FU
+561-379-7824 OP/CN/FU
+561-676-8767 OP/FU
+561-379-7824 OP/PU
+561-E7E-8767 OP/SU
+561-676-8767 0P/90
+5E1-185-2920 PP/80
+561-714-2981
+561-478-4188
+561-478-5222
+561-478-5222
+travallable
+Unavailable
+561-352-7000
+561-662-3098
+561-714-2981
+561-329-0798
+Unavaliable
+PP/PU
+PP/FU
+PP/PU
+PP/FU
+PP/FU
+PP/PU
+PP/FU
+P/PU
+561-714-2981
+561-676-8767
+PP/FU|
+561-676-8767
+561-478-5222
+PP/CW/FU
+PP/FU
+561-676-8767
+561-676-8767
+561-478-5222
+561-E7E-#767
+561-432-2930
+561-478-5222
+OF/FU
+Op/PU
+OP/CW/FU
+561-E62-5398
+561-662-5398
+OP/NS/ PU
+561-662-3098
+561-662-5398
+821225-E108
+Min:Sec
+3,00
+3:00
+1100
+2:00
+1:00
+3:00
+4:00
+2:00
+2:00
+1:00
+1:00
+1:00
+14:00
+1:00
+5:00
+3:00
+2:00
+2:00
+2:00
+2:00
+7:00
+5:00
+3:00
+3:00
+1 =0g
+2:00
+2:00
+2:00
+J:0a
+1:00
+1:00
+10:00
+1:00
+1:00
+Usage
+4.00
+4.DD
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+8.00 |
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+4.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+D.DD
+0.00|
+D.D0
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.00 |
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+a.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+(561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Footnote
+Item # Date Time CallTo
+001 Jul 09 10:51 EM N PALM BCH, PL
+902 Jul 09 10:54 IM Inconing
+000 Jul 10 12:45 AM N FALM BCH,PL
+004 Jul 10 01:08 AM Incoring
+BOS Jul 10 01:10 AM Inconling
+BOB Jul 10 09:10 AM N PALM BCH, PL
+907 Jul 10 09:19 AM N FALA BCH, PL
+p08 Jul 10 11.19 AM Inconing
+909 Jul 10 11:66 AM N FALM BCH, PL
+910 Jul 10 12:01 PM W FALM BCH, PL
+911 Jul 10 12:34 EM Inconing
+912 Jul 10 12:47 # Inconing
+913 Jul 10 12:56 IM N PALM BCH, PL
+914 Jul 10 01:05 PM W FALK BCH, PL
+015 Jul 10 O1.0€ EM Inconing
+916 Jul 10 01:07 PM N PALA RCH, IL
+817
+Jul
+10 01:48 IM N PALM BCH ,PL
+918
+Jul 10 01:45 EM W PALM BCH, PL
+919
+Jul 10 01:58 IN N PALM BCH, PL
+830
+Jul
+01:59 IN W PALM BCH,PL
+821 Jul 10 02:02 PM Inconing
+022
+Jul 10 02:05 EM W PALM BCH, PL
+Jul 10 02:08 PM Inconing
+824
+Jul 10 02:30 PM Inconing
+Jul
+10 00:31 PM N PALM BCH,PL
+Jul 10 05:35 EM Incondng
+Jul 10 05:39 PM N PALM BCH, PL
+928
+Jul
+10
+05:44 PM W FALK BCH ,PL
+029
+Tul 10
+06:04 PM Incondng
+930
+Jul
+10 06:09 IN N PALA BCH, PL
+831
+10 06:14 IM N PALM BCH, PL
+Jul 10 06:27 PM Inconing
+133
+Jul
+06:46 PM Incondng
+Jul 10 06:47 PM Inconleg
+805
+Jul 10 06:57 PM Inconing
+038
+Jul
+10 07:05 PM Incondug
+837
+Jul 10 07:39 PM A FALA BCH, PL
+B38
+Jul 10 08:38 IM Incoring
+930
+Jul
+10 09:24 IN Inconing
+Jul 10 09:43 EM Incondng
+041 Jul
+1. м тасодва
+Number
+561-662-5398
+561-662-5398
+CP / PU
+561-662-3098 CP/FU
+770-466-2216 GP/PU
+770-40E-2216 OF/FU
+561-471-5207
+CD IDI
+561-601-3439
+DE /FU
+561-714-2941
+OP /PU
+5E1-124-7931
+DE/FU
+561-324-7931
+561-714-2941 CP/PU
+5E1-793-4189
+De /FU
+561-793-4189 0D/PU
+561-714-2941 CE/FU
+561-793-4149 CP/PU
+5E1-714-2981 CB/FU
+561-793-4189 00/PU
+561-762-1545 0P/PU
+561-827-2542
+De/FU
+561-827-2542
+0D /PU
+561-762-3585 CE/CN/FU
+561-427-2542
+561-762-1585 C/CK/FU
+561-827-2542 00/PU
+561-427-2542 CP/PU
+561-714-2941 08/PU
+561-790-3459 00/PU
+561-379-7824 GE/FU
+561-379-7624 08/PU
+561-67E-8767 DE/FU
+561-324-1931 00/PU
+561-329-8070 CE/FU
+561-309-5958 08/PU
+561-309-5958 CF/FU
+561-309-5958 CE/FU
+561-790-3459 0P/PU
+561-790-3459 C0/FU
+561-676-4767 00/PU
+561-754-4316
+De /FU
+561-676-4767
+Ge /PU
+Min: Sec
+3:00
+1:00
+1: 00
+2:00
+24:00
+9: 06
+2:00
+3,00
+1:0D
+1:0D
+7:00
+1:0D
+2,00
+2:00
+1:00
+1:0D
+9:00
+3,00
+1: 0D
+9:00
+5,00
+4. 00
+2:00
+5:00
+1,00
+1:0D
+3: 00
+3:00
+I: 0D
+Usage
+6.08
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+D.DD
+Charges
+D.0D
+0,00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+Account number 747607414
+SUNSHINE SVCS UNLIMITED (561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Item # Date Time Call To
+942 Jul 14 11:16 PM M BALK BCH, FL
+943 Jul 10 11:42 PM I DALM BCH, PL
+TOTAL
+Number
+Footnote Min:Sec
+561-662-3098 OP/FU
+2:00
+561-202-4665 0P/PO
+2316,00
+Usage
+4.00
+Footnote
+Features
+CW-Cal Waiting
+CF-Call Forwarding
+3V-Three Way Call
+DS-Dialup Service
+Networks
+Services
+NN-National Network
+CN-Canadian Network
+AL- Man Promotoral Usage
+PF-Partial Free
+Ta Tuna times cunt PC-Free Cal
+(561) 662-6616
+Telecommunications Services Call Detail (561) 662-6616
+Item # Date Time Call To
+Number
+See
+Footnote Min:Sec
+1 Jun 11 DE:Se AN Inconleg
+561-503-8425 OP/PU
+1:00
+2 Jun 11 07:05 AM 5 PALE BCH, PL
+561-357-5751
+PP/PU
+1:00
+3 Jun 12 D9.31 AN Inconleg
+PP/FU
+4 Jun 11 09:34 AN BOTTONECI, FL
+561-503-5930
+P/BU
+2:47
+Jun 11 01:48 PM BOYTONBCH, PL
+561-503-5930
+PP/FU
+2:27
+Jun 11 02:43 IN Inconleg
+561-662-66E8
+PP/FU
+2137
+7 Jun 11 03.15 IN Inconing
+EE1605.2961
+PP/PU
+8 Jun 11 04:09 IN BOTTONIC, FL
+561-503-5330
+1:00
+Jun 11 04:30 IN Inconleg
+561-357-5751
+PP/FU
+1:45
+10 Jun 12 07,38 PM I PALE BCH, PL
+561-714-0246
+PP/FU
+1:00
+11 Jun 12 07,40 IN BOTTONCH. FL
+12 Jun 11 07:44 IN M PALE BCH, FL
+13 Jun 12 07152 PM PADE BCH, PL
+14 Jun 12 07:54 PM N PALA BCH, PL
+15 Jun 11 08:44 IN M PALE BCH, FL
+16 Jun 12 01:08 AM Inconieg
+17 Jun 12 DE139 AN W PALE BCH, PL
+18 Jun 12 O6:41 AM M BALE BCH, PL
+19 Jun 12 11:40 AN BOTTONCH, FL
+20 Ju 12 03:31 IN BOYTONECH, PL
+21 Jun 12 03:50 PM M PALA BON, PL
+561-503-5930
+561-714-0244
+561-714-0244
+561-714-0244
+561-714-0244
+561-712-9018
+561-662-6616
+561-502-7753
+561-503-8425
+561-503-8429
+561-662-6616
+PP/PU
+1,00
+PP/FU
+1: 00
+PP/FU
+1:00
+PR/PU
+1.00
+PP/PU
+1:00
+OP/PU
+5:10
+1136
+OP/PU
+1:00
+1:00
+OP/PU
+Op/U
+1:00
+1:00
+22 Jun 12 03:51 IN M BALE BC, PL
+1:54
+23 Jun 12 10:09 IN BOYTONECH, PL
+24 Jun 13 12,36 IN ROYTONRCH, PL
+25 Jun 13 01/05 IN BOTTONICH, FL.
+25 Jul 13 04:07 IN M PALE BCS, FL
+561-503-8429
+OP/PU
+561-503-8429
+561-503-8429
+OP/PU
+821 2299808
+1:00
+1:00
+1100
+1:26
+27 Jun 13 05:25 PM & PAIR BCH, PL.
+28 Jun 17 05,40 PM U PALE BOH, PL
+561-714-0244
+561-712-9018
+OP/PU
+1:04
+1, 49
+Usage
+0.0D
+0.0D
+$.00
+= 5[
+2.56
+0.0D
+0.0D
+$.00
+0.0D
+• 5г
+- ar
+$.00
+• ar
+0.0D
+$.00
+•.00
+$.00
+•.00
+Distance
+89.00
+Time Period
+PP-Peak Period
+OP-Off Peak Period
+MP-Muliple Pariod
+Total
+Charges
+9.00
+$9.00
+Long
+Distance
+D.D0
+D.DO
+0,00
+D.DO
+0,00
+• Do
+D.DD
+0.D0
+D.D0
+n no
+D.D0
+D.DO
+D.DD
+0.D0
+corticued.
+Total
+Charges
+9.00
+0,00
+d.cd
+9.00
+9.00
+9.00
+a.ca
+9.00
+g.00
+9.00
+g.c0
+9.00
+9,00
+Account number 747607414
+00
+(561) 662-6616 continued...
+Telecommunications Services Call Detail (561) 662-6616
+See
+Footnote
+Item # Date Time CallTo
+29 Jun 14 06:41 AM N PALM BCH, PL
+30 Jun 14 06:51 AM N PALM BCH, PL
+31 Jun 14 07:0€ AM Inconing
+32 Jun 14 07:12 AM BOYTONBCH, PL
+33 Jun 14 07:15 лМ ВОгТоМОСи, 05
+34 Jun 14 09:47 AM Inconing
+35 Jun 14 09:52 AM BOYTONBCH, PL
+36 Jun 14 04:16 EM W PALM BCH, PL
+37 Jun 14 05:38 PM N FALA BCH, PL
+38 Jun 14 07:42 PM BOYTONBCH, PL
+39 Jun 14 09:25 EM W PALM BCH,PL
+40 Jun 15 08:06 AM Inconing
+41 Jun 15 10:07 AM BOYTONECH, PL
+42 Jun 15 01:37 PM Inconing
+43 Jun 15 03:21 PM BOYTONBCH, PL
+44 Jun 15 03:19 IN N PALA RCH, PL
+$
+Jun 15
+03:20 IN W PALA BCH ,PL
+15 03.21 EM W FAIM BCH,PL
+Jun
+Jun 15
+06:40 IM W PALM BCH, PL
+49 Jun 15 06:55 PM W PAIN BCH, PL
+50 Jun 16 10:03 AM W PALM BCH ,PL
+51 Jun 16 10:03 AM Inconing
+52 Jun 16 10:36 AM W PALM BCH,PL
+Jun 16 01:03 PM N FALM BCH ,PL
+Jun 16 01,31 EM PALM BCH,PL
+8
+Jun 16 01:21 PM NPALA BCH, PL
+:
+01:42 PM Inconing
+Jun 16 01:52 EM Incondng
+01:54 IN BOETONACH, PL
+9:
+Jun 16
+02:07 IM Incoring
+Jun 16 02:26 PM Inconing
+Jun
+16 02,32 PM Incondug
+Jun 16 02:56 PM Inconing
+16 03:35 PM N PALM BCH.PL
+03,36 PM W PALM BCH,PL
+Jun 1e 04:06 SM Inconlog
+Jun 16 05:01 IM Incoring
+Jun 16 06:11 PM Inconing
+Jun 16 11,53 EM NPACM BCH,PL
+8
+I1:54 PM A FALM BCH .PL
+Number
+561-502-7753
+561-502-7753
+Ce / PU
+561-503-4429 FF/FU
+561-503-5930 PP/PU
+561-103-8429 FF/FU
+561-503-5930
+561-503-8429
+561-662-6616
+PP/PU
+5E1-157-5751
+S61-503-8429 FF/FU
+561-714-0244 GP/PU
+5E1-502-7753 FF/FU
+561-503-8429 PD/PU
+561-503-8429 FF/FU
+561-503-4429
+Fe/PU
+561-357-3751 FD/FU
+561-714-0244
+PD /PU
+561-433-0547 PP/PU
+561-903-8422 FF/FU
+561-687-2039 PD/PU
+561-687-2039 PE/FU
+561-662-6616 PP/PU
+561-627-0141 FF/FU
+561-714-0244 PD/PU
+561-405-6700 FF/PU
+561-905-6700 PP/PU
+561-712-9018 PD/PU
+561-503-4429
+FF/FU
+561-503-9429 PP/PU
+561-103-8429 FF/FU
+561-503-8429 PD/PU
+561-951-5175 FF/PU
+561-951-5175 PP/PU
+unava llable
+561-758-4626 FF/FU
+561-712-9018 PP/PU
+561-712-9014 FD/FU
+561-503-8429 PD/PU
+561-754-4626 FP/FU
+561-662-6616 0P/PU
+SEL-CER-CELE OF/FU
+Min: Sec
+1104
+1:00
+1100
+1,00
+1113
+1,00
+1:0D
+1:00
+1:0D
+1,00
+1:0D
+1:08
+1:49
+1,00
+1: 36
+4: 40
+2:30
+2:59
+1,00
+1101
+1:02
+2144
+1:59
+5:03
+1:00
+2:11
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+D.DD
+D. DD
+0.0D
+D. DD
+D.DD
+Charges
+D.0D
+0,00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6616
+See
+Footnote
+Item # Date Time Call To
+70 Jun 16 11:57 PM W PALK BCH, FL
+71 Jun 17 06:41 AM Ieconing
+72 Jun 17 DE14E AN Inconleg
+73 Jun 17 07:14 AM Inconing
+74 Jun 17 08:52 AN Incoeleg
+75 Jun 17 10:45 AM Inconieg
+76 Jun 17 11:07 AM Inconing
+77 Jun 17 11/27 JM Inconing
+78 Jun 17 12:05 m Incoeleg
+79 Jun 17 03:56 EN W PALE BCH, PL
+B0 Jun 17 05134 EN Inconing
+81 Jun 17 05:42 WN Incoeleg
+82 Jun 17 D6:13 PM Inconieg
+83 Jun 17 07:49 PM M BALE BCH, PL
+B4 Jun 17 07,50 EM W BALE BCH, FL
+85 Ju 17 07:51 PM BALA BOT, PL
+BS Jun 17 08:03 PM M PALA BCH, PL
+87 Jun 17 08,07 PM M PALA BCH, PL
+B8 Jun 17 D8:11 IN M PALE BCH, VL
+89 Jun. 17 08:59 PM M DALK BCH, PL
+90 Jun 17 10:32 EN I PALE BCH, PL
+Q1 Jun 17 10,33 PM Inconing
+82 JuN IN DE:5S AN INCORLEG
+83 Jun 1# 11:51 AM M PALM BCH, PL
+94 Jun 14 04:10 PM BOYTONECH, FL
+05 Jun 14 04:14 EM Inconleg
+B5 Jun 1# 04:21 PM BOYTONECH, PL
+97 Jun 14 04:22 PM BOYTONBCH, PL
+8$ Jun 19 04:48 EM BOYTONCH, FL
+JuN IN DE:59 IN INCORleg
+100 Jun 14 07:01 PM M PALK BCH, PL
+101 Jun 14 07:03 PM M BALE BCH, PL
+102 Jun 19 07:41 EN Inconing
+103 Jun 19 D8:10 JN BOTTONSCH, FL
+104 Jun 19 06:25 PM M PALE BCH, PL
+105 Jun 19 08:08 EN Inconing
+105 Ju. 21 04:22 PM I PALE BCH, PL
+107 Jun 21 04:58 PM InconieT
+108 Jun 21 05:20 P
+BOTTONCH, FL. I
+100 Jum 21 05:49 PM Inconleg
+110 Ju
+Number
+561-662-6616
+561-712-9018
+OP/PU
+561-712-9018 OP/NN/FU
+561-712-9018 PP/N/FU
+561-662-EGE8 PP/FU
+561-A9R-A1RA
+561-478-4188 PP/FU
+561-478-4188
+PP/FU
+561-502-8429
+PP/FU
+561-478-4188 PP/PU
+561-289-2669 PP/SU
+561-662-6688
+561-214-0244 P/S0
+561-714-024÷
+561-714-0244
+PP/PU
+PP/FU
+561-304-3378
+561-714-024÷
+561-433-0547
+PP/PU
+PP/FU
+561-714-0244
+561-714-0244
+561-714-024÷
+op/PU
+561-503-8429
+561-687-2039
+P/PU
+561-503-8429
+PP/FU
+561-737-5100
+PP/PU
+561-503-8429
+561-503-8429
+561-503-8429
+561-324-1491
+561-324-1491
+561-324-1491
+561-712-9018
+561-503-8429
+561-662-6616
+561-357-5751
+561-304-3378
+561-686-4702
+561-503-5930
+561-503-5930
+PP/FU
+PP/FU
+PP/FU
+PP/PU
+PP/FU
+PP/PU
+PE/FU
+P/PO
+PP/FU
+PP/FU
+Min:Sec
+2133
+1:00
+1124
+1:00
+1:00
+1:00
+1:00
+2117
+1:00
+1:30
+1107
+4:39
+2:56
+1:00
+1:00
+3:59
+1,00
+2:36
+1:09
+1.00
+1.00
+1:00
+1:24
+1:00
+2141
+1:00
+1:00
+1:00
+1: 00
+1:00
+1:00
+2127
+1: 0a
+1:00
+1100
+1:00
+1:13
+1:00
+1137
+1.15
+Usage
+4.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+$.5B
+$.00
+0.0D
+•.00
+9,00
+$.00
+0.0D
+0.0D
+$.00
+0.0D
+•.00
+- •r
+•.0B
+$.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+0.D0|
+п nn
+corticued.
+Total
+Charges
+9.00
+a.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+Account number 747607414
+(561) 662-6616 continued...
+Telecommunications Services Call Detail (561) 662-6616
+See
+Footnote
+Item # Date Time CallTo
+111 Jun 21 06:26 EM N PALM BCH,PL
+112 Jun 21 06:30 IM N PALM BCH, PL
+113 Jun 21 06:37 PM Inconing
+114 Jun 21 06:34 EM N PALM BCH,PL
+115 Jun 21 07:34 PM N RAIN BCH, PL
+116 Jun 22 07:43 AM Incoring
+117 Jun 22 10:51 AM Inconing
+118 Jun 22 03:14 PM BOYTONBCH, PL
+119 Jun 22 03:60 IN N FALM BCH, PL
+120 Jun 22 04:19 PM Inconing
+121 Jun 22 04:31 EM W PALM BCH ,PL
+122 Jun 22 06:11 PM BOETONBCH, PL
+123 Jun 22 07:21 IM W PALM BCH, PL
+124 Jun 23 06:39 AM Inconing
+125 Jun 23 06:55 AM BOYTONBCH, PL
+Jun 23 06:57 AM BOTCH,L
+Jun
+06:59 AM BOYTONBCH, PL
+23 07.04 AM BOYTONBCH, PL
+8
+Jun
+07:05 AM BOTCH, PL
+Jun
+07:09 AM BOYTONBCH, PL
+131 Jun 23 07:12 AM BOYTONBCH, P5
+132 Jun 23 09:50 AM Incoring
+133 Jun 23 09:54 AM Inconing
+134 Jun 29 11:07 AM BOYTONECH, PL
+135
+Jun 23 12:07 PM N FALM BCH, PL
+Jun 23 12:08 EM W PALM BCH,PL
+Jun 23 12:10 PM Inconing
+Jun
+23
+12:13 PM Inconing
+23
+03:06 PM Inconing
+141
+03:07 IM W PALM BCH ,PL
+142 Jun 23 03:30 IN BOYTONCH, PL
+Jun
+23 07:31 EM Incordng
+144 Jun 24 07:02 AM BOZTONICH, PL
+Jun 24 07:05 AM BONTONBCH, PL
+Jun
+07:07 AM
+BOYTONECH, PL
+147 Jun 24 07:09 AM BOZTONICH, IL
+148 Jun 24 07:10 AM BOYTONBCH, PL
+Jun 24
+07:12 AM BOYTONBCH, PL
+Jun 24 07,12 AM BOYTONBCH, PL
+151
+07:11 A BOXINCH. PL
+Number
+561-357-5751
+PP/FU
+561-357-5751
+PD/PU
+561-357-5751 FF/FU
+561-667-3715 PP/PU
+561-324-1491 FF/FU
+561-503-8429
+PP/PU
+561-503-8429
+561-503-4429
+FP /PU
+5E1-104-3378
+FE /FU
+561-667-3715 FP/FU
+561-662-6616 PP/PU
+SEL-303-8429 FF/FU
+561-662-6616 PD/PU
+561-324-3491 CE/FU
+561-503-4429
+0P/PU
+5E1-303-8429 C0/FU
+561-503-#429
+MD /PU
+561-503-8429
+pP/pu
+561-903-8422 FF/FU
+561-503-8429 PD/PU
+561-503-8429 PE/FU
+561-662-6E48 pP/pU
+561-103-8429
+Fe /Fu
+561-503-8429 PD/PU
+561-324-1491
+561-324-1491 PP/PU
+561-324-1491 PD/PU
+561-324-1491
+FF /FU
+561-712-9018
+561-758-B62E FF/FU
+561-758-8626
+PD/PU
+561-503-4429 FF/PU
+561-503-9429
+pP /pt
+561-101-8429
+561-503-4429 FF/FU
+561-503-4429
+PP/PU
+561-503-8423 FD/FU
+561-503-8429
+PD /PU
+561-503-4429
+FE /FU
+561-503-9429
+PP/PU
+Fp /FU
+Min: Sec
+3113
+1: 00
+1,00
+1:00
+1:07
+1115
+1:0D
+1:35
+1116
+1:0D
+1:00
+1100
+1,00
+1:0D
+1:00
+1,00
+1:0D
+1:00
+1,24
+1:22
+1:00
+1:23
+1152
+1:05
+1,00
+1:00
+1,00
+1:0D
+1:00
+1,00
+I: 0D
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+0.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6616
+See
+Number
+Footnote
+Item # Date Time Call To
+152 Jun 24 07:15 3M BOTTONCH. FL
+153 Jun. 24 07:16 AM M PAL BCH, PL
+154 Jun 24 07116 AN BOYTONECH, PL.
+155 Jun 24 07,17 3M BOTTONECH, FL.
+157 Jun. 24 05:36 IN BOYTONBCH, PL
+155 Jun 24 D6:04 PM BOTTONECH, PL
+159 Jun 24 D6:07 PM BOYTONBCH, FL
+180 Jut 24 DE:14 IN Incoeleg
+181 Jun 24 D6:21 PM BOTTONSCH, PL
+182 Jun 24 D6147 PM N PALK BCH, PL
+163 Jun 24 DE:47 WN M BALE BCH, VL.
+164 Jun. 24 07:59 PM 5 PALK BCH, PL
+165 Jun 24 08:04 IN M BALE BCH, PL
+108 Jun 25 07,09 AN BOYTONCH, FL
+167 Jun 25 10:28 AN M PALE BCH, FL
+168 Jun. 25 11:19 AM I PALA BCH, PL
+170 Ju. 25 01:23 IN M PALE BCH, PL
+171 Jun 25 01:24 PM 5 DALK BCH, PL
+172 Jun 25 02:26 PM Inconleg
+173 Jun 25 01,40 PM M PATE BCH, PL
+174 2am 25 8:43 m Inceled
+175 Jut 25 08:49 PM Inconiet
+176 Jun 26 D6:38 AN IncomiNg
+177 Jun 26 08:47 AM M BAL BCH, FL
+178 Jun 26 04:36 PM Inconley
+179 Jun 26 05:45 PM BOTTONBCH, PL
+180 Jun 26 05:47 PM Inconing
+181 Jun 27 07:43 AN ROTTONCH, FL.
+182 Jun 27 07:44 AM BOYTONBCH, PL.
+183 Jun 27 08:45 JМ BOYTONCH, FL.
+184 Jun 27 09124 JM BOYTONBCH.FL
+185 Ju 27 08:39 JN BOTTONCH, FL.
+188 Jun 27 09:58 AM BOYTONCH, FL.
+187 Jun 27 10:54 AN BOTTONECH, FL
+188 лил 27 11:20 лн коттоваси, г.
+189 Jun 27 12:13 PM BOYTONECH. PL.
+190 Jun 27 12:15 IN M BALE BCH, PL
+191 Jun 27 01:33 IN BOSTONECH, FL
+561-503-8429 PP/PU
+561-662-6616
+561-503-8429 PP/FU
+561-503-8429 PP/FU
+561-503-8429 PP/FU
+561-508-8424
+561-503-5980
+561-503-5930
+561-503-5930
+PP/FU
+PP/FU
+PP/FU
+561-357-5751
+PP/FU
+561-714-0244 PP/SU
+561-357-5751 PP/PU
+5E1-214-0244 PP/SO
+561-503-8429
+561-502-5123
+561-719-9993
+561-662-6688
+561-662-6GE8
+561-662-6688
+561-662-6688
+561-662-6616
+561-712-9018
+561-712-9018
+561-503-8429
+PP/PU
+PP/FU
+PP/PU
+PP/FU
+PP/FU
+PP/PU
+FF /FU
+561-967-0443
+561-503-8429
+Op/FU
+OP/PU
+Op/FU
+OF/FU
+561-503-8429
+561-503-8429
+561-503-8429
+561-503-8429
+561-503-8429
+561-503-8429
+561-503-8429
+561-503-8429
+561-714-0244
+561-503-8429
+OF/FU
+Op/PU
+DE/FU
+Min:Sec
+1,00
+1100
+1:00
+1:00
+1:00
+1:04
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1: 13
+1:00
+1:00
+1:00
+1,38
+1:00
+2:17
+1:55
+1:00
+1:00
+1:00
+1:34
+1126
+1: 00
+1:00
+1:00
+1:00
+1: 0a
+1:00
+1100
+1:00
+1:00
+1:00
+1:49
+2:02
+Usage
+4.00
+$.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+8.00 |
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+$.00
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+0.D0|
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+Account number 747607414
+(561) 662-6616 continued...
+Telecommunications Services Call Detail (561) 662-6616
+See
+Item # Date Time CallTo
+Number
+Footnote
+Min: Sec
+199 Jun 27 04:54 EM N PALM BCH, PL
+561-662-6616
+Ge /FU
+1,00
+194 Jun 27 05:35 IM Inconing
+561-712-9018
+0P/PU
+3:29
+195 Jun 27 06:24 PM I FALA BCH, PL
+561-324-2491 CP/FU
+1: 00
+196 Jun 28 06:56 AM BOYTONBCH, PL
+561-503-8429 OP/PU
+1,00
+197 Jun 28 07:18 AM N RAIN BCH, PL
+561-765-0722 FF/FU
+198 Jun 28 07:48 AM BOYTONECH, PL
+561-503-5930
+190 Jun 28 08:35 AM Inconing
+561-503-5930
+1100
+200 Jun 28 10:24 AM BOCA RATON, PL
+561-305-1272
+PP/PU
+201 Jun 28 10:36 AM BOCA RATON, PL
+5E1-105-1272
+202 Jun 28 10:34 AM Inconing
+209 Jun 28 05:35 EM Inconing
+204 Jun 28 06:20 PM Inconleg
+200 Jun 28 07:47 IM W PALM BCH, PL
+208 Jun 29 06:56 A BOYTONBCH, PL
+207 Jun 29 07:01 AM Inconing
+Jun 2307:43 AM BOSTONBCH, PL
+Jun 29 61:36 I Incoming
+210
+29 02:52 EM W FAIM BCH,PL
+211 Jun
+23 09:02 IN Incondag
+П
+| Jun 29 09:02 IM W PALM BCH, PL
+213 Jun 29 09:03 PM N FALM RCH,PL
+214 Jun 30 07:09 AM BOYTONBCH, PD
+215 Jun 30 09:10 AM Incoeing
+210 Jun 90 09:13 AM Incoring
+217
+Jun 30 10:27 MM Inconing
+218 Jun 30 10:27 AM Inconing
+219 Jun 90 11:06 AM N PALM BCH ,PL
+220
+Jun
+30 11:27 AM Inconing
+221
+30 11:52 AM BOYTONBCH, PL
+222
+30 11:55 AM Inconing
+223
+Jun 30
+12:39 IM W PALM BCH,PL
+Jun 30 04:21 IN N PALM BCH, PL
+Jun
+06:11 PM Incondug
+Jun 30 06:33 PM Inconleg
+Jun 30 07:07 PM BOYTONCH, PL
+278
+Jun 30
+07,13 PM W PALM BCH,PL
+229 Jun 30 08:35 PM N FALA BCH, PL
+Jul 01 06:13 AM R PALM BCH,PL
+231 Jul 01 06:19 AM N PALM BCH, PL
+Jul 01 07.11 AM Incondng
+561-662-6C88 PP/PU
+SE1-6E2-EEBE FF/FU
+561-644-9726 PD/PU
+561-503-8429 CE/FU
+561-503-4429
+PP/pu
+5E1-303-5930 FD/FU
+561-662-6688
+PD /PU
+561-844-3954
+pP/pu
+561-758-B82E OB/FU
+561-758-8826 00/PU
+561-758-8826 CE/FU
+561-503-4429 pP/pU
+561-478-4188 FF/FU
+561-662-6688 PD/PU
+561-767-$443 FF/PU
+561-967-0443 PP/PU
+561-476-4168 PD/PU
+561-712-9018
+FF/FU
+561-503-9429
+PP/PU
+561-103-8428
+561-502-5123 PD/PU
+561-662-66L6 FF/FU
+561-662-6688
+pP/PU
+561-101-8429 FF/FU
+561-503-4429 FF/FU
+561-662-6616 PP/PU
+561-714-0244 FD/FU
+561-662-6616 00/PU
+561-712-9018 0E/FU
+561-662-6648
+PP/PU
+1,00
+1:35
+1:53
+1100
+1,00
+1:0D
+1:00
+1,00
+1,00
+1:48
+1:00
+1,00
+1:00
+2120
+1:42
+1,00
+1:21
+1:11
+1:00
+223
+1ї пт
+2:29
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+0.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6616
+See
+Footnote
+Item # Date Time Call To
+234 Jul 01 10103 3M Inconing
+235 Jul 01 10:23 JM M DALM BCH, PL
+236 Jul 01 12:09 A M PALK BCH, PL
+237 Jul 01 11:20 3M M BALK BCH, FL
+235 Jul 02 05:57 J0 M PALE BCH, FL
+239 Jul 02 06:44 JM • PAL BCH, PL
+240 Jul 02 07:16 AN BOTTONCH, PL.
+241 Jul 02 07121 3M BOYTONBCH, FL
+242 Jul 02 08:15 J M BALE BCH, VL
+243 Jul 02 09:31 AM M BALE BCH, PL
+244 Jul 02 09,34 AM BOCA RATON, PL
+245 Jul 02 10:5E AN BOYTONRCH, FL.
+245 Jul 02 11:58 AM Inconing
+247 Jul 02 12:15 IN BOTTONECH, PL
+248 Jul 02 12:40 EN Inconing
+249 Jal 02 02:01 W M PALE BCH, FL
+250 Jul 02 02:34 IN I PALA BCH, PL
+251 Jul 02 02,34 PM BOCA RATON, PL
+252 Jul 02 02:40 IN M PALE BCH, PL
+253 Jul 02 02:40 PM 5 DALK BCH, PL
+254 Jul 02 02141 PM BOCE BATON, PI.
+255 Jul 02 03:00 IN Inconing
+257 Jul 02 03:44 PM BOYTONECH, PL
+258 Jul 02 05:01 IN IncomiNg
+250 Jul 02 06:31 PM BOSTONECH, PL
+200 Jul 02 06:41 PM BOYTONECH, PL.
+281 Jul 02 07:16 IN BOTTONECH, PL
+262 Ja] 02 07,29 PM BOYTONCH, FL
+263 Jl 02 07:52 IN M PALE BCH,L
+254 Jul 02 07:54 PM M PALK BCH, PL
+265 Jul 02 07:59 PM MAK BCH, PL
+200 Jul 02 08:44 IN BOSTONECH, FL
+268 Jul 02 12:23 PM BOYTONECH, FL.
+280 Jal 03 04:57 AM M BAI BCH, PL
+270 14) 03 04:58 AN PALE BOUL
+271 Jul 09 06:55 AM Inconier
+273 Jal 03 09,39 3М BOYTONCE, FL
+274 74)
+Number
+561-712-9018 PP/FU
+561-152-7000
+PP/FU
+561-758-8826 PP/FU
+561-662-6616 OF/FU
+561-259-5951
+OP/PU
+561-503-8429 PP/FU
+561-503-8429
+PP/FU
+561-EE2-EE16
+PP/FU
+561-662-6616 PP/FU
+561-305-1272
+PP/FU
+561-503-8429 PP/SU
+561-502-7753 P9/90
+5E1_503-6129 PP/SO
+561-503-8429
+561-964-1515
+561-662-6616
+561-305-1272
+561-662-6616
+561-662-6616
+561-305-1272
+561-305-1272
+561-502-7753
+561-503-8429
+561-712-9018
+PP/PU
+PP/FU
+PP/PU
+PP/FU
+PP/FU
+PP/PU
+PP/FU
+PP/FU
+561-503-8429
+561-503-8429
+PP/FU|
+561-712-9012
+561-712-9018
+561-712-9018
+561-503-5930
+561-712-9018
+561-503-8429
+561-662-6616
+561-502-7753
+561-662-6688
+561-687-2039
+561-503-8429
+PP/FU
+PP/PU
+PP/FU
+PP/PU
+DE/FU
+Min:Sec
+1:03
+1:09
+3:00
+1:30
+1:51
+2:28
+1:00
+1:00
+1:00
+2123
+1:00
+1:25
+1:37
+2:00
+1:00
+1.00
+1:00
+1:00
+1:34
+2v21
+1:0a
+1:00
+1:33
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1.00
+1: 0a
+1:00
+1100
+1:00
+1:32
+1:01
+1:00
+1.15
+Usage
+4.00
+$.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+8.00 |
+0.0D
+0.0D
+0.0D
+$.5B
+$.00
+0.0D
+•.00
+9,00
+$.00
+0.0D
+$.00
+0.0D
+•.00
+0.0D
+•.00
+0.0B
+•.00
+$.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.D0|
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+Account number 747607414
+(561) 662-6616 continued...
+Telecommunications Services Call Detail (561) 662-6616
+See
+Item # Date Time CallTo
+275 Jul 03 11:27 AM BOYTONBCH, PL
+270 Jul 03 02:13 IM N PALM BCH, PL
+277 Jul 03 03:00 PM BOYTONECH, PL
+278 Jul 03 05:00 EM Incordng
+279 Jul 03 05:34 PM N FALA BCH, PL
+280 Jul 04 07:25 AM N PALM BCH, PL
+281 Jul 04 07:31 AM N FALA BCH, PL
+282 Jul 04 01:01 PM BOYTONBCH, PL
+283 Jul 04 02:40 SM BOZTONICH, IL.
+284 Jul 04 04:40 PM BOYTONBCH, PL
+285 Jul 04 04:41 EM W PALM BCH ,PL
+286 Jul 0a 04:48 PM BOETONCH, PL
+287 Jul 04 05:12 IM BOYTONECH, PL
+288 Jul 04 06:32 PM W FALK BCH, PL
+280 Jul 04 07:52 EM BOYTONBCH, PL
+Number
+Footnote Min: Sec
+561-503-9429
+Ge /FU
+1,00
+561-662-6616
+0P/PU
+1:00
+561-503-4429 CP/FU
+561-357-5751 0P/PU
+561-357-5751 OF/FU
+561-357-5751
+561-714-0244
+1:00
+561-503-4429
+OP /PU
+5E1-903-8429
+DE/FU
+1:0D
+S61-503-8429 CE/FU
+561-714-0244 GP/PU
+SE1-303-8429
+De /FU
+561-503-4429
+OP/PU
+1,00
+1:0D
+1:00
+561-304-3378 CE/NN/FU
+561-503-4429 08/PU
+5E1-712-2018 FD/FU
+561-712-9016 PD/PU
+561-662-6616 PP/PU
+293
+07:20 AM W PALA BCH, PL
+07:24 AM W FAIM BCH,PL
+07:28 AM N PALM BCH, PL
+Jul
+08:59 AM W PALM BCH ,PL
+285 Jul 05 09:14 M Inconing
+200 Jul 05 09,48 AM Incordng
+207 Jul 05 03:05 ALACE,L
+298 Jul 06 07:07 AM Incoring
+Jul 06 09:34 AM BOYTONBCH, PL
+300 Jul 06 09.36 AM Inconing
+301 Jul 06 10:55 AM Incoring
+Jul
+12:04 PM Inconing
+Jul 06
+08:27 PM Incondng
+304
+Jul 07
+11:04 AM BOETONACH, PL
+306 Jul 07
+11:16 AM Incoring
+300 Jul 07
+04:35 PM N PAEN BCH, PL
+307 Jul
+04:37 PM W PALM BCH,PL
+07:15 IN BOETNACH, PL
+07:02 AM BONTONECH,PL
+310
+Jul
+09:30 AM Incordug
+311 Jul 08 03:25 IN Incoring
+312 Jul 08 04:23 PM Incoring
+313
+Jul
+05:05 PM N PALK BCH,PL
+314 Jul 08
+05:06 PM W PALM BCH,PL
+315
+na
+05:07 PM N FALM BCH .PL
+561-102-3212
+561-662-6616 PD/PU
+1:0D
+1:00
+1,00
+1:09
+1:00
+561-502-5212 PE/FU
+561-541-5449 pp/pU
+561-712-2018 FF/FU
+561-503-8429 PD/PU
+3: 11
+1:00
+561-503-5936
+561-503-5930 PP/PU
+561-967-0671 PD/PU
+1:18
+561-662-6698
+FF/FU
+561-712-9018
+1,00
+561-103-1930
+561-503-5930
+PD /PU
+1:00
+561-662-66L6 FF/FU
+561-662-6688
+pP/PU
+1117
+561-101-8429 FF/FU
+561-503-4429 FF/FU
+561-662-6648 PP/PU
+561-503-8423 FD/FU
+561-503-8429 PD/PU
+1:00
+1,00
+1:0D
+1:00
+561-640-0978 FP/FU
+561-707-6448 PP/PU
+1_1s.1578
+Fp /FU
+I: 0D
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+D.DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6616
+See
+Number
+Footnote
+Item # Date Time Call To
+316 Jal 04 05140 PM Inconing
+317 Jul 09 07:09 AM BOYTONECH, PL.
+318 Jul 09 07117 AN BOYTONCH, PL.
+319 Jul 09 07:17 3M BOTTONECH, FL
+320 лиl 03 07:22 / Incoeleg
+321 Jul 09 01:24 IN • PALA BCH, PL
+322 Jul 09 02:33 IN INCOmINg
+323 Jul 09 05/06 EN Inconing
+324 Jul 03 08:54 IN Incoeleg
+325 Jul 10 07:11 AM Inconleg
+328 Jul 10 10,00 AM N PALA BCH, PL
+327 Jul 10 10:02 AM M PALE BCH, FL.
+328 Jul 10 11:36 AM M DALK BCH, PL
+329 Jul 10 12:38 AN M PALE BCH, PL
+330 Jul 10 11:43 AM M BALK BCH, FL
+331 Jul 10 12:3E WN M PALE BCH, FL
+332 Jul 10 03:37 IN BOYTONECH, PL
+333 Jul 10 07,17 # Inconlea
+TOTAL
+561-662-6688 PP/FU
+561-503-8429 PP/90
+561-503-8429 PP/FU
+561-503-8429 PP/FU
+561-503-8429 PP/FU
+561-665-66RA
+561-662-6688
+PP/FU
+561-662-6688
+PP/FU
+561-357-5751
+FP/FU
+561-503-8429 OP/FU
+561-712-9018 OP/PU
+561-75E-BE26 OP/SU
+561-712-9018 0P/PU
+5E1-EES-6E1E 0P/80
+561-662-6616 OP/PU
+5E1-EE2-EE1E OF/FU
+561-503-8429 0P/90
+561-712-9018 OP/PU
+Min:Sec
+1:19
+1:00
+1100
+1:00
+1:00
+1:00
+1:50
+1:00
+4:47
+1:00
+1:03
+1:07
+1:11
+1:11
+1,00
+1:00
+1:00
+2135
+435:31
+Footnote i
+Features
+CW-Call Waiting
+CF-Cal Forwarding
+IW-Three Way Call
+DS-Dialup Service
+Networks i
+Services
+NN-National Network
+CN-Canadian Network
+PF-Partial Free
+WD-Worldwide Discount FC-Free Call
+TJ. Truana Network
+(561) 662-6688
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time
+Call To
+1 Jun 11 DE:SE AN Inconleg
+2 Jun 12 D6159 AN Incolng
+3 Jun 11 07:03 AN A BADA BCS, FL
+* Jun 11 07:06 AM M PALE BCH, PL
+5 Jun 11 07,11 AN Inconing
+6 Jun 11 07:15 AN INCORLeg
+7 Jun 11 07:20 AM Ieconleg
+Number
+Min:Sec
+561-827-2542
+3:00
+561-541-4051 MP/C
+3:00
+561-662-6688 PF
+3:00
+561-329-0783 PP
+1:00
+561-324-1491 PP
+1:00
+561-827-2542 PE
+1:00
+561-722-1628 PP
+5:00
+561-502-5212 PP
+2,00
+• Jun 11 07,52 AN IncOmIng
+561-242-6019 PP
+2100
+10 Jun 11 D8:10 AN INDeleg
+1.an
+11 Jun 11 08:21 AM Inconley
+12 Jun 13 08,22 AN U PALE RCH, PL
+561-255-1015|
+561-255-1015
+1.00
+1,00
+Usage
+4.00
+$.00
+• DE
+0.0D
+$.00
+$.00
+4.00
+0.0D
+0.0D
+0.0D
+Usage
+0.0D
+0.0D
+$.00
+0.0D
+$.00
+0.0D
+$.00
+•.00
+$.00
+•.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+Time Period
+PP.Peak Period
+OP-Off Peak Period
+MP-Muliple Period
+Long
+Distance
+D.D0
+D.D0 |
+D.DO
+D.DD
+0.D0
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+Total
+Charges
+9.00
+g.00
+9.00
+g.c0
+9.00
+9,00
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time Call To
+13 Jun 11 69:26 AM Inconing
+14 Jun 11 C8:47 AM Incoring
+15 Jun 11 09:50 AM N FAEM BCH ,PL
+16 Jun 11 09:01 AM W PALM BCH ,PL
+17 Jun 11 09:04 AM N RADA RCH, PL
+18 Jun 11 09:05 AM Inconing
+19 Jun 11 09:09 AM N FALM BCH, PL
+20 Jun 11 09:14 AM I PALA BCH,PL
+21 Jun 11 09:23 AM Inconing
+22 Jun 11 09:27 AM N FAIM BCH ,PL
+23 Jun 11 09.31 AM DEEREDECH,PL
+24 Jun 11 09:47 AM N FALE BCH, PL
+25 Jun 11 10:26 AM Inconing
+28 Jun 11 10:52 AM Inconing
+Jun 11 11:00 AM Inconing
+28 Jun 11 11:28 AM Incoelng
+Jun 11 11:33 AM Inconing
+Jun 11 11,33 AM W FAIM BCH.PL
+Jun 11 11:42 AM N PALM BCH, PL
+Jun 11 11:53 AM Inconing
+33 Jun 11 12:01 PM W PAIN BCH,PL
+34 Jun 11 12:04 EM Incordng
+Jun 11 12:09 PM Incondag
+36 Jun 11 12:12 IM BOCA RATON, PL
+Jun 11 12:19 IN W FALK BCH,PL
+38 Jun 11 12:24 PM Incondng
+39 Jun 11 12:26 IM N PALM BCH, PL
+Jun 11 12:34 PM Inconing
+41 Jun 11 12:47 EM Incondng
+Jun 11 12:59 IM Incoring
+43 Jun 11 01:02 IM Inconing
+44 Jun 11 01:30 PM Inconing
+45 Jun 11 01:35 EM Incondng
+46 Jun 11 01:36 PM Inconing
+47 Jun 11 01:42 IN N PALA BCH. PL
+Jun 11 02:03 PM W PALM BCH,PL
+49 Jun 11 02:05 PM N FAIM ACH, PL
+50 Jun 11 02:12 IN W PALM BCH .PL
+Jun 11 00:16 PM Inconing
+Jun 11 02:21 EM PALM BCH,PL
+Number
+561-965-4949
+561-965-4959
+561-236-6852
+561-365-4949 FP
+561-842-6414 FP
+561-123-1621 PD/CH
+561-644-9726
+561-615-0011
+5E1-23E-E852
+561-440-1706
+954-650-3393 PP
+5E1-3E5-4585 FD
+561-942-6414 PD
+561-502-3666
+561-122-0047
+5E1-341-4051
+561-202-8497
+561-358-7914
+561-129-0761
+561-723-1821
+561-385-7914
+561-723-1421
+561-662-E813 FF/CN
+561-368-5488P0
+561-765-4989 FP
+561-502-3866 PP
+561-352-7000
+Unava llable
+FF /NN
+561-541-4051 PP/NN
+561-659-3452
+FF /N3
+561-123-1621
+PD /CH
+561-541-4051 FF/NN
+561-502-5212
+PP /NN
+561-236-E852
+FP /CN
+561-202-7640 FF/NN
+561-502-7753 PP
+561-478-4388 FP
+561-478-4188
+561-965-4949
+561-123-1421
+Min: Sec
+6:00
+3:00
+2100
+1,00
+1:00
+9: 06
+2:00
++: 00
+Usage
+3:0D
+15,00
+1:0D
+3:00
+4:00
+1,00
+3: 0D
+1:00
+1,00
+1:0D
+1,00
+2100
+1:00
+3: 00
+4. 00
+2,00
+6: 0D
+1:00
+4: 00
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DĐ
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+D.DD
+Charges
+D.0D
+0,00
+0,00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time Call To
+54 Jun 11 02141 PM W PALK BCH, FL
+55 Jun 11 02:43 PM M PALA BCH, PL
+56 Jun 12 02146 FN Inconleg
+57 Jun 11 02:56 EN Inconing
+55 JulIa 03:15 Incalad
+59 Jun 11 03:31 IM Inconieg
+60 Jun 12 03:32 EN INCORINg
+81 Jun 11 03,34 PM W BALK BCH, PL
+82 лив 12 03:35 0 1nceleg
+83 Jun 11 03:48 EN W PALE BCH, PL
+84 Jun 12 03:53 EN Inconing
+65 Jun 11 04:06 PM 5 PALE BCH, PL
+87 Jun 12 04:19 PM Inconing
+88 Jun 11 04,25 PM M PALK BCH, PL
+09 Jun 11 04:29 IN INCORLEG
+70 Jun 11 04:44 PM M PALA BCH, PL
+71 Jun 11 04:52 IN Inconing
+12 Jun 11 05/10 m Inclag
+Jun 11 05:21 IN Incoming
+74 Jun 11 05:33 PM Inconleg
+75 Jun 112 05,59 PM N PALA BCH, PL
+76 JuE 11 DE:DE IN INCORLEG
+77 Jut 11 06:47 PM Inconiet
+78 Jun 12 06:55 PM M PALE BCH, PL
+79 Jun 11 06156 EM Inconleg
+BO Jun 11 07:09 PM M PALK BCH, PL
+81 Jun 12 08:59 AM INCOnLET
+82 Jun 12 09,31 AM N PALA BCH, PL
+Jun 12 10:31 AN M PALE BCH, PL
+B4 Jun 12 10:58 AM Inconing
+85 Jun 12 12:46 AM Inconley
+B6 Jun 12 01,03 PM Inconleg
+87 Jun 12 02:48 IN M PALE BCH, PL
+Jun 12 02,58 PM M BALK BCH, PL
+DO JuR 12 02:59 IN M PALE BCH. FL
+91 Jun 12 03:03 IN Inconieg
+92 Jun 12 03:12 IN INORIT
+03 Jun 12 03,30 PM M BALE BCH, FL
+94 JUL 1203:12 FA CEL
+Number
+561-723-1821
+561-662-6616
+561-723-1821 PP
+561-723-1821 PP
+561-723-1821
+561-505-5215
+561-352-7000 PP/CN
+561-502-5212
+561-541-5449 FP
+561-683-1816 FF
+561-502-7753 PP
+561-202-8497 PP
+561-686-9043 V9
+561-065-1989
+561-502-7753
+561-965-4989
+561-202-7640
+561-541-4051
+561-502-5212
+561-753-9832
+561-541-4051
+561-644-9726
+561-827-2542
+561-541-5449
+561-541-5449 PP/CW
+561-352-7000
+Unavaliable
+561-541-4051
+561-541-5443
+561-239-2245
+561-723-3440
+8
+8
+8
+8
+561-502-3866
+561-707-760D
+8
+561-502-3866
+561-964-5511
+561-723-1821
+561-723-1821
+8
+8
+8
+561-827-2542
+561-686-9043
+82T11E1AE
+8
+Min:Sec
+2:00
+6100
+1:00
+1:00
+2:00
+2:00
+3:00
+1:00
+2:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1.00
+1:00
+2:00
+2:00
+1.00
+1:00
+3:00
+2:00
+3,00
+4:00
+1:00
+2:00
+1:00
+3: 00
+2:00
+1:00
+1: 0a
+4:00
+1:00
+1:00
+6:00
+13:00
+1,00
+Usage
+4.00
+$.00
+• DE
+0.0D
+$.00
+•.0D
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+8.50 |
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.DD
+D.DD
+D.DD
+0.00l
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+0.D0|
+п nn
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time CallTo
+Number
+Footnote Min: Sec
+Usage
+95 Jun 12 03:37 EM Incondng
+561-315-0345
++: 00
+9 Jun 12 03:58 IM N PALM BCH, PL
+561-662-6688
+4:00
+97 Jun 12 04:02 PM BOCA RATON, PL
+561-362-6691
+110D
+98 Jun 12 04:33 EM N PREM BCH,PL
+561-502-5212
+2:00
+99 Jun 12 05:56 PM N RAIN RCH, PL
+561-707-TEDD
+1:00
+100 Jun 12 05:57 IM N PALM BCH, PL
+561-352-7000
+7:00
+101 Jun 12 06:07 PM N FALK BCH, PL
+561-352-3000
+2:00
+102 Jun 12 06:10 EM I PALM BCH ,PL
+561-352-7000
+2100
+103 Jun 12 06:11 IN N FALM RCH, PL
+5E1-6E2-EEBE
+1:0D
+104 Jun 12 06:12 IN W FALK BCH, PL.
+561-478-4168
+2:0D
+105 Jun 12 07.34 EM Inconing
+561-502-77530P
+3,00
+106 Jun 12 07:43 PM Incoring
+SE1-302-3753 OF
+19:00
+107 Jun 12 C8:51 IM Inconing
+301-608-0584 00
+108 Jun 12 09:17 PM Inconing
+561-502-7753 C8
+1:00
+109 Jun 13 08:21 AM N PALM BCH, PL
+561-723-3440
+110 Jun 13 08:15 AM N FALM RCH ,PL
+561-341-3449
+111 Jun 13 C8:32 AM Incoming
+561-723-3440
+112 Jun 13 09:55 AM W PALM BCH.PL
+561-502-5212
+Jun 13 10:23 AM PALA BOH,
+561-102-3212
+114 Jun 19 10:24 AM Incoring
+561-502-5212
+2:00
+4: 00
+1,00
+1:0D
+1:00
+115 Jun 13 10:34 AN FALK RCH,PL
+561-502-5212
+118 Jun 13 10:36 AM Incoring
+561-502-5212
+117 Jun 13 11:53 AM Incondug
+561-123-3440
+118 Jun 13 02:21 PM Incoring
+561-502-5212
+Jun 13 07:35 PM N FALM BCH ,PL
+561-333-7536
+1:00
+120 Jun 14 06:55 AM Incondng
+561-315-0345
+121 Jun 14 07:43 AM Inconing
+561-723-1621
+2:00
+Jun
+07:46 AM Inconing
+561-123-1621
+123
+Jun 1A
+07.47 AM BOYTONBCH, PL
+124
+Jun 14 08:30 AM Inconing
+Jun 14 09:31 AM BOYTONBCH, PL
+Jun
+14 08,38 AM Incordug
+Jun 14 08:45 AM Inconing
+Jun 14 08:47 AM Inconing
+130
+Jun
+=
+08:50 AM Incordug
+131 Jun 14 09:06 AM Inconlog
+132
+Jun 14 09:16 AM W PALM BCH ,PL
+Jun 14 09:25 AM Inconing
+Jun 14 09:25 AM W PALM BCH,PL
+135
+561-182-19C4
+561-503-5930
+561-577-6425
+772-223-0274
+561-177-6425
+561-502-5212
+561-723-3440
+561-478-4188
+561-615-0011
+561-324-7931
+561-324-7931
+:
+1:00
+2:00
+1,00
+2:00
+2:00
+$: 0D
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Changes
+D.0D
+0,00
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time Call To
+138 Jun 14 09:45 3M Inconing
+137 Jun 14 09:48 JM Toll Pree
+138 Jun 14 09:53 AN M PALK BCH, PL
+130 Jun 14 10:03 3M M BALK BCH, FL
+140 Jun 14 10:11 AM Inconleg
+141 Jun 14 10:15 AM Inconieg
+142 Jun 14 10:27 AN INCORleg
+143 Jun 14 10:33 JM Inconing
+144 Jut 14 10:41 JC M BALE BCH, VL
+145 Jun 14 10:51 AM M BALE BCH, PL
+146 Jun 14 12,06 AN U PALK BCH, PL
+147 Jun 14 11:40 AN Iscoeleg
+145 Jun 14 11:55 AM Inconing
+149 Jun 14 12:58 AN M PALE BCH, PL
+150 Jun 14 12/04 PM Inconing
+151 Jun 14 12:10 WN KIAMI, FL
+152 Jun 14 12:12 IN Incoming
+153 Ju 1+ 12,15 РН ЛОРІТЯ, РІ.
+154 Jun 14 12:19 IN M PALE BCH, PL
+155 Jun 14 12:29 IM Ieconieg
+156 Jun 14 12:33 PM M PALE BCH, PL
+157 Jun 14 12,36 PM M PATE BCH, PL
+158 Jun 14 12:38 IN M PALE BCH, PL
+159 Jut 14 12:57 PM Inconiet
+160 Jun 14 02:09 PM Inconing
+181 Jun 14 01:34 PM Inconing
+162 Ju 14 01:54 IM Icceler
+163 Jun 14 02:06 PM M PALE BCH, PL
+184 Jun 14 02127 PM Inconing
+165 J.
+14
+02:29 PM Incoeleg
+105 Jut 14 02:36 IN MIAMI, PL
+167 Jun 14 02:38 PM M BALE BCH, PL
+165 Jun 14 02141 PM N BALK BCH, FL
+180 Jun 14 03:05 IN INCORLET
+170 Jum 14 03:09 М Інопіт
+171 Jun 14 03:18 PM Incon/eg
+172 Ju 14 03:20 # Incle
+173 Jun 14 04:07 # Інсонівт
+174 Jun 14 04:16 #N
+175 Jun 14 04,17 PM Incoming
+Number
+561-820-3949
+800-730-7201
+561-541-4051 PP
+561-324-7931 PP
+561-541-4051 FF
+561-324-7931 P
+561-655-7027 FF
+954-730-9676 PP
+561-478-4168 FP
+561-478-4188 FF
+561-615-0011 PP
+561-723-1821 PP
+561-202-8497 V9
+561-228-1821
+305-796-3825
+561-723-1821
+561-262-0911
+561-478-4188
+561-478-4188
+561-478-4188
+561-615-0011
+561-723-1821
+561-478-4188
+561-723-1821
+561-697-4835
+561-478-4188
+561-615-0011
+561-478-4188
+561-723-1821
+305-796-3825
+561-541-4051
+561-478-4188
+561-820-1195
+561-478-4188
+561-502-5212
+561-503-8429
+561-714-1522
+561-478-4168
+561-714-1522
+561-202-8497
+Min:Sec
+3,00
+1100
+1:00
+1:00
+1:00
+2:00
+2:00
+3:00
+2:00
+3:00
+4:00
+2:00
+2:00
+3:00
+5:00
+2:00
+3:00
+1.00
+1:00
+2:00
+3:00
+2:00
+1:00
+1:00
+T=00
+2:00
+3:00
+1.00
+1: 0a
+3:00
+2:00
+2:00
+2:00
+1:00
+1:00
+Usage
+4.00
+$.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+8.00 |
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+0.D0|
+п nn
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time CallTo
+Number
+Footnote
+Min: Sec
+177 Jun 14 04:24 EM N PALM BCH, PL
+561-662-4444
+5100
+178 Jun 14 04:45 IM N PALM BCH, PL
+561-842-6414
+1:00
+179 Jun 14 04:52 PM Inconing
+561-503-4429 FP
+2100
+180 Jun 14 04:53 EM Incondng
+561-502-5212
+PP/CN
+181 Jun 14 04:59 PM N FALA BCH, PL
+561-062-EE8E
+4: 0D
+182 Jun 14 05:03 IM N PALM BCH, PL
+561-842-6414
+183 Jun 14 05:04 PM N FALK BCH, PL
+561-445-3546
+5:00
+184 Jun 14 05:13 EM FTLAUDERDC,PL
+954-581-4200
+185 Jun 14 05:23 #N Inconing|
+5E1-202-8497
+1:0D
+180 Jun 14 05:24 FM W FALK BCH, PL
+561-127-1421
+9:00
+187 Jun 14 06.04 EM Inconing
+561-502-5212
+3,00
+188 Jun 14 06:25 IN LAUREI.,MD
+240-393-4162 FD
+2:00
+189 Jun 14 06:28 IM W PALM BCH, PL
+561-951-1444 PD
+2:00
+190 Jun 14 06:35 PM W FALK BCH, PL
+561-644-4949
+1100
+191 Jun 14 06:36 PM W PALM BCH, PL
+561-333-7530
+1,00
+192 Jun 14 06:58 PM N FALM RCH, PL
+5E1-202-8497
+1:0D
+Jun
+:
+07:13 W Incoming
+561-541-5449
+10:00
+1+ 07:33 PM Incondng
+561-541-5449 pP
+1,00
+Jun
+15 06:49 AM Inconleg
+561-827-2542
+Jun
+06:51 AM Inconing
+561-723-3440
+0P/CH
+197 Jun 15 06:56 AM N PAIN ECH, PL
+561-502-7753 CF
+198 Jun 15 06:56 AM Incordng
+561-502-7753
+190 Jun 15 O6:59 AM N PALM BCH, PL
+561-582-19C4
+200 Jun 15 07:03 AM Incoring
+561-827-2542
+201
+Jun 15 07:10 AM N FALM BCH ,PL
+561-541-4051
+1:00
+Jun 15 07:25 AM Incondng
+561-202-9497
+R
+Jun 15 07:27 AM PLAUDERD, PL
+954-444-3066
+Jun
+15
+07:36 AM PILAUDERDG,PL
+954-581-4300
+205
+Jun 15
+07:47 AM W PALM BCH,PL
+561-615-0011
+4:00
+3: 00
+1,00
+206
+07:50 AM Inconleg
+561-364-5511
+207
+Jun 15 C8:04 AM BOYTONBCH, PL
+561-503-5449
+1:00
+Jun 15 08:22 AM Inconing
+561-790-5347
+209
+Jun
+15 08:27 AM Incondug
+561-354-7914
+2,00
+210 Jun 15 08:06 AM Inconing
+561-23E-EE52
+211 Jun 15 09:11 AM Inconing
+561-434-9697
+П
+Jun 15 09:21 AM W PALM BCH ,PL
+561-662-6648
+213 Jun 15 09:36 AM Inconlog
+561-122-3311
+214 Jun 15 09:52 AM Incoring
+561-423-2542
+5:00
+$:0D
+3: 00
+215
+Jun 15 09:57 AM Inconing
+561-502-7753
+218
+Jun 15 10:02 AM Incondng
+561-582-9575
+1,00
+217
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+0.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time Call To
+218 Jun 15 10:17 3M Inconing
+219 Jun 15 10:20 AM Inconieg
+220 Jun 15 18:33 AN Incoming
+221 Jun 15 10:44 AM Inconing
+222 Jan 15 12:07 An Inconlea
+223 Jun 15 11:15 JM M PALA BCH, PL
+224 Jun 15 12:19 AN IncomiNg
+225 Jun 15 11,58 AN U BALK BCH,PG|
+226 Jut 15 12:12 IN M BALE BCH, VL
+227 Jun 15 12:19 IN Incoming
+228 Jun 15 12/25 EN Inconing
+229 Jun 15 12:38 IN JUPITER, FL
+230 Jun 15 12:42 PM 5 PALK BCH, PL
+231 Jun 15 12:44 IN M BALE BCH, PL
+232 Jun 15 12:51 EM M BALK BCH, FL
+233 Jun 15 12:57 W Iscoeleg
+234 Jun 15 01:00 IN Incoming
+235 Jun 15 01,10 PM N PALA BCH, PL
+236 Ju 15 01:33 IN M PALE BCH, PL
+237 Jun 15 01:38 PM M DALK BCH, PL
+238 Jun 15 03:43 PM Inconleg
+230 Jun 15 01:45 PM M BALA BCH, PL
+240 Ju 15 01:46 IN M PALE BCH, FL
+241 Jun 15 01:55 PM MIAMI, PL
+242 Jun 15 02:01 PM Inconleg
+243 Jun 15 02:12 PM Inconing
+244 Jun 15 02:15 PM Inconley
+245 Jun 15 02:28 IN Incoming
+240 Jun 15 02:19 PM M BALA BCH, PL
+247
+15 02:19 IN Inconleg
+245 Jun 15 02:20 IM Inconieg
+249 Jun 15 02:21 PM IncOnleT
+250 Jun 15 02:35 PM Inconleg
+251 JuR 15 02:36 IN BOCA ZATON, FL
+252 Jun 1502:58 PM TAUDERD,PL
+253 Jun 15 02159 IN FTLAUDERDL, FL
+254 Jun 15 02:59 m Inconleg
+255 JuR 15 03:01 IN PILAUDERDL, PL
+257 Jun 15 03,25 PM Inconleg
+258 JUL 15 03:28 PALE BOL
+Number
+561-478-4188
+561-964-5511
+561-827-2542
+561-478-7760 PP
+561-827-2542 FF
+561-582-1964 P9
+561-502-7753 FF
+561-964-5511 PP
+561-358-7914 FP
+561-503-5930 FF
+561-358-791+ PP
+561-262-0911 PP
+561-478-4188 V9
+561-541-4051 PP
+561-683-1816
+561-951-1444
+Unavailable
+561-478-4188
+561-358-7914
+561-255-2520
+561-644-9726
+561-616-8240
+561-644-9726
+305-796-3825
+561-358-7914
+561-478-4833 PP
+561-644-9726
+561-616-8240
+561-644-9726
+561-827-2542
+561-616-8240
+561-687-8791
+561-202-8497
+561-105-948D
+954-587-8220
+954-587-8220
+561-833-3002
+954-587-8220
+954-587-8220
+561-582-2164
+PP/CN
+Min:Sec
+2:00
+9:00
+2:00
+1:00
+2:00
+2:00
+1:00
+1:00
+4:00
+1:00
+1:00
+1:00
+1:00
+5.00
+1:00
+2:00
+2:00
+1:00
+2:00
+1:00
+1:00
+1:00
+1:00
+1: 00
+1:00
+1:00
+1.00
+4: 00
+2:00
+2:00
+1:00
+2:00
+2:00
+1,00
+Usage
+4.00
+$.00
+4.DD
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.00 |
+п nn
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time CallTo
+Number
+Footnote
+Min: Sec
+259 Jun 15 04:11 EM Incondng
+954-444-6836
+5100
+280 Jun 15 04:53 IM N PALM BCH, PL
+561-502-5212
+1:00
+281 Jun 15 04:53 PM Inconing
+561-502-5212 FF/CH
+110D
+282 Jun 15 04:56 PM PILAUDERDG, PL
+954-587-9724 FP
+1,00
+283 Jun 15 04:56 IN PTLAUDERD, PL
+954-587-8220
+2:00
+254 Jun 15 04:59 IM N PALM BCH, PL
+561-478-4188
+1:00
+285 Jun 15 05:05 PM N FALK BCH, PL
+561-845-9004
+1100
+208 Jun 15 05:31 EM BOCA RATON, PL
+561-305-3440
+267 Jun 15 05:32 IN BOCA RATON, PL
+5E1-105-3480
+288 Jun 15 05:40 PM Inconing
+561-541-5449 FP
+280 Jun 15 05:55 EM Inconing
+561-502-5212
+2,00
+270 Jun 15 06:15 IN N FADE RCE, PL
+5E1-364-3511 FD
+5:0D
+271 Jun 15 06:28 IM Incoring
+561-502-5212
+2:00
+272 Jun 15 06:40 PM Inconing
+561-541-5449
+4: 0D
+273
+15 07:07 EM Inconing
+561-502-5212
++100
+274 Jun 15 07:29 PM Incoring
+5E1-202-8497
+1:0D
+275
+Jun
+15
+07:32 I Inconing
+561-434-9897
+3:00
+278
+16 06:47 AM W PALM BCH, PL
+561-502-366E
+1,00
+277
+Jun
+16 07:15 AM Incondag
+561-364-5511
+278
+Jun
+07:21 AM Incoring
+561-964-5511
+279 Jun 16 07:33 M Inconing
+561-764-5511
+4:00
+Jun 16 07:60 AM N PALM BCH, ,PL.|
+561-541-4051
+281 Jun 16 07:53 AM N FALA RCH, PL
+561-122-1632
+282 Jun 16 08:21 AM Incoring
+561-432-5325
+R
+Jun 16 09:24 AM N FALM BCH ,PL
+561-723-3440
+2:00
+284 Jun 16 09.27 AM Inconing
+561-503-5930
+285 Jun 16 09:24 AM Incoring
+561-255-2520
+288
+Jun 16 09:27 AM Inconing
+561-123-1621
+287
+Jun 16 09:28 AM Incondng
+561-474-4148
+9:00
+3: 00
+2,00
+288
+00:55 AM N FALM RCH, PL
+561-121-1212
+2: 00
+289
+Jun 16
+09:58 AM W PALM BCH, PL
+561-502-5212
+2:00
+280 Jun 16 AM AMN PALM BCH,PL
+561-315-0345
+291 Jun 16 10:05 MM Inconing
+S61-474-4148
+6:00
+292 Jun 16 10:10 AM BOCA RATON,PL
+561-JC8-3488|
+R
+Jun 16 10:12 AM W PALM BCH ,PL
+561-123-3421
+Jun 16 10:16 AM Incondug
+561-686-9977
+295 Jun 16 10:21 AM N PALM BCH, PL
+561-252-4654
+Jun 16 10:26 AM Incoring
+561-432-2239
+1:00
+5:00
+2:00
+1:00
+297
+Jun 16 10:31 AM Inconing
+561-329-0743
+298 Jun 1610:40 AMN PALM BCH.PL
+561-123-1421
+299
+10:84 A FAN CHUL
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+0.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time Call To
+300 Jun 16 11:03 3M Inconing
+301 Jun 16 11:19 AM BOYTONECH, PL
+302 Jun 16 13:20 AN POMPANORCH, PL
+303 Jun 16 11/21 AM Inconing
+304 Jun 16 11:27 AM INcoRleg
+305 Jun. 16 11:30 AM FILAUDERDL, PL
+305 J 16 12:35 JМ Inconing
+307 Jun 16 11:41 AN FILAUDERDG, PG|
+308 Jut 16 11:4E AN Incoeleg
+309 Jun 16 12/16 PM W BALK BCH, PL
+310 Jun 16 12:20 PM N PALK BCH, PL
+311 Jun 1€ 12:23 W Incoeleg
+312 Jun 16 12:26 IM Inconieg
+313 Jun 16 12:27 PM CHARLOTTE, NC
+314 Jun 16 12:33 EN Inconing
+315 Jun 16 12:34 IN M PALE BCH, PL
+316 Jun. 16 12:37 PM M PALA BCH, PL
+317 Jun 16 12,48 PM N PALA BCH, PL
+318 Ju 1€ 12:50 IN M PALE BCH, PL
+319 Jun 16 12:52
+IN 5 PALK BCH, PL
+320 Jun 16 12:55 PM M PALE BCH, PL
+321 Jun 16 12,59 PM Inconing
+322 Jun 16 01:01 IN M PALE BCH, PL
+323 Jun 16 01:03 PM Inconiet
+324 Jun 1€ 02:08 PM Inconleg
+325 Jun 16 01:09 PM Inconing
+325 Ju 16 01:12 PM Inconley
+327 Jun 16 02:16 PM Inconieg
+328 Jun 16 01,18 PM Inconleg
+329 JuR 1€ 01:20 IN INCEleT
+330 JuR 16 01:22 IN INcoRieT
+331 Jun 16 02:27 PM M BALE BCH, FL
+332 Jun 16 01:34 PM Inconleg
+333 JuR 16 01:38 W IncaleT
+334 Jun 16 02:40 IN BOYTONECH, FL
+335 Jum 16 01,51 PM Incon/eg
+338 Jun 16 02:01 IN IncoRleg
+337 Jun 16 02:07 # Іксовівт
+338 Jun 16 0a:17 IN
+330 Jum 16 02121 PM Inconleg
+340 JUL 16 02:31 PM PALE BO.PL
+Number
+561-478-4188
+561-577-6425
+954-971-9222
+561-305-9480 PP
+561-577-6425 PP/CN
+954-ALA-T0E6
+561-478-4188
+954-587-8220 PP
+561-723-1821 PP
+561-723-3440 FF
+561-833-3002 PP
+561-723-1821 PP
+561-202-8497 PP/CN
+704-364-5840 PP
+561-478-5890
+561-EG2-EGEB
+561-723-1821
+561-582-1964
+561-805-6700
+561-805-6700
+561-805-6700
+954-587-8220
+561-805-6700
+561-723-1821
+561-659-2911
+561-659-2911
+561-659-2911
+561-832-9036
+561-659-2916
+561-659-9899
+561-723-1821
+954-444-8097
+561-503-5930
+561-577-6425
+561-478-7760
+561-723-1821
+561-478-5890
+561-202-8497
+561-721-1821
+Min:Sec
+1:00
+1100
+3:00
+2:00
+1:00
+3:00
+2:00
+1:00
+4:00
+3:00
+4:00
+2:00
+1:00
+3:00
+2:00
+2:00
+4:00
+1.00
+1:00
+4: 00
+1:00
+1:00
+1:00
+1:00
+1:00
+1: 00
+1:00
+1:00
+3:00
+1: 0a
+2:00
+4:00
+2:00
+5:00
+4:00
+1,00
+2:00
+Usage
+4.00
+$.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+$.00
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+0.D0|
+п nn
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time CallTo
+Number
+Footnote Min: Sec
+341 Jun 16 02:40 EM W PALM BCH,PL
+561-723-1421
++:00
+342 Jun 16 02:45 IM N PALM BCH, PL
+561-478-5890
+2:00
+343 Jun 16 02:57 PM W FALK RCH, PL
+561-662-6648
++: 0D
+344 Jun 16 03:10 EM BOCA RATON, PL
+561-364-5498
+1,00
+345 Jun 16 03:28 PM Inconlog
+561-615-3213
+3: 0D
+346 Jun 16 04:13 I Incoring
+561-122-3311
+347 Jun 16 64:26 PM N FALM BCH, PL
+561-122-3311
+1:00
+348 Jun 16 05:09 PM BOYTONBCH, PL
+561-577-6425
+349 Jun 16 05:10 IN N FALM BCH, PL
+5E1-502-1753
+350 Jun 16 05:12 PM Inconing
+561-723-3440 FP/CH
+1:0D
+351 Jun 16 05:16 EM Inconing
+561-723-3440PP/CN
+3,00
+352 Jun 16 05:20 PM N FALA BCH, PL
+5E1-123-3440 FD
+1:0D
+353 Jun 16 05:23 IM W PALM BCH, PL
+561-798-3549 P0
+3:00
+354 Jun 16 05:34 PM Inconing
+561-541-5449 FP
+355 Jun 16 05:43 EM Incondng
+561-502-7753 PP/C
+3,00
+Jun 17 06:42 AM Incoring
+561-712-3018 OF
+4: 00
+Jun 17
+07:41 AM W PALA BCH ,PL
+561-333-7530
+2:00
+Jun 17 07:44 M W FAIM BCH,PL
+561-358-7914
+1:00
+350
+Jun 17 07:48 AM N PALM BCH, PL
+561-333-7530
+380
+Jun 17
+08:05 AM W PALM BCH, PL
+561-356-7914
+2: 0D
+1:00
+381 Jun 17 08:05 AM N PALM RCH,PL
+561-718-0935
+382 Jun 17 09:06 AM Incordng
+561-722-3311
+2,00
+383 Jun 17 08:13 AM Incondag
+561-358-7914
+364 Jun 17 08:20 AM N PALM BCH,PL
+561-644-9726
+305 Jun 17 08:21 AM N FALA BCH,PL
+561-687-3636
+1:00
+300 Jun 17 09:22 AM N PALM BCH,PL
+561-687-3636
+307 Jun 17 08:29 AM BOYTONECH, PL
+561-436-2106
+1:00
+388 Jun 17
+08:30 AM BONTONECH, PL
+561-434-210€
+Jun 17
+09.35 AM W PALM BCH,PL
+561-687-3636
+370
+Tun
+08=45 AM Inconing
+561-305-3480
+2: 00
+371
+Jun 17
+08:46 AM W PALM BCH, PL
+561-478-4168
+2:00
+Jun 17 08:48 AM N PAEN BCH,PL
+561-502-7753
+373
+Jun
+17 08.56 AM Inconing
+561-305-3480
+1,00
+374
+Jun 17 Ca:SE AM Inconing
+561-121-1821
+FP /CN
+375
+Jun 17 09:07 AM W PALM BCH, PL
+561-722-3311 FP
+378
+Jun
+=
+09:07 AM Inconing
+561-722-3311 PP/CH
+377
+Jun 17 00:18 AM N FALO BCH.UL
+5E1-122-3311 FE
+Jun 17 09:26 AM W PALM BCH PL
+561-478-4188
+1:0D
+1:00
+379 Jun 17
+09:29 AM N PALK BCH,PL
+561-722-3311
+Jun 17
+09:32 AM Incondng
+561-122-3311
+381 Jun
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+0.00 |
+D.0D
+0.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time Call To
+382 Jun 17 09:50 AM M BALK BCH, FL
+383 Jun 17 09:51 AM M PALA BCH, PL
+354 Jun 17 09152 AN M PALK BCH, PL
+365 Jun 17 10/11 AM Inconing
+350 Jun 17 10:19 1м Incorleg
+387 Jun. 17 10:22 AM Inconing
+368 Jun 17 10:24 AN IncomiNg
+360 Jun 17 10:58 JM Inconing
+390 J 17 11:01 M M FAL ECH, FL
+391 Jun 17 11:04 14 Inconleg
+302 Jun 17 11/20 AN Inconing
+383 Jun 17 11:31 AM INcoRleg
+394 Jun 17 11:40 AM Inconieg
+305 Jun 17 12:43 AN Inconleg
+306 Jun 17 11,50 AM M BALK BCH, FL
+397 Jun 17 12:21 W Iscoeleg
+388 Jun. 17 12:25 IN M PALA BCH, PL
+309 Jun 17 12129 IN Inconing
+400 Ju. 17 01:12 # Iscoeleg
+401 Jun 17 01:14 PM 5 PALK BCH, PL
+402 Jun 17 03:27 PM Inconleg
+403 Jun 17 01,19 PM M PATE BCH, PL
+404 Jun 17 01:19 IN M PALE BCH, FL
+405 Jun 17 01:21 PM 5 PALK BCH, PL
+405 Jun 17 01:26 FM INCOmiNg
+407 Jun 17 01,28 PM M BALE BCH,FL
+408 Jun 17 01:30 PM 5 PALK BCH, PL
+409 Jun 17 03:37 PM M PALE BCH, PL
+410 Jun 17 02,52 PM M BALA BCH, PL
+411 Ju
+17 02:02 IN M BALAC BOTE, FL
+412 Jut 17 02:10 IN Inconieg
+413 Jun 17 02:16 PM IncOnleT
+414 Jun 17 02:28 PM N BALA BCH, FL
+415 Ju 17 02:32 # M PALE BCH, FL
+418 Jun 17 02:59 PM MALE BCH, PL
+417 Jun 17 03:02 EM Inconing
+418 Jun 17 03:03 PM M PALE BCH, FL
+419 Jun 17 03:06 PM M PALA BCH,PL
+420 Jun 17 03:09 PM M BALE BCH, PL
+421 Jun 17 03111 IN W BALK BCH, FL
+422 Jun 17 03:12 IN Inconleg
+Number
+561-667-4222
+561-502-5123
+Min:Sec
+561-662-6616 PP
+561-863-9964 PP
+561-848-8172 FF
+561-508-5930
+561-863-9964 FF
+561-667-4222 PP
+561-723-3440
+561-202-8497 FF
+561-478-4188 PP
+561-85E-43D6 PP
+561-502-3866 V9
+561-233-1455
+561-723-3440
+561-478-4188
+561-478-4188
+561-577-6425
+561-790-1722
+561-723-1821
+561-723-3440
+PP/CN
+561-727-1440
+561-723-1821
+561-644-9726
+561-723-3440
+561-644-9726
+561-541-4051
+561-723-1440
+561-723-3440
+561-721-5212
+561-723-3440
+561-842-6416
+561-723-3440
+561-352-7000
+561-841-9007
+561-352-7000
+561-829-2542
+561-358-7914
+561-662-6688
+D80L502502
+PP/CN
+PRICH
+1:00
+1100
+2:00
+2:00
+2:00
+1:00
+1:00
+1:00
+1:00
+6100
+3:00
+1:00
+1:00
+1:00
+4: 00
+2100
+3:00
+4: 00
+2:00
+1,90
+2:00
+2:00
+2:00
+1:00
+1:00
+2:00
+T=00
+7:00
+1:00
+4:00
+1: 0a
+4:00
+2:00
+1:00
+3:00
+1:00
+$100
+1:00
+Usage
+4.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+8.00 |
+0.0D
+0.0D
+0.0D
+8.50 |
+• 0[
+0.0D
+•.00
+9,00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.DD
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+0.D0|
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time CallTo
+423 Jun 17 03:15 EM Incondng
+424 Jun 17 03:23 IM N PALM BCH, PL
+425 Jun 17 03:27 PM W FALK RCH, PL
+420 Jun 17 03:24 PM Toll Free
+427 Jun 17 03:29 PM N RADA BCH, PL
+Jun 17 64:02 I Inconing
+429 Jun 17 S4:04 PM Inconing
+430 Jun 17 (4.33 EM Incondng
+431 Jun 17 04:15 #N Inconing
+432 Jun 17 04:17 PM W FALA BCH, PL
+433 Jun 17 04:34 PM Inconing
+434 Jun 17 05:03 IN N FALE RCE, PL
+435 Jun 17 05:05 IM Inconing
+436 Jun 17 05:07 PM W FALK BCH,PL
+437 Jun 17 05:10 EM W FALM BCH, PL
+438 Jun 17 05:32 PM Incoring
+Jun 17 05:39 I Inconing
+Jun 17 05:44 EM Incondng
+441 Jun 17 06:04 PM Incondag
+442
+Jun 17 06:13 IM W PALM BCH, PL
+443 Jun 17 06:54 PM Inconing
+444 Jun 17 07:29 PM W PALM BCH,PL
+445 Jun 17 07:39 PM Inconiag
+446 Jun 18 06:58 AM N PALM BCH ,PL
+447 Jun 18 07:04 A N FALA BCH, PL
+448 Jun 18 07.11 AM Inconing
+449 Jun 18 07:19 AM Incoring
+Jun
+07:32 AM Inconing
+07:43 AM Incondng
+07:53 AM Inconing
+Jun 18
+08:05 AM W PALM BCH,PL
+454 Jun 18 08:05 AM Inconing
+Jun
+1A 08,08 AM Incondug
+456 Jun 1a 08:10 AM Incoeing
+Jun 18 08:12 AM W PALM BCH.PL
+458
+Jun 18 09:13 AM BOYTONECH, PL
+430 Jun 18 08:14 AM Inconlog
+Jun 18 Ca:16 AM I PALM BCH,PL
+481 Jun 18 04:34 AM N PALM BCH.PL
+482 Jun 18 08:20 AM W FALM BCH, PL
+483
+Ca:ZE AM Incorlea
+Number
+Footnote Min: Sec
+561-722-0047
+PP /CN
++: 00
+561-662-6688
+4:00
+561-352-1000
+1100
+900-344-3498
+1,00
+561-689-6733 FP
+1:00
+561-577-6425
+4:00
+561-427-2542
+2:00
+561-714-1522
+Unava ll able
+S61-352-3000 FF
+561-927-2542 PP
+5E1-255-3725 FD
+561-964-5511 PD/CN
+561-478-4188 FP
+2,00
+3: 0D
+1:00
+3:00
+561-474-4148 PP/NN
+561-434-3697 FD
+561-965-5507
+3: 0D
+3:00
+561-541-5449
+561-103-5930
+561-662-6616
+56L-722-6047
+561-762-2474
+561-842-2050
+561-795-9549
+561-358-7914
+3,00
+5: 0D
+1:00
+1:00
+561-427-2542
+561-502-5212
+561-354-7914
+561-624-4701
+9:00
+1:00
+1,00
+452
+561-102-1212
+561-795-9549
+561-502-5212
+S61-474-4148
+1:00
+2:00
+1,00
+561-801-6445
+:
+561-502-1753
+561-503-5930
+361-102-7753 FP/CN
+561-798-4900
+1,00
+1:0D
+1:00
+561-714-6548
+561-502-7753
+010.1152
+2:0D
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+0.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time Call To
+454 Jun 19 08:30 3M Inconing
+465 Jun 14 08:32 AM M PALA BCH, PL
+406 Jun 14 DE146 AN M PALE BCH, PL
+487 Jun 14 08148 3M M BALK BCH, FL
+455 лип 18 D8:52 АМ ВОУТОВЕСИ, Г.
+489 Jun 14 09:02 AM Incoeleg
+470 Jun 14 09:03 AN INCOmINg
+471 Jun 14 09:10 JM Inconing
+472 Jut 14 08:13 AN Incoeleg
+473 Jun 14 09119 AN M PALK BCH, PL
+474 Jun 18 09/22 AN Inconing
+475 Jul 1# 10:0E AN Iscoeleg
+476 Jun 14 10:07 AM Inconing
+477 Jun 14 10:10 AN Inconleg
+478 Jun 14 10:14 AN Inconing
+479 Jun 1# 10:26 AN Iscoeleg
+480 Jun. 1# 10:36 AM I PALA BCH, PL
+481 Jun 14 10,38 AM N PALA BCH, PL
+482 JuL 1# 10:38 N M PALE BCH, FL
+483 Jun 14 10:57 AM Incoming
+454 Jun 14 12:25 AM Inconleg
+485 Jun 14 11,27 AM I PAT BCH, PL
+Number
+561-502-7753
+561-RAD-1446
+561-723-3440 PP
+561-863-9964 PP
+561-503-5449 FF
+561-722-3311 PP
+561-541-5449 PP/CN
+561-502-7753 PP
+561-863-9964 FP
+561-502-7753 FP
+561-255-2520 PP/CN
+561-784-1405 PP
+561-202-849719
+561-202-8497 PP
+561-747-2467
+561-547-0346
+561-723-3440
+561-719-1538
+561-719-1531
+561-719-1531
+5E1-478-418R
+487 Jun 1# 11:37 AM Inconiet
+458 Jun 14 12:44 /M Inconing
+450 Jun 14 12:05 PM M BALA BCH, PL
+490 Jun 1# 12:07 PM M PALK BCH, PL
+491 Jun 14 12:20 IN FTLAUDEADL, PL
+492 Jun 19 12:15 PM Inconing
+483 Jun 18 12:16 mIscoeleg
+494 Jun 1# 12:30 PM M PALK BCH, PL
+Jun 14 12:37 #N Inconleg
+495 Jun 19 12:40 PM Inconleg
+497 Jun 18 12:43 W BOTTONECH, FL.
+498 Jun 14 02:23 PM M PALE BCH, PL
+Jun 14 01:26 IN Inconing
+500 Jun 1801:27 # Incleg
+501 Jun 1# 01:27 PM M PALA BCH,PL
+502 Jun 1403:28 IN PALE BON, PL
+503 Jun 1# 01:38 EN Inconing
+504 JuR 18 01:49 PN Inconleg
+561-744-3618 FF
+561-744-3618 PP
+561-723-1821
+561-478-4188 PP
+561-352-7000
+954-581-4200
+561-502-5212
+561-541-5449
+PP /CN
+561-502-5212
+561-503-5930
+561-723-1821
+561-503-5930 PP
+561-687-3636 PP
+561-541-5449
+PP/CW
+561-358-7914 FP/CN
+561-352-7000
+561-358-7914
+561-687-3636
+Min:Sec
+2:00
+2100
+2:00
+1:00
+1:00
+1:00
+1:00
+2:00
+4:00
+2:00
+1:00
+1:00
+1:00
+2:00
+5:00
+2:00
+2:00
+1:00
+1.00
+5,00
+5:00
+1:00
+2:00
+2:00
+3:00
+3:00
+3,00
+2:00
+1:00
+1:00
+3:00
+1: 0a
+3:00
+2100
+1:00
+1:00
+1:00
+1:00
+2:00
+Usage
+4.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+8.00 |
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+0.D0|
+п nn
+corticued.
+Total
+Charges
+9.00
+a.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time CallTo
+Number
+Footnote
+Min: Sec
+506 Jun 18 02:00 PM Incordng
+561-577-5425
+2:00
+506 Jun 18 02:36 IM Inconing
+561-202-8497
+1:00
+507 Jun 18 02:37 PM JUPITER, PL
+561-745-4668 FP
+110D
+508 Jun 18 02:42 EM Inconing
+561-745-9848 FP
+2:00
+509 Jun 18 02:53 PM A RAIN BCH, PL
+561-889-4973 FP
+2:00
+510 Jun 18 03:02 I Incoring
+561-889-4973 PP
+1. 06
+511 Jun 18 03:10 PM Inconing
+561-795-6201 FP
+1:00
+512 Jun 18 03.11 EM W PALM BCH,PL
+561-541-5449 PP
+513
+Jun 18 03:15 #M Inconing
+5E1-795-620D
+514 Jun 18 03:27 PM W FALA BCH, PL
+SE1-541-4051
+515 Jun 18 03:33 PM W PALM BCH,PL
+561-723-1421
+2,00
+516 Jun 18 09:36 IN N FALE RCH, PL
+SE1-302-3BEE FD
+1:0D
+517 Jun 18 09:41 IM N PALA BCH, PL
+561-723-1821
+518 Jun 18 03:41 PM N FALK BCH, PL
+561-202-3640 FP
+3:00
+519
+Jun 18 03:45 PM Incondng
+561-474-4148
+Jun 18 04:1E IN N PALM RCH, PL
+5E1-6E2-ECEE FU
+3: 0D
+18
+04:19 IM W PALM BCH, PL
+561-352-7000
+3:00
+04:22 PM Incondng
+561-723-3440 PP/C
+1,00
+Jun
+04:23 IN N PALM BCH, PL
+561-062-ECEE FP
+574
+:
+04-28
+561-352-7000 00
+2:00
+525 Jun 18 04:29 PM N PALM RCH,PL
+561-502-3753 FF
+526
+Jun 18 04:34 PM Incondng
+561-667-4222
+pp/CH
+6:00
+1,00
+Jun 18 05:14 IN Inconing
+561-103-5930 FP
+528
+Jun 18 05:14 IM N PALM BCH ,PL
+561-723-3440 PD
+Jun
+:
+05:22 PM W PACK BCH, PL
+561-541-5449
+2:00
+Jun 18 05:23 EM W PALM BCH,PL
+561-502-5212
+531 Jun 18 05:27 IN N PALM BCH,PL
+561-644-4989
+Jun
+05:32 PM N FALM BCH ,PL
+561-585-4211
+533
+05:43 EM W PALA BCH,PL
+561-502-5212
+6:00
+3: 00
+1,00
+534
+05:47 IN BOETONACH, VL
+561-103-8428
+Jun
+06:51 PM Incoring
+561-502-5212
+536
+Jun 18 07:41 PM Inconing
+561-541-5449
+537
+Jun
+19 07:64 AM W PALM BCH,PL
+561-502-7753
+2:00
+1,00
+538
+Jun 19 07:53 AM Inconing
+561-141-3443
+539
+Jun 19 07:55 AM Inconing
+561-541-5449
+1:00
+540
+Jun
+19 08,07 AM Incondug
+561-502-7753
+Jun 13 08:11 AM Inconng
+561-102-7753
+542
+Jun 19 09:37 AM Incoring
+561-502-1753
+2:00
+2:00
+543
+Jun 19 10:05 AM N PALM BCH,PL
+561-964-5512
+544 Jun 19 10:06 AM BOYTONBCH, PL
+561-503-5930
+545
+Jun 19 10:14 AM N FAIN OCH .PL
+5EL-ED2-2281
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+0.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time Call To
+546 Jun 19 10:21 3M M BALK BCH, FL
+547 Jun 19 10:22 AM Inconies
+545 Jun 19 13119 AN Inconleg
+549 Jun 19 11,32 3M M BALK BCH, FL
+550 Ju. 17 11:14 A BOSTONCH, F.
+551 Jun 19 11:37 AM BOYTONBCH, PL
+552 Jun 19 11:41 AN IncomiNg
+553 Jun 19 11142 3M M BALK BCH, FL
+554 Jut 19 12:15 IN Incoeleg
+555 Jun 19 12:25 PM M BALK BCH, PL
+558 Jun 19 12141 PM N PALK BCH, PL
+557 Jul 19 12:47 IN M PALE BCH, VL.
+558 Jun. 19 12:56 IM I PALK BCH, PL
+559 Jun 19 01:01 EN Inconleg
+580 Jun 19 01:02 PN M PALK BCH, FL
+581 Jun 13 01:0E IN BOTTONICH, FL
+562 Jun 19 01:15 PM M PALK BCH, PL
+583 Jun 19 02:00 PM Inconing
+564 Ju 19 02:11 W Inceled
+565 Jun 19 03:12 IM Isconieg
+566 Jun 19 04:06 PM M PALE BCH, PL
+587 Jun 19 04:14 PM BOCA RAZON, PL
+568 Jun 19 04:14 IN INHEL, MD
+509 Jun 19 04:17 PM Incorlet
+570 Jun 19 04:43 IN M BALE BCH, PL
+571 Jun 19 05:09 PM M BALA BCH, PL
+572 Jun 19 05:15 PM Inconley
+573
+Jun 19 05:20 PM Inconieg
+574 Jun 19 05:29 PM Inconing
+575 J.
+13 05:44 IN ROTTONICH, FL.
+576
+Jun 19 06:43 PM Inconies
+577
+Jun 19 D8:17 #N Inconleg
+578 Jun
+20 10:24 30 M BALK BCH, FL
+79 Jan 20 10 40 10 Incle
+580 Juл 20 1050 А Іні
+581 Jun 20 12/22 AN M BALA BCH, FL
+583 JuR 20 01:16 PM M PALK BCH,PL
+584 Jum 20 03,39 М Ініт
+585 Jum 20 02:05 PM Inconleg
+588 JuL 20
+Min:Sec
+561-602-2291
+561-502-5212
+8
+8
+561-577-6425
+561-502-7753 OP/NN
+561-577-6425 OF/NN
+561-599-6425
+OP /NN
+561-503-5980
+OP/NN
+561-333-7530
+OP/NN
+561-762-2874
+OP/NN
+561-585-4211 OP/N
+561-358-7914 OP
+561-662-3098
+8
+561-722-0047 0P
+561-723-3440 OP
+561-723-3440
+8
+561-577-6425
+8
+561-714-5776
+8
+561-722-0047
+8
+561-827-2542
+8
+561-478-2692
+561-252-4383
+8
+561-061-1444
+8
+240-593-4162
+8
+561-478-2692
+8
+561-585-4211
+561-644-4989
+8
+561-503-5930
+8
+561-252-4383
+561-503-5930
+561-577-6425
+561-478-2692
+561-753-9832
+8
+8
+8
+561-827-2542
+561-827-2542
+561-827-2542
+561-827-2542
+561-829-2542
+561-827-2542
+561-478-2692
+821 02 817
+8
+8
+8
+8
+8
+2100
+1:00
+1:00
+1:00
+1:00
+3:00
+1:00
+1:00
+1:00
+2:00
+1:00
+2:00
+2:00
+3: 00|
+2,00
+3:00
+8: 00
+2:00
+1.00
+2:00
+1:00
+4:00
+2:00
+2:00
+1:00
+1: 00
+2:00
+1:00
+2:00
+5:0a
+1:00
+1:00
+1:00
+1:00
+1:00
+Usage
+4.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+0.0B
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+$.00
+0.0D
+$.00
+0.0D
+•.00
+$.00
+- •r
+•.00
+4.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.00 |
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+g.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time CallTo
+Number
+Footnote Min: Sec
+Usage
+587 Jun 20 02:44 EM N PALM BCH, PL
+561-662-3098
+2:00
+50d Jun 20 04:57 IM Inconing
+561-502-7753
+2:00
+580 Jun 21 07:01 AM Inconing
+561-503-4429
+1100
+500 Jun 21 07:10 AM Incoring
+561-427-2542
+591 Jun 21 07:15 AM N RADA BCH, PL
+561-723-3440
+1:00
+092 Jun 21 07:19 AM N PALM BCH, PL
+561-123-3440
+1. 06
+583 Jun 21 07:24 AM Operator
+1:00
+504 Jun 21 07:29 AM W PALM BCH ,PL
+561-333-7530
+2100
+585 Jun 21 07:36 AM A FALA BCH, PL
+5E1-582-19C4
+500 Jun 21 07:37 AM N FALK BCH, PL
+561-615-0011
+597 Jun 21 07:39 AM N PALM BCH,PL
+561-615-0011
+1,00
+508 Jun 21 07:6E AM N FALE BCH, PL
+SEL-E15-0D11
+3: 0D
+399 Jun 21 07:49 AM W PALM BCH, PL
+561-615-0011
+1:00
+800 Jun 21 07:57 AM N FALK BCH, PL
+561-615-8011
+801
+Jun 21 04.03 AM Incondng
+561-719-1531
+2,00
+g
+Jun 21 08:17 AM Incoelng
+561-255-2520
+2:00
+Jun
+08:19 AM W PALM ECH, PL
+561-585-4484
+3:00
+21
+08:26 AM W PALM BCH,PL
+561-252-4343
+1,00
+605
+Jun
+21
+08:27 AM Incoring
+561-252-4383
+08:35 AM Incoring
+561-502-7753
+2:00
+807 Jun 21 08:53 AMN PALM RCH,PL
+561-723-3440
+608
+Tun
+21 09:03 AM Inconding
+561-503-4429
+Jun 21 09:0E AM Inconing
+561-141-4051
+610 Jun 21 09:08 AM Incoring
+561-202-4497
+611
+Jun
+21 09:10 AM Inconing
+561-585-4772
+1:00|
+812
+Jun 21 09.19 AM Incondng
+561-541-4785
+613 Jun 21 69:35 AM Incoring
+561-502-1753
+1:00
+Jun
+21 09:36 AM N PALE BCH,PL
+561-795-9549
+815
+Jun 21 09:46 AM N PALM BCH,PL
+561-541-4785
+616
+21 09:47 AM BOCA RATON, UL
+561-105-1272
+1: 00
+617
+21 09:56 AM Incoring
+561-252-4363
+2:00
+Jun 21 09:54 AM CHARLOTTE, N
+704-363-0857
+819
+561-252-4343 PP
+2,00
+Jun 21 10:05 AM Inconleg
+Jun 21 10:09 AM Inconing
+822
+Jun
+21 10:15 AM W PALM BCH ,PL
+623
+Jun 21 10:32 AM Inconing
+624
+21 10:39 AM Incoring
+Jun
+21 10:44 AM Inconing
+Jun 21 11:00 AM Incondng
+827
+21
+11:03 AM Incorleg
+561-102-5121 FF/CN
+561-305-3272 FP
+561-723-3440 PP
+361-456-7568 FE
+561-503-8429
+$:0D
+1:00
+561-503-4429
+561-252-4343
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DĐ
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Changes
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time Call To
+828 Jun 21 11:06 3M Inconing
+629 Jun. 21 11:30 AM Inconieg
+830 Jun 21 11,32 AN Inconleg
+831 Jun 21 11,33 3M M BALK BCH, FL
+832 Ju 21 12:00 IN M PALE BCH, FL
+633 Jun. 21 12:02 IN BOCA RATON, PL
+834 Jun 21 12:10 PM IncomiNg
+835 Jun 21 12/15 EN Inconing
+836 Jut 21 12:20 IN Iscoeleg
+837 Jun 21 12,22 PM M PALK BCH, PL
+838 Jun 21 12:22 PM N PALK BCH, PL
+639 Jul. 21 12:41 WN M PALE BCH, VL.
+640 Jun. 21 12:48 IM LAUREL, MD
+841 Jun 21 12:49 PM M BALE BCH, PL
+842 Jun 21 01,00 PM N BALA BCH, FL
+643 JuN 21 01:04 WN INCORleg
+644 Jun 21 01:14 PM IncORieT
+845 Jun 21 01,23 PM Inconing
+848 Jul. 21 01:37 IN INCORLeg
+647 Jun 21 01:46 PM Inconieg
+845 Jun 22 03:59 PM Inconleg
+840 Jun 21 02122 PM ICelE
+850 Ju. 21 02:52 Incoeleg
+051 Jut 21 04:12 IM M PALA BCH, PL
+852 Jun 23 05:28 PM M PALE BCH, PL
+853 Jun 21 05,29 PM M PAI BCH, PL
+654 Jun 21 05:31 PM M PADE BCH, PL
+855 Jun 21 05:34 PM M PALE BCH, PL
+858 Jun 21 05,35 PM M PATA BCH, PT.
+657
+Jun 21 05:40 IN CHARLOTTE, NC
+05:41 PM M PALK BCH, PL
+659 Jun 22 05:41 PM M BALE BCH, PL
+850 Jun 21 05143 PM N BALA BCH, FL
+081 JuR 21 05:44 IN M PALE BCH, VL.
+882 Jun 22 06:18 PM PALE BCH, PL
+083 Jun 22 06:40 PM PALA BCH, PD
+654 JuR 21 07:09 IN M PALE BCH, FL
+065 Jun 21 07:30 IN LAUREL ,MD
+666 Jun 21 07:37 IN M ANE BCH, FL
+087 Jun 22 08:45 EM Inconleg
+668JL 22 DE:57 1 I0l
+561-252-4383
+561-252-43RR
+561-202-8497 PP
+561-798-8900 PP
+561-352-7000
+561-205-1292
+561-352-7000 FF
+561-502-5123 PP
+561-202-8497 FP
+561-434-2500 FF
+561-433-2500 PP
+561-805-670D PP
+240-593-4162 V9
+561-805-6700
+561-964-1515
+561-502-7953
+561-478-4188
+561-502-7753
+561-478-4188
+561-478-5890
+561-840-1582
+561-36E-E89C
+561-662-6813
+561-503-7753
+561-541-4785
+561-662-6688
+563-663-6688
+561-662-6688
+704-364-584D
+561-718-5004
+561-966-689E
+561-541-47E5
+561-541-4785
+561-544 4989
+561-964-5511
+240-593-4162
+561-541-7753
+[E1 43E-4739
+561-827-2542
+Min:Sec
+3,00
+1:00
+1100
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+2:00
+6: 00
+3:00
+2:00
+4: 00
+10:00
+1:00
+3:00
+2:00
+2:00
+1:00
+1:00
+2:00
+1:00
+5100
+1:00
+2:00
+1:00
+2100
+17:00
+5:00
+3:00
+Usage
+4.00
+$.00
+• DE
+0.0D
+$.00
+•.0D
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.DD
+D.DD
+D.DD
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.00 |
+n an
+corticued.
+Total
+Charges
+9.00
+a.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time CallTo
+Number
+Footnote
+Min: Sec
+989 Jun 22 06:54 AM Incondng
+561-927-2542
+฿: 00
+870 Jun 22 07:51 AM N PALM BCH, PL
+561-840-0590
+4:00
+871 Jun 22 04:07 AM Inconing
+561-502-1753
+2100
+872 Jun 22 09:34 AM Inconing
+561-616-4240
+1,00
+673 Jun 22 08:39 AM N RAIN BCH, PL
+561-062-EEEE FP
+1:00
+674 Jun 22 C9:43 AM Incoring
+561-585-4772
+2:00
+875
+Jun 22 08:47 AM Inconing
+561-616-4240
+2:00
+878 Jun 22 09:49 AM W PALM BCH,PL
+561-585-4772
+A77
+Jun 22 08:56 AM Inconing
+5E1-903-8429
+878 Jun 22 09:54 AM BOYTONBCH, PL
+S61-503-8429 FP
+879 Jun 22 09113 AM Inconing
+561-723-1421 PP
+3,00
+680 Jun 22 09:21 AN Inconing
+5E1-202-8497
+1:0D
+681 Jun 22 09:23 AM N PALM BCH, PL
+561-202-7640
+1:00
+682 Jun 22 09:25 AM N FALM BCH, PL
+561-565-4211
+1100
+22 09:25 AM W PALM BCH ,PL
+561-433-2500
+1,00
+Jun 22 09:27 AM Incolng
+5E1-795-7715
+2:00
+Jun
+09:32 AM CHARLOTTE, SC
+704-364-5840
+3:00
+09.36 AM Incondng
+561-122-4259 PP
++: 00
+687
+09:33 AM IncoRleg
+561-762-2874 FF/CN
+1:0D
+638.
+22
+09:49 AM W PALM BCH ,PL
+561-476-418800
+880 Jun 22 10:00 M Inconing
+561-714-4005 PP
+8
+Tun
+10:05 AM Inconding
+561-721-5212
+4: 0D
+2,00
+891 Jun 22 10:13 AM Incondug
+254-314-4070
+Jun 22 10:30 AM Inconing
+561-684-6672
+Jun
+10:35 AM W PACK BCH,PL
+561-723-3440
+Jun 22 10:39 AM W PALM BCH,PL
+561-684-6672
+Jun 22
+10:43 AM Inconing
+954-816-3335
+Jun
+10:49 AM Inconing
+561-433-2642
+4: 00
+5100
+5:00
+1:00
+10:50 AM N PALM BCH,PL
+561-474-4148
+698
+11:04 AM N FALO RCH, PL
+561-123-1821 FP
+4. 00
+8
+22 11:09 AM W PALM BCH, PL.
+561-478-4168
+700 Jun 22 11:21 AM Inconing
+561-723-1621 FF/CH
+701 Jun 22 11:23 AM Incondug
+561-474-589D PP
+14:00
+2:00
+4:00
+702 Jun 22 11:23 AM Inconing
+561-121-1821 FD/CN
+Jun 22 11:40 AM Inconing
+561-476-5690 FP
+704
+Jun 22 11:47 AM BOYTONBCH, PL
+561-577-6425 PP
+1,00
+2:00
+706 Jun 22 12:00 PM N PALM BCH, PL
+561-478-4388 FP
+Jun 22 12:21 I Incoring
+561-478-4188
+Jun 22 12:43 PM N PALM BCH,PL
+561-662-6648
+1:00
+3:00
+70e
+Jun 22 12145 EM W PALM BCH ,PL
+561-615-0011
+709
+Tia 55
+12:67 PM N FALM BCH .PL
+$: 0D
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DĐ
+D.0D
+D.DD
+0.0D
+D.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+0.0D
+D.DD
+D. DD
+D.DD
+D. DD
+D.DD
+Charges
+D.0D
+0,00
+0,00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time Call To
+710 Jun 22 01:11 PM M BALK BCH, FL
+711 Jun 22 01:18 IM Inconieg
+712 Jun 22 01128 PM Isconleg
+713 Jun 22 01/31 EM Inconing
+714 Jun 22 01:35 IN M FALC BCH, PL
+715 Jun. 22 01:44 IN • PALA BCH, PL
+716 Jun 22 03:54 EN IncOmiNg
+717 Jun 22 02/01 IN BOCA RATON, FL
+718 Jut 22 02:02 IN Incoeleg
+719 Jun 22 02:07 AN Inconleg
+720 Jun 22 02/18 EN Inconing
+721 Jun 22 02:23 W Inconleg
+722 Jun. 22 02:46 IM Inconieg
+723 Jun 22 02:57 IN PILAUDERDL, PL
+724 Jun 22 03,07 PM M PALA BCH, PL
+725 Ju. 22 03:12 IN POMANORCH, PL
+725 Jun. 22 03:14 IN PILAUDERDL, PL
+727 Jun 22 03/24 IN Inconing
+728 Ju 22 03:28 IN M PALE BCH, PL
+729 Jun. 22 03:44 PM Iscoeleg
+730 Jun 22 03:48 PM M PALE BCH, PL
+731 Jun 22 03:49 PM Incoming
+732 Ju. 22 04:13 IN M PALE BCH, FL
+733 Jun 22 04:52 PM Iconiet
+734 Jun 22 D6:18 PM Inconleg
+735 Jun 22 06:46 PM M BALA BCH, PL
+735 Jun 22 06:58 PM M PALK BCH, PL
+737 Jun 22 07:02 PM M PALE BCH, PL
+738 Jun 22 07123 EM Inconing
+739 J 22
+740 Jun 22 08:54 PM BOYTONBCH, PL.
+741 Jun 23 D6:52 AN Inconleg|
+742 Jun.
+23 07,04 3M M PALA BCH, PL
+743 JuR 21 07:05 AN PALE BCH, FL
+744 Jun 23 07:40 AN M PALE BCH, PL
+745 Jun 23 07:49 AM M BALA BCH, FL
+746 Jun 21 07:50 AM M PALE BCH, FL
+747 Jun 23 08:09 AM Inconiey
+748 Jun 23 08:17 AN M BALE BCH, PL
+740 Jum 23 08,32 1М Ікоп/я
+750 JuR 27 DE:36 AN Inconley
+Number
+561-723-1821
+561-723-1821
+561-723-1821
+561-577-6425 PP
+561-697-968D FF
+561-723-1821 PP
+561-723-1821 FF
+561-305-1272
+561-478-4168 FP
+561-723-1821 FF
+561-478-4188 PP
+561-502-7753 PP
+561-478-4188 V9
+054-6A3-533T
+561-723-3440
+954-977-5010
+954-581-4744
+561-478-4188
+561-352-7000
+561-644-4989 FP
+561-582-2164
+PP/CW
+561-312-6654
+Unavailable
+561-541-4785
+561-541-4785 PP
+561-541-4785
+561-541-4785
+561-133-7530
+561-723-3440
+561-503-5930
+561-723-3440
+8
+561-502-5123
+561-714-1522
+561-333-7530
+561-662-6688
+561-255-2520
+561-305-1272
+561-659-2040
+561-502-7753
+121L8058151
+Min:Sec
+2:00
+2:00
+2:00
+1:00
+1:00
+2:00
+1:00
+2:00
+2:00
+1:00
+4:00
+5:00
+2:00
+2:00
+8: 00|
+4:00
+1:00
+3:00
+2:00
+1:00
+1:00
+2:00
+7:00
+1:00
+1:00
+1:00
+1:00
+T=00
+1:00
+4:00
+1.00
+1: 0a
+2:00
+2100
+2:00
+1:00
+1:00
+2100
+2:00
+Usage
+4.00
+$.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+8.00 |
+0.0D
+0.0D
+0.0D
+8.50 |
+• 0[
+0.0D
+•.00
+9,00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+0.D0|
+п nn
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time CallTo
+751 Jun 23 04:45 AM N PALM BCH,PL
+782 Jun 29 08:50 AM N PALM BCH, PL
+753 Jun 23 09:10 AM Inconing
+754 Jun 23 09:17 AM N PALM BCH ,PL
+755 Jun 23 09:20 AM LAUREL., MO
+756 Jun 29 09:24 AM N PALM BCH, PL
+757 Jun 23 09:25 AM Inconing
+758 Jun 23 09:24 AM W PALM BCH ,PL
+750 Jun 23 09:29 AM N PALA BCH, PL
+760 Jun 23 09:31 AM Inconing
+781 Jun 23 09,34 AM W PALM BCH,PL
+782 Jun 23 09:45 AM Incorlng
+163 Jun 23 09:48 AM Inconing
+784 Jun 23 09:57 AM N FALK BCH, PL
+785 Jun 23 09,57 AM W PALM BCH, PL
+766 Jun 23 10:03 AM BOZTONBCH, VL.
+747
+Jun 23 10:04 AM Inconing
+Jun 23 10:20 AM Incondng
+760
+Jun 23 10:37 AM Inconing
+Jun 29 10:40 AM W PALM BCH ,PL
+771 Jun 23 10:42 AM N PALM RCH, PL
+772 Jun 23 10:44 AM W PALM BCH,PL
+773 Jun 23 10:64 AM Inconing
+774 Jun 23 10:46 AM N PALM BCH,PL
+775 Jun 23 10:49 A N PALM BCH, PL
+770 Jun 23 10:50 AM JUPITER, FL
+777 Jun 23 10:51 AM N PALM BCH,PL
+778 Jun 23 10:53 A N PALM BCH, PL
+779 Jun 23 11:25 AM N PALM BCH,PL
+Jun 21 11:2E AM N FALO BOH,L
+781 Jun 23 11:29 AM Incoring
+782 Jun 23 11:40 AM Inconing
+783 Jun 23 11:50 AM Incondug
+784 Jun 21 12:01 PM Inconing
+Jun 23 12:04 PM PILAUDEROG, PL
+788
+Jun 23 12:06 PM W PALM BCH ,PL.
+787
+Jun 23 12:07 IM Incondog
+788
+Jun 23 12:12 IM W PALM BCH .PL
+789
+Jun 23 12:19 PM Inconing
+790
+Jun 23
+12124 EM DEBAFLOBCH,PL
+791
+1. тоніва
+Number
+561-474-4148
+561-662-6616
+561-255-2520
+561-662-6648
+240-193-4162
+561-842-6414
+561-719-3531
+561-719-1537
+5E1-185-7914
+561-719-1537
+561-723-1421
+5E1-478-4188 FD
+561-476-5690
+561-478-4168
+561-474-5450
+5E1-STT-E425
+954-650-9306
+561-305-3440
+301-ED8-0584
+561-662-6688
+561-644-4989 FF
+561-474-4148
+561-745-B6EE FF/CN
+561-476-4188P0
+561-662-6648 FP
+561-745-9898
+561-476-4188
+561-644-4999
+561-694-2040
+561-659-4020
+561-478-4168
+561-721-5212
+954-942-5788
+pP/CH
+561-655-3791 FP
+954-540-2117 FP
+561-541-4051
+561-721-1212
+561-478-4188
+Unavailable
+954-650-9306
+Min: Sec
+3:00
+2:00
+7:00
+3: 0D
+1:00
+3:00
+1:0D
+2,00
+2:00
+9:00
+1100
+1:0D
+1,00
+2:00
+1,00
+1:00
+1: 00
+17:00
+1,00
+1,00
+5:0D
+3: 00
+1,00
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+0.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time Call To
+792 Jun 23 12:35 PM PILAUDERDG, FL
+793 Jun. 29 12:45 IN Inconieg
+794 Jun 23 02/05 EN Inconleg
+705 Jun 23 01,31 PM DEERFLOBCH, FL
+795 Jun 23 01:34 IN M PALE BCH, FL
+797 Jun 29 01:37 IN PLAUDERDL, PL
+795 Jun 23 02:39 PM M BALK BCH, PL
+790 Jun 23 02/06 IN BOCA RATON, FL
+B00 Jut 23 02:15 IN Incoeleg
+801 Jun 23 02:23 PM Incoming
+802 Jun 23 02,30 PM N PALK BCH, PL
+B03 Ju. 23 03:02 WN M PALE BCH, VL.
+004 Jun. 23 03:06 PM 5 PALK BCH, PL
+805 Jun 23 03:15 PM M BALE BCH, PL
+B08 Jun 23 03/28 EN Inconing
+B07 Jun 21 03:45 W Iscoeleg
+B08 Jun. 23 03:51 IN Incoming
+809 Jun 23 03,51 PH M PALA BCH, FL.
+810 J: 23 03:54 w Iscoeleg
+811 Jun 23 03:56 PM 5 DALK BCH, PL
+812 Jun 23 03:57 PM Inconleg
+813 Ju 23 04:47 PM M PAT BCH, PL
+814 JuR 23 04:48 IN M PALE BCH, FL
+815 Ju. 23 05:04 PM M PALK BCH, PL
+816 Jun 23 05:14 PM Inconleg
+817 Jun 23 05:15 PM Inconing
+818 шв 29 05:37 М Інсовіет
+819 Jun 23 05:41 IN Incoming
+820 Jun 23 05155 PM Inconleg
+821 лил.
+DE: 39 IN M PALE BCS, VL
+822
+Jun 23 06:40 PM M PALK BCH, PL
+Jun 23 07:15 PM M BALE BCH, PL
+824 Jun 23 07:18 PM Inconleg
+825 Ju: 2307:47 Inceleg
+828 Jum 24 06:44 1М Інспікт
+827Jum Jun 2406474 /g
+828 JUR 24 DE:52 AN M PALE BCH.FL
+B29 Jun 24 06:53 AM Inconieg
+Number
+954-540-2117
+561-152-7000
+954-650-9306 PP
+561-662-66E8 FF
+954-581-2200
+561-152-7000|
+561-478-4168 FP
+561-586-1644 FF
+561-723-1821 PP
+561-502-5123 PP
+561-842-6414 V9
+561-719-4961 PP
+561-541-4051
+561-502-5123
+561-502-5123
+561-801-6445
+561-541-4051
+561-719-4961
+561-723-1821
+561-662-6688
+561-723-1821
+561-478-4188
+561-503-5930
+561-502-7753
+610-995-7084
+561-856-6967
+Min:Sec
+2:00
+1100
+1:00
+3:00
+1:00
+3:00
+1:00
+16:00
+1:00
+1:00
+2:00
+1:00
+1.00
+2:00
+1:00
+1,00
+1.00
+2:00
+1:00
+1:00
+1:00
+1:00
+12:00
+1:00
+2:00
+5:00
+2:00
+2:00
+3.00
+Usage
+4.00
+$.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+561-E62-6GE8
+0.0D
+561-255-2520
+561-478-7760
+•.00
+561-478-7760
+561-502-7753
+0.0D
+561-721-5212
+•.00
+561-723-3440
+8
+5:00
+561-721-5212
+2:00
+- •r
+561-721-5212
+9:00
+954-581-4200
+1:00
+•.00
+831 Jun 24 07:03 AN W BALK BCH, FL
+561-723-1821
+$.00
+832 Jun 24 07:11 1н Inconley
+1:00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.D0|
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time CallTo
+Number
+Footnote
+Min: Sec
+833 Jun 24 07:12 AM Incordng
+561-255-2520
+1,00
+034 Jun 24 07:13 AM Inconing
+561-723-1621
+7:00
+835 Jun 24 07:19 AM W FALK RCH,PL
+561-255-2520
+110D
+836 Jun 24 07:21 AM W PALM BCH ,PL
+561-927-2542 PP
+1,00
+837 Jun 24 07:29 AM N RAIN BCH, PL
+561-723-1821
+1:00
+838 Jun 24 07:34 AM BOYTONBCH, PL
+561-577-6425
+1:00
+B30 Jun 24 07:34 AM Inconing
+561-541-5449 FP
+1100
+840 Jun 24 09:02 AM W PALM BCH,PL
+561-121-5212
+1,00
+841 Jun 24 08:11 AM Inconing|
+5E1-121-5212
+842 Jun 24 08:14 AM W FALA BCH, PL
+S€1-352-7000
+843 Jun 24 09125 AM Inconing
+561-296-3707
++:00
+B44 Jun 24 09:57 AN Inconing
+5E1-305-3480
+1:0D
+845 Jun 24 09:58 AM N PALM BCH, PL
+561-722-0047 PP
+1:00
+848 Jun 24 10:01 AM N FALM BCH, PL
+561-385-7914
+1:00
+847 Jun 24 10:02 AM W PALM BCH, PL
+561-345-7914
+1,00
+848 Jun 24 10:02 AM N PALA RCH, IL
+561-358-7914
+2:00
+Jun 24 10:25 AM W PALM BCH ,PL
+561-121-5212
+2:00
+850 Jun 24 10:27 AM W PALM BCH.PL
+561-723-1421
+1:00
+851 Jun 24 10:37 AM Incoring
+561-123-1821
+Jun 24 10:46 AM Inconing
+561-721-5212
+5: 0D
+2:00
+853 Jun 24 10:55 M Inconing
+561-745-8888
+854 Jun 24 10:57 AM N PAM BCH, ,PI.|
+561-474-4148
+855 Jun 24 10:58 AM ATLANTA NK, GA
+770-447-4332
+830 Jun 24 11:02 AM Incoring
+561-478-4188
+857
+Jun 24 11:13 AM N PALM BCH, PL
+561-721-5212
+1,00
+3: 0D
+4: 00
+1:00|
+858 Jun 24 11,14 AM Inconing
+561-721-5212
+Jun 24 11:21 AM N PALM BCH ,PL
+561-502-3666
+Jun
+11:44 AM Inconing
+561-122-3311
+2,00
+2:00
+5:00
+Tun sA
+561-722-0047
+882
+12:01 PM Inconlag
+Jun 24 12:13 IM Inconing
+004 Jun 24 12:24 PM Inconing
+88S Jun 24 01:17 PM NINE, PA
+B86 Jun 24 01:26 PM Inconleg
+Jun 24 02:41 IN PILAUDEROG,PL
+B88
+Jun 24 01:47 PM PILAUDEROG, PL.
+Jun 24 01:69 IN PTLAUDERDE, PL
+870
+Jun 24 01:56 IM Incoring
+871
+Jun 24
+00:22 PM N PALM BCH,PL
+872
+Jun 24 03:09 EM Incondng
+873
+00:35 PM N FALM BCH .PL
+561-122-0047
+2: 00
+561-585-4772
+2:00
+610-995-7044
+610-995-7084
+561-721-3440
+954-581-4300
+954-581-4200
+354-581-4200|
+561-723-1621
+1,00
+1:0D
+7:00
+561-354-7914
+561-433-3169
+01E-901л
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+• 0n
+D. DD
+D.DD
+0.0D
+D.DD
+Changes
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time Call To
+874 Jun 24 03,35 PM M BALK BCH, FL
+875 Jun. 24 03:40 IN Inconieg
+876 Jun 24 03:56 PM M PALE BCH, PL
+877 Jun 24 04,30 PM M BALK BCH, FL
+878 Jшt 24 04:34 IN M PALE BCH, FL
+879 Jun. 24 04:37 PM M PALA BCH, PL
+850 Jun 24 04:41 PM M BALK BCH, PL
+851 Jun 24 D4:42 EM Inconleg
+B82 Jut 24 05:31 IN M BALE BCH, VL
+863 Jun 24 05132 PM M PALK BCH, PL
+854 Jun 24 D6102 PM N PALK BCH, PL
+885 Ju. 24 DE:04 W Iscoeleg
+BBS Jun 25 06:53 AM M DALE BCH, PL
+887 Jun 25 D6:55 AM M BALE BCH, PL
+888 Jun 25 06:57 AM PTLAUDERDL, FL
+890 Jun. 25 07:23 AM I PALA BCH, PL
+891 Jun 25 07,39 A PADEAD, PL
+092 Jam 25 07:45л Inteleg
+Jun 25 07:49 AM Isconieg
+894 Jun 25 07:56 AM M PALE BCH, PL
+805 Ju 25 08,03 3М M PAT BCH, PL
+B9S Jun 25 DE:05 AN Inclay
+887 Jut 25 08:06 AM M PALA BCH, PL
+B8S Jun 25 08:08 2M BOCA RATON, PL
+800 Jun 25 08:11 AM M BALA BCH, PL
+900 Jun. 25 08:13 AN Inconley
+901 Jun 25 08:14 24 M BALE BCH, PL
+002 Jun 25 08115 AN Inconing
+903
+Tun
+Jun 25 08:18 AM Inconies
+Jun 25 D8:19 AN Inconleg
+908 Jun
+25 08:20 AM BALA BCH, FL
+Jun 25 08,54 AN Incoming
+B11 Jun 25 09:05 AM Inconieg
+912
+013 Jun 25 09,07 AN W BALK BCH, FL
+914 Ju 25 08:55 10 Incle
+Number
+561-358-791÷
+561-723-1821
+Min:Sec
+561-358-7914 PP
+561-662-6688 PP
+561-E44-4369 PF
+561-644-4989 M
+1:00
+2100
+3:00
+3:00
+5:00
+• DE
+0.0D
+$.00
+561-662-66B8 FF
+•.0D
+561-965-0277 PP
+2:00
+4.00
+561-EE2-EEEE FP
+1:00
+561-502-3866 FF
+9:00
+561-358-791+ PP
+1:00
+561-358-7914 PP
+1:00
+561-662-6688 08
+561-602-6612
+8
+1:00
+954-581-4200
+8
+954-581-4200
+8
+561-662-6688
+954-581-4200
+561-502-6617
+561-541-4051
+1:00
+1:00
+3.00
+2:00
+1:00
+561-719-1537
+0.0D
+0.0D
+0.0D
+0.0D
+$.5B
+561-502- 1REE
+• 0[
+561-202-8497
+561-682-6505
+561-305-1272
+561-719-1537
+561-719-1537
+561-795-9549
+561-E40-9857
+561-795-9543
+561-722-0047
+561-640-3526
+561-795-9549
+561-541-5449 PP
+561-582-1964 PP
+561-503-5930
+561-718-4222
+561-502-7953
+561-716-4222
+PP/CW
+561-844-9994
+821 20902n
+1.00
+1:00
+2:00
+1:00
+1:00
+1:00
+1:00
+1: 00
+1:00
+1:00
+1:00
+1: 0a
+2:00
+1:00
+2:00
+1:00
+2:00
+2:00
+Usage
+4.00
+$.00
+0.0D
+•.00
+9,00
+$.00
+0.0D
+$.00
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.DD
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.D0|
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time CallTo
+Number
+Footnote
+Min: Sec
+915 Jun 25 10:05 AM I PALM BCH.PL
+561-582-1964
+2:00
+816 Jun 25 10:17 AM N PALM BCH, PL
+561-433-4634
+=
+1:00
+917 Jun 25 10:33 AM W FALA RCH, PL
+561-123-1421
+110D
+918 Jun 25 10:34 AM I PALM BCH.PL
+561-682-6505
+1,00
+919 Jun 25 10:37 AM LAUREL, MO
+240-193-4162
+1:00
+820 Jun 25 10:38 AM Incoring
+561-640-8307
+821 Jun 25 10:40 AM BOCA RATON, PL
+561-305-3272
+2:00
+822 Jun 25 10:49 AM W PALM BCH.PL
+561-942-9994
+1,00
+Jun 25 10:51 AM N FAIN RCH ,PL
+561-844-9954
+824 Jun 25 10:59 AM BOCA RATON, PL
+561-305-1272
+925 Jun 25 11:01 AM N PALM BCH,PL
+561-582-1964 PP
+3,00
+826 Jun 25 11:04 AM N FALA BCH, IL
+5E1-123-1821
+2:00
+827 Jun 25 11:06 AM BOCA RATON, PL
+561-305-1272
+828 Jun 25 11:56 AM N FAL BCH, PL
+561-502-3666
+1:00
+029
+Jun 25 11,57 AM N PALM BCH, PL
+561-662-6688
+2,00
+Jun 25 11:58 AM Incondng
+5E1-721-1821
+Sp/CN
+1:0D
+11:59 AM W PALA BCH ,PL
+561-723-3440
+1:00
+25 12:01 EM W PALM BCH, PL
+561-662-6688
+2,00
+933
+Jun
+25 12:03 PM N PALM BCH, PL
+561-478-7760
+12:04 IM W PALM BCH ,PL
+561-352-7000
+1:00
+805 Jun 25 12:05 PM W PALM RCH,PL
+561-502-3866
+5:00
+038
+Tun
+25 12:09 PM BOCA RATON, PI.
+561-305-1272
+2,00
+937
+Jun 25 12:45 PM W FALA BCH, PL
+561-152-7000
+3: 0D
+938
+Jun 25 12:47 PM Inconing
+561-723-3440 PD/CH
+Jun
+25 12:57 PM N PACK BCH, PL
+561-352-7000
+6:00
+040
+Jun 25 01.07 EM W PALM BCH,PL
+561-478-4188 PP
+941 Jun 25 01:11 IM N PALM BCH ,PL
+561-502-3666
+1:00
+Jun
+25
+01:17 PM DESAPLDECH ,PL
+954-450-9306
+2,00
+043
+01:19 PM W PACM BCH,PL
+561-354-7914
++:00
+944
+01:22 PM Inconleg
+561-662-EELE FF/CH
+01:23 IM W PALM BCH, PL
+561-562-1964 PD
+Jun 25 01:26 PM N PAEN BCH,PL
+561-662-6616
+2:00
+047
+Jun
+01:28 PM N PAIN BCH.PL.
+561-582-1964
+3,00
+948
+Jun 25 02:35 PM Inconleg
+561-7E5-0277
+049
+Jun 25 01:39 PM W PALM BCH, PL
+561-662-6616 FP
+1:00
+050
+Jun
+01:43 PM W PALM BCH,PL
+561-795-9549
+051
+Jun 25 02:02 IM Incondog
+561-102-3BEE
+2:00
+Jun
+25 02:03 IM W PALM BCH .PL
+561-478-4188
+1:00
+Jun
+00:04 PM N PALM BCH.PL
+561-474-4148
+Jun 25 02111 EM Incondng
+561-585-3660
+955
+02:24 PM N FALM BCH .PL
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+0.00 |
+D.0D
+0.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time Call To
+956 Jun 25 02I46 PM Inconing
+B57 Jun 25 02:57 PM Incoeieg
+958 Jun 25 02157 PM M PALE BCH, PL
+959 Jun 25 03,35 PM M BALK BCH, FL
+960 J: 25 03:55 IN BOTTONECH, FL
+951 Jun 25 03:56 IN Isconing)
+082 Jun 25 04:03 PM M BALK BCH, PL
+983 Jun 25 04:06 PM W BALK BCH, PL
+954 Jut 25 04:22 IN M BALE BCH, VL
+985 Jun 25 04:24 PM Inconing
+08S Jun 25 04:36 EN Inconing
+957 Jum 25 04:48 W Iscoeleg
+96S Jun 25 04:53 IM Inconieg
+989 Jun 25 04:57 PM M BALE BCH, PL
+070 Jun 25 05122 EN Inconing
+971 Jul. 25 05:33 WN M PALE BCH, FL
+972
+Jun 25 05:38 IN M DALK BCH,PL
+Jun 25 05,49 PM M PALA BCH, PL
+974 JuL 25 05:50 IN M PALE BCH, PL
+975
+Jun 25
+05:52 PM M PALK BCH, PL
+976 Jun 25 D6:09 PM M PALE BCH, PL
+077 Jun 25 D6:16 PM Inconing
+978 Jun 25 DE:26 W Inceled
+979 Jun. 25 06:29 PM Inconley
+880 Jun
+07:23 IN Inconieg
+051 Jun 25 08:30 PM M BALA BCH, PL
+882 Jun 25 08:39 PM M PALK BCH, PL
+883 Jun 25 08:52 PM M BALS BCH, PL
+054 Jun 25 06:56 AM Inconing
+955 J.
+Jun 26 09:17 AM Inconies
+Jun 26 09:33 AM BOCA RATON, PL
+058 Jun 26 11,38 2M Inconing
+089 Ju 20 11:43 1н Incaleg
+980 Ju 24 12:52 AN Isonley
+091 Jun 26 12:40 IN M BALE BCH, FL
+982 Jun 26 01:41 PM M PALE BCH, FL
+983 Jun 26 03:41 IN Incories
+904 Jun 26 04:23 MINORIT
+9Q5 Jun 26 08:25 PM MANIA BCH, FL
+996 Jun 26 08:29 Inconleg
+Number
+561-541-5449
+561-202-8497
+561-842-6414 PP
+561-662-6688 PP
+561-503-5930 FF
+C9A-6AD-1814N
+561-352-7000 FF
+561-502-3866
+561-718-4222 FP
+561-503-5930 FF
+561-503-5930 PP
+561-502-38EE PP
+561-503-5930 V9
+561-541-5449 PP
+561-541-5449
+561-842-2050
+561-644-4989
+561-544-4989
+561-644-4989
+561-723-3440
+561-644-4989
+561-541-5449
+561-585-366D
+561-502-5212
+561-965-4989
+561-762-2842
+561-352-7000
+561-662-3098
+561-503-8429
+561-719-9374
+561-723-3440
+561-305-1272
+561-104-288$
+561-252-4396
+561-478-7760
+561-827-2542
+561-61E-E240
+561-723-3440
+561-723-3440
+561-722-0047
+8
+8
+8
+8
+8
+8
+8
+8
+Min:Sec
+1:00
+3:00
+3:00
+1:00
+1:00
+3:00
+1:00
+1:00
+1:00
+2:00
+3:00
+1:00
+2:00
+1:00
+1.00
+3:00
+1:00
+1.00
+1.00
+2:00
+2:00
+1:00
+2:00
+5:00
+3,00
+1: 00
+3:00
+2:00
+5,00
+2:00
+2:00
+1:00
+3:00
+2:00
+1:00
+Usage
+4.00
+$.00
+• DE
+0.0D
+$.00
+•.0D
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+$.5B
+$.00
+0.0D
+•.00
+9,00
+$.00
+0.0D
+$.00
+0.0D
+•.00
+0.0D
+•.00
+0.0B
+•.00
+$.00
+Long
+Distance
+D.D0
+D.DD
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.D0|
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time CallTo
+Number
+Footnote
+Min: Sec
+097 Jun 26 08:44 EM Incondng
+561-722-0047
+3:00
+990 Jun 27 07:50 AM Inconing
+561-723-3440
+4:00
+P00 Jun 27 07:57 AM Inconing
+561-502-1753
+2100
+1000 Jun 27 09:55 AM W PALM BCH.PL
+561-541-5449 OP
+1,00
+1001 Jun 27 10:42 AM Inconing
+561-585-204908
+4: 0D
+1002 Jun 27 12:16 IM N PALM BCH, PL
+561-541-5449
+1003 Jun 27 12:24 PM N FALA BCH, PL
+561-502-5212
+1100
+1004 Jun 28 06:45 AM I PALM BCH ,PL
+561-123-3440
+5:00
+1005 Jun 28 07:08 AM N FAL BCH,PL
+5E1-6E2-EEBE
+1006 Jun 28 07:10 AM W FALA BCH, PL
+561-662-6638
+$:0D
+1007 Jun 28 07:15 AM W PALM BCH ,PL
+561-722-1631 PP
+2,00
+1008 Jun 28 07:29 AM I FALE BCH, PL
+SE1-358-7914 FP
+1009 Jun 28 08:18 AM N PALM BCH, PL
+561-541-5449 PP
+1:00
+1010 Jun 28 09:24 AM W FALK BCH, PL
+561-352-7000
+2:00
+1011 Jun 28 04:25 AM W PALM BCH ,PL
+561-541-5449
+1012 Jun 28 08:27 AM N RAIN RCH, PL
+561-433-2500
+1:0D
+1013 Jun 28 08:28 AM N PALM BCH, PL
+561-723-3440
+1014 Jun 28 08:43 AM W FALM BCH,PL
+561-352-7000
+1:00
+1015 Jun 28 08:4E AM JUPITER, FL
+561-262-0911
+1016 Jun 28 08:51 AM W PALM ECH, PL
+561-686-1100
+1:00
+1017 Jun 28 08:52 AM N PAIN BCH, PL
+561-844-9994
+1018 Jun 28 C4,53 AM N PArM BCH,PL
+561-744-9994
+1019 Jun 28 08:02 AM Inconing
+561-840-05P0
+6: 0D
+1020 Jun 28 09:17 AM Incoring
+561-577-6425
+1021 Jun 28 09:25 AM Inconing
+561-541-5449
+$:00
+1022 Jun 28 10:04 AM LAUREL,MO
+240-593-4162
+1023 Jun 28 10:26 AM N PALM BCH, PL
+561-844-9994
+$100
+6:00
+1024 Jun 28 10:32 AM N FALM BCH ,PL
+561-474-4188
+1025 Jun 28 10:40 AM Inconing
+561-474-4148
+1026 Jun
+10:47 AM Inconlag
+561-640-3526
+2: 00
+1027 Jun 28 10:56 AM PLAUDERDC, PL
+954-444-6636
+2:00
+1020 Jun 28 10:59 AM N PALA BCH, PL
+561-662-6648
+1029 Jun 28 11:04 AM N PRIM BCH ,PL
+561-662-5616
+1030 Jun 28 11:04 AM N FALA RCH, PL
+561- 61E-0011
+1001 Jun 28 11:05 AM N PALA BCH. PL
+561-616-3100
+1032 Jun 28 11:06 AM W FALM BCH, PL
+561-615-0011
+1:00
+1,00
+1033 Jun 28 11:07 AM N FALO BCH.UL
+561-582-1PC4
+1034 Jun 28 11:35 AM W PALM BCH .PL
+561-640-3526
+1:00
+1005 Jun 28 11:37 AM N PALM BCH,PL
+561-714-5776
+1038 Jun 28 11:49 AM W PALM BCH ,PL
+561-662-6648
+1037 Jun.
+28 11:51 AM Incorlea
+Usage
+000|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+• 0n
+D. DD
+D.DD
+0.0D
+D.DD
+Charges
+D.0D
+0,00
+0.00|
+•.00
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time Call To
+1038 Jun 24 11,52 3M M BALK BCH, FL
+1030 Jun 24 11:53 AM I DALM BCH, PL
+1040 Jun 24 12:56 AN M PALK BCH, PL
+1041 Jun 24 12/28 EM Inconing
+1042 Jut 28 12:38 W Incoeleg
+1043 Jun. 24 01:49 IN Incoeleg
+1044 Jun 24 02:03 IN INCOmINg
+1045 Jun 24 02:05 PM M BALK BCH, FL
+1045 Jun 28 02:06 IN Inconleg
+1047 Jun 24 02:08 AN Inconleg
+1048 Jun 24 02/14 PM M PALK BCH, PL
+1049 Ju 28 02:33 W Iscoeleg
+1050 Jun. 24 02:58 IM I PALA BCH, PL
+1051 Jun 24 03:03 PM M PALE BCH, PL
+1052 Jun 24 03:04 EM FTLAUDERD, FL
+1053 can 203:0 10ly
+1054 Jun. 24 03:08 PM I PALA BCH, PL
+1056 Jun 24 03,12 EM Inconing
+1050 Jun 28 03:21 Inconleg
+1057 Jun 24 03:49 PM Incoming
+1058 Jun 24 04:02 PM Inconleg
+1050 Jun 24 04/15 EM Inconing
+1000 Jun 28 04:17 IN M PALE BCH, PL
+1051 Jun 24 04:19 PM Inconley
+1052 Jun 24 04:29 PM BALTIMORE,MD
+1080 Jun 24 04:34 EM BALTIMORE.MD
+1054 Jun. 24 04:44 PM Inconley
+1085 Jun 24 04:46 PM PALE BCH, PL
+1088 Jun 29
+04:47 PM M BALA BCH, PL
+04:47 IN M PALE ECH, FL
+1008 Jun 24 05:05 PM Incoming
+1050 Jun 24 05:06 PM IncOnly
+1070 Jun 29 05:13 PM PALA BCH,PL
+1071 Jun 28 05:15 IN M PALE BCH, VL
+1072 Jun 24 05:16 PM MALE BCH, PL
+1073 Jun 24 05117 EM Inconing
+107436200531 Incla
+1075 Jun 24 06:11 PM M PALA BCH, PL
+1076 Jun 24 06:198 InleT
+1077 Jun 24 06:20 IN W BALK BCH, FL
+1078 24 20 07:31 Incl
+Number
+561-697-9680
+561-662-668R
+Min:Sec
+561-697-9680 PP
+561-312-7961 PP
+561-478-4168 FF
+561-281-3814 P9
+561-478-4188 FF
+561-502-3866 PP
+561-478-4168 FP
+561-541-7631 FF
+561-502-3866 PP
+561-478-4188 PP
+561-478-4188 V9
+561-585-4484
+954-484-8402
+561-47E-5890
+561-644-4989
+561-472-2888
+561-478-4188
+561-472-2888
+561-478-4188 PP
+561-502-5212 PP
+561-723-1821 FF
+561-586-5908
+410-336-4861
+410-336-4961 PP
+561-478-2692
+561-478-4168
+561-478-4188
+561-478-4188
+561-541-5449 P9
+561-642-4090
+561-352-7000
+561-E62-C616 PP
+561-662-3098 PP
+561-541-5449
+PP/C
+561-541-5449 FF
+561-644-1957
+561-842-2050
+561-662-6616
+2:00
+3:00
+1:00
+2:00
+2:00
+1:00
+1:00
+6:00
+3:00
+2:00
+1:00
+3:00
+1:00
+3:00
+3:00
+6: 00
+9:00
+2:00
+1,00
+3: 00
+1:00
+1:00
+2:00
+1:00
+1:00
+1:00
+1:00
+3:00
+1:00
+1: 0a
+5:00
+Aran
+2:00
+1:00
+1:00
+Usage
+4.00
+$.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+8.50 |
+• 0[
+0.0D
+•.00
+9,00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+0.00 |
+п nn
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Min: Sec
+Item # Date Time CallTo
+1079 Jun 28 07:32 FM Inconing
+1080 Jun 28 08:45 PM Incoring
+1081 Jun 29 06:33 AM Inconing
+1082 Jun 29 07:14 AM Incordng
+1083 Jun 23 07:32 AM N RAIN BCH, PL
+1084 Jun 29 07:43 AM Inconing
+1085 Jun 29 07:49 AM N FALM BCH, PL
+1086 Jun 29 07:51 AM I PALM BCH,PL
+1087 Jun 29 07:53 AM POMPANDECH , PL
+1088 Jun 29 07:55 AM PLAUDERDG, PL
+1089 Jun 29 08:05 AM W PALM BCH ,PL
+1060 Jun 23 08:10 A Incondng
+1091 Jun 29 08:14 AM Incoring
+1092 Jun 29 08:25 M W FALA BCH, PL
+1093 Jun 29 08:19 AM W PALM BCH, PL
+1094 Jun 23 08:33 AM Inconleg
+1095 Jun 29 08:52 AM W PALM BCH ,PL
+1008 Jun 29 09.55 AM Incondng
+1097 Jun 23 09:05 AM Incondog
+1098 Jun 29 09:21 AM Incoring
+1090 Jun 29 $9:23 AM ATLANTA NE.GA
+1100 Jun 29 09,57 AM N PArM BCH,PL
+1101 Jun 23 10:03 AM N PALM RCH, PL
+1102 Jun 29 10:35 AM Inconing
+1103 Jun 29 11:09 AM Inconing
+1104 Jun 29 11:15 AM Incondng
+1105 Jun 29 11:20 AM N PALM BCH ,PL
+1106 Jun 29 11:25 AM Inconing
+1107 Jun 29 11:27 AM N PRIM BCH ,PL
+1108 Jun 23 11:40 AM N FALO BCH, PL
+1109 Jun 29 11:45 AM Inconing
+1110 Jun 29 11:52 AM NPALA BCH, PL
+1111 Jun 29 11:53 AM N PREM BCH,PL
+1112 Jun 23 11:53 AM Inconing
+1113 Jun 29 12:02 PM Inconing
+1114 Jun 29 12:04 PM W FALM BCH, PL
+1115 Jun 29 12:08 IN N FALM BCH .UL
+1116 Jun 29 12:17 IN W PALM BCH .PL
+1117 Jun 29 12:17 PM N PALM BCH,PL
+1118 Jun 29 01:09 PM Incondng
+1119 Jun 23 01:36 PM N PALM RCH ,PL
+Number
+561-386-4928
+561-307-7722
+561-427-2542
+Unavailable
+561-102-5212
+561-502-5212
+561-444-9994
+561-585-4454 PP
+354-377-5010
+954-581-4744
+561-585-4484 PP
+5E1-302-3212 FD
+561-427-2542
+561-502-5212
+561-502-5212
+unava llable
+561-502-3866
+561-502-5212
+770-330-1715
+561-723-1821
+770-330-1715
+561-944-9954
+561-478-418E
+864-268-6662
+561-476-4148
+561-502-5212
+561-476-4188
+561-502-5212
+561-502-3666
+561-102-1212
+561-502-1753
+561-723-3446
+561-944-9954
+561-478-4188 FF/CN
+561-502-7753 FP/CH
+561-723-3440 PP
+561-582-1564 FP
+561-723-3470
+561-723-3440
+561-123-1421
+2:00
+2100
+1:00
+1100
+1:0D
+5:00
+1,00
+1100
+1,00
+3: 0D
+1:00
+2:00
+2:00
+$100
+1:00
+9: 00
+1:00
+1,00
+1:0D
+1:00
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+0.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Changes
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time Call To
+1120 Jun 29 03,36 PM M PALK BCH, FL
+1121 Jun. 29 01:56 PM M PALM BCH, PL
+1122 Jun 29 03:59 PM M PALK BCH, PL
+1123 Jun 29 02/11 EN Inconing
+1124 Ju 29 02:28 IN M FALE BCH, FL
+1125 Jun 29 02:30 IM Incoring
+1120 Jun 29 02:46 PM Inconing
+1127 Jun 29 02,54 IN W BALK BCH, FL
+1128 Jun 29 02:5E IN M BALE BCH, VL
+1129 Jun 29 03:05 PM M PALK BCH, PL
+1130 Jun 29 03,08 PM W PALK BCH, PL
+1131 Jun 27 03:13 IN M BALE BCH, VL.
+1132 Jun 29 04:38 PM M PALA BCH, PL
+1130 Jun 29 04:41 PM M BALK BCH, PL
+1134 Jun 29 04,55 PM M PALK BCH, PL
+1136 Jun 27 05:05 IN M PALE BCH, VL.
+1136 Jun 29 06:11 PM M PALA BCH, PL
+1137 Jun 29 DE,LE IN N PALA BCH, PL
+1138 Jun 27 D6:24 IN M PALE BCH, VL
+1130 Jun 30 07:01 AM N PALK BCH, PL
+1140 Jun 30 07:07 AN M PALE BCH, PL
+1141 Jun 30 07/11 AM N PALA BCH, PL
+1142 Jun 30 07:11 A Inteleg
+1143 Jun 30 07:12 AM M PALK BCH, PL
+1144 Jun 30 07:13 AM I PALE BCH, PL
+1145 Jun 30 07:20 AN Inconleg
+1146 Jun 30 07:41 A N PALK BCH, PL
+1147 Jun 30 07:46 AM Inconleg
+1148 Jun 30 08105 AN PALA BCH,PL
+1149 JuR J0 DE:DE AN M PALE BCH, VL.
+1150 Jun 30 08:22 AM N PALK BCH, PL
+1151 Jun 30 08:33 AN ALCH, PL
+1152 Jun 30 08,35 3М Inconing
+1153 um 30 08:41 AN Inconleg
+1154 Jun 300907 A leT
+1156 Jun 30 09,12 AM BOYTONCH, FL
+1150 Jun 30 08:12 AN I BAI BCH, PL
+1157 Jun 30 09:38 AM BOCA BATON, PL
+1150 ли 30 10:05 ЛА Ін
+Min:Sec
+561-662-6616
+561-684-6672
+561-582-1964
+561-478-4188 PP
+561-47E-4168 PP
+Unavailable
+561-478-4188 FF
+561-478-4188 PP
+561-478-4168 FP
+561-310-1025 FF
+561-714-5776 PP
+561-844-9354 PF
+561-844-9994 V9
+5E1-811-0994
+561-844-9994
+561-352-7000
+561-333-7206
+561-352-7000
+561-541-5449
+561-644-1957
+561-662-6688
+5E1-662-66RR
+561-827-2542
+561-662-6688 PP
+561-662-6688 PP
+561-541-5449 PP
+561-842-6414 PP
+561-503-5930
+PP/CN
+561-541-4051
+561-202-7640
+561-478-7760
+561-662-6688
+561-503-5930
+PP/CS
+561-502-5212
+561-731-4777
+561-503-5930
+561-EE2-EE1E
+561-305-1272
+561-305-1272
+561-478-4188
+PP/NN
+3:00
+4:00
+2:00
+4:00
+1:00
+1:00
+2:00
+1:00
+3:00
+4:00
+1:00
+5:00
+5100
+5:00
+1:00
+2,00
+1:00
+1:00
+1,00
+2:00
+1:00
+6:00
+2:00
+6: 00
+1:00
+1:00
+1: 00
+11:00
+2:00
+1:00
+2:00
+3:00
+1:00
+1:00
+5:00
+1:00
+4:00
+1:00
+Usage
+4.00
+$.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+8.50 |
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+1160 Jun 30 10:16 AM M FALK BCH, FL
+Long
+Distance
+D.D0
+D.DD
+D.DD
+D.DD
+0.00l
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+0.D0|
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time CallTo
+Number
+Footnote
+Min: Sec
+1161 Jun 30 10:17 AM Inconing
+561-964-1515
+2:00
+1162 Jun 30 10:19 AM N PALM BCH, PL
+561-723-1621
+3:00
+1163 Jun 30 10:41 AM I FALM BCH ,PL
+561-123-1421
+2100
+1164 Jun 30 11:04 AM Inconing
+561-722-3311 PP
+2:00
+1185 Jun 30 11:38 AM Inconing
+561-722-3311
+2:00
+1166 Jun 30 11:30 AM Inconing
+561-122-3311
+1. 06
+1167 Jun 30 11:36 AM Inconing
+561-123-3440
+1:00
+1188 Jun 30 11:37 AM Incordng
+561-502-5212
+1169 Jun 30 11:64 AM N FALM BCH ,PL
+5E1-478-4822
+1170 Jun 30 11:46 AM N FALK BCH, PL
+561-644-4549 FP
+1171 Jun 30 11:50 AM Inconing
+561-478-4148 PP
+3,00
+1172 Jun 30 11:59 AM FALO BONL
+5E1-122-3311 FF
+1:0D
+1173 Jun 30 12:00 IM Inconing
+561-833-4002 PD/CN
+1:00
+1174 Jun 30 12:03 PM Inconing
+561-723-3421 FP
+1100
+1175 Jun 30 12:12 PM W PALM BCH ,PL
+561-723-1421
+1,00
+1176 Jun 30 12:17 PM Inconleg
+5E1-352-700D
+2:00
+1177 Jun 30 12:22 PM Inconing
+561-122-3311
+1178 Jun 30 12:30 PM Incondng
+561-352-7000
+1:00
+1179 Jun 30 12:48 IN PTLAUDERDC, PL
+254-484-8402
+1:0D
+1180 Jun 30 12:49 IM W PALM BCH, PL
+561-840-0590
+1181 Jun 30 12:52 PM N PAIN BCH, PL
+561-840-8590
+1182 Jun 30 01:05 EM Inconding
+561-502-3666
+1183 Jun 30 01:29 PM Inconing
+561-122-3311
+1184 Jun 30 01:31 PM Incoring
+561-722-9311
+1185 Jun 30 01:34 PM N FALK BCH PL
+561-502-5212
+1:00
+1:00|
+1180 Jun 30 02:20 EM N PALM BCH,PL
+561-722-3311
+1187 Jun 30 02:21 PM W PALM BCH, PL
+561-722-3311
+1:00
+1188 Jun 30 62:41 PM W FALM BCH ,PL
+561-352-7000
+1189 Jun 30 02:53 PM Incordng
+561-502-5212
+1190 Jun 30 02:57 PM Inconing
+561-182-2164
+1191 Jun 30 03:05 IM Inconing
+561-502-5212
+1192 Jun 30 03:06 PM Inconing
+561-722-3311 FF/CH
+1193 Jun 30 03:15 PM N PREM BCH,PL
+561-684-6672
+2:00
+4: 00
+1,00
+1194 Jun 30 0:1E IN Incoring
+561-122-3311
+1195 Jun 30 03:17 PM BOYTONBCH, PL
+561-503-5930
+1190 Jun 30 03:34 PM Incondng
+561-722-3311
+1197 Jun 30 04:18 PM Inconing
+361-202-7C40|
+1198 Jun 30 04:20 IM W PALM BCH ,PLI
+561-662-6616|
+2:00
+2:00
+2:00
+1:00
+1190 Jun 30 04:27 PM N PALM BCH,PL
+561-723-1421
+1200 Jun 30 04:32 EM W PALM BCH ,PL
+561-582-1964
+1201 Jun 30
+C4:34 PM N FALM BCH .PL
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+0.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time Call To
+1202 Jun 30 04,36 PM M BALK BCH, FL
+1200 Jun 90 04:51 IM Inconing
+124 Jun 30 D5:02 PM Inconleg
+1206 Jun 30 05/16 EM Inconing
+1200 Jun. J0 03:47 I M PALE BCH, PL
+1207 Jun 30 05:56 PM Incoming
+1208 Jun 30 06:11 PM M BALK BCH, PL
+1200 Jun 30 06127 IN M BALK BCH, FL
+1210 J: 30 DE:32 # M BALE BCH, VL
+1211 Jun 30 D6:34 EN FAROKES, FL.
+1212 Jun 30 07:03 EN Inconing
+1213 Ju: 30 07:28 W Iscoeleg
+1214 Jun. 30 07:48 PM DALK BCH, PL
+1215 Jun 30 08:32 EN Inconleg
+1218 Jun 30 08157 EN Inconing
+1218 Jul 01 06:53 AM S VALA BCH, PL
+1219 Jul 01 07,11 A M PALA BCH, PL
+1220ли 01 07:13 8 0 PALE BCH, FL
+1221 Jul 01 07:32 AM Isconieg
+1222 Jul 01 07:35 1М Inconleg
+1223 Jul 01 08,38 AM Inconleg
+1224 dal 01 08 40 0 Inteleg
+1220 Jul 01 08:49 AM M PALA BCH, PL
+1220 Jul 01 09:14 AN PALE BCH, PL
+1227 Jel 01 09,15 3N BAL BCH, PL
+1228 Jul 01 09:34 AN Inconley
+1229 Jul 01 09:34 AN PALE BCH, PL
+1230 Jal 01 09,45 1М Inconleg
+1231 Jul 01 10:01 AN M PALE BCH, FL
+1232 Jul 01 10:15 AM M PALK BCH, PL
+1230 Jul 02 10:18 2м InconleT
+1234 Jal 01 10:20 AN Inconleg
+123814l 0110:301 BOTONCE,
+1236Jul 02 10:42 1М Інспікт
+1237 Jul 01 10:44 AM Inconleg
+1238 Jul 01 10:52 AN BAI BO,PL
+1230 Jul 01 10:54 AM Inconieg
+1240 2иl 01 12:14 М Іні
+1241 Jul 01 11:31 3N Inconleg
+1242 14l 01 11:50 AN INcle
+561-844-999÷
+561-541-5449 PP
+561-202-7640 PP
+561-762-2874 PP
+561-644-1457 M
+561-662-6616 FF
+561-644-1957 PP
+561-502-5123 PP
+561-924-8880 FF
+561-544-4989 PP
+561-85E-69E7 PP
+561-502-5212 V9
+561-502-5212
+561-478-776D
+561-582-1964
+8
+8
+561-662-6616
+561-844-3954
+561-714-5776
+561-502-5123 FP
+561-790-5387
+561-630-8737
+561-719-4961
+561-502-5212
+561-662-6688
+561-723-1821
+561-723-1821
+561-827-2542
+561-502-5212
+561-503-5930
+561-541-5449
+561-503-5930
+561-856-6967
+561-723-1821
+561-502-5212
+561-503-5930
+561-478-4188
+561-503-5930
+Min:Sec
+7.00
+1100
+1:00
+1:00
+5.00
+1:00
+1:00
+17,00
+1:00
+1:00
+2:00
+1:00
+1:00
+1:00
+2:00
+1:00
+1,00
+3: 00
+3:00
+1:00
+4:00
+1:00
+1:00
+2:00
+1:00
+1:00
+7,00
+1: 0a
+1:00
+2:00
+1:00
+1:00
+1:00
+2:00
+Usage
+4.00
+$.00
+4.DD
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+8.50 |
+• 0[
+0.0D
+•.00
+9,00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+4.00
+Long
+Distance
+D.D0
+D.DD
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.00 |
+п nn
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time CallTo
+1243 Jul 01 11:53 AM I PALM BCH.PD
+1244 Jul 01 11:56 AM N PALM BCH, PL
+1245 Jul 01 11:54 AM JUPITER, PL
+1240 Jul 01 12:11 FM Inconing
+1247 Jul 01 12:39 PM N RAIN RCH, PL
+1248 Jul 01 12:20 IM N PALM BCH, PL
+1240 Jul 01 12:22 PM N FALA BCH, PL
+1250 Jul 01 12:34 EM Incondng
+1251 Jul 01 12:41 PM Inconing
+1252 Jul 01 12:52 PM Inconing
+1253 Jul 01 12:59 PM W PALM BCH ,PL
+1254 Jul 01 02:00 IN N FALE RCH, PL
+1255 Jul 01 01:03 IN Incoring
+1258 Jul 01 01:31 PM Inconing
+1257 Jul 01 01.12 PM W PALM BCH ,PL
+1258 Jul 01 01:13 PM N PALM RCH, PL
+1258 Jul
+01 01:14 W Incoming
+1280 Jul 01 01.22 EM W PALM BCH.PL
+1281 Jul 01 01:25 aM Inconleg
+1202 Jul
+01 01:30 W Incoring
+1283 Jul 01 01:43 PM Inconing
+1264 Jul 01 01,54 PM N pArM BCH,PL
+1285 Jul 01 01:55 EM N FAL ACH, PL
+1200 Jul 01 02:09 PM Incoring
+1287 Jul 01 02:16 PM N FALK BCH, PL
+1288 Jul 01 02151 EM Inconding
+1208 Jul 01 02:56 IM Inconing
+1270 Jul 01 03:10 PM Inconing
+1271 Jul 01 03:44 PM Incordng
+1272 Jul 01 05:31 IN N FALO BCH, PL
+1273 Jul 01 05:34 IM W PALM BCH, PL
+1274 Jul 01 06:41 PM PALA BCH,PL
+1275 Jul 02 07,54 AM Incordng
+1276 Jul 02 08:09 AM Inconing
+1277 Jul 02 08:12 AM Inconing
+1278 Jul 02 08:54 AM Incondng
+1279 Jul 02 08:12 AM Inconing
+1280 Jul 02 09:24 AM W PALM BCH .PL
+1281 Jul 02 09:53 AM Inconing
+1282 Jul 0209,54 AM PALAC.PL
+12233l 03
+0a:58 AM Incorina
+Number
+561-474-4148
+561-722-3311
+561-744-4703
+:
+561-744-4703
+561-714-577E
+561-644-3360
+561-719-3531
+561-502-5212
+561-714-577E
+SE1-502-5212
+561-478-4148
+5E1-352-700D
+561-503-5930
+561-502-5212
+561-714-1421
+5E1-721-1821
+561-714-5776
+561-502-7753
+561-141-5443 F0/CN
+561-541-4051 00
+561-352-7000
+561-352-7000
+561-478-418E
+561-502-5212
+561-352-7000
+561-582-9575
+561-856-6967
+561-502-3666
+561-456-6967
+561-827-2542
+561-123-3440
+561-333-7536
+561-474-7760
+561-121-1821
+561-305-3272
+561-502-3666
+361-105-1272
+561-478-0783
+561-723-1421
+561-795-9549
+Min: Sec
++: 00
+1:00
+13:00
+2:00
+1. 06
+1100
+1:0D
+1,00
+1:0D
+1100
+1,00
+1:0D
+4: 00|
+1:00
+3: 00
+1,00
+3: 0D
+1:00
+1:00
+2:00
+3: 00
+$100
+1:00
+2,00
+2:00
+2:00
+2:00
+5:00
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+0.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time Call To
+1284 Jul 02 10:17 3M Inconing
+1285 Jul 02 10:20 AM Inconing
+1286 Jul 02 10:22 AN Inconleg
+1287 Jul 02 10:24 3M M BALK BCH, PG
+1288 Jul 02 11:08 AM M PALE BC, FL
+1289 Jul 02 11:13 AM Incoming
+1200 Jul 02 12:32 AN BALK BCH, PL
+1291 Jul 02 11,34 JM Inconing
+1292 Jul 02 11:58 AN Inconleg
+1200 Jul 02 12:07 PM Incoming
+1204 Jul 02 12:13 PM W PALK BCH, PL
+1296 Jul 02 12:15 W Iscoeleg
+1296 Jul 02 12:20 IM Inconieg
+1207 Jul 02 12:21 IN M PALE BCH, PL
+1208 Jul 02 12,22 PM M PAL BCH, PL
+1290 Jul 02 12:49 IN M PALE BCH, VL.
+1300 Jul 02 01:03 PM Incoming
+1301 Jul 02 01,20 PM Inconing
+1302ли] 02 01:25 N M PALE BCH, FL
+1300 Jul 62 01:36 PM Incoming
+1304 Jul 02 03:39 PM Inconleg
+1306 Jal 02 01:42 EM M BALE BCH, PL
+1306 aul 02 01:55 m Inteleg
+1307 Jul 02 01:57 PM M PALE BCH, PL
+1300 Jul 02 02:27 PM IsoniNg
+1300 Jul 02 02132 PM Inconing
+1311 Jul 02 02:41 IN Incoming
+1312 Jul 02 03,06 PM Inconleg
+1313 u] 02 03:14 #N INcoRleg
+1314 Jul 02 03:19 PM M PALK BCH, PL
+1315 Jul 02 03:20 PM M BALE BCH, PL
+1318 Jal 02 03132 PM Inconleg
+1317 Jal 02 03:14 # IncoaleT
+1318 Jul
+02 03:38 PM M PALE BCH, PL
+1319 Ja]
+02 03,39 PM M BAIR BCH, PL
+1320 1иl 02 03:40 m Inclea
+1321 Jul 62 04:10 PM M PALA BCH, PL
+1322 Jul 62 04:15 IN DEEPLECH, PL
+1329 Jal 02 04:28 PM Incoming
+04:34 IN Inceled
+Number
+561-502-3866
+561-722-3311
+561-502-3866 PP
+561-795-9549 PP
+561-722-3311 PP
+561-502-5212 09
+561-541-4051 FF
+561-723-1821 PP
+561-502-386E FP
+561-502-3866 FF
+561-951-4819 PP
+561-723-1821 PP
+561-503-8429 V9
+561-478-4188
+561-202-7640
+561-827-2542
+561-842-641+
+561-723-3440
+561-707-7600
+561-722-3311
+PP/CN
+561-727-1440
+561-478-4188 FP
+561-722-3311 PP
+561-478-4168
+561-502-3866 PP
+561-478-4188
+561-795-7715
+561-478-4188
+561-502-5212
+561-478-1190
+562-684-3332
+561-541-5449
+561-627-15ED|
+PP /CN
+561-541-5449
+561-627-1560
+561-827-2542
+561-723-3440
+954-818-3335
+561-478-4188
+82T A9aA1
+Min:Sec
+3,00
+3,00
+1:00
+2:00
+1:00
+1:00
+1:00
+2:00
+3:00
+2:00
+3:00
+1:00
+1:00
+1:00
+5.00
+2:00
+4: 00
+1.00
+3,00
+2:00
+1:00
+2:00
+2:00
+1:00
+3:00
+1:00
+2:00
+1:00
+1:00
+3,00
+4: 00
+1:00
+1100
+1:00
+4:00
+2:00
+2:00
+7:00
+Usage
+4.00
+$.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+8.50 |
+• 0[
+0.0D
+•.00
+9,00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.DD
+D.DD
+D.DD
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• on
+0.00 |
+п nn
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Min: Sec
+Item # Date Time CallTo
+1325 Jul 02 04:4+ FM N PALM BCH, PL
+1326 Jul 02 04:45 IM N PALM BCH, PL
+1327 Jul 02 05:27 PM I FALM BCH, PL
+1328 Jul 02 05:28 FM 1 PALM BCH, PL
+1329 Jul 02 05:30 PM Inconing
+1330 Jul 02 05:46 IM N PALM BCH, PL
+1331 Jul 02 05:51 PM N FALA BCH, PL
+1332 Jul 02 05:52 EM W PALM BCH,PL
+1333 Jul 02 05:53 #M Inconing |
+1334 Jul 02 06:11 PM W FALA BCH, PL
+1335 Jul 02 06.34 EM Incondng
+1336 Jul 02 07:20 # Inconing
+1337 Jul 02 07:49 IM N PALM BCH, PL
+1338 Jul 02 07:56 PM Inconing
+1330 Jul 02 08:25 EM Incondng
+1340 Jul 03 06:65 AM N RAIN RCH, PL
+1341 Jul
+03 06:47 AM W PALM BCH ,PL
+1342 Jul 03 06:45 AM W FALM BCH,PL
+1343 Jul 03 06:50 AM N PALM BCH,PL
+1344 Jul 09 06:55 AM W PALM BCH, PL
+1345Jul Jul 03 MM AN FALK BCH,PL
+1348 Jul 03 07:54 AM Inconding
+1347 Jul 03 08:32 AM N PALM RCH, PL
+1348 Jul 09 08:39 AM N PALM BCH, PL
+1340 Jul 03 09:15 M N PALM BCH ,PL
+1350 Jul 03 09:17 AM Incondng
+1301 Jul 03 09:36 AM Inconing
+1352 Jul 03 10:23 AM Inconing
+1363 Jul 03 10:26 AM N PRIM BCH, PL
+1354 Jul 03 10:40 AM N PALM BCH, PL
+1355 Jul 09 10:44 AM W PALM BCH, PL
+1356 Jul 03 10:49 AM Inconing
+1357 Jul 03 10:52 AM Incondng
+1358 Jul 03 10:57 AM N FAIN RCH, PL
+1350 Jul 03 11:36 AM N PALM BCH,PL
+1360 Jul 03 11:27 AM W FALM BCH, PL
+1361 Jul 0J 11:60 AM Inconing
+1362 Jul 03 11:47 AM W PALM BCH,PLI
+1363 Jul 03 11:44 AM Inconing
+1364 Jul 03 11,52 AM N FAL BCH, PL
+1365 Jul 03 11:55 AM N PALM RCH ,PL
+Number
+561-684-3559
+561-684-3559
+561-714-0935
+561-541-5449
+561-141-5443 FF
+561-123-3440
+561-502-3666
+561-474-7760
+5E1-502-3BEE
+561-502-5212
+561-951-4819 PP
+5E1-842-2050 FD
+561-951-4819 P0
+561-951-4619
+561-427-2542
+561-478-77ED
+561-723-3440
+561-723-3440
+561-CE2-ECEE
+561-662-6616
+561-723-3440
+561-541-5449
+561-141-4051
+561-951-4819
+561-358-7914
+561-358-7914
+561-252-4363
+561-766-2295
+561-252-4343
+561-188-0883
+561-951-4619
+561-951-4519
+561-541-7631
+561-BC8-3479
+561-951-4619
+561-951-4819
+561- 85E-EDE7
+561-252-4383
+561-502-5212
+561-951-4819
+BI_SEE_9158
+2:00
+1100
+1,00
+7:00
+1:00
+1100
+1,00
+4:00
+1,00
++:00
+2:00
+6:00
+1:00
+2,00
+2:00
+2:00
+1,00
+2:00
+6,00
+1:00
+1:00
+1:00
+1,00
+2,00
+1:00
+1,00
+3:0D
+1:00
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+• 0n
+D. DD
+D.DD
+0.0D
+D.DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time Call To
+1386 Jul 03 11:57 3M Inconing
+1367 Jul 03 12:15 IM Inconing
+1368 Jul 03 12:27 PM M PALK BCH, PL
+1300 Jul 03 12,30 PM SILVER SPG,MD
+1370 Jul 03 12:32 PM M PALE BCH, FL
+1371 Jul 03 12:45 IM Inconing
+1372 Jul 03 12:45 PM M BALK BCH, PL
+1373 Jul 03 01:03 PM M BALK BCH, PL
+1374 Jul 03 01:04 IN Inconleg
+1375 Jul 03 03:08 PM M PALK BCH, PL
+1378 Jul 03 01/10 EN Inconing
+137 aal 03 02:09 Incala
+1378 Jul 03 02:15 IM M DALK BCH, PL
+1379 Jul 03 02:20 PM M PALK BCH, PL
+1350 Jul 03 02,22 PM M PALK BCH, PL
+1381 Jul 03 02:33 WN M PALE BCH, FL
+1382 Jul 03 03:04 IN IncoRiet
+1383 Jul 03 03,56 PM N PALA BCH, PL
+1384 cal 03 04:47 Inclay
+1385 Jul 03 05:01 PM S PALK BCH, PL
+1366 Jul 03 05:03 PM M PALE BCH, PL
+1387 Jal 04 09,36 AM Inconing
+1358 aal 04 11:45 a Inteleg
+1389 Jul 04 03:16 PM M PALA BCH, PL
+1300 Jul 04 03:34 PM Inconteg
+1301 Jul 04 03:40 PM M BALA BCH, PL
+1392 Jul 04 03:42 PM M PALK BCH, PL
+1300 Jul 04 03:43 # Incoming)
+1304 Jal 04 03151 PM PALA BCH, PL
+13005:00 Il
+1396 Jul 04 05:24 PM 5 PALK BCH, PL
+1397 Jul 04 08:12 PM InconleT
+1308 Jal 0507,09 AB,PL
+1300 Jal 03 07:15 AN PALE BCH, FL
+1401 Jal 05 09,07 AM Inconing
+1402 ul 03 08:47 AN Incaleg
+1400 Jul 05 09:49 AM Incorieg
+1406 Jul 05 10:41 AN I BALE BCH, FL
+14062l03 1:05 A0 1Cle
+Number
+561-951-4819
+8
+561-676-3248
+8
+561-662-6688 OF
+301-608-0584 OP
+561-951-4815 OF
+561-5A1-54д9 Ca
+561-541-5449 OP
+561-644-8737 0P
+561-541-5449 OP/CN
+561-333-7530 OP
+561-333-7530
+8
+561-541-5449 OF
+561-333-7530 08
+5E1-EE2-1098
+561-541-5449
+561-252-4383
+561-616-8240
+561-662-3098
+561-393-7530
+8
+8
+8
+8
+8
+5E1-924-RRRD
+561-827-2542
+561-964-5511
+561-502-5212
+561-662-3098
+561-827-2542
+561-662-3098
+561-762-7428
+561-827-2542
+561-602-2291
+561-255-2520
+561-255-2520
+561-502-5212
+561-541-5449
+561-502-5212
+561-541-5449
+561-541-5449
+561-202-7640
+561-202-7640
+8
+8
+8
+8
+8
+8
+8
+8
+8
+Min:Sec
+2:00
+3:00
+2:00
+1:00
+1:00
+1:00
+2:00
+4:00
+2:00
+3:00
+6: 00
+1:00
+1:00
+1:00
+3: 00
+1:00
+3:00
+1,90
+1:00
+3:00
+2:00
+1:00
+3:00
+1100
+4: 00
+3:00
+1:00
+2:00
+2:00
+1:00
+1:00
+1:00
+1:00
+1,00
+Tonn
+Usage
+4.00
+$.00
+• DE
+0.0D
+$.00
+$.00
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+8.50 |
+• 0[
+0.0D
+•.00
+9,00
+0.0D
+$.00
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.DD
+D.DD
+D.DD
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+0.D0|
+п nn
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time CallTo
+Number
+Footnote
+Min: Sec
+1407 Jul 05 12:04 FM Inconing
+561-964-4362
++: 00
+1400 Jul 05 12:20 IM Inconing
+561-202-7640
+1:00
+1400 Jul 05 01:34 PM Incoming
+561-502-5212
+110D
+1410 Jul 05 05,35 PM W PALM BCH,PL
+561-723-3440
+1,00
+1411 Jul 05 05:36 PM Inconing
+561-723-3440
+8: 0D
+1412 Jul 06 07:18 AM N PALM BCH, PL
+561-662-6688
+1413 Jul 06 07:20 AM N FALA BCH, PL
+561-502-5212
+1:00
+1414 Jul 06 07:21 AM PILAUDERDE, PL
+954-581-4200
+2100
+1415 Jul DE 07:27 A N FAL ECH ,PL
+561-844-3444
+1416 Jul 06 07:34 AM N FALA BCH, PL
+561-444-9954
+$:0D
+1417 Jul 06 07:43 AM W PALM BCH ,PL
+561-541-4051
+2,00
+1418 Jul DE 07:50 AM I FALE BCH, PL
+5E1-341-3449 FD
+1:0D
+1419 Jul 06 08:40 AM N PALM BCH, PL
+561-541-5449 P0
+2:00
+1420 Jul 06 08:43 AM Inconing
+561-434-9006
+1100
+1421 Jul 06 09:14 AM Incondng
+954-650-9306
+2,00
+1422 Jul 0E 09:16 AM Inconleg
+410-336-4561|
+Sp/CN
+1:0D
+1423 Jul 06 09:18 AM DEERPLORCH,PL
+954-650-9306
+3:00
+1424 Jul 06 09:24 AM Incondng
+561-202-7640
+1425 Jul 06 00:31 AM A PALM BCH, PL
+561-723-3440
+1426 Jul 06
+09:34 AM W PALM BCH, PL
+561-202-7640
+2:00
+1:00
+1427 Jul 06 09:37 AM N PALM BCH,PL
+561-719-4222
+1428 Jul 06 09:51 AM Inconding
+561-514-4940
+2,00
+1429 Jul 06 00:54 AM DEERILDCH, PL
+254-650-330€
+1430 Jul 06 10:00 AM N PALM BCH ,PL
+561-686-4622
+1431 Jul 06 10:02 MM Inconing
+561-302-7646
+1:00
+1432 Jul 06 10:09 AM Incondng
+561-502-3866
+1433 Jul 06 10:17 AM N PALM BCH, PL
+561-951-4619
+1434 Jul 06 10:22 AM N FALM BCH ,PL
+561-478-4148
+5:00
+1:00
+1435 Jul 06 10:22 AM Incondng
+561-723-3440
+pP/ew
+1436 Jul 0E 10:26 AM Inconing
+561-123-1821 FF
+3: 00
+1437 Jul 06 10:31 AM W PALM BCH ,PL
+561-964-1515
+1430 Jul 06 10:36 AM N PALA BCH, PL
+561-478-4148
+1439 Jul 06 10:37 AM BALTIMORE,MD
+410-336-4961
+1:00
+2,00
+1440 Jul DE 10:38 AM Incoring
+410-336-4961
+FP /CN
+1441 Jul 06 10:39 AM N PALM BCH,PL
+561-723-3621 FP
+1442 Jul 06 10:54 AM BOYTONBCH, PL
+561-577-4416 PP
+1443 Jul DE 10:57 AM N FALM BCH .UL
+561-478-4388 FP
+1444 Jul 06 11:02 AM W PALM BCH .PL
+561-478-4188
+1,00
+$:0D
+2:00
+1445 Jul 06 11:03 AM N PALM BCH,PL
+561-474-4148
+1448 Jul 06 11:04 AM WALA BCH,PL
+561-663-1116
+1447 Jul 0E 11:0P AM Inconing
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DĐ
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+0.0D
+D.0D
+0.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time Call To
+1448 Jul 06 11:20 3M M BALK BCH, FL
+1449 Jul 06 11:22 AM M PALE BCH, PL
+1450 Jul 06 13:27 AM Inconleg
+1451 Jul 06 11,35 AM M PALK BCH, FL
+1452 Jul 06 11:40 A BOSTONECH, FL
+1453 Jal 06 11:47 AM N PALK BCH, PL
+1454 Jul 06 12:56 AN W BALK BCH, PL
+1456 Jul 06 11,58 AM Inconing
+1456 Jul 0€ 12:01 IN M BALE BCH, PL
+1457 Jul 06 12:04 EN W PALE BCH, PL
+1458 Jul 06 12/05 EM Inconing
+1450 Jul 0€ 12:11 IN M BALE BCH, VL.
+1450 Jul 06 12:24 PM Inconieg
+1481 Jal 06 12:27 PM N BALE BCH, PL
+1482 Jul 06 12,30 PM M PALK BCH, PL
+1480 Jul 06 12:38 PM BALA BOT, PL
+1454 Jul 06 12:41 IM Incoming
+1486 Jul 06 12143 PM Inconing
+1400 Jul 0€ 01:21 IN M PALE BCH, PL
+1457 Jul 06 01:22 PM Incoming
+1458 Jul 06 03:23 PM Inconleg
+1480 Jul 06 03,28 PM M PALA BCH, PL.|
+1470 Jul 0€ 01:29 IN M PALE BCH, PL
+1471 Jul 06 01:35 PM M PALK BCH, PL
+1472 Jul 06 03:42 PM M PALE BCH, PL
+1473 Jul 06 01:44 EM N BAI BCH, PL
+1474 Jul 06 01:45 PM 5 PALK BCH, PL
+1475 Jul 06 02:46 PM M PALE BCH, PL
+147฿ Jul 06 02,49 PM M BALA BCH, PL
+1477 Jul 06 01:59 INcoRley
+1478 Jul 06 03:03 PM BOYTONBCH, PL
+1479 al 06 03:04 PM PALE BCH, PL
+1450 Ja] 06 03,05 PM Inconleg
+148124l 06 03:080 Inclag
+1482 Jul 06 03:17 PM Incle
+1483J 0603,19 PM ALB,PL
+1454 Jul 06 03:24 PM INCORLeg
+1485 Jul 06 03:33 PM Incorleg
+1486 Jul 06 04:00 IN M PAIR BCH, PL
+1487 Jal 06 04,03 PM M BALE BCH, PL
+1488 74l 06 04:05 IN M PALE BCH, FL
+Min:Sec
+561-856-122÷
+561-478-4188
+561-478-4168 PP
+561-478-4188 PP
+561-577-4416 PP
+561-A44-9994 M
+561-202-7640 FF
+561-478-4188 PP
+561-723-3440
+561-662-6616 FP
+561-721-5212
+PP/C
+561-844-9354 PF
+561-310-1025 P9
+561-333-7530 PP
+561-202-7640
+954-962-1079
+561-202-7640
+561-202-7640
+561-502-5212
+561-719-5032
+561-502-5212
+561-202-7640
+561-686-4924
+561-502-7753
+561-478-4188
+561-662-3098
+561-352-7000
+561-721-5212
+561-502-5212
+561-503-1359
+561-827-2542
+561-502-7753
+561-478-4188
+561-502-5212
+561-502-7753
+561-502-5212
+561-541-5449
+561-827-2542
+561-659-4020
+PP/CW
+PP/CW
+P/CN
+7:00
+4:00
+1:00
+6:00
+2:00
+1:00
+1:00
+1:00
+4:00
+2:00
+2:00
+1:00
+1:00
+16:00
+1:00
+3:00
+3:00
+2100
+6: 00
+1:00
+1:00
+1:00
+1:00
+2:00
+4.00
+2:00
+1:00
+2:00
+4,00
+J:0a
+3:00
+1:00
+2:00
+1:00
+1:00
+7:00
+Usage
+4.00
+$.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+8.50 |
+• 0[
+0.0D
+•.00
+9,00
+0.0D
+$.00
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+4.00
+Long
+Distance
+D.D0
+D.DD
+D.DD
+D.DD
+D.DD
+0.00|
+D.D0
+D.DD
+0.00 |
+0,00
+D.D0
+• DO
+• on
+0.00 |
+п nn
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+g.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time CallTo
+1480 Jul 06 04:29 PM Inconing
+1490 Jul 06 04:37 IM Inconing
+1491 Jul D€ 04:51 PM Inconing
+1492 Jul 06 05:06 EM W PALM BCH ,PL
+Footnote
+Min: Sec
+1,00
+1:00
+110D
+1,00
+1:00
+1494 Jul 06 05:08 IM N PALM BCH, PL
+1495 Jul 06 05:13 PM W FALA BCH, PL
+1490 Jul 06 05:15 EM W PALM BCH, PL
+1497 Jul DE 05:16 IN N FALM BCH, PL
+1498 Jul 06 05:19 PM W FACE BCH, PL
+1499 Jul 06 05:25 PM W PALM BCH ,PL
+1500 Jul DE 05:31 PM 1 FALE BCH, PL
+1501 Jul 06 05:37 IM Incoring
+1502 Jul 06 05:44 PM Inconing
+1509 Jul 07 06:53 AM Incondng
+1504 Jul 07 07:02 AM PTLADERD, PL
+1505 Jul
+07:03 AM Inconing
+1508 Jul 07 07:07 AM Incordng
+1507 Jul 07 07:28 AM Inconing
+1508 Jul 07
+08:22 AM W PALM BCH ,PL
+1500 Jul 07 08:36 M Inconing
+1510 Jul 07 04.53 AM N PAIM BCH, PL.
+1511 Jul 07 08:56 AM Inconing
+1512 Jul 07 09:01 AM N PAL BCH, PL
+1513 Jul 07 09:03 AM N FALM BCH, PL
+1514 Jul 07 09,06 AM N PALM BCH,PL
+1515 Jul 07 09:15 AM Inconing
+1516 Jul 07 09:20 AM Inconing
+1517 Jul 07 09.34 AM Incondng
+1518 Jul 07 10:08 AM N FALO BCH, PL
+1519 Jul 07 10:26 AM W PALM BCH, PL
+1520 Jul 07 10:24 AM N PALA BCH, PL
+1521 Jul 07 10:29 AM W PACK BCH ,PL
+1522 Jul 07 10:43 AM Inconing
+1523 Jul 07 10:46 AM Inconing
+1524 Jul 07 11:01 AM Inconing
+1525 Jul 07 11:02 AM N FALO BCH .UL
+1526 Jul 07 11:06 AM Incoring
+1527 Jul 07 11:26 AM N PALM BCH,PL
+1528 Jul 07
+11:43 AM Incordug
+1529 Jul 07
+Number
+561-541-5449
+561-478-4188
+561-502-5212
+561-502-5212 FP
+561-062-EEEE FP
+561-662-6688
+561-721-5212
+561-333-7530
+5E1-85E-1224
+SE1-121-5212
+561-478-4148 PP
+SE1-3DE-1841 FP
+561-476-4188 PP
+561-502-5212 FP/CN
+561-427-2542
+254-444-EB3E FD
+561-502-5212
+954-444-5836
+pP /CN
+561-329-0783 FP
+561-827-2542
+954-342-3544
+561-965-0722
+561-627-1560
+561-476-4188P0
+561-427-2542
+561-627-1560
+561-502-1753
+561-427-2542
+561-644-1957
+561-683-181E
+561-844-9994
+561-662-6616
+561-602-4074
+561-495-6762
+:
+561-723-3440 FP/CH
+561-627-1560
+561-478-4188 FP
+561-541-5449
+561-723-3440
+954-450-4251
+1100
+1,00
+6:00
+1,00
+5:0D
+3: 0D
+1:0D
+5:00
+2,00
+7: 00
+1:00
+3: 00
+2,00
+4: 0D
+1,00
+6:00
+2: 00
+2:00
+$100
+2:00
+4: 00
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.DD
+D. DD
+D.DD
+0.0D
+D. DD
+Changes
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time Call To
+1530 Jul 07 11:50 3M M BALK BCH, FL
+1531 Jul 07 12:01 IM Inconieg
+1532 Jul 07 12:09 EN IncoRleg
+1530 Jul 07 12:18 PM FADERD, PL
+1534 Jul 07 12:20 IN M FALE BCH, FL
+1536 Jul 07 12:36 PM 5 PALK BCH, PL
+1538 Jul 07 12:39 PM M BALK BCH, PL
+1537 Jul 07 12:40 IN W BALK BCH, FL
+1538 Jul 07 12:54 IN M BALE BCH, VL
+1530 Jul 07 12:56 EN Inconleg
+1540 Jul 07 01/10 EN Inconing
+1541 Jul 07 01:11 IN M BALE BCH, VL.
+1542 Jul 07 01:15 PM 5 PALK BCH, PL
+1543 Jul 07 02:27 PM PLAUDEADL, PL
+1544 Jul 07 01,19 PM M PAL BCH, PL
+1545 Jul 07 01:19 IN M PALE BCH, VL.
+1546 Jul 07 01:46 IN I PALA BCH, PL
+1547 Jul 07 01,50 IN Inconing
+1548 al 07 02:10 Incle
+1549 Jul 07 02:24 PM 5 PALK BCH, PL
+1550 Jul 07 02:29 PM Inconleg
+1551 Jul 07 02,33 PM M PALE BCH, PL
+1552 Jul 07 02:47 IN M PALE BCH, PL
+1553 Jul 07 03:11 PM M PALA BCH, PL
+1554 Jul 07 03:19 PM M PALE BCH, PL
+1556 Jul 07 03:22 PM M BALA BCH, PL
+1550 Jul 07 03:24 PM PALE BCH, PL
+1557 Jul 07 03:34 PM I PALE BCH, PL
+1558 Jul 07 03:46 PM M BALA BCH, PL
+1500 Jul 07 04:37 PM Incoming
+1561 Jul 07 04:50 PM InconleT
+1580 Ja] 07 05:20 PM Inconleg
+1583 Jul 07 05:21 IN M PALE BCH, FL
+1584 Jul 07 05:33 PM PALE BCH, PL
+1586 Jal 07 05:48 PM Inconing
+1500 all 07 05 40 0 Incalag
+1567 Jal 07 06:13 PM PALE BC,PL
+1580 Jal 07 06:16 IN MAA BCH, FL
+157024l0 0:11 1cla
+Number
+561-502-3866
+561-478-4188
+561-723-1821
+954-581-4200 PP
+561-723-1821 PP
+561-229-LLAN
+561-502-96D6 FF
+561-723-3440 PP
+561-844-9954 FP
+561-502-96DE FF
+954-942-3544 PP
+561-723-3440 PP
+561-723-3440 V9
+954-581-1200
+561-827-2542
+561-827-2542
+561-723-3440
+561-798-1595
+561-723-3440
+561-721-5212
+561-784-0843
+5E1-541-4051
+561-662-6616
+561-478-4188
+561-596-1841
+561-478-4188
+561-951-1444
+561-721-5212
+561-721-5212
+561-662-6616
+Unavaliable
+561-502-5212
+561-502-5212
+561-856-7802
+561-502-5212
+561-324-1491
+561-793-1712
+561-333-7530
+561-333-7530
+Min:Sec
+2:00
+1:00
+4:00
+2:00
+E:00
+3:00
+1:00
+4:00
+1:00
+1:00
+2:00
+1:00
+1:00
+1:00
+4: 00
+1:00
+3.00
+3:00
+3:00
+4:00
+1:00
+1:00
+2:00
+1:00
+3,00
+2:00
+1:00
+1:00
+2:00
+1:00
+1:00
+1:00
+1: 0a
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+2:00
+Usage
+4.00
+$.00
+4.DD
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+8.50 |
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.DD
+D.DD
+D.DD
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+0.D0|
+п nn
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Min: Sec
+Item # Date Time CallTo
+1571 Jul 08 06:59 AM Incordng
+1572 Jul 08 07:02 AM N PALM BCH, PL
+1573 Jul 08 07:04 AM PILAUDERD, PL
+1574 Jul 08 07:05 AM BOCA RATON, PL
+1575 Jul 08 07:08 AM BOCA RATON, PL
+1576 Jul 08 07:09 AM BOCA RATON, PL
+1577 Jul 08 07:09 AM BOCA RATON, PL
+1578 Jul 08 07.09 AM Inconding
+1579 Jul 08 07:21 AM Inconing
+1580 Jul 08 07:54 AM W FALA BCH, PL
+1581 Jul 08 07:57 AM BOCA RATON, PL
+1582 Jul 08 08:02 AM Inconing
+1583 Jul 08 08:08 AM Incoring
+1584 Jul 08 08:13 AM BOCA RATON, PL
+1585 Jul 08 08.54 AM W PALM BCH, PL
+1586 Jul 08 08:59 AM N FALA RCH ,PL
+09:04 AM Incoming
+1588 Jul 08 09.07 AM W PALM BCH.PL
+1580 Jul 08 00:15 AM A PAL SCH,PL
+1590 Jul
+08 69:18 AM N PALM BCH, PL
+1501 Jul 08 09:21 AM N PALM RCH,PL
+1502 Jul 08 09,30 AM N PArM BCH,PL
+1503 Jul 08 00:45A0AFAL0 CHAL
+1594 Jul 08 09:47 AM Incoring
+1595 Jul 08 09:55 AM Inconing
+1500 Jul 08 10:08 AM Inconing
+1597 Jul 08 10:44 AM W PALM BCH, PL
+1590 Jul 08 10:52 AM N FALM BCH ,PL
+1590 Jul 08 11:31 AM Incondug
+1600 Jul 08 11:36 AM Inconing
+1601 Jul 08 11:46 AM Inconing
+1602 Jul 08 11:54 AM PTLAUDERDG, PL
+1803.Ju1 08 12:03 PM Incordng
+1604 Jul 08 12:06 PM Inconing
+1605 Jul 08 12:34 PM BOYTONBCH, PL
+1600 Jul 08 12:29 EM W FALA BCH, PL
+1607 Jul D8 12:20 PM N FAI RCH, PL
+1608 Jul 08 12:21 IN W PALM BCH.PL|
+1600 Jul 08 12:37 PM BOYTONECH, PL
+1810 Jul 08 12:41 Incondug
+1811 Jul
+Number
+561-502-5212
+561-358-7914
+954-581-4300
+561-929-5414 PP
+561-729-6414 FF
+561-929-6414 PD
+561-929-6414 FP
+561-929-6414 PP/CH
+561-728-6414 FF
+561-666-4924 FP
+561-929-6414 PP
+5E1-358-7914 FD
+561-427-2542
+561-929-6414
+561-474-4148
+5E1-352-700D
+561-427-2542
+561-474-4148
+561-478-418E
+561-795-9549
+561-721-5212
+561-662-6616
+561-818-6527
+561-818-6527
+561-476-4148
+561-687-4791
+561-502-5212
+561-914-6527
+561-474-5890
+TDE-745-1394
+561-818-6527
+954-581-4200
+561-929-5414
+561-122-1873
+:
+561-436-4378
+561-474-4148
+561-352-7000|
+561-478-4188
+561-434-4378
+954-476-3037
+1:00
+2: 00
+2:00
+1:00
+1:00
+1100
+1:0D
+2,00
+3: 0D
+2:00
+1100
+1:0D
+1:00|
+5,00
+2: 0D
+1:00|
+2:00
+2,00
+•: D0
+2:00
+4: 00
+1,00
+1:0D
+5:00
+1,00
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DĐ
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+• 0n
+D. DD
+D.DD
+0.0D
+D.DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time Call To
+1812 Jal 04 01:41 PM Inconing
+1613 Jul 04 01:48 IM Inconieg
+1814 Jul 04 03:59 PM M PALE BCH, PL
+1815 Jel 04 02/10 EM Inconing
+1616 Jul 08 02:17 a Incleg
+1617 Jul 08 02:17 IN • PAL BCH, PL
+1818 Jul 04 02118 PM M BALK BCH, PL
+1819 Jul 04 02/18 EM Inconing
+1820 Jul 08 02:21 IN Incoeleg
+1821 Jul 04 02:43 FN Inconleg
+1822 Jul 08 02,50 PM M PALA BCH, PL
+1623 Jul 0e 02:51 w Iscoeleg
+1624 Jul 08 03:09 PM 5 PALK BCH, PL
+1625 Jal 04 03:10 PM M PALE BCH, PL
+1828 Jul 08 03,12 PM M PALA BCH, PL
+18272) Jal ACT,
+1628 Jul 04 03:14 IN BOCA RATON, PL
+1829 Jul 04 03,16 PM BOCA RATON, PL
+130 al c0 03:10 m Inclay
+1631 Jul 0e 03:20 PM S PALK BCH,PL
+1832 Jul 04 03:24 PM M PALE BCH, PL
+1830 Jul 04 03,43 PM M PALA BCH, PL
+1834 J4l 08 04:28 I Inceled
+1630 Jul 0# 04:22 PM M PALA BCH, PL
+1638 Jul 04 04:36 PM Inconleg
+1837 Jul 04 04:38 PM M BALA BCH, PL
+1638 Jul 08 04:40 PM Iscoeleg
+1830 Jul 04 04:55 PM Inconleg
+1840 Jul 04 05,17 PM I PATA BCH.PL
+1541 Jal a 05/26 m Inconleg
+1642 Jel 08 05:38 PM PALE BC,PL
+1843 Jul 08 05:40 PM M PALE BCH, PL
+1844 Jul 09 05:45 PM LAUREL ,MD
+1545 Jl 04 05:4€ IN M PALE BCH, FL
+1848 Jul 08 05:54 PM PALE BCH, PL
+1847 Jal 09
+05:55 PM M BAIR BCH, PL
+1848 J6l 00 06:20 A Incle
+1549 Jul 64 07:18 W Inconer
+1850 Jul 0409:00#M BLAIR/VE,GA
+1851 Jul 04 09,01 IN BLAIREVD, GA
+Number
+561-795-7715
+561-478-4188
+561-662-5747 PP
+561-723-3440 PP
+561-723-1821 PP
+561-723-1821 P9
+561-723-1821 FF
+561-723-1821 PP/C
+561-723-1821 FP
+561-502-3866 FF
+561-722-1873 PP
+561-722-1873 PP
+561-723-1821 V9
+561-793-4189
+561-723-1821
+561-723-1821
+561-929-6414
+561-929-641+
+561-793-4189
+561-842-6414
+561-793-1712
+561-478-4188
+561-541-4051
+561-723-1812
+561-649-3388
+561-649-3388
+561-255-2520
+561-541-5449
+561-723-1812
+561-723-3440
+561-856-7802
+561-662-6616
+240-593-4162
+561-951-1444
+561-827-2542
+561-723-3440
+561-842-2050
+561-541-1153
+706-745-5394
+706-745-5394
+E2TR2S.22a
+8
+Min:Sec
+3,00
+1100
+4:00
+1:00
+1:00
+1:00
+2:00
+1:00
+3:00
+1:00
+2:00
+3:00
+1,00
+1:00
+3:00
+2100
+3:00
+2:00
+3:00
+1:00
+1:00
+1:00
+1:00
+3,00
+1:00
+1:00
+1:00
+10:00
+3:00
+2:00
+1.00
+1: 0a
+1:00
+4:00
+1:00
+2:00
+1:00
+1:00
+Usage
+4.00
+$.00
+4.DD
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+8.00 |
+0.0D
+0.0D
+0.0D
+8.50 |
+• 0[
+0.0D
+•.00
+9,00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+0.00l
+D.DD
+0.00|
+D.D0
+D.DD
+0.00 |
+0,00
+D.D0
+• DO
+• on
+0.00 |
+п nn
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time CallTo
+Number
+Footnote Min: Sec
+1853 Jul 09 06:41 AM Incordng
+561-502-5212
++: 00
+1804 Jul 09 06:47 AM N PALM BCH, PL
+561-719-5032
+1:00
+1655 Jul 09 07:13 AM BOYTONECH, PL
+561-434-4378
+110D
+1656 Jul 09 07:14 AM N PALM BCH ,PL
+561-547-9599
+1,00
+1867 Jul 03 07:16 AM BOCA RATON, PL
+561-728-6414 FP
+1:00
+1858 Jul 09 07:17 AM Incoring
+561-324-1491
+1:00
+1650 Jul 09 $7:50 AM BOCA RATON, PL
+561-305-3272
+3:00
+1680 Jul 090754 AM Incong
+561-541-5449
+1,00
+1601 Jul 09 08:02 AM N FALM BCH, PL
+5E1-158-7914
+1:0D
+1062 Jul 09 08:03 AM Inconing
+S61-541-2153 FP
+1683 Jul 09 09:11 AM W PALM BCH, PL
+561-502-3666 PP
+1,00
+1664 Jul 03 08:13 AM N FACE RCE, PL
+SE1-719-5032 FP
+3: 0D
+1005 Jul 09 08:16 AM N PALM BCH, PL
+561-352-7000 PP
+1608 Jul 08 08:23 AM Inconing
+561-427-2542 FF/CN
+1100
+1887 Jul 09 09.24 AM Incondng
+561-436-4374 PP/CH
+2,00
+1000 Jul 03 08:25 AM NEARCH, PL
+561-358-7914 FD
+2:00
+1808 Jul
+08:30 AM W PALM BCH, PL
+561-541-5449
+1:00
+1870 Jul 09 08.37 AM W PALM BCH.PL
+561-541-5449
+1,00
+561-141-1153
+1672 Jul 09 08:50 AM W PALM BCH, PL
+1673 Jul 09 08:51 AM POMPANORCH, PL
+1874 Jul 09 09.JE AM N PAIM BCH,PL
+561-842-6414
+1:00
+954-341-4078
+561-474-4148
+1,00
+561-152-7000
+1676 Jul 09 09:26 AM Inconing
+1677 Jul 09 09:35 AM N FALK BCH,PL
+1678 Jul 09 09:42 AM Inconing
+1679 Jul 09 69:47 AM W PALM BCH, PL
+1680 Jul 09 10:00 AM Inconing
+561-478-4188
+561-476-4148
+2:00
+561-541-5449 Pe
+561-541-5449
+561-949-4336
+2:00
+2:00
+561-541-5449
+1682 Jul 03 10:05 AM N PALM BCH, PL
+1683 Jul 09 10:06 AM W PALM BCH, PL
+1684 Jul 09 10:33 AM Inconing
+1685.Jul 09 10:42 AM Incondng
+1686 Jul 03 11:38 AM Incoring
+1687 Jul 09 12:05 PM W PALM BCH, PL
+1688 Jul 09 12:20 PM W FACE BCH, PL
+1680 Jul 03 12:24 PM N PALM BCH, PL
+1090 Jul 09 12:34 IN W PALM BCH .PL
+1691 Jul 09 12:36 PM Inconing
+1692J1109
+12:34 EM W PREM BCH,PL
+1693 Jul 03 12:63 PM N PALM RCH ,PL
+561-848-4336
+561-848-4336
+561-306-2673 FP
+561-721-5212
+561-252-4383 FP
+1:00
+9:00
+7,00
+15:0D
+561-541-5449 FP
+561-793-1712
+561-341-3449FP
+561-541-5449
+3:00
+1:0D
+1:00
+561-541-5449
+561-942-6414
+1,00
+2:0D
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+0.00 |
+D.0D
+0.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time Call To
+1804 Jul 09 12:50 PM M BALK BCH, FL
+1690 Jul 09 12:52 PM I DALM BCH, PL
+1606 Jul 09 12:53 PM PALK BCH, PL
+1807 Jul 09 12:55 PM Incoming
+1006 Jul 02 12:5E IN M PALAC BCH, PL
+1699 Jul 09 12:59 IM • PAL BCH, PL
+1700 Jul 09 02:00 IN BALK BCH, PL
+1701 Jal 09 01:03 EM Incoming
+1702 Jul 09 01:01 IN M BALE BCH, PL
+1700 Jul 09 03:14 PM Inconleg
+1704 Jul 09 01,17 PM W PALK BCH, PL
+1706 Jul 03 01:19 W Iscoeleg
+1706 Jul 09 01:24 PM Inconieg
+1707 Jul 09 03:25 EN Incoming
+1708 Jul 09 01,45 PM M PALK BCH, PL
+1700 Jul 03 01:47 WN M PALE BCH, VL.
+1710 Jul 09 01:53 PM I PALA BCH, PL
+1711 Jul 09 01,57 PM M PALA BCH, PL
+1712 лul 03 01:58 IN M PALE BC, PL
+1713 Jul 09 02:01 PM 5 PALK BCH, PL
+1714 Jul 09 02:0E EN Inconing
+1715 Jul 09 02107 IN Inconing
+1716 aul 03 02:21 Inteleg
+1717 Jul 09 02:32 PM M PALE BCH, PL
+1718 Jul 09 02:33 PM M PALE BCH, PL
+1719 Jul 09 02135 PM M BALA BCH, PL
+1720 Jul 09 02:39 PM 5 PALK BCH, PL
+1721 Jal 09 03:26 PM N PALE BCH, PL
+1722 Ja] 09 03118 PM PAL BC,PL
+1723 4) 03 03:19 PM BAI BOT,
+1724 Jul 09 03:21 PM Inconieg
+1725 dal 09 03:22 PM ALCH, PL
+1728 Jul 09 03,39 PM BAI BCH, PL
+1727 26l 03 03:40 0 Inteleg
+Min:Sec
+561-793-1712
+561-795-9549
+561-541-5449 PP
+561-541-5449 PP
+561-793-1712
+561-293-1912
+561-541-5449 FF
+561-541-5449 PP
+561-541-5449 FP
+561-478-0818 FF
+561-723-1821
+561-502-5212 PP/CN
+561-662-6616 PP/CN
+561-502-5212 PP
+561-842-641+
+561-84E-4336
+561-689-3186
+561-583-181÷
+561-E83-1816
+561-478-4188
+561-721-5212
+561-502-5212
+561-502-5212
+561-723-3440
+561-662-6616
+561-793-1712
+561-818-6527
+561-502-5212
+561-478-4188
+1:00
+1100
+1:00
+2:00
+2:00
+1:00
+1:00
+1:00
+4:00
+2:00
+6: 00
+1:00
+1:00
+2:00
+1:00
+1:00
+2:00
+1,00
+2:00
+1:00
+Usage
+4.00
+$.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+8.50 |
+• 0[
+2:00
+3:00
+1:00
+2:00
+0.0D
+•.00
+9,00
+0.0D
+2:00
+561.721-1440|
+1:00
+0.0D
+561-743-1030
+1:00
+561-723-1821
+1:00
+•.00
+561-541-5449
+1:00
+561-541-5449 PP/CN
+4: 00
+0.0D
+561-644-4989 PP
+2:00
+•.00
+1729 Jul 09 03:46 PM Inconing
+561-478-5890
+PP/CN
+3:00
+1730 141 03 03:54 PM M BAI BCH, PL
+561-478-5890
+Tran
+- •r
+1731 Jul 09 04:00 PM Isconieg
+561-478-4188
+1732 Jul 09 04:01 MIlET
+561-352-7000
+1739 Jul 09 04:02 PM Inconleg
+561-478-4188
+1734 Jal 02 04:08 IN M PALE BCH, FL
+2:00
+1:00
+1,00
+1:00
+•.00
+$.00
+Long
+Distance
+D.D0
+D.DD
+D.DD
+D.DD
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.00 |
+п nn
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+Account number 747607414
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time CallTo
+Number
+Footnote
+Min: Sec
+1735 Jul 09 04:34 PM Inconing
+561-541-5449
+2:00
+1736 Jul 09 04:50 IM Inconing
+561-845-4336
+1:00
+1737 Jul 09 04:51 PM Inconing
+561-502-5212
+110D
+1738 Jul 09 04:55 PM Inconing
+561-944-4336 FP
+1,00
+1730 Jul 03 05:01 PM A RAIN RCH, PL
+561-062-EEEE FP
+5:00
+1740 Jul 09 05:06 IM N PALM BCH, PL
+561-662-6616 PP
+1:00
+1741 Jul 09 05:07 PM N FALA BCH, PL
+561-307-1722
+4: 00
+1742 Jul 09 05:11 EM Incondng
+561-123-3440
+1743 0ưl 03 08 68
+5E1-842-2050
+1744 Jul 09 05:50 IN BALTIMORE,MD
+410-334-4961
+2:0D
+1745 Jul 09 06:14 EM W PALM BCH ,PL
+561-644-4949 PP
+1,00
+1746 Jul 09 06:1E W Inconing
+5E1-341-4051
+1:0D
+1747 Jul 09 06:17 IM N PALM BCH, PL
+561-476-7760
+1748 Jul 09 06:27 PM W FALK BCH, PL
+561-365-1305
+19:00
+1749 Jul 09 06:45 PM BALTIMORE,MD
+410-334-4961
+2,00
+1750 Jul 03 06:69 PM N FAL RCH ,PL
+5E1-302-3212
+3: 0D
+1751 Jul
+07:43 IN W PALA BCH ,PL
+561-502-5212
+2:00
+1752 Jul 09 07:44 EM Incondng
+561-502-5212
+1,00
+1753 Jul 03 07:45 IM Inconing
+561-827-2542
+1754 Jul 09
+87:57
+IN W PALM BCH ,PL
+561-827-2542
+1:00
+1755 Jul 09 08:09 PM Inconing
+561-427-2542
+1756 Jul 09 04.42 PM N PAM BCH, PL.|
+561-427-2542
+1757 Jul 03 08:43 PM N PALM BCH, PL
+561-827-2542
+1758 Jul 10 06:27 AM N PALM BCH ,PL
+561-502-5212
+1750 Jul 10 06:54 AM Inconing
+561-442-2050
+1:00
+1760 Jul 10 07:44 AM N PALM BCH, PL
+561-456-7802
+1761 Jul 10 08:50 AM Inconing
+561-827-2542
+1762 Jul 10 10:19 AM N FALM BCH ,PL
+561-427-2542
+1763 Jul 10 10:21 AM Incondng
+561-202-7640
+2:00
+1:00
+1,00
+1764 Jul 10 10:31 AM Inconing
+561-842-1161
+S: 00
+1765 Jul 10 10:93 AM Incoring
+561-502-3666
+Ge /CH
+1:00
+1786 Jul 10 10:55 AM N PALA BCH, PL
+561-427-2542
+1767 Jul 10 11:05 AM N PREM BCH,PL
+561-942-1161
+2,00
+1768 Jul 10 11:09 AM N FAIN RCH, PL
+561-827-2542
+1780 Jul 10 12:04 PM Inconing
+561-723-3440
+1770 Jul 10 01:22 PM Incondng
+561-662-5747
+1771 Jul 10 02:03 PM Inconing
+361-202-7C40|
+1772 Jul 10 62:34 PM Incoring
+561-202-7640
+1773 Jul 10 02:45 #M Inconing
+561-723-3440
+2:00
+1:00
+4: 00
+1774 Jul 10 03:29 PM Incondng
+561-202-7640
+1775 Jul 10 03:36 PM Inconing
+01101-1077
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+0.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+Telecommunications Services Call Detail (561) 662-6688
+See
+Footnote
+Item # Date Time Call To
+1778 Jal 14 03,37 PM Inconing
+1777 Jul 10 03:40 PM Incoming
+1778 Jul 10 03:47 AN Inconleg
+1779 Jal 10 03154 EM Inconing
+1780 Jul 10 D6:41 IN M PALE BCH, FL
+1781 Jul 10 07:57 PM 5 PALA BCH, PL
+1782 Jul 10 08:57 PM Inconing
+1783 Jul 10 09:27 EN Inconing
+1784 Jul 10 08:28 IN Inconleg
+1785 Jul 10 09:30 AN Inconleg
+1788 Jul 10 09,36 PM W PALK BCH, PL
+1787 Jul 10 08:37 IN M BALE BCH, VL.
+1788 Jul 10 09:38 DM 5 PALK BCH, PL
+1780 Jul 10 09:42 EN Incoming
+1790 Jul 10 09,51 I Inconleg
+TOTAL
+Number
+561-793-0077
+561-202-7640
+Min:Sec
+2:00
+Usage
+4.00
+Long
+Distance
+8
+8
+561-842-2050
+561-433-1938 OP
+561-842-2050
+8
+561-856-1194
+561-856-1194
+8
+561-827-2542
+8
+561-827-2542
+8
+561-333-7530 OF
+561-333-7530 0P
+561-333-7530 OF
+561-827-2542
+561-827-2542 OP
+561-856-1194
+8
+2:00
+1:00
+1:00
+1:00
+1:00
+1:00
+2:00
+1:00
+1:00
+1:00
+4.DD
+D.D0
+0.0D
+$.00
+•.5E
+4.00
+D.DD
+0.0D
+D .00
+2:00
+D.DD
+0. 00
+3368: 00
+0.0D
+s0.c0
+Footnote
+Features
+Cal Forwarding
+3W-Three Way Call
+DS-Dialup Service
+Networks
+Services
+NN-National Network
+CN-Canadan Network
+AL: Man/Prematonal Usage
+WW-Nedel Worldwide
+PF-Partial Free
+WD-Waridwide Discount FC-Free Call
+TJ-Tuana Network
+Time Period
+10. Dant Doin
+OP-Off Peak Period
+MP-Muliple Period
+UNIT 5
+(561) 719-9544
+Telecommunications Services Call Detail (561) 719-9544
+See
+Number
+Footnote
+Item # Date Time
+Call To
+1 Jun 12 04:25 PM Inconing
+2 Jun 11 04:27 IN M PALE BCH, FL
+3 Jun 11 05:44 PM M PALE BCH, PL
+* Jun 12 D6114 PM POMPANORCH, PL
+5 Jun 12 09,55 PM M PALE BCH, PL
+§ Jun 11 09:55 IN M BALE BCH, FL
+7 Jun 11 09:57 IM M PALE BCH, PL
+8 Jun 12 09.31 AN Inconing
+• Jun 12 09:57 AM INCoRleg
+10 JuR 12 11:16 AM M PALK BCH, PL
+11 Jun 12 12:52 AN Inconleg
+12 Jun 12 11,5E AN Incoming
+13 Jun 12 12:01 W INCORleg
+14 Jun 12 12:14 PM Ieconieg
+15 Лип 12 02,30 РН Іксовівт
+954-448-2120
+5E1.642-1151
+PP/FU
+PP/PU
+561-644-1121
+PP/PU
+954-942-5959 PP/FU
+561-544-1121
+OP/PU
+561-E44-1121
+De/FU
+561-644-1121
+OP/PU
+561-644-1121
+OP/PU
+561-723-3440 OP/PU
+561-616-8240 OP/PO
+954-448-2120 OP/FU
+772-631-9612
+954448-3120p/80
+754-235-7628
+OP/PU
+561-616-8240
+Min:Sec
+2100
+3.00
+Usage
+Long
+Distance
+3:00
+2:00
+1:00
+0.0D
+0.0b
+$.00
+0.D0
+D.D0
+D.D0 |
+1:00
+2:00
+D.DO
+1:00
+$.00
+1:00
+0.0D
+D.DD
+1:00
+$.00
+1:00
+•.00
+2.00
+$.00
+3,00
+•.00
+0.D0
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+Total
+Charges
+a.ca
+9.00
+g.00
+9.00
+g.c0
+9.00
+9,00
+Account number 747607414
+Telecommunications Services Call Detail (561) 719-9544
+See
+Item # Date Time CallTo
+16 Jun 12 02:53 PM Inconing
+17 Jun 12 02:53 IM N PALM BCH, PL
+18 Jun 12 02:59 PM N FAEM BCH ,PL
+19 Jun 12 03:00 PM Inconing
+20 Jun 15 07:38 AM N RAIN RCH, PL
+21 Jun 15 11:09 AM N PALM BCH, PL
+Jun 15 12:45 PM POMPANCECH, PL
+Jun 15 OL:34 EM Inconing
+Jun 15 03:21 IN POMPANECH PL
+25 Jun 15 03:24 PM POMPANORCH, PL
+28 Jun 15 03:35 PM POMPANCBCH, PL
+Jun 15 04:5€ I POMPANDACH, PL
+28 Jun 16 04:07 IM POMPANCECH ,PL
+29 Jun 19 10:5€ IM Inconing
+Jun 20 09:01 AM W FACE BCH,PL
+31 Jun 21 07:08 AM N FALK RCH ,PL
+Jun 21 05:39 IM POMPANCECH ,PL
+Jun 2209,35 AM POMPANOBCH, PL
+Jun 22 11:20 AM Incondag
+R
+Jun 22 11:21 AM POMPANOBCH, PL
+38 Jun 22 12:59 PM POMPANORCH ,PL
+Jun 22 01.01 PM POMPANORCH PL.
+38 Jun 22 02:42 PM POMPANCACH, PL
+39 Jun 24 09:40 AM Inconing
+Jun 24 04:30 PM Inconing
+41 Jun 25 07:06 AM N PALM BCH,PL
+42 Jun 25 04:54 IM POMPANCECH, PL
+Jun 26 02:05 PM Inconing
+Jun 26 02:20 EM PALM BCH,PL
+Jun 26 03:32 PM Inconlag
+Jun 26 03:56 IM Inconing
+47 Jun 26 04:36 IN PLAUDERDG, PL
+Jun 28 09:12 AM POMPANOBCH ,PL
+49 Jun 28 09:17 AM ROCHESTER, MN
+50 Jun 28 07:21 IN PALACH.PL
+Jun 29 04:23 PM Incondug
+Jun 23 08:25 PM Incondog
+Jun 29 08:33 IN Incoring
+Jun 30 00:37 PM POMPANCECH,PL
+Number
+Footnote Min: Sec
+561-616-9240
+Ge /FU
+1,00
+561-616-8240
+0P/PU
+3:00
+561-616-4240 CP/FU
+561-616-4240 0P/PU
+1100
+3:00
+561-683-8511 FF/FU
+561-848-4345
+1:00
+954-942-5959
+1:00
+561-502-7753
+FP /PU
+354-342-5959
+1:0D
+954-942-5959
+FE /FU
+954-342-5959 PP/PU
+254-342-5959 FF/FU
+954-942-5959 PD/PU
+561-644-3121 CE/FU
+561-644-1121
+ce /pU
+5E1-719-9544 FD/FU
+954-942-5959
+PD /PU
+1,00
+1:0D
+2:00
+2:00
+1100
+1:0D
+2:00
+954-342-5959 PP/PU
+254-448-2120 FD/FU
+1:0D
+954-942-5959 PD/PU
+954-342-5959 FF/FU
+954-342-5959 PP/PU
+254-342-5952 FF/FU
+856-467-4775 PD/PU
+2,00
+2:0D
+1:00
+561-371-5257 FF/PU
+561-364-5511 PP/PU
+954-942-5959 PD/PU
+2:00
+561-502-5212
+561-502-5212
+561-102-1751 OF/FU
+1,00
+1: 00
+954-448-2120 0B/PU
+954-444-2120 CE/PU
+754-235-8617 PP/PU
+2:00
+3:00
+2:00
+50T-288-4959 FF/FU
+561-719-9544 FF/FU
+754-235-7624 PP/PU
+1,00
+754-215-7624 FD/FU
+754-235-7628 PD/PU
+1:00
+954-942-5959 FP/FU
+954-942-5959
+PP/PU
+08:03 PM Incordaa
+2:0D
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+D.DD
+Charges
+D.0D
+0,00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+UNIT 5
+(561) 719-9544 continued...
+Telecommunications Services Call Detail (561) 719-9544
+See
+Footnote
+Item # Date Time Call To
+57 Jal 01 10:23 AM STUART, PL
+58 Jul 01 10:34 AM Incoming
+50 Jul 01 12:29 AN M PALK BCH, PL
+00 Jul 01 11,35 A M BALK BCH, FL
+01 al 01 12:09 # Incoeleg
+62 Jul 01 12:33 IM M PALA BCH, PL
+83 Jul 01 12:35 PM IncOmiNg
+84 Jul 01 05,03 PM POMPANCBCH, PL
+05 Jul 01 05:14 IN POMPANORCH, PL
+68 Jul 01 05126 PM POMPANORCH, PL
+87 Jul 02 02152 PM POMPANCECH, PL
+68 Jul 02 07:37 IN POMPANOECT, IL.
+69 Jul 02 09:36 PM POMPANCBCH, PL
+70 Jul 03 02:09 PM POMPANDECH, PL
+71 Jul 06 10:35 AM POMPANECH, FL
+72 JAl O6 DE:20 IN POMPANOECT, PL
+73 Jul 07 07:57 PM POMPANCBCH, PL
+74 Jul 07 08,12 PM POMPANORCH, PL
+75 Jal 07 D8:23 IN POMPANECH, PL
+76 Jul 07 08:35 PM POMPANCH, PL
+TOTAL
+Number
+772-631-9612
+PP/FU
+772-631-9612
+561-722-3311 PP/FU
+561-722-3311 PP/FU
+561-722-3311 PP/FU
+561-722-3311
+561-722-3311 PP/FU
+954-942-5959 PP/FU
+954-942-5959
+PP/FU
+954-942-5959 PP/FU
+954-942-5959 PP/PU
+954-942-5959 PP/SU
+954-942-5959 OP/PU
+954-015-595g 0p/80
+Min:Sec
+2:00
+3:00
+2:00
+1:00
+1:00
+1:00
+1:00
+1:00
+2:00
+1:00
+3:00
+1:00
+1:00
+954-942-5959 PP/PU
+954-346-4833
+PP/FU
+954-942-5959
+954-942-5959 PP/PU
+954-342-5959
+PP/FU
+954-942-5959
+1:00
+1:00
+1,00
+4: 00
+1:00
+123,00
+Footnote
+Features
+CWCall Waiting
+CF-Call Forwarding
+3M4-Three Way Call
+DS-Dialup Service
+Networks
+NN Mational Maharele
+Services
+PF-Partial Free
+WD-Worldwide Discount FC-Free Call
+TJ-Tiuana Network
+(561) 723-1821
+Telecommunications Services Call Detail (561) 723-1821
+See
+Footnote
+Item # Date Time Call To
+1 Jun 11 07:11 AN M BADAS BC, FL
+2 Jun 11 07:12 AM M PALE BCH, PL
+3 Jun 12 07,15 AN N PALE BCH, PL
+1 Jun 11 DE: 0 InCl
+5 Jun 11 08:11 2M M PALA BCH, PL
+8 Jun 12 08,55 AN JUPITER, FL
+7 Jun 11 09,05 AN I PALA BOH, FL
+§ Jun 11 10:18 AM INCORleg
+9 JuR 11 10:40 AM IncoRLey
+10 Jun 13 10142 AN ROCA RATON, PL
+Number
+561-719-3077
+561-478-4822
+561-719-1077
+Min: Sec
+561-478-4188 PF
+561-586-1648 PP
+561-747-2467 PP
+561-662-6688 PP
+561-202-8497 PP
+561-477-7880 PP
+1:00
+2:00
+3:00
+1:00
+3:00
+1:00
+3:00
+1:00
+2.00
+5,00
+Usage
+4.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+8.00 |
+0.0D
+0.0D
+0.0D
+$0.00|
+Usage
+0.0D
+$.00
+0.0D
+$.00
+0.0D
+$.00
+•.00
+$.00
+•.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+D.DD
+0.00|
+D.D0
+$4.60
+Time Period
+pP-Peak Period
+OP-Off Peak Period
+MP-Muliple Period
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+Long
+Distance
+D.DO
+D.DD
+0.D0
+corticued.
+Total
+Charges
+g.00
+9.00
+g.c0
+9.00
+9,00
+Account number 747607414
+(561) 723-1821 continued...
+Telecommunications Services Call Detail (561) 723-1821
+See
+Item # Date Time CallTo
+Number
+Footnote Min: Sec
+11 Jun 11 10:44 AM N PALM BC, PL
+561-723-1421
+2:00
+12 Jun 11 11:29 AM N PALM BCH, PL
+561-352-7000
+1:00
+13 Jun 11 11:53 AM N FAEM BCH, PL
+561-662-6648
+3: 0D
+14 Jun 11 12:08 PM N PALM BCH ,PL
+561-662-6648
+1,00
+15 Jun 11 12:35 PM BOCA RATON, PL
+561-445-5981
+1:00
+16 Jun 11 12:43 IM N PALM BCH, PL
+561-714-3077
+17 Jun 11 01:02 PM W FALM BCH, PL
+561-662-6C48
+3:00
+18 Jun 11 01:17 EM Incondng
+561-613-2400
+19 Jun 11 01:50 #M Inconing
+5E1-315-0145
+1:0D
+20 Jun 11 02:21 PM Inconing
+SE1-662-6C48
+21 Jun 11 02:40 EM W PALA BCH ,PL
+561-662-6648 PP
+1,00
+Jun 11 02:41 PM Inconing
+SE1L-6E2-EEBE FD
+2:00
+23 Jun 11 02:46 IM W PALM BCH,PL
+561-662-6688 P0
+6:00
+24 Jun 11 02:55 PM W FALK BCH, PL
+561-352-7000
+2:00
+Jun 11 02:56 EM W FALM BCH,PL
+561-662-6688
+1,00
+Jun 11 03:03 PM Inconleg
+unava llable
+2:00
+Jun
+11 03:19 IM N PALM BCH ,PL
+561-662-6688
+Jun 11 05:44 EM Incondng
+561-474-4148
+2,00
+Jun 12 03:02 IN N PALM BCH, PL
+561-123-1821
+Jun 12 03:03 IM W PALM BCH, PL
+561-662-6688
+31 Jun 14 06:59 AM Inconing
+561-764-5511
+32 Jun 14 07,37 AM N PALM BCH, ,Pl.|
+561-662-6648
+33 Jun 14 07:43 AM N PAL RCH, PL
+561-062-ECEE
+34 Jun 14 07:46 AM W PALM BCH,PL
+561-662-6688
+R
+Jun 14 09:05 AM BOCA RATON, PL
+561-477-7660
+1:00
+1:00
+38 Jun 14 09.05 AM BOCA RATON,PL
+561-445-5991
+37 Jun 14 69:06 AM BOCA RATON, PL
+561-445-5981
+Jun 14 09:11 AM Incoring
+561-577-6425
+30 Jun 14 09,35 AM W PALM BCH,PL
+561-964-5511
+5:00
+3: 00
+6,00
+Jun 1408:20 AM BOTTONICH, IL
+561-103-1930
+41 Jun 14 09:21 AM BOYTONBCH, PL
+561-573-6425
+1:00
+42 Jun 14 09:29 AM Inconing
+561-503-5936
+43 Jun 14 09:46 AM BOCA RATON, PL
+561-305-1272
+1,00
+44 Jun 14 09:68 AM N FALM RCH, PL
+561-121-1821
+:
+45 Jun 14 09:51 AM JUPITER,PL
+561-427-0478
+4฿ Jun 14 10:44 AM JUPITER, FL
+561-427-0470
+47 Jun 14 11:06 AM N RAIN ACH, PL
+561-625-E955
+48 Jun 14 11:26 AM Incoring
+561-202-8497
+3:0D
+2:00
+49 Jun 14 11:27 AM Inconing
+561-302-8497
+50 Jun 14 11,24 AM DELAY BCH,PL
+561-306-3016
+51 Jun 14 11:37 AM N PALM RCH, PL
+BIISELTDEE
+2:0D
+Usage
+6.08
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+0.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+
+
+
+(561) 723-1821 continued..
+Telecommunications Services Call Detail (561) 723-1821
+See
+Number
+Footnote
+Item # Date Time Call To
+52 Jun 1+ 11:40 AM W PALK BCH, FL
+53 Jun 14 11:44 AM JUPITER, PL
+54 Jun 14 12,58 AN Inconleg
+55 Jun 14 12:04 PM M BALK BCH, FL
+50 Jun 14 12:12 IN M PALAC BCH, FL
+57 Jun 14 12:38 PM Incoeieg
+58 Jun 14 02:06 PM M PALK BCH, PL
+50 Jun 14 01,09 IN W BALK BCH, PL
+60 Jun 14 01:16 PM BALAE BCH, FL.
+61 Jun 14 02,29 PM M PALK BCH, PL
+82 Jun 14 02152 EM Inconing
+83 лил. 14 03:00 М 1002/270000, Г.
+54 Jun 14 03:01 PM BOCA RATON, PL
+65 Jun 14 04:21 IN Inconleg
+88 Jun 14 05124 EN Inconing
+57 JuN 14 05:43 PM BALE BOT,PL
+68 Jun 15 07:45 AM BOYTONECH, PL.
+80 Jun 15 07,46 AN U PALA BCH, PL
+70 Jun 15 07:51 AN M PALE BCH, VL
+71 Jun 15 08:14 AM N PALA BCH, PL
+72 Jun 15 08:16 AN N PALE BCH, PL
+73 Jun 15 08,28 AM BOCA RATON, PL.
+74 JuN 15 D8:31 AN BOCA RATO, PL
+75 Jut 15 08:32 AM BOCA RATON, PL
+76 Jun 15 08:37 АМ ВОСА RATON, PL.
+77 Jun 15 08:46 AM Inconleg
+78 Лив 15 09:59 АМ Інсонівт
+79 Jun 15 10:01 AM Incoming
+80 Jun 15 10/06 AM N PALA BCH, PL
+81 Jun 15 10:13 J8 M FALL BCT, FL
+82 Jun 15 10:47 AM INcoRleT
+83 Jun 15 12:00 AM NAALE BCH, PL
+84 Jun 15 12,07 AM MBAL BCH,PL
+B5 Ju 15 11:17 AN 1 PALE BCH, VL
+08 Jun 15 02:49 MIleT
+Jun 15 02112 PM M BALE BCH,PL
+BB Jun 15 02:18 PM I BAI BCH, PL
+B9 Jun 15 02:32 PM M PALA BCH, PL
+00 Jun 15 03:30 IN INCORLET
+91 Jun 15 04:16 PM Inconing
+561-662-6688
+561-427-0490
+561-662-6688 PP
+561-662-6688 PP
+561-662-6GE8 PP
+561-665-66RA
+561-842-6434 FF
+561-662-6688 PP
+561-478-4168 FP
+561-662-6CE8 FF
+561-202-8497
+561-061-6511
+561-662-6688
+561-723-1821
+561-503-5930
+561-964-5511
+561-364-5511
+561-723-1821
+561-820-4659
+561-393-791÷
+561-393-7914
+561-393-7930
+561-391-0611
+847-623-3253 PP
+561-427-0470
+561-478-4168
+561-964-5511
+561-478-4188
+561-202-8497
+561-478-4168
+561-662-66R8
+561-723-1821
+561-503-5930
+561-723-1821
+561-707-9911
+561-478-4188
+561-478-4188
+PP/NN
+Min:Sec
+4:00
+4:00
+2:00
+3:00
+1:00
+4:00
+3:00
+1:00
+7.00
+1:00
+1:00
+1:00
+9.00
+2:00
+1:00
+1.00
+1:00
+3:00
+3:00
+1:00
+1:00
+5:00
+1:00
+8:00
+2:00
+2:00
+2:00
+1:00
+1:00
+3:00
+1:00
+J:0a
+2:00
+2100
+1:00
+3:00
+4:00
+1:00
+S:00
+Usage
+4.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+8.00 |
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+0.D0|
+п nn
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+Account number 747607414
+(561) 723-1821 continued...
+Telecommunications Services Call Detail (561) 723-1821
+See
+Item # Date Time CallTo
+Number
+Footnote Min: Sec
+93 Jun 16 09:26 AM N PALM BCH, PL
+561-662-6698
+3:00
+94 Jun 16 09:29 AM N PALM BCH, PL
+561-585-8010
+2:00
+85 Jun 16 09:54 AM I FALK BCH ,PL
+561-401-3297
+3: 0D
+Se Jun 16 10:04 AM I PALM BCH, PL
+561-422-5294
+1,00
+97 Jun 16 10:12 AM Inconing
+561-062-6EEE FF
+1:00
+98 Jun 16 10:19 AM N PALM BCH, PL
+561-625-6955
+2, 06
+99 Jun 16 10:40 AM Inconing
+561-662-6C48
+1:00
+100 Jun 16 10:41 AM Toll Free
+800-730-7201
+2100
+101 Jun 16 10:43 AM PILAUDERDE, PL
+954-444-2146
+1:0D
+102 Jun 16 10:46 AM Inconing
+561-573-6425
+3:0D
+103 Jun 16 11:31 AM W PALM BCH,PL
+561-422-8262
+9,00
+104 Jun 1E 11:40 AM N FALA BCH, PL
+SE1-EE2-EEBE FD
+2:00
+105 Jun 16 11:42 AM BOCA RATON, PL
+561-391-0611
+106 Jun 16 11:43 AM N FALM BCH ,PL
+561-478-4168
+107 Jun 16 11,46 AM N PALM BCH ,PL
+561-662-6688
+3,00
+108 Jun 16 11:55 AM N FALM RCH, PL
+561-820-4221
+1:0D
+Jun 16 12:05 IM BOYTONBCH, PL
+561-577-6425
+110 Jun 16 12:05 PM BOYTONBCH, PL
+561-577-5425
+111 Jun 16 12:17 IN N PALM BCH, PL
+561-478-418E
+Jun 16 12:19 IM BOCA RATON, PL
+561-305-1272
+113 Jun 16 12:23 PM N PALM RCH, PL
+561-662-6688
+5,00
+2:00
+2:00
+4:00
+114 Jun 16 12:32 EM W PALM BCH,PL
+561-474-4148
+115 Jun 16 12:37 # Inconag
+561-062-ECEE
+116 Jun 16 12:41 IM N PALM BCH ,PL
+561-719-3077
+117 Jun 16 12:43 IN N PALM BCH, PL
+561-716-4222
+118 Jun 16 12:45 PM N PALM BCH,PL
+561-478-4198
+119 Jun 16 12:48 IM N PALM BCH ,PL
+561-476-4188
+Jun 16 12:53 PM Inconing
+561-613-2400
+1:00
+2:00
+3:00
+4:00
+$:00
+Jun 16 0L.01 EM N PALM BCH,PL
+561-662-5698
+1,00
+16 01:03 IM N PALA BCH, PL
+561-662-ECEE
+Jun 16 01:09 IM Incoring
+561-202-8497
+1:00
+124 Jun 16 01:35 PM N PALA BCH, PL
+561-723-1421
+Jun 16 01:26 EM Incondng
+561-306-2673
+3,00
+Jun 1E 01:37 PM Inconing
+561-478-4188
+:
+Jun 16 01:44 PM W PALM BCH, PL
+561-791-2143
+1:00
+178
+Jun
+16 02:07 PM W PALM BCH ,PL.
+561-662-6648
+129 Jun 16 02:12 PM Inconlog
+561-107-9911
+130
+Jun 16 02:33 IM Incoring
+561-662-6688
+1:0D
+2:00
+131 Jun 16 02:35 PM Inconing
+561-503-5938
+Jun 16 02137 EM W PACM BCH,PL
+561-662-6648
+133
+02:40 PM Incorina
+$: 0D
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.DD
+D. DD
+D.DD
+D.DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+
+
+
+(561) 723-1821 continued..
+Telecommunications Services Call Detail (561) 723-1821
+See
+Number
+Footnote
+Item # Date Time Call To
+134 Jun 16 02148 PM Inconing
+135 Jun 16 03:02 IN M PALA BCH, PL
+136 Jun 16 03103 PN BOCA RATON, PL
+137 Jun 16 03:07 PM M BALK BCH, FL
+135 JuL 1E 03:0E IN M PALE BCH, FL
+139 Jun 16 03:10 PM • PALK BCH, PL
+140 Jun 16 03:27 IN INCOmINg
+141 Jun 16 03,39 PM M BALK BCH, FL
+142 JuL 16 D3:4E IN BOCA RATON, FL
+143 Jun 16 04:03 PM Isoleg)
+144 Jun 16 04:26 EN Inconing
+145 JuR 17 07:31 AM DELANE BCH, PL
+145 Jun 17 07:38 AM M PALE BCH, PL
+147 Jun 17 07:56 AN M BALE BCH, PL
+148 Jun 17 07,57 AN ITASCA, IL
+149 Jun 17 D7:5E AN M PALE BCH, FL
+150 Jun. 17 08:14 AM PLAUDERDL, PL
+151 Jun 17 D8,56 AN M PALA BCH, FL.
+152 лш 17
+D8:0D AN DELANE BOSE, FL
+153 Jun 17
+09:02 3M 5 DALK BCH, PL
+154 Jun 17 09:53 AM M PALE BCH, PL
+155 Jun 17 10/16 AM Incoming
+156 Ju 17 10:53 AN M PALE BCH , FL
+157 Jut 17 11:04 AM Inconiet
+158 Jun 17 12:08 /M Inconing
+150 Jun 17 11/11 AM M BAL BCH, FL
+160 Jun 17 11:12 AN Inconieg
+181 Jun 17 12:18 2N M BALE BCH, PL
+162 Jun 17 12,55 AM M BALA BCH, FL
+183 Ju 17 11:57 AN M PALE BCH, FL
+154 Jun 17 12:20 PM Inconiet
+165 Jun 17 12:28 PM M BALE BCH, FL
+160 Jun 17 12:30 PM BOCA RATON, FL
+167 Jun 17 12:37 IN Inceled
+168 Jun 17 12:50 PM PALE BCH, PL
+180 Jun 17 12:53 IN FTLAUDERDL, FL
+171 Jun 17 01:02 PM Inconier
+172 Jum 17 03:14 М Інопіт
+173 Jun 17 01/19 EM Inconleg
+174 Jun 17 01:27 # Inconley
+561-202-8497
+561-24R-4980
+561-305-1272
+561-233-5180 PP
+561-233-5170
+561-615-3213 09
+561-615-3213 FF
+561-379-8816 PP
+561-445-5961 FP
+561-248-4980 FF
+561-791-2182 PP
+561-441-8028 PP
+561-723-1821 V9
+561-718-0878
+630-775-3320
+561-723-1821
+954-444-2146
+561-662-6688
+561-441-8028
+561-723-1821
+561-723-1821
+561-421-2000
+561-366-760D
+561-202-8497
+561-202-8497
+561-723-1821
+561-202-8497
+561-179-8816
+561-109-8106
+561-723-1821
+561-309-8106
+561-723-1821
+561-479-3337
+561-577-6425
+561-716-4222
+954-444-4809
+561-718-4222
+561-358-8864
+561-662-6688
+561-662-6688
+
+Min:Sec
+1,00
+1:00
+3:00
+1:00
+2:00
+1:00
+2:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+2:00
+2:00
+1:00
+2:00
+1.00
+2:00
+1:00
+2:00
+1:00
+2:00
+1:00
+1:00
+2:00
+2:00
+5100
+1: 0a
+1:00
+1:00
+2:00
+3:00
+4:00
+Tonn
+Usage
+4.00
+• DE
+0.0D
+$.00
+$.00
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+$.00
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.DD
+D.DD
+D.DD
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+0.D0|
+п nn
+corticued.
+Total
+Charges
+9.00
+9.00
+a.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+(561) 723-1821 continued..
+Telecommunications Services Call Detail (561) 723-1821
+See
+Item # Date Time CallTo
+Number
+Footnote Min: Sec
+175 Jun 17 01:57 PM Incordng
+561-966-7603
+3:00
+176 Jun 17 02:13 IM Inconing
+561-842-5414
+=
+3:00
+177 Jun 17 00:34 PM Inconing
+561-420-3549 FP
+11:00
+178 Jun 17 03:02 EM Incoring
+561-202-4497
+1,00
+179 Jun 17 03:11 PM Inconleg
+E30-8D3-SESE FP
+2:00
+180 Jun 17 03:27 IM N PALM BCH, PL
+561-723-1621 P0
+2:00
+181 Jun 17 S4:12 PM Inconing
+561-202-8497
+2:00
+182 Jun 17 04:14 PM CLEARNATER, PL.|
+727-634-7146
+3,00
+183 Jun 17 O4:46 IM Incoelng
+5E1-202-8497
+2:00
+184 Jun 17 05:35 PM Inconing
+SE1-478-56PD
+5:00
+185 Jun 18 07:34 AM BOXTONBCH, PL
+561-503-5930
+2,00
+188 Jun 18 O7:44 AM Incoelng
+5E1-624-0701
+4: 0D
+187 Jun 18 C8:35 AM Inconing
+561-503-5930
+1:00
+188 Jun 18 04:49 AM Inconing
+561-503-5930
+1100
+189 Jun 18 09:20 AM PILAUDERDG, PL
+954-444-2150
+1,00
+Jun 1a 09:11 AM Incoring
+254-444-2150
+2:00
+Jun 18 09:52 AM W PALM BCH, PL
+561-478-2025
+1:00|
+Jun 18 09:54 AM W PALM BCH, PL.
+561-719-1531
+5,00
+Jun 1a 10:30 AM BOZINCH, PL
+561-9TT-6425
+2: 0D
+Jun 18 10:45 AM Inconing
+561-304-2724
+2:00
+195 Jun 18 11:02 AM W FALK BCH, PL
+561-420-4659
+4:00
+190 Jun 19 11:17 AM W PALM BCH,PL
+561-420-4659
+$100
+197 Jun 18 11:32 AM Incondag
+561-30E-7603
+198 Jun 18 11:44 AM W PALM BCH,PL
+561-662-6688
+Jun 18 12:04 PM N PALM BCH, PL
+561-582-4363
+200 Jun 18 12:40 PM N PALM BCH,PL
+561-662-6688
+201 Jun 18 01:01 IM Inconing
+561-820-3549
+Jun 18 01:05 PM Inconing
+561-577-6425
+1:00
+3:00
+4:00
+$:00
+Jun 18 0L:16 EM Incondng
+561-577-5425
+204
+18 01:43 IN N PAIN BCH, PL
+561-662-ECEE
+Jun 18 02:17 PM Incoring
+561-478-4168
+1:00
+200 Jun 18 00:21 IN N PALM BCH,PL
+561-471-4148
+207 Jun 18 02:21 EM W PALM BCH,PL
+S61-474-4148
+6:00
+208 Jun 18 02:27 IN BOCA RATON, PL
+561-105-1272
+Jun 18 00:31 PM W PALM BCH, PL
+561-476-4148
+210 Jun 18 03:04 PM W FALM BCH, PL
+561-379-4816
+211 Jun 18 03:33 PM Inconlog
+3E1-CE2-CCEE
+Jun 1a 03:36 IM Incoring
+561-478-4188
+1:00
+2:00
+2:00
+2:00
+213
+Jun 18 03:34 PM JUPITER, PL
+561-747-2467
+214 Jun 18 03,39 EMPALM BCH.PL
+561-662-6648
+1,00
+215
+18 00:41 PM Incorlea
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+• 0n
+D. DD
+D.DD
+0.0D
+D.DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+
+
+
+(561) 723-1821 continued..
+Telecommunications Services Call Detail (561) 723-1821
+See
+Number
+Footnote
+Item # Date Time Call To
+216 Jun 19 09:25 3M Inconing
+217 Jun 19 10:50 AM Inconieg
+218 Jun 21 D8:19 AN Inconleg
+219 Jun 21 08129 3M M BALK BCH, FL
+220 Jun. 21 D8:52 AM M PALE BCH, FL
+221 Jun. 21 08:57 AM M PALA BCH, PL
+222 Jun 21 09:19 AN M BALK BCH, PL
+223 Jun 21 09,39 3M M BALK BCH, FL
+224 Jut 21 08:42 JC M BALE BCH, VL
+225 Jun 21 09:44 AM M BALE BCH, PL
+228 Jun 21 09,45 AM N PALK BCH, PL
+227 Ju 21 08:47 AN BOTTONRCH, FL.
+228 Jun. 21 09:50 AM Inconley
+229 Jun 21 10:00 AN Inconleg
+230 Jun 21 10,01 AN FTLAUDERDL, PL
+231 Jul 21 10:16 AN M PALE BCH, FL
+232 Jun. 21 11:03 AM M PALA BCH, PL
+233 Jun 21 11,04 AM N PALA BCH, PL
+234 Jun 21 11:05 J Iscoeleg
+235 Jun 21 11:05 JM Ieconieg
+235 Jun 21 12:06 AM M PALE BCH, PL
+237 Jun 21 11,08 AM M PAIN BCH, PL
+238 Jun 21 11:47 AM INCORLeT
+239 Jun 21 12:11 PM Inconiet
+240 Jun 22 12:26 PM M PALE BCH, PL
+241 Jun 21 12:17 PM M BALA BCH, PL
+242 Jun 21 12:19 PM M PALE BCH, PL
+243 Jun 21 12:41 PM Inconleg
+244 Jun 21 01,04 PM M PATA RCH, PL
+245 Jun 21 02:25 mN Incoeleg
+Jun 21 03:18 PM Inccelet
+247 Jun 22 03:21 PM DELANE BCH, PL
+245 Jun 21 03142 PM Inconleg
+240 JuN 21 03:48 IN INCORLET
+250 Jum 22 03:50 PM PALE BCH, PL
+251 Jun 21 03,53 PM M BALA BCH, PL
+252 Jun 21 04:01 m Inconleg
+253 JuR 21 05:19 PM PALE BCH, PL
+254 Jun 21 05:24 IN ARE BON, PL
+255 Jun 21 05:25 PM BALA BCH, FL
+250J 2105:27 FA FL
+561-202-8497
+561-503-5930
+8
+8
+561-624-0701
+561-624-0701 PP
+561-791-8271 PP
+561-820-4659
+561-585-8010 FF
+561-723-1821
+561-793-4372
+561-722-4609 FF
+561-844-5202
+561-436-0767 PP
+561-722-4609 PP/CN
+561-202-8497 PP
+954-931-7085
+561-793-4372
+561-478-4188
+561-352-7000
+561-352-7000
+561-352-7000
+561-723-1821
+561-964-5511
+561-202-8497
+561-202-8497
+561-433-2500
+561-791-4482
+561-801-3297
+561-533-0604
+561-662-6688
+561-436-4378
+561-809-4224
+561-809-4224
+561-718-4005
+561-718-4222
+561-662-6688
+561-718-4222
+561-296-3090
+561-723-1821
+561-642-7750
+561-662-6688
+561-E42-7750
+Min:Sec
+1,00
+11:00
+1:00
+2:00
+5:00
+4:00
+2:00
+1:00
+1:00
+2:00
+4:00
+2:00
+9.00
+4: 00
+1:00
+1.00
+1:00
+1:00
+2:00
+2100
+1:00
+2:00
+2:00
+3:00
+5:00
+4:00
+11:00
+3:00
+2:00
+2:00
+2:00
+1:00
+2:00
+3:00
+1:00
+Usage
+4.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.00 |
+п nn
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+(561) 723-1821 continued...
+Telecommunications Services Call Detail (561) 723-1821
+See
+Item # Date Time CallTo
+Number
+Footnote Min: Sec
+257 Jun 21 05:54 EM N PALM BCH, PL
+561-723-1421
+3:00
+25d Jun 22 07:47 AM Inconing
+561-909-4224
+1:00
+250 Jun 22 09:26 AM W FALK RCH,PL
+561-602-2291 FP
+2: 00
+280 Jun 22 04:44 AM W PALM BCH ,PL
+561-714-4222
+281 Jun 22 09:06 AM N RADA BCH, PL
+561-642-7750
+5:00
+202 Jun 22 09:11 AM N PALM BCH, PL
+561-716-4222
+2:00
+283 Jun 22 09:13 AM N FALK BCH, PL
+561-662-6C48
+3:00
+284 Jun 22 09:21 AM Incondng
+561-202-4497
+2100
+285 Jun 22 09:23 AM N BALA BCH, PL
+5E1-E49-0623
+4:00
+250 Jun 22 09:39 AM N FALK BCH, PL.
+561-420-4659 PP
+287 Jun 22 09:61 AM N PALM BCH,PL
+561-366-7600
+1,00
+288 Jun 22 09:47 AM N FALE BCH, PL
+5E1-E42-7750
+2:00
+209 Jun 22 09:56 AM N PALM BCH, PL
+561-585-8010
+2:00
+270 Jun 22 10:06 AM Inconing
+561-202-8497
+1100
+271 Jun 22 10:49 AM W PALM BCH, PL
+561-420-4659
+2,00
+272
+Jun 22 11:04 AM Incondng
+5E1-6E2-ECEE
+4: 00
+277
+Jun
+11:09 AM Incoming
+561-420-3549
+3:00
+274
+22 11.12 AM W PALM BCH, PL
+561-714-4222
+1,00
+275
+Jun
+22 11:13 AM N PALM BCH, PL
+561-718-4222
+276
+22 11:14 AM N PALM BCH, PL
+561-686-2555
+1:00
+277 Jun 22 11:15 AM N PALM BCH,PL
+561-688-2555
+278 Jun 22 I1.16 AM N PALM BCH, ,PI.|
+561-688-2555
+279 Jun 22 11:18 AM N PALM RCH, PL
+561-718-4005
+280 Jun 22 11:19 AM Incoring
+561-718-4222
+281 Jun 22 11:21 AM N FALA BCH, PL
+561-662-6648
+1:00
+2:00
+282 Jun 22 11:22 AM N PALM BCH,PL
+561-718-4222
+283 Jun 22 11:23 AM N PALM BCH,PL
+561-662-6668
+1:00
+Jun 22
+11:26 AM W FALK BCH ,PL
+561-352-7000
+285
+Jun
+11:46 AM Incondng
+561-474-4148
+2,00
+286
+01:14 IN N PALA RCH, PL
+561-121-1821
+287
+Jun
+22 01:14 IM W PALM BCH, PL
+561-662-6668
+288 Jun 22 01:24 PM N PALM BCH,PL
+561-420-4228
+7:00
+2:00
+Jun
+22 01,26 PM N PALM BCH,PL
+561-920-4161
+290 Jun 22 01:27 PM N FALA RCH, PL
+561-820-4E59
+:
+291 Jun
+22 01:24 PM N PALM BCH, PL
+561-662-6C4
+2:00
+202
+Jun
+01:29 PM W PALM BCH,PL
+561-642-7750
+Jun 22 02:44 IM Incondog
+361-CE2-CCEE
+Jun 22 01:51 IN W PALM BCH .PL
+561-688-2555
+1:0D
+2:00
+Jun 22 01:54 PM N PALM BCH, PL
+561-662-6648
+Jun 22
+0L.55 PM Incordng
+561-420-3549
+PP/CN
+1,00
+297
+0L:57 PM N FALM BCH .PL
+Usage
+6.08
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+• 0n
+D. DD
+D.DD
+0.0D
+D.DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+
+
+
+(561) 723-1821 continued..
+Telecommunications Services Call Detail (561) 723-1821
+See
+Number
+Footnote
+Item # Date Time Call To
+208 Jun 22 02107 PM M BALK BCH, FL
+299 Jun 22 02:09 PM I DALM BCH, PL
+300 Jun 22 02117 IN Inconleg
+301 Jun 22 02/19 PM M BALK BCH, FL
+302 лил 22 02:20 И м виДк вст, FL.
+303 Jun. 22 02:23 IN M PALA BCH, PL
+304 Jun 22 02:24 PM M BALK BCH, PL
+305 Jun 22 03147 EM Inconing
+305 Jl 23 07:41 J M BALE BCH , VL
+307 Jun 23 07,44 AN BOCA RATON, PL
+308 Jun 23 08,07 AN Inconleg
+309 Jun 23 D8:35 AN I FALK BCH, FL.
+310 Jun. 23 08:40 AM Isconieg
+311 Jun 23 08:51 AN M PALE BCH, PL
+312 Jun 23 09,00 AN BOYTONCH. FL
+313 Ju 23 08:11 AM M PAL BCH, PL
+314 Jun 23 09:46 AM M PALK BCH, PL
+315 Ju 23 09,58 A M PAI BCH, PL
+317 Jun 23 11:06 AM Inconing
+318 Jun 23 02:30 PM Inconleg
+319 Ju 23 03,07 PM BOGA RATON, PL
+320 JuR 23 03:08 IN BOCA RATON, PL
+321 Jut 23 03:15 PM M PALA BCH, PL
+322 Jun 23 03:26 IN BELLEOLADE, PL
+323 Jun 23 03,17 PM M PAI BCH, PL
+324 Jun 23 03:34 PM M PALK BCH, PL
+325 Jun 23 03:36 PM M PALA BCH, PL
+328 Jum 23 03,38 PM I PATA BCH.PL.
+327 JuR 21 03:40 IN PAL BE,FL
+328 Jun 23 03:40
+INS PALK BCH, PL
+329 Jun 23 03:42 PM
+DEERAY BCH, PL
+330 Jun 23 03147 PM N BALK BCH, FL
+331 Jun 21 03:49 # M PALE BCH, FL
+332 Jun 23 03:57 PM PALE BCH, PL
+333 Jun 23 04:01 PM Incon/eg
+334 JUN 21 04:05 IN M PALE BCH.FL
+335 шп 29 04:32 М Інсовівт
+336 Jun 23 04:34 IN PALE BON, FL
+337 Jun 23 04:44 PM Incoming
+338 JUL 27 04:48 PIECELET
+561-662-6688
+561-478-4188
+561-585-1237 PP
+561-820-4659 PP
+561-585-8010 PP
+561-966-7651 M
+561-9CE-76DD FF
+561-503-8429 PP
+561-642-7750
+561-305-1272 PP
+561-602-2291 PP
+561-642-7750 V9
+561-964-5511
+561-577-6425
+5E1-58E-1644
+561-723-1821
+561-642-7750
+561-503-5930
+561-642-7950
+561-663-6688
+561-394-8434
+561-289-85E0
+561-263-4945
+561-379-3168
+561-478-4158
+GET .198.1188
+561-478-4188
+561-723-1821
+561-723-1821
+561-582-9998
+561 478-4188
+561-723-1821
+561-478-4188
+561-662-6688
+561-964-5511
+Min:Sec
+2:00
+4:00
+1:00
+1:00
+1:00
+2:00
+1:00
+2:00
+2:00
+1:00
+7:00
+2:00
+2:00
+2100
+2:00
+2:00
+16:00
+1.00
+3: 00
+1:00
+1:00
+1:00
+3:00
+2:00
+1: 00
+1:00
+5:00
+2:00
+2:00
+4:00
+1:00
+1:00
+2100
+2:00
+Usage
+4.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+8.00 |
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.D0|
+п nn
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+(561) 723-1821 continued...
+Telecommunications Services Call Detail (561) 723-1821
+See
+Item # Date Time CallTo
+330 Jun 23 05:21 EM BOCA RATON, PL
+340 Jun 23 05:22 IM DELRAY BCH, PL
+341 Jun 23 05:23 PM DELAY BCH, PL
+342 Jun 24 07:13 AM I PALM BCH.PL
+343 Jun 24 07:29 AM Inconlug
+344 Jun 24 08:41 AM N PALM BCH, PL
+345 Jun 24 09:47 AM Inconing
+348 Jun 24 09:06 AM W PALM BCH,PL
+347 Jun 24 09:47 AM Inconing
+348 Jun 24 09:52 AM W FALM BCH, PL
+349 Jun 24 10:26 AM N PALM BCH,PL
+350 Jun 24 10:27 AM N FALA BCH, PL
+351 Jun 24 10:31 AM W PALM BCH, PL
+352 Jun 24 10:34 A N FALK BCH, PL
+353 Jun 24 10:35 AM W PALM BCH, PL
+354 Jun 24 10:37 AM N PALA RCH, IL
+Jun 24 11:21 AM N PALM BCH ,PL
+350 Jun 24 11:24 AM Inconing
+Jun
+24 11:57 AM Incondag
+358
+Jun 24 12:14 IM W PALM BCH, PL
+350 Jun 24 12:22 PM Inconing
+380 Jun 24 12:57 PM Incordng
+391 Jun 24 01:42 PM N PALM RCH, PL
+302 Jun 24 01:42 IM N PALM BCH, PL
+R
+Jun 24 01:44 IN W FALK BCH,PL
+304 Jun 24 01,56 PM N PALM BCH,PL
+305 Jun 24 02:17 IM N PALM BCH ,PL
+Jun 24 03:11 PM Inconing
+Jun 24 03.17 FM W PALM BCH,PL
+388
+00:21 IN N PALM RCH, PL
+309 Jun 24 09:23 IM W PALM BCH, PL
+370 Jun 24 03:24 PM PALM BCH,PL
+371
+Jun 24 03:27 EM BOCA RATON, PL
+Jun 24 03:32 PM BOCA RATON, PL
+373
+Jun 24 03:36 PM JUPITER, PL
+374
+Jun
+03,37 PM W PALM BCH,PL
+375
+Jun 24 03:40 IN N FAIN BCH UL
+376
+Jun 24 09:49 IN W PALM BCH .PL
+177
+Jun 24 04:00 PM N PALM BCH, PL
+378
+Jun 24 04.01 EM Incondng
+379
+04:03 PM N FALM BCH .PL
+Number
+Footnote Min: Sec
+561-362-4224 PP
+561-809-4224 PP
+1:00
+561-409-4224 FP
+3: 0D
+561-662-6648 PP
+561-062-EEEE FP
+561-602-4074 PP
+1:00
+2, 06
+561-602-4074
+1:00
+561-366-4690
+2100
+5E1-642-1717
+561-478-4148
+561-662-6648 PP
+5E1-478-4188 FD
+1:0D
+7,00
+1,00
+1:0D
+561-420-4659 PP
+561-668-2555
+561-714-4222
+5E1-EE2-EEEE
+561-364-5511
+561-474-4148
+1100
+1,00
+5:0D
+2:00
+5,00
+561-30E-7603
+561-818-2845
+561-420-3549
+2:00
+4:00
+561-305-1272
+561-718-4222
+561-688-2555
+561-476-4148
+1:00|
+561-662-6688
+561-966-8690
+1:00
+561-433-2169
+561-123-1421
+2,00
+561-121-1821
+2: 00
+561-478-4168
+561-478-4148
+561-362-4224
+1:00
+3:00
+3,00
+561-445-8677
+561-745-3025
+561-309-2511
+3E1-CE2-CCEE
+561-309-2511
+1:00
+2:00
+1:0D
+5:00
+561-309-2511
+224-627-9132
+15 9•
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+• 0n
+D. DD
+D.DD
+0.0D
+D.DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+
+
+
+(561) 723-1821 continued..
+Telecommunications Services Call Detail (561) 723-1821
+See
+Number
+Footnote
+Item # Date Time Call To
+350 Jun 24 05124 EN NBALK BCH, FL
+381 Jun 24 05:51 PM I DALM BCH, PL
+362 Jun 24 05:59 PM M PALE BCH, PL
+363 Jun 24 D6:07 EN Inconing
+354 Jun. 24 DE:14 IN BOTTONECH, FL.
+385 Jun 25 07:52 2м ы PAL BCH, PL
+366 Jun 25 08:08 AN M BALK BCH, PL
+387 Jun 25 08:12 AM JUPITER, FL
+388 Jut 25 DE:57 A Incoeleg
+369 Jun 25 09154 AN M PALK BCH, PL
+300 Jun 25 10102 AN N PALK BCH, PL
+381 Jun 25 10:33 AM M PALE BCH, PL
+392 J. 25 10:51 AM 5 PALK BCH, PL
+303 Jun 25 12:04 AN Incoming
+304 Jun 25 11,07 AN M PALA BCH, PL
+305 Ju 25 11:54 AM M PALE BCH, PL
+395 Jun. 25 11:56 JM Incoming
+307 Jun 25 11,58 AM N PALA BCH, PL
+398 Ju 25 12:16 IN M PALE BCH, PL
+399 Jun. 25
+12:19
+IN 5 PALK BCH, PL
+400 Jun 25 12:38 PM W PALE BCH, PL
+401 Jun 25
+12:40 PM M BALK BCH, FL
+402 Jun 21 12:50 IN M PALE BCH, PL
+403 Jun 25 12:59 PM M PALK BCH, PL
+404 Jun 25
+03:36 PM M PALE BCH, PL
+405 Jun 25 01,52 PM M BAL BCH, FL
+405 Jun 25 01:59 PM M PALK BCH, PL
+40T Jun
+02:27 PM BALE BCH, PL
+408 Jun 25
+04:23 PM Inconing
+409 Ju
+410 Jun
+25
+05:55
+IN PALK BCH, PL
+411 Jun 24 07:43 38 Incoming)
+412 Jun
+08:47 AM PALA BCH,FO
+413 Jun 24 DE:48 JN M PALE BCH,L
+414 Jun 24 08:49 AN M PALE BCH, PL
+415 Jun 29
+AN W PALK BCH, FL
+416 Jun 24 D8:56 AM M PALE BCH, FL
+417 JuR 24 09:03 AM M PALA BCH, PL
+418 Jun 24 09:05 AR
+BELEILADE,PL
+410 Jun 24 09:10 3N Inconleg
+561-662-6688
+561-662-6688
+561-309-2511
+561-333-7530 PP
+561-577-6425 PP
+561-505-8857 M
+561-718-4222 FF
+561-745-3028 PP
+561-820-4238 FP
+561-478-4188 FF
+561-352-7000 PP
+561-718-4222 PP
+561-688-2555 V9
+561-662-6688
+561-820-4659
+561-502-8827
+561-352-7000
+561-662-6688
+561-502-8827
+561-502-8827
+561-502-8827
+561-964-5511
+561-718-4222
+561-502-8827
+561-248-4980
+561-723-1821
+561-248-4980
+561-248-4980
+561-964-5511
+561-964-5511
+561-723-1821
+561-503-5930
+561-718-4222
+561-CBB-2555
+561-688-2233
+561-688-2555
+561-801-3497
+561-801-3297
+561-261-4945
+561-202-8497
+Min:Sec
+1,00
+1100
+7:00
+3:00
+1:00
+4:00
+2:00
+1:00
+1:00
+4:00
+2:00
+2:00
+3,00
+2:00
+2:00
+1.00
+1:00
+1:00
+E.00
+1:00
+1:00
+16:00
+3,00
+3:00
+2:00
+4:00
+2:00
+1:00
+1:00
+1100
+1: 0a
+1:00
+1:00
+1:00
+2:00
+4:00
+1,00
+1:00
+Usage
+4.00
+• DE
+0.0D
+$.00
+$.00
+4.00
+0.0D
+8.00 |
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.DD
+D.DD
+D.DD
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.D0|
+п nn
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+Account number 747607414
+(561) 723-1821 continued...
+Telecommunications Services Call Detail (561) 723-1821
+See
+Footnote Min: Sec
+Item # Date Time CallTo
+421 Jun 28 09:13 AM N PALM BCH, PL
+422 Jun 28 09:14 AM N PALM BCH, PL
+423 Jun 28 09:21 AM W FALA RCH,PL
+424 Jun 28 10:25 AM Incordng
+425 Jun 28 10:45 AM DELRAY BCH, PL
+420 Jun 28 10:52 AM N PALM BCH, PL
+427 Jun 28 10:57 AM Inconing
+428 Jun 28 12:36 EM Incondng
+429 Jun 28 02:05 IN Inconing
+430 Jun 28 02:24 PM BOCA RATON, PL
+431 Jun 28 02:40 PM W PALM BCH,PL
+432 Jun 28 02:52 # Inconing
+433 Jun 28 03:36 IM BOCA RATON, PL
+434 Jun 28 S4:37 PM Inconing
+435 Jun 29 07,30 AM W PALM BCH, PL
+8
+Jun 23 08:14 AM N PALM BOH, PL
+437
+Jun
+08:15 AM W PALA BCH, PL
+29 09.21 AM W PALM BCH,PL
+430
+Jun
+12:17 IN Inconing
+440
+Jun
+12:23 W Incoring
+441 Jun 29 12:26 PM Inconing
+442 Jun 29 12:40 PM Incoring
+443 Jun 29 01:07 PM Incondag
+444 Jun 29 01:08 PM N PALM BCH ,PL
+445 Jun 29 01:15 PM N PALM BCH,PL
+440 Jun 29 01:21 PM N PALM BCH,PL
+447 Jun 29 09:12 IN N PALM BCH,PL
+Jun 30 08:04 AM N FALM BCH, PL
+449
+09:30 AM N PALM BCH ,PL
+450
+30
+08:11 AM N PALM RCH, PL
+451 Jun
+08:45 AM Incoring
+Jun 30 08:59 AM Inconing
+Jun
+69.34 AM BELLEOLADE,PL
+Jun 30 10:07 AM Inconleg
+Jun 30 10:19 AM Inconing
+Jun 30
+10:41 AM Incondug
+457 Jun 30 11:53 AM N FACE NCH .UL
+Jun 30 12:03 PM W PALM BCH,PL
+450 Jun 30 12:03 PM N PALM BCH.PL
+Jun BO 12:06 EM N PALM BCH ,PL
+481 Jun
+12:12 PM Incorina
+Number
+561-784-2391
+561-784-2391
+561-420-4659
+561-474-4148 PP
+561-272-330E
+561-245-4980 PP
+561-801-3297 FP
+561-474-4148
+5E1-478-4188
+561-445-8637
+561-478-4148 PP
+5E1-478-4188 FD
+561-362-4224 PP
+561-662-6648
+561-365-4277
+5E1-718-4D05
+561-718-4222
+561-662-6C48
+561-478-418E
+561-476-4188
+561-478-4148
+561-733-2077
+561-365-0277
+561-662-6688
+561-716-4222
+561-684-2555
+561-723-1621
+561-641-7717
+561-697-9643
+561-718-4207
+561-718-4207
+561-361-0033
+561-261-4545
+561-747-9128
+:
+561-662-664
+561-662-6648
+361-118-4222
+561-662-6688
+561-723-1421
+561-433-4002
+1:00
+1100
+1,00
+2:00
+2, 06
+2:00
+1:0D
+3,00
+3: 0D
+3:00
+2,00
+1:0D
+2, 00
+2:00
+2:00
+5,00
+1:00
+2100
+2:00
+3: 00
+3:00
+2:00
+1:0D
+1:00
+3:00
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+• 0n
+D. DD
+D.DD
+0.0D
+D.DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+
+
+(561) 723-1821 continued..
+Telecommunications Services Call Detail (561) 723-1821
+See
+Number
+Footnote
+Item # Date Time Call To
+482 Jun 30 03:29 PM M BALK BCH, FL
+463 Jun. 30 02:21 IN M PALK BCH, PL
+454 Jun 30 04:27 PM Incoming
+405 Jal 01 08:05 AM BELLEGADE, PG
+450 Jul 01 DE: DE A M FAL BCT, FL
+457 Jul 01 08:07 AM BELLECLADE, PL
+485 Jul 01 08:57 AM M BALK BCH, PL
+489 Jul 01 09,04 3M M BALK BCH, FL
+470 Jul 01 08:21 J Incoeleg
+471 Jul 01 09:33 AM M BALE BCH, PL
+472 Jul 01 09,34 3M M PALA BCH, PL
+473 Jul 01 10:41 A Iccele
+474 Jul 01 10:42 JM 5 PALK BCH, PL
+475 Jul 02 10:44 AN M PALE BCH, PL
+478 Jul 01 10,50 AM M PALA BCH, PL
+477 dal 01 11:33 A Iscoeleg
+478 Jul 01 12:04 IN W PALK BCH, PL
+479 Jul 01 03,50 IN Inconing
+480 Jul 01 03:52 IN M PALE CE, PL
+481 Jul 01 04:00 PM 5 PALK BCH, PL
+462 Jul 01 04:17 IN M BALE BCH, PL
+483 Jul 01 05128 IN M BALA BCH, FL
+484 2ul 01 05:38 I INcele
+485 Jul 02 07:43 AM M PALA BCH, PL
+485 Jul 02 08:09 2M M PALE BC, PL
+457 Jul 02 08:12 AM M BALA BCH, PL
+488 Jul 02 08:14 AM M PALK BCH, PL
+489 Jul 02
+08:15 AN M BALK BCH, PL
+400 Jul 02
+08:22 AM BELGIGADE, PL
+491 Jul
+DE:37 AM INCoRle
+08:42 AM 5 PALA BCH, PL
+dul 0a
+09:26 AN M BALK BCH, PL
+09,29 AM M BALA BCH, PL
+tal 02
+08:51 AN I PALE BCH, PL
+09:58 AN M BALK BCH, PL
+09,59 3M M BALK BCH, FL
+498 Jul 02
+10:00 AM M PALE BCH, PL
+499 Jul 62 10:11 AM M PALA BCH, PL
+561-833-4002
+561-723-1821
+Min:Sec
+1,00
+1:00
+5:00
+Usage
+4.00
+561-662-6688 PP
+561-261-4945 PP
+561-585-8010 PP
+561-261-4945 M
+• DE
+561-964-5511 FF
+561-502-8827 PP
+561-395-1111 FP
+561-662-6CE8 FF
+561-662-6688 PP
+561-478-4188 PP
+561-723-1821 V9
+561-662-6688
+561-478-4188
+561-478-4188
+561-502-8827
+561-478-4188
+561-718-4222
+561-502-8827
+561-478-4188
+1:00
+2:00
+1:00
+2:00
+1:00
+1:00
+1:00
+1:00
+1:00
+0.0D
+$.00
+$.00
+4.00
+0.0D
+2:00
+0.0D
+1,00
+2:00
+0.0D
+1:00
+2100
+2:00
+0.0D
+1:00
+1.00
+$.5B
+561-966- 2690)
+1.00
+• 0[
+561-502-8827
+561-585-8010
+561-662-6688
+1:00
+0.0D
+3:00
+3:00
+•.00
+2:00
+9,00
+561-688-2555
+1:00
+$.00
+561-718-4222
+3:00
+0.0D
+561-261-4945
+1:00
+561-718-D878
+5:00
+561-723-1821
+3:00
+561-820-4659
+1:00
+561-820-4161
+1:00
+561-E62-CEE8
+5:0a
+561-723-1821
+1:00
+561-964-5511
+2:00
+561-9CE-BE9D
+2:00
+0.0D
+•.00
+0.0D
+•.00
+- •r
+561-670-5084
+2:00
+561-670-5084
+1:00
+•.00
+501 Jel 02 10:15 AM W BALK BCH, FL
+561-670-5084
+2:00
+$.00
+502 Jul 0z
+4: 00
+Long
+Distance
+D.D0
+D.DD
+D.DD
+D.DD
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• on
+0.D0|
+n an
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+corticued.
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+(561) 723-1821 continued...
+Telecommunications Services Call Detail (561) 723-1821
+See
+Item # Date Time CallTo
+Number
+Footnote Min: Sec
+509 Jul 02 10:31 AM I PALM BCH.PL
+561-966-9690
+2:00
+504 Jul 02 10:34 AM N PALM BCH, PL
+561-547-5527
+1:00
+505 Jul 02 10:53 AM Inconing
+561-764-5511
+2100
+508 Jul 02 11:20 AM W PALM BCH ,PL
+561-964-5511 FP
+507 Jul 02 11:34 AM N RAIN BCH, PL
+561-062-EEEE FP
+1:00
+508 Jul 02 11:46 AM Incoring
+561-820-4531
+2:00
+509 Jul 02 12:15 PM N FALK BCH, PL
+561-662-6C48
+3:00
+510 Jul 02 12:27 EM Incordng
+561-503-4429
+=
+2100
+511 Jul 02 12:63 IN N FALM BCH ,L|
+5E1-502-B827
+:
+1:0D
+512 Jul 02 01:12 PM Inconing
+561-367-1095
+513 Jul 02 02:40 PM Incondng
+561-478-4148 PP
+1,00
+514 Jul 02 02:46 IN N FALE RCH, PL
+5E1-123-1821 FP
+5:0D
+515 Jul 02 09:26 IM N PALM BCH, PL
+561-502-8827
+518 Jul 02 03:53 PM N FALK BCH, PL
+561-502-8427
+Jul 02 04:06 EM W FAIM BCH ,PL
+561-364-5511
+518 Jul 02 04:18 IN N PALM RCH, PL
+5E1-302-8827
+1:0D
+"10
+Jul
+08:07 AM Incoming
+513-354-7900
+Jul 06 09.14 AM W PALM BCH, PL
+561-714-4222
+1,00
+Jul DE 08:24 AM N PALM RCH, PL
+561-718-4005
+2:00
+522
+Jul
+08: 26 AM W PALM BCH, PL
+561-716-4222
+1:00
+523 Jul 06 08:36 AM N FALM RCH,PL
+561-723-1821
+:
+524 Jul 06 09:44 AM Inconing
+561-306-2673
+Jul DE 08:55 AM N FALA BCH, PL
+561-718-4222
+:
+2,00
+6: 0D
+Jul 06 09:34 AM Inconing
+561-503-5930
+527
+Jul
+09:49 AM Inconing
+561-503-5936
+Jul 06 10:04 AM Incondng
+561-503-5930
+Jul 06 10:23 AM Inconing
+561-503-5930
+530
+Jul
+10:26 AM W FALK BCH ,PL
+561-662-6698
+531
+TuT nE
+10.39 AM Incordng
+561-662-5698
+1:00
+3: 00
+1,00
+532
+DE
+11:45 AM N FALM RCH, PL
+561-121-1821
+533
+Jul
+02:43 PM Incoring
+561-478-4168
+534
+Jul 06 02:49 PM Inconing
+561-503-3359
+=
+4: 00
+3:00
+535
+Jul
+561-714-4222
+536
+Jul 07 07:55 AM N FALA RCH, PL
+561-714-4005|
+537
+Jul 07 04:01 AM N PALM BCH, PL
+561-964-5511
+538
+Jul
+09:04 AM Incondug
+561-714-4222
+539
+Jul 07 00:15 AM N FAIN BCH UL
+561-691-3395
+540
+Jul 07 10:29 AM Incoring
+561-642-1717
+1:0D
+2:00
+541 Jul
+10:45 AM N PALK BCH,PL
+561-420-4161
+Jul 07 11:23 AM Incondng
+561-474-4148
+543
+11 n7
+11:37 AM A FALM BCH PL
+2:0D
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+
+
+(561) 723-1821 continued..
+Telecommunications Services Call Detail (561) 723-1821
+See
+Number
+Footnote
+Item # Date Time Call To
+544 Jul 07 11:42 3M M BALK BCH, FL
+545 Jul 07 11:47 AM JUPITER, PL
+546 Jul 07 11:49 AN Inconleg
+547 Jul 07 11:49 3M M BALK BCH, FL
+548 J] 07 12:09 IN M PALE BCH, FL
+549 Jul 07 12:14 IM 5 PALK BCH, PL
+550 Jul 07 12:19 PM M BALK BCH, PL
+551 Jal 07 12:20 EN Inconing
+552 Jul 07 12:26 IN M BALE BCH, VL
+553 Jul 07 03,34 PM M PALK BCH, PL
+554 Jul 07 01,45 PM M PALA BCH, PL
+555 Jul 07 01:59 w Iscoeleg
+550 Jul 07 02:01 I Inconieg
+557 Jul 07 02:11 EN Inconleg
+558 Jul 07 02/16 EN Inconing
+559 Jul 07 DE:4E IN M PALE BCH, FL
+560 Jul de 07:15 AM Inconley
+581 Jul 08 07,15 AN I PAL/ BCH, PL.
+562 Jul 08 07:52 AN M PALE BC, PL
+Jul de 07:53 AM Isconieg
+564 Ли] с4 08:19 лМ ВОУТОНЕСН, РБ
+565 Jul 04 09,19 M M PA BCH, PL
+50024l 0808:25 AN INCle
+567 Jal 08 09:35 AM BOYTONECH, PL
+568 Jul 04 10:04 AM M BALE BCH, PL
+589 Jul 08 10:05 3M Inconing
+570 Jul 04 10:42 AM M PALK BCH, PL
+571 Jul 04 10:46 AM NEWARX, NJ
+572 Jul 04 10:49 M BOYTONCH, PL
+573 Jul 08 11:12 J8l Inconleg
+574 Jul Q4 12:01 PM Inccelet
+575 Jul 04 12:17 PM BOYTONCH, FL.
+576 Jul 08 12141 EM Inconing
+577 Jal 08 01:54 # IncaleT
+578 Jul 08 02:12 PM JUPITER, PL
+579 Jul 04 02127 IN M BALA BCH, FL
+58026l00 02:17 Incle
+581 Jul 64 02:18 PM M PALA BCH,PL
+583 Jul 04 02,57
+IN W BALK BCH,PL
+584 Jul 04 03:12 IN Incoeleg
+561-478-4188
+561-749-5R4R
+561-478-4188
+561-842-2482 PP
+561-662-66E8
+561-21R-A005
+561-662-66B8 FF
+561-662-6688 PP
+561-718-4005
+561-965-2335 FF
+561-478-4188 PP
+561-791-9363 PP
+561-965-2335 V9
+5E1-249_5A1T
+561-432-1793
+561-252-4354
+561-964-5511
+561-964-5511
+561-364-5511
+561-964-5511
+561-742-2363
+561-966-7600
+561-436-4378
+561-436-4378
+561-642-3100
+561-478-4188
+561-478-4188
+973-332-7125
+561-436-4378
+561-436-4378
+561-820-4567
+561-436-5722
+CE1_1nE_Sc57
+561-478-4188
+561-262-3194
+561-662-6688
+561-EG2-EEEB
+561-662-6688
+561-662-6688
+561-662-6688
+E2TR2S.22a
+Min:Sec
+2:00
+1:00
+1100
+1:00
+4:00
+5.00
+1:00
+6:00
+1:00
+2:00
+1:00
+1:00
+1:00
+4:00
+1:00
+1:00
+1.00
+2:00
+1:00
+2:00
+2100
+5:00
+2:00
+1:00
+4: 00
+2:00
+24:00
+4: 00
+3: 00
+2:00
+2:00
+J:0a
+1:00
+1:00
+2:00
+1:00
+1,00
+1:00
+Usage
+4.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+8.00 |
+0.0D
+0.0D
+0.0D
+8.0B
+0.0D
+•.00
+$.00
+0.0D
+$.00
+0.0D
+$.00
+0.0D
+•.00
+$.00
+0.0B
+•.00
+4.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+0.00 |
+D.DD
+0,00|
+D.D0
+• DO
+0.00 |
+D.DD
+n an
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+0.00 l
+Account number 747607414
+(561) 723-1821 continued...
+Telecommunications Services Call Detail (561) 723-1821
+See
+Item # Date Time CallTo
+Number
+Footnote Min: Sec
+585 Jul 08 03-14 EM N PALM BCH, PL
+561-662-6698
+:
+500 Jul 08 03:14 IM N PALM BCH, PL
+561-662-6668
+1:00
+587 Jul 08 03:19 PM W FADE RCH, PL
+561-474-4148
+2100
+588 Jul 08 03.33 EM Incordng
+561-474-4148
+7,00
+589 Jul De 06:36 IN BOCA RATON, PL
+561-361-0033
+=
+4: 0D
+390 Jul 09 07:27 AM BOCA RATON, PL
+561-361-0033 PP
+501 Jul 09 07:29 AM BOCA RATON, PL.
+561-361-0033 FP
+1100
+592 Jul 09 09.36 AM W PALM BCH.PL
+561-373-5776
+583 Jul 09 08:26 AM Inconing|
+5E1-171-577E
+504 Jul 09 08:29 AM N FACE BCH, PL
+561-644-3360
+505 Jul 09 10:34 AM Inconing
+561-306-2673 PP
+500 Jul0310:33 ANJURITE, I
+SE1-262-3154 FD
+097 Jul 09 10:52 AM Inconing
+561-863-2764
+508 Jul 09 11:27 AM Inconing
+561-744-7506
+500 Jul 09 11:20 AM W FALM BCH,PL
+561-474-4148
+Jul 03 11:31 AM IncoRing
+561-478-4188 FD
+601
+01:17 I Inconing
+561-662-6688
+09 01.20 EM W PALM BCH, PL
+561-474-0418
+603
+02:35m Incondag
+561-0E2-30PE
+604
+Jul
+02:43 IM W PALM BCH, PL
+561-722-1328
+6:00
+1:0D
+1:00
+4: 0D
+5100
+2:00
+2:00
+3,00
+5: 0D
+4: 00|
+805 Jul 09 03:19 PM BOYTONBCH, PL
+561-503-5936
+1:00
+608
+Jul 09 03.22 PM Incondng
+561-662-6648
+Jul 03 03:30 EM BOSTONECH, PL
+561-714-1030
+Jul 09 09:31 PM JUPITER, PL
+561-743-1030
+Jul 09 03:32 PM BOYTONICH, PL
+561-503-5936
+810 Jul 09 03,33 PM N PALM BCH,PL
+561-723-1421 PP
+611 Jul 0903:35 IN JUPITER, PL
+561-743-1030
+฿12
+Jul 09 03:5€ EM Inconing
+561-503-5930 FF
+1:00
+1,00
+2:00
+1:00
+813 Jul 09 04:13 PM Incondug
+561-503-5930 PP
+814 Jul 03 05:28 PM N FALA RCH, PL
+561-123-1821 FP
+TOTAL
+1421:00
+Usage
+000|
+50.00
+Footnote
+Features
+Networks
+NN-National Network
+CN-Canadian Network
+Services
+Do Tale Serie
+Pr-Partial Free
+TJ-Tijuana Network
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+0.0D
+D.DD
+50.00
+Time Period
+MP-Muiticle Period
+Charges
+D.0D
+0,00
+0.00|
+•.00
+0.0D
+0.0D
+
+
+
+(561) 723-3440
+Telecommunications Services Call Detail (561) 723-3440
+See
+Number
+Footnote
+Item # Date Time Call To
+Jun 12 D8113 100 IncoRleg
+2 Jun 11 09:04 AM M BALE BOTE, FL
+3 Jun 11 09:15 AM Incoming
+4 Jun 12 D8,29 AN I PALA RCH, PL
+5 Jun 11 10:13 AN PTLAUDEADL, PL
+6 Jun 11 11:59 AN Incla
+7 Jun 11 02:23 PM N PALE BCH, PL
+$ Jun 11 02128 IN M PALE BCH, PL
+9 Jun 11 02:45 IN Inconing
+10 Jun 11 02:52 IM Inconing
+11 Jun 11 D4,0D IN Inconleg
+12 Jun 11 09:13 IN Inconing
+13 Jun 11 11:12 IN INcoRleg
+14 Jun 12 09:35 AM M PALK BCH, PL |
+15 Jun 12 D8,57 AN M PALK BCH, PL
+16 Jun 12 10:01 AN FTLAUDEADL, PL
+17 Jun 12 11:28 AM ITLADEADO, FL
+18 Jun 12 11:30 AM BOYTONBCH, PL
+19 Jun 12 11:44 AN FILAUDEADL, PL
+20 Jun 12 11:46 AM M BALE ECT, PL
+21 Jun 12 12:06 IM Inconing
+22 Jun 12 03/28 EN Incoming
+Jun 12 01,33 IN Incoming
+24 tun 13 07:41 AM INCORLeG
+Jun 13 08:06 2M PALE BCH, PL
+Jun 1] 08111 AN Incoming
+27 un 13 08:32 0 0 BALA BO, PL
+28 Jun 13 09:00 2M Inconing
+20 Jun 17 09,02 AN Inconleg
+30 Ju 13 09,39 AN M PALE BCH, PL
+31 dum 13 0340 n Incl
+32 Лип 13 11:52 АМ Ieconieg
+33 Jun 1] 12,53 AN M PALE BCH, PL
+34 Jun 13 12,39 PM M PALA BCH, PL
+Jun 13 08:14 PM SPALK BCH, PL
+R
+37 Jun 14 08:50 AM M PALA BCH, PL
+39 Jun 14 09:25 AM Inconing
+40 Jun 14 10,02 AN Inconleg
+561-478-4188
+S61.541-4051
+561-718-4005
+561-718-4005
+954-295-6132
+954-295-6132
+PP/FU
+PP/PU
+561-616-8240 PP/FU
+561-616-8240 PP/FU
+561-616-8240
+561-616-8240 PP
+561-827-2542
+561-503-8429
+8
+561-758-8826
+561-6A9-1636
+561-719-9546
+954-295-6132
+954-295-6132
+561-503-8429
+954-295-6132
+561-662-6688
+954-295-6132
+561-333-7530
+561-333-7530
+561-502-7753
+OP/PO
+OP/PU
+OP/PU
+OP/PU
+OP/PU
+8
+8
+8
+8
+561-6G2-6688
+561-662-6688
+561-133-7530
+561-333-7530
+g
+S61-616-8240
+OP/PU
+561-616-8240
+8
+561-616-8240
+8
+Op/FU
+561-616-8240
+Op/PU
+561-E62-E688
+561-965-D722
+561-503-8429
+F/PU
+S61-427-2542
+Min: Sec
+1:00
+2:00
+2:00
+2:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+4:00
+3:00
+2:00
+4:00
+2:00
+1:00
+2:00
+2:00
+2:00
+2:00
+1:00
+1:00
+1:00
+4:00
+4: 00
+1:00
+3,00
+1.00
+1:00
+1:00
+2.00
+2:00
+1:00
+1:00
+1:00
+Usage
+9.00
+•.b[
+0.0D
+• 5[
+$.00
+0.0D
+0.0D
+$.00
+•.00
+0.0D
+•.00
+$.00
+•.00
+0.00 |
+$.00 |
+•.0D
+0.0D
+•.0D
+•.00
+0.0D
+฿.00 |
+0.0B
+0.0B
+0.0D
+0.0D
+0.00 |
+Long
+Distance
+D.DD
+D.00
+D.DD
+D.DD
+D.0D
+0. 00
+D.DD
+D.D0 |
+D.DO
+D.DD
+D.D0
+D.D0
+0.00|
+D.D0
+D.DO
+0.D0
+n no
+corticued.
+Total
+Charges
+9.00
+d.00
+9.00
+9.00
+9.00
+4.00
+1.86
+9.00
+9.00
+d.00
+1.20
+a.ca
+Account number 747607414
+Telecommunications Services Call Detail (561) 723-3440
+See
+Footnote
+Item # Date Time CallTo
+42 Jun 14 11:11 AM N PALM BCH ,PL
+43 Jun 14 11:29 AM N PALM BCH, PL
+44 Jun 14 12:26 PM Inconing
+45 Jun 14 01/19 EM Inconing
+48 Jun 14 01:37 IN N RAIN RCH, PL
+47 Jun 14 01:37 IM N PALM BCH, PL
+48 Jun 14 01:39 PM W FALM BCH, PL
+49 Jun 14 01:53 EM Incondng
+Jun 14 02:0€ IN N FAIN BCH ,PL
+51 Jun 14 03:5€ IN Inconing
+52 Jun 14 05:22 PM BOTTONBCH, PL
+Jun 14 08:39 # Inconing
+54 Jun 15 06:51 AM N PALM BCH, PL
+55 Jun 15 05:04 PM Inconing
+Jun 16 04:34 AM Incondng
+Jun 16 08:32 AM N PALM BOH, PL
+Jun 16
+10:47 AM W PALA BCH ,PL
+Jun 16 11:06 AM W PALM BCH, PL
+8
+Jun 16 12:03 IN N PALM BCH, PL
+Jun 16
+12:17 W Incoring
+82 Jun 16 Ø1:46 IN W PAIN BCH,PL
+8
+Jun 16 02:10 PM PALM BCH,PL
+Jun 16 02:10 PM N FAIM BCH, PL
+Jun 16 02:14 PM Inconing
+0Q:44 IN W FALK BCH,PL
+Jun 16 02:54 EM W PALM BCH,PL
+Jun 16 05:11 I Incoring
+Jun 16
+05:32 PM W PALM BCH,PL
+Jun 16 05:33 EM N PALM BCH,PL
+16 05:16 IN N PALA RCH, PL
+Jun 16
+05:20 IM Inconing
+73 Jun 17 06:02 AM N PALM BCH, PL
+74 Jun 17 09:24 AM N PREM BCH,PL
+Jun 17 08:30 AM BOTTONICH, VL.
+Jun 17 08:38 AM PILAUDERDG, PL
+Jun 17 04:41 AM Incondug
+78 Jun 17 08:42 AM Inconleg
+79 Jun 17 Ce:46 AM Incoring
+Jun 17 04:52 AM Inconing
+Jun 17
+09:04 AM Incondng
+CO:15 AM N FALM BCH .PL
+Number
+561-723-3440
+PP/FU
+561-683-4511
+PD/PU
+561-616-4240 FP
+561-687-3636 FP
+561-683-8511
+FE /FU
+561-845-4345
+561-616-4240 FP/FU
+561-683-1219 PP
+5E1-848-4145
+FE /FU
+561-616-4240 FP
+561-577-4416 PP/PU
+unavallable SP
+561-662-6688 0D/PU
+561-502-5212 FP
+561-662-6688
+5E1-E1E-824D
+SP/FU
+561-616-4240
+PD /PU
+561-352-7000
+pP/pu
+561-662-ECEE FF/FU
+561-662-6688 00
+561-616-4240 FF/FU
+561-687-3636 pP/PU
+561-CET-363E FF/FU
+561-616-4240 P0
+561-616-4240 FF/PU
+561-616-9240 FP/PU
+561-796-0446P0
+561-662-6698
+FF/FU
+561-794-0448 PP/PU
+561-662-ECEE FF/FU
+561-662-6668 PP
+561-662-6668 CE/FU
+561-687-3636
+561-43E-210E
+954-295-6132 FF/FU
+561-722-3311 PP
+561-122-3311
+561-722-3311
+954-295-6132
+561-122-3311
+Min: Sec
+1,00
+3:00
+1:00
+1:00
+1:0D
+3:0D
+3,00
+1:0D
+5:00
+Usage
+2100
+1:0D
+3:00
+2:00
+1,00
+2:0D
+2:00
+1:00
+3,00
+4. 00
+1:00
+2:00
+1,00
+1:0D
+1:00
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+•.00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+(561) 723-3440 continued...
+Telecommunications Services Call Detail (561) 723-3440
+See
+Footnote
+Item # Date Time Call To
+83 Jun 17 09:17 JM Inconing
+84 Jun 17 10:06 AM Incoming
+85 Jun 17 10139 A M PAL BCH, PL
+Ba Jun 17 11/01 AM Inconing
+B7 Jun 17 11:29 AN Incoeleg
+BB Jun 17 12:29 IM M PALA BCH, PL
+89 Jun 17 02:16 PM M BALK BCH, PL
+00 Jun 17 01,19 EN Inconleg
+91 Jun 17 01:19 IN M FALL ECH, FL
+92 Jun 17 02:23 EN Inconleg
+93 Jun 17 01,26 PM N PALA BCH,PL
+94 Jun 17 01:2E IN M PALE BCH, VL.
+95 Jun 17 01:29 PM 5 PALE BCH, PL
+95 Jun 17 02:30 PM M BALE BCH, PL
+97 Jun 17 01,33 EM W BALE BCH, FL
+88 JuN 17 01:47 PM BALA BOT, PL
+99 Jun 17 01:52 IN Incoming
+100 Jun 17 02:00 PM Inconing
+101 Jun 17 02:02 N Inceled
+102 Jun 17 02:16 PM 5 PALK BCH, PL
+103 Jun 17 02:18 PM M PALE BCH, PL
+104 Jun 17 02121 PM Incoming
+105 Ju 17 02:53 IN M PALE BCH, VL.
+105 Jut 17 02:54 PM M PALA BCH, PL
+107 Jun 17 04:11 PM Inconleg
+105 Jun 14 08134 JM Inconing
+109 Jun 14 08:46 AN Inconley
+110 Jun 14 10:36 AN Incoming
+111 Jun 14 12,36 AM M BALA BCH, PL
+112 Jun 18 11:57 AN Incoeleg
+113 Jun 1# 01:23 PM M PALK BCH, PL
+114 Jun 14 03:26 #N Inconleg|
+115 Jun 19 03125 PM N BALA BCH, FL
+116 Jun 1804:20 Inchelag
+117 Jun 14 04:21 PM M PALE BCH, PL
+118 Jun 19 04:27 IN M BALA BCH, FL
+119 Jun 1# 04:34 PM M PALE BCH, FL
+120 Jun 1# 05:18 IN Incories
+121 Jun 14 05:41 IN InconleT
+122 Jun 14 D6,55 PM INCOmİng
+Number
+561-722-3911
+561-478-4188 PP
+561-687-1686
+PP/FU
+Min:Sec
+561-667-4222
+561-478-4168 FF
+561-RAR-6A1A
+561-662-66RR
+PP/FU
+561-662-6688
+561-E1E-8240
+FP/FU
+561-662-6688
+PP/FU
+561-723-344D PP/SU
+561-644-9726 PP/90
+SEI -EAR-TERE PRISO
+561-644-9726
+561-E1E-E24D
+PP/PU
+PP/FU
+561-662-6688
+561-616-8240
+561-662-6GE8
+561-662-6688
+561-662-6688
+PP/FU
+561-233-7710 PP
+561-358-7914
+FP /FU
+561-686-2246 PP/90
+561-358-7914
+561-358-7914 PP
+561-662-6688
+561-662-6688
+561-723-1440
+561-E87-3636
+561-723-3440
+561-616-9240
+561-687-3636
+PP/PU
+561-CRE-E906
+561-662-6688 PP/PU
+561-616-8240 PP/FU
+561-EG2-EGEE FP/FU
+561-662-6688
+=
+561-503-8429
+561-333-7530
+BETTE SAN
+1:00
+3:00
+2:00
+3:00
+1:00
+2:00
+1:00
+2:00
+3:00
+2:00
+1:00
+2:00
+2:00
+2:00
+3.00
+7=00
+2:00
+1,00
+3,00
+2:00
+2:00
+2:00
+2:00
+1:00
+2:00
+2:00
+2:00
+2:00
+1: 0a
+1:00
+1:00
+3:00
+3:00
+2:00
+Usage
+4.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+8.00 |
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+0.00 |
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+corticued.
+SUNSHINE SVOS UNLIMITED
+Account number 747607414
+Telecommunications Services Call Detail (561) 723-3440
+See
+Footnote
+Item # Date Time CallTo
+124 Jun 19 07:29 AM Incondng
+125 Jun 19 07:31 AM N PALM BCH, PL
+126 Jun 19 07:32 AM Inconing
+127 Jun 19 07:53 AM Incondng
+128 Jun 19 07:56 AM Inconleg
+129 Jun 19 08:05 AM Inconing
+130 Jun 19 08:0€ AM Inconing
+131 Jun 19 09.12 AM W PALM BCH,PL
+132 Jun 19 08:14 AM Inconing
+133 Jun 19 09:17 AM Inconing
+134 Jun 19 12:20 PM Incondng
+135 Jun 13 01:01 PM 1 FALE BCH, PL
+136 Jun 19 01:02 IM Inconing
+137 Jun 19 04:21 PM N FALK BCH, PL
+138 Jun 20 03:22 PM PILAUDERDG, PL
+g
+Jun 20 03:51 PM Incoring
+Jun 21 08:48 AM W PALM BCH ,PL
+141 Jun 21 09.53 AM Incondng
+Jun 21 09:43 AM Incondng
+Jun 21 69:49 AM Inconing
+144 Jun 21 10:31 AM W PALM BCH, PL
+145 Jun 21 10:12 AM W PALM BCH,PL
+146 Jun 21 10:15 AM Inconing
+147 Jun 21 09:29 IM N PALM BCH,PL
+148 Jun 21 03:30 PM N FAL BCH, PL
+149 Jun 21 03:41 FM Incondng
+150 Jun 21 64:25 PM Incoring
+151
+06:15 PM Inconing
+Jun 21 07:02 EM Incondng
+153
+08:50 AM N PALM RCH, PL
+22
+09:33 AM PLAUDERDG, PL
+155 Jun 22 09:43 AM N PALM BCH,PL
+Jun
+22 10:32 AM PALM BCH,PL
+Jun 22 10:35 AM Inconing
+Jun 22 10:52 AM Inconing
+150
+Jun 22
+10,55 AM W PALM BCH,PL
+160 Jun 22 10:57 AM FAL NCH.PL
+181 Jun 22 11:00 AM W PALM BCH, PLI
+Jun 22 11:02 AM Inconing
+Jun 22 01:41 EM Incondng
+184 Jun
+01:52 PM N FALM BCH .PL
+Number
+561-333-7530
+561-723-3440
+0P/PU
+561-333-7530 CP
+561-333-75300P
+561-141-5443 08/NN
+561-502-17530P
+561-502-1753 OF
+561-333-7530 0P/PU
+561-333-7530 OF
+561-333-7530 OF
+561-616-8240 OP
+SEL-EE2-ECBE DE/FU
+561-662-6688 00
+561-616-4240 CE/FU
+954-295-6132
+0P/PU
+254-225-6132
+561-478-4188
+PD /PU
+561-662-6C48 PP
+561-478-4188 FP
+561-476-4188
+561-662-6658 PE/FU
+561-474-4148 PP/PU
+561-062-ECEE FP
+561-662-6688 PD/PU
+561-476-4148 FF/PU
+561-478-4188 PP
+561-616-8240
+561-687-3636
+:
+561-616-9240
+561-61E-8240
+954-295-6132
+PD /PU
+561-616-4240 FF/PU
+561-662-6688 PP/PU
+Min: Sec
+2:00
+1:00
+2100
+1,00
+1100
+2100
+1,00
+1:0D
+2:00
+1100
+6: 0D
+2:00
+1,00
+1:0D
+3,00
+2:00
+2100
+4:00
+3: 00
+1,00
+4. 00
+1:00
+1,00
+561-502-6713 FP
+561-502-6713
+PP/PU
+561-E1E-8240 FD/FU
+561-502-6713 PD/PU
+561-502-4713 PP
+561-503-9429
+01_05.171
+1,00
+1:0D
+1:00
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+0,00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+(561) 723-3440 continued...
+Telecommunications Services Call Detail (561) 723-3440
+See
+Number
+Footnote
+Item # Date Time Call To
+185 Jun 22 03:07 PM Inconing
+106 Jun. 22 03:11 PM M PALA BCH, PL
+187 Jun 22 03113 PN DETAAY BCH, PL
+188 Jun 22 04,33 PM BOYTONECH. FL.
+109 Ju 22 05:09 IN M PALE BCH, FL
+170 Jun. 22 05:20 IN • PALA BCH, PL
+171 Jun 22 08:41 PM Inconing
+172 Jun 22 08:45 PM W BALK BCH, PG|
+173 Jut 23 DE:52 JC M BALE BCH, VL
+174 Jun 23 DE:55 AM M BALE BCH, PL
+175 Jun 23 07,50 AM N BALK BCH, FL
+176 Ju 23 08:11 N Incoeleg
+177 Jun. 23 09:38 AM Inconieg
+178 Jun 23 10:35 AM Inconleg
+179 Jun 23 11:12 AM Inconing
+180 Ju. 21 11:47 AN M PAL BCH, VL
+181 Jun 29 11:56 AM N PALK BCH, PL
+182 Jun 23 12/16 PN M PALA BCH, FL.
+183 JuL 23 DE:01 IN M PALE BCH, PL
+184 Jun. 24 06:47 3M M DALK BCH, PL
+185 Jun 24 07:15 AM Inconleg
+158 Jun 24 07,21 AM M PATE BCH, PL
+187 Jun 24 12:17 AN M PALE BCH, FL
+188 Jun. 24 11:49 AN Inconley|
+180 Jun 24 12:35 PM M PALE BCH, PL
+190 Jun 24 12,36 PM M BAL BCH, FL
+191 Jun 24 01:26 PM 5 PALK BCH, PL
+192 Jun 24 02:33 PM Inconleg
+193 Jun 24 02:19 PM Inconing
+194 Jun 24 03:20 IN M PALE BCH, FL
+Jun 24 04:18 PM Inconies
+195 Jun 25 12:14 2М InconleT
+197 Jun 25 11,59 2M Inconing
+198 JuR 25 12:00 IN M PALE BCH, FL
+200 Jun 25 03,55 IN M BALA BCH, FL
+201 Jun 25 02:51 Inconleg
+202 Jun 25 03:28 PM M PALA BCH,PL
+20324250329M ON,PL
+204 Jun 2503,33 PM Incoming
+205 Jun 23 03:14 #N Inconleg
+561-662-6688
+561-689-1636
+561-276-5399 PP/FU
+561-503-8429 PP/FU
+561-502-6713 PP/FU
+561-502-6713 PP/PO
+561-333-7530 PP
+561-662-6688
+PP/FU
+561-EE2-CEEE
+OF/FU
+561-616-8240 OP/FU
+561-502-6713 PP/PU
+561-964-4420 PP
+561-503-593019
+561-503-8429 PP
+561-478-4188
+561-502-7753
+PP/FU
+561-352-7000
+561-352-7000
+561-723-3440
+PP/PU
+pP/FU
+561-662-6688
+561-827-2542
+561-827-2542
+PP/PU
+561-502-6713
+PP/PU
+954-548-8594P9
+561-502-6713
+561-616-8240 PP/PU
+561-662-6688
+P/PU
+561-616-8240
+Unava11ahle
+561-352-700D
+FF/FU
+561-478-4168
+561-616-9240
+561-662-6688
+561-152-700D
+PR/FU
+561-662-6688
+PP/FU
+561-585-4772
+PP/FU
+561-E1E-E240|
+561-616-8240
+561-502-6713
+p/PO
+PP/FU
+561-503-5930
+Min:Sec
+2:00
+1100
+2:00
+2:00
+1:00
+3:00
+7,00
+4:00
+2:00
+1:00
+1:00
+2:00
+1:00
+3:00
+2:00
+5:00
+3:00
+1.00
+1:00
+1:00
+4:00
+6: 00
+2:00
+3,00
+10:00
+2:00
+2:00
+1:00
+1: 0a
+2:00
+2:00
+1:00
+1:00
+1:00
+Usage
+4.00
+$.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+8.00 |
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.DD
+D .00
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+0.D0|
+п nn
+n an
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+corticued.
+Account number 747607414
+Telecommunications Services Call Detail (561) 723-3440
+See
+Footnote
+Item # Date Time CallTo
+200 Jun 25 03:50 PM Incordng
+207 Jun 25 04:35 IM N PALM BCH, PL
+208 Jun 25 04:36 PM W FADE RCH, PL
+200 Jun 25 05/17 EM Incoring
+210 Jun 25 05:52 PM Inconlog
+211 Jun 26 09:17 AM N PALM BCH, PL
+I Jun 26 10:40 AM PILAUDERDG, PL
+213 Jun 26 10:55 AM W PALM BCH,PL
+214 Jun 26 10:59 AM Incoring
+215 Jun 26 11:55 AM Inconing
+218 Jun 26 12:13 EM Incondng
+217 Jun 26 12:17 PM N FALM BCH, PL
+218 Jun 26 12:22 IM N PALM BCH, PL
+210 Jun 26 01:35 PM Inconing
+220 Jun 26 01:46 PM W PALM BCH, PL
+221 Jun 26 01:47 PM Incoring
+Jun
+02:00 I Inconing
+02:09 PM Inconing
+224
+26 02:09 IN IncoRleg
+225
+Jun
+02:10 W Incoring
+220 Jun 26 02:26 PM N PALM RCH,PL
+Jun 26 02131 EM Incondng
+228 Jun 26 02:34 PM N PALM RCH, PL
+Jun 26 02:35 IM N PALM BCH, PL
+230
+Jun 26 00:35 PM N FALM BCH ,PL
+231 Jun 26 02:40 PM Inconing
+232
+Jun 26 03:14 PM Inconing
+Jun
+03:41 PM W FALK BCH ,PL
+03.54 PM Incondng
+235
+04:23 PM N PALM BO, PL
+236
+Jun
+05:25 PM Incoring
+237
+Jun 26 06:00 PM Inconing
+Jun
+06:33 AM A PALM BC,PI.
+Jun 27 06:34 AM N PALM BCH, PL
+240
+Jun 27 07:04 AM N PALM BCH, PL
+241
+Jun 27 07:13 AM Incondug
+Jun 27 07:43 AM N FAEN BCH, PL
+243
+Jun 27 11:32 AM Incoring
+Jun 27 12:14 PM Inconing
+Jun 27
+12:23 PM Inconing
+248
+0E:0O IN N FALM BCH .PL
+Number
+561-503-5930
+561-541-4051
+PD/PU
+561-281-3614 FF/FU
+561-616-4240 FP
+561-062-EEEE FP
+561-662-6688
+954-295-6132
+De /FU
+561-616-4240 0P/PU
+354-295-6112
+561-502-6713 OF
+954-295-6132
+5E1-502-E713 DE/FU
+561-333-7530 0D/PU
+541-759-3696 OF
+561-502-6713 08/PU
+5E1-E1E-824D
+561-502-5212
+561-541-5449 0P
+561-141-344908
+561-502-5212
+561-723-3440 CE/FU
+561-502-5212
+561-102-6713
+De /Fu
+561-502-6713 0D/NN/PU
+561-616-4246
+GE /NN/FU
+561-616-9240
+954-295-6132
+561-662-6698
+561-502-67130P
+561-662-ECEE OF/FU
+561-712-9018 0P
+561-502-5212
+561-723-3440
+561-102-1212
+CE /FU
+561-502-5212
+De /FU
+561-502-5212 OP
+561-662-6C88 C0/FU
+541-832-2676 00
+561-541-5449 0F
+561-541-5449
+01_05.171
+no detr
+Min: Sec
+1,00
+1:00
+1100
+1,00
+1:00
+3:00
+1100
+35:00
+$:0D
+5:00
+1:0D
+2:00
+10:00
+1,00
+1:0D
+1:00
+1,00
+1:0D
+2:00
+1,00
+1:00|
+2:00
+4: 0D
+1,00
+2:00
+1:00
+1,00
+1:00
+$:0D
+8: 00
+2:0D
+Usage
+0.00|
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+0.0D
+D.DD
+D. DD
+D.DD
+D. DD
+Charges
+D.0D
+0,00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+(561) 723-3440 continued...
+Telecommunications Services Call Detail (561) 723-3440
+See
+Number
+Footnote
+Item # Date Time Call To
+247 Jun 27 08I16 PM Inconing
+245 Jun 24 06:46 AM Incoming
+240 Jun 24 08:10 AN Inconleg
+250 Jun 24 08127 AM M BALK BCH, PG|
+251 Jun 20 00:2010 Inconta
+252 Jun. 24 08:49 AM BOYTONBCH, PL
+253 Jun 24 12:18 IN IncomiNg
+254 Jun 24 05/01 EN Inconing
+255 Jut 24 07:11 # Incoeleg
+256 Jun 24 09:55 PM M BALE BCH, PL
+257 Jun 29 07,39 AM POMPANCECH, PL
+258 JUR 29 DE:10 AM ITARD, PL
+259 Jun. 29 09:22 AM Inconing
+260 Jun 29 09:24 AM PILAUDERDL, PL
+281 Jun 29 09:42 AN Inconing
+282 Ju 27 10:20 Iscoeleg
+263 Jun. 29 10:21 JM Incoming
+284 Jun 29 10,49 AM N PALA BCH, PL
+205лш 29 10:50 N M PALE BCH, FL
+205 Jun 29 11:03 JM Inconieg
+287 Jun 29 12:09 AM M PALE BCH, PL
+288 Jun 29 11,52 AM Incoming
+200 Jun 29 12:04 IN INCORleT
+270 Jun 29 12:17 PM Inconiet
+271 Jun 29 02:20 PM M PALE BCH, PL
+272 Jun 29 02:46 PM Inconing
+273 Jun. 29 02:57 PM Inconley
+274 Jun 29 05:21 EN Incoming
+275 Jun 29 05140 PM POMPANCECH, PL
+276 J 29 DE:36 IN M PALE BCH, FL
+Jun 29 08:38 IM Incoming
+278 Jun 30 07:54 2М Іконікт
+279 Jun 30 08:10 2M Inconing
+200 10 00:35 лн 100l09
+281 Jum 30 08:55 1М Ікопіт
+282 Jun 30 09,51 AN M BALA BCH, FL
+263 Jun 30 11:36 AM M PALE BCH, FL
+284 Jun 30 02:20 # Іксовіет
+265 Jum 30 03:20 М Інопіт
+268 Ju 34 03,46 PM Inconleg
+561-502-5212
+8
+561-662-6688
+8
+561-541-5449 PP
+561-662-6688 PP/FU
+561-662-66E8 FF
+561-599-2416 p/0
+561-502-6713 FF
+561-616-8240 PP
+Unava 11 able
+=
+561-502-6713 OP/FU
+954-942-5959 PP/PU
+954-295-6132 PP/SU
+954-295-6132 19
+954-295-6132
+561-478-4188
+561-827-2542
+561-827-2542
+561-616-8240
+561-502-6713
+PP /FU
+615-324-2054
+561-502-6713 PP/FU
+561-662-6688
+561-662-66E8
+561-662-6688 PP
+561-502-6713 PP/FU
+954-295-6132
+561-502-6713
+561-616-8240
+954-942-5959
+561-502-6713
+FF/FU
+561-502-6713
+561-742-6000
+561-502-7753
+561-478-4188 PP
+561-503-5930 PP
+561-352-7000
+PP/FU
+561-EG2-EGEE FP/FU
+561-662-6813
+561-616-8240
+561-827-2542
+BETTE SAN
+Min:Sec
+4:00
+1100
+1:00
+2:00
+4:00
+1:00
+1:00
+1:00
+1:00
+2:00
+2:00
+1:00
+3,00
+1:00
+3:00
+6: 00
+2:00
+4:00
+1:00
+1:00
+2:00
+1:00
+3,00
+1:00
+2:00
+2:00
+3: 00
+3:00
+1.00
+1: 0a
+1:00
+2:00
+1:00
+1:00
+1:00
+2:00
+Usage
+4.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.D0|
+п nn
+corticued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+9.00
+Account number 747607414
+(561) 723-3440 continued...
+Telecommunications Services Call Detail (561) 723-3440
+See
+Footnote
+Item # Date Time CallTo
+288 Jun 30 04:30 FM Incordng
+289 Jun 30 05:46 IM Inconing
+290 Jun 30 05:48 PM W FALK RCH,PL
+21 Jul 01 04:09 AM N PALM BCH ,PL
+292 Jul 01 08:42 AM N RADA BCH, PL
+293 Jul 01 08:53 AM N PALM BCH, PL
+24 Jul 01 09:03 AM Inconing
+295 Jul 01 10.31 AM Incondng
+296 Jul 01 03:15 PM Inconleg
+297 Jul 01 04:26 FM N FACE BCH, PL
+208 Jul 01 05:14 PM W PALA BCH,PL
+290 Jul 01 05:32 PM Inconing
+300 Jul 01 05:34 IM Inconing
+301 Jul 01 07:27 PM Inconing
+Jul 01 09:24 PM W PALM BCH, PL
+Jul 02 08:25 AM N PALM BOH, PL
+Jul
+g
+08:26 AM W PALA BCH ,PL
+09.02 AM BOYTONBCH, PL
+306
+Jul
+10:34 AM IncoRing
+307
+Jul
+g
+10:37 AM Inconing
+308 Jul 02 11:17 M Inconing
+300 Jul 02 11:41 AM Inconing
+310 Jul 02 12:14 PM Inconlag
+311 Jul 02 12:27 IM BOYTONECH, PL
+312
+Jul
+g
+12:34 PM Inconing
+313
+Jul 02
+01.25 PM Inconing
+314 Jul 02 01:39 PM Inconing
+315
+Jul
+01:40 PM Inconing
+318
+Jul
+01:42 PM Incondng
+317
+Jul
+0=
+02:57 PM Inconleg
+318
+Jul
+03:31 IM W PALM BCH,PL
+318 Jul 02 03:31 PM N PALM BCH,PL
+Jul
+03:41 PM Incondng
+321 Jul 02 03:54 PM Inconleg
+Jul 02 04:10 PM Inconing
+373
+Jul 02
+04:37 PM Incordug
+324 Jul 02 05:11 IM N PALM BCH, PL
+Jul 02 05:16 IN Incoring
+Jul 02
+05:45 PM Inconing
+Jul 02
+06:21 PM Incordug
+328
+DE:ES PM POMPANDOCH PL
+Number
+954-295-6132
+561-502-6713
+561-502-6713 FF/FU
+561-842-6414 PP/PU
+561-102-6713 FF/FU
+561-502-6713 PD/PU
+561-502-6713 FP
+561-474-4148 PP
+5E1-141-2839
+561-644-1514 FP/FU
+561-644-1518 PP/PU
+SEL-ELE-8240 FP
+561-662-6688 PP
+954-295-6132 FP
+561-502-6713 OP/PU
+5E1-302-6713 FD/FU
+561-616-4240 PD/PU
+561-503-8429 PP/PU
+561-478-4188 FP
+561-476-418800
+561-541-2839 FF
+561-942-2050
+561-103-8429 FP
+561-503-8429 PD/PU
+561-503-4429 FP
+561-662-6658 PP
+561-616-8240
+561-616-4240
+561-662-5699
+561-103-8428
+561-502-6713 PD/PU
+561-616-4240 FF/PU
+561-541-5449 Pe
+561-101-8429
+561-662-6C4
+561-502-7753
+561-502-4713 FD/FU
+561-502-6713
+561-662-6648
+561-964-5511
+SE-SIS_DES
+Fp /FU
+Min: Sec
++: 00
+1:00
+2100
+2:00
+1:00
+2:00
+1:0D
+Usage
+1,00
+1:0D
+1:00
+4: 0D
+2,00
+1:0D
+2:00
+1,00
+2:00
+2100
+1: 0D
+1:00
+2100
+1:00
+2:00
+1:00
+1:00
+1,00
+1,00
+1:0D
+1:00
+1:00
+2:0D
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+0.0D
+D.DD
+D. DD
+D.DD
+D. DD
+D.DD
+Charges
+D.0D
+0,00
+0,00
+0.0D
+0.0D
+0.0D
+0.0D
+
+
+
+(561) 723-3440 continued...
+Telecommunications Services Call Detail (561) 723-3440
+See
+Number
+Footnote
+Item # Date Time Call To
+329 Jal 02 07:44 EN Inconing
+330 Jи] 03 08:30 3М M PALA BCH, PL
+331 Jul 03 D8132 AN M PALK BCH, PL
+332 Jul 04 05,38 EM Inconing
+333ли] 04 07:17 m Inconley
+334 Jul 04 07:22 IN M PALA BCH, PL
+335 Jul 05 08:41 AN IncOmiNg
+338 Jul 05 10:04 JM Inconing
+337 Jul 05 11:47 J M BALE BCH, VL
+336 Jul 05 11:48 AM Inconleg
+330 Jul 05 12,53 AM M PALA BCH,PL
+340 Jul 05 02:58 W Iscoeleg
+341 Jul 05 03:20 IM Inconieg
+342 Jul 05 05:36 IN M BALE BCH, PL
+343 Jul 06 09.31 3N Inconing
+344 Jul ок 10:16 ли Iscceleg
+345 Jul o6 10:18 JM Incoming
+348 Ju1 06 10,22 A M PAL BCH, PL
+347 Jul 0€ 10:55 N M PALE BCH, FL
+345 Jul 06 11:46 AM Incoming
+349 Jul 06 12:01 PM Inconleg
+350 Jul 06 12,30 IN M PALE BCH, FL
+352 Jul 06 08:48 PM Inconiet
+353 Jul 07 08:42 AN Incoming
+354 Jul 07 08151 2M Inconleg
+355 Jul 07 09:48 AM M PALE BCH, PL
+356 Jul 07 09:49 JM M PALE BCH, PL
+357 Ja] 07 09,52 AM Inconleg
+359 Jul 07 10:46 AM 5 PALE BCH, PL
+360 ли] 07 16:56 АМ ВОУТОНЕСН, Р
+381 Jul 07 11:16 2N Inconing
+382 Jal 07 11:17 AN 1 PALE BCH, PL
+363 Jи] 07 13:20 мм Іковіт
+384 Jul 07 11/26 3N Inconing
+385110711:49 ALECL
+305 Jul 67 11:50 AM M PALA BCH,PL
+388 Jal 07 12,15 PM BAL BC,PL
+309 Jul 07 12:36 IN IncoRleg
+561-503-5930
+561-723-1440
+OP/PU
+561-662-6688
+561-502-7753 OP
+561-502-6713 OF
+561-505-6219
+561-502-6713 PP
+561-616-8240 PP
+561-502-6713 PP/FU
+561-502-6713 FF
+561-719-9544 PP/PU
+unavallahle PP
+561-616-824019
+SEI-EER-EERA PRISO
+561-662-6688
+561-502-6713
+561-577-4416
+561-662-6688
+561-842-6414
+561-627-8887
+561-662-6688
+561-502-6713
+561-502-6713
+561-502-6713 PP
+561-478-4168
+561-478-4188
+561-842-6414
+561-842-6416
+pP/FU
+PP/PU
+P/PO
+PP/FU
+561-478-4188
+5E1-61E-6240
+561-662-6688
+561-503-8429
+561-503-5930
+561-827-2542
+561-712-9018
+561-662-6688
+561-627-88E7
+561-662-6688
+561-352-7000
+561-616-8240
+PP/FU
+PR/FU
+p/PO
+PP/FU
+PP/FU
+Min:Sec
+1,00
+1:00
+1100
+2:00
+1:00
+2:00
+1:00
+1:00
+1:00
+1:00
+2:00
+1:00
+8:00
+2:00
+1:00
+3:00
+2:00
+1:00
+1,00
+3,00
+1:00
+2:00
+1:00
+1:00
+1:00
+3:00
+1 =0g
+6:00
+1:00
+1:00
+2:00
+1:00
+1:00
+Tonn
+Usage
+4.00
+• DE
+0.0D
+$.00
+•.5E
+4.00
+0.0D
+0.0D
+0.0D
+0.0D
+$.5B
+• 0[
+0.0D
+•.00
+9,00
+$.00
+0.0D
+0.0D
+•.00
+0.0D
+•.00
+- •r
+•.00
+$.00
+Long
+Distance
+D.D0
+D.D0
+D.DD
+D .00
+D.DD
+0. 00
+D.DD
+0.00|
+D.D0
+D.DD
+0,00
+D.D0
+• DO
+• on
+0.00 |
+n an
+corticued.
+Total
+Charges
+9.00
+a.00
+9.00
+9.00
+9.00
+9.00
+9.00
+g.00
+d.00
+9.00
+g,00
+9.00
+9.00
+d.00
+9.00
+9.00
+a.0c
+9.00
+Account number 747607414
+(561) 723-3440 continued...
+Telecommunications Services Call Detail (561) 723-3440
+See
+Footnote
+Item # Date Time CallTo
+370 Jul 07 12:40 PM Incordng
+371 Jul 07 01:32 IM N PALM BCH, PL
+372 Jul 07 01:46 PM Inconing
+373 Jul 07 02:03 EM Inconing
+374 Jul 07 02:16 PM N FALA BCH, PL
+375 Jul 07 08:44 W Incoring
+376 Jul 08 09:04 AM Inconing
+377 Jul 08 10:32 AM Incondng
+378 Jul De 10:68 AM Inconing
+379 Jul 08 01:03 PM Inconing
+380 Jul 08 02:10 PM W PALM BCH,PL
+381 Jul De 05:01 PM Inconing
+32 Jul 08 05:21 IM Inconing
+383 Jul 08 05:24 PM W FALK BCH, PL
+384 Jul 08 05:34 PM W PALM BCH, PL
+Jul 0a 05:39 PM A FALA RCH,PL
+Jul
+05:55 # Inconing
+Jul 08 06.22 EM W PAIM BCH.PL
+388
+389
+Jul
+07:47 IM Inconing
+300 Jul 08 08:39 PM Inconing
+301 Jul 09 09:24 AM Incordng
+382 Jul 03 08:30 AM N FALA RCH, PL
+383 Jul 09 08:42 AM Incoring
+Jul 09 09:44 AM Inconing
+305 Jul 09 09.17 AM Inconing
+390 Jul 09 09:19 AM N PALM BCH,PL
+397
+Jul
+01:17 PM Inconing
+398 Jul 09
+01:37 EM Incondng
+300
+Jul
+01:38 PM Inconing
+Jul
+02:59 IM W PALA BCH,PL
+401 Jul 09 03:00 PM Inconing
+402
+Jul
+05:31 PM W PALM BCH.PL
+Jul 09
+06:30 PM W FALK BCH,PL
+405
+Jul
+07:04 AM Incondug
+406 Jul 10 07:16 AM FAL CHUL
+Jul 1007:22 AM W PALM BCH.PL
+408 Jul
+07:56 AM N PALM BCH,PL
+Jul 10 08:20 AM Incondng
+410 Jul
+C4:28 AM N FALM BCH .PL
+Number
+561-662-6698
+561-723-3440 PD/PU
+561-662-6648 FP
+561-842-6414 PP
+561-662-6EEE FF/FU
+561-502-6713 PD
+UnavaIlable
+561-577-4416 PP
+5E1-502-6713 FF
+S61-502-6713 FP
+561-662-6C88 PP/PU
+SE1-502-E713 FP
+561-255-1776 PP
+561-662-6668 FF/FU
+561-502-6713 PP/PU
+5E1-302-6713 FD/FU
+561-662-6688
+561-255-1776
+pP/pu
+561-255-177E FF/FU
+561-616-8240 00
+561-792-1947 FF
+561-616-4240
+561-616-8240
+Fe /Fu
+561-255-1776P0
+561-255-1776 FP
+561-616-4240 PP
+561-616-8240
+PD/PU
+561-255-1776 FF
+561-502-6713 PP
+561-102-6713 FP
+561-502-6713 PD/PU
+561-616-4240 FF/CH
+561-662-6688 PP/PU
+561-616-8240 FP
+561-616-4240 FF/FU
+561-442-2050 0P
+561-333-7530 C0/FU
+561-333-7530 00/PU
+561-333-7538 0E/FU
+561-616-42400P
+op /FU
+Min: Sec
++:00
+1:00
+1100
+3: 0D
+3:00
+1:00
+2100
++:00
+1:0D
+10:00
+1,00
+3: 0D
+4: 00
+2:00
+2,00
+3:00
+1,00
+1:00
+2:00
+1,00
+3: 00
+1:00
+4: 00
+2:00
+7:00
+2:00
+4: 0D
+Usage
+Long
+Distance
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.DD
+D.0D
+D.DD
+0.0D
+D.0D
+D.DD
+D.DD
+D.DD
+D.DD
+D.D0
+D.DD
+D.0D
+D.0D
+D.DD
+D. DD
+D.DD
+D. DD
+D.DD
+Charges
+D.0D
+0,00
+0,00
+0.0D
+0.0D
+0.0D
+
+
+(561) 723-3440 continued...
+Telecommunications Services Call Detail (561) 723-3440
+See
+Footnote
+Item # Date Time Call To
+411 Jul 14 11:12 JM Inconing
+412 Jul 10 11:13 AM BOYTONBCH, PL
+413 Jul 14 12:00 IN Inconleg
+414 Jul 10 12:08 PM M BALK BCH, PG|
+415 Ju) 10 12:16 и воУтоваси, L.
+416 Jul 10 02:45 IN • PALE BCH, PL
+417 Jul 10 03:20 PM M BALK BCH, PL
+418 Jul 10 04:26 EN Inconing
+419 Jul 10 05:59 IN Incoeleg
+420 Jul 10 07:23 PM M PALK BCH, PL
+421 Jul 10 07/27 EN Inconing
+422 Jul 10 07:28 IN M PALE BCH, FL
+TOTAL
+Number
+561-333-7530
+561-503-8429
+OP/PU
+561-502-6713
+561-662-6688
+OP/PU
+561-503-8429 OF/FU
+561-665-66RA
+OP/PU
+561-844-1735 OP/FU
+561-616-8240 OP
+954-295-6132
+561-502-6713 OP/FU
+561-502-6713 OP
+561-502-6713 OP/SU
+Min:Sec
+1:00
+1.00
+2:00
+1:00
+4:00
+1100
+1100
+1:00
+1:00
+1,00
+1:00
+872-00
+Footnote
+Features
+Networks
+Services
+Usage
+4.00
+$.00
+Distance
+D.D0
+D.D0
+D.00
+$0.c0
+Time Period
+PP.Peak Period
+MP-Muliple Period
+DS-Dialup Service
+TJ-Tuana Network
+Total
+Charges
+9.00
+2.00
+9.00
+40.c0
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/010521b739bf4a4abf23b36ea1e7aa207ebe5975a6606aa653160b2c9d2f2f99.receipt.json b/vision-fixhub/ds9-unparsed-06/010521b739bf4a4abf23b36ea1e7aa207ebe5975a6606aa653160b2c9d2f2f99.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..da8a252f496e587d0d37f6f4526dbba667fae285
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/010521b739bf4a4abf23b36ea1e7aa207ebe5975a6606aa653160b2c9d2f2f99.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -57289,
+  "dataset": "marble-joined",
+  "doc_id": "010521b739bf4a4abf23b36ea1e7aa207ebe5975a6606aa653160b2c9d2f2f99",
+  "engine": "marble-apple-vision",
+  "event_count": 117,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "68ffea455da69f316dba421e1b99bf4fc3df09bdf5fada915915837930da990f",
+  "output_sha256": "549f53ca14a3189c0adef1774f04a1c91737b618dde3d3db3b5036c4d14ce1f5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/010e510a41c5417dcc1ea7effed6470b1db7333f805db7dca3b5ca84dab97b62.md b/vision-fixhub/ds9-unparsed-06/010e510a41c5417dcc1ea7effed6470b1db7333f805db7dca3b5ca84dab97b62.md
new file mode 100644
index 0000000000000000000000000000000000000000..e82c166b400810953aa9563484d001f7f60e959f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/010e510a41c5417dcc1ea7effed6470b1db7333f805db7dca3b5ca84dab97b62.md
@@ -0,0 +1,41 @@
+LAW OFFICES OF
+GERALD B. LEFCOURT, P.C.
+A PROFESSIONAL CORPORATION
+NEW YORK, NEW YORK 10021
+GERALD B. LEFCOURT
+SHERYL E- REICH
+RENATO C. STABILE
+FAITH A. FRIEDMAN
+VIA E-MAIL
+Deputy Chief, Northern Region
+Office of the United States Attorney
+Southern District of Florida
+May 22, 2007
+Jeffrey Epstein
+Dear Mr. Lourie:
+I write as counsel to Jeffrey Epstein, the subject of a grand jury investigation being
+conducted by your office.
+I understand from you that in the next month or two a decision will be made by your
+to meet with you.
+Additionally, because we believe that any decision to indict requires both a complex legal
+analysis in a detailed factual context and resolution of significant policy concerns, if our meeting
+does not resolve the matter, we would like an opportunity to make a presentation first to
+Chief of the Criminal Division, and J
+• First Assistant United States
+Attorney, and then, again, if no resolution is reached, the opportunity to meet with United States
+
+
+LAW OFFICES OF
+GERALD B. LEFcoURt, P.C.
+Deputy Chief, Northern Region
+Office of the United States Attorney
+_Southern District of Florida
+May 22, 2007
+Page 2
+Attorney Alexander Acosta.
+Thank you for your cooperation in this matter. If you have any questions, please do not
+hesitate to call.
+Very truly yours,
+Gerald B. Lefcourt
+cc:
+Lilly Ann Sanchez, Esq.
diff --git a/vision-fixhub/ds9-unparsed-06/010e510a41c5417dcc1ea7effed6470b1db7333f805db7dca3b5ca84dab97b62.receipt.json b/vision-fixhub/ds9-unparsed-06/010e510a41c5417dcc1ea7effed6470b1db7333f805db7dca3b5ca84dab97b62.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..5c1fa7c300dfe4ebb1f824280310c0c2e83a36f2
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/010e510a41c5417dcc1ea7effed6470b1db7333f805db7dca3b5ca84dab97b62.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "010e510a41c5417dcc1ea7effed6470b1db7333f805db7dca3b5ca84dab97b62",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "a4de0b34ece01325aef052bdd1eac8cd8f08ebae9d9df7e2e23d13147c41a130",
+  "output_sha256": "4c509c93f3260c20a8217db811da9a83812b414944d98e980d0d1dace71b4a7d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/01475d3658004784efbe20cc5db01ad1a86720f1fe566b16d4c6d4a253696702.md b/vision-fixhub/ds9-unparsed-06/01475d3658004784efbe20cc5db01ad1a86720f1fe566b16d4c6d4a253696702.md
new file mode 100644
index 0000000000000000000000000000000000000000..194a3af9992acd11e9cba0d95d8a9e02390fedea
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/01475d3658004784efbe20cc5db01ad1a86720f1fe566b16d4c6d4a253696702.md
@@ -0,0 +1,44 @@
+From:
+To:
+Subject: Activity in Case 9:08-cv-80893-KAM Doe v. Epstein Motion in Limine
+Date: Mon, 05 Jul 2010 17:18:29 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. Distriet Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Pike, Michael on 7/5/2010 at 1:18 PM EDT and filed on 7/5/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 199
+Doe v. Epstein
+9:08-cv-80893-KAM
+Jeffrey Epstein
+Docket Text:
+Defendant's MOTION in Limine to Exclude Certain Testimony and Opinions of Jane Doe's
+Expert Witness by Jeffrey Epstein. (Pike, Michael)
+9:08-cv-80893-KAM Notice has been electronically mailed to:
+Bradley James Edwards
+Jack Alan Goldberger
+Katherine Warthen Ezell
+Michael James Pike
+Paul G. Cassell
+Robert Deweese Critton, Jr
+9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+The following documents) are associated with this transaction:
+
+
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=7/5/2010] [FileNumber=7754557-0]
+[5b97cfbeb76252b6e220410ea6332331d12ace4403b8a885411a690681f01caf4b2a
+3af6dfd778e6cb600571f812190еебeb4d65aedaed81575b58dl1354c46f]]
diff --git a/vision-fixhub/ds9-unparsed-06/01475d3658004784efbe20cc5db01ad1a86720f1fe566b16d4c6d4a253696702.receipt.json b/vision-fixhub/ds9-unparsed-06/01475d3658004784efbe20cc5db01ad1a86720f1fe566b16d4c6d4a253696702.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ef9077a6dbe47f89bc154e9471d7ef2a83fdbfb8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/01475d3658004784efbe20cc5db01ad1a86720f1fe566b16d4c6d4a253696702.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "01475d3658004784efbe20cc5db01ad1a86720f1fe566b16d4c6d4a253696702",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "09d4ed1b7223287920b35a5aa139245abf35f6d196b1b54e5d7628c748144c26",
+  "output_sha256": "01c0071d8d3bc300ab3a5d515df8d3f9a231365ea3c187ef98e7fdae1a0beda5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0259af64b14e25f665acd5cd56773c28bafa8ec1d8299c74f2ee3c3160af03b9.md b/vision-fixhub/ds9-unparsed-06/0259af64b14e25f665acd5cd56773c28bafa8ec1d8299c74f2ee3c3160af03b9.md
new file mode 100644
index 0000000000000000000000000000000000000000..5b71ac20b8cdfdcf963b4d2f1124b7a48bc59cc9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0259af64b14e25f665acd5cd56773c28bafa8ec1d8299c74f2ee3c3160af03b9.md
@@ -0,0 +1,156 @@
+From:
+To: "
+(USAFLS)" _
+(USAFLS)" ≤
+(USAFLS)" <
+- (USAFLS)"
+(USAFLS)" S
+(USAFLS)"
+Cc: "
+(USAFLS)" ≤
+<2
+P, at 2: <00.p.m.@hp-
+s0-71-2.usa.doj.gov»;
+Subject: RE: Jane Does 1 and 2 | United States - Hearing on Friday, August 12, 2011, at 2:00 p.m.
+Date: Tue, 16 Aug 2011 20:59:37 +0000
+Importance: Normal
+Thanks for the update,
+From:
+(USAFLS)
+Sent: Tuesday, August 16, 2011 9:39 AM
+To:
+• (USAFLS);
+Cc:
+.. (USAFLS);
+(USAFLS); I
+(USAFLS);
+I (USAFLS)
+Subject: RE: Jane Does 1 and 2 | United States - Hearing on Friday, August 12, 2011, at 2:00 p.m.
+(USAFLS)
+The hearing last 2.5 hours. Judge Marra first heard from the proposed intervenors, Bruce Reinhart and Roy Black. Bruce
+seeks to intervene to move for sanctions against the victims' attorneys for making baseless allegations against Reinhart for
+purported violations of DOJ and Florida Bar rules. Black seeks to intervene to prevent the unsealing and use of Epstein's
+defense attorneys' work product, as referenced in the series of one-sided e-mails provided to the victims' attorneys in the
+civil litigation against Epstein. Judge Marra gave Black and the government two weeks to submit additional briefing on
+the issue, with an opportunity for the victims to respond. Marra questioned how a matter could still be protected
+attorney work-product if it had been revealed to the government, the opposing side, in the Epstein criminal
+investigation. Black argued that criminal defense attorneys should be allowed to be candid and frank with prosecutors,
+free from any fear that their thoughts and impressions will be made public at some future time.
+The court denied the victims' motion to accept facts. Judge Marra said the victims had not denominated their motion as
+one for summary judgment, recognized that many of the alleged "facts" were opinions and conclusions, and said it was
+unfair to make the government stipulate or disagree with those "facts." The Court heard argument on the motion to
+compel the government to provide relevant information helpful to their case, and the motion for a finding that the CVRA
+had been violated.
+During our portion of the argument, I emphasized section 3771(d)(6)'s admonition that "Injothing in this chapter shall be
+construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction." I suggested
+that, if the court was faced with two possible interpretations of a provision, and one would impair the A/G's prosecutorial
+discretion and one would not, the court was obligated to choose the one that would not.
+Judge Marra was skeptical that applying 3771(a)(5), the right to reasonably consult with the attorney for the government
+in the case, would really impair prosecutorial discretion. At one point, he stated that, if the government had consulted
+with the victims prior to entering into the non-prosecution agreement, while the victims may not have agreed with that
+course of action, there was nothing they could do. He asked how that would impair prosecutorial discretion. I argued
+that U.S. Attorney's Offices decline prosecutions frequently, and that construing 3771(a)(5) to apply prior to the filing of a
+formal charge, would require the government to consult with identified victims prior to declining a case for prosecution.
+Additionally, I expressed pessimism that victims would not try to seek court intervention in the event an unfavorable
+decision had been made by the U.S. Attorney's Office.
+
+
+The Court inquired about an evidentiary hearing. I told the Court that the government had asserted a 'best efforts"
+defense, and that the resolution of that issue would require an evidentiary hearing. On the issue of discovery, the Court
+asked me if it had the authority to permit discovery. I said yes, if the court believed discovery was necessary to resolve
+disputed factual issues in the case.
+I do not expect the court to rule until the round of briefing on the work-product issue is completed. I have included
+and
+Con this e-mail. They both attended the hearing and I welcome any comments they might want to add.
+From:
+- (USAFLS)
+Sent: Tuesday, August 16, 2011 9:02 AM
+I (USAFLS);
+(USAFLS);
+(USAFLS);
+Subject: RE: Jane Does 1 and 2 |. United States - Hearing on Friday, August 12, 2011, at 2:00 p.m.
+What happened at the hearing?
+From:
+(USAFLS)
+Sent: Friday, August 12, 2011 9:16 AM
+To:
+_ (USAFLS);
+(USAFLS);
+(USAFLS);
+.. (USAFLS)
+Cc:
+(USAFLS);
+(USAFLS);
+(USAFLS)
+Subject: RE: Jane Does 1 and 2 . United States - Hearing on Friday, August 12, 2011, at 2:00 p.m.
+Good luck. Let me know what happens after the hearing. Sure to get press calls.
+(USAFLS)
+(USAFLS);
+From:
+1. (USAFLS)
+Sent: Friday, August 12, 2011 9:07 AM
+To:
+(USAFLS);
+(USAFLS);
+• (USAFLS);
+subject: Re: Jane Does 1 and 2 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m.
+Best of luck,
+We're in good hands with you there. Thanks for all your hard work in this difficult matter.
+(USAFLS)
+From:
+(USAFLS)
+Sent: Friday, August 12, 2011 12:06 AM
+To:
+Subject: Re: Jane Does 1 and 2 United States - Hearing on Fiday, August 12, 2021, at 2.00 p.m.
+• (USAFLS)
+I agree that we should go forward with our best efforts defense, at least at this point.
+Good luck tomorrow,
+any evidentiary hearing.
+Hopefully, the judge will realize that he never needs to get to the best efforts defense or to
+From:
+(USAFLS)
+Sent: Thursday, August 11, 2011 07:38 PM
+To:
+• (USAFLS);
+• (USAFLS);
+Cc:
+(USAFLS)
+(USAFLS);
+(USAFLS);
+(USAFLS);
+(USAFLS)
+Subject: Jane Does 1 and 2 I. United States - Hearing on Friday, August 12, 2011, at 2:00 p.m.
+
+
+Colleagues,
+Judge Marra will be holding a hearing tomorrow, August 12, at 2:00 p.m., on the victims four (4) motions. In
+the court's order, he stated he would be asking for the parties' positions on whether an evidentiary hearing is
+necessary. For our part, on the legal issue of whether rights under the Crime Victims Rights Act attached prior
+to the filing of a formal charge, the government does not believe any evidentiary hearing is necessary. The only
+two facts which are relevant are not disputed by the victims: (1) no formal charge was ever filed against Epstein
+in the S.D.Fla.; and (2) Epstein entered pleas of guilty to state charges on June 30, 2008, in Palm Beach County
+Circuit Court.
+If the court were to find that CVRA rights did attach in the absence of a formal charge against Epstein, the
+government has asserted that it used its "best efforts" to comply with the CVRA. In October 2007, after the
+non-prosecution agreement was signed, FBI agents met with four victims and advised them of the agreement.
+There is a dispute over what was told to these individuals, and the reasons why notifications to other victims
+did not occur. The victims also claim that CVRA letters sent to them by the FBI in January 2008 and May 2008
+were deceptive, since an agreement with Epstein had already been reached (although not fully approved by
+Main Justice).
+I believe an evidentiary hearing would be necessary for the government to present its "best efforts" defense.
+This would involve the government calling witnesses, including
+o, the FBI agents, and other current and
+former DOJ employees with relevant knowledge of our efforts to comply with the CVRA.
+We need to decide whether to maintain our best efforts defense, since it exposes us to an opportunity for the
+victims to probe what we did, and why we did it, and provide a platform for making us look bad. One
+consideration is whether our chances of prevailing, e.g. convincing the Court that we did use our best efforts, is
+sufficiently great to justify the effort and ordeal.
+I believe we should go forward with our best efforts defense. Our office did its best to ensure the victims
+were apprised of events in the matter involving Epstein, despite howls of protest coming from Epstein's
+attorneys. Our office had to walk a narrow path between perceived CVRA responsibilities, the incessant
+complaining from Epstein's legal camp, and preserving what might still have been a federal prosecution of
+Epstein had he gotten the agreement overturned at DOJ, or reneged on it completely. Giving up on the best
+efforts defense would be conceding too much.
+: We will call you tomorrow after the hearing, to let you know about what went on, and the press
+coverage.
+I will be leaving here at 9:00 a.m. and hope to be at the West Palm Beach office by 11:00 a.m. Thanks.
diff --git a/vision-fixhub/ds9-unparsed-06/0259af64b14e25f665acd5cd56773c28bafa8ec1d8299c74f2ee3c3160af03b9.receipt.json b/vision-fixhub/ds9-unparsed-06/0259af64b14e25f665acd5cd56773c28bafa8ec1d8299c74f2ee3c3160af03b9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d6e477263a57061fbc8c1898f3e5b3abecd34659
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0259af64b14e25f665acd5cd56773c28bafa8ec1d8299c74f2ee3c3160af03b9.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "0259af64b14e25f665acd5cd56773c28bafa8ec1d8299c74f2ee3c3160af03b9",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "c8d8314d27318ccf33986167b1de52f72629d6b81b89d8719b60368070779b45",
+  "output_sha256": "a7c2b2a719711d6817098af9f1effb14e6c2322215cabcb37c57c54176bb79b1",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0310c62a21c3488a03a0d778a9c58ba33ca64542d29c69bffaf279266b886316.md b/vision-fixhub/ds9-unparsed-06/0310c62a21c3488a03a0d778a9c58ba33ca64542d29c69bffaf279266b886316.md
new file mode 100644
index 0000000000000000000000000000000000000000..fd7b559d75872a31dd55ca484e862da6b492122b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0310c62a21c3488a03a0d778a9c58ba33ca64542d29c69bffaf279266b886316.md
@@ -0,0 +1,1044 @@
+Entered on FLSD Docket 05/03/2011 Page 1 of 31
+ATTACHMENT TO MOTION
+TO INTERVENE OR IN THE
+ALTERNATIVE FOR A SUA
+SPONTE RULE 11 ORDER
+
+
+Entered on FLSD Docket 05/03/2011 Page 2 of 31
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-Civ-Marra/Johnson
+JANE DOE #1 AND JANE DOE #2,
+Plaintiffs,
+V.
+UNITED STATES OF AMERICA,
+Defendant.
+BRUCE E. REINHART,
+Intervenor
+/
+INTERVENOR'S MOTION FOR SANCTIONS
+Comes now, Bruce E. Reinhart, intervenor and party in interest (hereinafter
+"Movant"), and moves this Honorable Court to impose sanctions under Federal Rule of
+Civil Procedure 11(b) and 28 U.S.C. 1927 based on intentional or reckless false, bad
+faith, vexatious factual and legal assertions made about Movant in Paragraphs 52 and 53
+of Plaintiff's Motion for Finding of Violations of the Crime Victims' Rights Act (the
+"Motion") [DE 48].
+BACKGROUND
+The instant cause of action involves claims by Plaintiffs that Defendant violated
+the Crime Victims Rights Act (CVRA), 18 U.S.C. §3771, in its handling of a criminal
+investigation of Jeffrey Epstein ("Epstein") and others. The investigation ultimately
+resulted in a non-prosecution agreement between the United States and Epstein. On
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 3 of 31
+March 21, 2011, Plaintiffs filed their Motion.' Numbered paragraphs 1-50 of the Motion
+are a chronological review of the background of the Epstein investigation, including the
+interactions among the victims' counsel, counsel for Epstein, the Government and the
+FBI. Paragraph 51 asserts that at all relevant times it was feasible for the Government to
+provide certain notifications to Plaintiffs.
+Without attempting to make any connection to the asserted violation of the
+CVRA, Paragraphs 52 and 53 falsely allege that Movant violated Florida Bar rules and
+Department of Justice regulations by representing Epstein's employees in civil litigation
+after Movant retired from the United States Attorney's Office for the Southern District of
+Florida ("Office"). They also falsely allege that Movant, while still employed by the
+Office engaged in improper conduct relating to Epstein. These allegations are made in
+bad faith, unreasonably, without reasonable inquiry into the law and facts, vexatiously,
+and for the improper purpose of gratuitously harassing Movant.
+LEGAL STANDARDS
+Federal Rule of Criminal Procedure 11
+Federal Rule of Civil Procedure 11 states that a lawyer signing any pleading in
+federal court is certifying that:
+[T]to the best of the person's knowledge, information, and belief, formed
+after an inquiry reasonable under the circumstances:
+(I) it is not being presented for any improper purpose, such as to harass,
+cause unnecessary delay, or needlessly increase the cost of litigation;
+(2) the claims, defenses, and other legal contentions are warranted by
+existing law or by a nonfrivolous argument for extending, modifying, or
+reversing existing law or for establishing new law;
+'Movant was not served with a copy of the pleading. Movant first saw the
+pleading on April 20, 2011.
+2
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 4 of 31
+(3) the factual contentions have evidentiary support or, if specifically so
+identified, will likely have evidentiary support after a reasonable
+opportunity for further investigation or discovery.
+Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan v. Daimler Chrysler,
+A.G., 331 F.3d 1251, 1255 (11th Cir. 2003). The analysis is whether "a reasonable
+attorney in like circumstances could believe that his actions were factually and legally
+justified." Id. (citing Riccard v. Prudential Ins. Co., 307 F.3d 1277, 1294 (1Ith Cir.
+2002). Violations of Rule 11 are punishable by monetary and non-monetary sanctions
+against both the lawyer filing the pleading and the lawyer's client. Fed: R. Civ. P. 11(c).
+28 U.S.C. $1927
+Title 28, United States Code, Section 1927 states:
+Any attorney or other person admitted to conduct cases in any court of the
+incurred because of such conduct.
+To impose sanctions under § 1927, the Court must find that the attorney's conduct is
+• "tantamount to bad faith.'' Amlong & Amlong, 500 F.3d 1230, 1239 (11'* Cir. 2007)
+(quoting Avirgan v. Hull, 932 F.2d 1572, 1582 (11th Cir. 1991)). "[T]he attorney must
+knowingly or recklessly pursue a frivolous claim." Id. at 1242. The finding of bad faith
+does not turn on "the attorney's subjective intent, but on the attorney's objective
+conduct." Id. at 1239. The standard is "whether, regardless of the attorney's subjective
+intentions, the conduct was unreasonable and vexatious when measured against an
+objective standard." Hudson v. Int'l Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (11th
+Cir. 2007).
+3
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 5 of 31
+DISCUSSION
+Paragraphs 52 and 53 contain inflammatory claims that are false, misleading, and
+irrelevant to the relief sought in the Motion. See generally Declaration of Bruce E.
+Reinhart (attached as Exhibit 1 and incorporated by reference). They ultimately allege,
+"[Movant's] representations [of Epstein's employees] are in contravention of Justice
+Department regulations and Florida bar rules. Such representations also give, at least, the
+improper appearance that Reinhart may have attempted to curry [sic] with Epstein and
+then reap his reward through favorable representation." Plaintiff's Motion at 153. They
+do not cite to any particular bar rule or regulation that they believe was violated. They do
+not explain how the alleged conduct contributed to the Department of Justice's alleged
+violation of the CVRA. Nor do they explain how the alleged conduct is imputable to the
+Department of Justice. These otherwise slanderous accusations against a non-party are
+false. They were made in bad faith, without a factual inquiry reasonable under the
+circumstances, or elementary research into the legal basis for the allegations.
+Paragraphs 52 and 53 omit the following true facts, which Plaintiffs should have
+investigated before making their allegations: (1) Movant did not participate in any way in
+the Office's investigation of Epstein, (2) after leaving government employment, Movant
+did not represent Epstein before the Department of Justice, nor did Movant communicate
+with the Department of Justice about Epstein, and (3) Movant did not use confidential
+information obtained during his Government employment to the detriment of the United
+States. See Declaration of Bruce E. Reinhart at 9911-12, 17.
+Rather than conducting the required inquiry, Plaintiffs simply make two
+irresponsible and unsupported leaps. First, they incorrectly conclude that merely because
+4
+
+
+• Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 6 of 31
+Movant worked in the Office at the time of the Epstein case, Moyant must have been
+involved in the internal decisionmaking at the Office about Epstein. Second, they
+incorrectly conclude that because Movant later represented Epstein's employees in
+private civil litigation, Movant must have used confidential Government information
+improperly in his representation of Epstein's employees, and for his own financial gain.
+It is apparent that Plaintiffs conducted no factual inquiry to substantiate their
+accusations before making them. They never contacted Movant. On information and
+belief, they did not speak to any current or former personnel from the Office or the FBI
+who were familiar with the structure of the West Palm Beach Office or with Movant's
+role (or lack thereof) in the Epstein investigation. Had they done so, they would have
+learned that there were approximately 20 Assistant United States Attorneys in the West
+Palm Beach Office during the relevant time period. See Declaration of Bruce E. Reinhart
+at 110. They would have learned that Movant was not assigned to the same section as the
+prosecutor handling the Epstein matter. Id. They would have learned that Movant had a
+different chain of supervision from the prosecutor assigned to the Epstein matter. Id.
+They would have learned that Movant had no involvement in the Epstein investigation.
+See Declaration of Bruce E. Reinhart at 1911-12.
+Further, Plaintiffs did not conduct an adequate inquiry into the applicable
+Department of Justice regulations. As discussed below, to violate the relevant
+regulations,
+a former employee must appear before, or communicate with, the
+Department of Justice, about a particular matter in which the former employee
+participated personally and substantially while employed at the Department of Justice.
+See 5 C.F.R. §2641.201(a). The Motion contains approximately 50 paragraphs of a
+-
+5
+
+
+Case 9:08-cv-80736-KAM Document 79-1|
+Entered on FLSD Docket 05/03/2011 Page 7 of 31
+detailed historical litany of the interactions among the parties to the Epstein matter. The
+Motion does not allege that Movant participated at all, let alone personally and
+substantially, as a government employee in the Epstein investigation. The Motion does
+not allege that that Movant subsequently appeared before, or communicated with, the
+Department of Justice about Epstein. To the contrary, the Motion alleges only that, after
+leaving the Office, Movant represented Epstein's employees in litigation with non-
+Governmental third parties. Had Plaintiffs conducted rudimentary research into the
+applicable regulations, they would have known that any allegation that Movant violated
+these regulations was frivolous.
+Movant Did Not Violate Any Florida Bar Rule
+Relevant Florida Bar Rules
+The potentially applicable Florida Bar rules are Rule 4-1.6(a) (Confidentiality of
+Information), Rule 4-1.9 (Conflict of Interest; Former Clients), and Rule 4-1.11 (Special
+Conflicts of Interest for Former and Current Government Officers and Employees). For
+purposes of these rules, the U.S. Department of Justice was Movant's client during his
+employment in the Office. Movant did not violate any of the bar rules.
+Rule 4-1.6(a) states:
+A lawyer shall not reveal information relating to representation of a client
+except as stated in subdivisions (b), (c), and (d), unless the client gives
+informed consent.
+Rule 4-1.6 was not violated because Movant did not know any confidential
+information about the Epstein matter, so none could be revealed.
+Rule 4-1.9 states:
+A lawyer who has formerly represented a client in a matter shall not
+thereafter:
+6
+
+
+Entered on FLSD Docket 05/03/2011 Page 8 of 31
+(a) represent another person in the same or a substantially related matter
+in which that person's interests are materially adverse to the interests
+of the former client unless the former client gives informed consent; or
+(b) use information relating to the representation to the disadvantage of
+the former client except as these rules would permit or require with
+respect to a client or when the information has become generally
+known; or,
+(C) reveal information relating to the representation except as these rules
+would permit or require with respect to a client.
+Rule 4-1.9 was not violated because Movant never represented the United States in the
+Epstein matter.
+Rule 4-1.11 states in pertinent parts:
+(a) A lawyer who has formerly served as a public officer or employee of
+the government:
+(1) is subject to rule 4-1.9(b); and
+(2) shall not otherwise represent a client in connection with a
+matter in which the lawyer participated personally and substantially as a
+public officer or employee, unless the appropriate government agency
+gives its informed consent, confirmed in writing, to the representation.
+(c) A lawyer having information that the lawyer knows is confidential
+government information about a person acquired when the lawyer was a
+public officer or employee may not represent a private client whose
+interests are adverse to that person in a matter in which the information
+could be used to the material disadvantage of that person. As used in this
+rule, the term "confidential government information" means information
+that has been obtained under governmental authority and which, at the
+time this rule is applied, the government is prohibited by law from
+disclosing to the public or has a legal privilege not to disclose and which is
+not otherwise available to the public.
+(d) A lawyer currently serving as a public officer or employee:
+(1) is subject to rules 4-1.7 and 4-1.9; and
+7
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 9 of 31
+(2) shall not:
+(A) participate in a matter in which the lawyer participated
+personally and
+substantially while in private practice or
+nongovernmental employment, unless the appropriate government
+agency gives its informed consent; or
+(B) negotiate for private employment with any person who
+is involved as a party or as attorney for a party in a matter in which
+the lawyer is participating personally and substantially.
+Rule 4-1.11(a) was not violated because Movant did not participate personally and
+substantially in the Epstein matter. Rule 4-1.11(c) was not violated because Movant did
+not have any confidential Government information within the meaning of the rule, so he
+did he use any confidential Government information about a third party to the detriment
+of that third party. Rule 4-1.11(d) was not violated because Movant did not participate
+personally and substantially in the Epstein matter.
+Movant Did Not Violate Department of Justice Regulations
+Department of Justice Regulations
+The Department of Justice regulation containing post-employment restrictions, 5
+C.F.R. §2641.201, states in most pertinent part:
+(a) Basic prohibition of 18 U.S.C. 207(a)(1). No former employee shall
+knowingly, with the intent to influence, make any communication to or
+appearance before an employee of the United States on behalf of any other
+paris, in whichie participated personally and substant sly is an arty loyee,
+and in which the United States is a party or has a direct and substantial
+interest.
+(1) Participate: To "participate" means to take an action as an employee through
+decision, approval, disapproval, recommendation, the rendering of advice,
+investigation, or other such action, or to purposefully forbear in order to affect
+the outcome of a matter ... An employee does not participate in a matter
+8
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 10 of
+merely because he had knowledge of its existence or because it was pending
+under his official responsibility.
+Movant did not violate 5 C.F.R. §2641.201 because he did not participate personally and
+substantially in the Epstein matter as a Government employee. He did not appear before
+thé United States on behalf of Epstein after leaving Government employment. He did
+not communicate with the United States on behalf of Epstein after leaving Government
+employment.
+He represented Epstein's employees in civil cases in which the
+Government was not a party.
+It is clear from the face of the regulations that Movant's representing Epstein's
+employees in civil matters not involving the Government did not violate §2641(a). In
+fact, had Plaintiffs and their counsel properly investigated the facts and law, they would
+have seen that §2641(a) would have permitted Movant to represent Epstein, himself,
+openly against the Department of Justice. Movant did not. The allegation that Movant
+violated Department of Justice regulations is frivolous.
+2 A complete copy of this regulation is attached to this Motion as Exhibit 2.
+9
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 11 of
+CONCLUSION
+The allegations in Paragraph 52 and 53 of the Motion are false, made in bad faith,
+and made without sufficient inquiry into the law and facts. They are irrelevant to whether
+the United States Attorney complied with the CVRA. Notably, the Motion does not
+attempt to tie the allegations against Movant to the alleged violation of the CVRA. The
+allegations are included gratuitously in the Motion solely to harass Movant in a forum
+where the accusations are not legally slanderous. The allegations are made without
+reasonable pre-filing inquiry into the facts or law. This Court should issue an Order to
+Show Cause why sanctions should not be imposed under Rule 11 or 28 U.S.C. §1927.
+Respectfully submitted,
+Is/ Bruce E. Reinhart
+BRUCE E, REINHART RA
+West Palm Beach, Florida 33401
+CERTIFICATE OF SERVICE
+I hereby certify that a true and correct copy of the foregoing Intervenor's Motion
+For Sanctions was served on all counsel of record by CM/ECF on
+_ 2011.
+Is/Bruce Reinhart
+BRUCE REINHART
+10
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 12 of
+
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 13 of
+2.
+DECLARATION OF BRUCE E. REINHART
+I, Bruce E. Reinhart, make the following declaration pursuant to 28 U.S.C. §1746.
+I am a licensed attorney in solo practice as Bruce E. Reinhart, P.A. My office
+is located at
+West Palm Beach, Florida,
+33401.
+I am a member in good standing of the bars of the states of Florida,
+Pennsylvania, and New Jersey. I am also admitted to the practice in the
+United States District Court for the Southern District of Florida, the U.S.
+Court of Appeals for the Eleventh Circuit, the U.S: Supreme Cout, and
+several other federal courts.
+I graduated from Princeton University in 1984 with a B.S.E. in civil
+engineering cum laude. I graduated from the University of Pennsylvania Law
+School in 1987, cum laude. I also served as an Editor of the University of
+Pennsylvania Law School.
+After graduating from law school, I served as judicial law clerk to the
+Honorable Norma L. Shapiro, United States District Judge for the Eastern
+District of Pennsylvania.
+In 1988, I began working at the Criminal Division of the United States
+Department of Justice in Washington, D.C., through the Attorney General's
+Honors Program. From 1988-1994, I worked in the Public Integrity Section
+of the Criminal Division. While working there, I received two Special
+Achievement Awards for Meritorious Acts and Service from the
+Department of Justice.
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 14 of
+
+While at the Public Integrity Section, I was involved in investigating and
+prosecuting people who violated federal conflict of interest and postemployment statutes. I attended multiple training conferences where federal
+conflicts of interest laws and regulations were discussed
+From in or about July 1994 to on or about May 1, 1996, I served as Senior
+Policy Advisor to the Undersecretary of the Treasury for Enforcement at the
+United States Department of the Treasury.
+In that position, I helped. the
+Undersecretary, the Deputy Secretary, and the Secretary of the Treasury to
+develop law enforcement policies for U.S. Customs, ATF, Secret Service, and
+IRS Criminal Investigations. I also acted as principal staff liaison to the
+Deputy Attorney General, the FBI and the other Department of Justice law
+enforcement agencies. For my service, I was awarded the Undersecretary for
+Enforcement's Award for Exceptional Service.
+I am the former Vice Chair of the Palm Beach County Bar's Professionalism
+Committee. I am the former President of the Palm Beach County Chapter of
+the Federal Bar Association. I currently serve as an Ethics Commissioner on
+the Palm Beach County Commission on Ethics.
+From May 1, 1996 to January 1, 2008, I served as an Assistant United States
+Attorney in the Southern District of Florida, assigned to the West Palm Beach
+office. From in or about July 1998 to in or about October 2002, I was a
+Supervisory Assistant United States Attorney. From October 2002 to January
+2008, I was a non-supervisory Assistant United States Attorney handling my
+own docket of cases.
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 15 of
+
+10.
+At all relevant times, the Office had approximately 20 Assistant U.S.
+Attorneys assigned to the West Palm Beach location. The prosecutor assigned
+to the Epstein case,
+• and I were assigned to different
+sections within the Office. We reported to different supervisors.
+11.
+I did not participate in any way in the Office's investigation of Epstein. I was
+not involved in any of the Office's decisionmaking with regard to the Epstein
+matter.
+12.
+I never learned any confidential, non-public information about the Epstein
+matter.
+In late December 2007, I had an "exit meeting" with
+the Office's
+ethics officer. As part of that meeting, Mr.
+reviewed with me the
+Department of Justice's post-employment restrictions.
+Based on our
+conversation, it was my understanding that I could work on any matter so long
+as I had not participated in it personally and substantially as a Government
+employee. I also understood that I could not use non-public Government
+information for any purpose.
+14.
+After opening my private practice on January 2, 2008, I was retained to
+represent
+for purposes of civil depositions in causes of action to
+which the United States was not a party. At a later time, I was retained to
+represent several other members of Mr. Epstein's staff in their civil
+depositions.
+After leaving the Office, I did not participate in any of the negotiations over
+Mr. Epstein's non-prosecution agreement.
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 16 of
+16.
+17.
+18.
+
+After leaving the Office, I did not communicate with the Office, in person or
+in writing, about any matters relating to possible criminal charges against Mr.
+Epstein.
+Because I did not have any, I did not share non-public confidential
+information about the Epstein investigation with any of Epstein's attorneys.
+Prior to the filing of Plaintiff's Motion for Finding of Violations of the Crime
+Victims' Rights Act, neither Mr. Edwards, nor Judge Cassell, nor anyone on
+their behalf contacted me to determine if the allegations in Paragraphs 52 and
+53 of that Motion were true.
+I declare under penalty of perjury that the foregoing is true and correct.
+Executed on May 3, 2011.
+Sure lambel
+Bruce E. Reinhart
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 17 of
+
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 18 of
+§ 2641.201 Permanent restriction on any former employee's.... 5 C.F.R. § 2641.201
+Code of Federal Regulations
+Title 5. Administrative Personnel
+Chapter XVI. Office of Government Ethics
+Subchapter B. Government Ethics
+Part 2641. Post-Employment Conflict of Interest Restrictions (Refs & Annos)
+Subpart B. Prohibitions
+5 C.F.R. § 2641.201
+§ 2641.201 Permanent restriction on any former employee's representations to United States
+concerning particular matter in which the employee participated personally and substantially.
+Effective: July 25, 2008
+Currentness
+(a) Basic prohibition of 18 U.S.C. 207(a)(1). No former employee shall knowingly, with the intent to influence, make any
+communication to or appearance before an employee of the United States on behalf of any other person in connection with a
+particular matter involving a specific party or parties, in which he participated personally and substantially as an employee, and
+in which the United States is a party or has a direct and substantial interest.
+(b) Exceptions and waivers. The prohibition of 18 U.S.C. 207(a)(1) does not apply to a former employee who is:
+(1) Acting on behalf of the United States. See § 2641.301(a).
+(2) Acting as an elected State or local government official. See § 2641.301(b).
+(3) Communicating scientific or technological information pursuant to procedures or certification. See § 2641.301(e).
+(4) Testifying under oath. See § 2641.301(f). (Note that this exception from § 2641.201 is generally not available for expert
+testimony. See § 2641.301(D(2).)
+(5) Acting on behalf of an international organization pursuant to a waiver. See § 2641.301(h).
+(6) Acting as an employee of a Government-owned, contractor-operated entity pursuant to a waiver. See § 2641.301(i).
+(c) Commencement and length of restriction. 18 U.S.C. 207(a)(1) is a permanent restriction that commences upon an employee's
+termination from Government service. The restriction lasts for the life of the particular matter involving specific parties in
+which the employee participated personally and substantially.
+(d) Communication or appearance--
+(1) Communication. A former employee makes a communication when he imparts or transmits information of any kind,
+including facts, opinions, ideas, questions or direction, to an employee of the United States, whether orally, in written
+correspondence, by electronic media, or by any other means. This includes only those communications with respect to
+which the former employee intends that the information conveyed will be attributed to himself, although it is not necessary
+that any employee of the United States actually recognize the former employee as the source of the information.
+(2) Appearance. A former employee makes an appearance when he is physically present before an employee of the United
+States, in either a formal or informal setting. Although an appearance also may be accompanied by certain communications,
+an appearance need not involve any communication by the former employee.
+WestlawNext © 2011 Thomson Reuters. No claim to original U.S. Government Works.
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 19 of
+§ 2641.201 Permanent restriction on any former employee's.... 5 C.F.R. § 2641.201
+(3) Behind-the-scenes assistance. Nothing in this section prohibits a former employee from providing assistance to another
+person, provided that the assistance does not involve a communication to or an appearance before an employee of the
+United States.
+Example 1 to paragraph (d): A former employee of the Federal Bureau of Investigation makes a brief telephone call to a
+colleague in her former office concerning an ongoing investigation. She has made a communication. If she personally attends
+an informal meeting with agency personnel concerning the matter, she will have made an appearance.
+Example 2 to paragraph (d): A former employee of the National Endowment for the Humanities (NEH) accompanies other
+representatives of an NEH grantee to a meeting with the agency. Even if the former employee does not say anything at the
+meeting, he has made an appearance (although that appearance may or may not have been made with the intent to influence,
+depending on the circumstances).
+Example 3 to paragraph (d): A Government employee administered a particular contract for agricultural research with Q
+Company. Upon termination of her Government employment, she is hired by Q Company. She works on the matter covered by
+the contract, but has no direct contact with the Government. At the request of a company vice president, she prepares a paper
+describing the persons at her former agency who should be contacted and what should be said to them in an effort to increase
+the scope of funding of the contract and to resolve favorably a dispute over a contract clause. She may do so.
+Example 4 to paragraph (d): A former employee of the National Institutes of Health (NIH) prepares an application for an NIH
+research grant on behalf of her university employer. The application is signed and submitted by another university officer, but it
+lists the former employee as the principal investigator who will be responsible for the substantive work under the grant. She has
+not made a communication. She also may sign an assurance to the agency that she will be personally responsible for the direction
+and conduct of the research under the grant, pursuant to § 2641.201(e)(2)(iv). Moreover, she may personally communicate
+scientific or technological information to NIH concerning the application, provided that she does so under circumstances
+indicating no intent to influence the Government pursuant to § 2641.201(e)(2) or she makes the communication in accordance
+with the exception for scientific or technological information in § 2641.301(e).
+Example 5 to paragraph (d): A former employee established a small government relations firm with a highly specialized practice
+in certain environmental compliance issues. She prepared a report for one of her clients, which she knew would be presented
+to her former agency by the client. The report is not signed by the former employee, but the document does bear the name
+of her firm. The former employee expects that it is commonly known throughout the industry and the agency that she is the
+author of the report. If the report were submitted to the agency, the former employee would be making a communication and not
+merely confining herself to behind-the-scenes assistance, because the circumstances indicate that she intended the information
+to be attributed to herself.
+(e) With the intent to influence--
+(1) Basic concept. The prohibition applies only to communications or appearances made by a former Government employee
+with the intent to influence the United States. A communication or appearance is made with the intent to influence when
+made for the purpose of:
+(i) Seeking a Government ruling, benefit, approval, or other discretionary Government action; or
+(i) Affecting Government action in connection with an issue or aspect of a matter which involves an appreciable element
+of actual or potential dispute or controversy.
+Example 1 to paragraph (e)(1): A former employee of the Administration on Children and Families (ACF) signs a grant
+application and submits it to ACF on behalf of a nonprofit organization for which she now works. She has made a communication
+with the intent to influence an employee of the United States because her communication was made for the purpose of seeking
+a Government benefit.
+WestlawNext © 2011 Thomson Reuters. No claim to original U.S. Government Works.
+2
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 20 of
+§ 2641.201 Permanent restriction on any former employee's..., 5 C.F.R. § 2641.201
+Example 2 to paragraph (e)(1): A former Government employee calls an agency official to complain about the auditing methods
+being used by the agency in connection with an audit of a Government contractor for which the former employee serves as
+a consultant. The former employee has made a communication with the intent to influence because his call was made for the
+purpose of seeking Government action in connection with an issue involving an appreciable element of dispute.
+(2) Intent to influence not present. Certain communications to and appearances before employees of the United States are
+not made with the intent to influence, within the meaning of paragraph (e)(1) of this section, including, but not limited to,
+communications and appearances made solely for the purpose of:
+(i) Making a routine request not involving a potential controversy, such as a request for publicly available documents or
+an inquiry as to the status of a matter;
+(ii) Making factual statements or asking factual questions in a context that involves neither an appreciable element of
+dispute nor an effort to seek discretionary Government action, such as conveying factual information regarding matters
+that are not potentially controversial during the regular course of performing a contract;
+(iii) Signing and filing the tax return of another person as preparer;
+(iv) Signing an assurance that one will be responsible as principal investigator for the direction and conduct of research
+under a Federal grant (see example 4 to paragraph (d) of this section);
+(v) Filing a Securities and Exchange Commission (SEC) Form 10-K or similar disclosure forms required by the SEC;
+(vi) Making a communication, at the initiation of the Government, concerning work performed or to be performed under a
+Government contract or grant, during a routine Government site visit to premises owned or occupied by a person other than
+the United States where the work is performed or would be performed, in the ordinary course of evaluation, administration,
+or performance of an actual or proposed contract or grant; or
+(vii) Purely social contacts (see example 4 to paragraph (f) of this section).
+Example 1 to paragraph (e)(2): A former Government employee calls an agency to ask for the date of a scheduled public hearing
+on her client's license application. This is a routine request not involving a potential controversy and is not made with the intent
+to influence.
+Example 2 to paragraph (e)(2): In the previous example, the agency's hearing calendar is quite full, as the agency has a significant
+backlog of license applications. The former employee calls a former colleague at the agency to ask if the hearing date for her
+client could be moved up on the schedule, so that her client can move forward with its business plans more quickly. This is a
+communication made with the intent to influence.
+Example 3 to paragraph (e)(2): A former employee of the Department of Defense (DOD) now works for a firm that has a DOD
+contract to produce an operator's manual for a radar device used by DOD. In the course of developing a chapter about certain
+technical features of the device, the former employee asks a DOD official certain factual questions about the device and its
+properties. The discussion does not concern any matter that is known to involve a potential controversy between the agency
+and the contractor. The former employee has not made a communication with the intent to influence.
+Example 4 to paragraph (e)(2): A former medical officer of the Food and Drug Administration (FDA) sends a letter to the
+agency in which he sets out certain data from safety and efficacy tests on a new drug for which his employer, ABC Drug Co.,
+is seeking FDA approval. Even if the letter is confined to arguably "factual" matters, such as synopses of data from clinical
+trials, the communication is made for the purpose of obtaining a discretionary Government action, i.e., approval of a new drug.
+Therefore, this is a communication made with the intent to influence.
+Example 5 to paragraph (e)(2): A former Government employee now works for a management consulting firm, which has a
+Government contract to produce a study on the efficiency of certain agency operations. Among other things, the contract calls
+WestlawNext* © 2011 Thomson Reuters. No claim to original U.S. Government Works.
+3
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 21 of
+§ 2641.201 Permanent restriction on any former employee's.... 5 C.F.R. § 2641.201
+for the contractor to develop a range of alternative options for potential restructuring of certain internal Government procedures.
+The former employee would like to meet with agency representatives to present a tentative list of options developed by the
+contractor. She may not do so. There is a potential for controversy between the Government and the contractor concerning the
+extent and adequacy of any options presented, and, moreover, the contractor may have its own interest in emphasizing certain
+options as opposed to others because some options may be more difficult and expensive for the contractor to develop fully
+than others.
+Example 6 to paragraph (e)(2): A former employee of the Internal Revenue Service (IRS) prepares his client's tax return, signs
+it as preparer, and mails it to the IRS. He has not made a communication with the intent to influence. In the event that any
+controversy should arise concerning the return, the former employee may not represent the client in the proceeding, although
+he may answer direct factual questions about the records he used to compile figures for the return, provided that he does not
+argue any theories or positions to justify the use of one figure rather than another.
+Example 7 to paragraph (e)(2): An agency official visits the premises of a prospective contractor to evaluate the testing procedure
+being proposed by the contractor for a research contract on which it has bid. A former employee of the agency, now employed
+by the contractor, is the person most familiar with the technical aspects of the proposed testing procedure. The agency official
+asks the former employee about certain technical features of the equipment used in connection with the testing procedure. The
+former employee may provide factual information that is responsive to the questions posed by the agency official, as such
+information is requested by the Government under circumstances for its convenience in reviewing the bid. However, the former
+employee may not argue for the appropriateness of the proposed testing procedure or otherwise advocate any position on behalf
+of the contractor.
+(3) Change in circumstances. If, at any time during the course of a communication or appearance otherwise permissible
+under paragraph (e)(2) of this section, it becomes apparent that circumstances have changed which would indicate that
+any further communication or appearance would be made with the intent to influence, the former employee must refrain
+from such further communication or appearance.
+Example 1 to paragraph (e)(3): A former Government employee accompanies another employee of a contractor to a routine
+meeting with agency officials to deliver technical data called for under a Government contract. During the course of the meeting,
+an unexpected dispute arises concerning certain terms of the contract. The former employee may not participate in any discussion
+of this issue. Moreover, if the circumstances clearly indicate that even her continued presence during this discussion would be
+an appearance made with the intent to influence, she should excuse herself from the meeting.
+(4) Mere physical presence intended to influence. Under some circumstances, a former employee's mere physical presence,
+without any communication by the employee concerning any material issue or otherwise, may constitute an appearance
+with the intent to influence an employee of the United States. Relevant considerations include such factors as whether:
+(i) The former employee has been given actual or apparent authority to make any decisions, commitments, or substantive
+arguments in the course of the appearance;
+(ii) The Government employee before whom the appearance is made has substantive responsibility for the matter and does
+not simply perform ministerial functions, such as the acceptance of paperwork;
+(i) The former employee's presence is relatively prominent;
+(iv) The former employee is paid for making the appearance;
+(v) It is anticipated that others present at the meeting will make reference to the views or past or present work of the
+former employee;
+(vi) Circumstances do not indicate that the former employee is present merely for informational purposes, for example,
+merely to listen and record information for later use;
+WestlawNext © 2011 Thomson Reuters. No claim to original U.S. Government Works.
+4
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 22 of
+§ 2641.201 Permanent restriction on any former employee's.... 5 C.F.R. § 2641.201
+(vii) The former employee has entered a formal appearance in connection with a legal proceeding at which he is present; and
+(viii) The appearance is before former subordinates or others in the same chain of command as the former employee.
+Example 1 to paragraph (e)(4): A former Regional Administrator of the Occupational Safety and Health Administration (OSHA)
+becomes a consultant for a company being investigated for possible enforcement action by the regional OSHA office. She is
+hired by the company to coordinate and guide its response to the OSHA investigation. She accompanies company officers to
+an informal meeting with OSHA, which is held for the purpose of airing the company's explanation of certain findings in an
+adverse inspection report. The former employee is introduced at the meeting as the company's compliance and governmental
+affairs adviser, but she does not make any statements during the meeting concerning the investigation. She is paid a fee for
+attending this meeting. She has made an appearance with the intent to influence.
+Example 2 to paragraph (e)(4): A former employee of an agency now works for a manufacturer that seeks agency approval for a
+new product. The agency convenes a public advisory committee meeting for the purpose of receiving expert advice concerning
+the product. Representatives of the manufacturer will make an extended presentation of the data supporting the application for
+approval, and a special table has been reserved for them in the meeting room for this purpose. The former employee does not
+participate in the manufacturer's presentation to the advisory committee and does not even sit in the section designated for the
+manufacturer. Rather, he sits in the back of the room in a large area reserved for the public and the media. The manufacturer's
+speakers make no reference to the involvement or views of the former employee with respect to the matter. Even though the
+former employee may be recognized in the audience by certain agency employees, he has not made an appearance with the
+intent to influence because his presence is relatively inconspicuous and there is little to identify him with the manufacturer or
+the advocacy of its representatives at the meeting.
+(f) To or before an employee of the United States--
+(1) Employee of the United States. For purposes of this paragraph, an "employee of the United States" means the President,
+the Vice President, and any current Federal employee (including an individual appointed as an employee or detailed to the
+Federal Government under the Intergovernmental Personnel Act (5 U.S.C. 3371-3376)) who is detailed to or employed
+by any:
+(i) Agency (including a Government corporation);
+(ii) Independent agency in the executive, legislative, or judicial branch;
+(iii) Federal court; or
+(iv) Court-martial.
+(2) To or before. Except as provided in paragraph (f)(3) of this section, a communication "to" or appearance "before" an
+employee of the United States is one:
+(i) Directed to and received by an entity specified in paragraphs (f)(1)(i) through (f)(1)(iv) of this section even though
+not addressed to a particular employee, e.g., as when a former employee mails correspondence to an agency but not to
+any named employee; or
+(ii) Directed to and received by an employee in his capacity as an employee of an entity specified in paragraphs (f)(1)
+(i) through (f)(1)(iv) of this section, e.g., as when a former employee directs remarks to an employee representing the
+United States as a party or intervenor in a Federal or non-Federal judicial proceeding. A former employee does not direct
+his communication or appearance to a bystander who merely happens to overhear the communication or witness the
+appearance.
+(3) Public commentary.
+WestlawNext © 2011 Thomson Reuters. No claim to original U.S. Government Works.
+5
+
+
+Case 9:08-CV-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 23 of
+§ 2641.201 Permanent restriction on any former employee's.... 5 C.F.R. § 2641.201
+(i) A former employee who addresses a public gathering or a conference, seminar, or similar forum as a speaker or panel
+participant will not be considered to be making a prohibited communication or appearance if the forum:
+(A) Is not sponsored or co-sponsored by an entity specified in paragraphs (f)(1)(i) through (f)(1)(iv) of this section;
+(B) Is attended by a large number of people; and
+(C) A significant proportion of those attending are not employees of the United States.
+(ii) In the circumstances described in paragraph (f)(3)(i) of this section, a former employee may engage in exchanges with
+any other speaker or with any member of the audience.
+(iii) A former employee also may permit the broadcast or publication of a commentary provided that it is broadcast or
+appears in a newspaper, periodical, or similar widely available publication.
+Example 1 to paragraph (f): A Federal Trade Commission (FTC) employee participated in the FTC's decision to initiate an
+enforcement proceeding against a particular company. After terminating Government service, the former employee is hired
+by the company to lobby key Members of Congress concerning the necessity of the proceeding. He may contact Members of
+Congress or their staff since a communication to or appearance before such persons is not made to or before an "employee of
+the United States" as that term is defined in paragraph (f(1) of this section.
+Example 2 to paragraph (f): In the previous example, the former FTC employee arranges to meet with a Congressional staff
+member to discuss the necessity of the proceeding. A current FTC employee is invited by the staff member to attend and is
+authorized by the FTC to do so in order to present the agency's views. The former employee may not argue his new employer's
+position at that meeting since his arguments would unavoidably be directed to the FTC employee in his capacity as an employee
+of the FTC.
+Example 3 to paragraph (f): The Department of State granted a waiver pursuant to 18 U.S.C. 208(b)(1) to permit one of its
+employees to serve in his official capacity on the Board of Directors of a private association. The employee participates in a
+Board meeting to discuss what position the association should take concerning the award of a recent contract by the Department
+of Energy (DOE). When a former DOE employee addresses the Board to argue that the association should object to the award
+of the contract, she is directing her communication to a Department of State employee in his capacity as an employee of the
+Department of State.
+Example 4 to paragraph (f): A Federal Communications Commission (FCC) employee participated in a proceeding to review
+the renewal of a license for a television station. After terminating Government service, he is hired by the company that holds
+the license. At a cocktail party, the former employee meets his former supervisor who is still employed by the FCC and begins
+to discuss the specifics of the license renewal case with him. The former employee is directing his communication to an FCC
+employee in his capacity as an employee of the FCC. Moreover, as the conversation concerns the license renewal matter, it is
+not a purely social contact and satisfies the element of the intent to influence the Government within the meaning of paragraph
+(e) of this section.
+Example 5 to paragraph (f): A Federal Trade Commission economist participated in her agency's review of a proposed merger
+between two companies. After terminating Government service, she goes to work for a trade association that is interested in
+the proposed merger. She would like to speak about the proposed merger at a conference sponsored by the trade association.
+The conference is attended by 100 individuals, 50 of whom are employees of entities specified in paragraphs (Đ(1)(i) through
+(f(1)(iv) of this section. The former employee may speak at the conference and may engage in a discussion of the merits of the
+proposed merger in response to a question posed by a Department of Justice employee in attendance.
+Example 6 to paragraph (f): The former employee in the previous example may, on behalf of her employer, write and permit
+publication of an op-ed piece in a metropolitan newspaper in support of a particular resolution of the merger proposal.
+WestlawNext © 2011 Thomson Reuters. No claim to original U.S. Government Works.
+6
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 24 of
+§ 2641.201 Permanent restriction on any former employee's..., 5 C.F.R. § 2641.201
+Example 7 to paragraph (f): ABC Company has a contract with the Department of Energy which requires that contractor
+personnel work closely with agency employees in adjoining offices and work stations in the same building. After leaving the
+Department, a former employee goes to work for another corporation that has an interest in performing certain work related to
+the same contract, and he arranges a meeting with certain ABC employees at the building where he previously worked on the
+project. At the meeting, he asks the ABC employees to mention the interest of his new employer to the project supervisor, who
+is an agency employee. Moreover, he tells the ABC employees that they can say that he was the source of this information. The
+ABC employees in turn convey this information to the project supervisor. The former employee has made a communication to
+an employee of the Department of Energy. His communication is directed to an agency employee because he intended that the
+information be conveyed to an agency employee with the intent that it be attributed to himself, and the circumstances indicate
+such a close working relationship between contractor personnel and agency employees that it was likely that the information
+conveyed to contractor personnel would be received by the agency.
+(g) On behalf of any other person--
+(1) On behalf of.
+(i) A former employee makes a communication or appearance on behalf of another person if the former employee is acting
+as the other person's agent or attorney or if:
+(A) The former employee is acting with the consent of the other person, whether express or implied; and
+(B) The former employee is acting subject to some degree of control or direction by the other person in relation to
+the communication or appearance.
+(i) A former employee does not act on behalf of another merely because his communication or appearance is consistent
+with the interests of the other person, is in support of the other person, or may cause the other person to derive a benefit
+as a consequence of the former employee's activity.
+(2) Any other person. The term "person" is defined in § 2641.104. For purposes of this paragraph, the term excludes the
+former employee himself or any sole proprietorship owned by the former employee.
+Example 1 to paragraph (g): An employee of the Bureau of Land Management (BLM) participated in the decision to grant a
+private company the right to explore for minerals on certain Federal lands. After retiring from Federal service to pursue her
+hobbies, the former employee becomes concerned that BLM is misinterpreting a particular provision of the lease. The former
+employee may contact a current BLM employee on her own behalf in order to argue that her interpretation is correct.
+Example 2 to paragraph (g): The former BLM employee from the previous example later joins an environmental organization
+as an uncompensated volunteer. The leadership of the organization authorizes the former employee to engage in any activity
+that she believes will advance the interests of the organization. She makes a communication on behalf of the organization
+when, pursuant to this authority, she writes to BLM on the organization's letterhead in order to present an additional
+argument concerning the interpretation of the lease provision. Although the organization did not direct her to send the specific
+communication to BLM, the circumstances establish that she made the communication with the consent of the organization and
+subject to a degree of control or direction by the organization.
+Example 3 to paragraph (g): An employee of the Administration for Children and Families wrote the statement of work for a
+cooperative agreement to be issued to study alternative workplace arrangements. After terminating Government service, the
+former employee joins a nonprofit group formed to promote family togetherness. He is asked by his former agency to attend a
+meeting in order to offer his recommendations concerning the ranking of the grant applications he had reviewed while still a
+Government employee. The management of the nonprofit group agrees to permit him to take leave to attend the meeting in order
+to present his personal views concerning the ranking of the applications. Although the former employee is a salaried employee
+of the non-profit group and his recommendations may be consistent with the group's interests, the circumstances establish that
+he did not make the communication subject to the control of the group.
+WestlawNext © 2011 Thomson Reuters. No claim to original U.S. Government Works.
+7
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 25 of
+§ 2641.201 Permanent restriction on any former employee's.... 5 C.F.R. § 2641.201
+Example 4 to paragraph (g): An Assistant Secretary of Defense participated in a meeting at which a defense contractor pressed
+Department of Defense (DOD) officials to continue funding the contractor's sole source contract to develop the prototype of a
+specialized robot. After terminating Government service, the former Assistant Secretary approaches the contractor and suggests
+that she can convince her former DOD colleagues to pursue development of the prototype robot. The contractor agrees that the
+former Assistant Secretary's proposed efforts could be useful and asks her to set up a meeting with key DOD officials for the
+following week. Although the former Assistant Secretary is not an employee of the contractor, the circumstances establish that
+she is acting subject to some degree of control or direction by the contractor.
+(h) Particular matter involving a specific party or parties--
+(1) Basic concept. The prohibition applies only to communications or appearances made in connection with a "particular
+matter involving a specific party or parties." Although the statute defines "particular matter" broadly to include
+"any investigation, application, request for a ruling or determination, rulemaking, contract, controversy, claim, charge,
+accusation, arrest, or judicial or other proceeding," 18 U.S.C. 207(i)(3), only those particular matters that involve a specific
+party or parties fall within the prohibition of section 207(a)(1). Such a matter typically involves a specific proceeding
+affecting the legal rights of the parties or an isolatable transaction or related set of transactions between identified parties,
+such as a specific contract, grant, license, product approval application, enforcement action, administrative adjudication,
+or court case.
+Example 1 to paragraph (h)(1): An employee of the Department of Housing and Urban Development approved a specific city's
+application for Federal assistance for a renewal project. After leaving Government service, she may not represent the city
+in relation to that application as it is a particular matter involving specific parties in which she participated personally and
+substantially as a Government employee.
+Example 2 to paragraph (h)(1): An attorney in the Department of Justice drafted provisions of a civil complaint that is filed in
+Federal court alleging violations of certain environmental laws by ABC Company. The attorney may not subsequently represent
+ABC before the Government in connection with the lawsuit, which is a particular matter involving specific parties.
+(2) Matters of general applicability not covered. Legislation or rulemaking of general applicability and the formulation
+of general policies, standards or objectives, or other matters of general applicability are not particular matters involving
+specific parties. International agreements, such as treaties and trade agreements, must be evaluated in light of all relevant
+circumstances to determine whether they should be considered particular matters involving specific parties; relevant
+considerations include such factors as whether the agreement focuses on a specific property or territory, a specific claim,
+or addresses a large number of diverse issues or economic interests.
+Example 1 to paragraph (h)(2): A former employee of the Mine Safety and Health Administration (MSHA) participated
+personally and substantially in the development of a regulation establishing certain new occupational health and safety standards
+for mine workers. Because the regulation applies to the entire mining industry, it is a particular matter of general applicability,
+not a matter involving specific parties, and the former employee would not be prohibited from making post-employment
+representations to the Government in connection with this regulation.
+Example 2 to paragraph (h)(2): The former employee in the previous example also assisted MSHA in its defense of a lawsuit
+brought by a trade association challenging the same regulation. This lawsuit is a particular matter involving specific parties,
+and the former MSHA employee would be prohibited from representing the trade association or anyone else in connection
+with the case.
+Example 3 to paragraph (h)(2): An employee of the National Science Foundation formulated policies for a grant program for
+organizations nationwide to produce science education programs targeting elementary school age children. She is not prohibited
+from later representing a specific organization in connection with its application for assistance under the program.
+WestlavNext © 2011 Thomson Reuters. No claim to original U.S. Government Works.
+8
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 26 of
+§ 2641.201 Permanent restriction on any former employee's.... 5 C.F.R. § 2641.201
+Example 4 to paragraph (b)(2): An employee in the legislative affairs office of the Department of Homeland Security
+(DHS) drafted official comments submitted to Congress with respect to a pending immigration reform bill. After leaving
+the Government, he contacts DHS on behalf of a private organization seeking to influence the Administration to insist on
+certain amendments to the bill. This is not prohibited. Generally, legislation is not a particular matter involving specific parties.
+However, if the same employee had participated as a DHS employee in formulating the agency's position on proposed private
+relief legislation granting citizenship to a specific individual, this matter would involve specific parties, and the employee would
+be prohibited from later making representational contacts in connection with this matter.
+Example 5 to paragraph (h)(2): An employee of the Food and Drug Administration (FDA) drafted a proposed rule requiring
+all manufacturers of a particular type of medical device to obtain pre-market approval for their products. It was known at the
+time that only three or four manufacturers currently were marketing or developing such products. However, there was nothing
+to preclude other manufacturers from entering the market in the future. Moreover, the regulation on its face was not limited in
+application to those companies already known to be involved with this type of product at the time of promulgation. Because
+the proposed rule would apply to an open-ended class of manufacturers, not just specifically identified companies, it would not
+be a particular matter involving specific parties. After leaving Government, the former FDA employee would not be prohibited
+from representing a manufacturer in connection with the final rule or the application of the rule in any specific case.
+Example 6 to paragraph (h)(2): A former agency attorney participated in drafting a standard form contract and certain standard
+terms and clauses for use in all future contracts. The adoption of a standard form and language for all contracts is a matter of
+general applicability, not a particular matter involving specific parties. Therefore, the attorney would not be prohibited from
+representing another person in a dispute involving the application of one of the standard terms or clauses in a specific contract
+in which he did not participate as a Government employee.
+Example 7 to paragraph (h)(2): An employee of the Department of State participated in the development of the United States'
+position with respect to a proposed treaty with a foreign government concerning transfer of ownership with respect to a parcel
+of real property and certain operations there. After terminating Government employment, this individual seeks to represent the
+foreign government before the Department with respect to certain issues arising in the final stage of the treaty negotiations.
+This bilateral treaty is a particular matter involving specific parties, and the former employee had participated personally and
+substantially in this matter. Note also that certain employees may be subject to additional restrictions with respect to trade and
+treaty negotiations or representation of a foreign entity, pursuant to 18 U.S.C. 207(b) and (f).
+Example 8 to paragraph (h)(2): The employee in the previous example participated for the Department in negotiations with
+respect to a multilateral trade agreement concerning tariffs and other trade practices in regard to various industries in 50
+countries. The proposed agreement would provide various stages of implementation, with benchmarks for certain legislative
+enactments by signatory countries. These negotiations do not concern a particular matter involving specific parties. Even though
+the former employee would not be prohibited under section 207(a)(1) from representing another person in connection with this
+matter, she must comply with any applicable restrictions in 18 U.S.C. 207(b) and (f).
+(3) Specific parties at all relevant times. The particular matter must involve specific parties both at the time the individual
+participated as a Government employee and at the time the former employee makes the communication or appearance,
+although the parties need not be identical at both times.
+Example 1 to paragraph (h)(3): An employee of the Department of Defense (DOD) performed certain feasibility studies and
+other basic conceptual work for a possible innovation to a missile system. At the time she was involved in the matter, DOD
+had not identified any prospective contractors who might perform the work on the project. After she left Government, DOD
+issued a request for proposals to construct the new system, and she now seeks to represent one of the bidders in connection
+with this procurement. She may do so. Even though the procurement is a particular matter involving specific parties at the
+time of her proposed representation, no parties to the matter had been identified at the time she participated in the project as
+a Government employee.
+WestlawNext © 2011 Thomson Reuters. No claim to original U.S. Government Works.
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 27 of
+§ 2641.201 Permanent restriction on any former employee's... 5 C.F.R. § 2641.201
+Example 2 to paragraph (h)(3): A former employee in an agency inspector general's office conducted the first investigation of
+its kind concerning a particular fraudulent accounting practice by a grantee. This investigation resulted in a significant monetary
+recovery for the Government, as well as a settlement agreement in which the grantee agreed to use only certain specified
+accounting methods in the future. As a result of this case, the agency decided to issue a proposed rule expressly prohibiting
+the fraudulent accounting practice and requiring all grantees to use the same accounting methods that had been developed
+in connection with the settlement agreement. The former employee may represent a group of grantees submitting comments
+critical of the proposed regulation. Although the proposed regulation in some respects evolved from the earlier fraud case,
+which did involve specific parties, the subsequent rulemaking proceeding does not involve specific parties.
+(4) Preliminary or informal stages in a matter. When a particular matter involving specific parties begins depends on
+the facts. A particular matter may involve specific parties prior to any formal action or filings by the agency or other
+parties. Much of the work with respect to a particular matter is accomplished before the matter reaches its final stage,
+and preliminary or informal action is covered by the prohibition, provided that specific parties to the matter actually have
+been identified. With matters such as grants, contracts, and other agreements, ordinarily specific parties are first identified
+when initial proposals or indications of interest, such as responses to requests for proposals (RFP) or earlier expressions
+of interest, are received by the Government; in unusual circumstances, however, such as a sole source procurement or
+when there are sufficient indicia that the Government has explicitly identified a specific party in an otherwise ordinary
+prospective grant, contract, or agreement, specific parties may be identified even prior to the receipt of a proposal or
+expression of interest.
+Example I to paragraph (h)(4): A Government employee participated in internal agency deliberations concerning the merits of
+taking enforcement action against a company for certain trade practices. He left the Government before any charges were filed
+against the company. He has participated in a particular matter involving specific parties and may not represent another person
+Example 2 to paragraph (h)(4): A former special Government employee (SGE) of the Agency for Health Care Policy and
+Research served, before leaving the agency, on a "peer review" committee that made a recommendation to the agency
+concerning the technical merits of a specific grant proposal submitted by a university. The committee's recommendations are
+nonbinding and constitute only the first of several levels of review within the agency. Nevertheless, the SGE participated in a
+particular matter involving specific parties and may not represent the university in subsequent efforts to obtain the same grant.
+Example 3 to paragraph (h)(4): Prior to filing a product approval application with a regulatory agency, a company sought
+guidance from the agency. The company provided specific information concerning the product, including its composition and
+intended uses, safety and efficacy data, and the results and designs of prior studies on the product. After a series of meetings,
+the agency advised the company concerning the design of additional studies that it should perform in order to address those
+issues that the agency still believed were unresolved. Even though no formal application had been filed, this was a particular
+matter involving specific parties. The agency guidance was sufficiently specific, and it was clearly intended to address the
+substance of a prospective application and to guide the prospective applicant in preparing an application that would meet
+approval requirements. An agency employee who was substantially involved in developing this guidance could not leave the
+Example 4 to paragraph (h)(4): A Government scientist participated in preliminary, internal deliberations about her
+agency's need for additional laboratory facilities. After she terminated Government service, the General Services
+Administration issued a request for proposals (RFP) seeking private architectural services to design the new laboratory
+space for the agency. The former employee may represent an architectural firm in connection with its response to the
+RFP. During the preliminary stage in which the former employee participated, no specific architectural firms had been
+identified for the proposed work.
+Example 5 to paragraph (h)(4): In the previous example, the proposed laboratory was to be an extension of a recently
+completed laboratory designed by XYZ Architectural Associates, and the Government had determined to pursue a sole
+WestlawNext © 2011 Thomson Reuters. No claim to original U.S. Government Works:
+10
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 28 of
+§ 2641.201 Permanent restriction on any former employee's.... 5 C.F.R. § 2641.201
+source contract with that same firm for the new work. Even before the firm was contacted or expressed any interest
+concerning the sole source contract, the former employee participated in meetings in which specifications for a potentia!
+sole source contract with the firm were discussed. The former employee may not represent XYZ before the Government
+in connection with this matter.
+(5) Same particular matter--
+(i) General. The prohibition applies only to communications or appearances in connection with the same particular matter
+involving specific parties in which the former employee participated as a Government employee. The same particular
+matter may continue in another form or in part. In determining whether two particular matters involving specific parties
+are the same, all relevant factors should be considered, including the extent to which the matters involve the same basic
+facts, the same or related parties, related issues, the same confidential information, and the amount of time elapsed.
+(ii) Considerations in the case of contracts, grants, and other agreements. With respect to matters such as contracts, grants
+or other agreements:
+(A) A new matter typically does not arise simply because there are amendments, modifications, or extensions of a
+contract (or other agreement), unless there are fundamental changes in objectives or the nature of the matter;
+(B) Generally, successive or otherwise separate contracts (or other agreements) will be viewed as different matters
+from each other, absent some indication that one contract (or other agreement) contemplated the other or that both
+are in support of the same specific proceeding;
+(C) A contract is almost always a single particular matter involving specific parties. However, under compelling
+circumstances, distinct aspects or phases of certain large umbrella-type contracts, involving separate task orders or
+delivery orders, may be considered separate individual particular matters involving specific parties, if an agency
+determines that articulated lines of division exist. In making this determination, an agency should consider the relevant
+factors as described above. No single factor should be determinative, and any divisions must be based on the contract's
+characteristics, which may include, among other things, performance at different geographical locations, separate
+and distinct subject matters, the separate negotiation or competition of individual task or delivery orders, and the
+involvement of different program offices or even different agencies.
+Example 1 to paragraph (h)(5): An employee drafted one provision of an agency contract to procure new software. After she left
+Government, a dispute arose under the same contract concerning a provision that she did not draft. She may not represent the
+contractor in this dispute. The contract as a whole is the particular matter involving specific parties and may not be fractionalized
+into separate clauses for purposes of avoiding the prohibition of 18 U.S.C. 207(a)(1).
+Example 2 to paragraph (h)(5): In the previous example, a new software contract was awarded to the same contractor through a
+full and open competition, following the employee's departure from the agency. Although no major changes were made in the
+contract terms, the new contract is a different particular matter involving specific parties.
+Example 3 to paragraph (h)(5): A former special Government employee (SGE) recommended that his agency approve a new
+food additive made by Good Foods, Inc., on the grounds that it was proven safe for human consumption. The Healthy Food
+Alliance (HFA) sued the agency in Federal court to challenge the decision to approve the product. After leaving Government
+service, the former SGE may not serve as an expert witness on behalf of HFA in this litigation because it is a continuation of
+the same product approval matter in which he participated personally and substantially.
+Example 4 to paragraph (h)(5): An employee of the Department of the Army negotiated and supervised a contract with
+Munitions, Inc. for four million mortar shells meeting certain specifications. After the employee left Government, the Army
+sought a contract modification to add another one million shells. All specifications and contractual terms except price, quantity
+and delivery dates were identical to those in the original contract. The former Army employee may not represent Munitions
+in connection with this modification, because it is part of the same particular matter involving specific parties as the original
+contract.
+WestlawNext © 2011 Thomson Reuters. No claim to original U.S. Government Works.
+11
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 29 of
+§ 2641.201 Permanent restriction on any former employee's.... 5 C.F.R. § 2641.201
+Example 5 to the paragraph (h)(5): In the previous example, certain changes in technology occurred since the date of the
+original contract, and the proposed contract modifications would require the additional shells to incorporate new design
+features. Moreover, because of changes in the Army's internal system for storing and distributing shells to various locations,
+the modifications would require Munitions to deliver its product to several de-centralized destination points, thus requiring
+Munitions to develop novel delivery and handling systems and incur new transportation costs. The Army considers these
+modifications to be fundamental changes in the approach and objectives of the contract and may determine that these changes
+constitute a new particular matter.
+Example 6 to paragraph (h)(5): A Government employee reviewed and approved certain wiretap applications. The prosecution
+of a person overheard during the wiretap, although not originally targeted, must be regarded as part of the same particular matter
+as the original wiretap application. The reason is that the validity of the wiretap may be put in issue and many of the facts giving
+rise to the wiretap application would be involved.
+Example 7 to paragraph (h)(5): The Navy awards an indefinite delivery contract for environmental remediation services in the
+northeastern U.S. A Navy engineer is assigned as the Navy's technical representative on a task order for remediation of an oil
+spill at a Navy activity in Maine. The Navy engineer is personally and substantially involved in the task order (e.g., he negotiates
+the scope of work, the labor hours required, and monitors the contractor's performance). Following successful completion of the
+remediation of the oil spill in Maine, the Navy engineer leaves Government service and goes to work for the Navy's remediation
+contractor. In year two of the contract, the Navy issues a task order for the remediation of lead-based paint at a Navy housing
+complex in Connecticut. The contractor assigns the former Navy engineer to be its project manager for this task order, which
+will require him to negotiate with the Navy about the scope of work and the labor hours under the task order. Although the task
+order is placed under the same indefinite delivery contract (the terms of which remain unchanged), the Navy would be justified
+in determining that the lead-based paint task order is a separate particular matter as it involves a different type of remediation, at
+a different location, and at a different time. Note, however, that the engineer in this example had not participated personally and
+substantially in the overall contract. Any former employee who had-for example, by participating personally and substantially
+in the initial award or subsequent oversight of the umbrella contract--will be deemed to have also participated personally and
+substantially in any individual particular matters resulting from the agency's determination that such contract is divisible.
+Example 8 to paragraph (h)(5): An agency contracts with Company A to install a satellite system connecting the headquarters
+office to each of its twenty field offices. Although the field offices are located at various locations throughout the country, each
+installation is essentially identical, with the terms of each negotiated in the main contract. Therefore, this contract should not
+be divided into separate particular matters involving specific parties.
+(i) Participated personally and substantially--
+(1) Participate. To "participate" means to take an action as an employee through decision, approval, disapproval,
+recommendation, the rendering of advice, investigation, or other such action, or to purposefully forbear in order to affect
+the outcome of a matter. An employee can participate in particular matters that are pending other than in his own agency.
+An employee does not participate in a matter merely because he had knowledge of its existence or because it was pending
+under his official responsibility. An employee does not participate in a matter within the meaning of this section unless
+he does so in his official capacity.
+(2) Personally. To participate "personally" means to participate:
+(i) Directly, either individually or in combination with other persons; or
+(ii) Through direct and active supervision of the participation of any person he supervises, including a subordinate.
+(3) Substantially. To participate "substantially" means that the employee's involvement is of significance to the matter.
+Participation may be substantial even though it is not determinative of the outcome of a particular matter. However, it
+requires more than official responsibility, knowledge, perfunctory involvement, or involvement on an administrative or
+WestlawNext © 2011 Thomson Reuters. No claim to original U.S. Government Works.
+
+
+Case 9:08-Cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 30 of
+§ 2641.201 Permanent restriction on any former employee's.... 5 C.F.R. § 2641.201
+peripheral issue. A finding of substantiality should be based not only on the effort devoted to a matter, but also on the
+importance of the effort. While a series of peripheral involvements may be insubstantial, the single act of approving or
+participating in a critical step may be substantial. Provided that an employee participates in the substantive merits of a
+matter, his participation may be substantial even though his role in the matter, or the aspect of the matter in which he
+is participating, may be minor in relation to the matter as a whole. Participation in peripheral aspects of a matter or in
+aspects not directly involving the substantive merits of a matter (such as reviewing budgetary procedures or scheduling
+meetings) is not substantial.
+Example 1 to paragraph (i): A General Services Administration (GSA) attorney drafted a standard form contract and certain
+standard terms and clauses for use in future contracts. A contracting officer uses one of the standard clauses in a subsequent
+contract without consulting the GSA attorney. The attorney did not participate personally in the subsequent contract.
+Example 2 to paragraph (i): An Internal Revenue Service (IRS) attorney is neither in charge of nor does she have official
+responsibility for litigation involving a particular delinquent taxpayer. At the request of a co-worker who is assigned
+responsibility for the litigation, the lawyer provides advice concerning strategy during the discovery stage of the litigation. The
+IRS attorney participated personally in the litigation.
+Example 3 to paragraph (i): The IRS attorney in the previous example had no further involvement in the litigation. She
+participated substantially in the litigation notwithstanding that the post-discovery stages of the litigation lasted for ten years
+after the day she offered her advice.
+Example 4 to paragraph (i): The General Counsel of the Office of Government Ethics (OGE) contacts the OGE attorney who
+is assigned to evaluate all requests for "certificates of divestiture" to check on the status of the attorney's work with respect to
+all pending requests. The General Counsel makes no comment concerning the merits or relative importance of any particular
+request. The General Counsel did not participate substantially in any particular request when she checked on the status of all
+pending requests.
+Example 5 to paragraph (i): The OGE attorney in the previous example completes his evaluation of a particular certificate of
+divestiture request and forwards his recommendation to the General Counsel. The General Counsel forwards the package to the
+Director of OGE with a note indicating her concurrence with the attorney's recommendation. The General Counsel participated
+substantially in the request.
+Example 6 to paragraph (i): An International Trade Commission (ITC) computer programmer developed software designed to
+analyze data related to unfair trade practice complaints. At the request of an ITC employee who is considering the merits of a
+particular complaint, the programmer enters all the data supplied to her, runs the computer program, and forwards the results
+to the employee who will make a recommendation to an ITC Commissioner concerning the disposition of the complaint. The
+programmer did not participate substantially in the complaint.
+Example 7 to paragraph (i): The director of an agency office must concur in any decision to grant an application for technical
+assistance to certain nonprofit entities. When a particular application for assistance comes into her office and is presented to
+her for decision, she intentionally takes no action on it because she believes the application will raise difficult policy questions
+for her agency at this time. As a consequence of her inaction, the resolution of the application is deferred indefinitely. She has
+participated personally and substantially in the matter.
+() United States is a party or has a direct and substantial interest-
+(1) United States. For purposes of this paragraph, the "United States" means:
+(i) The executive branch (including a Government corporation);
+(1i) The legislative branch; or
+(iii) The judicial branch.
+WestlawNext © 2011 Thomson Reuters. No claim to original U.S. Government Works.
+
+
+Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 31 of
+§ 2641.201 Permanent restriction on any former employee's..., 5 C.F.R. § 2641.201
+(2) Party or direct and substantial interest. The United States may be a party to or have a direct and substantial interest in
+a particular matter even though it is pending in a non-Federal forum, such as a State court. The United States is neither a
+party to nor does it have a direct and substantial interest in a particular matter merely because a Federal statute is at issue
+or a Federal court is serving as the forum for resolution of the matter. When it is not clear whether the United States is
+a party to or has a direct and substantial interest in a particular matter, this determination shall be made in accordance
+with the following procedure:
+(i) Coordination by designated agency ethics official. The designated agency ethics official (DAEO) for the former
+employee's agency shall have the primary responsibility for coordinating this determination. When it appears likely that
+a component of the United States Government other than the former employee's former agency may be a party to or have
+a direct and substantial interest in the particular matter, the DAEO shall coordinate with agency ethics officials serving
+in those components.
+(ii) Agency determination. A component of the United States Government shall determine if it is a party to or has a direct
+and substantial interest in a matter in accordance with its own internal procedures. It shall consider all relevant factors,
+including whether:
+(A) The component has a financial interest in the matter;
+(B) The matter is likely to have an effect on the policies, programs, or operations of the component;
+(C) The component is involved in any proceeding associated with the matter, c.g., as by having provided witnesses
+or documentary evidence; and
+(D) The component has more than an academic interest in the outcome of the matter.
+Example 1 to paragraph (i): An attorney participated in preparing the Government's antitrust action against Z Company. After
+leaving the Government, she may not represent Z Company in a private antitrust action brought against it by X Company on
+the same facts involved in the Government action. Nor may she represent X Company in that matter. The interest of the United
+States in preventing both inconsistent results and the appearance of impropriety in the same factual matter involving the same
+party, Z Company, is direct and substantial. However, if the Government's antitrust investigation or case is closed, the United
+States no longer has a direct and substantial interest in the case.
+SOURCE: 73 FR 36186, June 25, 2008, unless otherwise noted.
+AUTHORITY: 5 U.S.C. App. (Ethics in Government Act of 1978); 18 U.S.C. 207; E.O. 12674, 54 FR 15159, 3 CFR, 1989
+Comp., p. 215, as modified by E.O. 12731, 55 FR 42547, 3 CFR, 1990 Comp., p. 306.
+Current through April 21, 2011; 76 FR 22602
+End of Document
+© 2011 Thomson Reuters, No claim to original U.S. Government Works.
+WestlawNext © 2011 Thomson Reuters. No claim to original U.S. Government Works.
+14
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/0310c62a21c3488a03a0d778a9c58ba33ca64542d29c69bffaf279266b886316.receipt.json b/vision-fixhub/ds9-unparsed-06/0310c62a21c3488a03a0d778a9c58ba33ca64542d29c69bffaf279266b886316.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0f673f0ebdf4c3e82ee41e1652749d7d86febf56
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0310c62a21c3488a03a0d778a9c58ba33ca64542d29c69bffaf279266b886316.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -537,
+  "dataset": "marble-joined",
+  "doc_id": "0310c62a21c3488a03a0d778a9c58ba33ca64542d29c69bffaf279266b886316",
+  "engine": "marble-apple-vision",
+  "event_count": 38,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "64b67e102c2d80c0e18daa11fd4236208055dccaa6ff8a509dd5eb8d3543603c",
+  "output_sha256": "74b09614993c274962be629047028a6b9e6cf3e652b001a4934a4868b877f806",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/036cbec14d42c1013995543af662ee49da898e330fa4d4bacbcddcc07771f1aa.md b/vision-fixhub/ds9-unparsed-06/036cbec14d42c1013995543af662ee49da898e330fa4d4bacbcddcc07771f1aa.md
new file mode 100644
index 0000000000000000000000000000000000000000..4d030af3186c4563e30627cbd3aaf40433cec9ae
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/036cbec14d42c1013995543af662ee49da898e330fa4d4bacbcddcc07771f1aa.md
@@ -0,0 +1,368 @@
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 1 of 14
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA/JOHNSON
+JANE DOES #1 AND #2,
+Plaintiffs,
+VS.
+UNITED STATES,
+Defendant.
+ORDER
+THIS CAUSE is before the Court upon Plaintiffs' Motion for Finding of Violations of the
+Crime Victims' Rights Act (DEs 48, 52), Plaintiffs' Motion to Have Their Facts Accepted
+Because of the Government's Failure to Contest Any of the Facts (DE 49), Plaintiffs' Motion for
+Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (DE 50), and
+Bruce E
+Motion to Intervene or in the Alternative for a Sua Sponte Rule 11 Order
+(DE 79).' All motions are fully briefed and ripe for review, and the Court has heard oral
+arguments on all motions. The Court has carefully considered the briefing and the parties"
+arguments and is otherwise fully advised in the premises.
+' The Court is awaiting supplemental briefing on the Motion to Intervene of Roy Black,
+Martin Weinberg, and Jay Lefkowitz (DE 56) and will rule on that motion after it is fully briefed.
+Also, because the proposed interveners seek intervention to request a protective order against
+disclosure of certain correspondences at issue in Plaintiffs' Motion to Use Correspondence to
+Prove Violations of the Crime Victims' Rights Act and to Have Their Unredacted Pleadings
+Unsealed (DE 51), the Court will defer ruling on the latter motion until the intervention motion is
+ripe for review.
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 2 of 14
+Background'
+Plaintiffs Jane Doe #1 and Jane Doe #2 are alleged victims of federal sex crimes
+committed by Jeffrey Epstein in Palm Beach County. Between 2001 and 2007, Epstein sexually
+abused multiple underage girls at his Palm Beach mansion, including Plaintiffs. In 2006, the
+Federal Bureau of Investigation ("FBI") opened an investigation into allegations that Epstein was
+inducing underage girls to engage in sexual acts. The case was eventually presented to the
+United States Attorney's Office for the Southern District of Florida, which accepted it for
+investigation. The Palm Beach County State Attorney's Office was also investigating similar
+allegations against Epstein. Plaintiffs allege that the FBI and U.S. Attorney's Office's
+investigation developed a strong case for a federal prosecution against Epstein based on
+"overwhelming" evidence.
+In June 2007, the FBI delivered to Jane Doe #1 a standard victim-notification letter,
+which explained that the case against Epstein was "under investigation" and notified Jane Doe #1
+of her rights under the Crime Victims' Rights Act ("CVRA"). In August 2007, Jane Doe #2
+received a similar notification letter.
+In September 2007, Epstein and the U.S. Attorney's Office began plea discussions. The
+negotiations led to an agreement under which Epstein would plead guilty to two state felony
+offenses for solicitation of prostitution and procurement of minors for prostitution and the U.S.
+= This background discussion is based on the allegations in Plaintiffs' Petition for
+Enforcement of Crime Victims' Rights Act (DE 1) and the Statement of Material Facts in
+Plaintiffs' Motion for Finding of Violation of the Crime Victims' Rights Act (DEs 48, 52).
+These allegations are not yet supported by evidence and the Court relies on them here solely to
+provide the context for the threshold legal issues addressed in this order. As discussed below,
+further factual development is necessary to resolve the additional issues raised in Plaintiffs'
+motions.
+2
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 3 of 14
+Attorney's Office would agree not to prosecute Epstein for federal offenses. On September 24,
+2007, Epstein and the U.S. Attorney's Office executed a Non-Prosecution Agreement ("NPA")
+under these terms.
+Plaintiffs contend that the U.S. Attorney's Office did not confer with them regarding the
+plea discussions and, in fact, intentionally kept secret the negotiations and the NPA. From
+September 24, 2007, the day on which the NPA was executed, through June 2008, the U.S.
+Attorney's Office did not notify either Plaintiff of the existence of the NPA.
+During this period, Plaintiffs communicated multiple times with the FBI and U.S.
+Attorney's Office, but neither Plaintiff was informed of the NPA. On January 10, 2008, the FBI
+sent letters to Plaintiffs advising them that "It]his case is currently under investigation," but
+failing to disclose the existence of the NPA. On January 32, 2008, Jane Doe #1 met with FBI
+agents and attorneys from the U.S. Attorney's Office to discuss her abuse by Epstein. The
+government did not disclose the existence of the NPA. In mid-June 2008, Plaintiffs' counsel
+contacted the Assistant United States Attorney ("AUSA") handling their case to discuss the
+status of the investigation. The AUSA did not disclose the existence of the NPA. On June 27,
+2008, the U.S. Attorney's Office notified Plaintiffs' counsel that Epstein was scheduled to plead
+guilty in state court on June 30, 2008. The U.S. Attorney's Office did not disclose the existence
+of the NPA nor the relationship between Epstein's state plea and the U.S. Attorney's Office's
+agreement to forgo federal charges. On July 3, 2008, Plaintiffs' counsel sent a letter to the U.S.
+Attorney's Office stating Jane Doe #1's desire that it bring federal charges against Epstein.
+3
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 4 of 14
+On July 7, 2008, Jane Doe #1 filed a petition in this Court to enforce her rights under the
+CVRA. Jane Doe #1 alleged that she believed plea discussions were under way between Epstein
+and the U.S. Attorney's Office, and that the government, by failing to notify her of this
+development, had violated her rights under the CVRA. The United States responded to the
+petition on July 9, 2008, arguing that (1) a federal indictment had never been returned against
+Epstein and therefore the CVRA did not attach, and (2) nevertheless, the U.S. Attorney's Office
+had used its best efforts to comply with the CVRA. The government's response also disclosed
+that the U.S. Attorney's Office had entered into the NPA with Epstein.
+On July 11, 2008, this Court held a hearing on Jane Doe #1's petition, at which Jane Doe
+#2 was added as a plaintiff. At the hearing, Plaintiffs explained that their petition did not present
+an emergency and that therefore an immediate resolution was not necessary. On August 14,
+2008, the Court held a status conference and ordered the United States to turn over the NPA to
+all identified victims, including Plaintiffs, and further ordered the parties to work out the terms of
+a protective order governing the NA's disclosure.
+This action was relatively inactive for the next year and one-half while Plaintiffs litigated
+civil actions against Epstein. After those cases settled, Plaintiffs attempted to resolve their
+CVRA dispute with the U.S. Attorney's Office. On March 18, 2011, after the parties" settlement
+efforts failed, Plaintiffs filed a series of motions, which the Court now addresses in turn, along
+with
+Motion to Intervene.
+3 Jane Doe #2 joined this action after Jane Doe #1 filed the initial Petition for
+Enforcement of Crime Victims' Rights Act.
+4
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 5 of 14
+Motion for Finding of Violations of the Crime Victims' Rights Act
+The CVRA was designed to protect victims' rights and ensure them involvement in the
+criminal-justice process. United States I. Moussaoui, 483 F.3d 220, 234 (4" Cir. 2007); Kenna I
+U.S. Dist. Court, 435 F.3d 1011, 1016 (9" Cir. 2006) ("The [CVRA] was enacted to make crime
+victims full participants in the criminal justice system."). The statute enumerates the following
+eight rights:
+(1) The right to be reasonably protected from the accused
+(2) The right to reasonable, accurate, and timely notice of any public court
+proceeding, or any parole proceeding, involving the crime or of any release or escape
+of the accused.
+(3) The right not to be excluded from any such public court proceeding, unless the
+court, after receiving clear and convincing evidence, determines that testimony by the
+victim would be materially altered if the victim heard other testimony at that
+proceeding.
+(4) The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, sentencing, or any parole proceeding.
+(5) The reasonable right to confer with the attorney for the Government in the case.
+(6) The right to full and timely restitution as provided in law.
+(7) The right to proceedings free from unreasonable delay.
+(8) The right to be treated with fairness and with respect for the victim's dignity and
+privacy.
+18 U.S.C. § 3771(a).
+If a prosecution is underway, the CVRA grants victims standing to vindicate their rights
+in the ongoing criminal action. 18 U.S.C. § 3771(d)(3). If, however, a prosecution is not
+underway, the victims may initiate a new action under the CVRA in the district court of the
+5
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 6 of 14
+district where the crime occurred.* Id. The statute also tasks the district courts and the
+prosecutors with the responsibility of protecting these rights. See 18 U.S.C. § 3771(b)(1) ("IT]he
+court shall ensure that the crime victim is afforded the rights described in subsection (a)."); §
+3771(c)(1) ("Officers and employees of the Department of Justice ... shall make their best
+efforts to see that crime victims are notified of, and accorded, the rights described in subsection
+(a).").
+Here, Plaintiffs first argue that as a matter of law the CVRA's protections attach before a
+formal charge is filed against the criminal defendant. Accordingly, Plaintiffs contend that the
+CVRA applied here and that the U.S. Attorney's Office violated their CVRA rights; namely,
+their rights to confer, to be treated with fairness, and to accurate and timely notice of court
+proceedings. Based on these violations, Plaintiffs request that this Court set a briefing schedule
+and hearing on the appropriate remedy, which according to Plaintiffs is to invalidate the nonprosecution agreement.
+The United States argues that as a matter of law the CVRA does not apply before formal
+charges are filed, i.e., before an indictment or similar charging document, and therefore does not
+apply here because formal charges were never filed against Epstein. The United States further
+argues that even if the CVRA applied here, the U.S. Attorney's Office complied with its
+requirements.
+The Court first addresses the threshold issue whether the CVRA attaches before the
+government brings formal charges against the defendant The Court holds that it does because the
+"Here, because no criminal case was pending, Plaintiffs filed their petition as a new
+matter in this judicial district, which the Clerk of Court docketed as a civil action.
+6
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 7 of 14
+statutory language clearly contemplates pre-charge proceedings. For instance, subsections (a)(2)
+and (a)(3) provide rights that attach to "any public court proceeding ... involving the crime."
+Similarly, subsection (b) requires courts to ensure CVRA rights in "any court proceeding
+involving an offense against a crime victim." Court proceedings involving the crime are not
+limited to post-complaint or post-indictment proceedings, but can also include initial appearances
+and bond hearings, both of which can take place before a formal charge. By way of example,
+under Rule 5(a)(1)(A) of the Federal Rules of Criminal Procedure, upon arrest the defendant
+must be taken before a magistrate judge "without unnecessary delay" for an initial appearance. If
+the arrest takes place on a weekday, "without unnecessary delay" will typically require that the
+initial appearance occur the following morning, which will often be within twenty-four hours of
+arrest. See United States I. Mendoza, 473 F.2d 697, 702 (5" Cir. 1973) (holding that the
+government satisfied Rule 5's "without unnecessary delay" requirement by bringing the
+defendant before the magistrate judge on the first weekday morning following the arrest). By
+contrast, Rule 5(b) requires that where the defendant is arrested without a warrant, the
+government must file the complaint "promptly." The Supreme Court has interpreted "promptly"
+under Rule 5(b) as generally requiring that the complaint be filed within forty-eight hours of
+arrest. Cnty. Of Riverside I. McLaughlin, 500 U.S. 44, 56-57 (1991). It is therefore possible that
+where the defendant is arrested on a weekday without a warrant, the initial appearance—which
+may also involve the detention or bond hearing under Rule 5(d)(3)-will take place before the
+government files the criminal complaint.
+Subsection (c)(1) requires that "Officers and employees of the Department of Justice and
+other departments and agencies of the United States engaged in the detection, investigation, or
+7
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 8 of 14
+prosecution of crime shall make their best efforts to see that crime victims are notified of, and
+accorded, the rights in subsection (a)." (Emphasis added). Subsection (c)(1)'s requirement that
+officials engaged in "detection [or] investigation" afford victims the rights enumerated in
+subsection (a) surely contemplates pre-charge application of the CVRA.
+Subsection (d)(3) explains that the CVRA's enumerated rights "shall be asserted in the
+district court in which a defendant is being prosecuted for the crime or, if no prosecution is
+underway, in the district court in the district in which the crime occurred." (Emphasis added). If
+the CVRA's rights may be enforced before a prosecution is underway, then, to avoid a strained
+reading of the statute, those rights must attach before a complaint or indictment formally charges
+the defendant with the crime.
+This interpretation is consistent with other federal decisions that have addressed the scope
+of the CVRA. For instance, in In re Dean, 527 F.3d 391 (5" Cir. 2008), the court held that
+subsection (a)(5)'s "right to confer" applied before any prosecution is underway. Id. at 394.
+Specifically, the court explained:
+The district court acknowledged that "there are clearly rights under the CVRA that
+apply before any prosecution is underway." Logically, this includes the CVRA's
+establishment of victims" "reasonable right to confer with the attorney for the
+Government." At least in the posture of this case (and we do not speculate on th
+applicability to other situations), the government should have fashioned a reasonable
+way to inform the victims of the likelihood of criminal charges and to ascertain the
+victims' views on the possible details of a plea bargain.
+Id. at 394 (internal citation and quotation marks omitted). Federal district courts have reached
+similar conclusions. See, e.g., United States . Rubin, 558 F. Supp. 2d 411, 417 n.5 (E.D.N.Y.
+2008) (discussing victims' "ability to seek pre-prosecution relief" under the CVRA); United
+States I. Okun, No. 08-132, 2009 WL 790042, at *2 (E.D. Va. Mar. 24, 2009) ("IT]he Fifth
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 9 of 14
+Circuit has noted that victims acquire rights under the CVRA even before prosecution. This
+view is supported by the statutory language, which gives the victims rights before the accepting
+of plea agreements and, therefore, before adjudication of guilt."); United States I. BP Prods N.
+Am. Inc., No. 07-434, 2008 WL 501321, at *11 (S.D. Tex. Feb. 21, 2008) ("There are clearly
+rights under the CVRA that apply before any prosecution is underway."), mandamus denied in
+part, In re Dean 527 F.3d 391 (5"' Cir. 2008).
+The United States argues that because the CVRA accords rights related to "any court
+proceeding," 18 U.S.C. §§ 3771(b)(1), (d)(3), and "in the case," § 3771(b)(5), the CVRA applies
+only after formal charges are filed. The Court finds this argument unavailing. First, as discussed
+above, "court proceedings" can occur before formal charges are filed. Similarly, subsection
+(a)(5)'s reference to the right to confer with "the attorney for the Government in the case," is not
+limited to post-charge proceedings, as the United States is represented by attorneys in each
+criminal case at, for example, initial appearances and bond hearings. Last, the government's
+interpretation ignores the additional language throughout the statute that clearly contemplates
+pre-charge protections, such as subsection (c)(1)'s mandate that U.S. agencies involved at the
+"detection" and "investigation" stage use their best efforts to accord victims their enumerated
+rights under the CVRA and subsection (d)(3)'s provision that victims may vindicate their CVRA
+s For this reason, the Court respectfully disagrees with the interpretation adopted in In re
+Petersen, No. 10-298, 2010 WL 5108692 (N.D. Ind. Dec. 8, 2010), upon which the United States
+relies. See id. at *2 (holding that a "victim's "right to be treated with fairness and with respect
+for [his or her] dignity and privacy' may apply before any prosecution is underway and isn't
+necessarily tied to a 'court proceeding' or 'case,' but concluding that "the right "to confer with
+the attorney for the Government in the case' ... arise[s] only after charges have been brought
+against a defendant and a case has been opened"). But see In re Dean, 527 F.3d at 394 (holding
+that under subsection (a)(5), "the government should have fashioned a reasonable way to inform
+the victims of the likelihood of criminal charges").
+9
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 10 of 14
+rights even if "no prosecution is underway." See United States I. DBB, Inc., 180 F.3d 1277,
+1281 (11" Cir. 1999) ("[W]e read the statute to give full effect to each of its provisions. We do
+not look at one word or term in isolation, but instead we look to the entire statutory context.")
+(citation omitted).
+The Court also rejects the United States' argument that pre-charge CVRA rights could
+impair prosecutorial discretion and decision-making. Any encroachment into the prosecutors'
+discretion is expressly limited by the CVRA itself, which provides: "Nothing in this chapter shall
+be construed to impair the prosecutorial discretion of the Attorney General or any officer under
+his direction." 18 U.S.C. § 3771(d)(6). As the court explained in Rubin, "there is absolutely no
+suggestion in the statutory language that victims have a right independent of the government to
+prosecute a crime, set strategy, or object to or appeal pretrial or in limine orders .... In short, the
+CVRA, for the most part, gives victims a voice, not a veto." 558 F. Supp. at 418; see also BP
+Prods N. Am., 2008 WL 501321, at *15 ("Even under an expansive approach, the reasonable
+right to confer on a proposed plea agreement and the government's obligation to provide notice
+of that right is subject to the limit that the CVRA not impair prosecutorial discretion."). Thus, to
+the extent that the victims' pre-charge CVRA rights impinge upon prosecutorial discretion, under
+the plain language of the statute those rights must yield.
+Having determined that as a matter of law the CVRA can apply before formal charges are
+filed, the Court must address whether the particular rights asserted here attached and, if so,
+whether the U.S. Attorney's Office violated those rights. However, the Court lacks a factual
+record to support such findings and must therefore defer ruling on these two issues pending the
+limited discovery discussed below.
+10
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 11 of 14
+11.
+Motion to Have Their Facts Accepted Because of the Government's Failure to
+Contest Any of the Facts
+For the reasons stated on the record at the August 12, 2011 hearing on this motion, the
+Court will deny Plaintiffs' request to have their facts accepted as true.
+Ill.
+Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant
+Evidence
+Plaintiffs request an order from the Court "directing the U.S. Attorney's Office not to
+suppress material evidence relevant to this case." (DE 50 at 1). Specifically, Plaintiffs seek all
+information and material known to the government that may be favorable to the victims
+regarding possible violations of their rights under the CVRA. The United States opposes the
+motion, arguing that neither the CVRA nor the Federal Rules of Civil Procedure impose a duty
+upon the U.S. Attorney's Office to provide evidence to Plaintiffs here.
+At the August 12, 2011 hearing on this motion, the United States agreed that this Court,
+under its inherent authority to manage this case, could impose discovery obligations on each
+party. Because the Court finds that some factual development is necessary to resolve the
+remaining issues in this case, it will permit Plaintiffs the opportunity to conduct limited
+discovery in the form of document requests and requests for admissions from the U.S. Attorney's
+Office. Either party may request additional discovery if necessary.
+Because the Court will allow this limited factual development, it is unnecessary to decide
+here whether the CVRA or the Federal Rules of Civil Procedure provide discovery rights in this
+context. The Court therefore reserves ruling on Plaintiffs' motion.
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 12 of 14
+IV.
+Motion to Intervene or in the Alternative for a Sua Sponte Rule
+TI Order
+seeks leave to intervene as a party-in-interest under Rule 24(b) of the
+Federal Rules of Civil Procedure. Reinhart seeks to intervene to file a motion for sanctions
+based on allegedly "unfounded factual and legal accusations made about Movant in Plaintiffs"
+Motion for Finding of Violations of the Crime Victims' Rights Act." (DE 79 at 1). In that
+motion, Plaintiffs alleged that Reinhart, a former Assistant U.S. Attorney, "joined Epstein's
+payroll shortly after important decisions were made limiting Epstein's criminal liability" and
+improperly represented Epstein victims in follow-on civil suits. (DE 48 at 22). Plaintiffs
+contend that such conduct "give[s], at least, the improper appearance that Reinhart may have
+attempted to curry [favor] with Epstein and then reap his reward through favorable employment."
+(DE 48 at 23).
+lakes great offense to these accusation-
+-which he contends are false,
+irrelevant to the CVRA claims, and gratuitous and seeks intervention to rebut these allegations
+and move for sanctions.
+Under Rule 24(b) of the Federal Rules of Civil Procedure, "the court may permit anyone
+to intervene who ... has a claim or defense that shares with the main action a common question
+of law or fact." It is "wholly discretionary with the court whether to allow intervention under
+Rule 24(b) and even though there is a common question of law or fact, or the requirements of
+Rule 24(b) are otherwise satisfied, the court may refuse to allow intervention." In re Bayshore
+Ford Trucks Sales, Inc., 471 F.3d 1233, 1246 (11"" 2006). The Court will deny
+request to intervene.
+12
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 13 of 14
+First, the Court finds that
+•claim does not share a common question of law or
+fact with the CVRA action. Reinhart claims that two paragraphs of Plaintiffs' forty-page motion
+make groundless and bad-faith accusations against his integrity and character. However, the
+veracity of Plaintiffs' two paragraphs —i.e., whether Reinhart used his position at the U.S.
+Attorney's Office to ingratiate himself with Epstein and advance his career in private
+practice-involves no common questions with the Plaintiffs' claims that the U.S. Attorney's
+Office violated their CVRA rights through the process in which it entered into the NPA with
+Epstein. Indeed, I
+motion argues that the allegations against him are "irrelevant" and
+that Plaintiffs "do[] not make any effort to connect these allegations to the relief [they] seek[]."
+(DE 79 at 2).
+Second, even if these accusations shared common questions with Plaintiffs' CVRA
+claims, the Court would exercise its discretion and deny intervention. The Court cannot permit
+anyone slighted by allegations in court pleadings to intervene and conduct mini-trials to vindicate
+their reputation. Absent some other concrete interest in these proceedings, the Court does not
+believe that the allegations here are sufficiently harmful to justify permissive intervention.
+Reinhart has publicly aired his opposition to and denial of Plaintiffs' contentions, both on this
+docket and in open court, and the Court finds that further proceedings on this issue are
+unwarranted. For the same reason, the Court declines to conduct a sua sponte Rule 11 inquiry.
+Conclusion
+For the foregoing reasons, it is hereby ORDERED AND ADJUDGED that Plaintiffs'
+Motion for Finding of Violations of the Crime Victims' Rights Act (DEs 48, 52) is GRANTED
+IN PART. The Court concludes that the CVRA can apply before formal charges are filed. The
+13
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 14 of 14
+Court defers ruling on the merits of Plaintiffs' CVRA claims until the parties complete the
+discovery ordered herein.
+It is further ORDERED AND ADJUDGED that Plaintiffs' Motion to Have Their Facts
+Accepted (DE 49) is DENIED.
+The Court reserves ruling Plaintiffs' Motion for Order Directing the U.S. Attorney's
+Office Not to Withhold Relevant Evidence (DE 50) pending the discovery ordered herein.
+It is further ORDERED AND ADJUDGED that Bruce E. L
+Motion to Intervene
+or in the Alternative for a Sua Sponte Rule 11 Order (DE 79) is DENIED.
+DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, Florida
+this 26" day of September, 2011.
+KENNETH A. MARRA
+United States District Judge
+14
diff --git a/vision-fixhub/ds9-unparsed-06/036cbec14d42c1013995543af662ee49da898e330fa4d4bacbcddcc07771f1aa.receipt.json b/vision-fixhub/ds9-unparsed-06/036cbec14d42c1013995543af662ee49da898e330fa4d4bacbcddcc07771f1aa.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1fabad5917567a0901ce19dad393ed95881799e4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/036cbec14d42c1013995543af662ee49da898e330fa4d4bacbcddcc07771f1aa.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -170,
+  "dataset": "marble-joined",
+  "doc_id": "036cbec14d42c1013995543af662ee49da898e330fa4d4bacbcddcc07771f1aa",
+  "engine": "marble-apple-vision",
+  "event_count": 15,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "02102658293f522248f907711a4a57bd47d5f434bdd782aca1b8566fe3d1cfdd",
+  "output_sha256": "54edc8dee1a0fb29ff8aa62f923f9c88f3fc70ac83876be2d79dd92342140cb6",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/037b6ff9ced1452944131e1bebdda26b41c831c25b03f8eb19c3c48661274da5.md b/vision-fixhub/ds9-unparsed-06/037b6ff9ced1452944131e1bebdda26b41c831c25b03f8eb19c3c48661274da5.md
new file mode 100644
index 0000000000000000000000000000000000000000..ee59182dd3ad04c712d6ca899f8ede6f1ea40150
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/037b6ff9ced1452944131e1bebdda26b41c831c25b03f8eb19c3c48661274da5.md
@@ -0,0 +1,71 @@
+From: Paul Cassell
+To:
+Cc: Brad Edwards «
+Subject: RE: Letter to Ferrer
+Date: Fri, 30 Sep 2011 03:30:20 +0000
+Importance: Normal
+Attachments: letter-to-usattorney-sept29-2011 .pdf
+Hi
+Thanks for getting back to us so promptly. While we strenuously disagree with your assertions, we appreciate
+you letting us know quickly.
+Brad and I fed-exed the attached letter to US Attorney Ferrer today. We are sending co's to you and
+via
+snail mail. I thought you might want a courtesy copy quickly.
+Paul Cassell for Jane Doe #1 and Jane Doe #2
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+S.J. Quinney College of Law at the University of Utah
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidenital. This message is
+tended only for the use of the addressee. If you are not the intended recipient, the person responible to deliver
+› the intended recipient, you may not use, disseminate, distribute or copy this communication. If vou hat
+received this message in error, please immediately notify the sender by reply electronic mail and delete the
+original message. Thank you.
+From:
+Sent: Thursday, September 29, 2011 8:20 PM
+To: Paul Cassell;
+Ce: Brad Edwards
+Subject: RE: Any voluntary production of documents?
+Dear Paul and Brad:
+Your request is still under advisement, but I am going to be out tomorrow and I wanted to respect Paul's request
+for a response by Friday.
+After conferring with
+from our review of your request, it appears that the documents that you have
+reges of ed. chim. Po de) ecolin, yok padut and other pirie and many art overed by the secrecy
+If we receive any different direction, I will let you know promptly.
+
+
+Thank you.
+Assistant U.S. Attorney
+----Original Message----
+From: Paul Cassell [r
+Sent: Wednesday, September 28, 2011 11:50 AM
+To:
+Ce:
+Brad Edwards
+Subject: Any voluntary production of documents?
+Dear
+As you know, Judge Marra has now ordered discovery in this case. We are in the process of formulating our
+discovery requests.
+We are writing to inquire as to whether the Government will voluntarily produce any documents to us. We
+understand that briefing is still on-going regarding the U.S. Attorney's correspondence. But there are other items
+that are plainly relevant that are not subject to that litigation, including (but not limited to): the "pros memo" in
+this case; the "case file" in this case; the draft indictments; the draft plea agreements and non-prosecution
+agreements; the draft CVRA notices to victims; information obtained by OPR as part of its investigation/inquiry;
+and correspondence or communications between the USAO and the FBI regarding this case, including crime
+victims issues.
+It would obviously help us to narrow down our document production request if you would voluntarily provide
+some of this information to us. We also continue to believe that you are obligated to provide all of this
+information to us as part of (among other things) (1) the Justice Department's "best efforts" requirements under
+the CVRA, particularly now that Judge Marra has rejected your position that the CVRA was never triggered in
+this case; and (2) the Justice Department's obligation to afford victims their right to be "treated with fairness."
+Thanks in advance for letting us know whether we can receive any voluntary production of documents relevant
+to our pending summary judgment motion. The favor of a reply by the close of business this Friday would be
+greatly appreciated.
+Brad Edwards and Paul Cassell for Jane Doe #1 and Jane Doe #2
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is
+intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver
+it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have
+received this message in error, please immediately notify the sender by reply electronic mail and delete the
+original message. Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/037b6ff9ced1452944131e1bebdda26b41c831c25b03f8eb19c3c48661274da5.receipt.json b/vision-fixhub/ds9-unparsed-06/037b6ff9ced1452944131e1bebdda26b41c831c25b03f8eb19c3c48661274da5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a55a2d2519a1c17a120573ff0bf3be3c4e2f7dad
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/037b6ff9ced1452944131e1bebdda26b41c831c25b03f8eb19c3c48661274da5.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "037b6ff9ced1452944131e1bebdda26b41c831c25b03f8eb19c3c48661274da5",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "acb55db7decea23228b2508339362a3b97902d8a061799b4648b4780a3d0b6bc",
+  "output_sha256": "381e6dadf9f85c3656c30ca71f53f695349b7b96c8b783db3b749bf5def7aa04",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/038c57e1830613c3141c7b2a9856c976b8de1d14fd777fa3fce907b8edc2c9b8.md b/vision-fixhub/ds9-unparsed-06/038c57e1830613c3141c7b2a9856c976b8de1d14fd777fa3fce907b8edc2c9b8.md
new file mode 100644
index 0000000000000000000000000000000000000000..c3b648573e759e1a973c7c9dad469d2886683703
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/038c57e1830613c3141c7b2a9856c976b8de1d14fd777fa3fce907b8edc2c9b8.md
@@ -0,0 +1,10 @@
+From: "l
+To: "d
+Subject: I sent a total of 8 emails
+Date: Fri, 29 Oct 2010 00:43:43 +0000
+Importance: Normal
+- These are the emails re Epstein. Some of those 8 email contain multiple emails within. Please let
+me know if you have any trouble opening any of them.
+Do you still have the big correspondence notebooks in case
+or Willy need them?
+Thanks!
diff --git a/vision-fixhub/ds9-unparsed-06/038c57e1830613c3141c7b2a9856c976b8de1d14fd777fa3fce907b8edc2c9b8.receipt.json b/vision-fixhub/ds9-unparsed-06/038c57e1830613c3141c7b2a9856c976b8de1d14fd777fa3fce907b8edc2c9b8.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..8147cb4c8593d02e5f7138687117f41541d53c89
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/038c57e1830613c3141c7b2a9856c976b8de1d14fd777fa3fce907b8edc2c9b8.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "038c57e1830613c3141c7b2a9856c976b8de1d14fd777fa3fce907b8edc2c9b8",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "b5e87d70f7d0007a9f26e609d64351301e9f1b7347abc6ad34f7bd34e130fd56",
+  "output_sha256": "b13c4594d67f5d3bceaeadcfaeb83221b250f8dbebab2af8c33eaa5fe55c0fc8",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/03ae50f606049922186abcd1c0a7e2fe923c32b6706db591c378e6b0ef91f2b6.md b/vision-fixhub/ds9-unparsed-06/03ae50f606049922186abcd1c0a7e2fe923c32b6706db591c378e6b0ef91f2b6.md
new file mode 100644
index 0000000000000000000000000000000000000000..c4f84434688a31f32809e9ca17e3945145e9733b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/03ae50f606049922186abcd1c0a7e2fe923c32b6706db591c378e6b0ef91f2b6.md
@@ -0,0 +1,22 @@
+From:
+To: "BigJimLaw@aol.com"
+Subject:
+Date: Tue, 24 Oct 2006 17:51:07 +0000
+Importance: Normal
+Hi Jim -- Thank you for the e-mail, and I will even forgive the football reference. I was just set for trial, so the earliest I will
+be able to reschedule the testimony will be after Thanksgiving. I will give you a call to discuss the immunity issue but l an
+compel, motions for orders to show cause why she shouldn't be held in contempt, etc., etc.?
+As always, thank you for your assistance.
+Regards,
+From:
+Sent: Tuesday, October 24, 2006 12:00 PM
+To: L
+(USAFLS)
+Subject:
+Sorry I did not get back to you sooner. I have been out of town for several weeks. As to L
+she still does not
+wish to testify in this case and has a Fifth Amendment basis for her position. She wishes not to accept the "proffer letter "
+cover of immunity, which again is her right. I think it is a waste of time to have her appear Friday to just take the Fifth.
+suggest that you huddle with your people. (It is football season). If you want to push the issue you will have to get forma
+immunity. I will accept service now and in the future for you so you don't have to chase
+]down. Jim Eisenberg
diff --git a/vision-fixhub/ds9-unparsed-06/03ae50f606049922186abcd1c0a7e2fe923c32b6706db591c378e6b0ef91f2b6.receipt.json b/vision-fixhub/ds9-unparsed-06/03ae50f606049922186abcd1c0a7e2fe923c32b6706db591c378e6b0ef91f2b6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3c90c5d216089d880a3054d1f3c3c9d8d45508a3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/03ae50f606049922186abcd1c0a7e2fe923c32b6706db591c378e6b0ef91f2b6.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "03ae50f606049922186abcd1c0a7e2fe923c32b6706db591c378e6b0ef91f2b6",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "ca9dabacb47e5b09cae0e1b14c991c06dd4dd68d2821f6fa03cd00e76995a85f",
+  "output_sha256": "dca679d72d0cfee9f3469d25dad4032067b22f32036ad793b68e5b6b961ca602",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/03ea8cce29689c4983ea96837a4b62727c27c5779ad0f8db2dbaeb389791d1bd.md b/vision-fixhub/ds9-unparsed-06/03ea8cce29689c4983ea96837a4b62727c27c5779ad0f8db2dbaeb389791d1bd.md
new file mode 100644
index 0000000000000000000000000000000000000000..83fa6156855932cfee45cf8b16d99376fa42430c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/03ea8cce29689c4983ea96837a4b62727c27c5779ad0f8db2dbaeb389791d1bd.md
@@ -0,0 +1,26 @@
+From: "
+To: "
+(USAFLS)" -
+| (USAFLS)" {
+Cc: "l
+(USAFLS)" </
+Subject: RE: Jane Doe litigation
+Date: Fri, 28 Oct 2011 18:03:39 +0000
+Importance: Normal
+(USAFLS)"
+The request for production was served by e-mail on October 3, 2011. Adding 30 days, and three days for mailing, the
+government's response is due on November 5, which is a Saturday. The due date is Monday, November 7, as you state.
+Next week is fine for me. Enjoy your trip.
+From:
+(USAFLS)
+Sent: Friday, October 28, 2011 1:57 PM
+(USAFLS);
+Cc:
+(USAFLS)
+Subject: Jane Doe litigation
+| (USAFLS)
+I am leaving the office to fly to Boston in about 10 minutes. I had hoped to get you all a preliminary draft of the
+motion to dismiss, but it is still "in pieces." By my quick calculation, we do not have to respond to the RFP until
+November 7. Can you confirm that I am not mistaken? If so, that should also be the target date for filing the
+motion to dismiss. Unless someone would really like to see my still disjointed writings, I would rather get a
+somewhat cohesive draft out either late on Monday or, more likely, on Tuesday. Does that work for everyone?
diff --git a/vision-fixhub/ds9-unparsed-06/03ea8cce29689c4983ea96837a4b62727c27c5779ad0f8db2dbaeb389791d1bd.receipt.json b/vision-fixhub/ds9-unparsed-06/03ea8cce29689c4983ea96837a4b62727c27c5779ad0f8db2dbaeb389791d1bd.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..5bb23fb1dd914ef4aee8a93fff2d8ae531bb656c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/03ea8cce29689c4983ea96837a4b62727c27c5779ad0f8db2dbaeb389791d1bd.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "03ea8cce29689c4983ea96837a4b62727c27c5779ad0f8db2dbaeb389791d1bd",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "d902363e4f417a3d3ea60e63daf6264c7461930ac0659a730fc400284b1ed49d",
+  "output_sha256": "624629e4f79483dbbba18331d5c2589ccdddf08317b6db8f7bdc9408d732d199",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0458ec9940b54b4e90758dd5008d0ff0c4f9d9f447b5f87609589b848448d872.md b/vision-fixhub/ds9-unparsed-06/0458ec9940b54b4e90758dd5008d0ff0c4f9d9f447b5f87609589b848448d872.md
new file mode 100644
index 0000000000000000000000000000000000000000..e11ca37c478e4e6586b4c9e50fb3372a018237ba
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0458ec9940b54b4e90758dd5008d0ff0c4f9d9f447b5f87609589b848448d872.md
@@ -0,0 +1,49 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80893-KAM Doe |. Epstein Order Dismissing Case
+Date: Tue, 20 Jul 2010 18:54:17 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 7/20/2010 at 2:54 PM EDT and filed on 7/20/2010
+Case Name:
+Doe | Epstein
+Case Number:
+9:08-cv-80893-KAM
+Filer:
+WARNING: CASE CLOSED on 07/20/2010
+Document Number: 211
+Docket Text:
+ORDER DISMISSING CASE with prejudice. All pending motions are denied as moot. This case
+is CLOSED. Signed by Judge Kenneth A. Marra on 7/20/2010. (ir)
+9:08-ev-80893-KAM Notice has been electronically mailed to:
+Ann Marie C. Villafana
+ann.marie.c.villafana@usdoj.gov, shawn.ball@usdoj.gov
+Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com
+Jack Alan Goldberger
+jagesq@bellsouth.net, nalanis@agwpa.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+Michael James Pike
+MPike@bclclaw.com, bobbie@bclclaw.com, jcadwell@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Robert Deweese Critton, Jr rcrit@bclclaw.com, bobbie@bclclaw.com
+9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+
+
+The following document(s) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=7/20/2010] [FileNumber=7805876-0
+][37aa3fb659a9e5d13644640521d089ab97dbd8e7a1b0119b980f5ccb97e1d496bf5
+49b8ab38201a6090b0a35bf45cc89ee1469ebdd815d914daflee83993d2ed]]
diff --git a/vision-fixhub/ds9-unparsed-06/0458ec9940b54b4e90758dd5008d0ff0c4f9d9f447b5f87609589b848448d872.receipt.json b/vision-fixhub/ds9-unparsed-06/0458ec9940b54b4e90758dd5008d0ff0c4f9d9f447b5f87609589b848448d872.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..609d90f448220882037d1ad51bc9977e14374172
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0458ec9940b54b4e90758dd5008d0ff0c4f9d9f447b5f87609589b848448d872.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "0458ec9940b54b4e90758dd5008d0ff0c4f9d9f447b5f87609589b848448d872",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "fed48289218cd8d8f3fcdcdd442b48513cc5c1c127685d1a2bd2e76bbbf29cd5",
+  "output_sha256": "8b6bd387c2202486b8a99ddf1fcaa08cff80638ad9e31b68c7b99cfc10247c4e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/04d5b93b3252c486b38d033e30ae4ae32cc200bb0c25c41ca52fdb0d514beb63.md b/vision-fixhub/ds9-unparsed-06/04d5b93b3252c486b38d033e30ae4ae32cc200bb0c25c41ca52fdb0d514beb63.md
new file mode 100644
index 0000000000000000000000000000000000000000..b4af979c85a64b0d10a038ec4a1e0c02d9b56992
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/04d5b93b3252c486b38d033e30ae4ae32cc200bb0c25c41ca52fdb0d514beb63.md
@@ -0,0 +1,9 @@
+From:
+L. (USAFLS)" ≤
+To: Dave Brannon <
+Subject: PleaAgreementSideLetter1.pdf
+Date: Wed, 27 Jan 2010 20:36:55 +0000
+Importance: Normal
+Attachments: PleaAgreementSideLetter1.pdf
+Hi Dave - Forget to send you the "side letter." Here it is.
+<<PleaAgreementSideLetter1.pdf>>
diff --git a/vision-fixhub/ds9-unparsed-06/04d5b93b3252c486b38d033e30ae4ae32cc200bb0c25c41ca52fdb0d514beb63.receipt.json b/vision-fixhub/ds9-unparsed-06/04d5b93b3252c486b38d033e30ae4ae32cc200bb0c25c41ca52fdb0d514beb63.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..49668e58fe8624879796b1ce83248c60ba5bb882
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/04d5b93b3252c486b38d033e30ae4ae32cc200bb0c25c41ca52fdb0d514beb63.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "04d5b93b3252c486b38d033e30ae4ae32cc200bb0c25c41ca52fdb0d514beb63",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "b5fa64e637e4950b6c9b16b0e46367c6de85c1174d768025f2e18f4dc6b66200",
+  "output_sha256": "bbc95915305e1a9d8670622b4ed38294c1b666b16d5030b8ca6db01463ce19b9",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0526fe77ac213155ad35a5f9cd4b5c43fac50043313cf298fe985f7e6121cd80.md b/vision-fixhub/ds9-unparsed-06/0526fe77ac213155ad35a5f9cd4b5c43fac50043313cf298fe985f7e6121cd80.md
new file mode 100644
index 0000000000000000000000000000000000000000..752b6c4c28b0b4a15041e7760516cd394ab5c318
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0526fe77ac213155ad35a5f9cd4b5c43fac50043313cf298fe985f7e6121cd80.md
@@ -0,0 +1,41 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov»
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80232-KAM Doe No. 3 L. Epstein Clerks Notice of Docket
+Correction - Chambers and Clerks
+Date: Thu, 14 Jan 2010 16:38:53 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 1/14/2010 at 11:38 AM EST and filed on 1/14/2010
+Case Name:
+Case Number:
+Filer:
+Doe No. 3 |. Epstein
+9:08-CV-80232-KAM
+Document Number: 138(No document attached)
+Docket Text:
+Clerks Notice of Docket Correction re [137] MOTION for Sanctions. Document Filed in
+Wrong Case; Document restricted and docket text modified. Document refiled in correct case
+# 08CV80119-KAM. (tp)
+9:08-cv-80232-KAM Notice has been electronically mailed to:
+Adam D. Horowitz ahorowitz@sexabuseattorney.com
+Jack Alan Goldberger
+jagesq@bellsouth.net, nalanis@agwpa.com
+Jeffrey Mare Herman
+jherman@hermanlaw.com
+Michael James Pike MPike@bclclaw.com, bobbie@bclclaw.com, jcadwell@bclclaw.com
+Robert Deweese Critton, Jr rerit@bclclaw.com, bobbie@bclelaw.com
+Stuart S. Mermelstein ssm@sexabuseattorney.com, jarbour@sexabuseattorney.com,
+Irivera(@sexabuseattorney.com
+
+
+9:08-cv-80232-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
diff --git a/vision-fixhub/ds9-unparsed-06/0526fe77ac213155ad35a5f9cd4b5c43fac50043313cf298fe985f7e6121cd80.receipt.json b/vision-fixhub/ds9-unparsed-06/0526fe77ac213155ad35a5f9cd4b5c43fac50043313cf298fe985f7e6121cd80.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4e3f0f4ed3ad91e0bbada2a9aa427eec79a95d77
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0526fe77ac213155ad35a5f9cd4b5c43fac50043313cf298fe985f7e6121cd80.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "0526fe77ac213155ad35a5f9cd4b5c43fac50043313cf298fe985f7e6121cd80",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3fd6d0fd21d6fb1622fd61f71475877808fd85defd246e8493cb8deb40012648",
+  "output_sha256": "060818fba892d8c736d0cec5352f02e58fecd088dd4e5ce74729ddd8281efa48",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/052bdd30747d1c0bc4d39cec676d4b19a3c7cf04a06cac3ece9bf4f57a20a795.md b/vision-fixhub/ds9-unparsed-06/052bdd30747d1c0bc4d39cec676d4b19a3c7cf04a06cac3ece9bf4f57a20a795.md
new file mode 100644
index 0000000000000000000000000000000000000000..5e661ef597f6bbda0668a56802f42eb3e6bb0fb9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/052bdd30747d1c0bc4d39cec676d4b19a3c7cf04a06cac3ece9bf4f57a20a795.md
@@ -0,0 +1,66 @@
+From:
+To:
+Subject: Re: Jane Does US
+Date: Thu, 20 Jun 2013 16:38:14 +0000
+Importance: Normal
+But I need you to be ok - if u need me on it so be it.
+On Jun 20, 2013, at 12:13 PM,
+wrote:
+> You probably want out. You have a lot on your plate.
+>
+>
+> Assistant US Attorney
+> Sent from my iPhone
+>
+> On Jun 20, 2013, at 11:51 AM
+>
+>>
+wrote:
+>> Let me know if you you want me to be on the call or u can update me later - if too many cooks...
+>> On Jun 20, 2013, at 11:40 AM,
+> wrote:
+• > Yes. Just let me know.
+>>> Assistant US Attorney
+>>> Sent from my iPhone
+>>>
+>>> On Jun 20, 2013, at 11:38 AM
+wrote:
+>>>
+>>>> I was.
+and Kathy Salyer spoke yesterday, and
+told Kathy to contact DOJ about the adverse
+rulings. I believe she notified
+ad DOJ Criminal Appellate, even though this unusual matter was
+docketed by the clerk's office as a civil case.
+Lis out until Monday, but he asked me to see if we can meet to
+start forming a game plan. We can then update him when he gets back and make any necessary changes or
+273>
+>>>>
+>>>>----Original Message-..--
+>>>> From:
+>>>> Sent: Thursday, June 20, 2013 11:13 AM
+>>>> To:
+(USAFLS)
+>>>> Subject: RE: Jane Does I US
+2333
+>>>> I think
+s talking with Kathy about the adverse decisions.
+2733
+>>>>---Original Message-....
+>>>> From
+>>>> Sent: Thursday, June 20, 2013 T0:I7 AM
+>>>> To:
+(USAFLS,,
+
+
+>>>> Subject: Jane Does | US
+23>3
+>>>> Hi everyone: I know you received Roy Black's email. He also left me a voicemail. When are you available
+to discuss? I am in debriefings but can step out as needed. Thank you.
+>>>>
+>>>> PS: should we ask
+to attend to discuss appellate issues?
+>>>>
+23>
+>>>> Assistant US Attorney
+>>>> Sent from my iPhone
diff --git a/vision-fixhub/ds9-unparsed-06/052bdd30747d1c0bc4d39cec676d4b19a3c7cf04a06cac3ece9bf4f57a20a795.receipt.json b/vision-fixhub/ds9-unparsed-06/052bdd30747d1c0bc4d39cec676d4b19a3c7cf04a06cac3ece9bf4f57a20a795.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..fd8b7bf68e7bdf573e43daa85d670a0d4f0e1178
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/052bdd30747d1c0bc4d39cec676d4b19a3c7cf04a06cac3ece9bf4f57a20a795.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "052bdd30747d1c0bc4d39cec676d4b19a3c7cf04a06cac3ece9bf4f57a20a795",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "dc3df018481a02e2a9707615b7550477b217b7b90f08d7e3dce2e3f39c1dddeb",
+  "output_sha256": "b91ca2a776ad80333e5bccb5f312716ddd613b3a4182d80c1db9c7bcb28e2161",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/05519e76b40648e04427848fc3e1d8f4c89ef1fccc42e23200a489de6929a4bc.md b/vision-fixhub/ds9-unparsed-06/05519e76b40648e04427848fc3e1d8f4c89ef1fccc42e23200a489de6929a4bc.md
new file mode 100644
index 0000000000000000000000000000000000000000..993e91169296e658fe274a9dc4dbe7f1b0997721
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/05519e76b40648e04427848fc3e1d8f4c89ef1fccc42e23200a489de6929a4bc.md
@@ -0,0 +1,185 @@
+Memorandum
+SubjectDate
+Re: Jeffrey Epstein Investigation
+July 26, 2011
+ToErom
+First Assistant U.S. Attorney
+I. Introduction
+This memorandum summarizes the conflict of interest related to the investigation by the Federal
+Bureau of Investigation ("FBI") of additional crimes committed by Jeffrey Epstein ("Epstein"). The
+memo begins with a brief overview of the original investigation of Epstein, dubbed "Operation Leap
+Year"; summarizes the resolution of Operation Leap Year by the Southern District of Florida; and
+addresses the events following the resolution of Operation Leap Year, including the basis for the
+conflict. Lastly, the memo briefly addresses the additional crimes that the FBI wants to investigate.
+II. "Operation Leap Year"
+The investigation of Jeffrey Epstein initially was undertaken by the City of Palm Beach Police
+Department in response to a complaint received from the parents of a 14-year-old girl,
+from
+1. When
+and another girl began fighting at school because the other girl accused
+of being a prostitute, one of the school principals intervened. The principal searched
+purse and found $300 cash. The principal asked
+where the money came from.
+initially
+claimed that she earned the money working at "
+" which no one believed
+then claimed
+that she made the money selling drugs; no one believed that either.
+finally admitted that she had
+been paid $300 to give a massage to a man on Palm Beach island.
+parents approached the Palm
+Beach Police Department ("PBPD") about pressing charges.
+PBPD began investigating the recipient of the massage, Jeffrey Epstein, and
+and
+PBPD identified 27 girls who went to Epstein's house to perform
+"massage services" (not including one licensed massage therapist). The girls' ages ranged from 14
+years' old to 23 years' old. Some girls saw Epstein only once and some saw him dozens of times. The
+"massage services" performed also varied. Some girls were fully clothed while they massaged Epstein;
+some wore only their underwear; and some were fully nude. During all of these massages. Epstein
+masturbated himself and he would
+usually
+and
+either over their clothing or on their bare skin. Epstein often used a
+vibrator to
+a number of them. For the girls who saw him
+more often, Epstein graduated to
+Epstein sometimes brought
+into the sexual activity. One of the girls described
+as Epstein's "sex slave"
+On October 18, 2005, PBPD obtained a search warrant with the assistance of the Palm Beach
+County State Attorney's Office (PBSAO"). By this time, PBSAO had already been contacted by
+Epstein's cadre of lawyers. When PBPD arrived at Epstein's home two days later (10/20/05) to execute
+the search warrant, they found several items conspicuously missing. For example, computer monitors
+and keyboards were found, but the CPUs were gone. - Similarly, surveillance cameras were found, but
+they were disconnected and the videotapes were gone. Nonetheless, the search did recover some
+evidence of value, including message pads showing messages from many girls over a two year span.
+The messages show girls returning phone calls to confirm appointments to "work." Messages were
+taken by three of Epstein's "personal assistants."
+Photographs taken inside the home showed that the girls' descriptions of the layout of the home
+and master bedroom/bathroom area were accurate. PBPD also found massage tables and oils, the high
+school transcript of one of the girls, and sex toys.
+
+
+In sum, the PBPD investigation showed that girls from
+would be
+contacted by one of Epstein's assistants to make an appointment to "work." Up to three appointments
+each day would be made. The girls would travel to Epstein's home in Palm Beach where they would
+meet Epstein's chef and Epstein's
+-in the kitchen. The assistant would
+escort the girls upstairs to the master bedroom/bathroom area and set up the massage table and massage
+oils. The girl sometimes was instructed to remove her clothing. The assistant would leave and Epstein
+would enter the room wearing a robe. He would remove the robe and lie face down and nude on the
+massage table. Epstein would then instruct the girl on what to do and would ask her to remove her
+clothing. After some time, Epstein would turn over, so that he was lying face up. Epstein would
+masturbate himself and
+When Epstein climaxed, the massage
+was over, and the girl was instructed to get dressed and to go downstairs to the kitchen while Epstein
+showered. Epstein's assistant would be in the kitchen and the girl would be paid usually $200 and if it
+was a "new" girl, the assistant would ask for the girl's phone number to contact her in the future. E2
+Girls were encouraged to find other girls to bring with them. If a girl brought another girl to perform a
+"massage," each girl would receive $200. Each time a girl returned to the house, Epstein would
+pressure the girl to go further sexually,
+•. Epstein would pay
+more for these acts - in the words of one girl, "the more you do, the more you make."
+The PBPD investigation consisted primarily of sworn taped statements from the girls. When
+PBPD began having problems with PBSAO, they approached the FBI. The investigation was formally
+presented to the FBI and to the U.S. Attorney's Office after PBSAO "presented" the case to a state grand
+jury and the state grand jury returned an indictment charging Epstein only with one felony count of
+solicitation of [adult] prostitution.
+After the matter was presented to the U.S. Attorney's Office and there was a determination that
+federal statutes had been violated, FBI, ICE, and the U.S. Attorney's Office opened files. The federal
+investigation focused on the interstate nexus required for all of the federal violations, so a number of
+grand jury subpoenas were issued for telephone records, flight manifests, and credit card records. The
+federal agents also re-interviewed some of the girls. The agents delved into Epstein's history and
+interviewed other girls and obtained records to corroborate the girls' stories. FBI also interviewed girls
+who came forward after the PBSAO indictment was reported in the papers and the additional girls
+identified through those interviews.
+The attempt to handle secretly the federal case was doomed from the start when the Chief of the
+Palm Beach Police Department gave a letter to each of the victims identified through his investigation
+telling them that, because of his disappointment in the way that the PBSAO had handled the case, the
+matter had been referred to the FBI. Almost immediately, Epstein's attorneys began calling to request a
+meeting with the U.S. Attorney's Office. When one attorney was unable to schedule a meeting, Epstein
+hired another attorney who called up the chain of command until someone agreed to a meeting.
+Between January and May 2007, an indictment package was prepared, charging Epstein and three
+of his personal assistants with a number of child exploitation offenses. The case agent made several
+appearances before the grand jury. Attorneys for Epstein made several presentations to the U.S.
+Attorney's Office to convince the Office not to prosecute, and made allegations of prosecutorial
+misconduct against the line Assistant and the First Assistant U.S. Attorney. Epstein also challenged the
+legal analysis behind the prosecution, both within the U.S. Attorney's Office (up to the U.S. Attorney)
+and to the Child Exploitation and Obscenity Section at the Justice Department. All of Epstein's
+challenges were considered and rejected.
+III. The Resolution of "Operation Leap Year"
+On September 24, 2007, Epstein signed a Non-Prosecution Agreement wherein the U.S.
+Attorney's Office for the Southern District of Florida promised not to prosecute Epstein for the crimes
+that were the subject of the grand jury investigation if: (1) he pled guilty to two crimes in state court -
+
+
+the state felony prostitution charge and a state charge of procuring minors into prostitution, which would
+require Epstein to register as a sex offender; (2) he were sentenced to at least 18 months' imprisonment,
+and (3) he agreed to pay damages to the victims of his offenses. After signing this Agreement, Epstein
+and his counsel decided that they were dissatisfied with its terms, and again complained to the Justice
+Department, seeking review to the Deputy Assistant Attorney General and the Deputy Attorney General.
+After those attempts also failed, on June 30, 2008, Epstein entered his guilty plea in state court
+and began serving his sentence.
+IV. Post-Resolution Events
+A few days before the plea and sentencing (in state court those occur on the same day), the
+Assistant U.S. Attorney handling the matter contacted counsel for three of Epstein's identified victims
+and informed him of the upcoming court date, encouraging his clients to attend and be heard. They did
+not appear. On July 7, 2008, two of those victims filed suit against the United States in federal court
+claiming that their rights had been violated under the Crime Victims' Rights Act because they had not
+been consulted before the Office entered into the Non-Prosecution Agreement. (This will be referred to
+as the "CVRA Action.")
+After an initial flurry of activity, the Petitioners obtained a copy of the confidential Non-
+Prosecution Agreement, and the Court ordered that it be shared with all of the identified victims. After
+it was provided, the Petitioners and most of Epstein's victims focused on their civil suits against him.
+In 2009, the U.S. Attorney's Office in Fort Lauderdale initiated an investigation into a Ponzi
+scheme operated by Scott Rothstein through his law firm. As part of his Ponzi scheme, Rothstein told
+investors that his law firm represented several of Epstein's victims and that Epstein was willing to pay
+huge sums of money to avoid exposing his criminal activities. The attorney representing the victims in
+the CVRA Action, Brad Edwards ("Edwards"), worked at the Rothstein firm. Epstein sued Edwards,
+alleging that Edwards was part of the Ponzi scheme, and alleging that Edwards' attempts to subpoena
+some of Epstein's high-powered friends were done to increase the value of the Ponzi scheme, rather
+than for legitimate discovery purposes.
+In the summer of 2010, most of the civil suits against Epstein were settled, including the suits
+filed by the two victims in the CVRA Action. All of the settlements were confidential, so it is unknown
+how much each of the victims received
+In September 2010, U.S. District Judge Kenneth Marra, who handled most of the civil cases and
+the CVRA Action, issued an Order closing the CVRA Action. Almost immediately thereafter, the
+Petitioners filed a Motion to Reopen, stating that they had obtained discovery through their civil suits
+against Epstein that showed that the U.S. Attorney's Office had violated their rights as victims.
+For several months, attempts were made to resolve the matter. In short, the victims have asked
+that the U.S. Attorney's Office disavow the Non-Prosecution Agreement, on the basis that the CVRA
+was violated, and bring charges against Epstein. Edwards has said that one of his clients repeatedly
+calls and asks him when Epstein is going to jail. One of the other attorneys on the case has suggested
+that emails he considers to be embarrassing to the Office will not be disclosed if we re-open our
+investigation of Epstein and prosecute him.
+Herein lies the conflict. If the U.S. Attorney's Office for the Southern District of Florida reinitiates a grand jury investigation of Jeffrey Epstein, it will be perceived - correctly or incorrectly - as
+having been done at the insistence of the victims in the CVRA Action. And Epstein will allege that any
+prosecution arising therefrom will have been undertaken in an effort to resolve the CVRA Action, not
+based upon the merits of the investigation itself.
+V. The FBI's Current Investigation
+The main focus of the FBI's current investigation is a victim,
+who refused to speak with
+agents during the "Operation Leap Year" investigation. Based upon her debriefing, Epstein engaged in
+several additional crimes, in the Southern District of Florida and, more importantly, in several other
+
+
+Districts, with
+Land other minor females. Epstein transported
+in his private airplanes to
+engage in sexual activity with him. Epstein also "pimped"
+to several of his other important
+friends, and transported her to those sexual encounters. This activity was not part of the initial
+investigation.
+also reported that, during the "Operation Leap Year" investigation, she was contacted by
+Epstein's investigators, lawyers, and Epstein himself, and offered payment to remain silent when
+contacted by the police.
+FBI agents are seeking grand jury subpoenas at this time to corroborate
+statement.
+They also are asking for permission to approach one of Epstein's "personal assistants," who was served
+with a target letter during the "Operation Leap Year" investigation, to give her a "de-target" letter and
+interview her.
+-During a meeting, two of Epstein's attorneys, Gerald Lefcourt and Lilly Ann Sanchez, admitted that
+attorney Roy Black instructed Epstein to have the CPUs removed although they insisted that those instruction
+were given well in advance of the execution of the search warrant - not in response to a "leak."
+Sometimes Epstein made the payment and asked for the phone number, sometimes it was the assistant.
diff --git a/vision-fixhub/ds9-unparsed-06/05519e76b40648e04427848fc3e1d8f4c89ef1fccc42e23200a489de6929a4bc.receipt.json b/vision-fixhub/ds9-unparsed-06/05519e76b40648e04427848fc3e1d8f4c89ef1fccc42e23200a489de6929a4bc.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..cb6c7bc9c474a41f61e962204457964bfa55d585
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/05519e76b40648e04427848fc3e1d8f4c89ef1fccc42e23200a489de6929a4bc.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -50,
+  "dataset": "marble-joined",
+  "doc_id": "05519e76b40648e04427848fc3e1d8f4c89ef1fccc42e23200a489de6929a4bc",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "b63b540e523dd88c0d70d24ea9f50693d49f27c90cd3f92fdc8de2138837d604",
+  "output_sha256": "d306796957b518060031de915afbd7f2967f607811a6b77643f34078ad94fa89",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/057c5a51c8d375901d2fc4bad878385f29f4834340bb2a15e5491c47ebc7f63f.md b/vision-fixhub/ds9-unparsed-06/057c5a51c8d375901d2fc4bad878385f29f4834340bb2a15e5491c47ebc7f63f.md
new file mode 100644
index 0000000000000000000000000000000000000000..6c0eb0c77f321dd74f8f05edd78288cb34a13e19
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/057c5a51c8d375901d2fc4bad878385f29f4834340bb2a15e5491c47ebc7f63f.md
@@ -0,0 +1,24 @@
+From: Paul Cassell <
+To:
+| (USAFLS)" <
+Subject: RE: Jane Doe |. United States - please me now
+Date: Mon, 07 Nov 2011 22:44:51 +0000
+Importance: Normal
+Thanks! Paul
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+S.J. Quinney College of Law at the University of Utah
+Email:
+http://www.law.utah.edu/profiles/default.asp?PersonID=57&name=Cassell,Paul
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only
+for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended
+recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error,
+please immediately notify the sender by reply electronic mail and delete the original message. Thank you.
+From:
+1. (USAFLS) [mailto:
+Sent: Monday, November 07, 2011 2:18 PM
+To: Paul Cassell
+Subject: Jane Doe L. United States
+Hi Paul - I am sorry to bother you, but has Dexter been in touch with you regarding a Motion to Stay Discovery? If not,
+could you let me know your position regarding such a Motion?
+Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/057c5a51c8d375901d2fc4bad878385f29f4834340bb2a15e5491c47ebc7f63f.receipt.json b/vision-fixhub/ds9-unparsed-06/057c5a51c8d375901d2fc4bad878385f29f4834340bb2a15e5491c47ebc7f63f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7daa0b131b4790f6474ee53feff005496b946a9d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/057c5a51c8d375901d2fc4bad878385f29f4834340bb2a15e5491c47ebc7f63f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "057c5a51c8d375901d2fc4bad878385f29f4834340bb2a15e5491c47ebc7f63f",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "aa0eb2196e0ecc76fd754333461d442c4836b99b2a5c8534eb3e8af57eaa7837",
+  "output_sha256": "fbcab064bf078e50b4519ca59716b1fadae0f39bc6e65b676b3f6eecb61b533d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/05be0adb1d5dce2e348e3b0a95c8e60960ac0d26a173c6eeaf469795b2d855a7.md b/vision-fixhub/ds9-unparsed-06/05be0adb1d5dce2e348e3b0a95c8e60960ac0d26a173c6eeaf469795b2d855a7.md
new file mode 100644
index 0000000000000000000000000000000000000000..bef697dc0c3e633dd839ae66150ab64f7c671d8f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/05be0adb1d5dce2e348e3b0a95c8e60960ac0d26a173c6eeaf469795b2d855a7.md
@@ -0,0 +1,28 @@
+MARTIN G. WEINBERG, P.C.
+ATTORNEY AT LAW
+B030 AM SAI 5 02116
+(617) 227-3700
+FAX (617) 338-9538
+NIGHT EMERGENCY:
+(617) 901-3472
+EMAIL ADDRESSES:
+owimch@att.net
+owlmgw@at.net
+July 22, 2011
+Re:
+Jeffrey Epstein
+Dear Ms. Villafaña:
+Roy Black forwarded to me your letter to him dated July 21, 2011, from the District
+Attorney of the County of New York. We thank you for providing notice of the intended
+disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related
+list of witness/victims on the basis of the confidentiality provisions of paragraph 13. Absent an
+enforceable subpoena - which we would have the right to move to quash in the Court from which
+it was issued - there exists no right or duty to disclose the confidential Non-Prosecution
+Agreement or the non-public witness/victim list which was referenced in paragraph 7 of the
+NPA. Further, given that the witness/victim list was compiled based on the federal grand jury
+investigation, we object under Fed. R. Crim. P. 6(e) to its disclosure absent an appropriate court
+order.
+Very truly yours,
+Mate Is Warly 120
+Martin G. Weinberg
+ce: Roy Black
diff --git a/vision-fixhub/ds9-unparsed-06/05be0adb1d5dce2e348e3b0a95c8e60960ac0d26a173c6eeaf469795b2d855a7.receipt.json b/vision-fixhub/ds9-unparsed-06/05be0adb1d5dce2e348e3b0a95c8e60960ac0d26a173c6eeaf469795b2d855a7.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2f224d9e983cb4b77ef574db776d37facb4cde90
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/05be0adb1d5dce2e348e3b0a95c8e60960ac0d26a173c6eeaf469795b2d855a7.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "05be0adb1d5dce2e348e3b0a95c8e60960ac0d26a173c6eeaf469795b2d855a7",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "4f7ed88550abe61b4e8d8bdbd3883092b5798cc967f786ee4234f45c46c41252",
+  "output_sha256": "d6181aa2fb52d95cde20118214794acaf09540e87e919268198dc8d3c5bde1d0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/05d125fed182b92bdf52a66b521e78a7007e5dfa998e4829aaa4764d4d20df49.md b/vision-fixhub/ds9-unparsed-06/05d125fed182b92bdf52a66b521e78a7007e5dfa998e4829aaa4764d4d20df49.md
new file mode 100644
index 0000000000000000000000000000000000000000..85c8f8332b809b6e13354fe22b489841bab5dbd2
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/05d125fed182b92bdf52a66b521e78a7007e5dfa998e4829aaa4764d4d20df49.md
@@ -0,0 +1,11 @@
+From:
+To: Roy BLACK
+Cc:
+Subject: Jeffrey Epstein
+Date: Fri, 02 Apr 2010 14:57:27 +0000
+Importance: Normal
+Attachments: 20100402
+tr_to_Black.pdf
+Dear Roy: Attached please find our response to your letter of March 29, 2010. Thank you.
+<<20100402
+Ltr to Black.pdf>>
diff --git a/vision-fixhub/ds9-unparsed-06/05d125fed182b92bdf52a66b521e78a7007e5dfa998e4829aaa4764d4d20df49.receipt.json b/vision-fixhub/ds9-unparsed-06/05d125fed182b92bdf52a66b521e78a7007e5dfa998e4829aaa4764d4d20df49.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b7cf6ada91f26ed0b85c22fc1cd83924a2a7f38c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/05d125fed182b92bdf52a66b521e78a7007e5dfa998e4829aaa4764d4d20df49.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "05d125fed182b92bdf52a66b521e78a7007e5dfa998e4829aaa4764d4d20df49",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "f9448ec0408bc743fbe3cff6c2471061d0970b6a4fcbaecb4eaeccd96b139051",
+  "output_sha256": "8c0b879cac70e3451c4974e52190094d5ffa2386ff39f1548ccea95d02a3a884",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/06364f98abb5bc47d1c81bcab94ccb85fcdc38102d615211333818d384282ece.md b/vision-fixhub/ds9-unparsed-06/06364f98abb5bc47d1c81bcab94ccb85fcdc38102d615211333818d384282ece.md
new file mode 100644
index 0000000000000000000000000000000000000000..eb52c95a9cb10d89680543f9d2512f79687fa7a0
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/06364f98abb5bc47d1c81bcab94ccb85fcdc38102d615211333818d384282ece.md
@@ -0,0 +1,219 @@
+Case 9:08-cv-80736-KAM
+Document 13
+Entered on FLSD Docket 07/15/2008
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA/JOHNSON
+IN RE: JANE DOE,
+Petitioner.
+FILED by_ZA D.C.
+JUL 0 9 2008
+STEVEN US AT CT
+S.D. OF FLA. - W.PE
+GOVERNMENT'S RESPONSE TO VICTIM'S EMERGENCY PETITION
+FOR ENFORCEMENT OF CRIME VICTIM RIGHTS ACT, 18 U.S.C. § 3771
+The United States of America, by and through its undersigned counsel, files its Response
+to Vietim's Emergency Petition for Enforcement of Victim Rights Act, 18 U.S.C. § 3771, and
+states:
+THERE IS NO "COURT PROCEEDING" UNDER 18 U.S.C. § 3771(b)
+Petitioner complains that she has been denied her rights under the Crime Victims Rights
+Act, 18 U.S.C. § 3771. In the emergency petition filed by the victim, she alleges the Government
+has denied her rights since she has received no consultation with the attorney for the government
+regarding possible disposition of the charges (18 U.S.C. § 3771(a)(5)); no notice of any public
+court proceedings (18 U.S.C. § 3771(a)(2)); no information regarding her right to restitution (18
+U.S.C. § 3771(a)(6)); and no notice of rights under the Crime Victim Rights Act (CVRA).
+Emergency Petition, 1 S.
+The instant case is unique in several respects. First, in 2006, Jeffrey Epstein was charged
+with felony solicitation of prostitution in the Circuit Court of the Fifteenth Judicial Circuit, Palm
+Beach County, Florida. This charge was based upon the offenses alleged in paragraph 1 of the
+petition. Second, while Epstein has been under federal investigation, he has not been charged in
+7/B
+
+
+Case 9:08-cv-80736-KAM Document 13 Entered on FLSD Docket 07/15/2008 Page 2 of 8
+the Southern District of Florida.
+Title 18, U.S.C., Section 3771(b)(1) provides in pertinent part that, "li]n any court
+proceeding involving an offense against a crime victim, the court shall ensure that the crime
+victim is afforded the rights described in subsection (a)." There is no "court proceeding" in the
+instant case since Epstein has not been charged with violation of any federal statute. No federal
+grand jury indictment has been returned, nor has any criminal information been filed. There can
+thus be no failure of a right to notice of a public court proceeding or the right to restitution.
+In her memorandum, petitioner relies upon In Re Dean, 527 F.3d 391 (Sth Cir. 2008),
+where the Fifth Circuit held that the CVRA required the government to "confer in some
+reasonable way with the victims before ultimately exercising its broad discretion." Id. at 395. In
+Dean, the government sought and obtained an ex parte order permitting it to negotiate a plea
+agreement with BP Products North America, without first consulting with the victims,
+individuals injured and survivors of those killed in a refinery explosion. A plea agreement was
+ultimately negotiated and the victims objected. The appellate court found that the CVRA granted
+a right to confer. However, the court declined to grant mandamus relief for prudential reasons,
+finding that the district court had the benefit of the views of the victims who chose to participate
+at the hearing held on whether the plea agreement should be accepted. Id. at 396.
+Dean is legally distinguishable in several respects. For one thing, the court's discussion
+of the scope of the right to confer was unnecessary because the court ultimately declined to issue
+mandamus relief. Dean, 527 F.3d at 395. Also, in offering its view that this right applies precharge, it is noteworthy that the court, in purporting to quote the statute, omitted the last three
+words of section 3771(a)(5)("*in the case"), words that arguably point in the opposite direction by
+- 2-
+
+
+Case 9:08-cv-80736-KAM Document 13 Entered on FLSD Docket 07/15/2008 Page 3 of 8
+suggesting that the right applies post-charge. Further, the court went to great lengths to
+emphasize that its holding was limited to the particular circumstances presented in that case (i.e.,
+the simultaneous filing of a plea agreement and formal charges), which of course, is not the case
+here. No federal charges have been filed in the instant case, and this case, unlike Dean, involves
+an agreement to defer federal prosecution in favor of prosecution by the State of Florida and not a
+guilty plea. Id. at 394. Finally, the Dean court expressly declined to "speculate on the [right to
+confer's] applicability to other situations." Id. Nothing in § 3771(a)(5) supports the petitioner's
+claim that she had a right to be consulted before the Government could enter into a nonprosecution agreement which defers federal prosecution in exchange for state court resolution of
+criminal liability, and a significant concession on an element of a claim for compensation under
+18 U.S.C. § 2255.
+II.
+THE GOVERNMENT HAS USED ITS BEST EFFORTS TO COMPLY WITH
+18 U.S.C. § 3771(a)
+The Epstein case was investigated initially by the Palm Beach Police Department in 2006.
+Exhibit A, Declaration of Assistant United States Attorney A. Marie Villafaña, 9 2.
+Subsequently, the Palm Beach Police Department sought the assistance of the Federal Bureau of
+Investigation (FBI). Id. Throughout the investigation, when a victim was identified, victim
+notification letters were provided to the victim by both the FBI Victim-Witness Specialist and
+AUSA Villafaña. Id., 1 3. Petitioner's counsel, Brad Edwards, Esq., currently represents C.W.,
+T.M., and S.R. The U.S. Attorney's Office victim notification letter to C.W. was provided by the
+FBl. and the letter to T.M. was hand-delivered by AUSA Villafaña to her when she was
+interviewed in April 2007. FBI victim notification letters were mailed to C.W. and T.M. on
+- 3-
+
+
+Case 9:08-cv-80736-KAM Document 13 Entered on FLSD Docket 07/15/2008 Page 4 of 8
+January 10, 2008, and to S.R. on May 30, 2008. Villafaña Decl., 9 3.
+Throughout the investigation, AUSA Villafaña and the FBI's Victim-Witness Specialist
+had contact with C.W. Villafaña Decl., 9 4. Earlier in the investigation, T.M. was represented by
+James Eisenberg, Esq. Consequently, all contact with T.M. was made through Mr. Eisenberg.
+In mid-2007, Epstein's attorneys approached the U.S. Attorney's Office in an effort to
+resolve the federal investigation. Id., 1 5. At that time, Mr. Epstein had been charged by the
+State of Florida with solicitation of prostitution, in violation of Florida Statutes § 796.07. Mr.
+Epstein's attorneys sought a global resolution of this matter. The United States subsequently
+agreed to defer federal prosecution in favor of prosecution by the State of Florida, so long as
+certain basic preconditions were met. One of the key objectives for the Government was to
+preserve a federal remedy for the young girls whom Epstein had sexually exploited. Thus, one
+condition of that agreement, notice of which was provided to the victims on July 9, 2008, is the
+following:
+"Any person, who while a minor, was a victim of a violation of an
+offense enumerated in Title 18, United States Code, Section 2255,
+will have the same rights to proceed under Section 2255 as she
+would have had, if Mr. Epstein had been tried federally and
+convicted of an enumerated offense. For purposes of
+implementing this paragraph, the United States shall provide Mr.
+Epstein's attorneys with a list of individuals whom it was prepared
+to name in an Indictment as victims of an enumerated offense by
+Mr. Epstein. Any judicial authority interpreting this provision,
+including any authority determining which evidentiary burdens if
+any a plaintiff must meet, shall consider that it is the intent of the
+parties to place these identified victims in the same position as they
+would have been had Mr. Epstein been convicted at trial. No
+more; no less."
+The Attorney General Guidelines for Victim and Witness Assistance (May 2005), Article
+- 4-
+
+
+Case 9:08-cv-80736-KAM Document 13 Entered on FLSD Docket 07/15/2008 Page 5 of 8
+IV, Services to Victims and Witnesses, provides the following guidance for proposed plea
+agreements:
+(3) Proposed Plea Agreements. Responsible officials should make reasonable
+efforts to notify identified victims of, and consider victims' views about,
+prospective plea negotiations. In determining what is reasonable, the responsible
+official should consider factors relevant to the wisdom and practicality of giving
+notice and considering views in the context of the particular case, including, but
+not limited to, the following factors:
+(a) The impact on public safety and risks to personal safety.
+(b) The number of victims.
+(c) Whether time is of the essence in negotiating or entering a proposed plea.
+(d) Whether the proposed plea involves confidential information or conditions.
+(e) Whether there is another need for confidentiality.
+(f) Whether the victim is a possible witness in the case and the effect that relaying any
+information may have on the defendant's right to a fair trial.
+Throughout negotiations, Epstein's attorneys claimed that one reason victims came
+forward and pressed their claims was their desire for money. They argued that victims might
+have an inducement to fabricate or enhance their testimony, in order to maximize their
+opportunities to obtain financial recompense. Villafaña Decl., 1 8. The Government was
+extremely concerned that disclosure of the proposed terms would compromise the investigation
+by providing Epstein the means of impeaching the victim witnesses, should the parties fail to
+reach an agreement. In light of the fact (i) that the United States agreed to defer prosecution to a
+previously filed state criminal case; (ii) that as a result sentencing would take place in state court
+before a state judge; (iii) that if the state resolution failed to meet minimum standards such that a
+federal prosecution was warranted, the victims would be witnesses and thus potential
+- 5-
+
+
+Case 9:08-cv-80736-KAM Document 13 Entered on FLSD Docket 07/15/2008 Page 6 of 8
+impeachment issues were of concern; and (iv) the United States was already making efforts to
+secure for victims the right to proceed federally under 18 U.S.C. § 2255 even if prosecution took
+place in state court, the Government determined that its actions in proceeding with this
+agreement best balanced the dual position of the Jane Does as both victims and potential
+witnesses in a criminal proceeding
+On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA Villafaña received a copy
+of the proposed state plea agreement, and learned that Epstein's state plea hearing was scheduled
+for Monday, June 30, 2008, at 8:30 a.m. Villafaña Decl., 9 10. AUSA Villafaña and the Palm
+Beach Police Department attempted to provide notification to victims in the short time that they
+had. Id. Although all known victims were not notified, AUSA Villafaña did call attorney
+Edwards to provide notice to his clients regarding the hearing. AUSA Villafaña did this, even
+though she had no obligation to provide notice of a state court hearing. Mr. Edwards advised that
+he could not attend but that someone would be present at the hearing. Id.
+The Government has complied with 18 U.S.C. § 3771(c)(1) by using its best efforts to
+"see that crime victims are notified of, and accorded, the rights described in subsection (a)."
+Specifically, petitioner was afforded the reasonable right to confer with the attorney for the
+Government under 18 U.S.C. § 3771(a)(5). Disclosure of the specific terms of the negotiation
+were not disclosed prior to a final agreement being reached because the Government believed
+doing so would jeopardize and prejudice the prosecution in the event an agreement could not be
+made. Further, although 18 U.S.C. § 3771(a)(2) does not apply to state court proceedings, the
+government nonetheless notified petitioner's counsel on June 27, 2008, of the plea hearing in
+state court on June 30, 2008.
+- 6-
+
+
+Case 9:08-cv-80736-KAM Document 13 Entered on FLSD Docket 07/15/2008 Page 7 of 8
+Section 3771(d)(6) provides, in relevant part, that "InJothing in this chapter shall be
+construed to impair the prosecutorial discretion of the Attorney General or any officer under his
+direction." The Government exercised its judgment and discretion in determining that there was
+a need for confidentiality in the negotiations with Epstein. The significant benefit of obtaining
+Epstein's concession that victims suing him under 18 U.S.C. § 2255(a) were "victims" of the
+enumerated offenses, despite the fact he has not been convicted in federal court, was of sufficient
+importance to justify confidentiality of the negotiations.
+III. THE GOVERNMENT'S DISCUSSIONS WITH T.M., C.W., AND S.R.
+Attorney Brad Edwards has advised the Government that he represents T.M., C.W., and
+S.R. Victim letters were provided to all three individuals. The letters to C. W. and T.M. were
+forwarded on January 10, 2008. Villafaña Decl., ° 3. On May 28, 2008, S.R.'s status as a victim
+was confirmed when she was interviewed by federal agents. Id. The FBI Victim Witness
+specialist sent her a letter on May 30, 2008. Id.
+When the agreement was signed in September 2007, T.M. was openly hostile to a
+prosecution of Epstein, and S.R. had refused to speak with federal investigators. Id., 9 7. While
+individual victims were not consulted regarding the agreement, none of Mr. Edwards' clients
+had expressed a desire to be consulted prior to the resolution of the federal investigation. Id.
+In October 2007, C. W. was not represented by counsel. Id.. 18. She was given
+telephonic notice of the agreement, as were three other victims. Id. These four individuals were
+also given notice of an expected change of plea, in state court, in October 2007.
+In mid-June 2008, Mr. Edwards contacted AUSA Villafaña to advise that he represented
+C. W. and S.R., and requested a meeting. Id., 1 9. AUSA Villafaña asked Mr. Edwards to send
+- 7-
+
+
+Case 9:08-cv-80736-KAM
+Document 13 Entered on FLSD Docket 07/15/2008 Page 8 of 8
+to her any information that he wished her to consider. Nothing was provided. Id. AUSA
+Villafaña also told Mr. Edwards he could contact the State Attorney's Office, if he wished. To
+her knowledge, Mr. Edwards did not make the contact.
+The Government has acted reasonably in keeping T.M, C.W., and S.R. informed
+Petitioner's rights under the CVRA have not been violated. Therefore, her emergency petition
+should be denied.
+Respeetfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+Assistant U.S. Attorney
+99 N.E. 4" Street
+Miami, Florida 33132
+Attorney for Respondent
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via facsimile
+transmission and U.S. Mail, this day of July, 2008, to: Brad Edwards, Esq., The Law
+Offices of Brad Edwards & Associates, LLC,
+Assistant U.S. Attorney
+- 8-
diff --git a/vision-fixhub/ds9-unparsed-06/06364f98abb5bc47d1c81bcab94ccb85fcdc38102d615211333818d384282ece.receipt.json b/vision-fixhub/ds9-unparsed-06/06364f98abb5bc47d1c81bcab94ccb85fcdc38102d615211333818d384282ece.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..aebdc2da8e1a973da22a4e9fee16fb000e32667f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/06364f98abb5bc47d1c81bcab94ccb85fcdc38102d615211333818d384282ece.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -111,
+  "dataset": "marble-joined",
+  "doc_id": "06364f98abb5bc47d1c81bcab94ccb85fcdc38102d615211333818d384282ece",
+  "engine": "marble-apple-vision",
+  "event_count": 11,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "f47e85d66f8958b57f3131b4de8f7b27b5f574d72d2dbd0ccd01100a8501ee9d",
+  "output_sha256": "24d9b50a1fb2d936010f16b1d56ddd0fa8c77968161a69af91624fa79a5c904b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/06397bc34fa8d1c3dc240a664553e295dad9837186a8bf41819ec4259278359b.md b/vision-fixhub/ds9-unparsed-06/06397bc34fa8d1c3dc240a664553e295dad9837186a8bf41819ec4259278359b.md
new file mode 100644
index 0000000000000000000000000000000000000000..97e15f7850348a7a55af76501a783ae23867319c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/06397bc34fa8d1c3dc240a664553e295dad9837186a8bf41819ec4259278359b.md
@@ -0,0 +1,8 @@
+From:
+To: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+Subject: Out of Office AutoReply: Activity in Case 9:08-cv-80119-KAM Doe I. Epstein Extension of
+Time to File Response/Reply
+Date: Thu, 18 Mar 2010 19:09:31 +0000
+Importance: Normal
+I will be in court this afternoon and will have only limited access to email. If the matter is urgent, please contact my assistant, Fran Prager.
+Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/06397bc34fa8d1c3dc240a664553e295dad9837186a8bf41819ec4259278359b.receipt.json b/vision-fixhub/ds9-unparsed-06/06397bc34fa8d1c3dc240a664553e295dad9837186a8bf41819ec4259278359b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c0574568dda55abc71976491079d08eb0a895a1a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/06397bc34fa8d1c3dc240a664553e295dad9837186a8bf41819ec4259278359b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "06397bc34fa8d1c3dc240a664553e295dad9837186a8bf41819ec4259278359b",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "d1bb316632a280e7fa38d0e3f2e96e8fa86928a753527c19b18d9b93fe58f86b",
+  "output_sha256": "d7d4902f3f202f264438bc5a1752106755998c390b51e87fc76ea6a2f858d555",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/065d64c006dabbc275ebbadef5b2d2bf28b47928d1a00af32bb2ff28556d0ffd.md b/vision-fixhub/ds9-unparsed-06/065d64c006dabbc275ebbadef5b2d2bf28b47928d1a00af32bb2ff28556d0ffd.md
new file mode 100644
index 0000000000000000000000000000000000000000..239268f25aef2ecc7f1b5221bba554f3b47b9033
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/065d64c006dabbc275ebbadef5b2d2bf28b47928d1a00af32bb2ff28556d0ffd.md
@@ -0,0 +1,35 @@
+From:
+T0:
+(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=
+(USAFLS)" <
+Cc:
+- (USAFLS)"
+Subject: FW: Jeffrey Epstein
+Date: Tue, 22 May 2007 19:10:31 +0000
+Importance: Normal
+Attachments: 2007-05-22
+_letter_to_AUSA
+pdf
+(USAFLS)"
+Gentlemen,
+and I have already met with Lefcourt, which is really the meeting I promised him. I spoke to him last week and he
+said he had more information they wanted to present. I told him he could make an appointment to come in again if he
+wanted to and that we would meet with him again, but I did not promise that we would wait to give him a meeting
+"before" we charged.
+So, I think he is really ready for the next level rather than a second meeting with me.
+also mentioned to me at
+some point that they wanted to make a presentation on the law and I suggested to him that he contact without
+telling him exactly what stage of review we were at. I don't know if and Lefcourt have crossed wires or not.
+In any event, I am forwarding this letter to you. I am going to suggest to Lefcourt the same thing that I suggested to
+I assume you would grant his attorneys a chance to make whatever presentation they desire. It would probably be
+helpful to us in any event to hear their legal arguments in case we have missed something. Whether Alex would be
+present or grant them another meeting after that is his call.
+From: Gerald Lefcourt [mailto:
+Sent: Tuesday, May 22, 2007 2:05 PM
+(USAFLS)
+1. (USAFLS); Lilly Ann Sanchez
+Subject: Jeffrey Epstein
+attached is a letter seeking meetings, as discussed with you, but with others if it is not resolved. Thanks for your
+attention.
+Could you email back so that I know you have received this letter?
+Gerald B. Lefcourt, P.C.
diff --git a/vision-fixhub/ds9-unparsed-06/065d64c006dabbc275ebbadef5b2d2bf28b47928d1a00af32bb2ff28556d0ffd.receipt.json b/vision-fixhub/ds9-unparsed-06/065d64c006dabbc275ebbadef5b2d2bf28b47928d1a00af32bb2ff28556d0ffd.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2ba97c1294affd47506a2d4da1f301a4c9b47070
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/065d64c006dabbc275ebbadef5b2d2bf28b47928d1a00af32bb2ff28556d0ffd.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "065d64c006dabbc275ebbadef5b2d2bf28b47928d1a00af32bb2ff28556d0ffd",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "c6ab045f25e03eaf638ca977fd4cc795ea5c4989853a56cc63ef6e2b78065bce",
+  "output_sha256": "0adc83186e21ec0800c9ea38e46498d33e3d7095ad3d2b02f3dbebf265945992",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/066329ad0d95b696d692774b99cf3c0f6911e2b303293603c7998e8c397ce258.md b/vision-fixhub/ds9-unparsed-06/066329ad0d95b696d692774b99cf3c0f6911e2b303293603c7998e8c397ce258.md
new file mode 100644
index 0000000000000000000000000000000000000000..43dd5245c26d3527beb2664e9b50bd2ffe27cfc3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/066329ad0d95b696d692774b99cf3c0f6911e2b303293603c7998e8c397ce258.md
@@ -0,0 +1,10 @@
+Subject: Re: I sent a total of 8 emails
+Date: Fri, 29 Oct 2010 01:41:33 +0000
+Importance: Normal
+Yes we have two sets. I will get on these asap. G'nite
+Sent: Thursday, October 28, 2010 08:43 PM
+Subject: I sent a total of 8 emails
+These are the emails re Epstein. Some of those 8 email contain multiple emails within. Please let
+me know if you have any trouble opening any of them.
+Do you still have the big correspondence notebooks in case Ben or Willy need them?
+Thanks!
diff --git a/vision-fixhub/ds9-unparsed-06/066329ad0d95b696d692774b99cf3c0f6911e2b303293603c7998e8c397ce258.receipt.json b/vision-fixhub/ds9-unparsed-06/066329ad0d95b696d692774b99cf3c0f6911e2b303293603c7998e8c397ce258.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..077be29e2ae948e16234fe0236f9720bcb99be4d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/066329ad0d95b696d692774b99cf3c0f6911e2b303293603c7998e8c397ce258.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "066329ad0d95b696d692774b99cf3c0f6911e2b303293603c7998e8c397ce258",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "77b6cafde8827be4ea3883784bd88d850478d705de597f5c13b39072733db244",
+  "output_sha256": "dc57387bcd81b96005b5da0b35321e6f200a91d9e2e53f057bd155a02698f2d4",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0691cace0eb84d7ef3de424af5820150a9ce913ee1bc4a6278ed8f51aa3343b7.md b/vision-fixhub/ds9-unparsed-06/0691cace0eb84d7ef3de424af5820150a9ce913ee1bc4a6278ed8f51aa3343b7.md
new file mode 100644
index 0000000000000000000000000000000000000000..7ea6842c82c19da652d802b4c6903c0289e30ddf
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0691cace0eb84d7ef3de424af5820150a9ce913ee1bc4a6278ed8f51aa3343b7.md
@@ -0,0 +1,507 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs
+V.
+UNITED STATES,
+Defendants
+JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR PRODUCTION
+TO THE GOVERNMENT REGARDING INFORMATION RELEVANT TO THEIR
+PENDING ACTION CONCERN THE CRIME VICTIMS RIGHTS ACT
+COME NOW Jane Doe #1 and Jane Doe #2 ("the victims"), by and through undersigned
+counsel, and request the defendant United States (hereinafter "the Government") to produce the
+original or best copy of the items listed herein below for inspection and/or copying, pursuant to
+the Court's Order (DE #99) directing discovery in this case.
+BACKGROUND
+As the Government will recall, the victims have asked the Government to stipulate to
+undisputed facts in this case. The Government has declined. Accordingly, the victims filed their
+Motion for Finding of Violations of the Crime Victims' Rights Act and Request for a Hearing on
+Appropriate Remedies (DE 48) (the victims* "summary judgment motion") along with a Motion
+to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts
+(DE 49).
+On September 26, 2011, the Court denied the victims" motion to have their facts accepted
+(DE 99 at 11). At the same time, however, the Court has ordered discovery to develop the
+
+
+factual record concerning the summary judgment motion (DE 99 at 11). The Court reserved
+ruling on the victims' motion for an order directing the Government not to suppress relevant
+evidence (DE 99 at 11).
+On September 28, 2011, the victims requested that the Government voluntarily provide
+documents concerning this case. The Government declined to provide even a single document.
+Accordingly, the victims now seek the following information relevant to their pending summary
+judgment motion.
+DISCOVERY REQUESTED
+The numbered discovery requests below should all be construed in light of the definitions of
+terms provided at the end of the requests.
+1. In the victims' currently-pending summary judgment motion, the victims contend that the
+Government conducted an extensive criminal investigation into Jeffrey Epstein's sexual
+exploitation of young girls, including Jane Doe #1 and Jane Doe #2 between 2001 and 2008.
+The victims also contend that the FBI and other federal agencies established that Epstein
+operated a large criminal enterprise that used paid employees and underlings to repeatedly find
+and bring minor girls to him. In deferring ruling on the victims' summary judgment motion, the
+Court noted that the victims had alleged that the FBI and the U.S. Attorney's Office's
+"investigation developed a strong case for a federal prosecution against Epstein based on
+"overwhelming' evidence." DE 99 at 2. The Court, however, also noted that this was an
+allegation that needed "further factual development." DE 99 at 2 n.2. Please provide all
+documents, correspondence, and other information that supports these victims" allegations,
+including:
+(a) the FBI case file on the Epstein case;
+(b) all documents, correspondence, witness statements, FBI 302s, and other
+similar information, that the Government collected as part of its case against
+and/or investigation of Epstein, including any information provided to Epstein
+or receive from Epstein as part of "discovery" or exchange of information
+concerning the case;
+(c) all documents, correspondence, witness statements, and other similar
+information that the Government received from any federal, state, local, or
+other law enforcement agency regarding sex offenses committed against
+children by Jeffrey Epstein;
+(d) the 82-page prosecution memorandum (a/k/a "pros memo") outlining
+numerous federal sexual offenses committed by Epstein (and any attachments
+to that memorandum) and the 53-page draft indictment for numerous federal
+
+
+offenses that the Government developed in this case and any similar successor
+or predecessor document; and
+(e) Any other prosecution memorandum regarding Jeffrey Epstein (and any
+documents attached to that memorandum) and all draft federal indictments
+that were prepared regarding Epstein. Please also provide all documents,
+correspondence, and
+other information regarding these prosecution
+memoranda and the draft federal indictments.
+2. Throughout their pending summary judgment motion, the victims contend that they
+received only limited notifications from the Government (and, in particular, the U.S. Attorney's
+Office acting through FBI agents) about the plea negotiations that occurred with Jeffrey Epstein
+and the non-prosecution agreement that was ultimately reached. Please provide all documents,
+correspondence and other information regarding victim notifications in this case, including (but
+not limited to):
+a) All crime victims notifications (and draft notifications) sent to Jane Doe #1 and
+Jane Doe #2 and the other identified victims of Epstein's offenses;
+b) All correspondence, documents, and other information regarding negotiations
+between the Government and Epstein's defense attorneys concerning the extent
+and nature of notifications to be made to Epstein's victims;
+c) All correspondence, documents, and other information regarding discussions
+between the Government, the FBI, the Palm Beach Police Department, the Palm
+Beach County State Attorney's Office, and Epstein's defense attorneys
+concerning the extent and nature of notifications to be made to Epstein's victims;
+d) All correspondence, documents, and other information regarding "marching
+orders" that were given to FBI agents regarding the information that they could
+provide to the victims about the negotiations and the non-prosecution agreement;
+e) All correspondence, documents, and other information regarding information that
+could be given to attorneys for the victims about the non-prosecution agreement,
+including information about what could be told to Brad Edwards (counsel for Jane
+Doe #1 and Jane Doe #2) about the non-prosecution agreement;
+f) All correspondence, documents, and other information regarding Epstein's
+awareness that his victims (including Jane Doe #1 and Jane Doe #2) would not be
+notified of the non-prosecution agreement (and its ultimate presentation in court)
+or given a chance to confer regarding the plea negotiations he was conducting
+with the Government.
+3. The victims allege in their pending summary judgment motion that the Government
+negotiated a non-prosecution agreement with Epstein and that among the subjects covered in that
+non-prosecution agreement was a confidentiality provision that precluded disclosing the
+agreement to them and to other victims. Please provide all draft plea agreements (both state and
+tederal) and non-prosecution agreements prepared either by attorneys for the Government or by
+attorneys for Epstein, as well as any correspondence, documents or other information pertaining
+to these agreements and to any confidentiality provision in these agreements. Please indicate
+that date on which each of these proposed agreements was drafted and by whom.
+
+
+4. The victims allege in their pending summary judgment motion that the Government was
+interested in finding a place to conclude any plea agreement that would effectively keep
+Epstein's vietims (most of whom resided in or about West Palm Beach) from learning what was
+happening through the press.
+Please provide all correspondence, documents, and other
+information pertaining to negotiations between the Government and Jeffrey Epstein concerning
+the court and/or location in which Jeffrey Epstein would enter any guilty plea (including in
+particular any negotiations concerning concluding the plea in Miami or other location outside of
+West Palm Beach).
+5. The victims allege in their pending summary judgment motion that part of the plea
+negotiations with Epstein involved Epstein's efforts to make sure that the victims would be
+represented in civil cases against Epstein by someone who was not an experienced personal
+injury lawyer. Please provide all correspondence, documents, and other information pertaining
+to negotiations between the Government and Jeffrey Epstein regarding any legal representation
+of the victims in civil cases against Epstein, including any negotiations about what kinds of
+representation should be provided in a plea agreement or non-prosecution agreement.
+6. The victims allege in their pending summary judgment that the Government wanted the
+non-prosecution agreement with Epstein concealed from public view because of the intense
+public criticism that would have resulted had the agreement been disclosed and/or the possibility
+that victims would have objected in court and convicted the judge not to accept the agreement.
+Please provide all correspondence, documents, and other information concerning the
+Government's and/or Epstein awareness or discussion of this possible public criticism and/or
+victim objections.
+7. The victims allege in their pending summary judgment motion that the Government was
+aware that it potentially had obligations under the CVRA to notify the victims about the nonprosecution agreement and any related state court plea agreement. Please provide all
+correspondence, documents, and other information regarding the Government's awareness of its
+potential CVRA obligations in this case and regarding any discussions between the Government
+and Epstein concerning these CVRA obligations in this case. This should include any objections
+raised by Epstein to any notification of the victims (including Jane Doe #1 and Jane Doe #2) and
+any Government response to these objections. This should also include any correspondence and
+information about whether the CVRA applied to the victims.
+8. The victims allege in their pending summary judgment motion that, after Epstein signed
+the non-prosecution agreement, his performance was delayed while he used his significant social
+and political connections to lobby the Justice Department to obtain a more favorable plea deal
+(including lobbying components of the Justice Department in Washington, D.C., including the
+Child Exploitation Obscenity Section). Please provide all correspondence, documents, and other
+information regarding Epstein's lobbying efforts to persuade the Government to give him a more
+favorable plea arrangement and/or non-prosecution agreement, including efforts by former
+President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York),
+Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy
+Black on his behalf.
+
+
+9. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI
+advising them that "this case is currently under investigation." Please provide all documents,
+correspondence, and other information relating to those representations being made by the FBI to
+Jane Doe #1 and Jane Doe #2, including all information about whether the FBI was aware of the
+non-prosecution agreement at that time and about whether Epstein was aware of the notifications
+being made to the victims.
+10. In their pending summary judgment motion, the victims have alleged that the FBI was led
+to believe that their investigation of Epstein was going to produce a federal criminal prosecution
+and that the FBI was also misled by the U.S. Attorney's office about the status of the case.
+Please provide all documents, correspondence, and other information relating to these
+allegations, including:
+) All documents, correspondence, and other information relating to discussior
+etween the U.S. Attorney's Office and the FBI concerning the status of th
+investigation and the plea discussions with Epstein, as well as what kind of
+charges would appropriately be filed against Epstein;
+b) All documents, correspondence, and other information relating to the U.S.
+Attorney's Office's representations to the FBI and any other state or local law
+enforcement agency about how this case was being handled; and
+c) All documents, correspondence, and other information relating to whether the FBI
+would support the position of the U.S. Attorney's Office that it has not violated
+the rights of Epstein's victims in this case.
+11. In their pending summary judgment motion, the victims have alleged that they had
+various meetings with Government prosecutors and/or agents (including FBI agents). Related to
+these meetings, they also allege that in mid-June 2008, their attorney (Bradley J. Edwards)
+discussed with an AUSA involved in the case the need for filing federal charges and that the
+AUSA asked the attorney to send a letter about why such charges should be filed without
+these meetings with the victims and their legal counsel, including meetings with the victims on
+October 26, 2007, and January 31, 2008, and the contact with their legal counsel in mid-June
+2008. Please also provide all documents, correspondence, and other information related to
+contacts between the Government and the National Crime Victim's Law Institute (NCVLI)
+concerning possible legal representation or other assistance to the victims by NCVLI.
+12. In their pending summary judgment motion, the victims allege that in mid-June 2008,
+their attorney (Bradley J. Edwards) discussed with an AUSA involved in the case the need for
+filing federal charges and that the AUSA asked the attorney to send a letter about why such
+charges should be filed without disclosing the existence of the non-prosecution agreement. The
+victims further allege that on about July 3, 2008, their attorney sent a letter urging the filing of
+federal charges against Epstein. Please provide all documents, correspondence, and other
+information regarding these contacts, including e-mails and correspondence generated as a result
+of the attorney's inquiry and any action that was taken in response to the letter that he sent.
+
+
+13. In their pending summary judgment motion, the victims allege that on or about June 27,
+2008, the Government learned that Epstein would be entering his plea to state charges on about
+June 30, 2008. Please provide all documents, correspondence, and information regarding:
+a) How the Government Office learned that the plea was going to be entered;
+b) How the Government notified victims about the entry of the guilty plea; and
+c) The contents of the notifications given to the victims about the entry of the guilty,
+including whether the victims were informed about the non-prosecution
+agreement and about whether the entry of this plea would preclude prosecution of
+crimes Epstein had committed against them.
+14. In their pending summary judgment motion, the victims have alleged that the
+Government and Epstein worked together to keep the existence of the non-prosecution
+agreement secret, including declining comment about the existence of such an agreement when
+asked about it when his guilty plea in state court became public knowledge. Please provide all
+documents, correspondence, and information about the Government's and Epstein's efforts to
+keep the existence of the non-prosecution agreement secret, including all e-mails and
+correspondence about "declining comment" or similar devices to keep the non-prosecution
+agreement secret.
+15. In their pending summary judgment motion, the victims allege that at all materials times,
+it would have been practical and feasible for the Government to have kept the victims informed
+about the discussions concerning the non-prosecution agreement. The victims further allege that
+on about July 9, 2008, the U.S. Attorney's Office provided notice to Jane Doe #1 of some of the
+terms of the agreement between it and Jeffrey Epstein. The victims also received a "corrected"
+notification letter on about September 3, 2008. Please provide all documents, correspondence,
+and other information about these notifications, including:
+a) any information about whether these notifications should or should not include
+some mention of the non-prosecution agreement;
+b) any information about the contents of these notifications;
+c) any communications between the Government and Epstein's counsel regarding
+what the notifications should contain, including any communication on or about
+July 9, 2008, objecting to parts of the draft;
+d) Any communications between the Government and Epstein's counsel about
+which parts of the non-prosecution agreement were operative (including whether
+Part 3 was operative);
+e) Any communications between the Government and Epstein's counsel regarding
+the September 3, 2008, corrected notification letter; and
+f) any documents, correspondence, and other information regarding the practicality
+and feasibility of providing notice to the victims of the existence of the
+agreement, which shall include any correspondence related to meeting with the
+victims or notifying them in any way of the non-prosecution agreement.
+16. In their pending summary judgment motion, the victims allege that one of the senior
+prosecutors in the U.S. Attorney's Office joined Epstein's payroll shortly after important
+decisions were made limiting Epstein's criminal liability - and improperly represented people
+close to Epstein. In light of this fact, the peculiar nature of the non-prosecution agreement
+
+
+reached in this case, and other information in the possession of the victims, it is also possible that
+other improper relationships exist between Government agents and Epstein. Please provide any
+documents, correspondence, and other information regarding the possibility of any improper
+relationship, including:
+a) Attorney Brac
+involvement in and/or awareness of any aspect of the
+Government's criminal investigation and/or possible prosecution/non-prosecution
+of Epstein;
+b) Attorney Bruce
+involvement in and/or awareness of the Government's
+interest in any witness, subject, or target of the Epstein investigation, including
+Ghislaine Maxwell,
+Lesley Groff,
+•. Larry Morrison, Larry Visoki, David Rogers, William
+Hammond, and Robert Roxburgh;
+c) All documents, correspondence, and other information reflecting telephone calls
+(including telephone logs and telephone billing statements) made by or received
+by Reinhart from Jellrey Epstein, the Florida Science Foundation, Jack
+Goldberger, Alan Dersowitz, Roy Black, Ken Starr, Lillian Sanchez, and any
+other person involved with the criminal defense of Jeffrey Epstein, including
+telephone calls to and from Jack Goldberger and the Florida Science Foundation;
+d) All documents, correspondence, and other information (including, for example, e-
+mails) that were sent to, copied to, or sent by Reinhart in which the word
+"Epstein,"
+"Morrison," "Visoki," "Rogers," "Hammond,"
+"Florida Science Foundation," "Starr," "Black,"
+"Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," "358 El Brillo Way"
+appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger,
+or the Jeffrey Epstein investigation or prosecution;
+e) All documents, correspondence, and other information (including for example e-
+mails) of a similar nature that indicate that any other Government prosecutor has
+represented (or discussed representing) a person or entity related to Jeffrey
+Epstein or has received business or funds from a person or entity related to Jeffrey
+Epstein;
+f) All documents, correspondence, and other information that indicate or suggest
+that any Government prosecutor or investigator (including state and local
+prosecutor or investigator) has had any form of business, social, personal, or other
+relationship with Jeffrey Epstein or a person or entity related to Jeffrey Epstein;
+and
+g) All documents, correspondence, and other information that indicate or suggest
+that any Government prosecutor or investigator (including state and local
+prosecutor or investigator would receive anything of value, directly or indirectly
+from Jeffrey Epstein or a person or entity related to Jeffrey Epstein (including any
+charitable contributions to be made by Epstein to any entity).
+17. In December 2010, the victims sent a letter to the U.S. Attorney's Office for the Southern
+District of Florida, requesting that the Office investigate whether "improper influences" were
+brought to bear during the negotiations involving the possible prosecution (and ultimately the
+non-prosecution) of Jeffrey Epstein. That letter led to a reference of the matter to the Office of
+
+
+Professional Responsibility (OPR) in the Justice Department in Washington, D.C., which began
+some kind of an inquiry/investigation. Please provide:
+a) All documents, correspondence, and other information collected by the Office of
+Professional Responsibility (OPR) and any other component of the Justice
+Department (including the FBI) in response to the victims' letter;
+b) All documents, correspondence, witness statements, and other information
+c) All documents, correspondence, witness statements and other information
+collected as part of any criminal inquiry/investigation that was initiated as a result
+of that letter, including any inquiry/investigation into criminal conflict of interest
+violations (such as 18 U.S.C. § 205 and § 207)
+d) All documents, correspondence, witness statements, and other information
+collected by any federal investigative agency that was triggered by OPR's
+inquiry/investigation, including any FBI inquiry/investigation regarding any
+improper influences or criminal or ethical violations that may have been
+committed by government attorneys during the handling of the Epstein
+investigation and/or prosecution;
+e) Any documents, correspondence, and other information regarding the accuracy or
+inaccuracy of Bruce
+sworn statements (found in DE 79-1 at p. 31) that
+he "did not participate in any way in the Office's investigation of Epstein;" that he
+"was not involved in any of the Office's decisionmaking with regard to the
+Epstein matter;" and that he "never learned any confidential, non-public
+information about the Epstein matter;"
+f) Any documents, correspondence,
+or other
+information regarding the
+circumstances that lead OPR to send a letter to the victims on May 6, 2011,
+indicating that they would not provide any further assistance to the victims in
+connection with their allegations that improper influences were brought to bear on
+the Epstein case;
+g) Any document, correspondence, e-mail, memoranda, or other information
+prepared by OPR, the FBI, or other Justice Department Component as a result of
+or following up on the victims' December 2010 letter concerning the Epstein
+case: and
+h) Any documents, correspondence, or other information that OPR has collected or
+obtained regarding the Epstein investigation and/or prosecution.
+18. At a couple points during the prosecution of this action, including in approximately
+December 2010 and most recently after the August 2011 hearing, the Justice Department in
+Washington, D.C., discussed or determined that the U.S. Attorney's Office for the Southern
+District of Florida (USAO SDFL) was "conflicted out", or may be conflicted out, of handling
+various issues related to the Epstein case because it suffered from a conflict of interest. The
+Justice Department accordingly sent various issues related to the Epstein case (and, on
+information and belief, issues related to Jane Doe #1 and Jane Doe #2) to the Department of
+Justice and to a United States Attorney's Office in another District. Please provide all
+documents, correspondence, and other information regarding the potential conflicts of interest
+that the Justice Department discussed or determined existed for the USAO SDFL, as well as any
+referral that was made to Main Justice or to any other District, including any documents that
+
+
+were transmitted to any other District regarding the conflict and regarding what was to be
+investigated.
+19. In March 2011, former U.S. Attorney Alexander Acosta sent a three-page letter to the
+news media in which he claimed that when Government attorneys began investigating Epstein,
+Epstein launched "a yearlong assault on the prosecution and the prosecutors." Shortly thereafter,
+Jeffrey Epstein's defense attorney Roy Black sent a responsive letter to Alexander Acost's letter
+to the news media in which he claimed that he did not pry into the personal lives of prosecutors
+but merely pointed out misconduct and over-reaching by certain people involved in the Epstein
+investigation. Please provide all documents, correspondence and other information that supports
+or contradicts Acosta's allegations in his letter, including any information that the Justice
+Department received from Epstein attacking the prosecutors and investigators working on the
+case. Please also provides all documents, correspondence, information about misconduct and
+over-reaching that was provided by Black and that the Government found that supported or
+contradicted such allegations.
+20. In their pending summary judgment motion, the victims have alleged that Epstein's guilty
+plea to state charges was intended to be the consummation of a non-prosecution agreement that
+barred prosecution of federal offenses committed against them. They have further alleged that
+Epstein entered such a guilty plea on or about June 30, 2008. Please provide all documents,
+correspondence, and other information between the Government and state and local prosecutors
+and police agencies (including The Palm Beach Police Department and Palm Beach State
+Attorney's Office) regarding the Epstein investigation and ultimate Epstein plea.
+21. In their pending summary judgment motion, the victims have alleged that correspondence
+in the possession of the Government will support their claims. Please provide all documents,
+correspondence, and other information between Government attorneys/officials (including both
+federal and state prosecutors) and attorneys for Jeffrey Epstein (or non-attorney acting on
+Epstein's behalf) relating to (1) negotiations involving the possible prosecution (and ultimately
+the non-prosecution) by federal or state agencies for sex offenses, including sex offenses
+committed against Jane Doe #1 and Jane Doe #2, (2) Epstein's entry of state guilty pleas for
+related sex offenses; (3) a non-prosecution agreement entered into between Epstein and the
+Government that barred his prosecution for offenses committed against Jane Doe #1 and Jane
+Doe #2; (4) the fulfillment of Epstein's and/or the Government's obligations under the nonprosecution agreement and/or the state guilty pleas Epstein entered; (5) any work release or other
+conditional release of Epstein from confinement; (6) any designation of Epstein as a sex offender
+or restrictions on him contacting victims of his offenses (including Jane Doe #1 and Jane Doe
+#2); and (7) any termination of supervision or parole of Epstein. This information should include
+unredacted e-mails, letters, and correspondence of any type between government prosecutors
+working on the case (including, but not limited to, federal prosecutors Alexander Acosta,
+and state prosecutors
+_and others involved in the Epstein
+investigation) and defense attorneys representing Epstein (including, but not limited to, Roy
+Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy
+Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein
+(including, but not limited to former President Bill Clinton and Andrew Albert Christian Edward
+
+
+(a/k/a Prince Andrew, Duke of York). This should also include letters of recommendation or
+similar communications submitted to any Government official vouching for or providing support
+for Jeffrey Epstein.
+22. As you know, throughout their pending summary judgment motion, the victims have
+alleged that they were not properly notified of plea negotiations with Jeffrey Epstein and were
+denied their right to confer by the Government and that instead the Government gave Epstein
+generous concessions through the plea negotiations. Please provide any documents,
+correspondence and other information that reflects or discusses any consideration of any type
+that Epstein had previously provided or offered to provide to the Government (or any individual
+within the Government, in either his official or private capacity) or any person previously
+employed by the Government and involved in the Epstein investigation or prosecution. The
+documents, correspondence, and other information should include any information discussing:
+(a) Any donation or offer to donate, directly or indirectly, either funds, services,
+or any other valuable consideration to any person or entity;
+(b) Any offer to assist, directly or indirectly, any person to obtain employment,
+business opportunities, business clients, real estate, office properties;
+(c) Any offer to assist the Government or law enforcement agencies in the
+investigation or prosecution of any federal or state criminal offense;
+(d) Any consideration that Epstein had provided to Government or law
+enforcement agencies in the past; and
+(e) Any other consideration of any type that Epstein offered to provide or had
+provided in the past that could provide a basis for the Government extending
+Epstein a more generous or lenient plea bargain or non-prosecution agreement
+than would be received by any other similarly situated child abuse suspect.
+23. The Crime Victims' Rights Act, 18 U.S.C. § 3771(c)(1), requires the Government to use
+its "best efforts" to protect the rights of crime victims.
+Please provide all documents,
+correspondence, and other information that will assist Jane Doe #1 and Jane Doe #2 in protecting
+their rights under the CVRA, including all documents, correspondence, and other information
+that the Government previously identified as being helpful to the victims but refused to provide
+based on its legal interpretation (now rejected by the Court) that the CVRA did not apply to this
+case because no indictment was filed
+24. In the course of its investigation of Epstein and negotiations with Epstein, the
+rovernment (1.e
+prosecuting and law enforcement agencies, prosecuting and law enforcement agencies in other
+countries, Epstein's legal counsel, legal counsel for crime victims, and other entities. Please
+provide all documents, correspondence, and other information that the Government shared with
+any entity or person outside the federal government, including all correspondence (including e-
+mails) with those entities or persons.
+25. After the victims had made extensive efforts to try and reach a stipulated set of facts in
+this case, in March 2011 the Government refused to negotiate about such facts. Accordingly, at
+that time the victims filed various motions to obtain evidence in this case and, at the same time,
+
+
+the victims voluntarily made all initial disclosures on their part that are required by Federal Rule
+of Civil Procedure 26(a)(1). Please provide all initial disclosures required by the Federal Rules
+of Civil Procedure, including all disclosures required by Rule 26(a)(1).
+DEFINITIONS
+For the purpose of construing the foregoing discvery requests, the following terms are
+defined:
+The term "documents" means and includes, without limitation, all writings of any kind,
+ncluding the originals and all non-identical copies or drafts, whether different from the origina
+by reason of any notation made on such copy or draft or otherwise including, without limitatior
+correspondence, memoranda, notes, diaries, statistics, letters, e-mails, electronic computer files,
+telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries,
+pamphlets, books, prospectuses, interoffice communications, offers, notations of any sort of
+converse on telephone calls, facingles, there mortions and laida pined matter,
+modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records
+or representations of any kind including, without limitation, photographs, charts, graphs,
+microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or
+electric records or representations of any kind including, without limitation, tapes, cassettes and
+dise recordings, and writings and printed material of every kind.
+The term "correspondence" means any tangible object that conveys information or
+memorializes information that was conveyed in tangible or oral form including, but not limited
+to, writings, letters, memoranda, reports, notes, e-mails, telephone logs, telephone billing
+information, telephone recordings, and interoffice communications.
+The term "Epstein's victims" means any person that the Government identified as a
+possible victim of a sex offense committed by Jeffrey Epstein, including Jane Doe #1, Jane Doe
+#2, all victims identified in attachment to the non-prosecution agreement entered into by Epstein,
+and another person that the Government investigated as a possible victim of Epstein's sex
+offenses.
+The term "Government" means the federal government, including all employees of and
+components of the United States Department of Justice (such as, the Office of the Attorney
+General, the Office of the Deputy Attorney General, the Criminal Divisions, the Office of
+Professional Responsibility, the Child Exploitation and Obscenity Section, the U.S. Attorney's
+Offices for the Southern District and Middle District of Florida, and the Federal Bureau of
+Investigation) and other federal government agencies with law enforcement responsibilities
+related to the Epstein case (such as the Internal Revenue Service). This request for production
+seeks all documents, correspondence, and other information held by all of these entities,
+including all employees of and components of the Justice Department that worked on or were in
+any way involved the Epstein investigation and/or that possess information relevant to the
+victims' claims.
+
+
+The term "including" means containing within the request, but not limiting the request.
+The term
+"witness statement" means any document or other recording in any form
+(including oral form) reflecting, recording, or otherwise memorializing a statement made or
+information conveyed by a potential witness, including for example FBI 302's. The term
+cludes information collected by any law enforcement, prosecuting or government agency
+ncluding all federal. state. and local law enforcement agencies located in Washington. D.C., c
+Florida.
+NO GRAND JURY TRANSCRIPTS SOUGHT
+If any of the foregoing requests cover grand jury transcripts, do not provide the grand
+jury transcript. If any of the foregoing requests include documents that quote directly from a
+grand jury transcript, please redact that particular quotation.
+PRIVILEGE LOG
+If you believe that any document, correspondence, or other information requested in this
+equest is subject to a privilege and if you intend to assert that privilege, please provide a
+"privilege log" consistent with Local Rule 26.1(g), including a description a document that is
+ocument, get ral sal iel after of the document dile of one holdene, ale the top a
+REDUCING UNDUE BURDEN
+If you believe that complying with any of the foregoing requests would be unduly
+any such burdease contact victims counsel - Bradley J. Edwards - to discuss ways to reduce
+DATED: October 3, 2011
+Respectfully Submitted,
+s/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+
+
+and
+Paul G. Cassell
+Pro Hac Vice
+Attorneys for Jane Doe #1 and Jane Doe #2
+CERTIFICATE OF SERVICE
+The foregoing document was served on October 3, 2011, on the following via US Mail and
+E-Mail Transmission:
+Roy Black, Esq.
+Jackie Perczek, Esq.
+Black, Srebnick, Kornspan & Stumpf, P.A. (
+Respectfully Submitted,
+S/ Bradley.J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
diff --git a/vision-fixhub/ds9-unparsed-06/0691cace0eb84d7ef3de424af5820150a9ce913ee1bc4a6278ed8f51aa3343b7.receipt.json b/vision-fixhub/ds9-unparsed-06/0691cace0eb84d7ef3de424af5820150a9ce913ee1bc4a6278ed8f51aa3343b7.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ecf63c8560bdfc500efe44f57e8351acfcab0b4a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0691cace0eb84d7ef3de424af5820150a9ce913ee1bc4a6278ed8f51aa3343b7.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -160,
+  "dataset": "marble-joined",
+  "doc_id": "0691cace0eb84d7ef3de424af5820150a9ce913ee1bc4a6278ed8f51aa3343b7",
+  "engine": "marble-apple-vision",
+  "event_count": 15,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "ebe2ca4c1d7dec63269233f3dabbbc845d12cc1a3f0d1aecf42f50bb4e34a06b",
+  "output_sha256": "356cf6553c8f503b993fbf1718933de23ed1d207cd654c0de81dcb52cb31d27e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/06b0670328c1825b2ae5d2622574b4097a32c2868c1bd4c0c1b535eaaa495ab7.md b/vision-fixhub/ds9-unparsed-06/06b0670328c1825b2ae5d2622574b4097a32c2868c1bd4c0c1b535eaaa495ab7.md
new file mode 100644
index 0000000000000000000000000000000000000000..5fdff9b3227aba27e2d9ab3b6134e56bd86dd889
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/06b0670328c1825b2ae5d2622574b4097a32c2868c1bd4c0c1b535eaaa495ab7.md
@@ -0,0 +1,50 @@
+From:
+To:
+Subject: Activity in Case 9:08-cv-80893-KAM Doe |. Epstein Appeal of Magistrate Judge Order to
+District Court
+Date: Tue, 28 Sep 2010 22:40:44 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Ackerman, Joseph on 9/28/2010 at 6:40 PM EDT and filed on
+9/28/2010
+Case Name:
+Doe | Epstein
+Case Number:
+9:08-cv-80893-KAM
+Filer:
+Jeffrey Epstein
+WARNING: CASE CLOSED on 07/20/2010
+Document Number: 220
+Docket Text:
+APPEAL OF MAGISTRATE JUDGE ORDER to District Court by Jeffrey Epstein re [216] Clerks
+Notice of Docket Correction and Instruction to Filer - Attorney,, [218] Order on Motion for
+Protective Order, Order on Motion for Leave to File, [217] Response to Motion, (Ackerman,
+Joseph)
+9:08-cv-80893-KAM Notice has been electronically mailed to:
+Bradley James Edwards
+Jack Alan Goldberger
+Katherine Warthen Ezell
+Lilly Ann Sanchez
+Michael James Pike
+Paul G. Cassell
+
+
+Robert Deweese Critton, Jr
+9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:/a
+Electronic document Stamp:
+[STAMP dcecfStamp_ID=1105629215 [Date=9/28/2010] [FileNumber=8046506-0
+]|19d68cc5321ccdb119db81c2cf6771588cb26cd0757d2273e61f2af1338d2d3d3bb
+e59449ab81d9c9fс9eЗaa6b0f11f69455e025f509a7f7587919c2e8ffb0cell
diff --git a/vision-fixhub/ds9-unparsed-06/06b0670328c1825b2ae5d2622574b4097a32c2868c1bd4c0c1b535eaaa495ab7.receipt.json b/vision-fixhub/ds9-unparsed-06/06b0670328c1825b2ae5d2622574b4097a32c2868c1bd4c0c1b535eaaa495ab7.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..675d14f7513649dd367daf1a4363c141d9347f62
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/06b0670328c1825b2ae5d2622574b4097a32c2868c1bd4c0c1b535eaaa495ab7.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "06b0670328c1825b2ae5d2622574b4097a32c2868c1bd4c0c1b535eaaa495ab7",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "8f960b7d4aeb0bde0a70d7acd01f992d7946585914371c29b7ab9120a39b139a",
+  "output_sha256": "3c6eda475055230b5c5eea09a76852879a1dbcad79af47ac8fa0915c467f2003",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/06b2dd24ee6252314addcd707459fef2503ab70f7fe1f972c64293f8bea9c4f9.md b/vision-fixhub/ds9-unparsed-06/06b2dd24ee6252314addcd707459fef2503ab70f7fe1f972c64293f8bea9c4f9.md
new file mode 100644
index 0000000000000000000000000000000000000000..62a9b4cf6e29356cb2acb91e5886f64940a71348
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/06b2dd24ee6252314addcd707459fef2503ab70f7fe1f972c64293f8bea9c4f9.md
@@ -0,0 +1,25 @@
+From:
+(USAFLS)"
+To: "
+Subject: FW: Memorandum regarding investigation
+Date: Fri, 10 Aug 2007 12:50:51 +0000
+Importance: Normal
+Attachments:L
+Memo.pdf
+Good morning, Dr.
+I never received a response from this e-mail that I sent a while ago. Can you respond
+and let me know if you are available to do a conference call?
+Thank you.
+Assistant U.S. Attorney
+West Palm Beach, FL 33401
+From:
+(USAFLS)
+Sent: Thursday, June 21, 2007 1:12 PM
+To:
+Subject: Memorandum regarding investigation
+Dear Dr.
+: I have enclosed a memo giving the status of the investigation and the topics that I am hoping
+you can cover, if this case ever gets to trial. Perhaps we could do a conference call with the FBI agents on
+Wednesday or Friday of next week to go over these topics?
+Thank you again.
+West Palm Beach, FL 33401
diff --git a/vision-fixhub/ds9-unparsed-06/06b2dd24ee6252314addcd707459fef2503ab70f7fe1f972c64293f8bea9c4f9.receipt.json b/vision-fixhub/ds9-unparsed-06/06b2dd24ee6252314addcd707459fef2503ab70f7fe1f972c64293f8bea9c4f9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6f57896d4400d92526e09375e826174a9a03cda1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/06b2dd24ee6252314addcd707459fef2503ab70f7fe1f972c64293f8bea9c4f9.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "06b2dd24ee6252314addcd707459fef2503ab70f7fe1f972c64293f8bea9c4f9",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "fdf88b8085194587b50a0b65da226f1a1e8519d6aed0e9621ec0201d1493efff",
+  "output_sha256": "b975299ff7dc6c27b9a63643235c2d85960d31003c383b4aa5cd30dbc9a95725",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/06b45692a50bf0f3e035e0015a253a39a4af421d733a8dd2008a2a99db56cd8f.md b/vision-fixhub/ds9-unparsed-06/06b45692a50bf0f3e035e0015a253a39a4af421d733a8dd2008a2a99db56cd8f.md
new file mode 100644
index 0000000000000000000000000000000000000000..039830a467d0cfa05f1701f40321cf43dd56a6e0
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/06b45692a50bf0f3e035e0015a253a39a4af421d733a8dd2008a2a99db56cd8f.md
@@ -0,0 +1,174 @@
+X cingular
+Questions or Changes?
+cingular.com
+611 from your wireless phone
+TTY users - 1 866 429-7TTY
+Date of Invoice: March 12, 2005
+SUMMARY OF MONTHLY CHARGES FOR ACCOUNT
+Previous
+Balance
+0.30
+Payments
+Received
+0.00
+Late Payment
+Charge
+0.00
+Account
+Adjustments
+0.00
+Your billing cycle began on February 12, 2005 and ended on March 11, 2005
+Current Monthly Charges
+Subscriber Adjustments
+Monthly Service
+Monthly Usage
+Charges
+Credits
+Government Fees and Taxes
+Total Current Monthly Charges
+TOTAL AMOUNT - Due Upon Receipt
+Balanc
+orward
+0.30
+Current Monthly
+Charges
+0.00
+Total
+Amount Due
+0.30
+0.00
+0.00
+0.00
+0.00
+0.00
+0.00
+0.00
+0.30
+cingular
+Account Name:
+Please Return This Portion With Your Payment
+Use of service or payment of this invoice
+indicates concions for viteless servicterms
+Note:
+=>
+We Print on
+Front and Back
+Service #/
+Account #|
+Date Due
+UPON RECEIPT
+Total
+Amount Due
+0.30
+Crackes secretse.
+Amount
+Paid
+5.0101.1011.0000
+Allahabadhoodoodloodoodollood
+CINGULAR WIRELESS
+PO BOX 8229
+AURORA IL 60572-8229
+
+
+
+Recurring Electronic Fund Transfer (REFT): To enroll: sign below, check the REFT box on the reverse side and
+remit with this month's payment. Keep paying your bill until your statement indicates "Do Not Pay". REFT
+Agreement: I authorize my financial institution to deduct the amount of my monthly wireless phone bill from the
+account associated with the enclosed check and remit payment to Cingular Wireless. This authority will be effective
+until I notify Cingular Wireless to terminate it. I agree that I may be assessed a service charge (up to $20) or late
+tee or both it a payment is returned by my bank. For more information visit cingular.com/myaccount or call 1 866
+293-4634. Please keep a copy of the form below and this REFT Agreement for your records or retain a copy of the
+blank form from next month's invoice.
+Questions? We can help: Cingular Wireless appreciates your business and welcomes the opportunity to assist
+you. Visit our website at cingular.com or contact Customer Care by dialing 611 from your wireless phone or 1 866
+293-4634. ¿ Sabías que también ofrecemos servicio al cliente en tu idioma? Marca 611 desde tu teléfono
+inalambrico ó 1 866 293 4634 desde cualquier teléfono y oprime el *.
+Driving Wireless Safety: Your wireless phone gives you the freedom and flexibility to stay in touch when you
+travel, but don't let a phone call distract you from driving safely. Use hands-free device if allowed or required by
+law. Call Carefully, Arrive Safely.
+Cingular Wireless Processing Fees: Accounts suspended for non-payment will be subject to a $25 reactivation
+fee per line and may be assessed a security deposit prior to reinstatement. Checks returned for non-sufficient funds
+will be charged up to a $30.00 fee.
+Local Tax: Local taxes are based on local government boundaries, the address information you provide for your
+account and/or your wireless telephone number. Please review the local tax charges on your bill. If you believe
+there is an error in the local tax charge, please contact us immediately at 1 866 293-4634. Please note that some
+local or state laws may require you to follow special procedures when notifying us about a local tax dispute. You
+may also use the form below to notify us of any change to your taxing address. Thank you for your cooperation.
+Early Termination Fee (ETF): If you cancel service before your contract end date (including if you switch your
+wireless number to another carrier), you will be charged an Early Termination Fee of up to $200.
+Please Send Correspondence To:
+Cingular Wireless Next Generation Correspondence
+P.O. Box 68056
+Anaheim Hills, CA 92817-8056
+0.000016550.2
+Accoung Name and transier Financial Responsibless clearly and check the box on the reverse side. Please contact Customer Care to change the
+New Billing Address
+City
+State
+Zip
+Home Phone (.
+_)
+Work Phone (.
+If your billing address is NOT your Tax Address, please enter the Tax Address below. (Multi-line accounts should attach a list of each wireless number
+and the respective Tax Address.)
+New Tax Address
+City
+Wireless Number (
+State
+Zip
+Recurring Electronic Fund Transfer (REFT) Enrollment. Please read the agreement on the top portion of this page, sign below and check
+he "REFT Registration" box on the reverse side
+Financial Account Holder Signature
+• + I do not wish to receive email notification of special ofter avalable to Cingular Wireless customers.
+
+
+X cingular
+raising the bar
+Account Number
+Account Name
+Date of Invoice
+March 12, 2005
+
+ACCOUNT DETAILS
+Current Subscriber Monthly Charges and Credits
+Subscriber Number
+Subscriber Name
+Total Current Subscriber Monthly Charges and Credits
+Total Current Monthly Charges
+SUMMARY OF CURRENT ACTIVITY
+FOR
+Monthly Service Charges
+Item Description
+Service Dates
+1 CALL WAITING
+02/12/05 • 03/11/05
+3 TREE WA SAL NEPLENISHMENT
+02/12/05 - 03/11/05
+02/12/05 • 03/11/05
+02/12/05 • 03/11/05
+5 GO PHONE UNLIMITED NIGHTS AND WEEKENDS
+02/12/05 - 03/11/05
+02/12/05 - 03/11/05
+Total Monthly Service Charges
+TOTAL CHARGES FOR
+Charge
+0.00
+Charge
+0.00
+0.00
+0.00
+** THIS SPACE INTENTIONALLY LEFT BLANK ***
+0.00
+0.000016551
+
+
+• *cingular
+ng the
+Account Number
+Account Name
+Date of Invoice
+March 12, 2005
+
+*** THIS SPACE INTENTIONALLY LEFT BLANK ***
+***THIS SPACE INTENTIONALLY LEFT BLANK ***
+
diff --git a/vision-fixhub/ds9-unparsed-06/06b45692a50bf0f3e035e0015a253a39a4af421d733a8dd2008a2a99db56cd8f.receipt.json b/vision-fixhub/ds9-unparsed-06/06b45692a50bf0f3e035e0015a253a39a4af421d733a8dd2008a2a99db56cd8f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..764032303f4805bb0c0fa37831762a95e7f91c3c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/06b45692a50bf0f3e035e0015a253a39a4af421d733a8dd2008a2a99db56cd8f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -122,
+  "dataset": "marble-joined",
+  "doc_id": "06b45692a50bf0f3e035e0015a253a39a4af421d733a8dd2008a2a99db56cd8f",
+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "ad519f8bfc45a0436a947b71b4f48de437e4192387f9a01566fbb0c8351dd63b",
+  "output_sha256": "c5d19ceba1af4e15a91b5c878e49a7542a6147c2bd4f68c72589a8194cc4e932",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/06f348ba0501db66935429c67afd87a042ff409c954184b79165431885927a45.md b/vision-fixhub/ds9-unparsed-06/06f348ba0501db66935429c67afd87a042ff409c954184b79165431885927a45.md
new file mode 100644
index 0000000000000000000000000000000000000000..1a3cb45fc766148fedf1a1a54a9d9ee522bbae52
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/06f348ba0501db66935429c67afd87a042ff409c954184b79165431885927a45.md
@@ -0,0 +1,20 @@
+From:
+To:
+Subject: RE: Setting up a conference call
+Date: Fri, 04 Feb 2011 20:38:39 +0000
+Importance: Normal
+They can join at any time.
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Sent: Friday, February 04, 2011 3:37 PM
+Subject: RE: Setting up a conference call
+Do you want them to be "announced" or free to join at any time?
+Sent: Friday, February 04, 2011 3:30 PM
+Subject: Setting up a conference call
+Hi Shawn - Can you set up another one of those "official" conference calls? For Thursday at 10:30? It is with
+the Epstein lawyers. I guess I will be the "organizer." 10:30 to 12:00 should be plenty of time.
+Thanks.
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
diff --git a/vision-fixhub/ds9-unparsed-06/06f348ba0501db66935429c67afd87a042ff409c954184b79165431885927a45.receipt.json b/vision-fixhub/ds9-unparsed-06/06f348ba0501db66935429c67afd87a042ff409c954184b79165431885927a45.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..921610ae2fcc0312f0adcc8eaa717b59d4adeb9b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/06f348ba0501db66935429c67afd87a042ff409c954184b79165431885927a45.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "06f348ba0501db66935429c67afd87a042ff409c954184b79165431885927a45",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "190effb9a1bd2f7931998bddc7969631c39f090b29572e5b1a0e78d37e2f8a59",
+  "output_sha256": "fc7a91d0bf756af1aa3af5c27ea6f6813564bf1d73f92a444581bfc09acd1395",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0716846c52b39152a4ab00e435f42a5cba2d1cd8cd9d431be476bc964c249c5b.md b/vision-fixhub/ds9-unparsed-06/0716846c52b39152a4ab00e435f42a5cba2d1cd8cd9d431be476bc964c249c5b.md
new file mode 100644
index 0000000000000000000000000000000000000000..4e36f7eb1c30fd6cf0c536f18b78ddb16abc7a55
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0716846c52b39152a4ab00e435f42a5cba2d1cd8cd9d431be476bc964c249c5b.md
@@ -0,0 +1,24 @@
+From:
+To:
+(USAFLS)" -
+Subject: Re: A tip
+Date: Wed, 03 Mar 2010 18:51:43 +0000
+Importance: Normal
+I tried it and it works! Unfortunately the judge is the one who publishes the orders and I dont think he'll want to add an extra
+Courtroom Deputy
+Judge Marra's Chambers
+03/03/2010 01:45 PM
+To a
+cc
+Subject A tip
+Hi Irene - Just got one of Judge M's orders on Epstein. Not that it is any of my business, but just wanted you to
+know that if he wants to avoid that really annoying line that sometimes appears at the beginning of paragraphs
+when you "publish" a document to PDF, there is a simple fix.
+Instead of "publishing" the document, "print" the document, and then select Adobe PDF as the printer. It will
+ask you to give it a file name, and then will create the pdf document.
+(Now you know why the US Attorney's Office can't ever fire me, I am the only one who actually knows all the
+computer geek stuff.)
+Assistant U.S. Attorney
+
+
+=
diff --git a/vision-fixhub/ds9-unparsed-06/0716846c52b39152a4ab00e435f42a5cba2d1cd8cd9d431be476bc964c249c5b.receipt.json b/vision-fixhub/ds9-unparsed-06/0716846c52b39152a4ab00e435f42a5cba2d1cd8cd9d431be476bc964c249c5b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6c86a1cc27e45631ad66a98d10144e83e107c36c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0716846c52b39152a4ab00e435f42a5cba2d1cd8cd9d431be476bc964c249c5b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "0716846c52b39152a4ab00e435f42a5cba2d1cd8cd9d431be476bc964c249c5b",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "657e1aa19ab009fb72a273c7de6b6e5b6311de75e25c9b2bb651fafa0b855dbd",
+  "output_sha256": "fd1634d7da9aecffd94ee2a26cec6ed51475318023f8cc882b7707d28f80281a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/078fd424c14aa88fff4d8fc9fabb37fee6e47446d872fd2cfe5a18d66e9150d6.md b/vision-fixhub/ds9-unparsed-06/078fd424c14aa88fff4d8fc9fabb37fee6e47446d872fd2cfe5a18d66e9150d6.md
new file mode 100644
index 0000000000000000000000000000000000000000..75d87fd80decfdef570c301dffae267fcac4e3dd
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/078fd424c14aa88fff4d8fc9fabb37fee6e47446d872fd2cfe5a18d66e9150d6.md
@@ -0,0 +1,15 @@
+Subject: Emailing: 20110721|
+Date: Thu, 21 Jul 2011 18:05:07 +0000
+Importance: Normal
+Attachments: 20110721_
+Ltr_to_Black.wpd
+/ Ltr to Black.wpd
+<<20110721
+]Ltr to Black.wpd>> HiL
+revised version. Any further thoughts before I send?
+recommended removing the reference to the Privacy Act. Here is the
+The message is ready to be sent with the following file or link attachments:
+
+Ltr to Black.wpd
+Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your
+e-mail security settings to determine how attachments are handled.
diff --git a/vision-fixhub/ds9-unparsed-06/078fd424c14aa88fff4d8fc9fabb37fee6e47446d872fd2cfe5a18d66e9150d6.receipt.json b/vision-fixhub/ds9-unparsed-06/078fd424c14aa88fff4d8fc9fabb37fee6e47446d872fd2cfe5a18d66e9150d6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..75f99f8d9b617f72458cf53f3fdeb2c0a3f22c5a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/078fd424c14aa88fff4d8fc9fabb37fee6e47446d872fd2cfe5a18d66e9150d6.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -21,
+  "dataset": "marble-joined",
+  "doc_id": "078fd424c14aa88fff4d8fc9fabb37fee6e47446d872fd2cfe5a18d66e9150d6",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3c6be42adeddf2f77871cd7f67cfd444b41c2b2710d7fee47b6b041ec8ea94da",
+  "output_sha256": "7d5afe7aaffbfe93e440eccd82117470c339c7ab88f7aaad0ade862f3aa6a8fb",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/07d3314d46767c094380b90ae0fec3852134276b9c6e2176801f042bee3f36f4.md b/vision-fixhub/ds9-unparsed-06/07d3314d46767c094380b90ae0fec3852134276b9c6e2176801f042bee3f36f4.md
new file mode 100644
index 0000000000000000000000000000000000000000..28b444b399f31e7f9855689fdbe2bceb728237c8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/07d3314d46767c094380b90ae0fec3852134276b9c6e2176801f042bee3f36f4.md
@@ -0,0 +1,163 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA
+JANE DOE #1 and JANE DOE #2,
+Petitioners,
+Vs.
+UNITED STATES,
+Respondent.
+/
+RESPONDENT'S OPPOSITION TO PETITIONERS' MOTION REQUESTING
+AN ORDER DIRECTING THE GOVERNMENT TO FILE REDACTED
+PLEADINGS IN THE PUBLIC COURT FILE
+Respondent, by and through its undersigned counsel, files its Opposition to Petitioners'
+Motion Requesting an Order Directing the Government to File Redacted Pleadings in the Public
+Court file, and state:
+I.
+THE GOVERNMENT HAS COMPLIED WITH THE ORDER PERMITTING
+LIMITED DISCLOSURE OF GRAND JURY INFORMATION BY FILING THE
+REFERENCED MEMORANDUM, MOTION TO STAY DISCOVERY, AND REPLY,
+UNDER SEAL
+Petitioners ask this Court to issue an order directing respondent to file redacted versions
+of its (1) Sealed Memorandum in Support of Motion to Dismiss for Lack of Subject Matter
+Jurisdiction; (2) Sealed Motion to Stay Discovery; and (3) Sealed Reply in Support of Motion to
+Dismiss for Lack of Subject Matter Jurisdiction. Petitioners' motion should be denied because
+the government has filed these three documents under seal in compliance with the Order granting
+limited disclosure of grand jury information, entered on November 7, 2011.
+
+
+On November 7, 2011, the government sought a Court order pursuant to Fed.R.Cr.P.
+6(e)(3)(E)(i), to permit limited disclosure of grand jury information which was relevant to
+whether this Court has subject matter jurisdiction. On the same day, the Honorable Donald M.
+Middlebrooks, United States District Judge, entered a Sealed Order granting the government's
+motion for limited disclosure of grand jury matter.' The disclosure was conditioned on the
+following:
+(1) the disclosure of the aforementioned grand jury information should be limited to
+filings made under seal in Case No. 08-80726-CIV-MARRA;
+(2) the service of filings containing the aforementioned grand jury information shall be
+limited to counsel for Petitioners Jane Doe No.1 and Jance Doe No. 2 and for the government in
+Case No. 08-80736-CIV-MARRA, and shall be accompanied by a copy of this Order; and
+(3) further dissemination by any person or entity receiving disclosure of the grand jury
+information authorized to be disclosed by this Order shall be limited to the individual Petitioners
+in Case No. 08-80736-CIV-MARRA, and any dissemination of such grand jury information shall
+be accompanied by a copy of this Order.
+Under Fed.R.Cr.P. 6(e)(2)(B), certain individuals, such as grand jurors, prosecutors,
+stenographers and others are forbidden from disclosing "matters occurring before the grand
+jury." "This phrase -- "matters occurring before the grand jury" - includes not only what has
+occurred and what is occurring, but also what is likely to occur." In re Motions of Dow Jones &
+Company, 142 F.3d 496, 500 (D.C. Cir. 1998). Further, "[e]ncompassed within the rule of
+secrecy are "the identities of witnesses or jurors, the substance of testimony" as well as actual
+transcripts, "the strategy or direction of the investigation, the deliberations or questions of jurors,
+and the like."" Id. at 500, citing SEC v. Dresser Industries, Inc., 628 F.2d 1368, 1382 (D.C. Cir.
+' SDFL IOP 8.01.00 provides: "Grand jury matters, and all matters reasonably related to the original grand jury
+matter, will be handled by the district judge before whom the original matter was filed." Since Judge Middlebrooks
+issued the Order granting the government limited authority to disclose grand jury material, any issue regarding the
+scope of the Order should be addressed to Judge Middlebrooks.
+2
+
+
+1980)(en banc). Plainly, the scope of what constitutes "matters occurring before the grand jury"
+is not as narrow as petitioners contend.
+Petitioners rely upon United States v. Ignasiak, - F.3d -- , 2012 WL 149314 (11" Cir.
+Jan. 19, 2012), and Romero v. Drummond Co., Inc., 480 F.3d 1234 (11" Cir. 2007). D.E. 150 at
+2-3. Neither of these cases involve the sealing of matters occurring before the grand jury. In
+Ignasiak, the government filed under seal, a post-trial in camera notice to the court, containing
+impeachment information about Dr. Arthur Jordan, a key witness for the government. 2012 WL
+149314 at *15. The defendant, Ignasiak, moved to unseal the notice, along with the
+accompanying affidavit from the trial prosecutor. The government opposed the motion, and the
+district court summarily denied the motion to unseal. On appeal, the Eleventh Circuit reversed
+the district court. Id. at 16. The appellate court noted there was a value of openness in criminal
+proceedings, where the public had a "right to know the extent of Dr. Jordan's involvement with
+the government." Id. Finding that the public's right to know outweighed any privacy interest of
+Dr. Jordan, the appellate court found the district court had abused its discretion in denying the
+motion to unseal.
+In Romero v. Drummond Company, Inc., 480 F.3d 1234 (11" Cir. 2007), the Eleventh
+Circuit found that a district court abused its discretion by refusing to unseal a motion for
+reconsideration and accompanying affidavits filed by the plaintiffs. The Court of Appeals
+recognized a common law right of access to judicial proceedings, and in particular, "[m]aterial
+filed in connection with any substantive pretrial motion, unrelated to discovery, is subject to the
+common law right of access." Id. at 1245 (citation omitted). The appellate court found the
+lower court had abused its discretion in refusing to unseal Romero's Motion to Submit Pertinent
+Information to U.S. State & Justice Departments, with two attached declarations; Drummond's
+3
+
+
+sealed motion to seal Romero's motion and two attached declarations; and Romero's motion for
+reconsideration.
+The sealing of these documents was not predicated in any way on the concept
+of grand jury secrecy.
+The common law right of access to judicial proceedings, recognized in Ignasiak and
+Romero v. Drummond, does not apply in the instant case because grand jury secrecy is the basis
+for sealing the three documents referenced in petitioners' motion. In In re Motions of Dow Jones
+& Company, the Court of Appeals observed that the press had advanced a common law right of
+access to ancillary proceedings, based upon the Supreme Court's recognition of a common law
+right of access to inspect and copy judicial records. 142 F.3d at 504, citing Nixon v. Warner
+Communications, 435 U.S. 589, 598 (1978). The appellate court also observed that this
+common law right was not absolute:
+Although some have identified a common law tradition of public access to
+criminal trials, this never extended to preindictment, pretrial proceedings
+involving a grand jury. Gannett Co. 443 U.S. 368, 99 S.Ct. 2898, indicates as
+much. In any event, even if there was once a common law right of access to
+materials of the sort at issue here, the common law has been supplanted by Rule
+6(e)(5) and Rule 6(e)(6) of the Federal Rules of Criminal Procedure. These
+Rules, not the common law, now govern. See In re Grand Jury Subpoena (John
+Doe No. 4), 103 F.3d at 237.
+142 F.3d at 504. Additionally, a district court is not compelled to take the least restrictive
+means available to protect the secrecy of the grand jury proceedings during the pendency of
+those proceedings. In re Subpoena to Testify Before Grand Jury, 864 F.2d 1559, 1564 (11"* Cir.
+1989), and United States v. Smith, 123 F.3d 140, 152-54 (3rd Cir. 1997)(refusing to require
+district court to redact briefs).
+The government has acted with reasonable prudence and caution in filing the three
+referenced documents under seal. The November 7, 2011 Order granted the government
+limited authority to make disclosure of what would otherwise be information subject to grand
+4
+
+
+jury secrecy.
+The government's fidelity to the conditions placed by the Court on the disclosure
+should not be the basis for castigating the government.
+Petitioners argue that keeping the pleadings under seal "unduly burdens counsel for the
+victims." D.E. 150 at 4.
+However, petitioners acknowledge that they filed lengthy responses to
+the sealed memorandum in support of motion to dismiss for lack of subject matter jurisdiction,
+and sealed motion to stay discovery, on December 5, 2011. D.E. 150 at 2. Further, petitioners
+stated they filed these responses in the public file, while filing short, sealed responses to what
+petitioners contend were issues "that touched on the confidential grand jury information." Id. It
+is difficult to understand how petitioners' ability to effectively respond to the government's
+sealed motions has been impeded in any meaningful way. Moreover, petitioners have made
+their own judgment as to what is covered by Fed.R.Cr.P. 6(e) by filing large portions of their
+responses in the public court file. Petitioners are free to make their own choices as to what is,
+and is not encompassed in the November 7, 2011 Order. At the same time, the government
+should not be faulted for choosing what it believes is a more prudent course.
+Petitioners' motion requesting an order directing the government to file redacted
+pleadings in the public court file should be denied
+DATED: February 24, 2012
+Respectfully submitted,
+WIFREDO A. FERRER
+UNITED STATES ATTORNEY
+By:
+Assistant U.S. Attorney
+Assistant U.S. Attorneys
+5
+
+
+Miami, Florida 33132
+Attorneys for Respondent
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on February 24, 2012, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF.
+IT TEE
+Assistant U.S. Attorney
+SERVICE LIST
+Jane Does 1 and 2 v. United States,
+Case No. 08-80736-CIV-MARRA/JOHNSON
+United States District Court, Southern District of Florida
+Bradley J. Edwards, Esq.,
+Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.
+Fort Lauderdale, Florida 33301
+Paul G. Cassell
+S.J. Quinney College of Law at the
+University of Utah
+Salt Lake City, Utah 84112
+Attorneys for Jane Doe # 1 and Jane Doe #2
+6
diff --git a/vision-fixhub/ds9-unparsed-06/07d3314d46767c094380b90ae0fec3852134276b9c6e2176801f042bee3f36f4.receipt.json b/vision-fixhub/ds9-unparsed-06/07d3314d46767c094380b90ae0fec3852134276b9c6e2176801f042bee3f36f4.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..fb337a756e0db90d112210f71bc30dcd3d0f1b7d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/07d3314d46767c094380b90ae0fec3852134276b9c6e2176801f042bee3f36f4.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -72,
+  "dataset": "marble-joined",
+  "doc_id": "07d3314d46767c094380b90ae0fec3852134276b9c6e2176801f042bee3f36f4",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "dcc0077840c32f12d90f6f9f0f820f2e1ddb1701ce1ac728f2d0f5f75ec80b61",
+  "output_sha256": "d50fbd3e3183448a8f6751fb3f4b34720e411fc829a7b07e991a0bdb368585ea",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/07d932185a745bb1a7b712a683e220d2ad8883bc7951fa07711b715fb343c6a4.md b/vision-fixhub/ds9-unparsed-06/07d932185a745bb1a7b712a683e220d2ad8883bc7951fa07711b715fb343c6a4.md
new file mode 100644
index 0000000000000000000000000000000000000000..c767363f2de7e168520d6061c80170265fc086d6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/07d932185a745bb1a7b712a683e220d2ad8883bc7951fa07711b715fb343c6a4.md
@@ -0,0 +1,25 @@
+From:
+To:
+Cc: "
+(USAFLS)" ‹
+(USAFLS)" <
+(USAFLS)" <
+Subject: Assistance needed with computer-related discovery of USAO files
+Date: Tue, 17 Jan 2012 22:41:20 +0000
+Importance: Normal
+(USAFLS)"
+Several months ago, you and
+assisted in collecting email and other files related to the
+Periones in the mater i sane Do i and Sane Doe par s. United sales. We have receives an adhional
+request that calls for materials beyond what we had originally discussed, so I am hoping that you can assist me in
+gathering this information.
+Based upon the request, we need to obtain: (1) any emails sent by Bruce Reinhart while he was still an AUSA;
+(2) any emails sent by Bruce Reinhart after he left the U.S. Attorney's Office to any of the following members of
+he U.S. Attorney's Office/U.S. Department of Justice - Alex Acosta, Jeff Sloman,
+The relevant time period is 1/1/2006 through 12/31/2007.
+Also, if you have available to you any documentation that would show the period when Mr. Reinhart was and
+was not a supervisor in the West Palm Beach office, that information also would be useful.
+And if there are any electronic calendars for Mr. Reinhart or for these other individuals that show
+meetings/telephone contact with Mr. Reinhart, those should be produced.
+Thank you so much for your assistance.
+Assistant U.S. Attorney
diff --git a/vision-fixhub/ds9-unparsed-06/07d932185a745bb1a7b712a683e220d2ad8883bc7951fa07711b715fb343c6a4.receipt.json b/vision-fixhub/ds9-unparsed-06/07d932185a745bb1a7b712a683e220d2ad8883bc7951fa07711b715fb343c6a4.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b014547552ae1c0eaff5130cc17613581801eb20
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/07d932185a745bb1a7b712a683e220d2ad8883bc7951fa07711b715fb343c6a4.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "07d932185a745bb1a7b712a683e220d2ad8883bc7951fa07711b715fb343c6a4",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "6467c82ad838dd7324aa3a029eaf0f04810698ef3cbaa228a4becf27004c97f3",
+  "output_sha256": "ba6dc3b48781f49a285443c16efb5df17c23fab9fe458be79093caadcc98a28a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0836d8e19485ea700656b8a4fb8db62ed82df22613adb60f35058005536d8f18.md b/vision-fixhub/ds9-unparsed-06/0836d8e19485ea700656b8a4fb8db62ed82df22613adb60f35058005536d8f18.md
new file mode 100644
index 0000000000000000000000000000000000000000..47419a1e2f6714de04a0bf68206737a3a511bcfd
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0836d8e19485ea700656b8a4fb8db62ed82df22613adb60f35058005536d8f18.md
@@ -0,0 +1,32 @@
+From:
+To: <
+Cc: "l
+Subject: Jeffrey Epstein
+Date: Fri, 05 Jan 2007 21:04:51 +0000
+Importance Normal
+hope you had a great holiday season.
+and I would like to speak with you early next week on the Epstein
+matter. if you provide me with some convenient dates and times for us to call you, i will coordinate with!
+and confirm
+same.
+regards
+Esq.
+FOWLER WHITE BURNETT P.A.
+Espirito Santo Plaza, 14th Floor
+**TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance
+with requirements imposed by the IRS, we inform you that any tax
+advice contained in this communication (including attachments) was
+not intended or written to be used, and cannot be used, for the
+purpose of (i) avoiding penalties under the Internal Revenue Code
+or (ii) promoting, marketing or recommending to another party any
+transaction or matter addressed herein. If you would like such advice,
+please contact us.***
+***Attention: The information contained in this E-mail message
+is attorney privileged and confidential information intended only
+for the use of the individual(s) named above. If the reader of this
+message is not the intended recipient, you are hereby notified that any
+dissemination, distribution or copy of this communication is strictly
+prohibited. If you have received this communication in error, please
+contact the sender by reply E-mail and
+destroy all copies of the original
+message. Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/0836d8e19485ea700656b8a4fb8db62ed82df22613adb60f35058005536d8f18.receipt.json b/vision-fixhub/ds9-unparsed-06/0836d8e19485ea700656b8a4fb8db62ed82df22613adb60f35058005536d8f18.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..cf8faea6968103f7b8469d4424fc1efc72985d89
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0836d8e19485ea700656b8a4fb8db62ed82df22613adb60f35058005536d8f18.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "0836d8e19485ea700656b8a4fb8db62ed82df22613adb60f35058005536d8f18",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "dc45a3fa6463eb4de8cf45cc692047c832938c67418c06c9130354fa07742b4e",
+  "output_sha256": "391edb99e0f2fb1b82e88f4427dc5b2f2a4793cced182049aadd0691994ede09",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0853b8951a614578f7e59b5cae39d3b76dcdc704fbde7f5dccb81503d5a85e2f.md b/vision-fixhub/ds9-unparsed-06/0853b8951a614578f7e59b5cae39d3b76dcdc704fbde7f5dccb81503d5a85e2f.md
new file mode 100644
index 0000000000000000000000000000000000000000..ee490b2d90c678f3e7c40f59ac709876ae2b0aed
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0853b8951a614578f7e59b5cae39d3b76dcdc704fbde7f5dccb81503d5a85e2f.md
@@ -0,0 +1,19 @@
+Subject: RE: WPTV - Jeffrey Epstein
+Date: Fri, 12 Aug 2011 20:36:45 +0000
+Importance: Normal
+We just left you a voicemail. Call if you ca
+-Original Messag.-...•
+Subject: RE: WPTV- Jeffrey Epstein
+Thanks for your email. I believe that agreement is not public. Additionally, we won't be making any out of court comments.
+Criminal Maccane
+Subject: WPTV -- Jeffrey Epstein
+Good afternoon-- I am attending the 2pm hearing in regards to case against the US attney over Jeffrey Epstein's non-prosecution
+agreement.
+Case is 08-80736. Can u please send me a copy? In addition, please call me when you get a moment.
+Thank you!
+Katie LaGrone
+WPTV
+561-313-6334
+Sent from iPhone
+Scripps Media, Inc., certifies that its advertising sales agreements do not discriminate on the basis of race or ethnicity. All advertising sales
+agreements contain nondiscrimination clauses.
diff --git a/vision-fixhub/ds9-unparsed-06/0853b8951a614578f7e59b5cae39d3b76dcdc704fbde7f5dccb81503d5a85e2f.receipt.json b/vision-fixhub/ds9-unparsed-06/0853b8951a614578f7e59b5cae39d3b76dcdc704fbde7f5dccb81503d5a85e2f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1ad4b3b849f063e1c2c1ff8e1879eef998fabe8d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0853b8951a614578f7e59b5cae39d3b76dcdc704fbde7f5dccb81503d5a85e2f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "0853b8951a614578f7e59b5cae39d3b76dcdc704fbde7f5dccb81503d5a85e2f",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3b33ad4f4e9f77a6afce469d90efdcea20d446084b18f186f9f54593fa03db6f",
+  "output_sha256": "1250a15c4a6d869257b9b5d87c3a87b064d12617350d26d163cc2e9750af43f9",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/090fd7a4e62fe059e1f91588abe7eca6cbc869f6a8da45a5858b68e1a356021a.md b/vision-fixhub/ds9-unparsed-06/090fd7a4e62fe059e1f91588abe7eca6cbc869f6a8da45a5858b68e1a356021a.md
new file mode 100644
index 0000000000000000000000000000000000000000..6f4cd344ea1051d85455a84a1665bc68faf1de3b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/090fd7a4e62fe059e1f91588abe7eca6cbc869f6a8da45a5858b68e1a356021a.md
@@ -0,0 +1,68 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80119-KAM Doe |. Epstein Motion for Extension of Time to
+Complete Discovery
+Date: Fri, 19 Feb 2010 17:00:06 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Pike, Michael on 2/19/2010 at 12:00 PM EST and filed on 2/19/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 470
+Doe L. Epstein
+9:08-CV-80119-KAM
+Jeffrey Epstein
+Docket Text:
+Joint MOTION for Extension of Time to Complete Discovery as to Jane Doe, 08-80893 by
+Jeffrey Epstein. (Attachments: # (1) Text of Proposed Order Proposed Order)(Pike, Michael)
+9:08-Cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+ahorowitz@sexabuseattorney.com
+Bradley James Edwards
+brad@pathtojustice.com, beth@pathtojustice.com
+Isidro Manuel Garcia
+isidrogarcia @bellsouth.net
+Jack Alan Goldberger
+jagesq@bellsouth.net, nalanis@agwpa.com
+Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com,
+sas@searcylaw.com, vat@searcylaw.com
+Jeffrey Mare Herman jherman@hermanlaw.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+
+
+Michael James Pike MPike@bclclaw.com, bobbie@bclelaw.com, jcadwell@bclelaw.com
+Paul G. Cassell cassellp@law.utah.edu
+Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com
+Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton@podhurst.com,
+mestradal@podhurst.com
+Robert Deweese Critton, Jr rcrit@belclaw.com, bobbie@belclaw.com
+Stuart S. Mermelstein ssm@sexabuseattorney.com, jarbour@sexabuseattorney.com,
+Irivera@sexabuseattorney.com
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+Martin G. Weinberg
+20 Park Plaza
+Boston, MA 02116
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=2/19/2010] [FileNumber=7276597-0
+] [89cae5b769bdbfl346b5eb744f1538449318a0c2028cd8a35e9492d90730347347a
+e5b3ad44ae20af94c8eb90f4d8b7db82df8ea9b5bcfбa665630c3e03b62cf]]
+Document description: Text of Proposed Order Proposed Order
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=2/19/2010] [FileNumber=7276597-1
+][28a4ad458068ae225afeb178835c12895e4a1175dc0e5b68c9588bd84af70a85a00
+72371c4031ac9e229c2ac8d14e9651596206723e9505a98093ab9c210e7fb]]
diff --git a/vision-fixhub/ds9-unparsed-06/090fd7a4e62fe059e1f91588abe7eca6cbc869f6a8da45a5858b68e1a356021a.receipt.json b/vision-fixhub/ds9-unparsed-06/090fd7a4e62fe059e1f91588abe7eca6cbc869f6a8da45a5858b68e1a356021a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ca4eade2f922bcee07c24526ef6c569107dad395
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/090fd7a4e62fe059e1f91588abe7eca6cbc869f6a8da45a5858b68e1a356021a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "090fd7a4e62fe059e1f91588abe7eca6cbc869f6a8da45a5858b68e1a356021a",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "35f999fe078b7072b4f92450342dacd360279ec7cadd0f373ce4a86fdc24ed86",
+  "output_sha256": "67db53d420842cfa90c79a4d49608be57e4dbd06a44052bfe1f3330a99b6443e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0995398b9a0fa8d1c04298edd51455adeead4b16f5b8f8730f3b31ea5bb440a4.md b/vision-fixhub/ds9-unparsed-06/0995398b9a0fa8d1c04298edd51455adeead4b16f5b8f8730f3b31ea5bb440a4.md
new file mode 100644
index 0000000000000000000000000000000000000000..69bbb75aea68594526368d4f01bb29b65899d2ad
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0995398b9a0fa8d1c04298edd51455adeead4b16f5b8f8730f3b31ea5bb440a4.md
@@ -0,0 +1,68 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80119-KAM Doe |. Epstein Extension of Time to File
+Response/Reply
+Date: Fri, 19 Mar 2010 14:47:50 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Pike, Michael on 3/19/2010 at 10:47 AM EDT and filed on 3/19/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 495
+Doe | Epstein
+9:08-cV-80119-KAM
+Jeffrey Epstein
+Docket Text:
+Amended MOTION for Extension of Time to File Response/Reply as to [485] Response in
+Opposition to Motion,, Unopposed by Jeffrey Epstein. (Attachments: # (1) Text of Proposed
+Order Proposed Order)(Pike, Michael)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz ahorowitz@sexabuseattorney.com
+Ann Marie C. Villafana ann.marie.c.villafanal@usdoj.gov
+Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com
+Isidro Manuel Garcia isidrogarcia(@bellsouth.net
+Jack Alan Goldberger jagesq@bellsouth.net, nalanis@agwpa.com
+Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com,
+sas@searcylaw.com, vat@searcylaw.com
+Jeffrey Mare Herman jherman@hermanlaw.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+
+
+Michael James Pike MPike@bclclaw.com, bobbie@bclclaw.com, jcadwell@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com
+Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton@podhurst.com,
+mestrada@podhurst.com
+Robert Deweese Critton, Jr rerit@bclclaw.com, bobbie@bclclaw.com
+Stuart S. Mermelstein
+Irivera @sexabuseattorney.com
+ssm@sexabuseattorney.com, jarbour@sexabuseattorney.com,
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+Martin G. Weinberg
+20 Park Plaza
+Boston, MA 02116
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=3/19/2010] [FileNumber=7377665-0
+] [880b1cebeefleaabeabf5e545ac553487ea9c02fa419caeaa3287e414b891cebb89
+289f30bb51d76f4636ee1b00c0f47728a9f43a1cbf50b5c717657a006d84d]]
+Document description: Text of Proposed Order Proposed Order
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=3/19/2010] [FileNumber=7377665-1
+1[9b2e077ffcccacefb76537b93d3811ef4fe22e5dbced455073c2554bf461d73780e
+5blce4913519d719c2ec4a5cla898084aff5051a77da61403886bee2dde6e]]
diff --git a/vision-fixhub/ds9-unparsed-06/0995398b9a0fa8d1c04298edd51455adeead4b16f5b8f8730f3b31ea5bb440a4.receipt.json b/vision-fixhub/ds9-unparsed-06/0995398b9a0fa8d1c04298edd51455adeead4b16f5b8f8730f3b31ea5bb440a4.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2989d6849839e65fe8a1d247a99b973fa727044a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0995398b9a0fa8d1c04298edd51455adeead4b16f5b8f8730f3b31ea5bb440a4.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "0995398b9a0fa8d1c04298edd51455adeead4b16f5b8f8730f3b31ea5bb440a4",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "cd1448dbffccf9d42669146cba5b22aab4047e5d2d6127e2b5f420496209c91d",
+  "output_sha256": "c87773c2b900a59501c0ac713723a6baaedb56e91b88c91cd56408ff533c70d4",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/09ac68fc554abb73c3a612b791bcb00e52f91ee943007bb2521e12633cc2059f.md b/vision-fixhub/ds9-unparsed-06/09ac68fc554abb73c3a612b791bcb00e52f91ee943007bb2521e12633cc2059f.md
new file mode 100644
index 0000000000000000000000000000000000000000..3ede3b5275439e725ee6b8f48d84704fdd084bb2
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/09ac68fc554abb73c3a612b791bcb00e52f91ee943007bb2521e12633cc2059f.md
@@ -0,0 +1,68 @@
+Jane Doe # 1 and Jane Doe # 2|. United States
+Plaintiffs' Request for Production
+No. 7: Plaintiffs seek correspondence and documents regarding the government's knowledge of
+any obligations it had under the CVRA to notify the victims about the non-prosecution
+agreement and any related state court plea agreement.
+I understand there were discussions
+between the Child Exploitation and Obscenity Section (CEOS) and the S.D.Fla.. regarding
+whether the CVRA applied to the NPA, and whether notification should be made to the victims.
+This would include letters, memos, and e-mail traffic.
+No. 8: Plaintiffs seek documents relating to Epstein's efforts, after the execution of the NPA in
+September 2007, to appeal to Main Justice to obtain a more favorable outcome. I understand he
+first appealed to CEOS, which found the S.D.Fla. had acted within its discretion. Epstein's
+attorneys next sought review at the DAG level, which resulted in then Deputy Attorney General
+Mark Filip finding that the S.D.Fla. had appropriated exercised its prosecutorial discretion. The
+documents sought include letters from Epstein's attorneys seeking review of the S.D.Fla.'s
+actions in the case, as well as possible letters of support from former
+No. 17: Plaintiffs seek documents pertaining to the OPR inquiry into Cassell's allegations of
+misconduct by the U.S. Attorney's Office, contained in a December 10, 2010 letter delivered to
+the Crited State.
+Plaintiffs seek eight (8) categories of information.
+OPR sent Cassell a letter on May 6, 2011, advising him that most of his allegations were
+currently being litigated in the CVRA lawsuit, and OPR's policy was to refrain from
+investigating issues or allegations that were, are being, are could have been addressed in the
+1
+
+
+course of litigation, unless a court has made a specific finding of misconduct by a DOJ attorney
+or law enforcement personnel, or there are present other extraordinary circumstances. Since
+there was no finding of misconduct, or extraordinary circumstances, OPR declined to commence
+an investigation.
+No. 19: Plaintiffs seek documents pertaining to former U.S. Attorney Alex Acosta's March
+2011 statement to the news media that Epstein's attorneys launched "a yearlong assault on the
+prosecution and the prosecutors" when the U.S. Attorney's Office began investigating Epstein,
+and Roy Black's response that they merely pointed out misconduct and over-reaching by certain
+people involved in the Epstein investigation.
+Potentially responsive documents would include
+complaints lodged by Epstein's attorneys with DOJ OPR or OIG regarding alleged misconduct
+by employees of the U.S. Attorney's Office, S.D.Fla. This would also include documents
+supporting Epstein's attorney's claims of misconduct and overreaching, and documents showing
+whether the allegations were supported or contradicted
+No. 21: Plaintiffs seek correspondence and communications between government prosecutors
+working on the case and Epstein's attorneys, and agents acting on Epstein's behalf, regarding
+seven (7) subject-matter areas.
+No. 22: Plaintiffs contend that Epstein offered consideration to the government as an
+inducement to obtaining favorable concessions on his plea negotiations. They seeks five (5)
+categories of documents, including offers to donate to funds or services to any person or entity;
+offers to assist in business opportunities; offers to assist the government or law enforcement
+2
+
+
+agencies in the investigation or prosecution of any federal or state criminal offense;
+consideration that Epstein has provided to the government or law enforcement agencies in the
+past; and any other consideration that Epstein offered to provide or had provided in the past that
+could provide a basis for the government extending Epstein a more generous or lenient plea
+bargain or non-prosecution agreement that would be received by any other similarly situated
+child abuse suspect.
+No. 23: Plaintiffs request all documents, correspondence, and other information that will assist
+the victims in protecting their rights under the CVRA. During the litigation, the victims claimed
+the government had an obligation to provide information helpful to their case, just as the
+government is obligated under Brady I. Maryland to provide exculpatory information in its
+possession. I view this request as covering any documents which would assist the vietims, and
+hurt the government.
+No. 24: Plaintiffs seek documents, correspondence, and information the government shared with
+persons outside the federal government, including state and local prosecuting and law
+enforcement agencies, law enforcement agencies in other countries, legal counsel for crime
+victims, and other entities. This would cover communications sent by a DOJ component,
+regarding the Epstein investigation, to entities and persons outside the federal government.
+3
diff --git a/vision-fixhub/ds9-unparsed-06/09ac68fc554abb73c3a612b791bcb00e52f91ee943007bb2521e12633cc2059f.receipt.json b/vision-fixhub/ds9-unparsed-06/09ac68fc554abb73c3a612b791bcb00e52f91ee943007bb2521e12633cc2059f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..8c09501e8569a1409d91da40f3679a34b34eeb85
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/09ac68fc554abb73c3a612b791bcb00e52f91ee943007bb2521e12633cc2059f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "09ac68fc554abb73c3a612b791bcb00e52f91ee943007bb2521e12633cc2059f",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "590fa494adafe00c9632f337cfa38e09010c67056ced03292a77d09f5ec7886f",
+  "output_sha256": "4dcd157f70097ecbdfc892eb282a12f85db5a715c3a4f41a8dba3aabd0645696",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/09bb966b69405b26b25596ba174502886878acea4cfd8a6a60a842f3f31e7a13.md b/vision-fixhub/ds9-unparsed-06/09bb966b69405b26b25596ba174502886878acea4cfd8a6a60a842f3f31e7a13.md
new file mode 100644
index 0000000000000000000000000000000000000000..78bb7ff8438aeda159b3cb2e3b31cbf00a484a20
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/09bb966b69405b26b25596ba174502886878acea4cfd8a6a60a842f3f31e7a13.md
@@ -0,0 +1,9 @@
+Subject: Recovered Epstein related emails
+Date: Tue, 25 Jun 2013 14:23:56 +0000
+Importance: Normal
+Attachments: unnamed
+Embedded: unnamed(1); unnamed(2); unnamed(3); unnamed(4); unnamed(5); unnamed(6);
+unnamed(7); unnamed(8); unnamed(9); unnamed(10); unnamed(11); unnamed(12);
+unnamed(13); unnamed(14); unnamed(15); unnamed(16); unnamed(17); unnamed(18);
+unnamed(19); unnamed(20); unnamed(21); unnamed(22); unnamed(23); unnamed(24);
+unnamed(25); unnamed(26); unnamed(27); unnamed(28); unnamed(29)
diff --git a/vision-fixhub/ds9-unparsed-06/09bb966b69405b26b25596ba174502886878acea4cfd8a6a60a842f3f31e7a13.receipt.json b/vision-fixhub/ds9-unparsed-06/09bb966b69405b26b25596ba174502886878acea4cfd8a6a60a842f3f31e7a13.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b3edabd42648ad725f9e4b77156f3121037b16d0
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/09bb966b69405b26b25596ba174502886878acea4cfd8a6a60a842f3f31e7a13.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "09bb966b69405b26b25596ba174502886878acea4cfd8a6a60a842f3f31e7a13",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "b2144eb581052cf9bde609a34f0c52d42d963737cd08f322069e574e9367ba89",
+  "output_sha256": "a858e49b78255939b2c50e401837d36f7ec149a1cff656d8ec0124328c83bb19",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/09cf767f064a34326ac9781bc1aa5b9b1a06cab3ce6ef5458fffc42c9f63e0ce.md b/vision-fixhub/ds9-unparsed-06/09cf767f064a34326ac9781bc1aa5b9b1a06cab3ce6ef5458fffc42c9f63e0ce.md
new file mode 100644
index 0000000000000000000000000000000000000000..bf71d581bfa257f7b2452f3c622355f9bbff9bfe
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/09cf767f064a34326ac9781bc1aa5b9b1a06cab3ce6ef5458fffc42c9f63e0ce.md
@@ -0,0 +1,55 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80893-KAM Doe I. Epstein Motion for Hearing
+Date: Thu, 02 Sep 2010 20:14:07 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Sanchez, Lilly Ann on 9/2/2010 at 4:14 PM EDT and filed on 9/2/2010
+Case Name:
+Doe | Epstein
+Case Number:
+9:08-cv-80893-KAM
+Filer:
+Jeffrey Epstein
+WARNING: CASE CLOSED on 07/20/2010
+Document Number: 213
+Docket Text:
+Defendant's MOTION for Hearing Jeffrey Epstein's Request for Oral Argument in Connection
+with his Motion for Protective Order and Objection to Disclosure of Certain Documents by
+Jeffrey Epstein. (Sanchez, Lilly Ann)
+9:08-cv-80893-KAM Notice has been electronically mailed to:
+Ann Marie C. Villafana
+ann.marie.c.villafana@usdoj.gov, shawn.ball@usdoj.gov
+Bradley James Edwards
+brad@pathtojustice.com. beth@pathtojustice.com
+Jack Alan Goldberger
+jagesq@bellsouth.net, nalanis@agwpa.com
+Katherine Warthen Ezell
+KEzell@podhurst.com, mestrada@podhurst.com
+Lilly Ann Sanchez
+Isanchez@fowler-white.com
+Michael James Pike
+MPike@belclaw.com, bobbie@bclclaw.com, jcadwell@bolelaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Robert Deweese Critton, Jr rcrit@bclclaw.com, bobbie(@bclclaw.com
+
+
+9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP dcecfStamp_ID=1105629215 [Date=9/2/2010] [FileNumber=7962310-0]
+[2a54ecbd12801fc9122023184861f454ffb0e5cбсd08060c4a540355d9c91bdf39a5
+d2d4c22f98a98acdd7fd821112467a519483e6f997e7288824748ae81d09]]
diff --git a/vision-fixhub/ds9-unparsed-06/09cf767f064a34326ac9781bc1aa5b9b1a06cab3ce6ef5458fffc42c9f63e0ce.receipt.json b/vision-fixhub/ds9-unparsed-06/09cf767f064a34326ac9781bc1aa5b9b1a06cab3ce6ef5458fffc42c9f63e0ce.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0a017c5306f209757ca364ca9d5fd5fa76e6279c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/09cf767f064a34326ac9781bc1aa5b9b1a06cab3ce6ef5458fffc42c9f63e0ce.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "09cf767f064a34326ac9781bc1aa5b9b1a06cab3ce6ef5458fffc42c9f63e0ce",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "9dae003e7c220daa0845b37dca9ed932e51fcad2c48ef0e527f75ae9c116d595",
+  "output_sha256": "1605eee4d557402232d010282cb124196e824996fc8ba398ed53b33db45f483c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/09de7a95d10b8bb4f623cfbb3a2fed4055ac66bdebbdc31609b86729b658a481.md b/vision-fixhub/ds9-unparsed-06/09de7a95d10b8bb4f623cfbb3a2fed4055ac66bdebbdc31609b86729b658a481.md
new file mode 100644
index 0000000000000000000000000000000000000000..95bd9ba10632fa16a9095c6b10ce7b4678696008
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/09de7a95d10b8bb4f623cfbb3a2fed4055ac66bdebbdc31609b86729b658a481.md
@@ -0,0 +1,97 @@
+Case 9:08-cv-80736-KAM Document 39
+Entered on FLSD Docket 09/13/2010 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA/JOHNSON
+JANE DOES #1 and #2,
+Petitioners,
+UNITED STATES,
+Respondent.
+PETITIONERS JANE DOE #1 AND JANE DOE #2'S NOTICE
+IN RESPONSE TO ADMINISTRATIVE ORDER CLOSING CASE
+As the Court is aware, this is an action under the Crime Victims' Rights Act
+(CVRA), 18 U.S.C. § 3771, in which two crime victims, petitioners Jane Doe #1 and
+Jane Doe #2, allege that the U.S. Attorney's Office violated their rights under the Act by
+failing to advise them of a plea agreement it had reached with sex offender Jeffrey
+Epstein. On September 9, 2010, this Court sua sponte entered an administrative order
+"closing" the case. The basis for this order was "the underlying [civil settlements]
+between the victims and Mr. Epstein." Order at 1. Jane Doe #1 and Jane Doe #2
+hereby give notice that they intend to make subsequent filings in this case shortly. They
+accordingly request administrative reopening of the case and, if the Court deems it
+advisable, a scheduling conference with the U.S. Attorney's Office regarding the case.
+Precisely what the effect is of an order administratively closing a case is not
+immediately clear to Jane Doe #1 and Jane Doe #2. They believe that such an order
+
+
+Case 9:08-cv-80736-KAM Document 39 Entered on FLSD Docket 09/13/2010 Page 2 of 4
+would automatically lose effect in the event of a subsequent filing. They note that the
+Court did not dismiss their case. Nonetheless, out of an abundance of caution - and to
+provide the Court with additional information about the status of the case -- Jane Doe #1
+and Jane Doe #2 are filing this brief notice that they will be making subsequent filings
+shortly.
+The fact that Jane Doe #1 and Jane Doe #2 have settled their civil cases against
+sex offender Jeffrey Epstein in no way affects their determination to move forward with
+the above-captioned CVRA action against a different entity - the U.S. Attorney's Office
+for the Southern District of Florida. For reasons explained in their earlier pleadings, that
+Office grossly violated their rights under the Act. The fact that Epstein has settled with
+Jane Doe #1 and #2 to resolve his civil liability in no way exonerates the U.S. Attorney's
+Office for its failure to discharge its responsibilities under the Act.
+If the Court wishes to proceed to an expeditious conclusion to this case, Jane
+Doe #1 and Jane Doe #2 have no objection to the Court setting up an expedited
+schedule for proceeding on the case. The Court should be aware, however, of the
+reasons why Jane Doe #1 and Jane Doe #2 have not yet filed for summary judgment in
+this case.
+Jane Doe #1 and Jane Doe #2 have long believed that correspondence between
+the U.S. Attorney's Office and Jeffrey Epstein would corroborate their argument that the
+Office had grossly violated their rights under the CVRA. Just two months ago, in
+connection with their civil case against Epstein, Jane Doe #1 and Jane Doe #2's
+suspicions were confirmed when their legal counsel received correspondence between
+
+
+Case 9:08-cv-80736-KAM Document 39 Entered on FLSD Docket 09/13/2010 Page 3 of 4
+Epstein's criminal defense lawyers and the Office proving that the Office had tried to
+conceal the existence of the plea agreement from them.
+In addition to the
+correspondence, Counsel has received other information from witnesses that further
+strengthens our clients' case under the CVRA. Counsel are now in the process of
+attempting to move forward on this new information and prove their clients' cases
+against the Defendant United States and will be filing the appropriate pleadings to do
+So.
+In light of all this, Jane Doe #1 and #2 ask that the case be administratively
+reopened and, if the Court deems it advisable, that a scheduling conference be set for
+this case.
+DATED: September 13, 2010
+Respectfully Submitted,
+/s/ Bradley J. Edwards
+Bradley J. Edwards
+DuCA
+Paul G. Cassell
+Pro Hac Vice
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+-and-
+
+
+Case 9:08-cv-80736-KAM Document 39
+Entered on FLSD Docket 09/13/2010 Page 4 of 4
+Jay Howell, Esq.
+jay@jayhowell.com
+Jay Howell & Assoc.
+644 Cesery Boulevard
+Suite 250
+Jacksonville, FL 32211
+CERTIFICATE OF SERVICE
+| HEREBY CERTIFY that on September 13, 2010 | electronically filed the
+foregoing document with the Clerk of the Court using CM/ECF. I also certify that the
+foregoing document is being served this day on all parties on the attached Service List
+in the manner specified, either via transmission of Notices of Electronic Filing generated
+by CM/ECF or in some other authorized manner for those parties who are not
+authorized to receive electronically filed Notices of Electronic Filing.
+Is/ Bradley J. Edwards
+Bradley J. Edwards
+SERVICE LIST
+Jane Does 1 and 2 |]. United States
+United States District Court, Southern District of Florida
+Case No. 08-80736-CIV-MARRA/JOHNSON
+Attorney for United States
diff --git a/vision-fixhub/ds9-unparsed-06/09de7a95d10b8bb4f623cfbb3a2fed4055ac66bdebbdc31609b86729b658a481.receipt.json b/vision-fixhub/ds9-unparsed-06/09de7a95d10b8bb4f623cfbb3a2fed4055ac66bdebbdc31609b86729b658a481.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..38dd54aa2ec3f866d7c430a5bed1309b447f0492
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/09de7a95d10b8bb4f623cfbb3a2fed4055ac66bdebbdc31609b86729b658a481.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -48,
+  "dataset": "marble-joined",
+  "doc_id": "09de7a95d10b8bb4f623cfbb3a2fed4055ac66bdebbdc31609b86729b658a481",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "8af85b0b66f4b6554524657eea1e11fe0c83b35800fbd70852cb1c6d3fc17a3d",
+  "output_sha256": "6239e1713bc4e4935c7ed84b823047782aa43e922f57da5a30a5bd0950585e8b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0a2cfdc1dc9bdcbfb541053d516b25b0f6619bfc03820e458a39198a6ae8976e.md b/vision-fixhub/ds9-unparsed-06/0a2cfdc1dc9bdcbfb541053d516b25b0f6619bfc03820e458a39198a6ae8976e.md
new file mode 100644
index 0000000000000000000000000000000000000000..ca76d33b3c6979769530ffd0ad1e798a71ee23d0
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0a2cfdc1dc9bdcbfb541053d516b25b0f6619bfc03820e458a39198a6ae8976e.md
@@ -0,0 +1,3082 @@
+Questions or Changes?
+cingular.com
+• Toll Free 1|
+:
+611 from your wireless phone
+TTY users - 1 866 429-7TTY
+SUMMARY OF MONTHLY CHARGES FOR ACCOUNT
+Previous
+Balance
+629.23
+Payments
+Received
+-629.23
+Late Payment
+0.00
+Total
+Adjustments
+0.00
+Your billing cycle began on October 03, 2005 and ended on November 02, 2005
+Current Monthly Charges
+Monthly Service
+Monthly Usage
+Charges
+Credits
+Government Fees and Taxes
+Total Current Monthly Charges
+TOTAL AMOUNT - Due Upon Receipt
+Date of Invoice: November 05, 2005
+Balanci
+Forward
+0.00
+Current Monthly
+Charges
+388.14
+Total
+Amount Due
+388.14
+300.15
+39.11
+20.00
+-5.00
+33.88
+388.14
+388.14
+AS A CLARIFICATION TO SEPTEMBER'S ANNOUNCEMENT,
+EFFECTIVE OCTOBER 5, 2005, CINGULAR MODIFIED ITS
+INTERNATIONAL DIALING RATES FOR CUSTOMERS WITH THE
+ENHANCED DISCOUNTED INTERNATIONAL DIALING FEATURE.
+RATES FOR CALLS THAT TERMINATE TO A MOBILE PHONE IN
+CERTAIN COUNTRIES CHANGED TO REFLECT CHANGES TO
+SURCHARGES IMPOSED BY OVERSEAS CARRIERS.
+FOR DETAILS, INCLUDING THE NEW RATES FOR EACH COUNTRY,
+VISIT WWW.CINGULAR.COM/NEWINTLRATES.
+r Fold and tear here 7
+Please Return This Portion With Your Payment.
+Use of service or payment of this invoice
+indicates agreement with the General Terms
+and Conditions for wireless service.
+Account Name: JEFFREY E EPSTEIN
+e5, I want to enroll in REFT and hav
+tomatically deducted from the account on my enclosed che
+(see reverse - signature required).
+Date Due
+UPON RECEIPT
+Note:
+>>
+We Print on
+Front and Back
+Service #
+Account
+Total
+Amount Due
+388.14
+Crack esser cree.
+Amount
+Paid
+#BWNHAIGR
+#00000
+2000189 02AT0.517 +AUTO +AUTO T21 1102 10022.5.22.01.1034.0000
+CINGULAR WIRELESS - ATLYS
+PO BOX 6444
+CAROL STREAM, IL 60197-6444
+0000000000000000••
+
+
+Recurring Electronic Fund Transfer (REFT): To enroll: sign below, check the REFT box on the reverse side and
+remit with this month's payment. Keep paying your bill until your statement indicates "Do Not Pay". REFT
+Agreement: I authorize my financial institution to deduct the amount of my monthly wireless phone bill from the
+account associated with the enclosed check and remit payment to Cingular Wireless. This authority will be effective
+until I notify Cingular Wireless to terminate it. I agree that I may be assessed a service charge (up to $20) or late.
+fee or both if a payment is returned by my bank. For more information visit cingular.com/myaccount or call 1
+Please keep a copy of the form below and this REFT Agreement for your records or retain a copy of the
+blank form from next month's invoice.
+Questions? We can help: Cingular Wireless appreciates your business and welcomes the opportunity to assist.
+mu. Visit our website at cinqular.com or contact Customer Care by dialing bll from vour wireless onone or .
+¿ Sabías que también ofrecemos servicio al cliente en tu idioma? Marca 611 desde tu teléfon
+inalambrico ó 1
+desde cualquier teléfono y oprime el *.
+Driving Wireless Safety: Your wireless phone gives you the freedom and flexibility to stay in touch when you
+travel, but don't let a phone call distract you from driving safely. Use hands-free device if allowed or required by
+law. Call Carefully, Arrive Safely.
+Processing Fees: When you pay by check, Cingular Wireless will present the check for payment by your bank
+electronically. Your bank account will be debited in the amount of the check and the transaction will appear on your
+bank statement. Your original check will be destroyed once processed, and you will not receive your cancelled
+check back. If we cannot post the transaction electronically, an image copy of your check will be presented for
+payment. For additional information, please call 1
+Accounts suspended for non-payment will be
+subject to a $25 reactivation fee per line and may be assessed a security deposit prior to reinstatement. Checks
+returned for non-sufficient funds will be charged up to a $30.00 fee.
+Local Tax: Local taxes are based on local government boundaries, the address information you provide for your
+account and/or your wireless telephone number. Please review the local tax chames on vour bill. If you believe
+there is an error in the local tax charge, please contact us immediately at 1|
+local or state laws may require you to follow special procedures when notifying us about a local tax dispute. You
+may also use the form below to notify us of any change to your taxing address. Thank you for your cooperation.
+Early Termination Fee (ETF): If you cancel service before your contract end date (including if you switch your
+wireless number to another carrier), you will be charged an Early Termination Fee of up to $200.
+One Time Checking Account Payment Authorization Agreement (for use with kiosk payment): I authorize
+Cingular Wireless to make this one-time bill payment by debiting my bank account. I can cancel authorization by
+contacting an in-store sales person. If my bank rejects a payment, I may be charged a return fee.
+Please Send Correspondence To:
+Cingular Wireless Next Generation Correspondence
+P.O. Box 68056
+Anaheim Hills, CA 92817-8056
+2000189.000001349.8
+Accoung Name and transier Financial Responsibles clearly and check the box on the reverse side. Please contact Customer Care to change the
+New Billing Address
+City
+State
+Zip
+Home Phone (
+_)
+Work Phone (
+If your billing address is NOT your Tax Address, please enter the Tax Address below. (Multi-line accounts should attach a list of each wireless number
+and the respective Tax Address.)
+New Tax Address
+City
+Wireless Number (
+State
+Zip
+Recurring Electronic Fund Transfer (REFT) Enrollment. Please read the agreement on the top portion of this page, sign below and check
+he "REFT Registration" box on the reverse side
+Financial Account Holder Signature
+• + I do not wish to receive email notification of special oilers avalable to Cingular Wireless customers.
+
+
+LATE PAYMENT CHARGE:
+A 1.5% LATE PAYMENT CHARGE PER MONTH MAY BE APPLIED FOR
+AMOUNTS UNPAID 20 DAYS AFTER THE DATE OF INVOICE
+(AK 0.875%, AR 0.085%, NE 1.33%, WI 1.00%).
+ACCOUNT DETAILS
+Detail of Payments - Thank You!
+Item Description
+1 PAYMENT
+Total of Payments
+Current Subscriber Monthly Charges and Credits
+Subscriber Number
+Subscriber Name
+Date Applied/Reversed Payment Amount
+10/29/05
+-629.23
+Total Current Subscriber Monthly Charges and Credits
+Total Current Monthly Charges
+SUMMARY OF CURRENT ACTIVITY
+FOR
+Monthly Service Charges
+Item Description
+1 CALL WAITING
+2 TEXT MESSAGING PLAN - 0 MSGS
+3 CALLER ID
+4 VOICEMAIL
+5 DETAIL BILLING
+6 REGULATORY PROGRAM CHARGE
+7 CALL FORWARDING
+8 WORLDCONNECT
+9 THREE WAY CALLING
+10 BLACKBERRY $49.99
+11 NATIONAL PLAN $29.99
+Total Monthly Service Charges
+Service Dates
+10/03/05 • 11/02/05
+10/03/05 - 11/02/05
+10/03/05 - 11/02/05
+10/03/05 - 11/02/05
+10/03/05 - 11/02/05
+10/03/05 - 11/02/05
+10/03/05 • 11/02/05
+10/03/05 - 11/02/05
+10/03/05 - 11/02/05
+10/03/05 - 11/02/05
+10/03/05 • 11/02/05
+Monthly Usage Charges
+Item Description
+1 100 ADD'L ANYTME MIN
+2 UNLIMITED N/KND MIN
+3 MESSAGE RETRIEVAL
+Total Monthly Usage Charges
+Onty Used
+22 MIN
+10 MIN
+3 EVT
+-629.23
+-629.23
+266.35
+82.12
+39.67
+388.14
+388.14
+0.00
+0.00
+0.00
+0.00
+0.00
+1.75
+0.00
+0.00
+0.00
+49.99
+29,99
+81.73
+0.00
+0.00
+0,00
+0.00
+Account Name
+SUMMARY OF CURRENT ACTIVITY - CONTINUED
+Other Subscriber Charges
+Item Description
+1 MCTD SURCHARGE
+2 NY CITY UTILITY G.R. SUR
+3 STATE TELECOM EXCISE TAX
+4 FEDERAL UNIVERSAL SERVICE FUND SURCHARGE
+Total Other Subscriber Charges
+Other Subscriber Credits
+Item Description
+1$5 MONTHLY CREDIT
+Total Other Subscriber Credits
+Subscriber Govemment Fees and Taxes
+Item Description
+1 SALES TAX
+2 FEDERAL EXCISE TAX
+Total Subscriber Government Fees and Taxes
+TOTAL CURRENT CHARGES FOR
+DETAIL OF CURRENT ACTIVITY
+VOICE USAGE FOR
+Number
+Item Date Time
+Called
+10241287A
+13022.
+7:59
+8 10/23 03:45P
+9 10/25 09:36A
+10 10/25 09:40A
+11 10/25 01:21P
+13 1823 81 36P
+14 10/27 06:37P
+15 10/31 01:13P
+TOTAL VOICE USAGE FOR
+COLUMBUS OH
+COLUMBUS OH
+EW YORK N
+ICOMING
+CANALWHSTR C
+COLUMBUS OH
+Onty
+Used
+Rate
+ШИШЕЧШЕ
+
+0.16
+0.52
+0.71
+212
+-5.00
+-5.00
+2.41
+0.87
+3.28
+82.12
+
+
+
+2000189.000001350
+* cingular
+SUMMARY OF CURRENT ACTIVITY
+FOR
+Monthly Service Charges
+Item Description
+1 CALL WAITING
+2 TEXT MESSAGING PLAN - 0 MSGS
+3 CALLER ID
+4 EARLY EVENING
+5 ENH DISCOUNT INTL DIAL
+6 MULTIME DIA MESSAGING $2.99
+8 MMODE/DATA SERVICE (4MB)
+9 NATIONAL PLAN $149.99
+10 THREE WAY CALLING
+11 REGULATORY PROGRAM CHARGE
+12 VOICEDIAL SERVICE $3.99
+13 DETAIL BILLING
+14 DISCOUNTED INTERNATIONAL ROAMING
+Total Monthly Service Charges
+Monthly Usage Charges
+Item Description
+1 100 INCL. MSGS SENT
+2 UNLIMITED N/WKND MIN
+3 ENH DISC INT DL
+4 MESSAGE RETRIEVAL
+5 400 ADDI ANYTME MIN
+6 UNLIM MOBL TO MOBL
+7 CALL WAITING
+8 EARLY EVENING N/WKND
+9 411 INFO
+10 INCLUDED IN PLAN MB
+11 INT'L ROAMING VOICE
+12 INTL ROAM TEXT MSG
+13 INCLUDED MINUTES
+14 INTL TEXT MSG
+15 TEXT MESSAGES SENT
+16 CONFERENCE CALLING
+Total Monthly Usage Charges
+| 1,024 Kilobytes (KB) = 1 Megabyte (MB)
+Other Subscriber Charges
+Item Description
+1 FEDERAL UNIVERSAL SERVICE FUND SURCHARGE
+2 MCTD SURCHARGE
+3 NY CITY UTILITY G.R. SUR
+4 STATE TELECOM EXCISE TAX
+Total Other Subscriber Charges
+Service Dates
+10/03/05 - 11/02/05
+10/03/05 - 11/02/05
+10/03/05 - 11/02/05
+10/03/05 - 11/02/05
+10/03/05 - 11/02/05
+1003/05 11/02/05
+10/03/05 - 11/02/05
+10/03/05 - 11/02/05
+10/03/05 - 11/02/05
+10/03/05 - 11/02/05
+10/03/05 - 11/02/05
+10/03/05 • 11/02/05
+10/03/05 - 11/02/05
+Onty Used
+SF7A8
+10-58
+0.00
+0.00
+6.70
+0.00
+0.00
+0.00
+0.00
+0.00
+10.50
+13.96
+0.50
+0.00
+0.75
+6.70
+0,00
+39.11
+Account Name
+SUMMARY OF CURRENT ACTIVITY - CONTINUED
+Subscriber Government Fees and Taxes
+Item
+Description
+1 LOCAL WIRELESS SURCHARGE
+2 ROAMING TAX
+3 SALES TAX
+4 ST WIRELESS COMM SURCHARGE
+5 FEDERAL EXCISE TAX
+Total Subscriber Government Fees and Taxes
+TOTAL CURRENT CHARGES FOR
+DETAIL OF CURRENT ACTIVITY
+VOICE USAGE FOR
+Number
+Item Date Time
+Called
+WPALMBEACH FL
+PALM BEACH FL
+IPALMBEACH FL
+W ANGELES CA
+NY ZONE 1 NY
+mobile UK
+1115
+BEN ON N
+NEW
+IWINCITIES MN
+NCOMING
+PALM BEACH FE
+ACH E
+W PALMBEACH FL
+WPALMBEACH FL
+mobile UK
+1158A
+01:25P
+
+83888
+NY ZONE 1 NY
+RALEIGH NC
+NEWYORKZNI NY
+NY ZONE 1 NY
+WPALMBEACH FL
+NCOMING
+NCOMING
+NWYRCYZNO1 NY
+OMIN
+NCOMING
+PALM BEACH FL
+JEW YOR
+40 10/02 05:18P
+
+0.30
+0.32
+11:20
+23.19
+266.35
+Used Rate Description
+2 MIN
+UNLIMITED N/WKND MIN
+EMIN
+VLIM
+JI IM
+D
+KND
+KN
+M
+1 MI
+2 MIN
+UNLIMITEB NA
+ANU MIL
+CND MIN
+2MIN
+UNLIMITED N/WKND MIN
+UNLIMITED NW KND MIN
+ШШЕ
+1 MIN
+2 MIN
+1 MIN
+IMIN
+IMIN
+1 MIN
+0.25 ENH DISC INT DL
+UNLIMITED
+NAWKNDMIN
+LIMIT
+UNLIMITED N/WKND MIN
+UNLIMITED
+EB NAWRNB
+JNLIMITED
+LARKND MIN
+JNLIMITED
+WKND MIR
+MESSAGE RETRIEVAL
+UNLIMITED NWIN MIN
+UNLIMITED N/WKND MIN
+UNLIMITED NIND MIN
+0.25 ENH DISC INT DL
+UNLIMITED NAND MIN
+1 MIN
+UNLIMITED N/WKND MIN
+MESSAGE RETRIEVAL
+UNLIMI
+ED NAWKND
+L MIN
+LEM
+2 MIN
+2 MIT
+5 MIN
+3MIN
+2 MIN
+1 MIN
+1 MIN
+UNLIMITED
+VW KND MIl
+MESSAGE RETRIEVAI
+UNLIMITED N/WKND MIN
+UNLIMIT
+UNLIM
+ER
+NWIND MIN
+UNLIMI
+ED N/WKND MI
+UNLI
+22
+KND
+WEND
+UNLIMIT
+ED
+N/WKND MIN
+UNLIMI
+ED
+UN
+MAKE MIN
+KND
+JNLIT
+INLIMO
+N
+KND
+KND
+8MIN
+UNL
+ED
+KND MIN
+UNLIM
+ED NASKND MIN
+NAVEND MIN
+1EVT
+1 MIN
+MESSAGE RETRIEVAL
+UNLIMITED N/KND MIN
+
+
+VOICE USAGE FOR
+Number
+Called
+Item Date Time
+41 10/02 05:19P
+42 10/02 05:26P
+13 10/02 05:418
+44
+10/02 05-50P
+45 10/02 05:53P
+46
+47
+NOz 05:53
+0/02 05:57
+48 10/02 05:58P
+49 10/02 06:02P
+50 10/02 06:51P
+51
+10/02 07:43P
+10/02 07:44P
+07:46P
+10/02 0B:32P
+09:37P
+09:47P
+08:58A
+10/03
+09:02A
+10/03
+09:06A
+10/03 09:09A
+0/03 09:10A
+10/03 09:11A
+NEWYORKZN1 NY
+NY ZONE
+W ANGELÉS
+W ANGELES CA
+W ANGE.
+.ES CA
+- Continued
+Onty
+Used
+3MIN
+7MIN
+4MIN
+2 MIN
+1 MIN
+IMIN
+1EVT
+LMIN
+W
+ANGELES CA
+WPALMBEACH FL
+NEWYORKZNI NY
+WPALMBEACH FL
+BOCA RATON FL
+WPALMBEACH FL
+NCOMING
+1 MIN
+LEVI
+2 MIN
+Rate Description
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND MIN
+UNLIMITEB NAVRNB MI
+INLIMITED NAVKND
+UNLIMITED N/KND MIN
+UNLIMITED N/KND MIN
+UNLIMITED N/KND MIN
+MESSAGE RETRIEVAL
+INLIMIT
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND MIN
+MESSAGE RETRIEVAL
+UNLIMITEB NWNB MIN
+INLIMIT
+UNLIMITED N/WKND MIN
+UNLIMITED
+N/WKND
+63
+10/03 09:12A
+388G
+10/03 09:13A
+09:14A
+ID/D3 09:37A
+10/03 09:38A
+68 10/03 09:45A
+69 10/03 09:52A
+L0V03 09
+10/03 09:357
+MIAMI FL
+23
+OMING
+ALMBEACH FL
+WPALMBEACH FL
+PALM BEACH FL
+NCOMING
+IEW YORK NY
+100 05
+18/03 10:204
+10/03 11:21A
+1003 13.118
+NO MANY OH
+70100313:19
+20/03 12:388
+NCOMING
+10/03 01:38P
+10/03 01:39P
+NY ZONE 1 NY
+10/03 01:41P
+10/03 01:45P
+NWYRCYZNO1NY
+10/03 01:52P
+10/03 01:53P
+89 10/03 02:24P
+90 10/03 02:49P
+91
+10/03 03:45P
+92 10/03 03:48P 30165/80820
+FRANCE
+10/03 03:56P
+10/03 03:59P
+10/03 04:01P
+MARION OH
+WPALMBEACH FL
+UNLIM
+400 AD
+UNLIM
+9MIN
+9MIN
+0.63
+IMIN
+UNLIM
+Account Name
+VOICE USAGE FOR
+Number
+Called
+Item Date Time
+96 10/03 04:02P
+97 10/03 07:26P
+10/03 07:2
+10:03 07:2
+100 10/03 07:29P
+01 10/03 07:34
+12 1003 07:35
+103 10/03 09:14P
+14 10 04 06:59
+)5 10/04 08:26
+106 10/04 08:50A
+108 1004 08 554
+19 10 04 08:55
+10 10/04 09:27
+I PALMBEACH F
+ARION O
+JEW YORK NY
+OMING
+NWYRCYZNO1 NY
+IEW YORK N
+ROOKLYN N'
+BROOKLYN NY
+- 10104 09:2
+EW YORK N
+TPALMBEACH F
+- Continued
+Onty
+Used Rate Description
+3 MIN
+400 ADD'L ANYTME MIN
+1 MIN
+EARLY EVENING N/WKND
+MI
+MI
+1 MIN
+1MIN
+1 MIN
+ZMIN
+1MIN
+3 MIN
+2 MIN
+NANKN
+EARLY EVENING N/WKND
+EARLY EVENING NWKNE
+N/WKND
+UNLIMITED N/WKND MIN
+UNLIM MOBL TO MOBL
+400 ADD'L ANYTME MIN
+400 ADD'L ANYTME MIN
+EMIN
+_ML
+1EVT
+I MIN
+400 ADD'L ANYTME MIN
+100 ADD'L ANYTME
+1.50 411 INFO
+100 ADD'U
+ANYTME MIN
+6MIN
+FL
+NEW
+RTH FL
+ACH FL
+
+2A28888888888888888888888888
+1AMI F
+EA
+NIN
+NING
+N/W
+N/W KND
+G
+N/W
+KND
+KNB
+ANYTME
+ISE 100000 681000Z
+
+
+VOICE USAGE FOR
+Number
+Item Date Time Called
+160 10/05 10:32A
+161 10/05 10:57A
+55
+10/85 11:01A
+-01A
+164 10/05 11:11A
+100 A
+167 10/05 11:18A
+169 10/83 11:38A
+10/05
+170 10/05 11:58A
+171
+10/05 12:01P
+133
+10/05 12:07P
+:07P
+174 10/05 12:45P
+10/05 01:48P
+12:49P
+EW YORK
+NY
+EW YORK
+NY
+JEW YORK NY
+EW YORK
+NY
+- Continued
+Onty
+Used Rate Description
+2 MIN
+400 ADD'L ANYTME MIN
+3MIN
+MI
+400 ADD'L ANYTME MIN
+100 ABB'L ANYTE MIN
+6MIN
+400 ADD'L ANYTME MIN
+MI
+OU ADD"
+ANYTME MIN
+INLIM MOBL TO MOBI
+1 MIN
+UNLIM MOBL TO MOBL
+2 MIN
+1 MIN
+3MIN
+JEW YORK NY
+NCOMING
+NCOMING
+332₴
+22
+B88838203
+§=9ºĞ6ґ
+
+
+TY
+NY
+2N2
+0O
+< NY
+YO
+RK NY
+MING
+N
+YRCYZNO1 NY
+FRANCE
+3MN
+[MIN
+1 MIN
+3MIN
+3 MIN
+FEEB
+
+1 MIN
+2 MIN
+3 MIN
+1 MIN
+4 MIN
+1M
+2 MIN
+1 MIN
+IMIN
+0.07
+400 ADD'L ANYTME MIN
+100 ADD'L ANYTME MIN
+' ALL WAITING
+00 ADD'L ANYTME MIl
+NLIM MOBL TO MOBI
+400 ADD'L ANYTME MIN
+DO ADD'L ANTIME MI
+400
+100
+40
+400
+100
+Account Name
+
+VOICE USAGE FOR
+Number
+Item Date Time Called
+221 10/06 02:59P
+2 10/06 03:-
+МО6 03:1
+224 10/06 04:23P
+225 10/06 04:25P
+226 10/06 04:26P
+27 10/06 04:28
+228 10/06 04:318
+229 10/06 04:37P
+• 10/0b 05:2
+WPALMBEACH FL
+MIAMI FL
+32 1006 05:39
+33 10/06 05:40
+234 10/06 05:44P
+235 10/06 05:47P
+MIAMI FE
+NEW YORK
+ORK NY
+W PALMBEACH FL
+- Continued
+Onty
+Used Rate Description
+8MIN
+UNLIM MOBL TO MOBL
+1EVT
+CALL WAITING
+EMIN
+400 ABBL ANYTME MIN
+2 MIN
+UNLIM MOBL TO MOBL
+MESSAGE RETRIEVAL
+400 ADDI ANYTME MIN
+2 MIN
+MIl
+MIR
+2 MIN
+LMIN
+1 MIN
+4 MIN
+4 MIN
+L MIN
+LEV
+400 ADDL ANYTME MIN
+400 ABBL ANYT ME MIN
+400 ADDL ANYTME MIN
+400 ABBL ANYTE MIN
+JNLIM MOBL TO MOBL
+100 ADDL ANYTME MIN
+UNLIM MOBL TO MOBL
+UNLIM MOBL
+TO MOBL
+DROP
+IN
+1 MIN
+6 MIN
+0.07
+213
+10/06
+01:55P
+sasses
+9gg5985
+NY
+323₴
+•1:00
+RK NY
+RK NY
+NY
+NY
+MOBL
+IKND
+MO
+IN
+IN
+ISE100000 681000Z
+04:30P
+04:32P
+10/07 04:38P
+10/07
+05:05P
+10/07
+05:14P
+10/07
+05:39P
+MIAM
+CAM
+NEW
+MA
+NY
+FL
+MIAMİ
+FRANCE
+HE MIN
+B MIN
+2 MIN
+1 MIN
+TO MOBI
+NAWKNO
+: MIN
+0.0
+0.07
+ENH
+DISC
+INT
+DL
+J0 ADDL ANYIME M
+O ADDI ANYTME M
+400 ADD ANYTME MIN
+0.07
+1.12
+
+
+VOICE USAGE FOR
+Number
+Called
+Item Date Time
+2BD 10/07 06:03P
+281 10/07 06:24P
+32 10/07 08:40
+33 10 07 08:41
+284 10/07 09:32P
+35 10/08 02:33
+287 10/08 01:56P
+10/08 02:00P
+290 10/08 02:07P
+8 02:08
+92 10/08 03:08
+291 1008 03328
+295 10/09 01:47P
+§5º899=8ЕCs98€98
+
+10/11
+:00
+WPALMBEACH FL
+EW YORK N
+(PALMBEACH F
+NEW YORK ANY
+DADE
+WPALMBEACH FL
+PALM BEACH FL
+NEW
+YORK NY
+NEW YORK NT
+CHTAMST
+THSV
+- Continued
+Onty
+Used
+Rate Description
+1MIN
+UNLIM MOBL TO MOBL
+1 MIN
+1 MIN
+SMIN
+1 MIN
+SMIN
+1MIN
+1MIN
+1 MIN
+2MIN
+1MIN
+ED
+ZMIN
+2 MIN
+SMIN
+2MIN
+1 MIN
+1 MIN
+1 MIN
+UNLIM
+UNLIM
+UNLIM
+UNLIM
+UNLIMBER
+UNLIM
+UNLIM
+ED
+UNLIM
+ED
+UNLIM
+KND
+KNB
+IN
+KN
+99g
+xxX
+zzzİ
+22
+DENZO
+IN
+NY
+NE
+NY
+ORK
+NY
+MING
+OMING
+NY
+22
+TIm
+INC
+NEW
+ORK NY
+IF
+OO
+NY
+IN
+000z
+K
+NY
+0000
+XXXX
+2333z
+NY
+ING
+22
+mm
+vl
+INC
+INC
+MAR
+INC
+222ONNO
+ON OH
+MING
+NE 1 NY
+1 NY
+NY
+NY
+00
+NY
+RANDOLPH MA
+IN
+IN
+INL
+INT
+IN
+Account Name
+VOICE USAGE FOR
+Number
+Called
+Item Date Time
+344 10/13 01:02P
+345 10/13 02:43P
+345 1843 83560
+348 10/13 04:11P
+349 10/13 04:12P
+05:20P
+352 10/13 05:20P
+13 05:26P
+354 10/13 03:57P
+35 1013 07:358
+56 10/13 07:36F
+37 1013 07:38
+8 10 13 07:64
+08
+888
+NY
+VE 1
+NY
+ORK
+NY
+ORKN
+RK
+NY
+ISTTHS
+RK
+VI
+NY
+RK
+NY
+I BANY
+ALBANY OH
+YORK NY
+ING
+ORK
+RK
+LSD14
+CA
+ING
+NE 1
+ING
+OO
+RK
+RK
+ING
+VT
+2 MIN
+1EVT
+L MIN
+I MIN
+2 MIN
+L MIN
+1 MIN
+7 MIN
+4 MIN
+4 MIN
+12MIN
+ITEr
+4 MIN
+1EVT
+2 MIN
+I MIN
+7 MIN
+IEV
+-
+gg839 1
+BEE BEE
+- Continued
+Onty
+Used Rate Description
+6MINI
+UNLIM MOBL TO MOBL
+1 MIN
+400 ADD'L ANYTME MIN
+NCOMING
+- MIN
+NLIM MOBL TO MOB
+DO ADO'L ANYTME MI
+2 MIN
+UNLIM MOBL TO MOBL
+EVT
+MESSAGE RETRIEVAL
+IMIN
+400 ADD'L ANYTME MIN
+1EVT
+CALL WAITING
+2 MIN
+UNLAR MOALTO MOBIL
+MOBL TO MOBL
+NY ZONE 1 NY
+1 MIN
+UNLIM MOBL TO MOBL
+4 MIN
+1 MIN
+VEENS N
+2MIN
+IEW YORK N
+2MIN
+EARLY EVEN AN
+1EVT
+MESSAGE RETRIEVAL
+JY ZONE 1 N'
+1 MIN
+EW YORK N'
+NY
+1 MIN
+NE
+NY
+ORKE
+NY
+ING
+RK
+NY
+TEDION
+ND
+KND
+G
+ND
+ND
+KND
+N/WKND
+6 MIN
+MINC
+LMIN
+400
+ATE MIN
+YORK NY
+1MIN
+FRE
+ILII
+M
+MOBL
+3MIN
+UN
+1 MIN
+IMIN
+FEEL
+INCLUDE
+
+MOBL
+UNLIM MOBL TO MOBL
+'ALL W
+UNLIM
+AITING
+MOBL TO MOBL
+
+2000189.000001352
+
+2000189.000001352
+VOICE USAGE FOR
+Number
+Called
+Item Date Time
+400 10/14 03:03P
+401 10/14 07:20P
+483
+10/14 07
+404
+10/14
+07:40P
+LO.
+10/14 07:58P
+10/14
+10/14
+09-20A
+10:07A
+9588
+8888888gg
+88889
+Toll Free CL
+VEWYORKZNI NY
+COMING
+NY
+ZONE
+1 NY
+NCOMING
+GLEN COVE NY
+NY ZONE 1 NY
+• Continued
+Onty
+Used
+Rate Description
+3MIN
+1 MIN
+EARLY EVENING N/WKND
+_ MIN
+IMIN
+ING NAWKNO
+1 MIN
+EARLY EVENING N/WKND
+•MIL
+EARLY EVENING N/WKND
+EARLY EVENING N/WKND
+2MIN
+EARLY EVENING N/WKND
+EMIN
+EARLY EVENING
+NIWKND
+ITED NAKND
+2 MIN
+UNLIMITED N/KND
+INLIMI
+INLIMITI
+3 MIN
+2 MIN
+UNLIMIT
+UNLIM
+UNL
+LIMIT
+NY
+eca..............
+220222:
+Account Name
+VOICE USAGE FOR
+Number
+Item Date Time
+Called
+465 10/15 06:39P
+466 10/15 06:51P
+57 10/15 07:22
+58 10/15 07:33
+469 10/15 07:35P
+471 18/16 08 З1A
+10/16 08 34A
+472 10/16 08:35A
+13 10/16 08:42
+74 10/16 08:50
+475 10/16 09:04A
+479 18/16 1:054
+478 10/16 11:09A
+479 10/16 11:13A
+8110/18 11:27A
+10/16
+20A
+10/16
+10/16
+
+....
+: 33838383333
+
+NWYRCYZN01 NY
+OMIN
+QUEENS NY
+OUEENS NY
+WILLOUGHBY OH
+- Continued
+Onty
+Used
+Rate Description
+2 MIN
+UNLIMITED N/WKND MIN
+1 MIN
+UNLIMITED N/WKND MIN
+2 MIN
+UNLIMITE NANB MIN
+2 MIN
+EMIN
+1 MIN
+1 MIN
+2 MI
+3 MIN
+2MI
+2 MIN
+EV
+4 MIN
+3 MIN
+L MIN
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND
+UNLIMITED NWKND
+UNLIMITED N/WKND MIN
+UNLIMITED NWKND MIN
+LIMI
+ED NWKND
+UNLIMITED N/WKND MIN
+UNLIMITE NAWNB MIN
+1.50 411 INFO
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND MIN
+UNLIMITED
+UNLIMITED MAKE MIN
+HBY
+OH
+222≥ ≥≥
+N
+IM
+!!!!!!!!!
+NY
+RI
+35
+NY
+IRK NY
+G
+JNI
+
+NY
+UN
+5 5
+
+150
+125
+
+
+VOICE USAGE FOR
+Number
+Called
+Item Date Time
+529 10/18 03:20P
+530 10/18 03:45P
+31 10/18 03:47P
+32 10/18 03:51F
+533 10/18 03:52P
+0/L& 03:53
+536
+10/18 04:34P
+88 1018 0478P
+539 10/18 04:50P
+543 10/9 08:564
+544 10/19 09:37A
+545 10/9 09 SLA
+Been 200200800040020028000802082860000200A9053
+888888889058889999988888888888888E8855888
+èс°°9e9g8°998990°738E38098e33÷B99E
+
+
+CHTAMSTTHS VI
+IEW YORK NY
+'HTAMSTTHS V
+NCOMING
+ORK N
+EW YORK N
+NCOMING
+NEW
+YORK NY
+MARION OH
+NY
+NY
+- Continued
+Onty
+Used
+Rate Description
+1MIN
+2MIN
+UNLIM MOBL TO MOBL
+2 MIN
+VCLUDED MINUTE:
+1 MIN
+CLUDED MINUTE
+1 MIN
+ZMIN
+3MIN
+UNLIM MOBL TO MOBL
+2MIN
+UNLIM MOBL TO MOBL
+2MIN
+1 MIN
+6MIN
+MINUT
+IMIN
+UNLIM
+BL 10 MoBI
+1 MIN
+INLIM MOBL TO MOBI
+2MIN
+UNLIMITED N/WKND MIN
+1 MIN
+UNLIM MOBL
+O MOBL
+3MIN
+6 MIN
+4MIN
+NCLUDED MINUTES
+IC
+NY
+NY
+RK
+RK
+33 323
+VI
+IN
+INLIN
+INLIN
+INCLU
+NCLU
+UNLIM
+LU
+IN
+KN
+U
+INC
+INC
+INC
+Account Name
+
+VOICE USAGE FOR
+- Continued
+Number
+Item Date Time
+Called
+Onty
+Used Rate Description
+594 10/20 05:59P
+1 MIN
+UNLIM MOBL TO MOBL
+595 10/20 07:53P
+1 MIN
+EARLY EVENING N/WKND
+597 10/20 08:01P
+MARION OH
+10/20 08:01P
+1 MIN
+EARLY EVENING N/WKND
+10/21 05:15A
+D000
+21
+NCOMING
+. MIN
+05:39A
+MARION OH
+UNLIMITEB NAVNB MIN
+INLIMITE
+21 05:50A
+MARION OH
+1 MIN
+UNLIMITED N/WKND MIN
+21 07:23A
+2MIN
+CLUDED MINU
+09:40A
+2 MIN
+CHINED MINUT
+121 10:43A
+QUEENS NY
+4 MIN
+10:478
+JEW YORK NY
+2 MIN
+11:004
+NCOMING
+1 MIN
+NELUBEB MINUTE!
+ED MINUTES
+606
+607
+10/21 127A
+4 MIN
+NCLUDED MINUTES
+NCOMING
+1 MIN
+NCLUDED MINUTES
+608 10/21
+11:58A
+1 MIN
+9009e8 990802280880020200298
+10
+12:10P
+2:12P
+2 MIN
+NCLUDED MINUT
+2MIN
+NCLUDED MINUT
+NEW ARK NJ
+2 MIN
+1 MIN
+[THS VI
+2 MIN
+NCOMING
+NCOMING
+1 MIN
+CHTAMSTTHS VI
+CHTAMSTTHS V
+NPALME
+CHTAMSTTHS VI
+WPALMBEA
+NEW
+
+636
+
+04-
+:29F
+637
+10/21 04:30P
+638
+04:35P
+BEBERO
+
+
+645
+05:26P
+
+PRODDE
+
+NO KE NY
+NCOMING
+NORTH DADE FL
+NCOMING
+CHTAMSTTHS VI
+NCOMING
+NCLUDED MINUT
+LUDED
+INCLU
+MINU
+DED
+MINI
+UDED
+MI
+UTES
+CLUDED
+ZMIL
+2 MIN
+1 MIN
+MINUTES
+IN
+CLUDED
+MINUT
+22
+UTES
+LUBEB
+1MIN
+1 MIN
+3 MIN
+2 MIN
+2 MIN
+1 MIN
+2 MIN
+INCLUDED
+22
+IN
+LUDED
+MI
+22
+UTES
+CLUBEB
+MINI
+NUTES
+CALL DANUTES
+1 MIN
+5 MIN
+INCLUBEB MINUTES
+INCLUBEB MINUTES
+1 MIN
+TO MOBL
+IEVT
+MESSAGE RETRIEVAL
+CLUDED MINUTE
+LI WAITIN
+LEVT 1.50 419
+NEINDED MINUTES
+6MIN
+1 MIN
+3 MIN
+1 MIN
+2 MIN
+I MIN
+UNLIM MO BL TO MOBIL
+1EVT
+MESSAGE RETRIEVAL
+UNLIM MOBL TO MOBL
+MESSAGE RETRIEVAL
+ЗMIN
+2 MIN
+3 MIN
+2 MIN
+2 MIN
+INCLUBED MINUTES
+CLUDED MINUTE
+CLUDED MINUTE
+EARLY EVENING N/WKND
+2000189.000001353
+
+
+2000189.000001353
+VOICE USAGE FOR
+Number
+Called
+Item Date Time
+652 10/21 08:05P
+653 10/21 08:06P
+654 10/21 08:08P
+655
+659
+08:13P
+10/2
+09:15P
+10:01P
+658
+10/21 10:02P
+10:55P
+10/2
+11:05P
+661
+11:06P
+12L
+107H
+66-4
+10/22 09:04A
+565
+10/22
+09:09A
+666 10/22 09:44A
+10/22 09:46A
+668 10/22 02:02P
+669 10/22 02:59P
+670
+10/22 03:28P
+872
+673
+DO
+04:16P
+04:17P
+10/22 04:21P
+674
+10/22
+04:59P
+876
+16:08P
+677
+16:50₽
+10/22 07:54P
+0/8
+<70
+10/22 07:56P
+10/77 08-180
+680
+L0/22 08:19|
+681
+10/22 10:181
+683 18/23 13:93A
+685 18/23 10:50A
+689 18/23 1196A
+688 10/23 11:42A
+6R0
+1823 1145
+691 10/23 01:01P
+692 10/23 01:26P
+893 18/23 0139₽
+696 18/23 0138P
+697 10/23 02:23P
+69B 10/23 02:24P
+699 10/23 02:26P
+700 18/23 02:39P
+702 10/23 04:18P
+703 10/23 04:19P
+704 10/23 04:45P
+QUEENS NY
+MIAMI FL
+NOZONE
+ZONE I NY
+NWYRCYZNO1 NY
+NWYRCYZNO1 NY
+NEW
+YORK NY
+NCOMING
+CHTAMS"
+THS VI
+- Continued
+Onty
+Used Rate Description
+1 MIN
+EARLY EVENING N/WKND
+3MIN
+EARLY EVENING N/WKND
+EV
+EARLYEVENNG NAWKND
+2 MIN
+EMIN
+2 MIN
+EMIN
+1 MIN
+I MIN
+1 MIN
+2 MIN
+1 MIN
+EV
+1 MIN
+LEVT
+1 MIN
+ZMIN
+LENT
+1 MIN
+EARLY EVENING N/WKND
+INLIMITED NAVKND MIR
+INLIMITED NAVKND MI
+UNLIMITED N/WKND MIN
+UNLIMIT
+UNLIM
+WKN
+UNLIMITED N/WKND
+UNLIMITED MAKE
+UNLIMITED NAKND
+UNLIM
+ITED NWKND
+UNLIMITED N/KND MIN
+MESSAGE RETRIEVAL
+UNI
+UNL
+MIAMI FL
+NEWYORKZNI NY
+YORK NY
+NEW ORK NY
+MIC OMING
+NCOMING
+NE TOOK Y
+IWYRCYZNO1 N
+COMIN
+MIAMI FL
+NCOMING
+NEW YORK N°
+2 MIN
+2 MIN
+• MIN
+LEVT
+2 MIN
+2 MIS
+1EVT
+EMIN
+1EVT
+EMIN
+1 MIN
+EMIN
+1 MIN
+8MIN
+IMIN
+1EVT
+EMIN
+1 MIN
+2 MIN
+MI
+> MIN
+1EVT
+1 MIN
+IN
+Account Name
+VOICE USAGE FOR
+Number
+Item Date Time Called
+705 10/23 04:47P
+16 10/23 04:48
+07 10/23 07:05
+708 10/23 07:06P
+718 10/23 08:22P
+711 10/23 08:23P
+712 10/23 08:42P
+713 10/23 08:42P
+714 10/23 08:44P
+715 10/23 08:45P
+/23 08:58
+BP
+888
+:OBP
+:42A
+:22A
+
+
+: 23A
+:03P
+:09P
+68058
+Annie
+99999
+88888
+740 10/25
+09:33A
+3A2
+88
+
+g88983
+749
+10/25
+11:03A
+99999
+HANA
+EW YORK N
+Y ZONE 1 N
+INCOMING NY
+BROOKLYN NY
+NEW YORK
+NWYRCYZN01 NY
+INF 201
+ZONE 1 NY
+NY ZONE 1 NY
+INCOMIN
+- Continued
+Onty
+Used Rate Description
+1EVT
+MESSAGE RETRIEVAL
+1 MIN
+UNLIMITED N/WKND MIN
+UNLIMITE NW KNB MIN
+1EVT
+2 MIL
+LEV
+1EVT
+ZMIN
+2 MIN
+CONFERENCE CALLING
+LIMITED NWKND I
+NFERENCE CALLI
+CALL WAITING
+UNLIMITED MARN MIN
+UNLIMITED N/WKND MIN
+MELTED TUKE MIN
+DNAKND MI'
+1 MIN
+1 MIN
+1 EV
+2 MIN
+2 MIN
+1EV
+25 MIN
+L MIN
+I MIN
+UNLIMITED N/WKND MIN
+UNLIMITED N/KND MIN
+MESSAGE RETRIEVAL
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND MIN
+MESSAGE
+RETRIEVAL
+UNLIMIT
+ED
+M
+KND MIN
+INCLUDED
+UNLIM MOBI
+TO TO BL
+PEACE
+EVAL
+Mil
+1 MIN
+L MIN
+1 MIN
+IMIN
+MI
+MI
+1 MIN
+L MIN
+1 EM
+1 MIN
+NCLI
+UTES
+NCLUDED
+MINUTES
+UNLIM MOBL TO
+UNLIM MOBL TO MOBL
+INCLUBEB MINUTES
+EARLY EVENING N/WKND
+REVALND
+EARLY EVENING N/WKND
+EARLY EVENING NWKN
+COMING
+EW YORK N
+COM
+COMIN
+UK
+mobile UK
+NCOMING
+NCOMING
+EMIN
+1EVT
+MESSAGE RETRIEVAL
+3MIN
+1 MIN
+INCLUBED MINUTES
+2 MIN
+SMIN
+IEVT
+UNLIM MOBLI
+MESSAGE RETRIEVAL
+LENT
+CAL PER NUTES
+WAITING
+ICLUDED MINUTE
+iMIr
+UNLIM MOBL
+5 MOB
+1EVT
+MESSAGE RETRIEVAL
+L MIN
+› MIN
+3MIN
+INCLUBEB MI
+1 MIN
+5 MIN
+INCLUBED MINUTES
+1 MIN
+LMIN
+).06 ENH DISC INT DL
+EMIN
+NCLUDED MINUTES
+4MIN
+0.25 ENH DISC INT DL
+1MIN
+4MIN
+INCLUBED MINUTES
+_ MIN
+VCLUDED MINUTE!
+CLUDED MINUTE
+1 MIN
+UNLIM MOBL TO MOBL
+
+0.06
+1.00
+
+
+VOICE USAGE FOR
+Number
+Item Date Time
+Called
+755 10/25 12:42P
+10/25 12:59
+758 10/25 01:04P
+59 10/25
+01:06P
+60 10/25 02:359
+761 10/25 03:07P
+165 10/23 05:43F
+15:48P
+764 10/25 06:02P
+765 10/25 06:03P
+766 10/25 07:19P
+767 10/25 07:56P
+768 10/25 08:13P
+769 10/25 08:15P
+770 10/25 08:16P
+10/25
+1/25
+08:19P
+08:20F
+773 10/25 09:16P
+774 10/25 09:29P
+775 10/25 09:29P
+776 10/25 10:01P
+777 10/26 07:47A
+778
+780 10/26 08:48A
+781 10/26 08:48A
+782 10/26 08:49A
+783 10/26 08:50A
+78 18/28 09:54A
+786 10/26 09:05A
+787 10/26 09:23A
+10/26
+35
+585
+10/26
+
+:30A
+:38A
+
+/26
+10:54A
+12:06P
+12:08P
+12:12P
+7:34P
+2:46P
+10/26
+10
+02:00P
+2:02P
+
+IEW YORK NY
+IEW YORK NY
+NCOMING
+NCOMING
+NEWYORKZN1 NY
+MIAMI FL
+NEWYORKZN1 NY
+NCOMING
+mobile UK
+OUEENS NY
+YORK NY
+NCOMING
+- Continued
+Onty
+Used
+Rate Description
+1EVT
+MESSAGE RETRIEVAL
+1 MIN
+1MIN
+2 MI
+NCLUDED
+2MIN
+INCLUDED
+MINUTES
+NCLUDE
+IMI
+NCLUDE
+MI
+N
+1MIN
+IMIN
+1 MIN
+INCLUDED MINU
+2MIN
+2MIN
+1EVT
+I MI
+LEV
+1 MIN
+1EV
+2MIN
+EVENING
+GE RETR
+lEVAI
+EVENING
+N/WKND
+GE RETA
+IEVAL.
+2MIN
+3 MIN
+1MIN
+N/WKND
+IEVT
+6 MIN
+13 MIN
+QUEENS NY
+NEW
+ORK NY
+MIAMI FL
+NCOMING
+NEWYORK7N1 MY
+COMING
+COMING
+YORK NY
+NEW
+ORK NY
+NEW
+YORK NY
+NCOMING
+32 MIN
+3MIN
+1 MIN
+1 MIN
+1MIN
+1MIN
+1EV
+1 MIN
+TENT
+1 MIN
+1 MIN
+3 MIN
+1 MIN
+1 MIN
+1 MIN
+IEVT
+CL
+UNLIM
+MESSI
+UNLIM
+INCLU
+INCLU
+NCLU
+NCLU
+INCLU
+NCLU
+INCLU
+INCLU
+INCLU
+Account Name
+VOICE USAGE FOR
+Number
+Called
+Item Date Time
+810 10/26 04:40P
+811 10/26 05:12P
+813 10/26 05 37P
+814 10/26 07:22P
+B15 10/26 08:276
+16 10/26 09:33P
+817 10/26 09:38P
+18 10/26 09:49
+19 10/26 10:011
+0 10 20 10:02
+21 10/26 10:03
+822 10/26 10:05P
+823 10/26 10:05P
+824 10/26 10:07P
+825 10/27 09:00A
+ś89999959
+GOONSONGS
+
+83
+10/27
+10:36A
+- Continued
+Onty
+Toll Free CL
+Used Rate Description
+3 MIN
+1MIN
+MIT
+UNLIM MOBL TO MO
+TOBL TÕ MOBL
+Toll Free CL
+1 MIN
+EARLY EVENING N/WKND
+ROOKLYN N
+LMIN
+ARLY EVENING
+N/WKND
+MPTNGRDND (
+2 MIN
+UNLIMITED NAWKND MIN
+NEWYORKZNI NY
+1 MIN
+UNLIMITED NAKND MIN
+NEW YOR NO
+JEW YORK N
+1EVT
+MESSAGE RETRIEVAL
+L MIN
+IY ZONE 1 N'
+3 MIN
+L MIN
+EVT
+1 MIN
+IY ZONE 1 NY
+11 MIN
+UNLIMITED NAKND MIN
+ALL WAITING
+UNLIMITED NAKND MIN
+UNLIMITED N/WKND MIN
+JEW YORK NY
+1MIN
+NY
+NY
+MING
+YORK NY
+Toll Free CL
+JEW YORK N
+YORK NY
+CHNSTDSTCR VI
+5MIN
+1MIN
+1 MIN
+AMIN
+2 MIN
+3 MIN
+> MIN
+2MIN
+2 MIN
+2 MIN
+IMIN
+3 MIN
+2 MIN
+5 MIN
+4 MIN
+4 MIN
+2 MIN
+IMIN
+1 MIN
+IMIN
+1 MIN
+4 MIN
+2 MIN
+INCLUDED
+UNI
+MESSAG
+
+2000189.000001354
+UNLIM
+BL
+) MOR
+NELUBEB
+MINUTES
+MINUTES
+
+
+* cingular
+VOICE USAGE FOR
+Number
+Item Date Time Called
+- Continued
+Onty
+Used Rate Description
+LEVT
+CALL WAITING
+1 MIN
+UNLIM MOBL TO MOBL
+868 10/27 06:15P
+869 10/27 06:21P
+870 10/27 06:25P
+872 107 88538
+873 10/27 06:53P
+374 10/27 06:55F
+375 10/27 07:20F
+876 10/27 07:22P
+878 10/27 8746P
+879 10/27 07:57P
+380 10/27 0258P
+882 10/2B 12:22A
+883 10/28 10:06A
+.0/2B 10:19.
+0/7R 10-
+00-
+10/28 02.00₽
+888
+889
+10/2B 03:53P
+10/28 09:35P
+890
+10/29 01:37P
+891
+10/29 05:19P
+907
+10/29 09:20P
+10:02P
+
+88
+10
+LO
+30
+BERNARA ®
+QUEENS NY
+QUEENS NY
+JEW YORK NY
+VY ZONE I NY
+NCOMING
+'OMING
+NEW
+YORK NY
+OMING
+>
+NEV
+NFU
+ORK N
+3 MIN
+EMIN
+1 MIN
+EMIN
+1 MIN
+UNLIM MOBL TO MOBL
+VLIM MOBL TO MOB
+CLUDED MINUTE
+UNLIM MOBL TO MOBL
+MCLUDED MINUTES
+EARLY EVENING N/WKND
+1 MIN
+2 MIN
+1 MIN
+3 MIL
+2 MIN
+1 MIN
+LENT
+1EV
+SMIN
+1 MIN
+2 MI
+1 MIN
+EARLY EVENING NAWAB
+EARLY EVENING N/WKND
+EARLY EVENING N/WKNO
+1 MIN
+EVT
+1EVT
+1 MIN
+EMIN
+UNL
+Account Name
+VOICE USAGE FOR
+Number
+Item Date Time Called
+923 10/30 02:40P
+924 10/30 02:42P
+925 10/30 02:47P
+926 10/30 03:24P
+27 10/30 03:25P
+928 10/30 03:25P
+929 10/30 03:28P
+30 10/30 03:44R
+31 10/30 03:491
+932 10/30 03:49P
+830 10000
+935 10/30 05:35P
+36 10/30 05:38F
+937 10/30 05:41F
+EW YORK N
+EW YORK N
+NY ZONE 1 NY
+VEW YORK N°
+JEW YORK NY
+- Continued
+Onty
+Used Rate Description
+2 MIN
+UNLIMITED N/WKND MIN
+3 MIN
+UNLIMITED N/KND MIN
+HEN
+UNSATED NTED MIN
+1 MIN
+UNLIMITED N/WKND MIN
+MIl
+INLIMITED NAWKND MIL
+3MIN
+UNLIMITED N/WKND MIN
+1 MIN
+4 MIN
+UNLIMITED NWKND MIN
+DNWKND MIN
+1EVT
+MESSAGE RETRIEVAL
+MIl
+NUIMITED NWKND MI
+ALL WAIT
+UNLIMITED N/WKND MIN
+MI
+UNLIMITED NKND MIN
+3MIN
+UNLIMITED N/WKND MIN
+LENN 150 UNLIMITE
+UNLIMITED N/KND MIN
+2 MIN
+UNLIMITED N/WKND MIN
+
+
+2000189.000001354
+98999
+920
+98
+12:
+:40P
+NEW
+NEW
+NEV
+NE
+NE
+W
+YORK NY
+SS
+YORK
+YORK
+NY
+NY
+UN
+ECAR
+888
+965
+11/01
+09:28A
+967
+01:42P
+968
+11/01
+01:49P
+AAA
+888
+972 11/01
+02:39P
+29
+YORK NY
+ZONE 1 NY
+NCOMING
+NWYRCYZN01 NY
+NEW
+YORK NY
+NEW TO
+MARION OH
+mobile UK
+1EVT
+6MIN
+2 MIN
+2 MIN
+1 MIN
+1 MIN
+2 MIN
+2 MIN
+2 MIN
+i MIN
+IMIN
+8MIN
+1 MIN
+2 MIN
+1 MIN
+1 MIN
+5 MIN
+1MIN
+IMIN
+1 MIN
+A MIN
+1 MIN
+UNLIMIT
+NWKND
+UNLIMIT
+UNLIMITEB
+NAWN MIN
+UNLIMITED
+INCLUDED
+UNLIM MO
+INCLUDED
+INCLUDED MINUT
+INCLUBED MINUT
+INCLUDED
+MI
+MI
+INLIM MOBI
+ешшшшшш?
+NELUDED NOTESY
+MINUTES
+ICLUDED MINUTE
+ARIY EVENIN
+N/WKND
+UNLIM MOBL TO MOBL
+NEEDED MINES
+2 MIN
+UNLIM MOBL TO MOBL
+LIM MOBL IO MU
+SSAGE RETRIEV
+SMIN O.25 ENH DISC NUDIES
+1 MIN
+EV
+UNLIM MOBL TO MOBL
+lESSAGE RETRIEVA
+INLIM MOBL TO MOB
+IEVT
+MESSAGE RETRIEVAL
+MESSAGE RETRIEVAL
+2 MIN
+2 MIL
+NCLUDED MINUTES
+• MIF
+UNLIM MOBL TO MOBL
+1EVT
+MESSAGE RETRIEVAL
+1MIN
+TEVT
+2 MIN
+2 MIN
+2 MIN
+CLUDED MINUTE
+CLUDED MINUTE
+0.25 ENH DISC INT DL
+1.25
+0.50
+
+
+VOICE USAGE FOR
+Number
+Called
+Item Date Time
+975 11/01 04:23P
+976 11/01 04:26P
+77 11/01 04:419
+78 1101
+05:19P
+979 11/01 06:55P
+07:01P
+981 11/01 87:05P
+982 11/01 07:08P
+9831
+11:01
+09:17P
+984 11/01 09:26P
+985 11/02 07:40A
+986 11/02 07:52A
+9B7 11/02 08:55A
+988 11/02 09:13A
+989 11/02 09:51A
+99111/02
+1:00A
+1:264
+992 11/02 11:27A
+994 11/02
+994฿
+11:28A
+:30A
+995
+096
+11/02 1:31A
+
+ggg 11/02 12:18P
+1000 11/02 12:18P
+1001 11/02 12:19P
+1002 11/02 12:20P
+1003 11/02 12:20P
+1004 11/02 12:20P
+1005 11/02 12:22P
+1007
+1008
+1009
+02:20P
+1010
+1012
+10
+:26P
+L44P
+02:45P
+: 02:48P
+: 02:52P
+02:53P
+•5SP
+JESSES:
+12P
+03:28P
+W ANGELES CA
+NCOMING
+NEWYORKZNI NY
+YORK NY
+- Continued
+Qnty
+Used
+Rate Description
+1MIN
+UNLIM MOBL TO MOBL
+3MIN
+UNLIM MOBL TO MOBL
+3MIN
+1 MIN
+1 MIN
+IMIN
+2M|N
+2 MIN
+1MIN
+1 MIN
+2 MIN
+2MIN
+1MIN
+EARLY EVENING AND
+CARLY EVENING NAWKND
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND MIN
+UNLIM MOBL TO MOBL
+MESSAGE RETRIEVAL
+JNLIM MOBL TO MOBL
+UNLIM MOBL TO MOBL
+NEW
+NCOMING
+ROCKVILLE MD
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+YORK
+QUEENS NY
+DUEENS
+i NY
+CAMBRIDGE MA
+QUEENS NY
+2011
+2MIN
+MI
+MI
+IEVT
+1 MIN
+1 MIN
+IEVT
+IMIN
+EVT
+I MIN
+I MIN
+1EVT
+1EVT
+1 MIN
+1 MIN
+1MIN
+1 MIN
+2 MIN
+3MIN
+1 MIN
+2 MIN
+EMIN
+4 MIN
+1 MIN
+2 MIN
+1 MIN
+1 MIN
+IMIN
+1 MIN
+IMIN
+2 MIN
+2MIN
+1 MIN
+2 MIN
+CLUDED MINUTE
+CLUDED MINUTE
+CLUDED MINUTE
+MESSAGE RETRIEVAL
+NCLUDED MINUTES
+INLIM MORI
+O MOBL
+MESSAGE RETRIEVAL
+TO MOBL
+UNLIM MOBL TO MOBL
+MESS NORETO MOBL
+RETOMOBL
+MESSAGE RETRIEVAL
+ILIM MOBL TO MO
+CCAGE RETRIEV
+UNLIM MOBL TO MOBL
+MEENAMORETO MOBL
+MESSAGE RETRIEVAL
+INCLUBED MINUTES
+UNLIM MOBL TO MOBL
+NADED MINUTES
+MINUTE
+NCLUDED MINUTES
+INLIM MOBL TO MOBI
+NCLUDED MINUTE!
+ALL WAITING
+UNLIM MOBL TO MOBL
+ICLUDED MINUTE
+CLUDED MINUTE
+INLIM MOBLTO MOB
+INLIM MORI TO MOR
+UNLIM MOBL TO MOBL
+UNLIM MOBLTO MOBL
+UNLIM MOBL TO MOBL
+UNLIM MOBL TO MOBL
+Account Name
+VOICE USAGE FOR
+Number
+Item Date Time
+Called
+1030 11/02 03:59P
+1031 11/02 04:00P
+1032 11/02 04:01P
+1033 11/02 04:20P
+134 11/02 04:21
+135 11/02 04•23
+1036 11/02 04:25P
+1037 11/02 04:46P
+1039 11/02 09.15P
+1040 11/02 09:17P
+041 11/02 09:18
+142 11/02 11:19
+TOTAL VOICE USAGE FOR
+Toll Free CL
+BROOKLYN NY
+- Continued
+Onty
+Used Rate Description
+2 MIN
+CLUDED MINUTE
+1 MIN
+INLIM MOBL TO MOB
+1 MIN
+NCOMING
+NCO MING
+1 MIN
+IEVT
+1 MIN
+EMIN
+1MIN
+2MIN
+NCLUDED MINUTEC
+LUDED MINUTI
+LUDED MINUT
+NCLUDED MINUTES
+1.50 411
+INFO
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND MIN
+JNLIMITED N/WKND MIN
+ROAMER USAGE FOR
+Number
+Item Date Time
+Called
+LULU 12.9.
+0 12.47
+3 10/18 03:41P
+TOTAL ROAMER USAGE FOR
+WHILE IN BR VIRIGIN I---
+Onty Used Description
+1 MIN
+T'L ROAMING VOIC
+T'L ROAMING VOIC
+2 MIN
+INT'L ROAMING VOICE
+WHILE IN BR VIRIGIN I -
+DATA USAGE FOR
+Item Date
+Onty Used
+O/D
+120 KL
+16 KE
+344 KB
+3 10/22
+TOTAL DATA USAGE FOR I
+Charge Description
+CLUDED IN PLAN M
+CLUDED IN PLAN M
+INCLUDED IN PLAN MB
+TEXT/MULTIMEDIA MSGS FOR
+Item Date
+Time
+Sent To/Revd From
+1 10/01
+09:43P
+3 10/02
+09:58A
+09:59A
+$ 10/02
+10.084
+10/02
+10:36A
+10002
+10:59A
+11:48A
+05:36P
+00 350
+10/02
+. 0/0.
+06:53P
+07:53F
+19•368
+10
+10/02
+102
+19:431
+10.531
+09:57P
+09:57P
+02:35P
+02:49P
+550
+83:164
+104
+10/04
+04:40P
+04:40P
+Charge Description
+100 INCL. MSGS SENT
+100 ELMS SENT
+100 IN CL: M583 SENT
+100 INCL. MSGS SENT
+100 IN EL: MEGS SENT
+100 INCL. MSGS SENT
+100 INEL: M383 SENI
+.. MSGS SENT
+100 INCL. MSGS SENT
+100 INEL: ME8
+_MSGS
+LAU
+SENT
+ENT
+100 INCL. MSGS
+00 INCL. MS
+SENT
+00 INCL. M
+SENT
+100 INCL. MSGS
+SENT
+100 INCL. MSGS
+SENT
+
+17.20
+3.49
+6.98
+13.96
+0.00
+
+
+Account Name
+
+
+TEXT/MULTIMEDIA MSGS FOR
+- Continued
+Item Date
+Time
+Sent To/Rovd From
+25 10/05
+10/05
+05:48P
+Charge Description
+100 INCL. MSGS SENT
+87:03F
+100 INCL. MSGS SENT
+: 10/05
+07:18P
+100 INCL. MSGS SENT
+02:00P
+100 INCL: MESS SENT
+
+69281
+1812
+10/12
+10:38P
+100฿
+02:51P
+100
+INEL: MESS SENT
+100 INCL. MSGS SENT
+10:13P
+06:50A
+100 INEL:
+MSGS SENT
+MSGS SENT
+06:57P
+09:58A
+100 INCL
+MSGS SENT
+NTL ROAMTEXT M50
+10:01A
+100 INCL
+ASGS SENT
+100 INCL. MSGS SENT
+1:37A
+7:39A
+100 INCE:
+MSGS
+09:06A
+100
+INCL
+MSG
+S8888888888888899AA88088888888886888858888888888
+s888888888888
+22
+22222
+
+000000000000000LI
+0.50
+TEXT/MULTIMEDIA MSGS FOR
+Continued
+Item Date
+Time
+92 10/21
+09:01P
+Sent To/Revd From
+Charge Description
+100 INCL. MSGS SENT
+09:278
+9510/21
+10:39P
+39 1022
+D:47
+2910/22
+14:20P
+100 10/22
+06:59P
+07:32₽
+07:58P
+103 10/22
+103 10/22
+106 10/23
+108 1023
+110 10/23
+10:22P
+12:05A
+13034
+83:038
+100 INCL. MSGS SENT
+IT TERMS SENT
+NOTES SENT
+100 INCL. MSGS SENT
+100 INEL: MS8 SENT
+100 INCL. MSGS SENT
+TEXT MESSAGES SENT
+IEXT MESSAGES SENT
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+835
+0.10
+8:18
+8:18
+000000000000000 00
+
+
+TEXT/MULTIMEDIA MSGS FOR
+Item Date
+Time
+Sent To/Revd From
+159 11/01
+07:02P
+60 11/0
+07:08P
+61 110
+07:08P
+162 11/01
+07:11P
+163 11/01
+19:30P
+164 11/02
+17:50A
+165 11/02
+02:33P
+66 11/0.
+67 11/0.
+168 11/02
+07:18P
+169 11/02
+09:03P
+170 11/03
+09:07P
+171 11/02
+09:26P
+TOTAL TEXT/MULTIMEDIA MSG USAGE FOR
+- Continued
+Charge Description
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+TEXI
+MESSAG
+TEYT
+MESSAG
+BENE
+TEXT
+MESSAG
+SENT
+TEXT MESSAG
+TEXT
+MESSAG
+SENT
+TEXT
+:SSAU
+ESS
+SENT
+SENT
+TEXT
+MESSAG
+SENT
+TEXT
+MESSAGE
+• SENT
+SUMMARY OF CURRENT ACTIVITY
+FOR
+Monthly Service Charges
+Item Description
+Service Dates
+1 CALL WAITING
+10/03/05 - 11/02/05
+2 TEXT MESSAGING PLAN - 0 MSGS
+10/03/05 • 11/02/05
+3 CALLER ID
+10/03/05 - 11/02/05
+4 VOICE MAIL
+10/03/05 - 11/02/05
+5 GSM AMERICA LOCAL $29.99
+10/03/05 - 11/02/05
+6 DOMESTIC LONG DISTANCE FRM SERVICE AREA
+10/03/05 - 11/02/05
+7 CALL FORWARDING
+10/03/05 • 11/02/05
+8 WORLDCONNECT
+10/03/05 - 11/02/05
+9 REGULATORY PROGRAM CHARGE
+10/03/05 • 11/02/05
+10 DETAIL BILLING
+10/03/05 • 11/02/05
+Total Monthly Service Charges
+Other Subscriber Charges
+Item Description
+1 MCTD SURCHARGE
+2 NY CITY UTILITY G.R. SUR
+3 STATE TELECOM EXCISE TAX
+4 FEDERAL UNIVERSAL SERVICE FUND SURCHARGE
+Total Other Subscriber Charges
+Subscriber Government Fees and Taxes
+Item Description
+1 SALES TAX
+2 ST WIRELESS COMM SURCHARGE
+3 FEDERAL EXCISE TAX
+0.10
+0.10
+0.10
+0.10
+0.10
+0.10
+8:18
+0.10
+0.10
+0.10
+010
+7.95
+0.00
+0.00
+0.00
+0.00
+29.99
+0.00
+0.00
+0.00
+1.75
+0.00
+31.74
+0.19
+0.62
+0.84
+0.82
+2.52
+change
+1.04
+Account Name
+
+SUMMARY OF CURRENT ACTIVITY - CONTINUED
+Subscriber Government Fees and Taxes - Continued|
+Item Description
+4 LOCAL WIRELESS SURCHARGE
+Total Subscriber Government Fees and Taxes
+TOTAL CURRENT CHARGES FOR I
+0.30
+5.41
+39.67
+2000189.000001356
+
+
+• *cingular
+ng the
+ccount Nam
+EFFREY E EPSTEI
+
+***THIS SPACE INTENTIONALLY LEFT BLANK ***
+***THIS SPACE INTENTIONALLY LEFT BLANK ***
+2000189.000001356
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/0a2cfdc1dc9bdcbfb541053d516b25b0f6619bfc03820e458a39198a6ae8976e.receipt.json b/vision-fixhub/ds9-unparsed-06/0a2cfdc1dc9bdcbfb541053d516b25b0f6619bfc03820e458a39198a6ae8976e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7b4e0f8ca80d4a23e75cc520499c21e1fa88ecc6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0a2cfdc1dc9bdcbfb541053d516b25b0f6619bfc03820e458a39198a6ae8976e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -7432,
+  "dataset": "marble-joined",
+  "doc_id": "0a2cfdc1dc9bdcbfb541053d516b25b0f6619bfc03820e458a39198a6ae8976e",
+  "engine": "marble-apple-vision",
+  "event_count": 61,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "a6763f3c35f47ebab7cb37ceda32bbd9d2b40344dc429d85250cfb1e74571703",
+  "output_sha256": "17f5ba8993bd7ba93225f67e544abef1eb66a6d9b7d8f7292f07c3a2d8b5ad95",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0a56c5d043fe41f0829dd579e38eaf8fafeaa1666f4fbf270b99bca466a01111.md b/vision-fixhub/ds9-unparsed-06/0a56c5d043fe41f0829dd579e38eaf8fafeaa1666f4fbf270b99bca466a01111.md
new file mode 100644
index 0000000000000000000000000000000000000000..fde39eccc17f507fe3ed57db579ad86f677ad799
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0a56c5d043fe41f0829dd579e38eaf8fafeaa1666f4fbf270b99bca466a01111.md
@@ -0,0 +1,59 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80119-KAM Doe |. Epstein Order on Motion for Protective Order
+Date: Wed, 03 Mar 2010 23:06:11 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 3/3/2010 at 6:06 PM EST and filed on 3/3/2010
+Case Name:
+Doe | Epstein
+Case Number:
+9:08-cv-80119-KAM
+Filer:
+Document Number: 479
+Docket Text:
+ORDER Granting nunc pro tunc [475] Motion for Protective Order. Signed by Magistrate Judge
+Linnea R. Johnson on 3/3/2010. (sa)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+ahorowitz@sexabuseattorney.com
+Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov
+Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com
+Isidro Manuel Garcia
+isidrogarcial@bellsouth.net
+Jack Alan Goldberger jagesq@bellsouth.net, nalanis@agwpa.com
+Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com,
+sas@searcylaw.com, vat(@searcylaw.com
+Jeffrey Marc Herman jherman@hermanlaw.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+Michael James Pike MPike@bclclaw.com, bobbie@bclclaw.com, jcadwell@bclclaw.com
+
+
+Paul G. Cassell cassellp@law.utah.edu
+Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com
+Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton@podhurst.com,
+mestrada@podhurst.com
+Robert Deweese Critton, Jr rerit@belclaw.com, bobbie@bclelaw.com
+Stuart S. Mermelstein ssm@sexabuseattorney.com, jarbour@sexabuseattorney.com,
+Irivera(@sexabuseattorney.com
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+Martin G. Weinberg
+20 Park Plaza
+Boston, MA 02116
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=3/3/2010] [FileNumber=7321375-0]
+[62800771d861d07026ee5a7fcfad28d639354бас94c730ab6b8e8b72286f9ба830a9
+af9b6d72bа299cd2d7db31f06ee5a2d2164e0163010130625f15137b5c00]]
diff --git a/vision-fixhub/ds9-unparsed-06/0a56c5d043fe41f0829dd579e38eaf8fafeaa1666f4fbf270b99bca466a01111.receipt.json b/vision-fixhub/ds9-unparsed-06/0a56c5d043fe41f0829dd579e38eaf8fafeaa1666f4fbf270b99bca466a01111.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..495b8d88591a2a64886bb5794801f344baa15d7a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0a56c5d043fe41f0829dd579e38eaf8fafeaa1666f4fbf270b99bca466a01111.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "0a56c5d043fe41f0829dd579e38eaf8fafeaa1666f4fbf270b99bca466a01111",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "5ffc33cac198e8e6c897f06cd29088b2d34dd5f8da8ba697fec3c6f486a510d0",
+  "output_sha256": "219ad326802a7e1c6381028b1ce8aa1604520922461878494dedd693b33ba1c4",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0b1d35373b2ea3f69598110e29a7806fe8d12de2cf3a04f8b669f1d2c90e1530.md b/vision-fixhub/ds9-unparsed-06/0b1d35373b2ea3f69598110e29a7806fe8d12de2cf3a04f8b669f1d2c90e1530.md
new file mode 100644
index 0000000000000000000000000000000000000000..913f2ff3e871fa03baefd9e4ea36bfe84cbb6518
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0b1d35373b2ea3f69598110e29a7806fe8d12de2cf3a04f8b669f1d2c90e1530.md
@@ -0,0 +1,259 @@
+Case 9:08-cv-80893-KAM Document 214
+Entered on FLSD Docket 09/02/2010 Page 1 of 10
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+FT. LAUDERDALE DIVISION
+JANE DOE,
+Plaintiff,
+V.
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT, JEFFREY EPSTEIN'S
+MOTION FOR PROTECTIVE
+ORDER AND OBJECTION TO
+DISCLOSURE OF CERTAIN
+DOCUMENTS WITH INTEGRATED
+MEMORANDUM OF LAW
+Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant
+to a Joint Stipulation Regarding Certain Documentation files this his Motion for Protective Order
+and Objection to Disclosure of Certain Correspondence and Discovery for the reasons set forth
+below:
+I. PRELIMINARY STATEMENT
+During the underlying litigation, Epstein vigorously sought protection from the Court that
+these and other documents produced would be used for purposes other than those contemplated by
+the Federal Rules of Civil Procedure for discovery; i.e., dissemination in the media. His rights to
+contest this type of use were preserved as part of the settlement of these proceedings, which provided
+for confidentiality of the settlement as well as provisions to bring these matters to a close. Now, the
+fears that led to Epstein's efforts to seek protection from the court have now come to pass. The
+intended use of these documents is now leading to more litigation that the settlement of these cases
+was designed to end. Epstein requests that the court grant protection so that this does not occur.
+FOWLER WHITE BURNETT, P.A. • PHILLIPS POINT - WEST TOWER, SUITE 901, 777 SOUTH FLAGLER DRIVE, WEST PALM BRACH, FLORIDA 33401 - (561) 802-9044
+
+
+Case 9:08-cv-80893-KAM Document 214 Entered on FLSD Docket 09/02/2010 Page 2 of 10
+Epstein's MPO, Objections and Integrated Memo of Law et al.
+II.
+STATEMENT OF PROCEEDINGS
+1.
+In July 2010, the Defendant, pursuant to certain discovery orders (D.E. 462 and 572)
+entered by this court produced
+correspondence and documentation between Epstein's
+attorneys/agents and federal prosecutors ("Correspondence").
+2.
+Shortly thereafter, the parties entered into settlement agreements in the above-styled
+matter and in matters of L.M. v. Epstein, Case No. 502008 CA028051 XXXXMB AB in the
+Fifteenth Judicial Circuit in and for Palm Beach County and in E.W. vs. Epstein, Case No. 502008
+CA028058 XXXXMB AB, filed in the Fifteenth Judicial Circuit in and for Palm Beach County,
+Florida.
+The parties entered into a Joint Stipulation, a copy of which is attached hereto as Exhibit
+"I" to govern the use of public disclosure of discovery of the Correspondence. The Court reserved
+jurisdiction to enforce the Stipulation.
+4.
+On August 26, 2010, counsel for the Plaintiff served notice of its intent to use the
+Correspondence in two court proceedings, an internal Justice Department Complaint procedure, and
+other, essentially public matters. It is also anticipated that the documents will be released to the
+media. A copy of the Notice of Intent to Use is attached hereto as Exhibit "2".
+The Joint Stipulation provides that if Epstein chooses to serve an objection, the
+Correspondence will remain confidential until the court has had an adequate opportunity to review
+the materials and enter a ruling.
+-2-
+FOWLER WHITe: BURNETT, P.A. • PHILIPS POINT - WesT TowaR, SUIts 901, 777 SOUTH FLAOLER DRIVE, WEST PALM BEACH, FLORIDA 33401 - (561) 802-9044
+
+
+Case 9:08-cv-80893-KAM Document 214 Entered on FLSD Docket 09/02/2010 Page 3 of 10
+Epstein's MPO, Objections and Integrated Memo of Law et al.
+6. On August 30, 2010, the undersigned's firm requested counsel for the Plaintiff to
+identify the documents they intend to use so that Epstein would be in a position to prepare an
+appropriate response, which was rejected. The undersigned's law firm understands that the
+correspondence in question is in excess of 100 documents. In general, the documents consist of
+communications between Mr. Epstein's defense counsel and the United States Attorney's Office
+regarding the investigation, negotiation and settlement of potential criminal charges against Mr.
+Epstein.
+III. DESCRIPTION OF INTENDED USE
+Epstein respectfully submits that a brief description of the proceedings that counsel for the
+Plaintiff has stated that they intend to use the Correspondence will be helpful to the court:
+A.
+Epstein v. Edwards, Case No. 502009 CA040800XXXXMB AG
+The Plaintiff Epstein commenced an action on December 7, 2009 seeking damages
+against Defendants, Scott Rothstein, Bradley J. Edwards, and LM,' based on an alleged illegal Ponzi
+scheme by the Defendants, and the Plaintiff believes others as well, to market investments to outside
+investors in lawsuits brought against Epstein by a number of Plaintiffs, represented by the now
+defunct Law Firm of Rothstein, Rosenfeldt & Adler, P.A. ("RRA"). Some of the lawsuits were
+transferred to a newly formed firm of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL
+("Farmer Jaffe"). Epstein has alleged and believes that the Defendants and perhaps other former
+employees of RRA conspired to use the Epstein/LM litigation before this court and perhaps other
+' The claim against LM was dismissed pursuant to a settlement agreement.
+-3-
+FOWLER WHITE BURNETT, P.A. • PHILLIPS POINT - WEST TOWER, SUITE 901, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 - (561) 802-9044
+
+
+Case 9:08-cv-80893-KAM Document 214 Entered on FLSD Docket 09/02/2010 Page 4 of 10
+Epstein's MPO, Objections and Integrated Memo of Law et al.
+litigation to lure investors in to making approximately $13 million dollars worth of investments into
+phoney settlements by using pending real cases.
+Counsel for those investors, William Scherer, whose is also a member of the Creditor's
+Committee in the RRA bankruptcy, represented to the bankruptcy court that a number of his clients
+and their lawyer went into the RRA conference room and were allowed to go through the LM case
+file boxes, approximately 10 of them, and concluded that the Epstein case was a real case and
+ultimately invested money. A copy of the transcript of this hearing is attached hereto as Exhibit "3".
+Mr. Scherer's remarks appear on pages 17-22.?
+On August 13, 2010, Bankruptcy Judge Raymond Ray ordered in response to a subpoena
+from Epstein the appointment of a special master to review in excess of 6,000 electronically stored
+documents of RRA that relate to Epstein and other litigation to prepare a privilege log in
+anticipation of production of relevant non-privileged documents. A copy of that Order is attached
+hereto as Exhibit "4".
+B. In Re: Jane Doe, Case No. 08-80736-Marra/Johnson
+In 2008, Jane Doe filed an action under the Crime Victims Rights Act ("CVRA"), 18
+U.S. Code § 3771 on behalf of two alleged victims of the alleged sexual assault by Epstein. Since
+2008 there has been little if any activity on that file. The articulated purpose of the use of these
+documents is in an effort to set aside the "Non Prosecution Agreement" which Epstein entered into
+It is difficult to believe that if what Mr. Scherer has stated is true, that Mr. Edwards was
+not aware that his case files were being shown to outside investors.
+-4-
+FOWLER WITH BURNETT, P.A. • PHILLIPS POINT - WEST TOWER, SUITE 901, 777 SOUTH FLAGLE DRIVE, WIST PALM BRACH, FLORIDA 33401 - (561) 802-9044
+
+
+Case 9:08-cv-80893-KAM Document 214 Entered on FLSD Docket 09/02/2010 Page 5 of 10
+Epstein's MPO, Objections and Integrated Memo of Law et al.
+with the federal government. Neither victim has met the requirements of 18 U.S. Code §
+3771(d)(5)(A-C), which requires the court to assert her rights before and during the proceeding and
+to petition the court of appeals for a writ of mandamus if such right is denied. (See: Docket Entries
+for Doe v. U.S., 9:08-80736-KAM). It is hard to believe that a case that has been languishing in
+excess of two years will be revived to invalidate an agreement that the U.S. Attorneys Office entered
+into with Epstein after the agreement has been fully performed.
+C. Justice Department Ombudsman and other uses
+The Code of Federal Regulations has set out the procedures to promote compliance with
+crime victims' rights. 28 C.F.R. § 45.10. In order to take advantage of this complaint process, the
+Code of Federal Regulations requires that complaints must be submitted within ninety (90) days of
+the victim's knowledge of a violation, but not more than one (I) year after the actual violation. 28
+C.F.R. § 45.10(c)(3).
+It is obvious from the inaction of these proceedings and earlier filed pleading that this
+time frame has expired. Therefore the articulated intended use of the documents in this complaint
+proceeding is suspect on its face, thus leaving the only other articulated purposes which essentially
+is to allow the documents to go into the public domain.
+IV. MEMORANDUM OF LAW
+The policies behind FRE 408, and 410 provide this court for basis of sustaining Epstein's
+objections to the production of these documents. The intended use contravenes a critical public
+policy of encouraging resolution of criminal prosecutions without trial. Defendants are considerably
+-5-
+FOWLER WHITE BURNETT, P.A. • PHILIPS POINT - WEsT TOWER, SUITE 901, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 » (561) 802-9044
+
+
+Case 9:08-cv-80893-KAM Document 214 Entered on FLSD Docket 09/02/2010 Page 6 of 10
+Epstein's MPO, Objections and Integrated Memo of Law et al.
+more likely to engage in full and frank discussions with the government if they do not fear that
+statements they or their counsel make to government prosecutors will be used against them to their
+detriment in other proceedings. More specifically, Rule 408 prohibits the use of any evidence
+offered to prove liability for, invalidity of, or the amount of any claim that was disputed. Rule 410
+makes inadmissible pleas, plea discussions and related statements. The exceptions under each of
+these rules do not apply.
+Evidence of statements made during plea negotiations are also not admissible under Florida
+Rules of Criminal Procedure 3.172(i). They are not admissible in any civil or criminal proceeding
+against the person who made the plea or offer or who conducted the negotiations. Similar provisions
+in Florida Evidence Code exist. Statements made as part of settlement negotiations are inadmissible.
+The exception under each of these rules also do not apply. See: §§ 90.408 and 90.410, Fla. Stat
+(1976).
+The Florida Rule, like its Federal Rule Counterpart, was adopted to promote plea bargaining
+by allowing a defendant to negotiate without waiving Fifth Amendment protection. The most
+significant factor in the rules of adoption was the need for free and open discussion between the
+prosecution and defense during attempts to reach a compromise United States v. Davis, 617 F. 2d
+677, 683 (DC Cir. 1979), cited in Nunes v State of Florida, 988 So. 2d 636 (Fla. 2d DCA 2008).
+It would obviously present a chilling effect on any settlement discussions if such discussions
+could later be used as admissions of liability at trial or in any other proceeding. Bank Card America,
+Inc. v. Universal Bank Card Systems, Inc., 203 F. 3d 477, 483 (7" Cir. 2000). One court in the
+-6-
+FOWLER WHITE BURNETT, P.A. • PHILLIPS POINT - WIST TowER, SUITE 901, 777 SOUTH FLAOLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044
+
+
+Case 9:08-cv-80893-KAM Document 214 Entered on FLSD Docket 09/02/2010 Page 7 of 10
+Epstein's MPO, Objections and Integrated Memo of Law et al.
+federal court system has held that communications falling within the parameters of Rule 408 are
+covered by settlement privilege which insulates them not just from admission into evidence but from
+discovery as well. Goodyear Tire & Rubber Company v. Chiles Power Supply, Inc., 332 F. 3d 976,
+979-983 (6th Cir. 2003). The court specifically stated:
+There exists a strong publie interest in favor of secrecy
+of matters discussed by parties during settlement
+negotiations.the ability to negotiate and settle a case
+without trial fosters a more efficient, more cost effective,
+and significantly less burden to the judicial system...parties
+must be able to abandon their adversarial tendencies to
+some degree. They must be able to make hypothetical
+concessions, offer creative quid pro quos, and generally
+make statements that would otherwise belie their litigation
+efforts. Goodyear Tire, Id. at 980.
+The same is no less true in the plea negotiation context particularly where a central
+component of the discussions and negotiations between counsel for Epstein and counsel for the
+United States Attorney was to reach an agreement on conditions relating to compensation for his
+alleged victims.
+The court ordered discovery of this Correspondence so the Plaintiff could determine if
+it contained any admissible information that would advance a stand-alone federal civil action.
+Instead, Epstein submits that the real use of this Correspondence will be to further counsel for the
+Plaintiffs legislative, political and philosophical mission to expand victim rights. This kind of
+extrinsic use of such discovery chills and compromises the presumptive confidentiality of written
+and often frank discussions between counsel. Epstein intended his communications with United
+States Attorney's Office to be private and protected by FRE 410. The communications from the U.S.
+-7-
+FOWLER WITE BURNETT, P.A. - PHILIPS POINT - WEST TOWER, SUITE 901, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 3340] » (561) 802-9044
+
+
+Case 9:08-cv-80893-KAM Document 214 Entered on FLSD Docket 09/02/2010 Page 8 of 10
+Epstein's MPO, Objections and Integrated Memo of Law et al.
+Attorney to Epstein's counsel reflect these discussions and were also intended to be private. Now,
+after the fact to allow it to be disseminated to victim's rights advocates to change legislation totally
+defeats the public policy consideration of encouraging the resolution of criminal prosecutions
+without trial.
+V. RELIEF REQUESTED
+Epstein requests that this Court grant the Motion for Protective Order by preventing disclosure
+and order Plaintiffs' counsel to return, without keeping copies, the Correspondence to counsel for
+Epstein.
+Alternatively, there are in excess of 100 documents of Correspondence; and as noted, counsel
+for Plaintiff has refused to agree to designate which they intend to use. Therefore, in the event this
+court is inclined to order the release of said correspondence, then Epstein requests an in-camera
+inspection of which documents Plaintiff intends to use to determine what, if any, documents are
+related to the foregoing pleas and what documents are not. Along the same lines, Epstein requests
+an in-camera inspection in an effort redact any information that may violate third party privacy rights
+or information that would implicate Epstein's Fifth Amendment rights and to further brief these
+issues.
+VI. LOCAL RULE 7.1 STATEMENT
+Pursuant to the above Rule, the undersigned counsel and Plaintiff's counsel have
+conferred and are unable to resolve this matter.
+-8-
+FOWLER WHErE BURNETT, P.A. • PHILLIPS POINT - WEST TowIR, SUITE 901, 777 SOUTH FLAGLER DRIVE, WIST PALM BEACH, FLORIDA 33401 • (561) 802-9044
+
+
+Case 9:08-cv-80893-KAM Document 214 Entered on FLSD Docket 09/02/2010 Page 9 of 10
+Epstein's MPO, Objections and Integrated Memo of Law et al.
+VII. CERTIFICATE OF SERVICE
+THEREBY CERTIFY that a true and correct copy of the foregoing was electronically
+filed with the Clerk of the Court using CM/ECE. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following service list in the manner
+specified via transmission of Notices of Electronic Filing generated by CM/ECF on this 2nd day of
+September, 2010.
+Brad Edwards, Esq.
+Farmer, Jaffe, Weissing, Edwards, Fistos
+& Lehrman, PL
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Amatralion Arranno South
+432 N Andean Amanua
+FOWLER WHITE BURNETT, P.A, + PHILLIPS POINT - WEST TowaR, SurrE 901, 777 SoUTH FLAGLeR DRIVE, WEST PALM BEAcH, FLORIDA 33401 + (561) 802-9044
+
+
+Case 9:08-cv-80893-KAM Document 214 Entered on FLSD Docket 09/02/2010 Page 10 of 10
+Epstein's MPO, Objections and Integrated Memo of Law et al.
+Paul G. Cassell, Esq.
+Pro Hac Vice
+33
+Respectfully submitted,
+Is/ Joseph L. Ackerman, Jr.
+seph L. Ackerman, J
+la. Bar No. 23595
+Lilly Ann Sanchez.
+Fla. Bar No. 195677
+FOWLER WHITE BURNETT P.A.
+901 Phillips Point Woot
+777 South Flaalor Dring
+Co-Counsel for Defendant Jeffrey Epstein
+[nat] W: 80743 MTNPRO07-Motion for Protection Order USDC Doe v lipsisin JLA(9/2/10-15:59)
+-10-
+FOWLER WITE BURNETT, P.A. • PHILLIPS POINT - WesT TOWER, SUITE 901, 777 SOUTH FLAGLER DRIVE, Wast PALM BRACH, FLORIDA 33401 - (561) 802-9044
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/0b1d35373b2ea3f69598110e29a7806fe8d12de2cf3a04f8b669f1d2c90e1530.receipt.json b/vision-fixhub/ds9-unparsed-06/0b1d35373b2ea3f69598110e29a7806fe8d12de2cf3a04f8b669f1d2c90e1530.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7099a4944409353ba59ffa7334b9b832be4a4fbf
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0b1d35373b2ea3f69598110e29a7806fe8d12de2cf3a04f8b669f1d2c90e1530.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -733,
+  "dataset": "marble-joined",
+  "doc_id": "0b1d35373b2ea3f69598110e29a7806fe8d12de2cf3a04f8b669f1d2c90e1530",
+  "engine": "marble-apple-vision",
+  "event_count": 11,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "7d1adc1dc213595d12176c32fd8b54546261a86473a5154155238d4949308c4e",
+  "output_sha256": "3076a965937e1aed577dac573817a623329112f81d23d9d80f195e331aab4a71",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0b97e84dd2d0e4ca68a07d7577f3359d4129b9ba443333df38ca976212b0e840.md b/vision-fixhub/ds9-unparsed-06/0b97e84dd2d0e4ca68a07d7577f3359d4129b9ba443333df38ca976212b0e840.md
new file mode 100644
index 0000000000000000000000000000000000000000..e04521c629cef48c970d7afff56cdc5e39193414
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0b97e84dd2d0e4ca68a07d7577f3359d4129b9ba443333df38ca976212b0e840.md
@@ -0,0 +1,11 @@
+From:
+To:
+Subject: Read:
+Date: Wed, 18 Apr 2012 17:02:40 +0000
+Importance: Normal
+US -- Notice of Supplemental Authority filed by Epstein, et al.
+Your message
+Subject: RE:
+I. US -- Notice of Supplemental Authority filed by Epstein, et al.
+Sent: Wednesday, April 18, 2012 11:51:53 AM (UTC-05:00) Eastern Time (US & Canada)
+was read on Wednesday, April 18, 2012 1:01:41 PM (UTC-05:00) Eastern Time (US & Canada).
diff --git a/vision-fixhub/ds9-unparsed-06/0b97e84dd2d0e4ca68a07d7577f3359d4129b9ba443333df38ca976212b0e840.receipt.json b/vision-fixhub/ds9-unparsed-06/0b97e84dd2d0e4ca68a07d7577f3359d4129b9ba443333df38ca976212b0e840.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..00fec9701da97d940cf88ad6aa719c725513ccdc
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0b97e84dd2d0e4ca68a07d7577f3359d4129b9ba443333df38ca976212b0e840.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "0b97e84dd2d0e4ca68a07d7577f3359d4129b9ba443333df38ca976212b0e840",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "c6edf76160e818caa6e690bf585a7baddd0a0dcdd93bb7401a7513d4d57bc07e",
+  "output_sha256": "3ff844d2e2fb0c034f20e55787d461794d47c3a85663d733e871591d597e2e99",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0ba0dabb429dcbb9100a039a471ed930a3a5771f6f82ae9f96b5ac25d7ce5a52.md b/vision-fixhub/ds9-unparsed-06/0ba0dabb429dcbb9100a039a471ed930a3a5771f6f82ae9f96b5ac25d7ce5a52.md
new file mode 100644
index 0000000000000000000000000000000000000000..ee67d0877d069986c1c0dd484e64c3895cbb317f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0ba0dabb429dcbb9100a039a471ed930a3a5771f6f82ae9f96b5ac25d7ce5a52.md
@@ -0,0 +1,8 @@
+Subject: Re: Epstein Meeting
+Date: Tue, 26 Jan 2010 18:38:15 +0000
+Importance: Normal
+10-4!
+Sent: Tue Jan 26 13:34:22 2010
+Subject: Epstein Meeting
+Is scheduled for Monday, February 1s at 1:00 in Miami. Can you check with Mike and see who, if anyone else,
+should go?
diff --git a/vision-fixhub/ds9-unparsed-06/0ba0dabb429dcbb9100a039a471ed930a3a5771f6f82ae9f96b5ac25d7ce5a52.receipt.json b/vision-fixhub/ds9-unparsed-06/0ba0dabb429dcbb9100a039a471ed930a3a5771f6f82ae9f96b5ac25d7ce5a52.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7c98c414f9ed3acc44c997dc7bb4b9706c374efe
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0ba0dabb429dcbb9100a039a471ed930a3a5771f6f82ae9f96b5ac25d7ce5a52.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "0ba0dabb429dcbb9100a039a471ed930a3a5771f6f82ae9f96b5ac25d7ce5a52",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "f62901cc04c7147c677101f4313fc0d766619b96313357f78d4efc48c2528e18",
+  "output_sha256": "f97a5ac7f4c5cd01dc15f5b334144390dda07757c9e12159b6d4cad834a9939b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0c3c12741443f1b63573e7132e78c1c15e789040a3ff9e6534ea91b21df4b56b.md b/vision-fixhub/ds9-unparsed-06/0c3c12741443f1b63573e7132e78c1c15e789040a3ff9e6534ea91b21df4b56b.md
new file mode 100644
index 0000000000000000000000000000000000000000..0f77befa88bfb5a52943f9bf989cbabda7217545
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0c3c12741443f1b63573e7132e78c1c15e789040a3ff9e6534ea91b21df4b56b.md
@@ -0,0 +1,3851 @@
+Questions or Changes?
+cingular.com
+• Toll Free 1//
+:
+611 from your wireless phone
+TTY users - 1 866 429-7TTY
+SUMMARY OF MONTHLY CHARGES FOR ACCOUNT
+Previous
+Balance
+966.41
+Payments
+Received
+-966.41
+Late Payment
+Total
+Adjustments
+Your billing cycle began on June 03, 2006 and ended on July 02, 2006
+Current Monthly Charges
+Monthly Service
+Monthly Usage
+Charges
+Credits
+Government Fees and Taxes
+Total Current Monthly Charges
+TOTAL AMOUNT - Due Upon Receipt
+Date of Invoice: July 03, 2006
+Balance
+Forward
+337.15
+191.24
+25.19
+-5.00
+24.93
+573.51
+Current Monthly
+Charges
+573.51
+Total
+Amount Due
+573.51
+573.51
+411 FEE CHANGE
+EFFECTIVE AUGUST 1, 2006, CINGULAR 411 CALLS WILL BE
+$1.79 PER CALL PLUS AIRTIME CHARGES IF APPLICABLE.
+FOR YOUR SAFETY AND CONVENIENCE, TAKE ADVANTAGE OF
+OUR CALL COMPLETION FEATURE AT NO ADDITIONAL CHARGE.
+CINGULAR 411 OFFERS LOCAL AND NATIONAL NUMBERS FOR
+BUSINESS, RESIDENTIAL, AND GOVERNMENT LISTINGS, ALONG
+WITH MOVIE SHOW TIMES AND DRIVING DIRECTIONS.
+Note:
+=>
+We Print on
+Front and Back
+* cingular
+r Fold and tear here 7
+Please Return This Portion With Your Payment.
+Use of service or payment of this invoice
+indicates agreement with the General Terms
+and Conditions for wireless service.
+Service #
+Account:
+Account Name: JEFFREY E EPSTEIN
+us maticatty dedulled from the account on my enclosed check
+(see reverse - signature required).
+Crackes secretse.
+Date Due
+#BWNHNGR
+#00000
+UPON RECEIPT
+Total
+Amount Due
+573.51
+Amount
+Paid
+2000743 0ZAB 0554 -4010 TB O 0702 10022.5.12.01.1200.0000
+CINGULAR WIRELESS - ATLYS
+PO BOX 6444
+CAROL STREAM, IL 60197-6444
+0000000000••••••••
+
+
+Recurring Electronic Fund Transfer (REFT): To enroll: sign below, check the REFT box on the reverse side and
+remit with this month's payment. Keep paying your bill until your statement indicates "Do Not Pay". REFT
+Agreement: I authorize my financial institution to deduct the amount of my monthly wireless phone bill from the
+account associated with the enclosed check and remit payment to Cingular Wireless. This authority will be effective
+until I notify Cingular Wireless to terminate it. I agree that I may be assessed a service charge (up to $20) or late.
+fee or both if a payment is returned by my bank. For more information visit cingular.com/myaccount or call 1
+Please keep a copy of the form below and this REFT Agreement for your records or retain a copy of the
+blank form from next month's invoice.
+Questions? We can help: Cingular Wireless appreciates your business and welcomes the opportunity to assist.
+mu. Visit our website at cinqular.com or contact Customer Care by dialing bll from vour wireless onone or .
+¿ Sabías que también ofrecemos servicio al cliente en tu idioma? Marca 611 desde tu teléfon
+inalambrico ó 1
+desde cualquier teléfono y oprime el *.
+Driving Wireless Safety: Your wireless phone gives you the freedom and flexibility to stay in touch when you
+travel, but don't let a phone call distract you from driving safely. Use hands-free device if allowed or required by
+law. Call Carefully, Arrive Safely.
+Processing Fees: When you pay by check, Cingular Wireless will present the check for payment by your bank
+electronically. Your bank account will be debited in the amount of the check and the transaction will appear on your
+bank statement. Your original check will be destroyed once processed, and you will not receive your cancelled
+check back. If we cannot post the transaction electronically, an image copy of your check will be presented for
+payment. For additional information, please call 1
+Accounts suspended for non-payment will be
+subject to a $25 reactivation fee per line and may be assessed a security deposit prior to reinstatement. Checks
+returned for non-sufficient funds will be charged up to a $30.00 fee.
+Local Tax: Local taxes are based on local government boundaries, the address information you provide for your
+account and/or your wireless telephone number. Please review the local tax chames on vour bill. If you believe
+there is an error in the local tax charge, please contact us immediately at 1|
+local or state laws may require you to follow special procedures when notifying us about a local tax dispute. You
+may also use the form below to notify us of any change to your taxing address. Thank you for your cooperation.
+Early Termination Fee (ETF): If you cancel service before your contract end date (including if you switch your
+wireless number to another carrier), you will be charged an Early Termination Fee of up to $200.
+One Time Checking Account Payment Authorization Agreement (for use with kiosk payment): I authorize
+Cingular Wireless to make this one-time bill payment by debiting my bank account. I can cancel authorization by
+contacting an in-store sales person. If my bank rejects a payment, I may be charged a return fee.
+Please Send Correspondence To:
+Cingular Wireless Next Generation Correspondence
+P.O. Box 68056
+Anaheim Hills, CA 92817-8056
+2000743.000005576.8
+Accoung Name and transier Financial Responsibless clearly and check the box on the reverse side. Please contact Customer Care to change the
+New Billing Address
+City
+State
+Zip
+Home Phone (
+_)
+Work Phone (.
+If your billing address is NOT your Tax Address, please enter the Tax Address below. (Multi-line accounts should attach a list of each wireless number
+and the respective Tax Address.)
+New Tax Address
+City
+Wireless Number (
+State
+Zip
+Recurring Electronic Fund Transfer (REFT) Enrollment. Please read the agreement on the top portion of this page, sign below and check
+he "REFT Registration" box on the reverse side
+Financial Account Holder Signature
+• + I do not wish to receive email notification of special oilers avalable to Cingular Wireless customers.
+
+
+STARTING AUGUST 1, YOUR ACCOUNT NAME AND WIRELESS
+NUMBER WILL DISPLAY ON CALLER ID WHEN YOU MAKE
+WIRELESS-TO-LANDLINE CALLS. BEFORE, ONLY YOUR WIRELESS
+NUMBER WAS DISPLAYED. BLOCK YOUR NAME FROM APPEARING
+TO LANDLINE CUSTOMERS BY ENABLING CINGULAR'S WCAL
+FEATURE. LOG IN OR REGISTER TO MY ACCOUNT ON
+CINGULAR.COM. GO TO MY FEATURES, CHOOSE AVAILABLE
+FEATURES, AND THEN SELECT CALLING NAME BLOCK.
+LATE PAYMENT CHARGE:
+A 1.5% LATE PAYMENT CHARGE PER MONTH MAY BE APPLIED FOR
+AMOUNTS UNPAID 20 DAYS AFTER THE DATE OF INVOICE
+(AK 0.875%, AR 0.085%, NE 1.33%, WI 1.00%).
+ACCOUNT DETAILS
+Detail of Payments - Thank You!
+Item Description
+1 PAYMENT
+Total of Payments
+Current Subscriber Monthly Charges and Credits
+Subscriber Number
+Gubscribar blonse
+Date Applied/Reversed Payment Amount
+06/22/06
+-966.41
+-966.41
+-966.41
+Total Current Subscriber Monthly Charges and Credits
+Total Current Monthly Charges
+453.39
+81.37
+38.75
+573.51
+573.51
+SUMMARY OF CURRENT ACTIVITY
+FOR
+Monthly Service Charges
+Item Description
+1 CALL WAITING
+2 TEXT MESSAGING PLAN - 0 MSGS
+3 CALLER ID
+4 VOICEMAIL
+5 DETAIL BILLING
+6 REGULATORY PROGRAM CHARGE
+7 CALL FORWARDING
+Service Dates
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+1.75
+Account Name
+SUMMARY OF CURRENT ACTIVITY - CONTINUED
+Monthly Service Charges - Continued
+Item Description
+8 WORLDCONNECT
+9 THREE WAY CALLING
+10 BLACKBERRY $49.99
+11 NATIONAL PLAN $29.99
+Total Monthly Service Charges
+Service Dates
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+16/03/06 - 07/02/0
+16/03/06 - 07/02/0
+Monthly Usage Charges
+Item Description
+1 100 ADDI ANYTME MIN
+2 MESSAGE RETRIEVAL
+3 UNLIMITED N/WKND MIN
+Total Monthly Usage Charges
+Onty Used
+72 MIN
+3 EVT
+11 MIN
+Other Subscriber Charges
+Item Description
+1 MCTD SURCHARGE
+2 NY CITY UTILITY G.R. SUR
+3 STATE TELECOM EXCISE SURCHARGE
+4 FEDERAL UNIVERSAL SERVICE FUND SURCHARGE
+Total Other Subscriber Charges
+Other Subscriber Credits
+Item Description
+1 $5 MONTHLY CREDIT
+Total Other Subscriber Credits
+Subscriber Govemment Fees and Taxes
+Item Description
+1 SALES TAX
+Total Subscriber Government Fees and Taxes
+TOTAL CURRENT CHARGES FOR L
+DETAIL OF CURRENT ACTIVITY
+Number
+Onty
+Item Date Time
+Called
+Calls To
+Used Rate Description
+1 06/06 11:07A
+INCOMING
+3 06/06 81 31P
+4 06/08 03:59P
+NEW ALBANY OH
+06/08 04:06P
+1 MIN
+6 06/93 11:164
+EMIN
+7 0614 01:45P
+ICOMING
+5 MIN
+8 06/15 02:00₽
+OLUMBUS OF
+MIN
+9 06/15 05:47P
+EV
+INCOMING
+6MIN
+100 ADD'L ANYTME MIl
+100 ABB'L ANYTME MIA
+100 ADD'L ANYTME MIN
+) ADD'L ANYTME M
+SSAGE RETRIEV,
+100 ADD'L ANYTME MIN
+
+49.99
+22.73
+0,00
+Chario
+0.55
+0.71
+0,20
+2.22
+15000
+242
+2.42
+81.37
+2000743.000005577
+
+
+* cingular
+Number
+Called
+Item Date Time
+10 06/19 11:19A
+11 06/19 12:35P
+06/21 83 030
+03:07P
+06/21
+06/21
+03:26P
+16
+03:35P
+06/21 09:21P
+17 06/21 09:34P
+18 06/23 06:37P
+28
+0621 08 530
+21 06/27 02:47P
+
+33 0629 076 1A
+27 06/29 07:26P
+TOTAL VOICE USAGE FOR
+Calls To
+COLUMBUS OH
+INCOMING
+OLUMBUS OI
+COMIN
+ALBANY OH
+COLUMBUS OH
+Toll Free CL
+INCOMING
+COLUMBUS OH
+INCOMING
+COMIN
+COMIN
+DUBLIN OH
+INCOMING
+COLUMBUS OH
+INCOMING
+Continued
+Qnty
+Used Rate Description
+J0 ADD'L ANYTME MI
+ESSAGE RETRIEVA
+100 ADD'L ANYTME MIN
+2 MIN
+ZAIN
+3 MIN
+EMIN
+1 MIN
+LEVT
+1 MIN
+1 MIN
+J MIN
+6MIN
+2MIN
+MIN
+UNLIMITED N/WKND MIN
+INLIMTED NKND MIN
+JNLIM
+100 ADD'L ANYTME MIN
+INLIMITED NWKND MIN
+00 ADD'L ANYTME MIN
+100 ADD'L ANYTME MIN
+00 ADD'L ANYTME MIN
+INLIMITED NANKND MIN
+ANYTME MIN
+UNLIMITED NANDINN
+100 ADD'L ANYTME MIN
+100 ADD'L ANYTME MIN
+SUMMARY OF CURRENT ACTIVITY
+FOR
+Monthly Service Charges
+Item Description
+1 CALL WAITING
+2 TEXT MESSAGING PLAN - 0 MSGS
+3 CALLER ID
+4 EARLY EVENING
+5 ENH DISCOUNT INTL DIAL
+6 MULTIMEDIA MESSAGING $2.99
+7 CALL FORWARDING
+8 VOICEMAIL
+9 GSM AMERICA NATIONAL ADD-ON $149.99
+10 BLACKBERRYACCESSUNIT
+11 THREE WAY CALLING
+12 REGULATORY PROGRAM CHARGE
+13 VOICEDIAL SERVICE $3.99
+14 DETAIL BILLING
+15 DISCOUNTED INTERNATIONAL ROAMING
+Total Monthly Service Charges
+Service Dates
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+06/03/06 - 07/02/06
+Monthly Usage Charges
+Item Description
+1 INCLUDED MINUTES
+2 MESSAGE RETRIEVAL
+3 100 INCL. MSGS SENT
+4 EARLY EVENING N/WKND
+5 UNLIMITED DATA
+Onty Used
+1003 MIN
+151 EVT
+100 EVT
+304 MIN
+3279 KB
+4.99
+3.99
+2.99
+149.99
+49.99
+1.75
+3.99
+5,99
+223.68
+Account Name
+SUMMARY OF CURRENT ACTIVITY - CONTINUED
+Monthly Usage Charges - Continued
+Item Description
+6 UNLIMITED N/WKND MIN
+7 CALL WAITING
+8 ENH DISC INT DL
+9 INTERNATIONAL DATA
+10 INT'L ROAMING VOICE
+11 TEXT MESSAGES SENT
+12 INTL TEXT MSG
+13 411 INFO
+Total Monthly Usage Charges
+1,024 Kilobytes (KB) = 1 Megabyte (MB)
+Onty Used
+996 MIN
+29 EVT
+15 MIN
+77 KB
+67 MIN
+188 EVT
+2 EVT
+7 EVT
+Other Subscriber Charges
+Item Description
+1 FEDERAL UNIVERSAL SERVICE FUND SURCHARGE
+2 MCTD SURCHARGE
+3 NY CITY UTILITY G.R. SUR
+4 STATE TELECOM EXCISE SURCHARGE
+Total Other Subscriber Charges
+Subscriber Government Fees and Taxes
+Item
+Description
+1 ROAMING TAX
+2 SALES TAX
+Total Subscriber Government Fees and Taxes
+TOTAL CURRENT CHARGES FOR
+DETAIL OF CURRENT ACTIVITY
+Number
+Called
+Item Date Time
+1 06/01 08:24A
+3 06/01 09 43A
+06/01 09:47A
+4 06/01 12:16P
+5 06/01 12:48P
+06/01 02:21P
+9 06/01 82:36P
+8 06/01 07:15P
+9 0601 07•740
+10 06/01 07:25P
+11 06/02 06:25A
+12 06/02 08:59A
+13 06/02 09:24A
+14 06/02 10:44A
+Calls To
+INCOMING
+INCOMING
+INCOMING
+"COMING
+INCOMING
+COMING
+Qnty
+Used Rate Description
+2 MIN
+1EVT
+MESSAGE RETRIEVAL
+L MIN
+IMIN
+INCLUBEB MINUTES
+1 MIN
+MELUDED MINTESAL
+IMIN
+1EVT
+LMIN
+IMIN
+7 MIN
+2 MIN
+TEVi
+1 MIN
+1 MIN
+1 MIN
+1EVT
+INCLUBER MINUTES
+MESSAGE RETRIEVAL
+EARLY EVENING NAVIN
+EARLY EVENING NWKND
+MESSAGE RETRIEVAL
+INCLUBEB MINUTES
+MESSAGE RETRIEVAL
+
+4.11
+155.83
+18.80
+0.50
+10,50
+191.24
+9.57
+1.25
+4.15
+552
+20.34
+0.12
+18.01
+18.13
+453.39
+
+
+Number
+Called
+Item Date Time
+15 06/02 10:44A
+16 06/02 10:46A
+7 06/02 10:50A
+IB 06/02 10:54A
+19 06/02 10:58A
+20 06/02 11:00A
+21
+06/02 11:02A
+22 06/02 11:03A
+23 06/02 11:03A
+24 06/02 11:07A
+25
+06/02 11:0ВА
+26 06/02 11:10A
+27 06/02 11:134
+28 06/02 12•20P
+29 06/02 12:48P
+30 06/02 12:49P
+31 06/02 12:50P
+32 06/02 01:13P
+33 06/02 01:34P
+34
+06/02 03:01P
+06/02 04:24P
+06/03
+:04:43P
+06/02 06:29P
+06/02 07:36P
+06/03 05:02A
+40
+41
+
+16/0
+42 ОБ/03 12:03Р
+43 ОБ/03 12:31Р
+44 ОБ/03 12:3ВP
+06/03 12:46
+6/03 12:48
+06/03 12:49F
+888888888g
+1888g
+:24P
+03:21F
+03:55₽
+04:02P
+:04:03P
+8G68
+88g
+Calls To
+CHTAMSTTHS VI
+BROOKLYN NY
+-WYORKN
+EW YORK N
+BROOKLYN NY
+RANDOLPH MA
+BROOKLYN NY
+MORIARTY NM
+INCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+- Continued
+Onty
+Used Rate Description
+1 MIN
+4 MIN
+EMIN
+CLUDED MINUT!
+CLUDED MINUTI
+2 MIN
+CLUDED MINUTE
+IMIN
+1 MIN
+INCLUDED N
+INCLUDED
+INCLUBEB MINUTES
+CLUDED MINUTE
+ICLUDED MINUTE
+NCOMING
+NCOMING
+INCOMING
+YORK NY
+RANDOLPH MA
+NEW YORK Y
+EW YORKN
+TATESBORO G
+INCOMING
+CAMBRIDGE MA
+oll Free O
+AMBRIDGE M
+NEW
+NEW
+'ORK NY
+NY
+NY
+ZOI
+NEW
+NE
+1
+NY
+I YORK NY
+INCOMING
+NEW
+YORK NY
+INCOMING
+INCOMING
+INCOMING
+NY ZONE 1
+I NY
+INCOMING
+INCOMING
+1 MIN
+AMIT
+2 MIN
+2 MIN
+1 MIN
+1 MIN
+1 MIN
+1EVI
+LESTEE
+MIN
+1EVT
+1 MIN
+IMIN
+1EVT
+/T
+1 MIN
+6 MIN
+2 MIN
+1 MIN
+IMIN
+INI IN
+
+UNLIM
+MESSI
+Account Name
+Number
+Item Date Time Called
+69 06/03 06:21P
+/0 06/03 06:36F
+/1 06/03 06:37F
+72 06/03 06:38P
+3 06/03 06:398
+4 06/03 06:41P
+3 0603 87358
+77 06/03 09:40P
+8 06/03 10:56
+9 06/04 09:35
+80 06/04 10:004
+Calls To
+INCOMING
+INCOMING
+IEW YORK N
+EW YORKN
+NY ZONE ANY
+EW YORK 1
+EW YORK N
+- Continued
+Onty
+Used Rate Description
+14 MIN
+UNLIMITED N/WKND MIN
+2 MIN
+UNLIMITED N/WKND MIN
+UNLIMITED N/KND MIN
+CALL WAITING
+1 MIN
+MIR
+IMIN
+2 MIN
+3MIN
+1 MIN
+1 MIN
+LEVI
+I MIN
+2 MIN
+1EV
+4MIN
+2 MIN
+1 EV
+UNLIMITED N/KND MIN
+LIMITED NAWKND M
+OP CALL CRED
+UNLIMITED N/WKND MIN
+LIMITED N/WKND M
+LIMITED NKND M
+UNLIMITED N/WKND MIN
+LIMITED NIKND M
+ESSAGE RETRIEVA
+UNLIMITED N/WKND MIN
+NLIMITED NIKND MI
+RETRIEVA
+
+
+
+
+
+SP
+123 06/04 04:10P
+124 06/04 06:08P
+125 06/04 06:24P
+IRK NY
+GA
+NY
+ED
+ED
+IMIN
+2 MIN
+1EV
+2 MIN
+UNL
+UN
+UNLI
+UNLI
+UNL
+N/W
+MESSAGE
+....!
+RETRIEVAL
+INLIMITEL
+KND MIN
+UNLIMIT
+MESSAGE
+RETRIEVAL
+UNLIMITED N/W KND MIN
+
+
+* cingular
+BL5S00000 E#2000Z
+Number
+Item Date Time
+Called
+126 06/04 06:27P
+127
+06/D5 08:18A
+129
+08:18A
+130
+09.
+•217
+
+09:24A
+ОБ/
+105
+09:
+38A
+137
+888
+B5g58
+:47,
+:11A
+42A
+5
+6P
+12:25P
+139
+06/
+05
+1332P
+140 06/05
+52P
+141
+01:41P
+01:45P
+142 06/05 01:51P
+143 06/05 02:00P
+144
+06/D5
+145
+:12P
+
+06/DE
+04:01P
+04:04P
+04:05P
+1888
+04:06Р
+04:
+09P
+04:
+06/
+:11P
+04:13P
+555
+06
+06
+04:15P
+04:53P
+05-5
+5555
+06:03P
+06:158
+06/05 06:16P
+06/05 06:44P
+180 06/05 83:385
+182
+06/05 08:08P
+O6ME
+08-0GP
+
+06
+88888
+/06
+
+88888
+/06
+08:42A
+/06
+08:
+:43A
+083
+6/06
+43A
+08:47A
+06
+18:26A
+706
+10:57A
+06/06
+11:01A
+178 ОБ/06 11:04A
+130 06/06 11:074
+181 06/06 12:02P
+182
+: 06/D6 12:03P
+Calls To
+INCOMING
+INCOMING
+INCOMING
+NEWYORKZN2 NY
+INCOMING
+INCOMING
+INCOMING
+NCOMING
+INCOMING
+Continued
+Onty
+Used Rate Description
+13 MIN
+UNLIMITED N/WKND MIN
+1 MIN
+INCLUBEB MINUTES
+CLUBEB MINUTE
+INCLUBED MINUTES
+INCOMING
+NEW
+YORK NY
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+NE
+NEW
+YOR
+NEI
+NE
+NE
+00
+SESS
+KNY
+YORKINY
+YORK NY
+YORK NY
+QUEENS NY
+INCOMING
+NEW
+YORK NY
+NEW
+'ORK
+RK
+NE WOOK NY
+NEZ YORK NY
+EW YORK N
+COMIN
+INCOMING
+YORK NY
+NCOMING
+NCOMING
+COMING
+INCOMING
+INCO
+OMING
+'OMING
+NCOMING
+NCOMING
+NEW
+YORK NY
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+2 MIN
+_ MIN
+3 MIN
+1 MIN
+2MIN
+3 MIN
+3MIN
+IEVI
+EMIN
+. MIN
+5MIN
+. MIN
+1EVT
+1 MIN
+3 MIN
+3 MIN
+2 MIN
+1 MIN
+IMIN
+1 MIN
+2 MIN
+2 MIN
+INCLUBED MINUTES
+2MIN
+2 MIN
+1 MIN
+1EVT
+2 MIN
+1 MIN
+12 MIN
+EMIN
+1EVT
+1EVT
+EMIN
+1 MIN
+LEVAL
+N/WKNO
+NWKND
+IEVAL
+I MIN
+EMIN
+1 MIN
+MI
+MI
+IMIN
+1MIN
+MIN
+AIN
+EMIN
+Account Name
+Number
+Item Date Time Called
+183 06/06 12:07P
+184 06/06 12:39P
+185 006 1335P
+1 06/06 01:5.
+8 06/06 02-51
+189 06/06 03:42P
+10 06/06 04:10
+91 06/06 04:18
+
+94 0b/0b 04:26
+95 06/06 04:311
+196 06/06 06:03P
+97 06/06 06:20
+98 06/06 06:21
+199 06/06 07:21P
+201 06/06 08:49Р
+06/06 08:49Р
+202
+06/06
+08:49P
+06/06
+204 06/07 08:28A
+205 06/07 09:07A
+206 06/07 09:14A
+207
+06/07 09:1
+208
+06/07
+09:27A
+209
+06/07 09:28A
+210 06/07 09:32A
+06
+
+09
+:56A
+BENNEEDNEED ENDURABE
+...
+09:57A
+09:584
+10:0
+ga99992999EEABBBBEA
+:ОБА
+122A
+Calls To
+INCOMING
+INCOMING
+NCOMING
+JEW YORK NY
+COMIN
+COMI
+INCOMING
+ROOKLYN N
+COMIN
+JEW YORK NY
+NCOMING
+INCOMING
+NCOMING
+NCOMING
+000
+‹<3
+• Continued
+Onty
+Used Rate Description
+2 MIN
+2 MIN
+IMIN
+CLUBEB MINUTE
+NUTE
+1EVT
+MESSAGE RETRIEVAL
+IMIN
+INCLUBED MINUTES
+1 MIN
+EMIN
+CLUDED MINUTE
+NUTE
+1EVT
+MESSAGE RETRIEVAL
+EMIN
+INCLUBEB MINUTES
+2 MIN
+MIN
+1 MIN
+L MIN
+CLUDED MINUT!
+3 MIN
+2:
+332
+YOR
+KZN2
+IRK
+NY
+NEW
+NY
+ORKZN1
+YORK
+NY
+AS VI
+NY
+EEEEEEEE
+ШЕЕ ТЕ ШЕНИШШ
+
+MIN
+
+
+Number
+Called
+Item Date Time
+241 06/07 12:07P
+242 06/07 12:07P
+43 06/07 12:09P
+244 06/07 12:12F
+245 06/07 12:17P
+46 06/07
+12:36P
+47 06/07 12:37P
+248 06/07 12:39P
+249 06/07 12:46P
+250 06/07 12:50P
+00/02
+252 06/07 01:01P
+253 06/07 01:07P
+254 06/02 02:12P
+55 06/07 03:21P
+256 06/07 03:26P
+257 06/07 03:27P
+258 06/07 03:28F
+59 06/07 03:44
+60 06 07 03:45
+261 06/07 03:48P
+262 06/07 03:49P
+263 06
+03:51P
+264 06
+03:52P
+265 06/07 03:55P
+266 06/07 03:56P
+267 06/07 03:57P
+268 06/07 04:10P
+269 06/07 04:15P
+70 06/07 04:19
+271
+373 08/07 84:28P
+274 06/07 04:50P
+275 06/07 08:33P
+276 06/07 08:38P
+77 06/07 09:19
+78 0608 0817
+279 06/08 09:51A
+2B0 06/08 10:15A
+302 06/08 01 330
+283 06/08 02:33P
+284 06/08 03:11P
+285 06/08 04:06P
+286 06/08 04:07
+287 06/08 05:47
+288 06/08 06:38P
+2B9 06/09 09:52A
+390 06/09 05 388
+292 06/09 05:39P
+293 06/09 05:56P
+Calls To
+INCOMING
+BROOKLYN NY
+COMIN
+COMINI
+BROOKLYN NY
+BROOKLYN NY
+QUEENS NY
+JEENS NY
+EW YORK N'
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+NY ZONE 1 NY
+INCOMING
+- Continued
+Onty
+Used
+Rate Description
+1MIN
+1 MIN
+2 MIN
+1 MIN
+MINUT
+1 MIN
+INCLUDED MINU
+IMIN
+INCLU
+DED
+MINU
+ES
+1 MIN
+NCLUDED MINUTE
+1MIN
+1EVT
+MESSAGE RETRIEVAL
+2 MIN
+2MIN
+NCLUDED MINUTES
+NCLUDED
+MINUT
+1 MIN
+DELUDED MINUTES
+1EVT
+MESSAGE RETRIEVAL
+IMIN
+UDED MINUT
+1EVT
+MESSAGE RETRIEVAL
+2MIN
+NCLU
+1 MIN
+NELUDED MINUTES
+IMIN
+2MIN
+1 MIN
+IEVT
+2 MIN
+IMIN
+QUEENS NY
+NEW
+YORK NY
+NEW
+NEW
+NY ZONE 1 NY
+INCOMING
+INCOMING
+INCOMING
+22
+2222
+BROOKLYN NY
+INCOMING
+INCOMING
+QUEENS NY
+COMING
+INCOMING
+INCOMING
+GUADELOUPE
+INCOMING
+NEWYORKZNI NY
+IMIN
+1 MIN
+2MIN
+1 MIN
+1EVT
+1 MIN
+EV
+1MIN
+EMIN
+IMIN
+1MIN
+TEVE
+2MIN
+2 MIN
+IMIN
+IMIN
+MIl
+1 MIN
+IMIN
+2 MIN
+MIl
+MI
+IMIN
+2MIN
+EMIN
+1MIN
+1EVT
+1 MIN
+IEVT
+2MIN
+IMIN
+1 MIN
+TEVT
+2MIN
+D
+0.60
+IKND
+MIN
+0.60
+Account Name
+Number
+Item Date Time
+Called
+- Continued
+Onty
+Used Rate Description
+1EVT
+MESSAGE RETRIEVAL
+1MIN
+UNLIMITED NAKND MIN
+294 06/10 11:24A
+295 06/10 11:25A
+296 06/10 12:30P
+297
+06/10 04:06P
+298 06/10 05:10P
+299 06/10 07:00P
+300 06/10 09:06P
+301 06/11 08:12A
+0z 06/11 09:18
+12 0611
+11:03A
+04 06/11 11:25
+307 06/11 04:08P
+308
+06/11 04:11P
+309
+06/11 04:12P
+88888
+88889
+:31P
+
+BBOBOONOER
+325
+06/12 10:19P
+
+WOGDOONONEEE
+88888
+9925
+=1
+1:28A
+/13
+06/13
+11:29A
+06/13 11:30A
+Calls To
+INCOMING
+CHTAMSTTHS VI
+NCOMING
+NCOMING
+mobile UK
+COMING
+IEW YORK N°
+NCOMING
+NCOMING
+INCOMING
+FRANCE
+mobile FRA
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+NCOMING
+OMING
+INCOMING
+NCOMING
+NCOMING
+COMING
+IEW ALBANY OI
+BROOKLYN NY
+INCOMING
+NEW
+QUEENS
+ENS NY
+STATESBORO GA
+INCOMING
+STATESBORO GA
+INCOMING
+BROOKLYN NY
+NCOMING
+RK
+RK
+YORK
+W
+YORK
+3223
+YORK NY
+1 MIN
+IMIN
+7 MIN
+2 MIN
+LEVI
+1 MIN
+1 MIN
+NLIMITED I
+UNLIMITED N/WKND MIN
+UNLIMITED NAN MIN
+INLIMITE
+UNLIMITED N/WKND MIN
+ESSAGE RETRIEVA
+NLIMITED NAVKND MI
+0.25 ENH DISC INT DL
+MIN
+1EVT
+4 MIN
+1MIN
+3MIN
+2 MIN
+EVT
+1 MIN
+1 MIN
+1 MIN
+17 MIN
+3MIN
+1 MIN
+2MN
+1MIN
+3 MIN
+WN
+MIN
+MIN
+INLIMITED NAVKND MI
+INLIMITED NAND MI
+MESSAGE RETRIEVAL
+NIMITED NOVKND M
+NLIMITED NA/KND M
+UNLIMITED N/WKND MIN
+UNLIMITED NAKND MIN
+MESSAGE RETRIEVAL
+UNLIMITED
+KND MIN
+0.07 ENH DIS
+UNLIMIT
+EDNANKND MIN
+0.31 ENLIMIT
+UNLIM
+DU
+KND MIN
+INCLUDED
+N.
+W
+MINUT
+BEB
+NC
+533
+UT
+E332
+E
+UT
+4 MIN
+2MIN
+2 MIN
+MIN
+1 MIN
+EV
+1 MIN
+LEVT
+MIN
+1 MIN
+1 MIN
+MIN
+MIN
+MIN
+1 MIN
+MIN
+1 MIN
+IMIN
+1 MIN
+2 MIN
+1EVT
+S9SS
+MIN
+AM.
+Om
+N/WKND MIN
+UNLIM
+LIN
+LIM
+UN
+LIM
+UNLIMI
+MIN
+U
+MIN
+EVT
+NC
+ED
+§92s95
+
+0.25
+0.07
+0.31
+2000743.000005579
+
+
+2000743.000005579
+Number
+Called
+Item Date Time
+345
+06/13 11:31A
+06/13
+
+11:34A
+11 SBA
+50A
+11:
+53A
+880KE
+54A
+24P
+:33P
+355
+356
+06/13
+01-46P
+06/13
+02:14P
+613 0217
+06/13
+2-111
+20580
+06/13
+:43P
+10P
+7P
+364 06/13 07:06Р
+16/13
+367
+06/13
+88
+08:07P
+370
+06/13 08:19P
+06/13
+06.
+/13
+:25P
+11
+20P
+373 06/13 11:33P
+374 06/13 11:37P
+275
+6/14 08:57
+376
+6114 00-01
+377 06/14 09:05A
+378 06/14 09:33A
+379 06/14 09:37A
+380 06/14 09:58A
+383
+06/14 10:23A
+06
+:28A
+10-30A
+10:33A
+06/14
+01:10P
+12P
+06.
+01-21 P
+06/14 02:55P
+392 06/14 02:56P
+393 06/14 02:57P
+394 06/14 03:21P
+395 06/14 03-44P
+04:49P
+05:17P
+06/14 05:21P
+Calls To
+NEWYORKZN2 NY
+NY ZONE 1 NY
+INCOMING
+NEW
+YORK NY
+INCOMING
+VEW YORK NY
+VWYRCYZNO1 NY
+W ANGELES CA
+NY ZONE 1 NY
+NCOMING
+NY ZONE 1 NY
+- Continued
+Onty
+Used Rate Description
+1 MIN
+2MIN
+INCLUBEB MINUTES
+1 MIN
+CLUBEB MINUTE
+INUTE
+12 MIN
+LMIN
+2 MIN
+28 MIN
+EW YORK N
+EW YORI
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+BEDOKLYN NY
+JET
+NY
+NY ZONE 1 NY
+NE ZONE NY
+INCOMING
+NY ZONE 2 NY
+NY ZONE 1 NY
+INCOMING
+QUEENS NY
+INCOMING
+INEW MORN
+NEW
+INCOMING
+NEV
+SFATESBORO GA
+BROOKLYN NY
+NCOMING
+NEWYORKZNI NY
+NY
+ZONE 1 NY
+INCOMING
+NEWYORKZNI NY
+INCOMING
+EMIN
+. MIN
+1EVT
+3MIN
+1 MIN
+1 MIN
+LMIN
+17 MIN
+2MIN
+MESSAGE RETRIEVAL
+INCLUBED MINUTES
+1MIN
+A MIN
+2 MIN
+IMIN
+4 MIN
+6 MIN
+MIN
+2MIN
+LEVE
+4 MIN
+SMIN
+IMIN
+2 MIN
+EV
+2 MIN
+2 MIN
+SMIN
+2 MIN
+MI
+MIN
+2 MIN
+2 MIN
+1 MIN
+1 MIN
+1EVI
+1EVT
+3MIN
+2 MIN
+TECT
+1 MIN
+4 MIN
+1 MIN
+NCI
+Account Name
+
+Number
+Item Date Time
+Called
+399 06/14 05:23P
+400 06/14 05:26P
+403 06/14 05:37P
+404 06/14 05:49Р
+205 06/14 0616Р
+407 06/14 06:26P
+109 06/14 06:288
+06/14 06:341
+412 06/14 06:38P
+413 06/14 09:57P
+414 06/14 10:43P
+415 06/14 10:45P
+416 06/14 10:46P
+417 06/14 10:49P
+418 06/14 11:02P
+419 06/15 12:48A
+221 06/1 08A
+422
+06/15 08:48A
+423 06/15 08:54A
+424 06/15 08:57A
+425
+426
+15
+/15
+88888
+430 06/15 09:48A
+232 06E 1029A
+ДА ОВ НОВА
+
+SEEEEE
+seated
+441 06/15 12:48Р
+442 06/15 12:59P
+BESEES
+
+
+1:15P
+B9g99
+5P
+449
+06/15 01:47P
+450
+06/15
+01:56P
+Calls To
+STATESBORO GA
+INCOMING
+INCOMING
+ROOKLYN N
+ICOMING
+COMIN
+COMING
+NY ZONE 1 NY
+BROOKLYN NY
+NY ZONE 1 NY
+NY ZONE
+NY
+NEW
+YORK
+INCOMING
+CHTAMST
+THS V
+INCOMING
+• Continued
+Onty
+Used Rate Description
+1 MIN
+1 MIN
+HMIN
+CLUDED MINUT!
+CLUDED MINUTE
+1 MIN
+LL WAITI
+LUDED MINUTI
+1EVT
+LMIN
+1M
+1 MIN
+EMIN
+IMIN
+1 MIN
+L MIN
+LEV
+2 MIN
+1EV
+1 MIN
+1 MIN
+MESSAGE RETRIEVAL
+INCLUBEB MINUTES
+INCLUBED MINUTES
+UNLIMITED N/WKND MIN
+MESSAGE RETRIEVAL
+UNLIMITED N/WKND MIN
+MESSAGE RETRIEVAL
+UNLIMITED N/WKND MIN
+UNLIMITED
+N/W
+KND MIN
+ESSAG
+IR
+NLIMITE
+TREMIN
+VAI
+MIN
+MIN
+1 MIN
+1EV
+BMIN
+7 MIN
+1 MIN
+7MIN
+4 MIN
+1EV
+1 MIN
+4 MIN
+2 MIN
+1 MIN
+HEIN
+1EVT
+AMIN
+1EVT
+2MIN
+IEVT
+1 MIN
+2 MIN
+1 MIN
+LEVY
+12 MIN
+LEVY
+2 MIN
+2 MIL
+1 MIN
+1 MIN
+3MIN
+1EVT
+4 MIN
+3MIN
+UNLIMI
+UNLIMI
+INCLUDE
+INCLUDED
+INCLUDED
+CAI
+AIT
+INCLUDED
+N
+INCOMING
+EW YORK N
+EW YORK N
+EWBURGH N
+NY
+Y ZONE 1 N
+NY
+ANDOLPH M
+COMIN
+JEW YORK N
+LANDOLPH M.
+INCLUDED
+INCLUDED
+MCLUDED
+MESSAGE
+INCLUBEE
+MESSAGE
+IELUBER
+B MINUTES
+MESSAGE RETRIEVAL
+INCLUBER M
+INUTES
+INCLUBEB
+MINUTES
+MINI
+NCLUDED
+MESSRGE RETRIEVAL
+ESSAGE RET
+O RETRIEVA
+AL
+INCLUDE
+INCLUDE
+00
+INUTES
+INCLUBED MINUTES
+CALL WAITING
+NCLUDED MINUTES
+
+
+Number
+Item Date Time
+Called
+451 06/15 02:35P
+452 06/15 03:36P
+453 06/15 03:42P
+454 06/15 03:43P
+455 06/15 04:40P
+156 06/15 834Р
+458 06/15 05:46P
+150 06/5 09.28P
+18 0613 020
+462 06.
+463 06/15 10:05P
+464 06
+465 06
+0:371
+466
+12:02A
+467
+468
+02.054
+469
+470 06/
+06/16
+2A
+:29 A
+412
+473฿
+06
+08/16 09.06А
+474 06/16 09:52A
+475 06/16 10:12A
+476 06/16 10:17A
+06/16 10:20A
+478 06/16 12:25P
+481
+182
+1R3 1
+484
+Ub/
+02:43F
+485
+06,
+03:04P
+486
+06/16 03:15P
+487 06/16
+488 06/16
+489
+490
+101
+492
+08281
+
+3:22P
+3:24P
+156Р
+:S7P
+BP
+Calls To
+INCOMING
+NY ZONE 1 NY
+INCOMING
+NEWYORKZNI NY
+ZN1 NY
+INCOMING
+NEWYORKZNI NY
+NY ZONE 1 NY
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+NEUMINU
+IING
+INCOMING
+NEW
+YORK NY
+RANDOLPH MA
+INCOMING
+INCOMING
+NEW YORK NANY
+- Continued
+Onty
+Used
+Rate Description
+1MIN
+2MIN
+EV
+MIl
+NELSOED MINUTESAL
+2MIN
+lEVT
+IMIN
+NALUDED MINUTES
+1EVT
+MESSAGE RETRIEVAL
+IMIN
+1 MIN
+CLUDED MINUTE
+CLUDED MINU
+6MIN
+CHIN
+1 MIN
+UNLIMITED NWKND
+4MIN
+UNLIMITED N/WKND
+3MIN
+UNLIM
+ED NAVI
+3MIN
+UNLIM
+ED NAKN
+IMIN
+UNLIM
+ITED N/W
+1 MIN
+AN BACCO
+3MIN
+SMIN
+2 MIN
+3MIN
+IMIN
+8MIN
+!!!!
+1 MIN
+IEVT
+HEVY
+4 MIN
+3MIN
+10MIN
+IEVT
+NCOMING
+INCOMING
+RO
+GA
+ORK NY
+JEW
+BRK NY
+IEV
+IMIN
+1MIN
+1 MIN
+SMIN
+MIl
+Account Name
+
+Number
+Called
+Item Date Time
+507 06/16 07:30P
+508 06/16 07:47P
+18 06/16 08.46
+511 06/17 08:46A
+06/17 08:47A
+06/17 09:37A
+314 06/17 09324
+516 06/17 09:43A
+6/22 0932
+Calls To
+INCOMING
+JEW YORK N
+HE AMORS VI
+QUEENS NY
+- Continued
+Onty
+Used Rate Description
+3 MIN
+EARLY EVENING N/WKND
+17 MIN
+EARLY EVENING N/WKND
+EMIN
+ARLY EVENING NOWN
+TWKN
+1 MIN
+UNLIMITED N/WKND MIN
+ZMIN
+INLIMITED NAKND MI
+2 MIN
+NLIMITED NAWKND MIl
+1EVT
+MESSAGE RETRIEVAL
+SMIN
+MIN
+UNEMITED NUK MIN
+2 MIN
+UNLIMITED N/WKND MIN
+2 MIN
+NLIMILED NAVKND M
+6/17 09-47
+
+17
+09:48A
+17 09-50A
+/17
+09:51A
+17 09:53A
+110-00
+88
+COMINGZI NY
+YORK NY
+CHTAMSTTHS VI
+TEENS A
+COMING
+QUEENS N
+COMING
+DUEENS NY
+COMING
+DUEENS NY
+IMIN
+3 MIN
+MIN
+2MIN
+4 MIN
+2MIN
+ANONANA
+1MIN
+52
+UNLIMITED NA
+MIN
+UNLIMITED NAV
+MIN
+UNLIMITED NA/KND
+MIN
+KND MIN
+KND MIN
+IKND MIN
+WKND MIN
+8888888888888 888 88
+
+889
+18280
+88
+493 06/16 04:20P
+494
+495
+06.
+05:05Р
+06/
+05:08P
+496 06/16 06:15P
+497 06/16 06:23P
+498฿
+06/16
+
+
+5:27P
+:50P
+:05P
+7:07P
+ZN1
+NY
+: 1 NY
+INCOMING
+NY
+IEWY
+GA
+4MIN
+8MIN
+1MIN
+IEV
+1MIN
+4MIN
+НАД!
+
+BROOKLYN NY
+INCOMING
+NY
+W YORK NY
+33
+YORK NY
+YORK NY
+INCOMING
+NY ZONE 1 NY
+NCOMING
+VY ZONE 1 N
+NCOMING
+INCOMING
+NCOMING
+ZONE 1 NY
+NY ZONE 1 NY
+~COMING
+NEWYORKZN2 NY
+JEENS I
+NEWYORKZNI NY
+1 MIN
+1 MIN
+11 MIN
+1 MIN
+2 MIN
+•MIN
+MIN
+1 MIN
+2 MIN
+• MIN
+1 MIN
+EV
+MiT
+2 MIN
+1 MIN
+2 MIN
+1EVT
+EMIN
+L MIN
+IEVT
+3 MIN
+19 MIN
+2 MIN
+10 MIN
+6MIN
+2 MIN
+2 MIN
+IMIN
+2 MIN
+1 MIN
+2 MIN
+NM
+UNI I
+MESS.
+CALL
+....
+UNI
+LETRI
+IEVAL
+0B000052000Z
+
+
+2000743.0000055B0
+Number
+Called
+Item Date Time
+565 06/17 05:12P
+566 06/17 05:20P
+16/17 05:26:
+16/17 05:278
+569 06/17 05:28P
+570 06/17 05:29P
+572
+06/17 05:30P
+05:31P
+573 06/17 05:32P
+074 06/17 05:33P
+75 06/17 08:38P
+576 06/17 08:40P
+05/17
+08:41P
+42P
+57
+583
+06/18
+46A
+06/18
+584
+06/18
+:01A
+585
+09:01A
+06/18 09:01A
+586 06/18 09:02A
+06/18 09:07A
+188 06/18 09-34A
+589 06/18 10:58A
+590 06/18 10:59A
+591 06/18 11:00A
+392
+507
+06/18
+06/18
+585 06/8 1:054
+596 06/18 11:10A
+597 06/18 11:41A
+599 об/л8 0213А
+600 06/18 02:44P
+601 06/18 04:51P
+02 06/18 08:46
+604 06/19 11:21A
+605 06/19 11:24A
+606 06/19 11:27A
+607 06/19 01:18P
+608 06/19 02:22P
+609 06/19 02:45P
+BESE
+08/18 02.-528
+4040
+19 03:35P
+06019 09-21P
+- Continued
+Onty
+Calls To
+NY ZONE 1 NY
+NY ZONE 1 NY
+NY ZONE 1 NY
+NCOMING
+Used Rate Description
+3 MIN
+UNLIMITED N/KND MIN
+1 MIN
+UNLIMITED N/KND MIN
+L MIN
+UNLIMITED NAVKND MIN
+1 MIN
+STATESBORO GA
+INCOMING
+1EVT
+INLIMITED NWKND MIN
+CALL WAITING
+MIN
+LEVI
+UNLIMITED N/WKND MIN
+MESSAGE RETRIEVAL
+1 MIN
+UNLIMITED N/WKND MIN
+LIMIN
+UNLIMITED NAKND MIN
+_ MIN
+UNLIMITED NAKND MIN
+1 MIN
+UNLIMITED N/KND MIN
+LEVT
+WAILING
+QUEENS NY
+UNLIMITED NAWKND MIN
+MIN
+LEV
+INLIBITED NAVKND MIN
+ESSAGE RETRIEVA
+2 MIN
+UNLIMITED N/KND MIN
+NEWYORKZN2 NY
+1 MIN
+NLIMITED N/KND MI
+NCOMING
+1 MIN
+NINTED NAVKNI
+MIN
+BROOKLYN NY
+1 MIN
+UNLIMITED N/WKND MIN
+INCOMING
+3 MIN
+JNLIMITED N/WKND MI
+2.
+NEW
+YORK NY
+LMIN
+INLIMITED
+2 MIN
+N/WKND
+MIN
+UNLIMITED N/WKND
+MIN
+INCOMING
+1 MIN
+INLIMI
+STATESBORO GA
+INCOMING
+I MIN
+MIN
+1 MIN
+INCOMING
+4 MIN
+NEWYORKZNI NY
+mobile FRA
+mobile FRA
+FRANCE
+FRANCE
+mobile FRA
+1 MIN
+EMIN
+. MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+UNLIMITED N/WKND MIN
+INLIMI
+INLIMI
+UNLIMIT
+WKND
+.31 ENH DI
+INLIMÍ
+WIND
+UNLIMIT
+N/WKND
+) N/
+KAMIN
+NEW YOR MY
+MESSAGE
+ALBUQURQUE NM
+INCOMING
+NEW YORK N'
+1 MIN
+EMIN
+IMIN
+LEV
+MIN
+1EVT
+EW YORK N
+EW YORK i
+NCOMING
+JEW YORK N°
+1EVT
+TEWT
+1 MIN
+CY I
+1 MIN
+1 MIN
+1EVT
+INCL
+0.31
+Account Name
+
+- Continued
+Number
+Item Date Time
+Called
+Onty
+Calls To
+Used Rate Description
+614 06/20 01:47P
+3 MIN
+815 06/20 02 15₽
+1EVT
+MESSAGE RETRIEVAL
+WYORKZNI N
+LMIN
+obile BR
+[MIN
+INCLUBEB MINUTES
+1MIN 0.26 ENH DISC INT DL
+0.26
+617 06/20 06:34P
+CLUDED MINUTE
+• SSAGE RETRIEVA
+618 06/21 08:22A
+2 MIN
+619 06/21 10:48A
+SSAGE RETRIEVE
+MINIIT
+620 06/21 11:14A
+621 06/21 11:49A
+622 06/21 12:14P
+1EVT
+MESSAGE RETRIEVAL
+ICLUDED MINUTE.
+ESSAGE RETRIEVAI
+VCLUDED MINUTE:
+IESSAGE RETRIEVAL
+1 MIN
+MESSAGE RETRIEVAI
+23 0621 12:30
+24 06/21 01:33
+625 06/21 03:59P
+NCLUDED MINUTES
+626 06/21 03:59P
+ELEE
+INCLUDED
+NELUDED
+MESSAGE
+LEVE
+NCLUD
+MESSA
+11/1
+627 06/21 05:16P
+1 MIN
+NCLUDED
+ОБ.
+ALBUQURQUE NM
+3MIN
+MESSAGE
+628 06/21 07:44P
+EARLY
+N/WKND
+07:48P
+08:5DP
+INCOMING
+› MIN
+CARLI
+T MIN
+: AR
+NE
+IMIN
+22
+'KNO
+631 06/21 09:06Р
+1 NY
+UNLIMIT
+N/WKND MIN
+632
+Db/2
+09:07P
+20 MIN
+UNLIMI
+633
+06/21
+09:32P
+URQUE NM
+IMIN
+UNL
+NIW KNB
+I MIN
+634 06/21 09:33P
+09:35P
+ALBUQURQUE NM
+1 MIN
+UNLIMIT
+ED
+WEND
+MIN
+636 06/22 0431A
+INCOMING
+5 MIN
+1 MIN
+UNLIMIT
+UNLIMIT
+NAN
+ND MIN
+IEVT
+KND MIN
+MESSAGE RETRIEVAL
+EMIN
+1 MIN
+i MIN
+UNLIMITED NWN MIN
+3MIN
+UNLIMITED N/WKND MIN
+1 MIN
+19 MIN
+INCLUBED MINUTES
+NY ZONE 1 NY
+5 MIN
+EW YORK!
+2 MIN
+• ZONE 11
+I MIN
+INCLUBEB MINUTES
+INCOMING
+4 MIN
+ОБ
+INCLUBED MINUTES
+NCOMING
+L MIN
+1EVT
+CLUBEBI
+MINUTE
+MESSAGE RETRIEVAL
+652 06/22 07:34P
+MIN
+EARLY
+LEV
+653 06/23 08:33А
+IMIN
+654 06/23 09:51A
+856 06/23 02:01P
+657 06/23 02:55P
+388
+1EVT
+2 MIN
+1 MIN
+1EVT
+1 MIN
+IEV
+2 MIN
+2 MIN
+1 MIN
+MESSAGE RETRIEVAL
+NUTI
+-LUBED MINUTI
+MESSAGE RETRIEVAL
+IMESSAGE RETRIEVAL
+CLUDE
+INUTE
+ICLUDE
+IN U
+
+
+- Continued
+Number
+Item Date Time
+Called
+Qnty
+Calls To
+Used
+Rate Description
+661 06/23 05:10P
+1 MIN
+662 06/23 05:10P
+1 MIN
+663 06/23 06:59P
+1 MIN
+CLUDED MINUTE
+LEVT
+ESSAGE RETRIEVA
+664 06/23 07:14P
+INCOMING
+2MIN
+EARLY EVENING N/WKND
+665 06/23 07:20P
+NCOMING
+3MIN
+666 06/24 09:25A
+INCOMING
+1MIN
+EARLY EVENING N/KND
+UNLIMTED NAVKND MIN
+667 06/24 09:39A
+ASPEN CO
+4MIN
+UNLIMITED N/WKND MIN
+68 06/24 09:424
+SLENWO
+69 06/24 09:444
+2MIN
+2 MIN
+09:46A
+872 06/24 09:48A
+1MIN
+UNLIMITEB NINB MIN
+UNLIMI
+670 06/24 09:45A
+ASPEN CO
+UNLIM
+TED N/WKND MIN
+SPEN C
+LMIN
+UNLIMITED NINE MIN
+673 06/24 09:49A
+1 MIN
+INLIMITEDNAIKND MI
+674 06/24 09:50A
+BROOKLYN NY
+1 MIN
+675 06/24 09:51A
+1 MIN
+UNLIMIT
+DNAK
+ID MIN
+UNLIM
+676 06/24 09:5ZA
+UEENS N
+UNLIMITED N/WKND MIN
+677 06 24 03:55P
+EW YORK N
+3MIN
+ITED N/WKND MIN
+10 N
+IEVT
+UNLIMITED NAWKND MIN
+MESSAGE RETRIEVAL
+678 06/24 03:57P
+1 MIN
+UNLIMITED N/WKND MIN
+1EV
+MESSAGE RETRIEVAL
+679 06/24 03:58P
+IMIN
+UNLIMITED N/WKND MIN
+lEV
+680 06/24 03:58P
+IMIN
+150 DROP CALL CREDIT
+1EV
+681 06/24 03:58P
+EMIN
+IEVT
+1.50 411 INFO
+683 06/24 04:14P
+3 MIN
+INLIMO
+SMIN
+UNLIMITED WIND MIN
+IEVT
+1.50 411 INFO
+684 06/24 05:22P
+685 06/24 05:40P
+BROOKLYN NY
+LEVT
+UNLIMITED N/WKND MIN
+MESSAG
+iE
+1 MIN
+UNLIMITED
+B6 06/24 0
+B$ 0624 9513
+BROOKLYN NY
+1 MIN
+UNLIMIT
+ANGELES
+CA
+5 MIN
+UNLIMIT
+KNB
+688 06/24 06:00P
+1 MIN
+UNLIMITED
+5B9 06/24 06:01
+NEW YO
+00 0674 06.47|
+INCOMING NY
+MI
+UNLIMITED
+682 08/24 08 48P
+NEAN GEES CA
+EMIN
+NLIM
+INLIMITE
+693 06/24 06:54P
+INCOMING
+3MIN
+4 06/24 06:5
+5 0601 06•E
+SOUTHAMES CAY
+3 MIN
+ANGELES
+AMIT
+696 06/24 07:03P
+2 MIN
+697 06/24 07:09F
+NCOMING
+1 MIN
+698 0624 07:097
+NCOMING
+16MIN
+699 06/24 07:25
+W ANGELES CA
+1EVT
+10 MIN
+INCOMING
+1 MIN
+1EVT
+701 06/24 07:36P
+SMIN
+702 06/24 07:44P
+1 MIN
+703 06/24 07:44P
+W ANGELES CA
+IEVT
+EMIN
+4MIN
+MESSAGED
+UNLIMIT
+704 06/24 08:00P
+702 06/24 08:16P
+706 0604|
+STATE SORO
+UNLIMITED
+UNLIMIT
+UNLIMI
+MIN
+707 06/24 08:36P
+08:43P
+NE
+1MIN
+W
+YORK NY
+1 MIN
+IKND MIN
+08 06/2
+1 MIN
+MIN
+0620 85
+mobile UK
+3MIN
+2 MIN
+06/23
+10:004
+COMIN
+COMIN
+12MIN
+0.50
+DE
+06
+REDI
+10214
+1MIN
+2 MIN
+10:23A
+WPALMBEACH FL
+IMIN
+IMIN
+UNLIM
+UNLIM
+Account Name
+Number
+Called
+Item Date Time
+715 06/25 10:23A
+716 06/25 10:24A
+718 06/23 10:29A
+10-29A
+719 06/25 10:30A
+20 06/25 10:31A
+06/25 10:35A
+722 06/25 10:38A
+723 06/25 11:04A
+724 06/25 11:09A
+726 06/25 1113A
+727 06/25 11:22A
+128 06/25 11:26A
+729 06/25 11:29A
+8888
+BEE
+13b
+731
+738 06/25 12:21P
+Calls To
+W PALMBEACH FL
+Toll Free CL
+V PALMBEACH FL
+OSTON MA
+CHILMARK MA
+MIAMI FL
+N ANGELES CA
+W ANGELES CA
+NPALMBEACH FL
+Toll Free CL
+INCOMING
+Toll Free CL
+INCOMING
+Toll Free CL
+- Continued
+Onty
+Used Rate Description
+2 MIN
+UNLIMITED N/KND MIN
+3MIN
+UNLIMITED N/WKND MIN
+2 MIN
+IMIN
+1 MIN
+ZMIN
+IMIN
+5MIN
+UNLIMITED N/WKND MIN
+ND MIN
+INLIMITED NAWKND MIN
+UNLIMITED N/WKND MIN
+UNLIMITED NAKND MIN
+MESSAGE RETRIEVAL
+UNLIMITED N/KND MIN
+MIAMI FL
+WPALMBEACH FL
+INCOMING
+W ANGELES CA
+W
+W
+NE
+• Bona
+
+gagg
+YORK NY
+NCOMING
+NEW YORK N
+2 MIN
+9 MIN
+4 MIN
+1EVT
+6MIN
+LEV
+6MIN
+1 MIN
+MIN
+1 MIN
+: MIN
+MIN
+MIN
+1EVT
+UNLIMITED N/KND MIN
+ALL WAITING
+UNLIMITED NAKND MIN
+UNLIMITED N/KND MIN
+ALL WAITING
+ELEE
+EEEE
+ILIM
+
+222
+33
+411
+N/W
+UN
+INLIMI
+INLIMI
+UN
+UN
+
+
+
+88888
+150 08/26 0325P
+03:21
+762 06/26 03:338
+
+INCOMING
+NEW YORKZNI NY
+3MIN
+A IN
+MIN
+1 MIN
+1 MIN
+1 MIN
+2 MIN
+EMIN
+2 MIN
+EMIN
+iMIN
+9MIN
+MI
+1 MIN
+2 MIN
+1EVT
+6MIN
+1 MIN
+IEVT
+1 MIN
+IMIN
+PENN
+IMIN
+4 MIN
+1 MIN
+1 MIN
+IEVT
+INCLUBEB
+NCLU
+NCLUD
+1.50 411 INFO
+ES
+
+2000743.000005581
+
+I9SS00000 E#2000Z
+Number
+Item Date Time
+Called
+770 06/26 09:41P
+771 06/26 11:02P
+373
+05/28 11 14P
+11-44P
+774 06/26 11:59P
+175
+06/27 08:32A
+176
+06/27 09:02A.
+777 06/27 09:35Al
+778 06/27 12:53P
+779 06/27 01:40P.
+780 06/27 01:52P
+782 06/27 82:18P
+18P
+783 06/27 03:43P
+79S 06/27 0403P
+786 06/27 05:16P
+787
+06/27 05:24P
+788
+06/27 05:49P
+06/27
+7 06:55P
+07:00P
+08/27
+87.20P
+:20P
+06/27
+07:22P
+06
+86/27
+796
+06/27 07:49P
+797 06/27 07:50P
+798
+06/27 07:53P
+79g 06/27 07:58P
+800
+06/27 08:00P
+06
+28
+888BE58888828
+06/28
+05:
+:36P
+
+
+
+Calls To
+NY ZONE 1 NY
+INCOMING
+NCOMING
+STATESBORO GA
+mobile UK
+INCOMING
+mobile UK
+INCOMING
+NCOMING
+INCOMING
+INCOMING
+INCOMING
+NCOMING
+COMING
+JEANS N
+COMIN
+NY
+INCOMING
+NCOMI
+ING
+• Continued
+Onty
+Used Rate Description
+1 MIN
+UNLIMITED N/KND MIN
+2 MIN
+UNLIMITED N/KND MIN
+1 MIN
+5 MIN
+TAKN
+1 MIN
+UNLIMITED N/KND
+FEE
+3 MIN
+8 MIN
+ICLUBEB MINUTE
+1 MIN
+AMIN
+25 ENH DISC INT.!
+_ MIN
+ICLUDED MINUTE
+1 MIN
+EMIN
+0.25 INCH DISC MINUTES
+IMIN
+. MIN
+INCLUBED MINUTES
+2 MIN
+Z MIN
+4 MIN
+1 MIN
+LEVT
+11 MIN
+5MIN
+2 MIN
+IMIN
+EMIN
+LMIN
+1 MIN
+7 MIN
+MIN
+1 MIN
+EV
+3 MIN
+NEW
+NEWYORKZNI NY
+mobile UK
+NEW
+ICO
+INC
+/WKND
+N/WKND
+N/WKND
+BEET
+6MIN
+MIN
+0.25 ENH
+0.25
+0.25
+0.25
+Account Name
+Number
+Called
+Item Date Time
+827 06/28 07:35P
+828 06/28 07:53P
+29 06/28 08:01
+30 06/28 08:02
+06/28 08:131
+833 06/28 08:14P
+34 06/28 08:17
+35 06/28 08:10
+836 06/28 08:50P
+837 06/28 11:04P
+839 06/28 H:95P
+341 06/29 10334
+Calls To
+STATESBORO GA
+INCOMING
+JEWYORKZNINY
+NCOMING
+NEWYORKZNIN
+NCOMING
+INCOMING
+EW YORK N
+EW YORK N
+INCOMING
+NY ZONE 1 NY
+JEW YORK NY
+- Continued
+Onty
+Used Rate Description
+3MIN
+6MIN
+EARLY EVENING N/WKND
+EARLY EVENING N/WKND
+L MIN
+5 MIN
+G NANKN
+1EVT
+1MIN
+3MIN
+EMIN
+2 MIN
+CALL WAITING
+ARLY EVENING NWKN
+EARLY EVENING N/WKND
+ALY EVENING NAWKI
+IN KN
+EARLY EVENING N/WKND
+MIN
+LEV
+7 MIN
+1 MIN
+1EVT
+1 MIN
+INLIMITEB NWKNE MIl
+INLIMI
+MESSAGE RETRIEVAL
+UNLIMITED
+N/W
+MIN
+1 MIN
+
+
+
+864 06/29 03:45P
+865
+866
+D6/
+/29
+03
+:46P
+06/29
+05:17P
+88882
+
+
+·U3980E
+
+8g
+88 8[558888
+NY
+ICLUDE
+NY
+NY ZONE 1 NY
+1MIN
+IMIN
+LEVT
+2 MIN
+1 MIN
+INLIMITEL
+CLUDE.
+IWKND MIN
+INUT
+INCLU
+IDED
+MINUTES
+MESSAGE RETRIEVAL
+
+
+Number
+Item Date Time
+Called
+5 06/30 02:03
+37 06/30 02:18
+38 06/30 02:48
+- Continued
+Onty
+Calls To
+INCOMING
+SANBARBARA CA
+INCOMING
+Used
+Rate Description
+EMIN
+CLE MINUTE
+3 MIN
+IMIN
+B9 06/30 02:53F
+00 0630 03:187
+891 06/30 06:13P
+892 06/30 06:14P
+NY ZONE 1 NY
+INCOMING
+1EVT
+SMIN
+BMIN
+1MIN
+LEVI
+2 MIN
+1EVT
+13 00/50 (
+1 0550 0750
+TZONEIN
+COMINI
+12MIN
+805 06/30 07:42P
+896 067
+30 07:43P
+NY ZONE 1 NY
+897 06/30 08:16P
+NY ZONE 1 NY
+898 06/30 09:29P
+899 07/01 10:13A
+900 07/01 10:19A
+10:284
+
+903 07/01 10:45A
+904 07/01 11:10A
+NEW YORK
+CHTAMST
+THS VI
+INCOMING
+BMIN
+2MIN
+1 MIN
+1EV
+2MIN
+lEVT
+4MIN
+1EVT
+2 MIN
+6MIN
+10 MIN
+1 MIN
+1EV
+3 MIN
+907 07/01 11:304
+908 07/01 12:23P
+909 07/01 12:31P
+10 07/01 01:00
+11 07/01 01:19
+NOOMING
+ZONE 1 NY
+mobile UK
+INCOMING
+SANBARBARA CA
+NY ZONE 1 NY
+NEW YORK N'
+912 07/01 01:24
+INCOMING
+3MIN
+3MIN
+1 MIN
+2MIN
+9MIN
+1 MIN
+IEVT
+AMIN
+MESSAGE RETRIEVAL
+ICLUDED MINUTE.
+ICLUDED MINUTE
+SSAGE RETRIEV
+CLUDED MINUTE
+CALL WAITING
+ICLUDED MINUTE,
+ARLY EVENING NAVKNO
+EARLY EVEN NOB
+EARLY EVENING N/KND
+NLIMITED N/WKND MIl
+ESSAGE RETRIEVA
+UNLIMITED N/WKND MIN
+MESSAGE RETRIEVA
+UNLIMITED NWKND MIN
+MESSAGE RETRIEVAL
+UNLIMIT
+UNLIMITED NAND MIN
+UNLIMITED N/WKND MIN
+/WKND MI
+JNLIMI
+UNLIMITED KNE MIN
+UNLIMITED N/WKND MIN
+0.25
+ENH DISC INT DI
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND MIN
+INLIMITED N/WKND MI
+INLIMITED NAWKND MI
+MESSAGE RETRIEVAL
+UNLIMITED NAWNB MIN
+0.75
+14 0
+06.38
+916 07/01 06:53P
+07:34P
+18 07/01 07:46
+919 07/01 07:53P
+20 07/02 12:42
+10702 085
+3230702 09:214
+924 07/02 09:29A
+25 07/02 09:31
+92
+927 07/02
+10:29A
+330 07/02 10:324
+931 07/02 10:45A
+932 07/02 11:34A
+933 07/02 11:35A
+99
+999
+B89NE
+155A
+54P
+:098
+NEW
+YORK NY
+INCOMING
+YORK MY
+CMPTNGRDND C
+NEW
+YORK NY
+CHTAMSTTHS VI
+EENS NY
+ORK NY
+NEW MORN
+ORK NY
+NEAN GERS CA
+CHTAMSTTHS VI
+CHTAMSTTHS VI
+INCOMING
+NEW
+NEW
+ORK NY
+ORK NY
+NEW
+YORK NY
+4MIN
+1 MIl
+1 MI
+1 MIN
+6 MIN
+2 MIN
+IEVT
+MIl
+3MIN
+2MIN
+SMIN
+3 MIN
+1 MIN
+IEVT
+1MIN
+2MIN
+1 MIN
+1EVT
+TMIN
+2MIN
+5
+MIN
+UNLIMIT
+UNLIMITED NAND MIN
+UNLIMİ
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND
+MIN
+INLIMITED NAWKND
+MESSAGE RETRIEVAL
+UNLIM
+LINE IM
+TED
+N/WKND
+M
+WKND MIN
+UNLIM
+ITED N/WKND MIN
+UNLIMITI
+UNLINITEB
+UNLIM
+UNLIMITED NOMIN
+MESSAGE RETRIEVAL
+INLIMI
+UNLIMITED N/WKND MIN
+MESSAGE RETRIEVA
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND MIN
+UNLIM
+ED
+UNLIM
+KAMIN
+UNLIM
+ED
+UNLIMITED
+KN
+MIN
+MIN
+UNLIMITED
+N/WKND MIN
+Account Name
+Number
+Item Date Time Called
+Calls To
+942 07/02 03 33P
+943 07/02 03:44P
+944 07/02 03:52P
+TOTAL VOICE USAGE FOR
+- Continued
+Onty
+Used Rate Description
+THIN
+UNITE NARMIN
+UNLITE NAN MIN
+1 MIN
+2 MIN
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND MIN
+ROAMER USAGE FOR
+Number
+Called
+Item Date Time
+1 06/09 11:11A
+3 06/09 11:50A
+4 06/09 12:07P
+0640913:298
+06/09 12:30P
+12:43P
+/09 01:03P
+06/09 01:23P
+06/09 01:47P
+06/09 01:49P
+06/09 01:50P
+06/D9 02:03P
+15
+06/09 02:16P
+06/09 02:26P
+06/09 02:56P
+18
+06/09 03:04P
+06/09 03:04P
+06/09 03:05P
+06/09 03:18P
+080090349p
+06/09
+04:13P
+06/09 04:16P
+26 06/09 04:21P
+TOTAL ROAMER USAGE FOR
+WHILE IN GUADELOUPE --
+Calls To
+Onty Used
+5 MIN
+2 MIN
+2 MIN
+Description
+INT'L ROAMING VOICE
+INTIL ROAMING VOICE
+INT'L ROAMING VOICE
+!!!!
+INTIL ROAMING VOICE
+NEW YORK N
+GUADELOUPE
+NCOMING
+NCOMING
+NEW ALBANY OH
+GUADELOUPE
+INCOMING
+NCOMING
+NCOMING
+COMING
+EW YORK N
+EWYORKZN3 N
+INCOMING
+2 MIN
+I WHILE IN GUADELOUPE --
+INT'L ROAMING VOICE
+NT'L ROAN
+ROA
+VOR
+INT'L
+ROAI
+INT'L
+ROA
+NT
+INT
+ROAL
+NT'L
+NT
+INT
+ROA
+22
+ROAI
+IOA
+RO
+INT'L
+ROAM
+INFL ROAMING
+NT'L ROAMING VOI
+IT'L ROAMING VOIC
+INT'L ROAMING VOICE
+ROAMER USAGE FOR
+Number
+Item Date Time
+Called
+1 06/09 10:21A
+2 06/09 10:35A
+TOTAL ROAMER USAGE FOR
+Calls To
+INCOMING
+INCOMING
+WHILE IN BR VIRIGIN I ---
+Onty Used
+Description
+1 MIN
+IT'L ROAMING VOIC
+IT'L ROAMING VOIC
+DATA USAGE FOR
+Item Date
+1 06/01
+2 06/02
+: 06/03
+, 06/04
+N07
+06/08
+06/09
+Onty Used
+2 KB
+10 KB
+Charge Description
+UNLIMITED DATA
+UNLIMITED DATA
+UNLIMITEB BATA
+UNLIMITED DATA
+NLIMITED DAT
+NUMITED DAT
+NLIMITED DAT
+LIMITED DAT
+
+14.61
+11.45
+2.38
+4.58
+2.38
+11.45
+8.87
+2.29
+259
+.58
+6.
+87
+16.03
+4.58
+2.2g
+2.29
+29
+4.
+29
+58
+4.18
+4.58
+148.85
+3.49
+3.4g
+6.98
+2000743.000005582
+
+
+* cingular
+DATA USAGE FOR
+Item Date
+10 06/09
+
+13 06/12
+14 06/13
+15 06/14
+19 06/15
+18 06/17
+9 06/18
+0 06/19
+06/20
+2 082
+24 06/23
+25 06/24
+27
+06/26
+6/2
+06/
+85/30
+07/01
+33 07/02
+TOTAL DATA USAGE FOR
+Qnty Used
+77 KB
+23 KB
+51 KB
+
+64 KE
+- Continued
+Charge Description
+INTERNATIONAL DATA
+UNLIMITEB BATA
+UNLIM
+UNLIN
+ED DATA
+UNLIN
+UNLIM
+EB BATA
+ITED DATA
+- D
+DATA
+UNLIN
+ITED DATA
+UNLIMITED DATA
+UNLIM
+ED DATA
+UNLIMITED DATA
+UNLI
+UNLIMIT İ
+ED DATA
+DATA
+UNLIMITED DATA
+UNLIMI
+UNLIMIT
+UNLIMITED DATA
+TEXT/MULTIMEDIA MSGS FOR
+Item Date
+Time
+Sent To/Revd From
+06002
+2:551
+0.264
+06/02
+16/02
+11:43A
+12:03P
+06/03
+05:51P
+100 L
+100 INCL
+100
+100 INCL
+
+
+
+2000743.0000055B2
+15G
+EN
+SENT
+
+
+Account Name
+TEXT /MULTIMEDIA MSGS FOR
+Item Date
+Time
+3B 06/12
+01:13P
+Sent To/Revd From
+
+03-128
+41 06/12
+10:29P
+
+D:46
+1:45
+44 06/13
+12:27A
+4606/13
+18:97A
+1:40
+3 06/
+49 06/13
+0:01
+11:16P
+11:21F
+11:21F
+11:23P
+1:24
+1:36
+Continued
+Charge Description
+100 INCL. MSGS SENT
+100 INEL: MESS SENT
+100 INCL. MSGS SENT
+100 INCE: MEGS SENT
+100 INCL. MSGS SENT
+100 INEL: MEGS SENT
+Lo0 INE. MS&S SENT
+100 INCL. MSGS SENT
+100 IN L: M583
+SEN*
+100 INCL. MSGS SENT
+100 INCL: M5GS SENT
+
+9888899=9₴7
+
+/24
+06/1
+06
+888888888888888888888888888888g
+9A
+
+
+TEXT/MULTIMEDIA MSGS FOR
+Item Date
+Time
+Sent To/Revd From
+105 06/15
+10:20P
+07 06/1
+1831P
+108 06/15
+10:32P
+.09 06/1.
+.10 06/1.
+10:37P
+11:09P
+112 06/13
+H18P
+113 06/15
+11:50P
+115 06
+115 06/18
+.:09
+9:27
+116 06/16
+117 06/16
+10:36A
+118 06/16
+1435A
+119 06/16
+01:03P
+• 06/
+01:28P
+12:40P
+122 06/16
+06:54P
+
+- Continued
+Charge Description
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+TEXE MESSAGES SENT
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+ITL TEXT MS
+TEXT MESSAGES
+TEXT
+MESSAGES
+TEXT MESSI
+TEXT MESS.
+NT
+TEXT MESS
+TEXT MESS
+00000
+.10
+0.25
+.10
+
+000000000000000000 C
+
+BдA20#2 A030200/220#/20//0/2/20///02/004/23
+Account Name
+
+TEXT/MULTIMEDIA MSGS FOR
+Item Date
+Time
+Sent To/Rcvd From
+172 06/21
+5 Ub/
+08:11P
+4 06/
+2-50
+175 06/22
+05:56A
+6:54
+01:02F
+9 0F
+180 06/23
+181 06/23
+182 06/24
+183 06/24
+_84 06/24
+L85 06/24
+186 06/24
+37 06/24
+.88 06/24
+19 06/2
+0 06/1
+02:00P
+03:29P
+04:33P
+05:09P
+04:10P
+04:11P
+16:06F
+06:13F
+06:20P
+07:53P
+08:17P
+08:18P
+08:24P
+• Continued
+Charge Description
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+TEXT MESSAGES SEME
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+SENT
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+8:18
+201202019#2212/2019#421#227021201208
+....
+88888888888888888888888888888888888888888888888g
+
+2000743.000005583
+
+
+* cingular
+TEXT/MULTIMEDIA MSGS FOR
+Item Date
+Time
+Sent To/Rcvd From
+239 06/29
+02:58P
+40 004
+16:50P
+242 06/29
+16:58P
+07:45P
+343 0B/28
+08:58P
+10:13P
+245 06/29
+10:14P
+346 06/29
+0:460
+1:15
+248 06/30
+05:38A
+05/38
+05:47A
+09:05A
+19:55/
+9-34
+06
+130
+16/30
+16/30
+09:47A
+09:47A
+10:19A
+10:42A
+257
+01:46P
+- Continued
+Charge Description
+TEXT MESSAGES SENT
+TEXT
+MESSAG
+TE
+XT
+MESSAG
+TEXE
+MESSAC
+TEXT MESSAG
+TEXT MESSA
+NT
+NT
+TEXT MESSAG
+TEXT MESSA
+TEXT MESSA
+TEXT MESSA
+TEXT MESSI
+TEXT MESSA
+MES
+10
+.10
+g88333g
+5058
+.10
+MULTIMEDIA MSG
+UI
+USAGE
+FOR
+E8SS00000 EPL0002
+Account Name
+
+SUMMARY OF CURRENT ACTIVITY
+FOR
+Monthly Service Charges
+Item Description
+Service Dates
+1 CALL WAITING
+06/03/06 - 07/02/06
+2 TEXT MESSAGING PLAN - 0 MSGS
+06/03/06 - 07/02/06
+3 CALLER ID
+06/03/06 - 07/02/06
+4 VOICEMAIL
+06/03/06 - 07/02/06
+5 GSM AMERICA LOCAL $29.99
+06/03/06 - 07/02/06
+6 DOMESTIC LONG DISTANCE FRM SERVICE AREA
+06/03/06 - 07/02/06
+7 CALL FORWARDING
+06/03/06 - 07/02/06
+B WORLDCONNECT
+06/03/06 - 07/02/06
+9 REGULATORY PROGRAM CHARGE
+06/03/06 - 07/02/06
+10 DETAIL BILLING
+06/03/06 - 07/02/06
+Total Monthly Service Charges
+Other Subscriber Charges
+Item
+Description
+1 MCTD SURCHARGE
+2 NY CITY UTILITY G.R. SUR
+3 STATE TELECOM EXCISE SURCHARGE
+1 FEDERAL UNIVERSAL SERVICE FUND SURCHARGE
+Total Other Subscriber Charges
+Subscriber Government Fees and Taxes
+Item Description
+1 SALES TAX
+2 ST WIRELESS COMM SURCHARGE
+3 LOCAL WIRELESS SURCHARGE
+Total Subscriber Government Fees and Taxes
+TOTAL CURRENT CHARGES FOR |
+29.99
+1.75
+39.74
+0.19
+0.65
+0.84
+0,95
+2.63
+2.88
+1.20
+2.36
+38.75
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/0c3c12741443f1b63573e7132e78c1c15e789040a3ff9e6534ea91b21df4b56b.receipt.json b/vision-fixhub/ds9-unparsed-06/0c3c12741443f1b63573e7132e78c1c15e789040a3ff9e6534ea91b21df4b56b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c2941c43a95edb79a051c940f4f64515a3dbbf03
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0c3c12741443f1b63573e7132e78c1c15e789040a3ff9e6534ea91b21df4b56b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -7843,
+  "dataset": "marble-joined",
+  "doc_id": "0c3c12741443f1b63573e7132e78c1c15e789040a3ff9e6534ea91b21df4b56b",
+  "engine": "marble-apple-vision",
+  "event_count": 84,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "e40165fcec65d0334d13e3f5b706dbbd5de46f72a8a6b14ecbd919852cbc4763",
+  "output_sha256": "25d9931db52ca37717b40e1eed5a79a0f09cbdecfe27ed136e643315500d1ca5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0c55efe9d84a1f5f2585e954708d981054b9b4b33f7c9e8f7ac8b3b45405f11d.md b/vision-fixhub/ds9-unparsed-06/0c55efe9d84a1f5f2585e954708d981054b9b4b33f7c9e8f7ac8b3b45405f11d.md
new file mode 100644
index 0000000000000000000000000000000000000000..4c0bde1f33a155a7a5c34917a6679001ad7b33cd
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0c55efe9d84a1f5f2585e954708d981054b9b4b33f7c9e8f7ac8b3b45405f11d.md
@@ -0,0 +1,191 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs
+V.
+UNITED STATES,
+Defendants
+JANE DOE #1 AND JANE DOE #2'S SUPPLEMENTAL REQUEST
+FOR PRODUCTION TO THE GOVERNMENT REGARDING NEW INFORMATION
+CONCERNING INVESTIGATION OF HANDLING OF EPSTEIN NON-
+PROSECUTION AGREEMENT
+COME NOW Jane Doe #1 and Jane Doe #2 ("the victims), by and through undersigned
+counsel, and request the defendant United States (hereinafter "the Government") to produce the
+original or best copy of the items listed herein below for inspection and/or copying, pursuant to
+the Court's Order (DE 99) directing discovery in this case, the Court's Order denying the
+Government's motion to dismiss and lifting stay of discovery (DE 189), and the Court's
+Omnibus Order (DE 190):
+BACKGROUND
+As the Government will recall, the victims have repeatedly asked the Government to
+stipulate to undisputed facts in this case. The Government has declined. Accordingly, the
+victims filed their Motion for Finding of Violations of the Crime Victims" Rights Act and
+Request for a Hearing on Appropriate Remedies (DE 48) (the victims" "summary judgment
+motion") along with a Motion to Have Their Facts Accepted Because of the Government's
+Failure to Contest Any of the Facts (DE 49).
+
+
+On September 26, 2011, the Court denied the victims' motion to have their facts accepted
+(DE 99 at 11). At the same time, however, the Court has ordered discovery to develop the
+factual record concerning the summary judgment motion (DE 99 at 11). The Court reserved
+ruling on the victims' motion for an order directing the Government not to suppress relevant
+evidence (DE 99 at 11).
+On September 28, 2011, the victims requested that the Government voluntarily provide
+documents concerning this case. The Government declined to provide even a single document.
+On October 3, 2011, the victims sent requests for production of documents relevant to
+this case.
+On November 8, 2011, the same day that the production of this discovery was due, rather
+than produce a single item of discovery or stipulate to a single fact, the Government filed a
+motion to dismiss the victims' case. The Government also filed an accompanying motion for a
+stay in this case.
+On November 8, 2011, the Government filed an ex parte, sealed motion to stay further
+discovery in this case. (DE 121). On November 9, 2011, the Court granted an ex parte, sealed
+order to stay. (DE 123).
+On December 5, 2011, the victims filed a response to Government's motion to stay. The
+victims strenuously objected to the Government's approach, alleging specifically that "delay
+appears to be the Government's motivation for filing the motion to dismiss." DE 129 at 2. The
+victims went on to recount the fact that the Government had waited three years to file a motion to
+dismiss, concluding that "as a practical matter, the Government's motion has had the desired
+effect of delay: While its motion remains pending, the victims have been effectively denied any
+ability to obtain discovery from the Government." DE 129 at 2-3. The victims also filed a
+
+
+protection motion to compel (DE 130) asking that the Court direct the Government to produce
+the requested materials.
+On January 24, 2012, the Government filed a reply in support of its motion to stay. DE
+140. In that reply, the Government represented that it would voluntarily be providing
+information to the victims:
+"IT]he United States has agreed to provide some information to [the
+victims] even during the pendency of the stay and is undertaking a search for that
+information." DE 140 at 4. Contrary to that representation, however, over the next seventeen
+months, the Government did not provide any information to the victims.
+A year after the Government's motion to dismiss, on December 6, 2012, the victims filed
+a Motion for a Prompt Ruling Denying the Government's Motion for a Stay (DE 179). The
+motion explained that it had been more than a year since the Government had filed its motion for
+a stay and that the Government's refusal to produce any information continues to effective block
+the victims from learning what happened during the Government's plea negotiations with the
+man who sexually abused them. The Government filed a response in opposition to that motion
+(DE 182).
+On February 25, 2013, counsel for the victims sent a request to the Government that, in
+view of that fact that its requested stay had never been granted, it should begin fulfilling its
+court-ordered discovery obligations:
+The victims believe that in view of fact that it has been more than fifteen
+months since the Government filed its motion for a stay of discovery and yet the
+Court has not granted that motion, the Court's discovery order is in effect and
+controlling. Accordingly, the victims respectfully request that by March 8, 2013,
+the Government produce all of the materials which is covered by the victims'
+liscovery requests. If the Government has not produced those materials b
+March 8, 2013, the victims may be forced to seek the intervention of the Court t
+order the Government to follow its obligations.
+If you would like to discuss this further, please feel free to set up a time
+where we can talk to you over the phone about all this. We are happy to work
+
+
+with you to try and minimize any unnecessary burden from your discovery
+obligations.
+E-mail from Paul G. Cassell & Bradley J. Edwards to Dexter Lee, et al., Counsel for the
+Government (February 25, 2013).
+The Government ignored the e-mail and did not respond in any way.
+Accordingly, in view of the Government recalcitrance and refusal to even discuss its
+discovery obligations, on March 14, 2013, the victims filed a motion to compel production of
+discovery materials. The Government did not respond to this motion.
+On June 1, 2013, the Court denied the Government's motion to dismiss. DE 189. That
+denial also lifted stay of discovery proceedings. DE 189 at 14 ("The stay of discovery pending
+ruling on the Government's motion to dismiss entered on November 8, 2011 [DE# 123] is also
+lifted."). The Court also entered an Omnibus Order (DE 190) that, among other things, granted
+the victim motion to compel (DE 130).
+SUPPLEMENTAL DISCOVERY REQUEST
+The victims now request one specific item of supplemental discovery relating to information
+that, in large measure, has come into existence since they filed the first request for production of
+documents on October 3, 2011:
+Jane Doe #1 and Jane Doe #2 have asked the Government to investigate their allegations that
+the U.S. Attorney's Office for the Southern District of Florida entered into a non-prosecution
+agreement with Jeffrey Epstein for sexual offenses committed against them and other victims
+based on considerations apart from the merits of the criminal case and also that violations of
+criminal law, rules of ethics, Justice Department policies (including policies on crime
+victims' rights), and the Crime Victims Rights Act occurred during the negotiations leading
+up to and surrounding the entry of the non-prosecution agreement. Please provide any
+information that the Government has developed concerning or relating to those allegations
+and the handling of the negotiations and consummation of the non-prosecution agreement,
+including any information developed by the Justice Department's Office of Professional
+Responsibility (OPR), the Federal Bureau of Investigation or other federal investigative
+entity, and any grand jury investigating these (or releated) allegations, including any grand
+jury meeting in the Southern District of Florida, the Middle District of Florida, the District of
+
+
+New Jersey, and/or the District of Columbia. For this one discovery request only, please
+include all relevant grand jury transcripts and evidence collected by the grand jury.
+DEFINITIONS
+For the purpose of construing the foregoing discovery requests, the following terms are
+defined:
+The term "documents" means and includes, without limitation, all writings of any kind,
+including the originals and all non-identical copies or drafts, whether different from the original
+by reason of any notation made on such copy or draft or otherwise including, without limitation,
+correspondence, memoranda, notes, diaries, statistics, letters, e-mails, electronic computer files,
+telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries
+pamphlets, books, prospectuses, interoffice communications, offers, notations of any sort of
+conversation, telephone calls, meetings or other communications, bulletins, printed matter,
+computer print-outs, teletypes, facsimiles, invoices, work sheets and all dratts, alterations,
+modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records
+or representations of any kind including, without limitation, photographs, charts, graphs,
+microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or
+electric records or representations of any kind including, without limitation, tapes, cassettes and
+dise recordings, and writings and printed material of every kind.
+The term "correspondence" means any tangible object that conveys information or
+memorializes information that was conveyed in tangible or oral form including, but not limited
+to, writings, letters, memoranda, reports, notes, e-mails, telephone logs, telephone billing
+information, telephone recordings, and interoffice communications.
+The term "Epstein's victims" means any person that the Government identified as a
+possible victim of a sex offense committed by Jeffrey Epstein, including Jane Doe #1, Jane Doe
+#2, all victims identified in attachment to the non-prosecution agreement entered into by Epstein,
+and another person that the Government investigated as a possible victim of Epstein's sex
+offenses.
+The term "Government" means the federal government, including all employees of and
+components of the United States Department of Justice (such as, the Office of the Attorney
+General, the Office of the Deputy Attorney General, the Criminal Divisions, the Office of
+Professional Responsibility, the Child Exploitation and Obscenity Section, the U.S. Attorney's
+Offices for the Southern District and Middle District of Florida, and the Federal Bureau of
+Investigation) and other federal government agencies with law enforcement responsibilities
+related to the Epstein case (such as the Internal Revenue Service). This request for production
+seeks all documents, correspondence, and other information held by all of these entities,
+including all employees of and components of the Justice Department that worked on or were in
+any way involved the Epstein investigation and/or that possess information relevant to the
+victims' claims.
+The term "including" means containing within the request, but not limiting the request.
+
+
+The term "witness statement" means any document or other recording in any form
+(including oral form) reflecting, recording, or otherwise memorializing a statement made or
+information conveyed by a potential witness, including for example FBI 302's.
+The term
+includes information collected by any law enforcement, prosecuting or government agency,
+including all federal, state, and local law enforcement agencies located in Washington, D.C., or
+PRIVILEGE LOG
+If you believe that any document, correspondence, or other information requested in this
+request is subject to a privilege and if you intend to assert that privilege, please provide a
+consistent with Local Rule 26.1(g), including a description a document that is
+consistent with Local Rule 26.1(g)(3)(B). Your privilege log should include the type of
+document, general subject matter of the document, date of the document, and author and
+addressee of the document or correspondence.
+REDUCING UNDUE BURDEN
+If you believe that complying with any of the foregoing requests would be unduly
+burdensonur please contact victims counsel - Bradley J. Edwards - to discuss ways to reduce
+DATED: June 24, 2013
+Respectfully Submitted,
+s/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS. FISTOS & LEHRMAN, P.L.
+Fort Lauderdale, Florida 33301
+and
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utah
+
+
+Salt Lake City. UT 84112
+Telephone:
+Facsimile:
+E-Mail:
+Attorneys for Jane Doe #1 and Jane Doe #2
diff --git a/vision-fixhub/ds9-unparsed-06/0c55efe9d84a1f5f2585e954708d981054b9b4b33f7c9e8f7ac8b3b45405f11d.receipt.json b/vision-fixhub/ds9-unparsed-06/0c55efe9d84a1f5f2585e954708d981054b9b4b33f7c9e8f7ac8b3b45405f11d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d17a200bdc10fdfc03ce66270e3e035dbdb7dfa6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0c55efe9d84a1f5f2585e954708d981054b9b4b33f7c9e8f7ac8b3b45405f11d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -84,
+  "dataset": "marble-joined",
+  "doc_id": "0c55efe9d84a1f5f2585e954708d981054b9b4b33f7c9e8f7ac8b3b45405f11d",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "ea4170192800fe9558d4f828e8908fd66f12ddf0606b4063027c1e714d4357b6",
+  "output_sha256": "9f9d00e7f8d284a20fd94092f4a96339145b75572915165db8559e033e97467a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0c73230100c902dc11c335305e6d4ca6f36719c9ce0ae52171ab1633268dcfcb.md b/vision-fixhub/ds9-unparsed-06/0c73230100c902dc11c335305e6d4ca6f36719c9ce0ae52171ab1633268dcfcb.md
new file mode 100644
index 0000000000000000000000000000000000000000..c4c1785238f24733e7e5cb1f03cf3a3ba8f813fb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0c73230100c902dc11c335305e6d4ca6f36719c9ce0ae52171ab1633268dcfcb.md
@@ -0,0 +1,93 @@
+From: "
+(USAFLS)"
+To:
+| (USAFLS)" <
+Subject: FW: Epstein
+Date: Fri, 06 Jul 2007 11:49:13 +0000
+Importance: Normal
+Good morning!
+Assistant U.S. Attorney
+----Original Message-...
+From:
+To:
+Cc:
+(USAFLS)
+Sent: Thursday, July 05, 2007 3:30 PM
+• (USAFLS);
+(USAFLS)
+Subject: RE: Epstein
+(USAFLS)
+Both the tone and substance of your email are totally inappropriate and, in combination with other matters in the
+past, it seriously calls your judgment into question.
+As you well know, the US Attorney has not even decided whether to go forward with a prosecution in this
+matter, thus you should have respected his position before engaging in plea negotiations.
+Despite being told these things, you prepared a pros memo and indictment that included a
+definitive date for indictment. It has come to my attention that you led the agents to believe that the indictment of
+this matter was a foregone conclusion and that our decision to put off that date and listen to the defense attorneys'
+concerns is indicative of the office having second thoughts about indicting. As you well knew, you were never
+given authorization by anyone to seek an indictment in this case.
+called me before, not after, the June 26th meeting. It was an informal discussion and not in the
+nature of an official plea offer but rather a feeling out by both sides as to what it might take to resolve the matter.
+You should also know that my
+discussion with
+was made with the US Attorney's full knowledge. Had
+expressed
+interest in pursuing this avenue further, I certainly would have raised it with all the interested individuals in this
+case, including you and the agents. In any event, I fail to see how a discussion that went nowhere has hurt our
+bargaining position. I am also quite confident that no one on the defense team believes that the federal
+investigation in this matter has been for show.
+
+
+Nor are your arguments that I have violated the Ashcroft memo, the USAM or any other policy well taken. As
+Chief of the Criminal Division, I am the person designated by the US Attorney to exercise appropriate discretion
+in deciding whether certain pleas are appropriate and consistent with the Ashcroft memo and the USAM -- not
+you.
+As for your statement that my concerns about this case hurting Project Safe Childhood are unfounded, I made it
+clear to you that those concerns were voiced by the US Attorney. Whether or not you are correct, matters of
+policy are always within his purview and any decisions in that area ultimately rest with him.
+Finally, you may not dictate the dates and people you will meet with about this or any other case. If the US
+Attorney or the First Assistant desire to meet with you, they will let you know. Nor will I direct Epstein's lawyers
+to communicate only with you. If you want to work major cases in the district you must understand and accept
+the fact that there is a chain of command - something you disregard with great regularity.
+-----Original Message-----
+From:
+(USAFLS)
+Sent: Wednesday, July 04, 2007 5:16 PM
+To:
+(USAFLS);
+Subject: FW: Epstein
+I (USAFLS)
+Hi
+- I am in trial, so I just got your message.
+First, it is inappropriate for you to enter into plea negotiations without consulting with me or the investigative
+agencies, and it is more inappropriate to make a plea offer that you know is completely unacceptable to the FBI,
+ICE, the victims, and me. These plea negotiations violate the Ashcroft memo, the U.S. Attorney's Manual, and all
+of the various iterations of the victims' rights legislation.
+. If you make it seem like the
+U.S. Attorney doesn't have faith in our investigation, Epstein has no incentive to make a deal.
+Second, your discussion makes it appear that my investigation is for "show" only and completely undermines my
+ability to deal with Epstein's attorneys directly. In my eight years of civil practice (before the six years that I have
+spent with this Office), I have litigated against attorneys far more formidable than
+and
+and have managed to convince the Eighth, Ninth, and Federal Circuits that my legislative
+interpretation was correct. Your concerns about this prosecution hurting the rest of the Project Safe Childhood
+Program are unfounded.
+My trial should end early next week. I would like to make a presentation to the U.S. Attorney, • I
+1 and
+you with our side of the investigation and a revised indictment. The presentation will address the points raised by
+Epstein's counsel and will convince you all of the strength of the case.
+In the meantime, please direct all communications from Epstein's counsel to me.
+Assistant U.S. Attorney
+
+
+---Original Message----
+From:
+(USAFLS)
+Sent: Tuesday, July 03, 2007 1:47 PM
+To:
+(USAFLS)
+Subject: Epstein
+, my blackberry is giving me trouble so i'm using J
+offender status may satisfy the usa. It was a non-starter for them
+I told lily that a state plea with jail time and sex
+Sent from my GoodLink synchronized handheld (www.good.com)
diff --git a/vision-fixhub/ds9-unparsed-06/0c73230100c902dc11c335305e6d4ca6f36719c9ce0ae52171ab1633268dcfcb.receipt.json b/vision-fixhub/ds9-unparsed-06/0c73230100c902dc11c335305e6d4ca6f36719c9ce0ae52171ab1633268dcfcb.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..22c47efdd8d8fdb38e32d58cb9e31262145b7ebe
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0c73230100c902dc11c335305e6d4ca6f36719c9ce0ae52171ab1633268dcfcb.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "0c73230100c902dc11c335305e6d4ca6f36719c9ce0ae52171ab1633268dcfcb",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "257645602231e191a5004c2ae08279a8710f8df84f47c8e5d24145208c001fd7",
+  "output_sha256": "dbc290cab1f815e3cb076f85c11263a2c6f1fa843954a100281ddbf066bb72bc",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0d09bf97c9c0e4a5473017770f3ad71c161869b7cad0c046e5342d8e6a3db333.md b/vision-fixhub/ds9-unparsed-06/0d09bf97c9c0e4a5473017770f3ad71c161869b7cad0c046e5342d8e6a3db333.md
new file mode 100644
index 0000000000000000000000000000000000000000..d7097f4316cec7ca4e45b4550f412589fcce5738
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0d09bf97c9c0e4a5473017770f3ad71c161869b7cad0c046e5342d8e6a3db333.md
@@ -0,0 +1,230 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOES #1 and #2
+Petitioners,
+UNITED STATES
+Respondent.
+RESPONDENT'S MOTION TO DISMISS
+Respondent, United States of America, by and through its undersigned counsel, files its Motion to
+Dismiss, pursuant to Rules 12(b)(6) and 41(b), Federal Rules of Civil Procedure, and states:
+I. LITIGATION HISTORY
+On July 7, 2008, plaintiff Jane Doe filed her "Emergency Victim's Petition for Enforcement of Crime
+Victim's Rights Act, 18 U.S.C. Section 3771." (D.E. 1). On the same day, this Court issued an Order directing
+the United States Attorney to file a response to the petition by 5:00 p.m., Wednesday, July 9, 2008. (D.E. 3).
+On July 9, 2008, the United States Attorney filed the "Government's Response to Victim's Emergency Petition
+for Enforcement of Crime Victim Rights Act, 18 U.S.C. § 3771." (D.E. 7). The Court held a hearing on July
+11,2008.
+On August 18, 2008, the Court held a status conference. On August 21, 2008, the Court ordered the
+Government to produce a copy of the Non-Prosecution Agreement between the United States Attorney and
+Jeffrey Epstein, and simultaneously entered a protective order prohibiting petitioners from disseminating the
+Non-Prosecution Agreement beyond designated individuals. (D.E. 26).
+On September 25, 2008, petitioners filed their motion to unseal document. (D.E. 28). On October 8,
+2008, the Government filed its response in opposition to petitioners' motion. (D.E. 29). Petitioners filed their
+reply on October 16, 2008. (D.E. 30). On February 12, 2009, the Court denied petitioners' motion to unseal
+document. (D.E. 36).
+Since February 12, 2009, there has been no activity in this case, other than the filing of a notice by
+petitioners' counsel of his change in firm affiliation. (D.E. 37).
+II. THIS CASE SHOULD BE DISMISSED FOR LACK OF PROSECUTION
+Under Fed.R.Civ.P. 41(b), "Ti]f the plaintiff fails to prosecute or to comply with these rules or a court
+order, a defendant may move to dismiss the action or any claim against it." In Goforth | Owens, 766 F.2d 1533
+(11 " Cir. 1985), the Eleventh Circuit observed that "[a] district court is authorized, on defendant's motion, to
+dismiss an action for failure to prosecute or to obey a court order or federal rule." Id. at 1535.
+A court's
+
+
+power to dismiss is an inherent aspect of its authority to enforce its orders and insure prompt disposition of
+lawsuits. Id., citing Link |. Wabash Railroad Co., 370 U.S. 626, 630-31 (1962), and Jones | Graham, 709
+F.2d 1457, 1458 (11 # Cir. 1983).
+Under Rule 41(b), the legal standard to be applied is "whether there is a
+clear record of delay or willful contempt and a finding that lesser sanctions would not suffice." 766 F.3d at 1535.
+Dismissal of a case with prejudice is considered a sanction of last resort, applicable only in extreme
+circumstances. Id.
+The Government believes the instant case should be dismissed because of the clear record of delay.
+After the initial filing on July 7, 2008, and the emergency hearing on July 11, 2008, the only notable activity in
+the case was petitioners' invocation of this Court's authority to obtain a copy of the Non-Prosecution Agreement.
+D.E. 19. The Government, pursuant to the Court's Order to Compel Production and Protective Order (D.E.
+26), provided a copy of the Agreement to petitioners. On September 25, 2008, petitioners attempted to have the
+Court "unseal" the Non-Prosecution Agreement (D.E. 28). The Government opposed the motion because the
+Non-Prosecution Agreement had never been filed with the Court, under seal or otherwise. D.E. 29. On
+February 12, 2009, the Court denied petitioners' motion (D.E. 36). The Court specifically addressed
+petitioners claim that the Non-Prosecution Agreement should be unsealed because the government had
+mischaracterized some of its provisions:
+If and when such alleged mischaracterizations become relevant to an issue to be
+decided by the Court, the parties will be given an opportunity to advance their
+positions and the Court will resolve the issue. If disclosure of the Agreement will
+be required for the Court to resolve the issue, appropriate disclosure will be
+ordered (D.E. 36 at 1-2).
+Since nothing has occurred in the instant case since the February 12, 2009 Order, presumably petitioners did not
+believe the mischaracterizations they claimed were made by the Government became relevant to any issue to be
+decided by the Court.
+On September 8, 2010, this Court entered its Order Closing Case (D.E. 38). The Court noted that "[a]n
+examination of the docket reveals that no activity has taken place in this case since April of 2009. In light of the
+underlying settlements between the vietims and Mr. Epstein, it is hereby ORDERED AND ADJUDGED that
+this case is CLOSED." (D.E. 38)(emphasis in original).
+It is not unreasonable to believe that the instant
+action under the Crime Victims Rights Act was auxiliary litigation to support petitioners claims against Jeffrey
+Epstein for money damages, particularly with regard to obtaining documents and information from the United
+States Attorney. Once petitioners' damage claims against Mr. Epstein had been resolved, there would be no
+
+
+need for this auxiliary litigation. The absence of any activity in the case since April 2009 supports the
+conclusion that vindicating the petitioners' rights under the CVRA was not the primary purpose of this case.
+"A district court has inherent authority to manage its own docket "so as to achieve the orderly and
+expeditious disposition of cases."" Equity Lifestyle Properties, Inc.. Florida Mowing and Landscape Service,
+Inc., 556 F.3d 1232, 1240 (11 « Cir. 2009)(citation omitted). Under Rule 41(b), the court may dismiss a claim
+if the plaintiff fails to prosecute it or comply with a court order. Id. "The power to invoke this sanction is
+necessary in order to prevent undue delays in the disposition of pending cases and to avoid congestion in the
+calendars of the District Court." Id., citing Durham Fla. East Coast Ry. Co., 385 F.2d 366, 367 (5 h Cir.
+1967). The instant case was filed as an emergency matter on July 7, 2008. Within two days, the government
+filed a written response to the emergency petition, and the Court held an emergency hearing four days after the
+emergency petition was filed. After this initial flurry of activity, predicated on petitioners' claim of an
+emergency, petitioners have done little to advance the litigation and seek resolution of their claims. El
+This
+clear record of delay provides ample basis for this Court to exercise its discretion and dismiss this case for lack
+of prosecution under Rule 41(b).
+III. PETITIONERS HAVE FAILED TO STATE A CLAIM UPON WHICH RELIEF CAN BE
+GRANTED UNDER 18 U.S.C. $ 3771(a)(2)
+The heart of petitioners' claim under the Crime Victims Rights Act (CVRA) is that the United States
+Attorney was legally obligated, under 18 U.S.C. § 3771(a)(5), to consult with them prior to entering into the
+Non-prosecution Agreement with Jeffrey Epstein. D.E. 1, 9 5. This claim should be dismissed under Rule
+12(b)(6) because it fails to state a claim upon which relief can be granted.
+In Bell Atlantic Corp.|. Twombly, 127 S.Ct. 1955 (2007), the Supreme Court observed that a plaintiff's
+obligation to provide the grounds of his entitlement to relief requires more than labels and conclusions, and a
+formulaic recitation of the elements of a cause of action will not do. Id. at 1964-65. Instead, factual
+allegations must be enough to raise a right to relief above the speculative level.
+"The standard is one of
+"plausible grounds to infer" Id. In Ashcroft Iqbal, 129 S.Ct. 1937 (2009), the Supreme Court noted that two
+working principles underlay its decision in Twombly : (1) the tenet that a court must accept as true all of the
+allegations contained in a complaint is inapplicable to legal conclusions; and (2) only a complaint that states a
+plausible claim for relief survives a motion to dismiss. Id. at 1949-50.
+The rights of crime victims are set forth in 18 U.S.C. § 3771(a), and include eight (8) specific rights.
+The petition alleges a violation of § 3771(a)(5), the right to consult with the attorney for the Government; §
+
+
+3771(a)(2), the right to reasonable, accurate, and timely notice of any public court proceeding; § 3771(a)(6), the
+right to full and timely restitution as provided in law; and notice of her rights under the CVRA.
+It is undisputed that no federal criminal charges have been filed against Jeffrey Epstein, in the U.S.
+District Court, Southern District of Florida, pertaining to the sexual abuse of minors. #
+The United States
+submits that, since there is no "case" pending in the Southern District of Florida against Epstein, or any "court
+proceeding" involving an offense against Jane Does 1 and 2, they cannot invoke any protections under 18 U.S.C.
+§ 3771(a)(2) and (5).
+Title 18, United States Code, § 3771(a)(5), provides that a crime victim has "[t]he reasonable right to
+confer with the attorney for the Government in the case." In its interpretation of a federal statute, the court
+assumes that "Congress used words in a statute as they are commonly and ordinarily understood," and reads the
+statute to give full effect to each of its provisions. United States |. DBB. Inc., 180 F.3d 1277, 1281 (11 " Cir.
+1999), citing United States . McLymont, 45 F3d 400, 401 (11 ' Cir. 1995). Section 3771(a)(5) grants a
+crime victim the reasonable right to confer with the attorney for the Government "in the case." The phrase "in
+the case" must be considered since there is a canon of statutory construction that "discourages courts from
+adopting a reading of a statute that renders any part of the statute mere surplusage." Bailey. United States,
+516 U.S. 137, 146 (1995)(noting that each word in a statute is intended to have "particular, nonsuperfluous
+meaning").
+Respondents submit that Congress intended the phrase "in the case" to mean a case filed in the district
+court.
+Federal criminal cases are filed in the United States district courts through the filing of a criminal
+complaint, Fed.R.Crim.P. 3, or indictment, Fed. R.Crim.P. 7. In each instance, an attorney representing the
+United States Government is required to sign the complaint or indictment. Thus, each criminal case filed in the
+district court has an attorney for the Government representing the sovereign United States.
+In contrast, § 3771(a)(1) provides that a crime victim "has the right to be reasonably protected from the
+accused." No mention is made about a case or court proceeding. Thus, Congress intended that this right
+attaches even before a case is filed in the district court. The absence of any mention of the attorney for the
+Government is also telling, since the case may still be in the investigative stage, and not yet been assigned an
+attorney. In such a case, the federal law enforcement agency would be responsible for providing the reasonable
+protection from the accused.
+Because there is not any case against Epstein in the Southern District of Florida, Jane Does 1 and 2 have
+no rights under § 3771(a)(5) to consult with the attorney for the Government. The United States Attorney's
+
+
+Office was under no obligation to consult with Jane Does 1 and 2 prior to concluding its Non-Prosecution
+Agreement with Epstein. For the same reason, Jane Doe's claim under § 3771(a)(2) also fails. There has
+been no "public court proceeding" against Epstein in the U.S. Distriet Court, Southern District of Florida, since
+no criminal case has been filed against him in the federal court. Consequently, there has been nothing for
+which the U.S. Attorney's Office was required to give notice to Jane Doe.
+A different provision in the CVRA, 18 U.S.C. § 3771(b), also supports the Government's interpretation of
+§ 3771(a)(5). Section 3771(b)(1) provides as follows:
+In any court proceeding involving an offense against a crime victim, the court
+shall ensure that the crime victim is afforded the rights described in subsection (a).
+Before making a determination described in subsection (a)(3), the court shall
+make every effort to permit the fullest attendance possible by the victim and shall
+consider reasonable alternatives to the exclusion of the victim from the criminal
+proceeding. The reasons for any decision denying relief under this chapter shall be
+clearly stated on the record.
+There is no "court proceeding" in this case because no federal criminal charges have been lodged against
+Jeffrey Epstein. Section 3771(b)(1) envisions that a district court presiding over a criminal trial will be
+responsible for ensuring that a crime victim will be afforded rights granted in § 3771(a).
+Section 3771(a)(3),
+which is expressly referenced in § 3771(b)(1), provides that a crime victim has
+The right not to be excluded from any such public court proceeding, unless the
+court, after receiving clear and convincing evidence, determines that testimony by
+the victim would be materially altered if the victim heard other testimony at that
+proceeding.
+This provision contemplates that, in the event a defendant invokes the rule of sequestration in Fed.R.Evid. 615,
+the court must consider the crime victim's rights under § 3771(a)(3), and can only exclude the victim from the
+proceeding if the court finds there is clear and convincing evidence that the victim's testimony would be
+materially altered if the victim was allowed to hear other testimony at the proceeding.
+By providing a difficult
+evidentiary standard which must be met before a victim's right to be present in the court proceeding can be
+denied, Congress was purposefully limiting a court's discretion in sequestering trial witnesses.
+In the instant case, there is no "court proceeding" since no federal criminal charges have been brought
+against Epstein. Therefore, § 3771(b)(1) is inapplicable. There is no role for this Court to fulfill under §
+3771(b)(1).
+The petition fails to state facts upon which the Court can find a plausible claim for relief exists.
+Accordingly, the petition should be dismissed for failure to state a claim upon which relief can be granted.
+IV. SEPARATION OF POWERS PRINCIPLES PRECLUDE THE COURT FROM GRANTING ANY
+RELIEF REGARDING THE NON-PROSECUTION AGREEMENT
+
+
+In the instant case, the Non-Prosecution Agreement between the Government and Jeffrey Epstein was
+concluded in September and October 2007, months before petitioners instituted their action. By entering into
+the Non-Prosecution Agreement, the United States was exercising its prosecutorial discretion as to the best
+means to resolve the allegations that Epstein had violated federal law by engaging in criminal sexual misconduct
+with minors.
+The Executive Branch enjoys exceedingly broad discretion in deciding how, or whether, to charge an
+individual. Bordenkircher | Hayes, 434 U.S. 357, 668 (1978)("In our system, so long as the prosecutor has
+probable cause to believe that the accused committed an offense defined by statute, the decision whether or not
+to prosecute, and what charge to file or bring before a grand jury, generally rests entirely in his discretion"
+(footnote omitted), and Nixon . United States, 418 U.S. 683, 693 (1974)(Executive Branch has exclusive
+authority and absolute discretion to decide whether to prosecute a case). Mindful of that principle, Congress
+expressly provided in the CVRA that, "InJothing in this chapter shall be construed to impair the prosecutorial
+discretion of the Attorney General or any officer under his direction." 18 U.S.C. § 3771(d)(6).
+Petitioners had no right under the CVRA to confer with the attorney for the Government, prior to the
+entry into the Non-Prosecution Agreement, because there was no existing case in the U.S. District Court.
+Moreover, even if they had the right to confer, they had no legal means to prevent the United States from
+negotiating the Agreement it ultimately entered into with Epstein. Unlike the situation in In Re Dean, 527 F.3d
+391 (5 " Cir. 2008), the Non-Prosecution Agreement did not come before any federal court for review and
+approval, nor was such action required. In Dean, if the district court believed that the victims had been denied
+their right to consult under § 3771(a)(5), it could reject the plea agreement and direct that the required
+consultation occur prior to the negotiation of any new plea agreement. In contrast, the Non-Prosecution
+Agreement never came before this court.
+Therefore, this Court is without authority to provide a remedy under §
+3771(b)(1).
+Respectfully submitted,
+WIFREDO A. FERRER
+UNITED STATES ATTORNEY
+
+
+Attorney for Respondent
+CERTIFICATE OF SERVICE
+, 2010, I electronically filed the foregoing document with the
+I HEREBY CERTIFY that on October
+Clerk of the Court using CM/ECF.
+SERVICE LIST
+Jane Does 1 and 2 . United States,
+Case No. 08-80736-CIV-MARRA/JOHNSON
+United States District Court, Southern District of Florida
+Brad Edwards, Esq.,
+The Law Offices of Brad Edwards & Associates, LLC
+2020 Hansioon Staat Quito 202
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+Attorneys for Petitioners
+E The emergency was based upon petitioners' belief that Jeffrey Epstein was engaged in plea
+negotiations with the United States Attorney's Office and that such negotiations would likely result in a
+disposition of the charges within the "next several days." D.E. 1, 9| 3. The petitioner noted that Epstein had
+already entered a plea of guilty on June 30, 2008, in the Circuit Court for Palm Beach County, Florida, to similar
+state offenses including solicitation of minors for prostitution. D.E. 1, 912.
+I2 "A district court may take judicial notice of public records within its files relating to the particular
+case before it or other related cases." Cash Inn of Dade, Inc. |. Metropolitan Dade County, 932 F.2d 1239,
+1243 (11 * Cir. 1991) (citations omitted). Additionally, in a Rule 12(b)(6) motion, a court may properly consider
+materials of which it has taken judicial notice.
diff --git a/vision-fixhub/ds9-unparsed-06/0d09bf97c9c0e4a5473017770f3ad71c161869b7cad0c046e5342d8e6a3db333.receipt.json b/vision-fixhub/ds9-unparsed-06/0d09bf97c9c0e4a5473017770f3ad71c161869b7cad0c046e5342d8e6a3db333.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..86cb3535a0968995db4428e0dfba3e60a135460f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0d09bf97c9c0e4a5473017770f3ad71c161869b7cad0c046e5342d8e6a3db333.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -84,
+  "dataset": "marble-joined",
+  "doc_id": "0d09bf97c9c0e4a5473017770f3ad71c161869b7cad0c046e5342d8e6a3db333",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "c17f759ac83ffbdc9db18369c195b739a474aaa481ae7d200d532a680c0b1941",
+  "output_sha256": "4f21afbbb5a90a4b844375f2114958913c749510373e17adc4d1fca047f3d178",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0d222b9e2cf222475e039bfece06c87fc19fc30b08bc686012d1a526968fe441.md b/vision-fixhub/ds9-unparsed-06/0d222b9e2cf222475e039bfece06c87fc19fc30b08bc686012d1a526968fe441.md
new file mode 100644
index 0000000000000000000000000000000000000000..a25feb1e53ae106d2e5cbf1f70b0ad53828ef8c2
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0d222b9e2cf222475e039bfece06c87fc19fc30b08bc686012d1a526968fe441.md
@@ -0,0 +1,3428 @@
+Questions or Changes?
+cingular.com
+• Toll Free 1/
+:
+611 from your wireless phone
+TTY users - 1 866 429-7TTY
+SUMMARY OF MONTHLY CHARGES FOR ACCOUNT
+Previous
+Balance
+412.46
+Payments
+Received
+-412.46
+Late Payment
+0.00
+Total
+Adjustments
+14.99
+Your billing cycle began on May 03, 2006 and ended on June 02, 2006
+Current Monthly Charges
+Monthly Service
+Monthly Usage
+Charges
+Credits
+Government Fees and Taxes
+Total Current Monthly Charges
+TOTAL AMOUNT - Due Upon Receipt
+Date of Invoice: June 04, 2006
+Balanci
+Forward
+14.99
+337.15
+555.19
+23.93
+-5.00
+40.15
+951.42
+Current Monthly
+Charges
+951.42
+Total
+Amount Due
+966.41
+966.41
+LATE PAYMENT CHARGE:
+A 1.5% LATE PAYMENT CHARGE PER MONTH MAY BE APPLIED FOR
+AMOUNTS UNPAID 20 DAYS AFTER THE DATE OF INVOICE
+(AK 0.875%, AR 0.085%, NE 1.33%, WI 1.00%).
+Note:
+=>
+We Print on
+Front and Back
+Account Name: JEFFREY E EPSTEIN
+r Fold and tear here 7
+Please Return This Portion With Your Payment.
+Use of service or payment of this invoice
+indicates agreement with the General Terms
+and Conditions for wireless service.
+us maticatty dedulled from the account on my enclosed check
+(see reverse - signature required).
+Date Due
+UPON RECEIPT
+Service
+Account
+Total
+Amount Due
+966.41
+Crackes secretse.
+Amount
+Paid
+#BWNHNGB
+#0000000
+2000317 02 AT 0.545 +AUTO T33 0602 10022.5.12.01.1200.0000
+CINGULAR WIRELESS - ATLYS
+PO BOX 6444
+CAROL STREAM, IL 60197-6444
+00000000000000000•0
+
+
+Recurring Electronic Fund Transfer (REFT): To enroll: sign below, check the REFT box on the reverse side and
+remit with this month's payment. Keep paying your bill until your statement indicates "Do Not Pay". REFT
+Agreement: I authorize my financial institution to deduct the amount of my monthly wireless phone bill from the
+account associated with the enclosed check and remit payment to Cingular Wireless. This authority will be effective
+until I notify Cingular Wireless to terminate it. I agree that I may be assessed a service charge (up to $20) or late.
+fee or both if a payment is returned by my bank. For more information visit cingular.com/myaccount or call 1
+Please keep a copy of the form below and this REFT Agreement for your records or retain a copy of the
+blank form from next month's invoice.
+Questions? We can help: Cingular Wireless appreciates your business and welcomes the opportunity to assist.
+mu. Visit our website at cinqular.com or contact Customer Care by dialing bll from vour wireless onone or .
+¿ Sabías que también ofrecemos servicio al cliente en tu idioma? Marca 611 desde tu teléfon
+inalambrico ó 1
+desde cualquier teléfono y oprime el *.
+Driving Wireless Safety: Your wireless phone gives you the freedom and flexibility to stay in touch when you
+travel, but don't let a phone call distract you from driving safely. Use hands-free device if allowed or required by
+law. Call Carefully, Arrive Safely.
+Processing Fees: When you pay by check, Cingular Wireless will present the check for payment by your bank
+electronically. Your bank account will be debited in the amount of the check and the transaction will appear on your
+bank statement. Your original check will be destroyed once processed, and you will not receive your cancelled
+check back. If we cannot post the transaction electronically, an image copy of your check will be presented for
+payment. For additional information, please call 1
+Accounts suspended for non-payment will be
+subject to a $25 reactivation fee per line and may be assessed a security deposit prior to reinstatement. Checks
+returned for non-sufficient funds will be charged up to a $30.00 fee.
+Local Tax: Local taxes are based on local government boundaries, the address information you provide for your
+account and/or your wireless telephone number. Please review the local tax chames on vour bill. If you believe
+there is an error in the local tax charge, please contact us immediately at 1|
+local or state laws may require you to follow special procedures when notifying us about a local tax dispute. You
+may also use the form below to notify us of any change to your taxing address. Thank you for your cooperation.
+Early Termination Fee (ETF): It you cancel service before your contract end date (including it you switch your
+wireless number to another carrier), you will be charged an Early Termination Fee of up to $200.
+One Time Checking Account Payment Authorization Agreement (for use with kiosk payment): I authorize
+Cingular Wireless to make this one-time bill payment by debiting my bank account. I can cancel authorization by
+contacting an in-store sales person. If my bank rejects a payment, I may be charged a return fee.
+Please Send Correspondence To:
+Cingular Wireless Next Generation Correspondence
+P.O. Box 68056
+Anaheim Hills, CA 92817-8056
+2000317.000002409.8
+Accoung Name and transier Financial Responsibless clearly and check the box on the reverse side. Please contact Customer Care to change the
+New Billing Address
+City
+State
+Zip
+Home Phone (
+_)
+Work Phone (.
+If your billing address is NOT your Tax Address, please enter the Tax Address below. (Multi-line accounts should attach a list of each wireless number
+and the respective Tax Address.)
+New Tax Address
+City
+Wireless Number (
+State
+Zip
+Recurring Electronic Fund Transfer (REFT) Enrollment. Please read the agreement on the top portion of this page, sign below and check
+he "REFT Registration" box on the reverse side
+Financial Account Holder Signature
+• + I do not wish to receive email notification of special oilers avalable to Cingular Wireless customers.
+
+
+* cingular
+ACCOUNT DETAILS
+Detail of Payments - Thank You!
+Item Description
+1 PAYMENT
+Total of Payments
+Date Applied/Reversed Payment Amount
+05/21/06
+-412.46
+Current Subscriber Monthly Charges and Credits
+Subscriber Number
+Subscriber Name
+Total Current Subscriber Monthly Charges and Credits
+Total Current Monthly Charges
+SUMMARY OF CURRENT ACTIVITY
+FOR
+Monthly Service Charges
+Item Description
+1 CALL WAITING
+2 TEXT MESSAGING PLAN - 0 MSGS
+3 CALLER ID
+4 VOICEMAIL
+5 DETAIL BILLING
+6 REGULATORY PROGRAM CHARGE
+7 CALL FORWARDING
+8 WORLDCONNECT
+9 THREE WAY CALLING
+10 BLACKBERRY $49.99
+11 NATIONAL PLAN $29.99
+Total Monthly Service Charges
+Service Dates
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+Monthly Usage Charges
+Item Description
+1 100 ADD'L ANYTME MIN
+2 UNLIMITED N/WKND MIN
+3 MESSAGE RETRIEVAL
+4 SPECIAL NUMBER CALLS
+Total Monthly Usage Charges
+Onty Used
+62 MIN
+2 MIN
+8 EVT
+16 MIN
+Other Subscriber Charges
+Item Description
+1 MCTD SURCHARGE
+2 NY CITY UTILITY G.R. SUR
+3 STATE TELECOM EXCISE SURCHARGE
+4 FEDERAL UNIVERSAL SERVICE FUND SURCHARGE
+Total Other Subscriber Charges
+-412.46
+-412.46
+829.34
+82.26
+39.82
+951.42
+951.42
+0.00
+0.00
+0.00
+0.00
+0.00
+1.75
+0.00
+0.00
+0.00
+49.99
+29,99
+81.73
+0.00
+0.00
+0.00
+0,00
+0.00
+0.16
+0.55
+0.71
+0.82
+2.24
+Account Name
+SUMMARY OF CURRENT ACTIVITY - CONTINUED
+Other Subscriber Credits
+Item Description
+1 $5 MONTHLY CREDIT
+Total Other Subscriber Credits
+Subscriber Government Fees and Taxes
+Item Description
+1 SALES TAX
+2 FEDERAL EXCISE TAX
+Total Subscriber Government Fees and Taxes
+TOTAL CURRENT CHARGES FOR L
+DETAIL OF CURRENT ACTIVITY
+Item Date Time Called
+1 05/03 12:03P
+30510501-395
+4 05/12 05:38P
+5 05/13 03:41P
+05-6 92:0
+19 05:05P 6
+8 05/19 05:14P 611
+Calls To
+INCOMING
+COMIN
+INCOMING
+COLUMBUS OH
+INCOMING
+Lust Care CL
+Cust Care CL
+COMIN
+COMIN
+05/23 01:20P
+5/24 11:39
+INCOMING
+DWAY C
+5/24 02:59
+14 05/24 08:25P
+COMIN
+COLUMBUS OH
+15 05/26 10:29A
+COLUMBUS OH
+16 05/26 10:34A
+COLUMBUS OH
+17 05/26 10:38A
+19 05/26 00:25
+05/26 01:291
+20 05/30 10:00A
+21 05/30 04:34P
+22 05/31 07:30A
+23 05/31 03:55P
+24 06/02 12:13P
+25 06/02 12:21P
+COLUMBUS OH
+COLUMBUS OH
+COLUMBUS OH
+INCOMING
+COLUMBUS OH
+COLUMBUS OH
+TOTAL VOICE USAGE FOR
+Onty
+Used Rate Description
+2 MIN
+100 ADD'L ANYTME
+: MIN
+1 MIN
+D ADD'L ANYTI
+2 MIN
+O ADD'L ANYTI
+4 MIN
+MIN
+100 ADD'L ANYTME MIN
+SSAGE RETRIEVA
+2 MIN
+8MIN
+ANYTME MIN
+8MIN
+SPECIAL NUMBER CALLS
+SPECIAL NUMBER CALLS
+4MIN
+14 MIN
+100 ABBL ANYTME MIN
+1 MIN
+EVT
+ЗMIN
+2 MIN
+88883¡88338
+TME
+ADD'E
+1EVT
+ADD'L
+1 MIN
+1EVT
+LEVY
+1MIN
+/AL
+O ADD'L ANYTME I
+ESSAGE RETRIEV
+100 ADD'L ANYTME MIN
+100 ADD'L ANYTME MIN
+MESSAGE RETRIEVAL
+
+-5.00
+-5.00
+2.42
+3.29
+82.26
+2000317.000002410
+
+
+2000317.
+L7.000002410
+* cingular
+SUMMARY OF CURRENT ACTIVITY
+FOR
+Detail of Subscriber Adjustments
+Item Description
+1 WARRANTY EXCH PROCESSING CHRG
+Total of Subscriber Adjustments
+Monthly Service Charges
+2 TEXT MESSAGING PLAN - 0 MSGS
+4 EARLY EVENING
+5 ENH DISCOUNT INTL DIAL
+6 MULTIMEDIA MESSAGING $2.99
+9 GSM AMERICA NATIONAL ADD-ON $149.99
+10 BLACKBERRYACCESSUNIT
+11 THREE WAY CALLING
+12 REGULATORY PROGRAM CHARGE
+13 VOICEDIAL SERVICE $3.99
+14 DETAIL BILLING
+15 DISCOUNTED INTERNATIONAL ROAMING
+Total Monthly Service Charges
+Monthly Usage Charges
+Item Description
+1 UNLIMITED DATA
+2 UNLIMITED N/WKND MIN
+6 EARLY EVENING NAKND
+7 CALL WAITING
+8 ENH DISC INT DL
+10 TEXT MESSAGES SENT
+11 INTL TEXT MSG
+12 INTERNATIONAL DATA
+13 DISCOUNT INT'L ROAM
+14 INTL ROAM TEXT MSG
+16 INT'L ROAMING VOICE
+Total Monthly Usage Charges
+1,024 Kilobytes (KB) = 1 Megabyte (MB)
+Date Applied
+05/09/06
+Service Dates
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+Used
+225
+1244
+g92"*
+SEE SE
+1 EVT
+1323 KB
+398 MIN
+43 EVT
+13 EVT
+58 MIN
+14.99
+14.99
+0.00
+4.99
+0.00
+0.00
+3.99
+2.99
+0.00
+0.00
+149.99
+49.99
+0.00
+1.75
+3.99
+0.00
+5,99
+223.68
+0.00
+0.00
+0.00
+0.00
+0.00
+0.00
+0.00
+3.67
+7.50
+4.50
+0.25
+25.73
+394.02
+21.50
+0.00
+98.02
+555.19
+Account Name
+SUMMARY OF CURRENT ACTIVITY - CONTINUED
+Other Subscriber Charges
+Item
+Description
+1 FEDERAL UNIVERSAL SERVICE FUND SURCHARGE
+2 MCTD SURCHARGE
+3 NY CITY UTILITY G.R. SUR
+4 STATE TELECOM EXCISE SURCHARGE
+Total Other Subscriber Charges
+Subscriber Government Fees and Taxes
+Item Description
+1 ROAMING TAX
+2 SALES TAX
+3 FEDERAL EXCISE TAX
+Total Subscriber Government Fees and Taxes
+TOTAL CURRENT CHARGES FOR
+DETAIL OF CURRENT ACTIVITY
+Called
+Item Date Time
+1 04/25 09:14P
+2 04/27 08:58A
+3 04/27 09:50A
+4 04/27 03:27P
+5 04/28 11:02A
+5 04/38 03:20P
+8 04/30 09:15A
+9 05/01 07:48A
+10 05/01 09:48A
+11 05/01 11:48A
+12 05/01 01:05P
+13 05/02 09-42A
+14
+05/02 09:42A
+15
+05/02 09:43A
+16 05/02 09:44A
+17 05/02 09:45A
+18 05/02 09:49A
+19
+0507 00-57A
+20 05/02 09:58A
+21 05/02 10:02A
+22 05/02 11:50A
+
+25
+05/03 07:59A
+26
+: 05/03 09:24A
+27 05/03 11:32A
+Calls To
+INCOMING
+NE WORK NY
+INCOMING
+INCOMING
+ZONE 1 NY
+NWYRCYZNO1 NY
+INCOMING
+NY ZONE 1 NY
+BOSTON MA
+INCOMING
+COMIN
+COMIN
+INCOMING
+NY ZONE 1 NY
+June 04,2006
+
+8.09
+1.27
+4.21
+19.03
+4.30
+18.38
+829.34
+Onty
+Used
+Rate Description
+1 MIN
+4 MIN
+1EVT
+HEAT
+1 MIN
+LEV
+I MIN
+1 MIN
+2 MIN
+2 MIN
+1 MIN
+2 MIN
+IMIN
+3MIN
+1 MIN
+EV
+3MIN
+1MIN
+RETRIEVAL
+CLUDED MINUTE
+ECCAGE RETRIEVA
+NESSED MINDE
+MESSAGE RETRIEVAL
+UNLIMITED NAMIN
+MESSAGE RETRIEVAL
+CLUBER MINUTE
+INUTE
+ELUDED MINUTES
+MESSAGE RETRIEVAL
+LUDED
+VINUTES
+VCLUDED MINUTE.
+CLUDED MINUTE
+MESSAGE RETRIEV
+RIEVAL
+INCLUBED MINUTES
+ESSAGE RETRIEV
+
+
+Called
+Item Date Time
+28 05/03 11:40A
+29
+05/03 01:55P
+05/03 01:57P
+0503 03:01P
+05/03 04:28P
+103
+85/03
+05:09P
+05:10P
+05/03 05:24P
+05/03 05:24P
+15103
+05:38P
+05/03 07:18P
+05/03 07:270
+05/03 08:52P
+41 0503 08:32
+42
+05/03
+08:54P
+43 05/03 08:56P
+44 05/04 08:07A
+8888
+
+9998KE
+WNNENE
+2ege89s9989
+
+
+Calls To
+INCOMING
+NCOMING
+COMING
+INCOMING
+INCOMING
+INCOMING
+NCOMING
+INCOMING
+INCOMING
+NY ZONE 1 NY
+INCOMING
+- Continued
+Onty
+Used
+Rate Description
+18MIN
+3 MIN
+1 MIN
+ELUDED MINUTES
+NCLUDED MINUT
+1 MIN
+MIN
+IMIN
+INCLUDED MINUTE
+INCLUDED MINUTEG
+1 MIN
+MIN
+INCLUBED MINUTES
+1 MIN
+EARLY EVENING N/WKND
+MIN
+IMIN
+ARLY EVENING NWH
+JING NAKA
+2 MIN
+2 MIN
+1EVT
+4 MIN
+CALL WAITING
+EARLY EVENING N/WKND
+NY ZONE 1 NY
+NEW YORK Y
+E
+1
+W
+RK
+mo
+TZ
+20
+01
+IG
+OMING
+YORK NY
+OMIN
+z23EE3 з8₴z
+Account Name
+Called
+Item Date Time
+88 05/04 07:26P
+Calls To
+91 05/04 09:22P
+92 05/04 09:32P
+03 05/04 09:34P
+94 05/05 08:07A
+95 05/05 0B:08A
+96 05/05 08:53A
+Y ZONE IN
+COMINI
+INCOMING
+INCOMING
+INCOMING
+• Continued
+Onty
+Used Rate Description
+1 MIN
+1EVT
+EARLY EVENING N/WKND
+MESSAGE RETRIEVAL
+2 MIN
+RLY EVENING NWKI
+1 MIN
+RLY EVENING NANKI
+1 MIN
+UNLIMITED N/WKND MIN
+MIN
+IMIN
+INLIMITEB NWKNE MI
+NUMI
+1 MIN
+1EVT
+MESSAGE RETRIEVAL
+1 MIN
+INC
+UDED MINU
+2 MIN
+
+55555EE55E58B5E5ED5EG555GEÜERSE©5EGEE EEE5555ñ§555§g89
+05/05 08:54A
+05/05
+09.32A
+5/05 10:18/
+5/05 11:23
+/05
+11:42A
+12:05P
+B15P
+COMING
+JEWARK N
+INCOMING
+INCOMING
+NE
+3 MIN
+1 MIN
+IMIN
+MIN
+1 MIN
+ZMIN
+1MIN
+INCLUDED MINUT
+NCLUDED MI
+INCLUDED M
+NCLUDED M
+CLUDED M
+222:
+2222
+223
+
+IT 2000002002
+
+
+Called
+Item Date Time
+151
+05/06 10:34A
+05/D6 10:35A
+/ОБ
+10:
+37A
+11:06A
+/ОБ
+11:06A
+/D6
+11:08A
+12:05P
+05/06
+12:22P
+05/06
+133Р
+05/06
+12:26P
+12:52P
+05/06
+01:04P
+05/06
+05,
+/ОБ
+01:05P
+01:41P
+05/06
+01-48P
+/D6
+U2:
+/06
+12
+129P
+Calls To
+INCOMING
+INCOMING
+NEW I
+YORK NY
+BROOKLYN NY
+NEWYORKZNI NY
+INCOMING
+ZONE 1 NY
+INCOMING
+NEWYORKZNI NY
+ZNO1 NY
+QUEENS NY
+- Continued
+Onty
+Used Rate Description
+1 MIN
+UNLIMITED
+WKND
+1 MIN
+UNLIMITED N/KND
+HING
+UNLIMITED NINE
+2 MIN
+UNLIMITED N/WKND
+VLIN
+KND
+VLIMI
+1 MIN
+1MIN
+MIN
+1 MIN
+KND
+UNLIMITED N/WKND
+UNLIMIT
+D N/WKND
+2 MIN
+2MIN
+UNLI
+UNLIN
+UNLIM
+UNLIMIT
+UNLIM
+UNL
+INLIMI
+INLIMITED NA
+!!!!
+Account Name
+- Continued
+Onty
+Item Date Time
+Calls To
+Rate Description
+
+LI
+2000317.000002411
+722
+un
+CA
+EEEEEEEE OZEE
+
+zzzzzzz
+
+Called
+215 05/07 06:36P
+216 05/07 07:06P
+13 85/07 10:28
+219 05/07 10:31P
+220 05/07 10:42P
+221 05/07 10:43P
+2285/0809:00
+5108 12:18/
+224 05/08 12:25P
+25 05/08 12:31F
+27 05/08 12:30P
+15108
+02:48P
+05/08
+
+-54P
+:08P
+=18P
+s8888888888888888888888388
+888
+
+QUEENS NY
+NEW YORK
+INCOMING
+JEW YORK NY
+DUEENS NY
+QUEENS NY
+QUEENS NY
+YORK NY
+oll Free Cu
+NCOMING
+QUEENS NY
+BROOKLYN NY
+INCOMING
+$2
+Used
+5MIN
+1 MIN
+2MIN
+4 MIN
+1 MIN
+1 MIN
+2 MIN
+1 MIN
+2 MIN
+44 MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+1
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND MIN
+UNLIMITED NWNB MIN
+DROP CALL CREDIT
+INLIMITEB NWINB MI
+INLIMIT
+DROP CALL CREDIT
+NELUBEB MINUTE:
+MINUT
+INCLUDED MI
+NCLUDED
+MINUT!
+NCLUDED MINUT
+ICLUDED MINUI
+MINUT
+INCLUDED M
+NCLUDED MIN
+NCLUDED MINUT
+00000
+
+
+Called
+Item Date Time
+279 05/09 01:14P
+BD 05/09 01:15P
+181 05/09 01:18F
+2B2 05/09 01:19P
+05/09 01:22P
+284 05/09 01:33P
+285 05/09 01:38P
+109 02:0
+2B8 05/09 02:43P
+B9 05/09 02:46
+90 05/09 02:47
+392 85/09 82 18P
+09 02:48P
+293 05/09 02:51P
+194 05/09 02:530
+195 05/09 02:565
+296 05/09 03:08P
+298 05/09 0392P
+209
+05/09
+03
+:19P
+05/09
+05:09
+:44P
+05/09
+14:331
+04:38P
+05/09
+04:40P
+05/09
+05/09 06
+05/09 06:42P
+05/09
+05/09
+881
+:43P
+:50P
+05/09
+07:41P
+05/09
+:41P
+15:09
+
+•450
+
+•18P
+7A
+
+2828
+:38A
+:42A
+88:
+89999
+- Continued
+Onty
+Calls To
+INCOMING
+Used
+Rate Description
+1MIN
+1EVT
+CALL WAITING
+NCOMING
+NCOMING
+INCOMING
+INCOMING
+NWYRC
+ZN03 NY
+QUEENS NY
+NEW
+CHTAMST
+AMSTTHS VI
+INCOMING
+NEW
+YORK NY
+INCOMING
+NCOMING
+-COMING
+3MIN
+1 MIN
+2MIN
+INCLUDED MINU
+ZMIN
+NCLU
+IMIN
+INCLU
+1MIN
+INCLU
+1 MIN
+1 MIN
+INCLU
+INCLU
+2MIN
+INCLU
+IMIN
+INCLU
+1 MIN
+INCLU
+1 MIN
+NCLU
+1 MIN
+NCLU
+1MIN
+INCLU
+1 MIN
+NCLU
+4MIN
+IMIN
+NCLUDED MIR
+QUEENS NY
+BROOKLYN NY
+1MIN
+INCLUDI
+INCOMING
+NCOMING
+QUE
+•ENS
+NCOMING
+NCOMING
+INCOMING
+LING
+INC
+INCOMING
+INCOMING
+RK NY
+INCOMING
+NEW
+NEW
+>>
+NEW
+INCOMING
+CHAMETTHE VI
+INCOMING
+NCOMING
+NEW
+(YORKZNI NY
+NEW YORK N
+USENS NI
+COMIN
+NCOMING
+NCOMING
+INCOMING
+INCOMING
+INCOMING
+22
+IEWYORKZNI N'
+IEW YORK N°
+NY ZONE 1 NY
+INC
+OMIN
+NEW
+NEW
+NEW
+>>
+1 MIN
+1 MIN
+TMIN
+2MIN
+1MIN
+13MIN
+2MIN
+1 MIN
+2MIN
+6MIN
+IMIN
+M
+222
+INCLU
+INCLU
+INCLU
+INCLU
+NCLU
+NCLU
+INCLU
+0000
+Account Name
+Called
+Item Date Time
+342 05/10 11:50A
+343 05/10 11:54A
+345 05/18 0116₽
+346 05/10 01:10P
+05/10 01:13P
+05/10 01-25P
+05/10 01:33P
+LO 01-43P
+05/10 01:45P
+353
+354
+85/10 02428
+05/10 022
+0 03:05
+357
+05/10 03:29P
+05/10 03:49P
+359 05/10 03:51P
+Calls To
+ICOMING
+ICOMING
+VE YORK I
+W YORK N
+NCOMING
+INCOMING
+NCOMING
+UK
+3:50
+mmmmmm
+
+88888
+iRK NY
+OMING
+OMING
+OMING
+ING
+- Continued
+Onty
+Used Rate Description
+2 MIN
+2MIN
+ICLUDED MINUT!
+MIT
+1 MIN
+MIN
+6MIN
+MIN
+1 MIN
+IMIN
+1 MIN
+IMIN
+1 MIN
+L MIN
+EMIN
+MILE
+22
+3 MIN
+MIN
+MIN
+1MIN
+CLUDED MINUTE
+INCLUDED MINUTI
+UDED MINU
+LUD:
+ED MINUT
+шші
+URED MINUTE
+MINUT
+CL
+UDED MINU
+'ES
+LUDED
+INCLUBEB MINUTE
+MINULES
+INCLUBEE
+0.25
+1.50
+0Ow
+MIN
+MIN
+22
+
+
+FD
+IKND
+
+
+UT
+55555555550555:
+1.50
+RK NY
+ДАДЯ
+
+
+2000317.000002412
+* cingular
+Called
+Item Date Time
+404
+405
+05/11 11:54A
+BEEEEEEEEI
+
+ANANAASS!
+:01P
+25P
+:29P
+48P
+:57P
+:38P
+39P
+05:47P
+06235
+06:36Р
+419
+420
+05/11
+06:39P
+05/11
+06:51P
+06:52P
+
+447
+05
+448
+09:15A
+09:16A
+
+11:07P
+
+
+460
+05/13 10:20A
+461 05/13 11:01A
+Calls To
+INCOMING
+NCOMING
+NEW YORK MY
+EW YORK N
+WYRCYZNOL N
+UEENS N°
+COMING
+INCOMING
+NEWYORKZNI NY
+≥z2™™Z
+33333
+YO
+YORK NY
+MING
+ORK NY
+IG
+MI
+ING
+OH
+- Continued
+Onty
+Used Rate Description
+3MIN
+2 MIN
+_ MIN
+2 MIN
+INCLUBEB MINUTES
+1 MIN
+L MIN
+3 MIN
+CLUBEB MINUTE
+MINUTE
+2MIN
+1 MIN
+13MIN
+INCLUBEB MINUTES
+3MIN
+IMIN
+1 MIN
+2 MIN
+4 MIN
+1 MIN
+BMIN
+1 MIN
+INCOMING
+INCOMING
+NCOMING
+QUEENS NY
+NCOMING
+COMING NY
+INCOMING
+NY ZONE 1 NY
+INCOMING
+IWYRCYZNO1 N°
+NEW YORK N°
+YORK N'
+NEW YORK N
+BROOKLYN NY
+BROOKLYN NY
+INCOMING
+INCOMING
+ROOKLYN N
+COMIN
+NEW YORKI
+NCOMING
+1 MIN
+MIN
+2 MIN
+MIN
+2 MIN
+• MIN
+1 MIN
+EMIN
+/T
+
+UNLI
+UNL
+..50
+KND
+MIN
+MES
+RETRI
+Account Name
+
+Item Date Time
+Called
+462 05/13 11:01A
+463 05/13 11:06A
+464 05/13 11:11A
+465 05/13 11:42A
+466 05/13 11:45A
+467 05/13 11:46A
+169 05/3 H59A
+470 05/13 11:52A
+472 05/3 HEA
+3 05/13 12:09
+4 05/13 12:21
+475 05/13 12:23P
+476 05/13 12:24P
+MAAAA
+482
+483
+05/13
+88
+:28P
+: 29P
+484฿
+05/13
+01:30P
+485
+05/13
+02:
+39398
+88888g 88
+88888
+88888
+
+- Continued
+Onty
+Calls To
+BOSTON MA
+Used
+Rate Description
+4 MIN
+UNLIMITED N/WKND MIN
+1 MIN
+UNLIMITED N/WKND MIN
+2 MIN
+NLIMITED _N/WKND M
+LEV
+ESSAGE RETRIEVA
+QUEENS NY
+NCOMING
+QUEENS NY
+RANDOLPH MA
+NCOMING
+NCOMING
+NY ZONE 1 NY
+NCOMING
+mobile FRA
+mobile FRA
+5 MIN
+UNLIMITED N/WKND MIN
+2 MIN
+UNLIMITED N/WKND MIN
+LEV
+CALL WAITING
+3MIN
+UNLIMITED N/WKND MIN
+EMIN
+UNLIMITEB NIW KNB MIN
+1 MIN
+UNLIMITED N/WKND MIN
+2 MIN
+INLIMITEB NWRNB ME
+3 MIN
+UNLIMITED NWKND MIN
+1 MIN
+UNLIMITED NKND MIN
+1 MIN
+UNLIMITED N/WKND MIN
+0.31 ENH DISC
+IMIN
+IMIN 0.31 ENH DISC INT DL
+NEWYORKZN3 NY
+1 MIN
+UNLIMITED N/WKND MIN
+2 MIN
+UNLIMITED N/WND MIN
+1 MIN
+UNLIMITED N/WKND MIN
+2 MIN
+UNLIMITED
+3 MIN
+UNLIMITED NAWNB MIN
+1EVT 1.50 411 INFO
+NY ZONE 1 NY
+ITED NWKND MIN
+2 MIN
+UNLIMITED N/WKND MIN
+INCOMING
+IN 150 ALIM
+IEVT
+ITED NWKND MIN
+CALL WAITING
+1 MIN
+1EV
+UNLIMITED
+MESSAGI
+NAKED MON
+EVAL
+3MIN
+UNLIMITED N/WKND MIN
+2 MIN
+4 MIN
+UNLIMITEB NA
+KND MIN
+INCOMING
+2 MIN
+UNLIMITED N/WKND MIN
+MI
+NEIMITED NAWKNBM
+INCOMING
+EMIN
+MESSAGED KNEA
+) MI
+1 MIN
+UNLIMITED N/WKND MIN
+UNESTED MIND MIN
+I MIN
+NCOMING
+UNLIMITED N/WKND MIN
+NCOMING
+MIN
+1 MIN
+. EVT
+3MIN
+INCOMING
+› MI
+NEWYORKZNI NY
+IMIN
+5 MIN
+1 MIN
+IEVT
+1MIN
+INCOMING
+3MIN
+FTLAUDERDL FL
+W PALMBEACH FL
+IMIN
+2 MIN
+1 MIN
+2 MIN
+INCOMING
+1 MIN
+1 MIN
+oll Free
+2 MIN
+NCOMING
+INCOMING
+1 MI
+1 MIN
+UNLIMITED
+N/W KND MIN
+MESSAG
+RE
+UNI IMIT
+NAN
+EVA
+KND MIN
+UNLIMIT
+UNLIMIT
+FEB
+WIND MEN
+UNLIMITED N/WKND MIN
+IMITED
+KND MIN
+MESSAGE
+EVAL
+UNLIMITED N/WKND MIN
+UNLIMITEB
+UNLIMIT
+NOW IN MEN
+UNLIMITED NA
+UNLIMITED
+UNUMITED
+UNLIMITED
+UNLIMIT
+N/W
+UNT
+ED
+KND
+D
+UNLIM
+UNLIMIT
+шш
+UNLIMITED
+22
+MIN
+N/WKND
+MIN
+0.31
+0.31
+150
+150
+
+
+Called
+Item Date Time
+516 05/14 10:05A
+517 05/14 10:06A
+318 05/14 29:97A
+520 05/14 12:35P
+521 05/14 12:43P
+522 05/14 12:66P
+523 05/14 12:48P
+524 05/14 12
+:48P
+525 05/14 12:49P
+526 0514 12:49P
+228 85/11 13:30P
+529 05/14 12:58P
+01:09P
+14
+30P
+14
+BRRRRERERE
+
+
+C59e0593
+- Continued
+Onty
+Calls To
+Used
+Rate Description
+FTLAUDERDL FL
+1 MIN
+UNLIMITED N/WKND MIN
+WPALMBEACH FL
+1 MIN
+UNLIMITED N/WKND MIN
+EW YORK N
+1 MIN
+UNLIMITED NAKND MI
+2 MIN
+ED NAVKNO
+NY ZONE 1 NY
+8MIN
+UNLIM
+TED N/WKND
+UNLIM
+1EVT
+TED
+MIN
+N/WKND MIN
+MESSAGE RETRIEVAL
+INCOMING
+2MIN
+UNLIMITED N/WKND MIN
+NCOMING
+1 MIN
+UNLIMITED
+NAWKND MIN
+QUEENS NY
+1 MIN
+UNLIMI
+NAWKND MIN
+INCOMING
+1 MIN
+UNLIMITED N/WKND MIN
+LEVT
+QUEENS NY
+2 MIN
+GALIMTEDNAWKND MIN
+DURHAM
+NC
+1 MIN
+UNLIMIT
+ED
+MIN
+UNLIM
+NEWYORKZNI NY
+11 MIN
+UNLIM
+ED
+UNLIM
+ED
+INCOMING
+UNLIM
+ED
+ZNI NY
+YORK NY
+mC
+NM
+ALAMO
+5 NM
+TSMOUTH N
+ALAMOS NM
+OMIN
+INCI
+OMING
+INCOMING
+YORK NY
+₴99902009
+K NT
+YORK NY
+••O
+›MING
+23
+N
+ORK NY
+MING
+988888888008008=08885588882888888
+INC
+OMING
+22000
+MIN
+000I
+ORA
+KZ
+N1
+ORK NY
+7mm mmm mI
+222
+Account Name
+
+Called
+Item Date Time
+577 05/15 08:25P
+578 05/15 08:32P
+08:50P
+10:10P
+/16 09:24A
+09:53A
+0:54A
+33P
+39P
+:41P
+:32P
+01:50P
+Calls To
+INCOMING
+NY ZONE 1 NY
+EW YORK N
+COMIN
+NEWYORKZN1 NY
+INCOMING
+INCOMING
+INCOMING
+NE
+NE
+YORKZNIN
+I YORK N'
+N YORK NY
+- Continued
+Onty
+Used Rate Description
+2 MIN
+EARLY EVENING N/WKND
+TIMIN
+EARLY EVENING N/WKND
+ARLY EVENING N/WKN
+iMi
+NLIMITED NAVKND MI
+1 MIN
+NELUBEB MINUTES
+D MINUTES
+1 MIN
+5 MIN
+18 MIN
+3MIN
+2 MIN
+1 MIN
+2 MIN
+2MIN
+2MIN
+2 MIN
+1MIN
+NELUBED MINUTE!
+CLUDED
+INCLUBED MINUTES
+TES
+28028898800g C2082988
+
+607
+05/16
+06:00P
+g82888g
+wwW
+59999
+BARTEE
+WUNA
+YORK NY
+NEW
+88 8888888
+
+W
+1M
+MIN
+1MIN
+MIN
+2 MIN
+1 MIN
+2 MIN
+MIN
+7 MIN
+14 MIN
+1 MIN
+2 MIN
+3 MIN
+IMIN
+1 MIN
+2 MIN
+MIN
+1 MIN
+4 MIN
+1 MIN
+L MIN
+MIN
+IMIN
+1EVT
+1 MIN
+-NNN
+1 MIN
+1 MIN
+1EVT
+1 MiN
+IMIN
+INCLUDED
+NELUB
+ED
+UNLIM
+UNLIM
+UNLIMM
+INC
+LUDED
+ED
+MESS
+NCLU
+INCLUDED
+N/WKNI
+SVAl
+NWKND
+NWKNO
+MIN
+CND
+2000317.000002413
+
+
+2000317.000002413
+Item Date Time
+Called
+Calls To
+637 05/17 04:36P
+04:38P
+640
+05/17
+642
+85/13
+06:32P
+643
+05/17
+858
+:33P
+:22P
+:16P
+644 05/17
+08:41P
+645 05/17
+09:43P
+04b
+43P
+641
+648
+44P
+650
+05/18
+:01P
+15/18
+09:30A
+09:47A
+Ba40a0033333333
+538666o6866
+
+00.00
+
+
+
+88
+EW YORK
+NEWYORKZNI NY
+INCOMING
+INCOMING
+HE TORKY
+JEW YORK NY
+COMING
+COMING
+NY ZONE 1 NY
+NCOMING
+JEW YORK NY
+- Continued
+Onty
+Used Rate Description
+1EVT
+MESSAGE RETRIEVAL
+1 MIN
+. MIR
+IMIN
+INCLUBEB MINUTES
+1 MIN
+ZML
+NCLUDED MINUTES
+EARLY EVENING N/WKND
+1 MIN
+EARLY EVENING N/WKND
+1 MIN
+1EV
+1 MIN
+EMIN
+3 MIN
+MIN
+1 MIN
+MIN
+UNLIMITED N/KND MIN
+UNLIMITED NANINB MIN
+UNLIMITED NAINB MIN
+UNLIMITED N/KND MIN
+INCLUDED
+MINUTES
+≥≥ ≥≥≥≥≥≥≥ ≥≥
+55
+·2·000
+INCOMING
+NEW
+YORK NY
+0.25
+Account Name
+Item Date Time Called
+696 05/18 09:10P
+697 05/18 09:21P
+698 05/18 09:23P
+99 05/18 09:56
+J0 05/18 10:25
+701 05/19 10:12A
+303 05/13 18:324
+303 05/19 10364
+J6 05/19 10:42
+719 10-43
+708 05/19 10:43A
+709 05/19 10:51A
+
+29209
+90999
+ä888888888 88888
+750
+05/19
+02
+2:42P
+Calls To
+IN ME NY
+INCOMING
+COMIN
+COMIN
+INCOMING
+INCOMING
+NEW YORK
+YORK
+NEW YO
+RK
+mobile UK
+INCOMING
+NCOMING
+INCOMING
+INCOMING
+PLAINSBORO N
+INCOMING
+INC
+- Continued
+Onty
+Used Rate Description
+MESSAGE RETRIEVAL
+UNLIMITED N/WKND MIN
+UNSATED NTKED MIN
+122
+22
+1 MIN
+3MIN
+8MIN
+7 MIN
+1 MIN
+2 MIN
+EMIN
+L MIL
+7 MIN
+7MIN
+LENT
+6MIN
+4 MIN
+2 MIN
+7 MIN
+2 MIN
+UNLIMITED N/WKND MIN
+NIMITED NAWKND MI
+NLIMITED NAWKND MI
+ICLUDED MINUTE!
+ROP CALL CREDI
+INCLUBEB MINUTES
+ALL WAITIN
+EI
+1 MIN
+FL
+0.25
+1 MIN
+L MIN
+1 MIN
+: MIN
+MIN
+SMIN
+MIN
+1EVT
+2 MIN
+3 MIN
+1 MIN
+
+≥≥≥z2≥2≥
+NEWYORKZNI NY
+INCOMING
+3MIN
+30C
+LU
+DROP
+0000
+9988
+83860
+D
+52
+D
+INC
+INC
+
+
+
+Called
+Item Date Time
+751 05/19 02:48P
+752 05/19 02:55P
+753 0519 83218
+755 05/19 03:34P
+56 05/19 04:11P
+57 05/19 05:50P
+758 05/19 06:52P
+759 05/19 06:54P
+760 05/19 06:55P
+/b1 05/19 00:5/P
+762 05/19 07:24P
+763 05/19 07:59P
+164 05/
+19 09:01P
+765 05/19 08:03P
+766 05/19 08:04P
+767 05/19 08:34P
+768 05/19 09:06P
+769 05/19 09:07P
+770
+05/19
+09:22P
+772
+9898
+:30%
+175
+779
+88g:
+12:02A
+10:04A
+10:07A
+7/8
+05/20
+10:08A
+179
+05
+10:36A
+780 05/20
+10:42A
+781 05/20
+11:34A
+782 05/20 11:35A
+78A 03/28 1 394
+785 85/28 13368
+787 05/20 01:08P
+B8 05/20 01:22
+00 05 00 01 22
+790 05/20 01:24P
+792 85/20 0139P
+793 05/20 02:02P
+706.
+02:04P
+705
+15/20 02:05
+389 83/20 03.5P
+798 05/20 06:26
+1gg 05/20 07:02F
+B00 05/20 07:03P
+B01 05/20 07:05P
+802 05/20 07:19P
+803 05/20 07:50P
+804 05/20 08:28P
+805 05/20
+09:15P
+806 05/20 09:17P
+05/20 09:48P
+B08 05/26 07:14P
+809 05/26 07:18P
+Calls To
+INCOMING
+INCOMING
+COMING
+COMING
+INCOMING
+NCOMING
+INCOMING
+NY ZONE 1 NY
+NCOMING
+NCOMING
+INCOMING
+NCOMING
+INCOMING
+PTWASHIGN NY
+INCOMING
+PTWASHIGN NY
+INCOMING
+NCOMING
+INCOMING
+NEI
+YORK NY
+NCOMING
+NEW
+YORK NY
+ORK MY
+INCOMING
+PORTSMOUTH N
+INCOMING
+NEW
+YORK NY
+lEW
+JEW YORK N
+INCOMING
+QUEENS
+NEWYORKZNI NY
+NEW YORK NO
+NEW
+NEWYORKZNI NY
+INCOMING
+NEW
+ORK NY
+- Continued
+Qnty
+Used
+Rate Description
+1MIN
+1 MIN
+1 MIN
+2 MIN
+INCLUDED
+1 MIN
+INCLUDED
+MINUT
+NUE MINUTES
+NCLUDED MINUTES
+MESSAGE RETRIEVAL
+EARLY EVENING N/KND
+EARLY EVENING NANKB
+EARLY EVENING N/WKND
+NEW
+YORK NY
+INCOMING
+INCOMING
+NEWYORK7N1 MY
+INCOMING
+INCOMING
+BROOKLYN NY
+1MIN
+2 MIN
+IMIN
+1EVT
+2MIN
+ZMIN
+4MIN
+1 MIN
+1 MIN
+1MIN
+2 MIN
+1 MIN
+IMIN
+lEVT
+9MIN
+1MIN
+2 MIN
+1 MIN
+6MIN
+7MIN
+10 MIN
+4 MIN
+1 MIN
+IEVT
+1 MIN
+2 MIN
+2MIN
+1MIN
+16V1
+1 MIN
+MI
+MIl
+4 MIN
+2 MIN
+4MIN
+1 MIN
+1 MIN
+2 MIN
+1 MIN
+3 MIN
+1 MIN
+2 MIN
+1 MIN
+3MIN
+1 MIN
+1EVT
+2MIN
+1 MIN
+2 MIN
+1MIN
+IEVT
+2MIN
+3MIN
+1MIN
+1 MIN
+1 MIN
+IMIN
+1 MIN
+1EVT
+1 MIN
+UNLIM
+UNLIM
+UNLIM
+INLIM
+Account Name
+
+Called
+Item Date Time
+810 05/26 07:18P
+811 05/26 07:19P
+813 0526 8721
+814 05/26 08:39P
+816 85/26 0842P
+05/26 08:42P
+817 05/26 08:42P
+89 0526 08 580
+820 05/26 08:57P
+2/20 08:59
+22 05/26 09:05
+823 05/26 10:34P
+05/26
+10:57P
+05/26 11:02P
+05/26 11:36P
+nivu
+129
+03:59P
+835
+05
+129
+04:01P
+
+·993g03
+
+
+88
+Nw
+Calls To
+BROOKLYN NY
+JEW YORK NY
+NCOMING
+BROOKLYN NY
+BROOKLYN NY
+INCOMING
+BROOKLYN NY
+NCOMING
+COMING
+ICOMING
+QUEENS NY
+INCOMING
+YORK NY
+mobile FRA
+MY ZONEY
+NWYRCYZNO1 NY
+TORK N
+ONE 1N
+INCOMING
+INCORE NOT NY
+CHTAMSTTHS VI
+INCOMING
+NCOMING
+mobile LTU
+QUEENS NY
+INCOMING
+COMIN
+COMIN
+NCOMING
+INCOMING
+INCOMING
+Free Cl
+YORK NY
+YORK NY
+- Continued
+Onty
+Used Rate Description
+1 MIN
+EARLY EVENING NANKND
+1 MIN
+EARLY EVENING NAWKND
+1 MIN
+3 MIN
+EARLY EVENING NIKNE
+EVENING
+N/WKND
+2 MIN
+EARLY EVENING N/WKND
+2 MIN
+EARLY EVENING
+NAW
+1 MIN
+EARLY EVENING
+1 MIN
+EARLY EVENING N/WKND
+1 MIN
+1MIN
+NWKND
+2 MIN
+EARLY EVENING N/WKND
+2 MIN
+CARLY EVENING
+NWKND
+2MIN
+UNLIMITED NAND MIN
+2MIN
+UNLIMITED NAVKND MIN
+2MIN
+UNLIMITED N
+MIN
+1 MIN
+UNLIMITED NAKND
+MIN
+5 MIN
+UNLIMITED N/
+2 MIN
+9 MIN
+UNLIMITED N/WKND MIN
+EMIN
+L MIN
+UNLIMITED NAVNB MIN
+LEVT
+UNLIMIT
+N/W
+MESSAGE RETRIEVAL
+2 MIN
+UNLIMIT
+1 MIN
+UNLIMI
+WIND M
+L MIN
+MES REE
+RETRIEVAL
+1 MIN
+L MIN
+0.31 ENH DISC
+5 MIN
+E CLUDED MNUTES
+2 MIN
+0.07 ENH DISC INT DL
+SMIN
+I MIN
+2MIN
+NWKND
+EARLY
+N/WKND
+1 MIN
+IMIN
+EARL
+EVENING
+mm
+VE
+NIN
+zZ
+ND
+1 MIN
+EARLY EVENING N/WKND
+EARLWAFINGG NIWKND
+37 MIN
+1 MIN
+EMIN
+2 MIN
+26 MIN
+2MIN
+1EVT
+6MIN
+3MIN
+EMIN
+19 MIN
+I MIN
+MIN
+4 MIN
+1 MIN
+9MIN
+1 MIN
+EVT
+MIN
+6MIN
+2 MIN
+3MIN
+1 MIN
+2 MIN
+1EVT
+EARLY EVENING NWKN
+EARLY EVENING N/WKND
+ARLY EVENING NIKN
+WKN
+IN CLUBED MINUTES
+MEC
+SAGE
+RETRIEVAL
+UD
+0.45
+DISC
+CLUDED
+INCLUDED
+NCLUDI
+FD
+INCLUBEB
+ICLUD
+25
+AGE
+RETRIEVAL
+JDED MINUTES
+NCLUDED MINUTES
+BEB
+MINUTES
+INCLUBEB
+I MINUTES
+MESSAGE RETRIEVAL
+0.31
+0.14
+1.35
+2000317.000002414
+
+
+Called
+Item Date Time
+867 05/30 08:01P
+Calls To
+868 05/30 09:30P
+869 05/31 07:43A
+870 05/31 08:16A
+05/31 09-27A
+05/31 10:17A
+05/31
+L 10:18A
+874
+05/31 10:18A
+875
+876
+10:58A
+05/31 2938Р
+877
+05/31 02:30P
+878 03/31 02:37P
+05/31
+L 02-41P
+880 05/31 03:33P
+881 05/31 04:13P
+INCOMING
+COMIN
+COMIN
+INCOMING
+NCOMING
+BROOKLYN NY
+INCOMING
+882 05/31 04:49P
+183 05/3
+06:41P
+884 05/31 08:39P
+TOTAL VOICE USAGE FOR
+NCOMING
+NCOMING
+- Continued
+Onty
+Used Rate Description
+1 MIN
+EARLY EVENING N/WKND
+1EVT
+MESSAGE RETRIEVAL
+VLIMITED NWKND MI
+ESSAGE RETRIEVI
+1 MIN
+ZMIN
+L MIN
+IMIN
+1 MIN
+ELUBEB M UTE
+ICLUDED MINUTE
+CHUNED MINITO
+.UDED MINUT!
+LUDED MINUTI
+6MIN
+1 MIN
+1 MIN
+2MIN
+LEVT
+1 MIN
+IEVT
+4 MIN
+1 MIN
+14 MIN
+INCLUBEB MINUTES
+SSAGE RETRIEV
+MESSAGE RETRIEVAL
+CLUDED MINUTE
+CLUDED MINUTE
+EARLY EVENING N/WKND
+ROAMER USAGE FOR
+Item Date Time
+Called
+1 05/21 04:56P
+05/22 03:52P
+05/22
+04:00P
+05/22 04:18P
+04:19P
+Calls To
+INCOMING
+INCOMING
+NCOMING
+NEWYORKZN1 NY
+WHILE IN FRANCE --.
+Onty Used
+1 MIN
+3 MIN
+I MIN
+1 MIN
+. MIN
+Description
+DISCOUNT
+DISCO
+DISC
+z22
+DISC
+ROAM
+OAM
+JAM
+OAM
+OAM
+!!!!!!!!!!!
+HAAAAAAAAAAAAmAHN@NMNHAHMAANM
+
+NENENER NN A N N NONCOCNE
+2000317.000002414
+INT
+INT
+OAI
+OA
+
+cocódo
+T GÓNGÓ HTHNHO GO NOO HN
+222
+Account Name
+ROAMER USAGE FOR
+Item Date Time Called
+37 05/23 08:05P
+38 05/23 08:54P
+20 0323 09338
+41 05/23 10:15P
+12 05/23 10:21P
+43 05/23 10:26P
+4 05/23 10:33
+5 05/23 10:39
+46 05/23 11:17P
+43 05/34 12:07₽
+TOTAL ROAMER USAGE FOR
+WHILE IN FRANCE .. - Cont.
+Calls To
+INCOMING
+FRANCE
+NCOMING
+NCOMING
+INCOMING
+ICOMIN
+ICOMINI
+INCOMING
+INCOMING
+INCOMING
+FRANCE
+INCOMING
+WHILE IN FRANCE ---
+Onty Used
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+MIN
+1 MIN
+1 MIN
+1 MIN
+4 MIN
+MIN
+IMIN
+Description
+DISCOUNT INT'L ROAM
+DISCOUNT INT'L ROAM
+OUNT
+INT
+. ROAM
+DISCOUNT INT'L ROAM
+DISCOUNT
+DISCOUNT
+INT'L
+RO
+INT 'L ROAM
+DISCOUNT INT'
+'L ROAM
+DISCOUNT
+DISCOUNT
+INT
+ROAM
+INT'L ROAM
+DISCOUNT
+INT'L ROAM
+DISCOUNT
+INT'LROAM
+ROAMER USAGE FOR
+Item Date Time
+Called
+05/22 12:32P
+12:39P
+:27P
+:40P
+:26P
+Calls To
+FRANCE
+FRANCE
+OMING
+NCOMING
+NWYRCYZN01 NY
+RANC
+FRANC
+шш
+FRANCE
+'OMING
+ш
+UX
+UUUUUUUUUUU
+cobedetey
+ORK NY
+INCOMIN
+
+
+000
+INCO
+MIN
+NE
+YORK NY
+COMING
+ING
+OMING
+INCO
+ING
+OMING
+NE'
+MING
+ORK NY
+22
+MIN
+OMING
+WHILE IN FRANCE --
+Onty Used
+Description
+1 MIN
+DISCOUNT INT'L ROAM
+MI
+22222
+OAM
+MIN
+,MIN
+, MIN
+i MIN
+1 MIN
+1 MIN
+3 MIN
+L MIN
+HHNHNNA N ỆN NƯAAAAMG 1H
+Ш!Ш!
+2222
+MIN
+MIN
+_ MIN
+MIN
+
+INT'L
+000
+272
+00
+FE
+JU
+•••00
+NF
+NT
+JOUUL
+INT
+INT
+222
+INT
+000
+,22
+222
+--L-
+KKCKKKKOKKCKUCKKCKCCCCCCCCOO
+FE
+O0000C
+J une 04, 2006
+
+oom
+96
+.98
+1.98
+81.18
+11.17
+2.97
+99
+.99
+BAM
+OAM
+4.95
+.99
+.99
+.99
+1.99
+A.I-
+)AM
+DAM
+M
+
+
+ROAMER USAGE FOR
+Called
+Item Date Time
+47 05/25 03:27P
+48 05/25 03:31P
+50
+58 83/25 83:00P
+51
+05/25 04:21P
+15/25 04:24F
+05/25 04:562
+54 05/25 04:57P
+55 05/25 05:00P
+56 05/25 05:37P
+02/25 03:41P
+58 05/25 06:16P
+59 05/25 06:19P
+60 05/25 06:22P
+61
+0525 06:33P
+62
+05/25 06:47P
+63 05/25 07:00P
+64 05/25 07:01P
+98080
+05/25 07:20P
+0Z
+05/23 8733P
+07:238
+85/25
+05/25 07:43P
+05/25
+:03P
+05/25
+22P
+08:57P
+05/25 09:03P
+05
+05
+
+11:28A
+11:36A
+42A
+01:23P
+01:31P
+01:47P
+05/26 01:54P
+05/26
+01:59P
+TOTAL ROAMER USAGE FOR
+Calls To
+INCOMING
+INCOMING
+COMING
+COMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+NEWYORKZN1 NY
+INCOMING
+INCOMING
+NCOMING
+INCOMING
+INCOMING
+NEW
+YORK NY
+WHILE IN FRANCE ... - Cont.
+Onty Used
+1 MIN
+Description
+DISCOUNT INT'L ROAM
+DISCOUNT INT'L ROAM
+BISCOUNT
+• ROAM
+[ROAM
+L ROAM
+ROAM
+ROAM
+ROAM
+ROAM
+FRANCE
+222
+OMIN
+881
+G00O
+INCOMING
+FRANCE
+NCOMING
+INCOMING
+NCOMING
+FRANCE
+INCOMING
+INCOMING
+INCOMING
+NCOMING
+INCOMING
+INCOMING
+NCOMING
+NCOMING
+INCOMING
+INCOMING
+INCOMING
+WHILE IN FRANCE -
+ROAM
+ROAM
+DISCOUNT
+ROAM
+MSG RETRIEVAL
+ISCOUNT
+OUNT
+INT'L ROAM
+INT'L ROAM
+INT'L ROAM
+DISCOUNT INT'L ROAM
+ROOMS RETRIEVAL
+I MSG RETRIEVAL
+OAM
+CO
+'000
+
+C
+.98
+2.97
+2.97
+98
+1.98
+2.97
+2.97
+4.95
+HOOON
+pig ipig ie
+Nº90900
+egginges
+OOH!
+POONO HOA000000
+Account Name
+ROAMER USAGE FOR
+Item Date Time Called
+1 05/26 05:47P
+TOTAL ROAMER USAGE FOR
+WHILE IN UK --
+Calls To
+INCOMING
+Onty Used Description
+ROAMER USAGE FOR
+Item Date Time
+Called
+2 05/21 12:008
+3 05/21 12:11P
+121 13:20P
+12 0229P
+02:29P
+Calls To
+WHILE IN FRANCE --
+Onty Used
+IMIN
+2 MIN
+1 MIN
+Description
+BISCOUNT INTERGAN
+INT
+DISCOUNT INTL ROAM
+L MIN
+MIN
+2 MIN
+DISCOUNT INT'L ROAM
+DISCOUNT
+DISCOUNT INT'L ROAM
+DISCOUNT INT'L
+BISCOUNT INTL ROAM
+DISCOUNT INT'L ROAM
+BISCOUNT INTLAGAM
+
+1.99
+99
+1.98
+HOWO00O
+g3º8·º739ů8ª€g29ª99989₴đ
+KZN1
+2E82222ENNOUONON
+ORK NY
+AN
+
+EEEEEEEEEEEEECEES
+
+
+
+
+ONOOHOOOOOONOHOWGOOONGOONN.
+gig igig is igig ig gig ig gigis gis gig is sig is isin is isig isis ig isin ig inis
+2000317.000002415
+
+
+ROAMER USAGE FOR
+Called
+Item Date Time
+58 05/26 03:18P
+59 05/26 03:19P
+SAPPOPS
+85/26 03396
+05/26 03:29P
+05/26
+05/26
+03:36P
+04:20P
+85728 04358
+67
+05/26 04:47P
+68 05/26 04:48P
+69 05/26 04:52P
+70 85/26 04:57P
+05:13P
+05/26 05:26P
+120
+05:32P
+05:35P
+05/26 05:36P
+83/26 08:58P
+(26 06:30P
+78 05/26 06:33P
+TOTAL ROAMER USAGE FOR
+WHILE IN FRANCE ... - Cont.
+Calls To
+FRANCE
+FRANCE
+RANC
+COMIN
+BROOKLYN NY
+NCOMING
+INCOMING
+QUEENS N°
+BROOKLYN NY
+BROOKLYN NY
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+1 MIN
+WHILE IN FRANCE -..
+Onty Used
+1 MIN
+1 MIN
+1 MIN
+1 MI
+1 MIN
+Description
+DISCOUNT INT'L ROAM
+DISCOUNT INT'L ROAM
+BISCOUNT INTE
+ROAM
+ROAM
+DISCOUNT
+ROAM
+MIN
+3 MIN
+MIN
+MIN
+MIN
+EV
+MIN
+22
+MIN
+DISCOU
+)ISCOUN
+DISCOUNT
+DISCOI
+RO
+ROAM
+DISCO
+ROAM MSC
+DISCOUNT
+OC
+SCOUNT
+DISCOUNT
+DISCOUNT
+ROAM
+INT'
+ROAM
+ROAM
+INTL
+ROAM
+INT 1
+DISCOUNT INT'L ROAM
+DISCOUNT
+INT'L
+ROAM
+ROAMER USAGE FOR
+Item Date Time
+Called
+1 05/27 12:31P
+05/27 12:32P
+05/27 12:35P
+Calls To
+IN 2 I NY
+INCOMING
+WHILE IN TURKS&CAICOS --
+Onty Used
+1 MIN
+3 MIN
+1 MIN
+Description
+INTL ROAMING VOICE
+INT'L
+ROAMING VOI
+INT'L
+OAMING
+VO
+F
+NT'L
+NT'I
+ROAMING
+1 8934
+
+3205128 05338
+23 05/29 09:46A
+3 MIN
+1 MIN
+ROAMING
+1 MIN
+1EVT
+I MIN
+INCOMING
+INCOMING
+NEWYORKZNI NY
+INCOMING
+PROVIDNCLS TO
+IEW YORK NY
+INCOMING
+EW YORK NI
+NEW YORK N
+: MIN
+MIN
+NT'L
+INT"
+ROAMING VOIC
+ROAMING
+mm
+INT'L ROAMING VOICE
+NEL ROAMIN
+ROAMING
+COMIN
+COMIN
+CERTER
+VOlO
+INT'L ROAMING
+VOIC
+mi
+ROAMING
+INTERNING
+TY ROAMIN
+ROAM MSG RETRIEVAL
+INCOMING
+MIN
+INCOMING
+. MIl
+LEVE
+ROAM
+ROAMING VOICE
+MSG RETRIEVAL
+WHILE IN TURKS&CAICOS -
+SIDZ00000 LTED0DZ
+26 05/29 11:22A
+TOTAL ROAMER USAGE FOR
+1.98
+297
+4.95
+1.98
+ON
+1.
+id igis
+.99
+.99
+0.
+143.55
+1.69
+1:69
+69
+—HWW
+1.
+98.02
+Account Name
+ROAMER USAGE FOR
+Item Date Time Called
+1 05/26 06:15P
+2 05/26 06:25P
+3 05/26 06.75P
+40L14
+05/26 07:04P
+15/26 07:46P
+05/26 07:478
+8 05/26 08 13P
+TOTAL ROAMER USAGE FOR
+Calls To
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+COMIN
+COMIN
+NCOMING
+COMING
+WHILE IN IRELAND --
+WHILE IN IRELAND --
+Onty Used
+Description
+1 MIN
+DISCOUNT INT'L ROAM
+1 MIN
+DISCOUNT INT'L ROAM
+ISCOUNT INT'L ROA
+SCOUNT INT'L ROA
+1 MIN
+DISCOUNT INT'L ROAM
+INT INT'L ROA
+1 MIN
+I MIN
+DISCOUNT INT'L ROAM
+DISCOUNT INT'L ROAM
+DATA USAGE FOR
+Item Date
+1 04/25
+28
+Onty Used
+22 KB
+KB
+KB
+KB
+BEGEONNE
+30
+TOTA
+ATA USAGE
+FOR
+Charge Description
+UNLIMITED DATA
+UNEMITED BATA
+UNLIMITED DATA
+NLIMITED DAU
+VLIMITED DAT
+UNLIMITED DATA
+UNLIMITED BATA
+UNLIMITEB BATA
+UNLIMITED DATA
+INTED BAT
+UNLIMITED DATA
+NUTE BAT
+UNLIMITED DATA
+INTERNATIONAL BATA
+INTER NATIONAL BATA
+INTERNATIONAL DATA
+ITERNATIONAL DAT
+LIMITED DAT
+UNLIMITED DATA
+NTERNATONAT DATA
+INTERNATIONAL DATA
+UNEMTEB BATA
+UNLIMITED DATA
+UNLIMITED BATA
+TEXT/MULTIMEDIA MSGS FOR
+Item Date
+500wAUEWNH
+126
+Time
+Sent To/Revd From
+01:44P
+:OSP
+2893
+Charge Description
+100 INCL. MSGS SENT
+100 INEL: MAGS SENT
+100 INCL. MSGS SENT
+100 INEL: MEGS SENT
+100 INCL. MSGS SENT
+100 INCL: MESS SENT
+100 INCL. MSGS SENT
+June 04,2006
+
+8.98
+1.90
+0.90
+8.91
+25.73
+
+
+Account Name
+J une 04, 2006
+
+TEXT/MULTIMEDIA MSGS FOR
+Item Date
+Time
+Sent To/Revd From
+11 05/04
+07:29P
+05/04
+87328
+: 05/04
+1540
+89888
+9:36P
+05/05
+05/0-
+05/08
+05/06
+05V0e
+05/0€
+05/06
+12:17A
+03:14P
+08:12P
+09:52P
+12:03P
+05:02P
+01
+/08
+/D8
+- Continued
+Charge Description
+100 INCL. MSGS SENT
+LO NEL NS SENE
+100 INCL. MSGS SENT
+100 INEL M58S SENT
+SENT
+SENT
+100 INCL. MSGS
+SENT
+100 INCL. M5GS
+SENT
+100 INCL. MSGS
+SENT
+100 INCL. MSGS SENT
+00 INCL. MSG.
+0O INCL. MSG
+SENT
+100 INCL. MSGS SENT
+100 INCL
+MSG.
+100 INCL
+.MSG
+SENT
+100 INCL. MSGS
+CElIT
+š3š8§8§8
+
+§š33š33š8§8883š8838
+#0222*1217/2/220701071222100
+TEXT/MULTIMEDIA MSGS FOR
+Item Date
+Time
+78 05/14
+02:48P
+Sent To/Revd From
+30 05/4
+0331P
+81 05/14
+03:53P
+04:11P
+0514
+05/14
+02:33P
+08:39P
+09:53P
+10:00P
+10:04P
+10:07P
+10:10P
+83:59P
+- Continued
+Charge Description
+100 INCL. MSGS SENT
+100 INEL: MEGS SENE
+100 INCL. MSGS SENT
+100 INCL: MS8 SENT
+100 INEL: M583 SENT
+100 INCL. MSGS SENT
+MSGS
+100 INCL. MSG5 SENT
+100 INCL. MSG5 SENT
+HOG NE S SEN
+
+2000317.000002416
+
+
+2000317.000002416
+TEXT/MULTIMEDIA MSGS FOR
+Item Date
+Time
+Sent To/Rcvd From
+145 05/26
+01:40P
+149 05/28
+bangs
+05
+26
+07:15P
+03/26
+29:078
+05/26
+09:41P
+85/27
+85:424
+05/27
+08:19A
+08327
+1:34/
+2:08
+05/27
+12:12P
+12:17P
+12:23P
+12:25P
+12:36₽
+162 05/28
+11:07A
+62052
+12:53P
+02:49P
+165 05/28
+02:52P
+166 05/28
+02:55P
+167 05/28
+03:14P
+168 05/28
+9 050
+03:20P
+0 050
+171 05/29
+05331
+09:33A
+172 05/29
+10:18A
+173 05/29
+10:25A
+4 050
+2:431
+5 057
+4-431
+176 05/29
+08:0BP
+12052
+08:48P
+78 05/3
+179 05/30
+09:06P
+09:08P
+04:03A
+182 05/31
+10:03A
+04:37P
+08: 22P
+186 05/81
+08:44P
+09:14P
+187 05/31
+09:15P
+188 033.
+19:191
+189 05/31
+9:231
+TOTAL TEXT/MULTIMEDIA MSG USAGE FOR
+- Continued
+Charge Description
+INTL ROAM TEXT MSG
+INTERAM TEXT MES
+TEXT MESSAGES SENT
+TEXT MESSAGES
+SENT
+- NT
+IEXT MESSAGES
+ENT
+TEXT MESSAGE
+ENT
+TEXT MESSAGES
+Unu
+ENT
+ENT
+INTE ROAM TEXT
+MSC
+INTL ROAM TEXT MS
+INTL ROAM TEXT MEC
+0a60000
+INTL ROAM TEXT MS
+INTL ROAM TEXT MS
+IL ROAMTEXIN
+L ROAM TEXT
+IT RAM TERM
+INTL ROAM TEXT MSG
+TEXT MESSAGES
+SENT
+TEXT
+TEXT MESSAG
+TEXT MESSAGES
+SENT
+SENT
+MESSAGE
+MESSAG
+mmmm
+NT
+MESSAGES
+NT
+MESSI
+AGES SENT
+SUMMARY OF CURRENT ACTIVITY
+FOR
+Monthly Service Charges
+Item Description
+Service Dates
+1 CALL WAITING
+2 TEXT MESSAGING PLAN - 0 MSGS
+3 CALLER ID
+4 VOICEMAIL
+5 GSM AMERICA LOCAL $29.99
+6 DOMESTIC LONG DISTANCE FRM SERVICE AREA
+7 CALL FORWARDING
+05/03/06 - 06/02/06
+0.50
+0:50
+0.10
+0.10
+0.10
+0.10
+0.10
+0.10
+0.10
+0.50
+0.50
+0.50
+50
+0.50
+0.50
+0.50
+0.50
+0.50
+0.50
+0.50
+0.50
+0.50
+0.50
+0.10
+0.10
+.10
+10
+0.10
+.10
+0.00
+2.00
+0.00
+29.99
+0.00
+0.00
+Account Name
+
+SUMMARY OF CURRENT ACTIVITY - CONTINUED
+Monthly Service Charges - Continued
+Item Description
+8 WORLDCONNECT
+9 REGULATORY PROGRAM CHARGE
+10 DETAIL BILLING
+Total Monthly Service Charges
+Other Subscriber Charges
+Item Description
+1 MCTD SURCHARGE
+2 NY CITY UTILITY G.R. SUR
+3 STATE TELECOM EXCISE SURCHARGE
+4 FEDERAL UNIVERSAL SERVICE FUND SURCHARGE
+Total Other Subscriber Charges
+Subscriber Government Fees and Taxes
+Item Description
+1 SALES TAX
+2 ST WIRELESS COMM SURCHARGE
+3 FEDERAL EXCISE TAX
+4 LOCAL WIRELESS SURCHARGE
+Total Subscriber Government Fees and Taxes
+TOTAL CURRENT CHARGES FOR |
+Service Dates
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+05/03/06 - 06/02/06
+0.00
+1.75
+39.04
+0.19
+0.65
+0.84
+0.98
+2.66
+2.88
+1.20
+1.04
+39.82
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/0d222b9e2cf222475e039bfece06c87fc19fc30b08bc686012d1a526968fe441.receipt.json b/vision-fixhub/ds9-unparsed-06/0d222b9e2cf222475e039bfece06c87fc19fc30b08bc686012d1a526968fe441.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3aa970886052f7fa2143388605c5cd7831a71a4b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0d222b9e2cf222475e039bfece06c87fc19fc30b08bc686012d1a526968fe441.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -7354,
+  "dataset": "marble-joined",
+  "doc_id": "0d222b9e2cf222475e039bfece06c87fc19fc30b08bc686012d1a526968fe441",
+  "engine": "marble-apple-vision",
+  "event_count": 82,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "b1a6780cc1ce6c87735fc3227f53b06c1476a7fd5531cf056ccec8c0780a66dc",
+  "output_sha256": "fff5d4b916bf4ab447fd1ff2e2e5e8c59aa027b155e7ee3a3b2b4e6981b6bcd7",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0d34276ac8794901e0182424ed9a56d5937dd35fe9935c44ec6c32a18b4abd6b.md b/vision-fixhub/ds9-unparsed-06/0d34276ac8794901e0182424ed9a56d5937dd35fe9935c44ec6c32a18b4abd6b.md
new file mode 100644
index 0000000000000000000000000000000000000000..4959c348090f1f7fd4f03900fc789fab8d2bd6d1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0d34276ac8794901e0182424ed9a56d5937dd35fe9935c44ec6c32a18b4abd6b.md
@@ -0,0 +1,168 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOES #1 and #2
+Petitioners,
+UNITED STATES OF AMERICA,
+Respondent.
+RESPONDENT'S OPPOSITION TO VICTIMS' MOTION
+TO UNSEAL NON-PROSECUTION AGREEMENT
+Respondent, by and through its undersigned counsel, files its Opposition to Victims*
+Motion to Unseal Non-Prosecution Agreement, and states:
+THE MOTION TO UNSEAL SHOULD BE DENIED BECAUSE
+THE NON-PROSECUTION AGREEMENT HAS NEVER BEEN
+FILED UNDER SEAL IN THIS COURT.
+Petitioners have filed their motion to unseal the non-prosecution agreement, claiming that
+no good cause exists for sealing it. As an initial matter, the motion should be denied because the
+non-prosecution agreement entered into between the United States Attorney's Office and Jeffrey
+Epstein was never filed in the instant case by the United States, either under seal or otherwise.
+On August 14, 2008, this Court held a telephonic hearing to discuss petitioners request for a
+copy of the non-prosecution agreement. The United States advised the Court that the Agreement
+had a confidentiality provision, which the United States was obligated to honor. The United
+States requested that, if the Agreement was to be produced to petitioners, it should be done
+
+
+pursuant to a protective order, to ensure that further dissemination of the Agreement would not
+occur. At that time, petitioners had no objection to such a procedure.
+On August 21, 2008, this Court entered its Order to Compel Production and Protective
+Order (DE 26). Subpart (b) of the Order provides that, "Petitioners and their attorneys shall not
+disclose the Agreement or its terms to any third party absent further court order, following notice
+to and an opportunity for Epstein's counsel to be heard." (DE 26 at 1) Presumably, petitioners'
+motion to unseal is an effort to modify the terms of the Protective Order, to enable them to
+disclose the Agreement to third parties.
+Since the Agreement has not been filed under seal with this Court, the legal authority
+cited by petitioners regarding sealing of documents, United States |. Ochoa-Vasque, 428 F.3d
+1015 (11" Cir. 2005), is inapposite. The parties who negotiated the Agreement, the United
+States Attorney's Office and Jeffrey Epstein, determined that the Agreement should remain
+confidential. They were free to do so, and violated no law in making such an agreement. Since
+the Agreement has become relevant to the instant lawsuit, petitioners have been given access to
+it, upon the condition that it not be disclosed further.' Petitioners have no legal right to disclose
+the Agreement to third parties, or standing to challenge the confidentiality provision.
+In order to have standing, petitioners must show: (1) an injury in fact, meaning an injury
+that is concrete and particularized, and actual or imminent; (2) a causal connection between the
+injury and the causal conduct; and (3) a likelihood that the injury will be redressed by a favorable
++ It is unclear whether the Petitioners themselves (as opposed to their attorneys) have actually
+reviewed the Non-Prosecution Agreement. The Court's Order to Compel Production required
+petitioners' counsel to review and agree to the Protective Order and to do the same with their
+clients. Copies of those signed acknowledgements to abide by the Protective Order were then to
+be provided "promptly" to the United States. To date, only Attorney Brad Edwards has provided
+a signed acknowledgement.
+2
+
+
+decision. Granite State Outdoor Advertising, Inc. |. City of Clearwater, Fla., 351 F.3d 1112,
+1116 (11" Cir. 2003). Petitioners already have obtained access to the agreement, so they cannot
+claim a denial of access as an injury in fact. Their motion to unseal refers to their stated desire to
+confer with other victims of Epstein and their attorneys "to determine whether they were
+likewise provided with inaccurate information about the nature of the plea agreement." (DE 28
+at 5.)
+This asserted reason for needing to unseal the Agreement is baseless given that the
+Protective Order, at the Court's direction, specifically provides for a very simple procedure to
+allow other victims and their lawyers to see the Agreement. (See DE 26 at 1-2, subpart (d).) All
+that is required is for the victims and/or their attorneys, to review and agree to the terms of the
+Protective Order, and to provide the signed acknowledgment of that agreement to the United
+States.
+Petitioners' claim that they wish to discuss with others the "possible legal responses" to
+the Government, including the National Alliance of Victims' Rights Attorneys, also provides no
+basis for vacatur of the Protective Order. Petitioners contend that the "sealing order would
+apparently block these forms of consultation ..." (DE 28 at 5.) First, there is no sealing order.
+Second, the Protective Order does not prevent petitioners from consulting with anyone; it only
+prevents them from disclosing the Agreement. Petitioners fail to mention why it is necessary for
+the National Alliance of Victims' Rights Attorneys to have the Agreement in hand, in order to
+meaningfully consult with them.
+Petitioners also assert that they would like to be able to reference the Agreement "in a
+parallel civil suit that is pending before this Court." (DE 28 at 5.) Given that the suit names
+Jeffrey Epstein as a defendant and is pending before the same district judge, it seems that
+3
+
+
+litigation regarding the production and use of the Agreement should occur in that case, where the
+true party in interest, Jeffrey Epstein, is present and represented by counsel, rather than in a suit
+that was originally filed in July as an "Emergency Petition" under the various victims' rights
+laws.
+II.
+THE GOVERNMENT ACCURATELY DESCRIBED THE
+PROVISIONS OF THE AGREEMENT, AT THE TIME THE
+RESPONSES WERE FILED WITH THE COURT.
+Petitioners castigate the Government for inaccurately describing the non-prosecution
+agreement. (DE 28 at 2-5.) They contend a particular provision cited by the Government does
+not appear in the copy of the Agreement produced to them.
+During the telephonic hearing on August 14, 2008, Government counsel advised the
+Court and petitioners' counsel that there was an ongoing dispute between the Government and
+Epstein's attorneys over what constituted the Agreement. Government counsel advised that the
+Agreement had three parts. The first part was executed in September 2007, the second part, an
+addendum, was executed in October 2007, and the third part was a December 2007 letter from
+the United States Attorney to Epstein's attorneys, suggesting a further modification of the
+Agreement. The Government advised the Court that it believed that all three parts comprised the
+Agreement, while it appeared that Epstein's attorneys were contending the Agreement was
+comprised only of parts one and two.
+At the commencement of the instant litigation, in July 2008, the Government believed the
+Agreement was comprised of all three parts mentioned above. This belief was expressed in
+victim notifications, including one sent to Jane Doe #1,2 the Government's July 9, 2008 response
+2 The victim notification letter was provided to Epstein's attorneys prior to being sent, who
+approved the language of which the petitioners now complain. Thus, petitioners' repeated
+4
+
+
+to the Emergency Petition for Enforcement of Victims Rights Act, as well as the Declaration of
+A. Marie Villafaña, Assistant U.S. Attorney, which accompanied the Government's response.
+This belief continued until August 2008, when the Government advised Epstein's attorneys that
+the victims had demanded disclosure of the Agreement to them, and discussions ensued about
+what constituted the Agreement. Epstein's attorneys then told the Government that Epstein
+believed the Agreement consisted only of the first and second parts. These were the parts
+disclosed to petitioners pursuant to the Protective Order in compliance with the Court's order to
+compel production. The fact that an erroneous disclosure was inadvertently made to one
+petitioner after Epstein had already entered his guilty plea, was sentenced, and surrendered to
+begin serving his sentence does not create an injury where one did not exist before.
+assertions that the Government made these errors intentionally and/or negligently are meritless.
+(See, e.g., DE 28 at 4-5 ("The Government apparently feels free to disclose to the victims one
+provision in the non-prosecution agreement that it believes it is to its advantage to disclose, but
+not others. The Government should not be permitted to pick and choose, particularly where it
+has inaccurately described the provision that it has chosen to disclose.") The Government seeks
+no "advantage" in this suit brought by the two victims. Furthermore, the petitioners' original
+emergency petition focused on their concern about the amount of jail time that Epstein would
+serve. The provision that they complain of now has no relation to jail time. Furthermore,
+petitioners aver that the October 2007 disclosure to Jane Doe #1 contained inaccurate
+information, but that disclosure was made before the December 2007 letter and, therefore, did
+not include anything related to the now-defunct part three of the Agreement.
+
+
+CONCLUSION
+For the foregoing reasons, the United States respectfully requests that the Court deny
+Petitioners' Motion to Unseal the Non-Prosecution Agreement.
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+Fla. Bar No. 0936693
+99 N.E. All Street
+Miami, Florida 33132
+(305) 961-9320
+Fax: (305) 530-7139
+E-mail: dexter.lee@usdoj.gov
+Attorney for Respondent
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on October
+document with the Clerk of the Court using CM/ECF.
+_ 2008, I electronically filed the foregoing
+s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+6
+
+
+SERVICE LIST
+Jane Does 1 and 2|. United States
+Case No. 08-80736-CIV-MARRA/JOHNSON
+United States District Court, Southern District of Florida
+Brad Edwards, Esq.,
+The Law Offices of Brad Edwards & Associates, LLC
+2028
+Street. Suite 202
+Hollywood, Florida 33020
+(954) 414-8033
+Fax: (954) 924-1530
+7
diff --git a/vision-fixhub/ds9-unparsed-06/0d34276ac8794901e0182424ed9a56d5937dd35fe9935c44ec6c32a18b4abd6b.receipt.json b/vision-fixhub/ds9-unparsed-06/0d34276ac8794901e0182424ed9a56d5937dd35fe9935c44ec6c32a18b4abd6b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..8f668202ee5ba8d8b05225bf4a5e8b2209741f6b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0d34276ac8794901e0182424ed9a56d5937dd35fe9935c44ec6c32a18b4abd6b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -84,
+  "dataset": "marble-joined",
+  "doc_id": "0d34276ac8794901e0182424ed9a56d5937dd35fe9935c44ec6c32a18b4abd6b",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "39091d6141e4fc33db4ab7afb4ec460a29673ac7f2b14cfd11e6e95967173ac6",
+  "output_sha256": "bf09a88c61d96dbc1e1ff4432866f36fea07f7e79f3f58a038b7fad385ac52b6",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0d8f9b00c514b8d4171384bf0f375a4a22c40290f90f0197bb7f4367e665d4f9.md b/vision-fixhub/ds9-unparsed-06/0d8f9b00c514b8d4171384bf0f375a4a22c40290f90f0197bb7f4367e665d4f9.md
new file mode 100644
index 0000000000000000000000000000000000000000..3faaa1b3700a746a02a16f3d3c3056d8f64bde0f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0d8f9b00c514b8d4171384bf0f375a4a22c40290f90f0197bb7f4367e665d4f9.md
@@ -0,0 +1,4 @@
+Date: Wed, 25 Aug 2010 13:31:13 +0000
+Importance: Normal
+I got your voicemail that said you were in meetings so I figured I'd send you an e-mail. Can you call me when
+you get a chance? I got a strange inquiry from a reporter on Epstein. Thanks.
diff --git a/vision-fixhub/ds9-unparsed-06/0d8f9b00c514b8d4171384bf0f375a4a22c40290f90f0197bb7f4367e665d4f9.receipt.json b/vision-fixhub/ds9-unparsed-06/0d8f9b00c514b8d4171384bf0f375a4a22c40290f90f0197bb7f4367e665d4f9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..118d69598ab67e557bed7365f4c6b4edb5fca2d4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0d8f9b00c514b8d4171384bf0f375a4a22c40290f90f0197bb7f4367e665d4f9.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "0d8f9b00c514b8d4171384bf0f375a4a22c40290f90f0197bb7f4367e665d4f9",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "ad3010d7e7c300c7ec09e253d93322cf8054c7ff9c44ecec05776a0634152b14",
+  "output_sha256": "bf531f8045bf69a7765ed69bdfda43b50f6f76f0a4f1566d7d8234de2b4ca951",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0da4231c58cd8346f9d9b011a69b609bdb4453883ba35c30edb6be52b6cae429.md b/vision-fixhub/ds9-unparsed-06/0da4231c58cd8346f9d9b011a69b609bdb4453883ba35c30edb6be52b6cae429.md
new file mode 100644
index 0000000000000000000000000000000000000000..fa0aec575e1797b71a8ad40e0d61cac2f2698586
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0da4231c58cd8346f9d9b011a69b609bdb4453883ba35c30edb6be52b6cae429.md
@@ -0,0 +1,71 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov»
+Subject: Activity in Case 9:08-cv-80893-KAM Doe |. Epstein Motion for Attorney Fees
+Date: Thu, 01 Apr 2010 15:13:54 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Pike, Michael on 4/1/2010 at 11:13 AM EDT and filed on 4/1/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 135
+Doe | Epstein
+9:08-cv-80893-KAM
+Jeffrey Epstein
+Docket Text:
+Defendant's MOTION for Attorney Fees and Costs Based on Dismissal With Prejudice of
+Plaintiff's RICO Claim by Jeffrey Epstein. Responses due by 4/19/2010 (Attachments: # (1)
+Exhibit Part I, # (2) Exhibit Part II, # (3) Exhibit B, # (4) Exhibit C)(Pike, Michael)
+9:08-Cv-80893-KAM Notice has been electronically mailed to:
+Ann Marie C. Villatana
+ann.marie.c.villafana@usdoj.gov
+Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com
+Jack Alan Goldberger
+jagesq@bellsouth.net, nalanis@agwpa.com
+Michael James Pike MPike@bclclaw.com, bobbie@bclclaw.com, jcadwell@bclelaw.com
+Paul G. Cassell cassellp@law.utah.edu
+Robert Deweese Critton, Jr _rerit@bclclaw.com, bobbie@bclclaw.com
+9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+The following documents) are associated with this transaction:
+
+
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=4/1/2010] [FileNumber=7425463-0]
+[0788481f3d866327883a3ae8eбс10f521da91flaalf578ecb745001d3f0fc6f6d967
+4a3cc4c58b08c14a3f3be13ffla180d4ad16c21904afd34a3271f99b9e2a]]
+Document deseription: Exhibit Part I
+Original filename:n/a
+Electronie document Stamp:
+[STAMP dcecfStamp_ID=1105629215 [Date-4/1/2010] [FileNumber=7425463-1]
+[976cc21cefa5d0d546509fbafc1418218836825789094630237dd4012396cd6ce5be
+cc430c908bff350d3d454e54fe579c88335dc32d7dfe94laaeeea519e701]]
+Document description: Exhibit Part II
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=4/1/2010] [FileNumber=7425463-2]
+[41c5422d014a0561b8913e355c974313f044598f4b34cac42889fa27a8c8a78a2eea
+bca135cdd70fda405e383e2a87201c1d1bd762a470abbd8624e876007bac]]
+Document description:Exhibit B
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date-4/1/2010] [FileNumber=7425463-3]
+[82ffbe68fc0fb9ac46f1bcd94781d65df8af8f48d6cad79719f79bd47870cb195975
+3a542c2c3f64e94255b14bf8c16ccd1f271f79b33b21ca2d8371a85fd195]]
+Document description: Exhibit C
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=4/1/2010] [FileNumber=7425463-4]
+[43961acb50809e6267ff6c1ac826b866d612478d0a95d723b3dfbbecaed443c1d59a
+bb9бебfbЗa75a18d5cafd30f7868870c2728c65eeb8d94dd2358691977c81]
diff --git a/vision-fixhub/ds9-unparsed-06/0da4231c58cd8346f9d9b011a69b609bdb4453883ba35c30edb6be52b6cae429.receipt.json b/vision-fixhub/ds9-unparsed-06/0da4231c58cd8346f9d9b011a69b609bdb4453883ba35c30edb6be52b6cae429.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..8fb57e3ceb318b04d30041e28f25519d49ca0891
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0da4231c58cd8346f9d9b011a69b609bdb4453883ba35c30edb6be52b6cae429.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "0da4231c58cd8346f9d9b011a69b609bdb4453883ba35c30edb6be52b6cae429",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "0e2f8771a660d3fcb69f68426b2cb1d693a462c35a0cb4627f176c3c11e246a5",
+  "output_sha256": "17bb4d1983447238eb5d6c122790df0fbcafec6b6e47b05b6ab6e53f54c56269",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0dc5f2003666fd42e24c46e19266a42e5fdd5e19dfa6fa3f1a15f3799f2955b9.md b/vision-fixhub/ds9-unparsed-06/0dc5f2003666fd42e24c46e19266a42e5fdd5e19dfa6fa3f1a15f3799f2955b9.md
new file mode 100644
index 0000000000000000000000000000000000000000..721608b2076ec76b58c5a033886a9a7208873eff
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0dc5f2003666fd42e24c46e19266a42e5fdd5e19dfa6fa3f1a15f3799f2955b9.md
@@ -0,0 +1,48 @@
+From: Jackie Perczek •
+To: Paul Cassell
+Subject: RE: Doe v. USAO
+Date: Mon, 22 Aug 2011 20:31:50 +0000
+Importance: Normal
+Inline
+mares: ATT00001 jp
+Of course -- and thanks.
+>>>
+From: Paul Cassell
+To:
+Jackie Perczek
+Date:
+8/22/2011 4:27 PM
+Subject: RE: Doe v. USAO
+Hi Jackie - We have no problem, provided associated deadlines also extended. PC
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+S.J. Quinney College of Law at the University of Utah
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended
+only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the
+intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this
+message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank
+From: Jackie Perczek [mailto:
+Sent: Monday, August 22, 2011 1:52 PM
+To: Paul Cassell; •
+Subject: Doe v. USAU
+Dear counsel,
+
+
+Anticipating that I will lose one if not two or more days of work preparing for and then dealing
+with Hurricane Irene, I would like to file the attached motion asking Judge Marra for a one-week extension
+of this Friday's briefing deadline. I am hopeful that you have no objection to this short extension. Pls let me
+know as soon as you can so I can file the motion.
+Many thanks,
+Jackie Perczek, Esq.
+BLACK
+SREBNICK
+KORNSPAN
+STUMPF
+TRIAL ATTORNEYS
+www.royblack.com
+***********************************************
+The information in this email transmission is privileged and confidential. If you are not the intended
+recipient, nor the employee or agent responsible
+for delivering it to the intended recipient, you are hereby notified that any dissemination or copying of this
+transmission (including any attachments) is strictly prohibited. If you have received this email in error,
+please notify the sender by email reply. Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/0dc5f2003666fd42e24c46e19266a42e5fdd5e19dfa6fa3f1a15f3799f2955b9.receipt.json b/vision-fixhub/ds9-unparsed-06/0dc5f2003666fd42e24c46e19266a42e5fdd5e19dfa6fa3f1a15f3799f2955b9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6297d56175366b8c7bab4b630c7de192230b5680
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0dc5f2003666fd42e24c46e19266a42e5fdd5e19dfa6fa3f1a15f3799f2955b9.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "0dc5f2003666fd42e24c46e19266a42e5fdd5e19dfa6fa3f1a15f3799f2955b9",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "5d539708b07e0d57a231cf0da92f49ad690547ced323e1ea7f4aaa487441fa26",
+  "output_sha256": "64bbe4682ce8506450aa747a6e2e8fa46f1dd524b65fbe77cb454f02a5b87ee2",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0dfc612d0bda258389b26cde1e41f7c31fdadafc18ad4025e206e2fb68f14264.md b/vision-fixhub/ds9-unparsed-06/0dfc612d0bda258389b26cde1e41f7c31fdadafc18ad4025e206e2fb68f14264.md
new file mode 100644
index 0000000000000000000000000000000000000000..47beb5d2e62e4deadf46868f9ea8e4a20ca46dd2
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0dfc612d0bda258389b26cde1e41f7c31fdadafc18ad4025e206e2fb68f14264.md
@@ -0,0 +1,31 @@
+Subject: RE: Jane Doe Nos. 1 and 2|| United States
+Date: Wed, 14 Dec 2011 01:34:22 +0000
+Importance: Normal
+Happy holidays to you too. I know we are on the opposite sides of the dispute, but we have always appreciated all your
+courtesy. Paul
+Paul G. Cassell
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only
+for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended
+recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error,
+please immediately notify the sender by reply electronic mail and delete the original message. Thank you.
+Sent: Tuesday, December 13, 2011 6:07 PM
+To: Brad Edwards: Paul Cassell
+Subject: RE: Jane Doe Nos. 1 and 2 I. United States
+Brad and Paul,
+Thanks very much and a happy holiday to both of you.
+From: Brad Edwards [mailto:bedwards@pathtojustice.com]
+Sent: Tuesdav. December 13. 2011 7:42 PM
+Subject: Re: Jane Doe Nos. 1 and 2 | United States
+January 6th is fine. Have a nice vacation.
+Sent via BlackBerry by AT&T
+Date: Tue, 13 Dec 2011 17:35:06 -0500
+To: Paul Cassell<cassellp@law.utah.edu>; Brad Edwards<bedwards@pathtojustice.com>
+
+
+Subject: Jane Doe Nos. 1 and 2L. United States
+Paul and Brad,
+The government's replies to the victims' responses are due on December 15, 2011. The responses to the motion for
+remedies, and protective motion to compel, are due on December 22, 2011.
+ill be on annual leave for the holidays at various times over the next two and one-half weeks, until the
+new year. Do you have any objection to the government seeking an enlargement of time, to respond to the four (4)
+documents filed on December 5, up to and including January 6, 2012? Thanks.
diff --git a/vision-fixhub/ds9-unparsed-06/0dfc612d0bda258389b26cde1e41f7c31fdadafc18ad4025e206e2fb68f14264.receipt.json b/vision-fixhub/ds9-unparsed-06/0dfc612d0bda258389b26cde1e41f7c31fdadafc18ad4025e206e2fb68f14264.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f037cad0f18570e9fe3cd44babd398dc79f9f0c6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0dfc612d0bda258389b26cde1e41f7c31fdadafc18ad4025e206e2fb68f14264.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "0dfc612d0bda258389b26cde1e41f7c31fdadafc18ad4025e206e2fb68f14264",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "a62fc5d1f73feb79c78504e76d2e120a7388d0d800f35066e68e54b8082ef48a",
+  "output_sha256": "b7ffc9c05bf8039830caae1308a57164a2c9f0c67e0efb5d580837abccf6795c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0e93bc920434fbf9bc082f01d49a2c2ff98e3cd472fe7a898b3b77fbb091aa6b.md b/vision-fixhub/ds9-unparsed-06/0e93bc920434fbf9bc082f01d49a2c2ff98e3cd472fe7a898b3b77fbb091aa6b.md
new file mode 100644
index 0000000000000000000000000000000000000000..e2a2a116f56aabc4efa5d73a6c56d16e5cf67d48
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0e93bc920434fbf9bc082f01d49a2c2ff98e3cd472fe7a898b3b77fbb091aa6b.md
@@ -0,0 +1,8119 @@
+Billing Cycle Date:
+Account Number:
+1 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+How To Contact Us:
+• 1-800-331-0500 or 611 from your wireless phone
+• For Deaf / Hard of Hearing Customers (TTY/TDD)
+1-866-241-6567
+Wireless Number with Rollover
+Previous Balance
+Payments Posted
+CREDIT BALANCE
+Monthly Service Charges
+Usage Charges
+Credits/Adjustments/Other Charges
+Government Fees and Taxes
+TOTAL CURRENT CHARGES
+Due May 21, 2006
+Late fees assessed after May 21
+Total Amount Due $691.22
+449.02
+-456.74
+-7.72
+69.98
+506.82
+16.96
+105.18
+698.94
+Cingular has the Fewest Dropped Calls!
+It's official - independent tests show Cingular has the fewest dropped calls.
+In the past year we invested $6.6 billion to improve our GSM network coverage
+and quality. We now have over 47,000 cell sites in America, more than any
+other wireless carrier and it doesn't stop there...
+We promised to build the best network and we're delivering.
+PO BOX 772349 - (MIA)
+OCALA, FL 34477-2349
+*BWNHHBD
+#06091813030015*
+Return the guitar Weles th payment.
+Account Number: 06091813-001-03
+Total Amount Due:
+$691.22
+Amount Paid:
+$
+* Please do not send correspondence wish paymens.
+124
+SEMINOLE LAKES DR
+ROYAL PALM BEACH, FL 33411-4210
+Total Amount
+Due by May 21, 2006
+Please Make Check Payable To:
+ingular Wirele
+.0. Box 3141
+Tampa, FL 33631-3488
+
+
+
+Billing Cycle Date:
+Account Number:
+2 of 4:
+03/29/06 - 04/28/0
+06091813-001-03
+General Information
+• Terms: The past due amount is due immediately. Late payment charges of 1.5% may be
+applied to any unpaid balance as of your next billing date. When you send us a
+check as payment, you authorize us to clear your check electronically. Electronic
+payments may clear the same day we receive payment. Returned checks or othe
+negotiable instruments may be represented electronically and may result in the
+selected services. Usage and toll charges are billed in arrears. Certain usage
+and toll charges may appear more than one month in arrears. Prorated monthly
+charges may apply for new services or changes to existing services during a
+billing period. These will appear in the Monthly Service Charges sections of the
+bill
+• Please do not enclose correspondence with your payment for we cannot guarantee
+TO BOX 772349- (A) OGA. 0L3401-ing: Cingular Wireles,
+• Calls to our Customer Service Centers may be monitored to ensure high quality
+service to our customers.
+• Questions on accessibility by persons with disabilities: 1-866-241-6568
+• Cingular Wireless Tax ID # 84-1659970 / Cingular Wireless DUNS # 003548489
+**********************************************************************
+Auto Pay Authorization Agreement - For use only with Auto Pay phone enrollment
+If I enroll, I authorize Cingular Wireless to pay my bill monthly by debiting my
+bank account. I can cancel authorization by notifying Cingular at
+www.cingular.com, by calling 1-800-331-0500, or by dialing 611 from my wireless
+phone. If my bank rejects a payment, I may be charged a return fee.
+How To Pay
+Checking and savings account payments, check cards, credit cards are accepted.
+Payments made with a representative may be subject to a service fee.
+Note: There is no fec for choosing any of the following payment channels:
+Pay using your wireless phone for free
+- Dial *PAY (*729), then hit send.
+- Make a one time payment following the instructions provided.
+Pay using any landline phone - Dial 1-800-331-0500
+- Enter your wireless number and billing ZIP Code and follow the prompts
+- Go to www.cingular.com/
+- Mail your remittance stub and a check or money order in the envelope provided.
+- It may take up to 7 - 10 days for the payment to post.
+
+
+-
+X
+Prior Activity
+Previous Balance
+Detail of Payments Posted
+Payment by ACH payment at lockbox posted on Apr 01, 2006
+Payment by ACH payment at lockbox posted on Apr 12, 2006
+TOTAL CREDIT BALANCE
+Wireless Line Summary For:
+User Name:
+Monthly Service Charges
+Rate Plan
+rent Rate Pl
+TPODORUMMUN
+Includes:
+- BASIC VOICEMAIL-N/C
+- CALL FORWARDING N/C
+- CALL WAITING N/C
+- CALLER ID N/C
+- DATA VOLUME DETAILED BILLING
+- DETAILED BILLING N/C
+- MULTIMEDIA PAY PER USE
+- THREE PARTY CALL N/C
+- WRLSS INTRNT XPRS PAY PER USE
+Other Services
+/900 ANYTIME MINS
+/ANYTIME MIN ROLLOVER
+/EXPANDED INTL. ROAMG SVC
+/INTLRM AUSTRALIA $1.69
+JINTLRM MEX/CAN $.79
+/INTLRM PREMIUM $3.99
+/INTLRM W.EUR $1.29
+/INTLRME.EU AS/PA $1.99
+/INTIRMMIDE/AFR$2.49
+/INTLRMS/C AM/CAR $1.99
+/NATION GAIT/GSM
+/UNLIMITED EXPANDED M2M-N/C
+JUNLIMITED NIGHT & WEEKEND CTH
+CINGULAR NATIONWIDE TOLL FREE
+FL. ROAM WITH HOME
+OFF-NETWORK ROAM
+Wireless Data
+TEXT MESSAGING 1000
+TOTAL MONTHLY SERVICE CHARGES
+Usage Charges
+(See Usage Charge Details)
+TOTAL USAGE CHARGES
+Billing Cycle Date:
+lecount Number
+3 of 45
+03/29/06 - 04/28/0
+06091813-001-0
+06091813-001-03
+449.02
+-256.74
+-200.00
+Period
+03129-04/28
+$-7.72
+Monthly
+Charge
+Total
+Charge
+59.99
+59.99
+03/29-04/28
+03/29-04/28
+03/29-04/28
+03/29-04/28
+03/29-04/28
+03/29-04/28
+03/29-04/28
+03/29-04/28
+03/29-04/28
+03/29-04/28
+03/29-04/28
+03/29-04/28
+03/29-04/28
+03/29-04/28
+03/29-04/28
+03/29-04/28
+03/29-04/28
+0-00
+9.99
+0-00
+9.99
+$69.98
+$506.82
+
+
+X
+4 of 45
+03/29/06 - 04/28/06
+06091813-001-0:
+Wireless Line Summary For (Continued):
+User Name:
+Credits, Adjustments & Other Charges
+FED UNIVERSAL SVC CHARGE
+REGULATORY COST RECOVERY CHARGE
+TOTAL CREDITS, ADJUSTMENTS & OTHER CHARGES
+Government Fees and Taxes
+FEDERAL EXCISE TAX
+STATE COMMUNICATIONS TAX
+LOCAL COMMUNICATIONS TAX
+911 MONTHLY
+TOTAL GOVERNMENT FEES and TAXES
+16.83
+$16.96
+TOTAL AMOUNT DUE
+Usage Charge Details
+User Name:
+Summary of
+Usage Charges
+NATP900RUMMUNW
+Peak
+JUNLIMITED EXPANDED M2M-N
+/UNLIMITED NIGHT & WEEKEN
+Long Distance
+Domestic
+Roaming
+Subtotal
+Summary of
+Wireless Data
+Text Messaging
+-CINGULAR MOBILE TO MOBILE Ourgoing
+- CINGULAR MOBILE TO MOBILE Incoming
+- MTM Other Incoming
+- OTHER MOBILE TO MOBILE Outgoing
+WRLSS INTRNT XPRS PAY PER USE
+Peak
+Subtotal
+16.82
+55.10
+32.76
+0.50
+$105.18
+$698.94
+Minutes
+Included
+Minutes
+Billed
+In Plan
+Used
+Minutes
+Billed
+Rate
+Total
+Charge
+900
+2167
+108
+960
+1267
+506.80
+1653
+See Call Details
+See Call Details
+$506.80
+Msg/KB/Min
+Included
+Msg/KB/ Billed
+Billed
+In Plan
+Min Used Msg/KB/Min
+Rate
+Total
+Charge
+16
+20
+10
+45
+2
+2
+0-00
+0.02
+$0.02
+
+
+Billing Cycle Date:
+Account Number
+5 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+$506.82
+TOTAL USAGE CHARGES
+Summary of Rollover Minutes
+/ User Name:
+Current Rollover Balance
+*) Unused Package Minutes Expire After 12 Billing Period
+Call Detail
+User Name:
+Call Location(CL): AU=Aucilla, BR=Bristol, BU=Bushnell, CH=Chiefland, CL.=Clewiston, DB=Daytona, FL.=Flagler,
+FK=Florida Keys. FM=Fort Myers, FP=Fort Pierce, FW=Fort Walton, GV=Gainesville, JX=Jacksonville, LC=Lake City.
+L.B=Leesburg, MI=Miami, MA=Marianna, MB=Melbourne, MX=Mexico Beach, OC=Ocala, OR=Orlando, PL.=Palatka, PC=Panama City,
+PS=Pensacola, PJ=Port St Joe, SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa, VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Ot Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Feature: 1=PTT One-to-One event; a=Automated Call Return; B=Direct Asst Call Complete; C=Call Waiting: D=Data Call;
+d=Directory Assistance Call; F=Call Forwarding: g=PTT Group event; H=Group Mobile to Mobile Calls; I=Incoming Call;
+K=Fax Call; M=Mobile To Mobile Discount; N=Of-Network; O
+Item
+Day
+Wed
+6
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+26
+27
+28
+29
+Date
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+Time
+12: 07AM
+01:09AM
+08: 55AM
+09: 43AM
+10: 04AM
+11:07AM
+11:16AM
+11:48AM
+12:19PM
+12:25PM
+12: 53PM
+02:23PM
+03:23PM
+03:27PM
+03: 40PM
+CL
+Number
+Called
+561-254-3057
+772-219-4743
+850-294-9750
+561-876-2957
+772-321-2693
+561-876-2957
+561-876-2957
+03:41PM
+03:43PM
+04:29PM
+06:00PM
+06: 02PM
+06:04PM
+06:16PM
+06:24PM
+06:26PM
+06:39PM
+08:29PM
+09:17PM
+10:03PM
+786-266-8989
+561-876-2957
+561-876-2957
+772-321-2693
+T2-173-69
+772-321-2693
+772-321-2693
+Call To
+W PAIM FL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+W PAIM FL
+W PAIM FL
+W PAIM FL
+STUART FL
+W PAIM FL
+INCOMI CL
+INCOMI CL
+W PAIM FL
+VERO B FL
+W PALM FL
+W PALM FL
+MIAMI
+FL
+MIAMI
+FL
+W PALM
+W PALM
+FL
+VERO B
+FL
+INCOMI
+CL
+W PAIM FL
+VERO B FL
+INCOMI CL
+VERO B FL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI CL
+Rate Rate Fea- Airtime
+Min Code Pd ture Charge
+2 NPA2 O
+RW
+1
+NPA2
+NPA2
+5
+NPA2
+P
+NPAZ
+NPA2
+NPA2
+IR
+R
+R
+R
+17
+NPAZ
+P
+P
+NPA2
+NPA2
+6
+4
+2
+NPA2
+NPA2
+IR
+IR
+R
+NPAZ
+NPA2
+NPA2
+NPA2
+2
+2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+P
+R
+R
+IR
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+IR
+R
+IR
+R
+2
+15
+NPA2
+NPA2
+o
+IRW
+LD
+DA
+Total
+Charge
+
+
+User Name:
+6 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+30
+31
+32
+33
+34
+35
+36
+37
+38
+39
+40
+41
+42
+43
+44
+Day
+Thu
+46
+47
+48
+49
+50
+51
+52
+53
+54
+55
+56
+57
+58
+59
+60
+61
+62
+63
+64
+65
+66
+67
+68
+69
+70
+71
+Date
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+Time
+CL
+Called
+772-321-2693
+772-321-2693
+772-321-2693
+-5714
+954-801-8575
+954-801-8575
+561-876-2957
+239-691-0713
+561-876-2957
+904-272-3799
+772-485-4893
+561-876-2957
+850-217-4869
+239-189-1784
+561-876-2957
+Call To
+W PAIM FL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+W PAIM FL
+INCOMI
+CL
+INCOMI
+CL
+W PAIM FL
+INCOMI
+CL
+W PALM FL
+FILAUD FL
+INCOMI
+CL
+W PAIM FL
+W PAIM FL
+W PAIM FL
+W PAIM FL
+W PAIM FL
+W PALM FL
+W PALM
+I FL
+PALM FL
+INCOMI
+CL
+W PAIM
+FL
+FORT M FL
+W PALM FL
+W PAIM FI
+ORANGE FL
+W PAIM FL
+INCOMI CL
+INCOMI CL
+INCOMI CI
+INCOMI CL
+W PALM FL
+INCOMI
+CL
+W PAIM FL
+INCOMI
+CL
+W PALM
+FL
+INCOMI
+CL
+W PALM FI
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+Rate Rate Fea-
+Min Code
+Pd
+ture Charge
+2
+NPA2
+11 NPA2 O
+3 NPA2 P
+1 NPA2
+P
+IRN
+IR
+IR
+IR
+2
+3
+2
+7
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+16
+NPA2
+NPAZ
+NPA2
+1
+NPA2
+1
+NPA2
+NPA2
+NPA2
+6
+NPA2
+13
+NPA2
+6
+NPA2
+55 NPA2
+2 NPA2
+1 NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+2
+NPA2
+NPA2
+NPA2
+NPA2
+P
+P
+P
+P
+IR
+IR
+R
+IR
+R
+IRM
+IR
+RM
+IR
+IR
+IRM
+IR
+R
+IRM
+IRW
+DA
+Total
+Charge
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+72
+73
+74
+75
+76
+77
+78
+79
+80
+81
+82
+83
+84
+85
+86
+87
+88
+89
+90
+91
+92
+93
+94
+95
+96
+97
+98
+99
+100
+102
+103
+104
+105
+106
+107
+108
+109
+110
+111
+112
+113
+Day
+Fri
+Date
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+03/31
+11:53AM
+12:48PM
+01:01 PM
+02: 40PM
+02: 49PM
+02:58PM
+03:14PM
+04:31PM
+05:24PM
+05:25PM
+05:28PM
+05: 33PM
+05:46PM
+05:53PM
+05: 55PM
+05: 59PM
+06:03PM
+06: 05PM
+06:07PM
+06:12PM
+07:01PM
+
+954-801-8575
+954-675-4802
+772-321-2693
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+INCOMI CL
+W PAIM FI
+INCOMI CL
+W PALM FL
+W PAIM FI
+800 BE CL
+FTLAUD FL
+INCOMI CL
+INCOMI
+CL
+W PAIM
+FL
+W PAIM FL
+VERO
+FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+7 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Rate Rate Feature Charge
+11
+9
+5
+12
+13
+2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+P
+P
+P
+IR
+IR
+R
+IR
+IR
+R
+RM
+IRM
+IRM
+P
+P
+IR
+IR
+Total
+Charge
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+114
+115
+116
+117
+118
+119
+120
+121
+122
+123
+124
+125
+126
+127
+128
+130
+131
+132
+133
+134
+135
+136
+137
+138
+139
+140
+141
+142
+144
+145
+146
+147
+148
+149
+150
+151
+152
+153
+154
+155
+Sat
+Sun
+Mon
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+CL
+CL
+07:28AM
+08:45AM
+08:51AM
+08: 56AM
+08: 56AM
+10: 48AM
+11:24AM
+12:12PM
+12:29PM
+02: 40PM
+02: 49PM
+02:50PM
+
+W PAIM FL
+W PALM FL
+800 SE CL
+W PAIM FL
+INCOMI
+CL
+W PAIM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+VERO B FL
+W PALM FL
+2
+8 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Rate Rate Feature Charge
+N
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+P
+P
+IR
+IR
+IRM
+IR
+IR
+R
+Total
+Charge
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+156
+157
+158
+159
+161
+162
+163
+164
+165
+166
+167
+168
+169
+170
+171
+172
+173
+175
+176
+177
+178
+179
+180
+181
+182
+183
+184
+185
+186
+187
+188
+190
+191
+192
+193
+194
+195
+196
+772-321-2693
+Tue
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+10:50PM
+10:57PM
+11:00PM
+11:06PM
+11:11PM
+11:13PM
+11:15PM
+11:16PM
+11:16PM
+786-266-8989
+01:17AM
+01:31AM
+08: 55AM
+10:11AM
+11:24AM
+11:51AM
+11:52AM
+12:08PM
+850-521-9988
+850-491-0739
+561-502-2324
+239-691-0711
+MIAMI
+FL
+CL
+INCOMI
+CL
+N PALM FL
+W PAIM FL
+W PAIM FI
+MIAMI
+FL
+INCOMI CL
+W PAIM FL
+W PAIM FL
+W PALM FL
+W PAIM FI
+TALLAH
+FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+FORT M FL
+9 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Rate Rate Feature Charge
+NPAZ
+2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+1 NPA2
+38 NPA2
+2 NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+26
+NPA2
+NPA2
+15
+NPAZ
+NPA2
+IRM
+IRW
+P
+P
+IRM
+IR
+IR
+IR
+IR
+Total
+Charge
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+850-644-1644
+216
+217
+218
+219
+220
+221
+222
+223
+224
+225
+226
+227
+228
+229
+230
+231
+232
+233
+234
+235
+236
+237
+238
+219
+Wed
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/05
+03:06PM
+03:30PM
+04: 41PM
+04:42PM
+04:44PM
+04:49PM
+04:56PM
+04:57PM
+05:02PM
+05: 06PM
+05:24PM
+05: 58PM
+06:16PM
+06: 43PM
+06:51PM
+08:30PM
+08:52PM
+09:03PM
+09:18PM
+09:30PM
+09: 40PM
+10:58PM
+11:08PM
+01:06AM
+850-644-1644
+772-321-2693
+561-876-2957
+772-321-2693
+786-266-8989
+772-321-2693
+772-121-2693
+772-321-2693
+786-266-8989
+772-321-2693
+772-321-2693
+561-309-1375
+TALLAH FL
+TALLAH
+FL
+W PALM FL
+VERO
+W PAIM FL
+VERO B
+FL
+MIAMI FL
+INCONI CL
+VERO B FL
+VERO B FL
+W PALM FL
+W PAIM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+INCOMI
+CL
+INCOMI
+CL
+MIAMI
+EL
+W PALM FL
+VERO B FI
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+10 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Rate Rate Feature Charge
+2
+1
+19
+13
+11
+12
+2
+10
+2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+INPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+HPAZ
+NPA2
+P
+IR
+P
+IR
+IR
+IR
+IRW
+IRW
+IRM
+Total
+Charge
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+240
+241
+242
+243
+245
+246
+247
+248
+249
+250
+251
+252
+253
+254
+255
+256
+257
+258
+259
+260
+261
+262
+263
+264
+265
+266
+267
+268
+269
+270
+271
+272
+273
+274
+275
+276
+277
+278
+279
+280
+291
+Day
+Thu
+04/05
+04/05
+04/05
+04/05
+04/05
+04/05
+04/05
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+07:19PM
+07: 31PM
+08: 06PM
+09:04PM
+09:47PM
+10:01PM
+10: 04PM
+12:59AM
+09:37AM
+09:39AM
+09: 48AM
+09:54AM
+09: 56AM
+10: 26AM
+10:27AM
+10:30AM
+10:38AM
+10: 49AM
+10:50AM
+10:51AM
+10: 56AM
+11:12AM
+11:14AM
+239-691-0713
+772-485-4893
+772-321-2693
+772-321-2693
+850-644-7161
+850-644-1644
+800-627-6872
+850-414-3300
+850-644-7161
+850-847-6299
+CL
+INCOMI
+CL
+W PALM FL
+FORT M FL
+INCOMI
+CL
+VERO B
+FL
+INCOMI CL
+W PALM FI
+W PAIM FL
+TALLAH FL
+TALLAH FL
+W PAIM FL
+W PAIM FL
+W PALM FL
+800 SE CL
+SE CL
+TALLAH
+FL
+W PALM FL
+INCOMI
+CL
+TALLAH
+FL
+TALLAH FI
+NEW YO
+NY
+W PAIM FL
+INCOMI CL
+43
+1
+1
+23
+12
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+P
+P
+P
+P
+11 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+ture Charge
+IR
+IRW
+INN
+IR
+IR
+Total
+Charge
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+292
+283
+284
+285
+Day
+287
+288
+299
+290
+291
+292
+293
+294
+295
+296
+297
+298
+299
+300
+301
+302
+303
+304
+305
+306
+307
+308
+309
+310
+311
+312
+313
+314
+315
+316
+317
+318
+319
+320
+321
+322
+323
+Eri
+Date
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+07
+07
+08
+10
+10
+10
+11
+09
+10
+10
+10
+11
+12
+12
+12
+12
+12
+12
+12
+12
+12
+12
+772-913-1587
+772-485-4893
+772-913-1587
+561-838-5400
+561-308-0347
+
+
+850-224-1100
+SEBAST FL
+INCOMI
+CL
+W PALM FL
+INCOMI
+CL
+W PAIM FL
+INCOMI
+CL
+INCOMI CI
+INCOMI
+CL
+W PAIM FI
+W PAIM FL
+W PALM FL
+INCOMI CL
+W PAIM FL
+800 8E CL
+W PALM FL
+INCOMI
+CL
+8.00
+SE
+CL
+W PAIM FL
+PALM
+FL
+W PALM
+FL
+W PALM
+FL
+INCOMI
+CL
+W PAIM FI
+TALLAH FL
+21
+2
+15
+1
+3
+12
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+P
+P
+P
+RM
+IRM
+IRW
+IRM
+IRW
+IR
+IR
+IR
+12 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Airtime LD
+DA
+Total
+Charge
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+324
+325
+326
+327
+328
+329
+330
+332
+333
+334
+335
+336
+337
+338
+339
+340
+341
+343
+344
+345
+346
+347
+348
+349
+350
+351
+352
+354
+355
+356
+357
+358
+359
+360
+361
+362
+363
+364
+365
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04/07
+04:58PM
+05:09PM
+05:09PM
+05:10PM
+05:23PM
+05: 29PM
+05:39PM
+06: 01PM
+06:15PM
+06:44PM
+06: 49PM
+06: 52PM
+06:53PM
+06:55PM
+06: 56PM
+06:59PM
+07:08PM
+07:38PM
+08:58PM
+08:58PM
+09: 06PM
+09:07PM
+09:11PM
+09:52PM
+850-251-1648
+
+772-913-1587
+
+
+800-529-4800
+561-239-0553
+2-AI-KETE
+772-321-2693
+772-913-1587
+772-321-2693
+INCOMI CL
+800 SE CL
+W PAIM FL
+PALM FL
+INCOMI
+CL
+CL
+800
+SE
+CL
+800 SE CL
+800 SE CL
+W PAIM FL
+INCOMI CL
+W PALM FL
+W PAIM FL
+W PAIM EL
+W PALM FL
+INCOMI CL
+INCOMI
+CL
+INCOMI
+CL
+VERO
+W PALM FL
+INCOMI
+CL
+INCOMI CL
+INCOMI CL
+FORT M FL
+VERO
+FL
+11
+NPA2
+NPA2
+12
+2
+NPA2
+NPA2
+NPAZ
+2
+1
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+2
+NPA2
+NPA2
+2
+NPA2
+NPA2
+1 NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+P
+P
+N
+13 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+ture Charge
+IR
+IR
+IRM
+R
+IRM
+IR
+IRM
+IR
+IR
+IRW
+Total
+Charge
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+CL
+FL
+561-714-6296
+394
+396
+397
+398
+399
+400
+401
+402
+403
+404
+405
+406
+407
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+12:50PM
+01:51PM
+01:53PM
+01:58PM
+02:50PM
+03:25PM
+04: 02PM
+04: 05PM
+05:41 PM
+05:49PM
+05: 49PM
+10:27PM
+10: 43PM
+772-321-2693
+
+561-767-0654
+INCOMI
+INCOMI CL
+W PAIM FL
+CL
+CL
+CL
+14 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Rate Rate Feature Charge
+N
+N
+NPA2
+NPA2
+NPA2
+1 NPA2
+1 NPA2
+2 NPA2
+NPA2
+2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+IRW
+N
+N
+IRW
+IRM
+IRW
+RK
+IRW
+Total
+Charge
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+408
+410
+411
+412
+413
+414
+415
+416
+417
+418
+419
+420
+421
+422
+423
+424
+425
+426
+427
+428
+429
+430
+431
+432
+433
+434
+435
+436
+437
+438
+439
+440
+441
+442
+443
+444
+445
+446
+447
+448
+449
+Day
+Mon
+Tue
+Date
+04/09
+04/09
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/11
+04/11
+04/11
+04/11
+04/11
+Time
+10:45PM
+11:59PM
+12:44AM
+12:45AM
+09:18AM
+10:31AM
+10:50AM
+10:59AM
+11: 32AM
+11:39AM
+11:46AM
+12:19PM
+12:20PM
+12:34PM
+12:41PM
+02: 44PM
+02:48PM
+03:22PM
+03:35PM
+03:59PM
+04:06PM
+04: 53PM
+04:54PM
+04:57PM
+05: 02PM
+05:10PM
+05:31 PM
+05:45PM
+06:11PM
+09:03PM
+09:04PM
+09:10PM
+09:16PM
+09:18PM
+09:21PM
+09:56PM
+10:11PM
+09: 46AM
+09: 56AM
+11:24AM
+01:23PM
+01:24PM
+CL
+Called
+954-588-8846
+
+786-266-9989
+772-219-4743
+561-379-7924
+561-351-6930
+772-321-2693
+321-663-5044
+561-351-6930
+561-351-6930
+772-321-2693
+321-663-5044
+772-321-2693
+772-321-2693
+Call To
+INCOMI CL
+INCOMI CL
+W PALM FL
+FTLAUD FL
+INCOMI
+CL
+W PAIM FL
+INCOMI
+CL
+W PALM FL
+W PAIM FL
+INCOMI
+CL
+800 SE CL
+W PAIN FL
+INCOMI
+CL
+W PAIM FL
+W PAIM FL
+MIAMI
+FL
+STUART FL
+INCOMI CL
+INCOMI
+INCOMI
+CL
+W PALM FL
+VERO
+SEBAST
+FL
+INCOMI
+CL
+INCOMI CL
+W PAIM FI
+INCOMI
+CL
+SEBAST FL
+INCOMI CL
+W PAIM FL
+INCOMI CL
+VERO B FL
+INCOMI CL
+W PAIM FL
+W PAIM FL
+INCOMI
+CL
+W PAIM FL
+W PAIM FL
+INCOMI CI
+INCOMI CL
+W PAIM FL
+W PALM FL
+15 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Rate Rate Fea-
+Min Code
+Pd
+ture Charge
+1
+NPA2 N
+IRM
+3
+NPA2 N
+IRW
+NPA2 N
+NPA2
+1
+15
+7
+7
+14
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPAZ
+NPAZ
+NPA2
+NPA2
+5
+2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+10
+NPA2
+NPA2
+2
+NPA2
+1
+NPA2
+3
+NPA2
+• NPA2
+1 NPA2
+1 NºA2
+1 NPA2
+9
+NPA2
+1
+NPA2
+2
+NPA2
+NPA2
+NPA2
+NPA2
+2
+NPA2
+NPA2
+P
+P
+P
+P
+P
+P
+P
+P
+IR
+IR
+IR
+R
+R
+IRM
+RM
+IR
+IR
+IR
+RM
+IR
+IRM
+IRM
+IR
+IRN
+IRW
+IRM
+R
+IR
+IR
+5.60
+1.60
+2.00
+4.00
+1.60
+DA
+Total
+Charge
+5.60
+1.60
+2.00
+4.00
+1.60
+
+
+User Name:
+16 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+450
+451
+452
+453
+454
+455
+456
+457
+458
+459
+460
+461
+462
+463
+464
+465
+466
+467
+468
+469
+470
+471
+472
+473
+474
+475
+476
+477
+478
+479
+480
+491
+482
+Day
+Wed
+484
+485
+486
+487
+488
+489
+490
+491
+Date
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/12
+04/12
+04/12
+04/12
+04/12
+04/12
+04/12
+04/12
+04/12
+Time
+01:28PM
+01:31PM
+01:47PM
+01:48PM
+02:45PM
+03:16PM
+03:25PM
+03: 46PM
+04:10PM
+04:23PM
+04:45PM
+04:52PM
+04:59PM
+04: 59PM
+05:00PM
+05: 00PM
+05: 03PM
+05: 25PM
+06:41PM
+06:42PM
+06:47PM
+06:49PM
+07: 09PM
+07:24PM
+07: 43PM
+07:48PM
+07:59PM
+07:59PM
+09:40PM
+10:33PM
+11:41PM
+11:56PM
+08:12AM
+08:14AM
+08: 43AM
+08: 43AM
+11: 45AM
+02: 06PM
+02:07PM
+02: 12PM
+CL
+Called
+786-266-8989
+772-121-2693
+561-876-2957
+240-138-2395
+850-294-9750
+561-308-0347
+954-801-8575
+239-691-0713
+239-691-0713
+561-876-2957
+561-308-0347
+954-801-8575
+240-338-2395
+240-338-2395
+850-644-7233
+240-338-2395
+239-691-0713
+Call To
+MIAMI
+FL
+VERO B FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+INCOMI
+CL
+W PAIM FL
+INCOMI
+CL
+SILVER
+MD
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+SEBAST FL
+SEBAST FL
+W PAIM FL
+INCOMI CL
+FORT M FL
+W PALM FL
+INCOMI
+CL
+W PAIM FL
+INCOMI
+CL
+INCOMI CL
+INCONI CL
+INCOMI
+CL
+W PAIM FL
+W PALM FL
+INCOMI CL
+FTLAUD EL
+SILVER MD
+W PALM FL
+VERO B FL
+INCOMI
+CL
+SILVER
+MID
+FL
+SILVER
+MD
+W PALM FL
+W PALM FL
+W PAIM FL
+FORT M EL
+Rate Rate Fea-
+Min
+Code
+Pd
+ture Charge
+3
+NPA2
+1 NPA2 P
+10
+NPA2 P
+NPA2
+P
+R
+IRM
+IR
+NPAZ
+NPAZ
+IR
+NPA2
+3
+NPA2
+NPAZ
+NPA2
+2.80
+NPA2
+NPAZ
+P
+NPA2
+NPA2
+NPA2
+NPAZ
+IR
+R
+IR
+IRM
+IR
+IR
+IR
+IRM
+RM
+2.80
+NPA2
+NPA2
+NPA2
+5
+NPA2
+NPA2
+NPAZ
+2
+2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+20
+NPA2
+2
+NPA2
+2 NPAZ
+1 NºA2
+NEAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+P
+P
+P
+P
+P
+R
+IRM
+IRM
+R
+IR
+IRM
+IR
+IR
+R
+IRW
+IR
+2.00
+2.40
+DA
+Total
+Charge
+2.80
+2.80
+2.00
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+17 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+P
+P
+
+
+User Name:
+18 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+551
+552
+553
+554
+555
+556
+557
+558
+559
+560
+561
+562
+563
+564
+565
+566
+568
+569
+570
+571
+572
+573
+574
+575
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+07: 51PM
+07:54PM
+07:55PM
+07:55PM
+07:56PM
+07:56PM
+07:57PM
+07:58PM
+07:58PM
+07:59PM
+08: 00PM
+08: 01PM
+08:05PM
+08:06PM
+08:15PM
+08:16PM
+08:24PM
+08:25PM
+08:26PM
+08:27PM
+08:45PM
+08: :45PM
+08:46PM
+08:49PM
+09:38PM
+786-266-8989
+772-219-4743
+772-485-4893
+772-219-4743
+772-485-4893
+772-485-4893
+772-219-4743
+772-485-4893
+772-219-4743
+772-485-4893
+772-219-4743
+772-219-4743
+772-485-4893
+772-485-4893
+772-219-4743
+954-776-4192
+786-266-8989
+772-321-2693
+772-219-4743
+772-321-2693
+954-675-4802
+MIAMI
+FL
+STUART FL
+STUART
+FL
+STUART
+FL
+STUART
+EL
+STUART
+FL
+STUART
+FL
+STUART FL
+STUART FL
+STUART FL
+STUART
+FL
+STUART FL
+STUART FL
+STUART EL
+STUART FL
+STUART FL
+MIAMI
+FL
+W PAIM FL
+FTLAUD
+FL
+DEEREL
+FL
+MIAMI
+FL
+VERO B
+FL
+STUART FL
+INCOMI
+CL
+DEEREL EL
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+1
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+1
+NPA2
+NPA2
+1 NPAZ
+7 NºA2
+1 NPA2
+NPA2
+NPA2
+18
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+12
+NPAZ
+P
+P
+P
+P
+P
+RM
+RM
+RM
+R
+RM
+R
+RM
+RM
+IR
+2.80
+2.80
+Total
+Charge
+.00
+.40
+2.80
+2.80
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+576
+577
+578
+579
+581
+582
+583
+584
+585
+586
+587
+588
+589
+590
+591
+592
+593
+594
+595
+596
+597
+598
+599
+600
+601
+602
+603
+604
+605
+606
+607
+608
+610
+611
+612
+613
+614
+615
+616
+617
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+10:11AM
+10:11AM
+10:12AM
+10:29AM
+11: 02AM
+11:07AM
+11:14AM
+11:23AM
+11: 36AM
+11:44AM
+11:47AM
+11: 49AM
+11: 52AM
+01:02PM
+02:16PM
+02:16PM
+02:18PM
+02:23PM
+02:31PM
+02: 40PM
+800-442-
+3426
+808-0H4C3GOG
+800-861-8380
+850-251-3979
+-2A-CEO
+850-251-3979
+850-552-0602
+772-219-4743
+786-266-8989
+850-552-0601
+772-219-4743
+CL
+800
+CL
+CL
+800
+SE
+CL
+INCOMI CI
+INCOMI
+CL
+TALLAH
+FL
+INCOMI
+CL
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM EL
+W PAIM FL
+STUART
+FL
+W PAIM FL
+MIAMI
+FL
+TALLAH
+FL
+INCOMI
+CL
+STUART FL
+W PAIM FL
+W PAIM FL
+19 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Rate Rate Feature Charge
+NPA2
+NPAZ
+NPA2
+1
+NPA2
+NPA2
+NPA2
+NPA2
+13
+NPA2
+NPA2
+NPA2
+NPA2
+2
+NPA2
+NPAZ
+34
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+2
+NPA2
+P
+R
+IR
+IR
+IR
+R
+IR
+IR
+RM
+IR
+2.00
+5.20
+13.60
+2.40
+Total
+Charge
+.40
+2.00
+5.20
+13.60
+2.40
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+618
+619
+620
+621
+622
+623
+624
+625
+626
+627
+628
+629
+630
+631
+632
+633
+634
+635
+636
+637
+638
+639
+640
+641
+642
+643
+644
+645
+646
+647
+648
+649
+650
+651
+652
+653
+654
+655
+656
+657
+658
+659
+Day
+Sat
+Sun
+Mon
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/15
+04/15
+04/15
+04/15
+04/15
+04/15
+04/15
+04/15
+04/15
+04/16
+04/16
+04/16
+04/16
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04:32PM
+04:44PM
+05: 31PM
+10: 05PM
+12:05AM
+12:13AM
+12: 13AM
+02: 22AM
+08:13AM
+11:00AM
+11:10AM
+01:07PM
+03:13PM
+11:54AM
+07:56PM
+10:44PM
+12:19AM
+09: 46AM
+09:57AM
+12:33PM
+01:05PM
+01:23PM
+IX
+IX
+JX
+JX
+561-767-0654
+561-714-6296
+772-321-2693
+904-955-0927
+904-955-0927
+904-955-0927
+772-485-4893
+772-485-4893
+850-499-9657
+INCOMI
+CL
+BOYTON
+FL
+INCOMI
+CL
+INCOMI
+CL
+JACKSO
+FL
+JACKSO FL
+JACKSO
+FL
+INCOMI
+CL
+INCOMI
+CL
+W PAIM FL
+INCOMI CL
+W PALM FL
+INCOMI CL
+STUART EL
+W PAIM FL
+PALM
+FL
+W PALM
+PALM
+FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PAIM FL
+FIWALT FL
+1
+2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+INPA2
+NEAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+N
+N
+N
+N
+P
+P
+20 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+IRM
+IR
+IRW
+IRM
+IRM
+IRW
+IRW
+IR
+Total
+Charge
+2.40
+1.60
+1.60
+1.60
+2.00
+2.40
+2.00
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+660
+661
+662
+663
+Day
+665
+666
+667
+668
+669
+670
+671
+672
+673
+674
+675
+676
+677
+678
+679
+680
+681
+682
+683
+684
+685
+686
+687
+688
+689
+690
+691
+692
+693
+694
+695
+696
+697
+698
+699
+700
+701
+Tue
+Date
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/18
+04/18
+04/18
+04/18
+04/18
+Time
+02:38PM
+04:09PM
+04:11PM
+04:18PM
+04:19PM
+04:30PM
+04: 31PM
+04:40PM
+04: 41PM
+04: 41PM
+04:44PM
+04:45PM
+04:47PM
+04:48PM
+04: 50PM
+04:52PM
+04:54PM
+04:55PM
+04:56PM
+05:06PM
+05:07PM
+05: 20PM
+05: 26PM
+05:37PM
+05: 48PM
+05: 50PM
+06:02PM
+06:12PM
+06:17PM
+06:20PM
+06:23PM
+06:26PM
+09:33PM
+09:35PM
+09:35PM
+09:36PM
+10:18PM
+09:34AM
+10:27AM
+10: 28AM
+10:50AM
+10:57AM
+CL
+Called
+561-379-7924
+772-485-4893
+772-485-4893
+850-644-1644
+561-355-7183
+772-485-4893
+772-219-4743
+850-552-0602
+772-219-4743
+772-321-2693
+772-321-2693
+772-321-2693
+772-321-2693
+
+321-663-5044
+772-321-2693
+772-321-2693
+321-663-5044
+321-663-5044
+321-663-5044
+Call To
+INCOMI CL
+INCOMI CL
+INCOMI CL
+TALLAH FL
+TALLAH FL
+W PAIM FL
+W PAIM FL
+W PALM FL
+STUART
+FL
+STUART FL
+INCOMI
+CL
+TALLAH FL
+W PAIM FL
+N PAIM FL
+STUART FL
+W PAIM FL
+W PAIM FL
+VERO B FL
+W PAIM FL
+VERO
+B FL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+SEBAST
+FL
+INCOMI CL
+SEBAST FL
+SEBAST
+FL
+SEBAST
+FL
+800
+8E
+CL
+W PAIM FL
+INCOMI CL
+INCOMI CL
+W PAIM FL
+VERO
+B FL
+W PAIM FL
+INCOMI
+CL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+ORLAND FL
+Min
+Code
+NPA2
+NPAZ
+P
+NPA2
+1
+11
+NPA2
+NPAZ
+NPAZ
+9
+NPA2
+NPA2
+NPAZ
+NPA2
+2
+NPA2
+NPAZ
+P
+NPA2
+2
+2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+2
+2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+2
+1
+NPA2
+NPA2
+NPA2
+5 NPA2
+2 NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+P
+Pd
+ture
+IRM
+IRM
+IRM
+R
+R
+IRM
+R
+IR
+IR
+IR
+R
+IR
+IR
+IRW
+R
+IR
+IR
+IR
+21 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+DA
+4.40
+1.60
+2.00
+Total
+Charge
+4.40
+1.60
+.40
+.40
+2.00
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Feature:
+1=PTT
+d=Directory
+Assisti
+K=Fax Call; M=Mi
+R-Roam with Hom
+Item
+702
+703
+704
+705
+706
+707
+708
+709
+710
+711
+712
+713
+714
+715
+716
+717
+718
+719
+720
+721
+722
+723
+724
+725
+726
+727
+728
+729
+730
+731
+732
+733
+734
+735
+736
+737
+738
+739
+740
+741
+742
+743
+Day
+Wed
+Date
+04/1g
+04/18
+04/18
+04/18
+04/18
+04/18
+04/18
+04/18
+04/18
+04/18
+04/18
+04/18
+04/18
+04/18
+04/18
+04/18
+04/18
+04/18
+04/18
+04/18
+04/18
+04/18
+04/18
+04/18
+04/18
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+22 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Rate Rate Fea-
+Total
+Charge
+7.20
+2.40
+2.80
+44.80
+2.00
+1.60
+1.60
+4.40
+2.00
+9.20
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Fe
+d=
+K=
+R=
+Item
+744
+745
+746
+747
+748
+749
+750
+751
+752
+753
+754
+755฿
+756
+757
+758฿
+759
+760
+761
+762
+763
+764
+765
+766
+767
+768
+769
+770
+771
+772
+773
+774
+775
+776
+Day
+Thu
+778
+779
+780
+781
+782
+783
+784
+785
+Date
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/20
+04/20
+04/20
+04/20
+04/20
+04/20
+04/20
+04/20
+04/20
+04/20
+04/20
+04/20
+04/20
+04/20
+04/20
+Time
+01:13PM
+02:25PM
+02:25PM
+02: 34PM
+02: 35PM
+02:42PM
+02: 59PM
+03:19PM
+03: 30PM
+04:20PM
+04:34PM
+04: 40PM
+05:46PM
+08: 05PM
+08:08PM
+08:20PM
+08:22PM
+08:29PM
+09:04PM
+09:15PM
+09:32PM
+09:49PM
+09:49PM
+10:13PM
+10:16PM
+11: 02PM
+11:22PM
+09:45AM
+09:49AM
+09: 53AM
+10: 03AM
+10:14AM
+10: 28AM
+12:04PM
+01:00PM
+01:10PM
+01:46PM
+03:06PM
+03:10PM
+03:13PM
+03:23PM
+03:29PM
+CL
+Called
+772-321-2693
+850-644-7161
+850-644-7161
+772-321-2693
+904-276-3100
+
+904-276-3100
+561-
+561-714-571
+321-663-5044
+850-521-9988
+850-591-2620
+954-588-8846
+772-121-2693
+954-588-8846
+239-691-0713
+239-691-0713
+772-321-2693
+561-309-1375
+850-942-6800
+850-942-6800
+890-942-0800
+CL
+CL
+EL
+CL
+CL
+CL
+CL
+CL
+CL
+B EL
+CL
+FL
+CL
+FL
+FL
+FL
+Min
+Code
+2
+NPA2
+1 NPA2
+NPA2
+1
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+P
+NPAZ
+NPA2
+NPA2
+2
+NPA2
+NPAZ
+54
+NPA2
+NPA2
+17
+17
+NPA2
+NPA2
+NPA2
+26
+NPAZ
+NPAZ
+2
+NPA2
+2
+NPA2
+NPA2
+1
+NPA2
+NPA2
+NPA2
+2 NPAZ
+2 NPA2
+2 NPA2
+1 NPAZ
+2
+NPA2
+1
+NPA2
+NPA2
+NPA2
+NPA2
+2
+NPA2
+NPA2
+NPA2
+P
+P
+Pd
+IR
+ture
+R
+IR
+IR
+IRM
+RM
+IR
+IR
+IR
+IR
+IRW
+IRM
+IRM
+IRN
+R
+IR
+IR
+IRM
+R
+IRM
+23 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Charge
+1.60
+2.40
+1.60
+2.00
+1.60
+21.60
+DA
+0.90
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate
+Period
+Call
+To:
+Feature:
+1=l
+d=Directory
+K=Fax Call;
+R=Roam wil
+Item
+786
+787
+798
+789
+Day
+791
+792
+793
+794
+795
+796
+797
+798
+799
+800
+Fri
+802
+803
+804
+805
+806
+807
+808
+809
+810
+811
+812
+813
+814
+816
+817
+818
+Sat
+820
+821
+822
+823
+824
+825
+826
+827
+CL
+24 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Rate Rate Fea-
+N
+N
+N
+Total
+Charge
+5.60
+2.80
+4.80
+6.00
+5.60
+2.80
+1.60
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+828
+829
+830
+831
+832
+833
+834
+835
+836
+837
+838
+839
+840
+841
+842
+843
+844
+845
+846
+847
+848
+849
+851
+852
+853
+854
+855
+856
+857
+858
+859
+860
+861
+862
+863
+864
+865
+866
+867
+868
+Day
+Sun
+Date
+04/22
+04/22
+04/22
+04/22
+04/22
+04/22
+04/22
+04/22
+04/22
+04/22
+04/22
+04/22
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+Time
+05:37PM
+05:42PM
+05: 42PM
+05: :43PM
+06:37PM
+06: 49PM
+08:58PM
+10:13PM
+11:41PM
+11:42PM
+11:48PM
+12:47AM
+12: 49AM
+12: 51AM
+01:09AM
+01:31AM
+02: 25AM
+10:23AM
+12:14PM
+12:54PM
+01:04PM
+01:20PM
+01:21PM
+01:21PM
+01:22PM
+01:22PM
+01:22PM
+01:23PM
+01:25PM
+01:28PM
+01:29PM
+01:36PM
+01:50PM
+02:14PM
+02: 32PM
+03:31PM
+04:08PM
+04: 51PM
+05:05PM
+06:08PM
+06:09PM
+CL
+Called
+904-272-3799
+850-499-9657
+561-714-6296
+772-321-2693
+772-321-2693
+561-635-6181
+772-321-2693
+772-321-2693
+772-321-2693
+772-321-2693
+904-272-3799
+561-714-6296
+772-321-2693
+772-121-2693
+850-499-9657
+772-321-2693
+Call To
+INCOMI CL
+W PAIM FL
+ORANGE FL
+W PAIM FL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+N PAIM FL
+VERO B FL
+INCOMI CI
+INCOMI CL
+W PAIM FL
+VERO B FL
+INCOMI CL
+INCOMI CL
+W PAIM FL
+W PALM FL
+INCOMI CL
+INCOMI
+CL
+VERO
+FL
+W PALM FL
+INCOMI
+CL
+W PAIM FL
+W PALM FL
+ORANGE FL
+W PAIM FL
+W PAIM FL
+W PALM FL
+W PAIM FL
+INCOMI CL
+W PALM FL
+INCOMI
+INCOMI
+INCOMI
+INCOMI
+CL
+CL
+CL
+CL
+W PALM
+FL
+INCOMI
+CL
+FIWALT
+FL
+INCOMI
+CL
+VERO B FL
+Min
+Code
+1
+NPA2
+N
+1
+NPA2
+N
+NPA2
+NPA2
+33
+3
+2
+2
+1
+2
+17
+1
+2
+4
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPAZ
+NPAZ
+NPA2
+17
+40
+21
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NEAZ
+NPA2
+NPA2
+NPA2
+NPA2
+INPA2
+NPA2
+NPA2
+NPA2
+N
+N
+N
+25 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Pd
+ture Charge
+IRW
+DA
+IRM
+IRW
+IRW
+IRW
+IRW
+IRW
+IRN
+IRN
+IRW
+IRN
+IRN
+IRW
+IRM
+IRM
+IRW
+IRW
+IRM
+Total
+Charge
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+870
+971
+872
+873
+Day
+875
+876
+877
+Mon
+879
+880
+881
+882
+883
+884
+886
+887
+889
+890
+891
+892
+893
+894
+895
+896
+897
+898
+899
+900
+901
+902
+903
+904
+905
+906
+907
+908
+909
+910
+911
+Tue
+CL
+FL
+26 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+P
+P
+P
+Total
+Charge
+1.60
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+912
+913
+914
+915
+916
+917
+918
+919
+920
+921
+922
+923
+924
+925
+926
+927
+928
+929
+930
+931
+932
+933
+934
+935
+936
+937
+938
+939
+940
+942
+943
+944
+946
+947
+948
+949
+950
+951
+952
+953
+Hed
+CL
+CL
+12:54PM
+04/26
+04/26
+04/26
+04/26
+04/26
+04/26
+04/26
+04/26
+04/26
+04/26
+04/26
+04/26
+03:27PM
+03: 31PM
+03: 35PM
+03:39PM
+04:32PM
+05:15PM
+05: 45PM
+05: 56PM
+06: 08PM
+07:01PM
+07:02PM
+07:07PM
+321-663-5044
+321-663-5044
+850-559-4435
+INCOMI CL
+INCOMI CL
+ORLAND FL
+INCOMI
+CL
+INCOMI
+CL
+TALLAH
+W PAIM
+FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PAIM FL
+VERO
+FL
+4
+1
+P
+P
+P
+27 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+IR
+IR
+IRM
+IR
+RM
+R
+IR
+1.60
+2.00
+Total
+Charge
+5.60
+2.00
+20.80
+3.20
+1.60
+2.00
+
+
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+Day
+Date
+954
+04/26
+955
+04/26
+956
+04/26
+957
+04/26
+958
+04/26
+959
+04/26
+960
+04/26
+961
+04/26
+962
+Thu
+04/27
+963
+04/27
+964
+04/27
+965
+04/27
+966
+04/27
+967
+04/27
+968
+04/27
+969
+04/27
+970
+04/27
+971
+04/27
+972
+04/27
+973
+04/27
+974
+04/27
+975
+04/27
+976
+04/27
+977
+04/27
+978
+04/27
+979
+04/27
+980
+04/27
+981
+04/27
+982
+04/27
+983
+04/27
+984
+04/27
+985
+04/27
+986
+04/27
+987
+04/27
+988
+04/27
+989
+Fri
+04/28
+990
+04/28
+991
+04/28
+992
+04/28
+993
+04/28
+994
+04/28
+995
+04/28
+Time
+07:23PM
+07: 38PM
+07:56PM
+11:00PM
+11:01PM
+11:09PM
+11: 51PM
+11:53PM
+12: 47AM
+09: 49AM
+09: 50AM
+11:48AM
+11: 50AM
+11:54AM
+12: 02PM
+12:20PM
+12:29PM
+01:56PM
+01:57PM
+02:58PM
+03:23PM
+03:38PM
+03:48PM
+03:49PM
+05:53PM
+06:08PM
+06: 59PM
+07:26PM
+10:05PM
+10:11PM
+10:16PM
+10:19PM
+10:21PM
+10:27PM
+12: 02AM
+12:14AM
+12:19AM
+12: 26AM
+02: 56AM
+04:00AM
+04:11AM
+CL
+561-714-6296
+772-485-4893
+772-219-4743
+772-321-2693
+850-521-9988
+305-724-8214
+772-321-2693
+772-321-2693
+772-321-2693
+772-321-2693
+Call To
+INCOMI CL
+W PAIM FL
+INCOMI CL
+800 SE CL
+INCOMI CL
+800
+SE CL
+INCOMI
+CL
+VERO B EL
+W PAIM FL
+TALLAH FL
+TALLAH FL
+W PAIM FL
+W PAIM FL
+STUART FL
+INCOMI CL
+W PAIM FL
+W PAIM FL
+W PALM FL
+W PAIM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+ORANGE
+FL
+INCOMI CL
+INCOMI CL
+W PAIM FL
+INCOMI
+CL
+INCOMI CL
+STUART FL
+W PALM FL
+VERO B FL
+W PALM FI
+INCOMI CL
+W PAIM FL
+TALLAH
+FL
+W PALM
+FL
+INCOMI
+CL
+VERO B
+FL
+VERO B FL
+INCOMI CL
+INCOMI CL
+Min
+15
+1
+2
+12
+1
+N
+2
+15
+14
+5
+3
+28 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Rate Rate Fea-
+Pd
+ture
+P
+P
+IR
+R
+IR
+P
+P
+P
+IRW
+IRW
+RM
+IR
+IR
+IR
+IR
+IR
+R
+IR
+IR
+IR
+IRM
+IRW
+Charge
+6.00
+DA
+5.60
+2.40
+6.00
+5.60
+1.60
+RK
+IRM
+IRM
+Total
+Charge
+6.00
+5.60
+2.40
+6.00
+5.60
+1.60
+
+
+User Name:
+29 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+996
+997
+998
+999
+1000
+L001
+1002
+2003
+1004
+1005
+1006
+1007
+1008
+1009
+1010
+1011
+1012
+1013
+1014
+1015
+1016
+1017
+1018
+1019
+1020
+1021
+1022
+1023
+2024
+1025
+1026
+1027
+1028
+1029
+1030
+1031
+1032
+1033
+1034
+1035
+1036
+Day
+CL
+01:37PM
+04/28
+04/28
+04/28
+04/28
+04/28
+04/28
+04/28
+04/28
+04/28
+04/28
+04/28
+04/28
+04/28
+04/28
+04/28
+04/28
+04/28
+04/28
+04/28
+04/28
+04/28
+04/28
+04/28
+02:28PM
+02: 31PM
+02: 31PM
+02: :32PM
+02:32PM
+02: 33PM
+02: 33PM
+02:35PM
+02:37PM
+02:38PM
+03:06PM
+03:09PM
+03:21PM
+03:23PM
+03:29PM
+03:32PM
+03:37PM
+05: 58PM
+07:00PM
+11:46PM
+11: 52PM
+11:52PM
+MI
+MI
+850-644-
+850-644-1644
+850-644-1234
+850-644-1234
+850-644-1644
+850-644-1234
+772-219-4743
+239-691-0713
+INCOMI CL
+INCOMI
+CL
+TALLAH
+FL
+TALLAH
+TALLAH
+FL
+TALLAH
+FL
+TALLAH FL
+TALLAH FL
+INCOMI CL
+W PAIM FL
+W PALM FL
+W PAIM FL
+STUART FL
+INCOMI CL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+FORT M FL
+W PAIM FL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+1
+2
+3
+10
+2
+14
+NPAZ
+NPA2
+NPA2
+P
+P
+P
+P
+P
+IR
+IR
+R
+R
+R
+IRM
+R
+R
+IR
+IR
+IR
+IR
+RM
+R
+40
+20
+0.
+40
+0.
+40
+0.
+40
+4.00
+Total
+Charge
+4.80
+3.20
+.20
+.40
+4.00
+
+
+30 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+CL
+1037
+561-379-7924
+Call To
+INCOMI CL
+Rate Rate Fea- Airtime
+Min Code Pd ture Charge
+1 NPA2
+Totals
+11:55PM
+Subtotal Miast2s
+3542
+506.80
+506.80
+0.00 506.80
+DA
+Total
+Chargo
+Roaming Call Detail
+User Name:
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Feature: 1=PTT One-to-One event: a=Automated Call Return; B=Direct Asst Call Complete; C=Call Waiting: D=Data Call;
+d=Directory Assistance Call; F=Call Forwarding: g=PTT Group event; H=Group Mobile to Mobile Calls; I=Incoming Call:
+K=Fax Call; M=Mobile To Moble Discount; N=Ot-Network; O-
+=Roam with Home: S=Shared Minutes: I=Three Way Calling:
+- Voice Activated Crime: =-Night and ekeve: Q- -VPS
+Rate
+Fea- Airtime
+ture
+Anarge Charge
+Intl
+Tax
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Thu
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/30
+03/30
+03/30
+03/30
+03/30
+03:41PM
+03:41PM
+03:44PM
+04:29PM
+06: 00PM
+06: 04PM
+06:17PM
+06:27PM
+08:29PM
+09:18PM
+12:34AM
+12: 04PM
+12:55PM
+01:29PM
+02:23PM
+786-266-8989
+MIAMI
+FL
+786-266-8999
+MIAMI
+FL
+561-876-2957
+W PALM FL
+561-876-2957 N PALM FL
+772-321-2693 VERO B FL
+561-714-5714 W PALM FL
+772-321-2693 VERO B FL
+772-321-2693 VERO B FL
+561-792-6375 N PALM FL
+561-714-5714 N PALM FL
+561-714-5714 W PALM FL
+561-714-5714 N PALM FL
+561-207-0257 N PALM FL
+561-207-0257 N PALM FL
+954-801-8575
+FILAUD FL
+NPA2
+1 NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+Total
+Charg
+
+
+Billing Cycle Date:
+Account Number:
+31 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Roaming Call Detail (Continued)
+User Name:
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Fee or AT One Cal, Cal atoning Call meet a Cole to CoCain coming Call
+Number
+Called
+Charge
+Item Day
+26
+27
+28
+29
+10
+31
+32
+33
+34
+35
+36
+37
+38
+39
+40
+41
+42
+43
+44
+45
+46
+47
+Date
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+03/30
+Fri
+03/31
+03/31
+49
+03/31
+Time
+02: 43PM
+05: 22PM
+05: 48PM
+05: :51PM
+05: 53PM
+05: 56PM
+06: 00PM
+06:21PM
+06:23PM
+06:24PM
+06:24PM
+06:25PM
+06:26PM
+08:15PM
+09:04PM
+09:08PM
+09:31PM
+10:44PM
+10: 48PM
+11:10PM
+11:17PM
+08:30AM
+08:58AM
+09:13AM
+50
+03/31
+51
+03/31
+52
+03/31
+53
+03/31
+54
+03/31
+55
+03/31
+56
+03/31
+57
+03/31
+58
+03/31
+59
+03/31
+60
+03/31
+61
+03/31
+62
+03/31
+63
+03/31
+64
+03/31
+65
+03/31
+66
+03/31
+Charges
+Incurred
+While
+67
+Sat
+04/01
+04:27PM
+68
+Sun
+04/02
+10: 45AM
+Charges
+Incurred
+While
+69
+04/02
+08:30PM
+70
+04/02
+09:42PM
+tax
+561-714-
+561-
+239-691-0713
+772-321-2693
+561-714-571
+E'L
+7 NPA2
+NPA2
+1
+NPA2
+1
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+1
+7
+NPA2
+NPA2
+NPA2
+2 NPA2
+Total
+Chargi
+
+
+32 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Roaming Call Detail (Continued)
+User Name:
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Feature ory at me Cal tell Earning a rome coal Come to Cal at coming Cal:
+Item Day
+71
+72
+Mon
+73
+74
+75
+76
+77
+78
+79
+80
+81
+82
+83
+84
+85
+88
+89
+90
+91
+92
+93
+94
+95
+96
+97
+98
+99
+100
+101
+102
+Tue
+104
+105
+106
+107
+Date
+04/02
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+11:23PM
+07:29AM
+08: 45AM
+08: 56AM
+10: 48AM
+02:49PM
+02: 50PM
+04: 32PM
+04: 50PM
+05: 00PM
+05: 00PM
+05: 03PM
+05:05PM
+05: 06PM
+05: 28PM
+05: 30PM
+06: 08PM
+09: 02PM
+09: 03PM
+09:08PM
+10:57PM
+11:00PM
+11:07PM
+11:11PM
+11:14PM
+11:16PM
+11:16PM
+11:16PM
+11:24AM
+12:08PM
+12:14PM
+12:23PM
+12:23PM
+01:10PM
+01:12PM
+01:17PM
+01:40PM
+Number
+Call To Min Rade Fure Anarge charge
+772-321-2693 VERO B FL
+1
+361-714-5714 N PALM FL
+561-714-5714 N PALM FL
+1
+561-714-5714 N PALM FL
+561-714-5714 N PALM FL
+772-321-2693
+VERO B FL
+PALM FL
+772-321-2693
+B FL
+904-651-4326
+JACKSO FL
+772-321-2693 VERO B FI
+786-266-8989 MIAMI
+FL
+786-266-8989 MIAMI
+FL
+786-266-8989 MIAMI
+FL
+561-818-3331 N PALM FL
+904-955-0927 JACKSO FL
+772-321-2693 VERO B FL
+772-321-2693 VERO B FL
+904-651-4326 JACKSO FL
+561-714-5714 W PALM FL
+561-714-5714 W PALM FL
+561-714-571
+W PALM FL
+PALM FL
+W PALM FL
+786-266-8989 MIAMI
+FL
+561-714-5714 W PALM FL
+561-714-5714 W PALM FL
+561-714-5714 W PALM FL
+561-714-5714 W PALM FL
+561-714-5714 N PALM FL
+38
+26
+239-691-0713 FORT M FL
+904-955-0927 JACKSO FL
+239-691-0713 FORT M FL
+239-691-0713 FORT M FL
+786-266-8989
+MIAMI
+FL
+904-955-0927
+JACKSO FL
+W PALM FL
+239-691-0713
+FORT M FL
+561-876-2957 N PALM FL
+Ta:
+Total
+Chargi
+.00
+1.00
+. 00
+. 00
+
+
+33 of 45
+Billing Cycle Date:
+03/29/06 - 04/28/06
+Account Number:
+06091813-001-03
+Roaming Call Detail (Continued)
+User Name:
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Fee or AT One Cal, Cal aroman Call meet a Cole to CoCain coring Call:
+Item Day
+118
+119
+120
+121
+122
+123
+124
+125
+126
+127
+128
+129
+Thu
+130
+131
+132
+133
+134
+135
+136
+137
+138
+139
+140
+141
+142
+143
+144
+Fri
+145
+146
+147
+148
+149
+150
+151
+152
+153
+154
+155
+156
+157
+158
+159
+160
+161
+162
+163
+164
+Date
+Time
+04/05
+09: 50AM
+04/05
+10:25AM
+04/05
+10:46AM
+04/05
+11:45AM
+04/05
+11: 47AM
+04/05
+04:53PM
+04/05
+04: 54PM
+04/05
+07: 31PM
+04/05
+08:06PM
+04/05
+09:47PM
+04/05
+10: 05PM
+04/06
+12: 59AM
+04/06
+09:48AM
+04/06
+09:54AM
+04/06
+09: 56AM
+04/06
+10:38AM
+04/06
+10:57AM
+04/06
+11:13AM
+04/06
+01:40PM
+04/06
+04:34PM
+04/06
+05:13PM
+04/06
+05:38PM
+04/06
+06: 03PM
+04/06
+07:12PM
+04/06
+08:17PM
+04/06
+10:33PM
+04/07
+10:04AM
+04/07
+10:16AM
+04/07
+10: 17AM
+04/07
+12:00PM
+04/07
+12:04PM
+04/07
+12: 07PM
+04/07
+12: 08PM
+04/07
+12:27PM
+04/07
+12:44PM
+04/07
+12:47PM
+04/07
+02:10PM
+04/07
+02:53PM
+04/07
+03:47PM
+04/07
+04:25PM
+04/07
+04:58PM
+04/07
+05:10PM
+04/07
+06:45PM
+04/07
+06:52PM
+04/07
+06:54PM
+04/07
+06: 55PM
+04/07
+06:56PM
+Number
+Called
+Call Min Code
+561-714-5714 W PALM FL
+561-876-2957 N PALM FL
+561-714-5714 N PALM FL
+239-691-0713 FORT M FL
+1
+1
+1
+772-321-2693
+VERO
+B FL
+239-691-0713
+FORT
+M FL
+239-
+FORT
+M FL
+561-
+W PALM FL
+239-691-0713 FORT M FL
+772-321-2693 VERO B FL
+561-714-5714 W PALM FL
+561-714-5714 N PALM FL
+561-792-6375 W PALM FL
+561-714-5714 N PALM FL
+561-714-5714 W PALM FL
+561-792-6375 N PALM FL
+NEW YO NY
+12
+561-792-6375 W PALM FL
+561-792-6375 W PALM FL
+1
+561-207-0257 W PALM FL
+W PALM FL
+11
+PALM FL
+561-308-0347
+W PALM FL
+29
+772-913-1587 SEBAST FL
+561-714-5714 N PALM FL
+561-714-5714 W PALM FL
+561-792-6375 W PALM FL
+561-838-5400 W PALM FL
+561-308-0347 N PALM FL
+561-714-5714 N PALM FL
+561-207-0257 N PALM FL
+561-714-5714 N PALM FL
+561-714-5714 W PALM FL
+12
+561-207-0257 W PALM FL
+561-207-0257 N PALM FL
+W PALM FL
+239-691-0713 FORT M FL
+561-714-5714 W PALM FL
+786-266-8989 MIAMI
+FL
+786-266-8989 MIAMI
+FL
+561-792-6375 W PALM FL
+561-792-6375 N PALM FL
+12
+561-714-5714 N PALM FL
+561-714-5714 N PALM FL
+561-714-5714 W PALM FL
+561-714-5714 W PALM FL
+561-714-5714 N PALM FL
+TaX
+Total
+Chargi
+.00
+
+
+Billing Cycle Date:
+Account Number:
+34 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Roaming Call Detail (Continued)
+User Name:
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item Day
+165
+166
+167
+168
+169
+170
+Sat
+171
+172
+173
+174
+175
+176
+Sun
+177
+178
+179
+180
+181
+192
+184
+185
+186
+187
+188
+199
+190
+191
+192
+193
+194
+195
+196
+197
+198
+199
+200
+201
+202
+203
+204
+205
+206
+207
+208
+209
+210
+211
+Mon
+Date
+04/07
+04/07
+04/07
+04/07
+04/07
+04/08
+04/08
+04/08
+04/08
+04/08
+04/08
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/09
+04/10
+04/10
+04/10
+04/10
+04/10
+Time
+07: 39PM
+08:58PM
+09:12PM
+09:53PM
+09:54PM
+09:38AM
+11:59AM
+02: 22PM
+02: 54PM
+10:23PM
+10: 53PM
+12:15AM
+12:15AM
+12:17AM
+12:27AM
+01: 33AM
+11: 43AM
+12: 02PM
+12:10PM
+12:11PM
+01: 50PM
+01:52PM
+01:53PM
+04:02PM
+05: 41PM
+05: 49PM
+05:50PM
+10: 44PM
+12: 44AM
+12: 46AM
+10:32AM
+10:59AM
+11: 32AM
+Called
+Call To Min Code
+772-321-2693 VERO B FL
+NPA2
+561-714-5714 N PALM FL
+NPA2
+239-691-0713 FORT M FL
+NPA2
+772-321-2693 VERO B FL
+NPA2
+561-207-0257 N PALM FL
+NPA2
+PALM FL
+NPAZ
+772-485-4893
+STUART
+FL
+NPA2
+W PALM FL
+NPA2
+N PALM FL
+NPAZ
+786-266-8989 MIAMI
+FL
+NPA2
+772-321-2693 VERO B FL
+NPA2
+904-651-4326 JACKSO FL
+NPA2
+904-651-4326 JACKSO FL
+NPAZ
+904-651-4326 JACKSO FL
+NPA2
+904-651-4326 JACK80 FL
+NPA2
+772-321-2693 VERO B FL
+NPA2
+772-321-2693 VERO B FL
+NPA2
+561-714-6296 W PALM FL
+NPA2
+561-792-1446 W PALM FL
+NPA2
+561-767-0654 BOYTON FL
+NPA2
+W PALM FL
+NPA2
+772-360-6791
+VERO B FL
+NPA2
+772-321-2693
+VERO B FL
+NPA2
+772-360-6781 VERO B FI
+NPAZ
+772-360-6781 VERO B FL
+NPA2
+772-360-6781 VERO B FL
+NPA2
+561-207-0257 W PALM FL
+NPA2
+561-714-5714 N PALM FL
+NPA2
+561-714-5714 N PALM FL
+NPA2
+954-588-8846 FTLAUD FL
+NPA2
+561-714-5714 N PALM FL
+NPA2
+561-714-5714 N PALM FL
+NPA2
+561-714-5714 N PALM FL
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+Total
+Chargi
+.00
+. 00
+1.00
+1.00
+1.00
+
+
+35 of 45
+Billing Cycle Date:
+03/29/06 - 04/28/06
+Account Number:
+06091813-001-03
+Roaming Call Detail (Continued)
+User Name:
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Fee or AT One Cal, Cal atoning Call meet al Cole to CoCain coring Call:
+Item Day
+213
+214
+215
+216
+217
+218
+219
+220
+221
+222
+223
+224
+225
+226
+227
+228
+229
+230
+231
+232
+233
+234
+235
+236
+237
+238
+239
+240
+241
+242
+243
+244
+245
+246
+247
+248
+249
+250
+251
+252
+253
+254
+255
+256
+257
+258
+Tue
+Red
+Thu
+Date
+04/10
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/12
+04/12
+04/12
+04/12
+04/12
+04/12
+04/12
+04/12
+04/12
+04/12
+04/12
+04/12
+04/12
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+04/13
+Time
+10:12PM
+09: 46AM
+01:23PM
+01:25PM
+01:28PM
+01:31PM
+02: 02PM
+03:16PM
+03:47PM
+05: 00PM
+05: 00PM
+05: 04PM
+06:41PM
+06: 43PM
+06:49PM
+07:59PM
+08: 00PM
+10:34PM
+11: 42PM
+11:56PM
+12: 22AM
+08:15AM
+08: 43AM
+11:45AM
+02:07PM
+02: 08PM
+02:12PM
+02:57PM
+03:47PM
+05: 05PM
+06:24PM
+10:58PM
+11:17PM
+09:28AM
+11:01AM
+11: 05AM
+11:10AM
+11:10AM
+12:12PM
+12:14PM
+12:18PM
+12:23PM
+03: 31PM
+03:34PM
+05: 32PM
+05: 53PM
+Number
+Called
+Call To Min Code
+561-714-5714 W PALM FL
+561-714-5714 N PALM FL
+1
+561-714-5714 W PALM FL
+561-792-6375 N PALM FL
+4
+786-266-8989 MIAMI
+FL
+772-321-2693
+VERO B FL
+561-876-2957
+W PALM FI
+W PALM FL
+240-338-2395 SILVER MD
+772-913-2153 SEBAST FI
+772-913-2153 SEBAST FI
+561-714-5714 N PALM FL
+1
+239-691-0713 FORT M FL
+561-714-5714 N PALM FL
+561-876-2957 W PALM FL
+561-714-5714 N PALM FL
+561-714-5714 W PALM FL
+954-801-8575 FILAUD FL
+240-338-2395 SILVER MD
+561-714-5714 W PALM FL
+772-321-2693
+VERO B FI
+240-338-2395 SILVER MD
+240-338-2395 SILVER MD
+561-792-6375 N PALM FI
+561-714-5714 N PALM FI
+561-792-6375 W PALM FL
+1
+239-691-0713 FORT M FL
+772-485-4893 STUART FL
+10
+772-913-1587 SEBAST FL
+561-792-6375 N PALM FL
+9
+772-321-2693 VERO B FL
+561-714-5714 W PALM FL
+786-266-8989 MIAMI
+FL
+561-714-5714 W PALM FL
+561-714-571
+PALM FL
+561-792-637
+PALM FL
+561-355-7183
+W PALM FL
+561-355-7363 N PALM FI
+561-714-5714 N PALM FL
+561-792-6375 N PALM FL
+561-790-3459 N PALM FL
+904-864-0861 JACKSO FL
+772-321-2693 VERO B FL
+786-266-8989 MIAMI
+FL
+561-502-2324 N PALM FL
+16
+561-714-5714 W PALM FL
+561-714-5714 N PALM FL
+taX
+Total
+Chargi
+.00
+1.00
+1.00
+. 00
+. 00
+
+
+Billing Cycle Date:
+Account Number:
+36 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Roaming Call Detail (Continued)
+User Name:
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+eDurectory Ariance Cal Feal Forwaring Cal Group even HAGroup Come to Cale Cals, Encoming Call.
+= Directory Assistance Call: F=Call Forwarding: g=
+Item Day
+259
+260
+261
+262
+263
+264
+265
+266
+267
+268
+269
+270
+271
+272
+273
+274
+275
+276
+277
+278
+279
+280
+281
+282
+293
+284
+285
+286
+287
+288
+289
+290
+291
+292
+293
+294
+295
+296
+297
+298
+299
+300
+Fri
+301
+302
+303
+304
+305
+Number
+Date
+Call To Min Rade Fure Anarge charge
+04/13
+772-321-2693 VERO B FL
+1
+04/13
+NPA2
+06:08PM
+772-321-2693 VERO B FL
+NEAZ
+04/13
+772-913-1587 SEBAST FL
+1
+NPA2
+04/13
+561-792-6375 N PALM FL
+1
+04/13
+561-792-6375 N PALM FL
+NPA2
+NPA2
+04/13
+NPAZ
+04/13
+NPA2
+04/13
+07:28PM
+772-485-4893
+STUART
+FL
+NPA2
+04/13
+07: 51PM
+786-266-8989
+MIAMI
+FL
+NPAZ
+04/13
+07: 54PM
+772-219-4743 STUART FL
+NPA2
+04/13
+07:55PM
+772-485-4893 STUART FL
+NPA2
+04/13
+07: 56PM
+772-219-4743 STUART FL
+NPA2
+04/13
+07:56PM
+772-485-4893 STUART FL
+NPA2
+04/13
+07:57PM
+772-485-4893 STUART FL
+NPA2
+04/13
+07:57PM
+772-219-4743 STUART FL
+NPA2
+04/13
+07:58PM
+772-485-4893 STUART FL
+NPA2
+04/13
+07:59PM
+772-219-4743 STUART FL
+NPA2
+04/13
+08: 00PM
+772-219-4743 STUART FL
+NPA2
+04/13
+08: 00PM
+772-485-4893 STUART FL
+NPA2
+04/13
+08:01PM
+772-219-4743
+STUART FL
+NPA2
+04/13
+08: 05PM
+772-219-4743
+STUART FL
+NPA2
+04/13
+08: 06PM
+772-485-4893
+STUART FL
+NPA2
+04/13
+08:16PM
+772-485-4893 STUART FL
+NPA2
+04/13
+08:16PM
+772-219-4743 STUART FI
+NPAZ
+04/13
+08:24PM
+786-266-8989 MIAMI
+FL
+NPA2
+04/13
+08:27PM
+954-675-4802 DEERFL FL
+18
+NPA2
+04/13
+08:45PM
+786-266-8989 MIAMI
+FL
+NPA2
+04/13
+08:45PM
+772-321-2693 VERO B FL
+NPA2
+04/13
+08: 46PM
+772-219-4743 STUART FL
+NPA2
+04/13
+09: 38PM
+954-675-4802 DEERFL FL
+12
+NPA2
+04/13
+10:08PM
+561-714-5714 N PALM FL
+1
+NPA2
+04/13
+10:16PM
+561-714-5714 N PALM FL
+NPA2
+04/13
+10:16PM
+904-272-3799 ORANGE FL
+NPA2
+04/13
+10:22PM
+954-588-8846 FTLAUD FL
+NPA2
+04/13
+10:23PM
+954-588-8846
+FTLAUD FL
+NPA2
+04/13
+10: 31PM
+954-588-8846
+FTLAUD FL
+NPA2
+04/13
+10:41PM
+239-691-0713 FORT M FL
+NPAZ
+04/13
+10:59PM
+561-714-5714 N PALM FL
+NPA2
+04/13
+11:04PM
+954-588-8846 FTLAUD FL
+NPA2
+04/13
+11:04PM
+561-714-5714 N PALM FL
+NPA2
+04/13
+11:19PM
+772-913-1587 SEBAST FL
+NPA2
+04/14
+01:38AM
+239-691-0713 FORT M FL
+NPA2
+04/14
+11: 24AM
+561-714-5714 N PALM FL
+13
+NPA2
+04/14
+11:48AM
+561-792-6375 N PALM FL
+NPA2
+04/14
+11: 49AM
+561-792-6375 W PALM FL
+NPA2
+04/14
+11:51AM
+561-792-6375 W PALM FL
+NPA2
+04/14 11:53AM 772-219-4743 STUART FL
+34
+NPA2
+taX
+Total
+Chargi
+
+
+Billing Cycle Date:
+Account Number:
+37 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Roaming Call Detail (Continued)
+User Name:
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+K=Fa
+R=Re
+Item Day
+306
+307
+308
+309
+310
+311
+312
+313
+314
+315
+316
+317
+Date
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+04/14
+Chai
+318
+Sat
+04/15
+319
+04/15
+320
+Sun
+04/16
+321
+04/16
+322
+04/16
+Charges Incurred
+323
+04/16
+324
+Mon
+04/17
+325
+04/17
+326
+04/17
+327
+04/17
+328
+04/17
+329
+04/17
+330
+04/17
+331
+04/17
+332
+04/17
+333
+04/17
+334
+04/17
+335
+04/17
+336
+04/17
+337
+04/17
+338
+04/17
+339
+04/17
+340
+04/17
+341
+04/17
+342
+04/17
+343
+04/17
+344
+04/17
+345
+04/17
+346
+04/17
+347
+04/17
+348
+04/17
+349
+04/17
+350
+04/17
+Time
+01:02PM
+02:16PM
+02:23PM
+02: :31PM
+02: 40PM
+02:43PM
+02: 59PM
+03:04PM
+03:10PM
+03: 43PM
+04:27PM
+04: 45PM
+11:01AM
+01:07PM
+11: 54AM
+11:56AM
+07:56PM
+10:44PM
+12: 19AM
+09:57AM
+12:33PM
+01:05PM
+01:23PM
+04:30PM
+04: 31PM
+04: 40PM
+04:41PM
+04:42PM
+04:48PM
+04:51PM
+04: 53PM
+04:54PM
+04:57PM
+05: 07PM
+05: 07PM
+05: 38PM
+05: 51PM
+06:03PM
+06:12PM
+09:33PM
+09:35PM
+09: 35PM
+09:36PM
+Call To Min Code
+2 NPA2
+FL
+NPA2
+9
+9
+NPA2
+NPA2
+NPA2
+PALM FL
+PALM FL
+PALM FL
+NPA2
+NPA2
+NPA2
+NPA2
+NEA2
+NPA2
+NPAŻ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+W PALM FL
+W PALM FL
+PALM FI
+VERO
+FL
+N PALM FL
+SEBAST FL
+SEBAST FL
+SEBAST FL
+SEBAST FL
+FL
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+TaX
+Total
+Chargi
+. 00
+
+
+Billing Cycle Date:
+Account Number:
+38 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Roaming Call Detail (Continued)
+User Name:
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Feature ory at me Cal tell atoning a rome coal Come to Cal at coming Cal:
+Item Day
+351
+Tue
+352
+353
+354
+355
+356
+357
+358
+359
+360
+361
+362
+363
+364
+365
+366
+Wad
+367
+368
+369
+370
+371
+372
+373
+374
+375
+376
+377
+378
+379
+380
+381
+382
+383
+384
+385
+Thu
+386
+387
+388
+389
+390
+391
+392
+393
+Fri
+394
+395
+396
+397
+Date
+Time
+04/18
+09: 35AM
+04/18
+10: 57AM
+04/18
+11: 50AM
+04/18
+11:51AM
+04/18
+12:54PM
+04/18
+12:55PM
+04/18
+04: 36PM
+04/18
+04: 55PM
+04/18
+04:59PM
+04/18
+06: 43PM
+04/18
+08:35PM
+04/18
+08:45PM
+04/18
+08:46PM
+04/18
+09:39PM
+04/18
+10: 35PM
+04/19
+08: 51AM
+04/19
+09:15AM
+04/19
+09:57AM
+04/19
+10: 34AM
+04/19
+11:27AM
+04/19
+11: 30AM
+04/19
+12:41PM
+04/19
+12: 42PM
+04/19
+02:34PM
+04/19
+03:19PM
+04/19
+03:31PM
+04/19
+05: :46PM
+04/19
+08:05PM
+Number
+Called
+Call To Min Code
+561-714-5714 N PALM FL
+321-663-5044 ORLAND FL
+361-792-6375 N PALM FL
+561-792-6375 N PALM FL
+2
+1
+954-435-7760 HOLLYN FL
+954-303-7531
+FTLAUD FL
+SEBAST FI
+321-663-5044
+ORLAND FI
+772-913-2153 SEBAST FI
+561-792-6375 N PALM FL 112
+772-321-2693 VERO B FI
+772-321-2693 VERO B FL
+561-207-0257 N PALM FL
+561-714-5714 N PALM FL
+772-321-2693 VERO B FL
+561-714-5714 N PALM FL
+561-714-5714 W PALM FL
+561-714-5714 W PALM FL
+561-714-5714 N PALM FL
+W PALM FL
+FI
+772-321-2693
+VERO
+B FI
+772-913-2153 SEBAST FI
+772-321-2693 VERO B FI
+772-913-2153 SEBAST FI
+561-714-5714 W PALM FL
+561-714-5714 N PALM FL
+561-792-6375 W PALM FL
+TaX
+Total
+Chargi
+.00
+.00
+F'TLAUD EL
+
+
+Billing Cycle Date:
+Account Number:
+39 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Roaming Call Detail (Continued)
+User Name:
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Of Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Fee or AT One Cal, Cal atoning Call meet a Cole to CoCain coring Call:
+Fax Call; M=Mobile To Mobile Discount, N=Off-Network; O=Auto Dropped Call Credit; P=Priority Access Service; Q=-VI
+Roam with Home; S=Shared Minutes; T=Three Way Calling: =Voice Activated Dialing: W=Night and Weeken
+Number
+Item Day
+Call To Min Code
+398
+13
+399
+1
+400
+3
+401
+2
+402
+403
+404
+Sat
+405
+406
+407
+21
+408
+409
+410
+411
+412
+413
+414
+Sun
+415
+416
+417
+418
+419
+420
+421
+422
+423
+424
+425
+426
+427
+428
+429
+430
+431
+432
+Mon
+434
+435
+436
+437
+438
+439
+440
+441
+442
+443
+444
+04/22
+04/22
+04/22
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/23
+04/24
+04/24
+04/24
+04/24
+04/24
+04/24
+04/24
+04/24
+04/24
+04/24
+04/24
+04/24
+04/24
+05: 45PM
+10:14PM
+11:41PM
+12: 48AM
+12: 49AM
+01: 31AM
+12:55PM
+01: 04PM
+01:21PM
+01:22PM
+01:22PM
+01:22PM
+01:23PM
+01:24PM
+01:25PM
+01:29PM
+04:08PM
+05:06PM
+06:10PM
+06:10PM
+09:50PM
+12:03AM
+09: 58AM
+11: 51AM
+12:05PM
+03:30PM
+04: :38PM
+04:53PM
+06:11PM
+06:20PM
+07:04PM
+08:14PM
+08:17PM
+08: 30PM
+561-714-5714 W PALM FL
+561-714-6296 W PALM FL
+772-321-2693 VERO B FL
+561-714-5714 W PALM FL
+772-321-2693 VERO B FL
+561-207-0257 N PALM FL
+772-321-2693 VERO B FL
+W PALM FL
+561-714-5
+N PALM FL
+561-714-5714 N PALM FL
+904-272-3799 ORANGE FL
+561-714-5714 W PALM FI
+561-714-5714 W PALM FL
+561-714-5714 W PALM FL
+561-792-6375 N PALM FL
+561-714-6296 N PALM FL
+561-792-6375 N PALM FL
+850-499-9657 FTWALT FL
+772-321-2693 VERO B FL
+772-321-2693 VERO B FL
+239-691-0713
+FORT M FL
+W PALM FL
+850-499-9
+850-499-9657
+FTWALT FL
+772-321-2693
+VERO B FL
+239-691-0713 FORT M FL
+239-691-0713 FORT M FL
+561-207-0257 N PALM FL
+904-651-4326 JACKSO FL
+561-714-5714 N PALM FL
+904-476-6114 JACKSO FL
+904-476-6114 JACKSO FL
+904-476-6114 JACKSO FL
+904-476-6114 JACKSO FL
+17
+4
+TaX
+Total
+Chargi
+.00
+. 00
+1.00
+.00
+
+
+40 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Roaming Call Detail (Continued)
+User Name:
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+-bectory Asiance Cal Escal Forwarning: S Group even Group Come Cale Cals Encoming Coll
+Item Day
+446
+Tue
+447
+448
+449
+450
+451
+452
+453
+454
+455
+456
+457
+458
+459
+460
+461
+462
+463
+Hed
+464
+465
+466
+467
+468
+469
+470
+471
+472
+473
+474
+475
+Thu
+476
+477
+478
+479
+480
+481
+482
+483
+484
+485
+486
+487
+488
+489
+Fri
+490
+491
+Date
+Time
+04/24
+10:27PM
+04/25
+11:00AM
+04/25
+01: 36PM
+04/25
+01:39PM
+04/25
+01:39PM
+04/25
+03:25PM
+04/25
+03:27PM
+04/25
+03:29PM
+04/25
+03:32PM
+04/25
+04:24PM
+04/25
+06: 04PM
+04/25
+06:18PM
+04/25
+06:27PM
+04/25
+09:00PM
+04/25
+09:18PM
+04/25
+10:32PM
+04/25
+10:37PM
+04/25
+10:40PM
+04/26
+12:55PM
+04/26
+12:57PM
+04/26
+01:39PM
+04/26
+03:12PM
+04/26
+03:36PM
+04/26
+05:45PM
+04/26
+06: 08PM
+04/26
+07: 01PM
+04/26
+07:02PM
+04/26
+07:07PM
+04/26
+07: 39PM
+04/26
+11:53PM
+04/27
+12:48AM
+04/27
+11: 47AM
+04/27
+11:48AM
+04/27
+11: 51AM
+04/27
+12: 02PM
+04/27
+12:20PM
+04/27
+12:29PM
+04/27
+01:57PM
+04/27
+06: 08PM
+04/27
+10: 05PM
+04/27
+10:11PM
+04/27
+10:17PM
+04/27
+10:19PM
+04/27
+10:27PM
+04/28
+12:15AM
+04/28
+12: 26AM
+04/28
+02: 57AM
+Number
+Called
+Call To Min Rade fare Antige Charge
+561-714-5714 N PALM FL
+1
+561-714-5714 N PALM FL
+1
+NPA2
+NEAZ
+850-499-9657 FINALT FL
+904-476-6114 JACKSO FL
+JACKSO FL
+904-707-0034
+JACKSO FL
+SEBAST
+FL
+904-707-0034
+FL
+W PALM FL
+561-207-0257 N PALM FI
+561-714-5714 W PALM FL
+14
+561-207-0257 N PALM FL
+561-792-6375 W PALM FL
+561-714-5714 N PALM FL
+561-207-0257 W PALM FL
+850-261-8226 PENSAC FL
+772-321-2693 VERO B FL
+772-321-2693 VERO B FL
+561-714-5714 N PALM FL
+561-207-0257 W PALM FL
+561-207-0257 W PALM FL
+321-663-5044
+ORLAND
+FI
+321-663-5044
+ORLAND FI
+561-714-5714 N PALM FI
+561-714-5714 W PALM FI
+561-207-0257 W PALM FI
+561-207-0257 N PALM FL
+772-360-6781 VERO B FL
+561-207-0257 N PALM FL
+772-360-6781 VERO B FL
+561-714-5714 W PALM FL
+561-714-5714 N PALM FL
+561-792-6375 N PALM FL
+772-485-4893
+STUART FL
+W PALM FL
+13
+561-714-5
+PALM EL
+W PALM FL
+561-207-0257 N PALM FL
+561-714-6296 N PALM FL
+772-219-4743 STUART FL
+561-714-5714 N PALM FL
+772-321-2693 VERO B FL
+561-207-0257 N PALM FL
+561-207-0257 N PALM FL
+561-792-6375 N PALM FL
+772-321-2693 VERO B FL
+772-321-2693 VERO B FL
+Total
+Chargi
+.00
+200
+. 00
+. 00
+1.00
+. 00
+. 00
+. 00
+
+
+Billing Cycle Date:
+Account Number:
+41 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Roaming Call Detail (Continued)
+User Name:
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item Day
+Call To Min Code
+493
+494
+495
+496
+497
+498
+499
+500
+501
+502
+503
+504
+505
+506
+Totals
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+Data Detail
+User Name:
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Feature: 1=PTT One-to-One event; a=Automated Call Return; B=Direct Asst Call Complete; C=Call Waiting; D=Data Call;
+d=Directory Assistance Call; F=Call Forwarding: g=PTT Group event; H=Group Mobile to Mobile Calls; I=Incoming Call:
+=Fax Call; M=Mobile To Mobile Discount; N=Off-Network; O=Auto Dropped Call Credit; P=Priority Access Service: Q=_-VPN
+‹=Roam with Home; S=Shared Minutes; T=Three Way Calling: =Voice Activated Dialing: W=Night and Weekend
+Item
+Day
+Mon
+Wed
+Thu
+Sat
+10
+11
+12
+13
+14
+15
+16
+17
+18
+Sun
+Mon
+Date
+03/27
+03/27
+03/29
+03/30
+03/30
+03/30
+04/01
+04/01
+04/01
+04/01
+04/02
+04/02
+04/03
+04/03
+04/03
+04/03
+04/03
+04/03
+Time
+11: 02PM
+11:05PM
+09:12PM
+10:50AM
+03:04PM
+10:12PM
+03:44PM
+03:47PM
+04: 26PM
+04:28PM
+08:28PM
+10: 46AM
+05:27PM
+08:38PM
+08: 43PM
+09:32PM
+11:59PM
+To/From
+CINGULAR MOBILE
+CINGULAR MOBILE
+MIM Other
+MIM Other
+OTHER MOBILE TO
+OTHER MOBILE TO
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+OTHER MOBILE TO
+OTHER MOBILE TO
+MIM Other
+OTHER MOBILE TO
+OTHER MOBILE 2O
+OTHER MOBILE TO
+1 Mag NPA2
+1 Mag NPA2
+1 Mag NPA2
+1 Mag
+1 Mag
+NPA2
+NPA2
+1 Mag
+1 Mag
+NPA2
+NPA2
+1 Mag
+NPA2
+1 Mag
+NPA2
+1 Mag
+NPA2
+1 Mag
+NPA2
+1 Mag
+NPA2
+1 Msg
+NPA2
+1 Msg NPA2
+1 Mag NPA2
+1 Mag NPA2
+1 Mag
+NPA2
+1 Mag NPA2
+In
+In
+In
+Out
+Out
+In
+Out
+In
+Out
+In
+Out
+Out
+Out
+In
+Out
+Out
+Out
+Total
+Chargi
+Total
+Charge
+
+
+Data Detail (Continued)
+User Name:
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Feature:
+1=PTT
+One-to-One
+event: a=Automated Call
+Return:
+Assistance Call;
+K=Fax
+M=Mobile
+Co Mobile scound = Nerve
+8=PTT
+R=Roam with
+Home:
+S=Shared Minutes; T=Three
+Way
+Item
+19
+20
+21
+22
+23
+24
+25
+26
+27
+28
+29
+30
+31
+32
+33
+34
+35
+36
+37
+38
+39
+40
+41
+42
+43
+44
+45
+46
+47
+48
+49
+50
+51
+52
+53
+54
+55
+56
+57
+58
+59
+60
+61
+62
+63
+64
+65
+Day
+Tue
+Wed
+Thu
+Fri
+Sat
+Mon
+Tue
+Date
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/04
+04/05
+04/05
+04/05
+04/05
+04/05
+04/05
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/06
+04/07
+04/07
+04/07
+04/08
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/10
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+04/11
+Time
+To/From
+Type
+05:23PM
+561-379-7824 CINGULAR MOBILE
+05:23PM
+CINGULAR MOBILE
+05: 35PM 561-379-7824
+CINGULAR MOBILE
+05: 37PM
+CINGULAR MOBILE
+05:58PM
+MIM Other
+10:19PM
+MIM Other
+10:23PM
+MIM Other
+11:23PM
+OTHER MOBILE TO
+11:24PM
+MIM Other
+11:25PM
+OTHER MOBILE TO
+10:48AM
+CINGULAR MOBILE
+10: 50AM
+CINGULAR MOBILE
+11: 48AM
+CINGULAR MOBILE
+11: 52AM
+CINGULAR MOBILE
+03:01PM
+CINGULAR MOBILE
+08: 30PM
+OTHER MOBILE TO
+11:44AM
+MIM Other
+11: 46AM
+OTHER MOBILE TO
+06:38PM
+OTHER MOBILE TO
+07:54PM
+MIM Other
+10:18PM
+MIM Other
+10:21PM
+MIM Other
+10:24PM
+MIM Other
+10:26PM
+MIM Other
+10:28PM
+MIM Other
+11:19PM
+OTHER MOBILE TO
+11:22PM
+OTHER MOBILE TO
+11:25PM
+OTHER MOBILE TO
+11:27PM
+OTHER MOBILE TO
+08: 26AM
+MIM Other
+01:55PM
+OTHER MOBILE 2O
+07:20PM
+OTHER MOBILE TO
+03:34PM
+CINGULAR MOBILE
+09: 33AM
+MIM Other
+10:29AM
+MIM Other
+10:32AM
+OTHER MOBILE TO
+11:57AM
+MIM Other
+11:58AM
+OTHER MOBILE TO
+05: 25PM
+MIM Other
+06:27PM
+OTHER MOBILE TO
+07:23AM
+MIM Other
+05:48PM
+MTM Other
+09:02PM
+MIM Other
+09:20PM
+MIM Other
+10:15PM
+OTHER MOBILE TO
+10:15PM
+OTHER MOBILE 10
+10:33PM
+OTHER MOBILE TO
+42 of 45
+Billing Cycle Date:
+03/29/06 - 04/28/06
+Account Number:
+06091813-001-03
+VPN:
+1 Mag NPA2
+1 Mag NPA2
+NPA2
+NPA2
+Out
+out
+In
+Out
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+Out
+In
+Out
+Out
+In
+In
+Out
+In
+Out
+In
+Out
+In
+In
+In
+In
+Out
+Out
+Out
+Total
+Chargi
+
+
+Data Detail (Continued)
+User Name:
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Feature:
+1=PTT
+One-to-One
+event: a=Automated Call
+Return:
+K-Fax Call,
+Assistance Call;
+K=Fax
+M=Mobile
+To Mobile
+one scount NOt Network:
+8=PTT
+R=Roam with
+Home:
+S=Shared Minutes; T=Three
+Way
+Item
+66
+67
+68
+69
+70
+71
+72
+73
+74
+75
+76
+77
+78
+79
+80
+81
+82
+83
+84
+85
+86
+87
+88
+89
+90
+91
+92
+93
+94
+95
+96
+97
+98
+99
+100
+101
+102
+103
+104
+105
+106
+107
+108
+109
+110
+111
+112
+Day
+Wed
+Thu
+FI1
+Mon
+Wed
+Thu
+Fri
+Date
+04/11
+04/11
+04/11
+04/12
+04/12
+04/12
+04/13
+04/13
+04/13
+04/13
+04/13
+04/14
+04/14
+04/14
+04/14
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/17
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/19
+04/20
+04/20
+04/20
+04/20
+04/20
+04/20
+04/20
+04/20
+04/20
+04/20
+04/20
+04/21
+04/21
+Time
+10:34PM
+10:38PM
+10:39PM
+02: 54PM
+03:47PM
+04:28PM
+10: 04AM
+10:04PM
+10:22PM
+10:24PM
+11:04PM
+01: 20AM
+08: 02AM
+09:28AM
+11: 33AM
+09:53AM
+09: 53AM
+10: 52AM
+10:54AM
+02:36PM
+02:39PM
+03:31PM
+03:33PM
+03:33PM
+03:39PM
+08:14AM
+09:19AM
+06:12PM
+06:16PM
+06:19PM
+07:14PM
+07:18PM
+07:19PM
+08:09PM
+01: 08AM
+01:10AM
+01:11AM
+01:11AM
+01:12AM
+01:13AM
+01:16AM
+10:41AM
+11: 43AM
+04:14PM
+10:16PM
+08: 26AM
+10:37AM
+To/From
+Type
+OTHER MOBILE TO
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+MIM Other
+MIM Other
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+MIM Other
+CINGULAR MOBILE
+CINGULAR MOBILE
+MIM Other
+MIM Other
+MIM Other
+OTHER MOBILE TO
+OTHER MOBILE TO
+MIM Other
+MIM Other
+OTHER MOBILE TO
+MIM Other
+OTHER MOBILE TO
+OTHER MOBILE TO
+MIM Other
+MT Other
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+MIM Other
+OTHER MOBILE 2O
+OTHER MOBILE TO
+MIM Other
+OTHER MOBILE TO
+OTHER MOBILE 10
+OTHER MOBILE TO
+OTHER MOBILE TO
+MIM Other
+OTHER MOBILE ZO
+MIM Other
+MIM Other
+OTHER MOBILE TO
+OTHER MOBILE TO
+Biling Cycle Date:
+43 of 45
+03/29/06 - 04/28/06
+Account Number:
+06091813-001-03
+Out
+In
+Total
+Charg
+.00
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+Out
+In
+Out
+Out
+In
+In
+Out
+Out
+Out
+In
+Out
+Out
+In
+Out
+Out
+Out
+Out
+In
+out
+In
+In
+Out
+Out
+
+
+Billing Cycle Date:
+Account Number:
+44 of 45
+03/29/06 - 04/28/06
+06091813-001-03
+Data Detail (Continued)
+User Name:
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+113
+114
+115
+116
+117
+118
+119
+121
+122
+123
+Totals
+Day
+Sat
+Sun
+Mon
+Tue
+Thu
+Wed
+Date
+Time
+04/21
+10: 55AM
+04/22
+10:42AM
+04/23
+02: 35AM
+04/23
+01:47PM
+04/24
+03: 32PM
+04/24
+03:34PM
+04/25
+01:25PM
+04/25
+01:28PM
+04/25
+02:25PM
+Subtotahnleisgs
+04/13
+01: 36AM
+04/19
+01:41PM
+Subtotal risKBs
+To/From
+Type
+361-379-7824 OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+MIM Other
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+Data Transfe
+Data Transie
+MyWirelessWind
+MywirelessWind
+0.02
+Code Pd
+1 Msg NPA2
+1 Mag NPA2
+1 Mag NPA2
+1 Mag NPA2
+1 Mag NPA2
+1 Mag NPA2
+1 Mag NPA2
+1 Mag NPA2
+1 Mag NPA2
+1 KB NPA2 P
+1 KB
+NPA2 P
+ture Out
+Out
+out
+Out
+In
+In
+In
+In
+Out
+In
+Out
+Out
+Total
+Chargi
+0.01
+0.01
+Parental Controls - Make your phone kid safe!
+Cingular Parental Controls gives parents choice and control over the content children can
+purchase (Purchase Blocker) and access (Content Filters) on Cingular devices. These
+filters can be set right from a child's phone by going to MEdia Net - Customize MEdia Net -
+Parental Controls. There's no monthly charge to use Parental Controls. Standard usage
+charges apply for the brief data usage needed to set the controls. For more info, visit
+www.cingular.com/medianet and select Parental Controls.
+Wireless AMBER Alerts
+Sign up to receive Wireless AMBER Alerts at www.cingular.com/amberalerts or by sending
+a text message with up to 5 zip codes to the short code AMBER (i.e. send SUBSCRIBE 12345
+to short code 26237). Customers capable of receiving text messages can receive these
+geographically specified alerts. There is no charge to sign up or to receive AMBER alerts.
+Normal airtime charges will apply if you place a call in response to an AMBER alert message.
+One Time Checking Account Payment Authorization Agreement (for use with kiosk payment):
+I authorize Cingular Wireless to pay my bill by debiting my bank account. I can cancel
+authorization by contacting an in-store sales person. If my bank rejects a payment.
+I may be charged a return fee.
+
+
+45 of 45
+Acoit De: 050385-02895
+Looking for a great job? Check out Cingular!
+Treat pay, excellent benefits, flexible hours, full and part time possible
+/isit Cingular.com, click on Careers, and apply online. EOE AA/M/F/D/
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/0e93bc920434fbf9bc082f01d49a2c2ff98e3cd472fe7a898b3b77fbb091aa6b.receipt.json b/vision-fixhub/ds9-unparsed-06/0e93bc920434fbf9bc082f01d49a2c2ff98e3cd472fe7a898b3b77fbb091aa6b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..dc4358c5d4ac367e18768e1c4b017aa2ad52405a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0e93bc920434fbf9bc082f01d49a2c2ff98e3cd472fe7a898b3b77fbb091aa6b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -18390,
+  "dataset": "marble-joined",
+  "doc_id": "0e93bc920434fbf9bc082f01d49a2c2ff98e3cd472fe7a898b3b77fbb091aa6b",
+  "engine": "marble-apple-vision",
+  "event_count": 64,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "1ed846770f1156a896d334577c4acdbe7536d7fdf47c602b9fe42991edea399c",
+  "output_sha256": "2475e0c661e5076a3e36c2f8df709fe784458e2fea6c2a0a7ab8a3e5d5c989db",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0f2b49df3321b46b62c35fbb949b3a336303ee9a7dddd8df3afa56761ddef8ed.md b/vision-fixhub/ds9-unparsed-06/0f2b49df3321b46b62c35fbb949b3a336303ee9a7dddd8df3afa56761ddef8ed.md
new file mode 100644
index 0000000000000000000000000000000000000000..435443d300f1020733466725883ba4842e83459e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0f2b49df3321b46b62c35fbb949b3a336303ee9a7dddd8df3afa56761ddef8ed.md
@@ -0,0 +1,11 @@
+From:
+To:
+| (USAFLS)" <
+Subject: Motion to Quash
+Date: Wed, 18 Jul 2007 14:01:45 +0000
+Importance: Normal
+Attachments: Motn_to_Quash001.pdf
+(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=
+(USAFLS)"
+Here it is. Please let me know if this item or the affidavit don't come through.
+Assistant V.S. Attorney
diff --git a/vision-fixhub/ds9-unparsed-06/0f2b49df3321b46b62c35fbb949b3a336303ee9a7dddd8df3afa56761ddef8ed.receipt.json b/vision-fixhub/ds9-unparsed-06/0f2b49df3321b46b62c35fbb949b3a336303ee9a7dddd8df3afa56761ddef8ed.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..444762368de22bbb17622b35b953f4667c608f1b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0f2b49df3321b46b62c35fbb949b3a336303ee9a7dddd8df3afa56761ddef8ed.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "0f2b49df3321b46b62c35fbb949b3a336303ee9a7dddd8df3afa56761ddef8ed",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3060508e714ffc377f3ee62a340c75469577a7430f5c5a69815a7b5cccebeea3",
+  "output_sha256": "b1e07237897de0f06a01e23300e462aed43488743324e677729980f785b06b0d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0f3717d560e0458d1d8e7baca71fac3ca14adf390a98f19a6d1d70992dd260f8.md b/vision-fixhub/ds9-unparsed-06/0f3717d560e0458d1d8e7baca71fac3ca14adf390a98f19a6d1d70992dd260f8.md
new file mode 100644
index 0000000000000000000000000000000000000000..76b606c0c8c05111a1b05382778e884cd31e8fe9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0f3717d560e0458d1d8e7baca71fac3ca14adf390a98f19a6d1d70992dd260f8.md
@@ -0,0 +1,12 @@
+From: "Gerald Lefcourt"
+To: =
+Ce: $
+Subject: Jeffrey Epstein
+Date: Tue, 22 May 2007 18:05:25 +0000
+Importance: Normal
+Attachments: 2007-05-
+P, "Lilly Ann Sanchez" <
+I attached is a letter seeking meetings, as discussed with you, but with others if it is not resolved. Thanks for your
+attention. Could vou email back so that I know vou have received this letter?
+Gerald B. Lefcourt
+Gerald B. Lefcourt, P.C.
diff --git a/vision-fixhub/ds9-unparsed-06/0f3717d560e0458d1d8e7baca71fac3ca14adf390a98f19a6d1d70992dd260f8.receipt.json b/vision-fixhub/ds9-unparsed-06/0f3717d560e0458d1d8e7baca71fac3ca14adf390a98f19a6d1d70992dd260f8.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..5c457a28539eae007bbb3e3bbafdfd2fce243333
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0f3717d560e0458d1d8e7baca71fac3ca14adf390a98f19a6d1d70992dd260f8.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "0f3717d560e0458d1d8e7baca71fac3ca14adf390a98f19a6d1d70992dd260f8",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "856f8852a2d7d45a88d1487350c424d7e5d1ecc6b8d121ffd00b6aede40b4af9",
+  "output_sha256": "4275a1b430e137e69dd12aa5cfa74c42eeffc703987aa5a1dc1997de55bb6912",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0f61540c3cde0fe2c1016aaf350ef1c64a9b56f99084fc4096b5b078961cd317.md b/vision-fixhub/ds9-unparsed-06/0f61540c3cde0fe2c1016aaf350ef1c64a9b56f99084fc4096b5b078961cd317.md
new file mode 100644
index 0000000000000000000000000000000000000000..33105b26ae9643d3ba767a744662cd67f03760f3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0f61540c3cde0fe2c1016aaf350ef1c64a9b56f99084fc4096b5b078961cd317.md
@@ -0,0 +1,699 @@
+Page 1
+2 of 2 DOCUMENTS
+Copyright 2003 The Conde Nast Publications Inc.
+All Rights Reserved
+Vanity Fair
+March 2003
+SECTION: The Talented Mr. Epstein; No. 511; Pg. 300
+LENGTH: 7494 words
+HEADLINE: The Talented Mr. Epstein;
+Lately, Jeffrey Epstein's high-ying style has been drawing oohs and aahs: the bachelor
+nancier lives in New York's largest private residence, claims to take onlybillionaires
+as clients, and ies celebrities including Bill Clinton and Kevin Spacey on his Boeing
+727. But pierce his air of mystery and the picture changes. VICKY WARD explores
+Epstein's investment career, his ties to retail magnate Leslie Wexner, and his
+complicated past
+BYLINE: Vicky Ward, Contributing Editor
+BODY:
+On Manhattan's Upper East Side, home to some of the most expensive real estate
+on earth, exists the crown jewel of the city's residential town houses. With its
+15-foot-high oak door, huge arched windows, and nine floors, it sits on-or, rather,
+commands-the block of 7lst Street between Fifth and Madison Avenues. Almost
+ludicrously out of proportion with its four- and five-story neighbors, it seems more
+like an institution than a house. This is perhaps not surprising-until 1989 it was
+the Birch Wathen private school. Now it is said to be Manhattan's largest private
+residence.
+Inside, amid the flurry of menservants attired in sober black suits and pristine
+white gloves, you feel you have stumbled into someone's private Xanadu. This is no
+mere rich person's home, but a high-walled, eclectic, imperious fantasy that seems
+to have no boundaries.
+The entrance hall is decorated not with paintings but with row upon row of
+individually framed eyeballs; these, the owner tells people with relish, were imported
+from England, where they were made for injured soldiers. Next comes a marble foyer,
+which does have a painting, in the manner of Jean Dubuffet ... but the host coyly
+refuses to tell visitors who painted it. In any case, guests are like pygmies next
+to the nearby twice-life-size sculpture of a naked African warrior.
+Despite its eccentricity the house is curiously impersonal, the statement of
+someone who wants to be known for the scale of his possessions. Its occupant, financier
+Jeffrey Epstein, 50, admits to friends that he likes it when people think of him this
+way. A good-looking man, resembling Ralph Lauren, with thick gray-white hair and a
+weathered face, he usually dresses in jeans, knit shirts, and loafers. He tells people
+he bought the house because he knew he "could never live anywhere bigger." He thinks
+51, 000 square feet is an appropriately large space for someone like himself, who deals
+mostly in large concepts-especially large sums of money.
+Guests are invited to lunch or dinner at the town house-Epstein usually refers
+to the former as "tea," since he likes to eat bite-size morsels and drink copious
+
+
+Page 2
+The Talented Mr. Epstein;Lately, Jeffrey Epstein's high-ying style
+quantities of Earl Grey. (He does not touch alcohol or tobacco.) Tea is served in
+the "leather room, " so called because of the cordovan-colored fabric on the walls.
+The chairs are covered in a leopard print, and on the wall hangs a huge, Oriental
+fantasy of a woman holding an opium pipe and caressing a snarling lionskin. Under
+her gaze, plates of finger sandwiches are delivered to Epstein and guests by the
+menservants in white gloves.
+Upstairs, to the right of a spiral staircase, is the "office," an enormous gallery
+spanning the width of the house. Strangely, it holds no computer. Computers belong
+in the "computer room" (a smaller room at the back of the house), Epstein has been
+known to say. The office features a gilded desk (which Epstein tells people belonged
+to banker J. P. Morgan), 18th-century black lacquered Portuguese cabinets, and a
+nine-foot ebony Steinway
+"D" grand. On the desk, a paperback copy of the Marquis de
+Sade's The Misfortunes of Virtue was recently
+spotted. Covering the floor, Epstein
+has explained,
+"is the largest Persian rug you'll ever see in a private home-so big,
+it must have come from a mosque. " Amid such splendor, much of which reflects the work
+of the French decorator Alberto Pinto, who has worked for Jacques Chirac and the royal
+families of Jordan and Saudi Arabia, there is one particularly startling oddity: a
+stuffed black poodle, standing atop the grand piano. "No decorator would ever tell
+you to do that," Epstein brags to visitors.
+"But I want people to think what it means
+to stuff a dog." People can't help but feel it's Epstein's way of saying that he always
+has the last word.
+In addition to the town house, Epstein lives in what is reputed to be the largest
+private dwelling in New Mexico, on an $18 million,
+7,500-acre ranch which he named
+"Zorro." "It makes the town house look like a shack," Epstein has said. He also owns
+Little St. James, a 70-acre island in the U.S. Virgin Islands, where the main house
+is currently being renovated by Edward Tuttle, a designer of the Amanresorts. There
+is also a $6.8 million house in Palm Beach, Florida, and a fleet of aircraft: a
+Gulfstream IV, a helicopter, and a Boeing 727, replete with trading room, on which
+Epstein recently flew President Clinton, actors Chris Tucker and Kevin Spacey,
+supermarket magnate Ron Burkle, Lew Wasserman's grandson, Casey Wasserman, and a few
+others, on a mission to explore the problems of aids and economic development in Africa.
+Epstein is charming, but he doesn't let the charm slip into his eyes. They are
+steely and calculating, giving some hint at the steady whir of machinery running behind
+them. "Let's play chess, " he said to me, after refusing to give an interview for this
+"You be white. You get the first move." It was an appropriate metaphor for
+a man who seems to feel he can win no matter what the advantage of the other side.
+His advantage is that no one really seems to know him or his history completely or
+what his arsenal actually consists of. He has carefully engineered it so that he remains
+one of the few truly baffling mysteries among New York's moneyed world. People know
+snippets, but few know the whole.
+"He's very enigmatic," says Rosa Monckton, the former C.E.O. of Tiffany & Co. in
+the U.K. and a close friend since the early 1980s. "You think you know him and then
+you peel off another ring of the onion skin and there's something else extraordinary
+underneath. He never reveals his hand... He's a classic iceberg. What you see is not
+what you get."
+Even acquaintances sense a curious dichotomy: Yes, he lives like a "modern maharaja,"
+as Leah Kleman, one of his art dealers, puts it. Yet he is fastidiously, almost
+obsessively private-he lists himself in the phone book under a pseudonym. He rarely
+attends society gatherings or weddings or funerals; he considers eating in restaurants
+like "eating on the subway"-i.e., something he'd never do. There are many women in
+his life, mostly young, but there is no one of them to whom he has been able to commit.
+He describes his most public companion of the last decade, Ghislaine Maxwell, 41,
+
+
+Page 3
+The Talented Mr. Epstein;Lately, Jeffrey Epstein's high-ying style
+the daughter of the late, disgraced media baron Robert Maxwell, as simply his "best
+friend." He says she is not on his payroll, but she seems to organize much of his
+life-recently she was making telephone inquiries to find a California-based yoga
+instructor for him. (Epstein is still close to his two other long-term girlfriends,
+Paula Heil Fisher, a former associate of his at the brokerage firm Bear Stearns and
+now an opera producer, and Eva Andersson Dubin, a doctor and onetime model. He tells
+people that when a relationship is over the girlfriend "moves up, not down, " to
+friendship status.)
+Some of the businessmen who dine with him at his home-they include newspaper
+publisher Mort Zuckerman, banker Louis Ranieri, Revlon chairman Ronald Perelman,
+real-estate tycoon Leon Black, former Microsoft executive Nathan Myhrvold, Tom
+Pritzker (of Hyatt Hotels), and real-estate personality Donald Trump-sometimes seem
+not all that clear as to what he actually does to earn his millions. Certainly, you
+won't find Epstein's transactions written about on Bloomberg or talked about in the
+trading rooms. "The trading desks don't seem to know him. It's unusual for animals
+that big not to leave any footprints in the snow, " says a high-level investment manager.
+Unlike such fund managers as George Soros and Stanley Druckenmiller, whose client
+lists and stock maneuverings act as their calling cards, Epstein keeps all his deals
+and clients secret, bar one client: billionaire Leslie Wexner, the respected chairman
+of Limited Brands. Epstein insists that ever since he left Bear Stearns in 1981 he
+has managed money only for billionaires-who depend on him for discretion. "I was the
+only person crazy enough, or arrogant enough, or misplaced enough, to make my limit
+a billion dollars or more," he tells people freely. According to him, the flat fees
+he receives from his clients, combined with his skill at playing the currency markets
+"with very large sums of money, " have afforded him the lifestyle he enjoys today.
+Why do billionaires choose him as their trustee? Because the problems of the
+mega-rich, he tells people, are different from yours and mine, and his unique
+philosophy is central to understanding those problems: "Very few people need any more
+money when they have a billion dollars. The key is not to have it do harm more than
+anything else... You don't want to lose your money."
+He has likened his job to that of an architect-more specifically, one who specializes
+in remodeling: "I always describe (a billionaire)
+as someone who started out in a
+small home and as he became wealthier had add-ons. He added on another addition, he
+built a room over the garage ... until you have a house that is usually a mess...
+It's a large house that has been put together over time where no one could foretell
+the financial future and their accompanying needs."
+He makes it sound as though his job combines the roles of real-estate agent,
+accountant, lawyer, money manager, trustee, and confidant. But, as with Jay Gatsby,
+myths and rumor swirl around Epstein.
+Here are some of the hard facts about Epstein-ones that he doesn't mind people
+knowing: He grew up middle-class in Brooklyn. His father worked for the city's parks
+department. His parents viewed education as "the way out" for him and his younger
+brother, Mark, now working in real estate. Jeffrey started to play the piano-for which
+he maintains a passion-at five, and he went to Brooklyn's Lafayette High School. He
+was good at mathematics, and in his early 20s he got a job teaching physics and math
+at Dalton, the elite Manhattan private school. While there he began tutoring the son
+of Bear Stearns chairman Ace Greenberg and was friendly with a daughter of Greenberg's.
+Soon he went to Bear Stearns, where, under the mentorship of both Greenberg and current
+Bear Stearns C.E.O. James Cayne, he did well enough to become a limited partner-a
+rung beneath full partner. He abruptly departed in 1981 because, he has said, he wanted
+to run his own business.
+
+
+Page 4
+The Talented Mr. Epstein;Lately, Jeffrey Epstein's high-ying style
+Thereafter the details recede into shadow. A few of the handful of current friends
+who have known him since the early 1980s recall that he used to tell them he was a
+"bounty hunter, " recovering lost or stolen money for the government or for very rich
+people. He has a license to carry a firearm. For the last 15 years, he's been running
+his business, J. Epstein & Co.
+Since Leslie Wexner appeared in his life-Epstein has said this was in 1986; others
+say it was in 1989, at the earliest-he has gradually, in a way that has not generally
+made headlines, come to be accepted by the Establishment. He's a member of various
+commissions and councils: he is on the Trilateral Commission, the Council on Foreign
+Relations, the New York Academy of Sciences, and the Institute of International
+Education.
+His current fan club extends to Cayne, Henry Rosovsky, the former dean of Harvard's
+Faculty of Arts and Sciences, and Larry Summers, Harvard's current president. Harvard
+law professor Alan Dershowitz says, "I'm on my 20th book... The only person outside
+of my immediate family that I send drafts to is Jeffrey." Real-estate developer and
+philanthropist Marshall Rose, who has worked with Epstein on projects in New Albany,
+"He digests and decodes the information very rapidly, which
+is to me terrific because we have shorter meetings."
+Also on the list of admirers are former senator
+Mitchell and a gaggle of
+distinguished scientists, most of whom Epstein has helped fund in recent years. They
+include Nobel Prize winners Gerald Edelman and Murray Gell-Mann, and mathematical
+biologist Martin Nowak. When these men describe Epstein, they talk about "energy"
+and "curiosity," as well as a love for theoretical physics that they don't ordinarily
+find in laymen. Gell-Mann rather sweetly mentions that "there are always pretty ladies
+around" when he goes to dinner chez Epstein, and he's under the impression that
+Epstein's clients include the Queen of England. Both Nowak and Dershowitz were thrilled
+to find themselves shaking the hand of a man named "Andrew" in Epstein's house. "Andrew"
+turned out to be Prince Andrew, who subsequently arranged to sit in the back of
+Dershowitz's law class.
+Epstein gets annoyed when
+anyone suggests that Wexner "made him." "I had really
+rich clients before," he has said. Yet he does not deny that he and Wexner have a
+special relationship. Epstein sees it as a partnership of equals.
+"People have said
+it's like we have one brain between two of us: each has a side."
+"I think we both possess the skill of seeing patterns," says Wexner. "But Jeffrey
+sees
+patterns in politics and financial markets, and I see patterns in lifestyle and
+fashion trends. My skills are not in investment strategy, and, as everyone who knows
+Jeffrey knows, his are not in fashion and design. We frequently discuss world trends
+as each of us sees them."
+By the time Epstein met Wexner, the latter was a retail legend who had built a $3
+billion empire-one that now includes Victoria's Secret, Express, and Bath & Body
+Works-from $5,000 lent him by his aunt.
+"Wexner saw in Jeffrey the type of person
+who had the potential to realize his (Jeffrey's) dreams, " says someone who has worked
+closely with both men. "He gave Jeffrey the ball, and Jeffrey hit it out of the park."
+Wexner, through a trust, bought the town house in which Epstein now lives for a
+reported $13.2 million in 1989. In 1993, Nexner married Abigail Koppel, a 31-year-old
+lawyer, and the newlyweds relocated to Ohio; in 1996, Epstein moved into the town
+house. Public documents suggest that the house is still owned by the trust that bought
+it, but Epstein has said that he now owns the house.
+Wexner trusts Epstein so completely that he has assigned him the power of fiduciary
+over all of his private trusts and foundations,
+says a source close to Wexner. In
+1992, Epstein even persuaded Wexner to put him on the board of the Wexner Foundation
+
+
+Page 5
+The Talented Mr. Epstein;Lately, Jeffrey Epstein's high-ying style
+in place of Wexner's ailing mother. Bella Wexner recovered and demanded to be
+reinstated. Epstein has said they settled by splitting the foundation in two.
+Epstein does not care that he comes between family members. In fact, he sees it
+as his job. He tells people, "I am there to represent my client, and if my client
+needs protecting-sometimes even from his own family-then it's often better that people
+nate me, not the client."
+"You've probably heard I'm vicious in my representation of my clients," he tells
+people proudly; Leah Kleman describes his haggling over art prices as something like
+a scene out of the movie Mad Max: Beyond Thunderdome. Even a former mentor says he's
+seen "the dark side" of Epstein, and a Bear Stearns source recalls a meeting in which
+Epstein chewed out a team making a presentation for Wexner as being so brutal as to
+be "irresponsible."
+One reporter, in fact, received three threats from Epstein while preparing a piece.
+They were delivered in a jocular tone, but the message was clear: There will be trouble
+for your family if I don't like the article.
+On the other hand, Epstein is clearly very generous with friends. Joe Pagano, an
+Aspen-based venture capitalist, who has known Epstein since before his Bear Stearns
+days, can't say enough nice things: "I have a boy who's dyslexic, and Jeffrey's gotten
+close to him over the years... Jeffrey got him into music. He bought him his first
+piano. And then as he got to school he had difficulty ... in studying ... so Jeffrey
+got him interested in taking flying lessons."
+Rosa Monckton recalls Epstein telling her that her daughter, Domenica, who suffers
+from Down syndrome, needed the
+sun, and that Rosa should feel free to bring her to
+his house in Palm Beach anytime.
+Some friends remember that in the late 80s Epstein would offer to upgrade the airline
+tickets of good friends by affixing first-class stickers; the only problem was that
+the stickers turned out to be unofficial. Sometimes the technique worked, but other
+times it didn't,
+and the unwitting recipients found themselves exiled to coach.
+(Epstein has claimed that he paid for the upgrades, and had no knowledge of the
+stickers.) Many of those who benefited from Epstein's largesse claim that his
+generosity comes with no strings attached. "I never felt he wanted anything from me
+in return," says one old friend, who received a first-class upgrade.
+Epstein is known about town as a man who loves women-lots of them, mostly young. Model
+types have been heard saying they are full of gratitude to Epstein for flying them
+around, and he is a familiar face to many of the Victoria's Secret girls. One young
+woman recalls being summoned by Ghislaine Maxwell to a concert at Epstein's town house,
+where the women seemed to outnumber the men by far. "These were not women you'd see
+that Prince Andrew attended, which was filled, she says, with young Russian models.
+- gust so no 5s 30, he son a go
+"He's reckless," says a former business associate, "and he's gotten more so. Money
+does that to you. He's breaking the oath he made to himself-that he would never do
+anything that would expose him in the media. Right now, in the wake of the publicity
+following his trip with Clinton, he must be in a very difficult place."
+According to S.E.C. and other legal documents unearthed by Vanity Fair, Epstein may
+have good reason to keep his past cloaked in secrecy: his real mentor, it might seem,
+was not leslie Wexner but Steven Jude Hoffenberg, 57, who, for a few months before
+the S.E.C. sued to freeze his assets in 1993, was trying to buy the New York Post.
+
+
+Page 6
+The Talented Mr. Epstein;Lately, Jeffrey Epstein's high-ying style
+He is currently incarcerated in the Federal Medical Center in Devens, Massachusetts,
+serving a 20-year sentence for bilking investors out of more than $450 million in
+one of the largest Ponzi schemes in American history.
+When Epstein met Hoffenberg in London in the 1980s, the latter was the charismatic,
+audacious head of the Towers Financial Corporation, a collection agency that was
+supposed to buy debts that people owed to hospitals, banks, and phone companies. But
+Hoffenberg began using company funds to pay off earlier investors and service a lavish
+lifestyle that included a mansion on Long Island, homes on Manhattan's Sutton Place
+and in Florida, and a fleet of cars and planes.
+Hoffenberg and Epstein had much in common. Both were smart and obsessed with making
+money. Both were from Brooklyn. According to Hoffenberg, the two men were introduced
+by Douglas Leese, a defense contractor. Epstein has said they were introduced by John
+Mitchell, the late attorney general.
+Epstein had been running International Assets Group Inc. (I.A.G.), a consulting
+company, out of his apartment in the Solo building on East 66th Street in New York.
+Though he has claimed that he managed money for billionaires only, in a 1989 deposition
+he testified that he spent 80 percent of his time helping people recover stolen money
+from fraudulent brokers and lawyers. He was also not above entering into risky,
+tax-sheltered oil and gas deals with much smaller investors. A lawsuit that Michael
+Stroll, the former head of Williams Electronics Inc., filed against Epstein shows
+that in 1982 I.A.G. received an investment from Stroll of $450,000, which Epstein
+put into oil. In 1984, Stroll asked for his money back; four years later he had received
+only $10, 000. Stroll lost the suit, after Epstein claimed in court, among other things,
+that the
+check for $10, 000 was
+for a horse he'd bought from Stroll. "My net worth
+never exceeded four and a half million dollars," Stroll has said.
+Hoffenberg, says a close friend,
+"really liked Jeffrey... Jeffrey has a way of
+getting under your skin, and he was under Hoffenberg's. " Also appealing to Hoffenberg
+were Epstein's social connections; they included oil mogul Cece Wang (father of the
+designer Vera) and Mohan Murjani, whose clothing company grew into Gloria Vanderbilt
+Jeans. Epstein lived large even then. One friend recalls that when he took Canadian
+heiress Wendy Belzberg on a date he hired a Rolls-Royce especially for the occasion.
+(Epstein has claimed he owned it.)
+In 1987, Hoffenberg, according to sources, set Epstein up in the offices he still
+occupies in the Villard House, on Madison Avenue,
+across a courtyard from the
+restaurant Le Cirque. Hoffenberg hired his new protege as a consultant at $25,000
+a month, and the relationship flourished. "They traveled everywhere together-on
+Hoffenberg's plane, all around the world, they were always together, " says a source.
+Hoffenberg has claimed that Epstein confided in him, saying, for example, that he
+Several of Epstein's Bear Stearns contemporaries recall that Epstein left the
+company very suddenly. Within the company there were rumors also that he was involved
+in a technical infringement, and it was thought that the executive committee asked
+that he resign after his two supporters, Ace Greenberg and Jimmy Cayne, were
+outnumbered. Greenberg says he can't recall this; Cayne denies it happened, and Epstein
+has denied it as well.
+"Jeffrey Epstein
+left Bear Stearns of his own volition," says
+Cayne. "It was never suggested that he leave by any member of management, and management
+never looked into any improprieties by him. Jeffrey said specifically, 'I don't want
+to work for anybody else. I want to work
+for myself.'" Yet, this is not the story
+that Epstein told to the S.E.C. in 1981 and to lawyers in a 1989 deposition involving
+a civil business case in Philadelphia.
+In 1981 the S.E.C. 's Jonathan Harris and Robert Blackburn took Epstein's testimony
+and that of other Bear Stearns employees in part of what became a protracted case
+
+
+Page 7
+The Talented Mr. Epstein;Lately, Jeffrey Epstein's high-ying style
+about insider trading around a tender offer placed on March 11, 1981, by the Seagram
+Company Ltd. for St. Joe Minerals Corp. Ultimately several Italian and Swiss investors
+were found guilty, including Italian financier Giuseppe Tome, who had used his
+relationship with Seagram owner Edgar Bronfman Sr. to obtain information about the
+tender offer.
+After the tender offer was announced, the S.E.C. began investigating trades
+involving St. Joe at continued on page 343 continued from page 305 Bear Stearns and
+other firms. Epstein resigned from Bear Stearns on March 12. The S.E.C. was tipped
+off that Epstein had information on insider trading at Bear Stearns, and it was
+therefore obliged to question him. In his S.E.C. testimony, given on April 1, 1981,
+Epstein claimed that he had found "offensive" the way Bear Stearns management had
+handled a disciplinary action following its discovery that he had committed a possible
+"Reg D" violation-evidently he had lent money to his closest friend. (In the 1989
+deposition he said that he'd lent approximately $20, 000 to Warren Eisenstein, to buy
+stock.) Such an action could have been considered improper, although Epstein claimed
+he had not realized this until afterward.
+According to Epstein, Bear Stearns management had questioned him about the loan
+around March 4. The questioners, Epstein said, were Michael (Mickey) Tarnopol and
+Alvin Einbender. In his 1989 deposition Epstein recalled that the partner who had
+an "issue"
+of the matter was Marvin Davidson. On March 9, Epstein said, he had
+met with Tarnopol and Einbender again, and the two partners told him that the executive
+committee had
+weighed the offense, together with previous "carelessness" over
+expenses, and he would be fined $2,500.
+"There was discussion whether, in fact, I had ever put in an airline ticket for
+someone else and not myself and I said that it was possible, ... since my secretary
+handles my expenses, " Epstein told the S.E.C. In his 1989 testimony he stated that
+the "Reg D" incident had
+cost him a shot at partnership that year.
+What the S.E.C. seemed to be especially interested in was whether there was a
+connection between Epstein's leaving and the alleged insider trading in St. Joe
+Minerals by other people at Bear Stearns:
+Q: Sir, are you aware that certain rumors may have been circulating around your firm
+in connection with your reasons for leaving the firm?
+A: I'm aware that there were many rumors.
+Q: What were the rumors you heard?
+A: Nothing to do with St. Joe.
+Q: Can you relate what you heard?
+A: It was having to do with an illicit affair with a secretary.
+2: Have you heard any other rumors suggesting that you had made a presentation or
+communication to the Executive Committee concerning alleged improprieties by other
+members or employees of Bear Stearns?
+A: I, in fact, have heard that rumor, but it's been from Mr. Harris in our conversation
+last week.
+Q: Have you heard it from anyone else?
+A: No.
+A little later the interview focuses on James Cayne:
+Q: Did you ever hear while you were at Bear Stearns that Mr. Cayne may have trader
+or insider information in connection with St. Joe Minerals Corporation?
+A: No.
+Q: Did Mr. Cayne ever have any conversation with you about St. Joe Minerals?
+Q: Did you happen to overhear any conversations between Mr. Cayne and anyone else
+regarding St. Joe Minerals?
+
+
+Page 8
+The Talented Mr. Epstein; Lately, Jeffrey Epstein's high-ying style
+And still later in the questioning comes this exchange:
+I: Have you had any type of business dealings with Mr. Cayne?
+A: There's no relationship with Bear Stearns.
+Q: Pardon?
+A: Other than Bear Stearns, no.
+Q: Have you been a participant in any type of business venture with Mr. Cayne?
+A: No.
+Q: Do you have any expectation of participating in any business venture with Mr. Cayne?
+A: No.
+Q: Have you had any business participations with Mr. Theram?
+A: No; nor do I anticipate any.
+• Mr. Epstein, d
+hour. nostein, de anyone Bar Stee Minerals to woe star otta chattie
+and Exchange Commission?
+Q: Has anyone indicated to you in any way, either directly or indirectly, in words
+or substance, that your compensation for this past year or any future monies coming
+to vou from Bear Stearns will be contingent upon vour not divulging information to
+the Securities and Exchange Commission?
+Despite the circumstances of Epstein's leaving, Bear Stearns agreed to pay him
+his annual bonus-which he anticipated as being approximately $100,000.
+The S.E.C. never brought any charges against anyone at Bear Stearns for insider
+trading in St. Joe, but its questioning seems to indicate that it was skeptical of
+Epstein's answers. Some sources have wondered
+why, if he was such a big producer at
+Bear Stearns, he would have given it up over a mere $2,500 fine.
+Certainly the years after Epstein left the firm were not obviously prosperous ones.
+His luck didn't seem to change until he met Hoffenberg.
+One of Epstein's
+first assignments for Hoffenberg was to mastermind doomed bids to
+take over Pan American World Airways in 1987 and Emery Air Freight Corp. in 1988.
+Hoffenberg claimed in a 1993 hearing before a grand jury in Illinois that Epstein
+came up with the idea of financing these bids through Towers's acquisition of two
+ailing Illinois insurance companies, Associated Life and United Fire. "He was hired
+by us to work on the securities side of the insurance companies and Towers Financial,
+supposedly to make a profit for us and for the companies, " Hoffenberg reportedly told
+the grand jury. He also alleged that Epstein was the "technician," executing the
+schemes, although, having no broker's license, he had to rely on others to make the
+trades. Much of Hoffenberg's subsequent testimony in his criminal case has proven
+to be false, and Epstein has claimed he was merely asked how the bids could be
+accomplished and has said he had nothing to do with the financing of them. Yet Richard
+Allen, the former treasurer of United Fire, recalls seeing Epstein two or three times
+at the company. He and another executive
+say they had direct dealing with Epstein
+over the finances. And in his deposition of 1989, Epstein stated that he was the one
+who executed "all" Hoffenberg's instructions to buy and sell the stock. He called
+it "making the orders." He could not recall whether he had chosen the brokers used.
+To win approval from the Illinois insurance regulators for Towers's acquisition
+of the companies, Hoffenberg promised to inject $3 million of new capital into them.
+In fact, in his grand-jury testimony Hoffenberg claimed that he, his chief operating
+officer, Mitchell Brater, and Epstein came up with a scheme to steal $3 million of
+the insurance companies' bonds to buy Pan Am and Emery stock. "Jeffrey Epstein and
+Mitch Brater arranged the various brokerage accounts for the bonds to be placed with
+in New York, and I think one in Chicago, Rodman & Renshaw, " Hoffenberg reportedly
+and chink one in chicago,
+
+
+Page 9
+The Talented Mr. Epstein;Lately, Jeffrey Epstein's high-ying style
+said. Then, said Hoffenberg, while making it appear as though they were investing
+the bonds in much safer financial instruments, they used them as collateral to buy
+the stock. "Epstein was the person in charge of the transactions, and Mitchell Brater
+was assisting himwith it in coordination on behalf of the insurance companies' money,"
+Hoffenberg claimed at the time.
+At one point, according to Hoffenberg, a broker forged the documents necessary
+for a $1.8 million check to be written on insurance-company funds. The check was used
+to buy more stock in the takeover targets. Meanwhile, in order to throw the insurance
+regulators off, the $1.8 million was reported as being safely invested in a
+money-market account.
+United Fire's former chief financial officer Daniel Payton confirms part of
+Hoffenberg's account. He says he recalls making one or two telephone calls to Epstein
+(at Hoffenberg's direction) about the missing bonds. "He said, 'Oh, yeah, they still
+exist.' But we found out later that he had sold those assets |
+•.. leveraged them ...
+(and) used some margin account to take some positions in ... Emery and Pan Am, " says
+Epstein's extraordinary creativity was, according to Hoffenberg, responsible for
+the purchase by the insurance companies of a $500, 000 bond, with no money down. "Epstein
+created a great scheme to purchase a $500,000 treasury bond that would not be shown
+... (as) margined or collateralized, " he reportedly told the grand jury. "It looked
+like it was free and clear but it actually wasn't," he said.
+Epstein has denied he ever had any dealings with anyone from the insurance
+companies. But Richard Allen says he recalls talking to Epstein at Hoffenberg's
+direction and telling him it was urgent they retrieve the missing bonds for a state
+examination. According to Allen, Epstein said, "We'11 get them back." He had "kind
+Epstein, according to Hoffenberg, also came up with a scheme to manipulate the price
+of Emery Freight stock in an attempt to minimize the losses that occurred when
+Hoffenberg's bid went wrong and the share price began to fall. This was alleged to
+have involved multiple clients' accounts controlled by Epstein.
+Eventually, in 1991, insurance regulators in Illinois sued Hoffenberg. He settled
+the case, and Epstein, who was only a paid consultant, was never deposed or accused
+of any wrongdoing. Barry Gross, the attorney who was handling the suit for the
+regulators, says of Epstein,
+"He was very elusive... It was hard to really track him
+down. There were a substantial number of checks for significant dollars that were
+paid to him, I remember... He was this character we never got a handle on. Again we
+presumed that he was involved with the Pan Am and Emery run that Hoffenberg made,
+but we never got a chance to depose him."
+"From the government's discovery in the main sentencing against Hoffenberg it would
+seem the government was perhaps a bit lazy, " says David Lewis, who represented Mitchell
+Brater. "They went for what they knew they could get ... and that was the fraudulent
+promissory notes (i.e., the much larger and unrelated part of Hoffenberg's fraud,
+based in New York State)... What they couldn't get, they didn't bother with."
+Another lawyer involved in the criminal prosecution of Hoffenberg says, "In a
+criminal investigation like that, when there is a guilty plea, to be quick and dirty
+about it, discovery is always incomplete... They don't have to line up witnesses;
+they don't have to learn every fact that might come out on cross-examination."
+Epstein was involved with Hoffenberg in other questionable transactions. Financial
+records show that in 1988 Epstein invested $l.6 million in Riddell Sports Inc., a
+
+
+Page 10
+The Talented Mr. Epstein;Lately, Jeffrey Epstein's high-ying style
+company that manufactures football helmets. Among his co-investors were the theater
+mogul Robert Nederlander and attorney Leonard Toboroff. A source close to this
+transaction claims that Epstein told Nederlander and Toboroff that he had raised his
+share of the money from a Swiss banker, whose identity they could not be allowed to
+know. But Hoffenberg has claimed the money came from him, and Towers's financial
+statements for that year show a loan to Epstein of $400,000. (Epstein has said he
+can't remember the details and has disputed the accuracy of the Towers financial
+reports.)
+Around the same time, Nederlander and Toboroff let Epstein come in with them on
+a scheme to make money out of Pennwalt, a Pennsylvania chemical company. The plan
+was to group together with two other parties to take a substantial declared position
+in the stock. According to a source, Epstein was supposed to help Nederlander and
+Toboroff raise $15 million. He seemed to fail to find other investors, say those
+familiar with the deal. (Epstein has
+said he was merely an investor.) He invested
+$1 million, which he told his co-investors was his own money. But in his 1989 deposition
+he said that he put in only $300, 000 of his own money. Where did the rest come from?
+Hoffenberg has said it came from him, in a loan that Nederlander and Toboroff didn't
+know about.
+Two things happened that alarmed Nederlander and Toboroff. After the group signaled
+a possible takeover, the Pennwalt management threatened to sue the would-be raiders.
+Epstein was reluctant initially to give a deposition about his share of the money,
+telling Toboroff there were "reasons" he didn't want to. Then, after the opportunity
+for new investors was closed, co-investors recall Epstein announcing that he'd found
+one at last: Dick Snyder, then C.E.O. of the publisher Simon & Schuster, who wanted
+to put up
+approximately
+$500, 000. (Neither Epstein nor Snyder can now recall the
+investment. Yet in the 1989 deposition Epstein said that he had recruited Snyder,
+whom he had met socially, into the deal.)
+According to a source, Toboroff and Nederlander told Epstein that Snyder was too
+late, but, without their
+realizing it, Hoffenberg has claimed, Snyder wrote a check
+to Hoffenberg and bought out some of his investment. But then Snyder wanted out.
+"Nederlander started to get these irate calls from (Snyder,) who wasn't part of
+the deal, saying he was owed all this money, " says someone close to the deal. Toboroff
+and Nederlander were baffled.
+Eventually, a source close to Hoffenberg says, Hoffenberg paid Snyder off.
+Just as Nederlander and Toboroff were growing wary of Epstein, he became increasingly
+involved with Leslie Wexner, whom he had met through insurance executive Robert Meister
+and his late wife. Epstein has told people that he met Wexner in 1986 in Palm Beach,
+and that he won his confidence by persuading him not to invest in the stock market,
+just as the 1987 crash was approaching. His story has subsequently changed. When asked
+if Wexner knew about his connection to Hoffenberg, Epstein said that he began working
+for Wexner in 1989, and that "it was certainly not the same time."
+Wherever and whenever it was that Epstein
+and Wexner actually met, there was an
+immediate and strong personal chemistry. Wexner says he thinks Epstein is "very smart
+with a combination of excellent judgment and unusually high standards. Also, he is
+always a most loyal friend."
+Sources say Epstein proved that he could be useful to Wexner as well, with "fresh"
+ideas about investments.
+"Wexner had a couple of bad investments, and Jeffrey cleaned
+those up right away," says a former associate of Epstein's.
+Before he signed on with Wexner, Epstein had several meetings with Harold Levin,
+then head of Wexner Investments, in which he enunciated ideas about currencies that
+Levin found incomprehensible.
+"In fact," says someone who used to work very closely
+with Wexner, "almost everyone at the Limited wondered who Epstein was; he literally
+
+
+Page 11
+The Talented Mr. Epstein;Lately, Jeffrey Epstein's high-ying style
+came out of nowhere."
+"Everyone was mystified as to what his appeal was, " says Robert Morosky, a former
+vice-chairman of the Limited.
+Much of Epstein's work is related to cleaning up, tightening budgets, andefficiencies.
+One person who worked for Wexner and who saw a contract drawn up between the two men
+says Epstein is involved in "everything, not just a little here, a little there.
+Everything!" In addition, he says,
+"Wexner likes having a hatchet man... Whenever
+there is dirty work to be done he'd stick Jeffrey on it... He has a reputation for
+being ruthless but he gets the job done."
+Epstein has evidently been asked to fire personal-staff members when needed. "He
+was that mysterious person that everyone was scared to death of, " says a former
+employee.
+Meanwhile, he is also less than popular with some people outside Wexner's company
+with whom he now deals. "He 'inserted' himself into the construction process of Leslie
+Wexner's yacht... That resulted in litigation down the road between Mr. Wexner and
+the shipyard that eventually built the vessel, " says Lars Forsberg, a lawyer whose
+firm at the time, Dickerson and Reily, was hired to deal with litigation stemming
+from the construction of Wexner's Limitless-at 315 feet, one of the largest private
+yachts in the world. Evidently, Epstein stalled on paying Dickerson and Reily for
+its work. "It's probably once or twice in my legal career that I've had to sue a client
+for payment of services that he'd requested and we'd performed ... without issue on
+the performance, " says Forsberg. In the end the matter was settled, but Epstein claims
+he now has no recollection of it.
+The incident is one of a number of disputes Epstein has become embroiled in. Some
+are for sums so tiny as to be baffling; for instance, Epstein sued investment adviser
+Herbert Glass, who sold him the Palm Beach house in 1990, for $13,444-Epstein claimed
+this was owed him for furnishings removed by Glass.
+In 1998 the U.S. Attorney's Office sued Epstein for illegally subletting the former
+home of the deputy consul general of Iran to attorney Ivan Fisher and others. Epstein
+paid $15,000 a month in rent to the State Department, but he charged Fisher and his
+colleagues $20,000. Though the exact terms of the agreement are sealed, the court
+ruled against Epstein.
+Wexner offers some insight into his friend's combative style. "Many times people
+confuse winning and losing, " Wexner says. "Jeffrey has the unusual quality of knowing
+when he is winning. Whether in conversations or negotiations, he always stands back
+and lets the other person determine the style and manner of the conversation or
+negotiation. And then he responds in their style. Jeffrey sees it in chivalrous terms.
+He does not pick a fight, but if there is a fight, he will let you choose your weapon."
+One case is rather more serious. Currently, Citibank is suing Epstein for defaulting
+on loans from its private-banking arm for $20 million. Epstein claims that Citibank
+"fraudulently induced" him into borrowing the money for investments. Citibank disputes
+this charge.
+The legal papers for another case offer a rare window into Epstein's finances.
+In 1995, Epstein stopped paying rent to his landlord, the nonprofit Municipal Arts
+Society, for his office in the Villard House. He claimed that they were breaking the
+terms of the lease by not letting his staff in at night. The case was eventually settled.
+However, one of the papers filed in this dispute is Epstein's financial statement
+for 1988, in which he claimed to be worth $20 million. He listed that he owned $7
+million in securities, $1 million in cash, zero in residential property (although
+he told sources that he had already bought the home in Palm Beach), and $1l million
+in other assets, including his investment in Riddell. A co-investor in Riddell says:
+"The company had been bought with a huge amount of debt, and it wasn't public, so
+
+
+Page 12
+The Talented Mr. Epstein;Lately, Jeffrey Epstein's high-ying style
+it was meaningless to attach a figure like that to it ... the price it cost was about
+$1.2 million." The co-investors bought out Epstein's share in Riddell in 1995 for
+approximately $3 million. At that time, when Epstein was asked, as a routine matter,
+to sign a paper guaranteeing he had access to a few million dollars in case of any
+subsequent disputes over the sale price, Wexner signed for him. Epstein has explained
+that this was because the co-investors wanted an indemnity against being sued by
+Wexner. One of the investors calls this "bullshit."
+Epstein's appointment to the board of New York's Rockefeller University in 2000 brought
+him into greater social prominence. Boasting such social names as Nancy Kissinger,
+Brooke Astor, and Robert Bass, the board also includes such pre-eminent scientists
+as Nobel laureate Joseph Goldstein. "Epstein was thrilled to be elected, " says someone
+who knows him.
+After one term Epstein resigned. According to New York magazine, this was because
+he didn't like to wear a suit to meetings. A spokesperson for the Rockefeller board
+says Epstein left because he had insufficient time to commit; a board member recalls
+that he was "arrogant" and "not a good fit." The spokesperson admits that it is
+"infrequent" for board members not to be renominated after only one term.
+Still, the recent spate of publicity Epstein has inspired does not seem to have
+fazed him. In November he was spotted in the front row of the Victoria's Secret fashion
+show at New York's Lexington Avenue Armory; around the same time the usual coterie
+of friends and beautiful
+women were whisked off to Little St. James (which he tells
+people has been renamed little St. Jeff) for a long weekend.
+Thanks to Epstein's introductions, says Martin Nowak, the biologist finds himself
+moving from Princeton to Harvard, where he is assuming the joint position of professor
+of mathematics and professor of biology. Epstein has pledged at least $25 million
+to Harvard to create the Epstein Program for Mathematical Biology and Evolutionary
+Dynamics, and Epstein will have an office at the university. The program will be
+dedicated to searching for nature's algorithms, a pursuit that is a specialty of
+Nowak's. For Epstein this must be the summit of everything he has worked toward: he
+has been
+seen proudly displaying Harvard president Larry Summers's letter of
+commitment as if he can't quite believe it is real. He says he was reluctant to have
+his name attached to the program, but Summers persuaded him. He rang his mentor Wexner
+about it, and Wexner told him it was all right.
+Soul hia relaxation SEts as 1e Covet plause has to be
+self-improvement. Nowak says that, when he goes to stay with Epstein in the Caribbean,
+they'll get up at six and, as the sun rises, have three-hour conversations about
+theoretical physics. "Then he'll go off and do some work, re-appear, and we'll talk
+some more."
+Another person who went to the island with Epstein, Maxwell, and several beautiful
+women remembers that the women "sat around one night teasing him about the kinds of
+grasping women who might want to date him. He was amused by the idea... He's like
+a king in his own world."
+Many people comment there is something innocent, almost childlike about Jeffrey
+Epstein. They see this as refreshing, given the sophistication of his surroundings.
+Alan Dershowitz says that, as he was getting to know Epstein, his wife asked him if
+he would still be close to him if Epstein suddenly filed for bankruptcy. Dershowitz
+says he replied, "Absolutely. I would be as interested in him as a friend if we had
+hamburgers on the boardwalk in Coney Island and talked about his ideas." N
+
+
+The Talented Mr. Epstein;Lately, Jeffrey Epstein's high-ying style
+GRAPHIC: LEFT, BY JAMES ESTRIN; RIGHT, BY DUBLIN CAINE; MR. BIG Jeffrey Epstein in
+New York, 2001. Left, Epstein's nine-floor, 51,000-square- foot town house. He also
+owns a 7, 500-acre ranch in New Mexico, a house in Palm Beach, and a Caribbean island.;
+TOP TO BOTTOM: BY ALBERTO PINTO, LISA HINGE, J. B. SCHMITKA; unreal estate From top:
+the "leather room" in Epstein's house, where "tea" is served to guests; Epstein at
+his Zorro ranch in 1991 with his "best friend," Ghislaine Maxwell; Epstein in 1979.;
+TOP TO BOTTOM: BY LISA HINGE, SARAH KELLEN, ADAM SCULL; SPOILS OF SUCCESS From top:
+Epstein's 70- acre island, Little St. James, in the U.S. Virgin Islands-he now calls
+it Little St. Jeff; Epstein with President Clinton in Brunei, 2002; Leslie Wexner
+with his future wife, Abigail, at the 1990 C.F.D.A. Fashion Awards, in New York, 1991.;
+ALBERTO PINTO; OFFICE SPACE The "office" in Epstein's house. It has no computers,
+but it does have a desk that Epstein tells people once belonged to banker J. P. Morgan,
+and "the largest Persian rug you'll ever see in a private home."; Pages 300-301: Left,
+from The New York Times. Page 304: Bottom, from Globe Photos.
+LOAD-DATE: January 24, 2005
diff --git a/vision-fixhub/ds9-unparsed-06/0f61540c3cde0fe2c1016aaf350ef1c64a9b56f99084fc4096b5b078961cd317.receipt.json b/vision-fixhub/ds9-unparsed-06/0f61540c3cde0fe2c1016aaf350ef1c64a9b56f99084fc4096b5b078961cd317.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d2c9f91028f4345645e151fa9abb2dc03570370a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0f61540c3cde0fe2c1016aaf350ef1c64a9b56f99084fc4096b5b078961cd317.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -156,
+  "dataset": "marble-joined",
+  "doc_id": "0f61540c3cde0fe2c1016aaf350ef1c64a9b56f99084fc4096b5b078961cd317",
+  "engine": "marble-apple-vision",
+  "event_count": 13,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "c6a9a2debb1dfcb64890c91f38272d95a3fabbb9060987fa9f772e489cb0923e",
+  "output_sha256": "ec54207317c229e34e3dfc5b22f24243dca316e113f35c93dc4dbe2b6b478503",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0f69249cfe851e5f516c53e415dc6d1ea99e50798bc3a0cfb30fdedef20b5dc6.md b/vision-fixhub/ds9-unparsed-06/0f69249cfe851e5f516c53e415dc6d1ea99e50798bc3a0cfb30fdedef20b5dc6.md
new file mode 100644
index 0000000000000000000000000000000000000000..792e656eae46f5dd0098c1966ed19774a87861f1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0f69249cfe851e5f516c53e415dc6d1ea99e50798bc3a0cfb30fdedef20b5dc6.md
@@ -0,0 +1,2759 @@
+LefERey E EPsTeIN
+Questions or Changes?
+: Tolites 11
+attwireless.com
+:
+611 from your wireless phone
+TTY users - 1 866 4-AW S-TTY
+SUMMARY OF MONTHLY CHARGES FOR ACCOUNT
+Previous
+Payments
+Balance
+Late Payment
+Received
+622.73
+-622.73
+0.00
+Account
+Adjustments
+0.00
+Your billing cycle began on October 03, 2004 and ended on November 02, 2004
+Current Monthly Charges
+Subscriber Adjustments
+Monthly Service
+Monthly Usage
+Charges
+Credits
+Taxes, Surcharges & Regulatory Fees
+Total Current Monthly Charges
+DUE UPON RECEIPT
+TOTAL AMOUNT DUE
+Date of Invoice: November 05, 2004
+Balance
+Forward
+0.00
+Current Monthly
+Charges
+419.68
+Total
+Amount Due
+419.68
+0.00
+186.68
+189.05
+0.00
+0.00
+43.95
+419.68
+419.68
+Note:
+=>
+We Print on
+Front and Back
+AT&T WIRELESS APPRECIATES YOUR BUSINESS
+Please Retur This Portion With Your Payment
+use ofe General Terms and Chinions for vies see t
+Account Name: JEFFREY E EPSTEIN
+Yes at to deal ted to the cave my the ec
+(see reverse - signature required)
+Date Due
+UPON RECEIPT
+Service #
+Account
+Chack ess see chaese.
+Total
+Amount Due
+419.68
+Amount
+Paid
+#BWNHNGB
+
+
+LEFEREY E EPSTEIN
+W
+#AUTO T2 0 1102 10022.5.22.01.1000.0000
+AT&T WIRELESS
+PO BOX 8229
+AURORA IL 60572-8229
+000000000000000000•
+
+
+Recurring Electronic Fund Transfer (REFT): To enroll: sign below, check the REFT box on the reverse side and
+remit with this month's payment. Keep paying your bill until your statement indicates "Do Not Pay". REFT
+Agreement: I authorize my financial institution to deduct the amount of my monthly wireless phone bill from the
+account associated with the enclosed check and remit payment to AT&T Wireless. This authority will be effective
+until I notify AT&T Wireless to terminate it. I agree that I may be assessed a service charge (up to $20) or late fee
+or both if a payment is returned by my bank. For more information visit attwireless.com/ocs or call 1
+Please keep a copy of the form below and this REFT Agreement for your records or retain a copy of the blank form
+from next month's invoice.
+Questions? We can help: AT&T Wireless appreciates your business and welcomes the opportunity to assist you.
+As part of our commitment to you, we are always adding new calling plans and promotions to match your individual
+needs. Visit our website at attwireless.com or contact Customer Care by dialing 611 from your wireless phone or 1
+1. ¿Sabias que también ofrecemos servicio al cliente en tu idioma? Marca 611 desde tu teléfono
+inalámbrico ó 1
+desde cualquier teléfono y oprime el *.
+Driving Wireless Safety: Your wireless phone gives you the freedom and flexibility to stay in touch when you
+travel, but don't let a phone call distract you from driving safely. Use hands-free device if allowed or required by
+law. Call Carefully, Arrive Safely.
+AT&T Wireless Processing Fees: Accounts suspended for non-payment will be subject to a $25 reactivation fee
+per line and may be assessed a security deposit prior to reinstatement. Checks returned for non-sufficient funds will
+be charged up to a $20.00 fee.
+Local Tax: Local taxes are based on local goverment boundaries, the address information you provide for your
+account and/or your wireless telephone number. Please review the local tax charges on vour bill. If you believe
+here is an error in the local tax charge, please contact us immediately at 1
+local or state laws may require you to follow special procedures when notifying us about a local tax dispute. You
+may also use the form below to notify us of any change to your taxing address. Thank you for your cooperation.
+Early Termination Fee (ETF): If you cancel service before your contract end date (including if you switch your
+wireless number to another carrier), you will be charged an Early Termination Fee of up to $200.
+Please Send Correspondence To:
+AT&T Wireless Next Generation Correspondence
+P.O. Box 68056
+Anaheim Hills, CA 92817-8056
+2000297.000002130.6
+Change of Address Only. Please print address clearly and check the box on the reverse side. Please contact Customer Care to change the
+Account Name and transfer Financial Responsibility
+New Billing Address
+City
+State
+Zip
+Home Phone (
+Work Phone (.
+If your billing address is NOT your Tax Address*, please enter the Tax Address below. (Multi-line accounts should attach a list of each wireless number
+and the respective Tax Address.)
+New Tax Address*
+Wireless Number (
+Jnder Federal laws, your Tax Address must be: your primary place of use, your residential or business address, and located within AT&T Wireless
+censed service area. Non-business customers on AT&T Digital One Rate, Regional Advantage or Shared Advantage plans must use their residentia
+address as their tax address.
+Recurring Electronic Fund Transfer (REFT) Enrollment. Please read the agreement on the top portion of this page, sign below and check
+the "REFT Registration" box on the reverse side.
+Financial Account Holder Signature
+- 6.1 - 3G
+• + I do not wish to receive email notification of special oilers avalable to AT&T Wireless customers.
+
+
+ACCOUNT DETAILS
+Detail of Payments - Thank You!
+Item Description
+1 PAYMENT
+Total of Payments
+Current Subscriber Monthly Charges and Credits
+lumber
+Subscriber Name
+Date Applied/Reversed Payment Amount
+10/24/04
+-622.73
+Tolal current Subscriber Monthly Charges and Credits
+Total Current Monthly Charges
+SUMMARY OF CURRENT ACTIVITY
+Monthly Service Charges
+Item Description
+4 EARLY EVENING
+5 ENH DISCOUNT INTL DIAL
+6 MULTIMEDIA MESSAGING $2.99
+7 AT&T VOICEMAIL
+8 MMODE/DATA SERVICE (4MB)
+9 NATIONAL PLAN $149.99
+10 THREE WAY CALLING
+11 REGULATORY PROGRAMS FEE
+12 VOICEDIAL SERVICE $3.99
+14 DISCOUNTED INTERNATIONAL ROAMING
+Total Monthly Service Charges
+Service Dates
+10/03/04 - 11/02/04
+10/03/04 - 11/02/04
+10/03/04 - 11/02/04
+10/03/04 - 11/02/04
+10/03/04 - 11/02/04
+10/03/04 - 11/02/04
+10/03/04 - 11/02/04
+10/03/04 - 11/02/04
+10/03/04 - 11/02/04
+10/03/04 - 11/02/04
+10/03/04 - 11/02/04
+10/03/04 - 11/02/04
+10/03/04 - 11/02/04
+10/03/04 - 11/02/04
+Monthly Usage Charges
+Item Description
+1 UNLIMITED N/WKND MIN
+2 MESSAGE RETRIEVAL
+3 CALL WAITING
+4 400 ADD'L ANYTME MIN
+5 UNLIM MOBL TO MOBL
+6 411 INFO
+7 EARLY EVENING N/WKND
+8 100 INCL. MSGS SENT
+9 INTL TEXT MSG
+10 ENH DISC INT DL
+11 INCLUDED MINUTES
+12 DISCOUNT INT'L ROAM
+Onty Used
+927 MIN
+37 EVT
+27 EVT
+400 MIN
+163 MIN
+7 EVT
+200 MIN
+20 EVT
+5 EVT
+50 MIN
+480 MIN
+164 MIN
+- 622.73
+-622.73
+419.68
+419.68
+419.68
+0.00
+4.99
+0.00
+0.00
+3.99
+2.99
+0.00
+12.99
+149.99
+0.00
+1.75
+1:33
+0.00
+0.00
+0.00
+0.00
+0.00
+10.50
+0.00
+0.00
+1.25
+13.44
+0.00
+162.36
+
+SUMMARY OF CURRENT ACTIVITY - CONTINUED
+Monthly Usage Charges - Continued
+Item Description
+13 INTL ROAM TEXT MSG
+14 INCLUDED IN PLAN MB
+Anty Used
+3 EV
+180 KB
+Taxes, Surcharges and Regulatory Fees
+Item Description
+1 LOCAL WIRELESS SURCHARGE
+2 MCTD SURCHARGE
+3 FEDERAL TAX
+4 TELECOM EXCISE TAX
+5 SALES TAX
+5 ST WIRELESS COMM SURCHARGE
+7 UNIVERSAL CONNECTIVITY CHARGE
+8 NY CITY UTILITY G.R. SUR
+Total Taxes, Surcharges and Regulatory Fees
+TOTAL CHARGES FOR
+DETAIL OF CURRENT ACTIVITY
+Item Date Time
+Called
+1 10/03 10:53A
+2 10/03 11:21A
+
+5 10/03 01:50P
+6 10/03 03:55P
+7 10/03 04:17P
+8 10/03 04:18P
+9 10/03 04:19P
+12 10/03 09:13P
+15 10/04 09:15A
+19 1004 10-214
+18 10/04 10:55A
+28 10/04 13:36P
+10/04 12:59P
+25 10/04 01:00P
+26 10/04 01:01P
+HE REACH FL
+NCOMING
+JEW YORK NY
+LAKE WORTH FL
+NCOMING
+LENE VORTIFE
+NEW YORK NY
+COMING
+INCOMING
+ICOMIN
+COMIN
+INCOMING
+INCOMING
+VILLOUGHBY OF
+EWYORKZN1 N
+VEWYORKZN1 NY
+NEW YORK NY
+VILLOUGHBY OH
+IEWYORKZN1 NY
+Qnty
+Used Rate Description
+1 MIN
+UNLIMITED N/WKND MIN
+1 MIN
+UNLIMITED N/WKND MIN
+2 MIN
+> MIN
+UNLIMITED WIND MIN
+5 MIN
+UNLIMITED N/WKND MIN
+MESSAGE RETREA
+2 MIN
+UNLIMITED N/WKND MIN
+1 MIN
+HMIN
+UNLIMITED N/WKND MIN
+UNLIMITE NANK MIN
+1EVT
+13 MIN
+1 MIN
+EMIN
+2 MIN
+I MIN
+1 MIN
+1 MIN
+MESSAGE RETRIEVAL
+NAMED NOT
+400 ADD'L ANYTME MIN
+IO ADD'L ANY
+400 ADD'L ANYTME MIN
+400 ABBLANYTE MIN
+UNLIM MOBL TO MOBL
+400 ADD'L ANYTME MIN
+400 ADD'L
+ANYTME
+MIN
+1 MIN
+1 MIN
+UNLIM MOBL TO MOBL
+400 ADD'L ANYTME MIN
+0,00
+189.05
+0.30
+1.72
+6.27
+6.98
+17.59
+5,30
+4.36
+43.95
+419.68
+2000297.000002131
+
+
+TET200000 262000Z
+ber
+Item Date Time
+Called
+27 10/04 01:14P
+28 10/04 01:17P
+0/04 01:24
+0 10/04 01-25
+31 10/04 01:26P
+32
+10/04 01:27P
+10/04 01:46R
+34 10/04 01:48P
+1004 81:50
+38 10/04 02:31P
+41 10/04 02:44P
+13 10/04 02:04P
+
+§§5555655§55888858585555555
+
+{8KE58588
+BOYNTONBCH FL
+NEW YORK NY
+W PALMBEACH FL
+COMIN
+COMIN
+WPALMBEACH FL
+PALMBEACH I
+PALMBEACH R
+WPALMBEACH FL
+INCOMING
+NEW YORK NY
+COMIN
+- Continued
+Qnty
+Used Rate Description
+1 MIN
+UNLIM MOBL TO MOBL
+2 MIN
+400 ADD'L ANYTME MIN
+EMIN
+O ADD'L ANTIME M
+1MIN
+400 ADDL ANYTME MIN
+4 MIN
+INLIM MOBL TO MOB
+2 MIN
+O ADD'L ANYTME M
+1 MIN
+400 ADD'L ANYTME MIN
+AMIN
+400 ABB'L ANYTE MIN
+3 MIN
+I00 ADD'L ANYTME MIN
+3 MIN
+100 ADD'L ANYTME MIN
+1EVT 1.50 411 INFO
+DO ADD'L ANYTME MI
+NLIM MOBL TO MOB
+2 MIN
+MIN
+400 ADD'L ANYTME MIN
+400 ADD'L ANYTME MIN
+3838
+
+
+Item Date Time Called
+90 10/06 04:30P
+91 10/06 05:16P
+3 10/06 09:28
+‹ 106 0
+94 10/06 09:39P
+• 10/0G 09:40
+¡ 10/06 09:43
+97 10/07 07:31A
+8 10/07 02:23
+O0 10/07 04:28
+01 10/07 04:29
+
+103 10/07 04:39P
+104 10/07 06:06P
+5 10/07 06:09
+06:15
+5br55=525E35=85855EE E5E55ğ5ğEEB3Eğ8ЭĞåEEEGE&8ăăą$
+INCOMING
+INCOMING
+W YORK C
+• ZONE 1N
+NEW YORK NY
+SECON
+NEW YORK NY
+INCOMING
+NEW YORK NY
+mobile UK
+- Continued
+Onty
+Used Rate Description
+2 MIN
+400 ADD'L ANYTME MIN
+2 MIN
+400 ADD'L ANYTME MIN
+15 MIN
+UNLIMITED NAB MIN
+UNLIMITED N/WKND MIN
+NEW YORK NY
+NWYRCYZNO1 NY
+= 33 33
+NY
+PALM
+NCOM
+:OM
+EACH FL
+2 MIN
+IMIN
+UNLIM MOBL TO MOBL
+1 MIN
+00 ADD'
+0.28 ENH DISC INT DL
+UNLAR MOBL TO MOBIN
+400 ADD'L ANYTME MIN
+2 MIN
+5 MIN
+2 MIN
+31
+833883333[83333 888335CLE CELEBEES
+AD
+AD
+UNLIM
+BL
+
+
+Item Date Time
+Called
+154 10/08 04:24P
+155 10/08 04:26P
+b 1008 04:3
+7 10 08 05:0
+158 10/08 08:07P
+159 10/08 08:08P
+160 10/08 08:28P
+2 10/08 085
+163 10/08 09:58P
+164 10/09 11:59A
+_b> 1009
+166 10/09 12:22P
+167 10/09 12:43P
+168 10/09 12:47P
+169 10/09 12:48P
+170 10/09 12:57P
+10/09 01:14F
+10/09
+01:76P
+173 10/09 01:36P
+174 10/09 01:37P
+520
+10/09
+01:41P
+10/09 01:49P
+10/09 03:21P
+170
+
+180 10/09
+03:45P
+101
+10/09
+04:02P
+18A 10009 04:24P
+188 10/09 03:31P
+188 1009 0352P
+189 10/09 07:38P
+190 10/09 07:40P
+- Continued
+Qnty
+NEW YORK NY
+WPALMBEACH FL
+NCOMING
+DUEENS NY
+INCOMING
+NEW YORK NY
+PALM BEACH FL
+VPALMBEACH FL
+JEW YORK NY
+Used Rate Description
+1 MIN
+400 ADD'L ANYTME MIN
+1 MIN
+UNLIM MOBL TO MOBL
+1 MIN
+400 ADDI
+ANYTME MIN
+IMIN
+UNLIM MOBL TO MOBI
+1 MIN
+EARLY EVENING NAKND
+2 MIN
+1EVT
+MESSAGE RETRIEVAL O
+MESSAGE
+3 MIN
+EARLY EVENING N/KND
+1 MIN
+2 MIN
+INCOMING
+1EVT
+EARLY EVENING NAKN
+ESSAGE RETRIEVA
+58 MIN
+NLIMITED NIKND M
+INCOMING
+1 MIN
+UNLIMITED N/WKND MIN
+INCOMING
+WILLOUGHBY OH
+AMIN
+UNLIMITED MININ
+NEW YORK NY
+2 MIN
+UNLIMITED N/WKND MIN
+INCOMING
+NEW YORK NY
+IMIN
+1 MIN
+MESSAGE
+RETRIEVAL
+NWYRCYZN01 NY
+INCOMING
+INCOMING
+NEW YORK NY
+NEW YORK NY
+1 MIN
+10 MIN
+1 MIN
+1EVT
+_MIN
+1EVT
+WPALMBEACH FL
+INCOMING
+EMIN
+WPALMBEACH FL
+2 MIN
+INCOMING
+MILLOUGHRY OH
+INCOMING
+1 MIN
+NWYRCYZNO2 NY
+NEW YORK MY
+REW YORK NY
+NEW MORE Y
+INCOMING
+NEW YORK NY
+193 10/09 08:10P
+183 10/09 09:028
+196 10/09 10:58P
+197 10/10 09:194
+198 10/10 09:23A
+199 10/10 09:23A
+200 10/10 09:32A
+202 18/0 12:044
+104
+18/18
+13:935
+205 10/10
+12:50P
+206 10/10 04:32P
+207 10/10 05:02P
+INCOMING
+OMING
+INCOMING
+IEWYORKZNI NY
+NCOMING
+INCOMING
+NEW YORK NY
+WPALMBEACH FL
+NEW YORK NY
+QUEENS NY
+NCOMIN
+VPALMBEACH F
+WALMBEACH FE
+INCOMING
+INCOMING
+1 MIN
+1 MIN
+1EVT
+1 MIN
+1 MIN
+1EVT
+4 MIN
+4 MIN
+1 MIN
+. MIl
+EV
+1 MIl
+1 MIN
+1 MIN
+2 MIN
+I MIR
+2 MIN
+2 MIN
+1EV
+1 MIN
+IMIT
+IMIN
+EMIN
+2 MIN
+IMIN
+150 RE
+UNLIMIT
+KND
+MIN
+MIN
+
+Called
+Item Date Time
+208 10/10 05:15P
+209 10/10 05:18P
+210 10/10 08318
+10/10 08:318
+212 10/10 08:32P
+10/10 08:43P
+LO 09:12P
+215
+10/10 09:24P
+/10 09:2
+10 09:2
+219 10/0 09:328
+220 10/10 10:17P
+222 10/10 10:20P
+10/10
+10:
+25P
+INCOMING
+INCOMING
+COMIN
+EW YORK N°
+NEW YORK NY
+NEW TO NO
+QUEENS NY
+INCOMING
+INCOMING
+NEW YORK NY
+- Continued
+Qnty
+Used Rate Description
+3MIN
+UNLIMITED N/WKND MIN
+9MIN
+UNLIMITED N/WKND MIN
+1 MIN
+INLIMILED NIWKND MIR
+1 MIN
+1 MIN
+UNLIMITED NWKND MIN
+1 MIN
+1 MIN
+UNLIMITEB NAND MIN
+ID MIN
+2 MIN
+UNLIMITED NAWKND MIN
+2 MIN
+SMIN
+31 MIN
+1 MIN
+INLIMTER NAEND MIN
+TED NAV
+ND MIN
+UNLIMITED N/WKND MIN
+1 MIN
+3MIN
+1 MIN
+3MIN
+1 MIN
+UNLIMITED N/WKND MIN
+NLIMITED N/WKND MIl
+KND
+≥8З₴Е{£&·Ę{&åå8BЗЗЗЗЗЗĘ8ЗЗЗЗЗЗЗ8ЗЗ&₴&BЗЗЗЗЗĘ8ЗĘ{{
+2000297.000002132
+
+
+2000297.000002132
+Item Date Time
+Called
+274 10/11 03:58P
+275 10/11 04:23P
+278 10/11 05:48P
+270
+10 11 0550r
+15-50P
+281 10/11 05:51P
+
+383 18/11 05:33P
+05:53P
+28918/11 18/1105:36P
+28B 10/11 05:58P
+25018/11 18/1105:81P
+SS58353555858363638389833
+88888885988:
+
+S6S28402
+NEW YORK NY
+NEW YORK NY
+QUEENS NY
+VEENS N
+EW YORK N
+NEW YORK NY
+CHNSTDSTCR VI
+COMIN
+NEW YORK NY
+- Continued
+Qnty
+Used Rate Description
+1 MIN
+UNLIM MOBL TO MOBL
+1 MIN
+UNLIM MOBL TO MOBL
+INLIM MOBL TO MOB
+INTIME MI
+2 MIN
+1 MIN
+1 MIN
+1 MIN
+EMIN
+L MIN
+1 MIN
+1EVT
+EMIN
+1 MIN
+SMIN
+UNLIM MOBL TO MOBL
+JNLIM MOBL TO MOBL
+100 ADD'L ANYTME MIN
+400 ADD'L ANYTME MIN
+100 ABB'L ANY THE MIN
+INLIM MOBL TO MOB
+00 ADD'L ANYTME MIl
+CALL WAITING
+400 ADD'L ANYTME MIN
+CALL WAITING
+≥ ≥≥≥≥≥≥©≥
+100 ABB
+ADD
+- ANYTME
+400 ADD'L ANYTME
+IN
+00 ADD'L Al
+MiN
+DO ADD'L AN
+MIN
+EARLY
+ING
+UNLI
+zzZ
+N/WKND
+KI
+UNLIMITEB
+400 ADD'L
+MIN
+00 ADD'
+IN
+100 ADD'
+SOLM NOBL TO MOBIL
+400 ADD'L ANYTME MIN
+: MIN
+100 ABD'L ANYTE MIN
+400 ADD'L ANYTME MIN
+400 ADD'L ANYTME MIN
+400 ADD'L ANYTME
+MIN
+MIt
+MIN
+400 ADD'L ANYTME MIN
+UNLIM MOBL
+400 ADD'L ANYTME MIN
+UNLIM MOBL TO MOBL
+400 ADD
+'L ANYTME MIN
+UNLIM MOBL TO MOBL
+MOBI
+12
+400 ADD'L ANYTME MIN
+MIN
+MIN
+400 ADD'L ANYTME MIN
+400 ADD'L ANYTME MIN
+
+Item Date Time Called
+338 10/12 02:43P
+339 10/12 03:01P
+40 10/22 03:146
+41 10/12 03:16P
+342 10/12 03:16P
+343 10/12 03:29P
+344 10/12 03:31P
+346 18/12 0337P
+347 10/12 03:38P
+348 10/12 04:01P
+349 10/12 04:07P
+
+352 10/12 04:11P
+333 18/12 01538
+358 18/12 09 S0P
+10.
+12:18P
+358
+3500
+B2.18P
+361 10/13 02:41P
+362 10/13 03:05P
+36:
+26A
+01250
+367 10/14 03:06P
+368 10/14 03:07P
+369 10/14 03:20P
+370 10/14 03:28P
+371 10/14 06:13P
+372 10/14 07:25P
+373 10/14 09:14P
+374 10/14 09:16P
+338 18/15 18-334
+378 181
+02:138
+02:16P
+380 10/13 02 18P
+381 10/15 02:21P
+382 10/15 02:38P
+385 10/16 09:32A
+386 10/16 11:56A
+387 10/16 11:57A
+INCOMING
+INCOMING
+VI YORK N
+LOOKLYN N
+INCOMING
+INCOMING
+NEW YORK NY
+- Continued
+Onty
+Used Rate Description
+1 MIN
+400 ADD'L ANYTME MIN
+1 MIN
+400 ADD'L ANYTME MIN
+EMIN
+TO MOBL
+DO ADDL ANYTME MI
+1 MIN
+400 ADD'L ANYTME MIN
+L'ANYTME MIN
+400 ADD'L ANYTME MIN
+UEENS N
+COMIN
+INCOMING
+NEW YORK NY
+NEW YORK NY
+COMIN
+EW YORK N
+INCOMING
+NEW YORK NY
+WPALMBEACH FL
+WPALMBEACH FL
+NCOMING
+NEW YORK NY
+NEW YORK NY
+NCOMING
+NEW YORK NY
+QUEENS NY
+COMING
+NEW YORK NY
+NEW YORK NY
+INCOMING
+INCOMING
+NEW YORK NY
+NEW YORK NY
+NEW YORK NY
+NEW YORK NY
+COMIN
+IN COMING
+NEW YORK NY
+INCOMING
+INCOMING
+QUEENS NY
+YORK NY
+INCOMING
+NEW YORK NY
+NEW YORK NY
+1 MIN
+2 MIN
+3 MIN
+2 MIN
+3 MIN
+1 MIN
+1EVT
+1 MIN
+B MIN
+1 MIN
+4 MIN
+2 MIN
+1 MIN
+1 MIN
+LENT
+1EVT
+1 MIN
+1 MIN
+1EVT
+1 MIN
+LEVT
+2 MIN
+LEV
+2 MIN
+25 MIN
+1 MIN
+LEV
+1 MIN
+1EVT
+IMIN
+1EVT
+EMIN
+2 MIN
+LEVY
+1 MIN
+2 MIN
+11 MIN
+AMIN
+6 MIN
+EV
+7 MIN
+AND AD BALT ME MIN
+400 ADD'L ANYTME MIN
+400 ADD'L ANYTME MIN
+EARL EVEN KND
+MESSAGE RETRIEVAL
+JNLIMIT
+MESSAGE RETRIEVAL
+TETRIEVAL
+400 ADD'L ANYTME MIN
+10 ADD'L ANYTME M
+O ADD ANYTME M
+UNLIM MOBL TO MOBL
+MESSAGE RETRIEVAL
+INI IM MORI
+O MOBL
+MESSAGE RETRIEVAL
+400 ADD'L
+BOANTONE MIN
+TO MORI
+MESSAGE RETRIEVAL
+UNLIM MOBL TO MOBL
+400 ADDI ANYTME MIN
+IM MOBLTO MOB
+¡ESSAGE RETRIEVA
+UNLIM MOBL TO MOBL
+400 ADD'L ANYTME MIN
+NLIM MOBL TO MOB
+ESSAGE RETRIEVA
+EARLY EVENING N/WKND
+MESSAGE RETRIEVAL
+UNLIMITED N/KND MIN
+MESSAGE RETRIEVAL
+JNLIMITED N/WKND MIN
+INLIM MOBL TO MOBI
+MESSAGE RETRIEVAL
+400 ABL ANY ME MIN
+400 ADD'L ANYTME MIN
+400 ADD'L ANYTME MIN
+DADD'L ANYTMEN
+DED MINIIT
+UNLIMITED MANK MIND
+INLIMI
+UNLIMITED N/WKND MIN
+INLIMITED NAWKND MIL
+ESSAGE RETRIEVA
+UNLIMITED N/KND MIN
+
+
+Item Date Time Called
+388 10/16 12:11P
+389 10/16 12:40P
+390 10/16 01:58P
+382 10/16 02:23P
+393 18/18 02:32P
+95 10/16 02:43P
+96 10/16 02:44P
+
+399 10/16 03:21P
+400 10/16 03:22P
+401 10/16 08:17P
+402
+403
+10/16
+09:00P
+1006
+09:10P
+404
+10/16
+:29P
+405
+10
+406
+407
+2999
+
+9881
+56/
+3B80006A636006888#8ä889=EE036839§
+e98888g8@95Е98Ggg§g888g89e8gęĘ;
+INCOMING
+NEW YORK NY
+NEW YORK NY
+- Continued
+Qnty
+Used Rate Description
+1 MIN
+UNLIMITED N/WKND MIN
+1 MIN
+UNLIMITED N/WKND MIN
+1EVT
+MESSAGE RETRIEVA
+1 MIN
+UNLIMITED NAWKND MIN
+1EVT
+MESSAGE RETRIEVAL
+6 MIN
+1 MIN
+INLIMITED NWIND M
+1EVT
+MESSAGE RETRIEVAL
+INCOMING
+NEW YORK NY
+INCOMING
+NEW YORK NY
+NEW YORK NY
+WPALMBEACH FL
+INCOMING
+INCOMING
+INCOMING
+BROOKIY
+YN NY
+BROO
+KLYN
+NY
+KEN YORI
+IRK
+NY
+INCOMING
+NEW
+YORK NY
+NY
+NW
+N
+NY
+IRK NY
+NEW YORK NY
+INCOMING
+NY
+ZONE
+NWYR
+1 NY
+ZN01 NY
+NEW
+YORK N'
+NY ZONE 1 NY
+TWINCITIES MN
+INCOMING
+oll Free CL
+INCOMING
+INCOMING
+NEW
+ORK NY
+INCOMING
+NCOMING
+JEW YORK NY
+NEW YORK NY
+INCOMING
+INCO
+NY
+HS
+VIl
+NEW
+ORK NY
+NCO
+IN
+G
+ORK
+K NY
+INCOMING
+EMIN
+1EVT
+1 MIN
+IEVT
+1 MIN
+MIN
+1 MIN
+1
+2 MIN
+2 MIN
+1 MIN
+3 MIN
+10 MIN
+1 MIN
+10 MIN
+2 MN
+UNLIMITED WIND MIN
+MESSAGE RETRIEVAL
+NLIMIIED NVIKND M
+NLIMITED NWKND M
+UNLIMITED N/WKND MIN
+INCLU
+CLU
+LT
+INCLU
+INCLU
+UNLIM
+INCLU
+B8008:
+MI
+233г
+ELY
+ILIM
+000
+533
+55595
+
+Called
+Item Date Time
+446 10/18 06:38P
+447 10/18 06:39P
+448 10/18 06:40P
+449 10/18 06:40P
+450 10/18 09:17P
+451
+452
+10/18 10:44P
+10/18 10:45P
+453
+10/19 08:43A
+155 10/19 13:258
+
+10/19 12:52P
+458 10/19 12:54P
+459 10/19 12:55P
+460 10/19 12:57P
+162 1019 01:03Р
+10/19 01:03P
+INCOMING
+NEW YORK NY
+NEW YORK NY
+NEW YORK NY
+INCOMING
+NEW YORK Y
+NEW YORK Y
+NEW YORK NY
+INCOMING
+NEW YORK NY
+NEW YORK Y
+- Continued
+Qnty
+Used Rate Description
+1 MIN
+INCLUDED MINUTES
+1 MIN
+INCLUDED MINUTES
+-1L1
+IMIN
+CLUBEL
+B MINUTE
+UNLIMITED NWKND MIN
+1 MIN
+1 MIN
+UNLIMITED MIN
+SMIN
+INCLUDED MINUTES
+1 MIN
+1 MIN
+JCLUDED MINUT
+1 MIN
+1 MIN
+UDED MINUTES
+1 MIN
+INCLUDED MINUTES
+LEVT
+CLUDED MINUTE
+ALI WAITIN
+1 MIN
+INCLUDED MINUTES
+EMIN
+NLIM MOBL TO MOB
+FL
+497
+
+
+10
+88
+05:02A
+aaaaaaaaaaaaadaddadda
+
+
+
+3.64
+mobile UK
+YORK NY
+TIES MI
+4MIN
+1EVT
+1 MIN
+1 MIN
+UNLIM M
+EARLY
+EARLY
+TIm
+N/WI
+0.2B
+ID
+MIN
+NT DL
+INCLUDED MINUTES L
+CARLY AVENG
+EVENING NWKND
+EARLY EVENING N/WKND
+1.12
+E512000002620002
+
+
+2000297.000002133
+Item Date Time
+Called
+- Continued
+Qnty
+Used Rate Description
+1EVT
+CALL WAITING
+1 MIN
+EARLY EVENING NWKND
+507 10/20 08:04P
+0B 10/20 08:07P
+500 10/20 08:45P
+510 10/20 08:48P
+511 10/20 08:57P
+512 10/25 06:47P
+10/25 07
+09350
+10125
+07:45₽
+10 DE
+07-
+45P
+517
+10/25
+08:07P
+18/25
+18:19F
+08:30P
+520 10/25 08:38P
+522
+0/2
+08:50F
+09-БАР
+523 10/25 09:00P
+18/23 89:05P
+09:06P
+09:08P
+10:36P
+1/25
+529
+855
+10:54P
+10/26 06:50A
+530
+10/26 08:56A
+10/26
+09:03A
+1006
+09:04A
+10/26 09:05A
+534
+10/26
+09:06A
+535 10/26 09:07A
+536 10/26 09:10A
+10/26 09:13A
+
+88988E
+9ex89092230er
+888
+556 10/26 04:18P
+
+
+
+INCOMING
+NCOMING
+JEW YORK NY
+COSTA RICA
+NEWYORKZNI NY
+NEW YORK NY
+NEWYORKZN1 NY
+NEW YORK NY
+NEW ORNY
+INCOMING
+NEW MORNIN
+NEW
+YORK NY
+NCOMING
+NEW YORK NY
+mobile UK
+INCOMING
+WORTH
+FL
+ONBCH FL
+WPALMBEACH FU
+INCOMING
+INCOMING
+WPALMBEACH FL
+INCO
+NCOMING
+NCOMING
+FL
+YZNO1 NY
+NEW
+NEW
+NEW YORK NY
+TWINCITIES MN
+INCOMING
+mobile UK
+NWYRCYZNO1 NY
+COMING
+OMINE
+NEWYORKZNINY
+BROOKLYN NY
+ICOMING
+mobile UK
+6 MIN
+1 MIN
+IMIN
+1 MIN
+EMIN
+1 MIN
+SMIN
+1 MIN
+EMIN
+1 MIN
+5 MIN
+1 MIN
+1 MIN
+IMIN
+3MIN
+1 MIN
+1 MIN
+4 MIN
+LEVA
+2 MIN
+EVT
+1 MIN
+1 MIN
+EMIN
+1 MIN
+MIL
+EMIN
+1 MIN
+1 MIN
+1 MIN
+IMIN
+6MIN
+1 MIN
+EMIN
+2 MIN
+1 MIN
+MIN
+1M
+EARLY EVENING N/WKND
+EVENING N/WKND
+UNLIM MOBL TO MOBL
+VLIM MOBL IO MO
+LRIY EVENING NANKN
+EARLY EVENING N/WKND
+EARLY EVENING NAND
+EARLY EVENING N/WKND
+EARLY EVENING NAWNB
+0.28 ENCH
+BL
+0.28 ENLI
+1.62
+
+Item Date Time Called
+664 10/26 04:46P
+65 10/26 04:50P
+566 10/26 05:28P
+67 10/26 05:281
+68 10/26 05:321
+70 10/26 0
+571 10/26 05:39P
+572 10/26 05:52P
+575 10/26 06:20P.
+576 10/26 06:36P
+577 10/26 07:00P
+
+7:12P
+10/27
+SKa8
+2:22A
+588 10/27 06:57A
+580 1027 06-588
+590 10/27 08:19A
+591 10/27 08:25A
+592 10/27 08:27A
+593 10/27 08:30A
+594 10/27 08:45A
+7A
+INCOMING
+mobile UK
+INCOMING
+INCOMING
+NEW YORK NY
+NE ZEK NY
+mobile UK
+W PALMBEACH FL
+NEW YORK NY
+mobile UK
+mobile UK
+TWINCITIES MN
+INCOMING
+COMIN
+W PALMBEACH FL
+NWYRCYZN01 NY
+mobile UK
+NCOMING
+NWYRCY7N01 NY
+INCOMING
+mobile UK
+mobile UK
+BROOKLYN NY
+mobile UK
+INCOMING
+AUSTRIA
+NEW CANAAN CT
+mobile UK
+BROOKLYN NY
+BROOKLYN NY
+mobile UK
+NWYRCYZN01 NY
+NY ZONE 1 NY
+NCOMING
+NCOMING
+INCOMING
+NEW YORK NY
+INCOMING
+EWYORKZNIN
+COMING
+NY ZONE 1 NY
+K N
+INCOMING
+NCOMING
+NCOMIN
+NEW YORK NY
+- Continued
+Onty
+Used Rate Description
+1 MIN 0.28 ENH DISC INT DL
+3 MIN
+INCLUDED MINUTES
+IMIN
+CLUDED MINUTE
+0.28 ENH DISC INT D
+1 MIN
+INCLUDED MINUTES
+EMIN
+MOBL
+TO MÖBL
+1EVT
+MESSAGE RETRIEVAL
+2 MIN
+INCLUDED MINUTES
+TO MOBL
+EMIN
+0.28 ENCH DR MUTES
+DISC INT OL
+2 MIN
+INCLUDED MINUTES
+INCLUBED MINUTES
+2MIN
+EMIN
+1 MIN
+INCLUDED MINUTES
+NCLUDED MINUTES
+.28 ENH DISC INT DL
+EARLY EVENING N/WKND
+0.28 EAR YECENTNG NWKND
+4 MIN
+EARLY
+EVENING N/WKND
+RIT
+VENING NAN
+1 MIN
+EARLY EVENING N/WKND
+2 MIN
+UNLIMITED N/WKND MIN
+1 MIN
+UNLIMITED N/WKND MIN
+1 MIN
+0.28 ENH DISC INT DL
+MIN
+2 MIN
+UNLIMITED NIND MIN
+INI IMIT
+NAND MIN
+1 MIN
+UNLIMITED N/WKND MIN
+1 MIN
+IMIN
+).28 ENH DIS
+ENDS AND MIN
+1 MIN
+INCLUDED MINUTES
+. MIN
+0.28 ENH DISC INT DL
+1 MIN
+UNLIM MORI
+. TO MOBL
+L MIN
+IMIN
+0.28 ENH DISC INTOLES
+1 MIN
+INCLUDED MINUTES
+BMIN
+INCLUDED MINUTES
+0.08 ENH DISC INT
+3MIN
+DL
+INCLUDED MINUTES
+L MIN
+INCLUDED MINUTES
+[MIN
+0.28 ENH DISC INT
+1 MIN
+'DL
+UNLIM MOBL TO MOBL
+EMIN
+UNLIM MOBL
+. TO MOBL
+INCLUDED MINUTES
+MIl
+0.28 ENH DISC INT DL
+IMIT
+NCLUDED MINUTES
+1 MIN
+INCLUDED MINUTES
+16 MIN
+INCLUBED MINUTES
+6 MIN
+INCLUDED MINUTES
+LEIN
+GALIMMOBING
+TO MOBI
+2 MIN
+INCLUDED MINUTES
+1 MIL
+INUTE.
+NELUBEB MINUTE
+1 MIN
+INCLUDED MINUTES
+9 MIN
+IMI
+UNLIM OBLI TO MS BL
+UNLIM
+L MIN
+INCLUBEB MINUTES
+1 M
+1 M
+2555E
+UNLIM MOBL TO MOBL
+INELUBEB MINUTES
+UNLIM MOBL TO MOBL
+0.24
+
+
+Item Date Time
+Called
+616 10/27 02:10P
+617 10/27 02:11P
+18 1027 02:111
+519 10/27 02:13P
+620 10/27 02:14P
+21 10/27 02:26
+22 10 27 02:27
+623 10/27 02:27P
+24 10/22 02:29
+25 10/27 02:32
+626 10/27 02:33P
+¿/ 1U2 UZ.J
+28 10/27 03:33
+638 18/27 84:138
+631 10/27 05:14P
+833 1827 85 14P
+61
+24
+25
+10/
+• 401
+636
+1007
+05:49P
+627
+•20.
+638
+639
+2c.a1m
+640
+27
+647
+649
+650
+08:59P
+651 10/27 10:42P
+652 10/27 11:29P
+837 10027
+11:31
+10/28
+11:46
+1 0B:51A
+656
+657
+1028
+09:20A
+09:36A
+859102301.400
+660
+661
+662
+664
+666
+2F
+667
+668
+669 10/28 04:16P
+670 10/28 04:17P
+671 10/28 04:17P
+672
+10
+04:22P
+98
+383
+NEW YORK NY
+NEW YORK NY
+BROOKLYN NY
+NEW YORK NY
+NEW YORK NY
+NCO MING
+INCOMING
+INCOMING
+IEW YORK NI
+ZN01 NY
+NY ZONE 1 NY
+NY ZONE 1 NY
+NEW YORK Y
+NEW YORK NY
+NEW YORK Y
+NY
+INC
+NWYRCYZN01 NY
+NEW YORK NY
+INCOMING
+NEW
+'ORK NY
+INC
+ING
+NEW
+YORK NY
+NY ZONE 1 NY
+O MING
+ORK NY
+E
+ORKZNI NY
+- Continued
+Qnty
+Used Rate Description
+1 MIN
+INCLUDED MINUTES
+1 MIN
+INCLUDED MINUTES
+NLIM MOBL TO MOB
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+1EVT
+CLUDED MINUTE
+INCLUDED MINUTES
+CLUDED MINUTE
+ILIM MOR
+TO MOBL
+CALL WAITING
+CALL AT INUTES
+1 MIN
+LUDED MINUT.
+1 MIN
+HIDEO MINUT
+5 MIN
+INCLUDED MINUTES
+2 MIN
+. LUDED MINUT
+5 MIN
+CLUDED MINUT
+1EVT 1.50 411 INFO
+1 MIN
+LIM MOBL TO MO
+1 MIN
+LIV MORI TO MO
+1 MIN
+DED
+4MIN
+1 MIN
+BEB
+2
+MIN
+EMIN
+1 MIN
+1 MIN
+12 MIN
+1 MIN
+1 MIN
+Анач
+1 MIN
+252
+NE
+NY
+NWYR
+101
+NY
+NEW YORK NY
+INCOMING
+NY ZONE 1 NY
+NEWY
+ORKZNI NY
+INCOMING
+INCOMING
+INCOMING
+NEW
+YORK NY
+QUEENS NY
+NEW YORK NY
+WPALMBEACH FL
+NWYRCY
+NWYRGYZNO1 NY
+NEW YORK NY
+NEW
+>>
+NEW YORK NY
+INCOMING
+INCOMING
+NEW YORK NY
+INCOMING
+INCO
+MING
+INCOMING
+. MIN
+4 MIN
+1 MIN
+2 MIN
+2 MIN
+16 MIN
+3MIN
+1 MIN
+1 MIN
+2 MIN
+1 MIN
+2 MIN
+1 MIN
+1 MIN
+UNLIM
+NCLUD
+1MIN
+UNLIM
+CALL
+INCLU
+IN
+INCLU
+00000
+
+Item Date Time
+Called
+676 10/28 05:04P
+677 10/28 07:07P
+28 1028 02:081
+79 10/28 07:10P
+680 10/28 07:25P
+
+08:11P
+683 10/28 08:15P
+684 10/28 08:23P
+10/28 08:49P
+10/28 08:55P
+687 10/28 09:43P
+• 008 055
+690 10/28 10:37P
+91 10/28 10:38
+92 10/28 10:438
+10
+/28
+
+10/29
+
+TWINCITIES MN
+QUEENS NY
+INCOMING
+zz
+WYRCTENOLN
+• ZONE 1 N
+mobile AUT
+INCOMING
+NEW YORK NY
+INCOMING
+NEW YORK NY
+INCOMING
+INCOMING
+NEWYORKZNI NY
+INCOMING
+- Continued
+Qnty
+Used Rate Description
+1 MIN
+INCLUDED MINUTES
+2 MIN
+EARLY EVENING N/WKND
+-111
+ARLY EVENING NAWKNI
+MI
+ARLY EVENING NAWKNI
+1 MIN
+EARLY EVENING N/WKND
+1 MIN
+1 MIN
+EARLY EVENING NAWKNE
+NWKNO
+1 MIN
+EARLY EVENING N/WKND
+1 MIN
+1 MIN
+30 EARLY EGENING NAWKN
+1 MIN
+4 MIN
+IWKN
+2 MIN
+UNLIMITED N/WKND MIN
+4MIN
+3 MIN
+1 MIN
+1 MIN
+6 MIN
+UNLIMITED N/WKND MIN
+UNLIMITED NINB MIN
+MAN
+3MIN
+1 MIN
+EVT
+IMIN
+1 MIN
+MIN
+15 MIN
+2 MIN
+1 MIN
+16 MIN
+2 MIN
+1 MIN
+MI
+MI
+3MIN
+0.3
+0.3
+N/WKND MIN
+ДОДАТИИ
+0.30
+0.60
+0.60
+
+
+58
+•Sessesse
+28
+INCOMING
+COMIN
+FONT
+NEWYORKZNI NY
+NCOMING
+NCOMING
+3MIN
+17 MIN
+2 MIN
+2 MIN
+1 MIN
+1 MIN
+6 MIN
+2 MIN
+4MIN
+. MIN
+IMIN
+SMIN
+IMIN
+EMIN
+EMIN
+IMIN
+1 MIN
+1 MIN
+11 MIN
+UN
+BEB
+ALIM
+CALL WANTES
+INCLUDED MINUTES
+ICLUDED MINUTE
+NLIM MORI TO MOR
+UNLIM MOBL TO MOBL
+EARLY EVENING NW KNB
+EARLY EVENING N/WKND
+
+
+Called
+Item Date Time
+734 10/29 07:12P
+735 10/29 07:13P
+739
+10/29 07:27P
+10/20 07:28P
+738 10/29 07:28P
+10/29 07:40P
+10/29
+07:41P
+10/29 07:53P
+44
+10/29 10:36P
+10/30 12:50A
+746 10/30 12:51A
+1838฿
+1352A
+749 10/30 01:07A
+351
+0/30 03:14
+020 02-15
+10,
+30
+3U
+03:23A
+L0/30 04:11A
+0/30 08:017
+130
+10,
+130
+09:
+:18A
+10/30
+09:
+:19A
+09:20A
+18/38
+09:32A
+10/30 09:23A
+10,
+10,
+09:51A
+09:56A
+10/30
+09:58A
+18/38
+10,
+13
+10/30
+10/30
+12:34P
+12:38P
+102
+12-39P
+10/30 12:42P
+778
+10/30
+12:47P
+779
+10/30
+17-47P
+W PALMBEACH FL
+INCOMING
+NEW YORK NY
+NY ZONE 1 NY
+V YORK NY
+NCOMING
+- Continued
+Qnty
+Used Rate Description
+1 MIN
+EARLY EVENING N/WKND
+1 MIN
+EARLY EVENING N/WKND
+EARLY EVENING
+N/WKND
+ARLY EVENING NKND
+4 MIN
+1 MIN
+2 MIN
+2 MIN
+2 MIN
+1 MIN
+1 MIN
+1 MIN
+EARLY EVENING N/WKND
+EARLY EVENING NAWKNB
+ING
+EARLY EVENING NWKND
+IVAN
+ARLY EVENING WEN
+NEW YORK NY
+MPALMBEACH FU
+NEWYORKZN1 NY
+TWINCITIES MN
+NCOMING
+INCOMING
+NCOMING
+NCOMING
+INCOMING
+INCOMING
+COMING
+COMIN
+ALR
+H FL
+WPALMB
+H FI
+NPALMORTH
+FL
+FL
+PALM BEACH FL
+COMING
+JAI MA
+FACH FI
+WPALMBEACH FL
+MING
+0
+RK NY
+ORK7N1 MY
+NCOMING
+NEW YORK NY
+NEW YORK NY
+INCOMING
+INCOMING
+PALMBEACH FL
+INCOMING
+NEWYORKZNI NY
+INCOMING
+3 MIN
+. MIN
+MIN
+8 MIN
+3MIN
+8 MIN
+1 MIN
+L MIN
+1 MIN
+1 MIN
+MIN
+2 MIN
+IMIN
+2MIN
+2 MIN
+L MIN
+1 MIN
+EMIN
+1 MIN
+4 MIN
+3MIN
+2 MIN
+2 MIN
+2 MIN
+1 MIN
+1 MIN
+3 MIN
+VKND MI
+UNLIMITED N/KND MIN
+UNLIMITED
+22
+UNLIMITED NWKND
+VLIMITED NAKN
+IN
+!.!!!!!!!!!!!
+2:
+PREPPE
+2000297.000002134
+780 10/30 12:49P
+781
+10/30 12:50P
+10/30 12:50P
+10/30 12:51P
+10/38
+62130
+10/30
+01:35P
+10/30 02:15P
+183002-158
+10/30
+03:01P
+10/30 03-038
+10/30 03:04P
+10/30 03:22P
+10/30 03:29P
+NEW YORK NY
+INCOMING
+WPALMBEACH FL
+NEWYORKZNI NY
+NEWYORKZNI NY
+JEW YORK NY
+BOYNTONBCH FL
+NWYRCYZNO1 NY
+NCOMING
+NEW YORK NY
+NEW YORK NY
+PALMBEACH FL
+NEW YORK NY
+M PALMBEACH FI
+INCOMING
+BOYNTONBCH FL
+1EV
+IMIN
+1 MIN
+LEVT
+IMIN
+1 MIN
+8 MIN
+I MIN
+1 MIN
+2 MIN
+1MIN
+1 MIN
+1 MIN
+2 MIN
+EMIN
+3MIN
+1 MIN
+
+2z222222zz
+UN
+UNE
+UNLI
+UNLI
+EZE
+
+Item Date Time Called
+797 10/30 03:37P
+798 10/30 04:52P
+300 10/30 05 15P
+801 10/30 05:18P
+802 10/30 05:18P
+803
+10/30 05:20P
+804 10/30 05:23P
+0/30 05:341
+06 10/30 05:38
+B07 10/30 05:40P
+808 10/30 05:53P
+INCOMING
+NEWYORKZNI NY
+TWINCITIES MN
+NEW YORK NY
+WPALMBEACH FL
+LAKE
+WORTH
+FL
+WPALMBEACH FL
+INCOMING
+PALMBEACH F
+COMIN
+- Continued
+Onty
+Used
+Rate Description
+3 MIN
+UNLIMITED N/WKND MIN
+5 MIN
+UNLIMITED N/WKND MIN
+1 MIN
+EMIN
+1 MIN
+UNLIMITED N/KND MIN
+UNLIMITE NAW KND MIN
+UNLIMITED NKND MIN
+MIN
+1 MIN
+CALITED NAVEND MIN
+UNLIMITED N/WKND MIN
+809 10/30 05:54P
+810 10/30 06:09P
+811 10/30 06:15P
+NEW YORK NY
+NEW YORK NY
+mobile UK
+SHARR
+3685.
+88888
+99999
+88
+1888
+888
+9000
+mona debea
+
+RK NY
+FL
+Ex
+INCOMIN
+1 MIN
+1 MIN
+1 MIN
+MIN
+EMIN
+mm-.
+MIN
+: MIN
+NAN
+S2
+2 MIN
+MIN
+. MIN
+1 MIN
+2 MIN
+: MIN
+TIMITED NAUKND MI
+UNLIMITED N/WKND MIN
+02 NOISE BAND MIN
+UNLIMITED N/WKND MIN
+IN
+411
+ENH
+4111
+UNLIMIT
+Ш!!!
+
+UNLIMI
+UNLIMIT
+UN
+UNLIMIT
+UN
+IMIT
+UNEMIT
+SALIM
+N
+N
+KND MIN
+WEND MIN
+D
+00
+333
+KND
+ID
+KND
+MIN
+MIN
+MIN
+KNBI
+MIN
+MIN
+KN
+D
+22
+0000
+MIN
+MIN
+KND
+MIN
+150
+0.56
+988888988AESEECE
+WPALMBEACH FL
+NY ZONE 1 NY
+RALEIGH NC
+INCOMING
+YORK NY
+NCOMIN
+HANAA
+1$54H010
+IN
+4 MIN
+4 MIN
+MIN
+D
+UNLIMITED
+UNLIMITE
+UNLI
+UNLI
+UNLIM
+IMI
+0000
+Ш!!
+00000
+00
+22
+!!!
+MIN
+MIN
+MIN
+D
+MIN
+MIN
+NANI
+KNBI
+KND MIN
+KN
+ID
+MIN
+
+
+Item Date Time
+Called
+856 10/31 11:54A
+857 10/31 01:01P
+358 10/31 01:02P
+59 10/31 01:03P
+860 10/31 01:07P
+86z 10/31
+862
+11:09
+)1:77F
+863 10/31 01:29P
+864
+865
+865 18/23
+867
+04:36P
+04:36P
+868 10/31 04:38P
+878 10/31
+05230
+871 10/31 07:03P
+372 10/31
+07:33P
+373 10/31 07:44P
+874 10/31 07:59P
+878 18/81 08:16P
+10/31
+08:36P
+878
+10/31
+09:59P
+879
+11/01
+04:15P
+880
+11/01
+881
+882
+11/01
+883
+11/01
+884
+10.
+06:39P
+11/01
+885
+11/01
+07:03P
+886
+11/01
+887
+888
+11/01
+889
+/01
+09:28P
+: 38P
+890
+893
+11
+896
+897
+898
+899
+11/02
+02:43P
+1/02
+02:45P
+02:45P
+11/02
+03:12F
+904
+11/02
+11/02
+03:17Г
+03:18P
+:45P
+906
+907
+11/02
+06:46Р
+910
+11/02
+ОБ
+пир
+SP
+- Continued
+Qnty
+CHTAMSTTHS VI
+NEW YORK NY
+EW YORK N
+EW YORK N
+QUEENS NY
+NEW YORK NY
+NCOMING
+INCOMING
+BEENS N
+)RK MI
+NCOMING
+NPALMBEACH FL
+NEW YORK NY
+Used
+Rate Description
+1 MIN
+1 MIN
+N/W
+KND
+N/W
+MIN
+KND
+MIN
+1 MIN
+N/W
+KND
+MIN
+SMIN
+2MIN
+N/W
+KND
+MIN
+1 MIN
+1 MIN
+ED NAWKND MIN
+MIN
+1 MIN
+ED NWKND MIN
+3MIN
+UNIVIANU MII
+1 MIN
+TED NAWKND MIN
+1 MIN
+N/W
+KND
+2 MIN
+ED NAWKND
+MIN
+MIN
+1 MIN
+ED N/WKND
+MIN
+2 MIN
+N/W
+KND
+MIN
+2 MIN
+N/W
+KND
+MIN
+NY ZONE 1 NY
+1 MIN
+N/W
+KND
+HTAMSTTHS VI
+2 MIN
+KND
+MIN
+YORK NY
+INCOMING
+13 MIN
+3MIN
+VAN YORKON DE
+7 MIN
+YORK N'
+9 MIN
+TWINC
+IES MN
+OMING
+INCOMING
+20NE
+: 1 NY
+MING
+2Z
+TIm
+22
+TWINC
+MN
+NEW
+NEW
+22
+00000
+xxX
+23333
+TWINCITIES MN
+NCOMING
+INCOMING
+NEW YO
+NY
+NEW YO
+RIK NY
+NEW YORK NY
+NEW YORK NY
+NEW
+NY
+QUEENS NY
+LEW
+YORK NY
+INCOMING
+NEW YORK NY
+NWYRCYZNO1 NY
+NCOMING
+NEW
+YORK NY
+NEW YORK NY
+NEW YORK NY
+INCOMING
+YORK NY
+NEWYORKZNI NY
+NEW
+MN
+NEV
+G
+INCOMING
+1 MIN
+1 MIN
+1 MIN
+5MIN
+11 MIN
+2 MIN
+10 MIN
+AMIN
+2 MIN
+2 MIN
+MIN
+MIN
+IN
+
+Called
+Item Date Time
+922 11/02 08:43P
+923 11/02 08:48P
+124 11/02 08:49P
+025 11/02 08:52P
+926 11/02 08:56P
+927 11/02 08:59P
+928 11/02 09:32P
+929 11/02 10:09P
+TOTAL VOICE USAGE FOR
+ROAMER USAGE FOR
+Item Date Time
+Called
+10/22 0821
+NCOMING
+WPALMBEACH FL
+AKE WORTH F
+ALM BEACH -
+INCOMING
+TW INCITIES MN
+WPALMBEACH FL
+NEW YORK NY
+- Continued
+Qnty
+Used Rate Description
+1MIN
+EARLY EVENING N/WKND
+1 MIN
+EARLY EVENING N/WKND
+. MIN
+2 MIN
+3MIN
+1 MIN
+1 MIN
+1 MIN
+EARLY EVENING N/KND
+EARLY EVENING NAWKND
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND MIN
+WHILE IN FRANCE .-.
+Onty Used Description
+NY
+MING
+PPPI
+CO
+UNT
+INT'L
+RO
+AM
+23.94
+0.99
+›000
+223
+322
+NEW
+NY
+SET 200000: 262000Z
+
+OONOOOHOWOGODODOH
+=CC
+
+
+
+ROAMER USAGE FOR
+Item Date Time Called
+51 10/25 09:10P
+52 10/25 09:11P
+TOTAL ROAMER USAGE FOR
+ROAMER USAGE FOR
+Item Date Time Called
+1 10/21 10:10A
+2 10/21 10:22A
+10/21 10:22A
+10/21
+10:23
+10/21
+0:23
+mm
+Onty Used
+INCOMING
+1 MIN
+INCOMING
+1 MIN
+WHILE IN FRANCE -
+WHILE IN FRANCE --. - Cont.
+Description
+DISCOUNT INT'L ROAM
+DISCOUNT INT'L ROAM
+INCOMING
+INCOMING
+NEW YORK NY
+NCOMING
+NEW YORK NY
+NCOMING
+JEW YORK NY
+g9999999B9999
+=
+WHILE IN FRANCE ---
+Onty Used
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+. MIN
+1 MIN
+Description
+DISCOUNT INT'L ROAM
+DISCOUNT INT'L ROAM
+DISCOUNT INT'L ROAM
+DISCOUNT INT'L
+ROAM
+DISCOUNT INT'L
+ROAM
+ISCOUNT INT'L ROAM
+ISCOUN
+'L ROAM
+INT'L ROAM
+ROAM
+INT
+ROAM
+NY
+FEREE
+
+2000297.000002135
+USAGE
+: FOR
+IN
+FRANCE -
+0.99
+0.99
+77.22
+0.99
+0.99
+0.99
+0.99
+
+DATA USAGE FOR
+Item Date
+1 11/02
+TOTAL DATA USAGE FOR
+Onty Used
+480 KB
+Charge Description
+NCLUDED IN PLAN ME
+TEXT/MULTIMEDIA MSGS FOR
+Item Date
+Time
+Sent To/Rovd From
+1 10/04
+07:30P
+2 10/05
+06:13A
+3 10/11
+04:07P
+$ 18/13
+11:26P
+7 10/14
+918/18
+11:55P
+2:441
+0:071
+10 10/18
+10:13P
+12 10/18
+U:18
+0-10|
+Charge Description
+100 INCL. MSGS SENT
+100 INCL. MSGS SENT
+INTE TEXT MES
+INTE TEXT MSG
+INTL TEXT MSG
+100 INEL. MEGS SENT
+100 INCL. MSGS SENT
+
+0 INCL. MSGS SE
+
+0.00
+8.33
+0.25
+TOTAL
+- TEXT/MULTIMEDIA MSG USAGE FOR
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/0f69249cfe851e5f516c53e415dc6d1ea99e50798bc3a0cfb30fdedef20b5dc6.receipt.json b/vision-fixhub/ds9-unparsed-06/0f69249cfe851e5f516c53e415dc6d1ea99e50798bc3a0cfb30fdedef20b5dc6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1f71af757e094b10e168ccd7cc1cccf474164a04
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0f69249cfe851e5f516c53e415dc6d1ea99e50798bc3a0cfb30fdedef20b5dc6.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -3425,
+  "dataset": "marble-joined",
+  "doc_id": "0f69249cfe851e5f516c53e415dc6d1ea99e50798bc3a0cfb30fdedef20b5dc6",
+  "engine": "marble-apple-vision",
+  "event_count": 60,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "21479e897cc50b68ff612630a9dce6f9c843701958e3542f4db5442b79a864f7",
+  "output_sha256": "20aa1b69635076c79100299a3061fc366b6a0a14413acca6b871ee0d1e7173f2",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0f969028e77d2178cffa29c2c0b087e703a30f27380bae49d83a1db94663bd28.md b/vision-fixhub/ds9-unparsed-06/0f969028e77d2178cffa29c2c0b087e703a30f27380bae49d83a1db94663bd28.md
new file mode 100644
index 0000000000000000000000000000000000000000..c9b80098cd74f32efee7abd7922bbd966e7105f9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0f969028e77d2178cffa29c2c0b087e703a30f27380bae49d83a1db94663bd28.md
@@ -0,0 +1,10 @@
+From:
+To:
+Subject: Read: Memo regarding Conflict in Epstein Investigation
+Date: Tue, 26 Jul 2011 21:12:07 +0000
+Importance: Normal
+Your message
+To:
+Subject: Memo regarding Conflict in Epstein Investigation
+Sent: Tuesday, July 26, 2011 5:03:18 PM (UTC-05:00) Eastern Time (US & Canada)
+was read on Tuesday, July 26, 2011 5:11:08 PM (UTC-05:00) Eastern Time (US & Canada).
diff --git a/vision-fixhub/ds9-unparsed-06/0f969028e77d2178cffa29c2c0b087e703a30f27380bae49d83a1db94663bd28.receipt.json b/vision-fixhub/ds9-unparsed-06/0f969028e77d2178cffa29c2c0b087e703a30f27380bae49d83a1db94663bd28.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3944e24fff15e9e70f71f1a6bba1a28738379dc3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0f969028e77d2178cffa29c2c0b087e703a30f27380bae49d83a1db94663bd28.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "0f969028e77d2178cffa29c2c0b087e703a30f27380bae49d83a1db94663bd28",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "a1f3634fe1178c2616eeae3f1320013f1fab74b76dc8304e024d4cb8ee6f1728",
+  "output_sha256": "7d0847de5af0708d2a21b8ceff918abeaf65291f71d2a49e3e3ca10c99b24b31",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0fe38ac9ccb8d2b380cd6973fd15b3c0a5a1bbda168ab608f873ae910d2a01eb.md b/vision-fixhub/ds9-unparsed-06/0fe38ac9ccb8d2b380cd6973fd15b3c0a5a1bbda168ab608f873ae910d2a01eb.md
new file mode 100644
index 0000000000000000000000000000000000000000..728259cb0ce5cc56acc89ed7c55a822b96a3decd
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0fe38ac9ccb8d2b380cd6973fd15b3c0a5a1bbda168ab608f873ae910d2a01eb.md
@@ -0,0 +1,46 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80893-KAM Doe |. Epstein Order
+Date: Tue, 20 Jul 2010 17:56:40 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. Distriet Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 7/20/2010 at 1:56 PM EDT and filed on 7/20/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 209
+Doe | Epstein
+9:08-cv-80893-KAM
+Docket Text:
+ORDER ADOPTING AND ENTERING JOINT STIPULATION re [207] Stipulation filed by Jeffrey
+Epstein. Signed by Judge Kenneth A. Marra on 7/20/2010. (ir)
+9:08-cv-80893-KAM Notice has been electronically mailed to:
+Ann Marie C. Villafana
+ann.marie.c.villafana@usdoj.gov, shawn.ball@usdoj.gov
+Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com
+Jack Alan Goldberger jagesq@bellsouth.net, nalanis@agwpa.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+Michael James Pike MPike@bclclaw.com, bobbie@bclclaw.com, jcadwell@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Robert Deweese Critton, Jr rcrit@bclclaw.com, bobbie@bclclaw.com
+9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+The following documents) are associated with this transaction:
+
+
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP dcecfStamp_ID=1105629215 [Date=7/20/2010] [FileNumber=7805241-0
+][71b2dcd7c0b28b3cb8ff8dd1ec08e55fde15f36ad1bfa0b7f6b05aeb6fdOaea0ed8
+166f64cf31 dafdb83aa1f1d562ddf6e36debb02cf4a714888b0546c836294]]
diff --git a/vision-fixhub/ds9-unparsed-06/0fe38ac9ccb8d2b380cd6973fd15b3c0a5a1bbda168ab608f873ae910d2a01eb.receipt.json b/vision-fixhub/ds9-unparsed-06/0fe38ac9ccb8d2b380cd6973fd15b3c0a5a1bbda168ab608f873ae910d2a01eb.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..8ca4e07d9abd82f66430b98756cd4eda6d081302
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0fe38ac9ccb8d2b380cd6973fd15b3c0a5a1bbda168ab608f873ae910d2a01eb.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "0fe38ac9ccb8d2b380cd6973fd15b3c0a5a1bbda168ab608f873ae910d2a01eb",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "1e37ab3776b73d04cd81311c409ad61788e1d5bedebfa8276e4391ffe9b70cbe",
+  "output_sha256": "59ad92e977a317de6292fd23ca429250b5ab09269fe6545f1e7a5cf75ecbdb3f",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/0fef1844f1eede1226ea081f341d338af4b69a4fc82dfeefc22e9e31be445be7.md b/vision-fixhub/ds9-unparsed-06/0fef1844f1eede1226ea081f341d338af4b69a4fc82dfeefc22e9e31be445be7.md
new file mode 100644
index 0000000000000000000000000000000000000000..b2ca0664aa57934e5de822cee30ac39dc4b87e9c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0fef1844f1eede1226ea081f341d338af4b69a4fc82dfeefc22e9e31be445be7.md
@@ -0,0 +1,58 @@
+From: "Gerald Lefcourt".
+To:
+| (USAFLS)" <
+Ce: "Lilly Ann Sanchez" <
+Subject: RE: Jeffrey Epstein
+Date: Wed, 18 Jul 2007 21:18:57 +0000
+Importance: Normal
+Attachments: 2007-071
+>, "Roy BLACK"
+please consider this letter in response to the subpoena to NES.
+Gerald B. Lefcourt
+Gerald B. Lefcourt, P.C.
+-----Original Message-----
+From:
+(USAFLS) [mailto:_
+Sent: Wednesday, July 04, 2007 4:07 PM
+To: Lilly Ann Sanchez
+Ce: Gerald Lefcourt
+Subject: RE: Jeffrey Epstein
+Dear
+and
+I: Thank you for your e-mail and your message. This e-mail was supposed to have gone out
+yesterday while I was in trial. I have no objection to the two-week extension with respect to NES, New York
+Strategy Group, and Epstein Virgin Islands Foundation.
+With respect to the subpoena to the investigator, I would like to get the computer equipment as soon as possible.
+If you prefer to simply turn over the equipment without anyone appearing before the grand jury that is fine. If w
+proceed that way, we can defer litigating the issue of the applicability of the attorney-client and/or work produc
+privilege to information related to how and why the equipment was removed. I will be in trial this week, so
+please contact
+at the FBI directly at
+I look forward to your July 11th submission. If you would like to discuss the possibility of a federal resolution of
+the fies case that could nud wil ge bay to yoy star rest has ended for the vey message on my voicemail
+Thank you.
+Assistant U.S. Attorney
+-----Original Message-----
+From:
+_Ann Sanchez [mailto:
+Sent: Friday, June 29, 2007 4:05 PM
+
+
+To:
+Cc: Gerald Lefcourt
+Subject: Jeffrey Epstein
+(USAFLS)
+As i stated in my earlier voicemail today, we were calling to request a two-week extension on the return date of
+the following outstanding subpoenas:
+1. NES
+2. NY Strategy
+3. Investigator
+4. Certification for St. Thomas entity
+We will be providing an additional submission to the Office by July 11 and hope to be able to reach a state-based
+resolution shortly thereafter.
+as your voicemail to me indicted, you would not oppose a one to two-week extension. accordingly, we would
+like to extend the return date two weeks-- to July 24.
+regards
+Lilly Ann Sanchez, Esq.
+FOWLER WHITE BURNETT P.A.
+Espirito Santo Plaza, 14th Floor
diff --git a/vision-fixhub/ds9-unparsed-06/0fef1844f1eede1226ea081f341d338af4b69a4fc82dfeefc22e9e31be445be7.receipt.json b/vision-fixhub/ds9-unparsed-06/0fef1844f1eede1226ea081f341d338af4b69a4fc82dfeefc22e9e31be445be7.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..968a5d72e9903ceef5674b9da8c06e3a1a223a47
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/0fef1844f1eede1226ea081f341d338af4b69a4fc82dfeefc22e9e31be445be7.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "0fef1844f1eede1226ea081f341d338af4b69a4fc82dfeefc22e9e31be445be7",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "19249ecda2a9da6f671a0d4333481a2fe30896f9960e93566c9a1e613cdab08a",
+  "output_sha256": "530b525317ee1bcdde990e27b8bc6e03bd1717e960976dd0c708b14ee736a6af",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/10a6580497fbf65ff81c589af2c4cf0d41977478e5b38955fd140f298b7dd73c.md b/vision-fixhub/ds9-unparsed-06/10a6580497fbf65ff81c589af2c4cf0d41977478e5b38955fd140f298b7dd73c.md
new file mode 100644
index 0000000000000000000000000000000000000000..cd3a3cea31ab19c920bc7375221d41b2035b6589
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/10a6580497fbf65ff81c589af2c4cf0d41977478e5b38955fd140f298b7dd73c.md
@@ -0,0 +1,96 @@
+Document 64
+Entered on FLSD Docket 04/24/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON
+C.M.A.,
+Plaintiff,
+VS.
+JEEEREY EPSTEIN and
+Defendants.
+PLAINTIFF'S MEMORANDUM IN OPPOSITION TO DEFENDANT, JEFFREY
+EPSTEIN'S MOTION TO STAY AND OR CONTINUE ACTION FOR TIME CERTAIN
+BASED ON PARALLEL CIVIL AND CRIMINAL PROCEEDINGS WITH
+INCORPORATED MEMORANDUM OF LAW
+Plaintiff, C.M.A., by and through undersigned consel, files this Memorandum in
+Opposition to Defendant, Jeffrey Epstein's Motion to Stay And Or Continue Action For
+Time Certain Based On Parallel Civil And Criminal Proceedings With Incorporated
+Memorandum of Law (D.E. 51), and states:
+Defendant, Jeffrey Epstein, seeks to have this action stayed until late 2010.
+Epstein's Motion to Stay filed in the instant case is identical to the ones he filed in Jane
+Doe v. Epstein, Case. No. 08-CV-90893, Jane Doe No. 2 v. Epstein, Case No. 08-CV-
+80119, Jane Doe No. 3 v. Epstein, Case No. 08-CV-80232, Jane Doe No. 4 v. Epstein,
+Case No. 08-CV-80380, Jane Doe No. 5 v. Epstein, Case No. 08-CV-80381, Jane Doe
+No. 6 v. Epstein, Case No. 08-CV-90994, and Jane Doe No. 7 v. Epstein, Case No. 08-
+80993, which are all currently pending before this Court. Consel for Jane Doe No.1
+and Jane Does No. 2-7 have both filed Memorandums in Opposition to Epstein's
+
+
+Document 64 Entered on FLSD Docket 04/24/2009 Page 2 of 4
+Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
+Plaintiff's Memorandum in Opposition to Defendant Jeffrey Epstein's Motion to Stay And Or Continue
+Action For Time Certain Based On Parallel Civil And Criminal Proceedings With Incorporated
+Memorandum of Law
+
+Motions for Stay in their respective cases. Rather than unnecessarily recite and
+duplicate their well-reasoned arguments in opposition to Epstein's Motions for Stay,
+C.M.A. incorporates by reference the arguments raised in Plaintiff's Response In
+Opposition to Defendant's Motion to Stay Complaint in Jane Doe No.1 v. Epstein (Case
+No. 08-CV-80893, D.E. 31)(Attached hereto as Exhibit "1") and Plaintiff's Memorandum
+in Opposition to Motion to Stay and or Continue Action in Jane Doe No. 2 v. Epstein
+(Case No. 08-CV-80119, D.E. 82) (Attached hereto as Exhibit "2") in her Memorandum
+in Opposition to Epstein's Motion For Stay as if they had fully been set forth herein.
+WHEREFORE, in light of the foregoing, the Plaintiff respectfully requests this
+Court enter an order denying Defendant, Jeffrey Epstein's Motion to Stay And Or
+Continue Action For Time Certain Based On Parallel Civil And Criminal Proceedings
+With Incorporated Memorandum of Law.
+Respectfully submitted,
+Is/Jack P. Hill
+JACK SCAROLA
+Florida Bar No. 169440
+JACK P. HILL
+Florida Bar No.: 0547808
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+West Palm Beach, Florida 33409
+Attorneys for Plaintiff
+
+
+Document 64 Entered on FLSD Docket 04/24/2009 Page 3 of 4
+Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
+Plaintiff's Memorandum in Opposition to Defendant Jeffrey Epstein's Motion to Stay And Or Continue
+Action For Time Certain Based On Parallel Civil And Criminal Proceedings With Incorporated
+
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on April 24, 2009, I electronically filed the foregoing
+document with the Clerk of Court using CM/ECF. I also certify that the foregoing
+document is being served this day on all counsel of record identified above via
+transmission of Notices of Electronic Filing generated by CM/ECF.
+Is/Jack P. Hill
+JACK SCAROLA
+Florida Bar No. 169440
+JACK P. HILL
+Florida Bar No.: 0547808
+Searcv Dennev Scarala Barnhart & Shipley, P.A.
+West Palm Beach, Florida 33409
+Attorneys for Plaintiff
+
+
+Document 64 Entered on FLSD Docket 04/24/2009 Page 4 of 4
+Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
+Plaintiff's Memorandum in Opposition to Defendant Jeffrey Epstein's Motion to Stay And Or Continue
+Action For Time Certain Based On Parallel Civil And Criminal Proceedings With Incorporated
+Memorandum of Law
+
+COUNSEL LIST
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+West Palm Beach, FL 33401
+Bruce E. Reinhart, Esquire
+Bruce E Reinhart DA
+West Palm Beach. EL 33401
+Robert Critton, Esquire
+Burman Critton Luttier & Coleman LLP
+West Palm Beach. FL. 33414
+Richard H. Willis, Esquire
+Richard H. Willits, P.A.
+Lake Worth, FL 33461
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/10a6580497fbf65ff81c589af2c4cf0d41977478e5b38955fd140f298b7dd73c.receipt.json b/vision-fixhub/ds9-unparsed-06/10a6580497fbf65ff81c589af2c4cf0d41977478e5b38955fd140f298b7dd73c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..83f439cb8852ae594671f16fafa73ccb861a127b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/10a6580497fbf65ff81c589af2c4cf0d41977478e5b38955fd140f298b7dd73c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -255,
+  "dataset": "marble-joined",
+  "doc_id": "10a6580497fbf65ff81c589af2c4cf0d41977478e5b38955fd140f298b7dd73c",
+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "eafeb0a2e3b75ad20081912cba60b86be3fde99f66c473a5379f5563183af164",
+  "output_sha256": "bde468b6157d2ab6d1dd9839e4eb19601f7e63654f5ebb9421d5f2d05e906515",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/111162fbae62a3ce617e385d414b7b31ef7857563628acb1b007556e7c7bbef1.md b/vision-fixhub/ds9-unparsed-06/111162fbae62a3ce617e385d414b7b31ef7857563628acb1b007556e7c7bbef1.md
new file mode 100644
index 0000000000000000000000000000000000000000..29da3ee25101f55b838df705fc6d7f0a25fd74de
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/111162fbae62a3ce617e385d414b7b31ef7857563628acb1b007556e7c7bbef1.md
@@ -0,0 +1,18 @@
+From:
+To:
+Subject: Re: Epstein Mtg
+Date: Mon, 25 Jan 2010 18:03:38 +0000
+Importance: Normal
+Tomorrow is my only conflict but if it can not be changed I will see what I can do! Let me know!
+From:
+To:]
+Sent: Mon Jan 25 10:24:30 2010
+Subject: Epstein Mtg
+HiL
+with
+Thanks.
+- Are you available Tuesday (tomorrow) or Thursday afternoon of this week to go to Miami to meet
+If not, how about Monday, Tuesday, or Wednesday of next week?
+Assistant U.S. Attorney
+500 E. Broward Blvd, 7th Floor
+Ft Lauderdale, FL 33394
diff --git a/vision-fixhub/ds9-unparsed-06/111162fbae62a3ce617e385d414b7b31ef7857563628acb1b007556e7c7bbef1.receipt.json b/vision-fixhub/ds9-unparsed-06/111162fbae62a3ce617e385d414b7b31ef7857563628acb1b007556e7c7bbef1.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..34de539be5db707651614ec9a12f7824754033e0
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/111162fbae62a3ce617e385d414b7b31ef7857563628acb1b007556e7c7bbef1.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "111162fbae62a3ce617e385d414b7b31ef7857563628acb1b007556e7c7bbef1",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "eb35933948124aa4af548f24789c9e47313b076954a40b95874d26f1955c4394",
+  "output_sha256": "b2292f05f346736b2e694e16f108c9c84e29b6f22d1a729e535ac3fd2bcae806",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/112d7c87192c227a070832483b71b2eef33c6d9a492fd998a507f2d05f365522.md b/vision-fixhub/ds9-unparsed-06/112d7c87192c227a070832483b71b2eef33c6d9a492fd998a507f2d05f365522.md
new file mode 100644
index 0000000000000000000000000000000000000000..617ff6e87533407baabb6fdc3585a61b80959be8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/112d7c87192c227a070832483b71b2eef33c6d9a492fd998a507f2d05f365522.md
@@ -0,0 +1,51 @@
+Date: Tue, 16 Nov 2010 21:07:15 +0000
+Importance: Normal
+Thank you very much Marie. I think I have Twiler already as I saw her name on some documents that were filed
+in Court that were not under seal.
+I will be in your office on Thursday so perhaps we can meet IF you are available. I am participating in an
+interview at 1:00 that should last 3 hours or so.
+I was thinking that now that you are back, we should also send a litigation hold letter to the FBI and the police.
+Was there any FBI attorney contact on this matter. If not, I can address the letter to the head of the section if
+you have that name. If you have some time on Thursday, perhaps we can meet. I can leave earlier and get up
+there.
+What is CEOS?
+Thanks!
+J
+Sente Tuesday, November 16. 2010 3:38 PM
+subject: RE: Jane Does . U.5. (re Jenrey Epstein)- Litigation Hold
+- I have attached the two signed documents for your files. I have a series of large stored e-mail backup
+files but when I tried to access some of them a few months ago when this first started heating back up, they were
+empty. I mentioned it to Ricky Vidarte but then I got busy with something else. Some of those items were also
+pdf'd and burned to CD or put on the main server, so all may not be lost, but IT may have to do some digging.
+When I sent you the bunch of names eatlier I forgot to include the following:
+Gerald Lefcourt (counsel for Epstein)
+(victim coordinator at FBI in West Palm Beach)
+Thank you.
+<< File: 20101117044620.pdf >>
+<< File: 20101117044557.pdf >>
+
+
+Sent: Tuesday, November 16, 2010 2:09 PM
+Subject: Jane Does |. U.S. (re Jeffrey Epstein) - Litigation Hold
+Importance: High
+This email is a follow-up to my communication of Nov. 2 regarding a Litigation Hold in the above-referenced
+case. Please read and acknowledge your receipt and agreement to the terms of the attached letter. Kindly
+complete and sign the form accompanying the letter
+Please return the originals of both documents to me at your earliest convenience.
+Thanks very much.
+James
+SelLe taY NOVED 02720105348 PM
+Subject: Jane Does |. U.S. (re Jeffrey Epstein) - Litigation Hold
+Importance: High
+<< File: Re.Jeffrey Epstein.Jane Does |. U.S. - 11.2.2010 JAW Lit Hold Ltr to Individual in USAO.SD.Fla.pdf >> <
+File: Re.Jeffrey Epstein.Jane Does |. U.S. - Typable 3-13.300.003 Attachment.1.pdf >>
+As a follow-up to your recent meeting concerning the above-referenced case, I write this letter in my capacity as
+the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the
+Southern District of Florida (USAO-SDFLA) to advise you of the USAO-SDFLA's legal obligation to preserve
+documents and data relevant to the lawsuit and to enlist your assistance in this regard.
+I request that you please read and acknowledge your receipt and agreement to the terms of this letter. I also
+ask that you please complete and sign the form accompanying this letter. Please return the originals of both
+documents to me by November 9, 2010.
+Should you have any questions, please let me know.
+
+
diff --git a/vision-fixhub/ds9-unparsed-06/112d7c87192c227a070832483b71b2eef33c6d9a492fd998a507f2d05f365522.receipt.json b/vision-fixhub/ds9-unparsed-06/112d7c87192c227a070832483b71b2eef33c6d9a492fd998a507f2d05f365522.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9ebed7f06f8fabafd3d6cac8921cc669ee8cec5e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/112d7c87192c227a070832483b71b2eef33c6d9a492fd998a507f2d05f365522.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "112d7c87192c227a070832483b71b2eef33c6d9a492fd998a507f2d05f365522",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "8ef3b5cc8b550553f4bf5adc6a9d44a1a76d4e73d1cb67c0f9fb5f9386b3c6cb",
+  "output_sha256": "267e31eec7644cfb09a2e47d909a436f10e8c9f9b1f2f72091e464a5f9182ff5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1156e70c49cac5ae0beb73552e7fcaf2af6b2dff25ae3971591cf3fa984b2844.md b/vision-fixhub/ds9-unparsed-06/1156e70c49cac5ae0beb73552e7fcaf2af6b2dff25ae3971591cf3fa984b2844.md
new file mode 100644
index 0000000000000000000000000000000000000000..14813238c4ff1eea7a535c6dbd3f704fb2f76f7a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1156e70c49cac5ae0beb73552e7fcaf2af6b2dff25ae3971591cf3fa984b2844.md
@@ -0,0 +1,362 @@
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 1 of 14
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA/JOHNSON
+JANE DOES #1 AND #2,
+Plaintiffs,
+VS.
+UNITED STATES,
+Defendant.
+ORDER
+THIS CAUSE is before the Court upon Plaintiffs' Motion for Finding of Violations of the
+Crime Victims' Rights Act (DEs 48, 52), Plaintiffs' Motion to Have Their Facts Accepted
+Because of the Government's Failure to Contest Any of the Facts (DE 49), Plaintiffs' Motion for
+Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (DE 50), and
+Bruce E. Reinhart's Motion to Intervene or in the Alternative for a Sua Sponte Rule 11 Order
+(DE 79).' All motions are fully briefed and ripe for review, and the Court has heard oral
+arguments on all motions. The Court has carefully considered the briefing and the parties"
+arguments and is otherwise fully advised in the premises.
+' The Court is awaiting supplemental briefing on the Motion to Intervene of Roy Black,
+Martin Weinberg, and Jay Lefkowitz (DE 56) and will rule on that motion after it is fully briefed.
+Also, because the proposed interveners seek intervention to request a protective order against
+disclosure of certain correspondences at issue in Plaintiffs' Motion to Use Correspondence to
+Prove Violations of the Crime Victims' Rights Act and to Have Their Unredacted Pleadings
+Unsealed (DE 51), the Court will defer ruling on the latter motion until the intervention motion is
+ripe for review.
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 2 of 14
+Background'
+Plaintiffs Jane Doe #1 and Jane Doe #2 are alleged victims of federal sex crimes
+committed by Jeffrey Epstein in Palm Beach County. Between 2001 and 2007, Epstein sexually
+abused multiple underage girls at his Palm Beach mansion, including Plaintiffs. In 2006, the
+Federal Bureau of Investigation ("FBI") opened an investigation into allegations that Epstein was
+inducing underage girls to engage in sexual acts. The case was eventually presented to the
+United States Attorney's Office for the Southern District of Florida, which accepted it for
+investigation. The Palm Beach County State Attorney's Office was also investigating similar
+allegations against Epstein. Plaintiffs allege that the FBI and U.S. Attorney's Office's
+investigation developed a strong case for a federal prosecution against Epstein based on
+"overwhelming" evidence.
+In June 2007, the FBI delivered to Jane Doe #1 a standard victim-notification letter,
+which explained that the case against Epstein was "under investigation" and notified Jane Doe #1
+of her rights under the Crime Victims' Rights Act ("CVRA"). In August 2007, Jane Doe #2
+received a similar notification letter.
+In September 2007, Epstein and the U.S. Attorney's Office began plea discussions. The
+negotiations led to an agreement under which Epstein would plead guilty to two state felony
+offenses for solicitation of prostitution and procurement of minors for prostitution and the U.S.
+= This background discussion is based on the allegations in Plaintiffs' Petition for
+Enforcement of Crime Victims' Rights Act (DE 1) and the Statement of Material Facts in
+Plaintiffs' Motion for Finding of Violation of the Crime Victims' Rights Act (DEs 48, 52).
+These allegations are not yet supported by evidence and the Court relies on them here solely to
+provide the context for the threshold legal issues addressed in this order. As discussed below,
+further factual development is necessary to resolve the additional issues raised in Plaintiffs'
+motions.
+2
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 3 of 14
+Attorney's Office would agree not to prosecute Epstein for federal offenses. On September 24,
+2007, Epstein and the U.S. Attorney's Office executed a Non-Prosecution Agreement ("NPA")
+under these terms.
+Plaintiffs contend that the U.S. Attorney's Office did not confer with them regarding the
+plea discussions and, in fact, intentionally kept secret the negotiations and the NPA. From
+September 24, 2007, the day on which the NPA was executed, through June 2008, the U.S.
+Attorney's Office did not notify either Plaintiff of the existence of the NPA.
+During this period, Plaintiffs communicated multiple times with the FBI and U.S.
+Attorney's Office, but neither Plaintiff was informed of the NPA. On January 10, 2008, the FBI
+sent letters to Plaintiffs advising them that "It]his case is currently under investigation," but
+failing to disclose the existence of the NPA. On January 32, 2008, Jane Doe #1 met with FBI
+agents and attorneys from the U.S. Attorney's Office to discuss her abuse by Epstein. The
+government did not disclose the existence of the NPA. In mid-June 2008, Plaintiffs' counsel
+contacted the Assistant United States Attorney ("AUSA") handling their case to discuss the
+status of the investigation. The AUSA did not disclose the existence of the NPA. On June 27,
+2008, the U.S. Attorney's Office notified Plaintiffs' counsel that Epstein was scheduled to plead
+guilty in state court on June 30, 2008. The U.S. Attorney's Office did not disclose the existence
+of the NPA nor the relationship between Epstein's state plea and the U.S. Attorney's Office's
+agreement to forgo federal charges. On July 3, 2008, Plaintiffs' counsel sent a letter to the U.S.
+Attorney's Office stating Jane Doe #1's desire that it bring federal charges against Epstein.
+3
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 4 of 14
+On July 7, 2008, Jane Doe #1 filed a petition in this Court to enforce her rights under the
+CVRA. Jane Doe #1 alleged that she believed plea discussions were under way between Epstein
+and the U.S. Attorney's Office, and that the government, by failing to notify her of this
+development, had violated her rights under the CVRA. The United States responded to the
+petition on July 9, 2008, arguing that (1) a federal indictment had never been returned against
+Epstein and therefore the CVRA did not attach, and (2) nevertheless, the U.S. Attorney's Office
+had used its best efforts to comply with the CVRA. The government's response also disclosed
+that the U.S. Attorney's Office had entered into the NPA with Epstein.
+On July 11, 2008, this Court held a hearing on Jane Doe #1's petition, at which Jane Doe
+#2 was added as a plaintiff. At the hearing, Plaintiffs explained that their petition did not present
+an emergency and that therefore an immediate resolution was not necessary. On August 14,
+2008, the Court held a status conference and ordered the United States to turn over the NPA to
+all identified victims, including Plaintiffs, and further ordered the parties to work out the terms of
+a protective order governing the NA's disclosure.
+This action was relatively inactive for the next year and one-half while Plaintiffs litigated
+civil actions against Epstein. After those cases settled, Plaintiffs attempted to resolve their
+CVRA dispute with the U.S. Attorney's Office. On March 18, 2011, after the parties" settlement
+efforts failed, Plaintiffs filed a series of motions, which the Court now addresses in turn, along
+with Bruce E. Reinhart's Motion to Intervene.
+3 Jane Doe #2 joined this action after Jane Doe #1 filed the initial Petition for
+Enforcement of Crime Victims' Rights Act.
+4
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 5 of 14
+Motion for Finding of Violations of the Crime Victims' Rights Act
+The CVRA was designed to protect victims' rights and ensure them involvement in the
+criminal-justice process. United States v. Moussaoui, 483 F.3d 220, 234 (4" Cir. 2007); Kenna v.
+U.S. Dist. Court, 435 F.3d 1011, 1016 (9" Cir. 2006) ("The [CVRA] was enacted to make crime
+victims full participants in the criminal justice system."). The statute enumerates the following
+eight rights:
+(1) The right to be reasonably protected from the accused
+(2) The right to reasonable, accurate, and timely notice of any public court
+proceeding, or any parole proceeding, involving the crime or of any release or escape
+of the accused.
+(3) The right not to be excluded from any such public court proceeding, unless the
+court, after receiving clear and convincing evidence, determines that testimony by the
+victim would be materially altered if the victim heard other testimony at that
+proceeding.
+(4) The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, sentencing, or any parole proceeding.
+(5) The reasonable right to confer with the attorney for the Government in the case.
+(6) The right to full and timely restitution as provided in law.
+(7) The right to proceedings free from unreasonable delay.
+(8) The right to be treated with fairness and with respect for the victim's dignity and
+privacy.
+18 U.S.C. § 3771(a).
+If a prosecution is underway, the CVRA grants victims standing to vindicate their rights
+in the ongoing criminal action. 18 U.S.C. § 3771(d)(3). If, however, a prosecution is not
+underway, the victims may initiate a new action under the CVRA in the district court of the
+5
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 6 of 14
+district where the crime occurred.* Id. The statute also tasks the district courts and the
+prosecutors with the responsibility of protecting these rights. See 18 U.S.C. § 3771(b)(1) ("IT]he
+court shall ensure that the crime victim is afforded the rights described in subsection (a)."); §
+3771(c)(1) ("Officers and employees of the Department of Justice ... shall make their best
+efforts to see that crime victims are notified of, and accorded, the rights described in subsection
+(a).").
+Here, Plaintiffs first argue that as a matter of law the CVRA's protections attach before a
+formal charge is filed against the criminal defendant. Accordingly, Plaintiffs contend that the
+CVRA applied here and that the U.S. Attorney's Office violated their CVRA rights; namely,
+their rights to confer, to be treated with fairness, and to accurate and timely notice of court
+proceedings. Based on these violations, Plaintiffs request that this Court set a briefing schedule
+and hearing on the appropriate remedy, which according to Plaintiffs is to invalidate the nonprosecution agreement.
+The United States argues that as a matter of law the CVRA does not apply before formal
+charges are filed, i.e., before an indictment or similar charging document, and therefore does not
+apply here because formal charges were never filed against Epstein. The United States further
+argues that even if the CVRA applied here, the U.S. Attorney's Office complied with its
+requirements.
+The Court first addresses the threshold issue whether the CVRA attaches before the
+government brings formal charges against the defendant The Court holds that it does because the
+"Here, because no criminal case was pending, Plaintiffs filed their petition as a new
+matter in this judicial district, which the Clerk of Court docketed as a civil action.
+6
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 7 of 14
+statutory language clearly contemplates pre-charge proceedings. For instance, subsections (a)(2)
+and (a)(3) provide rights that attach to "any public court proceeding ... involving the crime."
+Similarly, subsection (b) requires courts to ensure CVRA rights in "any court proceeding
+involving an offense against a crime victim." Court proceedings involving the crime are not
+limited to post-complaint or post-indictment proceedings, but can also include initial appearances
+and bond hearings, both of which can take place before a formal charge. By way of example,
+under Rule 5(a)(1)(A) of the Federal Rules of Criminal Procedure, upon arrest the defendant
+must be taken before a magistrate judge "without unnecessary delay" for an initial appearance. If
+the arrest takes place on a weekday, "without unnecessary delay" will typically require that the
+initial appearance occur the following morning, which will often be within twenty-four hours of
+arrest. See United States v. Mendoza, 473 F.2d 697, 702 (S'" Cir. 1973) (holding that the
+government satisfied Rule 5's "without unnecessary delay" requirement by bringing the
+defendant before the magistrate judge on the first weekday morning following the arrest). By
+contrast, Rule 5(b) requires that where the defendant is arrested without a warrant, the
+government must file the complaint "promptly." The Supreme Court has interpreted "promptly"
+under Rule 5(b) as generally requiring that the complaint be filed within forty-eight hours of
+arrest. Cnty. Of Riverside v. McLaughlin, 500 U.S. 44, 56-57 (1991). It is therefore possible that
+where the defendant is arrested on a weekday without a warrant, the initial appearance—which
+may also involve the detention or bond hearing under Rule 5(d)(3)-will take place before the
+government files the criminal complaint.
+Subsection (c)(1) requires that "Officers and employees of the Department of Justice and
+other departments and agencies of the United States engaged in the detection, investigation, or
+7
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 8 of 14
+prosecution of crime shall make their best efforts to see that crime victims are notified of, and
+accorded, the rights in subsection (a)." (Emphasis added). Subsection (c)(1)'s requirement that
+officials engaged in "detection [or] investigation" afford victims the rights enumerated in
+subsection (a) surely contemplates pre-charge application of the CVRA.
+Subsection (d)(3) explains that the CVRA's enumerated rights "shall be asserted in the
+district court in which a defendant is being prosecuted for the crime or, if no prosecution is
+underway, in the district court in the district in which the crime occurred." (Emphasis added). If
+the CVRA's rights may be enforced before a prosecution is underway, then, to avoid a strained
+reading of the statute, those rights must attach before a complaint or indictment formally charges
+the defendant with the crime.
+This interpretation is consistent with other federal decisions that have addressed the scope
+of the CVRA. For instance, in In re Dean, 527 F.3d 391 (5" Cir. 2008), the court held that
+subsection (a)(5)'s "right to confer" applied before any prosecution is underway. Id. at 394.
+Specifically, the court explained:
+The district court acknowledged that "there are clearly rights under the CVRA that
+apply before any prosecution is underway." Logically, this includes the CVRA's
+establishment of victims" "reasonable right to confer with the attorney for the
+Government." At least in the posture of this case (and we do not speculate on th
+applicability to other situations), the government should have fashioned a reasonable
+way to inform the victims of the likelihood of criminal charges and to ascertain the
+victims' views on the possible details of a plea bargain.
+Id. at 394 (internal citation and quotation marks omitted). Federal district courts have reached
+similar conclusions. See, e.g., United States v. Rubin, 558 F. Supp. 2d 411, 417 n.5 (E.D.N.Y.
+2008) (discussing victims' "ability to seek pre-prosecution relief" under the CVRA); United
+States v. Okun, No. 08-132, 2009 WL 790042, at *2 (E.D. Va. Mar. 24, 2009) ("IT]he Fifth
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 9 of 14
+Circuit has noted that victims acquire rights under the CVRA even before prosecution. This
+view is supported by the statutory language, which gives the victims rights before the accepting
+of plea agreements and, therefore, before adjudication of guilt."); United States v. BP Prods N.
+Am. Inc., No. 07-434, 2008 WL 501321, at *11 (S.D. Tex. Feb. 21, 2008) ("There are clearly
+rights under the CVRA that apply before any prosecution is underway."), mandamus denied in
+part, In re Dean 527 F.3d 391 (5"' Cir. 2008).
+The United States argues that because the CVRA accords rights related to "any court
+proceeding," 18 U.S.C. §§ 3771(b)(1), (d)(3), and "in the case," § 3771(b)(5), the CVRA applies
+only after formal charges are filed. The Court finds this argument unavailing. First, as discussed
+above, "court proceedings" can occur before formal charges are filed. Similarly, subsection
+(a)(5)'s reference to the right to confer with "the attorney for the Government in the case," is not
+limited to post-charge proceedings, as the United States is represented by attorneys in each
+criminal case at, for example, initial appearances and bond hearings. Last, the government's
+interpretation ignores the additional language throughout the statute that clearly contemplates
+pre-charge protections, such as subsection (c)(1)'s mandate that U.S. agencies involved at the
+"detection" and "investigation" stage use their best efforts to accord victims their enumerated
+rights under the CVRA and subsection (d)(3)'s provision that victims may vindicate their CVRA
+s For this reason, the Court respectfully disagrees with the interpretation adopted in In re
+Petersen, No. 10-298, 2010 WL 5108692 (N.D. Ind. Dec. 8, 2010), upon which the United States
+relies. See id. at *2 (holding that a "victim's "right to be treated with fairness and with respect
+for [his or her] dignity and privacy' may apply before any prosecution is underway and isn't
+necessarily tied to a 'court proceeding' or 'case,' but concluding that "the right "to confer with
+the attorney for the Government in the case' ... arise[s] only after charges have been brought
+against a defendant and a case has been opened"). But see In re Dean, 527 F.3d at 394 (holding
+that under subsection (a)(5), "the government should have fashioned a reasonable way to inform
+the victims of the likelihood of criminal charges").
+9
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 10 of 14
+rights even if "no prosecution is underway." See United States v. DBB, Inc., 180 F.3d 1277,
+1281 (11" Cir. 1999) ("[W]e read the statute to give full effect to each of its provisions. We do
+not look at one word or term in isolation, but instead we look to the entire statutory context.")
+(citation omitted).
+The Court also rejects the United States' argument that pre-charge CVRA rights could
+impair prosecutorial discretion and decision-making. Any encroachment into the prosecutors'
+discretion is expressly limited by the CVRA itself, which provides: "Nothing in this chapter shall
+be construed to impair the prosecutorial discretion of the Attorney General or any officer under
+his direction." 18 U.S.C. § 3771(d)(6). As the court explained in Rubin, "there is absolutely no
+suggestion in the statutory language that victims have a right independent of the government to
+prosecute a crime, set strategy, or object to or appeal pretrial or in limine orders .... In short, the
+CVRA, for the most part, gives victims a voice, not a veto." 558 F. Supp. at 418; see also BP
+Prods N. Am., 2008 WL 501321, at *15 ("Even under an expansive approach, the reasonable
+right to confer on a proposed plea agreement and the government's obligation to provide notice
+of that right is subject to the limit that the CVRA not impair prosecutorial discretion."). Thus, to
+the extent that the victims' pre-charge CVRA rights impinge upon prosecutorial discretion, under
+the plain language of the statute those rights must yield.
+Having determined that as a matter of law the CVRA can apply before formal charges are
+filed, the Court must address whether the particular rights asserted here attached and, if so,
+whether the U.S. Attorney's Office violated those rights. However, the Court lacks a factual
+record to support such findings and must therefore defer ruling on these two issues pending the
+limited discovery discussed below.
+10
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 11 of 14
+11.
+Motion to Have Their Facts Accepted Because of the Government's Failure to
+Contest Any of the Facts
+For the reasons stated on the record at the August 12, 2011 hearing on this motion, the
+Court will deny Plaintiffs' request to have their facts accepted as true.
+Ill.
+Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant
+Evidence
+Plaintiffs request an order from the Court "directing the U.S. Attorney's Office not to
+suppress material evidence relevant to this case." (DE 50 at 1). Specifically, Plaintiffs seek all
+information and material known to the government that may be favorable to the victims
+regarding possible violations of their rights under the CVRA. The United States opposes the
+motion, arguing that neither the CVRA nor the Federal Rules of Civil Procedure impose a duty
+upon the U.S. Attorney's Office to provide evidence to Plaintiffs here.
+At the August 12, 2011 hearing on this motion, the United States agreed that this Court,
+under its inherent authority to manage this case, could impose discovery obligations on each
+party. Because the Court finds that some factual development is necessary to resolve the
+remaining issues in this case, it will permit Plaintiffs the opportunity to conduct limited
+discovery in the form of document requests and requests for admissions from the U.S. Attorney's
+Office. Either party may request additional discovery if necessary.
+Because the Court will allow this limited factual development, it is unnecessary to decide
+here whether the CVRA or the Federal Rules of Civil Procedure provide discovery rights in this
+context. The Court therefore reserves ruling on Plaintiffs' motion.
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 12 of 14
+IV.
+Bruce E. Reinhart's Motion to Intervene or in the Alternative for a Sua Sponte Rule
+11 Order
+Bruce E. Reinhart seeks leave to intervene as a party-in-interest under Rule 24(b) of the
+Federal Rules of Civil Procedure. Reinhart seeks to intervene to file a motion for sanctions
+based on allegedly "unfounded factual and legal accusations made about Movant in Plaintiffs"
+Motion for Finding of Violations of the Crime Victims' Rights Act." (DE 79 at 1). In that
+motion, Plaintiffs alleged that Reinhart, a former Assistant U.S. Attorney, "joined Epstein's
+payroll shortly after important decisions were made limiting Epstein's criminal liability" and
+improperly represented Epstein victims in follow-on civil suits. (DE 48 at 22). Plaintiffs
+contend that such conduct "give[s], at least, the improper appearance that Reinhart may have
+attempted to curry [favor] with Epstein and then reap his reward through favorable employment."
+(DE 48 at 23). Reinhart takes great offense to these accusation-
+-which he contends are false,
+irrelevant to the CVRA claims, and gratuitous and seeks intervention to rebut these allegations
+and move for sanctions.
+Under Rule 24(b) of the Federal Rules of Civil Procedure, "the court may permit anyone
+to intervene who ... has a claim or defense that shares with the main action a common question
+of law or fact." It is "wholly discretionary with the court whether to allow intervention under
+Rule 24(b) and even though there is a common question of law or fact, or the requirements of
+Rule 24(b) are otherwise satisfied, the court may refuse to allow intervention." In re Bayshore
+Ford Trucks Sales, Inc., 471 F.3d 1233, 1246 (11"" 2006). The Court will deny Reinhart's
+request to intervene.
+12
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 13 of 14
+First, the Court finds that Reinhart's claim does not share a common question of law or
+fact with the CVRA action. Reinhart claims that two paragraphs of Plaintiffs' forty-page motion
+make groundless and bad-faith accusations against his integrity and character. However, the
+veracity of Plaintiffs' two paragraphs —i.e., whether Reinhart used his position at the U.S.
+Attorney's Office to ingratiate himself with Epstein and advance his career in private
+practice-involves no common questions with the Plaintiffs' claims that the U.S. Attorney's
+Office violated their CVRA rights through the process in which it entered into the NPA with
+Epstein. Indeed, Reinhart's motion argues that the allegations against him are "irrelevant" and
+that Plaintiffs "do[] not make any effort to connect these allegations to the relief [they] seek[]."
+(DE 79 at 2).
+Second, even if these accusations shared common questions with Plaintiffs' CVRA
+claims, the Court would exercise its discretion and deny intervention. The Court cannot permit
+anyone slighted by allegations in court pleadings to intervene and conduct mini-trials to vindicate
+their reputation. Absent some other concrete interest in these proceedings, the Court does not
+believe that the allegations here are sufficiently harmful to justify permissive intervention.
+Reinhart has publicly aired his opposition to and denial of Plaintiffs' contentions, both on this
+docket and in open court, and the Court finds that further proceedings on this issue are
+unwarranted. For the same reason, the Court declines to conduct a sua sponte Rule 11 inquiry.
+Conclusion
+For the foregoing reasons, it is hereby ORDERED AND ADJUDGED that Plaintiffs'
+Motion for Finding of Violations of the Crime Victims' Rights Act (DEs 48, 52) is GRANTED
+IN PART. The Court concludes that the CVRA can apply before formal charges are filed. The
+13
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 14 of 14
+Court defers ruling on the merits of Plaintiffs' CVRA claims until the parties complete the
+discovery ordered herein.
+It is further ORDERED AND ADJUDGED that Plaintiffs' Motion to Have Their Facts
+Accepted (DE 49) is DENIED.
+The Court reserves ruling Plaintiffs' Motion for Order Directing the U.S. Attorney's
+Office Not to Withhold Relevant Evidence (DE 50) pending the discovery ordered herein.
+It is further ORDERED AND ADJUDGED that Bruce E. Reinhart's Motion to Intervene
+or in the Alternative for a Sua Sponte Rule 11 Order (DE 79) is DENIED.
+DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, Florida
+this 26" day of September, 2011.
+KENNETH A. MARRA
+United States District Judge
+14
diff --git a/vision-fixhub/ds9-unparsed-06/1156e70c49cac5ae0beb73552e7fcaf2af6b2dff25ae3971591cf3fa984b2844.receipt.json b/vision-fixhub/ds9-unparsed-06/1156e70c49cac5ae0beb73552e7fcaf2af6b2dff25ae3971591cf3fa984b2844.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..eec2b3712123ed718d213b5719048fe362eaf85f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1156e70c49cac5ae0beb73552e7fcaf2af6b2dff25ae3971591cf3fa984b2844.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -170,
+  "dataset": "marble-joined",
+  "doc_id": "1156e70c49cac5ae0beb73552e7fcaf2af6b2dff25ae3971591cf3fa984b2844",
+  "engine": "marble-apple-vision",
+  "event_count": 15,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "7234dcc5c810ddde05550f1d2a2fdbd9edbbbf2455c26df180ee5e80fdce8237",
+  "output_sha256": "b5445c2e291bfcde344c6c35c7cafadb153d0d03136f5e63bfb7fbe9b6fc6afc",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1167ca37484ca6e376e95e2903d44c698191b88b9dc0a896d224268007dd7bac.md b/vision-fixhub/ds9-unparsed-06/1167ca37484ca6e376e95e2903d44c698191b88b9dc0a896d224268007dd7bac.md
new file mode 100644
index 0000000000000000000000000000000000000000..b59a215333105c420fba14b75e001c843f362456
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1167ca37484ca6e376e95e2903d44c698191b88b9dc0a896d224268007dd7bac.md
@@ -0,0 +1,56 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov»
+Subject: Activity in Case 9:08-cv-80119-KAM Doe |. Epstein Motion for Sanctions
+Date: Thu, 14 Jan 2010 16:40:24 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. Distriet Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 1/14/2010 at 11:40 AM EST and filed on 1/13/2010
+Case Name:
+Case Number:
+Filer:
+Doe | Epstein
+9:08-cv-80119-KAM
+Jeffrey Epstein
+Document Number: 451(No document attached)
+Docket Text:
+MOTION for Sanctions and Incorporated Memorandum of Law by Jeffrey Epstein. DOCKET
+CORRECTION - SECOND PART OF DOCUMENT [450] (tp)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+ahorowitz@sexabuseattorney.com
+Bradley James Edwards
+brad@pathtojustice.com. beth@pathtojustice.com
+Isidro Manuel Garcia
+isidrogarcia@bellsouth.net
+Jack Alan Goldberger
+jagesq@bellsouth.net, nalanis@agwpa.com
+Jack Patrick Hill
+jph@searcylaw.com, c/w@searcylaw.com, kmo@searcylaw.com, s.slater@searcylaw.com,
+sas@searcylaw.com, vat@searcylaw.com
+Jeffrey Mare Herman
+jherman@hermanlaw.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+Michael James Pike MPike@bclclaw.com, bobbie@bclclaw.com, jcadwell@bclclaw.com
+
+
+Paul G. Cassell cassellp@law.utah.edu
+Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com
+Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton@podhurst.com,
+mestrada@podhurst.com
+Robert Deweese Critton, Jr rerit@belclaw.com, bobbie@bclelaw.com
+Stuart S. Mermelstein ssm@sexabuseattorney.com, jarbour@sexabuseattorney.com,
+Irivera(@sexabuseattorney.com
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+Martin G. Weinberg
+20 Park Plaza
+Boston, MA 02116
diff --git a/vision-fixhub/ds9-unparsed-06/1167ca37484ca6e376e95e2903d44c698191b88b9dc0a896d224268007dd7bac.receipt.json b/vision-fixhub/ds9-unparsed-06/1167ca37484ca6e376e95e2903d44c698191b88b9dc0a896d224268007dd7bac.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ed9f71ec60f00686cfd0a16918e91e939d902df0
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1167ca37484ca6e376e95e2903d44c698191b88b9dc0a896d224268007dd7bac.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "1167ca37484ca6e376e95e2903d44c698191b88b9dc0a896d224268007dd7bac",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3d9b1aa46e7ea591e8246276d8995bd379eb77ac9e51d54950e120d1c5ee342f",
+  "output_sha256": "5c4d6cbdaf164c90ef3eb72cdb9be9a658b069bf6beca1b6127ab6783eb65e67",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/11784bb4537eccca7419084d82411e9031100e2104ea4d47686bbd63d787d4ad.md b/vision-fixhub/ds9-unparsed-06/11784bb4537eccca7419084d82411e9031100e2104ea4d47686bbd63d787d4ad.md
new file mode 100644
index 0000000000000000000000000000000000000000..2c41a94ed64e3a26292ca006085fb284ef49f838
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/11784bb4537eccca7419084d82411e9031100e2104ea4d47686bbd63d787d4ad.md
@@ -0,0 +1,814 @@
+* cingular®
+Subscriber Number:
+Call Date Call Time
+Dialed #
+Duration
+Location
+Feature
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+08/01/2006 03:37:17 PM
+08/01/2006 03:09:24 PM
+08/01/2006 02:04:25 PM
+08/01/2006 01:25:34 PM
+08/01/2006 01:23:14 PM
+08/01/2006 12:21:12 PM
+08/01/2006 10:30:29 AM
+08/01/2006 10:09:50 AM
+08/01/2006 09:33:31 AM
+08/01/2006 09:28:35 AM
+08/01/2006 09:23:23 AM
+08/01/2006 09:12:09 AM
+08/01/2006 09:00:24 AM
+08/01/2006 08:59:49 AM
+08/01/2006 08:49:58 AM
+08/01/2006 08:23:18 AM
+07/31/2006 03:50:41 PM
+07/31/2006 03:50:25 PM
+07/31/2006 01:23:21 PM
+07/31/2006 12:05:31 PM
+07/31/2006 10:09:30 AM
+00:00:24
+00:00:34
+00:00:24
+00:00:22
+00:00:16
+00: 01:05
+00:00:01
+00:00:16
+00:00:35
+00:00:10
+00:01:01
+00:00:07
+00:00:28
+00:00:11
+00:00:27
+00:00:09
+00:00:14
+00:00:31
+00:00:52
+00:00:54
+00:00:34
+EL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+FL 37Miami500-A
+FL 37Mi ami500-A
+EL 75Jacksonville500-A
+EL 15Jacksonville500-A
+EL 75Jacksonville500-A
+FL 37Miami500-A
+FL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+FL 37Miami500-A
+EL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+All "Calls to Destination" and "Subscriber Activity" reports are recorded in Local switch Time.
+This data provided may be in pre-bill format. Due to possible data losses it is not necessarily a complete record of all calls, and is not the
+same as an invoice received by a subscriber.
+JJM
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless and its Affiliates
+1
+
+
+Call Date
+Call Time
+Dialed #
+Duration
+Location
+Feature
+22
+23
+24
+25
+26
+27
+28
+29
+30
+31
+32
+33
+34
+35
+36
+37
+38
+39
+40
+41
+42
+43
+44
+07/31/2006 09:22:36 AM
+07/27/2006 02:58:53 PM
+07/27/2006 02:07:06 PM
+07/27/2006 01:08:23 PM
+07/27/2006 11:49:50 AM
+07/27/2006 08:45:42 AM
+07/27/2006 08:40:26 AM
+07/27/2006 08:39:04 AM
+07/26/2006 01:15:39 PM
+07/26/2006 12:46:45 PM
+07/26/2006 12:44:02 PM
+07/26/2006 12:21:32 PM
+07/26/2006 10:41:16 AM
+07/26/2006
+10:40:24 AM
+07/26/2006
+10:30:50 AM
+07/26/2006 08:31:19 AM
+07/25/2006 02:40:25 PM
+07/25/2006 01:43:03 PM
+07/25/2006 12:06:51 PM
+07/25/2006 12:04:34 PM
+07/25/2006 10:59:01 AM
+07/25/2006 09:51:52 AM
+07/24/2006 12:27:17 PM
+00:00:32
+00:01:09
+00:00:16
+00:00:33
+00:00:47
+00:01:16
+00:00:48
+00: 01:03
+00:00:19
+00:00:33
+00: 00:32
+00:00:33
+00:00:49
+00:00:27
+00:02:40
+00:01:14
+00:04:24
+00:00:40
+00:00:38
+00:00:14
+00:00:20
+00:00:19
+00:00:22
+EL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+EL 37Miami500-A
+FL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+All "Calls to Destination" and "Subscriber Activity" reports are recorded in Local switch Time.
+This data provided may be in pre-bill format. Due to possible data losses it is not necessarily a complete record of all calls, and is not the
+same as an invoice received by a subscriber.
+JJM
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless and its Affiliates
+2
+
+
+Call Date
+Call Time
+Dialed #
+Duration
+Location
+Feature
+45
+46
+47
+48
+49
+50
+51
+52
+53
+54
+55
+56
+57
+58
+59
+60
+61
+62
+63
+64
+65
+66
+67
+07/24/2006 10:14:11 AM
+07/24/2006 09:54:40 AM
+07/24/2006 09:51:47 AM
+07/24/2006 09:46:10 AM
+07/20/2006 02:37:02 PM
+07/20/2006 02:34:35 PM
+07/20/2006 01:59:58 PM
+07/20/2006 01:10:33 PM
+07/19/2006 10:41:48 AM
+07/19/2006 10:40:34 AM
+07/19/2006 10:15:06 AM
+07/18/2006 03:39:36 PM
+07/18/2006 02:02:41 PM
+07/18/2006 09:59:36 AM
+07/18/2006 09:13:03 AM
+07/13/2006 02:01:27 PM
+07/13/2006 01:58:32 PM
+07/13/2006 01:56:02 PM
+07/13/2006 01:33:49 PM
+07/13/2006 01:24:06 PM
+07/13/2006 01:21:21 PM
+07/13/2006 01:20:16 PM
+07/13/2006 01:18:22 PM
+00:00:50
+00:00:18
+00:00:58
+00:02:48
+00: 02:31
+00: 01:09
+00:00:49
+00:01:40
+00:00:50
+00:00:54
+00:00:52
+00:00:31
+00:00:25
+00:00:19
+00:00:52
+00:00:24
+00:02:41
+00: 01:10
+00: 02:17
+00:00:55
+00:00:20
+00:00:29
+00:00:11
+FL 37Miami500-A
+FL 37Miami500-A
+EL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 75Jacksonville500-A
+FL 37Miami500-A
+EL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 75Jacksonville500-A
+FL 37Miami500-A
+FL 37Miami500-A
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+All "Calls to Destination" and "Subscriber Activity" reports are recorded in Local switch Time.
+This data provided may be in pre-bill format. Due to possible data losses it is not necessarily a complete record of all calls, and is not the
+same as an invoice received by a subscriber.
+JJM
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless and its Affiliates
+3
+
+
+Call Date Call Time
+Dialed #
+Duration
+Location
+Feature
+68
+69
+70
+71
+72
+73
+74
+75
+76
+77
+78
+79
+80
+81
+82
+83
+84
+85
+86
+87
+88
+89
+90
+07/13/2006 01:15:55 PM
+07/13/2006 01:03:26 PM
+07/13/2006 11:38:20 AM
+07/13/2006 11:12:54 AM
+07/13/2006 08:49:24 AM
+07/12/2006 02:57:15 PM
+07/12/2006 01:48:56 PM
+07/12/2006 10:29:19 AM
+07/12/2006 10:12:34 AM
+07/12/2006 10:10:37 AM
+07/11/2006 03:34:27 PM
+06/29/2006 12:34:34 PM
+06/28/2006 04:17:51 PM
+06/28/2006 03:40:48 PM
+06/28/2006 03:37:39 PM
+06/28/2006 03:36:34 PM
+06/28/2006 03:35:49 PM
+06/28/2006 12:58:24 PM
+06/28/2006 12:17:03 PM
+06/28/2006 12:15:45 PM
+06/28/2006 07:28:16 AM
+06/28/2006 07:06:01 AM
+06/28/2006 07:04:17 AM
+00:00:37
+00:00:35
+00:00:30
+00:00:24
+00:00:45
+00:00:45
+00:00:48
+00:00:55
+00:00:59
+00:00:18
+00:00:13
+00:01:04
+00:00:42
+00:03:14
+00: 01:51
+00:00:06
+00:00:17
+00:01:22
+00:00:25
+00:00:11
+00:00:29
+00:00:18
+00:00:02
+EL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+FL 37Miami500-A
+EL 75Jacksonville500-A
+FL 75Jacksonville500-A
+FL 75Jacksonville500-A
+FL 75Jacksonville500-A
+EL 75Jacksonville500-A
+EL 37Miami500-A
+FL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+EL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+EL 37Miami500-A
+FL 37Miami500-A
+EL 37Miami500-A
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+NONE
+All "Calls to Destination" and "Subscriber Activity" reports are recorded in Local switch Time.
+This data provided may be in pre-bill format. Due to possible data losses it is not necessarily a complete record of all calls, and is not the
+same as an invoice received by a subscriber.
+JJM
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless and its Affiliates
+4
+
+
+*cingular®
+Call Date
+Call Time
+Dialed #
+Duration
+Location
+Feature
+91
+06/28/2006 06:55:07 AM
+00:00:13
+FL 37Miami500-A
+NONE
+All "Calls to Destination" and "subscriber Activity" reports are recorded in Local Switch Time.
+This data provided may be in pre-bill format. Due to possible data losses it is not necessarily a complete record of all calls, and is not the
+same as an invoice received by a subscriber.
+JJM
+5
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless and its Affiliates
+
+
+* cingular®
+From: 01/01/2006 12:00 AM
+To:
+08/01/2006 11:59 PM
+Number Called:
+MobileId
+Call Date
+Call Time
+HR: MN: SC
+Call Duration
+HR: MN: SC
+Location
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+16
+17
+18
+19
+JJM
+08/01/2006
+08/01/2006
+08/01/2006
+08/01/2006
+08/01/2006
+08/01/2006
+08/01/2006
+08/01/2006
+08/01/2006
+07/31/2006
+07/31/2006
+07/31/2006
+07/31/2006
+07/27/2006
+07/27/2006
+07/27/2006
+07/26/2006
+07/26/2006
+07/26/2006
+03:09:11 PM
+01:22:57 PM
+10:09:39 AM
+09:32:59 AM
+09:28:24 AM
+09:22:52 AM
+09:11:52 AM
+09:00:16 AM
+08:23:06 AM
+03:50:36 PM
+01:23:09 PM
+12:05:21 PM
+09:22:24 AM
+02:06:59 PM
+11:49:33 AM
+08:46:13 AM
+01:15:25 PM
+12:46:31 PM
+12:43:40 PM
+00:00:46
+00:00:33
+00:00:27
+00: 01:08
+00: 00:21
+00:01:32
+00:00:24
+00:00:36
+00:00:21
+00:00:19
+00:01:04
+00:01:04
+00:00:44
+00:00:23
+00:01:04
+00:01:15
+00:00:33
+00:00:47
+00:00:54
+FL 37Miami500-A
+FL 37Miami500-A
+EL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+System:24 Switch: 201
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+* - indicates the first time the calling number appears on the report
+ill "Calls to Destination" and "subscriber Activity" reports are recorded in Local Switch Time
+his data provided may be in pre-bill format. Due to possible data losses it is not necessarily a complete record of all calls, and is not thi
+same as an invoice received by a subscriber.
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless and its Affiliates
+Page 1
+
+
+*cingular®
+MobileId
+Call Date
+Call Time
+HR: MN: SC
+Call Duration
+HR: MN: SC
+Location
+20
+21
+22
+23
+24
+25
+26
+27
+28
+29
+30
+31
+32
+33
+34
+35
+36
+37
+38
+39
+40
+41
+42
+JJM
+07/25/2006
+07/25/2006
+07/25/2006
+07/25/2006
+07/24/2006
+07/24/2006
+07/24/2006
+07/22/2006
+07/17/2006
+07/13/2006
+07/13/2006
+07/13/2006
+07/13/2006
+07/13/2006
+07/13/2006
+07/12/2006
+07/12/2006
+07/11/2006
+07/07/2006
+07/05/2006
+07/03/2006
+07/03/2006
+06/29/2006
+02:40:16 PM
+12:06:37 PM
+12:04:13 PM
+09:51:28 AM
+12:27:02 PM
+09:55:10 AM
+09:52:17 AM
+05:27:03 AM
+03:05:42 PM
+01:34:19 PM
+01:23:55 PM
+01:18:11 PM
+01:03:15 PM
+11:38:10 AM
+11:12:44 AM
+01:48:44 PM
+10:29:08 AM
+03:34:20 PM
+07:48:28 AM
+08:59:01 AM
+02:00:10 PM
+12:40:02 PM
+12:35:03 PM
+00:04:33
+00:00:52
+00:00: 35
+00:00:43
+00:00:37
+00:00:18
+00:00:57
+00:00:14
+00:00:09
+00:02:17
+00:01:07
+00:00:21
+00:00:46
+00:00:40
+00:00:34
+00:01:00
+00:01:06
+00:00:20
+00:00:33
+00:00:12
+00:00:46
+00:00:17
+00:01:04
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+EL 37Miami500-A
+FL 37Miami500-A
+System: 24 Switch: 201
+System:24 Switch: 201
+System: 24 Switch: 201
+FL 24FortLauderdale1-B
+System: 24 Switch: 201
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 37Miami500-A
+FL 75Jacksonville500-A
+FL 75Jacksonville500-A
+FL 75Jacksonville500-A
+FL 37Miami500-A
+System: 24 Switch: 201
+System: 24
+Switch: 201
+System: 24 Switch: 201
+System: 24 Switch: 201
+System: 24
+Switch: 201
+* - indicates the first time the calling number appears on the report
+ill "Calls to Destination" and "subscriber Activity" reports are recorded in Local Switch Time
+his data provided may be in pre-bill format. Due to possible data losses it is not necessarily a complete record of all calls, and is not thi
+same as an invoice received by a subscriber.
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless and its Affiliates
+Page 2
+
+
+* cingular®
+MobileId
+Call Date
+Call Time
+HR: MN: SC
+Call Duration
+HR: MN: SC
+Location
+43
+44
+45
+06/28/2006
+06/28/2006
+06/28/2006
+12:16:28 PM
+07:08:48 AM
+07:04:47 AM
+00:01:00
+00: 00:09
+00: 00:01
+FL 37Miami500-A
+FL 24Fortlauderdalel-B
+System: 24
+Switch: 202
+JJM
+* - indicates the first time the calling number appears on the report
+11 "Calls to Destination" and "Subscriber Activity" reports are recorded in Local Switch Time
+his data provided may be in pre-bill format. Due to possible data losses it is not necessarily a complete record of all calls, and is not thi
+same as an invoice received by a subscriber.
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless and its Affiliates
+Page 3
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/11784bb4537eccca7419084d82411e9031100e2104ea4d47686bbd63d787d4ad.receipt.json b/vision-fixhub/ds9-unparsed-06/11784bb4537eccca7419084d82411e9031100e2104ea4d47686bbd63d787d4ad.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..995e4bff8a26f2b370c4c3f0ff1cea434fb0718c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/11784bb4537eccca7419084d82411e9031100e2104ea4d47686bbd63d787d4ad.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -665,
+  "dataset": "marble-joined",
+  "doc_id": "11784bb4537eccca7419084d82411e9031100e2104ea4d47686bbd63d787d4ad",
+  "engine": "marble-apple-vision",
+  "event_count": 9,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "659910ae9d034807e779bebdb14afc45c446d3b55015b2d6a43caacfbf938d4d",
+  "output_sha256": "c7f447f18a181cf6bc189aa29c21ad95ef13a3d2db60f0b9304138fd0186e483",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/11886b1014eab8ba9c98a907a17a2ea5807e97cec05332617447b3aed6d7908d.md b/vision-fixhub/ds9-unparsed-06/11886b1014eab8ba9c98a907a17a2ea5807e97cec05332617447b3aed6d7908d.md
new file mode 100644
index 0000000000000000000000000000000000000000..278a3150ab7e865653fae690ba21a72d25aaac07
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/11886b1014eab8ba9c98a907a17a2ea5807e97cec05332617447b3aed6d7908d.md
@@ -0,0 +1,69 @@
+From:
+To: "
+• (USAFLS)"
+</0=USA/OU=FLS/CN=RECIPIENTS/CN-|
+(USAFLS)" <
+Subject: RE: JE -- letter
+Date: Thu, 02 Aug 2007 18:47:13 +0000
+Importance: Normal
+(USAFLS)"
+(USAFLS)" <
+I am free any time before 5:30. Should Andy and I call you from his office?
+Assistant U.S. Attorney
+----Original Message-
+From:
+(USAFLS)
+Sent: Thursday, August 02, 2007 2:30 PM
+To:
+(USAFLS);
+(USAFLS); L
+(USAFLS)
+Subject: Re: JE - letter
+Yes, I think we should.
+has to leave early but is available by phone.
+Sent from my BlackBerry Wireless Handheld
+-----Original Message--...
+From:
+To:
+(USAFLS) <
+(USAFLS) <
+(USAFLS)
+(USAFLS) <
+Sent: Thu Aug 02 14:06:14 2007
+Subject: RE: JE -- letter
+Do you want to do a conference call? And has a meeting with Alex been set up yet?
+Thanks.
+Assistant U.S. Attorney
+----Original Message-.
+(USAFLS)
+I (USAFLS);
+Subject: FW: JE -- letter
+. (USAFLS); L
+(USAFLS)
+FYI
+----Original Message--.
+From:
+[mailto:
+
+
+Sent: Thursday, August 02, 2007 12:38 PM
+To:
+(USAFLS)
+Cc: |
+Subject: JE -- letter
+I- please see attached and confirm receipt.
+i am also having letter hand-delivered to you and alex.
+regards
+, Esq.
+FOWLER WHITE BURNETT P.A.
+Espirito Santo Plaza, 14th Floor
+**TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS,
+we inform you that any tax advice contained in this communication (including attachments) was not intended or
+written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code
+or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you
+would like such advice, please contact us.***
+***Attention: The information contained in this E-mail message is attorney privileged and confidential
+information intended only for the use of the individual(s) named above. If the reader of this message is not the
+intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is
+strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail
+and destroy all copies of the original message. Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/11886b1014eab8ba9c98a907a17a2ea5807e97cec05332617447b3aed6d7908d.receipt.json b/vision-fixhub/ds9-unparsed-06/11886b1014eab8ba9c98a907a17a2ea5807e97cec05332617447b3aed6d7908d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d1f75738df35ab11fd0c34a350fef0a274b23ec1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/11886b1014eab8ba9c98a907a17a2ea5807e97cec05332617447b3aed6d7908d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "11886b1014eab8ba9c98a907a17a2ea5807e97cec05332617447b3aed6d7908d",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "daba0abe00929c8ba4959ea37e4af54124d660cb3f2e323fd69c972ac628a89e",
+  "output_sha256": "7404cdd13f699b7e9aa109d04397d7d96a0b1afa5b5af1c5a26fa67daed26d2a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/11e5f2e645c880c08d72001cc690d96e35a0316871c334249167410e42e188af.md b/vision-fixhub/ds9-unparsed-06/11e5f2e645c880c08d72001cc690d96e35a0316871c334249167410e42e188af.md
new file mode 100644
index 0000000000000000000000000000000000000000..662b341dccdc5f02d1630aa0ee383c62d1a5f16b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/11e5f2e645c880c08d72001cc690d96e35a0316871c334249167410e42e188af.md
@@ -0,0 +1,331 @@
+X cingular
+Billing Cycle Date:
+Account Number:
+1 of 5
+09/15/05 - 10/14/05
+How To Contact Us:
+• 1-800-331-0500 or 611 from your wireless phone
+• For Deaf / Hard of Hearing Customers (TTY/TDD)
+1-866-241-6567
+Wireless Number
+Previous Balance
+Payments Posted
+BALANCE
+Monthly Service Charges
+Usage Charges
+Credits/Adjustments/Other Charges
+Government Fees and Taxes
+TOTAL CURRENT CHARGES
+Due Nov 06, 2005
+Late fees assessed after Nov 06
+Total Amount Due $165.21
+190.98
+-190.98
+4.50
+150.12
+10.59
+165.21
+Wireless AMBER Alerts
+Sign up to receive Wireless AMBER Alerts at www.cingular.com/amberalerts or by sending
+a text message with up to 5 zip codes to the short code AMBER (i.e. send SUBSCRIBE 12345
+to short code 26237). Customers capable of receiving text messages can receive these
+cographically specified alerts. There is no charge to sign up or to receive AMBER alen
+ormal airtime charges will apply if you place a call in response to an AMBER alert messag
+*BWNHHBD
+#05725942030013*
+Return the portion below with paymen
+to Cingular Wireless only
+Account Number: 05725942-001-03
+Total Amount Due:
+$165.21
+Amount Paid:
+$
+* Please do not send correspondence wish paymens.
+Total Amount
+Due by Nov 06, 2005
+Please Make Check Payable To:
+
+
+
+X cingular
+Billing Cycle Date:
+Account Number:
+2 of 5
+09/15/05 - 10/14/05
+General Information
+• Terms: The past due amount is due immediately. Late payment charges of 1.5% may be
+applied to any unpaid balance as of your next billing date. When you send us a
+selected services. Usage and toll charges are billed in arrears. Certain usage
+and toll charges may appear more than one month in arrears. Prorated monthly
+charges may apply for new services or changes to existing services during a
+billing period. These will appear in the Monthly Service Charges sections of the
+• Please do not enclose correspondence with your payment for we cannot guarantee
+TO BOX 772349- (A) OGA. 0L3401-ing: Cingular Wireles,
+• Calls to our Customer Service Centers may be monitored to ensure high quality
+service to our customers.
+• Questions on accessibility by persons with disabilities: 1-866-241-6568
+• Cingular Wireless Tax ID # 84-1659970 / Cingular Wireless DUNS # 003548489
+***********************************************************************
+Auto Pay Authorization Agreement - For use only with Auto Pay phone enrollment
+If I enroll, I authorize Cingular Wireless to pay my bill monthly by debiting my
+bank account. I can cancel authorization by notifying Cingular at
+www.cingular.com, by calling 1-800-331-0500, or by dialing 611 from my wireless
+phone. If my bank rejects a payment, I may be charged a return fee.
+How To Pay
+Checking and savings account payments, check cards, credit cards are accepted.
+Payments made with a representative may be subject to a service fee.
+Note: There is no fec for choosing any of the following payment channels:
+Pay using your wireless phone for free
+- Dial *PAY (*729), then hit send.
+- Make a one time payment following the instructions provided.
+Pay using any landline phone - Dial 1-800-331-0500
+- Enter your wireless number and billing ZIP Code and follow the prompts
+- Go to www.cingular.com/
+Pay by Mail
+- Mail your remittance stub and a check or money order in the envelope provided.
+- It may take up to 7 - 10 days for the payment to post.
+DST X280-9900 (10/03)
+
+
+cingular
+Prior Activity
+Previous Balance
+Detail of Payments Posted
+Payment by One-time Payment posted on Sep 25, 2005
+TOTAL BALANCE
+Wireless Line Summary For:
+User Name: MICHAEL DAVIS
+Usage Charges
+(See Usage Charge Details)
+TOTAL USAGE CHARGES
+Credits, Adjustments & Other Charges
+LIQUIDATED DAMAGES - CHARGE
+FED UNIVERSAL SVC CHARGE
+TOTAL CREDITS, ADJUSTMENTS & OTHER CHARGES
+Government Fees and Taxes
+FEDERAL EXCISE TAX
+STATE SALES TAX
+STATE COMMUNICATIONS TAX
+COUNTY SURTAX
+LOCAL COMMUNICATIONS TAX
+TOTAL GOVERNMENT FEES and TAXES
+TOTAL AMOUNT DUE
+Usage Charge Details
+User Name:
+Summary of
+Usage Charges
+/RGNP 600 UMM 5KNW
+Peak
+UNLIMITED EXPANDED M2M-N
+15000 NIGHT/WKND MINS CTH
+Directory Assistance
+Long Distance
+Domestic
+Subtotal
+Minutes
+Included
+In Plan
+600
+5000
+Billing Cycle Date
+Iccount Number
+301505 - 101405
+190.98
+-190.98
+$0.00
+150.00
+0.12
+0.15
+9.00
+0.12
+0.75
+0.27
+$4.50
+$150.12
+$10.59
+$165.21
+-
+Minutes
+Billed
+Used
+Minutes
+263
+148
+390
+Billed
+Rate
+3 Call (s)
+See Call Details
+1.50
+Total
+Charge
+4.50
+$4.50
+
+
+cingular
+Billing Cycle Date:
+Account Number
+4 of 5
+09/15/05 - 10/14/05
+Usage Charge Details (Continued)
+User Name: |
+Summary of
+Wireless Data
+Text Messaging
+- CINGULAR MOBILE TO MOBILE Incoming
+- OTHER MOBILE TO MOBILE Incoming
+Msg/KB
+Included
+In Plan
+Msg/KB
+Used
+Billed
+Msg/KB
+Billed
+Rate
+Subtotal
+TOTAL USAGE CHARGES
+Long Distance Call Detail
+User Name: N
+Rate Code: RSD1=/RGNP 600 UMM 5KNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Feature: 1=PTT One-to-One event: a=Automated Call Retum; B=Direct Asst Call Complete; C=Call Waiting: D=Data Call;
+Item
+Number
+Called
+Day
+Thu
+Fri
+Mon
+Tue
+Wed
+Fri
+10
+11
+12
+13
+14
+15
+16
+Totals
+Sun
+Mon
+Date
+09/15
+09/16
+09/18
+09/19
+09/27
+09/28
+09/29
+09/30
+09/30
+09/30
+10/02
+10/02
+10/03
+10/03
+10/03
+10/03
+Time
+07: 24AM
+07:34PM
+11: 48AM
+11: 45AM
+05:12PM
+03:26PM
+01:42PM
+07:06PM
+08:48PM
+09:17PM
+04: 32PM
+07:26PM
+11:21AM
+03:59PM
+04: 00PM
+09:31PM
+Call To
+DA Call
+NEW YO NY
+NEW YO NY
+NEW YO NY
+DA Call
+NEW
+YO NY
+NEW
+NY
+NEW
+YO NY
+OXNARD CA
+NEW YO NY
+NEW YO NY
+DA Call
+NEW YO NY
+NEW YO NY
+NEW YO NY
+OXNARD CA
+Min
+Rate
+Code
+RSD1
+RSD1
+RSD1
+R8D1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+R8D1
+RSD1
+Rate
+Pd
+Feature
+P
+P
+N
+P
+W
+M
+N
+N
+P
+M
+P
+18
+4.50 4.50
+One Time Checking Account Payment Authorization Agreement (for use with kiosk payment):
+I authorize Cingular Wireless to pay my bill by debiting my bank account. I can cancel
+authorization by contacting an in-store sales person. If my bank rejects a payment.
+I may be charged a return fee.
+Total
+Charge
+$0.00
+$4.50
+LD
+Charge
+DA/Add.
+Charge
+1.50
+1.50
+1.50
+Total
+Charge
+1.50
+1.50
+1.50
+DST X280-9900 (10/03)
+
+
+*cingular
+501505 - 1014005
+Looking for a great job? Check out Cingular!
+ireat pay, excellent benefits, flexible hours, full and part time possible
+/isit Cingular.com, click on Careers, and apply online. EOE AA/M/F/D/
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/11e5f2e645c880c08d72001cc690d96e35a0316871c334249167410e42e188af.receipt.json b/vision-fixhub/ds9-unparsed-06/11e5f2e645c880c08d72001cc690d96e35a0316871c334249167410e42e188af.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..bf2de3b34bde3ab275e0308876e2a8ef85c50143
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/11e5f2e645c880c08d72001cc690d96e35a0316871c334249167410e42e188af.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -280,
+  "dataset": "marble-joined",
+  "doc_id": "11e5f2e645c880c08d72001cc690d96e35a0316871c334249167410e42e188af",
+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "8dcc524879c739d69abd128b9851e5988cb165fecced6db569871e2e70e4a96d",
+  "output_sha256": "26be3d6f840710ecdf59aef5307195ce50c469af7200b7fe3a329327ad9a4186",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/121bc0897d4eb8b495f9877a7ccb1f6c1c2c509f9d155e7f06b91fd6be6b6df6.md b/vision-fixhub/ds9-unparsed-06/121bc0897d4eb8b495f9877a7ccb1f6c1c2c509f9d155e7f06b91fd6be6b6df6.md
new file mode 100644
index 0000000000000000000000000000000000000000..e7a885082bbe0e69fce4b181bb088766304fbe90
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/121bc0897d4eb8b495f9877a7ccb1f6c1c2c509f9d155e7f06b91fd6be6b6df6.md
@@ -0,0 +1,70 @@
+STATE OF FLORIDA
+VS.
+Jeffre, Epsten
+• Defendant.
+IN THE CIRCUIT COURT OF THE FIFTEENTH
+JUDICIAL CIRCUIT IN AND FOR PALM BEACH
+COUNTY, FLORIDA - CRIMINAL DIVISION
+CASEND: 206889381AX14M
+FILED
+Circuit Criminal Department
+Der: 1 8 2009
+SHARON R. BOCK
+Clerk & Comptroller
+Paim Beach County
+THIS MATTER comes before the Cout upon D mots for tove!
+The Court, having been made aware that both counsel have agreed to sald motion..
+Accordingly, it is hereby:
+ORDERED and ADJUDGED hat D" mater is graded under
+reveived.
+DONE and ORDERED in Chambers, West Palm Beach, Palm Beach County,
+Florida, this
+_ day of
+12/18/0
+
+
+IN THE CIRCUIT COURT OF THE FIFTEENTH
+JUDICIAL CIRCUIT, IN AND FOR PALM BEACH
+COUNTY, FLORIDA
+CASE NO. 2008CF009381A
+STATE OF FLORIDA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+MOTION FOR AUTHORIZATION TO TRAVEL
+COMES NOW the Defendant, JEFFREY EPSTEIN, by and through his undersigned
+attorney and moves this Honorable Court to enter an Order authorizing the Defendant's
+travel for business purposes related to ongoing litigation. In support thereof the Defendant
+would state as follows:
+1. The Defendant has been on community control since July 22, 2009.
+2. The Defendant has been in complete compliance with his conditions of
+community control since being placed on supervision.
+3. The Defendant was given permission to travel to New York on December 3, 2009
+for the purposes of meeting with his attorney, Harry Susman.
+4. After being granted permission, the Defendant arranged his travel plans with his
+community control officer,
+and traveled to New York in complete
+compliance with the rules set forth by his community control officer.
+5 The Defendant needs to travel out of state for additional meetings with his
+attoreys to continue to review documents. See letter from Harry Susman attached hereto
+as Exhibit "A".
+6. Given the Defendant's complete compliance with the terms of supervision since
+being placed on community control on July 22, 2009, the Defendant's community control
+
+
+-
+officer
+has no objection to the Defendant being given permission to travel
+for purposes related to his ongoing litigation as long as the dates and times of travel are
+cleared in advance and approved by his community control officer.
+WHEREFORE, the Defendant moves this Honorable Court to enter an Order
+authorizing the Defendant to travel for business purposes related to ongoing litigation as
+long as it is approved in advance by his community control officer.
+1 HEREBY CERTIFY that a copy of the foregoing has been furnished by fax and
+mail to
+Esquire, State Attorney's Office,
+Palm Beach, Florida 33401 and to
+Department of Corrections,
+Lake Worth, Florida 33461, this 16" day of December, 2009.
+OKA GOLDBERGER, ESQ.
+Atferbufy, Goldberger & Weiss, P.A.
diff --git a/vision-fixhub/ds9-unparsed-06/121bc0897d4eb8b495f9877a7ccb1f6c1c2c509f9d155e7f06b91fd6be6b6df6.receipt.json b/vision-fixhub/ds9-unparsed-06/121bc0897d4eb8b495f9877a7ccb1f6c1c2c509f9d155e7f06b91fd6be6b6df6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1894e2c95fead4d928c50fa87a0ddd29ee9f2f0f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/121bc0897d4eb8b495f9877a7ccb1f6c1c2c509f9d155e7f06b91fd6be6b6df6.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "121bc0897d4eb8b495f9877a7ccb1f6c1c2c509f9d155e7f06b91fd6be6b6df6",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3eb8152e93aa35c8c70ee91d3f561d50fd452a766c851260f5ac852a14e89dd7",
+  "output_sha256": "7151f99a56d499dc0038d98131e66d1bdb8a2cc71f4737846959feee029963d9",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/12404df5f88874be1d04fe1e025bd84db3b6b7387845e0181a720c0f4f78703e.md b/vision-fixhub/ds9-unparsed-06/12404df5f88874be1d04fe1e025bd84db3b6b7387845e0181a720c0f4f78703e.md
new file mode 100644
index 0000000000000000000000000000000000000000..ec8023311965850a2b6b4e0c642b8e3db31ae879
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/12404df5f88874be1d04fe1e025bd84db3b6b7387845e0181a720c0f4f78703e.md
@@ -0,0 +1,46 @@
+From:
+To:
+Subject: Activity in Case 9:08-cv-80893-KAM Doe v. Epstein Order on Motion for Hearing
+Date: Tue, 21 Sep 2010 12:47:13 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. Distriet Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 9/21/2010 at 8:47 AM EDT and filed on 9/21/2010
+Case Name:
+Doe v. Epstein
+Case Number:
+9:08-cv-80893-KAM
+Filer:
+WARNING: CASE CLOSED on 07/20/2010
+Document Number: 219
+Docket Text:
+ORDER Denying as Moot [213] Motion for Hearing. Signed by Magistrate Judge Linnea R.
+Johnson on 9/21/2010. (sa)
+9:08-ev-80893-KAM Notice has been electronically mailed to:
+Bradley James Edwards
+Jack Alan Goldberger
+Katherine Warthen Ezell
+Lilly Ann Sanchez
+Michael James Pike
+Paul G. Cassell
+Robert Deweese Critton, Jr
+
+
+9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at
+1:
+The following document(s) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=9/21/2010] [FileNumber=8018675-0
+][0c197d0de14e86d39abbfe87e0798ed03c371454c185aaeb8446fdaaaf75a8ed459
+4ес0eaf6149dbf137b6153aЗ38fd951b8fd44823437d9955fd5аб3d&c&c00]]
diff --git a/vision-fixhub/ds9-unparsed-06/12404df5f88874be1d04fe1e025bd84db3b6b7387845e0181a720c0f4f78703e.receipt.json b/vision-fixhub/ds9-unparsed-06/12404df5f88874be1d04fe1e025bd84db3b6b7387845e0181a720c0f4f78703e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..81302ff411b0a5173e6ebc4a0f731da8b73c6239
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/12404df5f88874be1d04fe1e025bd84db3b6b7387845e0181a720c0f4f78703e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "12404df5f88874be1d04fe1e025bd84db3b6b7387845e0181a720c0f4f78703e",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e399fb5bc0fa07aa5456954389a3b30125a98bac65c854b2f7e55268451c3a21",
+  "output_sha256": "0c223f77d1eef33cf8f92353e83c60acc3b857a51704a985a604ed7aa247b257",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/12ac1a44f34aaa83ebedf095c8c655dbde1e8aed39e63514555236d5feea1641.md b/vision-fixhub/ds9-unparsed-06/12ac1a44f34aaa83ebedf095c8c655dbde1e8aed39e63514555236d5feea1641.md
new file mode 100644
index 0000000000000000000000000000000000000000..ed0085b0b9ce541d05208830df4a2092815bbd18
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/12ac1a44f34aaa83ebedf095c8c655dbde1e8aed39e63514555236d5feea1641.md
@@ -0,0 +1,55 @@
+From: "
+I (USAFLS)"
+</O=USA/OU=FLS/CN=RECIPIENTS/CN=L
+To: "1
+<
+Subject: RE: Epstein Matter
+Date: Mon, 12 Feb 2007 20:42:51 +0000
+Importance Normal
+Thank you,
+Assistant U.S. Attorney
+From:
+[mailto:/
+Sent: Monday, February 12, 2007 1:45 PM
+To:
+I. (USAFLS)
+Subject: Re: Epstein Matter
+i received your email. i will speak to L
+hope you are well.
+regards
+, Esq.
+FOWLER WHITE BURNETT P.A.
+Espirito Santo Plaza, 14th Floor
+] and get back to you shortly on both items.
+>>>
+| (USAFLS)" <
+> 2/12/2007 12:24 PM >>>
+- Please let
+know that I took his comments to heart and I am re-reviewing all of the tapes. I noticed that he had
+transcripts of at least some of the tapes. Any chance you would be willing to share those with me? It would make the review oh so much
+quicker.
+And, could you send me the list of the lawyers who represent current or former employees? Before you ask, Rule 6(e) requires that I
+keep matters before the grand jury secret, so I cannot tell you who or what I am subpoenaing. If the subpoenaed party (or his/her
+attorney) decides to disclose that information to you, that is his/her prerogative, but I can't do it.
+Thank you very much.
+Assistant U.S. Attorney
+
+
+**TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance
+with requirements imposed by the IRS, we inform you that any tax
+advice contained in this communication (including attachments) was
+not intended or written to be used,
+and cannot be used, for the
+purpose of (i) avoiding penalties under the Internal Revenue Code
+or (ii) promoting, marketing or recommending to another party any
+transaction or matter addressed herein. If you would like such advice,
+Please contact us.***
+***Attention: The information contained in this E-mail message
+is attorney privileged and confidential information intended only
+for the use of the individual(s) named above. If the reader of
+message is not the intended recipient, you are hereby notified that any
+dissemination, distribution or copy of this communication is strictly
+prohibited. If you have received this communication in error, please
+contact the sender by reply E-mail and
+destroy all copies of the original
+message. Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/12ac1a44f34aaa83ebedf095c8c655dbde1e8aed39e63514555236d5feea1641.receipt.json b/vision-fixhub/ds9-unparsed-06/12ac1a44f34aaa83ebedf095c8c655dbde1e8aed39e63514555236d5feea1641.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3fae0ad4337e4a524d74f2944bba3e91a5516cef
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/12ac1a44f34aaa83ebedf095c8c655dbde1e8aed39e63514555236d5feea1641.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "12ac1a44f34aaa83ebedf095c8c655dbde1e8aed39e63514555236d5feea1641",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "c262ad6af9c43918c3d1e6d7556c3ef560f6373ae9525fb000f4ad6d4dd82568",
+  "output_sha256": "1126b191b5822d3a283f6714e6f8c0f9e71e9821f8af5f48871f81189339b4ca",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/12cd17f899ac7250cad66841c57f72631b030c96ba5f3993b337d5f79b0b7b62.md b/vision-fixhub/ds9-unparsed-06/12cd17f899ac7250cad66841c57f72631b030c96ba5f3993b337d5f79b0b7b62.md
new file mode 100644
index 0000000000000000000000000000000000000000..64830d15d7ee4ed4e45546f1d067f6f7ad7bbca6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/12cd17f899ac7250cad66841c57f72631b030c96ba5f3993b337d5f79b0b7b62.md
@@ -0,0 +1,138 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOES #1 and #2
+v.
+UNITED STATES
+JANE DOE #1 AND JANE DOE #2'S STATUS REPORT AND RESPONSE TO
+COURT'S ORDER TO SHOW LACK OF PROSEUCTION
+Jane Doe #1 and Jane Doe #2 (*the victims"), through counsel, file the response to
+Court's order to file a status report and show cause regarding prosecution of the case (doc. #40).
+BACKGROUND
+As the Court is aware, it entered an order administratively closing this case on September
+9, 2010 (doc. #38). That order recited that fact that Jane Doe #1 and Jane Doe #2 had recently
+settled their civil cases with Jeffrey Epstein as the basis for closure. On September 13, 2010, the
+victims promptly filed a notice that, while they had settled their case with Jeffrey Epstein, they
+had reached no settlement with the U.S. Attorney's Office and intended to make filings in this
+case shortly (doc. #39). The victims requested administrative reopening of the case and, if the
+Court deemed it advisable, a prompt scheduling conference with the U.S. Attorney's Office
+regarding the case. The victims also advised that they had only recently received important
+correspondence between the U.S. Attorney's Office and the Epstein proving that there had been
+an orchestrated decision to deny them their rights.
+On October 8, 2010, the Court entered an order directing the victims to file a status report
+and show cause why the case should not be dismissed for want of prosecution.
+1
+
+
+STATUS REPORT
+As the Court is aware from the victims' filing on September 13, 2010 (doc. #39, the
+victims have now received important evidence that allows them to file a comprehensive motion
+explaining the factual background underlying the denials of their rights under the Crime Victims
+Rights Act and the legal reasons for concluding that their rights under the Act have been
+violated. A full motion to that effect is being filed simultaneously with this pleading. The
+motion looks something like a summary judgment motion, although the exact procedures for
+CVRA cases are unclear. The victims stand ready to promptly provide whatever pleading or
+motion the Court believes is appropriate to resolve this case quickly. The victims' motion also
+asks for an evidentiary hearing if the facts are disputed by the U.S. Attorney's Office. Before
+filing the motion, the victims had also sent a copy of the facts to the U.S. Attorney's Office in an
+effort to obtain their agreement to them and to expedite the case. (As the Court is aware from the
+victims' earlier filing, the victims attempted to negotiate a stipulated set of facts with the U.S.
+Attorney's Office, only to be rebuffed by the U.S. Attorney's Office. See doc. #17 (U.S.
+Attorney giving "notice" that only two facts are relevant to this case and declining to provide
+information on other facts in the case); doc. #19 (victims response); doc. #22 (U.S. Attorney's
+reply).) Discussions with the U.S. Attorney's Office to reach a stipulated set of facts are
+continuing.
+In light of today's filing of a comprehensive motion, the victims would propose the
+following schedule for bringing this case to a conclusion:
+November 10, 2010 - U.S. Attorney's Office files response to the victims' motion.
+November 17, 29010 - Victims' file Reply to Response.
+Evidentiary Hearing (if facts contested) - early December, at a time convenient to the Court.
+January 1, 2011 - Court issues ruling on whether victims' rights were violated.
+If the Court enters a finding that the victims rights were violated, then ....
+January 14, 2011 - Victims brief on the appropriate remedy for a violation;
+2
+
+
+January 28, 2011 -- U.S. Attorney's Office (and any other interested person) files response to
+victims' remedy brief.
+February 4, 2011 - Victims reply on remedy issues.
+Hearing if necessary - mid-February, at a time convenient to the Court.
+This proposed schedule would allow Jane Doe #1 and Jane Doe #2 to have their case
+fully resolved on the merits within the next few months. The victims would have no objection to
+the Court accelerating the schedule. The victims have also submitted this proposed schedule to
+the U.S. Attorney's Office in an effort to reach a stipulated and accelerated schedule.
+THE CASE SHOULD NOT BE DISMISSED FOR LACK OF PROSECUTION
+Jane Doe #1 and Jane Doe #2 should not have their case dismissed for lack of prosecution
+for the simple reason that they have not failed to prosecute it. To the contrary, as recounted more
+fully in the statement of facts contained in their contemporaneously filed motion for a finding of
+violation of their rights, they have been attempting to secure information that would help prove
+their case. The victims hereby expressly incorporate that statement of facts, and supporting
+evidence (particularly the Declaration from Bradley J. Edwards, Esq.,) as part of this pleading.
+Although the victims rely on all of the information contained in the statement of facts, in
+the interest of a brief summary the victims would note that they have been diligently attempting
+to secure correspondence between Epstein and the U.S. Attorney's Office regarding the nonprosecution agreement reached in this case. After the U.S. Attorney's Office declined to provide
+the information, the victims sought to secure that information as part of their civil lawsuits
+against Epstein. This was because of a reasonable legal judgment that the victims' counsel that it
+was in their best interest to pursue the civil lawsuit against Epstein had a faster pace. Because of
+protracted litigation from Epstein's battery of lawyers, the vietims did not secure any of the
+correspondence they sought until June 30, 2010. Even then, they secured only part of that
+correspondence - litigation to secure the rest of that correspondence continues to this day. See
+3
+
+
+Declaration of Bradley J. Edwards, Esq., Attachment to Jane Doe #1 and Jane Doe #2's Motion
+for Finding of Violations of the Crime Victims' Rights Act.
+The victims would also note that the Court has never advised them of a deadline for
+moving forward with their CVRA case. The victims also knew that the Court was aware of the
+intense and protracted litigation what was proceeding with Epstein in the various civil cases
+against him. It seemed reasonable to the victim to resolve those cases first and then turn to the
+CVRA case - and the victims assumed that the Court was also proceeding on this approach, as
+the victims never received any inquiry from the Court about their CVRA case until the
+September 2010 order "administratively" closing the case. Within 5 days of receiving that
+communication from the Court, the victims promptly advised the Court of their intent to continue
+moving forward with the case and suggesting a scheduling conference if the Court deemed it
+advisable.
+The victims have now proposed a specific schedule that will bring this matter to a final
+conclusion in the next few months. There is no reason to dismiss the case precipitously now on
+the eve of a final resolution.
+The Eleventh Circuit has repeatedly noted that dismissal with prejudice is an "extreme
+sanction" and "is plainly improper unless and until the district court finds a clear record of delay
+or willful conduct and that lesser sanctions are inadequate to correct such conduct." Betty K
+Agencies, Ltd. v. M/V MONADA, 432 F.3d 1333, 1338-39 (11th Cir.2005). In this case, there is
+no clear record of delay or willful conduct. To the contrary, there is a pattern of the victims
+diligently attempting to secure evidence (i.e., the correspondence) vital to their case in the face of
+determined opposition from both the United States and a billionaire sex offender represented by
+a battery of attorneys.
+The Eleventh Circuit has held that simple negligence in meeting a court-
+4
+
+
+imposed deadline is not sufficient to warrant dismissal. See McKelvey |. AT & T Techs., Inc., 789
+F.2d 1518, 1520 (11th Cir.1986) (per curiam). Here, there is not even negligence, as the victims
+have not failed to meet any deadline that the Court has set and today stand ready to bring the
+case to an expeditious conclusion on the schedule they propose. On September 13, 2010, the
+victims also suggested to the Court that a scheduling conference would be one way to proceed in
+this case - a suggestion that they continue to offer to the Court.
+CONCLUSION
+The Court should establish the schedule proposed by the victims and bring this case to a
+conclusion on the merits as the victims propose.
+DATED: October 27, 2010
+Respectfully Submitted,
+s/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+Fort Lauderdale, Florida 33301
+and
+Paul G. Cassell
+Pro Hac Vice
+Salt Lake City, UT 84112
+5
+
+
+Attorneys for Jane Doe #1 and Jane Doe #2
+
+
+CERTIFICATE OF SERVICE
+Epstein through current counsel.
+7
diff --git a/vision-fixhub/ds9-unparsed-06/12cd17f899ac7250cad66841c57f72631b030c96ba5f3993b337d5f79b0b7b62.receipt.json b/vision-fixhub/ds9-unparsed-06/12cd17f899ac7250cad66841c57f72631b030c96ba5f3993b337d5f79b0b7b62.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0edff3386b18aa855974e94632841ff2f5b99711
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/12cd17f899ac7250cad66841c57f72631b030c96ba5f3993b337d5f79b0b7b62.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -86,
+  "dataset": "marble-joined",
+  "doc_id": "12cd17f899ac7250cad66841c57f72631b030c96ba5f3993b337d5f79b0b7b62",
+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "d9034815022015e6d65922c906ac82eec4e86f1724066e13b5eb5e77859ab0c2",
+  "output_sha256": "bf21b4d7f6f63472efe6d0ddc35e06199ead2e3eb7f753628d38b3acaca6d3eb",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/12f0bc8ee21da6d20a38e401007f2bff461e1659765b774e8b1bf22f7b887c93.md b/vision-fixhub/ds9-unparsed-06/12f0bc8ee21da6d20a38e401007f2bff461e1659765b774e8b1bf22f7b887c93.md
new file mode 100644
index 0000000000000000000000000000000000000000..f9de872683fcd07afbeaaab4044e95d323513299
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/12f0bc8ee21da6d20a38e401007f2bff461e1659765b774e8b1bf22f7b887c93.md
@@ -0,0 +1,62 @@
+ROY BLACK
+HOWARD M. SREBNICK
+SCOTT A. KORNSPAN
+LARRY A. STUMPF
+MARIA NEYRA
+JACKIE PERCZEK
+MARK A.J. SHAPIRO
+JARED LOPEZ
+BLACK
+SREBNICK
+KORNSPAN
+& STUMPF
+: P.A.
+JENIPER J. SOAH FOX
+E-Mail: RBlack@RoyBlack.com
+January 20, 2010
+RE: Jeffrey Epstein
+Dear Marie:
+We are now facing a difficult issue about the attorney's fees in the civil cases
+brought against Mr. Epstein related to your prior criminal investigation. I
+broached this subject with you on the phone a couple of weeks ago, but I could
+see our discussion was not fruitful at that time. Since we could not come to any
+agreement on how to handle this, we must proceed ahead based on our
+understanding of the non-prosecution agreement.
+Mr. Epstein has paid the attorney representative $526,000 and accepts his
+obligation under the NPA to pay additional reasonable legal fees that precede
+litigation claims under 97C of the Addendum. However we believe that the
+request by the attorney representative for over $1.5M additional fees is both
+unreasonable and outside the Addendum's criteria for payment.
+Litigation may ensue since we have been unable to resolve these matters
+through an agreement. We never contemplated that the legal fee agreement would
+result in a bill for $2.1M when the Addendum was entered. We understand you
+and Jay had different views on whether an attorney representative could both sue
+Epstein for some clients and remain as counsel to settle other cases. We believe
+that the attorney representative could either settle the cases and be paid hourly
+or litigate and be paid out of the judgment, but not both. The language of the NPA
+is in need of legal construction regarding whether Epstein's obligations end when
+201 S. Biscayne Boulevard, Suite 1300 • Miami. Florida 3313l • Phone: 305-371-6421 • Fax: 305-358-2006 • www.RoyBlack.com
+
+
+the attorney representative brings a lawsuit for any of his clients - a matter that
+a court should settle free from any consideration that initiating litigation to resolve
+this outstanding issue would be perceived as a breach.
+Just to be sure, Mr. Epstein will pay whatever fees a court determines are
+owed and we only want assurance that litigating the legal and factual issues over
+such liability will be consistent with and not violate the NPA. We don't think it is
+the government's position that Epstein must simply pay any bill he receives,
+regardless of the amount and type of work done, particularly one for $2. 1M. So we
+have no alternative but to go to court to resolve this issue. We are sending you
+this letter because the attorney representative is using the threat of a breach as
+leverage to get his fees. I don't believe the government's power to indict and
+incarcerate should be used to assist a private lawyer in collecting an exorbitant
+legal fee. Thus we are putting you on notice, and asking that if you disagree with
+our legal opinion that a suit is not in conflict with the NPA, to tell us without
+delay.
+Cordially yours,
+Martin G. Weinberg, Esq.
+Robert D. Critton, Jr.
+Roy Black,
+By:
+MW:RC:RB/wg
+Black, Srebnick, Kornspan & Stumpf. P.A.
diff --git a/vision-fixhub/ds9-unparsed-06/12f0bc8ee21da6d20a38e401007f2bff461e1659765b774e8b1bf22f7b887c93.receipt.json b/vision-fixhub/ds9-unparsed-06/12f0bc8ee21da6d20a38e401007f2bff461e1659765b774e8b1bf22f7b887c93.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3412281f238dff678e4579644f6c73f8de3679eb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/12f0bc8ee21da6d20a38e401007f2bff461e1659765b774e8b1bf22f7b887c93.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "12f0bc8ee21da6d20a38e401007f2bff461e1659765b774e8b1bf22f7b887c93",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e8b0c0b5e20d42a9ae5af4a397fdfdc7ebcba217a427c1ed27e8faf86d29eb9b",
+  "output_sha256": "b8c1956cac7365a0d685aaaa77649d52395c0b965cce12b5770b6d159792572e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/132c6ca4a73b65fdf956ae980a376db433d02f93862c76127c8ebdb28fec5c3b.md b/vision-fixhub/ds9-unparsed-06/132c6ca4a73b65fdf956ae980a376db433d02f93862c76127c8ebdb28fec5c3b.md
new file mode 100644
index 0000000000000000000000000000000000000000..1e2ab471c52eede98f458fb38d7125b1cfa673c9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/132c6ca4a73b65fdf956ae980a376db433d02f93862c76127c8ebdb28fec5c3b.md
@@ -0,0 +1,38 @@
+From:
+(USAFLS)"
+</0=USA/OU=FLS/CN=RECIPIENTS/CN=
+To: "
+Cc:
+(USAFLS)" <SBall@usa.doj.gov»
+Subject: RE: Representation of Financial Trust Company, Inc., J. Epstein & Company, Inc., and other
+corporate entities
+Date: Fri, 01 Jun 2007 00:26:17 +0000
+Importance: Normal
+Hi
+- Sorry. I was out and then I had to start trial. You will receive them tomorrow. Thank you again.
+Assistant U.S. Attorney
+From:
+[mailto:
+Sent: Thursday, May 31, 2007 11:56 AM
+To:
+1. (USAFLS)
+Subject: RE: Representation of Financial Trust Company, Inc., 1. Epstein & Company, Inc, and other corporate entities
+Subject: RE: Representation of Financial Trust Company, Inc., J. Epstein & Company, Inc., and other corporate entities
+Marie, when we spoke last Thursday I agreed to accept service of a subpoena (without promising I would represent
+Financial Trust depending on what was being requested) that I think you said you would fax. This is just to let you know
+that I never received any fax to that end - just in case it was sent somewhere else in error.
+Gerald B. Lefcourt, P.C.
+From: |
+I. (USAFLS) [mailto:Ann.Marie.C.Villafana@usdoj.gov]
+Sent: Tuesday, May 22, 2007 7:14 PM
+To:
+Subject: Representation of Financial Trust Company, Inc., J. Epstein & Company, Inc., and other corporate entities
+Dear
+: I noticed that, at least as of July 2005, you have served as counsel to Financial Trust Company, Inc.
+in connection with litigation. Can you let me know if you still represent Financial Trust Company, Inc., and if
+you represent J. Epstein & Company, Inc., J. Epstein Virgin Islands Foundation, Inc., and/or Epstein Interests?
+If you represent any or all of those entities, are you willing to accept service of subpoenas via fax?
+Thank you for your assistance.
+
+
+Assistant U.S. Attorney
diff --git a/vision-fixhub/ds9-unparsed-06/132c6ca4a73b65fdf956ae980a376db433d02f93862c76127c8ebdb28fec5c3b.receipt.json b/vision-fixhub/ds9-unparsed-06/132c6ca4a73b65fdf956ae980a376db433d02f93862c76127c8ebdb28fec5c3b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a79bc0b0ee4d8f3c10810aeb586f8f59be3cae99
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/132c6ca4a73b65fdf956ae980a376db433d02f93862c76127c8ebdb28fec5c3b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "132c6ca4a73b65fdf956ae980a376db433d02f93862c76127c8ebdb28fec5c3b",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "0d1fd3a52c5756da55673825d59c7671898c8e8bcce9ccad71237aaf8d6d8ed5",
+  "output_sha256": "c8c0d72e60852295cd7b2ef9ee315e94c44676d0457f208ddc3bc69579f5b377",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1356c03f7332d6141fbf6367a2b509041ee6654fe47a82c2ac7f767ba2e4417d.md b/vision-fixhub/ds9-unparsed-06/1356c03f7332d6141fbf6367a2b509041ee6654fe47a82c2ac7f767ba2e4417d.md
new file mode 100644
index 0000000000000000000000000000000000000000..500d391e8356879ec48194bdbbe3ed386adde96e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1356c03f7332d6141fbf6367a2b509041ee6654fe47a82c2ac7f767ba2e4417d.md
@@ -0,0 +1,59 @@
+From: Paul Cassell <
+To: "
+Cc:
+(USAFLS)" <
+(USAFLS) (
+Subject: RE: Doe | USAO
+Date: Tue, 15 Nov 2011 00:34:11 +0000
+Importance: Normal
+P, Brad Edwards
+Hey
+and
+1. As you may know, Brad is buried in a three-week jury trial, so I have not been able to consult with him at any
+as gong-sole died vacatiom the we do Thank go sing. In ligh a allis, Tami dung to hing lie aboday, as well
+Government's position concerning a ten-day extension of the due date to respond to the motion to dismiss until
+December 5.
+2. I noticed that you have filed two pleadings entirely under seal - your motion to dismiss and your motion to
+stay. And yet the vast bulk of both motions do not involve any secret grand jury material and thus (in my view)
+there is little reason for the vast bulk of the pleadings to be under seal. Are you willing to file redacted pleadings
+in the public court file?
+3. If the answer to question 2 is no, what is your position on a motion from the victims asking for the court to
+direct the Government to file redacted pleadings in the public court file, redacting only the secret grand jury
+information?
+4. It is our view that a bland motion for extension of time would not need to be filed under seal, because it would
+not disclose any grand jury materials. Here is the draft of our motion for extension of time, which we are not
+planning to file under seal. Please advise if you have any concerns.
+JANE DOE #1 AND JANE DOE #2'S UNOPPOSED MOTION FOR 10-DAY EXTENSION OF TIME TO
+RESPONSE TO GOVERNMENT'S MOTION TO DISMISS AND MOTION FOR STAY OF DISCOVERY
+COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned
+counsel, to file an unopposed motion for extension of time to respond to the Government's motion to dismiss and
+motion to stay proceedings.
+The victims' response to these two motions is currently due on Friday, November 25, 2011 - the Friday
+immediately following Thanksgiving. One of the victims' counsel, Bradley J. Edwards, has been in (and
+continues to be in) a three-week jury trial that has prevented him from turning to the pending motion. The other
+of the victims' counsel, Paul G. Cassell, has a brief due in the Fifth Circuit on November 23, 2011, and also longscheduled vacation the week of Thanksgiving. Accordingly, victims counsel seek a 10-day extension to Monday,
+December 5, 2011, to file their responses to the Government's two pending motions.
+Counsel have conferred and the Government does not oppose the motion.
+5. I notice in the court file that the Court entered two orders on November 9, 2011. These are sealed orders and
+we have not received notice of the orders. We are assuming that these are court orders granting your motion to
+file under seal. If they are something else, we would of course be concerned about ex parte motion practice. If
+they are granting the motions to file under seal, I wonder why we didn't consult about the extent of the sealing on
+the phone last week -- it does seem like the Government has gone overboard on sealing here, but I am hopeful
+that you will agree to filing redacted pleadings and obviate any problem.
+Thanks for your help on these questions/issues.
+Paul Casssell
+Co-Counsel for Jane Doe #1 and Jane Doe #2
+
+
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+S.J. Quinney College of Law at the University of Utah
+Voice:
+Fax:
+Email:
+http://www.law.utah.edu/profiles/default.asp?PersonID=57&name=Cassell,Paul
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is
+intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver
+it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have
+received this message in error, please immediately notify the sender by reply electronic mail and delete the
+original message. Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/1356c03f7332d6141fbf6367a2b509041ee6654fe47a82c2ac7f767ba2e4417d.receipt.json b/vision-fixhub/ds9-unparsed-06/1356c03f7332d6141fbf6367a2b509041ee6654fe47a82c2ac7f767ba2e4417d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..27f56b877083760d919dd1b27e78467c75083c66
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1356c03f7332d6141fbf6367a2b509041ee6654fe47a82c2ac7f767ba2e4417d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -26,
+  "dataset": "marble-joined",
+  "doc_id": "1356c03f7332d6141fbf6367a2b509041ee6654fe47a82c2ac7f767ba2e4417d",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "6fa9de3220796f47bd2ff6410d9227fe8866c53a166b90b6df8b235feb9e849d",
+  "output_sha256": "f9942303f364efec396f0e92d67d9b959c154d62e3943e553f501021f072694a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/13b1c2ae09242c1b00bc82e47c154d5cad8cf9d043d37359472447d7a9a2435a.md b/vision-fixhub/ds9-unparsed-06/13b1c2ae09242c1b00bc82e47c154d5cad8cf9d043d37359472447d7a9a2435a.md
new file mode 100644
index 0000000000000000000000000000000000000000..d0b25a12d3a62cee77b3920b7e95706fa361a1fe
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/13b1c2ae09242c1b00bc82e47c154d5cad8cf9d043d37359472447d7a9a2435a.md
@@ -0,0 +1,71 @@
+From:
+To:
+Subject: Activity in Case 9:08-cv-80119-KAM Doe I. Epstein Motion for Sanctions
+Date: Mon, 04 Jan 2010 19:23:49 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. Distriet Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Horowitz, Adam on 1/4/2010 at 2:23 PM EST and filed on 1/4/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 444
+Doe | Epstein
+9:08-cv-80119-KAM
+Jane Doe
+Docket Text:
+Plaintiff's MOTION for Sanctions, MOTION for Protective Order and Incorporated Memorandum
+of Law by Jane Doe. (Attachments: # (1) Exhibit A, # (2) Exhibit B)(Horowitz, Adam)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+ahorowitz@sexabuseattorney.com
+Bradley James Edwards
+Isidro Manuel Garcia
+isid
+Jack Alan Goldberger
+jag
+Jack Patrick Hill jph@sea
+sas@searcylaw.com, vat@so
+Jeffrey Mare Herman
+jher
+Katherine Warthen Ezell
+Michael James Pike MPil
+
+
+Paul G. Cassell
+ca
+Richard Horace Will
+Robert C. Josefsberg
+mestrada@podhurst.
+Robert Deweese Cri
+Start S Mermelstei
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+Martin G. Weinberg
+The following document(s) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=1/4/2010] [FileNumber=7115350-0]
+[7db6567bab81e30cбеb2aa7aa4b2572514d172b9eaбefadbfe587aa56656b4dbea18
+e9bbd3e4679a9da36e8de68a36ab6d976115ba3773817499a676bc2f0d61]]
+Document description: Exhibit A
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=1/4/2010] [FileNumber=7115350-1]
+[6582f54eebfa137fb547feaf45a773464d1d0b0a7cffa01bc60429fdd4bbb8437703
+cff8e2ac11e3a305d4e30c9686f123155945170548f8cf4652bdbb38bf92]]
+Document description:Exhibit B
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=1/4/2010] [FileNumber=7115350-2]
+[2dЬ00248f6f36c09cdb1ef326430655a59fc276bfe76cff796c8308792a21f40d6c4
+e86баf3bd05268fc69670555c86105d6bbfld7db920e18cf4c472475d9fe]]
diff --git a/vision-fixhub/ds9-unparsed-06/13b1c2ae09242c1b00bc82e47c154d5cad8cf9d043d37359472447d7a9a2435a.receipt.json b/vision-fixhub/ds9-unparsed-06/13b1c2ae09242c1b00bc82e47c154d5cad8cf9d043d37359472447d7a9a2435a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..fb0ebb9ee1e51748a9cf647a9a5019002edf2556
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/13b1c2ae09242c1b00bc82e47c154d5cad8cf9d043d37359472447d7a9a2435a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "13b1c2ae09242c1b00bc82e47c154d5cad8cf9d043d37359472447d7a9a2435a",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "6e3166cccdd4560207fa8d94d22769def11758818cedc8cfcac2f790d50146fa",
+  "output_sha256": "defbf2d7e80df386c2fbe6f8e3cfab339bb4519e4f7e0c2475b7093c0fd82fec",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/144cdb4d8fd912e424d232e424f84d472fb916aa4760e5d79c9982982de7b496.md b/vision-fixhub/ds9-unparsed-06/144cdb4d8fd912e424d232e424f84d472fb916aa4760e5d79c9982982de7b496.md
new file mode 100644
index 0000000000000000000000000000000000000000..18396765e3d8c06dac331a2be0f2d02f30e8d062
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/144cdb4d8fd912e424d232e424f84d472fb916aa4760e5d79c9982982de7b496.md
@@ -0,0 +1,10 @@
+From
+To: "James L. Eisenberg (bigjimlaw@aol.com)" <bigjimlaw@aol.com>
+Subject: Writter Proffer
+Date: Tue, 13 Feb 2007 18:28:17 +0000
+Importance: Normal
+Hi Jim — I haven't received your written proffer of
+Thank you.
+Assistant U.S. Attorney
+561 209-1047
+likely testimony. Have you sent it already?
diff --git a/vision-fixhub/ds9-unparsed-06/144cdb4d8fd912e424d232e424f84d472fb916aa4760e5d79c9982982de7b496.receipt.json b/vision-fixhub/ds9-unparsed-06/144cdb4d8fd912e424d232e424f84d472fb916aa4760e5d79c9982982de7b496.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d804da4e83a8173af848271710b711fc389bb549
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/144cdb4d8fd912e424d232e424f84d472fb916aa4760e5d79c9982982de7b496.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "144cdb4d8fd912e424d232e424f84d472fb916aa4760e5d79c9982982de7b496",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e39d96a42f786af517bed35e1df32820633ba98a66ecbfb59711911ee86789b6",
+  "output_sha256": "78bbe8ff59fdbb0e8f70df1497d28803fea1c6d21ed7c642cd7cd8ede9b228af",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/145a9c30cdb024807ce1ac0aaa06897c7934c8b03c98b0ddbc6ac6a8e5643fde.md b/vision-fixhub/ds9-unparsed-06/145a9c30cdb024807ce1ac0aaa06897c7934c8b03c98b0ddbc6ac6a8e5643fde.md
new file mode 100644
index 0000000000000000000000000000000000000000..087c8e18da3389d685823c8e1f6ae0b4473957e4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/145a9c30cdb024807ce1ac0aaa06897c7934c8b03c98b0ddbc6ac6a8e5643fde.md
@@ -0,0 +1,13 @@
+To: Amy Ederi •
+Subject: Epstein Hearing
+Date: Fri, 12 Aug 2011 22:42:23 +0000
+Importance: Normal
+"KATHERINE W. EZELL"
+Hi everyone - I wanted to let you know that we left today's hearing with no decisions. If I were a betting person,
+I would bet that Judge Marra is going to allow the plaintiffs to seek discovery and that we will be having an
+evidentiary hearing a few months from now.
+On another note, I just heard that I received an interview for one of the magistrate positions. The interviews are
+going to occur on the 24* and 27th
+', so keep your fingers crossed on that note, too.
+I will keep you all posted.
+Thank you!
diff --git a/vision-fixhub/ds9-unparsed-06/145a9c30cdb024807ce1ac0aaa06897c7934c8b03c98b0ddbc6ac6a8e5643fde.receipt.json b/vision-fixhub/ds9-unparsed-06/145a9c30cdb024807ce1ac0aaa06897c7934c8b03c98b0ddbc6ac6a8e5643fde.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..647a5244803e69f9d28a42e51023683a28a52558
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/145a9c30cdb024807ce1ac0aaa06897c7934c8b03c98b0ddbc6ac6a8e5643fde.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "145a9c30cdb024807ce1ac0aaa06897c7934c8b03c98b0ddbc6ac6a8e5643fde",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "1d71f2cb7b2bce21c77a4f8e9819cd2e5541cc718832ca0d12f9f125988736bf",
+  "output_sha256": "4f08953483285d39004b42da037709983bfcd8b481e0de37c8d982f70c673090",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/148799968ea11c268519e6c83a59998b06f72a2f99d23b39a6d46cee27acb2cf.md b/vision-fixhub/ds9-unparsed-06/148799968ea11c268519e6c83a59998b06f72a2f99d23b39a6d46cee27acb2cf.md
new file mode 100644
index 0000000000000000000000000000000000000000..a0e04136f1434268232b364dba1b9f820625ff92
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/148799968ea11c268519e6c83a59998b06f72a2f99d23b39a6d46cee27acb2cf.md
@@ -0,0 +1,49 @@
+From:
+To: "
+(USAFLS)"
+</0=USA/OU=FLS/CN=RECIPIENTS/CN-|
+(USAFLS)" <
+Subject: RE: JE -- letter
+Date: Thu, 02 Aug 2007 18:06:14 +0000
+Importance: Normal
+(USAFLS)"
+(USAFLS)" 4
+Do you want to do a conference call? And has a meeting with
+been set up yet?
+Thanks.
+Assistant U.S. Attorney
+--Original Message-
+From:
+(USAFLS)
+Sent: Thursday, August 02, 2007 12:56 PM
+To: I
+(USAFLS):
+Subject: FW: JE -- letter
+FYI
+-----Original Message--
+From:
+[mailto:
+Sent: Thursday, August 02, 2007 12:38 PM
+(USAFLS)
+Ce:
+Subject: JE -- letter
+1- please see attached and confirm receipt.
+i am also having letter hand-delivered to you and M
+regards
+• (USAFLS); •
+(USAFLS)
+Esq.
+FOWLER WHITE BURNETT P.A.
+Espirito Santo Plaza, 14th Floor
+**TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS,
+we inform you that any tax advice contained in this communication (including attachments) was not intended or
+written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code
+or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you
+would like such advice, please contact us.***
+
+
+***Attention: The information contained in this E-mail message is attorney privileged and confidential
+information intended only for the use of the individual(s) named above. If the reader of this message is not the
+intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is
+strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail
+and destroy all copies of the original message. Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/148799968ea11c268519e6c83a59998b06f72a2f99d23b39a6d46cee27acb2cf.receipt.json b/vision-fixhub/ds9-unparsed-06/148799968ea11c268519e6c83a59998b06f72a2f99d23b39a6d46cee27acb2cf.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..850801a922f89e1d0937583e348d13c9ed0b785f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/148799968ea11c268519e6c83a59998b06f72a2f99d23b39a6d46cee27acb2cf.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "148799968ea11c268519e6c83a59998b06f72a2f99d23b39a6d46cee27acb2cf",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "bce5fe781ccb406395ee808a5152fdc1d609f2f5ea0392e57d32c587bad5e11a",
+  "output_sha256": "c6d91e39c63ac7ef8e3e30b1af23ff4672e5e8e9e946491254364462433abf51",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/148873f94863ea63c0c2e186fbf546e23771dd1f87ee91d8f0250a0795d23cc9.md b/vision-fixhub/ds9-unparsed-06/148873f94863ea63c0c2e186fbf546e23771dd1f87ee91d8f0250a0795d23cc9.md
new file mode 100644
index 0000000000000000000000000000000000000000..2357ad97f9350034af48f5f47328c8ce49bf6c91
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/148873f94863ea63c0c2e186fbf546e23771dd1f87ee91d8f0250a0795d23cc9.md
@@ -0,0 +1,58 @@
+From: "
+To: "Roy Black" < RBlack@royblack.com>
+Bcc:
+Subject: RE: Epstein
+Date: Mon, 24 Jun 2013 14:29:33 +0000
+Importance: Normal
+Hi Roy -- I called your office too late on Friday and I didn't want to bother you over the weekend. If I remember
+correctly, you are in Montana, so whenever it is a good time for you, please give me a ring. I am on page 15 of
+your motion to stay right now.
+Hope you are well.
+Assistant U.S. Attorney
+Southern District of Florida
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+ann.marie.c.villafana@usdoj.gov
+561-209-1047
+•---Original Message--.--
+From: Roy Black [mailto:RBlack@royblack.com|
+Sent: Thursday, June 20, 2013 10:13 AM
+Tol
+Subject: RE: Epstein
+Thanks
+Thanks Roy
+• I talked to dexter a few minutes ago. I was just concerned you might file the plea materials right
+away and he said that wouldn't happen. We will send you our proposed motion to stay to get your position on it.
+-----Original Message----.
+From:
+_USAFLS) [mailto:_
+Sent: Thursday, June 20, 2013 10:11 AM
+To: Roy Black
+Subject: Re: Epstein
+Hi Roy: I have been in debriefings so our team hasn't had a chance to meet yet. I will give you a call to advise as
+soon as we do. Thank you.
+Assistant US Attorney
+Sent from my iPhone
+On Jun 20, 2013, at 9:57 AM, "Roy Black" <RBlack@royblack.com<mailto:RBlack@royblack.com>> wrote:
+I left a message with you yesterday about Judge Marra's orders entered on Tuesday. I need to know when
+or if you intend to file the plea bargain materials because we are going to file for a stay of the order per rule 410
+etc. Please let me know the government's position on the materials. Also let me know if the government will
+oppose or not our request for a stay. Thank you Roy
+
+
+Roy Black, Esq.
+www.royblack.com<http://www.royblack.com>
+Black Srebnick Kornspan & Stumpf, PA
+Miami, FL 33131
+<image001.jpg>
+<image002.jpg>
+Telephone:
+Fax:
+305-371-6421
+305-358-2006
+The information in this email transmission is privileged and confidential. If you are not the intended recipient,
+nor the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any
+dissemination or copying of this transmission (including any attachments) is strictly prohibited. If you have
+received this email in error, please delete all copies of this email and any attachments and notify us immediately.
+Thank you.
+<image003.jpg>
diff --git a/vision-fixhub/ds9-unparsed-06/148873f94863ea63c0c2e186fbf546e23771dd1f87ee91d8f0250a0795d23cc9.receipt.json b/vision-fixhub/ds9-unparsed-06/148873f94863ea63c0c2e186fbf546e23771dd1f87ee91d8f0250a0795d23cc9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..badc9d1694fabf456f5e46859292567b458bdffc
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/148873f94863ea63c0c2e186fbf546e23771dd1f87ee91d8f0250a0795d23cc9.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "148873f94863ea63c0c2e186fbf546e23771dd1f87ee91d8f0250a0795d23cc9",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "46c162c5de76c77a651596e23d8f907205460c392987c798166fd9a703dd87fb",
+  "output_sha256": "e01e2b248449a6a8ad25d7f102f654b76245b3730366cc464d595bd5a978c7e3",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/153ce08799f18528946381f508e999d05ff6d06ea5c8e0622e0faba574eec220.md b/vision-fixhub/ds9-unparsed-06/153ce08799f18528946381f508e999d05ff6d06ea5c8e0622e0faba574eec220.md
new file mode 100644
index 0000000000000000000000000000000000000000..fa7e4f4a505067aeeb47422ed1cfc3816a8fb27d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/153ce08799f18528946381f508e999d05ff6d06ea5c8e0622e0faba574eec220.md
@@ -0,0 +1,468 @@
+MARY JO WHITE
+United States Attorney
+Southern District of New York
+Attorney for Plaintiff
+United States of America
+By: Serene K. Nakano (SN-9556)
+Assistant United States Attorney
+100 Church Street - 19th Floor
+New York, New York 10007
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+-X
+UNITED STATES OF AMERICA, :
+Plaintiff, : 96 Civ. 8307 (DC)
+- against - : SECOND AMENDED
+JEFFREY E. EPSTEIN, IVAN S. FISHER, :
+ELLYN BANK, DEBRA ELISA COHEN,
+DIANE FISHER d/b/a THE FISHER GROUP, :
+FISHER & SOFFER a/k/a FISHER & SOPHIR,
+LAWRENCE D. GERZOG, ROBERT HEILBRUN, :
+SUZANNE McDERMOTT, CHRISTOPHER
+H. MARTIN, JESSIE SIEGEL a/k/a :
+JESSE SIEGEL, SIEGEL, MARTIN
+& HEILBRUN, RON SOFFER, CARMEN TALSIG, :
+JOHN DOES 1 through 10 and
+X CORPORATIONS 1 through 10, :
+COMPLAINT
+Defendants. :
+The United States of America, by its attorney, Mary Jo White, United States Attorney for the
+Southern District of New York, for its second amended complaint alleges upon information and belief as follows:
+NATURE OF THE ACTION
+This is an action by plaintiff United States of America (the "Government") on behalf of the
+Office of Foreign Missions ("OFM") of the United States Department of State (the "State Department") against
+defendants Jeffrey E. Epstein ("Epstein"), Ivan S. Fisher ("Fisher"), Ellyn Bank, Debra Elisa Cohen, Diane
+Fisher d/b/a The Fisher Group, Fisher & Soffer a/k/a Fisher & Sophir, Lawrence D. Gerzog, Robert Heilbrun,
+Suzanne McDermott, Christopher H. Martin, Jessie Siegel a/k/a Jesse Siegel, Siegel, Martin & Heilbrun, Ron
+Soffer, Carmen Talsig, John Does 1 through 10 and X Corporations 1 through 10 (collectively, the "Defendants")
+in connection with certain premises located at 34 East 69th Street, New York, New York (the "Premises").
+This action arises from Defendants' unlawful uses of the benefits of a foreign mission,
+namely, property of the government of Iran ("Iran"), in violation of the Foreign Missions Act of 1982, 22 U.S.C.
+§ 4301 et seq. ("FMA"). The Government took custody of the Premises on behalf of Iran following the
+
+
+severance of diplomatic ties with Iran in 1980 and has maintained, managed, protected and preserved the
+Premises at all times relevant to this suit pursuant to the Vienna Convention on Consular Relations ("VCCR"),
+the FMA, the International Emergency Economic Powers Act, 50 U.S.C. § 1701 et seq • ("IEEPA"), and
+authorities thereunder.
+PARTIES
+The plaintiff is the United States of America on behalf of its agency, the United States
+Department of State, Office of Foreign Missions, which is the trustee-landlord for the Premises.
+Defendant Epstein is a resident of the State of New York and has been a tenant of the
+Premises. Epstein has availed himself of the use and benefits of the Premises and has failed to surrender
+possession of the Premises to the Government.
+Defendant Fisher is a resident of the State of New York and is an unapproved subtenant of
+the Premises. Fisher has availed himself of the use and benefits of the Premises and has failed to surrender
+possession of the Premises to the Government. Defendant Ellyn Bank ("Bank") is a resident of the State of New
+York with a business address at 34 East 69th Street, New York, New York. Bank is named as a defendant
+because she has been an unapproved occupant of the Premises; has availed herself of the use and benefits of the
+Premises; and has or may claim to have an interest in the Premises.
+Debra Elisa Cohen ("Cohen") is a resident of the State of New York with a business
+address at 34 East 69th Street, New York, New York. Cohen is named as a defendant because she has been an
+unapproved occupant of the Premises; has availed herself of the use and benefits of the Premises; and has or may
+claim to have an interest in the Premises.
+Diane Fisher ("Ms. Fisher"), doing real estate business as The Fisher Group, is a resident
+of the State of New York with both a home and business address at 34 East 69th Street, New York, New York.
+Ms. Fisher is named as a defendant because she is an unapproved occupant of the Premises; has availed herself
+of the use and benefits of the Premises; and has or may claim to have an interest in the Premises.
+Ron Soffer ("Soffer") is a resident of both the State of New York and France, with a
+business address at 34 East 69th Street, New York, New York. Soffer is named as a defendant because he is an
+unapproved occupant of the Premises; has availed herself of the use and benefits of the Premises; and has or may
+claim to have an interest in the Premises.
+Fisher & Soffer a/k/a Fisher & Sophir ("Fisher & Soffer") is a general partnership with a
+business address at 34 East 69th Street, New York, New York. Defendants Fisher and Soffer are partners in
+
+
+Fisher & Soffer. Fisher & Soffer is named as a defendant because it is an unapproved occupant of the Premises;
+has availed itself of the use and benefits of the Premises; and has or may claim to have an interest in the
+Premises.
+Lawrence D. Gerzog ("Gerzog") is a resident of the State of New York with a business
+address at 34 East 69th Street, New York, New York. Gerzog is named as a defendant because he is an
+unapproved occupant of the Premises; has availed himself of the use and benefits of the Premises; and has or
+may claim to have an interest in the Premises.
+Jessie Siegel a/k/a Jesse Siegel ("Siegel") is a resident of the State of New York with a
+business address at 34 East 69th Street, New York, New York. Siegel is named as a defendant because he is an
+unapproved occupant of the Premises; has availed himself of the use and benefits of the Premises; and has or
+may claim to have an interest in the Premises.
+Robert Heilbrun ("Heilbrun") is a resident of the State of New York with a business
+address at 34 East 69th Street, New York, New York. Heilbrun is named as a defendant because he is an
+unapproved occupant of the Premises; has availed himself of the use and benefits of the Premises; and has or
+may claim to have an interest in the Premises.
+Christopher H. Martin ("Martin") is a resident of the State of New York, who, at various
+times pertinent to this lawsuit, has had a business address at 34 East 69th Street, New York, New York. Martin is
+named as a defendant because, at various times pertinent to this lawsuit, he has been an unapproved occupant of
+the Premises; has availed himself of the use and benefits of the Premises; and has or may claim to have an
+interest in the Premises. Although Martin may not currently occupy the Premises, he is named as a defendant
+because he is a partner of the law firm of defendant Siegel, Martin & Heilbrun.
+Siegel, Martin & Heilbrun ("SM&H") is a general partnership with a business address at
+34 East 69th Street, New York, New York. Defendants Siegel, Martin and Heilbrun are partners in SM&H,
+which, as of the date of this second amended complaint, is conducting business under the name SM&H. SM&H
+is named as a defendant because it is an unapproved occupant of the Premises; has availed itself of the use and
+benefits of the Premises; and has or may claim to have an interest in the Premises.
+Suzanne McDermott ("McDermott") is a resident of the State of New York with a business
+address at 34 East 69th Street, New York, New York. McDermott is named as a defendant because she is an
+unapproved occupant of the Premises; has availed herself of the use and benefits of the Premises; and has or may
+claim to have an interest in the Premises.
+
+
+Carmen Talsig ("Talsig") is a resident of the State of New York with a business address at
+34 East 69th Street, New York, New York. Talsig is named as a defendant because she is an unapproved
+occupant of the Premises; has availed herself of the use and benefits of the Premises; and has or may claim to
+have an interest in the Premises.
+John Does 1 through 10 (the "John Does") and X Corporations 1 through 10 (the "X
+Corporations") are persons or entities whose identities are presently unknown to the Government but who may
+be using the Premises as their business address. John Does and X Corporations are named as defendants because
+they are unapproved occupants of the Premises; have availed themselves of the use and benefits of the Premises;
+and have or may claim to have an interest in the Premises.
+JURISDICTION AND VENUE
+This Court has jurisdiction over this action by virtue of 28 U.S.C. § 1345 because the
+United States is the plaintiff in this action and by virtue of the FMA. See 22 U.S.C. §§ 4301(a), 4311.
+Venue in this district is proper pursuant to 28 U.S.C. § 1391(b) because this is the district
+in which the defendants reside and because this is the district in which the claims arose.
+THE INTERNATIONAL TREATIES
+AND STATUTORY SCHEMES
+A. The Foreign Missions Act of 1982
+Pursuant to the FMA, 22 U.S.C. § 4301 et seq ., "the operation in the United States of
+foreign missions... is a proper subject for the exercise of Federal jurisdiction." Id. § 4301(a). The FMA
+provides, inter alia, that "it is the policy of the United States ... to facilitate the secure and efficient operation in
+the United States of foreign missions ... and to assist in obtaining appropriate benefits, privileges, and immunities
+for those missions ... in accordance with international law." Id. § 4301(b). The State Department's actions
+pursuant to the FMA are grounded in national security and foreign policy concerns and issues of reciprocity
+among nations.
+See id.
+The FMA defines a "foreign mission" as "any mission to or agency or entity in the United
+States which is involved in the diplomatic, consular, or other activities of, or which is substantially owned or
+effectively controlled by ... a foreign government ... including any real property of such a mission" and "any
+right, title, or interest in or to, or the beneficial use of, any real property in the United States ... or other building."
+Id. $§ 4302(a)(3), (4).
+Under the FMA, "the United States, acting on its own behalf or on behalf of a foreign
+mission, has standing to bring ... an action to obtain compliance" with the FMA, including any action for
+
+
+injunctive or other equitable relief. Id. § 4311(a).
+The Secretary of State (the "Secretary") is empowered under the FMA to determine the
+treatment to be accorded to a foreign mission in the United States. Id. § 4301(c); see § 4302(a)(6). The FMA
+provides that "a denial by the Secretary involving a benefit of a foreign mission within the jurisdiction of a
+particular State or local government shall be controlling." Id. § 4307.
+OFM was established under the FMA pursuant to the Secretary's authority. Id. § 4303.
+OFM, inter alia, carries out the purposes of the FMA, as determined by the Secretary, and provides and assists
+in the provision of benefits for or on behalf of a foreign mission under the FMA. See id. § 4303(4). OFM also
+performs such other functions as the Secretary determines are in furtherance of the policy of the FMA.
+B. The Vienna Convention on Consular Relations
+And The Bilateral Treaty With Iran
+The VCCR, 21 U.S.T. 77, 596 U.N.T.S. 261, TIAS 6820, is a multilateral treaty to which
+the United States and Iran (and numerous other nations) are parties. The VCCR governs the conduct of consular
+relations, consular posts and their property and personnel. Article 27(1)(a) of the VCCR provides as follows:
+Protection of consular premises and archives and of the interests of the sending State in
+exceptional circumstances
+1. In the event of the severance of consular relations between two States:
+(a) the receiving State shall, even in case of armed conflict, respect and protect the
+consular premises, together with the property of the consular post and the consular
+archives....
+VCCR art. 27(1)(a).
+In addition to the VCR, the United States and Iran have entered into a bilateral treaty
+known as the 1955 Treaty of Amity, Economic Relations and Consular Rights Between the United States of
+America and Iran (the "Bilateral Treaty"). See 8 U.S.T. 899, TIAS 3853. Accordingly, the Premises also enjoy
+privileges and exemptions accorded under the Bilateral Treaty.
+C. The International Emergency Economic Powers Act
+In 1980, the Government severed diplomatic ties with Iran and pursuant to Article 27(1)(a)
+of the VCCR and the IEEPA, 50 U.S.C. § 1701 et seq. and applicable executive orders, respectively, took
+custody of the Premises and froze the assets of Iran located in the United States, including its diplomatic and
+consular properties (collectively, the "Iranian Diplomatic Properties").
+Under IEEPA, 50 U.S.C. § 1701 et seq ., and regulations promulgated thereunder, control
+and preservation of the Iranian Diplomatic Properties are licensed by the United States Department of Treasury
+(the "Treasury Department") to OFM. See 31 C.F.R. § 535.203(e) (1980).
+
+
+At all times pertinent to this suit, OFM has controlled, protected, managed and leased the
+Premises pursuant to the FMA, the VCCR, IEEPA and the terms of a license granted to OFM by the Treasury
+Department, Office of Foreign Assets Control (the "License").
+Under the FMA, the Secretary is empowered to "protect and preserve" and assume
+responsibility for the maintenance of the Iranian Diplomatic Properties, including the Premises licensed under
+TEEPA. See 22 U.S.C. § 4305(c)(1). Acting under the FMA, the Secretary has continued United States custody,
+control and protection of the Premises.
+Under the License, OFM accounts periodically to the Treasury Department, inter alia, as
+to the income stream generated by each of the Iranian Diplomatic Properties, including the Premises. The
+License states, inter alia, that "all income generated by or other use of the referenced properties would itself
+constitute blocked Iranian property" (License § 1.4).
+In addition, under the FMA, "[a]ssets of or under the control of the Department of State,
+wherever situated, which are used by or held for the use of a foreign mission shall not be subject to attachment,
+execution, injunction, or similar process, whether intermediate or final." 22 U.S.C. § 4308(f).
+The Premises were the residence of the former Iranian Consul General. Accordingly, the Premises are a foreign
+mission under the terms of the FMA. Id. §§ 4302(3), (4). The possession, preservation, control, benefits and use
+of the Premises are governed by the FMA, the VCCR, the Bilateral Treaty and IEEPA under terms and
+conditions prescribed by OFM.
+DEFENDANTS' WRONGFUL ACTS
+On or about February 1, 1992, OFM entered into a written lease with Epstein for his use
+and occupancy of the Premises as a single-family residence. The term of the Lease was from February 1, 1992
+through January 31, 1994. A true copy of the Lease is attached hereto as Exhibit A and is incorporated herein by
+reference.
+The Lease contained a use of premises clause, stating:
+Use
+The Premises will be occupied by (i) Tenant [Epstein], his/her spouse (if any), and his/her
+children (if any) as their personal residence; (ii) Tenant's personal servants and employees; and/or
+(il) approved subtenants or approved assignees and their respective families, and for no other
+purpose.
+(the "Use of Premises Clause") (Exhibit A, page 1). In addition, the Lease contained an assignment and sublet
+clause, stating:
+Assignment, Sublet
+Tenant may sublet all or part of the Premises, or assign this lease or permit any other
+person to use the Premises with the advance written permission of Landlord [OFM] .
+
+
+(the "Assignment and Sublet Clause") (Exhibit A, page 4) (emphasis added).
+On or about August 28, 1992, Epstein and OFM entered into an amendment to the Lease,
+which, inter alia, extended the term of the Lease through January 31, 1997 (the "Lease Amendment"). A true
+copy of the Lease Amendment is attached as Exhibit B and is incorporated herein by reference. The Lease
+Amendment was made retroactively effective to February 1, 1992. The Lease Amendment did not amend either
+the Use of Premises or Assignment and Sublet Clauses.
+On or about February 1, 1992, Epstein took possession of the Premises. On or about
+January 3, 1996, without OFM's knowledge, Epstein abandoned the personal occupancy of the Premises required
+by the Use Clause.
+By letter dated April 19, 1996, Epstein informed the Government, through his attorney, that he
+wished to sublet the Premises or to assign the Lease and Lease Agreement to Fisher.
+By letter dated April 26, 1996, the Government informed Epstein that it would not
+approve a sublease or assignment of the Lease and Lease Agreement to Fisher. A true copy of the April 26, 1996
+letter is attached as Exhibit C and is incorporated herein by reference.
+Despite the Government's decision not to approve Fisher as a subtenant or assignee,
+Epstein entered into a sublease for the Premises with Fisher on or about May 7, 1996 (the "Unpermitted
+Sublease"). A true copy of the Unpermitted Sublease (minus attachments referenced in the table of contents
+thereto) is attached as Exhibit D and is incorporated herein by reference.
+On or about May 16, 1996, a Government employee visited the Premises and found that Fisher
+was occupying and using the Premises. Fisher was not a person permitted to occupy the Premises under the Use
+Clause.
+By letter dated June 3, 1996, sent to Epstein by certified mail, return receipt requested, the
+Government notified Epstein that he was in default of the Lease and Lease Amendment for not occupying the
+Premises personally and for permitting an unapproved subtenant to occupy the Premises (the "Notice of
+Default"). Consistent with the Lease, the Notice of Default granted Epstein thirty days to cure the default. True
+copies of the Notice of Default and the certified mail receipt are collectively attached as Exhibit E and
+incorporated herein by reference.
+On or about July 19, 1996, a Government employee visited the Premises and confirmed
+that Fisher continued to occupy the Premises.
+
+
+By letter dated August 7, 1996, sent to Epstein by certified mail, return receipt requested,
+the Government notified Epstein that because of his failure to cure the default, the Lease would be terminated as
+of August 23, 1996 (the "Termination Notice"). The Termination Notice directed Epstein to have the Premises
+vacated and to return the keys to the OFM by August 20, 1996. True copies of the Termination Notice and the
+certified mail receipt are collectively attached as Exhibit F and incorporated herein by reference.
+Epstein has since refused to return the keys to the Premises to the Government or to have
+the Premises vacated and thereby holds and continues in possession of the Premises without the Government's
+permission or consent.
+Fisher holds and continues in possession of the Premises without the Government's
+permission or consent.
+At times pertinent to this lawsuit, Fisher has permitted defendants Ellyn Bank, Debra Elisa
+Cohen, Diane Fisher d/b/a The Fisher Group, Fisher & Soffer, Lawrence D. Gerzog, Robert Heilbrun, Suzanne
+McDermott, Christopher H. Martin, Jessie Siegel a/k/a Jesse Siegel, SM&H, Ron Soffer, Carmen Talsig, John
+Does 1 through 10 and X Corporations 1 through 10 (collectively, "Fisher's Subtenants") to occupy the Premises.
+The Government did not consent to any occupancy of the Premises by Fisher's Subtenants.
+Moreover, even under the Unpermitted Sublease, the validity of which the Government disputes, Epstein did not
+consent to the use and occupancy of the Premises by Fisher's Subtenants.
+Fisher's Subtenants hold and continue in possession of the Premises without the
+Government's permission or consent.
+On or about November 18, 1997, the Government sent a series of letters by Federal
+Express to all of Fisher's known Subtenants except for Ms. Fisher (who is Fisher's spouse), Martin (for whom
+the Government had no current address) and McDermott (who is apparently associated with or a member of
+Fisher's law firm), requesting, inter alia, that each of them confirm to the Government by November 28, 1997,
+whether or not they had understandings with Fisher concerning their use and benefit of the Premises and, if so,
+their plans to vacate the Premises. As of the date of this second amended complaint, none of Fisher's Subtenants
+who were contacted by the Government has denied to the Government that they occupy the Premises or has
+agreed to leave without a Court order.
+The Government has an immediate right to exclusive possession of the Premises.
+Under the FMA ( see 22 U.S.C. § 4305(c)(1)), article 27 of the VCCR and IEEPA, the
+Secretary protects and preserves the Premises on behalf of Iran. Defendants' actions seriously curtail the
+
+
+authority of the Secretary to preserve and execute control over the Premises. Defendants' wrongful possession of
+the Premises, which are the property of Iran, and of which the United States is custodian, violates the FMA and
+interferes with the Government's obligations under the VCCR.
+FIRST CLAIM
+Pursuant To The FMA, 22 U.S.C. § 4301
+et seg ., Against Epstein And Fisher
+For Ejectment From The Premises
+The Government repeats and realleges paragraphs 1 through 53 of the second amended
+complaint as if fully set forth herein.
+Epstein and Fisher have unlawfully availed themselves of the benefits of the Premises in
+violation of the FMA as follows:
+After the termination of the Lease and Lease Agreement, Epstein wrongfully has
+withheld possession of the Premises and has refused to have the Premises vacated and to return the keys thereto
+to the Government.
+Epstein wrongfully entered into the Unpermitted Sublease with Fisher and
+transferred possession of the Premises to Fisher.
+Fisher has maintained possession of the Premises and has refused to return
+exclusive possession of the Premises to OFM.
+By reason of the actions of Epstein and Fisher, the Government is entitled to a judgment
+declaring that it is entitled to exclusive possession of the Premises, awarding it exclusive possession of the
+premises and ejecting Fisher and Epstein from the Premises.
+SECOND CLAIM
+Pursuant To The FMA, 22 U.S.C. § 4301
+et seq ., Against Defendants Bllyn Bank,
+Debra Elisa Cohen, Diane Fisher d/b/a
+The Fisher Group, Fisher & Soffer a/k/a
+Fisher & Sophir, Lawrence D. Gerzog,
+Robert Heilbrun, Suzanne McDermott.
+Christopher H. Martin, Jessie Siegel
+a/k/a Jesse Siegel, Siegel, Martin
+& Heilbrun, Ron Soffer, Carmen Talsig,
+John Does 1 through 10 and X Corporations
+1 through 10 For Ejectment From The Premises
+The Government repeats and realleges paragraphs 1 through 56 of the second amended
+complaint as if fully set forth herein.
+
+
+Fisher's Subtenants have unlawfully availed themselves of the benefits of the Premises in
+violation of the FMA by occupying the Premises without the Government's permission and consent and by
+refusing to return exclusive possession of the Premises to the Government.
+By reason of the actions of Fisher's Subtenants, the Government is entitled to a judgment
+declaring that Fisher's Subtenants are not entitled to occupy the Premises, awarding the Government exclusive
+possession of the Premises and ejecting Fisher's Subtenants from the Premises.
+THIRD CLAIM
+Pursuant To The FMA, 22 U.S.C.
+§ 4301 et seq., Against Epstein
+For Unjust Enrichment
+The Government repeats and realleges paragraphs 1 through 59 of the second amended
+complaint as if fully set forth herein.
+Under the Lease Agreement, Epstein was to pay OFM monthly rent in the sum of $15,000
+per month during the period, February 1, 1996 through January 31, 1997 (Exhibit B, page 2). Under the
+Unpermitted Sublease, Epstein has been receiving from Fisher monthly rent in the amount of $20,000
+commencing with June 1, 1996 to a date unknown to the Government (Exhibit D 9 5).
+The total amount of the monies paid to Epstein by Fisher for the use and benefit of the
+premises is unknown to the Government.
+Through his unlawful use and benefit of the Premises, Epstein has unjustly enriched himself in an amount to be
+determined at trial. The circumstances of Epstein's unjust enrichment are such that in equity and good
+conscience, Epstein should not retain such payments.
+FOURTH CLAIM
+Pursuant To The FMA, 22 U.S.C.
+§ 4301 et seq ., Against Fisher
+For Unjust Enrichment
+The Government repeats and realleges paragraphs 1 through 63 of the second amended
+complaint as if fully set forth herein.
+Fisher has unlawfully availed himself of the use and benefit of the Premises from a date
+unknown to the Government through the present and has paid no monies to the Government. Fisher has refused
+to surrender possession of the Premises to the Government, thereby preventing the Government from leasing the
+Premises. Moreover, Fisher may have profited in amounts and ways presently unknown to the Government
+through the receipt of monies or other forms of consideration from Fisher's Subtenants.
+
+
+Through his unlawful use and benefit of the Premises, Fisher has unjustly enriched himself in an amount to be
+determined at trial. The circumstances of Fisher's unjust enrichment are such that in equity and good conscience,
+Fisher should not retain such benefits.
+FIFTH CLAIM
+Pursuant To The FMA, 22 U.S.C. §
+4301 et seq ., Against Defendants
+Ellyn Bank, Debra Elisa Cohen, Diane Fisher
+d/b/a The Fisher Group, Fisher & Soffer a/k/a Fisher & Sophir, Lawrence D. Gerzog,
+Robert Heilbrun, Suzanne McDermott, Christopher H. Martin, Jessie Siegel a/k/a Jesse
+Siegel,
+Siegel, Martin & Heilbrun, Ron Soffer,
+Carmen Talsig, John Does 1 through 10 and
+X Corporations 1 through 10 For Unjust Enrichment
+The Government repeats and realleges paragraphs 1 through 66 of the second amended
+complaint as if fully set forth herein.
+Fisher's Subtenants have unlawfully availed themselves of the use and benefit of the
+Premises from dates unknown to the Government through the present and have paid no monies to the
+Government. Fisher's Subtenants have refused to surrender possession of the Premises to the Government,
+thereby preventing the Government from leasing the Premises.
+Through their unlawful use and benefit of the Premises, Fisher's Subtenants have unjustly enriched themselves as
+against the Government in amounts to be determined at trial. The circumstances of Fisher's Subtenants' unjust
+enrichment as against the Government are such that in equity and good conscience, Fisher's Subtenants should
+not retain such benefits as against the Government.
+SIXTH CLAIM
+Pursuant To The FMA, 22 U.S.C.
+§ 4301 et seq ., For Injunctive Relief
+Against Epstein Directing Him
+To Return Fixtures To The Government
+The Government repeats and realleges paragraphs 1 through 69 of the second amended
+complaint as if fully set forth herein.
+The Lease provides in pertinent part that "[a]ll improvements done by a previous tenant
+indicated on the attached list entitled 'Chandeliers, Sconces, Mirrors,' (the "Fixtures") have become the sole
+property of Landlord [OFM] and may not be disposed of without the Landlord's written consent" (Exhibit A,
+page 3; List entitled "Chandeliers, Sconces, Mirrors" (the "Fixtures Clause").
+Iran is the prior tenant who installed the Fixtures on the Premises. The Government is the
+proprietor of the Fixtures and protects and preserves the Fixtures on behalf of Iran pursuant to the FMA, VCCR
+
+
+and IEEPA.
+The Government has not consented to any disposal of any Fixtures by Epstein. Epstein
+has not returned the Fixtures to the Government. Pursuant to the FMA, an injunction should issue requiring
+Epstein to return the Fixtures to the Government.
+SEVENTH CLAIM
+Against Epstein -
+Common Law Breach Of Contract
+The Government repeats and realleges paragraphs 1 through 73 of the second amended
+complaint as if fully set forth herein.
+Epstein defaulted under the Lease and Lease Agreement and failed to cure such default
+within the time demanded in the Termination Notice.
+The Lease provides in pertinent part:
+Tenant's Defaults and Landlord's Remedies
+If the Lease is terminated as [a] result of Tenant's default hereunder beyond all applicable
+grace and cure periods, Landlord may re-rent the Premises and anything in it for any term
+... Tenant shall be responsible for Landlord's reasonable costs of re-renting.
+(Exhibit A, page 5).
+The Government has been unable to re-rent the property because Epstein has failed to cure
+his default by, inter alia, allowing Fisher to have possession of the Premises, thereby preventing the Government
+from re-renting the Premises.
+Epstein is liable to the Government for monetary damages from August 23, 1996, the
+effective date of the termination of the Lease and Lease Agreement, until exclusive possession of the Premises is
+returned to the Government.
+EIGHTH CLAIM
+Against Epstein -
+Common Law Breach Of Contract
+The Government repeats and realleges paragraphs 1 through 78 of the second amended
+complaint as if fully set forth herein.
+Epstein has not returned the Fixtures to the Government and has accordingly breached the
+Fixtures Clause. The Government has been damaged by Epstein's breach of the Fixtures Clause in an amount to
+be determined at trial.
+NINTH CLAIM
+Against Epstein -
+Common Law Conversion
+
+
+The Government repeats and realleges paragraphs 1 through 81 of the second amended
+complaint as if fully set forth herein.
+In the Unpermitted Sublease, Epstein asserts that he, as "Overtenant" owns all property
+listed on a schedule attached to the Lease ... which is entitled "Chandeliers, Sconces and Mirrors" (Exhibit D9
+10), i.e., the Fixtures.
+The Fixtures, as to which Epstein claims ownership, are not Epstein's property. The
+Government is the proprietor of the Fixtures on behalf of Iran pursuant to the FMA, VCCR, IEEPA and the
+License.
+The Government did not consent to Epstein's conversion of the Fixtures.
+The Government has been damaged by Epstein's conversion of the Fixtures in an amount
+to be determined at trial.
+WHEREFORE, plaintiff United States of America prays for judgment against the Defendants:
+(a) On Claim 1 against Epstein and Fisher, pursuant to the FMA, 22 U.S.C. § 4301 et seq.,
+adjudicating that the Government is entitled to immediate and exclusive possession of the Premises; ejecting
+Epstein and Fisher from possession of the Premises; and returning exclusive possession of the Premises to the
+Government:
+(b) On Claim 2 against Fisher's Subtenants, pursuant to the FMA, 22 U.S.C. § 4301 et seq .,
+adjudicating that Fisher's Subtenants are not entitled to occupy the Premises; ejecting Fisher's Subtenants from
+the Premises; and returning exclusive possession of the Premises to the Government;
+(c) On Claim 3 against Epstein, pursuant to the FMA, 22 U.S.C. § 4301 et seq ., awarding the
+Government the amount by which Epstein was unjustly enriched, a total to be determined at trial;
+(d) On Claim 4 against Fisher, pursuant to the FMA, 22 U.S.C. § 4301 et seq ., awarding the
+Government the amount by which Fisher was unjustly enriched, a total to be determined at trial;
+(e) On Claim 5 against Fisher's Subtenants, pursuant to the FMA, 22 U.S.C. § 4301 et seq .,
+awarding the Government the respective amounts by which Fisher's Subtenants were unjustly enriched as against
+the Government, in amounts to be determined at trial;
+(f) On Claim 6 against Epstein, pursuant to the FMA, 22 U.S.C. § 4301 et seq ., for an injunction
+directing Epstein to return the Fixtures to the Government;
+(g) On Claim 7 against Epstein, damages under the Lease and Lease Agreement, for the
+Government's cost of re-renting the Premises, a total to be determined at trial;
+
+
+(h) On Claim 8 against Epstein, damages under the Lease and Lease Agreement, for Epstein's
+breach of the Fixtures Clause;
+(i) On Claim 9 against Epstein, damages for Epstein's conversion of the Fixtures;
+(i) The costs and disbursements of this action; and
+(k) For such other and further relief as this Court deems just and proper.
+Dated: New York, New York
+December 17, 1997
+By:
+MARY JO WHITE
+United States Attorney for the
+Southern District of New York
+Attorney for Plaintiff
+United States of America
+Assistant United States Attorney
+100 Church Street, 19th Floor
+New York, New York 10007
diff --git a/vision-fixhub/ds9-unparsed-06/153ce08799f18528946381f508e999d05ff6d06ea5c8e0622e0faba574eec220.receipt.json b/vision-fixhub/ds9-unparsed-06/153ce08799f18528946381f508e999d05ff6d06ea5c8e0622e0faba574eec220.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..16ac065a6a1a257e51dcb6e07f33ffbbfb708077
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/153ce08799f18528946381f508e999d05ff6d06ea5c8e0622e0faba574eec220.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -168,
+  "dataset": "marble-joined",
+  "doc_id": "153ce08799f18528946381f508e999d05ff6d06ea5c8e0622e0faba574eec220",
+  "engine": "marble-apple-vision",
+  "event_count": 14,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "6a0a22191a20671da80002c8f38765aec9eea0f04fa1e89564d04685b25cf204",
+  "output_sha256": "db0b0dae9fd13555ab33ef7e5cb6c451b84c777e73b876282669875ebc4ad074",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/153d17d30d8c4cc8f2e37c1bd01386d4a4cadeb01d03c818f4bbacb79834d5cb.md b/vision-fixhub/ds9-unparsed-06/153d17d30d8c4cc8f2e37c1bd01386d4a4cadeb01d03c818f4bbacb79834d5cb.md
new file mode 100644
index 0000000000000000000000000000000000000000..188ac94be64f2053f9effffa4c50be9e66cffdc5
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/153d17d30d8c4cc8f2e37c1bd01386d4a4cadeb01d03c818f4bbacb79834d5cb.md
@@ -0,0 +1,20 @@
+From:
+To: =
+Cc:
+Subject: Jeffrey Epstein
+Date: Fri, 29 Jun 2007 20:04:39 +0000
+Importance: Normal
+As i stated in my earlier voicemail today, we were calling to request a two-week extension on the return date of
+the following outstanding subpoenas:
+1. NES
+2. NY Strategy
+3. Investigator Riley
+4. Certification for St. Thomas entity
+We will be providing an additional submission to the Office by July 11 and hope to be able to reach a state-based
+resolution shortly thereafter.
+as your voicemail to me indicted, you would not oppose a one to two-week extension. accordingly, we would
+like to extend the return date two weeks-- to July 24.
+regards
+Esq.
+FOWLER WHITE BURNETT P.A.
+Espirito Santo Plaza, 14th Floor
diff --git a/vision-fixhub/ds9-unparsed-06/153d17d30d8c4cc8f2e37c1bd01386d4a4cadeb01d03c818f4bbacb79834d5cb.receipt.json b/vision-fixhub/ds9-unparsed-06/153d17d30d8c4cc8f2e37c1bd01386d4a4cadeb01d03c818f4bbacb79834d5cb.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..61333d0c6a2bad7da2e92ec2a78872778527fbf4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/153d17d30d8c4cc8f2e37c1bd01386d4a4cadeb01d03c818f4bbacb79834d5cb.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "153d17d30d8c4cc8f2e37c1bd01386d4a4cadeb01d03c818f4bbacb79834d5cb",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "a3311241edf6c793f7bb1576fa425c275a46fa0c8d8b857d4c170cf3d0bca1dc",
+  "output_sha256": "bad5973c87c83423bb1bcffa601a4c52e8a852dce3c3ef720ade326526e7fdea",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/15a417e60da0e42086d56349ba81778da800481696e6e6afbad8bf8ab74ad63f.md b/vision-fixhub/ds9-unparsed-06/15a417e60da0e42086d56349ba81778da800481696e6e6afbad8bf8ab74ad63f.md
new file mode 100644
index 0000000000000000000000000000000000000000..8337753df0958602596de2e03208043560cd3f00
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/15a417e60da0e42086d56349ba81778da800481696e6e6afbad8bf8ab74ad63f.md
@@ -0,0 +1,2689 @@
+*cingular
+Questions or Changes?
+attwireless.com
+• Toll Free 1 866 293-4634
+:
+611 from your wireless phone
+TTY users - 1 866 4-AWS-TTY
+SUMMARY OF MONTHLY CHARGES FOR ACCOUNT 0035224228
+Previous
+Balance
+-42.64
+Payments
+Received
+-65.83
+Late Payment
+0.00
+Account
+Adjustments
+0.00
+Your billing cycle began on November 12, 2004 and ended on December 11, 2004
+Current Monthly Charges
+Subscriber Adjustments
+Monthly Service
+Monthly Usage
+Charges
+Credits
+Government Fees and Taxes
+Total Current Monthly Charges DUE UPON RECEIPT
+TOTAL CREDIT AMOUNT
+CREDIT BALANCE - DO NOT PAY
+WE ARE PROUD TO ANNOUNCE THAT AT&T WIRELESS IS NOW
+PART OF CINGULAR WIRELESS. IN THE COMING MONTHS YOU
+WILL RECEIVE EXCITING INFORMATION ABOUT HOW THE
+COMBINED STRENGTH OF THESE TWO COMPANIES WILL BENEFIT
+YOU. THERE WILL BE NO CHANGE TO HOW YOU ARE BILLED OR
+HOW YOU PAY YOUR BILL. HOWEVER, YOU WILL NOTICE A FEW
+CHANGES TO THE PHYSICAL APPEARANCE OF YOUR BILL.
+WELCOME TO THE CINGULAR WIRELESS FAMILY!
+Date of Invoice: December 12, 2004
+Balance
+Forward
+-108.47
+Current Monthly
+Charges
+70.47
+Total
+Credit Amount
+-38.00
+0.00
+0.00
+58.62
+0.00
+0.00
+11.85
+70.47
+-38.00
+‹cingular
+TIRELESS
+Account Name:
+ease Return This Portion With Your Payme
+se of service or payment of this invol
+No Pin o
+Front and Back
+Service # 5613080282
+Account # 0035224228
+Chack he for vis.
+THIS IS NOT AN INVOICE|
+- DO NOT PAY
+#BWNHNGB
+#0000000352242283#w
+S.01.02.0011.1000
+LOAT TAND AT NI
+AT&T WIRELESS
+PO BOX 8229
+AURORA IL 60572-8229
+
+
+
+Recurring Electronic Fund Transfer (REFT): To enroll: sign below, check the REFT box on the reverse side and
+remit with this month's payment. Keep paying your bill until your statement indicates "Do Not Pay". REFT
+Agreement: 1 authorize my financial institution to deduct the amount of my monthly wireless phone bill from the
+account associated with the enclosed check and remit payment to AT&T Wireless. This authority will be effective
+until I notify AT&T Wireless to terminate it. I agree that I may be assessed a service charge (up to $20) or late fee
+or both if a payment is returned by my bank. For more information visit attwireless.com/ocs or call 1 866 293-4634.
+Please keep a copy of the form below and this REFT Agreement for your records or retain a copy of the blank form
+from next month's invoice.
+Questions? We can help: AT&T Wireless appreciates your business and welcomes the opportunity to assist you.
+As part of our commitment to you, we are always adding new calling plans and promotions to match your individual
+needs. Visit our website at attwireless.com or contact Customer Care by dialing 611 from your wireless phone or 1
+866 293-4634. ¿ Sabias que también ofrecemos servicio al cliente en tu idioma? Marca 611 desde tu teléfono
+inalámbrico ó 1 866 293 4634 desde cualquier teléfono y oprime el *.
+Driving Wireless Safety: Your wireless phone gives you the freedom and flexibility to stay in touch when you
+travel, but don't let a phone call distract you from driving safely. Use hands-free device if allowed or required by
+law. Call Carefully, Arrive Safely.
+AT&T Wireless Processing Fees: Accounts suspended for non-payment will be subject to a $25 reactivation fee
+per line and may be assessed a security deposit prior to reinstatement. Checks returned for non-sufficient funds will
+be charged up to a $20.00 fee.
+Local Tax: Local taxes are based on local government boundaries, the address information you provide for your
+ccount and/or your wireless telephone number. Please review the local tax charges on your bill. If you believe
+here is an error in the local tax charge, please contact us immediately at 1 866 293-4634. Please note that som
+local or state laws may require you to follow special procedures when notifying us about a local tax dispute. You
+may also use the form below to notify us of any change to your taxing address. Thank you for your cooperation.
+Early Termination Fee (ETF): If you cancel service before your contract end date (including if you switch your
+wireless number to another carrier), you will be charged an Early Termination Fee of up to $200.
+Please Send Correspondence To:
+AT&T Wireless Next Generation Correspondence
+P.O. Box 68056
+Anaheim Hills, CA 92817-8056
+0.000003029.5
+coung ame and ranse an espires clearly and check the box on the reverse side. Please contact Customer Care to change the
+Name and transfer Financial Responsibility.
+New Billing Address
+City
+State
+Zip
+Home Phone (
+Work Phone (.
+If your billing address is NOT your Tax Address*, please enter the Tax Address below. (Multi-line accounts should attach a list of each wireless number
+and the respective Tax Address.)
+New Tax Address*
+Wireless Number (
+City
+State
+Zip
+Inder Federal laws, your Tax Address must be: your primary place of use, your residential or business address, and located within AT&T Wireless
+ensed service area. Non-business customers on AT&T Digital One Rate, Regional Advantage or Shared Advantage plans must use their resident
+address as their tax address.
+Recurring Electronic Fund Transfer (REFT) Enrollment. Please read the agreement on the top portion of this page, sign below and check
+the "REFT Registration" box on the reverse side.
+Financial Account Holder Signature
+6.1 - 3G
+• • I do not wish to receive email notlication of special ollers avallable to AT&T Wireless customers.
+
+
+
+ACCOUNT DETAILS
+Detail of Payments - Thank You!
+Item Description
+1 PAYMENT
+Total of Payments
+Date Applied/Reversed Payment Amount
+12/04/04
+-65.83
+Detail of Account Government Fees and Taxes
+Item Description
+1 COUNTY 911 TAX
+2 FEDERAL TAX
+3 STATE COMM SERVICE TAX
+4 UTILITY USERS TAX 1|
+5 *UNIVERSAL CONNECTIVITY CHARGE
+Total Account Government Fees and Taxes
+* This is not a tax or government required charge, it is a fee assessed on telecommunications carriers.
+Current Subscriber Monthly Charges and Credits
+Subscriber Number
+Subscriber Name
+
+Total Current Subscriber Monthly Charges and Credits
+Total Current Monthly Charges
+-65.83
+-65.83
+0.50
+1.68
+5.09
+3.09
+1.49
+11.85
+58.62
+58.62
+70.47
+SUMMARY OF CURRENT ACTIVITY
+Monthly Service Charges
+Item Description
+1 CALL WAITING
+2 CALLER ID
+3 GO PHONE $53.98 REPLENISHMENT
+4 THREE WAY CALLING
+5 GO PHONE UNLIMITED NIGHTS AND WEEKENDS
+6 DETAIL BILLING
+Total Monthly Service Charges
+Monthly Usage Charges
+Item Description
+1 UNLIMITED N/WKND MIN
+2 AIRTIME MINUTES
+3 CALL WAITING
+4 MESSAGE RETRIEVAL
+5 TEXT MESSAGES SENT
+6 SPECIAL NUMBER CALLS
+Total Monthly Usage Charges
+TOTAL CHARGES FOR (561)308-0282
+Service Dates
+11/12/04 - 12/11/04
+11/12/04 - 12/11/04
+11/12/04 - 12/11/04
+11/12/04 - 12/11/04
+11/12/04 - 12/11/04
+11/12/04 - 12/11/04
+0.00
+0.00
+0.00
+0.00
+0.00
+0.00
+0.00
+Onty Used
+1253 MIN
+648 MIN
+33 EVT
+29 EVT
+3 EVT
+5 MIN
+0.00
+58.32
+0.00
+0.00
+0.30
+0.00
+58.62
+58.62
+DETAIL OF CURRENT ACTIVITY
+VOICE USAGE FOR (561)308-0282
+Item Date Time Called
+1 11/12 12:34A
+2 11/12 03:32A
+3 11/12 12:13P (581)204-7788
+11/12 02:10P
+11/12 02 13 561847-3349
+11/12 02:17P (561 635-3454
+11/12 02.19P 561/635-3484
+11 11/12 02:20P
+12 11/12 02:23P (561)676-4056
+18 1V12 0224P 381282-3300
+15 11/12 02:29P (561 602-9566
+1112 02 30 561817-3330
+Calls To
+INCOMING
+INCOMING
+'ALMBEACH
+›ALMBEACH
+INCOMING
+PALMBEACH F
+/PALMBEAC
+WPALMBEACH FL
+VPALMBEACH F
+PALMBEACH F
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FI
+WPALMBEACH
+LAKE WORTH FL
+LAKE WORTH FI
+11/12 02:31P (917|855-3363
+1/12 02.33 (897) 833-3363
+11/12
+02:35P
+1122-30
+11/
+08 34P 861338-0180
+SASSES
+03:38P (561)333-0180
+: 0125P
+07:28P
+(561)644-7633
+2 0733P
+61)602-956
+611644-763
+2 07:34P (561)723-8559
+12 07:35P (561)602-9566
+2 07:38P
+
+11/12 07:40P
+1/12 07:46P
+12 8763P (561)602-9566
+11/12 07:59P (561)644-7633
+1/12 08:04
+41
+1/12 08:58P (561)635-345
+INCOMING
+INCOMING
+KE WORTH I
+COMIN
+FL
+WPALMBEACH FL
+COMIN
+PAI MREACH I
+115 09-15
+• 11/12 09:15P (561 317-3348
+11A2 09:28P (S51)644-9633
+112030 561/614-7633
+11/12 09:30P
+11/12 09:40P
+/12 09:46P
+2 10:29 (881 383-2281
+2 10:46P
+13 12:03A
+12:26A
+01-38A
+11/13 01:42A (561)201-5511
+INCO
+INCOMING
+INCOMING
+INCOMING
+LAKE WORTH FL
+ICOMINI
+INCOMING
+INCOMING
+INCOMING
+WPALMBEACH FL
+Onty
+Used Rate Description
+8MIN
+18MIN
+3 MIN 8:09 AIRTIME MINUTES
+1 MIN
+0.09 AIRTIME MINUTES
+3MIN
+IMIN
+.09 AIRTIME MINUTE
+.09 AIRTIME MINUTE
+1 MIN
+0.09 AIRTIME MINUTES
+1 MIN
+.09 AIRTIME MINUTE
+3MIN
+09 AIRTIME MINUTE
+0.09 AIRTIME MINUTES
+CALL WAITING
+1 MIN
+0.09 AIRTIME MINUTES
+1 MIN
+09 AIRTIME MINUTE
+1 MIN
+09 AIRTIME MINUTE
+1 MIN
+0.09 AIRTIME MINUTES
+1 MIN
+1 HIN
+0.
+8g
+AIRTIME
+
+8.73
+0.21
+0.29
+00090
+000000000 00 000
+3MIN
+3MIN
+1 MIN
+2MIN
+3MIN
+1 EVT
+2MIN
+2MIN
+1MIN
+SMIN
+1 MIN
+1 MIN
+1 MIN
+2 MIN
+1 MIN
+1 MIN
+2MIN
+2MIN
+0E0E000000
+AIN
+UNLIMITED
+N/WKND MIN
+
+
+
+
+Item Date Time Called
+63 11/13 09:28A
+64 11/13 09:34A
+9211130940A (561)635-3454
+09-42A
+67
+11/13 09:56A (561)635-3454
+69
+1310:184
+(561)635-3454
+70 11/13 10:19A (561 602-9566
+71 11/13 10:20A
+72 11/13 10:21A
+73 11/13 10:23A (561)602-9566
+75 11/13 10:234
+Calls To
+INCOMING
+INCOMING
+NPALMBEACH FL
+NCOMING
+WPALMBEACH FL
+COMING
+PALMBEACH F
+LAKE WORTH FL
+INCOMING
+INCOMING
+LAKE WORTH FL
+COMINI
+COMING
+79 11/18 19:57A (967313-3738
+Onty
+Used Rate Description
+3 MIN
+1 MIN
+2 MIN
+1 MIN
+UNLIMITED NWINB
+1 MIN
+UNLIMITED N/WKND
+1 MIN
+VLIHITED NAWKN
+1 MIN
+LIMITED NWKN
+LE
+IN
+4 MIN
+VLIMITED NIWKND MI
+ALL WAITIN
+WAITING
+UNLIMITED NAWKND MIN
+CALL WAITING
+NLIMITED N/WKND MI
+MIl
+78 11/13 11:09A
+(561 793-7719
+88 111311264
+61)317-334
+61)317-334
+81
+11/13
+11:35A
+82
+11/13 11:39A
+NEW YORK NY
+LAKE WORTH FL
+WPALMBEACH FL
+WALMBEACH FE
+INCOMING
+INCOMING
+1 MIN
+1 EVT
+I MIN
+6 MIN
+1 EVT
+1 MIN
+1MN
+1 MIN
+13 MIN
+11 MIN
+10MIN
+1 EVT
+1 MIN
+11:44A
+
+99899
+(561)317-3348
+:14P
+07P
+40P
+2A
+(5611313-6730
+561 793-9291
+(561)762-9805
+(561)723-8559
+(561|282-8500
+(561)793-9291
+(561313-6730
+1644-7633
+1 MIN
+1 MIN
+2MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+ND
+(961)
+13-67:
+-770
+5611635-6986
+(581)
+1635-6986
+1635-6986
+his
+1P
+(561)502-4728
+6A
+113
+11/15 01:46P
+114
+11/15 03:01P
+(561)753-1604
+/1S 04:07P 561602-956
+115 04-079
+
+(561)333-0225
+11/16
+08:56P
+(561)798-6616
+11-44P
+02:50P
+WPALMBEACH FL
+INCOMING
+INCOMING
+AKE WORTH
+WPALMBEACH
+WPALMB
+ACH
+INCOMIN
+WPALMBEACH
+WPALMBEACH
+INCOMING
+WP
+ALMBEACH
+WPALN
+WOR
+BEACH
+INCOMING
+INCOMING
+INCOMING
+NCOI
+INCOMING
+LAKE WOR
+MPAIN
+WPALMBEA
+MPALME
+CH
+MPAL MR
+NOOMING
+NOOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+LAKE WORTH FL
+WPALMBEACH FL
+INCOMING
+INCOMING
+WK
+1 MIN
+SMIN
+OMIN
+1 MIN
+0.
+109
+0.
+AIRT
+0.
+.09
+UNLIMIT
+AIRTIME
+KND MIN
+00O
+0.18
+Item Date Time Called
+122 11/16 06:08P
+123 11/16 07:10P
+125 1116 0032P
+126 11/17 10:52P
+127
+128
+1/17 11:231
+1/18 02-367
+(561)313-6730
+129 11/18 02:48P (561)793-7719
+130 11/18 03:13P (561)635-6986
+132 11/18 05:40P
+133
+1/18 08 385
+• (561)687-212
+136 1118 1036Р
+(561)313-6730
+561 644-8233
+137 11/18 10:48P
+(561)644-8233
+139 11/18 11:16
+5611644-8235
+5611358-4117
+Calls To
+INCOMING
+INCOMING
+COMING
+JOOMINC
+INCOMING
+NCOMING
+AKE WORTH FL
+WPALMBEACH FL
+NOONING
+MPALMBEACH FL
+INCOMING
+COMING
+(PALMBEACH F
+1к- WORTH •
+/PALMBEACH FL
+WPALMBEACH FL
+VPALMBEACH F
+MPALMBEACH FI
+FTLAUDERDL FL
+INCOMING
+INCOMING
+INCOMING
+NOOMING
+COMING
+79
+9291
+868-4878
+700
+12
+01
+-26A
+11/20 01:55A
+(561)502-4728
+11/20 02:38A
+INCOMING
+COMIN
+(PALMBEAC
+IFL
+WPALMBEACH
+FL
+WPALMBEACH FL
+NOOMING
+WPALMBEACH FL
+FTLAUDERDL FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+Onty
+Used
+Rate Description
+1 MIN 0.09 AIRTIME MINUTES
+1 MIN
+0.09 AIRTIME MINUTES
+6 MIN
+LIMITED NWKND M
+8 MIN
+INLIMITED NOWKND N
+1 MIN
+19 MIN
+JNLIMITED N/WKND MIl
+MIN 0.09 ART ME MINUTE:
+3MIN
+0.09 AIRTIME MINUTES
+1 MIN
+3MIN
+0.08 A REME MINUTES
+0.09 AIRTIME MINUT
+5MIN
+0.09 AIRTIME MINUTES
+MIl
+ONLIMITED N/WKND MIT
+INLIMITED N
+3 MIN
+INLIMITED N'WKND
+2 MIN
+UNLIMIT
+I NIWKNI
+1 MIN
+UNLIMITED N/WKND
+1 MIN
+UNLIMITED NWKND
+2 MIN
+UNLIMITED NIWKND
+1 MIN
+1 MIN
+1 MIN
+0.09 AIRTIME MINUTES
+2 MIN
+0.09 AIRTIME
+2 MIN
+MINUT
+1 MIN
+0.09 AIRTIME MINUTES
+MIl
+0.09 AIRTME MINUTES
+1 MIN
+0.09 AIRTIME
+0.08 AB-M
+.09 AIRTIME MINUT
+1 MIN
+1 MIN
+5MIN
+1 MIN
+0.09 AIRTIME MINUTES
+1.09 AIRTIME MINUTES
+0.09 AIRTIME MINUTES
+109 AIRIM
+IMIN
+2MIN
+1 MIN
+2 MIN
+INLIMI
+UNWEND MIN
+1 MIN
+EV
+2MIN
+MINTED KNAMIN
+
+0.27
+0.45
+0.18
+B0088888888988
+174
+11
+8 8888888888g
+03:4
+I1P
+
+(954)410-9674
+(9541655-0720
+(954)655-0720
+(917)855-3363
+INCOMING
+WPALMBEACH FL
+LAKE WORTH FI
+WPALMBEACH FL
+W YORK 1
+KE WORTH
+WPALMBEACH FL
+NEW YORK NY
+INCOMING
+NEW YORK NY
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+INCOMING
+FLAUBERBL FL
+FTLAUDERDL FL
+INCOMING
+NEW YORK NY
+4 MIN
+14 MIN
+3MIN
+1 MIN
+i MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+1EVT
+2MIN
+2MIN
+1 MIN
+2 MIN
+1 MIN
+1 MIN
+1 MIN
+UNITED MAIN MIN
+UNLIMITED WIND MIN
+UNLIMITED N/WKND MIT
+
+
+
+Item Date Time
+Called
+182 11/20 05:53P (561)502-4728
+183 11/20 06:08P
+185 11/20 06:20P (954)655-0720
+187
+11/
+20 06:40P (561)502-4728
+11/
+20 06:47P
+188
+189
+11/
+20 06:49P
+11/20 06:50P
+561)383-6810
+5611602-5720
+Calls To
+WPALMBEACH FL
+INCOMING
+FTLAUDERDL FL
+NCOMING
+WPALMBEACH FL
+COMIN
+PALMBEACH i
+LAKE WORTH FL
+190
+91
+11/
+11/
+16:56P
+5611317-3348
+5611644-1565
+192
+20 06:59P
+30880
+11/20
+07:00P
+(561)656-1947
+07:01P (5611333-0225
+11/20
+07:27P
+18:19P
+11/20
+08:35P
+11/28
+0851P
+61)602-956
+1611602-956
+200 11/20 08:54P
+(561|602-9566
+202 11120 09:02P
+(561/602-9566
+203 11/20 09:48P (561)313-6730
+11/20 09:59P
+0512010560 (5611313-6730
+206 11/20 11:26P
+(561)30B-0282
+207 11/20 11:28P (561)308-0282
+208 11/20 11:29P (561)502-4728
+209 11/20 11:30P (561/308-0282
+210 11/20 11:32P (561)308-0282
+WPALMBEACH FL
+COMIN
+PALMBEACH
+COMING
+ICOMING
+INCOMING
+AKE WORTH F
+AKE WORTH
+LAKE WORTH FL
+LAKE WORTH FL
+INCOMING
+LAKE WORTH FL
+INCOMING
+LAKE WORTH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FLI
+WPALMBEACH FL
+WPALMBEACH FL
+211 11/20 11:33P (561)308-0282
+Onty
+Used
+Rate Description
+1 MIN
+1 MIN
+1 MIN
+INLIMITED WIND MIN
+4MIN
+INLIMITED N/WKND MIN
+1 MIN
+1 MIN
+NLIMITED NIWKND MI
+1 MIN
+NUMITED N/WKND MI
+1 MIN
+2MIN
+NLIMITED N/WKND M
+3MIN
+NLIMITE
+1MIN
+N/WKND MIN
+1 MIN
+VWKND MIl
+2MIN
+INLIMITED NWKND MIl
+1 MIN
+1 MIN
+UNLIMITED WIN MIN
+N/WKND MIN
+6MIN
+1 MIN
+NIMITE
+N/WKND MIN
+1 MIN
+NLIMITED N/WKND M
+1 MIN
+1 MIN
+1 MIN
+2MIN
+1 MIN
+1 MIN
+ILIMITED N/WKND N
+UNLIMIT
+N/WKND
+UNLIMM
+N/WKND
+UNLIMIT
+LIMITE
+1 MIN
+1 EVT
+1 MIN
+1 MIN
+1 EVT
+1 MIN
+1EVT
+RETRIEVAL
+JWKND MIN
+WPALMBEACH FL
+ED N/WKND MIN
+
+Item Date Time
+Called
+Onty
+Calls To
+Used Rate Description
+236 11/21 01:19P (954)655-0720
+FTLAUDERDL FL
+1 MIN
+237 11/21 02:10P (561)333-0180
+WPALMBEACH FL
+1 MIN
+239 1121 0236P
+INCOMING
+2 MIN
+OMING
+2MIN
+241
+11/21 03:16P
+3MIN
+UNLIMITEB WIND MIN
+NOWAD MIN
+240 11/21 02:54P
+INCOMING
+NCOMING
+242
+3MIN
+11/21 03:59P (561)252-4753
+WPALMBEACH FL
+243 11/21 05:20P (561)502-4728
+WPALMBEACH FL
+THIN
+UNLATEDNE
+UNLIMIT
+N/WKND MIN
+1 MIN
+244
+11/21 05:298
+245
+NCOMING
+2 MIN
+1/21 07:54P (561)502-472
+MPALMBEACH FI
+1 MIN
+UNLIMIT
+ED N/W
+246 11/21 09:14P (561)502-4728
+WPALMBEACH FL
+1 MIN
+247 11/21 0926P 561712-3087
+WPALMBEACH FL
+MPALMBEACH FI
+UNLIMIT
+1V21 11:14P
+(815)621-6100
+ROCKFORD IL
+1 MIN
+INLIMITED NWRND MIl
+11/22 11:27A
+NCOMING
+1 MIN
+UNLIMIT
+D NWKND MI
+INCOMING
+11/22 01:10P (561)333-0224
+NCOMING
+20 MIN
+0.09 AIRTIME MINUTES
+2 MIN
+0.09 AIRLIME MINUTES
+MPALMBEACH FI
+1 MIN
+2.09 AIRTIME MINUTES
+1.80
+EEEEEEEEEEEEEEEE
+(561)723-7752
+(561)313-6730
+: (561)333-9056
+(561)313-6730
+5611723-7559
+3-8559
+(561)793-7719
+11/20 11:34P (561)308-0282
+213 11/20 11:34P
+214 11/21 12:26A (561)308-0282
+215 11/21 12:57A (561)308-0282
+216 11/21 12:58A (561)308-0282
+217 11/21 02 31A (561502-4728
+318 11/21 00.90
+219 11/21 02:55A (561)723-7752
+220 11/21 18:7A
+222 11/21 10:50A (561)723-7752
+223 1121
+19:57A
+61|723-775
+5611317-334
+225 11/21 11:12A
+225 11/21
+1133A (561) 333-0220
+228 11/21 11:44A
+29 11/2
+11:50A
+5611317-4115
+230 11/2
+11:58A
+585|802-8561
+231 11/21
+11:59A
+232 11/21 12:17P (561)793-9291
+233 11/21 12:24P
+234 11/21
+12:47P
+235 11/21 01:17P (561)317-4115
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FLI
+INCOMING
+WPALMBEACH FL
+INCOMING
+NCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+AKE WORTH F
+VPALMBEACH F
+WPALMBEACH FL
+ROCHESTER NY
+INCOMING
+INCOMING
+WPALMBEACH FL
+NCOMING
+NCOMING
+WPALMBEACH FL
+1 MIN
+1EVT
+1 MIN
+1 EVT
+1 MIN
+2MIN
+EV
+Mil
+1 KN
+9MIN
+1MIN
+3MIN
+1 MIN
+17MIN
+OMIN
+1 MIN
+2MIN
+2MIN
+4MIN
+1 MIN
+1EVT
+1 MIN
+SMIN
+1 MIN
+2MIN
+MESSAGE
+RETRIEVAL
+GALIMITED NAWKND MIN
+CALMED NWIND MIN
+JWKNO MIN
+UNLIMITED
+N/WKND
+zzzzz
+N/WKND MIN
+VLIMITE
+ITED
+NLIMITED N/WKND M
+CALL WAITING
+UNLIMITED N/KND MIN
+11
+B==
+03:36A
+03:41A
+WPALMBEACH FL
+LAKE WORTH FI
+NEW
+IK NY
+NCOMIN
+WPALMBEACH FL
+INCOMING
+VPALMBEACH F
+JCOMING
+LAKE WORTH FL
+WALNBEACH
+WPALMBEACH
+FL
+INCOMING
+INCOMING
+COMIN
+COMIN
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+ICOMIN
+(PALMBEACH F
+FTLAUDERDL FL
+INCOMING
+INCOMING
+WPALMBEACH FL
+NCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+NOOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+0.09 AIRTIME MINUTES
+0.09 AIRTIME MINUTES
+AIRTIME MINUTES
+AIRTIME
+MINUT
+ARTME MINUTES
+09
+AIRTME MINUTES
+AIRTIME MINUTES
+8.09
+ARTME MINUTES
+AIRTIME MINUTES
+.OS
+09
+BIME MINUTE
+NUTE
+.09
+| AIRTIME MINUTES
+0.09 ALL MEAMTINTES
+ED
+N/WKND
+0.
+
+ED N/WKND
+1 MIN
+SMIN
+OMIN
+1 MIN
+4 MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+2 MIN
+1 MIN
+1 MIN
+8MIN
+1
+!!!
+LE0600000 D
+!!!!
+WKND
+
+
+0.000003031
+
+Item Date Time Called
+301 11/25 02:19P (561)753-5472
+302 11/25 03:36P
+561252-4753
+Calls To
+WPALMBEACH FL
+WPALMBEACH FL
+303 1/23 0921Р
+5183-2513
+11/25 09:28P
+(561)313-6730
+307 1/25 10:078
+5611313-6730
+308 11/25 10:30P (561)308-0282
+309 11/25 10:41P (561)313-6730
+310 11/25 10:41P (561)723-7752
+FEEEEFEEFE
+- 1012P (561)723-775
+1:441
+LAKE WORTH FL
+WPALMBEACH FL
+LAKE WORTH FL
+WPALMBEACH FL
+LAKE WORTH FL
+WPALMBEACH FL
+(PALMBEACH F
+COMIN
+07:48A
+07-53A
+08:16A
+9:227
+1:03
+INCOMING
+NCOMING
+288
+(561)313-6730
+730
+366
+730
+(561)723-7752
+(561)313-6730
+(561)248-6370
+(561)313-6730
+(561)313-6730
+561)502-4728
+
+1134A (561)502-4728
+188I5I93
+INCOMIN
+INCOMING
+WPALMBEACH FL
+INCOMING
+FL
+
+FL
+WPALMBEACH FL
+NCOMING
+Onty
+Used Rate Description
+6MIN
+2MIN
+1 MIN
+LIMITED N/WKND M
+IMIN
+LIMITED NWKND M
+1 MIN
+1 MIN
+NLIMITED NWKND MI
+SMIN
+NLIMITED N/WKND MI
+4 MIN
+ESSAGE RETRIEVA
+INLIMITED N/WKND MIl
+1 MIN
+IMIN
+I MIN
+UNLIMIT
+D N/WKND MIT
+I MIN ARE NOTES
+1 MIN
+0.09 AIRTIME MINUTES
+SMIN
+0.09 AIRLIME MINUTE:
+•FFFFF
+1 MIN
+1 MIN
+0.08
+.09
+
+
+Item Date Time Called
+364 11/27 12:10P (561)798-3650
+365 11/27 12:10P
+(561)793-0345
+369 11/27 1212P 561/6353253
+368 11/27 12:14P (561)707-2657
+9112 1230
+127 0127
+(561)313-6730
+371 11/27 03:05P
+561)795-2149
+7 06:47P (561)308-028.
+Calls To
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACHEL
+WPALMBEACH FL
+NCOMING
+LAKE WORTH FL
+WPALMBEACH FL
+COMING
+(PALMBEACH F
+373 11/27 07:11P (561)723-7752
+379 1427 0800Р
+378 11/27 08:29P
+79 11/27 09:448
+80 11/27 09-54P
+382 11/27 11:30P (561)308-0282
+
+DIO CO
+88
+38
+25
+-3454
+(561)635-3454
+28
+:52P
+assessess
+555..
+МОНА НЕЛ
+D 02 ALO
+TC
+0702 02 cr
+сосо со со
+(56
+)602-
+-9566
+VPALMBEACH F
+COMING
+COMING
+COMING
+INCOMING
+Onty
+Used
+Rate Description
+1 MIN
+1 MIN
+I MIN
+7MIN
+EMIN
+JNLIMITED NAWKND MIN
+INLIMITED NOWKND MIN
+6MIN
+4MIN
+NLIMITED N/WKND MI
+1 MIN
+1EVT
+NLIMITED N/WKND MI
+MESSAGE RETRIEVAL
+EMIN
+NAMITE WE MI
+VLIMI
+1 MIN
+1 MIN
+UNLIMITED NIWKND MIN
+W/WKND MIN
+1 MIN
+1 MIN
+1 MIN
+FL
+ший її
+FL
+WPALMBEACH FL
+--
+INCOMING
+F1
+LAKE WORTH FL
+INCOMING
+NLIMIT:
+ESSAG
+WKND M
+-TRIEV
+1 MIN
+3MIN
+1 MIN
+i MIN
+1 MIN
+шШШ!
+1 MIN
+1 MIN
+2MIN
+1 MIN
+4MIN
+88
+0.0
+0.09 AIRTIME
+0.09 AIRTIME MINUTEC
+doddddi
+S808833
+_09
+18
+36
+
+
+
+Item Date Time
+Called
+425 11/29 05:18P
+426 11/29 06:20P
+(561)723-7752
+7 11/29 06:2
+(5611317-3348
+8 11/29 06:2
+5611753-1604
+429 11/29 06:29P
+130 11/29 07.67P (561)876-2331
+432 11/29 07:10P (561)723-7752
+34 11/29 09:13
+435 11/29 09:09P
+136 11/28 19:54P
+Calls To
+INCOMING
+WPALMBEACH FL
+WALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+INCOMING
+(954)655-0720
+139 11/30 03:05P
+(561j635-3454
+440 11/30 03:29P
+130 04:0
+2 11/30 04:0
+443 11/30 04:18P
+115 1130 0427P {
+611333-022
+61j248-94
+446
+30 04:30P
+447
+30 04:32P (917)855-3363
+448
+1/30 04:99
+11/30 04:59P
+451
+05:13P
+11/30 05:31P (917)855-3363
+05:34F
+11/30 06:32P
+455
+11/
+456
+11,
+130 07:03P
+07:18P
+NCOMING
+INCOMING
+NCOMING
+NCOMING
+INCOMING
+/PALMBEACH !
+VPALMBEACH I
+INCOMING
+NEW YORK NY
+NCOMING
+NCOMING
+NCOMING
+NEW YORK NY
+INCOMING
+OMING
+INCOMING
+NCOMING
+COMINC
+Onty
+Used Rate Description
+1MIN 0.09 AIRTIME MINUTES
+3MIN
+0.09 AIRTIME MINUTES
+3 MIN 0:09 AIRTIME MINUTES
+11 MIN
+0.09 AIRTIME MINUTES
+1 MIN
+3MIN
+0.09 ARU
+MINUTE
+0.09 ARTIME
+NUTE
+SMIN
+0.09 AIRTIME MINUTES
+3MIN
+4MIN
+SMIN
+0.08 AIRTIME MINUTES
+0.09 A|P
+TMIN
+1MIN
+INLIMITED N/WKND MIN
+7MIN
+NUMITED WAND MI
+3MIN
+09 AIRTIME MINUTE
+3MIN
+0.09 AIRTIME MINUTES
+1 MIN
+AIRTIME
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+2MIN
+1 MIN
+.09 AIRTIME
+0.09 AIRTIME
+09 AIRLIN
+3MIN
+2 MIN
+(MIN
+1 MIN
+0.09 AIRTIME
+SMIN
+1 MIN
+6MIN
+0.09 AIRTIME
+17MIN
+1 MIN
+0.27
+.99
+.09
+27
+45
+0.27
+0.36
+0.27
+27
+
+157
+11/30 09:00P
+458
+11/30 09:19P
+(561)938-0654
+459 11/30 09:22P
+160 11/30 18:03P (561)346-1086
+163 11/30 1024P
+464 11/30 10:45P
+465 11/30 11:11P (561)644-7633
+466 11/30 11:18P
+167 12/01 01:00A (561)502-4728
+168 12/01 01:004
+490 1281
+12/01 01:08A
+01:12A
+471 12/01 01:13A (561)723-7752
+472 12/01 01:17A
+473 12/01 01:20A (561)723-7752
+474 12/01 01:20A (561)723-7752
+475
+476
+12/01 19:50A (561856-1885
+477 12/01 12:04P
+178
+55
+12:14P
+561 317-3348
+(561)723-7752
+480
+12
+481฿
+482
+483
+484
+485
+12
+
+12:36P
+12:43P
+12:45P (561)248-9412
+12.588
+01:00P (561 248-9412
+01:50P
+02:57P
+PALMBEACH
+ОДІ МедС
+INCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+NCOMING
+NOOMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+NCOMING
+DAIM BEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+1 EVT
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+3 MIN
+3 MIN
+2MIN
+1 EVT
+1 MIN
+1 MIN
+2 MIN
+1 MIN
+1 EVT
+SMIN
+1 MIN
+1 CUT
+7 MIN
+3MIN
+1 EVT
+1 MIN
+10 MIN
+1 MIN
+3MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+2MIN
+3MIN
+UNLIM
+0.09 AIRTI
+0 00
+8.09 AIRT
+00 A
+2.09 AIRTINE
+0.09 AIRTIME
+
+0000000000g
+Onty
+Item Date Time Called
+Calls To
+Used Rate Description
+486 12/01 04:56P
+INCOMING
+2MIN 0.09 AIRTIME MINUTES
+487 12/01 05:10P
+INCOMING
+2MIN
+0.09 AIRTIME MINUTES
+189 12/01 09:10P (561)379-4845
+WPALMBEACH FL
+489 12/01 0
+INCOMING
+AMIN 009 ONLIMITED NWKND MIN
+490 12/01 10:01 (954)655-0720
+FTLAUDERDL FL
+491
+12/01 10:06P
+3MIN
+NCOMING
+492 12/01 10:08P
+NCOMING
+INLIMITED N/WKND MIN
+493 12/01 10:15P (561)635-3454
+WPALMBEACH FL
+IMIN
+JNLIMITED WEND MIN
+1 MIN
+494 12/01 10:16P
+(5611798-3650
+WPALMBEACH FI
+495 12/01 10:26P (561)798-3650
+WPALMBEACH FL
+SMIN
+INLIMITED WEND MIN
+22 MIN
+UNLIMIT
+ID NWKND MIN
+496 12/02 12:53P
+INCOMING
+1 MIN
+0.09 AIRTIME MINUTES
+497 12/02 01:54P
+NCOMING
+498 12/02 09:26P
+NCOMING
+16 MIN
+1.09 AIRLIME MINUTE
+NLIMITED N/WKND MIl
+499 12/02 09:41P
+INCOMING
+1 MIN
+CALL WAITING
+
+0.18
+0.18
+500 12/02 09:50P (561)723-7752
+55
+(954)655-0720
+(561)202-7649
+(772)215-
+-5265
+8888
+
+04
+09:
+:30A
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FI
+WPALMBEACH FL
+INCOMING
+INCON
+MING
+FTLAUDERDL FL
+INCOMING
+COMIN
+COMIN
+INCOMING
+NEW YORK N
+LAKE WORTH FI
+NEW YORK NY
+ICOMIN
+PALMBEACH F
+WPALMBEACH FL
+WPALMBEACH F
+NCOMING
+INCOMING
+STUART FL
+WPALMBEACH FL
+WPALMBEACH F.
+NCOMING
+COMING
+COMING
+NCOMING
+COMING
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+1 MIN
+1 MIN
+1 MIN
+3222*
+1
+1M
+1 MIN
+1 MIN
+1 MIN
+2MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+1 AN
+3MIN
+SMIN
+2MIN
+TWIN
+1 MIN
+7MIN
+1 MIN
+1EVT
+SMIN
+EMIN
+1 MIN
+7MIN
+MIl
+2MIN
+UNLIMITED NIWKND MIN
+IN
+2.0%
+AIRTIME
+INU
+
+
+
+N/WKND M
+1635-
+WPALMBEACH FI
+NCOMING
+LAKE WORTH FL
+PALMBEACH
+KE WORTH
+WPALMBEACH FL
+1 EVT
+SMIN
+2MIN
+2 MIN
+1 MIN
+1 MIN
+2 MIN
+1 MIN
+2 MIN
+1 MIN
+SPECAL NOMBER CALLS
+UNLIMITED WIND MIN
+UNLIMIT
+UNLITE MAKIN
+JNLIMI
+UNITED WAD MIN
+2E0E000000
+
+
+660600000°0
+
+Called
+Item Date Time
+547 12/04 05:05P
+548 12/04 05:25P
+12/04 06:
+551
+02-0566
+12/04 06:56P (561 602-9566
+12/04
+04 06.38P
+(561)502-4728
+554
+12/04 07:14P
+(561)313-6730
+1204 0728P 581833-8180
+557
+12/04 07:21P
+130407-380
+560
+12/04 08:00P (561333-0180
+| 09:04P
+12/04 09:06P
+10:16F
+12
+04 10:52₽
+19541655-0720
+21A
+(561)543-3802
+(561)502-4728
+561)676-7438
+561)543-3802
+(954)655-0720
+561 502-4728
+(56
+1333-0180
+561)333-9056
+3051583-4959
+:22A
+582
+12
+
+10:53P
+(561)602-9566
+108P
+(561)635-7164
+5 12:22A
+12/05 12:23A
+(561)333-0180
+
+(954)655-0720
+
+12:29/
+0-026
+12:43A
+12:44A
+(561)793-7719
+561)543-3802
+
+L45A
+B838929333
+561)333-0180
+(305 583-4959
+3051583-4959
+5611533-3058
+(561
+9056
+80
+40CQ
+(252-2171
+(561)502-4728
+S93593258
+SHEREE
+1:3802
+-3289
+-0180
+-1885
+-9566
+(561)252-4753
+Calls To
+INCOMING
+INCOMING
+AKE
+LAKE WORTH FL
+COMIN
+PALMBEACH F
+LAKE WORTH FL
+INCOMING
+INCOMIN
+WPALMBEACH FL
+INC
+OMING
+INCOMING
+COMING
+UDERDL F
+LAKE WORTH FL
+NCOMING
+WPALMB
+BEACH FL
+INCOMING
+COMIN
+PALMBEACH F
+EACH
+FTLAL
+WPAI
+MIAMI
+SACH
+WPALMBEACH FL
+FTLAUDERDL FI
+COMING
+COMI
+DAI MRSACH
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+MIAMI
+MIAMI
+NPALMBEACHE
+EACH FL
+IN
+EACH
+FL
+INCOMING
+WPAL!
+WPALM
+AC
+EA
+PALM
+LAKE
+WPALMBEACH FL
+Onty
+Used Rate Description
+1 MIN
+1 MIN
+1 MIN
+IM
+1 MIN
+1 MIN
+2 MIN
+1 MIN
+MIt
+1 MIN
+IMIN
+IMIN
+1 MIN
+1MIN
+LIMITED N/WKND M.
+VLIMITED NIWKND M
+UNLIMITED NWKND MIT
+UNLIMIT
+ID N/WKND MIN
+UNLIMITED WINDMIN
+INLIMIT
+INLIMITED NWAND MI
+UNLIMIT
+D N/WKND R
+JITED AND MIN
+2MIN
+1 MIN
+2 MIN
+1 MIN
+2 MIN
+2 MIN
+1MIN
+2MIN
+2MIN
+1 MIN
+4MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+1M N
+1 MIN
+SMIN
+I MIN
+1 MIN
+SMIN
+SMIN
+3MIN
+IMIN
+4 MIN
+1 MIN
+3MIN
+14MIN
+2MIN
+SMIN
+8898=8 2888888888888888
+-000 020710001210022
+AIN
+Item Date Time Called
+610 12/05 11:19A (561)333-0225
+611 12/05 11:34A
+(561)644-7633
+12 12/05 11:35A (561)793-9291
+13 12/05 11:42A
+Calls To
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+614 12/05 11:43A
+615 12/05 12:05P
+6191205 01085 (561635-3454
+12/05 01:18P
+618 12/05 01:27P (763)442-0904
+619
+620 1205 8138P
+5b11333-6107
+561 333-6107
+21 1205 0131
+22 12/05 01:33
+23 12/05 0206P (561)635-716
+INCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+TWINCITIES MN
+WPALMBEACH FL
+WPALMBEACH
+INCOMING
+INCOMING
+WPALMBEACH FL
+Onty
+Used
+Rate Description
+15MIN
+2MIN
+3 MIN
+JNLIMITED N/WKND MIN
+SMIN
+JNLIMITED N/WKND MIN
+1 EVT
+CALL WAITING
+INLIMITED N/WKND MIN
+ALL WAITING
+11 MIN
+2MIN
+UNLIMITED NAWEND MIN
+UNLIMIT
+N/WKND MIN
+NIMILED NºWKND MIl
+NLIMITED NIWKND MI
+Malli
+MIT
+1 EVT
+UNLIMITED NIWKND MIN
+JNLIMIT
+CALL WAITING
+NUMITED N/WKND MIl
+
+880080028838809000888g884882088883 808
+8888
+8998888300888888282888289888888888 8889
+24 12/05 02-28
+INCOMING
+(561)723-7752
+(561)723-
+-8559
+(561)
+888
+(56
+18
+9412
+(561)719-6438
+(917)855-3363
+1)333-9056
+(561)
+9888
+109
+-0282
+88
+-9056
+-7719
+FL
+ED
+INCOMING
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+1EVT
+1 MIN
+1 MIN
+6MIN
+c
+8988 998988988888893
+MESSAGE RETRIEVAL
+0000
+8888
+TIME MINUT
+AIRTIME
+AIRTIME
+MINU
+MINUT
+AIRTIME MINUTES
++0000
+0.
+- 0000
+0000
+popp
+0.27
+0.54
+
+
+
+Item Date Time
+Called
+670 12/06 06:38P
+671 12/06 07:45P
+673 12/06 08:22F (561)333-0225
+674 12/06 08:23P
+75 12/06 08:35P
+76 12/06 08:38F
+677 12/06 08:44P (561)502-4728
+678 12/06 08:59P
+(561|333-0225
+679 12/06 09:03P
+680 12/06 09:24Р
+681 12/06 10:31P
+(561)723-8559
+B2 12/06 10:35F
+(561|512-3067
+83 12/06 10:37P
+684 12/06 11:21P (561)308-0282
+685 12/06 11:22P (561)628-1629
+686 12/07 01:36P
+687 12/07 03:06P
+1 03:06P 1561)602-9566
+689 12/07 03:07P
+(561
+602-
+-95
+590 12/07
+14:181
+14:441
+333-0225
+581635-6986
+692 12/07 95:990
+Calls To
+INCOMING
+INCOMING
+WPALMBEACH FL
+NCOMING
+INCOMING
+INCOMING
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+NCOMING
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+AKE WORTH F
+AKE WORTH FI
+LAKE WORTH
+JJ
+FL
+WPALMB
+WPALMBEAC
+T T
+INCOMING
+INCOMING
+694
+695
+696
+12107
+25:24฿
+12/07 05:45P
+(561)252-1031
+697
+698
+12/07 87 18P
+12/07
+699 12/07 07:51P
+700
+707/
+561)313-6730
+702 12/07 08:53P
+(561)793-7719
+183 12/87 09:040
+561)333-0180
+12/07 09:04F
+
+5611313-6730
+(561)798-0695
+707 12/07 11:23P (561)723-7752
+709 12/08 08:08F
+12/08 03:08F
+710 12/08 03:21P
+712 12/08 0823P
+713 12/08 09:08P
+71S 1209 18:35P (561602-9566
+719
+718 12/09 05:06P
+719 12/09 06:19P (561)308-0282
+720 12/09 06:21P
+12/09 08:02P
+2/09 08:03P
+723 12/09 08:14P
+(581)723-712
+2/09 08:29F
+23 12008:29
+729 1209 08 41P (561)602-9566
+728 12/09 08:52P (713)376-9073
+729 1209 09 15P 1561723-7752
+NCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+COMING
+INCOMING
+COMING
+WORT
+WPALMBEACH
+NPALMBEACH
+AKE WORTH
+WPALMBEACH
+ґҐЕґҐ
+COMING
+WPALMBEACH FL
+COMING
+INCOMING
+ICOMINI
+COMIN
+INCOMING
+AKE WORTH F
+COMING
+NCOMING
+COMIN
+INCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+INCOMING
+WPAIMRFACH FI
+INCOMING THEL
+HOUSTON TX
+WPALMBEACH FL
+Onty
+Used
+10MIN
+1 MIN
+4MIN
+1 MIN
+1 MIN
+2 MIN
+2MIN
+1 MIN
+1 MIN
+1 MIN
+4MIN
+Rate Description
+0.09 AIRTIME MINUTES
+0.09 AIRTIME MINUTES
+0.09 AIRTIME MINUTES
+0.09 AIRTIME MINUTES
+0.09 AIRTIP
+E MINUTES
+0.09 AIRTIME MINUTES
+0.09 AIRTIME MINUTES
+2 MIN
+1 MIN
+VLIM
+1 MIN
+3MIN
+1 MIN
+EV
+ESSAGE RETRIEVA
+9MIN
+VLIMITED N/WKND MI
+0.09 AIRTIME MINUTES
+1 MIN
+1 MIN
+OR ALTONE MINUTES.
+1 MIN
+18MIN
+AIRTIME
+MINUTE
+O 0C
+3 MIN
+0.09 AIRTINE
+MINUL
+SMIN
+1 MIN
+0,09 AIRTIME
+1 EVT
+CALL I
+MINUTE
+WA
+ANU
+AITING
+1 MIN
+09 AIRTIM
+3MІN
+2MIN
+09 AIRTIN
+MINU
+0.09 AIRTIME MINUTES
+2MIN
+1 MIN
+0.09 AIRTIME
+0 09 AIR
+MINUTE
+AINU
+SACO
+1 MIN
+0.09 AIRTIME
+1 MIN
+1 MIN
+109 AIRTIM
+MINE
+1 MIN
+0.09 AIRTIME MINUTES
+2MIN
+1 MIN
+009 ANTED WAND MIN
+MIl
+MAI
+UNEMITED NIWAN MIN
+1 MIN
+MIl
+0:09 AIRTIME MINUTES
+1 MIN
+0.09 AIRTIME MINUTES
+3MIN
+1 MIN
+009 AIRTIME
+MINUTE
+2MIN
+3MІN
+3 MIN
+0.09 AIRTIME MINUTES MIN
+3MIN
+7 MIN
+0.09 AIRTIME MINUTES
+SMIN
+0.09 AIRTIME MINUTES
+ESSAGE RE
+2MIN
+0.09 AIRTIME MINUTES
+1 MIN
+1 MIN
+0.09 AIR TIME MINUTES
+1 MIN
+0.09 AIRTIME MINUTES
+2 MIN
+1 MIN
+0.09 AIRTIME MINUTES
+1 EVT
+MESSAGE RETRIEVAL
+2MIN
+1 MIN
+8.09 AIRTIME MINUTES
+1 EVT
+1 MIN
+0.90
+0.36
+.18
+0.18
+0.81
+0.
+27
+c000o
+09
+0.18
+8881
+o0o
+6607
+18
+88
+18
+0.18
+
+Item Date Time
+Called
+730 12/09 09:19P
+731 12/09 09:35P (713)376-9073
+12/09 10:23P
+734 12/09 10:47P (561)644-7633
+12/09 10:51P
+12/09 10:55P
+737 12/10 12:28A (561)313-6730
+739 12/10 03:08P
+12/10 03:08P
+(561)502-4728
+740 12/10 03:11P
+(561)635-3454
+742 12/10 0321P
+1561)212-8739
+744 12/10 04:13P (561)635-3454
+745 12/10 04:21P (561)644-7633
+12/10 04:23P
+747 12/10 04:25P
+Calls To
+INCOMING
+HOUSTON TX
+COMIN
+COMIN
+WPALMBEACH FL
+MOOMIN
+COMING
+LAKE WORTH FL
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+AKE WORIH F
+(PALMBEACH P
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+INCOMING
+749 1210 04 15Р (561)333-0225
+12/10
+04:45P
+04:47P
+04:48P
+04:49P
+5811232-995
+04:51P
+15511333-0180
+(561 333-0225
+10
+04:54P
+18
+04:57P
+05:00P
+2/10 05:03P
+2/10 05:04P
+(561)333-9056
+(305 583-4959
+(954)655-0720
+05:08P
+121
+10
+05:36P
+10
+08:47P (561)723-7752
+10
+08:55P
+09:04P
+09:30P
+09:33P
+Q-CC
+10:00P
+2/10 10:02P
+12/
+10:03P
+2/10
+10:13P
+10:36P
+10:36P
+900
+(561)723-7752
+10:37P
+11:15P
+5611313-6730
+11:19P i
+12/10
+11:19P
+561\262-5577
+10
+21P
+22P
+25P
+(561)313-6730
+(561 635-6986
+(561)635-3454
+27P
+29P
+30P
+1:34P
+1:49P
+12:19A
+12:58A
+561)635-3454
+
+-B454
+561602-5720
+(561)262-5577
+(561)346-1086
+01:05A
+01-58A (
+(561)313-6730
+888
+:02A
+:11A
+37A
+(561)346-1086
+NPALMBEACH FI
+NCOMING
+WPALMI
+WPALMB
+INCOMING
+_MBEACH I
+FL
+MIAMI FL
+FTLAUDERDL
+FL
+INCOMI
+INCOMING
+VPALMBEACH F
+COMIN
+INCOMING
+INCOMING
+COMI
+PALMBEACH
+INCOMING
+AKE WORTH F
+(PITER P
+INCOMING
+WPALMBEACH
+WPALMBEACH
+INCOMING
+WALMBEACH FL
+LAKE WORTH FL
+JUPITER EI
+WPALMBEACH FL
+INCOMING
+INCOMING
+LAKE WORTH FL
+INCOMING
+INCOMING
+WPALMBEACH FL
+Onty
+Used Rate Description
+1 MIN
+1 MIN
+1 MIN
+NUMITEB NWINB M
+NAWKND M
+1 MIN
+INLIMITED NIWKND MIl
+NUMITED NAWKND MIl
+1 MIN
+2 MIN
+1 MIN
+6MIN
+0.09 AIRTIME MINUTES
+0.09 AIRTIME MINUTES
+5 MIN
+5 MIN
+COS ATE MINES
+12 MIN
+2 MIN
+DOS ANTIME MINUTES
+1 MIN
+3MIN
+0.09 AIRTIME MINUTES
+09 AIRTIME MINUL
+3 MIN
+LIN
+00000
+00000
+!.....
+IN
+N
+INL
+0.54
+0.45
+1.98
+0.27
+48
+coooooooc
+EE0E000000
+IN
+
+
+
+
+Called
+Item Date Time
+793 12/11 03:48A
+794 12/11 03:53A
+2/11 03
+13554
+(561)502-4728
+12/11 04:01A (561)502-4728
+2/11
+04:11A
+14:21 A
+(561)793-9291
+2/11 04:22A (561 502-4728
+1211 88.03A
+05:09A
+1211
+5:29A (561)602-9566
+15-334
+12/11 05:34A
+12/11 02-06Р
+808
+02:01P
+611798-365
+13 376-907
+12/11 03:53P
+561)313-6730
+1311
+ол:58Р. (561)635-3454
+811 12/11 04:21P
+813 1211 08: 38P
+815 1211 06 35P (561)644-7633
+816 12/11 08:56P
+В 0 11 00 5 0 56 1 723-775
+1A 19H
+819 12/11 09:39P (561)723-7752
+829 12/41 18:17P (561)3-46-1086
+822 12/11 11:04P
+23 12/11 11:49
+824
+211
+TOTAL VOICE USAGE FOR (561)308-0282
+Calls To
+INCOMING
+INCOMING
+MERLINE
+EACH FL
+WPALMBEACH FL
+COMIN
+VPALMBEACH F
+WPALMBEACH FL
+COMING
+MINI
+LAKE WORTH FL
+INCOMING
+INCOMING
+WPALMBEACH FL
+HOUSTON T
+LAKE WORTH FL
+WPALMBEACH FL
+INCOMING
+INCOMING
+COMIN
+COMIN
+Onty
+Used Rate Description
+1 MIN
+JNLIMITED N/WKND MIl
+1 MIN
+JNLIMITED N/WKND MIl
+: MIN
+4 MIN
+1 MIN
+MI
+INCOMING
+WPALMBEACH FL
+PALMBEACH P
+COMIN
+INCOMING
+NCOMING
+NCOMING
+2MIN
+1 MIN
+7MIN
+3 MIN
+1MIN
+1 MIN
+2 MIN
+3MIN
+1 MIN
+2MIN
+I MIN
+3 MIN
+7MIN
+2 MIN
+AM
+1MIN
+MIr
+3MIN
+1 MIN
+1 MIN
+UNT AWA
+N/WKND
+UNITE AWA
+) NIWKN
+UNLIMITED N/WKND
+•N/WKN
+UNLIMITED N/WKND
+INLIM I
+TEXT/MULTIMEDIA MSGS FOR (561)308-0282
+Item Date
+Time
+Sent To/Rovd From
+1 11/19
+01:06P
+(561)602-9566
+312/01
+01:03A
+TOTAL TEXT/MULTIMEDIA MSG USAGE FOR (561)308-0282
+Charge Description
+HERE MESSAGE SENT
+*** THIS SPACE INTENTIONALLY LEFT BLANK ***
+58.32
+0.10
+0.10
+2.30
+EEOE000000
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/15a417e60da0e42086d56349ba81778da800481696e6e6afbad8bf8ab74ad63f.receipt.json b/vision-fixhub/ds9-unparsed-06/15a417e60da0e42086d56349ba81778da800481696e6e6afbad8bf8ab74ad63f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..801461e27118022febb3bef727718749eb39c783
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/15a417e60da0e42086d56349ba81778da800481696e6e6afbad8bf8ab74ad63f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -5137,
+  "dataset": "marble-joined",
+  "doc_id": "15a417e60da0e42086d56349ba81778da800481696e6e6afbad8bf8ab74ad63f",
+  "engine": "marble-apple-vision",
+  "event_count": 52,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "c45b42c4de49e68a66e55671bac370d5d25be3957844e6bb8fed7c375d4f0016",
+  "output_sha256": "5505aa34b089d946eb5c1f0bb7948794232936ce558206aec5d8447dc60de632",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/162439f347da77cfb3724e49f6050970f65cce460a517b4099ee24f4703c7cfe.md b/vision-fixhub/ds9-unparsed-06/162439f347da77cfb3724e49f6050970f65cce460a517b4099ee24f4703c7cfe.md
new file mode 100644
index 0000000000000000000000000000000000000000..a48d8dda435eeb1f4e4f316affa688625a72632b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/162439f347da77cfb3724e49f6050970f65cce460a517b4099ee24f4703c7cfe.md
@@ -0,0 +1,50 @@
+From:
+To:
+Subject: Activity in Case 9:08-cv-80119-KAM Doe |. Epstein Clerks Notice of Docket Correction and
+Instruction to Filer - Attorney
+Date: Tue, 02 Feb 2010 18:47:55 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 2/2/2010 at 1:47 PM EST and filed on 2/2/2010
+Case Name:
+Case Number:
+Filer:
+Doe L Epstein
+9:08-CV-80119-KAM
+Document Number: 458(No document attached)
+Docket Text:
+Clerks Notice to Filer re [456] Response to Motion. Two or More Document Events Filed
+as One; ERROR - Only one event was selected by the Filer but more than one event was
+applicable to the document filed. The docket entry was corrected by the Clerk. It is not
+necessary to refile this document but in the future, the Filer must select all applicable events.
+(tp)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+Bradley James Edwards
+Isidro Manuel Garcia
+Jack Alan Goldberger
+Jack Patrick Hill
+
+
+Jeffrey Mare Herman
+Katherine Warthen Ezell
+Michael James Pike
+Paul G. Cassell
+Richard Horace Willits
+Robert. Josefsberg
+Robert Deweese Critton, Jr
+Stuart S. Mermelstein
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-L
+Martin G. Weinberg
+20 Park Plaza
+Boston, MA 02116
diff --git a/vision-fixhub/ds9-unparsed-06/162439f347da77cfb3724e49f6050970f65cce460a517b4099ee24f4703c7cfe.receipt.json b/vision-fixhub/ds9-unparsed-06/162439f347da77cfb3724e49f6050970f65cce460a517b4099ee24f4703c7cfe.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a92d8ba89007e79201306aeb7e8f4f5e05784de1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/162439f347da77cfb3724e49f6050970f65cce460a517b4099ee24f4703c7cfe.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "162439f347da77cfb3724e49f6050970f65cce460a517b4099ee24f4703c7cfe",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "82d02e0b192b6eeea50afc3fae25def01948071a1b68077d9c5e7464eb7f57ee",
+  "output_sha256": "154fe16a015f1686bc5db5827059e05f1ae46c913d512cee701f7ed03f3315c5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/16334455476639676c81664264af8f4810bc822740820ff057a11945232252ee.md b/vision-fixhub/ds9-unparsed-06/16334455476639676c81664264af8f4810bc822740820ff057a11945232252ee.md
new file mode 100644
index 0000000000000000000000000000000000000000..4d0b8491faf41ef0dde71fb270f442468a03dbb3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/16334455476639676c81664264af8f4810bc822740820ff057a11945232252ee.md
@@ -0,0 +1,80 @@
+From: Paul Cassell <
+To: "!
+(USAFLS)" <
+1. (USAFLS)"
+Cc: "
+(USAFLS)" <
+>, Brad Edwards
+Subject: RE: Judge Marra's Order Granting the Victims' Motion to Compel Discovery Within 30 Days
+Date: Tue, 25 Jun 2013 00:46:56 +0000
+Importance: Normal
+Attachments: ORDER-omnibus-wrapup.pdf
+[tried to send this earlier, but it may not have gone out]
+Dear
+We haven't seen the sealed order granting the Government's motion for stay either. (Have you?).
+But, in any event, Judge Marra's order on June 19, 2013 (DE 190) specifically stated that "The petitioners' motion to
+compel discovery from the Government [DE 130] is GRANTED. Within THIRTY (30) DAYS from the date of entry of this
+order, the Government shall ... [produce various discovery]." For your convenience, I attach a copy of DE 190 ordering
+the Government to produce discovery within 30 days.
+So we are expecting to see you produce the bulk of our discovery on July 19, 2013, as specifically directed in DE 190
+which granted our motion to compel.
+Looking forward to moving the case towards a resolution.
+Brad Edwards and Paul Cassell for Jane Doe #1 and Jane Doe #2
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+S.J. Quinney College of Law at the University of Utah
+332 S. 1400 E., Room 101
+Salt Lake City, UT 84112-0730
+(phone)
+(tax)
+You can access my publications on http://ssrn.com/author=30160
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee.
+If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in
+error, please immediately notify the sender by reply electronic mail and delete the original message. Professor Cassell is admitted to the Utah State
+Bar, but not the bars of other states. Thank you.
+Sent: Monday, June 24, 2013 5:24 PM
+To: Paul Cassell;
+L. (USAFLS)
+I (USAFLS); Brad Edwards
+Subject: RE: One additional discovery request in Jane Doe #1 and Jane Doe #2 vs. U.S., No. 08-80736
+Paul,
+You have addressed your additional discovery request to the correct person. In the Court's order denying the
+government's motion to dismiss, the Court referenced "[t]he stay of discovery pending ruling on the government's motion
+to dismiss entered November 8, 2011 [DE #123] is LIFTED." I checked back into my CM/ECF notifications on Outlook,
+
+
+and did not find any for D.E. 123.I checked the docket sheet, which indicates a sealed order being entered on November
+9, 2011, which is D.E. # 123.
+I was under the impression the Court had not ruled on the government's motion to stay. On December 6, 2012, the
+petitioners filed their Motion for Prompt Ruling Denying Government's Motion to Stay (D.E. 179), in which the petitioners
+noted that, "It]he government's motion was filed more than one year ago, yet (presumably because of a flurry of other
+motions) the Court has yet to rule on this particular motion." From this, it appears petitioners also believed the Court
+had not ruled on the government's motion for stay.
+In any event, your e-mail states that "you look forward to receiving the discovery materials that the Court has ordered you
+to produce on the schedule that the Court has ordered them produced." What is your view as to the schedule that the
+Court has ordered the documents produced? Is that contained in D.E. 123? Thanks.
+From: Paul Cassell [mailto:
+Sent: Monday, June 24, 2013 4:07 PM
+I. (USAFLS);
+(USAFLS); Brad Edwards
+Subject: RE: One additional discovery request in Jane Doe #1 and Jane Doe #2 vs. U.S., No. 08-80736
+Dear
+I am writing to confirm that you remain the person that we should be contacted with regard to the above-captioned
+case. If not, please advise as to who the appropriate contact person is (and please forward this message to that person).
+In light of the Court lifting the stay on discovery, we are writing send one additional discovery request. Of course, this
+request is in ADDITION to the requests previously sent. It should not be viewed as replacing the other discovery requests
+or extending the deadline for producing the materials covered by the other discovery requests.
+We look forward to receiving the discovery materials that the Court has ordered you to produce on the schedule that the
+Court has ordered them produced.
+Please let us know if you have any questions.
+Paul Cassell and Brad Edwards for Jane Doe #1 and Jane Doe #2
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+S.J. Quinney College of Law at the University of Utah
+332 South 1400 East, Room 101 Salt Lake City, UT 84112-0730
+http://www.law.utah.edu/profiles/default.asp?PersonlD=57&name=Cassell,Paul
+You can access my publications on http://ssrn.com/author=30160
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee.
+If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in
+error, please immediately notify the sender by reply electronic mail and delete the original message. Professor Cassell is admitted to the Utah State
+Bar, but not the bars of other states. Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/16334455476639676c81664264af8f4810bc822740820ff057a11945232252ee.receipt.json b/vision-fixhub/ds9-unparsed-06/16334455476639676c81664264af8f4810bc822740820ff057a11945232252ee.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..91088920349b4e012fe0746c29eab71f7f180e37
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/16334455476639676c81664264af8f4810bc822740820ff057a11945232252ee.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "16334455476639676c81664264af8f4810bc822740820ff057a11945232252ee",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "a7b8f3f435248f82b5b0e72d661464deb0adaf17e722eda336edbf151a5aa7e0",
+  "output_sha256": "43c0c5e49f333bc6ceede3b9f298d7dee787564ab99be0be10bab641ae1789a2",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1676643088e82ee8bd149930982a01133ed6ea1be872ea7c148b2ba9b173ffab.md b/vision-fixhub/ds9-unparsed-06/1676643088e82ee8bd149930982a01133ed6ea1be872ea7c148b2ba9b173ffab.md
new file mode 100644
index 0000000000000000000000000000000000000000..9669dd702f1e077df4bb144e8d786da7331d4dae
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1676643088e82ee8bd149930982a01133ed6ea1be872ea7c148b2ba9b173ffab.md
@@ -0,0 +1,16 @@
+From: "
+To:
+(USAFLS)"
+(USAFLS)" <
+Subject: Draft Response to Letter
+Date: Thu, 02 Aug 2007 20:54:42 +0000
+Importance: Normal
+Attachments: 070802[
+Itr_from
+P.
+| (USAFLS)" <
+| (USAFLS)"
+L.wpd
+Here is a draft. I put tomorrow's date on it so
+will have time to talk to
+Assistant U.S. Attorney
diff --git a/vision-fixhub/ds9-unparsed-06/1676643088e82ee8bd149930982a01133ed6ea1be872ea7c148b2ba9b173ffab.receipt.json b/vision-fixhub/ds9-unparsed-06/1676643088e82ee8bd149930982a01133ed6ea1be872ea7c148b2ba9b173ffab.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2e9ac99875afadb0170675d7800a972c79f169d7
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1676643088e82ee8bd149930982a01133ed6ea1be872ea7c148b2ba9b173ffab.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "1676643088e82ee8bd149930982a01133ed6ea1be872ea7c148b2ba9b173ffab",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "f5cbe992e34131232da77a9044738e2235d4f97b9474462f182715da6cc22f03",
+  "output_sha256": "a88ef59ab99f77b38a91f74035f21685baabc8b50cbae0cd417199b31404a3ed",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/17d6d99e1654ad08be7d15dca1ff8f2fe6a922c98ec6975cfef7b8ef045f115c.md b/vision-fixhub/ds9-unparsed-06/17d6d99e1654ad08be7d15dca1ff8f2fe6a922c98ec6975cfef7b8ef045f115c.md
new file mode 100644
index 0000000000000000000000000000000000000000..6af6e1497abab0d8d12ae9b7dee561cf7cb85716
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/17d6d99e1654ad08be7d15dca1ff8f2fe6a922c98ec6975cfef7b8ef045f115c.md
@@ -0,0 +1,2154 @@
+Questions or Changes?
+* attwireless.com
+Toll Free 1 866 293-4634
+611 from your wireless phone
+• TTY users - 1 866 4-AWS-TTY
+SUMMARY OF MONTHLY CHARGES FOR ACCOUNT
+Previous
+Payments
+Account
+Balance
+Received
+Adjustments
+1459.57
+-1459.57
+0.00
+Your billing cycle ended on July 02, 2004
+Current Monthly Charges
+Subscriber Adjustments
+Monthly Service
+Monthly Usage
+Charges
+Credits
+Taxes, Surcharges & Regulatory Fees
+Total Current Monthly Charges DUE UPON RECEIPT
+TOTAL AMOUNT DUE
+Balance
+Forward
+0.00
+Date of Invoice: July 03, 2004
+Current Monthly
+Charges
+335.69
+Total
+Amount Due
+335.69
+0.00
+186.68
+91.71
+0.00
+0.00
+57.30
+335.69
+335.69
+ALL MONTHLY CHARGES IN YOUR BILL ARE DUE & PAYABLE FOR
+THE ENTIRE BILLING CYCLE COVERED BY THE BILL. FOR ANY
+TERMINATION (INCLUDING WHEN YOU SWITCH YOUR WIRELESS
+NUMBER TO ANOTHER CARRIER), YOU WILL BE RESPONSIBLE FOR
+PAYMENT FOR ALL FEES AND CHARGES THROUGH THE END OF THE
+BILLING CYCLE. FOR MORE INFORMATION ABOUT BILLING AND
+YOUR RIGHTS AND OBLIGATIONS, PLEASE CONSULT THE TERMS
+AND CONDITIONS OF SERVICE IN YOUR SUBSCRIBER AGREEMENT.
+AT&T WIRELESS APPRECIATES YOUR BUSINESS
+lease Retum This Portion With Your Payment
+Wit he General Terms and Conditions tor wireles serice.
+Account Name: JEFFREY E EPSTEIN
+Note: =>
+We Print on
+Front and Back
+Date Due
+UPON RECEIPT
+Service #
+Account #
+Total
+Amount Due
+335.69
+Chack her for change.
+Amount
+Paid
+AT&T WIRELESS
+PO BOX 8229
+AURORA IL 60572-8229
+
+
+Recurring Electronic Fund Transfer (REFT): To enroll: sign below, check the REFT box on the reverse side and
+remit with this month's payment. Keep paying your bill until your statement indicates "Do Not Pay". REFT
+Agreement: 1 authorize my financial institution to deduct the amount of my monthly wireless phone bill from the
+account associated with the enclosed check and remit payment to AT&T Wireless. This authority will be effective
+until I notify AT&T Wireless to terminate it. I agree that I may be assessed a service charge (up to $20) or late fee
+or both if a payment is returned by my bank. For more information visit attwireless.com/ocs or call 1 866 293-4634.
+Please keep a copy of the form below and this REFT Agreement for your records or retain a copy of the blank form
+from next month's invoice.
+Questions? We can help: AT&T Wireless appreciates your business and welcomes the opportunity to assist you.
+As part of our commitment to you, we are always adding new calling plans and promotions to match your individual
+needs. Visit our website at attwireless.com or contact Customer Care by dialing 611 from your wireless phone or 1
+866 293-4634. ¿ Sabías que también ofrecemos servicio al cliente en tu idioma? Marca 611 desde tu teléfono
+inalámbrico ó 1 866 293 4634 desde cualquier teléfono y oprime el *.
+Driving Wireless Safety: Your wireless phone gives you the freedom and flexibility to stay in touch when you
+travel, but don't let a phone call distract you from driving safely. Use hands-free device if allowed or required by
+law. Call Carefully, Arrive Safely.
+AT&T Wireless Processing Fees: Accounts suspended for non-payment will be subject to a $25 reactivation fee
+per line and may be assessed a security deposit prior to reinstatement. Checks returned for non-sufficient funds will
+be charged up to a $20.00 fee.
+Local Tax: Local taxes are based on local government boundaries, the address information you provide for your
+account and/or your wireless telephone number. Please review the local tax charges on your bill. If you believe
+there is an error in the local tax charge, please contact us immediately at 1 866 293-4634. Please note that some
+local or state laws may require you to follow special procedures when notifying us about a local tax dispute. You
+may also use the form below to notify us of any change to your taxing address. Thank you for your cooperation.
+Early Termination Fee (ETF): If you cancel service before your contract end date (including if you switch your
+wireless number to another carrier), you will be charged an Early Termination Fee of up to $200.
+Please Send Correspondence To:
+AT&T Wireless Next Generation Correspondence
+P.O. Box 68056
+Anaheim Hills, CA 92817-8056
+2000278.000002009.6
+Change of Address Only. Please print address clearly and check the box on the reverse side. Please contact Customer Care to change the
+Name and transfer Financial Responsibility.
+New Billing Address
+City
+State
+Zip
+Home Phone (
+Work Phone (.
+If your billing address is NOT your Tax Address*, please enter the Tax Address below. (Multi-line accounts should attach a list of each wireless number and
+the respective Tax Address.)
+New Tax Address*
+Wireless Number (
+City
+State
+Zip
+Inder Federal laws, your Tax Address must be: your primary place of use, your residential or business address, and located within AT&T Wireless
+censed service area. Non-business customers on AT&T Digital One Rate, Regional Advantage or Shared Advantage plans must use their residenti
+address as their tax address.
+Recurring Electronic Fund Transfer (REFT) Enrollment. Please read the agreement on the top portion of this page, sign below and check the
+"REFT Registration" box on the reverse side.
+6.1 - 3G
+Financial Account Holder Signature
+• • I do not wish to receive email notilication of special ofers avalable to AT&T Wireless customers.
+
+
+THE CHARGE FOR AT&T WIRELESS 411 INFO IS INCREASING
+$.25. THE NEW COST OF $1.50/CALL WILL BE EFFECTIVE
+8/18/04. GET THE SAME GREAT FEATURES AND SERVICES, SUCH
+AS: DRIVING DIRECTIONS, MOVIE TIMES & RESTAURANT
+LISTINGS. WE WILL CONNECT YOU AT NO ADDITIONAL CHARGE,
+PLUS WE WILL SEND THE NUMBER VIA TEXT MESSAGE! FOR
+MORE INFO ABOUT YOUR RIGHTS AND OBLIGATIONS, CONSULT
+THE TERMS AND CONDITIONS IN YOUR SUBSCRIBER AGREEMENT.
+THE $1.75 REGULATORY PROGRAMS FEE HELPS TO FUND AT&T
+WIRELESS COMPLIANCE WITH VARIOUS GOVERNMENT-MANDATED
+PROGRAMS SUCH AS E911, NUMBER POOLING, AND LOCAL NUMBER
+PORTABILITY WHICH MAY OR MAY NOT YET BE AVAILABLE IN
+YOUR AREA. IT IS AN ADDITIONAL MONTHLY CHARGE CREATED,
+ASSESSED AND COLLECTED BY AT&T WIRELESS. FOR MORE
+INFORMATION AND A DESCRIPTION OF THESE PROGRAMS PLEASE
+VISIT OUR WEBSITE AT HTTP://WWW.ATTWIRELESS.COM/RPF
+ACCOUNT DETAILS
+Detail of Payments - Thank You!
+Item Description
+1 PAYMENT
+Total of Payments
+Current Subscriber Monthly Charges and Credits
+Subscriber Number
+Subscriber Name
+Date Applied/Reversed Payment Amount
+06/24/04
+-1459.57
+Total Current Subscriber Monthly Charges and Credits
+Total Current Monthly Charges
+SUMMARY OF CURRENT ACTIVITY
+Monthly Service Charges
+Item Description
+1 CALL WAITING
+2 AT&T TEXT MESSAGING
+3 CALLER ID
+4 EARLY EVENING
+5 ENH DISCOUNT INTL DIAL
+Service Dates
+06/03/04 - 07/02/04
+06/03/04 - 07/02/04
+06/03/04 - 07/02/04
+06/03/04 - 07/02/04
+06/03/04 - 07/02/04
+-1459,57
+-1459.57
+335.69
+335.69
+335.69
+0.00
+4.99
+0.00
+0.00
+3.99
+
+SUMMARY OF CURRENT ACTIVITY - CONTINUED
+Monthly Service Charges - Continued
+Item Description
+6 MULTIMEDIA MESSAGING $2.99
+7 AT&T VOICEMAIL
+8 MMODE/DATA SERVICE (4MB) |
+9 NATIONAL PLAN $149.99
+10 THREE WAY CALLING
+11 REGULATORY PROGRAMS FEE
+12 VOICEDIAL SERVICE $3.99
+13 DETAIL BILLING
+14 DISCOUNTED INTERNATIONAL ROAMING
+Total Monthly Service Charges
+Monthly Usage Charges
+2 400 ADD'L ANYTME MIN
+4 EARLY EVENING N/WKND
+5 DROP CALL CREDIT
+6 UNLIMITED N/WKND MIN
+9 100 INCL. MSGS SENT
+10 MESSAGE RETRIEVAL
+11 INCLUDED MINUTES
+14 LONG DISTANCE
+Total Monthly Usage Charges
+1,024 Kilobytes (KB) = 1 Megabyte (MB)
+Taxes, Surcharges and Regulatory Fees
+Item Description
+1 LOCAL WIRELESS SURCHARGE
+2 MCTD SURCHARGE
+3 FEDERAL TAX
+4 TELECOM EXCISE TAX
+5 SALES TAX
+6 ST WIRELESS COMM SURCHARGE
+7 UNIVERSAL CONNECTIVITY CHARGE
+• NY CITY UTILITY G.R. SUF
+otal Taxes, Surcharges and Regulatory Fee
+TOTAL CHARGES FOR
+Service Dates
+06/03/04 - 07/02/04
+06/03/04 - 07/02/04
+06/03/04 - 07/02/04
+06/03/04 - 07/02/04
+06/03/04 - 07/02/04
+06/03/04 - 07/02/04
+06/03/04 - 07/02/04
+06/03/04 - 07/02/04
+06/03/04 - 07/02/04
+214 MIN
+2 MIN
+763 MIN
+53 MIN
+21 EVI
+396 KB
+216 MIN
+2 MIN
+2.99
+0.00
+12.99
+149.99
+0.00
+1.75
+3.99
+0.00
+5.99
+186.68
+0.00
+19:25
+0.00
+0.00
+0.00
+15.26
+0.00
+0.00
+0.00
+0.00
+0.00
+64.80
+91.71
+2.30
+8.47
+9.27
+23.46
+1.20
+6.59
+17.30
+335.69
+
+
+DETAIL OF CURRENT ACTIVITY
+Item Date Time Called
+03 08:4
+06/03 08-4
+3 06/03 08:47A
+06/03 10:3
+06/03 10:4
+6 06/03 11:00A
+7 06/03 12:30P
+06/03 01:16P
+9
+06/03 01:35P
+19
+06/03 01:45P
+06/03 01•55P
+12 06/03 02:04P
+12 0603 0213P
+15
+06/03 02:32F
+16/03 03:40P
+17 06/03 04:47P
+19
+20
+
+
+
+88888
+88889
+99008
+61
+06/03
+09-09P
+62
+06/03
+09:19P
+(3471665-3401
+NEW YORK NY
+COMING
+COMING
+NCOMING
+COMING
+NEW YORK NY
+WPALMBEACH FL
+NEW YORK NY
+OMING
+NEW YORK NY
+NEW YORK NY
+RK
+QUEENS NY
+NEW YORK NY
+Onty
+Used Rate Description
+1MIN
+NLIM MOBL TO MOB
+O ADD'L ANYTME M
+UNLIM MOBL TO MOBL
+UNLIM MOBL TO MOBL
+400 ADD'L ANYTME MIN
+4MIN
+MIl
+4 MIN
+EMIN
+4MIN
+400 ADD'L ANYTME MIN
+100 ABB'L ANYTME MIN
+400 ADD'L ANYTME MIN
+400 ADD'L ANYTME MIN
+SMIN
+D
+UNIT
+1.
+
+Item Date Time
+Called
+64 06/03 08:27P
+65 06/03 09:28P
+6 06/03 09:58F
+06/03 10:01P
+68 06/03 10:02P
+9 06/03 10:04P
+O 06/03 10:08F
+71 06/03 10:18P
+2 06/03 10:408
+3 06/03 10:44R
+74 06/03 10:44P
+75 06/03 10:45P
+NS
+NEW YORK NY
+INCON
+NEWYORKZN1 NY
+COMIN
+LEENS N
+NEWYORKZN1 NY
+COMING
+COMING
+- Continued
+Onty
+Used
+2MIN
+2 MIN
+IMIN
+Rate Description
+UNLIMITED WIND MIN
+UNLIMITED N/WKND
+MIN
+UNLIMITEB NAWKNE
+NKND
+UNLIMITED N/WKND
+MIN
+UNLIMITED NWKND MIN
+INLIMITI
+ED NAMKND
+UNLIMITED N/WKND MIN
+2MIN
+UNLIMITED N/WKND MIN
+1 INFO
+1.25
+§ 06/03 10347
+603 10•511
+06/03
+
+
+4 MIN
+JNLIMI
+0.28
+400 ADDL
+1.25
+1.25
+NONDONNEE
+33
+ADLANTE MIN
+100 ABBL ANYTME MIN
+
+
+Item Date Time
+Called
+125 06/04 01:928
+06/04 01:380
+128 06/04 01:58P
+129 06/04 02:26P
+130 06/04 02:47P
+131 06/04 03:02P
+32 06/04 03:04P
+33 06/04 03:17P
+134
+06/04 03:18P
+35 06/04 03:24P
+136
+06/04 03:25P
+137 06/04 03:28P
+38 06/04 03:301
+39 06/04 03:31F
+141 06/04 04:18F
+06/04 04:188
+142 06/04 04:21P
+143 06/04 04:21P
+144 06/04 04:23P
+145 06/04 04:31P
+145
+04:43P
+08/04 85:17P
+148 06/04 09:30P
+149
+06/04 09:30P
+150
+06/04
+09:39P
+
+
+06/05 09:56A
+
+06/05
+10:39A
+10:41A
+06/08
+06/05
+0:41A
+8881
+06/
+
+COMINI
+IPALMBEACH F
+NCOMING
+COMIN
+PALMBEACH i
+WPALMBEACH FL
+WPALMBEACH FL
+VPALMBEACH F
+EW YORK N
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+QUEENS
+NALYACH FL
+WPALMBEACH
+WPALMBE
+FL
+DELRAY
+BOCA RATI
+WPALMBEACH
+NEW YOF
+WPALME
+FL
+WPALMBEACH
+FL
+06/05
+06/05 08:19P
+168
+06/05
+08:20P
+169
+06/05
+08:22F
+170
+06/05 08:23P
+06/0S
+08:25P
+10:28P
+06/05
+11:56P
+174
+176
+Обов 11334
+176
+06/06
+177
+06/06
+12.80
+178 06/06 01:00P
+179 06/06 01:00P
+180 06/06 01:00F
+181
+06/06 01:21P
+06/06 01:34P
+06/06
+03:06P
+06/06
+04:07P
+06/06
+04:09P
+186
+187
+06/06
+M-250
+06/
+8888฿
+1.30P
+IEW YORK N
+IEW YOR
+WPALMBEACH FL
+QUEENS
+WPALME
+ACH FL
+NWYRC
+ZN01 NY
+NABEACH
+I FL
+NEW YORK NY
+COMIN
+PALMBEACH I
+WPALMBEACH FL
+QUEENS NY
+VPALMBEACH F
+IEW YORK N
+HONOLULU H
+NEW YORK NY
+QUEENS
+§ NY
+WPALMBEACH FL
+WALMBEACH FL
+- Continued
+Qnty
+Used
+Rate Description
+6 MIN
+1100 ABB'L ANYTME MIN
+UNLIM MOBL TO MOBL
+2 MIN
+UNLIM MOBL TO MOBL
+UNLIM MOBL TO MOBL
+10 MIN
+DO ADD
+2 MIN
+2 MIN
+2 MIN
+1MIN
+2 MIN
+2 MIN
+UNLIM
+UNLIM
+UNLIM
+UNLIM
+UNLIM
+UNLIM
+UNLIM
+3MIN
+11 MIN
+4 MIN
+2MIN
+3 MIN
+2 MIN
+2MIN
+16 MIN
+1MIN
+UNLIM
+UNLIM
+UNLIN
+UNLIN
+UNLIM
+UNLIM
+UNLIM
+UNLIM
+UNLIM
+UNLIM
+UNLIM
+3MIN
+UNLIM
+UNLIM
+UNLIM
+10 MIN
+7 MIN
+UNLIM
+2MIN
+3MIN
+1M
+
+Called
+Item Date Time
+16 04•54
+194 06/06 04:58P
+195 06/06 04:59P
+196
+06/06 05:00P
+198 06/08 05:02Р
+199 06/06 05:07P
+200 06/06 05:09P
+201 06/06 10:22P
+202 06/07 08:48A
+- Continued
+Onty
+Used Rate Description
+EMIN
+NECOMING NY
+UNLIMITED N/WKND MIN
+UNLIMITED WIND MIN
+CALL WAITING
+1EVT
+2 MIN
+JEENS T
+obile Fi
+3MN
+3MIN
+3 06/07 09:01А
+06/07 09:04A
+UNLIMITED N/WKND MIN
+JNLIMITED N/WKND MIN
+CALL WAITING
+UNLIMITED N/WKND MIN
+0.28 EN BISC AT ME MIN
+100 ABBY ANYTE MIN
+0.84
+
+5/07
+N/WKNI
+
+3MIN
+4MIN
+MIN
+TO MOB
+MIN
+ТО МОВ
+
+
+Called
+Item Date Time
+4 06/08 07:19
+55 06 08 07:31
+256 06/08 07:32P
+06/08 07:46P
+06/08 08:44P
+259 06/08 08:45P
+260
+06/08 10:12P
+06/08 11:01P
+262
+06/08 11:24P
+06/08
+11:25P
+06/09 08:38A
+265
+06/09 08:43A
+06/09 08:45A
+06/09 09:20A
+06/09 09:51A
+06/09 10:18A
+10:31A
+99995
+276 06/09 01:29P
+
+#8680858-8000988398
+•21P
+QP
+03:23P
+298 06/09 03:25P
+299 06/09 03:26P
+300
+06/09
+03:36P
+201
+06/09
+03:48P
+302 06/09 03:48P
+303 06/09 03:50P
+304 06/09 06:09P
+307 06/09 06:41P
+308 06/09 06:42P
+309 06/09 06:54P
+- Continued
+Onty
+Used
+-W YORK I
+• ZONE 1N
+QUEENS NY
+NCOMING
+NEW YORK NY
+NEW YORK NY
+NCOMING
+NEW YORK NY
+NEW YORK NY
+NCOMING
+NEW YORK NY
+NY
+NEW YORK NY
+S
+NY
+NMA
+CITY NJ
+INC
+NY
+NEW YORK NY
+NEW YORK NY
+NCOMING
+NEW YORK NY
+NEW YORK NY
+NEWYORKZN1 NY
+NEW YORK NY
+NEW YORK NY
+MIN
+2 MIN
+2 MIN
+Rate Description
+ARLYEVENING AWARE
+I/WKNI
+EARLY EVENING N/WKND
+RLY EVENING NAWKI
+RLY EVENING N/WKI
+EARLY EVENING N/WKND
+UNLIMITED WINNING
+UNLIMITED N/WKND MIN
+NLIMITED N/WKND MIL
+00 ADD'L ANYTME MIl
+400 ADD'L ANYTME MIN
+100 ABBIL ANYTME MIN
+JNLIM MOBL TO MOBL
+100 ADD'L ANYTME MIN
+6MNi
+REmE
+S252
+3MN
+2 MIN
+2 MIN
+14 MIN
+EMIN
+2 MIN
+MIt
+2 MIN
+3MIN
+SMIN
+Mir
+2MIN
+1
+MOBL
+
+Called
+Item Date Time
+10 06/09 07:00
+11 06/09 07:03
+312 06/09 07:06P
+13 06/09 07:08
+4 06/09 07:10
+315 06/09 07:18P
+16 06 09 07:46
+17 06/09 07:47
+Toll Free CL
+RD N
+- Continued
+Onty
+Used
+Rate Description
+3 MIN
+EARLY EVENING ANNE
+3MIN
+EARLY EVENING N/WKND
+3 MIN
+EARLY EVEN AN
+2 MIN
+EARLY EVENING N/WKND
+EARLY EVENING NIMIN
+1 EVT
+2MIN
+2 MIN
+2MIN
+CALL WAITING
+EARLY EVENING NAWAB
+NING N/WKND
+EARLY EVENING N/WKND
+EARLY EVENING NAWKNB
+EARLY
+N/WKND
+EVENING
+N/WKND
+18 06/09 07:52
+9 06/09 07-57
+320 06/09 08:01P
+06/09 08:03
+9 08-2*
+24
+6/09 08:23F
+6/09 08-25P
+
+
+80.000
+
+
+
+
+888 888888
+
+500
+999
+06/
+10 07:46P
+COMIN
+COMIN
+NEWYORKZN1 NY
+COMIN
+JEENS N
+NG N/WKI
+FL
+QUEENS NY
+NEW YORK NY
+2MIN
+EARLY EVENING N/WKND
+EARLY EVENING N/WKND
+CARLYAVENNG NIWKND
+
+
+Item Date Time
+Called
+72 06/10 07:51
+73 06/10 07:53
+374 06/10 08:21P
+75 06/10 08:221
+76 06/10 08:24H
+377 06/10 08:26P
+378 06/10 08:39P
+379 06/10 09:05P
+BD 06/10 10:03F
+81 06/11 01:26A
+382 06/11 01:29A
+381 06/11 81:39A
+11 01:41A
+385 06/11 06:11A
+386 06/11 08:00A
+387 06/11 09:07A
+388 06/11 09:19A
+389 06/11 09:20A
+390 06/11 09:52A
+391 06/11 09.59A
+383 06/11
+394 06/11 10:06A
+395
+396
+
+NEW YORK NY
+NY ZONE 1 NY
+- Continued
+Qnty
+Used
+Rate Description
+MIl
+MIN
+2 MIN
+2 MIN
+EARLY EVENING N/WKND
+EARLY EVENING WIND
+NEW YORK NY
+NCOM
+ING
+QUEENS NY
+NEW CANAAN CT
+NEW YORK NY
+NEW YORK NY
+UK
+NEW YORK NY
+NEW YORK NY
+NEW
+442
+YORK
+NY
+W YORK NY
+I CANAAN CT
+57 MIN
+2 MIN
+2 MIN
+2 MIN
+1EVT
+1 EVT
+SMIN
+1.2
+EMIN
+2MIN
+2 MIN
+7 AAIN
+1.25
+0.06
+397 06/11 10:20A
+398 06/11
+00 6 1 10•554
+400 06/11 10:24A
+401
+402
+06/11 18:594
+10•C0Д
+403
+06/11
+11:04A
+404
+06/11
+11:15A
+405 06/11
+11:19A
+406 06/11
+11:22A
+407
+06/11
+11:29
+408
+06/11
+11:37A
+409 06/11 11:38A
+410 06/11
+11:42A
+411
+06/11
+11.46Д
+412 06/11 11:55A
+413 06/11 11:57A
+414 06/11 12:00P
+415 06/11 12:01P
+416 06/11 12:08P
+417 06/11 12:10P
+418 06/11 12:12P
+419
+420
+WPALMBEACH FL
+NEW CANAAN CT
+CHICAGO IL
+KINGPRUSSI PA
+LEW YORK N
+IDAI MREACH P
+QUEENS NY
+mobile SAF
+NEW YORK NY
+WALMBEACH FL
+NEW YORK NY
+NEW YORK N
+IY ZONE 1 N
+mobile FRA
+WPALMBEACH FL
+IWYRCYZN08 N
+ASTBOSTON M.
+mobile UK
+CHTAMSTTHS VI
+NEW YORK NY
+NEW CANAAN CT
+2MIN
+2 MIN
+2 MIN
+1 EVT
+AMIN
+TMIN
+4MIN
+3MIN
+3MIN
+OMIN
+3MIN
+EMIN
+2MIN
+2 MIN
+EVT
+2MIN
+400 AD
+1.56
+0.26
+
+EEEEEEEEE
+
+98699
+QUEENS NY
+NCOMING
+2MIN
+2 MIN
+INL
+IM
+100.
+
+Called
+Item Date Time
+129 06/11 02:271
+11 02.278
+430 06/11 02:29P
+431 06/11 02:59P
+432 06/11 03:20P
+133 06/11 08.29Р
+435 06/11 04:23P
+436
+06/11
+04:40P
+437
+06/11 05:08P
+- Continued
+Onty
+Used
+Rate Description
+2MIN
+100 ABB'L ANYTME MIN
+NEW YORK NY
+UNLIM MOBL TO MOBL
+MESSANOEL TO MORL
+NWYRCYZNOB NY
+COMIN
+UEENS N
+NEWYORKZN1 NY
+mobile UK
+SMIN
+2 MIN
+400 ADD'L ANYTME MIN
+ALAMEL TO MOM
+400 ADD'L ANYTE MIN
+438 06/11 07:09P
+138
+06/1
+1 8744P
+NEW YORK NY
+COMIN
+EWYORKZN1 N'
+QUEENS NY
+88
+9997 77 ÷9999ũ
+08:09P
+2F
+NEW YORK NY
+WPALMBEACH FL
+QUEENS NY
+UEENS NI
+IEWYORKZN2 N'
+1 MIN 0.26 ENH DISC INT DL
+MESSAGE ALTRIEVAKND
+RLY EVENING N/WH
+RLY EVENING NIWKN
+2 MIN
+3MIN
+2 MIN
+2MIN
+1 EVT
+2MN
+6MN
+1EVT
+1MIN
+EARLY EVENING N/WKND
+EARLY EVENING WIND
+EARLY EVENING N/WKND
+SAGE RETRIEVAL
+EVENING N/WKND
+EARLY EVENING N/WKND
+CALL WAITING
+N/WKND MIN
+NWKND MIN
+UNLIMİ
+N/WKND MIN
+1MIN
+2 MIN
+OMIN
+1EVT
+MIN
+4MIN
+UNLIMITED
+N/WKND MIN
+JNLIMITE
+N/WKND MIN
+INLIMI
+AWD MIN
+CALL WAITING
+N/WKND MIN
+UNLITER NAKE
+UNLIMITED N/WKND MIN
+0.26
+888
+
+
+QUEENS NY
+1EVT
+2MIN
+4 MIN
+iMIN
+2MIN
+1MN
+WAITING
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND MIN
+UNLIMITED WIND MIN
+NU
+UNLIMITED WIND MIN
+UNLI
+UNLIMITED N/WKND MIN
+UNLIMITED WIND MIN
+
+
+#0#A85N0008GS
+
+8999g8
+
+NEW YORK NY
+NCOMING
+NCOMING
+COMIN
+COMING
+COMING
+NCOMING
+3MIN
+EVT
+4MIN
+4 MIN
+3MIN
+SMIN
+2 MIN
+3MIN
+AMIN
+2 MIN
+UNLIMITED N/WKND MIN
+MESSAGE RETRIEVAL
+UNLIMITED
+UNLIMITED N/WKND MIN
+UNLIMITED WE MIN
+JNLIMI
+UNL
+_IMITE
+N/WKND MIN
+KND MIN
+N/WKND MIN
+UNITED WIND MIN
+UNLIMIT
+TINI IMIT
+UNLIMIT
+AND MIN
+N/WKND MIN
+UNLI
+IMIT
+N/WKND MIl
+UNLIMIT
+UKND MIN
+UNLIMITE
+ED N/WKND MIN
+UNLIMI
+UNLIMIT
+UNL
+UNLIMIT
+NLIM
+NUM
+N/WKND MIN
+N/WKND
+MIN
+N/WKND MIN
+D NWKND MIN
+AND MIN
+
+
+Called
+Item Date Time
+85 06/13 11:12
+06/13
+487 06/13 11:55A
+488
+06/13
+489
+11:58A
+06/13 12:01|
+NCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+490
+49
+492
+493
+06/13
+494
+06/1
+12:20P
+06/1
+495
+06/1
+49)
+06/1
+498
+0909 09 0902
+12:21P
+12.27P
+12:29P
+01:37P
+02:08P
+06/13 03:08P
+499 06/13 03:20P
+
+COMIN
+(PALMBEACH F
+FTLAUDERDL FL
+NY ZONE 1 NY
+NWYRCYZN01 NY
+NC
+OMING
+NEW YORK NY
+- Continued
+Onty
+Used
+Rate Description
+MIN
+NOWKND M
+MIN
+2 MIN
+UNLIMITED N/WKND MIN
+NLIMITED N/WKND MI
+2MIN
+NLIMITED N/WKND MI
+1EVT 1.25 411 INFO
+1MIN
+I MIN
+2 MIN
+MIN
+TEV
+D NWKND MIl
+UNLIMITED N/WKND MIN
+LIMITED N/WKND M
+VLIMITED NIWKND M
+UNLIMITED N/WKND MIN
+LIMITED N/WKND M
+LIMITED N/WKND M
+NLIMITED NWKND MIl
+ESSAGE RETRIEVA
+INLIN
+le
+1.25
+
+Called
+Item Date Time
+16 06/14 04:11
+17 06/14 04:14
+548 06/14 04:17P
+49 06/14 04:37P
+50 06/14 04:47P
+551 06/14 05:56P
+NEW YORK N
+QUEENS NY
+COMIN
+COMIN
+- Continued
+Onty
+Used Rate Description
+2 MIN
+2 MIN
+EMIN
+2 MIN
+UNLIM MOBL TO MOBL
+INCLUBED MINUTES
+INCLUDED MINUTES
+
+g8888898888988
+g88888
+5gg9ggggg8ggggg
+RKZN1
+
+
+/14
+06:24P
+14 06-26P
+14
+06:29P
+06:42P
+06:49P
+06:53P
+06:56P
+08:02P
+14
+08:12P
+14
+08:18P
+14
+Gonna ad
+888888888 8888
+8888888 8888
+889886688 8898
+ree Cl
+NWYRCYZN08 NY
+VY ZONE T NY
+ONE
+COMIN
+hala
+ile
+303ğ
+≥ ½½
+deland
+2 MIN
+2 MIN
+EMIN
+.......
+1 EVT
+GMIN
+2 MIN
+2 MIN
+MIN
+CLUDED MINUTE
+CLUDED MINUTE
+UNLIM MOBL TO MOBL
+CLUBER MINUTE
+D MINUTE
+UNLIM MOBL TO MOBL
+ARLY EVENING NI
+TWKNI
+ARLY EVENING N/WKN
+0.52
+1.56
+UNLIM MOBI
+O MOBI
+UNLIMITED
+UNLIMIT
+UNLIM MOBL
+CLUDE
+O MOR
+UNLIM MOBI
+TO MOBL
+EARLY EVENING NANKND
+AWKND MIN
+NAMITE WIND MI
+
+
+Called
+Item Date Time
+508 06/16 11:018
+509 06/16 11:02F
+610 06/17 10:07A
+611 06/17 01:20P
+612 06/17 01:23P
+313 06/17 81 :281
+514 06/17 01
+615 06/17 01:29P
+616
+$17
+88
+'17
+01:35F
+17 01.398
+618
+06/17 02:02P
+628
+06/103590
+08 4 08 050
+717 06:05P
+623 06/17 06:07P
+1.410
+637
+11:46P
+•GOP
+640
+06/18
+07:02A
+
+IA
+==
+11:34A
+11:48A
+2:17F
+2:51P
+01:
+660
+AAT
+662 06/18 04:19P
+663 06/18 04:30P
+664 06/18 04:39P
+665
+88888
+18
+04:56P
+0000 0000
+05:04F
+5:09P
+:29P
+41P
+EW YORK N
+ROOKLYN N
+NEW YORK NY
+NEW YORK NY
+NEW YORK NY
+NOOMING
+Toll Free CL
+NEW YORK NY
+NEW YORK NY
+NCOMING
+NEW YORK NY
+Y ZONE 1 N
+W YORK N
+NEW YORK NY
+CHTAMSTTHS VI
+NEW YORK NY
+NEW YORK NY
+I ZONE 1 I
+COMIN
+NEW YORK NY
+VPALMBEACH
+LEOSAIRAA
+FL
+NEW
+NEW
+VORK
+≥≥≥ЪżЪžI≥Ъ₴
+FL
+VPALMBEACH F
+EW VORK N
+NY ZONE 1 NY
+- Continued
+Qnty
+Used
+MIN
+2 MIN
+1EVT
+2MIN
+6MIN
+3 MIN
+3 MIN
+8 MIN
+4 MIN
+2 MIN
+3MIN
+2 MIN
+6MIN
+2MN
+1MIN
+9MIN
+SMIN
+E MIN
+2 MIN
+6MIN
+2MIN
+2 MIN
+1MIN
+3MIN
+3MIN
+2 MIN
+1 EVT
+2MIN
+2 MIN
+1 EVT
+NEW YORK NY
+CHTAMSTTHS V
+Ra
+2 MIN
+MIN
+M
+ÜNLIM
+ICLU
+ICLU
+ICLU
+UNLIM
+1.25
+125
+
+Called
+- Continued
+Onty
+Used
+Rate Description
+Item Date Time
+670 06/18 05 438
+672 06/18 05:47P
+673 06/18 05:49P
+674 06/18 05:50P
+75 06/18 05:54B
+576 06/18 06:02P
+677 06/18 06:06P
+678 06/18 06:07P
+679 06/18 06:08P
+680 06/18 06:30P
+682 06/18 06.34Р
+08/18
+W YORK N
+COMIF
+2 MIN
+1 EVT
+1MIN
+SMIN
+8MIN
+IMIN
+2 MIN
+4 MIN
+2MIN
+2 MIN
+INCLUDED MINUTES
+ALL WAITINO
+ICLUDED MINUTE•
+INCLUDED MINUTES
+ICLUDED MINUTE:
+NLIM MOBL T(
+MOBL
+INCLUDED MINUTES
+IGLUBEB MINUTE
+) MINUTE
+UNLIM MOBL TO MOBL
+INLIM MOBL 10 MOB
+IOBI
+JNLIM MOBL TO MOB
+ARLY EVENING NIWKNI
+38888-89988---
+18
+
+serrrr.
+
+=
+ID
+I NY
+žžž≥
+₴{{₴g
+!!!!
+
+
+Item Date Time Called
+34 06/20 08:20,
+35 06/20 09:07
+736 06/20 10:32A
+757 06/20 10524
+739 06/20 10:55A
+740 06/20 1123A
+742 06/20 12:10P
+43
+44
+12:14P
+06/28 1214P
+745 06/20 12:20P
+0620 12 21H
+06/20
+748
+49
+16/20 12:261
+16/20 12-278
+06/20
+17.000
+
+
+
+
+
+
+gagggggg
+
+Rate Description
+COMIN
+VIN
+WPALMBEACH FL
+EW YORK N
+HTAMSTTHS '
+QUEENS NY
+NEW YORK NY
+NCOMING
+HONOLULU HI
+NCOMING
+NOOMING
+INCOMING HS VI
+MING
+MBEACH
+CH
+FL
+- Continued
+Onty
+Used
+EMIN
+EMIN
+2 MIN
+1MIN
+2 MIN
+2 MIN
+FL
+2333602RRRE
+
+--- NO.
+!!!!!!!!!!
+UNLIMITED N/WKND MIN
+NLIMITED N/WKND M
+WKND MIN
+UNLIMITED N/WKND MIN
+INLIMITED WIND MIF
+DN/WKND MIN
+UNLIMITED N/WKND MIN
+NLIMITED N/WKND MI
+NLIMITED NWKND MI
+UNLIMITED N/WKND MIN
+0.
+NLIMITED NWKND
+NLIM
+N/WKND MIN
+MIAMILKIN
+1101212111111101-11121217 1121
+
+Called
+Item Date Time
+97 06/20 11:598
+98 06/21 08-264
+799 06/21 08:59A
+800
+801
+06/21
+06/21
+09:08A
+09:08A
+802 06/21
+09:12A
+803
+804
+805
+806
+807
+808
+809
+10
+
+21
+09:12A
+11:32A
+12:34P
+12:35P
+12:40P
+02:20P
+02:49P
+02:51P
+02:54P
+02:55P
+03:33P
+
+8$9$8·89%
+PALMBEACH :
+NEW YORK NY
+- Continued
+Onty
+Used
+EMIN
+Rate Description
+INCLUDED MINUTES MIN
+MINUTES
+UNLIM MOBL TO MOBL
+ROOKLYN N
+COMING
+NOOMING
+NCOMING
+NWYRCYZN08 NY
+ARDENA O
+NEW YO
+VWYRCYZN08 NY
+NEW YORK NY
+MIN
+2 MIN
+JNLIM MOBL
+UNLIM MOBL TO MOBL
+JCLUDED MINUTE
+NLIM MOBL TO MOB
+INCLUDED MINUTES
+INCLUDED MINUTES
+UNLIM MOBL TO MOBL
+INCLUDED MINUTES
+CLUDED NUTE
+MINUTE
+CLUBEB MINUTE
+D MINUTE
+
+
+- Continued
+Qnty
+Item Date Time
+Called
+Used
+Rate Description
+53 06/22 06:31
+VYRCYZN08 1
+S4 06/22 07:04
+W YORK N
+MIl
+ARLY EVENINGN
+/ENING N/WKN
+865 06/22 07:06P
+NEW YORK NY
+EARLY EVENING N/WKND
+66 06/22 07:08P
+867 06/22 07:28P
+NOMING
+868 06/22 09:10P
+NEW YORK NY
+UNLIMITED N/WKND MIN
+569 06/22 09:10
+EW YORK N
+70 06/22 09:10F
+LEEN
+UNLIMITED N/WKND MIN
+2 MIN
+UNLIMITED NANKND MIN
+871 06/22 09:14P
+2 MIN
+UNLIMITED N/WKND MIN
+872 06/22 09:45P
+873 06/22 09:50P
+MONTEREY CA
+V/WKND MIN
+MIN
+INEMITEB NIWNB MIF
+874 06/22 09:56P
+TWINCITIES MN
+2MIN
+UNLIMITED N/WKND MIN
+75 06 22 09:59
+Y ZONET N'
+29 MIN
+NUIMITED N/WKND MI
+76 06/22 10:27
+COMINI
+LIMITED N/WKND MI
+1 EVT
+CALL WAITING
+877 06/22 10:27P
+NWYRCYZN08 NY
+INLIMITED N/WKND MIN
+878 06/22 10:28P
+NEW YORK NY
+879 06/22 10:316
+Y ZONE 1 N
+6MIN
+380 06/22 10:47P
+COMINC
+881 06/22 10:47P
+NWYRCYZN08 NY
+3B3
+884
+888
+:48P
+0:49P
+NWYRCYZ
+NY
+MIN
+NEW YORK
+INY
+UNLIM
+885
+:10:55P
+MONTEREY CA
+11:23P
+3MIN
+UNLIM
+886
+:36P
+HON
+RR7
+50P
+888฿
+889฿
+06
+:06A
+12:13A
+880
+ŞIZEŞI
+1 AAIN
+MIN
+UNLIM
+UNLIM
+UNLIM
+SMIN
+2 MIN
+892
+A Q2
+06/
+01:02A
+894
+88
+06:35A
+MONT
+CA
+15 MIN
+INLIM
+VCLU
+895
+896
+06/
+07:42A
+NEW YORK NY
+007
+881
+07
+:56
+8 MIN
+08:03A
+NEW YORK NY
+898 06/23 08:11A
+800 062 0A
+INEM MOR K NY
+06/23 08:26A
+EMIN
+902 06/23
+08:31A
+UK
+903 06/23 08:32A
+904 06/23 08:42A
+905 06/23 08:46A
+906 06/23 08:46A
+907 06/23 08:49A
+908 06/23 08:53A
+909 06/23 08:56-
+910 06/23 08:57A
+011
+812 06/23 09:004
+913 06/23 09:01A
+914
+915
+06/23 09:22A
+06/29
+: 09:59A
+916 06/23 12:41P
+917 06/24 01:25P
+mobile UK
+NEW YORK NY
+mobile UK
+UK
+NEW CANAAN CT
+NEW YORK NY
+BROOKI VN NV
+NEWYORKZN1 NY
+NEW MORK NV
+QUEENS NY
+NEW YORK NY
+NEW YORK NY
+2 MIN
+2 MIN
+VCLU
+VCLU
+IMIN
+MIN
+3MIN
+UNLIM
+INCLU
+UNLIN
+1 EVT
+3MIN
+EVT
+918 06/24 01:34P
+820 06/24 01:39P
+NEW YORK NY
+NEW TORK MY
+OrO.
+M
+0.06
+0.26
+0.26
+12
+Called
+- Continued
+Onty
+Used
+Rate Description
+Item Date Time
+921 06/24 01:52P
+922 06/24 03:52P
+923 06/24 04:03P
+924 06/24 05:01P
+925 06/24 05:36P
+926 06/2A 05 31P
+06/24 06:25P
+16/24 06:27P
+NEW YORK NY
+NY ZONE 1 NY
+NY ZONE 1 NY
+NY ZONE 1
+NY ZONE 1
+ZO
+EV
+0.30 CALL FORWARDING
+.30 CALL FORWARDINO
+1MIN
+30 CALL FORWARDINO
+0.30 CALL FORWARDING
+2MIN
+2 MIN
+0.30 CALL FORWARDING
+FÖRWARDING
+2 MIN
+0.30 CALL FORWARDING
+CALL FORWARDING
+
+0.60
+60
+0.60
+
+16/24 06:48P
+06/24 09:46P
+
+12:10A
+12:27A
+01:21A
+10:00A
+11:04A
+2233
+22
+ZO
+N
+NY
+20
+≥}≥?}???3????}????}???⅖≥?3≥?≥?3≥???3}??3≥???3??₴?3ZZl
+281
+ZO
+AnAmni
+ZONE
+hmmmmmmmmmmmmmmmmmmmmmmm
+333
+CALL FORWARDING
+0.30 CALL FORWARDING
+:30 GALL FORWARBING
+FORWARDING
+2 MIN
+1MIN
+30
+CALL FORWARDING
+CALL FORWARDING
+2 MIN
+0.30 CALL FORWARDING
+
+30
+88
+88
+0.60
+33333333333333333333333333333333:
+→0 - con →--
+
+00000
+ig z ggig1
+
+Item Date Time
+Called
+986
+06/28 01:39A
+GAF
+06/28 02:1
+988 06/28 02:22A
+989
+06/28 02:22A
+990
+06/28 02-31A
+991 06/28 10:45A
+992
+06/28 10:47A
+06/28 10:48A
+994
+06/28 10:51A
+16/28
+06/28 01327
+997
+06/28 02:01P
+998
+06/28 03:03P
+999 06/28 11:25P
+00
+06/29 01:57A
+06/29 02:02A
+1002 06/29 11:04A
+
+88888898BB
+889
+
+a99998888g
+
+04-36P
+04:468
+99
+56P
+06:19P
+1035
+103
+07.
+06:31P
+1027
+07/81
+
+046
+1047
+07/02 06:14P
+1048
+07/02 06:15P
+1049
+07/02 06:17P
+NY ZONE 1 NY
+NY ZONE
+- Continued
+Onty
+Used
+Rate Description
+IN CALL FORWARDING
+1 MIN 0.30 CALL FORWARDING
+I IN 8.30 CALL FORWARBING
+2MIN 0.30 CALL FORWARDING
+0.30 CALL FORWARDING
+2 MIN 0.30 CALL FORWARDING
+MAN O0 CALL FORWARBING
+0.30 CALL FORWARDING
+ONE
+2 MIN
+ZONE
+2 MIN 8:30 CALL FORWARBING
+NY ZONE
+NY
+1 MIN 0.30 CALL FORWARDING
+3333z
+0.30 CALL FORWARDING
+0000
+
+33723333}
+NY ZONE 1
+NY
+MONTREAL PO
+NEW YORK NY
+-ORWARDING
+CALL FORWARDING
+CALL FORWARBING
+WARDIN
+CALL FORWARDING
+AL!
+CALL
+FORWARDING
+FORWARDING
+CALL FORWARDING
+WARDING
+FORWARDING
+30 CALL FORWARDING
+FORWARDING
+CALL FORWARDING
+ALL FORWARDIN
+ALL FORWARDIN
+ORWARDING
+ALL FORWARDIN
+FORWARDING
+INCLUDED MINUTES
+0.30 CALL FORWARDINGAL
+INCLUDED MINUTES
+TANC
+8.30
+0.60
+8.50
+0:30
+0.60
+0.50
+0:60
+0.60
+0.
+8.10
+8.30
+0.60
+30
+0.60
+0.90
+1.30
+3.00
+0 30
+0.60
+.80
+0.90
+0.20
+
+Item Date Time Called
+1050 07/02 06:18P
+1051 07/02 06:19P
+1052 07/02 06:36P
+- Continued
+Onty
+Used
+MONTREAL PO
+NEW YORK NY
+1055 07/02 06:40P
+1057 07/02 0640Р
+58 07/02 06:5
+59 07/02 07:1
+1060 07/02 09:15P
+1061 07/02 09:18P
+1063 07/02 09:300
+1064 07/02 09:51P
+065 07/02 09:59
+J66 07/02 11:16
+COMING
+BROOKLYN N
+NEW YORK NY
+NEW YORK NY
+LAS VEGAS NV
+Rate Description
+CLUDED MINUTE
+INCLUDED MINUTES
+CALL WAITING
+UNLIM MOBL TO MOBL
+1 EVT
+MESSAGE RETRIEVAL
+IMIN
+MIN
+UNLIM MOBL TO MOBL
+UNLIM MOBL TO MOBL
+2MIN
+0.30 CALL FORWARDING
+TO MOBL
+TWKN
+UNLIMITED N/WKND MIN
+MIN
+DESCALE ETERNAL
+1 EVT
+MESSAGE RETRIEVAL
+ANTED AWN MIN
+UNLIMITED N/WKND MIN
+1069 07/02 11:23P
+1070 07/02 11:28P
+TOTAL VOICE USAGE FOR
+IMIN
+UNEMITEB NIWINB MIN
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND MIN
+DATA USAGE FOR
+Item Date
+1 06/17
+TOTAL DATA USAGE FOR
+Onty Used
+396 KR
+harge Descriptior
+NCLUDED IN PLAN ME
+TEXT/MULTIMEDIA MSGS FOR
+Item Date
+Time
+Sent To/Revd From
+1 06/06
+2 06/06
+09:41P
+10:14P
+3 ОБ/06
+10:14P
+04:30P
+5 06/16
+08:53A
+5 0Б/1
+11:04P
+02-19P
+06/1
+1-05
+10 06/20
+12:08P
+12 06/20
+05:23Р
+15-338
+13 06/20
+05:33P
+TOTAL TEXT/MULTIMEDIA MSG USAGE FOR
+Charge Description
+100 INGL. MSGS SENI
+100 INCL. MSGS SEN
+100 INCL. MSGS SENT
+100 INCL. MSGS SENT
+100 NOT. MISS SENT
+0.20
+0.60
+91.71
+0.00
+0.00
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/17d6d99e1654ad08be7d15dca1ff8f2fe6a922c98ec6975cfef7b8ef045f115c.receipt.json b/vision-fixhub/ds9-unparsed-06/17d6d99e1654ad08be7d15dca1ff8f2fe6a922c98ec6975cfef7b8ef045f115c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..dc92bd0537dbcd48a7a5fb4e41cfe9792efd9328
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/17d6d99e1654ad08be7d15dca1ff8f2fe6a922c98ec6975cfef7b8ef045f115c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -5910,
+  "dataset": "marble-joined",
+  "doc_id": "17d6d99e1654ad08be7d15dca1ff8f2fe6a922c98ec6975cfef7b8ef045f115c",
+  "engine": "marble-apple-vision",
+  "event_count": 76,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "a8803ef78d4bdfe43bc5c6052c82b31de955f47a51d80bd26d8d17b42ad3ef02",
+  "output_sha256": "ed9e3c363b27e91c894214746c9107a11076ff31599175e1523179b4f6ff379b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1837ad377e41337d5a49f13b98bd98234695a0db18bc08b49ba3b691bdefa2f4.md b/vision-fixhub/ds9-unparsed-06/1837ad377e41337d5a49f13b98bd98234695a0db18bc08b49ba3b691bdefa2f4.md
new file mode 100644
index 0000000000000000000000000000000000000000..8b2abc2251c9456e6e95bedc953a9c6e360566d4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1837ad377e41337d5a49f13b98bd98234695a0db18bc08b49ba3b691bdefa2f4.md
@@ -0,0 +1,38 @@
+Case 9:08-cv-80736-KAM Document 159 Entered on FLSD Docket 03/29/2012 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80736-CIV-MARRA/HOPKINS
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs,
+VS.
+UNITED STATES OF AMERICA,
+Defendant.
+ORDER ON MOTION FOR INTERVENTION BY JEFFREY EPSTEIN
+THIS CAUSE is before the Court upon the Motion to Intervene For Limited Intervention
+by Jeffrey Epstein (DE 93). This matter is fully briefed and is now ripe for review. The Court
+has carefully considered the briefs and is fully advised in the premises.
+"Permissive intervention under [Federal Rule of Civil Procedure 24(b)] is appropriate
+where a party's claim or defense and the main action have a question of law or fact in common
+and the intervention will not unduly prejudice or delay the adjudication of the rights of the
+original parties." Mt. Hawley Ins. Co. I. Sandy Lake Properties, Inc., 425 F.3d 1308, 1312 (11'"
+Cir. 2005) (citing Georgia Il. United States Army Corps of Eng'rs, 302 F.3d 1242, 1250 (11" Cir.
+2002)). Through their Motion, Epstein asks to intervene "for the limited purpose of seeking a
+protective order and responding to the motions of Jane Doe 1 and Jane Doe 2 for disclosure,
+evidentiary use, and widespread dissemination of the plea negotiation letters and emails between
+his lawyers and federal prosecutors." Motion at 1. After carefully reviewing the briefs from all
+parties involved, the Court finds that Epstein has a legitimate interest in asserting a claim that the
+
+
+Case 9:08-cv-80736-KAM Document 159 Entered on FLSD Docket 03/29/2012 Page 2 of 2
+documents in question may be privileged. Further, the Court finds that the intervention will not
+unduly prejudice or delay the adjudication of the rights of the original parties. Accordingly, the
+Court will exercise its discretion to permit Epstein to intervene pursuant to Federal Rule of Civil
+Procedure 24(b). This order should not be construed as an indication of how the Court will rule
+on the merits of the claim that the documents in question are subject to a privilege.
+It is therefore ORDERED AND ADJUDGED that the Motion to Intervene For Limited
+Intervention by Jeffrey Epstein (DE 93) is GRANTED.
+DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County,
+Florida, this 29" day of March, 2012.
+KENNETH A. MARRA
+United States District Court
+2
diff --git a/vision-fixhub/ds9-unparsed-06/1837ad377e41337d5a49f13b98bd98234695a0db18bc08b49ba3b691bdefa2f4.receipt.json b/vision-fixhub/ds9-unparsed-06/1837ad377e41337d5a49f13b98bd98234695a0db18bc08b49ba3b691bdefa2f4.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4df519622a03fe6c5d71ab0f22201166c25d8751
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1837ad377e41337d5a49f13b98bd98234695a0db18bc08b49ba3b691bdefa2f4.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "1837ad377e41337d5a49f13b98bd98234695a0db18bc08b49ba3b691bdefa2f4",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "eb2405823d31a3314f72676b87562d6a0ac5a456a94a1713996e6b7f7ff23975",
+  "output_sha256": "de88b45db319b5817ba81a826d226918ef5447b5db85cb1f338b0bfab1f99f30",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/18f74b7cd6d6b72e0862213c5605508085954dc520b0b240451155d8d9b88871.md b/vision-fixhub/ds9-unparsed-06/18f74b7cd6d6b72e0862213c5605508085954dc520b0b240451155d8d9b88871.md
new file mode 100644
index 0000000000000000000000000000000000000000..c9fa407f95b87febebfcfd6da9ae0123c38122a8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/18f74b7cd6d6b72e0862213c5605508085954dc520b0b240451155d8d9b88871.md
@@ -0,0 +1,33 @@
+Subject: Availability of Civil Remedies - Crime Victims Rights Act Suit, Jane Does 1 and 2 . United
+States
+Date: Tue, 17 Jan 2012 15:51:34 +0000
+Importance: Normal
+Attachments: 127 pet_opp_MTD.pdf
+In July 2008, two victims of Jeffrey Epstein filed an action under the Crime Victims Rights Act (CVRA), claiming
+they were entitled to be consulted before the U.S. Attorney's Office entered into a non-prosecution agreement
+with Epstein in September 2007. The case was assigned to me, and I filed an initial response to the petition,
+arguing that the CVRA did not apply because Epstein had never been formally charged in federal court. I also
+appeared in a hearing on July 11, 2008, before Judge Marra.
+The case was inactive for several years, the victims being content to litigate their civil damage claims against
+Epstein. In mid-2010, the case became active again, and Paul Cassell, a former federal judge from Utah, and
+victims' rights advocate, entered his appearance on behalf of the victims. We first litigated the issue of
+whether CVRA rights apply in the absence of a formal federal criminal charge. On September 26, 2011, Judge
+Marra issued an order finding that the CVRA can apply before formal charges are filed.
+The next phase of the litigation is whether the government used its best efforts to comply with the CVRA, and if
+it did not, what the remedy would be. We have always argued that the Court had no authority to set aside the
+non-prosecution agreement because such agreements, unlike plea agreements, do not come before the Court
+for approval. The Court allowed the victims to engage in limited discovery, to include requests for production
+and requests for admissions. The government has been served with both.
+The government filed a motion to dismiss based on lack of standing, arguing that the alleged CVRA violation
+was not redressable. The victims have responded with a lengthy opposition, including a listing of remedies
+they claim are available to them (pages 14-15).
+prepared the motion to dismiss for lack of
+standing. He needs assistance from someone in the Civil Division to specifically address the issue of the
+availability of remedies specified by the victims. I have attached the victims' response to our motion to dismiss,
+which includes the listing of remedies.
+Our response is due on Tuesday, January 24, and we are on our second extension of time. My trial in l
+United States will begin on Monday, January 23, so I don't have much time to devote to this other litigation.
+Can you assign someone to assist |
+on the issue of the availability of civil remedies?
+Thanks. (
+<<127_pet_opp_MTD.pdf>>
diff --git a/vision-fixhub/ds9-unparsed-06/18f74b7cd6d6b72e0862213c5605508085954dc520b0b240451155d8d9b88871.receipt.json b/vision-fixhub/ds9-unparsed-06/18f74b7cd6d6b72e0862213c5605508085954dc520b0b240451155d8d9b88871.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2645ffac243b3699dd73563cb472d6d594e98602
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/18f74b7cd6d6b72e0862213c5605508085954dc520b0b240451155d8d9b88871.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "18f74b7cd6d6b72e0862213c5605508085954dc520b0b240451155d8d9b88871",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "7ab713f6fe6b5cbed54efb56b4a9a7f5d8de57032ef41dd8dff663e0d74803fa",
+  "output_sha256": "8e475cb06e171fa90c2c0a5e0e15c54a20378bd849c8b4fd795d23e36c0977f6",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1976099327a291e98e2cc661e9663b22cea8228ffae0a7db272fc9b96c341ab0.md b/vision-fixhub/ds9-unparsed-06/1976099327a291e98e2cc661e9663b22cea8228ffae0a7db272fc9b96c341ab0.md
new file mode 100644
index 0000000000000000000000000000000000000000..cadeedc363bef8aa4a203d0e72001ca036fb0c73
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1976099327a291e98e2cc661e9663b22cea8228ffae0a7db272fc9b96c341ab0.md
@@ -0,0 +1,41 @@
+Subject: RE: (draft) Pleadings to Be Filed Tomorrow -- RE JEFFREY EPSTEIN
+Date: Tue, 26 Oct 2010 21:08:42 +0000
+Importance: Normal
+In addition to the thoughts I raised earlier, I'd note that two weeks doesn't seem like much time.
+Sent: Tuesday, October 26, 2010 5:02 PM
+Subject: FW: (draft) Pleadings to Be Filed Tomorrow -- RE JEFFREY EPSTEIN
+Good afternoon, everyone. So much for my telephone call this morning. Judge Cassell has apparently taken a
+different point of view. Please see below and attached.
+From: Paul Cassell [mailto:cassellp@law.utah.edu]
+Sent: Tuesday, October 26, 2010 4:49 PM
+Subject: (draft) Pleadings to Be Filed Tomorrow
+I wanted to send you drafts of the pleadings we are in the process of preparing to file tomorrow, pursuant to Judge
+Marra's order. As mentioned in several previous e-mails, we stand ready to work with you to try and narrow the range of
+disputed facts - and trust that you will be willing to stipulate to all the facts that are correct in our pleadings. (Most of
+them are now based on documented e-mails, so we trust the bulk of the facts will gain your stipulated approval.)
+1am also writing because co-counsel Brad Edwards has been working with M
+In a possible approach to the
+filings tomorrow. AtMarie's suggestion, Brad has offered to take out a paragraph that Marea was concerned about in our
+fact section and to file our pleadings under seal tomorrow for, say, a period of (at least) two weeks. This would give us an
+opportunity to work with you to resolve disputed facts and, more generally, to try and resolve the entire dispute. In
+exchange, we request that you agree not to file a motion to dismiss for lack of prosecution and not to argue that we need
+to file some sort of civil complaint to litigate these issues (both suggestions you raised in your earlier e-mail). Brad and I
+don't believe such arguments would be legally well founded in any event. But if you are asking for concessions on our
+part, we would like to narrow the subjects of the litigation that we have to respond to in exchange.
+As we have mentioned at every stage of this case, we stand ready to work with you to try and resolve the matter. We
+continue to be willing to attempt a fair resolution that protects our client's interests. Along those lines, if you have
+
+
+concerns about us filing our pleadings under seal tomorrow, we are ready to discuss the idea of delaying any filing for a
+period of, say, two weeks. Such a delay, however, would be contingent on your obtaining an extension from Judge Marra
+of our filing deadline. As you can see, we are ready to file and would delay only as an accommodation to you - and would
+except you to do the motion that would be required for such an extension).
+Brad and I stand ready to discuss these issues at any time with you and/or
+Sincerely,
+Paul Cassell
+Counsel for Jane Doe #1 and Jane Doe #2
+801-201-8271 (cell phone)
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only
+for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended
+recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error,
+please immediately notify the sender by reply electronic mail and delete the original message. Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/1976099327a291e98e2cc661e9663b22cea8228ffae0a7db272fc9b96c341ab0.receipt.json b/vision-fixhub/ds9-unparsed-06/1976099327a291e98e2cc661e9663b22cea8228ffae0a7db272fc9b96c341ab0.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..76ddcf7f3494f3ff365f834d95e89ba0fdba3b2a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1976099327a291e98e2cc661e9663b22cea8228ffae0a7db272fc9b96c341ab0.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "1976099327a291e98e2cc661e9663b22cea8228ffae0a7db272fc9b96c341ab0",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e81affc3a5f1407d141ddea19b95cf97282d6e7513faff348225c4ef4a43c89c",
+  "output_sha256": "72699a2dadfd258d919262729b885332ed382b1b7d0e1b2b5cbeb3edaed0d18e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/199fcc01c90662f9cfe1c941f9905d59c4ab25c27c65d64b16452bf2cac47012.md b/vision-fixhub/ds9-unparsed-06/199fcc01c90662f9cfe1c941f9905d59c4ab25c27c65d64b16452bf2cac47012.md
new file mode 100644
index 0000000000000000000000000000000000000000..8f33cd044be00c93ef38bb5e0d9e6e80fd74a15b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/199fcc01c90662f9cfe1c941f9905d59c4ab25c27c65d64b16452bf2cac47012.md
@@ -0,0 +1,43 @@
+From: "l
+(USAFLS)"
+</O=USA/OU=FLS/CN=RECIPIENTS/CN=|
+To: "l
+<
+Subject: RE: JE
+Date: Thu, 15 Feb 2007 20:20:30 + 0000
+Importance Normal i
+-- This is a silly question but I know some people from an earlier generation get upset. The agents and I had set
+aside next week to go through all the tapes, so we are setting up a warroom and I was planning to just wear jeans. Do you
+think
+Assistant U.S. Attorney
+From:
+[mailto:
+Sent: Thursday, February 15, 2007 3:18 PM
+To: L
+|(USAFLS)
+Subject: JE
+confirmed meeting on Tuesday at 10am with
+see you then.
+safe trip.
+FOWLER WHITE BURNETT P.A.
+Espirito Santo Plaza, 14th Floor
+**TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance
+with requirements imposed by the IRS, we inform you that any tax
+advice contained in this communication (including attachments) was
+not intended or written to be used, and cannot be used, for the
+purpose of (i) avoiding penalties under the Internal Revenue Code
+or (ii) promoting, marketing or recommending to another party any
+transaction or matter addressed herein. If you would like such advice,
+please contact us.***
+***Attention: The information contained in this E-mail message
+is attorney privileged and confidential information intended only
+for the use of the individual(s) named above. If the reader of this
+
+
+message is not the intended recipient, you are hereby notified that any
+dissemination, distribution or copy of this communication is strictly
+prohibited. If you have received
+this communication in error, please
+contact the sender by reply E-mail and
+all copies of the original
+message. Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/199fcc01c90662f9cfe1c941f9905d59c4ab25c27c65d64b16452bf2cac47012.receipt.json b/vision-fixhub/ds9-unparsed-06/199fcc01c90662f9cfe1c941f9905d59c4ab25c27c65d64b16452bf2cac47012.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..fa43eae606afacd5d41b4882bd676b87aec3bcc9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/199fcc01c90662f9cfe1c941f9905d59c4ab25c27c65d64b16452bf2cac47012.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "199fcc01c90662f9cfe1c941f9905d59c4ab25c27c65d64b16452bf2cac47012",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "036634311cb599f7e11779b3166f51351c17478b52288f28324a94fb0eed3845",
+  "output_sha256": "e15bb704912e726c2f5e7a84d275c360eb1aee98e235044c6ce74fa3b932d416",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1a0f2b2e846baecae012bd94bae618fc2d1663c840d41cdee1dca8663ad6dfee.md b/vision-fixhub/ds9-unparsed-06/1a0f2b2e846baecae012bd94bae618fc2d1663c840d41cdee1dca8663ad6dfee.md
new file mode 100644
index 0000000000000000000000000000000000000000..1e91e149673478be68f19bb53dfa01000aaf0838
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1a0f2b2e846baecae012bd94bae618fc2d1663c840d41cdee1dca8663ad6dfee.md
@@ -0,0 +1,32 @@
+From: Paul Cassell <cassellp@law.utah.edu>
+To: "Villafana, Ann Marie C. (USAFLS)" <Ann.Marie.C.Villafana@usdoj.gov>
+Cc: Brad Edwards <bedwards@pathtojustice.com>
+Subject: RE: Jane Doe L. United States - please call and I'II get you a position quickly
+Date: Mon, 07 Nov 2011 23:14:38 +0000
+Importance: Normal
+Hey Maria,
+Brad has asked me to get back to you on your questions regarding the motion.
+We are happy to work with you, but I would like just a little more information about what you are asking us to agree to
+(I'm not completely clear on what we are being asked to agree to). Dexter hasn't called me and if he is trying to reach
+Brad, Brad is in the middle of a three week trial. So please call my cell at 801-201-8271 and I'll work with you quickly. Paul
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+S.J. Quinney College of Law at the University of Utah
+332 South 1400 East, Room 101
+Salt Lake City, UT 84112-0730
+Voice: 801-585-5202
+Fax: 801-581-6897
+Email: cassellp@law.utah.edu
+http://www.law.utah.edu/profiles/default.asp?PersonlD=57&name=Cassell,Paul
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only
+for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended
+recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error,
+please immediately notify the sender by reply electronic mail and delete the original message. Thank you.
+From: Villafana, Ann Marie C. (USAFLS) [mailto:Ann.Marie. C. Villafana@usdoj.gov]
+Sent: Monday, November 07, 2011 2:18 PM
+To: Paul Cassell
+Subject: Jane Doe I. United States
+Hi Paul - I am sorry to bother you, but has Dexter been in touch with you regarding a Motion to Stay Discovery? If not,
+could you let me know your position regarding such a Motion?
+Thank you.
+Marie
diff --git a/vision-fixhub/ds9-unparsed-06/1a0f2b2e846baecae012bd94bae618fc2d1663c840d41cdee1dca8663ad6dfee.receipt.json b/vision-fixhub/ds9-unparsed-06/1a0f2b2e846baecae012bd94bae618fc2d1663c840d41cdee1dca8663ad6dfee.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..75203ab9a7dd2ed6a7d852d333eff0aa9fa54b97
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1a0f2b2e846baecae012bd94bae618fc2d1663c840d41cdee1dca8663ad6dfee.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "1a0f2b2e846baecae012bd94bae618fc2d1663c840d41cdee1dca8663ad6dfee",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3c9c5740fae21d9c040bfe4cf4a5f873af26d7377bbe862f477aa4a7826f7c89",
+  "output_sha256": "c6a9395cc56f3d24a3ae0209c400ec457fc7c66f4536c6858676048d7bd12f1b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1a91431010f400a32765a43a7a72b6d70c3dcdb42985c136c9aa110d4f499382.md b/vision-fixhub/ds9-unparsed-06/1a91431010f400a32765a43a7a72b6d70c3dcdb42985c136c9aa110d4f499382.md
new file mode 100644
index 0000000000000000000000000000000000000000..cde57080b8432e7b9a54b684f9a8d05bf2203521
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1a91431010f400a32765a43a7a72b6d70c3dcdb42985c136c9aa110d4f499382.md
@@ -0,0 +1,10 @@
+From:
+To:
+• (USAFLS)" <
+(USAFLS)" {
+Subject: Memo re Epstein
+Date: Tue, 26 Jul 2011 13:14:45 +0000
+Importance: Normal
+Hi Ben - Do you want me to summarize the basis for the confliet or the new leads or both?
+Assistant U.S. Attorney
+Fax
diff --git a/vision-fixhub/ds9-unparsed-06/1a91431010f400a32765a43a7a72b6d70c3dcdb42985c136c9aa110d4f499382.receipt.json b/vision-fixhub/ds9-unparsed-06/1a91431010f400a32765a43a7a72b6d70c3dcdb42985c136c9aa110d4f499382.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d140851f3a1c45755222d21e4d39fbb7cc79598d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1a91431010f400a32765a43a7a72b6d70c3dcdb42985c136c9aa110d4f499382.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "1a91431010f400a32765a43a7a72b6d70c3dcdb42985c136c9aa110d4f499382",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "f776b5a7df8c77e3b4edb4eac9cbb88d6910ccdbd164abba53a677904ace4e68",
+  "output_sha256": "20e77c84ba64bb39f675c1d099d72435432c245dafea1fc4978a1f4ab59f26dd",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1b1cda5b488fdf9052e65340360eb66204676614bc4547636cf2f42ce6685083.md b/vision-fixhub/ds9-unparsed-06/1b1cda5b488fdf9052e65340360eb66204676614bc4547636cf2f42ce6685083.md
new file mode 100644
index 0000000000000000000000000000000000000000..2e0a41656af7705809e3899f32bb235c546127db
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1b1cda5b488fdf9052e65340360eb66204676614bc4547636cf2f42ce6685083.md
@@ -0,0 +1,104 @@
+GERAID B. LEFCOURT, P.C.
+A PROFESSIONAL CORPORATION
+148 EAST 78™ STREET
+NEW YORK, NEW YORK 10021
+GERALD B. LEFCOURT
+TELEPHONE
+FACSIMILE
+SHERYL E. REICH
+RENATO G. STABILE
+FAITH A. FRIEDMAN
+BY FEDERAL EXPRESS
+Assistant United States Attorney
+Souther Distinct od Storis Armey
+June 12, 2007
+Subpoenas dated May 31, 2007, to J. Epstein Virgin Islands Foundation, Inc., J. Epstein & Co.,
+Inc.; Epstein Interests; and Financial Trust Company, Inc.
+Dear Ms. Villafana:
+I write to respond to the subpoenas served on the above entities all dated May 31, 2007.
+Each of the subpoenas has a substantively identical Attachment to Subpoena describing the
+Be advised that J. Epstein & Co., Inc., executed a certificate of dissolution in December
+2000 and therefore could not have any documents responsive to the subpoena. Please be further
+advised that no entity has any documents responsive to Request Nos. 1, 3, 4 and 5. We are still in
+the process of ascertaining whether documents responsive to Request No. 2 exist, and will
+provide them to you, assuming they do exist, as soon as we are able to do so. Finally, we have
+enclosed for your review all documents we believe to be responsive to Request No. 6, including a
+schedule of the corporate directors, board members and shareholders of each entity, to the extent
+the question is applicable to each entity.
+The documents provided bear the following production numbers, which we note were
+placed on said documents for control purposes only and do not appear on the documents in the
+normal course:
+Schedule of Corporate Directors, Board Members, Shareholders
+J. Epstein Virgin Islands Foundation, Inc.
+JEVIF 0001
+
+
+GERALD B. LEFCOURT, P.C.
+Assistant United States Attorney
+Office of the United States Attorney
+Sune h2, District of Florida
+IRS Form 1096 J. Epstein Virgin Islands Foundation, Inc. 2004
+IRS Form 1099 J. Epstein Virgin Islands Foundation, Inc. 2004
+IRS Form 1096 J. Epstein Virgin Islands Foundation, Inc. 2003
+IRS Form 1099 J. Epstein Virgin Islands Foundation, Inc. 2003
+Schedule of Corporate Directors, Board Members, Shareholders
+Epstein Interests
+IRS Forms W2 Epstein Interests 2006
+IRS Form W2 Epstein Interests 2005
+IRS Form 1096 Epstein Interests 2005
+IRS Form 1099 Epstein Interests 2005
+Schedule of Corporate Directors, Board Members, Shareholders
+Financial Trust Co., Inc.
+IRS Form W3 Financial Trust Co., Inc. 2006
+IRS Forms W2 Financial Trust Co., Inc. 2006
+IRS Form W3 Financial Trust Co., Inc. 2005
+IRS Forms W2 Financial Trust Co., Inc. 2005
+IRS Form W3 Financial Trust Co., Inc. 2004
+IRS Forms W2 Financial Trust Co., Inc. 2004
+IRS Form W3 Financial Trust Co., Inc. 2003
+IRS Forms W2 Financial Trust Co., Inc. 2003
+IRS Form 1096 Financial Trust Co., Inc. 2006
+IRS Forms 1099 Financial Trust Co., Inc. 2006
+IRS Form 1096 Financial Trust Co., Inc. 2005
+IRS Forms 1099 Financial Trust Co., Inc. 2005
+IRS Form 1096 Financial Trust Co., Inc. 2004
+IRS Forms 1099 Financial Trust Co., Inc. 2004
+IRS Form 1096 Financial Trust Co., Inc. 2003
+IRS Forms 1099 Financial Trust Co., Inc. 2003
+JEVIF 0002
+JEVIF 0003
+JEVIF 0004
+JEVIF 0005
+EI 0001
+EI 0002-0003
+EI 0004
+EI 0005
+EI 0006
+FTC 0001
+FTC 0002
+FTC 0003-0008
+FTC 0009
+FTC 0010-0015
+FTC 0016
+FTC 0017-0022
+FTC 0023
+FTC 0024-0030
+FTC 0031
+FTC 0032-0033
+FTC 0034
+FTC 0035-0036
+FTC 0037
+FTC 0038-0041
+FTC 0042
+FTC 0043-0045
+
+
+GERALD B. LEFCOURT, P.C.
+Assistant United States Attorney
+Office of the United States Attorney
+Southern District of Florida
+June 12, 2007
+Page 3
+If you have any questions, please do not hesitate to call.
+cc: Special Agent
+Lilly Ann Sanchez, Esq.
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/1b1cda5b488fdf9052e65340360eb66204676614bc4547636cf2f42ce6685083.receipt.json b/vision-fixhub/ds9-unparsed-06/1b1cda5b488fdf9052e65340360eb66204676614bc4547636cf2f42ce6685083.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..815b1a336bc0fc3177e09f9a1755ade36cae909c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1b1cda5b488fdf9052e65340360eb66204676614bc4547636cf2f42ce6685083.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -82,
+  "dataset": "marble-joined",
+  "doc_id": "1b1cda5b488fdf9052e65340360eb66204676614bc4547636cf2f42ce6685083",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "9fcd0ec1d8d0b46bdf4deef260897102a8222a7a750f6e2b354686619769a4ee",
+  "output_sha256": "d2afbaa8e65866dd95e81cdb128ef04467b8fac115b9ff7733d221c3e87ef0a1",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1b22866f2a48b49b6978948bfe30b0ccf0329007459e4d75b1b57763374bfe4e.md b/vision-fixhub/ds9-unparsed-06/1b22866f2a48b49b6978948bfe30b0ccf0329007459e4d75b1b57763374bfe4e.md
new file mode 100644
index 0000000000000000000000000000000000000000..ae4e3f3f1157dd8e61a898d12215c1bdb5174e38
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1b22866f2a48b49b6978948bfe30b0ccf0329007459e4d75b1b57763374bfe4e.md
@@ -0,0 +1,154 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA
+JANE DOE #1 and JANE DOE #2,
+Petitioners,
+VS.
+UNITED STATES,
+Respondent.
+RESPONDENT'S REPLY TO PETITIONERS' RESPONSE
+TO RESPONDENT'S SEALED MOTION TO STAY DISCOVERY
+PENDING RULING UPON RESPONDENT'S MOTION TO DISMISS [DE 129]
+AND RESPONDENT'S RESPONSE IN OPPOSITION
+TO PETITIONERS' PROTECTIVE MOTION TO COMPEL [DE 130]
+Respondent, by and through its undersigned counsel, hereby files this Reply to Petitioner Jane Doe #1
+and Jane Doe #2's Response to the Respondent's Sealed Motion to Stay Discovery Pending Ruling upon
+Respondent's Motion to Dismiss [DE129] and Response in Opposition to Petitioners' Protective Motion to
+Compel [DE 130]. For the following reasons and the reasons set forth in Respondent's Motion to Stay
+Discovery, the Court should grant the United States' Motion to Stay Discovery pending the Court's decision on
+the United States' Motion to Dismiss for Lack of Subject Matter Jurisdiction and, similarly, deny the Petitioners"
+Protective Motion to Compel.
+In both their Response to the Motion to Stay Discovery and their Motion to Compel, Petitioners fail to
+cite any statute or case law that supports their position that the Court should order the United States to produce
+discovery while a motion to dismiss for lack of subject matter jurisdiction is pending. The Eleventh Circuit has
+clearly and repeatedly stated that dispositive motions should be decided before discovery begins:
+Facial challenges to the legal sufficiency of a claim or defense, such as a motion to dismiss based
+on failure to state a claim for relief, should, however, be resolved before discovery begins. ...
+[D]iscovery imposes several costs on the litigant from whom discovery is sought. These burdens
+include the time spent searching for and compiling relevant documents; the time, expense, and
+aggravation of preparing for and attending depositions; the costs of copying and shipping
+documents; and the attorneys' fees — generated in interpreting discovery requests, drafting
+responses to interrogatories and coordinating responses to production requests, advising the client
+as to which documents should be disclosed and which ones withheld, and determining whether
+certain information is privileged.
+Chudasama v. Mazda Motor Corp., 123 F.3d 1353, 1367 (11th Cir: 1997) (citations omitted). See also Moore v
+Potter, 141 Fed. Appx. 803, 807-08 (11th Cir. 2005) (quoting Chudasama at 1367, 1368) (affirming district
+court's decision to stay proceedings, including all discovery, pending ruling on defendant's 12(b)(6) motion to
+dismiss); Cheshire v. Bank of America, 351 Fed. Appx. 386, 388 (11th Cir. 2009) (citing Chudasama at 1367)
+("'a plaintiff has no right to discovery upon the filing of a motion to dismiss that raises a purely legal question");
+Horsley v. Feldt , 304 F.3d 1125, 1131 n.2 (11th Cir. 2002) (affirming district court's decision to suspend
+
+
+discovery pending resolution of motion for judgment on the pleadings); Smith v. Potter, 400 Fed. Appx. 806,
+812 (5th Cir. 2010) (affirming district court's stay of discovery pending a motion to dismiss for lack of subject
+matter jurisdiction); Cotton v. Massachusetts Mut. Life Ins. Co., 402 F.3d 1267 (11th Cir. 2005) (noting that
+because every claim has the potential to enlarge the scope and cost of discovery, the need to resolve a facially
+challenged claim before discovery is based on the extent to which the claim expands discovery).
+The concerns raised in Chudasama and its progeny are present here. The motion to dismiss for lack of
+subject matter jurisdiction is dispositive of the entire case. Thus, staying discovery until the Court rules will save
+the entire cost related to discovery, if the Court rules that it lacks jurisdiction. As noted in the United States'
+Motion to Stay, the discovery requests that have been propounded by Petitioners far exceed the Court's directive
+that they could "conduct limited discovery in the form of document requests and requests for admissions from
+the U.S. Attorney's Office" in order to allow " limited factual development." (DE 99 at 11 (emphasis added).)
+The Court ordered that the discovery should address only "whether the particular [CVRA] rights asserted here
+attached and, if so, whether the U.S. Attorney's Office violated those rights." (Id. at 10.) Instead the document
+requests and the later-served requests for admissions seek documents and information pertaining to the substance
+of the criminal investigation of Jeffrey Epstein, including any prosecution memoranda and drafts of any
+indictments prepared in the case, which are governed by the grand jury secrecy rules. See Request for
+Production No. 1. Petitioners also seek discovery regarding events that occurred long after the negotiation of the
+Non-Prosecution Agreement and, in fact, long after the Petitioners filed their action. For example, in Requests
+17 and 18, Petitioners ask for documents and correspondence created as recently as August 2011, approximately
+three years after the latest of the relevant facts in the case. Petitioners request the production of information and
+documents that would violate the attorney-client privilege, the work product doctrine, the deliberative process
+privilege, and the privacy rights of other victims identified in the case. Merely collecting all of the requested
+materials, cataloguing them, and asserting the various privileges would be a tremendous undertaking.
+Furthermore, unlike a Rule 12(b)(6) motion, the government's motion alleges that the Court lacks jurisdiction -
+that is, the power - to hear the case. Respondent is the United States, an entity that normally has sovereign
+immunity from suit and, hence, from discovery obligations. Requiring the United States to engage in the overly
+burdensome discovery that the Petitioners have requested, prior to reaching a determination that the Court has
+jurisdiction over the subject matter of this dispute, is contrary to both the letter and the spirit of Chudasama and
+Cotton, supra. Cf. Butler v. Sukhoi Co., 579 F.3d 1307, 1314 (11th Cir. 2009) (noting that, in the context of
+the Foreign Sovereign Immunities Act (FSIA"), the principles of comity underlying the FSIA require the district
+
+
+court to promptly consider claims of lack of jurisdiction to avoid discovery costs to erode the protections of the
+FSIA).
+Petitioners' sole argument is their assertion that the United States has filed its Motion to Dismiss as a
+"stall tactic" and their allegation that the United States has refused to agree to any facts in this case. First, as has
+been repeatedly asserted, the United States has tried on many occasions to reach agreed statements of fact with
+Petitioners, and is continuing to do so. If the Court should rule against the United States on its Motion to
+Dismiss, the United States continues to hope that a set of Stipulated Facts can be reached. Second, the United
+States has agreed to provide some information to Petitioners even during the pendency of the stay and is
+undertaking a search for that information. Third, the Court has before it a Motion related to whether the
+Petitioners can use documents and information that they received via discovery from other lawsuits in this
+litigation, as well as briefing related to Roy Black, et al.'s motion asserting a work product privilege. Much of
+the material that falls within the scope of the Court's order, which allowed only limited factual development
+regarding whether the CVRA rights attached and if they were violated, cannot be made available until the Court
+has ruled on those motions.
+Lastly, in their Response to the Motion to Stay and in their Protective Motion to Compel, Petitioners ask
+the Court to Order that within fourteen days of the denial of either the Motion to Stay or the Motion to Dismiss,
+the government should be ordered to provide:
+(1) the Government's initial disclosures pursuant to Fed. R. Civ. P. 26(a)(1);
+(2) answers to the requests for admissions;
+(3) all documents, correspondence, and other information that the Government distributed to persons or
+entities outside of the federal government or received from persons or entities outside of the federal government;
+(4) all documents, correspondence, and other information covered by the victims' discovery request that
+is not subject to a claim of privilege;
+(5) a privilege log.
+(See DE 129 at 3.)
+Here again, Petitioners have attempted to go beyond the Court's Order, which allowed only "limited
+discovery." As the Court acknowledged, this is not a civil case, it is a proceeding under the CVRA, which is
+meant to accompany criminal litigation. As such, the Federal Rules of Civil Procedure do not apply, including
+the disclosure rules at Fed. R. Civ. P. 26. E2 The third request, for all documents distributed to persons outside
+the government or received from persons outside the government, is not limited by date, subject matter,
+
+
+recipient, sender, or otherwise. As written, it calls for virtually every piece of paper and document in electronic
+storage within the "federal government" that has ever been shown to any third party.
+Rather than provide an exhaustive accounting of all of the objections to the discovery requests at this
+time, the United States means only to show that there are numerous objections that are legally cognizable.
+Accordingly, the United States respectfully requests that the Court deny the Petitioners' Protective Motion to
+Compel and order that, within 30 days following the Court's denial of the Motion to Dismiss (or, alternatively,
+the denial of the Motion to Stay), the United States must serve any responses and/or objections to the Petitioners"
+Requests for Admissions and First Request for Production.
+CONCLUSION
+For the foregoing reasons, the United States respectfully requests that the Court:
+(1) grant the United States Motion to Stay Discovery Pending Ruling upon Respondent's Motion to
+Dismiss; and
+(2) deny Petitioners' Protective Motion to Compel.
+If the Court should deny the United States' Motion to Stay Discovery, or if the Court should grant the
+Motion to Stay and later deny the United States' Motion to Dismiss, then the United States respectfully requests
+that it be allowed thirty (30) days to serve any responses and/or objections to the Petitioners' Requests for
+Admissions and First Request for Production.
+Respectfully submitted,
+WIFREDO A. FERRER
+LINITED STATES ATTORNEY
+By:
+Assistant U.S. Attorney
+Miami, Florida 33132
+Attorney for Respondent
+CERTIFICATE OF SERVICE
+The undersigned hereby certifies and affirms that a copy of the foregoing was served via the Court's
+CM/ECF system this 24th day of January, 2012, upon Counsel for Petitioners Jane Doe #1 and Jane Doe #2.
+ASSISTANT U.S. ATTORNEY
+SERVICE LIST
+Jane Does 1 and 2 v. United States
+Case No. 08-80736-CIV-MARRA
+
+
+United States District Court, Southern Distriet of Florida
+Bradley Edwards, Esq.,
+Farmer Jaffe Weissing Edwards Fistos Lehrman
+Fort Lauderdale, FL 33301-3268
+Paul G. Cassell
+S.J. Quinney College of Law at the
+University of Utah
+Salt Lake City, Utah 84112
+Attorneys for Jane Doe # 1 and Jane Doe # 2
+Although the Respondent is represented by the U.S. Attorney's Office and, accordingly, does not pay
+attorneys' fees for its representation, the Court should consider the "costs" to the Office and the public by having
+criminal prosecutors and civil litigators devoting the tremendous amount of time required to respond to the
+overbroad requests of the Petitioners in lieu of investigating and prosecuting criminal defendants or affirmative
+civil cases.
+Although the United States objects to the application of Fed. R. Civ. P. 26, part of what it has agreed to
+voluntarily provide is some, but not all, of the information called for by this Rule.
diff --git a/vision-fixhub/ds9-unparsed-06/1b22866f2a48b49b6978948bfe30b0ccf0329007459e4d75b1b57763374bfe4e.receipt.json b/vision-fixhub/ds9-unparsed-06/1b22866f2a48b49b6978948bfe30b0ccf0329007459e4d75b1b57763374bfe4e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..bb71eed4dcb3288260331d1b6563de5fb6c82d6a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1b22866f2a48b49b6978948bfe30b0ccf0329007459e4d75b1b57763374bfe4e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -60,
+  "dataset": "marble-joined",
+  "doc_id": "1b22866f2a48b49b6978948bfe30b0ccf0329007459e4d75b1b57763374bfe4e",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "4e2af6b4495e9c5c31fd7569a4af5c448e58330f2ca1defe1a981c0cbfdc4243",
+  "output_sha256": "2adc76b81cb553735f23b718399887677e9cf292f97d124e38d919941225f901",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1bb458c8232893faa0032061a0a3606930934f0da90e1932cbee6c3000b4df27.md b/vision-fixhub/ds9-unparsed-06/1bb458c8232893faa0032061a0a3606930934f0da90e1932cbee6c3000b4df27.md
new file mode 100644
index 0000000000000000000000000000000000000000..06c596facc91200d71c44a41de0192ac7b0511c7
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1bb458c8232893faa0032061a0a3606930934f0da90e1932cbee6c3000b4df27.md
@@ -0,0 +1,71 @@
+(USAFLS)"
+To:
+Subject: RE: A question regarding a very old case
+Date: Thu, 21 Jun 2007 17:20:15 +0000
+Importance: Normal
+>
+No problem,
+Life here has been crazy, and I am sure it is the same for you.
+Assistant U.S. Attorney
+Sent: Thursday, June 21, 2007 1:20 PM
+To:
+1. (USAFLS)
+Subject: RE: A question regarding a very old case
+I apologize for the delay in sending the email.
+To:
+I. (USAFLS) [mailto:
+Sent: Thursday, June 21, 2007 1:08 PM
+I (USANYS)
+Subject: RE: A question regarding a very old case
+Thank you so much!
+Assistant U.S. Attorney
+Sent: Thursday, June 21, 2007 12:47 PM
+To:
+(USANYS)
+Cc:
+1. (USAFLS)
+Subject: FW: A question regarding a very old case
+1, a Criminal AUSA in Florida, is seeking access to our files in US Jeffrey Epstein & Ivan
+Fisher, 96 Civ. 8307 (DC), my infamous landlord-tenant case. Would it be possible for you to have someone
+order the files for her? She is looking for Epstein's deposition transcript.
+Complicating matters is the fact that Epstein had a protective order regarding certain financial discovery, so,
+assuming the files can be located, it would be necessary to have someone review the transcript before giving
+a copy.
+
+
+contact information is below.
+Many thanks. Hope all is well.
+I. (USAFLS) [mailto:
+Sent: Thursday, June 14, 2007 2:15 PM
+To:
+Subject: RE: A question regarding a very old case
+If it isn't too much trouble. Let me just review the protective order that you sent to me to make sure I don't get
+us into trouble by looking at those items for possible use in my case.
+Assistant U.S. Attorney
+Sent: Thursday, June 14, 2007 2:09 PM
+To:
+1. (USAFLS)
+Subject: RE: A question regarding a very old case
+I have a very vague memory of deposing him. Do you want me to put you in touch with someone in the USAO
+to see if they can order the file?
+To:
+I. (USAFLS) [mailto:
+Sent: Thursday, June 14, 2007 1:35 PM
+Subject: RE: A question regarding a very old case
+Thank you so much,
+• Were you able to determine if you ever deposed my subject?
+Assistant U.S. Attorney
+Sent: Thursday, June 14, 2007 1:24 PM
+To:
+1. (USAFLS)
+Subject: RE: A question regarding a very old case
+Attached is a copy of the complaint, summary judgment brief and court's decisions. Please let me know if you
+need any further info. Good luck!
+
+
+\ (USAFLS) [mailto:
+Sent: Tuesday, June 12, 2007 3:40 PM
+Subject: A question regarding a very old case
+- I saw that you were the AUSA who worked on a case several years ago against Jeffrey Epstein
+involving the lease of a former embassy. Do you remember anything about the case that you might be willing to
+Assistant U.S. Attorney
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/1bb458c8232893faa0032061a0a3606930934f0da90e1932cbee6c3000b4df27.receipt.json b/vision-fixhub/ds9-unparsed-06/1bb458c8232893faa0032061a0a3606930934f0da90e1932cbee6c3000b4df27.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a181a618c51b6e8978ea5f6d6867c8b5ca58eaee
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1bb458c8232893faa0032061a0a3606930934f0da90e1932cbee6c3000b4df27.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -91,
+  "dataset": "marble-joined",
+  "doc_id": "1bb458c8232893faa0032061a0a3606930934f0da90e1932cbee6c3000b4df27",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "457558aa5cfe4916dbc77e17c55bcfa7d07908572f821367caf9e0503ea0114d",
+  "output_sha256": "1f1229417c913ee8178fb8742a546baf0309859fc403c7a8ba1cb017b16d0ba2",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1c209c2a9dd43a13e46ee35d93259612d47e6e848f77e45dd9d5f7bf69f7dcf6.md b/vision-fixhub/ds9-unparsed-06/1c209c2a9dd43a13e46ee35d93259612d47e6e848f77e45dd9d5f7bf69f7dcf6.md
new file mode 100644
index 0000000000000000000000000000000000000000..4a9c7d3b705fd3562ac89a27678271d4934dae29
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1c209c2a9dd43a13e46ee35d93259612d47e6e848f77e45dd9d5f7bf69f7dcf6.md
@@ -0,0 +1,5 @@
+
+
+4. State Attorney's Office for Palm Beach County
+Barry Krisher
+Lanna Behlolahvek
diff --git a/vision-fixhub/ds9-unparsed-06/1c209c2a9dd43a13e46ee35d93259612d47e6e848f77e45dd9d5f7bf69f7dcf6.receipt.json b/vision-fixhub/ds9-unparsed-06/1c209c2a9dd43a13e46ee35d93259612d47e6e848f77e45dd9d5f7bf69f7dcf6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0aa5fa81c0b9a7fa241ab2b90ed0ff91bad7e04b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1c209c2a9dd43a13e46ee35d93259612d47e6e848f77e45dd9d5f7bf69f7dcf6.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "1c209c2a9dd43a13e46ee35d93259612d47e6e848f77e45dd9d5f7bf69f7dcf6",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "44944a7cc185d4984d760e97c8a885b7897d0f603e01cd9f1d1aae1692a55a5d",
+  "output_sha256": "eb224765ffd2a8b449ffbf788480de398bd2e052cded896aaf514f3275289ee4",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1c586aeab0a175690d95d5f03e0972c6c9346b7cae94ae28a4c2ff75f5e42e5c.md b/vision-fixhub/ds9-unparsed-06/1c586aeab0a175690d95d5f03e0972c6c9346b7cae94ae28a4c2ff75f5e42e5c.md
new file mode 100644
index 0000000000000000000000000000000000000000..e95265d4f60aba9593073bb55e45bf9682e27522
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1c586aeab0a175690d95d5f03e0972c6c9346b7cae94ae28a4c2ff75f5e42e5c.md
@@ -0,0 +1,507 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs
+UNITED STATES,
+Defendants
+JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR PRODUCTION
+TO THE GOVERNMENT REGARDING INFORMATION RELEVANT TO THEIR
+PENDING ACTION CONCERN THE CRIME VICTIMS RIGHTS ACT
+COME NOW Jane Doe #1 and Jane Doe #2 ("the victims"), by and through undersigned
+counsel, and request the defendant United States (hereinafter "the Government") to produce the
+original or best copy of the items listed herein below for inspection and/or copying, pursuant to
+the Court's Order (DE #99) directing discovery in this case.
+BACKGROUND
+As the Government will recall, the victims have asked the Government to stipulate to
+undisputed facts in this case. The Government has declined. Accordingly, the victims filed their
+Motion for Finding of Violations of the Crime Victims' Rights Act and Request for a Hearing on
+Appropriate Remedies (DE 48) (the victims" "summary judgment motion") along with a Motion
+to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts
+(DE 49).
+On September 26, 2011, the Court denied the victims' motion to have their facts accepted
+(DE 99 at 11). At the same time, however, the Court has ordered discovery to develop the
+
+
+factual record concerning the summary judgment motion (DE 99 at 11). The Court reserved
+ruling on the victims' motion for an order directing the Government not to suppress relevant
+evidence (DE 99 at 11).
+On September 28, 2011, the victims requested that the Government voluntarily provide
+documents concerning this case. The Government declined to provide even a single document.
+Accordingly, the victims now seek the following information relevant to their pending summary
+judgment motion.
+DISCOVERY REQUESTED
+The numbered discovery requests below should all be construed in light of the definitions of
+terms provided at the end of the requests.
+1. In the victims' currently-pending summary judgment motion, the victims contend that the
+Government conducted an extensive criminal investigation into Jeffrey Epstein's sexual
+exploitation of young girls, including Jane Doe #1 and Jane Doe #2 between 2001 and 2008.
+The victims also contend that the FBI and other federal agencies established that Epstein
+operated a large criminal enterprise that used paid employees and underlings to repeatedly find
+and bring minor girls to him. In deferring ruling on the victims' summary judgment motion, the
+Court noted that the victims had alleged that the FBI and the U.S. Attorney's Office's
+"investigation developed a strong case for a federal prosecution against Epstein based on
+'overwhelming' evidence." DE 99 at 2. The Court, however, also noted that this was an
+allegation that needed "further factual development." DE 99 at 2 n.2. Please provide all
+documents, correspondence, and other information that supports these victims" allegations,
+including:
+(a) the FBI case file on the Epstein case;
+(b) all documents, correspondence, witness statements, FBI 302s, and other
+similar information, that the Government collected as part of its case against
+and/or investigation of Epstein, including any information provided to Epstein
+or receive from Epstein as part of "discovery" or exchange of information
+concerning the case;
+(c) all documents, correspondence, witness statements, and other similar
+information that the Government received from any federal, state, local, or
+other law enforcement agency regarding sex offenses committed against
+children by Jeffrey Epstein;
+(d) the 82-page prosecution memorandum (a/k/a "pros memo") outlining
+numerous federal sexual offenses committed by Epstein (and any attachments
+to that memorandum) and the 53-page draft indictment for numerous federal
+
+
+offenses that the Government developed in this case and any similar successor
+or predecessor document; and
+(e) Any other prosecution memorandum regarding Jeffrey Epstein (and any
+documents attached to that memorandum) and all draft federal indictments
+that were prepared regarding Epstein. Please also provide all documents,
+correspondence, and
+other information regarding these prosecution
+memoranda and the draft federal indictments.
+2. Throughout their pending summary judgment motion, the victims contend that they
+received only limited notifications from the Government (and, in particular, the U.S. Attorney's
+Office acting through FBI agents) about the plea negotiations that occurred with Jeffrey Epstein
+and the non-prosecution agreement that was ultimately reached. Please provide all documents,
+correspondence and other information regarding victim notifications in this case, including (but
+not limited to):
+a) All crime victims notifications (and draft notifications) sent to Jane Doe #1 and
+Jane Doe #2 and the other identified victims of Epstein's offenses;
+b) All correspondence, documents, and other information regarding negotiations
+between the Government and Epstein's defense attorneys concerning the extent
+and nature of notifications to be made to Epstein's victims;
+c) All correspondence, documents, and other information regarding discussions
+between the Government, the FBI, the Palm Beach Police Department, the Palm
+Beach County State Attorney's Office, and Epstein's defense attorneys
+concerning the extent and nature of notifications to be made to Epstein's victims;
+d) All correspondence, documents, and other information regarding "marching
+orders" that were given to FBI agents regarding the information that they could
+provide to the victims about the negotiations and the non-prosecution agreement;
+e) All correspondence, documents, and other information regarding information that
+could be given to attorneys for the victims about the non-prosecution agreement,
+including information about what could be told to Brad Edwards (counsel for Jane
+Doe #1 and Jane Doe #2) about the non-prosecution agreement;
+f) All correspondence, documents, and other information regarding Epstein's
+awareness that his victims (including Jane Doe #1 and Jane Doe #2) would not be
+notified of the non-prosecution agreement (and its ultimate presentation in court)
+or given a chance to confer regarding the plea negotiations he was conducting
+with the Government.
+3. The victims allege in their pending summary judgment motion that the Government
+negotiated a non-prosecution agreement with Epstein and that among the subjects covered in that
+non-prosecution agreement was a confidentiality provision that precluded disclosing the
+agreement to them and to other victims. Please provide all draft plea agreements (both state and
+federal) and non-prosecution agreements prepared either by attorneys for the Government or by
+attorneys for Epstein, as well as any correspondence, documents or other information pertaining
+to these agreements and to any confidentiality provision in these agreements. Please indicate
+that date on which each of these proposed agreements was drafted and by whom.
+
+
+4. The victims allege in their pending summary judgment motion that the Government was
+interested in finding a place to conclude any plea agreement that would effectively keep
+Epstein's victims (most of whom resided in or about West Palm Beach) from learning what was
+happening through the press.
+Please provide all correspondence, documents, and other
+information pertaining to negotiations between the Government and Jeffrey Epstein concerning
+the court and/or location in which Jeffrey Epstein would enter any guilty plea (including in
+particular any negotiations concerning concluding the plea in Miami or other location outside of
+West Palm Beach).
+5. The victims allege in their pending summary judgment motion that part of the plea
+negotiations with Epstein involved Epstein's efforts to make sure that the victims would be
+represented in civil cases against Epstein by someone who was not an experienced personal
+injury lawyer. Please provide all correspondence, documents, and other information pertaining
+to negotiations between the Government and Jeffrey Epstein regarding any legal representation
+of the victims in civil cases against Epstein, including any negotiations about what kinds of
+representation should be provided in a plea agreement or non-prosecution agreement.
+6. The victims allege in their pending summary judgment that the Government wanted the
+non-prosecution agreement with Epstein concealed from public view because of the intense
+public criticism that would have resulted had the agreement been disclosed and/or the possibility
+that victims would have objected in court and convicted the judge not to accept the agreement.
+Please provide all correspondence, documents, and other information concerning the
+Government's and/or Epstein awareness or discussion of this possible public criticism and/or
+victim objections.
+7. The victims allege in their pending summary judgment motion that the Government was
+aware that it potentially had obligations under the CVRA to notify the victims about the nonprosecution agreement and any related state court plea agreement. Please provide all
+correspondence, documents, and other information regarding the Government's awareness of its
+potential CVRA obligations in this case and regarding any discussions between the Government
+and Epstein concerning these CVRA obligations in this case. This should include any objections
+raised by Epstein to any notification of the victims (including Jane Doe #1 and Jane Doe #2) and
+any Government response to these objections. This should also include any correspondence and
+information about whether the CVRA applied to the victims.
+8. The victims allege in their pending summary judgment motion that, after Epstein signed
+the non-prosecution agreement, his performance was delayed while he used his significant social
+and political connections to lobby the Justice Department to obtain a more favorable plea deal
+(including lobbying components of the Justice Department in Washington, D.C., including the
+Child Exploitation Obscenity Section). Please provide all correspondence, documents, and other
+information regarding Epstein's lobbying efforts to persuade the Government to give him a more
+favorable plea arrangement and/or non-prosecution agreement, including efforts by former
+President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York),
+Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy
+Black on his behalf.
+
+
+9. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI
+advising them that "this case is currently under investigation." Please provide all documents,
+being made to the victims.
+10. In their pending summary judgment motion, the victims have alleged that the FBI was led
+to believe that their investigation of Epstein was going to produce a federal criminal prosecution
+and that the FBI was also misled by the U.S. Attorney's office about the status of the case.
+Please provide all documents, correspondence, and other information relating to these
+allegations, including:
+a) All documents, correspondence, and other information relating to discussions
+between the U.S. Attorney's Office and the FBI concerning the status of the
+investigation and the plea discussions with Epstein, as well as what kind of
+charges would appropriately be filed against Epstein;
+b) All documents, correspondence, and other information relating to the U.S.
+Attorney's Office's representations to the FBI and any other state or local law
+enforcement agency about how this case was being handled; and
+c) All documents, correspondence, and other information relating to whether the FBI
+would support the position of the U.S. Attorney's Office that it has not violated
+the rights of Epstein's victims in this case.
+11. In their pending summary judgment motion, the victims have alleged that they had
+various meetings with Government prosecutors and/or agents (including FBI agents). Related to
+these meetings, they also allege that in mid-June 2008, their attorney (Bradley J. Edwards)
+discussed with an AUSA involved in the case the need for filing federal charges and that the
+AUSA asked the attorney to send a letter about why such charges should be filed without
+disclosing the existence of a previously-signed non-prosecution agreement. The victims further
+allege that on about July 3, 2008, their attorney sent a letter urging the filing of federal charges
+against Epstein. Please provide all documents, correspondence, and other information regarding
+these meetings with the victims and their legal counsel, including meetings with the victims on
+October 26, 2007, and January 31, 2008, and the contact with their legal counsel in mid-June
+2008. Please also provide all documents, correspondence, and other information related to
+contacts between the Government and the National Crime Victim's Law Institute (NCVLD)
+concerning possible legal representation or other assistance to the victims by NCVLI.
+12. In their pending summary judgment motion, the victims allege that in mid-June 2008,
+their attorney (Bradley J. Edwards) discussed with an AUSA involved in the case the need for
+filing federal charges and that the AUSA asked the attorney to send a letter about why such
+charges should be filed without disclosing the existence of the non-prosecution agreement. The
+victims further allege that on about July 3, 2008, their attorney sent a letter urging the filing of
+federal charges against Epstein. Please provide all documents, correspondence, and other
+information regarding these contacts, including e-mails and correspondence generated as a result
+of the attorney's inquiry and any action that was taken in response to the letter that he sent.
+
+
+13. In their pending summary judgment motion, the victims allege that on or about June 27,
+2008, the Government learned that Epstein would be entering his plea to state charges on about
+June 30, 2008. Please provide all documents, correspondence, and information regarding:
+a) How the Government Office learned that the plea was going to be entered;
+b) How the Government notified victims about the entry of the guilty plea; and
+c) The contents of the notifications given to the victims about the entry of the guilty,
+including whether the victims were informed about the non-prosecution
+agreement and about whether the entry of this plea would preclude prosecution of
+crimes Epstein had committed against them.
+14. In their pending summary judgment motion, the victims have alleged that the
+Government and Epstein worked together to keep the existence of the non-prosecution
+agreement secret, including declining comment about the existence of such an agreement when
+asked about it when his guilty plea in state court became public knowledge. Please provide all
+documents, correspondence, and information about the Government's and Epstein's efforts to
+keep the existence of the non-prosecution agreement secret, including all e-mails and
+correspondence about "declining comment" or similar devices to keep the non-prosecution
+agreement secret.
+15. In their pending summary judgment motion, the victims allege that at all materials times,
+it would have been practical and feasible for the Government to have kept the victims informed
+about the discussions concerning the non-prosecution agreement. The victims further allege that
+on about July 9, 2008, the U.S. Attorney's Office provided notice to Jane Doe #1 of some of the
+terms of the agreement between it and Jeffrey Epstein. The victims also received a "corrected"
+notification letter on about September 3, 2008. Please provide all documents, correspondence,
+and other information about these notifications, including:
+a) any information about whether these notifications should or should not include
+some mention of the non-prosecution agreement;
+b) any information about the contents of these notifications;
+c) any communications between the Government and Epstein's counsel regarding
+what the notifications should contain, including any communication on or about
+July 9, 2008, objecting to parts of the draft;
+d) Any communications between the Government and Epstein's counsel about
+which parts of the non-prosecution agreement were operative (including whether
+Part 3 was operative:
+e) Any communications between the Government and Epstein's counsel regarding
+the September 3, 2008, corrected notification letter; and
+f) any documents, correspondence, and other information regarding the practicality
+and feasibility of providing notice to the victims of the existence of the
+agreement, which shall include any correspondence related to meeting with the
+victims or notifying them in any way of the non-prosecution agreement.
+16. In their pending summary judgment motion, the victims allege that one of the senior
+prosecutors in the U.S. Attorney's Office joined Epstein's payroll shortly after important
+decisions were made limiting Epstein's criminal liability - and improperly represented people
+close to Epstein. In light of this fact, the peculiar nature of the non-prosecution agreement
+
+
+reached in this case, and other information in the possession of the victims, it is also possible that
+other improper relationships exist between Government agents and Epstein. Please provide any
+documents, correspondence, and other information regarding the possibility of any improper
+relationship, including:
+a) Attorney
+nvolvement in and/or awareness of any aspect of the
+Government's criminal investigation and/or possible prosecution/non-prosecution
+of Epstein;
+b) Attorney
+• involvement in and/or awareness of the Government's
+interest in any witness, subject, or target of the Epstein investigation, including
+, Ghislaine Maxwell, Madi
+•. Lesley Groff, dal
+bulla Ruboyo, Larry Morison, Lary Visok, David Rogers, Wantam
+Hammond, and Robert Roxburgh;
+c) All documents, correspondence, and other information reflecting telephone calls
+(including telephone logs and telephone billing statements) made by or received
+by Reinhart from Jeffrey Epstein, the Florida Science Foundation, Jack
+Goldberger, Alan Dersowitz, Roy Black, Ken Starr, Lillian Sanchez, and any
+other person involved with the criminal defense of Jeffrey Epstein, including
+telephone calls to and from Jack Goldberger and the Florida Science Foundation;
+d) All documents, correspondence, and other information (including, for example, e-
+mails) that were sent to, copied to, or sent by Reinhart in which the word
+"Epstein," "Kellen, "Ruboyo," "Morrison," "Visoki," "Rogers." "Hammond,"
+Roxburgh," Wiltafana,
+"Florida Science Foundation," "Starr," "Black,"
+"Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," "358 El Brillo Way"
+appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger,
+or the Jeffrey Epstein investigation or prosecution;
+e) All documents, correspondence, and other information (including for example e-
+mails) of a similar nature that indicate that any other Government prosecutor has
+represented (or discussed representing) a person or entity related to Jeffrey
+Epstein or has received business or funds from a person or entity related to Jeffrey
+Epstein;
+f) All documents, correspondence, and other information that indicate or suggest
+that any Government prosecutor or investigator (including state and local
+prosecutor or investigator) has had any form of business, social, personal, or other
+relationship with Jeffrey Epstein or a person or entity related to Jeffrey Epstein;
+and
+g) All documents, correspondence, and other information that indicate or suggest
+that any Government prosecutor or investigator (including state and local
+prosecutor or investigator) would receive anything of value, directly or indirectly
+from Jeffrey Epstein or a person or entity related to Jeffrey Epstein (including any
+charitable contributions to be made by Epstein to any entity).
+17. In December 2010, the victims sent a letter to the U.S. Attorney's Office for the Southern
+District of Florida, requesting that the Office investigate whether "improper influences" were
+brought to bear during the negotiations involving the possible prosecution (and ultimately the
+non-prosecution) of Jeffrey Epstein. That letter led to a reference of the matter to the Office of
+
+
+Professional Responsibility (OPR) in the Justice Department in Washington, D.C., which began
+some kind of an inquiry/investigation. Please provide:
+a) All documents, correspondence, and other information collected by the Office of
+Professional Responsibility (OPR) and any other component of the Justice
+Department (including the FBI) in response to the victims' letter;
+b) All documents, correspondence, witness statements, and other information
+collected as part of OPR's inquiry/investigation;
+c) All documents, correspondence, witness statements and other information
+collected as part of any criminal inquiry/investigation that was initiated as a result
+of that letter, including any inquiry/investigation into criminal conflict of interest
+violations (such as 18 U.S.C. § 205 and § 207)
+d) All documents, correspondence, witness statements, and other information
+collected by any federal investigative agency that was triggered by OPR's
+inquiry/investigation, including any FBI inquiry/investigation regarding any
+improper influences or criminal or ethical violations that may have been
+committed by government attorneys during the handling of the Epstein
+investigation and/or prosecution;
+e) Any documents, correspondence, and other information regarding the accuracy or
+inaccuracy of Bruce Reinhart's sworn statements (found in DE 79-1 at p. 31) that
+he "did not participate in any way in the Office's investigation of Epstein;" that he
+"was not involved in any of the Office's decisionmaking with regard to the
+Epstein matter;" and that he "never learned any confidential, non-public
+information about the Epstein matter;"
+f) Any documents, correspondence,
+or other
+information regarding the
+circumstances that lead OPR to send a letter to the victims on May 6, 2011,
+indicating that they would not provide any further assistance to the victims in
+connection with their allegations that improper influences were brought to bear on
+the Epstein case;
+g) Any document, correspondence, e-mail, memoranda, or other information
+prepared by OPR, the FBI, or other Justice Department Component as a result of
+or following up on the victims' December 2010 letter concerning the Epstein
+case: and
+h) Any documents, correspondence, or other information that OPR has collected or
+obtained regarding the Epstein investigation and/or prosecution.
+18. At a couple points during the prosecution of this action, including in approximately
+December 2010 and most recently after the August 2011 hearing, the Justice Department in
+Washington, D.C., discussed or determined that the U.S. Attorney's Office for the Southern
+District of Florida (USAO SDFL) was "conflicted out", or may be conflicted out, of handling
+various issues related to the Epstein case because it suffered from a conflict of interest. The
+Justice Department accordingly sent various issues related to the Epstein case (and, on
+information and belief, issues related to Jane Doe #1 and Jane Doe #2) to the Department of
+Justice and to a United States Attorney's Office in another District. Please provide all
+documents, correspondence, and other information regarding the potential conflicts of interest
+that the Justice Department discussed or determined existed for the USAO SDFL, as well as any
+referral that was made to Main Justice or to any other District, including any documents that
+
+
+were transmitted to any other District regarding the conflict and regarding what was to be
+investigated.
+19. In March 2011, former U.S. Attorney Alexander Acosta sent a three-page letter to the
+news media in which he claimed that when Government attorneys began investigating Epstein,
+Epstein launched "a yearlong assault on the prosecution and the prosecutors." Shortly thereafter,
+Jeffrey Epstein's defense attorney Roy Black sent a responsive letter to Alexander Acost's letter
+to the news media in which he claimed that he did not pry into the personal lives of prosecutors
+but merely pointed out misconduct and over-reaching by certain people involved in the Epstein
+investigation. Please provide all documents, correspondence and other information that supports
+or contradicts Acosta's allegations in his letter, including any information that the Justice
+Department received from Epstein attacking the prosecutors and investigators working on the
+case. Please also provides all documents, correspondence, information about misconduct and
+over-reaching that was provided by Black and that the Government found that supported or
+contradicted such allegations.
+20. In their pending summary judgment motion, the victims have alleged that Epstein's guilty
+plea to state charges was intended to be the consummation of a non-prosecution agreement that
+barred prosecution of federal offenses committed against them. They have further alleged that
+Epstein entered such a guilty plea on or about June 30, 2008. Please provide all documents,
+correspondence, and other information between the Government and state and local prosecutors
+and police agencies (including The Palm Beach Police Department and Palm Beach State
+Attorney's Office) regarding the Epstein investigation and ultimate Epstein plea.
+21. In their pending summary judgment motion, the victims have alleged that correspondence
+in the possession of the Government will support their claims. Please provide all documents,
+correspondence, and other information between Government attorneys/officials (including both
+federal and state prosecutors) and attorneys for Jeffrey Epstein (or non-attorney acting on
+Epstein's behalf) relating to (1) negotiations involving the possible prosecution (and ultimately
+the non-prosecution) by federal or state agencies for sex offenses, including sex offenses
+committed against Jane Doe #1 and Jane Doe #2, (2) Epstein's entry of state guilty pleas for
+related
+sex offenses; (3) a non-prosecution agreement entered into between Epstein and the
+Government that barred his prosecution for offenses committed against Jane Doe #1 and Jane
+Doe #2; (4) the fulfillment of Epstein's and/or the Government's obligations under the nonprosecution agreement and/or the state guilty pleas Epstein entered; (5) any work release or other
+conditional release of Epstein from confinement; (6) any designation of Epstein as a sex offender
+or restrictions on him contacting victims of his offenses (including Jane Doe #1 and Jane Doe
+#2); and (7) any termination of supervision or parole of Epstein. This information should include
+unredacted e-mails, letters, and correspondence of any type between government prosecutors
+working on the case (including, but not limited to, federal prosecutors Alexander Acosta, Jeffrey
+H. Sloman, Matt Menchel, Andy Lourie, Ann Marie Villafana, Dexter Lee, and Bruce Reinhart
+and state prosecutors Dahlia Weiss, Lana Belolovek, and others involved in the Epstein
+investigation) and defense attorneys representing Epstein (including, but not limited to, Roy
+Black, Jay Letkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy
+Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein
+(including, but not limited to former President Bill Clinton and Andrew Albert Christian Edward
+
+
+(a/k/a Prince Andrew, Duke of York). This should also include letters of recommendation or
+similar communications submitted to any Government official vouching for or providing support
+for Jeffrey Epstein.
+22. As you know, throughout their pending summary judgment motion, the victims have
+alleged that they were not properly notified of plea negotiations with Jeffrey Epstein and were
+denied their right to confer by the Government and that instead the Government gave Epstein
+generous concessions through the plea negotiations. Please provide any documents,
+correspondence and other information that reflects or discusses any consideration of any type
+that Epstein had previously provided or offered to provide to the Government (or any individual
+within the Government, in either his official or private capacity) or any person previously
+employed by the Government and involved in the Epstein investigation or prosecution. The
+documents, correspondence, and other information should include any information discussing:
+(a) Any donation or offer to donate, directly or indirectly, either funds, services,
+or any other valuable consideration to any person or entity;
+(b) Any offer to assist, directly or indirectly, any person to obtain employment,
+business opportunities, business clients, real estate, office properties;
+(c) Any offer to assist the Government or law enforcement agencies in the
+investigation or prosecution of any federal or state criminal offense;
+(d) Any consideration that Epstein had provided to Government or law
+enforcement agencies in the past; and
+(e) Any other consideration of any type that Epstein offered to provide or had
+provided in the past that could provide a basis for the Government extending
+Epstein a more generous or lenient plea bargain or non-prosecution agreement
+than would be received by any other similarly situated child abuse suspect.
+23. The Crime Victims' Rights Act, 18 U.S.C. § 3771(c)(1), requires the Government to use
+its "best efforts" to protect the rights of crime victims.
+Please provide all documents,
+correspondence, and other information that will assist Jane Doe #1 and Jane Doe #2 in protecting
+their rights under the CVRA, including all documents, correspondence, and other information
+that the Government previously identified as being helpful to the victims but refused to provide
+based on its legal interpretation (now rejected by the Court) that the CVRA did not apply to this
+case because no indictment was filed.
+24. In the course of its investigation of Epstein and negotiations with Epstein, the
+Government (i.e., federal investigators and prosecutors) shared documents, correspondence, anc
+information with other persons outside the federal government, including state and local
+prosecuting and law enforcement agencies, prosecuting and law enforcement agencies in other
+countries, Epstein's legal counsel, legal counsel for crime victims, and other entities. Please
+provide all documents, correspondence, and other information that the Government shared with
+any entity or person outside the federal government, including all correspondence (including e-
+mails) with those entities or persons.
+25. After the victims had made extensive efforts to try and reach a stipulated set of facts in
+this case, in March 2011 the Government refused to negotiate about such facts. Accordingly, at
+that time the victims filed various motions to obtain evidence in this case and, at the same time,
+
+
+the victims voluntarily made all initial disclosures on their part that are required by Federal Rule
+of Civil Procedure 26(a)(1). Please provide all initial disclosures required by the Federal Rules
+of Civil Procedure, including all disclosures required by Rule 26(a)(1).
+DEFINITIONS
+For the purpose of construing the foregoing discvery requests, the following terms are
+defined:
+The term "documents" means and includes, without limitation, all writings of any kind,
+including the originals and all non-identical copies or drafts, whether different from the origina
+y reason of any notation made on such copy or draft or otherwise including, without limitation
+correspondence, memoranda, notes, diaries, statistics, letters, e-mails, electronic computer files,
+telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries,
+pamphlets, books, prospectuses, interoffice communications, offers, notations of any sort of
+converter on telephone cales, facings, inhere morties and latinatined mater,
+modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records
+or representations of any kind including, without limitation, photographs, charts, graphs,
+microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or
+electric records or representations of any kind including, without limitation, tapes, cassettes and
+dise recordings, and writings and printed material of every kind.
+The term "correspondence" means any tangible object that conveys information or
+memorializes information that was conveyed in tangible or oral form including, but not limited
+to, writings, letters, memoranda, reports, notes, e-mails, telephone logs, telephone billing
+information, telephone recordings, and interoffice communications.
+The term "Epstein's victims" means any person that the Government identified as a
+possible victim of a sex offense committed by Jeffrey Epstein, including Jane Doe #1, Jane Doe
+#2, all victims identified in attachment to the non-prosecution agreement entered into by Epstein,
+and another person that the Government investigated as a possible victim of Epstein's sex
+offenses.
+The term "Government" means the federal government, including all employees of and
+components of the United States Department of Justice (such as, the Office of the Attorney
+General, the Office of the Deputy Attorney General, the Criminal Divisions, the Office of
+Professional Responsibility, the Child Exploitation and Obscenity Section, the U.S. Attorney's
+Offices for the Southern District and Middle District of Florida, and the Federal Bureau of
+Investigation) and other federal government agencies with law enforcement responsibilities
+related to the Epstein case (such as the Internal Revenue Service). This request for production
+seeks all documents, correspondence, and other information held by all of these entities,
+including all employees of and components of the Justice Department that worked on or were in
+any way involved the Epstein investigation and/or that possess information relevant to the
+victims' claims.
+
+
+The term "including" means containing within the request, but not limiting the request.
+The term
+(including oral form) reflecting, recording, or otherwise memorializing a statement made or
+information conveyed by a potential witness, including for example FBI 302's. The term
+neludes information collected by any law enforcement, prosecuting or government agency
+ncluding all federal. state. and local law enforcement agencies located in Washington, D.C.. c
+Florida.
+NO GRAND JURY TRANSCRIPTS SOUGHT
+If any of the foregoing requests cover grand jury transcripts, do not provide the grand
+guayd jury ran cript, pled the foregoin pareguests quotade documents that quote directly from a
+PRIVILEGE LOG
+If you believe that any document, correspondence, or other information requested in this
+equest is subject to a privilege and if you intend to assert that privilege, please provide a
+"privilege log" consistent with Local Rule 26.1(g), including a description a document that is
+consistent with Local Rule 26.1(g)(3)(B). Your privilege log should include the type of
+document, general subject matter of the document, date of the document, and author and
+REDUCING UNDUE BURDEN
+If you believe that complying with any of the foregoing requests would be unduly
+any such burderease contact victims counsel - Bradley J. Edwards - to discuss ways to reduce
+DATED: October 3, 2011
+Respectfully Submitted,
+s/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+DIDDO DROOL LED DI
+
+
+and
+Paul G. Cassell
+Pro Hac Vice
+Attorneys for Jane Doe #1 and Jane Doe #2
+CERTIFICATE OF SERVICE
+The foregoing document was served on October 3, 2011, on the following via US Mail and
+E-Mail Transmission:
+5
+Roy Black, Esq.
+Jackie Perczek, Esq.
+Respectfully Submitted
+S/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
diff --git a/vision-fixhub/ds9-unparsed-06/1c586aeab0a175690d95d5f03e0972c6c9346b7cae94ae28a4c2ff75f5e42e5c.receipt.json b/vision-fixhub/ds9-unparsed-06/1c586aeab0a175690d95d5f03e0972c6c9346b7cae94ae28a4c2ff75f5e42e5c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ee7f24707ea09b5572c941a864afa8c11c8f16ec
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1c586aeab0a175690d95d5f03e0972c6c9346b7cae94ae28a4c2ff75f5e42e5c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -160,
+  "dataset": "marble-joined",
+  "doc_id": "1c586aeab0a175690d95d5f03e0972c6c9346b7cae94ae28a4c2ff75f5e42e5c",
+  "engine": "marble-apple-vision",
+  "event_count": 15,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "395fe8b0ee8406f4bc06f9fea3ade89fc522338743469cb75209ad0f05209e98",
+  "output_sha256": "4173cedab5e1234216338036298f519d60805830ed150819764433aaeaa13b2e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1c6682724e439921053ff6749d90f54b8bd82c6e0ad497c8a2ee6c6a3e393c4a.md b/vision-fixhub/ds9-unparsed-06/1c6682724e439921053ff6749d90f54b8bd82c6e0ad497c8a2ee6c6a3e393c4a.md
new file mode 100644
index 0000000000000000000000000000000000000000..821512d4177fb176df0bd6f5cfea8a7ee638cdda
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1c6682724e439921053ff6749d90f54b8bd82c6e0ad497c8a2ee6c6a3e393c4a.md
@@ -0,0 +1,51 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80893-KAM Doe |. Epstein Order
+Date: Wed, 20 Oct 2010 17:10:29 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 10/20/2010 at 1:10 PM EDT and filed on 10/20/2010
+Case Name:
+Doe | Epstein
+Case Number:
+9:08-cv-80893-KAM
+Filer:
+WARNING: CASE CLOSED on 07/20/2010
+Document Number: 222
+Docket Text:
+ORDER re [220] Appeal of Magistrate Judge Order [218] to District Court, filed by Jeffrey
+Epstein. The Magistrate's Order is set aside and this case is REMANDED to the Magistrate
+Judge for further proceedings consistent with the directives of this Order. Signed by Judge
+Kenneth A. Marra on 10/20/2010. (ir)
+9:08-cv-80893-KAM Notice has been electronically mailed to:
+Ann Marie C. Villafana
+ann.marie.c.villafana@usdoj.gov, shawn.ball@usdoj.gov
+Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com
+Jack Alan Goldberger
+jagesq@bellsouth.net, nalanis@agwpa.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+Lilly Ann Sanchez Isanchez@fowler-white.com
+Michael James Pike MPike@bclclaw.com, bobbie@bclclaw.com, jcadwell@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Robert Deweese Critton, Jr rcrit@bclclaw.com, bobbie@bclclaw.com
+
+
+9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:/a
+Electronic document Stamp:
+[STAMP dcecfStamp_ID=1105629215 [Date=10/20/2010] [FileNumber=8117157-
+0] [75488d8aa92aafce2dbeb7dece4cbf8a4e92a8006eeb53bca5531528c2a59b4022
+69a744bcf005f542cf25530525dde3b7a45c0c766c4f58447f8853a1c7bf4d]]
diff --git a/vision-fixhub/ds9-unparsed-06/1c6682724e439921053ff6749d90f54b8bd82c6e0ad497c8a2ee6c6a3e393c4a.receipt.json b/vision-fixhub/ds9-unparsed-06/1c6682724e439921053ff6749d90f54b8bd82c6e0ad497c8a2ee6c6a3e393c4a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..fbc09014ab6133f99624b48e3ea0d662561f9329
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1c6682724e439921053ff6749d90f54b8bd82c6e0ad497c8a2ee6c6a3e393c4a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "1c6682724e439921053ff6749d90f54b8bd82c6e0ad497c8a2ee6c6a3e393c4a",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "8bf0a1d8243eed003645b127da3220430ed85df2f50fd14bec0b91ae4a45f07c",
+  "output_sha256": "d0c2052c87e98a79d0d8b645f33a9ac8da7c9268461da67a39cb0762d43afbdd",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1d8aa1469c3f3e7a3543b48f9e38bc9915735030446c085a9914cd314e672255.md b/vision-fixhub/ds9-unparsed-06/1d8aa1469c3f3e7a3543b48f9e38bc9915735030446c085a9914cd314e672255.md
new file mode 100644
index 0000000000000000000000000000000000000000..fd616818d8efc0fdf21988b60600beda32b4242e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1d8aa1469c3f3e7a3543b48f9e38bc9915735030446c085a9914cd314e672255.md
@@ -0,0 +1,286 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.
+UNITED STATES OF AMERICA
+VS.
+ALFREDO RODRIGUEZ,
+Defendant.
+PLEA AGREEMENT
+The United States of America and Alfredo Rodriguez (hereinafter referred to as the
+"defendant") enter into the following agreement:
+The Charge to Which the Defendant Is Pleading Guilty: The defendant agrees
+to plead guilty to the sole count of the Information, which charges that, from at least as early
+as January 18, 2007, through on or about November 3, 2009, in Palm Beach County, in the
+Southern District of Florida, and elsewhere, the defendant did corruptly conceal a record,
+document, or other object, with the intent to impair the object's availability for use in an
+official proceeding, that is proceedings before a federal grand jury, and otherwise corruptly
+obstructed and impeded said official proceeding; in violation of Title 18, United States Code,
+Section 1512(c).
+The Elements of the Offense of Conviction: The elements of the offense of
+obstruction of justice, in violation of Title 18, United States Code, Section 1512(c), are as
+
+
+
+follows:
+First, that the defendant concealed a record, document, or other object with the
+intent to impair the object's availability for use in an official proceeding, or otherwise
+obstructed or impeded that proceeding;
+Second, that the defendant did so "corruptly," that is, wrongfully and with
+improper purpose; and
+Third, that the defendant's conduct had a relationship in time, causation or
+logic with the official proceeding, that is, that the endeavor had the natural and
+probable effect of interfering with the due administration of justice.
+Statutory Penalties: The defendant understands and acknowledges that, as to
+the charge contained in the Information, the Court may impose a maximum sentence of
+twenty (20) years' imprisonment to be followed by a term of supervised release of up to three
+(3) years, and may impose a fine of up to $250,000. The defendant also understands that, in
+addition to any term of imprisonment and supervised release and/or any fine that is imposed,
+the Court may order him to pay restitution to any victim of his offense, as required by law.
+The defendant understands and acknowledges that a violation of the terms of his supervised
+release can result in additional criminal penalties.
+Special Assessment: The defendant further understands and acknowledges that,
+in addition to the sentence imposed under paragraph 3 of this Agreement, a special
+assessment in the amount of $100 will be imposed. The defendant agrees that any special
+assessment imposed shall be paid at the time of sentencing.
+
+
+
+5.
+Applicability of Sentencing Guidelines: The defendant is aware that the
+sentence will be imposed by the Court after considering the Federal Sentencing Guidelines
+and Policy Statements (hereinafter "Sentencing Guidelines"). The defendant acknowledges
+and understands that the Court will compute an advisory sentence under the Sentencing
+Guidelines and that the applicable guidelines will be determined by the Court relying in part
+on the results of a Pre-Sentence Investigation by the Court's Probation Office, which
+investigation will commence after the entry of the defendant's guilty plea. The defendant is
+also aware that, under certain circumstances, the Court may depart from the advisory
+sentencing guideline range that it has computed, and may raise or lower that advisory
+sentence under the Sentencing Guidelines. The defendant further understands that the Court
+is required to consider the advisory guideline range determined under the sentencing
+guidelines, but is not bound to impose that sentence; the Court is permitted to tailor the
+ultimate sentence in light of other statutory concerns, and such sentence may be either more
+severe or less severe than the Sentencing Guidelines' advisory sentence.
+Knowing these
+facts, the defendant understands and acknowledges that the Court has the authority to impose
+any sentence within and up to the statutory maximum authorized by law for the offense
+identified in paragraph 1 and that the defendant cannot withdraw his guilty plea solely as a
+result of the sentence imposed.
+6.
+Rights Waived by Pleading Guilty: The defendant understands that by pleading
+guilty, he knowingly and voluntarily waives the following rights:
+a.
+the right to plead not guilty and to persist in a plea of not guilty;
+
+
+
+the right to a speedy and public trial before a jury of his peers;
+c.
+the right to the effective assistance of counsel at trial, including, if the
+defendant could not afford an attorney, the right to have the Court appoint an attorney
+for the defendant;
+the right at trial to be presumed innocent until guilt has been proven
+beyond a reasonable doubt by the United States;
+the right at trial to confront and cross-examine witnesses against the
+defendant;
+f.
+the right to compel or subpoena the testimony of witnesses and other
+evidence to present at trial;
+g.
+the right at trial to testify or to remain silent, and the right that such
+silence could not be used against the defendant;
+h.
+the right to challenge the sufficiency of the Information; and
+i.
+the right to appeal any pretrial rulings or a finding of guilt.
+Government's Right to Disclose Information to the Court: The Office of the
+United States Attorney for the Southern District of Florida (hereinafter "Office") reserves the
+right to inform the Court and the Probation Office of all facts pertinent to the sentencing
+process, including all relevant information concerning the offenses committed, whether
+charged or not, as well as concerning the defendant and the defendant's background. Subject
+only to the express terms of any agreed-upon sentencing recommendations contained in this
+Agreement, this Office further reserves the right to make any recommendation as to the
+
+
+
+quality and quantity of punishment.
+Acceptance of Responsibility: The United States and the defendant agree that,
+although not binding on the Probation Office or the Court, they will jointly recommend that
+the Court should reduce by two levels the sentencing guideline level applicable to the
+defendant's offense, pursuant to Section 3E1.1 of the Sentencing Guidelines, based upon the
+defendant's recognition and affirmative acceptance of personal responsibility. If at the time
+of sentencing the defendant's offense level is determined to be 16 or greater, and the
+defendant complies with the requirements of Section 3E1.1, the government will make a
+motion requesting an additional one-level decrease pursuant to Section 3E1.1(b) of the
+Sentencing Guidelines, stating that the defendant has assisted authorities in the investigation
+or prosecution of his own misconduct by timely notifying authorities of his intention to enter
+a plea of guilty, thereby permitting the government to avoid preparing for trial and permitting
+the government and the Court to allocate their resources efficiently.
+Limitation on Joint Sentencing Recommendations: The defendant understands
+and agrees that the United States will not be required to make the motion and sentencing
+recommendation set forth in paragraph (8) if the defendant: (a) fails or refuses to make a full,
+accurate and complete disclosure to the Probation Office of the circumstances surrounding
+the relevant offense conduct; (b) is found to have misrepresented facts to the government
+prior to entering this plea agreement; (c) commits any misconduct after entering into this plea
+agreement, including but not limited to committing a state or federal offense, violating any
+term of release, or making false statements or misrepresentations to any governmental entity
+
+
+
+or official; or (d) fails to abide by the terms of the side agreement between the defendant and
+this Office.
+10.
+Factual Proffer: The defendant, his counsel, and the United States further agree
+that, had this case proceeded to trial, the United States would have introduced the following
+evidence, which is sufficient to support a plea of guilty and proves beyond a reasonable doubt
+that the defendant is guilty of the charge contained in the Information.
+The defendant was formerly employed as a property manager by Jeffrey
+Epstein ("Epstein"), and lived and worked at Epstein's residence in Palm Beach, Florida, in
+the Southern District of Florida, in 2004 and 2005.
+b.
+In 2006, the defendant was interviewed by members of the Town of
+Palm Beach Police Department regarding allegations of illicit sexual conduct between Epstein
+and several minor females. On January 18, 2007, Special Agents of the Federal Bureau of
+Investigation also interviewed the defendant in connection with a federal grand jury
+investigation of Epstein's criminal activity. The defendant was asked by law enforcement
+to produce any information or evidence in his possession related to Epstein's criminal
+activity. The defendant also was provided with contact information for FBI Special Agents
+and was asked to contact them if he remembered or discovered any further information.
+c.
+In July and August 2009, the defendant was subpoenaed to appear for
+deposition in connection with several civil lawsuits filed against Epstein by minor female
+victims of his criminal conduct. The subpoenas called for the defendant to appear and
+produce documents related to Epstein. The defendant appeared for deposition but did not
+
+
+
+produce any documents.
+Beginning in August 2009, after the conclusion of the second deposition,
+the defendant contacted a cooperating witness (CW) and informed the CW that he had
+additional information that he had not previously disclosed to any law enforcement agency
+or any of the civil attorneys, including lists of "hundreds" of additional victims and their
+telephone numbers.
+The defendant agreed to turn this information over to the CW in
+exchange for $50,000. The CW tried to convince the defendant to turn over the material
+voluntarily, but the defendant refused. The CW then approached law enforcement. During
+a consensually monitored telephone call on October 28, 2009, the CW told the defendant that
+he would be contacted by an associate of the CW regarding the purchase of the material. The
+"associate" was, in fact, an undercover Special Agent of the Federal Bureau of Investigation
+("UCE").
+e.
+On October 29, 2009, the UCE contacted the defendant via telephone.
+The defendant again explained that he would only turn over the information in exchange for
+monetary compensation. During the conversation, the defendant admitted that he knew that
+the information was relevant to the FBI's criminal investigation and was called for by the
+investigation. The defendant explained that he had not turned over the information to the FBI
+because: (1) it was his "property" and he should be compensated for it; and (2) he was afraid
+that Epstein would make him "disappear" or otherwise harm him, and the information was
+his "insurance policy."
+f.
+On November 3, 2009, the defendant met with the UCE ata
+
+
+
+predetermined location. During the meeting, the defendant produced a small bound book and
+several sheets of legal pad paper containing hand-written notes. The defendant discussed in
+detail the information contained within the book, which he admitted removing from Epstein's
+home without Epstein's permission, and identified important information to the UCE. In
+addition, the defendant admitted that he had previously lied to the FBI during the course of
+the federal criminal investigation of Epstein.
+The defendant asked the UCE about the
+$50,000.00, took possession of the money, and began counting it. The defendant was then
+detained for Obstruction of Official Proceedings, in violation of Title 18, United States Code,
+Section 1512(c), and questioned. After Miranda warnings were administered by agents, the
+defendant waived his rights and signed a written waiver of those rights. The defendant
+admitted that he had the documents and book in his possession and had never turned them
+over to local law enforcement or the FBI. In addition, the defendant advised he had
+witnessed naked girls whom he believed were minors at the pool area of Epstein's home,
+knew that his former employer was engaging in sexual contact with underage girls, and had
+viewed pornographic images of underage girls on computers in Epstein's home.
+g.
+The items that the defendant attempted to sell to the UCE were reviewed
+by an FBI Special Agent involved in the federal grand jury investigation of Epstein. As the
+defendant had described, the items contained information material to the Epstein
+investigation, including names of material witnesses and additional victims. The items also
+would have corroborated testimony of victims already identified. Had the items been
+produced in response to the inquiries of the state or federal authorities, or if the defendant had
+
+
+
+contacted the federal authorities at any time after his initial interview to produce these items,
+the materials would have been presented to the federal grand jury.
+11.
+No Promises or Representations Regarding Ultimate Sentence: The defendant
+is aware that the sentence has not yet been determined by the Court. The defendant also is
+aware that any estimate of the probable sentencing range or sentence that the defendant may
+receive, whether that estimate comes from the defendant's attorney, the government, or the
+probation office, is a prediction, not a promise, and is not binding on the government, the
+probation office, or the Court. The defendant understands further that any recommendation
+that the government makes to the Court as to sentencing, whether pursuant to this agreement
+or otherwise, is not binding on the Court and the Court may disregard the recommendation
+in its entirety. The defendant acknowledges that no one has promised or guaranteed what
+sentence the Court will impose. The defendant understands and acknowledges, as previously
+acknowledged in paragraph 5 above, that the defendant may not withdraw his plea based
+upon (a) the Court's decision not to accept a sentencing recommendation made by the
+defendant and/or the government, or (b) the fact that he received an incorrect estimate of the
+sentence that he would receive, whether that estimate came from his attorney, the United
+States, and/or the Probation Office.
+12.
+Voluntariness of Plea: The defendant agrees that he has entered into this Plea
+Agreement freely and voluntarily, and that no threats or promises, other than the promises
+contained in this written Plea Agreement, were made to induce the defendant to enter his plea
+of guilty.
+
+
+
+13.
+Consent to Forfeiture/Disposal/Destruction of Items: The defendant agrees to
+forfeit all interests in any items seized during the course of this investigation, whether the
+defendant currently owns, has previously owned, or over which the defendant currently, or
+has in the past, exercised control, directly or indirectly. Defendant agrees to hold the United
+States, its agents, and employees harmless from any claims whatsoever in connection with
+the forfeiture, seizure, or destruction of property covered by this agreement. The defendant
+agrees that this property may be destroyed or disposed of in accordance with the policies and
+procedures of the custodial agency. The defendant further agrees to waive all constitutional
+and statutory challenges in any manner (including direct appeal, habeas corpus, or any other
+means) to any destruction or disposal of property carried out in accordance with this Plea
+Agreement on any grounds, including that the forfeiture constitutes an excessive fine or
+punishment. Defendant acknowledges that all property covered by this agreement is subject
+to forfeiture as property involved in illegal conduct giving rise to forfeiture.
+14.
+Appeal Waiver: The defendant is aware that Title 18, United States Code,
+Section 3742 affords the defendant the right to appeal the sentence imposed in this case.
+Acknowledging this, in exchange for the undertakings made by the United States in this plea
+agreement, the defendant hereby waives all rights conferred by Section 3742 to appeal any
+sentence imposed, including any restitution order, or to appeal the manner in which the
+sentence was imposed, unless the sentence exceeds the maximum permitted by statute or is
+the result of an upward departure and/or a variance from the guideline range that the court
+establishes at sentencing. The defendant further understands that nothing in this agreement
+
+
+
+shall affect the government's right and/or duty to appeal as set forth in Title 18, United States
+Code, Section 3742(b). However, if the United States appeals the defendant's sentence
+pursuant to Section 3742(b), the defendant shall be released from the above waiver of
+appellate rights. By signing this agreement, the defendant acknowledges that he has
+discussed the appeal waiver set forth in this agreement with his attorney. The defendant
+further agrees, together with the United States, to request that the district court enter a
+specific finding that the defendant's waiver of his right to appeal the sentence to be imposed
+in this case was knowing and voluntary.
+15.
+Entire Agreement: This is the entire agreement and understanding between the
+United States and the defendant. There are no other agreements, promises, representations,
+or understandings unless contained in a side letter from the United States Attorney's Office
+executed by all parties and counsel prior to the change of plea.
+JEFFREY H. SLOMAN
+UNITED STATES ATTORNEY
+Date:
+By:
+ASSISTANT UNITED STATES ATTORNEY
+Date:
+By:
+ALFREDO RODRIGUEZ, DEFENDANT
+Date:
+By:
+DAVE LEE BRANNON, ESQ.
+ATTORNEY FOR DEFENDANT
+
diff --git a/vision-fixhub/ds9-unparsed-06/1d8aa1469c3f3e7a3543b48f9e38bc9915735030446c085a9914cd314e672255.receipt.json b/vision-fixhub/ds9-unparsed-06/1d8aa1469c3f3e7a3543b48f9e38bc9915735030446c085a9914cd314e672255.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..dc5a24d7fe1a4a5dbf652998acac0d3e73242cd1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1d8aa1469c3f3e7a3543b48f9e38bc9915735030446c085a9914cd314e672255.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -266,
+  "dataset": "marble-joined",
+  "doc_id": "1d8aa1469c3f3e7a3543b48f9e38bc9915735030446c085a9914cd314e672255",
+  "engine": "marble-apple-vision",
+  "event_count": 22,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "be012d09c7658d7e7cb1ebbbe8518aa416dac64a12cb846a5a8d987a8242325f",
+  "output_sha256": "4c9e372bf61bd0a8684a1ec749755050710d94c1d8ec6a5024bf5c3dcc695ba7",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1ddd046e2c868a5e250e9cd0089559632ed1e381c2508739127f4c9e4fc33895.md b/vision-fixhub/ds9-unparsed-06/1ddd046e2c868a5e250e9cd0089559632ed1e381c2508739127f4c9e4fc33895.md
new file mode 100644
index 0000000000000000000000000000000000000000..7404f0039e91384b74993154e6702848d3aa3fd5
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1ddd046e2c868a5e250e9cd0089559632ed1e381c2508739127f4c9e4fc33895.md
@@ -0,0 +1,10 @@
+From:
+Subject:
+Importance: Normal
+To: "BigJimLaw@aol.com" < BigJimLaw@aol.com>
+Date: Wed, 28 Feb 2007 16:27:41 +0000
+ti Jim - Your favorite AUSA contacting you about your favorite clientel hope all is well. I reviewed the proffer and I wi
+nake the request to Washington. I will be out of town next week, but hopefully will have an answer by the time I return
+Thank you.
+Assistant U.S. Attorney
+141 300 1019
diff --git a/vision-fixhub/ds9-unparsed-06/1ddd046e2c868a5e250e9cd0089559632ed1e381c2508739127f4c9e4fc33895.receipt.json b/vision-fixhub/ds9-unparsed-06/1ddd046e2c868a5e250e9cd0089559632ed1e381c2508739127f4c9e4fc33895.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c62fa7c54dd5d61faf55ba4956df48d259328dda
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1ddd046e2c868a5e250e9cd0089559632ed1e381c2508739127f4c9e4fc33895.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "1ddd046e2c868a5e250e9cd0089559632ed1e381c2508739127f4c9e4fc33895",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "bf44f063451c46c9428f5b591856f1a4fe752a538e6a6cc4fa903ce3d501aecf",
+  "output_sha256": "218a9a2d7ba43288cf3e11a28348bcc2a6c71f522fbbd7822dd2346b04ceb48b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1e7666d4dbc803a452324ab8def1a9ec1a1e7d849d6c23f9c763630ff31e32b2.md b/vision-fixhub/ds9-unparsed-06/1e7666d4dbc803a452324ab8def1a9ec1a1e7d849d6c23f9c763630ff31e32b2.md
new file mode 100644
index 0000000000000000000000000000000000000000..77f98e488227fb7c7ee8f143631fc229ff0f8aa4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1e7666d4dbc803a452324ab8def1a9ec1a1e7d849d6c23f9c763630ff31e32b2.md
@@ -0,0 +1,96 @@
+From:
+To:
+(USAFLS)" <
+- (USAFLS)" •
+(USAFLS)" <
+Subject: RE: Telephone Conference re: Epstein & Jane Doe | Enited States
+Date: Thu, 01 Dec 2011 16:11:50 +0000
+Importance: Normal
+I will come on up.
+From:
+1. (USAFLS)
+Sent: Thursday, December 01, 2011 11:05 AM
+To: |
+(USAFLS); L
+(USAFLS)
+Subject: Re: Telephone Conference re: Epstein & Jane Doe I. Enited States
+Sounds fine.
+AUSA
+From:
+(USAFLS)
+Sent: Thursday, December 01, 2011 11:00 AM
+To:
+1. (USAFLS); |
+I (USAFLS)
+Subject: RE: Telephone Conference re: Epstein & Jane Doe I. Enited States
+Shall we confer briefly at 1:30 to make sure we're on the same page and then call him? Is there any reason why
+we need to make this a scheduled conference call including Edwards, or should we just initiate the call to
+Cassell and let him decide if he wants to postpone it to bring in Edwards?
+From:
+I. (USAFLS)
+I (USAFLS)
+Subject: RE: Telephone Conference re: Epstein & Jane Doe I. Enited States
+Yes, I think we need to call him. Do you want to try for 1:30 since we have the time already set aside?
+Assistant U.S. Attorney
+Fax
+From:
+(USAFLS)
+Sent: Thursday, December 01, 2011 10:15 AM
+To: l
+1. (USAFLS); L
+(USAFLS)
+
+
+(USAFLS)
+Subject: RE: Telephone Conference re: Epstein & Jane Doe |. Enited States
+I just received a call from
+assistant. T
+is canceling today's conference call; he is feeling a
+little under the weather and is not coming into the office today. She told me that he will call me tomorrow to
+reschedule. Sorry. Given that it is unlikely that we are going to have a substantive discussion with
+week, do you think we should reach out and call Cassell back before the week is over? I admit that thought is
+also making me feel a little bit under the weather.
+From:
+(USAFLS)
+Sent: Wednesday, November 30, 2011 7:35 PM
+To:
+(USAFLM)
+Cc:
+1. (USAFLS);
+I (USAFLS);.
+Subject: RE: Telephone Conference re: Epstein & Jane Doe I. Enited States
+(USAFLS)
+We're on for 1:30 tomorrow. I'll set things up for a conference call at that time and send out the call-in
+information.
+Thanks,
+From:
+(USAFLS)
+Sent: Tuesday, November 29, 2011 6:11 PM
+(USAFLM)
+Cc:
+(USAFLS); I
+(USAFLS);
+Subject: Telephone Conference re: Epstein & Jane Doe I. Enited States
+(USAFLS)
+Hi,
+I hope you had a great Thanksgiving.
+As we had previously discussed, I am contacting you to see if we can set up a telephone conference to address
+some of the outstanding matters that we need to discuss to complete the transfer of the criminal case to your
+district and meet our obligations under USAP 3-2.170.001. (I also left a message with your assistant earlier
+today.) Those matters include: the nature and scope of any charges/investigation that may potentially remain
+viable in the SDFL following the entry of the Non-Prosecution Agreement; the need to advise the FBI in
+connection with the agents' pending requests for grand jury subpoenas and their expressed intent to continue
+investigating allegations against Epstein, advice which in all likelihood will require informing the FBI agents
+about other USAOs that might be able to assist them in light of the grand jury evidence previously obtained;
+and the handling of the criminal case file.
+We (
+,, who was previously assigned to the criminal investigation; |
+, who is handling the
+CVRA litigation; and me) can make ourselves available to confer with you after 10:30 tomorrow morning,
+tomorrow afternoon, or Thursday morning. If those blocks of time do not work, please let us know and we can
+make other arrangements to accommodate your schedule.
+Thanks,
+
+
+United States Attorney's Office
+E-mail:
diff --git a/vision-fixhub/ds9-unparsed-06/1e7666d4dbc803a452324ab8def1a9ec1a1e7d849d6c23f9c763630ff31e32b2.receipt.json b/vision-fixhub/ds9-unparsed-06/1e7666d4dbc803a452324ab8def1a9ec1a1e7d849d6c23f9c763630ff31e32b2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e7e676c3538459a76249e91e2c4608c7970f1bbb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1e7666d4dbc803a452324ab8def1a9ec1a1e7d849d6c23f9c763630ff31e32b2.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "1e7666d4dbc803a452324ab8def1a9ec1a1e7d849d6c23f9c763630ff31e32b2",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "ac24fab2d8fdc2fff71ee688c9a6e8f5e87f43ea4a044564152694a016c1a3bb",
+  "output_sha256": "061cd8d9957371e9e7388f93b4baf0b09d47ea676e48473c511e165f63726686",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1f6af172de2e7603469dd31ff6c7d4bdad605648f2ce4c82e2acccb0e8903255.md b/vision-fixhub/ds9-unparsed-06/1f6af172de2e7603469dd31ff6c7d4bdad605648f2ce4c82e2acccb0e8903255.md
new file mode 100644
index 0000000000000000000000000000000000000000..ed9c37fd2e0921f9704860c72f80d99c26c6ae3d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1f6af172de2e7603469dd31ff6c7d4bdad605648f2ce4c82e2acccb0e8903255.md
@@ -0,0 +1,6161 @@
+Statements
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 1,2006
+THROUGH
+December 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 30,2006
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802-1348
+Pursuant to your previously issued instructions, Bear Stearns Securities Corp, provides duplicate monthly statements and/or transaction confirmations to the
+third parties listed on the cover page of this statement, If you wish to modify or cease distribution to any of the recipients indicated, please contact your
+Account Executive. This reminder notice will continue to be provided to you on your quarterly statements.
+Third Party
+EPSTEIN INTERESTS
+A/C JEFFREY EPSTEIN
+ATIN HARRY BELLER
+457 MADISON AVE 4TH FLR
+NEW YORK NY 10022
+027
+12/30/06:09:23 001
+
+
+INVESTMENT PROFESSIONAL
+ZICHERMAN.IRA
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .........
+.....
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ..........................................
+Your Messages
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 1, 2006
+THROUGH
+December 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 30,2006
+3
+6
+6
+8
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802-1348
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+4,667,973
+5,051,800
+$9,719,773
+10,347,987
+-628,214
+or sel apen sers onese for your other ponding buy
+Market Value of Your Portfolio
+Cash & Equivalent
+Equities
+$5,051,800
+$5.690.854
+$4,667,973
+$4,657,133
+......
+Current market value
+Last statement's market value
+If any information regarding
+2006interest, dividends,
+miscellaneous income, gross
+proceeds or original issue
+discount is required to be
+reported to the IRS for this
+account, a Consolidated Form
+1099will be mailed to you by
+January 31,2007or a 10429
+py March 15,2007
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859
+027
+SIP The surren s four or ratanal purposes rear die Set revere date for portant iformation.
+12/30/06.09:23 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+12/30/06 09:23 001|
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Funds Deposited
+Dividends/Interest
+Amount Credited
+Money Fund
+Funds Withdrawn
+-.-..
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+4,026,934.53
+3,311,309.87
+22,702.25
+$7,360,946.65
+-3,360,946.65
+-4,000,000.00
+5-7,360,946.65
+$0.00
+Income Summary
+THIS PERIOD
+Dividends
+49,636.78
+Total
+.$49.636.78
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+12/30/06 09:23 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 1, 2006
+THROUGH
+December 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 30, 2006
+YEAR TO DATE
+322,345.81
+......
+$322,345.81.
+5,051,800
+4,667,973
+$9,719,773
+....
+Your Portfolio
+Allocation
+Cash & Equivalent
+52%
+Equities
+48%
+Unshaded portions denole debi balance and'or short
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 1, 2006
+THROUGH
+December 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 30,2006
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST, 30 DAY AVG YIELD 5.1700%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+QUANTITY
+5,051,800.21
+FRICE
+1.0000
+MARKET
+VALUE
+5,051,800
+ESTIMATED
+CURRENT
+ANNUAL INCOME
+YELD IN
+257,642
+5.1000
+$5,051,800
+$257,642
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department. The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+correspond directly to the underlying rating system used by each provider or BSC), The ratings information contained herein is for informational purposes only and is not intended
+to provide tax, legal, or investment advice. Bear Stears is neither soliciting any action based on such information, nor endorsing any recommendation or opinion expressed by
+any independent, third-party research provider. The symbol indicates that continuing coverage of the subject company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost. Customers can access this research
+FELCOR LODGING TRUST INC
+••••••//•/•••••••••••••••••••••///••••
+GLIMCHER REALTY TRUST-SBI
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+SYMBOL/CUSIP
+FCH
+GRT
+HRP
+HPT
+CASH
+QUANTITY
+2,000
+.......
+CASH
+2,000
+CASH
+10,000
+CASH
+2,000
+PRICE
+21.8400
+.... ••!!
+26.7100
+12.3500
+47.5300
+MARKET
+VALUE
+43,680
+53,420
+123,500
+95,060
+ESTIMATE
+CURRENT
+NNUAL INCOM
+YIELD (%
+2,000
+4.5788
+•••••••••••••••••••••••••••••••••••-•••••••.
+3,846
+7.1996
+8,400
+6.8016
+5,920
+6.2276
+027
+1230/06.0923 001
+
+
+5 of a
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+JOHNSON& JOHNSON
+CRATING STOCK SECTOR M
+ED DAVIS RESEARCH RATIN
+KIMCO REALTY CORP
+SIMBCLCUSIP
+JNJ
+CASH
+KIM
+CASH
+WTS LUCENT TECHNOLOGIES INC
+EXP 12/10/2007
+NAYARIT GOLD INC
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+SIRIUS SATELLITE RADIO ING
+LUTHW
+NYRTF
+PEI
+CASH
+CASH
+CASH
+APT
+CASH
+SIRI
+CASH
+Total Equities& Options
+TOTAL EQUITIES
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+QUANTITY
+57,800
+98
+235
+19
+1,794
+12,000
+1,000
+027
+PRICE
+66.0200
+44.9500
+0.3100
+0.6010
+39.3800
+38.1400
+3.5400
+MARKET
+VALLE
+3,815,956
+4,405
+73
+11
+70,648
+457,680
+3,540
+$4,667,973
+$4,667,973
+$390,219
+$9,719,773
+ESTIMATED
+ANNUAL INCOME
+86,700
+141
+4,090
+21,480
+$132,577
+$132,577
+12/30/06:09:23 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 1, 2006
+THROUGH
+December 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+November 30,2006
+YELD (S
+2.2720
+3.2009
+5.7893
+4.6932
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of 8
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+12/07/06
+TRANSACTION
+FND WIRED
+12/15/06
+FUNDS REC
+1218/06
+FND WIRED
+12/19/06
+FND WIRED
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MODAY
+12/01/06
+TRANSACTION
+....
+12/01/06
+DIVIDEND
+12/01/06
+REINVEST
+1207/06
+1212/06
+BOUGHT
+WIRED TO
+FNDS WIRED TO CITIBANK FROM
+COMPASS BANK
+NIRED T
+HEREASE BENS NA
+WIRED TO
+IPNOBTEEDERLASE BADE NA
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+MONTHLY DIVIDEND
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+DIVIDEND REINVEST
+"DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+*DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+027
+DEBIT AMOUNT
+....
+2,000,000.00
+$-4,000,000.00
+SYMBOUCUSIP
+XXOIa
+DICXX
+DICXX
+DICXX
+CREDIT AMOUNT
+3,311,309.87
+......
+$3,311,309.87
+QUANTITY
+5,690,853.56
+26,934.53
+1,000,000
+21,679.67
+12/30/06:09:23 001
+PRICE
+1.0000
+1.0000
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 1,2006
+THROUGH
+December 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 30, 2006
+DEBIT AMOUNT
+CREDIT AMOUNT
+26.934.53
+26,934.53
+21,679.67
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+7 of a
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+TRANSACTION
+12/15/06
+BOUGHT
+12/15/06
+BOUGHT
+1218/06
+"SOLD
+12/19/06
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+ASTION SHAGEMENICA
+ASTUTIONA SHAESGEMEVI CLA
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+12/29/06
+TOTAL
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+12/04/06
+212/0
+1215/06
+GLENBOROUGH REALTY TRUST ING
+ABBIE DIN PIMNTS.002336
+REC 112806 PAY 12/1206
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+REC 12/01/06 PAY 12/15/06
+SYMBOUCUSIP
+37803P105
+JNJ
+PEI
+TOTAL
+027
+SYMBOUCUSIP
+DICXX
+DICXX
+DICXX
+DICXX
+QUANTITY
+008'29
+1,794
+QUANTITY
+1,022.58
+3,311,309.87
+-1,000,000
+-2,000,000
+5,051,800.21
+PRICE
+1.0000
+1.0000
+1.0000
+1.0000
+RATE (S)
+SLE!
+0.5700
+DEBIT AMOUNT
+12/30/06:09:23 001
+LEARED THROUGH T
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 1,2006
+THROUGH
+December 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+November 30,2006
+DEBIT AMOUNT
+1,022.58
+CREDIT AMOUNT
+3,311,309.87
+2,000,000.00
+$-3,360,946.65
+$4,026,934.53
+CREDIT AMOUNT
+4.67
+21,675.00
+1,022.58
+$22,702.25
+
+
+8 of a
+Bear, Stears & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+Your messages
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 1, 2006
+THROUGH
+December 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+November 30,2006
+As part of the National Association of Securities Dealer's (NASD) Investor
+STOP
+****** End of Statement******
+027
+12/30/06 09:23 001|
+
+
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ........
+.....
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ..........................................
+Your Messages
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD November 1, 2006
+THROUGH
+November 30, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 31,2006
+3
+6
+6
+9
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802-1348
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+4,657,133
+5,690,854
+$10,347,987
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+12,331,625
+-1,983,638
+or sel apen sers onese for your other pending buy
+Cash & Equivalent
+Equities
+Market Value of Your Portfolio
+$4.657.133
+$4.762,060
+55,690,854l 57.569,565
+......
+....
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+027
+SP The suremen s four or ratanal purposes rearde Set revere date for portant iformation.
+12/01/06.05:56 001
+
+
+2 of 9
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+12/01/06 05:56 001|
+
+
+3 or 9
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Securities Sold
+Money Fund
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Money Fund
+Funds Withdrawn
+Amount Debited
+Closing Balance
+THIS PERICO
+$0.00
+52,000.00
+2,039,075.39
+4,043.11
+26,170.34
+$2,121,288.84
+-121,288.84
+-2,000,000.00
+$-2.121.288.84
+$0.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+43,118.50
+543.118.50
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+12/01/06 05:56 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD November 1, 2006
+THROUGH
+November 30, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 31,2006
+YEAR TO DATE
+272,709.03
+....
+$272.709.03.
+5,690,854
+4,657,133
+$10,347,987
+... . .
+..........
+Your Portfolio
+Allocation
+Equities
+45%
+Cash & Equivalent:
+55%
+Unshaded portions denole debi balance and'or short
+
+
+4 of g
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD November 1, 2006
+THROUGH
+November 30, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 31,2006
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST, 30 DAY AVG YIELD 5,1900%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+QUANTITY
+5,690,853.56
+FRICE
+1.0000
+MARKET
+VALUE
+5,690,854
+$5,690,854
+ESTIMATED
+CURRENT
+ANNUAL INCOME
+YELD IN
+301,615
+5.3000
+$301,615
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department. The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+correspond directly to the underlying rating system used by each provider or BSC), The ratings information contained herein is for informational purposes only and is not intended
+to provide tax, legal, or investment advice. Bear Stearns is neither soliciting any action based on such information, nor endorsing any recommendation or opinion expressed by
+any independent, third-party research provider. The symbol indicates that continuing coverage of the subject company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost. Customers can access this research
+FELCOR LODGING TRUST INC
+••••••//•/•••••••••••••••••••••///••••
+GLIMCHER REALTY TRUST-SBI
+HRPT PROPERTIES TR-SBI
+HOSPITALITY PROPERTIES TRUST
+SYMBOL/CUSIP
+FCH
+GRT
+HRP
+HPT
+CASH
+QUANTITY
+2,000
+.......
+CASH
+2,000
+CASH
+10,000
+CASH
+2,000
+PRICE
+22.0100
+.!!!
+26.9700
+2.5700
+50.1900
+MARKET
+VALUE
+44,020
+53,940
+125,700
+100,380
+ESTIMATEC
+CURREN
+ANNUAL INCOME
+YIELD (%
+1,600
+3.6347
+...............
+3,846
+7.1301
+8,400
+6.6826
+5,920
+5.8976
+027
+1201/06.05:56 001
+
+
+5 or g
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+JOHNSON& JOHNSON
+CRATING STOCK SECTOR M
+ED DAVIS RESEARCH RATIN
+KIMCO REALTY CORP
+SIMBCLCUSIP
+JNJ
+CASH
+KIM
+CASH
+WTS LUCENT TECHNOLOGIES INC
+EXP 12/10/2007
+NAYARIT GOLD INC
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+LUTHW
+NYRTF
+PEI
+CASH
+CASH
+CASH
+APT
+CASH
+SIRIUS SATELLITE RADIO INC
+SIRI
+CASH
+Total Equities& Options
+TOTAL EQUITIES
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+QUANTITY
+57,800
+98
+235
+19
+1,794
+12,000
+1,000
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD November 1, 2006
+THROUGH
+November 30, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 31,2006
+PRICE
+65.9100
+46.3800
+0.2250
+0.7450
+39.5000
+36.9800
+4.2600
+MARKET
+VALLE
+3,809,598
+4,545
+53
+14
+70,863
+443,760
+4,260
+$4,657,133
+$4,657,133
+$433,792
+$10,347,987
+ESTIMATED
+ANNUAL INCOME
+86,700
+141
+YIELD (%)
+2.2758
+3.1023
+4,090
+....................
+21,480
+4.8405
+$132,177
+$132,177
+12/01/06.05:56 001
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of g
+Transaction Detail
+INVESTMENT ACTIVITY
+SATEMENT TREE
+11/01/06
+TRANSACTION
+EXCHANGE
+11/01/06
+MERGER
+11/30/06
+MERGER
+DESCRPTION
+KIMCO REALTY CORP
+580,075225 Me i
+PAN PACIFIC RETAIL PROPERTIES
+580.0/56.2253 KINCO
+GLENBOROUGH REALTY TRUST INC
+CASH MERGER @ $26 P/S
+TOTAL
+DEPOSITS AND WITHDRAWALS
+DATE
+11/06/06
+TRANSACTION
+FND WIRED
+1147/06
+END WIRED
+LENDS WIRED TO
+MENWETERIAEASE BANK, NA
+.........
+ENDSWIRED TO
+MPMOEGAMRHASE BANK NA
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MODAY
+11/01/06
+TRANSACTION
+DESCAIPTION
+OPENINGBALANCE
+027
+SYMBOLGUSIP
+KIM
+69806L104
+GLB
+DEBIT AMOLNT
+$2,000,000.00
+SYMBOUCUSIP
+QUANTITY
+98
+-436
+-2,000
+CREDIT AMOUNT
+QUANTITY
+7,569,564.72
+12/01/06.05:56 001
+PRICE
+PRICE
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD November 1, 2006
+THROUGH
+November 30, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+October 31, 2006
+DEBIT AMOUNT
+CREDIT AMOUNT
+.........
+.. . .
+2,000.0
+$52,000.00
+DEBIT AMOUNT
+CREDIT AMOUNT
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+7 of g
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+TRANSACTION
+11/01/06
+DIVIDEND
+11/01/06
+REINVEST
+DESCAIPTION
+DREYFUS CASH MANAGEMENT-CL A
+MONTHLY DID ENORES
+*DREYFUS CASH MANAGEMENT-CLA
+11/02/06 BOUGHT
+11/06/06
+11/1606
+BOUGHT
+1117/06
+11/22/06
+BOUGHT
+
+"BOUGHT
+•••••••••••••••••••••••••••••••••
+11/30/06
+TOTAL
+STIONAL SHARESCEMENT-CL
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+•DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+"DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+•••••••••••••••••••••••••••••••••••••••••••
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+DESCRUPTION
+11/01/06
+PAN PACIFIC RETAIL PROPERTIES
+DIDEND @3, 2365 PIS
+SYMBOUCUSIP
+69806L104
+027
+SYMBOUGUSIP
+DICXX
+XXOI
+DICXX
+DICXX
+DICXX
+DICXX
+DICXX
+DiCXX
+QUANTITY
+QUANTITY
+39,075.39
+26,273.45
+-1,000,000
+1,480
+1,000,000
+2,100
+52,360
+5,690,853.56
+PRICE
+1.0000
+1.0000
+1.0000
+1.0000
+1.0000
+1.0000
+RATE (5)
+DEBIT AMOUNT
+12/01/06.05:56 001
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD November 1, 2006
+THROUGH
+November 30, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 31,2006
+DEBIT AMOUNT
+CREDIT AMOUNT
+39,075.39
+39.075.39
+26,273.45
+1,480.00
+,000,000.00
+2,100.00
+52,360.00
+$-121,288.84
+$2,039,075.39
+CREDIT AMOUNT
+103.11
+
+
+8 of g
+Transaction Detail (continued)
+DIVIDENDS (continued)
+DATE
+11/16/06
+11/22006
+
+HOSPITALITY PROPERTIES TRUST
+SEC 10/16/06 PAY 11/16:06
+HAPT PROPERTIES TR-SBI
+REC 10/23/06 PAY 11/22/06
+HLENBOROUGH REALTY TRUST INC
+DIN PAYMENT § $, 18 PIS
+TOTAL
+MISCELLANEOUS
+DATE
+MO/DAY
+TRANSACTION
+11/01/06
+CASH-LIEU
+11/01/06
+- MERGER
+SYMBOUGUSIP
+HPT
+QUANTITY
+2,000
+10,000
+RATE (S)
+0.7400
+0.2100
+DEBIT AMOUNT
+KIMCO REALTY CORP
+$60.00P/S&,2253 KIMCO
+*PAN PACIFIC RETAIL PROPERTIES
+TO S
+$60.00P/S&.2253 KIMOO
+DEBIT AMOUNT
+TOTAL
+CRECIT AMOUNT
+10.34
+26,160.00
+$26,170.34
+027
+12/01/0605:56 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD November 1, 2006
+THROUGH
+November 30, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 31,2006
+CREDIT AMOUNT
+1,480.00
+,100.0
+360.00
+$4,043.11
+
+
+9 of g
+Bear, Steams & Co. Inc
+383 Madison Avenue
+New York, New York 10179
+Your messages
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD November 1, 2006
+THROUGH
+November 30, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+October 31,2006
+Bear, Stearns Securities Corp, would like to inform you that the Securities
+orporation's (the "OCC") proposal to reduce the automatic exercise threshold
+or listed equity options. Please be advised that this change is now in effect
+in-the-money by $.06 when it expires, the position will be automatically
+exercised at expiration unless we have received instructions to the contrary.
+Please note that this procedure only applies to options cleared by the OCC
+and regulated by the SEC, This does not apply to options on debt, foreign
+currency, and futures among others, It also does not apply to FLEX options or
+options traded on foreign exchanges or over-the-counter,
+If you should have any questions regarding this matter, please contact your
+Investment Professional.
+STOP
+.*...
+End of Statement******
+027
+12/01/0605:58 001
+
+
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .......
+Your Portfolio Holdings
+Transaction Detail ..................................
+Fund Activity ...................
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 30, 2006
+THROUGH
+October 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 29,2006
+3
+4
+6
+6
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802-1348
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+4,762,060
+7,569,565
+$12,331,625
+15,116,000
+-2,784,375
+or sel apen sers onese for your other ponding buy
+Market Value of Your Portfolio
+$7.569.565
+Cash & Equivalent
+Equities
+2 $10.513.444
+$4.762,060
+$4.602,556
+......
+....
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+027
+SIP The suremen s foul ratanal purger red de Set revere dise for portant iformation.
+11/01/06.05:26 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+11/01/06 05:26 001|
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Funds Withdrawn
+mount Debite
+Closing Balance
+THIS PERIOD
+$0.00
+3,048,560.41
+7,560.64
+$3,056,121.05
+-56,121.05
+-3,000,000.00
+3,056,121.0
+$0.00
+Income Summary
+THIS PERIOD
+Dividends
+56,121.05
+Total
+$56,121.05
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 30, 2006
+THROUGH
+October 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 29,2006
+YEAR TO DATE
+229,590.53
+.....
+....
+$229,590.53.
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+7,569,565
+4,762,060
+$12,331,625
+......
+Your Portfolio
+Allocation
+Equities
+38%
+Cash & Equivalent
+62%
+Unshaded portions denole debi balance and'or short
+027
+11/01/0605:26 001
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 30, 2006
+THROUGH
+October 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 29, 2006
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST, 30 DAY AVG YIELD 5,1900%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+QUANTITY
+7,569,564.72
+FRICE
+1.0000
+MARKET
+VALUE
+7,569,565
+$7,569,565
+ESTIMATED
+ANNUAL INCOME
+386,048
+CURRENT
+YELD IN
+5.1000
+$386,048
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department. The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+ESPERATE
+where such research is available. The various providers use different ratings systems and have normalized them as follows: B = Buy: H = Hold; S = Sell (this may not always
+correspond directly to the underlying rating system used by each provider or BSC), The ratings information contained herein is for informational purposes only and is not intended
+to provide tax, legal, or investment advice. Bear Stearns is neither soliciting any action based on such information, nor endorsing any recommendation or opinion expressed by
+any independent, third-party research provider. The symbol indicates that continuing coverage of the subject company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost, Customers can access this research
+SYMBOL/CUSIP
+QUANTITY
+MARKET
+PRICE
+VALTE
+FELCOR LODGING TRUST INC
+FCH
+CASH
+2,000
+20.7600
+41,520
+GLENBOROUGH REALTY TRUST INC
+GLB
+SO RATING: STOCK P/SECTOR MW
+2,000
+25.9800
+51,960
+CURREN
+YIELD (%
+1,600
+3.8536
+........
+2,200
+4.2340
+NED DAVIS RESEARCH RATING: H
+GLIMCHER REALTY TRUST-SBI
+HAPT PROPERTIES TR-SBI
+GRT
+HRP
+CASH
+CASH
+2,000
+10,000
+25.7600
+11.9000
+51,520
+119,000
+3,846
+8,400
+7.4651
+7.0588
+027
+11/01/06.0526 001
+
+
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+HOSPITALITY PROPERTIES TRUST
+SBI
+....
+JOHNSON& JOHNSON
+SYMBOLCUSIP
+HPT
+CASH
+JNJ
+CASH
+WTS LUCENT TECHNOLOGIES INC
+EXP 12/10/2007
+NAYARIT GOLD INC
+PAN PACIFIC RETAIL PROPERTIES
+LUTHW
+CASH
+NYATF
+PNP
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+SIRIUS SATELLITE RADIO INC
+BSC RATING: STOCK O/SECTOR MW
+ATLANTIS RESEARCH RATING: B
+Total Equities& Options
+TOTAL EQUITIES
+PEI
+APT
+CASH
+CASH
+CASH
+CASH
+SIRI
+CASH
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+QUANTITY
+2,000
+57,800
+235
+19
+436
+1,794
+12,000
+1,000
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 30, 2006
+THROUGH
+October 31,2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+September 29,2006
+PRICE
+48.4600
+67.4000
+0.1750
+0.5350
+69.9500
+43.1000
+32.8100
+3.8300
+MARKET
+VALLE
+96,920
+3,895,720
+41
+30,498
+77,321
+393,720
+3,830
+$4,762,060
+$4,762,060
+$520,696
+$12,331,625
+ESTIMATED
+ANNUAL INCOME
+5,920
+CURRENT
+YIELD (%)
+6.1081
+... . . .
+86,700
+2.2255
+412
+060'г
+21,480
+$134,648
+$134,648
+1.3509
+5.2896
+5.4557
+11/01/06:05:26 001
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of 7
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+10/04/06
+TRANSACTION
+FND WIRED
+10/12/06
+* FND WIRED
+10/27/06
+END WIRED
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MODAY
+09/30/06
+TRANSACTION
+10/02/06
+BOUGHT
+... ...
+10/02/06
+DIVIDEND
+10/02/06
+REINVEST
+10/04/06
+
+WIRED TO
+HEN BEEN ALASE BANS NA
+WIRED TO
+HEMORGAN CHASE BANK NA
+WIRED TO
+PENNA CASE BANE NA
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+REYFUS CASH MANAGEMENT-CL
+MONTHLY DIVEN ES
+'''DREYFUS CASH MANAGEMENT-CLA
+NSTITUTIONAL SHARES
+DIVIDEND REINVES
+DREYFUS CASH MANAGEMENT CLA
+INSTITUTIONAL SHARES
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+DEBIT AMOUNT
+$-3,000,000.00
+SYMBOUCUSIP
+DICXX
+CREDIT AMOUNT
+*.....
+__...
+DICXX
+DICXX
+027
+QUANTITY
+10,513,443.67
+5,649.04
+48,560.41
+-1,000,000
+1,000,000
+11/01/06:05:26 001
+PRICE
+1.0000*
+1.0000
+1.0000
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 30, 2006
+THROUGH
+October 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+September 29,2006
+DEBIT AMOUNT
+5,649.04
+48,560.40
+CREDIT AMOUNT
+48,560.41
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+7 of 7
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+TRANSACTION
+10/16/06
+BOUGHT
+10/27/06 SOLD
+1031/06
+"BOUGHT
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+ASTUTIONA SHAESGEMEVI CLA
+10/31/06
+TOTAL
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+10/02/06
+
+10/16/06
+10/16/06
+10/31/06
+TOTAL
+PAN PACIFIC RETAIL PROPERTIES
+C 09/19,06 PAY 0929106
+RAMCO GERSHENSON PROPERTIES
+RUST-MD SI
+EC 09/20/06 PAY 10/02/0
+LENBOROUGH REALTY TRUST IN
+EC 10/01/06 PAY 10/16/0
+GLIMCHER REALTY TRUST-SBI
+REC 09/2906 PAY 10/16/06
+FELCOR LODGING TRUST INC
+REC 10/16/06 PAY 10/31/06
+SYMBOUCUSIP
+PNP
+APT
+GLB
+GRT
+FCH
+SYMBOUCUSIP
+DICXX
+DICXX
+DICXX
+QUANTITY
+436
+12,000
+2,000
+2,000
+2,000
+027
+QUANTITY
+1,511.60
+-1,000,000
+400
+7,569,564.72
+PRICE
+1.0000
+1.0000*
+L.0000
+RATE (S)
+0.6400
+0.4475
+0.2750
+0.4808
+0.2000
+DEBIT AMOUNT
+11/01/06:05:26 001
+CLEARED THROUGH IT:
+"HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 30, 2006
+THROUGH
+October 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+September 29,2006
+DEBIT AMOUNT
+1,511.60
+CREDIT AMOUNT
+400.00
+$-56,121.05
+$3,048,560.41
+CREDIT AMOUNT
+279.04
+5,370.00
+550.00
+961.60
+400.00
+$7,560.64
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 1, 2006
+THROUGH
+September 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 31, 2006
+JEFFREY EPSTEIN
+CIO FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802-1348
+Pursuant to your previously issued instructions, Bear Stearns Securities Corp, provides duplicate monthly statements and/or transaction confirmations to the
+third parties listed on the cover page of this statement, If you wish to modify or cease distribution to any of the recipients indicated, please contact your
+Account Executive. This reminder notice will continue to be provided to you on your quarterly statements.
+Third Party
+EPSTEIN INTERESTS
+A/C JEFFREY EPSTEIN
+ATIN HARRY BELLER
+457 MADISON AVE 4TH FLR
+NEW YORK NY 10022
+027
+09/30/0608:39 001
+
+
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ......
+.....
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ..........................................
+Your Messages
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 1, 2006
+THROUGH
+September 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 31, 2006
+3
+6
+6
+8
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802-1348
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+4,602,556
+10,513,444
+15.116.000
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+17,035,517
+-1,919,517
+or sel apen sers onese for your other pending buy
+Market Value of Your Portfolio
+Cash & Equivalent
+Equities
+$10.513.444
+5 $12,451,687
+......
+......
+$4,602,556
+$4,583,830
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859
+027
+SIP The suremen s four erratanal purposes rearde Set revere date for portant iformation.
+
+
+2 of 10
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+09/30/06 08:39 001|
+
+
+3 of 10
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 1, 2006
+THROUGH
+September 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 31,2006
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Funds Withdrawn
+mount Debite
+Closing Balance
+THIS PERIOD
+$0.00
+2,039,059.05
+22,697.58
+$2,061,756.63
+-61,756.63
+-2,000,000.00
+$-2,061,756.63
+$0.00
+Income Summary
+THIS PERIOD
+Dividends
+61,756.63
+Total
+$61,756.63
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+YEAR TO DATE
+173,469.48
+.......
+173,469.4
+....................
+10,513,444
+4,602,556
+$15,116,000
+......
+Your Portfolio
+Allocation
+Equities
+30%
+Cash & Equivalent
+70%
+Unshaded portions denole debt balance and'or short
+from the absolute market value of your portfolio.
+027
+
+
+4 of 10
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 1, 2006
+THROUGH
+September 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 31, 2006
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST, 30 DAY AVG YIELD 5,2300%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+QUANTITY
+10,513,443.67
+FRICE
+1.0000
+MARKET
+VALUE
+10,513,444
+ESTIMATED
+CURRENT
+ANNUAL INCOME
+YELD IN
+557,213
+5.3000
+$10,513,444
+$557,213
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department. The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+ESPERATE
+correspond directly to the underlying rating system used by each provider or BSC), The ratings information contained herein is for informational purposes only and is not intended
+to provide tax, legal, or investment advice. Bear Stearns is neither soliciting any action based on such information, nor endorsing any recommendation or opinion expressed by
+any independent, third-party research provider. The symbol indicates that continuing coverage of the subject company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost, Customers can access this research
+SYMBOL/CUSIP
+QUANTITY
+MARKET
+PRICE
+VALLE
+ANIMAL MOONE
+CURRENT
+YIELD (%)
+FELCOR LODGING TRUST INC
+FCH
+•••••••••••••••••••••••••••••••••••••••••••••••
+CASH
+2,000
+20.0500
+40,100
+1,600
+3.9900
+.................
+GLENBOROUGH REALTY TRUST INC
+GLB
+2,000
+25.7300
+51,460
+2,200
+4.2752
+BSC RATING: STOCK P/SECTOR MW
+NED DAVIS RESEARCH RATING: H
+GLIMCHER REALTY TRUST-SBI
+HAPT PROPERTIES TR-SBI
+GRT
+HRP
+CASH
+CASH
+2,000
+10,000
+24.7800
+11.9500
+49,560
+119,500
+3,846
+8,400
+7.7603
+7.0293
+027
+09300608:39 001
+
+
+5 of 10
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+HOSPITALITY PROPERTIES TRUST
+SBI
+....
+JOHNSON& JOHNSON
+SYMBOLCUSIP
+HPT
+CASH
+JNJ
+CASH
+WTS LUCENT TECHNOLOGIES INC
+EXP 12/10/2007
+NAYARIT GOLD INC
+PAN PACIFIC RETAIL PROPERTIES
+LUTHW
+CASH
+NYATF
+PNP
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+SIRIUS SATELLITE RADIO INC
+BSC RATING: STOCK O/SECTOR MW
+ATLANTIS RESEARCH RATING: B
+Total Equities& Options
+TOTAL EQUITIES
+PEI
+APT
+CASH
+.. . .
+CASH
+CASH
+CASH
+SIRI
+CASH
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+QUANTITY
+2,000
+57,800
+235
+19
+436
+1,794
+12,000
+1,000
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 1, 2006
+THROUGH
+September 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 31,2006
+PRICE
+47.2000
+64.9400
+0.1900
+0.5810
+... ..
+69.4200
+42.5700
+31.9500
+3.9100
+MARKET
+VALLE
+94,400
+3,753,532
+45
+30,267
+76,371
+383,400
+3,910
+$4,602,556
+$4,602,556
+$692,565
+$15,116,000
+ESTIMATED
+ANNUAL INCOME
+5,920
+CURRENT
+YIELD (%)
+6.2712
+....
+86,700
+2.3098
+1,116
+4,090
+21,480
+$135,352
+$135,352
+3.6872
+5.3554
+5.6025
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of 10
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+09/07/06
+TRANSACTION
+FND WIRED
+09/20/06 END WIRED
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+09/01/06
+TRANSACTION
+09/01/06
+DIVIDEND
+09/01/06
+REINVEST
+D9/07/01
+19/12/0
+09/15/06
+09/20106
+BOUGHT
+BOUGHT
+WIRED TO
+TENORER REASE BANK NA
+WIRED TO
+IPMORGAN CHASE BANK NA
+BRRER
+OPENINGBALANCE
+•DREYFUS CASH MANAGEMENT-CLA
+MONTHLY DIVIDENDRES
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARE:
+DIVIDEND REINVEST
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+*DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+.. . .
+REYFUS CASH MANAGEMENT-CL
+INSTITUTIONAL SHARES
+DEBIT AMOUNT
+1,000.000.00
+$-2,000,000.00
+SYMBOUCUSIP
+DiCXX
+DICXX
+DICXX
+DICXX
+DICXX
+DICXX
+CREDIT AMOUNT
+QUANTITY
+12,451,687.04
+39,059.05
+-1,000,000
+21,675
+T.022.58
+1,000,000
+PRICE
+1.0000
+1.0000
+1.0000
+1.0000
+027
+09130106.08:39 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 1, 2006
+THROUGH
+September 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 31, 2006
+DEBIT AMOUNT
+CAEDIT AMOUNT
+39,059.05
+39,059.05
+21,675.00
+1,022.58
+
+
+7 of 10
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MODAY
+09/29/06
+TOTAL
+TRANSACTION
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+09/12/06
+09/15/06
+JOHNSON& JOHNSON
+REC 08/2906 PAY 09/12/06
+"PENNSYLVANIA REAL ESTATE"
+INVESTMENT TRUST-SBI
+REC 09/01/06 PAY 09/15/06
+TOTAL
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+SYMBOUCUSIP
+SYMBOUGUSIP
+JNJ
+PEI
+QUANTITY
+57,800
+1,794
+027
+QUANTITY
+10,513,443.67
+PRICE
+RATE (S)
+0.3750
+0.5700
+DEBIT AMOUNT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 1, 2006
+THROUGH
+September 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+August 31, 2006
+DEBIT AMOUNT
+CREDIT AMOUNT
+$-61,756.63
+$2,039,059.05
+CREDIT AMOUNT
+21,675.00
+1.022.58
+$22,697.58
+
+
+8 of 10
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Your messages
+Revenue Sharing
+serving shaiti ain eat ra mutuai und pays out ny shown assets.
+fund's prospectus fee table. Rule 12b-1 fees and other expenses described in
+a fund's prospectus fee table increase a fund's expense ratio and decrease the
+fund's yield, Revenue sharing fees, on the other hand, are paid out of the
+assets of the fund affiliate and not from the fund's assets and, therefore, have
+no impact on a funds expense ratio or yield.
+With respect to money market funds, Bear Steams negotiates revenue sharing
+payments separately with each fund family and not all fund families pay the
+same amount or pay according to the same formula. These payments are
+calculated based on a percentage of the dollar value of the fund assets held by
+Bear Stearns in customer accounts, Bear Stearns receives up to 0,66% per
+ear of the average daily assets of fund shares carried in customers account
+t Bear Stears. Money market funds whose affiliates do not make revenu
+sharing payments to Bear Stearns are generally not offered or recommended
+by Bear Stearns to its customers,
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 1, 2006
+THROUGH
+September 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+August 31, 2006
+These money market funds may in some cases have higher yields than money
+market funds whose affiliates do make revenue sharing payments. There is,
+therefore, a potential conflict of interest in the form of an additional financial
+incentive to Bear Stearns for making available to customers money market
+funds whose affiliates enter into revenue sharing arrangements. In certain
+circumstances, a portion of these revenue sharing payments may be passed
+on as compensation to certain Private Client Services account executives.
+With respect to non-money market fund shares held in Bear Stearns
+accounts, Bear Steams may receive Rule 12b-1 fees and other compensation
+described in a fund's prospectus but does not receive revenue sharing
+payments, With respect to non-money market fund shares held by certain
+Private Client Services customers away from Bear Stears, Bear Stearns does
+receive revenue sharing payments in limited circumstances, A portion of these
+revenue sharing payments are passed on as compensation to the Private
+Client Services account executive designated by the customer. Bear Stearns
+does not believe that these revenue sharing arrangements involving such
+Private Client Services customers pose a conflict of interest with respect to
+customers whose accounts are held at Bear Stearns.
+The prospectus and statement of additional information of mutual funds
+available through Bear Steams may contain additional information regarding
+revenue sharing payments made by affiliates of the fund company.
+
+
+9 of 10
+Bear, Stears & Co. Inc
+383 Madison Avenu
+New York, New York 10179
+Bear, Stearns Securities Corp. Net Capital and Net Capital Requirements:
+At May 31, 2006 and July 31, 2006, the Company's net capital of
+A complete copy of the Bear, Stearns Securities Corp, Statement of Financial
+Condition is available on the web site www.bearstearns,com, Alternatively, to
+request a free printed copy please call - toll free 1-866-299-9331.
+027
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 1, 2006
+THROUGH
+September 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+August 31,2006
+Securities and other assets in your account are the firm's collateral for any
+margin loan made to you. If the securities and other assets in your account
+decline in value, so does the value of the collateral supporting your loan, and,
+as a result, the firm can take action, such as issue a margin call and/or sell
+securities or other assets in any of your accounts held with the member, in
+order to maintain the required equity in the account, It is important that you
+fully understand the risks involved in trading securities on margin, These risks
+include the following:
+- You can lose more funds than you deposit in the margin account.
+- The firm can force the sale of securities or other assets in your accounts).
+• The firm can sell your securities or other assets without contacting you.
+- You are not entitled to choose which securities or other assets in your
+accounts) are liquidated or sold to meet a margin call.
+- The firm can increase its "house" maintenance margin requirements at any
+time and is not required to provide you advance written notice.
+- You are not entitled to an extension of time on a margin call,
+
+
+10 of 10
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+This statement is provided to explain Bear, Stearns & Co. Inc.'s ("BSC")
+BSC routes a majority of orders for customer securities transactions to the
+receives no cash payment or other consideration for such order routing other
+than favorable executions or executions of limit orders at no additional charge.
+STOP
+****** End of Statement******
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD September 1, 2006
+THROUGH
+September 29, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+August 31, 2006
+Pursuant to SEC Rule 606, please note the following:
+Bear, Stearns & Co. Inc, will post its quarterly routing statistics at the following
+web link: http://www.bearsteams.com/. Click on Individual Investor, Click on
+Equities, Click on Order Routing Practices.
+Customers of Bear, Stearns & Co. Inc, may request information on any order
+executed within the prior six months from the time of the request, Specifically.
+you may request the identity of the venue to which the identified orders were
+routed for execution, whether the order was directed by you to that venue, and
+the time of the executions, if any, that resulted from such orders.
+
+
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .......
+Your Portfolio Holdings
+Transaction Detail ..................................
+Fund Activity ...................
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD August 1,2006
+THROUGH
+August 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 31, 2006
+3
+4
+6
+6
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802-1348
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+MONEY MARKET FUND BALANCE
+4,583,830
+12,451,687
+$17,035,517
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+9,084,654
+7,950,863
+or sel apen sers onese for your other ponding buy
+Cash & Equivalent
+Equities
+......
+Market Value of Your Portfolio
+$4,670,736
+$4,583,830
+$4,413,918
+Current market value
+Last statement's market value
+$12,451,687
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolect Center North, Brooklyn, N.Y. 11201-3859.
+027
+SIP The suremen s foul ratanal purger red de Set revere date for portant iformation.
+09/01/06.07:58 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+09/01/06 07:58 001|
+
+
+Bear, Stearns & Co. Ine.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD August 1,2006
+THROUGH
+August 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 31,2006
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Funds Deposited
+Dividends/Interest
+Amount Credited
+Money Fund
+Funds Withdrawn
+Amount Debited
+Net Cash Activity
+.. .
+Closing Balance.
+THIS PERICO
+$63,052.55
+5,025,467.24
+12,749,804.62
+3,580.00
+$17,778,851.86
+-12,841,904.41
+-5,000,000.00
+517.84.90441.
+-63,052.55
+$0.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+31,147.24
+531.14724
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+YEAR TO DATE
+111,712.85
+5111.712.85
+......
+12,451,687
+4,583,830
+$17.035,517
+Your Portfolio
+Allocation
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+63,052.55
+$63,052.55
+CLOSING
+0.00
+..... .
+$0.00
+Equities
+26%
+Cash & Equivalent
+74%
+Unshaded portions denole debit balance andor short
+from the absolute market value of your portfolio.
+027
+09/01/0607:58 001
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD August 1,2006
+THROUGH
+August 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 31, 2006
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST, 30 DAY AVG YIELD 5,2300%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+QUANTITY
+12,451,687.04
+FRICE
+1.0000
+MARKET
+VALUE
+12,451,687
+ESTIMATED
+ANNUAL INCOME
+659,939
+CURRENT
+YELD IN
+5.3000
+$12,451,687
+$659,939
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department. The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers use different ratings systems and have normalized them as follows: B = Buy: H = Hold; S = Sell (this may not always
+correspond directly to the underlying rating system used by each provider or BSC), The ratings information contained herein is for informational purposes only and is not intended
+to provide tax, legal, or investment advice. Bear Stearns is neither soliciting any action based on such information, nor endorsing any recommendation or opinion expressed by
+any independent, third-party research provider. The symbol indicates that continuing coverage of the subject company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost, Customers can access this research
+FELCOR LODGING TRUST INC
+GLENBOROUGH REALTY TRUST INC
+SO RATING: STOCK P/SECTOR MW
+NED DAVIS RESEARCH RATING: H
+GLIMCHER REALTY TRUST-SBI
+HAPT PROPERTIES TR-SBI
+SYMBOL/CUSIP
+FCH
+GLB
+CASH
+QUANTITY
+2,000
+2,000
+PRICE
+21.4500
+...
+25.8100
+MARKET
+VALLE
+42,900
+51,620
+ANNAL NOME
+CURRENT
+YIELD (%
+1,600
+3.7296
+........
+2,200
+4.2619
+GRT
+HRP
+CASH
+CASH
+2,000
+10,000
+24.4000
+11.6000
+48,800
+116,000
+3,846
+8,400
+7.8811
+7.2414
+027
+0901/06.07.58 001
+
+
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+HOSPITALITY PROPERTIES TRUST
+SBI
+....
+JOHNSON& JOHNSON
+SYMBOLCUSIP
+HPT
+CASH
+JNJ
+CASH
+WTS LUCENT TECHNOLOGIES INC
+EXP 12/10/2007
+NAYARIT GOLD INC
+PAN PACIFIC RETAIL PROPERTIES
+LUTHW
+CASH
+NYATF
+PNP
+CASH
+CASH
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+PEI
+APT
+CASH
+CASH
+SIRIUS SATELLITE RADIO INC
+BSC RATING: STOCK O/SECTOR MW
+ATLANTIS RESEARCH RATING: B
+Total Equities& Options
+TOTAL EQUITIES
+SIRI
+CASH
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+QUANTITY
+2,000
+57,800
+235
+19
+436
+1,794
+12,000
+1,000
+027
+PRICE
+46.3200
+64.6600
+0.2350
+0.6870
+69.8200
+42.3200
+32.0000
+4.0900
+MARKET
+VALLE
+92,640
+3,737,348
+55
+30,442
+75,922
+384,000
+4,090
+$4,583,830
+$4,583,830
+$795,291
+$17,035.517
+ESTIMATED
+ANNUAL INCOME
+5,920
+CURRENT
+YIELD (%)
+6.3903
+... . . .
+86,700
+2.3198
+1,116
+4,090
+21,480
+$135,352
+$135,352
+3.6660
+5.3871
+5.5938
+09/01/06.07:58 001
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD August 1,2006
+THROUGH
+August 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 31,2006
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of 7
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+08/07/06
+TRANSACTION
+FND WIRED
+08/11/06
+ND WIRE
+08/14/06
+"FUNDS REC
+08/17/06
+FND WIRED
+8/25/06
+FND WIRED
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+08/01/06
+TRANSACTION
+08/01/06
+08/01/06
+BOUGHT
+DIVIDEND
+08:01/06
+REINVEST
+WIRED TO
+NEW EGAN RHASE BANS NA.
+WIRED TO
+TEMPERAM RHASE BANK NA
+FNDS WIRED TO CITIBANK FROM
+COMPASS BANK
+MDA#M8263725NDS WIRED TO
+IPMOBGAN CHASE BANK NA
+MDA#CT960504FNDS WIRED TO
+IPMORGAN CHASE BANK, NA
+OPENINGBALANCE
+*DREYFUS CASH MANAGEMENT-CLA
+MONTHLY DIN ENRES
+"DREYFUS CASH MANAGEMENT-CLA
+DINDEND RENSESRES
+027
+DEBIT AMOUNT
+2,000,000.00
+$-5,000,000.00
+SYMBOUCUSIP
+DICXX
+DICXX
+DICXX
+CREDIT AMOUNT
+12,749,804.62
+$12,749,804.62
+QUANTITY
+4.607,682.63
+63,052.55
+27,567.24
+09/01/06.07:58 001
+PRICE
+0000
+......
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD August 1,2006
+THROUGH
+August 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 31, 2006
+DEBIT AMOUNT
+63,052.55
+27,567.24
+CREDIT AMCUNT
+27,567.24
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+7 of 7
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+TRANSACTION
+08/07/06
+08/11/06
+08/15/06
+*BOUGHT
+08/17/06
+BOUGHT
+08/17/06
+08/25/06
+DESCAIPTION
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+ASTION SHAGEMENT CLA
+ASTUTIONA SHAESGEMEVI CLA
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+DREYFUS CASH MANAGEMENT-CL /
+NSTITUTIONAL SHARE
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+08/31/06
+TOTAL
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+08/17/06
+08/25/06
+TOTAL
+HOSPITALITY PROPERTIES TRUST
+REC 07/14/06 PAY 08/17/06
+.. . .
+HAPT PROPERTIES TR-SBI
+REC 07/25/06 PAY 08/25/06
+SYMBOUGUSIP
+HPT
+SYMBOUGUSIP
+DICXX
+DICXX
+DICXX
+DICXX
+DICXX
+DICXX
+QUANTITY
+-1,000,000
+-2,000,000
+12,749,804.62
+1,480
+1,000,000
+-997,900
+12.451,687.04
+PRICE
+1.0000
+1.0000
+1.0000
+1.0000
+1.0000
+1.0000
+QUANTITY
+2,000
+RATE (S)
+0.7400
+10,000
+- 0.2100
+DEBIT AMOUNT
+027
+09/01/06.07:58 001
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD August 1,2006
+THROUGH
+August 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+July 31, 2006
+DEBIT AMOUNT
+CREDIT AMOUNT
+2,000,000.00
+12.749,804.62
+1,480.00
+997,900.00
+$5.025,467.24
+$-12,841,904.41
+CREDIT AMOUNT
+1,480.00
+,100.0
+$3,580.00
+
+
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .......
+Your Portfolio Holdings
+Transaction Detail ..................................
+Fund Activity ..................
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD July 1,2006
+THROUGH
+July 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 30, 2006
+3
+4
+6
+6
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802-1348
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+NET CREDIT BALANCE
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+4,413,918
+63,053
+4,607,683
+$9.084,654
+........
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+4,931,284
+4,153,370
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$697,631
+Cash & Equivalent
+Equities
+$4.670,736
+• $4,413,918
+$4,233,653
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+027
+SIP The suremen s four ratanal purger red de Set revere die for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+08/01/06 07:56 001|
+
+
+3 ora
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Funds Deposited
+Dividends/Interest
+Miscellaneous
+Amount Credited
+Money Fund
+Funds Withdrawn
+Amount Debited
+Net Cash Activity
+Closing Balance
+Cash Balance Summary
+Cash
+Net Cash Balance
+OFENING
+0.00
+$0.00
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERIOD
+$0.00
+49,101,258.09
+63,052.55
+7,281.60
+53,000,000.00
+$102,171,592.24
+-53,008,539.69
+-49,100,000.00
+$-102,108,539.69
+63,052.55
+$63.052.55
+Income Summary
+Dividends
+Total
+THIS PERIOD
+10,051.29
+$10,051.29
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+CLOSING
+63,052.55
+... ....
+63.052.5
+027
+08/01/0607:56 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIO July 1,2006
+THROUGH
+July 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 30, 2006
+YEAR TO DATE
+80,565.61
+.. . .
+......
+$80,565.61..
+4,670,736
+4,413,918
+$9.084.654
+......
+..........
+Your Portfolio
+Allocation
+Cash & Equivalent
+52%
+Equities
+48%
+Unshaded portions denole debit balance andor short
+from the absolute market value of your portfolio.
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD July 1, 2006
+THROUGH
+July 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 30, 2006
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+EST, 30 DAY AVG VIELD 5,1900%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOL/CUSIP
+DICXX
+QUANTITY
+4,607,682.63
+PRICE
+1.0000
+MARKET
+VALUE
+63,053
+4,607,683
+$4,670,736
+ESTIMATED
+ANNUAL INCOME
+221,169
+$221,169
+CURRENT
+YELD (SI
+4.8000
+EQUITIES
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department, The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O= Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers use different ratings systems and have normalized them as follows: B = Buy; H = Hold; S = Sell (this may not always
+correspond directly to the underlying rating system used by each provider or BSC), The ratings information contained herein is for informational purposes only and is not intended
+to provide tax, legal, or investment advice, Bear Stearns is neither soliciting any action based on such information, nor endorsing any recommendation or opinion expressed by
+any independent, third-party research provider, The symbol indicates that continuing coverage of the subject company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost, Customers can access this research
+FELCOR LODGING TRUST INC
+GLENBOROUGH REALTY TRUST INC
+BSC RATING: STOCK P/SECTOR MW
+NED DAVIS RESEARCH RATING: S
+GLIMCHER REALTY TRUST SE
+SYMBOL/CUSIP
+FCH
+GLB
+CASH
+.....
+CASH
+QUANTITY
+2,000
+2,000
+PRICE
+22.0000
+22.2000
+44,000
+44,400
+1,600
+2,200
+3.6364
+4.9550
+GRT
+CASH
+2,000
+23.6500
+47,300
+3.846
+........
+8.1311
+027
+
+
+5 or 8
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+HRPT PROPERTIES TR-SBI
+SOSPITALITY PROPERTIES TRUST
+JOHNSON& JOHNSON
+SYMBCUCUSIP
+HRP
+HPT
+109T
+CASH
+......
+CASH
+JNI
+CASH
+WTS LUCENT TECHNOLOGIES INC
+EXP 12/10/2007
+NAYART GOLD INC
+PAN PACIFIC RETAIL PROPERTIES
+LUTHW
+NYRTF
+PNP
+CASH
+CASH
+CASH
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+PEI
+CASH
+APT
+CASH
+SIRI
+CASH
+Total Equities& Options
+TOTAL EQUITIES
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+QUANTITY
+10,000
+2,000
+57,800
+235
+19
+436
+1,794
+12,000
+1,000
+027
+PRICE
+11.7500
+43.5700
+62.5500
+0.1700
+0.6190
+69.1000
+39.3800
+29.4300
+4.2000
+MARKET
+117,500
+87,140
+3,615,390
+40
+30,128
+70,648
+353,160
+4,200
+$4,413,918
+$4,413,918
+$356,521
+$9,084,654
+STIMATE
+NNUAL INCON
+8,400
+5,920
+86,700
+1,116
+4,090
+21,480
+$135,352
+$135,352
+CLEARED THROUGH IT:
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD July 1,2006
+THROUGH
+July 31,2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+June 30, 2006
+CURRENT
+YIELD IN)
+7.1489
+6.7937
+2.3981
+3.7042
+5.7893
+6.0822
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+6 of 8
+Transaction Detail
+DEPOSITS AND WITHDRAWALS
+DATE
+07/06/06
+TRANSACTION
+FND WIRED
+07/10/08
+AND WIRED
+07/21/06
+END WIRED
+07731/06
+FUNDS REC
+TOTAL
+MONEY FUND ACTIVITY
+DATE
+MO/DAY
+07/01/06
+TRANSACTION
+07/03/06
+DIVIDEND
+07/03/06
+REINVEST
+07/05/06
+07/05/06
+BOUGHT
+BOUGHT
+WIRED TO
+MISBENS NATONEL ASSOCIATI
+на........
+WIRED TO
+IPMORGAN CHASE BANK NA
+WIRED TO
+PENNA CASE BANE NA
+......
+NDS WIRED TO CITIBANK FROI
+ALPINE GLENWOOD SP
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT-CLA
+STITUTIONAL SHAR
+ONTHLY DIVIDEI
+DREYFUS CASH MANAGEMENT-CL A
+STITUTIONAL SHAR
+VIDEND REINVE
+DREYFUS CASH MANAGEMENT-CL
+INSTITUTIONAL SHARES
+DREYFUS CASH MANAGEMENT-CL /
+INSTITUTIONAL SHARES
+027
+DEBIT AMOUNT
+47,100,000.00
+$-49,100,000.00
+SYMBOUCUSIP
+DICXX
+DICXX
+DICXX
+DICXX
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIO July 1,2006
+THROUGH
+July 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 30, 2006
+CREDIT AMOUNT
+....... .
+__...
+.........
+63,052.55
+$63.052.55
+QUANTITY
+697,631.34
+2,769.69
+5,370
+53,000,000
+PRICE
+1.0000
+1.0000
+DEBIT AMOUNT
+2.769.69
+5,370.00
+53,000,000.00
+CREDIT AMOUNT
+2,769.69
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+7 of a
+Transaction Detail (continued)
+MONEY FUND ACTIVITY (continued)
+DATE
+MO/DAY
+TRANSACTION
+07/06/06
+07/10/06
+07/21/06
+"SOLD
+07/28/06
+BOUGHT
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+STIN SANGEMENT CLA
+ASTUTIONA SHAESGEMEVI CLA
+DREYFUS CASH MANAGEMENT. CLA
+INSTITUTIONAL SHARES
+07/31/06
+TOTAL
+CLOSINGBALANCE
+DIVIDENDS
+DATE
+07/03/06
+RAMCO GERSHENSON PROPERTIES
+RUST-MISE
+IEC 06/20/06 PAY 07/03/0
+17/17/0€
+37/17/04
+RE 070I106 PAT OTTY DEUST INC
+GLIMCHER REALTY TRUST-SBI
+REC 06/30/06 PAY 07/17/06
+7/28/0
+TOTAL
+FELCOR LODGING TRUST INC
+REC 07/14/06 PAY 07/28/06
+SYMBOUCUSIP
+APT
+GLB
+GRT
+FCH
+SYMBOUCUSIP
+DICXX
+DICXX
+DICXX
+DICXX
+QUANTITY
+12,000
+2,000
+2,000
+2,000
+027
+QUANTITY
+-47,100,000
+-1,000,000
+-998,488.40
+400
+4,607,682.63
+PRICE
+1.0000
+1.0000
+1.0000
+1.0000
+RATE (S)
+0.4475
+.275
+0.4808
+0.2000
+DEBIT AMOUNT
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIO July 1,2006
+THROUGH
+July 31,2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 30,2006
+DEBIT AMOUNT
+CREDIT AMOUNT
+47,100,000.00
+998,488.40
+400.00
+$-53,008,539.69
+$49,101,258.09
+CREDIT AMOUNT
+5,370.00
+550.00
+961.60
+400.00
+$7,281.60
+
+
+8 of a
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+MISCELLANEOUS
+DATE
+MODAY
+07/05/06
+TOTAL
+TRANSACTION
+JOURNAL
+FROM
+DEBIT AMOUNT
+CRECIT AMOUNT
+53,000,000.00
+$53,000,000.00
+STOP
+****** End of Statement******
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIO July 1,2006
+THROUGH
+July 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+June 30, 2006
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD June 1,2006
+THROUGH
+June 30, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 31, 2006
+JEFFREY EPSTEIN
+CIO FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802-1348
+Pursuant to your previously issued instructions, Bear Stearns Securities Corp, provides duplicate monthly statements and/or transaction confirmations to the
+third parties listed on the cover page of this statement, If you wish to modify or cease distribution to any of the recipients indicated, please contact your
+Account Executive. This reminder notice will continue to be provided to you on your quarterly statements.
+Third Party
+EPSTEIN INTERESTS
+A/C JEFFREY EPSTEIN
+ATIN HARRY BELLER
+457 MADISON AVE 4TH FLR
+NEW YORK NY 10022
+027
+07/01/06:10:58 001
+v911
+
+
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary ......
+.....
+Your Portfolio Holdings
+Transaction Detail
+Fund Activity ..........................................
+Your Messages
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD June 1,2006
+THROUGH
+June 30, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 31, 2006
+3
+6
+7
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802-1348
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+4,233,653
+697,631
+$4,931,284
+4,892,951
+38,333
+or sel apen sers onese for your other ponding buy
+Cash & Equivalent
+Equities
+......
+Market Value of Your Portfolio
+697,63
+671,91
+Current market value
+Last statement's market value
+$4.233,653
+ME S4,221,032
+Confirmation: Unless we hear
+from you to the contrary, it is
+our understanding that any
+free credit balances in your
+account are being maintained
+to facilitate your intention to
+invest such amounts through
+US.
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; Or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+027
+SP The suren s four or ratanal fryer rear de Set revere date for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+3 ora
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+2,735.31
+22,976.62
+$25,711.93
+-25,711.93
+$-25,711.93
+.....
+$0.00
+......
+Income Summary
+Dividends
+Total
+THIS PERIOD
+25,711.93
+$25,711.93
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+YEAR TO DATE
+70,514.32
+••••*•
+... . .
+70.514.32.
+697,631
+4,233,653
+....
+$4.031.284
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD June 1,2006
+THROUGH
+June 30, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 31, 2006
+Your Portfolio
+Allocation
+Cash & Equivalent
+15%
+- Equities
+85%
+Unshaded portions denole debi balance and'or short
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD June 1,2006
+THROUGH
+June 30, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 31, 2006
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST. 30 DAY AVG YIELD 5.1700%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+QUANTITY
+697,631.34
+PRICE
+1.0000
+MARKET
+VALUE
+697,631
+$697,631
+ESTIMATED
+ANNUAL INCOME
+34,184
+$34,184
+CURRENT
+YELD IN
+4.9000
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department. The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O= Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Neight; MU = Market underweight, In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+correspond directly to the underlying rating system used by each provider or BSC), The ratings information contained herein is for informational purposes only and is not intended
+to provide tax, legal, or investment advice. Bear Stears is neither soliciting any action based on such information, nor endorsing any recommendation or opinion expressed by
+any independent, third-party research provider. The symbol indicates that continuing coverage of the subject company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost, Customers can access this research
+SYMBOL/CUSIP
+FELCOR LODGING TRUST INC
+FCH
+••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••
+GLENBOROUGH REALTY TRUST INC
+GLB
+SO RATING: STOCK P/SECTOR MW
+NED DAVIS RESEARCH RATING: S
+GLIMCHER REALTY TRUST-SBI
+HAPT PROPERTIES TR-SBI
+GRT
+HRP
+CASH
+QUANTITY
+2,000
+2,000
+PRICE
+21.7400
+21.5400
+MARKET
+VALLE
+43,480
+•••••••••••••••••
+43,080
+ANNAL NOME
+CURREN
+YIELD (%
+1,600
+3.6799
+.................
+2,200
+5.1068
+CASH
+CASH
+2,000
+10,000
+24.8100
+11.5600
+49,620
+115,600
+3,846
+8,400
+7.7509
+7.2664
+027
+07/01/06:10.56 001
+
+
+5 or8
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+HOSPITALITY PROPERTIES TRUST
+SBI
+....
+JOHNSON& JOHNSON
+SYMBOLCUSIP
+HPT
+CASH
+JNJ
+CASH
+WTS LUCENT TECHNOLOGIES INC
+EXP 12/10/2007
+NAYARIT GOLD INC
+PAN PACIFIC RETAIL PROPERTIES
+LUTHW
+CASH
+NYATF
+PNP
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+SIRIUS SATELLITE RADIO INC
+BSC RATING: STOCK O/SECTOR MW
+ATLANTIS RESEARCH RATING: B
+Total Equities& Options
+TOTAL EQUITIES
+PEI
+APT
+CASH
+CASH
+CASH
+CASH
+SIRI
+CASH
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+QUANTITY
+2,000
+57,800
+235
+19
+436
+1,794
+12,000
+1,000
+027
+PRICE
+43.9200
+59.9200
+0.2700
+0.8060
+69.3700
+40.3700
+26.9300
+4.7500
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD June 1,2006
+THROUGH
+June 30, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 31, 2006
+MARKET
+VALLE
+87,840
+3,463,376
+63
+30,245
+72,424
+323,160
+4,750
+$4,233,653
+$4,233,653
+$169,456
+$4,931,284
+ESTIMATED
+ANNUAL INCOME
+5,840
+CURRENT
+YIELD (%)
+6.6485
+....
+86,700
+2.5033
+1,116
+4,090
+21,480
+$135,272
+$135,272
+3.6899
+5.6473
+6.6469
+
+
+6 of a
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MODAY
+06/01/06
+TRANSACTION
+06/01/06 DIVIDEND
+06/01/06
+REINVEST
+06/14/06
+BOUGHT
+aaaaaaaaaaaaaaaaaaaaaaaaaaani
+06/15/06
+BOUGHT
+06/30/06
+TOTAL
+DIVIDENDS
+DATE
+06/13/06
+JOHNSON& JOHNSON
+REC 05/30/06 PAY 06/13/06
+06/15/06
+"AN PACIFIC RETAIL PROPERTIE
+NEC O52606 PAY 06/15:06
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT-CL A
+MONTHLY DIVENES
+DREYFUS CASH MANAGEMENT-CLA
+RETTON SHAAGEMENT CLAI
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+CLOSINGBALANCE
+SYMBOUCUSIP
+DICXX
+DICXX
+DICXX
+PNP
+QUANTITY
+57,800
+436
+027
+QUANTITY
+671,919.41
+2,735.31
+21,675
+1,301.62
+697,631.34
+PRICE
+1.0000
+1.0000
+RATE (S)
+0.3750
+0.6400
+DEBIT AMOUNT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD June 1,2006
+THROUGH
+June 30, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 31, 2006
+DEBIT AMOUNT
+CREDIT AMOUNT
+2,735.31
+2,735.31
+21,675.00
+1,301.62
+$-25,711.93
+CREDIT AMOUNT
+21,675.00
+279.04
+$2,735.31
+
+
+7 of a
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+DIVIDENDS (continued)
+DATE
+06/15/06
+PENNSYLVANIA REAL ESTATE
+TOTAL
+SYMBOUCUSIP
+PEI
+QUANTITY
+1,794
+Your messages
+I NOTICE OF CHANGE PURSUANT TO TRUTH IN LENDING SEC RULE 10b-16
+The annual rate of interest charged on any credit extended to you by Bear,
+Stearns Securities Corp. ('BSS") for the purpose of purchasing, carrying or
+trading in any security or other property shall continue to be based on either
+the BSSC Margin Basis Rate, the BSSC Fed Funds Rate or the London
+Interbank Offered Rate ("LIBOR*), as notified to you upon request, The BSSC
+borrowing money.
+The purpose of this notice is to advise you that effective no earlier than thirty
+(30) days from your receipt of this statement:
+027
+RATE (S)
+0.5700
+DEBIT AMOUNT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD June 1,2006
+THROUGH
+June 30, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 31, 2006
+CREDIT AMOUNT
+1,022.58
+$22.976.62
+1) The BSSC Fed Funds Rate shall be the rate for U,S, dollar funds, as
+quoted by an independent broker of such funds selected by BSSC for the
+first transaction completed on the opening of the business day on which
+such rate is determined,
+2) The rate of interest charged to you on any such credit extended to you in
+abal bank, and irapeated your mors or stateme provided by BSS'S
+4) Tolde purt last of securis for which payou ars made dinest may
+which BSSC has not yet received credit
+
+
+8 of 8
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD June 1,2006
+THROUGH
+June 30, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+May 31, 2006
+If BSSC makes changes in any of the credit terms and conditions described
+herein or if a change is required by law, we will notify you of such change within
+i reasonable period of time, unless such change results in the same or a
+nigher rate to you, in which case we will provide you at least 30 days' prio
+written notice, The annual rate of interest you are charged may fluctuate with
+changes in the BSSC Margin Basis Rate, the BSSC Fed Funds Rate, LIBOR,
+any of the rates quoted by Reuters or the rate provided by BSSC's local bank
+The changes in rates resulting from this fluctuation will be made without prio
+notice of you a cont prod with a learn in therei terms and conditions,
+he Truth-in-Lending disclosure previously provided to you shall continue t
+apply except as specifically noted above
+STOP
+****** End of Statement******
+027
+
+
+TELEPHONE
+VISIT OUR WEBSITE
+www.bearstearns.com
+What's In This Statement
+Financial Summary .......
+Your Portfolio Holdings
+Transaction Detail ..................................
+Fund Activity ...................
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 29,2006
+THROUGH
+May 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 28, 2006
+3
+4
+6
+6
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802-1348
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+MONEY MARKET FUND BALANCE
+4,221,032
+671,919
+$4,892,951
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+4,816,952
+75,999
+oh sel arenates on i to your ator pending bury
+Market Value of Your Portfolio
+$671,919
+$665,510
+Cash & Equivalent
+Equities
+$4.221,032
+$4.151.442
+......
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+027
+SP The suremen s four ratanal purger red de Set revere dise for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+4909
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+2,549.49
+3,860.00
+$6,409.49
+-6,409.49
+........
+-6,409.4
+50.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+6,409.49
+$6.409.49
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 29,2006
+THROUGH
+May 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 28,2006
+YEAR TO DATE
+44,802.39
+... ..
+... . .
+514,802.39.
+671,919
+4,221,032
+$4,892,951
+Your Portfolio
+Allocation
+Cash & Equivalent
+14%
+\ Equities
+86%
+Unshaded portions denole debi balance and'or short
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 29,2006
+THROUGH
+May 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 28, 2006
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+QUANTITY
+671,919.41
+FRICE
+1.0000
+MARKET
+VALUE
+671,919
+$671,919
+ESTIMATED
+CURRENT
+ANNUAL INCOME
+YELD IN
+30,908
+4.6000
+$30,908
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department. The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O= Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+ESPERATE
+where such research is available. The various providers use different ratings systems and have normalized them as follows: B = Buy: H = Hold; S = Sell (this may not always
+correspond directly to the underlying rating system used by each provider or BSC), The ratings information contained herein is for informational purposes only and is not intended
+to provide tax, legal, or investment advice. Bear Stearns is neither soliciting any action based on such information, nor endorsing any recommendation or opinion expressed by
+any independent, third-party research provider. The symbol indicates that continuing coverage of the subject company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost, Customers can access this research
+SYMBOL/CUSIP
+QUANTITY
+MARKET
+PRICE
+VALUE
+ANNUAL MONE
+CURREN
+YIELD (%
+FELCOR LODGING TRUST INC
+FCH
+CASH
+2,000
+20.8100
+41,620
+1,200
+2.8832
+••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••
+••••••••••••••••
+........
+GLENBOROUGH REALTY TRUST INC
+GLB
+2,000
+19.9100
+39,820
+2,200
+5.5249
+SO RATING: STOCK P/SECTOR MW
+NED DAVIS RESEARCH RATING: S
+GLIMCHER REALTY TRUST-SBI
+HAPT PROPERTIES TR-SBI
+GRT
+HRP
+CASH
+CASH
+2,000
+10,000
+25.2500
+11.1600
+50,500
+111,600
+3,846
+8,400
+7.6158
+7.5269
+027
+06/01/06.11:28 001
+
+
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+HOSPITALITY PROPERTIES TRUST
+SBI
+JOHNSON& JOHNSON
+RED DAVIS RESEARCH RATE
+WTS LUCENT TECHNOLOGIES INC
+EXP 12/10/2007
+NAYARIT GOLD INC
+PAN PACIFIC RETAIL PROPERTIES
+SYMBOLCUSIP
+HPT
+CASH
+JNJ
+CASH
+LUTHW
+CASH
+NYATF
+PNP
+CASH
+CASH
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+SIRIUS SATELLITE RADIO INC
+BSC RATING: STOCK O/SECTOR MW
+ATLANTIS RESEARCH RATING: B
+Total Equities& Options
+TOTAL EQUITIES
+PEI
+APT
+CASH
+CASH
+SIRI
+CASH
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+QUANTITY
+2,000
+57,800
+235
+19
+436
+1,794
+12,000
+1,000
+027
+PRICE
+42.1700
+60.2200
+0.3300
+0.9540
+66.2700
+37.3000
+26.0000
+4.5300
+HOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 29,2006
+THROUGH
+May 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 28,2006
+MARKET
+VALLE
+84,340
+3,480,716
+78
+18
+28,894
+66,916
+312,000
+4,530
+$4,221,032
+$4,221,032
+$165,780
+$4,892,951
+ESTIMATED
+ANNUAL INCOME
+5,840
+CURRENT
+YELD IN
+6.9244
+... . . .
+86,700
+2.4909
+1,116
+060'
+21,480
+$134,872
+$134,872
+3.8624
+6.1121
+6.8846
+
+
+6 of 7
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MODAY
+04/29/06
+TRANSACTION
+05/01/06
+"'DIVIDEND
+05/01/06
+REINVEST
+05/03/06
+BOUGHT
+...
+05/11/06
+BOUGHT
+05/24/06
+BOUGHT
+05/31/06
+TOTAL
+DIVIDENDS
+DATE
+05/01/06
+05/1/06
+ELCOR LODGING TRUST IN
+EC 04/15/06 PAY 05/01/0
+HOSPTALITY PROPERTIES TRUST
+REC 04/1206 PAY 05/1106
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT-CL A
+MONTHLY DIVENES
+DREYFUS CASH MANAGEMENT-CLA
+NTIONAL SHARE CEMENT CLIM
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+............
+BREYFUS CASH MANAGEMENT-CLARI BIC)
+INSTITUTIONAL SHARES
+CLOSINGBALANCE
+SYMBOU/CUSIP
+DICXX
+DICXX
+DICXX
+SYMBOUCUSIP
+FCH
+HPT
+QUANTITY
+2,000
+2,000
+027
+QUANTITY
+665,509.92
+2,549.49
+300
+1,460
+2,100
+671,919.41
+RATE (S)
+0.1500
+0.7300
+PRICE
+1.0000
+1.0000
+1.0000
+DEBIT AMOUNT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 29,2006
+THROUGH
+May 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 28, 2006
+DEBIT AMOUNT
+CREDIT AMOUNT
+2,549.49
+2,549.49
+300.00
+1,460.00
+•••••••••••••••••••••••••••••••••••••••••!••...
+2.100.00
+$-6,409.49
+$2,549.49
+CREDIT AMOUNT
+300.00
+1.460.00
+
+
+7 of 7
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+DIVIDENDS (continued)
+DATE
+05/24/06
+HAPT PROPERTIES TR-SBI
+EC 04/24/06 PAY 05/24/0
+TOTAL
+SYMBOUCUSIP
+HRP
+QUANTITY
+10,000
+RATE (S)
+0.2100
+DEBIT AMOUNT
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 29,2006
+THROUGH
+May 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+April 28,2006
+CREDIT AMOUNT
+2,100.00
+$3,860.00
+STOP
+****** End of Statement******
+027
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail ..................................
+Fund Activity .....................
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 1, 2006
+THROUGH
+April 28, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 31, 2006
+3
+4
+6
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+4,151,442
+665,510
+$4,816,952
+4,904,546
+-87,594
+or sel apen sters onese for your other ponding buy
+Market Value of Your Portfolio
+฿665,510
+$656,047
+Cash & Equivalent
+Equities
+$4,151,442
+$4,248,499
+....
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859
+027
+SP The suren s four or ratanal purposes rear die Set revere date for portant iformation.
+04/23/06.08:33 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+04/29/06 08:33 001|
+V9O8
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+...
+Closing Balance
+THIS PERIOD
+$1.79
+2,431.98
+7,031.60
+$9,463.58
+-9,465.37
+$ 9,465.37
+-1.79
+.50.00
+....
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+1.79
+$1.79
+Income Summary
+THIS PERIOD
+Dividends
+9,463.58
+Total
+$9.463.58
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+027
+04/29/06.08:33 001
+CLOSING
+0.00
+.......
+$0.00
+.................L....
+YEAR TO DATE
+38,392.90
+.... . .
+$38.392.90.
+665,510
+4,151,442
+$4,816,952
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 1, 2006
+THROUGH
+April 28, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 31,2006
+Your Portfolio
+Allocation
+Cash & Equivalent
+14%
+\ Equities
+86%
+Unshaded portions denote debit balance andor short
+market values. The alocation percentago is derived
+
+
+4 of 8
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 1, 2006
+THROUGH
+April 28, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 31, 2006
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+EST, 30 DAY AVG YIELD 4.7100%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+QUANTITY
+665,509.92
+PRICE
+1.0000
+MARKET
+VALUE
+665,510
+$665,510
+ESTIMATED
+ANNUAL INCOME
+29,948
+$29,948
+CURRENT
+YELD IN
+4.5000
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department. The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers use different ratings systems and have normalized them as follows: B = Buy: H = Hold; S = Sell (this may not always
+correspond directly to the underlying rating system used by each provider or BSC), The ratings information contained herein is for informational purposes only and is not intended
+to provide tax, legal, or investment advice. Bear Stearns is neither soliciting any action based on such information, nor endorsing any recommendation or opinion expressed by
+any independent, third-party research provider. The symbol indicates that continuing coverage of the subject company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost, Customers can access this research
+at www.bearstears.com or can call (800) 517-2327 to request that a copy of this research be sent to them.
+SYMBOL/CUSIP
+QUANTITY
+MARKET
+PRICE
+VALLE
+ANAL MOMEN
+CURREN
+YIELD (%
+FELCOR LODGING TRUST INC
+FCH
+CASH
+2,000
+21.6500
+43,300
+1,200
+...
+2.7714
+.....
+.........
+GLENBOROUGH REALTY TRUST ING
+GLB
+2,000
+20.9500
+SO RATING: STOCK P/SECTOR MW
+41,900
+2,200
+5.2506
+NED DAVIS RESEARCH RATING: H
+GLIMCHER REALTY TRUST-SBI
+HAPT PROPERTIES TR-SBI
+GRT
+HRP
+CASH
+CASH
+2,000
+10,000
+25.8000
+10.9800
+51,600
+109,800
+3,846
+8,400
+7.4535
+7.6503
+027
+042910608:33 001
+V908
+
+
+5 org
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+HOSPITALITY PROPERTIES TRUST
+SBI
+JOHNSON& JOHNSON
+RED DAVIS RESEARCH RATE
+WTS LUCENT TECHNOLOGIES INC
+EXP 12/10/2007
+NAYARIT GOLD INC
+PAN PACIFIC RETAIL PROPERTIES
+SYMBOLCUSIP
+HPT
+CASH
+JNJ
+CASH
+LUTHW
+CASH
+NYATF
+PNP
+CASH
+CASH
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+SIRIUS SATELLITE RADIO INC
+BSC RATING: STOCK O/SECTOR MW
+ATLANTIS RESEARCH RATING: B
+Total Equities& Options
+TOTAL EQUITIES
+PEI
+APT
+CASH
+CASH
+SIRI
+CASH
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+QUANTITY
+2,000
+57,800
+235
+19
+436
+1,794
+12,000
+1,000
+027
+PRICE
+43.1000
+58.6100
+0.4400
+1.0990
+66.6400
+40.5600
+27.0300
+4.6800
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD April 1, 2006
+THROUGH
+April 28, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+March 31, 2006
+MARKET
+86,200
+3,387,658
+103
+29,055
+72,765
+324,360
+4,680
+$4,151,442
+$4,151,442
+$164,820
+$4,816,952
+ESTIMATED
+ANNUAL INCOME
+5,840
+CURRENT
+YIELD (%)
+6.7749
+... . . .
+86,700
+2.5593
+1,116
+4,090
+21,480
+$134,872
+$134,872
+3.8410
+5.6208
+6.6223
+04/29/06.08:33001
+
+
+6 of8
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+04/01/06
+04/03/06 BOUGHT
+04/03106
+DIVIDEND
+04/03/06
+REINVEST
+04/17/06
+BOUGHT
+nonossanssnsnnssnssniisısnnsnssnannnni
+04/28/06
+TOTAL
+DIVIDENDS
+DATE
+04/03/06
+DESCAIPTION
+TRAMCO GERSHENSON PROPERTIES
+TEC 0320106 PAY 04103106
+4/17/0
+04/17/06
+TOTAL
+GLENBOROUGH REALTY TRUST INC
+REC 04/01/06 PAY 04/17/06
+GLIMCHER REALTY TRUST-SBI
+REC 03/31/06 PAY 04/17/06
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+DESCHIPTION
+OPENINGBALANCE
+ISETS A S HAN ENENI CLA"
+DREYFUS CASH MANAGEMENT-CLA
+MONTHALY DINDENARES
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+DIVIDEND REINVEST
+DREYFUS CASH MANAGEMENT-CLA
+INSTITUTIONAL SHARES
+CLOSINGBALANCE
+SYMBOUCUSIP
+DICXX
+DICXX
+DICXX
+DICXX
+SYMBOLCUSIP
+APT
+GLB
+QUANTITY
+12,000
+2,000
+2,000
+027
+QUANTITY
+656,044.55
+5,371.79
+2,431.98
+1,661.60
+665,509.92
+PRICE
+1.0000
+1.0000
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocktyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOO April 1,2006
+THROUGH
+April 28, 2006
+ACCOUNT NUMBER
+TAPAYER NUMBER On File
+March 31, 2006
+DEBIT AMOUNT
+CREDIT AMOUNT
+5,371.79
+2,431.98
+2,431.98
+1,661.60
+••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••!•• . .
+$-9,465.37
+$2,431.98
+RATE (S)
+0.4475
+0.3500
+0.4808
+DEBIT AMOUNT
+04/23/06.08:33 001
+CREDIT AMOUNT
+5,370.00
+700.00
+961.60
+$7,031.60
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD March 1, 2006
+THROUGH
+March 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+February 28,2006
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Pursuant to your previously issued instructions, Bear Stearns Securities Corp, provides duplicate monthly statements and/or transaction confirmations to the
+third parties listed on the cover page of this statement, If you wish to modify or cease distribution to any of the recipients indicated, please contact your
+Account Executive. This reminder notice will continue to be provided to you on your quarterly statements.
+Third Party
+EPSTEIN INTERESTS
+027
+04/01/06:10:28 001
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail ..................................
+Fund Activity .....................
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD March 1,2006
+THROUGH
+March 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+February 28, 2006
+3
+4
+6
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+4.248.499
+NET CREDIT BALANCE
+2
+MONEY MARKET FUND BALANCE
+656,045
+NET EQUITY THIS PERIOD
+$4.904,546
+.......
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+4,750,352
+154,194
+There are no "Stop Loss" orders or other pending buy
+or sell open orders on file for your account.
+Market Value of Your Portfolio
+$656,047
+$633,588
+Cash & Equivalent
+Equities
+$4,248,499
+IT S4,116.764
+Current market value
+Last statement's market value
+Flease report any difference or non-receipt of chacks or stocks, indicated as delivered to you,
+to Client Services at 800-634-1428; Or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four ratanal pur yes rear de Set revere dae for portant iformation.
+04/01/06;10:28 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+04/01/06:10:28 001
+
+
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Net Cash Activity
+...
+Closing Balance
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+THIS PERIOD
+$0.00
+2,081.28
+20,377.41
+$22,458.69
+-22,456.90
+$22.456.90
+1.79
+.$1.79
+Cash Balance Summary
+Cash
+Net Cash Balance
+OPENING
+0.00
+$0.00
+CLOSING
+1.79
+$1.79
+.....................
+Income Summary
+Dividends
+Total
+THIS PERIOD
+22,458.69
+$22,458.69
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+YEAR TO DATE
+28,929.32
+... . .
+$28,929.32...
+656,047
+4,248,499
+•••••••••••••••••••••••••
+54,904,546
+.............
+027
+04/01/06;10:28 001
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD March 1,2006
+THROUGH
+March 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+February 28,2006
+Your Portfolio
+Allocation
+Cash & Equivalent
+14%
+\ Equities
+86%
+Unshaded portions denote debit balance and or shart
+
+
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD March 1,2006
+THROUGH
+March 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+February 28,2006
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+CASH BALANCE
+DREYFUS CASH MANAGEMENT-CL A
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOL/CUSIP
+DICXX
+QUANTITY
+656,044.55
+PRICE
+1.0000
+MARKET
+VALUE
+2
+656,045
+$656,047
+ESTIMATED
+CURRENT
+ANNUAL INCOME
+26,242
+4.0000
+$26,242
+EQUITIES
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the BSC Equity Research Department, The first rating represents the stock's total return
+relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform. The second rating
+represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW = Market
+Weight; MU = Market underweight. In cases where the BSC rating is present, the name of an independent, third-party research provider and their rating may also be displayed,
+where such research is available. The various providers use different ratings systems and have normalized them as follows: B = Buy; H = Hold; S = Sell (this may not always
+correspond directly to the underlying rating system used by each provider or BSC), The ratings information contained herein is for informational purposes only and is not intended
+to provide tax, legal, or investment advice, Bear Stearns is neither soliciting any action based on such information, nor endorsing any recommendation or opinion expressed by
+any independent, third-party research provider, The symbol indicates that continuing coverage of the subject company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost, Customers can access this research
+at www.bearstears.com or can call (800) 517-2327 to request that a copy of this research be sent to them.
+FELCOR LODGING TRUST INC
+GLENBOROUGH REALTY TRUST INC
+BSC RATING: STOCK P/SECTOR MW
+NED DAVIS RESEARCH RATING: S
+GLIMCHER REALTY TRUST SE
+SYMBOL/CUSIP
+FCH
+GLB
+CASH
+.....
+CASH
+QUANTITY
+2,000
+2,000
+PRICE
+21.1000
+21.7500
+VALUE
+42,200
+43,500
+ANNUAL MONE
+1,200
+2,200
+2.8436
+5.0575
+GRT
+CASH
+2,000
+28.4000
+56,800
+3.846
+...
+6.7711
+027
+04/01/06;10:28 001
+
+
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+HRPT PROPERTIES TR-SBI
+SOSPITALITY PROPERTIES TRUST
+JOHNSON& JOHNSON
+LEO DAVIS RESEARCH TO
+WTS LUCENT TECHNOLOGIES INC
+EXP 12/10/2007
+NAYART GOLD INC
+PAN PACIFIC RETAIL PROPERTIES
+SYMBCUCUSIP
+HRP
+HPT
+109T
+CASH
+......
+CASH
+JNI
+CASH
+LUTHW
+NYRTF
+PNP
+CASH
+CASH
+CASH
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+PEI
+CASH
+APT
+CASH
+SIRI
+CASH
+Total Equities& Options
+TOTAL EQUITIES
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+QUANTITY
+10,000
+2,000
+57,800
+235
+19
+436
+1,794
+12,000
+1,000
+PRICE
+11.7400
+43.6700
+59.2200
+0.6250
+1.4560
+70.9000
+44.0000
+30.2700
+5.0800
+027
+MARKET
+VALUE
+117,400
+87,340
+3,422,916
+147
+28
+30,912
+78,936
+363,240
+5,080
+$4,248,499
+$4,248,499
+$150,710
+$4,904,546
+ESTIMATE
+INNUAL INCOM
+8,400
+......
+5,840
+76,296
+1,116
+4,090
+21,480
+$124,468
+$124,468
+04/01/06;10:28 001
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD March 1,2006
+THROUGH
+March 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+February 28,2006
+CURRENT
+YIELD (%)
+7.1550
+6.6865
+2.2290
+3.6102
+5.1814
+5.9134
+
+
+6 of 7
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MODAY
+TRANSACTION
+03/01/06
+03/01/06
+"'DIVIDEND
+03/01/06
+REINVEST
+03/14/06
+BOUGHT
+aaaaaaaaaaaaaaaaaaaaaaaıaaaaani
+03/15/06
+BOUGHT
+03/31/06
+TOTAL
+DIVIDENDS
+DATE
+03/14/06
+JOHNSON& JOHNSON
+REC 02/28/06 PAY 03/14/06
+
+"AN PACIFIC RETAIL PROPERTIE
+C 0224106 PAY 03/15106
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT-CL A
+MONTHLY DIVENES
+DREYFUS CASH MANAGEMENT-CLA
+RETTA SAN CEMENT CLA
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+CLOSINGBALANCE
+SYMBOUGUSIP
+DICXX
+DICXX
+DICXX
+SYMBOUCUSIP
+JNJ
+PNP
+QUANTITY
+57,800
+436
+027
+QUANTITY
+633,587.65
+2,081.28
+•...
+9,07
+1,301.62
+656,044.55
+RATE (S)
+0.3300
+0.6400
+PRICE
+1.0000
+1.0000
+DEBIT AMOUNT
+04/01/06;10:28 001
+LEARED THROUGH M
+HOLLY OWNED SUBSIDIAR
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD March 1, 2006
+THROUGH
+March 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER
+On File
+February 28,2006
+DEBIT AMOUNT
+CREDIT AMOUNT
+2,081.28
+2,081.28
+19.074.00
+1,301.62
+$-22,456.90
+$2,081.28
+CREDIT AMOUNT
+19,074.00
+279.04
+
+
+7 of 7
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Transaction Detail (continued)
+DIVIDENDS (continued)
+
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+,001
+SYMBOUCUSIP
+PEI
+QUANTITY
+1,794
+RATE (S)
+0.5710
+DEBIT AMOUNT
+TOTAL
+STOP
+****** End of Statement******
+027
+04/01/06:10:28 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD March 1,2006
+THROUGH
+March 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+February 28,2006
+CREDIT AMOUNT
+1,024.37
+$20,377.41
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail ..................................
+Fund Activity .....................
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD February 1, 2006
+THROUGH
+February 28, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+January 31, 2006
+3
+4
+6
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+4,116,764
+633,588
+$4,750,352
+4,727,506
+22,846
+oh sel arenates on i to your ator pending bury
+Cash & Equivalent
+Equities
+Market Value of Your Portfolio
+$633,588
+$627,817
+$4,116.764
+I S4.099.689
+....
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; Or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SIP The suremen s four or ratanal purposes rear de Set revere date for portant iformation.
+03/01/06;09:04 001
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+03/01/06:08:04 001
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+THIS PERIOD
+$0.00
+2,210.63
+3,560.00
+$5,770.63
+-5,770.63
+$-5,770.63
+50.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+5,770.63
+$5,770.63
+YEAR TO DATE
+6,470.63
+.. . .
+....
+$6.470.63
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+633,588
+4,116,764
+.....
+$4,750.352....
+027
+03/01/06:08:04 001
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD February 1, 2006
+THROUGH
+February 28, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+January 31,2006
+Your Portfolio
+Allocation
+Cash & Equivalent
+14%
+\ Equities
+86%
+Unshaded portions denole debi balance and'or short
+
+
+4 of 8
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD February 1, 2006
+THROUGH
+February 28, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+January 31, 2006
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+SYMBOUCUSIP
+DICXX
+QUANTITY
+633,587.65
+FRICE
+1.0000
+MARKET
+VALUE
+633,588
+ESTIMATED
+ANNUAL INCOME
+26,611
+CURRENT
+YELD IN
+4.2000
+TOTAL CASH & CASH EQUIVALENTS
+$633,588
+$26,611
+EQUITIES
+Equities & Options
+The research ratings for Bear Stearns (BSC) are shown for certain securities covered by the Firm's Equity Research Department, The first rating represents the stock's total
+return relative to the other stocks covered by that Analyst. The key for the stock rating values is as follows: O = Outperform; P = Peer Perform; U = Underperform, The second
+rating represents the rating of the coverage universe relative to the regional broader market index, The key for the sector rating is as follows: MO = Market Overweight; MW =
+Market Weight; MU = Market Underweight, In cases where a BSC rating is present, the name of an independent, third-party research provider and their rating may also be
+displayed, where such research is available, The various providers have normalized their ratings systems as follows: B = Buy; H = Hold; S = Sell, The ratings information
+intained herein is for informational purposes only and is not intended to provide tax, legal or investment advice, Bear Stearns is neither soliciting any action based on su
+formation, nor endorsing any recommendation or opinion expressed by any independent, third-party research provider, The symbol indicates that continuing coverage
+the subject company is temporarily not available due to legal reasons.
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear Stearns at no cost, Customers can access this research
+at www.bearsteams.com or can call (800) 517-2327 to request that a copy of this research be sent to them,
+SYMBOL/CUSIP
+QUANTITY
+MARKET
+PRICE
+VALLE
+ANNAL NOME
+CURREN
+YIELD (S
+FELCOR LODGING TRUST INC
+FCH
+CASH
+2,000
+19.8500
+39,700
+1,200
+3.0227
+GLENBOROUGH REALTY TRUST ING
+GLB
+2,000
+...............
+19.3500
+38,700
+2,200
+5.6848
+BSC RATING: STOCK P/SECTOR W
+NED DAVIS RESEARCH RATING: H
+GLIMCHER REALTY TRUST-SBI
+HAPT PROPERTIES TR-SBI
+GRT
+HRP
+CASH
+CASH
+2,000
+10,000
+26.6800
+10.7200
+53,360
+107,200
+1,050
+8,400
+1.9678
+7.8358
+027
+0301106:00:04 001
+
+
+5 org
+Your Portfolio Holdings (continued)
+Equities & Options (continued)
+HOSPITALITY PROPERTIES TRUST
+SBI
+JOHNSON& JOHNSON
+RED DAVIS RESEARCH RATE
+WTS LUCENT TECHNOLOGIES INC
+EXP 12/10/2007
+NAYARIT GOLD INC
+PAN PACIFIC RETAIL PROPERTIES
+SYMBOLCUSIP
+HPT
+CASH
+JNJ
+CASH
+LUTHW
+CASH
+NYATF
+PNP
+PENNSYLVANIA REAL ESTATE
+INVESTMENT TRUST-SBI
+RAMCO GERSHENSON PROPERTIES
+TRUST-MD SBI
+SIRIUS SATELLITE RADIO INC
+BSC RATING: STOCK O/SECTOR MW
+ATLANTIS RESEARCH RATING: B
+Total Equities& Options
+TOTAL EQUITIES
+PEI
+APT
+CASH
+.. . .
+CASH
+CASH
+CASH
+SIRI
+CASH
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICEDPORTFOLIOHOLDINGS
+Bear, Stears & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+QUANTITY
+2,000
+57,800
+235
+19
+436
+1,794
+12,000
+1,000
+PRICE
+44.5000
+57.6500
+0.5750
+0.7750
+.....
+69.2100
+40.4000
+29.0600
+5.1100
+027
+MARKET
+VALLE
+89,000
+3,332,170
+135
+15
+....
+30,176
+72,478
+348,720
+5,110
+$4,116,764
+$4,116,764
+$138.287
+$4,750,352
+ESTIMATED
+ANNUAL INCOME
+5,840
+CURRENT
+YIELD IN
+6.5618
+... . . .
+76,296
+2.2897
+1,116
+4,090
+11,484
+$111,676
+$111,676
+3.6983
+5.6431
+3.2932
+03/01/06;09:04 001
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD February 1, 2006
+THROUGH
+February 28, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+January 31,2006
+
+
+BEARR
+6 of8
+Transaction Detail
+MONEY FUND ACTIVITY
+DATE
+MOVDAY
+TRANSACTION
+02/01/06
+02/01/06
+"'DIVIDEND
+02/01/06
+*REINVEST
+02/16/06
+BOUGHT
+.. . . .
+02/27/06
+BOUGHT
+anuaaaaannnanatss sasaaaaaaaaaaaan
+02/28/06
+TOTAL
+DIVIDENDS
+DATE
+DESCRPTION
+02/16/06
+HOSPITALITY PROPERTIES TRUST
+REC 0127106 PAY 0216106
+02/23/06
+TOTAL
+HAPT PROPERTIES TR-SE
+EC 01/20/06 PAY 02/23/0
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT-GL A
+MONTHLY DIDENDES
+DREYFUS CASH MANAGEMENT-CLA
+RETU TONA SHAEAGEMENT-CLA
+DREYFUS CASH MANAGEMENT-CL A
+INSTITUTIONAL SHARES
+CLOSINGBALANCE
+SYMBOU/CUSIP
+DICXX
+DICXX
+DICXX
+DICXX
+SYMBOUCUSIP
+HPT
+- HRP
+QUANTITY
+2,000
+10,000
+027
+QUANTITY
+627,817.02
+2,210.63
+1,460
+2,100
+633,587.65
+RATE (S)
+0.7300
+0.2100
+PRICE
+1.0000
+1.0000
+DEBIT AMOUNT
+03/01/06;09:04 001
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocktyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD February 1,2006
+THROUGH
+February 28,2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+January 31,2006
+DEBIT AMOUNT
+CREDIT AMOUNT
+2,210.63
+2,210.63
+1,460.00
+2,100.00
+$-5,770.63
+$2.210.63
+CREDIT AMOUNT
+1,460.00
+2,100.00
+$3,560.00
+
+
+Bear, Stearns & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+ACCOUNT EXECUTIVE
+TELEPHONE
+VISIT OUR WEBSITE
+ZICHERMAN, IRA
+www.bearstears.com
+What's In This Statement
+Financial Summary ...............................
+Your Portfolio Holdings
+Transaction Detail ..................................
+Fund Activity ..............I....
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 31, 2005
+THROUGH
+January 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+December 30, 2005
+3
+5
+5
+JEFFREY EPSTEIN
+C/O FINANCIAL TRUST COMPANY
+ATTN JEANNE BRENAN
+6100 RED HOOK QUATER B-3
+ST THOMAS VI 00802
+Your Portfolio at a Glance
+TOTAL VALUE OF SECURITIES THIS PERIOD
+MONEY MARKET FUND BALANCE
+NET EQUITY THIS PERIOD
+NET EQUITY LAST STATEMENT
+CHANGE SINCE LAST STATEMENT
+4,099,689
+627,817
+$4,727,506
+4,818,382
+-90,876
+o sel apen resortie to your ator pending bury
+Market Value of Your Portfolio
+627,81
+618,81
+Cash & Equivalent
+Equities
+$4,099,689
+$4,199,568
+......
+Current market value
+Last statement's market value
+Flease raport any diference or non-receipt of chacks or stocks, indicated as dalivared to you,
+to Client Services at 800-634-1428; or write to Cient Services at Bear, Steams Securities
+Corp., One Metrolech Center North, Brooklyn, N.Y. 11201-3859.
+SP The suren s four erratanal purposes red die Set revere date for portant iformation.
+
+
+Bear, Steams Securities Corp.
+One Metrotech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT BACKER IS PRINTED ON THIS PAGE
+027
+
+
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York, New York 10179
+Cash Flow Analysis
+Opening Balance
+Money Fund
+Dividends/Interest
+Amount Credited
+Money Fund
+Amount Debited
+Closing Balance
+Your Portfolio Holdings
+CASH & CASH EQUIVALENTS
+REYFUS CASH MANAGEMENT-CL
+STITUTIONAL SHARE
+EST, 30 DAY AVG YIELD 4,1800%
+TOTAL CASH & CASH EQUIVALENTS
+SYMBOLCUSIP
+DICXX
+THIS PERIOD
+$0.00
+2,091.88
+6,911.60
+$9,003.48
+-9,003.48
+$-9,003.48
+...•.*........
+$0.00
+Income Summary
+Dividends
+Total
+THIS PERIOD
+700.00
+$700.00
+Portfolio Composition
+Cash/Cash Equivalent
+Equities
+Total
+YEAR TO DATE
+700.00
+......
+$700.00
+627,817
+4,099,689
+6472-506
+QUANTITY
+627,817.02
+PRICE
+1.0000
+MARKE
+VALU
+627,817
+$627,817
+ESTIMATE
+ANUAL INCON
+25,740
+$25,740
+URRE
+ELD I
+4.0999
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brocklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 31, 2005
+THROUGH
+January 31,2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+December 30, 2005
+Your Portfolio
+Allocation
+(ash & Equivalent
+\ Equities
+86%
+Unshaded portions denote debit balance and or shart
+
+
+Sear, Stears & Co. Inc
+83 Madison Avenue
+New York, New York 10179
+4 of 6
+Your Portfolio Holdings (continued)
+EQUITIES
+Equities & Options
+Independent, third-party research on certain companies covered by the Firm's research is available to customers of Bear
+Stearns at no cost, Customers can access this research at www.bearstears,com or can call (800) 517-2327 to
+request that a copy of this research be sent to them,
+MARKET
+SYMBOUCUSIP
+QUANTITY
+PRICE
+FELCOR LODGING TRUST INC
+FCH
+CASH
+2,000
+VALUE
+19.8600
+39,720
+GLENBOROUGH REALTY TRUST ING
+GLB
+CASH
+2,000
+19.6800
+39,360
+GLIMCHER REALTY TRUST SBI
+GRT
+CASH
+2,000
+27.3400
+54,680
+HRPT PROPERTIES TR-SBI
+HRP
+CASH
+10,000
+10.7300
+107,300
+HOSPITALITY PROPERTIES TRUST
+HPT
+CASH
+2,000
+42.8700
+85,740
+JOHNSON & JOHNSON
+JNJ
+CASH
+WTS LUCENT TECHNOLOGIES INC
+LUTHW
+CASH
+57,800
+57.5400
+3,325,812
+235
+0.5150
+121
+EXP 12/10/2007
+NAYARIT GOLD INC
+PAN PACIFIC RETAIL PROPERTIES
+NYATF
+PNP
+PENNSYLVANIA REAL ESTATE
+PEI
+INVESTMENT TRUST-SBI
+RAMCO GERSHENSON PROPERTIES
+APT
+CASH
+••••••••••
+CASH
+....
+CASH
+CASH
+19
+436
+1,794
+0.5780
+69.2000
+40.6600
+11
+30,171
+72,944
+12,000
+28.1800
+338,160
+TRUST-MD SB
+SIRIUS SATELLITE RADIO INC
+Total Equities& Options
+TOTAL EQUITIES
+SIRI
+CASH
+1,000
+5.6700
+5,670
+$4,099,689
+$4,099,689
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 31, 2005
+THROUGH
+January 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+December 30, 2005
+ESTIMATE
+NNUAL INCOM
+1,200
+.....
+2,800
+1,050
+8,400
+5,840
+76,296
+1,029
+3,773
+11,484
+$111,872
+$111,872
+CURRENT
+YIELD (%)
+3.0211
+7.1138
+1.9203
+7.8285
+6.8113
+2.2941
+3.4106
+5.1725
+3.3960
+027
+
+
+5 or 8
+Bear, Steams & Co. Inc.
+383 Madison Avenue
+New York. New York 10179
+Your Portfolio Holdings (continued)
+YOUR PORTFOLIOHOLDINGSESTIMATED ANNUAL INCOME
+YOUR PRICED PORTFOLIOHOLDINGS
+Transaction Detail
+MONEY FUND ACTIVITY
+12/31/05
+01/0306
+01/03/06
+01/03/06
+01/17/06
+01/31/06
+TOTAL
+TRANSACTION
+BOUGHT
+REINVEST
+DIVIDEND
+BOUGHT
+DESCAIPTION
+OPENINGBALANCE
+DREYFUS CASH MANAGEMENT-CL
+VSTITUTIONAL SHARE
+DREYFUS CASH MANAGEMENT-CLA
+INDEND A SEES T
+DREYFUS CASH MANAGEMENT-CLA
+DREYFUS CASH MANAGEMENT-CL
+INSTITUTIONAL SHARES
+CLOSINGBALANCE
+SYMBOLCUSIP
+DICXX
+DICXX
+DICXX
+DICXX
+$137,612
+$4,727,506
+QUANTITY
+618,813.54
+5,250
+2,091.88
+1,661.60
+627,817.02
+027
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 31, 2005
+THROUGH
+January 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+December 30, 2005
+PRICE
+1.0000
+DEBIT AMOUNT
+5,250.00
+2.091.88
+CREDIT AMOUNT
+2,091.88
+1.0000
+1.661.60
+$-9,003.48
+$2,091.88
+
+
+6 of 8
+Transaction Detail (continued)
+DIVIDENDS
+
+01/13/06
+
+TOTAL
+RAMCO GERSHENSON PROPERTIES
+ASH DI
+GLENBOROUGH REALTY TRUST IN
+© 01/01/06 PAY 01/13/
+GLIMCHER REALTY TRUST-SBİ
+CASH DIV ON
+2000 SHS
+SYMBOL/CUSIP
+RPT
+STOP
+****** End of Statement******
+QUANTITY
+2,000
+RATE (S)
+0.3500
+027
+DEBIT AMOUNT
+EARED THROUGH
+IOLLY OWNED SUBSIDIA
+Bear, Steams Securities Corp.
+One Metratech Center North
+Brooklyn, New York 11201-3859
+JEFFREY EPSTEIN
+STATEMENT PERIOD December 31, 2005
+THROUGH
+January 31, 2006
+ACCOUNT NUMBER
+TAXPAYER NUMBER On File
+December 30, 2005
+CREDIT AMOUNT
+5,250.00
+700.00
+961.60
+$6.911.60
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/1f6af172de2e7603469dd31ff6c7d4bdad605648f2ce4c82e2acccb0e8903255.receipt.json b/vision-fixhub/ds9-unparsed-06/1f6af172de2e7603469dd31ff6c7d4bdad605648f2ce4c82e2acccb0e8903255.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9f338a637cb80921e6597f6e1fdb1e3cdfc317e9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1f6af172de2e7603469dd31ff6c7d4bdad605648f2ce4c82e2acccb0e8903255.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -10034,
+  "dataset": "marble-joined",
+  "doc_id": "1f6af172de2e7603469dd31ff6c7d4bdad605648f2ce4c82e2acccb0e8903255",
+  "engine": "marble-apple-vision",
+  "event_count": 103,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "99a760ff9b027d45e7a136b7be7aaffc1e7ac1eb86512995758a0b76723b8bb7",
+  "output_sha256": "043a697b1451129225fd5b489aa3155ab9bb4ac1a37e07144ad6c7088e8c00ef",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1f8455ed9653bcee41beefbaa7271e11a3a6f7e8ee2cbc646dcf1105838c345f.md b/vision-fixhub/ds9-unparsed-06/1f8455ed9653bcee41beefbaa7271e11a3a6f7e8ee2cbc646dcf1105838c345f.md
new file mode 100644
index 0000000000000000000000000000000000000000..8cab615163fd442e3f38a330d98023145ebaac44
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1f8455ed9653bcee41beefbaa7271e11a3a6f7e8ee2cbc646dcf1105838c345f.md
@@ -0,0 +1,81 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80119-KAM Doe |. Epstein Response/Reply (Other)
+Date: Thu, 11 Feb 2010 16:51:23 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Pike, Michael on 2/11/2010 at 11:51 AM EST and filed on 2/11/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 467
+Doe | Epstein
+9:08-cv-80119-KAM
+Jeffrey Epstein
+Docket Text:
+RESPONSE/REPLY to [456] Response to Motion Epstein's Reply to Jane Doe #3's Response to
+Epstein's Motion for Sanctions by Jeffrey Epstein. (Attachments: # (1) Exhibit A, # (2) Exhibit B,
+# (3) Exhibit C)(Pike, Michael)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+ahorowitz@sexabuseattorney.com
+Bradley James Edwards
+brad@pathtojustice.com, beth@pathtojustice.com
+Isidro Manuel Garcia
+isidrogarcia @bellsouth.net
+Jack Alan Goldberger
+jagesq@bellsouth.net, nalanis@agwpa.com
+Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com,
+sas(@searcylaw.com, vat@searcylaw.com
+Jeffrey Mare Herman jherman@hermanlaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com, mestrada@podhurst.com
+
+
+Michael James Pike MPike@bclclaw.com, bobbie@bclelaw.com, jcadwell@bclelaw.com
+Paul G. Cassell cassellp@law.utah.edu
+Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com
+Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton@podhurst.com,
+mestradal@podhurst.com
+Robert Deweese Critton, Jr rcrit@belclaw.com, bobbie@belclaw.com
+Stuart S. Mermelstein ssm@sexabuseattorney.com, jarbour@sexabuseattorney.com,
+Irivera@sexabuseattorney.com
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+Martin G. Weinberg
+20 Park Plaza
+Boston, MA 02116
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=2/11/2010] [FileNumber=7250130-0
+][305c7d0b75b0cec4e8329cec07e429ed5d105f9ef3010ed98d19133433acd46c865
+8331e03c8e26d6483ce9c62f8739746ee4b692ed07c25bce0cleec9f686fa]]
+Document description:Exhibit A
+Original filename:n/a
+Electronic document Stamp:
+[STAMP dcecfStamp_ID=1105629215 [Date=2/11/2010] [FileNumber=7250130-1
+][042d871c1c076655d7c8d8ea60afa1c53b65370f08e63b0e0ac0b4f31бас3е624f3
+d4cefedd3f4288530fae7a4c9f17e4c2ebbda9ac377f0a8b9efc08550d0e8]]
+Document description:Exhibit B
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=2/11/2010] [FileNumber=7250130-2
+][797efbalaб33бс905fb9a2fa41eба786fae2e52fa2c9e768a6d9de64458605dbadb
+d55738362875d8a034eb31df496bbe7af57375ae0847c45ae0b246b7bcf7a]]
+Document description:Exhibit C
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=2/11/2010] [FileNumber=7250130-3
+] [9446abd5983a27492736f433197159c6b5a8befbcafa9bacdd8c9e6d8524f483441
+f20f05eb1c4e726cb13e547bb4a5c40b32acd44095ad627391502744e7e65]]
diff --git a/vision-fixhub/ds9-unparsed-06/1f8455ed9653bcee41beefbaa7271e11a3a6f7e8ee2cbc646dcf1105838c345f.receipt.json b/vision-fixhub/ds9-unparsed-06/1f8455ed9653bcee41beefbaa7271e11a3a6f7e8ee2cbc646dcf1105838c345f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b12ec5efb9603b9b320e6b4ca8a78eb8fad4a0d1
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1f8455ed9653bcee41beefbaa7271e11a3a6f7e8ee2cbc646dcf1105838c345f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "1f8455ed9653bcee41beefbaa7271e11a3a6f7e8ee2cbc646dcf1105838c345f",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "70dfe0521ef6696cf72fcf6ed7796d0060848f1702177930637d43a07d6753f9",
+  "output_sha256": "c0e9533af5703d8b935d025f1bdb0fd71081be47a43642ee4a12eeaf50f2a1cb",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/1fdfc0d05a614fe2f096fde68cd7ff3c971ee255cac5e5a731bf76aad6c8cc72.md b/vision-fixhub/ds9-unparsed-06/1fdfc0d05a614fe2f096fde68cd7ff3c971ee255cac5e5a731bf76aad6c8cc72.md
new file mode 100644
index 0000000000000000000000000000000000000000..ba1491d84bdd60257106ae4b2fa8767d8beb7332
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1fdfc0d05a614fe2f096fde68cd7ff3c971ee255cac5e5a731bf76aad6c8cc72.md
@@ -0,0 +1,170 @@
+JUN-28-2010 07:09
+P.Ø3
+AO 88A (ev. U1/09) Subpoena to Testify al a Deposion or la Prodace Documents in a Civil Acciona
+UNITED STATES DISTRICT COURT
+for the
+Southern District of Florida
+)
+JANE DOE
+Plaintif
+)
+)
+JEFFREY EPSTEIN
+Defendant
+Civil Action No. 0B-80893CIV-MARRA/JOHNSO
+(IF the action is pending in toother district, state where:
+SUBPOENA TO TESTIFY AT A DEPOSITION
+OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION
+To: Faderal Bureau of Investigation - Fu
+FBI - Miami Field Office Legal Dept, 16320 NW 2nd Ave., N. Miami Beach, FL 33189
+• Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a
+deposinon to be taken in this civil action. If you are an organization that is nor a party in this case, you must designate
+one or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf
+about the following matters, or those set forth in an attachnent:
+•
+Place: Farmer, Jaffe, Weissing, ef al.
+425 North Andrews Avenue, Sulte 2
+Date and Time:
+07/08/20102:00 pm
+EL Lauderdale. EL 3330.-
+The deposition will be recorded by this method: -
+/ Production: You, or your representatives, must also bring with you to the deposition the following documents
+iccironically stored information, or objcets, and permit their inspection, copying, testing, or sampling of th
+Any and All documents, photographs, videos, memos, or any other objects or items that reference, depict, or in any way
+elate directly to Jane Doe (Jane Doe's name and DOB are in cover letter to protect her identity), including but not limita
+to all things obtained during any criminal investigation of Jeffrey Epstein, his co-conspirators or his former employee
+The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule
+45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are
+Date:
+06/25/2010
+CLERK OF COURT
+OR
+Signature of Clerk or Deply Clerk
+Aroney's signature
+The namc, address, e-mail, and telephone number of the attorney representing (hame of party)
+Jane Doe
+, who issues or requests this subpoena, are:
+Bradiey Edwards, Esq., Farmer, Jaffe, Weissing, e1 al., 425 North Andrews Avenue, Sulte 2. Ft. Lauderdale, FL. 33301
+(954) 524-2820, brad@pathtojustice.com
+
+
+07:09
+P.04
+1D88A (Rev. 01109) Subpadad to Testify «s a Deperition or bo Prouce Documents in a Civil Actlon (Page 2)
+Civil Action No. 08-80B93CIV-MARRA/JOHNSO
+PROOF OF SERVICE
+(This section should not be filed with the court unless required by Fed, R. Civ. P. 45.)
+This subpoena for (name of individual and fitle, if any)
+was received by me on (dare)
+O i personally served the subpoena on the individual at (place)
+ola (raie)
+; 0г
+7 I left the subpoena at the individual's residence or usual place of abode with (name)
+, a person of suitable age and discretion, who resides there.
+00 (dale)
+"and mailed a copy to the individual's last known address; or
+• i served the subpocna on (name of indistinal)
+, who is
+designated by law to accept service of process on behalf of (name of organisation)
+oD (dase)
+; or
+;or
+• I returned the subpoena unexecuted because
+• Othics (specif):
+Unless the subpoena was issued on behalf of the United States, or one of its officers or ageuts, I have also
+tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of
+•
+My fees are $
+for travel and S
+for services, for a total of s
+0.00
+I declare under penalty of perjury that this information is true.
+Date:
+---
+Server's signature
+Printed name and sitte
+Server's address
+Additional information regarding attempted service, etc:
+
+
+su, JN-28-2818 87:09
+P.05
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE.
+Plaintiff,
+CASE NO. OB-CV-80893-CIV-MARRAJOHNSON
+Vs.
+JEFFREY EPSTEIN, et al.
+Defendant.
+Related Cases:
+08-80119, 08-80232, 08-80380, 08-80381,
+08-80994, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+PRIVACY WAIVER
+ane Doe), hereby consent to release of information that the
+FBI is maintaining about me in connection with its criminal investigation of Jeffrey
+Epstein and specifically consent to release of the information under the Privacy Act,
+Title 5, United States code, Section 552a. I hereby authorize disclosure to my attorney
+in the civil action against Jeffrey Epstein. My attorney is Bradley Edwards, Esq.
+You can send the materials to Mr. Edwards at: Farmer, Jaffe, Weissing,
+Edwards, Fistos & Lehrman, P.L., 425 North Andrews Avenue, Suite 2, Ft. Lauderdale,
+FL, 33301.
+STATE OF FLORIDA
+COUNTY OF Brianal
+
+
+07:10
+P.06
+CASE NO: 08-CV-B0119-MARRA/JOHNSON
+The foregoing instrument was acknowledged before me this
+day of
+, 2010 byl
+who is personally known to me of who has
+_ as identification and who did/did
+march
+produced
+not take an oath.
+Notary Public
+My. Commission EXplies Notary Puk: Slate of Foresta
+Steven Jathe
+My Commission D0537838
+Expires 04/06/2010
+2
+TOTAL P.06
+
+
+07:09
+P.02
+Farmer, Jaffe, Weissing,
+Edwards, Fistos & Lehrman, P.L.
+Out Tam
+L Class Acthan
+Personal injury
+Wrongrul Death
+Commercial Litrgation
+June 25, 2010
+VIA FACSIMILE (305) 787-6124 (S Pages)
+FBİ - Miami Field Office Legal Depr.
+16320 NW 2nd Ave.
+N. Miami Beach, FL 33169
+Re:
+Jane Doe |. Epstein / Case Number 08-cv-80893-MARRA/JOHNSON
+Subpoena for Documents
+Dear N
+1 am writing with regard to the subpoena refcrenced above to provide a statement which
+Alexciter demares of sexual abuse ched po her by defendan elecy pen weat
+she was a minor. The records soughr go directly to proving her claims.
+Attached plense find a copy of the subpoena and a Privacy Waiver executed by my client.
+Jane Doe's real name is:
+her dare of birth is
+and her partial social security
+number is 593-70-xXXX.
+If I can provide any further information, please do not hesitate to call.
+Very truly yours,
+Bradley Edwards
+BJE/w
+Attachments as stated
+425 North Andrews Avenue, Suite 2, Fort Lauderdale, Florida 33301
+954.524.2820 office 954.524.2822 fax
+...
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/1fdfc0d05a614fe2f096fde68cd7ff3c971ee255cac5e5a731bf76aad6c8cc72.receipt.json b/vision-fixhub/ds9-unparsed-06/1fdfc0d05a614fe2f096fde68cd7ff3c971ee255cac5e5a731bf76aad6c8cc72.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3c581c7622e620392e9ad27024e8dc2ec268010f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/1fdfc0d05a614fe2f096fde68cd7ff3c971ee255cac5e5a731bf76aad6c8cc72.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -97,
+  "dataset": "marble-joined",
+  "doc_id": "1fdfc0d05a614fe2f096fde68cd7ff3c971ee255cac5e5a731bf76aad6c8cc72",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "14605a82a3353b8c64c806ccf5c5bda436937ae75f9a605a7861f81ae142cf1b",
+  "output_sha256": "219ae311ffaa7bc34a101aec882c5130d2b11754c6ec4f3495ae3df802668f56",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/20500fcacda72d661837ec4594127844350b8cba3009eea10878dc3dec32eb76.md b/vision-fixhub/ds9-unparsed-06/20500fcacda72d661837ec4594127844350b8cba3009eea10878dc3dec32eb76.md
new file mode 100644
index 0000000000000000000000000000000000000000..a88f4df60d2a187a07f6d6020c2a81fc7085235a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/20500fcacda72d661837ec4594127844350b8cba3009eea10878dc3dec32eb76.md
@@ -0,0 +1,687 @@
+Questions or Changes?
+attwireless.com
+: ToliFe 1 866 293-4634
+611 from your wireless phone
+TTY users - 1 866 4-AWS-TTY
+SUMMARY OF MONTHLY CHARGES FOR ACCOUNT
+Previous
+Payments
+Balance
+Received
+-23.96
+0.00
+Account
+Adjustments
+0.00
+Your billing cycle ended on September 11, 2004
+Current Monthly Charges
+Subscriber Adjustments
+Monthly Service
+Monthly Usage
+Charges
+Credits
+Taxes, Surcharges & Regulatory Fees
+Total Current Monthly Charges DUE UPON RECEIPT
+TOTAL AMOUNT DUE
+Balance
+Forward
+-23.96
+Date of Invoice: September 12, 2004
+Current Monthly
+Charges
+23.96
+Total
+Amount Due
+0.00
+0.00
+0.00
+18.24
+5.72
+0.00
+0.00
+23.96
+0.00
+PLAY JUMBLE, THE GREAT SCRAMBLED WORD GAME, ON YOUR
+PHONE FOR FREE!*
+DOWNLOAD TODAY AND ENJOY 5 FREE* PLAY SESSIONS.
+AFTER YOUR 5 FREE PLAY SESSIONS, YOU CAN SUBSCRIBE FOR
+JUST $2.99/MONTH AND ENJOY OVER 4,000 MIND-BENDING
+PUZZLES, LIVE HIGH-SCORE COMPETITIONS, AND MORE.
+VISIT GAMEROOM.ATTWIRELESS.COM FOR MORE INFO
+*STANDARD DATA CHARGES APPLY FOR ALL DOWNLOADS.
+AT&T WIRELESS APPRECIATES YOUR BUSINESS
+Account Name: |
+Note:
+We Print on
+Front and Back
+(see reverse - signature required).
+Date Due
+UPON RECEIPT
+Service #
+Account #
+Total
+Amount Due
+0.00
+Chack here for change.
+Amount
+Paid
+AT&T WIRELESS
+PO BOX 8229
+AURORA IL 60572-8229
+
+
+Recurring Electronic Fund Transfer (REFT): To enroll: sign below, check the REFT box on the reverse side and
+remit with this month's payment. Keep paying your bill until your statement indicates "Do Not Pay". REFT
+Agreement: I authorize my financial institution to deduct the amount of my monthly wireless phone bill from the
+account associated with the enclosed check and remit payment to AT&T Wireless. This authority will be effective
+until I notify AT&T Wireless to terminate it. I agree that I may be assessed a service charge (up to $20) or late fee
+or both if a payment is returned by my bank. For more information visit attwireless.com/ocs or call 1 866 293-4634.
+Please keep a copy of the form below and this REFT Agreement for your records or retain a copy of the blank form
+from next month's invoice.
+Questions? We can help: AT&T Wireless appreciates your business and welcomes the opportunity to assist you.
+As part of our commitment to you, we are always adding new calling plans and promotions to match your individual
+needs. Visit our website at attwireless.com or contact Customer Care by dialing 611 from your wireless phone or 1
+866 293-4634. ¿ Sabías que también ofrecemos servicio al cliente en tu idioma? Marca 611 desde tu teléfono
+inalámbrico ó 1 866 293 4634 desde cualquier teléfono y oprime el *.
+Driving Wireless Safety: Your wireless phone gives you the freedom and flexibility to stay in touch when you
+travel, but don't let a phone call distract you from driving safely. Use hands-free device if allowed or required by
+law. Call Carefully, Arrive Safely.
+AT&T Wireless Processing Fees: Accounts suspended for non-payment will be subject to a $25 reactivation fee
+per line and may be assessed a security deposit prior to reinstatement. Checks returned for non-sufficient funds will
+be charged up to a $20.00 fee.
+Local Tax: Local taxes are based on local government boundaries, the address information you provide for your
+may also use the form below to notify us of any change to your taxing address. Thank you for your cooperation.
+Early Termination Fee (ETF): If you cancel service before your contract end date (including if you switch your
+wireless number to another carrier), you will be charged an Early Termination Fee of up to $200.
+Please Send Correspondence To:
+AT&T Wireless Next Generation Correspondence
+P.O. Box 68056
+Anaheim Hills, CA 92817-8056
+0.000018221.3
+count ame and ranse an espires clearly and check the box on the reverse side. Please contact Customer Care to change the
+Name and transfer Financial Responsibility.
+New Billing Address
+City
+State
+Zip
+Home Phone (
+Work Phone (.
+If your billing address is NOT your Tax Address*, please enter the Tax Address below. (Multi-line accounts should attach a list of each wireless number
+and the respective Tax Address.)
+New Tax Address*
+Wireless Number (
+City
+State
+Zip
+Inder Federal laws, your Tax Address must be: your primary place of use, your residential or business address, and located within AT&T Wireless
+ensed service area. Non-business customers on AT&T Digital One Rate, Regional Advantage or Shared Advantage plans must use their resident
+address as their tax address.
+Recurring Electronic Fund Transfer (REFT) Enrollment. Please read the agreement on the top portion of this page, sign below and check
+the "REFT Registration" box on the reverse side.
+Financial Account Holder Signature
+6.1 - 3G
+• • I do not wish to receive email notlication of special ollers avallable to AT&T Wireless customers.
+
+
+APPLY NOW FOR THE AT&T UNIVERSAL CARD!
+CALL 1-800-426-3430 TODAY!
+*ENJOY A GREAT LOW APR ON BALANCE TRANSFERS
+*OPTIONS TO ENROLL IN CASH BACK OR REWARDS PROGRAM
+*ALL CARDMEMBERS ENJOY SPECIAL CALLING BENEFITS
+*NO ANNUAL FEE CREDIT CARD
+ACCOUNT DETAILS
+Detail of Other Account Charges
+Item Description
+1 30 DAY BALANCE EXPIRATION
+Total of Other Account Charges
+Current Subscriber Monthly Charges and Credits
+Subscriber Number
+Subscriber Name
+Total Current Subscriber Monthly Charges and Credits
+Total Current Monthly Charges
+SUMMARY OF CURRENT ACTIVITY
+Monthly Service Charges
+Item Description
+Service Dates
+1 CALL WAITING
+08/12/04 - 09/11/04
+2 CALLER ID
+08/12/04 - 09/11/04
+3 GO PHONE $53.98 REPLENISHMENT
+08/12/04 - 09/11/04
+4 THREE WAY CALLING
+08/12/04 - 09/11/04
+5 GO PHONE UNLIMITED NIGHTS AND WEEKENDS
+08/12/04 - 09/11/04
+6 DETAIL BILLING
+08/12/04 - 09/11/04
+Total Monthly Service Charges
+Monthly Usage Charges
+Item Description
+1 UNLIMITED N/WKND MIN
+2 MMODE/DATA USAGE
+3 AIRTIME MINUTES
+4 CALL WAITING
+5 MESSAGE RETRIEVAL
+Onty Used
+414 MIN
+465 KB
+151 MIN
+11 EVT
+7 EVT
+18.
+18.
+23.96
+0.00
+0.00
+0.00
+13888
+
+SUMMARY OF CURRENT ACTIVITY - CONTINUED
+Monthly Usage Charges - Continued
+Item Description
+6 DROP CALL CREDIT
+Total Monthly Usage Charges
+1,024 Kilobytes (KB) = 1 Megabyte (MB)
+Onty Used
+TOTAL CHARGES FOR
+DETAIL OF CURRENT ACTIVITY
+VOICE USAGE FOR
+Number
+Called
+Calls To
+0.00
+18.24
+18.24
+Item Date Time
+1 08/12 01:32A
+Onty
+Used Rate Description
+UNLIMITED N/WKND MIN
+2A
+иттт..
+1
+
+MINU
+
+N
+!!!!
+
+
+VOICE USAGE FOR
+Number
+Item Date Time
+Called
+50 08/14 03:35A
+51
+08/14 11:39A
+08/14 11:49A
+3 08/14 12-44P
+54
+08/14 12:45P
+08/14 01:01P
+08)
+14 01:1
+57
+08/14 01:12P
+59
+
+60
+08/14 01:36P
+08/14|
+01:43P
+62
+08/14 02:41P
+08/14 83:190
+08 12 04
+65 08/14 04:38P
+18/14 05:34F
+08/14 05:52P
+Calls To
+INCOMING
+LAKE WORTH FL
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+NPALMBEACH F
+LMBEACH FI
+LAKE WORTH FL
+LAKE MORTH
+WEST CHEL
+WPALMBEACH FL
+- Continued
+Qnty
+Used Rate Description
+5 MIN
+UNLIMITED N/WKND MIN
+UNLIMITED
+N/WKND
+2 MIN
+I MIN
+I MIN
+2MIN
+WKN I
+UNLIMITED N/WKND
+UNLIMITED WIND
+UNLIMITED N/WKND
+WPALMBEACH FL
+WESTENCH FE
+AMIN
+4 MIN
+SMIN
+SMIN
+SMIN
+UNLIMITED NIMAN
+N/W
+UNLIMITED N/WKND
+D N/WKNI
+INLIMITED NWIN
+UNLIMITED N/WKND
+626810000°0
+
+002188606119-10662T020000
+99 98
+5õõ₫
+
+
+VOICE USAGE FOR
+Number
+Item Date Time Called
+114 08/15 03:25P (5611628-2190
+115 08/15 03:47P
+116 08/15 04:00P
+117 08/15 06:27P
+118 08/15 06:33P
+119 08/15 06:38P
+20 08/15 06:415
+21 08/15 07:078
+122 08/15 07:07P
+- Continued
+Used Rate Description
+1 EVT
+MESSAGE RETRIEVAL
+2MIN
+UNLIMITED N/WKND MIN
+5MIN
+NAMITE AWE AL
+NLIMI
+UNLIMITED N/WKND MIN
+MESSAGE RETRIEVAL
+JNLIMITED NKND MIN
+3MIN
+UNLIMITED N/WKND MIN
+123 08/15 07:12P
+124 08/15 08:31P
+08/15 09:05P
+25N338898810328580811205966522266=§8848028359309
+10:38P
+175
+08.
+10:02P
+Calls To
+WPALMBEACH FL
+PALMBEACH
+PALMBEACH I
+WPALMBEACH FL
+INCOMING
+INCOMING
+NPALMBEACH FL
+NCOMING
+INCOMING
+WPALMBEACH FL
+FLAUBERBL FE
+INCOMING
+COMIN
+COMIN
+2MIN
+CALL WAITING
+UNLIMITED N/WKND MIN
+2MIN
+UNLIMITED N/WKND
+INLIMITED N/WKND
+JNLIMIT
+MIN
+OMI
+
+B000000009998 28008
+
+
+AIRI
+
+
+SMIN
+UNLIMITED
+MIN
+
+
+VOICE USAGE FOR
+Number
+Item Date Time
+Called
+Calls To
+176 08/18 10:03P
+177 08/18 10:04P
+178 08/18 10:08P
+179 08/18 10:09P
+180 08/18 10:11P
+181 08/18 10:24P
+182 08/18 10:24P
+183 08/18 10:30P
+184 08/18 10:34P
+185 08/18 10:35P
+186 08/18 10:44P
+BB 08/19 04 35F
+88 08/19 0
+189 08/19 09:38P
+190 08/19 09:39P
+191 08/19 09:42P
+192 08/19 09.458
+193 08/19 09:46P
+194 08/19 09:47P
+195 08/19 09:50P
+196
+08/19
+198
+08/19
+10:44P
+193
+:59P
+08/19
+U8/
+11:00P
+199
+200
+08/19
+:53P
+203 08/20
+
+08/20 03:42A
+205
+08/
+206
+08.
+:424
+03:45A
+208 08/20 04:024
+209 08/20 04:03A
+08/20 04:024
+1 04:08A
+08/20 04:41A
+15
+102.225
+08/20 02:49P
+216 08/20 02:51P
+217
+218
+
+219 08/20 04:29P
+220
+221
+08/20
+1 04:37P
+08.
+/20
+10:22P
+222 08/20
+10:23P
+223 08/20 10:55P
+08/20
+0:35.
+08/20 11:25P
+
+
+
+:33A
+$85
+INCOMING
+PALMBEACH F
+INCOMING
+LAKE WORTH FL
+INCOMING
+OYNIO
+OYNTONBCH FI
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FLI
+WPALMBEACH FL
+- Continued
+Qnty
+Used Rate Description
+1 EVT
+CALL WAITING
+UNLIMITED N/WKND MIN
+3MIN
+UNLIMITED
+NAND MIN
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND MIN
+1 EVI
+ALL WAILIN
+2 MIN
+NLIMITE
+N/WKND MIN
+UNLIMITED N/WKND MIN
+4 MIN
+UNLIMITED N/WKND MIN
+EMIN 8.0S AIRTINE MINUTES
+UNLMITED
+N/WKND
+N/WKND
+WPALMBEACH FL
+WPALMBEACH
+FL
+BOYNTONBCH
+WPALMRFA
+LAKE WORTH
+INCOMING
+WPALMBE
+MPAIMP
+WPALMBEA
+FTLAUD
+FTLA
+INCO
+MIN
+ICOMINO
+COMINI
+INCOMING
+FTLAUDERDL FL
+INCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+LAKE WORTH FL
+WPALMBEACH
+FL
+WPALMBEA
+WPALMBEACH FL
+WPALMBEACH FL
+AKE WORTH F
+COMIN
+LAKE WORTH FL
+COMIN
+COMIN
+AKE WORTH F
+COMING
+LAKE WORTH FL
+ORLANDO
+NPALMBEACH FI
+INCOMING
+MIN
+1 MIl
+3MIN
+MIN
+UNLIM
+4 MIN
+SMIN
+8 MIN
+3MIN
+6MIN
+6MIN
+1
+1 EVT
+2 MIN
+2MIN
+1MIN
+7MIN
+2MIN
+8MIN
+2MIN
+UNLIM
+UNLIM
+0.09
+0000
+2000
+8282
+Page |of 6
+VOICE USAGE FOR
+Number
+Item Date Time
+Called
+235 08/21 09:52P
+236 08/21 09:53P
+237 08/21 09:55P
+1:06₽
+240 08/21 11:46P
+242 08/22 01:00A
+244 08/22 02.284
+245 08/22 11:54A
+247 08/22 06 11P
+248 08/22 07:19P
+Calls To
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+ORANDO CHIE
+INCOMING
+ORLANDO FL
+WPALMBEACH FL
+COMING
+ORLANDO FI
+- Continued
+Qnty
+Used Rate Description
+UNLIMITED N/WKND MIN
+SMIN
+UNLIMITED N/WKND MIN
+1 EVT
+26 MIN
+1 EVT
+CALL WAITING
+MIN
+MIN
+SMIN
+(ND MIN
+UNLIMITED N/WKND MIN
+EMIN
+3MIN
+EMIN
+NO MIN
+UNLIMITED N/WKND MIN
+UNAMITE WANN
+UNLIMITED N/WKND MIN
+JNLIMITE
+ED
+N/
+WKND
+MIl
+08.
+124
+8800
+NENREONGNEBAASI
+888F5555-55555
+
+฿8.068
+ORLAND
+WPALM
+IKE WOR
+WPALMB
+BEACH
+NOOMIN
+INCOMING
+INCOMING
+INCOMING
+LAKE WORTH FL
+INCOMING
+NOOMING
+COMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+IN
+IN
+0000
+00000
+00900
+MIN
+0000
+8088
+00000
+8ö888
+00000
+88888
+410 -
+3MIN
+1 EVT
+1EVT
+2 MIN
+3MIN
+2 MIN
+3MIN
+4 MIN
+7MIN
+MIN
+1 EVT
+OoOO
+AIRTIME
+09
+AIRTIME
+INLIMI
+UNLIMITE
+UNLIMI
+UNLIMITED N/WKND MIN
+0000
+88NS
+
+
+→ ATST Wireless
+VOICE USAGE FOR
+Number
+Item Date Time
+Called
+293 08/26 12:50A
+TOTAL VOICE USAGE FOR
+Calls To
+WPALMBEACH FL
+- Continued
+Qnty
+Used Rate Description
+3 MIN
+UNLIMITED NWKND MIN
+DATA USAGE FOR
+Item Date
+2 08/16
+3 08/17
+4 08/23
+5 08/24
+TOTAL DATA USAGE FOR
+Onty Used
+4 Kg
+281 KB
+31 KB
+83 KB
+66 KB
+Charge Description
+MMODE BATA USAGE
+MMODE DATA USAGE
+MMODE DATA USAGE
+MMODE/DATA USAGE
+
+13.59
+281
+0.66.
+4.65
+*** THIS SPACE INTENTIONALLY LEFT BLANK ***
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/20500fcacda72d661837ec4594127844350b8cba3009eea10878dc3dec32eb76.receipt.json b/vision-fixhub/ds9-unparsed-06/20500fcacda72d661837ec4594127844350b8cba3009eea10878dc3dec32eb76.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9374dedbe596018cd99fcb7887d0197dcb5d93bd
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/20500fcacda72d661837ec4594127844350b8cba3009eea10878dc3dec32eb76.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1286,
+  "dataset": "marble-joined",
+  "doc_id": "20500fcacda72d661837ec4594127844350b8cba3009eea10878dc3dec32eb76",
+  "engine": "marble-apple-vision",
+  "event_count": 26,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "664dfed45d9288d51b414d3745ac11113e6b8385870d63d5ca86e939a7f3421f",
+  "output_sha256": "132e07f5e380e8e4546636798fc47730d9a74adf16485739b5d55d5e9252c32f",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/20c53b50e4d5ce389fc7e39f8d299f22d8875dbba49b82a150ef299f0f1e6565.md b/vision-fixhub/ds9-unparsed-06/20c53b50e4d5ce389fc7e39f8d299f22d8875dbba49b82a150ef299f0f1e6565.md
new file mode 100644
index 0000000000000000000000000000000000000000..9323554280244908adb55b8b7c34513a038c7533
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/20c53b50e4d5ce389fc7e39f8d299f22d8875dbba49b82a150ef299f0f1e6565.md
@@ -0,0 +1,17 @@
+From: "
+￾ (USAFLS)" </O=USA/OU=L/CN=RECIPIENTS/cN=|
+To:
+Subject: FW: Possible Retainer for a Federal Criminal Investigation/Prosecution
+Date: Mon, 16 Apr 2007 21:24:47 +0000
+Importance: Normal
+Hi
+-- Here are the questions that I have raised for the potential expert. Thank you.
+The types of issues that I am hoping the expert can address include:
+1. Why victims do not report sexual abuse and, when discovered, why it may take several sessions for a victim
+to disclose all of the sexual activity that took place.
+2. Different types of paraphilia -- in particular, describing a predator's interest in post-pubescent children (many
+people are asking why we should prosecute someone who didn't go after really young children).
+3. Traits of psychopathy.
+4. Effects of abuse on victims.
+Thank you.
+Assistant U.S. Attorney
diff --git a/vision-fixhub/ds9-unparsed-06/20c53b50e4d5ce389fc7e39f8d299f22d8875dbba49b82a150ef299f0f1e6565.receipt.json b/vision-fixhub/ds9-unparsed-06/20c53b50e4d5ce389fc7e39f8d299f22d8875dbba49b82a150ef299f0f1e6565.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a4552b3508770a03ecd91752edd1c96705afed73
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/20c53b50e4d5ce389fc7e39f8d299f22d8875dbba49b82a150ef299f0f1e6565.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "20c53b50e4d5ce389fc7e39f8d299f22d8875dbba49b82a150ef299f0f1e6565",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "606becff00a8cb24509c325ecbbc061745859b931bae7b2f430322a2d3a318a5",
+  "output_sha256": "4d92ea7310845be8287fa7b25a0f7671e3ceb1d80d40c6371b75a1f76c50997d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/20e49dceb7fcd153ecb73432d70e134a8e19f461cafe3b9cd3cfa78c11dbdf4e.md b/vision-fixhub/ds9-unparsed-06/20e49dceb7fcd153ecb73432d70e134a8e19f461cafe3b9cd3cfa78c11dbdf4e.md
new file mode 100644
index 0000000000000000000000000000000000000000..6b708eb9d01850bce39f100e2fe5e28bccb8b3bf
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/20e49dceb7fcd153ecb73432d70e134a8e19f461cafe3b9cd3cfa78c11dbdf4e.md
@@ -0,0 +1,9 @@
+Subject: Yesterday's Letter
+Date: Thu, 21 Jan 2010 19:59:14 +0000
+Importance Normal
+* On second thought my letter yesterday went too far in one respect. So that there is no misunderstanding of the
+last paragraph of yesterday's letter, our concern is not that the attorney representative in fact has used the threat of a
+reach as leverage to get his fees, only that there exists the legitimate concern that the agreement could be so used an
+he reality that any concern about such use significantly and unfairly burdens Mr Epstein's right to resort to the courts t
+resolve outstanding legal issues regarding the criteria for payment and the amount of payment owed. I hope this clarifies
+our concern in this one area. Thanks
diff --git a/vision-fixhub/ds9-unparsed-06/20e49dceb7fcd153ecb73432d70e134a8e19f461cafe3b9cd3cfa78c11dbdf4e.receipt.json b/vision-fixhub/ds9-unparsed-06/20e49dceb7fcd153ecb73432d70e134a8e19f461cafe3b9cd3cfa78c11dbdf4e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2a085b9c2d27e7e08b1cef7d5d0c022b49aa1e63
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/20e49dceb7fcd153ecb73432d70e134a8e19f461cafe3b9cd3cfa78c11dbdf4e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "20e49dceb7fcd153ecb73432d70e134a8e19f461cafe3b9cd3cfa78c11dbdf4e",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "d63a595e445159bd64cbbd4b8d52fe5da6b8bd17163ad99477c70a48e5905d0a",
+  "output_sha256": "c430549aca572d3286cea9417e0a658f0d2a27779f478c0705acd23caef08e84",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/215290f05fa6896eb363ffd35d2613d7197ed168d74a72a4281bd68001ca86f3.md b/vision-fixhub/ds9-unparsed-06/215290f05fa6896eb363ffd35d2613d7197ed168d74a72a4281bd68001ca86f3.md
new file mode 100644
index 0000000000000000000000000000000000000000..2da2fec0e40d7a6fcfc105c9e2047bf41fdf4853
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/215290f05fa6896eb363ffd35d2613d7197ed168d74a72a4281bd68001ca86f3.md
@@ -0,0 +1,1745 @@
+Entered on FLSD Docket 09/02/2010 Page 1 of
+Page I
+UNITED STATES BANKRUPTCY COURT
+SOUTHERN DISTRICT OF FLORIDA
+1
+2
+3
+4
+CASE NO.: 09-34791-BC-RBH
+In Re:
+7 ROTHSTEIN ROSENFELDT ADLER, P.A.,
+Debtor.
+8
+9
+10
+11
+MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM TRUSTEE 12
+12 PURSUANT TO DOCUMENT PRODUCTION PROTOCOL ESTABLISHED 13
+BY DE4672 (30T); AMENDED MOTION FOR PROTECTIVE ORDER
+(819)
+14
+15
+16
+August 4, 2010
+17
+25
+The above-entitled causo came on for
+hearing befure the HONORABLE RAYMOND B. RAY,
+one of the Judges of the UNITED STATES BANKRUPTCY
+COURT, in and for the SOUTHERN DISTRICT OF FLORIDA,
+a1 299 East Broward Blvd, Fort Lauderdale, Broward
+County, Florida, on Tuesdry, Auguat 4, 2010,
+commending et er about 9:30 am, and the following
+procuedings were had.
+Reported By: Margaret Franzen
+18
+19
+20
+21
+22
+23
+24
+25
+Page 2
+UN-
+0 un de
+4000 =
+APPEARANCES:
+BERGER SINGERMAN, By
+CHARLES H. LICHIMAN, ESQUIRE
+on behalf of the Trustee
+CONRAD & SCHERER, by
+WILLIAM R. SCHERER, ESQUIRE
+en behaif of victims
+FOWLER WHITE BURNETT, by
+RONALD G. NETWIRTH, ESQUIRE
+LILLY ANN SANCHEZ, ATTORNEY-AT-LAW
+CHRISTOPHER B. KNIGHT, ESQUIRE
+JOSEPH L. ACKERMAN, ESQUIRE
+on behalf of Jettiey Epstein
+2
+3
+4
+5
+10
+11
+12
+13
+14
+15
+FARMER JAFFE WEISSING EDWARDS FISTOS & LEHRMAN, by
+GARY FARMER, ESQUIRE
+BRAD EDWARDS, ESQUIRE
+on behalf of LM, Brad Edwards and
+Farmer Jaffe Weissing Edwards Fistos & Letman
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 3
+THE COURT: Rothstein Rosenfeldt & Adler.
+All right. May I have appearances, please?
+MR. LICHTMAN: Good morning, Judge.
+Chuck Lichtman, Berger Singerman, for the trustee.
+MR. NEIWIRTH: Good morning, your Honor.
+Ronald Neiwirth, Fowler White Burnett, on behalf of
+the movant, Epstein, and with me today are two of my
+partners, Chris Knight and Lilly Ann Sanchez -
+MS. SANCHEZ: Good morning, your Honor.
+MR. KNIGHT: Good morning, your Honor.
+MR. NEIWIRTH: - both of whom are more
+familiar with the State Court angle on this than I
+am, so they came along to be able to elucidate that
+end of it.
+MR. FARMER: Good morning, your Honor,
+Gary Farmer on behalf of LM, Brad Edwards, and
+the Farmer Jaffe Weissing law firm. We are an
+interested party and have filed a motion for
+protective order as to the subpoena that is at
+issue here today.
+THE COURT: All right. Insofar as the
+TD Bank motion, Docket Entry 780, that has been the
+subject matter of an agreed order that was submitted
+to me.
+MR. LICHTMAN: Correct, Judge.
+Page 4
+THE COURT: Mr, Scherer.
+MR. SCHERER: Yes, sir, your Honor.
+I'm William Scherer and I'm here on behalf of a
+number of victims in the State Court action, as
+well as the chairman of the creditors' committee
+in the bankruptcy.
+THE COURT: All right. That leaves us with
+Docket Entry 807 and 819. 807 is Jeffrey Epstein's
+motion.
+MR. NEIWIRTH: Thank you, your Honor, and
+again, good morning. We represent Jeffrey Epstein.
+He has a civil claim pending in State Court in
+Palm Beach County. He had served a subpoena on
+Mr. Stettin requesting documents from the RRA estate.
+That was back in April.
+While this was still in process, in
+May, under Docket Entry 672, your Honor entered
+an order standardizing procedures for obtaining
+discovery from Mr. Stettin and the RRA estate,
+and at least on the face of it, it takes
+jurisdiction over all discovery efforts against
+the trustee. That left us in a quandary.
+We had a subpoena pending in State
+Court. We had correspondence from Berger
+Singerman on behalf of the trustee that they had
+1 (Pages I to 4)
+OUELLETTE & MAULDIN COURT REPORTERS,
+ТЕХНІВЛЕ
+
+
+Entered on FLSD Docket 09/02/2010 Page 2 of
+Pege 5
+Pago 7
+1
+2
+3
+4
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+identified information and they were processing
+it, including vetting for attorney/client
+privilege issues, but then in the meantime came
+your Honor's order on May 18th, so we had to go
+back and reinvent the wheel and go through the
+necessary hoops in order to comply with that.
+In the meantime, as we sit here now, we
+still have no production. We have a trial date
+coming up in October, and we have a motion for
+protective order coming from a party who's
+already settled out, the LM party. They no
+longer have anything directly to do with this.
+Further, we are advised by the
+creditors' committee that in addition to what was
+proffered to us, that at some point in time there
+had been something like ten boxes of records
+pertaining to these particular issues and someone
+on behalf of the victims had been given, or
+several someones, had been given access to those
+ten boxes and had viewed them, which would
+vitiate any attorney/client privilege in any
+event.
+So what we are trying to do is fashion
+a mechanism so we can comply with your order,
+Docket 672, about standardized means of getting
+Page 6
+1
+2
+production from the trustee, allow for the
+appropriate vetting of the materials for
+attorney/client privilege, and we must bear in
+4
+5
+6
+mind that this is one objector, there's a lot
+more documents than that.
+To the best of our knowledge, the
+documents that pertain to the LM party, who is
+settled anyway, may be 15 percent of those which
+9
+are responsive to the inquiry that we made of the
+10
+trustee, but in any event, someone has to vet
+11
+them for attorney/client privilege and do a
+12
+privilege log.
+13
+Now, Mr. Farmer's office on behalf of
+14
+LM wants to do that. We don't think that's
+15 appropriate. We think the privilege at this
+point, since the case is settled, lies with RRA
+17
+and, therefore, the trustee, rather than
+18
+Mr. Farmer and his client, because as to them the
+19
+case is over.
+20
+Furthermore, we don't think there is
+21
+any privilege because the boxes have been vetted
+before and we'll hear more about that from
+23
+24
+25
+Mr. Scherer, I assume, because he was the one
+that was aware of that.
+And last, but not least, your Honor has
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+taken jurisdiction over these discovery matters
+and attempted to standardize discovery efforts
+for the trustee. There's a lot of people that
+want things from the trustee.
+The trustee is overseeing an estate
+which involved somewhere in excess of 70 lawyers
+and lots of cases and lots of problems, and
+literally millions of documents, and we have
+absolutely no problem with the standardized
+order, but that means that somehow or other we
+have to be able to deal with it in a standardized
+manner, instead of Mr. Farmer's suggestion, which
+is go back to State Court and deal with it over
+there.
+THB COURT: What is the status of the State
+Court proceeding?
+MR. NEIWIRTH: May I defer to my partner,
+who is more familier with that?
+MR. KNIGHT: Your Honor, Christopher
+Knight, if I may? While we were waiting for the
+documents from the Stettin office, we obviously
+wanted to go down two tracks because we had an
+October trial date. The status of it is we could not
+come to an agreement with the other side.
+Mr. Ackerman was at the last hearing, in which the
+Page 8
+]
+2
+3
+4
+judge said, one, 1 need a representative of the
+trustee here and two, shouldn't this be back before
+you, Judge Ray.
+THE COURT: You can't proceed against
+Rothstein in the State Court, they're here.
+MR. KNIGHT: And that is the same thing I
+think Judge Crow recognized, and that's why wete
+8
+back here, and that's why we had to file the motion.
+9
+MR. ACKERMAN: The claim against
+10
+Rothstein is against him individually, and it's
+11
+against Brad Edwards individually, and it was
+12
+against one of the claimants, LM individually.
+13
+THE COURT: So it's not against the debtor
+14
+15
+MR. ACKERMAN: That's correct.
+16
+MR. KNIGHT: Just to go a little further on
+17 what Mr. Neiwirth was saying. Out of these documents
+18
+we've been asking for for a long time, very few of
+19
+them would even have privilege on their face because
+20
+they have nothing to do with the clients that were
+21
+represented, what's been called as LM.
+22
+If there's going to be a log, if
+23
+there's any need, which I don't think there is
+24
+because I think privilege has been waived, it
+25
+needs to be a log put together by the trustee,
+2 (Pages 5 to 8)
+OUELLETTE & MAUDIN COURT REPORTERS, INC.
+
+
+Entered on FLSD Docket 09/02/2010 Page 3 of
+Page 9
+not anybody else that has some sort of interest
+If there's a problem with payment for
+those, et cetera, our client has already offered
+to the trustee, to Mr. Lichtman, we will pay for
+it, whether it's a special master or whether it's
+a contract attorney, if they need to do that, but
+I don't think we even need to reach that.
+I think these documents are long
+overdue. They have been produced to others, they
+have been used in depositions for others, they
+are out there, and I think the privilege issue is
+just being used as a smoke screen to keep our
+client from being able to get the documents he
+needs to be able to prove his case.
+MR. ACKERMAN: Your Honor, one other
+matter. Judge Crow expressed a concern about
+entering any order against the trustee or his
+counsel without them being present.
+Initially we had filed a motion to
+compel in the State Court, but we didn't realize
+at the time or it was unclear, because we had
+just taken over the case from another law firm,
+that the Court had entered its order.
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 11
+everybody first.
+MR. KNIGHT: Okay.
+MR. FARMER: Thank you, your Honor, may it
+please the Court. Again, Gary Farmer on behalf of
+the interested party, LM, also on behalf of
+Brad Edwards and I'm sorry, your Honor, Mr. Edwards
+is here with me. I neglected to introduce him to the
+Court carlier.
+MR. EDWARDS: Good morning, your Honor.
+MR. FARMER: There has been a lot of
+discussion here about your Honor's standardized
+production order and I think that you noed to
+understand that this particular matter, which is
+before you today, is anything but standard or common
+to the matters before this Court.
+You need to understand the nature of
+the case. Jeffrey Epstein is an admitted
+convicted pedophile. He sexually assaulted
+dozens and dozens of young girls under the age of
+15. He pled guilty to this and he has settled
+every civil lawsuit filed against him on this
+issue.
+Despite all of this, Mr. Epstein has
+seen fit to file a lawsuit against LM, who is one
+of the plaintiffs against him; against
+Page 10
+Page 12
+2
+5
+9
+10
+11
+12
+13
+14
+16
+17
+18
+19
+20
+21
+There was some discussion prior to the
+hearing and when we went to the hearing, it was
+clear that there was no agreement that had
+existed and Judge Crow said, I'm not entering an
+order, I'm not doing anything on this motion
+until the bankruptey trustee is represented.
+He was concerned because this Court's
+order had set up the standardized procedure for
+dealing with these arguments and had reserved
+jurisdiction relating to any subpoena or request
+for documents from the trustee, so that's why
+we're here now.
+THE COURT: All right.
+MR. KNIGHT: Your Honor, just one other
+point. We tried to work, and we've been working with
+Mr. Lichtman, tried to work out a protective order
+between the trustee and Epstein regarding the
+subpoena. Mr. Lichtman and Ms. Sanchez agreed to
+language on it. I have a copy of it.
+Mr. Farmer, with his motion for
+protective order, would not agree to that, but if
+the Court would like to have a copy of what the
+draft was, I will approach your clerk, but if you
+do not want that, I also --
+THE COURT: Well, let me hear from
+2
+4
+5
+6
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Brad Edwards, LM's attorney; and against
+Mr. Rothstein.
+Now, Edwards, myself, and all the
+members of our firm were RRA attorneys when
+Mr. Rothstein took his ill-fated trip to Morocco
+and did the things which are now so well known,
+but the fact of the matter is that this discovery
+request is a blatant attempt to obtain clearly
+privileged documents related to the
+representation of LM and many other victims, by
+the way.
+And ifl can show your Honor a copy of
+the subpoena itself, I don't think that the
+breadth of the subpoena has been adequately
+represented to the Court. If you peruse this,
+you will see they are asking for communications
+with private investigators, they're asking for
+contingency fee contracts, they're asking for
+every communication between any member of the
+firm, and they throw Rothstein in just to make it
+sexy, about these cases.
+Now, your Honor, clearly communication
+about the representation of a client falls under
+not only the work product, but if the client is
+involved in the communication, also the
+3 (Pages 9 to 12)
+
+
+Entered on FLSD Docket 09/02/2010 Page 4 of
+1
+2
+3
+4
+5
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 13
+Page 15
+attorney/client privilege.
+Now, most of this stuff we've already
+responded and said none, none, none, but for many
+of these items, we have asserted the privilege
+and we continue to assert the privilege.
+Now, the only reason the trustee is
+here —-
+THE COURT: Wait, there's been a privilege
+asserted in the State Court proceeding?
+MR. FARMER: Yes, sir.
+THE COURT: And there is a privilege log
+and the judge has made a ruling?
+MR. FARMER: No. The dispute now really is
+over who's going to file the privilege log and
+respectfully, Judge, what we suggest is that the
+trustee has been thrust into this matter simply
+because the trustee stands in the shoes of all the
+former attorneys at RRA, and the trustee is likewise
+bound by the privileges that attach to the cases and
+to the lawyers that were at the firm.
+The trustee has repeatedly acknowledged
+the fact that it is bound by those privileges
+and, of course, as your Honor knows, the
+privilege belongs to the client, not to any
+lawyer or any law firm.
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Mr. Scherer's clients, who have claims before
+this Court, and hopefully they will get some form
+of relief from the Bankruptey Court, Epstein is
+not seeking any bankruptcy assets. He's suing
+Brad Edwards and LM personally, and Scott
+Rothstein, and it's not an estate claim, it's
+against Scott Rothstein personally.
+So my suggestion, your Honor, is that
+you instruct the trustee to turn this electronic
+documentation information over to us. We will
+file the appropriate privilege log with the
+Circuit Court judge who is presiding over the
+case, who is most familiar with the case, who
+will be considering the upcoming motion for
+summary judgment, and possibly trying the case,
+and that way your Honor is not burdened with this
+matter, the trustee does not incur fees and
+expenses of having to go through all of these
+documents, prepare a privilege log and our
+clients and Mr. Edwards - Mr. Edwards is also a
+party of that lawsuit. He enjoys his own
+privilege, your Honor, over and above, or in
+addition to, I should say, the privilege
+possessed by our former clients and, of course, I
+know counsel knows that the privilege extends
+Page 14
+Page 16
+So the trustee is really kind of stuck
+2
+in the middle here. You've got the pedophile who
+3
+wants documents related to the cases he's already
++ in
+settled and pled guilty for. Those documents,
+the electronic documents, at least, the e-mails,
+6
+electronically stored information is how it's
+7
+referred to in the discovery request, your Honor,
+8
+are not in our possession, they are in the
+9
+possession of the trustee because the trustee
+10
+took the computer system.
+11
+So the trustee doesn't want to incur
+12
+the cost and expense of filing a privilege log
+13
+and, frankly, I don't know that the trustee has a
+14
+full appreciation of the nature and specific
+15
+facts of the cases that would enable it to
+16 conduct a complete privilege log.
+17
+been rejected - I believe it's acceptable to the
+19 trustee, but it's been rejected by Mr. Epstein's
+20 counsel, is the trustee be removed from this
+21 equation, There's no need that we come back
+22 before you.
+23
+This case, this Epstein case, is not a
+24 matter which would involve bankruptcy estate
+assets going to Mr. Epstein. Unlike
+1
+2
+3
+4
+5
+beyond the litigation.
+So although Mr. Epstein paid a ton of
+money for this claim that is supposedly
+frivolous, it has been settled, but the privilege
+still extends and it remains in place. So we
+simply want to make sure that our investigative
+7
+materials, our reports, other documentation
+8
+relating to the claims we have and have had
+9
+against Jeffrey Epstein are not put into the
+10
+hands of Jeffrey Epstein's attorneys.
+11
+Now, we just want the chance to review
+12
+these documents and prepare the privilege log and
+13
+the trustee is kind of stuck in the middle here,
+14
+Judge. Remove the trustee from the equation, let
+15 us get the documents, we'll file the privilege
+16 log, and then Mr. Epstein and us can go before
+17 Judge Crow. He can review the privilege log,
+18 review the documents in camera.
+All that is going to be pretty time
+20 consuming, but he's much more suited, a better
+21 suited judge because he's more familiar with the
+22 facts to engage in that inquiry.
+23
+THE COURT: Thank you.
+24
+25
+MR. FARMER: Thank you, your Honor,
+THE COURT: Mr. Lichtman, Mr. Scherer, your
+4 (Pages 13 to 16)
+
+
+Entered on FLSD Docket 09/02/2010 Page 5 of
+2
+3
+4
+5
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 17
+input, please.
+MR. LICHTMAN: I'm going to let Mr. Scherer
+go first.
+MR. SCHERER: I think he wants me to go
+first.
+THE COURT: All right.
+MR. SCHERER: Your Honor, in November
+we filed a lawsuit in State Court and we alleged
+that as a part of Mr. Rothstein and the firm, and
+the firm's employees, and maybe some of the
+firm's attorneys, conspired to use the Epstein/IM
+litigation in order to lure $13.5 million worth
+of my victims, my clients, into making
+investments in these phoney settlements.
+And as we alleged in that State Court
+proceeding, and we've sharpened the allegations
+as we've amended a few times, we allege that
+sometime in late October, that my clients were
+invited into the Rothstein firm with
+Mr. Rothstein, and he explained that he had a
+litigation going in State Court with Mr. Edwards
+representing LM, a victim of Mr. Epstein, and
+these are kind of sensational allegations and
+it's been printed widely.
+And my clients, a number of them and
+Page 18
+their lawyer, went into the Rothstein conference
+room and Mr. Rothstein brought down - summoned
+the investigators, two of them, two or three of
+them, to bring down the Epstein file. And the
+lawyer that my clients brought from a national
+finn, went through the LM boxes, ten of them that
+the investigators brought down, and concluded
+that the Epstein case was a real case.
+And what Mr. Rothstein did with that
+real case, of course, is he told everybody that
+not only did he have the LM client of
+Mr. Edwards, that there were a number of other
+young ladies, that was widely published in the
+newspaper, that the firm was representing and
+that wanted to settle with Mr. Epstein on a
+confidential basis.
+So he used the real case in order to
+defrund my clients into investing into these
+phoney settlements and paid 13 and a half million
+dollars. I believe that Mr. Rothstein and others
+in the firm also told that story to a lot of
+other people, and let a lot of other people
+examine those ten boxes of the real case.
+In addition, as we have alleged, that
+Mr. Edwards and the firm put sensational
+Page 19
+1
+2
+3
+4
+9
+10
+11
+12
+13
+14
+15
+116
+17
+18
+19
+20
+21
+22
+23
+24
+25
+allegations in the LM case that they knew were
+not true, in order to entice my clients into
+believing that Bill Clinton was on the airplane
+with Mr. Epstein and these young woman and other
+personages, I can't remember who they are, and
+all sorts of other allegations that really were
+not even related to the LM case.
+And to the extent that any lawyers from
+the RRA firm, former lawyers, made a ton of money
+or however Mr. Farmer talked about it, we're
+interested in that ton of money because if they
+were involved in this scheme, this fraud, there's
+a crime fraud exception, and in addition, I want
+to see the ten boxes that they brought down.
+The trustee does not have those ten
+boxes. Those ten boxes were taken by Mr. Edwards
+when he left the law firm, I presume. So we want
+the ten boxes, we want all the communications and
+we want to look through everything on behalf of
+my State Court case, but also on behalf of the
+creditors' committee because the creditors'
+committee is looking to see if anybody else in
+the firm, other than Rothstein, was involved in
+this massive fraud that used the Epstein case.
+The model of using an existing case and
+Page 20
+then spinning off a fraud from it is the same
+2
+3
+4
+5
+6
+7
+that was perpetrated on the Morse - in the Morse
+situation, as has been alleged and widely
+produced.
+I can't conceive that Mr. Edwards and
+the predecessor law firm would have any standing
+to prepare privilege logs or anything else, given
+what I just told the Court. That would be like
+9
+having the fox guard the hen house. That Epstein
+10
+case is settled, and to the extent it's the ten
+11
+boxes of stuff that we looked through, and I'1l
+12
+have to get the boxes to see if the attorney who
+13
+looked through them, and how much time he spent
+14
+looking through them -
+15
+16
+THE COURT: Where are the ten boxes?
+MR. SCHERER: That's a good question.
+17
+The trustee does not have the ten boxes. I
+18 presume the ten boxes are residing with the
+19
+lawyers who took the case, Mr. Edwards and the
+20 successor law firm. The trustee does not have
+21 them, And then in addition, there's about 6,000
+22, e-mails that the trustee has, and I bet you when
+23
+we look at Qtask, there's going to be a boatload
+24
+more.
+25
+My clients were also advised during
+5 (Pages 17 to 20)
+
+
+Entered on FLSD Docket 09/02/2010 Page 6 of
+Page 21
+1
+2
+4
+5
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+their due diligence, short due diligence to
+settle these cases with these young ladies -
+these putative young ladies who had to get the
+money and leave town because of whatever the
+stories were, that there were other members of
+the firm that told my clients that they, indeed,
+had even identified more of these victims that
+Mr. Rothstein didn't even know about at that
+time. So we know it wasn't just Mr. Rothstein
+spinning the tale, there were a lot of people in
+the firm.
+We've alleged almost all of this in our
+State Court action that we filed in Noverber, up
+to where we are right now, but, your Honor, I
+think your Honor is going to have to deal with
+these issues in this court and I would urge you
+to have the trustee get involved and let the
+trustee do its job with respect to whether there
+are privileges that need to be protected, work
+product or attorney/client privileges, given
+what's going on, and I believe the trustee will
+be investigating whether the trustee wants to
+bring any claims on behalf of the estate by
+virtue of what Fve just laid out for you.
+Thank you.
+2
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 23
+to take those ten boxes to start with.
+THE COURT: All right. Mr. Lichtman.
+MR. LICHTMAN: Good morning, Judge, I'm
+going to try to walk you through sort of
+chronologically the trustee's perspective of what has
+happened here. I think that what I've heard from all
+the parties are comments that are correct, and not
+necessarily correct, and I'm not suggesting
+falsehoods. We just have kind of a different
+perspective of some things and there are some points
+that ought to be corrected.
+Mr. Stettin received a subpoena in a
+Palm Beach State Court action for production of
+documents, and as we had done in virtually every
+subpoena, we went to our forensic accountants,
+the Berkowitz Dick Pollack & Brant firm, and
+said, okay, we need to produce e-mails and we
+need to also then, with the staff that we have at
+Berger Singerman and elsewhere, and look to see
+if there are any hard documents that we can find,
+notwithstanding what we'll call the issues as to
+the RRA hard drive that contain client files.
+We quickly realized that this is a
+claim different than all of the other subpoenas.
+The subpoenas that we had been receiving from
+Page 22
+THE COURT: So your lawsuit in State Court
+names these poople as defendants?
+MR. SCHERER: It names Rothstein. It
+does not name Mr. Edwards, It just names
+Rothstein, not the firm, and lays out the facts
+and says other people in the firm. We did not
+name them because we want to see the documents
+and see whether they had involvement.
+But the facts that I have alleged for
+10
+you, your Honor, is pretty much what I've alleged
+11
+in my first through third amended complaint in
+12
+State Court.
+13
+THE COURT: So, in essence, your position
+14
+in this matter would be to support the motion to
+15
+compel and deny the motion for protective order?
+16
+MR. SCHERER: Yes, sir, notwithstanding
+17
+that Mr. Epstein is a convicted pedophile.
+18
+want to put that on the record. You know, he's
+19
+served his time and whatever, but I support the
+20
+same position that he -- that he has asked the
+21
+Court, and that is to have the trustee deal with
+22
+this, get these documents and deal with it with
+23
+you, rather than allow the successor law firm to
+24
+bave them.
+25
+I don't know where they had the right
+Pago 24
+virtually every other party in the case were
+requests for production of documents related to
+claims that those moving parties or requesting
+parties would have as it pertains to them trying
+5
+to recover some aspect of money as pertained to
+6
+the Ponzi scheme.
+7
+Okay. Like Mr. Scherer, who said I
+8
+need a bunch of documents, can you help us? So
+9
+we would enter into, on a one by one basis, a
+10
+protective order that was very, very tightly
+11
+negotiated. There is no standard form protective
+12
+order in this case, contrary to what everybody
+13
+has told you. We have a form that we usc, and
+14
+everybody that has come to us, we said, we need
+15
+to have a protective order in place --
+16
+THE COURT: We have Docket Entry 672, which
+17 apparently is the document production protocol.
+18
+MR. LICHTMAN: We have that, yes, but then
+19
+we also, as an example, Document 685, have a
+20 protective order that was entered with Mr. Scherer's
+21
+clients, We have, as an example, Document 715 that
+22 pertains to MS Capital, and on and on.
+23
+So, in any event, what we realized is
+24 the case with respect to the Epstein vs. Scott
+25
+Rothstein, Bradley Edwards case, is this is
+6 (Pages 21 to 24)
+
+
+Entered on FLSD Docket 09/02/2010 Page 7 of
+2
+3
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+different. This is not an asset either to the
+RRA estate, nor is it really an asset to any
+potential creditor of the RRA estate that is
+investigating claims that can bring a recovery
+that can help in terms of the overall dollars
+into either RRA or to a particular creditor on
+their individual lawsuits.
+The Epstein case, rather, is a lawsuit
+between a third party that was being sued by the
+Rothstein firm against Rothstein lawyers, and we
+had a different privilege issue than we had
+focused on with all these other document
+productions.
+So we get the 6,000 e-mails, and on the
+eve of one of my colleagues getting ready to
+enter into - either enter into one of these
+protective orders or say, here, take them, like
+we've done with everybody else, we looked up and
+Mr. Stettin and I said, time out. We have a
+legitimate privilege issue here.
+And I want to be clear, we don't want
+to come anywhere close to stepping in the mess of
+waiving attorney/client privilege, unless and
+until the Court tells us to, and I want to also
+be clear, we wish we weren't here. We would
+1
+2
+5
+9
+10
+11
+12
+13
+14
+15
+16
+170®
+19
+20
+21
+24
+25
+prefer not to have a fight on any of this stuff
+and on one hand, we don't care who does the
+privilege log and who gets the documents, and on
+the other hand, because of some things that
+Mr. Scherer just commented on, that I learned
+literally today, and because of the common
+interest agreement that everybody knows we have
+with Mr. Scherer and the committee, in some
+respects, I don't think it prudent for me to
+discuss why I would want to look at some of those
+documents.
+But be that as it may, we found that
+there were 6,000 e-mails and this was the one
+time that rather than go through the usual
+protocol of preparing the stipulated protective
+order that is effectively a mirror image of that
+which is provided by Federal Rule of Bvidence
+502, we said there is a need for a real privilege
+log here.
+There are 6,000 e-mails, give or take,
+and we quickly assessed that the time to review
+6,000 e-inails, this could not be done by a
+paralogal, it would have to be done by a lawyer.
+THE COURT: Does this include Qtask or is
+this in addition to?
+Page 25
+Pago 27
+1
+5
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+: 20
+21
+22
+23
+24
+25
+MR. LICHTMAN: Qtask is not part of this
+equation as of right now. Now, it may be, and wete
+still trying to get that. I'm just talking about
+internal e-mails where we would put in a name search,
+give it to the Berkowitz firm and say, run an e-mail
+search on the following names.
+And when we realized the volume of
+work, and you can imagine, you know, like trom a
+ream of paper, 500 sheets of paper, and you
+multiply that out and you get to 12 reams of that
+paper, it takes up a lot of paper, it takes up a
+tremendous amount of time. This is not an asset
+of the estate that we can, if we have to, warrant
+doing the work, the hard work, as we've done on
+many of the other claims, some of which already
+are before you for settlement purposes. This is
+a liability to the estate and an expensive one.
+So we realiy didn't want to go through
+the undertaking of having to protect the
+privilege, though we would, and candidly,
+Epstein's counsel has said we'll pay you to do
+it, but then there's also the manpower issue
+because we are pressed very hard to get certain
+adversaries moving as quickly as we can and wete
+fighting a lot of battles on a lot of different
+Pago 28
+Page 26
+1
+2
+grounds, we still really don't want to do that,
+and also because we don't know the Epstein case
+well enough to be able to assess what is
+privileged, what is not, and preparing a
+5
+privilege log the proper way is really a time
+consuming mess.
+So I teed it up for both sides and
+said, here's what I'm willing to do. Putting
+9
+aside the issue as to really whether or not the
+10
+Court does have jurisdiction on a State Court
+11
+12
+subpoena, which ultimately I leave to you, we
+said, we're still willing to enter into a
+13
+modified version of the protective order that we
+14
+gave to you, which effectively provides the
+15
+additlonal language of no claims can be brought
+16
+against Mr. Stettin or the estate if we produce
+17
+these documents.
+18
+We don't really have a bone to pick in
+19
+this mess, we just want to make sure that we
+20
+21
+follow all of the ethical boundaries required by
+Florida law, by rules of professional conduct.
+22
+We don't wish to necessarily waive somebody
+23
+else's privilege. We don't think that's
+24
+necessarily prudent, but we really don't want to
+25
+have a fight in this battle, and we wanted the
+7 (Pages 25 to 28)
+
+
+Entered on FLSD Docket 09/02/2010 Page 8 of
+Page 29
+Page 31
+1
+2
+3
+4
+5
+6
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Court to approve - whatever it is you want us to
+do, to tell you the truth, we're happy to do. We
+just want to make sure that Mr. Stettin is
+personally insulated and that the estate is
+Insulated in whatever it is -
+THE COURT: All I see is -
+MR. LICHTMAN: - you direct.
+THE COURT: -- the potential of a claim
+against Stettin and the estate for breach of the
+attorney/client privilege.
+MR. LICHTMAN: correct.
+THE COURT: So the basis -
+MR. LICHTMAN: And hence the dilemma.
+THE COURT: - for the claim is there.
+MR. LICHTMAN: Yeah, right, hence the
+dileruma.
+Now we come to the issue of hard
+documents because the o-mails are one thing, and
+I had a number of conversations candidly with
+Ms. Sanchez, where I think that we had told her
+originally we had heard there were, as an
+example, some loan files or transaction files
+related to Ponzi deals related to Mr. Epstein,
+because I remember myself even hearing that going
+back many, many, many months ago.
+Page 30
+Suffice it to say, that I have
+conducted a very thorough discussion, without
+3
+waiving our internal privileges or work product,
+and we can't find those, and it appears as if
+they really did not exist, that what had occurred
+is that somehow Epstein was listed on a shoet for
+a potential deal that never closed.
+8
+In terms of the ten boxes of documents,
+9
+one of the functions the trustee served carly on
+10
+in the case was to facilitate transfers of
+11
+12
+THE COURT: 1 remember that.
+13
+MR. LICHTMAN: - from two attorneys that
+14
+were handling cases. All right. I had a general
+15
+understanding that most of the files were picked up
+16
+by the Farmer firm because they were continuing on
+17
+with that litigation, and that would have made some
+18
+sense, but then we had also heard that there were
+19
+some boxes that were left behind.
+20
+I believe there are two boxes, I'm not
+21
+positive of that, two boxes I think that we may
+22
+still have, and I'm pretty sure we've sent
+23
+e-mails a couple of times to the Farmer firm
+24
+saying, come get your documents.
+25
+Now, why would we do that? A, because
+2
+3
+4
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+they had been counsel for LM and others in
+litigation respecting Epstein, and that we
+assured that they would have been files they
+would want; and B, because at the time that this
+matter on the subpoena came before the State
+Court judge, we stood outside the courtroom and
+here's what happened. I was effectively going to
+tell the State Court judge basically the same
+story I've told you in complete detail and say,
+we don't really care. We just want to make sure
+Mr. Stettin is protected and the estate is
+protected.
+And we had reached an agreement that
+day, which was we were going to turn over the
+boxes to Mr. Farmer's firm and we were going to
+give e-mails to them, and they were going to do
+the privilege log because that would save us a
+ton of time, important time, and as important, a
+lot of money to the estate, and we did not wish
+to burden the creditors of the estate with legal
+fees for putting together the privilege log, so
+it was agreed that we would do that,
+1, personally, reiterated the terms to
+all the lawyers that were standing outside the
+courtroom, as to what was to be reflected in a
+I
+2
+3
+4
+5
+6
+written order because I didn't want to leave it
+to chance as to what was agreed on.
+Suffice it to say, when the lawyers for
+Mr. Epstein and the lawyers for Mr. Edwards went
+back to try to reduce to writing that which was
+in part agreed upon outside the courtroom, they
+were unable to do so, and that teed up the filing
+8
+of the motion before you to compel us to produce
+9
+the e-mails and the documents.
+10
+I wish to reiterate, I think that
+11
+Mr. Scherer has shared something with me that we
+12
+need to investigate and will, and I was unaware
+13
+of that literally until I rode up the elevator
+14
+with him this morning. And I don't wish to spend
+more time on it than that right now, but I take
+16 him at his word because an awful lot of what I've
+17
+seen him work on so far has borne fruit.
+18
+I don't care what you want us to do.
+19 AllI want to know is that at the end 1 can walk
+20 out of court with an order that protects the
+21
+estate and protects Mr. Stettin. So I have told
+22 you the story and leave it to you to fashion what
+remedy you think appropriate.
+24
+25
+IfI can answer any questions, Im
+happy to.
+Page 32
+8 (Pages 29 to 32)
+
+
+Case 9:08-cv-80893-KAM
+Document 214-3
+Entered on FLSD Docket 09/02/2010 Page 9 of
+2
+5
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 33
+THE COURT: Well, the trustee knows what
+the trustee has, obviously.
+MR. LICHTMAN: Yes.
+THE COURT: So the trustee is capable of
+preparing a log of what he has.
+MR. LICHTMAN: Meaning we have the
+following data.
+THE COURT: Yes.
+MR. LICHTMAN: Yes, we can do that.
+THE COURT: Then the parties can then argue
+whether or not that is subject to privilege. The
+plaintiff can still get from Mr. Farmer and his
+clients in the State Court discovery. The discovery
+being sought here is from the trustee --
+MR. LICHTMAN: Correct.
+THE COURT: - and would be subject to the
+trustee's responsibility for the privilege log
+because of his potential liability.
+MR. LICHTMAN: Yes, and I think you
+understand, though, why if we can somehow deflect
+that responsibility, because of the extreme amount of
+cost and time to do that, we would be happy to do
+that because, you know, otherwise, we submit fee
+petitions that show a tremendous amount of time on
+something that doesn't produce an asset to the
+Раде 34
+1
+2
+3
+4
+5
+6
+7
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 35
+MR. FARMER: Yes, your Honor, Just very
+briefly. I thank you for the opportunity to address
+the Court again. I just wanted to clear something
+up, your Honor. Understand that when this all
+happened, there were six of us now who are partners,
+who had dozens and dozens of on-going cases.
+THE COURT: I remember we held hearings and
+I authorized the trustee --
+MR. FARMER; And you authorized, yes,
+THE COURT: - to deliver the information
+so the lawyers could continue to represent the
+clients.
+MR. FARMER: It just seemed to be maybe
+suggested here today that something untoward occurred
+as far as the removal of these boxes. These were
+litigation files, pleadings, investigative reports,
+all of these things.
+So we needed to get on with those
+cases, but I think you've heard now from the
+trustee that this is not an asset and it is an
+expense. I still think that we are the party who
+should prepare this privilege log. We are most
+familiar -
+THE COURT: Well, no, if I appoint a
+special master, you will have an input into that
+1
+2
+3
+estate, just a liability.
+THE COURT: Right. This is not an asset of
+the estate.
+MR. LICHTMAN: No, it's just a liability.
+THE COURT: But could be a substantial
+6
+7
+8
+MR. LICHTMAN: Hence the dilemma.
+THE COURT: Well, I can appoint a special
+master to do it at the expense of the movant and not
+release the information until the special master
+reports back to me and I authorize the relcase.
+What I propose to do by my authorizing
+the release - I'm sorry, Stettin, as trustec, to
+release the information, 1 would, theretore, be
+protecting the estate from any claims for the
+16 release of that information.
+MR, LICHTMAN: We would be happy to do
+18 that, your Honor, and I note, I don't wish to speak
+19 for the Epstein lawyers, they actually offered to pay
+20 time for us doing that, and I said, well, you know,
+21 that's part of the equation, the other part is -
+THE COURT: No, no, no, I can appoint a
+MR. LICHTMAN: Yes.
+THE COURT: All right. Mr. Famer.
+Page 36
+1
+2
+3
+4
+5
+special master and you'll have an opportunity to be
+heard before me before I authorize the release of the
+information, because ultimately the order that's
+going to authorize the release of the information is
+going to provide protection to the trustee and the
+estate.
+7
+8
+MR. FARMER: And, thank you, Judge, I just
+wanted to make sure, and 1 was going to request, that
+we have an opportunity to review whatever the master
+10
+does and if we think they've missed a privilege or
+11
+are wrong in an assertion, that we have an
+12
+opportunity to address that.
+13
+THE COURT: There is going to be a hearing
+14
+before the information gets released.
+15
+MR. FARMER: Understood. Thank you, your
+16
+Honor.
+17
+THE COURT: All right. Mr. Lichtman -
+18
+MR. LICHTMAN: Yes.
+19
+THE COURT: - 1 want you to prepare the
+20
+order. I'm going to continue the hearing on the two
+21
+motions, Docket Entry 807 and 819, and I'm going to
+22 have you draft an order appointing a special master,
+23 the expense of which will be borne by the Epstein
+24 movants. The special master will meet with both
+25 sides, Epstein and Edwards, and then with the
+9 (Pages 33 to 36)
+
+
+Entered on FLSD Docket 09/02/2010 Page 10 of
+10
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+4
+5
+6
+7
+8
+12
+13
+14
+15
+16
+17
+18
+19
+20
+23
+24
+25
+Page 37
+trustee, and will prepare a privilege log, the
+release of which will be noticed for hearing in front
+of me.
+MR. LICHTMAN: Do I pick the special master
+or do you?
+THE COURT: You can -- if you all can - 1
+hate to use the word agree, but if you all can agree,
+that's fine. If you can't agree, give me three names
+to choose from.
+1
+2
+3
+4
+CERTIFICATION
+5
+STATE OF FLORIDA:
+6
+COUNTY OF DADE:
+7
+8
+1, Margaret Franzen, Shorthand Reporter
+9
+and Notary Public in and for the State of Florida
+10
+at Largo, do hereby certify that the foregoing
+11
+proceedings were taken before me at the date and
+THE COURT: You're going to have to check
+12
+place as stated in the caption hereto on Page 1;
+with this, quote, "special master" to make sure they
+13
+that the foregoing computer-aided transcription is
+have the time to review the privilege log.
+14
+a true record of my stenographie notes taken at said
+MR. LICHTMAN: The documents.
+15
+proceedings.
+THE COURT: And it has to be somebody that
+16
+WITNESS my hand this 5th day of
+doesn't have a conflict of interest.
+17 August, 2010.
+18
+MR. LICHTMAN: Right. Okay.
+THE COURT: All right. Run the order by
+Mr. Neiwirth and Mr. Farmer.
+Margaret Franzen
+MR. LICHTMAN: Thank you.
+21
+Court Reporter and Notary Public
+MR. FARMER: Thank you, your Honor.
+MR. NEIWIRTH: Your Honor, may it please
+22
+in and for the State of Florida at Large
+My Commission Expires: April 14, 2014
+the Court?
+THE COURT: Yes.
+23
+MR. NEIWIRTH: Can we say something about 35
+Page 38
+the time frame because as we sit here right now we
+still have a trial coming in October,
+THE COURT: Well, I understand that, but I
+probably have between five and 6,000 active cases
+right now and within the Rothstein case, I don't even
+know how many adversaries and contested matters are
+pending. I'll get to it as soon as I can.
+But you can proceed to obtain the
+information from Edwards and LM in the State
+Court proceeding. All I'm governing is what the
+trustee is going to release from the debtor
+estate.
+All right. Mr. Lichtman, see to the
+order.
+MR. EDWARDS: Thank you, your Honor.
+MR. FARMER: Thank you for your time, your
+Honor.
+MR. NEIWIRTH: Thank you, Judge.
+(Thereupon, the hearing was concluded.)
+Page 39
+10 (Pages 37 to 39)
+• -
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/215290f05fa6896eb363ffd35d2613d7197ed168d74a72a4281bd68001ca86f3.receipt.json b/vision-fixhub/ds9-unparsed-06/215290f05fa6896eb363ffd35d2613d7197ed168d74a72a4281bd68001ca86f3.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f6415ce83559d6c8f7f59c49950571e0aa06dc29
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/215290f05fa6896eb363ffd35d2613d7197ed168d74a72a4281bd68001ca86f3.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -949,
+  "dataset": "marble-joined",
+  "doc_id": "215290f05fa6896eb363ffd35d2613d7197ed168d74a72a4281bd68001ca86f3",
+  "engine": "marble-apple-vision",
+  "event_count": 11,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "2b3499aaa8b936aecd5d4371c32849145d6135cd0acba5191b4344f66729c68f",
+  "output_sha256": "d8537bddc56788e0fc9d3ab29d4681e1c7c02d64bbd46af195bdb1e7018e28af",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/218ebebbac2f824cd2b93f48a92e2cf21bb56c4830a5ca9884023abd0e788265.md b/vision-fixhub/ds9-unparsed-06/218ebebbac2f824cd2b93f48a92e2cf21bb56c4830a5ca9884023abd0e788265.md
new file mode 100644
index 0000000000000000000000000000000000000000..21ad972c3eaebb22d039f0813013b5186eca4cbe
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/218ebebbac2f824cd2b93f48a92e2cf21bb56c4830a5ca9884023abd0e788265.md
@@ -0,0 +1,56 @@
+From:
+To:
+Subject: Activity in Case 9:08-cv-80119-KAM Doe |. Epstein Response/Reply (Other)
+Date: Wed, 10 Feb 2010 21:56:02 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Pike, Michael on 2/10/2010 at 4:56 PM EST and filed on 2/10/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 466
+Doe | Epstein
+9:08-cv-80119-KAM
+Jeffrey Epstein
+Docket Text:
+RESPONSE/REPLY to [465] Response to Motion, Reply to Plaintiff Jane Doe's Objection to
+Extension of Time to File Appeal and, in the Alternative, Request for Direction to Epstein to
+Begin Assembling Documents by Jeffrey Epstein. (Pike, Michael)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+Bradley James Edwards
+Isidro Manuel Garcia
+Jack Alan Goldberger
+Jack Patrick Hill
+Jeffrey Mare Herman
+Katherine Warthen Ezell
+
+
+Michael James Pike
+Paul G. Cassell
+Richard Horace Willits
+Robert. Josefsberg
+Robert Deweese Critton, Jr
+Stuart S. Mermelstein
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-
+1.:
+Martin G. Weinberg
+20 Park Plaza
+Boston, MA 02116
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=2/10/2010] [FileNumber=7248326-0
+][1910acbbe954f64db869dабad74ff5b101db1ab0cb3fd2ca2ef3a0525cc82baef4f
+32819dca9fa15836dfbefed244ee05e584acfb296b8f5edab6c0daa2130191]
diff --git a/vision-fixhub/ds9-unparsed-06/218ebebbac2f824cd2b93f48a92e2cf21bb56c4830a5ca9884023abd0e788265.receipt.json b/vision-fixhub/ds9-unparsed-06/218ebebbac2f824cd2b93f48a92e2cf21bb56c4830a5ca9884023abd0e788265.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0a088ae10140b80f8229e553e98ec5c116e7134b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/218ebebbac2f824cd2b93f48a92e2cf21bb56c4830a5ca9884023abd0e788265.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "218ebebbac2f824cd2b93f48a92e2cf21bb56c4830a5ca9884023abd0e788265",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e115cb1a633dea5269e709ff27db692f07822a862d2964a0b72d21ee1f3516d3",
+  "output_sha256": "14b4dfe60eef0d1a492a6259c0b816746140064f34cb80983147e80c0d882f08",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/230b5f73321ecaccc4ef6567f154b728674c7717eb38c49610b774eb7ec27198.md b/vision-fixhub/ds9-unparsed-06/230b5f73321ecaccc4ef6567f154b728674c7717eb38c49610b774eb7ec27198.md
new file mode 100644
index 0000000000000000000000000000000000000000..9bbe68f8ef4f421a3e3c58f1f05c471305af7360
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/230b5f73321ecaccc4ef6567f154b728674c7717eb38c49610b774eb7ec27198.md
@@ -0,0 +1,30390 @@
+
+SUBSCRIBER INFORMATION
+*cingular®
+NY
+KSM1X10
+CMD ==>
+4BA/W49A3
+ACCOUNT DESCRIPTION
+NY
+08/23/06
+5:19P
+ACCOUNT:
+CTL: 12RT LAST CHANGE: 111805 BY: AAR
+SERVICE ORDER: X3913
+
+TYPE: B
+INITIATION: 031700
+PURCHASE ORDER:
+
+CLASS: R INVC QTY: 01 D
+STATUS:
+CANCEL
+040304 REASON:
+0
+SSN:
+ACTIVE PHONES:
+RESERVED PHONES:
+ACCOUNT REP:
+CREDIT CLASS: B4
+CREDIT LIMIT:
+DETAIL BILL: DBC DATA: N
+DEPOSIT REQUIRED:
+PAID:
+TAX ID: T23
+DUE LAST BILL:
+DUE NOW:
+LAST PAYMENT:
+76.29 072504
+LOOKUP NAME: JEFFREY E INITIAL DEALER: 00115 00115
+H/W: N
+SUSPEND CNT:
+BILL TO NAME AND ADDRESS
+SIC:
+ACCT ALERT:
+PERSONAL GUARANTOR
+NAME:
+JEFFREY E EPSTEIN & CO
+ATTENTION 1:
+ATTENTION 2:
+STREET ADDR:
+CITY ST ZIP:
+
+HOME PHONE:
+CCI: 2
+BUSS PHONE:
+
+DATA SERV ACTIVE:
+CANCEL:
+SUSPEND:
+DIGITAL EQUIP EXISTS
+FED N ST N MUN N 01 N 02 N 03 N 04 N 05 N 06 N 07 N 08 N 09 N 10 N 11 N 12 N
+MESSAGE
+AT&T WIRELESS SVCS NEW YO
+KSM1031 4BA/W49A3
+CMD ==>
+SERVICE DESCRIPTION
+NY
+08/23/06 5:19P
+ACCOUNT:
+NAME: JEFFREY E EPSTEIN & CO
+CTL: 12RT
+D TELEPHONE:
+STATUS: CANCEL
+PREVIOUS STATUS: ACTIVE
+042203 TC
+LAST SERVICE ORDER: 5504฿
+ELEC SERIAL NO:
+MECH SERIAL NUM: 8265
+EPF PIN:
+DEALER CODE: 2W277 L6P9C
+RATE PLAN: NIS 042203
+LAST CHANGE 111805 BY AAR
+040304 3G
+EQUIPMENT:
+
+NOK
+ORDER DATE: 042203
+BILLING START DATE: 042203
+BILL THRU DATE: 040204
+CP:
+SERVICE USER:
+DEPOSIT REQUIRED:
+PAID:
+IEC: 0288 042203
+PAPERWK ST: VB
+HELD:
+ORIG CONTRACT DATE:
+MESSAGE
+CONTRACT START DATE: 042203 CONTRACT LENGTH: 12
+MODEL:
+YR:
+AT&T WIRELESS SVCS NEW YO
+LAM
+Page 1
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless and its Affiliates
+
+
+
+LNY
+Run Date:
+01/16/04
+06:03:06
+Account:
+MOBILE
+ESN
+* cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+BRIDGETOWN BD
+BRIDGETOWN
+MIAMI
+BD
+FL
+NACN
+NEW YORK
+SPEIGHTSTN
+SPEIGHTSTN
+BROOKLYN
+NEW YORK
+NEW YORK
+W PALM BCH
+NEW YORK
+NY
+BD
+BD
+NY
+NY
+NY
+FL
+NY
+NACN
+MOBILE
+SPEIGHTSTN
+BD
+SPEIGHTSTN
+BD
+NEW YORK
+NY
+BROOKLYN
+NY
+N PALM BCH
+FL
+NACN
+DIR. ASST.
+WEST PALM
+FL
+WEST PALM
+FL
+DIR. ASST.
+W PALM BCH FL
+NACN
+DIR. ASST.
+WEST PALM FL
+DIR. ASST.
+WEST PALM FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/01
+3: 1615₽
+01/04 12:4634P
+01/04
+5: 5555₽
+01/04
+5:5713P
+01/04
+6: 5108₽
+01/04
+6: 5332₽
+01/04
+6: 5425₽
+01/04
+6: 5941₽
+01/04
+7: 5728₽
+01/05
+8: 4525A
+01/05
+9:3259A
+01/05
+9: 3337A
+01/05
+9: 3413A
+01/05 11:1031A
+01/05 11:1238A
+01/05 11:1335A
+01/05 11:2704A
+01/05 11:2844A
+01/05 11:4645A
+01/05 11:4755A
+01/05 12:1051P
+01/05 12:1052P
+01/05 12:1323P
+01/05 12:1633P
+01/05 12:3130P
+01/05 12:3240P
+01/05 12:3917P
+01/05 12:3918P
+01/05
+2: 0128P
+01/05 2:0129P
+DUR
+0
+0
+1
+1
+1
+2
+1
+14
+N O
+2
+1
+1
+5
+1
+1
+0
+4
+• H
+2
+0
+0
+3
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+• 65
+1.95
+. 65
+1.3
+0
+0
+0
+6
+3
+0
+• 0
+0
+0
+25
+• O
+0
+0
+0
+• 65
+1.95
+• 65
+1.3
+0
+. 65
+3.25
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+37
+37
+37
+37
+37
+37
+37
+37
+37
+37
+37
+37
+25
+37
+37
+37
+37
+37
+25
+37
+37
+37
+37
+37
+c
+Page1
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+QUEENS
+MOBILE
+NEW YORK
+NY
+NY
+W PALM BCH FL
+NACN
+QUEENS
+NY
+MOBILE
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+WEST PALM
+FL
+WLOSANGELS
+CA
+NEW YORK
+NY
+NEW YORK
+NY
+OAHU
+HI
+SPEIGHTSTN
+BD
+NEW YORK
+NY
+NEW YORK
+QUEENS
+SPEIGHTSTN
+MOBILE
+NY
+NY
+BD
+NY
+NEW YORK
+NEW YORK
+SPEIGHTSTN
+MOBILE
+SPEIGHTSTN
+SPEIGHTSTN
+NEW YORK
+NY
+NY
+BD
+NY
+BD
+BD
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+01/05 2:0430₽
+01/05
+2: 1154₽
+INCOMING
+01/05
+2: 5618₽
+01/05
+2:5719₽
+01/05
+3: 2305₽
+INCOMING
+01/05
+3:2411P
+01/05
+3: 5731P
+01/05
+3: 5749₽
+01/05
+4:0649P
+INCOMING
+01/05
+4: 0813₽
+01/05
+4: 1433P
+01/05
+4:1848P
+01/05
+4: 2416P
+01/05
+7: 5141P
+01/05
+7:5204P
+01/05
+8:2954P
+01/05
+8: 3201P
+01/05
+9:1446P
+INCOMING
+INCOMING
+01/05
+9:2343P
+01/05
+9: 4903P
+01/05
+9:4956P
+01/05
+9: 5154P
+01/05
+9:5533₽
+01/05
+10:0421P
+INCOMING
+01/05 10:1654P
+01/05 10:2227P
+01/05 10:2349P
+01/05 10:2441P
+01/05 10:3105P
+01/05 10:4036P
+01/05 11:0306P
+01/05 11:0453P
+DUR
+1
+1
+1
+3
+0
+1
+1
+1
+0
+1
+4
+2
+26
+1
+2
+3
+2
+2
+1
+1
+1
+H ч
+16
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+• 00 • 0 O
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+37
+37
+37
+37
+25
+37
+37
+37
+25
+37
+37
+37
+37
+2
+5
+25
+25
+2
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+н н
+Page2
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+SPEIGHTSTN BD
+MOBILE
+NY
+SPEIGHTSTN BD
+SPEIGHTSTN BD
+ETLAUDERDI FI
+NEW YORK
+NY
+MOBILE
+UN. KINGDO
+UN. KINGDO
+NY
+NEW YORK
+NY
+NWYRCYZNO1 NY
+SPEIGHTSTN BD
+NEW YORK
+NY
+W PALM BCH FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+01/05 11:2727P
+01/05 11:2811P
+01/05 11:4141P
+01/05 11:4947P
+01/06 12:0147A
+INCOMING
+INCOMING
+INCOMING
+01/06 12:0432A
+01/06 1:1353A
+01/06 2:3506A
+01/06 8:5215A
+INCOMING
+INCOMING
+INCOMING
+01/06 10:0255A
+01/06 10:1039A
+01/06 12:4209P
+01/06 12:4810P
+01/06 12:4946P
+01/06 12:5552P
+INCOMING
+01/06
+1: 0921P
+01/06
+1:1027P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/06
+3:2143P
+01/06
+3: 2714P
+01/06
+5: 0002P
+01/06 5:0344P
+01/06 8:0642P
+INCOMING
+INCOMING
+INCOMING
+01/06 8:3427P
+01/06 9:5118P
+01/06 10:2622P
+01/06 11:0641P
+INCOMING
+INCOMING
+01/06 11:0743P
+01/06 11:0817P
+01/07
+9: 1715A
+01/07
+9: 2106A
+INCOMING
+INCOMING
+01/07
+9:2135A
+01/07 10:3359A
+DUR
+1
+1
+1
+2
+7
+56
+1
+4
+5
+4
+HAMN
+H N
+1
+1
+18
+2
+5
+1
+1
+3
+HAN
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+1.3
+0
+1
+15
+0
+0
+. 65
+0
+0
+1.3
+0
+0
+0
+0
+0
+0
+1.05
+.7
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2
+5
+25
+25
+2
+5
+25
+25
+2
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 3
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+SPEIGHTSTN BD
+MOBILE
+NY
+MOBILE
+NEW YORK
+NY
+NY
+NWYRCYZN01 NY
+SPEIGHTSTN
+BD
+MOBILE
+NY
+SPEIGHTSTN BD
+SPEIGHTSTN BD
+SPEIGHTSTN BD
+MOBILE
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+01/07 10:5718A
+INCOMING
+01/07 12:2711₽
+INCOMING
+INCOMING
+01/07 1:1919₽
+INCOMING
+01/07 2:4317P
+01/07
+2:4426P
+01/07
+3: 0435₽
+01/07
+3: 0512P
+INCOMING
+INCOMING
+INCOMING
+01/07
+3: 3323P
+01/07
+3: 4019P
+01/07 4:0715₽
+01/07 4:0755₽
+01/07 4:0922P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/07
+4:1434P
+01/07
+4: 1605P
+01/07
+4: 5319P
+01/07
+5:0820P
+01/07
+5:1334P
+01/07
+5:1818P
+01/07
+5:2339P
+01/07
+5: 2515P
+01/07
+5: 5633P
+01/07
+7: 3308₽
+01/07
+8: 0406P
+01/07
+8: 3000P
+INCOMING
+INCOMING
+01/07
+8: 4421P
+01/07 10:2336P
+01/07 10:2635P
+01/07 10:3242P
+01/07 10:3254P
+01/07 10:3921P
+01/07 10:5954P
+01/07 11:3113P
+DUR
+1
+1
+3
+1
+1
+1
+1
+5
+1
+2
+N A A N
++ m
+2
+1
+HA HAN
+HAN
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless
+AIR
+LAND TOTAL RSYS
+0
+. 65
+0
+0
+0
+• 65
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+0
+0
+0
+0
+0
+0
+0
+• 00
+• 0 o
+• 0
+• • 0 0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+UHHH U
+Page 4
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+SPEIGHTSTN BD
+SPEIGHISTN BD
+NEW YORK
+NY
+NEW YORK
+NEW YORK
+NEW YORK
+MOBILE
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+SPEIGHTSTN BD
+NEW YORK
+NY
+NEW YORK
+NY
+ETLAUDERDI FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+01/07 11:3732P
+INCOMING
+01/08
+7: 5332A
+01/08 9:0312A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/08
+9: 0949A
+01/08 10:1311A
+01/08 10:2646A
+01/08 11:0125A
+01/08 11:1545A
+01/08 11: 3100A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/08 11:5114A
+01/08 12:1136P
+01/08 12:1454P
+01/08 12:2911P
+01/08
+12: 3915
+P
+01/08 12:4217P
+01/08 12:4245P
+01/08
+12:4504P
+01/08
+12:4532P
+01/08 12:5114P
+01/08
+1:3927P
+01/08
+1: 3952P
+INCOMING
+INCOMING
+INCOMING
+01/08 2:1257₽
+01/08
+2: 5442₽
+01/08 5:2117₽
+01/08 5:2243P
+INCOMING
+01/08 6:00378
+01/08 6:3259P
+INCOMING
+INCOMING
+01/08 6:4632₽
+01/08 6:5628P
+01/08 6:5747P
+01/08 7:0724P
+INCOMING
+01/08 7:1236P
+DUR
+1
+1
+1
+1
+1
+1
+9
+1
+2
+2
+1
+12
+1
+1
+9
+1
+3
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+4.55
+4.55
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+• 65
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2.
+5
+25
+2
+2
+2
+2
+5
+2
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Il
+UH U
+Page 5
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NEWYORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+NEW YORK
+NY
+UN. KINGDO
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+W PALM BCH FL
+NACN
+UN. KINGDO
+UN. KINGDO
+W PALM BCH
+FL
+W PALM BCH FL
+NACN
+NACN
+UN. KINGDO
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+NEW YORK
+NY
+NEW ALBANY OH
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+01/08 7:5324P
+INCOMING
+01/08 9:2850₽
+01/08
+9: 4240P
+01/08
+9: 4343₽
+01/08
+9:4419P
+01/08
+9:5705P
+INCOMING
+INCOMING
+01/08 10:0206P
+01/09 12:3755A
+01/09 1:0722A
+01/09 10:0726A
+INCOMING
+01/09 10:0840A
+01/09 10: 3825A
+INCOMING
+01/09 10:3933A
+01/09 10:51
+40.
+A
+INCOMING
+01/09 10:5150A
+01/09
+1:0833P
+INCOMING
+INCOMING
+01/09
+1:0944P
+01/09
+1:1203P
+01/09
+1:2339P
+INCOMING
+01/09
+1:2449P
+01/09
+1:4715P
+01/09
+1:4825P
+01/09
+2: 0934P
+01/09
+2:1005P
+INCOMING
+INCOMING
+01/09
+2: 1043P
+01/09
+2: 1110₽
+01/09
+2:1527P
+01/09
+2: 2409P
+INCOMING
+01/09
+2:2517₽
+01/09
+2: 4025₽
+INCOMING
+01/09
+2: 5947₽
+01/09
+3: 0236P
+DUR
+1 l
+1
+1
+1
+1
+0
+O HO
+5
+ON H
+0
+2
+0
+2
+NAM
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+LAND TOTAL RSYS
+0
+25
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+37
+.35
+0
+•35
+0
+37
+25
+37
+25
+0
+37
+2
+5
+0
+37
+• 00
+2
+17
+7
+2
+0
+• 35
+. 35
+37
+. 35
+• 35
+37
+37
+25
+0
+0
+0
+0
+0
+0
+0
+• 0 o
+000 0 000
+0
+0
+0
+0
+25
+37
+37
+37
+25
+37
+37
+37
+37
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular°
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+JERSEYCITY NJ
+WEST PALM
+FL
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW ALBANY OH
+UN. KINGDO
+UN. KINGDO
+W PALM BCH FL
+NACN
+WEST PALM
+NEW YORK
+NEW YORK
+MIAMI
+FL
+NY
+NY
+FL
+NACN
+MIAMI
+FL
+NACN
+NEW YORK
+NEW YORK
+NEW YORK
+MIAMI
+NY
+NY
+NY
+FL
+NACN
+JERSEYCITY
+NJ
+OAKLAND
+CA
+OAKLAND
+CA
+SAUSALITO
+CA
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+W PALM BCH FL
+NACN
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+01/09 3:0539P
+01/09
+3: 2006₽
+01/09
+3: 4018₽
+INCOMING
+01/09
+3: 4127₽
+01/09
+3: 5310₽
+INCOMING
+01/09
+3: 5421P
+01/09
+4: 0554P
+01/09
+4: 1547₽
+01/09
+4: 1624P
+01/09
+4: 2251₽
+INCOMING
+01/09
+4:2402P
+01/09
+4: 2902₽
+01/09
+5:5834P
+01/09
+5:5910P
+01/09
+6: 4311P
+INCOMING
+01/09
+6:4424P
+01/09
+7: 1521P
+INCOMING
+01/09
+7: 1631P
+01/09
+7:2423P
+01/09
+7: 4004P
+01/09
+7: 4906P
+01/09
+8: 0117P
+INCOMING
+01/09
+8: 0231P
+01/09
+9: 3912P
+01/10 12:2943A
+01/10 12: 3036A
+01/10 12:3105A
+01/10 12:4157A
+INCOMING
+01/10 12:4308A
+01/10 12:5523A
+01/10 12:3418P
+INCOMING
+01/10 12:3428P
+DUR
+1
+1
+2
+0
+1
+1
+4
+N AN
++ O
+1
+8
+1
+10
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+. 35
+.35
+0
+0
+• 00
+• 0 o
+• o
+0
+0
+0
+0
+• 35
+• 35
+0
+0
+0
+0
+0
+0
+37
+37
+25
+37
+25
+37
+37
+37
+37
+25
+37
+37
+37
+7
+25
+37
+25
+37
+37
+37
+37
+25
+37
+37
+37
+37
+37
+25
+37
+37
+25
+37
+Page 7
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NY
+W PALM BCH FL
+NACN
+DIR. ASST.
+WEST PALM FI
+W PALM BCH FL
+NACN
+NEW YORK
+NEW YORK
+NY
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+OAKLAND
+OAKLAND
+NY
+CA
+CA
+W PALM BCH FL
+NACN
+WEST PALM
+FL
+W PALM BCH FL
+NACN
+SEBASTIAN
+FL
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+OAHU
+HI
+W PALM BCH FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+01/10 2:0855₽
+01/10 4:1408P
+INCOMING
+01/10
+4: 1527P
+01/10
+4: 2101₽
+01/10
+4: 2102P
+01/10
+4: 3553P
+INCOMING
+INCOMING
+01/10
+4: 3703P
+01/10
+4: 3737₽
+01/10
+4: 3805P
+01/10
+5:4928₽
+INCOMING
+01/10
+5: 5037₽
+01/10
+5: 5525P
+INCOMING
+01/10
+5: 5634P
+01/10
+6: 0318P
+INCOMING
+INCOMING
+01/10
+6: 0426P
+01/10
+6: 4056P
+01/10
+6:4650P
+01/10
+6: 4732P
+01/11 10:1038A
+INCOMING
+01/11 10:1149A
+01/11 10:1253A
+01/11 10:1333A
+INCOMING
+01/11 10:1441A
+01/11 10:1616A
+01/11 11:2928A
+INCOMING
+01/11 11:2938A
+01/11 12:1857P
+INCOMING
+01/11 12:2007P
+01/11 1:1958P
+INCOMING
+01/11 1:2108P
+01/11 2:2754P
+01/11 3:1250P
+DUR
+1
+0
+0
+2
+0
+1
+0
+2
+5
+0
+MHO
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+• 00
+• 0 o
+• 00
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+37
+25
+37
+37
+37
+25
+37
+37
+37
+25
+37
+25
+37
+2
+5
+37
+37
+37
+37
+37
+25
+37
+37
+25
+37
+25
+37
+25
+37
+37
+25
+Page 8
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+NEW YORK
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+MOBILE
+NEW YORK
+NY
+MOBILE
+W PALM BCH FL
+NACN
+NEW YORK
+WILLOUGHBY OH
+NEW YORK
+QUEENS
+NY
+NY
+NY
+W PALM BCH FL
+NACN
+QUEENS
+NY
+WILLOUGHBY OH
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+01/11 3:1359P
+01/11 4:5347₽
+INCOMING
+INCOMING
+INCOMING
+01/11 4:5453P
+01/11 4:5557P
+01/11
+5:0835P
+01/11
+5:1154P
+INCOMING
+01/11 |
+5:1304P
+01/11
+5:2214P
+INCOMING
+01/11
+5:2331P
+01/11 5:3059P
+INCOMING
+01/11
+5: 3209P
+01/11 6:1452₽
+INCOMING
+01/11 6:1604P
+01/11
+6: 1653P
+INCOMING
+01/11
+6: 3551P
+01/11
+6: 3632P
+01/11
+6: 4931P
+INCOMING
+INCOMING
+01/11
+6: 5048P
+01/11
+9: 3651P
+01/11
+9:3843P
+INCOMING
+01/12 12:0235A
+01/12 10:1242A
+01/12 10:3419A
+INCOMING
+01/12 10:3527A
+01/12 10:4505A
+01/12 10:5035A
+01/12 11:0647A
+INCOMING
+01/12 11:0800A
+01/12 11:0835A
+INCOMING
+01/12 11:0944A
+01/12 11:1744A
+INCOMING
+01/12 11:1851A
+DUR
+2
+1
+2
+2
+0
+4
+4
+2
+1
+2
+0
+2
+1
+2
+0
+2
+3
+O H
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+37
+25
+37
+37
+37
+25
+37
+25
+37
+25
+37
+25
+37
+37
+5
+37
+37
+37
+37
+37
+25
+37
+37
+37
+25
+37
+25
+37
+25
+37
+Page 9
+
+
+
+06:03:06
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+WEST PALM
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+FL
+NY
+NY
+NY
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NEW YORK
+W PALM BCH
+NY
+NY
+FL
+NACN
+NWYRCYZN01
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK NY
+NEW YORK
+NY
+W PALM BCH
+FL
+NACN
+UN. KINGDO
+NEW YORK
+NEW YORK
+NY
+NY
+NEW YORK NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/12 11:2534A
+01/12 11:2641A
+01/12 11:3649A
+01/12 11:3758A
+01/12 11:5002A
+01/12 11:5106A
+01/12 11:5126A
+01/12 11:5254A
+01/12 12:3525P
+01/12 12:5344P
+01/12 12:5452P
+01/12 1:2726P
+01/12
+1: 2834P
+01/12
+2:0736P
+01/12
+2:0817P
+01/12
+2: 2126P
+01/12
+2:2233P
+01/12
+3:2538P
+01/12
+3:2900P
+01/12
+3: 2909P
+01/12
+4:1615P
+01/12 4:1721P
+01/12
+4:2719P
+01/12
+4: 2826P
+01/12
+4: 4729P
+01/12
+4: 4830₽
+01/12
+4: 5214P
+01/12
+4: 5321P
+01/12
+5:1746P
+01/12
+5: 5017₽
+01/12
+5: 5131P
+01/12
+5: 5622P
+DUR
+1
+1
+1
+1
+0
+1
+NHO
+2
+0
+0
+HAMO
+5
+2
+HN N
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+25
+37
+25
+37
+37
+37
+37
+37
+37
+25
+37
+25
+37
+37
+° ° °
+_• C
+0 O
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+37
+25
+37
+25
+37
+37
+37
+25
+37
+37
+37
+37
+37
+0 H
+Page10
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+NY
+NEW YORK
+NEW YORK
+OAHU
+MOBILE
+NY
+NY
+HI
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+01/12
+6: 1031P
+INCOMING
+01/12
+6: 1138₽
+01/12
+6: 1258₽
+INCOMING
+INCOMING
+INCOMING
+01/12
+6: 1407₽
+01/12
+8: 2333P
+01/12
+9:2020₽
+01/12
+9: 2216P
+INCOMING
+01/12
+9: 2342₽
+01/12
+9:2410P
+01/12
+9: 2505P
+01/12
+9:4117P
+01/12
+01/12
+11/12
+INCOMING
+01/12 10:4327P
+01/12 10:4436P
+01/12 10: 4515₽
+01/12 11:2025P
+01/12 11:2239P
+DUR
+2
+1
+4
+2
+1
+1
+3
+9
+- N
+35
+2
+2
+AIR
+0
+LAND TOTAL RSYS
+0
+0
+000 O
+• 0 • •
+00
+0
+• o
+0
+0
+25
+37
+25
+37
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+LAM
+Not
+for
+use
+or
+PROPRIETARY AND CONFIDENTIAL
+disclosure outside Cingular Wireless
+Page11
+
+
+
+Account:
+MOBILE
+ESN
+X cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NEW YORK
+US VIRGI
+NEW YORK
+Local Call
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+US VIRGI
+NEW YORK
+FLORIDA
+NEW YORK
+FLORIDA
+US VIRGI
+FLORIDA
+NEW YORK
+NEW YORK
+NEW YORK
+FLORIDA
+Local Call
+N CAROLI
+NEW YORK
+NEW YORK
+FLORIDA
+UN. KINGDO
+UN. KINGDO
+UN. KINGDO
+UN. KINGDO
+NY
+NY
+VI
+NY
+NY
+NY
+NY
+NY
+VI
+NY
+FL
+NY
+FL
+VI
+FL
+NY
+NY
+NY
+FL
+NC
+NY
+NY
+FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/01 1:0919A
+01/01 1:1114A
+01/01
+3: 4158P
+01/01
+3: 5216P
+01/01
+4: 1710P
+01/01
+4: 2001P
+01/01
+4:2909P
+01/02
+1:2501P
+01/02
+1:2550P
+01/02
+1:2710P
+01/02
+3: 5804P
+01/02
+3:5957P
+01/02
+4: 0442P
+01/02
+5:0254P
+01/02
+5: 0529P
+01/02
+5: 0616P
+01/03
+5:2854P
+01/03
+11:0519P
+01/03 11:0617P
+01/03 11:0841P
+01/04
+1:4729P
+01/04 2:0713P
+01/04
+2: 4138P
+01/04
+2:5453P
+01/04
+2: 5544P
+01/13 12:1414A
+01/13
+1: 3823A
+01/13
+8: 3702A
+01/13
+8: 5636A
+01/13
+8: 5922A
+01/13
+9: 0016A
+01/13
+9: 0100A
+DUR
+1
+1
+2
+1
+2
+2
+2
+1
+2
+1
+1
+1
+3
+25
+1
+1
+1
+2
+1
+1
+1
+1
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+LAND TOTAL RSYS
+. 99
+. 82
+1.81 8160
+. 99
+. 82
+1.81
+8160
+6.93
+5.71
+12.64
+8160
+1.98
+1.63
+3.61
+8160
+. 99
+.08
+1.07
+8160
+.99
+• 82
+1.81
+8160
+.99
+. 82
+1.81
+8160
+. 99
+. 82
+1.81
+8160
+.99
+.82
+1.81
+8160
+1.98
+1.63
+3.61
+8160
+1.98
+1.63
+3.61
+8160
+. 99
+. 82
+1.81
+8160
+3.96
+3.26
+7.22
+8160
+1.98
+1.63
+3.61
+8160
+. 99
+. 82
+1.81
+8160
+.99
+.82
+1.81
+8160
+1.98
+1.63
+3.61
+8160
+. 99
+.82
+1.81
+8160
+.99
+.82
+1.81
+8160
+. 99
+. 82
+1.81
+8160
+2.97
+.23
+3.2
+8160
+24.75 20.38 45.13 8160
+. 99
+.99
+.82
+1.81
+8160
+.82
+1.81
+8160
+.99
+. 82
+1.81
+8160
+25
+1.05
+1.05
+25
+25
+25
+25
+,35
+.35
+25
+25
+Page12
+
+
+
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NY
+NEW YORK
+NY
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+NEW YORK
+NY
+NEW ALBANY OH
+NEW YORK NY
+MOBILE
+NY
+UN. KINGDO
+NEW YORK
+NEW YORK
+NY
+NY
+WILLOUGHBY OH
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+01/13 9:0632A
+INCOMING
+01/13
+9:0818A
+INCOMING
+01/13
+9:1546A
+INCOMING
+01/13 9:4331A
+INCOMING
+01/13
+9: 5335A
+INCOMING
+01/13 9:5859A
+INCOMING
+01/13 10:3000A
+INCOMING
+01/13 10:3240A
+01/13 10:3819A
+01/13 10:4013A
+01/13 10:5108A
+INCOMING
+01/13 10:5246A
+01/13 10:5559A
+01/13 11:0032A
+01/13 11:0256A
+01/13 11:0627A
+INCOMING
+INCOMING
+INCOMING
+01/13 11:0707A
+01/13 11:0858A
+01/13 11:1049A
+01/13 11:1523A
+01/13 11: 2656A
+01/13 11: 3925A
+INCOMING
+INCOMING
+01/13 11: 4624A
+01/13 11:5152A
+01/13 11: 5259A
+INCOMING
+01/13 11:5521A
+01/13 12:0032P
+01/13 12:0227P
+01/13 12:0713P
+INCOMING
+01/13 12:2544P
+01/13 12:2746P
+INCOMING
+01/13 12:2950P
+DUR
+1
+2
+2
+3
+3
+1
+M AM
+4
+2
+3
+2
++ m
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+* cingular®
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2.
+25
+25
+25
+0
+• 35
+0
+• 35
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page13
+
+
+
+Account:
+MOBILE
+ESN
+X cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+W PALM BCH FL
+W PALM BCH FL
+W PALM BCH FL
+MOBILE
+NY
+NEW YORK
+NY
+CHARLI AML VI
+CHARLI AML VI
+NEW YORK
+NY
+NEW YORK
+NY
+NEW YORK
+NEW YORK
+NEW ALBANY
+NY
+NY
+OH
+NEW YORK
+MOBILE
+NY
+NY
+MOBILE
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NEW YORK NY
+NEW ALBANY OH
+ANS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/13 12:3118P
+01/13 12: 3326P
+01/13 12:4109P
+01/13 12:4224P
+01/13
+1: 0902P
+01/13
+1:1258P
+01/13
+1:1512P
+01/13
+1:1625P
+01/13
+1:2141P
+01/13 1:2220P
+01/13
+1: 3353P
+01/13
+1: 3641P
+01/13
+1: 3826P
+01/13
+1: 3943P
+01/13
+1: 4540P
+01/13
+1:5854P
+01/13
+2: 0206P
+01/13
+2:0918P
+01/13
+2:1001P
+01/13
+2:1239P
+01/13 2:1502P
+01/13 2:2306P
+01/13
+2: 3409₽
+01/13
+2:3441P
+01/13
+3: 2018P
+01/13
+3: 3435₽
+01/13
+3: 3708P
+01/13
+3: 3746₽
+01/13
+3: 3905₽
+01/13
+3: 4346₽
+01/13
+3: 4957₽
+01/13 4:0122P
+DUR
+1
+1
+3
+26
+1
+2
+5
+1
+1
+1
+3
+1
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+. 4
+0
+0
+0
+0
+. 4
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2
+0
+0
+0
+0
+0
+0
+• a
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page14
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NY
+NWYRCYZNO1 NY
+NEW YORK
+NEW YORK
+NEW YORK
+UN. KINGDO
+NEW YORK
+NY
+NY
+NY
+NY
+UN. KINGDO
+NEW YORK
+NY
+NEW YORK
+NY
+NEW YORK
+NEW YORK
+NY
+NY
+NEW YORK
+NEW YORK
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+01/13 4: 0652P
+INCOMING
+01/13 4:1857P
+01/13 4:2518P
+01/13 4: 3251P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/13
+4: 3354P
+01/13 4:5202P
+01/13 5:0358P
+01/13
+5:0519P
+01/13
+5: 0628P
+01/13 5:0702P
+01/13
+6: 0219P
+01/13 6:0513P
+01/13
+6: 0823P
+INCOMING
+INCOMING
+01/13
+6:2941P
+01/13
+7: 0243P
+01/13
+7: 0327P
+01/13
+7: 1103P
+INCOMING
+INCOMING
+01/13
+7:2748P
+01/13
+7: 3441P
+01/13
+7: 3538P
+INCOMING
+INCOMING
+01/13
+8: 0306P
+01/13 8:0614P
+01/13
+8: 0645P
+01/13
+8: 1952₽
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/13
+8: 2741P
+01/13 11:1023P
+01/14
+9: 2918A
+01/14
+9: 3211A
+01/14
+9: 3516A
+01/14
+9: 4545A
+01/14
+9:4850A
+01/14
+9: 4945A
+DUR
+5
+1
+1
+2
+3
+1
+1
+1
+1
+3
+N AN
+1
+In N
+1
+HAN
+1
+5
+5
+1
+2
+1
+3
+1
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2
+5
+2
+5
+0
+0
+0
+0
+0
+0
+0
+roooi
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page15
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NEW YORK
+NEW YORK
+DIR. ASST.
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+NEW YORK
+NY
+NEW YORK
+NY
+NEW YORK
+MOBILE
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+UN. KINGDO
+UN. KINGDO
+NEW ALBANY OH
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+01/14 9:5105A
+01/14
+9:5900A
+01/14 10:0041A
+01/14 10:0309A
+01/14 10:0604A
+01/14 10:0605A
+01/14 10:0827A
+INCOMING
+INCOMING
+01/14 11:1528A
+01/14 11:1712A
+01/14 12:3438P
+INCOMING
+01/14 12:3518P
+01/14 12: 3620P
+INCOMING
+01/14 12:3840P
+01/14 12:5114P
+01/14 12:5258P
+01/14 12:5604P
+01/14
+1:1732P
+01/14
+1: 5308P
+INCOMING
+INCOMING
+01/14
+2:0055P
+01/14
+2:2939P
+01/14
+2: 3042P
+01/14
+2: 3125P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/14
+2: 4822₽
+01/14
+2: 5338P
+01/14
+3: 1130₽
+01/14
+4: 4618₽
+01/14
+4: 5546₽
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/14
+4: 5637₽
+01/14
+6: 3843₽
+01/14
+6: 5452₽
+01/14
+7: 0533P
+01/14 7:1529P
+DUR
+1
+2
+2
+2
+1
+1
+1
+3
+1
+3
+#N N
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+• 35
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+• 35
+• 7
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 16
+
+
+
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+UN. KINGDO
+OAHU
+MOBILE
+NEW YORK
+HI
+NY
+NY
+NEW YORK
+NY
+NEW YORK
+NEW YORK
+NY
+NY
+NEW YORK
+NY
+NEW YORK
+MOBILE
+NY
+NY
+W PALM BCH FL
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NEW YORK
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+01/14 8:5945P
+01/14
+9:0027P
+INCOMING
+01/14
+9: 0114P
+01/14
+9:0351P
+01/14
+9:0842P
+01/14
+9:4551P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/14 11:1512P
+01/15 8:4831A
+01/15 10:0756A
+01/15 10:1744A
+01/15 10:1812A
+INCOMING
+01/15 10:2738A
+01/15 10:2938A
+01/15 10:3009A
+INCOMING
+01/15 10:4616A
+01/15 10:5829A
+INCOMING
+INCOMING
+INCOMING
+01/15 11:0045A
+01/15 11:0319A
+01/15 11:0417A
+01/15 11:1015A
+01/15 11:2851A
+01/15 11:2947A
+INCOMING
+01/15 11:3804A
+01/15 11:3945A
+01/15 11:4057A
+01/15 11:5048A
+INCOMING
+01/15 11:5543A
+01/15 12:1840P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/15 12:4433₽
+01/15
+1:1939P
+01/15
+1: 5252P
+01/15
+2: 0829P
+DUR
+1
+1
+2
+1
+2
+1
+3
+5
+3
+1
+1
+NAMM
+N N
+HAM AN
+1
+2
+2
+1
+2
+1
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+X cingular®
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+• 35
+• 35
+0
+0
+0
+0
+0
+0
+• C
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2.
+25
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 17
+
+
+
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+UN. KINGDO
+NEW ALBANY OH
+NEW YORK
+NY
+UN. KINGDO
+NEW YORK
+NY
+NEW YORK
+MOBILE
+NY
+NY
+MOBILE
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+01/15 2:1849P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/15
+2: 2603P
+01/15
+2: 3138P
+01/15
+2:3301P
+01/15
+2: 3653P
+01/15
+3: 1311P
+01/15
+3: 1905P
+INCOMING
+INCOMING
+01/15
+4:2239P
+01/15
+4: 3335P
+01/15 5:0903₽
+INCOMING
+01/15 5:1305P
+01/15 5:2125P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/15
+5:2252P
+01/15
+5:2655P
+01/15
+5: 3806P
+01/15
+5: 4529P
+01/15
+6:2419P
+INCOMING
+INCOMING
+INCOMING
+01/15
+6: 5135P
+01/15
+7: 0612P
+01/15
+7:1635P
+01/15 7:1903P
+01/15 7:2046P
+INCOMING
+INCOMING
+01/15
+7: 2217₽
+01/15
+8: 0939P
+01/15
+8: 2818P
+01/16 12:3639A
+INCOMING
+01/16 12:3747A
+01/16 10:1646A
+INCOMING
+01/16 10:1755A
+01/16 10:3012A
+INCOMING
+INCOMING
+01/16 10:3121A
+01/16 10:4934A
+DUR
+1
+1
+1
+4
+1
+3
+2
+5
+1
+1
+N HN M
+2
+1
+10
+5
+3
+2
+1
+0
+1
+0
+1
+OH M
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+cingular®
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+• 35
+• 35
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+5
+25
+0
+• • •
+• 0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+2
+2
+25
+25
+25
+25
+25
+25
+37
+25
+37
+25
+37
+37
+Page18
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+UN. KINGDO
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+DIR. ASST.
+NEW YORK
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+WILLOUGHBY OH
+W PALM BCH FL
+NACN
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+01/16 11:3735A
+INCOMING
+INCOMING
+01/16 11:3843A
+01/16
+1: 0633P
+01/16
+1: 4109₽
+INCOMING
+01/16
+1:4217P
+01/16
+2:5439₽
+INCOMING
+INCOMING
+01/16
+2: 5547₽
+01/16
+4:2427₽
+01/16
+4: 2844P
+01/16
+4: 3307₽
+INCOMING
+01/16
+4: 3416₽
+01/16 4:5204P
+INCOMING
+01/16
+4: 5312P
+01/16
+5:2
+INCOMING
+01/16
+5:2441P
+01/16
+5: 3130P
+INCOMING
+01/16
+5:3243P
+01/16
+5:4445P
+INCOMING
+01/16
+5: 4553P
+01/16 10:1457P
+INCOMING
+01/16 10:1605P
+01/16 10:5539P
+INCOMING
+01/17
+9: 2502A
+01/17
+9:2857A
+INCOMING
+01/17
+9: 3004A
+01/17 10:3531A
+INCOMING
+01/17 10:3638A
+01/17 10:5438A
+INCOMING
+01/17 10:5545A
+01/17 11:1134A
+01/17 11:2244A
+INCOMING
+01/17 11: 2357A
+DUR
+0
+2
+2
+0
+0
+2
+2
+2
+1
+0
+22
+2
+1
+0
+2
+0
+2
+0
+4
+HON
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+25
+37
+37
+0
+25
+37
+0
+25
+37
+37
+1.05
+1.05
+37
+25
+37
+25
+0
+37
+2.
+5
+• 00
+• 0 o
+• 00
+0
+0
+0
+0
+0
+0
+0
+0
+0
+2
+25
+37
+15
+37
+2
+5
+37
+37
+37
+25
+37
+25
+37
+25
+37
+37
+25
+37
+Page19
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+W PALM BCH FL
+NACN
+WEST PALM FL
+UN. KINGDO
+W PALM BCH FL
+NACN
+WEST PALM
+NEW YORK
+NEW YORK
+FL
+NY
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+WILLOUGHBY OH
+NACN
+QUEENS
+NY
+WEST PALM
+FL
+NEW YORK
+NY
+NEW YORK
+NY
+WEST PALM
+FL
+WILLOUGHBY OH
+WEST PALM FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+01/17 11:4210A
+INCOMING
+01/17 11:4323A
+01/17 11:4904A
+01/17 11:5641A
+01/17 11:5818A
+INCOMING
+01/17 11:5930A
+01/17 12:0049P
+01/17 12:5404P
+INCOMING
+01/17
+1: 3627P
+01/17
+2: 0916₽
+INCOMING
+01/17
+2: 1024P
+01/17
+2: 1545P
+INCOMING
+01/17
+2:1653P
+01/17
+3: 2027P
+INCOMING
+INCOMING
+01/17
+3: 2135P
+01/17
+4: 5042P
+01/17
+5:5614P
+INCOMING
+01/17
+5: 5720P
+01/17
+6: 0406P
+INCOMING
+01/17
+6:0511P
+01/17
+6: 1456₽
+INCOMING
+01/17
+6: 1602₽
+01/17|
+7: 0330₽
+01/17
+7: 0348P
+INCOMING
+01/17
+7: 0435P
+01/17
+7: 0540₽
+01/17
+7: 0559₽
+INCOMING
+01/17
+8: 3145P
+01/17
+9:5203₽
+01/18 10:0854A
+01/18 10:1002A
+01/18 10:1127A
+DUR
+0
+2
+3
+1
+1
+1
+1
+ONO
+• H W
+0
+0
+2
+0
+HAN
+N H
+1
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+25
+37
+37
+1.05
+0
+1.05
+37
+25
+37
+37
+0
+37
+37
+0
+0
+25
+37
+25
+0
+37
+2.
+5
+0
+0
+0 0 0
+0 0 0
+00 O
+• 00
+0
+0
+0
+0
+0
+0
+0
+0
+37
+37
+2
+5
+37
+25
+37
+25
+37
+37
+37
+37
+37
+37
+37
+37
+37
+Page 20
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+BROOKLYN
+NEW YORK
+BROOKLYN
+NEW YORK
+NEW YORK
+NEW YORK
+WEST PALM
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+FL
+W PALM BCH FL
+NACN
+NEW YORK
+NEW YORK
+NY
+NY
+UN. KINGDO
+NEW YORK
+W PALM BCH
+NY
+FL
+NACN
+W PALM BCH FL
+NACN
+WEST PALM
+FL
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+WILLOUGHBY OH
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+NEW YORK
+NY
+WILLOUGHBY OH
+NEW YORK NY
+NEW YORK
+NY
+W PALM BCH FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/18 10:5844A
+01/18 11:0156A
+01/18 11:0241A
+01/18 11:0323A
+01/18 11:2614A
+01/18 11:2636A
+01/18 12:1159P
+01/18 12:2708P
+01/18 12:5743P
+01/18 12:5854P
+01/18
+1:1337P
+01/18
+1:2732P
+01/18
+1: 2922P
+01/18
+1:3513P
+01/18
+1: 3725P
+01/18
+1: 3830P
+01/18
+2: 3907P
+01/18
+2:4014P
+01/18
+4: 3737P
+01/18
+4: 5413P
+01/18
+4: 5521P
+01/18
+5:3824P
+01/18
+5: 3932₽
+01/18
+6: 0804P
+01/18
+6: 1655₽
+01/18
+6: 1803₽
+01/18
+7: 0252₽
+01/18
+9:2021P
+01/18
+9:2405₽
+01/19 11:1057A
+01/19 11:4438A
+01/19 12:0808P
+DUR
+2
+1
+1
+2
+1
+1
+1
+1
+0
+2
+11
+N N$
+NONMON
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+37
+37
+37
+37
+37
+37
+37
+37
+25
+37
+37
+37
+37
+0500
+0
+0
+0
+0
+0
+0
+0
+0
+0
+• 0
+0 0 0 0 0 O
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+37
+5
+37
+25
+37
+37
+25
+37
+37
+37
+37
+37
+37
+25
+Page21
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NACN
+NEW YORK
+NY
+NEW YORK
+NY
+W PALM BCH FI
+NACN
+NEW YORK
+NY
+W PALM BCH FI
+NACN
+W PALM BCH FL
+NEW YORK
+NY
+NACN
+NEW YORK
+NY
+FRANCE
+UN. KINGDO
+W PALM BCH
+FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FI
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK NY
+W PALM BCH FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+01/19 12:0922P
+INCOMING
+01/19 12:1914P
+INCOMING
+01/19
+2:0020P
+01/19
+2:4938P
+INCOMING
+INCOMING
+01/19
+2: 5051P
+01/19
+3: 1837P
+01/19
+3: 4504₽
+INCOMING
+01/19
+3: 4612₽
+01/19
+4:1530P
+INCOMING
+INCOMING
+INCOMING
+01/19 4:1558₽
+01/19 4:1635P
+01/19 4:3614P
+01/19
+4: 3706P
+01/19
+4: 3852P
+01/19
+4: 4026P
+INCOMING
+01/19
+4: 4142P
+01/19
+4:4146P
+INCOMING
+01/19
+4:4257P
+01/19
+4:4744P
+INCOMING
+01/19
+4: 4909P
+01/19
+4: 5049P
+INCOMING
+01/19
+4: 5201P
+01/19
+5:2238P
+INCOMING
+01/19
+5: 2346₽
+01/19
+5:2700₽
+INCOMING
+01/19
+5:2808P
+01/19
+5: 5325P
+INCOMING
+01/19
+5:5433P
+01/19
+5:5550₽
+INCOMING
+INCOMING
+01/19
+5:5700₽
+01/19
+5:5838₽
+01/19
+6:1037P
+DUR
+1
+1
+2
+0
+2
+1
+0
+2
+0
+5
+0
+HOHHO
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+LAND TOTAL RSYS
+0
+0
+. 7
+0
+0
+0
+0
+0
+0
+. 7
+• 35
+0
+0
+37
+37
+37
+25
+37
+37
+25
+37
+25
+37
+37
+37
+37
+25
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+37
+25
+37
+25
+37
+25
+37
+25
+37
+37
+25
+Page 22
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NACN
+QUEENS
+NY
+NEW YORK
+NY
+WEST PALM
+FL
+W PALM BCH FL
+W PALM BCH FL
+NACN
+NACN
+W PALM BCH FL
+NACN
+WEST PALM FL
+W PALM BCH FL
+NACN
+WEST PALM
+WEST PALM
+NEW YORK
+WEST PALM
+NEW YORK
+WEST PALM
+BROOKLYN
+NEW YORK
+NEW YORK
+FL
+FL
+NY
+FL
+NY
+FL
+NY
+NY
+NY
+W PALM BCH FL
+NACN
+WEST PALM FL
+MOBILE
+NEW YORK
+BROOKLYN
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+W PALM BCH FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+01/19 6:1103P
+01/19
+6:1453P
+INCOMING
+01/19
+7: 1219₽
+01/19
+7: 1504₽
+01/20 10:0447A
+01/20 10:0518A
+INCOMING
+INCOMING
+01/20 10:0556A
+01/20 10:0624A
+01/20 10:1319A
+INCOMING
+01/20 10:1436A
+01/20 10:2559A
+01/20 10:2640A
+INCOMING
+01/20 10:2747A
+01/20 10:2810A
+01/20 10:2930A
+INCOMING
+01/20 10:3134A
+01/20 10:3438A
+01/20 10:3907A
+01/20 10:3959A
+01/20 10:4412A
+01/20 10:4504A
+01/20 10:4918A
+01/20 10:5238A
+INCOMING
+01/20 10:5347A
+01/20 10:5454A
+01/20 11:1521A
+INCOMING
+01/20 11:4440A
+01/20 12:0714P
+01/20 12:0821P
+01/20 12:1017P
+01/20 12:1208P
+01/20 12:1307P
+DUR
+1
+2
+1
+1
+3
+0
+2
+2
+1 H
+3
+1
+1
+HN M
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+• 0 o
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+37
+37
+37
+37
+25
+25
+37
+37
+25
+37
+37
+25
+37
+17
+37
+37
+37
+31
+37
+37
+37
+37
+25
+37
+37
+37
+37
+37
+37
+37
+37
+25
+Page 23
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NACN
+NEW YORK
+NY
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+WEST PALM
+• FL
+W PALM BCH FL
+NACN
+UN. KINGDO
+NEW YORK
+NY
+UN. KINGDO
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+UN. KINGDO
+UN. KINGDO
+BROOKLYN
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NEW YORK
+NEW YORK
+QUEENS
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+W PALM BCH FL
+NACN
+NEW YORK
+NEW YORK
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+01/20 12:1413P
+INCOMING
+01/20 12:5709P
+01/20 12:5721P
+INCOMING
+01/20 12:5826P
+01/20
+1: 0230P
+01/20
+1: 0415P
+01/20
+1:3627P
+INCOMING
+01/20
+1: 3734P
+01/20
+1: 4322P
+INCOMING
+01/20
+2: 1644₽
+01/20
+2:1717₽
+01/20
+2: 2618P
+INCOMING
+01/20
+2:2727P
+01/20
+2:2823P
+INCOMING
+INCOMING
+01/20
+2: 2932P
+01/20
+2:4158P
+01/20
+2:4236P
+01/20
+2:4253P
+01/20
+2:5052P
+01/20
+3: 0659P
+INCOMING
+01/20
+3: 0820P
+01/20 4:0856P
+INCOMING
+01/20
+4: 1012₽
+01/20
+4: 3051P
+01/20
+4:5430P
+INCOMING
+01/20
+5:2710P
+01/20
+5: 3741P
+INCOMING
+01/20
+5: 3845P
+01/20
+5:5208₽
+INCOMING
+01/20
+5: 5331P
+01/20
+5:5545P
+01/20 5:5733P
+DUR
+1
+2
+1
+1
+2
+0
+2
+1
+7
+2
+HAMO
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+1.05
+2.45
+0
+. 3
+5
+. 3
+5
+0
+• o
+0
+0
+0
+0
+0
+1.05
+2.45
+• 0
+0
+35
+3
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+37
+37
+25
+37
+37
+37
+25
+37
+37
+37
+37
+25
+37
+2
+5
+37
+37
+2
+5
+37
+25
+37
+37
+37
+37
+37
+37
+25
+37
+37
+37
+Page 24
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+MOBILE
+MOBILE
+NEW YORK
+NEW YORK
+NEW YORK
+MOBILE
+MOBILE
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+01/20 6:0820P
+INCOMING
+01/20 8:4556P
+01/20 8:5401P
+01/20
+9:0005P
+INCOMING
+01/20
+9:4101P
+01/20
+9: 4126P
+01/20
+9:5240₽
+INCOMING
+INCOMING
+INCOMING
+01/20 10:3202P
+01/20 10:3330P
+01/20 10:3717P
+01/20 10:5637P
+01/20 11:0249P
+01/20 11:1340P
+INCOMING
+INCOMING
+01/21
+9:1334A
+01/21
+9:1427A
+01/21
+9: 2342A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/21
+9:2536A
+01/21
+9: 4838A
+01/21 11:0703A
+01/21 11:2910A
+01/21 11: 3015A
+01/21 12:2826P
+01/21 12:2956P
+01/21
+1: 0148P
+01/21
+1:2547P
+01/21
+1: 2618P
+01/21
+1: 3213P
+01/21
+1: 3843P
+01/21
+1: 3919P
+01/21
+1:4240P
+01/21
+1: 4652₽
+INCOMING
+01/21
+2:0418P
+DUR
+4
+10
+1
+2
+1
+1
+2
+1
+1
+1
+2
+H H
+5
+2
+17
+HAN
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+37
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+5
+25
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 25
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+MOBILE
+MOBILE
+NY
+NY
+OAHU
+HI
+NWYRCYZNO1 NY
+MOBILE
+NY
+NEW YORK
+NY
+NEW ALBANY
+OH
+MOBILE
+NY
+NEW YORK
+MOBILE
+MOBILE
+NEW YORK
+MOBILE
+NY
+NY
+NY
+NY
+NY
+W PALM BCH FL
+NEW YORK NY
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+01/21 2:0450₽
+01/21
+2: 0727P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/21
+2: 5205P
+01/21
+3: 0437₽
+01/21
+3: 3116₽
+01/21
+3: 4346₽
+01/21
+4: 0434P
+01/21
+4: 0736P
+INCOMING
+INCOMING
+01/21
+4:2330P
+01/21 4:2457₽
+01/21 4:2536P
+01/21 4:5117P
+01/21
+4: 5359P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/21
+4: 5941P
+01/21
+5: 1710P
+01/21
+5:2447P
+01/21
+6:0105P
+01/21
+6: 1937P
+01/21
+7: 2232P
+INCOMING
+01/21
+7:2323P
+01/21
+7:2533P
+01/21 7:2609P
+01/21
+7: 3412₽
+01/21
+7: 3436₽
+01/21
+7: 3533P
+01/21
+7: 5607₽
+INCOMING
+01/21
+8: :0023P
+01/21
+8: 1436P
+INCOMING
+01/21
+9: 1801P
+01/21
+9:1913P
+01/21
+9:2110P
+01/21
+9: 2156P
+DUR
+1
+1
+1
+5
+1
+1
+2
+2
+1
+3
+17
+HAAAAAH
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+• 0 o
+• 00
+000a
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 26
+
+
+
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+LOSANGELES CA
+MOBILE
+NY
+NEW YORK
+NY
+MOBILE
+NEW YORK
+NY
+NY
+NEW YORK
+NEW YORK
+GARDENA
+NY
+NY
+CA
+NEW YORK
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+01/21 11:2354P
+INCOMING
+01/21 11:2518P
+INCOMING
+01/22 8:2723A
+INCOMING
+01/22 10:3118A
+INCOMING
+01/22 11: 0312A
+01/22 11: 2616A
+INCOMING
+INCOMING
+INCOMING
+01/22 11: 3346A
+01/22 11:3551A
+01/22 11:5023A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/22 11:5131A
+01/22 12:0923P
+01/22 12:1714P
+01/22 12:3717P
+01/22
+1:0141P
+01/22
+1: 3110P
+INCOMING
+01/22
+1:5047P
+01/22
+1:5333P
+INCOMING
+01/22
+2:3420P
+01/22
+4: 5045P
+01/22
+4: 5544P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/22
+5:0842P
+01/22
+5:1937₽
+01/22
+5: 3242P
+01/22
+5:4023₽
+01/22
+6: 3232P
+01/22
+6: 4257₽
+01/22
+6: 4456₽
+01/22
+6: 5144P
+INCOMING
+INCOMING
+01/22 11:3449P
+01/23
+8: 0104A
+01/23
+8: 3344A
+INCOMING
+01/23 8:4953A
+DUR
+1
+1
+1
+1
+1
+1
+1
+2
+1
+2
+2
+2
+1
+5
+1
+2
+2
+4
+3
+5
+1
+1
+5
+2
+2
+2
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless
+X cingular®
+AIR
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2
+25
+0
+0
+0
+0
+0
+0
+0
+0
+• • 0 0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+D
+Page 27
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+MOBILE
+NEW YORK
+NEW YORK
+MOBILE
+NEW YORK
+MOBILE
+MOBILE
+MOBILE
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NWYRCYZN01 NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+01/23 9:1112A
+INCOMING
+01/23 9:1514A
+INCOMING
+01/23
+9:2212A
+INCOMING
+01/23 9:2250A
+INCOMING
+01/23 10:0434A
+INCOMING
+01/23 10:0746A
+INCOMING
+01/23 10:0911A
+INCOMING
+01/23 10:4248A
+INCOMING
+01/23 10:5449A
+01/23 12:5639P
+01/23 12:5731P
+01/23 1:0122P
+INCOMING
+01/23
+1:0210P
+01/23
+1:0331
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/23
+1: 0952P
+01/23
+1: 3637P
+01/23
+2:4357P
+01/23
+2: 4941P
+01/23
+2:5308P
+01/23
+4: 0659P
+01/23
+4: 1246P
+01/23
+4:2428P
+01/23
+4:2759P
+01/23
+4: 4103P
+01/23
+4: 4531₽
+01/23
+4: 5049P
+01/23
+5:2159P
+INCOMING
+01/23
+6: 0504P
+01/23
+6: 0628P
+INCOMING
+INCOMING
+01/23
+6:1031P
+01/23
+6: 3952P
+01/23
+7: 0234P
+DUR
+1
+3
+8
+2
+2
+1
+1
+1
+1
+1
+N A HANN
+2
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+• 00
+• 0
+• O
+0
+• C
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 28
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK NY
+W PALM BCH FL
+DIR. ASST.
+NEW YORK NY
+NWYRCYZN01 NY
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NEW YORK
+NY
+NWYRCYZN01
+NWYRCYZN01
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+NEW YORK
+NEW YORK
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+01/24 11:4943A
+01/24 11:5030A
+01/24 11:5830A
+01/24 11:5831A
+INCOMING
+01/24 3:1348P
+01/24
+3: 2817P
+INCOMING
+INCOMING
+01/24
+6: 2102P
+01/24
+7: 4108₽
+01/24
+7: 4225₽
+01/24
+7: 5024P
+01/24
+9:1902P
+INCOMING
+INCOMING
+01/24 11: 0025P
+01/24 11:0820P
+01/25 12:0742P
+INCOMING
+01/25 12:1727P
+01/25
+3: 1030P
+01/25
+3: 1423P
+01/25
+3: 1506P
+01/25
+6:2807P
+INCOMING
+01/25
+7:4011P
+01/26
+9: 1509A
+01/26 9:1854A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/26 10:2017A
+01/26 10:2253A
+01/26 10:3637A
+01/26 11:2554A
+01/26 12:2116P
+01/26 12:4822P
+01/26
+1: 0115P
+01/26
+1:2513P
+01/26
+1:2837P
+01/26 2:2846P
+DUR
+1
+4
+0
+2
+2
+2
+2
+5
+2
+1
+1
+1
+HAMM
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+0
+0
+0
+0
+0
+0
+0
+0
+0
+• 0
+° o
+0
+0
+0
+0
+0
+0
+2
+2
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 29
+
+
+
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NEW YORK
+MOBILE
+NEW YORK
+NEW YORK
+MOBILE
+NY
+NY
+NY
+NY
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+01/26 5:2248P
+INCOMING
+01/26 5:5954P
+INCOMING
+01/26 6: 0138P
+INCOMING
+01/26 6:5511₽
+INCOMING
+01/26 7:0554P
+INCOMING
+01/26 7:1440₽
+INCOMING
+01/26 7:2111P
+INCOMING
+01/26
+7:3741P
+01/26 7:3906P
+01/26 7:4506₽
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/26 8:1801₽
+01/26 8:2616P
+01/26 8:4034P
+01/26
+9:1604P
+01/26
+9:1722P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/26
+9: 3533P
+01/27
+9:0851A
+01/27
+9:1054A
+01/27
+9:1459A
+01/27
+9:1754A
+01/27
+9:2429A
+01/27 9:4547A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/27 10:5351A
+01/27 11:2639A
+01/27 11:4031A
+01/27
+1:2635₽
+01/27
+2:4011P
+01/27
+2: 4116P
+INCOMING
+01/27
+3: 0618₽
+01/27
+3: 0859P
+INCOMING
+INCOMING
+01/27
+3: 0922P
+01/27 3:4125P
+DUR
+2
+2
+4
+1
+2
+4
+1
+1
+2
+1
+2
+2
+2
+2
+1
+9
+2
+HMMAAN
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+X cingular®
+AIR
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+0
+• 0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 30
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+DIR. ASST.
+MOBILE
+MOBILE
+NY
+NY
+NEW YORK
+NY
+NWYRCYZN01 NY
+NEW YORK
+NEW YORK
+NY
+NY
+NEW YORK
+NEW YORK
+UN. KINGDO
+UN. KINGDO
+UN. KINGDO
+NEW YORK
+NY
+NY
+NY
+MOBILE
+NEW YORK
+NY
+NY
+MOBILE
+NEW YORK
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+01/27 4:2217P
+01/27
+5: 3211P
+01/27
+5: 3436P
+01/27
+5:3729P
+INCOMING
+01/27
+6: 1619P
+01/27
+6: 1903P
+01/27
+7:4206P
+INCOMING
+INCOMING
+01/27
+7: 4351P
+01/27
+8: 2707P
+01/27 8:3003P
+01/27
+8:4943P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/27
+8: 5741P
+01/27
+9: 1142P
+01/27
+9:1612P
+01/27
+10:1311P
+01/27
+10:5021P
+01/27|
+10:5428P
+01/28
+7: 4502A
+01/28
+7: 5055A
+01/28
+7: 5235A
+01/28
+8:4102A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/28
+9:2241A
+01/28
+9: 2959A
+01/28
+9:5708A
+01/28 10:1340A
+01/28 10:2242A
+01/28 10:3130A
+01/28 10:3920A
+INCOMING
+01/28 10:4035A
+01/28 10:4113A
+01/28 11:1706A
+INCOMING
+01/28 11: 2250A
+DUR
+1
+3
+1
+1
+2
+1
+3
+1
+2
+1
+HAN
+3
+1
+2
+1
+1
+1
+5
+4
+2
+1
+N A M
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+• 00
+. 4
+0
+• C
+0
+0
+0
+0
+0
+0
+0
+7
+i
+. 4
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2
+5
+2
+2
+2
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 31
+
+
+
+Account:
+MOBILE
+ESN
+X cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+MOBILE
+NEW YORK
+NEW YORK
+GAHANNA
+NEW YORK
+MOBILE
+NEW YORK
+NEW YORK
+MOBILE
+NEW YORK
+MOBILE
+NEW YORK
+CHARLT AML
+MOBILE
+NEW YORK
+MOBILE
+NEW YORK
+NEW YORK
+NEW YORK
+MOBILE
+NEW YORK
+NEW YORK
+MOBILE
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+VI
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/28 11:2845A
+01/28 11:5652A
+01/28 12:2439P
+01/28 12:2631P
+01/28 12:2752P
+01/28 12:4247P
+01/28 12:4337P
+01/28 12:4445P
+01/28 12:4926P
+01/28 12:5146P
+01/28 12:5604P
+01/28 12:5731P
+01/28
+1: 0638P
+01/28
+1:13
+:30P
+01/28
+1:1650P
+01/28
+1: 1710P
+01/28
+1:1823P
+01/28
+1: 3318P
+01/28
+2: 3243P
+01/28
+2:3943P
+01/28
+3: 1417P
+01/28
+3: 1531P
+01/28
+3: 3040₽
+01/28
+3: 5120₽
+01/28
+3: 5829P
+01/28
+4: 3635₽
+01/28
+5:0042P
+01/28
+5:0126P
+01/28
+5:0220P
+01/28
+5:0420₽
+01/28
+5: 0523P
+01/28
+5: 0554P
+DUR
+1
+3
+2
+1
+2
+1
+1
+3
+1
+2
+1
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+. 6
+• a
+0
+0
+0
+0
+0
+00
+• 6
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 32
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular°
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NY
+MOBILE
+NY
+MOBILE
+NY
+NEW YORK
+NY
+NEW YORK C NY
+NEW YORK C NY
+NEW YORK C NY
+NEW YORK C NY
+SANTURCE
+PR
+SANTURCE
+PR
+SANTURCE
+PR
+NEW YORK C
+NY
+BROOKLYN
+NY
+NACN
+NACN
+NACN
+SANTURCE
+PR
+BROOKLYN
+NY
+NEW YORK C NY
+NEW YORK C NY
+NACN
+SANTURCE
+PR
+NEW YORK C NY
+NEW YORK C NY
+NACN
+NEW YORK C NY
+SANTURCE
+PR
+NACN
+SANTURCE
+PR
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+01/28 5:0658₽
+INCOMING
+01/28
+5:0747P
+01/28
+5:1757₽
+INCOMING
+INCOMING
+01/28
+6: 2053P
+01/28
+6: 2930₽
+01/28
+7: 4058₽
+01/28
+7: 4214P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/29 12:1219A
+01/29 12:1326A
+01/29 10:1650A
+01/29 12:0543P
+01/29 12:2435P
+01/29 12:3045P
+01/29 12:3440P
+INCOMING
+01/29
+1:1103P
+01/29
+1: 1542P
+INCOMING
+INCOMING
+INCOMING
+01/29
+1: 2530P
+01/29
+1: 3144P
+01/29
+1: 3444P
+01/29
+2: 0436P
+01/29
+2:0843P
+INCOMING
+INCOMING
+INCOMING
+01/29 2:2243P
+01/29
+3: 0039₽
+01/29
+3: 0530₽
+01/29
+5: 3949P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+01/29
+6: 1942₽
+01/29
+6: 3933P
+01/29
+6: 3952₽
+01/29
+6: 4233₽
+01/29
+6: 4419₽
+INCOMING
+01/29
+7: 4523₽
+01/29
+7: 5623P
+DUR
+1
+1
+2
+2
+1
+1
+1
+2
+1
+0
+2
+3
+23
+0
+1
+1
+1
+2
+0
+3
+3
+1
+0
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+• 69
+• 69
+1.38
+• 69
+0
+• 69
+2.76
+1.38
+2.07
+15.87
+0
+• 69
+• 69
+.69
+1.38
+0
+• 69
+2.07
+2.07
+2.07
+LAND TOTAL RSYS
+0
+0
+25
+25
+25
+25
+0
+0
+25
+25
+0
+0
+0
+0
+25
+.4
+. 6
+4.6
+• 69
+• 69
+1.38
+• 69
+4175
+40683
+40683
+40683
+25
+.8
+0
+.4
+•2
+• 6
+4.6
+. 69
+3.56
+1.38
+2.07
+15.87
+. 4
+.89
+• 69
+• 69
+1.38
+25
+25
+40683
+40683
+40683
+40683
+40683
+25
+40683
+40683
+40683
+0
+• 6
+40683
+25
+0
+0
+• 6
+• 69
+2.07
+2.07
+• 69
+• 6
+2.07
+• 4
+40683
+40683
+40683
+40683
+25
+40683
+25
+Page 33
+
+
+
+Account:
+MOBILE
+ESN
+X cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NACN
+BROOKLYN
+NY
+SANTURCE
+PR
+NEW YORK C NY
+NACN
+SANTURCE
+PR
+NACN
+SANTURCE
+PR
+NACN
+NEW YORK C NY
+NEW YORK NY
+CHARLI AML VI
+CHARLT AML
+VI
+SANTURCE
+PR
+NEW YORK
+NY
+NACN
+NEW YORK C
+BROOKLYN
+SANTURCE
+SANTURCE
+NY
+NY
+PR
+PR
+NACN
+NACN
+NEW YORK C NY
+SANTURCE
+SANTURCE
+PR
+PR
+NACN
+NACN
+SANTURCE
+PR
+NACN
+NEW YORK C NY
+NEW YORK
+NEW YORK
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+01/29 8:5624P
+01/30 12:2353A
+01/30 9:5006A
+INCOMING
+INCOMING
+01/30 10:2228A
+01/30 10:5022A
+01/30 11:0814A
+INCOMING
+01/30 12:0817P
+01/30 12:1000P
+INCOMING
+INCOMING
+01/30
+1:1105P
+01/30
+2:1451P
+01/30
+2:1531P
+01/30
+2:1726P
+01/30
+2:1931P
+01/30
+2:4914P
+01/30
+3:0446P
+INCOMING
+INCOMING
+01/30
+3: 4924P
+01/30
+4: 1929P
+01/30
+4: 2040P
+01/30
+8: 0222P
+01/30
+8:1450P
+INCOMING
+INCOMING
+INCOMING
+01/30
+9: 0253P
+01/30
+9:1504P
+01/30
+9:5828₽
+01/30 11:2746P
+01/30 11:5334P
+INCOMING
+INCOMING
+01/31 12:2755A
+01/31 12:5336A
+01/31 11:4009A
+INCOMING
+INCOMING
+01/31 12:4107P
+01/31
+3: 2638P
+01/31
+3: 3337₽
+01/31
+3: 5203P
+DUR
+2
+2
+1
+2
+2
+2
+1
+2
+2
+2
+1
+5
+1
+2
+0
+1
+1
+0
+0
+2
+2
+0
+32
+1
+3
+2
+PROPRIETARY AND CONFIDENTIAL
+Not for
+use
+or disclosure outside Cingular Wireless
+AIR
+LAND TOTAL RSYS I
+1.38
+1.38
+0
+. 69
+1.38
+0
+1.38
+0
+1.38
+• 69
+1.38
+1.38
+1.38
+0
+. 69
+3.45
+. 69
+1.38
+• 69
+3.45
+.69
+1.38
+1.38
+0
+. 4
+• 4
+0
+0
+• 4
+0
+.4
+0
+• 4
+. 4
+. 4
+. 2
+. 4
+.4
+1
+• 4
+•4
+0
+6.4
+22.080
+• 69
+2.07
+1.38
+•6
+.4
+1.38
+40683
+1.78
+40683
+. 4
+25
+. 69
+40683
+1.38
+40683
+• 4
+25
+1.38
+40683
+. 4
+25
+1.38
+40683
+. 69
+40683
+1.78
+40683
+1.78
+40683
+1.78
+40683
+1
+25
+.89
+40683
+3.45
+40683
+• 69
+40683
+1.78
+40683
+. 4
+25
+1
+25
+• 69
+40683
+3.45
+40683
+• 69
+40683
+25
+25
+1.38
+40683
+1.38
+40683
+6.4
+25
+22.08 40683
+• 69
+40683
+2.67
+40683
+1.78
+Page 34
+
+
+
+Account:
+MOBILE
+ESN
+X cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+SANTURCE
+PR
+NACN
+SANTURCE
+PR
+NACN
+SANTURCE
+PR
+SANTURCE
+PR
+BROOKLYN
+NY
+NACN
+NACN
+NEW YORK C NY
+SANTURCE PR
+CHARLI AML VI
+NACN
+BROOKLYN
+NY
+SANTURCE
+PR
+NEW YORK C NY
+CHARLT AML VI
+NACN
+NEW YORK C NY
+NEW YORK C NY
+BROOKLYN
+NY
+BROOKLYN
+NY
+SANTURCE
+PR
+NACN
+BROOKLYN
+SANTURCE
+BROOKLYN
+BROOKLYN
+NY
+PR
+NY
+NY
+NACN
+BROOKLYN
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+01/31 6:1846P
+INCOMING
+01/31 7:1946P
+01/31
+8: 4734P
+INCOMING
+01/31 9:4743P
+01/31 11:2416P
+01/31 11:3258P
+02/01 12:1640A
+INCOMING
+INCOMING
+INCOMING
+02/01 12:2511A
+02/01 12:3300A
+02/01 10:2123A
+02/01 10:2736A
+02/01 11:0757A
+INCOMING
+02/01 11:2836A
+02/01 12:0713P
+02/01 12:2652P
+INCOMING
+02/01 12:2913P
+02/01
+1:0112P
+INCOMING
+INCOMING
+INCOMING
+02/01
+1:2754P
+02/01
+1: 3608P
+02/01
+3: 0616P
+02/01
+4:2649P
+02/01
+4: 2850P
+02/01
+4: 4614P
+INCOMING
+02/01
+5:4714P
+02/01
+5: 5004P
+02/01
+5: 5514P
+02/01
+6: 3714P
+02/01
+6: 4248P
+INCOMING
+02/01
+6: 5533P
+02/01
+8: 1522P
+02/01 10:4057P
+02/01 11:0304P
+DUR
+4
+0
+5
+5
+1
+11
+1
+0
+5
+1
+1
+1
+1
+1
+1
+1
+3
+2
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+2.76
+0
+3.45
+0
+0
+3.45
+• 69
+7.59
+. 69
+• 69
+. 69
+3.45
+. 69
+. 69
+. 69
+. 69
+• 69
+• 69
+• 69
+• 69
+.69
+• 69
+.69
+2.07
+1.38
+• 69
+1.38
+LAND TOTAL RSYS
+° io
+1
+0
+.2
+2.2
+1
+0
+0
+.2
+0
+1
+. 2
+. 2
+0
+•2
+. 2
+.2
+0
+. 2
+. 8
+. 2
+. 2
+• 4
+.2
+• 8
+2.76
+1
+3.45
+.2
+2.2
+4.45
+. 69
+7.59
+• 69
+.2
+.89
+.69
+4.45
+. 2
+. 69
+. 89
+. 69
+. 69
+. 69
+.89
+. 89
+.2
+. 69
+.89
+. 8
+. 89
+.89
+2.07
+1.78
+.89
+1.78
+25
+40683
+25
+40683
+25
+25
+40683
+40683
+40683
+40683
+25
+40683
+40683
+40683
+25
+40683
+40683
+40683
+40683
+40683
+40683
+40683
+25
+40683
+40683
+25
+40683
+40683
+40683
+40683
+40683
+Page 35
+
+
+
+Account:
+MOBILE
+ESN
+X cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+BROOKLYN
+NY
+NEW YORK C NY
+NEW YORK C NY
+NEW YORK C NY
+SANTURCE
+PR
+SANTURCE
+PR
+NEW YORK C NY
+SANTURCE
+PR
+NACN
+SANTURCE
+SANTURCE
+SANTURCE
+PR
+PR
+PR
+NACN
+NACN
+NACN
+NACN
+NACN
+NEW YORK
+SANTURCE
+NY
+PR
+NACN
+SANTURCE
+SANTURCE
+NEW YORK C NY
+SANTURCE
+PR
+PR
+PR
+NACN
+NACN
+SANTURCE
+SANTURCE
+PR
+PR
+NACN
+NACN
+NACN
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+NEW YORK C NY INCOMING
+PROPRIETARY AND CONFIDENTIAL
+Not for
+use
+or disclosure outside Cingular Wireless
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/01 11:4431P
+02/01 11:4620P
+02/02 |
+9:5132A
+02/02 |
+9: 5753A
+02/02 10:1909A
+02/02 10:4612A
+02/02 10:5111A
+02/02 10:5415A
+02/02 11:1910A
+02/02 11:1913A
+02/02 11:2255A
+02/02 11:2639A
+02/02 11:4713A
+02/02 11:5417A
+02/02 12:2014P
+02/02 12:2355P
+02/02 12:2644P
+02/02 12:2945P
+02/02 12:5513P
+02/02
+1: 5622P
+02/02
+1:5759P
+02/02
+2:2048P
+02/02
+2: 3813P
+02/02
+2: 5202P
+02/02
+2:5859P
+02/02
+3: 2143P
+02/02
+3: 2503P
+02/02
+3: 4208P
+02/02
+3: 5205P
+02/02
+4: 2558P
+02/02
+4: 4315₽
+02/02 4:5451P
+DUR
+2
+2
+1
+1
+0
+1
+0
+0
+1
+1
+0
+10
+1
+1
+AIR
+1.38
+1.38
+• 69
+• 69
+0
+0
+• 69
+2.07
+0
+0
+0
+. 69
+5.52
+. 69
+1.38
+2.07
+2.76
+1.38
+0
+0
+• 69
+1.38
+. 69
+0
+6.9
+2.07
+- 69
+- 69
+LAND TOTAL RSYS
+0
+. 6
+.2
+1.6
+0
+.2
+. 4
+• 8
+0
+0
+. 8
+.4
+2
+• 6
+. 2
+0
+1.78
+40683
+1.38
+40683
+• 69
+40683
+• 69
+40683
+• 6
+25
+.2
+25
+. 69
+40683
+1.6
+25
+2.07
+40683
+.2
+25
+• 4
+25
+.8
+25
+. 69
+40683
+5.52
+40683
+. 69
+40683
+1.38
+40683
+2.07
+40683
+3.56
+40683
+. 4
+25
+1.38
+40683
+25
+.2
+• 69
+2
+1.38
+• 69
+• 6
+.2
+6.9
+2.07
+• 69
+• 69
+25
+40683
+25
+40683
+40683
+25
+25
+40683
+40683
+40683
+40683
+Page 36
+
+
+
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+BROOKLYN
+NY
+NEW YORK
+NY
+MOBILE
+NY
+CHARLI AML VI
+MOBILE
+NY
+NEW YORK
+NY
+MOBILE
+NEW YORK
+NEW YORK
+MOBILE
+NY
+NY
+NY
+NY
+NEW YORK
+NEW YORK
+NY
+NY
+MOBILE
+NY
+NEW YORK NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/02 4: 5715₽
+INCOMING
+INCOMING
+INCOMING
+02/02 7:5219P
+02/02 7:5254P
+02/02
+7:5723P
+02/02
+8: 4332P
+02/02
+8:4447P
+02/02 8:4535P
+INCOMING
+02/02 8:4803P
+02/02 8:4916P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/02 9:0043₽
+02/02 9:1755P
+02/02 10:2639P
+02/03
+8: 2602A
+02/03
+9: 0207A
+02/03
+9: 0638A
+02/03
+9: 2613A
+02/03
+9:2736A
+INCOMING
+INCOMING
+02/03
+9: 3121A
+02/03
+9: 3246A
+02/03
+9: 3342A
+02/03
+9: 3358A
+02/03
+9: 3523A
+02/03
+9: 3602A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/03 10:1230A
+02/03 10:1737A
+02/03 10:2429A
+02/03 10:4632A
+02/03 11:1931A
+02/03 11:2246A
+INCOMING
+02/03 11: 3233A
+02/03 11: 3357A
+02/03 11: 3805A
+DUR
+2
+1
+1
+2
+1
+1
+1
+1
+2
+1
+[ m
+5
+2
+4
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+X cingular®
+AIR
+1.38
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+• 4
+0
+. 4
+0
+• O
+• 00
+0
+0
+0
+0
+1.78
+0
+0
+. 4
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+40683
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2
+2
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+D
+D
+Page 37
+
+
+
+Account:
+MOBILE
+ESN
+X cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+MOBILE
+NEW YORK
+NY
+NY
+NEW YORK
+NY
+NEW YORK
+MOBILE
+NEW YORK
+NY
+NY
+NY
+DIR. ASST.
+NEW YORK
+NY
+DIR. ASST.
+DIR. ASST.
+DIR. ASST.
+DIR. ASST.
+NEW YORK
+NEW YORK
+NY
+NY
+DIR. ASST.
+MOBILE
+WILLOUGHBY OH
+MOBILE
+MOBILE
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+MOBILE
+MOBILE
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+02/03 11:4154A
+02/03 11:4307A
+02/03 11:4413A
+INCOMING
+02/03 11:4659A
+02/03 11:5846A
+INCOMING
+02/03 12:0039P
+02/03 12: 0324P
+02/03 12:2208P
+02/03 12:2443P
+INCOMING
+02/03 12:2739P
+02/03 12:2752P
+02/03 12:4701P
+INCOMING
+02/03 12:5606P
+02/03
+1:
+041
+P
+02/03
+1:2913P
+02/03
+1: 3333P
+02/03
+1:3851
+P
+02/03
+1: 3852P
+02/03
+1: 4138P
+02/03
+1:4637P
+02/03
+1:5050P
+02/03
+1:5329P
+02/03
+1: 5918P
+02/03
+1: 5945P
+02/03
+2: 0803P
+02/03
+2: 0933₽
+INCOMING
+02/03
+2:1441P
+02/03
+2:1609P
+02/03
+2: 3603₽
+INCOMING
+INCOMING
+INCOMING
+02/03
+3: 3234P
+02/03
+4: 0413₽
+02/03 4:2450P
+DUR
+2
+1
+3
+1
+2
+3
+1
+4
+2
+2
+2
+0
+3
+2
+2
+1
+2
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0 0 0
+0 0
+0
+• O
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 38
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+MOBILE
+NY
+MOBILE
+NY
+NEW YORK
+NEW YORK
+NY
+NY
+WILLOUGHBY OH
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+INCOMING
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+ANS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+02/03 4:4048P
+02/03
+5:5019P
+INCOMING
+02/03
+6:1214P
+02/03
+6: 3927P
+INCOMING
+02/03
+6: 5008P
+02/03
+7: 0246P
+INCOMING
+INCOMING
+02/03
+7: 1120₽
+02/03
+8: 3204P
+02/03
+8: 4638P
+INCOMING
+02/03 9:5421P
+02/03 9:5527P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/04 9:1423A
+02/04 10:0743A
+02/04 12:01
+P
+02/04 12:0517P
+02/04 12:1
+657₽
+02/04
+1:1341P
+02/04
+2:2350P
+02/04
+3: 0306P
+02/04
+3:0744P
+02/04
+3: 4723P
+02/04
+3: 5233₽
+02/04
+3: 5438₽
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/04
+4: 0923P
+02/04
+4: 2232P
+02/04
+4:2653P
+02/04
+4: 3931P
+02/04
+5: 3853P
+02/04
+6: 0559P
+02/04
+6: 0924P
+02/04
+6: 3445P
+02/04
+6: 4925₽
+DUR
+1
+1
+4
+1
+1
+1
+1
+2
+3
+1
+2
+3
+NA NAM
+H N
+5
+1
+2
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+• o
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2
+25
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 39
+
+
+
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+MOBILE
+NEW YORK
+NY
+NY
+NEW YORK
+NY
+MOBILE
+NY
+NEW YORK
+NY
+NEW YORK
+NY
+W PALM BCH FL
+MOBILE
+NY
+NEW YORK
+MOBILE
+NY
+NY
+NEW YORK
+MOBILE
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+INCOMING
+INCOMING
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+X cingular®
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/04 6:5007P
+02/04 7:2415P
+INCOMING
+INCOMING
+02/04 8:1949P
+02/04 10:3151P
+02/04 10:3333P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/04 11:0626P
+02/05 8:4819A
+02/05 9:0334A
+02/05 9:0428A
+02/05 9:0626A
+INCOMING
+02/05 9:2901A
+02/05 9:3256A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/05
+9: 3534A
+02/05 10:1524A
+02/05 10:1746A
+02/05 10:2744A
+02/05 10:5256A
+02/05 12:2057P
+INCOMING
+02/05 12:2351P
+02/05 12:2422P
+02/05 12: 3300P
+INCOMING
+INCOMING
+02/05 12:3935P
+02/05 12:4011P
+02/05 12:4708P
+02/05 12:5429P
+INCOMING
+02/05
+1: 0041P
+02/05
+1: 2724P
+02/05
+2: 4725₽
+02/05
+2:4900₽
+02/05
+2: 5925₽
+02/05
+3: 0952P
+02/05
+3:1248P
+DUR
+1
+13
+1
+1
+14
+8
+3
+1
+1
+2
+2
+HAMM
+3
+3
+1
+10
+1
+1
+2
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+5
+25
+2
+25
+2
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 40
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+MOBILE
+NY
+W PALM BCH FL
+NEW YORK
+NEW YORK
+NEW YORK
+MOBILE
+NY
+NY
+NY
+NY
+MOBILE
+NY
+NEW YORK
+NY
+MOBILE
+MOBILE
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+W PALM BCH
+NY
+NY
+NY
+NY
+NY
+NY
+FL
+NACN
+W PALM BCH FL
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/05 3:1629P
+INCOMING
+02/05
+3:1658P
+02/05
+3: 1813P
+INCOMING
+INCOMING
+02/05
+3: 5015₽
+02/05
+3: 5300₽
+02/05
+3: 5536P
+02/05
+4: 0221P
+02/05
+4: 0912P
+02/05
+4: 0950P
+02/05
+4: 1041P
+02/05
+4:1909P
+02/05 4: 3135P
+02/05
+4: 3253P
+02/05
+4: 3657
+P
+02/05
+4: 5414P
+02/05
+5:4604P
+02/05
+5:5840P
+02/05
+6: 0509P
+02/05
+6: 2913P
+02/05
+7:1341P
+02/05
+7:1618P
+02/05
+7:4940P
+02/05
+7: 5012₽
+02/05
+8: 0454P
+02/05
+8: 1312P
+02/05 10:3728P
+02/05 10:4630P
+02/06
+9: 2915A
+02/06 10:0726A
+02/06 10:1903A
+02/06 10:2010A
+02/06 11:4209A
+DUR
+2
+2
+2
+1
+3
+2
+1
+1
+2
+2
+2
+2
+1
+2
+3
+1
+0
+14
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2
+2
+25
+25
+25
+25
+25
+37
+37
+37
+37
+25
+37
+25
+Page 41
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NEW YORK
+NY
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+WEST PALM
+WEST PALM
+WEST PALM
+FL
+FL
+FL
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+QUEENS
+WEST PALM
+NY
+FL
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+WEST PALM FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+02/06 11: 4321A
+02/06 11:4509A
+INCOMING
+02/06 11:4618A
+02/06 12:0419P
+02/06 12:0459P
+INCOMING
+02/06 12:0532P
+02/06 12:0902P
+INCOMING
+02/06 12:1008P
+02/06 12: 3516P
+INCOMING
+02/06 12: 3622₽
+02/06 12:4009P
+INCOMING
+02/06 12:4118P
+02/06 12:4404P
+INCOMING
+02/06 12:4521P
+02/06 12:5513P
+02/06 12:5842P
+02/06 12:5902P
+02/06 1:1203P
+INCOMING
+02/06 1:1315P
+02/06
+1:1731P
+INCOMING
+02/06
+1:1839P
+02/06
+1:4333P
+INCOMING
+02/06
+1: 4444P
+02/06
+2:0804P
+INCOMING
+02/06
+2:0918P
+02/06
+2: 2819P
+02/06
+2: 3131P
+02/06
+2: 5405₽
+INCOMING
+02/06
+2: 5532₽
+02/06
+3: 0059₽
+INCOMING
+02/06
+3: 0218P
+02/06 3:0333P
+DUR
+1
+0
+19
+1
+2
+0
+2
+0
+4
+4
+0
+4
+10
+0
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+• 0 0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+37
+25
+37
+25
+37
+37
+25
+37
+25
+37
+25
+37
+25
+37
+37
+37
+25
+37
+25
+37
+25
+37
+25
+37
+37
+37
+25
+37
+25
+37
+37
+Page 42
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+BROOKLYN
+NY
+QUEENS
+NY
+W PALM BCH FL
+MOBILE
+NACN
+NEW YORK
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+WILLOUGHBY OH
+W PALM BCH FL
+NACN
+NEW YORK
+NEW YORK
+NY
+NY
+W PALM BCH FL
+NACN
+BROOKLYN
+NY
+W PALM BCH
+FL
+NACN
+WEST PALM FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/06 3:0821P
+02/06
+3: 1127₽
+02/06
+3: 1824P
+02/06
+3: 1831₽
+INCOMING
+INCOMING
+02/06
+3: 1930₽
+02/06
+3: 4346P
+02/06
+4: 0840₽
+INCOMING
+02/06
+4:0949P
+02/06
+4: 1142P
+INCOMING
+02/06
+4: 1250₽
+02/06
+4: 2417₽
+02/06
+4: 4345₽
+INCOMING
+02/06
+4:4457P
+02/06
+5:00
+1
+8
+P
+INCOMING
+02/06
+5: 0127P
+02/06
+5: 1118P
+INCOMING
+02/06
+5:1224P
+02/06
+5:2523P
+INCOMING
+02/06
+5: 2632P
+02/06
+5: 4208P
+INCOMING
+02/06
+5: 4322P
+02/06
+5: 4525₽
+02/06
+6: 0244P
+INCOMING
+INCOMING
+02/06
+6: 0351P
+02/06
+6: 1506₽
+02/06
+6: 1721₽
+02/06
+6: 2533P
+INCOMING
+02/06
+6: 2638P
+02/06
+6: 3158P
+02/06
+6: 5535P
+INCOMING
+02/06
+6: 5643P
+02/06
+6:5900P
+DUR
+0
+1
+2
+1
+3
+0
+1
+21
+0
+8
+OHHONAN
+0
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+LAND TOTAL RSYS
+0
+0
+0
+37
+37
+25
+37
+37
+37
+25
+37
+25
+37
+37
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0 0 0 00 O
+0
+0
+0
+0
+0
+0
+0
+0
+0
+37
+37
+37
+25
+37
+37
+37
+25
+37
+37
+25
+37
+37
+Page 43
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+AWS NEW YORK
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NEW YORK
+NY
+NACN
+MOBILE
+NEW YORK
+NY
+NEW YORK
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+QUEENS
+NY
+CALLED PHONE CDATE CTIME
+02/06 7:1416P
+INCOMING
+02/06
+7:1430₽
+02/06
+7: 2549₽
+INCOMING
+02/06
+7:2700₽
+02/06
+7:4812P
+INCOMING
+INCOMING
+02/06
+7: 4821P
+02/06
+7: 4920₽
+02/06
+8: 4518P
+INCOMING
+INCOMING
+02/06 10:0315P
+02/06 10:2538₽
+02/06 10:5523P
+INCOMING
+02/06 10:5632P
+02/06 11:1908P
+INCOMING
+02/06 11:2015P
+02/06 11:2629P
+INCOMING
+02/06 11:2637P
+02/06 11:2858P
+INCOMING
+INCOMING
+02/06 11:3007P
+02/07
+8: 2306A
+02/07
+8: 4226A
+INCOMING
+02/07
+8: 4337A
+02/07
+9: 5712A
+INCOMING
+02/07
+9: 5821A
+02/07 10:0001A
+02/07 10:2047A
+02/07 10:2155A
+INCOMING
+02/07 10:5021A
+02/07 10:5857A
+INCOMING
+02/07 11:0005A
+02/07 11: 3903A
+INCOMING
+02/07 11:4011A
+02/07 11: 5238A
+DUR
+3
+0
+2
+0
+2
+1
+1
+2
+1
+0
+24
+0
+5
+* ON
+" HO
+1
+4
+HON
+0
+10
+1
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+25
+37
+25
+37
+25
+37
+37
+37
+37
+37
+25
+37
+25
+37
+5
+0 0 0
+0 0 0
+• 00
+000
+0
+0
+0
+0
+• o
+0
+0
+0
+0
+0
+37
+2.
+37
+25
+37
+37
+37
+37
+37
+25
+37
+25
+37
+37
+Page 44
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+QUEENS
+QUEENS
+NY
+NY
+W PALM BCH FL
+NACN
+NEW YORK
+QUEENS
+NY
+NY
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+WEST PALM
+FL
+W PALM BCH FL
+NACN
+WEST PALM
+NEW YORK
+WEST PALM
+FL
+NY
+FL
+MOBILE
+QUEENS
+NY
+W PALM BCH FL
+NACN
+MOBILE
+W PALM BCH FL
+W PALM BCH FL
+NACN
+NACN
+WEST PALM FL
+W PALM BCH FL
+NACN
+WEST PALM FL
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/07 11:5254A
+02/07 12:1422P
+02/07 12:1645P
+INCOMING
+02/07 12:1701P
+02/07 12:2106P
+02/07 12:3721P
+02/07 1:2414P
+INCOMING
+INCOMING
+02/07
+1:2520P
+02/07
+1: 5311P
+02/07
+2: 1104P
+02/07
+2: 5036P
+INCOMING
+02/07
+2: 5147P
+02/07
+2: 5224P
+02/07
+2:5515P
+02/07
+3: 2906P
+02/07
+3: 4016P
+02/07
+3: 4251P
+02/07
+3: 4408P
+INCOMING
+02/07
+3: 4420₽
+02/07
+3: 5429P
+02/07
+4:0734P
+02/07
+4: 0752P
+INCOMING
+INCOMING
+02/07
+4:0839P
+02/07
+4: 0908P
+02/07
+4:0930₽
+02/07
+4: 1300₽
+INCOMING
+02/07
+4: 1420₽
+02/07
+4: 2428P
+02/07
+4: 2453P
+INCOMING
+02/07
+4: 2606₽
+02/07 4:5629P
+INCOMING
+02/07 4:5742P
+DUR
+1
+1
+4
+16
+0
+1
+1
+1
+0
+0
+H H
+MOH
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+37
+37
+25
+37
+37
+37
+25
+37
+37
+37
+25
+37
+37
+37
+37
+37
+25
+37
+37
+25
+25
+37
+37
+37
+25
+37
+37
+25
+37
+25
+37
+Page 45
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+WEST PALM
+NEW YORK
+WEST PALM
+WEST PALM
+NY
+FL
+NY
+FL
+FL
+W PALM BCH FL
+NACN
+NEW YORK
+NEW YORK
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/07 5:3410P
+INCOMING
+02/07
+5:3429₽
+02/07
+8:1923P
+INCOMING
+INCOMING
+02/07 8:2032P
+02/07 11:0456P
+02/07 11:1228P
+INCOMING
+02/07 11:1237P
+02/07 11:5426P
+INCOMING
+02/07 11:5439P
+02/08 12: 3634A
+INCOMING
+02/08 12: 3646A
+02/08 12:4035A
+INCOMING
+02/08 12:4040A
+02/08 12:4055A
+INCOMING
+02/08 12:4103A
+02/08 12:4143A
+INCOMING
+02/08 12:4152A
+02/08 12:4236A
+INCOMING
+02/08 12:4244A
+02/08 12:5448A
+INCOMING
+02/08 12:5508A
+02/08 12:5516A
+INCOMING
+02/08 12:5527A
+02/08 12:5744A
+02/08 12:1623P
+INCOMING
+02/08 12:2127P
+02/08 12:2211P
+02/08 12:2241P
+02/08 12:5021P
+INCOMING
+INCOMING
+02/08 12:5133P
+02/08
+1:2056P
+02/08 1: 2124P
+DUR
+2
+1
+1
+0
+3
+0
+37
+4
+O HO
+0
+1
++ O
+1
+2
+5
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+37
+25
+37
+37
+25
+37
+25
+37
+25
+37
+25
+37
+2
+5
+37
+25
+37
+25
+37
+25
+37
+25
+37
+37
+37
+37
+37
+37
+25
+37
+37
+37
+Page 46
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+WEST PALM FL
+MOBILE
+WEST PALM
+FL
+WEST PALM
+FL
+W PALM BCH FL
+NACN
+NEW YORK NY
+W PALM BCH FL
+NACN
+NEW YORK
+WEST PALM
+BEVERLYHLS
+BROOKLYN
+NY
+FL
+CA
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+BROOKLYN NY
+BROOKLYN
+NY
+W PALM BCH FL
+NACN
+NEW YORK NY
+W PALM BCH FL
+NACN
+NEW YORK
+WEST PALM
+NY
+FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/08 1:2658P
+02/08
+2: 4646P
+02/08
+2: 5634P
+02/08
+2:5838P
+02/08
+2: 5842P
+02/08
+2:5954P
+02/08
+3:2733P
+02/08
+3: 5400₽
+02/08
+3: 5509₽
+02/08
+4: 1808₽
+02/08
+4: 2229₽
+02/08
+4: 5028₽
+02/08
+4: 5604P
+02/08
+5:02
+301
+02/08
+5: 0342P
+02/08
+5: 0922P
+02/08
+5:0934P
+02/08
+5:1801P
+02/08
+5:1911P
+02/08
+11: 0034P
+02/08 11:0049P
+02/08 11:0948P
+02/08 11:0956P
+02/08 11:1011P
+02/08 11:1022P
+02/08 11:1051P
+02/08 11:1059P
+02/09 12:5140A
+02/09 12:5144A
+02/09 12:5153A
+02/09 8:2833A
+02/09 8:2953A
+DUR
+2
+1
+1
+1
+1
+0
+1
+1
+0
+2
+• H C
+0
+9
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+37
+37
+37
+37
+25
+37
+37
+25
+37
+37
+37
+mm
+0
+0
+0
+0
+0
+0
+0
+0
+• O
+• 0 o
+0 0 0 00 O
+0
+0
+0
+0
+0
+0
+0
+0
+0
+37
+37
+37
+25
+37
+37
+37
+25
+37
+37
+25
+37
+37
+37
+Page 47
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NEW YORK
+BROOKLYN
+W PALM BCH
+NY
+NY
+NY
+FL
+NACN
+W PALM BCH
+FL
+NACN
+SLOVAKIA
+SLOVAKIA
+ITALY
+NEW YORK
+NY
+SLOVAKIA
+NEW YORK
+NEW YORK
+NEW
+YORK
+NEW
+YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+NY
+MOBILE
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/09 9:4343A
+02/09 10:0202A
+INCOMING
+02/09 10:0312A
+02/09 10:5805A
+INCOMING
+02/09 10:5911A
+02/09 12:0542P
+INCOMING
+02/09 12:0649P
+02/09 12:2005P
+INCOMING
+02/09 12:2111P
+02/09
+1:0741P
+INCOMING
+INCOMING
+INCOMING
+02/09
+1: 0751P
+02/09
+1: 2920P
+02/09
+2: 3226P
+02/09
+2: 3830P
+02/09
+3 : 0302P
+INCOMING
+02/09
+3:0409P
+02/09
+3: 5211P
+INCOMING
+02/09
+3: 5320P
+02/09
+4: 0430P
+02/09
+4: 0612P
+02/09
+4: 0836P
+02/09
+4: 2205P
+02/09
+4: 2742P
+02/09
+6: 5656P
+02/09
+6:5914P
+02/09
+7:0020P
+02/09
+7: 0025P
+02/09
+7: 0245₽
+02/09
+7:0645P
+INCOMING
+INCOMING
+02/09
+7: 0816P
+02/09
+7:0934P
+02/09
+7:1013P
+DUR
+2
+0
+1
+0
+2
++ O
+1
+4
+N N
+1
+4
+1
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+37
+25
+37
+25
+37
+25
+37
+25
+37
+25
+37
+37
+37
+• •
+0
+0
+0
+5
+1
+1.4
+1
+1.
+5
+1.4
+2.25
+0
+2.25
+0
+0
+0
+0
+0
+0
+0
+0
+37
+2.
+5
+37
+37
+37
+37
+37
+37
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 48
+
+
+
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+MOBILE
+NY
+NEW YORK
+NY
+FRANCE
+MOBILE
+MOBILE
+NY
+NY
+NEW YORK
+NY
+C ST CROIX VI
+CHARLI AML VI
+NEW YORK
+NY
+NEW YORK
+NY
+MOBILE
+NY
+C ST CROIX VI
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+02/09 7:5712P
+02/09 8:1016P
+INCOMING
+INCOMING
+02/09 8:3004P
+02/09 8:5442P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/09 8:5521P
+02/10 8:3538A
+02/10 9:2225A
+02/10 9:5852A
+02/10 10: 0145A
+02/10 10:0243A
+02/10 10:0329A
+02/10 10:0919A
+02/10 10:1444A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/10 10:2534A
+02/10 10:2839A
+02/10 10:4055A
+02/10 11:2616A
+02/10 11:4207A
+02/10 11:5423A
+02/10 11: 5500A
+INCOMING
+INCOMING
+02/10 12:0328P
+02/10 12:4606P
+02/10 12:5859P
+02/10
+2: 4635P
+02/10
+2: 4658P
+INCOMING
+02/10
+3: 1807₽
+02/10
+3: 3506₽
+INCOMING
+02/10
+3: 4305P
+02/10
+3: 5844P
+INCOMING
+02/10
+4: 0059₽
+02/10
+4: 0132P
+02/10 4:0504P
+DUR
+2
+1
+1
+2
+2
+3
+2
+1
+1
+2
+1
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+X
+cingular®
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2.
+25
+25
+0
+0
+• O
+0
+0
+0:0o
+0
+0
+.2
+0
+• 4
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 49
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+MOBILE
+MOBILE
+NEW YORK
+NEW
+YORK
+MOBILE
+MOBILE
+NEW YORK
+NEW
+YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NEW
+YORK
+NEW YORK
+NEW
+YORK
+MOBILE
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/10 4:0756P
+02/10 4:1238P
+INCOMING
+02/10
+4:2442P
+02/10
+5:1718P
+INCOMING
+02/10
+5:1940P
+02/10
+7: 0846P
+INCOMING
+INCOMING
+02/10
+7: 5522₽
+02/10
+7:5749₽
+02/10
+8: 2209P
+INCOMING
+INCOMING
+02/10
+8: 2735P
+02/10
+8: 3704P
+02/10
+8: 5625P
+INCOMING
+02/10
+9: 0735P
+02/10
+9:31
+21
+INCOMING
+02/11
+9: 2728A
+02/11
+9: 5424A
+02/11
+9:5605A
+02/11
+9: 5826A
+INCOMING
+02/11 10:0002A
+02/11 10:0259A
+INCOMING
+02/11 10:0520A
+02/11 10:1306A
+02/11 10:1704A
+02/11 10:1910A
+02/11 10:2004A
+02/11 10:2503A
+02/11 10:2601A
+INCOMING
+02/11 10:2851A
+02/11 10:2920A
+02/11 11: 0918A
+02/11 11:1007A
+02/11 11:1149A
+DUR
+1
+3
+1
+2
+1
+1
+1
+1
+19
+2
+2
+2
+1
+2
+2
+2
+1
+IN M
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2
+25
+0
+0
+0
+0
+0
+0
+0
+• 0
+• 0
+° o
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 50
+
+
+
+Account:
+MOBILE
+ESN
+X cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NY
+NEW YORK
+MOBILE
+NY
+NY
+MOBILE
+MOBILE
+NY
+NY
+CHARLT AML VI
+ITALY
+MOBILE
+NEW YORK
+MOBILE
+NY
+NY
+NY
+NEW YORK
+NY
+NEW YORK
+MOBILE
+NY
+NY
+MOBILE
+NY
+NEWYORK
+NEW YORK
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/11 11:1253A
+INCOMING
+02/11 11:1946A
+02/11 11:2017A
+02/11 11:2259A
+INCOMING
+INCOMING
+02/11 11:3353A
+02/11 11:3445A
+02/11 11:3603A
+02/11 11:5200A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/11 12:0946P
+02/11 12:1544P
+02/11 12:2550P
+02/11 12:4059P
+02/11 12:5337P
+02/11 1:3
+2
+1P
+02/11 1:4224P
+02/11 1:4644P
+INCOMING
+02/11
+1:5453P
+02/11 1:5842P
+02/11
+1: 5904P
+02/11
+2:0433P
+INCOMING
+INCOMING
+02/11 2:1406P
+02/11 2:4935P
+02/11
+3:4917P
+INCOMING
+02/11
+3: 5211₽
+02/11
+3: 5242₽
+02/11
+4: 0038P
+INCOMING
+02/11
+4: 0634P
+02/11
+5: 3707₽
+INCOMING
+INCOMING
+02/11
+6:0640P
+02/11
+6: 1001P
+02/11
+7:0309P
+02/11
+7: 0444P
+DUR
+2
+1
+1
+2
+1
+2
+1
+2
+1
+2
+1
+4
++M H
+2
+# A A =
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+• 0
+.8
+1.
+4
+0
+0
+0
+° o
+0
+0
+0
+0
+0
+0
+00
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 51
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NY
+NEW YORK
+NEW YORK
+NY
+NY
+NEW YORK
+NEW YORK
+MOBILE
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+NEW YORK
+NEW YORK
+NY
+NY
+NEW YORK C NY
+NEW YORK
+NY
+NEW YORK C NY
+NEW YORK
+NY
+DIR. ASST.
+PROVO
+UT
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/11 7:0904P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/11
+7: 1513₽
+02/11
+7:4218₽
+02/11
+8: 0204P
+02/11
+8: 2515P
+02/11
+8: 3036P
+02/11 8:4400₽
+02/11
+8: 5241P
+02/11
+9:0633P
+02/11 10:4135₽
+02/11 10:4945P
+02/11 10:5839P
+02/11 11:4827P
+02/12
+8: 5234A
+02/12 9:3533A
+INCOMING
+02/12 10:5434A
+02/12 10:5643A
+02/12 11:0411A
+02/12 11:2635A
+02/12 11:3108A
+02/12 11: 3337A
+INCOMING
+INCOMING
+02/12 11:4759A
+02/12 11:5454A
+02/12 11:5627A
+02/12 12:0119P
+INCOMING
+INCOMING
+02/12 12:0224P
+02/12
+2: 0808P
+02/12
+2:1047₽
+INCOMING
+02/12
+5: 3128₽
+02/12
+5: 3316P
+02/12
+5:5156P
+02/12
+5: 5157P
+DUR
+3
+7
+1
+1
+1
+2
+1
+2
+1
+1
+4
+4
+L H
+2
+1
+2
+2
+4
+2
+1
+0
+5
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+5
+25
+0
+0
+0
+0
+0
+0
+0
+• o
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+5
+25
+25
+25
+25
+25
+25
+4111
+4111
+91
+91
+91
+91
+U U
+Page 52
+
+
+
+Account:
+MOBILE
+ESN
+* cingular®
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+CALLED LOC
+PROVO
+SAVANNAH
+PROVO
+NEW YORK
+PROVO
+PROVO
+NACN
+NACN
+PARK CITY
+PARK CITY
+AWS NEW YORK
+UT
+GA
+UT
+NY
+UT
+UT
+UT
+UT
+CALLED PHONE CDATE CTIME
+02/12 5:5609P
+02/12
+6: 0528P
+02/12
+6: 0604P
+02/12
+6: 4127₽
+02/12
+6: 5111P
+02/12
+6:5209P
+INCOMING
+INCOMING
+02/12
+7: 1306P
+02/12
+7:5333P
+02/12
+9: 1154P
+02/12 9:5222P
+DUR
+in r
+1
+1
+1
+2
+3
+2
+0
+AIR
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+91
+91
+91
+0
+0
+0
+0
+0
+30871
+30871
+30871
+30871
+30871
+0
+0
+25
+25
+LAM
+Not
+for
+use
+or
+PROPRIETARY AND CONFIDENTIAL
+disclosure outside Cingular Wireless
+Page 53
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular°
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NY
+NACN
+NACN
+PROVO
+NEW YORK C NY
+BROOKLYN
+PARK CITY
+NACN
+UT
+NY
+UT
+PARK CITY UT
+NEW YORK C NY
+NEW YORK C NY
+NEW YORK
+NY
+NACN
+PARK CITY
+PARK CITY
+BROOKLYN
+UT
+UT
+NY
+NACN
+ITALY
+ITALY
+NEW YORK
+PARK CITY
+NY
+UT
+ITALY
+FRANCE
+NACN
+FRANCE
+PARK CITY UT
+NACN
+PARK CITY UT
+NACN
+PARK CITY UT
+NACN
+PARK CITY UT
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/13 8:4831A
+INCOMING
+INCOMING
+02/13 9:4455A
+02/13 10:1807A
+02/13 10:1846A
+INCOMING
+02/13 11:2041A
+02/13 11:2144A
+02/13 11:4333A
+INCOMING
+02/13 11:5907A
+02/13 12:1750P
+INCOMING
+INCOMING
+02/13 12:2920P
+02/13 12:5942P
+02/13 1:0050P
+INCOMING
+02/13
+1: 3514P
+02/13
+1:5846P
+02/13
+3: 3401P
+02/13
+3: 3656P
+INCOMING
+02/13
+9: 0155P
+02/13
+10:1103P
+02/13 10:1213P
+02/13 10:2430P
+02/13 11:0133P
+02/14 12:4811A
+02/14 12:5009A
+INCOMING
+02/14 11:1057A
+02/14 1:0656P
+02/14
+1: 0934P
+INCOMING
+02/14
+3: 0614P
+02/14
+5: 0556P
+INCOMING
+02/14
+8: 2124P
+02/14 10:2109P
+INCOMING
+02/15 9:5401A
+02/15 11:5344A
+DUR
+2
+1
+2
+1
+1
+0
+0
+2
+1
+N Un
+0
+0
+2
+1
+1
+3
+1
+0
+1
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+. 35
+1.4
+.7
+. 35
+0
+1.05
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+. 35
+1.4
+0
+.35
+1.05
+0
+0
+30871
+30871
+30871
+30871
+30871
+30871
+25
+30871
+25
+30871
+30871
+30871
+30871
+25
+25
+30871
+30871
+30871
+30871
+30871
+25
+30871
+30871
+30871
+30871
+25
+30871
+25
+30871
+25
+30871
+25
+Page 54
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK C NY
+NACN
+BROOKLYN
+PARK CITY
+NY
+UT
+NACN
+FRANCE
+SALT LAKE
+UT
+FRANCE
+FRANCE
+NEW YORK
+MOBILE
+NEW YORK
+MOBILE
+MOBILE
+NY
+NY
+NY
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+02/15 12:1013₽
+INCOMING
+02/15 12:3849P
+02/15 2:2625P
+02/15 2:3731P
+INCOMING
+02/16
+8: 4954A
+02/16
+9:2939A
+02/16 10:4953A
+INCOMING
+02/16
+4: 4813P
+02/16 4:5016P
+02/16 5:0038₽
+INCOMING
+02/16
+5: 3618P
+02/16
+6: 0556₽
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/16
+6:2021P
+02/16
+6:2241
+P
+02/16
+8:1301P
+02/17
+9: 1114A
+02/17
+9:1359A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/17
+9:1607A
+02/17 10:5919A
+02/17 11: 4054A
+02/17 12:4012P
+02/17 12:5521P
+02/17 2:1903P
+02/17
+4: 0356P
+02/17
+5: 3734P
+02/17
+5: 4046₽
+02/17
+5: 5646₽
+INCOMING
+INCOMING
+INCOMING
+02/17
+6: 1332₽
+02/17
+6:1606P
+02/17
+6: 3002₽
+02/17
+6: 3033P
+INCOMING
+02/17
+6: 3105P
+DUR
+1
+1
+2
+1
+2
+0
+2
+3
+2
+1
+MMNANNA
+9
+4
+1
+3
+5
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+30871
+30871
+30871
+25
+91
+. 7
+0
+• 7
+91
+25
+25
+1.05
+• 7
+1.05
+25
+5. o
+25
+25
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+• o o
+• 0
+• a
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 55
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NEW YORK
+NY
+NY
+NEW ALBANY OH
+TROY
+NEW YORK
+MI
+NY
+MOBILE
+NEW YORK
+NY
+NY
+MOBILE
+NY
+NEW YORK
+NY
+W PALM BCH FL
+NEW YORK
+NY
+NEW YORK
+NY
+NEW YORK
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+02/17 7:2631P
+INCOMING
+02/17
+8: 3624P
+INCOMING
+02/17
+8:5458P
+INCOMING
+02/18 12: 3051A
+02/18
+8:2449A
+02/18
+8: 2720A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/18
+9: 4352A
+02/18
+9: 5613A
+02/18 10:4909A
+02/18 12:0232P
+02/18 12:5335P
+02/18 12:5833P
+INCOMING
+02/18 1:5018P
+02/18
+1:51
+54P
+02/18
+2:0301P
+INCOMING
+02/18
+2:1731P
+02/18
+3:2807P
+02/18
+3:2931P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/18
+3: 3031P
+02/18
+3: 5741P
+02/18
+4: 2815P
+02/18
+5:2630P
+02/18
+5:4717P
+02/18
+6: 0702P
+02/18
+6: 0735P
+02/18
+6:1033P
+02/18
+6: 1957₽
+INCOMING
+02/18
+6:4739P
+02/18
+7: 1134₽
+INCOMING
+INCOMING
+02/18
+7: 2046P
+02/18
+8: 2114P
+02/18
+9:0013P
+DUR
+7
+3
+6
+1
+2
+1
+1
+1
+1
+2
+3
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+X cingular®
+AIR
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+0
+0
+• 0 C
+• 00
+0
+0
+0
+0
+0
+• 000
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 56
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NY
+NEW YORK
+NY
+MOBILE
+NY
+NEW YORK
+NY
+NEW YORK
+NY
+W PALM BCH FL
+NEW YORK
+NY
+CHARLI AML VI
+NEW YORK NY
+MOBILE
+NY
+NEW YORK
+NY
+NEW YORK
+NY
+NEW YORK
+NY
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+X cingular®
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+02/18 9:4921P
+INCOMING
+02/19
+8: 5628A
+02/19
+9:0253A
+INCOMING
+INCOMING
+INCOMING
+02/19 10:0443A
+02/19 10:1542A
+02/19 10:1904A
+02/19 10:1939A
+INCOMING
+02/19 10:2259A
+02/19 10:2825A
+02/19 10:3026A
+02/19 10:4346A
+02/19 10:5156A
+02/19 10:5219A
+02/19 10:5304A
+02/19 10:5525A
+02/19 11:0252A
+02/19 11:0945A
+02/19 11:1038A
+02/19 11:1206A
+02/19 11:1216A
+02/19 11: 2216A
+02/19 11:2532A
+02/19 11:2619A
+02/19 11:3036A
+02/19 11:3832A
+02/19 11:5323A
+02/19 12:0739P
+02/19 12:1101P
+02/19 12:2159P
+02/19 12:3154P
+02/19 12:3717P
+02/19 12:4135P
+DUR
+2
+3
+2
+11
+1
+1
+1
+1
+2
+3
+2
+2
+1
+2
+1
+2
+2
+1
+1
+2
+2
+N A M
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+• 00
+• 0
+• O
+0
+0
+0
+0
+0
+0
+0
+0
+0
+• 4
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 57
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NEW YORK
+MOBILE
+NEW YORK
+MOBILE
+NEW YORK
+NEW YORK
+MOBILE
+NEW YORK
+MOBILE
+NEW YORK
+NEW YORK
+NEW YORK
+MOBILE
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+02/19 12:4301P
+INCOMING
+INCOMING
+02/19 12:4418P
+02/19 12:4815P
+02/19 12:5323P
+02/19 12:5428P
+02/19 12:5631P
+02/19 12:5935P
+INCOMING
+02/19
+1: 1506P
+02/19
+1: 1607P
+INCOMING
+INCOMING
+02/19
+1:2018P
+02/19
+2:1329P
+02/19
+2:1422P
+INCOMING
+INCOMING
+02/19
+2:2134P
+02/19
+2:2354P
+02/19
+2:2423P
+02/19
+2: 2705P
+02/19
+2:2857P
+02/19
+2:2925P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/19
+2: 3014P
+02/19
+2:3748P
+02/19
+2:3943P
+02/19
+2: 4402P
+02/19
+3: 0610₽
+02/19
+3: 0644P
+INCOMING
+INCOMING
+02/19
+3: 0757₽
+02/19
+3: 1124₽
+02/19
+3: 1137₽
+INCOMING
+02/19
+3: 2035₽
+02/19
+3: 3006₽
+02/19
+4: 0235P
+INCOMING
+02/19
+4: 5753P
+02/19
+5:2825P
+DUR
+1
+1
+1
+2
+1
+1
+1
+2
+2
+1
+2
+HNHHANAAAAAA
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Il
+0
+0
+0
+• 0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 58
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+* cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NEW YORK
+NY
+NY
+MOBILE
+NY
+NEW YORK
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NEW YORK
+NY
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/19 5:2918P
+02/19
+5:2951₽
+INCOMING
+INCOMING
+02/19
+5:4029₽
+02/19
+5: 4224P
+02/19
+5:5737₽
+INCOMING
+INCOMING
+INCOMING
+02/19
+6:1740₽
+02/19
+6:2338P
+02/19 10:2752P
+02/19 11:0023P
+INCOMING
+02/19 11:0130₽
+02/20 9:1328A
+INCOMING
+02/20 9:1436A
+02/20
+9: 5935A
+INCOMING
+02/20
+10:0
+02/20 10:3500A
+INCOMING
+02/20 10:3607A
+02/20 10:4909A
+INCOMING
+INCOMING
+02/20 10:5019A
+02/20 11:1104A
+02/20 11:1433A
+INCOMING
+02/20 11:1544A
+02/20 11:1806A
+INCOMING
+02/20 11:1920A
+02/20 11:2749A
+INCOMING
+02/20 11:2857A
+02/20 11:4843A
+02/20 11:4846A
+INCOMING
+02/20 11:4947A
+02/20 11: 5539A
+INCOMING
+02/20 11:5653A
+02/20 11: 5827A
+INCOMING
+02/20 11: 5938A
+DUR
+1
+10
+2
+1
+1
+0
+3
+0
+NO M
+2
+0
+5
++ O
+2
+0
+2
+0
+2
+2
+NOM
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+25
+25
+25
+0
+25
+25
+25
+0
+0
+25
+37
+25
+0
+37
+25
+0
+• 0
+• 0 o
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+37
+25
+37
+25
+37
+25
+37
+37
+25
+37
+25
+37
+Page 59
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+W PALM BCH FL
+W PALM BCH FL
+NACN
+NACN
+WEST PALM FL
+W PALM BCH FL
+WEST PALM FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK NY
+W PALM BCH FL
+NACN
+QUEENS
+QUEENS
+NY
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/20 12: 0052P
+02/20 12:0140P
+INCOMING
+INCOMING
+02/20 12:0203P
+02/20 12:0255P
+02/20 12:0311P
+02/20 12:0337P
+02/20 12:0355P
+INCOMING
+02/20 12:0441P
+02/20 12:0507P
+INCOMING
+02/20 12:0615₽
+02/20 12:1242P
+INCOMING
+02/20 12:1353P
+02/20 12: 3926P
+INCOMING
+02/20 12:4034P
+02/20 12:4650P
+INCOMING
+02/20 12:4807P
+02/20
+1: 41061
+INCOMING
+02/20
+1:4217P
+02/20
+2:1458P
+INCOMING
+02/20
+2:1609P
+02/20
+2: 2006P
+INCOMING
+02/20
+2:2119P
+02/20
+2:2621P
+INCOMING
+INCOMING
+02/20
+2: 2734P
+02/20
+3: 0923P
+02/20
+4: 3444₽
+INCOMING
+02/20
+4: 3554P
+02/20
+4: 3909₽
+02/20
+4: 3954P
+02/20
+4: 4149₽
+INCOMING
+02/20
+4: 4258P
+02/20 5:0605P
+DUR
+0
+1
+1
+0
+2
+1
+0
+1
+0
+• N
+0
+M HO
+N A HOMO
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+• 00
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+37
+37
+37
+25
+37
+37
+25
+37
+25
+37
+25
+5
+37
+37
+2
+37
+25
+37
+25
+37
+37
+25
+37
+37
+37
+25
+37
+25
+Page 60
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+* cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+MOBILE
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+WEST PALM
+NEW YORK
+FL
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+WILLOUGHBY OH
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+WEST PALM
+FL
+W PALM BCH FL
+NACN
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+02/20 5:0714P
+02/20
+5:2119P
+INCOMING
+02/20
+5:2227P
+02/20
+5: 3745P
+INCOMING
+02/20
+5:3855P
+02/20
+5:4028P
+02/20
+5: 4304₽
+02/20
+5: 5214P
+INCOMING
+02/20
+5: 5325P
+02/20
+5:5723₽
+INCOMING
+02/20
+5: 5832₽
+02/20
+6: 0138₽
+INCOMING
+02/20
+6: 0244P
+02/20
+6: 0758P
+02/20
+6: 1523P
+02/20
+6:1709P
+INCOMING
+02/20
+6:1817P
+02/20
+7:1907P
+INCOMING
+02/20
+7: 2017P
+02/20
+7: 2825P
+INCOMING
+02/20
+7:2933P
+02/20 8:0633P
+02/20
+9: 4545₽
+INCOMING
+02/20
+9:4657₽
+02/20 10:2636P
+INCOMING
+02/20 10:2746P
+02/20 11:2911P
+INCOMING
+INCOMING
+02/20 11: 3019P
+02/21 10:4721A
+02/21 11:0624A
+02/21 11:1339A
+INCOMING
+02/21 11:1451A
+DUR
+7
+3
+0
+1
+2
+3
+4
+0
+2
+1
+0
+5
+0
+2
+0
+NO m
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+• 00
+• 0 o
+• 00
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+37
+25
+37
+25
+37
+37
+37
+25
+37
+25
+37
+25
+37
+37
+17
+25
+37
+37
+37
+25
+37
+25
+37
+25
+37
+37
+37
+25
+37
+Page 61
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+W PALM BCH FL
+NACN
+NEW YORK
+WEST PALM
+WEST PALM
+NY
+FL
+FL
+W PALM BCH FL
+NACN
+NEW YORK
+NEW YORK
+NY
+NY
+W PALM BCH FL
+NACN
+NEW YORK
+WEST PALM
+NY
+FL
+UN. KINGDO
+WEST PALM
+FL
+W PALM BCH
+FL
+NACN
+NEW YORK
+NEW YORK
+WEST PALM
+NY
+NY
+FL
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+WILLOUGHBY OH
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/21 12:1647P
+INCOMING
+INCOMING
+02/21 12:1758P
+02/21 12:1845P
+02/21 12:2158P
+02/21 12:3727P
+02/21
+2: 1549P
+INCOMING
+INCOMING
+02/21
+2:1703₽
+02/21
+3: 1051P
+02/21
+3: 1130₽
+02/21
+3: 4635₽
+INCOMING
+02/21
+3: 4743₽
+02/21
+3: 4811₽
+02/21
+4:3103P
+02/21
+4: 3909P
+02/21
+4: 4304P
+02/21
+4:4424P
+INCOMING
+INCOMING
+02/21
+4:4534P
+02/21
+4: 4701P
+02/21
+4: 4802P
+02/21
+5:0548P
+02/21
+5:0941P
+INCOMING
+02/21
+5:1050₽
+02/21
+5:1936P
+INCOMING
+02/21
+5:2048P
+02/21
+6: 2755₽
+INCOMING
+02/21
+6: 2901₽
+02/21
+6: 5310₽
+INCOMING
+02/21
+6: 5417₽
+02/21
+8: 2033P
+INCOMING
+02/21
+8: 2148P
+02/21
+8: 2413₽
+02/21
+8: 2432P
+DUR
+1
+1
+2
+1
+0
+1
+1
+2
+0
+1
+2
+2
+0
+2
+0
+2
+0
+3
+O H
+NO M
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+25
+37
+37
+37
+37
+25
+37
+37
+37
+25
+37
+37
+37
+3
+0
+0
+0
+0
+0
+0
+0
+0
+35
+0
+0
+0
+0
+0
+0
+0
+37
+37
+25
+37
+25
+37
+25
+37
+25
+37
+25
+37
+25
+37
+Page 62
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+* cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+WEST PALM
+FL
+W PALM BCH FI
+NACN
+W PALM BCH FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+02/21 8:2538P
+02/21 8:2639P
+INCOMING
+02/21
+8:2746₽
+02/21 9:0825P
+INCOMING
+02/21 9:0933P
+02/21 10:2801P
+INCOMING
+02/21 10:2910P
+02/21 11:1923P
+INCOMING
+02/21 11:2031P
+02/21 11:2313P
+INCOMING
+02/21 11:2420P
+02/22 9:5254A
+INCOMING
+02/22
+9: 5358A
+02/22 11:3
+00A
+INCOMING
+02/22 11:3509A
+02/22 11:3615A
+INCOMING
+INCOMING
+02/22 11:3721A
+02/22 11:4846A
+02/22 12:1202P
+INCOMING
+02/22 12:1310P
+02/22 12:4449P
+INCOMING
+02/22 12:4558P
+02/22
+1:2423P
+INCOMING
+02/22
+1:2531P
+02/22
+2:2037P
+INCOMING
+02/22
+2: 2150₽
+02/22
+3: 4815₽
+INCOMING
+02/22
+3: 4927₽
+02/22
+3: 5816₽
+02/22
+4: 0709₽
+INCOMING
+02/22
+4: 0819P
+02/22
+4: 1426P
+DUR
+1
+0
+1
+4
+0
+37
+0
+10
+O HONO HO
+10
+0
+2
+0
+HN I
+• H
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+• 0 o
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+37
+25
+37
+25
+37
+25
+37
+25
+37
+25
+37
+25
+37
+2.
+5
+37
+2
+17
+2
+5
+37
+25
+37
+25
+37
+25
+37
+25
+37
+37
+25
+37
+25
+Page 63
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular°
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+MOBILE
+W PALM BCH FL
+W PALM BCH FL
+NACN
+NACN
+NEW YORK
+NEW YORK
+NEW YORK
+GARDENA
+NY
+NY
+NY
+CA
+W PALM BCH FL
+NACN
+QUEENS
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NEW YORK
+NY
+QUEENS
+NY
+NEW YORK
+NY
+W PALM BCH FL
+NEW YORK
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/22 4:1500P
+INCOMING
+02/22 4:1538P
+02/22 4:1613P
+INCOMING
+INCOMING
+02/22 4: 1615₽
+02/22 4:1727₽
+02/22
+4: 2732P
+INCOMING
+02/22 4: 2842P
+02/22 4:3826P
+INCOMING
+02/22 4:3934P
+02/22 4: 5302P
+INCOMING
+02/22 4:5424P
+02/22 4:5455P
+02/22
+4: 5724P
+02/22
+4:5748P
+INCOMING
+INCOMING
+02/22
+4: 5836P
+02/22
+4: 5859P
+02/22
+5:2645P
+INCOMING
+02/22
+5: 3951P
+02/22
+5:4705P
+02/22
+6:2646P
+02/22
+6: 3330₽
+INCOMING
+02/22
+6: 3436P
+02/22
+6: 4032P
+02/22
+6:4533P
+02/22
+6: 5531₽
+INCOMING
+INCOMING
+02/22
+9:1658₽
+02/22
+9:1849₽
+02/22
+9:1949P
+02/22
+9:2559P
+02/22
+9: 3045P
+02/22
+9: 3113P
+02/22
+9: 3210P
+DUR
+1
+1
+1
+1
+12
+1
+M HO
+H N
+1
+2
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+• 00
+• 00 C
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+37
+25
+37
+37
+25
+37
+25
+37
+25
+37
+37
+37
+37
+37
+37
+25
+37
+37
+37
+37
+25
+25
+25
+25
+25
+25
+25
+Page 64
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+MOBILE
+NEW YORK
+NY
+NY
+NEW YORK
+NY
+NEW YORK
+NY
+NEW YORK
+NY
+NWYRCYZN01 NY
+UN. KINGDO
+NEW YORK
+NY
+MOBILE
+NEW YORK
+MOBILE
+NEW YORK
+NY
+NY
+NY
+NY
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/22 9:3221P
+02/22
+9:3253P
+INCOMING
+02/22
+9: 3441P
+02/22 10:0143P
+INCOMING
+02/22 10:0739P
+02/22 10:2536P
+INCOMING
+02/22 10:3018P
+02/22 11:0101P
+02/22 11:0232P
+INCOMING
+02/22 11:5219P
+02/23 8:5541A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/23
+9: 2006A
+02/23
+9: 3736A
+02/23 10:1955A
+02/23 11:1442A
+02/23 11:1813A
+02/23 11: 5143A
+02/23 12:2805P
+02/23 12:3301P
+02/23 12:3351P
+02/23 12: 3918P
+02/23 1: 3602P
+02/23
+1:5800₽
+02/23
+2: 4304P
+02/23
+3: 1200₽
+02/23
+3: 1611P
+02/23
+3: 1725P
+INCOMING
+02/23
+4: 2809P
+02/23
+4: 3046₽
+02/23
+4: 3129P
+02/23
+4:3229P
+02/23
+4: :5522P
+DUR
+1
+2
+1
+1
+1
+1
+1
+2
+2
+1
+1
+HNN HAM
+AIR
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+. 35
+0
+0
+0
+0
+0
+• 35
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2
+25
+0
+0
+0
+0
+0
+0
+0
+• 0
+• 0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 65
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NEW YORK
+NY
+NY
+MOBILE
+NY
+W PALM BCH FL
+W PALM BCH FL
+NEW YORK
+MOBILE
+NY
+NY
+NEW YORK
+NY
+NEW YORK
+NEW YORK
+NY
+NY
+NEW YORK
+GARDENA
+MOBILE
+NY
+CA
+NY
+NEW YORK
+NY
+NEW YORK
+NY
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/23 4: 5605₽
+02/23
+4: 5724P
+INCOMING
+02/23
+5: 0157₽
+02/23
+5: 0303₽
+02/23
+5:0412P
+02/23
+5: 0550₽
+02/23
+5:0734P
+02/23
+5: 0835₽
+02/23
+5: 1002P
+02/23
+5:1120P
+02/23
+5: 1137P
+02/23
+5:2734P
+02/23
+5: 3523P
+02/23
+5: 4715P
+02/23
+6: 0248P
+02/23
+6: 0535P
+02/23
+6: 5925P
+02/23
+7:0241P
+02/23
+7: 0315P
+02/23
+7:0429P
+02/23
+7: 0839P
+02/23
+7:1112P
+02/23
+8: 0638₽
+02/23
+8:1712P
+02/23
+9:2837P
+02/23 10:0722P
+02/23 10:4434P
+02/23 10:5549P
+02/23 11:10278
+02/24
+9: 0939A
+02/24
+9:2242A
+02/24
+9: 2702A
+DUR
+1
+1
+1
+1
+2
+1
+2
+1
+1
+1
+1
+5
+27
+HAN
+1
+1
+NAN
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+0
+0
+0
+0
+0
+0
+0
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 66
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NY
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+MOBILE
+NEW YORK
+MOBILE
+NY
+NY
+NY
+MOBILE
+NY
+W PALM BCH FL
+MOBILE
+MOBILE
+NY
+NY
+MOBILE
+NEW YORK
+NEW YORK
+NEW YORK
+BROOKLYN
+NACN
+NACN
+NACN
+NEW YORK
+NEW YORK
+NACN
+NACN
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/24 9:2941A
+INCOMING
+02/24
+9:4541A
+02/24
+9: 5056A
+02/24 10:0339A
+02/24 10:1654A
+INCOMING
+INCOMING
+02/24 10:1952A
+02/24 10:2730A
+02/24 10:2808A
+02/24 10:3324A
+02/24 10:5355A
+INCOMING
+02/24 10:5853A
+02/24 11:1815A
+INCOMING
+02/24 11:1934A
+02/24 11:2028A
+INCOMING
+INCOMING
+02/24 11:4010A
+02/24 11:4434A
+02/24 11:5012A
+02/24 11:5845A
+INCOMING
+INCOMING
+02/24 12:2007P
+02/24 12:2230P
+02/24 12:2743P
+INCOMING
+INCOMING
+02/24 3:2716P
+02/24
+3: 3007₽
+02/24
+4: 0547P
+02/24
+4: 2531P
+INCOMING
+INCOMING
+INCOMING
+02/24
+4: 3107P
+02/24
+4: 3855P
+02/24
+4: 5311P
+02/24
+5: 3300₽
+INCOMING
+INCOMING
+INCOMING
+02/24
+5: 4406₽
+02/24
+5:4500₽
+02/24
+6: 3111₽
+DUR
+2
+1
+1
+1
+1
+8
+1
+2
+1
+3
+2
+NAN
+4
+2
+3
+2
+~ m
+AN O
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2
+5
+2
+5
+25
+25
+25
+527
+527
+527
+527
+527
+527
+527
+527
+527
+527
+527
+Page 67
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NACN
+SAN JOSE
+BROOKLYN
+SAN JOSE
+NEW CANAAN
+NEW CANAAN
+NEW YORK
+BROOKLYN
+SAN JOSE
+NEW YORK
+NEWYORK
+NEW YORK
+CA
+NY
+CA
+CT
+CT
+NY
+NY
+CA
+NY
+NY
+NY
+NACN
+NACN
+NEW YORK
+SAN
+JOSE
+SAN JOSE
+SAN JOSE
+SAN
+JOSE
+SAN JOSE
+NEW YORK
+NEW YORK
+NY
+CA
+CA
+CA
+CA
+CA
+NY
+NY
+NACN
+NACN
+NEWPORTBCH CA
+BEVERLYHLS CA
+NACN
+NEW YORK
+NY
+NACN
+BROOKLYN
+NEW YORK
+NY
+NY
+NACN
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/24 7:1724P
+02/24
+7: 3043P
+02/24
+7: 3701₽
+02/24
+7: 3746P
+02/24
+7: 4107P
+02/24
+7: 4403P
+02/24
+7: 4601₽
+02/24
+7: 4822P
+02/24
+7: 5202P
+02/24
+7: 5240P
+02/24
+7: 5342₽
+02/24
+7: 5413P
+02/24
+7: 5856P
+02/24
+8:1200P
+02/24
+8: 1309P
+02/24
+8:4442P
+02/24
+9: 3002P
+02/24
+10:1613P
+02/24 10:5745P
+02/24 11:1135P
+02/25
+7: 0755A
+02/25
+7: 0845A
+02/25
+7: 1117A
+02/25
+7: 3022A
+02/25
+7: 3257A
+02/25
+7: 3413A
+02/25
+8: 1416A
+02/25
+8: 3403A
+02/25
+8: 4531A
+02/25
+9: 1432A
+02/25
+9: 2833A
+02/25
+9: 3340A
+DUR
+8
+0
+4
+2
+3
+0
+1
+1
+0
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+527
+25
+527
+25
+527
+527
+527
+527
+25
+527
+527
+527
+527
+527
+527
+25
+2
+25
+25
+25
+527
+527
+527
+527
+527
+527
+527
+527
+527
+527
+527
+527
+Page 68
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NACN
+NEW YORK
+BROOKLYN
+SAN JOSE
+SAN JOSE
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+CA
+CA
+NY
+NY
+NY
+NACN
+SAN JOSE
+NEW YORK
+CA
+NY
+NACN
+KENSINGTON
+MD
+NACN
+SAN JOSE
+THOUSNDOAK
+NEW YORK
+CA
+CA
+NY
+NACN
+SAN JOSE
+SAN JOSE
+NEW YORK
+KENSINGTON
+NEW YORK
+NEW YORK
+CA
+CA
+NY
+MD
+NY
+NY
+NACN
+NEW YORK
+NEW
+YORK
+NEW YORK
+NEW YORK
+SAN JOSE
+NEW YORK
+QUEENS
+NY
+NY
+NY
+NY
+CA
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/25 9:4342A
+02/25 10: 0926A
+02/25 10:1001A
+02/25 10:1006A
+02/25 10:2911A
+02/25 10:5428A
+02/25 10:5707A
+02/25 11:0413A
+02/25 11:0956A
+02/25 11:1306A
+02/25 11:1336A
+02/25 11: 3122A
+02/25 11: 3608A
+02/25 11:3856A
+02/25 11:4418A
+02/25 11:4541A
+02/25 12:2548P
+02/25 12:3128P
+02/25 12:3229P
+02/25 12:4229P
+02/25 12:4339P
+02/25 12:4709P
+02/25 12:5019P
+02/25
+1: 0131P
+02/25
+1: 0424P
+02/25
+1: 0903P
+02/25
+1:1306P
+02/25
+1:1654P
+02/25
+1: 1926P
+02/25
+2: 0847₽
+02/25
+2: 0957₽
+02/25
+2: 1216₽
+DUR
+1
+1
+7
+0
+2
+2
+1
+HM NO
+N M
+0
+H N
+4
+1
+5
+4
+4
+N N
+OH M
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+527
+0
+527
+527
+0
+25
+25
+527
+0
+0
+0
+527
+527
+527
+0
+0
+0
+0
+25
+527
+527
+527
+0
+527
+25
+527
+527
+527
+25
+25
+0
+527
+• • •
+• 00
+527
+0
+527
+527
+527
+0
+527
+527
+0
+527
+0
+0
+527
+25
+527
+527
+Page 69
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+BROOKLYN
+NEW YORK
+QUEENS
+NACN
+NEW YORK
+LOSANGELES
+SAN JOSE
+MONTEREY
+DIR. ASST.
+MONTEREY
+SAN JOSE
+NEW YORK
+QUEENS
+NACN
+WLOSANGELS
+NEW YORK
+BROOKLYN
+QUEENS
+QUEENS
+SAN JOSE
+NACN
+NACN
+SAN JOSE
+NACN
+NACN
+SAN JOSE
+BROOKLYN
+BROOKLYN
+SAN JOSE
+WLOSANGELS
+SAN JOSE
+SAN JOSE
+NY
+NY
+NY
+NY
+CA
+CA
+CA
+CA
+CA
+NY
+NY
+CA
+NY
+NY
+NY
+NY
+CA
+CA
+CA
+NY
+NY
+CA
+CA
+CA
+CA
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/25 2:1513P
+02/25
+2: 1721P
+02/25
+2: 1802₽
+02/25
+2:2237P
+02/25
+2:2354P
+02/25
+2: 2611P
+02/25
+2: 3007₽
+02/25
+2: 3648P
+02/25
+2: 3708P
+02/25
+2: 3709P
+02/25
+2: 3718P
+02/25
+2: 5001P
+02/25
+2: 5101P
+02/25
+2:5240P
+02/25
+2: 5624P
+02/25
+2: 5702P
+02/25
+2:5944P
+02/25
+3: 0209P
+02/25
+3: 0656P
+02/25
+3: 3110P
+02/25
+3: 3933P
+02/25
+3: 4127₽
+02/25
+4: 0310₽
+02/25
+4: 4544P
+02/25
+4: 4617₽
+02/25
+5:2128₽
+02/25
+5: 4452₽
+02/25
+5: 5126P
+02/25
+5: 5131₽
+02/25
+5:5548P
+02/25
+6: 3821P
+02/25
+6:4004P
+DUR
+1
+5
+1
+2
+9
+0
+1
+0
+3
+0
+1
+2
+NNH
+W N
+ONMONTON
+N W
+16
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+LAND TOTAL RSYS
+0
+527
+527
+527
+0
+527
+527
+527
+0
+0
+25
+527
+527
+0
+0
+0
+0
+527
+25
+527
+527
+0
+527
+527
+527
+527
+527
+0
+0
+0
+0
+0
+0
+0
+• 0 o
+0 0 0 00 O
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+527
+25
+527
+527
+25
+527
+527
+25
+527
+527
+25
+527
+25
+25
+Page 70
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+BROOKLYN
+QUEENS
+QUEENS
+QUEENS
+SAN JOSE
+SAN JOSE
+QUEENS
+NEW YORK
+QUEENS
+NY
+NY
+NY
+NY
+NY
+CA
+CA
+NY
+NY
+NY
+NACN
+NEW YORK
+QUEENS
+MONTEREY
+NY
+NY
+CA
+NACN
+SAN JOSE
+SAN JOSE
+NEW
+YORK
+NEW
+YORK
+NEW
+YORK
+NEW YORK
+QUEENS
+CA
+CA
+NY
+NY
+NY
+NY
+NY
+NACN
+BROOKLYN
+NY
+KENSINGTON MD
+NACN
+SAN MONICA CA
+QUEENS
+GARDENA
+NEW YORK
+NEW YORK
+NY
+CA
+NY
+NY
+BRAZIL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/25 6:4933₽
+02/25
+6: 5528P
+02/25
+7: 0507₽
+02/25
+7: 0521₽
+02/25
+7: 3114P
+02/25
+7: 4434P
+02/25
+7: 4501₽
+02/25
+7:4959P
+02/25
+7: 5519P
+02/25
+7: 5739P
+02/25
+8: 0937₽
+02/25
+8: 2833P
+02/25
+8: 2922P
+02/25
+8: 3033
+P
+02/25
+9: 1222P
+02/25 11:0915P
+02/26
+12:1205A
+02/26
+7: 4021A
+02/26
+7: 5314A
+02/26
+8:1956A
+02/26
+8: 3341A
+02/26
+8: 4414A
+02/26
+8: 4928A
+02/26
+9: 0625A
+02/26
+9: 1701A
+02/26
+9:2617A
+02/26
+9: 3415A
+02/26
+9: 4209A
+02/26
+9: 4310A
+02/26
+9:5146A
+02/26
+9:5550A
+02/26 10:1551A
+DUR
+1
+2
+1
+1
+0
+0
+1
+2
+1
+2
+A NU
+0
+1
+2
+1
+8
+N m
+2
+2
+3
+PROPRIETARY AND CONFIDENTIAL
+Not for
+use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+527
+527
+527
+0
+527
+527
+25
+0
+0
+25
+527
+527
+0
+0
+0
+0
+527
+527
+527
+527
+527
+527
+25
+0
+0
+25
+527
+527
+527
+0
+0
+0
+527
+527
+0
+0
+0
+0
+0
+0
+0
+527
+527
+527
+0
+0
+527
+527
+527
+527
+0
+527
+527
+• 65
+• 65
+527
+Page 71
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NEW YORK
+NEW YORK
+NEW
+YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+FRANCE
+BROOKLYN
+BROOKLYN
+WLOSANGELS
+NEW YORK
+NY
+NY
+CA
+NY
+WLOSANGELS CA
+NACN
+QUEENS
+NEW YORK
+NY
+NY
+NACN
+FRANCE
+SAN JOSE
+NEW YORK
+NEW YORK
+CA
+NY
+NY
+NACN |
+BRAZIL
+NACN
+SAN JOSE
+CA
+UN. KINGDO
+NEW YORK
+NEW YORK
+BROOKLYN
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/26 10:1640A
+02/26 10:1727A
+02/26 10:1910A
+02/26 10:1943A
+02/26 10:2008A
+02/26 10:4225A
+02/26 10:4246A
+02/26 10:4805A
+02/26 10:5629A
+02/26 11:0704A
+02/26 11:1425A
+02/26 11:1820A
+02/26 11:1940A
+02/26 11:2448A
+02/26 11:2535A
+02/26 11:2816A
+02/26 11:3355A
+02/26 11:4249A
+02/26 11:4817A
+02/26 11:5941A
+02/26 11: 5955A
+02/26 12:0907₽
+02/26 12:1258P
+02/26 12:1353P
+02/26 12:2504P
+02/26 12:2947P
+02/26 12:3450P
+02/26 12:3911P
+02/26 12:4618P
+02/26 12:5630P
+02/26
+1:0134P
+02/26 1:1130P
+DUR
+1
+2
+1
+1
+1
+1
+5
+1
+3
+2
+OH N
+3
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+527
+0
+527
+527
+527
+527
+0
+0
+.35
+0
+0
+0
+• 35
+0
+527
+527
+527
+527
+527
+527
+• 0
+527
+527
+527
+527
+0
+0
+. 3
+5
+0
+0
+527
+527
+. 35
+527
+25
+.65
+0
+0
+0
+• 65
+527
+527
+527
+527
+527
+25
+.35
+0
+0
+0
+0
+• 35
+527
+527
+527
+0
+0
+0
+527
+527
+527
+527
+U
+Page 72
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+BEVERLYHLS
+NEW YORK
+BROOKLYN
+NEW YORK
+NEW YORK
+SAN JOSE
+SAN JOSE
+SAN JOSE
+SAN JOSE
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NEW
+YORK
+NEW
+YORK
+NEW
+YORK
+NEW
+YORK
+NEW
+YORK
+NEW
+YORK
+NEW
+YORK
+NEW YORK
+NEW YORK
+NEW
+YORK
+NEW
+YORK
+NEW YORK
+NEW
+YORK
+NEW
+YORK
+NEW YORK
+BEVERLYHLS
+NEW YORK
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+CA
+NY
+NY
+NY
+NY
+CA
+CA
+CA
+CA
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+CA
+NY
+02/26 1:1718P
+02/26
+1:2249P
+02/26
+1: 4328P
+02/26
+1:5059P
+02/26
+2:0021P
+02/26
+2: 2339P
+02/26
+2: 3232P
+02/26
+3: 0754P
+02/26
+3: 1224P
+INCOMING
+02/26
+3: 1857₽
+02/26
+3: 5530₽
+02/26
+3: 5613P
+02/26
+3: 5713P
+02/26
+3: 57381
+P
+02/26
+4: :0002P
+02/26
+4: 0035P
+02/26
+5:3409P
+02/26
+5:5731P
+02/26
+6: 1757P
+02/26
+6:5935P
+02/26
+7: 3652P
+02/26 8:2734P
+02/26 11:2232P
+02/26 11: 3531P
+02/27 12:5755A
+02/27
+1: 3429A
+02/27
+8: 2601A
+02/27
+9: 0916A
+02/27
+9:1327A
+02/27
+9:1455A
+02/27
+9:1702A
+02/27
+9:1728A
+DUR
+2
+1
+2
+4
+2
+0
+1
+1
+H N N
+1
+1
+11
+1
+HAMM
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+.25
+.25
+.25
+25
+5
+1
+25
+.25
+.25
+2.75
+.25
+1.5
+.25
+LAND TOTAL RSYS
+0
+527
+527
+527
+0
+527
+527
+25
+0
+0
+0
+0
+0
+0
+.25
+.25
+.25
+25
+25
+25
+5
+1
+.. 5
+25
+25
+25
+25
+527
+25
+25
+25
+25
+25
+25
+25
+25
+25
+0
+0
+0
+0
+0
+0
+.25
+.25
+2.75
+.25
+1.5
+.25
+• 5
+0
+25
+25
+25
+25
+25
+25
+25
+25
+527
+527
+527
+527
+Page 73
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NACN
+BRAZIL
+LAS VEGAS
+NV
+BEVERLYHLS CA
+NEW YORK
+NY
+NEW YORK
+NY
+NACN
+NACN
+NACN
+NEW YORK
+NY
+REDWOOD CY CA
+BEVERLYHLS
+CA
+NEW YORK
+NY
+NEW YORK
+NY
+NEW YORK
+NY
+BEVERLYHLS CA
+NACN
+QUEENS
+GARDENA
+NEW CANAAN
+NEW YORK
+BEVERLYHLS CA
+NEW YORK
+NY
+CA
+CT
+NY
+NY
+NACN
+CANOGAPARK CA
+NEW YORK
+NEW YORK
+NY
+NY
+NACN
+NEW YORK
+SAN MONICA
+ANAHE IM
+NEW YORK
+NY
+CA
+CA
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+02/27 9:1811A
+02/27
+9:2848A
+02/27
+9: 3150A
+02/27
+9: 3317A
+02/27
+9: 4205A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/27 10:0835A
+02/27 10:0919A
+02/27 10:1201A
+02/27 10:1231A
+02/27 10:1849A
+02/27 10:2003A
+02/27 10:2332A
+INCOMING
+02/27 10: 3329A
+02/27 10:3419A
+INCOMING
+02/27 11:0551A
+02/27 11:1715A
+INCOMING
+02/27 11:1828A
+02/27 11:2454A
+02/27 11:2603A
+02/27 11:2918A
+02/27 11: 3243A
+02/27 11: 3750A
+INCOMING
+INCOMING
+02/27 11: 4057A
+02/27 11:4226A
+02/27 11: 4452A
+INCOMING
+02/27 11: 5339A
+02/27 11:5436A
+INCOMING
+INCOMING
+02/27 11:5524A
+02/27 11:5710A
+02/27 11:5757A
+02/27 12:0042P
+02/27 12:0140P
+DUR
+11
+2
+2
+2
+15
+3
+2
+1
+1
+2
+2
+10
+1
+15
+1
+~ H
+1
+3
+4
+3
+2
+3
+1
+9
+1
+1
+2
+1
+N N
+6
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+X cingular®
+AIR
+0
+0
+0
+3.7
+5
+0
+0
+0
+0
+0
+0
+0
+1.5
+LAND TOTAL RSYS
+0
+1.3
+0
+1.3
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+3.75
+0
+0
+0
+0
+1.5
+527
+527
+527
+527
+527
+527
+527
+527
+527
+527
+527
+527
+527
+25
+527
+527
+527
+527
+527
+527
+527
+527
+527
+527
+527
+527
+527
+527
+527
+527
+527
+25
+Page 74
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NY
+NACN
+NEW YORK
+NEW YORK
+NY
+NY
+NACN
+SAN JOSE
+NEW YORK
+QUEENS
+QUEENS
+NEW YORK
+BROOKLYN
+NEW YORK
+QUEENS
+NEW YORK
+CA
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NACN
+BRAZIL
+BRAZIL
+SAN JOSE
+NEW YORK
+CA
+NY
+VANCOUVER
+SAN JOSE
+SAN JOSE
+CA
+CA
+BEVERLYHLS CA
+NACN
+NEW YORK
+NEW YORK
+NY
+NY
+NACN
+BRAZIL
+NEW YORK
+SAN JOSE
+BEVERLY HI
+NEW YORK
+NY
+CA
+CA
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/27 12:0447P
+02/27 12:1133P
+02/27 12:1219P
+02/27 12:1341P
+02/27 12:1512P
+02/27 12:1658P
+02/27 12:1704P
+02/27 12:1934P
+02/27 12:1947P
+02/27 12:2101P
+02/27 12:2241P
+02/27 12:2929P
+02/27 12:4231P
+02/27 12:4357P
+02/27 12:5823P
+02/27 1:01
+52P
+02/27
+1:
+03441
+02/27
+1: 0907P
+02/27
+1: 0937P
+02/27
+1:11
+06P
+02/27 1:1150P
+02/27 1:1209P
+02/27
+1:1339P
+02/27
+1:1438P
+02/27
+1: 4616P
+02/27
+2: 0226₽
+02/27
+2: 0458P
+02/27
+2:0840P
+02/27
+2: 1607₽
+02/27
+2:1720₽
+02/27
+2: 1819₽
+02/27
+2: 2010P
+DUR
+2
+1
+2
+1
+0
+2
+1
+2
+1
+4
+N H
+0
+N M
+3
+2
+1
+8
+2
+ON M
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+• 5
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+1
+1
+3
+• 5
+0
+0
+0
+0
+0
+0
+• 00 O
+0
+0
+00
+0
+0
+.. 3
+1.3
+0
+. 2
+25
+527
+527
+527
+527
+25
+527
+527
+527
+527
+527
+527
+527
+527
+527
+527
+527
+25
+527
+5
+0
+0
+0
+0
+0
+0
+0
+.. 000O
+0
+5.2
+0
+0
+0
+0
+5.2
+0
+0
+25
+25
+527
+527
+27
+27
+27
+27
+27
+25
+27
+27
+UHU
+Page 75
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+* cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+MOBILE
+GARDENA
+CA
+SANTA MONI CA
+WEST LOS A CA
+NEW YORK
+NY
+WEST LOS A CA
+SAN JOSE
+CA
+NEW YORK
+NY
+NACN
+MOBILE
+MOBILE
+MOBILE
+NEWPORT BE CA
+SAN JOSE
+CA
+NACN
+NACN
+SANTA MONI
+SAN JOSE
+SAN JOSE
+SANTA MONI
+ASPEN
+CA
+CA
+CA
+CA
+CO
+NACN
+QUEENS
+NEW YORK
+LOS ANGELE CA
+NEW YORK
+SAN JOSE
+BEVERLY HI CA
+GARDENA
+BROOKLYN
+QUEENS
+NY
+NY
+NY
+CA
+CA
+NY
+NY
+NACN
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/27 2:2127₽
+02/27
+2:2504P
+02/27
+2:2659P
+02/27
+2: 3127₽
+02/27
+2: 3752₽
+02/27
+2: 3931P
+02/27
+2: 4113P
+02/27
+2:4424P
+INCOMING
+02/27
+2:4617P
+02/27
+2: 4810₽
+02/27
+2:4859P
+02/27
+2:4935P
+02/27
+2: 5037P
+02/27
+2:5414P
+INCOMING
+INCOMING
+02/27
+2: 5627P
+02/27
+2:5846P
+02/27
+3: 0642P
+02/27
+3: 1019P
+02/27
+3:1404P
+02/27
+3: 1417P
+02/27
+3: 2138P
+INCOMING
+02/27
+3: 3008P
+02/27
+3: 3130₽
+INCOMING
+02/27
+3: 4725₽
+02/27
+3: 4827₽
+INCOMING
+02/27
+3: 5503P
+02/27
+3: 5707₽
+02/27
+3: 5715₽
+02/27
+3: 5816P
+02/27
+3: 5931₽
+02/27
+4: 0453P
+INCOMING
+02/27
+4: 0857P
+DUR
+2
+2
+4
+6
+1
+0
+2
+2
+1
+1
+N H W
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+• •
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+• 0°
+0 0 0
+• • •
+000
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+27
+27
+27
+27
+27
+27
+25
+27
+27
+27
+27
+27
+27
+25
+25
+27
+27
+27
+27
+27
+27
+27
+25
+27
+27
+27
+27
+27
+Page 76
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+GARDENA
+SAN JOSE
+NY
+CA
+CA
+NACN
+GARDENA
+SEATTLE
+CA
+WA
+MOBILE
+NACN
+VAN NUYS
+CA
+NACN
+NEW YORK
+NY
+NACN
+NACN
+GARDENA
+SANTA MONI
+CA
+CA
+NACN
+NEW YORK
+PALMDALE
+NEW YORK
+PALMDALE
+PALMDALE
+NEW YORK
+BEVERLY HI
+PALMDALE
+NEW YORK
+BEVERLY HI
+PALMDALE
+NEW YORK
+WEST LOS A CA
+PALMDALE
+NEW YORK
+NEW YORK
+NY
+CA
+NY
+CA
+CA
+NY
+CA
+CA
+NY
+CA
+CA
+NY
+CA
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+02/27 4:1014P
+02/27 4:1046P
+02/27
+4: 1322P
+INCOMING
+02/27
+4: 1953₽
+02/27
+4: 2134P
+02/27
+4: 3240₽
+02/27
+4: 3854P
+INCOMING
+02/27
+4: 5912P
+02/27
+5:0434P
+INCOMING
+02/27
+5: 0456₽
+02/27
+5:0806₽
+INCOMING
+INCOMING
+02/27
+5:0849₽
+02/27
+5: 1123P
+02/27
+5:1957P
+02/27
+5:2031P
+INCOMING
+INCOMING
+02/27
+5: 2245P
+02/27
+5:2640P
+02/27
+5: 4508P
+INCOMING
+02/27
+5:5048P
+02/27
+5:5516P
+02/27
+5:5740₽
+02/27
+6:1050P
+02/27
+6:2854P
+02/27
+6:2900₽
+02/27
+6: 3505P
+02/27
+6: 4252₽
+02/27
+7: 0750₽
+INCOMING
+02/27
+7: 0934P
+02/27
+7:1240P
+02/27
+7: 1830₽
+INCOMING
+02/27
+7:4730P
+02/27
+7: 4808P
+DUR
+1
+1
+1
+3
+2
+4
+0
+1
+1
+H H
+2
+0
+0
+0
+0
+N 4
+HOYT
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+27
+27
+25
+27
+27
+27
+27
+27
+25
+27
+27
+27
+27
+27
+25
+• 00 • 0 O
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+27
+27
+25
+27
+27
+25
+27
+27
+25
+27
+27
+Page 77
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+* cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+PALMDALE
+NEW YORK
+NEW YORK
+BROOKLYN
+PALMDALE
+NACN
+PALMDALE
+PALMDALE
+NACN
+NACN
+PALMDALE
+MOBILE
+NEW YORK
+NACN
+BRAZIL
+BRAZIL
+NEW YORK
+NEW YORK
+PALMDALE
+PALMDALE
+PALMDALE
+BROOKLYN
+BROOKLYN
+BROOKLYN
+NACN
+PALMDALE
+BROOKLYN
+NEW YORK
+MOBILE
+BROOKLYN
+MOBILE
+PALMDALE
+CA
+NY
+NY
+NY
+CA
+CA
+CA
+CA
+NY
+NY
+NY
+CA
+CA
+CA
+NY
+NY
+NY
+CA
+NY
+NY
+NY
+CA
+ANS NEW YORK
+CALLED PHONE CDATE CTIME
+02/27 7:5802P
+02/27 7:5855P
+INCOMING
+02/27
+7: 5958₽
+02/27
+8: 0030₽
+02/27
+8: 0342P
+INCOMING
+02/27
+8: 0648P
+02/27
+8: 0742₽
+02/27
+8: 1015₽
+INCOMING
+INCOMING
+02/27
+8: 1214P
+02/27
+8: 1603P
+02/27
+8: 2126P
+02/27
+8:2949P
+02/27
+8: 3142P
+INCOMING
+02/27
+9:0354P
+02/27
+10:0554P
+02/27 10:0641P
+02/27 10:0858P
+02/27 10:4837P
+02/27 11:0534P
+02/27 11:1101P
+02/27 11:1444P
+02/27 11: 2623P
+02/27 11:2700P
+02/27 11:3206P
+INCOMING
+02/27 11:4715P
+02/28 12:0340A
+02/28 12:1025A
+INCOMING
+02/28 12:1055A
+02/28 12:1143A
+02/28 12:1610A
+02/28 12:2602A
+02/28
+2: 4657A
+DUR
+1
+4
+0
+0
+4
+0
+H ч
+1
+0
+0
+1
+H ч
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+65
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+65
+0
+0
+0
+0
+0
+0
+0
+0
+25
+27
+27
+27
+25
+27
+25
+25
+27
+27
+25
+27
+27
+2
+27
+27
+27
+2
+5
+25
+27
+27
+27
+27
+25
+27
+27
+27
+27
+27
+25
+Page 78
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+AWS NEW YORK
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+CALLED PHONE CDATE CTIME
+NEW YORK
+NY
+INCOMING
+NEW YORK
+NY
+02/28 8:0136A
+INCOMING
+02/28 8:0809A
+NEW YORK
+NY
+INCOMING
+NEW YORK
+NY
+02/28 8:2336A
+02/28 8:2445A
+NACN
+INCOMING
+02/28 8:3806A
+NEW YORK
+NY
+NACN
+02/28 8:3928A
+INCOMING
+02/28 8:4936A
+NACN
+INCOMING
+02/28
+9: 0514A
+GARDENA
+CA
+02/28
+9:1109A
+MOBILE
+02/28
+9:1239A
+NACN
+INCOMING
+02/28
+9:1915A
+NACN
+INCOMING
+02/28
+9: 1946A
+NEW YORK
+NY
+02/28
+9: 2050A
+NACN
+INCOMING
+02/28
+9: 2205A
+LOS ANGELE CA
+02/28
+9:2324A
+QUEENS
+NY
+02/28
+9:2446A
+NACN
+INCOMING
+02/28
+9: 4035A
+BROOKLYN
+NY
+02/28
+9:4754A
+NACN
+INCOMING
+02/28
+9: 5519A
+NEW YORK
+NY
+INCOMING
+02/28
+10: 0044A
+BROOKLYN
+NY
+02/28 10:0256A
+NACN
+INCOMING
+02/28 10: 0606A
+NACN
+INCOMING
+02/28 10:1240A
+NACN
+INCOMING
+02/28 10:2133A
+NACN
+INCOMING
+02/28 10: 3609A
+LOS ANGELE CA
+02/28 10:3624A
+MORIARTY
+NM
+02/28 10:3910A
+GARDENA
+CA
+02/28 11: 2006A
+NEW YORK
+NY
+INCOMING
+02/28 11: 2059A
+MAR VISTA
+CA
+02/28 11:2132A
+NEW YORK
+NY
+02/28 11:2427A
+NEW YORK
+NY
+02/28 11: 2550A
+DUR
+2
+2
+1
+1
+1
+2
+1
+2
+1
+2
+3
+1
+2
+1
+1
+N N M
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+• 0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+• • o
+• 0 0 0 00.
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+2
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+Page 79
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NACN
+NEW YORK
+WEST LOS A CA
+QUEENS
+NY
+NY
+NACN
+MORIARTY
+NM
+MOBILE
+PALMDALE
+NEW YORK
+NEW YORK
+CA
+NY
+NY
+NACN
+NEW YORK
+PALMDALE
+NY
+CA
+NACN
+NACN
+NACN
+PALMDALE
+CA
+NACN
+NACN
+PALMDALE
+PALMDALE
+CA
+CA
+NACN
+PALMDALE
+BROOKLYN
+MORIARTY
+CA
+NY
+NM
+NACN
+NACN
+PALMDALE
+NEW YORK
+MAR VISTA
+NEW YORK
+PALMDALE
+CA
+NY
+CA
+NY
+CA
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/28 11:2711A
+02/28 11:2908A
+02/28 11:2951A
+02/28 11:3118A
+02/28 11:3159A
+02/28 11:3300A
+02/28 11:3515A
+02/28 11:3653A
+02/28 11:3908A
+02/28 11:3931A
+02/28 11:4031A
+02/28 11:4148A
+02/28 11:4825A
+02/28 11:4901A
+02/28 12:0114P
+02/28 12:0311P
+02/28 12:0408P
+02/28 12:0629P
+02/28 12:1104P
+02/28 12:1807P
+02/28 12:1832P
+02/28 12:1958P
+02/28 12:2059P
+02/28 12:2252P
+02/28 12:2707P
+02/28 12: 3028P
+02/28 12:3044P
+02/28 12:4017P
+02/28 12:4619P
+02/28 12:5145P
+02/28 12:5303P
+02/28 12:5404P
+DUR
+2
+1
+2
+1
+1
+2
+1
+0
+1
+1
+2
+0
+1
+0
+0
+2
+0
+3
+0
+HAMO
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+• 0 o
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+27
+27
+27
+27
+27
+27
+27
+25
+27
+27
+27
+27
+27
+27
+25
+27
+25
+27
+27
+27
+27
+25
+27
+27
+27
+25
+Page 80
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NACN
+PALMDALE
+PALMDALE
+CA
+CA
+NACN
+PALMDALE
+PALMDALE
+ELMSFORD
+ELMSFORD
+CA
+CA
+NY
+NY
+DIR. ASST.
+BEVERLY HI CA
+SANTA ANA
+CA
+NACN
+NACN
+PALMDALE
+PALMDALE
+PALMDALE
+PALMDALE
+CA
+CA
+CA
+CA
+NACN
+NACN
+PALMDALE
+PALMDALE
+PALMDALE
+CA
+CA
+CA
+NACN
+NACN
+PALMDALE
+QUEENS
+QUEENS
+QUEENS
+CA
+NY
+NY
+NY
+NACN
+PALMDALE
+NEW YORK
+NEW YORK
+CA
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/28 12:5410P
+02/28 1:0459P
+02/28
+1: 1134P
+02/28
+1:1429P
+02/28
+1:2025P
+02/28
+1: 3453P
+02/28
+1:4144P
+02/28
+1: 4244P
+02/28
+1:4418P
+02/28
+1:4419P
+02/28
+1:5135P
+02/28
+2: 0255P
+02/28
+2: 0701P
+02/28
+2: 2605
+P
+02/28
+2: 3037P
+02/28
+2: 3909P
+02/28
+2:4748P
+02/28
+2:5919P
+02/28
+3 : 0002P
+02/28
+3: 0009P
+02/28
+3: 0206P
+02/28
+3: 0511₽
+02/28
+3: 0625P
+02/28
+3: 0932P
+02/28
+3: 0957₽
+02/28
+3: 1147₽
+02/28
+3: 1158₽
+02/28
+3: 1214P
+02/28
+3: 1555₽
+02/28
+3: 1847₽
+02/28
+3: 1950₽
+02/28
+3: 2240P
+DUR
+1
+0
+4
+1
+1
+0
+3
+2
+M HO
++ HO
+0
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+27
+25
+25
+27
+25
+25
+27
+27
+27
+27
+27
+25
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+27
+27
+25
+27
+27
+27
+27
+25
+27
+27
+Page 81
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+PALMDALE
+PALMDALE
+CA
+CA
+NACN
+NACN
+NEW YORK
+GARDENA
+NY
+CA
+NACN
+NEWPORT BE CA
+NACN
+PALMDALE
+PALMDALE
+NEW YORK
+MAR VISTA
+MAR VISTA
+NEWPORT BE
+CA
+CA
+NY
+CA
+CA
+CA
+MOBILE
+PALMDALE
+SANTA MONI
+QUEENS
+PALMDALE
+NEW YORK
+QUEENS
+CA
+CA
+NY
+CA
+NY
+NY
+MOBILE
+NACN
+NACN
+NEW YORK
+NY
+NACN
+NEW YORK
+NY
+NACN
+PALMDALE
+PALMDALE
+CA
+CA
+MOBILE
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/28 3:2918P
+02/28
+3: 2932P
+INCOMING
+INCOMING
+02/28
+3: 3810₽
+02/28
+3: 4028₽
+02/28
+3: 4122₽
+02/28
+3: 4359P
+INCOMING
+02/28
+3: 4929₽
+02/28
+3: 5206₽
+INCOMING
+02/28
+3: 5254₽
+02/28
+3: 5303P
+02/28
+4: 1321₽
+02/28
+4:1850P
+02/28
+4: 2209P
+02/28
+4:25
+1
+P
+02/28
+4:5417P
+02/28
+4: 5547P
+02/28
+5:0244P
+02/28
+5:0409P
+02/28
+5: 0539P
+02/28
+5:0651P
+02/28
+5: 0722P
+02/28
+5:1504₽
+02/28
+5:1632P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/28
+5:2231P
+02/28
+5:2412P
+02/28
+5: 3250₽
+02/28
+5:4141P
+02/28
+5: 4327₽
+02/28
+5:4837₽
+02/28
+5: 5808P
+02/28
+5: 5852₽
+02/28
+6: 0303₽
+DUR
+0
+3
+2
+2
+0
+0
+0
+O H
+PROPRIETARY AND CONFIDENTIAL
+Not for
+use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+• 0O
+• • •
+• 0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+27
+27
+27
+27
+27
+27
+27
+25
+25
+27
+27
+27
+27
+2
+27
+27
+27
+27
+27
+27
+27
+27
+27
+25
+25
+27
+Page 82
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+PALMDALE
+QUEENS
+PALMDALE
+PALMDALE
+CA
+NY
+CA
+CA
+NACN
+PALMDALE
+PALMDALE
+CA
+CA
+MOBILE
+PALMDALE
+PALMDALE
+CA
+CA
+NACN
+NACN
+MOBILE
+NACN
+NEW YORK
+NY
+MOBILE
+NEW YORK
+NY
+MOBILE
+NACN
+NACN
+CLAREMONT- CA
+NACN
+WEST LOS A CA
+MAR VISTA
+CA
+NACN
+NEW YORK
+NY
+SANTA MONI CA
+NACN
+NACN
+NACN
+NACN
+NEW YORK
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/28 6: 0517₽
+02/28
+6: 0711P
+02/28
+6: 0824P
+02/28
+6:1446₽
+INCOMING
+02/28
+6: 3117₽
+02/28
+6: 3653P
+02/28
+6: 3917₽
+02/28
+6: 4342₽
+02/28
+6: 4824P
+02/28
+6: 5149₽
+INCOMING
+INCOMING
+02/28
+7: 0339₽
+02/28
+7: 0822P
+02/28
+7: 1052P
+INCOMING
+02/28
+7:1516P
+02/28
+7:1659P
+02/28
+7: 1820P
+02/28
+7:1934P
+02/28
+7:2339P
+INCOMING
+INCOMING
+02/28
+7:2634P
+02/28
+7:3426P
+02/28
+7: 3612P
+INCOMING
+02/28
+7: 3959₽
+02/28
+7: 4128₽
+02/28
+7:4249P
+INCOMING
+02/28
+7: 5332P
+02/28
+7: 5516P
+02/28
+7: 5624P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/28
+7: 5643P
+02/28
+7: 5710P
+02/28
+7: 5937₽
+02/28
+8: 0346P
+02/28 8:0404P
+DUR
+1
+0
+0
+2
+0
+2
+2
+1
+H N
+1
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+• 0 o
+• 00
+• 00 O
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+27
+25
+25
+27
+25
+25
+27
+25
+25
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+Page 83
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+PALMDALE
+PALMDALE
+CA
+CA
+NACN
+PALMDALE
+CA
+NEW YORK
+NY
+PALMDALE
+CA
+BROOKLYN
+NY
+WEST LOS A CA
+LOS ANGELE CA
+NACN
+NACN
+WEST LOS A CA
+NACN
+PALMDALE
+CA
+NACN
+NACN
+MOBILE
+NEW YORK
+PALMDALE
+PALMDALE
+PALMDALE
+NY
+CA
+CA
+CA
+NACN
+PALMDALE
+PALMDALE
+CA
+CA
+NACN
+PALMDALE
+BROOKLYN
+PALMDALE
+PALMDALE
+PALMDALE
+PALMDALE
+PALMDALE
+CA
+NY
+CA
+CA
+CA
+CA
+CA
+ANS NEW YORK
+CALLED PHONE CDATE CTIME
+02/28 8:2123P
+02/28 8:2306P
+INCOMING
+02/28
+8: 2906P
+02/28
+8: 4128₽
+INCOMING
+02/28
+8:4348P
+02/28
+8:4725P
+02/28
+8: 5047₽
+02/28
+8: 5422₽
+02/28
+9:0028P
+INCOMING
+INCOMING
+02/28
+9: 0616₽
+02/28
+9:0716P
+02/28
+9: 1231₽
+INCOMING
+02/28
+9:2213P
+02/28
+9: 30041
+P
+INCOMING
+INCOMING
+02/28
+9: 3548P
+02/28
+9: 4034P
+02/28
+9:4553P
+INCOMING
+02/28
+9:4631P
+02/28 10:0326P
+02/28 10:0710P
+02/28 10:1410P
+INCOMING
+02/28 10:2335P
+02/28 10:2522P
+02/28 10:3314P
+INCOMING
+02/28 10:3746P
+02/28 10:3851P
+02/28 10:4809P
+02/28 10:5221P
+02/28 10:5538P
+02/28 10:5603P
+02/28 10:5830P
+02/28 11: 0238P
+DUR
+0
+1
+1
+1
+4
+H N
+0
+1
+1
+0
+1
+0
+0
+4
+0
+2
+0
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+25
+25
+27
+0
+25
+27
+25
+0
+27
+0
+27
+27
+0
+0
+27
+27
+27
+27
+0
+2
+5
+• O
+0
+• 0
+0
+0
+0
+0
+0
+0
+0
+27
+2
+5
+25
+27
+25
+25
+27
+25
+27
+25
+25
+25
+25
+25
+Page 84
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NACN
+NACN
+PALMDALE
+NACN
+PALMDALE
+PALMDALE
+PALMDALE
+PALMDALE
+PALMDALE
+PALMDALE
+PALMDALE
+PALMDALE
+PALMDALE
+PALMDALE
+QUEENS
+LOS ANGELE
+QUEENS
+LOS ANGELE
+NACN
+BROOKLYN
+NEW YORK
+QUEENS
+DIR. ASST.
+SANTA MONI
+GARDENA
+NACN
+NACN
+BROOKLYN |
+WEST LOS A
+BROOKLYN
+BROOKLYN
+BROOKLYN
+CA
+CA
+CA
+CA
+CA
+CA
+CA
+CA
+CA
+CA
+CA
+NY
+CA
+NY
+CA
+NY
+NY
+NY
+CA
+CA
+NY
+CA
+NY
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/28 11:0726P
+02/28 11:1323P
+02/28 11:2750P
+02/28 11:5055P
+02/29 12: 0607A
+02/29 12:0611A
+02/29 12:2102A
+02/29 12:3536A
+02/29 12:3921A
+02/29
+1: 2225A
+02/29
+1: 3635A
+02/29
+2: 0612A
+02/29
+2: 1207A
+02/29
+2:4941A
+02/29
+8: 0828A
+02/29
+8:1432A
+02/29
+8: 3607A
+02/29
+8: 3619A
+02/29
+8: 4606A
+02/29
+8: 5008A
+02/29
+8: 5020A
+02/29
+8: 5207A
+02/29
+8: 5225A
+02/29
+8: 5226A
+02/29
+8: 5537A
+02/29
+8: 5643A
+02/29
+9: 1408A
+02/29
+9:2540A
+02/29
+9: 3400A
+02/29
+9: 3520A
+02/29
+9: 4425A
+02/29
+9: 5201A
+DUR
+1
+1
+0
+NAHANAAMO
+3
+2
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+27
+27
+25
+27
+25
+25
+25
+25
+25
+25
+25
+25
+25
+5
+0
+• o
+0
+0
+0
+• • •
+• 000
+• o
+0
+0
+0
+0
+0
+0
+0
+0
+21
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+Page 85
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+DIR. ASST.
+BEVERLY HI
+BROOKLYN
+BROOKLYN
+BROOKLYN
+BROOKLYN
+BROOKLYN
+ELMSFORD
+BROOKLYN
+BROOKLYN
+NEW YORK
+NEW YORK
+NACN
+GARDENA
+NEW YORK
+NACN
+BROOKLYN
+NACN
+NEW YORK
+NEW YORK
+GLENWDSPGS
+ASPEN
+PALMDALE
+ELMSFORD
+PALMDALE
+ELMSFORD
+PALMDALE
+NEW YORK
+NEW YORK
+MOBILE
+NEW YORK
+NEW YORK
+CA
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+CA
+NY
+NY
+NY
+NY
+CO
+CO
+CA
+NY
+CA
+NY
+CA
+NY
+NY
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+02/29 9:5438A
+02/29 9:5439A
+02/29 10:0153A
+02/29 10:0909A
+02/29 10:1354A
+02/29 10:2423A
+02/29 10:2632A
+02/29 10:2906A
+02/29 10:3017A
+02/29 10:3144A
+02/29 10: 3226A
+02/29 10:5649A
+02/29 10:5733A
+02/29 10:3
+5816A
+02/29 10:5923A
+02/29 11:0058A
+02/29 11:0203A
+02/29 11:0632A
+02/29 11:1155A
+02/29 11:2736A
+02/29 11: 3345A
+02/29 11: 3445A
+02/29 11:4457A
+02/29 11:4824A
+02/29 11: 5536A
+02/29 12:0854P
+02/29 12:1301P
+02/29
+1:2358P
+02/29
+1: 2808P
+02/29
+1: 2857P
+02/29
+1: 3124P
+02/29
+1: 3335P
+DUR
+2
+1
+1
+1
+1
+1
+3
+N AN
++ m
+HAAN
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+• 0
+0
+0
+0
+0
+0
+0
+0
+0
+00
+0
+0
+0
+0
+0
+0
+0
+0
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+27
+7
+27
+27
+25
+27
+25
+27
+25
+27
+27
+27
+27
+27
+Page 86
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+QUEENS
+QUEENS
+BROOKLYN
+PALMDALE
+MORIARTY
+PALMDALE
+PALMDALE
+NY
+NY
+NY
+CA
+NM
+CA
+CA
+NEW YORK C NY
+NACN
+INCOMING
+ALBUQURQUE
+SANTA FE
+NM
+NM
+INCOMING
+SANTA FE
+NM
+INCOMING
+INCOMING
+INCOMING
+SANTA FE
+SANTA FE
+SANTA FE
+NEW YORK
+NM
+NM
+NM
+NY
+INCOMING
+INCOMING
+QUEENS
+SANTA FE
+SANTA FE
+NEW YORK
+MORIARTY
+NY
+NM
+NM
+NY
+NM
+NACN
+NEW YORK
+NY
+NEW YORK
+NY
+ALBUQURQUE
+NM
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+02/29 1:3429P
+02/29
+1:4859P
+02/29
+1: 5229P
+02/29
+1:5629P
+02/29
+1: 5633P
+02/29
+1: 5955₽
+02/29
+2: 0525₽
+INCOMING
+INCOMING
+INCOMING
+02/29
+4: 3120P
+02/29
+4: 5704P
+02/29
+5: 3426₽
+02/29
+6: 5551₽
+02/29
+7:3450₽
+INCOMING
+02/29
+8: 4809P
+02/29 10:4832P
+INCOMING
+INCOMING
+INCOMING
+03/01 10:0403A
+03/01 10:0748A
+03/01 10:2155A
+03/01 12:0427P
+03/01 12:0812P
+03/01 12:2216P
+INCOMING
+INCOMING
+INCOMING
+03/01 12: 3326P
+03/01 12:4600₽
+03/01
+1:0250P
+03/01
+1: 5904P
+03/01
+2: 4528₽
+03/01
+3: 0218₽
+03/01
+3: 1407₽
+03/01
+3: 1925₽
+INCOMING
+03/01
+4: 0116P
+03/01
+4: 0604P
+03/01
+4: 3154P
+03/01
+5: 5959P
+DUR
+1
+1
+1
+0
+2
+0
+0
+2
+4
+2
+0
+N O
+2
+3
+0
+1
+9
+6
+1
+0
+H H
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+27
+27
+27
+25
+27
+25
+25
+4128
+4128
+1499
+25
+25
+1499
+25
+1499
+1499
+1499
+25
+25
+25
+1499
+1499
+1499
+1499
+25
+25
+1499
+1499
+4128
+4128
+4128
+25
+Page 87
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+MOBILE
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+FTLAUDERDI FL
+W PALM BCH
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+W PALM BCH
+FL
+NY
+NY
+NY
+NY
+NY
+FL
+W PALM BCH FL
+SAN MONICA CA
+W PALM BCH FL
+W PALM BCH FL
+W PALM BCH FL
+W PALM BCH FL
+W PALM BCH FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+03/01 9:4057P
+03/01 9:5444P
+03/01 10:1053P
+03/01 11:0718P
+03/02
+8: 0848A
+INCOMING
+INCOMING
+03/02
+9:1544A
+03/02
+9: 4018A
+03/02
+9: 4201A
+03/02
+9: 4230A
+03/02
+9:4426A
+03/02
+9: 4508A
+03/02
+9: 5105A
+03/02
+9: 5224A
+03/02
+9: 5346A
+03/02
+9: 5518A
+INCOMING
+INCOMING
+INCOMING
+03/02 10:1355A
+03/02 10:2240A
+03/02 10:3754A
+03/02 10:3935A
+INCOMING
+INCOMING
+03/02 10:4302A
+03/02 10:5829A
+03/02 11:2120A
+INCOMING
+INCOMING
+INCOMING
+03/02 11: 4135A
+03/02 12:2551P
+03/02 12:4653P
+03/02 12:4725P
+03/02 12:5107P
+INCOMING
+03/02 12:5650P
+03/02
+1: 0244P
+03/02
+1: 0340P
+INCOMING
+03/02
+1: 0558P
+03/02
+1: 1351₽
+DUR
+1
+2
+1
+1
+1
+2
+2
+1
+1
+3
+HNN
+1
++ N
+1
+1
+2
+1
+2
+1
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+• 000
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2.
+2
+2
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 88
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NY
+W PALM BCH FL
+NEW YORK
+SAN MONICA CA
+NEW YORK
+NY
+NY
+DIR. ASST.
+NEW YORK
+NEW YORK
+MOBILE
+NEW YORK
+NY
+NY
+NY
+NY
+NWYRCYZN01
+CAHU
+NY
+HI
+MOBILE
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+W PALM BCH FL
+W PALM BCH FL
+W PALM BCH FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/02 1:1408P
+03/02
+1:1447P
+03/02
+1:2347P
+03/02
+1:2403P
+03/02
+1:5429P
+03/02
+2: 1150P
+03/02
+2:1341P
+03/02
+2:1639P
+03/02
+2: 1640P
+03/02
+2:1954P
+03/02
+2:2154P
+03/02
+3: 5547P
+03/02
+3: 5628P
+03/02
+4: 0200P
+03/02
+4: 0236P
+03/02
+4:2425P
+03/02
+4:3048P
+03/02
+4: 3750P
+03/02
+5: 0636P
+03/02
+5:3444P
+03/02
+5: 3553P
+03/02
+7: 0135P
+03/02
+7: 1731₽
+03/02
+7: 1855₽
+03/02
+8: 1031P
+03/02
+8: 2521P
+03/02 10:0531P
+03/03
+9: 4139A
+03/03
+9: 4301A
+03/03
+9: 4615A
+03/03
+9: 5133A
+03/03 10:1001A
+DUR
+1
+2
+1
+1
+2
+2
+0
+3
+2
+1
+MANAHANNNN
+15
+NAMM
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+5
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 89
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+W PALM BCH FL
+NEW YORK
+MOBILE
+MOBILE
+NY
+NY
+NY
+W PALM BCH FL
+MOBILE
+NY
+NEW YORK
+MOBILE
+NY
+NY
+MOBILE
+NEW YORK
+MOBILE
+NY
+NY
+NY
+MOBILE
+MOBILE
+NY
+NY
+NEW YORK
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+03/03 10:1434A
+INCOMING
+03/03 10:1651A
+INCOMING
+03/03 10: 2636A
+INCOMING
+03/03 10: 3320A
+INCOMING
+03/03 10: 3928A
+INCOMING
+03/03 11: 0923A
+INCOMING
+03/03 12:1812P
+INCOMING
+03/03 12:1853P
+03/03 12:1940P
+INCOMING
+INCOMING
+03/03 12: 3435₽
+03/03 12:4535P
+03/03 12:4843P
+03/03
+1: 5043P
+03/03
+1: 5119P
+INCOMING
+03/03
+2:1123P
+03/03
+2: 3046P
+03/03
+2: 3224P
+INCOMING
+INCOMING
+03/03
+2:4804P
+03/03
+2: 5537P
+03/03
+3: 1207P
+03/03
+3: 2306P
+INCOMING
+INCOMING
+03/03 3:2801P
+03/03
+3: 3922₽
+03/03
+3: 5352₽
+03/03
+3: 5824P
+03/03
+4: 0034P
+INCOMING
+INCOMING
+03/03
+4: 0502₽
+03/03
+4: 0630₽
+03/03
+4: 1604P
+03/03
+4: 1841₽
+INCOMING
+03/03
+4:2648P
+03/03 4:4026P
+DUR
+1
+6
+3
+1
+1
+1
+1
+1
+3
+15
+4
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+• 00
+• 0
+• 0
+• • 0 0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+5
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+H H
+Page 90
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+MOBILE
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+SAN MONICA
+NEW YORK
+NEW YORK
+QUEENS
+QUEENS
+MOBILE
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+NY
+CA
+NY
+INCOMING
+INCOMING
+NY
+NY
+NY
+INCOMING
+NY
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+NY
+INCOMING
+INCOMING
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+03/03 4:5223P
+03/03 4:5607₽
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/03
+5:0040P
+03/03 5:0946P
+03/03
+5:1617P
+03/03
+6:1942P
+03/03
+6: 5445P
+03/03
+7: 1345P
+03/03
+7:2023P
+INCOMING
+INCOMING
+INCOMING
+03/03
+7: 4311P
+03/03 7:4811₽
+03/03 8:3449P
+03/03
+8: 3525P
+INCOMING
+03/04
+8:44
+00A
+03/04 10:2522A
+03/04 11:4109A
+03/04 11:5613A
+03/04 12:0605P
+03/04 12:3342P
+03/04 12:4854P
+03/04
+2: 0340P
+03/04
+2:0430P
+03/04
+2:0620P
+03/04
+2: 0813P
+03/04
+2:1436P
+03/04
+2: 4112₽
+03/04
+2: 4844P
+03/04
+3: 2015₽
+03/04
+3: 3404₽
+03/04
+3: 3612P
+03/04
+3: 4024P
+03/04
+4: 1847P
+DUR
+1
+1
+1
+3
+2
+2
+3
+2
+9
+AIR
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+0
+0
+0
+0
+• 0
+0
+0
+• 00 O
+0
+0
+0
+0
+0
+0
+0
+0
+2
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 91
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NWYRCYZNO1 NY
+W PALM BCH FL
+W PALM BCH FL
+NEW YORK NY
+NWYRCYZN01 NY
+NWYRCYZN01 NY
+NWYRCYZN01 NY
+W PALM BCH FL
+W PALM BCH
+FL
+OAHU
+HI
+NEW YORK
+NY
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+03/04 4:2900₽
+03/04 4:3309P
+INCOMING
+03/04
+5:0540₽
+03/04
+5:0719P
+03/04
+5: 0817P
+03/04
+5: 3031P
+INCOMING
+03/04
+5:3039P
+03/04
+5:3440P
+INCOMING
+03/04
+5: 4052₽
+03/04
+5: 4302₽
+INCOMING
+03/04
+5: 4348P
+03/04
+5:4425P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/04
+5: 4551P
+03/04
+5:48
+6
+03/04
+5:5408P
+03/04
+5:5829P
+03/04
+6: 0132P
+03/04
+6: 0237P
+INCOMING
+03/04
+6:4246P
+03/04
+6: 4923P
+INCOMING
+03/04
+6:5859P
+03/04
+7:4914P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/04
+8: 3405₽
+03/04
+9: 3302P
+03/04
+9: 3812P
+03/04 10:1105P
+03/04 11:2237P
+03/04 11: 3203P
+03/04 11: 3732P
+INCOMING
+INCOMING
+INCOMING
+03/04 11:4016P
+03/04 11: 5524P
+03/04 11:5756P
+DUR
+2
+11
+1
+2
+1
+7
+2
+1
+1
+• N
+6
+6
+1
+25
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+X cingular®
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+• 00
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+D
+Page 92
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NEW YORK
+NY
+NY
+NEW YORK
+NY
+OAHU
+HI
+W PALM BCH FL
+W PALM BCH FL
+NEW YORK
+NY
+W PALM BCH FL
+NEW YORK
+NEW YORK
+NY
+NY
+MOBILE
+MOBILE
+NY
+NY
+NEW YORK
+NY
+NEW YORK
+NY
+MOBILE
+NY
+W PALM BCH FL
+MOBILE
+NY
+NEW YORK
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+03/05 12:0050A
+03/05 12:0155A
+INCOMING
+03/05 12:0717A
+03/05 12:0825A
+03/05 12:3258A
+03/05
+6: 4321A
+INCOMING
+03/05
+6: 5411A
+03/05 10:2941A
+INCOMING
+INCOMING
+03/05 10:4051A
+03/05 11: 4132A
+03/05 11:4713A
+INCOMING
+03/05 11: 5302A
+03/05 11:5748A
+INCOMING
+INCOMING
+03/05 12:2643P
+03/05 12:4612P
+03/05 12:4847P
+03/05 12:4911P
+INCOMING
+03/05 12:5440P
+03/05 12:5529P
+03/05
+12:5948P
+INCOMING
+03/05
+1:2323P
+03/05
+1: 3011P
+INCOMING
+03/05
+2: 0026P
+03/05
+2: 0358P
+INCOMING
+03/05
+2: 2240P
+03/05
+2:2612P
+INCOMING
+INCOMING
+03/05
+2: 3041P
+03/05
+4: 1752₽
+03/05
+4: 1902₽
+03/05
+4: 2016P
+03/05
+4: 2250₽
+INCOMING
+03/05 4:2950P
+DUR
+1
+6
+1
+25
+1
+1
+50
+12
+1
+1
+0 0 0 =
+1
+5
+1
+2
+5
+3
+1
+NAN
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+X cingular®
+AIR
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+5
+0
+0
+0
+0
+0
+0
+• 0
+• 0
+0
+• o
+0
+0
+0
+0
+0
+0
+2
+2
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 93
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NY
+W PALM BCH FL
+UN. KINGDO
+NEW YORK
+NY
+NEW YORK
+NY
+NWYRCYZNO1 NY
+UN. KINGDO
+W PALM BCH
+FL
+MOBILE
+NY
+W PALM BCH FL
+INCOMING
+NEW YORK
+DIR. ASST.
+DIR. ASST.
+NY
+INCOMING
+NEW YORK
+NY
+INCOMING
+INCOMING
+NEW YORK
+NY
+INCOMING
+W PALM BCH FL
+INCOMING
+INCOMING
+NEWYORKZN2 NY
+INCOMING
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+03/05 4:3149P
+03/05 4:3208P
+INCOMING
+03/05 4:4244P
+03/05 4: 4629P
+03/05 4:5009₽
+INCOMING
+INCOMING
+INCOMING
+03/05 5:0058P
+03/05 5:1450₽
+03/05 8:2711P
+03/05 8:2815P
+INCOMING
+03/05 9:4330₽
+03/05 11:1346P
+03/05 11: 3844P
+INCOMING
+03/06 10:2910A
+03/06 10:3137A
+03/06 10:3417A
+03/06 10:3634A
+03/06 11:4435A
+03/06 2:4815P
+03/06 10:2650P
+03/06 10:2833P
+03/06 11:5914P
+03/07 10:1236A
+03/07 10:1400A
+03/07 11:4454A
+03/07 12:0026P
+03/07 12:0358P
+03/07 12:1639P
+03/07 12:1709P
+03/07 12:1927P
+03/07 12:2515P
+03/07 12:2617P
+03/07 12:2743P
+DUR
+1
+3
+2
+2
++ m
+3
+3
+2
+11
+1
+3
+3
+2
+2
+5
+1
+2
+1
+2
+2
+2
+4
+13
++ m
+H A N A
+AIR
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+25
+25
+25
+25
+1.05
+0
+1.05
+0
+25
+25
+25
+25
+25
+0
+0
+25
+25
+25
+1
+05
+0
+1.05
+25
+2
+5
+25
+0
+0
+0
+25
+2
+25
+2
+5
+0
+5
+0
+25
+25
+0
+0
+0
+25
+25
+25
+0
+0
+0
+25
+25
+25
+0
+0
+25
+25
+25
+25
+Page 94
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+LEXINGTON MA
+W PALM BCH FL
+LEXINGTON MA
+SAN MONICA CA
+UN. KINGDO
+NEW YORK
+NEW YORK
+MOBILE
+NEWYORKZN2 NY
+MOBILE
+NY
+NY
+NY
+NY
+NEWYORKZN2 NY
+NEW YORK
+MOBILE
+NY
+NY
+MOBILE
+NEW YORK
+MOBILE
+NEW YORK
+NY
+NY
+NY
+NY
+NEW YORK
+LEXINGTON
+NEW YORK
+NEW YORK
+NY
+MA
+NY
+NY
+NEWYORKZN2 NY
+NEW YORK
+NY
+ANS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+03/07 12:3011P
+03/07 12:3122P
+03/07 12:3309P
+03/07 12:3516P
+03/07 12:3756P
+INCOMING
+03/07 12:4121P
+03/07 1:2603P
+03/07
+1: 3042P
+03/07
+1: 3145P
+03/07
+2: 5952P
+03/07
+4: 4858P
+03/07
+4:5010P
+INCOMING
+03/07
+4: 5225P
+03/07
+4:
+2
+:43
+INCOMING
+03/07
+4: 5503P
+03/07
+4: 5521P
+03/07
+4: 5611P
+INCOMING
+INCOMING
+03/07
+8: 3441P
+03/07
+8: 3531P
+03/07
+8: 3705P
+03/07
+8: 3927P
+03/07
+8: 4003₽
+03/07
+8: 4025P
+INCOMING
+03/07
+8: 4106₽
+03/07
+8: 4358P
+03/07
+8: 5534₽
+03/07
+8: 5653₽
+03/07
+8: 5846P
+INCOMING
+03/07 10:0040₽
+03/07 10:0107P
+03/07 10:0201P
+INCOMING
+03/07 11:2742P
+DUR
+1
+2
+2
+3
+2
+1
+1
+1
+1
+1
+1
+INMANN
+2
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+. 9
+0
+• o O
+• o
+° o
+0
+0
+0
+0
+0
+. 9
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 95
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+UN. KINGDO
+UN. KINGDO
+LEXINGTON
+WOBURN
+MOBILE
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+DIR. ASST.
+NEW YORK
+MOBILE
+NEW YORK
+NEW YORK
+MOBILE
+MA
+MA
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+03/08 8:1815A
+03/08 8:1935A
+INCOMING
+03/08 8:3933A
+03/08 8:4237A
+03/08
+8: 4353A
+INCOMING
+03/08
+8:5311A
+03/08
+8: 5700A
+03/08
+8: 5834A
+03/08
+9: 0142A
+INCOMING
+03/08
+9: 0235A
+03/08
+9: 0512A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/08
+9: 3724A
+03/08
+9: 5033A
+03/08
+9: 5938A
+03/08
+10:2155A
+03/08
+10:5424A
+03/08
+11:0358A
+03/08
+11:0422A
+03/08
+11:5445A
+03/08
+12:5146P
+03/08
+1:0320P
+03/08
+1:1640₽
+03/08
+1:5733₽
+03/08
+1: 5856P
+03/08
+1:5857P
+INCOMING
+03/08
+2: 0155P
+03/08
+2:1333P
+03/08
+2:1601P
+03/08
+2:1731P
+03/08
+2:1803P
+INCOMING
+INCOMING
+03/08
+2: 3134P
+03/08
+3:2921P
+DUR
+2
+1
+2
+2
+3
+1
+3
+2
+3
+1
+2
+2
+1
+2
+HMM
+M HN
+10
+1
+0
+2
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+9
+0
+0
+• C
+0
+0
+9
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 96
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NY
+NEW YORK
+NY
+NEW YORK
+MOBILE
+MOBILE
+NY
+NY
+NY
+NEW YORK
+NY
+W PALM BCH FL
+NEW YORK
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+03/08 3:3758P
+03/08
+3: 5306P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/08 4:2141P
+03/08
+5:1434P
+03/08
+5:2442P
+03/08
+5: 2602P
+03/08
+5:4341P
+03/08
+5: 4430P
+INCOMING
+INCOMING
+03/08
+6:2414P
+03/08
+6:2534P
+03/08
+6: 2625P
+03/08
+6:2704P
+03/08
+6: 2819P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/08
+7: 1130P
+03/08
+7:1948P
+03/08
+7:5443P
+03/09
+8:5747A
+03/09 10:5953A
+03/09 11:2243A
+03/09 11: 5809A
+03/09 12:1236P
+03/09 12:2307₽
+03/09
+1:4800₽
+03/09
+1: 4855P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/09
+1: 5039P
+03/09
+2: 3643₽
+03/09
+3: 0533P
+03/09
+3: 1700₽
+03/09
+3: 3019P
+03/09
+3: 3205P
+INCOMING
+03/09
+3: 3244P
+03/09
+3: 3503P
+DUR
+1
+1
+2
+1
+2
+1
+1
+1
+1
+1
+1
+11
+IN H
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+X cingular®
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2.
+2
+2
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 97
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+QUEENS
+NY
+QUEENS
+NY
+MOBILE
+NY
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+MOBILE
+NY
+NEWPORTBCH CA
+NEW YORK
+NY
+NEW YORK
+NEW YORK
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+03/09 3:4646P
+03/09 4:2219P
+INCOMING
+03/09 4:2903P
+03/09 4:2939P
+INCOMING
+03/09 4:3652P
+03/09 4:3749P
+INCOMING
+03/09
+5:1544P
+03/09
+5:1658P
+03/09 5:1734P
+03/09 5:2651₽
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/09 5:2901P
+03/09 5:5240P
+03/09 6:3146P
+03/09
+6: 5110P
+03/09
+6: 5327P
+03/09
+7:3908P
+INCOMING
+03/09
+8:1655P
+03/09
+8:2717P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/09
+8: 4626P
+03/09
+8:5504P
+03/09
+9:1742P
+03/09
+9:5001P
+03/10
+9: 0123A
+03/10
+9: 2206A
+03/10
+9: 2817A
+03/10
+9:2844A
+03/10
+9: 3132A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/10 10:0048A
+03/10 10:1901A
+03/10 10:2519A
+03/10 10:2755A
+03/10 10:3644A
+DUR
+1
+1
+1
+1
+1
+1
+2
+2
+1
+1
+2
+3
+6
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+X cingular®
+AIR
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+5
+Il
+0
+0
+0
+0
+• 0
+• 0
+• o
+0
+0
+0
+0
+0
+0
+0
+0
+2
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 98
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+W PALM BCH FL
+NEW YORK
+NY
+MOBILE
+NY
+NEW YORK
+NEW YORK
+NY
+NY
+NEW
+YORK
+NEW YORK
+NY
+NY
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+MOBILE
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+03/10 12:1509P
+INCOMING
+03/10 12:2253P
+INCOMING
+03/10 12:5423P
+INCOMING
+03/10
+1:0817P
+INCOMING
+03/10
+1:2850P
+INCOMING
+03/10
+1: 5949P
+03/10
+2: 1843₽
+03/10
+2: 3551P
+03/10
+2: 3636P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/10
+4: 5145P
+03/10
+5:0737P
+03/10
+5: 3914P
+03/10
+6: 2933P
+03/10
+6:4
+1
+0
+IP
+03/10
+6: 4936P
+INCOMING
+03/10
+6: 5126P
+03/10
+7:0417P
+03/10
+7: 0513P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/10
+8:2425P
+03/10
+9:2625P
+03/10
+9:4008P
+03/10 11:0214P
+03/10 11:0338P
+03/10 11:0443P
+03/10 11:0512P
+INCOMING
+03/11
+8: 5328A
+03/11
+9: 0108A
+03/11
+9: 1128A
+03/11
+9:1719A
+03/11
+9: 2029A
+INCOMING
+03/11
+9:2518A
+03/11
+9:2623A
+DUR
+2
+1
+1
+1
+2
+1
+1
+1
+1
+2
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+0
+0
+0
+0 0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+U H
+Page 99
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NEW YORK
+NY
+NY
+NEW YORK
+QUEENS
+MOBILE
+NY
+NY
+NY
+MOBILE
+NEW YORK
+NY
+NY
+WILLOUGHBY OH
+MOBILE
+NY
+MOBILE
+NY
+MOBILE
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+W PALM BCH FL
+W PALM BCH FL
+NEW YORK
+NEW YORK
+NEW YORK
+MORIARTY
+WILLOUGHBY
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NM
+NY
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+03/11 9:2718A
+03/11
+9: 2951A
+INCOMING
+03/11
+9: 3645A
+03/11
+9: 3857A
+03/11
+9:4729A
+03/11
+9: 5147A
+INCOMING
+03/11
+9: 5442A
+03/11
+9:5727A
+03/11
+9: 5806A
+INCOMING
+03/11
+9: 5959A
+03/11 10:1834A
+03/11 10:1939A
+INCOMING
+03/11 10:2142A
+03/11 10:3159A
+INCOMING
+03/11 10:5010A
+03/11 11:1839A
+03/11 11:2030A
+03/11 11:2815A
+03/11 11:2914A
+03/11 11:3005A
+INCOMING
+03/11 11: 3457A
+03/11 11:4058A
+03/11 11:4149A
+INCOMING
+03/11 11:4304A
+03/11 12:2356P
+03/11 12:2543P
+03/11 12:2635P
+03/11 12:2926P
+03/11 12:4139P
+03/11 12:5200P
+03/11 12:5301P
+03/11 12:5553P
+DUR
+3
+1
+3
+3
+4
+2
+1
+1
+2
+1
+1
+HNN
+1
+2
+N H
+2
+H H
++ NH
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+• •
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+• 00
+0 0 C
+00 O
+• 00 O
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2
+5
+2
+5
+2
+25
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+• H
+H HH H
+Page100
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NY
+NEW YORK
+NY
+NEW YORK
+NY
+W PALM BCH FL
+MOBILE
+MOBILE
+MOBILE
+MOBILE
+NEW YORK
+NEW YORK
+OAHU
+NEW YORK
+NEW YORK
+W PALM BCH
+NY
+NY
+NY
+NY
+NY
+NY
+HI
+NY
+NY
+FL
+NACN
+W PALM BCH FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+03/11
+1: 2142P
+INCOMING
+03/11
+1:4600P
+INCOMING
+03/11
+2:0252P
+03/11
+2: 4622P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/11
+3: 3510₽
+03/11
+3: 5633P
+03/11
+4: 1029P
+03/11
+4:4320P
+03/11
+5: 0453P
+03/11
+5: 0658P
+03/11 5:1731₽
+03/11
+5: 3613P
+03/11
+5: 5142P
+03/11
+6:5546P
+INCOMING
+03/11
+7:0158P
+03/11
+7: 0412P
+INCOMING
+INCOMING
+INCOMING
+03/11
+7:1326P
+03/11
+7:1626P
+03/11
+8: 0844P
+03/11
+8: 3455P
+03/11
+8: 3536P
+03/11
+8: 3707P
+03/11
+8: 3804P
+03/11
+8: 4042P
+INCOMING
+INCOMING
+03/11 11:2036P
+03/11 11:4008P
+03/12 12:2841A
+INCOMING
+INCOMING
+03/12 9: 3807A
+03/12 10:0511A
+03/12 10:4504A
+INCOMING
+03/12 10:4612A
+03/12 11:1851A
+DUR
+2
+1
+1
+1
+1
+1
+3
+1
+2
+1
+NAMAHAANN
+N N
+29
+• NO
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+X
+cingular®
+AIR
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2
+0
+0
+• 0O
+• 0 0 0 00.
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+2
+25
+25
+25
+25
+37
+37
+37
+37
+37
+25
+37
+25
+Page101
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+WEST PALM FL
+W PALM BCH FL
+NEW YORK
+NY
+NACN
+NEW YORK
+NEW YORK
+NEW YORK
+W PALM BCH
+NY
+NY
+NY
+FL
+NACN
+NEW YORK
+NEW YORK
+NEW
+YORK
+NEW YORK
+NEW YORK
+W PALM BCH
+NY
+NY
+NY
+NY
+NY
+FL
+NACN
+NEW YORK
+NEW YORK
+WEST PALM
+BROOKLYN
+NY
+NY
+FL
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+WILLOUGHBY OH
+NACN
+NEW YORK
+NEW YORK
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+03/12 11:2001A
+03/12 11:2101A
+INCOMING
+03/12 11:2213A
+03/12 11:3304A
+INCOMING
+03/12 11:3416A
+03/12 11:3747A
+03/12 12:0103P
+INCOMING
+INCOMING
+03/12 12:0111P
+03/12 12:0215P
+03/12 12:0346P
+INCOMING
+03/12 12:0517P
+03/12 12:0724P
+03/12 12:4204P
+INCOMING
+03/12 12:4314P
+03/12 12:4420P
+03/12 12:4727P
+03/12 12:5041P
+03/12 12:5219P
+03/12 12:5259P
+03/12 12:5311P
+INCOMING
+INCOMING
+03/12 12:5418P
+03/12 12:5725P
+03/12
+1: 0134P
+03/12 1:0256P
+03/12 1:0400P
+03/12
+1:0448₽
+INCOMING
+03/12
+1:0456P
+03/12
+1:1007P
+03/12
+1: 1026P
+INCOMING
+03/12
+1:1111P
+03/12
+1:1337₽
+INCOMING
+03/12 1:1801P
+DUR
+1
+0
+3
+2
+2
+3
+1
+2
+2
+2
+OH N
+2
+1
+н O
+3
+2
+2
+1
+1
+4
+0
+2
+NI M
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+37
+25
+37
+25
+37
+37
+25
+37
+37
+37
+37
+37
+25
+37
+37
+37
+37
+37
+37
+37
+37
+37
+37
+25
+37
+25
+37
+37
+37
+37
+Page102
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+W PALM BCH FL
+NACN
+BROOKLYN
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+W PALM BCH FL
+NACN
+MOBILE
+MOBILE
+NEW YORK
+NY
+W PALM BCH FL
+WEST PALM
+FL
+NACN
+WEST
+PALM
+NEW YORK
+FL
+NY
+DIR. ASST.
+WEST PALM
+QUEENS
+WEST PALM
+W PALM BCH
+FL
+NY
+FL
+FL
+NACN
+W PALM BCH FL
+NACN
+DIR. ASST.
+WEST PALM
+FL
+W PALM BCH FL
+NACN
+NEW YORK
+NEW YORK
+NY
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/12 1:2243P
+03/12 1:2402P
+03/12
+1: 4025P
+03/12
+1:4531P
+03/12
+1:4853P
+03/12
+2: 1215P
+03/12
+2: 1322P
+03/12
+2: 3025P
+03/12
+2: 3740P
+03/12
+3: 3348P
+03/12
+3: 3820₽
+03/12
+3: 3838P
+03/12
+3: 3934P
+03/12
+3:41
+081
+P
+03/12
+3:4141P
+03/12
+3: 4503P
+03/12
+3:4504P
+03/12
+3: 4700₽
+03/12
+3: 4712P
+03/12
+3: 4803P
+03/12 |
+3:4909P
+03/12
+3: 4954₽
+03/12
+3: 5058₽
+03/12
+3: 5312₽
+03/12
+3: 5313P
+03/12
+3: 5951P
+03/12
+4: 0101P
+03/12
+4: 0236P
+03/12
+4:0458P
+03/12
+4: 2047₽
+03/12 4:2157P
+03/12 4:2219P
+DUR
+1
+0
+1
+1
+2
+2
+0
+HN A N
+HN C
+0
+2
+2
+0
+5
+0
+2
+2
+3
+N O
+0
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0 0 0
+0 0 0
+• • •
+000
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+37
+37
+37
+37
+25
+37
+37
+37
+37
+25
+37
+37
+37
+37
+37
+37
+37
+2
+37
+25
+37
+37
+37
+25
+37
+37
+37
+25
+37
+25
+Page103
+
+
+
+06:05:15
+Account:
+MOBILE
+ESN
+* cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NACN
+NEW YORK
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+WILLOUGHBY OH
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+WEST PALM
+NY
+FL
+W PALM BCH FL
+NACN
+CHARLI AML VI
+BROOKLYN
+NY
+W PALM BCH FL
+NEW YORK NY
+NACN
+NEW YORK
+WEST PALM
+NY
+FL
+WILLOUGHBY OH
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+03/12 4:2334P
+03/12 4:2610₽
+03/12 4:4345₽
+INCOMING
+03/12
+4: 4457P
+03/12
+4: 5421₽
+INCOMING
+03/12
+4: 5433P
+03/12
+5: 0357₽
+INCOMING
+03/12
+5:0407₽
+03/12
+5:1519P
+INCOMING
+03/12
+5:1634P
+03/12
+5: 5652₽
+INCOMING
+03/12
+5: 5802₽
+03/12
+5: 5828P
+03/12
+6: 01311
+INCOMING
+INCOMING
+03/12
+6: 0145P
+03/12
+6: 4112P
+03/12
+6:4150P
+INCOMING
+03/12
+6: 4257P
+03/12
+6: 4531P
+INCOMING
+03/12
+6:4643P
+03/12
+6: 5928₽
+03/12
+7: 4055P
+03/12
+7:4700P
+INCOMING
+03/12
+7:4807₽
+03/12
+7: 5648P
+03/12
+7:5947P
+03/12
+8: 0606P
+03/12
+8: 0634P
+INCOMING
+INCOMING
+03/12
+8: 0721₽
+03/12
+8: 3722P
+03/12 10:0118P
+03/12 10:0206P
+DUR
+3
+2
+0
+2
+3
+0
+2
+1
+2
+3
+0
+• A HAN
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+LAND TOTAL RSYS
+0
+0
+• 0O
+0
+0
+0
+37
+37
+25
+37
+25
+37
+25
+37
+25
+37
+25
+37
+37
+2.
+5
+37
+37
+0
+0
+0
+0
+0
+0
+0
+0
+0
+000000%
+0
+0
+0
+2
+37
+37
+37
+25
+37
+37
+37
+25
+37
+37
+37
+37
+37
+Page104
+
+
+
+06:05:15
+Account :
+MOBILE
+ESN
+Xcingular®
+AWS NEW YORK
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+CALLED LOC
+NEW YORK
+NY
+NEW YORK
+NY
+NEW YORK
+NY
+W PALM BCH FI
+NACN
+CALLED PHONE CDATE CTIME
+03/12 10:1644P
+03/12 10:1742P
+03/12 10:1815P
+03/12 10:1915P
+INCOMING
+03/12 10:2023P
+DUR
+1
+0
+AIR
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+37
+37
+37
+25
+37
+LAM
+Not
+for
+use
+or
+PROPRIETARY AND CONFIDENTIAL
+disclosure outside Cingular Wireless
+Page105
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+BROOKLYN NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NEW YORK
+W PALM BCH
+NY
+NY
+FL
+NACN
+NEW YORK
+NEW YORK
+NEW YORK C NY
+SANTURCE
+BROOKLYN
+NEW YORK
+BROOKLYN
+SANTURCE
+NY
+NY
+PR
+NY
+NY
+NY
+PR
+NEW YORK C NY
+NACN
+NEW YORK C NY
+NACN
+SANTURCE
+PR
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+03/13 2:3312A
+03/13
+3: 1028A
+INCOMING
+03/13
+3: 1042A
+03/13
+3: 2552A
+INCOMING
+03/13
+3: 2603A
+03/13
+3: 2906A
+INCOMING
+03/13
+3: 2914A
+03/13
+3: 3704A
+INCOMING
+03/13
+3: 3713A
+03/13
+3: 4649A
+INCOMING
+03/13
+3: 4701A
+03/13
+4: 1726A
+INCOMING
+03/13
+4: 1739A
+03/13 10:2910A
+INCOMING
+03/13 10:3020A
+03/13 10:5620A
+03/13 11:2030A
+03/13 11:2358A
+INCOMING
+INCOMING
+03/13 11:2505A
+03/13 11: 3757A
+03/13 11: 3843A
+INCOMING
+03/13 3:0544P
+03/13 4:0434P
+03/13
+4: 1048P
+03/13
+4: 1119P
+03/13
+4: 1227P
+03/13
+4: 4214P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/13
+4: 4445P
+03/13
+5: 0435₽
+03/13
+5: 0943P
+03/13
+5: 4216P
+03/13
+5:4243P
+DUR
+2
+0
+3
+9
+0
+2
+2
+1
+5
+1
+2
+1
+1
+1
+1
+2
+5
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+• 69
+• 69
+.69
+. 69
+0
+1.38
+3.45
+- 69
+2.76
+LAND TOTAL RSYS
+0
+0
+0
+1.2
+NN°
+0
+0
+0
+0
+0
+0
+0
+0
+• 69
+1.2
+.89
+.89
+.89
+.8
+1.38
+3.45
+• 69
+2.76
+.2
+37
+25
+37
+25
+37
+25
+37
+25
+37
+25
+37
+25
+37
+2
+5
+37
+37
+37
+25
+37
+37
+37
+40683
+25
+40683
+40683
+40683
+25
+40683
+40683
+40683
+40683
+25
+Page106
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+SANTURCE
+PR
+NEW YORK C NY
+NACN
+NACN
+SANTURCE
+PR
+NEW YORK C NY
+NACN
+SANTURCE
+SANTURCE
+PR
+PR
+NACN
+NACN
+BROOKLYN
+SANTURCE
+SANTURCE
+NY
+PR
+PR
+NACN
+SANTURCE
+PR
+NACN
+NACN
+NEW YORK C NY
+NEW YORK C NY
+SANTURCE
+PR
+SANTURCE
+PR
+NACN
+NACN
+NEW YORK C NY
+BROOKLYN
+NY
+SANTURCE
+PR
+SANTURCE
+PR
+NACN
+BROOKLYN
+NY
+NACN
+AWS NEW YORK
+INCOMING
+NEW YORK C NY INCOMING
+CALLED PHONE CDATE CTIME
+03/13 5:5723P
+INCOMING
+INCOMING
+INCOMING
+03/13
+6: 3436P
+03/13
+6: 4344₽
+03/13
+6: 5825P
+03/13
+8: 3201P
+INCOMING
+INCOMING
+03/13
+8: 4639P
+03/13
+9: 3202₽
+03/13
+9:5936P
+03/13 10:3730P
+INCOMING
+INCOMING
+03/13 11: 0035P
+03/13 11:3735P
+03/13 11:5836P
+03/14 10:5603A
+03/14 11:5417A
+INCOMING
+03/14 11:5608A
+03/14 12:0919P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/14 12:5514P
+03/14
+1:1023P
+03/14
+2: 3416P
+03/14
+4: 3214P
+03/14
+5:5358P
+03/14
+5: 5524P
+INCOMING
+INCOMING
+INCOMING
+03/14
+6: 5403P
+03/14
+6: 5524P
+03/14
+8: 5700₽
+03/14
+9: 0458P
+03/14
+10: 3207P
+03/14 10:5027P
+INCOMING
+03/14 11: 3216P
+03/14 11:4919P
+03/14 11: 5032P
+03/15 12:2612A
+DUR
+1
+1
+0
+2
+1
+0
+0
+16
+4
+2
+0
+1
+1
+1
+0
+0
+2
+1
+3
+0
+0
+5
+1
+1
+1
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+LAND TOTAL RSYS
+0
+• 69
+• 69
+4.14
+1.2
+0
+.2
+1.38
+. 69
+0
+0
+3.2
+0
+. 8
+11.04 0
+2.76
+1.38
+.4
+0
+. 2
+1.38
+. 2
+. 69
+• 69
+. 69
+• 69
+0
+0
+1.38
+2.07
+.69
+2.07
+0
+0
+3.45
+- 69
+.69
+.69
+• 4
+0
+1.2
+.2
+.2
+1.2
+• 69
+• 69
+4.14
+.2
+. 4
+. 2
+.2
+. 69
+. 69
+• 6
+1.38
+2.07
+• 69
+2.67
+1.2
+3.45
+.89
+• 69
+• 69
+25
+40683
+40683
+40683
+25
+40683
+40683
+25
+25
+40683
+40683
+40683
+25
+25
+40683
+25
+40683
+40683
+40683
+40683
+25
+25
+40683
+40683
+40683
+40683
+25
+25
+40683
+40683
+40683
+40683
+Page107
+
+
+
+Account:
+MOBILE
+ESN
+X cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+SANTURCE
+SANTURCE
+SANTURCE
+PR
+PR
+PR
+NACN
+NACN
+W PALM BCH FL
+SANTURCE
+NACN
+PR
+SANTURCE
+SANTURCE
+PR
+PR
+NACN
+NACN
+NACN
+CHARLT AML
+NEW YORK C
+NEW YORK C
+BROOKLYN
+NEW YORK
+SANTURCE
+SANTURCE
+SANTURCE
+SANTURCE
+VI
+NY
+NY
+NY
+NY
+PR
+PR
+PR
+PR
+NACN
+NEW YORK C NY
+SANTURCE
+PR
+NACN
+NEW YORK C NY
+NACN
+NACN
+SANTURCE
+SANTURCE
+SANTURCE
+PR
+PR
+PR
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+03/15 8:5541A
+03/15
+9:0440A
+03/15
+9:2019A
+INCOMING
+INCOMING
+03/15
+9: 5632A
+03/15 10:0551A
+03/15 10:0828A
+03/15 10:1014A
+INCOMING
+03/15 10:2115A
+03/15 10:3644A
+03/15 10:3805A
+INCOMING
+INCOMING
+INCOMING
+03/15 11:1120A
+03/15 11:3742A
+03/15 11: 3901A
+03/15 11:4834A
+INCOMING
+INCOMING
+03/15
+1:0340P
+03/15
+1:2558P
+03/15
+1:2639P
+03/15
+1: 3354P
+03/15
+2:2438P
+03/15
+2:5548P
+03/15
+3: 1830₽
+03/15
+3: 2041₽
+INCOMING
+INCOMING
+03/15
+3: 2533₽
+03/15
+3: 2707₽
+03/15
+3: 4900₽
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/15
+3:5644P
+03/15
+4: 0217₽
+03/15
+4: 1924P
+03/15
+4: 2133₽
+03/15
+4: 3337₽
+03/15
+4: 4226P
+03/15 4:4603P
+DUR
+0
+0
+1
+3
+2
+0
+1
+0
+0
+3
+2
+1
+2
+1
+1
+2
+0
+0
+0
+2
+3
+0
+2
+2
+1
+2
+0
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+• 69
+2.07
+1.38
+0
+. 69
+0
+0
+2.07
+1.38
+• 69
+1.38
+1.38
+. 69
+. 69
+1.38
+0
+0
+0
+0
+1.38
+2.07
+1.38
+1.38
+.69
+1.38
+LAND TOTAL RSYS
+. 2
+• 6
+.2
+0
+0
+0
+•4
+.2
+1.6
+•2
+• 6
+•2
+• 69
+2.07
+1.78
+• 6
+• 69
+•4
+.2
+2.07
+1.38
+• 69
+1.78
+1.38
+. 69
+. 89
+1.78
+. 4
+. 4
+.2
+1.38
+2.07
+1.2
+1.38
+1.38
+. 69
+1.38
+.2
+1.6
+25
+25
+25
+40683
+40683
+40683
+25
+40683
+25
+25
+40683
+40683
+40683
+40683
+40683
+40683
+40683
+40683
+25
+25
+25
+25
+40683
+40683
+25
+40683
+40683
+40683
+40683
+25
+25
+25
+• 6
+0
+• 4
+. 2
+0
+0
+.2
+. 4
+.4
+. 4
+.2
+• 4
+0
+0
+1.2
+Page109
+
+
+
+Account:
+MOBILE
+ESN
+X cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NACN
+NEW YORK
+SANTURCE
+SANTURCE
+NY
+PR
+PR
+NACN
+NACN
+NACN
+NACN
+NACN
+NEW YORK
+SANTURCE
+NY
+PR
+NEW YORK C NY
+NACN
+SANTURCE
+PR
+NACN
+SANTURCE
+PR
+NACN
+CHARLI AML
+SANTURCE
+NEW YORK
+SANTURCE
+SANTURCE
+SANTURCE
+VI
+PR
+NY
+PR
+PR
+PR
+NACN
+NACN
+SANTURCE
+PR
+NACN
+SANTURCE
+PR
+NACN
+NACN
+NACN
+SANTURCE
+PR
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+03/15 4: 4906P
+03/15
+5:0932P
+03/15
+5:1129₽
+03/15
+5:1710₽
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/15
+5: 3341P
+03/15
+5:4320₽
+03/15
+5: 4607P
+03/15
+6: 1226P
+03/15
+6: 1803P
+03/15
+6: 2743P
+03/15
+6: 4004P
+INCOMING
+INCOMING
+03/15
+6: 5002P
+03/15
+7: 4103P
+03/15
+9:5246P
+INCOMING
+03/15
+10:5343P
+03/16
+9: 2549A
+INCOMING
+03/16 10:2650A
+03/16 11:0005A
+03/16 12:5703P
+03/16
+1:1011P
+03/16
+1:1107P
+03/16
+1: 3602P
+03/16
+1: 4149P
+INCOMING
+INCOMING
+03/16
+1: 5706P
+03/16
+2:1211P
+03/16
+2: 3523P
+INCOMING
+03/16
+2: 3703P
+03/16
+2: 3754P
+INCOMING
+INCOMING
+INCOMING
+03/16
+2:4258P
+03/16
+3: 3628P
+03/16
+3: 3855₽
+03/16
+5: 0045P
+DUR
+4
+0
+2
+1
+8
+5
+10
+1
+0
+2
+3
+0
+2
+2
+1
+0
+1
+13
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+4.14
+2.76
+0
+0
+1.38
+• 69
+5.52
+3.45
+6.9
+• 69
+.69
+2.76
+1.38
+2.07
+1.38
+1.38
+0
+0
+0
+1.38
+1.38
+0
+- 69
+• 69
+2.07
+8.97
+LAND TOTAL RSYS
+0
+.8
+1
+2
+0
+2.6
+4.14
+3.56
+1
+2
+1.38
+• 69
+5.52
+3.45
+6.9
+.89
+• 69
+2.76
+• 4
+1.38
+• 6
+2.07
+1.78
+. 4
+1.78
+1.38
+1.38
+• 6
+• 69
+2.6
+• 69
+2.07
+8.97
+40683
+40683
+25
+25
+40683
+40683
+40683
+40683
+40683
+40683
+25
+40683
+40683
+25
+40683
+25
+40683
+40683
+25
+40683
+25
+25
+25
+40683
+40683
+25
+40683
+25
+40683
+40683
+40683
+25
+0
+0
+. 8
+. 6
+. 4
+.4
+4
+• 4
+0
+• 6
+Page 109
+
+
+
+Account:
+MOBILE
+ESN
+X cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK C NY
+NACN
+W PALM BCH FL
+SANTURCE PR
+W PALM BCH FL
+NACN
+SANTURCE
+SANTURCE
+SANTURCE
+NACN
+PR
+PR
+PR
+SANTURCE
+PR
+NACN
+SANTURCE
+SANTURCE
+SANTURCE
+PR
+PR
+PR
+NACN
+NACN
+NACN
+SANTURCE
+PR
+NACN
+NACN
+NACN
+NACN
+SANTURCE
+PR
+UN. KINGDO
+NACN
+SANTURCE
+PR
+NACN
+SANTURCE
+SANTURCE
+SANTURCE
+SANTURCE
+PR
+PR
+PR
+PR
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+03/16 5:5438P
+INCOMING
+03/16
+6: 0153P
+03/16
+9:5754P
+03/17
+8: 3452A
+03/17
+8: 4624A
+INCOMING
+03/17
+9: 3555A
+03/17
+9: 4132A
+03/17
+9: 5819A
+03/17 10:1958A
+INCOMING
+03/17 10:4237A
+03/17 10:4413A
+INCOMING
+03/17 10:5918A
+03/17 11: 0200A
+03/17 11:0802A
+03/17 11:1138A
+INCOMING
+INCOMING
+INCOMING
+03/17 11:2059A
+03/17 11:4441A
+03/17 11:4514A
+03/17 11:5617A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/17 12:0258P
+03/17 12:0901P
+03/17 12:1235P
+03/17 12:5717P
+03/17 1:0127P
+03/17 1:0400P
+INCOMING
+03/17
+2:0230₽
+03/17
+3: 3952₽
+INCOMING
+03/17
+4: 4054P
+03/17
+4: 4435P
+03/17
+4: 5725₽
+03/17
+5: 0146P
+03/17
+5:0347P
+DUR
+1
+1
+1
+0
+1
+3
+0
+1
+0
+0
+2
+0
+2
+1
+1
+1
+1
+0
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+• 69
+- 69
+• 69
+0
+• 69
+2.07
+0
+0
+0
+• 69
+• 69
+0
+0
+. 69
+. 69
+1.38
+1.38
+• 69
+• 69
+.69
+1.38
+.69
+0
+- 69
+LAND TOTAL RSYS
+.2
+. 6
+. 2
+0
+.2
+. 2
+. 2
+• 4
+0
+0
+. 2
+.2
+1.1
+.2
+1
+• 69
+• 69
+.89
+• 6
+.89
+2.07
+• 2
+.2
+.2
+• 69
+•4
+• 69
+4
+2
+2
+. 69
+. 69
+1.38
+.2
+1.38
+• 69
+- 69
+• 69
+.2
+2.48
+• 69
+.2
+• 69
+.2
+i a
+1
+40683
+40683
+40683
+25
+40683
+40683
+25
+25
+25
+40683
+25
+40683
+25
+2
+5
+25
+40683
+40683
+40683
+25
+40683
+40683
+40683
+40683
+25
+40683
+40683
+25
+40683
+25
+25
+25
+25
+Page110
+
+
+
+Account:
+MOBILE
+ESN
+X cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+W PALM BCH FL
+SANTURCE
+PR
+NACN
+NACN
+NACN
+NACN
+W PALM BCH FL
+NEW YORK C NY
+SANTURCE
+SANTURCE
+PR
+PR
+NACN
+SANTURCE
+SANTURCE
+SANTURCE
+PR
+PR
+PR
+NACN
+NACN
+NACN
+NACN
+SANTURCE
+PR
+SANTURCE
+PR
+NEW YORK C NY
+NACN
+NACN
+C ST CROIX
+VI
+NEW YORK
+NY
+NEW YORK
+NY
+SANTURCE
+PR
+SANTURCE
+PR
+SANTURCE
+PR
+SANTURCE
+PR
+SANTURCE
+PR
+SANTURCE
+PR
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+03/17 5:3923P
+03/17
+5:4616P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/17
+5:5822P
+03/17
+6: 0248P
+03/17
+6: 0450P
+03/17
+6: 4715P
+03/17
+8: 5407P
+INCOMING
+03/17 11:2734P
+03/18
+9:4822A
+03/18 10:3943A
+INCOMING
+03/18 10:4918A
+03/18 11:1253A
+03/18 11:1613A
+03/18 11:3746A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/18 11:4043A
+03/18 12:1341P
+03/18 12:1711P
+03/18 12:3840P
+03/18
+1:0931P
+03/18
+1:1308P
+INCOMING
+INCOMING
+INCOMING
+03/18
+1:2724P
+03/18 2:1037P
+03/18
+2:1413₽
+03/18
+2: 3826P
+03/18
+3: 0351P
+03/18
+3:2717P
+03/18
+3: 4018P
+03/18
+3: 5030₽
+03/18
+3: 5534P
+03/18
+4: 1333₽
+03/18 4:1941P
+03/18 4:2119P
+DUR
+1
+3
+1
+5
+1
+1
+2
+0
+0
+3
+0
+1
+2
+1
+3
+H H
+0
+0
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+• 69
+2.07
+. 69
+3.45
+• 69
+. 69
+1.38
+0
+0
+2.07
+0
+. 69
+. 69
+. 69
+1.38
+• 69
+2.07
+- 69
+. 69
+. 69
+.69
+0
+LAND TOTAL RSYS
+•2
+.2
+0
+0
+0
+• 6
+.89
+.2
+2.07
+• 69
+3.45
+• 69
+. 89
+1.38
+• 6
+25
+40683
+40683
+40683
+40683
+40683
+25
+25
+25
+25
+25
+0
+0
+6
+. 2
+.2
+i i i
+2.07
+i i
+. 69
+. 69
+. 69
+1.38
+. 6
+. 2
+• 69
+2.07
+• 69
+.89
+.89
+.89
+• 8
+haina
+40683
+25
+25
+40683
+40683
+40683
+40683
+40683
+40683
+25
+25
+25
+25
+25
+25
+Page111
+
+
+
+Account:
+MOBILE
+ESN
+X cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+W PALM BCH FL
+NACN
+SANTURCE
+NACN
+PR
+NACN
+NACN
+NEW YORK C NY
+NACN
+NACN
+NACN
+UN. KINGDO
+NEW YORK
+SANTURCE
+NY
+PR
+NACN
+SANTURCE
+SANTURCE
+C ST CROIX
+C ST CROIX
+PR
+PR
+VI
+VI
+C ST CROIX VI
+NACN
+NACN
+SANTURCE
+SANTURCE
+SANTURCE
+SANTURCE
+SANTURCE
+SANTURCE
+PR
+PR
+PR
+PR
+PR
+PR
+NACN
+NACN
+NEW YORK
+NY
+NACN
+NACN
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+03/18 4:3741P
+INCOMING
+03/18
+4: 4117P
+03/18
+4: 4318P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/18
+4: 5127P
+03/18
+4: 5636P
+03/18
+5:1433P
+03/18
+5:2004P
+03/18
+5:2049P
+03/18
+5: 2222P
+03/18
+5:4413P
+03/18
+8: 4621P
+INCOMING
+03/18 11:2949P
+03/19
+7: 3803A
+INCOMING
+03/19
+8: 3903A
+03/19
+9: 0941A
+03/19
+9: 2158A
+03/19
+9:5457A
+03/19
+9: 5528A
+03/19
+9: 5811A
+INCOMING
+INCOMING
+03/19 10:1038A
+03/19 10:2308A
+03/19 11:2605A
+03/19 11:2648A
+03/19 11:3159A
+03/19 11:4457A
+03/19 11:5822A
+03/19 12:0318P
+INCOMING
+INCOMING
+03/19 12:2703P
+03/19 12:2746P
+03/19 12:2959P
+INCOMING
+INCOMING
+03/19 12: 3311P
+03/19 12:4558P
+DUR
+1
+4
+0
+3
+3
+1
+3
+3
+2
+1
+HON
+0
+1
+1
+11
+2
+0
+0
+0
+1
+1
+1
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+• 69
+2.76
+0
+2.07
+2.07
+2.07
+. 69
+2.07
+2.07
+1.38
+. 69
+• 69
+0
+1.38
+. 69
+. 69
+. 69
+7.59
+1.38
+0
+0
+0
+LAND TOTAL RSYS
+•2
+•4
+0
+0
+0
+0
+0
+0
+. 55
+.4
+2.2
+. 4
+.2
+. 2
+. 2
+0
+iN N
+. 8
+. 4
+• 6
+0
+• 69
+.69
+1.38
+- 69
+.4
+2.76 0
+.89
+40683
+2.76
+40683
+•4
+25
+2.07
+40683
+2.07
+40683
+2.07
+40683
+• 69
+40683
+2.07
+40683
+2.07
+40683
+1.38
+40683
+1.24
+40683
+• 69
+40683
+. 4
+25
+1.38
+40683
+2.2
+25
+.4
+25
+. 89
+40683
+. 89
+40683
+. 89
+40683
+7.59
+40683
+1.38
+40683
+.2
+25
+.2
+25
+25
+• 8
+25
+• 4
+25
+• 6
+25
+• 69
+40683
+• 69
+40683
+1.78
+40683
+. 69
+40683
+2.76
+Page 112
+
+
+
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+SANTURCE
+PR
+NACN
+NACN
+NEW YORK
+NY
+NACN
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+W PALM BCH
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NEW YORK
+NEW YORK
+NEW
+YORK
+NY
+NY
+NY
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NEW YORK NY
+WEST PALM
+FL
+NEW YORK
+NY
+W PALM BCH FL
+BROOKLYN NY
+ANS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/19 12:5406P
+03/19 12:5931P
+03/19
+1: 0419P
+03/19
+1:4922P
+03/19
+1: 5502P
+03/19
+1:5514P
+03/19
+3: 4156P
+03/19
+3: 4213P
+03/19
+3: 4242P
+03/19
+3: 5347P
+03/19
+3: 5844P
+03/19
+4: 0043P
+03/19
+4: 0954P
+03/19
+4: 1105P
+03/19
+4:1945P
+03/19
+4: 2054P
+03/19
+4:4148P
+03/19
+4: 4504P
+03/19
+4: 5204P
+03/19
+4: 5705P
+03/19
+6:2231P
+03/19
+6: 2338P
+03/19
+7: 0224P
+03/19
+7: 0336P
+03/19
+8: 4156P
+03/19
+8: 4310₽
+03/19
+9:1433P
+03/20 10:0208A
+03/20 10:2227A
+03/20 10:2832A
+03/20 10:4533A
+03/20 10:4601A
+DUR
+2
+3
+4
+1
+1
+1
+1
+3
+2
+2
+0
+3
+4
+7
+5
+2
+O HO
+4
+0
+31
+1
+1
+N HO H
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+X cingular®
+AIR
+0
+1.38
+2.07
+2.76
+• 69
+• 69
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+•2
+• 8
+0
+0
+0
+0
+• 0O
+0
+0
+•2
+1.38
+2.07
+3.56
+• 69
+.89
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+40683
+40683
+40683
+40683
+40683
+37
+37
+37
+37
+37
+37
+25
+25
+37
+37
+37
+25
+37
+25
+37
+25
+37
+37
+37
+37
+37
+25
+37
+Page113
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+WEST PALM FL
+W PALM BCH FL
+NACN
+WEST PALM FL
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+UN. KINGDO
+W PALM BCH
+FL
+NACN
+CHARLT AML
+VI
+CHARLT AML
+VI
+MOBILE
+NY
+NWYRCYZN01
+NY
+MOBILE
+NY
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+W PALM BCH FL
+DIR. ASST.
+NEW YORK
+NY
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+W PALM BCH FL
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+03/20 10:4649A
+03/20 11:0905A
+INCOMING
+INCOMING
+03/20 11:1014A
+03/20 12:1024P
+03/20 12:1113P
+03/20 12:1250P
+INCOMING
+03/20 12:1402P
+03/20 12: 3255P
+03/20 12:4605P
+INCOMING
+03/20 12:4716P
+03/20
+1: 0800P
+INCOMING
+03/20 1:0810P
+03/20
+1: 1214P
+03/20
+1:1252P
+INCOMING
+03/20
+1:1358P
+03/20
+4: 0718P
+03/20
+4:1102P
+03/20
+4:2241P
+03/20
+4: 5536P
+03/20
+4:5708P
+03/20
+4: 5827P
+03/20
+5:0640₽
+03/20
+5:2742P
+03/20
+5: 3522₽
+03/20
+5: 4107₽
+03/20
+6: 1046₽
+03/20
+6: 1047₽
+03/20
+6: 4716P
+03/20
+6: 5057P
+03/20
+6: 5515₽
+03/20
+6: 5628P
+03/20
+6:5829P
+DUR
+1
+0
+1
+2
+0
+1
+1
+0
+3
+0
+8
+2
+3
+1
+5
+IN H
+AIR
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+• 55
+• o
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+37
+25
+37
+37
+37
+25
+37
+37
+25
+37
+25
+37
+2.
+37
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+H H
+Page114
+
+
+
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+MOBILE
+NY
+NEW YORK
+NY
+NEW YORK
+NEW YORK
+OAHU
+GARDENA
+LAS VEGAS
+NY
+NY
+HI
+CA
+NV
+NEW YORK
+NY
+UN. KINGDO
+W PALM BCH FL
+NEW YORK NY
+MOBILE
+NY
+W PALM BCH FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+03/20 6: 5951₽
+INCOMING
+03/20 7:0825P
+INCOMING
+03/20 7:1133₽
+INCOMING
+03/20
+7: 4651P
+INCOMING
+03/20 9:0652₽
+INCOMING
+03/20 9:4458₽
+03/20 9:5451₽
+INCOMING
+INCOMING
+INCOMING
+03/20 9:5555₽
+03/20 9:5614P
+03/20 9:5715P
+03/20 9:5918₽
+INCOMING
+INCOMING
+INCOMING
+03/20 10:1327P
+03/20 10:1901P
+03/20 10:2245
+03/20 10:2446P
+03/20 10:2643P
+03/20 10:3324P
+03/20 10:3657P
+03/20 10:3835P
+INCOMING
+03/20 10:4452P
+03/20 10:4846P
+INCOMING
+03/20 11:1958P
+03/21
+8: 2451A
+INCOMING
+03/21
+8: 4526A
+03/21
+8: 4558A
+INCOMING
+03/21
+9: 0302A
+03/21
+9: 4825A
+INCOMING
+INCOMING
+03/21 10:4410A
+03/21 10:4736A
+03/21 11:5156A
+03/21 11:5238A
+INCOMING
+03/21 12:1045P
+DUR
+1
+1
+4
+2
+2
+10
+1
+2
+1
+1
+2
+2
+2
+2
+1
+2
+1
+4
+3
+1
+1
+5
+2
+2
+1
+H N
+10
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+X cingular®
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2
+5
+25
+25
+0
+0
+1.65
+0
+1.65
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page115
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+UN. KINGDO
+NEW YORK
+NEW YORK
+MOBILE
+UN. KINGDO
+NY
+NY
+NY
+W PALM BCH FL
+NEW YORK
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+03/21 12:3953₽
+03/21 12:5621F
+03/21
+1: 1102P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/21
+1: 4415P
+03/21
+2:4852P
+03/21
+3: 4254P
+03/21
+5:1519P
+03/21
+5:1639P
+03/21
+5: 5537₽
+INCOMING
+03/21
+6: 3443P
+03/21
+6: 3516P
+INCOMING
+INCOMING
+03/21
+7:1038P
+03/21
+7: 4551P
+03/21
+8: 3004P
+INCOMING
+INCOMING
+03/21
+8: 3756P
+03/21
+9: 0706P
+03/21
+9:0830P
+INCOMING
+03/21
+9:2027P
+03/22
+8: 5654A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/22
+9: 2648A
+03/22 10:0240A
+03/22 10: 0537A
+03/22 10:5601A
+03/22 11:1500A
+03/22 11:2548A
+03/22 11: 4036A
+03/22 12:0439P
+03/22 12:0512P
+03/22 12:0658P
+03/22 12:0820P
+INCOMING
+INCOMING
+03/22 12:1257P
+03/22 12:1424P
+DUR
+2
+1
+17
+1
+2
+1
+4
+1
+2
+m m
+8
+1
+2
+2
+INN
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+2.2
+• 000
+. 5
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+2.2
+0
+0
+55
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+5
+2
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page116
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+W PALM BCH FI
+W PALM BCH FI
+W PALM BCH FL
+W PALM BCH FL
+NEW YORK
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+INCOMING
+03/22 12:1446P
+03/22 12:1634P
+03/22 12:1709P
+03/22 12:1730₽
+INCOMING
+03/22 12:1830P
+03/22 12:2838P
+INCOMING
+INCOMING
+03/22 2:1114P
+03/22
+2:1952P
+03/22 2:2028P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/22 3:0750₽
+03/22 3:3601P
+03/22 4:1200P
+03/22
+4:1246P
+03/22
+4:1739P
+03/22
+4: 3743P
+03/22
+4: 5833P
+03/22
+6:1940P
+03/22
+6: 3114P
+03/22
+6: 3636P
+03/22
+7:1449P
+03/22
+7:2115P
+03/22
+7: 2631P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/22
+7: 3235₽
+03/22
+7: 4645P
+03/22
+7: 5708P
+03/22
+9:3137P
+03/22
+9: 4302P
+03/22
+9: 5501₽
+03/23
+9: 3321A
+03/23
+9: 5052A
+03/23 10:0118A
+03/23 10: 0309A
+DUR
+2
+1
+1
+1
+2
+1
+1
+1
+1
+IN AM
+2
+2
+4
+11
+11
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+0
+0
+0
+0
+0
+0
+• 0O
+5
+0
+0
+0
+0
+0
+• 0 0 0 0 0 0 0 O
+0
+0
+0
+0
+0
+0
+0
+2
+2
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page117
+
+
+
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NEW YORK
+NEW YORK
+UN. KINGDO
+NEW YORK
+NEW YORK
+DIR. ASST.
+NEW YORK
+NEW YORK
+DIR. ASST.
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+INCOMING
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+X cingular®
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+03/23 12:5359₽
+03/23 12:5541₽
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/23 1: 0542₽
+03/23
+1:1310P
+03/23
+1:4820P
+03/23
+2:3454P
+03/23
+3: 5739P
+03/23
+3: 5856P
+INCOMING
+03/23
+4:0400P
+03/23 4:2337P
+INCOMING
+INCOMING
+03/23 4:5144P
+03/23 4:5210P
+03/23
+4: 5421P
+INCOMING
+03/23
+5:4312P
+03/23
+6: 0047P
+INCOMING
+03/23
+6:1647P
+03/23
+6:2026P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/23
+7:2404P
+03/23
+7:4750P
+03/23
+7: 4813P
+03/23
+7:5154P
+03/23
+7: 5217₽
+03/23
+7: 5945P
+03/23 10:0843P
+03/24
+6: 3955A
+03/24
+7: 1312A
+03/24
+7: 5250A
+03/24
+7: 5251A
+03/24
+7: 5513A
+03/24
+8: 0735A
+03/24
+8: 2320A
+03/24
+9: 2341A
+DUR
+1
+1
+1
+1
+1
+1
+1
+1
+2
+1
+4
+1
+2
+3
+0
+2
+1
+M -н
+AIR
+0
+0
+LAND TOTAL RSYS
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+0
+0
+0
+0
+0
+0
+0
+0
+0
+• 000
+• 0
+• O
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page118
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW ALBANY OH
+NEW YORK
+NY
+NEW YORK
+NY
+NEW YORK
+NY
+QUEENS
+MOBILE
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+03/24 9:5502A
+INCOMING
+03/24 10:1719A
+INCOMING
+03/24 10:4231A
+INCOMING
+03/24 11:0641A
+INCOMING
+INCOMING
+03/24 11:1449A
+03/24 11:5234A
+03/24 12:2744P
+INCOMING
+03/24 12: 3852P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/24 1:0017₽
+03/24 1:0213P
+03/24 1:2534P
+03/24 2:2328P
+03/24
+3: 1033P
+03/24
+4: 0131P
+03/24
+4: 4039P
+03/24
+4: 4500P
+03/24
+4: 5552P
+03/24
+5:5504P
+03/24
+7:1056P
+INCOMING
+03/24
+7: 4402P
+03/24
+7:4829P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/24 8:0446P
+03/24
+8: 1956₽
+03/24
+8: 4428P
+03/24
+8: 5856P
+03/24
+9:0139P
+03/25
+8: 1331A
+03/25
+8: 5825A
+03/25
+9: 0956A
+03/25
+9: 2640A
+03/25
+9:5643A
+03/25
+9:5828A
+DUR
+1
+1
+1
+1
+1
+1
+1
+1
+3
+7
+6
+34
+5
+9
+3
+2
+4
+NNN
+N N M
+3
+2
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+• 0
+• • 0 0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page119
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NY
+DELRAY BCH FL
+NEW YORK
+NY
+UN. KINGDO
+UN. KINGDO
+NEW
+YORK
+W PALM BCH
+NY
+FL
+UN. KINGDO
+NEW YORK
+NEW YORK
+NEW YORK
+W PALM BCH
+NY
+NY
+NY
+FL
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+03/25 11:4658A
+INCOMING
+03/25 1:2316P
+INCOMING
+03/25 1:2356P
+INCOMING
+03/25 2:0004P
+INCOMING
+03/25
+3:1903P
+INCOMING
+03/25
+4:1107P
+INCOMING
+03/25
+4:1457P
+INCOMING
+03/25
+4: 3809P
+03/25
+4: 3857P
+03/25 4:4029P
+INCOMING
+03/25 5:1122₽
+03/25 5:1323P
+INCOMING
+03/25
+5:4746P
+03/25
+5:4832P
+INCOMING
+03/25
+5: 5030P
+03/25
+5:5054P
+03/25
+6: 0406P
+03/25
+6: 0751P
+INCOMING
+03/25
+6:2419P
+03/25
+6:2458P
+03/25
+6: 3106P
+03/25
+6: 5718₽
+03/25
+6: 5831₽
+03/25
+6: 5956P
+INCOMING
+INCOMING
+INCOMING
+03/25
+7: 0040P
+03/25
+7: 0150₽
+03/25
+7: 0234P
+03/25
+7: 0245₽
+03/25
+7:0509P
+03/25
+7:1629P
+03/25
+7:1739P
+INCOMING
+03/25
+7: 3702P
+DUR
+2
+1
+1
+1
+1
+1
+1
+2
+1
+2
+m N H
++ m
+2
+1
+1
+1
+2
+1
+2
+10
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+5
+5
+1
+0
+65
+0
+1
+65
+0
+0
+0
+0
+0
+0
+0
+0
+5
+5
+1.65
+1.65
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+2
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page120
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+AWS NEW YORK
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+UN. KINGDO
+NEW YORK
+NEW YORK
+NY
+NY
+MOBILE
+UN. KINGDO
+INTL NTWK
+UN. KINGDO
+INTL NIWK
+UN. KINGDO
+INTL NTWK
+INTL NIWK
+INTL NTWK
+CALL SVC
+UN. KINGDO
+UN. KINGDO
+UN. KINGDO
+UN. KINGDO
+UN. KINGDO
+UN. KINGDO
+UN. KINGDO
+UN. KINGDO
+UN. KINGDO
+INTL NTWK
+INTL NTWK
+INTL NIWK
+INTL NTWK
+INTL NIWK
+INTL NIWK
+NY
+CALLED PHONE CDATE CTIME
+INCOMING
+03/25 7:5049P
+03/25
+8:1821P
+INCOMING
+03/25
+9:0355P
+03/25
+9: 0502₽
+03/25
+9:0808P
+INCOMING
+INCOMING
+03/25
+9: 3943₽
+03/25
+9: 4014₽
+03/25
+9:4121P
+03/25 10:3414P
+03/26 10:2248A
+03/26 12:4923P
+03/26 2:1200P
+03/26
+2:1534P
+03/26
+2: 3918P
+03/26
+3: 1322P
+03/26
+5: 5352P
+03/27
+12: 0000A
+03/27
+6: 3808A
+03/27
+7: 5158A
+03/27
+8: :0610A
+03/27
+8: :0844A
+03/27
+8: 1607A
+03/27
+8: 3027A
+03/27
+9: 0130A
+03/27
+9: 0327A
+03/27 11:0151A
+03/27 12:1652P
+03/27 12:1744P
+03/27 12:1943P
+03/27 12:3938P
+03/27 12:5442P
+03/27 1:3902P
+DUR
+1
+1
+1
+3
+4
+1
+1
+1
+1
+1
+0
+* O
+1
+0
+0
+0
+1
+1
+2
+1
+1
+4
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+• 99
+3.96
+0
+. 99
+. 99
+1.98
+. 99
+LAND TOTAL RSYS
+0
+. 55
+0
+0
+. 55
+.35
+.55
+1.4
+4.4
+. 35
+.35
+. 7
+1.65
+0
+0
+. 55
+. 55
+1.1
+0
+2.2
+1.1
+0
+0
+. 55
+1.65
+1.1
+. 99
+. 35
+.99
+• 35
+1.98
+.?
+.99
+. 35
+.99
+.35
+3.96 1.4
+25
+. 55
+0
+0
+25
+25
+25
+25
+D
+25
+25
+25
+• 55
+25
+1.34
+75075
+• 55
+25
+5.36
+75075
+4.4
+25
+1.34
+75075
+1.34
+75075
+2.68
+75075
+. 99
+75075
+1.65
+25
+. 55
+25
+. 55
+25
+1.1
+25
+2.2
+25
+1.1
+25
+• 55
+25
+1.65
+25
+1.1
+25
+1.34
+75075
+1.34
+75075
+2.68
+75075
+1.34
+75075
+1.34
+75075
+5.36
+75075 C
+Page 121
+
+
+
+Account:
+MOBILE
+ESN
+Xcingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+AWS NEW YORK
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+CALLED PHONE CDATE CTIME
+INTL NTWK
+INTL NTWK
+INTL NTWK
+INTL NTWK
+INTL NTWK
+INTL NTWK
+INTL NTWK
+INTL NTWK
+INTL NTWK
+INTL NTWK
+INTL NTWK
+UN. KINGDO
+INTL NTWK
+INTL NTWK
+INTL NIWK
+INTL NIWK
+INTL NTWK
+INTL NTWK
+INTL NIWK
+INTL NTWK
+INTL NIWK
+INTL NIWK
+INTL NTWK
+INTL NTWK
+INTL NTWK
+INTL NTWK
+UN. KINGDO
+UN. KINGDO
+INTL NIWK
+INTL NTWK
+CALL SVC
+UN. KINGDO
+03/27 2:1117P
+03/27
+2:1645P
+03/27
+2:2854P
+03/27
+2:2926P
+03/27
+2:2939P
+03/27
+2: 3046P
+03/27
+2:3123P
+03/27
+2: 3701P
+03/27
+2:4240P
+03/27
+2: 4703P
+03/27
+2: 5101P
+03/27
+3: 0519₽
+03/27
+3: 3816P
+03/27
+3: 4025P
+03/27
+4: 0750P
+03/27
+7:5614P
+03/27
+8: :0102P
+03/27
+8: 0320P
+03/27
+9: 5719P
+03/27
+9:5904P
+03/27 10:0016P
+03/27 11: 0203P
+03/27 11:0514P
+03/27 11:2018P
+03/27 11:2045P
+03/27 11:2416P
+03/28 10:5759A
+03/28 12:4155P
+03/28
+3: 3130P
+03/28
+5:5825P
+03/29 12:0000A
+03/29 8:5057A
+DUR
+12
+1
+1
+1
+1
+2
+1
+2
+2
+2
+2
+1
+1
+1
+1
+10
+1
+1
+3
+0
+0
+1
+1
+1
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+LAND
+TOTAL RSYSI
+5.94
+2.1
+11.88 4.2
+.99
+.35
+. 99
+. 35
+. 99
+.35
+. 99
+.35
+4.95
+1.75
+4.95
+1.75
+.99
+. 35
+2.97
+1.05
+1.98
+• 7
+0
+1.1
+. 99
+.35
+4.95
+1.75
+1.98
+. 7
+1.98
+. 7
+1.98
+. 7
+1.98
+. 7
+. 99
+. 35
+.99
+. 35
+. 99
+. 35
+. 99
+. 35
+9.9
+3.5
+• 99
+. 35
+. 99
+. 35
+2.97
+1.05
+0
+1.1
+1.1
+•99
+. 35
+• 99
+. 35
+. 99
+0
+1.1
+8.04
+75075
+16.08 75075
+1.34
+75075
+1.34
+75075
+1.34
+75075
+1.34
+75075
+6.7
+75075
+6.7
+75075
+1.34
+75075
+4.02
+75075
+2.68
+75075
+1.1
+25
+1.34
+75075
+6.7
+75075
+2.68
+75075
+2.68
+75075
+2.68
+75075
+2.68
+75075
+1.34
+75075
+1.34
+75075
+1.34
+75075
+1.34
+75075
+13.4
+75075
+1.34
+75075
+1.34
+75075
+4.02
+75075
+1.1
+25
+1.1
+25
+1.34
+75075
+1.34
+75075
+.99
+75075
+1.1
+25
+Page122
+
+
+
+Account:
+MOBILE
+ESN
+X cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+INTL NTWK
+UN. KINGDO
+UN. KINGDO
+UN. KINGDO
+UN. KINGDO
+UN. KINGDO
+INTL NTWK
+INTL NTWK
+INTL NTWK
+INTL NTWK
+INTL NTWK
+INTL NTWK
+INTL NIWK
+INTL NTWK
+INTL NIWK
+INCOMING
+INCOMING
+NEW YORK
+NY
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+NEW YORK
+NY
+INCOMING
+NEW YORK
+NY
+INCOMING
+NEW YORK
+NY
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+03/29 9:0929A
+03/29
+9: 4308A
+03/29 10:2710A
+03/29 11:1153A
+03/29 11:1940A
+03/29 11:5949A
+03/29
+2:5431P
+03/29
+3: 2353P
+03/29
+3:2411P
+03/29
+3:2500₽
+03/29
+3: 2515P
+03/29
+3: 2546₽
+03/29
+3: 5248P
+03/29
+5:2208P
+03/29
+6: 0242P
+03/29
+9: 3023P
+03/29
+10:4626P
+03/29 10:4712P
+03/30
+8: 4738A
+03/30 11:2329A
+03/30
+1:4139P
+03/30 1: 4159P
+03/30
+2: 1312₽
+03/30
+2: 3711P
+03/30
+3: 0430₽
+03/30
+5:2628P
+03/30
+5: 3247₽
+03/30
+5:3450₽
+03/30
+5: 4312₽
+03/30
+6: 2602₽
+03/30
+6: 3926P
+03/30
+7:1549P
+DUR
+1
+0
+0
+1
+1
+1
+1
+1
+2
+1
+1
+1
+7
+1
+20
+4
+1
+2
+7
+1
+2
+3
+AIR
+• 99
+0
+0
+0
+0
+0
+. 99
+. 99
+. 99
+. 99
+.99
+.99
+1.98
+1.
+91
+8
+5.
+94
+0
+0
+0
+0
+0
+0
+LAND
+TOTAL RSYS
+. 35
+4.4
+1.1
+1.65
+. 55
+1.1
+. 35
+.35
+. 35
+.35
+.35
+. 35
+. 1
+0
+0
+0
+0
+0
+0
+0
+0
+1.34
+4.4
+1.1
+1.65
+. 55
+1.1
+1.34
+1.34
+1.34
+1.34
+1.34
+1.34
+2.68
+.68
+8.04
+0
+0
+0
+0
+0
+0
+0
+75075 C
+25
+25
+25
+25
+25
+75075
+75075
+75075
+75075
+75075
+75075
+75075
+75075
+75075
+25
+2
+5
+25
+2
+5
+2
+5
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 123
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NY
+DIR. ASST.
+NEW YORK
+NEW YORK
+NY
+NY
+NEW YORK
+NY
+MOBILE
+NY
+NEW YORK
+MOBILE
+NEW YORK
+NY
+NY
+NY
+MOBILE
+MOBILE
+MOBILE
+NY
+NY
+NY
+NEW YORK
+NY
+NEW YORK
+NEW YORK
+NY
+NY
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+03/31 9:0729A
+03/31 12:2603P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+03/31 12:4044P
+03/31 1:0623P
+03/31
+1:2911P
+03/31
+1: 3928P
+03/31
+3: 3832P
+03/31
+3: 4957P
+03/31
+4: 4041P
+03/31 4:4042P
+03/31
+4: 4805P
+INCOMING
+03/31 4:5341P
+03/31
+5: 5319P
+INCOMING
+03/31
+5:5
+P
+03/31
+5: 5942P
+INCOMING
+03/31
+6: 2622P
+03/31
+6:3527P
+03/31
+7: 0229P
+03/31
+7: 0321P
+INCOMING
+03/31
+8: 0351P
+03/31
+8: 0628P
+03/31
+8: 0739₽
+03/31
+8: 0955P
+INCOMING
+04/01
+8: 4921A
+04/01
+8: 5035A
+INCOMING
+04/01
+9:0849A
+04/01
+9: 0912A
+04/01
+9: 1031A
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+04/01
+9: 1159A
+04/01 10:2725A
+04/01 11:2441A
+04/01 11:3001A
+DUR
+1
+2
+2
+1
+2
+1
+3
+0
+3
+1
+2
+1
+2
+1
+1
+W #
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0 0 C
+0 0 C
+000
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page124
+
+
+
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NEW YORK
+NEW YORK
+MOBILE
+NEW YORK
+NEW YORK
+MOBILE
+NEW YORK
+MOBILE
+MOBILE
+MOBILE
+MOBILE
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+NY
+INCOMING
+INCOMING
+INCOMING
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+X
+cingular®
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+04/01 11:4201A
+INCOMING
+04/01 11:5123A
+INCOMING
+04/01 11:5836A
+INCOMING
+04/01 12:1146P
+04/01 12:5903P
+INCOMING
+04/01
+1: 0113P
+04/01
+1:0238P
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+04/01
+1:1327P
+04/01
+1:1955P
+04/01
+1: 3006P
+04/01 1:3128P
+04/01 1:4325P
+04/01
+5:2213P
+04/01
+6: 3318P
+04/01
+6: 3349P
+04/01
+6: 4331P
+INCOMING
+04/01
+7: 4229P
+04/01
+7:4344P
+04/01
+7: 4500P
+INCOMING
+INCOMING
+04/01
+7:4831P
+04/01
+7: 5302P
+04/01 7:5355P
+04/01
+8: 0227P
+04/01
+8: 0319P
+04/01
+8: 0417P
+04/01
+8: 0515₽
+04/01
+8: 0619P
+04/01
+8: 4203P
+04/01 11:3543P
+04/02
+8: 3317A
+04/02
+8: 3334A
+04/02
+8: 3810A
+DUR
+1
+1
+1
+1
+1
+1
+2
+1
+1
+7
+П н
+2
+2
+HANNHAN
+1
+2
+1
+2
+4
+AIR
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+0
+0
+• 0
+0
+0
+0
+• 0
+• O
+• a
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page 125
+
+
+
+Account:
+MOBILE
+ESN
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+W PALM BCH FI
+NEW YORK
+NY
+NEW YORK
+NY
+W PALM BCH FL
+NEW YORK
+NY
+NEW YORK
+MOBILE
+NY
+NY
+NEW YORK
+NEW YORK
+NEW YORK
+MOBILE
+NY
+NY
+NY
+NY
+NEW YORK
+NEW YORK
+NY
+NY
+NEW YORK
+NY
+NEW YORK
+NY
+MOBILE
+NY
+ANS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+04/02 9:1320A
+INCOMING
+04/02 9:1415A
+04/02 9:1508A
+INCOMING
+04/02 10:1456A
+04/02 10:1604A
+04/02 10:1711A
+04/02 10:2023A
+INCOMING
+04/02 10: 3913A
+04/02 10:4139A
+INCOMING
+INCOMING
+INCOMING
+04/02 10:4528A
+04/02 10:5639A
+04/02 10:5718A
+04/02 11:1835A
+04/02 11:1935A
+INCOMING
+04/02 11:1954A
+04/02 11:2052A
+04/02 11:2245A
+04/02 11:3304A
+04/02 11:3348A
+INCOMING
+INCOMING
+04/02 11:4516A
+04/02 12:0153P
+04/02 12:0933P
+04/02 12:1410P
+INCOMING
+INCOMING
+04/02 12:3544P
+04/02 12:3710P
+04/02 12:3817P
+INCOMING
+INCOMING
+INCOMING
+04/02 12:3951P
+04/02
+1:0920P
+04/02
+1: 5346₽
+04/02
+1: 5532₽
+INCOMING
+04/02
+1: 5605₽
+04/02 3:3239P
+DUR
+1
+1
+1
+1
+2
+1
+1
+2
+3
+1
+N N
+2
+2
+4
+1
+13
+1
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless
+X cingular®
+AIR
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+0
+0
+0
+0
+0
+0
+0
+0
+0
+• 0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+Page126
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+LAM
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+MOBILE
+NY
+W PALM BCH FL
+NEW YORK
+NEW YORK
+W PALM BCH FL
+NEW YORK
+NEW YORK
+NWYRCYZN01
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+NY
+MOBILE
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+W PALM BCH FL
+NACN
+NEW YORK NY
+W PALM BCH FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+04/02 3:4248P
+04/02 4:0456P
+04/02 4:0830₽
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+04/02
+4:1709P
+04/02
+5:0213P
+04/02
+6: 0442₽
+04/02
+6: 0533₽
+04/02
+6: 0905₽
+04/02
+6: 1215₽
+04/02
+6: 3115₽
+04/02
+6: 3246₽
+04/02
+6: 3515₽
+04/02
+6: 3739P
+04/02
+6: 3850
+P
+INCOMING
+INCOMING
+04/02
+6: 4324P
+04/02
+7:2820P
+04/02
+7:3140P
+04/02
+7: 3323P
+04/02
+7:4228P
+INCOMING
+04/02 11:1341P
+04/03 12: 3817A
+INCOMING
+04/03 12: 3831A
+04/03
+2: 3819A
+INCOMING
+04/03
+2:3828A
+04/03
+2: 4038A
+INCOMING
+04/03
+2:4045A
+04/03
+2: 5011A
+INCOMING
+04/03
+2: 5020A
+04/03
+3: 2923A
+INCOMING
+INCOMING
+04/03
+3: 2936A
+04/03
+9:5503A
+04/03 10: 0808A
+DUR
+1
+1
+1
+1
+1
+1
+2
+1
+2
+* HAM I
+0
+5
+0
+0
+9
+0
+5
+un r
+PROPRIETARY AND CONFIDENTIAL
+Not for use
+or disclosure outside Cingular Wireless and its Affiliates
+AIR
+0
+0
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+0
+• 00
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+25
+5
+2.
+2
+37
+25
+37
+25
+37
+25
+37
+25
+37
+25
+37
+37
+25
+D
+Page127
+
+
+
+Account:
+MOBILE
+ESN
+X
+cingular®
+BILLED USAGE
+MACRO/CELL
+BILLED USAGE
+RATE PLAN DESCRIPTION
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN
+$199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+NATIONAL PLAN $199.99
+CALLED LOC
+NACN
+W PALM BCH FL
+NACN
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NEW YORK
+NY
+NY
+NY
+NY
+NY
+NACN
+NEW YORK
+NY
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+BROOKLYN
+NY
+NEW YORK
+NY
+NEW YORK
+NY
+NEW YORK
+NY
+QUEENS
+NY
+QUEENS
+NY
+NEW YORK
+NY
+BROOKLYN
+NY
+NWYRCYZN01 NY
+NEW YORK
+NY
+W PALM BCH FL
+WEST PALM FL
+W PALM BCH FL
+NACN
+NEW YORK
+NY
+WEST PALM FL
+AWS NEW YORK
+CALLED PHONE CDATE CTIME
+INCOMING
+04/03 10:0918A
+04/03 11:1908A
+INCOMING
+04/03 11:2017A
+04/03 12:1616P
+04/03 12:2914P
+04/03 12:2932P
+04/03 12:2955P
+04/03 12:3029P
+INCOMING
+INCOMING
+04/03 12:3133P
+04/03 12:4358P
+04/03
+1:1047P
+INCOMING
+INCOMING
+04/03
+1:1158P
+04/03
+1:1840P
+04/03
+1: 1915P
+INCOMING
+INCOMING
+INCOMING
+04/03
+3: 0619P
+04/03
+3: 1810P
+04/03
+3:5651P
+04/03
+4: 0635P
+04/03
+4: 0831P
+INCOMING
+04/03
+4: 2844P
+04/03
+4: 3208P
+04/03
+4: 3722P
+04/03
+4:5138P
+04/03
+5:2700P
+04/03
+5:2931P
+04/03
+5:4055P
+INCOMING
+INCOMING
+04/03
+5: 4205P
+04/03
+5:4631P
+04/03
+5:4721P
+DUR
+2
+1
+13
+1
+1
+1
+1
+9
+1
+0
+AIR
+0
+0
+0
+11
+1 AM
+0
+0
+0
+0
+0
+LAND TOTAL RSYS
+0
+0
+0
+• •
+• 0 0 00
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+0
+37
+25
+37
+37
+37
+37
+37
+37
+37
+37
+25
+37
+37
+37
+37
+37
+37
+37
+37
+37
+37
+37
+37
+37
+25
+37
+37
+37
+U U
+LAM
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless
+Page 128
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/230b5f73321ecaccc4ef6567f154b728674c7717eb38c49610b774eb7ec27198.receipt.json b/vision-fixhub/ds9-unparsed-06/230b5f73321ecaccc4ef6567f154b728674c7717eb38c49610b774eb7ec27198.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a04f1f5417bef937edc30fe55638f33520c32ed6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/230b5f73321ecaccc4ef6567f154b728674c7717eb38c49610b774eb7ec27198.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -13999,
+  "dataset": "marble-joined",
+  "doc_id": "230b5f73321ecaccc4ef6567f154b728674c7717eb38c49610b774eb7ec27198",
+  "engine": "marble-apple-vision",
+  "event_count": 264,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "36cccd9a5c708ec9adf3070ba677a7911a23973349d43607eb24644ff9db8808",
+  "output_sha256": "283f0447e2750cdeb010736640bb37f10e474ad0ce958cb2fd9785adca164c23",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2313fb67601684ba10432236c24e036d6427f06635345747b43a77b2b7240828.md b/vision-fixhub/ds9-unparsed-06/2313fb67601684ba10432236c24e036d6427f06635345747b43a77b2b7240828.md
new file mode 100644
index 0000000000000000000000000000000000000000..9a0fc22aca1d757fa0f5283cdaca1e9252023f3b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2313fb67601684ba10432236c24e036d6427f06635345747b43a77b2b7240828.md
@@ -0,0 +1,796 @@
+Case 9:08-cv-80736-KAM Document 106-1 Entered on FLSD Docket 10/10/2011 Page 1 of 16
+
+
+
+Case 9:08-cv-80736-KAM Document 106-1 Entered on FLSD Docket 10/10/2011 Page 2 of 16
+1 SUPREME COURT
+NEW YORK COUNTY
+TRIAL TERM
+PART 66
+THE PEOPLE OF THE STATE OF NEW YORK:
+INDICTMENT #
+30129/2010
+page 1
+2
+3
+4
+AGAINST
+5
+JEFFREY EPSTEIN
+6
+Defendant.
+7
+8
+9
+10
+BEFORE:
+11
+12
+13
+14
+APPEARANCES:
+15
+For the People:
+16
+17
+18
+19|
+For the Defense:
+20
+21
+22
+23
+24
+25
+--× SORA HEARING
+111 Centre Street
+New York, New York 10013
+January 18, 2011
+HONORABLE RUTH PICKHOLZ
+Justice of the Supreme Court
+New York 10013
+BY: JENNIFER GAFFNEY, ESQ.
+Assistant District Attornev
+KIRKLAND & ELLI, LLP
+153 East 53rd Street
+New York, New York 10022
+BY: JAY' LEFKOWITZ
+ESQ.
+SANDRA MUSUMÉCI, ESQ.
+
+
+Case 9:08-cv-80736-KAM Document 106-1 Entered on FLSD Docket 10/10/2011 Page 3 of 16
+page 2
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+COURT CLERK: This is number two on the calendar,
+matter of Jeffrey Epstein.
+Your appearances please.
+MS. GAFFNEY: Jennifer Gaffney for the People.
+Good afternoon, Your Honor.
+MR. LEFKOWITZ: Jay Lefkowitz and Sandra Musumeci
+for Mr. Epstein.
+THE COURT: Mr. Epstein is not here.
+MR. LEFKOWITZ: That's correct.
+THE COURT: Are you waiving his appearance?
+MR. LEKWOWITZ: Yes.
+MS. GAFFNEY: Your Honor, this case is on for a
+SORA hearing this afternoon.
+The People did receive the board's recommendation
+of a Level Three. However, we received the underlying
+information from them and also had some contact with
+Florida, and we don't believe that we can rely on the entire
+probable cause affidavit.
+I don't know if the board sent that to you as
+well.
+THE COURT: I don't know why you cannot rely on
+it.
+MS. GAFFNEY: Because in Florida of all of the
+victims in that probable cause affidavit, they actually only
+went forward on one case. There was only an indictment for
+Senior Couri Reporter
+
+
+Case 9:08-cv-80736-KAM Document 106-1 Entered on FLSD Docket 10/10/2011 Page 4 of 16
+page 3
+one victim and that is what the defendant plead to.
+So it is unlike a situation where everything was
+indicted and then we get to sort of assess points for all of
+the victims, if it was part of a plea bargain. They did not
+actually choose to go forward on any except for the one
+victim.
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+So under the board guidelines, the risk assessment
+interim guidelines, it actually says, you know, by way of
+contrast if an offender is not indicted for an offense, it
+is strong evidence that the offense did not occur and I
+don't think --
+THE COURT: Do you find that if somebody is not
+indicted it is strong evidence that it did not occur?
+MS. GAFFNEY: I don't know that we can rely on it
+as clear and convincing evidence if the prosecutor's office
+never went forward on it. The prosecution said that the
+victims, although they spoke to the police early on, did not
+cooperate with them. So we don't have any follow up
+information.
+THE COURT: But the board found a Level Three.
+I have to tell you, I am a little overwhelmed
+because I have never seen the prosecutor's office do
+anything like this.
+I have never seen it. I had a case
+with one instance it was a marine who went to a bar, and I
+wish I had the case before me, but he went to a bar and a 17
+
+
+Case 9:08-cv-80736-KAM Document 106-1 Entered on FLSD Docket 10/10/2011 Page 5 of 16
+page 4
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+year old, he was an adult obviously, he was a Marine, a 17
+year old came up to him and one thing lead to another and he
+had sex with her and the People would not agree to a
+downward modification on that.
+So I am a little overwhelmed here because I see --
+I mean I read everything here, I am just a little
+overwhelmed that the People are making this application.
+I could cite many many, I have done many SORAs
+much less troubling than this one where the People would
+never make a downward argument like this.
+MS. GAFFNEY: I agree with Your Honor, it is
+incredibly unusual for us to make a downward argument. But
+the problem is the one thing that we have from the board is
+it seems to be in contradiction to their own guidelines
+which if something was not indicted, you are not supposed to
+rely on it.
+THE COURT: They obviously took that into
+consideration.
+MS. GAFFNEY: And I tried to reach -- I reached
+the authorities in Florida to try to see if they had all the
+interview notes or other things that we can then
+subsequently rely on that might be considered clear and
+convincing evidence, if they had interviewed these women on
+their own, and they never did. No one was cooperative and
+they did not go forward on any of the cases and none of them
+
+
+Case 9:08-cv-80736-KAM Document 106-1 Entered on FLSD Docket 10/10/2011 Page 6 of 16
+page 5
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+were indicted. So I don't know.
+THE COURT: And you spoke to the prosecutor?
+MS. GAFFNEY: The actual prosecutor left the
+office. I spoke to the prosecutor that took over the case.
+THE COURT: Maybe you can find the prosecutor that
+left the office.
+You have done more in other cases looking into it.
+I have never seen the prosecutor's office do this. I have
+to tell you, I am shocked.
+MS. GAFFNEY: Right, but I spoke to the prosecutor
+that took over the case and they don't have anything, any
+affidavits, any statements, any notes.
+THE COURT: Why don't you speak to the prosecutor
+that did do the case, I am sure you could find that
+prosecutor.
+MS. GAFFNEY: I can find her, but based upon what
+the other prosecutor said, they did not speak to that
+prosecutor either.
+THE COURT: You did not speak to the prosecutor
+yourself, you did not speak to them, that is hearsay. You
+did not speak to the prosecutor that handled the case.
+MS. GAFFNEY: That's right.
+THE COURT: I don't think you did much of an
+investigation here.
+MS. GAFFNEY: I mean I called the prosecutor.
+
+
+Case 9:08-cv-80736-KAM Document 106-1 Entered on FLSD Docket 10/10/2011 Page 7 of 16
+page 6
+1
+2
+3
+4
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Even though the first prosecutor left, presumably the
+prosecutor's office has the file.
+THE COURT: I would still call the prosecutor.
+MS. GAFFNEY: Anything from these women they would
+have forwarded it to us.
+THE COURT: I don't know that, I think you have to
+speak to the prosecutor.
+But be that as it may, I hear your argument.
+Anything else?
+MS. GAFFNEY: I mean that is why I don't think we
+can, I don't think we are entitled to rely on this because
+they did not go forward.
+THE COURT: The board made a recommendation.
+MS. GAFNEY: Correct.
+MS. MUSUMECI: May I speak, Your Honor?
+THE COURT: Yes.
+MS. MUSUMECI: Good afternoon.
+I would like to bring a few additional points to
+Your Honor's attention that don't come across in the board
+recommendation.
+The first is that Mr. Epstein is not a resident of
+New York, unlike most of these out of state, he has not
+changed his address and moved to New York, he maintains a
+vacation home in New York. His primary residence is the
+U.S. Virgin Islands.
+
+
+Case 9:08-cv-80736-KAM Document 106-1 Entered on FLSD Docket 10/10/2011 Page 8 of 16
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+page 7
+He is registered in the U.S. Virgin Islands, he
+has been since his release from jail. He notifies the
+Virgin Island authorities every time he leaves that
+jurisdiction. Virgin Island authorities rated him at the
+lowest level of registration.
+He also registered in Florida, which is the state
+of this particular offense, and the only reason that this
+conviction is even before Your Honor.
+The offense for which he was convicted is not a
+registrable offense in New York. He is only registrable
+here arguably because based on the provision of SORA that
+says if a crime is registrable in the state of conviction,
+then it is registrable here in New York. And the Florida
+authorities that considered that rated him at the lowest
+level of their SORA statute.
+He additionally has a vacation home in New Mexico
+and is registered in New Mexico. The New Mexican
+authorities when they considered his offenses, determined he
+need not register at all. Nevertheless, he has voluntarily
+registered with New Mexico and maintains that registration.
+Additionally, because of his possession of a
+vacation home in New York, he has been voluntarily
+registered with New York SOMU, the Sex Offender Monitoring
+Unit since May of this year. He notifies them whenever he
+comes to travel to New York. He never comes to New York for
+
+
+Case 9:08-cv-80736-KAM Document 106-1 Entered on FLSD Docket 10/10/2011 Page 9 of 16
+page 8
+1
+2
+3
+4
+5
+6
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+more than seven days or at least he has not since he has
+been registered. He has no intention to ever be here for
+Tonger than a period of ten days.
+Like I said, he does notify the authorities when
+he is here. He fully understands the reason for voluntary
+registration, he wants to be compliant with the Federal SORA
+law which requires wherever you own a property to register.
+To require Mr. Epstein to register as a Level
+Three offender in New York would actually require him to
+come to New York more than he does normally, it would
+require him to come every 90 days and renew his
+registration.
+He is very diligent in registering with New York
+authorities.
+All of the other jurisdictions that have
+considered his case have determined that he either not
+register at all or register at the lowest level, and he has
+been more than compliant with all of those requirements.
+Your Honor, we would join in the prosecutor's
+application.
+THE COURT: I am sure you would.
+MS. MUSUMECI: By way of background, we have been
+in contact with the prosecutor's office on this matter since
+I believe certainly since Mr. Epstein got his notification,
+which I believe was in August. We have met with the
+
+
+Case 9:08-CV-80736-KAM Document 106-1 Entered on FLSD Docket 10/10/2011 Page 10 of
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+page 9
+prosecutor and provided numerous materials for the
+prosecutor to consider. We have included in that a
+deposition from the detective who headed this investigation
+who acknowledged in a sworn deposition that the lead
+prosecutor who originally had the case, whose name I cannot
+pronounce, Lanna Belohlavek, I apologize for the
+mispronunciation, said to the detective after her
+investigation, there are no real victims here.
+All of the alleged conduct that is cited in the
+board's write up was commercial conduct. All of the alleged
+conduct the women went voluntarily, there are no allegations
+of force certainly none.
+THE COURT: There was no allegation of force in
+the marine either, who met a girl in a bar, a young girl 17,
+there was no force there.
+MS. MUSUMECI: It is our understanding that the
+prosecutor in Florida conducted a full investigation, as
+full as she was able with the cooperation afforded by these
+complainants, and determined that the only case that she
+could present to the grand jury was this indictment for a
+non registrable offense then --
+THE COURT: But it is registrable here.
+I don't know what you mean non registrable
+offense.
+MS. MUSUMECI: Let me explain, Your Honor.
+
+
+Case 9:08-cv-80736-KAM Document 106-1 Entered on FLSD Docket 10/10/2011 Page 11 of
+page 10
+Mr. Epstein plead to two charges, one was an
+indictment which is an offense that is not registrable, it
+is a Florida indictment for --
+THE COURT: Then why does he have to register
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+here?
+MS. MUSUMECI: It was a second offense that he
+plead to --
+THE COURT: That is registrable.
+MS. MUSUMECI: That is registrable.
+That offense was by information and that is the
+only registrable offense, that is what the DA's office is
+considering in doing their scoring.
+The indictment which was the only case that the
+prosecutor even prosecuted through grand jury is not even a
+registrable offense.
+THE COURT: He plead guilty to a registrable
+offense.
+20
+21
+22
+23
+24
+25
+MS. MUSUMECI: Yes.
+THE COURT: What did he plead guilty to?
+MS. GAFFNEY: He plead guilty to the procuring a
+person under 18 for prostitution.
+THE COURT: Procuring a person under 18 for
+prostitution.
+MS. GAFFNEY: Right.
+THE COURT: How old was she?
+
+
+Case 9:08-cv-80736-KAM Document 106-1
+Entered on FLSD Docket 10/10/2011 Page 12 of
+16
+page 11
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MS. GAFFNEY: It appears the first time they met
+she was either 16 or 17, then for the remainder of their
+relationship she was probably 17.
+THE COURT: How long was their relationship?
+MS. GAFFNEY: She met, she gave him approximately
+15 massages, including with sexual contact, and ultimately
+when she is 17 had intercourse with him.
+THE COURT: She is a child.
+MS. MUSUMECI: Your Honor, I would note that under
+SORA it is clear that prostitution offenses are only
+registrable when in fact by clear and convincing evidence
+the women or victim is 17, is under 17.
+THE COURT: Well, she met him at 16, he procured
+her at 16 from what I read.
+MS. MUSUMECI: There is evidence we challenged.
+THE COURT: He plead guilty to that, didn't he?
+MS. MUSUMECI: He plead guilty to under 18, which
+is the law in Florida, which is a different standard than
+what the law is in New York. And there is no evidence,
+there is no clear and convincing evidence as to her specific
+age at the time of the specific conduct.
+THE COURT: Well, the DA just told me she was most
+likely 17, she just said it on the record.
+MS. MUSUMECI: Your Honor, we agree that the
+evidence is that she was 17 on the one occasion she had
+
+
+Case 9:08-cv-80736-KAM Document 106-1
+Entered on FLSD Docket 10/10/2011 Page 13 of
+16
+page 12
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+consensual intercourse with him and 17 is not registrable or
+criminal under New York Taw.
+And the prostitution aspect of having intercourse
+with a 17 year old is not registrable conduct.
+THE COURT: Why does he have to register here?
+MS. GAFFNEY: Because it is a register able
+offense in Florida, New York State board of examiners --
+THE COURT: Recognizes it.
+MS. GAFFNEY: Recognizes it, yes.
+THE COURT: I have had many cases like that where
+it was not registrable here but it was in the state where
+the person came from and New York recognized that.
+MS. MUSUMECI: Your Honor, we are not saying that
+he should not register. Mr. Epstein has already registered
+and recognizes his duty to register.
+THE COURT: I am glad of that, very glad of that.
+I am sorry he may have to come here every 90 days.
+He can give up his New York home if he does not
+want to come every 90 days.
+Anything else?
+I rely on the board.
+MS. MUSUMECI: Your Honor, we would reserve our
+right to appeal Your Honor's ruling.
+THE COURT: Of course, do so.
+MS. GAFFNEY: For the record, Your Honor, he is
+
+
+•
+Case 9:08-CV-80736-KAM Document 106-1 Entered on FLSD Docket 10/10/2011 Page 14 of
+going to be deemed a Level Three sex offender with no
+designation, correct?
+THE COURT: Correct.
+MS. MUSUMECI: For purposes of the appeal I
+believe that Your Honor --
+THE COURT: Give me the board's scoring.
+The board has scored use of violence the least,
+page 13
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+10.
+Sexual contact with victim, 25. I agree.
+Number of victims, three or more. He only plead
+guilty to one, but apparently there were more than one and I
+think the People concede that although they say it was not
+reliable.
+Duration of offense, conduct with victim,
+continuing course of sexual misconduct, the People have told
+me it was continuing for 20 points.
+Age of victim 11 through 16, he got 20 points for
+that, and she was 16 at the time.
+Other victim characteristics, there was no mental
+disable or helplessness. I agree.
+Relationship with victim stranger, 20 points.
+Age at first act of sexual misconduct, 20 or less.
+They scored him zero on that.
+Number and nature of prior crimes, no history,
+they scored him five on that.
+
+
+Case 9:08-cV-80736-KAM Document 106-1 Entered on FLSD Docket 10/10/2011 Page 15 of
+page 14
+Recency of prior offense less than three years,
+they gave him zero.
+Drug or alcohol abuse history, they gave him zero.
+Acceptance of responsibility, they gave him zero.
+Conduct while confined, they gave him zero.
+And supervision, they gave him zero.
+Living employment situation, zero.
+They gave him 130 points, which is the highest
+level, and I agree with that.
+MR. LEFKOWITZ: If I could be heard for one
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+moment.
+It appears that the state board made its
+determination based on access to a police report in Florida.
+The prosecutor, the lead prosecutor, the lead sex
+crimes prosecutor in Palm Beach made a determination that
+the complainants and the police report itself was not
+credible and decided not to prosecute on the basis of all of
+that.
+In addition, there has been through the course of
+the last few years some civil litigation, as you might
+imagine, involving these matters and we now have sworn
+testimony in evidence from the complainants themselves
+disclaiming much of what appears in the police report.
+So, Your Honor, we would submit and this is not to
+make light in any way of the conduct what Mr. Epstein did or
+
+
+Case 9:08-cv-80736-KAM Document 106-1 Entered on FLSD Docket 10/10/2011 Page 16 of
+1
+2
+3
+4
+5
+6
+7
+8
+page 15
+what Mr. Epstein plead guilty to, but with respect to
+everything and that is why Mr. Epstein voluntarily
+registered in New York even though there is a question about
+whether he has any obligation just as a jurisdictional
+matter, but Your Honor, with respect to the appropriate
+level for him to register, we would submit Your Honor that
+the evidence simply does not support the foundation of the
+state's determination.
+THE COURT: You have made a very clear record and
+you have your right to appeal.
+I feel the board looked into all of this, made
+their recommendation, found him to have 130 points and I see
+no reason to disturb that.
+Thank you.
+10
+11
+12
+13
+14
+15
+16
+I, Vikki J. Benkel, a Senior Court Reporter in and for
+17
+the State of New York, do hereby certify that the foregoing
+18
+transcript is true and accurate to the best of my knowledge,
+19| skill and ability.
+20
+22
+23
+24
+25
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/2313fb67601684ba10432236c24e036d6427f06635345747b43a77b2b7240828.receipt.json b/vision-fixhub/ds9-unparsed-06/2313fb67601684ba10432236c24e036d6427f06635345747b43a77b2b7240828.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6faf5f06adf0b25c297f81c91ee2b46d14346983
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2313fb67601684ba10432236c24e036d6427f06635345747b43a77b2b7240828.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -999,
+  "dataset": "marble-joined",
+  "doc_id": "2313fb67601684ba10432236c24e036d6427f06635345747b43a77b2b7240828",
+  "engine": "marble-apple-vision",
+  "event_count": 18,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "d966489bad2b55f63fb5b5ebb76ba5d8316d62a2ad91cf40189221ba7487f08a",
+  "output_sha256": "9ec7df639068c42dcb1c574ae64929856d82e88d494143f0750a10f9bac724a2",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/23b9b6acc58b950e8edaa4e4446250b12705387ec644d44f1b2c2adb56eaaa21.md b/vision-fixhub/ds9-unparsed-06/23b9b6acc58b950e8edaa4e4446250b12705387ec644d44f1b2c2adb56eaaa21.md
new file mode 100644
index 0000000000000000000000000000000000000000..28579047b270b3b999007cd1927a17c578f33d97
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/23b9b6acc58b950e8edaa4e4446250b12705387ec644d44f1b2c2adb56eaaa21.md
@@ -0,0 +1,30 @@
+Date: Wed, 18 Jan 2012 01:26:53 +0000
+Importance: Normal
+Hi Jacquie - I will follow up with
+period?
+Is it possible that you have copies of the Duty Rosters for that time
+Thanks!
+-
+Sent: Tuesday, January 17, 2012 6:48 PM
+Subject: RE: Assistance needed with computer-related discovery of USAO files
+For the highlighted item you need to contact HR.
+I'm going to check what type of documentation is required from EOUSA for them to do the search on the mail
+server. I don't believe Shawn Ball was in the original Lit. Hold
+Sent: Tuesday, January 17, 2012 5:41 PM
+Subject: Assistance needed with computer-related discovery of USAO files
+Hi Jacquie - Several months ago, you and Damaris assisted in collecting email and other files related to the
+investigation and prosecution of Jeffrey Epstein in preparation for possible discovery requests from the
+Petitioners in the matter of Jane Doe #1 and Jane Doe #2 vs. United States. We have received an additional
+request that calls for materials beyond what we had originally discussed, so I am hoping that you can assist me in
+gathering this information.
+Based upon the request, we need to obtain: (1) any emails sent by Bruce Reinhart while he was still an AUSA;
+(2) any emails sent by Bruce Reinhart after he left the U.S. Attorney's Office to any of the following members of
+
+
+the U.S. Attorney's Office/U.S. Department of Justice
+The relevant time period is 1/1/2006 through 12/31/2007.
+Also, if you have available to you any documentation that would show the period when Mr. Reinhart was and
+was not a supervisor in the West Palm Beach office, that information also would be useful.
+And if there are any electronic calendars for Mr. Reinhart or for these other individuals that show
+meetings/telephone contact with Mr. Reinhart, those should be produced.
+Thank you so much for your assistance.
diff --git a/vision-fixhub/ds9-unparsed-06/23b9b6acc58b950e8edaa4e4446250b12705387ec644d44f1b2c2adb56eaaa21.receipt.json b/vision-fixhub/ds9-unparsed-06/23b9b6acc58b950e8edaa4e4446250b12705387ec644d44f1b2c2adb56eaaa21.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..70e140335dca0e7a72e29741f15094f05bbbb325
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/23b9b6acc58b950e8edaa4e4446250b12705387ec644d44f1b2c2adb56eaaa21.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "23b9b6acc58b950e8edaa4e4446250b12705387ec644d44f1b2c2adb56eaaa21",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "a6adeb6098a953d513250bddd6ce7f788cb372cdb974f52419b0f75c305fbaf1",
+  "output_sha256": "e84faf2de13440d3cab423adbdcb34648c495864caa9b26ec4022f6496725954",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/23f635df2425f4c22efc84217bb53e7ba571214ab6c3f4eb544728f54b43d388.md b/vision-fixhub/ds9-unparsed-06/23f635df2425f4c22efc84217bb53e7ba571214ab6c3f4eb544728f54b43d388.md
new file mode 100644
index 0000000000000000000000000000000000000000..4b705f05f7c84b694c1416a5feee560b89e2d756
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/23f635df2425f4c22efc84217bb53e7ba571214ab6c3f4eb544728f54b43d388.md
@@ -0,0 +1,25 @@
+Formatted Name
+Lilly Ann Sanchez
+Address • Work
+Miami, Florida 33131-3300
+United States of America
+Address • Worki
+Miami, Florida 33131-3300
+United States of America
+Email
+Full Address • Work
+Miami Florida 33131-3300
+Full Address • Work
+Miami Florida 33131-3300
+Name
+Lilly Sanchez (Ann)
+Telephone Number • Work
+Telephone Number • Fax, Work
+VCard Version
+3.0
+Website URL • Work
+http://www.fowler-white.com
+COMPANY
+Fowler White Burnett;
+
+
diff --git a/vision-fixhub/ds9-unparsed-06/23f635df2425f4c22efc84217bb53e7ba571214ab6c3f4eb544728f54b43d388.receipt.json b/vision-fixhub/ds9-unparsed-06/23f635df2425f4c22efc84217bb53e7ba571214ab6c3f4eb544728f54b43d388.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..cbf19651cec7ac2c38f4f38cae6aeeca6ec09d71
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/23f635df2425f4c22efc84217bb53e7ba571214ab6c3f4eb544728f54b43d388.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "23f635df2425f4c22efc84217bb53e7ba571214ab6c3f4eb544728f54b43d388",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "385c76d7ecef365811be2a2752c53ed6ea4c2e85479a4f29b46c0199d4ed13ad",
+  "output_sha256": "993bc644e6b5d57a8d432b65a9483b46cfb3045cdfb7dd0549a1cdb52e461eb2",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/242b9113d514967d2c7cb19330f8e8882f46f3c1f50905085957bd5d896704ee.md b/vision-fixhub/ds9-unparsed-06/242b9113d514967d2c7cb19330f8e8882f46f3c1f50905085957bd5d896704ee.md
new file mode 100644
index 0000000000000000000000000000000000000000..59902b820f3913a7976cc5f57ac2ce929c3d7c9b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/242b9113d514967d2c7cb19330f8e8882f46f3c1f50905085957bd5d896704ee.md
@@ -0,0 +1,7 @@
+Subject: Re: Memo re Epstein
+Date: Tue, 26 Jul 2011 13:17:59 +0000
+Importance: Normal
+I think basis of the conflict is the main issue but maybe add a paragraph on the leads. Thanks.
+Sent: Tuesday, July 26, 2011 09:14 AM
+Subject: Memo re Epstein
+Hi Ben - Do you want me to summarize the basis for the conflict or the new leads or both?
diff --git a/vision-fixhub/ds9-unparsed-06/242b9113d514967d2c7cb19330f8e8882f46f3c1f50905085957bd5d896704ee.receipt.json b/vision-fixhub/ds9-unparsed-06/242b9113d514967d2c7cb19330f8e8882f46f3c1f50905085957bd5d896704ee.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..eed3235d4087f567af8706a9e522b1ad15174a75
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/242b9113d514967d2c7cb19330f8e8882f46f3c1f50905085957bd5d896704ee.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "242b9113d514967d2c7cb19330f8e8882f46f3c1f50905085957bd5d896704ee",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "1d644932485bfca976d6a935579a9f2e7b4eefdcbb9cb185fa28a6ed89de3e25",
+  "output_sha256": "9d1fe92be3481b4dae59c88c9d00c34f77db9f5d08e0e66d606654684ceb05b5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/25f56c88b27f8b3db11e23c6618dc79fe655f6b79e5516fb38c04d449c6de1d6.md b/vision-fixhub/ds9-unparsed-06/25f56c88b27f8b3db11e23c6618dc79fe655f6b79e5516fb38c04d449c6de1d6.md
new file mode 100644
index 0000000000000000000000000000000000000000..81b01ba98dadb842fabcadac0937818435da2890
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/25f56c88b27f8b3db11e23c6618dc79fe655f6b79e5516fb38c04d449c6de1d6.md
@@ -0,0 +1,12 @@
+From: "
+• (USAFLS)" <
+To:
+Subject: Epstein
+Date: Tue, 12 Jan 2010 15:22:29 +0000
+Importance: Normal
+Attachments: 20100111143503.pdf
+Hi Barbara - This was just sent to me by someone in my office. In light of other instances where Mr. Epstein's
+counsel has falsely represented that something was agreed to, I just wanted to check with you to make certain
+that you were aware of, and joined in, the motion. Can you let me know?
+Thank you. (And Congratulations on your promotion!)
+<<20100111143503.pdf>>
diff --git a/vision-fixhub/ds9-unparsed-06/25f56c88b27f8b3db11e23c6618dc79fe655f6b79e5516fb38c04d449c6de1d6.receipt.json b/vision-fixhub/ds9-unparsed-06/25f56c88b27f8b3db11e23c6618dc79fe655f6b79e5516fb38c04d449c6de1d6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..bbc3a8e7e304e53cdf1359952b8a9131cf5fe1e0
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/25f56c88b27f8b3db11e23c6618dc79fe655f6b79e5516fb38c04d449c6de1d6.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "25f56c88b27f8b3db11e23c6618dc79fe655f6b79e5516fb38c04d449c6de1d6",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "1dd15089d6fa3daadce836af2f6385e42cbdd59a0d3d642f894cfa84881b5edc",
+  "output_sha256": "6d17e3c506744561cc04898a8caf888b0003b063858567062032fd57c17b37d4",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2628a2d0888eba346bf7c3b56c93ca7a321694a6256f054509e8626e829f9330.md b/vision-fixhub/ds9-unparsed-06/2628a2d0888eba346bf7c3b56c93ca7a321694a6256f054509e8626e829f9330.md
new file mode 100644
index 0000000000000000000000000000000000000000..1e98dc26921a302c8eeee42a08f1bb31ebdead6d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2628a2d0888eba346bf7c3b56c93ca7a321694a6256f054509e8626e829f9330.md
@@ -0,0 +1,60 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80119-KAM Doe |. Epstein Order
+Date: Thu, 28 Jan 2010 13:46:23 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+pply to all other users. To avoid later charges, download a copy of each document during this firs
+iewing. However, if the referenced document is a transcript, the free copv and 30 page limit do not appl
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 1/28/2010 at 8:46 AM EST and filed on 1/27/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 455
+Doe | Epstein
+9:08-cv-80119-KAM
+Docket Text:
+ORDER Affirming Magistrate Judge Johnson's Discovery Order; denying [327] Appeal of
+Magistrate Judge Decision to District Court filed by Jane Doe. Signed by Judge Kenneth A.
+Marra on 1/27/2010. (asl)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz ahorowitz@sexabuseattorney.com
+Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov
+Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com
+Isidro Manuel Garcia
+isidrogarcia@bellsouth.net
+Jack Alan Goldberger
+jagesq@bellsouth.net, nalanis@agwpa.com
+Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com,
+sas@searcylaw.com, vat@searcylaw.com
+Jeffrey Mare Herman jherman@hermanlaw.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+
+
+Michael James Pike MPike@bclclaw.com, bobbie@bclelaw.com, jcadwell@bclelaw.com
+Paul G. Cassell cassellp@law.utah.edu
+Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com
+Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton@podhurst.com,
+mestradal@podhurst.com
+Robert Deweese Critton, Jr rcrit@belclaw.com, bobbie@belclaw.com
+Stuart S. Mermelstein ssm@sexabuseattorney.com, jarbour@sexabuseattorney.com,
+Irivera@sexabuseattorney.com
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+Martin G. Weinberg
+20 Park Plaza
+Boston, MA 02116
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=1/28/2010] [FileNumber=7199590-0
+] [09cb05de068bfb64b868f490084429f52a654dea7f9ad35d7634b6f68920bcle24
+1f17ef29b9902a2068b337449fda962547d4e8dd25bd614606410f760ca8f]]
diff --git a/vision-fixhub/ds9-unparsed-06/2628a2d0888eba346bf7c3b56c93ca7a321694a6256f054509e8626e829f9330.receipt.json b/vision-fixhub/ds9-unparsed-06/2628a2d0888eba346bf7c3b56c93ca7a321694a6256f054509e8626e829f9330.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..34d881b6ee7423cb26a0bc75eca44bc9f9080dfa
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2628a2d0888eba346bf7c3b56c93ca7a321694a6256f054509e8626e829f9330.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "2628a2d0888eba346bf7c3b56c93ca7a321694a6256f054509e8626e829f9330",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "d8b63e4e24d880ac5b273d8740bf09a6260478e423b16e3c2041d10b2223c30e",
+  "output_sha256": "0c49794d1c39190839dae3d2c43c2f9656c198e63897804b00c76b067582aa74",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/265b56f1856caa969e9fb9516b6ff9ca9ad46890d6b6e3c8ccf4ffcadea5b824.md b/vision-fixhub/ds9-unparsed-06/265b56f1856caa969e9fb9516b6ff9ca9ad46890d6b6e3c8ccf4ffcadea5b824.md
new file mode 100644
index 0000000000000000000000000000000000000000..780fafc73a3b5e0f223e085a56218afd6d6f80b3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/265b56f1856caa969e9fb9516b6ff9ca9ad46890d6b6e3c8ccf4ffcadea5b824.md
@@ -0,0 +1,4 @@
+Subject: Accepted: Meeting re: Jane Does I, United States aka Epstein Matter
+Date: Thu, 20 Jun 2013 19:04:48 +0000
+Importance: Normal
+Attachments: unnamed
diff --git a/vision-fixhub/ds9-unparsed-06/265b56f1856caa969e9fb9516b6ff9ca9ad46890d6b6e3c8ccf4ffcadea5b824.receipt.json b/vision-fixhub/ds9-unparsed-06/265b56f1856caa969e9fb9516b6ff9ca9ad46890d6b6e3c8ccf4ffcadea5b824.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9742a6b1acc9e342d55c19baecb43a74268fa2c0
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/265b56f1856caa969e9fb9516b6ff9ca9ad46890d6b6e3c8ccf4ffcadea5b824.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "265b56f1856caa969e9fb9516b6ff9ca9ad46890d6b6e3c8ccf4ffcadea5b824",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "62542ace1e92d483900d4393f7b0a9305bb7db79178c038eda6919a0dda65412",
+  "output_sha256": "8911ba0a4b226a884d6ec3fa8267bb8c010625d6e4c4049f7ce1154b4355264d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/26b6356034cb4b9e71105dda9a94ce1688981d7b05f419e8af8aca8d6fd8e449.md b/vision-fixhub/ds9-unparsed-06/26b6356034cb4b9e71105dda9a94ce1688981d7b05f419e8af8aca8d6fd8e449.md
new file mode 100644
index 0000000000000000000000000000000000000000..040258c6567d54e6e61dcc46e7938cbcbb0e27ba
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/26b6356034cb4b9e71105dda9a94ce1688981d7b05f419e8af8aca8d6fd8e449.md
@@ -0,0 +1,66 @@
+From:
+To: Paul Cassell <
+Cc: "l
+(USAFLS)" <
+| (USAFLS)" ≤
+Subject: RE: Doe | USAO
+Date: Tue, 15 Nov 2011 00:37:05 +0000
+Importance: Normal
+>, Brad Edwards
+Paul and Brad,
+We have no objections as to the extension of time until December 5. Let me check with my colleagues on the
+other issues, and I will let you know tomorrow. Thanks.
+----Original Message----
+From: Paul Cassell [mailto:
+Sent: Monday, November 14, 2011 7:34 PM
+To:
+(USAFLS)
+Cc:
+(USAFLS); Brad Edwards
+Subject: RE: Doe | USAO
+Hey
+and
+1. As you may know, Brad is buried in a three-week jury trial, so I have not been able to consult with him at any
+length about the pending motion to dismiss and to stay. I also have another brief due on next Wednesday, as well
+as long-scheduled vacation the week of Thanksgiving. In light of all this, I am writing to inquire about the
+Government's position concerning a ten-day extension of the due date to respond to the motion to dismiss until
+December 5.
+2. I noticed that you have filed two pleadings entirely under seal - your motion to dismiss and your motion to
+stay. And yet the vast bulk of both motions do not involve any secret grand jury material and thus (in my view)
+there is little reason for the vast bulk of the pleadings to be under seal. Are you willing to file redacted pleadings
+in the public court file?
+3. If the answer to question 2 is no, what is your position on a motion from the victims asking for the court to
+direct the Government to file redacted pleadings in the public court file, redacting only the secret grand jury
+information?
+4. It is our view that a bland motion for extension of time would not need to be filed under seal, because it would
+not disclose any grand jury materials. Here is the draft of our motion for extension of time, which we are not
+planning to file under seal. Please advise if you have any concerns.
+JANE DOE #1 AND JANE DOE #2'S UNOPPOSED MOTION FOR 10-DAY EXTENSION OF TIME TO
+RESPONSE TO GOVERNMENT'S MOTION TO DISMISS AND MOTION FOR STAY OF DISCOVERY
+COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned
+counsel, to file an unopposed motion for extension of time to respond to the Government's motion to dismiss and
+motion to stay proceedings.
+The victims' response to these two motions is currently due on Friday, November 25, 2011 - the Friday
+immediately following Thanksgiving. One of the victims' counsel, Bradley J. Edwards, has been in (and
+continues to be in) a three-week jury trial that has prevented him from turning to the pending motion. The other
+of the victims' counsel, Paul G. Cassell, has a brief due in the Fifth Circuit on November 23, 2011, and also longscheduled vacation the week of Thanksgiving. Accordingly, victims counsel seek a 10-day extension to Monday,
+
+
+December 5, 2011, to file their responses to the Government's two pending motions.
+Counsel have conferred and the Government does not oppose the motion.
+5. I notice in the court file that the Court entered two orders on November 9, 2011. These are sealed orders and
+we have not received notice of the orders. We are assuming that these are court orders granting your motion to
+file under seal. If they are something else, we would of course be concerned about ex parte motion practice. If
+they are granting the motions to file under seal, I wonder why we didn't consult about the extent of the sealing on
+the phone last week -- it does seem like the Government has gone overboard on sealing here, but I am hopeful
+that you will agree to filing redacted pleadings and obviate any problem.
+Thanks for your help on these questions/issues.
+Paul Casssell
+Co-Counsel for Jane Doe #1 and Jane Doe #2
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is
+intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver
+it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have
+received this message in error, please immediately notify the sender by reply electronic mail and delete the
+original message. Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/26b6356034cb4b9e71105dda9a94ce1688981d7b05f419e8af8aca8d6fd8e449.receipt.json b/vision-fixhub/ds9-unparsed-06/26b6356034cb4b9e71105dda9a94ce1688981d7b05f419e8af8aca8d6fd8e449.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..629e4964d8166534e0261a5ba09d2f936987cf3d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/26b6356034cb4b9e71105dda9a94ce1688981d7b05f419e8af8aca8d6fd8e449.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -26,
+  "dataset": "marble-joined",
+  "doc_id": "26b6356034cb4b9e71105dda9a94ce1688981d7b05f419e8af8aca8d6fd8e449",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "87be7a75c6134b7b21e904948a983ca785192fdf9d3fe45a60e77f1fa752edd1",
+  "output_sha256": "541fcd0769213f02d0bc42ce09e9f9efe5a765110137316010bac36474b4e7d3",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/27379a69e6f2b5c3114fc5c263482f8c082b7e495ed2d8b17d0ad1ea6e3eedfa.md b/vision-fixhub/ds9-unparsed-06/27379a69e6f2b5c3114fc5c263482f8c082b7e495ed2d8b17d0ad1ea6e3eedfa.md
new file mode 100644
index 0000000000000000000000000000000000000000..482afc0bc4d4b745c151b6933b61eae8933e33fb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/27379a69e6f2b5c3114fc5c263482f8c082b7e495ed2d8b17d0ad1ea6e3eedfa.md
@@ -0,0 +1,26 @@
+Subject: FW: Confidential
+Date: Mon, 25 Jan 2010 14:47:06 +0000
+Importance: Normal
+Attachments: 20100111143503.pdf
+Please call
+to coordinate a meeting at your convenience. I'll let you decide who else to invite. Thanks,
+From: Alan Dershowitz [mailto:
+Sent: Saturday, January 23, 2010 11:33 AM
+Cc: Alan Dershowitz
+Subject: Confidential
+Dear Jeffrey:
+I hope this note finds you well. On January 11, 2010, I sent you the attached e-mail, following up on our
+discussion in December. I trust you received it. I am now back in miami. I realize you are very busy. I would
+very much appreciate it ,if you could provide some available dates so that Roy, Marty, and I can sit with you
+Cordially,
+From: Alan Dershowitz
+Sent: Mon 1/11/2010 2:25 PM
+subject: conndental
+January 11, 2010
+Dear Jeffrey:
+Happy New Year. I hope this note finds you and your family well. When I met with you, we agreed to try to
+schedule a meeting at the beginning of the new year. In the meantime, I'm sure you're aware that the state
+circuit court had issued an order authorizing Jeffrey Epstein to travel. I attach the order for your convenience.
+I'm back in Boston now for a few days but I look forward to meeting with you in the near future.
+Cordially,
+Alan
diff --git a/vision-fixhub/ds9-unparsed-06/27379a69e6f2b5c3114fc5c263482f8c082b7e495ed2d8b17d0ad1ea6e3eedfa.receipt.json b/vision-fixhub/ds9-unparsed-06/27379a69e6f2b5c3114fc5c263482f8c082b7e495ed2d8b17d0ad1ea6e3eedfa.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..66f68d6254d87932e24eae339cc7804130c04571
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/27379a69e6f2b5c3114fc5c263482f8c082b7e495ed2d8b17d0ad1ea6e3eedfa.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "27379a69e6f2b5c3114fc5c263482f8c082b7e495ed2d8b17d0ad1ea6e3eedfa",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "de057e7b48da619887b1430dcea86818d644168fe7df4bda6d2db765d46a2d92",
+  "output_sha256": "da47546e0d110bd3793db36a7e33b2db8c137f9fcac0b1f015e76c16ae3245dd",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/27918573ea8ece9dc8f0e830efc46e70c9cb018c2488a6d1c3d1d8e4762d8ea7.md b/vision-fixhub/ds9-unparsed-06/27918573ea8ece9dc8f0e830efc46e70c9cb018c2488a6d1c3d1d8e4762d8ea7.md
new file mode 100644
index 0000000000000000000000000000000000000000..fbd796ab5e272f3b6139acbb9c89dcfeff85b77d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/27918573ea8ece9dc8f0e830efc46e70c9cb018c2488a6d1c3d1d8e4762d8ea7.md
@@ -0,0 +1,8 @@
+From:
+To: "Sloman, Jeff (USAFLS)"
+Subject: Latest on Epstein
+Date: Tue, 25 Jul 2006 12:27:55 +0000
+Importance: Normal
+http://www.palmbeachpost.com/search/content/local_news/epaper/2006/07/25/m4b_EPSTEIN_0725.html
+I will get a copy of the indictment and the "report" that Palm Beach police is issuing and fax them to you.
+Assistant U.S. Attorney
diff --git a/vision-fixhub/ds9-unparsed-06/27918573ea8ece9dc8f0e830efc46e70c9cb018c2488a6d1c3d1d8e4762d8ea7.receipt.json b/vision-fixhub/ds9-unparsed-06/27918573ea8ece9dc8f0e830efc46e70c9cb018c2488a6d1c3d1d8e4762d8ea7.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..eb42d88cb4c098efc0669c6a3382c1348bc8f866
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/27918573ea8ece9dc8f0e830efc46e70c9cb018c2488a6d1c3d1d8e4762d8ea7.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "27918573ea8ece9dc8f0e830efc46e70c9cb018c2488a6d1c3d1d8e4762d8ea7",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "92a465ab9fb4bb4c5f90f019b4833f8d9815d5d8ba786a87d5b989fa331b0b62",
+  "output_sha256": "be9f84499f09f591e3cc09cdb6af2c0567e4b4b82d4e5ace11d43abb5731f658",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2853add3ad7fd9b70ab113418359d9714a31f83a5ce6b3f9d4cf6e1e8765368b.md b/vision-fixhub/ds9-unparsed-06/2853add3ad7fd9b70ab113418359d9714a31f83a5ce6b3f9d4cf6e1e8765368b.md
new file mode 100644
index 0000000000000000000000000000000000000000..33f815e19180bc7846d5fc73b10c6b5663c858c3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2853add3ad7fd9b70ab113418359d9714a31f83a5ce6b3f9d4cf6e1e8765368b.md
@@ -0,0 +1,13 @@
+From: "
+(USAFLS)"
+To: "
+Subject: Epstein
+Date: Tue, 07 Aug 2007 16:04:59 +0000
+Importance: Normal
+@usdoj.gov>
+Hi
+- I don't know how much and
+•have been keeping you in the loop, so let me know if you need
+any info or if you just want to talk before the meeting.
+Thanks.
+Assistant U.S. Attorney
diff --git a/vision-fixhub/ds9-unparsed-06/2853add3ad7fd9b70ab113418359d9714a31f83a5ce6b3f9d4cf6e1e8765368b.receipt.json b/vision-fixhub/ds9-unparsed-06/2853add3ad7fd9b70ab113418359d9714a31f83a5ce6b3f9d4cf6e1e8765368b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..17e31b0d71069770cefddff5f501bbc0d8a8b1a7
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2853add3ad7fd9b70ab113418359d9714a31f83a5ce6b3f9d4cf6e1e8765368b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "2853add3ad7fd9b70ab113418359d9714a31f83a5ce6b3f9d4cf6e1e8765368b",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "9ed4072c7031017a538e4c308a5b49d45fe738c9a5bacc4a6b5e71b5fe48b5da",
+  "output_sha256": "585e7460813f2ccc0caebcc7d4e5bb3f99fecbdd12e6a5d10378720b00d3abe7",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/28817a6722e7df751e249c9ad141558fecf20d8518d9389c4e991059c272c8cf.md b/vision-fixhub/ds9-unparsed-06/28817a6722e7df751e249c9ad141558fecf20d8518d9389c4e991059c272c8cf.md
new file mode 100644
index 0000000000000000000000000000000000000000..c55c57a95b411fc6559c5bc3e7c05d10388bc7c4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/28817a6722e7df751e249c9ad141558fecf20d8518d9389c4e991059c272c8cf.md
@@ -0,0 +1,141 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA
+JANE DOE #1 and JANE DOE #2,
+Petitioners,
+VS.
+UNITED STATES,
+Respondent.
+RESPONDENT'S REPLY TO PETITIONERS' RESPONSE
+TO RESPONDENT'S SEALED MOTION TO STAY DISCOVERY
+PENDING RULING UPON RESPONDENT'S MOTION TO DISMISS [DE 129]
+AND RESPONDENT'S RESPONSE IN OPPOSITION
+TO PETITIONERS' PROTECTIVE MOTION TO COMPEL [DE 130]
+Respondent, by and through its undersigned counsel, hereby files this Reply to Petitioner Jane Doe #1
+and Jane Doe #2's Response to the Respondent's Sealed Motion to Stay Discovery Pending Ruling upon
+Respondent's Motion to Dismiss [DE129] and Response in Opposition to Petitioners' Protective Motion to
+Compel [DE 130]. For the following reasons and the reasons set forth in Respondent's Motion to Stay
+Discovery, the Court should grant the United States' Motion to Stay Discovery pending the Court's decision on
+the United States' Motion to Dismiss for Lack of Subject Matter Jurisdiction and, similarly, deny the Petitioners"
+Protective Motion to Compel.
+In both their Response to the Motion to Stay Discovery and their Motion to Compel, Petitioners fail to
+cite any statute or case law that supports their position that the Court should order the United States to produce
+discovery while a motion to dismiss for lack of subject matter jurisdiction is pending. The Eleventh Circuit has
+clearly and repeatedly stated that dispositive motions should be decided before discovery begins:
+Facial challenges to the legal sufficiency of a claim or defense, such as a motion to dismiss based
+on failure to state a claim for relief, should, however, be resolved before discovery begins. Such a
+dispute always presents a purely legal question; there are no issues of fact because the allegations
+in the pleading are assumed to be true. ... Therefore, neither the parties nor the court have any
+need for discovery before the court rules on the motion. ... [D]iscovery imposes several costs on
+the litigant from whom discovery is sought. These burdens include the time spent searching for
+and compiling relevant documents; the time, expense, and aggravation of preparing for and
+attending depositions; the costs of copying and shipping documents; and the attorneys fees f
+generated in interpreting discovery requests, drafting responses to interrogatories and
+coordinating responses to production requests, advising the client as to which documents should
+be disclosed and which ones withheld, and determining whether certain information is privileged.
+Chudasama | Mazda Motor Corp. , 123 F.3d 1353, 1367 (11th Cir. 1997) (citations omitted). See also Moore |
+Potter, 141 Fed. Appx. 803, 807-08 (11th Cir. 2005) (quoting Chudasama at 1367, 1368) (affirming district
+court's decision to stay proceedings, including all discovery, pending ruling on defendant's 12(b)(6) motion to
+dismiss); Cheshire | Bank of America, 351 Fed. Appx. 386, 388 (11th Cir. 2009) (citing Chudasama at 1367)
+("a plaintiff has no right to discovery upon the filing of a motion to dismiss that raises a purely legal question");
+
+
+Horsley | Feldt , 304 F.3d 1125, 1131 n.2 (11th Cir. 2002) (affirming district court's decision to suspend
+discovery pending resolution of motion for judgment on the pleadings); Smith | Potter, 400 Fed. Appx. 806,
+812 (5th Cir. 2010) (affirming district court's stay of discovery pending a motion to dismiss for lack of subject
+matter jurisdiction); Cotton I Massachusetts Mut. Life Ins. Co., 402 F.3d 1267 (11th Cir. 2005) (noting that
+because every claim has the potential to enlarge the scope and cost of discovery, the need to resolve a facially
+challenged claim before discovery is based on the extent to which the claim expands discovery).
+The concerns raised in Chudasama and its progeny are present here. The motion to dismiss for lack of
+subject matter jurisdiction is dispositive of the entire case. Thus, staying discovery until the Court rules will save
+the entire cost related to discovery, if the Court rules that it lacks jurisdiction. As noted in the United States
+Motion to Stay, the discovery requests that have been propounded by Petitioners far exceed the Court's directive
+that they could "conduct limited discovery in the form of document requests and requests for admissions from
+the U.S. Attorney's Office" in order to allow " limited factual development." (DE 99 at 11 (emphasis added).)
+The Court ordered that the discovery should address only "whether the particular [CVRA] rights asserted here
+attached and, if so, whether the U.S. Attorney's Office violated those rights." (Id. at 10.) Instead the document
+requests and the later-served requests for admissions seek documents and information pertaining to the criminal
+investigation of Jeffrey Epstein, including the prosecution memo and drafts of the indictment prepared in the
+case, which are governed by the grand jury secrecy rules. See Request for Production No. 1. Petitioners also
+seek discovery regarding events that occurred long after the negotiation of the Non-Prosecution Agreement and,
+in fact, long after the Petitioners filed their action. For example, in Requests 17 and 18, Petitioners ask for
+documents and correspondence created as recently as August 2011, approximately three years after the latest of
+the relevant facts in the case. Petitioners request the production of information and documents that would violate
+the attorney-client privilege, the work product doctrine, the deliberative process privilege, and the privacy rights
+of other victims identified in the case. Merely collecting all of the requested materials, cataloguing them, and
+asserting the various privileges is a tremendous undertaking. Furthermore, unlike a Rule 12(b)(6) motion, the
+government's motion alleges that the Court lacks jurisdiction - that is, the power - to hear the case. Respondent
+is the United States, an entity that normally has immunity from suit and, hence, from discovery obligations.
+Requiring the United States to engage in the overly burdensome discovery that the Petitioners have requested,
+prior to reaching a determination that the Court has jurisdiction over the subject matter of this dispute, is contrary
+to both the letter and the spirit of Chudasama and Cotton, supra.
+
+
+Petitioners' sole argument is their assertion that the United States has filed its Motion to Dismiss as a
+"stall tactic" and their allegation that the United States has refused to agree to any facts in this case. First, as has
+been repeatedly asserted, the United States has tried on many occasions to reach agreed statements of fact with
+Petitioners, and is continuing to do so. The difficulty lies in the editorial narratives added by counsel. If the
+Court should rule against the United States on its Motion to Dismiss, the United States continues to hope that a
+set of Stipulated Facts can be reached. Second, the United States has agreed to provide some information to
+Petitioners even during the pendency of the stay and is undertaking a search for that information. Third, the
+Court has before it a Motion related to whether the Petitioners can use documents and information that they
+received via discovery from other lawsuits in this litigation, as well as briefing related to Roy Black, et al.'s
+motion asserting a work product privilege. Much of the relevant material cannot be made available until the
+Court has ruled on those motions.
+Lastly, in their Response to the Motion to Stay and in their Protective Motion to Compel, Petitioners ask
+the Court to Order that within fourteen days of the denial of either the Motion to Stay or the Motion to Dismiss,
+the government should be ordered to provide:
+(1) the Government's initial disclosures pursuant to Fed. R. Civ. P. 26(a)(1);
+(2) answers to the requests for admissions;
+(3) all documents, correspondence, and other information that the Government distributed to persons or
+entities outside of the federal government or received from persons or entities outside of the federal government;
+(4) all documents, correspondence, and other information covered by the victims' discovery request that
+is not subject to a claim of privilege;
+(5) a privilege log.
+(See DE 129 at 3.)
+Here again, Petitioners have attempted to go beyond the Court's Order, which allowed only "limited
+discovery." As the Court acknowledged, this is not a civil case, it is a proceeding under the CVRA, which is
+meant to accompany criminal litigation. As such, the Federal Rules of Civil Procedure do not apply, including
+the initial disclosure rules at Fed. R. Civ. P. 26(a)(1). E2 The third request, for all documents distributed to
+persons outside the government or received from persons outside the government, is not limited by date, subject
+matter, recipient, sender, or otherwise. As written, it calls for virtually every piece of paper and document in
+electronic storage within the "federal government" that has ever been shown to any third party.
+
+
+Rather than provide an exhaustive accounting of all of the objections to the discovery requests at this
+time, the United States means only to show that there are numerous objections that are legally cognizable.
+Accordingly, the United States respectfully requests that the Court deny the Petitioners' Protective Motion to
+Compel and Order that, within 30 days following the Court's denial of the Motion to Stay, the United States must
+serve any responses and/or objections to the Petitioners' Requests for Admissions and First Request for
+Production.
+CONCLUSION
+For the foregoing reasons, the United States respectfully requests that the Court:
+(1) grant the United States" Motion to Stay Discovery Pending Ruling upon Respondent's Motion to
+Dismiss; and
+(2) deny Petitioners' Protective Motion to Compel.
+Respectfully submitted,
+WIFREDO A. FERRER
+UNITED STATES ATTORNEY
+By: _s/
+CERTIFIC
+The undersigned hereby certifies and affirms that a copy of the foregoing was served via the Court's
+CM/ECF system this 24th day of January, 2012, upon Counsel for Petitioners Jane Doe #1 and Jane Doe #2
+Jane Does 1 and 2 | United States
+Case No. 08-80736-CIV-MARRA
+United States District Court, Southern District of Florida
+Bradley Edwards, Esq.,
+Farmer Jaffe Weissing Edwards Fistos Lehrman
+135 N Andeanne Arra Qia 3
+Paul G. Cassell
+\L Onionar Collare afl amat th
+
+
+3390
+Attorneys for Jane Doe # 1 and Jane Doe # 2
+Although the Respondent is represented by the U.S. Attorney's Office and, accordingly, does not pay
+attorneys' fees for its representation, the Court should consider the "costs" to the Office and the public by having
+criminal prosecutors and civil litigators devoting the tremendous amount of time required to respond to the
+overbroad requests of the Petitioners in lieu of investigating and prosecuting criminal defendants or affirmative
+civil cases.
+Although the United States objects to the application of Fed. R. Civ. P. 26(a)(1), part of what it has
+agreed to voluntarily provide is some, but not all, of the information called for by this Rule.
diff --git a/vision-fixhub/ds9-unparsed-06/28817a6722e7df751e249c9ad141558fecf20d8518d9389c4e991059c272c8cf.receipt.json b/vision-fixhub/ds9-unparsed-06/28817a6722e7df751e249c9ad141558fecf20d8518d9389c4e991059c272c8cf.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a3c763ba538cb26ff4aac9bb247295a466fb72e7
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/28817a6722e7df751e249c9ad141558fecf20d8518d9389c4e991059c272c8cf.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -60,
+  "dataset": "marble-joined",
+  "doc_id": "28817a6722e7df751e249c9ad141558fecf20d8518d9389c4e991059c272c8cf",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "dfa40ccdce6c7487306d8e26f17f822c6c8f5cd07986e1ea67d01b2f96c771b0",
+  "output_sha256": "6720a82b0bbe3765548747ad9ed272526cd42fa2bf7cafe8fd65a850e24b5c66",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2888fe11d35526b22c3cac5e68f72991d99a58a45ba90a1ae10534dee0e335e4.md b/vision-fixhub/ds9-unparsed-06/2888fe11d35526b22c3cac5e68f72991d99a58a45ba90a1ae10534dee0e335e4.md
new file mode 100644
index 0000000000000000000000000000000000000000..28fdf002e9b06f58c0254f4b9bc69074adae7ab6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2888fe11d35526b22c3cac5e68f72991d99a58a45ba90a1ae10534dee0e335e4.md
@@ -0,0 +1,84 @@
+From:
+To:
+- (USAFLS)" -
+(USAFLS)" <
+Subject: RE: CVRA case
+Date: Tue, 12 Oct 2010 20:49:04 +0000
+Importance: Normal
+I agree with your statement. I thought that you had framed our initial response to their complaint in terms of
+"mootness," but your response has reminded me that you didn't say it was moot, just that the Court had no
+authority to set aside the non-prosecution agreement.
+I will watch CM/ECF while you are at the NAC.
+Assistant U.S. Attorney
+Fax
+From:
+(USAFLS)
+Sent: Tuesday, October 12, 2010 4:46 PM
+To:
+1. (USAFLS)
+Subject: RE: CVRA case
+A moot case is one where there is no longer any dispute for which the court can grant relief. If their previous conduct is
+any indication, plaintiffs will probably assert that the CVRA obligated the government to consult with them prior to
+entering into the non-prosecution agreement. They seem to be resigned to the fact that the court cannot or will not set
+aside the non-prosecution agreement, since the relief plaintiffs seek is a declaratory judgment. I don't believe we can
+argue there is no longer any dispute between the parties.
+I agree that plaintiffs' leisurely pace in conducting the litigation has undermined the vitality of their case, but the issue is
+whether there is still a live controversy between plaintiffs and the government. Plaintiffs will no doubt dispute the
+government's contention that the court has no authority to grant relief. Moreover, a declaratory judgment is a form of
+relief. I will take a closer look at the caselaw to determine if we can advance a good faith mootness argument.
+I will be at the NAC next week. I intend to tell Judge Cassell that the government has no objection to stipulating to facts
+which we agree are correct, but we don't agree plaintiffs are entitled to any relief since we did not violate the CVRA.
+Please let me know what you think
+From:
+• (USAFLS)
+Sent: Tuesday, October 12, 2010 4:23 PM
+To:
+I (USAFLS)
+Subject: RE: CVRA case
+But isn't the judge asking why they haven't prosecuted the case in 2 years?
+The passage of time makes their case even more moot than it was before, don't you think?
+
+
+Assistant U.S. Attorney
+Fax
+From:
+I (USAFLS)
+Sent: Tuesday, October 12, 2010 3:58 PM
+To: L
+1. (USAFLS)
+Subject: FW: CVRA case
+This is plaintiffs' response to the order to show cause.
+From: Paul Cassell [mailto:
+Sent: Tuesday, October 12, 2010 3:47 PM
+To:
+I (USAFLS)
+Cc: Brad Edwards
+Subject: CVRA case
+Hi
+(if I may),
+I believe we have communicated electronically before. As you probably know, I am co-counsel with Brad Edwards on the
+CVRA case concerning the Epstein (non) prosecution.
+You will have seen Judge Marra's order today asking for us to explain the current situation on the CVRA case by October
+23. By October 23, we plan to file a motion asking the court to declare that there were violations of the CVRA. We will be
+doing that on the basis of a set of fact in the case, of course.
+I am writing to see if you would be interested in working with us on a stipulated set of facts? We will be in a position to
+give you a set of facts early to middle of next week. Would you be able to look at them quickly and let us know which facts
+are not dispute?
+Thanks in advance for your cooperation on narrowing the factual issues in this case and any idea for helping the case to
+progress smoothly.
+Sincerely,
+Paul Cassell
+Counsel for Jane Does
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+S.J. Quinney College of Law at the University of Utah
+Voice:
+Fax:
+Email:
+http://www.law.utah.edu/profiles/default.asp?PersonlD=578name=Cassell,Paul
+
+
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only
+for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended
+recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error,
+please immediately notify the sender by reply electronic mail and delete the original message. Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/2888fe11d35526b22c3cac5e68f72991d99a58a45ba90a1ae10534dee0e335e4.receipt.json b/vision-fixhub/ds9-unparsed-06/2888fe11d35526b22c3cac5e68f72991d99a58a45ba90a1ae10534dee0e335e4.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e450edb5841bfadfe42239b4a2adb3142f98bec8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2888fe11d35526b22c3cac5e68f72991d99a58a45ba90a1ae10534dee0e335e4.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "2888fe11d35526b22c3cac5e68f72991d99a58a45ba90a1ae10534dee0e335e4",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "23cca099350693a5aebc4586fd1ef639529b5e4be426861722c9ca8ad5fa237f",
+  "output_sha256": "d9b3bb342666c7c4f3cdc71ec8f33876e69fe8a3dcd28c397994a1f33f059711",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/28c831b1289412711bfff7814d110532d2ed4ed8bca7a596d673b2d5433a2043.md b/vision-fixhub/ds9-unparsed-06/28c831b1289412711bfff7814d110532d2ed4ed8bca7a596d673b2d5433a2043.md
new file mode 100644
index 0000000000000000000000000000000000000000..a3e5710704c2e96f5a57cbb9a614d55c8a712616
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/28c831b1289412711bfff7814d110532d2ed4ed8bca7a596d673b2d5433a2043.md
@@ -0,0 +1,90 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOE #1 and JANE DOE #2
+1.
+UNITED STATES
+JANE DOE #1 AND JANE DOE #2'S MOTION TO SUPPLEMENT AUTHORITIES IN
+SUPPORT OF THEIR MOTION FOR ANO ORDER DIRECTING THE U.S.
+ATTORNEY'S OFFICE NOT TO WITHHOLD RELEVANT EVIDENCE
+COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and
+through undersigned counsel, to move to supplement their authorities in support of their Motion
+for an Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (doc. #50)
+with a letter just received from the Justice Department's Office of Professional Responsibility.
+As the Court is aware, briefing on the victims' motion for an order directing the
+government not to withhold evidence was completed when the victims filed their reply
+memorandum on May 2, 2011. On May 10, 2011, however, victims" counsel received a letter
+from the Justice Department's Office of Professional Responsibility (attached as exhibit 1) that
+they wish to have the Court consider along with their pleading. This letter makes clear that the
+Government has in its possession information that will be helpful to the victims" case and further
+that the Government is not currently investigating these issues. Because this letter arrived only
+after the filing of their reply, the victims request leave to supplement their pleadings with this
+letter.
+1
+
+
+A bit of context may be useful. On December 10, 2010, Jane Doe #1 and her legal
+counsel, Brad Edwards and Paul Cassell, met in Miami with the Wilfredo Ferrer, United States
+Attorney for the Southern District of Florida; Ben Greenburg, First Assistant U.S. Attorney;
+line
+prosecutor on the Epstein matter. Without going into the details of that settlement discussion,
+the result of that meeting was a few days later, Mr. Ferrer sent a request to the Justice
+Department's Office of Professional Responsibility to investigate and determine whether any
+misconduct had occurred during the Epstein investigation and prosecution. Victim's counsel
+thereafter repeatedly requested information about the status of the investigation and received no
+information.
+On May 10, 2011, however, victims' counsel received a letter from OPR concluding that
+OPR had "completed an inquiry" into the issue and had decided not to investigate. The letter
+acknowledged that the Office had made an inquiry into the fact, but explained that it is "the
+policy of this Office to refrain from investigating issues or allegations that were, are being, or
+could have been addressed in the course of litigation ..." The letter noted that because the
+issues surrounding the Office's negotiation of the NPA were being litigated in this very case, it
+was not consistent with OPR policy to further investigate.
+The victims wish to include this letter as supplemental authority in support of their
+motion for an order directing the U.S. Attorney's Office not to withhold relevant information.
+The letter makes clear that it is only before this Court that such issues can be adjudicated. The
+letter further makes clear the stark bottom line of the pending motion - at least two Justice
+Department components (the U.S. Attorney's Office for the Southern District of Florida and the
+2
+
+
+Office of Professional Responsibility) have both reviewed the issues surrounding the Epstein
+case and have bundled together information regarding the case. And yet, on the basis that the
+victims are litigating before this Court, the Justice Department refuses to conduct its own
+investigation into what happened. The letter thus makes clear that if the Government is allowed
+to withhold relevant evidence from the victims" in this case, there will never a full understanding
+of why the Government violated the victims' rights and why it offered such an extraordinarily
+lenient non-prosecution agreement to Epstein without the victims' knowledge. For all these
+reasons, the letter strongly supports the victims' motion that the Court should enter an order
+directly the Government not to withhold evidence.
+The Government takes the position that -
+Accordingly, the Court should allow the victims' to supplement the authorities in support
+of their motion for an order directing the Government not to withhold evidence with the attached
+letter from OPR
+DATED: May 17, 2011
+Respectfully Submitted,
+s/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+and
+3
+
+
+Paul G. Cassell
+Attorneys for Jane Doe #1 and Jane Doe #2
+
+
+CERTIFICATE OF SERVICE
+The foregoing document was served on May 17, 2011, on the following using the Court's
+CM/ECF system:
+Roy Black, Esq.
+Jackie Perczek, Esq.
+Black, Srebnick, Kornspan & Stumpf, P.A.
+Martin G. Weinberg, P.C.
+30 Darl. Dlana
+1017] 20093020
+Joseph L. Ackerman, Jr.
+5
+
+
diff --git a/vision-fixhub/ds9-unparsed-06/28c831b1289412711bfff7814d110532d2ed4ed8bca7a596d673b2d5433a2043.receipt.json b/vision-fixhub/ds9-unparsed-06/28c831b1289412711bfff7814d110532d2ed4ed8bca7a596d673b2d5433a2043.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f5817e5c442e75c9df4056d67d56be35e0b655ab
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/28c831b1289412711bfff7814d110532d2ed4ed8bca7a596d673b2d5433a2043.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -72,
+  "dataset": "marble-joined",
+  "doc_id": "28c831b1289412711bfff7814d110532d2ed4ed8bca7a596d673b2d5433a2043",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "a65f9a95f4915fe14cc1aa8ff3a4ea52a98b8664f333029d3220739d4e813560",
+  "output_sha256": "ff46d31f827bfe7eedcd70684c4aa57f8b368cc5ba108f751a917a791018c010",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/28d4b339e7b59d8217f99f9c9511dc36cf7b0a30abb61431ad9b7dc56a253097.md b/vision-fixhub/ds9-unparsed-06/28d4b339e7b59d8217f99f9c9511dc36cf7b0a30abb61431ad9b7dc56a253097.md
new file mode 100644
index 0000000000000000000000000000000000000000..68caa5e0a389f646bc47be510a45714d6df379fc
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/28d4b339e7b59d8217f99f9c9511dc36cf7b0a30abb61431ad9b7dc56a253097.md
@@ -0,0 +1,73 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80893-KAM Doe |. Epstein Motion for Protective Order
+Date: Thu, 02 Sep 2010 20:20:39 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Sanchez, Lilly Ann on 9/2/2010 at 4:20 PM EDT and filed on 9/2/2010
+Case Name:
+Doe | Epstein
+Case Number:
+9:08-cv-80893-KAM
+Filer:
+Jeffrey Epstein
+WARNING: CASE CLOSED on 07/20/2010
+Document Number: 214
+Docket Text:
+Defendant's MOTION for Protective Order and Objection to Disclosure of Certain Documents
+with Integrated Memorandum of Law by Jeffrey Epstein. (Attachments: # (1) Exhibit Joint
+Stipulation, # (2) Exhibit Notice of Intent to Use, # (3) Exhibit Transcript, # (4) Exhibit Order)
+(Sanchez, Lilly Ann)
+9:08-cv-80893-KAM Notice has been electronically mailed to:
+Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com
+Jack Alan Goldberger
+jagesq@bellsouth.net, nalanis@agwpa.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+Lilly Ann Sanchez Isanchez@fowler-white.com
+Michael James Pike MPike@bclclaw.com, bobbie@bclclaw.com, jcadwell@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Robert Deweese Critton, Jr rcrit@bclclaw.com, bobbie@bclclaw.com
+
+
+9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=9/2/2010] [FileNumber=7962354-0]
+[14676a51ceedd27e31ae77d88d074577deb251aea23deb381936eefa34e8b0c7ac95
+df85baca 182ae13f38007003e0299962b98e5c5b2c9c61659036d0a26e931]
+Document description: Exhibit Joint Stipulation
+Original filename:/a
+Electronic document Stamp:
+[STAMP dcecfStamp_ID=1105629215 [Date=9/2/2010] [FileNumber=7962354-1]
+[762b0221cff9c114bc71e6240c6ed256913579ebec9d43d552964704b687ac9d9e28
+598fc5dbd3e86673c3b2ce2a97ba3caбde5d4b9cb4f482e1f2262a386ac0]]
+Document description: Exhibit Notice of Intent to Use
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=9/2/2010] [FileNumber=7962354-2]
+[88032a009b58fa73f46b74677ebffa6dbf1599e3df4fdafc614bc621029f8flef58e
+Document description:Exhibit Transcript
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=9/2/2010] [FileNumber=7962354-3]
+[066ef955bab0fede7bbdd3ab73728d21deedeb451d004197c08013el11269ff4ae43
+193241173cc058199e5e9e54792a32726b44абc692855098f3d3cc60477b]]
+Document description:Exhibit Order
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=9/2/2010] [FileNumber=7962354-4]
+[620c5c4cf5b0e2cfd2c7d1a79a9b07bfddea057bd4f2dfccda73364985aef5c3b0f3
+b25b6510e345f93a81eb636dbbbd8bfeaeba47530679830e193dd56b50af]]
diff --git a/vision-fixhub/ds9-unparsed-06/28d4b339e7b59d8217f99f9c9511dc36cf7b0a30abb61431ad9b7dc56a253097.receipt.json b/vision-fixhub/ds9-unparsed-06/28d4b339e7b59d8217f99f9c9511dc36cf7b0a30abb61431ad9b7dc56a253097.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..29cae409eca98af26b85f28fe3eb8755d9e1a4f3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/28d4b339e7b59d8217f99f9c9511dc36cf7b0a30abb61431ad9b7dc56a253097.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "28d4b339e7b59d8217f99f9c9511dc36cf7b0a30abb61431ad9b7dc56a253097",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e6f40f9d55604d89e4903bd68f45ae1daf160ca0254bbe1f82d3b89748631c62",
+  "output_sha256": "73bf16de59f7fda647feb2516bdbb9848a10f54934725769b0eacbb6a31ac49a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/28ea204d3c2fbf9ea19ec2bc4f78358c01ae12baaadcd3a7188cc0a1d63d7d62.md b/vision-fixhub/ds9-unparsed-06/28ea204d3c2fbf9ea19ec2bc4f78358c01ae12baaadcd3a7188cc0a1d63d7d62.md
new file mode 100644
index 0000000000000000000000000000000000000000..29c337223dcfb2754ff7e16a7bd2e4570d451bf4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/28ea204d3c2fbf9ea19ec2bc4f78358c01ae12baaadcd3a7188cc0a1d63d7d62.md
@@ -0,0 +1,111 @@
+From:
+(USAFLS)" {
+To:
+|. (USAFLS)"
+Subject: RE: CA5 Child Pornography Restitution Decisions
+Date: Mon, 01 Oct 2012 21:31:26 +0000
+Importance: Normal
+Not sure how best to notify the court. I don't remember being moved very much by the prior case, but this one
+come from the court that decided In re Dean and may impact the judge's thinking about that case's
+implications.
+As to Elroy, I think the decision was to continue the discussion after hearing from Zelman.
+From:
+- (USAFLS)
+Sent: Monday, October 01, 2012 5:09 PM
+(USAFLS)
+Subject: RE: CA5 Child Pornography Restitution Decisions
+I will read this tonight, but maybe this and the one from the 11th that I forwarded to you earlier? Just a "notice
+of supplemental authority'"?
+How were things left re Elroy?
+Assistant U.S. Attorney
+From:
+To:
+(USAFLS)
+Sent: Monday, October 01, 2012 5:01 PM
+1. (USAFLS);
+I (USAFLS)
+Subject: FW: CA5 Child Pornography Restitution Decisions
+Do you think it's worth filing something in the Epstein case? There is some interesting language in some of the
+footnotes about how the CVRA's different subsections work.
+From:
+To: A
+• (USAFLS)
+Sent: Monday, October 01, 2012 2:39 PM
+
+
+Subject: FW: CA5 Child Pornography Restitution Decisions
+From:
+(USAFLS)
+Sent: Monday, October 01, 2012 2:31 PM
+To: I
+1. (USAFLS)
+Subject: FW: CA5 Child Pornography Restitution Decisions
+Would you please forward this to your attorneys? I'll send it to the appellate attorneys.
+Thanks,
+Subject: FW: CA5 Child Pornography Restitution Decisions
+Mike Rotker summarized the decision:
+Earlier today, the en banc Fifth Circuit issued its decisions in In re: Amy Unknown, No. 09-41238 &
+United States I Paroline, No. 09-41254, consolidated with United States I Wright, No. 09-31215,
+which collectively addressed a number of procedural and substantive issues governing restitution in
+child pornography possession cases. Specifically, No. 09-41238 is Amy's petition for a writ of
+mandamus under the Crime Victims' Rights Act of 2004, 18 U.S.C. 3771(d)(3), challenging the denial
+of restitution, and No. 09-41254 was Amy's related "appeal" from the final judgment against the
+defendant, Doyle Paroline, also challenging the denial of restitution. No. 09-31215 was an appeal by
+the defendant, Michael Wright, from the order requiring him to pay $529,000 in restitution. The en
+banc court issued several important rulings, as follows.
+First, the en banc court, with no dissent, dismissed No. 09-41254, agreeing with the United States that
+Congress has not authorized nonparty crime victims to appeal from the final judgment in a criminal
+case.
+Second, in No. 09-41238, the court of appeals granted Amy's petition for a writ of mandamus, vacated
+the judgment and remanded for further proceedings. As an initial matter, the en banc court, again
+without dissent, agreed with the government that a CVRA mandamus petition is governed by
+traditional mandamus standards of review, and not (as Amy argued) by ordinary standards of appellate
+review. The Court's decision to grant Amy's mandamus petition was consistent with the position
+expressed by the United States that she had shown clear and indisputable error in that the district
+court ordered no restitution. The court's rationale on proximate cause, however, was one that we did
+not endorse. Specifically, the government took the position (which, prior to these decisions, had been
+embraced by seven other circuits) that the "proximate cause" limitation in subsection (F) of the
+mandatory restitution statute, 18 U.S.C. 2259(b)(3), applied to all of the categories of losses in the
+preceding five subsections. We further asserted that, although proximate cause applied to all
+categories of losses, the proximate cause standard could be met by a showing that the defendant was
+one of the members of the class of individuals who, in the aggregate, caused the victim's emotional
+harms. The nine-judge majority of the en banc court rejected our threshold argument, agreeing with
+Amy that the proximate-cause language in subsection (F) is limited to that subsection, and does not
+apply to the preceding subsections. In so holding, the court relied on various canons of statutory
+
+
+construction, primarily the rule-of-the-last-antecedent, which states that words within a single clause
+are generally presumed to modify only the words that immediately precede them. (Judges Dennis and
+Southwick wrote separate opinions, but each agreed with this aspect of the decision. Judge Davis,
+joined by Judges King, Smith & Graves, dissented on this point and agreed with our position and that
+of every other circuit).
+Third, the Court rejected our concern that a construction of Section 2259(b)(3) that dispensed with
+proximate cause could expose defendants to a risk of excessive punishment, finding that restitution's
+purpose was remedial, not punitive, and that concerns for excessive payment could be mitigated by
+allowing district courts to impose restitution jointly and severally with other defendants. In so ruling,
+the Court rejected the government's argument (endorsed by two other circuits) that the relevant
+statutes did not authorize the imposition of "joint and several liability" among different defendants in
+different cases but was instead limited to multi-defendant cases before the same court.
+No. 09-31215 was an appeal by defendant Michael Wright from the final judgment ordering him to pay
+$528,000 in restitution to Amy, which was less than the $3.3 million Amy requested. The en banc
+court vacated the judgment and remanded for further proceedings in light of the foregoing analysis,
+and in doing so, declined to enforce the appeal waiver in Wright's plea agreement. In doing so, the
+Court noted that the record in Wright's case did not disclose "why the district court reduced the
+Government's full request on Amy's behalf," and stated that the court's order was "seemingly at odds
+with Section 2259's requirement that it award Amy the full amount of her losses." (Insofar as the Court
+was implying that the district court on remand could, or should, impose an amount of restitution that
+was greater than the amount initially awarded, the Court was wrong. This was a defendant's appeal;
+we urged the court to dismiss the appeal or remand for further proceedings, and Amy urged the court
+to affirm. Wright, therefore, cannot lawfully be exposed to an amount of restitution on remand that
+exceeds the amount initially imposed.)
+Judge Dennis concurred in the judgments, but he opined that the majority had gone further than
+necessary to decide these cases and would have allowed the district courts to decide how best to
+proceed first.
+Judges Davis, King, Smith and Graves dissented. They agreed with the position of the United States
+that proximate cause is required for all categories of losses, and that proximate cause should be
+analyzed by focusing (as the First Circuit had in a case we endorsed, United States I Kearney, on the
+aggregated harms caused by possessors generally).
+Judge Southwick dissented, agreeing largely with Judge Davis's analysis but differing in part as to his
+reasoning.
+United States Department of Justice
+Criminal Division, Appellate Section
diff --git a/vision-fixhub/ds9-unparsed-06/28ea204d3c2fbf9ea19ec2bc4f78358c01ae12baaadcd3a7188cc0a1d63d7d62.receipt.json b/vision-fixhub/ds9-unparsed-06/28ea204d3c2fbf9ea19ec2bc4f78358c01ae12baaadcd3a7188cc0a1d63d7d62.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..bd22d7d3fa44010ddd12e6974bbd0cfeeb841876
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/28ea204d3c2fbf9ea19ec2bc4f78358c01ae12baaadcd3a7188cc0a1d63d7d62.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "28ea204d3c2fbf9ea19ec2bc4f78358c01ae12baaadcd3a7188cc0a1d63d7d62",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "56b3fea8a37516410634b2c3373e630dbd8864f093ec1b9a26f854e8f2e41fe5",
+  "output_sha256": "14ad81f7bf804934bc15bd7c5558754ddfbe76069685b9dc622744b870862ae8",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2911e1e52906cee3faefba1690d88b3185b50f42dbe38199d1121208c87364fe.md b/vision-fixhub/ds9-unparsed-06/2911e1e52906cee3faefba1690d88b3185b50f42dbe38199d1121208c87364fe.md
new file mode 100644
index 0000000000000000000000000000000000000000..9d7af21308030578a927d414c4a7b48dc492c88d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2911e1e52906cee3faefba1690d88b3185b50f42dbe38199d1121208c87364fe.md
@@ -0,0 +1,24 @@
+To: "JPerczek@royblack.com"' <JPerczek@royblack.com>
+Subject: Re: Doe |. USAO
+Date: Sat, 15 Oct 2011 01:01:08 +0000
+Importance: Normal
+Image: ATT00001
+Hi Jackie: I am so sorry. I just received this. I was traveling today. Of course, no obkection.
+From: Jackie Perczek [mailto:JPerczek@royblack.com]
+Sent: Friday, October 14, 2011 04:48 PM
+Subject: Doe L USAO
+In a little while, I will be filing Epstein's omnibus reply in support of his motion to intervene. It is one pleading.
+that replies to your response and to Cassell's response. It was better and more efficient to do one pleading. It
+will be 19 pages. Do you oppose a motion to file an overlong pleading? Cassell says he opposes anything longer
+than 15 pages.
+Also, my reply to Cassell's response to the supplemental briefing filed by the would-be intervenor lawyers is due
+early next week. I will be filing a motion for an extension until October 31. Cassell has no objection. Can I say
+the govt has no objection either?
+Thanks,
+Jackie Perczek, Esq.
+N020g
+The information in this email transmission is privileged and confidential. If you are not the intended recipient, nor
+the employee or agent responsible
+for delivering it to the intended recipient, you are hereby notified that any dissemination or copying of this
+transmission (including any attachments) is strictly prohibited. If you have received this email in error, please
+notify the sender by email reply. Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/2911e1e52906cee3faefba1690d88b3185b50f42dbe38199d1121208c87364fe.receipt.json b/vision-fixhub/ds9-unparsed-06/2911e1e52906cee3faefba1690d88b3185b50f42dbe38199d1121208c87364fe.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0461540ad97de3905a659a03591f9d933760ff4f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2911e1e52906cee3faefba1690d88b3185b50f42dbe38199d1121208c87364fe.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "2911e1e52906cee3faefba1690d88b3185b50f42dbe38199d1121208c87364fe",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "029ad3a662fae3c3fb644a8e8403c0c05a40e7e95ca9ce9d18fd980bc9522250",
+  "output_sha256": "85873c73ba5f3176aef9da9bed2da18ae87cf56281424738d206df910d0e09c0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/291c22b4c65165c717cb54016845468716c4c5e973096e9221f1c328c477346e.md b/vision-fixhub/ds9-unparsed-06/291c22b4c65165c717cb54016845468716c4c5e973096e9221f1c328c477346e.md
new file mode 100644
index 0000000000000000000000000000000000000000..1cd79340bc965a85a08d271d9f247f3055ee3c87
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/291c22b4c65165c717cb54016845468716c4c5e973096e9221f1c328c477346e.md
@@ -0,0 +1,16 @@
+From:
+To:
+Cc:
+Subject: Call from OPR
+Date: Tue, 04 Jan 2011 20:27:16 +0000
+Importance: Normal
+I've just spoken with
+at OPR, regarding the request for investigation submitted by Paul
+Cassell. She is in the preliminary stages of determining whether the matter should be opened into an
+investigation. To assist her in this process, she asked if we could produce the following:
+(1) documents such as memos or e-mails which show the decisional process for determining whether this
+Office should enter into the Non-Prosecution Agreement with Epstein. This would include opposing views
+within the office, as well as supporting views; and
+(2) documents showing whether the FBI was, or was not, made aware of the negotiations with Epstein
+regarding the Non-Prosecution Agreement. Cassell claims the FBI was kept completely out of the process.
+Can you canvass your files and find out whether responsive documents exist? Thanks.
diff --git a/vision-fixhub/ds9-unparsed-06/291c22b4c65165c717cb54016845468716c4c5e973096e9221f1c328c477346e.receipt.json b/vision-fixhub/ds9-unparsed-06/291c22b4c65165c717cb54016845468716c4c5e973096e9221f1c328c477346e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f81605b0c6a64479985e4039946b7690821cc1c3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/291c22b4c65165c717cb54016845468716c4c5e973096e9221f1c328c477346e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "291c22b4c65165c717cb54016845468716c4c5e973096e9221f1c328c477346e",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "c231b0bd483666eea43fc57d4d0bf4945a575e3fb7d0e8aeb5acc58776bb60c6",
+  "output_sha256": "430ac4ed14a3a7092c60a927a8cf3c2f9bb70bc41ee5b15a089e4f19852c9cfa",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/291e00d03fa0caafe32311ebdd7d7cf1c44141367a600e1656b44e6b123ce1a5.md b/vision-fixhub/ds9-unparsed-06/291e00d03fa0caafe32311ebdd7d7cf1c44141367a600e1656b44e6b123ce1a5.md
new file mode 100644
index 0000000000000000000000000000000000000000..d1c2cf0ea9b7791ab1aed90e03e9c2e70dcc98dc
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/291e00d03fa0caafe32311ebdd7d7cf1c44141367a600e1656b44e6b123ce1a5.md
@@ -0,0 +1,17 @@
+Subject: FW: Voluntary Production of Materials?
+Date: Tue, 17 Jan 2012 05:06:28 +0000
+Importance: Normal
+Attachments: Docket - 502008CA028058_
+I: Docket_- 502008CA028051_-
+I know that you normally do not go to the Palm Beach County Courthouse, but this is a bit of an emergency
+need this for filing in one of our federal civil cases. I don't know whether the state
+court will charge to get the certified copies or what we will need to do to get the certified copies, but can you
+work with
+to get this done?
+The docket entries that we need are listed below. I will be in tomorrow, but I might be a bit late.
+Thank you.
+Subject: RE: Voluntary Production of Materials?
+Attached are the two Palm Beach circuit court dockets. We need to get certified copies of the complaints in Case # 50-
+2008-CA-028051 (Docket Entries 1, 16, and 264) and Case # 50-2008-CA-028058 (Docket Entries 1, 23, and 221).
+Do either of you have any idea how we can get that done quickly?
+Ed
diff --git a/vision-fixhub/ds9-unparsed-06/291e00d03fa0caafe32311ebdd7d7cf1c44141367a600e1656b44e6b123ce1a5.receipt.json b/vision-fixhub/ds9-unparsed-06/291e00d03fa0caafe32311ebdd7d7cf1c44141367a600e1656b44e6b123ce1a5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9f3b052250b5062c473bdec17cebe77eefabdc18
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/291e00d03fa0caafe32311ebdd7d7cf1c44141367a600e1656b44e6b123ce1a5.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "291e00d03fa0caafe32311ebdd7d7cf1c44141367a600e1656b44e6b123ce1a5",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "0f2192a3a64818191941ce900441fbe7631f8bfbede35d5305a95000c3964856",
+  "output_sha256": "9ec1fcb02911910731f776f74ac84a759f1cd768893c9f46ddc62db0ff575788",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2944e10640adf22ea9a47f63dc235ca38eb1a92f9c026e1ebc75d765a9bad4fe.md b/vision-fixhub/ds9-unparsed-06/2944e10640adf22ea9a47f63dc235ca38eb1a92f9c026e1ebc75d765a9bad4fe.md
new file mode 100644
index 0000000000000000000000000000000000000000..58a5d79c6f0ee6ce39afbac1534a3bcc82a10954
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2944e10640adf22ea9a47f63dc235ca38eb1a92f9c026e1ebc75d765a9bad4fe.md
@@ -0,0 +1,9 @@
+From:
+To: "cmecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+Subject: Out of Office AutoReply: Activity in Case 9:08-cv-80119-KAM Doe v. Epstein Set Motion and
+R&R Deadlines/Hearings
+Date: Thu, 25 Mar 2010 19:12:39 +0000
+Importance: Normal
+I will be out of the office in meetings on March 25th and will have only limited access to email. If the matter is urgent, please contact my
+assistant.
+Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/2944e10640adf22ea9a47f63dc235ca38eb1a92f9c026e1ebc75d765a9bad4fe.receipt.json b/vision-fixhub/ds9-unparsed-06/2944e10640adf22ea9a47f63dc235ca38eb1a92f9c026e1ebc75d765a9bad4fe.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b873aa8de4dc6523442e900d7c8cc25b6ff3a1d8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2944e10640adf22ea9a47f63dc235ca38eb1a92f9c026e1ebc75d765a9bad4fe.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "2944e10640adf22ea9a47f63dc235ca38eb1a92f9c026e1ebc75d765a9bad4fe",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3205aacd4ba2ec93f710df5cc8a8cda7d9b9eee2958f63d115309f0fad64e3fe",
+  "output_sha256": "abcf042fd1dc58fa03d4bb91919a518cb93dc7bf15a8456bad3a3c0ec4a204d0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/294a8673f2f97cc66a8e6efee3568202daecdba37791dc18cc6b603720b7571d.md b/vision-fixhub/ds9-unparsed-06/294a8673f2f97cc66a8e6efee3568202daecdba37791dc18cc6b603720b7571d.md
new file mode 100644
index 0000000000000000000000000000000000000000..8c80b36939db00c2c8eb78bd28533327b861b0c0
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/294a8673f2f97cc66a8e6efee3568202daecdba37791dc18cc6b603720b7571d.md
@@ -0,0 +1,9 @@
+From:
+To:
+Subject: Read: Press Contact from Newsweek re Jefirey Epstein case
+Date: Wed, 20 Jul 2011 20:05:14 +0000
+Importance: Normal
+Your message
+Subject: Press Contact from Newsweek re Jeffrey Epstein case
+Sent: Wednesday, July 20, 2011 3:58:10 PM (UTC-05:00) Eastern Time (US & Canada)
+was read on Wednesday, July 20, 2011 4:04:45 PM (UTC-05:00) Eastern Time (US & Canada).
diff --git a/vision-fixhub/ds9-unparsed-06/294a8673f2f97cc66a8e6efee3568202daecdba37791dc18cc6b603720b7571d.receipt.json b/vision-fixhub/ds9-unparsed-06/294a8673f2f97cc66a8e6efee3568202daecdba37791dc18cc6b603720b7571d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b42f65a30b83d41cb9bc6a20c3abb797d01c9e64
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/294a8673f2f97cc66a8e6efee3568202daecdba37791dc18cc6b603720b7571d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "294a8673f2f97cc66a8e6efee3568202daecdba37791dc18cc6b603720b7571d",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "dc4dd629376c8aceb6edf017e346bb06a7a777a1fcda219d0195774c57897e1c",
+  "output_sha256": "9d278c12841fc7b2dd1a24326e06eebe5b9ecab2bbf3bda13d4cd2c4f39303d3",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/295c9ee013a2686af2a7c108d50895503e906da2158abc54ecbbb18366d8d9ea.md b/vision-fixhub/ds9-unparsed-06/295c9ee013a2686af2a7c108d50895503e906da2158abc54ecbbb18366d8d9ea.md
new file mode 100644
index 0000000000000000000000000000000000000000..fc381edaeff0107d0f39f550f8b7f7ac21080813
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/295c9ee013a2686af2a7c108d50895503e906da2158abc54ecbbb18366d8d9ea.md
@@ -0,0 +1,108 @@
+Mazzarelli, J.P.,
+Sweeny, Moskowitz, Acosta,
+Abdus-Salaam,
+JJ.
+6081
+The People of the State of New York,
+Respondent,
+-against-
+Jeffrey E. Epstein,
+Defendant-Appellant.
+Ind. 30129/10
+Kirkland & Ellis LLP, New York (Jay P. Lefkowitz of
+counsel),
+for
+appellant.
+Cyrus R. Vance, Jr., District Attorney, New York (Deborah
+L. Morse of counsel), for respondent.
+Order, Supreme Court, New York County (Ruth Pickholz,
+J.), entered on or about January 18, 2011, which
+adjudicated defendant a level three sex offender pursuant
+to the Sex Offender Registration Act (Correction Law art 6-
+C), unanimously affirmed, without costs.
+Clear and convincing evidence, including reliable
+hearsay (see People v Mingo, 12 NY3d 563, 571 [20091)
+supported the assessment of points for risk factors
+sufficient for a level three sex offender adjudication
+(Correction Law § 168-n[3]). In the circumstances of this
+case, the court properly relied on highly reliable proof of
+criminal conduct for which defendant was neither indicted
+nor convicted.
+The sex offender adjudication arises out of
+defendant's sex offenses in Florida.
+The evidence before
+the SORA hearing court established that defendant committed
+multiple offenses against a series of underage girls. The
+girls were brought to defendant's home to provide
+"massages" that led to very serious sex crimes.
+These facts were established by reliable hearsay,
+including the probable cause affidavit prepared by Florida
+law enforcement authorities after their investigation, and
+the Board of Examiners of Sex Offenders' case summary (see
+Mingo, 12 NY3d at 572-573, 577). The probable cause
+affidavit was extremely detailed. It set forth the sworn,
+tape-recorded statements of the victims. The victims'
+detailed accounts of defendant's crimes corroborated each
+other, and were also corroborated by other evidence,
+
+
+including declarations against penal interest made by
+defendant's accomplice.
+In 2006, the Florida prosecutor obtained an indictment
+charging defendant with solicitation of prostitution. In
+2008, the Florida prosecutor filed an information, this
+time charging procuring a person under 18 for prostitution.
+A few days after the information, defendant pleaded guilty
+to both accusatory instruments.
+Both instruments involved
+the same victim, who was only one of defendant's many
+victims.
+The Board and the hearing court are not limited to the
+underlying crime in determining an offender's risk level
+(see People v Johnson, 77 ADd 548, 549-550 [2010], 1v
+denied 16 NY3d 705 [2011]). "[T]he fact that an offender
+was not indicted for an offense may be strong evidence that
+the offense did not occur" (Sex Offender Registration Act:
+Risk Assessment Guidelines and Commentary, General
+Principles I 7, at 5 [2006]). However, here the strong
+evidence that the offenses
+against the other victims did
+occur outweighs any inferences to be drawn from the manner
+in which this case was prosecuted in Florida.
+The reasons for the actions taken by the Florida
+authorities remain unclear on this
+record. The record
+before us is insufficient to establish that those
+authorities reasonably believed the charges involving the
+other victims were unprovable.
+The record permits
+competing inferences.
+In any event, the hearing court was
+entitled to rely on the reliably proven facts themselves,
+and was not necessarily bound by any exercises of
+prosecutorial discretion.
+We reject defendant's argument that the People should
+be estopped from taking a different position on appeal from
+the position they took before the hearing court. At the
+hearing, the People mistakenly conceded that the conduct
+for which defendant was not indicted should not be
+considered, and that defendant should be adjudicated a
+level one offender. These were legal arguments that the
+court rejected, and it is the court's determination that we
+review on this appeal. Furthermore, when the court
+announced that it was rejecting the People's position and
+would consider the offenses against additional victims,
+defendant did not request any opportunity to challenge the
+reliability of the additional charges. Accordingly,
+defendant was not deprived of a fair opportunity to
+litigate the issue (see e.g. People v Strong, 276 ADd 271
+[2000], Iv denied 96 NY2d 807 [20011).
+Defendant's remaining claims are improperly raised for
+
+
+the first time on appeal (see People v Windham, 10 NY3d 801
+[20081), and are unavailing in any event.
+THIS CONSTITUTES THE DECISION AND ORDER
+OF THE SUPREME COURT, APPELLATE DIVISION, FIRST DEPARTMENT.
+ENTERED: NOVEMBER 17, 2011
+CLERK
diff --git a/vision-fixhub/ds9-unparsed-06/295c9ee013a2686af2a7c108d50895503e906da2158abc54ecbbb18366d8d9ea.receipt.json b/vision-fixhub/ds9-unparsed-06/295c9ee013a2686af2a7c108d50895503e906da2158abc54ecbbb18366d8d9ea.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1036b68fd7403984eda26ae1b551fdfbf2091d1b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/295c9ee013a2686af2a7c108d50895503e906da2158abc54ecbbb18366d8d9ea.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "295c9ee013a2686af2a7c108d50895503e906da2158abc54ecbbb18366d8d9ea",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "0dbf874debdb09e9a8ab409e116dc920d37c1c58db9a64a168b4c5dd2cbc8949",
+  "output_sha256": "e9ab0753fcfb04d5e8d2a3b80781cad283b3dab968e848802088ef83ce4e70fd",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/295e64a1bdd953205e3b5a7b2999d7eee58b9922976f4b6d4eff2fd2c3e73d34.md b/vision-fixhub/ds9-unparsed-06/295e64a1bdd953205e3b5a7b2999d7eee58b9922976f4b6d4eff2fd2c3e73d34.md
new file mode 100644
index 0000000000000000000000000000000000000000..c1b05b677fe8a0cf16fcfaa926e8dd40586b5a47
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/295e64a1bdd953205e3b5a7b2999d7eee58b9922976f4b6d4eff2fd2c3e73d34.md
@@ -0,0 +1,20 @@
+Subject: RE: Jane Doe Nos. 1 and 2 | United States
+Date: Wed, 14 Dec 2011 01:06:46 +0000
+Importance: Normal
+Brad and Paul,
+Thanks very much and a happy holiday to both of you.
+Dexter
+From: Brad Edwards [mailto:bedwards@pathtojustice.com]
+Sent: Tuesday, December 13, 2011 7:42 PM
+«uGAELS Paul Cassell: Brad Edwards
+Subject: Re: Jane Doe Nos. 1 and 2 | United States
+January 6th is fine. Have a nice vacation.
+Date: Tue, 13 Dec 2011 17:35:06 -0500
+To: Paul Cassell<cassellp@law.utah.edu>; Brad Edwards<bedwards@pathtojustice.com>
+Subject: Jane Doe Nos. T and 21. United States
+Paul and Brad,
+The government's replies to the victims' responses are due on December 15, 2011. The responses to the motion for
+remedies, and protective motion to compel, are due on December 22, 2011.
+Land I will be on annual leave for the holidays at various times over the next two and one-half weeks, until the
+new year. Do you have any objection to the government seeking an enlargement of time, to respond to the four (4)
+documents filed on December 5, up to and including January 6, 2012? Thanks.
diff --git a/vision-fixhub/ds9-unparsed-06/295e64a1bdd953205e3b5a7b2999d7eee58b9922976f4b6d4eff2fd2c3e73d34.receipt.json b/vision-fixhub/ds9-unparsed-06/295e64a1bdd953205e3b5a7b2999d7eee58b9922976f4b6d4eff2fd2c3e73d34.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..659454f7827a4c46b80a041ccc1f835e22be36bf
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/295e64a1bdd953205e3b5a7b2999d7eee58b9922976f4b6d4eff2fd2c3e73d34.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "295e64a1bdd953205e3b5a7b2999d7eee58b9922976f4b6d4eff2fd2c3e73d34",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "a88a1d5128d607db4dd014a76f5034be938e81379fc2b470f3ddf60a734c6ede",
+  "output_sha256": "5a9917b179a15379af2f90f357745611cce7653dd267b168c105bfddbe3cddfd",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2992a202f9ab29f3f6abb13e46b45bcd0f03bc3e7552cdd121a226e73aa5a5d2.md b/vision-fixhub/ds9-unparsed-06/2992a202f9ab29f3f6abb13e46b45bcd0f03bc3e7552cdd121a226e73aa5a5d2.md
new file mode 100644
index 0000000000000000000000000000000000000000..47bb2154ff838e5b4363c8aa6dc245fa135d7ce0
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2992a202f9ab29f3f6abb13e46b45bcd0f03bc3e7552cdd121a226e73aa5a5d2.md
@@ -0,0 +1,528 @@
+STATEMENT OF FACTS
+Jane Doe #1 and Jane Doe #2 offer the following statement of facts, which they are
+prepared to establish at any evidentiary hearing that the Court might schedule.
+1. Between about 2003 and 2006, defendant Jeffrey Epstein (a billionaire with significant
+political connections) sexually abused more than 40 minor girls at his mansion in West Palm
+Beach, Florida, and elsewhere.
+2. In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of
+Investigation ("FBI") opened an investigation into allegations that Jeffrey Epstein ("Epstein")
+and his personal assistants had used facilities of interstate commerce to induce young girls
+between the ages of thirteen and seventeen to engage in prostitution, among other offenses. The
+case was presented to the United States Attorney's Office for the Southern District of Florida,
+which accepted the case for investigation. See Declaration of Bradley J. Edwards, Esq. at 1
+(hereinafter "Edwards Declaration"). The Palm Beach County State Attorney's Office was
+investigating the case. Edwards Declaration at 1.
+3. The FBI determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults
+by Epstein while they were minors beginning when they were approximately thirteen years of
+age and approximately XXXXx years of age. Both Jane Does were initially identified through the
+Palm Beach Police Department's investigation of Epstein. Edwards Declaration at 1.
+4. On about June 7, 2007, FBI agents hand-delivered to Jane Doe #1 a standard CVRA victim
+notification letter.
+See Doc. #14
+'he
+notification promises that the Justice Department would makes its "best efforts" to protect Jane
+Doe #1's rights, including "It]he reasonable right to confer with the attorney for the United
+States in the case" and "to be reasonably heard at any public proceeding in the district court
+
+
+involving ... plea ...." The notification further explained that "[alt this time, your case is
+under investigation." That notification meant that the FBI had identified Jane Doe #1 as a victim
+of a federal offense and therefore as someone protected by the CVRA
+5. On about August 11, 2007, Jane Doe #2 received a standard CVRA victim notification letter.
+See Doc. #14 (attachment 2 to declaration of A. Marie
+The notification promises that
+the Justice Department would makes its "best efforts" to protect Jane Doe #1's rights, including
+"[t]he reasonable right to confer with the attorney for the United States in the case" and "to be
+reasonably heard at any public proceeding in the district court involving •.• plea ...." The
+notification further explained that "[a]t this time, your case is under investigation." That
+notification meant that the FBI had identified Jane Doe #2 as a victim of a federal offense and
+therefore as someone protected by the CVRA.
+6. Early in the investigation, the FBI agents and the Assistant U.S. Attorney had several
+meetings with Jane Doe #1. Jane Doe #2 was represented by counsel and, accordingly, all
+contact was made through that attorney. Edwards Declaration at 1.
+7. In May 2007, the U.S. Attorney's Office had a 82-page prosecution memorandum outlining
+numerous federal sexual offenses committed by Epstein, and had prepared a 53-page indictment
+for numerous federal offenses. U.S. Attorney's Correspondence at 4.
+In and around September 2007, plea discussions took place between Jeffrey Epstein,
+represented by numerous attorneys (including lead criminal defense counsel Jay Lefkowitz) and
+the U.S. Attorney's office for the Southern District of Florida, represented primarily by Assistant
+U.S. Attorney A. Marie
+The plea discussions generally began from the premise that
+Epstein would plead guilty at least one federal felony offense surrounding his sexual assaults of
+more than 40 minor girls. From there, the numerous defense attorneys progressively and
+
+
+relentlessly negotiated more favorable plea terms so that Epstein would ultimately plead to only
+two misdemeanor offenses and would serve only jail time. Many of the negotiations are
+reflected in e-mails between Lefkowitz and
+Copies of the correspondence are attached as
+Exhibit 2 to the Edwards Declaration accompanying this filing (hereinafter cited as "U.S. Attorney's
+Correspondence" and referenced by Bates number stamp).' Because Epstein has moved to keep these
+documents under seal, they are at this time filed under seal with the Court.
+9.
+In September 2007, in connection with plea discussions about a possible federal assault
+charges against Epstein, Assistant U.S. Attorney (AUSA)
+posed that
+Epstein plead to an assault charge involving a telephone call made by Epstein while he was on
+his private jet. During the telephone call, Epstein warned his personal assistant, Lesley Groff,
+against turning over documents and electronic evidence responsive to a subpoena issued by a
+federal grand jury in the Southern District of Florida investigating Epstein's sex offenses. U.S.
+Attorney's Correspondence at 49, 58.
+10. The correspondence also shows that A
+was interested in finding a place to
+conclude a plea bargain that would effectively keep the victims from learning what was
+happening through the press.
+She wrote in an e-mail to defense counsel: "On an 'avoid the
+press' note, I believe that Mr. Epstein's airplane was in Miami on the day of the Ms. Groff
+telephone call. If he was in Mimi-Dade County at the time, then I can file the charge in the
+District Court in Miami, which will hopefully cut the press coverage significantly." U.S.
+Attorney's Correspondence at 29.
+was aware that most of the victims of Epstein,
+• Through diligent efforts, counsel for Jane Doe #1 and Jane Doe #2 received copies of half of the e-mail
+correspondence (the half reflecting
+communications to defense counsel) on about June 30,
+2010.
+
+
+including Jane Doe #1 and Jane Doe #2, resided in the West Palm Beach area rather than the
+Miami area.
+11. On about September 24, 2007, A
+sent an e-mail to
+Jay Lefkowitz, criminal defense counsel for Epstein, regarding the agreement. The e-mail stated
+that the Government and Epstein's counsel would negotiate between themselves about what
+information would be disclosed to the victims about the agreement:
+Thank you, Jay.
+I have forwarded your message only to Alex [Acosta], Andy,
+and Roland. I don't anticipate it going any further than that. When I receive the
+originals, I will sign and return one copy to you. The other will be placed in the
+case file, which will be kept confidential since it also contains identifying
+information about the girls.
+When we reach an agreement about the attorney representative for the girls, we
+can discuss what I can tell him and the girls about the agreement. I know that
+Andy promised Chief Reiter an update when a resolution was achieved. ...
+Rolando is calling, but Rolando knows not to tell Chief Reiter about the money
+issue, just about what crimes Mr. Epstein is pleading guilty to and the amount of
+time that has been agreed to. Rolando also is telling Chief Reiter not to disclose
+the outcome to anyone.
+U.S. Attorney's Correspondence at 153 (emphases added).
+12. On about September 25, 2007, AUSA
+send an e-mail to Lefkowitz stating: "And
+can we have a conference call to discuss what I may disclose to .... the girls regarding the
+agreement." U.S. Attorney's Correspondence at 156.
+13. On about September 26, 2007, AUSA.
+sent an e-mail to Lefkowitz in which she
+stated: "Hi Jay - Can you give me a call at 561 209-[xxxx] this morning? I am meeting with the
+agents and want to give them their marching orders regarding what they can tell the girls." U.S.
+Attorney's Correspondence at xxxxx. The reasonable inference is that the "marching orders"
+agreed to between the Government and Epstein's defense counsel was that no mention would be
+
+
+made of the non-prosecution agreement between the U.S. Attorney's Office and Epstein, as no
+subsequent mention was made to the victims of the non-prosecution agreement.
+14.
+On about September 27, 2007, Assistant U.S. Attorney A. Marie
+revealed to an
+attorney (Bert Ocariz), who was under discussion to be a representative of victims of Epstein's
+sexual abuse, that a non-prosecution agreement was in the process of being reached with Epstein.
+The e-mail stated: "Bert's firm has raised a number of good questions about how they are going
+to get paid." U.S. Attorney's Correspondence at 161. The e-mail went on to state: "I told Bert
+that as part of our agreement we (the federal government) are not going to indict Mr. Epstein, but
+him an idea of the charged that we had planned to bring as related to 18 USC 2255." Id. The e-
+mail also asked permission from Epstein's counsel to send to Ocariz a copy of parts of the plea
+agreement: "With respect to question 2 [a question from Ocariz regarding "[w]hen will it be
+possible to see the plea agreement so that we understand exactly what Epstein concedes to in the
+civil case?], do I have your permission to send Bert just that section of the plea agreement that
+applies to the damages claims (I would recommend sending paragraphs 7 through 10, or at least
+7 and 8)?" Id.
+15. In a letter later sent by Jay Lefkowitz to the U.S. Attorney for the Southern District of
+Florida, Lefkowitz stated that ASUA
+had "assiduously" hidden from him the fact that
+Bert Ocariz was a friend of
+• boyfriend. U.S. Attorney's Correspondence at 267.
+Lefkowitz also stated that
+had misleadingly used the term "friend" rather than the more
+accurate term "boyfriend" to describe the connection. Id. at 268 Lefkowitz further stated the
+boyfriend had a business relationship with Ocariz and that the boyfriend would have
+financially benefitted from the presumably lucrative referral of sexual assault cases against
+Epstein to Ocariz. On December 13, 2007,
+wrote a letter to Lefkowitz to deny these
+
+
+accusations. In the letter,
+stated: "... I am surprised by your allegations regarding my
+role because I thought that we had worked very well together in resolving this dispute. I also am
+surprised because I feel that I bent over backwards to keep in mind the effect that the agreement
+would have on Mr. Epstein and to make sure that you (and he) understood the repercussions of
+the agreement." Id.
+16.
+On about September 24, 2007, Epstein and the U.S. Attorney's Office reached an
+agreement whereby the United States would defer federal prosecution in favor of prosecution by
+the State of Florida. Epstein and the U.S. Attorney's Office accordingly entered into a "Non-
+Prosecution Agreement" (NPA) reflecting their agreement. Most significantly, the NPA gave
+Epstein a promise that he would not be prosecuted for a series of federal felony offenses
+involving his sexual abuse of more than 30 minor girls. The NPA instead allowed Epstein to
+plead guilty to two state felony offenses for solicitation of prostitution and procurement of
+minors for prostitution. The NPA also set up a procedure whereby a victim of Epstein's sexual
+abuse could obtain an attorney to proceed with a civil claim against Epstein, provided that the
+victim agreed to proceed exclusively under 18 U.S.C. § 2255 (i.e., provided that the victim
+agreed to seek no more than $150,000 in damages against Epstein). See Affidavit of Bradley J.
+Edwards, Attachment xxxxxx (copy of the non-prosecution agreement). The agreement was
+signed by Epstein and his legal counsel, as well as the U.S. Attorney's Office, on about
+September 24, 2007.
+17. A provision in the non-prosecution agreement made the agreement secret. In particular, the
+agreement stated: "The parties anticipate that this agreement will not be made part of any public
+record.
+If the United States receives a Freedom of Information Act request or any compulsory
+process commanding the disclosure of the agreement, it will provide notice to Epstein before
+
+
+making the disclosure." See Edwards Declaration, Exhibit xxx (copy of the non-prosecution
+agreement), at &13.
+By entering into such a confidentiality agreement, the U.S. Attorney's
+Office put itself in a position notifying the crime victims (including Jane Doe #1 and Jane Doe
+#2) of the non-prosecution agreement would violate terms of the agreement - specifically the
+confidentiality provision. Accordingly, from September 24, 2007 through at least June 2008 - a
+period of more than nine months -- the U.S Attorney's Office did not notify any of the victims of
+the existence of the non-prosecution agreement.
+18. A reasonable inference from the evidence is that the U.S. Attorney's Office wanted the nonprosecution agreement kept from public view because of the intense public criticism that would
+have resulted from allowing a billionaire who had sexually abused more than 40 minor girls to
+escape from federal prosecution with only a county court jail sentence and because of the
+possibility that the victims could have objected to the agreement in court and prevented its
+consummation.
+19. The Non-Prosecution Agreement that had been entered into between the U.S. Attorney's
+Office and Epstein was subsequently modified by an October 2007 Addendum and a December
+19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez. See Supplemental
+Declaration of A. Marie
+doc. #35, at 1; U.S. Attorney's Correspondence at 234-37.
+The U.S. Attorney's Office did not notify any of the victims of the existence of these
+modifications of the agreement through at least June 2008 - a period of more than six months.
+On about August 14, 2008, Epstein's defense counsel told the U.S. Attorney's Office that they
+did not consider the December 19, 2007, letter to be operative. Id.
+20.
+In October 2007, shortly after the initial plea agreement was signed, Jane Doe #1 was
+contacted to be advised regarding the resolution of the investigation. On October 26, 2007,
+
+
+Special Agents E. Nesbitt Kuyrkendall and Jason Richards met in person with Jane Doe #1. The
+Special Agents explained that Epstein would plead guilty to state charges, he would be required
+to register as a sex offender for life, and he had made certain concessions related to the payment
+of damages to the victims, including Jane Doe #1. During this meeting, the Special Agents did
+not explain that an agreement had already been signed that precluded any prosecution of Epstein
+for federal charges.
+The agents could not have revealed this part of the non-prosecution
+agreement without violating the terms of the non-prosecution agreement. Whether the agents
+themselves had been informed of the existence of the non-prosecution agreement by the U.S.
+Attorney's Office is not certain. Because the plea agreement had already been reached with
+Epstein, the agents made no attempt to secure Jane Doe #1's view on the proposed resolution of
+the case. Edwards Declaration at xxxxxx.
+21.
+Jane Doe #1's perception of the explanation provided by the Special Agents was that only
+the State part of the Epstein investigation had been resolved, and that the federal investigation
+would continue, possibly leading to a federal prosecution. Edwards Declaration at xxxxxx.
+22.
+On about November 27, 2007, Assistant U.S. Attorney Jeff Sloman sent an e-mail to Jay
+Lefkowitz, defense counsel for Epstein. The e-mail stated:
+The United States has a statutory obligation (Justice for All Act of 2004) to notify
+omorrow will make one full week since you were formally notified of th
+election. I must insist that the vetting process come to an end. Therefore, unles
+U.S. Attorney's Correspondence at 255.
+
+
+23. On about November 29, 2007, Assistant U.S. Attorney A. Marie
+sent a draft of a
+crime victim notification letter to Jay Lefkowitz, defense counsel for Jeffrey Epstein. The
+notification letter explained: "I am writing to inform you that the federal investigation of Jeffrey
+Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an
+agreement containing the following terms ...." The letter then went on to explain that Epstein
+would plead guilty to two state offenses and receive an 18 month sentence. The letter did not
+explain that, as part of the agreement with Epstein, the Justice Department was agreeing not to
+prosecute Epstein for any of the numerous federal offenses that had been committed. U.S.
+Attorney's Correspondence at 256-59.
+24. Apparently because of concerns from Epstein's attorneys, the U.S. Attorney's Office never
+sent the proposed victim notification letter discussed in the previous paragraph to the victims.
+Instead, a misleading letter stating that the case was "currently under investigation" (described
+below) was sent in January 2008. At no time before reaching non-prosecution agreement did the
+Justice Department contact any victims, including Jane Doe #1, about their views on the nonprosecution.
+25. On about December 6, 2007, Jeffrey H. Sloman, First Assistant U.S. Attorney sent a letter to
+Jay Lefkowitz, noting the U.S. Attorney's Office's legal obligations to keep victims informed of
+the status of plea negotiations with Epstein. The letter stated:
+Finally, let me address your objections to the draft Victim Notification Letter.
+You write that you don't understand the basis for the Office's belief that it is
+appropriate to notify the victims. Pursuant to the "Justice for All Act of 2004;
+[another name from the CVRA] crime victims are entitled to: "The right to
+inasrine, crue an he mily not to be excluded tom any sech eding court
+proceeding .... ' 18 U.S.C. § 3771(a)(2) & (3). Section 3771 also commands
+investigation, or prosecution of crime shall make their best efforts to see that
+
+
+crime victims are notified of, and accorded, the rights described in subection (a)."
+18 U.S.C. § 3771(c)(1)....
+Our Non-Prosecution Agreement resolves the federal investigation by allowing
+Mr. Epstein to plead to a state offense. The victims identified through the federal
+investigation should be appropriately informed, and our Non-Prosecution
+Agreement does not require the U.S. Attorney's Office to forego its legal
+obligation.
+U.S. Attorney's Correspondence at 191-92.
+26. Despite this recognition of its obligation to keep victims "appropriately informed" about the
+non-prosecution agreement, the U.S. Attorney's Office did not follow through and inform the
+victims of the non-prosecution agreement. To the contrary, as discussed below, it continued to
+tell the victims that the case was "under investigation." Edwards Declaration at xxxxxxx.
+27. On December 13, 2007, A. Marie
+sent a letter to Jay Lefkowitz, defense
+counsel for Epstein, rebutting charges that had apparently been made against her by the Epstein
+defense. The letter stated that a federal indictment against Epstein "was postponed for more than
+five months to allow you and Mr. Epstein's other attorneys to make presentations to the Office to
+convince the Office not to prosecute." The letter also recounted that "You and I spent hours
+negotiating the terms [of the non-prosecution agreement], including when to use 'a' versus "the'
+and other minutiae. When you and I could not reach agreement, you repeatedly went over my
+head, involving Messrs. Lourie, Menchel, Sloman, and Acosta in the negotiations at various
+times." U.S. Attorney's Correspondence at 269.
+28. The December 13, 2007, letter also reveals that the Justice Department stopped making
+victim notifications because of objections from Epstein's criminal defense counsel: "Three
+victims were notified shortly after the signing of the Non-Prosecution Agreement of the general
+terms of the Agreement. You raised objections to any victim notification, and no further
+notifications were done." U.S. Attorney's Correspondence at 270 (emphasis added).
+
+
+29.
+Following the signing of the Agreement and the modifications thereto, Epstein's
+performance was delayed while he sought higher level review within the Department of Justice.
+See U.S. Attorney's Correspondence passim.
+30.
+On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI
+advising them that "[t]his case is currently under investigation. This can be a lengthy process
+and we request you continued patience while we conduct a thorough investigation." See Doc.
+#14 (attachments 3 and 4 to declaration of A. Marie|
+) (emphasis added). The statement
+in the notification letter was false. The case was not currently "under investigation." To the
+contrary, the case had been resolved by the non-prosecution agreement entered into by Epstein
+and the U.S. Attorney's Office discussed previously. Moreover, the FBI did not notify Jane Doe
+#1 or Jane Doe #2 that a plea agreement had been reached previously, and that part of the
+agreement was a non-prosecution agreement with the U.S. Attorney's Office for the Southern
+District of Florida. Edwards Declaration at xxxx.
+31.
+In early 2008, Jane Doe #1 and Jane Doe #2 came to believe that criminal prosecution
+of Epstein was extremely important. The also desired to be consulted by the FBI and/or other
+representatives of the federal government about the prosecution of Epstein. In light of the letters
+that they had received around January 10, they believed that a criminal investigation of Epstein
+was on-going and that they would be contacted before the federal government reached any final
+resolution of that investigation. Edwards Declaration at xxxx.
+32.
+On about February 25, 2008, Assistant U.S. Attorney Jay Sloman sent an e-mail to Jay
+Lefkowitz, Epstein's criminal defense counsel, explaining that the Justice Department's Child
+Exploitation Obscenity Section (CEOS) had agreed to review Epstein's objections to the
+proposed plea agreement that had been reached with the U.S. Attorney's Office for the Southern
+
+
+District of Florida. The letter indicated that, should CEOS reject Epstein's objections to the
+agreement, then "Mr. Epstein shall have one week to abide by the terms and conditions of the
+September 24, 2007 Agreement as amended by letter from United States Attorney Acosta to Jay
+Lefkowitz." U.S. Attorneys Correspondence at 290-91.
+33.
+In about April 2008, Jane Doe #1 contacted the FBI because Epstein's counsel was
+attempting to take her deposition and private investigators were harassing her. Assistant U.S.
+Attorney A. Marie
+secured pro bono counsel to represent Jane Doe #1 and several
+other identified victims in connection with the criminal investigation. Pro bono counsel was able
+to assist Jane Doe #1 in avoiding the improper deposition. AUSA
+secured pro bono
+counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in
+Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms.
+Garvin was not advised that a non-prosecution agreement had been reached in this matter.
+34.
+In mid-June 2008, Mr. Edwards contacted AUSA
+to inform her that he
+represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to provide
+information about the federal crimes committed by Epstein, hoping to secure a significant federal
+indictment against Epstein. AUSA
+and Mr. Edwards discussed the possibility of
+federal charges being filed. At the end of the call, AUSA
+asked Mr. Edwards was
+asked to send any information that he wanted considered by the U.S. Attorney's Office in
+determining whether to file federal charges.
+Because of the confidentiality provision that existed
+in the plea agreement, Mr. Edwards was not informed that previously, in September 2007, the
+U.S. Attorney's Office had reached an agreement not to file federal charges.
+Mr. Edwards was
+also not informed that any resolution of the criminal matter was imminent. Edwards Declaration
+at xxxxxx.
+
+
+35.
+On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA
+received a copy
+of Epstein's proposed state plea agreement and learned that the plea was scheduled for 8:30 a.m.,
+Monday, June 30, 2008. AUSA
+and the Palm Beach Police Department attempted to
+provide notification to victims in the short time that Epstein's counsel had provided. Attorney
+Edwards was called to provide notice to his clients regarding the hearing. AUSA |
+did
+not tell Attorney Edwards that the guilty pleas in state court would bring an end to the possibility
+of federal prosecution pursuant to the plea agreement. Edwards Declaration at xxxxxx.
+36.
+On June 30, 2008, AUSA
+sent an e-mail to Jack Goldberger, criminal defense
+counsel for Epstein, that stated: "Jack: The FBI has received several calls regarding the Non-
+Prosecution Agreement. I do not know whether the title of the document was disclosed when the
+Agreement was filed under seal, but the FBI and our office are declining comment if asked."
+U.S. Attorney's Correspondence at 321.
+37.
+On July 3, 2008, Mr. Edwards sent to AUSA
+a letter. See Affidavit of Bradley
+J. Edwards, Esq., at xxxxxx (attachment 2). In the letter, Mr. Edwards indicated his client's
+desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of
+his clients: "We urge the Attorney General and our United States Attorney to consider the
+fundamental import of the vigorous enforcement of our Federal laws. We urge you to move
+forward with the traditional indictments and criminal prosecution commensurate with the crimes
+Mr. Epstein has committed, and we further urge you to take the steps necessary to protect our
+children from this very dangerous sexual predator." When Mr. Edwards wrote this letter, he was
+still unaware that a non-prosecution agreement had been reached with Epstein - a fact that
+continued to be concealed from him (and the victims) by the U.S. Attorney's Office. Mr.
+Edwards first saw a reference to the NPA on or after July 9, 2008, when the Government filed its
+
+
+responsive pleading to Jane Doe's emergency petition. That pleading was the first public
+mention of the non-prosecution agreement and the first disclosure to Mr. Edwards (and thus to
+Jane Doe #1 and Jane Doe #2) of the possible existence of a non-prosecution agreement.
+Edwards Declaration at xxxx.
+38.
+On July 9, 2008, AUSA
+sent a victim notification to Jane Doe #1 via her
+attorney, Bradley Edwards, which is attached as Exhibit 6 to the
+Declaration. That
+notification contains a written explanation of some of the terms of the agreement between
+Epstein and the U.S. Attorney's Office. A full copy of the terms was not provided. A
+notification was not provided to Jane Doe #2 because the agreement limited Epstein's liability to
+victims whom the United States was prepared to name in an indictment. As a result, Jane Doe #2
+never received a notification a letter about the agreement. The notification did not mention the
+non-prosecution agreement with the U.S. Attorney's Office. Edwards Declaration at xxxx.
+39. On July 9, 2008, AUSA
+filed a sworn declaration with the Court in connection
+with the case (doc. #14). The declaration purported to recount limit parts of the non-prosecution
+agreement and stated that "these provisions were discussed" with several victims, including Jane
+Doe #1. Id. at 4.
+40.
+On July 11, 2008, the Court held a hearing on Jane Doe #1 and Jane Doe #2's Emergency
+Petition for Enforcement of Rights. During the hearing, the Government conceded that Jane Doe
+#1 and Jane Doe #2 were "victims" within the meaning of the Crime Victim's Rights Act. Tr. at
+14-15.
+41. During the July 11 hearing, the Court and the parties discussed the fact that the petition
+should not be treated as an "emergency" petition because there was not any particular rush to
+ruling on it. Tr. at 24-25.
+The Court further discussed a need to "hav[e] a complete record, and
+
+
+this is going to be an issue that's ... going to go to the Eleventh Circuit, [s] it] may be better to
+have acomplete record as to what your position is and the government's is as to what actions
+were taken. And I don't know if I have enough information, based on Ms. Villafana's affidavit
+or I need additional information. And because it is not an emergency, I don't have to do
+something quickly, we can play it b[y] ear and make this into a more complete record for the
+court of appeals." Tr. at 25-26. (
+Counsel for Jane Doe #1 and Jane Doe #2 explained: " ...
+Your Honor is correct in stating that it is not an emergency and it doesn't need to happen today.
+And, I will confer with the government on this and if evidence needs to be taken, it [can] be
+taken at a later date. It doesn't seem like there will be any prejudice to any party [from delay]."
+Tr. at 26. The hearing concluded: "So I'll let both of you confer about whether there is a need
+for any additional evidence to be presented. Let me know one way or the other. If there is, we'll
+schedule a hearing. If there isn't and you want to submit some additional stipulated information,
+do that, and then I'll take care of this in due course." Tr. at 32. The Court then adjourned, taking
+the victims' petition under advisement.
+42. The U.S. Attorney's Office and the victims then attempted to reach a stipulated set of facts
+underlying the case. The U.S. Attorney's Office set a proposed set of facts, and the victims sent
+a counter-proposal. Rather than respond to the victims' proposal, however, the U.S. Attorney's
+Office suddenly reversed course. (Doc. #19 at 2). On July 29, 2008, it filed a Notice to Court
+Regarding Absence of Need for Evidentiary Hearing (doc. #17). The Government took the
+position that, because no federal criminal charges had been filed in the Southern District of
+Florida, no additional evidence was required to decide the petition before the Court.
+43. On August 1, 2008, Jane Doe #land Jane Doe #2 filed (doc. #19) a response to the
+Government's "Notice."
+In the response, Jane Doe #1 and Jane Doe #2 gave a proposed
+
+
+statement of facts surrounding the case. The proposed statement of fact was based on the
+information available to the victims at that time. The proposed statement of facts highlighted the
+fact that the Government had signed a non-prosecution agreement containing an express
+confidentiality provision, which prevented the Government from disclosing the agreement to
+them and other victims. Id. at 5. The response also noted that the Court had taken the victims'
+petition under advisement. The response further noted that the Government had not attempted to
+work with the victims to draft a full set of undisputed facts and had refused the victims' efforts to
+obtain documents relevant to the case. Id. at 9. The victims response also requested that the
+Court direct the Government to confer with the victims regarding the undisputed facts of the
+case, produce the non-prosecution agreement at issue in the case, and produce an FBI Report of
+Interview with Jane Doe #1. The response also requested that the Court enter judgment for the
+victims' on their petition finding a violation of rights and schedule a hearing on the appropriate
+remedy. Id. at 14.
+44.On August 14, 2008, the Court held a hearing on the case. No schedule for further
+proceedings was established at that hearing.
+45. On October 9, 2008, Bradley J. Edwards, counsel for Jane Doe #1 and Jane Doe #2, sent a
+letter to counsel for the U.S. Attorney's Office in this case advising that two possibly false
+statements had been made to the Court in the July 9th sworn declaration of AUSA |
+See
+Oct. 9, 2008, Letter from Bradley J. Edwards to Marie
+at 1, Attachment xxxx to
+Edwards Declaration. First, while Ms.
+had described a term as being part of the plea
+agreement with Epstein, that term later became defunct, at least in the view of Epstein's
+attorneys (and apparently acceded to by the U.S. Attorney's Office). Second, Ms.
+had
+
+
+said that "four victims [including C.W. - i.e., Jane Doe #1] were contacted and these provisions
+were discussed," it was not clear what provisions had in fact been discussed.
+46. On December 22, 2008, AUSA Marie l
+filed a supplemental affidavit, "correcting"
+the statement made in her July 8, 2008, declaration about the terms of the plea agreement (doc.
+#35). The supplemental affidavit stated that "part 3" of the agreement with defendant Epstein
+was, in the view Epstein' legal counsel no longer operative. The supplemental affidavit,
+however, did not clarify what terms of the agreement had been discussed.
+47. On April 9, 2009, counsel for Jane Doe #1 and Jane Doe #2 sent to the Court in this case
+(via the PACER system) a notice of a change of law firm affiliation. Doc. #37.
+48. In approximately May 2009, counsel for Jane Doe #1 and Jane Doe #2 propounded
+discovery requests in both state and federal civil cases against Epstein, seeking to obtain
+correspondence between Epstein and prosecutors regarding his plea agreement - information that
+the U.S. Attorney's Office was unwilling to provide to Jane Doe #1 and Jane Doe #2. Epstein
+refused to produce that information, and extended litigation to obtain the materials followed.
+Edwards Declaration at xxxxx.
+49. Because of this extended litigation, Jane Doe #1 and Jane Doe #2 did not have access to
+important correspondence demonstrating a violation of their rights until June 30, 2010. On that
+day, counsel for Epstein sent to Bradley J. Edwards, Esq., legal counsel for Jane Doe #1 and Jane
+Doe #2, approximately 358 pages of e-mail correspondence between his legal counsel and the
+U.S. Attorney's Office for the Southern District of Florida regarding the plea agreement that had
+been negotiated between them. See Attachment 1 to Edwards Aff. These e-mail disclosed for
+the first time the steps that had been taken by the U.S. Attorney's Office to avoid having the
+victims in the case learn about the non-prosecution agreement that had been reached between
+
+
+Epstein and the Government.
+Litigation continues to this day to obtain the correspondence
+regarding
+the state prosecution and regarding
+what Epstein's attorneys said in the
+correspondence with the prosecutors. Edwards Declaration at xxxxxx.
+50. In mid-July 2010, Jane Doe #1 and Jane Doe #2 settled their civil lawsuits against Mr.
+Epstein. Notice of this fact was promptly provided to the Court. Edwards Declaration at xxx.
+51. On September 8, 2010, the Court entered an order stating that "[a]n examination fo the
+docket reveals that no activity has taken place in this case since April of 2009. In light of the
+underlying settlements between the victims and Mr. Epstein, it is hereby ordered and adjudged
+that this case is closed." Doc. #38.
+52. Promptly on the heels of this administrative order, on September 13, 2010, Jane Doe #1 and
+Jane Doe #2 filed a notice that they "intend to make subsequent filing in the case shortly. They
+accordingly request administrative reopening of the case and, if the Court deems it advisable, a
+scheduling conference with the U.S. Attorney's Office regarding the case." Doc. #39 at 1. They
+further advised the Court that their settlements with Jeffrey Epstein in no way affected "their
+determination to move forward with the above-captioned CVRA action against a different entity
+- the U.S. Attorney's Office for the Southern District of Florida." Id. at 2. The pleading further
+advised that "Tilf the Court wishes to proceed to an expeditious conclusion to this Case, Jane Doe
+#1 and Jane Doe #2 have no objection to the Court setting up an expedited schedule for
+proceeding on the case." Id. The pleading further advised that the reason the victims had not
+filed for summary judgment in the case was that they had been attempting to secure
+correspondence between the U.S. Attorney's Office and Epstein to corroborate their argument
+that the Office had violated their rights. They noted that they had just secured half of that
+
+
+correspondence two months earlier.
+Id. at 2. The victim asked that, "if the Court deems it
+advisable, that a scheduling conference be set for this case."
+53. At all times material to this statement of facts, it would have been practical and feasible for
+federal government to inform Jane Doe #1 and Jane Doe #2 of the details of the proposed nonprosecution agreement with Epstein, including in particular the fact that the agreement barred
+any federal criminal prosecution. Edwards Declaration at xxxx.
diff --git a/vision-fixhub/ds9-unparsed-06/2992a202f9ab29f3f6abb13e46b45bcd0f03bc3e7552cdd121a226e73aa5a5d2.receipt.json b/vision-fixhub/ds9-unparsed-06/2992a202f9ab29f3f6abb13e46b45bcd0f03bc3e7552cdd121a226e73aa5a5d2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..373823f38e5503001891d8d2a32e8034c5c7b9c9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2992a202f9ab29f3f6abb13e46b45bcd0f03bc3e7552cdd121a226e73aa5a5d2.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -234,
+  "dataset": "marble-joined",
+  "doc_id": "2992a202f9ab29f3f6abb13e46b45bcd0f03bc3e7552cdd121a226e73aa5a5d2",
+  "engine": "marble-apple-vision",
+  "event_count": 22,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "dc56959425efdd9335d38a154c151a36b0a28cfcf5dfb3559a0b9d4a70dc8e0c",
+  "output_sha256": "3b676ec9dbbc44c192f81c0c2c721766b233042092831dfc756425ff8233b113",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2ad5b3c2279698b7d052818116a127a16c2b3304c815d4d69de292dbdee849f8.md b/vision-fixhub/ds9-unparsed-06/2ad5b3c2279698b7d052818116a127a16c2b3304c815d4d69de292dbdee849f8.md
new file mode 100644
index 0000000000000000000000000000000000000000..0c88015f7441030a0bfaaaff831f174ffbd8c603
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2ad5b3c2279698b7d052818116a127a16c2b3304c815d4d69de292dbdee849f8.md
@@ -0,0 +1,147 @@
+Paul G. Cassell, Esq.
+399 0 1 100 г
+October 23, 2010
+U.S. Attorney's Office
+for the Southern District of Florida
+99 N.E. 4'h Street
+Miami, FL 33131 Via
+Re: Protecting the Rights of Jane Doe #1 and Jane Doe #2
+Dear Dexter:
+First, as mentioned before, please feel free to call me "Paul rather than "Judge Cassell."
+Brad Edwards and I hope to build a close and friendly working relationship with you as we
+proceed with our efforts to protect victims' rights. Also, if you could copy told on our e-mails,
+that would be helpful at our end. (Do you want me to "cc"l
+On behalf of Jane Doe #1 and Jane Doe #2 ("the victims"), I am writing to respond to the
+e-mail you sent to me yesterday. I am happy to hear that the Government will now agree with
+factual assertions that we present if they are correct. Attached along with this letter is a draft
+statement of facts section that the victims are in the process of preparing to file with the Court on
+October 27, 2010. The victims of course request your agreement to all of the facts presented
+there, as they obviously believe that they are all correct.
+If you believe that any of the facts they propose are incorrect, Jane Doe #1 and Jane Doe
+#2 would reiterate their long-standing request that you work with us to arrive at a mutuallyagreed statement of facts. As you know, in the summer of 2008 Jane Doe #1 and Jane Doe #2
+were working with you on a stipulation of facts when you reversed course and took that position
+that no recitation of the facts was necessary (see doc. #19 at 2). In particular, on July 29, 2008,
+you filed a Notice to Court Regarding Absence of Need for Evidentiary Hearing (doc. #17). At
+that time, you took the position that, because no federal criminal charges had been filed in the
+Southern District of Florida, no additional evidence was required to decide the victims' petition
+that was before the Court. I hope that your e-mail means that you will at least look at our facts
+and propose any modifications that you deem appropriate. Having that evidence quickly
+available to the Court could well help move this case to a conclusion.
+As you also know, because of the Government's decision not to work with us on agreed
+facts, we have had to secure information regarding the basis for your Office's treatment of the
+1
+
+
+victims from other sources. This has been an arduous process, since the only remaining source
+for much of the information was Jeffrey Epstein. As you know, he is a politically-connected
+billionaire that employs legions of attorneys to obstruct any efforts to obtain information from
+him. Fortunately, after extended litigation, on June 30, 2010, we obtained information from him
+that was highly relevant to the treatment of Jane Doe #1 and Jane Doe #2 in the criminal justice
+system - namely, correspondence between your Office and legal counsel for Jeffrey Epstein
+during the negotiations surrounding the non-prosecution agreement. Many of our "facts" come
+straight from these e-mails. I trust that you will agree that our recitations of the e-mails are
+correct and that they accurately reflect communications between your Office and Epstein's legal
+counsel during the plea negotiation process.
+As you will note, Epstein's legal counsel redacted half of the correspondence -
+specifically, all statements made by them to your Office. While this was done in violation of the
+court-ordered production, we never obtained a ruling on our motion for contempt because
+Epstein settled his civil cases with the victims shortly after we filed the contempt motion. Of
+course, that undisclosed half of the correspondence remains highly relevant to the issues under
+discussion in this CVRA case. We are continuing to try to obtain that information in Florida
+state court. While we have previously been politely rebuffed by you in our efforts to gain more
+information about Jane Doe #1 and Jane Doe #2's treatment, I wanted to make one more request
+to you to provide (in particular) the other half of the correspondence connected with the nonprosecution agreement. This correspondence would be highly useful to the victims, as well as to
+the Court, in developing a complete factual recording surrounding the victims' treatment.
+On another note, I was surprised to see in your e-mail what seemed to be a request for the
+victims to file a formal civil complaint. In particular, you stated: "No complaint has been filed
+[by the victims], which is the normal mechanism for commencing a civil action. Consequently,
+the government has not filed an answer." In July 2008, we elected to file a petition on behalf of
+Jane Doe #1 and Jane Doe #2 asking the Court to declare a CVRA violation - rather than a civil
+complaint. I have been involved in CVRA enforcement actions across the country at all levels of
+the federal courts, and this approach is the normal one for these courts (including courts of this
+Circuit). See, e.g., In re Stewart (11"h Cir. 2008) (CVRA enforcement action commenced by
+motion); In re Antrobus (10" Circuit 2008) (same); In re Dean (5'" Cir. 2008) (same). Indeed, in
+an important case in the District of Montana involving enforcement of victims' rights in the
+W.R. Grace case, I proceeded in this fashion at the direction of the Justice Department (i.e., the
+U.S. Attorney for the District of Montana, with whom we were working closely). In re Parker
+(9t Cir. 2009). So far as I can recall, in none of our previous discussions in this case have you
+raised the suggestion that a civil complaint was necessary to the resolution of this matter. Nor
+have you raised any such suggestion in court on previous hearings in this case. Would you be
+willing to explain what procedural steps you think we need to bring this matter to a conclusion?
+That way we can work with you to avoid unnecessary procedural wrangling. The Justice
+Department is, of course, statutorily obligated to use its "best efforts" to "see that crime victims
+are ... accorded the rights described in [the CVRA]." 18 U.S.C. § 3771(c)(1). Raising
+previously-undisclosed procedural objections to crime victims' efforts to protect their rights does
+not seem consistent with your Office's statutory obligations.
+
+
+I was also surprised to read in your e-mail the statement that "[wle will also be seeking
+dismissal on the ground of failure to prosecute." On behalf of Jane Doe #1 and Jane Doe #2, I
+respectfully ask you to reconsider that decision to attempt to throw another procedural roadblock
+in the path of the victims as they seek to secure their rights. Any such motion would not be
+legally well-founded. And I would be less than candid if I did not report to you our perception
+that, with all due respect, such a motion would smack of Government sandbagging of the
+victims. We presume that you and others in your office (i.e., Assistant U.S. Attorney Marie
+Villafaña) have been well aware of Jane Doe #1's and Jane Doe #2's efforts that past year-and-a-
+half to obtain information from Epstein relevant to their CVRA case. And during that time,
+Bradley J. Edwards and I have had many formal (and informal) contacts with the U.S. Attorney's
+Office. Until yesterday, no one in the Office has ever suggested that we had been less than
+diligent in pursuing the CVRA case or that we needed take steps other than the ones we were
+pursuing. For example, as you know, on September 13, 2010, we filed with the Court a notice in
+this CVRA case regarding our intention to make additional filings shortly. In that notice, we
+specifically offered to the Court (if it thought it helpful) to set up a scheduling conference with
+your Office to bring the case to an expeditious conclusion. That notice was served on your
+Office via the PACER electronic filing system. Yet, in spite of that offer to set up a scheduling
+conference made more than a month ago, your Office said nothing to the victims about doing so
+- until informing them yesterday of your intent to argue that we have failed to diligently
+prosecute the action.
+Jane Doe #1 and Jane Doe #2 believe that any such motion to dismiss their case would
+violate your Office's statutory obligations to use its "best efforts" to protect their rights. 18
+U.S.C. § 3771(c)(1). To make a motion to dismiss for failure to prosecute, your Office would be
+required to assume the truth of the allegations made by the victims (i.e., that your Office has
+violated their rights under the CVRA) but nonetheless move to dismiss their case. Your Office
+has never communicated to the victims any belief that any deadline was pending in the CVRA
+case or that our approach of attempting to obtain information through litigation with Epstein was
+somehow taking too long. A phone call or e-mail to us at any point during the process would
+have alerted us to your view on the issue and allowed us to work with you to address any
+concerns that you had about moving this case more rapidly. I respectfully submit that your
+silence on any need to move more quickly — at the same time as we were repeatedly in connect
+with Justice Department representatives - should lead you not to file any such failure-toprosecute motion.
+If after reviewing Jane Doe #1 and Jane Doe #2's points in this letter you still believe
+such a motion is appropriate, I respectfully request that you extend to them the same
+consideration that you extended to Jeffrey Epstein, the man who repeatedly sexually abused
+them. In particular, we would respectfully request an opportunity to confer and discuss such a
+motion before it is filed with: (1) The First Assistant U.S. Attorney in your Office; (2) if
+necessary, the U.S. Attorney; and (3) if necessary, the Child Exploitation and Obscenity Section
+of the Criminal Division of the Justice Department (CEOS).
+As we have now learned from reading the e-mails, your Office decided to enter into a
+non-prosecution agreement with Jeffrey Epstein( and make numerous other concessions to him)
+only after his legal representatives were allowed to plead his case to the First Assistant, the U.S.
+3
+
+
+Attorney, and CEOS through repeated meetings, telephone calls, e-mails, and letters. These
+discussions appear to have been far more extensive than is normally allowed to criminal
+defendants (particularly sex offenders) prosecuted by your Office.
+Unlike Epstein, Jane Doe #1 and Jane Doe #2 do not come from a wealthy background
+and lack political power. They nonetheless respectfully ask your Office to extend to them the
+same opportunities to protect their interests as you extended to him. Unlike Epstein - a man who
+committed numerous federal sexual offenses - they are innocent victims. Unlike Epstein - who
+had no right to engage in plea bargaining with your Office - they have a congressionallypromised "right" to "confer with the attorney for the Government in the case." 18 U.S.C. §
+3771(a)(5). Before taking any action that will prevent them from protecting their rights -
+including in particular filing a motion to dismiss - we respectfully request the same conferral
+rights that you gave Mr. Epstein with the First Assistant, the U.S. Attorney, and (if necessary)
+CEOS.
+Finally, Mr. Edwards and I stand ready to work with you to narrow the range of issues
+under consideration in this case. The newly-revealed e-mails appear to make it clear that your
+Office made a decision not to inform that Jane Doe #1 and Jane Doe #2 (and other victims) about
+the non-prosecution agreement. If you would be willing to stipulate to that fact - and then fully
+pursue your legal arguments and responses to the significance of that fact - this might help to
+move the case along to a more expeditious conclusion. We would appreciate the opportunity to
+discuss this idea with you in a telephone conference call at a mutually convenient time.
+Thank you again for your willingness to discuss all these issues. We look forward to
+continuing to work with you to protect the rights of Jane Doe #1 and Jane Doe #2.
+Sincerely,
+Paul G. Cassell
+Counsel for Jane Doe #1 and Jane Doe #2
+4
diff --git a/vision-fixhub/ds9-unparsed-06/2ad5b3c2279698b7d052818116a127a16c2b3304c815d4d69de292dbdee849f8.receipt.json b/vision-fixhub/ds9-unparsed-06/2ad5b3c2279698b7d052818116a127a16c2b3304c815d4d69de292dbdee849f8.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..fa73ded0645b0f1e4cbc4a8352e40d7c7d071362
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2ad5b3c2279698b7d052818116a127a16c2b3304c815d4d69de292dbdee849f8.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -56,
+  "dataset": "marble-joined",
+  "doc_id": "2ad5b3c2279698b7d052818116a127a16c2b3304c815d4d69de292dbdee849f8",
+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "33a4ea158e2e30f398abe5c49d267271fcc6a2e17335c6603ffabdadac5ccf27",
+  "output_sha256": "efac06106471423194ff21cbd7c59c0ae85f90fc119ac7c88b3d11bbd0cdf521",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2be8440c4bedd06de0fa5482dd546f319f517951d3e6239509600fda493d5312.md b/vision-fixhub/ds9-unparsed-06/2be8440c4bedd06de0fa5482dd546f319f517951d3e6239509600fda493d5312.md
new file mode 100644
index 0000000000000000000000000000000000000000..20ce36b040ac8ae3d824a8e0f5bb6ef28b246636
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2be8440c4bedd06de0fa5482dd546f319f517951d3e6239509600fda493d5312.md
@@ -0,0 +1,86 @@
+From:
+To:
+Subject: Re: FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GCO File No.
+REC-11-4159)
+Date: Mon, 03 Oct 2011 16:02:25 +0000
+Importance: Normal
+Nope.
+is the
+in MDFL. I'II reach out to him in the next day or so.
+From:
+To:
+Sent: Monday, October 03, 2011 12:00 PM
+Subject: FW: FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GCO File No. REC-11-4159)
+HiLl
+• - Did you ever get the name of a line AUSA? I just let a message on
+but wondered whether you had heard anything.
+secretary's voicemail,
+Assistant U.S. Attorney
+Subject: FW: FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GCO File No. REC-11-4159)
+From:
+To:
+Sent: Wednesday, August 24, 2011 7:28 PM
+FYI.
+From:
+-
+Sent: Wednesday, August 24, 2011 3:32 PM
+To:
+Cc:
+Subject: FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GCO File No. REC-11-4159)
+MEMORANDUM FOR:
+Wifredo A. Ferrer
+United States Attorney
+Southern District of Florida
+
+
+First Assistant United States Attorney
+Southern District of Florida
+Robert E. O'Neill
+United States Attorney
+Middle District of Florida
+First Assistance United States Attorney
+Middle District of Florida
+THROUGH:
+General Counsel
+Executive Office for United States Attorneys
+FROM:
+Assistant General Counsel
+Executive Office for United States Attorneys
+RE:
+Office-Wide Recusal of Southern District of Florida from the Investigation
+and Potential Prosecution of Mr. Jeffery Epstein (GCO File No. REC-11-4159)
+THIS IS FORMAL NOTICE that David Margolis, Associate Deputy Attorney General (ADAG), approved the
+office-wide recusal of the United States Attorney's Office for the Southern District of Florida (SDFL) from all
+matters, to include the investigation and potential prosecution, relating to Jeffrey Epstein's alleged sexual
+activities with minor females. The ADAG authorized this recusal in accordance with United States Attorney's
+Manual (USAM) 3-2.170 and United States Attorney's Procedures (USAP) 3-2.170.001 based upon existing
+conflicts of interest or the appearance of conflicts of interest pertaining to the matter.
+ADAG Margolis has assigned this matter to the United States Attorney's Office for the Middle District of Florida
+and, pursuant to 28 U.S.C. ' 515(a), has directed and authorized United States Attorney Robert E. O'Neill to
+conduct any kind of legal proceeding, civil or criminal, including grand jury proceedings and proceedings before
+committing magistrate judges, which the United States Attorney for the Southern District of Florida is authorized
+by law to conduct regarding this matter. See USAP 3-2.170.001(6)(C)(2)(b).
+Each office should communicate directly with each other concerning the investigations related to this matter in
+accordance with the procedures outlined in USAP 3-2.170.001(6)(C)(2)(b)(3). The point of contact for the
+Middle District of Florida is Criminal Chief
+who can be contacted at
+The point of
+contact for the Southern District of Florida is First Assistant United States Attorney
+who
+can be reached at
+
+
+All Assistant United States Attorneys subsequently assigned to this matter must be appointed as Special
+Attorneys in order to appear on behalf of the government in the Southern District of Florida. See USAM, 3-
+2.300 and USAP 3-2.170.001(g)(C)(2)(b). Please contact Nicole West, EOUSA Personnel Staff, Policy and
+Special Programs Division, at
+In accordance with USAP 3-2.170.001(6)(C)(2)(b)(3), any Special Attorney assigned the matter or case should
+sign any pleadings or documents using the signature block of the Middle District of Florida, with the addition of
+the Attorney General's name preceding that of the United States Attorney.
+If you have any questions relating to this recusal matter, please contact Assistant General Counsel|
+General Counsel's Office, EOUSA, at
+Thank you.
+Thank you,
+Assistant General Counsel
+General Counsel's Office
+Executive Office for United States Attorneys
diff --git a/vision-fixhub/ds9-unparsed-06/2be8440c4bedd06de0fa5482dd546f319f517951d3e6239509600fda493d5312.receipt.json b/vision-fixhub/ds9-unparsed-06/2be8440c4bedd06de0fa5482dd546f319f517951d3e6239509600fda493d5312.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0f63dd6e7a2b2c65c419f5d98ac767b8c5ac75f6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2be8440c4bedd06de0fa5482dd546f319f517951d3e6239509600fda493d5312.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "2be8440c4bedd06de0fa5482dd546f319f517951d3e6239509600fda493d5312",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "0473b79e143556beed04cfbee46efc6a3a824e694097afe4726075c008d686cf",
+  "output_sha256": "3de8f6f4da8c19a5b1cfd6baeab99cd5029ce533c19907ff35a68424529297ab",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2d04c24f5d240b758266a0fdc87de1d059382a15cc72ba6150153cbdca6adbb3.md b/vision-fixhub/ds9-unparsed-06/2d04c24f5d240b758266a0fdc87de1d059382a15cc72ba6150153cbdca6adbb3.md
new file mode 100644
index 0000000000000000000000000000000000000000..dcc2657f71f285315df7583a7d1ec60d179c7001
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2d04c24f5d240b758266a0fdc87de1d059382a15cc72ba6150153cbdca6adbb3.md
@@ -0,0 +1,25 @@
+From:
+To:
+Subject: Re: Jane Does v United States
+Date: Fri, 16 Sep 2011 14:36:23 +0000
+Importance: Normal
+Thanks. I will call vou late this afternoon. I am in training until 2:00
+AUSA
+•- Original Message .....
+From: Brad Edwards
+Sent: Fridav Sentember 16,201 DREAM
+To:
+Subject: Re: Jane Does v United States
+Of course not. Talk to you soon.
+--Original Message-....-
+From:
+To: Brad Edwards
+To:
+Subject: Jane Does v United States
+Sent: Sep 16, 2011 8:28 AM
+Dear Brad and Roy:
+I was in Bogota for 10 days where my phone didn't work and I had very limited access to email so I have a lot of catching up to do. Do you
+have any objection to a ten day extension of time to respond to Mr Epstein's motion?
+Thank you
+AUSA
+Sent via BlackBerry by AT&T
diff --git a/vision-fixhub/ds9-unparsed-06/2d04c24f5d240b758266a0fdc87de1d059382a15cc72ba6150153cbdca6adbb3.receipt.json b/vision-fixhub/ds9-unparsed-06/2d04c24f5d240b758266a0fdc87de1d059382a15cc72ba6150153cbdca6adbb3.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..01f8af1097b858e6e276abc5d35da0ba4028d6c7
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2d04c24f5d240b758266a0fdc87de1d059382a15cc72ba6150153cbdca6adbb3.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "2d04c24f5d240b758266a0fdc87de1d059382a15cc72ba6150153cbdca6adbb3",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "5d0aef5190e9dae6772837a23c56083044db5b5094f0c327ae4f4028f1e84191",
+  "output_sha256": "814d4b31b361ac4edd3061fdfa08f4932fdea4f2fc6da9a335fc6c3558587c58",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2d407c0932e41a89991a0389950de57604d40106a522b82d5529961abc67fd92.md b/vision-fixhub/ds9-unparsed-06/2d407c0932e41a89991a0389950de57604d40106a522b82d5529961abc67fd92.md
new file mode 100644
index 0000000000000000000000000000000000000000..797959fe405b987108c082841123fcb4de3ab37e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2d407c0932e41a89991a0389950de57604d40106a522b82d5529961abc67fd92.md
@@ -0,0 +1,28 @@
+From:
+To:
+C. (USAFLS)
+Subject: JE
+Date: Fri, 01 Dec 2006 13:39:51 +0000
+Importance: Normal
+I hope that the two weeks you will be out of the district is for a
+well-deserved vacation. I have been so busy lately that I am also
+looking forward to taking some time off closer to the end of the year.
+I am planning to be out of the office the weeks of Dec. 18 and Dec. 25
+to spend much quality time with my son who is now 8 years old and
+growing up too fast. Since it looks like we will miss each other before
+the New Year, I will be in touch at that time and hopefully we will be
+able to meet shortly thereafter. In the interim, I will check on the
+document requests you made and get back to you.
+Regards.
+Esq.
+FOWLER WHITE BURNETT P.A.
+Espirito Santo Plaza, 14th Floor
+>>>"
+_ (USAFLS)"
+P 11/17/2006 9:22 AM >>>
+Hi
+-- This is the correct e-mail address. I hope that you
+received the letter that I faxed yesterday. I will be out of the office
+today, but I will be back on Monday.
+Thank you.
+Assistant U.S. Attorney
diff --git a/vision-fixhub/ds9-unparsed-06/2d407c0932e41a89991a0389950de57604d40106a522b82d5529961abc67fd92.receipt.json b/vision-fixhub/ds9-unparsed-06/2d407c0932e41a89991a0389950de57604d40106a522b82d5529961abc67fd92.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b8838787e249b3afd062ae5e9d002d1342000676
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2d407c0932e41a89991a0389950de57604d40106a522b82d5529961abc67fd92.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "2d407c0932e41a89991a0389950de57604d40106a522b82d5529961abc67fd92",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "bea35cc951a58b0f23dc47175c85514c86604e7886eb691d12d56f2b375ce75b",
+  "output_sha256": "bc65d44e7e96c399e1473966f200162a329170c1749d091192ab110d7a5e2178",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2d543fb36dcd82a302933b3262eb95843236d5dee2ffcd6bed07b6344df7dd55.md b/vision-fixhub/ds9-unparsed-06/2d543fb36dcd82a302933b3262eb95843236d5dee2ffcd6bed07b6344df7dd55.md
new file mode 100644
index 0000000000000000000000000000000000000000..6843bc7f3359c5967af1efb781683f99809bbe4c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2d543fb36dcd82a302933b3262eb95843236d5dee2ffcd6bed07b6344df7dd55.md
@@ -0,0 +1,55 @@
+From:
+To:
+to File
+Date: Thu, 11 Feb 2010 19:13:22 +0000
+Importance: Normal
+Subject: Activity in Case 9:08-cv-80119-KAM Doe v. Epstein Order on Motion for Extension of Time
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 2/11/2010 at 2:13 PM EST and filed on 2/11/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 468
+Doe v. Epstein
+9:08-CV-80119-KAM
+Docket Text:
+ORDER granting in part and denying in part [464] Motion for Extension of Time to File Appeal.
+Deadline extended to 2/26/10. Signed by Judge Kenneth A. Marra on 2/11/2010. (ir)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+Bradley James Edwards
+Isidro Manuel Garcia
+Jack Alan Goldberger
+Jack Patrick Hill
+Jeffrey Mare Herman
+Katherine Warthen Ezell
+
+
+Michael James Pike
+Paul G. Cassell
+Richard Horace Willits
+Robert C. Josefsberg
+Robert Deweese Critton, Jr
+Stuart S. Mermelstein
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-
+1.:
+Martin G. Weinberg
+20 Park Plaza
+Boston, MA 02116
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=2/11/2010] [FileNumber=7251065-0
+][541be2e9137еб8b011ba2cbd75fа753fе08fc8edafd9a13bЗе0cc45042667d51b16
+a4e394fe2552218a4b4b999fab7786f1250b40de1f06028ef896ебebd729f]]
diff --git a/vision-fixhub/ds9-unparsed-06/2d543fb36dcd82a302933b3262eb95843236d5dee2ffcd6bed07b6344df7dd55.receipt.json b/vision-fixhub/ds9-unparsed-06/2d543fb36dcd82a302933b3262eb95843236d5dee2ffcd6bed07b6344df7dd55.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7f5e9d74fdd9f241075faddcc7b076fa5644a42d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2d543fb36dcd82a302933b3262eb95843236d5dee2ffcd6bed07b6344df7dd55.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "2d543fb36dcd82a302933b3262eb95843236d5dee2ffcd6bed07b6344df7dd55",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "b961d5836d805b2d3a8056ed480d79131f8944490470b8f544d5d1f6c9ee35fb",
+  "output_sha256": "60fa7af55196e037a10993f47ab8cb5c2a512cb6f3bbcc17f74eea44686dd0ec",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2d54c0fd0074ab77eddc368ae4fdde4397ec4906e9107b242b0d7fdc832d9acd.md b/vision-fixhub/ds9-unparsed-06/2d54c0fd0074ab77eddc368ae4fdde4397ec4906e9107b242b0d7fdc832d9acd.md
new file mode 100644
index 0000000000000000000000000000000000000000..ab2a4b95e53462f4a93ba17376b3b871d51ec042
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2d54c0fd0074ab77eddc368ae4fdde4397ec4906e9107b242b0d7fdc832d9acd.md
@@ -0,0 +1,515 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs
+V.
+UNITED STATES,
+Defendants
+JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR PRODUCTION
+TO THE GOVERNMENT REGARDING INFORMATION RELEVANT TO THEIR
+PENDING ACTION CONCERN THE CRIME VICTIMS RIGHTS ACT
+COME NOW Jane Doe #1 and Jane Doe #2 ("the victims"), by and through undersigned
+counsel, and request the defendant United States (hereinafter "the Government") to produce the
+original or best copy of the items listed herein below for inspection and/or copying, pursuant to
+the Court's Order (DE #99) directing discovery in this case.
+BACKGROUND
+As the Government will recall, the victims have asked the Government to stipulate to
+undisputed facts in this case. The Government has declined. Accordingly, the victims filed their
+Motion for Finding of Violations of the Crime Victims' Rights Act and Request for a Hearing on
+Appropriate Remedies (DE 48) (the victims" "summary judgment motion") along with a Motion
+to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts
+(DE 49).
+On September 26, 2011, the Court denied the victims' motion to have their facts accepted
+(DE 99 at 11). At the same time, however, the Court has ordered discovery to develop the
+
+
+factual record concerning the summary judgment motion (DE 99 at 11). The Court reserved
+ruling on the victims' motion for an order directing the Government not to suppress relevant
+evidence (DE 99 at 11).
+On September 28, 2011, the victims requested that the Government voluntarily provide
+documents concerning this case. The Government declined to provide even a single document.
+Accordingly, the victims now seek the following information relevant to their pending summary
+judgment motion.
+DISCOVERY REQUESTED
+The numbered discovery requests below should all be construed in light of the definitions of
+terms provided at the end of the requests.
+1. In the victims' currently-pending summary judgment motion, the victims contend that the
+Government conducted an extensive criminal investigation into Jeffrey Epstein's sexual
+exploitation of young girls, including Jane Doe #1 and Jane Doe #2 between 2001 and 2008.
+The victims also contend that the FBI and other federal agencies established that Epstein
+operated a large criminal enterprise that used paid employees and underlings to repeatedly find
+and bring minor girls to him. In deferring ruling on the victims' summary judgment motion, the
+Court noted that the victims had alleged that the FBI and the U.S. Attorney's Office's
+"investigation developed a strong case for a federal prosecution against Epstein based on
+'overwhelming' evidence." DE 99 at 2. The Court, however, also noted that this was an
+allegation that needed "further factual development." DE 99 at 2 n.2. Please provide all
+documents, correspondence, and other information that supports these victims" allegations,
+including:
+(a) the FBI case file on the Epstein case;
+(b) all documents, correspondence, witness statements, FBI 302s, and other
+similar information, that the Government collected as part of its case against
+and/or investigation of Epstein, including any information provided to Epstein
+or receive from Epstein as part of "discovery" or exchange of information
+concerning the case;
+(c) all documents, correspondence, witness statements, and other similar
+information that the Government received from any federal, state, local, or
+other law enforcement agency regarding sex offenses committed against
+children by Jeffrey Epstein;
+(d) the 82-page prosecution memorandum (a/k/a "pros memo") outlining
+numerous federal sexual offenses committed by Epstein (and any attachments
+to that memorandum) and the 53-page draft indictment for numerous federal
+
+
+offenses that the Government developed in this case and any similar successor
+or predecessor document; and
+(e) Any other prosecution memorandum regarding Jeffrey Epstein (and any
+documents attached to that memorandum) and all draft federal indictments
+that were prepared regarding Epstein. Please also provide all documents,
+correspondence, and
+other information regarding these prosecution
+memoranda and the draft federal indictments.
+2. Throughout their pending summary judgment motion, the victims contend that they
+received only limited notifications from the Government (and, in particular, the U.S. Attorney's
+Office acting through FBI agents) about the plea negotiations that occurred with Jeffrey Epstein
+and the non-prosecution agreement that was ultimately reached. Please provide all documents,
+correspondence and other information regarding victim notifications in this case, including (but
+not limited to):
+a) All crime victims notifications (and draft notifications) sent to Jane Doe #1 and
+Jane Doe #2 and the other identified victims of Epstein's offenses;
+b) All correspondence, documents, and other information regarding negotiations
+between the Government and Epstein's defense attorneys concerning the extent
+and nature of notifications to be made to Epstein's victims;
+c) All correspondence, documents, and other information regarding discussions
+between the Government, the FBI, the Palm Beach Police Department, the Palm
+Beach County State Attorney's Office, and Epstein's defense attorneys
+concerning the extent and nature of notifications to be made to Epstein's victims;
+d) All correspondence, documents, and other information regarding "marching
+orders" that were given to FBI agents regarding the information that they could
+provide to the victims about the negotiations and the non-prosecution agreement;
+e) All correspondence, documents, and other information regarding information that
+could be given to attorneys for the victims about the non-prosecution agreement,
+including information about what could be told to Brad Edwards (counsel for Jane
+Doe #1 and Jane Doe #2) about the non-prosecution agreement;
+f) All correspondence, documents, and other information regarding Epstein's
+awareness that his victims (including Jane Doe #1 and Jane Doe #2) would not be
+notified of the non-prosecution agreement (and its ultimate presentation in court)
+or given a chance to confer regarding the plea negotiations he was conducting
+with the Government.
+3. The victims allege in their pending summary judgment motion that the Government
+negotiated a non-prosecution agreement with Epstein and that among the subjects covered in that
+non-prosecution agreement was a confidentiality provision that precluded disclosing the
+agreement to them and to other victims. Please provide all draft plea agreements (both state and
+federal) and non-prosecution agreements prepared either by attorneys for the Government or by
+attorneys for Epstein, as well as any correspondence, documents or other information pertaining
+to these agreements and to any confidentiality provision in these agreements. Please indicate
+that date on which each of these proposed agreements was drafted and by whom.
+
+
+4. The victims allege in their pending summary judgment motion that the Government was
+interested in finding a place to conclude any plea agreement that would effectively keep
+Epstein's victims (most of whom resided in or about West Palm Beach) from learning what was
+happening through the press.
+Please provide all correspondence, documents, and other
+information pertaining to negotiations between the Government and Jeffrey Epstein concerning
+the court and/or location in which Jeffrey Epstein would enter any guilty plea (including in
+particular any negotiations concerning concluding the plea in Miami or other location outside of
+West Palm Beach).
+5. The victims allege in their pending summary judgment motion that part of the plea
+negotiations with Epstein involved Epstein's efforts to make sure that the victims would be
+represented in civil cases against Epstein by someone who was not an experienced personal
+injury lawyer. Please provide all correspondence, documents, and other information pertaining
+to negotiations between the Government and Jeffrey Epstein regarding any legal representation
+of the victims in civil cases against Epstein, including any negotiations about what kinds of
+representation should be provided in a plea agreement or non-prosecution agreement.
+6. The victims allege in their pending summary judgment that the Government wanted the
+non-prosecution agreement with Epstein concealed from public view because of the intense
+public criticism that would have resulted had the agreement been disclosed and/or the possibility
+that victims would have objected in court and convicted the judge not to accept the agreement.
+Please provide all correspondence, documents, and other information concerning the
+Government's and/or Epstein awareness or discussion of this possible public criticism and/or
+victim objections.
+7. The victims allege in their pending summary judgment motion that the Government was
+aware that it potentially had obligations under the CVRA to notify the victims about the nonprosecution agreement and any related state court plea agreement. Please provide all
+correspondence, documents, and other information regarding the Government's awareness of its
+potential CVRA obligations in this case and regarding any discussions between the Government
+and Epstein concerning these CVRA obligations in this case. This should include any objections
+raised by Epstein to any notification of the victims (including Jane Doe #1 and Jane Doe #2) and
+any Government response to these objections. This should also include any correspondence and
+information about whether the CVRA applied to the victims.
+8. The victims allege in their pending summary judgment motion that, after Epstein signed
+the non-prosecution agreement, his performance was delayed while he used his significant social
+and political connections to lobby the Justice Department to obtain a more favorable plea deal
+(including lobbying components of the Justice Department in Washington, D.C., including the
+Child Exploitation Obscenity Section). Please provide all correspondence, documents, and other
+information regarding Epstein's lobbying efforts to persuade the Government to give him a more
+favorable plea arrangement and/or non-prosecution agreement, including efforts by former
+President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York),
+Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy
+Black on his behalf.
+
+
+9. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI
+advising them that "this case is currently under investigation." Please provide all documents,
+being made to the victims.
+10. In their pending summary judgment motion, the victims have alleged that the FBI was led
+to believe that their investigation of Epstein was going to produce a federal criminal prosecution
+and that the FBI was also misled by the U.S. Attorney's office about the status of the case.
+Please provide all documents, correspondence, and other information relating to these
+allegations, including:
+a) All documents, correspondence, and other information relating to discussions
+between the U.S. Attorney's Office and the FBI concerning the status of the
+investigation and the plea discussions with Epstein, as well as what kind of
+charges would appropriately be filed against Epstein;
+b) All documents, correspondence, and other information relating to the U.S.
+Attorney's Office's representations to the FBI and any other state or local law
+enforcement agency about how this case was being handled; and
+c) All documents, correspondence, and other information relating to whether the FBI
+would support the position of the U.S. Attorney's Office that it has not violated
+the rights of Epstein's victims in this case.
+11. In their pending summary judgment motion, the victims have alleged that they had
+various meetings with Government prosecutors and/or agents (including FBI agents). Related to
+these meetings, they also allege that in mid-June 2008, their attorney (Bradley J. Edwards)
+discussed with an AUSA involved in the case the need for filing federal charges and that the
+AUSA asked the attorney to send a letter about why such charges should be filed without
+disclosing the existence of a previously-signed non-prosecution agreement. The victims further
+allege that on about July 3, 2008, their attorney sent a letter urging the filing of federal charges
+against Epstein. Please provide all documents, correspondence, and other information regarding
+these meetings with the victims and their legal counsel, including meetings with the victims on
+October 26, 2007, and January 31, 2008, and the contact with their legal counsel in mid-June
+2008. Please also provide all documents, correspondence, and other information related to
+contacts between the Government and the National Crime Victim's Law Institute (NCVLD)
+concerning possible legal representation or other assistance to the victims by NCVLI.
+12. In their pending summary judgment motion, the victims allege that in mid-June 2008,
+their attorney (Bradley J. Edwards) discussed with an AUSA involved in the case the need for
+filing federal charges and that the AUSA asked the attorney to send a letter about why such
+charges should be filed without disclosing the existence of the non-prosecution agreement. The
+victims further allege that on about July 3, 2008, their attorney sent a letter urging the filing of
+federal charges against Epstein. Please provide all documents, correspondence, and other
+information regarding these contacts, including e-mails and correspondence generated as a result
+of the attorney's inquiry and any action that was taken in response to the letter that he sent.
+
+
+13. In their pending summary judgment motion, the victims allege that on or about June 27,
+2008, the Government learned that Epstein would be entering his plea to state charges on about
+June 30, 2008. Please provide all documents, correspondence, and information regarding:
+a) How the Government Office learned that the plea was going to be entered;
+b) How the Government notified victims about the entry of the guilty plea; and
+c) The contents of the notifications given to the victims about the entry of the guilty,
+including whether the victims were informed about the non-prosecution
+agreement and about whether the entry of this plea would preclude prosecution of
+crimes Epstein had committed against them.
+14. In their pending summary judgment motion, the victims have alleged that the
+Government and Epstein worked together to keep the existence of the non-prosecution
+agreement secret, including declining comment about the existence of such an agreement when
+asked about it when his guilty plea in state court became public knowledge. Please provide all
+documents, correspondence, and information about the Government's and Epstein's efforts to
+keep the existence of the non-prosecution agreement secret, including all e-mails and
+correspondence about "declining comment" or similar devices to keep the non-prosecution
+agreement secret.
+15. In their pending summary judgment motion, the victims allege that at all materials times,
+it would have been practical and feasible for the Government to have kept the victims informed
+about the discussions concerning the non-prosecution agreement. The victims further allege that
+on about July 9, 2008, the U.S. Attorney's Office provided notice to Jane Doe #1 of some of the
+terms of the agreement between it and Jeffrey Epstein. The victims also received a "corrected"
+notification letter on about September 3, 2008. Please provide all documents, correspondence,
+and other information about these notifications, including:
+a) any information about whether these notifications should or should not include
+some mention of the non-prosecution agreement;
+b) any information about the contents of these notifications;
+c) any communications between the Government and Epstein's counsel regarding
+what the notifications should contain, including any communication on or about
+July 9, 2008, objecting to parts of the draft;
+d) Any communications between the Government and Epstein's counsel about
+which parts of the non-prosecution agreement were operative (including whether
+Part 3 was operative:
+e) Any communications between the Government and Epstein's counsel regarding
+the September 3, 2008, corrected notification letter; and
+f) any documents, correspondence, and other information regarding the practicality
+and feasibility of providing notice to the victims of the existence of the
+agreement, which shall include any correspondence related to meeting with the
+victims or notifying them in any way of the non-prosecution agreement.
+16. In their pending summary judgment motion, the victims allege that one of the senior
+prosecutors in the U.S. Attorney's Office joined Epstein's payroll shortly after important
+decisions were made limiting Epstein's criminal liability - and improperly represented people
+close to Epstein. In light of this fact, the peculiar nature of the non-prosecution agreement
+
+
+reached in this case, and other information in the possession of the victims, it is also possible that
+other improper relationships exist between Government agents and Epstein. Please provide any
+documents, correspondence, and other information regarding the possibility of any improper
+relationship, including:
+a) Attorney Bruce Reinhart's involvement in and/or awareness of any aspect of the
+Government's criminal investigation and/or possible prosecution/non-prosecution
+of Epstein;
+b) Attorney Bruce Reinhart's involvement in and/or awareness of the Government's
+interest in any witness, subject, or target of the Epstein investigation. including
+Ghislaine Maxwell,
+• Larry Morrison, Larry Visoki, David Rogers, William
+Hammond, and Robert Roxburgh;
+c) All documents, correspondence, and other information reflecting telephone calls
+(including telephone logs and telephone billing statements) made by or received
+by Reinhart from Jeffrey Epstein, the Florida Science Foundation, Jack
+Goldberger, Alan Dersowitz, Roy Black, Ken Starr, Lillian Sanchez, and any
+other person involved with the criminal defense of Jeffrey Epstein, including
+telephone calls to and from Jack Goldberger and the Florida Science Foundation;
+d) All documents, correspondence, and other information (including, for example, e-
+mails) that were sent to, copied to, or sent by Reinhart in which the word
+"Epstein," "
+" 'Morrison," "Visoki," "Rogers," "Hammond,"
+Roxburgh,"
+"Florida Science Foundation," "Starr," "Black,"
+"Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," "358 El Brillo Way"
+appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger,
+or the Jeffrey Epstein investigation or prosecution;
+e) All documents, correspondence, and other information (including for example e-
+mails) of a similar nature that indicate that any other Government prosecutor has
+represented (or discussed representing) a person or entity related to Jeffrey
+Epstein or has received business or funds from a person or entity related to Jeffrey
+Epstein;
+f) All documents, correspondence, and other information that indicate or suggest
+that any Government prosecutor or investigator (including state and local
+prosecutor or investigator) has had any form of business, social, personal, or other
+relationship with Jeffrey Epstein or a person or entity related to Jeffrey Epstein;
+and
+g) All documents, correspondence, and other information that indicate or suggest
+that any Government prosecutor or investigator (including state and local
+prosecutor or investigator) would receive anything of value, directly or indirectly
+from Jeffrey Epstein or a person or entity related to Jeffrey Epstein (including any
+charitable contributions to be made by Epstein to any entity).
+17. In December 2010, the victims sent a letter to the U.S. Attorney's Office for the Southern
+District of Florida, requesting that the Office investigate whether "improper influences" were
+brought to bear during the negotiations involving the possible prosecution (and ultimately the
+non-prosecution) of Jeffrey Epstein. That letter led to a reference of the matter to the Office of
+
+
+Professional Responsibility (OPR) in the Justice Department in Washington, D.C., which began
+some kind of an inquiry/investigation. Please provide:
+a) All documents, correspondence, and other information collected by the Office of
+Professional Responsibility (OPR) and any other component of the Justice
+Department (including the FBI) in response to the victims' letter;
+b) All documents, correspondence, witness statements, and other information
+collected as part of OPR's inquiry/investigation;
+c) All documents, correspondence, witness statements and other information
+collected as part of any criminal inquiry/investigation that was initiated as a result
+of that letter, including any inquiry/investigation into criminal conflict of interest
+violations (such as 18 U.S.C. § 205 and § 207)
+d) All documents, correspondence, witness statements, and other information
+collected by any federal investigative agency that was triggered by OPR's
+inquiry/investigation, including any FBI inquiry/investigation regarding any
+improper influences or criminal or ethical violations that may have been
+committed by government attorneys during the handling of the Epstein
+investigation and/or prosecution;
+e) Any documents, correspondence, and other information regarding the accuracy or
+inaccuracy of Bruce Reinhart's sworn statements (found in DE 79-1 at p. 31) that
+he "did not participate in any way in the Office's investigation of Epstein;" that he
+"was not involved in any of the Office's decisionmaking with regard to the
+Epstein matter;" and that he "never learned any confidential, non-public
+information about the Epstein matter;"
+f) Any documents, correspondence,
+or other
+information regarding the
+circumstances that lead OPR to send a letter to the victims on May 6, 2011,
+indicating that they would not provide any further assistance to the victims in
+connection with their allegations that improper influences were brought to bear on
+the Epstein case;
+g) Any document, correspondence, e-mail, memoranda, or other information
+prepared by OPR, the FBI, or other Justice Department Component as a result of
+or following up on the victims' December 2010 letter concerning the Epstein
+case: and
+h) Any documents, correspondence, or other information that OPR has collected or
+obtained regarding the Epstein investigation and/or prosecution.
+18. At a couple points during the prosecution of this action, including in approximately
+December 2010 and most recently after the August 2011 hearing, the Justice Department in
+Washington, D.C., discussed or determined that the U.S. Attorney's Office for the Southern
+District of Florida (USAO SDFL) was "conflicted out", or may be conflicted out, of handling
+various issues related to the Epstein case because it suffered from a conflict of interest. The
+Justice Department accordingly sent various issues related to the Epstein case (and, on
+information and belief, issues related to Jane Doe #1 and Jane Doe #2) to the Department of
+Justice and to a United States Attorney's Office in another District. Please provide all
+documents, correspondence, and other information regarding the potential conflicts of interest
+that the Justice Department discussed or determined existed for the USAO SDFL, as well as any
+referral that was made to Main Justice or to any other District, including any documents that
+
+
+were transmitted to any other District regarding the conflict and regarding what was to be
+investigated.
+19. In March 2011, former U.S. Attorney Alexander Acosta sent a three-page letter to the
+news media in which he claimed that when Government attorneys began investigating Epstein,
+Epstein launched "a yearlong assault on the prosecution and the prosecutors." Shortly thereafter,
+Jeffrey Epstein's defense attorney Roy Black sent a responsive letter to Alexander Acost's letter
+to the news media in which he claimed that he did not pry into the personal lives of prosecutors
+but merely pointed out misconduct and over-reaching by certain people involved in the Epstein
+investigation. Please provide all documents, correspondence and other information that supports
+or contradicts Acosta's allegations in his letter, including any information that the Justice
+Department received from Epstein attacking the prosecutors and investigators working on the
+case. Please also provides all documents, correspondence, information about misconduct and
+over-reaching that was provided by Black and that the Government found that supported or
+contradicted such allegations.
+20. In their pending summary judgment motion, the victims have alleged that Epstein's guilty
+plea to state charges was intended to be the consummation of a non-prosecution agreement that
+barred prosecution of federal offenses committed against them. They have further alleged that
+Epstein entered such a guilty plea on or about June 30, 2008. Please provide all documents,
+correspondence, and other information between the Government and state and local prosecutors
+and police agencies (including The Palm Beach Police Department and Palm Beach State
+Attorney's Office) regarding the Epstein investigation and ultimate Epstein plea.
+21. In their pending summary judgment motion, the victims have alleged that correspondence
+in the possession of the Government will support their claims. Please provide all documents,
+correspondence, and other information between Government attorneys/officials (including both
+federal and state prosecutors) and attorneys for Jeffrey Epstein (or non-attorney acting on
+Epstein's behalf) relating to (1) negotiations involving the possible prosecution (and ultimately
+the non-prosecution) by federal or state agencies for sex offenses, including sex offenses
+committed against Jane Doe #1 and Jane Doe #2, (2) Epstein's entry of state guilty pleas for
+related
+sex offenses; (3) a non-prosecution agreement entered into between Epstein and the
+Government that barred his prosecution for offenses committed against Jane Doe #1 and Jane
+Doe #2; (4) the fulfillment of Epstein's and/or the Government's obligations under the nonprosecution agreement and/or the state guilty pleas Epstein entered; (5) any work release or other
+conditional release of Epstein from confinement; (6) any designation of Epstein as a sex offender
+or restrictions on him contacting victims of his offenses (including Jane Doe #1 and Jane Doe
+#2); and (7) any termination of supervision or parole of Epstein. This information should include
+unredacted e-mails, letters, and correspondence of any type between government prosecutors
+working on the case (including, but not limited to, federal prosecutors Alexander Acosta,
+and Bruce Reinhart
+and state prosecutors Dahlia Weiss, Lana Belolovek, and others involved in the Epstein
+investigation) and defense attorneys representing Epstein (including, but not limited to, Roy
+Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy
+Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein
+(including, but not limited to former President Bill Clinton and Andrew Albert Christian Edward
+
+
+(a/k/a Prince Andrew, Duke of York). This should also include letters of recommendation or
+similar communications submitted to any Government official vouching for or providing support
+for Jeffrey Epstein.
+22. As you know, throughout their pending summary judgment motion, the victims have
+alleged that they were not properly notified of plea negotiations with Jeffrey Epstein and were
+denied their right to confer by the Government and that instead the Government gave Epstein
+generous concessions through the plea negotiations. Please provide any documents,
+correspondence and other information that reflects or discusses any consideration of any type
+that Epstein had previously provided or offered to provide to the Government (or any individual
+within the Government, in either his official or private capacity) or any person previously
+employed by the Government and involved in the Epstein investigation or prosecution. The
+documents, correspondence, and other information should include any information discussing:
+(a) Any donation or offer to donate, directly or indirectly, either funds, services,
+or any other valuable consideration to any person or entity;
+(b) Any offer to assist, directly or indirectly, any person to obtain employment,
+business opportunities, business clients, real estate, office properties;
+(c) Any offer to assist the Government or law enforcement agencies in the
+investigation or prosecution of any federal or state criminal offense;
+(d) Any consideration that Epstein had provided to Government or law
+enforcement agencies in the past; and
+(e) Any other consideration of any type that Epstein offered to provide or had
+provided in the past that could provide a basis for the Government extending
+Epstein a more generous or lenient plea bargain or non-prosecution agreement
+than would be received by any other similarly situated child abuse suspect.
+23. The Crime Victims' Rights Act, 18 U.S.C. § 3771(c)(1), requires the Government to use
+its "best efforts" to protect the rights of crime victims.
+Please provide all documents,
+correspondence, and other information that will assist Jane Doe #1 and Jane Doe #2 in protecting
+their rights under the CVRA, including all documents, correspondence, and other information
+that the Government previously identified as being helpful to the victims but refused to provide
+based on its legal interpretation (now rejected by the Court) that the CVRA did not apply to this
+case because no indictment was filed.
+24. In the course of its investigation of Epstein and negotiations with Epstein, the
+Government (i.e., federal investigators and prosecutors) shared documents, correspondence, anc
+information with other persons outside the federal government, including state and local
+prosecuting and law enforcement agencies, prosecuting and law enforcement agencies in other
+countries, Epstein's legal counsel, legal counsel for crime victims, and other entities. Please
+provide all documents, correspondence, and other information that the Government shared with
+any entity or person outside the federal government, including all correspondence (including e-
+mails) with those entities or persons.
+25. After the victims had made extensive efforts to try and reach a stipulated set of facts in
+this case, in March 2011 the Government refused to negotiate about such facts. Accordingly, at
+that time the victims filed various motions to obtain evidence in this case and, at the same time,
+
+
+the victims voluntarily made all initial disclosures on their part that are required by Federal Rule
+of Civil Procedure 26(a)(1). Please provide all initial disclosures required by the Federal Rules
+of Civil Procedure, including all disclosures required by Rule 26(a)(1).
+DEFINITIONS
+For the purpose of construing the foregoing discvery requests, the following terms are
+defined:
+The term "documents" means and includes, without limitation, all writings of any kind,
+including the originals and all non-identical copies or drafts, whether different from the origina
+y reason of any notation made on such copy or draft or otherwise including, without limitation
+correspondence, memoranda, notes, diaries, statistics, letters, e-mails, electronic computer files,
+telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries,
+pamphlets, books, prospectuses, interoffice communications, offers, notations of any sort of
+converter on telephone cales, facings, inhere morties and latinatined mater,
+modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records
+or representations of any kind including, without limitation, photographs, charts, graphs,
+microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or
+electric records or representations of any kind including, without limitation, tapes, cassettes and
+dise recordings, and writings and printed material of every kind.
+The term "correspondence" means any tangible object that conveys information or
+memorializes information that was conveyed in tangible or oral form including, but not limited
+to, writings, letters, memoranda, reports, notes, e-mails, telephone logs, telephone billing
+information, telephone recordings, and interoffice communications.
+The term "Epstein's victims" means any person that the Government identified as a
+possible victim of a sex offense committed by Jeffrey Epstein, including Jane Doe #1, Jane Doe
+#2, all victims identified in attachment to the non-prosecution agreement entered into by Epstein,
+and another person that the Government investigated as a possible victim of Epstein's sex
+offenses.
+The term "Government" means the federal government, including all employees of and
+components of the United States Department of Justice (such as, the Office of the Attorney
+General, the Office of the Deputy Attorney General, the Criminal Divisions, the Office of
+Professional Responsibility, the Child Exploitation and Obscenity Section, the U.S. Attorney's
+Offices for the Southern District and Middle District of Florida, and the Federal Bureau of
+Investigation) and other federal government agencies with law enforcement responsibilities
+related to the Epstein case (such as the Internal Revenue Service). This request for production
+seeks all documents, correspondence, and other information held by all of these entities,
+including all employees of and components of the Justice Department that worked on or were in
+any way involved the Epstein investigation and/or that possess information relevant to the
+victims' claims.
+
+
+The term "including" means containing within the request, but not limiting the request.
+The term
+(including oral form) reflecting, recording, or otherwise memorializing a statement made or
+information conveyed by a potential witness, including for example FBI 302's. The term
+neludes information collected by any law enforcement, prosecuting or government agency
+ncluding all federal. state. and local law enforcement agencies located in Washington, D.C.. c
+Florida.
+NO GRAND JURY TRANSCRIPTS SOUGHT
+If any of the foregoing requests cover grand jury transcripts, do not provide the grand
+grand jury transcript, pled the foregoin pareguests quotade documents that quote directly from a
+PRIVILEGE LOG
+If you believe that any document, correspondence, or other information requested in this
+equest is subject to a privilege and if you intend to assert that privilege, please provide a
+"privilege log" consistent with Local Rule 26.1(g), including a description a document that is
+consistent with Local Rule 26.1(g)(3)(B). Your privilege log should include the type of
+document, general subject matter of the document, date of the document, and author and
+REDUCING UNDUE BURDEN
+If you believe that complying with any of the foregoing requests would be unduly
+any such burdrease contact victims counsel - Bradley J. Edwards - to discuss ways to reduce
+DATED: October 3, 2011
+Respectfully Submitted,
+s/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS. FISTOS & LEHRMAN, P.L.
+Fort Lauderdale, Florida 33301
+
+
+and
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utah
+Salt Lake City, UT 84112
+Attorneys for Jane Doe #1 and Jane Doe #2
+CERTIFICATE OF SERVICE
+The foregoing document was served on October 3, 2011, on the following via US Mail and
+E-Mail Transmission:
+Assistant U.S. Attorneys
+West Palm Beach, FL 33401
+Attorneys for the Government
+Roy Black, Esq.
+Jackie Perczek, Esq.
+Black, Srebnick, Kornspan & Stumpf, P.A.
+Miami, FL 33131
+Attorneys for Proposed Intervenors Roy Black et al.
+Respectfully Submitted,
+S/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
diff --git a/vision-fixhub/ds9-unparsed-06/2d54c0fd0074ab77eddc368ae4fdde4397ec4906e9107b242b0d7fdc832d9acd.receipt.json b/vision-fixhub/ds9-unparsed-06/2d54c0fd0074ab77eddc368ae4fdde4397ec4906e9107b242b0d7fdc832d9acd.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..451e93bb75dede58e785069bb12c4cc3e6bc9c8e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2d54c0fd0074ab77eddc368ae4fdde4397ec4906e9107b242b0d7fdc832d9acd.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -160,
+  "dataset": "marble-joined",
+  "doc_id": "2d54c0fd0074ab77eddc368ae4fdde4397ec4906e9107b242b0d7fdc832d9acd",
+  "engine": "marble-apple-vision",
+  "event_count": 15,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "c9848262ee4bba659ca2b5df905e25eead10c425a334ce86cd678cd97b6e54ea",
+  "output_sha256": "fb4994504970096ad08bac7221182c09d9652b9b08e5bdb5088fffed0f81565e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2dba0126018baa282e8ebd46c4f9635ecc97454e7cf9b8b170051fd1276ec5be.md b/vision-fixhub/ds9-unparsed-06/2dba0126018baa282e8ebd46c4f9635ecc97454e7cf9b8b170051fd1276ec5be.md
new file mode 100644
index 0000000000000000000000000000000000000000..21350e2605d61375616988e34285c7e23318a7bb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2dba0126018baa282e8ebd46c4f9635ecc97454e7cf9b8b170051fd1276ec5be.md
@@ -0,0 +1,656 @@
+Order documents from our nationwide document retrieval service.
+- OR - Call 1.866.540.8818.
+Florida Circuit & County Courts
+FL Circuit & County - Palm Beach
+(Palm Beach)
+502008CA028058XXXXMB
+v. Epstein, Jeffrey
+The case was last updated by the court on Friday, July 15, 2011
+Header
+Case Number: 502008CA028058XXXXMB
+Date Filed: 09/11/2008
+Date Full Case Retrieved: 07/15/2011
+Status: Pending
+Misc: (170) OTHER NEGLIGENCE; Circuit Civil
+[Summary] [Additional Case Information] [Participants] [Additional Counsel] [Calendar][Fees] [Proceedings]
+Summary
+Judge: HAFELE, JUDGE DONALD W
+Additional Case Information
+Clerk Case Number: 2008ca028058
+Outstanding Warrant/Summon/Capias: Y
+Jury Trial: J
+Closed Case: N
+Last Docket Date: 04/24/2009
+Status Date: 04/24/2009
+Participants
+Litigant
+Plaintiff
+Epstein, Jeffrey
+Defendant
+Attorney
+Edwards, Brad
+2028 Harrison St Suite 202
+Hollywood FL 33020
+Goldberger, Jack A
+250 S Australian Ave Suite 1400
+West Palm Beach FL 33401
+Critton Jr, Robert D
+515 North Flagler Drive Suite 400
+West Palm Beach FL 33401
+Defendant
+Additional Counsel
+No Information is Available for this case
+
+
+Calendar
+No Information is Available for this case
+Fees
+Total Restitution Due
+Total Restitution Paid
+Total Amount Due
+$301.00
+Total Amount Paid
+$301.00
+Last Payment Date
+09/18/2008
+Proceedings
+Date
+09/11/2008 1
+Id Code Details
+Cmp Complaint
+09/11/2008 2
+Ccs
+Civil Cover Sheet
+09/11/2008 3
+Rqad Request For Admissions
+09/11/2008 4
+Reap Request to Produce
+09/11/2008 5
+Nofi
+Notice of Filing Interrogs
+09/11/2008 6
+Mot
+Motion
+To Proceed Anonymously
+09/11/2008 7
+Smis Summons Issued
+Sm-08-162543
+09/19/2008 8
+Dnae Docket Nbr Assigned in Error
+Motion to Proceed Anonymously, Granted. D E French.
+09/19/2008 9 Ordg
+Order Granting
+Motion to Proceed Anonymously, Granted. D E French.
+10/07/2008 10 Noap Notice of Appearance
+As Counsel For Dft Jeffrey Epstein.
+10/08/2008 11
+Mdis
+Motion to Dismiss
+For More Definite Statement And to Strike Directed to Pit Ew's Complaint.
+10/16/2008 12 Resp
+Response To:
+Dft's Motion to Dismiss For More Definite Statement And to Strike Complaint.
+10/17/2008 13
+Orsh
+Order Setting Hearing
+(Specially) For 12/5/08 From 9:30 AM to 9:45 Am. D E French.
+10/29/2008 14 Mdis
+Motion to Dismiss
+(Dft's Supplemental To) Count IV of Pit's Complaint.
+10/30/2008 15 Mext
+Motion For Extension of Time
+11/14/2008 16 Rprs Reply/Response
+& Objections to Pit's First Request For Production.
+11/19/2008 17 Rerq Response to Req For Admission
+To Pitf's First Request
+11/19/2008 18 Resp Response To:
+Response & Objections to Pitf's First Set of Interrogs
+12/10/2008 19 Ord Order
+On Dft's Motion to Dismiss........ Granted in Part & Denied in Part...... View Order. D E French.
+12/11/2008 20 Nos Notice of Service
+First Set of Interrogatories Directed to Pit.
+12/11/2008 21
+Reqp Request to Produce
+(Dft's First) to Plt.
+12/23/2008 22 Noun Notice of Unavailability
+
+
+12/29/2008 23 Cmp
+Complaint
+(Amended) as to
+12/30/2008 24 Mext
+Motion For Extension of Time
+To Amended Complaint.
+01/06/2009 25 Agor Agreed Order
+On Dit's Motion For Extension of Time to Respond to Amended Complaint, Granted. D E French.
+01/13/2009 26 Mdis
+Motion to Dismiss
+Count IV of Pit's Amended Complaint And Motion to Strike Specified Allegations.
+01/14/2009 27 Notd Notice of Taking Deposition
+Of Jeffrey Epstein C/O Robert D Critton JR Esq.
+01/16/2009 28
+Noap
+Notice of Appearance
+As Counsel For Dft Jeffrey Epstein.
+01/23/2009 29
+Orsh Order Setting Hearing
+For 3/6/09 From 9 to 9:15 Am. D E French.
+01/26/2009 30
+Resp
+Response To:
+Dft's Motion to Dismiss Count IV of Amended Complaint And Motion to Strike.
+01/26/2009 31
+Nos
+Notice of Service
+Of Pit's Answers to Dft's Interrogatories.
+01/26/2009 32 Resp
+Response To:
+Dft's First Request to Produce.
+02/02/2009 33
+Antd
+Re-Notice of Taking Deposition
+(Video) of Dft Jeffrey Epstein.
+02/06/2009 34 Rntd Re-Notice of Taking Deposition
+(Second) of Dft Jeffrey Epstein.
+02/11/2009 35 Npnp Notice of Production Non Party
+View List.
+02/17/2009 36 Mot
+Motion
+To Quash PIt's Notice of Taking Deposition
+02/18/2009 37 Nof
+Notice of Filing
+Affidavit of Jack A Goldberger, Attached.
+02/06/2009 38
+Antd
+Re-Notice of Taking Deposition
+(Second) of Dft Jeffrey Epstein.
+02/18/2009 39 Noh
+Notice of Hearing
+On 3/9/09 (At) 8:45 Am.
+02/17/2009 40 Mot
+Motion
+To Quash PIt's Notice of Taking Deposition
+02/20/2009 41
+Smis
+Summons Issued
+Sm-09-040541
+02/23/2009 42 Noh
+Notice of Hearing
+On 3/9/09 (At) 8:45 Am.
+02/23/2009 43 Obj
+Objection
+To Notice of Production And Subpoena Duces Tecum Without Deposition Directed to Yellow Cab.
+02/25/2009 44 Rprs
+Reply/Response
+To Pit's Response to Dft's Motion to Dismiss Count IV of Amendedcomplaint And Motion to Strike.
+03/09/2009 45 Resp
+Response To:
+Motion to Quash...
+03/12/2009 46 Ord
+Order
+Specially Set Hearing on April 24, 2009 at 9:00 AM (E Fine)
+03/17/2009 47 Mot
+Motion
+To Reassing And/Or Transfer to Division Ab.
+03/20/2009 48 Noh
+Notice of Hearing
+On 04/07/09
+03/20/2009 49 Ord
+On Dit's Mtn to Dismiss CT IV of Amended Complaint-Granted-See Tetx
+03/26/2009 50 Mot
+Motion
+To Stay And or Continue Action
+03/30/2009 51 Notd Notice of Taking Deposition
+
+
+03/30/2009 52 Notd Notice of Taking Deposition
+03/30/2009 53 Notd
+Notice of Taking Deposition
+03/30/2009 54 Notd
+Notice of Taking Deposition
+Of R/C Carp on 04/28/09
+03/30/2009 55 Notd
+Notice of Taking Deposition
+Of The R/C Jfk Medical Ctr-Served
+03/30/2009 56 Notd
+Notice of Taking Deposition
+Of The R/C Bethesda Memorial Hospital-On 04/28/09
+03/30/2009 57 Notd
+Notice of Taking Deposition
+Of R/C DR Randee Speciale on 04/28/09
+03/30/2009 58 Notd
+Notice of Taking Deposition
+Of Dominique Hyppolite on 04/28/09
+03/30/2009 59 Notd Notice of Taking Deposition
+R/C Pure Platinum
+03/30/2009 60 Notd
+Notice of Taking Deposition
+R/C T'S Lounge
+03/30/2009 61 Notd Notice of Taking Deposition
+R/C Spearmint Rhino
+03/30/2009 62 Notd
+Notice of Taking Deposition
+R/C Vegas Cabaret
+03/30/2009 63 Notd
+Notice of Taking Deposition
+R/C Cheetah Palm Beach
+03/30/2009 64 Notd
+Notice of Taking Deposition
+R/C Curves Cabaret
+03/30/2009 65 Notd
+Notice of Taking Deposition
+R/C Platinum Gold/Showgirls
+03/30/2009 66 Notd
+Notice of Taking Deposition
+R/C Duffy's Restaurant
+03/30/2009 67 Notd Notice of Taking Deposition
+Of The R/C of The Body Shop-On 04/17/09
+03/30/2009 68 Notd
+Notice of Taking Deposition
+Of The R/C Solid Gold on 04/17/09
+03/31/2009 69 Notd
+Notice of Taking Deposition
+Of RC Diamond Dolls
+04/06/2009 70 Nac Notice -Name/Address Change
+04/07/2009 71 Anad Answer & Affirmative Defenses
+To Plt Amended Complaint
+04/09/2009 72 Ord Order
+On Mtn to Reassign or Transfer-Denied
+04/09/2009 73 Mcmp Motion to Compel
+04/09/2009 74 Mcmp Motion to Compel
+04/14/2009 75 Nof
+Notice of Filing
+04/16/2009 76 Rprs
+Reply/Response
+To Pitf's Response
+04/20/2009 77 Ccpy
+Certified Copy
+Of Order Transferring Cases to AB
+04/24/2009 78 Nore
+Notice of Reassignment
+To Div AB Judge Hatele
+04/24/2009 79 Rqcp
+Request For Copies
+
+
+05/01/2009 80 Mcmp Motion to Compel
+Motion to Compel And For Sanctions
+05/05/2009 81 Ncom Notice of Compliance
+05/05/2009 82 Mcmp Motion to Compel
+And For Sanctions
+05/06/2009 83 Notd
+Notice of Taking Deposition
+L M
+05/06/2009 84 Notd Notice of Taking Deposition
+Jane Doe
+05/06/2009 85 Mot
+Motion
+For Protective Order
+05/06/2009 86 Mot
+Motion
+For Protective Order
+05/07/2009 87 Mot
+Motion
+Forprotective Order
+05/11/2009 88 Noh
+Notice of Hearing
+On 05/14/09
+05/11/2009 89 Not
+Notice
+Of Propounding Expert Interrogatories to Plt.
+05/11/2009 90 Mcmp Motion to Compel
+05/12/2009 91 Noh
+Notice of Hearing
+5/14/09
+05/12/2009 92 Mot
+Motion
+For Protective Order
+05/13/2009 93 Obj
+Objection
+To Deposition
+05/14/2009 94 Resp
+Response To:
+In Opposition to Dft Motion...
+05/14/2009 95 Srsv Subpoena Returned / Served
+Served Carp
+05/14/2009 96 Orsh
+Order Setting Hearing
+For 5/22/09. D Hafele.
+05/15/2009 97 Ord
+Order
+Granted. D Hafele.
+05/15/2009 98 Noh
+Notice of Hearing
+5/28/09
+05/15/2009 99 Noh
+Notice of Hearing
+6/4/09 8:45am
+05/18/2009 100 Noh
+Notice of Hearing
+5/28
+05/18/2009 101 Noh
+Notice of Hearing
+6/9/09
+05/18/2009 102 Noh
+Notice of Hearing
+6/10/09
+05/19/2009 103 Sup
+Supplement
+05/21/2009 104 Nof
+Notice of Filing
+05/22/2009 105 Ord
+Order
+Denied ...... View Order. D Hafele.
+05/22/2009 106 Nof
+Notice of Filing
+The Attached Documents
+05/27/2009 107 Mot
+Motion
+To Disquality
+05/28/2009 108 Noh
+Notice of Hearing
+
+
+On 05/28/09
+05/28/2009 109 Resp
+Response To:
+In Opposition to Plt Motion...
+06/01/2009 110 Nof
+Notice of Filing
+Transcripts Dated 05/22/09
+06/02/2009 111 Mot
+Motion
+06/02/2009 112 Rnoh Re-Notice of Hearing
+6/18/09 8:45
+06/10/2009 113 Nos
+Notice of Service
+06/12/2009 114 Ord
+Order
+Denied. D Hafele.
+06/19/2009 115 Ord
+Order
+Orverruled..... View Order. D Hafele.
+06/24/2009 116 Mot
+Motion
+For Leave to Add Count For Battery And Seek Punitive Damages.
+06/25/2009 117 Noh
+Notice of Hearing
+On 7/7/09.
+06/29/2009 118 Not
+Notice
+07/01/2009 119 Agor
+Agreed Order
+On Dits Motion *Dhafele*
+07/01/2009 120 Ltr
+Letter
+To Judge Hafele
+07/01/2009 121 Agor
+Agreed Order
+To Dft's Mtn to Compel
+07/01/2009 122 Ord
+Order
+On Dft's Mtn to Compel Better Answers
+07/01/2009 123 Sup
+Supplement
+Order
+07/09/2009 124 Orsh
+Order Setting Hearing
+07/14/2009 125 Resp
+Response To:
+Motion For Leave
+07/14/2009 126 Mcmp Motion to Compel
+07/16/2009 127 Ord
+Order
+On Mnt to Compel-See Order
+07/16/2009 128 Nof
+Notice of Filing
+07/17/2009 129 Nof
+Notice of Filing
+
+07/17/2009 130 Notd
+Notice of Taking Deposition
+(Cross) Alfredo Rodriguez
+07/21/2009 131 Not
+Notice
+07/22/2009 132 Nof
+Notice of Filing
+07/28/2009 133 Nof
+Notice of Filing
+07/31/2009 134 Ord
+Order
+On Mtn For Leave-Granted
+08/10/2009 135 Noh
+Notice of Hearing
+8/20/09
+08/10/2009 136 Mot
+Motion
+For Stay of Orders
+
+
+08/12/2009 137 Noh
+Notice of Hearing
+Mtn Cal
+08/12/2009 138 Req
+Request
+For Entry Upon Land
+08/13/2009 139 Mcmp Motion to Compel
+Compliance W/Court Order ....
+08/13/2009 140 Noh
+Notice of Hearing
+08/13/2009 141 Rprs Reply/Response
+In Opposition to EW Motion For Stay
+08/19/2009 142 Notd Notice of Taking Deposition
+Of LM C/O Brad Edwards Esq.
+08/19/2009 143 Anad Answer & Affirmative Defenses
+08/20/2009 144 Nac Notice -Name/Address Change
+08/24/2009 145 Ord
+Order
+On Mot For Special Set Hearing, Denied. D Hafele.
+08/24/2009 146 Ord
+Order
+Plt's Request For Entry Upon Land W/Drawn, DT 8/20/09 D Hafele
+08/24/2009 147 Ord
+Order
+PIt's Motion For Stay Granted as Set Forth in The Transcript, Dtd 8/20/09 D Hafele
+08/24/2009 148 Ord
+Order
+On Mot to Compel, Granted as Follows....
+...View Order. D Hafele.
+09/01/2009 149 Nos
+Notice of Service
+09/14/2009 150 Obj
+Objection
+09/17/2009 151 Notd
+Notice of Taking Deposition
+See List
+09/17/2009 152 Noh
+Notice of Hearing
+09/17/2009 153 Noh
+Notice of Hearing
+09/17/2009 154 Mstr
+Motion to Strike
+09/28/2009 155 Mot
+Motion
+08/10/2009 156 Tcpy
+True Copy
+Order From 4dca 4D09-2409 And 4D09-3001 Dtd 8-6-09 Motion to Consolidate Filed 8-4-09 is Granted,
+Case Numbers Are Consolidated
+09/25/2009 157 Noh
+Notice of Hearing
+Oct 1 2009
+09/29/2009 158 Noh
+Notice of Hearing
+09/29/2009 159 Mot
+Motion
+10/01/2009 160 Nojt
+Notice of Jury Trial
+10/02/2009 161 Resp
+Response To:
+10/05/2009 162 Orsh Order Setting Hearing
+10/14/2009 163 Nof
+Notice of Filing
+10/21/2009 164 Notd
+Notice of Taking Deposition
+
+
+10/28/2009 165 Notd Notice of Taking Deposition
+11/02/2009 166 Mot
+Motion
+For Partial Summary Judgement
+11/05/2009 167 Osjt Order Setting Jury Trial
+Calendar Call on 04/30/10
+11/05/2009 168 Srsv Subpoena Returned / Served
+Dr Amy Swan-Served
+11/18/2009 169 Notd Notice of Taking Deposition
+Du TE Records Only
+11/30/2009 170 Srsv Subpoena Returned / Served
+Presidential Womens Ctr-Served
+12/02/2009 171 Agor Agreed Order
+12/14/2009 172 Noap Notice of Appearance
+01/12/2010 173 Noh
+Notice of Hearing
+01/13/2010 174 Noh
+Notice of Hearing
+Jan 19 2010
+01/13/2010 175 Mcmp Motion to Compel
+01/15/2010 176 Rnoh Re-Notice of Hearing
+Jan 26 2010
+01/19/2010 177 Ord
+Order
+On Motion to Compel-Granted-Dhafele
+01/25/2010 178 Orsh
+Order Setting Hearing
+April 9 2009? Dhatele
+01/25/2010 179 Not
+Notice
+01/27/2010 180 Nojt
+Notice of Jury Trial
+01/28/2010 181 Nos
+Notice of Service
+3rd Set of Interrog
+02/05/2010 182 Mcmp Motion to Compel
+02/05/2010 183 Noh
+Notice of Hearing
+Feb 11 2010
+02/12/2010 184 Ord
+Order
+To Compel is Granted. D Hafele
+02/22/2010 185 Not
+Notice
+02/25/2010 186 Nos
+Notice of Service
+03/03/2010 187 Nos
+Notice of Service
+03/08/2010 188 Notd
+Notice of Taking Deposition
+03/08/2010 189 Notd
+Notice of Taking Deposition
+Of E.W. 4/2/10
+03/29/2010 190 Notd
+Notice of Taking Deposition
+To R/C DR Amy Swan
+03/31/2010 191 Resp
+Response To:
+Motion For Partial Summary Judgement
+04/02/2010 192 Nos
+Notice of Service
+04/05/2010 193 Rprs Reply/Response
+
+
+To Motion For Partial Summary Jjudgement
+04/09/2010 194 Mcmp Motion to Compel
+Deposition
+04/09/2010 195 Noh
+Notice of Hearing
+04/20/2010 196 Notd
+Notice of Taking Deposition
+See List
+04/28/2010 197 Notd
+Notice of Taking Deposition
+04/28/2010 198 Mot
+Motion
+For Leave to Serve Additional Interrs
+04/28/2010 199 Mcmp Motion to Compel
+Answers to 4th Set of Interrs
+04/30/2010 200 Noh
+Notice of Hearing
+5-12-10 at 8:45 AM
+05/05/2010 201 Rnot Re-Notice
+Of E.W.
+05/05/2010 202 Notd
+Notice of Taking Deposition
+Cross, Videotaped
+05/05/2010 203 Agor Agreed Order
+On Epstein Mtn to Compel-Granted-Dhafele
+05/05/2010 204 Agor Agreed Order
+On Motion to Compel Deposition
+05/05/2010 205 Noh
+Notice of Hearing
+May 11 2010
+05/06/2010 206 Rnoh Re-Notice of Hearing
+May 10 2010
+05/06/2010 207 Nos
+Notice of Service
+05/10/2010 208 Srsv
+Subpoena Returned / Served
+To Ashley Mcguire General Manager on 4/29/10
+05/10/2010 209 Srsv
+Subpoena Returned / Served
+To Ashley Mcguire General Manager
+05/10/2010 210 Srsv
+Subpoena Returned / Served
+To R/C Dr. Amy Swan
+05/12/2010 211 Resp
+Response To:
+To Motion For Leave to File Additional Interr
+05/13/2010 212 Orsh
+Order Setting Hearing
+Calendar Call on 09/17/10 Case Will be Set For Jury Trial at Calendar Call-Dhafele
+05/13/2010 213 Notd
+Notice of Taking Deposition
+05/13/2010 214 Notd Notice of Taking Deposition
+05/13/2010 215 Ord
+Order
+On Motion For Leave to Serve Additional Interro-Granted-Dhafele
+05/22/2010 216 Noh
+Notice of Hearing
+On 05/25/10
+05/22/2010 217 Mstr
+Motion to Strike
+Case From Trial Docket
+05/24/2010 218 Notd
+Notice of Taking Deposition
+Thomas Steinbacher
+05/25/2010 219 Ord
+Order
+Granting Mtn to Strike-Granted
+06/01/2010 220 Srsv
+Subpoena Returned / Served
+Thomas Ssteinbacher-Served
+06/01/2010 221 Cmp
+Complaint
+Pitt's Third Amended Compliant
+
+
+06/10/2010 222 Mcmp Motion to Compel
+06/14/2010 223 Noh
+Notice of Hearing
+On 06/28/10
+06/17/2010 224 Mdis
+Motion to Dismiss
+Counts 1 & II of Third Amended Complaint With Prejudice
+06/17/2010 225 Srns
+Subpoena Returned / Not Served
+William Duncan Owner-Served
+06/28/2010 226 Nos
+Notice of Service
+07/06/2010 227 Req
+Request
+07/23/2010 228 Stip
+Stipulation
+Of Dismissal W/Prejudice up 7/26/10 W/Unsigned Order
+Adopting Stipulation And Dismissing Case D Hafele
+07/29/2010 230 Ord
+Adopting Stipulation And Dismissing Case D Hafele
+copyright © 2012 LexisNexis CourtLink, Inc. All rights reserved
+* THIS DATA IS FOR INFORMATIONAL PURPOSES ONLY *1
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/2dba0126018baa282e8ebd46c4f9635ecc97454e7cf9b8b170051fd1276ec5be.receipt.json b/vision-fixhub/ds9-unparsed-06/2dba0126018baa282e8ebd46c4f9635ecc97454e7cf9b8b170051fd1276ec5be.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c670c50f75c169a675b0657cecc5e826c721908a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2dba0126018baa282e8ebd46c4f9635ecc97454e7cf9b8b170051fd1276ec5be.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -539,
+  "dataset": "marble-joined",
+  "doc_id": "2dba0126018baa282e8ebd46c4f9635ecc97454e7cf9b8b170051fd1276ec5be",
+  "engine": "marble-apple-vision",
+  "event_count": 12,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "f25bdb838a17ba698ead4cdfc449748ca6fe7f111f70d60e01950141b39011b2",
+  "output_sha256": "d9bde0ec3022a31573b8b52a1f77378fda395f507d485da2b4dabf140b41352c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2e0441f2478c915ad79e1ab51b8dab519231cd7c69050469fe7b711c5a233c93.md b/vision-fixhub/ds9-unparsed-06/2e0441f2478c915ad79e1ab51b8dab519231cd7c69050469fe7b711c5a233c93.md
new file mode 100644
index 0000000000000000000000000000000000000000..19752d51ed16ddb35cdc5cb3a8f784ef6be722b6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2e0441f2478c915ad79e1ab51b8dab519231cd7c69050469fe7b711c5a233c93.md
@@ -0,0 +1,40 @@
+From: "l
+To:
+Subject: KE: Ker
+Date: Mon, 26 Sep 2011 19:54:03 +0000
+Importance: Normal
+Setting aside the non-pros and prosecuting him as though the Non-pros had never been signed.
+----0
+From:
+To:
+Subject: Re:
+Sent: Monday, September 26, 2011 3:52 PM
+• (USAFLS)
+Suggest what thing?
+- - Original Message ---
+Fron
+To: F
+Sent: Mon Sep 26 15:48:05 2011
+Subject: RE:
+L. (USAFLS) {
+No. He already served his sentence in state court and performed all his other obligations under the Non-Pros (including paying damages to
+30-some girls). I argued it would be a Due Process violation to even suggest such a thing.
+----0
+From:
+Sent: 1
+To: L
+Subjec
+Have we conceded that a showing that we violated the CVRA would justify reoopening/setting aside the nonpros?
+Fron
+To: F
+Senti
+
+
+Subject: RE:
+Ideally to set aside the Non-Prosecution Agreement with Epstein and then to somehow convince us (probably through public pressure via
+the pressi to nrosecute him
+Fro
+Sen
+To:
+Subject:
+What is the relief jane does want in the evra case?
diff --git a/vision-fixhub/ds9-unparsed-06/2e0441f2478c915ad79e1ab51b8dab519231cd7c69050469fe7b711c5a233c93.receipt.json b/vision-fixhub/ds9-unparsed-06/2e0441f2478c915ad79e1ab51b8dab519231cd7c69050469fe7b711c5a233c93.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c8ba448a2d0d15a676418e2fe28c4e9d0245604b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2e0441f2478c915ad79e1ab51b8dab519231cd7c69050469fe7b711c5a233c93.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "2e0441f2478c915ad79e1ab51b8dab519231cd7c69050469fe7b711c5a233c93",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "a7cacc3fcfcc3b8dedd8137d123d5177b5765f9090cf8f31b77d800178bf9e81",
+  "output_sha256": "69f709d746b261c65d460a027d389c3b3a272c1c06642c5bae1b3e6c9eaa779c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2e447b3f75cb3c37fb742f05da30da2d6df481d4b23983ea07c88416d7715a97.md b/vision-fixhub/ds9-unparsed-06/2e447b3f75cb3c37fb742f05da30da2d6df481d4b23983ea07c88416d7715a97.md
new file mode 100644
index 0000000000000000000000000000000000000000..9e86569481e7388d912637b4559572ad927ddd6a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2e447b3f75cb3c37fb742f05da30da2d6df481d4b23983ea07c88416d7715a97.md
@@ -0,0 +1,9 @@
+From: "ROBERT C. JOSEFSBERG"
+To:
+Subject: Read: Epstein Hearing
+Date: Fri, 12 Aug 2011 22:49:12 +0000
+Importance: Normal
+Your message
+Subject: Epstein Hearing
+Sent: Friday, August 12, 2011 6:49:16 PM (UTC-05:00) Eastern Time (US & Canada)
+was read on Friday, August 12, 2011 6:49:12 PM (UTC-05:00) Eastern Time (US & Canada).
diff --git a/vision-fixhub/ds9-unparsed-06/2e447b3f75cb3c37fb742f05da30da2d6df481d4b23983ea07c88416d7715a97.receipt.json b/vision-fixhub/ds9-unparsed-06/2e447b3f75cb3c37fb742f05da30da2d6df481d4b23983ea07c88416d7715a97.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..34e81321457c3bc5f6e426bf84ac4f81dafa3673
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2e447b3f75cb3c37fb742f05da30da2d6df481d4b23983ea07c88416d7715a97.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "2e447b3f75cb3c37fb742f05da30da2d6df481d4b23983ea07c88416d7715a97",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "62397b90265473c7dd75551c884d9c66439a44e5d406536b5a5cc9dc4df37717",
+  "output_sha256": "8830dcffc8d7070bb323f65b426f65598da06e26604d675686d9f7a835e94a73",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2e72d9c3f76ab2ad266879494953559b40dc53168d9c9ba1a8a8e60077d4911b.md b/vision-fixhub/ds9-unparsed-06/2e72d9c3f76ab2ad266879494953559b40dc53168d9c9ba1a8a8e60077d4911b.md
new file mode 100644
index 0000000000000000000000000000000000000000..b9c3f3feb0a9627ef42592cf7f7eb3e8aa683a25
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2e72d9c3f76ab2ad266879494953559b40dc53168d9c9ba1a8a8e60077d4911b.md
@@ -0,0 +1,53 @@
+From:
+To: "
+Cc: "
+Bec: "
+(USAFLS)"
+(USAFLS)" <
+(USAFLS)"
+(USAFLS)" 4
+(USAFLS)" -
+Subject: RE: Jeffrey Epstein
+Date: Wed, 04 Jul 2007 20:06:43 +0000
+Importance: Normal
+Dear
+and
+: Thank you for your e-mail and your message. This e-mail was supposed to have gone out
+yesterday while I was in trial. I have no objection to the two-week extension with respect to NES, New York
+Strategy Group, and Epstein Virgin Islands Foundation.
+With respect to the subpoena to the investigator, I would like to get the computer equipment as soon as possible.
+If you prefer to simply turn over the equipment without anyone appearing before the grand jury that is fine. If we
+proceed that way, we can defer litigating the issue of the applicability of the attorney-client and/or work product
+privilege to information related to how and why the equipment was removed. I will be in trial this week, so
+please contact
+at the FBI directly at
+Ilook forward to your July 11th submission. If you would like to discuss the possibility of a federal resolution of
+Mr. Epstein's case that could run concurrently with any state resolution, please leave a message on my voicemail
+at the office
+D and I will get back to you after trial has ended for the day.
+Thank you.
+Assistant U.S. Attorney
+-----Original Message--.
+From:
+To:
+Cc:
+[mailto:
+Sent: Friday, June 29, 2007 4:05 PM
+• (USAFLS)
+Subject: Jeffrey Epstein
+As i stated in my earlier voicemail today, we were calling to request a two-week extension on the return date of
+the following outstanding subpoenas:
+1. NES
+2. NY Strategy
+3. Investigator Riley
+4. Certification for St. Thomas entity
+We will be providing an additional submission to the Office by July 11 and hope to be able to reach a state-based
+resolution shortly thereafter.
+as your voicemail to me indicted, you would not oppose a one to two-week extension. accordingly, we would
+like to extend the return date two weeks-- to July 24.
+regards
+
+
+Esq.
+FOWLER WHITE BURNETT P.A.
+Espirito Santo Plaza, 14th Floor
diff --git a/vision-fixhub/ds9-unparsed-06/2e72d9c3f76ab2ad266879494953559b40dc53168d9c9ba1a8a8e60077d4911b.receipt.json b/vision-fixhub/ds9-unparsed-06/2e72d9c3f76ab2ad266879494953559b40dc53168d9c9ba1a8a8e60077d4911b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..83871da7c72038127f4c225b6433f73d19e6a855
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2e72d9c3f76ab2ad266879494953559b40dc53168d9c9ba1a8a8e60077d4911b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "2e72d9c3f76ab2ad266879494953559b40dc53168d9c9ba1a8a8e60077d4911b",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "6858e3efc9d80bb2e0e4c9f9b54bb95347dce5daf4b0ad3f45fcb09ee39a9344",
+  "output_sha256": "f88dacd068b236a8efb467656a734fad0114d40f6ef2cc231ee74955b966a386",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2e91b7b84bd578e014a145a9b7dea0e9524fe9d5c88fc2310574c614a1ee053e.md b/vision-fixhub/ds9-unparsed-06/2e91b7b84bd578e014a145a9b7dea0e9524fe9d5c88fc2310574c614a1ee053e.md
new file mode 100644
index 0000000000000000000000000000000000000000..da7d13238f4a30d792bfb1a3e111c286e187a084
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2e91b7b84bd578e014a145a9b7dea0e9524fe9d5c88fc2310574c614a1ee053e.md
@@ -0,0 +1,45 @@
+From:
+To:
+Subject: Activity in Case 9:09-cv-80469-KAM Doe II |. Epstein et al Order Dismissing Case
+Date: Thu, 08 Jul 2010 14:54:01 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. Distriet Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 7/8/2010 at 10:54 AM EDT and filed on 7/8/2010
+Case Name:
+Doe II . Epstein et al
+Case Number:
+9:09-cv-80469-KAM
+Filer:
+WARNING: CASE CLOSED on 07/08/2010
+Document Number: 82
+Docket Text:
+ORDER DISMISSING CASE with prejudice. All pending motions are denied as moot. This case
+is CLOSED. Signed by Judge Kenneth A. Marra on 7/7/2010. (ir)
+9:09-ev-80469-KAM Notice has been electronically mailed to:
+Bradley James Edwards
+Bruce Reinhart
+Denise Kalland
+Isidro Manuel Garcia
+Jack Alan Goldberger
+Michael James Pike
+Robert Deweese Critton, Jr
+
+
+9:09-cv-80469-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP dcecfStamp_ID=1105629215 [Date=7/8/2010] [FileNumber=7765437-0]
+[243a4462c17c3d0c06bfbad6cae2b8c4a34319d328762156e5ef38630573091ed2d2
+b4b14b5бe4761еЗb2df99801b9b3813b29a93a8f23946c4988154fa5fad3]]
diff --git a/vision-fixhub/ds9-unparsed-06/2e91b7b84bd578e014a145a9b7dea0e9524fe9d5c88fc2310574c614a1ee053e.receipt.json b/vision-fixhub/ds9-unparsed-06/2e91b7b84bd578e014a145a9b7dea0e9524fe9d5c88fc2310574c614a1ee053e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ad89d1b948bbdfecee62781acc80569305fcbca6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2e91b7b84bd578e014a145a9b7dea0e9524fe9d5c88fc2310574c614a1ee053e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "2e91b7b84bd578e014a145a9b7dea0e9524fe9d5c88fc2310574c614a1ee053e",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3c1bfdfa449dd40d558abe22998f39888384bd6c401d3d319f446200705526de",
+  "output_sha256": "201eb6e21b14daf699d3956b83507a8082d3cd1174d965b276e3af1a2875309c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2e943ad0715d96afcb1b36b1c6d936fe3ce92318c6f210143e8e19d2043d01f5.md b/vision-fixhub/ds9-unparsed-06/2e943ad0715d96afcb1b36b1c6d936fe3ce92318c6f210143e8e19d2043d01f5.md
new file mode 100644
index 0000000000000000000000000000000000000000..2a2c07beb54526a17ae27562276d0e1da1dddf52
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2e943ad0715d96afcb1b36b1c6d936fe3ce92318c6f210143e8e19d2043d01f5.md
@@ -0,0 +1,23 @@
+From: "KATHERINE W. EZELL" <
+To: "l
+L. (USAFLS)" ≤
+JOSEFSBERG" <
+Subject: Re: Magistrate Interview
+Date: Wed, 24 Aug 2011 23:04:35 +0000
+Importance: Normal
+≥. "ROBERT
+That sounds so good, I think a hostile question answered well can be much more impressive and memorable than all
+friendly ones. We're behind you all the way! Fingers crossed. Keep us posted! K
+Sent from my Blackberry. Please excuse any typos. Thank you.
+1. (USAFLS) [mailto:
+Sent: Wednesday, August 24, 2011 05:44 PM
+To: ROBERT I. JOSEFSBERG; KATHERINE W. EZELL; Amy Ederi </
+Subject: Magistrate Interview
+Hi Bob, Kathy, and Amy - I had my interview with the committee this afternoon, and it seemed to go pretty well
+(knock wood). Only one hostile question, and I think I answered the question satisfactorily. No questions about
+Epstein at all.
+Thank you so much for all of the well-wishes and good thoughts!
+They are finishing up the interviews on Saturday and everyone thinks we will have an answer on whom they are
+sending through to the District Judges on Saturday night or Sunday.
+Fingers crossed for a little while longer, please.
+00
diff --git a/vision-fixhub/ds9-unparsed-06/2e943ad0715d96afcb1b36b1c6d936fe3ce92318c6f210143e8e19d2043d01f5.receipt.json b/vision-fixhub/ds9-unparsed-06/2e943ad0715d96afcb1b36b1c6d936fe3ce92318c6f210143e8e19d2043d01f5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ab56e6246b653396f3ee80eed4535328ef580fa3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2e943ad0715d96afcb1b36b1c6d936fe3ce92318c6f210143e8e19d2043d01f5.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "2e943ad0715d96afcb1b36b1c6d936fe3ce92318c6f210143e8e19d2043d01f5",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "150821cfca04f36bae890fc52d35691c0c79e1aa9df180265db2b34179d25326",
+  "output_sha256": "4dfdae14b3e579320cd70e9f52c73dfde619eb31df042fe252fffa1ef8c424c8",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2ede47e10b6f8f10af4750a860f7e685d7dc62616e2ff86c286da8e03ad47e65.md b/vision-fixhub/ds9-unparsed-06/2ede47e10b6f8f10af4750a860f7e685d7dc62616e2ff86c286da8e03ad47e65.md
new file mode 100644
index 0000000000000000000000000000000000000000..4a6415d059baaa05c8fd2f09edbaa4ff2c8e9e62
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2ede47e10b6f8f10af4750a860f7e685d7dc62616e2ff86c286da8e03ad47e65.md
@@ -0,0 +1,21 @@
+From:
+To:
+Cc:
+Subject: FW: Jeffrey Epstein
+Date: Fri, 30 Jul 2010 18:23:14 +0000
+Importance: Normal
+HI
+- I am forwarding your email to the AUSA and FBI for response. I told the reporter to call you, as he
+was talking about a DOJ investigation.
+Re DSFL, I told him we neither confirm nor deny......
+- please fill in
+Thanks
+From:
+Sent: Friday, July 30, 2010 1:57 PM
+To:
+Subject: Jeffrey Epstein
+Any idea if its true that there is an ongoing investigation? CNN just called and if this is completely untrue, I want to wave
+them off reporting that he is under investigation (without of course actually confirming or denying the existence thereof.)
+http://www.thedailybeast.com/blogs-and-stories/2010-07-29/jeffrey-epstein-feds-probe-possible-child-trafficking-charge/
+Office of Public Affairs
+Department of Justice
diff --git a/vision-fixhub/ds9-unparsed-06/2ede47e10b6f8f10af4750a860f7e685d7dc62616e2ff86c286da8e03ad47e65.receipt.json b/vision-fixhub/ds9-unparsed-06/2ede47e10b6f8f10af4750a860f7e685d7dc62616e2ff86c286da8e03ad47e65.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..210e23facc69a39bb6dc4d30e35286d9541579ed
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2ede47e10b6f8f10af4750a860f7e685d7dc62616e2ff86c286da8e03ad47e65.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "2ede47e10b6f8f10af4750a860f7e685d7dc62616e2ff86c286da8e03ad47e65",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "4c0cddfe44649bcef1ff55dc095593ff4fe619d4ba616ac254bd2d40f7938e13",
+  "output_sha256": "d3ab28a5ce4e4eb261d8964b4aa8a49c11c922a8403ee1dd873785754731e946",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2f1c3624d6b2289213d7c5e1d980f03699f1e1a4f15dbb74a3135d4d349280e4.md b/vision-fixhub/ds9-unparsed-06/2f1c3624d6b2289213d7c5e1d980f03699f1e1a4f15dbb74a3135d4d349280e4.md
new file mode 100644
index 0000000000000000000000000000000000000000..6a159f1476d33e06de97f7c40db5d9e2f7963ec8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2f1c3624d6b2289213d7c5e1d980f03699f1e1a4f15dbb74a3135d4d349280e4.md
@@ -0,0 +1,23 @@
+From: Maria Kelljchian <
+To:
+(USAFLS)"" =
+(USAFLS)" 4
+Cc: 'Paul Cassell' <
+Subject: Jane Doe #1 and Jane Doe #2 vs. US
+Date: Mon, 03 Oct 2011 18:05:49 +0000
+Importance: Normal
+Attachments: Plaintiffs_1st_RFP_to_US_ATTY.pdf
+Inline-Images: image001.jpg
+>
+P, "RBlack@royblack.com'" <
+Attached please find:
+JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT REGARDING
+INFORMATION RELEVANT TO THEIR PENDING ACTION CONCERN THE CRIME VICTIMS RIGHTS ACT
+Copy has also been sent via US Mail today.
+Maria W. Kelljchian
+Florida Registered Paralegal
+Farmer, Jaffe, Weissing,
+Edwards, Fistos & Lehrman, P.L.
+Fort Lauderdale, Florida 33301
+f
+Become our fan on Facebook
diff --git a/vision-fixhub/ds9-unparsed-06/2f1c3624d6b2289213d7c5e1d980f03699f1e1a4f15dbb74a3135d4d349280e4.receipt.json b/vision-fixhub/ds9-unparsed-06/2f1c3624d6b2289213d7c5e1d980f03699f1e1a4f15dbb74a3135d4d349280e4.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ec17d7eeb79f96220bcc7a93291871bd6b8e396c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2f1c3624d6b2289213d7c5e1d980f03699f1e1a4f15dbb74a3135d4d349280e4.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "2f1c3624d6b2289213d7c5e1d980f03699f1e1a4f15dbb74a3135d4d349280e4",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "d136a35c76c466ab86c30c5494e7c5ab86f6199318feaeb7e2e6be193b3fa77c",
+  "output_sha256": "3565abee525d6872a38e192f6332148911622b9aa14a379a66e142b95b665619",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2f38d808eb897ab31da0fb6fb2535567e9ab5b2b8e7ff14ff6e9fe4415bb44c2.md b/vision-fixhub/ds9-unparsed-06/2f38d808eb897ab31da0fb6fb2535567e9ab5b2b8e7ff14ff6e9fe4415bb44c2.md
new file mode 100644
index 0000000000000000000000000000000000000000..125f657fb48b54813a0c731f1aa1f6f93c274566
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2f38d808eb897ab31da0fb6fb2535567e9ab5b2b8e7ff14ff6e9fe4415bb44c2.md
@@ -0,0 +1,10069 @@
+Biling Cycle Date:
+Account Number:
+1 of 37
+05/15/05 - 06/14/05
+How To Contact Us:
+• 1-800-331-0500 or 611 from your wireless phone
+• For Deaf / Hard of Hearing Customers (TTY/TDD)
+1-866-241-6567
+Wireless Number
+561-324-7996
+Previous Balance
+Payments Posted
+PAST DUE BALANCE
+Payable Immediately
+Monthly Service Charges
+Usage Charges
+Credits/Adjustments/Other Charges
+Government Fees and Taxes
+TOTAL CURRENT CHARGES
+Due Jul 07, 2005
+Late fees assessed after Jul 07
+Total Amount Due $115.62
+83.65
+-61.84
+21.81
+48.97
+27.82
+3.50
+13.52
+93.81
+Send a picture message today
+Now you can share more pictures than ever with your Cingular phone. Snap a picture
+ersonalize it and send it to friends and family with a Cingular, Verizon or T-Mobili
+bonitor, shard pit any email aloney. Satindand wie charges diply Foging Package.
+Get more info at www.cingular.com/multimediamessaging
+PO BOX 772349 - (MIA)
+OCALA, FL 34477-2349
+*BWNHHBD
+#05725942030013*
+Return the guitar Wieles th payment
+Account Number
+Total Amount Due
+$115.62
+Amount Paid:
+$
+* Please do not send correspondence wish paymens.
+MICHAEL DAVIS
+Please Make Check Payable To:
+Cingular Wireless
+
+
+
+Billing Cycle Date:
+Account Number:
+2 of 37
+05/15/05 - 06/14/05
+General Information
+• Terms: The past due amount is due immediately. Late payment charges of 1.5% may be
+applied to any unpaid balance as of your next billing date. When you send us a
+selected services. Usage and toll charges are billed in arrears. Certain usage
+and toll charges may appear more than one month in arrears. Prorated monthly
+charges may apply for new services or changes to existing services during a
+billing period. These will appear in the Monthly Service Charges sections of the
+• Please do not enclose correspondence with your payment for we cannot guarantee
+TO BOX 772349- LOVE OGA 0L3401-ing: Cingular Wireles,
+• Calls to our Customer Service Centers may be monitored to ensure high quality
+service to our customers.
+• Questions on accessibility by persons with disabilities: 1-866-241-6568
+• Cingular Wireless Tax ID # 74-2955068 / Cingular Wireless DUNS # 003548489
+**********************************************************************
+Auto Pay Authorization Agreement - For use only with Auto Pay phone enrollment
+If I enroll, I authorize Cingular Wireless to pay my bill monthly by debiting my
+bank account. I can cancel authorization by notifying Cingular at
+www.cingular.com, by calling 1-800-331-0500, or by dialing 611 from my wireless
+phone. If my bank rejects a payment, I may be charged a return fee.
+How To Pay
+Checking and savings account payments, check cards, credit cards are accepted.
+Payments made with a representative may be subject to a service fee.
+Note: There is no fec for choosing any of the following payment channels:
+Pay using your wireless phone for free
+- Dial *PAY (*729), then hit send.
+- Make a one time payment following the instructions provided.
+Pay using any landline phone - Dial 1-800-331-0500
+- Enter your wireless number and billing ZIP Code and follow the prompts
+- Go to www.cingular.com/
+- Mail your remittance stub and a check or money order in the envelope provided.
+- It may take up to 7 - 10 days for the payment to post.
+DST X280-9900 (10/03)
+
+
+-
+Prior Activity
+Previous Balance
+Detail of Payments Posted
+Payment by One-time Payment posted on May 19, 2005
+TOTAL PAST DUE BALANCE
+Account Charges
+Credits, Adjustments & Other Charges
+Late Payment Fee
+ACCOUNT CREDITS, ADJUSTMENTS & OTHER CHARGES
+Government Fees and Taxes
+FEDERAL EXCISE TAX
+ACCOUNT GOVERNMENT FEES AND TAXES
+Wireless Line Summary For:
+User Name: MICHAEL DAVIS
+Monthly Service Charges
+Rate Plan
+Includes:
+- /WRLSS INTRNT XPRS PAY PER USE
+- BASIC VOICEMAIL-NIC
+- CALL FORWARDING N/C
+- CALL WAITING NIC
+- CALLER ID N/C
+- DATA VOLUME DETAILED BILLING
+- DETAILED BILLING NIC
+- MULTIMEDIA PAY PER USE
+- THREE PARTY CALL NIC
+Other Services
+15000 NIGHT/WKND MINS CTH
+1600 ANYTIME MINS
+/REGION GS
+/UNLIMITED EXPANDED M2M-N/C
+/UNLIMITED M2M EXPND MINS
+CINGULAR NATIONWIDE TOLL FREE
+FL ROAM WITH HOME
+NATIONWIDE $.79/MIN ROAMING
+ROAMER ADMIN FEE EXCLUSION
+WIRELESS PHONE INS. & SVC FEE
+Wireless Data
+TXT MSG PROMO 200
+Billing Cycle Date
+Iccount Number
+301305 - 061405
+05725942-001-03
+83.65
+-61.84
+$21.81
+05725942-001-03
+0.33
+$0.33
+0.01
+$0.01
+Period
+06/15-07/14
+Monthly
+Charge
+39.99
+Total
+Charge
+39.99
+-
+06/15-07/14
+06/15-07714
+06/15-07/14
+06/15-07/14
+06/15-07/14
+06/15-07/14
+06/15-07/14
+06/15-07/14
+06/15-07/14
+06/15-07/14
+06/15-07/14
+3.99
+1.99
+3.99
+4.99
+
+
+× cingular
+Wireless Line Summary For (Continued):
+User Name: MICHAEL DAVIS
+TOTAL MONTHLY SERVICE CHARGES
+Usage Charges
+(See Usage Charge Details)
+TOTAL USAGE CHARGES
+Credits, Adjustments & Other Charges
+FED UNIVERSAL SVC CHARGE
+911 MONTHLY
+REGULATORY COST RECOVERY FEE
+TOTAL CREDITS, ADJUSTMENTS & OTHER CHARGES
+Government Fees and Taxes
+FEDERAL EXCISE TAX
+STATE COMMUNICATIONS TAX
+LOCAL COMMUNICATIONS TAX
+TOTAL GOVERNMENT FEES and TAXES
+TOTAL AMOUNT DUE
+Usage Charge Details
+User Name: MICHAEL DAVIS
+Summary of
+Usage Charges
+/RGNP 600 UMM 5KNW
+Peak
+JUNLIMITED EXPANDED M2M-N
+15000 NIGHT/WKND MINS CTH
+Directory Assistance
+Long Distance
+Domestic
+Roaming
+Subtotal
+Summary of
+Wireless Data
+Text Messaging
+-CINGULAR MOBILE TO MOBILE Outgoing
+- CINGULAR MOBILE TO MOBILE Incoming
+DST X280-9900 (10103)
+Minutes
+Included
+In Plan
+600
+5000
+Msg/KB
+Included
+In Plan
+401305 - 061405
+$48.97
+$27.82
+2.30
+0.56
+2.09
+1.35
+$3.17
+$13.51
+$93.47
+Minutes
+Used
+Billed
+Minutes
+Billed
+Rate
+638
+608
+840
+38
+0.45
+> Call (8)
+2
+See Call Details
+See Call Details
+Msg/KB
+Billed
+Used
+Msg/KB
+Billed
+Rate
+22
+22
+Total
+Charge
+17.10
+10.50
+$27.60
+Total
+Charge
+
+
+* cingular
+Billing Cycle Date:
+Account Number:
+5 of 37
+05/15005 - 06/14/05
+Usage Charge Details (Continued)
+User Name: MICHAEL DAVIS
+Summary of
+Wireless Data
+ext Messagin
+Message Center-Anti Incoming
+- OTHER MOBILE TO MOBILE Ourgoing
+- OTHER MOBILE TO MOBILE Incoming
+/WRLSS INTRNT XPRS PAY PER USE
+Msg/KB
+Included
+In Plan
+Msg/KB
+Used
+Billed
+Msg/KB
+Billed
+Rate
+Total
+Charge
+1
+15
+17
+22
+22
+0.22
+Subtotal
+$0.22
+TOTAL USAGE CHARGES
+$27.82
+Call Detail
+User Name: MICHAEL DAVIS
+561-324-7996
+Call Location(CL): AU=Aucilla, BR=Bristol, BU=Bushnell, CH=Chiefland, CL=Clewiston, DB=Daytona, FL.=Flagler,
+FK=Florida Keys, FM=Fort Myers, FP=Fort Pierce, FW=Fort Walton, GV=Gainesville, JX=Jacksonville, LC=Lake City
+L.B=Leesburg, MI=Miami, MA=Marianna, MB=Melbourne, MX=Mexico Beach, OC=Ocala, OR=Orlando, PL.=Palatka, PC=Panama City,
+PS=Pensacola, PJ=Port St Joe, SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa, VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM 5KNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+eature: B=Duect Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H= Group Mobile to Mobile Call
+-Incoming Call; K=Fax Call: M-Mobile To Mobile Discount: P=Priority Access Service: Q=|-VPN; R=Roam with Hom
+S=Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Item
+Called
+10
+11
+12
+13
+14
+15
+16
+17
+19
+20
+21
+22
+Day Date
+Time
+Sun
+05/15 11:47AM
+05/15 12:05PM
+05/15 12:15PM
+05/15
+12:22PM
+05/15
+12:38PM
+05/15
+12:55PM
+05/15
+01:01PM
+05/15
+01:03PM
+05/15
+01: 50PM
+05/15
+03:16PM
+05/15
+03:18PM
+05/15
+04:29PM
+05/15
+04: 32PM
+05/15
+05/15
+05/15
+05/15
+05/15
+05/15
+05/15
+05/15
+05/15
+07:00PM
+07:05PM
+07: 30PM
+08: 46PM
+09: 02PM
+09: 03PM
+09:56PM
+09:56PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+" PALM FL
+NEW YO NY
+INCOMI CL
+" PALM FL
+MIAMI,
+FL
+INCOMI
+INCOMI
+CL
+# PALM
+FL
+W PALM
+FL
+" PALM
+FL
+INCOMI
+CL
+PALM
+FL
+PALM FL
+PALM FL
+W
+PALM FL
+PALM FL
+PALM
+INCOMI
+CI
+INCOMI
+CL
+" PALM FL
+" PALM FL
+Rate Rate Fea- Airtime
+Min Code
+RSD1
+Pd
+ture Charge
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+N
+N
+IN
+RSD1
+RSD1
+RSD1
+IW
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+ICH
+IN
+RSD1
+RSD1
+LD
+DA
+Total
+Charge
+-
+
+
+Billing Cycle Date
+Iccount Number
+6 of 37
+05/15/05-06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+23
+Non
+05/16
+24
+05/16
+25
+05/16
+26
+05/16
+27
+05/16
+28
+05/16
+29
+05/16
+30
+05/16
+31
+05/16
+32
+05/16
+33
+05/16
+34
+05/16
+35
+05/16
+36
+05/16
+37
+05/16
+38
+05/16
+39
+05/16
+40
+05/16
+41
+05/16
+42
+05/16
+43
+05/16
+44
+05/16
+45
+05/16
+46
+05/16
+47
+05/16
+48
+05/16
+49
+05/16
+50
+05/16
+51
+05/16
+52
+05/16
+53
+05/16
+54
+05/16
+55
+05/16
+56
+05/16
+57
+05/16
+58
+Tue
+05/17
+59
+05/17
+60
+05/17
+61
+05/17
+62
+05/17
+63
+05/17
+64
+05/17
+65
+05/17
+DST X280-9900 (10/03)
+Time
+08: 40A
+08: 41AM
+08:44AM
+08: 49AM
+08:50AM
+08: 55AM
+09:38AM
+11: 40AM
+11:41AM
+11: 42AM
+11:47AM
+11: 50AM
+11:59AM
+12:00PM
+12: 04PM
+12:04PM
+12:06PM
+12: 08PM
+12:14PM
+03:12PM
+03:31PM
+03: 50PM
+03:58PM
+04:05PM
+04:09PM
+04:12PM
+04:30PM
+04:34PM
+05:28PM
+05:41PM
+05: 55PM
+06: 40PM
+06:42PM
+06:44PM
+07:21PM
+08: 56AM
+08: 57AM
+08: 57AM
+09:08AM
+09: 11AM
+09: 12AM
+09:22AM
+09:24AM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+W PALM FL
+" PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+MIAMI,
+FL
+MIAMI,
+FL
+MIAMI,
+FL
+MIAMI,
+FL
+INCOMI
+CI
+INCOMI CL
+NEW YO NY
+INCOMI CL
+MIAMI
+FL
+INCOMI CL
+INCOMI CL
+DELRAY FL
+MIAMI,
+FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+" PALM FL
+W PALM FL
+INCOMI CL
+W PALM
+FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FI
+W PALM FL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM EL
+INCOMI CL
+W PALM FL
+INCOMI CL
+Min Code
+RSD1
+RSD1
+P
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+P
+RSD1
+RSD1
+RSD1
+P
+P
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+RSD1
+ture
+M
+M
+M
+M
+M
+M
+IR
+IRM
+M
+IN
+IM
+M
+M
+I
+M
+I
+M
+M
+Total
+Charge
+.00
+
+
+Billing Cycle Date:
+Account Number:
+7 of 37
+05/15/05 - 06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+PS=Pensacola, PI=Port St Joe, SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa, VB=Vero Beach, NA=Naples,
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+I=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service: O=_-VPN; R=Roam with Home
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+66
+05/17
+09: 39AM
+67
+05/17
+09:50AM
+68
+05/17
+10:12AM
+69
+05/17
+10:22AM
+70
+05/17
+12:37PM
+71
+05/17
+12:51PM
+72
+05/17
+02:09PM
+73
+05/17
+02:12PM
+74
+05/17
+02: :35PM
+75
+05/17
+02:38PM
+76
+05/17
+02: 41PM
+77
+05/17
+02: 44PM
+78
+05/17
+02:57PM
+79
+05/17
+03:27PM
+80
+05/17
+03: 34PM
+81
+05/17
+03: 36PM
+82
+05/17
+03:46PM
+83
+05/17
+03: 49PM
+84
+05/17
+03:57PM
+85
+05/17
+04: 00PM
+86
+05/17
+04:01PM
+87
+05/17
+04: 43PM
+88
+05/17
+05: 21PM
+89
+05/17
+05:27PM
+90
+05/17
+05: :34PM
+91
+05/17
+05: 50PM
+92
+05/17
+06: 26PM
+93
+05/17
+06:48PM
+94
+05/17
+06: 49PM
+95
+05/17
+06: 49PM
+96
+05/17
+06:49PM
+97
+05/17
+06: 53PM
+98
+05/17
+08: 08PM
+99
+Wed
+05/18
+08: 00AM
+100
+05/18
+08:18AM
+101
+05/18
+08:27AM
+102
+05/18
+08: 35AM
+103
+05/18
+08: 43AM
+104
+05/18
+08: 47AM
+105
+05/18
+10:04AM
+106
+05/18
+10:06AM
+107
+05/18
+10:07AM
+108
+05/18
+10:12AM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+MIAMI
+FL
+INCOMI
+CL
+MIAMI,
+FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+BOYTON FL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+JUPITE FL
+W PALM FL
+" PALM FL
+INCOMI CL
+JUPITE
+FL
+JUPITE
+FL
+JUPITE EL
+JUPITE EL
+W PALM FL
+W PALM FL
+W PALM FI
+W PALM FL
+MIAMI,
+FL
+MIAMI,
+FL
+INCOMI CL
+W PALM FL
+MIAMI,
+EL
+MIAMI,
+FL
+MIAMI,
+FL
+W PALM FL
+Min Rate Rade Fure Anarge
+ture
+RSD1
+P
+RSD1
+RSD1
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+R
+IR
+RSD1
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+M
+RSD1
+RSD1
+RSD1
+M
+M
+RSD1
+RSD1
+P
+P
+P
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+M
+RSD1
+RSD1
+M
+RSD1
+P
+RSD1
+RSD1
+RSD1
+RSD1
+P
+M
+RSD1
+RSD1
+RSD1
+RSD1
+P
+bA
+Total
+Charge
+.00
+
+
+Billing Cycle Date:
+Account Number:
+8 of 37
+05/15/05 - 06/14/05
+05700040 904-09
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Eloni Call a Cal. MeTal Wile Dion: Car Ales die: - bila abile me
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+109
+05/18
+110
+05/18
+111
+05/18
+112
+05/18
+113
+05/18
+114
+05/18
+115
+05/18
+116
+05/18
+117
+05/18
+118
+05/18
+119
+05/18
+120
+05/18
+121
+05/18
+122
+05/18
+123
+05/18
+124
+05/18
+125
+05/18
+126
+05/18
+127
+05/18
+128
+05/18
+129
+05/18
+130
+05/18
+131
+05/18
+132
+05/18
+133
+05/18
+134
+05/18
+135
+05/18
+136
+05/18
+137
+05/18
+138
+05/18
+139
+05/18
+140
+05/18
+141
+05/18
+142
+05/18
+143
+05/18
+05/18
+05/18
+146
+147
+148
+149
+150
+151
+05/18
+05/18
+05/18
+05/18
+05/18
+05/18
+DST X280-9900 (10/03)
+Time
+11:24AM
+11:29AM
+11:34AM
+11: 34AM
+11: 39AM
+01:02PM
+01:09PM
+01:10PM
+01:20PM
+01:28PM
+01:29PM
+01:40PM
+01:43PM
+01:59PM
+02: :02PM
+02:04PM
+02:04PM
+02: 05PM
+02: 09PM
+02:16PM
+03:24PM
+03:35PM
+03:54PM
+04:02PM
+04:09PM
+04:32PM
+04:47PM
+04:47PM
+05: :31PM
+05: 43PM
+05: 55PM
+05: 55PM
+06:19PM
+06: 22PM
+06:23PM
+06:24PM
+06:43PM
+06:43PM
+06: 48PM
+06: 58PM
+07:04PM
+07:12PM
+07:18PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+INCOMI CL
+" PALM FL
+INCOMI CL
+INCOMI
+CL
+INCOMI
+CL
+" PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM EL
+W PALM FL
+NEW YO NY
+PALM FL
+INCOMI CL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+MIAMI,
+FL
+W PALM FL
+W PALM FL
+W PALM
+FL
+N PALM EL
+W PALM EL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FI
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FI
+INCOMI CL
+MIAMI,
+FL
+W PALM FI
+Min Rade Rate Fure Alaine
+ture
+RSD1
+P
+RSD1
+I
+RSD1
+RSD1
+RSD1
+RSD1
+I
+IRM
+RSD1
+RSD1
+IM
+RSD1
+RSD1
+M
+RSD1
+R8D1
+RSD1
+IRM
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+M
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+P
+P
+M
+RSD1
+M
+RSD1
+RSD1
+RSD1
+P
+P
+P
+RSD1
+IM
+M
+RSD1
+P
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+IRM
+RSD1
+RSD1
+P
+P
+M
+bA
+Total
+Charg
+. 00
+1.00
+.00
+
+
+Billing Cycle Date:
+Account Number:
+9 of 37
+05/15/05 - 06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+1=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount; P=Priority Access Service; Q= -VPN; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+152
+05/18
+07: 25PM
+153
+05/18
+07:31PM
+154
+05/18
+07:32PM
+155
+05/18
+07:45PM
+156
+05/18
+08:16PM
+157
+05/18
+08:54PM
+158
+05/18
+08:59PM
+159
+05/18
+09: 02PM
+160
+05/18
+09:20PM
+161
+05/18
+09:24PM
+162
+05/18
+09:27PM
+163
+05/18
+09: 33PM
+164
+05/18
+10:35PM
+165
+05/18
+10:36PM
+166
+05/18
+10: 45PM
+167
+05/18
+11:22PM
+168
+Thu
+05/19
+10:15AM
+169
+05/19
+11: 36AM
+170
+05/19
+02: :53PM
+171
+05/19
+03:14PM
+172
+05/19
+03:19PM
+173
+05/19
+03:20PM
+174
+05/19
+03:29PM
+175
+05/19
+03:45PM
+176
+05/19
+03:55PM
+177
+05/19
+04:18PM
+178
+05/19
+04:19PM
+179
+05/19
+04:34PM
+180
+05/19
+04: 35PM
+181
+05/19
+04:37PM
+182
+05/19
+05:20PM
+183
+05/19
+05: 21PM
+184
+05/19
+05: 22PM
+05/19
+05: 28PM
+05/19
+05:34PM
+187
+05/19
+05:35PM
+05/19
+05: 43PM
+189
+190
+191
+192
+193
+194
+05/19
+05: 44PM
+05/19
+05: 54PM
+05/19
+05: 55PM
+05/19
+06:14PM
+05/19
+06:22PM
+05/19
+06:24PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+VOICE CL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+INCOMI
+CL
+W PALM FL
+PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+W PALM
+FL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FI
+W PALM FL
+W
+PALM
+FL
+N PALM
+FL
+W PALM EL
+W PALM EL
+" PALM FL
+I PALM FL
+W PALM FL
+W PALM FL
+PALM FL
+PALM FL
+PALM
+FL
+PALM FL
+W PALM EL
+W PALM FL
+W PALM FL
+W PALM FL
+Min Rade Rate Fire Alaine
+ture
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+R8D1
+RSD1
+RSD1
+10
+RSD1
+IN
+W
+ICH
+IN
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+I
+I
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+14
+RSD1
+IRM
+M
+M
+RSD1
+P
+P
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+M
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+M
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+bA
+Total
+Charge
+. 00
+.00
+.00
+1.00
+
+
+Billing Cycle Date:
+Account Number:
+10 of 37
+05/15/05 - 06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+195
+05/19
+06: 34PM
+196
+05/19
+06:35PM
+197
+05/19
+06:37PM
+198
+05/19
+06: 38PM
+199
+05/19
+06: 46PM
+200
+05/19
+07:10PM
+201
+05/19
+07:19PM
+202
+05/19
+08:34PM
+203
+05/19
+08: :36PM
+204
+05/19
+08:36PM
+205
+05/19
+08: 43PM
+206
+05/19
+09: 44PM
+207
+05/19
+09: 49PM
+208
+Fri
+05/20
+08: 22AM
+209
+05/20
+10: :36AM
+210
+05/20
+10: 48AM
+211
+05/20
+10: 50AM
+05/20
+11:17AM
+213
+214
+215
+216
+217
+218
+219
+220
+221
+222
+223
+224
+225
+226
+227
+228
+229
+230
+231
+232
+233
+234
+235
+236
+237
+05/20
+11:19AM
+05/20
+11: 21AM
+05/20
+11:22AM
+05/20
+11:24AM
+05/20
+11: 32AM
+05/20
+11: 36AM
+05/20
+11: 39AM
+05/20
+11: 46AM
+05/20
+11:48AM
+05/20
+11:53AM
+05/20
+12:14PM
+05/20
+12:21PM
+05/20
+12:27PM
+05/20
+12: 32PM
+05/20
+02: 45PM
+05/20
+02:47PM
+05/20
+03: 05PM
+05/20
+03:38PM
+05/20
+05:10PM
+05/20
+05:10PM
+05/20
+05:12PM
+05/20
+05: :13PM
+05/20
+05:26PM
+05/20
+05:26PM
+05/20
+05: 35PM
+DST X280-9900 (10/03)
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+W PALM FL
+" PALM FL
+W PALM FL
+W PALM FL
+MIAMI, I
+FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM EL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+MIAMI, FL
+MIAMI, FL
+W PALM FL
+W PALM FL
+W PALM FL
+VOICE
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+INCOMI CL
+MIAMI,
+FL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+MIAMI,
+FI
+INCOMI CL
+MIAMI, FL
+MIAMI,
+FL
+INCOMI CL
+Min Code
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+RSD1
+RSD1
+RSD1
+RSD1
+P
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+ture
+IC
+M
+M
+M
+M
+R
+RM
+M
+IN
+IR
+I
+IR
+IR
+RM
+ICM
+Total
+Charge
+.00
+
+
+Billing Cycle Date:
+Account Number:
+11 of 37
+05/15/05 - 06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+Incoming Call; K=Fax Call: M=Mobile To Mobile Discount; P=Priority Access Service; Q= -VPN; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+238
+05/20
+05: 36PM
+239
+05/20
+05:57PM
+240
+05/20
+05:57PM
+241
+05/20
+06:04PM
+242
+05/20
+06: 05PM
+243
+05/20
+06:06PM
+244
+05/20
+06:08PM
+245
+05/20
+06:11PM
+246
+05/20
+06:30PM
+247
+05/20
+06:46PM
+248
+05/20
+07:38PM
+249
+05/20
+07: 39PM
+250
+05/20
+07: 48PM
+251
+05/20
+08:28PM
+252
+05/20
+08: :34PM
+253
+05/20
+08: 35PM
+254
+05/20
+08:52PM
+255
+05/20
+08: 56PM
+256
+05/20
+09:21PM
+257
+05/20
+09:47PM
+258
+05/20
+10: 02PM
+259
+05/20
+10:04PM
+260
+05/20
+10:11PM
+261
+05/20
+11:46PM
+262
+05/20
+11:47PM
+263
+05/20
+11:55PM
+264
+Sat
+05/21
+12:56AM
+265
+05/21
+12:58AM
+266
+05/21
+01: 04AM
+267
+05/21
+09:29AM
+268
+05/21
+10:31AM
+269
+05/21
+10: 54AM
+270
+05/21
+10: 58AM
+271
+05/21
+11: 25AM
+272
+05/21
+11:25AM
+273
+05/21
+11:28AM
+274
+05/21
+02:43PM
+275
+05/21
+02: :44PM
+276
+05/21
+02: 52PM
+277
+05/21
+03: 07PM
+278
+05/21
+03:34PM
+279
+05/21
+06:11PM
+280
+05/21
+06: 27PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+W PALM FL
+" PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+MIAMI,
+FL
+INCOMI CL
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+MIAMI, FL
+INCOMI CL
+W PALM FL
+W PALM FL
+PALM FL
+PALM FL
+W
+PALM FL
+W PALM FL
+" PALM FL
+W PALM FL
+INCOMI CL
+MIAMI,
+FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+" PALM FL
+W PALM FL
+W PALM FL
+W PALM
+FL
+W PALM
+FL
+W PALM
+FL
+INCOMI
+CL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+INCOMI CL
+Min Code Rade Fure Alrige
+ture
+RSD1
+P
+IN
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+I
+RSD1
+RSD1
+RSD1
+I
+IR
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IRN
+RSD1
+RSD1
+RSD1
+N
+IN
+IW
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IW
+RSD1
+N
+RSD1
+RSD1
+RSD1
+RSD1
+= z z
+IN
+Total
+Charge
+.00
+1.00
+.00
+.00
+1.00
+
+
+Billing Cycle Date:
+Account Number:
+12 of 37
+05/15/05 - 06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+eature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Call
+LIncoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; Q- -VPN; R=Roam with Hon
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+ture
+Item Day Date
+Time
+281
+05/21
+06: 30PM
+282
+05/21
+06:33PM
+283
+05/21
+06:34PM
+284
+05/21
+06: 35PM
+285
+05/21
+07: 04PM
+286
+05/21
+07:24PM
+287
+05/21
+07:37PM
+288
+05/21
+07:39PM
+289
+05/21
+07:44PM
+290
+05/21
+07:58PM
+291
+05/21
+08: 01PM
+292
+05/21
+08: 01PM
+293
+05/21
+08: 02PM
+294
+05/21
+08:02PM
+295
+05/21
+08: 03PM
+296
+05/21
+08:10PM
+297
+05/21
+08:21PM
+298
+05/21
+09:21PM
+299
+05/21
+09:23PM
+300
+05/21
+10:13PM
+301
+05/21
+10:14PM
+302
+05/21
+10:14PM
+303
+05/21
+10:22PM
+304
+05/21
+10:30PM
+305
+05/21
+10:31PM
+306
+Sun
+05/22
+12: 55AM
+307
+05/22
+12:55AM
+308
+05/22
+12:18PM
+309
+05/22
+12: 31PM
+310
+05/22
+12: 42PM
+311
+05/22
+01:47PM
+312
+05/22
+01:49PM
+313
+05/22
+02: 21PM
+314
+05/22
+04: 24PM
+315
+05/22
+06:07PM
+316
+05/22
+07:11PM
+317
+05/22
+07:11PM
+318
+05/22
+08: 32PM
+319
+05/22
+08: 33PM
+320
+05/22
+08: 35PM
+321
+05/22
+08: 41PM
+322
+05/22
+08:43PM
+323
+05/22
+08:44PM
+DST X280-9900 (10/03)
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+561-753-8873
+Call To
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+VOICE
+CL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+" PALM FL
+INCOMI CL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM EL
+INCOMI CL
+INCOMI
+CL
+INCOMI CL
+" PALM FI
+VOICE
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PALM EL
+W PALM FL
+INCOMI CL
+INCOMI CL
+Min Code
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+R8D 1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+N
+N
+N
+2zzz
+IN
+W
+IN
+IN
+IN
+IN
+IN
+ICH
+Total
+Charge
+.00
+.00
+. 00
+.00
+.00
+
+
+Billing Cycle Date:
+Account Number:
+13 of 37
+05/15/05 - 06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa, VB=Vero Beach, NA=Naples,
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+1=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount; P=Priority Access Service; Q= -VPN; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Min Code Rade Fare Alrig
+ture
+Item Day Date Time
+324
+325
+326
+327
+328
+329
+330
+331
+332
+333
+334
+335
+336
+337
+338
+339
+340
+341
+342
+343
+344
+345
+346
+347
+348
+349
+350
+351
+352
+353
+354
+355
+356
+357
+358
+359
+360
+361
+362
+363
+364
+365
+366
+05/22
+08:51PM
+05/22
+10:01PM
+05/22
+10:01PM
+05/22
+10:04PM
+05/22
+10:28PM
+Mon
+05/23
+08: 45AM
+05/23
+08: 56AM
+05/23
+10: 08AM
+05/23
+10:38AM
+05/23
+11:51AM
+05/23
+11: 52AM
+05/23
+12: 31PM
+05/23
+02:57PM
+05/23
+02:59PM
+05/23
+03: 03PM
+05/23
+03: 56PM
+05/23
+04:39PM
+05/23
+05:14PM
+05/23
+05:16PM
+05/23
+05:19PM
+05/23
+05: 30PM
+05/23
+05: 42PM
+05/23
+05: 49PM
+05/23
+06:00PM
+05/23
+06: 09PM
+05/23
+06:13PM
+05/23
+06:25PM
+05/23
+06:26PM
+05/23
+06 : 49PM
+05/23
+06: 53PM
+05/23
+06:55PM
+05/23
+06: 56PM
+05/23
+07: 06PM
+05/23
+07:18PM
+05/23
+07:19PM
+05/23
+08:17PM
+05/23
+08:33PM
+05/23
+08:38PM
+05/23
+08:47PM
+05/23
+08:47PM
+05/23
+08:50PM
+05/23
+08:55PM
+05/23
+09:04PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM EL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+VOICE
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FI
+W PALM FL
+INCOMI CL
+INCOMI CL
+MIAMI,
+FL
+INCOMI CL
+W PALM FL
+INCOMI CL
+" PALM FL
+MIAMI, FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+MIAMI,
+FL
+INCOMI CL
+W PALM FL
+W PALM
+FL
+INCOMI
+CL
+MIAMI,
+FL
+MIAMI,
+FL
+INCOMI
+CL
+INCOMI CL
+W PALM FI
+W PALM
+FL
+W PALM
+FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PALM FI
+W PALM FI
+BOYTON FL
+INCOMI CL
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+R8D1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+IRM
+I
+IN
+IRM
+M
+M
+IR
+IRM
+IRM
+IRM
+R
+IRM
+P
+M
+IN
+M
+M
+P
+IN
+Total
+Charg
+.00
+
+
+Billing Cycle Date:
+Account Number:
+14 of 37
+05/15/05 - 06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+367
+05/23
+368
+05/23
+369
+05/23
+370
+05/23
+371
+05/23
+372
+05/23
+373
+05/23
+374
+05/23
+375
+05/23
+376
+05/23
+377
+05/23
+378
+05/23
+379
+05/23
+380
+05/23
+381
+05/23
+382
+05/23
+383
+Tue
+05/24
+384
+05/24
+385
+05/24
+386
+05/24
+387
+05/24
+388
+05/24
+389
+05/24
+390
+05/24
+391
+05/24
+392
+05/24
+393
+05/24
+394
+05/24
+395
+05/24
+396
+05/24
+397
+05/24
+398
+05/24
+399
+05/24
+400
+05/24
+401
+05/24
+402
+05/24
+403
+05/24
+404
+05/24
+405
+05/24
+406
+05/24
+407
+05/24
+408
+05/24
+409
+05/24
+DST X280-9900 (10/03)
+Time
+09:16PM
+09:16PM
+09:17PM
+09:20PM
+09: 35PM
+09:36PM
+10:00PM
+10: 03PM
+10:18PM
+10:27PM
+10:37PM
+10:53PM
+11:05PM
+11:45PM
+11:47PM
+11:47PM
+12:10PM
+12:21PM
+12: 26PM
+03: 02PM
+03:03PM
+03: 09PM
+03:10PM
+03:12PM
+03:22PM
+03: 27PM
+03: :33PM
+03:52PM
+03:53PM
+03: 54PM
+03:56PM
+03:57PM
+04: 00PM
+04:07PM
+04:55PM
+05: 22PM
+05: 59PM
+06:24PM
+06: 33PM
+06: :42PM
+06: 52PM
+06:54PM
+07: 00PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM EL
+W PALM FL
+INCOMI CL
+INCOMI CL
+INCOMI
+CL
+" PALM
+FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM EL
+W PALM FL
+W PALM EL
+W PALM EL
+INCOMI CL
+W PALM FL
+INCOMI CL
+MIAMI,
+FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+INCOMI
+CL
+N PALM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM EL
+W PALM EL
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PALM FI
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI CL
+W PALM FL
+W PALM EL
+N PALM FI
+W PALM FL
+W PALM FL
+Min Code
+Code Rade Fure Alrige
+ture
+RSD1
+RSD1
+CH
+RSD1
+RSD1
+IN
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+R8D1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IM
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+RM
+IR
+RSD1
+RSD1
+RSD1
+RSD1
+M
+IM
+M
+RSD1
+RSD1
+RSD1
+P
+P
+I
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+P
+RSD1
+RSD1
+I
+IM
+IN
+RSD1
+RSD1
+RSD1
+P
+P
+P
+RSD1
+M
+RSD1
+RSD1
+P
+P
+bA
+Total
+Charg
+.00
+. 00
+
+
+Billing Cycle Date:
+Account Number:
+15 of 37
+05/15/05 - 06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+I=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount; P=Priority Access Service; Q= -VPN; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+410
+05/24
+07:07PM
+411
+05/24
+07:11PM
+412
+05/24
+07:20PM
+413
+05/24
+07: 33PM
+414
+05/24
+07: 59PM
+415
+05/24
+08:01PM
+416
+05/24
+08: 06PM
+417
+05/24
+08:19PM
+418
+05/24
+09:43PM
+419
+05/24
+09:44PM
+420
+05/24
+09: 45PM
+421
+05/24
+09: 46PM
+422
+05/24
+09: 47PM
+423
+05/24
+09:49PM
+424
+05/24
+09: 52PM
+425
+05/24
+09: 54PM
+426
+05/24
+10:55PM
+427
+05/24
+11:14PM
+428
+05/24
+11:16PM
+429
+05/24
+11:20PM
+430
+05/24
+11:33PM
+431
+05/24
+11:37PM
+432
+05/24
+11: 42PM
+433
+Wed
+05/25
+02: :42AM
+434
+05/25
+03:10PM
+435
+05/25
+03: 24PM
+436
+05/25
+03: :31PM
+437
+05/25
+03: 44PM
+438
+05/25
+03:50PM
+439
+05/25
+03: 52PM
+440
+05/25
+03:53PM
+441
+05/25
+04: 04PM
+442
+05/25
+04:17PM
+05/25
+04:19PM
+444
+445
+446
+447
+448
+449
+450
+451
+452
+05/25
+04:27PM
+05/25
+04: 33PM
+05/25
+04:34PM
+05/25
+04:45PM
+05/25
+04:59PM
+05/25
+05: 03PM
+05/25
+05: 05PM
+05/25
+05:26PM
+05/25
+05: 28PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+INCOMI CL
+" PALM FL
+INCOMI CL
+VOICE
+CL
+W PALM FL
+" PALM
+FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PALM EL
+W PALM FL
+W PALM FI
+VOICE
+CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI CL
+NCHENR
+IL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+" PALM FL
+W PALM FL
+W PALM FI
+W PALM FL
+W PALM FL
+INCOMI
+CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+INCOMI CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+PERRIN FL
+W PALM FL
+INCOMI CL
+Min Rade Rate Fure Alaine
+ture
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IM
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+W
+IN
+IN
+RSD1
+RSD1
+W
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IC
+I
+RSD1
+RSD1
+RSD1
+RSD1
+P
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+IN
+RSD1
+RSD1
+M
+RSD1
+. 00
+.00
+
+
+Billing Cycle Date:
+Account Number:
+16 of 37
+05/15/05 - 06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+eature: B=Direct Asst Call Complete; C=Call Waiting: D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Call
+=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount; P=Priority Access Service; Q=-VPN; R=Roam with Hom
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+ture
+Item Day Date
+Time
+453
+05/25
+05: 31PM
+454
+05/25
+06:37PM
+455
+05/25
+07:31PM
+456
+05/25
+07: 45PM
+457
+05/25
+07:49PM
+458
+05/25
+08:16PM
+459
+05/25
+08:16PM
+460
+05/25
+08:20PM
+461
+05/25
+08:47PM
+462
+05/25
+08:51PM
+463
+05/25
+08:53PM
+464
+05/25
+09: 39PM
+465
+05/25
+09: 43PM
+466
+05/25
+09:44PM
+467
+05/25
+10: 06PM
+468
+05/25
+10:24PM
+469
+05/25
+10:28PM
+470
+05/25
+10: 30PM
+471
+05/25
+10:44PM
+472
+05/25
+10:48PM
+473
+Thu
+05/26
+01:44AM
+474
+05/26
+08: 22AM
+475
+05/26
+09: 41AM
+476
+05/26
+09: 42AM
+477
+05/26
+09: 45AM
+478
+05/26
+09: :46AM
+479
+05/26
+10: 21AM
+480
+05/26
+10:53AM
+481
+05/26
+10:54AM
+482
+05/26
+10:55AM
+483
+05/26
+10: 56AM
+484
+05/26
+10:57AM
+485
+05/26
+10:58AM
+486
+05/26
+11: 02AM
+487
+05/26
+11: 05AM
+488
+05/26
+11: 20AM
+05/26
+11:37AM
+490
+491
+492
+493
+494
+495
+05/26
+12:55PM
+05/26
+01: 05PM
+05/26
+01:15PM
+05/26
+01:16PM
+05/26
+01:52PM
+05/26
+02:15PM
+DST X280-9900 (10/03)
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+W PALM EL
+I PALM FL
+W PALM FI
+INCOMI CL
+INCOMI CI
+TAMPA
+FL
+INCOMI CL
+INCOMI CL
+INCOMI
+CL
+INCOMI
+CL
+" PALM
+EL
+" PALM
+FL
+INCOMI
+CL
+" PALM FL
+" PALM FL
+W PALM FL
+W PALM FL
+W PALM
+FL
+W PALM EL
+W PALM EL
+W PALM EL
+" PALM FL
+W PALM FI
+W PALM FI
+PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+MIAMI,
+FI
+INCOMI CL
+W PALM FL
+INCOMI CL
+MIAMI, FL
+Min Code
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+P
+RSD1
+RSD1
+P
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+IR
+IR
+IM
+IN
+IN
+IN
+W
+IN
+IW
+IN
+M
+M
+M
+M
+M
+I
+Total
+Charge
+. 00
+.00
+.00
+
+
+Billing Cycle Date:
+Account Number:
+17 of 37
+05/5/05-06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+1=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount; P=Priority Access Service; Q= -VPN; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+496
+05/26
+02:24PM
+497
+05/26
+02:24PM
+498
+05/26
+02: 46PM
+499
+05/26
+02:57PM
+500
+05/26
+02: 59PM
+501
+05/26
+03:01PM
+502
+05/26
+03:02PM
+503
+05/26
+03:04PM
+504
+05/26
+03:08PM
+505
+05/26
+04:20PM
+506
+05/26
+04:37PM
+507
+05/26
+05: 45PM
+508
+05/26
+06:44PM
+509
+05/26
+06: 45PM
+510
+05/26
+07: 31PM
+511
+05/26
+07: :33PM
+512
+05/26
+07:35PM
+513
+05/26
+07: 36PM
+514
+05/26
+09:47PM
+515
+05/26
+09: 50PM
+516
+05/26
+10:27PM
+517
+Fri
+05/27
+12: 31AM
+518
+05/27
+01:06PM
+519
+05/27
+01:28PM
+520
+05/27
+01:53PM
+521
+05/27
+01: 55PM
+522
+05/27
+01:59PM
+523
+05/27
+02:00PM
+524
+05/27
+02: 02PM
+525
+05/27
+02: 03PM
+526
+05/27
+02: 04PM
+527
+05/27
+02: 06PM
+528
+05/27
+02: 08PM
+529
+05/27
+02:16PM
+530
+05/27
+03:08PM
+531
+05/27
+03:11PM
+532
+05/27
+03:15PM
+533
+05/27
+03:28PM
+534
+05/27
+03:29PM
+535
+05/27
+03: 58PM
+536
+05/27
+03:58PM
+537
+05/27
+03:59PM
+538
+05/27
+03:59PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+INCOMI
+CL
+MIAMI,
+FL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM
+FL
+W PALM EL
+W PALM EL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FI
+INCOMI
+CL
+VOICE
+CL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI CL
+VOICE
+CL
+INCOMI CL
+Min Rade Rate Fure Alaine
+ture
+RSD1
+P
+RSD1
+M
+IN
+RSD1
+RSD1
+RSD1
+I
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+I
+IN
+IN
+M
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+RSD1
+M
+RSD1
+RSD1
+P
+P
+M
+RSD1
+RSD1
+M
+RSD1
+RSD1
+P
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+ICH
+RSD1
+RSD1
+RSD1
+P
+M
+IM
+. 00
+. 00
+1.00
+
+
+Billing Cycle Date:
+Account Number:
+18 of 37
+05/15/05 - 06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Eloni Call a Cal. MeTal Wile Dion: Car Ales die: - bila abile le
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+539
+05/27
+540
+05/27
+541
+05/27
+542
+05/27
+543
+05/27
+544
+05/27
+545
+05/27
+546
+05/27
+547
+05/27
+548
+05/27
+549
+05/27
+550
+05/27
+551
+05/27
+552
+05/27
+553
+05/27
+554
+05/27
+555
+05/27
+556
+05/27
+557
+05/27
+558
+05/27
+559
+05/27
+560
+05/27
+561
+05/27
+562
+05/27
+563
+05/27
+564
+05/27
+565
+05/27
+566
+05/27
+567
+05/27
+568
+05/27
+569
+05/27
+570
+05/27
+571
+05/27
+572
+05/27
+573
+05/27
+574
+05/27
+575
+05/27
+576
+05/27
+577
+05/27
+578
+05/27
+579
+05/27
+580
+05/27
+581
+05/27
+DST X280-9900 (10/03)
+Time
+04:12PM
+04:22PM
+04:30PM
+04: 34PM
+05: :22PM
+06:03PM
+06:30PM
+07:25PM
+07:43PM
+08:23PM
+08:54PM
+08:57PM
+08:59PM
+09:00PM
+09:31PM
+09: 31PM
+09:32PM
+09: 32PM
+09:33PM
+09:33PM
+09:33PM
+09:34PM
+09: 34PM
+09:35PM
+09: 36PM
+09: 37PM
+09: 37PM
+09:38PM
+09:39PM
+09:40PM
+09:40PM
+09: 41PM
+09: 41PM
+09:42PM
+09:43PM
+09:43PM
+09:43PM
+09:43PM
+09:44PM
+09: 45PM
+09: 47PM
+09:50PM
+09: 53PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+PALM FL
+PALM FL
+W PALM FL
+VOICE
+CL
+VOICE
+CL
+W PALM FL
+VOICE
+CL
+INCOMI
+CL
+W PALM FI
+W PALM EL
+W PALM FL
+W PALM FL
+W PALM FI
+W PALM FI
+VOICE
+CL
+VOICE
+CL
+W PALM EL
+INCOMI
+CL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+Min Rade Rate Fure Alaine
+1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+M
+IM
+IM
+RSD1
+RSD1
+RSD1
+M
+IM
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+N
+RSD1
+RSD1
+N
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+= z z
+= z z
+bA
+Total
+Charg
+. 00
+.00
+.00
+
+
+Billing Cycle Date:
+Account Number
+19 of 37
+05/15/05 - 06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa, VB=Vero Beach, NA=Naples,
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+1=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount; P=Priority Access Service; Q= -VPN; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+582
+05/27
+09:54PM
+583
+05/27
+09:54PM
+584
+05/27
+09:54PM
+585
+05/27
+09: 55PM
+586
+05/27
+10:23PM
+587
+05/27
+10:35PM
+588
+05/27
+10:44PM
+589
+05/27
+11:12PM
+590
+05/27
+11:51PM
+591
+Sat
+05/28
+12: 46AM
+592
+05/28
+12: 53AM
+593
+05/28
+01: 00AM
+594
+05/28
+01:03AM
+595
+05/28
+02: 06AM
+596
+05/28
+02: 24AM
+597
+05/28
+03: 07AM
+598
+05/28
+03:54AM
+599
+05/28
+04:18AM
+600
+05/28
+04: 43AM
+601
+05/28
+04: 47AM
+602
+05/28
+04: 53AM
+603
+05/28
+05: 01AM
+604
+05/28
+05: 06AM
+605
+05/28
+05: 57AM
+606
+05/28
+06:00AM
+607
+05/28
+06: 04AM
+608
+05/28
+06: 05AM
+609
+05/28
+06:10AM
+610
+05/28
+08: 42AM
+611
+05/28
+12: 30PM
+612
+05/28
+01:28PM
+613
+05/28
+01:36PM
+614
+05/28
+01:40PM
+615
+05/28
+03:07PM
+616
+05/28
+03:49PM
+617
+05/28
+04: 01PM
+05/28
+04:10PM
+619
+620
+621
+622
+623
+624
+05/28
+05:25PM
+05/28
+05:27PM
+05/28
+05: :35PM
+05/28
+05: 41PM
+05/28
+05: 50PM
+05/28
+05: 54PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+HI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+VOICE
+CL
+VOICE
+CL
+VOICE
+CL
+W PALM FL
+INCOMI
+CL
+" PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+MIAMI,
+FL
+" PALM FI
+W PALM FL
+INCOMI CL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+INCOMI CL
+INCOMI
+CL
+VOICE
+CL
+INCOMI
+CL
+PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+" PALM FL
+W PALM FL
+INCOMI CL
+W PALM
+FL
+N PALM EL
+W PALM EL
+W PALM FL
+" PALM FL
+W PALM FI
+W PALM FI
+INCOMI
+CL
+PALM
+FL
+INCOMI
+CL
+FL
+INCOMI
+CI
+INCOMI
+CL
+INCOMI
+• CL
+INCOMI CL
+W PALM FI
+Min Rade Rate Fire Alaine
+ture
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IW
+RSD1
+RSD1
+RSD1
+IN
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+N
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+W
+IN
+IW
+W
+IW
+RSD1
+RSD1
+RSD1
+IN
+IW
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+N
+RSD1
+IW
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+2zzz
+IW
+IN
+bA
+.00
+1.00
+.00
+.00
+2.00
+
+
+20 of 37
+05/15/05 - 06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Eloni Call a Cal. MeTal Wile Dion: Car Ales die: - bila abile le
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+625
+05/28
+626
+05/28
+627
+05/28
+628
+05/28
+629
+05/28
+630
+05/28
+631
+05/28
+632
+05/28
+633
+05/28
+634
+635
+636
+637
+638
+639
+640
+641
+642
+643
+644
+645
+646
+647
+648
+649
+650
+651
+652
+653
+654
+655
+656
+657
+658
+659
+Sun
+660
+661
+662
+663
+664
+665
+666
+667
+Time
+06: 04PM
+06: 05PM
+06:06PM
+06: 08PM
+06:16PM
+06:33PM
+06:36PM
+07:26PM
+07:32PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+VOICE
+CL
+A PALM FL
+* PALM FL
+* PALM FL
+INCOMI
+CL
+* PALM
+FL
+INCOMI
+CL
+* PALM FL
+PALM FL
+PALM FL
+* PALM FL
+* PALM FL
+INCOMI
+CL
+INCOMI
+CL
+A PALM
+FL
+* PALM FL
+A PALM FL
+INCOMI
+CL
+A PALM FL
+INCOMI
+CL
+* PALM
+FL
+A PALM
+FL
+PALM
+FL
+INCOMI
+CL
+* PALM FL
+A PALM FL
+A PALM
+FL
+A PALM
+FL
+VOICE
+CL
+INCOMI
+CL
+A PALM FL
+PALM FL
+PALM FL
+PALM FI
+PALM
+FL
+PALM
+FL
+INCOMI
+CI
+INCOMI
+INCOMI
+CL
+A PALM
+EL
+INCOMI
+CL
+A PALM
+I FL
+INCOMI CL
+DST X280-9900 (10/03)
+Min Code
+Code Rad Fure Alrige
+ture
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+R8D1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+IW
+RSD1
+RSD1
+IW
+RSD1
+RSD1
+RSD1
+RSD1
+CH
+IW
+RSD1
+RSD1
+RSD1
+= g
+RSD1
+N
+N
+RSD1
+RSD1
+IW
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+N
+RSD1
+IRW
+W
+RSD1
+RSD1
+RSD1
+IN
+Total
+Charge
+. 00
+1.00
+.00
+
+
+Billing Cycle Date:
+Account Number:
+21 of 37
+05/15/05 - 06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa, VB=Vero Beach, NA=Naples,
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+1=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount; P=Priority Access Service; Q= -VPN; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+668
+05/29
+07:13PM
+669
+05/29
+07:14PM
+670
+05/29
+07:25PM
+671
+05/29
+07:27PM
+672
+05/29
+07: :31PM
+673
+05/29
+07:55PM
+674
+05/29
+08:40PM
+675
+05/29
+09:00PM
+676
+05/29
+09: 01PM
+677
+05/29
+09:03PM
+678
+05/29
+09: 38PM
+679
+05/29
+10:25PM
+680
+05/29
+10:28PM
+681
+Mon
+05/30
+09:46AM
+682
+05/30
+02: 01PM
+683
+05/30
+02: 02PM
+684
+05/30
+02:03PM
+685
+05/30
+02: 03PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+686
+05/30
+03: 48PM
+687
+05/30
+03:49PM
+688
+05/30
+03:56PM
+689
+05/30
+04: 03PM
+MI
+MI
+690
+05/30
+04:53PM
+691
+05/30
+05: 54PM
+692
+05/30
+06:22PM
+693
+05/30
+06: :47PM
+694
+05/30
+07:24PM
+695
+05/30
+07:38PM
+696
+05/30
+07: 44PM
+697
+05/30
+07:49PM
+698
+05/30
+09:35PM
+699
+05/30
+09:36PM
+700
+05/30
+09:44PM
+701
+05/30
+09:45PM
+702
+05/30
+11:27PM
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+703
+Tue
+05/31
+08: 52AM
+704
+05/31
+08: 59AM
+MI
+705
+05/31
+10: 42AM
+MI
+706
+05/31
+11:01AM
+707
+05/31
+MI
+11:02AM MI
+708
+05/31
+11:07AM MI
+709
+05/31
+11:08AM
+MI
+710
+05/31
+11:10AM
+MI
+Call To
+W PALM FL
+W PALM FL
+" PALM FL
+W PALM FL
+INCOMI CL
+INCOMI
+CL
+# PALM
+FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+NEW YO NY
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+MIAMI, FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+MIAMI,
+FL
+INCOMI
+CL
+INCOMI CL
+W PALM FL
+INCOMI CL
+INCOMI CL
+TAMPA
+FL
+INCOMI CL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FI
+INCOMI
+CL
+MIAMI,
+FL
+DA Call
+W PALM FL
+W PALM FL
+W PALM EL
+W PALM FL
+W PALM FL
+W PALM FL
+Min Rade Rate Fure Alaine
+ture
+1
+RSD1
+RSD1
+W
+RSD1
+RSD1
+RSD1
+RSD1
+IW
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IR
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IM
+M
+13
+RSD1
+P
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+W
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+B
+RSD1
+M
+M
+M
+M
+RSD1
+RSD1
+bA
+1.50
+Total
+Charge
+. 00
+1.50
+
+
+22 of 37
+05/15/05 - 0614/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Eloni Call a Cal. MeTal Wile Dion: Car Ales die: - bila abile le
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Item Day Date
+Time
+711
+05/31
+11:11AM
+712
+05/31
+11:14AM
+713
+05/31
+11:15AM
+714
+05/31
+11:18AM
+715
+05/31
+11: 22AM
+716
+05/31
+11: 41AM
+717
+05/31
+12:08PM
+718
+05/31
+12:10PM
+719
+05/31
+12: 31PM
+720
+05/31
+12:57PM
+721
+05/31
+12: 58PM
+722
+05/31
+12: 58PM
+723
+05/31
+01:04PM
+724
+05/31
+01:13PM
+725
+05/31
+01:14PM
+726
+05/31
+01:15PM
+727
+05/31
+01:37PM
+728
+05/31
+02: 34PM
+729
+05/31
+03: 05PM
+730
+05/31
+03: 26PM
+731
+05/31
+03:30PM
+732
+05/31
+03:44PM
+733
+05/31
+05: 13PM
+734
+05/31
+05:15PM
+735
+05/31
+05:17PM
+736
+05/31
+05: 27PM
+737
+05/31
+05:28PM
+738
+05/31
+07:46PM
+739
+05/31
+07:48PM
+740
+05/31
+07:59PM
+741
+05/31
+08:15PM
+742
+05/31
+08:16PM
+743
+05/31
+08:34PM
+744
+05/31
+09:50PM
+745
+05/31
+10:29PM
+746
+Wed
+06/01
+01: 01PM
+747
+06/01
+01:03PM
+748฿
+06/01
+06:34PM
+749
+06/01
+06 : 36PM
+750
+06/01
+07:11PM
+751
+06/01
+07:11PM
+752
+06/01
+08:25PM
+753
+06/01
+08: 32PM
+CL
+MI
+MI
+MI
+Called
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+W PALM FL
+" PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+W PALM FI
+W PALM FL
+W PALM FI
+INCOMI CL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+TAMPA
+FL
+TAMPA
+FL
+MIAMI,
+FL
+PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+TAMPA
+FL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+N PALM EL
+TAMPA
+FL
+W PALM FL
+I PALM FL
+INCOMI CL
+INCOMI
+CL
+INCOMI
+CL
+MIAMI,
+FL
+MIAMI,
+FL
+W PALM FI
+W PALM FL
+W PALM EL
+W PALM FL
+INCOMI CL
+W PALM FI
+Min Code Rade Fre Arie
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+M
+RSD1
+RSD1
+RSD1
+IC
+IC
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+M
+IN
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+R8D1
+RSD1
+RSD1
+RSD1
+RSD1
+IC
+RSD1
+DST X280-9900 (10/03)
+Total
+Charg
+.00
+2.00
+
+
+Billing Cycle Date:
+Account Number:
+05415/05 - 06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+561-324-7996
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date Time
+754
+755
+756
+757
+758฿
+759
+760
+761
+762
+763
+764
+765
+766
+767
+768
+769
+770
+771
+772
+773
+774
+775
+776
+777
+778
+779
+780
+781
+782
+783
+784
+785
+786
+797
+788
+789
+790
+791
+792
+793
+794
+795
+796
+06/01
+08: 32PM
+06/01
+08:36PM
+06/01
+08:36PM
+06/01
+08: 38PM
+06/01
+08: :38PM
+06/01
+08:50PM
+06/01
+08:55PM
+06/01
+08: 56PM
+06/01
+09:13PM
+06/01
+09:34PM
+06/01
+09: 39PM
+06/01
+09: 46PM
+06/01
+10:13PM
+06/01
+10: 26PM
+06/01
+11: 46PM
+06/01
+11:47PM
+Thu
+06/02
+09: 51AM
+06/02
+12: 29PM
+06/02
+12: 54PM
+06/02
+12: 58PM
+06/02
+01:02PM
+06/02
+01: 02PM
+06/02
+01:04PM
+06/02
+01:53PM
+06/02
+02:04PM
+06/02
+02: 05PM
+06/02
+02: 09PM
+06/02
+03:51PM
+06/02
+03:52PM
+06/02
+03:59PM
+06/02
+05: 02PM
+06/02
+05: 10PM
+06/02
+05: :57PM
+06/02
+06: 00PM
+06/02
+06: 03PM
+06/02
+06:19PM
+06/02
+06:19PM
+06/02
+06:25PM
+06/02
+06: 33PM
+06/02
+07:19PM
+06/02
+08:07PM
+06/02
+08:11PM
+06/02
+08:11PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+361-371-8284
+Call To
+PALM FL
+PALM FL
+NCOMI CL
+PALM FL
+PALM FL
+PICE
+CL
+PALM
+FL
+PALM FL
+ACOMI
+CL
+NCOMI CL
+PALM FI
+NCOMI CL
+PALM FL
+NOMI CL
+PALM FL
+NCOMI
+CL
+PALM FL
+ERRIN FL
+SCOMI
+CL
+DRAL
+FL
+PALM
+FL
+PALM FL
+DICE
+CL
+NOMI CL
+PALM FL
+PALM FL
+PALM FL
+DPITE FL
+ACOMI
+CL
+UPITE EL
+PALM FL
+UPITE FL
+PALM FL
+NCOMI CL
+NCOMI
+CL
+NOMI CI
+NCOMI CI
+NCOMI CL
+COMI CL
+PALM FL
+NCOMI CI
+PALM FL
+W PALM FL
+Min Rade Rate Fire Alaine
+ture
+RSD1
+M
+RSD1
+RSD1
+IM
+RSD1
+RSD1
+RSD1
+M
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+R8D1
+IN
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+M
+RSD1
+RSD1
+RSD1
+M
+M
+RSD1
+RSD1
+RSD1
+P
+P
+P
+RSD1
+RSD1
+RSD1
+P
+P
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+B
+IC
+IN
+IN
+IN
+M
+RSD1
+RSD1
+RSD1
+M
+Total
+Charg
+. 00
+.00
+.00
+
+
+Billing Cycle Date:
+Account Number:
+24 of 37
+05/15/05 - 06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+eature: B=Direct Asst Call Complete; C=Call Waiting: D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Call
+-Incoming Call; K=Fax Call: M=Mobile To Mobile Discount; P=Priority Access Service; Q= -VPN; R=Roam with Hom
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+797
+06/02
+798
+06/02
+799
+06/02
+800
+06/02
+801
+06/02
+802
+06/02
+803
+06/02
+804
+06/02
+805
+06/02
+806
+06/02
+807
+Fri
+06/03
+808
+06/03
+809
+06/03
+810
+06/03
+811
+06/03
+812
+06/03
+813
+06/03
+814
+06/03
+815
+06/03
+06/03
+817
+818
+819
+820
+821
+822
+823
+824
+06/03
+06/03
+06/03
+06/03
+06/03
+06/03
+06/03
+06/03
+06/03
+826
+827
+828
+829
+830
+831
+832
+833
+834
+835
+836
+837
+838
+839
+06/03
+06/03
+06/03
+06/03
+06/03
+06/03
+06/03
+06/03
+06/03
+06/03
+06/03
+06/03
+06/03
+06/03
+DST X280-9900 (10/03)
+Time
+08:11PM
+08:13PM
+08:13PM
+08:15PM
+08:17PM
+08:23PM
+09:31PM
+09:32PM
+09: 57PM
+09:57PM
+03:23PM
+03: 25PM
+03:33PM
+03:41PM
+03: 43PM
+04: 00PM
+04:02PM
+04: 04PM
+04:09PM
+04:26PM
+04:34PM
+04:34PM
+04: 48PM
+04:52PM
+05: 03PM
+05: :22PM
+05: 32PM
+05:53PM
+05: 55PM
+06:15PM
+07:30PM
+07:31PM
+07:39PM
+08:10PM
+08:55PM
+09:09PM
+09:11PM
+09:11PM
+09:14PM
+09: 16PM
+09:22PM
+09:24PM
+09:26PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+HI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM EL
+W PALM FL
+" PALM FL
+JUPITE FL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+PALM FL
+W PALM FL
+W PALM FL
+W PALM EL
+INCOMI CL
+INCOMI CL
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+" PALM FL
+W PALM FL
+INCOMI
+CL
+JUPITE
+FL
+PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+INCOMI CL
+INCOMI
+CL
+W PALM EL
+INCOMI CL
+W PALM FL
+W PALM FI
+INCOMI CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+INCOMI CL
+INCOMI CL
+N PALM FL
+W PALM FL
+Min Rade Rate Fure Alaine
+ture
+RSD1
+P
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IM
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+I
+IM
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+M
+M
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+I
+IN
+IM
+M
+IN
+RSD1
+RSD1
+P
+P
+RSD1
+M
+IN
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+"zzz
+IN
+bA
+Total
+Charge
+. 00
+. 00
+.00
+1.00
+
+
+25 of 37
+05/15/05 - 06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+1=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount; P=Priority Access Service; Q= -VPN; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+840
+06/03
+10:10PM
+841
+06/03
+10:17PM
+842
+06/03
+10:24PM
+843
+06/03
+11:03PM
+844
+06/03
+11: 05PM
+845
+06/03
+11:10PM
+846
+06/03
+11:14PM
+847
+06/03
+11:15PM
+848
+06/03
+11:22PM
+849
+06/03
+11:26PM
+850
+Sat
+06/04
+12: 01AM
+851
+06/04
+12: 42AM
+852
+06/04
+12: 45AM
+853
+06/04
+12:47AM
+854
+06/04
+11: 04AM
+06/04
+01:08PM
+856
+857
+858
+859
+860
+861
+06/04
+01:25PM
+06/04
+01:35PM
+06/04
+01:37PM
+06/04
+01:49PM
+06/04
+01:50PM
+06/04
+01: 51PM
+06/04
+02: 35PM
+863
+864
+865
+866
+867
+868
+869
+870
+871
+872
+06/04
+02: 42PM
+06/04
+03: 02PM
+06/04
+03:20PM
+06/04
+03: 21PM
+06/04
+03:23PM
+06/04
+03:26PM
+06/04
+03:29PM
+06/04
+03:30PM
+06/04
+03:32PM
+06/04
+03:34PM
+06/04
+03:34PM
+874
+875
+876
+877
+878
+879
+880
+881
+882
+06/04
+03:42PM
+06/04
+04:13PM
+06/04
+04:39PM
+06/04
+08: 40PM
+06/04
+08:41PM
+06/04
+08: 43PM
+06/04
+08: 49PM
+06/04
+09:56PM
+06/04
+10:04PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+MIAMI,
+FL
+INCOMI
+CL
+MIAMI,
+FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM
+FL
+INCOMI
+CL
+" PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM
+FL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PALM FI
+W PALM FL
+INCOMI
+CL
+W PALM FL
+PALM FI
+W PALM FL
+W PALM FL
+W PALM EL
+W PALM FL
+INCOMI CL
+W PALM FI
+Min Code Rade Fure Alrige
+ture
+1
+RSD1
+N
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+IRM
+RSD1
+RSD1
+IRW
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+R8D1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+N
+N
+N
+N
+N
+zzzz
+IRW
+CH
+CH
+IN
+IN
+ICW
+IN
+IN
+IW
+IW
+. 00
+1.00
+1.00
+.00
+
+
+X
+Billing Cycle Date:
+Account Number:
+26 of 37
+05/15/05 - 06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+eature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Call
+LIncoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; Q- -VPN; R=Roam with Hom
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+ture
+Item Day Date
+Time
+883
+06/04
+11:11PM
+884
+Sun
+06/05
+12: 44AM
+885
+06/05
+02: 44AM
+886
+06/05
+11: 51AM
+887
+06/05
+12: 09PM
+888
+06/05
+02:18PM
+889
+06/05
+04:03PM
+06/05
+04: 05PM
+891
+892
+893
+894
+895
+896
+897
+898
+899
+900
+901
+902
+903
+904
+905
+906
+907
+908
+909
+910
+911
+912
+913
+914
+915
+916
+917
+918
+919
+920
+921
+922
+923
+924
+925
+06/05
+04:05PM
+06/05
+04:49PM
+06/05
+06:22PM
+06/05
+06:23PM
+06/05
+06:28PM
+06/05
+06: 36PM
+06/05
+06: :42PM
+06/05
+07: 06PM
+06/05
+07:09PM
+06/05
+07:37PM
+06/05
+07:39PM
+06/05
+07:40PM
+06/05
+07:42PM
+06/05
+07:44PM
+06/05
+07:46PM
+06/05
+07:47PM
+06/05
+07:47PM
+06/05
+07:48PM
+06/05
+07: 51PM
+06/05
+08:10PM
+06/05
+08:24PM
+06/05
+08:25PM
+06/05
+08:26PM
+06/05
+08:34PM
+06/05
+08: :46PM
+06/05
+08: 59PM
+06/05
+09:22PM
+06/05
+09:30PM
+06/05
+09:31PM
+06/05
+09:34PM
+06/05
+09: 42PM
+06/05
+09:44PM
+06/05
+11:32PM
+06/05
+11:33PM
+06/05
+11:59PM
+DST X280-9900 (10/03)
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+HI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+INCOMI
+CL
+" PALM
+FL
+INCOMI
+CL
+W PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM EL
+W PALM FL
+INCOMI CL
+NEW YO NY
+W PALM FL
+W PALM FL
+INCOMI CL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PALM
+FL
+INCOMI
+CL
+W PALM FL
+" PALM FL
+" PALM FL
+W PALM FI
+W PALM FL
+W PALM
+FL
+VOICE
+CL
+W PALM FL
+W PALM FL
+VOICE
+CL
+W PALM FI
+W PALM FL
+W PALM
+FL
+PALM
+FL
+BOYTON
+EL
+W PALM
+FL
+W PALM FL
+W PALN
+F1
+W PALM FL
+INCOMI CL
+INCOMI CL
+Min Code
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+RSD1
+RSD1
+N
+RSD1
+RSD1
+N
+RSD1
+RSD1
+RSD1
+RSD1
+R8D1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+IN
+IN
+IN
+IN
+W
+IN
+IW
+IN
+N
+bA
+Total
+Charge
+.00
+.00
+2.00
+
+
+Billing Cycle Date:
+Account Number:
+27 of 37
+05/15/05 - 06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+1=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount; P=Priority Access Service; Q= -VPN; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+926
+Mon
+06/06
+12:14AM
+927
+06/06
+12: 40PM
+928
+06/06
+12:41PM
+929
+06/06
+01: 02PM
+930
+06/06
+01:28PM
+931
+06/06
+01:29PM
+932
+06/06
+01:30PM
+933
+06/06
+01:31PM
+934
+06/06
+02:17PM
+935
+06/06
+02:22PM
+936
+06/06
+02:24PM
+937
+06/06
+02: 32PM
+938
+06/06
+02:44PM
+939
+06/06
+02: 47PM
+940
+06/06
+03: 03PM
+941
+06/06
+03:03PM
+942
+06/06
+03:04PM
+943
+06/06
+03: 05PM
+944
+06/06
+03:06PM
+945
+06/06
+03: 44PM
+946
+06/06
+04:09PM
+947
+06/06
+04:10PM
+948
+06/06
+04:16PM
+949
+06/06
+04:37PM
+950
+06/06
+04:37PM
+951
+06/06
+04: :38PM
+952
+06/06
+04:40PM
+953
+06/06
+04:42PM
+954
+06/06
+05:28PM
+955
+06/06
+05:48PM
+956
+06/06
+05: 50PM
+957
+06/06
+06: 23PM
+958
+06/06
+06:25PM
+959
+06/06
+06:37PM
+960
+06/06
+06:51PM
+961
+06/06
+07:15PM
+962
+06/06
+07:20PM
+963
+06/06
+07:20PM
+964
+06/06
+07:21PM
+965
+06/06
+07:21PM
+966
+06/06
+07:21PM
+967
+06/06
+07:23PM
+968
+06/06
+07:29PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM EL
+W PALM FL
+" PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+PALM FL
+INCOMI
+CL
+W PALM FL
+INCOMI CL
+W PALM FL
+INCOMI CL
+" PALM FL
+W PALM FL
+DA Call
+INCOMI CL
+W PALM FL
+DA Call
+W PALM FL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+" PALM FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM EL
+W PALM EL
+W PALM FL
+INCOMI CL
+W PALM FI
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FI
+W PALM FL
+W PALM FL
+W PALM EL
+W PALM FL
+W PALM FL
+INCOMI CL
+Min Code
+Code Rade Fre Aharge
+ture
+RSD1
+RSD1
+RSD1
+RSD1
+M
+M
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+IM
+M
+IN
+RSD1
+16
+RSD1
+M
+RSD1
+RSD1
+IM
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+ICM
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+M
+RSD1
+M
+RSD1
+RSD1
+P
+RSD1
+RSD1
+IC
+IM
+M
+RSD1
+RSD1
+RSD1
+M
+RSD1
+RSD1
+M
+RSD1
+P
+1.50
+1.50
+Total
+Charg
+. 00
+.00
+1.50
+1.50
+
+
+28 of 37
+Billing Cycle Date:
+05/15/05 - 06/14/05
+Account Number:
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+eature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Call
+=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; Q--VPN; R=Roam with Honv
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+CL
+Called
+Item Day Date
+969
+06/06
+970
+06/06
+971
+06/06
+972
+06/06
+973
+06/06
+974
+06/06
+975
+06/06
+976
+06/06
+977
+06/06
+978
+06/06
+979
+06/06
+980
+06/06
+981
+06/06
+982
+Tue
+06/07
+983
+06/07
+984
+06/07
+985
+06/07
+986
+06/07
+987
+06/07
+988
+06/07
+989
+06/07
+990
+06/07
+991
+06/07
+992
+06/07
+993
+06/07
+994
+Hed
+06/08
+995
+06/08
+996
+06/08
+997
+06/08
+998
+06/08
+999
+06/08
+1000
+06/08
+1001
+06/08
+1002
+06/08
+1003
+06/08
+1004
+06/08
+1005
+06/08
+2006
+06/08
+1007
+06/08
+L008
+06/08
+2009
+06/08
+1010
+06/08
+1011
+06/08
+DST X280-9900 (10/03)
+Time
+07:34PM
+07:35PM
+07:37PM
+07:45PM
+08:27PM
+08:34PM
+08:37PM
+08:41PM
+08:44PM
+08:48PM
+09:54PM
+10:07PM
+11:37PM
+12:10AM
+12:10AM
+12:12AM
+12:13AM
+12:17AM
+12:17AM
+12: 36PM
+12:36PM
+12:37PM
+12: 40PM
+05:03PM
+05:13PM
+03: 23PM
+03:31PM
+03:32PM
+03: 44PM
+04: 04PM
+04:11PM
+04: 52PM
+05:11PM
+05: 16PM
+05: 22PM
+05: 24PM
+05:28PM
+05: 48PM
+06: 07PM
+06: 25PM
+06: 32PM
+06:39PM
+06: 55PM
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+INCOMI CL
+MIAMI, FL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+N PALM FL
+W PALM EL
+W PALM FL
+INCOMI CL
+W PALM FL
+INCOMI CL
+W PALM FL
+INCOMI CL
+I PALM FL
+INCOMI CL
+W PALM FL
+VOICE
+CL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+INCOMI CL
+N PALM EL
+DELRAY FL
+INCOMI
+CL
+INCOMI
+: CL
+W PALM FL
+W PALM FL
+PALM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+INCOMI
+CL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI CL
+Min Rade Rade Fure Alrime
+ture
+RSD1
+P
+IR
+RSD1
+IR
+RSD1
+R
+RSD1
+RSD1
+M
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+ICH
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+CH
+IN
+M
+RSD1
+RSD1
+RSD1
+M
+M
+RSD1
+RSD1
+IM
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+RSD1
+M
+M
+IM
+RSD1
+RSD1
+RSD1
+P
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+M
+RSD1
+RSD1
+IM
+Total
+Charge
+. 00
+.00
+.00
+.00
+
+
+Billing Cycle Date:
+Account Number:
+29 of 37
+05415105-06/14105
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+1=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount; P=Priority Access Service; Q= -VPN; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Min Code Rade Forge
+ture
+Item Day Date
+Time
+2012
+06/08
+07:13PM
+1013
+06/08
+07:29PM
+1014
+06/08
+07:30PM
+1015
+06/08
+07: :31PM
+1016
+06/08
+07:36PM
+1017
+06/08
+07: 38PM
+1018
+06/08
+07:39PM
+1019
+06/08
+07: 51PM
+1020
+06/08
+07:52PM
+1021
+06/08
+09:17PM
+L022
+06/08
+09: 42PM
+1023
+06/08
+10: 08PM
+1024
+06/08
+11:08PM
+1025
+06/08
+11:16PM
+1026
+06/08
+11:26PM
+1027
+06/08
+11:48PM
+1028
+Thu
+06/09
+01:11AM
+1029
+06/09
+12:27PM
+1030
+06/09
+02: :32PM
+1031
+06/09
+03:14PM
+1032
+06/09
+03:15PM
+1033
+06/09
+03:15PM
+1034
+06/09
+03:18PM
+2035
+06/09
+03:31PM
+2036
+06/09
+03:33PM
+1037
+06/09
+03: 36PM
+1038
+06/09
+04: 05PM
+1039
+06/09
+04:28PM
+1040
+06/09
+04:29PM
+2041
+06/09
+05: 47PM
+1042
+06/09
+06:12PM
+1043
+06/09
+06: 58PM
+1044
+06/09
+06:58PM
+1045
+06/09
+07: 00PM
+1046
+06/09
+07:04PM
+1047
+06/09
+07: 05PM
+4048
+06/09
+07:07PM
+1049
+06/09
+07:34PM
+1050
+06/09
+08: 01PM
+1051
+06/09
+08: :15PM
+1052
+06/09
+08:22PM
+2053
+06/09
+08:23PM
+1054
+06/09
+09:00PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+PERRIN FL
+" PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+JUPITE FI
+W PALM FI
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+" PALM FL
+INCOMI
+CL
+INCOMI CL
+INCOMI
+CL
+W PALM EL
+INCOMI CL
+INCOMI CL
+" PALM FL
+W PALM FL
+" PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+JUPITE FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+INCOMI CL
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+R8D1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+R8D1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+P
+M
+M
+IM
+IN
+IN
+M
+IN
+IM
+IN
+M
+IN
+IC
+IN
+M
+M
+I
+MI
+bA
+. 00
+. 00
+.00
+
+
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+1055
+06/09
+2056
+Fri
+06/10
+2057
+06/10
+1058
+06/10
+1059
+06/10
+1060
+06/10
+1061
+06/10
+1062
+06/10
+1063
+06/10
+1064
+06/10
+LO65
+06/10
+1066
+06/10
+1067
+06/10
+1068
+06/10
+1069
+06/10
+1070
+06/10
+1071
+06/10
+1072
+06/10
+1073
+06/10
+1074
+06/10
+1075
+06/10
+1076
+06/10
+1077
+06/10
+2078
+06/10
+1079
+06/10
+Дово
+06/10
+1081
+06/10
+1082
+06/10
+1083
+06/10
+2084
+06/10
+1085
+06/10
+1086
+06/10
+1087
+06/10
+1088
+06/10
+1089
+06/10
+1090
+06/10
+1091
+06/10
+1092
+06/10
+1093
+06/10
+1094
+06/10
+1095
+06/10
+2096
+06/10
+2097
+06/10
+DST X280-9900 (10/03)
+Time
+09:21PM
+03:21PM
+03:22PM
+03:24PM
+03:26PM
+04:05PM
+04:10PM
+04:47PM
+04:48PM
+04:50PM
+04: 50PM
+04: 52PM
+04:53PM
+05:02PM
+05: :02PM
+05: :05PM
+05:09PM
+05: 09PM
+05:10PM
+05:10PM
+05:11PM
+05:14PM
+05:28PM
+05: 57PM
+06: 01PM
+06: 21PM
+06: 40PM
+06: 43PM
+06: 44PM
+06: 55PM
+07: 00PM
+07:48PM
+07: 48PM
+07: 56PM
+07:57PM
+07:58PM
+08:02PM
+08:04PM
+08:13PM
+08:14PM
+08:15PM
+08:16PM
+08:18PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+# PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM EL
+INCOMI CL
+INCOMI CL
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FI
+VOICE
+CL
+DA Call
+W PALM EL
+INCOMI CL
+W PALM FL
+W PALM EL
+INCOMI CL
+W PALM FL
+INCOMI CL
+Billing Cycle Date:
+Account Number:
+30 of 3
+05/15/05 - 06/14/0:
+561-324-7996
+Min Code
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+B
+RSD1
+RSD1
+B
+RSD1
+ture
+M
+M
+M
+M
+IC
+M
+M
+M
+M
+IM
+IN
+M
+ICM
+IM
+M
+M
+IN
+M
+I
+IN
+M
+IRM
+M
+M
+M
+M
+M
+IM
+M
+M
+IN
+M
+IM
+DA
+1.50
+Total
+Charg
+. 00
+.00
+1.00
+1.50
+
+
+Piling Cycle Date:
+Account Number:
+31 of 37
+05/15/05 - 06/14/0:
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+1=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount; P=Priority Access Service; Q= -VPN; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+1098
+06/10
+08:20PM
+1099
+06/10
+08:21PM
+2100
+06/10
+08:26PM
+1101
+06/10
+08:28PM
+1102
+06/10
+09:20PM
+1103
+06/10
+09:24PM
+2104
+06/10
+09:27PM
+2105
+06/10
+09:28PM
+1106
+06/10
+09:46PM
+2107
+06/10
+10:36PM
+2108
+06/10
+11:12PM
+1109
+Sat
+06/11
+12: 53AM
+2110
+06/11
+12: 55AM
+1111
+06/11
+12:56AM
+2112
+06/11
+03:16PM
+1113
+06/11
+03:19PM
+1114
+06/11
+03:21PM
+2115
+06/11
+03:24PM
+1116
+06/11
+03: 38PM
+1117
+06/11
+04:09PM
+0118
+06/11
+04:33PM
+1119
+06/11
+04:35PM
+1120
+06/11
+04:56PM
+0121
+06/11
+04:56PM
+1122
+06/11
+04:58PM
+1123
+06/11
+05: :01PM
+1124
+06/11
+05: 02PM
+0125
+06/11
+05:15PM
+1126
+06/11
+05:18PM
+1127
+06/11
+05: 55PM
+0128
+06/11
+06:29PM
+1129
+06/11
+07:35PM
+1130
+06/11
+07:40PM
+1131
+06/11
+08:35PM
+2132
+06/11
+08:35PM
+1133
+06/11
+08: 59PM
+1134
+06/11
+09:22PM
+2135
+06/11
+09:38PM
+2136
+06/11
+09:55PM
+1137
+06/11
+09:57PM
+1138
+06/11
+10:03PM
+2139
+06/11
+10:44PM
+1140
+06/11
+10:54PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+DA
+Call
+W PALM FL
+W PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI CL
+" PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM
+FL
+INCOMI
+CL
+MIAMI,
+FL
+MIAMI,
+FL
+MIAMI,
+FL
+MIAMI,
+FI
+MIAMI,
+FL
+W PALM
+FL
+INCOMI
+CL
+W PALM
+EL
+INCOMI CL
+INCOMI CL
+" PALM FL
+W PALM FI
+W PALM
+FL
+W PALM
+FL
+TAMPA
+W PALM FL
+MIAMI
+FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+INCOMI CL
+Min Code Rade Fure Alrige
+ture
+1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+N
+IN
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RED1
+N
+RSD1
+RSD1
+RSD1
+RSD1
+= z z
+IN
+IN
+1.50
+1.50
+.00
+1.00
+
+
+Billing Cycle Date:
+Account Number:
+32 of 37
+05/15/05 - 06/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Eloni Call a Cal. MeTal Wile Dion: Car Ales die: - bila abile le
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+ture
+Item Day Date
+Time
+P141
+06/11
+11:16PM
+2142
+Sun
+06/12
+02: 44AM
+2143
+06/12
+10:11AM
+1144
+06/12
+10:11AM
+1145
+06/12
+10:14AM
+2146
+06/12
+10:20AM
+2147
+06/12
+10: 22AM
+1148
+06/12
+10: 23AM
+1149
+06/12
+11:24AM
+2150
+06/12
+12:59PM
+1151
+06/12
+01: 03PM
+1152
+06/12
+01:04PM
+2153
+06/12
+01:09PM
+2154
+06/12
+01:09PM
+2155
+06/12
+01:16PM
+1156
+06/12
+01:46PM
+2157
+06/12
+01:46PM
+1158
+06/12
+01:47PM
+1159
+06/12
+01: :48PM
+1160
+06/12
+01:48PM
+1161
+06/12
+01:50PM
+1162
+06/12
+01: 52PM
+1163
+06/12
+01: 56PM
+2164
+06/12
+01:56PM
+1165
+06/12
+01:57PM
+2166
+06/12
+01:57PM
+1167
+06/12
+02: 00PM
+1168
+06/12
+02: 03PM
+1169
+06/12
+02:39PM
+1170
+06/12
+03:29PM
+2171
+06/12
+03:30PM
+1172
+06/12
+05: 39PM
+1173
+06/12
+06:04PM
+1174
+06/12
+06: 05PM
+2175
+06/12
+06:18PM
+1176
+06/12
+06:22PM
+1177
+06/12
+06:26PM
+2178
+06/12
+06:43PM
+1179
+06/12
+06: 44PM
+1180
+06/12
+07: 08PM
+1181
+06/12
+07:34PM
+1182
+06/12
+08:27PM
+1183
+06/12
+08:28PM
+DST X280-9900 (10/03)
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+INCOMI CL
+• PALM FL
+NEW YO NY
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+# PALM FL
+W
+PALM FL
+W PALM FL
+MIAMI,
+FL
+MIAMI,
+FL
+W PALM FI
+INCOMI CL
+INCOMI CL
+VOICE
+CL
+W PALM FL
+VOICE
+CL
+W PALM FL
+VOICE
+CL
+W PALM FL
+PALM FL
+PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+W PALM FI
+INCOMI CL
+MIAMI
+FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+" PALM FI
+INCOMI
+CL
+W PALM EL
+INCOMI CL
+INCOMI CL
+W PALM FI
+Min Code
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+RSD1
+RSD1
+RSD1
+RSD1
+N
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+zzzz
+IN
+IN
+CH
+IN
+IN
+IN
+IN
+IW
+IN
+IW
+IN
+W
+Total
+Charg
+. 00
+.00
+.00
+2.00
+
+
+Billing Cycle Date:
+Account Number:
+33 of 37
+natana natio
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa, VB=Vero Beach, NA=Naples,
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+1=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount; P=Priority Access Service; Q= -VPN; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Min Code Rade For Are
+Item Day Date Time
+1184
+2185
+2186
+2187
+1188
+1189
+2190
+1191
+1192
+2193
+1194
+1195
+2196
+2197
+198
+1199
+1200
+1201
+1202
+1203
+1204
+1205
+1206
+1207
+1208
+1209
+1210
+1211
+1212
+1213
+1214
+1215
+1216
+1217
+1218
+1219
+1220
+1221
+1222
+1223
+1224
+0225
+1226
+06/12
+08:28PM
+06/12
+08:29PM
+06/12
+08:31PM
+06/12
+08:35PM
+06/12
+08:49PM
+06/12
+08: 50PM
+06/12
+08:57PM
+06/12
+09:12PM
+06/12
+09:46PM
+06/12
+09:47PM
+06/12
+09: 55PM
+06/12
+10: 44PM
+06/12
+10:50PM
+06/12
+10: 52PM
+Mon
+06/13
+09: 47AM
+06/13
+09: 51AM
+06/13
+10: 55AM
+06/13
+10: 56AM
+06/13
+11: 41AM
+06/13
+11: 49AM
+06/13
+11:55AM
+06/13
+12:19PM
+06/13
+01:04PM
+06/13
+02:13PM
+06/13
+03: 02PM
+06/13
+03: 03PM
+06/13
+08:04PM
+06/13
+08: 05PM
+06/13
+08: 06PM
+06/13
+08:10PM
+06/13
+08:31PM
+06/13
+08: 35PM
+06/13
+09: 08PM
+06/13
+09:15PM
+06/13
+09:17PM
+06/13
+09:36PM
+06/13
+09:38PM
+06/13
+10:30PM
+06/13
+10:48PM
+06/13
+10: 58PM
+06/13
+11:08PM
+06/13
+11:15PM
+Tue
+06/14
+12:31AM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+W PALM FL
+" PALM FI
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+# PALM FL
+W PALM FL
+W PALM FL
+W PALM EL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+W PALM EL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM
+FL
+" PALM
+FL
+W PALM FL
+" PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM EL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+DA Call
+W PALM FI
+INCOMI
+CL
+DA Call
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM EL
+INCOMI CL
+MIAMI,
+FL
+INCOMI CL
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+P
+P
+IN
+IN
+M
+I
+IC
+M
+M
+M
+IM
+0.45
+W
+IN
+IN
+1.50
+1.50
+bA
+Charge
+. 00
+1.00
+1.00
+0.45
+1.50
+1.50
+
+
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+1227
+06/14
+11: 30AM
+1228
+06/14
+11: 32AM
+1229
+06/14
+11: 46AM
+1230
+06/14
+11: 48AM
+1231
+06/14
+11: :53AM
+1232
+06/14
+11: 56AM
+1233
+06/14
+12:04PM
+1234
+06/14
+12:18PM
+1235
+06/14
+12:19PM
+2236
+06/14
+12:21PM
+1237
+06/14
+12: 28PM
+1238
+06/14
+12:29PM
+1239
+06/14
+12:34PM
+1240
+06/14
+12:37PM
+1241
+06/14
+01:07PM
+1242
+06/14
+01:08PM
+1243
+06/14
+01:12PM
+1244
+06/14
+01:15PM
+1245
+06/14
+01:42PM
+1246
+06/14
+02:57PM
+1247
+06/14
+03:06PM
+1248
+06/14
+04:32PM
+1249
+06/14
+04:37PM
+1250
+06/14
+04:46PM
+1251
+06/14
+05: 03PM
+1252
+06/14
+05: :04PM
+1253
+06/14 05:27PM
+L254
+06/14 05:31PM
+1255
+06/14 05:44PM
+1256
+06/14
+07:14PM
+1257
+06/14
+07:18PM
+1258
+06/14
+07:23PM
+1259
+06/14
+07: 31PM
+1260
+06/14
+07:33PM
+1261
+06/14
+08: 05PM
+1262
+06/14
+08:06PM
+1263
+06/14
+11:59PM
+Totals
+2086
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+PERRIN EL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+" PALM FL
+W PALM FL
+PERRIN FL
+W PALM FL
+W PALM FL
+INCOMI CL
+BOYTON FL
+MIAMI,
+EL
+MIAMI, FL
+MIAMI, FL
+" PALM FL
+W PALM FL
+INCOMI
+CL
+" PALM
+FL
+INCOMI
+CL
+W PALM
+FL
+OXNARD
+CA
+N PALM FL
+W PALM FI
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+17.10 10.50
+27.60
+DST X280-9900 (10/03)
+Billing Cycle Date:
+Account Number:
+34 of 37
+05/15/05 - 06/14/05
+Min Code
+Code Rade Fure Alrige
+ture
+1
+RSD1
+0.45
+RSD1
+0.45
+RSD1
+0.45
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+0.45
+1.80
+0.45
+0.45
+0.45
+3.15
+RSD1
+M
+R8D1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+0.45
+1.35
+0.45
+0.45
+0.90
+0.45
+RSD1
+RSD1
+M
+M
+RSD1
+0.45
+RSD1
+RSD1
+RSD1
+2.25
+0.45
+RSD1
+M
+RSD1
+RSD1
+0.45
+0.45
+RSD1
+P
+RSD1
+IN
+IM
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+P
+M
+M
+M
+0.45
+RSD1
+M
+RSD1
+RSD1
+P
+M
+RSD1
+bA
+Total
+Charg
+0.45
+0.45
+0.45
+0.45
+1.80
+3.15
+0.45
+1.35
+0.45
+0.45
+0.90
+0.45
+0.45
+2.25
+0.45
+0.45
+0.45
+0.45
+
+
+Billing Cycle Date:
+Account Number:
+35 of 37
+05/15/05 - 06/14/05
+Roaming Call Detail
+User Name: MICHAEL DAVIS
+Rate Code: RSD1=/RGNP 600 UMM 5KNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+S=Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Fea- Airtime
+Item Day Date
+Time
+LD
+Called
+ture Charge Charg
+Charges Incurred While Roaming in Miami, FL --System ID #85029-A
+Intl
+Tax
+Total
+Charge
+Wireless Data Detail
+User Name: MICHAEL DAVIS
+Rate Code: RSD1=/RGNP 600 UMM 5KNW
+Rate Period (Pd.): P=Peak, O=Of Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls:
+1=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; O= -VPN; R=Roam with Home:
+S=Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Item
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+26
+27
+28
+29
+30
+31
+32
+33
+34
+Day
+Sun
+Tue
+Wed
+Fr1
+Sun
+Mon
+Tue
+Wed
+Date
+05/15
+05/17
+05/18
+05/18
+05/18
+05/18
+05/18
+05/20
+05/20
+05/20
+05/20
+05/20
+05/20
+05/20
+05/20
+05/20
+05/22
+05/22
+05/22
+05/22
+05/22
+05/22
+05/22
+05/22
+05/22
+05/23
+05/24
+05/24
+05/25
+05/25
+05/25
+05/25
+05/25
+05/25
+Time
+08:32PM
+12:34PM
+08: 03AM
+10: 50AM
+10: 52AM
+10:56AM
+10: 57AM
+08: 59AM
+09: 42AM
+09:42AM
+09:43AM
+09: 47AM
+09:47AM
+09:50AM
+09: 51AM
+09:59AM
+01:13AM
+01:14AM
+01:15AM
+01:17AM
+01:18AM
+01: 27AM
+02:13AM
+02: 26AM
+02: 30AM
+10:20PM
+07: 30AM
+10:09PM
+05:27PM
+07:22PM
+07:23PM
+07:43PM
+07: 46PM
+09:51PM
+To/From
+Type
+CINGULAR MOBILE
+CINGULAR MOBILE
+OTHER MOBILE TO
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR
+MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE
+TO
+OTHER MOBILE
+TO
+CINGULAR MOBILE
+OTHER MOBILE TO
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+Rate
+Msg/KB
+Code
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag RSD1
+1 Mag
+RSD1
+1 Mag RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag RSD1
+1 Mag RSD1
+1 Mag
+RSD1
+1 Mag RSD1
+1 Mag RSD1
+1 Mag RSD1
+1 Mag RSD1
+1 Mag RSD1
+1 Mag RSD1
+1 Mag RSD1
+1 Mag
+RSD1
+Rate
+Pd
+561-324-7996
+Fea-
+In/
+ture Out
+Out
+Out
+Out
+In
+Out
+In
+Out
+Out
+Out
+In
+Out
+In
+In
+Out
+In
+Out
+Out
+In
+In
+In
+In
+In
+Out
+In
+Out
+Out
+Out
+Total
+Charge
+.00
+0
+1.00
+.00
+.00
+
+
+X
+Billing Cycle Date:
+Account Number:
+36 of 37
+05/15/05 - 06/14/05
+Wireless Data Detail (Continued)
+User Name: MICHAEL DAVIS
+Felcoming Call Fa CaMbie To Mobile Discount, Priori Aces Service: - Role Will Home:
+S=Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Item Day
+35
+36
+37
+38
+Fri
+39
+40
+41
+42
+43
+44
+Sat
+Tue
+Wed
+45
+46
+47
+48
+Thu
+Sat
+49
+50
+Sun
+51
+52
+53
+Mon
+54
+55
+Tue
+56
+57
+58
+59
+Wed
+Thu
+60
+61
+62
+63
+64
+65
+66
+67
+68
+Sat
+69
+70
+71
+72
+73
+Mon
+74
+75
+76
+77
+78
+Tue
+Totals
+Date
+Time
+05/25
+09:52PM
+05/25
+09: 52PM
+05/27
+07:18PM
+05/27
+07:19PM
+05/27
+07: 192M
+05/27
+08:17PM
+05/27
+09:52PM
+05/28
+12:27PM
+05/31
+11: 02AM
+06/01
+07:49PM
+06/01
+08: 31PM
+06/01
+11:28PM
+06/02
+01: 43AM
+06/04
+03:42AM
+06/04
+04: 39AM
+06/05
+11:56PM
+06/05
+11:58PM
+06/05
+11:58PM
+06/06
+12:06PM
+06/06
+12:41PM
+06/07
+12:11PM
+06/07
+12:17PM
+06/07
+04:27PM
+06/08
+07:54PM
+06/09
+12:38PM
+06/09
+02:17PM
+06/09
+02:17PM
+06/09
+02:21PM
+06/09
+02:23PM
+06/09
+02:28PM
+06/09
+02:29PM
+06/09
+02: 31PM
+06/09
+06:03PM
+06/11
+03: 04AM
+06/11
+05: 02PM
+06/11
+08:33PM
+06/11
+09:36PM
+06/11
+10:36PM
+06/13
+08: 02PM
+06/13
+08:19PM
+06/13
+08:20PM
+06/13
+08:24PM
+06/13
+08: 31PM
+Subtotal ativisg's
+06/14
+05: 47PM
+Subtotal of taB's
+To/From
+Type
+CINGULAR MOBILE
+CINGULAR MOBILE
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+Message Center-
+CINGULAR MOBILE
+OTHER MOBILE
+TO
+OTHER MOBILE
+TO
+OTHER MOBILE
+TO
+OTHER MOBILE
+TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE
+TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+CINGULAR MOBILE
+CINGULAR
+OTHER MOBILE
+TO
+OTHER MOBILE
+TO
+CINGULAR
+MOBILE
+CINGULAR
+MOBILE
+CINGULAR
+MOBILE
+CINGULAR
+MOBILE
+CINGULAR MOBILE
+CINGULAR
+MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR
+MOBILE
+CINGULAR
+MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+Data Transfe wireless intern
+0.22
+0.22
+DST X280-9900 (10/03)
+Rate
+• Rate Fea- In/
+Msg/KB
+1 Mag
+Code
+RSD1
+Pd
+ture
+Out
+1 Mag
+In
+RSD1
+Out
+1 Mag RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+"~~-
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+22 KB RSD1
+P
+In
+Out
+Out
+Out
+Out
+In
+In
+In
+Out
+In
+In
+Out
+Total
+Charge
+_00
+0
+. 00
+.00
+. 00
+.00
+1.00
+.00
+0.22
+
+
+Billing Cycle Date:
+Account Number:
+37 of 37
+05/15/05 - 06/14/05
+¿ Desea recibir su cuenta en español?
+Llame al 611 y marque el 2 para hablar con una operadora en español.
+One Time Checking Account Payment Authorization Agreement (for use with kiosk payment):
+I authorize Cingular Wireless to pay my bill by debiting my bank account. I can cancel
+authorization by contacting an in-store sales person. If my bank rejects a payment,
+I may be charged a return fee.
+Looking for a great job? Check out Cingular!
+Great pay, excellent benefits, flexible hours, full and part time possible.
+Visit Cingular.com, click on Careers, and apply online. EOE AA/M/F/D/
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/2f38d808eb897ab31da0fb6fb2535567e9ab5b2b8e7ff14ff6e9fe4415bb44c2.receipt.json b/vision-fixhub/ds9-unparsed-06/2f38d808eb897ab31da0fb6fb2535567e9ab5b2b8e7ff14ff6e9fe4415bb44c2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6d7789838031b68ffc408df55934150ce61acc8c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2f38d808eb897ab31da0fb6fb2535567e9ab5b2b8e7ff14ff6e9fe4415bb44c2.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -7432,
+  "dataset": "marble-joined",
+  "doc_id": "2f38d808eb897ab31da0fb6fb2535567e9ab5b2b8e7ff14ff6e9fe4415bb44c2",
+  "engine": "marble-apple-vision",
+  "event_count": 39,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "8898d90f36b5f24de4705b3c0be24a0893e63d2dfe28069bb53d50523be6188c",
+  "output_sha256": "5eeabd1128f4e4e1d8acc25e32db689255939c135dd4821105c0c5b90bc3ec0e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2fa9762019141b9316a10fa851e25cdb34efb2c3aa51717a655b18b484bfbc8f.md b/vision-fixhub/ds9-unparsed-06/2fa9762019141b9316a10fa851e25cdb34efb2c3aa51717a655b18b484bfbc8f.md
new file mode 100644
index 0000000000000000000000000000000000000000..41bf535b3a9df8705015f5e49eec0f618ba75910
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2fa9762019141b9316a10fa851e25cdb34efb2c3aa51717a655b18b484bfbc8f.md
@@ -0,0 +1,52 @@
+From:
+To:
+Subject: Activity in Case 9:08-cv-80119-KAM Doe |. Epstein Response in Opposition to Motion
+Date: Wed, 31 Mar 2010 18:49:08 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. Distriet Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Pike, Michael on 3/31/2010 at 2:49 PM EDT and filed on 3/31/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 512
+Doe | Epstein
+9:08-cv-80119-KAM
+Jeffrey Epstein
+Docket Text:
+RESPONSE in Opposition re [489] Plaintiff's MOTION to Compel Production of Jane Doe Nos.
+2-7's Sworn Statements to FBI Investigators and Incorporated Memorandum of Law filed by
+Jeffrey Epstein. (Pike, Michael)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+Bradley James Edwards
+Isidro Manuel Garcia
+Jack Alan Goldberger
+Jack Patrick Hill
+Jeffrey Mare Herman
+Katherine Warthen Ezell
+
+
+Michael James Pike
+Paul G. Cassell
+Richard Horace Willits
+Robert C. Josefsberg
+Robert Deweese Critton, Jr
+Stuart S. Mermelstein
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:/a
+Electronic document Stamp:
+[STAMP dcecfStamp_ID=1105629215 [Date=3/31/2010] [FileNumber=7422643-0
+][6с07abdб7088е3d269dd4ес5b5f4fe16677db67cb200c213e0f115eefa81578d136
+c3е9d06167f31fa21aef3ad9a287fc327cf02fbbbe97a914e8737d2740598]]
diff --git a/vision-fixhub/ds9-unparsed-06/2fa9762019141b9316a10fa851e25cdb34efb2c3aa51717a655b18b484bfbc8f.receipt.json b/vision-fixhub/ds9-unparsed-06/2fa9762019141b9316a10fa851e25cdb34efb2c3aa51717a655b18b484bfbc8f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..61ff388224e3bfbfac10bc64868d2d7500da4abb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2fa9762019141b9316a10fa851e25cdb34efb2c3aa51717a655b18b484bfbc8f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "2fa9762019141b9316a10fa851e25cdb34efb2c3aa51717a655b18b484bfbc8f",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "0119ddf01e5c8b3f79a12ed80ccf129b63fe75ea6db5c55bf3cc5bbc4908dff8",
+  "output_sha256": "03b3c317666eed95011c6887fb53ad2d889e7ca63adb470284f3e9acd60ce115",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/2fcb971505f6b81185e9c9ce85189206835bff8dd17e0b75cc08ac3d3a7e13e5.md b/vision-fixhub/ds9-unparsed-06/2fcb971505f6b81185e9c9ce85189206835bff8dd17e0b75cc08ac3d3a7e13e5.md
new file mode 100644
index 0000000000000000000000000000000000000000..68f96cac456bbd878abe13b3edf5d9dd38a91a49
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2fcb971505f6b81185e9c9ce85189206835bff8dd17e0b75cc08ac3d3a7e13e5.md
@@ -0,0 +1,202 @@
+Case 9:08-cv-80811-KAM|
+
+C.M. A.,
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80811-MARRA/JOHNSON
+Plaintiff,
+JEFFREY EPSTEIN and
+Defendants,
+Defendant, Jeffrey Epstein's Reply to Plaintiff's Response In Opposition To Defendant's Motion To
+Stay And/Or Continue Action For Time Certain With Incorporated Memorandum Of Law
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his
+undersigned attorneys, hereby files his Reply to Plaintiff's Response In Opposition to
+Defendant's Motion to Stay and/or Continue Action (DE 64), and states:
+L.
+Introduction and Argument
+Plaintiff, in the instant matter, did not draft her own Response to the Motion to Stay.
+Instead, Plaintiff incorporated Plaintiffs' responses to the motion to stay in certain related matters
+(DE 64), and adopted those arguments as her own.'
+Plaintiff's Response in Opposition challenging the stay should not prevail when 5th
+Amendment principles are at issue and when there exists a real, substantial and not remote
+possibility that Epstein may face criminal prosecution by the United States Attorneys' Office
+("USAO") if the USAO unilaterally determines that Epstein somehow violated that certain Non-
+Prosecution Agreement dated June 30, 2008 ("NPA") and/or if Epstein is forced to waive those
+s* Amendment rights and participate in civil discovery in order to defend this civil action.
+Accordingly, Epstein adopts his arguments set forth in the Reply to Jane Doe's Response In Opposition
+filed in 08-CIV-80893 (DE 54) and incorporates same herein by reference.
+
+
+
+Page 2
+Epstein should not be confronted with the substantial risk of loosing this civil action by
+virtue of asserting his 5t Amendment privileges. Despite Plaintiff's contention, Epstein's
+Motion does not concentrate solely on the fact that the pleadings are not at the summary
+judgment stage. The motion also concentrates on Epstein's risk of loosing this entire civil action
+as a result of Epstein invoking his 5" Amendment rights. Severino v. Klytie's Developments,
+Inc., 2008 WL 1782637, *2 (D. Colo)(recognizing that a stay is appropriate under similar
+circumstances as in the instant case); see also infra.
+In fact, waiver of Epstein's 5'h Amendment privileges should not be compelled to defend
+this civil action (and could be remedied by a reasonable stay), especially when civil discovery
+may lead to the USAO unilaterally declaring a violation of the NPA.
+The USAO has already unilaterally claimed that EPSTEIN violated the NPA by, among
+other things, "investigating the Plaintiffs (by and though his attorneys) whom brought civil
+suits against him for purposes of defending those civil actions" and "by contesting damages in
+this action and in the other civil actions." See Motion to Stay and Jack Goldberger Affidavit
+attached thereto as Exhibit "B". Thus, these are not vague assertions as Plaintiff claims. How
+can Epstein truly defend these matters and be afforded his due process rights when to do so
+might result in the USAO claiming a breach of the NPA? The fact is that he cannot.
+Notwithstanding the allegations against Epstein, this Court has an obligation to ensure his due
+process rights are upheld in both the civil and criminal contexts.
+Next, in her response, Plaintiff claims that a stay should not be entered because a parallel
+criminal proceeding against Epstein does not exist. Not only is Plaintiff's theory incorrect for
+reasons set out herein and in the Epstein's Motion to Stay, but her response ignores the
+2
+
+
+Entered on FLSD Docket 05/13/2009 Page 3 of 7
+Page 3
+significant fact that a stay may be issued in light of an ongoing investigation. It is clear from the
+NPA and Jack Goldberger's Affidavit (attached to the Motion to Stay) ".. that the criminal
+matters against Epstein remain ongoing until the NPA expires by its terms in late 2010. .., and
+the threat of criminal prosecution against Epstein by the USAO continues presently and through
+late 2010." See Jack Goldberger's Affidavit, 15 (attached to the Motion to Stay)(DE 51). In
+fact, the FBI refused to provide information regarding this case and other related cases filed
+against Epstein ".... stating the materials are at this time exempt from disclosure because they are
+in an investigative file, i.e., the matter is still an ongoing criminal investigation." See Jack
+Goldberger's Affidavit, 17 (attached to the Motion to Stay)(DE 51).
+Additionally, Plaintiff's response downplays the fact that civil discovery may result in the
+USAO claiming a breach of the NPA. Epstein wishes to vigorously defend this case and others
+filed against him; however, he does not wish to risk waiver of his s' Amendment privileges, at
+least before the NPA expires or any investigation is closed.
+Further, Plaintiff adopts the arguments set forth in Jane Doe's Response to the Motion to
+Stay filed in 08-CIV-80893, which asserts that the NPA is not attached to Epstein's Motion to
+Stay. The Court has a copy of the NPA. While it may be sealed, this Court may review same, in
+camera. As such, Plaintiff's Best Evidence argument (as adopted) is entirely misplaced and
+should be disregarded.
+a.
+Justice Requires The Entry of A Stay
+As set out in the Motion to Stay, once the NPA expires, EPSTEIN intends to testify to all
+relevant and non-objectionable inquiries made to him in discovery be it a deposition, in
+interrogatories or in production requests. However, the current circumstances are such that by
+3
+
+
+
+Page 4
+testifying or responding to discovery, EPSTEIN will be required to waive his constitutional
+privileges, thereby subjecting himself to scrutiny by the USAO as a result of matters alleged in
+this civil action (and others before this Court and in the State of Florida 15" Judicial Circuit
+Court, Palm Beach County).
+When an ongoing criminal investigation exists, courts have granted motions to stay civil
+proceedings. In St. Paul Fire and Marine Insurance Company v. U.S., 24 CI.Ct 513 (1991), the
+court held that staying a civil action for 6-9 months was reasonable in light of a pending criminal
+investigation so long as the movant met certain elements (see infra) and the stay was not
+immoderate or unreasonable. Taking into consideration the Motion to Stay and this Reply as
+well as facts alleged by Plaintiff in her operative pleading against Epstein, it is clear that Epstein
+has met the elements of St. Paul Fire necessary for this Court to enter a stay:
+1.
+Epstein has made a clear showing, by direct or indirect proof, that the
+issues in the civil action are "related" as well as "substantially similar" to the
+issues in the criminal investigation.
+2.
+Epstein has made a clear showing of hardship or inequity if required to go
+forward with this civil case while the NPA and/or the ongoing investigation exist.
+(see supra and see also Motion to Stay and attached affidavit of Jack Goldberger,
+Esq. discussing Epstein's 5l* Amendment Rights and how those rights affect this
+civil litigation - see supra); and
+Epstein, in light of the stays granted by other courts, has shown that a stay
+in the instant matter until late 2010 (the date the NPA expires) and the likely date
+any ongoing investigation will be closed is not immoderate or unreasonable.
+St. Paul Fire and Marine Insurance Company v. U.S., 24 CI.Ct at 515-16; see also Wilson v.
+National Association of Letter Carriers, 2006 WL 3791313, *1 (E.D. La. 2006)(granting motion
+to stay civil proceeding for 2 years and 7 months pending criminal investigation); Ostrow v.
+U.S., 1986 WL 6855, *1 (M.D. Fla.) (recognizing a defendant's constitutional rights and allowing
+4
+
+
+
+Page 5
+for a stay of the civil case until the criminal aspects/investigation of Defendant's companion case
+are closed).
+Here, Epstein is not required to "contemplate an in haec verba iron-clad comparison of
+separate issues by direct proof." St. Paul Fire and Marine Insurance Company v. U.S., 24 CI.Ct
+at 516. Instead, a reading of the complaint, the NPA (in camera), the pleadings in support of and
+against Epstein's Motion to Stay along with other pleadings in the clerk's file, makes it clear that
+the facts in the instant matter and those in the ongoing investigation are "related" and/or
+"substantially similar." Id. As such, permitting this civil action to go forward would create a
+hardship on Epstein in that he will be forced to invoke his 5* Amendment Privilege and risk
+loosing this case by virtue of not being able to present evidence, or waive that right and risk a
+potential criminal prosecution. Eastwood v. U.S., 2008 WL 5412857, *1 (E.D. Tenn.))("When a
+party to a civil action is subject to criminal proceedings and/or investigations that relate to such
+civil action, courts will often stay the civil proceeding so as to prevent the use of civil discovery
+and evidentiary procedures to obtain evidence for use in the criminal matter). Id. Courts will
+also stay a civil case to preserve 5*" Amendment rights. Id. Further, a comparison of Fed.R.Civ.
+Pro. 26 may expand the rights of criminal discovery beyond the limits of Fed.R.Crim.Pro. 16(b).
+Epstein satisfies the requirements to stay this action as set forth in St. Paul Fire and in Eastwood,
+including the similarity of issues underlying the civil litigation and ongoing criminal
+investigation.
+As such, a stay should be entered in the instant matter. See also U.S. v.
+$75.020.00 In United States Funds, et al., 2009 WL 1010359 (M.D. G.a. 2009).
+5
+
+
+Entered on FLSD Docket 05/13/2009 Page 6 of 7
+Page 6
+II. Conclusion and Request for Relief
+Based upon the foregoing, Epstein is entitled to a full stay of this proceeding (and other
+related matters) until such time as the NPA expires and until the ongoing investigation by the
+USAO is closed (i.e., until late 2010). Alternatively, in an effort to protect Epstein's st
+Amendment and his due process rights in connection with defending these civil matters, this
+court should enter a stay of any discovery directed to Epstein and strike this case from the trial
+docket until the NPA and the ongoing investigation are both concluded and/or expired. In this
+manner, Plaintiff's investigation and discovery as to third parties will continue and will not be
+delayed. Epstein is invoking his st Amendment rights in the first place, which means that
+objections to discovery and deposition questions are being asserted so as not to waive those 5*
+Amendment rights. Once the NPA and the ongoing investigation terminate, this court could
+allow additional time for Plaintiff to complete Epstein's deposition and discovery directed to
+him, and then set this case on the Court's most available docket. Despite Plaintiff's contentions,
+Epstein's 5" Amendment rights and his due process rights associated therewith and in
+connection with defending this civil case should trump any civil claim for money damages when
+it comes to timing. Eastwood v. U.S., 2008 WL 5412857, *6 (reasoning that a stay is warranted
+when the risk to an individual's constitutional rights is magnified).
+WHEREFORE, Epstein requests the following relief set forth above, and for such other
+and further relief as this court deems just and proper.
+ROBERT D. CRITTON, JR., ESQ.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+6
+
+
+
+Page 7
+Richard Horace Willits, Esq.
+Richard H. Willits PA
+Lake Worth, FL 33461
+Counsel for Plaintiffl
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A
+West Palm Beach, FL 33401-5012
+Jack Scarola, Esq.
+Jack P. Hill, Esq.
+Searcy Denney Scarola Barnhart &
+Shipley. P.A.
+West Palm Beach, FL 33409
+Fax: 561-383-9424
+Co-Counsel for Plaintiff
+Counsel for Defendant Jeffrey Epstein
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+West Palm Beach. FL 33401
+Counsel for Defendant
+Respectfully submitted
+By:
+ROBERT D. CRITTON, JR., ESQ.
+Elorida Bar No. 224162
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+BURMAN, CRITTON, LUTTIER & COLEMAN
+SToN. Tragier Dive, Suite 400
+West Palm Beach, FL 33401
+7
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/2fcb971505f6b81185e9c9ce85189206835bff8dd17e0b75cc08ac3d3a7e13e5.receipt.json b/vision-fixhub/ds9-unparsed-06/2fcb971505f6b81185e9c9ce85189206835bff8dd17e0b75cc08ac3d3a7e13e5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9e20a42e62dbf98c16e4f0fc3b32cbb458205373
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/2fcb971505f6b81185e9c9ce85189206835bff8dd17e0b75cc08ac3d3a7e13e5.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -532,
+  "dataset": "marble-joined",
+  "doc_id": "2fcb971505f6b81185e9c9ce85189206835bff8dd17e0b75cc08ac3d3a7e13e5",
+  "engine": "marble-apple-vision",
+  "event_count": 13,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "8ae4af75b95a33482a6e2b01173e7106a7658775401acfb3881d5f0ade026fac",
+  "output_sha256": "ef48547307b2bdc1375551535ea8cbd565f6afc6539241603b05721ade61ada0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/304f66d36aba497629f8732a6da7c8a976eb64e4ba3ef4aa3d19f10958666833.md b/vision-fixhub/ds9-unparsed-06/304f66d36aba497629f8732a6da7c8a976eb64e4ba3ef4aa3d19f10958666833.md
new file mode 100644
index 0000000000000000000000000000000000000000..0d748a7299c91d4e6728db24051174cde5b7841e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/304f66d36aba497629f8732a6da7c8a976eb64e4ba3ef4aa3d19f10958666833.md
@@ -0,0 +1,51 @@
+From:
+To:
+Pages
+Date: Tue, 06 Apr 2010 13:56:04 +0000
+Importance: Normal
+Subject: Activity in Case 9:08-cv-80119-KAM Doe I. Epstein Order on Motion for Leave to File Excess
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 4/6/2010 at 9:56 AM EDT and filed on 4/6/2010
+Case Name:
+Doe | Epstein
+Case Number:
+9:08-CV-80119-KAM
+Filer:
+Document Number: 519
+Docket Text:
+ORDER Granting [501] Unopposed Motion for Leave to File Excess Pages. Signed by
+Magistrate Judge Linnea R. Johnson on 4/6/2010. (sa)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+Bradley James Edwards
+Isidro Manuel Garcia
+Jack Alan Goldberger
+Jack Patrick Hill
+Jeffrey Mare Herman
+Katherine Warthen Ezell
+
+
+Michael James Pike
+Paul G. Cassell
+Richard Horace Willits
+Robert C. Josefsberg
+Robert Deweese Critton, Jr
+Stuart S. Mermelstein
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=4/6/2010] [FileNumber=7437424-0]
+[3b41fb9fc6bбaa5d8c975bb25d22911a057f986c7374f77b20b3f6ee5b52e27acbal
+4a53f9e3b44a5541a3dde721a54c9786c7bebe98db525b3d5f0a1dee104b]]
diff --git a/vision-fixhub/ds9-unparsed-06/304f66d36aba497629f8732a6da7c8a976eb64e4ba3ef4aa3d19f10958666833.receipt.json b/vision-fixhub/ds9-unparsed-06/304f66d36aba497629f8732a6da7c8a976eb64e4ba3ef4aa3d19f10958666833.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c2da9034b06b81c4374aff6ae02b39e71bfd93e7
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/304f66d36aba497629f8732a6da7c8a976eb64e4ba3ef4aa3d19f10958666833.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "304f66d36aba497629f8732a6da7c8a976eb64e4ba3ef4aa3d19f10958666833",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "7a7e572f6a2f32b85ccc7026846e9e6605ca214ae985834186f955cb02160fd4",
+  "output_sha256": "9e18bb526ebccb58d204eea4340be34e02b2d314967f2607fbcfbc2333059d60",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/30d2182e44d23564d589d0b1b34cc5f6d5dfb7647cead6716c00b2ab824e002f.md b/vision-fixhub/ds9-unparsed-06/30d2182e44d23564d589d0b1b34cc5f6d5dfb7647cead6716c00b2ab824e002f.md
new file mode 100644
index 0000000000000000000000000000000000000000..f9cbe55779dcbb11da94daaf76056f3467a1b0fd
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/30d2182e44d23564d589d0b1b34cc5f6d5dfb7647cead6716c00b2ab824e002f.md
@@ -0,0 +1,2391 @@
+Questions or Changes?
+cingular.com
+• Toll Free 1 866 293-4634
+:
+611 from your wireless phone
+TTY users - 1 866 429-7TTY
+SUMMARY OF MONTHLY CHARGES FOR ACCOUNT 0031035751
+Previous
+Balance
+84.84
+Payments
+Received
+0.00
+Late Payment
+1.27
+Total
+Adjustments
+0.00
+Your billing cycle began on July 15, 2005 and ended on August 14, 2005
+Current Monthly Charges
+Monthly Service
+Monthly Usage
+Charges
+Credits
+Government Fees and Taxes
+Total Current Monthly Charges
+TOTAL AMOUNT - Due Upon Receipt
+Date of Invoice: August 15, 2005
+Balance
+Forward
+84.84
+Current Monthly
+Charges
+75.48
+Total
+Amount Due
+160.32
+59.96
+1.90
+2.72
+0.00
+10.90
+75.48
+160.32
+AS OF JULY 20TH, PAYMENTS SHOULD BE SENT TO THE
+FOLLOWING ADDRESS:
+CINGULAR WIRELESS
+PO BOX 6444
+CAROL STREAM, IL 60197
+Account Name: MARTIN GOLICK
+lease Return This Portion With Your Paymer
+Ise of service or payment of this invoic
+indicates contions for whites seracterms
+Yes alically deduled from the account my eric Posed check
+(see reverse - signature required).
+Date Due
+UPON RECEIPT
+Note:
+=>
+We Print on
+Front and Back
+Service # 5613797824
+Account # 0031035751
+Total
+Amount Due
+160.32
+Chack here for ha.
+Amount
+Paid
+#BWNHNGB
+#0000000310357512# w
+2006309 02 AT D.517 AUTO T40 0814 33411.5.52.02.1034.0000
+CINGULAR WIRELESS - ATLYS
+PO BOX 6444
+CAROL STREAM, IL 60197-6444
+
+
+
+Recurring Electronic Fund Transfer (REFT): To enroll: sign below, check the REFT box on the reverse side and
+remit with this month's payment. Keep paying your bill until your statement indicates "Do Not Pay". REFT
+Agreement: 1 authorize my financial institution to deduct the amount of my monthly wireless phone bill from the
+account associated with the enclosed check and remit payment to Cingular Wireless. This authority will be effective
+until | notify Cingular Wireless to terminate it. I agree that I may be assessed a service charge (up to $20) or late
+fee or both if a payment is returned by my bank. For more information visit cingular.com/myaccount or call 1 866
+293-4634. Please keep a copy of the form below and this REFT Agreement for your records or retain a copy of the
+blank form from next month's invoice.
+Questions? We can help: Cingular Wireless appreciates your business and welcomes the opportunity to assist
+you. Visit our website at cingular. com or contact Customer Care by dialing 611 from your wireless phone or 1 86b
+293-4634. ¿Sabias que también ofrecemos servicio al cliente en tu idioma? Marca 611 desde tu teléfonc
+inalámbrico ó 1 866 293 4634 desde cualquier teléfono y oprime el *.
+Driving Wireless Safety: Your wireless phone gives you the freedom and flexibility to stay in touch when you
+travel, but don't let a phone call distract you from driving safely. Use hands-free device if allowed or required by
+law. Call Carefully, Arrive Safely.
+Processing Fees: When you pay by check, Cingular Wireless will present the check for payment by your bank
+electronically. Your bank account will be debited in the amount of the check and the transaction will appear on your
+bank statement. Your original check will be destroyed once processed, and you will not receive your cancelled
+check back. If we cannot post the transaction electronically, an image copy of your check will be presented for
+payment. For additional information, please call 1 800 682-2978. Accounts suspended for non-payment will be
+subject to a $25 reactivation fee per line and may be assessed a security deposit prior to reinstatement. Checks
+returned for non-sufficient funds will be charged up to a $30.00 fee.
+Local Tax: Local taxes are based on local government boundaries, the address information you provide for your
+account and/or your wireless telephone number. Please review the local tax charges on your bill. It you believe
+there is an error in the local tax charge, please contact us immediately at 1 866 293-4634. Please note that some
+local or state laws may require you to follow special procedures when notifying us about a local tax dispute. You
+may also use the form below to notify us of any change to your taxing address. Thank you for your cooperation.
+Early Termination Fee (ETF): If you cancel service before your contract end date (including if you switch your
+wireless number to another carrier), you will be charged an Early Termination Fee of up to $200.
+One Time Checking Account Payment Authorization Agreement (for use with kiosk payment): I authorize
+Cingular Wireless to make this one-time bill payment by debiting my bank account. I can cancel authorization by
+contacting an in-store sales person. If my bank rejects a payment, I may be charged a return fee.
+Please Send Correspondence To:
+Cingular Wireless Next Generation Correspondence
+P.O. Box 68056
+Anaheim Hills, CA 92817-8056
+2006309.000019290.6
+count ame and ranse an espress clearly and check the box on the reverse side. Please contact Customer Care to change the
+New Billing Address
+City
+State
+Zip
+Home Phone (
+Work Phone (-
+If your billing address is NOT your Tax Address, please enter the Tax Address below. (Multi-line accounts should attach a list of each wireless number
+and the respective Tax Address.)
+New Tax Address
+City
+Wireless Number (.
+State
+Zip
+Recurring Electronic Fund Transfer (REFT) Enrollment. Please read the agreement on the top portion of this page, sign below and check
+the "REFT Registration" box on the reverse side
+Financial Account Holder Signature
+• • I do not wish to receive email notification of special offers avalable to Cingular Wireless customers.
+
+
+
+SIGN UP TO RECEIVE WIRELESS AMBER ALERTS AT
+WWW.CINGULAR.COM/AMBERALERTS OR BY SENDING A TEXT
+MESSAGE WITH UP TO 5 ZIP CODES TO THE SHORT CODE AMBER
+(I.E. SEND SUBSCRIBE 12345 TO SHORT CODE 26237).
+CUSTOMERS CAPABLE OF RECEIVING TEXT MESSAGES CAN
+RECEIVE THESE GEOGRAPHICALLY SPECIFIED ALERTS. THERE
+IS NO CHARGE TO SIGN UP OR TO RECEIVE AMBER ALERTS.
+NORMAL AIRTIME CHARGES WILL APPLY IF YOU PLACE A CALL
+IN RESPONSE TO AN AMBER ALERT MESSAGE.
+LATE PAYMENT CHARGE:
+A 1.5% LATE PAYMENT CHARGE PER MONTH MAY BE APPLIED FOR
+AMOUNTS UNPAID 20 DAYS AFTER THE DATE OF INVOICE
+(AK 0.875%, AR 0.085%, NE 1.33%, WI 1.00%).
+ACCOUNT DETAILS
+Detail of Other Account Charges
+Item Description
+1 LATE PAYMENT CHARGE
+Total of Other Account Charges
+Detail of Account Government Fees and Taxes
+Item Description
+1 FEDERAL EXCISE TAX
+Total Account Government Fees and Taxes
+Current Subscriber Monthly Charges and Credits
+Subscriber Number
+Subscriber Name
+
+Total Current Subscriber Monthly Charges and Credits
+Total Current Monthly Charges
+1.2Z
+1.27
+0.04
+0.04
+74.17
+74.17
+75.48
+
+SUMMARY OF CURRENT ACTIVITY
+FOR (561)379-7824
+Monthly Service Charges
+Item Description
+1 CALL WAITING
+2 TEXT MESSAGING PLAN - 0 MSGS
+3 CALLER ID
+4 VOICEMAIL
+5 DETAIL BILLING
+6 COM EQP 1.99EW/3.00INS $4.99
+7 CALL FORWARDING
+8 WORLDCONNECT
+9 THREE WAY CALLING
+10 $39.99 CHARTER OFFER
+11 1000 NIGHT AND WEEKEND MINUTES
+Total Monthly Service Charges
+Monthly Usage Charges
+Item Description
+1 500 ANYTIME MINUTES
+2 MESSAGE RETRIEVAL
+3 1000 NIGHT/WKEND MIN
+4 100 INCL. MSGS SENT
+5 CALL WAITING
+6 411 INFO
+7 MULTIMEDIA SNT
+8 INCLUDED MINUTES
+Total Monthly Usage Charges
+Other Subscriber Charges
+Item Description
+1 FEDERAL UNIVERSAL SERVICE FUND SURCHARGE
+Total Other Subscriber Charges
+Subscriber Government Fees and Taxes
+Item Description
+1 911 SURCHARGE
+3 FEDERAL EXCISE TAX
+4 STATE COMM SERVICE TAX
+5 LOCAL COMM SERVICE TAX
+Total Subscriber Government Fees and Taxes
+TOTAL CURRENT CHARGES FOR (561)379-7824
+Service Dates
+07/15/05 - 08/14/05
+07/15/05 - 08/14/05
+07/15/05 - 08/14/05
+07/15/05 - 08/14/05
+07/15/05 - 08/14/05
+07/15/05 - 08/14/05
+07/15/05 - 08/14/05
+07/15/05 - 08/14/05
+07/15/05 - 08/14/05
+07/15/05 - 08/14/05
+07/15/05 - 08/14/05
+Onty Used
+500 MIN
+24 EVT
+947 MIN
+26 EVT
+20 EVT
+1 EVT
+1 EVT
+403 MIN
+0.00
+4.99
+0.00
+0.00
+0.00
+4.99
+0.00
+0.00
+0.00
+39.99
+9,99
+59.96
+0.00
+0.00
+0.00
+0.00
+1:50
+0.40
+0.00
+1.90
+1,45
+1.45
+0.50
+0.32
+1.61
+5.31
+19.12
+74.17
+
+
+
+L626L00006069002
+DETAIL OF CURRENT ACTIVITY
+VOICE USAGE FOR (561)379-7824
+Item Date Time Called
+1 07/15 03:58P (561)792-5628
+2 07/15 04:01P (561)379-7824
+3 07/15 07:08P
+07/15 07:11P
+07/15 09:16P
+07/15 09:57P
+19811292-532
+61)792-637-
+7 07/16 11:51A (561|379-7824
+8 07/16 11:53A (561)801-3590
+9 07/16 11:54A (561)686-7440
+11 0718 12:03P 581218-9718
+Calls To
+NPALMBEACH FI
+NPALMBEACH FI
+VPALMBEACH E
+VPALMBEACH
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+VPALMBEACH F
+VPALMBEACH FI
+140P 5611541-619
+14 07/16 04:13P
+07/16 04:14P
+16 07116 04:18P
+COMIN
+(954)303-7531
+(954)258-2985
+(561)541-6152
+(561)541-6152
+CH
+8890088090000900990000BE
+
+200008808 888888888
+(561)801-3590
+
+Onty
+Used Rate Description
+500 ANYTIME MINUTES
+1MIN
+500 ANYTIME MINUTES
+LESSAGE RETRIEVA
+00 ANYTIME MINUTE
+2 MIN
+500 ANYTIME MINUTES
+000 NIGHT/WKEND MI
+JOD NIGHT WKEND MI
+2 MIN
+1000 NIGHT/WKEND MIN
+MIN
+2 MIN
+MIN
+1MIN
+2 MIN
+MIN
+2MIN
+1M
+3MIN
+2 MIN
+QMIN
+1000
+1000
+1000
+1000
+1000
+1000
+1000
+1000
+1000
+1000
+1000
+1000
+
+Item Date Time Called
+63 07/17 08:35P
+64 07/17 08:37P (561)317-5175
+07/17 08:51P (561)818-33
+117 10:11
+67 07/17 10:36P
+69 0717 11:20P (561818 3531
+59 07/17 11:20P
+70 07/17 11:38P
+72 87AZ 1130P (581818-5831
+73 07/18 12:03A
+76 87/18 12:31A
+78 07/18 12:57A
+561)714-5714
+Calls To
+WPALMBEACH FL
+WPALMBEACH FL
+NCOMING
+PALMBEARE E
+PALMBEAC
+WALMBEACH FL
+РАШУВЕАСЕ -
+PALM
+PALMBEACH
+DALMBEAT
+WPALMBEACH FL
+NPALMBEACH FI
+MPALMBEACH FI
+
+99999
+DID 0D 000D
+/19
+53088
+98989
+
+-8500
+56
+1)71
+
+(881)
+1801.
+coco
+09558
+(561)309-1375
+NE
+coco hang
+
+(561)801-3590
+8888
+8280
+(864)
+COMIN
+COMIN
+WPALMBEACH FL
+COMING
+WPALMBEACH FL
+COMIN
+COMIN
+WPALMBEACH Fl
+NCOMING
+WPALMBEACH FL
+OYNTONBCH F
+WPALMBEACH FL
+WPALMBEACH FL
+NCOMING
+COMING
+COMING
+WPALMBEACH FL
+FTLAUDERDL FL
+Onty
+Used
+Rate Description
+3MIN
+1000 NIGHT/WKEND MIN
+2 MIN
+1000 NIGHT/KEND MIN
+2MIN
+IMIN
+MIN
+1000 NIGHT/KEND
+1000 NIGH-WREND
+MIN
+I NIGHT/KEND MIN
+1000 NIGHT/KEND MIN
+JIGHTANKENI
+1000 NIGHT/KEND MIN
+JOO NIGHTWKEND M
+DO NIGHT MKEND M
+1000 NIGHT/KEND MIN
+DO NIGHTAWKEND M
+MI
+19MIN
+4 MIN
+MINUT
+ANYTIME
+MINUT
+1000 NIGHT/WKEND MIN
+EMIN
+2 MIN
+2MIN
+EMIN
+1 EVT
+1.50 411 INFO
+SOO ANYTIME MINUTES
+500 ANYTIME MINUTES
+MINU
+2 MIN
+EVT
+2MIN
+2 MIN
+2MIN
+500 ANYTIME MINUTES
+SOO ANYTIME MINUTES
+500 ANYTIME MINUTES
+DO ANYTIME MINUTE
+DO ANYTIME MINUTE
+DD ANYTIME MINUTE
+DO ANYTIME MINUTE
+500 ANYTIME MINUTES
+500 ANYTIME MINUTES
+500 ANYTIME MINUTES
+1.50
+
+
+
+
+Item Date Time
+Called
+126 07/19 08:41P
+127 07/19 08:42P
+(561)313-5654
+28 07/19 08:46P
+(561)818-3331
+19 09:09P
+5611309-1379
+130 07/19 10:03P
+131
+'561)309-1375
+07/19 10:04P
+(561)719-5911
+32 07/19 10:05R
+133 07/19 10:27P
+133 87/18 10:380 (581)713-5811
+136 07/19 10:38P
+138 07/19 10:41F
+140 87/18 10:430
+(561)317-5175
+141 07/20 01:22A
+143 07/20 91:30A
+:55P
+:56P
+Calls To
+LAKE WORTH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+PALMEEARE
+PALMBB
+NCOMINC
+NPALMBEACH FI
+NCOMING
+NCOMING
+NCOMING
+NCOMING
+INCOMIN
+NOON
+NGOM
+Onty
+Used
+I MIN
+ZMIN
+2MIN
+7MIN
+385g820°gб6522E
+
+:57P
+:01P
+:05P
+05:000
+07/20
+05:22P
+07/20 05:22P
+160 07/20 05:23P
+161
+162
+
+05:26P
+163 07/20 05:29P (561)714-6296
+164 07/20 05:34P
+16.
+07/20 05:42F
+П6•00P
+167
+07/20 06:01P
+(561|714-5714
+168
+07/20 06:07P
+169 07/20 06:16P
+179
+07/20
+06:20P
+ПA.00P
+(561)313-5654
+071
+07
+06:33P
+07/20
+561)714-5714
+07.
+120
+06:33P
+5611714-5714
+07:28Р
+7721485-4803
+772)485-4893
+07/20 07:31P
+07)
+Bg
+09:03P
+00•18P
+07/20
+10:48P
+87/20
+10:49P
+10:50P
+(S61)714-5714
+07/20
+1
+07J
+9995
+gờggg
+10:52P
+10:588
+10
+•59F
+1:00P
+:04P
+(561)541-3826
+5611541-4982
+11:13P
+COMING
+OMINC
+WPALMBEACH FL
+COMING
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+NOOMING
+MPALMBEACH FI
+WPALMBEACH FL
+WPALMBEACH FL
+NOOMING
+I AKE WORTH FI
+NOOMING
+WPALMBEACH FL
+WPALMBEACH FL
+TUART F
+TUART F
+NOOMING
+MPALMRFACH FIl
+WPALMBEA
+WAL BEACH FLE
+NOMING
+WPALMBEACH FL
+WPALMBEACH FL
+Rate Description
+500 ANYTIME MINUTES
+500 ANYTIME MINUTES
+DO ANYTIME MINUTE
+DOO NIGHT WKEND MIT
+1000 NIGHT/KEND MIN
+0 NIGHT/WKEI
+0 NIGHTAWKEI
+MIN®
+1000 NIGHT/KEND
+MIN
+HT/WK
+D
+Item Date Time Called
+189 07/20 11:14P (561)818-3331
+190 07/20 11:16P
+(561)351-5190
+192 87/20 11:19P
+5928
+11:19P
+07/20
+561 541-4
+11:21P (561)351-4517
+17/20
+11:22P
+(813)905-6645
+11-23P
+561719-5911
+07/20
+11:24P
+11:25P
+198 87/20 11:25P
+(561)603-4453
+198
+Calls To
+WPALMBEACH FL
+PALNACH EE
+VPALMBEAC
+(PALMBEAC
+WPALMBEACH
+TAMPACNTRL
+WPALMBEACH FL
+AKE WORTH F
+COMI Ni
+26P
+(561)281-0170
+1137P
+11:39P
+VPALMBEACH F
+INCONNG
+NCOMING
+Onty
+Used Rate Description
+2MIN
+1000 NIGHT/KEND MIN
+1000 NIGHT/KEND
+ZMIN
+1000 NIGHT/WKEND
+1000 NIGHT/KEND
+1000 NIGHT/KEND
+1 HIN
+1000 NIGHT/WKEN
+1 HIN
+1000 NIGHTANKEND
+1000 NIGHT/KEND
+2MIN
+1000 NIGHT/WKEND MID
+000 NIG
+HT/KEND
+1 EVT
+CALL
+10
+......
+561)
+1281-8170
+561)281-0170
+(561)281-0170
+(561)856-9275
+(581)
+(56
+889-
+-71
+100
+(561)889-7100
+9888
+(954)552-7581
+D0 C0-100 00
+NPALMBEACH FL
+PД000 7
+WPALME
+WPALME
+2006309.000019292
+
+
+2006309.000019292
+
+Item Date Time
+Called
+253 07/21 11:24P
+(561)541-4382
+07/21 11:24P
+561)317-5175
+1Е38P
+07
+11:33P
+(561)719-5911
+00 1|8 l
+4-5714
+611715-6303
+11:44P
+1:44P
+/21
+:53P
+1:53P
+561)714-5714
+(561)715-6303
+11:55P
+11-58P
+611714-571
+611714-571
+12:09A
+12:15A (954)552-7581
+12:31A
+1233A
+35A
+611801-359
+61j818-333
+274
+07/22
+12:36A
+275 07/22 12:38A
+15611856-9275
+276 07/22 12:52A (561j379-7824
+07/22 10:31A (561)714-5714
+
+0:32A (561)792-057
+:29A
+-OTA
+(561)792-0574
+12:04P
+:09P
+2.20г
+561)792-0574
+5611792-6375
+561)714-5714
+561|792-6375
+(562) 293-1775
+(772)485-4893
+
+
+Calls To
+VPALMBEACH F
+VPALMBEACH F
+NOOMING
+MPALMBEACH FL
+WPALMBEACH FL
+DELRAY BCH FL
+WPALMBEACH FL
+WPALMBEACH FL
+DELRAY BCH FL
+COMIN
+VPALMBEACH F
+PALMBEACH F
+PALMBEACH F
+COMING
+TLAUDERDL-
+PALMBEACH
+DAI MIREACH
+PALM BEACH FLI
+WPALMBEACH FL
+WPALMBEACH FL
+NPALMBEACH FI
+NOOMING
+WPALMBEACH FL
+NOOMING
+WPALMBEACH FL
+WPALMBEACH FL
+RISMERLEM
+LL
+WPALI
+WPALA
+• • ҐЕґҐЕй
+Onty
+Used
+Rate Description
+1000 NIGHT/WEND MIN
+1000 NIGHT/KEND
+MIN
+TAWKEN
+3MIN
+1000 NIGHT/KEND
+X00 NIGHT/WKEN
+MIN
+2 MIN
+XO NIGHTAWKEN
+1000 NIGHT/WKEND
+00 NIGHT/WRET
+1000 NIGHT/KEND
+1MIN
+2 MIN
+2 MIN
+MIN
+FF
+1MIN
+•MIN
+2MIN
+TAWKENI
+1000 NIGHT WIEND
+1000 NIGHT/KEND
+000 NIGHT/WKEN
+000 NIGHT KEN
+000 NIGHT/WK
+000 NIGHT/WKEN
+1000
+00I
+500
+500
+Item Date Time Called
+Calls To
+16 07/23 09:14A (561)714-5714
+318 87/23 09:32A (561) 753-8592
+319 07/23 10:02A (561)840-6828
+329 07/23 10:13A (772)219-4743
+07/23 10:19A
+322 07/23 10:32A
+323 07/23 10:35A (561)389-3470
+325 07/23 10:48A
+:10:55A
+17/23 11:024
+(561)840-6828
+11:164
+(561)801-3590
+11-25A
+(561)818-7836
+11:27A
+12-06P
+(561)723-8702
+(561)753-8592
+19P
+(561)798-3949
+MPALMBEACH R
+NPALMBEACH FL
+WPALMBEACH FL
+STUART FL
+WPALMBEACH FL
+WPALMBEACH FL
+PALMBEACH I
+WPALMBEACH FL
+VPALMBEACH F
+/PALMBEACH FL
+Onty
+Used Rate Description
+1EVT
+MESSAGE RETRIEVAL
+1000 NIGHT/KEND MIN
+EMIN
+ANKEND MIN
+1000 NIGHT/KEND MIN
+1S MIN
+1000 NIGHT/KENB MIN
+TANKEND MIN
+3MIN
+1000 NIGHT/KEND MIN
+EMIN
+ND MIN
+1000 NIGHT/KEND MIN
+EMIN
+EMIN
+2 MIN
+2 MIN
+ND MIN
+1000 NIGHT/KEND MIN
+NIGHT WHEN MING
+(786)393-9001
+
+
+9541552-7581
+-3590
+(561)541-4382
+11-4382
+(561)541-4382
+(561)541-4382
+ҐЕҐ ЕЕКЕ"
+5:
+NCOMING
+.......
+
+
+
+Item Date Time
+Called
+380 07/25 08:39A
+381 07/25 09:25A
+2 07/25 10:21
+3 07H
+10:28A (561)798-8500
+384 07/25 11:04A
+(7721219-4743
+38% 87/25 11:38A (954)552-7581
+387 07/25 11:53A (772)219-4743
+189 07/25 12:001
+189 07
+390 07/25 12:11P
+392 07/23 12168
+(561)309-1375
+391 07/25 1213P
+395 07/25 12:28P
+(561)840-6827
+12:44P
+(561)840-6827
+07H
+Calls To
+NCOMING
+COMING
+MPALMBEACH FL
+STUART FL
+NOOMING
+TLAUDERDL FI
+STUART FL
+NCOMING
+NOOMING
+NOOMING
+NPALMBEACH FL
+NCOMING
+NPALMBEACH FL
+WPALMBEACH FL
+NCOMING
+NCOMING
+(561)801-3590
+1317-5175
+541-4382
+309-1375
+29g
+Q.
+
+561
+01
+1581)
+(561)301-6368
+98828R09829
+
+61)386-638
+611644-332
+1561282-8891
+(561)719-5911
+(561|379-7824
+438
+07/26 03:41P
+439
+440
+07/26 04.16P
+5611708-1653
+04:16P
+07/26
+790-4794
+04•21P
+126
+(561|601-0725
+04-26P
+07/26
+04:29P
+(561)204-4902
+P
+29999999999999 997 999 99
+«ť Ґứґ ¿Ợď ťďďďďďď«ứứưďứ
+WPALMBEACH FI
+NOOMING
+PAI MRFA
+MALMBEACH
+WALMBEACH
+NOOMING
+NCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+WALMBEACH FL
+WPALMBEA
+LAKE WORTH FL
+NCOMING
+WPALMBEACH FL
+Onty
+Used
+Rate Description
+2 MIN
+500 ANYTIME MINUTES
+500 ANYTIME MINUTES
+IMIN
+500 ANYTIME MINUTES
+2MIN
+500 ANYTIME MINUTES
+4 MIN
+500 ANYTIME MINUTES
+iMIN
+500 ANYTIME MINUTES
+SMIN
+500 ANYTIME MINUTES
+3MIN
+500 ANYTIME MINUTES
+2 MIN
+00 ANYTIME MINUTE:
+3MIN
+00 ANYTIME MINUTES
+2MIN
+500 ANYTIME MINUTES
+IMIN
+00 ANYTIME MINUTES
+00 ANYTIME MINUTES
+DO ANYTIME MINUTE
+2 MIN
+6MIN
+2 MIN
+2MIN
+ELEEEEEEE
+2MIN
+2MIN
+Item Date Time Called
+444 07/26 04:31P (561)282-8891
+445 07/26 04:38P
+249 87/26 04 50P
+: 04:50P (561)317-5175
+448 07/26 05:02P
+449 07/26 05:19P
+Calls To
+WPALMBEACH FL
+WPALMBEACH FL
+5611644-332
+450 07/26 05:23P
+611309-137
+451 07/26 05:31P
+(561)383-7101
+453 07/26 06-378
+5611792-637:
+561)792-6371
+07/26 06:42P
+455
+07/26 06:45P
+(561)719-5911
+561 792-6375
+456
+07/26 06:47P
+5611719-5911
+07/26 07:07P (561) 309-1375
+459
+07/26 07:19P
+£3ß938#^88ź8ß₫9
+07/26 07:22P
+07/26 07:26P
+
+
+WPALMBEACH
+WPALMBEACH FL
+MPALMBEACH E
+WPALMBEACH
+WPALMBEACH FL
+NPALMBEACH FL
+MPALMBEACH FI
+WPALMBEACH FL
+OMING
+060609880053฿
+(561/723-
+63 c
+
+88888888888888995#
+
+0 4
+25 58
+8848R28
+
+NANNONE
+S59253%
+561)379-7824
+·23220
+CH
+
+REBELS
+28982
+44488
+Qnty
+Used Rate Description
+2MIN
+500 ANYTIME MINUTES
+3MIN
+500 ANYTIME MINUTES
+O0 ANYTIME MINUTE:
+OO ANYTIME MINUTE!
+500 ANYTIME MINUTES
+2 MIN
+1 HIN
+SOO ANYTIME MINUTES
+3MIN
+2 MIN
+2 MIN
+3MIN
+.....
+
+ANYTIME MINUTES
+NYTIME MINUT
+AN
+TIME MINUTE
+ANYTIME MINUTES
+ANYTIME MINUTE:
+IME MINUTES
+ANYTIME MINUTES
+ANYTIME MINUTES
+
+2006309.000019293
+
+
+2006309.000019293
+
+Onty
+Item Date Time Called
+Calls To
+Used
+Rate Description
+507 07/27 10:35P
+2 MIN
+1000 NIGHT/WKEND MIN
+508 07/27 10:58P (561)281-0170
+WPALMBEACH FL
+"MIN
+1000 NIGHT/KEND MIN
+1128 12:07
+COMIN
+MIN
+MING
+TWKEN
+07/28 01:15A
+1000 NIGHT/KEND
+07/28 01:47A
+07/28 11:23A
+1581) 309-1368
+PALMBEAR E
+PALMBEAC
+DOD NIGHT/WKEN
+00 ANYTIME MINU
+07/28 11:24A
+500 ANYTIME MINUTES
+515 07/28 11:25A
+516
+07/28 11:27A
+(561)301-6368
+MINUTES
+WPALMBEACH FL
+500 ANYTIME MINUTES
+8728 12265
+561]
+581/309:1373
+VPALMBEACH F
+VPALMBEACH F
+EMIN
+X0 ANYTIME MINU
+128
+/28
+12.37P
+17721219-4743
+282-8891
+STUART -
+2 MIN
+NPALMBEACH FL
+MIN
+00 ANYTIME MINUTE
+00 ANYTIMI
+12:39P
+561)309-1375
+2:41P
+WPALMBEACH FL
+2 MIN
+242P
+(561)301-6368
+WPALMBEACH FL
+2 MIN
+ES
+:59P
+2M N
+: (561)676-5836
+07J
+:45P
+8838
+11P
+:32P
+:30F
+55
+05:03P
+07P
+39P
+44P
+:09P
+1P
+06:13P
+16P
+061
+*291
+(954)552-7581
+(561)512-0370
+(561)790-4794
+5611790-4739
+561)309-1375
+954)552-7581
+(561)309-1375
+(854) 52-7381
+08:34P
+561)379-7824
+550 07/28 08:38P (561)379-7824
+28
+18:41F
+08:45F
+(851 582-7301
+08:50P
+28 0a:53P
+192219-4796
+8888
+
+
+÷:01P
+8820230539-99
+EA
+FLAUBERBL FL
+WPALMBEACH FL
+WPALMBEACH FL
+FLAUBERBL EL
+STUART EACH FL
+TLAUDE!
+•TI AUDERDI
+FTLAUDERDL
+FTLAUDERDL
+NOOMING
+FTLAT
+2MIN
+MIN
+MIN
+2 MIN
+2 MIN
+MIN
+MESSA
+1000
+1000
+1000
+1000
+Onty
+Item Date Time Called
+Calls To
+Used Rate Description
+569 07/28 09:50P
+1000 NIGHT/KEND MIN
+570 07/28 09:52P (561)379-7824
+WPALMBEACH FL
+1000 NIGHT/KEND MIN
+571 07/28 09:52P (954)552-7581
+572 07/28 09:53P
+561)310-4757
+FTLAUDERDL FLI
+WPALMBEACH FL
+2 MIN
+1000 NIGHT/KEND MIN
+574 07/28 09:558
+954)552-7581
+5611801-3590
+-ILAUDERDL F
+NPALMBEACH FL
+575 07/28 10:00P
+(561)301-6368
+WPALMBEACH FL
+EMIN
+TANKEND MIN
+1000 NIGHT/KEND MIN
+526 0728 10:018
+561)798-0772
+07/28 10:02P
+561301-6368
+WPALMBEACHFL
+2MIN
+578 07/28 10:03P
+6MIN
+579 07/28 10:09P (561)801-3590
+WPALMBEACH FL
+D MIN
+1000 NIGHT/KEND MIN
+GALL
+1000 NIGHT/KEND MIN
+580 07/28 10:11P
+07/28 10:11P (561)310-4757
+582
+07/28 10:15P 5611714-5714
+WALNEACH
+MIl
+MIT
+COMING
+1000 NIGHT/KEND MIN
+1000
+NIGHT/KEND
+MIN
+ICOMIN
+128 10:34P
+:10:39P
+5611603-0441
+561)603-0441
+8888
+08
+FF
+-38A
+(561)389-3470
+11:39A
+LET EE
+
+:59A
+F58999888888888
+
+s88888888888888888888888888888888888888
+BE BARE
+(561,80
+1801/
+-3590
+-3590
+(561)767-0654
+561 792-6375
+INC
+OMI
+INCLUD
+ED
+INCLUD
+ED
+CLU
+CLU
+INCL
+1000
+1000
+1000
+ED
+ED
+1000
+I NIGHT
+NIGHT
+JUT
+WALMBEACH FL
+2 MIN
+2MIN
+2MIN
+
+
+
+Item Date Time
+Called
+632 07/30 08:41A (561)309-1375
+633 07/30 10:39A
+(561)309-1375
+34 07/30 10:41
+111792-63
+15 07/30 10:58
+11309-137
+636 07/30 11:05A
+(561)309-1375
+636 87/38 11:36A (813)905-6645
+639 07/30 11:55A
+641 87/30 12 125 951)550-7794
+642 07/30 12:17P (561)792-6375
+13 87/30 81:528 (961)784-571
+615 87/30 82:06P (561)714-5714
+647 07/30 02:28P (561)801-3590
+19 07/30 03:11P 1581714371
+Calls To
+WPALMBEACH FL
+WPALMBEACH FL
+WALMBEACH FL
+WPALMBEACH FL
+NCOMING
+TAMPACNTRL FL
+WRANBEACH
+WPALMBEACH FL
+LAUDERL
+PALMBEACH F
+COMIN
+PALMBEACH F
+WPALMBEACH FL
+VPALMBEACH FI
+111314-577
+(561)
+714-
+(5611512-0370
+(561)512-0370
+581312-0310
+1512
+0370
+(561)801-3590
+07
+18271792-4373
+07/
+
+678
+07/
+679
+680
+681
+9999
+20F
+561)792-6375
+5611329-7137
+5611389-3470
+5611389-3470
+071
+10:34P
+714-6296
+5611714-6296
+684 07/30 10:44P
+685 07/30 10:45P
+686
+687
+07/30 1046P
+(S61)314-3714
+688
+07/30
+87/31
+11:05P
+08:04A
+07.
+07/31
+08:59A
+1)792-63
+21485-48
+071
+09:10A
+09:27A
+07
+•41 A
+222
+999
+9
+O COBO B
+:51A
+(772)485-4893
+(772)485-4893
+:56A
+10:10A
+Onty
+Used Rate Description
+1000 NIGHT/KEND MIN
+3MIN
+1000 NIGHT/KEND MIN
+IMIN
+1000 NIGHT/WK
+IMIN
+0 NIGHTA
+0 NIGHTA
+1000 NIGHT/WK
+1000 NIGHT WK
+IT/WK
+1000 NIGHT/WK
+IGHL/
+3 MIN
+1000 NIGHT/WK
+2 MIN
+000 NIGHTA
+2MIN
+1000 NIGHT/WK
+2MN
+W
++ FL
+SPALMBEACH FL
+NOOMING
+NOOMING
+MPALMBEA
+WPALMBEA
+WPALMB
+MPAI MR
+MPAINA
+FA
+WPALMBEA
+299 999
+WPALMBEACH
+WPALMBEA
+WPALMBEA
+STUART FACH FLE
+STUART
+INCOMIN
+STUART
+STUART,
+
+Item Date Time Called
+697 07/31 10:18A (561)389-3470
+698 07/31 10:25A (561)801-3590
+Calls To
+WPALMBEACH FL
+WPALMBEACH FL
+Qnty
+Used Rate Description
+1000 NIGHT/KEND MIN
+1000 NIGHT/KEND MIN
+
+ĚğŇžğšěğ$
+99
+10:
+35A
+1 10:41A (561)389-347
+07/31 10:58A (561)714-6296
+07/31 12:53P
+5611714-6296
+17/31 01 48P 561714-6296
+07/31 01:56P
+07/31 02 26P (581/714-6296
+07/31 02:28P
+709 07/31 02:32P (561)714-5714
+710 07/31 02:43P
+711
+07/31 03:03P
+(561/714-6296
+56
+(561)714-
+561)792-6375
+31
+05:55P
+
+Sowwwwwwwwwa
+888888888-88
+(561)379-7824
+
+
+
+(562/2194795
+219-4743
+(561)379-7824
+
+8888838838888≤
+
+
+888
+979
+88-
+14-
+561)312-9092
+5611601-7888
+2
+(561)379-7824
+08
+/03
+11
+1:53A
+(772)219-4743
+COMIN
+PALMBEACH F
+WPALMBEACH
+WPALMBEACH
+WPALMBEACH FL
+WPALMBEACH FL
+VPALMBEACH f
+VPALMBEACH F
+NPALMBEACH FL
+NCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+ING
+IG
+CH
+CH
+ACH FL
+ACH
+I FL
+JPALMBEACH F
+TUAF
+WPALMBEACH FL
+COMING
+COMING
+NCOMING
+WPALMBEACH FL
+FTLAUDERDL FL
+WPALMBEACH FL
+WPALMBEACH FL
+PALMBEACH
+KE WORTH
+WALMBEACH FL
+STUART FL
+3 MIN
+2 MIN
+2 MIN
+2 MIN
+2 MIN
+3MIN
+1 EVT
+2MIN
+2 MIN
+SHIN
+2222
+BREE
+3MIN
+EVT
+MIN
+MIN
+TIẾN
+3MIN
+1EVT
+4MIN
+1000 NIGHT/KEND
+1000 NIGHT/WKEND
+1000 NIGHT/KEND
+1000 NIGHTWKEN
+MIN
+1000 NIGHTANKEND
+1000 NIGHT/KEND
+1000 NIGHT/KEND
+000 NIGHT/NK
+1000 NIGHT/KEND
+1000 NIGHTWKEND
+ELLE
+CALL WAITING
+000 NIGHT/KEND MIN
+1000 NIGHT/KEND
+1000 NIGHT/KEND
+INUTE (
+INUTE:
+RETRIEVA
+-CCAR
+UD.
+1000 NIGHTANKEND MIN
+NCLUDED MINUTES
+MESSAGE RETRIEVAL
+INCLUDED MINUTES
+2006309.000019294
+
+
+#626L0000 606900Z
+* cingular
+
+Item Date Time
+Called
+757 08/03 12:54P (561)379-7824
+Calls To
+WPALMBEACH FL
+759 08/03 12 38P 1561)802-8925
+760 08/03 07:56P
+08/03 08:33P
+561)792-6375
+561)714-5714
+182 08/03 10:01P 1381|792-3375
+763 08/03 10:46P
+764 08/04 03:39P (561)379-7824
+765 08/04 05:28P (772)219-4743
+766
+767
+08/04 06:56P
+08/04 07:83P 5611801-3590
+768 08/04 08:21P 21P 561379-7824
+"ALMBEACH
+KE WORTH P
+WPALMBEACH FL
+PALMBEACH i
+PALMBEACH i
+WPALMBEACH FL
+STUART FL
+NOOMING
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+ORANGEPARK FL
+DELRAY BCH FL
+DEERFLDBCH FL
+FTLAUDERDL FL
+WPALMBEACH FL
+4 MIN
+769 08/04 08:22P
+770 08/05 11:14A
+(904)264-9844
+771
+08/05 01:37P
+5611715-6303
+772 08/05 01:38P
+(754)367-2371
+773 08/05 01:44P
+08/05 01:58P
+(954)588-8846
+775 08/05 03:01P
+776 08/05 03:24P (561)379-7824
+777 08/05 03:26P
+0343P 561714-5714
+779 08/05 03:46P
+280
+08/05 03:58P
+781
+08/05 04:12P
+782
+08/05 04:33P
+783
+08/05 06:48P (561)792-6375
+784
+08/05 06:53P
+785 08/05 09:59P
+786
+08/06 01:14A (561)379-7824
+787 08/06 12:09P
+(954)435-7760
+789 08/08 12:18P (954)303-7531
+799
+80812-35 361)579-9834
+785 08/08 1237P 773)485-4893
+08/06
+794
+08/06 01:13P
+795
+08/06 05:36F
+796
+08/06 09:09F
+08/06 09:53P
+08/07
+11:03/
+9541588-8846
+1807 11 05A
+800
+561|792-6375
+08/07 11:06A (954)435-7760
+801
+18/07 11:24A (7721219-4743
+802 08/07 12:23P
+803 08/07 01:24P (561)317-5175
+804
+08/07 03:10P
+805 08/07 03:45P
+806
+08/07 04:26P (772)485-4893
+807
+08/07 04:26P
+808 08/07 09:35P (561)379-7824
+08/08
+01:05A
+08/08 09:03A (561)792-6375
+08/08 09:12A
+08/08 09:20A
+02:02P
+(904)264-3903
+03:19P
+08/08
+03:34P
+Onty
+Used Rate Description
+INCLUDED MINUTES
+1 EVT
+MESSAGE RETRIEVAL
+4 MIN
+2 MIN
+INCLUDED MINUTES
+RANGEPARK
+DAI MREAG
+COMING
+COMING
+WPALMBEACH FL
+WPALMBEACH FL
+HOLLYWOOD FL
+INCOMING L FL
+WALMBEACH EL
+TUART E
+WPALMBEACH FL
+TLAUDERDL F
+VPALMBEACH F
+WPALMBEACH FL
+STUART FL
+WPALMBEACH FL
+WPALMBEACH FL
+NCOMING
+DRANGEPARK FL
+NCOMING
+1000 NIGHT/WKEND MIN
+2 MIN
+2 MIN
+2 MIN
+3MIN
+2 MIN
+2 MIN
+3MIN
+2 MIN
+EV
+SINi
+2MIN
+2 MIN
+6 MIN
+6MIN
+2 MIN
+3MIN
+19 MIN
+1 EVT
+4 MIN
+7 MIN
+INCLUDED MINUTES
+INCLUDED MINUTES
+INCLUDED MINUTES
+INCLUDED MINUTES
+1 EVT
+16 MIN
+15 MIN
+6 MIN
+4MN
+2 MIN
+7 MIN
+3MIN
+4 MIN
+2 MIN
+3MIN
+8MIN
+1EVT
+2 NI
+2 MIN
+MIN
+3MIN
+Onty
+Item Date Time Called
+Calls To
+Used Rate Description
+816 08/08 06:53P
+817 08/08 07:01P
+(5611792-6375
+PALMBEACH E
+EMIN
+INCLUDED MINUTES
+VPALMBEACH
+2 MIN
+INCLUDED MINUTES
+818 08/08 10:29P
+ICOMIN
+819 08/08 11:04P (5611719-5911
+/PALMBEACH !
+820 08/08 11:05P
+821
+822
+08/09 12:38A
+561)801-3590
+WPALMBEACI
+561)309-1375
+VPALMBEACH F
+08/09 12:53A
+561801-3590
+VPALMBEACH FL
+2MIN
+823 08/09 12:55A
+(561)719-5911
+WPALMBEACH FL
+824฿
+08/09 01:00A
+825
+08/09 08:44A
+COMIN
+3 MIN
+(PALMBEACH F
+826 08/09 11:36A
+WPALMBEACH FL
+4 MIN
+08/04
+12:52P
+WPALMBEACH FL
+฿28 08/09 02-19P
+829 0809 03:34P
+08/09 03:40P
+(561 801-3590
+WPALMBEACHFL
+2 MIN
+831 08/09 03:45P (772219-4743
+STUART FL
+B32 08/09 03:54P (561714-5714
+833 08/09 03-55P
+1561 379-7824
+PALMBEACH E
+I MIN
+1000 NIGHT/KEND MIN
+1000 NIGHT/WKENB MIN
+IT/KEND MIN
+1000 NIGHT/KEND MIN
+VOLUDED MINUTES IT
+D MINUTE
+INCLUDED MINUTES
+INCLUBEB MINUTES
+CLUDED MINUTE
+I MINUTE
+INCLUDED MINUTES
+CLUDED
+MINUTE
+(PALMBEACH
+3 MIN
+834 08/09 03:56P
+
+60888
+
+39568
+988
+#69200008388
+
+
+9:0880008880908029990553
+754
+244-9110
+
+(56
+11)792
+-63
+PALMREACH FL
+.....
+2 MIN
+2 MIN
+000 NIGH
+INCLUDED
+INCLUDED
+NCLUD
+NCLUD
+NCLUDED
+
+
+
+Item Date Time Called
+877 08/10 09:02P (561)767-0654
+178 08/11 10:58A
+879 08/11 12:04P
+880 08/11 12:07P (561)791-7605
+881 08/11 12:14P
+882 08/11
+07:27P
+883 08/11 07:56P
+884 08/11 07:56P
+885 08/11 07:578
+886 08/11
+07•58P
+887 08/11 08:16P
+(561)317-5175
+(561)784-8778
+(561)541-4382
+714-5714
+561)714-6296
+88 08/110820
+390 08/11 09:10P 561767-6296
+892 08/11 09:11P
+(561)767-0654
+193 08/11 09:20
+104 08/11 09:218
+3/11
+5611315-6303
+561)512-0370
+FE
+(561)767-0654
+1767
+654
+11
+j767-0654
+(561,
+j541-
+-3826
+Calls To
+BOYNTONBCH FL
+NCOMING
+MPALMBEACH FL
+COMIN
+VPALMBEACH F
+WPALMBEACH FL
+WALMBEACH EL
+WPALMBEACH FL
+COMIN
+COMIN
+JOYNTONBCH FI
+NPALMBEACH FI
+BOYNTONBCH FL
+WPALMBEACH FL
+DELRAY BCH FL
+WPALMBEACH FL
+BOYNTONBCH FL
+BOYNTOI
+BOYNTON
+BOYNTON
+BOYNTON!
+SARAIRAM
+EA
+Onty
+Used Rate Description
+SMIN
+000 NIGHT/KEND MIN
+VCLUDED MINUTES
+EMIN
+CLUDED MINUTE
+CLUDED MINUTE
+2 MIN
+INCLUDED MINUTES
+4 MIN
+IMIN
+NCLUDED MINUTES
+NCLUDED MINUTES
+INCLUDED MINUTES
+2 MIN
+CLUBED MINUTE
+CLUDE
+INCLUDED MINUTES
+CLUDED MINUTE
+CLUDED MINUTE
+10DD NIGHT/WKEN!
+000 NIGHT/KEND
+3MIN
+100
+2 MIN
+2MN
+100
+88
+NIGH
+88
+888t
+561)801-3590
+561)791-6375
+08/
+12
+55A
+561
+791-
+912 08/12 03:33P
+BRA
+913 08/12 03:43P
+914 08/12 03:44P
+
+917 08/12 04:39P
+919 08/12 8448P
+SORRESPRE
+920 08/12 05:04P
+(561)784-8778
+822
+5811790-1752
+923
+08/12 05:13P
+924
+08/12
+561|541-4382
+925
+08/12
+0.150
+561
+1351-5190
+926 08/12 05:15P
+156
+561
+1676-5836
+(561)790-0859
+828 08/12 05.378
+(561)985-2667
+929
+08/12 05:39F
+930
+931
+08/12 05:50P
+08/12 06:19P
+(561)541-6152
+0000
+I32 08/12 06:22F
+(561)329-2508
+133 08/12 06:23P
+(561)798-8091
+934 08/12 06:24P
+935 08/12 06:25P (561)329-2508
+NCON
+MPAL
+WPAL
+NCOMING
+WPALMBEACH FL
+VPALMBEACH F
+VPALMBEACH FI
+WPALMBEACH FL
+.......!
+N
+937 08/12 06:31P (561)758-7752
+938 08/12 06:34P
+939
+08/12 06:37P
+(561)784-8778
+940
+08/12 06:39P
+(561)767-0654
+WPALMBEACH FL
+NCOMING
+WPALMBEACH FL
+BOYNTONBCH FL
+1EVT
+2M
+2MIN
+3MIN
+88
+INC
+88
+ČLUDED MINUTI
+INCLUDED MINUTES
+INCLUBED MINUTES
+INCLUDED MINUTES
+INCLUDED MINUTES
+INCLUDED MINUTES
+INCLUDED MINUTES
+LUDED MINUT
+LUDED MINUTI
+CLUBER MINUTE
+NCLUDE
+INCLUDED MINUTES
+INCLUDED MINUTES
+INCLUDED MINUTES
+CAL
+LT
+WAITING
+INCLUDED MINUTES
+INCLUDED MINUTES
+ILL WAITIN
+LUDED MINUTI
+CLUDED MINUTE
+CLUDED MINUT:
+INCLUDED MINUTES
+Item Date Time Called
+342 08/13 06108
+12 06:41P(561/281-116
+43 08/12 06 50P 361798-809
+945 08/12 07:04P (561 281-0170
+946
+08/12 07:08P (561)758-7752
+947
+08/12 07:13P
+Calls To
+LRAY BCH.
+PALMBEACH
+PALMBEACH
+ALMBEACH
+WPALMBEACH FL
+NPALMBEACH FL
+NCOMING
+948
+949
+950
+Onty
+Used Rate Description
+MIr
+MIN
+INCLUBEB MINUTES
+CLUDED MINUTE
+CLUDED MINUTE
+INCLUDED MINUTES
+2 MIN
+CLUDED MINUTE
+2 MIN
+CLUDED MINUTE
+
+
+
+/12 07:16P
+/12
+(561)281-0170
+12 07:
+0Z:24฿
+(561)281-0170
+320-2508
+/12 07:35P
+(561)758-7752
+07:38P 561)329-2508
+07:39P
+:41P
+:42P (561)758-7752
+44P
+29-250
+(561/662-2294
+08:08P
+(561)784-8778
+6368
+08:20P
+541-3828
+(561)541-3826
+08:20P
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+PALMBEACH F
+COMING
+NCOMING
+NPALMBEACH FL
+WPALMBEACH FL
+MPALMBEACH FI
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FI
+WPALMBEACH FL
+967
+08:248
+968
+COMIN
+08:26P
+(5611541-4382
+PALHBEACH
+969
+08/12 08:28P
+(561)389-3470
+WPALMBEACH FL
+970
+08/12 08:59P
+971
+08/13 12:35A (561)792-6375
+373
+10-08A
+WPALMBEACH FL
+974
+18
+113 10-56A
+(904)264-9844
+NCOMING
+DRANGEPARK Fi
+08/13 11:40A (904|264-9844
+ORANGEPARK FL
+975
+976
+08/13 01 34P (861)782-6375
+08/13 01:54P
+WALEASHEE
+878 08/13 00:34F 581782-6375
+979 08/13 10:55P (772/219-4743
+STUART FL
+980 08/14 11:03A (904)264-390:
+981
+08/14 11:04A (904)264-984
+ORANGE ARK FE
+982 08/14 11:49A
+984 08/14 03-58P (561792-6315
+WALMBEACH FL
+985 08/14 06:00P /772/219-4743
+STUART FL
+986
+0B
+987
+V14 0727P (561]714-5/
+VPALMBEACH F.
+/14 07-08P 7661714.57
+NPALMBEACH FI
+TOTAL VOICE USAGE FOR (561)379-7824
+2MIN
+2MIN
+2MIN
+2MIN
+SMIN
+1 EVT
+2MIN
+2MIN
+3MIN
+MIN
+EMIN
+6MIN
+EMIN
+EMIN
+4 MIN
+6MIN
+TEXT/MULTIMEDIA MSGS FOR (561)379-7824
+Item Date
+1 07/17
+cum
+≥ 07/17
+: 07/11
+4 07/18
+5 07/19
+6 07/19
+7 07/19
+8 07/20
+9 07/20
+10 07/20
+Time
+Sent To/Rovd From
+12:49A
+(561)541-3826
+03:08A
+61|317-517
+01:38P
+611889-7100
+09:39A
+561)714-5714
+02:00A
+06:08P
+581)918-3794
+10:43P
+12•10A
+561)714-5714
+09:37P
+714-5714
+561\714-5714
+11:52P
+(561)889-7100
+Charge Description
+100 INCL. MSGS SENT
+100 INCL. MSGS SENT
+• INCL MCGS CE'
+) INCL. MSGS SE
+100 INCL. MSGS SENT
+100 INCL. MSGS SENT
+00 INCL. MSGS SENT
+100 INCL. MSGS SENT
+INCLUDED MINUTES
+LUDED MINUTI
+" LIDEO MINUTI
+INCLUDED MINUTES
+INCLUBEB MINUTES
+LUDED MINUT
+LUDED MINUTI
+INCLUDED MINUTES
+JCLUDED MINUTE
+ICLUDED MINUTE:
+INCLUDED MINUTES
+NCLUDED MINUTES
+NCLUDED MINUTES
+INCLUDED MINUTES
+NCLUDED MINUTES
+JCLUDED MINUTES
+INCLUDED MINUTES
+VAITING
+CLUDED MINUTE
+CLUDED HINUTE
+INCLUDED MINUTES
+1000
+CLUDED MINUTES
+NIGHT/KEND
+MIN
+1000 NIGHT/KEND
+MIN
+1000 NIGHT/WKEND
+1000 NIGHT/KEND
+1000 NIGHT/KEND
+1000 NIGHTWEN
+1000 NIGHT/KEND
+000 NIGHT/WK
+000 NIGHT/KEN
+1000 NIGHT/KEND
+000 NIGHT/WKEN!
+00O NIGHT/KEN,
+1000 NIGHT/KEND
+1.50
+
+
+
+
+
+TEXT/MULTIMEDIA MSGS FOR (561)379-7824 - Continued
+Item Date
+Time
+Sent To/Rcvd From
+11 07/21
+10:24A
+100 INCL. MSGS SENT
+1387/23
+04:42P
+Charge Description
+11-58A
+619714-571
+MULTIMEDIA
+100 INCE MISSS SENT
+14 07/24
+12:28A
+1 OT
+107"
+12:53A
+100 INCL. MSGS SENT
+11:04A
+(561)818-3331
+100 INCE MS SENT
+1887/25
+1348
+561)714-5714
+0-05
+5611714-5714
+11:41A
+(954)552-7581
+100 INEL MSS SENT
+19 07/25
+100 INCL. MSGS SENT
+20 07/25
+19-32P
+9541552-7581
+100 INC
+22 07/29
+10:17P
+561714-5714
+DO INCI
+L. MEGS SENT
+(561)309-1375
+100 INCL. MSGS SENT
+82:53P
+221309-137
+25 07/31
+01:29P
+61)714-0
+11:31A
+(561714-6296
+100 INCL. MSGS SENT
+54 588-884
+54)588-884
+100 INCE MES SENT
+TOTAL TEXT/MULTIMEDIA MSG USAGE FOR (561)379-7824
+0.40
+0.00
+** THIS SPACE INTENTIONALLY LEFT BLANK ***
+2006309.000019295
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/30d2182e44d23564d589d0b1b34cc5f6d5dfb7647cead6716c00b2ab824e002f.receipt.json b/vision-fixhub/ds9-unparsed-06/30d2182e44d23564d589d0b1b34cc5f6d5dfb7647cead6716c00b2ab824e002f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..979272d4ffec237035875c3b5b3492aa87356bcd
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/30d2182e44d23564d589d0b1b34cc5f6d5dfb7647cead6716c00b2ab824e002f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -6477,
+  "dataset": "marble-joined",
+  "doc_id": "30d2182e44d23564d589d0b1b34cc5f6d5dfb7647cead6716c00b2ab824e002f",
+  "engine": "marble-apple-vision",
+  "event_count": 76,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "d4122f10fd45b7c95337c0f038e3442a1ab32894fa131b52148e98c0f27ff6f0",
+  "output_sha256": "9e27710c9804f642d8a7ee6b88b98afef9e14cb70b92b39c5e575e82728b3989",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/313dacdd0d0d7ab1df3db8fb38b0bc80faf17ae05b385179eb43723b3e984cfd.md b/vision-fixhub/ds9-unparsed-06/313dacdd0d0d7ab1df3db8fb38b0bc80faf17ae05b385179eb43723b3e984cfd.md
new file mode 100644
index 0000000000000000000000000000000000000000..1a3e1ef3f76cd4399aac57979d0da332b01aa50c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/313dacdd0d0d7ab1df3db8fb38b0bc80faf17ae05b385179eb43723b3e984cfd.md
@@ -0,0 +1,10 @@
+From:
+To: "brad@pathtojustice.com" < brad@pathtojustice.com>, "RBlack@RoyBlack.com"
+<RBlack@RoyBlack.com>
+Subject: Jane Does _ United States
+Date: Fri, 16 Sep 2011 12:28:35 +0000
+Importance: Normal
+Dear Brad and Roy:
+I was in Bogota for 10 days where my phone didn't work and I had very limited access to email so I have a lot of catching up to do. Do you
+have any objection to a ten day extension of time to respond to Mr Epstein's motion?
+Thank you
diff --git a/vision-fixhub/ds9-unparsed-06/313dacdd0d0d7ab1df3db8fb38b0bc80faf17ae05b385179eb43723b3e984cfd.receipt.json b/vision-fixhub/ds9-unparsed-06/313dacdd0d0d7ab1df3db8fb38b0bc80faf17ae05b385179eb43723b3e984cfd.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..dd25214578e7ed146df22b370a58563ffc3c5b48
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/313dacdd0d0d7ab1df3db8fb38b0bc80faf17ae05b385179eb43723b3e984cfd.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "313dacdd0d0d7ab1df3db8fb38b0bc80faf17ae05b385179eb43723b3e984cfd",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "4c72f64e4c0c36e2dabfb302923f76fa88e4a92fef1e18eb527cacc474f07923",
+  "output_sha256": "efeaecce017ad7c2d3242b9ead88fb0e8215181b7336ef8459c167f2352e1ac7",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/314e6394c5aafc274dfd6d32b0558d9272a55c40d07413e56616a4cffbfa8243.md b/vision-fixhub/ds9-unparsed-06/314e6394c5aafc274dfd6d32b0558d9272a55c40d07413e56616a4cffbfa8243.md
new file mode 100644
index 0000000000000000000000000000000000000000..622e29d0060d1f7280c655bb832a42100164d424
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/314e6394c5aafc274dfd6d32b0558d9272a55c40d07413e56616a4cffbfa8243.md
@@ -0,0 +1,1517 @@
+Questions or Changes?
+cingular.com
+• Toll Free 1 866 293-4634
+:
+611 from your wireless phone
+TTY users - 1 866 429-7TTY
+SUMMARY OF MONTHLY CHARGES FOR ACCOUNT 0035224228
+Previous
+Balance
+0.30
+Payments
+Received
+-66.54
+Late Payment
+0.00
+Account
+Adjustments
+0.00
+Your billing cycle began on March 12, 2005 and ended on April 11, 2005
+Current Monthly Charges
+Subscriber Adjustments
+Monthly Service
+Monthly Usage
+Charges
+Credits
+Government Fees and Taxes
+Total Current Monthly Charges
+TOTAL AMOUNT - Due Upon Receipt
+Date of Invoice: April 12, 2005
+Balanc
+Forwaro
+-66.24
+Current Monthly
+Charges
+66.82
+Total
+Amount Due
+0.58
+0.00
+0.00
+54.56
+0.00
+0.00
+12.26
+66.82
+0.58
+ATTENTION: OUR WEBSITE ADDRESSES ARE CHANGING
+ON APRIL 26, ATTWIRELESS.COM CHANGES TO CINGULAR.COM
+ONLINE ACCESS TO SERVICES, INCLUDING ONLINE CUSTOMER
+SUPPORT, CAN NOW BE FOUND AT CINGULAR.COM
+AFTER APRIL 26, THE ATTWIRELESS.COM ADDRESS WILL NO
+LONGER WORK. PLEASE REMEMBER TO RESET YOUR PERSONAL
+BOOKMARKS.
+cingular
+Account Name: |
+#BWNHNGB
+#0000000352242283# w
+.S.01.01.1011.0000
+lease Return This Portion With Your Paymer
+Ise of service or payment of this invoic
+indicates contions for wireles seracterms
+Note:
+We Print on
+Front and Back
+Service # 5613080282
+Account # 0035224228
+Yes ataly deducted from he auto my eised check
+(see reverse - signature required).
+Crackles for chaise.
+Date Due
+UPON RECEIPT
+Total
+Amount Due
+0.58
+Amount
+Paid
+Allahabadhoodoodloodoodollobod
+CINGULAR WIRELESS
+PO BOX 8229
+AURORA IL 60572-8229
+
+
+
+Recurring Electronic Fund Transfer (REFT): To enroll: sign below, check the REFT box on the reverse side and
+remit with this month's payment. Keep paying your bill until your statement indicates "Do Not Pay". REFT
+Agreement: I authorize my financial institution to deduct the amount of my monthly wireless phone bill from the
+account associated with the enclosed check and remit payment to Cingular Wireless. This authority will be effective
+until i notity Cingular vireless to terminate it. Tagree that I may be assessed a service charge (up to $z0) or late
+fee or both if a payment is returned by my bank. For more information visit cingular.com/myaccount or call 1 866
+293-4634. Please keep a copy of the form below and this REFT Agreement for your records or retain a copy of the
+blank form from next month's invoice.
+Questions? We can help: Cingular Wireless appreciates your business and welcomes the opportunity to assist
+you. Visit our website at cingular.com or contact Customer Care by dialing 611 from your wireless phone or 1 866
+293-4634. ¿Sabias que también ofrecemos servicio al cliente en tu idioma? Marca 611 desde tu teléfono
+inalámbrico ó 1 866 293 4634 desde cualquier teléfono y oprime el *.
+Driving Wireless Safety: Your wireless phone gives you the freedom and flexibility to stay in touch when you
+travel, but don't let a phone call distract you from driving safely. Use hands-free device if allowed or required by
+law. Call Carefully, Arrive Safely.
+Cingular Wireless Processing Fees: Accounts suspended for non-payment will be subject to a $25 reactivation
+fee per line and may be assessed a security deposit prior to reinstatement. Checks returned for non-sufficient funds
+will be charged up to a $30.00 fee.
+Local Tax: Local taxes are based on local government boundaries, the address information you provide for your
+account and/or your wireless telephone number. Please review the local tax charges on your bill. If you believe
+there is an error in the local tax charge, please contact us immediately at 1 866 293-4634. Please note that some
+local or state laws may require you to follow special procedures when notifying us about a local tax dispute. You
+may also use the form below to notify us of any change to your taxing address. Thank you for your cooperation.
+Early Termination Fee (ETF): If you cancel service before your contract end date (including if you switch your
+wireless number to another carrier), you will be charged an Early Termination Fee of up to $200.
+Please Send Correspondence To:
+Cingular Wireless Next Generation Correspondence
+P.O. Box 68056
+Anaheim Hills, CA 92817-8056
+0.000016403.4
+count ame and ranse an espress clearly and check the box on the reverse side. Please contact Customer Care to change the
+New Billing Address
+City
+State
+Zip
+Home Phone (
+Work Phone (.
+If your billing address is NOT your Tax Address, please enter the Tax Address below. (Multi-line accounts should attach a list of each wireless number
+and the respective Tax Address.)
+New Tax Address
+City
+Wireless Number (.
+State
+Zip
+Recurring Electronic Fund Transfer (REFT) Enrollment. Please read the agreement on the top portion of this page, sign below and check
+the "REFT Registration" box on the reverse side
+Financial Account Holder Signature
+• • I do not wish to receive email notification of special offers avalable to Cingular Wireless customers.
+
+
+* cingular
+raising the bar
+
+IMPORTANT INFORMATION FOR OUR SPANISH-SPEAKING
+CUSTOMERS:
+DESEA RECIBIR SU CUENTA EN ESPANOL? LLAMA AL 611 Y
+MARQUE EL 2 PARA HABLAR CON UNA OPERADORA EN ESPANOL.
+TRANSLATION: "WOULD YOU LIKE TO RECEIVE YOUR BILL IN
+SPANISH? DIAL 611 AND PRESS 2 TO SPEAK WITH A CUSTOMER
+CARE REPRESENTATIVE IN SPANISH."
+ACCOUNT DETAILS
+Detail of Payments - Thank You!
+Item Description
+1 PAYMENT
+Date Applied/Reversed Payment Amount
+03/18/05
+-66.54
+Total of Payments
+Detail of Account Government Fees and Taxes
+Item Description
+1 FEDERAL TAX
+2 LOCAL COMM SERVICE TAX
+3 STATE COMM SERVICE TAX
+4 *UNIVERSAL CONNECTIVITY CHARGE
+5 911 SURCHARGE
+Total Account Government Fees and Taxes
+* This is not a tax or goverment required charge, it is a fee assessed on telecommunications carriers.
+Current Subscriber Monthly Charges and Credits
+Subscriber Number
+Subscriber Name
+
+Total Current Subscriber Monthly Charges and Credits
+Total Current Monthly Charges
+SUMMARY OF CURRENT ACTIVITY
+FOR (561)308-0282
+Monthly Service Charges
+Item Description
+1 CALL WAITING
+2 CALLER ID
+3 GO PHONE $53.98 REPLENISHMENT
+4 THREE WAY CALLING
+Service Dates
+03/12/05 - 04/11/05
+03/12/05 - 04/11/05
+03/12/05 - 04/11/05
+03/12/05 - 04/11/05
+-66.54
+-66.54
+1.70
+3.27
+5.13
+1.66
+0.50
+12.26
+54.56
+54.56
+66.82
+0.00
+0.00
+0.00
+0.00
+
+SUMMARY OF CURRENT ACTIVITY - CONTINUED
+Monthly Service Charges - Continued
+Item Description
+Service Dates
+5 GO PHONE UNLIMITED NIGHTS AND WEEKENDS 03/12/05 - 04/11/05
+6 DETAIL BILLING
+03/12/05 - 04/11/05
+Total Monthly Service Charges
+Monthly Usage Charges
+Item Description
+1 UNLIMITED N/WKND MIN
+2 MESSAGE RETRIEVAL
+3 TEXT MESSAGES SENT
+4 AIRTIME MINUTES
+5 CALL WAITING
+6 MMODE/DATA USAGE
+anty Used
+851 MIN
+27 EVT
+15 EVT
+586 MIN
+12 EVT
+32 KB
+Total Monthly Usage Charges
+1,024 Kilobytes (KB) = 1 Megabyte (MB)
+TOTAL CHARGES FOR (561)308-0282
+DETAIL OF CURRENT ACTIVITY
+VOICE USAGE FOR (561)308-0282
+Item Date Time Called
+1 03/19 11:46A (561)308-0282
+2 03/19 11:47A (561)308-0282
+Calls To
+3 03/19 11:50A
+5 03/19 08:06P (581)813-3318
+6 03/19 03:12P
+
+(561)313-6730
+9 03/19 03:32P
+561793-7710
+(561)644-2611
+10 03/19 09:53P (561)308-0282
+11 03/19 09:54P (561)308-0282
+12 03/19 09:59P
+14 03/19 10:06P
+561)313-673
+754 235-482
+15 03/19 10:15P
+(561)635-3454
+16031020 1313348
+03/19 11:50P
+(561)452-8865
+18 03/19 11:54P (561)723-8559
+9 03/20 01:10A
+20
+21
+3/20 03-58A (561)452-886
+03/20 03:58A (561)452-8865
+03/20
+) 04:01A
+(561)452-8865
+13/20 04:02A
+(561|452-8865
+03/20 04:03A
+561 723-855
+03/20 04:04A
+26
+5611452-886
+03/20 04:08A
+(561)452-8865
+/20 04:10A
+20 04:15A
+03/20 04:19A
+452-8865
+03/20 04:41A
+(561)452-8865
+Onty
+Used Rate Description
+INLIMITED N/WKND MIr
+TESSAGI
+RETRIEVAL
+0.00
+0.00
+0.00
+0.00
+0.00
+1.50
+52.74
+0.00
+0.32
+54.56
+54.56
+
+
+0.000016404
+Item Date Time Called
+31 03/20 12:20P
+32 03/20 12:48P
+3 08/20 81300
+35 03/20 02:35P
+03/20 02:36P
+(561)313-6730
+561 793-7719
+03/20 03:10P
+561 452-8865
+38
+03/20 03:28P
+39 03/20 03:41P
+(561)635-3454
+40 03/20 05:26P
+561)798-3650
+13/20 05:261
+561 632-3454
+2 03/20 05:27P
+5611317-3348
+43฿
+3 20 05:30-
+13/20 0:
+:31P
+(561 723-7753
+1644-2611
+45 03/20 05:32P
+(561)723-7752
+16 03/20 05:34P
+561346-1086
+20 05:36P
+561 313-6730
+
+515-3054
+1561
+B965
+89988
+(6561)
+1)723
+1635
+рід і0
+07 02 02
+888
+0 0702
+(561)635-3454
+го сро
+(561)313-6730
+(561)313-6730
+0003 02 02 02 02
+(561)
+CO CC
+Onty
+Calls To
+Used Rate Description
+INCOMING
+2 MIN
+UNLIMITED
+N/WKND
+INCOMING
+2MIN
+UNLIMITED N/WKND
+INCOMING
+NC
+OMING
+2MIN
+INLIMITED N/WKN!
+INLIMITED N/WKNO
+LAKE WORTH FL
+UNLIMITED N/WKND
+JNLIMITED N/WKNI
+9MIN
+INUIMITED N/WKNI
+UNLIMITED N/WKND
+LEVI
+MESSAGE RETRI
+UNLIMITED N/WKND
+MEALMBEACH E
+LIMITED NWKA
+WPALMB
+3 MIN
+LIMITED N/WKN
+VPALMBEACH F
+(PALMBEAC
+2 MIN
+UNAMITE AMANE
+2 MIN
+UNLIMITI
+N/WKND
+UNLIMITED N/WKND
+10 MIN
+UNLIMITER
+
+
+
+
+Item Date Time Called
+Calls To
+96 03/21 02:15P (561)308-0282
+97 03/21 02:16P (561)635-3454
+98 03/21 02:32P
+99
+03/21
+02:32P
+(561)793-7719
+561313-6730
+100฿
+0321
+02-33P
+101 03/21 03:58P
+561793-7719
+102
+103
+03,21
+05:42P
+3/21
+06:19P
+104 03/21 06:31P
+(561)635-3454
+105
+106
+13/27
+06:34P
+107
+108
+03/21 87:29P
+109
+2E80088959979999980000089
+
+21
+29P
+07:30P
+(561)333-0180
+(561)252-4753
+561252-4753
+5611313-6730
+602
+(561)602-9566
+888
+88
+88
+2
+3888
+2000
+H538
+88
+88
+(561)
+10317-
+-3348
+(561)
+1635-3454
+39988
+561
+793
+-7719
+AKE WORTH F
+VPALMBEACH FL
+INCOMING
+INCOMING
+COMING
+COMINI
+COMING
+MPALMBEACH FI
+NPALMBEACH FL
+Qnty
+Used Rate Description
+1EVT
+CALL WAITING
+1 MIN 0.09 AIRTIME MINUTES
+ZEN 0.09 AIRTAS METE MAL
+0.09 AIRTIME MINUTES
+1 MIN 0.09 AIRTIME MINUTES
+4 MIN
+0.09 AIRTIME MINUTES
+3MIN
+0.09 AIRTIME MINUTES
+MIN 00 AIRTIME MINUTES
+1 MIN O AIRTIME MINUTES
+0.09 AIRTIME MINUTES
+0.09 AIRTIME MINUTES
+0000000000dgg00o
+0oóddddd0000c
+
+1 M
+1EV
+MINUTES
+MESSAGE RETRIEVAL
+0.09 AIRTIME MINUTES
+0.63
+0.36
+1.18
+1.00
+0.27
+0.00
+
+88898888985-838
+
+
+
+
+Onty
+Item Date Time
+Called
+Calls To
+Used
+Rate Description
+159 03/23 06:54P
+(561)313-6730
+LAKE WORTH FL
+0.09 AIRTIME MINUTES
+160 03/23 06:55P
+561)313-6730
+LAKE WORTH FL
+61 03/23 08:37
+561)313-6730
+LAKE WORTH FL
+2MIN
+0.09 AIRTIME MINUTES
+62 03 23 09:03
+NCÕMING
+2MIN 009 ANLIMTED NWEND MIN
+163 03/23 09:06P (561)317-3348
+164 03/23 09:06P
+INCOMING
+3MIN
+UNLIMITED N/WKND MIN
+INLIMITED N/WKND MIN
+'ALL WAITING
+165 03/23 09:16P
+(561)635-3454
+UNLIMITED N/WKND MIN
+187 03/23 09:36₽
+(561635-3454
+JNLIMITED N/WKND MIN
+INCOMING
+16MIN
+168
+1MIN
+JNLIMITED N/WKND MIN
+168 03/23 09:46P (561)313-6730
+LAKE WORTH FL
+UNLIMITED N/WKND MIN
+03/23 10:44F
+0:441
+(561)313-6730
+LAKE WORTH FL
+INCOMING
+172 03/24 19:334
+18 MIN
+561)317-3348
+NCOMINC
+NPALMBEACH FL
+19 MIN
+COS ARTEMINES
+173 03/24 02:15P
+(561\602-9566
+LAKE WORTH FL
+7MIN
+0.09 AIRTIME MINUTES
+133 03/24 02.37P
+561313-6730
+5611644-2611
+AKE
+MPALMBEACH FL
+19 AIRLIME MINUL
+2MIN
+176 03/24 02:42P
+INCOMING
+1MIN
+177 03/24 09:54P (561)308-0282
+1 EVT
+178 03/24 09:56P (561)313-6730
+LAKE WORTH FL
+03/24 10:00P
+(561
+317-3348
+VPALMBEACH r
+03/24 10:04P
+561)718-5794
+VPALMBEACH F
+NOOMING
+10:06P
+NOON
+03/24 10:09P (561)313-6730
+LAKE WORTH FL
+2MIN
+10:13P
+NOOMING
+OMING
+2MIN
+186
+03/24 10:17P
+INCOMING
+2 MIN
+187
+188 03
+83/24 19:12P
+5611313-6730
+611313-6730
+LAKE WORTH FL
+189 03/24 11:45P
+INCOMING
+189 83/25 02:03A (561)313-6730
+LAKE WORTH FL
+192 03/25 02:37A
+(561)702-9357
+OMING
+4 MIN
+DELRAY BCH FL
+03/25 02:38A
+(561)702-9357
+M
+03/25 02:45A
+195 03/25 02:50A
+INCOMING
+196 03/25 02:51A
+INCOMING
+2MIN
+197 03/25 02:54A
+(561)452-8865
+EMIN
+198 03/25 03:00A
+(561j635-3454
+6MIN
+199 03/25 03:17A
+(561\308-0282
+200 03/25 10:58A (561\602-9566
+LAKE WORTH FL
+
+10:59A
+(561)543-9076
+11:01A
+INCOMING
+1:414
+1:43/
+COMINI
+38MIN
+2 MIN
+11:44A
+'561670-6828
+VPALMBEACH F
+TMIN
+561)702-9357
+11:52A
+DELRAY BCH FL
+NCOMING
+12:06P
+NCOMING
+12:07P
+3MIN
+INCOMING
+SMIN
+0:09 AIRTIME
+0.09 AIRTIME
+.09 AIRTIM
+.09 AIRTIM
+0.09 AIRTIME
+1 EV
+209 03/25 12:25P
+210
+03
+561)670-6828
+WPALMBEACH
+
+12:27P
+5611635-3454
+WPALMBEA
+:01:15P
+1670-6828
+WPALME
+01:20P
+WPALME
+02:23P
+5611798-7979
+(561)723-7752
+161452-886
+WALM
+02:28P
+02:45P
+61313-673
+WI
+WPALM
+77
+WPALME
+5611670-6928
+WPALM
+
+252
+4 MIN
+
+09
+09
+1:52
+0.63
+
+
+Item Date Time
+Called
+219 03/25 03:03P (561)333-0180
+220 03/25 03:05P (561333-0180
+222 03/23 88:09P 561)333-0130
+03.
+/25
+03:13P
+(561)333-0180
+03/25 03:22P (561)670-6828
+03/25 03:37P
+03/25 03:51P (561)798-3650
+032508-530
+(561)635-3454
+(5611670-6828
+03/25 03:58P
+03/25 04:01P (581/662-3184
+03/23 04:078
+03/25 05:02P (561)452-8865
+05:52P
+561)317-3348
+Calls To
+PALMBEACH !
+PALMBEACH i
+INCOMING
+NCOMING
+PALMBEACH F
+/PALMBEACH F
+INCOMING
+IPALMBEACH F
+UPITER F
+COMING
+ICOMINI
+06:02P 5611452-8866
+Onty
+Used Rate Description
+1 MIN 0.09 AIRTIME MINUTES
+1 MIN 0.09 AIRTIME MINUTES
+EMIN 8:09 AIRTIME MINUTES
+2MIN
+0.09 AIRTIME MINUTES
+MIl
+0.09 AIRTIME MINUTE
+109 AIRTIME MINUTE
+1 MIN 0.09 AIRTIME MINUTES
+2MIN
+.09 AIRTIME MINUTE
+09 AIRTIME MINUTE
+0.09 AIRTIME MINUTES
+O.O9 AIRTIME MINUTES
+09 AIRLIME MINUTE
+09 AIRTIME MINUTE
+2 MIN
+0.09 AIRTIME MINUTES
+2 MIN
+2 MIN
+AIRTIME
+MINUTE
+09 AIRTIME
+
+8.18
+8:18
+18
+88990
+9999 NEED
+
+- 3758
+(561)31
+13-67
+
+(561)793-9291
+ALN
+98 88 99008
+
+
+
+Onty
+Item Date Time
+Called
+Calls To
+Used
+Rate Description
+283 03/27 02:05A
+(561)601-6113
+LAKE WORTH FL
+2 MIN
+UNLIMITED N/WKND MIN
+284 03/27 02:12A (561|601-6113
+LAKE WORTH FL
+2 MIN
+UNLIMITED N/WKND MIN
+286 03/27 82 35A
+02-35A
+JCOM NO
+JNLIMITED N/WKND ML
+ICOM NO
+INLIMITED N/WKND MIT
+287
+03/27 03:31A
+288
+(561)313-6730
+LAKE WORTH FL
+UNLIMITED N/WKND MIN
+13/21
+03:31A
+5611313-6730
+289
+13/27 03:31A
+611262-6186
+AKE WORTH F
+MIl
+IPITER A
+UNLIMITED WIND MIN
+290
+03/27 03:32A
+561)313-6730
+291
+LAKE WORTH FL
+UNLIMITED N/WKND MIN
+03/27 11:35A (561)308-0282
+SSAGE RETRIEVA
+03/27 11:36A
+(561)601-6113
+LAKE WORTH FL
+UNLIMITED N/WKND MIN
+13
+11:37A (561)313-6730
+03
+11:42A
+LAKE WORTH FL
+• MIN
+NLIMITED NWKND M.
+HEASA
+61313-6730
+LAKE WORTH FL
+I MIN
+ROP CALL CRED
+3806-886
+6186
+JOKE WORTH FL
+LIMITED N/WKND M
+JUPITER
+LIMITED N/WKND M
+11:44A
+(561)723-7752
+4 MIN
+UNLIMITED
+N/WKND
+4:08P (561)635-345
+3 MIN
+UNLIMITED N/WKND
+04:
+04:
+07:
+36181-2619
+561
+1,31
+3-6730
+ANGE
+IN
+(561)644-2611
+!!!!!!!!!!
+(561)333-0180
+(36 1)
+635-3454
+313-6730
+oc c
+(561)262-6186
+(561)313-6730
+88
+
+N/WKND MIN
+8888 0008880
+
+
+Item Date Time Called
+348 03/29 09:14P (561)793-7719
+349 03/29 09:14P
+(561)313-6730
+351 03/29 10:11P
+561262-6186
+16/29 10:11 P
+561 644-2611
+352 03/29 10:13P
+353
+03/29 10:19P
+354|
+03/29 10:29P
+51313-673
+51635-341
+355 03/29 10:31P
+Calls To
+LAKE WORTH FL
+PITER
+DALMBEACH P
+INCOMING
+KE WORTH.
+ALMBEACH
+INCOMING
+359
+08/29 10-188
+358
+10:48P
+03/29 10:51P
+88/29 11:18P (954)687-3797
+08/30 0322A
+30 03:21A (954)687-3797
+03/30 03:21A
+(954)687-3797
+INCOMING
+FTLAUDERDL FL
+NCOMING
+INCOMING
+TLAUDERDL FL
+FTLAUDERDL FL
+WPALMBEACH F
+CH
+
+/30
+D4:03A
+
+04:04A
+581723-7759
+89998
+(407
+JP
+381
+03/30 02:13P
+(561
+)308-0282
+
+
+
+JEW YORK N
+MPAI MREACH
+-0-7
+FL
+MIl
+2 MIN
+
+
+
+(561)723-8559
+400 03/30 10:57P (561)308-0282
+WPALMBEACH FI
+NCOMING
+INCOMING
+INCOMING
+INCOMING
+SMIN
+
+(561)346-1086
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+Qnty
+Used Rate Description
+UNLIMITED N/WKND MIN
+2 MIN
+UNLIMITED N/WKND MIN
+2MIN
+UNLIMITED N/WKND MIN
+2MIN
+UNLIMIT
+ED NWKND MIN
+UNLIMITED N/WKND MIN
+EMIN
+UNLIMITED NAWKND MIN
+UNLIMITED NAWKND MIN
+2MIN
+UNLIMITED N/WKND MIN
+UNLIMITEB NAWKNE MIN
+ED N/WKND MIN
+UNLIMITED N/WKND MIN
+UNLIMITED NAWAND MIN
+INLIMITED N/WKND MIN
+UNLIMITED WANNIN
+JNLIMI
+UNLIMITED N/WKND MIN
+UNLIMITED N/WEND MIN
+2MIN
+3 MIN
+I MIN
+00000
+AWKND HIN
+CRED
+MESSAGE
+2 MIN
+2 MIN
+2 MIN
+2 MIN
+0.0
+AIRTIME MINUTES
+MINUTES
+| AIRTIME
+MINUTE
+0.09 AIRTIME MINUTE
+0.09 AIRTIME MINUTES
+00000
+88888
+0.27
+8:27
+8.38
+8.72
+8:98
+18
+dod
+-18
+.18
+
+
+Called
+Onty
+Used
+Item Date Time
+408 03/31 10:52A
+400 03/31 11:03A (561)358-5947
+410 03/31
+03/31 11:21A (561)358-5947
+112
+413฿
+
+414
+03/31 11:42A
+29P (561)254-6039
+417 03/31 01:56P
+419 03/31 81:52P (861)352-5603
+420
+12
+03/31 02:38P (561)282-7592
+422
+03:05P
+03:11P
+04:17P
+04:24P
+04:26P
+05:07P
+05:09P (561)317-2143
+:17P
+:42P
+(561)333-0225
+:07P
+:25P
+06:25P
+(561)635-3454
+435
+03/31 07:06P
+03/
+
+-3348
+(561)358-5947
+7P
+
+888888õ9
+8822888-
+
+1578-
+-8282
+: (561)574-8714
+
+Calls To
+INCOMING
+Rate Description
+1 MIN 0.09 AIRTIME MINUTES
+CALL WAITING
+COMING
+INCOMING
+NCOMING
+NCOMING
+NCOMINC
+NPALMBEACH FI
+INCOMING
+PALMBE
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+NCOMING
+WPALMBEACH |
+INCOMIN
+FL
+INCOMING
+NCOMING
+INCOMING
+JAMAICA/II
+LAKE
+WPALMBE
+INCOMING
+2 MIN
+2 MIN
+3 MIN
+2 MIN
+0.09 AIRTIME MINUTES
+0.09 AIRTIME MINUTES
+0.09 AIRTIME MINUTES
+0.09 AIRTIME MINUTES
+DO AIRTIME MINUTES
+8.09 AIRTIME MINUTES
+AIRTIME MINUTES
+TIME MINUT
+88888888888888_
+UNLIM
+ПІВНИ
+
+8.18
+118
+0.
+18
+0.27
+0.09)
+
+8038NA 800881
+0.
+
+8b888088888888
+88
+
+
+Item Date Time Called
+470 04/01 07:19P (561)655-7629
+471 04/01 07:20P (561)308-0282
+472 04/01 07:21P (561)317-2143
+473 04/01 07:25P (561)317-2143
+175 04/81 10:09P
+04/81 10:09P 881313-6738
+476 04/01 10:10P (561)333-0225
+173 04/01 10:128 561592-3736
+479 04/01 10:12P (561)317-3348
+481 04/81 10:35P (561)602-9566
+483 04/01 10:43Р (561)798-7979
+484 04/01 11:53P
+485
+486
+04/02 12.06A 581602-3318
+Calls To
+AKE WORTH E
+AKE WORT
+LAKE WORTH FL
+AKE WORTH F
+COMING
+WALMBEACH FL
+INCOMING
+FL
+Onty
+Used Rate Description
+1 MIN 0.09 AIRTIME MINUTES
+1 MIN 0.09 AIRTIME MINUTES
+0.0g AIRTIME NETEEVAL
+0.09 AIRTIME MINUTES
+UNLIMITEB NAWNB MIN
+JAWKND MIN
+UNLIMITED N/WKND MIN
+UNLIMITED WIND MIN
+UNLIMITED N/WKND MIN
+INLIMITED NAWIND MIF
+NAWKND MIN
+NAWKND I
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND
+: 12:08A
+I MIN
+IMIN
+3MIN
+3 MIN
+2 MIN
+3MIN
+2MIN
+3MIN
+SS888888
+
+82888888999N88999
+83880808443002B33B83
+561)313-6730
+561.
+313-67
+(561)313-6730
+(561)723-7752
+25.
+222
+(861)
+208-
+00g.
+88
+38
+88
+(786)473-3267
+ME
+AP
+ND
+
+(561)
+)308-0282
+2MIN
+1 EVT
+MES
+G
+RET
+IN
+0.000016406
+
+
+raising the bar
+
+Item Date Time
+Called
+530 04/03 12:57A (561)644-4783
+531 04/03 04:19A (561|644-2611
+533 04/08 01:238
+Calls To
+INCOMING
+MPALMBEACH FL
+14/03 01:276
+14/03 01-298
+536
+(581122:2002
+04/03 01:31P
+561)798-7979
+533
+
+611723-775.
+61635-345
+04/03
+04/03
+39P
+(561)313-6730
+02-32P
+04/03 02:38P
+02-39P
+5611602-9566
+02-40P
+561 602-9566
+04/03 02:41P
+1/00
+(561)313-6730
+3:131
+(561)635-3454
+NPALMBEACH EL
+NPALMBEACH
+MPALMBEACH
+LAKE WORTH FL
+INCOMING
+K- WORTH
+KE WORT
+LAKE WORTH FL
+3-46
+gigi
+co Co
+
+
+(5611833-8111
+(561 317-3348
+(561)317-
+561)
+21
+3348
+13-6730
+спіл слоі
+сто слів сліді
+(56
+(561
+NOOI
+WP
+Onty
+Used Rate Description
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND MIN
+2 MIN
+UNLIMITED NOW MIN
+1 EVT
+MESSAGE RETRIEVAL
+UNLIMITED N/WKND MIN
+INLIMITED N/WKND MIN
+6 MIN
+UNLIMITED N/WKND MIN
+ED N/WKN
+22!
+6 MIN
+UNLIMITED NAWKNE
+UNLIMITE
+) N/WKND
+UNLIMITED N/WKND
+INLIMITED NIWKN
+NLIMITED N/WKN
+4 MIN
+UNLIMITED N/WKND
+UNLIMITED N/WKND
+2 MIN
+UNLIMITED N/WKND
+UNLIMITED N/WKND MIN
+INLIMITED N/WKND MI
+NLIMITED
+• N/WKND
+I MIN
+UNLIMITED N/WKND MIN
+22
+UNLIMITED MAKE MIN
+UNLIMITED N/WKND MIN
+MESSAGE RETRIEVA!
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND MIN
+NLIMITED N/WKND M
+NLIMITED N/WKND M
+UNLIMITED N/WKND MIN
+UNLIMITED WIND MIN
+IN
+.09 AIRTIME MINUTES
+0S AIRTIME MINUTES
+09 AIRTIME MINUTES
+9 AIRTIME MINUTE
+9 AIRTIME MINUTE
+09 AIRTIME MINUTES
+•O AIRTIME MINUTES
+.09 AIRTIME MINUTES
+88
+| AIRTIME MINUTE
+AIRTIME MINUTE
+•O AIRTIME MINUTES
+.09 AIRTIME MINUTES
+9 AIRTIME MINUTE
+19 AIRTIME MINUTE
+90*9L00000
+584
+04/04
+08:18P
+88
+8888
+3888
+8888
+-3348
+1500-
+- 3282
+02 0202 00
+=888
+INCOMING
+WP
+.09 AIRTIME MINUTES
+0.09 AIRSSAGE NETRIEVAL
+0.09 AIRTIME MINUTES
+ILL WAITIN
+AIRTIME MINUT
+.09 AIRTIME MINUTE
+ESSAGE RETRIEVI
+.09 AIRTIME MINUTES
+000
+381
+AIRTIME MINUTES
+09 AIRTIME MINUTES
+09 AIRTIME MINUTES
+0.45
+8.08
+
+.18
+
+0.27
+0.27
+0.45
+Item Date Time Called
+Calls To
+591 04/04 09:01P (561)313-6730
+LAKE WORTH FL
+599 04/04 09:10P
+KE WORTH
+KE WORTH
+594 04/04 09:14P (561|833-8111
+NPALMBEACH FI
+595 04/04 10:03P (561)308-0282
+NPALMBEACH FL
+596 04/04 10:36P
+INCOMING
+597 04/04 10:45P
+598 04/04 1016P (603 321:2939
+'HOENIX AL
+JASHUA NH
+599 04/04 10:47P (603)321-2939
+NASHUA NH
+600 04/04 10:50P
+NCOMING
+601 04/04 11:21P (603)321-2939
+NASHUA NH
+602 04041139P 561/346-1086
+WPALMBEACHFL
+04/04 11:32P
+INCOMING
+05
+04/04 11:46P
+COMING
+04/05 01 21A
+ICOMINI
+607 04/05 01:38A
+INCOMING
+608 04/05 11:48A
+11798-791
+PALMBEACH I
+609 04/05 02:59P
+51)30B-02
+PALMBEACH
+10 0005 :90
+61)723-77
+4/05 03:33
+11313-67
+
+5611262-618
+04/05
+561j262-618
+614 04/05 03:43P (561)543-3802
+JUPITER FL
+615 04/05 03:54F
+16 04/05 04:10P (5611635-3454
+617 04/05 04:14P (561/262-6186
+JUPITER FL
+TOTAL VOICE USAGE FOR (561)308-0282
+Qnty
+Used
+Rate Description
+2 MIN
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND MIN
+NLIMITED N/WKND MI
+NLIMITED NAWKND MI
+UNLIMITED N/WKND MIN
+INLIMITED NWKND MIR
+MESSAGE RETRIEVAl
+UNLIMITED N/WKND MIN
+LIMITED WINE MIN
+TED N/WKND MIN
+3 MIN
+UNLIMITED N/WKND MIN
+3MIN
+UNLIMITED NIWKND MIN
+3MIN
+UNLIMITED N/WKND MIN
+INLIMITED NWKND MIr
+INLIMITED NAWKND MIN
+2 MIN
+UNLIMITED N/WKND MIN
+I MIN
+UNLIMITED WEND MIN
+INLIMITED NIWKND MIN
+UNLIMITED N/WKND MIN
+MIN THE MINUTES
+1 EVT
+MESSAGE RETRIEVAL
+IMIN
+1 0.0S AIRTIME MINUTES
+1MIN
+COS AIRTIME MINUTES
+3MIN
+0.09 AIRTIME MINUTES
+EMIN
+9 AIRTIME MINUT!
+9 AIRTIME MINUTI
+0.09 AIRTIME MINUTES
+DATA USAGE FOR (561)308-0282
+Item Date
+Onty Used
+1 03/25
+28 KB
+2 03/26
+4 KB
+TOTAL DATA USAGE FOR (561)308-0282
+Charge Description
+MMODE/DATA USAGE
+MMODE/DATA USAGE
+TEXT/MULTIMEDIA MSGS FOR (561)308-0282
+Item Date
+2 08/21
+a co
+, 03/2
+10202
+5 03/29
+5, 08,29
+Time
+Sent To/Revd From
+06:07A
+06028
+06:07P
+581313-3348
+O6•0OP
+
+06:03P
+06:04P
+06:13P
+19611543-9076
+06:21P
+(561 543-9076
+02:25A
+561 543-9076
+10:31A
+561 601-611:
+11 03/31
+12 03/3
+14 04/03
+15 04/04
+12:23P
+12:24P
+11•06P
+11:29P
+(561)876-2208
+08:12P
+TOTAL TEXT/MULTIMEDIA MSG USAGE FOR (561)308-0282
+Charge Description
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+
+9.09
+0.27
+8.18
+52.74
+0.28
+0.32
+8:18
+0.10
+010
+0.10
+0.10
+00
+0.10
+0.10
+0.10
+1.50
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/314e6394c5aafc274dfd6d32b0558d9272a55c40d07413e56616a4cffbfa8243.receipt.json b/vision-fixhub/ds9-unparsed-06/314e6394c5aafc274dfd6d32b0558d9272a55c40d07413e56616a4cffbfa8243.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..16e71ab8b61382136d2b7b3321f03849ad411e3e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/314e6394c5aafc274dfd6d32b0558d9272a55c40d07413e56616a4cffbfa8243.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -4332,
+  "dataset": "marble-joined",
+  "doc_id": "314e6394c5aafc274dfd6d32b0558d9272a55c40d07413e56616a4cffbfa8243",
+  "engine": "marble-apple-vision",
+  "event_count": 67,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "720814882b68554f6392c2185ae0e8bea73ab6c905b1522e083d9c9835e999fd",
+  "output_sha256": "8595a008a35f8b9bf3fafbcc3fc00e7db458044d85e895abe51dd9100142469c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/31a4fd889af371d0c4564d327bbdd69f6482c3930a8761ffe6e2103028a9aef6.md b/vision-fixhub/ds9-unparsed-06/31a4fd889af371d0c4564d327bbdd69f6482c3930a8761ffe6e2103028a9aef6.md
new file mode 100644
index 0000000000000000000000000000000000000000..148885e942bd47e08ef8229e863bd7d294384bb6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/31a4fd889af371d0c4564d327bbdd69f6482c3930a8761ffe6e2103028a9aef6.md
@@ -0,0 +1,2212 @@
+Questions or Changes?
+• attwireless.com
+Toll Free 1 866 293-4634
+611 from your wireless phone
+* TTY users - 1 866 4-AWS-TT'
+SUMMARY OF MONTHLY CHARGES FOR ACCOUNT 0035224228
+Previous
+Payments
+Balance
+Account
+Received
+Adjustments
+-6.63
+-54.12
+0.00
+Balance
+Forward
+-60.75
+Your billing cycle ended on March 11, 2004
+Current Monthly Charges
+Subscriber Adjustments
+Monthly Service
+Monthly Usage
+Charges
+Credits
+Taxes, Surcharges & Regulatory Fees
+Total Current Monthly Charges DUE UPON RECEIPT
+TOTAL CREDIT AMOUNT
+CREDIT BALANCE - DO NOT PAY
+IMPORTANT ACCOUNT INFORMATION:
+IF YOU CANCEL SERVICE BEFORE YOUR CONTRACT END DATE
+(INCLUDING IF YOU SWITCH YOUR WIRELESS NUMBER TO
+ANOTHER CARRIER), YOU WILL BE CHARGED AN EARLY
+TERMINATION FEE OF UP TO $200.
+Date of Invoice: March 12, 2004
+Current Monthly
+Charges
+38.75
+Total
+Credit Amount
+-22.00
+0.00
+0.00
+38.75
+0.00
+0.00
+0.00
+38.75
+-22.00
+AT&T WIRELESS APPRECIATES YOUR BUSINESS
+Please Retum This Portion With Your Payment.
+Use of service and payment of this invoice indicates agreement
+with the General Terms and Conditions for wireless service.
+EAT&T Wireless
+Account Name:
+Note: =>
+We Print on
+Front and Back
+Service # 5613080282
+Account # 0035224228
+(see reverse - signature required).
+THIS IS NOT AN INVOICE
+- DO NOT PAY
+#BWNHNGB
+#0000000352242283# w
+.S.01.03.0011.0000
+AT&T WIRELESS
+PO BOX 8229
+AURORA IL 60572-8229
+
+
+
+*51890501C 0*
+REFT (Recurring Electronic Fund Transfer): To enroll: sign below, check the REFT box on the reverse side and
+remit with this month's payment. Keep paying your bill until your statement indicates "Do Not Pay."
+REFT Agreement: 1 authorize my financial institution to deduct the amount of my monthly wireless phone bill from
+the account associated with the enclosed check and remit payment to AT&T Wireless. This authority will be
+effective until | notify AT&T Wireless to terminate it. I agree that I may be assessed a service charge (up to $20) or
+late fee or both if a payment is returned by my bank. For more information visit attwireless.com or call 1 866
+293-4634.
+Questions? We can help: AT&T Wireless appreciates your business and welcomes the opportunity to assist you.
+As part of our commitment to you, we are always adding new calling plans and promotions to match your individual
+needs. Visit our website at attwireless.com or contact our Customer Care at 1 866 293-4634 or dial 611 from your
+wireless phone. ¿Sabias que también ofrecemos servicio al cliente en tu idioma? Marca 611 desde tu teléfono
+inalámbrico, o 1 866 293-4634 desde cualquier teléfono y oprime el *.
+Driving Wireless Safety: Your wireless phone gives you the freedom and flexibility to stay in touch when you
+travel, but don't let a phone call distract you from driving safely. Use hands-free device if allowed or required by
+law. Call Carefully, Arrive Safely.
+AT&T Wireless Processing Fees: Accounts suspended for non-payment will be subject to a $25 reactivation fee
+per line and may be assessed a security deposit prior to reinstatement. Checks returned for non-sufficient funds will
+be charged up to a $20 fee.
+Local Tax: Local taxes are based on local government boundaries, the address information you provide for your
+account and/or your wireless telephone number. Please review the local tax charges on your bill. If you believe
+there is an error in the local tax charge, please contact us immediately at 1 866 293-4634. Please note that some
+ocal or state laws may require you to follow special procedures when notifying us about a local tax dispute. Yo
+nay also use the form below to notify us of any change to your taxing address. Thank you for your cooperatior
+Please Send Correspondence To:
+AT&T Wireless Next Generation Correspondence
+P.O. Box 68056
+Anaheim Hills, CA 92817-8056
+0.000005189.5
+Change of Address Only. Please print address clearly and check the box on the reverse side. Please contact Customer Care to change the
+Name and transfer Financial Responsibility.
+New Billing Address
+City
+State
+Zip
+Home Phone (
+Work Phone (.
+If your billing address is NOT your Tax Address*, please enter the Tax Address below. (Multi-line accounts should attach a list of each wireless number and
+the respective Tax Address.)
+New Tax Address*
+Wireless Number (
+City
+State
+Zip
+Inder Federal laws, your Tax Address must be: your primary place of use, your residential or business address, and located within AT&T Wireless
+ensed service area. Non-business customers on AT&T Digital One Rate, Regional Advantage or Shared Advantage plans must use their resident
+address as their tax address.
+Recurring Electronic Fund Transfer (REFT) Enrollment. Please read the agreement on the top portion of this page, sign below and check the
+"REFT Registration" box on the reverse side.
+6.1 - 3G
+Financial Account Holder Signature
+• I do not wish to receive email notilication of special ofers avalable to AT&T Wireless customers.
+
+
+
+ACCOUNT DETAILS
+Detail of Payments - Thank You!
+Item Description
+1 PAYMENT
+Total of Payments
+Date Applied/Reversed Payment Amount
+02/20/04
+-54.12
+Current Subscriber Monthly Charges and Credits
+Subscriber Number
+Subscriber Name
+
+Total Current Subscriber Monthly Charges and Credits
+Total Current Monthly Charges
+SUMMARY OF CURRENT ACTIVITY
+Monthly Service Charges
+Item Description
+1 CALL WAITING
+2 CALLER ID
+3 GO PHONE $53.98 REPLENISHMENT
+4 THREE WAY CALLING
+5 GO PHONE UNLIMITED NIGHTS AND WEEKENDS
+6 DETAIL BILLING
+Total Monthly Service Charges
+Service Dates
+02/12/04 - 03/11/04
+02/12/04 - 03/11/04
+02/12/04 - 03/11/04
+02/12/04 - 03/11/04
+02/12/04 - 03/11/04
+02/12/04 - 03/11/04
+Monthly Usage Charges
+Item Description
+1 AIRTIME MINUTES
+2 CALL WAITING
+3 UNLIMITED N/WKND MIN
+4 MESSAGE RETRIEVAL
+5 TEXT MESSAGES SENT
+6 DROP CALL CREDIT
+7 SPECIAL NUMBER CALLS
+8 MMODE/DATA USAGE
+Total Monthly Usage Charges
+1,024 Kilobytes (KB) = 1 Megabyte (MB)
+Onty Used
+287 MIN
+25 EVT
+1064 MIN
+43 EVT
+129 EVT
+5 MIN
+4 MIN
+2 KB
+Taxes, Surcharges and Regulatory Fees
+Item Description
+1 FEDERAL TAX
+2 FEDERAL TAX
+3 UNIVERSAL CONNECTIVITY CHARGE
+4 UNIVERSAL CONNECTIVITY CHARGE
+5 LOCAL COMM SERVICE TAX
+6 LOCAL COMM SERVICE TAX
+7 STATE COMM SERVICE TAX
+-54.12
+-54.12
+38,75
+38.75
+38.75
+0.00
+0.00
+0.00
+0.00
+0.00
+0.00
+0.00
+25.83
+0.00
+0.00
+0.00
+12.90
+0.00
+0.00
+0,02
+38.75
+-0.77
+0.77
+-0.94
+0.94
+-2.53
+2.53
+-3.64
+SUMMARY OF CURRENT ACTIVITY - CONTINUED
+Taxes, Surcharges and Regulatory Fees - Continued
+Item Description
+8 STATE COMM SERVICE TAX
+Total Taxes, Surcharges and Regulatory Fees
+TOTAL CHARGES FOR (561)308-0282
+DETAIL OF CURRENT ACTIVITY
+VOICE USAGE FOR (561)308-0282
+Item Date Time Called
+1 02/12 02:04P (954)655-0720
+3 0212 07-18P (954)655-0720
+4 02/12 07:32P
+Calls To
+TLAUDERDL F
+NOAMDERDL FI
+INCOMING
+8 02/12 07:30Р
+7 02/12 08:24P
+
+(561|632-0139
+WPALMBEACH
+MPALMBEAU
+COMING
+19 02/12 08:44₽
+13
+02/12
+: 08:52P
+10:07P
+14
+02/12 10:23P
+/12 11:02P (561)254-3672
+17
+/12
+11:33P
+02
+13
+09:11A
+09:12д
+219 0529р
+12:21P (561)333-6718
+: ОВ 28Р (881)632-8139
+- 213 08 16 86 1308.0282
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+WALMBEACH FL
+02
+36 0218 08 2 598108 0252
+29 02/13 09:22P (561)324-1610
+0 02/13 09:23P (561|632-013
+11 02/13 09:24P (561 308-028
+32 02/13 09:26P (561)308-0282
+33 02/13 09:26P (561)308-0282
+34 02/13 09:36P
+20 2013 18 1561798-0695
+38 18 18388
+13 02/13 1134P 5811827-9505
+44 02/14 12:02A (561)596-9528
+WPALMBEACH FL
+NPALMBEACH E
+VPALMBEACH F
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+PALMBEACH
+INCOMING
+WPALMBEACH FL
+INCOMING
+MPALMBEACH F
+NPALMBEACH FI
+WPALMBEACH FI
+WPALMBEACH FI
+WPALMBEACH FL
+Onty
+Used
+Rate Description
+2MIN 0.09 AIRTIME MINUTES
+MIN 8.09 AIRTIME MINUTES
+1 MIN 0.09 AIRTIME MINUTES
+1EVT
+OMIN
+2MIN
+2MIN
+84 MIN
+4MIN
+2 MIN
+3MIN
+2 MIN
+IMIN
+.09
+AIRTIME MINUTES
+.09
+.09
+ARTIME MINUTES
+CALL WAITING
+0 00
+ARTIME
+AIRTIN
+MINUTES
+MINUT
+0.09 ANIMITED WIND MIN
+UNLIMIT
+UNLIMIT
+UNLIMI
+222
+I N/WKND
+poppe
+
+MINUT
+2 MIN
+2MIN
+1EVT
+2 MIN
+SMIN
+1MN
+2 MIN
+2 MIN
+SMIN
+
+3.60
+38.75
+0.18
+00000C
+
+200
+868
+
+N90888
+AMIN
+RETRIEVAL
+INLIMITED N/WKND MIR
+lESSAGE RETRIEVA
+¡ETRIEVA
+UNLIMITED MAKE MIND
+TWEND MIN
+NAME WIND ME
+NLIM
+INLIMITED N/WKND MI
+'ESSAGE RETRIEVA
+UNLIMITED N/WKND MIL
+INLIMITED NIWKND MIN
+D.000005190
+
+
+0.000005190
+
+Called
+Onty
+Used
+Item Date Time
+12 02/14 12:05A
+03:04A (561)254-3672
+47 02/14 07:21A (561)793-9291
+190214 8730A (581793-3231
+02/14 07:49A
+02/14 8731A
+881) 383-9036
+88888
+4 07:59A
+/14
+08:10A (561)389-1035
+114
+9:09 A
+/14
+09:16A
+14 09:39A (561)688-0026
+0:39A
+114
+114
+11:83A
+02/14 11:06A
+19811632-8935
+(561)827-5411
+62/14 11:02A 561/688-0026
+64
+02/14 12:49P
+65
+66
+02111850(
+(581) 351-9056
+67 02/14 01:21P
+0214 01:38P (561)333-90
+69
+79 02/14 04-29P
+(561)818-5750
+72 02/14 04:23P
+23 02/14 04:29P
+4 02/14 04:38P
+(561)827-0842
+75 02/14 04:38P
+76 02/14 04:39P
+(561)795-8642
+(561)252-7988
+77 02/14 05:00P
+5611632-0139
+78 02/14 06:25P
+(561j308-0282
+79 02/14 06:26P (561)308-0282
+80 0311 06-58
+82 02/14 07:00P (561)798-6999
+83 02/14 07:42P
+84 02/14 07:57P (561)876-2208
+• 02/14 08:131
+6 02/14 08:17P (5611827-084
+87 02/14 08-55P
+88 02/14 08:57P (561)308-0282
+89 02/14 DB:59P (561)308-0282
+90 02/14 09:00P (561)308-0282
+91 02/14 09:57P (561)827-0842
+92 02/14 09:58P (561)329-4256
+3 02/14 10:00P (561)253-5338
+4 02/14 10:117
+95 02/14 10:20P (561)308-0282
+96 02/14 10:22P (561)324-1610
+97 02/14 10:24P (561j688-0026
+5611827-0842
+3 82/14 18:30Р 581953-489
+100
+02/14 10:32P (561j795-0655
+5883
+02/14 10:36P
+02/14 10:41
+82/14 18:58P (561)791-3816
+Rate Description
+Calls To
+COMING
+VPALMBEACH F
+WPALMBEACH FL
+PALMBEACH B
+PALMBEACH P
+INCOMING
+WALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+WPALMBEACH FL
+NCOMING
+NPALMBEACH FI
+MPALM:
+WPALMBEACH FL
+WPALMBEACH FL
+NCOMING
+INCOMING
+VPALMBEACH FI
+VPALMBEACH FI
+INCOMING
+WPALMBEACH FL
+INCOMING
+COMING
+(PALMBEACH F
+INCOMING
+COMING
+(PALMBEACH F
+WPALMBEACH FL
+WPALMBEACH FL
+MPALMBEACH FI
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+NCOMING
+WPALMBEACH FL
+COMIN
+PALMBEACH FI
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WALMBEACH FL
+WPALMBEACH FL
+COMIN
+COMIN
+WALNBEACH FL
+MIl
+2MIN
+2 MIN
+2 MIN
+10 MIN
+2 MIN
+2MIN
+2 MIN
+2 MIN
+2 MIN
+1 MAIN
+2 MIN
+1EVT
+1EVT
+SMIN
+2MIN
+1 EVT
+2MIN
+2 MIN
+2 MIN
+3 MIN
+EMIN
+UNLIMIT
+UNLIMIT
+UNLIMITE
+UNLIMIT
+INLIMITED N/WK
+INLIMIT
+UNLIMIT
+NUMITED
+UNLIMITE
+UNLIMITE
+UNLIMITI
+UNLIMITI
+ШАШНИ
+ПЛ00022100011101101375
+*51900502C 0°
+
+Item Date Time Called
+Onty
+Used
+106 02/14 11:19P (561)308-0282
+Calls To
+WPALMBEACH FL
+108 0214 11:16P
+198 02/15 1222A
+111 02/15 12:39A
+(561)253-5388
+561329-4256
+12 02/15 12:40A
+13 02/15 12 434
+329-1
+114
+/15
+12:50A
+256
+(561 329-4256
+01:09A
+561
+29-4256
+(5bl
+501]
+320-4256
+(561)307-4274
+PALACH EL
+WPALMBEACH FL
+WALMBEACH EL
+WPALMBEACH FL
+WALMBEACH FL
+CUMIN
+PALMBEACH i
+1 EVT
+2 MIN
+1EVT
+4 MIN
+I MIN
+Rate Description
+N/WKND M
+MESSAGE RETRIEVAL
+JNLIMIT
+CALL WAITING
+INLIMITED N/WKND MIN
+DROP CALL CREDI
+UNLIMITED SWIND MIN
+WKND
+UNLIMITED AMEND M
+#P=*#8N808808882 882
+8 8888
+80095993 9900000009080000
+880
+
+561 307-4274
+(561)333-9056
+(561)333-9056
+(561)
+(561)324-1610
+(305)945-7977
+(917)312-7816
+1202
+WPALMBEACH FL
+INCOMING
+N88MING
+EACH FL
+2:
+IC
+COI
+WALM ACH
+WPALMBEACH FL
+INCOMING
+INCOMING
+WPALMBEACH FL
+NCOMING
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+NCOMING
+NCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+WPALMBEACH FI
+WPALMBEACH FL
+COMING
+COMING
+ORTH DADE
+COMIN
+WPALMBEACH FL
+PALMBEACH F
+PAIMREACH
+(PAI MREACH F
+INCOMING
+WPALMBEACH FL
+INCOMING
+ШШШ
+4 MIN
+2 MIN
+3MIN
+1EVT
+2 MIN
+SMIN
+SMIN
+SMIN
+2 MIN
+4 MIN
+2MIN
+2MIN
+3MIN
+2MIN
+N/WKND
+N/WKND
+W/WKND
+UNLIM
+CALL
+MANAND
+/KN
+UNLIMITEB!
+KNI
+UNLIMITED N
+JNLIMITED
+WKND MIN
+WKND MIN
+
+
+
+Called
+Item Date Time
+i5 02/15 07:08
+0/15 07:08
+167 02/15 07:19P
+168 02/15 08:31P (561)254-3672
+169 02/15 08:42P
+5611254-3672
+170 02/15 08:45P (561|254-3672
+71 02/15 09:471
+72 02/15 09:597
+173 02/15 10:01P (561)329-4256
+174 02/15 10:07P
+175 02/15 10:46P
+981632-0059
+176 02/15 11:22P (561)308-0282
+177 02/15 11:23P (561)308-0282
+178 02/15 11:23P (561)632-0139
+179 02/15 11:35P (561)324-1610
+(561)333-9056
+(866) 26-9608
+866)
+B26-9608
+
+B8BB88B888GBG
+BRENNE
+
+561)723
+561\255-271
+(58 1255-2717
+(561)254-0433
+:57P
+:58P
+(561\632-0139
+Calls To
+COMIN
+COMIN
+INCOMING
+WPALMBEACH FL
+PALMBEACH FL
+WPALMBEACH FL
+COMINO
+COMINI
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+COMINI
+COMINI
+INCOMING
+INCOMIN
+WPALMBEACH FL
+LIW
+FL
+FL
+INCOMING
+INCOMING
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+COMIN
+COMIN
+INCOMING
+INCOMING
+INCOMING
+WALMBEACH
+WPALMBEA
+WPALME
+WPALMBEACH FL
+INCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+WALMEACH L
+INCOMING
+WPALMBEACH FL
+INCOMING
+Qnty
+Used Rate Description
+UNLIMITEB NWIND MIN
+) N/WKND MIN
+UNLIMITED N/
+/KND MIN
+2 MIN
+UNLIMITED N/
+WKND MIN
+2MIN
+2 MIN
+UNLIMITED /WEND MIN
+UNLIMITED N/KND MIN
+1 EVT
+MESSATED TEND MIN
+1 EVT
+MESSAGE RETRIEVAL
+OMIN
+AIN
+3 MIN
+1EVT
+2MIN
+3MIN
+2 MIN
+2 MIN
+2 MIN
+2MIN
+0.0
+O000
+.09
+ALL
+
+.09
+IRTI
+UNLIMI
+CALL I
+UNLIMI
+UNLIN
+UNLIM
+UNLIN
+NLIMITE
+
+
+Item Date Time
+Called
+226 02/21 12:31A (561)301-6596
+02/21
+12:32A
+(561)301-6596
+02/21 12:35A
+02
+/21 12:41A (561)632-0139
+02/21 12:57A
+/21 04:57P
+21 04:58P (561)798-8887
+/21 05:14P
+05:21P
+611329-420
+88
+21 06:33P
+21 06:56P
+02/21 07:00P (561)790-1085
+Calls To
+COMIN
+PALMBEACH
+WPALMBEACH FL
+COMIN
+PALMBEACH P
+INCOMING
+COMIN
+PALMBEACH i
+INCOMING
+COMIN
+PALMBEACH P
+INCOMING
+WALME FE
+COMIN
+WPALMBEACH FL
+/PALMBEACH F
+4 MIN
+3MIN
+3MIN
+2 MIN
+2 MIN
+02
+09:16P
+6P
+BRRRRRRRR
+(561)324-1610
+(561)333-0180
+Onty
+Used
+Rate Description
+N/WKND M
+UNLIMITED NWIND MIN
+N/WKND MIN
+INLIMITED NWKND MIN
+INLIMI
+ED N/WKND MIN
+UNLIMITE
+D N/WKND MIN
+UNLIMITER NWNB MIN
+N/WKND MIN
+NLIMITED NWKND MIl
+NLIMI
+N/WKND MIN
+UNLI
+UNL
+INCOMING
+N/WKND
+WKND MIN
+I MIN
+INCOMING
+INCOMING
+NCO
+INCOMING
+NCOMING
+NCOMING
+WPALMBEACH FL
+INCOMING
+
+(954)655-0720
+(561)753-4896
+(561)324-1610
+(561)723-9357
+(561)644-9897
+
+COMING
+NPALMBEACH
+WPALMBEA
+WPALMBEACH
+INCOMING
+NPALMBEACH F
+COMING
+INCOMING
+COMING
+TLAUDERD
+FL
+INCOMING
+COMIN
+COMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH
+INCOMING
+INCOMING
+INCOMING
+WPALMBEACH
+INCOMIN
+WPALMBE
+LAKE
+AKE
+OR
+SMIN
+2MIN
+2 MIN
+3MIN
+_000000001000010
+!!!!
+
+
+
+
+161900000°0
+
+Item Date Time
+Called
+Onty
+Used
+90 02/22 03:34P (561)876-220
+2/22 04-21
+292 02/22 04:27P
+293 02/22 04:31P
+294
+02/22 04:49P (561)324-1610
+295 02/22 04:49P
+296 02/22 05:03P (561)632-0139
+297
+02/22 05:31P
+298 02/22 05:36P
+02/22 05 38P (5611308-0282
+Calls To
+WPALMBEACH FL
+NCOMING
+INCOMING
+NOOMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+NOOMING
+MPALMBEACH FI
+300
+82/22 06.468 581993-0239
+122
+02
+07:29P
+22
+09:05P (561)324-1610
+02/22 09:20P
+8888฿
+56118
+130
+- 202
+309
+02/22
+11:09P
+
+TOO CT
+Kak
+ORDERERE
+(561)876-2208
+(561)324-1645
+(845)590-9909
+(954)655-0720
+(954j655-0720
+501
+1255-
+-2717
+661
+976
+10:5
+RESSI
+(561)876-2208
+(561)309-4673
+Rate Description
+COMIN
+VPALMBEACH F
+INCOMING
+WPALMBEACH FL
+WPALMBEACH
+FL
+INCOMING
+WPALMB
+INCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+JEWBURGH N
+COMING
+INCOMING
+INCOMING
+FTLAUDERDL FL
+FTLAUDERDL FL
+INCOMING
+INCOMING
+INCOMING
+NOOMING
+OMING
+WPALMBEACH FL
+COMING
+INCOMING
+NPALMBEACH FL
+NCOMING
+3MIN
+2 MIN
+4 MIN
+EV
+2 MIN
+1 EVT
+4 MIN
+NLIMITED N/WKND M
+N/WKND MIN
+LL WAITIN
+LIMITED NAWKND M
+LIMITED N/WKND M
+VLIMITED NWKND MI
+MESSAGE RETRIEVAL
+N/WKND MIN
+3 MIN
+NLIM
+NWKND MIN
+UNLIMITED /WND MIN
+CAL
+CREDI
+N/WKND MIl
+UNLIMITI
+UNLI
+UNLIMITED
+W/WKND
+N/WKND
+ED N/WKND
+MINUTE
+MINUT
+IN
+2MIN
+2 MIN
+
+
+0000
+
+EMIN
+MI
+:09 AIRTIME MINUTES
+*51910503C
+
+8:18
+
+Item Date Time
+Called
+12 02/24 06:36
+124 07•48
+354 02/24 08:04P
+355
+02/24 09:02P
+356
+02/24 09:20P (561)795-0655
+02/25 02:58P
+02
+125 04:61P (561)676-7338
+06:33P
+125
+07:43P
+25
+07:44P
+25 09:37P (561)324-1610
+25
+10:26
+ñ-00P
+(561)793-9291
+02/25 10:43P
+561793-9291
+02/26 06:33A
+HЗ0A
+5611793-9291
+(561)254-3672
+11:46A
+(561)254-3672
+:15P
+Calls To
+COMIN
+BORIN
+INCOMING
+COMIN
+PALMBEACH R
+INCOMING
+ESTPLMBCH P
+COMIN
+INCOMING
+ICOMIN
+COMIN
+WPALMBEACH FL
+COMIN
+PALMBEACH F
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+COMIN
+COMIN
+WPALMBEACH FL
+COMIN
+COMIN
+INCOMING
+Onty
+Used
+Rate Description
+1 MIN 8:09 ARTIME MINUTES
+0.09 AIRTIME MINUTES
+2 MIN
+AMIN
+TIN
+511324-16
+1007_64
+(561)626-0930
+:11P
+INCOMING
+WALMBEACH FL
+NCO
+INCOMING
+561)793-929
+1793-929
+07:07P
+
+(561)324-1610
+(561)324-1610
+393 02/26 10:40P (561)308-0282
+INCOMING
+INCOMING
+WPALMBEACH FL
+VPALMBEACH FL
+COMING
+NCOMING
+NPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+JNLIMIT
+0.09 AIRTIME MINUTES
+2.09 ARTIME MINUTES
+0.09 AIRTIME MINUTES
+0.09 AIRTIME MINUTE:
+09 AIRTIME MINUTES
+UNLIMITED NOW MON
+INLIM
+LIMITED N/WKND M
+19 AIRTIME MINUTE
+0.09 AIRTIME MINUTES
+2.09 ARTME MINUTES
+MINUT
+0.09 AIRTIME MINUTES
+8:09
+IRTIME MINUTE
+ARTIME MINUTE:
+0.09 AIRTIME MINUTES
+0.09 AIRTIME MINUTES
+GO ATE MINUTES
+0.09 AIRTIME MINUTES
+EMIN
+09 AIRTIME MINUTE
+0.09 AIRTIME MINUTES
+0.09 AROP ALL CREDIT
+0.09 AIRTIME MINUTES
+_ 0.09 AIRTIME MINUTES
+CALL WAITING
+2 MIN
+0.09 AIRTIME MINUTES
+13MIN
+17 MIN
+UNLIMITED WIND MIN
+394 02/26 10:41P
+396 02/26 10:55P
+(561)254-3672
+£A11927.5/11
+(561/308-0282
+397 02/26 10:56P
+398 02/26 10:56P (561)308-0282
+
+
+1:57P
+(561)795-0655
+b8ºğ+9·8929
+(561)254-3672
+(561)313-6730
+(561)254-3672
+(551)302-
+113-6730
+02-1130
+NPALMBEACH FL
+MPALMBEACH FI
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+1EVT
+7 MIN
+MESSAGE RETRIEVAL
+LIMITED N/WKND M
+CALL WAITING
+1 EVT
+MESSAGE RETRIEVAL
+INCOMING
+I 0.O9 ARTIME MINUTEND MIN
+0.09 AIRTIME MINUTES
+NCOMING
+WPALMBEACH FL
+2 MIN
+09 AIRTIME MINUTE
+no ARTIME MINUTE
+LAKE WORTH FL
+NOOMINC
+0.09 AIRTIME MINUTES
+NPALMBEACH FL MI
+8.09 AIRTIME MINUTES
+INCOMING
+0.09 AIRTIME MINUTES
+IMIN
+0.09 AIRTIME MINUTES
+0.09 AIRTIME MINUTES
+AINUI
+109 AIRTIME MINUTES
+.09
+1.09
+0.27
+18
+0.63
+0.18
+8:99
+8.09
+D.09
+
+
+
+Item Date Time
+Called
+0127 06:32
+414 02/27 07:05P (561324-1610
+15 02/27 07:218
+561|333-0180
+16 02/27 07:220
+5611333-0180
+417 02/27 07:31P
+(561)876-2208
+18 02/27 07:35P (561)793-929
+19 02/27 08:02
+420 02/27 09:18P (561)632-0139
+421 02/27 09:18P (561)308-0282
+422 02/27 09:19P
+423 02/27 09:21P (561)308-0282
+424 02/27 09:23P (561)632-0139
+425 02/27 09:23P (561\632-0139
+426 02/27 09:54F
+127 02/27 10:178
+428 02/27 11:57P
+(561)308-0282
+429 02/27 11:57P
+430
+431
+
+139
+
+12:02A
+2:06A
+9993m
+02:
+=93892
+18880
+655-0720
+3-0180
+827-5411
+4-1610
+7-5411
+02:45P
+04:42P
+(561)827-5411
+440
+441
+02/28 04:49P
+561/324-1610
+12/28 04:50F
+561/324-1610
+02/28 04:50F
+561
+1632-0139
+443 02/28 04:51P
+(561|632-0139
+145 03/2024P 561)324-1610
+446 02/28 06:02P
+447
+02/28 06:12P
+(561)308-0282
+48 02/28 06:23P (561)632-013
+449 02/28 06:25P
+11308-00
+150 02/28 09:05P (561)33-0180
+452 02/28 09:20P
+02/28 18:9
+
+10:47P
+457 02/28 11:07P (561)254-7565
+138 02/28 11:32
+(561)329-4256
+460 02/29 12:12A
+461
+02/21
+11:41A
+(561)254-3672
+462
+02/2
+11:48A
+SA11964-2672
+463
+02/29 11:57A
+465
+02
+129
+2:529
+55055
+466
+(561)324-1610
+02/29 04:52P
+467 02/29 05:08P
+(561)308-0282
+468 02
+168 02/28 05:195
+: 861)308-5232
+Calls To
+COMINO
+ICOMINI
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+COMIN
+COMIN
+WPALMBEACH FL
+INCOMING
+INCOMING
+TING
+FTLAUDER
+MPALMBE
+WPALMBEACH
+WPALMB
+WPALMB
+INCOMING
+COMIN
+PALMBEAd
+FL
+WPALMBEACH
+FL
+WPALMBEACH FL
+NCOMING
+WPALMBEACH FI
+WALMBEACH FL
+WPALMBEACH FI
+NCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+WPALM
+INCOMING
+INCOMING
+MPAI MREACH FIl
+INCOMING
+WPALMBEACH FL
+Qnty
+Used
+Rate Description
+1 MIN 0:08 AIRTIME MINUTES
+4 MIN
+0.09 AIRTIME MINUTES
+2MIN
+0.09 AIR TIME MINUTES
+0.09 AIRTIME MINUTES
+3MIN
+1.09 AIRTIME MINUTE
+.09 AIRTIME MINUTE:
+3 MIN
+MESSAGE RETRIEVAL
+2MIN
+1 EVT
+ALL WAITING
+2 MIN
+NLIMITED NAWKND MIl
+1 EVT
+MESSAGE RETRIEVAL
+4MIN
+N/WKND
+7MIN
+2 MIN
+3MIN
+1 EV
+2 MIN
+1EVT
+2 MIN
+1MIN
+DAIN
+4MIN
+2MIN
+JNLE
+INI A
+2 MIN
+2MIN
+1 EVT
+3MIN
+1 EVT
+2MIN
+2 MIN
+2MIN
+2 MIN
+3 MIN
+1 EVT
+2MIN
+1 MIl
+8.00
+0.36
+0.18
+0.27
+0.00
+
+Item Date Time
+Called
+470 02/29 05:17P (561)644-9897
+471 02/29 07:37P
+472 02/29 08:28P
+(561) 383-8200
+473 02/29 08:32P
+61)793-9291
+474 02/29 09:00P
+(561)793-9291
+5 02/29 09:46P (561)254-36
+476
+129 09:51
+477 02/29 10:21P
+179 02/29 10:33P
+479
+10:39P
+480 02/29 10:49P
+481 03/01 02:53P (561)308-0282
+482 03/01 02:55P (561)308-0282
+483 03/01 02:56P (561)308-0282
+Calls To
+WPALMBEACH FL
+INCOMING
+WPALMBEACHEL
+WPALMBEACH FL
+Onty
+Used
+EV
+: MIN
+2MIN
+2 MIN
+1MN
+2 MIN
+3 MIN
+6MN
+10MIN
+Rate Description
+MESSAGED TEND MIN
+INLIMITED NIWKND MIl
+NLIMITED N/KND MIl
+JNLIMITED NIWKND MIN
+JNLIMITED N/WKND MIN
+INCOMING
+:22
+COMIN
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+1 MIN 0.09 AIRTIME MINUTES
+1EVT
+ESSAGE RETRIEVI
+199
+
+§9§9§99999
+
+
+(561)254-3672
+888
+(561)308-0282
+888
+=08
+(561)254-3672
+5611308-
+88
+01:0
+(561
+1303-
+39
+02
+01:16P
+(561)
+)308-0282
+WPALMBEACH FL
+INCOMING
+WPALMB
+ДДД
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+2MIN
+1 EV
+1 MAIN
+7MIN
+.09 AIRTIME MINUTE
+0.09 AIRTIME MINUTES
+0O
+188
+MINUTE:
+I AIRTIME MINUTES
+UNLIMIT
+KND
+UNLIM
+UNLIM
+UNLIMIT:
+UNLIMITED
+UNLIMITED
+/WKND MIN
+WKND MIN
+0.09 AIRTIME MINUTES
+_ 0.09 AIRTIME MINUT
+LEV
+NESSAGE RETRIEVAL
+1 MIN 0.09 AIRTIME MINUTES
+88888
+
+o CC
+(813)267-0663
+(973)9
+(561)
+32
+-0139
+(381)
+)823-
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+INCOMING
+INCOMING
+NEWTON NJ
+INCOMING
+PALMBEAO
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FI
+NPALMBEACH F
+VPALMBEACH
+FTLAUDERDL FL
+COMIN
+COMIN
+40
+2MIN
+2MIN
+50MIN
+3MIN
+IMIN
+IMIN
+2MIN
+2MIN
+8MIN
+0.09 ARTSMEMNETESVAL
+8.09 AIRTMEMINUTES
+0.09 AIRTIME MINUTES
+0.09 AIMED WIND MIN
+C.O8 AIRTME MINUTES
+0.09 AIRTIME MINUTES
+0.09 AIRTIME MINUTES
+09 AIRTIME MINUT
+09 AIRTIME MINUTI
+0.09 AIRTIME MINUTES
+
+MINUTE
+8:09 AIRTIME MINUTES
+0.09 AIRTIME MINUTES
+0.09 AIRTIME MINUTE.
+NIND MIN
+JNLIMITEl
+N/WKND MIN
+INLIMITED NANKNO
+MAWKIDMIN
+UNLIMITED WIND MIN
+100
+88
+0.18
+D.000005192
+
+
+261900000*0
+
+Item Date Time Called
+Calls To
+Onty
+Used
+528 0303 09:34P
+530 03/03 18:53P (867)798-8916
+532 03/03 10:34P
+33 03/03 10:44P
+03/0E
+11:30P (561)324-1610
+535
+596
+03/04 02:51P (561|254-3672
+03/04 02:52P (561)795-0655
+538
+03/04 02:57P
+03/04 03:06P (954)655-0720
+10
+03/04 04:39P (561)753-4896
+542 03/04 07 25P
+543 03/04 07:34P
+
+
+-26P
+1581723-
+23-5933
+-6738
+So000
+10:42P
+10:47P
+(561)793-9291
+561|856
+1435
+5611856-1435
+559
+03/05 12:04A /5611308-0282
+560 03/05 12:28A
+561 03/05 12:28A (561)793-9291
+: 8385 02:28P (561)308-0282
+04:34P
+04:57P
+(954)655-0720
+INCOMING
+COMIN
+PALMBEACH P
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+FTLAUDERDL FL
+WPALMBEACH FL
+NCOMING
+NOMING
+NCOMING
+INCOMING
+COMING
+JCOMING
+INCOMING
+NCOMING
+NCOMING
+INCOMING
+LAKE
+MPAI
+AK-
+AKE
+WOR
+INCOMING
+WPAL!
+VPALMBEACH FL
+PALM BEACH FL
+PALM BEACH FL
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INPALINEACH FL
+INCOMING
+FTLAUDERDL FL
+1 EVT
+22 MIN
+EMIN
+2MIN
+4 MIN
+3 MIN
+3MIN
+VIN
+4 MIN
+2 MIN
+EV
+
+
+85
+, 07:54P
+08:06P (561)254-3672
+08:13P
+3/05
+08:26P
+03/05 08:27P
+INCOMING
+WPALMBEACH FL
+NOOMING
+INCOMING
+INCOMING
+OMIN
+2MIN
+03005
+09•00p
+nE
+08:41P
+03/05 09:01P
+(561)856-9869
+03/05 09:04P
+561)254-3672
+57
+03/05 09:05F
+03/05 09:06P
+09:12P
+(561)254-3672
+61\876-220
+09:24P
+A11705.072
+888
+11:25P (561)676-7336
+01:04A
+(561329-2412
+03/06 01:08A (561/308-0282
+03/06 01:13A
+03:08 18:434 (561)254-3672
+PALM BEACH FL
+NPALMBEACH F
+NCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WESTPLMBCH FL
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+COMING
+3MIN
+EMIN
+8MIN
+2 MIN
+3 MIN
+2 MIN
+1 EVT
+2MIN
+Rate Description
+CALL WAITING
+0.09 AIRTIME MINUTES
+09 AIRTIME MINUTE
+I AIRTIME MINUTE
+0.09 AIRTIME MINUTES
+IS ARTHE MINUT
+19 AIRTIME MINUTE
+0.09 AIRTIME MINUTE
+9 AIRTIME MINUTE:
+0.0
+UNL
+
+UNLI
+JUMITE
+*51920504C 0*
+8.09
+000
+88
+
+
+
+Item Date Time Called
+Calls To
+589 0306 19:21A 561616-3873
+590 03/06 12:57P
+Onty
+Used
+591 03/06 01:49P (561)308-0282
+592 03/06 02:14P (561)723-9701
+3/06 04:088
+595
+03/06 06:02P
+19 030 07:20P 561333-012
+7 03/06 07-24
+598 03/06 07:29P (561)632-0139
+59 03 06 07:47
+00 03/06 07-501
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+NCOMING
+INCOMING
+WPALMBEACH FI
+NPALMBEACH FL
+WPALMBEACH FL
+COMIN
+COMIN
+EMIN
+4 MIN
+Rate Description
+601 03/06 07:51P
+602
+03/06
+A7.CA0
+(561)818-9039
+INCOMING
+LIMITE
+ESSAC
+LIMITED N/WKND M
+UNLIMITI
+NLIMITED NWKND MI
+NLIMITED NANKND MI
+CALL WAITING
+630
+
+
+(561)723-9933
+134
+07
+03:17P
+(561)308-0282
+ZZ
+WPALMBEACH FL
+
+
+(561)792-5923
+1792.
+59
+g88
+SAN
+INCOMING
+INCOMING
+BOYNTONBCH FL
+VPALMBEACH F
+VPALMBEACH P
+WPALMBEACH FL
+VPALMBEACH F
+WPALMBEACH FL
+/PALMBEACH FI
+WPALMBEACH FL
+WPALMBEACH FL
+SMIN
+222
+Z
+ZZ
+DROP CALL CREDIT
+
+
+
+Item Date Time
+Called
+49 03/08 03:01P (561)254-3672
+50 00/08 03•24₽
+651 03/08 05:29P
+652 03/08 05:37P
+653 03/08 06:04P (561)827-5411
+654 03/08 06:04P
+655 03/09 03:15P
+656 03/09 03:37P
+657 09/09 0412P
+(681)254-3672
+59 03/09 04:15F
+60 03/09 04:16P (561)254-367:
+661 03/09 04:34P
+561)503-1875
+52 03/09 04:35
+161|333-022
+53 03/09 04:37
+611333-022
+664 03/09 06:50P
+665 03/09 07:36P
+666 03/09 07:41P
+667 03/09 08:15P
+668
+669
+3,09 08:2
+13/09 09:12F
+5611333-0225
+670 03/09 09:16P
+561 723-9357
+03/09 09:22P
+061254-3672
+672 03/09 09:30P
+254-3672
+673
+03/09
+09:41P
+674
+(561)856-1435
+Qnty
+Calls To
+Used
+Rate Description
+NCOMINGACH FL 1MIN 8:09 AIRTIME MINUTES
+NCOMING
+INCOMING
+6MIN
+0.09 AIRTIME MINUTES
+INCOMING
+1.09 AIRTIME MINUTE
+WPALMBEACH FL
+1.09 AIRTIME MINUTE:
+INCOMING
+0.09 AIRTIME MINUTES
+ILL WANIN
+INCOMING
+09 AIRTIME MINUTE
+INCOMING
+0.09 AIRTIME MINUTES
+VRALMBEACH E
+VPALM
+0.09 AIRTINE
+MINUTE
+MINUTE
+COMINI
+VPALMBEACH F
+8.09 AIRTIME MINUTES
+BOYNTONBCH FL
+0.09 AIRTIME MINUTES
+WPALMBEACH FL
+WPALMBEACH FL
+0.09 AIRTIME
+MINUTE
+NCOMING
+0.0
+INCOMING
+INCOMING
+COMING
+WPALMBEACH
+WPALMBEACH
+WPALMBEACI
+WPALMBEAI
+PALM BEACH FL
+INCOMING
+675 03/09 11:15P
+03/09 11:16P
+INCOMING
+INCOMING
+IMIN
+2 MIN
+2MIN
+3MIN
+4MIN
+4MIN
+8MIN
+1EVT
+SMIN
+1EVT
+0.0
+UNLIM
+UNLIM
+UNLIM
+UNLIM
+677 03/09 11:17P
+678 03/09 11:24P
+679 03/09 11:31P
+680
+681
+03/10 09:29A (561)856-1435
+03/10 09:36A
+82 03/10 04:30P
+(561)252-4753
+683 03/10 04:31P
+684 03/10 04:41P (561)723-9357
+685฿
+03/10 05:22P
+686 03/10 05:45P
+687
+03/10 07:07P
+688
+03/10 07:09P
+689 03/10 07:42P
+690
+03/10 07:50P
+(561)723-9357
+691
+03/10 08:36P
+692 03/10 09:16P (561)308-0282
+693 03/10 10:44P
+694 03/10 11:06P
+695 03/10 11:19P (561)254-3672
+696 03/10 11:20P
+697 03/10 11:24P
+698 03/11 06:16P (561)308-0282
+699 03/11 08:22P
+700 03/11 08:26P
+
+EEEEEEE
+
+(561)723-7752
+(561 723-7752
+382-0250
+561)790-5475
+1:39P
+1:47P
+157P
+INCOMING
+INCOMING
+INCOMING
+PALM BEACH FI
+INCOMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+COMING
+INCOMING
+COMING
+COMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+VPALMBEACH F
+VPALMBEACH F
+WPALMBEACH FL
+NCOMING
+INCOMING
+COMING
+COMING
+11 MIN
+3MIN
+2MIN
+OMIN
+4 MIN
+13MIN
+2MIN
+4MIN
+1EVT
+4MIN
+-N-
+EVT
+2MIN
+2MIN
+2 MIN
+UNLIM
+CALL 1
+0.09 AIRTIME
+0.09 AIRTIME
+1.09 AIRTIM
+.09 AIRTIM
+-COc
+09
+868R82888
+09
+288°
+00OC
+088856825801862021112838398089209635000-20
+18888R88888R8R88883838RRRRRRBBSSARAABARAAAARRARRRR
+8:18
+
+8.00
+0.54
+0.08
+0.18
+000c
+Item Date Time Called
+708 03/11 10:03P
+Calls To
+INCOMING
+Onty
+Used
+TOTAL VOICE USAGE FOR (561)308-0282
+Rate Description
+DATA USAGE FOR (561)308-0282
+Item Date
+Onty Used
+1 02/29
+2 KB
+TOTAL DATA USAGE FOR (561)308-0282
+Charge Description
+MMODE/DATA USAGE
+TEXT/MULTIMEDIA MSGS FOR (561)308-0282
+Item Date
+1 02/14
+2 02/14
+Time
+Sent To/Rcvd From
+02:59A
+03:21A
+(561)876-2208
+Charge Description
+TEXT MESSAGES SENT
+25.83
+0.02
+0.02
+
+
+
+
+
+TEXT/MULTIMEDIA MSGS FOR (561)308-0282 - Continued
+Item Date
+52 02/22
+53 02/22
+5402/22
+56 02/22
+Time
+Sent To/Rcvd From
+Charge Description
+09:27P
+(5611876-2208
+09:29P
+(561)876-2208
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+09:30P
+(561)876-2208
+09:30P
+09:35P
+561)876-2208
+TEXT MESSAGES SENT
+(561)876-2208
+TEXT MESSAGES SENT
+09:35P
+611876-221
+611876-221
+TEXT MESSAGES SENT
+50 02/2
+61 02/22
+5 02/2
+64 02/22
+• U2
+021
+67 02/22
+69 02/22
+REMARR
+0942P 581876-2208
+TEXT MESSAGES SENT
+09:44P
+09:478
+(561|876-2208
+TEXT MESSAGES SENT
+9•54P
+581)876-220
+TEXT MESSAGES SENT
+09:58P
+(561)876-2208
+TEXT MESSAGES SENT
+8:03P 381)876-220
+561 876-2201
+TEXT MESSAGES SENT
+10:04P
+(561)876-2208
+TEXT MESSAGES SENT
+18:09P
+681,876-2208
+TEXT
+SENT
+
+0.000005193
+*51930505C
+09000
+
+
+
+TEXT/MULTIMEDIA MSGS FOR (561)308-0282 - Continued
+Item Date
+Time
+Sent To/Rcvd From
+Charge Description
+119 03/03
+11:26P
+(561)876-2208
+EXT MESSAGES SEN
+120 03/05
+122 03/05
+09:36P
+(561)876-2208
+EXT MESSAGES SENT
+0.23F
+
+123 03/07
+4:01F
+561)876-2208
+TEXT MESSAGES SENT
+10:16A
+(561)339-0379
+TEXT MESSAGES SENT
+5 031
+08:31A
+1581876-2278
+TEXT MESSAGES SENT
+26 03/0
+08-368
+2
+(561)876-2208
+TEXT MESSAGES SENT
+128 03/09
+04:42P
+129 03/09
+04:50P
+1561)876-2208
+EXT MESSAGES SENT
+EXT MESSAGES SENT
+TOTAL TEXT/MULTIMEDIA MSG USAGE FOR (561)308-0282
+8:10
+8:18
+8:18
+010
+12.90
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/31a4fd889af371d0c4564d327bbdd69f6482c3930a8761ffe6e2103028a9aef6.receipt.json b/vision-fixhub/ds9-unparsed-06/31a4fd889af371d0c4564d327bbdd69f6482c3930a8761ffe6e2103028a9aef6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..848aad018b1948b1a11f4ddb7d6c2a0346f2ec73
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/31a4fd889af371d0c4564d327bbdd69f6482c3930a8761ffe6e2103028a9aef6.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -6057,
+  "dataset": "marble-joined",
+  "doc_id": "31a4fd889af371d0c4564d327bbdd69f6482c3930a8761ffe6e2103028a9aef6",
+  "engine": "marble-apple-vision",
+  "event_count": 77,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "7bc0665a04d6442ecbfc6225aa2dd6810f92a80b4fac3c8d1d220506b898a75d",
+  "output_sha256": "b7ec3619278364ead51f0d0e5fc363302716db825fcfe5a809919968637c3a7d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/32ca4b6204843b53fe8c52aa94e32ab27e7c3aa0fbc43f4a4996dbcd06724292.md b/vision-fixhub/ds9-unparsed-06/32ca4b6204843b53fe8c52aa94e32ab27e7c3aa0fbc43f4a4996dbcd06724292.md
new file mode 100644
index 0000000000000000000000000000000000000000..10ec23486c44b65bec834668f4b829b3a5da502c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/32ca4b6204843b53fe8c52aa94e32ab27e7c3aa0fbc43f4a4996dbcd06724292.md
@@ -0,0 +1,9 @@
+From:
+To: Dave Brannon
+Subject: Rodriguez Plea Agreement.pdf
+Date: Wed, 27 Jan 2010 19:28:24 +0000
+Importance: Normal
+Attachments: Rodriguez_Plea_Agreement.pdf
+Hi Dave - Here you go. Can you double-check that I don't have any mistakes? Thanks.
+«Rodriguez Plea Agreement.pdf>>
+Assistant U.S. Attorney
diff --git a/vision-fixhub/ds9-unparsed-06/32ca4b6204843b53fe8c52aa94e32ab27e7c3aa0fbc43f4a4996dbcd06724292.receipt.json b/vision-fixhub/ds9-unparsed-06/32ca4b6204843b53fe8c52aa94e32ab27e7c3aa0fbc43f4a4996dbcd06724292.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0b8eaf50e65eaa1852055385d0725052ad675752
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/32ca4b6204843b53fe8c52aa94e32ab27e7c3aa0fbc43f4a4996dbcd06724292.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "32ca4b6204843b53fe8c52aa94e32ab27e7c3aa0fbc43f4a4996dbcd06724292",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "6b85dd0770ca86335ebb6e62b9cc6e8e5d8d52ead0a9e1d974b674c23b14c5ec",
+  "output_sha256": "458fe136bb15f173efa02414227a02a16692746063a546159f3242f0fa5cf63a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3308d8dfd03de4f0d3b0d7f2fe46d0eea2af178320d7b614b8571b19a458944a.md b/vision-fixhub/ds9-unparsed-06/3308d8dfd03de4f0d3b0d7f2fe46d0eea2af178320d7b614b8571b19a458944a.md
new file mode 100644
index 0000000000000000000000000000000000000000..c28ff0aad9cfd1c0b1007da5be953257b331a55a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3308d8dfd03de4f0d3b0d7f2fe46d0eea2af178320d7b614b8571b19a458944a.md
@@ -0,0 +1,67 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 S. Australian Ave, Ste 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+February 11, 2010
+DELIVERY BY ELECTRONIC MAIL
+Roy Black, Esq.
+Black Srebnick Kornspan & Stumpf P.A.
+201 S. Biscayne Blvd, Suite 1300
+Miami, FL 33131
+Re: Jeffrey Epstein
+Dear Mr. Black:
+Thank you for meeting with our Office last week. During our discussion, you and your
+colleagues raised three issues: (1) whether our Office would consider it a breach of the Non-
+Prosecution Agreement for Mr. Epstein to file suit against the victim's attorney-representative
+relating to the amount of attorney's fees; (2) whether our Office would consider it a breach of the
+Non-Prosecution Agreement for Mr. Epstein to argue that he has no liability for claims raised
+exclusively under 18 U.S.C. § 2255 as to any of the victims on the identified list; and (3) whether
+our Office would have any objection to Mr. Epstein applying for early termination of his community
+control.
+As we have told you before, our Office cannot give advisory opinions as to what will and
+will not be a breach of the Non-Prosecution Agreement. Furthermore, as to the first item, your
+colleagues admitted that efforts to reach an agreement with Robert Josefsberg regarding the amount
+of fees owed have not been completed. Similarly, as to the second item, your colleagues admitted
+that there are no currently pending cases arising exclusively under 18 U.S.C. § 2255 as to any of the
+victims on the identified list. Given that these matters may never arise and, if they do arise, there
+will be innumerable legal and factual issues that have not been shared with our Office, we again
+decline to provide any advisory opinions. As discussed during the meeting, the purpose of having
+the parties and a Special Master involved at the beginning of the process in the selection of the
+attorney-representative was to avoid dealing with this issue at the end of the process. As with all
+matters related to the Agreement, we expect that Mr. Epstein will act in good faith and comply with
+the letter and spirit of the NPA.
+As to the third item, we have reviewed your letter to Mr. Sloman of February 8, 2010. While
+Mr. Acosta did state in his letter of December 19, 2007, that he did not believe that the Office was
+
+
+Roy BLACK, EsQ.
+FEBRUARY 11, 2010
+
+obligated to notify the victims identified through the federal investigation of proceedings occurring
+in state court, the U.S. Department of Justice's position may have changed in the interim in light of
+internal guidance regarding prosecutors' obligations pursuant to 18 U.S.C. § 3771, 42 U.S.C. §
+10607, and Fed. R. Crim. P. 60 (effective December 1, 2008).
+In light of Mr. Acosta's prior statements to Mr. Epstein's counsel that Mr. Epstein would be
+eligible for any benefit available to other similarly-situated state defendants, the Office agrees that
+Mr. Epstein may apply for early termination or modification of community control in accordance
+imposed in the community control plan.
+rip sed int.he comms miy 208.ro 4) assuming tale akes in action red the sanctions
+application; it is entirely within the discretion of the State Attorney's Office and the Palm Beach
+County Circuit Court Judge as to whether it is in "the best interests of justice and the welfare of
+society" to allow Mr. Epstein to terminate prematurely his community control. Mr. Epstein and his
+counsel may not make a representation to the State Attorney's Office, the Court, or any victim that
+the U.S. Attorney's Office agrees with, joins in, or does not oppose such a motion. In light of prior
+erroneous statements in court filings, we respectfully request that a copy of any court filing be
+provided to our office.
+If such a motion is made, in accordance with your proposal, the U.S. Attorney's Office will
+notify the federal victims that the application was filed and, if a hearing is scheduled, the date, time,
+and location of such hearing. The communication will consist merely of a notification and will
+neither encourage nor discourage attendance or submission of materials related to the application.
+Sincerely,
+Jeffrey H. Sloman
+United States Attorney
+cc: Jeffrey H. Sloman, U.S. Attorney
+Dabad IZ Gasion Matice Theat Manita
diff --git a/vision-fixhub/ds9-unparsed-06/3308d8dfd03de4f0d3b0d7f2fe46d0eea2af178320d7b614b8571b19a458944a.receipt.json b/vision-fixhub/ds9-unparsed-06/3308d8dfd03de4f0d3b0d7f2fe46d0eea2af178320d7b614b8571b19a458944a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..efb4c141abce47439ba22a6660df740d401730c4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3308d8dfd03de4f0d3b0d7f2fe46d0eea2af178320d7b614b8571b19a458944a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -35,
+  "dataset": "marble-joined",
+  "doc_id": "3308d8dfd03de4f0d3b0d7f2fe46d0eea2af178320d7b614b8571b19a458944a",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "e49a191415b6473be5f69252db5f9c2b432631ef3a4088c8e7938e4e93ea1098",
+  "output_sha256": "88341e30882df7a2a5252ee9276e9d8d0d8b679a828c1efc6fed39cbc589992b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/335056efaa284bdbd64e85f679a4d16464e06d3b7c5ef636770b1c4d50081132.md b/vision-fixhub/ds9-unparsed-06/335056efaa284bdbd64e85f679a4d16464e06d3b7c5ef636770b1c4d50081132.md
new file mode 100644
index 0000000000000000000000000000000000000000..c5de53079e31f12894488a5aa522600cda2ba322
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/335056efaa284bdbd64e85f679a4d16464e06d3b7c5ef636770b1c4d50081132.md
@@ -0,0 +1,370 @@
+Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 1 of 6
+JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE
+CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE
+REMEDIES
+CASE NO:
+08-80736-Ciy-Marra/Johnson
+
+
+
+Case 9:08-cv-80736-KAM Document 48-2
+Entered on FLSD Docket 03/21/2011 Page 2 of 6
+•
+FD-302 (Rev. 10-6-95)
+- 1-
+FEDERAL BUREAU OF INVESTIGATION
+Date of transcription 08/14/2007
+was interviewed in West Palm Beach,
+Florida, regarding a
+tederal investigation involving the sexual
+exploitation of minors.
+After being advised of the identity of the
+interviewing agents and the nature of the interview,
+provided
+the following information:
+In 2003 Or 2004
+was
+• introduced to JEFFREY EPSTEIN
+for the purpose of providing him with personal massages.
+was
+approached at a party by a female she believed was named
+She described the female as having brown hair and taller
+The
+female was later identified as
+told
+and
+l's friend,
+that they could make money by
+providing massages to EPSTEIN.
+• told
+I that she could
+provide the massages with her clothes on or off.
+• who was
+fifteen years old,
+believed that she was close to turning sixteen
+when she first met EPSTEIN.
+However, during
+• first contact
+with EPSTEIN, she told him that she had just turned eighteen.
+and
+traveled to EPSTEIN's residence in Palm
+Beach by
+tax
+was
+I at the time.
+Once at the
+residence,
+took
+upstairs. EPSTEIN entered the room
+wearing only a rope.
+Once EPSTEIN had removed the robe, both
+and
+and
+provided EPSTEIN with a massage.
+had removed their clothing and remained only in their
+underwear. EPSTEIN asked
+to leave.
+Once alone with
+EPSTEIN began to
+was uncomfortable.
+After
+EPSTEIN climaxed the massage was over.
+believed that
+had mentioned EPSTEIN might
+• during the massage but
+she
+was still very surprised when he
+EPSTEIN paid
+$200.00.
+EPSTEIN did not touch'
+during that massage.
+departed EPSTEIN's residence with two men that worked for EPSTEIN.
+They drove |
+to a Shell Gas Station located near Okeechobee
+Boulevard and the Florida Turnpike.
+Prior to departing the residence,
+provided her
+telephone number to one of EPSTEIN's assistants,
+(PHONETIC) .
+described her as a
+¡remale in
+her early twenties, with long brown hair
+and approximately 5'5" to
+5'6" tall.
+stated that
+another of EPSTEIN's
+assistants, of EPSTEIN would usuarty
+contact her.
+would
+telephone and ask if she was available or if she had any other
+Investigation on
+08/07/2007
+" West Palm Beach, Florida
+File • 31E-MM-108062
+by
+SA
+SA
+Date dictated 08/07/2007
+This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency:
+it and its contents are not to be distributed outside vour agency
+
+
+Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 3 of 6
+Continuation of FD-302 of
+, On 08/07/2007
+.. Page.
+2
+girls she could bring.
+When EPSTEIN telephoned,
+• he usually asked
+for
+to come over.
+According to
+EPSTEIN's house
+telephone number began with the
+digits 655.
+She would call
+sometimes and leave a message.
+stated that when they
+telephoned her they would inform c
+back to town and if
+she might have anyone new.
+did not
+believe that EPSTEIN ever really liked her.
+traveled to the EPSTEIN's residence during 2003 and
+2004 over twenty five times.
+believed that she
+provided
+EPSTEIN with approximately 10-15 massages. EPSTEIN initially
+started out touching l
+but gradually the massages
+became more sexual. EPSTEIN would instruct
+on how and what to
+do during the massages.
+He would request
+to rub his chest and
+stated that on approximately two occasions, BPSTEIN
+asked that
+remove her underwear and provide the massage nude.
+complied.
+stated that BPSTEIN would make her feel that
+she had the option to do what she wanted.
+During one massage,
+stated that she had been giving
+EPSTEIN a massage for approximately 30-40 minutes when instead of
+EPSTEIN turning over to l
+EPSȚEIN brought another female
+into the massage area.
+described the female as a beautiful
+blonde girl, a "Cameron Diaz" type, 19 years of age, bright blue
+eyes, and speaking with an accent.
+EPSTEIN had
+straddle the
+female on the massage dante.
+EPSTEIN wanted
+to touch the
+females
+. According to
+EPSTEIN "
+• the female
+while
+was straddled on top
+of the female:
+stated she
+could hear what she believed to be
+said for
+EPSTEIN it was all about
+the female.
+After the female
+EPSTEIN patted wo
+•on
+the shoulder and she removed
+herself from the table.
+into the spa/sauna.
+The female got up from the table and went
+EPSTEIN commented to
+minutes
+: the female would realize what had just happened to her.
+received $200.00.
+advised the interviewing agents that EPSTEIN had
+used a
+EPSTEIN asked her first if he
+could use the
+• on her.
+_stated that she had held her
+breath when EPSTEIN used the
+Ton her.
+_stated
+that at no time during any of
+the massages had EPSTEIN caused her
+During another massage,
+believed by this time she
+was seventeen,
+EPSTEIN placed his hand on
+touching
+
+
+Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 4 of 6
+Continuation of FD-302 of
+• On 08/07/2007
+_ Page .
+- 3
+was uncomfortable and told him to stop.
+EPSTEIN complied.
+stated that the incident freaked her out.
+Istated that EPSTEIN was upset because she was upset.
+never return to the residence.
+stated that she did not deal
+with EPSTEIN anymore after that incident.
+EPSTEIN gave both
+and
+"Massage for Dummies".
+They recel
+EPSTEIN also commented how strong
+each a book entitled
+the books on the same visit.
+s hands were when it came to
+her providing his massages.
+On another occasion,
+mentioned to EPSTEIN that she
+was looking at a car
+Toyota Corolla.
+EPSTEIN provided
+with
+$600.00 - $700.00.
+stated that EPSTEIN gave her the money
+after the incident with
+the other female.
+According to
+EPSTEIN would ask her to bring him
+other girls.
+who started dancing
+when she was
+16, brought girls from the
+• as well as from other sources.
+stated she brought girls from fifteen years of age to twentyfive years of age.
+stated that EPSTEIN would get frustrated
+with her if she did noc nave new females for him.
+On one instance,
+EPSTEIN hung up on her because she could not provide him with
+anyone new.
+Istated that EPSTEIN's preference was short,
+little, white girls.
+stated that EPSTEIN was upset when one
+of the
+other girls brought a black girl.
+stated that EPSTEIN
+did not want black girls or girls with tatoos.
+stated that one of the girls she stayed with on
+occasion,
+also started providing EPSTEIN with
+massages.
+number for
+was
+said that her family resides inl
+F10
+PODDED Y
+also stayed with
+during this same
+time period.
+However,
+never went to EPSTEIN's house or
+provided him with massages.
+has a
+address.
+Another girl that
+had taken to EPSTEIN's residence
+was
+Last Name Unknown (LNU) -
+According to
+• EPSTEIN
+liked
+LNU a lot.
+said that she was never a favorite of
+EPSTEIN. EPSTEIN offered W
+T$300.00 to bring!
+LNU.
+LNU was a couple years younger than
+believed tha
+vas either 16 a
+said that
+any part of it after that.
+LNU if she saw her photograph.
+2-3 times but that she did not want
+believes she could identify
+also stated that
+LNU at
+
+
+Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 5 of 6
+FD-302e (Rev. 10-6-95)
+. On 0B/07/2007
+_, Page
+4
+Continuation of FD-302 of
+also
+one time attended
+believed that they had met through a group of trienas
+wilile
+attending
+mentioned another girl by the name of
+EPSTEIN distinguished the two
+by referring to
+as
+worked at an
+shop.
+stated that she did not like
+and that
+was a storyteller and a bad liar.
+stated that
+never
+really wanted to go to EPSTEIN's residence but she went anyway.
+said that she had not taken a good 1o0k at EPSTEIN's
+explained that it seemed like he would always try and
+hide his
+• stated that EPSTEIN never asked her for sex.
+started dancing when she was sixteen
+let her dance.
+The owner,
+worked at
+Beach, Florida.
+located
+has also
+in Boynton
+during the years she provided
+Said that EPSTEIN tried to provide her
+EPSTEIN with massages.
+with advice regarding
+stated that she met with EPSTEIN's attorneys,
+and a unidentified female (UF), at the ALE HOUSE RESTAURANT.
+met with them after she contacted]
+•, who confirmed that
+tney
+were really working for EPSTEIN.
+stated that l
+also
+balked of her
+and stated that she was living in
+Manhattan.
+found out that
+and the UF are employed by
+They asked a lot of questions.
+They
+specifically asked
+about
+land a l
+reiterated
+her dislike for
+spoken to
+told
+videoed her.
+confirmed her association to the following telephone
+numbers:
+Old cellular number -.
+Possibly an old cellular number
+Is telephone number
+
+
+Case 9:08-cv-80736-KAM Document 48-2 Entered on FLSD Docket 03/21/2011 Page 6 of 6
+Continuation of FD-302 of
+, On 08/07/2007_,Pagc
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/335056efaa284bdbd64e85f679a4d16464e06d3b7c5ef636770b1c4d50081132.receipt.json b/vision-fixhub/ds9-unparsed-06/335056efaa284bdbd64e85f679a4d16464e06d3b7c5ef636770b1c4d50081132.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..28efb5b584b279381564e346a8416448316073cb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/335056efaa284bdbd64e85f679a4d16464e06d3b7c5ef636770b1c4d50081132.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -215,
+  "dataset": "marble-joined",
+  "doc_id": "335056efaa284bdbd64e85f679a4d16464e06d3b7c5ef636770b1c4d50081132",
+  "engine": "marble-apple-vision",
+  "event_count": 9,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "fc33e8681ac6edb4a5ec0f780442805e8e36af104b089ba499751bfb09551cb8",
+  "output_sha256": "6049699c28195cdbe8f0d4c05583ef90fea44450e24c81b91ec8efeffb050ba6",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/33d156ad18cf3978ab8373bc0561a25d5e7c1c94a6b18f35e1a806f71189db00.md b/vision-fixhub/ds9-unparsed-06/33d156ad18cf3978ab8373bc0561a25d5e7c1c94a6b18f35e1a806f71189db00.md
new file mode 100644
index 0000000000000000000000000000000000000000..43a8aca9c0b3b4c2ab9d72742beb8396eba4999f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/33d156ad18cf3978ab8373bc0561a25d5e7c1c94a6b18f35e1a806f71189db00.md
@@ -0,0 +1,33 @@
+From:
+To:
+Subject: RE: Request for Official Comment on an Investigation
+Date: Thu, 29 Jul 2010 19:03:41 +0000
+Importance: Normal
+Hi
+- Thank you.
+From:
+Sent: Thursday, July 29, 2010 1:34 PM
+Cc:
+Subject: FW: Request for Official Comment on an Investigation
+FYI - second inquiry of the day. I have replied the same to both.
+From:
+Sent: Thursday, July 29, 2010 1:33 PM
+To: 'Reeve, Elle'
+Cc: 0
+Subject: RE: Request for Official Comment on an Investigation
+Hi Elle.
+Thank you for your email. The USAO cannot comment. It is against DOJ and USAO Guidelines to either
+confirm or deny the existence of any investigation. Thank you for checking with me.
+From: Reeve, Elle [mailto: E
+Sent: Thursday, July 29, 2010 12:19 PM
+To:
+Subject: Request for Official Comment on an Investigation
+Hello
+My name is Elle Reeve and I'm a fact-checker with the news website The Daily Beast. We're running an article stating that
+the FBI has re-opened an investigation into Jeffrey Epstein, that the investigation has been widened to include Epstein's
+associate Jean Luc Brunel plus Brunel's modelling agency, and that investigators are looking for evidence of child
+trafficking. Would you be able to give us an official response to these claims?
+Thank you,
+Elle Reeve
+
+
diff --git a/vision-fixhub/ds9-unparsed-06/33d156ad18cf3978ab8373bc0561a25d5e7c1c94a6b18f35e1a806f71189db00.receipt.json b/vision-fixhub/ds9-unparsed-06/33d156ad18cf3978ab8373bc0561a25d5e7c1c94a6b18f35e1a806f71189db00.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c38089571aebc80b760723c133aea8d344e37b9b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/33d156ad18cf3978ab8373bc0561a25d5e7c1c94a6b18f35e1a806f71189db00.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "33d156ad18cf3978ab8373bc0561a25d5e7c1c94a6b18f35e1a806f71189db00",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "2f3941e14c4b75efef510c8ce0b40aec8afee943968ab090dd00fdc7efa211bb",
+  "output_sha256": "2ba95ff54725dd71084f02fe7d7901882a755a7c5850056f36f52d8de36a4b75",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3452e46948743160ffda24e95e606b55fe8c9f69ba83139bcbaf017bb100d5c9.md b/vision-fixhub/ds9-unparsed-06/3452e46948743160ffda24e95e606b55fe8c9f69ba83139bcbaf017bb100d5c9.md
new file mode 100644
index 0000000000000000000000000000000000000000..108526fa4cbd9b004be5ee666ceb4eee33e23c46
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3452e46948743160ffda24e95e606b55fe8c9f69ba83139bcbaf017bb100d5c9.md
@@ -0,0 +1,85 @@
+Entered on FLSD Docket 06/05/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON
+Plaintiff,
+VS.
+JEFFREY EPSTEIN and :
+Defendants.
+PLAINTIFF,
+Plaintiff,
+by and through her undersigned counsel, hereby files her
+Conditional Notice of Intent to Exclusively Rely on Statutory Damages Provided by 18
+U.S.C. §2255, and in support thereof states as follows:
+1. This is an action to recover money damages against Defendant,
+JEFFREY EPSTEIN, for acts of sexual abuse and prostitution committed upon the thenminor, l
+2.
+Plaintiff has plead thirty separate counts against EPSTEIN for separate
+incidences of abuse committed by EPSTEIN against Plaintiff pursuant to 18 U.S.C.
+§2255. 18 U.S.C. §2255, entitled "Civil remedy for personal injuries", creates a private
+right of action for minor children who were the victim of certain enumerated sex
+offenses. 18 U.S.C. §2255 also creates a statutory floor for the amount of damages a
+
+
+Document 113 Entered on FLSD Docket 06/05/2009 Page 2 of 4
+victim can recover for a violation of same. Plaintiff has also alleged a single count of
+Sexual Battery against EPSTEIN as well.
+3.
+There presently exists between the Plaintiff and EPSTEIN a disagreement
+as to whether the statutory damage floor established in 18 U.S.C. §2255 is recoverable
+for each commission of an enumerated sex offense listed in 18 U.S.C. §2255, or
+whether the statutory damage floor can only be enforced once, regardless of how many
+times a defendant perpetrates an enumerated sex offense against a minor victim.
+4. This disagreement between the parties is properly the subject of
+Defendant's Motion to Dismiss First Amended Complaint For Failure to State a Cause
+of Action, and Motion For More Definite Statement; Motion to Strike, and Supporting
+Memorandum of Law (D.E. 47) which is currently pending before this Court.
+5.
+In the event that the Court rules that the Plaintiff is entitled to recover the
+statutory damages created by 18 U.S.C. §2255 for each violation', Plaintiff will be
+pursuing only those statutory damages, and will not pursue damages available at
+common law.
+6.
+Should the Court rule however, that the statutory damage floor can only
+be applied once, Plaintiff will be pursuing any and all damages available to her, whether
+they be pursuant to statute or by common law.
+' The parties also disagree about the amount the statutory damage floor should be for this case. 18
+U.S.C. §2255 was amended in 2006 to increase the floor from $50,000 to $150,000. The parties
+essentially disagree about which version of 18 U.S.C. §2255 should apply in this case.
+
+
+Entered on FLSD Docket 06/05/2009
+
+-
+Respectfully submitted,
+Is/Jack P. Hill
+JACK SCAROLA
+Florida Bar No.
+JACK P. HILL
+Florida Bar No.i
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+Attorneys for Plaintiff,
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on June 5th, 2009, I electronically filed the foregoing
+document with the Clerk of Court using CM/ECF. I also certify that the foregoing
+document is being served this day on all counsel of record identified on the attached
+counsel list via transmission of Notices of Electronic Filing generated by CM/ECF.
+Ls/Jack P. Hill
+JACK SCAROLA
+Florida Bar No.
+JACK P. HILL
+Florida Bar No.:
+Searcy Dennev Scarola Barnhart & Shipley, P.A.
+Attorneys for Plaintiff,
+
+
+Entered on FLSD Docket 06/05/2009 Page 4 of 4
+COUNSEL LIST
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+Bruce E. Reinhart, Esquire
+Bruce E. Reinhart, P.A.
+Robert Critton, Esquire
+Burman Critton Luttier & Coleman LLP
+Richard H. Willits, Esquire
+Richard H. Willits, P.A.
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/3452e46948743160ffda24e95e606b55fe8c9f69ba83139bcbaf017bb100d5c9.receipt.json b/vision-fixhub/ds9-unparsed-06/3452e46948743160ffda24e95e606b55fe8c9f69ba83139bcbaf017bb100d5c9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2b2929723bae83ce1b2eb593a4b26e765b94b903
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3452e46948743160ffda24e95e606b55fe8c9f69ba83139bcbaf017bb100d5c9.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -181,
+  "dataset": "marble-joined",
+  "doc_id": "3452e46948743160ffda24e95e606b55fe8c9f69ba83139bcbaf017bb100d5c9",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "881334654cfebe277a77d76354487633640ec3b820aa85d6a1310e875b24706b",
+  "output_sha256": "f6475f31f0ce3457df9c2cef5cb52a3eca0429732ee2a62b22fc7c22fa5850d5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/34bc243dc86e287da6684f78eca8b9ca7fed5e197ddd2accf9fa96bf95afea69.md b/vision-fixhub/ds9-unparsed-06/34bc243dc86e287da6684f78eca8b9ca7fed5e197ddd2accf9fa96bf95afea69.md
new file mode 100644
index 0000000000000000000000000000000000000000..cb38c5841b2bc1c7386e67b53904203d94b09bfb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/34bc243dc86e287da6684f78eca8b9ca7fed5e197ddd2accf9fa96bf95afea69.md
@@ -0,0 +1,1556 @@
+Questions or Changes?
+• attwireless.com
+Toll Free 1 866 293-4634
+611 from your wireless phone
+• TTY users - 1 866 4-AWS-TTY
+SUMMARY OF MONTHLY CHARGES FOR ACCOUNT 0031035751
+Previous
+Payments
+Balance
+Account
+Received
+Adjustments
+71.31
+-71.31
+0.00
+Balance
+Forward
+0.00
+Your billing cycle ended on March 14, 2004
+Current Monthly Charges
+Subscriber Adjustments
+Monthly Service
+Monthly Usage
+Charges
+Credits
+Taxes, Surcharges & Regulatory Fees
+Total Current Monthly Charges DUE UPON RECEIPT
+TOTAL AMOUNT DUE
+Date of Invoice: March 15, 2004
+Current Monthly
+Charges
+69.50
+Total
+Amount Due
+69.50
+0.00
+54.97
+2.50
+0.00
+0.00
+12.03
+69.50
+69.50
+IMPORTANT ACCOUNT INFORMATION:
+IF YOU CANCEL SERVICE BEFORE YOUR CONTRACT END DATE
+(INCLUDING IF YOU SWITCH YOUR WIRELESS NUMBER TO
+ANOTHER CARRIER), YOU WILL BE CHARGED AN EARLY
+TERMINATION FEE OF UP TO $200.
+AT&T WIRELESS APPRECIATES YOUR BUSINESS
+2 AT&T Wireless
+Account Name:
+see reverse - signature required
+Note: =>
+We Print on
+Front and Back
+Service # 5613797824
+Account # 0031035751
+Total
+Amount Due
+69.50
+Chack her for change.
+Amount
+Paid
+#BWNHNGB
+#0000000310357512# w
+1029393 02 AT 0.517 **AUTO T60 0914 33411. 5.41.03.1034.0000
+Date Due
+UPON RECEIPT
+AT&T WIRELESS
+PO BOX 8229
+AURORA IL 60572-8229
+
+
+
+*52050501D00*
+REFT (Recurring Electronic Fund Transfer): To enroll: sign below, check the REFT box on the reverse side and
+remit with this month's payment. Keep paying your bill until your statement indicates "Do Not Pay."
+REFT Agreement: 1 authorize my financial institution to deduct the amount of my monthly wireless phone bill from
+the account associated with the enclosed check and remit payment to AT&T Wireless. This authority will be
+effective until | notify AT&T Wireless to terminate it. I agree that I may be assessed a service charge (up to $20) or
+late fee or both if a payment is returned by my bank. For more information visit attwireless.com or call 1 866
+293-4634.
+Questions? We can help: AT&T Wireless appreciates your business and welcomes the opportunity to assist you.
+As part of our commitment to you, we are always adding new calling plans and promotions to match your individual
+needs. Visit our website at attwireless.com or contact our Customer Care at 1 866 293-4634 or dial 611 from your
+wireless phone. ¿Sabias que también ofrecemos servicio al cliente en tu idioma? Marca 611 desde tu teléfono
+inalámbrico, o 1 866 293-4634 desde cualquier teléfono y oprime el *.
+Driving Wireless Safety: Your wireless phone gives you the freedom and flexibility to stay in touch when you
+travel, but don't let a phone call distract you from driving safely. Use hands-free device if allowed or required by
+law. Call Carefully, Arrive Safely.
+AT&T Wireless Processing Fees: Accounts suspended for non-payment will be subject to a $25 reactivation fee
+per line and may be assessed a security deposit prior to reinstatement. Checks returned for non-sufficient funds will
+be charged up to a $20 fee.
+Local Tax: Local taxes are based on local government boundaries, the address information you provide for your
+account and/or your wireless telephone number. Please review the local tax charges on your bill. If you believe
+there is an error in the local tax charge, please contact us immediately at 1 866 293-4634. Please note that some
+local or state laws may require you to follow special procedures when notifying us about a local tax dispute. You
+may also use the form below to notify us of any change to your taxing address. Thank you for your cooperation
+Please Send Correspondence To:
+AT&T Wireless Next Generation Correspondence
+P.O. Box 68056
+Anaheim Hills, CA 92817-8056
+1029093.000025185.5
+Change of Address Only. Please print address clearly and check the box on the reverse side. Please contact Customer Care to change the
+Name and transfer Financial Responsibility.
+New Billing Address
+City
+State
+Zip
+Home Phone (
+Work Phone (.
+If your billing address is NOT your Tax Address*, please enter the Tax Address below. (Multi-line accounts should attach a list of each wireless number and
+the respective Tax Address.)
+New Tax Address*
+Wireless Number (
+City
+State
+Zip
+Under Federal laws, your Tax Address must be: your primary place of use, your residential or business address, and located within AT&T Wireless
+censed service area. Non-business customers on AT&T Digital One Rate, Regional Advantage or Shared Advantage plans must use their residenti
+address as their tax address.
+Recurring Electronic Fund Transfer (REFT) Enrollment. Please read the agreement on the top portion of this page, sign below and check the
+"REFT Registration" box on the reverse side.
+6.1 - 3G
+Financial Account Holder Signature
+• I do not wish to receive email notilication of special ollers avalable to AT&T Wireless customers.
+
+
+
+ACCOUNT DETAILS
+Detail of Payments - Thank You!
+Item Description
+1 PAYMENT
+Total of Payments
+Date Applied/Reversed Payment Amount
+03/12/04
+-71.31
+Current Subscriber Monthly Charges and Credits
+Subscriber Number
+Subscriber Name
+
+Total Current Subscriber Monthly Charges and Credits
+Total Current Monthly Charges
+SUMMARY OF CURRENT ACTIVITY
+Monthly Service Charges
+Item Description
+1 CALL WAITING
+2 AT&T TEXT MESSAGING
+3 CALLER ID
+4 AT&T VOICEMAIL
+5 DETAIL BILLING
+6 $39.99 CHARTER OFFER
+7 1000 NIGHT AND WEEKEND MINUTES
+8 CALL FORWARDING
+9 THREE WAY CALLING
+Total Monthly Service Charges
+Service Dates
+02/15/04 - 03/14/04
+02/15/04 - 03/14/04
+02/15/04 - 03/14/04
+02/15/04 - 03/14/04
+02/15/04 - 03/14/04
+02/15/04 - 03/14/04
+02/15/04 - 03/14/04
+02/15/04 - 03/14/04
+02/15/04 - 03/14/04
+Monthly Usage Charges
+Item Description
+1 1000 NIGHT/WKEND MIN
+2 DROP CALL CREDIT
+3 500 ADD'L ANYTME MIN
+4 MESSAGE RETRIEVAL
+5 AT&T CONNECT
+6 CALL COMPLETION
+7 CALL WAITING
+8 100 INCL. MSGS SENT
+9 INCL. IN PLAN DATA
+10 INCLUDED MINUTES
+Total Monthly Usage Charges
+1,024 Kilobytes (KB) = 1 Megabyte (MB)
+Onty Used
+600 MIN
+4 MIN
+500 MIN
+20 EVT
+2 EVT
+14 EVT
+78 EVT
+4 KB
+142 MIN
+Taxes, Surcharges and Regulatory Fees
+Item
+Description
+1 UNIVERSAL CONNECTIVITY CHARGE
+2 STATE COMM SERVICE TAX
+3 LOCAL COMM SERVICE TAX
+4 COUNTY 911 TAX
+-71.31
+-71.31
+69.50
+69.50
+69.50
+0.00
+4.99
+0.00
+0.00
+0.00
+39.99
+9.99
+0.00
+0.00
+54.97
+88888
+8882k
+SUMMARY OF CURRENT ACTIVITY - CONTINUED
+Taxes, Surcharges and Regulatory Fees - Continued
+Item Description
+5 FEDERAL TAX
+Total Taxes, Surcharges and Regulatory Fees
+TOTAL CHARGES FOR (561)379-7824
+DETAIL OF CURRENT ACTIVITY
+VOICE USAGE FOR (561)379-7824
+Item Date Time Called
+Calls To
+02/15
+(361/301-
+-9368
+(561)798-0772
+(561)92-8375
+(561)818-3331
+(561)315-7476
+(561)818-3331
+561 315-7476
+(561)236-3299
+561)798-8807
+61)818-3331
+561 818-3331
+(561
+7478
+-331
+561)818-333
+61 818-333
+dEt dur tü cưuu
+Onty
+Used
+Rate Description
+2MIN
+C MIN
+ZZ2
+-FNN-
+
+12.83
+69.50
+IIN
+(561)543-3180
+(561)790-3459
+981920000 D606201
+......
+
+
+
+Item Date Time
+Called
+Onty
+Used
+SS 0216 0335P
+02/16
+54 02/16 04:14P (561|236-3299
+55
+02/16 04:24P
+56
+(561)818-3331
+02/16 04:43P
+5611818-3331
+57
+02/16 04:46P
+19
+0217 08.23А (951) 256-3295
+60
+02/17 10:21A
+(561)790-3459
+B2 02/17 09:15P
+48P (5611315-7476
+63 02/17 09:54P
+64 02/17 10:23P
+(561)379-7824
+Calls To
+COMIN
+COMIN
+WPALMBEACH FL
+VPALMBEACH FL
+NPALMBEACH FI
+TLAUDERDL F
+PALMBEACH P
+WPALMBEACH FL
+COMING
+AKE WORTH FI
+WPALMBEACH FL
+2 MIN
+65 02/17 10:27Р (561)315-7476
+KE WORTH F
+COMIN
+67
+02
+118
+(561)790-3459
+(561)790-3459
+(561)790-1060
+681-633
+6333
+1681-6333
+WPALMBEACH FL
+WPALMB
+WPALMBEACH
+WPALMBEACH FL
+(305)555-1212
+2 MIN
+10 MIN
+3 MIN
+3MIN
+1 EVT
+75
+02/18 12:23P
+(561)681-6333
+76 02/18 12:26P
+(5611790-1060
+WPALMBEACH FL
+WPALMBEACH FL
+77 02/18 12:29P
+(305)555-1212
+2 MIN
+1 EVT
+Rate Description
+500 ABBL ANYTME MIN
+500 ADD'L ANYTME MIN
+O0 ADD'L ANYTME MI
+00 ADD'L ANYTME MIT
+500 ADD'L ANYTME MIN
+SOO ABLAME MIN
+500 ADD'L ANYTME MIN
+DO ADD'L ANYTME MIl
+DOO NIGHT/WKEND MI
+1000 NIGHT/WKEND MIN
+JD0 NIGHT/WKEND M
+ESSAGE RETRIEVA
+DO0 NIGHT/WKEND M
+500
+500
+1.25
+78 02/18 12:30P (561)681-6333
+WPALMBEACH FL
+1 EVT
+WPALI
+1029393.000025186
+2000g
+
+88888
+g88888
+88859 89899
+071 02
+(561)
+*52060
+£ҐҐ Ґи £¿ґ
+1.25
+1.25
+
+Item Date Time
+Called
+Onty
+Used
+190 02/19 03:15₽
+111 02/19 03:23P (561)236-2293
+113 0219 03259
+114 02/19 06:10P
+116 02/19 10:22P (561)315-7476
+17 02/20 06:19A
+(561)792-5628
+11922006-22A
+(954)258-2985
+120 02/20 11:23A
+Calls To
+COMING
+WPALMBEACH FL
+MOOMING
+)HING
+INCOMING THEL
+WPALMBEACH FL
+FTLAUDERDL FL
+122 02/20 11344 (581/282-4331
+124 02/20 02264
+125 02/20 03:04P
+COMIN
+DHIN
+2 MIN
+2MIN
+IMIN
+IMIN
+2 MIN
+IMIN
+3 MIN
+
+
+(561 662-3
+
+Rate Description
+500 ABBL ANYTME MIN
+500 ADD'L ANYTME MIN
+00 ABBL ANYTME MIN
+O'L ANYTME
+500 ADD'L ANYTME MIN
+JO ADD'L ANYTME MIl
+J0O NIGHT/WKEND MI
+500 ADD'L ANYTME MIN
+500 ABBL ANYTME MIF
+I'L ANYTME
+500 ADD'L ANYTME MIN
+00 ABBL ANYTE MIA
+00 A
+500 ABD'L ANYTME MIT
+I'L ANYTMI
+500 ADD'L ANYTME MIN
+
+(561)798-8807
+315-7476
+(718)848-2677
+(561)662-7668
+(561)818-3331
+(561)818-3331
+(561)818-3331
+COMIN
+/PALMBEACH F
+WPALMBEACH FL
+LA
+VPAL
+WPALMBEACH FL
+NCOMING
+NPALMBEACH FI
+AKE WORTH F
+NPALMBEACH F
+WPALMBEACH FL
+WPALMBEACH FL
+NCOMING
+WPALMBEACH FL
+NCOMING
+COMING
+WPALMBEACH FL
+NOOMING
+NCOMING
+NCOMING
+COMINE
+2 MIN
+2 MIN
+I MIN
+2 MIN
+1 EV
+3 MIN
+2 MIN
+IMIN
+2MIN
+1 EVT
+2MIN
+2 MIN
+3MIN
+8 MIN
+500 ADD ANY THE MIN
+500 ADD'L ANYTME MIN
+500
+922
+D'L
+ANYTME MIN
+92
+ANY THE MIN
+OC
+Al
+ANYTME
+500 ADD'L
+ANYTME MIN
+500 ABBL
+500
+500
+AD
+D'L
+ANYTME MIN
+500 ADD
+D'L
+IYTME MIN
+500 ADD'L
+ANYTME MIN
+AD
+500฿
+500 ADD'L ANYTME MIN
+500 ABB'L ANYTME MIN
+500 ADD'L ANYTME MIN
+CALL WAITING
+500
+500
+AIN
+YTME MIN
+IIN
+100
+100
+1000
+1000
+1000
+NI
+1000
+NIGHTAKE
+
+
+
+Item Date Time
+Called
+173 82/21 19:384 (561) 790-1060
+:56A
+174 02/21 11:58A (561)236-3299
+175 02/21
+176 02/21
+12:07P
+12:07P
+561)753-5298
+177 02/21
+12:30P
+5611543-3180
+178 02/21
+12:31P
+561)662-7668
+179 02/21 12:33P (561)379-7824
+180 02/21 12:34P (561)379-7824
+Calls To
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+81 02/21 12:426
+82 02/2
+12:46P
+38798-165
+798-1
+183 02/21
+12:51P 561 601-6282
+184 02/21 01:02P
+185 02/21 01:03P
+561|236-3299
+561)236-3299
+186 02/21 01:04P
+(561)236-3299
+(561)236-3299
+(561)818-3331
+88222
+(561)
+J81
+-DO D0 00
+galE
+(561)818-3331
+(561)792-6375
+J818-3331
+790-1060
+(561)236-3299
+(561)236-3299
+5611236-3299
+(561)818-3331
+6F
+(561)790-3384
+(561|818-3331
+(561)236-2293
+(561)236-2293
+VPALMBEAC
+LAKE WORTH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+FL
+WPALMBEACH
+MBEACH
+IG
+FL
+MING
+FL
+ACH
+INCOMIN
+ICOMING
+COMI
+PALMBEACH F
+Qnty
+Used
+Rate Description
+2 MIN
+2 MIN
+2MIN
+1EVT
+EVT
+1 EVT
+2MIN
+1----
+- 10-CO--.
+---C-
+1000 NIGHT/KEND MIN
+00 NIGHT WKEND A
+JO NIGHT/WKEND R
+1000 NIGHT/WKEND MIN
+1000 NIGHT/WEND MIN
+CALL WAITING
+1000 NIGHT/WKEND MIN
+SSAGE RETRIEV
+OP CALL CREI
+MESSAGE RETRIEVAL
+JD NIGHTWKEND B
+0 NIGHT/WKEND N
+000 NIGHT WKEND MI
+DOO NIGHT WKEND MIl
+1000
+ENBI
+1001
+
+Called
+Item Date Time
+1 02/22 07:1
+5 02/22 10:44A (561)317-24
+236 02/22 10:52A (561|236-2293
+237
+38
+02/22 10:564 5611236-2293
+239 02/22 11:18A
+240 02/22 12:39P (561/662-1668
+242 02/22
+: 12:44P
+02/22
+02/22 01:56P (5721219-7943
+245 02/22 03:14P
+02/22 03:34P (561)236-3299
+88
+2 03:36P (561)762-665
+2 03:38R
+Calls To
+COMIN
+PALMBEACH
+WPALMBEACH FL
+STARTEACH FL
+NPALMBEACH F
+WORTH
+FL
+Onty
+Used
+1MIN
+3MIN
+2MIN
+2MIN
+Rate Description
+100
+100
+100
+100
+100
+
+BRRRRRRR
+
+38
+02
+
+88
+
+/22 04:40P
+cric
+- 5825
+co chich
+5611
+315-7476
+90929
+561)790
+561)790
+700-
+O CO
+561)236-2293
+(561)315-7476
+(554)
+NIN
+2290
+
+99999
+999
+1029399.000025187
+
+
+
+
+Item Date Time
+Called
+Calls To
+Onty
+Used
+0 0323 0822
+02/23 08-248
+1561238-2293
+300 02/23 08:25P (561 543-3180
+301
+02/25
+02
+08:26P
+02/23
+2828
+08:49P
+02/23 08:49P
+(561)798-8807
+82/23 08:58P (561)543-3180
+02/23 09:12P
+09:13P
+309
+022309:180
+561)790-1060
+02/23 09:23P (561)379-782
+WPALMBEACH FL
+PALMBEACH I
+WPALMBEACH FL
+MING
+NOMINC
+VPALMBEACH F
+VPALMBEACH F
+IMIN
+IMIN
+310 02/23 09:43P (561879-7831
+PALMBEACH F
+PALMBEACH F
+312 02/23 09:44P
+
+GENGENNNM MMM MON NENNONNNNNE
+(561)236-3299
+1)324-
+1236-
+0833
+(561)236-3299
+561 236-3299
+561)236-2293
+(561j236-2293
+61)791-485
+611236-329
+(561)801-3590
+(561)236-3299
+[561j236-3299
+(561)386-7455
+(954)258-2985
+561|236-2293
+(561)315-7476
+(561|317-2428
+6A11
+02-4276
+(561)628-8997
+561|236-2293
+(561)379-7824
+359
+02/26 10:22P (954|258-2985
+Rate Description
+500 ABBY ANY TME MIN
+500 ADD'L ANYTME MIN
+00 ADD'L ANYIME MIl
+00 ADD'L ANYTME MIl
+500 ADD'L ANYTME MIN
+00 ADD'L ANYIME MI
+0 ADD'L ANYTME MIl
+1000 NIGHT/KEND MIN
+OD NIGHT/WKEND M
+OO NIGHT/WKEND M
+1000 NIGHT/KEND MIN
+ESSAGE RETRIEV
+00 NIGHT WKEND MI
+000 NIGH T/WKEND MIT
+ESSAGE RETRIEVA
+1000 M
+ZZS
+MING
+OMING
+WALNB ACH
+223÷$r
+999
+WPALMBEACH FL
+WPALMBEACH FL
+NCOMING
+WPALMBEACH FL
+EACH FL
+-AC-
+1B
+FL
+EACH FLi
+WPALMB
+EACH FL
+WPALMBEACH FL
+FTLAUDERDL FL
+*52070503000*
+
+Item Date Time
+Called
+Calls To
+361 8226 10:32P (561)313-5654
+362 02/26 10:41P
+0221 06.02A 951/258-2985
+02/27 06:02A
+02/27 06:08A (561)792-5628
+02/27 86:30A (934)238-298
+2/27 06:30A
+02/27 06:31A (954)258-2985
+(27 06:36A (561)792-5628
+127
+06:39A
+02/27 01:22P
+
+(581)792-2178
+373 02/27 02 46P (561)324-1517
+HALAUDERDE FL
+WPALMBEACH FL
+FLAUBERL FL
+FTLAUDERDL FL
+WPALMBEACH FL
+NOOMING
+WALMACH FL
+WPALMBEACH FL
+NOOMNG
+
+GOONNOONONNONONNNS
+
+$88389458889838993
+(561)236-229
+)31
+15-
+-7476
+Ghận cn
+222
+geeen gg94฿
+Onty
+Used
+Rate Description
+I MIN
+MIl
+MIT
+2 MIN
+MIl
+1000 NIGHT/KEND MIN
+SOO ADEL ANTAE MIN
+500 ADD'L ANYTME MIN
+00 ABBL ANYTME MIF
+500 ADD'L ANYTME MIN
+O ADDI ANVIME M
+O ADD'L ANYTM
+500 ADD'L ANYTME MIN
+500 ABBL ANYTME MIN
+00 ADDL ANYIME MI
+J0 ADD'L ANYTM
+500
+98808 29 888888
+324
+1517
+(561)
+)309
+8686
+KE
+
+
+
+Item Date Time
+Called
+Calls To
+125 02/28 18:214 581) 236-2299
+PALMBE
+PALMBEACH I
+426 02/29 10:22A (561|236-3299
+WPALMBEACH FL
+4 MIN
+128 82/29 18:30A (961/236-2290
+128 02/29 10:50A
+2 MIN
+429 02/29 10:56A
+138 02/29 81:37P (581)712-6375
+432 02/29 02:06P
+33 02/29 02:361
+3 MIN
+34 02 29 03:06
+2 MIN
+435 02/29 04:34P
+ICO MINI
+7 02/29 08.34P (561)315-747
+AKE WORTH F
+13B 02/29 08:55H
+561)792-6375
+WPALMBEACH FL
+2 MIN
+139 03/01 08:25A (561)315-7478
+LAKE WORTH FL
+440 03/01 03:05P
+141 03/01 03:097
+COMIN
+42 03/01 03:36F
+COMIN
+444
+443 03/01 04:13P
+16 MIN
+445
+(561)393-9825
+PALMBEAI
+3 MIN
+1EVT
+446
+03/01
+09:14P
+447
+03/01
+09:16P
+611324-151
+1611601-628
+ARE WORE
+448
+03/01
+09:17P
+449 03/01 09:17P
+(561)790-1060
+WPALMBEACH FL
+150
+03/01 09:18P
+(561)790-1060
+WPALMBEACH FL
+03/
+/01
+NCOMING
+452
+03/
+/01
+09:22P
+09:23P (561)790-1060
+WPALMBEACH FL
+453
+03/01 09:23P
+454 03/01 09:23P
+2 MIN
+TEVI
+
+g8gg888g8888g88888888g
+
+BiSE
+AKB
+(561)315-7476
+LAKE
+Lundul i
+(561)676-2167
+561j236-2293
+88
+Qnty
+Used Rate Description
+Lula
+IT/WKEND N
+1000 NIGHT/KEND MIN
+DO NIGHTWKEND N
+DO NIGHT WKEND N
+1000 NIGHT/WKEND MIN
+DD0 NIGHT/WKEND MI
+000 NIGHT/WKEND MI
+1000 NIGHT/WKEND MIN
+1000 NIGHT WIEND
+MI
+ND
+1000 N
+CALL
+
+Called
+Item Date Time
+485 03/03 12:27P
+486 03/03 01:14P
+487 03/03 03:13P
+(561)236-3299
+188 03/03 03:13P
+489
+561)236-3299
+03/03 03:16P
+611236-3299
+490
+03/03 03:16P 561|236-3299
+491
+03/03 03:19P (561)236-3299
+492
+03/03 03:24P (561)315-7476
+493
+494
+03/03 03:50P
+03/03 04:19P
+495
+496
+03/03 04:27P (561)309-1375
+03/03 05:47P
+03/03 06 02Р
+3 06:02₽
+499
+500
+3/03 06:136
+03/03 06.13P 1561898-333
+501
+03/03 06:21P
+502 03/03 10:21P (561)379-7824
+503 03/03 11:25P (561)379-7824
+Calls To
+WPALMBEACH FL
+WPALMBEACH FL
+WARE WORTH FL
+COMIN
+VPALMBEACH F
+COMIN
+COMIN
+Onty
+Used Rate Description
+500 ABBLAME MIN
+500 ADD'L ANYTME MIN
+MIL
+MIl
+1MIN
+2 MIN
+8 MIN
+3MIN
+ML
+500 ADD'L ANYTME MIN
+500 ADD'L ANYTME MIN
+500 ADD'L ANYTME
+500 ADD'L ANYTME MIN
+500 ADD'L
+ANYTME
+500 ADD'L ANYTME
+: MIN
+500 ADD'L ANYTME MIN
+OD ADD'L ANYIME MIl
+DO ADD'L ANYTM
+:MIN
+500 ADD'L ANYTME MIN
+OD ADD'L ANYTME MIN
+100
+34090848238202049900033803288022-808
+
+3990or
+121
+13-
+-5654
+ҐЕ Ґґґґи ґґ¿
+# Ґиґ ґґґ
+88
+3299
+(561)
+
+
+
+1029393.000025188
+
+Item Date Time
+Called
+Onty
+Used
+S49 0305 87:32Р (772)219-4743
+550 03/05 07:44P (561)236-3299
+03/05 09:01P
+
+5611309-1375
+03/05 09:04P
+5611317-2428
+03/05 09:04P
+03/05 09:16P
+561)792-6375
+03/05 10:31P
+611309-132
+611792-6
+03/05 10:33P
+105
+11:37P (561)792-6375
+03/06
+01:13A
+03/06 01:24A
+(561)236-3299
+13106 01:33A
+03.
+106
+11-58A
+511309-137
+311601-628
+03/06
+03/06
+11:31A
+11:32A (561)662-7668
+03/06 11:35A
+561 662-7668
+03/06
+11:54A
+03/06 12:03P
+(561)379-7824
+03
+12:04P
+12-24P
+1211P
+Calls To
+STUART FL
+NCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WALEACH
+WPALMBEACH FL
+WPALMBEACH FL
+LAKE WORTH FL
+AKE
+COMIN
+VPALMBEACH F
+WPALMBEACH FL
+WPALMBEACH FL
+WPALME
+МРДІ
+MIl
+2 MIN
+3MIN
+'MIN
+I MIN
+3 MIN
+2 MIN
+
+03
+
+01:00P
+- 8300
+0600
+1060
+(561)762-6655
+WPALM
+WPALMR:
+Ŵ襥
+01:
+:16P
+03-
+24P
+(954)258-2985
+04:08P
+14-0OP
+05:52P
+OMINC
+FTLAUDERDL
+NCOMING
+COMING
+07:
+:25P
+
+
+8888888g
+BARRAS
+10
+5611379-7824
+
+g==880ggg-0060553886
+.....
+Rate Description
+«' «ґиґґл
+/T
+000
+*520805
+
+Onty
+Item Date Time
+Called
+Calls To
+Used
+Rate Description
+612 03/08 81 20Р (561)315-7476
+INCOMING THEL
+500 ABBL ANYTE MIN
+613 03/08 02:52P (561)315-7476
+AKE WORTH FL
+500 ADD'L ANYTME MIN
+614 03/08 03:00P (954)258-2989
+TLAUDERDL F.
+615 03/08 03:02P
+5611790-3459
+VPALMBEACH F
+616 03/08 03:24P (561)379-7824
+WPALMBEACH FL
+617 03/08 03:25P
+2EN
+618 03/08 03:27P
+9 03/08 04:24P (561)790-106
+WPALMBEACH FL
+0 08/08 04-31
+621 03/08 04:33P (5611790-1060
+MPALMBEACH FI
+622 03/08 05:10P 5611379-7824
+MPALMBEACH FI
+3MIN
+500 ADD'L ANYTME MIN
+SOARDE ANTENN
+500 ADD'L ANYTME MIN
+O ADDL ANVIME N
+O ADD'L ANYTI
+500 ADD'L ANYTME MIN
+MESSAGE RETRIE
+23 03/08 05:11P (561)236-3298
+24 03 08 05:408
+03/
+/08
+VPALMBEACH FI
+COMING
+ié888888888o88888ª88888889808o88gºeºG68888#E#=_00
+
+
+(561)
+160
+6282
+BE BRA
+
+- 3257
+)282
+(561)791-
+-3394
+88
+BARRA
+• = = v= =
+
+
+
+Item Date Time
+Called
+575 03/10 12:56P
+76 83/18 d2:39P (961)262:8891
+677 03/10 03:14P
+678 03/10 03:28P (561)282-8891
+679 03/10 03:30P
+6B0 03/10 03:32P (561)792-6375
+681 03/10 03:49P
+682 03/10 03:50P
+6B3 03/10 04:52P (561)282-8891
+B4 03/10 04:541
+85 03/10 05:39F
+686 03/10 05:47P
+(561)282-8891
+BB 03/18 08 388
+(561)282-8891
+B8 0
+589 03/10 07:01F
+590 03/10 07:04P
+063085893446383B939N8990898
+(561)792-6375
+(561)601-6282
+(561)753-7831
+Calls To
+WALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+COMINO
+COMINI
+WPALMBEACH FL
+WPALMBEACH FL
+PALMBEACH FI
+COMINC
+WPALMBEACH FL
+COMINO
+LAKE
+ORTH FL
+WPALMBEACH FL
+(561)662-6615
+CH FL
+(561)282-8891
+
+1|25
+5-
+-76
+bouga
+
+-88
+SENNAS
+ACH
+(561)315-7476
+(561)792-6375
+(561)317-2428
+561)313-5654
+561)313-5654
+(561)379-7824
+WRALMBEACHFL
+WPALMBEACH
+LAKE
+LAKE
+WPALMBEA
+CH
+
+10:26A
+
+1838-89603398861
+(561)317-2428
+317-2428
+(561)818-3331
+(881)358-8452
+(561)B27-4493
+(561)379-6422
+(561)309-1375
+(561)253-4977
+(561|324-6449
+Qnty
+Used
+Rate Description
+2 MIN
+CLUDED MINUTE
+CLUDED MINUTE
+INCLUDED MINUTES
+NOLUDED MINUTES
+NOLUDED MINUTES
+INCLUDED MINUTES
+NCLUDED MINUTE:
+VOLUDED MINUTES
+INCLUDED MINUTES
+VOLUDED
+VCLUDED MINUTE!
+INCLUDED MINUTES
+2 MIN
+INGLEED MINUTES
+INCLUDED MINUTES
+ICLUDED MINUTE
+CLUDED MINUTE
+ED MONTES
+1000 NIGHT WREND
+0D0 D
+INCLUDED MINT
+INCLUDED MINUT
+INCLUDED
+MINUTES
+ED
+WPALM
+WPAL
+WPALM
+
+Item Date Time
+Called
+Calls To
+41 03/12 10:04P
+10:04P (561309-137
+742 03/12 10:07P
+43 03/12 10:35f
+44 03/12 11:00F
+745 03/13 08:37A
+47 83/13 10:37A (361)792-637
+3/13 10:37A
+748
+03/13 10:38A
+10:46A
+(561)753-0169
+10:48A
+10:52A
+11:05A
+(561)315-7476
+11:52A (561)324-1517
+12:04P
+12:27P (561)310-6943
+COMIN
+WALMBEACH FL
+WPALMBEACH FL
+NCOMING
+LAKE WORTH FL
+COMIN
+PALMBEACH F
+COMIN
+COMIN
+WPALMBEACH FL
+Onty
+Used
+2 MIN
+2 MIN
+IMIN
+1MIN
+8 MIN
+2 MIN
+SMIN
+1MIN
+02:56P
+04:11P (561)753-0169
+08:15P
+(561)379-7824
+CH
+FL
+FL
+Rate Description
+1000 NIGHT/KEND MIN
+DD NIGHT/WKEND M
+DO NIGHT WKEND M
+1000 NIGHT/KEND MIN
+1000 NIGHT/KEND MIN
+1000 NIGHT/KEND MIN
+1000 NIGHT/KEND
+ODD NIGHT/WKEN!
+ODO NIGHTWKENI
+1000 NIGHT/KEND MIN
+100 NIGHTWEN MN
+HT/KEND
+DD NIGHT/WKER
+DO NIGHT KEND M
+1000
+NIGHTANKEND
+888888888888888888888888888888888888 88
+3/13
+88:13P
+(561)379-6422
+05:300
+06:09P
+06. 24P
+:24P
+06:28P
+(561)315-7476
+06:36P (561)315-7476
+06:57P
+07:1
+87
+07:45P (561)315-7476
+11:57P
+01:38A (561)317-2428
+08:44A
+09:28A
+11 284
+1:26P
+(561)379-6422
+01:3
+(561)662-6615
+02:09P
+02:12P
+2:13P
+(561)310-6943
+(561j379-6422
+:3OP
+eestes
+561j310-6943
+(561)313-5654
+02:37P (561)792-5628
+12:38R
+(561)818-3331
+(561)317-2428
+:53P
+02:54P
+(561)818-3331
+03:27P
+5:05P
+08
+33R
+1•3
+888
+(561)315-7476
+(561|379-6422
+(561)662-7668
+(561)379-7824
+00 ₫₫ 0000 _ ₫ [ 4 ₫÷÷.
+aa..................•.**
+1029399.000025189
+
+
+
+Item Date Time Called
+904 0314 08300
+| 09-20P
+806 03/14 09:56P (561)317-2428
+807
+03/14 11:13P
+808 03/14
+11:38P
+Calls To
+COMIN
+COMIN
+WPALMBEACH FL
+NCOMING
+COMING
+10 MIN
+TOTAL VOICE USAGE FOR (561)379-7824
+Onty
+Used
+Rate Description
+1000 NIGHT/KEND MIN
+000 NIGHT/WKEND M
+000 NIGHT/KEND MI
+DATA USAGE FOR (561)379-7824
+Item Date
+Onty Used
+1 02/21
+4 KB
+TOTAL DATA USAGE FOR (561)379-7824
+Charge Description
+INCL. IN PLAN DATA
+TEXT/MULTIMEDIA MSGS FOR (561)379-7824
+Item Date
+1 02/19
+Time
+02:57P
+Charge Description
+CL
+2.50
+0.00
+CI
+100
+100
+68192000 0808201
+*52090505D00*
+
+TEXT/MULTIMEDIA MSGS FOR (561)379-7824 - Continued
+Item Date
+48 03/02
+49 03/02
+50 03002
+52 03/03
+5308/03
+Time
+10:33P
+10:35P
+10:45P
+10:51P
+10:30P
+Sent To/Revd From
+Charge Description
+(561)601-6282
+00 INCL. MSGS SEN
+(561|601-6282
+O0 INCL. MSGS SENT
+100 INEL. MSGS SENT
+(561|317-2428
+100 INCL. MSGS SENT
+100 INC: MS SENT
+57 03/04
+59 03/04
+60 03/04
+62 03.08
+63 03/06
+65 03/05
+87:314
+881315-3078
+11:48A
+(561 315-7476
+3:50
+1:01
+81)601-6282
+09:24P
+(561)315-7476
+03:34P
+04:05P
+12.094
+100 IN MESS SENT
+100 INCL. MSGS SENT
+100 IN: MISS SENT
+100 INCL. MSGS SENT
+100 IN MS SENT
+(561)601-6282
+561 601-6282
+100 INCL. MSGS SENT
+100 INEL MISSS SENT
+
+9308
+10:24P
+12:09A
+03/12
+01:24P
+(561)309-
+78 03/14
+08:49P
+(56
+
+
+TOTAL TEXT/MULTIMEDIA MSG USAGE FOR (561)379-7824
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/34bc243dc86e287da6684f78eca8b9ca7fed5e197ddd2accf9fa96bf95afea69.receipt.json b/vision-fixhub/ds9-unparsed-06/34bc243dc86e287da6684f78eca8b9ca7fed5e197ddd2accf9fa96bf95afea69.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3a102ba0b53feae13549af61db6e904e5ed15730
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/34bc243dc86e287da6684f78eca8b9ca7fed5e197ddd2accf9fa96bf95afea69.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -4533,
+  "dataset": "marble-joined",
+  "doc_id": "34bc243dc86e287da6684f78eca8b9ca7fed5e197ddd2accf9fa96bf95afea69",
+  "engine": "marble-apple-vision",
+  "event_count": 64,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "73c9375887adb48214dfcf283bbe04174bd9309bf7e242910b6f15b29763039a",
+  "output_sha256": "bb4c0ecbf42e31a8e9d90085284c45ef76b7930bb999ce482e8cc2368955d7b5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/34eed7630af78a0f1a1c9551841af820da42992a38d84d98a87fdbd279fbd695.md b/vision-fixhub/ds9-unparsed-06/34eed7630af78a0f1a1c9551841af820da42992a38d84d98a87fdbd279fbd695.md
new file mode 100644
index 0000000000000000000000000000000000000000..7195f830e8cc0228bf34001e0243cf85361d2ee2
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/34eed7630af78a0f1a1c9551841af820da42992a38d84d98a87fdbd279fbd695.md
@@ -0,0 +1,6994 @@
+Billing Cycle Date:
+Account Number:
+1 of 28
+03/15/05 - 04/14/05
+How To Contact Us:
+• 1-800-331-0500 or 611 from your wireless phone
+• For Deaf / Hard of Hearing Customers (TTY/TDD)
+1-866-241-6567
+Wireless Number
+Previous Balance
+Payments Posted
+Adjustments to Previous Balance
+CREDIT BALANCE
+Monthly Service Charges
+Usage Charges
+Credits/Adjustments/Other Charges
+Government Fees and Taxes
+TOTAL CURRENT CHARGES
+Due May 07, 2005
+Late fees assessed after May 07
+Total Amount Due $61.84
+179.96
+-179.96
+-13.15
+-13.15
+52.30
+9.30
+2.60
+10.79
+74.99
+Customer Service Payment Processing Fee
+Please be advised that payments processed by a Customer Service Professional will be subject
+to a payment processing fee. Our Representatives will be happy to provide assistance on hor
+o make payments using one of our self-service options. These options can also be reference
+on the 'How To Pay' section on page 2 of your invoice.
+#05725942030013*
+return the portion below with paymer
+to Cingular Wireless onl
+Account Number:
+Total Amount Due
+$61.84
+Amount Paid:
+$
+* Please do not send correspondence with paymens.
+Total Amount
+Due by May 07, 2005
+Please Make Check Payable To:
+
+
+
+Billing Cycle Date:
+Account Number:
+2 of 28
+03/15/05 - 04/14/05
+acco do normal
+General Information
+• Terms: The past due amount is due immediately. Late payment charges of 1.5% may be
+applied to any unpaid balance as of your next billing date. When you send us a
+check as payment, you authorize us to clear your check electronically. Electronic
+payments may clear the same day we receive payment. Returned checks or other
+negotiable instruments may result in the maximum processing charge allowed by law.
+Notations made on checks or accompanying materials will not secure your rights.
+• The 'Recurring Monthly Charges' can be billed in advance or arrears based on
+selected services. Usage and toll charges are billed in arrears. Certain usage
+and toll charges may appear more than one month in arrears. Prorated monthly
+charges may apply for new services or changes to existing services during a
+billing period. These will appear in the Monthly Service Charges sections of the
+bill.
+• Please do not enclose correspondence with your payment for we cannot guarantee
+receipt. Address all correspondence to the following: Cingular Wireless,
+PO BOX 772349 - (MIA). OCALA. FL 34477-2349.
+• Calls to our Customer Service Centers may be monitored to ensure high quality
+service to our customers.
+• Questions on accessibility by persons with disabilities: 1-866-241-6568
+• Cingular Wireless Tax ID # 74-2955068 / Cingular Wireless DUNS # 003548489
+********************************************************************
+Auto Pay Authorization Agreement - For use only with Auto Pay phone enrollment
+If I enroll, I authorize Cingular Wireless to pay my bill monthly by debiting my
+bank account. I can cancel authorization by notifying Cingular at
+www.cingular.com, by calling 1-800-331-0500, or by dialing 611 from my wireless
+phone. If my bank rejects a payment, I may be charged a return fee.
+How To Pay
+Check and savings account payments, debit cards,
+credit cards are accepted.
+Payments made with a representative may be subject to
+Note: There is no fec for choosing any of the following payment channels:
+Pay using your wireless phone for free
+- Dial *PAY (*729), then hit send.
+- Make a one time payment following the instructions provided.
+Pay using any landline phone - Dial 1-800-331-0500
+- Enter your wireless number and billing ZIP Code and follow the prompts
+- Go to www.cingular.com
+Recurring Credit Card Paymen
+- Also sign up to receive your wireless bill online at no additional charge.
+Pay by Mail
+- Mail your remittance stub and a check or money order in the envelope provided.
+- It may take up to 7 - 10 days for the payment to post.
+DST X280-9900 (10/03)
+
+
+-
+Prior Activity
+Previous Balance
+Detail of Payments Posted
+Payment by SERVICE CENTER PAYMENT posted on Mar 18, 2005
+Payment by SERVICE CENTER PAYMENT posted on Mar 26, 2005
+Adjustments to Previous Balance
+COUNTY UTILITY USER TAX ADJUSTMENT
+CREDIT FOR LOCAL AIRTIME
+FED UNIVERSAL SVC CHARGE ADJUSTMENT
+FEDERAL EXCISE TAX
+STATE TELE SALES TAX ADJUSTMENT
+TOTAL CREDIT BALANCE
+Wireless Line Summary For:
+User Name:
+Monthly Service Charges
+Rate Plan
+IRISS INTRNT XPES PAY PER USE
+- BASIC VOICEMAIL-N/C
+- CALL FORWARDING N/C
+- CALL WAITING N/C
+- CALLER ID N/C
+- DATA VOLUME DETAILED BILLING
+- DETAILED BILLING NIC
+- MULTIMEDIA PAY PER USE
+- THREE PARTY CALL N/C
+Other Services
+15000 NIGHT/WKND MINS CTH
+1600 ANYTIME MINS
+/REGION GSM
+JUNLIMITED EXPANDED M2M-N/C
+JUNLIMITED M2M EXPND MINS
+CINGULAR NATIONWIDE TOLL FREE
+FL ROAM WITH HOME
+NATIONWIDE $ 79/MIN ROAMING
+ROAMER ADMIN FEE EXCLUSION
+WIRELESS PHONE INS. & SVC FEE
+Wireless Data
+TXT MSG PROMO 200
+TXT MSG PROMO 200
+TOTAL MONTHLY SERVICE CHARGES
+Usage Charges
+(See Usage Charge Details)
+Period
+04/15-05/14
+Prorated
+Charge
+04/15-05/14
+04/15-05/14
+04/15-05/14
+04/15-05/14
+04/15-05/14
+04/15-05/14
+04/15-05/14
+04/15-05/14
+04/15-05/14
+004/1-05/14
+03/26-04/14
+04/15-05/14
+3.33
+3 of 28
+03/15/05 - 04/14/05
+179.96
+-96.22
+-83.74
+-0.67
+-10.80
+-0.33
+-0.33
+-1.02
+$-13.15
+Monthly
+Charge
+39.99
+Total
+Charge
+39.99
+3.99
+1.99
+3.99
+3.33
+1.99
+$52.30
+
+
+* cingular
+Wireless Line Summary For (Continued):
+User Name:
+TOTAL USAGE CHARGES
+Credits, Adjustments & Other Charges
+FED UNIVERSAL SVC CHARGE
+911 MONTHLY
+REGULATORY COST RECOVERY FEE
+TOTAL CREDITS, ADJUSTMENTS & OTHER CHARGES
+Government Fees and Taxes
+FEDERAL EXCISE TAX
+STATE COMMUNICATIONS TAX
+LOCAL COMMUNICATIONS TAX
+TOTAL GOVERNMENT FEES and TAXES
+TOTAL AMOUNT DUE
+Usage Charge Details
+User Name: MICHAEL DAVIS
+Summary of
+Usage Charges
+/RGNP 600 UMM 5KNW
+Peak
+/UNLIMITED EXPANDED M2M-N
+15000 NIGHT/WKND MINS CTH
+Directory Assistance
+Long Distance
+Domestic
+Roaming
+Subtotal
+Summary of
+Wireless Data
+Text Messaging
+- CINGULAR MOBILE TO MOBILE Ourgoing
+- CINGULAR MOBILE TO MOBILE Incoming
+- Chicago EMAIL. Incoming
+- OTHER MOBILE TO MOBILE Outgoing
+- OTHER MOBILE TO MOBILE Incoming
+- CINGULAR MOBILE TO MOBILE Ourgoing
+-CINGULAR MOBILE TO MOBILE Incoming
+DST X280-9900 (10/03)
+Minutes
+Included
+In Plan
+600
+5000
+Msg/kB
+Included
+In Plan
+illing Cycle Dat
+ccount Numbe
+401305-041405
+$9.30
+Minutes
+Used
+502
+279
+880
+2
+Msg/KB
+Used
+1
+15
+14
+Billed
+Minutes
+Billed
+Rate
+3 Call (s)
+See Call Details
+See Call Details
+Billed
+Msg/KB
+Billed
+Rate
+1
+1.54
+0.50
+0.56
+$2.60
+1.51
+5.51
+3.77
+$10.79
+$74.99
+561-324-7996
+Total
+Charge
+1.50
+0-00
+$4.50
+Total
+Charge
+0.70
+0.70
+
+
+Billing Cycle Date:
+Account Number:
+5 of 28
+03/15/05 - 04/14/05
+Usage Charge Details (Continued)
+User Name:
+Summary of
+Wireless Data
+Text Messaging
+- OTHER MOBILE TO MOBILE Ougoing
+- OTHER MOBILE TO MOBILE Incoming
+Msg/KB
+Included
+In Plan
+Msg/KB
+Billed
+Used
+Msg/KB
+Billed
+Rate
+Total
+Charge
+Subtotal
+$4.80
+TOTAL USAGE CHARGES
+$9.30
+Call Detail
+User Name: MICHAEL DAVIS
+561-324-7996
+Call Location(CL): AU=Aucilla, BR=Bristol, BU=Bushnell, CH=Chiefland, CL.=Clewiston, DB=Daytona, FL.=Flagler,
+FK=Florida Keys, FM=Fort Myers, FP=Fort Pierce, FW=Fort Walton, GV=Gainesville, JX=Jacksonville, LC=Lake City.
+L.B=Leesburg, MI=Miami, MA=Marianna, MB=Melbourne, MX=Mexico Beach, OC=Ocala, OR=Orlando, PL.=Palatka, PC=Panama City,
+PS=Pensacola, PJ=Port St Joe, SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa, VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Ot Peak, N=Nights
+eature: B=Direct Asst Call Complete: C=Call Waiting:
+elcoming Call Fax Call: M-Mobile To Mobile Discount: P-Priority Access Service: R-Roam Witb Hom Mobile Call
+S=Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Item
+CL
+Called
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Day
+Date
+won
+03/07
+03/07
+03/07
+Tue
+03/08
+03/08
+03/08
+03/08
+Hed
+03/09
+03/09
+Thu
+03/10
+03/10
+Eri
+03/11
+03/11
+Sat
+Sun
+03/12
+03/13
+03/13
+03/13
+03/13
+03/13
+03/13
+Tue
+03/15
+03/15
+03/15
+03/15
+03/15
+Time
+09:56PM
+10:09PM
+11:23PM
+11:35AM
+11: 36AM
+12:40PM
+07:38PM
+04:29PM
+04:30PM
+12:40PM
+12:41PM
+09:51PM
+10:08PM
+01:02PM
+02:19PM
+02:20PM
+02:22PM
+02:27PM
+06:43PM
+04:37AM
+12:39PM
+01 :54PM
+02:21 PM
+03:30PM
+MI
+MI
+MI
+MI
+Call To
+MIAMI,
+FL
+MIAMI,
+FL
+MIAMI,
+FL
+MIAMI,
+FL
+INCOMI
+CL
+MIAMI,
+FL
+INCOMI CL
+INCOMI CL
+INCOMI
+CL
+MIAMI,
+FL
+MIAMI,
+FL
+INCOMI
+INCOMI
+INCOMI
+CL
+CL
+INCOMI
+MIAMI,
+MIAMI,
+MIAMI,
+FL
+FL
+FL
+INCOMI
+MIAMI
+FL
+W PALM
+FL
+MIAMI,
+FL
+INCOMI
+CL
+N PALM FL
+INCOMI CL
+Rate Rate Fea. Airtime
+Min Code
+Pd ture Charge
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IRM
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IRM
+IR
+IR
+R
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IRW
+IRN
+IRW
+IRW
+RSD1
+RSD1
+RSD1
+RBD1
+RK
+IRW
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+н =
+LD
+DA
+Total
+Charge
+-
+
+
+Billing Cycle Date:
+Account Number
+601305 - 04/1005
+Call DetaiL(Continued)
+User Name:
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+eature: B=Direct Asst Call Complete: C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Call
+-Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Hom
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+26
+03/15
+27
+03/15
+28
+03/15
+29
+03/15
+30
+03/15
+31
+03/15
+32
+03/15
+33
+03/15
+34
+03/15
+35
+03/15
+36
+03/15
+37
+03/15
+38
+03/15
+39
+03/15
+40
+03/15
+41
+Had
+03/16
+42
+03/16
+43
+03/16
+44
+03/16
+45
+03/16
+46
+03/16
+47
+03/16
+48
+03/16
+49
+03/16
+50
+03/16
+51
+03/16
+52
+03/16
+53
+03/16
+54
+03/16
+55
+03/16
+56
+03/16
+57
+03/16
+58
+03/16
+59
+03/16
+60
+03/16
+61
+03/16
+62
+03/16
+63
+03/16
+64
+03/16
+65
+03/16
+66
+03/16
+67
+03/16
+68
+03/16
+DST X280-9900 (10/03)
+Time
+05: 13PM
+05:24PM
+05:25PM
+05: 25PM
+05:27PM
+05:35PM
+05:59PM
+06:19PM
+08:14PM
+08:15PM
+09: 54PM
+10: 43PM
+10:54PM
+11:18PM
+11:23PM
+10:22AM
+12:59PM
+03: 04PM
+03:11PM
+03:13PM
+03:21PM
+03:44PM
+03: 46PM
+04:00PM
+04: 04PM
+04: 57PM
+04:59PM
+05:00PM
+05:20PM
+05: 41PM
+05: 56PM
+06: 00PM
+06: 01PM
+06: 02PM
+06: 02PM
+06:10PM
+06:16PM
+06:22PM
+06:25PM
+07:14PM
+07:25PM
+07:33PM
+07:37PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+W PALM FL
+INCOMI CL
+INCOMI CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FI
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PALM EL
+MIAMI, FL
+MIAMI, FL
+DELRAY FL
+W PALM FL
+W PALM FL
+MIAMI,
+FL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+" PALM FL
+W PALM FI
+W PALM FI
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+INCOMI CL
+W PALM FI
+W PALM FI
+W PALM FL
+DELRAY
+FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+INCOMI CL
+W PALM FL
+INCOMI CL
+INCOMI CL
+19
+Min Cade Rade Fire Altime
+ture
+RSD1
+P
+I
+RSD1
+M
+RSD1
+ICM
+RSD1
+I
+RSD1
+I
+RSD1
+IM
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+IN
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+P
+M
+RSD1
+RSD1
+RSD1
+P
+P
+RSD1
+M
+RSD1
+RSD1
+P
+RSD1
+M
+RSD1
+RSD1
+ICM
+RSD1
+RSD1
+RSD1
+RSD1
+P
+RSD1
+I
+IR
+Total
+Charge
+. 00
+1.00
+
+
+Billing Cycle Date:
+Account Number:
+7 of 28
+03/15/05 - 04/14/05
+Call Detail (Continued)
+User Name:
+PS=Pensacola, PI=Port St Joe, SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa, VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+I=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+69
+03/16
+70
+03/16
+71
+03/16
+72
+Thu
+03/17
+73
+03/17
+74
+03/17
+75
+03/17
+76
+03/17
+77
+03/17
+78
+03/17
+79
+03/17
+80
+03/17
+81
+03/17
+82
+03/17
+83
+03/17
+84
+03/17
+85
+03/17
+86
+03/17
+87
+03/17
+88
+03/17
+89
+03/17
+90
+03/17
+91
+03/17
+92
+03/17
+93
+03/17
+94
+03/17
+95
+03/17
+96
+03/17
+97
+03/17
+98
+03/17
+99
+Fri
+03/18
+100
+03/18
+101
+03/18
+102
+03/18
+103
+03/18
+104
+03/18
+105
+03/18
+106
+03/18
+107
+03/18
+108
+03/18
+109
+03/18
+110
+03/18
+111
+03/18
+Time
+08:16PM
+08:19PM
+08:38PM
+06: 21AM
+06: 34AM
+08: 31AM
+08:37AM
+09:47AM
+12: 49PM
+12:53PM
+12: 57PM
+01:06PM
+01:37PM
+02: 30PM
+02: 33PM
+03:48PM
+03:51PM
+03: 52PM
+08:11PM
+08:12PM
+08:29PM
+09:36PM
+09: 38PM
+09:40PM
+09:42PM
+09: 45PM
+09:49PM
+10:07PM
+10: 38PM
+10:38PM
+06: 41AM
+07: 09AM
+07:11AM
+07:12AM
+07:14AM
+07:28AM
+07: 29AM
+11:58AM
+12: 43PM
+12: 44PM
+12:44PM
+12:53PM
+01: 00PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+W PALM FL
+MIAMI, EL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+MIAMI,
+FL
+INCOMI
+CL
+W PALM
+FL
+INCOMI
+CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+MIAMI, FL
+MIAMI, FL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+MIAMI,
+FL
+MIAMI,
+FL
+PERRIN FL
+" PALM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM EL
+PERRIN FL
+INCOMI CL
+" PALM FL
+W PALM FI
+W PALM FI
+INCOMI
+CL
+W PALM FL
+INCOMI
+CL
+INCOMI CL
+W PALM FL
+W PALM EL
+INCOMI CL
+MIAMI,
+FL
+W PALM FL
+Min Rade Rate Fure Alaine
+ture
+RSD1
+P
+RSD1
+RSD1
+R
+RSD1
+RSD1
+RSD1
+IR
+RSD1
+RSD1
+RSD1
+RSD1
+IC
+RSD1
+RSD1
+RSD1
+RSD1
+M
+RSD1
+RSD1
+IR
+RSD1
+RSD1
+RSD1
+M
+RSD1
+RSD1
+IR
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+IRN
+RSD1
+RSD1
+P
+P
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+IRM
+RSD1
+RSD1
+RSD1
+M
+IN
+RSD1
+RSD1
+bA
+Total
+Charge
+.00
+1.00
+.00
+.00
+.00
+1.00
+
+
+Billing Cycle Date:
+Account Number:
+8 of 28
+03/15/05 - 04/14/05
+Call Detail (Continued)
+User Name:
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+eature: B=Direct Asst Call Complete: C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Call
+=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Hom
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+112
+03/18
+01: 21PM
+113
+03/18
+03: 00PM
+114
+03/18
+03:05PM
+115
+03/18
+03:09PM
+116
+03/18
+03: 12PM
+117
+03/18
+03:17PM
+118
+03/18
+03:33PM
+119
+03/18
+04: 01PM
+120
+03/18
+04: 06PM
+121
+03/18
+05:48PM
+122
+03/18
+08: 40PM
+123
+03/18
+08: 47PM
+124
+03/18
+10:38PM
+125
+03/18
+10:40PM
+126
+03/18
+10: 41PM
+127
+03/18
+10: 42PM
+128
+03/18
+10:43PM
+129
+03/18
+10:46PM
+130
+03/18
+10:47PM
+131
+03/18
+10:47PM
+132
+03/18
+10:48PM
+133
+03/18
+10:59PM
+134
+03/18
+11:00PM
+135
+03/18
+11:01PM
+136
+03/18
+11: 02PM
+137
+03/18
+11: 02PM
+138
+03/18
+11:03PM
+139
+03/18
+11:05PM
+140
+03/18
+11:08PM
+141
+03/18
+11:09PM
+142
+03/18
+11:09PM
+143
+03/18
+11:10PM
+144
+03/18
+11: 27PM
+145
+03/18
+11: 30PM
+146
+03/18
+11:32PM
+Sat
+03/19
+12: 26AM
+03/19
+12: 27AM
+149
+150
+151
+152
+153
+154
+03/19
+11:58AM
+03/19
+03: 07PM
+03/19
+03:11PM
+03/19
+03:12PM
+03/19
+03:14PM
+03/19
+03: 50PM
+DST X280-9900 (10/03)
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FI
+W PALM FL
+PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+MIAMI,
+FL
+" PALM FL
+W PALM FL
+" PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+MIAMI, FL
+MIAMI, FL
+MIAMI, FL
+INCOMI
+CL
+W PALM
+FL
+PALM FL
+W PALM FL
+" PALM FL
+W PALM FL
+W PALM FL
+W
+PALM
+FL
+W PALM
+FL
+W PALM EL
+INCOMI CL
+" PALM FL
+N PALM FI
+INCOMI
+CL
+INCOMI
+CL
+W PALM
+FL
+INCOMI
+CL
+W PALM
+FL
+W PALM
+EL
+I PALN
+I FL
+W PALM FL
+INCOMI CL
+Min Rade Rate Fire Alaine
+RSD1
+IN
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+IR
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+RSD1
+RSD1
+RSD1
+RSD1
+RK
+RW
+RSD1
+RSD1
+IRW
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+W
+RSD1
+RSD1
+RSD1
+RSD1
+N
+N
+RSD1
+RSD1
+N
+RSD1
+ICH
+RSD1
+RSD1
+RSD1
+IN
+R8D1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+W
+IN
+bA
+Total
+Charg
+. 00
+.00
+1.00
+2.00
+
+
+Billing Cycle Date:
+Account Number:
+9 of 28
+03/15/05 - 04/14/05
+Call Detail (Continued)
+User Name: N
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+I=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+155
+03/19
+04: 21PM
+156
+03/19
+04:21PM
+157
+03/19
+08:35PM
+158
+03/19
+08:45PM
+159
+03/19
+08: 50PM
+160
+03/19
+08:54PM
+161
+03/19
+08:55PM
+162
+03/19
+08:58PM
+163
+03/19
+09:01PM
+164
+03/19
+09:04PM
+165
+03/19
+09: 05PM
+166
+03/19
+09:09PM
+167
+03/19
+09:11PM
+168
+03/19
+09:57PM
+169
+03/19
+10:11PM
+170
+03/19
+10:25PM
+171
+03/19
+10:52PM
+172
+03/19
+10:56PM
+173
+03/19
+10:57PM
+174
+03/19
+10:58PM
+175
+03/19
+10:58PM
+176
+03/19
+11:21PM
+177
+03/19
+11:21PM
+178
+03/19
+11:50PM
+179
+Sun
+03/20
+01:01AM
+180
+03/20
+01: 13AM
+181
+03/20
+02:00PM
+182
+03/20
+02:01PM
+183
+03/20
+02: 02PM
+184
+03/20
+02:06PM
+185
+03/20
+02:15PM
+186
+03/20
+02: 20PM
+187
+03/20
+02:21PM
+188
+03/20
+02:22PM
+189
+03/20
+02:23PM
+190
+03/20
+02:24PM
+191
+03/20
+02: 28PM
+192
+03/20
+04:59PM
+193
+03/20
+05: 00PM
+194
+03/20
+05: 01PM
+195
+03/20
+05:07PM
+196
+03/20
+05:08PM
+197
+03/20
+05: 08PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+W PALM FL
+W PALM FL
+MIAMI, FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+I PALM FL
+INCOMI CL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+" PALM FL
+W PALM FL
+W PALM FL
+W PALM
+FL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+INCOMI CL
+INCOMI CL
+W PALM FI
+MIAMI
+FL
+W PALM EL
+W PALM EL
+MIAMI, EL
+" PALM FL
+W PALM FL
+W PALM FI
+W PALM
+FL
+W PALM
+FL
+INCOMI
+CL
+W PALM
+FL
+" PALM FI
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+Min Rade Rate Fire Alaine
+ture
+RSD1
+N
+RSD1
+CH
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IW
+IN
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+R8D1
+RSD1
+RSD1
+RSD1
+IK
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+zzzz
+Total
+Charg
+. 00
+1.00
+.00
+1.00
+
+
+Billing Cycle Date:
+Account Number:
+10 of 28
+03/15/05 - 04/14/05
+Call Detail (Continued)
+User Name:
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete: C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Call
+=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service, R=Roam with Hone
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+198
+03/20
+05:18PM
+199
+03/20
+05:19PM
+200
+03/20
+05:51PM
+201
+03/20
+05: :53PM
+202
+03/20
+05: :59PM
+203
+03/20
+06:32PM
+204
+03/20
+06: 52PM
+205
+03/20
+07:13PM
+206
+03/20
+08:11PM
+207
+03/20
+08:56PM
+208
+03/20
+08: 56PM
+209
+03/20
+09:11PM
+210
+03/20
+09:25PM
+211
+03/20
+10:15PM
+03/20
+10:16PM
+213
+214
+215
+216
+217
+218
+219
+220
+221
+222
+223
+224
+225
+226
+227
+228
+229
+230
+231
+232
+233
+234
+235
+236
+237
+238
+239
+240
+03/20
+10:25PM
+Mon
+03/21
+11:19AM
+03/21
+11: 20AM
+03/21
+11: 23AM
+03/21
+11:24AM
+03/21
+11:28AM
+03/21
+11: 45AM
+03/21
+11: 51AM
+03/21
+03:22PM
+03/21
+03:26PM
+03/21
+03: 27PM
+03/21
+03:46PM
+03/21
+03:50PM
+03/21
+03: 58PM
+03/21
+04: 02PM
+03/21
+08:55PM
+03/21
+08: 59PM
+03/21
+09: 03PM
+03/21
+09: 08PM
+03/21
+09:09PM
+03/21
+09:24PM
+03/21
+09:27PM
+03/21
+09:40PM
+03/21
+10:25PM
+03/21
+10:26PM
+03/21
+10: 38PM
+Tue
+03/22
+12:11PM
+03/22
+12:11PM
+DST X280-9900 (10/03)
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+W PALM FL
+" PALM FL
+" PALM FL
+PALM FL
+PALM FL
+PALM FL
+PALM FL
+PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM
+FL
+" PALM FL
+" PALM FL
+" PALM FL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI CL
+W PALM FL
+MIAMI,
+FL
+MIAMI,
+FL
+MIAMI,
+FL
+W PALM FL
+W PALM FI
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+Min Cade Rade Fire Altime
+ture
+2
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+IN
+M
+IN
+M
+bA
+Total
+Charg
+. 00
+1.00
+.00
+.00
+1.00
+
+
+11 of 28
+Call Detail (Continued)
+User Name:
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+I=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Min Code Rade Forge
+Item Day Date Time
+241
+03/22
+12: 31PM
+242
+03/22
+12:36PM
+243
+03/22
+12:40PM
+244
+03/22
+12: 43PM
+245
+03/22
+12: 44PM
+246
+03/22
+02:09PM
+247
+03/22
+02:27PM
+248
+03/22
+02:34PM
+249
+03/22
+02: 43PM
+250
+03/22
+03:47PM
+251
+03/22
+04:00PM
+252
+03/22
+04: :31PM
+253
+03/22
+07:07PM
+254
+03/22
+07:17PM
+255
+03/22
+08:04PM
+256
+03/22
+08: 05PM
+257
+03/22
+08:10PM
+258
+03/22
+08:12PM
+259
+03/22
+08:12PM
+260
+03/22
+09:23PM
+261
+03/22
+09:50PM
+262
+03/22
+10: 02PM
+263
+03/22
+10: 02PM
+264
+03/22
+10:04PM
+265
+03/22
+10:09PM
+266
+03/22
+10:12PM
+267
+03/22
+10:53PM
+268
+03/22
+11:23PM
+269
+03/22
+11:43PM
+270
+Wed
+03/23
+10: 42AM
+271
+03/23
+12:24PM
+272
+03/23
+12: 43PM
+273
+03/23
+01:40PM
+274
+03/23
+01:44PM
+275
+03/23
+01:49PM
+276
+03/23
+04:47PM
+277
+03/23
+04: 50PM
+278
+03/23
+05:00PM
+279
+03/23
+05: 03PM
+280
+03/23
+05: :08PM
+281
+03/23
+05: 36PM
+282
+03/23
+06:01PM
+283
+03/23
+06:47PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+11
+INCOMI
+CL
+INCOMI
+CL
+# PALM FL
+" PALM FI
+INCOMI CL
+" PALM FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+" PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+PALM FL
+PALM FL
+PALM FL
+N PALM FL
+W PALM FL
+BOCA R FL
+INCOMI CL
+W PALM FL
+W PALM EL
+W PALM EL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FI
+INCOMI
+CL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM EL
+W PALM FL
+INCOMI CL
+W PALM FL
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+R8D1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+P
+P
+P
+I
+IN
+M
+I
+IN
+M
+M
+I
+bA Charge
+. 00
+. 00
+.00
+1.00
+
+
+12 of 28
+02/15/05 - 04/14/05
+Call Detail (Continued)
+User Name:
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+284
+03/23
+06: 48PM
+285
+03/23
+06: 49PM
+286
+03/23
+07:12PM
+287
+03/23
+07:13PM
+298
+03/23
+07: 30PM
+289
+03/23
+07:54PM
+290
+03/23
+08:21PM
+291
+03/23
+08:25PM
+292
+03/23
+09:11PM
+293
+03/23
+09:12PM
+294
+03/23
+09:16PM
+295
+03/23
+10: 00PM
+296
+03/23
+10:08PM
+297
+03/23
+10:32PM
+298
+03/23
+10:40PM
+299
+03/23
+10:45PM
+300
+03/23
+10:47PM
+301
+03/23
+10:48PM
+302
+03/23
+11:49PM
+303
+Thu
+03/24
+01:15AM
+304
+03/24
+12:49PM
+305
+03/24
+12: 50PM
+306
+03/24
+01:07PM
+307
+03/24
+01:08PM
+308
+03/24
+02:21PM
+309
+03/24
+02: 22PM
+310
+03/24
+02: :58PM
+311
+03/24
+03:20PM
+312
+03/24
+03: 30PM
+313
+03/24
+03: 44PM
+314
+03/24
+03:48PM
+315
+03/24
+04: 47PM
+316
+03/24
+04: 48PM
+317
+03/24
+05:07PM
+318
+03/24
+05: 41PM
+319
+03/24
+05: 50PM
+320
+03/24
+05: 51PM
+321
+03/24
+07:13PM
+322
+03/24
+07:36PM
+323
+03/24
+08: 06PM
+324
+03/24
+08:23PM
+325
+03/24
+09:03PM
+326
+03/24
+09: 32PM
+DST X280-9900 (10/03)
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FI
+W PALM FL
+W PALM FL
+MIAMI, FL
+INCOMI CL
+W PALM FL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+PALM FL
+PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+W PALM EL
+INCOMI CL
+BOCA R FL
+INCOMI CL
+W PALM FI
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM EL
+W PALM FL
+W PALM FL
+W PALM FL
+Min Code Rade Fure Alrig
+ture
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+I
+RSD1
+RSD1
+IM
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+IRW
+IRW
+IW
+RSD1
+RSD1
+W
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IC
+IN
+RSD1
+P
+RSD1
+RSD1
+RSD1
+RSD1
+P
+RSD1
+RSD1
+RSD1
+RSD1
+P
+RSD1
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+= z
+Total
+Charg
+. 00
+. 00
+.00
+
+
+Billing Cycle Date:
+Account Number:
+13 of 28
+03/15/05 - 04/14/05
+Call Detail (Continued)
+User Name:
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Call
+=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Hono
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+327
+03/24
+328
+03/24
+329
+03/24
+330
+03/24
+331
+Fri
+03/25
+332
+03/25
+333
+03/25
+334
+03/25
+335
+03/25
+336
+03/25
+337
+03/25
+338
+03/25
+339
+03/25
+340
+03/25
+341
+03/25
+342
+03/25
+343
+03/25
+344
+03/25
+345
+03/25
+346
+03/25
+347
+03/25
+348
+03/25
+349
+03/25
+350
+03/25
+351
+03/25
+352
+03/25
+353
+03/25
+354
+03/25
+355
+03/25
+356
+03/25
+357
+03/25
+358
+03/25
+359
+Sat
+03/26
+360
+03/26
+361
+03/26
+362
+03/26
+03/26
+364
+365
+366
+367
+368
+369
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+Time
+09:33PM
+09: 38PM
+09:46PM
+10:05PM
+12:17AM
+12:24AM
+03:53PM
+03:56PM
+03:58PM
+04:09PM
+04:10PM
+07:57PM
+08:58PM
+08:59PM
+09: 01PM
+09: 01PM
+09:04PM
+09: 51PM
+09: 52PM
+09: 52PM
+10:07PM
+10:10PM
+10:16PM
+10:46PM
+11: 04PM
+11: 08PM
+11:11PM
+11:11PM
+11:12PM
+11:20PM
+11:22PM
+11:37PM
+12: 21AM
+12:22AM
+12: 23AM
+01: 43PM
+01:52PM
+02:18PM
+02:18PM
+02: :36PM
+02: 38PM
+02: 40PM
+03:28PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MD
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+W PALM FL
+" PALM FL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+PALM FL
+PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM EL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+INCOMI
+CL
+W PALM
+FL
+PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+W PALM FI
+W PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+# PALM
+FL
+W PALM
+FL
+PALM
+FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM EL
+W PALM FL
+W PALM FL
+INCOMI CL
+Min Rade Rate Fure Alaine
+RSD1
+RSD1
+W
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+M
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+IRM
+IW
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IW
+IN
+= 3
+RSD1
+RSD1
+RSD1
+N
+N
+N
+IW
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+RSD1
+RSD1
+RSD1
+N
+IN
+Total
+Charg
+.00
+1.00
+.00
+1.00
+
+
+Billing Cycle Date:
+Account Number:
+14 of 28
+03115105-04/14/05
+Call Detail (Continued)
+User Name:
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+370
+03/26
+04: 40PM
+371
+03/26
+08:36PM
+372
+03/26
+08:36PM
+373
+03/26
+08:37PM
+374
+03/26
+08: :41PM
+375
+03/26
+08:43PM
+376
+03/26
+08:47PM
+377
+03/26
+08:47PM
+378
+03/26
+08:48PM
+379
+03/26
+09:44PM
+380
+03/26
+09: 45PM
+381
+03/26
+10: 39PM
+382
+03/26
+10:41PM
+383
+03/26
+10:51PM
+384
+03/26
+11: 22PM
+385
+03/26
+11:23PM
+386
+Sun
+03/27
+12: 06AM
+387
+03/27
+12:15AM
+388
+03/27
+10:20AM
+389
+03/27
+11:30AM
+390
+03/27
+11:52AM
+391
+03/27
+11: 56AM
+392
+03/27
+12: 02PM
+393
+03/27
+12:17PM
+394
+03/27
+12: 46PM
+395
+03/27
+12: 49PM
+396
+03/27
+01:02PM
+397
+03/27
+01:17PM
+398
+03/27
+01:21PM
+393
+400
+401
+402
+03/27
+01:47PM
+03/27
+01:49PM
+03/27
+01:54PM
+03/27
+02:04PM
+03/27
+02: :33PM
+404
+405
+406
+407
+408
+409
+410
+411
+412
+03/27
+02:43PM
+03/27
+02: 59PM
+03/27
+03:00PM
+03/27
+03:01PM
+03/27
+03: 03PM
+03/27
+03: 07PM
+03/27
+04:34PM
+03/27
+04:39PM
+03/27
+04: 55PM
+DST X280-9900 (10/03)
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM EL
+W PALM FL
+INCOMI CL
+INCOMI CL
+MIAMI,
+FL
+MIAMI,
+FL
+W PALM FL
+PALM FL
+PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+MIAMI,
+FL
+W PALM FL
+W PALM FI
+W PALM FL
+INCOMI CL
+W PALM FL
+INCOMI
+CL
+OXNARD
+CA
+INCOMI
+CL
+W PALM
+FL
+W PALM
+FL
+" PALM FL
+W PALM FL
+OXNARD
+CA
+INCOMI CL
+OXHARD
+CA
+OXNARD
+CA
+OXNARD
+CA
+INCOMI
+CL
+OXNARD
+CA
+OXNARD
+CA
+W PALM
+FL
+INCOMI
+CL
+W PALM
+FL
+DELRAY
+FL
+W PALM
+FL
+W PALM FL
+W PALM
+EL
+W PALM
+FL
+INCOMI
+CL
+INCOMI CL
+Min Cade Rade Fire Altime
+ture
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+W
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IRW
+RSD1
+RSD1
+RSD1
+N
+RSD1
+RSD1
+RSD1
+N
+RSD1
+RSD1
+IW
+RSD1
+RSD1
+RSD1
+RED1
+N
+RSD1
+RSD1
+RSD1
+RSD1
+zzzz
+IRM
+bA
+Total
+Charg
+.00
+.00
+1.00
+
+
+Billing Cycle Date:
+Account Number:
+15 of 28
+02/15/05. 04614/05
+Call Detail (Continued)
+User Name:
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa, VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+I=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date Time
+413
+414
+415
+416
+417
+418
+419
+420
+421
+422
+423
+424
+425
+426
+427
+428
+429
+430
+431
+432
+433
+434
+435
+436
+437
+438
+439
+440
+441
+442
+443
+444
+445
+446
+447
+448
+449
+450
+451
+452
+453
+454
+455
+03/27
+05: 22PM
+03/27
+05:28PM
+03/27
+05:33PM
+03/27
+05:50PM
+03/27
+05: 54PM
+Mon
+03/28
+12:43PM
+03/28
+03:00PM
+03/28
+03:43PM
+03/28
+03:47PM
+03/28
+10:40PM
+Tue
+03/29
+02:37PM
+03/29
+02: 45PM
+03/29
+02:59PM
+03/29
+03:09PM
+03/29
+03:10PM
+03/29
+03:13PM
+03/29
+03:21PM
+03/29
+03:24PM
+03/29
+03: 32PM
+03/29
+03: 36PM
+03/29
+03:43PM
+03/29
+03/29
+03: 53PM
+03/29
+03/29
+03/29
+03/29
+03:59PM
+04:04PM
+04:14PM
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+03/29
+06:31PM
+06:37PM
+03/29
+03/29
+03/29
+07:53PM
+03/29
+03/29
+03/29
+08: 07PM
+08:46PM
+Wed
+03/30
+03/30
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+PALM
+FL
+DELRAY
+FL
+DELRAY FL
+W PALM FI
+INCOMI CL
+INCOMI CL
+INCOMI CL
+DELRAY FL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+" PALM FL
+INCOMI
+CL
+DELRAY
+FL
+" PALM
+FL
+INCOMI
+CL
+MIAMI,
+FL
+MIAMI,
+FL
+W PALM FL
+INCOMI CL
+MIAMI,
+FL
+INCOMI
+CL
+W PALM EL
+W PALM FL
+W PALM FL
+W PALM FI
+W PALM FI
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+" PALM FI
+W PALM FL
+INCOMI CL
+W PALM FL
+INCOMI CL
+MIAMI,
+FL
+Min Code Rade Fure Alrige
+ture
+RSD1
+N
+RSD1
+RSD1
+IRW
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+I
+IRM
+RSD1
+RSD1
+I
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IR
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+RSD1
+RSD1
+P
+RSD1
+RSD1
+I
+IM
+M
+RSD1
+RSD1
+P
+M
+RSD1
+RSD1
+RSD1
+RSD1
+P
+bA Charge
+.00
+
+
+Billing Cycle Date:
+Account Number:
+16 of 28
+03/15/05 - 04/14/05
+Call Detail (Continued)
+User Name: N
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+CL
+Called
+Item Day Date
+Time
+456
+03/30
+03: 05PM
+457
+03/30
+03:08PM
+458
+03/30
+03:09PM
+459
+03/30
+04:12PM
+460
+03/30
+05:14PM
+461
+03/30
+08:37PM
+462
+03/30
+08:38PM
+463
+03/30
+09:33PM
+464
+03/30
+10:09PM
+465
+Thu
+03/31
+02:03PM
+466
+03/31
+02:53PM
+467
+03/31
+02: 55PM
+468
+03/31
+02: 56PM
+469
+03/31
+02:58PM
+470
+03/31
+03: 02PM
+471
+03/31
+03: 06PM
+472
+03/31
+03:26PM
+473
+03/31
+04: 02PM
+474
+03/31
+04:13PM
+475
+03/31
+07: 03PM
+476
+03/31
+07:03PM
+477
+03/31
+09: 05PM
+478
+03/31
+09:05PM
+479
+03/31
+09:12PM
+480
+03/31
+09:22PM
+481
+03/31
+09: 39PM
+482
+03/31
+09:40PM
+483
+03/31
+09:43PM
+484
+03/31
+09: 53PM
+485
+03/31
+09:54PM
+486
+03/31
+09:58PM
+487
+03/31
+09:59PM
+488
+03/31
+09:59PM
+489
+03/31
+10:03PM
+490
+Fri
+04/01
+09:35PM
+491
+04/01
+09:35PM
+492
+04/01
+09:36PM
+493
+04/01
+10:24PM
+494
+04/01
+10:29PM
+495
+04/01
+10: 30PM
+496
+04/01
+10:32PM
+497
+04/01
+10:35PM
+498
+04/01
+11:19PM
+DST X280-9900 (10/03)
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MD
+MI
+MIL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+MIAMI, FL
+MIAMI,
+FL
+MIAMI,
+FL
+INCOMI CL
+W PALM FL
+W PALM FL
+DIR ASSI
+INCOMI
+CL
+INCOMI
+CL
+MIAMI,
+FL
+MIAMI,
+FI
+MIAMI,
+FL
+INCOMI
+CL
+INCOMI
+CL
+MIAMI,
+FL
+W PALM FL
+W PALM FL
+W PALM FL
+MIAMI, FL
+W PALM FL
+PALM FL
+PALM FL
+BOYTON FL
+" PALM FL
+W PALM FL
+BOYTON FL
+W PALM FI
+INCOMI
+CL
+INCOMI
+CL
+BOTTON
+LEL
+BOYTON FI
+" PALM FL
+W PALM FL
+# PALM FL
+W PALM
+FL
+W PALM
+FL
+PALM FL
+W PALM FL
+I PALM FI
+BOCA R FI
+INCOMI CL
+INCOMI CL
+W PALM FL
+Min Code Rade Fure Alrige
+ture
+RSD1
+P
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+R
+IM
+M
+M
+RSD1
+RSD1
+RSD1
+IN
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IRM
+IRM
+RSD1
+RSD1
+RSD1
+RSD1
+M
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+IW
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+IN
+RSD1
+N
+1.50
+Total
+Charge
+1.50
+. 00
+.00
+
+
+17 of 28
+03/15/05 = 04/14/05
+Call Detail (Continued)
+User Name:
+PS=Pensacola. PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa, VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+eature: B=Direct Asst Call Complete; C=Call Waiting: D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Call
+=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Hom
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+499
+04/01
+11:30PM
+500
+04/01
+11:40PM
+501
+04/01
+11:42PM
+502
+Sat
+04/02
+12:12AM
+503
+04/02
+12:17AM
+504
+04/02
+10: 56AM
+505
+04/02
+10: 58AM
+506
+04/02
+10:59AM
+507
+04/02
+11: 02AM
+508
+04/02
+11:07AM
+509
+04/02
+11: 08AM
+510
+04/02
+11: 09AM
+511
+04/02
+11:10AM
+512
+04/02
+11:31AM
+513
+04/02
+02: 19PM
+514
+04/02
+02:20PM
+515
+04/02
+02:23PM
+516
+04/02
+02:27PM
+517
+04/02
+02:28PM
+518
+04/02
+02: :32PM
+519
+04/02
+02:33PM
+520
+04/02
+02: 39PM
+521
+04/02
+02: 50PM
+522
+04/02
+02: 52PM
+523
+04/02
+03: 08PM
+524
+04/02
+03: 39PM
+525
+04/02
+03: 44PM
+526
+04/02
+07:51PM
+527
+04/02
+07:52PM
+528
+04/02
+09: 01PM
+529
+04/02
+09:04PM
+530
+04/02
+09: 04PM
+531
+04/02
+09: 06PM
+532
+04/02
+09:10PM
+533
+04/02
+09:10PM
+534
+04/02
+09:11PM
+535
+04/02
+09:15PM
+536
+04/02
+09:24PM
+537
+04/02
+09:30PM
+538
+04/02
+09: 52PM
+539
+04/02
+09:56PM
+540
+04/02
+09:59PM
+541
+04/02
+10: 02PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+HI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+W PALM FL
+" PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FI
+NEW YO NY
+NEW YO NY
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+MIAMI, FL
+MIAMI, FL
+MIAMI, FL
+W PALM FL
+W PALM
+FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM
+FL
+DELRAY
+FL
+W PALM EL
+W PALM FL
+" PALM FL
+W PALM FL
+W PALM FL
+W PALM
+FL
+INCOMI
+CL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM EL
+W PALM FL
+W PALM FL
+INCOMI CL
+Min Rade Rate Fure Alaine
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+W
+IN
+17
+RSD1
+RSD1
+RSD1
+N
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+N
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RK
+RW
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+IN
+RSD1
+RSD1
+N
+RSD1
+RSD1
+N
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IRN
+RSD1
+N
+RSD1
+W
+RSD1
+RSD1
+RSD1
+= z z
+IRW
+Tota
+Charg
+. 00
+.00
+.00
+
+
+18 of 28
+02/15105 = 04/14/05
+Call Detail (Continued)
+User Name: MICHAEL DAVIS
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+CL
+Called
+Item Day Date
+Time
+542
+04/02
+10:05PM
+543
+04/02
+10:07PM
+544
+04/02
+10:12PM
+545
+04/02
+10: 33PM
+546
+Sun
+04/03
+12: 41AM
+547
+04/03
+07:04AM
+548
+04/03
+09: 04AM
+549
+04/03
+10:11AM
+550
+04/03
+10:15AM
+551
+04/03
+10:16AM
+552
+04/03
+10:19AM
+553
+04/03
+10: 57AM
+554
+04/03
+10:58AM
+555
+04/03
+11: 01AM
+556
+04/03
+11: 02AM
+557
+04/03
+11: 06AM
+558
+04/03
+11:14AM
+559
+04/03
+11: 47AM
+560
+04/03
+11: 54AM
+561
+04/03
+11: 58AM
+562
+04/03
+12:35PM
+563
+04/03
+01:13PM
+564
+04/03
+01:19PM
+565
+04/03
+01:40PM
+566
+04/03
+01: 42PM
+567
+04/03
+01: 42PM
+568
+04/03
+01: 59PM
+569
+04/03
+02:22PM
+570
+04/03
+02:38PM
+371
+04/03
+02:39PM
+572
+04/03
+03:08PM
+573
+04/03
+03:21PM
+574
+04/03
+03:22PM
+575
+04/03
+05: 29PM
+576
+04/03
+05: 32PM
+577
+04/03
+05: 37PM
+578
+04/03
+05: 53PM
+579
+04/03
+08:30PM
+580
+Mon
+04/04
+02: 56PM
+581
+04/04
+03: 03PM
+582
+04/04
+04: 31PM
+583
+Tue
+04/05
+02:54PM
+584
+04/05
+03: 03PM
+DST X280-9900 (10/03)
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+MIAMI, FL
+INCOMI CL
+MIAMI, FL
+INCOMI CL
+W PALM FL
+PALM
+FL
+PALM
+FL
+DELRAY
+FL
+W PALM FL
+W PALM FL
+OXNARD
+CA
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PALM FL
+PALM
+FL
+PALM FL
+MIAMI,
+FL
+INCOMI
+CL
+OXNARD
+CA
+INCOMI
+CL
+BOYTON EL
+INCOMI
+CL
+INCOMI
+CL
+W PALM EL
+INCOMI CL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PALM EL
+W PALM FI
+W PALM FL
+INCOMI CL
+Min Code Rade Fure Alrige
+ture
+RSD1
+IRR
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+IW
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IW
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+W
+IN
+IN
+RSD1
+N
+RSD1
+RSD1
+RSD1
+RSD1
+N
+N
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+N
+N
+B
+IN
+RSD1
+M
+M
+RSD1
+RSD1
+M
+RSD1
+P
+Total
+Charg
+.00
+
+
+Billing Cycle Date:
+Account Number:
+19 of 28
+03/15/05 - 04/14/05
+Call Detail (Continued)
+User Name:
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+I=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Item Day Date
+Time
+CL
+Called
+Call To
+Min Code Rade are Alrig
+ture
+585
+04/05
+03:10PM
+MI
+INCOMI CL
+26
+586
+04/05
+03:39PM
+MI
+W PALM FL
+RSD1
+587
+04/05
+04:27PM
+MI
+W PALM FL
+RSD1
+588
+04/05
+04:28PM
+MI
+W PALM FL
+RSD1
+589
+04/05
+06:15PM
+MI
+INCOMI CL
+RSD1
+590
+04/05
+06:46PM
+MI
+INCOMI CL
+RSD1
+I
+591
+04/05
+06: 51PM
+MI
+" PALM FL
+RSD1
+592
+04/05
+06:54PM
+MI
+" PALM
+FL
+RSD1
+593
+04/05
+06: 57PM
+MI
+INCOMI
+CL
+RSD1
+594
+04/05
+07:27PM
+MI
+INCOMI
+CL
+RSD1
+595
+04/05
+07: 32PM
+596
+04/05
+07: 33PM
+MI
+INCOMI
+CL
+RSD1
+MI
+W PALM FL
+R8D1
+597
+04/05
+07:39PM
+MI
+W PALM FL
+12
+RSD1
+598
+Wed
+04/06
+09:04AM
+MI
+W PALM FL
+RSD1
+M
+599
+04/06
+09:24AM
+MI
+W PALM FL
+RSD1
+600
+04/06
+10: 02AM
+MI
+W PALM FL
+RSD1
+M
+601
+04/06
+10: 02AM
+MI
+W PALM FL
+RSD1
+602
+04/06
+10: 03AM
+MI
+W PALM FL
+RSD1
+603
+04/06
+10: 07AM
+W PALM FL
+RSD1
+M
+604
+04/06
+10: 07AM
+MI
+W PALM FL
+RSD1
+605
+04/06
+10:10AM
+MI
+INCOMI
+CL
+RSD1
+606
+04/06
+10: 44AM
+MI
+INCOMI
+CL
+RSD1
+IN
+607
+04/06
+11: 00AM
+MI
+" PALM FI
+RSD1
+608
+04/06
+03:00PM
+MIAMI,
+FL
+RSD1
+609
+04/06
+03:50PM
+MI
+INCOMI
+CL
+RSD1
+610
+04/06
+04: 58PM
+MI
+W PALM FI
+RSD1
+611
+04/06
+05:07PM
+MI
+=
+W PALM FL
+RSD1
+M
+M
+612
+04/06
+05:08PM
+MI
+W PALM
+FL
+RSD1
+P
+613
+04/06
+05:09PM
+MI
+W PALM EL
+RSD1
+614
+04/06
+05:21PM
+MI
+W PALM EL
+RSD1
+615
+04/06
+05:23PM
+MI
+W PALM FL
+RSD1
+M
+616
+04/06
+05: 25PM
+MI
+INCOMI CL
+RSD1
+P
+617
+04/06
+05: 28PM
+MI
+INCOMI
+RSD1
+618
+04/06
+05: 30PM
+MI
+INCOMI
+CL
+RSD1
+619
+04/06
+05:44PM
+MI
+INCOMI
+CL
+RSD1
+620
+04/06
+05: 48PM
+MI
+" PALM
+FL
+RSD1
+IN
+I
+IM
+M
+621
+04/06
+06:03PM
+MI
+W PALM
+FL
+RSD1
+622
+04/06
+06:12PM
+MI
+OXNARD
+CA
+RSD1
+623
+04/06
+06:16PM
+MI
+INCOMI
+CI
+RSD1
+624
+04/06
+06: 24PM
+MI
+INCOMI
+CL
+RSD1
+B
+625
+04/06
+06: 33PM
+MI
+W PALM FL
+RSD1
+626
+04/06
+06:53PM
+MIAMI,
+FL
+RSD1
+627
+04/06
+08:19PM
+MI
+INCOMI CL
+RSD1
+bA
+Total
+Charg
+.00
+.00
+
+
+20 of 28
+Billing Cycle Date:
+03/15/05 - 04/14/05
+Account Number:
+Call Detail (Continued)
+User Name:
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+eature: B=Direct Asst Call Complete: C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Call
+=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Hom
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+628
+04/06
+629
+04/06
+630
+Thu
+04/07
+631
+04/07
+632
+04/07
+633
+04/07
+634
+04/07
+635
+04/07
+636
+04/07
+637
+04/07
+638
+04/07
+639
+04/07
+640
+04/07
+641
+04/07
+642
+04/07
+643
+04/07
+644
+04/07
+645
+04/07
+646
+04/07
+647
+04/07
+648
+04/07
+649
+04/07
+650
+04/07
+651
+04/07
+652
+04/07
+653
+04/07
+654
+Fri
+04/08
+655
+04/08
+656
+04/08
+657
+04/08
+658
+04/08
+659
+04/08
+660
+04/08
+661
+04/08
+662
+04/08
+663
+04/08
+664
+04/08
+665
+04/08
+666
+04/08
+667
+04/08
+668
+04/08
+669
+Sat
+04/09
+670
+04/09
+DST X280-9900 (10/03)
+Time
+09: 52PM
+10:35PM
+06: 48AM
+06: 48AM
+06:48AM
+07:16AM
+12:45PM
+03:08PM
+03:13PM
+03:20PM
+03:23PM
+03:29PM
+03:29PM
+03:58PM
+04: 06PM
+04: 20PM
+04:43PM
+08: :41PM
+09:11PM
+09:13PM
+09:14PM
+09:19PM
+09:26PM
+10:13PM
+10:15PM
+10: 57PM
+07:14AM
+03:14PM
+04: 31PM
+04:44PM
+04:45PM
+04: 46PM
+08:53PM
+08:55PM
+09:58PM
+10:47PM
+10:51PM
+10:54PM
+11:03PM
+11: 32PM
+11:50PM
+12:48AM
+01:23AM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+INCOMI CL
+" PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+MIAMI,
+FL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM EL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+• PALM FL
+BOYTON FL
+W PALM FL
+BOYTON FL
+MIAMI,
+FL
+MIAMI,
+FL
+INCOMI
+CL
+" PALM FL
+" PALM FL
+INCOMI CL
+DELRAY EL
+FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+INCOMI CL
+MIAMI,
+FL
+MIAMI,
+FL
+W PALM FL
+PALM FL
+W PALM FL
+INCOMI
+CL
+INCOMI CL
+W PALM FL
+MIAMI, FL
+W PALM FL
+W PALM FL
+Min Cade Rade Fure Glarge
+1
+RSD1
+IN
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+W
+W
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+13
+RSD1
+RSD1
+IN
+M
+RSD1
+P
+P
+RSD1
+RSD1
+RSD1
+13
+RSD1
+P
+P
+M
+RSD1
+RSD1
+RM
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+ICH
+IN
+W
+RSD1
+RSD1
+RSD1
+"zzz
+= z
+Total
+Charge
+.00
+1.00
+.00
+1.00
+
+
+21 of 28
+03/15/05 - 04/14/05
+Call Detail (Continued)
+User Name:
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+eature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Call
+=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Hono
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Min Code Rade Forge
+Item Day Date
+Time
+671
+04/09
+01: 41AM
+672
+04/09
+09: 55AM
+673
+04/09
+10:14AM
+674
+04/09
+10:24AM
+675
+04/09
+10:54AM
+676
+04/09
+11:25AM
+677
+04/09
+12:00PM
+678
+04/09
+01:28PM
+679
+04/09
+01:33PM
+680
+04/09
+02:31PM
+681
+04/09
+03: 04PM
+682
+04/09
+04: 06PM
+683
+04/09
+04:10PM
+684
+04/09
+04:55PM
+685
+04/09
+06 : 06PM
+686
+04/09
+06:16PM
+687
+04/09
+06:21PM
+688
+04/09
+06:23PM
+689
+04/09
+06: 25PM
+690
+04/09
+06: 26PM
+691
+04/09
+06:28PM
+692
+04/09
+06:28PM
+693
+04/09
+06: 31PM
+694
+04/09
+06:31PM
+695
+04/09
+07:03PM
+696
+04/09
+07: 33PM
+697
+04/09
+07:44PM
+698
+04/09
+07:49PM
+699
+04/09
+08: 09PM
+700
+04/09
+08:26PM
+701
+04/09
+08: 41PM
+702
+04/09
+08:58PM
+703
+04/09
+10:15PM
+704
+04/09
+10:53PM
+705
+04/09
+11:21PM
+706
+04/09
+11:29PM
+707
+04/09
+11:35PM
+708
+Sun
+04/10
+12: 56AM
+709
+04/10
+01: 03AM
+710
+04/10
+01: 34AM
+711
+04/10
+02:20AM
+712
+04/10
+02: 32AM
+713
+04/10
+02: 48AM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM
+FL
+INCOMI
+CL
+# PALM FL
+W PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI CL
+DELRAY FI
+INCOMI
+CL
+INCOMI
+CL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+DELRAY
+FL
+W PALM
+FL
+PALM FL
+W PALM FL
+" PALM FL
+INCOMI CL
+W PALM FL
+INCOMI CL
+W PALM
+FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FI
+W PALM FI
+INCOMI
+CL
+W PALM FL
+W PALM
+INCOMI
+CL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+N PALM FL
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+W
+IN
+IW
+IN
+IN
+IN
+IN
+IN
+IW
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+N
+N
+N
+2===
+Total
+Charg
+.00
+.00
+.00
+2.00
+
+
+Billing Cycle Date:
+Account Number:
+22 of 28
+03/15/05 - 04/14/05
+Call DetaiL(Continuedi
+User Name:
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date Time
+714
+715
+716
+717
+718
+719
+720
+721
+722
+723
+724
+725
+726
+727
+728
+729
+730
+731
+732
+733
+734
+735
+736
+737
+738
+739
+740
+741
+742
+743
+744
+745
+746
+747
+748
+749
+750
+751
+752
+753
+754
+755
+756
+04/10
+03: :03AM
+04/10
+03: 04AM
+04/10
+03: 06AM
+04/10
+03: 08AM
+04/10
+03: 16AM
+04/10
+03:25AM
+04/10
+03: 27AM
+04/10
+05: 22AM
+04/10
+10: 04AM
+04/10
+10: 08AM
+04/10
+11: 05AM
+04/10
+11: 06AM
+04/10
+11:08AM
+04/10
+11:17AM
+04/10
+12: 23PM
+04/10
+12: 25PM
+04/10
+01:06PM
+04/10
+01:12PM
+04/10
+01:25PM
+04/10
+01:32PM
+04/10
+01: 43PM
+04/10
+01:47PM
+04/10
+01:47PM
+04/10
+01:51PM
+04/10
+01:52PM
+04/10
+01:54PM
+04/10
+02:07PM
+04/10
+02:16PM
+04/10
+02: 48PM
+04/10
+02: 49PM
+04/10
+03:34PM
+04/10
+03:38PM
+04/10
+05: 01PM
+04/10
+05: :05PM
+04/10
+06:48PM
+04/10
+07: 01PM
+04/10
+07:04PM
+04/10
+08: 01PM
+04/10
+09:20PM
+04/10
+09: 49PM
+04/10
+09:59PM
+Mon
+04/11
+05: 45AM
+04/11
+06: 34AM
+DST X280-9900 (10/03)
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM
+FL
+INCOMI
+CL
+W PALM FI
+N PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PALM EL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+W PALM
+EL
+PALM
+FL
+PALM FL
+DELRAY FL
+W PALM FL
+W PALM FI
+W PALM FL
+BOYTON
+EL
+INCOMI
+CL
+INCOMI CL
+PERRIN EL
+W PALM FL
+W PALM FL
+W PALM FI
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+INCOMI
+CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+INCOMI CL
+Min Code Rade Fure Alrige
+ture
+RSD1
+IN
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+IW
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IW
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+RSD1
+RSD1
+W
+RSD1
+RSD1
+RSD1
+RSD1
+N
+N
+N
+N
+ICH
+IW
+RSD1
+RSD1
+RSD1
+N
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+N
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+2zzz
+IN
+W
+IN
+Total
+Charge
+.00
+.00
+
+
+Billing Cycle Date:
+Account Number:
+23 of 28
+03/15/05 - 04/14/05
+Call Detail (Continued)
+User Name:
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+I=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Home
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+757
+04/11
+758
+04/11
+759
+04/11
+760
+04/11
+761
+04/11
+762
+04/11
+763
+04/11
+764
+04/11
+765
+04/11
+766
+04/11
+767
+04/11
+768
+04/11
+769
+04/11
+770
+04/11
+771
+04/11
+772
+04/11
+773
+04/11
+774
+04/11
+775
+04/11
+776
+04/11
+777
+04/11
+778
+04/11
+779
+04/11
+780
+04/11
+781
+04/11
+782
+Tue
+783
+784
+785
+786
+787
+788
+789
+790
+791
+792
+793
+794
+795
+796
+797
+798
+Wed
+799
+Time
+07:20AM
+09:57AM
+12:38PM
+12: 53PM
+12: 53PM
+03:03PM
+03:06PM
+04:14PM
+04:20PM
+04:20PM
+04:21PM
+04:24PM
+04:30PM
+04:48PM
+08:38PM
+08:39PM
+08:40PM
+09:38PM
+09:39PM
+09: 42PM
+09:43PM
+09:47PM
+09:53PM
+09:55PM
+10: 21PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+W PALM FL
+MIAMI, FL
+W PALM FL
+MIAMI
+FL
+W PALM FL
+BOYTON FL
+" PALM FL
+W PALM FL
+NEW YO NY
+W PALM FL
+INCOMI CL
+W PALM EL
+INCOMI CL
+MIAMI,
+FL
+MIAMI, EL
+MIAMI, FL
+MIAMI, FL
+MIAMI, FL
+MIAMI,
+FL
+MIAMI,
+FL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+" PALM FL
+MIAMI,
+BOYTON FI
+INCOMI
+CL
+MIAMI.
+FL
+MIAMI,
+FL
+MIAMI, FL
+W PALM FL
+DELRAY FL
+W PALM FL
+W PALM
+FL
+MIAMI
+FL
+W PALM FI
+W PALM FL
+W PALM FL
+INCOMI CL
+BOYTON FL
+MIAMI,
+FL
+BOYTON FL
+Min Rade Rate Fure Alaine
+ture
+RSD1
+P
+RSD1
+M
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+IM
+RSD1
+RSD1
+R
+RSD1
+RSD1
+RSD1
+RK
+RW
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IW
+RSD1
+RSD1
+RSD1
+P
+P
+RSD1
+IR
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+RSD1
+RSD1
+M
+RSD1
+RSD1
+R
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+I
+= =
+RSD1
+P
+bA
+Total
+Charg
+. 00
+. 00
+.00
+
+
+Billing Cycle Date:
+Account Number:
+24 of 28
+03/15/05 - 04/14/05
+Call Detail (Continued)
+User Name:
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+eature: B=Direct Asst Call Complete: C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Call
+=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Hom
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+CL
+Called
+Item Day Date
+Time
+800
+04/13
+03:05PM
+801
+04/13
+03:07PM
+802
+04/13
+03:08PM
+803
+04/13
+03:09PM
+804
+04/13
+03:12PM
+805
+04/13
+03:14PM
+806
+04/13
+03:21PM
+807
+04/13
+03:22PM
+808
+04/13
+03: 36PM
+809
+04/13
+03:42PM
+810
+04/13
+03: 43PM
+811
+04/13
+03: 47PM
+812
+04/13
+03:47PM
+813
+04/13
+03:47PM
+814
+04/13
+03: 47PM
+815
+04/13
+03:51PM
+816
+04/13
+03:53PM
+817
+04/13
+03: 53PM
+818
+04/13
+03: 54PM
+819
+04/13
+03: 54PM
+820
+04/13
+03:55PM
+821
+04/13
+03:55PM
+822
+04/13
+03: 58PM
+823
+04/13
+03:59PM
+824
+04/13
+03:59PM
+825
+04/13
+03: 59PM
+826
+04/13
+04:29PM
+827
+04/13
+04:59PM
+828
+04/13
+05:13PM
+829
+04/13
+05: 45PM
+830
+04/13
+05: 54PM
+831
+04/13
+06: 05PM
+832
+04/13
+06:13PM
+04/13
+06: 47PM
+834
+835
+836
+837
+838
+839
+840
+841
+842
+04/13
+07:53PM
+04/13
+07: 56PM
+04/13
+08:22PM
+04/13
+08:36PM
+04/13
+08:48PM
+04/13
+08: 51PM
+04/13
+08: 58PM
+04/13
+09:01PM
+Thu
+04/14
+03: 01PM
+DST X280-9900 (10/03)
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+MIAMI,
+FL
+MIAMI,
+FL
+MIAMI,
+FL
+MIAMI,
+FL
+MIAMI,
+FL
+INCOMI
+CL
+MIAMI
+FL
+MIAMI,
+FL
+I PALM
+FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PALM FL
+I PALM FL
+I PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM
+FL
+W PALM
+FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+INCOMI CL
+N PALM EL
+INCOMI
+CL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+DA Call
+I PALM FL
+INCOMI CL
+BOYTON FL
+W PALM FL
+DA Call
+BOYTON FL
+W PALM FL
+W PALM FL
+Min Code Rade Fure Alrige
+ture
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IR
+RSD1
+RSD1
+R
+RSD1
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+RSD1
+RSD1
+RSD1
+M
+IRM
+I
+M
+I
+RSD1
+RSD1
+RSD1
+P
+RSD1
+IM
+M
+RSD1
+P
+RSD1
+RSD1
+I
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+bA
+1.50
+1.50
+Total
+Charg
+. 00
+1.00
+1.50
+1.30
+
+
+25 of 28
+03/15/05 - 04/14/05
+Call Detail (Continued)
+User Name:
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting: D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+I=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+843
+04/14
+844
+04/14
+845
+04/14
+846
+04/14
+947
+04/14
+848
+04/14
+849
+04/14
+850
+04/14
+Totals
+Time
+03: 02PM
+04: 41PM
+08:41PM
+08: 42PM
+09:24PM
+09:25PM
+09:34PM
+09:37PM
+1661
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM EL
+W PALM FL
+• PALM FL
+QUEENS NY
+W PALM FL
+DELRAY EL
+INCOMI CL
+INCOMI CL
+Min Code Rade Forge
+RSD1
+RSD1
+RSD1
+M
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+IN
+4.50
+4.50
+Roaming Call Detail
+User Name:
+Rate Code: RSDIETRONT 600 OMN SEN W
+Rate Period (Pd.): P=Peak, O=Of Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls:
+I=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Home:
+S=Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Item Day
+Date
+Time
+Called
+Call To
+Min
+Rate
+Fea- Airtime
+Code
+ture
+Charge
+LD
+Charge
+Charges Incurred While Roaming in Miami, FL --System ID #85029-A
+Sat
+03/26
+08: 43PM 805-509-0568 MIAMI,
+RSD1
+2 Mon
+04/11
+08:39PM 786-246-6607 MIAMI, FL
+RSD1
+Totals
+Intl
+Tax
+Wireless Data Detail
+User Name:
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Wasting; D=Data Call; F=Call Forwardng: H=Group Mobile to Mobile Calls:
+I=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Home:
+S=Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Item
+Day
+Tue
+Fri
+Tue
+Date
+03/08
+03/08
+03/11
+03/11
+03/15
+03/15
+03/15
+03/15
+Time
+10:59PM
+11:21PM
+04: 03PM
+04: 06PM
+05: 40AM
+05: 45AM
+01:48PM
+01:53PM
+To/From
+Type
+561-324-7996 CINGULAR MOBILE
+561-324-7996 CINGULAR MOBILE
+561-602-1278 CINGULAR MOBILE
+561-324-7996 CINGULAR MOBILE
+561-602-1278 CINGULAR MOBILE
+561-324-7996 CINGULAR MOBILE
+561-324-7996 CINGULAR MOBILE
+561-602-1278 CINGULAR MOBILE
+Rate Rate Fea- In/
+Msg/KB
+Code
+Pd
+ture Out
+1 Mag RSD1
+In
+1 Mag RSD1
+In
+1 Mag RSD1
+Out
+1 Mag RSD1
+1 Mag RSD1
+In
+Out
+1 Mag RSD1
+1 Mag RSD1
+In
+In
+1 Mag RSD1
+Out
+Total
+Charg
+Total
+Charg
+-
+Total
+Charge
+
+
+Billing Cycle Date:
+Account Number:
+26 of 28
+02/15105 - 04/14/05
+Wireless Data Detail (Continued)
+User Namel
+Rate Code: RSDI=/RGNP 600 UMM SKNV
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Night
+cature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Ca
+ncoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service: R=Roam with Hon
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Item Day
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+26
+27
+28
+29
+30
+31
+32
+33
+14
+35
+36
+37
+38
+39
+40
+41
+42
+43
+44
+45
+46
+47
+48
+49
+50
+51
+52
+53
+54
+55
+56
+57
+Wed
+FI1
+Tue
+Fri
+Sat
+Sun
+Mon
+Tue
+Date
+03/15
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/17
+03/17
+03/18
+03/18
+03/18
+03/18
+03/18
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/25
+03/25
+03/25
+03/25
+03/25
+03/25
+03/25
+03/25
+03/25
+03/25
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/28
+03/29
+03/29
+DST X280-9900 (10/03)
+Time
+01:56PM
+10: 30AM
+12:26PM
+12: 36PM
+12:36PM
+12:40PM
+12:41PM
+12:59PM
+05:24PM
+01:44AM
+09: 29AM
+12:25PM
+12:26PM
+12:30PM
+12: 31PM
+12:33PM
+04: 52PM
+04: 54PM
+04:56PM
+05: 00PM
+07:16PM
+07:17PM
+12: 01AM
+10:42PM
+10:56PM
+10:59PM
+11:07PM
+11:26PM
+11: 33PM
+11:39PM
+11:54PM
+11:57PM
+12: 05AM
+12: 08AM
+12: 25AM
+12: 33AM
+12: 35AM
+12: 41AM
+05: 56AM
+06: 57AM
+01:46PM
+02:37PM
+02:49PM
+05:32PM
+05:41PM
+06:29PM
+08:21AM
+12:17AM
+06: 03PM
+To/From
+Type
+CINGULAR MOBILE
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+Chicago
+EMAIL
+CINGULAR MOBILE
+CINGULAR
+MOBILE
+CINGULAR
+MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE
+TO
+CINGULAR
+MOBILE
+CINGULAR
+CINGULAR
+MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR
+MOBILE
+CINGULAR
+MOBILE
+CINGULAR
+CINGULAR
+MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+CINGULAR MOBILE
+CINGULAR MOBILE
+Rate
+• Rate Fea- In/
+Msg/KB
+Code
+Pd
+ture
+• Out
+1 Mag RSD1
+1 Mag
+In
+out
+1 Mag RSD1
+In
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSOL
+RSD1
+RSD1
+RSD1
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+1 Mag
+RSD1
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+Out
+Out
+out
+In
+In
+In
+In
+Out
+In
+In
+Out
+In
+In
+Out
+Out
+Out
+Total
+Charge
+
+
+Billing Cycle Date:
+Account Number:
+27 of 28
+03/15/05 - 04/14/05
+Wireless Data Detail (Continued)
+User Name
+Rate Code: RSD1=/RGNP 600 UMM 5KNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+cature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Cal
+Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service: R=Roam with Hon
+S=Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Item
+58
+59
+60
+61
+62
+63
+64
+65
+66
+67
+68
+69
+70
+71
+72
+73
+74
+75
+76
+77
+78
+79
+80
+81
+82
+83
+84
+85
+86
+87
+88
+Day
+Wed
+Thu
+Fri
+Sun
+Wed
+Thu
+FI1
+Mon
+Tue
+Thu
+Date
+Time
+03/30
+10: 32AM
+03/30
+11: 07AM
+03/30
+12: 23PM
+03/31
+01: 51PM
+03/31
+02:28PM
+04/01
+11:28PM
+04/03
+03: 26AM
+04/03
+03:26AM
+04/06
+04:10AM
+04/06
+08:10PM
+04/06
+08:22PM
+04/06
+10:09PM
+04/07
+10:35AM
+04/07
+11:21AM
+04/07
+11: 25AM
+04/07
+09:40PM
+04/07
+09:47PM
+04/07
+10:44PM
+04/07
+10:56PM
+04/08
+12: 53AM
+04/08
+12:54AM
+04/08
+01:33AM
+04/08
+10: 08AM
+04/08
+01:01PM
+04/08
+01: 03PM
+04/08
+04:16PM
+04/08
+09:18PM
+04/11
+11:45AM
+04/11
+11:35PM
+04/12
+02:04PM
+04/14
+12:17AM
+Subtotal odivisg's
+To/From
+Type
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CIRCULAR MOBILE
+OTHER MOBILE TO
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+OTHER MOBILE TO
+OTHER MOBILE TO
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR
+MOBILE
+CINGULAR
+MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+OTHER MOBILE TO
+OTHER MOBILE TO
+CINGULAR
+MOBILE
+CINGULAR
+MOBILE
+CINGULAR MOBILE
+OTHER MOBILE TO
+CINGULAR MOBILE
+CINGULAR MOBILE
+OTHER MOBILE TO
+CINGULAR MOBILE
+Rate
+Rate Fea. In/
+Msg/KB
+Code
+1 Mag RSD1
+Pd
+ture Out
+1 Mag RSD1
+In
+out
+1 Mag RSD1
+Out
+1 Mag RSD1
+1 Mag RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+1 Mag
+RSD1
+Mag
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+1
+RSD1
+1
+1
+Out
+Out
+Totals
+Total
+Charge
+.00
+.00
+0
+.00
+4.80
+4.80
+Exclusive Star Wars content only from Cingular!
+Cingular Exclusive! Official Star Wars(TM) ringtones, graphics & games are now available
+the new bibe screa tar an an ie in treates May 19. Or make your sei of from the s
+past Star Wars blockbusters. To load your phone with exclusive Star Wars ringtones, graphics
+and games, go to MEdia Net, hit WHAT'S HOT and select STAR WARS.
+
+
+Poling Cycle Date:
+Account Number:
+28 of 28
+03/15/05 - 04/14/05
+Looking for a great job? Check out Cingular!
+ireat pay, excellent benefits, flexible hours, full and part time possible
+/isit Cingular.com, click on Careers, and apply online. EOE AA/M/F/D/_
+DST X280-9900 (10/03)
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/34eed7630af78a0f1a1c9551841af820da42992a38d84d98a87fdbd279fbd695.receipt.json b/vision-fixhub/ds9-unparsed-06/34eed7630af78a0f1a1c9551841af820da42992a38d84d98a87fdbd279fbd695.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9b06ed926baa05425754ffab134f2436aa5e635e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/34eed7630af78a0f1a1c9551841af820da42992a38d84d98a87fdbd279fbd695.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -5521,
+  "dataset": "marble-joined",
+  "doc_id": "34eed7630af78a0f1a1c9551841af820da42992a38d84d98a87fdbd279fbd695",
+  "engine": "marble-apple-vision",
+  "event_count": 30,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "2a4e5e62271142ae4e06ab7843ab4c569c8e0476c32d9d29a0879a1ecf0d5b72",
+  "output_sha256": "6ec3b9145e15dbbc60487ade9bf30337c7c5c13aea705437f7b804cbcd3e8fa3",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/357644e653ab8307b47ff6343b7595e0c5fc6acb3d9e6c198c922ffc95daeb56.md b/vision-fixhub/ds9-unparsed-06/357644e653ab8307b47ff6343b7595e0c5fc6acb3d9e6c198c922ffc95daeb56.md
new file mode 100644
index 0000000000000000000000000000000000000000..1b281e9248c580a20f7029d94c87f79a75369ff8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/357644e653ab8307b47ff6343b7595e0c5fc6acb3d9e6c198c922ffc95daeb56.md
@@ -0,0 +1,45 @@
+Case 9:08-cv-80736-KAM Document 163 Entered on FLSD Docket 04/18/2012 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE No. 08-80736-CIV-MARRA/JOHNSON
+JANE DOE 1 and JANE DOE 2,
+Plaintiffs,
+UNITED STATES OF AMERICA,
+Defendant.
+/
+NOTICE OF SUPPLEMENTAL AUTHORITY OF THE
+UNITED STATES SUPREME COURT
+In two decisions last term, the Supreme Court constitutionalized the right to competent
+counsel in plea negotiations by ruling that the Sixth Amendment right to effective assistance of
+counsel "extends to the plea bargaining process" and that defendants are entitled to "the effective
+assistance of competent counsel" during plea negotiations. Lafler I. Cooper, 132 S. Ct. 1376, 1384
+(2012); Missouri Il. Frye, 132 S. Ct. 1399, 1407-09 (2012). Under Laffer and Frye, counsel have
+an ongoing obligation to provide effective representation in plea bargaining and to engage in
+communications with the client and the prosecutor to discharge that obligation. The limited
+intervenor lawyers and limited intervenor Jeffrey Epstein submit Lafler and Frye in support of their
+motions for protective orders and their objections to disclosure and use of plea negotiations by Jane
+Doe 1 and Jane Doe 2.
+The limited intervenors also submit Lafler and Frye in direct support of their arguments that
+the Court should recognize a common-law privilege in this case under Rule 501 in part because plea
+negotiations are an integral part of our criminal justice system. This was expressly recognized by the
+
+
+Case 9:08-cv-80736-KAM Document 163 Entered on FLSD Docket 04/18/2012 Page 2 of 2
+Supreme Court in Lafler and Frye when it found that "plea bargains are ... central to the
+administration of the criminal justice system" because ours is "a system of pleas, not a system of
+trials":
+Ninety-four percent of state convictions are the result of guilty pleas. The reality is
+that plea bargains have become so central to the administration of the criminal justice
+system that defense counsel have responsibilities in the plea bargain process,
+responsibilities that must be met to render the adequate assistance of counsel that the
+Sixth Amendment requires in the criminal process at critical stages. Because ours "is
+for the most part a system of pleas, not a system of trials," it is insufficient simply to
+point to the guarantee of a fair trial as a backstop that inoculates any errors in the
+pretrial process.
+Lafler, 132 S. Ct. at 1388; Frye, 132 S. Ct. at 1407.
+We certify that on April 18, 2012, the foregoing document was filed electronically with the
+Clerk of the Court using the CM/ECF system.
+Respectfully submitted,
+BLACK, SREBNICK, KORNSPAN
+& STUMPF, P.A.
+2
diff --git a/vision-fixhub/ds9-unparsed-06/357644e653ab8307b47ff6343b7595e0c5fc6acb3d9e6c198c922ffc95daeb56.receipt.json b/vision-fixhub/ds9-unparsed-06/357644e653ab8307b47ff6343b7595e0c5fc6acb3d9e6c198c922ffc95daeb56.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..bf1b3008fc558b68985768b71020eca4fee0fc0b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/357644e653ab8307b47ff6343b7595e0c5fc6acb3d9e6c198c922ffc95daeb56.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "357644e653ab8307b47ff6343b7595e0c5fc6acb3d9e6c198c922ffc95daeb56",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "96e9309f82f87321811afaa5a017c2994d88d7f44a937bb04a77d084ab038b12",
+  "output_sha256": "0c852c7265c241369f58daab0252c767803896b67da61992b85e1ba436a91871",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/358692cad569d6f07241db34244a32739dbee41a57682ec6964f6450362038c0.md b/vision-fixhub/ds9-unparsed-06/358692cad569d6f07241db34244a32739dbee41a57682ec6964f6450362038c0.md
new file mode 100644
index 0000000000000000000000000000000000000000..010628b04f367a1b0d967e9450cbdf55d72ad530
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/358692cad569d6f07241db34244a32739dbee41a57682ec6964f6450362038c0.md
@@ -0,0 +1,65 @@
+From:
+To:
+Subject: Activity in Case 9:08-cv-80119-KAM Doe v. Epstein Motion for Protective Order
+Date: Fri, 26 Feb 2010 20:13:58 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Goldberger, Jack on 2/26/2010 at 3:13 PM EST and filed on 2/26/2010
+Case Name:
+Doe | Epstein
+Case Number:
+9:08-cv-80119-KAM
+Filer:
+Document Number: 475
+Docket Text:
+Third Party MOTION for Protective Order as to the Deposition of
+(Attachments: # (1) Exhibit A)(Goldberger, Jack)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+ahorowitz@sexabuseattorney.com
+Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com
+Isidro Manuel Garcia
+isidrogarcia@bellsouth.net
+Jack Alan Goldberger jagesq@bellsouth.net, nalanis@agwpa.com
+Jack Patrick Hill
+jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com,
+sas@searcylaw.com, vat(@searcylaw.com
+Jeffrey Mare Herman jherman@hermanlaw.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+Michael James Pike MPike@bclclaw.com, bobbie@bclclaw.com, jcadwell@bclclaw.com
+
+
+Paul G. Cassell cassellp@law.utah.edu
+Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com
+Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton@podhurst.com,
+mestrada@podhurst.com
+Robert Deweese Critton, Jr rerit@belclaw.com, bobbie@bclelaw.com
+Stuart S. Mermelstein ssm@sexabuseattorney.com, jarbour@sexabuseattorney.com,
+Irivera(@sexabuseattorney.com
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+Martin G. Weinberg
+20 Park Plaza
+Boston, MA 02116
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=2/26/2010] [FileNumber=7304957-0
+][2738dbcbbd17d94230a8e7152b4eb008fad1320b09592fc4de033927f17e4dd4def
+ff01731218ba359e8df4cc1140a2e84582607d167271flef7cfee96e0a1f4]]
+Document description: Exhibit A
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=2/26/2010] [FileNumber=7304957-1
+][0d8ed83df3abOdcecb57db6361c04fb9c2e1af841d8b24d39b6866c47d7a167c999
+62c702ablec94295aaba0294bb218710e10a508df8bба7b6d17a7c0bc366f]]
diff --git a/vision-fixhub/ds9-unparsed-06/358692cad569d6f07241db34244a32739dbee41a57682ec6964f6450362038c0.receipt.json b/vision-fixhub/ds9-unparsed-06/358692cad569d6f07241db34244a32739dbee41a57682ec6964f6450362038c0.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..5a745a176d148508f8249caf2eb1363401a60810
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/358692cad569d6f07241db34244a32739dbee41a57682ec6964f6450362038c0.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "358692cad569d6f07241db34244a32739dbee41a57682ec6964f6450362038c0",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "b2ad49c278a97901a56d6b847a432dce7a0d18ef3b77bb8c572c44eb24ac2b06",
+  "output_sha256": "dd95800290bad5d94e9e50aba9c99819d5a92030f3731ef897817f0946ddfed8",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/35a1c817469c362bf655bbab4995682115958262c01155aa771ed6b353583bf5.md b/vision-fixhub/ds9-unparsed-06/35a1c817469c362bf655bbab4995682115958262c01155aa771ed6b353583bf5.md
new file mode 100644
index 0000000000000000000000000000000000000000..50e8b71009f3fd228fa9817b38e2e2fb07778203
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/35a1c817469c362bf655bbab4995682115958262c01155aa771ed6b353583bf5.md
@@ -0,0 +1,8 @@
+Subject: Jeffrey Epstein Matter
+Date: Thu, 21 Jul 2011 19:05:43 +0000
+Importance: Normal
+Attachments: 20110722051020.pdf
+Dear Roy:
+Please see the attached letter regarding the Jeffrey Epstein matter. Thank you.
+Suite 400
+3401
diff --git a/vision-fixhub/ds9-unparsed-06/35a1c817469c362bf655bbab4995682115958262c01155aa771ed6b353583bf5.receipt.json b/vision-fixhub/ds9-unparsed-06/35a1c817469c362bf655bbab4995682115958262c01155aa771ed6b353583bf5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9db6079834b83b7e141ea987aeb152e1eca3f42b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/35a1c817469c362bf655bbab4995682115958262c01155aa771ed6b353583bf5.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "35a1c817469c362bf655bbab4995682115958262c01155aa771ed6b353583bf5",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "7bfa57d2a951e0ecc87ec5d528ece3c7f06ce1b1106088a966f489cc2b937469",
+  "output_sha256": "f79afa626d449cb11c0087e83b984ee6f775f97d257376d06556a51b0565d325",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/363d281ce9e08bd54663ad3f6d6ba92b9b51fa7b7814f1cbebb4f2717629b490.md b/vision-fixhub/ds9-unparsed-06/363d281ce9e08bd54663ad3f6d6ba92b9b51fa7b7814f1cbebb4f2717629b490.md
new file mode 100644
index 0000000000000000000000000000000000000000..78eaa76f0f5f070ce364c4ac0391917431709c83
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/363d281ce9e08bd54663ad3f6d6ba92b9b51fa7b7814f1cbebb4f2717629b490.md
@@ -0,0 +1,622 @@
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 1 of 23
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE No. 08-80736-CIV-MARRA/JOHNSON
+JANE DOE 1 and JANE DOE 2,
+Plaintiffs,
+V.
+UNITED STATES OF AMERICA,
+Defendant.
+SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK,
+MARTIN WEINBERG, AND JAY LEFKOWITZ IN SUPPORT OF THEIR
+MOTION FOR A PROTECTIVE ORDER CONCERNING PRODUCTION,
+USE, AND DISCLOSURE OF PLEA NEGOTIATIONS
+During the hearing on August 12, 2011, the Court directed the proposed intervenors to file
+additional briefing on their argument that plea negotiations are privileged and not subject to
+discovery or use as evidence in these proceedings. Proposed intervenors submit the following
+memorandum of law, which is identical to Parts I and II of the memorandum of law submitted by
+proposed intervenor Jeffrey Epstein in support of his motion for a protective orderand his opposition
+to the motions of the plaintiffs for production, use, and disclosure of his plea negotiations. If
+allowed to intervene, the lawyers would incorporate these arguments into their motion for a
+protective order, which was attached to their initial motion to intervene.
+Established case law as well as sound and substantial policy considerations prohibit
+disclosure of the letters and emails prepared by Mr. Epstein's lawyers during plea negotiations with
+the government, and require that the letters and emails that Jane Doe 1 and Jane Doe 2 already have
+remain confidential.
+In support of their position, proposed intervenors submit this memorandum
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 2 of 23
+of law.
+Part I shows that the Court should deny disclosure and use of the plea negotiations by simple
+reference to Rule of Evidence 410 and Federal Rule of Criminal Procedure 11(f), without having to
+reach the other issues raised by the parties and the proposed intervenors. This is because during the
+hearing on August 12, 2011, Jane Doe 1 and Jane Doe 2 admitted that they intend to use the plea
+negotiation letters and emails as substantive evidence at a "remedies hearing" where they will seek
+invalidation of Mr. Epstein's Non-Prosecution Agreement. Using this correspondence as evidence
+against Mr. Epstein is plainly prohibited by Evidence Rule 410 and Criminal Rule 11.
+Part II of this memorandum shows that Jane Doe 1 and Jane Doe 2 are not entitled to
+discovery or use of the plea negotiations not only because of the reach of Rules 410 and 11, but also
+because plea negotiations enjoy an evidentiary privilege as recognized by the Supreme Court in
+United States v. Mezzanatto, 513 U.S. 196, 204 (1995) ("Rules 410 and 11(e)(6) 'creat[e], in effect,
+a privilege of the defendant,' and, like other evidentiary privileges, this one may be waived or varied
+at the defendant's request"). Additionally, because plea negotiations are "rooted in the imperative
+need for confidence and trust," and because their confidentiality serves significant public and private
+ends, they are properly subject to a common law privilege under Federal Rule of Evidence 501.
+Similar privileges, which are "rooted in the imperative need for confidence and trust" and which
+serve significant public and private ends, have been recognized by Judge Marcus in the case of In
+Re Air Crash Near Cali, Colombia, 959 F. Supp. 1529 (S.D. Fla. 1997); by Chief Judge Vinson of
+the Northern District of Florida in Reichhold Chemicals, Inc. v. Textron, Inc., 157 F.R.D. 522 (N.D.
+Fla. 1994); and by a number of district courts recognizing a mediation privilege which shields from
+disclosure and use mediation documents, letters, and communications.
+2
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 3 of 23
+PART I
+A.
+PLEA NEGOTIATIONS MAY Not BE USED AGAINST MR. EPSTEIN
+UNDER THE PLAIN LANGUAGE OF THE FEDERAL RULES
+The Court should deny disclosure and use of the plea negotiations by simple reference to
+Rule of Evidence 410 and Rule of Criminal Procedure 11(f), without having to reach the other issues
+raised by the parties and the proposed intervenors. During the August 12, 2011 hearing, the plaintiffs
+admitted that they seek the defense letters and emails to offer them as evidence to support their
+request that the Court invalidate Mr. Epstein's Non-Prosecution Agreement. According to the
+plaintiffs, the plea negotiations will show that Mr. Epstein supposedly "engineered" and
+"orchestrated" the claimed Crime Victims' Rights Acts violations and that therefore the plaintiffs
+are entitled to negate Mr. Epstein's interest in the protections and finality of the Non-Prosecution
+Agreement. [August 12, 2011 Trans. at 33-34, 61, 107-09].
+The letters and emails exchanged between the government and defense counsel during plea
+negotiations are classic settlement discussions, written with the intention that they remain
+confidential. As such, they are protected by the constitutional right to effective assistance of counsel
+and the express language of Rule 410 and Federal Rule of Criminal Procedure 11(f). FED. R. EVID.
+410 (discussions made during plea negotiations are "not, in any civil or criminal proceeding,
+admissible against the defendant who ... was a participant in the plea discussions"); FED. R. CRIM.
+P. 11(f) ("the admissibility or inadmissibility of ... a plea discussion and any related statement is
+governed by Federal Rule of Evidence 410").
+Obviously, the plaintiffs intend to use the plea negotiation letters "against" Mr. Epstein.
+They protested during the August 12 hearing that the letters would be offered "against the
+3
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 4 of 23
+government" and "not against Mr. Epstein," but this is disingenuous given their emphatic and
+categorical representations to the contrary. [Compare Trans. at 29-30 with Trans. at 33-34, 61, 107-
+09]. The plaintiffs' arguments and accusations throughout this litigation, including the various
+conspiracy allegations leveled against Mr. Epstein during the August 12 hearing, establish that the
+plaintiffs' true purpose is to use the plea negotiations against Mr. Epstein in the current proceeding.
+The prohibition on admission of plea negotiation communications clearly extends to the
+current proceeding, whether it is denominated a quasi-criminal ora civil proceeding. The committee
+notes to former Rule 11(e)(6), which read almost identical to Rule 410, specifically state that the
+words "not... admissible against the defendant" refer to "the purpose for which [the evidence] is
+offered" and not "to the kind of proceeding in which the evidence is offered." FED. R. CRIM. PRO.
+11 advisory committee note 1979 amendment (emphasis added). Rule 11 was amended in 1979
+specifically to avoid confusion or misunderstanding regarding this phrase, and to emphasize that
+"against the defendant" means "the purpose" for which the evidence is being used:
+The phrase "in any civil or criminal proceeding" has been moved from its present
+position, following the word "against," for purposes of clarity. An ambiguity
+presently exists because the word "against" may be read as referring either to the kind
+of proceeding in which the evidence is offered or the purpose for which is offered.
+The change makes it clear that the latter construction is correct.
+Committee on Rules of Practice And Procedure of The Judicial Conference of The United States,
+Standing Committee On Rules of Practice And Procedure, 77 F.R.D. 507, 538 (February 1978)
+(emphasis added).
+Even though the plaintiffs claim that they would technically offer the plea negotiation letters
+against the government because the government is its opponent, their real and express purpose is to
+offer the plea negotiations against Mr. Epstein to prove his supposed culpability in encouraging the
+4
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 5 of 23
+government to breach what the plaintiffs contend is their statutory right to consultation, and to then
+seek the unprecedented and unconstitutional remedy of invalidation of the Non-Prosecution
+Agreement despite the fact that Mr. Epstein has already suffered all of its penal and adverse
+collateral consequences: jail, community custody, payment of substantial legal fees to an attorney
+representative for his accusers, payment of substantial civil settlements driven by waivers negotiated
+by the government to facilitate its witnesses bringing successful civil lawsuits, and registration
+requirements.
+Rules 410 and 11 plainly prohibit admission of the plea communications.
+B.
+BECAUSE PLEA NEGOTIATIONS ARE INADMISSIBLE, THE PLAINTIFFS
+BEAR THE BURDEN OF PARTICULARIZING A PROPER BASIS FOR DISCOVERY
+When a discovery request seeks "information subject to exclusion under the Federal Rules
+of Evidence, such as settlement information, ... many courts shift the burden to the requesting party,
+requiring them to make a particularized showing that the inadmissible evidence is likely to lead to
+admissible evidence." Reist v. Source Interlink Co., 2010 WL 4940096 at *2 (M.D. Fla. Nov. 29,
+2010); Bottaro v. Hatton Assocs., 96 F.R.D. 158, 159-60 (E.D.N.Y. 1982) (*the object of the inquiry
+must have some evidentiary value before an order to compel disclosure of otherwise inadmissible
+material will issue*). Such a burden-shifting analysis is particularly important where the discovery
+is protected by a rule of inadmissibility, where the plaintiffs have not identified any principled basis
+for discovery other than to seek to admit the plea communications in evidence, and where the
+policies behind the rule of inadmissibility would be compromised by any disclosure, regardless of
+whether the communications are later excluded as evidence in proceedings in this case.
+The plaintiffs in Bottaro sued a number of defendants for securities fraud. One defendant
+5
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 6 of 23
+settled and was dismissed from the lawsuit. The remaining defendants later moved to compel
+disclosure of the settlement agreement. In denying the motion to compel, the Court recognized the
+strong public policy favoring settlements, and the need to encourage settlements by ensuring against
+"unnecessary intrusion" into "the bargaining table." Id. at 160. For this reason, the Court held,
+parties seeking discovery of inadmissible settlement negotiations must first make a "particularized
+showing of a likelihood that admissible evidence will be generated" by their discovery request:
+Given the strong public policy of favoring settlements and the congressional intent
+to further that policy by insulating the bargaining table from unnecessary intrusions,
+we think the better rule is to require some particularized showing of a likelihood that
+admissible evidence will be generated by the dissemination of the terms of a
+settlement agreement. Since the terms of settlement do not appear to be reasonably
+calculated to lead to discovery of admissible evidence and the defendants have not
+made any showing to the contrary, this justification for [discovery] must fail.
+Id.; accord Reist, 2010 WL 4940096 at *2 (recognizing the "chilling effect" that discovery can have
+on the willingness of parties to enter into settlement negotiations).
+Other than their conclusory statement during the August 12 hearing that the plea negotiations
+would be used against the government and not Mr. Epstein, the plaintiffs have not made any
+particularized showing to convince this Court that any admissible evidence would result from their
+discovery of the plea negotiations. Accordingly, their request for discovery of clearly inadmissible
+evidence should be denied
+c.
+THE PLEA NEGOTIATIONS ARE IRRELEVANT BECAUSE THE PLAINTIFES
+ARE NOT ENTITLED To INVALIDATE THE NON-PROSECUTION AGREEMENT
+Additionally, the purpose for which the plaintiffs seek the plea negotiation letters - to set
+aside the Non-Prosecution Agreement - is a remedy that, if granted, would violate the Constitution
+and the statutory rights of both the government and Mr. Epstein. It would also be extraordinarily
+6
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 7 of 23
+inequitable given that while the plaintiffs failed to urge that this Court resolve their Complaint as
+an exigent or emergency matter, Mr. Epstein served the entirety of a prison sentence that resulted
+from obligations imposed upon him by the Non-Prosecution Agreement. He also served the entire
+community control consecutive sentence, and pursuant to the Non-Prosecution Agreement, he made
+payments of huge sums of money to the attorney representative of certain claimants. Finally, Mr.
+Epstein settled cases because of waivers within the Non-Prosecution Agreement.
+Under the Crime Victims' Rights Act, neither Jane Doe 1 nor Jane Doe 2 can invalidate the
+Non-Prosecution Agreement. The Act expressly prohibits it: "Nothing in this chapter shall be
+construed to impair the prosecutorial discretion of the Attorney General or any officer under his
+direction." 18 U.S.C. § 3771(d)(6).
+Under the Crime Victims' Rights Act, neither Jane Doe 1 nor Jane Doe 2 can invalidate the
+Non-Prosecution Agreement. The Act expressly prohibits it: "Nothing in this chapter shall be
+construed to impair the prosecutorial discretion of the Attorney General or any officer under his
+direction." 18 U.S.C. § 3771(d)(6).
+The Act codifies the long-standing principle that "[t]he Attorney General and United States
+Attorneys retain broad discretion to enforce the Nation's criminal laws." United States v. Armstrong,
+517 U.S. 456, 464 (1996). This is due in large part to the separation of powers doctrine. Id.; U.S.
+CONST. art. II, § 3. Whether to investigate possible criminal conduct, grant immunity, negotiate a
+plea, or dismiss charges, are all central to the prosecutor's executive function. United States v.
+Smith, 231 F.3d 800, 807 (11th Cir. 2000). "The judiciary cannot interfere with a prosecutor's
+charging discretion, except in narrow circumstances where it is necessary to do so in order to
+discharge the judicial function of interpreting the Constitution." Id. And this Court has not been
+7
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 8 of 23
+called upon to interpret the Constitution.
+Even in the case of In re Dean, 527 F.3d 391 (5th Cir. 2008), upon which the plaintiffs rely,
+the district court, after remand from the Fifth Circuit, denied the motion of the victims to invalidate
+the defendant's plea agreement as a remedy for the claimed violation of the Crime Victims' Rights
+Act. The court found that "[t]he purpose of the conferral right is not to give the victims a right to
+approve or disapprove a proposed plea in advance or to participate in plea negotiations." In re Dean
+on remand as United States v. BP Products North America, Inc., 610 F. Supp. 2d 655, 727 (S.D.
+Tex. 2009). Instead, "It]he purpose of the reasonable right to confer is for victims to provide
+information to the government, obtain information from the government, and to form and express
+their views to the government and court." Id. The district court concluded that the violations alleged
+by the victims did not provide a basis for rejecting the plea agreement. Id. at 726-27; see In re Acker,
+596 F.3d 370, 373 (6th Cir. 2010) (denying mandamus where petitioners sought to vacate plea
+agreement which made no provision for restitution in deference to pending civil litigation); United
+States v. Aguirre-Gonzalez, 597 F.3d 46 (Ist Cir. 2010) (relying on the "strong interest in the finality
+of criminal sentences" to reject mandamus under the Act where a defendant had pleaded guilty and
+had been sentenced more than two years earlier); see also United States v. Bedonie, 413 F.3d 1126,
+1129-30 (10th Cir. 2005) (district court had no authority under mandatory restitution act to reopen
+restitution proceedings after sentencing).
+More recently in the case of In re Peterson, No. 2:10-CV-298, 2010 WL 5108692 (N.D. Ind.
+Dec. 8, 2010), the district court denied relief under the Crime Victims' Rights Act before any charges
+were filed. The court recognized that the Act "guarantees crime victims a range of substantive and
+participatory rights," but that "[w]hether charges might be filed and proceedings initiated in the
+8
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 9 of 23
+future is a matter of prosecutorial discretion, and the [Act] expressly provides that "[n]othing in this
+chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any office
+under his direction."" Id. at *2 (quoting 18 U.S.C. § 3771(d)(6)).
+For these reasons, the Court should deny the motion of Jane Doe 1 and Jane Doe 2 to
+discover and use the plea negotiation letters as evidence.
+PART II
+MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED
+AND NOT DISCOVERABLE UNDER RULE 501
+Jane Doe 1 and Jane Doe 2 are also not entitled to discovery or use of the plea negotiations
+because plea negotiations enjoy an evidentiary privilege, as recognized by the Supreme Court in
+United States v. Mezzanatto, 513 U.S. 196 (1995). Additionally, because plea negotiations are
+"Tooted in the imperative need for confidence and trust," and because their confidentiality serves
+significant public and private ends, they are properly subject to a common law privilege under
+Federal Rule of Evidence 501. That Rule provides, in relevant part:
+Except as otherwise required by the Constitution of the United States or provided by
+Act of Congress or in rules prescribed by the Supreme Court pursuant to statutory
+authority, the privilege of a witness, person, government, State, or political
+subdivision thereof shall be governed by the principles of the common law as they
+may be interpreted by the courts of the United States in the light of reason and
+experience.
+FED. R. EVID. 501. This Court "has the power to recognize new privileges, consistent with Rule 501
+of the Federal Rules of Evidence, in cases arising under federal law." In Re Air Crash Near Cali,
+Colombia, 959 F. Supp. 1529, 1533 (S.D. FL. Feb. 7, 1997).
+9
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 10 of 23
+*REASON AND EXPERIENCE" ARE THE TOUCHSTONES
+FOR ACCEPTING A COMMON LAW PRIVILEGE FOR PLEA NEGOTIATIONS
+Jaffee v. Redmond, 518 U.S. 1 (1996), is perhaps the leading case addressing Rule 501 and
+the common-law principles underlying the recognition of testimonial privileges. The case involved
+a police officer and the extensive counseling she received after a traumatic incident in which she shot
+and killed a man. She was sued by the man's estate, which demanded discovery of the notes taken
+bythe clinical social worker who provided therapy. Id. at 5-6. The officer and the therapist objected
+and asserted that their sessions were privileged, but the distriet court disagreed
+The Seventh Circuit reversed and concluded that "reason and experience," which are "the
+touchstone for acceptance of a privilege under Federal Rule of Evidence 501," compelled recognition
+of a privilege between patient and psychotherapist. Id. "Reason tells us that psychotherapists and
+patients share a unique relationship, in which the ability to communicate freely without fear of public
+disclosure is the key to successful treatment." Id. The Seventh Circuit also observed that even
+though a number of older federal decisions had previously rejected the privilege, things had changed
+in the intervening years and the "need and demand for counseling" had "skyrocketed during the past
+several years." Id.
+The Supreme Court accepted certiorari to resolve a conflict among the Circuits, and affirmed
+the finding of a privilege.
+The Court's analysis was grounded 'in the light of reason and
+experience," which showed that a therapist's ability to help a patient "is completely dependent" upon
+the patient's "willingness and ability to talk freely." Id. at 10, quoting Advisory Committee's Notes
+to Proposed Rules, 56 F.R.D. 183, 242 (1972). The Court found that the psychotherapist-patient
+privilege is "rooted in the imperative need for confidence and trust" and that "the mere possibility
+10
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 11 of 23
+of disclosure may impede the development of the confidential relationship necessary for successful
+treatment." Id. at 10.
+Following Jaffee, three important sets of decisions have recognized privileges under Rule 501
+to protect information that is exchanged in an environment that encourages candid disclosures, and
+that depends on this open exchange of information to promote significant private and public
+interests. They are:
+the decision of Judge Mareus, before he was appointed to the Eleventh Circuit,
+denying discovery and recognizing a privilege for airline pilots who report incidents
+and violations, In Re Air Crash Near Cali, Colombia, 959 F. Supp. 1529 (S.D. Fla.
+1997);
+the decision of Judge Vinson, now the Chief Judge in the Northern District of
+Florida, denying discovery and recognizing a privilege for a corporation that reports
+contamination and other environmental hazards and violations to the Florida
+Department of Environmental Regulation, Reichhold Chemicals, Inc. v. Textron, Inc.,
+157 F.R.D. 522 (N.D. Fla. 1994); and
+a number of district court decisions denying discovery and recognizing a mediation
+privilege where litigants can "rely on the confidential treatment of everything that
+transpires during mediation ....
+" Lake Utopia Paper Ltd. v. Connelly Containers,
+Inc., 608 F.2d 928 (2d Cir.1979); Folb v. Motion Picture Ind. Pension & Health
+Plans, 16 F. Supp. 2d 1164, 1173 (C.D.Ca. 1998); Sheldone v. Pennsylvania
+Turnpike Comm'n, 104 F. Supp. 2d 511, (W.D. Pa. 2000); Microsoft Corporation v.
+Suncrest Enterprise, 2006 WL 929257 (N.D. Cal. Jan. 6, 2006).
+Judge Mareus and The Common Law Privilege Of Pilots Reporting Incidents
+And Violations, In Re Air Crash Near Cali, Colombia, 959 F. Supp. 1529 (S.D.
+Fla. 1997)
+In re Air Crash Near Cali, Colombia involved the crash of an American Airlines plane as
+it arrived in Cali just before Christmas, 1995. The crash killed 159 passengers and crew members.
+One hundred and thirty lawsuits were consolidated before Judge Marcus, and a steering committee
+was created to represent the plaintiffs. 959 F. Supp. at 1530.
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 12 of 23
+During discovery, American Airlines refused to produce a number of responsive documents,
+asserting that they were privileged because they were prepared pursuant to the American Airlines
+Safety Action Partnership Program, known as the ASAP program. The program was an initiative
+by the FAA, the Allied Pilots Association, and American Airlines. It was a "voluntary pilot
+self-reporting program designed to encourage pilots to report incidents and violations." Id. at 1531.
+The objectives of the ASAP program were "to identify and to reduce or eliminate possible flight
+safety concerns, as well as to minimize deviations from Federal Aviation Regulations." Id.
+Judge Marcus agreed that American Airlines had made "a compelling argument for
+recognition of a limited common law privilege for the ASAP materials." Id. at 1533. Relying on
+Jaffee, Judge Marcus found that he had the ability "to recognize new privileges, consistent with Rule
+501 of the Federal Rules of Evidence, in cases arising under federal law." Id. He addressed the
+following four factors:
+First, the "private interests" involved - "in other words, whether dissemination of the
+information will chill the 'frank and complete disclosure of facts' shared in an 'atmosphere of
+confidence and trust." Id. at 1533. Judge Marcus found that American Airlines, the pilots, and the
+FAA had an interest in air safety and in encouraging the flow of safety information. The FAA, as
+the regulatory body, also had an interest in being made aware of violations. Id. at 1534.
+Second, Judge Marcus considered the "public interests" furthered by the proposed privilege
+and found that there was a compelling public interest in improving the safety of commercial flights.
+Third, the "likely evidentiary benefit that would result from the denial of the privilege." Id.
+Judge Marcus did not find a benefit from denying the privilege. On the contrary, he agreed that
+violations would be "kept secret if the pilots believed that their reports might be used in litigation
+12
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 13 of 23
+or otherwise disseminated to the public." Id. Judge Marcus also agreed that failure to recognize the
+privilege would "reduce the willingness of pilots to report incidents" and would "seriously damage
+and probably terminate a uniquely successful safety program ... [which] relies on an assumption of
+strict confidentiality." Id. at 1534. He concluded that "without a privilege, pilots might be hesitant
+to come forward with candid information about in-flight occurrences, and airlines would be
+reluctant, if not altogether unwilling, to investigate and document the kind of incidental violations
+and general flight safety concerns whose disclosure is safeguarded by the ASAP program." Id.
+Finally, Judge Marcus warned that absent a privilege, "the prospect of ASAP reports being used by
+adverse parties in the course of litigation undoubtedly will affect the content, timeliness and candor
+of the reports submitted by its pilots." Id.
+Fourth, whether the privilege had been recognized by the states. Id. The Court was not aware
+of any state or federal court that had recognized the privilege claimed by American Airlines, but that
+did not dissuade him from finding that a privilege existed.
+With these considerations in mind, Judge Marcus ruled that "[t]here is a genuine risk of a
+meaningful and irreparable chill from the compelled disclosure of ASAP materials in connection
+with the pending litigation." Id. at 1534. Likewise in Mr. Epstein's case, there is a genuine risk of
+a meaningful and irreparable chill from the compelled disclosure of plea negotiations in connection
+with the pending litigation.
+Significant private interests support a plea negotiations privilege. It cannot be denied that
+defendants, prosecutors, the court system, victims, and law enforcement agencies all have a
+legitimate interest that criminal cases or investigations resolve by pleas. Plea negotiations benefit
+defendants by limiting their exposure to jail or other punishment; they benefit all the parties in the
+13
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 14 of 23
+system by avoiding the many expenses associated with jury trials; they benefit the court by keeping
+the flow of its dockets and making judges available to handle matters that are proceeding to trial or
+that are contested; and they benefit prosecutors and law enforcement not only by freeing their time
+so that they can focus on contested matters, but also by allowing them to debrief defendants and
+gather information about criminal activity.
+The public interests in criminal cases resolving by way of plea negotiations also cannot be
+denied. The public has an interest in the finality of plea negotiations, in ensuring that the courts,
+prosecutors, and law enforcement agencies are available to dedicate their time to contested matters,
+and in information that may be provided by defendants that will help curb criminal activity in their
+communities. The public, as well as private victims and government entities, all have an interest in
+restitution.
+There are significant evidentiary consequences if the Court denies a privilege to plea
+negotiations. As with air safety violations that would be "kept secret if pilots believed their reports
+might be used in litigation," defendants and people under criminal investigation would not engage
+in plea negotiations and waive their Fifth Amendment rights if they believed that statements made
+during those negotiations could be used against them later in litigation with third parties. Candid
+discussions simply cannot take place if defendants fear that statements made during negotiations can
+be divulged to third parties in other proceedings and used to harm them, send them to prison, or
+invalidate their bargains years after they have served prison sentences and suffered all the
+consequences of their deals. Just as the work-product privilege is created, in part, to encourage
+lawyers to keep notes without fear of disclosure, a privilege for plea communications is necessary
+to encourage lawyers to communicate, in writing, without fear that their proposals, submissions,
+14
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 15 of 23
+arguments, analysis of the facts, or legal arguments will become the grist of later civil litigation to
+the potential detriment to the client.
+Few if any lawyers would engage in candid and open discussions with a prosecutor if their
+statements could later be used against their clients. The ethical and constitutional obligations we
+now have to initiate and engage in plea negotiations would be terribly at odds with any rule that
+made those negotiations public and admissible in evidence to be used as ammunition to harm our
+clients.
+Chief Judge Vinson and the Common Law Privilege Of Reporting
+Environmental Hazards and Violations, Reichhold Chemicals, Inc. v. Textron,
+Inc., 157 F.R.D. 522 (N.D. Fla. 1994)
+Reichhold Chemicals involved a Consent Order between Reichhold and the Florida
+Department of Environmental Regulation. The Order obligated Reichhold "to investigate and
+remediate the contamination of groundwater on and under, and storm water runoff from, an industrial
+plant site it owns in Pensacola, Florida." 157 F.R.D. 523-24.
+Reichhold brought an action against former owners of the plant site, to recover some of the
+cost of remediating the land. The defendants sought reports that Reichhold had prepared describing
+possible environmental violations. Reichhold asserted that these documents were protected by "the
+privilege of self-critical analysis." Id. at 524. This privilege, "also known as the self-evaluative
+privilege," had been adopted in other jurisdictions, but at the time, it presented an issue of first
+impression to Chief Judge Vinson. He ruled in favor of Reichhold and found that the privilege
+allows individuals and companies to candidly assess their compliance with legal requirements
+without creating evidence to be later used against them by their adversaries:
+The self-critical analysis privilege has been recognized as a qualified privilege which
+15
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 16 of 23
+protects from discovery certain critical self-appraisals. It allows individuals or
+businesses to candidly assess their compliance with regulatory and legal requirements
+without creating evidence that may be used against them by their opponents in future
+litigation. The rationale for the doctrine is that such critical self-evaluation fosters the
+compelling public interest in observance of the law.
+Id. at 524. Judge Vinson agreed with Reichhold that the privilege was necessary to protect an
+organization or individual from the Hobson's choice of either undertaking an aggressive investigation
+and correcting dangerous conditions, "thereby creating a self-incriminating record that may be
+evidence of liability," or "deliberately avoiding making a record on the subject (and possibly leaving
+the public exposed to danger) in order to lessen the risk of civil liability." Id.
+In recognizing the privilege, Judge Vinson relied on Bredice v. Doctor's Hospital, Inc., 50
+F.R.D. 249 (D.D.C.1970), the first case to find a common law self-evaluation privilege. There, the
+hospital held staff meetings where the professional staff'evaluated the treatment provided to patients.
+In a medical malpractice action, the estate of Bredice sought the minutes of the hospital's staff
+meetings where Bredice's treatment or death were discussed. The court denied the discovery, noting
+that "review of the effectiveness and results of treatments were valuable in improving the quality of
+health care available to the general public," and that "physicians would be unwilling to candidly
+critique the actions of their colleagues if such evaluations were subject to discovery and use as
+evidence in a subsequent malpractice action." Id. at 525.
+The Common Law Mediation Privilege
+As is true in the case of plea negotiations, it seems self-evident that no system of mediation
+can function if parties fear that statements made and documents submitted in furtherance of
+mediation create a trail of incrimination that can later be used against them. "[C]ounsel, of necessity,
+[would] feel constrained to conduct themselves in a cautious, tight-lipped, noncommittal manner
+16
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 17 of 23
+more suitable to poker players in a high-stakes game than adversaries attempting to arrive at a just
+solution of a civil dispute." Lake Utopia Paper Ltd. v. Connelly Containers, Inc., 608 F.2d 928 (2d
+Cir. 1979).
+Lake Utopia involved the Second Circuit's Civil Appeals Management Plan, which called
+for parties to engage in a conference before oral argument, to hopefully settle their dispute. The
+Circuit adopted this mediation program to encourage the parties to settle, and to expedite the
+processing of civil appeals. Id. at 929.
+Counsel for the parties in Lake Utopia met pursuant to the program in an attempt to settle.
+The appellee later disclosed to the Court certain admissions made during the conference which
+showed that the appeal was frivolous. Rather than embrace this information, the Court chastised the
+appellee for disclosing it, holding that the purpose of the conference program was to encourage the
+parties to settle, and that the program would not function if statements made during the conference
+were later used against the parties. "It is essential to the proper functioning of the Civil Appeals
+Management Plan that all matters discussed at these conferences remain confidential. The guarantee
+of confidentiality permits and encourages counsel to discuss matters in an uninhibited fashion often
+leading to settlement ...." Id. at 930.
+Ten years later, in Folb v. Motion Picture Ind. Pension & Health Plans, 16 F. Supp. 2d 1164,
+(C.D.Ca. 1998), the district court in California became the first federal court to adopt the mediation
+privilege as federal common law under Rule 501. Relying on Lake Utopia Paper as well as a
+number of other decisions addressing the confidentiality of settlement negotiations, Folb held that
+"the need for confidentiality and trust between participants in a mediation proceeding is sufficiently
+imperative to necessitate the creation of some form of privilege." Id. at 1175. The court emphasized
+17
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 18 of 23
+that the mediation privilege is particularly important because federal courts rely on mediation to
+manage their dockets: "This conclusion takes on added significance when considered in conjunction
+with the fact that many federal district courts rely on the success of ADR proceedings to minimize
+the size of their dockets." Id.
+More recently in Sheldone v. Pennsylvania Turnpike Comm'n, 104 F. Supp. 2d 511, (W.D.
+Pa. 2000), the court relied on Jaffee and on Judge Marcus' decision in In re Air Crash Near Cali,
+Colombia to hold that all mediation documents and mediation communications are privileged and
+not subject to discovery. Mediation "afford[s] to litigants an opportunity to articulate their
+position[s] and to hear, first hand, both their opponent's version of the matters in dispute and a
+neutral assessment of the relative strengths of the opposing positions." Id. at 513. Without a
+mediation privilege, "parties and their counsel would be reluctant to lay their cards on the table so
+that a neutral assessment of the relative strengths and weaknesses of their opposing positions could
+be made." Id. This, of course, assumes that parties "would even agree to participate in the mediation
+process absent confidentiality." Id. Confidentiality is therefore "essential to the mediation process,"
+and it is "beyond doubt that the mediation privilege is rooted in the imperative need for confidence
+and trust." Id. at 514.
+No real distinction exists between the need to keep mediation confidential and the need to
+keep plea negotiations confidential. Both processes, and the goals they serve, are essentially
+identical. Both processes aim at encouraging settlement and compromise. Both processes depend
+on parties speaking candidly about the strengths and weaknesses of their positions. And in both
+processes, it would be manifestly unfair to require that parties attempt to settle their disputes in this
+fashion, only to later allow third parties to use their words as a weapon against them.
+18
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 19 of 23
+THE COURT SHOULD RECOGNIZE A PLEA NEGOTIATIONS PRIVILEGE
+The "central feature" of Rule 410 "is that the accused is encouraged candidly to discuss his
+or her situation in order to explore the possibility of disposing of the case through a consensual
+arrangement." United States v. Herman, 544 F.2d 791, 797 (5th Cir. 1977). The Rule is derived
+from "the inescapable truth that for plea bargaining to work effectively and fairly, a defendant must
+be free to negotiate without fear that his statements will later be used against him." Id. at 796. The
+legislative history, too, "shows that the purpose of Fed.R.Ev. 410 and Fed.R.Crim.P. 11(e)(6) is to
+permit the unrestrained candor which produces effective plea discussions between the . . .
+government and the ... defendant." Committee on Rules of Practice And Procedure of The Judicial
+Conference of The United States, Standing Committee On Rules of Practice And Procedure, 77
+F.R.D. 507 (February 1978) (emphasis added).'
+For these reasons, criminal defense lawyers negotiate with prosecutors in an environment of
+confidentiality, fostered by the protections of Rules 410 and 11. These rules encourage a process
+of searching and honest disclosures, and parties expect that their negotiations, and the information
+they exchange, will be protected from future use by an adversary. And because criminal defense
+lawyers are required, by ethical and constitutional considerations, to engage in plea negotiations to
+discharge their duty to represent the client's best interest, they do so with the well-founded
+expectation that communications made during those negotiations will not later be used to harm the
+client.
+' Rule 11(f) was formerly Rule 11(e)(6), which read almost identical to Rule 410.
+19
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 20 of 23
+1.
+The Court Should Recognize A Plea Negotiations Privilege Because Plea
+Negotiations Are Critical To The Criminal Justice System
+The Supreme Court has recognized that "Rules 410 and 11(e)(6) "creat[e], in effect, a
+privilege of the defendant..." Mezzanatto, 513 U.S. at 204. This privilege encourages disposition
+of criminal cases by plea agreement, which is essential to the administration of justice:
+The disposition of criminal charges by agreement between the prosecutor and the
+accused, sometimes loosely called "plea bargaining," is an essential component of
+the administration of justice. Properly administered, it is to be encouraged. If'every
+criminal charge were subjected to a full-scale trial, the states and the federal
+government would need to multiply by many times the number of judges and court
+facilities.
+Santobello v. New York, 404 U.S. 257, 260 (1971). "IT]he fact is that the guilty plea and the often
+concomitant plea bargain are important components of this country's criminal justice system.
+Properly administered, they can benefit all concerned." Blackledge v. Allison, 431 U.S. 63, 71
+(1977).
+Those sentiments are just as true today. The Bureau of Justice Statistics of the Department
+of Justice reports that in 2005, 96.1% of federal criminal cases were resolved by way of a plea
+bargain. www.ojp.usdoj.gov/bjs/pub/html/fjsst/2005/fjs05st.htm
+That today's justice system
+depends on plea negotiations is a monumental understatement.
+2. Negotiaton Shred ical To The Prete Represens Primo Because Plea
+Whether to negotiate a plea or contest a criminal charge "is ordinarily the most important
+single decision in any criminal case." Boria v. Keane, 99 F.3d 492 (2d Cir. 1996). In the age of the
+Sentencing Guidelines, with the draconian sentences called for in federal criminal cases, minimum
+mandatories, and the abolition of parole, engaging in meaningful and effective plea negotiations is
+20
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 21 of 23
+perhaps one of the most important roles of a criminal defense attorney. Today, the lawyer's "ability
+to persuade the judge or the jury is ... far less important than his ability to persuade the prosecutor"
+during plea negotiations. United States v. Fernandez, 2000 WL 534449 (S.D.N.Y. May 3, 2000)
+at *1.
+Counsel's failure to discharge his duties during plea negotiations is malpractice: "[]t is
+malpractice for a lawyer to fail to give his client timely advice concerning" pleas. Id. It also
+constitutes ineffective assistance of counsel, and violates the Constitution. Thus, counsel has a duty
+to advise clients fully on whether a particular plea is desirable, since "[e]ffective assistance of
+counsel includes counsel's informed opinion as to what pleas should be entered." United States v.
+Villar, 416 F. Supp. 887, 889 (S.D.N.Y. 1976); Boria v. Keane, 99 F.3d 492, 497 (2d Cir. 1996),
+citing ABA Model Code of Professional Responsibility, Ethical Consideration 7-7 (1992).
+Counsel also has a constitutional obligation to seek out information from the government,
+especially information that the government intends to use against the client. Failure to do so
+constitutes ineffective assistance of counsel. Rompilla v. Beard, 545 U.S. 374 (2005). "The notion
+that defense counsel must obtain information that the state has and will use against the defendant is
+not simply a matter of common sense, ... it is the duty of the lawyer ...." Rompilla v. Beard, 545
+U.S. 374, 386 (2005), citing 1 ABA Standards for Criminal Justice 4 4.1 (2d ed. 1982 Supp).=
+The constitution also requires that criminal defense lawyers conduct "a prompt investigation
+of the circumstances of the case," and this includes making every effort to secure information
+directly from the prosecutors:
+2 The Supreme Court has "long .... referred [to these ABA Standards] as 'guides in
+determining what is reasonable."" Rompilla v. Beard, 545 U.S. 374, 387 (2005).
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 22 of 23
+It is the duty of the lawyer to conduct a prompt investigation of the circumstances of
+the case. The investigation should always include efforts to secure information in the
+possession of the prosecution and law enforcement authorities. The duty to
+investigate exists regardless of the accused's admissions or statements to the lawyer
+of facts constituting guilt or the accused's stated desire to plead guilty.
+Rompilla v. Beard, 545 U.S. 374, 386 (2005), citing 1 ABA Standards for Criminal Justice 4 4.1 (2d
+ed. 1982 Supp).
+The lawyer's duty to investigate and obtain information from the prosecutor goes hand-inhand with the lawyer's additional duty to "make suitable inquiry" to determine whether valid
+defenses exist. Jones v. Cunningham, 313 F.2d 347 (4th Cir. 1963) ("Of course, it is not for a lawyer
+to fabricate defenses, but he does have an affirmative obligation to make suitable inquiry to
+determine whether valid ones exist").
+And regardless of whether valid defenses exist, counsel has a duty to initiate plea
+negotiations if he is to discharge his duty to faithfully represent the client's interests. Hawkman v.
+Parratt, 661 F.2d 1161, 1171 (8th Cir. 1981) (counsel's "failure to initiate plea negotiations
+concerning the duplicitous felony counts constituted ineffective assistance of counsel which
+prejudiced Hawkman").
+The Court Should Recognize A Plea Negotiations Privilege To Avoid A
+Meaningful And Irreparable Chill In Plea Negotiations
+Reason and experience tell us that the system we have in place of sentencing laws, ethical
+rules, federal court dockets, and constitutional considerations, will not function if plea negotiations
+are not privileged. After all, "it is immediately apparent that no defendant or his counsel [would]
+pursue [plea negotiations] if the remarks uttered during the course of it are to be admitted in evidence
+as proof of guilt." Herman, 544 F.2d at 797. Plea negotiations are "rooted in the imperative need
+22
+
+
+Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 23 of 23
+for confidence and trust," Jaffee, 518 U.S. at 10, and maintaining their confidentiality advances
+significant public and private ends. Discovery and use of plea negotiations will cause "a meaningful
+and irreparable chill" to the "frank and complete disclosures" that result in negotiated resolution of
+criminal matters. In re Air Crash Near Cali, Colombia, 957 F.2d at 1533.
+For these reasons, plea negotiations are properly subject to a common law privilege under
+Federal Rule of Evidence 501. The Court should hold that the plea negotiation letters and emails
+between Mr. Epstein's lawyers and the government are privileged and not subject to discovery or
+evidentiary use by the plaintiffs.
+We certify that on April 17, 2012, the foregoing document was filed electronically with the
+Clerk of the Court using the CM/ECF system.
+Respectfully submitted,
+BLACK, SREBNICK, KORNSPAN
+& STUMPF, P.A.
+201 South Biscayne Boulevard
+Suite 1300
+Miami, Florida 33131
+Office:
+Fax:
+By.
+/S/
+ROY BLACK, ESQ.
+Florida Bar No. L
+JACKIE PERCZEK, ESQ.
+Florida Bar No. L
+23
diff --git a/vision-fixhub/ds9-unparsed-06/363d281ce9e08bd54663ad3f6d6ba92b9b51fa7b7814f1cbebb4f2717629b490.receipt.json b/vision-fixhub/ds9-unparsed-06/363d281ce9e08bd54663ad3f6d6ba92b9b51fa7b7814f1cbebb4f2717629b490.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..48a1b295085695d2ecb2e4661cdc8f183753eef7
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/363d281ce9e08bd54663ad3f6d6ba92b9b51fa7b7814f1cbebb4f2717629b490.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -278,
+  "dataset": "marble-joined",
+  "doc_id": "363d281ce9e08bd54663ad3f6d6ba92b9b51fa7b7814f1cbebb4f2717629b490",
+  "engine": "marble-apple-vision",
+  "event_count": 24,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "b1790f8952c3531852f061c463bd6dfe0e85a2cf7f92a5c8b7f70c70e4ef39f4",
+  "output_sha256": "d94f58d6708be1d582f287ea60b36459a1e0bee2a204cc1b8373448e6d7923ac",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/36751111ba714c46fee22aea580fbb50bd767e801ccfb662beb34d54801a0af2.md b/vision-fixhub/ds9-unparsed-06/36751111ba714c46fee22aea580fbb50bd767e801ccfb662beb34d54801a0af2.md
new file mode 100644
index 0000000000000000000000000000000000000000..e761b7256268b26bf562f8e696f64fbfd4e1cf63
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/36751111ba714c46fee22aea580fbb50bd767e801ccfb662beb34d54801a0af2.md
@@ -0,0 +1,21 @@
+From: "
+To: "LaGrone, Katie (WPTV)" .
+Cc: "Castillo, Annette (USAFLS
+Subject: RE: WPTV- Jeffrey Epstein
+Date: Fri, 12 Aug 2011 18:15:12 +0000
+Importance: Normal
+Thanks for your email. I believe that agreement is not public. Additionally, we won't be making any out of court comments.
+-Original Message---
+From: LaGrone, Katie (WPTV)
+Sent: Friday, August 12, 2011 1:12 PM
+To:
+Subject: WPTV-- Jeffrey Epstein
+Good afternoon-- I am attending the 2pm hearing in regards to case against the US attney over Jeffrey Epstein's non-prosecution
+agreement.
+Case is 08-80736. Can u please send me a copy? In addition, please call me when you get a moment.
+Thank you!
+Katie LaGrone
+WPTV
+Sent from iPhone
+Scripps Media, Inc., certifies that its advertising sales agreements do not discriminate on the basis of race or ethnicity. All advertising sales
+agreements contain nondiscrimination clauses.
diff --git a/vision-fixhub/ds9-unparsed-06/36751111ba714c46fee22aea580fbb50bd767e801ccfb662beb34d54801a0af2.receipt.json b/vision-fixhub/ds9-unparsed-06/36751111ba714c46fee22aea580fbb50bd767e801ccfb662beb34d54801a0af2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2048e56d4276be5eb55f0d553801609c3f9658d6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/36751111ba714c46fee22aea580fbb50bd767e801ccfb662beb34d54801a0af2.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "36751111ba714c46fee22aea580fbb50bd767e801ccfb662beb34d54801a0af2",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e83c71df13721f758a4e972c11c4456d4645a43f9f12ae5e2f185f26edf92d77",
+  "output_sha256": "01acd6ef2eeced4f2397819a38728f57df581442381771e4d5b714deb8f8c70a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3688f9c35a4065e481099307632a2dc6201125e26fcca0de998d71560ba99ea0.md b/vision-fixhub/ds9-unparsed-06/3688f9c35a4065e481099307632a2dc6201125e26fcca0de998d71560ba99ea0.md
new file mode 100644
index 0000000000000000000000000000000000000000..204db3658f6a4baa98200ba7d08cc23ba96daacc
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3688f9c35a4065e481099307632a2dc6201125e26fcca0de998d71560ba99ea0.md
@@ -0,0 +1,52 @@
+From: Paul Cassell <
+To: Paul Cassell <
+Cc: Brad Edwards <
+(USAFLS)"
+Subject: RE: Proposed Pleading to File - fixed a couple of sentences
+Date: Wed, 27 Oct 2010 20:10:21 +0000
+Importance: Normal
+Attachments: response-order-show-cause-usattyrevision2.doex
+(USAFLS)"
+I noticed that I missed a couple of sentences in the pleading I sent to you that made reference to the simultaneously filed declaration of
+Brad Edwards. This revision fixes those couple of sentences, making reference only to a soon-to-be filed declaration. Paul
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+S.J. Quinney College of Law at the University of Utah
+Salt Lake City, UT 84112-0730
+http://www.law.utah.edu/protiles/default.asp?PersonID=57&name=Cassell,Paul
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of
+the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use,
+disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by
+reply electronic mail and delete the original message. Thank you.
+-----Original Message-...-
+From: Paul Cassell
+Sent: Wednesday, October 27, 2010 1:50 PM
+Subject: RE: Proposed Pleading to Pile
+THE FOLLOWING COMMUNICATION IS A SETTLEMENT OFFER WITHIN THE MEANING OF FEDERAL RULE OF
+EVIDENCE 408
+Attached is proposed pleading that we would file, reflecting your request that we delay and reflecting your stipulation that the passage of
+time to this point has not prejudiced the U.S. Attorney's Office.
+I want to continue to remind your office of its obligation to use its "best efforts" to protect the rights of crime victims. 19 USC 3771(c)
+(1). I trust that as you review our proposed pleading you will bear that requirement in mind.
+I can be reached on my cell at
+As you know, we have to file today and are prepared to do so if we can't work something
+out. At the same time, we would like to work cooperatively with your office to bring Epstein to justice -- our revised pleadings are a step
+in that direction, while hopefully responding to the concerns that your Office has raised.
+Paul Cassell
+Counsel for Jane Doe #1 and Jane Doe #2
+
+
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah
+Salt Lake City, UT 84112-0730
+http://www.law.utah.edu/protiles/default.asp?Person|D=57&name=Cassell,Paul
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of
+the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use,
+disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by
+reply electronic mail and delete the original message. Thank you.
+--Original Message-...-
+Sent: Monday, October 25, 2010 10:16 AM
+To: Paul Cassell
+Subject: Out of Office AutoReply: Conferring on Statement of Facts Before Wednesday's Filing
+I will be on government travel from October 25-26, 2010. If you need to reach me, please call me at
+Thanks.
diff --git a/vision-fixhub/ds9-unparsed-06/3688f9c35a4065e481099307632a2dc6201125e26fcca0de998d71560ba99ea0.receipt.json b/vision-fixhub/ds9-unparsed-06/3688f9c35a4065e481099307632a2dc6201125e26fcca0de998d71560ba99ea0.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b5b650c0d93a6989d188633ea40850097b2d4486
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3688f9c35a4065e481099307632a2dc6201125e26fcca0de998d71560ba99ea0.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "3688f9c35a4065e481099307632a2dc6201125e26fcca0de998d71560ba99ea0",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "333313a5026951a4b22d5e5c93318e6334d18d979d0e25d3982f548892b7be70",
+  "output_sha256": "70f76036fffa46b43010961ba602c58967ca3c411768b629b8875a7850c80777",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/36cf3854517ded8e0aa888939813863bf5f40cc89d357c4f20b50f983882caf5.md b/vision-fixhub/ds9-unparsed-06/36cf3854517ded8e0aa888939813863bf5f40cc89d357c4f20b50f983882caf5.md
new file mode 100644
index 0000000000000000000000000000000000000000..fbd1717d76ce6d0e5b0ed15df01f8017526a0369
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/36cf3854517ded8e0aa888939813863bf5f40cc89d357c4f20b50f983882caf5.md
@@ -0,0 +1,62 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov»
+Subject: Activity in Case 9:08-cv-80119-KAM Doe |. Epstein Notice (Other)
+Date: Wed, 03 Feb 2010 21:46:23 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Pike, Michael on 2/3/2010 at 4:46 PM EST and filed on 2/3/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 461
+Doe | Epstein
+9:08-cv-80119-KAM
+Jeffrey Epstein
+Docket Text:
+NOTICE by Jeffrey Epstein Re-Notice (Date & Location Change) of Independent Medical
+Examination of Plaintiff, Jane Doe #7 (Pike, Michael)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+ahorowitz@sexabuseattorney.com
+Bradley James Edwards
+brad@pathtojustice.com, beth@pathtojustice.com
+Isidro Manuel Garcia
+isidrogarcia@bellsouth.net
+Jack Alan Goldberger
+jagesq@bellsouth.net, nalanis@agwpa.com
+Jack Patrick Hill
+jph@searcylaw.com, c/w@searcylaw.com, kmo@searcylaw.com, s.slater@searcylaw.com,
+sas@searcylaw.com, vat@searcylaw.com
+Jeffrey Mare Herman
+jherman@hermanlaw.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+Michael James Pike MPike@bclclaw.com, bobbie@bclclaw.com, jcadwell@bclclaw.com
+
+
+Paul G. Cassell cassellp@law.utah.edu
+Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com
+Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton@podhurst.com,
+mestrada@podhurst.com
+Robert Deweese Critton, Jr rerit@belclaw.com, bobbie@bclelaw.com
+Stuart S. Mermelstein
+ssm@sexabuseattorney.com, jarbour@sexabuseattorney.com
+Irivera(@sexabuseattorney.com
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+Martin G. Weinberg
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP dcecfStamp_ID=1105629215 [Date=2/3/2010] [FileNumber=7224328-0]
+[8efel5al12442alafld87b7fb0eb2059cdd02edfb8e7eedc2de0fb8ed03a83ca158e
+9c9a508a5aa4b6af7917fc0611ce8634bf84bf22d6766930elae54ff496a]]
diff --git a/vision-fixhub/ds9-unparsed-06/36cf3854517ded8e0aa888939813863bf5f40cc89d357c4f20b50f983882caf5.receipt.json b/vision-fixhub/ds9-unparsed-06/36cf3854517ded8e0aa888939813863bf5f40cc89d357c4f20b50f983882caf5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..8079d65a36cb8a30451251a88bb0f9f8d62db133
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/36cf3854517ded8e0aa888939813863bf5f40cc89d357c4f20b50f983882caf5.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -25,
+  "dataset": "marble-joined",
+  "doc_id": "36cf3854517ded8e0aa888939813863bf5f40cc89d357c4f20b50f983882caf5",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "dd2774a95827c836015c78bbc1d2b3e0e15359c855c0911d3f425019a264f677",
+  "output_sha256": "8ce083f528caf2ccc563c912aabcbfa4a1147873b70cd2a09c8695fb06e8270f",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/374fa0eabc3920cbd72a3d2ba1bbf46c3a39dce8e8bb1f6f055120526126c8aa.md b/vision-fixhub/ds9-unparsed-06/374fa0eabc3920cbd72a3d2ba1bbf46c3a39dce8e8bb1f6f055120526126c8aa.md
new file mode 100644
index 0000000000000000000000000000000000000000..58c993cfb5ff3406cff4d610d4a7846fcdd5b823
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/374fa0eabc3920cbd72a3d2ba1bbf46c3a39dce8e8bb1f6f055120526126c8aa.md
@@ -0,0 +1,32 @@
+From:
+To:
+Subject: FW: Jane Doe #1 and Jane Doe #2 vs. US
+Date: Mon, 03 Oct 2011 19:42:49 +0000
+Importance: Normal
+Attachments: Plaintifis
+_Ist_ RFP_to_US
+_ATTY.pdf
+Inline-Images: image001 jpg
+Hi everyone - 1 am forwarding to you the Jane Does first Requests for Production of Documents, which just
+arrived. This will give us some context for our discussion on Wednesday.
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Fax
+From: Maria Kelljchian [mailto:maria@pathtojustice.com]
+Sent: Monday, October 03, 2011 2:06 PM
+To: Villafana, Ann Marie C. (USAFLS); Lee, Dexter (USAFLS); 'RBlack@royblack.com'
+Cc: 'Paul Cassell'; brad@pathtojustice.com
+Subject: Jane Doe #1 and Jane Doe #2 vs. US
+Attached please find:
+JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT REGARDING
+INFORMATION RELEVANT TO THEIR PENDING ACTION CONCERN THE CRIME VICTIMS RIGHTS ACT
+Copy has also been sent via US Mail today.
+Maria W. Kelljchian
+Florida Registered Paralegal
+Farmer, Jaffe, Weissing,
+Edwards, Fistos & Lehrman, P.L.
+Fort Lauderdale, Florida 33301
+fax
+maria@pathtojustice.com
+Become our fan on Facebook
diff --git a/vision-fixhub/ds9-unparsed-06/374fa0eabc3920cbd72a3d2ba1bbf46c3a39dce8e8bb1f6f055120526126c8aa.receipt.json b/vision-fixhub/ds9-unparsed-06/374fa0eabc3920cbd72a3d2ba1bbf46c3a39dce8e8bb1f6f055120526126c8aa.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..93ad0e664ad3de54f0e9140f7c4373bce59d3749
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/374fa0eabc3920cbd72a3d2ba1bbf46c3a39dce8e8bb1f6f055120526126c8aa.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "374fa0eabc3920cbd72a3d2ba1bbf46c3a39dce8e8bb1f6f055120526126c8aa",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "d2e5835769f073139b55d6cc9f174b36bfba162401d10294d2dd6e88051403ac",
+  "output_sha256": "8bca8768fbeb9973421027588a5be8994f6382d3150e138df6f7d93bf21948fb",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3755ce7c8a3ceaeae6f9207784ff0498a356487eee812c0352447627c202db7d.md b/vision-fixhub/ds9-unparsed-06/3755ce7c8a3ceaeae6f9207784ff0498a356487eee812c0352447627c202db7d.md
new file mode 100644
index 0000000000000000000000000000000000000000..5426d887cb0f75de5dfa85737bc2d27b1da50734
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3755ce7c8a3ceaeae6f9207784ff0498a356487eee812c0352447627c202db7d.md
@@ -0,0 +1,9 @@
+Subject: Re: Epstein
+Date: Fri, 27 Aug 2010 21:48:21 +0000
+Importance: Normal
+Sure. We're going to be out on surveillance first thing Monday morning. Would late morning / early afternoon be ok?
+Sent: Fri Aug 27 17:14:04 2010
+Subject: FW: Epstein
+Ms. Sarnoff has called former U.S. Attorney Acosta with some information. Can we all talk on Monday?
+Thanks.
+Sent: Friday, August 27, 2010 4:07 PM
diff --git a/vision-fixhub/ds9-unparsed-06/3755ce7c8a3ceaeae6f9207784ff0498a356487eee812c0352447627c202db7d.receipt.json b/vision-fixhub/ds9-unparsed-06/3755ce7c8a3ceaeae6f9207784ff0498a356487eee812c0352447627c202db7d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7aab03cde89ad672fb851b2f025999c4986c908f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3755ce7c8a3ceaeae6f9207784ff0498a356487eee812c0352447627c202db7d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "3755ce7c8a3ceaeae6f9207784ff0498a356487eee812c0352447627c202db7d",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "f92e371a67f3c772e7362d96f6ebc9533a7d80b0dbc439828aab6af80329b34b",
+  "output_sha256": "26683a8738eaebfef667deb49072f402f57eb62a84321f69fc981914616008ed",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3767cead46b7abd0a793fbe2fff660481e5936fab1692b53e1194f9e9498ecad.md b/vision-fixhub/ds9-unparsed-06/3767cead46b7abd0a793fbe2fff660481e5936fab1692b53e1194f9e9498ecad.md
new file mode 100644
index 0000000000000000000000000000000000000000..70016de04f870fc5cf7109c4f91ca77fbaff7772
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3767cead46b7abd0a793fbe2fff660481e5936fab1692b53e1194f9e9498ecad.md
@@ -0,0 +1,515 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs
+UNITED STATES,
+Defendants
+JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR PRODUCTION
+TO THE GOVERNMENT REGARDING INFORMATION RELEVANT TO THEIR
+PENDING ACTION CONCERN THE CRIME VICTIMS RIGHTS ACT
+COME NOW Jane Doe #1 and Jane Doe #2 ("the victims"), by and through undersigned
+counsel, and request the defendant United States (hereinafter "the Government") to produce the
+original or best copy of the items listed herein below for inspection and/or copying, pursuant to
+the Court's Order (DE #99) directing discovery in this case.
+BACKGROUND
+As the Government will recall, the victims have asked the Government to stipulate to
+undisputed facts in this case. The Government has declined. Accordingly, the victims filed their
+Motion for Finding of Violations of the Crime Victims' Rights Act and Request for a Hearing on
+Appropriate Remedies (DE 48) (the victims* "summary judgment motion") along with a Motion
+to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts
+(DE 49).
+On September 26, 2011, the Court denied the victims" motion to have their facts accepted
+(DE 99 at 11). At the same time, however, the Court has ordered discovery to develop the
+
+
+factual record concerning the summary judgment motion (DE 99 at 11). The Court reserved
+ruling on the victims' motion for an order directing the Government not to suppress relevant
+evidence (DE 99 at 11).
+On September 28, 2011, the victims requested that the Government voluntarily provide
+documents concerning this case. The Government declined to provide even a single document.
+Accordingly, the victims now seek the following information relevant to their pending summary
+judgment motion.
+DISCOVERY REQUESTED
+The numbered discovery requests below should all be construed in light of the definitions of
+terms provided at the end of the requests.
+1. In the victims' currently-pending summary judgment motion, the victims contend that the
+Government conducted an extensive criminal investigation into Jeffrey Epstein's sexual
+exploitation of young girls, including Jane Doe #1 and Jane Doe #2 between 2001 and 2008.
+The victims also contend that the FBI and other federal agencies established that Epstein
+operated a large criminal enterprise that used paid employees and underlings to repeatedly find
+and bring minor girls to him. In deferring ruling on the victims' summary judgment motion, the
+Court noted that the victims had alleged that the FBI and the U.S. Attorney's Office's
+"investigation developed a strong case for a federal prosecution against Epstein based on
+"overwhelming' evidence." DE 99 at 2. The Court, however, also noted that this was an
+allegation that needed "further factual development." DE 99 at 2 n.2. Please provide all
+documents, correspondence, and other information that supports these victims" allegations,
+including:
+(a) the FBI case file on the Epstein case;
+(b) all documents, correspondence, witness statements, FBI 302s, and other
+similar information, that the Government collected as part of its case against
+and/or investigation of Epstein, including any information provided to Epstein
+or receive from Epstein as part of "discovery" or exchange of information
+concerning the case;
+(c) all documents, correspondence, witness statements, and other similar
+information that the Government received from any federal, state, local, or
+other law enforcement agency regarding sex offenses committed against
+children by Jeffrey Epstein;
+(d) the 82-page prosecution memorandum (a/k/a "pros memo") outlining
+numerous federal sexual offenses committed by Epstein (and any attachments
+to that memorandum) and the 53-page draft indictment for numerous federal
+
+
+offenses that the Government developed in this case and any similar successor
+or predecessor document; and
+(e) Any other prosecution memorandum regarding Jeffrey Epstein (and any
+documents attached to that memorandum) and all draft federal indictments
+that were prepared regarding Epstein. Please also provide all documents,
+correspondence, and
+other information regarding these prosecution
+memoranda and the draft federal indictments.
+2. Throughout their pending summary judgment motion, the victims contend that they
+received only limited notifications from the Government (and, in particular, the U.S. Attorney's
+Office acting through FBI agents) about the plea negotiations that occurred with Jeffrey Epstein
+and the non-prosecution agreement that was ultimately reached. Please provide all documents,
+correspondence and other information regarding victim notifications in this case, including (but
+not limited to):
+a) All crime victims notifications (and draft notifications) sent to Jane Doe #1 and
+Jane Doe #2 and the other identified victims of Epstein's offenses;
+b) All correspondence, documents, and other information regarding negotiations
+between the Government and Epstein's defense attorneys concerning the extent
+and nature of notifications to be made to Epstein's victims;
+c) All correspondence, documents, and other information regarding discussions
+between the Government, the FBI, the Palm Beach Police Department, the Palm
+Beach County State Attorney's Office, and Epstein's defense attorneys
+concerning the extent and nature of notifications to be made to Epstein's victims;
+d) All correspondence, documents, and other information regarding "marching
+orders" that were given to FBI agents regarding the information that they could
+provide to the victims about the negotiations and the non-prosecution agreement;
+e) All correspondence, documents, and other information regarding information that
+could be given to attorneys for the victims about the non-prosecution agreement,
+including information about what could be told to Brad Edwards (counsel for Jane
+Doe #1 and Jane Doe #2) about the non-prosecution agreement;
+f) All correspondence, documents, and other information regarding Epstein's
+awareness that his victims (including Jane Doe #1 and Jane Doe #2) would not be
+notified of the non-prosecution agreement (and its ultimate presentation in court)
+or given a chance to confer regarding the plea negotiations he was conducting
+with the Government.
+3. The victims allege in their pending summary judgment motion that the Government
+negotiated a non-prosecution agreement with Epstein and that among the subjects covered in that
+non-prosecution agreement was a confidentiality provision that precluded disclosing the
+agreement to them and to other victims. Please provide all draft plea agreements (both state and
+federal) and non-prosecution agreements prepared either by attorneys for the Government or by
+attorneys for Epstein, as well as any correspondence, documents or other information pertaining
+to these agreements and to any confidentiality provision in these agreements. Please indicate
+that date on which each of these proposed agreements was drafted and by whom.
+
+
+4. The victims allege in their pending summary judgment motion that the Government was
+interested in finding a place to conclude any plea agreement that would effectively keep
+Epstein's vietims (most of whom resided in or about West Palm Beach) from learning what was
+happening through the press.
+Please provide all correspondence, documents, and other
+information pertaining to negotiations between the Government and Jeffrey Epstein concerning
+the court and/or location in which Jeffrey Epstein would enter any guilty plea (including in
+particular any negotiations concerning concluding the plea in Miami or other location outside of
+West Palm Beach).
+5. The victims allege in their pending summary judgment motion that part of the plea
+negotiations with Epstein involved Epstein's efforts to make sure that the victims would be
+represented in civil cases against Epstein by someone who was not an experienced personal
+injury lawyer. Please provide all correspondence, documents, and other information pertaining
+to negotiations between the Government and Jeffrey Epstein regarding any legal representation
+of the victims in civil cases against Epstein, including any negotiations about what kinds of
+representation should be provided in a plea agreement or non-prosecution agreement.
+6. The victims allege in their pending summary judgment that the Government wanted the
+non-prosecution agreement with Epstein concealed from public view because of the intense
+public criticism that would have resulted had the agreement been disclosed and/or the possibility
+that victims would have objected in court and convicted the judge not to accept the agreement.
+Please provide all correspondence, documents, and other information concerning the
+Government's and/or Epstein awareness or discussion of this possible public criticism and/or
+victim objections.
+7. The victims allege in their pending summary judgment motion that the Government was
+aware that it potentially had obligations under the CVRA to notify the victims about the nonprosecution agreement and any related state court plea agreement. Please provide all
+correspondence, documents, and other information regarding the Government's awareness of its
+potential CVRA obligations in this case and regarding any discussions between the Government
+and Epstein concerning these CVRA obligations in this case. This should include any objections
+raised by Epstein to any notification of the victims (including Jane Doe #1 and Jane Doe #2) and
+any Government response to these objections. This should also include any correspondence and
+information about whether the CVRA applied to the victims.
+8. The victims allege in their pending summary judgment motion that, after Epstein signed
+the non-prosecution agreement, his performance was delayed while he used his significant social
+and political connections to lobby the Justice Department to obtain a more favorable plea deal
+(including lobbying components of the Justice Department in Washington, D.C., including the
+Child Exploitation Obscenity Section). Please provide all correspondence, documents, and other
+information regarding Epstein's lobbying efforts to persuade the Government to give him a more
+favorable plea arrangement and/or non-prosecution agreement, including efforts by former
+President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York),
+Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy
+Black on his behalf.
+
+
+9. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI
+advising them that "this case is currently under investigation." Please provide all documents,
+correspondence, and other information relating to those representations being made by the FBI to
+Jane Doe #1 and Jane Doe #2, including all information about whether the FBI was aware of the
+non-prosecution agreement at that time and about whether Epstein was aware of the notifications
+being made to the victims.
+10. In their pending summary judgment motion, the victims have alleged that the FBI was led
+to believe that their investigation of Epstein was going to produce a federal criminal prosecution
+and that the FBI was also misled by the U.S. Attorney's office about the status of the case.
+Please provide all documents, correspondence, and other information relating to these
+allegations, including:
+) All documents, correspondence, and other information relating to discussior
+etween the U.S. Attorney's Office and the FBI concerning the status of th
+investigation and the plea discussions with Epstein, as well as what kind of
+charges would appropriately be filed against Epstein;
+b) All documents, correspondence, and other information relating to the U.S.
+Attorney's Office's representations to the FBI and any other state or local law
+enforcement agency about how this case was being handled; and
+c) All documents, correspondence, and other information relating to whether the FBI
+would support the position of the U.S. Attorney's Office that it has not violated
+the rights of Epstein's victims in this case.
+11. In their pending summary judgment motion, the victims have alleged that they had
+various meetings with Government prosecutors and/or agents (including FBI agents). Related to
+these meetings, they also allege that in mid-June 2008, their attorney (Bradley J. Edwards)
+discussed with an AUSA involved in the case the need for filing federal charges and that the
+AUSA asked the attorney to send a letter about why such charges should be filed without
+these meetings with the victims and their legal counsel, including meetings with the victims on
+October 26, 2007, and January 31, 2008, and the contact with their legal counsel in mid-June
+2008. Please also provide all documents, correspondence, and other information related to
+contacts between the Government and the National Crime Victim's Law Institute (NCVLI)
+concerning possible legal representation or other assistance to the victims by NCVLI.
+12. In their pending summary judgment motion, the victims allege that in mid-June 2008,
+their attorney (Bradley J. Edwards) discussed with an AUSA involved in the case the need for
+filing federal charges and that the AUSA asked the attorney to send a letter about why such
+charges should be filed without disclosing the existence of the non-prosecution agreement. The
+victims further allege that on about July 3, 2008, their attorney sent a letter urging the filing of
+federal charges against Epstein. Please provide all documents, correspondence, and other
+information regarding these contacts, including e-mails and correspondence generated as a result
+of the attorney's inquiry and any action that was taken in response to the letter that he sent.
+
+
+13. In their pending summary judgment motion, the victims allege that on or about June 27,
+2008, the Government learned that Epstein would be entering his plea to state charges on about
+June 30, 2008. Please provide all documents, correspondence, and information regarding:
+a) How the Government Office learned that the plea was going to be entered;
+b) How the Government notified victims about the entry of the guilty plea; and
+c) The contents of the notifications given to the victims about the entry of the guilty,
+including whether the victims were informed about the non-prosecution
+agreement and about whether the entry of this plea would preclude prosecution of
+crimes Epstein had committed against them.
+14. In their pending summary judgment motion, the victims have alleged that the
+Government and Epstein worked together to keep the existence of the non-prosecution
+agreement secret, including declining comment about the existence of such an agreement when
+asked about it when his guilty plea in state court became public knowledge. Please provide all
+documents, correspondence, and information about the Government's and Epstein's efforts to
+keep the existence of the non-prosecution agreement secret, including all e-mails and
+correspondence about "declining comment" or similar devices to keep the non-prosecution
+agreement secret.
+15. In their pending summary judgment motion, the victims allege that at all materials times,
+it would have been practical and feasible for the Government to have kept the victims informed
+about the discussions concerning the non-prosecution agreement. The victims further allege that
+on about July 9, 2008, the U.S. Attorney's Office provided notice to Jane Doe #1 of some of the
+terms of the agreement between it and Jeffrey Epstein. The victims also received a "corrected"
+notification letter on about September 3, 2008. Please provide all documents, correspondence,
+and other information about these notifications, including:
+a) any information about whether these notifications should or should not include
+some mention of the non-prosecution agreement;
+b) any information about the contents of these notifications;
+c) any communications between the Government and Epstein's counsel regarding
+what the notifications should contain, including any communication on or about
+July 9, 2008, objecting to parts of the draft;
+d) Any communications between the Government and Epstein's counsel about
+which parts of the non-prosecution agreement were operative (including whether
+Part 3 was operative);
+e) Any communications between the Government and Epstein's counsel regarding
+the September 3, 2008, corrected notification letter; and
+f) any documents, correspondence, and other information regarding the practicality
+and feasibility of providing notice to the victims of the existence of the
+agreement, which shall include any correspondence related to meeting with the
+victims or notifying them in any way of the non-prosecution agreement.
+16. In their pending summary judgment motion, the victims allege that one of the senior
+prosecutors in the U.S. Attorney's Office joined Epstein's payroll shortly after important
+decisions were made limiting Epstein's criminal liability - and improperly represented people
+close to Epstein. In light of this fact, the peculiar nature of the non-prosecution agreement
+
+
+reached in this case, and other information in the possession of the victims, it is also possible that
+other improper relationships exist between Government agents and Epstein. Please provide any
+documents, correspondence, and other information regarding the possibility of any improper
+relationship, including:
+a) Attorney Bruce Reinhart's involvement in and/or awareness of any aspect of the
+Government's criminal investigation and/or possible prosecution/non-prosecution
+of Epstein;
+b) Attorney Bruce Reinhart's involvement in and/or awareness of the Government's
+interest in any witness, subject, or target of the Epstein investigation, including
+Ghislaine Maxwell,
+Lesley Groff,
+1, Larry Morrison, Larry Visoki, David Rogers, William
+Hammond, and Robert Roxburgh;
+c) All documents, correspondence, and other information reflecting telephone calls
+(including telephone logs and telephone billing statements) made by or received
+by Reinhart from Jellrey Epstein, the Florida Science Foundation, Jack
+Goldberger, Alan Dersowitz, Roy Black, Ken Starr, Lillian Sanchez, and any
+other person involved with the criminal defense of Jeffrey Epstein, including
+telephone calls to and from Jack Goldberger and the Florida Science Foundation;
+d) All documents, correspondence, and other information (including, for example, e-
+mails) that were sent to, copied to, or sent by Reinhart in which the word
+"Epstein,"
+. "Morrison," "Visoki," "Rogers," "Hammond,"
+Roxburgh,
+" "Florida Science Foundation," "Starr," "Black,"
+"Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," "358 El Brillo Way"
+appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger,
+or the Jeffrey Epstein investigation or prosecution;
+e) All documents, correspondence, and other information (including for example e-
+mails) of a similar nature that indicate that any other Government prosecutor has
+represented (or discussed representing) a person or entity related to Jeffrey
+Epstein or has received business or funds from a person or entity related to Jeffrey
+Epstein;
+f) All documents, correspondence, and other information that indicate or suggest
+that any Government prosecutor or investigator (including state and local
+prosecutor or investigator) has had any form of business, social, personal, or other
+relationship with Jeffrey Epstein or a person or entity related to Jeffrey Epstein;
+and
+g) All documents, correspondence, and other information that indicate or suggest
+that any Government prosecutor or investigator (including state and local
+prosecutor or investigator would receive anything of value, directly or indirectly
+from Jeffrey Epstein or a person or entity related to Jeffrey Epstein (including any
+charitable contributions to be made by Epstein to any entity).
+17. In December 2010, the victims sent a letter to the U.S. Attorney's Office for the Southern
+District of Florida, requesting that the Office investigate whether "improper influences" were
+brought to bear during the negotiations involving the possible prosecution (and ultimately the
+non-prosecution) of Jeffrey Epstein. That letter led to a reference of the matter to the Office of
+
+
+Professional Responsibility (OPR) in the Justice Department in Washington, D.C., which began
+some kind of an inquiry/investigation. Please provide:
+a) All documents, correspondence, and other information collected by the Office of
+Professional Responsibility (OPR) and any other component of the Justice
+Department (including the FBI) in response to the victims' letter;
+b) All documents, correspondence, witness statements, and other information
+c) All documents, correspondence, witness statements and other information
+collected as part of any criminal inquiry/investigation that was initiated as a result
+of that letter, including any inquiry/investigation into criminal conflict of interest
+violations (such as 18 U.S.C. § 205 and § 207)
+d) All documents, correspondence, witness statements, and other information
+collected by any federal investigative agency that was triggered by OPR's
+inquiry/investigation, including any FBI inquiry/investigation regarding any
+improper influences or criminal or ethical violations that may have been
+committed by government attorneys during the handling of the Epstein
+investigation and/or prosecution;
+e) Any documents, correspondence, and other information regarding the accuracy or
+inaccuracy of Bruce Reinhart's sworn statements (found in DE 79-1 at p. 31) that
+he "did not participate in any way in the Office's investigation of Epstein;" that he
+"was not involved in any of the Office's decisionmaking with regard to the
+Epstein matter;" and that he "never learned any confidential, non-public
+information about the Epstein matter;"
+f) Any documents, correspondence,
+or other
+information regarding the
+circumstances that lead OPR to send a letter to the victims on May 6, 2011,
+indicating that they would not provide any further assistance to the victims in
+connection with their allegations that improper influences were brought to bear on
+the Epstein case;
+g) Any document, correspondence, e-mail, memoranda, or other information
+prepared by OPR, the FBI, or other Justice Department Component as a result of
+or following up on the victims' December 2010 letter concerning the Epstein
+case: and
+h) Any documents, correspondence, or other information that OPR has collected or
+obtained regarding the Epstein investigation and/or prosecution.
+18. At a couple points during the prosecution of this action, including in approximately
+December 2010 and most recently after the August 2011 hearing, the Justice Department in
+Washington, D.C., discussed or determined that the U.S. Attorney's Office for the Southern
+District of Florida (USAO SDFL) was "conflicted out", or may be conflicted out, of handling
+various issues related to the Epstein case because it suffered from a conflict of interest. The
+Justice Department accordingly sent various issues related to the Epstein case (and, on
+information and belief, issues related to Jane Doe #1 and Jane Doe #2) to the Department of
+Justice and to a United States Attorney's Office in another District. Please provide all
+documents, correspondence, and other information regarding the potential conflicts of interest
+that the Justice Department discussed or determined existed for the USAO SDFL, as well as any
+referral that was made to Main Justice or to any other District, including any documents that
+
+
+were transmitted to any other District regarding the conflict and regarding what was to be
+investigated.
+19. In March 2011, former U.S. Attorney Alexander Acosta sent a three-page letter to the
+news media in which he claimed that when Government attorneys began investigating Epstein,
+Epstein launched "a yearlong assault on the prosecution and the prosecutors." Shortly thereafter,
+Jeffrey Epstein's defense attorney Roy Black sent a responsive letter to Alexander Acost's letter
+to the news media in which he claimed that he did not pry into the personal lives of prosecutors
+but merely pointed out misconduct and over-reaching by certain people involved in the Epstein
+investigation. Please provide all documents, correspondence and other information that supports
+or contradicts Acosta's allegations in his letter, including any information that the Justice
+Department received from Epstein attacking the prosecutors and investigators working on the
+case. Please also provides all documents, correspondence, information about misconduct and
+over-reaching that was provided by Black and that the Government found that supported or
+contradicted such allegations.
+20. In their pending summary judgment motion, the victims have alleged that Epstein's guilty
+plea to state charges was intended to be the consummation of a non-prosecution agreement that
+barred prosecution of federal offenses committed against them. They have further alleged that
+Epstein entered such a guilty plea on or about June 30, 2008. Please provide all documents,
+correspondence, and other information between the Government and state and local prosecutors
+and police agencies (including The Palm Beach Police Department and Palm Beach State
+Attorney's Office) regarding the Epstein investigation and ultimate Epstein plea.
+21. In their pending summary judgment motion, the victims have alleged that correspondence
+in the possession of the Government will support their claims. Please provide all documents,
+correspondence, and other information between Government attorneys/officials (including both
+federal and state prosecutors) and attorneys for Jeffrey Epstein (or non-attorney acting on
+Epstein's behalf) relating to (1) negotiations involving the possible prosecution (and ultimately
+the non-prosecution) by federal or state agencies for sex offenses, including sex offenses
+committed against Jane Doe #1 and Jane Doe #2, (2) Epstein's entry of state guilty pleas for
+related sex offenses; (3) a non-prosecution agreement entered into between Epstein and the
+Government that barred his prosecution for offenses committed against Jane Doe #1 and Jane
+Doe #2; (4) the fulfillment of Epstein's and/or the Government's obligations under the nonprosecution agreement and/or the state guilty pleas Epstein entered; (5) any work release or other
+conditional release of Epstein from confinement; (6) any designation of Epstein as a sex offender
+or restrictions on him contacting victims of his offenses (including Jane Doe #1 and Jane Doe
+#2); and (7) any termination of supervision or parole of Epstein. This information should include
+unredacted e-mails, letters, and correspondence of any type between government prosecutors
+working on the case (including, but not limited to, federal prosecutors Alexander Acosta,
+investigation) and defense attorneys representing Epstein (including, but not limited to, Roy
+Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy
+Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein
+(including, but not limited to former President Bill Clinton and Andrew Albert Christian Edward
+
+
+(a/k/a Prince Andrew, Duke of York). This should also include letters of recommendation or
+similar communications submitted to any Government official vouching for or providing support
+for Jeffrey Epstein.
+22. As you know, throughout their pending summary judgment motion, the victims have
+alleged that they were not properly notified of plea negotiations with Jeffrey Epstein and were
+denied their right to confer by the Government and that instead the Government gave Epstein
+generous concessions through the plea negotiations. Please provide any documents,
+correspondence and other information that reflects or discusses any consideration of any type
+that Epstein had previously provided or offered to provide to the Government (or any individual
+within the Government, in either his official or private capacity) or any person previously
+employed by the Government and involved in the Epstein investigation or prosecution. The
+documents, correspondence, and other information should include any information discussing:
+(a) Any donation or offer to donate, directly or indirectly, either funds, services,
+or any other valuable consideration to any person or entity;
+(b) Any offer to assist, directly or indirectly, any person to obtain employment,
+business opportunities, business clients, real estate, office properties;
+(c) Any offer to assist the Government or law enforcement agencies in the
+investigation or prosecution of any federal or state criminal offense;
+(d) Any consideration that Epstein had provided to Government or law
+enforcement agencies in the past; and
+(e) Any other consideration of any type that Epstein offered to provide or had
+provided in the past that could provide a basis for the Government extending
+Epstein a more generous or lenient plea bargain or non-prosecution agreement
+than would be received by any other similarly situated child abuse suspect.
+23. The Crime Victims' Rights Act, 18 U.S.C. § 3771(c)(1), requires the Government to use
+its "best efforts" to protect the rights of crime victims.
+Please provide all documents,
+correspondence, and other information that will assist Jane Doe #1 and Jane Doe #2 in protecting
+their rights under the CVRA, including all documents, correspondence, and other information
+that the Government previously identified as being helpful to the victims but refused to provide
+based on its legal interpretation (now rejected by the Court) that the CVRA did not apply to this
+case because no indictment was filed
+24. In the course of its investigation of Epstein and negotiations with Epstein, the
+jovernment (i.e., federal investigators and prosecutors) shared documents, correspondence, an
+information with other persons outside the federal government, including state and loca
+prosecuting and law enforcement agencies, prosecuting and law enforcement agencies in other
+countries, Epstein's legal counsel, legal counsel for crime victims, and other entities. Please
+provide all documents, correspondence, and other information that the Government shared with
+any entity or person outside the federal government, including all correspondence (including e-
+mails) with those entities or persons.
+25. After the victims had made extensive efforts to try and reach a stipulated set of facts in
+this case, in March 2011 the Government refused to negotiate about such facts. Accordingly, at
+that time the victims filed various motions to obtain evidence in this case and, at the same time,
+
+
+the victims voluntarily made all initial disclosures on their part that are required by Federal Rule
+of Civil Procedure 26(a)(1). Please provide all initial disclosures required by the Federal Rules
+of Civil Procedure, including all disclosures required by Rule 26(a)(1).
+DEFINITIONS
+For the purpose of construing the foregoing discvery requests, the following terms are
+defined:
+The term "documents" means and includes, without limitation, all writings of any kind,
+ncluding the originals and all non-identical copies or drafts, whether different from the origina
+by reason of any notation made on such copy or draft or otherwise including, without limitatior
+correspondence, memoranda, notes, diaries, statistics, letters, e-mails, electronic computer files,
+telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries,
+pamphlets, books, prospectuses, interoffice communications, offers, notations of any sort of
+converse on telephone calls, facingles, there mortions and laida pined matter,
+modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records
+or representations of any kind including, without limitation, photographs, charts, graphs,
+microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or
+electric records or representations of any kind including, without limitation, tapes, cassettes and
+dise recordings, and writings and printed material of every kind.
+The term "correspondence" means any tangible object that conveys information or
+memorializes information that was conveyed in tangible or oral form including, but not limited
+to, writings, letters, memoranda, reports, notes, e-mails, telephone logs, telephone billing
+information, telephone recordings, and interoffice communications.
+The term "Epstein's victims" means any person that the Government identified as a
+possible victim of a sex offense committed by Jeffrey Epstein, including Jane Doe #1, Jane Doe
+#2, all victims identified in attachment to the non-prosecution agreement entered into by Epstein,
+and another person that the Government investigated as a possible victim of Epstein's sex
+offenses.
+The term "Government" means the federal government, including all employees of and
+components of the United States Department of Justice (such as, the Office of the Attorney
+General, the Office of the Deputy Attorney General, the Criminal Divisions, the Office of
+Professional Responsibility, the Child Exploitation and Obscenity Section, the U.S. Attorney's
+Offices for the Southern District and Middle District of Florida, and the Federal Bureau of
+Investigation) and other federal government agencies with law enforcement responsibilities
+related to the Epstein case (such as the Internal Revenue Service). This request for production
+seeks all documents, correspondence, and other information held by all of these entities,
+including all employees of and components of the Justice Department that worked on or were in
+any way involved the Epstein investigation and/or that possess information relevant to the
+victims' claims.
+
+
+The term "including" means containing within the request, but not limiting the request.
+The term
+"witness statement" means any document or other recording in any form
+(including oral form) reflecting, recording, or otherwise memorializing a statement made or
+information conveyed by a potential witness, including for example FBI 302's. The term
+cludes information collected by any law enforcement, prosecuting or government agency
+ncluding all federal. state. and local law enforcement agencies located in Washington. D.C., c
+Florida.
+NO GRAND JURY TRANSCRIPTS SOUGHT
+If any of the foregoing requests cover grand jury transcripts, do not provide the grand
+jury transcript. If any of the foregoing requests include documents that quote directly from a
+grand jury transcript, please redact that particular quotation.
+PRIVILEGE LOG
+If you believe that any document, correspondence, or other information requested in this
+equest is subject to a privilege and if you intend to assert that privilege, please provide a
+"privilege log" consistent with Local Rule 26.1(g), including a description a document that is
+ocument, get ral sal iel after of the document dile of one holdene, ale the top a
+REDUCING UNDUE BURDEN
+If you believe that complying with any of the foregoing requests would be unduly
+any such burdease contact victims counsel - Bradley J. Edwards - to discuss ways to reduce
+DATED: October 3, 2011
+Respectfully Submitted,
+s/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+
+
+and
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utah
+Attorneys for Jane Doe #1 and Jane Doe #2
+CERTIFICATE OF SERVICE
+The foregoing document was served on October 3, 2011, on the following via US Mail and
+E-Mail Transmission:
+Assistant U.S. Attorneys
+500 S. Australian Ave.., Suite 400
+West Palm Beach. FL 33401
+Attorneys for the Government
+Roy Black, Esq.
+Jackie Perczek, Esq.
+Black, Srebnick, Kornspan & Stumpf, P.A.
+201 South Biscayne Boulevard
+Suite 1300
+Miami, FL 33131
+Attorneys for Proposed Intervenors Roy Black et al.
+Respectfully Submitted,
+S/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
diff --git a/vision-fixhub/ds9-unparsed-06/3767cead46b7abd0a793fbe2fff660481e5936fab1692b53e1194f9e9498ecad.receipt.json b/vision-fixhub/ds9-unparsed-06/3767cead46b7abd0a793fbe2fff660481e5936fab1692b53e1194f9e9498ecad.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d1b32faf279d554e9429769d5ded3f986a52d207
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3767cead46b7abd0a793fbe2fff660481e5936fab1692b53e1194f9e9498ecad.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -160,
+  "dataset": "marble-joined",
+  "doc_id": "3767cead46b7abd0a793fbe2fff660481e5936fab1692b53e1194f9e9498ecad",
+  "engine": "marble-apple-vision",
+  "event_count": 15,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "bfd2df3c20a9594e0831efdd90f37b875052b6631be1b3b10c5291947b25990a",
+  "output_sha256": "93de501e31d3ebe82253a46b850d3f9ad843c368ba8aee533e8b34e2cbde11aa",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/37c3cde2c5fc91745063c0e954c2b1b37cba8c3d030ffd67c4d73d1ef28606e9.md b/vision-fixhub/ds9-unparsed-06/37c3cde2c5fc91745063c0e954c2b1b37cba8c3d030ffd67c4d73d1ef28606e9.md
new file mode 100644
index 0000000000000000000000000000000000000000..1963d29ccd1a93cc8cea71f4d52ca2239b968ddf
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/37c3cde2c5fc91745063c0e954c2b1b37cba8c3d030ffd67c4d73d1ef28606e9.md
@@ -0,0 +1,237 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOES #1 and #2
+Petitioners,
+UNITED STATES
+Respondent.
+RESPONDENT'S MOTION TO DISMISS
+Respondent, United States of America, by and through its undersigned counsel, files its Motion to
+Dismiss, pursuant to Rules 12(b)(6) and 41(b), Federal Rules of Civil Procedure, and states:
+I. LITIGATION HISTORY
+On July 7, 2008, plaintiff Jane Doe filed her "Emergency Victim's Petition for Enforcement of Crime
+Victim's Rights Act, 18 U.S.C. Section 3771." (D.E. 1). On the same day, this Court issued an Order directing
+the United States Attorney to file a response to the petition by 5:00 p.m., Wednesday, July 9, 2008. (D.E. 3).
+On July 9, 2008, the United States Attorney filed the "Government's Response to Victim's Emergency Petition
+for Enforcement of Crime Victim Rights Act, 18 U.S.C. § 3771." (D.E. 7). The Court held a hearing on July
+11,2008.
+On August 18, 2008, the Court held a status conference. On August 21, 2008, the Court ordered the
+Government to produce a copy of the Non-Prosecution Agreement between the United States Attorney and
+Jeffrey Epstein, and simultaneously entered a protective order prohibiting petitioners from disseminating the
+Non-Prosecution Agreement beyond designated individuals. (D.E. 26).
+On September 25, 2008, petitioners filed their motion to unseal document. (D.E. 28). On October 8,
+2008, the Government filed its response in opposition to petitioners' motion. (D.E. 29). Petitioners filed their
+reply on October 16, 2008. (D.E. 30). On February 12, 2009, the Court denied petitioners' motion to unseal
+document. (D.E. 36).
+Since February 12, 2009, there has been no activity in this case, other than the filing of a notice by
+petitioners' counsel of his change in firm affiliation. (D.E. 37).
+II. THIS CASE SHOULD BE DISMISSED FOR LACK OF PROSECUTION
+Under Fed.R.Civ.P. 41(b), "Ti]f the plaintiff fails to prosecute or to comply with these rules or a court
+order, a defendant may move to dismiss the action or any claim against it." In Goforth v. Owens, 766 F.2d 1533
+(11 " Cir. 1985), the Eleventh Circuit observed that "[a] district court is authorized, on defendant's motion, to
+dismiss an action for failure to prosecute or to obey a court order or federal rule." Id. at 1535.
+A court's
+
+
+power to dismiss is an inherent aspect of its authority to enforce its orders and insure prompt disposition of
+lawsuits. Id., citing Link v. Wabash Railroad Co., 370 U.S. 626, 630-31 (1962), and Jones v. Graham, 709
+F.2d 1457, 1458 (11 # Cir. 1983).
+Under Rule 41(b), the legal standard to be applied is "whether there is a
+clear record of delay or willful contempt and a finding that lesser sanctions would not suffice." 766 F.3d at 1535.
+Dismissal of a case with prejudice is considered a sanction of last resort, applicable only in extreme
+circumstances. Id.
+The Government believes the instant case should be dismissed because of the clear record of delay.
+After the initial filing on July 7, 2008, and the emergency hearing on July 11, 2008, the only notable activity in
+the case was petitioners' invocation of this Court's authority to obtain a copy of the Non-Prosecution Agreement.
+D.E. 19. The Government, pursuant to the Court's Order to Compel Production and Protective Order (D.E.
+26), provided a copy of the Agreement to petitioners. On September 25, 2008, petitioners attempted to have the
+Court "unseal" the Non-Prosecution Agreement (D.E. 28). The Government opposed the motion because the
+Non-Prosecution Agreement had never been filed with the Court, under seal or otherwise. D.E. 29. On
+February 12, 2009, the Court denied petitioners' motion (D.E. 36). The Court specifically addressed
+petitioners claim that the Non-Prosecution Agreement should be unsealed because the government had
+mischaracterized some of its provisions:
+If and when such alleged mischaracterizations become relevant to an issue to be
+decided by the Court, the parties will be given an opportunity to advance their
+positions and the Court will resolve the issue. If disclosure of the Agreement will
+be required for the Court to resolve the issue, appropriate disclosure will be
+ordered (D.E. 36 at 1-2).
+Since nothing has occurred in the instant case since the February 12, 2009 Order, presumably petitioners did not
+believe the mischaracterizations they claimed were made by the Government became relevant to any issue to be
+decided by the Court.
+On September 8, 2010, this Court entered its Order Closing Case (D.E. 38). The Court noted that "[a]n
+examination of the docket reveals that no activity has taken place in this case since April of 2009. In light of the
+underlying settlements between the vietims and Mr. Epstein, it is hereby ORDERED AND ADJUDGED that
+this case is CLOSED." (D.E. 38)(emphasis in original).
+It is not unreasonable to believe that the instant
+action under the Crime Victims Rights Act was auxiliary litigation to support petitioners claims against Jeffrey
+Epstein for money damages, particularly with regard to obtaining documents and information from the United
+States Attorney. Once petitioners' damage claims against Mr. Epstein had been resolved, there would be no
+
+
+need for this auxiliary litigation. The absence of any activity in the case since April 2009 supports the
+conclusion that vindicating the petitioners' rights under the CVRA was not the primary purpose of this case.
+"A district court has inherent authority to manage its own docket "so as to achieve the orderly and
+expeditious disposition of cases."" Equity Lifestyle Properties, Inc. v. Florida Mowing and Landscape Service,
+Inc., 556 F.3d 1232, 1240 (11 « Cir. 2009)(citation omitted). Under Rule 41(b), the court may dismiss a claim
+if the plaintiff fails to prosecute it or comply with a court order. Id. "The power to invoke this sanction is
+necessary in order to prevent undue delays in the disposition of pending cases and to avoid congestion in the
+calendars of the District Court." Id., citing Durham v. Fla. East Coast Ry. Co., 385 F.2d 366, 367 (5 ' Cir.
+1967). The instant case was filed as an emergency matter on July 7, 2008. Within two days, the government
+filed a written response to the emergency petition, and the Court held an emergency hearing four days after the
+emergency petition was filed. After this initial flurry of activity, predicated on petitioners' claim of an
+emergency, petitioners have done little to advance the litigation and seek resolution of their claims. El
+This
+clear record of delay provides ample basis for this Court to exercise its discretion and dismiss this case for lack
+of prosecution under Rule 41(b).
+III. PETITIONERS HAVE FAILED TO STATE A CLAIM UPON WHICH RELIEF CAN BE
+GRANTED UNDER 18 U.S.C. $ 3771(a)(2)
+The heart of petitioners' claim under the Crime Victims Rights Act (CVRA) is that the United States
+Attorney was legally obligated, under 18 U.S.C. § 3771(a)(5), to consult with them prior to entering into the
+Non-prosecution Agreement with Jeffrey Epstein. D.E. 1, 9 5. This claim should be dismissed under Rule
+12(b)(6) because it fails to state a claim upon which relief can be granted.
+In Bell Atlantic Corp. v. Twombly, 127 S.Ct. 1955 (2007), the Supreme Court observed that a plaintiff's
+obligation to provide the grounds of his entitlement to relief requires more than labels and conclusions, and a
+formulaic recitation of the elements of a cause of action will not do. Id. at 1964-65. Instead, factual
+allegations must be enough to raise a right to relief above the speculative level.
+"The standard is one of
+"plausible grounds to infer" Id. In Ashcroft v. Iqbal, 129 S.Ct. 1937 (2009), the Supreme Court noted that two
+working principles underlay its decision in Twombly : (1) the tenet that a court must accept as true all of the
+allegations contained in a complaint is inapplicable to legal conclusions; and (2) only a complaint that states a
+plausible claim for relief survives a motion to dismiss. Id. at 1949-50.
+The rights of crime victims are set forth in 18 U.S.C. § 3771(a), and include eight (8) specific rights.
+The petition alleges a violation of § 3771(a)(5), the right to consult with the attorney for the Government; §
+
+
+3771(a)(2), the right to reasonable, accurate, and timely notice of any public court proceeding; § 3771(a)(6), the
+right to full and timely restitution as provided in law; and notice of her rights under the CVRA.
+It is undisputed that no federal criminal charges have been filed against Jeffrey Epstein, in the U.S.
+District Court, Southern District of Florida, pertaining to the sexual abuse of minors. #
+The United States
+submits that, since there is no "case" pending in the Southern District of Florida against Epstein, or any "court
+proceeding" involving an offense against Jane Does 1 and 2, they cannot invoke any protections under 18 U.S.C.
+§ 3771(a)(2) and (5).
+Title 18, United States Code, § 3771(a)(5), provides that a crime victim has "[t]he reasonable right to
+confer with the attorney for the Government in the case." In its interpretation of a federal statute, the court
+assumes that "Congress used words in a statute as they are commonly and ordinarily understood," and reads the
+statute to give full effect to each of its provisions. United States v. DBB. Inc., 180 F.3d 1277, 1281 (11 " Cir.
+1999), citing United States v. McLymont, 45 F3d 400, 401 (11 " Cir. 1995). Section 3771(a)(5) grants a
+crime victim the reasonable right to confer with the attorney for the Government "in the case." The phrase "in
+the case" must be considered since there is a canon of statutory construction that "discourages courts from
+adopting a reading of a statute that renders any part of the statute mere surplusage." Bailey v. United States,
+516 U.S. 137, 146 (1995)(noting that each word in a statute is intended to have "particular, nonsuperfluous
+meaning").
+Respondents submit that Congress intended the phrase "in the case" to mean a case filed in the district
+court.
+Federal criminal cases are filed in the United States district courts through the filing of a criminal
+complaint, Fed.R.Crim.P. 3, or indictment, Fed. R.Crim.P. 7. In each instance, an attorney representing the
+United States Government is required to sign the complaint or indictment. Thus, each criminal case filed in the
+district court has an attorney for the Government representing the sovereign United States.
+In contrast, § 3771(a)(1) provides that a crime victim "has the right to be reasonably protected from the
+accused." No mention is made about a case or court proceeding. Thus, Congress intended that this right
+attaches even before a case is filed in the district court. The absence of any mention of the attorney for the
+Government is also telling, since the case may still be in the investigative stage, and not yet been assigned an
+attorney. In such a case, the federal law enforcement agency would be responsible for providing the reasonable
+protection from the accused.
+Because there is not any case against Epstein in the Southern District of Florida, Jane Does 1 and 2 have
+no rights under § 3771(a)(5) to consult with the attorney for the Government. The United States Attorney's
+
+
+Office was under no obligation to consult with Jane Does 1 and 2 prior to concluding its Non-Prosecution
+Agreement with Epstein. For the same reason, Jane Doe's claim under § 3771(a)(2) also fails. There has
+been no "public court proceeding" against Epstein in the U.S. Distriet Court, Southern District of Florida, since
+no criminal case has been filed against him in the federal court. Consequently, there has been nothing for
+which the U.S. Attorney's Office was required to give notice to Jane Doe.
+A different provision in the CVRA, 18 U.S.C. § 3771(b), also supports the Government's interpretation of
+§ 3771(a)(5). Section 3771(b)(1) provides as follows:
+In any court proceeding involving an offense against a crime victim, the court
+shall ensure that the crime victim is afforded the rights described in subsection (a).
+Before making a determination described in subsection (a)(3), the court shall
+make every effort to permit the fullest attendance possible by the victim and shall
+consider reasonable alternatives to the exclusion of the victim from the criminal
+proceeding. The reasons for any decision denying relief under this chapter shall be
+clearly stated on the record.
+There is no "court proceeding" in this case because no federal criminal charges have been lodged against
+Jeffrey Epstein. Section 3771(b)(1) envisions that a district court presiding over a criminal trial will be
+responsible for ensuring that a crime victim will be afforded rights granted in § 3771(a).
+Section 3771(a)(3),
+which is expressly referenced in § 3771(b)(1), provides that a crime victim has
+The right not to be excluded from any such public court proceeding, unless the
+court, after receiving clear and convincing evidence, determines that testimony by
+the victim would be materially altered if the victim heard other testimony at that
+proceeding.
+This provision contemplates that, in the event a defendant invokes the rule of sequestration in Fed.R.Evid. 615,
+the court must consider the crime victim's rights under § 3771(a)(3), and can only exclude the victim from the
+proceeding if the court finds there is clear and convincing evidence that the victim's testimony would be
+materially altered if the victim was allowed to hear other testimony at the proceeding.
+By providing a difficult
+evidentiary standard which must be met before a victim's right to be present in the court proceeding can be
+denied, Congress was purposefully limiting a court's discretion in sequestering trial witnesses.
+In the instant case, there is no "court proceeding" since no federal criminal charges have been brought
+against Epstein. Therefore, § 3771(b)(1) is inapplicable. There is no role for this Court to fulfill under §
+3771(b)(1).
+The petition fails to state facts upon which the Court can find a plausible claim for relief exists.
+Accordingly, the petition should be dismissed for failure to state a claim upon which relief can be granted.
+IV. SEPARATION OF POWERS PRINCIPLES PRECLUDE THE COURT FROM GRANTING ANY
+RELIEF REGARDING THE NON-PROSECUTION AGREEMENT
+
+
+In the instant case, the Non-Prosecution Agreement between the Government and Jeffrey Epstein was
+concluded in September and October 2007, months before petitioners instituted their action. By entering into
+the Non-Prosecution Agreement, the United States was exercising its prosecutorial discretion as to the best
+means to resolve the allegations that Epstein had violated federal law by engaging in criminal sexual misconduct
+with minors.
+The Executive Branch enjoys exceedingly broad discretion in deciding how, or whether, to charge an
+individual. Bordenkircher v. Hayes, 434 U.S. 357, 668 (1978)("In our system, so long as the prosecutor has
+probable cause to believe that the accused committed an offense defined by statute, the decision whether or not
+to prosecute, and what charge to file or bring before a grand jury, generally rests entirely in his discretion")
+(footnote omitted), and Nixon v. United States, 418 U.S. 683, 693 (1974)(Executive Branch has exclusive
+authority and absolute discretion to decide whether to prosecute a case). Mindful of that principle, Congress
+expressly provided in the CVRA that, "InJothing in this chapter shall be construed to impair the prosecutorial
+discretion of the Attorney General or any officer under his direction." 18 U.S.C. § 3771(d)(6).
+Petitioners had no right under the CVRA to confer with the attorney for the Government, prior to the
+entry into the Non-Prosecution Agreement, because there was no existing case in the U.S. District Court.
+Moreover, even if they had the right to confer, they had no legal means to prevent the United States from
+negotiating the Agreement it ultimately entered into with Epstein. Unlike the situation in In Re Dean, 527 F.3d
+391 (5 " Cir. 2008), the Non-Prosecution Agreement did not come before any federal court for review and
+approval, nor was such action required. In Dean, if the district court believed that the victims had been denied
+their right to consult under § 3771(a)(5), it could reject the plea agreement and direct that the required
+consultation occur prior to the negotiation of any new plea agreement. In contrast, the Non-Prosecution
+Agreement never came before this court.
+Therefore, this Court is without authority to provide a remedy under §
+3771(b)(1).
+By:
+Respectfully submitted,
+WIFREDO A. FERRER
+UNITED STATES ATTORNEY
+Assistant U.S. Attorney
+99 N.E. 4 i Street
+Miami, Florida 33132
+
+
+Attorney for Respondent
+CERTIFICATE OF SERVICE
+, 2010, I electronically filed the foregoing document with the
+I HEREBY CERTIFY that on October
+Clerk of the Court using CM/ECF.
+Assistant U.S. Attorney
+SERVICE LIST
+Jane Does 1 and 2 v. United States,
+Case No. 08-80736-CIV-MARRA/JOHNSON
+United States District Court, Southern District of Florida
+Brad Edwards, Esq.,
+The Law Offices of Brad Edwards & Associates, LLC
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+S.J. Quinney College of Law at the University of Utah
+Attorneys for Petitioners
+H The emergency was based upon petitioners' belief that Jeffrey Epstein was engaged in plea
+negotiations with the United States Attorney's Office and that such negotiations would likely result in a
+disposition of the charges within the "next several days." D.E. 1, 9| 3. The petitioner noted that Epstein had
+already entered a plea of guilty on June 30, 2008, in the Circuit Court for Palm Beach County, Florida, to similar
+state offenses including solicitation of minors for prostitution. D.E. 1, 92.
+I2 "A district court may take judicial notice of public records within its files relating to the particular
+case before it or other related cases." (
+Cash Inn of Dade, Inc. v. Metropolitan Dade County, 932 F.2d 1239,
+1243 (11 # Cir. 1991)(citations omitted). Additionally, in a Rule 12(b)(6) motion, a court may properly consider
+materials of which it has taken judicial notice. Philips v. Pitt County Mem'l Hosp., 572 F.3d 176, 180 (4 ' Cir.
+2009).
diff --git a/vision-fixhub/ds9-unparsed-06/37c3cde2c5fc91745063c0e954c2b1b37cba8c3d030ffd67c4d73d1ef28606e9.receipt.json b/vision-fixhub/ds9-unparsed-06/37c3cde2c5fc91745063c0e954c2b1b37cba8c3d030ffd67c4d73d1ef28606e9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ddd3e9fe121010241cfe60459199180fae0e587a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/37c3cde2c5fc91745063c0e954c2b1b37cba8c3d030ffd67c4d73d1ef28606e9.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -84,
+  "dataset": "marble-joined",
+  "doc_id": "37c3cde2c5fc91745063c0e954c2b1b37cba8c3d030ffd67c4d73d1ef28606e9",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "471950e123c71de0d3043abc7dda94ac0d3b2b6cc554c2be7f6d046142731abd",
+  "output_sha256": "b2c96a0084b3eeb4c45d93a9d04ca74ac38be09d848465d40808c85017fdaa0a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/37c72396b23314f63c2259963e0069d9527ccd33c25440d59cc72623fb3fa794.md b/vision-fixhub/ds9-unparsed-06/37c72396b23314f63c2259963e0069d9527ccd33c25440d59cc72623fb3fa794.md
new file mode 100644
index 0000000000000000000000000000000000000000..2ee909d99130ecde279be7c8f1136ee776376eb4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/37c72396b23314f63c2259963e0069d9527ccd33c25440d59cc72623fb3fa794.md
@@ -0,0 +1,162 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+99 N.E. + Street
+Miami, FL 33132
+305.961.9290
+November 2, 2010
+Via E-Mail
+Wifredo A. Ferrer, United States Attorney
+InoobucA1C4 Civil Chief
+Privileged Communication
+Office of the United States Attorney
+Southern District of Florida
+99 NE 4' Street
+Miami, Florida 33132
+Re:
+Litigation Hold re:
+Jane Does #1 and #2 | United States, Case No.: 08-80736-CIV-
+MARRA/Johnson AND Jeffrey Epstein
+As a follow-up to your recent meeting concerning the above-referenced case, 1 write this
+letter in my capacity as the Electronic Discovery Coordinator within the Civil Division of the
+United States Attorney's Office for the Southern District of Florida (USAO-SDFLA). I write to
+advise you of the USAO-SDFLA's legal obligation to preserve documents and data relevant to
+the lawsuit and to enlist your assistance in this regard.
+The USAO-SDFLA is required by law to take all reasonable steps to preserve all
+documents and data relating to the claims set forth in the Victim's Emergency Petition for
+Enforcement of Crime Victim's Rights Act, 18 USC Section 3771 (DE 1) ("Victim's Petition")
+in Case No.: 9:08-cv-80736-Marra/Johnson in the Southern District of Florida, filed on July 7,
+2008. Based upon the facts set forth in the Court filings that are unsealed, I recommend that the
+Federal Bureau of Investigation (F.B.I.) and the Palm Beach Police Department also be requested
+to preserve any documents that they may have that are relevant to the Claims asserted in the
+above-referenced lawsuit.
+I request that you please read and acknowledge your receipt and agreement to the terms
+of this letter. I also ask that you please complete and sign the form accompanying this letter.
+Please return the originals of both documents to me by November 9, 2010.
+With respect to the claims asserted in the litigation, in the Victim's Petition (DE 1), Jane
+Doe # 1 brought claims against the United States for alleged violation of her rights under the
+Crime Victim's Rights Act ("CVRA"). The Jane Doe #1 petitioner alleges that she was the
+victim of federal crimes committed by Jeffrey Epstein, including sex trafficking of children by
+fraud in violation of 18 USC § 1591, use of interstate commerce to entice a minor to commit
+
+
+Re: Jane Does #1 and #2 |. United States
+Privileged Communication
+November 2, 2010
+Page -2-
+prostitution in violation of 18 USC § 2422 and wire fraud in violation of 18 US §1343. DE 1 at
+911. The Victim's Petition further alleges that in violation of the CVRA, Jane Doe #1 was not
+consulted with respect to the USAO-SDFLA's negotiations with Epstein (DE 1 at {13-6). The
+"Jane Doe #1 and Jane Doe # 2 Status Report and Response to Court's Order to Show Lack of
+Prosecution" (DE 41) argues that "there [was] an orchestrated decision [between the "U.S.
+Attorney's Office and Epstein] to deny the[] [Jane Doe Petitioners] their rights." DE 41 at 1. The
+Status Report alludes to communications between the USAO-SDFLA and counsel for Jeffrey Epstein
+"that [i]s highly relevant to the treatment of Jane Doe #1 and Jane Doe #2 in the criminal justice
+system - namely, correspondence between the [USAO-SDFLA] and legal counsel for Jeffrey Epstein
+during the negotiations surrounding the non-prosecution agreement" and the USAO-SDFLA and
+counsel for the Jane Does, on numerous matters related to Jeffrey Epstein, including contacts with
+AUSAs "Marie Villafaña and Dexter Lee." DE 41 at 3.
+The Government's filings frame the issue before the Court as to whether the
+"Government was obligated, under 18 U.S.C. § 3771(a)(5), to confer with petitioners prior to
+entering into an agreement with Jeffrey Epstein, which permitted the pending State of Florida
+prosecution to go forward, so long as Epstein agreed to certain conditions." Government's
+Notice To Court Regarding Absence of Need for Evidentiary Hearing. DE 17. The Government
+argues there are two relevant facts which will permit the Court to resolve the legal issue: (1)
+there are no criminal charges in the United States District Court, Southern District of Florida,
+filed against Jeffrey Epstein; and (2) Epstein entered pleas of guilty in Florida State Court on
+June 30, 2008, was sentenced, and is now imprisoned in Palm Beach County. DE 17. The
+Government's Response to the Victim's Petition ("Government's Response) notes that in 2006,
+Jeffrey Epstein was charged in the 15" Judicial Circuit Court in and for Palm Beach County,
+Florida with felony solicitation of prostitution. DE 13 at 1. The Response further notes that
+Epstein was not charged in the Southern District of Florida. DE 13 at 1-2. The Declaration of ...
+indicates that "in the summer of 2007, Mr. Epstein and the [USAO-SDFLA]
+entered into negotiations to resolve the investigation. At that time, Mr. Epstein had been charged
+by the State of Florida with solicitation of prostitution, in violation of Florida Statutes § 796.07."
+DE 14. The Declaration also details the communications that occurred when a victim was
+identified, including notification letters that were sent. DE 14. Attached to that Declaration are
+copies of redacted letters provided to victims "C.W.", "T.M.", and "S.R." by AUSA Villafaña
+and the FBI's Victim-Witness Specialist Twiller Smith. DE 14. In addition, appended to the
+DAd Special A USA infini itters to the copin ous. Badly dad a dial
+14. Special Agent doin Koychndo
+Agent Richards and Kuyrkendall are referenced in certain letters to Mr. Edwards. DE 14.
+Moreover, Epstein's counsel, Jack Goldberger, Esq. is copied on letters to Mi. Edwards. 1 also
+note that the Supplemental Declaration of c
+(DE 35) notes the existence of a
+September 2007 Non-Prosecution Agreement, an October 2007 Addendum and a letter dated
+December 19, 2007 from the U.S. Attorney to Attorney Lilly Ann Sanchez, Counsel to Jeffrey
+Epstein (DE 35 at 93).'
+I assume those involved in the above-referenced litigation, have copies of the relevant court
+filings, but if you desire any of the unsealed filings, let me know.
+
+
+Re: Jane Does #I and #2 |. United States
+November 2, 2010
+Page -3-
+Privileged Communication
+Included in this preservation order are all Documents and data, including electronically
+stored information ("ESI"), relating to the claims. The Victim's Petition alleges that in July
+2008, negotiations were taking place that led to a Non-Prosecution Agreement. However, it
+appears from AUSA
+1 Declaration that during the summer of 2007, negotiations
+between Epstein and the USAO-SDFLA commenced that led to the September 2007 Non-
+Prosecution Agreement. It would therefore appear that the logical time frame to preserve
+evidence is at least May 1, 2007 and/or as early as the commencement of the negotiations
+Leading to the September 2007 Non-Prosecution Agreement and through the present.
+"Documents and data" as used herein means not only paper copies of documents, but
+electronically stored information ("EST"), to include email, audio recordings, videotape, instant
+messages, word processing files, spreadsheets, databases, calendars, telephone logs, contact
+manager information, Internet usage files, and all other electronically stored information
+maintained, created, and/or received by the USAO-SDFLA or any of its employees and/or
+"Sources" include all paper documents, computer hard drives and other electronic
+storage media (e.g., CDs/DVDs, thumb drives, etc.), laptop computers, PDAs, Blackberry
+devices, and any other location where paper documents or electronic data is stored. Sources of
+potentially relevant information may also include personal computers or personal email accounts
+you use or have access to at home, or anywhere else. Also, relevant electronic data may be
+located on inaccessible storage media, such as backup tapes, which must he preserved as well, if
+an identical copy is not found elsewhere.
+In order to comply with its legal obligations, the USAO-SDFLA must immediately
+preserve all existing documents and data relevant to the claim/investigation described above and
+suspend deletion, overwriting, or any other possible destruction of unique, potentially relevant
+information. Effective immediately, all routine destruction efforts under USAO-SDFLA's
+existing document management and email policies are suspended for all information relevant to
+the above-referenced lawsuit.
+Guidance on how to preserve relevant documents and data should be directed to Jacquie
+Varela, IT-Manager at Jacquie. Varelat usdoi got on whom I am copying this letter. If you have
+any questions on how to comply with this directive, please contact Jacquie at extension 9218.
+Electronically stored information is an important and irreplaceable source of discovery
+and/or evidence in this matter. You must take every reasonable step to preserve this information
+until further notice. Failure to do so could result in severe penalties against the USAO-SDFLA
+and you. Intentional destruction or deletion of any document or data relevant to the lawsuit will
+not be tolerated by the USAO-SDELA and could expose you to criminal sanctions,
+I will contact those of you with more detailed information on the claims to ensure that I
+have the names of all relevant individuais for the Litigation Hold. In addition, in accordance
+with DOJ guidelines, you will be contacted in the future for an update on your preservation
+efforts and to answer any questions you may have. In the interim, if this correspondence is
+unclear, please contact me at extension 9290, for any assistance you may require.
+In accordance with Department of Justice guidelines, please sign and date a copy of
+this letter in the space provided below as an acknowledgment that you have received, read.
+
+
+Re: Jane Does #1 and #2 L. United States
+November 2, 2010
+Page -4-
+Privileged Communication
+and agree to comply with the preservation instructions contained in this letter. Please also
+complete, date and sign the attached form (Note - for your convenience, I have made sure
+that you can type in the date and click in any relevant boxes). I request that you return to
+me the originals containing vour signatures by November 9, 2010. If you wish, you can also
+send to me scanned copies of your letters.
+Should you have any questions, please feel free contact me.
+Regards,
+WIFREDO A. FERRER
+UNITED STATES ATTORNEY
+JAW/attachments
+CC:
+Meredith Perreira, Paralegal
+Jacquie Varela, IT Manager, Administrative Division
+Acknowledgment of Receipt of Litigation Hold Letter:
+I acknowledge that I have received and read the Litigation Hold letter dated November 2, 2010
+regarding Jane Does #1 and #2 | United States, Case No.: 08-80736-CIV-MARRA/Johnson and I have
+taken and agree to continue to take all reasonable steps necessary to preserve the documents and data as
+instructed in the letter and Form appended thereto.
+Dated: the lothday of November, 2010
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/37c72396b23314f63c2259963e0069d9527ccd33c25440d59cc72623fb3fa794.receipt.json b/vision-fixhub/ds9-unparsed-06/37c72396b23314f63c2259963e0069d9527ccd33c25440d59cc72623fb3fa794.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..386f6d94183a4f3ebf867a076f9f5008b3c4bf17
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/37c72396b23314f63c2259963e0069d9527ccd33c25440d59cc72623fb3fa794.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -133,
+  "dataset": "marble-joined",
+  "doc_id": "37c72396b23314f63c2259963e0069d9527ccd33c25440d59cc72623fb3fa794",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "1ac27bd8b6bd4dc12588410fac8df01b462fae37b7300aedce89ab6fa0ef73b9",
+  "output_sha256": "3484602f0d6d16cc4311649b2786ea1f7638b08545d4008ee864e17f07fa8857",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/382300d18154c34f882f56df4e1956958983262d0af6ceb59888a34dab6fa526.md b/vision-fixhub/ds9-unparsed-06/382300d18154c34f882f56df4e1956958983262d0af6ceb59888a34dab6fa526.md
new file mode 100644
index 0000000000000000000000000000000000000000..06c4bcb6ff77a736eb4c181d7dfc842d9f8ef21a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/382300d18154c34f882f56df4e1956958983262d0af6ceb59888a34dab6fa526.md
@@ -0,0 +1,46 @@
+From:
+To:
+Cc: "
+Subject: RE: Jane Does I. U.S. (re Jeffrey Epstein) - Litigation Hold
+Date: Tue, 16 Nov 2010 20:38:05 +0000
+Importance: Normal
+Attachments: 20101117044620.pdf; 20101117044557.pdf
+- I have attached the two signed documents for your files. I have a series of large stored e-mail backup
+files but when I tried to access some of them a few months ago when this first started heating back up, they were
+empty. I mentioned it to Ricky Vidarte but then 1 got busy with something else. Some of those items were also
+pdf"d and burned to CD or put on the main server, so all may not be lost, but IT may have to do some digging.
+When I sent you the bunch of names earlier I forgot to include the following:
+Myesha Braden (attorney at CEOS in DC)
+Gerald Lefcourt (counsel for Epstein)
+(victim coordinator at FBI in West Palm Beach)
+Thank you.
+<<20101117044620.pdf>>
+<<20101117044557.pdf>>
+0
+From:
+Sent: Tuesdav November 1162010 2-091 PM
+Subject: Jane Does |. U.S. (re Jeffrey Epstein) - Litigation Hold
+Importance: High
+This email is a follow-up to my communication of Nov. 2 regarding a Litigation Hold in the above-referenced
+case. Please read and acknowledge your receipt and agreement to the terms of the attached letter. Kindly
+complete and sign the form accompanying the letter
+Please return the originals of both documents to me at your earliest convenience.
+
+
+Thanks very much.
+From:
+Sent: Tuesday, November 02, 2010 5:48 PM
+Tour
+CC:
+Subject: Jane Does. U.S. (re Jeffrey Epstein) - Litigation Hold
+Importance: High
+« File: Re.Jeffrey Epstein.Jane Does I. U.S. - 11.2.2010 JAW Lit Hold Ltr to Individual in USAO.SD.Fla.pdf >> «<
+File: Re.Jeffrey Epstein.Jane Does |. U.S. - Typable 3-13.300.003 Attachment.1.pdf >>
+As a follow-up to your recent meeting concerning the above-referenced case, I write this letter in my capacity as
+the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the
+Southern District of Florida (USAO-SDFLA) to advise you of the USAO-SDFLA's legal obligation to preserve
+documents and data relevant to the lawsuit and to enlist your assistance in this regard.
+I request that you please read and acknowledge your receipt and agreement to the terms of this letter. I also
+ask that you please complete and sign the form accompanying this letter. Please return the originals of both
+documents to me by November 9, 2010.
+Should you have any questions, please let me know.
diff --git a/vision-fixhub/ds9-unparsed-06/382300d18154c34f882f56df4e1956958983262d0af6ceb59888a34dab6fa526.receipt.json b/vision-fixhub/ds9-unparsed-06/382300d18154c34f882f56df4e1956958983262d0af6ceb59888a34dab6fa526.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a3bb3cca82e6eb04786b0c806cbc112837946caf
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/382300d18154c34f882f56df4e1956958983262d0af6ceb59888a34dab6fa526.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "382300d18154c34f882f56df4e1956958983262d0af6ceb59888a34dab6fa526",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "4fcc8077081341b52bc006b004ba5dd53f1cdc572e694238cf6ab23280e32454",
+  "output_sha256": "051f4d370fc13046614cb1d87148ad26bbdcadd43f0789658ba7d46e9c68e18f",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3934cce5acb172644b4d25af00be2acd061b2640bbf980a10a43cbf73ba5f1f7.md b/vision-fixhub/ds9-unparsed-06/3934cce5acb172644b4d25af00be2acd061b2640bbf980a10a43cbf73ba5f1f7.md
new file mode 100644
index 0000000000000000000000000000000000000000..7c1de28dffa2adf2844df620700d8181b4e528ae
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3934cce5acb172644b4d25af00be2acd061b2640bbf980a10a43cbf73ba5f1f7.md
@@ -0,0 +1,18741 @@
+Statement dater
+
+May 11 - June 10, 2004
+Your Monthly Account Statement
+
+Customer Care
+Please call: 1-800-639-6111
+Web site: www.nextel.com
+Account Summary
+For Your Records
+Amount Paid
+Approved
+Previous balance
+Payments as of 06/13/04
+Outstanding balance
+New charges
+Total Amount Due
+Please pay immediately upon receipt
+$1,377.08
+$1,377.08
+1,089.48
+$2,466.56
+Summary of New Charges
+Adlecomts actions servither charges
+Nextel Direct Connect®
+Account takes, eas and assessments
+Account Level Equpment Charges
+Thie Party Sarges Custment and Taxes
+Total New Charges
+Nextel News: Please see the next page for important updates about your Nextel service.
+740.43
+142.34
+12.10
+0.30
+180.66
+$1,075.83
+13.65
+0000
+$1,089.48
+Norto annunications
+Denver, CO 80217-0990
+MANIFESTLINE-
+F55555444422CF
+Rea detect it paro an en it you paymen the enclosed envelope.
+Account name SUNSHINE SVCS UNLIMI
+Total amount due $2,466.56
+Statement date 74ne 15, 2004
+Due date
+Upon Receipt
+Amount paid
+Make checks payable to:
+Nextel Communications
+ONLY OR CHANCE BLING ADORES OCE
+Check here and complete the information on the reverse side.
+Mail Payment To:
+NEXTEL COMMUNICATIONS
+CarOl Stream, IL 60197-4191
+F601974191110F
+747607414 000108948 0001377080 0002466562
+
+
+May 11 - June 10, 2004
+A Guide to Your Monthly Nextel Statement
+Your Monthly Nextel Account Statement is organized into the following sections:
+Your Monthly Account Statement
+Your Nextel Account Summary
+Your Nextel Retail Stores - Charges &
+Services
+Nextel Direct Connect® Summary
+Additional Account Information
+Detail of Access and Usage by User
+number. It also provides the user's adjustments to new charges, access charges and
+breaks out usage by product or feature, such as Telecommunications Services,
+Messaging, Nextel Online® and third party charges, Nextel Direct Connecte and
+associated Taxes, fees and assessments.
+This section itemizes activities at your local Nextel Retail Stores that were charged to
+your existing Nextel account. The total from this page is reflected on your summary of
+new charges as Nextel Retail Stores Charges.
+Refer to this section for information on Nextel Direct Connect®,
+Nationwide Direct Connect(TM), and Nextel Group Connect(TM)
+including billable Group Connect(TM) call duration and usage.
+Depending on the activity in your account, this section includes summary information
+about payments, taxes, adjustments, and Nextel equipment and third party charges
+billed at the account level.
+Refer to this section for information on monthly adjustments, access and other charges.
+In addition, this section includes call detail, usage and associated Taxes, fees and
+assessments. Details about charges made for third party products are also contained
+in this section.
+Please fill out this form to pay your Nextel account balance using a credit card this month,
+or to change your billing address.
+Credit Card and Bank Account Payment
+Name (as it appears on the card)
+If you would like to pay by credit card or
+automatically debit your bank account on an
+Type of card (check one)
+• MasterCard
+American Express
+ongoing basis, please call Customer Care at
+Account Number
+1-800-639-6111 or dial 611 from your Nextel
+phone, for additional information.
+Credit Card Billing Zip Code
+Expiration date
+Amount $
+Month Year
+Change of Billing Address
+Email (Optional):
+Nextel may contact you regarding new
+offerings or promotions.
+Signature
+Company Name
+Contact Name
+Street Address.
+City.
+Phone (
+State
+Zip
+
+
+
+, 1. 3010.2020
+3
+4
+May 11 - June 10, 2004
+Nextel News continued...
+Your past due balance is payable immediately.
+Cross borders at the push of a button. Try International
+Direct Connect between the U.S. and Canada, Peru, Brazil,
+or Argentina for free until July 1, 2004! You automatically
+have access now. Beginning July 1, International Direct
+Connect calls use the Direct Connect minutes in your plan
+and incur an additional charge of $0.20/minute rounded to
+the second. Or pay a $5 monthly fee and only $0.10/minute
+rounded to the second. As with all Direct Connect services.
+International Direct Connect calls are charged to the call
+initiator and per-minute charges are multiplied by the
+number of participants on the call.
+Effective with your July invoice, the Nextel Service Plan,
+currently $2.50 per phone per month, will increase to $2.99
+per phone per month for each phone on your account.
+Remember! With the Nextel Service Plan, if your phone is
+repairable, it's covered at no additional charge at over
+1,300 Service & Repair locations nationwide. For
+additional information, call 1-800-724-9351 or visit
+Nextel.com/support and click on 'Service & Repair.
+GET THE i530 FOR JUST $74,99!! For a limited time, get the
+compact i530 phone for just $74.99, after $50 mail-in
+rebate, when you sign a two-year service agreement. The
+GPS-enabled i530 offers a durable flip design.
+speakerphone, 600-entry contact manager, and more.
+Hurry!! Call 1-800-569-1240 today!!! $50 mail-in rebate
+expires June 30, 2004. While supplies last. Requires twoyear service agreement. Allow 10-12 weeks after phone
+purchase, activation, mailing in of a complete and valid
+rebate form to receive rebate. One rebate per phone
+purchase. May not be available in all markets. Full terms
+and conditions on mail-in rebate form. Set up fee of $35
+per phone, up to $70 max per account (some markets a
+max of $B/account per order) applies. Shipping charge of
+$8.50 per phone ($12.00 in some markets) on up to 10
+Now you can report problems with your network service, such
+as dropped calls, inability to place or receive calls, or
+poor call quality. Go to www.nextel.com/support and look
+for the link called 'Report a Problem with Your Network
+Service' - anytime, day or night.
+30% SMALLER. 100%NEXTEL. Introducing the new, ultra-compact
+i830 phone. At only 3.6 ounces, this pocket-size powerhouse
+comes loaded with great features like Direct Connect(TM).
+65K color display, speakerphone, GPS capability, voiceactivated dialing and more! Right now, each i830 you add
+to your account is only $299.99 when you sign a two-year
+service agreement. Hurry!! Call 1-800-754-6615 TODAY and
+Nextel News continued...
+save!! While supplies last. Requires 2-year service
+agreement, new activation and credit approval. $200 early
+termination fee applies, after 15-day trial period
+(conditions apply). Set up fee of $35 per phone, up to $70
+max per account applies.
+SPECIAL TALK & TEXT OFFER! Stay connected in more ways
+with the coast-lo-coast walkie-talkie and Two-Way
+Messaging. Talk & Text packages start at $10 per month and
+include Unlimited Natiomvide Direct Connect(SM) access and
+Two-Way Messaging capability. Sign up now and get one
+month FREE, plus 100 BONUS anytime cellular minutes per
+month for 12 months! For more details and to add Talk &
+Text to your rate plan, visit wwww.nextel.com/talkandtext.
+contact your sales representative, or call 800-NEXTEL6.
+Please send all correspondence including billing inquiries
+to the below address. Please do not enclose vour payment
+with the correspondence.
+Nextel Communications
+PO Box 17990
+Denver, CO 80217-099C
+You may also contact Nextel Customer Care at 1-800-639-6111
+or by going to the following web site: www.nextel.com.
+'RECEIVE DRAMATIC DISCOUNTS** Subscribe to US Airways
+veekly E-Savers for last minute travel and other low fare
+promotions to selected cities in Europe, Canada, the
+Caribbean and within the United States. It's easy, and it's
+free. Enroll today at usairways.com/esavers.
+Do you have surplus inactive Nextel phones? Visit
+rextelbuyback.com to either donate surplus inactive phones
+or get a credit on your account for all eligible phones
+All Donations go to American Red Cross Armed Services
+Emergency Fund. Customers without Web Access may call the
+Buyback Support Line at 866-364-5680 for program
+'REFER SOMEONE TO NEXTEL AND EARN UP TO $250** With the
+Nextel Referral Rewards Program, you can get a $25 Referral
+Rewards card, redeemable anywhere VISA(R) debit cards are
+accepted (up to $250 per year), for each associate, friend
+and family member you refer to Nextel. And once they
+activate a new Nextel account, they I receive a $25
+invoice credit. Visit nextel.com/referral for full details.
+Referral Offer ends December 31. 2004. Referral rewards
+may be applied to the first ten qualified new accounts you
+efer tv December 31. 2004
+
+
+6
+Number of units in your account:
+Number
+of units
+Rate Plan Airtime Usage Summary
+The information in this grid is provided for each unit in the Detail of Access and Usage by User.
+Number
+Rate Plan
+of calls
+Total
+Min: Sec
+*Rate Plan " Other
+Billable
+Min:Sec
+Min:Sec Min:Sec
+Rate Charges
+Other Usage Charges
+Cal Forwarding
+Peak
+2:00
+2:00
+0.20
+0.40
+May 11 - June 10, 2004
+Rate Plan Airtime Usage Summary continued...
+Number
+of units
+Number
+Rate Plan
+of calls
+Total
+Min: Sec
+*Rate Plan
+Min: Sec
+" Other
+Min: Sec
+Billable
+Min: Sec
+Nextel National Shared 500
+Cellular Usage
+Peak
+Off Peak
+Neel Direct Connecte
+Peak
+Off Peak
+National Shared Value 500
+Coluter Usage
+Peak
+Off Peak
+Neel Direct Connect
+Peak
+Off Peak
+National Unlimited NDC Plus
+Cellar Usage
+Peak
+Off Peak
+Nextel Direct Cornecto
+Peak
+Off Peak
+Nextel Noel Free incoming 1000
+Nestel Direct Cornedo
+Peak
+Off Peak
+Nextel National Shared UDC
+Celular Usage
+Peak
+OM Peer
+Nestel Direct Cornedo
+Peak
+Off Peak
+National Free Incoming 600
+Celular Usage
+Peak Ineoming
+OM Peak Incoming
+Peak Culpoing
+Off Peek Ourgoing
+Nestel Direst Comecto
+Peak
+Off Posi
+541
+162
+660.50
+171:55
+660-5€
+171+55
+Rate
+Total
+Charges
+D.0D
+1.40
+0.40
+0.19
+0.15
+4.35
+0.40
+0.40
+B.DD
+0.D0
+54.90
+45.04
+D.0D
+6.00
+contiued...
+
+
+7
+May 11 - June 10,2004
+Rate Plan Airtime Usage Summary continued.
+Number
+of units
+Number
+Rate Plan
+of calls
+Total
+Min: Sec
+* Rate Plan
+Min: Sec
+"Other
+Billable
+Min: Sec Min:Sec
+Local instant Cormeet 1000
+Celular Usage
+Peak
+Off Peak
+Nextel Direct Connecte
+Peak
+Off Peak
+631:00
+131:00
+631:00
+731:00
+107
+145:32
+30:58
+145:32
+90-58
+Total Usage Charges
+Rate Plan Min:Sec includes rate plan and bonus minutes seconds usel
+• Other Min See includes free incoming minutes seconds used
+Summary of Shared Usage Adjustments*
+Telecom Shared Usage Adi
+Total Shared Usage Adjustments
+*This GRID reflects your savings for the billing period by using Shared Usage Price Plans. The actua/
+adjustments appear with the subscriber details.
+Total
+Rate Charges
+8112.28
+-$23.B8
+-$23.88
+8
+Statement date June 15, 2004
+May 11
+- June 10, 2004
+Nextel Direct Connect® Summary
+Nextel Direct Connect® Network Summary
+Network # 158*24
+Network # 159'26
+Network # 159*61
+Total Nextel Direct Connect® Charges
+12.10
+$12.10
+Network # 158°24
+Usage Charges
+Nextel Direct Connect®
+Nextel Group Connect(TM)
+Nationwide Direct Connect(TM)
+Total Usage Charges
+Total Charges for Network #
+158+24
+The Nextel Direct Connect@ minutes: seconds included in your rate
+plan are applied as you make Nextel Direct Connect®, Nextel Group
+Connect and International Direct ConnectSM) calls during the
+billing period. See Detail of Access and Usage by User for
+individual charges and minutes used.
+Nextel Direct Connect® Usage
+lumbe
+• Unite Rate Plar
+1
+Nestel Natonal Shared 500
+Peak
+Off Peak
+National Shared Value 500
+Peak
+Off Peak
+1 National Unlimted NOC Plus
+Peak
+Off Peak
+1 Nestel Naional Shared UDC
+Peak
+Off Peak
+Local Instant Connect 1000
+Peak
+Off Peak
+Min: Sec Less Min:Sec Less Other
+Used
+in Plan
+Min: Sec
+Billable
+Min: Sec
+250:37
+92-14
+250:37
+92:14
+
+107.59
+173/23
+78:37
+49:54
+29123
+783:32
+163:33
+793:32
+163:33
+220:05
+60:18
+220:05
+60:18
+
+90,58
+145:32
+90,58
+TOTAL
+11.87
+0.23
+$12.20
+$12.10
+Rato
+0.15
+0-00
+0-00
+Total
+Usage
+7.4
+4.43
+$11.07
+continued..
+
+
+1.20 10.01
+9
+Network #159*26
+Usage Charges
+Nextel Direct Connect®
+Nextel Group Connect(TM)
+Total Usage Charges
+Total Charges for Network #
+159*26
+The Nextel Direct Connect® minutes: seconds included in your rate
+lan are applied as you make Nextel Direct Connecte, Nextel Group
+Connect and International Direct Connect(SM) calls during the
+billing period. See Detail of Access and Usage by User fo
+dividual charges and minutes used
+Nextel Direct Connect® Usage
+Bill abl
+Min: Se
+Rato
+1 National Free Incoming 800
+Peak
+Off Peak
+660:50
+171:55
+TOTAL
+Network #159*61
+10
+0.000
+May 11 - June 10, 2004
+Network # 159*61
+Nextel Direct Connect® Usage
+Nuts Rato Pran
+Off Peak
+2124
+Billable
+in Plan
+Min: Sec
+Min: Sec
+2128
+TOTAL
+Rate
+Trage
+€6D:50
+171:55
+Usage Charges
+Nextel Direct Connect®
+Nextel Group Connect(TM)
+Total Usage Charges
+Total Charges for Network #
+159*61
+The Nextel Direct Connect® minutes: seconds included in your rate
+pian are applied as you make Nextel Direct Connect®, Nextel Group
+Connect and International Direct Connect(SM) calls during the
+billing period. See Detail of Access and Usage by User for
+individual charges and minutes used.
+Nextel Direct Connect® Usage
+Mutts Roco Pian
+1 National Unlimited NDC Plus
+Peak
+1 Nestel Nat Free Incoming 1000
+Peak
+Bill able
+Min Sec
+Rate
+24:45
+24-46
+14:16
+14:16
+cortinued...
+80.00
+
+
+Statement date June 15, 2004
+May 11 - June 10, 2004
+11
+Additional Account Information
+Payments to Previous Balance
+Date Received
+Total Payments to Previous Balance
+Misc. Additional Charge Summary
+Charge
+• Urits
+Late Payment
+Total Misc. Additional Charges
+Account Taxes, Fees and Assessments
+Rate
+Total Account Taxes, Fees and Assessments
+Adjustments to New Charges Summary
+Date
+Total Adjustments to New Charges
+Account Level Equipment Charges Summary
+Total Equipment Due
+Detail of Access and Usage by User
+Amount
+Amount
+13.65
+$13.65
+Amount
+Amours
+(561) 662-3098
+Adjustments, Access and Other Charges
+Local Instant Connect 1000 for 06/11-07/10
+Two-Way Messaging Premier for 05/12-06/10
+Two-Way Messaging Premier for 06/11-07/10
+Total Adjustments, Access and Other Charges
+59.99
+7.30
+$74.74
+ou are charged on a pro-rated basis when you sign up for service, or whe
+ou add to or remove units from a rate plar
+Telecommunications Services Charges (561) 662-3098
+Call Forwarding
+Long Distance
+Total Telecommunications Services
+Messaging Charges
+Short Message Service
+0.40
+2.80
+$3.20
+0.30
+cortinues..
+12
+Statement date June 15, 2004
+May 11 - June 10, 2004
+SUNSHINE SVCS UNLIMITED (561) 662-3098 continued...
+Messaging Charges
+Total Messaging Charges
+Nextel Direct Connect® - Number 158*24*31584
+Nextel Direct Connecto
+Nextel Group Connect(TM)
+Nationwide Direct Connect(TM)
+Total Nextel Direct Connect®
+Unit Taxes, Fees and Assessments
+Federal-Excise Tax
+• Federal-TRS Charge
+• Federal-Univ Serv Assessment
+State-Comm Service Tax
+County-Comm Service Tax
+3.000₴
+0.073%
+1.087%
+9.170%
+5.7208
+• Federal-Programs Cost Recovery
+County-911 Taxes
+Total Unit Taxes, Fees and Assessments
+* Fees Nextel elects to collect to recover its costs of funding
+and complying with Government mandates and initiatives.
+Total Nextel Charges for SUNSHINE SVCS
+UNLIMITED
+Rate Plan Airtime Usage Detail
+Date or Service
+Number
+of calls
+Total
+Min: Sec
+Rate Plan
+Min:Sec
+Other
+Min: Sec
+Billable
+Min: Sec
+Rate
+Cal Forwarding
+2:00
+2:00
+0.20
+Celular Usage
+Peak
+OF Peak
+Nestel Direct Cornedt
+Peak
+Of Peak
+Toted Usage Charges
+327
+346
+631,00
+731,00
+631,00
+731,00
+107
+36
+145:32
+90:58
+145:32
+90:58
+$0.30
+0.23
+$0.23
+1.98
+0.05
+0.72
+7.34
+4.62
+1.55
+0.50
+$16.76
+$95.23
+Total
+Charges
+0.40
+0.DD
+$0.40
+
+
+13
+Statement date June 15, 2004
+May 11 - June 10, 2004
+SUNSHINE SVCS UNLIMITED (561) 662-3098 continued....
+Telecommunications Services Call Detail (561) 662-3098
+See
+Footnote
+Item # Date Time
+Call To
+1 May 12 09,59 PM DIR 2687
+2 May 13 07:05 PM I PALA BCH, PL
+3 Jun 05 12:26 EN DIR N68T
+TOTAL MIN: SEC FOR CHARGED CALLS
+TOTAL MIN:SEC FOR UNCHARGED CALLS
+TOTAL
+Number
+411
+561-714-2981
+411
+Min: Sec
+1:00
+OP/FU
+2:00
+5,00
+1375:00
+Usage
+0.40
+$0.40
+80.00
+$0.40
+Long
+Distance
+1.40
+1.40
+$2.80
+$0.60
+$2.80
+Total
+Charges
+1.40
+0.40
+1.4°
+83.20
+80.00
+$3.20
+Footnote
+Features
+CV/Call Waiting
+CF-Call Forwarding
+DS-Dialup Service
+Networks
+africas
+NN-National Network
+CN-Canadian Network
+VW-Neel Worldwide Pf-Partial Free
+WD-Warldwide Discount FC-Free Call
+TJ-Tisina Network
+Time Period
+PP. Peak Period
+MP-Muliple Period
+Messaging Charges
+Text and Numeric Paging Detail
+Service Type
+Number
+of Pages
+Less Pages
+in Plan
+Less Othe
+Pages
+Billable
+Pages
+Rate
+Short Message Service
+Peak
+2
+0.15
+TOTAL
+Additional Messaging Detail
+Number of
+Number of
+Billable
+Initial
+Initial
+Additional Additional
+Messages in
+Messages Messages
+Rate Messages
+Rate
+Messages
+Plan
+Total
+Charges
+0.30
+$0.30
+Total
+Charges
+Service Type
+Two-Way Messaging Usa
+TOTAL
+137
+137
+137
+$0.30
+Total Messaging Charges
+Nationwide Direct Connect(TM) Call Summary 158°24 31584
+TOTAL
+Min: Sec
+2:16
+Total Nationwide
+Direct Connect TM
+$0.23
+Your Rate Plans
+Rate Plan
+Unlimited Night & Wand Minutes
+Caller ID - No Charge
+Browser Wireless Web Services
+Service
+Cellular Minutes
+Caller ID
+Packet Data Service
+PDS Application Datapod
+Packet Data Usage
+PDS Application
+cortinued...
+14
+May 11 - June 10, 2004
+SUNSHINE SVCS UNLIMITED (561) 662-3098 continued...
+Your Rate Plans
+Rate Plan
+Two-Way Messaging Premier
+NOL Web
+Local Instant Connect 1000
+Enhanced VoiceMail Service
+Service
+PDS Application
+Two-Way Messaging Usage
+PDS Application
+Short Message Service
+Operator Assisted Messaging
+Call Detail
+Nextel Group Connect,TM)
+Nextel Direct Connecte
+Direct Connect Cross Fleet
+Short Message Service
+Operator Assisted Messaging
+Cellular Usage
+Domestic Toll
+Cellular Minutes
+VoiceMail
+(561) 662-6616
+Adjustments, Access and Other Charges
+Enhanced VoiceMail Service for 06/11-07/10
+Nextel National Shared 500 for 06/11-07/10
+Nextel Service Plan $2.50 for 06/11-07/10
+Upgrade Handset Admin Fee
+Total Adjustments, Access and Other Charges
+1.00
+59.99
+2.50
+35.00
+$9B.49
+Nextel Direct Connect® - Number 158'24*17984
+Nextel Direct Connect®
+Nextel Group Connect(TM)
+Total Nextel Direct Connect®
+Unit Taxes, Fees and Assessments
+Federal-Excise Tax
+* Federal-TRS Charge
+* Federal-Univ Serv Assessment
+State-Sales Tax
+State-Comm Service Tax
+County-Comm Service Tax
+3.000₺
+0.073%
+1.087%
+6.000₴
+9.170%
+5.7208
+* Federal-Programs Cost Recovery
+County-911 Taxes
+Total Unit Taxes, Fees and Assessments
+2000
+1.89
+0.04
+0.69
+2.25
+5.73
+3.58
+1.55
+0.50
+$16.23
+continued
+
+
+15
+Statement date June 15, 2004
+May 11 - June 10, 2004
+B (561) 662-6616 continued....
+* Fees Nextel elects to collect to recover its costs of funding
+and complying with Government mandates and initiatives.
+Total Nextel Charges for B
+$114.72
+Rate Plan Airtime Usage Detail
+Date of Service
+Mastel National Shared 500
+05/11/04 - 05/10/04
+Celular Usage
+Peak
+Off Peak.
+Nestel Dined Cornecto
+202
+125
+Peak
+Off Peak
+Total Usage Charges
+Number
+Total
+of calls
+Min: Sec
+Rate Plan
+Min: Sec
+Other
+Min: Sec
+Billable
+Min: Sec
+Rate
+Total
+Charges
+273-41
+158.00
+273:41
+158:29
+250:37
+92:14
+250:37
+6.00
+92:14
+80.00
+Telecommunications Services Call Detail (561) 662-6616
+Item # Date Time Call To
+TOTAL MIN:SEC FOR CHARGED CALLS
+TOTAL MIN: BEC FOR UNCHARGED CALLS
+TOTAL
+See
+Number
+Footnote
+Min: Sec
+6:00
+431:43
+433-49
+Usage
+Long
+Distance
+80.00
+$0.c0
+Total
+Charges
+80.c0
+Footnote
+Features
+i-Call Forwardi-
+3W-Three Way Call
+DS-Dialup Service
+Networks
+Time Period
+Your Rate Plans
+Rate Plan
+Neatel National Shared 500
+Service
+Cal Detail
+Call Forwarding
+Caller ID
+Nextel Group Connect(TM)
+Nextel Direct Connecte
+Domestie LD Rate 50
+Direct Connect Cross Fleet
+Shared Cellular Minutes
+Celular Usage
+Domestic Toll
+Nextel Service Plan $2.50
+Text & Numeric Paging
+Short Message Service
+Operator Assisted Messaging
+cortiued.
+May 11 - June 10, 2004
+16
+B (561) 662-6616 continued...
+Your Rate Plans
+Rate Plan
+Enhanced VoiceMail Service
+Service
+VoiceMail
+(561) 662-6688
+Adjustments, Access and Other Charges
+National Unlimited NDC Plus for 06/11-07/10
+199.99
+Total Adjustments, Access and Other Charges
+$199.99
+Telecommunications Services Charges (561) 662-6688
+Long Distance
+Total Telecommunications Services
+37.80
+$37.80
+Nextel Direct Connect - Number 158*24*57985
+Nextel Direct Connect®
+Nextel Group Connect(TM)
+Total Nextel Direct Connect®
+Unit Taxes, Fees and Assessments
+Federal-Excise Tax
+* Federal-TRS Charge
+• Federal-Univ Serv Assessment
+State-Comm Service Tax
+County-Comm Service Tax
+* Federal-Programs Cost Recovery
+County-911 Taxes
+Total Unit Taxes, Fees and Assessments
+3.0008
+0.0738
+1.087%
+9.170%
+5.7208
+7.29
+0.15
+2.65
+21.95
+13.69
+1.55
+0.50
+$47.78
+Total Nextel Charges for C
+$285.57
+
+
+17
+May 11 - June 10,2004
+C (561) 662-6688 continued...
+Rate Plan Airtime Usage Detail
+Rate Plan
+Number
+Dates of Service
+of calls
+National Unlimited NDC Plus
+05/11/04 - 0S/10/04
+Calular Usage
+Feak
+Off Peak
+1697
+240
+Nendel Dired Connects
+Peak
+Off Peak
+627
+156
+Total Usage Charges
+Total
+Min:Sec
+Rate Plan
+Min:Sec
+Other
+Min: Sec
+4145:00
+610-00
+793,32
+163,33
+Telecommunications Services Call Detail (561) 662-6688
+Item # Date Time
+Call To
+1 May 11 07,35 AM DIR A68T
+Kay
+10:33
+Number
+411
+500
+Footnote
+FP
+Min:Sec
+3:00
+Pay 111
+May 12
+DIR ABST
+DER ASST
+Kay 13 09152
+DIR AEST
+Kay 14
+04 TE
+May 15
+Kay 15
+DER NEST
+May 15 08:36
+DIR NEST
+10 May 17 07:34 AM DIR AE8T
+11
+Kay 19 09:04
+AN DER ABST
+12
+Kay 19 10,35 3M
+DIR NEST
+13
+Kay 17 10:42
+DIR NIST
+14
+Kay
+20
+DIR AB8T
+15
+Kay
+25
+D6:4€
+DER ABST
+18
+May
+17
+Kay 27
+03:4E
+DIR AGAT
+18
+Kay
+DER ABST
+19
+Jun
+01
+08,17
+DIR AGAT
+20
+Jun.
+DIR NET
+21
+Jun.
+02l
+09:41
+DIR ABST
+22
+Jun
+DER ABST
+23
+Jun
+04
+12,37
+DIR NEST
+24
+Jun
+12,09 PM
+DIR NIST
+25
+Jun 07 09:39 AM
+DIR ABST
+26
+Jun 09 09,51 AM DIR A68T
+27
+Jun. 10
+DE:10
+AN DIR NEST
+TrOO
+2:00
+4rGO
+411
+2:00
+3:00
+4:00
+2:00
+4:00
+1:00
+2:00
+4:00
+2:00
+5,00
+4:00
+411
+411
+411
+411
+411
+4÷00
+3:00
+2:00
+2:00
+3:00
+Billable
+Min: Sec
+Rate
+4145:00
+610.00
+793,32
+
+Usage
+Long
+Distance
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1,40
+1.00
+1.40
+1.40
+1.40
+1.40
+continues.
+Total
+Charges
+50.00
+Total
+Charges
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+18
+May 11 - June 10, 2004
+C (561) 662-6688 continued..
+Telecommunications Services Call Detail (561) 662-6688
+Item # Date Time CallTo
+TOTAL MIN: SEC FOR CHARGED CALLS
+TOTAL MIN:SEC FOR UNCHARGED CALLS
+Number
+See
+Footnote Min: Sec
+54,00
+4661:00
+4755:00
+Usage
+80.00
+80.00
+Footnote
+Features
+CW-Call Wating
+CF-Call Forwarding
+W-Three Way Cal
+S-Dialup Servic
+Networks
+Services
+NN-National Network
+W-Nectel Worldwide
+WD-Worldwide Discount FC-Free Call
+TJ-Tyuana Network
+Your Rate Plans
+Rate Plan
+National Unlimited NDC Plus
+NOL Full Service Package
+Long
+Distance
+837.80
+86.00
+837.80
+Total
+Charges
+837.80
+80.00
+839.00
+Time Period
+PP.Peak Period
+OP-Off Peak Period
+MP-Mutiple Period
+Service
+Packet Data Service
+Call Detail
+Caller ID
+Nextel Group Connect(TM)
+Nextel Direct Connecte
+Domestic LD Rate $0
+Direct Connect Cross Fleet
+Cellular Usage
+Nationwide Direct Connect(TM)
+Packet Data Usage
+VoiceMail
+PDS Application
+Shared Text Messaging
+Short Message Service
+Operator Assisted Messaging
+Two-Way Messaging Usage
+(561) 662-6813
+Adjustments, Access and Other Charges
+Nextel National Shared UDC for 06/11-07/10
+Total Adjustments, Access and Other Charges
+Telecommunications Services Charges (561) 662-6813
+Telecom Shared Usage Ad
+Cellular Usage
+Long Distance
+Total Telecommunications Services
+39.99
+$39.99
+-23.98
+100.02
+2.80
+$78.94
+Nextel Direct Connect® - Number 158'24'37983
+Nextel Direct Connecte
+continued.
+
+
+19
+tatement date June 15, 200
+illing period May 11 - June 10, 200
+Миту 17-2010.200
+A (561) 662-6813 continued...
+Nextel Direct Connect® - Number 158*24 37983
+Nextel Group Connect(TM)
+Total Nextel Direct Connect®
+Unit Taxes, Fees and Assessments
+Federal-Excise Tax
+* Federal-TRS Charge
+• Federal-Univ Serv Assessment
+State-Comm Service Tax
+County-Comm Service Tax
+* Federal-Programs Cost Recovery
+County-911 Taxes
+3.0008
+0.0738
+1.087%
+9.170₴
+5.7208
+3.67
+0.03
+1.34
+11.05
+6.89
+1.55
+0.50
+Total Unit Taxes, Fees and Assessments
+• Fees Nextel elects to collect to recover its costs of funding
+and complying with Government mandates and initiatives.
+Total Nextel Charges for A
+$25.03
+$143.96
+Rate Plan Airtime Usage Detail
+Rate Plan
+Dates of Service
+Number
+of calls
+Total
+Min: Sec
+Rate Plan
+Min: Sec
+Other
+Min: Sec
+Billable
+Min: Sec
+Rate
+Total
+Charges
+Nestel National Shared UDC
+05/11/04 - 05/10/04
+Cellular Usage
+Peak
+Off Peak
+Nesdel Direct Connects
+Peak
+Off Peak
+Total Usage Charges
+115
+45
+156:57
+124:39
+156:57
+128:39
+54.98
+45.04
+210
+57
+220:05
+60: 18
+220:05
+6D: 18
+$100.02
+Telecommunications Services Call Detail (561) 662-6813
+See
+Footnote
+Item # Date Time
+Call To
+1 Kay 11 D6:50 AN Inconleg
+2 Kay 11 08:51 2М Inconleg
+3 Kay 12 08,02 AN Incorleg
+4 May 11 09:44 JM Incoming
+5 Kay 11 03:50 IM Inconleg
+§ May 11 03:52 PM Inconieg
+7 Kay 11 03:53 EN Inconleg
+8 KaY 12 D6:43 AM BOTTONECTE, PL.
+9 May 12 06:48 2M BOYTONBCH, PL
+10 Kay 12 DE:58 AN BOTTONACH, FL
+Number
+561-503-8429 08/NN
+561-503-8429 PP
+561-503-8429
+PP
+Min: Sec
+1:00
+Usage
+Long
+Distance
+1:18
+1:00
+0.46
+561-503-5930 PP
+561-827-2542
+1:00
+1:23
+0.48
+561-827-2542
+561-827-2542
+561-503-8429
+561-503-8429 OP
+561-503-8429
+OP
+1:00
+1:00
+1:00
+1,00
+1:00
+$.35
+0.00|
+0,00
+D.D0
+Total
+Charges
+0.46
+0.48
+d.35
+contirued...
+May 11 - June 10, 2004
+A (561) 662-6813 continued...
+Telecommunications Services Call Detail (561) 662-6813
+See
+Number
+Footnote
+Item # Date Time
+Call To
+11 May 12 07:02 AM BOXTONBCH, PL
+12 Kay 12 11:47 AM Incoming
+13 Kay 12 11:48 AM Inconing
+14 May 12 12:58 FM N PALA BCH, PL
+15 Kay 12 12:59 IM N BALE BCH, PL
+16 Kay 12 03:27 IM BOCA RATCH, PL
+17 Kay 12 03:30 PM BOCA RATON, PL
+18 May 12 03131 EM BOCA RATON, PL
+19 Kay 13 06:57 AM Inconlag
+20 Kay 13 03:33 PM BOYTONBCH, PL
+21 May 14 11123 AM N PACH BCH, PL
+22 кау 14 11:31 ли востовоси, пс
+23 Kay 14 11:32 AM Incoming
+24 Kay 14 11:33 AM Inconing
+25 May 14 12:57 PM Inconing
+20 Kay 14 01:07 m BOTONICH, PL
+27 Kay 14 03:22 IN
+Incoming
+28
+May 14 04:49 PM
+Inconing
+29 May 14 05:02 IN Inconing
+30 Kay 14 06:08 IM N PALA BCH, PL
+31 Kay 15 06:51 1M Inconing
+32 May 15 07.12 AM Inconing
+33 кну 15 07:33 ли вогтоваси, кс
+34 Kay 15 03:43 IM Inconing
+35 May 15 05:00 IM Inconing
+36 May 15 07:29 PM Incondng
+37 Kay 15 08:49 IM Inconing
+38 Kay 16 02:34 PM N PALE BCH, PL
+30 Kay 17 06.29 AM BOYTONCH, PL
+40 May 17 06:31 AM % FALL NCH, PL
+41 Kay 17 10:07 AM BOYTONECH, PL
+42 Kay 17 11:53 MM Inconing
+43 May 17 03,31 PM BOYTONCH, PO
+44 Kay 17 03:60 PM N FALL BCH, PL
+45 May 17 05:34 PM BOTONBCH, PL
+48 May 18 07:03 AM Inconing
+47 Кну 18 10:04 ЛМ N FAL RCH ,PL
+48 Kay 18 05:29 I Incoming
+49 May 18 07:34 PM N PALE BCH, PL
+50 May 18 07:46 EM W PALM BCH, PL
+51Ииу 18 07:67 PM 1 FALE NCH, PL
+Min: Sec
+561-503-9429 PP
+561-503-8429 PP
+561-502-7753 FF/CH
+561-357-5751 PP
+561-714-0244 FD
+561-393-7914 PP
+561-393-7914 FP
+561-393-7914 PP
+561-503-8429
+OE
+561-503-3429
+FF
+561-357-5751
+PP
+561-303-8429
+561-503-8429 PP
+561-357-5751 PB/CH
+561-503-5930
+561-503-5930
+561-357-5751
+561-303-5930
+561-714-0244
+PP
+561-503-2429
+561-964-5511 OP
+561-303-3930 CE
+561-503-5930
+561-503-5930
+561-712-9018
+561-503-8429
+561-714-0244
+561-503-9429
+561-712-2018
+561-503-8429
+PP
+561-503-9429
+pP
+561-503-4429
+FP
+561-503-8429
+361-357-3751
+FF
+561-968-2024
+PP
+561-502-5236 PP
+561-502-5236 PP
+561-302-3236 FF
+Usage
+1100
+1:00
+2:53
+1,00
+2:24
+2:37
+1:00
+1132
+1:00
+1100
+1112
+1:00
+1:00
+1,00
+1,19
+2,06
+1:00
+1:50
+1:00
+1,00
+1:00
+1:00
+1:00
+1,00
+2:41
+1:01
+1,00
+1:02
+1:00
+2:04
+1,00
+1:10
+1:45
+1,00
+2:39
+1:00
+1:00
+1,00
+1:00
+1.01
+0.84
+0.92
+0.5+
+0.42
+0.46
+0.95
+0.94
+0.36
+0.36
+0,72
+0.41
+0.61
+0.93
+20
+Long
+Distance
+0.0D
+0.0D
+Total
+Charges
+1.01
+0.84
+0.92
+0.54
+0.+2
+0.+6
+0,00
+0,00
+0-O0
+0.94
+0.36
+0.36
+0,72
+0.41
+0.61
+0.93
+
+
+21
+May 11 - June 10, 2004
+A (561) 662-6813 continued...
+Telecommunications Services Call Detail (561) 662-6813
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+52 May 19 09:44 PM M BALA BCH, FL
+561-502-7249 FP
+1:00
+53 May 14 08:45 PM M PALA BCH, PL
+561-502-7249
+1:02
+54 May 14 09:08 PM I PALA BCH, PL
+561-502-7249
+OP
+1:00
+55 May 19 10/11 IN M PALA BCH, PL
+561-502-7249
+1117
+55 May 18 10:12 IN M PALE BCH, FL
+561-502-5236
+OP
+1:22
+57 May 14 10:42 PM W PALA BCH, PL
+561-502-7249
+1:00
+58 May 19 12:42 3M N BALK BCH, PL
+561-502-7249
+OP
+1:00
+50 May 19 12:43 3M M BALK BCH, FL
+561-502-7249 OP
+1,00
+60 May 19 D8:13 AN DIR NEST
+411
+1:36
+81 May 19 11:54 AM VERO BEACH, PL
+772-713-7015
+PP
+2124
+82 May 19 02/06 EM Inconing
+772-713-7015
+FP
+1:00
+83 May 17 03:53 PM M PALE BCE, VL.
+561-686-4622
+1:06
+64 May 19 06:25 PM W DALK BCH, PL
+561-324-1491
+1:05
+85 May 19 07:05 PM M BALE BCH, PL
+561-662-6688
+1:12
+08 May 19 07/06 EM BOYTONECH, FL.
+561-508-5980
+PP
+1143
+87 May 19 07:15 m Inconleg
+563-324-1493
+1:00
+68 May 19 07:27 PM M PALK BCH, PL
+561-624-1441
+1:00
+80 May 19 08:07 IN M BALA BCH, PL
+561-540-0978
+1:00
+70
+Kay 20 09:52 AM M PALE BCH, FL
+71 Kay 20 10:16 AM M PALA BCH, PL
+72
+Kay 20 12:11 AM M BALK BCH, PL
+73 May 20 11:23 AM M BALK BCH, PL
+74 Kay 20 11:57 AN M PALE BCH, FL
+75
+Kay 20 01:30 PM M PALK BCH, PL
+76
+Kay 20 04:05 EM Toll Pree
+77
+Kay 20 04:48 PM M BALK BCH, PL
+78 Kay 20 06:36 PM M PALK BCH, PL
+561-686-4622
+561-686-4622
+561-686-4622
+5E1-EBG-4622
+561-686-4622
+800-248-2846
+561-686-4622
+561-686-4622
+PP
+FP
+PP
+79 Kay 20 06:37 PM M BALE BCH, PL
+561-324-1491
+80 May 21 07,48 AN M BALA BCH, PL
+561-502-5212
+FP
+FP
+81 May 21 09:50 AM M BALAC BCTE, FL
+561-686-4622
+1:00
+1:00
+1:00
+1:53
+1:00
+1:08
+1,00
+1:00
+1:00
+1:00
+1:23
+82 Kay 21 01:30 PM M DALK BCH, PL
+561-827-2542
+1:00
+83 May 21 01:42 PM Inconleg
+1:00
+84 May 21 02,19 PM M BALA BCH, PL
+561-324-14911
+PP
+1,00
+85 May 21 06:58 mN Inconleg
+563-503-5930
+85 May 21 07:36 FM W BALE BCH, PL
+PP
+87 May 21 09.50 EN WBALK BCH,PL
+85 Kay 21 D8:51 MN M PALK BCH, PL
+89 Kay 21 08:52 PM M PALE BCH,PL
+90 Kay 21 09:03 PM M BALE BCH, PL
+91 May 21 09,19 PM W BALA BCH, PL
+561-301-0203
+561-301-0203
+561-478-8280
+561-502-5236
+561-502-5236
+561-478-8280
+FF
+OP
+OP
+OF
+1:00
+1: 00
+2:22
+1:00
+1:00
+1:00
+Usage
+0.36
+0.45
+0.48
+6.35
+0.55
+0.84
+0.39
+0.38
+6.42
+0.60
+$.35
+$.40
+0.48
+0.39
+1,90
+0.83
+Long
+Distance
+D.D0
+1.40
+D.D0
+D.D0
+0,00
+D.00
+0000
+D.00
+D.D0
+Total
+Charges
+9.35
+0.36
+0.45
+0.48
+1.95
+0.84
+0.33
+0.38
+0.42
+0.60
+0.40
+0.48
+0.39
+1.90
+0.83
+May 11 - June 10, 2004
+A (561) 662-6813 continued...
+Telecommunications Services Call Detail (561) 662-6813
+See
+Item # Date
+Time
+Call To
+Number
+Footnote
+Min: Sec
+93 May 21 09:40 EM MPALM BCH, PL
+561-301-02030P
+1100
+94 Kay 21 09:43 IM N PALA BCH, PL
+561-301-020300
+1:00
+85 Kay 21 09:46 PM NPALE BCH, PL
+561-649-3913 OF
+1:00
+96 May 2109:48 FM PALA BCH, PL
+561-649-3913 OP
+8,32
+97 Kay 22 08:08 a Inconing
+561-303-3930 CE
+1:17
+98 Kay 22 12:32 IN N PALA BCH, PL
+561-324-1491 00
+1:01
+90 Kay 22 02:05 PM BOYTONBCH, PL
+561-503-5930
+1:00
+100 May 22 03,39 FM I PALA BCH,PL
+561-662-6648
+OP
+1113
+101 Kay 22 04:00 I Inconing
+561-324-1491
+DE
+1:00
+102 Kay 22 05:25 PM Inconing
+561-324-3491
+OF
+1114
+103 May 22 06,36 FM W PALA BCH, PL
+561-502-5212
+1,00
+104 ay 22 06:38 m Inconing
+361-302-1212 0B
+1:00
+100 Kay 22 06:40 I Incoming
+561-502-5212 00
+1:00
+108 Kay 22 07:24 PM N PALE BCH, PL
+561-324-3491
+1:00
+107 May 22 07:42 EM Incondng
+561-324-1491
+1,00
+108 Kay 22 08:63 PM N FAL2 BCH,L
+561-502-5236
+1:00
+109 Kay 22 08:45 IM N PALA BCH, PL
+561-502-5236
+1:00
+110 May 22 09:46 EM N PALM BCH, PL
+561-502-7249
+1,00
+111 Kay 22 08:55 PM Inconing
+361-302-323€
+112 Kay 22 09:31 IN Incoming
+561-502-7249
+113 Kay 23 01:42 AM Inconing
+561-324-3491
+ce
+114 May 23 09123 EM N PALM BCH, PL
+561-707-6448
+115 Kay 23 08:23 PM N FALE RCH, PL
+561-707-6884 DE
+116 Kay 23 68:24 IM N PALA BCH, PL
+561-707-6884
+117 Kay 23 08:26 PM N PALE BCH, PL
+561-707-6448
+118 May 23 09:45 EM N PALM BCH, PL
+561-707-6448
+119 Kay 23 08:45 IM N PALA BCH, PL
+561-707-6448
+120 Kay 23 04:46 1
+N PALE RCH, PL
+121 May 24 09:06 AM
+Inconing
+122 Kay 24 10:02 AM 7 BALA NCH, PL
+123 Kay 24 12:28 IN N PALA BCH, PL
+1:38
+124 Kay 24 12:46 IM Inconing
+561-707-6448
+561-964-3228
+561-EBC-4622
+561-666-4622
+561-684-4623
+1:00
+1:00
+1,00
+1:00
+1:00
+15:00
+1,00
+1:00
+12:02
+1,00
+1:00
+1:00
+125 May 24 12:48 PM NPALM BCH,PL
+126 Kay 24 12:50 m
+Inconing
+127 Kay 24 03:03
+IN W PALE BCH, PL
+128 May 24 04:20 EM W PALM BCH, PL
+129 Kay 24 10:00 PM N FACE ACH, PL
+130 Kay 24 10:02 IN N PALA BCH, PL.
+131 May 24
+10:09 IM N PALA BCH, PL
+132 May 24 10:10
+W PALM BCH,PL
+133 Иму 24 10:12
+I N FALA RCH, PL
+561-686-4622
+561-324-1491
+561-315-4028
+FF
+561-666-4623
+361-302-3216
+561-502-4279
+561-502-5234 CE
+561-502-4279 CP
+561-302-7249 CE
+1,00
+1:00
+1:00
+1,66
+1:00
+1:00
+1:00
+1,44
+1:00
+Usage
+2.99
+0.45
+0.36
+0.+3
+0.43
+0.95
+5.25
+4.21
+0.57
+0.61
+22
+Long
+Distance
+0.0D
+0.0D
+0.0D
+Total
+Charges
+2.99
+0.45
+0.36
+0.+3
+0.43
+0,00
+0,00
+0-O0
+5.25
+4.21
+0.57
+0,35
+0.61
+0.61
+
+
+23
+
+May 11 - June 10, 2004
+A (561) 662-6813 continued...
+Telecommunications Services Call Detail (561) 662-6813
+See
+Item # Date Time
+Call To
+Number
+Footnote
+134 Kay 24 10,15 IN M BALK BCH, FL
+561-502-5236 OP
+135 Kay 24 10:39 PM I PALA BCH, PL
+561-502-5236
+136 Kay 24 12:19 PM I PALE BCH, PL
+561-502-5236
+OP
+137 May 24 11,37 PM I PALA BCH, PL
+561-502-5236
+OP
+138 кау 25 12:12 ЛМ M PAL BCH, VL.
+561-502-5236
+OP
+139 Kay 25 12:12 AM W PALK BCH, PL
+561-502-4279
+140 Kay 25 12:13 AM M BALK BCH, PL
+561-502-7249
+OP
+141 May 25 12:14 AM M BALK BCH, FL
+561-502-5236 OP
+142 Kay 25 12:17 AL DIR NEST
+411
+OF
+143 Kay 25 12:22 AM M BALK BCH, PL
+561-502-5236
+OP
+144 Kay 25 12126 AM M PALA BCH, FL
+561-502-5239
+OP
+145 кку 23 12:27 ЛИ М ВАШК ВСТ, FL
+561-502-5236
+145 Kay 25 12:29 2M N PALK BCH, PL
+561-502-5236
+OP
+147 Kay 25 12:41 AN M BALK BCH, PL
+561-502-5236
+OP
+148 Kay 25 12:43 AM M BALK BCH, FL
+561-502-5236
+149 кку 23
+12:4E 38 M PALE BCH, PL
+150 Kay
+25 12:47 AM M PALK BCH, PL
+561-50207244
+151 May
+25 12,49 AM M BALK BCH, PL
+5614502-5288
+152 ay
+25 12:51 AM M PALK BCH, FL
+153 Kay
+AM I PALM BCH, PL
+561-502-5236
+154 Kay
+03:03 A M PALE BCH, PL
+561-502-5236
+OP
+155 May 25 01/06 AM I BALK BCH, PL
+561-502-5236
+OP
+156 Kay 25 01:08 AM M PALE BCH, FL.
+561-502-5236
+OP
+157 Kay 25 01:09 AM I PALK BCH, PL
+561-502-5236
+OP
+158 Kay 25 02:09 AM M BALE BCH, PL
+561-502-5236
+OP
+159 May 25 01,25 3 M BAI BCH, PL
+561-502-5236
+OP
+180 Kay 25 10:49 IN M PALK BCH, PL
+561-686-4622
+161 Kay 25 02:15 PM M BALK BCH, PL
+561-324-1491
+FP
+182 Kay 25 04.36 PM W BALK BCH, FL
+561-686-4622
+FP
+163 Kay 25 05:35 PM M PALAC BC, FL
+561-324-1491
+154 Kay 25 05:46 IN Inconieg
+561-502-5236
+165 Kay 25 07:28 IM Inconteg
+100 May 26 12,12 AM Inconleg
+561-502-5236
+OP
+187 Kay 26 05:01 AM M PALAC RCH, FL
+165 Kay 27 08:32 AN I BALK BCH, PL
+100 May 27 09,59 M Inconing
+561-502-5123
+170 Kay 27 10:00 A M PAIL BCH, FL
+561-502-5213
+FF
+171 Kay 27 10:02 AM Incoming
+561-686-4623
+172 Kay 27 02:52 PM M PALE BCN, PL
+561-686-4622
+FP
+173 May 27 04,34 IN M BALK BCH, FL
+561-686-4622
+FP
+174 Kay 27 05:09 PM M PALE BCH, PL
+561-EBE-4622
+FF
+Min: Sec
+Usage
+1,36
+1:00
+1:00
+1:00
+1:00
+1:00
+1:21
+1,00
+1:00
+1:00
+1:00
+1:22
+3:40
+1:00
+3,10
+1:02
+1:25
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1:02
+1:00
+1:06
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1: 00
+3:29
+2:07
+1:00
+1:00
+$.56
+6.47
+8.35
+0.48
+1.28
+6.35
+1.11
+0.36
+$.50
+0.55
+$.35
+6.35
+0.36
+0.39
+6.35
+1.21
+•.74
+Long
+Distance
+D.D0
+1.40
+D.D0
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+cortinued..
+Total
+Charges
+9.56
+0.47
+1.75
+0.48
+1.28
+1.11
+0.36
+0.50
+0.55
+0.36
+0.39
+1.21
+0.74
+24
+May 11 - June 10, 2004
+A (561) 662-6813 continued...
+Telecommunications Services Call Detail (561) 662-6813
+See
+Number
+Footnote
+Item # Date Time
+Call To
+175 May 27 05:10 EM W PALA BCH, PL
+176 Kay 27 05:34 IM N PALA BCH, PL
+177 Jun 02
+02:58 PM W PALE RCH, PL
+178 Jun
+03:00 FM I PALA BCH, PL
+179 Jun 02
+03:33 IN BALANCH, PL
+180 Jun 07 09:13 AM N PALE BCH, PL
+181 Jun 07 12:13 PM Inconing
+182 Jun 07 12:21 EM N PALA BCH ,PL
+183 Jun 07 12:22 IN N FACE RCH, PL
+184 Jun 07 02:14
+IN N PALE BCH ,PL
+185 Jun 07
+05:04
+W PALA BCH.PL
+186 Jun 07
+m Inconing
+187 Jun 08
+09:48 AM W PALA BCH, PL
+188 Jun 08
+11:29 AM Inconing
+189 Jun 08
+01:30 EM
+W PALE BCH,PL
+190 Jun
+08 03:37
+N FALE RICH,PL
+191 Jun
+08 04:54 W
+W PALE BCH ,PL
+192
+Jun
+09
+W PALA BCH,PL
+193
+AMN SALES ACH, PL
+194 Jun
+11:23 |
+AM
+N PALA BCH, PL
+195 Jun 09
+IN N PALE BCH,PL
+196 Jun 09 03:04 PM W PALA BCH, PL
+197 Jun 10 11:36 AM N FALA RCH, PL
+198 Jun 10 11:40 AM W PALA BCH, PL
+190 Jun 10 11:49 1M Inconing
+200 Jun 10 12:03 FM Inconing
+TOTAL MIN:SEC FOR CHARGED CALLS
+TOTAL MIN:SEC FOR UNCHARGED CALLS
+TOTAL
+Min: Sec
+Usage
+Long
+Distance
+561-324-1491
+PP
+561-281-3814P0
+561-541-5449 FF
+561-474-4148 PP
+561-341-3449 FD
+561-798-2719 PP
+561-476-4280
+FF
+561-827-2542
+PP
+561-827-2542
+FF
+561-798-2719
+FF
+561-794-2719
+PP
+361-471-1143
+FF
+561-666-4622
+PP
+561-502-5212
+561-686-4622
+PP
+561-6BE-4622
+1100
+1:37
+1:07
+1,03
+1:28
+1:10
+1:03
+1,00
+1:00
+1100
+8:03
+1:57
+1:07
+1,00
+2141
+1:00
+0.57
+0.39
+0.37
+0.51
+0.41
+0.37
+2.82
+0_68
+0.39
+0.94
+0.0D
+0.0D
+561-666-4622
+PP
+361-E62-8C8E
+561-686-4622
+561-666-4622
+561-686-4622
+PP
+FP
+PP
+561-E83-1100
+561-666-4622
+561-666-4623
+FF
+561-666-4623
+PP
+2,19
+1:05
+1:00
+1132
+1,00
+1:18
+1:00
+1:03
+1,00
+285:36
+9:39
+295,15
+0.81
+0.38
+0.54
+0.4€
+0.95
+0.37
+$100.62
+$100.02
+0.DD
+0.0D
+$2.90
+$2.80
+Footnote
+Features
+Networks
+Services
+Time Period
+CW-Call Wating
+NN-National Network
+AL - Alternate Line
+PP-Peak Period
+CF-Call Forwarding
+CN-Canadian Network
+PU-Plan/Promotional Usage
+OP-Off Peak Period
+3WThree Way Call
+W-Nedel Worldwide
+PF-Partial Fred
+MP-Multiple Period
+DS-Dialup Service
+WD-Worldwide Discount FC-Free Call
+TJ-Tijuana Network
+Total
+Charges
+0.57
+0.39
+0.37
+0.51
+0.41
+0.37
+2.82
+0.68
+0.39
+0.94
+D.4E
+0.81
+0.3e
+0.54
+D.4E
+0.37
+$102.82
+฿102.82
+Your Rate Plans
+Rate Plan
+Caller ID - No Charge
+Service
+Caller ID
+
+
+25
+May 11 - June 10, 2004
+A (561) 662-6813 continued....
+Your Rate Plans
+Rate Plan
+Nextel National Shared UDC
+UNIT 5
+Service
+Cal Detail
+Call Forwarding
+Nextel Group Connect(TM)
+Nextel Direct Connecte
+Domestic LD Rate 50
+Direct Connect Cross Fleet
+Shared Cellular Minutes
+Colular Usage
+Domestic Toll
+(561) 719-9544
+Adjustments, Access and Other Charges
+National Shared Value 500 for 06/11-07/10
+Service Fee for 06/11-07/10
+Total Adjustments, Access and Other Charges
+Nextel Direct Connect® - Number 158°24'20290
+Nextel Direct Connect®
+Nextel Group Connect(TM)
+Total Nextel Direct Connect®
+Unit Taxes, Fees and Assessments
+Federal-Excise Tax
+• Federal-TRS Charge
+• Federal-Univ Serv Assessment
+State-Comm Service Tax
+County-Comm Service Tax
+3.0008
+0.0738
+1.087%
+9.170%
+5.7208
+• Federal-Programs Cost Recovery
+County-911 Taxes
+Total Unit Taxes, Fees and Assessments
+* Fees Nextel elects to collect to recover its costs of funding
+and complying with Government mandates and initiatives.
+Total Nextel Charges for UNIT 5
+41.39
+$51.14
+11.87
+$11.87
+1.62
+0.05
+0.72
+5.92
+3.70
+1.55
+0.50
+$14.06
+$77.07
+continues.
+26
+May 11 - June 10, 2004
+UNIT5 (561) 719-9544 continued...
+Rate Plan Airtime Usage Detail
+Rate Plan
+Number
+Dates of Service
+of calls
+Total
+Min: Sec
+Rate Plan
+Min: Sec
+Other
+Min: Sec
+lational Shared Value 50
+05/1404 - 08/10/04
+Collar Usage
+Peak
+Of Peak
+36
+32
+91:00
+56:00
+91:00
+56:00
+Nextel Direct Connects
+Peak
+Of Peak
+211
+124
+
+107:59
+171/23
+78:37
+Total Usage Charges
+Telecommunications Services Call Detail (561) 719-9544
+Item # Date Time Call To
+TOTAL MIN: SEC FOR CHARGED CALLS
+TOTAL MIN:SEC FOR UNCHARGED CALLS
+TOTAL
+Number
+See
+Footnote Min:Sec
+0:00
+147,00
+147:00
+Footnote
+Features
+CF-Call Forwarding
+3WThree Way Call
+DS-Dialup Service
+WD-Worldwide Discount FC-Free Call
+TJ-Tijuana Network
+Your Rate Plans
+Rate Plan
+100 Cellular Bonus Minutes
+Unlimited Night & Wand Minutes
+Caller ID - No Charge
+National Shared Value 500
+Servico Foo
+Text & Numeric Paging
+Enhanced VoiceMail Service
+Billable
+Min: Sec
+Rate
+Total
+Charges
+2-40
+49:54
+29.23
+0.15
+0.15
+$11.87
+Usage
+50.00
+80.00
+so.e0
+Long
+Distance
+80.00
+86.00
+80.00
+Total
+Charges
+80.00
+80.00
+PP.Peak Period
+MP-Multiple Period
+Service
+Celular Minutes
+Celular Minutes
+Caller ID
+Call Detail
+Nextel Group ConnectTM)
+Nextel Direct Connecte
+Domestic LD Rate S0
+Direct Connect Cross Fleet
+Shared Cellular Minutes
+Shared DC/Group Connect Mins
+Cellular Usag
+Short Message Service
+VoiceMail
+
+
+27
+Statement date June 15, 2004
+Billing period May 11 - June 10, 2004
+(561) 723-1821
+Adjustments, Access and Other Charges
+Direct Protect Insurance for 06/11-07/10
+National Unlimited NDC Plus for 06/11-07/10
+Total Adjustments, Access and Other Charges
+Telecommunications Services Charges (561) 723-1821
+Long Distance
+Total Telecommunications Services
+Nextel Direct Connect® - Number 159°61'18727
+Nextel Direct Connect®
+Nextel Group Connect(TM)
+Total Nextel Direct Connect®
+Unit Taxes, Fees and Assessments
+Federal-Excise Tax
+• Federal-TRS Charge
+• Federal-Univ Serv Assessment
+State-Comm Service Tax
+County-Comm Service Tax
+3.000%
+0.0738
+1.0878
+9.1708
+5.720%
+• Federal-Programs Cost Recovery
+County-911 Taxes
+Total Unit Taxes, Fees and Assessments
+* Fees Nextel elects to collect to recover its costs of funding
+and complying with Government mandates and initiatives.
+Total Nextel Charges for SUNSHINE SVCS
+UNLIMITED
+4.95
+199.99
+$204.94
+19.60
+$19.60
+0.000
+6.73
+0.15
+2.45
+20.28
+12.65
+1.55
+0.50
+$44.31
+$268.85
+28
+May 11 - June 10, 200
+SUNSHINE SVCS UNLIMITED (561) 723-1821 continued..
+Rate Plan Airtime Usage Detail
+Number
+of calls
+Total
+Min:Sec
+Rate Plan
+Min: Sec
+Other
+Min: Sec
+Billable
+Min: Sec
+Rate
+tional Unlimited NDC PI
+1104-06/101
+Collar Usage
+Peak
+Of Peak
+Nexei Direct Connects
+286
+701:00
+10:00
+22
+24:46
+Newtel Direct Cornecte
+Peak
+Of Peak
+Toted Usage Charges
+14:16
+2:28
+Telecommunications Services Call Detail (561) 723-1821
+See
+Number
+Footnote
+Item # Date Time
+Call To
+1 Kay 12 12:53 IM DIR ABST
+2 Kay 14 07:59 MM DIR NUT
+3 May 14 09:04 AM DIR ABST
+4 Nay 14 08.09 AM DIR ASGT
+5 Kay 14 04.10 AM DIR ABET
+• May 14 08.13 2M DIR NEST
+7 Nay 14 09.34 AM DIR NAST
+8 Key 14 08:15 AM DIR ABUT
+• Kay 14 08:19 M DIR NUT
+10 Jun 03 09:26 AM DIR ABET
+11 Jun 04 08/14 AM DIR ASST
+12 Jun 07 07:20 AM DIR ABST
+13 Jun 07 12:17 IN DIR NEST
+14 Jun 09 09:13 AM DIR ASST
+TOTAL MIN:SEC FOR CHARGED CALLS
+TOTAL MIN: SEC FOR UNCHARGED CALLS
+TOTAL
+411
+411
+411
+411
+411
+411/
+PP
+PP
+FF
+PP
+PP
+411
+FP
+411
+PP
+411
+Min: Sec
+4: 00
+4: 00
+4: 00
+2:00
+3: 00
+1:00
+2: 0D
+2:00
+4:00
+5:00
+21 DD
+3:00
+411
+FF
+2:00
+7,00
+45:00
+667,00
+712:00
+Footnote
+101:00
+10:00
+24:46
+14:16
+2:28
+Usage
+0.08
+Long
+Distance
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+s0.00
+1.40
+1.40
+$19.60
+$19.60
+Features
+CW-Cal Wating
+CF-Call Forwarding
+JW-Three Viay Cal
+DS-Dialup Service
+Networks
+Services
+NN-National Network
+AL - Alternate Line
+CN-Canadian Network
+PU-Plan/Promotional Usage
+W-Nectel Workdwide
+Pf-Partial Free
+WD-Worldwide Discount FC-Free Call
+TJ-Tjuana Network
+Time Period
+PP-Peak Period
+OP-OfT Peak Period
+MP-Mutiple Period
+Your Rate Plans
+Rate Plan
+Caller ID - No Charge
+cortinued..
+Total
+Charges
+060-
+฿.0D
+$0-00
+Total
+Charges
+1.40
+1.40
+1.40
+1,40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.40
+1.+0
+1.40
+1.40
+$19.60
+฿19.60
+Service
+Caller ID
+
+
+29
+atement date June 15, 20
+ling peri
+May 11 - June 10, 2004
+SUNSHINE SVCS UNLIMITED (561) 723-1821 continued...
+Your Rate Plans
+Rate Plan
+National Unlimited NOC Plus
+Browser Wireless Web Services
+NOL Full Service Package
+Direct Pratect Insurance
+Text & Numeric Paging
+Nextel Natl Free Incoming 1000
+UNIT 4
+Service
+Packet Data Service
+Cal Detail
+Caller ID
+Nextel Group ConnectTM)
+Nextel Direct Connecte
+Domestic LD Rate $0
+Direct Connect Cross Fleet
+Celular Usage
+Nationwide Direct Connect(TM)
+Packet Data Usage
+VoiceMail
+Packet Data Service
+Packet Data Usage
+PDS Application
+Shared Text Messaging
+Short Message Service
+Operator Assisted Messaging
+Two-Way Messaging Usage
+Direct Protect Insurance Prgm
+Short Message Service
+Operator Assisted Messaging
+Cal Detail
+Nextel Group ConnectTM)
+Nextel Direct Connecte
+Domestic LD Rate S0
+Direct Connect Cross Fleet
+Colular Usage
+Catular Minutes
+VoiceMail
+(561) 723-3440
+Adjustments, Access and Other Charges
+Sarice Fee for 06mi1-0700 for 06/1-07/10
+Total Adjustments, Access and Other Charges
+Telecommunications Services Charges (561) 723-3440
+69.35
+$71.14
+cortinues..
+30
+Statement date June 15, 2004
+May 11 - June 10, 2004
+UNIT 4 (561) 723-3440 continued...
+Telecommunications Services Charges (561) 723-3440
+Long Distance
+Total Telecommunications Services
+Nextel Direct Connect - Number 159*26*4992
+Nextel Direct Connect®
+Nextel Group Connect(TM)
+Total Nextel Direct Connect®
+Unit Taxes, Fees and Assessments
+Federal-Excise Tax
+• Federal-TRS Charge
+• Federal-Univ Serv Assessment
+State-Comm Service Tax
+County-Comm Service Tax
+3.000₴
+0.073%
+1.087%
+9.170%
+5.7208
+• Federal-Programs Cost Recovery
+County-911 Taxes
+Total Unit Taxes, Fees and Assessments
+* Fees Nextel elects to collect to recover its costs of funding
+and complying with Government mandates and initiatives.
+Total Nextel Charges for UNIT 4
+Rate Plan Airtime Usage Detail
+Number
+of calls
+Total
+Min: Sec
+Rate Plan
+Min: Sec
+Other
+Min: Sec
+Billable
+Min:Sec
+Rate
+National Free Inconing 60
+25/1104 - 08/10/04
+Cellar Usage
+Peak incoming
+Of Peak Incoming
+Peak Outacing
+of peak Cursing
+Nentel Direct Cornect
+Peak
+of Pesk
+Told Usage Charges
+128
+S1
+148
+45
+238:00
+112:00
+297,00
+106,00
+239:00
+112,00
+297,00
+106,00
+0.40
+0.40
+541
+162
+660:50
+171:55
+660:50
+171:55
+2.80
+$2.80
+2.30
+0.05
+0.84
+6.93
+4.32
+1.55
+0.50
+$16.49
+$90.43
+Total
+Charges
+
+
+31
+June 15,2004
+May 11 - June 10, 2004
+UNIT 4 (561) 723-3440 continued...
+Telecommunications Services Call Detail (561) 723-3440
+Item # Date Time
+Call To
+1 May 25 07,42 AM DIR NEST
+2 Kay 27 02:59 PM DER A687
+TOTAL MIN:SEC FOR CHARGED CALLS
+TOTAL MIN: SEC FOR UNCHARGED CALLS
+TOTAL
+Number
+411
+Footnote
+FP/FU
+VP/PU
+7,00
+2:00
+Usage
+•.00
+Long
+Distance
+1.40
+1.40
+Total
+Charges
+1.40
+1.40
+$2.80
+MP Muliple Period
+ND-Warldwide Discount FC-Free Call
+TJ-Tuana Network
+Your Rate Plans
+Rate Plan
+Browser Wireless Web Services
+Two-Way Messaging Express
+Service
+Packet Data Service
+Packet Data Usage
+PDS Application
+Two-Way Messaging Usage
+Service Foo
+Text & Numeric Paging
+National Free incoming 800
+Enhanced VoiceMail Service
+Short Message Service
+Operator Assisted Messaging
+Cal Detail
+Caller ID
+Nextel Group Connect(TM)
+Nextel Direct Connecte
+Domestic LD Rate SO
+Direct Connect Cross Fleet
+Colular Usage
+Cellular Minutes
+VoiceMail
+
+
+May 11 - June 10, 2004
+Cellular Airtime Usage Summary
+The minutes displayed in this grid are for reference only. Always refer to the Detail of Access and Usage by user sections for full
+unit detai.
+User Name / DAC
+в
+UNIT 4
+UNIT 5
+Totals
+Number /
+Plan Minutes!
+Total Min Used /
+Pooling group
+Additional Min Used! Billable Min Used
+Total Plan Min
+Per Min Rate
+and Additional Min
+Used
+Billable Usage Charges /
+Shared Usage Adjustments /
+Total Usage Charges
+561-662-6616
+CSG7
+500:00
+131:49
+561-662-668B
+561-723-3440
+600:00
+351:00
+754: 00
+561-662-3098
+561-719-9544
+CDC1
+1000:00
+731:00
+1362:00
+50D: 0a
+56:00
+147:00
+561-723-1821
+551-162-6813
+3600 г00
+1138:00
+2694:49
+131:49
+4755:00
+4755:00
+754:00
+0.40
+1362:00
+0.40
+147:00
+0.40
+711:00
+721:00
+285: 31
+285:34
+446: 2
+151:3
+N/A
+50.00
+50.00
+50.00
+50.00
+50.00
+50.00
+50.00
+50.00
+s0.0a
+30.00
+30.00
+$100.02
+- $23.88
+$76.14
+$100.02
+-$23.88
+$76.14
+May 11 - June 10, 2004
+Detail of Access and Usage by User
+(561) 662-3098
+Telecommunications Services Call Detail (561) 662-3098
+See
+Number
+Footnote
+Min: Sec
+Item # Date Time
+Call To
+1 Kay 11 03:07 m Inconing
+2 Kay 11 04:00 IN N PALA BCH, PL.
+3 Kay 11 04:02 PM N PALA BCH, PL
+4 Kay 11 04:08 PM Inconing
+5 Kay 11 04:44 IM A PAIN BCH, PL
+6 Kay 11 04:51 PM NFALE BCH, PL
+7 May 11 04.5G FM Inconing
+Ma 1109:10400,0
+• May 11 05:20 IM N PAL BCH, PL
+10 Kay 11 05:25 PM BOYTONECH, PL
+11 May 11 05127 PM NPACH BCH, PL
+12
+Kay
+11
+05:28 M
+Inconing
+13 Kay 11 05:42
+BOYTONECH, PL
+14 May 11 05:53 PM
+Inconing
+15 Кау 11
+05:53
+Inconing
+16
+Kay
+11
+06:34
+BOYTONBCH ,PL
+17 Kay 11
+06:38
+N PALE BCH, PL
+May
+11
+07:44
+Inconing
+19 Kay 12 10:05 AM 7 FALL NCH, PL
+20 Kay 12 10:11 AM N PALA BCH, PL
+21 May 12 10:21 AM W PALE BCH ,PL
+22кау 12 12:53 PM N FAL/ BCH, PL
+23 Kay 12 02:40 IM N PALA BCH, PL
+24 May 12 02:41 PM N BALE BCH, PL
+25 May 12 02:42 FM I PALA BCH, PL
+26 Kay 12 02:42 PM N FALE BCH, PL
+27 Kay 12 63:01
+IM N PALA BCH, PL
+28 Kay 12 05:00 PM I PALE BCH,PL
+29 Kay 12 05:52 IM Inconing
+30 Kay 12 06:02 IM Incoring
+31 Kay 12 06:03 IM N PALE BCH, PL
+32 May 12 06:43 #M Inconing
+33 Kay 12 06:45 m Inconleg
+34 May 12 07:47 I Inconing
+35 Kay 12 07:59 PM Inconing
+38 May 12 09.14 PM N PALM BCH, PL
+37 Kay 12 09:20 IN N PALM BCH, PL
+38 Кау 12 10:00|
+I Custorer Care
+39 Na 13 11:35 AM N PALM BCH, PL
+561-478-4188 FF/FU
+561-602-1095 PD/PU
+561-762-3545 PP/PU
+561-309-5958 PD/PU
+561-343-6763 FP/FU
+561-383-6763 PP/PU
+561-432-2930 PD/PU
+561-577-4997 FP/PU
+561-714-2941
+PP/PU
+561-714-2981
+PP/CN/PU
+561-573-4997
+pP /FU
+561-714-2941
+561-377-4997
+PP /PU
+FF /pU
+561-577-4709
+PP /PU
+561-714-2981
+PP /FU
+561-762-1545
+PP/PU
+561-714-2981 FF/FU
+561-714-2981 PD/PU
+561-714-2941 PP/PU
+561-254-2023 FD/FU
+561-309-5958 PD/PU
+561-309-5954 PP/PU
+561-309-5959 PP/PU
+561-714-2981 FD/FU
+561-309-5958 P0/PU
+561-329-4070 PP/PU
+561-329-8070 FF/FU
+561-790-3459 PD/PU
+561-601-3439 FF/FU
+561-306-6037
+PP/PU
+561-30E-6037
+SE /FU
+561-714-2981
+PD /PU
+561-309-5958 FP/FU
+561-601-3439 08/PU
+561-601-3439 0P/PU
+611
+ce/Pc
+561-383-6763 PP/PU
+1:00
+1:00
+4:00
+5: 0D
+1:00
+1:00
+2:00
+1:00
+2:00
+3,00
+2:00
+3:00
+1,00
+1:00
+2:00
+2:00
+2:00
+1:00
+1:00
+1,00
+3: 00
+1:00
+1:00
+1,00
+3: 00
+1:00
+1:00
+2:00
+1:00
+3:00
+2,00
+1:0D
+2:00
+2:00
+2:00
+1:00
+2,00
+Usage
+0_00
+Long
+Distance
+D. DD
+0.0D
+0.0D
+0.0D
+0-00
+Total
+Charges
+0.UU
+0.00|
+0,00
+
+
+May 11 - June 10, 2004
+(561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Item # Date Time
+Call To
+Number
+Footnote
+40 May 13 11147 AM I BALK BCH, FL
+561-383-6763
+PP/FU
+41 May 13 12:11 PM N PALA BCH, PL
+561-714-2981
+VP/PU
+42 May 13 02:56 IN M PALE BCH, PL
+561-662-3098
+FP/FU
+43 May 13 02,55 PM Inconing
+561-714-2981
+PP/FU
+44 May 13 03:01 IN M PALE BCE, FL
+561-478-4188
+PP/BU
+45 May 19 03:03 PM W PALA BCH, PL
+561-317-2434 P9/90
+45 May 13 03:06 PM INcOMiNg
+561-317-2434
+FP/FU
+47 May 13 03:12 PM Incoming
+561-317-2434 FP/FU
+45 Kay 13 03:17 IN Incoalag
+561-317-2434
+FP/BU
+40 May 13 03127 PM Inconieg
+561-714-2981
+PP/PU
+50 May 13 03:44 EM M BALA BCH, FL
+561-317-2434
+FP/PU
+51 May 13 03:48 PM M PALE BCE, VL.
+561-432-2930
+P/SU
+52 May 19 03:54 PM Incoming
+561-432-2930
+IР/P0 1
+53
+May 13 05:24 PM M BALK BCH, PL
+561-432-2930
+IPP/NEN/FU
+54 May 13 05,25 EM M BALA BCH, FL
+561-432-2930
+PP/NN/FU
+55 May 13 05:27 IN M PALE BCH, FL
+561-432-2930
+PP/N9/FU
+55 May 13 05:34 IM Incoming
+561-432-2930
+V/P0
+57
+May 13 06,33 PM I BALA BCH, FL
+561-562-109%
+PP/FU
+55 May 13 07:44 m IncoRleg
+59 Kay 13 07:50 IM Incoming
+561-309-5958
+60
+May 13 08:32 PM M BALK BCH, PL
+561-324-7931
+FP/FU
+81
+May 13 08,33 PM M BALK BCH, PL
+561-329-8070
+RP/PU
+82 Kay 13 D8:42 IN M PALE BCH, FL
+561-795-9876
+SP/SU
+63 May 13 08:42 I Incoming
+561-324-7931
+10/8U
+84 May 13 09:38 PM Incoming
+561-329-8070
+OP/FU
+85 May 13 10:05 PM M BAIR BCH, FL
+561-329-8070
+OP/FU
+05 Кау 13 10:07 IM И РАЦИ ВСН, PL
+561-329-8070
+OP/PU
+87 Kay 13 10:07 PM M BALE BCH, PL
+561-329-8070
+OP/PU
+65 May 13 10,23 IN M BALA BCH, PL
+561-329-8070
+OP/PU
+09 May 1] 10:31 m INcoRleg
+561-329-8070
+OP/SU
+70 Kay 19 10:45 IM BOYTONBCH, PL
+561-577-4990
+0P/9U
+71 May 13 10:46 PM M PALE BCH, PL
+OP/FU
+72 May 13 10,54 PM M BALA BCH, PL
+561-329-8070
+OP/PU
+73
+KAy 13 10155 PM BOONCH, PL
+561-577-4990
+OP /FU
+74
+PAY 13 11192 I RESOLET
+561-329-8070
+OP/FU
+75
+May 14 10,32 AM Inconing
+561-714-2981
+FP/PU
+76 way 1410:45 A Inconleg
+561-827-3822
+FP/BU
+77
+Kay 14 10:46 AM M PALK BCH, PL
+561-309-5958
+May 14 10:47 AM M PALE BCH, PL
+561-383-6763
+PP/FU
+79 May 14 10:48 AM Inconing
+561-383-6763
+FP/FU
+B0 MAy 14 11:11 A M FALK BCH, FL.
+561-827-3822|
+Min: Sec
+Usage
+2100
+2:00
+1:00
+CEOU
+1:00
+5:00
+2:00
+SLUU
+6:00
+4:00
+5:00
+1:00
+1:00
+1:00
+TrOO
+2: 00
+1:00
+4:00
+3:00
+1,00
+1:00
+2:00
+1:00
+1:00
+1:00
+1:00
+1,00
+1:00
+1:00
+2400
+1: 00
+1:00
+1:00
+1:00
+1:00
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+6.00
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+
+May 11 - June 10, 2004
+SUNSHINE SVCS UNLIMITED (561) 662-3098 continued....
+Telecommunications Services Call Detail (561) 662-3098
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+81 May 14 11,15 AM Inconing
+82 May 14 12:35 I Inconing
+#3 Kay 14 03:15 PM Inconing
+84 May 14 03116 IM Inconing
+85 Kay 14 03:23 IM Inconing
+80 May 14 03:53 I Incoming
+87 Kay 14 05:31 PM Inconing
+88
+May 14 05:45 EM Inconing
+89 Kay 14 11:45 PM N FALA BCH, PL
+90 Kay 14 11:47 IN N PALE BCH, PL.
+91 May 15 05:07 FM W PACH BCH, PL
+92 Kay 15 05:34 m Inconing
+93 Kay 15 06:17 I Inconing
+Kay 15 06:23 #M Inconing
+95
+May 15 06.52 EM W PALM BCH, PL
+96
+Kay 15 08:20 I Inconing
+97 Kay 15 09:22 I
+Inconing
+98 May 15 09.24 PM
+Inconing
+90 May 15 08:29 IN SALE BCH, PL
+100 Kay 15 08:30 IM N PALA BCH, PL
+101 Kay 15 09:00 IM Inconing
+102 Kay 15 09:05 EM Inconing
+103 Kay 15 09:07 PM Inconing
+104 Kay 15 10:47 IM N PALA BCH, PL
+106 Kay 15 10:52 IM N FALK BCH, PL
+106 May 16 11:59 AM N PALM BCH, PL
+107 Kay 16 12:00 IM N PALM BCH, PL
+108 Kay 16 12:01 m
+W PALE BCH, PL
+100 May 16 12:03 PM Inconing
+110 Kay 16 01:01 IN X BALAL RCH, PL
+111 Kay 16 04:24 IN N PALA BCH, PL
+112 May 17 05:17 PM N PALE BCH, PL
+113 May 17 09:14 #M Inconing
+114 Kay 18 06:11 10 7 FALA RCH, PL
+115 Kay 18 10:31 AM
+Inconing
+118 May 18 05:23 EM
+Inconing
+117 Kay 18 06:28
+N FALA RCH, PL
+118 Kay 18 07:45 m
+Inconing
+119 Kay 18 07:48
+Inconing
+120 Кау 18 09:15 #М
+121 Kay 18 08:36 PM Inconing
+Min: Sec
+561-714-2941
+PP/PU
+561-432-2930 PD/PU
+561-383-6763 FF/FU
+561-343-6763 PP/PU
+561-714-2981 FD/FU
+561-383-6763 PP/PU
+561-790-3459
+FP /FU
+561-790-3459 PP/PU
+561-714-2981
+DE/FU
+561-317-2434
+Ce /FU
+561-644-1472 0P/PU
+161-687-3992 DB/FU
+561-629-6069 00/PU
+561-687-3992
+DE /FU
+554324-793
+DP/PU
+BOSSE
+449444-142
+561-644-1472
+DP/PU
+561-301-0308
+561-301-0308
+561-644-3472
+ce /FU
+561-644-2472 0P/PU
+561-644-1472 DE/FU
+561-363-6763 00/PU
+561-301-0308 08/PU
+561-309-5958 0P/PU
+561-662-3098
+0P/PU
+561-427-2542
+561-343-6763
+ce /PU
+561-790-3459
+DE /FU
+561-662-3098 00/PU
+561-432-2930
+PF /FU
+561-714-2991
+CP/PU
+561-662-3098
+DE/FU
+817-355-4399
+PP/PU
+561-790-3459 PP/PU
+361-862-3098 FF/FU
+561-686-4123 PD/PU
+561-686-4123 FP/PU
+561-324-7931 PP/PU
+561-714-2981 FF/FU
+Usage
+1100
+2:00
+1:00
+2:00
+1:00
+2:00
+1:00
+2,00
+1:00
+1100
+1,00
+1:00
+1:00
+1:00
+2:00
+2:00
+1:00
+3: 00
+2:00
+1,00
+1:00
+1:00
+1:00
+1,00
+2:00
+2:00
+2,00
+1:00
+1:00
+1:00
+2100
+2:00
+1:00
+2,00
+1:00
+1:00
+1:00
+2,00
+1:00
+9.00
+Long
+Distance
+Total
+Charges
+0.0D
+0.0D
+0.0D
+0.DD
+0,00
+0.OO
+0,00
+
+
+May 11 - June 10, 2004
+(561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Item # Date Time
+Call To
+Number
+Footnote
+122 Kay 19 10,28 IN M BALK BCH, FL
+561-309-5958
+OP/PU
+123 Kay 14 10:29 PM I PALA BCH, PL
+561-309-5958
+OP/PU
+124 May 19 12:00 AM I PALE BCH, PL
+561-329-8070
+FP/FU
+125 May 19 11/08 AM I PALA BCH, PL
+561-329-8070
+FP/FU
+126 кау 17 11:12 ЛМ M PAL BCH, VL.
+561-329-8070
+SP/BU
+127 Kay 19 11:13 AM Incoming
+561-329-8070
+#P/Cw/PU
+126 Kay 19 12:07 PM I PALE BCH, PL
+561-329-8070
+FP/FU
+129 Kay 19 12:08 PM I PALA BCH, FL
+561-329-8070
+FP/FU
+130 Kay 19 12:08 IN Incoaleg
+561-329-8070
+FP /CS/FU
+131 Kay 19 03:34 PM Incoming
+561-841-9956
+PP/PU
+132 May 19 03,56 PM M PALA BCH, FL
+561-662-3098
+FP/PU
+133 May 19 03:44 I IncoRleg
+561-309-5958
+134 Kay 19 04:27 IN Incoming
+561-309-5958
+135 Kay 19 05:02 PM Inconleg
+561-798-5195
+PP/PU
+138 Kay 19 05,39 EM Inconing
+561-798-5195
+PP/FU
+137 KAY 13 DE:DE IN M PALAT RCH, FL.
+561-841-9956
+138 Kay 19 06:30 PM Incoming
+561-714-2981
+V/P0
+139 Kay 19 07,32 EN Inconing
+561-827-2542
+PP/PU
+140 кку
+L7 BE H BECOBLESI
+561-329-8070
+141 Kay 19 07:53 I Incoming
+561-827-2542
+142 Kay
+19 08:36 PM M BALE BCH, PL
+561-667-0332
+FP/FU
+143 Kay 19 08150 PM M BALK BCH, FL
+561-324-7931
+RP/PU
+144 Kay 17 08:5E IN IncoRleg
+561-714-2981
+pP/sU
+145 Kay 19 10:18 DM N PALK BCH, PL
+561-644-1472
+146 Kay 19 10:19 PM Inconleg
+561-644-1472
+OP/PU
+147 May 19 10,38 PM Inconing
+561-644-1472
+OP/FU
+148 Кау 20 07:20 AМ Інсоміву
+561-714-2981
+I9/PU
+149 Kay 20 02:58 PM M BALE BCH, PL
+561-662-3098
+FP/PU
+150 Kay 20 02,59 PM Inconleg
+561-478-4188
+FP/CW/FU
+151 Kay 20 03:22 IN M PALE BCH, FL
+561-790-3459
+FP/BU
+152 Kay 20 03:32 IN BOTTONBCH, PL
+561-577-4709
+19/90
+153 Kay 20 06:34 PM Inconteg
+561-714-2981
+PP/PU
+154 May 20 06,50 PM N BALA BCH,PL
+561-662-3098
+PP/PU
+155 Kay 20 DE:51 PM M PALAC RCH, FL.
+561-714-2001
+FP/SU
+156 Kay 20 06:58 PM I BALK BCH, PL
+FP/FU
+157 May 20 07,57 EM W BALK BCH, FL
+561-714-2981
+FP/PU
+158 May 20 10:10 IN Incaleg
+561-329-8070
+159 Kay 20 10:16 W Incoming
+561-432-2930
+0P/PU
+160 Kay 20 12:28 PM Inconleg
+561-432-2930
+OP/FU
+181 May 21 07,25 M Inconing
+561-714-2981
+FP/FU
+182 Kay 21 11:57 AM Incoalag
+561-309-5958|
+Min: Sec
+Usage
+1:00
+5:00
+1:00
+1:00
+1:00
+1,00
+1:00
+1:00
+2:00
+1:00
+1:00
+1:00
+2:00
+4:00
+2:00
+4:00
+1:00
+2:00
+1:00
+1:00
+1:00
+1,00
+1:00
+2:00
+3:00
+1:00
+1:00
+3:00
+2:00
+2:00
+1:00
+JE0O
+1:00
+1:00
+1:00
+2:00
+•.00
+6.00
+6.00
+0.0D
+•.00
+6.00
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+0000
+D.D0
+D.D0
+0.00|
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+
+May 11 - June 10, 2004
+SUNSHINE SVCS UNLIMITED (561) 662-3098 continued....
+Telecommunications Services Call Detail (561) 662-3098
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+163 May 21 01:04 EM W PALA BCH,PL
+164 Kay 21 01:04 IN N PALM BCH, PL
+165 Kay 21 01:09 PM I PALES BCH, PL
+166 May 21 01/10 FM 1 PALA BCH,PL
+167 Kay 21 01:10 IN 1 BALE BCH, PL
+168 Kay 21 01:10 IN N PALE BCH, PL
+160 Kay 21 01:57 IN N PALE BCH ,PL
+170 May 21 01,59 EM N PALA BCH, PL
+171 Kay 21 02:31 IN N BALE RCH, PL
+172 Kay 21 02:47 PM W FACE BCH, PL
+173 May 21 03:00 PM
+W PALA BCH.PL
+175 Kay 21 06:02 IN N PALA BCH, PL
+176 Kay 21 07:24 PM Inconing
+177 Kay 21 09:48 FM Inconing
+178 Kay 21 08:49 m Inconlng
+179 Kay 21 08:50 W
+Inconing
+180 Kay 21 09.54 FM
+Inconing
+181киу 21 11:07 PM N FALE BICH, PL
+182 Kay 22 09:16 AM Incoming
+183 May 22 09:32 AM N FACE BCH, PL
+184Киу 22 09,36 AM I PALM BCH,PL
+185 кну 22 10:24 10 N RALE всН, PL
+180 Kay 22 10:33 AM Inconing
+187 Kay 22 10:56 AM N BALE BCH, PL
+188 May 22 11:47 AM Incondng
+189 Kay 22 11:48 AM N PALM BCH, PL
+190 Kay 22 04:17 #
+Inconing
+191 May 22 09,14 PM W PALM BCH, PL
+192 Кау 22 08:14 гм
+Inconing
+193 Kay 22 08:24 W
+Inconing
+194 May 22 09:13 PM BOYTONCH, PL
+195 May 22 09,15 EM BOYTONCH, PO
+190 кму 22 09:21 гм
+Inconing
+197 Kay 22 09:46 IN
+Inconing
+198 May 2211:05 EM
+PALA BCH,PL
+190 Kay 22 11:33 PM N FACE RCH, PL
+200 Kay 22 11:41 I
+BOYTONECH, PL
+201 Кау 22 11:42
+Inconing
+202 May 22 11:44 EM Inconing
+303 Kay 23 02:13 PM Inconlng
+Min: Sec
+561-324-7931
+PP/PU
+561-324-7931
+PD/PU
+561-714-2941
+FF/FU
+561-714-2941
+PP/PU
+561-714-2981 FD/FU
+561-714-2981 PD/PU
+561-662-3098
+FP /FU
+561-662-3098
+PP/PU
+561-714-2981
+FE /FU
+561-324-7931
+FF /FU
+561-478-4188
+PP/PU
+561-478-4188
+FD/FU
+561-478-4188
+PD/PU
+561-666-4001
+PF /FU
+561-502-5560
+PP/PU
+FF /FU
+561-502-5560
+PP/PU
+361-329-8070
+561-790-3459
+561-662-3098
+DE/PU
+561-667-5834 0P/PU
+561-309-3958 DE/FU
+561-190-3459 00/PU
+561-790-3459 08/PU
+561-343-6763
+op/PU
+561-790-3459
+CP/PU
+561-343-6763
+ce /PU
+561-343-6763
+561-383-6763
+DE/FU
+561-383-6763
+0P/PU
+561-523-1811
+De /FU
+561-523-1811
+CP/PU
+561-582-9982
+DE/FU
+561-644-2472
+ce/FU
+561-662-3098
+ce/pu
+361-309-5958 DE/FU
+561-573-4990 00/PU
+561-737-3103 C8/PU
+561-737-3103 08/PU
+561-309-3958 DE/FU
+Usage
+1100
+1:00
+1:00
+1,00
+1:00
+1:00
+1:00
+1,00
+1:00
+2:00
+3:00
+2:00
+1:00
+2:00
+1,00
+1:00
+1,00
+1:00
+2:00
+4: 00
+1,00
+2:00
+2:00
+1:00
+1,00
+3: 00
+1:00
+1,00
+4:00
+2:00
+2:00
+5:00
+1:00
+1,00
+2:00
+1:00
+2:00
+1,00
+1:00
+9.00
+0.0C
+Long
+Distance
+Total
+Charges
+0.0D
+0.0D
+0.DD
+0.DD
+0,00
+0-O0
+U .UU
+0.OO
+0,00
+
+
+
+May 11 - June 10, 2004
+(561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Number
+Footnote
+Item # Date Time
+Call To
+204 Kay 23 07,18 IN M BALK BCH, FL
+205 Kay 24 07:12 AM I PALA BCH, PL
+206 Kay 24 03:14 PM I PALE BCH, PL
+207 May 24 04135 EM Inconing
+205 Kay 24 08:35 IN M PALE BCS, PL
+209 Kay 24 08:36 PM I PALA BCH, PL
+210 Kay 24 10:09 PM BOTTONECH, PL.
+211 May 25 07.19 AM M BALA BCH, FL
+Kay 29 07:21 AN M BALA BCH, FL
+213 Kay 25 07:24 AM M PALE BCH, PL
+214 Kay 25 10123 AM M PALA BCH, FL
+215 кку 23 10:35 ЛИ М ВАШК ВСТ, FL.
+216 Kay 25 10:37 2M N PALK BCH, PL
+217 Kay 25 12,12 2Н M BALK BCH, PL
+218 Kay 25 11/12 AM M BALK BCH, FL
+219 кку 23 11:17 ЛИ M FALE ВСП, FL.
+220 Кку 25 11:21 AM M DALK BCH, PL.
+221 Kay 25 11,22 AM M PALA BCH, FL
+222 Kay 29 12:54 m Incoeleg
+223 Kay 25 12:54 IM I PALA BCH, PL
+224 Kay 25 12:55 PM Inconleg
+225 May 25 12,59 EM Inconing
+226 Kay 25 02:54 m Incoalag
+227 Kay 25 03:04 IN Incoming
+228 Kay 25 04:11 PM M PALE BCH, PL
+229 Kay 25 04:12 PM Inconing
+230 Kay 25 04:13 IN 5 PALK BCH, PL
+231 Kay 25 05:02 PM Inconteg
+232 Kay 25 05:08 PM Inconleg
+233 Kay 25 05:17 PM M BALE BCH, FL
+234 Kay 25 05:31 IN Inconieg
+235 Kay 25 05:36 PM M BALE BCH, PL
+236 May 25 06,57 PM N BALA BCH, PL
+237 Kay 25 07:21 PM M PALE RCH, FL
+236 Kay 25 07:22 PM I BALK BCH, PL
+230 May 25 07,23 EM M BALK BCH, FL
+240 Kay 25 07:25 IN M PAIL BCH, FL
+241 Kay 25 07:33 PM M PALK BCH, PL
+242 Kay 25 07:38 PM M PALE BCH, PL
+243 May 25 07:40 EN M BALK BCH, FL
+244 Kay 25 03:00 PM Incoalag
+Min:Sec
+561-309-5958
+OP/PU
+561-714-2981
+VP/PU
+561-644-1472
+FP/FU
+561-644-1472
+PP/FU
+561-662-3098
+PP/BU
+561-714-2981 V9/9U
+561-577-4990
+OP/FU
+561-662-3098 FP/FU
+561-714-2981
+FF /EU
+561-714-2981 PP/FU
+561-662-3098
+FP/PU
+561-644-7226
+FP/sU
+561-644-7226
+19/P0
+561-714-2981
+561-714-2981
+PP/FU
+PP/PU
+S61-74-2003
+FP/FU
+561-624-7451
+561-124-7921
+V/P0
+PP/FU
+561-309-5958
+561-309-5958
+561-689-3223
+561-689-3223
+RP/PU
+561-714-2981 VP/BU
+561-301-0308
+10/8U
+561-352-7000
+FP/FU
+561-352-7000
+PP/CW/FU
+561-714-2981
+I9/PU
+561-714-2981
+FP/PU
+561-835-1973
+FP/PU
+561-714-2981
+FP/BU
+561-686-4123
+#9/90
+561-714-2981
+561-795-9876
+FP/PU
+PP/PU
+563-L62-1094
+FP/SU
+561-667-5834
+FP/FU
+561-835-1973
+FP/PU
+561-667-5834
+FP/BU
+561-762-1585
+561-762-1585
+PP/FU
+561-795-9876 FP/PU
+561-835-1973 0P/SU
+Usage
+1:00
+3:00
+1:00
+1:00
+2:00
+2:00
+1,00
+2:00
+1:00
+1:00
+2:00
+1:00
+1:00
+2:00
+1:00
+1:00
+2:00
+1:00
+1:00
+SIOU
+7:00
+2:00
+1,00
+3:00
+1:00
+9:00
+1:00
+2:00
+1:00
+1,00
+2:00
+1:00
+1: 00
+1:00
+2:00
+1:00
+3:00
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+0.0D
+0.0D
+6.00
+6.00
+0.0D
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+0,00
+D.00
+0000
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+
+May 11 - June 10, 2004
+SUNSHINE SVCS UNLIMITED (561) 662-3098 continued....
+Telecommunications Services Call Detail (561) 662-3098
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+245 May 25 11,36 EM W PALM BCH, PL
+246 Kay 25 11:42 IM N PALA BCH, PL
+247 May 26 08:21 AM Inconing
+248 May 26 09,34 AM I PALM BCH, PL
+240 Kay 26 08:34 AM Inconing
+250 May 26 08:43 2M Inconing
+251 Kay 26 04:59 AM N PALE BCH ,PL
+252 May 26 09,16 AM Incondng
+253Киу 26 10:27 AM Inconing
+254 May 26 10:28 AM N PALA BCH, PL
+255 May 26 10,30 AM Inconing
+257 Kay 26 02:51 I Incoming
+258 Kay 26 03:01 PM N PALE BCH,PL
+250 May 26 03:27 PM Incondng
+280 Kay 26 05:00 m Inconlng
+201 Kay 26 05:30 I Incoming
+282 Kay 26 06.34 FM
+Inconing
+263 кау 26
+09:29 IN N SALE BCH, PL
+254 Kay 26
+IM W PALM BCH, PL
+285 May
+IN N PALE BCH, PL
+288 May 27 09,58
+AM W PALM BCH, PL
+267 кау 27
+10:0€ AM N FALA RCH, PL
+208 Kay 27 01:13 IN N PALA BCH, PL
+280 Kay 27 02:11 IN N FACE BCH,PL
+270 May 27 02112 EM N PALM BCH, PL
+271 Kay 27 02:42 IN N PALA BCH, PL
+272 Kay 27 05:22 PM N PALE BCH, PL
+273 May 27 06.35 PM I PALM BCH, PL
+274 Kay 27 06:56 m
+Inconing
+275 Kay 27 07:59 IN N PALA BCH, PL
+276 Kay 27 08:12 IM Inconing
+277 May 27 09:14 PM NPALM BCH,PL
+278 Kay 27 08:38 m Inconing
+279 Kay 27 09:14 PM N FALK BCH, PL
+280 Kay 27 09.22 EM N PALA BCH, PL
+281 Кну 27
+10:12 PM N FALA NCH, PL
+282 Kay 27 10:14 IM W PALA BCH, PL
+283 Кау 27
+10:27 IM N PALA BCH, PL
+284 Kay 27 10:27 EM W PALM BCH,PL
+285 Kay 27 10:29 PM Inconlng
+Min: Sec
+561-644-1472 08/PU
+561-714-2981 00/PU
+561-309-5954 FF/FU
+561-309-5954 PP/PU
+561-309-3958 FD/FU
+561-309-5958 PD/PU
+561-309-5958
+FP /FU
+561-935-1973 PP/PU
+561-309-5958
+FE /FU
+561-309-5954 FF/FU
+561-714-2981
+PP/PU
+561-662-3098
+FD/FU
+561-714-2981 PD/PU
+561-324-7933
+PF /FU
+PP/PU
+561-965-4949
+361-662-3098
+561-644-1472
+PP/PU
+CE /FU
+ce /FU
+561-662-3094 PP/PU
+561-309-3958 FD/FU
+561-662-3098
+PD/PU
+561-352-7000
+FF /PU
+561-927-2542
+PP/PU
+561-533-0845
+PP/PU
+561-629-6069
+PF /PU
+561-667-5834
+FP/PU
+561-795-3876
+FF/FU
+561-324-1931
+PD /PU
+561-784-4545
+PP /FU |
+561-784-9545
+PP/PU
+561-644-1472
+FF /FU
+561-329-4070
+De/FU
+561-309-5958
+ce/pu
+361-109-5958
+DE/FU
+561-309-5958 00/PU
+561-309-5954 C8/PU
+561-309-5954 CP/PU
+561-309-3958 DE/FU
+Usage
+5:00
+4:00
+5:00
+1,00
+2:00
+1:00
+1:00
+2,00
+1:00
+1100
+2:00
+1:00
+2:00
+1:00
+2:00
+6:00
+1,00
+1:00
+3: 00
+1:00
+1,00
+1:00
+1:00
+1:00
+2100
+2:00
+1:00
+2,00
+2:00
+2:00
+3:00
+1,00
+2:00
+2:00
+3,00
+1:00
+2:00
+1:00
+1,00
+2:00
+9.00
+Long
+Distance
+Total
+Charges
+0.0D
+0.0D
+0.OO
+0.DD
+0,00
+0,00
+
+
+May 11 - June 10, 2004
+(561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Number
+Footnote
+Item # Date Time
+Call To
+258 Kay 27 10:45 IN I BALK BCH, FL
+267 Kay 27 10:45 PM Incoming
+265 Kay 24 08:52 AN Incoming
+280 Kay 24 02:50 EM Inconing
+200 кау 20 02:52 И M PALE ВСП, РС.
+291 Kay 24 02:59 PM Incoming
+292 Kay 24 05:07 PM Inconleg
+203 Kay 24 05147 PM Inconing
+294 Kay 24 08:34 IN Incoeleg
+205 Kay 29 08:46 PM Inconleg
+296 Kay 24 10/10 EM M PALA BCH, FL
+297кку 28 10:11 IN M BALE BCH, FL
+285 Kay 24 10:31 IM Inconieg
+200 Кау 29 12:21 2Н М ВАЦК ВСН, PL.
+300 Кку 29 08:22 ЛМ И ВАШК ВСН, FG
+301кку 23 10:21 A Incaleg
+302 Kay 29 04:46 PM M DALK BCH, PL
+303 Kay 29 04151 EN Inconing
+304 May 27 04:53 IN M PALE BCS, VL.
+305 Kay 29 05:02
+IM Incoming
+305 Kay 29 07:15 PM Inconleg
+307 May 29 07,30 EM Inconing
+308кау 27 08:20 UN M PALE BCH, FL.
+309 Kay 29 08:33 PM Incoming
+310 Kay 29 09:25 PM M PALE BCH, PL
+311 May 29 09,27 PM M BAIR BCH, PL
+312 Kay 29 09:32 IN N PALK BCH, PL
+313 Kay 29 09:33 PM M BALAS BCH, PL
+314 Kay 29 09,52 EM Inconleg
+315кку 22 10:14 I INcoRLeg
+316 Kay 29 10:26 IN M PALK BCH, PL
+317 Kay 29 10:30 PM Inconteg
+318 Kay 29 10,54 EM JUPITER, FL
+319кку 29 10:57 PM M PALE RCH, FL.
+320 Kay 27 10:59 PM I BALK BCH, PL
+321 May 29 11:00 EM Inconleg
+322 May 27 11:0E IN M PALK BCH, VL.
+323 Kay 29 11:23 PM I PALK BCH, PL
+324 Kay 29 12:23 IM Inconleg
+325 May 29 11,26 EM Inconing
+328 Kay 30 12:17 AM Incoalag
+Min: Sec
+561-309-5958
+561-309-5958
+OP/PU
+561-383-6763
+FP/FU
+561-478-4188
+FP/FU
+561-478-4188
+sP/BU
+561-324-7931 V9/9U
+561-324-7931
+FP/FU
+561-309-5958 FP/FU
+561-309-5958
+FF /EU
+561-309-5958
+FP/FU
+561-309-5958
+OP/PU
+561-383-6763
+561-383-6763
+561-644-1472
+561-562-1094
+OP/PU
+OP/FU
+OP/FU
+S61-74-2003
+OP/FU
+S61÷5MS-1448
+561479-0012
+561-383-6763
+561-383-6763
+561-383-6763
+561-324-7931
+561-662-3098
+561-541-2114
+561-644-1472
+561-790-3459
+561-329-8070
+561-281-1518
+561-281-1518
+561-644-1472
+561-662-3098
+OP/FU
+OF/BU
+0P/PU
+OP/FU
+OP/PU
+OP/SU
+OP/FU
+OP/FU
+OP/PU
+OP/PU
+OP/PU
+OP/SU
+OP/FU
+561-262-8209
+561-644-1472
+OP/PU
+OP/SU
+OP/FU
+OP/PU
+561-281-1518
+561-644-1472
+561-281-1518
+561-281-1518
+561-339-2820
+561-644-5602
+0P/PU
+OP/FU
+OP/FU
+OP/SU
+Usage
+1:00
+1:00
+1:00
+3E0U
+1:00
+1:00
+2:00
+1:00
+2:00
+1:00
+2:00
+1:00
+1:00
+1:00
+3:00
+1:00
+2:00
+11:00
+2:00
+TROU
+3:00
+3:00
+2:00
+1:00
+1:00
+2:00
+1:00
+1:00
+2:00
+2:00
+1:00
+1:00
+4:00
+1: 00
+1:00
+1:00
+$:00
+3:00
+•.00
+6.00
+6.00
+•.0D
+6.00
+0.0D
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+0000
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+
+May 11 - June 10, 2004
+SUNSHINE SVCS UNLIMITED (561) 662-3098 continued....
+Telecommunications Services Call Detail (561) 662-3098
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+327 May 30 12:40 AM JUPITER, FL
+328 Kay 30 01:33 AM Inconing
+329 Кау 30 09:59 AM I PALE BCH, PL
+330 My 30 10122 AM I PALM BCH,PL
+331 a 30 10:29 aM Inconing
+332 Kay 30 10:29 AM N PALE BCH, PL
+333 Kay 30 10:36 AM N PALE BCH, PL
+334 May 30 10:52 AM N PALA BCH, PL
+335 Kay 30 10:36 AM Inconing
+338 Kay 30 11116 AM N FALA BCH, PL
+337 May 30 11127 AM I PALA BCH, PL
+338 ay 30 11:33 aM Inconing
+330 Kay 30 11:42 AM N PALA BCH, PL.
+340Кау 30 03:25 PM JUPITER, PL
+341 May 30 03:47 EM W PALA BCH, PL
+342 Kay 30 09:05 FALANCH,PL
+343 Kay 30 05:07 IM N PALA BCH, PL
+344 May 30 05:09 EM NPALA BCH, PL
+345 Kay 30 05:12 IN Inconing
+346 Kay 30 05:30 IM N PALA BCH, PL
+347 Kay 30 05:46 PM N FAIR BCH, PL
+348 Кву 30 07.12 ЕМ 1 РАСИ ВСН ,PL
+340 Kay JO 08:12 In Inconing
+350 Kay 30 68:22 IM Incoming |
+351 Kay 30 08:55 PM N FALK BCH, PL
+352 May 30 10:26 IM N PALM BCH,PL
+353 Kay 30 10:39 IM Inconing
+354 Kay 30 10:55 PM Inconing
+355 May 30 11.09 PM Inconing
+356 Kay 30 11:17 m
+Inconing
+357 Kay 3112:09 AM BOYTONBCH, PL
+358 Kay 31 12:24 AM N PALA BCH, PL
+350 May 31 12:28 AM NPALM BCH,PL
+380 кку 31 01:33 m
+Inconing
+301 May 31 00:07 PM Inconing
+382 May 31 03130 EM Inconing
+363 Jun 01
+10:02 AM N PALM ACH, PL
+354 Jun 01
+12:16 IN W PALA BCH, PL
+365 Jun 01 01:15 PM
+Inconing
+300 Jun 01 05:09 EM Inconing
+357 Jun 01 06:01 PM Inconing
+Min: Sec
+561-262-8209 08/PU
+561-281-1518 0P/PU
+561-309-5954 DE/FU
+561-309-5954 DP/PU
+561-309-3958 CD/FU
+561-309-5958 00/PU
+561-762-2674
+CE /FU
+561-762-2474 0P/PU
+561-762-2874
+DE/FU
+561-762-2874
+Ce /FU
+561-762-2474
+0P/PU
+361-762-2874
+DE /FU
+561-762-2674
+OP/PU
+561-262-8209
+DE /FU
+561-324-7931
+DP/PU
+BOSSE
+561-662-3098
+DP/PU
+361-329-8070
+561-644-1472
+CP/PU
+561-324-7931
+ce /FU
+561-644-2472 0P/PU
+561-714-2981 DE/FU
+561-644-5602 00/CW/PU
+561-644-1472
+ce /PU
+561-644-1472
+cP/PU
+561-714-2981
+CP/PU
+561-644-3472
+561-644-1472
+561-644-1472
+DE/FU
+561-436-4434 00/PU
+561-644-1472
+ce /PU
+561-667-5834
+561-254-9023
+FF /FU
+561-309-5958
+FP/FU
+561-254-9023
+Pe /pU
+361-842-648E FF/FU
+561-363-6763 PD/PU
+561-343-4763 FP/PU
+561-352-7000 PP/PU
+561-385-4371 FF/FU
+Usage
+1100
+8:00
+4: 00
++:00
+1:00
+1:00
+2:00
+1,00
+2:00
+2:00
+2:00
+1:00
+2:00
+1,00
+5:00
+3:00
+1,00
+1:00
+2:00
+5:00
+2,00
+4: 00
+1:00
+3: 00
+3,00
+1:00
+1:00
+1,00
+1:00
+8: 00
+1:00
+1,00
+2:00
+2,00
+1:00
+1:00
+4:00
+1,00
+1:00
+9.00
+Long
+Distance
+Total
+Charges
+0.0D
+0.0D
+0. 00
+0.DD
+0.DD
+0,00
+U .UU
+0.OO
+0,00
+
+
+May 11 - June 10, 2004
+(561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Item # Date Time
+Call To
+Number
+Footnote
+365 Jun 01 06:45 EN I BALA BCH, FL
+561-324-7931
+FP/FU
+369 Jun 01 06:47 PM Incoming
+561-324-7931
+VP/PU
+370 Jun 02 D6:51 PM IncoRleg
+561-687-2308
+FP/FU
+371 Jun 01 07,10 EM Inconing
+561-795-9876
+FP/FU
+372 Ju 01 07:29 IN M PALE BCH, FL
+561-385-4371
+PP/BU
+373 Jun 01 07:37 IN M PALK BCH, PL
+561-686-4123 V9/9U
+374 Jun 01 07:40 PM M BALE BCH, PL
+561-795-9876
+FP/FU
+375 Jun 01 07:41 PM Inconing
+561-795-9876
+PP/PU
+376 Ju: 01 07:43 IN M FAL ECH, FL
+561-68G-4123
+FP/BU
+377 Jun 02 08:51 PM Isconleg
+561-795-9876
+PP/FU
+378 Jun 01 09,53 EM Inconleg
+561-687-2308
+OP/PU
+379 Ju. 01 10:34 IN M BALE BCH, FL
+561-687-2305
+OP/sU
+380 Jun 01 10:47 PM N PALK BCH, PL
+561-714-2981
+OP/PU
+381 Jun 01 10:48 PM M BALE BCH, PL
+561-329-8070
+OP/FU
+382 Jun 01 11/12 EM Inconing
+561-109-1159
+OP/FU
+383 Jun 01 11:16 IN Incoeleg
+563-309-1352
+OP/FU
+3B4 Jun 01 11:21 PM M DALK BCH, PL.
+561-856-2247
+385 Jun 02 11:02 1M Inconlag
+954-695-6124
+PP/FU
+380 Jun 02 04:19 m Incoeleg
+561-540-8824
+387 Jun 02 06:12 IM Incoming
+561-259-4155
+DP/P0
+365 Jun 02 07:47 PM M BALK BCH, PL
+561-324-7931
+360 Jun 02 07:48 PM M BALK BCH, FL
+561-324-7931
+RP/PU
+300 Jun 02 10:43 PN M PALE BCH, FL
+561-301-0308
+OP/SU
+391 Jun 02 11:24 DM N PALK BCH, PL
+561-309-5958
+302 Jun 03 12:01 2M M PALE BCH, PL
+561-683-8612
+FP/FU
+393 Jun 03 01108 PM Inconing
+561-714-2981|
+RP/FU
+394 Jun 03 02:48 IN Inconieg
+561-966-2444
+I9/PU
+385 Jun. 03 05:43 PM M BALE BCH, PL
+561-966-2444
+FP/PU
+306 Jun 03 05:45 PM Inconleg
+561-329-8070
+FP/PU
+397 Jut 03 D5:47 PM M PALAC BC, FL
+561-366-2444
+FP/BU
+398 Jun 03 06:27 PM Incoming
+772-834-7899
+19/90
+300 Jun 03 07:37 PM Inconteg
+PP/FU
+400 Jun 03 08114 EM BOTTONECH, PL
+561-436-4434
+PP/PU
+401 Ju 03 De:15 IN ROTH,
+561-436-4434
+402 Jun 04 06:10 18 Inconleg
+403 Jun C4 10:09 AM Inconing
+404 Jun 04 11:01 At Incaleg
+405 Jun 04 11:12 AM Inconieg
+405 Jun 04 02:28 PM M PALE BCH, PL
+407 Jun 04 02:46 PM W BALK BCH, FL
+405 Jun. 04 03:21 PN M FALK BCH, FL
+Min: Sec
+561-714-2981
+561-383-6763
+561-795-9876
+561-714-2981
+561-432-2930
+561-795-9876
+561-714-2981
+OP/FU
+FP/PU
+P/BU
+PP/FU
+FP/FU
+Usage
+1:00
+1:00
+3:00
+1:00
+3:00
+1:00
+2:00
+2:00
+2:00
+1:00
+1:00
+1:00
+2:00
+3,00
+5:00
+1:00
+2: 00
+1:00
+TROU
+1:00
+4:00
+1,00
+5:00
+2:00
+2:00
+1:00
+1:00
+2:00
+1,00
+TrOO
+1:00
+4:00
+6: 00
+é:00
+2:00
+1:00
+1:00
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0.00|
+0,00
+D.00
+D.00
+D.D0
+Total
+Charges
+9.00
+9.00
+9.00
+
+May 11 - June 10, 2004
+SUNSHINE SVCS UNLIMITED (561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+400 Jun 04 03,51 EM W PALA BCH,PL
+410 Jun 04 03:52 IM N PALM BCH, PL
+411 Jun 04 03:52
+I N PALE RCH, PL
+412 Jun 04 03,57 EM W PALM BCH,PL
+413 Jun 0a 04:00 IN Inconing
+414 Jun 04 04:03 IN N PALE BCH, PL
+415 Jun 04 64:04 #M Inconing
+416 Jun 04 04:17 EM N PALA BCH, PL
+417 Jun 04 04:40 I Inconing
+418 Jun 04 04:41
+Inconing
+419 Jun 04 04:50 PM
+W PALA BCH,PL
+420 Jun 04 04:51
+m Inconing
+421 Jun 04 05:00 I Inconing
+422
+Jun 04 05:02 PM Inconing
+423 Jun 04 07:06 EM W PALA BCH, PL
+424 Jun 04 11:26 PM N FALA: BCH, PL
+Incoming
+426 Jun 05 04:34 PM
+Inconing
+427 Jun 05 04:38 W N SALE BCH, PL
+428 Jun 05 04:58 IM W PALM BCH, PL
+429 Jun 05 04:59 PM Inconing
+430 Jun 05 09.11 EM 1 PALA BCH ,PL
+431 Jun 05 08:12 PM Inconing
+432 Jun 05 08:21 IM W PALA BCH, PL
+433 Jun 05 08:27 IN N BALE BCH, PL
+434 Jun 05 08,30 PM
+Inconing
+435 Jun 05 08:53 IM N PALA BCH, PL
+438 Jun 05 09:53 PM N PALA BCH, PL
+437 Jum 05 09.55 EM PILAUDERD, PL
+438 Jun 05 08:58 IN N FAL/ #CH, PL
+439 Jun 05 09:00 IM N PALA BCH, PL
+440 Jun 05 09:03 PM N PALE BCH, PL
+441 Jun 05 09:03
+EM N PALE BCH, PL
+442 Jun 05 09:11 PM N FALA RCH, PL
+443 Jun 05 09:16 PM N FALK BCH, PL
+444 Jun 05 09.18 EM Inconing
+445 Jun
+446 Jun 05 09:30 IM W PALA BCH, PL
+447 Jun 05
+09:57
+N PALE BCH, PL
+448 Jun 05 10:04
+Incorans
+449 Jun 05 10:13 m
+Inconing
+Min: Sec
+561-329-9070 PP/PU
+561-329-8070 PD/PU
+561-795-9876 FF/FU
+561-329-4070 PP/PU
+561-329-8070 FD/FU
+561-329-8070 PD/PU
+561-540-8020
+FP /FU
+561-714-2981
+PP/PU
+561-255-1391
+FF/FU
+561-765-4939
+FP /NN/FU
+561-352-7000
+PP/PU
+561-352-7000
+SP/FU
+561-427-2542
+PD/PU
+561-827-2542
+PF /FU
+
+561-432-2930
+561-343-6763 0P/PU
+561-856-2974 DE/FU
+561-662-3098 00/PU
+561-383-6763 08/PU
+561-432-2930
+cP/PU
+561-662-3098
+CP/PU
+561-662-3098
+954-465-1894
+561-329-8070
+DE/FU
+561-329-8070 00/PU
+561-329-4070|
+561-541-9809
+CP/PU
+561-541-9809
+DE/FU
+561-541-9609
+De/PU
+561-719-3723 08/PU
+361-377-499D DE/FU
+561-644-5602 00/PU
+561-202-5214 C8/PU
+561-324-7931 CP/PU
+561-333-7530 DE/FU
+Usage
+1100
+1:00
+1:00
+1,00
+1:00
+1:00
+3:00
+1,00
+1:00
+2:00
+1,00
+1:00
+1:00
+5:00
+1,00
+21 DO
+3,00
+1:00
+1:00
+15:00
+1,00
+2:00
+1:00
+1:00
+1,00
+1:00
+2:00
+1,00
+1:00
+2:00
+1:00
+1,00
+1:00
+1,00
+1:00
+2:00
+2:00
+1,00
+2:00
+9.00
+Long
+Distance
+0.0D
+0.0D
+0.0D
+Total
+Charges
+0.OO
+0,00
+0.DD
+0,00
+
+
+
+May 11 - June 10, 2004
+(561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Number
+Footnote
+Item # Date Time
+Call To
+450 Jun 05 11,59 IN M BALA BCH, FL
+451 Jun 06 12:16 AM N PALK BCH, PL
+452 Jun 06 03:14 AN Incoming
+453 Jun O6 11/08 M Inconing
+454 Jum 0€ 11:27 A M PALE BCH, FL.
+455 Jun 06 11:29 AM W PALK BCH, PL
+456 Jun 06 12:45 AM M BALE BCH, PL
+457 Jun 04 03:05 PM M BALA BCH, FL
+455 Ju: 06 03:05 IN M PALE BCH, FL
+459 Jun 06 D6:13 PM I PALE BCH, PL
+480 Jun 06 06/15 EM N PALA BCH, FL
+481 JuL CE DE:20 IN M BALA BCS, FL
+452 Jun 06 06:22 IM Inconieg
+483 Jun 06 06:23 PM M BALE BCH, PL
+454 Jun O6 07,32 EM Inconing
+485 Jun 06 07:3E IN INcoRleg
+400 Jun O6 07:48 PM Incoming
+487 Jun 06 08,39 IN BOTTONBCH, PL
+405 Jun 06 09:01 IN Incoeleg
+459 Jun 06 09:08 PM M PAL/ BCH, PL
+470 Jun
+06 09:19 PM M PALE BCH, PL
+471 Jun 06 09:25 EM Inconing
+472 Jun 06 02:25 UN M PALE BCH, FL
+473 Jun 06 09:40 PM N PALK BCH, PL
+474 Jun 06 10:26 PM Inconleg
+475 Jun 06 11:22 PM Inconing
+476 Jun 07 12:48 AM W PALK BCH, PL
+477 Jun 07 02:12 AM M BALAS BCH, PL
+478 Jun 07 01:22 JM Inconing
+479 Jun 07 12:50 PM IncoRleg
+4B0 Jun 07 02:02 IN Incoming
+481 Jun 07 02:09 PM Inconteg
+452 Jun 07 03,15 PM Inconleg
+454 Jun 07 04:39 EN Inconleg
+485 Jun 07 04:40 PM N BALK BCH, PL
+450 Jam 07 08:39 m Incalag
+457 Jun 07 10:01 PM M PALA BCH, PL
+458 Jun 07 10:01 I Inconleg
+480 Jun 07 10,04 PM W BALK BCH, FL
+490 Jun 07 10:08 IN M FALK BCH, FL
+Min: Sec
+561-662-3098
+OP/PU
+561-714-2981
+OP/PU
+561-202-5286
+OP/FU
+561-432-2930
+OP/FU
+561-324-7931
+OP/BU
+561-762-1585 0P/9U
+561-762-1585
+OP/FU
+561-762-1585 OP/FU
+561-432-2930
+OP/BU
+561-662-3098
+OP/FU
+561-309-1159
+OP/PU
+561-309-1159
+561-309-1159
+561-202-5286
+561-309-1159
+OP/PU
+OP/FU
+OP/FU
+561-329-8070
+OP/SU
+561-762-1585
+0P/90
+561-577-4709
+OP/FU
+561-577-4709
+OF/BU
+561-324-7931
+0P/PU
+561-784-8545
+OP/FU
+561-541-7519
+OP/PU
+561-541-7519
+OP/sU
+561-541-7519
+561-202-5286
+561-202-5286
+561-541-7519
+561-541-7519
+561-541-7519
+561-547-2415
+OP/FU
+OP/FU
+OP/PU
+OP/PU
+OP/FU
+FP/BU
+19/90
+561-478-4188
+561-432-29301
+716-830-4005
+PP/PU
+S61-202-520C
+FP/FU
+561-541-7519
+FP/PU
+561-329-8070
+P/BU
+561-432-2930
+0P/PU
+561-383-6763
+oP/CN/FU
+561-383-6763 OP/FU
+561-202-5286|
+OP/SU
+Usage
+1:00
+1:00
+SIOU
+9:00
+3E0U
+1:00
+1:00
+1,00
+2:00
+2:00
+3:00
+2:00
+1:00
+7:00
+1:00
+2:00
+2:00
+SOO
+1:00
+1:00
+1:00
+6:00
+1:00
+1,00
+5:00
+2:00
+36:00
+3:00
+1:00
+11:00
+4:00
+1:00
+4:00
+1: 00
+1:00
+1:00
+1:00
+5:00
+•.00
+6.00
+6.00
+0.0D
+•.00
+6.00
+4.00
+0.0D
+$.00
+6.00
+6.00
+0.0D
+6.00
+0.0D
+•.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+0,00
+D.00
+0000
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+
+May 11 - June 10, 2004
+SUNSHINE SVCS UNLIMITED (561) 662-3098 continued....
+Telecommunications Services Call Detail (561) 662-3098
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+401 Jun 07 10,37 EM Inconing
+492 Jun 07 10:47 IM W PALM BCH, PL
+493 Jun 07 11:04 PM N PALE BCH, PL
+494 Jun 07 11:05 PM Inconing
+496 Jun 07 11:55 PM N FALA BCH, PL
+496 Jun 08 09:00 AM W PALM BCH, PL
+497 Jun 08 09:01
+AMN FALK BCH, PL
+498 Jun 08
+09:21 AM N PALA BCH, PL
+490 Jun
+10:23
+500 Jun 08
+10:48
+W PALE BCH ,PL
+501 Jun 08
+11,14 AM
+W PALA BCH.PL
+502 Jun D8 11:15
+AM I BALA BICH, PL
+503 Jun 08
+11:31 AM W PALA BCH, PL
+504 Jun 08
+AM N PALES BCH, PI.
+506 Jun
+AM
+506 Jun De 11:43
+507 Jun 08 11:45 AM W PALA BCH, PL
+508 Jun 08
+N PALK
+BCH , PL
+509 Jun Da
+510 Jun 08 11:49
+AM
+W PALA
+BCH, PL.
+511 Jun
+08 11:50
+AMN PALES
+BCH, PL
+512 Jun 08 11:59 AM
+W PALA
+BCH, PL
+513 Jun D8 12:03 PM N BALA RCH, PL
+514 Jun 08 12:05 W
+N PALE BCH, PL
+515 Jun 08 12:33 PM N PALE BCH, PL
+516 Jun 08 12:19 PM
+BCH, PL.
+517 Jun 08 12:46 IM
+N PALA BCH, PL
+518 Jun 08 12:44 PM
+N PALE BCH, PL
+519 Jun 08 01.04
+IN W PALM BCH, PL
+520 Jun D& 01:22 m
+Inconing
+521
+Jun 08 01:50 IM Inconing
+522 Jun 08 02:16 IM Inconing
+523 Jun 08 07:59 PM
+Incoring
+524 Jun 08 08:52 PM
+Inconing
+525 Jun 08 09:24 PM N PALA BCH, PL.
+528 Jun 08 09,33 EM W PALM BCH, PL
+527 Jun Da 11:54 PM Inconing
+528 Jun
+09
+01:08 AM W PALM BCH, PL
+529 Jun 09
+01:10 M
+Inconing
+530 Jun 09 10:21 AM
+W PALM BCH, PL
+531 Jun 03
+12:23
+Inconing
+Min: Sec
+Usage
+561-541-7519 08/PU
+561-714-2981
+0P/PU
+561-662-3098 DE/FU
+561-541-7519 0P/CN/FU
+561-341-7519 CD/FU
+561-478-4188 PD/PU
+561-352-7000
+FP /FU
+561-324-7931
+PP/PU
+561-365-4989
+FE /FU
+561-324-7933
+FF /FU
+561-324-7931
+PP/PU
+561-601-3439
+FD/FU
+561-383-6763
+PD / PU
+561-309-5958
+Fe /FU
+309-595
+PP/PU
+2100
+1:00
+1:00
+1,00
+PP/PU
+361-383-4763
+561-309-5958
+PP/PU
+561-309-5954
+Fe /FU
+561-309-5954 PP/PU
+561-309-3958 FD/FU
+561-309-5958 P0/PU
+561-309-5958 FP/PU
+561-309-5958
+PP/PU
+561-333-2711
+PP/PU
+561-351-7645
+PF /PU
+561-662-6698
+PP/PU
+561-351-7685 FF/FU
+561-383-6504 PD/PU
+561-383-4763 PP/PU
+561-927-2542
+PP/PU
+561-541-7519
+De/pU
+561-541-7519 08/PU
+361-386-0153
+De/FU
+561-541-7519 00/PU
+561-541-7519 C8/PU
+561-352-7000 PP/PU
+561-309-3958 FF/FU
+1:00
+2:00
+1,00
+2:00
+2:00
+1,00
+1:00
+1:00
+1,00
+21 DO
+1,00
+1:00
+1:00
+1:00
+1,00
+1:00
+1:00
+1:00
+1,00
+2:00
+7:00
+2,00
+15:00
+1:00
+2:00
+2100
+10: 00
+2:00
+1,00
+3:0D
+2:00
+6:00
+1,00
+1:00
+9.00
+O-OC
+Long
+Distance
+0.0D
+0.0D
+Total
+Charges
+U .UU
+0.OO
+0,00
+0.DD
+0,00
+0-O0
+
+
+May 11 - June 10, 2004
+(561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+See
+Number
+Footnote
+Item # Date Time
+Call To
+532 Jun 09 01:48 PM Inconing
+533 Jun 09 01:55 PM Incoming
+534 Jun 09 02:11 PM Incoming
+535 Jun 09 03:40 PM M BALK BCH, FL
+536 Jun 07 03:47 IN M PALE BCH, FL
+537 Jun 09 04:59 PM Incoming
+535 Jun 08 08:53 PM Inconleg
+539 Jun 09 10:03 PM M BALA BCH, FL
+540 Jun 09 10:05 IN M PALE BCH, FL
+541 Jun 09 10:24 FM Isconleg
+542 Jun 09 10/32 EM BOYTONECH, PL
+543 Jun 03 10:57 m Incoeleg
+544 Jun 09 11:08 PM N PALK BCH, PL
+545 Jun 09 11:09 FM Inconleg
+548 Jun 09 11,20 EM N BALE BCH, FL
+547 Jul 09 12:32 IN M PALE BCE, FL
+548 Jun 09 11:53 PM M PALK BCH, PL
+549 Jun 09 11,54 IN M BALK BCH, PL
+550 Jun 03 11:56 W Incoeleg
+551 Jun 09 11:59 PM 5 PALK BCH, PL
+552 Jun 10 12:29 A M BALK BCH, PL
+553 Jun 14 01,56 AM M BALK BCH, FL
+554 Jun 10 D8:49 AM Incoalag
+555 Jun 10 09:09 AM N PALK BCH, PL
+558 Jun 10 09:11 2M M PALE BCH, PL
+557 Jun 10 10:15 3M Inconleg
+558 Jun 10 11:18 JM Inconieg
+550 Jun 14 12:47 AM Inconleg
+580 Jun 10 01:40 PM Inconleg
+551 Jul 10 03:29 PM IncoRleg
+562 Jun 10 04:02 IM M PALK BCH, PL
+583 Jun 14 06:27 PM M BALE BCH, PL
+584 Jun 19 06,34 PM N BALA BCH, PL
+565 JuR 10 DE:35 IN M PALE BC, FL
+506 Jun 10 08:15 EN BOYTONBCH, FL.
+587 Jun 10 08.17 EM Inconing
+558 Ju 10 D8:21 IN M PALE BCH, FL.
+509 Jun 1d 08:27 PM M PALA BCH, PL
+570 Jun 10 08:28 PM BOTTONECH, PL.
+571 Jun 19 09,34 EM Inconing
+572 Jun 10 08:38 AN Iscoeleg
+Min: Sec
+561-966-2444
+FP/FU
+561-966-2444
+VP/PU
+561-790-3459
+FP/FU
+561-966-2444
+PP/FU
+561-966-2444
+sP/BU
+561-324-7931 P9/90
+561-333-7530
+FP/FU
+561-309-5958 OP/FU
+561-541-7519
+OF /EU
+561-541-7519 OP/FU
+561-577-4709
+OP/FU
+561-541-7519 O/SU
+561-541-7519 0P/P0
+561-541-7519
+OP/PU
+561-5414759
+OP/FU
+561-541-7519
+OP/FU
+S61-640514
+561-541-7519
+OP/FU
+561-541-7519
+OF/BU
+561-541-7519
+0P/PU
+561-541-7519
+OP/FU
+561-662-3098
+OP/PU
+561-324-7931
+pP/sU
+561-478-4188
+10/8U
+561-352-7000
+FP/FU
+561-662-6688
+RP/FU
+561-309-1159
+I9/PU
+561-432-2930
+FP/PU
+561-432-2930
+FP/PU
+561-541-7519
+FP/BU
+561-541-7519
+19/90
+PP/FU
+561-309-5958
+PP/PU
+561-432-2910
+561-577-4709
+561-644-1472
+561-662-3098
+FP/FU
+FP/PU
+P/BU
+561-644-1472
+561-577-4709
+PP/FU
+561-686-4123 FP/CW/FU
+561-EBE-6123|
+FP/sU
+4:00
+2:00
+1:00
+1:00
+5:00
+3:00
+2:00
+1:00
+3:00
+1:00
+12:00
+1:00
+11:00
+12:00
+22:00
+1:00
+2:00
+1:00
+74:00
+SLUU
+1:00
+2:00
+2:00
+1,00
+1:00
+4:00
+3:00
+4:00
+1:00
+1:00
+1,00
+1:00
+1:00
+2: 00
+2:00
+6:00
+--UU
+1:00
+Usage
+•.00
+6.00
+0.0D
+6.00
+•.0D
+•.00
+6.00
+0.0D
+$.00
+6.00
+6.00
+0.0D
+6.00
+0.0D
+•.00
+Long
+Distance
+D.D0
+D.D0
+D.00
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+SUNSHINE SVCS UNLIMITED (561) 662-3098 continued...
+Telecommunications Services Call Detail (561) 662-3098
+Item # Date Time
+TOTAL
+Call To
+See
+Number
+Footnote Min: Sec
+1370,00
+Usage
+80.00
+Long
+Distance
+80.00
+Total
+Charges
+90.00
+Footnote
+Features
+CW-Call Wating
+CF-Call Forwarding
+3W Three Viay Call
+05-Dialup Service
+Networks
+Services
+NN-National Network
+WNedel Worldwide PF-Partial Free
+WD-Worldwide Discount FC-Free Call
+TJ Tjuana Network
+Time Period
+PP.Peak Period
+OP-Off Peak Period
+MP-Muticle Period
+Nationwide Direct Connect(TM) Call Detail 158*24*31584
+Item # Date
+Time
+Call From
+Call To
+1
+Jun 05 12:53 FM LAKE NORTH, FL
+PENLEY, I
+2
+Jun 05 08,17 EM N PALM BEACH, FL TOMAHANDA, MY
+Jun 05
+08:13 FR
+NEL.LINCTON, FL.
+WILL TARGVILIAN, IT
+Jun 05
+08:20 PM
+W PALM BEACH, PL. WILLIANEVILLE, NY
+Number
+Called
+158*5*53429
+178•136626*2
+178*136436*2
+178*136626*1
+TOTAL
+Total Nationwide
+Min: Sec Direct Connect(TM)
+0:36
+0.03
+0.18
+0.03
+1:18
+0.13
+0:24
+0.04
+2,16
+$0.23
+To view coverage maps of the Nextel Direct Connect® service areas shown. visit www.nextel.com/readbill.
+(561) 662-6616
+Telecommunications Services Call Detail (561) 662-6616
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+Kay 18 09:32 IN SALE BO, PL
+May 18
+09:37 IM W PALM BCH, PL
+3 Kay 19 06:44
+BONTONRCH ,PL
+4 May 19 06:53
+AM
+BOYTONBCH,PL
+5 Кау 19 07:25 мм
+Inconing
+6 Kay 19 07:41
+AM
+W PALM BCH, PL
+7 Kay 19 04:00
+AM
+N PALE BON,PL
+8 Kay 19 12:34
+Kay 19
+01:52 |
+10 Kay 19 01,57
+Inconing
+Inconing
+11 Key 19 03:09 PM
+12 May 19 05:51 1
+Inconing
+13 Kay 19 05:52
+W PALA BCH, PL
+14 Киу 19 05:53 гМ
+W FACE RCH, PL
+15 Kay 13 09:53
+Inconing
+16 Kay 19 06:01
+W PALM BCH, PL
+17 Kay
+19 06157 PM W FALA BCH, PL
+18
+Key 19 07:05
+Inconing
+19
+Kay
+19
+07:26
+Inconing
+20
+May 19 07:54
+Inconing
+561-662-6616
+De /BU
+561-662-6616
+ce /PU
+561-503-4429 OF/FU
+561-503-9429
+OP /PU
+561-303-3930 FD/FU
+561-712-9018
+PP/PU
+561-758-3426
+PP /PU
+561-758-8826
+561-723-3440
+PP/PU
+561-723-3440
+FP/FU
+561-662-6616 PP/PU
+Min: Sec
+3:49
+1:28
+1:00
+1,00
+1:00
+1:00
+1:01
+4:12
+1:00
+1,00
+Usage
+Long
+Distance
+0. DD
+0.DD
+Total
+Charges
+0.0D
+0,00
+561-662-6616
+PP /PU
+FF /FU
+361-357-9751
+561-662-6616 PP/PU
+561-354-1475
+FF /FU
+561-712-7014 PP/PU
+561-714-0244 PD/PU
+561-758-4826 PP/PU
+1:00
+1:00
+1:00
+1,07
+1:00
+1:07
+1,00
+1,00
+1:38
+2: 07
+0.DD
+0.0D
+
+
+May 11 - June 10, 2004
+(561) 662-6616 continued...
+Telecommunications Services Call Detail (561) 662-6616
+See
+Number
+Footnote
+Item # Date Time
+Call To
+21 May 19 08:07 EN Incoming
+22 May 19 09:05 PM M PALA BCH, PL
+23 May 19 09:0E PM I PALA BCH, PL
+24 May 19 10141 IN M PALA BCH, PL
+25 May 19 10:50 IN M PALE BCH, FL
+26 May 19 11:06 PM W PALA BCH, PL
+27 Kay 19 12:17 PM M PALE BCH, PL
+28 May 20 06:47 AM BOTTONECH, FL
+29 Kay 20 D8:35 JIL BOTTONECH, FL
+30 Кау 20 08:41 AN ВОУТОНЕСН, PL.
+31 May 20 08.55 AM BOTTONECH, FL
+32 ray 20 Dв:55 л Inconleg
+33 May 20 08:58 AM Incoming
+34 May 20 08:58 AM BOYTONCH, PL.
+35
+May 20 08159 3M BOSTONECH, FL
+35
+KaY 20 08:0E 300 M PALE BC, VL.
+37
+Kay 20 09:20 3N Incoming
+35
+May 29 10132 84 801708908, PL
+39
+May 20 05:35 IN INCORLEg
+40
+Kay 20 07:05 PM BOYTONBCH, PL
+41
+20 07:05 PM BOYTONECH, PL.
+42 May 20 07,56 #M Inconing
+43 May 21 DE:35 AN Incoelag
+44 May 21 08:07 AM BOYTONECH, PL
+45 May 21 12:36 IN BOTTONBCH, PL
+45 May 21 05:10 PM M BAIR BCH, FL
+47 Kay 21 05:40 PM N PALK BCH, PL
+45 Kay 21 05:41 PM M BALE BCH, PL
+40 May 21 05,50 EM Inconing
+50 May 21 09:38 PM M BALA BCTE, FL.
+51 Kay 22 06:22 AM M DALK BCH,PL
+52 кау 22 07:37 АМ ВОУТОНЕСН, PL.
+53 May 22 07,39 AM BALA BCH, PL
+54 May 22 07:0E IN M PALE BCH, PL
+55 Kay 22 07:12 FM WBALE BCH, PL
+58 May 23 09.10 AM BOTTONECH, FL.
+57 KAY 23 08:25 AM M PAL BCH, PL
+5B Kay 23 08:27 AM M PALE BCH,PL
+50 Kay 23 08:31 AM M BALE BCH, PL
+80 May 23 10,18 AM BOTTONECH, FL
+81 кку 21 11:05 лИ БОТТОНОСИ, РС
+Min: Sec
+561-714-0244 FP/PU
+561-667-2715
+OP/PU
+561-667-3715
+OP/FU
+561-714-0244 OP/FU
+561-357-5751 OP/BU
+561-357-5751 OP/P0
+561-357-5751
+OP/FU
+561-503-8429
+tP/NN/FU
+561-503-5930
+FF /EU
+561-503-5930
+PP/FU
+561-503-5930
+FP/PU
+561-503-5930
+FP/sU
+561-503-8429
+19/P0
+561-503-5930
+561-503-8429
+PP/FU
+PP/FU
+SE075253
+FP/FU
+561-505-5450
+V/P0
+PP/FU
+561-503-5930
+561-357-5751
+561-503-8429
+DP/P0
+561-503-8429
+FP/FU
+561-503-5930
+PP/PU
+561-503-8429 OP/BU
+561-503-5930
+10/8U
+561-503-5930 FP/PU
+561-357-5751
+PP/FU
+561-714-0244
+P9/PU
+561-357-5751
+FP/PU
+561-714-0244
+561-714-0244
+FP/PU
+OP/SU
+561-662-6616
+0P/9U
+OP/PU
+561-712-9018
+OP/PU
+OP/SU
+S61-E97-S79
+OP/FU
+OP/PU
+561-503-8429
+561-712-9018
+561-662-6616
+561-712-9018
+561-503-8429
+561-503-8429
+0P/PU
+OP/FU
+oP/FU
+OP/SU
+1:00
+1:00
+1:07
+1:36
+1:00
+1,00
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1:36
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1,00
+1:00
+1:00
+1:00
+1:50
+1:00
+1:00
+1,00
+1:21
+1:00
+1:00
+1: 00
+1:02
+1:09
+1:00
+1:00
+Usage
+•.00
+6.00
+6.00
+0.0D
+•.00
+6.00
+4.00
+$.00
+6.00
+6.00
+0.0D
+0.0D
+•.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+
+May 11 - June 10, 2004
+(561) 662-6616 continued...
+Telecommunications Services Call Detail (561) 662-6616
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+62 May 23 11:20 AM Inconing
+53 May 23 11:41 AM Inconing
+84 Kay 23 11:51 AM Inconing
+65 May 23 12:06 FM Inconing
+00 May 2312:35 ALECT,PL
+67 May 23 62:04 I Incoming
+60 Kay 23 02:14 PM N PALE BCH, PL
+e9 May 23 03131 FM Inconing
+70Киу 23 03:34 IN IM FALE RCH, PL
+71 Kay 23 03:35 PM N PALE BCH, PL
+72 May 23 03,39 IM N PALA BCH, PL
+73 ay 23 03:47 m Inconing
+74 Kay 23 09:51 IM N PALM BCH, PL
+75 Kay 23 03:58 PM N PALE BCH, PL
+76
+May 23 06:14 EM W PALM BCH, PL
+Kay 24 06:47 10
+Inconing
+78 Kay 24 08:32 AM BOYTONECH, PL
+79 May 2410:11 AM BOTTONBCH, PL
+80
+Kay 24 11:12 л
+BOTTONCH, FL
+81 May 24 11:40 AM BOYTONBCH, PL
+82
+Kay 24 11:41 AM BOYTONBCH, PL
+83
+May 24 11:42 AM BOYTONBCH, PL
+84
+Kay 24 12:31 PM Inconing
+85
+Kay 24 12:36 I Incoming
+86
+Kay 24 01:53 #M BOYTONBCH, PL
+87
+May 24 02:20 EM
+BOYTONBCH ,PL
+88
+Kay 24 02:30 IM N PALM BCH, PL
+Kay 24 02:32 PM
+W PALE BCH, PL
+90
+Мау 24 02:33 #M
+W PALM BCH,PL
+91
+Kay 24 02:34 PM
+92
+Kay 24 02:43
+N PALA BCH, PL
+Kay 24 02:43 IM
+W PALE BCH,PL
+94
+May 24 02:55 EM
+W PALM BCH, PL
+95
+Киу 24 04:37 P
+96
+Kay 24 04:43 PM
+Inconing
+97
+May 24 09:00 EM Inconing
+98
+Kay 24 09:57 PM Inconing
+99
+Kay 24 10:29 IM N PALA BCH, PL
+100 Kay
+25
+06:54 AM
+BOYTONBCH, Ps.
+101 May 25 07:04 AM
+Inconing
+102 кну 25 07:40 мм
+Inconing
+561-712-9014 08/PU
+561-312-4988 00/PU
+561-503-4429 DE/FU
+561-503-4429 OP/PU
+561-712-374E OF/FU
+561-967-0443 00/PU
+561-389-2066
+CE /FU
+561-967-0443
+De/PU
+561-662-6616
+DE/FU
+561-662-6616
+561-662-6616
+ce /PU
+361-357-3751 CB/FU
+561-662-6616 00/PU
+561-357-5753
+De/FU
+561-662-6616
+De/PU
+561-503-4429
+PP/PU
+561-303-5930
+561-503-5930
+PP/PU
+561-503-5936
+Fe /FU
+561-503-5930 PP/PU
+561-303-3930 FD/FU
+561-503-2429 P0/PU
+561-503-4429 FP/PU
+561-503-9429 PP/PU
+561-662-6616 PP/PU
+561-357-5751 PP/PU
+561-714-0244 PP/PU
+561-357-5751
+FE /FU
+561-357-5751 PD/PU
+561-714-0244 PP/PU
+561-714-0244
+PP/PU
+561-503-8421
+FP /FU
+561-503-4429
+FP /pU
+561-357-5751 PP/PU
+361-357-3751 DE/FU
+561-714-0244 00/PU
+561-503-4429 C8/PU
+561-503-9429 PP/PU
+561-758-8824 FF/FU
+Min: Sec
+2120
+1:17
+1:00
+1,00
+1:00
+3:11
+1:00
+1,00
+1:00
+1100
+1,00
+1:00
+1:00
+1:45
+1,35
+1:00
+1,00
+1:00
+1:00
+1:00
+1,00
+1:00
+1:11
+1:00
+1,28
+2:21
+1:00
+1,00
+1:00
+1:00
+1:00
+2119
+1:26
+1,00
+1:00
+1:00
+1:00
+1,00
+1:26
+Usage
+9.00
+Long
+Distance
+Total
+Charges
+0.0D
+0.0D
+0.DD
+0.DD
+0,00
+0-O0
+U .UU
+0.OO
+0,00
+
+
+May 11 - June 10, 2004
+(561) 662-6616 continued...
+Telecommunications Services Call Detail (561) 662-6616
+See
+Number
+Footnote
+Item # Date Time
+Call To
+103 May 25 09,16 AM I BALK BCH, FL
+104 Kay 25 12:26 PM Incoming
+105 Kay 25 12:45 PM BOYTONECH, PL
+108 May 25 12:53 PM BOYTONECH, FL
+107 Kay 25 02:10 IN M PALE BCH, FL
+105 Kay 25 02:13 PM W PALK BCH, PL
+109 Kay 25 03:55 PM BOTTONBCH, PL
+110 Kay 25 04:41 PM Inconing
+111 Kay 25 05:34 IN Incoaleg
+112 Kay 25 D6:18 PM Inconleg
+113 Kay 25 07121 EM BOYTONECH, PL
+114 Kay 23 07:53 IN M BALIE BCH, FL
+115 Kay 25 07:54 PM N PALK BCH, PL
+116 Kay 25 08:21 PM BOTTONECH, PL.
+117 May 25 09,27 EM Inconing
+118 Kay 23 03:29 PM M BALA BCH, FL.
+119 Kay 25 09:32 PM M DALK BCH, PL
+120 May 25 09:43 IN M BALK BCH, PL
+121 may
+25 09:44 IN M PALE BCH, PL
+122 Kay 25 09:53 PM M PALK BCH, PL
+123 Kay
+25 09:55 PM M PALE BCH, PL
+124 Kay 25 09,58 PM M BALK BCH, FL
+125 Kay 25 10:00 IN M PALE BCH, FL
+126 Kay 25 10:03 DM M PALK BCH, PL
+127 Kay 25 10:10 IN M BALE BCH, PL
+128 May 25 10:17 PM M BAIR BCH, PL
+129 May 25 10:28 IN W PALK BCH, PL
+130 Kay 25 10:44
+I PALE BCH, PL
+131 Kay 25 10,52
+IN I BALE BCH,PL
+132 кку 25 11:00
+IN M PALE BCH, FL
+133 Kay 25 11:25 IN M PALK BCH, PL
+134 Kay 24 07:26 AM M BALE BCH, PL
+135 May 26 10,23 AM Inconleg
+136 Kay 26 10:25 AN M PALE BCH, PL
+137 Kay 26 10:26 AM Inconing
+138 May 26 11,27 AM Inconing
+139 Kay 26 12:28 IN Incoaleg
+140 Kay 26 12:38 PM M PALK BCH, PL
+141 Kay 24 12:39 PM M PALE BCN, PL
+142 Kay 26 12,56 PM M BALK BCH, FL
+143 Kay 26 02:04 IN M PALAC BCH, PL
+Min: Sec
+561-662-6688
+FP/PU
+561-503-8429
+561-503-8429
+FP/FU
+561-503-8429
+FP/FU
+561-967-0443
+PP/BU
+561-967-0443 P9/90
+561-503-5930
+FP/FU
+561-758-8826 FP/FU
+561-503-8429
+FF /EU
+561-357-5751 PP/FU
+561-503-5930
+FP/PU
+561-357-5751
+FP/sU
+561-714-0244
+19/90
+561-737-6480
+561-712-9018
+PP/FU
+CP/NS/FU
+561-357-5751
+OP/SU
+561-157-5251
+0P/90
+561-714-0244
+561-714-0244
+561-714-0244
+561-714-0244
+561-714-0244
+561-714-0246
+561-714-0244
+561-714-0244
+561-714-0244
+561-714-0244
+561-714-0244
+561-714-0244
+561-714-0244
+OF/BU
+0P/PU
+OP/FU
+OP/PU
+OP/SU
+OP/FU
+OP/FU
+OP/PU
+OP/PU
+OP/PU
+OP/SU
+561-714-0244
+561-503-8429
+PP/PU
+561-662-6688
+561-827-2542
+561-478-4188
+561-357-5751|
+561-357-5751
+561-478-4188
+561-478-6188
+FP/FU
+FP/PU
+P/BU
+PP/FU
+FP/FU
+1:00
+1:13
+1:00
+1:00
+2:25
+1:00
+3: 45
+1:00
+1:00
+1:00
+1:00
+1:18
+1:26
+1:07
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1,00
+1:00
+1:00
+1:00
+1:00
+1:01
+1:03
+1+12
+1:00
+1:00
+1: 00
+1:00
+1:00
+1:09
+1:37
+Usage
+•.00
+6.00
+6.00
+0.0D
+•.00
+6.00
+0.0D
+0.0D
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+0000
+D.D0
+0,00
+D.00
+D.00
+D.D0
+cortinued...
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+
+May 11 - June 10, 2004
+(561) 662-6616 continued...
+Telecommunications Services Call Detail (561) 662-6616
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+144 May 26 02:06 EM W PALA BCH, PL
+145 Kay 26 02:12 IM Incoming
+146 May 26 02:34 PM PALE RCH, PL
+147 May 26 02151 IM NPALM BCH,PL
+148 Kay 26 02:54 IN N BALE BCH, PL
+149 Kay 26 03:20 IN PALE BCH, PL
+150 Kay 26 04:54 PM N PALE BCH, PL
+151 May 26 06:02 FM N PALA BCH,PL
+152 Kay 26 06:44
+N FALE BICH ,PL
+153 Kay 26 08:15
+W PALE BCH ,PL
+154 May 26 09122 M
+W PALA BCH.PL
+156 Kay 27 05:45
+AM I BALA BICH, PL
+156 Kay 27 08:32 AM N PALA BCH, PL
+157 Kay 27 09:38 AM BOTONCH, PS.
+158 Kay 27 11:56 AM Inconing
+150 Kay 27 01:14 IN BOTONIC, VL.
+160 Kay 27 62:37 IN N PALA BCH, PL
+161 May 27 04.30 EM NPALA BCH, PL
+162 Kay 27 04:32 W N BAL/ BCH, PL
+163 Kay 27
+Inconing
+164 May 27 05:17 PM W FACE BCH, PL
+165 Kay 27
+05:47 PM W PALA BCH,PL
+106 ку 27 07:12 им вотомиси, r.
+167 Kay 27 07:35 I
+BOYTONECH, PL
+168 Kay 27 08:08 #M BOYTONBCH, PL
+169 May 27 09,32 PM I PALM BCH,PL
+170 Kay 27 09:43 IM N PALM BCH, PL
+171 Kay 27 09:47 #
+Inconing
+172 May 28 07:02 1M
+Inconing
+173 Kay 28 07:26 AM X BALA RCH, PL
+174 Kay 28 07:44 AM N PALA BCH, PL
+175 May 28 07:48 мм
+Inconing
+176 May 28 09:02 AM
+BOYTONECH ,PL
+177 Кау 28 09:15 лм
+BOTTONCH, PL
+178 Kay 28 09:41
+AM
+BOYTONBCH, PL
+179 Kay 28 10.18
+AM
+N PALM BCH, PL
+180 Киу 28/
+N FALA RCH, PL
+181 Kay 28
+12:44 PM
+BOYTONECH, PL
+182 Kay
+29
+04:03
+N PALE BCH, PL
+183 May
+09:05 AM
+W PALM BCH,PL
+184 Кку 23
+11:10 AM N FALA ACH, PL
+561-478-4198
+PP/PU
+561-478-4188 PD/PU
+561-478-4188 FF/FU
+561-357-5751 PP/PU
+561-368-2043 FD/FU
+561-714-0244 PD/PU
+561-662-6616
+FP /FU
+561-662-6616
+PP/PU
+561-357-5751
+FE /FU
+561-357-5753
+FF /FU
+561-357-5751
+PP/PU
+361-662-661E DE/FU
+561-357-5751
+PD /PU
+PF /FU
+503-593
+PP/PU
+PP/PU
+361-E62-8E1E
+561-712-9018
+PP/PU
+Fe /FU
+561-714-0244 PP/PU
+561-303-8429 FD/FU
+561-503-2429 P0/PU
+561-503-4429 FP/PU
+561-662-6616 0P/PU
+561-662-6616 0P/PU
+561-714-0244 CF/PU
+561-503-9429 PP/PU
+561-502-5123 FF/FU
+561-662-6616 PD/PU
+561-324-1491 PP/PU
+561-503-9429
+PP/PU
+561-503-8429
+FF /FU
+561-503-4429
+FP /pU
+561-615-0011 PP/PU
+361-827-2542 FF/FU
+561-503-5930 PD/PU
+561-662-6614 C8/PU
+561-714-0244 CP/PU
+561-E62-6E1E DE/FU
+Min: Sec
+3159
+1:00
+2:41
+1,00
+1:43
+3: 34
+1:00
+2153
+1:00
+1100
+1,00
+1:00
+1:24
+1:00
+1,00
+1:00
+1:00
+3:05
+1: 51
+1:00
+1,00
+1:00
+1:00
+1:00
+1,00
+1:00
+1:00
+1,00
+1:00
+1:00
+1:00
+1,00
+1:00
+1,00
+1:35
+2:52
+1:30
+3,20
+1:01
+Usage
+9.00
+Long
+Distance
+0.0D
+0.0D
+Total
+Charges
+0.OO
+0.0D
+0,00
+0.DD
+0,00
+0-O0
+
+
+May 11 - June 10, 2004
+(561) 662-6616 continued...
+Telecommunications Services Call Detail (561) 662-6616
+See
+Number
+Footnote
+Item # Date Time
+Call To
+185 Kay 29 11/11 AM I BALK BCH, FL
+105 Kay 29 02:29 М ВОУТОНЕСН, PL.
+187 May 29 04:08 PM BOYTONECH, PL.
+185 May 29 06:06 EM BOYTONECH, FL
+189 Kay 27 D6:50 IN BOYTONECH, FL.
+190 Kay 30 07:09 AM I PALA BCH, PL
+191 Kay 30 12:00 IN M BALK BCH, PL
+192 May 30 12143 PM M BALK BCH, FL
+193 Kay 30 01:13 IN BOTTONICH, FL.
+194 Kay 30 03:34 PM I BALK BCH, PL
+105 Kay 30 01,35 EM Inconleg
+195 Kay 30 02:55 IN M BALAL BCS, FL
+197 Kay 30 02:57 IN M PALA BCH, PL
+195 Kay 30 03:46 IN M BALK BCH, PL
+100 Kay 30 03:46 EM Inconing
+200кку 30 05:38 PM M BALA BCH, FL.
+201 Kay 30 05:51 PM M DALK BCH, PL.
+202 Kay 30 06108 IN I PALA BCH, FL
+203 May 30 07:02 IN M PALE BCS, VL.
+204 Kay 30 08:33 IM BOYTONCE, PL
+205 Kay 3009:54 PM Inconleg
+208 May 31 09151 AM Inconing
+207 Kay 31 01:01 PM Incoalag
+205 Kay 31 02:46 PM M PALK BCH, PL
+209 Kay 31 10:27 PM Incoming
+210 Jun 01 09,23 A M BAI BCH, PL
+211 Jun 01 09:24 JM Inconieg
+• Jun 01 10:38 AM Incoming
+213 Jun 01 10,56 AN ORGANDO, FL
+214 Jul 01 D6:19 PM M PALAC BCE, FL
+215 Jun 01 06:32 IM M PALK BCH, PL
+216 Jun 01 06:33 PM M BALE BCH, PL
+217 Jun 01 07,38 PM BOTTONECH, PL
+218 Jun. 01 07:44 PM BOTTONCH, FL.
+219 Jun 02 06:39 34 leg
+220 Jun 02 08:48 AM BOYTONBCH, FL.
+221 Jun 02 D8:5E AN BOTTONICH, FL
+222 Jun 02 09:54 AM M PALA BCH, PL |
+223 Jun 02 10:08 AM BOTTONECH, PL.
+224 Jun 02 10:08 AM BOSTONECH, FL
+225 Jun 02 10:35 Al Inconleg
+Min:Sec
+561-357-5751
+OP/PU
+561-503-8429
+OP/PU
+561-577-6425
+OP/FU
+561-503-8429
+OP/FU
+561-503-5930
+OP/BU
+561-662-6616 0P/9U
+561-662-6616
+OP/FU
+561-662-6616 OP/FU
+561-503-8429
+561-662-6616 OP/FU
+561-304-3378
+OP/CW/FU
+561-304-3378
+OP/sU
+561-304-3378
+OP/PU
+561-714-0244
+561-714-0244
+OP/PU
+OP/PU
+561-662-6616
+OP/SU
+561-714-0244
+0P/90
+561-714-0244
+OP/FU
+561-662-6616
+OF/BU
+561-503-5930
+0P/PU
+561-714-0244
+OP/FU
+561-503-5930
+RP/PU
+unavallable
+SP/SU
+561-714-0244
+10/8U
+561-714-0244
+OP/FU
+561-714-0244
+RP/FU
+561-714-0244
+P9/PU
+561-723-3440
+FP/PU
+407-509-6377
+561-662-6616
+FP/PU
+FP/BU
+561-357-5751
+19/90
+561-714-0244
+PP/FU
+561-503-5930
+PP/PU
+563-503-5930
+FP/SU
+OP/FU
+561-503-5930
+FP/PU
+561-503-5930
+P/BU
+561-662-6688
+561-503-5930
+PP/FU
+561-503-5930 PP/FU
+561-352-7000|
+2129
+1:00
+1:03
+1:00
+1:00
+1,00
+1:03
+1126
+1:16
+1:00
+1:00
+1:00
+1,25
+1:00
+1:53
+1:00
+1:00
+1:59
+1:00
+3:50
+2:55
+2:23
+1,00
+1:08
+1:35
+1:19
+1:06
+1:00
+1:21
+1,00
+1:00
+1:00
+1: 00
+2:30
+1:00
+1:00
+1:06
+Usage
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+0.0D
+0.0D
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+0000
+D.D0
+D.D0
+0,00
+D.00
+0000
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+(561) 662-6616 continued...
+Telecommunications Services Call Detail (561) 662-6616
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+228 Jun 02 11:43 AM W PALA BCH, PL
+227 Jun 02 11:44 AM Incoming
+228 Jun 02 01:57 PM Inconing
+229 Jun 02 C4:44 EM W PALM BCH,PL
+230 Jun 02 05:59 PM N BALA RCH, PL
+231 Jun 02 66:48 I Inconing
+232 Jun 02 07:36 PM Inconing
+233 Jun 03 06.56 AM Inconing
+234 Jun 03 10:49 AM Inconing
+235 Jun 03 10:52 AM W PALA BCH, PL
+236 Jun 03 11/32 AM N PALA BCH, PL
+237 Jun 03 01:22
+IN BALANCH, PL
+238 Jun 03 01:57 IM N PALA BCH, PL
+230 Jun 03 02:02 PM N PALE BCH, PL
+240 Jun 03 02111 EM Inconing
+241 Jun 03 03:19 PM Inconing
+242 Jun 03 05:21 IM N PALA BCH, PL
+243 Jun 03 05.31 EM Inconing
+244 Jun 03 05:35 I Inconing
+245 Jun 03 06:08 I Incoming
+248 Jun 03
+06:10 PM BOYTONBCH, PL
+247 Jun 03
+06:12 PM W PACK BCH,PL
+248 Jun 03
+06:2E IN N BALAL RCH, PL
+249 Jun 03 06:36 IM N PALA BCH, PL
+250 Jun 03 07:34 IN N BALE BCH, PL
+251 Jun 03 08:05 PM
+Inconing
+252 Jun 03 08:28 IN N PALA BCH, PL
+253 Jun 03 09:24 F
+Inconing
+254 Jun 03 09,25 PM
+BOXTONBCH, PO
+255 Jun 0a
+06:02 AM
+Inconing
+256 Jun 04 02:16 IM N PALA BCH, PL
+257 Jun 04
+02:17 PM N PALE BCH, PL
+258 Jun 04
+02:21 EM N PALM BCH,PL
+250 Jun 04
+280 Jun 04
+IN W PALE BCH, PL
+251 Jun 04
+04:08 PM N PALM BCH, PL
+262 Jun
+I N FALK ACH, PL
+203 Jun 04
+04:26 IM W PALM BCH, PL
+254 Jun 04
+05:03
+Inconing
+285 Jun
+05,31 PM W PALM BCH, PL
+286 Jun
+05:33 PM A FALA NCH, PL
+Min: Sec
+561-357-5751 PP/PU
+561-357-5751 PD/PU
+561-712-9014 FF/FU
+561-357-5751 PP/PU
+561-341-3447 FD/FU
+561-357-5751 PD/PU
+561-324-1491
+FP /FU
+561-503-4429 CP/NN/FU
+561-357-5751
+FE /FU
+561-357-5753
+FF /FU
+561-714-0244
+PP/PU
+361-662-661E FD/FU
+561-541-5449 PD/PU
+561-615-0013
+PP/PU
+561-541-5449
+561-324-1491
+PP/PU
+561-324-1491
+561-503-8429
+PP/PU
+561-503-2429
+FE/PU
+561-714-0244 PP/PU
+561-714-0244 FD/FU
+561-714-0244 P0/PU
+561-714-8244 FP/PU
+561-667-3715 PP/PU
+561-304-3378 PD/PU
+561-712-9014 CF/PU
+561-503-3429 08/PU
+361-712-2018 OF/FU
+561-662-6616 PD/PU
+561-798-8530 PP/PU
+561-357-5751
+pP/pu
+561-794-4516
+PP/PU
+561-794-8530
+Pe /pU
+361-714-0244 FF/FU
+561-304-3378 PD/PU
+561-754-4824 FP/PU
+561-754-9826 PP/PU
+561-758-8824 FF/FU
+1100
+3: 54
+5:53
+1:41
+1:00
+1:00
+1:26
+1,00
+1:00
+1120
+1,06
+1:00
+1:00
+1:05
+1,30
+1100
+2:22
+1:00
+1:00
+1,00
+1:00
+1:00
+1:00
+1121
+1:57
+1:00
+1,00
+1,00
+1:00
+1,00
+1:00
+1:26
+1:09
+1,00
+1:30
+Usage
+9.00
+Long
+Distance
+Total
+Charges
+0.0D
+0.0D
+0.0D
+0,00
+0,00
+0-O0
+0.OO
+0.OO
+0,00
+
+
+* 1.2010.01
+B (561) 662-6616 continued...
+Telecommunications Services Call Detail (561) 662-6616
+See
+Number
+Footnote
+Item # Date Time
+Call To
+287 Jun C4 05,33 PM Inconing
+268 Jun. 04 05:35 PM Incoming
+260 Jun 04 07:20 PM Inconleg
+270 Jun 04 10:29 PM M BALK BCH, FL
+272 Jun 05 01:01 PM M PALK BCH, PL
+273 Jun 05 02:41 PM Inconleg
+274 Jun 05 03:38 EM Inconing
+275 Jun 05 03:44 IN Incoaleg
+276 Jun O5 04:05 PM M PALE BCH, PL
+277 Jun O5 04:21 EM M PALA BCH, FL
+278 Jun 03 04:22 m Incoeleg
+279 Jun 05 04:23 PM N PALA BCH, PL
+280 Jun 05 04:23 PM M BALE BCH, PL
+281 Jun O5 05,36 EM Inconing
+282 Jun 05 05:58 IN M PALE BCE, FL
+283 Jun 05 06:17 PM Inconing
+284 Jun 05 06120 IN Incoming
+265 Jun 03 D6:31 I Incoeleg
+285 Jun 05 08:04 PM M PALK BCH, PL
+287 Jun 05 08:17 EM M BALE BCH, PL
+285 Jun 05 08123 EM Inconing
+289 Jun 05 02:04 IN M PALE BCH, FL
+290 Jun 06 11:06 AM N PALK BCH, PL
+291 Jun 06 02:52 PM Inconleg
+202 Jun 06 05:16 PM M BAIR BCH, PL
+293 Jun 06 06:55 IN Inconieg
+204 Jun 07 06:07 AM M BALE BCH, PL
+205 Jun 07 06:09 AM Inconleg
+295 Jun. 07 D6:28 J81
+Incoeleg
+297 Jun 07 02:53 PM M PALA BCH, PL
+288 Jun 07 02:54 PM M PALA BCH, PL.
+200 Jun 07 08:41 PM N BALA BCH, PL
+300 Jun.
+301 Jun 04 06:51 AN Inconleg
+302 Jun C9 07,14 AM BOYTONCE, FL
+303 Jun 08 04:17 m Incaleg
+304 Jun 04 07:51 PM M PALK BCH, PL
+305 Jun 04 08:08 IN Inconleg
+306 Jun 04 08:16 PM W BALK BCH, FL
+307 Jun ca De:le aN Inconleg
+Min: Sec
+Usage
+561-758-8826
+PP/CN/ FU
+561-758-8826
+VP/PU
+561-712-9018
+FP/FU
+561-662-6616
+OP/FU
+561-503-8429
+OP/BU
+561-714-0244 OP/PU
+561-312-4988
+OP/FU
+561-827-2542 OP/FU
+561-827-2542
+OP/BU
+561-357-5751
+OP/FU
+561-798-8530
+OP/PU
+561-827-2542
+OP/sU
+561-357-5751
+561-714-0244
+561-827-2542
+OP/PU
+OP/FU
+561-714-0244
+OP/FU
+561-357-5751
+561-662-6688
+561-662-66E8
+561-357-5751|
+561-357-5751
+561-357-5751
+561-357-5751
+561-655-4135
+561-324-1491
+561-324-1491
+561-324-1491
+561-324-1491
+OP/FU
+OF/BU
+0P/PU
+OP/FU
+OP/PU
+OP/SU
+561-324-1491
+561-324-1491
+561-357-5751
+OP/FU
+OP/FU
+OP/PU
+OP/PU
+OP/PU
+OP/SU
+09/90
+561-324-14911
+PP/PU
+SE-15-5251
+OP /FU
+S61-S0-s2
+OP/FU
+561-503-8429
+FP/PU
+561-357-5751
+P/BU
+561-714-0244
+561-304-3378
+561-714-0244
+PP/FU
+FP/FU
+561-503-8429
+1:00
+1:38
+1:39
+1:00
+1:00
+1:40
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1:07
+1:00
+1:45
+1:00
+1:31
+1127
+1:36
+1:52
+2:25
+1,00
+1:09
+1:03
+1:00
+1:00
+1:00
+2:34
+1,39
+TrOO
+1:27
+2:45
+1:00
+2:40
+1:00
+1:13
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+$.00
+6.00
+6.00
+0.0D
+6.00
+0.0D
+•.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+cortinued..
+Total
+Charges
+9.00
+9.00
+9.00
+
+May 11 - June 10, 2004
+(561) 662-6616 continued...
+Telecommunications Services Call Detail (561) 662-6616
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+308 Jun 09 03,34 AM W PALA BCH,PL
+309 Jun 09 03:35 AM Incoming
+310 Jun 09 07:08 AM BOYTONBCH, PL
+311 Jun 09 01121 EM Inconing
+312 Jun 03 07:09 I Inconing
+313 Jun 09 07:16 IN N PALE BCH, PL
+314 Jun 10 07:02 AM Inconing
+315 Jun 10 10:36 AM Inconing
+316 Jun
+11:00 AM BOTTONICH, FL
+317 Jun 10 12:27 F
+BOYTONBCH , PL
+318 Jun 10
+02:44 PM
+N PALM BCH ,PL
+319 Jun 10
+I N SALE RCH, PL
+320 Jun 10 04:00 m
+BOYTONECH , PL
+321 Jun 10 05:50
+N PALE BCH, PL
+322 Jun 10
+05:51
+BOYTONBCH " PL
+323 Jun 10
+BOTONEC , V.
+324 Jun 10
+W PALE BCH ,PL
+325 Jun 10
+N PALK
+BCH, PL.
+326 Jun 10
+BOTTONCH, FL
+327 Jun 10 C8:49 IM BOYTONBCH, PL
+TOTAL
+Min: Sec
+Usage
+Long
+Distance
+561-662-6616 08/PU
+561-503-8429 0P/CN/PU
+561-503-4429 FF/FU
+561-714-0244 PP/PU
+20-9-3093
+561-714-0244 PD/PU
+561-503-4429
+FP /FU
+561-503-9429 PP/PU
+561-503-8429
+FE /FU
+561-503-3429
+FF /FU
+561-357-5751
+PP/PU
+561-714-0244 FD/FU
+561-503-8429 PD/PU
+561-714-8244
+PF /FU
+561-503-9429
+PP/PU
+561-503-8428
+561-714-0244
+561-714-0244
+PP/PU
+1100
+1:00
+1:00
+1,00
+5:43
+2:17
+1:00
+1,20
+1:00
+1100
+1,00
+1:13
+1:00
+1:00
+1,00
+1:00
+2:30
+1,00
+9.00
+0.0D
+0.0D
+0.DD
+561-503-8429
+PP/PU
+1:00
+431,49
+80.00
+80.00
+Footnote
+Features
+CW-Call Wating
+CF-Call Forwarding
+3W-Three Way Call
+DS-Dialup Service
+Networks
+Services
+NN-National Network
+AL - Alternate Line
+ratan hears
+PU-Plan Promotional Usage
+W-Nedel Worldwide
+PF-Partial Free
+WD-Worldwide Discount FC-Free Call
+TJ-Tijuana Network
+Time Period
+PP-Peak Period
+OP.Off Peak Period
+MP-Muticle Period
+C
+(561) 662-6688
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+1 Kay 11 06:51 AM Inconing
+2 Кау 11 07:12 AM N PACH BCH, PL
+3 May 11 07:24 AM Incoming
+4 Кау 11 07:38 ЛМ И ВАЕИ ПСИ, PL
+5 Kay 11 08:01 AM Incoming
+฿ May 11 08:07 AM N FALA BCH, PL
+7 May 11 08.04 AM N PALA BCH, PL
+8 Kay 11 08:13 AM
+Inconing
+• Kay 11 08:16 AM Inconing
+10 May 11 04.17 AM N FALA RCH, PL
+Number
+Footnote
+561-264-5511 08
+561-669-7656
+eP
+561-684-6242
+PP
+561-815-0011
+FF
+561-434-8000
+PP
+561-684-2555
+FF
+561-352-7000
+PP
+361-352-700D
+FF
+561-502-7753
+561-427-2542
+Min: Sec
+1:00
+4:00
+3:00
+1:00
+2:00
+1100
+1,00
+1:00
+1:00
+1:00
+Usage
+0,00
+Total
+Charges
+Long
+Distance
+0.DD
+Total
+Charges
+0,00
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time
+Call To
+11 May 11 08:18 AM M BALA BCH, FL
+12 Kay 11 08:20 AM M PALA BCH, PL
+13 May 13 08:20 AM M PALA BCH, PL
+14 May 11 08123 AM M PALA BCH, FL
+15 Kay 11 08:23 AM Inconleg
+16 Kay 11 08:23 AM Incoming
+17 Kay 11 08:25 AM M BALK BCH, PL
+18 May 11 08:27 AM Inconing
+19 Kay 11 08:31 At Inconleg
+20 May 11 08:34 AM Inconleg
+21 May 11 08,34 AM Inconing
+22 кку 11 08:37 ЛИ ВОУТОВЕСИ, Г.
+23 May 11 08:42 AM Incoming
+24 May 11 08:4E AM M BALE BCH, PL
+25 May 11 08.59 AM M BALA BCH, FL
+20 May 11 03:01 18 Incaleg
+27
+May 11 09:02 3M Incoming
+25
+May 11 09,16 AM M BALA BCH, PL
+29
+May 11 09:18 AM IncoRleg
+30
+Kay 11 09:26 3M M PALK BCH, PL
+31
+Kay 11 09:27 AM M BALK BCH, PL
+32
+May 11 09,28 AM M BALK BCH, PL
+33 May 11 09:42 AN Inconleg
+34 Kay 11 09:46 3M M PALK BCH, PL
+35 Kay 11 09:52 3М M BALK BCN, PL |
+36 May 11 09,57 1М Incoming
+37 Kay 11 10:04 AM Incoeieg
+30 Kay 11 10/11 AN M BALA BCH, FL
+40 May 11 10:21 AM M BALAC BCTE, FL.
+41 May 11 10:22 AM Inconieg
+42 кау 11 18:25 ММ ВОТТОНЕСН, PL.
+43 May 11 10,29 AM Inconing
+44 May 11 10:45 AN Inconleg
+45 May 11 10:46 AM W BALE BCH, PL
+45 May 11 10,46 AM W BALK BCH, FL
+47 May 11 10:56 A/ Inconleg
+45 Kay 11 10:57 AM M PALE BCH, PL
+49 ay 11 11:01 AM Incoming
+50 May 11 11:02 AM W BALA BCH, PL
+51 May 11 11:05 at Inconleg
+Min: Sec
+561-827-2542
+PP
+561-827-2542
+561-541-4051
+561-827-2542
+FP
+FP
+561-478-4188
+561-502-3866
+VP/CW
+561-541-4051
+FP
+561-827-2542
+FP
+561-368-6853
+FF
+561-722-0047
+PP
+561-722-0047
+FP
+561-503-8429
+561-202-8497
+561-439-2398
+561-827-2542
+561-662-7746
+561-827-2542
+561-54 4051
+561-439-2398
+561-688-2555
+561-827-2542
+561-718-4005
+561-503-5930
+561-615-0011
+561-615-0011
+561-790-5465
+561-439-2398
+561-502-7753
+561-478-4188
+561-541-4051
+561-723-3440
+561-790-5465
+5E1-502-7253
+S61-981-60S
+561-502-7753
+561-541-4051
+561-502-7753
+561-478-4188
+561-626-0200
+561-502-7753
+PP
+FP
+FP
+FP
+FP
+PP
+FP
+FP
+FF
+FP
+FP
+FF
+Usage
+1:00
+1:00
+2:00
+1:00
+1,00
+2:00
+1:00
+2:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+2:00
+1:00
+2:00
+1:00
+1:00
+4:00
+1:00
+3:00
+1:00
+1:00
+3:00
+2:00
+1:00
+1:00
+1:00
+2: 00
+1:00
+1:00
+2:00
+1:00
+•.00
+6.00
+6.00
+0.0D
+•.00
+6.00
+6.00
+6.00
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+52 May 11 11:17 AM Inconing
+53 Kay 11 11:19 AM I PALM BCH, PL
+54 May 11 11:20 AM N PALE RCH, PL
+56 May 11 11124 AM NPALA BCH,PL
+56 Kay 11 11:25 AM N BAL RCH, PL
+57 Kay 11 11:26 AM I PALA BCH,PL
+58 Kay 11 11:36 AM Inconing
+50 May 11 11:46 AM Inconing
+60 Kay 11 12:05 IN FALO BCH, PL
+61 Kay 11 12:25 PM Inconing
+82 May 11 12:16 IM N PALA BCH, PL
+83 Kay 11 12:18 m Inconing
+61 Kay 11 12:57 I Inconing
+85
+Kay 11 01:29 PM Inconing
+ee
+May 11 01.37 EM W PALA BCH, PL
+67 May 11 01:46 M VISTLUCIES, PL
+08 Kay 11 01:52 IM N PALA BCH, PL
+60 May 11 01,54 FM NPACE BCH, PL
+70 May 11 01:53 IN Inconing
+71
+Kay
+02:03 IM W PALM BCH ,PL
+72
+Kay
+02:08 PM N FACE: BCH, PL
+May 11 02129 EM I PALM BCH ,PL
+74 May 11 02:40 PM Inconing
+75 Kay 11 02:41 IM N PALA BCH, PL
+76 May 11 02:58 IM Inconing
+77
+May 11 03,36 PM
+Incordng
+78 Kay 11 03:48 I
+Inconing
+79 Kay 11 04:26 PM N PALE BCH, PL
+80
+May 11 04:39 PM N PALA BCH,PL
+81 Kay 11 04:53 PM
+Inconing
+82 Kay 11 05:20 IM N PALA BCH, PL
+83 May 11 05:21 PM N PALA BCH, PL
+84 May 11 05:27 PM Inconing
+85 Kay 11 05:56 PM N FALA: BCH,PL
+Kay 12 06:17 AMN FALA BCH, PL
+87 May 12 06.54 AM Incondng
+88
+Kay 12
+06:56 AM Inconing
+89
+Kay 12 07:15 AM N PALA BCH, PL
+Min: Sec
+561-202-9497 PP
+561-718-4005P0
+561-175-5124 FF
+561-775-5124 PP
+561-791-4482 FD
+561-775-5178PP
+561-502-7753
+FF
+561-662-7746
+PP
+561-827-2542
+561-502-7753
+561-615-0011
+FF
+PP
+172-344-6631
+561-123-1821 PP
+561-662-7746
+561-723-1421
+561-793-9238
+PP
+561-722-0047
+561-662-6688
+PP
+561-615-0011
+561-542-1964
+PP
+561-722-0047 FD
+561-122-0047
+561-722-8047
+561-722-0047
+561-827-2542
+561-723-1421
+561-474-4148
+FF
+PP
+PP
+FF
+PP
+561-123-1821
+561-723-1621
+PP
+561-632-1842
+561-632-1842
+PP
+561-333-7530
+561-689-6733
+De
+361-324-1491
+561-615-0011
+PD
+561-324-1491 PP
+561-737-4175 PP
+561-721-1821 FF
+Usage
+2100
+1:00
+1:00
+1,00
+1:00
+3: 00
+1:00
+2,00
+1:00
+1100
+1,00
+6: 00
+1:00
+9:00
+1100
+6100
+1,00
+1:00
+5:00
+1:00
+3,00
+1:00
+5:00
+2:00
+3,00
+1:00
+4:00
+1,00
+1:00
+1:00
+1:00
+1,00
+21 DO
+1:00
+2,00
+2:00
+1:00
+1:00
+2,00
+1:00
+9.00
+91 May 12 07:24 AM BOYTONBCH, PL
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0.DD
+0.DD
+0,00
+Total
+Charges
+U .UU
+0.OO
+0,00
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+93 May 17 07,59 AM M BALA BCH, FL
+561-965-0722 FP
+2100
+94 May 12 08:18 AM M PALA BCH, PL
+561-352-7000 0P
+2:00
+95 Kay 12 08:21 AN M PALE BCH, PL
+561-252-4383
+FP
+6:00
+98 May 12 08:40 AM M PALA BCH, PL
+561-688-0400
+FP
+CEOU
+5E1-EBE-1005
+1:00
+88 May 12 08:54 AM Incoming
+561-723-9450
+2:00
+99 May 12 09:00 AM DEERPLOECH, PL
+954-650-9306
+FP
+1:00
+100 Kay 12 09,16 1M Inconing
+561-324-1491|
+2:00
+101 Kay 12 08:33 Al Incoaleg
+561-795-4856
+1:00
+102 Kay 12 09:36 A M PALE BCH, PL
+561-662-6688
+FP
+6:00
+103 Kay 12 09:42 AM Inconleg
+561-723-1821
+FP
+2:00
+104 May 12 08:43 AN IncoRleg
+561-373-5074
+4:00
+105 Kay 12 10:01 2M N PALK BCH, PL
+561-718-4005
+2:00
+105 Kay 12 10:12 AN M BALK BCH, PL
+561-662-6688
+FP
+4:00
+107 May 12 10127 1N
+Inconing
+561-502-1R6
+FP
+3,00
+108 Kay 12 10:42 AM INCoLeg
+unava11 able
+1:00
+109 Kay
+12 10:46 AM N PALK BCH, PL
+561-662-6688
+2:00
+110 Kay 12 11:03 1M Inconing
+561a719-8657
+3:00
+111 may
+12 11:12 AN M PALE BCH, PL
+112 Kay 12 11:21 AM Incoming
+113 Kay
+12 12:46 AM InDEleg
+114 May 12 12:07 EM Inconing
+115 ay 12 12:10 IN Incoeleg
+116 Kay 12 12:12 DM N PALK BCH, PL
+117 Kay
+12 12:14 IN M BALE BCN, PL
+118 May 12 12:44 PM M BAIR BCH, PL
+119 May 12 12:45 IN W PALK BCH, PL
+120 Kay 12 12:48 PM Inconleg
+561-503-5930
+561-722-0047
+561-202-8497
+561-667-4222
+561-502-5123
+561-723-1821
+561-644-4989
+561-722-0047
+561-478-4188
+1:00
+PP
+FP
+PP
+1:00
+2:00
+1:00
+1:00
+1,00
+2:00
+1:00
+121 Kay 12 12,52 PM W BALK BCH, FL
+FP
+FP
+122 кку 12 12:55
+IN A PALE ECH, FL
+561-541-4051
+561-541-4051
+2:00
+1:00
+123 May 12 01:00 IN Incoming
+561-662-0524
+1:00
+124 Kay 12 03:02 PM M BALE BCH, PL
+3:00
+125 Kay 12 01:05 PM Inconleg
+561-723-18211
+128 Kay
+12
+S61-255-225
+3:00
+5:00
+127 Kay 12 01:19 PM I BALK BCH, PL
+S61-4-*900
+PP
+128 May 12 01/28 EM ВОСА ДАТОН, FL
+129 May 12 01:42 IN M PALK BCH, VL.
+130 Kay 12 01:48 IM M PALK BCH, PL
+131 Kay 12 02:58 PM M PALE BCN, PL
+132 Kay 12 01,59 PM M BALK BCH, FL
+133 Kay 12 02:01 IN M FALK BCH, PL
+561-361-9171
+561-541-4051
+561-729-1821
+561-478-1190
+561-684-3332
+561-541-4051
+2400
+FP
+FP
+FF
+2: 00
+5:00
+1:00
+2:00
+2:00
+Usage
+•.00
+6.00
+6.00
+0.0D
+•.00
+6.00
+6.00
+6.00
+0.0D
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+0000
+D.D0
+0,00
+D.00
+D.00
+D.D0
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+134 May 12 02:03 EM W PALA BCH, PL
+135 Kay 12 02:06 IM N PALA BCH, PL
+136 Kay 12 02:07 PM Inconing
+137 May 12 02114 IM Inconing
+138 May 1202:22 IN FALANCE, PL
+139 May 12 02:32 I Inconing
+140 Kay 12 02:34 PM N PALE BCH, PL
+141 May 12 03:04 EM Inconing
+142 Kay 12 03:38 IN SALE SCH, PL
+143 Kay 12 03:40 PM Inconing
+144 May 12 03:47 EM BOCA RATON, PL
+145 Kay 12 03:53 SALE BCH, PL
+146 Kay 12 03:55 IN N PALA BCH, PL
+147 Kay 12 04:02 PM Inconing
+148 May 12 04:03 PM Inconing
+140 Kay 12 04:11 IN BALANCH,PL
+150 Kay 12 04:15 IM N PALA BCH, PL
+151 Key 12 (4.19 EM Incondng
+152 Kay 12 04:23 PM Inconing
+153 Kay 12 64:25 IM N PALA BCH, PL
+154 May 12 04:26 PM W FACE BCH, PL
+155 Kay 12 04:29 EM 1 PALM BCH ,PL
+156 Kay 12 04:32 MM N BALA RCH, PL
+157 Kay 12 64:35 IM N PALE BCH, PL
+158 Kay 12 04:38 PM N PALE BCH, PL
+150 May 12 04,39 FM NPALM BCH ,PL
+160 May 12 04:41 IM N PALM BCH, PL
+161 Kay 12 04:45 PM
+N PALE RCH, PL
+162 May 12 04:52
+IN W PALM BCH, PL
+163 Kay 12 04:56 1M
+164 Kay 12 05:50 m
+Inconing
+185 May 12 06:41 PM N PALA BCH, PL
+106 May 12 06:42 PM N PALM BCH,PL
+Min: Sec
+Usage
+561-662-6648 PP
+561-662-0524 PP
+561-123-1821 FF
+561-659-4791 PP/CH
+561-478-4188 FD
+561-582-1964 PP
+561-541-4051 FP
+561-474-4148 PP
+561-541-4051
+FE
+561-723-3821
+FF
+561-393-7920
+PP
+361-723-1821 FD
+561-123-1821 PP
+954-525-4816
+5454-405
+2100
+1:00
+8:00
+2:00
+2:00
+2:00
+1:00
+1,00
+1:00
+1100
+6:00
+1:00
+2:00
+2:00
+2:00
+9.00
+1:00
+4471-1441
+41 00
+561-624-4518
+PP
+361-723-1821
+561-541-4051
+PP
+561-541-4051
+561-541-4051
+PP
+361-662-6E0E FD
+561-541-4051
+561-541-4051
+561-662-6688
+561-664-3332
+3,00
+3:00
+1:00
+1:00
+1,00
+3:00
+1:00
+1:00
+2100
+2:00
+1:00
+5:00
+2:00
+160 May 12 07:34 m
+Inconing
+180 May 12 07153 EM Inconing
+170 Кау 12
+171 Kay 12 08:01 IM N PALA BCH,PL
+172 May 12 09:32 IN N PALM BCH, PL
+173 Kay 12 09:32 EM N PALM BCH, PL
+174 Kay 12 08:33 PM N FALA NCH, PL
+FF
+PP
+PP
+561-352-3000
+FF
+561-719-4961
+PP
+561-123-1821
+561-707-7600 PD
+561-776-3885
+561-644-4989
+561-776-3885
+561-722-0047
+FF
+561-722-0047
+361-303-5930
+FF
+561-964-5511
+PD
+561-762-2474 PP
+561-762-2474 PP
+561-762-2874 FF
+1:00
+2100
+EEDO
+1:00
+1,00
+1:00
+3:00
+1:00
+1,00
+2:00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0. 00
+0.DD
+0.DD
+0,00
+0-O0
+Total
+Charges
+U .UU
+0.OO
+0.0D
+0,00
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+175 Kay 17 08,36 IN M BALK BCH, FL
+561-352-7000 FP
+1:00
+176 Кау 13 06:21 АМ ВОУТОНЕСН, PL
+561-503-5930
+1:00
+177 May 13 06:29 AM I PALE BCH, PL
+561-689-6733
+OP
+2:00
+178 May 13 06,32 AM Inconing
+561-324-1491
+CEOU
+179 Kay 13 DE:57 AM IncoRleg
+561-827-2542
+OP
+1:00
+180 Kay 13 06:59 AM Incoming
+561-503-8429
+HP
+2:00
+181 Kay 13 07:05 AN I PALE BCH, PL
+561-582-1964
+FP
+4:00
+182 May 13 07:19 3M BOTTONBCH, PL
+561-503-8429
+1,00
+183 Kay 13 07:34 At Incoaleg
+561-723-1821
+2:00
+184 Kay 13 07:41 3M Inconleg
+561-723-1821
+FP
+1:00
+185 Kay 13 08.38 AM Inconleg
+561-478-4188
+FP
+2:00
+186 Kay 13 D8:44 A M BALAC BCH, FL
+561-541-4051
+2:00
+187 Kay 19 09:16 2M N PALK BCH, PL
+561-478-4188
+19/N09
+1:00
+188 Kay 13 09:16 AN M BALK BCH, PL
+561-352-7000
+1:00
+189 Kay 13 09,18 AM Inconing
+561-478-4188
+PP
+$:00
+190кку 13 03:30 A M BALA BCH, FL.
+561-582-1964
+1:00
+191 Kay 13 10:00 AM M DALK BCH, PL
+561-662-6688
+3:00
+192 Kay 13 10:02 AM Inconing
+561-434-8000
+PP/CS
+193 May 13 10:03 AN M PALE BC, VL.
+561-723-1821
+194 Kay 13 10:16 AM I PALK BCH, PL
+561-827-2542
+1:00
+195 Kay 13 10:24 AM M BALK BCH, PL
+561-478-4188
+106 May 13 10,34 AM I BALA BCH, PL
+561-965-0722
+197 Kay 13 10:3E AN M PALE BCH, FL
+561-965-0722
+FP
+PP/NS
+DP/1E9
+195 Kay 13 11:26 AM Incoming
+561-478-4188
+199 May 13 11:33 AM M BALE BCH, PL
+561-582-1964
+200 May 13 11,39 3 M BAI BCH, PL
+561-582-1964
+FP
+PP
+201 Kay 13 11:50 JM Inconieg
+561-737-3115
+202 Kay 13 12:20 PM M BALE BCH, PL
+561-723-3440
+2:00
+1:00
+1:00
+1:00
+1,00
+1:00
+1:00
+203 Kay 13 12,59 PM ORLANDO,EL
+204 Kay 13 01:10 PM IncoRleg
+321-229-2595
+561-723-1821
+FP
+FP
+2:00
+2:00
+205 Kay 13 01:15 IN Inconieg
+561-723-3440
+2:00
+205 Kay 13 01:36 PM Inconteg
+1:00
+207 May 13 02,05 PM Inconleg
+704-364-5840
+PP/NN
+2:00
+208 кку 13 02:07 #н
+ROTTONaCH, FL.
+S61-734-777
+TrOO
+209 Kay 13 02:08 FM Incoming
+210 May 13 02/09 EM N BALK BCH, FL
+211 Kay 17 02:56 IN Incaleg
+7 Kay 13 03:07 PM Incoming
+213 Kay 13 03:19 PM Inconleg
+214 May 13 03,25 EM M BALK BCH, FL
+215 Kay 13 03:31 PM M PALAC BCH, FL.
+704-364-5840
+561-478-4188
+561-478-4188
+561-478-4188
+561-373-7254
+561-662-6688
+561-723-1821
+FP
+FF
+FP
+FP
+FF
+1:00
+1:00
+2: 00
+é:00
+2:00
+5:00
+4:00
+Usage
+•.00
+6.00
+6.00
+0.0D
+•.00
+6.00
+0.0D
+6.00
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+0000
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+216 May 13 03:35 EM Inconing
+217 Kay 13 03:35 IM N PALA BCH, PL
+218 May 13 03:38 PM I PALE RCH, PL
+219 May 1303:47 PM I PALM BCH,PL
+220 kay 13 04:05 m Inconing
+221 May 13 64:10 I Inconing
+222 Kay 13 04:17 PM N PALE BCH,PL
+223 May 13 C4.19 EM Inconing
+224 Kay 1304:22 PLAUDERD, PL
+225 Kay 13 04:30 PM Inconing
+228 May 13 C4:49 FM Inconing
+228 Kay 13 05:19 IM N PALA BCH, PL
+220 Kay 13 05:22 PM N PALE BCH,PL
+230 Kay 13 05.31 EM W PALA BCH, PL
+231 Kay 13 09:32 IN BALANCH, PL
+232 Kay 13 05:54 IN PALA BCH, PL
+233 May 13 06:04
+Inconing
+234 Kay 13 06:30 IN SALE SCH, PL
+235 Kay 13 06:32 IM N PALA BCH, PL
+236 Kay 13 06:52 IM Inconing
+237 May 13 07:09 EM N PALM BCH, PL
+238 Kay 13 07:36 M N BALA RCH, PL
+230 Kay 13 68:45 IM N PALA BCH, PL
+240 Kay 14 06:38 AM Inconing
+241 May 14 07:03 AM N PALM BCH, PL
+242 May 14 07:22
+AM N PALM BCH, PL
+243 Kay 14 07:25
+MA N PALE BCH, PL
+244 May 14
+07:25
+AMN PALE BCH, PL
+245 Кму 14 07:61
+AMN FALE RICH, PL
+246 Kay 14 07:59
+AM W PALA BCH, PL
+247 May 14 09:07 AM N PALE BCH, PL
+248 May 14 09:09 AM N PALM BCH,PL
+240 кку 14 08:10 лм
+Inconing
+250 Кау 14 09:23 мм
+Inconing
+251 Kay 14 09.29 AM N PALA BCH, PL
+252 Кну 14 08:36 )
+AM N FALM ACH, PL
+253 Kay 14 08:40 AM
+Inconing
+254 May 14 09:44 лм
+Inconing
+256 May 14 09154 1M Incoming
+Min: Sec
+561-723-1421 PP
+561-255-1015P0
+561-442-6414 FF
+561-474-4148 PP
+561-303-3930 FD
+954-914-4070 PP
+561-502-7753
+FF
+561-474-4148
+PP
+354-914-4070
+561-722-0047
+561-722-0047
+FF
+PP
+361-662-6088
+561-662-6668 P8
+561-253-4923
+561-478-4148
+561-964-5511
+PP
+361-723-1821
+561-662-6688
+PP
+561-667-4222
+561-364-5511
+PP
+561-352-700D
+561-667-4222
+954-818-3335
+561-541-4051
+ce
+PP
+561-842-6414
+561-541-4053
+561-541-5449
+561-EBE -4924
+561-662-0524
+561-352-7008
+561-354-1875 PP
+561-358-1875
+561-541-5449 PF
+561-615-0011
+361-723-1440 FF
+561-642-0100 PD
+561-474-4144 PP
+561-723-3440 PP/CH
+561-721-3440 FF
+Usage
+1100
+3:00
+5:00
+2:00
+1:00
+6: 00
+2:00
+1,00
+1:00
+13:00
+1,00
+2:00
+3:00
+2:00
+1,00
+1:00
+6100
+12,00
+1:00
+2:00
+1:00
+26:00
+3:00
+1:00
+1:00
+2100
+1:00
+1:00
+1,00
+1:00
+1:00
+2,00
+1:0D
+1:00
+2,00
+4: 00
+1:00
+10:00
+1,00
+2:00
+9.00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0.DD
+0,00
+0,00
+0-O0
+Total
+Charges
+U .UU
+0.OO
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Item # Date Time
+Call To
+257 Kay 14 08,58 AM BOCA RATON, FL
+258 Kay 14 09:00 AM M PALA BCH, PL
+250 Kay 14 09:04 AN IncoRiNg
+280 May 14 09,11 AM I PALA BCH, PL
+201 кау 14 09:19 ЛИ М РАДЕ ВСП, РС.
+262 Kay 14 09:43 AM Incoming
+263 Kay 14 09:46 AN I PALE BCH, PL
+284 Kay 14 09:46 AM I PALA BCH, PL
+265 кку 14 09:50 ЛМ М РАДЕ ВСП, VL.
+260 Кау 14 09:51 АМ ВОСА КАТОМ, PL.
+287 Kay 14 09,58 AM Inconleg
+265 кку 14 10:04 лн котлонаси, П.
+269 Kay 14 11:01 2M Inconieg
+270 Kay 14 12:24 2н M BALK BCH, PL
+271 May 14 11,25 AM M BALK BCH, FL
+272 кку 14 12:02
+i Incoeleg
+273 Kay 14 12:03 P
+Incoeing
+274 Kay 14 12126 IN Inconing
+275 Kay 14 01:29 I Incoeleg
+276 Kay 14 01:36 IM JUPITER, PL
+277 Kay 14 03:57 PM Inconleg
+278 Kay 14 02/15 PM M BALK BCH, FL
+279 ay 14 02:24 IN M PALE BCH, FL
+280 Kay 14 02:25 DM N PALK BCH, PL
+261 Kay 14 02:27 IN M BALE BCH, PL
+262 Kay 14 02143 PM Inconing
+283 Kay 14 03:05 IN Inconieg
+284 Kay 14 03:20 PM
+265 Kay 14 03,58 PM Inconleg
+286 кку 14 06:19 им воттоваста, ГL.
+267 Kay 14 04:21 IN Inconieg
+268 Kay 14 04:22 PM M BALE BCH, PL
+280 May 14 04,31 PM Inconleg
+200 кку 14 05:43 М воУтоваси, ГL.
+291 Kay 14 06:07 PM I BALK BCH, PL
+202 May 14 06:07 EM Inconing
+293 May 14 DE:09 IN M PALK BCH, FL.
+294 Kay 14 08:14 IM M PALK BCH, PL
+285 Kay 14 08:15 PM Inconleg
+208 May 14 09:16 EM Inconing
+297 Kay 15 07:31 M Inconleg
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+561-305-1272 FP
+561-662-6688
+772-299-3181
+FP
+561-723-3440
+FP
+561-833-0846
+561-305-1272
+561-723-3440
+561-723-3440
+FP
+FP
+561-723-3440
+561-305-1272
+561-723-1821
+FP
+FP
+561-503-5449
+Min: Sec
+561-202-8497
+561-582-1964
+561-615-0011
+563-C86-4024
+S61e725-1M21
+561-684-3847
+561-746-5123
+561-478-4188
+561-644-4989
+561-644-4983
+561-352-7000
+561-723-3440
+561-602-2291
+561-582-9156
+561-202-8497
+772-794-0396
+561-737-2222
+561-723-1821
+561-503-5930
+561-577-6425
+561-722-0047
+561-662-6688
+561-324-1491|
+561-324-1491|
+561-253-4923
+561-502-7753
+PP
+PP/NV
+FP
+FP
+FP
+FP
+FP
+PP
+PP
+FP/Cs
+FF
+FP
+OF
+Usage
+2100
+4:00
+SIgU
+CEOU
+1:00
+3:00
+1:00
+4:00
+1:00
+3:00
+3:00
+1:00
+1:00
+1:00
+3,00
+1:00
+1:00
+4÷00
+5:00
+3:00
+2:00
+1:00
+1:00
+4:00
+10,00
+5:00
+1:00
+1:00
+1:00
+1:00
+1:00
+2:00
+4:00
+2:00
+2: 00
+1:00
+1:00
+3:00
+1:00
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+0.0D
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+0000
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+298 May 15 07,54 AM BOCA RATON, PL
+299 May 15 08:26 AM BOYTONCH, PL
+300 Kay 15 09:00 1М Inconing
+301 May 15 09,56 AM 1 PALA BCH,PL
+302 кну 15 10:17 ЛИ ВОСА RATON, PL.
+303 May 15 10:18 2M Inconing
+304 Kay 15 10:24 AM BOCA RATON, PL
+305 May 15 10:4* 1M Toll Pree Call
+306Киу 15 11:50 Inconing
+307 Kay 15 01:09 PM N FALE: BCH ,PL
+308 May 15 01/12 FM Inconing
+300 кку 15 01:14 m N вли вси,/L.
+310 Kay 15 01:21 IM Incoring
+311 Kay 15 01:30 PM N PALE BCH, PL
+312 May 15 01134 EM Inconing
+313 Kay 15 01:40 mM Inconing
+314 Kay 15 01:50 m
+Incoming
+315 May 15 02:15 PM
+Inconing
+316 Kay 15 02:16 IN SALE #CH, PL
+317 Kay 15 02:17 IM N PALA BCH, PL
+318 Kay 15 02:22 PM N FACE BCH, PL
+319 May 15 02153 EM N PALM BCH, PL
+320 Kay 15 03:27 PM Inconing
+321 Kay 15 03:36 IM N PALE BCH, PL
+322 Kay 15 04:09 #M N FALK BCH, PL
+323 May 15 04:10 #M Inconing
+324 Kay 15 04:14 IN N PALA BCH, PL
+325 Kay 15 04:16 PM N PALE BCH, PL
+328 May 15 04.21 PM Inconing
+Number
+Footnote
+561-305-1272 0P
+561-577-6425 00
+561-541-5449 OF
+561-364-5511 OP
+561-305-1272 CE
+561-305-1272 00/CN
+561-305-1272 08
+988-683-1000 0P
+561-365-5507
+DE
+561-541-5449
+561-541-5449
+561-341-3447 08
+561-577-6425 00
+561-502-5123
+ce
+561-541-5449
+561-502-7753
+561-723-3440
+561-723-3440
+561-502-7753
+ce
+561-502-7753
+561-341-3449 OF
+561-502-7753
+561-723-3440
+ce
+561-541-5449
+561-964-5511
+CP
+561-662-6648
+561-964-5511
+561-364-5511
+561-616-8240
+ce
+561-644-4999
+561-722-0047
+561-352-7000
+561-315-2500
+De
+361-303-8422
+561-503-8429 00
+561-503-4429 CE
+561-503-9429 CP
+561-758-8824 CE
+Usage
+2100
+3: 00
+2:00
+2:00
+2:00
+2:00
+2,00
+4: 0D
+1100
+2:00
+1:00
+1:00
+2:00
+2:00
+7:00
+1,00
+2:00
+1:00
+1:00
+2,00
+3:00
+1:00
+1:00
+2100
+1:00
+7:00
+2,00
+2:00
+1:00
+1:00
+4:00
+21 DO
+2:00
+3,00
+2:00
+1:00
+1:00
+1,00
+1:00
+9.00
+328 Kay 15 05:00 IM Incoring
+329 Kay 15 05:04 PM Inconing
+330 May 15 06:01 PM N PALM BCH,PL
+331 Kay 15 06:08 PM 7 FALA RCH, PL
+332 Kay 15 06:44 PM N FALK BCH, PL
+333 May 15 07.01 IN W PALM BCH, PL
+334 Kay 15 08:30
+Inconing
+335 Kay 15 08:33 m
+BOYTONECH, PL
+336 May 15 09:34
+337 May 15 09134
+BOYTONeCH, PL
+338 кну 15 08:35 тм
+Inconing
+Min: Sec
+Long
+Distance
+0.0D
+0.0D
+0.0D
+0.DD
+0.DD
+0,00
+0-O0
+Total
+Charges
+U .UU
+0.OO
+0.0D
+0,00
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time
+Call To
+330 Kay 15 08,38 IN I BALK BCH, FL
+340 Kay 15 08:42 PM I PALA BCH, PL
+341 May 15 D8:45 PM Incoming
+342 May 15 08:52 PM I PALA BCH, PL
+343 Kay 15 09:02 W INcoRleg
+344 Kay 15 10:36 PM M PALK BCH, PL
+345 Kay 16 08:33 AN I PALE BCH, PL
+346 May 16 08.35 AM M BALA BCH, FL
+347 Kay 16 D8:49 AN Incoeleg
+345 Kay 16 09:32 AM M PALE BCH, PL
+349 Kay 16 09,52 AM M PALA BCH, FL
+350 кку 16 11:05 лм Incoeleg
+351 Kay 16 11:39 ZM N PALK BCH, PL
+352 Kay 16 12:36 IN M BALK BCH, PL
+353 Kay 16 01/19 EM I BALK BCH, FL
+354 Kay 16 01:47 PM M PALAC BCH, FL
+355 Kay 16 01:57 PM Incoming
+358 Kay 16 02,15 IN M PALA BCH, FL
+357 Kay 16 02:58 I Incoeleg
+355 Kay 16 04:18 I Incoming
+350 Kay 16 04:42 PM M BALK BCH, PL
+360 May 15 05155 EM Inconing
+351 KAY 17 D6:32 AM M PALAC BCH, FL.
+362 Kay 17 06:49 AM Incoming
+363 Кау 17 06:51 2М И PALE BCH, PL.
+384 Kay 17 07:14 AM N PALM BCH, PL
+365 Кау 17 07:16 ЗМ И PALK BCH, PL
+360 Кау 17 07:31 АМ M BALE BCH, PL
+387 Kay 17 07,57 AN Inconleg
+355кку 17 08:01 3М M BALE BCH, FL
+309 Kay 17 08:04 1М Inconieg
+370 Kay 17 08:13 1М Inconteg
+371 May 17 08,35 AM I BALA BCH, PL
+372 Kay 17 08:37 AN M PALE BCH, PL
+373 Kay 17 09:44 AM Inconing
+374 May 17 09:48 AM M BALK BCH, FL
+375 Kay 17 08:10 A M FAIL BCH, FL
+376 Kay 17 09:11 AM PLAUDERDL, PL
+377 May 17 09:20 AM M PALE BCH, PL
+378 May 17 09,31 1М Inconing
+379 Kay 17 09:31 AM JUPITER, FL.
+Min: Sec
+561-758-8826 0P
+561-758-8826
+561-758-8826
+OP
+561-662-3098
+561-61E-8240
+OP
+561-616-8240
+561-315-2500
+OP
+561-795-4537
+561-502-7753
+561-776-3885
+OF
+OP
+OP
+561-541-5449
+561-965-1305
+561-547-2415
+561-965-1305
+561-965-1305
+563-541-5442
+561-667-4222
+561-541-5449
+561-616-0267
+561-924-8880
+561-723-1383
+561-588-9862
+561-582-1966
+561-324-1491
+561-662-6688
+561-541-4051|
+561-541-4051
+561-793-3808
+561-503-8429
+561.116-2500
+561-315-2500
+561-541-4051
+581-723-1440
+561-659-4020
+561-842-6414
+954-914-4070
+561-502-5123
+561-582-2164
+561-746-5123
+OP
+OP
+OP
+OP
+OP
+OP
+OP
+FP
+FP
+PP
+FP
+FF
+FP
+FP
+FF
+1:00
+2:00
+2:00
+SECU
+1:00
+1:00
+1,00
+2:00
+3:00
+1:00
+2:00
+4:00
+1:00
+1:00
+1:00
+1:00
+1:00
+5:00
+SLUU
+TROU
+2:00
+2:00
+1,00
+1:00
+1:00
+1:00
+2:00
+2:00
+4: 00|
+2:00
+2:00
+1:00
+2400
+1: 00
+2:00
+1:00
+1:00
+2:00
+Usage
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+0.0D
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+0000
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+380 May 17 09,36 AM JUPITER, FL
+561-745-5123 PP
+1100
+381Кау 17 10:15 AM I PALM BCH, PL
+561-582-1964P0
+1:00
+382 Kay 17 10:21 AM Inconing
+561-448-4172 FF
+3:00
+383 May 17 10139 AM Inconing
+561-329-0783 PP
+11,00
+384 ay 17 11:09 a Inconing
+561-74E-4400 FD
+7:00
+385 May 17 11:19 1M Incoming
+561-744-4703PP
+5:00
+306 Kay 17 11:23 AM Inconing
+561-723-3440 FP/CN
+1:00
+387 May 17 11135 1М Incondng
+561-352-7000 PP
+1,00
+388 Киу 17 11:43 1М Inconing
+561-324-1491 FE
+2:00
+380 Кау 17 11:47 м
+Inconing
+561-305-3272 PF
+2:00
+300 Кву 17 12:27 #М
+Inconing
+561-324-1491 PP
+1,00
+391 кну 17 01:01
+Inconing
+361-478-7760 FF
+7:00
+392 Kay 17 01:08 IM N PALA BCH, PL
+561-662-6668 P8
+3:00
+383 Kay 17 01:11 PM N PALE BCH,PL
+561-942-6414 PR
+1:00
+304Кву 17 01.32 EM NPALA BCH, PL
+1,00
+300 Kay 17 01:34 PM N FALE: BCH, PL
+4:00
+390 Kay 17 01:37 I Incoring
+4471-1441
+7:00
+397 Key 17 01,50 EM W PALA BCH, PL
+398 Ka 17 01:31 I BOCA RATON, PL
+399 Kay 17 01:53 IM N PALA BCH, PL
+400 May 17 01:56 PM W FACE BCH, PL
+401 May 17 02:04 EM Inconing
+402 Kay 17 02:07 PM Inconing
+403 Kay 17 02:11 IM N PALE BCH, PL
+404 May 17 02:22 IN N BALE BCH, PL
+405 May 17 02:25 FM Incondng
+406 Kay 17 02:28 IM Inconing
+407 Kay 17 02:52 PM N PALE BCH, PL
+408 Kay 17 02.53 PM N PALA BCH,PL
+400 Kay 17 02:55 IM DERRILOACH, PL
+410 Kay 17 03:03 I Inconing
+561-474-4148
+PP
+361-368-E853
+561-848-4336
+PP
+561-662-6688
+561-324-7931 PP
+561-722-0047 FD/CH
+561-478-4188 P0
+561-478-4188 PP
+561-667-4222 PP/CH
+561-502-5123 PP/CN
+561-502-5123
+ee
+561-667-4222
+PP
+254-426-6300
+561-324-7931
+PD
+2,00
+2:00
+2:00
+2:00
+3,00
+4: 00
+9: 00
+7:00
+1,00
+1:00
+1:00
+2,00
+411 May 17 03:11 IN N PALE BCH, PL
+412 May 17 03:21 PM BOCA RATON, PL
+561-393-7914
+1,00
+413 Kay 17 03:22 PM BOCA RATON, PL
+0101-70
+414 Kay 17 03:23 PM N FALK BCH, PL
+415 May 17 03.25 EM BOCA RATON, PL
+416 Kay 17 01:32 PM N FACE RCH, PL
+417 Kay 17 03:33 IN N PALA BCH, PL.
+418 Kay 17 03:34 IN PALM BCH, PL
+419 May 17 03:36 #M Inconing
+420ку 17 01:65 IN PTLALDERIK, PL
+561-793-2712
+FF
+561-393-7930
+361-867-4222
+FF
+561-615-0011
+PD
+561-502-5123 PP
+561-474-4144 PP
+254-791-8720 FF
+2:00
+7,00
+1:00
+1:00
+1:00
+7,00
+1:00
+Usage
+9.00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0. 00
+0.DD
+0,00
+0,00
+0-O0
+Total
+Charges
+U .UU
+0.OO
+
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time
+Call To
+421 May 17 03:45 IN M BALK BCH, FL
+422 Kay 17 03:54 PM M PALA BCH, PL
+423 May 17 04:12 PM Incoming
+424 May 17 04:29 PM Inconing
+425 Kay 17 04:30 IN Incoalag
+426 Kay 17 04:44 I Incoming
+427 Kay 17 06:10 PM I PALE BCH, PL
+428 Kay 17 06:12 PM I PALA BCH, PL
+429 Kay 17 D6:29 IN M FADE BON, FL
+430 May 17 06:31 PM M BALK BCH, PL
+431 May 17 06,34 EM NBALK BCH, PL
+432 Kay 17 DE:51 IN DELAAT BCH, FL
+433 Kay 17 06:56 IM N PALK BCH, PL
+434 Kay 14 07:01 AN I BALK BCH, PL
+435 Kay 19 07,11 AM Inconing
+436 кку 18 07:12 Л M FALE ВСП, FL.
+437 Kay 14 07:13 AM I DALK BCH, PL
+438 Kay 19 07,26 AM I PALA BCH, FL
+439 May 1# 07:28 AN M PALE BC, VL.
+440 Kay 14 07:31 AM I PALK BCH, PL
+441 Kay 1# 07:40 AM M BALK BCH, PL
+442 Kay 14 07,53 AM FILAUDERDG, FL
+443кау 18 D8:05 AN BOTTONCH, FL.
+444 Kay 14 08:07 AM M PALK BCH, PL
+445 Kay 14 08:13 AM M BAL BCH, PL
+448 May 19 08114 A M BAI BCH, PL
+447 Kay 14 08:15 AM PILAUDERDL, PL
+445 Kay 14 08:20 AM M BALE BCH, PL
+440 Kay 14 08.23 AN COCON,FL
+450 Kay 18 08:35 AM INcoRLeg
+451 Kay 14 08:39 AM COCOA, PL
+452 Kay 14 08:51 AM M BALE BCH, PL
+453 May 19 08,52 AM N BALA BCH, PL
+454 Kay 14 D8:54 AN M PALE BCH, PL
+455 Kay 14 08:57 AM Inconing
+456 May 19 09,12 AM M BALK BCH, FL
+457 May 1# 02:23 AN M PALK BCH, FL.
+458 Kay 14 09:31 AM Incoming
+450 May 14 09:33 AM M PALE BCH, PL
+450 May 19 09,34 Inconing
+451 Kay 10 09:39 A Incoalag
+Min: Sec
+Usage
+561-976-4168 F7
+561-324-7931
+561-964-5511
+561-667-4222
+561-502-7753
+561-255-3725
+561-352-7000
+561-644-4989
+561-964-5511
+561-662-6688
+561-478-2456
+FP
+FP
+FF
+PP
+FP
+561-715-7184
+2100
+2:00
+19:00
+FP
+FP/CW
+•.00
+6.00
+6.00
+•.0D
+561-662-6688
+561-541-5449
+561-964-5511
+S61-46SS
+5614541-6051
+561-723-3440
+561-615-0011
+561-723-3440
+954-791-8720
+561-503-5930
+561-324-1491
+561-842-1464
+561-842-6414
+954-914-4070
+561-662-6688
+321-243-0056
+561-252-4654
+321-243-0056
+561-478-4188
+561-352-7000
+561-152-7000
+561-324-1491
+561-793-1712
+561-202-8497
+561-281-6849
+561-281-6849
+561-502-7753
+FP
+PP
+FP
+FP
+FP
+FP
+FP
+PP
+FP
+FP
+FF
+4:00
+2:00
+14:00
+1:00
+3:00
+2:00
+2:00
+2:00
+2:00
+1:00
+1:00
+4:00
+2: 00
+1:00
+1:00
+1:00
+1:00
+1:00
+1,00
+2:00
+3:00
+1:00
+3:00
+4:00
+1:00
+3:00
+1:00
+10:00
+2400
+2: 00
+1:00
+--UU
+2:00
+6.00
+0.0D
+6.00
+6.00
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+continued..
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time
+Call To
+482 May 18 09:41 AM Inconing
+453 May 18 69:49 AM Incoming
+434 Kay 18 10:16 AM Inconing
+485 Nay 18 10,35 AM 1 PALA BCH ,PL
+457 May 18 10:38 1M Incoming
+408 Kay 18 10:40 AM Inconing
+489 May 18 10:40 AM I PALA BCH ,PL
+470 Кау 18 10:41 ли N вАи #си , L.
+471 Kay 18 10:45 AM Inconing
+472 May 18 10:47 AM I PALA BCH, PL
+473 кау 18 10:51 ли х вАки вси,L.
+474 Kay 18 10:56 AM N PALA BCH, PL
+475 Kay 18 10:54 MM Inconing
+478 May 18 11:00 AM W PALA BCH, PL
+477 Kay 18 11:01 AM Inconlng
+478 Kay 18 11:21 AM PILAUDERD, PL
+479 Key 18 11:50 AM N PALA BCH, PL
+430 кну 18 12:01 IM N FALE ПСИ, PL
+481 Kay 18 12:12 IM N PALA BCH, PL
+482 Kay 18 12:13 PM Inconing
+483 May 18 12:16 EM Inconing
+484 Kay 18 12:14 mM Inconing
+485 Kay 18 12:32 IM Inconing
+486 May 18 12:35 IM Inconing
+437 May 18 12138 FM Incondng
+488 Kay 18 12:50 IM N PALA BCH, PL
+430 Kay 18 01:31 PM N PALE BCH, PL
+400 Kay 18 01.33 EM Inconing
+491 Kay 18 01:57 PM 7 FALL NCH, PL
+492 Kay 18 01:58 IM N PALA BCH, PL
+493 May 18 02:22 PM N PALA BCH, PL
+494 May 18 02:45 PM Incondng
+485 Киу 18 03:01 тм
+490 Кау 18 03:19 #м
+Inconing
+497 Kay 18 03,19 EM
+N PALM BCH, PL
+490 Кну 18 03:25
+I N FALK ACH, PL
+499 Kay 18 03:34 IM
+500 May 18 03:35
+501 May 18 04:43
+502 кму 18 04:51
+Incoming
+DEERPLORCH, PL
+Inconing
+Inconing
+Min: Sec
+561-474-4148 PP/CH
+561-324-1491 PD
+561-642-0101 FF
+561-369-3694 PP
+561-718-4005 FD
+561-324-1491 PD/CN
+561-793-1712 FP
+561-723-3440 PP
+561-795-3549 FE
+561-718-4005 FF
+561-478-4184
+PP
+361-369-3696 FF
+561-281-6849 P8
+561-261-6549 PR
+561-252-4654
+561-644-4949
+PP
+561-791-4482
+561-478-4188
+PP
+561-715-7144
+561-202-9497 PP
+561-472-2683 FD
+561-856-6967 00
+561-969-3698 FP/CH
+561-956-6967 PP
+561-478-4188 PP
+561-542-1964 Pe
+561-502-5123 PP
+561-795-2543 FE
+561-793-1712 PD
+561-969-6660
+561-202-8497
+FF
+561-714-9915
+361-478-4188 FF
+561-478-4188 P0
+954-650-9306 PP
+561-474-4144 PP
+561-439-2398 FF
+Usage
+2100
+1:00
+1:00
+2:00
+2:00
+1:00
+1:00
+1,00
+1:00
+1100
+1,00
+2:00
+1:00
+1:00
+1,00
+1:00
+21O0
+1,00
+3:00
+3: 00
+2:00
+1,00
+2:00
+6:00
+3: 00
+3,00
+2:00
+3:00
+1,00
+1:00
+1:00
+3,00
+EEDO
+1:00
++: 00
+2:00
+1:00
+1:00
+4:00
+3:0D
+9.00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0. 00
+0.DD
+0.DD
+0,00
+0-O0
+Total
+Charges
+U .UU
+0.OO
+0,00
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+503 Kay 19 05:00 EM Inconing
+561-478-4188 FP
+6100
+504 Kay 14 05:08 PM PTLAUDERDL, PL
+954-444-6836
+2:00
+505 May 14 05:20 PM IncoRleg
+561-723-9450
+FP
+1:00
+508 May 19 05125 EM Inconing
+561-502-7753
+FP
+CEOU
+507 Kay 18 DE:19 IN INcoRleg
+361-202-0437
+1:00
+505 Kay 19 06:21 PM W PALK BCH, PL
+561-791-9809
+5:00
+509 Kay 14 06:54 PM I PALE BCH, PL
+561-434-9897
+FP
+2:00
+510 Kay 14 05,59 PM Inconing
+561-204-4558
+7,00
+511 Kay 14 07:07 IN M FALL BCH, FL
+561-352-7000
+SEOU
+512 Kay 19 07:15 PM M PALE BCH, PL
+561-662-6688
+FP
+3:00
+513 Kay 19 07,18 PM N PALA BCH, FL
+561-714-1523
+FP
+1:00
+514 Kay 18 07:19 IN M BALE BCH, FL
+561-798-2587
+4:00
+515 Kay 14 07:56 IM Inconieg
+561-722-0047
+3:00
+516 Kay 19 06:23 AN M BALK BCH, PL
+561-662-6688
+OP
+2:00
+517 Kay 19 07,14 AM Inconing
+561-541-5449
+PP
+2:00
+518 Kay 13 07:16 A M BALE BC, FL.
+561-616-8240
+1:00
+519 Kay 19 07:21 AM PILAUDERDL, PL.
+454-444-6MS6
+2:00
+520 Kay 19 07,24 JM Inconing
+5614242-6019
+PP
+1:00
+521 May 17 07:31 AN BOCA RATON, FL
+522 Kay 19 07:51 AM I PALK BCH, PL
+523 Kay 19 07:56 AM Inconing
+524 Кау 19 07,57 3М ВОСА RATON, FL
+525 KaY 17 DE:01 AN JUPITER, IL.
+526 Kay 19 08:10 AM DEERPLOBCH, PL
+527 Kay 19 08:12 AM DELAY BCH, PL
+528 May 19 08113 AM DELAY BCH, PL
+529 Kay 19 08:17 AM PILAUDERDL, PL
+530 Kay 19 08:20 AM M BALA BCH, PL
+531 Kay 19 08.33 AM FTLAUDERDG, FL
+532 Kay 19 08:37 3м IncoRleg
+561-718-9915
+561-827-2542
+561-393-7965
+561-747-2467
+954-428-6144
+561-278-2456
+561-276-5114
+954-444-6836
+561-585-4772
+954-444-6836
+561-252-4654
+FP
+FP
+PP
+1:00
+1:00
+1:00
+3:00
+2:00
+1:00
+2:00
+2:00
+3:00
+FP
+FP
+FP
+1:00
+1:00
+533 Kay 19 08:41 AM M PALK BCH, PL
+561-827-2542
+1:00
+534 Kay 19 08:42 AM Inconteg
+561-252-4654
+PP/CW
+535 Kay 19 08:43 AM Inconleg
+561-202-8497
+536 Kay 17 02:07 AN M PALE BCH, PL
+SE-470-4109
+2:00
+1:00
+1:00
+537 Kay 17 09:08 AN I BALK BCH, PL
+S6leiseeTu0dl
+PP
+538 May 19 09,13 AM Inconleg
+539 Kay 17 08:26 AL M FAIL BCH, FL
+540 Kay 19 09:29 AM I PALK BCH, PL
+541 May 19 09:31 1M Inconleg
+542 Кау 19 09,34 3М JUPIE, FL.
+543 Kay 19 09:46 A M PALAC BCH, FL
+561-541-4023
+561-722-0047
+561-718-1592
+561-541-4051
+561-741-8200
+561-58G-6011
+30I00
+FF
+1: 00
+1:00
+FP
+FP
+FF
+3:00
+2:00
+4:00
+Usage
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+0000
+D.D0
+D.D0
+0.00|
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time
+Call To
+544 May 19 09,51 AM W PALA BCH, PL
+545 Kay 19 10:14 AM PILAUDERDG, PL
+546 May 19 10:15 AM Inconing
+547 May 1910,50 AM PILAUDERD, PL
+548 Кку 12 10:53 ли и кАи вси, PL
+549 Kay 19 10:55 AM N PALE BCH, PL
+550 Kay 19 11:05 AM N PALE BCH,PL
+551 May 19 11123 AM Inconing
+552Киу 13 11:31 AM Inconing
+553 Kay 19 11:53 AM Inconing
+554 May 19 11/58 AM Inconing
+556 Kay 19 12:16 I Inconing
+557 Kay 19 12:40 PM JUPITER, PL
+558 Kay 19 01:02 EM Inconing
+530 Kay 13 01:10 IN BALANCH, PL
+380 Kay 19 01:13 m
+Incoming
+561 Key 19 01121 EM JUPITER, FL
+582 Kay 13 01:51 IN SALE #CH, PL
+503 Kay 19 02:10 I Incoming
+504 May 19 00:15 PM W FACE BCH, PL
+505 Kay 19 03:00 EM I PALA BCH ,PL
+500 Kay 13 03:01 PM I FALE RCH, PL
+567 Kay 19 03:09 IM Inconing
+568 May 19 03:15 IM Inconing
+500 May 19 03,54 FM
+Inconing
+570 Kay 19 04:18 m
+Inconing
+571 Kay 19 04:19 PM
+Inconing
+572 May 19 04:24 PM I PALM BCH,PL
+573 Kay 19 04:36 m
+Inconing
+574 Kay 19 06:12 IN BOYTONBCH, PL
+575 Kay 19 06:14 IM Inconing
+576 May 19 06139 PM N PALM BCH,PL
+577 Kay 19 06:50 PM 7 FALA RCH, PL
+578 May 19 07:02 m
+Inconing
+579 May 19 07.05 EM Inconing
+580 Kay 13 07:08
+IN FALK ACH, PL
+581 May 19 07:56 m
+InCORLET
+502 Кау 19 09:05
+Inconing
+583 May 20 06135 AM Incoming
+584Иму 20 06:37 AM I FALE NCH, PL
+Min: Sec
+561-352-7000 PP
+954-444-6836 PD
+561-448-4336 FF/CH
+954-791-4720 PP
+561-202-8497 FD
+561-641-9406 PP
+561-315-2500
+FF
+561-352-7000
+PP
+561-352-700D
+561-427-2542
+561-793-1712
+561-315-2500
+FF
+PP
+FF
+561-202-8497 P0
+561-747-2467
+561-502-3666
+561-502-3666
+561-747-2467
+PP/CH
+PP
+561-615-0011
+561-969-3698
+561-365-0976
+561-942-2464 PP
+561-842-6414 FD
+561-436-4739 00
+561-969-3698
+FF
+561-502-5212
+PP
+561-718-1592
+PP
+561-472-2834
+FF
+561-942-5414 PP
+561-422-1200 FE
+561-577-6425 PP
+561-502-5212 PP
+561-662-6684 PP
+561-802-3501 FF
+561-365-0976 PP/CH
+561-662-6813 PP
+361-644-4982 FF
+561-964-5511 PD
+561-723-3440 PP
+561-502-5212 OP
+561-662-6488 CE
+Usage
+2100
+1:00
+2:00
+2:00
+3:00
+2:00
+1:00
++: 00
+2:00
+2:00
+1,00
+1:00
+1:00
+2:00
+2:00
+4:00
+51 00
+2,00
+2:00
+4: 00
+1:00
+1,00
+2:00
+5:00
+2: 00
+1,00
+1:00
+6:00
+2,00
+4: 00
+2:00
+2:00
+11,00
+3:00
+2,00
+45:00
+3:00
+25:00
+3,00
+2:00
+9.00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0. 00
+0.0D
+0.DD
+0,00
+Total
+Charges
+U .UU
+0.OO
+0,00
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+585 Kay 20 06157 1М Inconing
+561-242-6019 OP
+2100
+505 Kay 20 07:16 AM Incoming
+561-722-0047
+2:00
+587 May 20 07:21 AM I PALE BCH, PL
+561-434-4440
+FP
+2:00
+585 May 20 07,30 AM I PALA BCH, PL
+561-723-9450
+FP
+CEOU
+589 кку 20 07:33 ЛИ М РАДЕ ВСП, РС.
+561-476-1190
+590 Kay 20 07:57 AM Incoming
+561-502-7753
+2:00
+591 Kay 20 08:10 AN Inconleg
+561-687-8716
+FP
+2:00
+592 Kay 20 08113 1M Inconing
+561-502-7753
+3:00
+593 Kay 20 08:25 A DELILDECH, FL
+954-428-6144
+1:00
+504 Kay 20 08:59 AM Inconleg
+561-352-7000
+FP
+2:00
+505 Kay 20 09/03 AM Inconleg
+561-422-1200
+FP
+27,00
+595 Kay 20 03:21 1/ Incoaleg
+561-502-3866
+FP/CN
+1:00
+597 Kay 20 09:23 2M Inconieg
+561-723-3440
+1:00
+505 Kay 20 09:48 AН M BALK BCH, PL
+561-502-3866
+FP
+1:00
+500 Kay 20 09,49 AM M BALK BCH, FL
+561-728-1440
+PP
+6:00
+000 Kay 20 03:55 A INceleg
+561-502-3866
+1:00
+001 Pay
+20
+Incoeing
+S61-6ME-4H77
+2:00
+802 Kay 20 10/01 AM I PALA BCH, FL
+5614255-1725
+PP
+2:00
+603 кку
+604 Kay 20 10:30 AM Incoming
+005 Kay
+20 12:23 AM M BALE BCH, PL
+005 Kay 20 12:16 PM M BALK BCH, FL
+007 Kay 20 12:16 IN M PALE BCH, FL
+605 Kay 20 12:17 IN Incoming
+609 Kay 20 12:16 IN M BAL BCH, PL
+810 May 20 12:20 PM M BAIR BCH, PL
+611 Kay 20 12:22 IN M PALK BCH, PL
+812 Kay 20 12:38 PM M BALE BCH, PL
+813 Kay 20 12,41 EN Inconleg
+814 Kay 20 01:13 IN INcoRLeg
+561-951-4819
+561-478-4188
+561-502-3866
+561-502-5212
+561-845-0562
+561-502-5212
+561-845-0562
+561-502-3866
+561-845-0562
+561-502-5212
+561-845-0667
+561-385-7513
+1:00
+FP
+FP
+PP
+FP
+FP
+1:00
+2:00
+2:00
+2:00
+2:00
+6:00
+3:00
+7,00
+2:00
+615 Kay 20 01:35 IN Inconieg
+561-723-9450
+3:00
+816 Kay 20 01:38 PM M BALE BCH, PL
+1:00
+817 May 20 01,39 PM M BALK BCH, PL
+561-502-5212
+PP
+818 кку 20
+563-684-1332
+1,00
+2:00
+819 Kay 20 01:53 PM I BALK BCH, PL
+S61-SH2-16s
+FP
+820 May 20 02:03 EM N BALA BCH,FL
+4:00
+1:00
+821 May 20 02:01 m Incaleg
+822 Kay 20 02:06 IM I PALK BCH, PL
+823 Kay 20 02:07 PM M PALE BCH, PL
+824 May 20 02,12 PM Inconing
+825 Kay 20 02:15 IN M FALK BCH, PL
+561-627-0400
+561-502-5212
+561-627-0200|
+561-627-0400
+561-502-7753
+561-832-2552
+FF
+JE0O
+FP
+FP
+FF
+1:00
+1:00
+2:00
+2:00
+Usage
+•.00
+6.00
+6.00
+0.0D
+•.00
+6.00
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0.00|
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+828 May 20 02:16 EM NPALM BCH, PL
+627 Kay 20 02:17 IM N PALA BCH, PL
+828 May 20 02:19 PM PALE RCH, PL
+829 My 20 03:01 IM NPALM BCH,PL
+830 Kay 20 03:03
+IN FALA BCH, PL
+031 May 20 03:03 I Inconing
+832 Kay 20 03:07 PM Inconing
+833 May 20 03:09 EM N PALM BCH,PL
+835 Kay 20 03:45 PM
+Inconing
+836 May 20 03:47 FM
+W PALA BCH,PL
+837 кау 20 03:43
+m Inconing
+038 Kay 20 04:07 IM Inconing
+830 Kay 2004:09 PM MILHAUKKE,WI
+640 May 20 04:22 EM BOCA RATON, PL
+641 Kay 20 04:38 m Inconing
+042 Kay 20 04:47 IM N PALA BCH, PL
+843 May 20 05:53 #M Inconing
+644 Kay 20 05:58 mN BALANCH, PL
+645 Kay 20 05:59
+W PALM BCH, PL
+646 May 20 06:04 PM N FALK BCH, PL
+847 May 20 06:10 EM N PALM BCH, PL
+648 Kay 20 06:11 PM Inconing
+G49 Kay 20 06:53 IM Incoming
+850 May 20 07:58 #M BOTONBCH, PL
+851 May 20 07,59 PM
+Inconing
+052 Kay 20 08:44 m
+Inconing
+053 Kay 20 09:20 m
+Inconing
+854 May 21 06:40 AM I PALM BCH, PL
+855 Киу 21 06:43 ЛИ N FAL2 #CH, PL
+056 Kay 21 06:50 AM BOCA RATON, PL
+857 May 21 07:11 AM N PALE BCH, PL
+058 May 21 07:27 AM Inconing
+850 Кку 21 07:43 ли к FAL2 RCH,PL.
+060 Kay 21 07:46 AMN FALK BCH, PL
+081 May 21 09.05 AM Inconing
+082 Иму 21
+08:03 AM Inconing
+053 Kay 21 08:16 AM N PALA BCH, PL
+054 May 21 09:17 лм
+085 May 21 09:34 1M Incoming
+056 Kay 21 08:27 AM Inconlng
+Min: Sec
+561-357-2904 PP
+561-191-5020 PP
+561-625-0216 FF
+561-722-0047 PP
+361-8C8-3479 FD
+561-478-4188 PD/CN
+561-357-2904 FP/CN
+561-502-7753 PP
+561-377-6425 FE
+561-718-3592 FF
+561-478-4188 PP
+Unava 11 able
+FF
+561-541-5449 PP
+414-328-8003
+561-393-7914
+561-965-0976
+PP
+361-385-4772
+561-644-4989
+PP
+561-644-4959
+561-644-4949
+PP
+561-302-3212 FD
+561-541-5449
+561-503-5936
+561-655-4230
+561-503-8429
+FF
+PP
+PP
+561-502-5212
+561-615-0011
+561-434-4440
+561-393-7965
+561-842-1454
+561-577-6286
+PP
+561-474-9590
+FF
+561-827-2542
+361-721-3212
+FF
+561-842-6414
+PP
+954-444-6836 PP
+561-502-7753 PP
+561-341-4051 FF
+Usage
+1100
+1:00
+4:00
+2:00
+1:00
+5:00
+1:00
++: 00
+1:00
+2:00
+1,00
+2:00
+2:00
+1:00
+1,00
+21 DO
+51 00
+1,00
+1:00
+1:00
+1:00
+1,00
+2:00
+6:00
+1:00
+1,00
+2:00
+1:00
+1,00
+1:00
+1:00
+1:00
+1,00
+2:00
+2,00
+5:00
+2:00
+2:00
+2,00
+2:00
+9.00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0. 00
+0.DD
+0.DD
+0,00
+Total
+Charges
+U .UU
+0.OO
+0,00
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+087 Kay 21 08:42 AM Inconing
+561-352-7000 FP
+2100
+055 Kay 21 08:46 AM I PALA BCH, PL
+561-582-1964
+1:00
+860 Kay 23 08:46 AM I PALE BCH, PL
+561-582-1964
+FP
+6:00
+870 May 21 08:53 AM I PALA BCH, PL
+561-352-7000
+FP
+871 Kay 21 09:15 A Incoelag
+561-502-5212
+1:00
+672 Kay 21 09:29 AM Incoming
+561-502-5212
+1:00
+873 Kay 21 10:04 AN Inconleg
+561-202-8497
+FP
+1:00
+874 Kay 21 10:05 1M Inconing
+561-502-5212
+PP/CW
+1,00
+875 Kay 21 10:0E AN ITLAUDEAD, FL
+954-444-6836
+FF
+1:00
+876 Kay 21 10:07 AM M PALE BCH, PL
+561-502-5212
+PP
+1:00
+877 Kay 21 10/11 AM Inconleg
+561-202-8497
+FP
+1:00
+678 кку 21 10:12 ЛИ М BALE ВСТ, FL.
+561-236-6852
+3:00
+679 Kay 21 10:21 2M Inconieg
+561-202-8497
+1:00
+880 Kay 21 11:08 1М Inconleg
+881 Kay 21 11,09 АМ ВОСА RATON, FL.
+561-202-8497
+561-393-7965
+PP
+1:00
+1:00
+882 кку 21 11:25 Л М FAL ВСП, FL.
+561-478-4188
+683 Kay 21 11:33 AM Incoming
+561-202-8447
+2:00
+1:00
+884 Kay 21 11,49 AM I PALA BCH, FL
+561-820-1949
+PP
+4:00
+655 кку 21 11:54 ЛИ ВОТЛОНОСИ, Г.
+685 Kay 21 11:55 AM BOYTONBCH, PL
+887 Kay
+21 12:08 PM M BALE BCH, PL
+885 May 21 12/11 EM I BALK BCH, PL
+689 ay 21 12:16 IN M PALE BCH, FL.
+680 Kay 21 12:18 IM BOCA RATON, PL
+891 May 21 12:22 IN M BALE BCH, PL
+892 Kay 21 12127 PM Inconing
+693 May 21 12:37 IN M PALK BCH, PL
+894 Kay 21 12:57 EM Incontag
+005 Kay 2112,58 PM FTLAUDERDG,PL
+561-577-6425
+561-577-6425
+561-502-3866
+561-541-4023
+561-628-5129
+561-368-3326
+561-352-7000
+561-502-5212
+561-478-1190
+561-502-5212
+954-444-6836
+561-502-5212
+PP/NS
+FP
+PP
+FP
+FP
+FP
+2: 00
+1:00
+1:00
+2:00
+4:00
+2:00
+2:00
+2:00
+2:00
+5:00
+3:00
+1:00
+1:00
+2:00
+2:00
+1:00
+1: 00
+1:00
+2:00
+$:00
+1:00
+•.00
+6.00
+6.00
+0.0D
+•.00
+6.00
+097 Kay 21 01:06 IN Inconieg
+895 May 21 01:06 IM M PALE BCH, PL
+900 May 21 01/15 PM Inconleg
+700 Kay 21 01:17 PM M PALA RCH, FL
+701 Kay 21 01:20 EN Incoming
+702 May 21 01122 EM Inconing
+703 Kay 21 01:59 IN BOTTONICH, FL
+704 Kay 21 02:00 IM BOYTONCH, PL.
+705 Kay 21 02:03 PM M PALE BCH, PL
+708 May 21 02:04 EM Inconing
+707 Kay 21 02:19 PM Inconleg
+954-444-6836
+561-502-5212
+561-502-5212
+PP
+S61-502-521
+S61-772
+PP
+561-503-5930
+561-577-6425
+561-503-5930
+561-502-5212
+561-541-4023
+561-202-8497
+FF
+FP
+FP
+FF
+Usage
+6.00
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date
+Time
+Call To
+Number
+Footnote
+708 May 21 02135 EM BOCA RATON, PL
+561-305-1272 PP
+709 Kay 21 02:42 IM Inconing
+561-502-5212 PP
+710 Kay 21 02:52 PM Inconing
+561-756-2813 FF
+711 May 21 03:02 #M Inconing
+561-502-5212 PP
+712 May 2103:04 ALEC, PL
+561-302-306E FD
+713 Kay 21 03:04 IN N PALE BCH, PL
+561-502-3666 PP
+714 Kay 21 03:11 PM Inconing
+561-502-5212
+FF
+715 May 21 03114 IM Inconing
+561-577-6425 PP
+716 Kay 21 03:21 I Inconing
+561-644-4989 FE
+717 Kay 21 03:24 PM Inconing
+561-844-6600 FF
+718 Kay 21 64:16 EM Inconing
+561-753-0656
+PP
+719 Kay 2104:20 7 BALANCH, PL
+561-202-8497 FF
+720 Kay 21 04:21 IN PALA BCH, PL.
+561-478-4168 P0
+721 Kay 21 04:24 PM N PALE BCH, PL
+561-582-1964 PR
+722 May 21 04.31 PM Incondag
+954-444-6836
+723 Kay 21 04:32 m Inconlng
+724 Kay 21 04:34 IM N PALA BCH, PL
+725 Kay 21 04.35 #M Inconing
+720 a 2105:08122 C,PL
+727 Kay 21 05:09 IM N PALA BCH, PL
+728 Kay 21 05:12 PM N FACE BCH, PL
+729 May 21 05:14 EM BOXTONBCH ,PU
+730 Kay 21 05:16 PM Inconing
+731 Kay 21 05:18 IM N PALE BCH, PL
+732 Kay 21 05:22 IM Inconing
+733 May 21 05:23 PM
+Incordng
+734 Kay 21 05:27 m
+Inconing
+735 Kay 21 05:56 PM
+N PALE RCH, PL
+736 May 21 06,36 PM
+Inconing
+737 Иму 21 07:13 гн
+Inconing
+738 Kay 21 07:14 IN PALA BCH, PL
+730 Kay 21 07:22 PM N PALE BCH, PL
+561-502-5212
+PP/CH
+561-478-4188
+561-478-4188
+PP
+561-663-1816
+561-577-6425
+PP
+561-478-4188 FD
+561-478-4168
+561-644-4989
+FF
+561-502-5212
+PP
+561-723-3440
+PP
+561-474-4148
+FF
+561-502-7753
+PP
+561-202-8497
+561-802-3501
+PD
+561-964-5512
+740 May 21 07:23 PM N PALM BCH,PL
+561-927-2542
+741 Kay 21 07:50 m
+Inconing
+742 Kay 21 09:14 PM N FALK BCH, PL
+743 May 21 09115 IM Inconing
+744 Кну 21
+08:45
+™ Inconing
+745 Kay 21 08:47 IN N PALA BCH, PL
+748 Кау 22
+07:21
+747 May 22 07123 AM Inconing
+561-427-2542
+FF
+561-722-1628
+361-302-3212
+FF
+561-502-5212
+PD
+954-792-3480 CE
+561-502-7753 C8
+561-302-1753 CE
+Min: Sec
+7,00
+4:00
+6:00
+1,00
+1:00
+1:00
+3:00
++: 00
+2:00
+1100
+2:00
+1:00
+2:00
+5:00
+2:00
+21 DO
+21O0
+5,00
+1:00
+2:00
+2:00
+1,00
+1:00
+2:00
+1:00
+1,00
+5:00
+2:00
+3,00
+2:00
+6:00
+1:00
+1,00
+2:00
+5,00
+1:00
+1:00
+1:00
+4:00
+1:00
+Usage
+9.00
+Long
+Distance
+0.0D
+B.DD
+0.0D
+B. DD
+0.0D
+0.DD
+0.DD
+0,00
+0-O0
+Total
+Charges
+U .UU
+0.OO
+0.0D
+0,00
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time
+Call To
+740 Kay 27 07,41 AM I BALK BCH, FL
+750 Kay 22 07:43 AM Incoming
+751 May 22 07:46 AM Incoming
+752 May 22 08.01 AM FTLADERDG, FL
+753 кау 22 08:40 ЛА УТІЛОВИАРС, РС
+754 Kay 22 08:49 AM M PALK BCH, PL
+755 Kay 22 09:00 AN Incoming
+750 May 2209,01 AM BOTTONCH, FL
+757 Kay 22 08:03 A ITALIAD, FL
+758 Kay 22 09:08 JМ Inconleg
+750 Kay 22 09,17 AM BOYTONCH, FL.
+700 кку 22 03:23 мм Incoeleg
+761 Kay 22 09:24 2M BOYTONBCH, PL
+762 Kay 22 09:33 1М Inconleg
+783 Kay 22 09,57 AM Inconing
+754 Kay 22 10:21 AN Incaleg
+765 Кку 22 10:35 A M DALK BCH, PL.
+768 Kay 22 10,37 AM M PALA BCH, FL
+767 Kay 22 11:32 A Incoeleg
+765 Kay 22 11:34 AM BOYNCH, PL
+780 Кау 2а 11:34 АМ М ВАЦА ВСН, PL
+770 Kay 22 11:43 AM M BALK BCH, PL
+771 Kay 22 12:11 IN Incoalag
+772 Kay 22 12:12 PM M PALK BCH, PL
+773 Kay 22 01:11 IN Incoming
+774 May 22 02:14 PM M BAIR BCH, PL
+775 Kay 22 02:37 IN Inconied
+776 Kay 22 04:43 PM Inconteg
+777 Kay 22 04:46 PM W BALK BCH, FL
+778 Kay 22 06:46 PM INcoRLeg
+779 Kay 22 06:02 IN Inconieg
+780 Kay 22 06:14 PM Inconteg
+781 Kay 22 07,19 PM Inconleg
+782 Kay 22 07:30 aN Incoeleg
+783 Kay 22 08:02 FM Incoming
+784 May 22 08,39 EM BOYTONBCH, FL.
+755 Kay 21 10:35 A Incaleg
+785 Kay 23 11:02 AM Inconieg
+787 Kay 23 12:04 1М Inconleg
+788 May 23 11:22 M Inconing
+789 Kay 21 12:40 HE M PALE BCH, PL
+Min: Sec
+561-547-2415 0P
+561-667-4222 OP
+561-667-4222 OP
+954-792-3880
+954-792-3880
+OP
+561-502-5212
+OP
+561-502-5212
+OP
+561-577-6425
+954-444-6836
+OF
+561-577-6425
+OP
+561-577-5425
+OP
+561-577-6425
+OF
+561-577-6425
+OP
+561-502-5212
+OP
+561-762-2874
+OP
+561-202-8497
+561-964-3555
+561-964-5511|
+561-577-6425
+561-577-6425
+561-790-1111
+561-352-7000
+561-856-6967
+561-856-6967
+561-394-8434
+561-502-5212
+561-667-4222
+561-541-5449
+OP
+OP
+OP
+OP
+OP
+OP
+OP
+561-662-6688
+561-502-5212
+561-502-5212
+561-502-5212
+OP
+561-965-0976
+OP
+5E1-0ES-0976
+OP
+561-577-6425
+954-444-6836
+OF
+561-502-3866
+561-827-2542
+OP
+561-951-4819 OP
+561-793-6889
+OF
+Usage
+2100
+1:00
+1:00
+CEOU
+10:00
+1:00
+1:00
+1,00
+1:00
+2:00
+1:00
+1:00
+1:00
+2:00
+2100
+2:00
+2:00
+1:00
+3:00
+4:00
+1:00
+2:00
+3:00
+3,00
+2:00
+3:00
+2:00
+8:00
+2:00
+1:00
+7:00
+T:00
+1:00
+1:00
+3: 00
+2:00
+3:00
+2:00
+1:00
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+0000
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date
+Time
+Call To
+790 May 23 01:45 EM W PALM BCH, PL
+791 Kay 23 01:46 IM Inconing
+792 Kay 23 01:50 PM I PALES BCH, PL
+793 May 23 02115 IM BOYTONBCH, PO
+794 Kay 23 02:20 m Inconing
+78G May 23 62:35 M Incoming
+796 Kay 23 02:34 PM Inconing
+797 May 23 05+15 FM I PALA BCH,PL
+Number
+Footnote
+561-662-664408
+561-827-2542 00/CN
+561-662-6688 OF
+561-577-6425 OP
+561-302-3212 CE
+561-577-642500
+561-577-6425
+561-662-6648 0P
+561-502-3212
+DE
+790 Kay 23 05121 PM N PALE BCH, PL
+800 May 23 05131 FM BOXTONBCH, PL
+801 Kay 23 09:40 m Inconing
+802 Kay 23 06:59 I Inconing
+8C3 Kay 23 07:00 #M Inconing
+804 Kay 23 07.28 FM NPALA BCH, PL
+561-662-3098
+OF
+561-577-6425
+561-367-044308
+561-856-4306 00
+561-456-430€
+ce
+561-856-7469
+B0G Kay 23 09:06 IN
+Inconing
+807 May 23 09,54 EM NPALE BCH, PL
+808 Kay 23 08:36 I Inconing
+809 Kay 23 08:59 IM N PALA BCH, PL
+810 Kay 23 09:13 PM Inconing
+811 May 24 06:43 AM Inconing |
+812 May 2406:4510 Inconing
+813 Kay 24 06:48 AM Incoming
+814 Kay 24 06:51 AM N FALK BCH, PL
+815 May 24 06:52 AM N PALM BCH, PL
+816 Kay 24 06:54 AM N PALA BCH, PL
+817 Kay 24 07:01 AM Inconing
+818 May 24 07,09 AM I PALM BCH, PL
+819 Kay 24 07:17 AM 7 BALA RCH, PL
+820 Kay 24 07:18 AM N PALA BCH, PL
+821 May 24 07:21 AM N PALA BCH, PL
+822 May 24 07:21 AM N PALM BCH,PL
+823 кму 24 07:40 мм
+Inconing
+824 Kay 24 07:51 AM BOYTONBCH, PL
+825 May 24 07,56 AM Inconing
+826 Kay 24 08:00 aM Inconing
+827 Kay 24 C8:06 AM Incoming
+820 Kay 24 09:07
+N PALE BCH, PL
+829 May 24 09:091
+Inconing
+830 кну 24 08:18 лм
+Inconing
+Min: Sec
+Usage
+561-856-430E
+561-456-4306
+561-302-3123
+561-502-3666
+561-456-4306
+ce
+561-502-5123
+561-302-3212 OF
+561-615-0011
+561-615-0011
+561-615-0011
+561-502-5123
+561-723-3440
+561-615-0011
+FF
+PP
+561-689-765E
+561-615-0011
+PP
+561-502-3866
+561-478-7760
+PP
+561-577-6425
+FP
+561-762-2874
+254-444-6836
+FF
+561-577-6425
+PP
+561-615-0011 PP
+561-647-4791 PP
+561-202-8497 FF
+2100
+4:00
+10:00
+1,00
+3:00
+2:00
+1:00
+3,00
+2:00
+2:00
+1,00
+1:00
+1:00
+4: 00
+2:00
+51 00
+1,00
+2:00
+2:00
+3:00
+2,00
+3: 00
+2:00
+1:00
+2100
+3: 00
+5:00
+2,00
+1:00
+2:00
+1:00
+1,00
+21 DO
+3:00
+3,00
+1:00
+1:00
+2:00
+1,00
+1:00
+9.00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0.DD
+0.DD
+0,00
+Total
+Charges
+U .UU
+0.OO
+0,00
+
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time
+Call To
+831 Kay 24 08.19 A M BALK BCH, FL
+832 Kay 24 08:27 AM M PALA BCH, PL
+833 Kay 24 08:28 AM I PALE BCH, PL
+834 May 24 08130 AM Inconing
+835 кку 24 08:32 Н M FAL BCH, FL
+836 Kay 24 08:33 AM M PAL BCH, PL
+837 Kay 24 08:35 AN Inconleg
+838 May 24 08,39 3M M BALA BCH, PG
+839 Kay 24 08:40 AN ITLADEAD, FL
+840 Кау 24 08:56 АМ ВОСА КАТОМ, РС.
+841 Kay 24 09/02 AM M PALA BCH, FL
+842 кку 24 03:07 лм Incoeleg
+843 Kay 24 09:08 AM I PALK BCH, PL
+844 Kay 24 09:10 1М Inconleg
+845 Kay 24 09,15 JМ Inconing
+846 Kay 24 03:22 AN M FALA BCH, FL.
+847 Kay 24 09:26 AM I DALK BCH, PL
+848 Kay 24 09,26 JM Incoming
+849 Kay 24 09:30 At Incoeleg
+850 Kay 24 09:33 AM Incoming
+851 May 24 10:06 1M Inconteg
+852 Kay 24 10:10 AM I BALK BC, PL
+853 Kay 24 10:19 AN Incoalag
+854 Kay 24 10:21 AM Incoming
+855 Kay 24 10:27 1М Inconleg
+856 Kay 24 10141 1M Inconing
+857 Kay 24 10:43 JM Inconieg
+858 Ka 24 10:44 AM M BALAS BCH, PL
+850 Kay 24 11,36 AN Inconleg
+850кку 24 12:06 IN M BALL BCH, FL.
+861 Kay 24 12:07 IN Inconieg
+062 Ka 24 12:09 PM M BALL BCH, PL
+883 May 24 12117 PM Inconleg
+854 Kay 24 12:22 PM Inconleg
+085 Kay 24 12:32 EM Incoming
+806 May 24 12,50 EM Inconleg
+887 May 2412:54 mIscaleg
+B6S Kay 24 12:55 IM M PALK BCH, PL
+089 Kay 24 02:06 PM Inconleg
+870 May 24 01/24 PM Incoming
+871 Kay 24 01:25 PM M FALK BCH, FL
+561-793-6029 FP
+561-793-6029
+561-236-6852
+561-333-7258
+FP
+FP
+561-620÷3343
+561-820-6023
+561-790-6483
+561-795-9549
+954-444-6836
+561-305-1272
+561-615-0011
+561-577-6425
+561-964-3228
+561-964-3358
+561-577-6425
+561-541-4051
+561-502-3866
+561-577-6425
+561-255-1015
+561-329-0783
+561-721-1940
+561-202-8437
+561-202-8497
+561-202-8497
+561-650-8149
+561-650-8149
+561-478-4188
+561-722-0047
+561-856-6967
+561-202-8497
+561-502-5212
+561-478-4188
+561-202-8497
+561-478-4188
+561-863-7783
+561-202-8497
+561-478-6188
+FP
+PP
+FP
+FP
+PP
+FP
+FP
+FP
+FP
+PP
+FP
+FP
+FP
+FP
+FF
+Min: Sec
+8:00
+2:00
+2:00
+CEOU
+1:00
+1:00
+2:00
+2:00
+1:00
+2:00
+1:00
+2:00
+3:00
+1:00
+1:00
+2:00
+1:00
+3:00
+7:00
+5:00
+2:00
+1:00
+1:00
+1:00
+1,00
+1:00
+2:00
+1:00
+1:00
+1:00
+3:00
+3:00
+5:00
+1:00
+5100
+1: 00
+1:00
+1:00
+1:00
+2:00
+Usage
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+0000
+D.D0
+D.D0
+0.00|
+0,00
+D.00
+D.00
+D.D0
+continued..
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date
+Time
+Call To
+Number
+Footnote
+872 May 24 01.27 EM Inconing
+561-202-9497 PP
+873 Kay 24 01:28 IM N PALA BCH, PL
+561-848-9770 PP
+874 May 24 01:33 PM Inconing
+561-502-3666 FF
+875 May 24 01134 #M Inconing
+561-577-6425 PP
+876 Kay 24 01:41 IN Inconing
+361-302-36CE FD
+877 Kay 24 01:42 IN N PALA BCH, PL
+561-502-5212 PP
+878 Kay 24 01:43 I Inconing
+561-502-3666
+FF
+879 May 24 01151 EM Inconing
+561-502-5212 PP
+880 Kay 24 02:03 I Inconing
+561-848-4337 FE
+681 Kay 24 02123 PM Inconing
+561-715-7144 FP
+882 May 24 02133 PM Inconing
+561-202-9497 PP
+B83 ay 24 02:64 m Inconing
+361-302-38CE FF
+884 Kay 24 09:05 IM N PALA BCH, PL
+561-795-9549 P8
+885 Kay 24 03:06 PM N PALE BCH, PL
+561-502-3666
+886 Kay 24 03:29 FM W PALA BCH, PL
+887 иму 24 03:33 т
+Inconing
+888 Kay 24 03:35 IM N PALA BCH, PL
+880 May 24 03:46 EM W PALA BCH, PL
+890 Ka 24 03:48 W N SAL/ BCH, PL
+891 May 24 04:12 IM W PALM BCH ,PL
+892 May 24 04:13 PM
+893 Kay 24 04:14 EM 1 PALM BCH ,PL
+894 Kay 24 04:21 PM N FAL/ RCH, PL
+880 Kay 24 05:59 IM W PALA BCH, PL
+896 Kay 24 06:08 #
+897 May 24 06:13 EM
+Incordng
+89B Kay 24 06:26 IM
+N PALA BCH, PL
+890 Kay 24 06:27 m
+W PALE BCH, PL
+900 May 24 06:46 PM W PALM BCH, PL
+901 Иму 24 07:10 #
+561-433-4634
+PP
+361-E62-8C8E
+561-478-4188
+PP
+561-202-2497
+561-948-9770
+PP
+561-478-4188 FD
+561-502-3666 P0
+561-541-5449 PP
+561-722-0047
+pP/CH
+561-502-3866
+PP
+561-474-7760
+561-616-9240
+PP
+561-385-1005
+902 Kay 24 07:19 I Inconing
+561-723-3440
+PD
+903 Kay 25 07:09 M Inconing
+904 May 25 07:16 AM NPALM BCH,PL
+561-434-9897
+905 кку 25 07:18 ли к кAL2 RCH,L.
+906 Kay 25 07:31 AM Inconing
+907 May 25 07.57 AM Inconing
+908 Kay 25 08:00
+Inconing
+909 Kay 25 08:01 AM
+Inconing
+910 Kay 25 04:07
+N PALE BCH, PL
+911 May 2509:44 1
+W PALM BCH,PL
+FF
+561-444-9770
+FF
+561-650-8149 PP
+361-722-0047 FF
+561-848-9770 00/CH
+561-255-4144 PP
+561-502-7753 PP
+561-302-1753 FF
+Min: Sec
+1100
+1:00
+2:00
+2:00
+1:00
+1:00
+1:00
+3,00
+2:00
+3:00
+1,00
+5: 00
+1:00
+2:00
+3,00
+1:00
+51 00
+2,00
+7:00
+2:00
+1:00
+5:00
+3: 00
+1:00
+5:00
+6:00
+1:00
+1:00
+2,00
+1:00
+4: 00
+1:00
+2100
+2:00
+1,00
+2:00
+6: 00
+2:00
+3,00
+1:00
+Usage
+9.00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0. 00
+0.DD
+0.DD
+0,00
+0-O0
+Total
+Charges
+U .UU
+0.OO
+0.0D
+0,00
+
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time
+Call To
+913 May 25 09,09 M Inconing
+814 Kay 25 09:11 AM I PALA BCH, PL
+915 Kay 25 09:14 AM I PALE BCH, PL
+916 May 25 09,16 AM Inconing
+917кау 25 09:17 M PAL BCH, FL.
+818 Kay 25 09:18 AM I PALK BCH, PL
+919 Kay 25 09:21 AN I PALE BCH, PL
+920 May 25 09,22 3M M BAIN BCH, FL
+921 Kay 25 08:24 A M PALE BCH, FL
+922 Kay 25 09:26 AM M PALE BCH, PL
+023 May 25 09/28 AM M PALA BCH, FL
+825 Kay 25 09:31 2M Inconieg
+828 Kay 25 09:33 AН M BALK BCH, PL
+927 May 25 09,35 JM
+Inconing
+928 кку 25 03:37 38
+Incoeleg
+B29 Kay
+25 09:45 20
+Incoeing
+930 Kay 25 09:47 AM ORLANDO, FL.
+931 Kay 25 09:47 A M PALE BCS, FL
+932 Kay 25 09:49 AM M PALK BCH, PL
+933 Kay
+25 09:52 AM M BALE BCH, PL
+934 Kay 25 09,56 AM ORLANDO, FL.
+935кау 25 10:02 3Н M PAL BCH, FL.
+835 Kay 25 10:08 AM Incoming
+837 Kay 25 10:11 1M Inconleg
+935 May 25 10:12 3M M BAIR BCH, PL
+839 Kay 25 10:13 1M Inconieg
+940 Кау 25 10:17 АМ М ВАЦК ВСН, PL
+041 Kay 25 10,18 AM Inconleg
+942 Kay 25 10:26 AM Incaleg
+943 Kay 25 10:28 AM M PALK BCH, PL
+944 Kay 25 10:32 AM M BALE BCH, PL
+045 May 25 10,40 AM Inconleg
+948 kay 25 10:50 AN Incceleg|
+947 Kay 25 10:56 AM Inconing
+043 May 25 11:00 AM M BALK BCH, FL
+949 May 25 11:01 AM MALIGAN, IL
+950 Kay 25 11:19 AM Incoming
+951 May 25 12:20 AM DELAY BCH, PL
+052 May 25 11,26 Inconing
+953кку 25 11:38 3Н M FALK BCH, FL
+Min: Sec
+561-723-3440
+PP/CW
+561-478-4188
+561-502-2634
+561-662-6616
+FP
+FP/CW
+561-502-7753
+561-688-0400
+561-541-4051
+561-723-3440
+561-502-7753
+561-795-9549
+561-723-1821
+FP
+FP
+FF
+PP
+FP
+561-964-5511
+561-577-6425
+561-541-4051
+561-577-6425
+561-577-6425
+561-202-8497
+4074509-5277
+561-791-4482
+561-791-4482
+561-964-5547
+407-509-6377
+561-582-1966
+561-502-7753
+561-502-7753
+561-644-9726
+561-795-7715
+561-478-4168
+561-644-9726
+561-723-3440
+561-723-3440
+561-478-4188
+561-667-4222
+56-202-6497
+561-791-4482
+224-627-2132
+561-202-8497
+561-249-8972
+561-502-3866
+561-662-66E8
+FP
+FP
+FP
+PP
+FP
+PP/CS
+FP
+PP
+FP
+FP
+FP
+FF
+1:00
+3:00
+2:00
+2:00
+1:00
+1,00
+1:00
+1:00
+1:00
+3:00
+1:00
+2:00
+1:00
+2:00
+1:00
+1:00
+2: 00
+SIgU
+2:00
+1:00
+1:00
+2:00
+4: 00
+2:00
+2:00
+2:00
+1:00
+2:00
+2:00
+1:00
+1:00
+JE0O
+1:00
+5:00
+3:00
+5:00
+Usage
+•.00
+6.00
+6.00
+0.0D
+•.00
+6.00
+0.0D
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+0000
+D.D0
+D.D0
+0.00|
+0,00
+D.00
+D.00
+D.D0
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+054 May 25 11:45 AM Inconing
+855 Kay 25 11:57 AM PORTPIERCE, PL
+856 May 25 12:24 PM Inconing
+857 My 2512127 IM I PALM BCH, PL
+958 May 2512:29 IN NALACE, PL
+859 Kay 25 12:30 IM N PALE BCH, PL
+960 Kay 25 12:54 PM Inconing
+951 May 25 01:09 FM I PALA BCH,PL
+982 Kay 25 01:29 I Inconing
+963 Kay 25 01:30 PM BOYTONBCH, PL
+054 May 25 01135 PM Inconing
+985 Kay 25 01:3€ m Inconing
+900 Kay 25 02:03 IM N PALA BCH, PL
+957 Kay 25 02:04 PM N FALK BCH, PL
+938 Kay 25 02:07 EM W PALA BCH, PL
+900 Kay 25 02:08 PM N FALA BCH,PL
+870 Kay 25 09:14 m
+Inconing
+971 May 25 03.15 EM NPALM BCH, PL
+972 Kay 25 03:18 SALE #CH, PL
+973 Kay 25 03:20 IM N PALA BCH, PL
+974 May 25 03:24 PM Inconing
+975 May 25 03125 EM N PALM BCH, PL
+976 Kay 25 03:31 IN N BALA RCH, PL
+877 Kay 25 03:40 IM PALA BCH, PL
+978 Kay 25 03:42 PM BOCA RATON, PL
+979 May 25 03:47 #M Inconing
+880 Kay 25 03:50 I Incoming
+981 Kay 25 03:58 PM Inconing
+982 May 25 03,59 EM JUPITER, FL
+883 Kay 25 04:02 x FALANCH, PL
+984 Kay 25 04:09 IM Inconing
+885 Kay 25 04:53 PM Inconing
+986 May 25 04:56 EM Inconing
+887 Kay 25 09:15 m
+980 Kay 25 05:24 PM Inconing
+930 May 25 09121 EM W PALM BCH, PL
+990 Kay 25 08:23
+991 Kay 25 08:25 IN N PALA BCH, PL
+992 Kay 25
+04:30
+IN PALM BCH, PL
+993 May
+26 06,39 AM
+084 Kay 26 06:45 AM N BALA RCH, PL
+Min: Sec
+305-645-6032 PP
+172-359-3858P0
+561-566-7050 FF
+561-762-2474 PP
+561-478-4188 FD
+561-352-7000 PP
+561-577-3687
+FF
+561-352-7000
+PP
+561-202-8497
+561-704-8099
+561-742-0070
+FP
+PP
+361-478-4188
+561-718-4222 PP
+561-688-2555
+561-754-5227
+PP
+561-478-4188
+561-478-4188
+PP
+561-202-2497
+561-942-6414 PP
+561-478-4188 FD
+561-478-4188
+561-393-7965
+561-352-7000
+561-352-7000
+561-202-4497
+561-747-2467
+FF
+PP
+PP
+FF
+PP
+561-820-3195
+561-202-8497
+PD
+561-969-3698
+561-502-5212
+561-329-0761
+FF
+561-644-4989
+361-377-8425
+FF
+561-333-7530
+PP
+561-616-4340 PP
+561-542-1964 CP
+561-615-0011 CE
+Usage
+1100
+4: 00
+2:00
+1:00
+2:00
+2:00
+7,00
+1:00
+2:00
+4:00
+7:00
+1:00
+1:00
+1,00
+1:00
+2,00
+2:00
+5:00
+1:00
+2,00
+4: 00
+2:00
+1:00
+2100
+3: 00
+1:00
+4:00
+2:00
+1:00
+2:00
+2100
+4: 00
+2,00
+1:00
+4: 00
+10:00
+6:00
+2:00
+9.00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0.DD
+0.DD
+0,00
+0-O0
+Total
+Charges
+U .UU
+0.OO
+0,00
+
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+905 Кау 26 06,55 ЛМ ВОСА RATON, FL
+561-393-7965
+oP
+2100
+895 Kay 26 07:07 AM I PALA BCH, PL
+561-333-7530
+2:00
+907 May 26 07:13 AN Incoming
+561-503-5930
+FP
+2:00
+09S May 26 07,15 AM Inconing
+561-502-7753
+FP
+999 кау 26 07:55 ЛМ M PALE BCH, FL.
+561-541-5449
+1:00
+1000 Kay 26 07:59 AM M PALA BCH, PL
+561-541-4051
+1:00
+1001 Kay 26 08:07 AM I PALE BCH, PL
+561-838-1817
+FP
+1:00
+1002 May 26 08:10 3M M BALA BCH, FL
+561-838-1833
+1,00
+1003 Kay 26 08:12 AN Incoeleg
+561-650-8143
+2:00
+1004 Kay 26 08:14 AM M BALS BCH, PL
+561-541-5449
+FP
+2:00
+1006 Kay 26 08:20 AM M BAIM BCH, PL
+561-683-5970
+FP
+5:00
+1005кку 26 08:31 A M BALA BC, FL.
+561-615-0011
+2:00
+1007 Kay 26 08:34 AM I PALK BCH, PL
+561-434-9897
+2:00
+1008 Kay 26 08:36 AN I BALK BCH, PL
+561-582-1964
+1:00
+1000 Kay 26 08,37 AM M BALA BCH, PL
+561-793-1441
+1:00
+1010кку 26 08:39 AN JUPITIA, FL.
+563-743-4039
+1:00
+1011 Kay 26 08:52 AM MINTERDARS, PL
+407-660-2552
+3:00
+1012 Kay 26 08155 JM Inconing
+561-722-0047
+PP
+1013 Kay 26 09:39 M Incoeleg
+1014 Kay 26 09:44 AM Incoming
+1015 Kay 26 09:47 1М Inconleg
+1016 May 26 09,50 AM Inconing
+1017 Kay 26 09:56 AN Incoalag
+1018 Kay 26 10:21 AM M PALK BCH, PL
+1019 Kay 26 10:24 1M Inconleg
+1020 Kay 26 10,26 AM I BALA BCH, FL
+1021 Kay 26 10:28 JM Inconieg
+1022 Kay 24 10:47 AM Inconleg
+1023 Kay 26 10,57 AN Inconleg
+1024 Kay 26 11:04 AN INcoRLeg
+561-514-4980
+561-202-8497
+561-202-8497
+561-650-8143
+561-301-3192
+561-585-4484
+561-662-6616
+561-243-8972
+561-827-2542
+561-827-2542
+561-202-8497
+2: 00
+FP
+2:00
+FP
+3:00
+3:00
+1,00
+3:00
+1:00
+FP
+FP
+2:00
+2:00
+1025 Kay 26 11:06 1M Inconieg
+561-503-8429
+2:00
+1028 Kay 24 12:08 1м Inconteg
+2:00
+1027 Kay 26 11124 2M Inconleg
+561-202-8497
+PP
+1028 кку 26 11:25 AN КОЛВАМ, IL
+
+1028 Kay 26 11:30 AM M BALK BCH, PL
+2:00
+4:00
+2:00
+1030 May 26 11,31 AM Inconleg
+1031 Kay 26 12:01 IN Incaleg
+1032 Kay 26 12:04 IN M PALK BCH, PL
+1030 Kay 24 12:10 PM FTLAUDERDL, PL
+1034 May 26 12,15 PM Inconing
+1035 Kay 26 12:21 IN Incoalag
+561-827-2542
+561-637-5907
+561-714-8274
+954-581-4200
+561-722-0047
+561-541-4051
+PP
+FP/Cs
+FF
+2400
+FP
+FP
+FF
+3: 00
+1:00
+3:00
+2:00
+1:00
+Usage
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+0.0D
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0.00|
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+1036 May 26 12124 EM Inconing
+561-684-2555 PP
+1100
+1037 Kay 26 12:35 I Inconing
+561-202-8497 P0
+1:00
+1038 kay 26 12:38 PM Inconing
+561-577-6425 FF
+3:00
+1039 May 26 12:44 IM Inconing
+561-472-2448 PP
++:00
+1040 Kay 26 12:52 IN Inconing
+561-650-8149 FD
+3:00
+1041 May 26 01:00 I Inconing
+561-762-2874 PP
+2:00
+1042 Kay 26 01:05 PM N PALE BCH, PL
+561-964-5547 FP
+2:00
+1043 May 26 01:07 EM N PALM BCH, PL
+561-964-3479 PP
+1,00
+561-436-8221 FE
+1:00
+1045 Kay 26 Ø1:29 PM Inconing
+561-737-3115 FF
+3:00
+1046 Kay 26 01135 EM Inconing
+561-753-9432 PP
+1,00
+1047 Kay 26 01:50 m Inconing
+561-478-4188 FF
+2:00
+1048 Kay 26 02:14 I Inconing
+561-655-0945 P8
+4:00
+1040 Kay 26 02:22 IM Inconing
+561-478-4188
+8:00
+1050 May 26 02123 EM Inconing
+561-753-9832
+1,00
+1051 Kay 26 02:37 PM Inconing
+FF
+2:00
+1082 Kay 26 02:39 m
+Incoming
+1053 May 26 02:52 PM
+Inconing
+1054 Kay 26 02:58 I Inconing
+1000 Kay 26 03:07 IM N PALA BCH, PL
+1056 Kay 2603:08 PM N FALK BCH, PL
+1057 May 26 03.12 PM Inconing
+1068 Kay 26 03:14 M N BALA RCH, PL
+1050 Kay 26 03:15 IM ALA BCH, PL
+1080 Kay 26 03:16 #M N FALK BCH, PL
+1061 May 26 03:21 #M Inconing
+1062 Kay 26 03:23 IN PALA BCH, PL
+1083 Kay 26 03:34 m
+W PALE BCH, PL
+1084 May 26 03.39 PM Inconing
+1065 Kay 26 01:50 m
+Inconing
+1006 Kay 26 03:58 I Inconing
+1067 Kay 26 04:14 IM Inconing
+1068 May 26 04:15 PM N PALM BCH,PL
+1000 Kay 26 04:22 m
+Inconing
+1070 Kay 26 64:50 PM Inconing
+1071 Kay 26 04:56 PM Inconing
+1072 Kay 26 05:45
+I N FALK ACH, PL
+1073 Kay 26 05:54 W
+InCORLET
+1074 Kay 26 06:04 m
+Inconing
+1075 May 26 06:10 EM Inconing
+1076 Kay 26 06:14 PM N FALE RCH, PL
+561-753-0925
+561-202-4497
+561-202-8497
+561-478-4188
+PP
+561-434-1833
+561-502-5212 PP
+561-838-1817 FD
+561-644-9162 P0
+561-478-4188 PP
+561-436-4739 PP/CH
+561-838-1833
+PD
+561-644-9162 PP
+561-474-4144 PP
+561-722-0047 FE
+561-502-5212 PD
+561-202-8497 PP
+561-966-0501 PP
+trava11 able
+FP
+561-503-5930
+561-503-5930
+361-478-2590
+FF
+561-762-2674
+PP
+561-503-5930 PP
+561-503-5930 PP
+561-385-1008 FF
+2:00
+2,00
+1:00
+1:00
+2:00
+2,00
+1:00
+1:00
+7:00
+1,00
+5:00
+1:00
+2100
+4:00
+1:00
+1:00
+3,00
+1:00
+2,00
+2:00
+3:00
+1:00
+1,00
+1:00
+Usage
+9.00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0.DD
+0.DD
+0,00
+0-O0
+Total
+Charges
+0,00
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+1077 Kay 26 06134 EN Inconing
+561-790-5483 FP
+2100
+1078 Kay 26 06:48 PM I PALA BCH, PL
+561-964-5511
+11:00
+1079 Kay 26 07:02 PM Incoming
+561-502-5212
+FP
+1:00
+1050 Kay 26 07,08 EM I PALA BCH, PL
+561-762-2874
+FP
+1:00
+1051 ay 26 07:44 IN M PAL: BCH, FL
+561-762-2874
+1:00
+1082 Kay 27 06:52 AM Incoming
+561-689-6733
+11:00
+1083 Kay 27 07:03 AM I PALE BCH, PL
+561-722-0047
+FP
+4:00
+1054 Kay 27 07:09 3 M BAI BCH, FG
+561-856-1077
+FP
+1,00
+1085 кку 27 07:11 АМ И РАДЕ ВСН, FL.
+561-502-5123
+FF
+1:00
+1080 Kay 27 07:12 AM M BALS BCH, PL
+561-615-0011
+PP
+1:00
+1057 Kay 27 07,31 AM M PAIN BCH, PL
+561-722-0047
+FP
+1:00
+1058 кку 27 07:33 мл Incoeleg
+561-856-1077
+2:00
+1089 Kay 27 07:37 1M Inconieg
+561-577-6425
+2:00
+1000 Кау 27 07:39 дн и ВАЦК ВСН, PL
+561-615-0011
+1:00
+1091 Kay 27 07:48 AM M BAIN BCH, PL
+561-795-9549
+1:00
+1082 Kay 27 D8:01 AN M FALA BCH, FL.
+561-478-9590
+4:00
+1080 Kay 27 08:07 AM Incoming
+561-202-8447
+2:00
+1094 Kay 27 08109 AM I PALA BCH, FL
+561-540-5442
+4:00
+1096 Kay 27 08:42 A Incoeleg
+1096 Kay 27 08:57 AM I PALA BCH, PL
+1097 Kay 27 09:14 1M Inconteg
+1098 Kay 27 09,33 JM Inconing
+1090кау 27 02:34 AN DELAY BCH, FL.
+1100 Kay 27 09:45 AM I PALK BCH, PL
+1101 Kay 27 09:47 1M Inconleg
+1102 May 27 09:48 3M M BAI BCH, FL
+1100 Kay 27 09:49 AM M PALK BCH, PL
+1104 Kay 27 09:50 AM Incontag
+561-798-8900
+561-683-1100
+561-503-5930
+561-202-8497
+561-278-0456
+561-615-0011
+561-202-8497
+561-784-1570
+561-784-1570
+561-202-8497
+FP
+FP
+FP
+PP
+1106 Kay 27 09,51 AN M BALA BCH, PL
+FP
+FP
+1105 Kay 27 08:52 AM M BAI BCS, PL
+561-784-1570
+561-868-3479
+1:00
+1:00
+1:00
+7:00
+1:00
+1:00
+1,00
+1:00
+2:00
+1:00
+2:00
+1107 Kay 27 09:54 AM M PALK BCH, PL
+561-868-3479
+2:00
+1108 Kay 27 10:34 AM M PALE BCH, PL
+561-478-4188
+5:00
+1100 Kay 27 10,39 2M Inconleg
+561-202-8497
+PP
+1110кку 27 10:40 AN M FALE RCH, FL.
+56-063-3969
+1111 Kay 27 10:41 AM M BALE BCH, PL
+FP
+1112 Nay 27 10:42 AM M BALK BCH, PL
+1113 Kay 27 10:45 A Incaleg
+1114 Kay 27 10:57 AM I PALK BCH, PL
+1115 Kay 27 10:58 1М Inconleg
+1116 May 27 11:05 ЛM Inconing
+1117 Kay 27 11:08 Al Incoaleg
+561-301-5732
+561-863-9964
+561-502-5212
+561-502-5212
+561-541-7608
+561-202-8497
+FP
+FP/CN
+FP
+FF
+1,00
+1:00
+2:00
+2:00
+13:00
+1:00
+1:00
+1:00
+1:00
+Usage
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+6.00
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0.00|
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+1118 May 27 11:09 AM NAUKEGAN, IL
+224-627-9132 PP
+6:00
+1119 Kay 27 11:20 AM Inconing
+561-667-4222 PP
+1:00
+1120 Kay 27 11:29 AM Inconing
+561-478-4168 FF
+3:00
+1121 May 27 12:14 EM Inconing
+561-723-3440 PP
+3,00
+1122 Kay 27 12:16 IM Inconing
+561-202-8497 FD
+1:00
+1123 Kay 27 12:17 IM N PALM BCH, PL
+561-622-8182 PP
+3: 00
+1124 Kay 27 12:20 PM Inconing
+561-723-3440 FP
+1:00
+1125 May 27 12:23 PM Incondng
+561-723-3440 PP
+1,00
+1126 Kay 27 12:24 W Inconing
+561-601-6698
+FE
+1:00
+1127 Kay 27 01:08 FM BOCA RATON, PL
+561-393-7914 FF
+2:00
+1128 Kay 27 01:14 EM Inconing
+561-764-1570
+PP
+3,00
+1129 Kay 27 01:27 BALANCH, PL
+361-364-3547 FF
+1:00
+1130 Kay 27 01:28 IM N PALA BCH, PL
+561-964-5547 P8
+1:00
+1131 Kay 27 01:33 PM Inconing
+561-202-8497
+1:00
+1132 May 27 01:37 PM Inconing
+561-502-7753
+2:00
+1133 Kay 27 01:45 PM BOCA RATON, PL
+1:00
+1134 Kay 27 01:46 I Inconing
+561-577-6425
+1135 Key 27 01:44 IM NPACE BCH ,PL
+561-643-1416
+PP
+1136 кму 27 01:52 IM BOTONICH, Р.
+361-3T7-E425
+1137 Kay 27 02:16 IM N PALE BCH, PL
+561-478-4188
+PP
+1138 Kay 27 02:22 PM Inconing
+561-202-2497
+1130 May 27 02123 EM N PALM BCH, PL
+561-642-2474
+PP
+1140 Kay 27 02:23 PM Inconing
+561-202-8497 FD
+1141 Kay 27 02:33 IM ORLANDO, PL
+407-509-6977 00
+1142 Kay 27 02:35 PM ORLANDO, PL
+407-509-6377
+FF
+1143 May 27 03:04 FM Incondng
+561-502-5212
+PP
+1144 Kay 27 03:20 IM Inconing
+561-472-2888
+PP
+1145 Kay 27 03:27 PM
+Inconing
+561-747-2467
+FF
+1148 May 27 03:41 EM W PALA BCH,PL
+561-627-0200
+PP
+1147 Kay 27 03:41 IN X BALA RCH,PL
+561-644-4989 FE
+5,00
+2:00
+1:00
+1:00
+6:00
+1:00
+2:00
+7:00
+2100
+5:00
+2:00
+1,00
+2:00
+1148 Kay 27 09:43 IM N PALA BCH, PL
+561-856-4306 PD
+1140 Kay 27 03:55 IM Inconing
+561-856-430€
+1:00
+1:00
+1150 May 27 04:11 PM N PALM BCH,PL
+561-688-2555
+2100
+1151 Kay 27 04:12
+N FALE RICH, PL
+21 DO
+1152 Kay 27 04:15 M
+W PALM BCH,PL
+561-345-2008
+FP
+1153 Kay 27 04:21
+W PALM BCH,PL
+561-472-2448 PP
+1154 Kay 27 04:26
+IN FALE RICH, PL
+361-471-6110 FF
+1155 Kay 27 04:27 I Incoming
+561-722-0047 PD/CH
+1156 Kay 27
+04:28
+N PALE BCH, PL
+561-471-4110 PP
+1157 May
+27 04,54 PM
+W PALM BCH,PL
+561-236-6852 PP
+1158 Kay 27 05:04 PM N FALE RCH, PL
+561-364-3547 FF
+2:00
+1,00
+1:00
+1:00
+3:00
+4:00
+1:00
+Usage
+9.00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0.DD
+0.DD
+0,00
+Total
+Charges
+0.OO
+0.0D
+0,00
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time
+Call To
+1150 Kay 27 05:05 IN I BALK BCH, FL
+1160 Kay 27 05:11 PM I PALA BCH, PL
+1161 Kay 27 05:26 PM I PALE BCH, PL
+1182 Kay 27 05129 EM I PALA BCH, PL
+1163 ay 27 05:48 IN M PAL: BC, FL
+1164 Kay 27 05:57 PM Incoming
+1165 Kay 27 05:59 PM Inconleg
+1166 Kay 27 06:03 PM Inconing
+1167 Kay 27 DE:05 IN IncoRleg
+1158 Kay 27 D6:17 EN Inconleg
+1180 Kay 27 06:31 EM Inconleg
+1170 Kay 27 D6:31 IN Incoaleg
+1171 Kay 27 07:03 IM Inconieg
+1172 Kay 27 07:08 PM MINTERBARK, PL
+1173 Kay 27 07:08 EM MINTERBARK, FL
+1174 Kay 27 07:09 IN M FALA BCH, FL.
+1175 Kay 27 07:10 PM M DALK BCH, PL.
+1178 Kay 27 07,22 PM I PALA BCH, FL
+1177 Kay 27 07:41 IN M PALE BCH, VL.
+1178 Kay 29 06:12 AM M PALK BCH, PL
+1170 Kay 24 D6:48 1M Inconleg
+1150 Kay 24 06,55 AM I PALA BCH, PL
+1181кау 28 07:26 3Н M PALE BCH, FL
+1182 Kay 24 07:33 AM Incoming
+1183 Kay 24 07:39 3М M BALE BCH, PL
+1184 May 24 07,56 3M M BAI BCH, FL
+1185 Kay 24 08:04 AM N PALK BCH, PL
+1180 Kay 24 08:09 AM PLAUDERDG, PL
+1187 Kay 24 08,32 AN M BALA BCH, PL
+1188 Kay 28 08:55 AN Incoeleg
+1180 Kay 24 08:59 AM M PALK BCH, PL
+1190 Kay 24 09:29 1М Inconteg
+1191 Kay 24 09,36 AM N BAL BCH,PL
+1192 кку 28 03:50 АМ воУтОваСи, ГL.
+1190 Kay 24 09:50 AM Incoming
+1194 Kay 29 09,52 AM BALK BCH, FL
+1196 Kay 28 09:56 A Incaleg
+1196 Kay 24 09:58 AM I PALK BCH, PL
+1197 Kay 24 09:59 JМ Inconleg
+1108 May 24 10:03 AM I BALA BCH, FL
+1190 кку 24 10:05 ЛИ И РАДА ВСК, РС
+Min: Sec
+561-541-7608 F7
+561-642-2474
+561-722-0047
+561-662-6688
+FP
+FP
+561-252-4383
+561-252-4383
+561-202-8497
+FP
+561-689-6733
+PP
+561-762-2874
+561-242-6019
+561-667-4222
+FP
+FP
+561-667-4222
+561-252-4383
+407-660-2552
+407-660-2552
+561-252-4383
+561-541-5444
+561-589-6728
+561-502-5212
+561-667-3739
+561-582-1964
+561-502-5212
+561-840-8811
+561-478-4822
+561-478-9590
+561-502-3866
+954-528-7558
+561-582-1964
+561-252-4383
+561-252-4383
+561-478-4188
+561-577-6425
+561-615-0011
+561-577-6425
+561-502-3866
+561-642-2474
+561-642-2476
+561-502-5212|
+PP
+PP
+OP
+OP
+FP
+FP
+FP
+PP
+PP/Cs
+FF
+FP/CN
+FP
+FF
+Usage
+2100
+1:00
+13:00
+16,00
+SIOU
+2:00
+1:00
+1,00
+1:00
+2:00
+1:00
+2:00
+5:00
+1:00
+1:00
+1:00
+7:00
+15,00
+1:00
+7:00
+2:00
+TROU
+6:00
+2:00
+3,00
+1:00
+1:00
+2:00
+2:00
+2:00
+1:00
+4:00
+1:00
+1:00
+4:00
+2: 00
+2:00
+4:00
+1:00
+1:00
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+$.00
+6.00
+6.00
+0.0D
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+1200 May 28 10:06 AM Inconing
+561-542-9575 PP
+2100
+1201 Kay 28 10:08 AM Inconing
+561-502-3866 PD
+1:00
+1202 Kay 28 10:12 AM Inconing
+561-514-4980 FF
+4:00
+1203 May 28 10/15 AM Incondng
+561-422-1200 PP/CH
+15:00
+1204 kay 28 10:33 AM Inconing
+561-303-8429 FD
+1:00
+1200 May 28 10:35 2M Inconing
+561-615-0011 PP
+2:00
+1206 Kay 28 10:37 AM BOYTONCH,PL
+561-573-6425 FP
+1:00
+1207 May 28 10:4* AM Inconing
+561-642-9437 PP
+1,00
+1208 Кку 20 10:51 ЛИ N FALE #CH, PL
+561-582-1964 FE
+1:00
+1200Киу 28 10:52 A N BALE BCH, PL
+561-478-4148 FF
+1100
+1210 May 28 10:53 AM I PALA BCH, PL
+561-478-4188 PP
+1,00
+1211 ay 28 11:14 aM Inconing
+361-868-3479 FF
+1:00
+1212 Kay 28 11:36 AM Incoring
+561-615-0011 PP
+1:00
+1213 Kay 28 11:37 MM Inconing
+561-722-0047 PB/CH
+1,00
+1214 Kay 28 11,38 AM W PALM BCH, PL
+561-722-0047
+1,00
+1215 ay 28 11:48 AM Inconing
+4: 0D
+1216 Kay 28 11:52 AM
+Incoming
+PP/CH
+21O0
+1217 Key 28 11:57 л
+Inconing
+561-503-5930
+PP
+4:00
+1218 Kay 28 12:00 I Inconing
+361-302-38CE
+1:00
+1219 Kay 28 12:01 IM N PALA BCH, PL
+561-502-3666
+PP
+4: 00
+1220 Kay 28 12:05 PM N FALK BCH, PL
+561-662-6688
+FF /NN
+4: 00
+1221 May 28 12:20 EM Inconing
+561-502-5123 PP
+1,00
+1222 Kay 28 12:21 PM Inconing
+561-8C8-3479 FF/CH
+1:00
+1223 Kay 28 12:29 IM Incoming
+561-478-4168
+1:00
+1224 Kay 28 12:35 PM N PALA BCH, PL
+561-478-4188
+1:00
+1225 Кву 28 12:41
+Inconing
+561-502-3866
+PP
+2100
+1226 Kay 28 12:43
+N PALA BCH, PL
+561-868-3479
+PP
+1:00
+1227 Кау 28 12:45
+N PALE BCH, PL
+1228 Kay 28 01:00
+W PALM BCH,PL
+1229 Kay 28 01:03
+Inconing
+1230 Kay 28 01:06 I
+N PALA BCH, PL
+1231 Kay 28 01:39 PM
+PILAUDERIC, PL
+1232 May 28 01:41 PM N PALM BCH,PL
+561-474-4148
+561-474-4148 PP
+FF /CN
+561-478-4188
+PD
+954-791-4728
+561-478-4188
+7:00
+4:00
+2:00
+1233 кку 28 01:42 m
+VILALDERDE, PL
+1234 Kay 2801:47 m
+W PALM BCH,PL
+1235 Kay 2803:54 F
+N PALM BCH, PL
+1236 Kay 28 03:54
+Inconing
+1237 Kay 28 03:57
+Incoming
+1230 Kay 28 04:00
+N PALE BCH, PL
+1230 May 28 04:13
+W PALM BCH,PL
+1240киу 28 04:15 PM N FALA NCH, PL
+PP
+FF
+561-545-4444
+FF
+561-644-4989 PP
+361-686-2977 F/CH
+Unavailable
+PP
+561-252-4654 PP
+561-255-3725 PP
+561-252-4654 FF
+2:00
+1,00
+1:0D
+9:00
+1,00
+2:00
+4: 00
+2:00
+2,00
+1:00
+Usage
+9.00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0.DD
+0.DD
+0,00
+0-O0
+Total
+Charges
+0.OO
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time
+Call To
+1241 Kay 24 04.16 IN I BALK BCH, FL
+1242 Kay 24 04:17 PM I PALA BCH, PL
+1243 Kay 24 04:19 PM I PALE BCH, PL
+1244 Kay 24 04:28 EM Incoming
+1245 ay 28 04:32 N M FALK BCH, FL
+1246 Kay 24 04:35 PM Incoming
+1247 Kay 24 04:37 PM I PALE BCH, PL
+1248 Kay 24 05:00 PM M BALA BCH, FL
+1249 Kay 24 05:09 IN Inconleg
+1250 Kay 24 05:12 PM M BALK BCH, PL
+1251 Kay 24 05:20 EM M BAIM BCH,PL
+1252 Kay 28 03:54 m Incoaleg
+1253 Kay 24 06:12 IM BOYTONBCH, PL
+1254 Kay 24 06:34 PM M BALK BCH, PL
+1256 Kay 24 08:50 EM N BALA BCH, PL
+1250кку 23 07:50 AN Incaleg
+1257 Kay 29 07:51 AM M DALK BCH, PL.
+1258 Kay 29 08,33 AM I PALA BCH, FL
+1250 Kay 27 09:21 AN M PALE BCH, VL.
+1200 Kay 29 10:25 AM Incoming
+1261 Kay 29 10:40 AM M BALK BCH, PL
+1282 Kay 29 10153 JM Inconing
+1283 Kay 27 10:54 A Incoalag
+1254 Kay 29 10:57 AM Incoming
+1265 Kay 29 10:59 3М M BALE BCH, PL
+1296 Kay 29 11,31 AM I BALA BCH, FL
+1267 Kay 29 11:48 AN Incoming
+1260 Kay 29 12:23 PM Inconleg
+1280 Kay 23 03,06 EN Inconleg
+1270 Kay 29 DE:18 IN Inconleg
+1271 Kay 29 06:23 IN Incoming
+1272 Kay 29 06:45 PM Inconteg
+1273 Kay 29 06,52 PM Inconleg
+1274 Kay 29 07:37 IN M PALE BCH, PL
+1275 Kay 27 08:04 FM BALK BCH, PL
+1278 May 29 08:09 EM BALA BCH, FL
+1277 Kay 27 08:10 IN M PAL BCH, FL
+1278 Kay 29 08:50 W Incoming
+1279 Kay 29 08:51 PM Inconleg
+1260 Kay 30 07,33 3М M BALK BCH, FL
+1281 Kay 30 DE:49 IN M PALAC BCH, PL
+Min: Sec
+561-685-1616
+561-281-3814
+561-848-8172
+561-236-6852
+FP
+FP
+561-502-7753
+561-502-7753
+561-236-6852
+561-502-7753
+561-236-6852
+561-502-7753
+561-707-3948
+FP
+FP
+FF
+FP
+FP
+561-856-4306
+561-503-5930
+561-252-4383
+561-722-0047
+561-582-9621
+561-582-9621
+5614758-9482
+561-964-5511
+561-541-5449
+561-856-4306
+OP
+561-502-7753
+OP
+561-616-8240
+OP/cw
+561-616-8240
+561-827-2542
+561-502-7753
+OP
+OP
+561-622-8182
+561-502-7753
+561-856-4306
+561-683-9750
+OP
+OP
+OF
+561-478-9868
+561-422-1200
+561-422-1200
+OP
+SE1-183-626
+OP
+561-841-9726
+561-667-3739
+561-252-4383
+561-252-4383
+561-723-3440
+561-762-2874
+OF
+OP
+OP
+OF
+Usage
+1:00
+3:00
+3:00
+3:00
+2:00
+1,00
+2:00
+7:00
+2:00
+1:00
+2:00
+3:00
+5:00
+1:00
+1:00
+2:00
+1:00
+1:00
+1,00
+2:00
+1:00
+4:00
+3:00
+3:00
+3:00
+11,00
+1:00
+5:00
+JE0O
+1:00
+3:00
+--UU
+1:00
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+6.00
+6.00
+0.0D
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0.00|
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+1282 May 30 07,35 EM N PALA BCH,PL
+561-502-5212 OP
+4:00
+1283 Kay 30 08:02 IM Incoming
+561-541-5449 0P
+9:00
+1284 Kay 30 08:04 PM Inconing
+561-456-4306 DE/CH
+3:00
+1285 May 30 10,19 IM I PALM BCH,PL
+561-616-4240 OP
+1,00
+1286 kay 30 10:20 IN Inconing
+361-61E-8240 DE
+1:00
+1287 Kay 31 09:28 AM N PALE BCH, PL
+561-252-3132 PP
+4: 00
+1288 Kay 31 01:21 PM Inconing
+561-667-4222 FP
+2:00
+1280 May 31 02+11 EM Inconing
+561-541-4300 PP
+3,00
+1290 Kay 31 03:43 I Inconing
+561-364-5511
+FE
+3:00
+1291 Kay 31 64:40 PM Inconing
+561-422-3200 PF
+8: 00
+1292 May 31 05.19 FM Inconing
+561-304-0616 PP
+1,00
+1293 Kay 31 07:25 m Inconlng
+361-304-2844 FF
+1:00
+1294 Jun 01 06:39 AM N PALA BCH, PL.
+561-662-6668 00
+6:00
+1295 Jun 01 06:47 AM BOYTONBCH ,PL
+561-577-6425 C8
+2:00
+1296 Jun 01 06:51 AM ORLANDO, FL
+407-509-6177
+1,00
+1297 Jun 01 06:57 AM BOCA RATON, PL
+1100
+1298 Jun 01 07:05 AM BOCA RATON, PL
+21O0
+1290 Jun 01 07:09 AM Inconing
+1300 Jun 01 07:18 AM ORLANDO, FL
+1301 Jun 01 07:20 AM W PALM BCH, PL
+1302 Jun 01 07:21 AM N FALE BCH, PL
+1303 Jun 01 07:27 AM Inconing
+1304 Jun 01 07:50 AM N SALE RCH, PL
+1308 Jun 01 68:08 AM MIAMI, PL
+1308 Jun 01 08:24 AM N PALE BCH, PL
+1307 Jun 01 09:50 AM N PALM BCH, PL
+1308 Jun 01 08:55 AM Inconing
+1309 Jun 01 09:00 MM
+Inconing
+1310 Jun 01 09:00 AM I PALA BCH, PL
+1311 Jun 01 09:18 1M
+Inconing
+1312 Jun 01 09:46 AM Inconing
+561-333-7530
+PP
+407-309-6377
+561-842-6414
+PP
+561-582-1964
+407-509-6377
+PP
+561-842-6414 FD
+305-592-3480
+561-795-9549
+FF
+561-541-4051
+PP
+561-471-5774
+PP
+561-202-4497
+FF
+561-949-4561
+PP
+407-509-6377
+561-478-4188
+1313 Jun 01 10:02 MM Inconing
+561-462-3098
+3,00
+1:00
+1:00
+4: 00
+10:00
+1:00
+2:00
+1:00
+1,00
+3: 00
+1:00
+3,00
+2:00
+2:00
+1:00
+1314 Jun 01 10:12 AM N PALM BCH,PL
+1315 Jun 01 10:23 дл
+Inconing i
+1316 Jun 01 10:35 AM Inconing
+1317 Jun 01 10:47 AM Inconing
+1318 Jun 01
+Inconing
+1319 Jun
+10:54 AM Incoming
+1320 Jun 01
+10:57
+N PALE BCH, PL
+1321 Jun 01 11,12 AM
+W PALM BCH,PL
+1322 Jun 01 11:13 AM Inconing
+561-964-9300
+PP
+561-422-1200
+561-622-4142
+FP
+561-965-5600
+361-382-2164
+FF
+561-719-3077
+PP
+561-684-2555 PP
+561-202-9497 PP
+561-202-8497 FF/CN
+2100
+EEDO
+1:00
+2,00
+1:00
+3:00
+2:00
+1,00
+1:00
+Usage
+9.00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0.DD
+0.DD
+0,00
+Total
+Charges
+U .UU
+0.OO
+0,00
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+1323 Jun 01 11/13 AM M BALK BCH, FL
+561-301-1166 FP
+1:00
+1324 Jun 01 11:24 AM Incoming
+561-541-4023
+3:00
+1325 Jun 01 12:28 AN M PALK BCH, PL
+561-541-4023
+FP
+17:00
+1328 Jun 01 11:45 AM BOTTONECH, PL
+561-577-5694
+FP
+3:00
+1327 лив 01 11:50 3Н M PALE BCH, FL
+561-478-9621
+3E0U
+1328 Jun 01 11:59 AM Incoming
+561-719-5032
+2:00
+1329 Jun 01 12:01 IN MIAMI, PL
+305-636-2090
+FP
+1:00
+1330 Jun 01 12:17 PM M BALA BCH, FL
+561-848-4661
+FP
+1,00
+1331 Jun 01 12:22 IN M FALL BCH, FL
+561-478-4188
+FF
+1:00
+1332 Jun 02 12:22 PM M PALE BCH, PL
+561-352-7000
+FP
+3:00
+1333 Jun 01 12128 EM Inconleg
+561-202-8497
+FP
+1:00
+1334 Jun 01 12:37 m Iscoeleg
+561-478-4188
+1:00
+1330 Jun 01 12:51 IM Ieconieg
+239-438-5697
+3:00
+1336 Jun 01 12:54 PM NO MAPLES, PL.
+239-438-5697
+FF
+2:00
+1337 Jun 01 12,54 EM Inconing
+305-636-2090
+PP/CS
+3,00
+1338 Ju 01 01:17 I M PALE BC, FL.
+1:00
+1338 Jun 01 01:20 PM EAU CALLIE, PL.
+42-255-0056
+1:00
+1340 Jun 01 01,21 IN M BALK BCH, PL
+S61-522-81K2
+PP
+2:00
+1341 Jun 01 01:31 IN M PALE BCH, VL.
+1342 Jun 01 01:44 PM & PALK BCH, PL
+1343 Jun 01 02:10 PM Inconteg
+1344 Jun 01 02/12 PM M BALK BCH, FL
+1345 Jun 01 02:15 IN M PALE BCH, FL
+1346 Jun 01 02:21 PM N PALK BCH, PL
+1347 Jun 01 02:29 IN M BALE BCH, PL
+1348 Jun 01 02133 PM Inconing
+1349 Jun. 01 02:52 IM BOCA RATON, PL
+1350 Jun 01 03:06 PM Inconleg
+1351 Jun 01 03117 EM BALA BCH,PL
+561-255-1015
+561-622-8182
+561-478-4188
+561-478-4188
+561-478-4188
+561-848-4661
+561-848-4661
+561-202-8497
+561-393-7120
+561-202-8497
+561-478-9621
+3: 00
+2: 00
+FP
+FP
+1:00
+SLUU
+FP
+PP
+FP
+FP
+1352 Jun 01 03:19 IN Incoeleg
+561.701-0620
+4:00
+2:00
+2:00
+1,00
+2:00
+1:00
+3:00
+2:00
+1353 Jun 01 03:36 IN Inconieg
+561-471-5774
+2:00
+1354 Jun 01 03:44 PM M PALE BCH, PL
+3:00
+1355 Jun 01 03,49 PM N BALA BCH,PL
+561-541-4023
+1,00
+1356 Ju: 01 04:00 Inchelag
+563-185-9794
+TrOO
+1357 Jun 01 05:00 PN M BALK BCH, PL
+PP
+1358 Jun 01 05/01 IN N BALK BCH, PL
+1:00
+1:00
+1350 Jun 01 05:06 I Incaleg
+1350 JuE 01 05:14 PM FTLAUDERDL, PL
+1361 Jun 01 05:16 I Inconleg
+1382 Jun 01 05:20 PM M BALK BCH, FL
+1383 Jun 01 05:22 PN M FALK BCH, PL
+561-688-5222
+561-722-0047
+954-444-6836
+561-798-1691
+561-352-7000
+561-644-4983
+FF
+"rOO
+FP/CN
+FP
+FF
+3: 00
+2:00
+2:00
+7.00
+Usage
+•.00
+6.00
+6.00
+0.0D
+•.00
+6.00
+6.00
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0.00|
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date
+Time
+Call To
+1364 Jun 01 05,31 EM W PALA BCH, PL
+1305 Jun 01 05:36 IM N PALA BCH, PL
+1366 Jun 01 05:38 PM Inconing
+1367 Jun 01 06:00 PM W PALA BCH,PL.
+1368 Jun 0106:01 FALABCS,PL
+1309 Jun 01 66:23 I Inconing
+1370 Jun 01 06:26 PM Inconing
+1371 Jun 01 06:36 EM N PALA BCH,PL
+1372 Jun 01 06:42 W Inconing
+1373 Jun 01 06:52 PM Inconing
+1374 Jun 01 07:44 EM Inconing
+Number
+Footnote
+Min: Sec
+561-722-0047 PP
+561-601-6403 PP
+561-601-6403 FF
+561-427-2542 PP
+561-762-2874 FD
+561-640-7769 PP
+561-964-5511
+FF
+561-644-4949
+PP
+561-502-5212 FE
+561-448-6023
+FF
+561-541-5449
+PP
+361-844-3190
+1376 Jun 01 09:40 IM Inconing
+1377 Jun 02 06:31 MM Inconing
+1378 Jun 02 06153 AM Inconing
+1379 Jun 02 07:13 AM ORLANDO, VL.
+1380 Jun 02 07:34 AM
+Inconing
+1381 Jun 02 07:45 AM Inconing
+1382 Jun 02 07:49 AM N SALE NCH, PL
+1383 Jun 02 07:52 AM Incoming
+1384 Jun 02 07:57 M Inconing
+1385 Jun 02 09:20 AM Inconing
+1386 Jun 0208:35 AM BOTTONCH, PL
+1387 Jun 02 08:36 AM N PALA BCH, PL
+1388 Jun 02 08:40 AM N PALE BCH, PL
+1389 Jun 02 09:13 AM Inconing
+1390 Jun 02 09:15 AM Inconing
+1391 Jun 02 09:16 AM Inconing
+1302 Jun 02 09,30 AM Inconing
+1383 Jun 02 09:32 1M
+Inconing
+1394 Jun 02 09:33 AM Inconing
+1395 Jun 02 09:34 m
+Inconing
+1308 Jun 02 09:36 AM Inconing
+1307 Jun 02 08:38 дм
+1398 Jun 02 09:47 AM N PALA BCH, PL.
+1390 Jun 02 09,53 AM I PALM BCH, PL
+1400 Jun 02 09:54
+Inconing
+1401 Jun 02 10:03 AM
+Incoming
+1402 Jun 02
+10:08
+Inconing
+1403 Jun 02 10:13
+1404 Jun 02 10:14 AM N FALM RCH, PL
+561-965-1305 00
+561-712-9014
++07-509-6377
+2100
+2:00
+1:00
+1,00
+3:00
+1:00
+9:00
+1,00
+4: 00
+1100
+1,00
+1:00
+1:00
+1,00
+15,00
+407-509-6377
+FF
+121 00
+954-818-3335
+561-123-3450
+361-E62-8C8E
+Unavailable
+PP/CH
+407-509-6377
+561-689-5072
+PP
+561-303-3930 FD
+561-827-2542
+561-689-6733
+561-722-0047
+239-695-2051
+FF
+PP
+PD/CH
+561-364-6853
+561-474-3613 PP
+407-660-2552
+561-478-9613
+1:00
+3,00
+5: 0D
+4: 00
+3:00
+5:00
+1:00
+1:00
+4: 00
+2100
+1:00
+2:00
+3,00
+2:00
+2:00
+239-695-2573
+561-478-9625
+PP
+1,00
+561-478-4188
+21 DO
+561-476-4144 PP
+561-541-4051 PP
+361-862-6616 FF/CH
+561-663-1100 PD
+561-577-6425 PP
+561-714-4222 PP
+561-688-2555 FF
+2:00
+1,00
+3:0D
+3:00
+2:00
+1,00
+1:00
+Usage
+9.00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0.0D
+0.DD
+0.DD
+0,00
+0-O0
+Total
+Charges
+U .UU
+0.0D
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time
+Call To
+1406 Jun 07 10,17 AM Inconing
+1400 Jun 02 10:18 AM Incoming
+1407 Jun 02 10:25 AN Incoming
+1408 Jun 02 10:26 AM M BALA BCH, FL
+1400 Jun 02 10:29 A Incoeleg
+1410 Jun 02 10:42 AM Incoming
+1411 Jun 02 10:57 AM M BALE BCH, PL
+1412 Jun 02 11:02 3M M BALA BCH, FL
+1413 Jun 02 11:0E Al Incoeleg
+1414 Jun 02 13:11 3M Inconleg
+1415 Jun 02 11/19 JM Inconing
+1416 Jut 02 11:59 AM M PALAC BCH, FL
+1417 Jun 02 12:06 IM N PALA BCH, PL
+1418 Jun 02 12:07 PM M BALE BCH, PL
+1419 Jun 02 12:07 EM N BALA BCH, PL
+1420 лив 02
+IN A PALE ECS, PL
+1421 Jun
+02
+12:18 PM Incoming
+1422 Jun
+02 12,39 IN M BALK BCH, PL
+1423 Jun
+02 12:44 IN IncoRleg
+1424 Jun 02 12:44 PM & PALK BCH, PL
+1425 Jun
+12:48 PM M BALK BCH, PL
+1428 Jun 02 12,53 PM M BALK BCH, FL
+1427 Jun 02 01:0E IN M PALE BCH, FL
+1428 Jun 02 01:10 PM 5 PALK BCH, PL
+1429 Jun
+02 01:32 PM PTLAUDEADL, PL
+1430 Jun 02 01,35 PM M BAIR BCH, FL
+1431 Jun 02 01:44 IN Incoming
+1432 Jun 02 02:49 PM Inconleg
+1433 Jun 02 01,53 EM M BALA BCH, PL
+1434 Jun
+02 02:02
+IN BOCA RATON, FL
+1436 Jun 02 03:45 WM Iscoeleg
+1436 Jun 02 03:49 PM Inconteg
+1437 Jun 02 03,54 PM Inconleg
+1438 Jun
+02 03:56 IN LECDELEG
+1430 Jun 02 03:59 PM M BALK BCH, PL
+1440 Jun 02 04:06 EM Inconing
+1441 Ju 02 04:16 IN M PALE BCH, VL.
+1442 Jun
+02 04:17 PM M PALK BCH, PL
+1443 Jun 02 04:27 PM M PALE BCH, PL
+1444 Jun 02 04:28 PM M BALK BCH, FL
+1445 Jun 02 04:32 IN Iscoeleg
+Min: Sec
+561-683-1100 FP
+561-840-1706
+561-683-1101
+FP
+561-541-5449
+561-541-5449
+561-856-4306
+561-722-0047
+561-856-4306
+FP
+FP
+561-722-0047
+561-856-4306
+561-697-8594
+FP
+FP
+561-502-3866|
+561-236-6852
+561-352-7000
+561-478-4188
+561-065-5507
+S61÷428-418m
+561-476-41-
+561-202-8497
+561-848-0330
+561-848-0330
+561-718-1592
+561-848-0330
+561-478-4188
+954-270-8701
+561-236-6852
+561-478-4188
+561-722-3311
+561-662-6688
+561-239-2245
+561-722-3311
+561-856-4306
+561-964-5511
+561-541-4023
+561-722-0047
+561-541-5449
+561-722-0047
+561-541-5449
+561-478-6188
+FP
+FP
+PP
+FP
+FP
+PP/CW
+PP/CW
+FP
+RP/CW
+FF
+FP
+FP
+FF
+Usage
+2100
+3:00
+1:00
+3:00
+1:00
+2:00
+5:00
+1,00
+2:00
+1:00
+11,00
+1:00
+1:00
+1:00
+$:00
+1:00
+5:00
+2:00
+2:00
+3:00
+4:00
+3:00
+3,00
+4: 00
+2:00
+$:00
+4:00
+14:00
+2:00
+1,00
+1:00
+10,00
+1: 00
+2:00
+1:00
+1:00
+7.00
+•.00
+6.00
+6.00
+0.0D
+•.00
+6.00
+6.00
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+1446 Jun 02 04.39 EM NPALA BCH,PL
+1447 Jun 02 04:45 IM N PALM BCH, PL
+1448 Jun 02 04:48 IN PALA BCH, PL
+1440 Jun 02 04152 FM PALA BCH, PL
+1450 Jun 02 04:53 M BOTONCH, FL
+1451 Jun 02 05:08 IN PALA BCH, PL
+1452 Jun 02 05:14 PM Inconing
+1459 Jun 02 05:45 #M Incondng
+1454 Jun 02 05:53 P
+Inconing
+1455 Jun 02 06:53 P
+W PALE BCH ,PL
+1456 Jun 02
+06:54 PM
+N PALM BCH ,PL
+1458 Jun 02 06:59 IM W PALA BCH, PL
+1450 Jun 02 07:08 PM FACE BCH, PL
+1480 Jun 02 07:19 EM Inconing
+1461 Jun 02 07:21 PM N BALA RCH, PL
+1462 Jun 02 07:27 M
+Incoming
+1463 Jun 02 04.10 EM Inconing
+1464 Jun 03 06:56 AM N SALE BCH, PL
+1405 Jun 03 06:57 AM Inconing
+1408 Jun 03 06:57 AM N FALK BCH,PL
+1487 Jun 03
+06.54 AM PALA BCH, PL
+1468 Jun 03
+06:58 AM N BALA RCH, PL
+1400 Jun 03 07:03 AM PALA BCH, PL
+1470 Jun 03 07:05 AM Inconing
+1471 Jun 03 07:06 AM N PAL/ BCH, PL
+1472 Jun 03 07:19 AM Toll Pree Call
+1473 Jun 03 07:43 AM N PALE BCH, PL
+1474 Jun 03 07:57 AM PALA BCH,PL
+1475 Jun 03 08:22 AM
+Inconing
+1476 Jun 03 08:36 AM
+Inconing
+1477 Jun 03 09:38 AM
+W PALE BCH, PL
+1478 Jun 03 09:44 AM
+Incoring
+1479 Jun 03 09:0€ Aл
+Inconing
+1480 Jun 03 09:11 AM
+Inconing
+1481 Jun 03 09.13 AM Inconing
+1482 Jun
+AM N FALM ACH, PL
+1483 Jun
+03
+09:19 AM W PALM BCH, PL
+1404 Jun 03
+09:33
+DEERPLORCH, PL
+1485 Jun 03 09136 AM Incordng
+1486 Jun 03 10:04 AM Inconing
+Min: Sec
+561-255-3725 PP
+561-644-4989 PD
+561-364-5511 FF
+561-364-5511 PP
+361-377-3434 FD
+561-722-0047 PP
+561-964-5511
+FF
+561-722-0047
+PP
+561-541-5449
+FE
+561-333-5281
+FP
+561-989-4973
+PP
+361-889-4973
+561-889-4973 P0
+561-315-2500
+561-315-2500
+561-352-7000
+561-616-4240
+561-255-1015
+561-255-1015
+561-615-0011
+ce
+561-615-0011
+561-615-0011|
+DE
+561-562-1964
+eP
+561-722-8047
+FF
+561-358-7914
+PP
+888-777-2700
+PP
+561-644-9726
+FF
+561-541-4051
+PP
+561-502-38CE
+561-289-2669
+561-964-2515
+PP
+PP
+561-478-4188
+PP
+561-463-3964
+FP
+561-732-0604
+361-364-3835
+FF
+561-964-9300
+PP
+954-424-4144 PP
+561-541-5449 PP
+172-221-0274 FF
+Usage
+6:00
+2:00
+3:00
+2:00
+1:00
+7:00
+13:00
+1,00
+1:00
+1100
+6:00
+1:00
+7:00
+2:00
+1,00
+1100
+7:00
+2,00
+1:00
+1:00
+1:00
+1,00
+2:00
+2:00
+1:00
+1,00
+2:00
+8:00
+2,00
+2:00
+3:00|
+5:00
+1,00
+2:00
+7,00
+1:00
+3:00
+1:00
+3,00
+2:00
+9.00
+Long
+Distance
+0.0D
+0.0D
+0.0D
+0.DD
+0,00
+Total
+Charges
+U .UU
+0.OO
+0,00
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Item # Date Time
+Call To
+1457 Jun 03 10,14 AM M BALA BCH, FL
+1450 Jun 03 10:23 AM Incoming
+1450 Jun 03 10:32 AN Incoming
+1400 Jun 03 10:45 AM M BALK BCH, FL
+1491 Jun 03 10:48 A M FAL BCH, FL
+1492 Jun 03 10:49 AM W PALK BCH, PL
+1490 Jun 03 10:52 AM Inconleg
+1404 Jun 03 10158 1M Inconing
+1496 J: 03 11:04 A M FAL BCH, FL
+1406 Jun 03 12:08 AM Inconleg
+1407 Jun 03 11/10 AM Inconleg
+1498 Jun 03 11:16 A M PALAC BCH, FL
+1490 Jun 03 11:24 AM Inconieg
+1500 Jun 03 11:27 24 M BALK BCH, PL
+1501 Jun 03 11,32 AN
+Inconing
+1502 лив ол 11:34
+Incoeleg
+1500 Jun
+03 11:37 AM
+Incoming
+1504 Jun 03 11,41 AN
+Inconing
+1506 Jun 03 11:41 At Incoeleg
+1506 Jun 03 11:41 AM Inconing
+1507 Jun 03 12:47 1M Inconleg
+1508 Jun 03 11,53 AM Inconing
+1500 Jun 03 11:55 AN M PALE BCH, FL
+1510 Jun 09 11:59 AM N PALK BCH, PL
+1511 Jun 03 11:59 3N Inconing
+1512 Jun 03 12:14 PM Inconing
+1513 Jun 03 12:15 IN N PALK BCH, PL
+1514 Jun 03 12:19 PM Inconleg
+1515 Jun 03 12,59 EM M BALA BCH,PL
+1516 Jun
+i Incoeleg
+1517 Jun 03 01:18 IN BOCA RATON, PL
+1518 Jun 03 01:22 PM M PALE BCH, PL
+1519 Jun 03 01,27 PM N BALA BCH, PL
+1520 лил
+1521 Jun 03 01:34 PN M BALK BCH, PL
+1522 Jun 03 01,35 EM Inconleg
+1523 Jun 03 01:46 m Incaleg
+1524 Jun 09 01:47 PM M PALA BCH, PL
+1525 Jun 03 02:05 PM M PALE BCH, PL
+1528 Jun 03 02:45 PM Inconing
+1527 Jun 03 02:50 # Iscoeleg
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+561-478-4188 PP
+561-252-6406
+561-202-8497
+FP
+561-718-1592
+FP
+561-478-4188
+561-352-700009
+561-722-3311
+PP/CS
+561-722-0047
+561-6E3-1100
+561-541-5449
+Min: Sec
+FP
+FP
+561-478-5890
+561-478-4188|
+754-234-7799
+561-478-4188
+561-540-5779
+PP
+561-471-0395
+561-722-4511
+561-722-3311
+561-662-0902
+561-662-0902
+561-722-3311
+561-478-4188
+561-683-1100|
+561-683-1100
+561-722-3311
+561-202-8497
+561-723-1821
+561-723-1821
+PP
+FP
+PP
+PP
+FP
+FP
+561-723-3440
+561-667-3739
+561-394-8434
+561-478-4188
+PP
+SE1-420-4109
+561-667-3739
+561-202-8497
+561-842-6414
+561-615-0011
+561-820-3949
+561-615-0011
+PP
+FP/CW
+FF
+FP
+FP
+FF
+3:00
+2:00
+1:00
+CEOU
+4:00
+6:00
+1,00
+SLUU
+1:00
+1:00
+1:00
+1:00
+2:00
+1:00
+1:00
+1:00
+2: 00
+1:00
+2:00
+SIOU
+1:00
+1:00
+1,00
+1:00
+1:00
+2:00
+3:00
+3:00
+5:00
+1,00
+2:00
+1:00
+5100
+1: 00
+3: 00
+2:00
+2:00
+1:00
+Usage
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+6.00
+6.00
+0.0D
+0.0D
+•.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time
+Call To
+1528 Jun 03 02:53 EM PALA BCH,PL
+1529 Jun 03 03:36 IM W PALM BCH, PL
+1530 Jun 03 03:37 PM PALE RCH, PL
+1531 Jun 03 C4:04 EM Inconding
+1532 Jun 03 C4:38 In Inconing
+1533 Jun 03 64:46 I Inconing
+1534 Jun 03 05:10 PM DERRPLORCH, PL
+1535 Jun 03 05:15 EM N PAL/ BCH,PL
+1536 Jun 03 05:25 PM N FALE BICH, PL
+1537 Jun 03 05:26
+IN N PALE BCH ,PL
+1538 Jun 03 05:31
+W PALA BCH.PL
+1530 Jun 03
+IN BALANCH, PL
+1540 Jun 03 05:56 m
+W PALA BCH,PL
+1541 Jun 03 06:30 #M Inconing
+1542 Jun 04 06:00 2M
+Inconing
+1543 Jun 04 06:20
+10 7ol1 Fies
+1544 Jun 04 06:24 AM
+W PALA BCH, PL
+1545 Jun 04 06:29 AM
+Inconing
+1546 Jun 04 06:51
+1547 Jun 04 06:54
+AM
+N PALA BCH, PL
+1548 Jun 04 07:50 M
+1549 Jun 04 07,56 AM
+Inconing
+1550 Jun 04 07:59 лм
+VILALDERDE, PL
+1551 Jun 04 08:00 AM
+Inconing
+1552 Jun 04 08:08 AM N PALE BCH, PL
+1553 Jun 04 09:23 AM
+Inconing
+1554 Jun 04 08:27 AM N PALM BCH, PL
+1555 Jun 04 04:33 AM
+Inconing
+1556 Jun 04 09.33 AM Incondng
+1557 Jun 04 08:34 AM
+N FALE BICH,PL
+1568 Jun 04 08:43 AM BOYTONECH, PL
+1550 Jun 04 08:45 MM Inconing
+1560 Jun 04 08,50 AM N PALA BCH,PL
+1561 Jun
+1562 Jun 04 09:04
+Inconing
+1583 Jun 0e 09,05 AM
+Incondng
+1564 Jun 04
+AM
+Inconing
+1565 Jun 04 09:13 AM W PALA BCH, PL
+1506 Jun 04
+09:27
+Inconing
+1567 Jun 04 09,31 AM
+BOCA RATON,PL
+1568 Jun 08 09:32 AM
+Inconing
+Min: Sec
+561-541-5449 PP
+561-662-6688P0
+561-662-6648 FF
+561-723-1421 PP
+561-302-7753 FD
+561-502-7753 PP
+954-421-9324
+FF
+561-723-9450
+561-541-4023
+FE
+561-644-4939
+FP
+561-662-6698
+PP
+361-302-6617
+561-502-5212 PP
+561-445-3963
+561-662-6688
+561-444-9103
+361-844-3765
+561-844-9765
+561-478-4188
+561-722-4259 PP
+254-270-8701 FD
+954-270-8701
+561-683-1816
+FF
+561-965-5544
+PP
+561-842-6414
+PP
+772-223-0274 PR
+561-644-3726 PP/CH
+361-202-7640 FF
+561-577-6425 PD
+561-868-3479 PP
+561-478-4184 PP
+561-577-6425 PF
+561-432-3048 PP
+361-478-4188 FF
+561-827-2542 P0
+561-202-7640 PP
+561-289-9540 PP
+561-202-7640 FF
+Usage
+1100
+1:00
+4:00
+8:00
+1:00
+6: 00
+3:00
+1,00
+1:00
+1100
+2:00
+2:00
+3:00
+5:00
+1,00
+4:00
+6100
+2,00
+1:00
+4: 00
+1:00
+2,00
+2:00
+1:00
+1:00
+2100
+2:00
+1:00
+1,00
+2,00
+2:00
+1,00
+2:00
+2:00
+2:00
+1,00
+2:00
+9.00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0.DD
+0.DD
+0,00
+0-O0
+Total
+Charges
+U .UU
+0.OO
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time
+Call To
+1500 Jun C4 09,51 AM Inconing
+1570 Jun. 04 09:52 AM Incoming
+1571 Jun 04 10:05 AN Incoming
+1572 Jun C4 10:06 AM Inconing
+1573 Jun 04 10:12 AN Incoeleg
+1574 Jun C4 10:14 AM Incoming
+1575 Jun 04 10:19 AM Inconleg
+1578 Jun C4 10,35 1M Inconing
+1577 Jun 04 10:45 A M PAL BC, FL
+1578 Jun 04 10:48 34 Inconleg
+1579 Jun 04 11:00 AM M BAIA BCH, PL
+1580 Ju 04 11:04 A M BALA BCH, FL
+1581 Jun 04 11:23 AM N PALK BCH, PL
+1582 Jun. 04 11:27 1M Inconleg
+1583 Jun C4 11,36 AM Inconing
+1554 Ju. 04 12:41 A M PAL: BC, FL.
+1585 Jun 04 11:43 AM M DALM BCH, PL.
+1556 Jun 04 11,51 AN M BALK BCH, PL
+1557 Jun C4 12:0E W Incoeleg
+1588 Jun 04 12:18 PM & PALK BCH, PL
+1580 Jun 04 12:35 PM M BALE BCH, PL
+1500 Jun C4 12144 EM Inconing
+1591 Jun 04 01:09 IN M PALE BCH, FL
+1592 Jun 04 01:13 PM 5 PALK BCH, PL
+1580 Jun 64 03:17 IN M BALE BCH, PL
+1504 Jun 04 01,19 PM M BAIR BCH, FL
+1590 Jun 04 01:27 IN PILAUDERDL, PL
+1506 Jun 04 03:30 PM Inconleg
+1507 Jun 04 01,33 EN Inconleg
+1508 Jun C4 01:35 PM M BALAC BCS, PL
+1590 Jun 04 01:39 IN Iscoeieg
+1800 Jun 04 01:46 PM M PALE BCH, PL
+1801 Jun 04 01:47 PM Inconleg
+S600 Jun C4 01:5E IN LECDELEg
+1800 Jun 04 01:58 IN OCALA, PL
+1804 Jun 04 02,07 IN MIAMI, FL
+1006 Jun 04 02:11 H KIAMI, FL
+1006 Jun 04 02:14 W Inconieg
+1607 Jun 04 02:15 PM M PALE BCH, PL
+1808 Jun 04 02,16 PM M BALK BCH, FL
+1000 Jun. 04 02:17 PN M FALK BCH, PL
+Min: Sec
+Usage
+561-541-5449 FP
+561-722-0047 VP
+561-655-8620
+FP
+561-827-2542
+PP/CW
+561-965-5507
+561-659-345209
+561-722-0047
+FP
+561-436-5794
+561-848-0330
+561-844-9765
+1:00
+2:00
+2:00
+561-790-5387
+FP
+FP
+561-541-5449
+561-358-7914
+561-502-3866
+561-840-1206
+563-541-5442
+561-840-1206
+561-644-4989
+561-723-1821
+561-622-8182
+561-541-5449
+301-608-0584
+561-662-66E8
+561-582-1964
+561-615-0011
+561-478-4188
+954-581-4200
+561-723-3440
+PP
+FP
+FP
+PP
+FP
+FP
+561-577-5425
+561-795-9549
+561-478-4188
+561-358-7914
+561-124-14911
+352-671-3406
+305-688-1101
+305-6EE-1101
+561-202-8497
+561-723-3440
+561-478-4188
+561-723-1851
+FP
+FP
+FF
+FP
+FP
+FF
+1:00
+3:00
+1:00
+5:00
+2:00
+4:00
+1:00
+1:00
+1:00
+4:00
+$:00
+2:00
+1:00
+1:00
+2: 00
+9:00
+4:00
+4:00
+2:00
+2:00
+3:00
+3:00
+1:00
+2:00
+2:00
+1:00
+1,00
+2:00
+2:00
+2400
+JE0O
+1:00
+1:00
+1:00
+1:00
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time
+Call To
+1610 Jun 04 02:17 EM W PALM BCH, PL
+1611 Jun 04 02:20 IM Incoming
+1612 Jun 04 02:24 PM Inconing
+1613 Jun 04 02:47 PM W PAL BCH ,PL.
+1614 Jun 04 02:49 PM N BALA BCH, PL
+1615 Jun 04 02:50 IN N PALE BCH, PL
+1616 Jun 04 02:51 PM Inconing
+1817 Jun 04 02152 EM Inconing
+1618 Jun 04 03:05 W Inconing
+1819 Jun 04 03:19 PM LAUREL.,AD
+1820 Jun 04 03:23
+W PALA BCH,PL
+1621 Jun 08
+m Inconing
+1622 Jun 04 03:45 IM Incoring
+1823 Jun 04 04:07 ## Inconing
+1624 Jun 04 64:15 EM Inconing
+1625 Jun 04 04:19 PM N FALA RCH, PL
+1626 Jun 04 05:10 IM Incoming
+1627 Jun 04 05.13 #M Inconing
+1628 Jun 04 05:16 IN SALE BCH, PL
+1629 Jun 04 05:58 IM W PALM BCH ,PL
+1630 Jun 04 06:08 PM BOYTONBCH, PL
+1631 Jun 04 06:11
+EM W PALM BCH,PL
+1632 Jun 06 06:15 M N BALA RCH, PL
+1633 Jun 04 66:16 IM N PALA BCH, PL
+1634 Jun 04 06:26 IM Inconing
+1635 Jun 04 06:39 #M N PALM BCH ,PL
+1636 Jun 04 06:58 IM Inconing
+1637 Jun 04 06:59 PM Inconing
+1638 Jun 04 07,05 EM W PALA BCH,PL
+1630 Jun 0a
+07:20 IN N FACE BICH, PL
+1640 Jun 04 07:27 IN N PALA BCH, PL
+1641 Jun 05 06:44 AM N PALE BCH, PL
+1642 Jun 05 08,10 AM N PALM BCH,PL
+1643 Jun 05 08:28 AM N FACE RCH, PL
+1644 Jun 05 08:30 AM Inconing
+1645 Jun 05 08:41 AM
+IncoRing
+1646 Jun 05 08:42 AM N FALE NCH, PL
+1647 Jun 05 09:09 AM W PALA BCH, PL
+1640 Jun 05
+09:16
+N PALE BCH, PL
+1649 Jun 05 09117 AM Inconing
+1650 Jun 05 09:17 AM Inconing
+Min: Sec
+561-723-1421 PP
+561-362-9191 PD/CH
+561-358-7914 FF
+561-427-2542 PP
+561-252-4383 FD
+561-252-4383 PP
+561-427-2542 FP
+561-647-2994 PP/CH
+561-252-4383 FE
+240-593-4162 FF
+561-722-0047 PP
+361-302-1212 FD
+240-593-4162 PP
+561-202-3497 PR
+44544
+561-502-5212
+PP
+561-202-8497
+561-722-0047
+PP
+561-577-6425
+561-352-7000
+PP
+561-793-4189 FD
+561-602-2291
+561-722-8047
+561-965-1305
+561-644-4989
+561-644-4949
+561-662-6698
+FF
+PP
+PP
+FF
+PP
+561-644-3726
+561-602-2291
+561-723-3450
+PP
+ce
+561-795-9549
+561-541-5449
+561-541-5449
+De
+361-795-3542
+561-502-3666
+561-541-5449 CE
+561-644-4949 C8
+561-341-3449 DE/CN
+3:00
+1:00
+3:00
+2:00
+1:00
+1:00
+2:00
+3:00
+4: 00
+1100
+3,00
+2:00
+12:00
+1:00
+1,00
+21 DO
+21O0
+3,00
+2:00
+2:00
+3:00
+1,00
+1:00
+6:00
+10:00
+18:00
+2:00
+1:00
+5:00
+2:00
+4: 00
+1:00
+1,00
+1:00
+1,00
+3:0D
+1:00
+1:00
+1,00
+1:00
+Usage
+9.00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0.DD
+0.DD
+0,00
+Total
+Charges
+U .UU
+0.OO
+0,00
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+Number
+Footnote
+1851 Jun 05 09124 JM Inconing
+561-541-5449 OP
+1652 Jun. 05 11:26 AM Incoming
+561-722-0047 OP
+1853 Jun OS 12:21 PM Inconleg
+561-827-2542 OP
+1854 Jun 05 12:44 PM M BALA BCH, FL
+561-541-5449
+1055 Jun 03 12:59 N Incoeleg
+561-827-2542
+OF
+1656 Jun 05 01:03 PM Incoming
+561-577-6425
+1857 Jun 05 03:13 IN M BALK BCH, PL
+561-722-0047
+OP
+1858 Jun 05 01:50 PM M BALA BCH, FL
+561-541-5449
+1650 Ju: 05 02:42 IN Incoaleg
+561-541-5443
+OF
+1650 Jun O5 03:17 PM M BALAS BCH, PL
+561-502-5212
+OP
+1081 Jun O5 03118 EM Inconleg
+561-722-0047
+OP
+1082 Jun 03 03:22 m Iscoeleg
+561-502-5212
+1663 Jun 05 03:28 IM N PALA BCH, PL
+561-723-3440
+OP
+1854 Jun 05 03:31 PM Inconleg
+561-827-2542
+OP
+1086 Jun 05 03,59 EM N BALA BCH, PL
+561-541-5449
+169 Ju: 05 04:10 Inchelag
+561-722-0047
+1057 Jun
+05 04:18 DM M PALA BCH, PL
+561-452-7000
+1058 Jun 05 04:23 PM Inconing
+561-124-1491
+OP
+1050 Jun 05 04:30 IN M PALE BCH, VL.
+1570 Jun 05 04:33 PM N PALK BCH, PL
+1871 Jun 05 04:35 PM Inconteg
+1872 Jun 05 04:46 EM Inconing
+1673 Jun 03 05:32 #N Incoeleg
+1674 Jun 05 05:41 PM 5 PALK BCH, PL
+1875 Jun 05 05:42 PM Inconleg
+1876 Jun 05 05151 PM M BAIR BCH, FL
+1677 Jun 05 06:20 IN N PALK BCH, PL
+1878 Jun 05 06:31 PM M BALAS BCH, PL
+1879 Jun 05 06,34 EM M BALA BCH, PL
+561-622-8182
+561-827-2542
+561-827-2542
+561-622-8182
+561-722-0047
+561-541-5449
+561-827-2542
+561-333-7530
+561-662-6616
+561-662-6616
+561-662-6616
+OP
+OP
+OP
+OP
+OP
+OP
+OP
+1880 Jun 09 DE:3E PM M BALAE BCS, PL
+861-131-7510
+1681 Jun 05 07:31 W Incoleg
+561-379-9891
+1882 Jun 05 09:30 PM M PALE BCH, PL
+1883 Jun 06 10,14 2M Inconleg
+561-722-0047
+OP
+1854 лил
+04E
+583-723-9450
+1885 Jun 06 05:32 PM Isoleg)
+OP
+1858 Jun 06 06,17 PN N BALK BCH, PL
+1857 JuL 06 06:14 m Incaleg
+1688 Jun 06 06:53 PM M PALA BCH, PL
+1880 Jun 04 06:54 PM M PALE BCH, PL
+1800 Jun 07 06:49 JM Incoming
+1091 Jun 07 DE:SE AN Iscoeleg
+561-644-4989
+561-644-4989
+561-616-8240
+561-723-3440
+561-723-1821
+561-502-5212
+OF
+OP
+OP
+OF
+Min: Sec
+1:00
+5:00
+1:00
+1:00
+2:00
+2:00
+1,00
+1:00
+1:00
+2:00
+1:00
+2:00
+2:00
+2:00
+5:00
+1:00
+1:00
+2:00
+2:00
+1:00
+1:00
+3,00
+2:00
+2:00
+1:00
+E:00
+1:00
+2:00
+1,00
+2:00
+1:00
+1:00
+2: 00
+1:00
+2:00
+$:00
+1:00
+Usage
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+$.00
+6.00
+6.00
+0.0D
+•.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+1892 Jun 07 06157 AM Incordng
+561-654-9447 08
+1100
+1693 Jun 07 07:04 AM PALE BCH, PL
+561-662-6688P0
+9:00
+1604 Jun 07 07:15 AM Inconing
+561-123-1821 FF
+4:00
+1005 Jun 07 07,19 AM PALA BCH, PL
+561-541-5449 PP
+1,00
+1600 Jun 07 07:21 AM Inconing
+561-341-3449 FD
+1:00
+1097 Jun 07 07:28 AM W PALM BCH, PL
+561-795-9549 PP
+3: 00
+1800 Jun 07 07:45 AM PALE BCH,PL
+561-541-4051 FP
+1:00
+1690 Jun 07 07:57 AM PAL/ BCH ,PL
+561-541-4051
+PP
+1,00
+1700 Jun 07 08:03 AM Inconing
+561-712-2014 FE
+1:00
+1701 Jun 07 09:04 AM Inconing
+561-379-9891
+FP
+3:00
+1702 Jun 07 09:10 AM
+Inconing
+561-478-4188
+PP
+3,00
+1703 Jun 07 08:17 AM Inconing
+561-414-E81E FF
+1:00
+1704 Jun 07 08:18 AM W PALA BCH, PL
+561-723-3440 P8
+1:00
+1705 Jun 07 08:23 AN FACE BCH, PL
+561-582-1964 PR
+1:00
+1708 Jun 07 09:24 AM W PALA BCH, PL
+561-542-1964
+6:00
+1707 Jun 07 08:37 AM Incoming
+3:00
+1708 Jun 07 08:40 AM W PALA BCH, PL
+4471-1441
+1700 Jun 07 04:40 AM I PALE BCH,PL
+1710 Jun 07 08:47 AM N SALE BCH, PL
+1711 Jun 07 68:56 AM MIAMI, PL
+1712 Jun 07 08:59 AM Inconing
+1713 Jun 07 09:02 AM W PALA BCH, PL
+1714 Jun 07 09:04 AM Inconing
+1715 Jun 07 09:06 AM N PALA BCH, PL
+1716 Jun 07 09:09 AM N PALE BCH, PL
+1717 Jun 07 09:16 AM Incondng
+1718 Jun 07 09:21 AM N PALM BCH, PL
+1719 Jun 07 09:25 AM
+Inconing
+1720 Jun 07 09124 AM Incondng
+1721 Jun 07 09:28 10
+N FALE BICH,PL
+561-123-1421
+PP
+561-478-4188
+305-796-3825
+PP
+561-664-3559
+561-686-4924
+PP
+561-684-3568 FD
+561-478-4188
+eP
+561-478-4188
+FF
+561-666-9977
+PP
+561-252-4654
+PP
+561-252-4654
+561-474-4148
+PP
+561-478-4188
+2,00
+2:00
+3: 00
+1:00
+1,00
+2:00
+2:00
+4: 00
+2100
+2:00
+3:00
+1,00
+1:00
+1722 Jun 07 09:32 AM Inconing
+561-638-4999
+1723 Jun 07 09:40 AM
+W PALE BCH,PL
+1724 Jun 07 09:48 AM
+Incoring
+561-354-7914
+407-660-2552
+4: 00
+2:00
+3,00
+1725 Jun 07 09:58 AM
+Inconing
+1726 Jun 07 10:06
+Inconing
+1727 Jun 07 10:07 AM PILAUDERDE, PL
+1728 Jun
+AM
+Inconing
+1729 Jun 07 10:33 AM
+Inconing
+1730 Jun 07 10:44 AM
+Inconing
+1731 Jun 07 10:49 AM Inconing
+1732 Jun 07 10:54 AM Inconing
+eP
+FF
+561-202-4497
+FP
+954-654-0974 PP
+254-658-0974 FF/CH
+561-202-8497 P0
+954-345-4764 PP
+954-650-3393 PP/CH
+561-721-1821 FF
+1:00
+2,00
+5:00
+1:00
+9:00
+4:00
+2:00
+Usage
+9.00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0. 00
+0.DD
+0.DD
+0,00
+0-O0
+Total
+Charges
+U .UU
+0.OO
+0,00
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+1733 Jun 07 10,58 AM Inconing
+561-742-2363 FP
+1:00
+1734 Jun 07 11:10 AM N PALK BCH, PL |
+561-723-1821
+2:00
+1735 Jun 07 12:27 AN Incoming
+561-723-9450
+FP
+1736 Jun 07 11:51 AM M BALK BCH, FL
+561-723-9450
+1737 Jun 07 11:57 AN INcaleg
+561-721-3212
+1730 Jun 07 11:59 AM N PALK BCH, PL
+561-723-1821
+1:00
+1730 Jun 07 12:06 PM Inconleg
+561-723-1821
+FP
+5:00
+1740 Jun 07 12:11 PM Inconing
+954-650-3393
+FP
+1,00
+1741 J: 07 12:33 # Incoaleg
+561-827-2542
+1:00
+1742 Jun 07 12:42 PM M BALAS BCH, PL
+561-827-2542
+FP
+1:00
+1743 Jun 07 12:42 EM M BAIM BCH, PL
+561-827-2542
+FP
+1:00
+1744 Jun 07 01:31 m Iscoeleg
+561-723-1821
+4:00
+1745 Jun 07 01:34 IM Ieconieg
+561-723-3440
+2:00
+1748 Jun 07 01:35 PM Inconleg
+561-723-3440
+FP
+1:00
+1747 Jun 07 01,36 EM N BALA BCH, PL
+561-722-1440
+1:00
+1748 Ju. 07 01:50
+IN DEEPLECH, PL
+954-650-3393
+1:00
+1748 Jun
+Incoming
+454-650-4545
+1:00
+1750 Jun 07 02:04 PM Inconing
+561-827-2542
+PP
+1751 Jun 07 02:05 mIscoeleg
+561-827-2542
+1752 Jun 07 02:49 PM N PALK BCH, PL
+561-662-6688
+1753 Jun 07 04:21 PM M BALK BCH, PL
+561-723-3440
+1754 Jun 07 04:22 EM Inconing
+561-478-4188
+FP
+PP/CS
+2: 00
+3:00
+7,00
+1755 Jun 07 04:29 IN M PALE BCH, FL
+561-723-3440
+SIOU
+1756 Jun 07 04:33 PM LAUREL MD
+240-593-4162
+1757 Jun 07 04:37 IN NISHI, PL
+305-796-3825
+1758 Jun 07 05,38 PM M BAIR BCH, FL
+561-721-5212
+FP
+PP
+1750 Jun 07 07:49 IN Inconieg
+561-848-9770
+1780 Jun 07 08:07 PM Inconleg
+561-924-8880
+1:00
+1:00
+5:00
+2:00
+3:00
+1781 Jun 07 08:09 EM Inconleg
+1762 Jut 07 08:12
+Incoeleg
+561-541-5449
+561-924-888D
+FP
+PP/CS
+FP
+1:00
+2:00
+1763 Jun 07 08:39 WM Iscoeleg
+561-723-3440
+9:00
+1764 Jun 07 08:45 PM Inconteg
+PP/CW
+1:00
+1786 Jun 07 08,50 PM N BALA BCH,PL
+561-352-7000
+PP
+2:00
+1705 лл.
+GT DEISA PR LECOBLEgI
+5E-024-62el
+TrOO
+1767 Jun 07904 play
+1768 Jun 07 09,42 IN N BALK BCH, PL
+OP
+OP
+1700 Jun 04 05:22 A M PALE BCH, VL.
+1770 Jun 09 06:24 AM Incoming
+1771 Jun 04 06:49 AM Inconleg
+1772 Jun 09 06:50 AM Inconing
+1773 Jun 08 DE:52 AM M FALK BCH, PL
+561-723-3440
+561-827-2542
+561-723-9450
+561-723-1821
+561-723-3440
+561-502-5212
+OP
+OF
+2: 00
+3: 00
+2:00
+2:00
+3:00
+Usage
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+0.0D
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+0000
+D.D0
+D.D0
+0.00|
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+1774 Jun 08 06:55 AM Incondng
+561-723-3450CP
+2100
+1775 Jun 08 07:15 AM N PALA BCH, PL
+561-827-2542 PP
+1:00
+1776 Jun 08 07:42 AM Inconing
+561-365-4959 FF
+2:00
+1777 Jun 08 07,56 AM PILAUDERDC, PL
+954-541-4200 PP
+1,00
+1778 Jun 0e 08:13 AM Inconing
+561-827-2542 FD
+1:00
+1779 Jun 08 08:23 2M Incoming
+561-924-3880 PP
+1:00
+1780 Jun 08 04:30 AM Inconing
+561-427-2542
+FF
+3:00
+1781 Jun 08 09:37 AM N PAL/ BCH,PL
+561-502-3666 PP
+1,00
+1782 Jun D8 08:42 AM Inconing
+561-820-3543
+FE
+2:00
+1783 Jun 08 08:55 AM Inconing
+561-202-3497
+FF
+1100
+1784 Jun 08 09:56 AM PALA BCH,PL
+561-723-1421
+PP
+2:00
+1785 Jun De 08:58 A STUART, PL
+772-223-0274 FD
+1:00
+1786 Jun 08 09:17 AM Inconing
+561-541-4051 PD
+1:00
+1787 Jun 08 09:24 AM Inconing
+561-541-4051
+1,00
+1788 Jun 08 09,30 AM W PALA BCH, PL
+a72345
+1780 Jun De 09:36 AM Inconing
+1:00
+1790 Jun 08 09:40 AM
+Incoming
+1791 Jun 08 09:44 AM
+Inconing
+1792 Jun 08 09:47 AM% SALE BCH, PL
+1793 Jun 08 09:54 AM
+Inconing
+1794 Jun 08 09:56 AM Inconing
+1795 Jun 08 10:56 AM Inconing
+1796 Jun De 11:09 AM Inconing
+1797 Jun 08 11:28 AM Incoming
+1798 Jun 08 12:11 IM Inconing
+1799 Jun 08 12:12 EM N PALM BCH ,PL
+1800 Jun 08 12:25 IM Incoming
+561-202-8497
+561-420-3949
+PP
+361-792-2025
+561-924-8880
+PP
+561-202-2497
+954-345-4748 PP
+561-723-1821 FD
+561-502-5123
+561-202-4497
+561-933-4634
+561-577-5694
+FF
+PP
+PP
+1801 Jun 08 12:34 PM Inconing
+561-202-4497
+1802 Jun 08 01.01 EM Incondng
+561-662-3098
+PP
+1803 Jun D8 01:0€ #M
+Inconing
+4:00
+2:00
+2:00
+1:00
+2,00
+1:00
+1:00
+1:00
+4:00
+2:00
+1:00
+1,00
+2:00
+1804 Jun 08 01:11 I Incoming
+561-478-4188
+PD
+4:00
+1805 Jun 08 01:17 m
+Inconing
+2:00
+1808 Jun 0801:31 M
+Incoring
+1807 Jun 08 03:59 m
+N FALA RCH, PL
+1808 Jun 08 04:05 PM N PALA BCH, PL
+1809 Jun 08 04:53 PM N PALM BCH, PL
+1810 Jun 0805:01/MIANI,PL
+1811 Jun 08 05:04 IN MIAMI, PL
+1812 Jun 08 05:07
+IN PALM BCH, PL
+1813 Jun
+JUPITER, FL
+1814 Jun 08
+Inconing
+561-255-3725
+361-662-600E
+561-662-6648
+PP
+FF
+FF
+561-662-6688
+105-796-3825
+FF
+305-796-3625 PD
+561-714-1522 PP
+561-744-4703 PP
+561-202-7640 FF
+2100
+21 DO
+4: 00
+7,00
+1:00
+1:00
+2:00
+4:00
+4: 00
+Usage
+9.00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0.DD
+0.DD
+0,00
+0-O0
+Total
+Charges
+U .UU
+0,00
+
+
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+1815 Jun 04 06155 IN M BALA BCH, FL
+561-722-0047 PP
+1:00
+1816 Jun 09 06:48 AM Incoming
+561-502-5212 OP
+2:00
+1817 Jun 09 D6:57 AN Inconleg
+561-827-2542 HIP
+21:00
+1818 Jun 09 07:21 AM M BALA BCH, FL
+561-722-0047
+SLUU
+1819 Ju 07 07:42 ЛН M РАЦК BCH, FL
+5E1-EB3-1816
+1820 Jun 09 07:56 AM N PALK BCH, PL
+561-662-6688
+8:00
+1621 Jun 08 08:19 AN Inconleg
+561-965-4989
+FP
+3:00
+1822 Jun 09 08150 1M Inconing
+561-255-1015
+4:00
+1823 Ju: 09 08:05 A BOTTONCH, FL.
+561-577-6425
+FF
+-EUU
+1824 Jun 09 09:27 AM M BALE BCH, PL
+561-662-6688
+FP
+2:00
+1825 Jun 09 09,29 AM Inconleg
+561-694-9402
+FP
+2:00
+1825 Jun 03 03:46 AL M BALA BCH, FL
+561-236-6852
+3:00
+1827 Jun 09 09:53 AM N PALA BCH, PL
+561-670-6732
+19/N09
+1:00
+1828 Jun 09 09:54 1M Inconleg
+561-582-9575
+FP
+2:00
+1829 Jun 09 09,59 AM BOYTONBCH, FL.
+561-577-6425
+PP
+1:00
+1830J 0710:00 A BOSTONCH, FL.
+561-577-6425
+1:00
+1831 Jun 09 10:03 AM Inconing
+561÷577-6425
+1:00
+1832 Jun 09 10,05 AN M BALK BCH, PL
+561-820-3949
+PP
+2:00
+1833 Jun 07 10:0E At Incoeleg
+561-577-6425
+1834 Jun 09 10:19 AM Incoming
+561-577-6425
+1835 Jun 09 10:22 AM BOTTONBCH, PL.
+561-577-6425
+1836 Jun 09 11:03 AM M BALK BCH, FL
+561-683-5970
+FP
+PP
+1837 Jun 07 11:0E AN M PALE BCH, FL
+561-845-1946
+1838 Jun 09 11:34 ЗМ ЛОРІТНЯ , PL
+561-744-4703
+1830 Jun 08 12:29 PM Inconleg
+561-820-3949
+FP
+1840 Jun 09 12:48 PM Inconing
+561-723-1821|
+1841 Jun 09 12:52 IM PILAUDERDG, PL
+954-444-6836
+1842 Jun 09 02:05 PM Inconleg
+561-723-1821
+1:00
+1:00
+1:00
+3:00
+2:00
+2:00
+4:00
+2:00
+1:00
+1843 Jun 09 01128 EN Inconleg
+FP
+FP
+1844 Jun 03 01:39 IN Incaleg
+561-502-5123
+561-723-1821
+2:00
+1:00
+1845 Jun 09 01:44 IN Iscoeleg
+561-723-1821
+1:00
+1846 Jun 09 01:59 PM Inconteg
+7:00
+1847 Jun 09 02,05 PM Inconleg
+561-721-5212
+1848 un.
+S61-723-1021
+1840 Jun 09 02:25 PM Isoleg)
+FP
+1850 Jun 09 02,36 IN N BALK BCH, PL
+1851 Ju 07 02:37 # M PALE BCH, VL.
+1852 Jun 09 02:41 PM M PALK BCH, PL
+1853 Jun 09 02:48 PM M PALE BCH, PL
+1854 Jun 09 02,52 PM Inconing
+1855 Jun 07 02:57 PN M FALK BCH, PL
+561-352-4000
+561-352-7000
+561-729-1821|
+561-841-9007
+561-841-9007
+561-827-2542
+FF
+FP
+FP
+FF
+7:00
+5:00
+2:00
+1:00
+2: 00
+4: 00
+1:00
+$:00
+2:00
+Usage
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+4.00
+0.0D
+0.0D
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0.00|
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time
+Call To
+1856 Jun 09 02159 EM W PALA BCH, PL
+1857 Jun 09 03:29 IM W PALM BCH, PL
+1458 Jun
+03:44 PM W PALE RCH, PL
+1850 Jun
+03152 FM N PALA BCH, PL
+1880 Jun
+03:53 PM FALA NCH,PL
+1861 Jun 09
+04:10 IM N PALM BCH, PL
+1862 Jun 09
+04:12 PM N PALE BCH ,PL
+1863 Jun 09
+04.17 EM Inconing
+1864 Jun 03
+04:33 IN FALE NICH, PL
+1885 Jun 09
+04:43 PM W PALE BCH, PL
+1800 Jun 09
+Inconing
+1867 Jun 03
+1868 Jun 09
+04:56 IM N PALA BCH, PL.
+1880 Jun 09 04:57 PM W FACE BCH, PL
+1870 Jun 09 04:54 EM JUPITER, FL
+1871 Jun 03 04:59 PM N BALA RCH, PL
+1872 Jun 09 05:00 IM JUPITER, PL
+1873 Jun 09 05,12 #M
+BOCA RATON, PL
+1874 Jun 03 05:32 IN SALE BCH, PL
+1875 Jun 09 05:41
+INCORLET
+1876 Jun 09 05:50 PM N FALE BCH, PL
+1877 Jun 09 06:04 EM N PALM BCH, PL
+1878 Jun 03 06:03mM Incoming
+1879 Jun 09 06:15 IM N PALA BCH, PL.
+1880 Jun 09 06:16 PM N FALK BCH, PL
+1881 Jun 09 06137 EM N PALM BCH, PL
+1882 Jun 10 06:57
+AM
+Inconing
+1883 Jun 10 07:07 AM N PALE BCH, PL
+1884 Jun
+10 07,59 AM
+Inconing
+1885 Jun
+08:05 A N FACE BICH, PL
+1886 Jun 10
+08:17 AM I PALM BCH, PL
+1887 Jun 10 08:35 M
+Inconing i
+1888 Jun 10 08:36 AM
+Incoring
+1889 Jun
+Inconing
+1890 Jun 10
+Inconing
+1891 Jun 10
+09.17 AM Inconing
+1892 Jun
+0TE200
+Inconing
+1893 Jun
+09:31 AM Incoming
+1894 Jun
+09:35
+Inconing
+1895 Jun
+09:42 AM
+1806 Jun 10
+AMN FALL RCH, PL
+Min: Sec
+561-945-1946 PP
+561-502-5212 PP
+561-502-7753 FF
+561-647-4791 PP
+561-687-8791 FD
+561-434-9897 PP
+561-723-3440
+FF
+561-541-5449 PP
+561-123-1821
+561-502-7753
+954-214-5343
+FP
+PP
+361-662-6088
+561-123-1821 PP
+561-723-3823
+561-262-0911
+561-841-2007
+561-262-0911
+PP
+561-176-2305
+PP
+561-776-2305
+PP
+561-302-3212 FD
+561-644-4989
+561-333-7530
+FF
+561-644-4989
+PP
+561-324-1491
+561-582-1964
+561-255-3725
+FF
+PP
+561-841-2007
+561-541-4051
+561-502-5212
+561-968-3479
+PP
+561-502-7753
+561-502-7753
+FP
+561-202-8497
+361-747-2467
+FF
+561-827-2542
+PP
+561-742-6000 PP
+561-659-2040 PP
+561-E94-2040 FF
+Usage
+2100
+1:00
+3:00
+1,00
+1:00
+3: 00
+1:00
+2,00
+2:00
+1100
+2:00
+6: 00
+1:00
+1:00
+1,00
+1:00
+1:00
+2:00
+3: 00
+2:00
+1,00
+4: 00
+1:00
+1:00
+2100
+1:00
+1:00
+2,00
+1:00
+2:00
+1:00
+3: 00
+2:00
+2,00
+2:00
+2:00
+3:00
+1,00
+1:00
+9.00
+0.0C
+Long
+Distance
+0.0D
+0.0D
+0.0D
+Total
+Charges
+U .UU
+0,00
+0.DD
+0,00
+
+
+* 1.2010.01
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time
+Call To
+1897 Jun 19 09:43 AM M BALA BCH, FL
+1890 Jun 10 09:47 AM • PALK BCH, PL
+1800 Jun 10 09:50 AN M PALK BCH, PL
+1900 Jun 10 09,54 AM M BALK BCH, FL
+1001 Jun 10 10:10 AN INCElag
+1902 Jun 10 10:15 AM N PALK BCH, PL
+1900 Jun 10 10:16 AM M BALK BCH, PL
+1004 Jun 14 10:41 AN JUPITER,FL
+1906 Jun 10 10:43 A M FAL BCH, FL
+1908 Jun 18 10:46 AM M BALE BCH, PL
+1907 Jun 10 10:46 AM Inconleg
+1908 Jun 10 10:48 A M PALAC BCH, FL
+1908 Jun 10 10:49 AM N PALK BCH, PL
+1910 Jun 10 10:50 JM Inconleg
+1Q11 Jun 10 10,54 AM N BALA BCH, PL
+1912 Jun 10 11:0E AN Incoeleg
+1913 Jun 10 11:11 AM & DALK BCH, PL.
+1914 Jun 10 11:18 AM Inconing
+1915 Jun 10 11:21 At Incoeleg
+1916 Jun 10 11:24 AM Isconing
+1917 Jun 10 12:26 AM M BALK BCH, PL
+1918 Jun 10 11:29 AM M BALK BCH, FL
+1919 Jun 10 11:32 AN Incoeleg
+1820 Jun 10 11:44 AM Incoming
+1921 Jun 10 11:49 AM M BALE BCH, PL
+1922 Jun 19 12:03 PM Inconing
+1823 Jun 10 12:18 IN N PALK BCH, PL
+1924 Jun 14 12:21 PM Inconleg
+1025 Jun 10 12,31 EN Inconleg
+1925 Jun 10 12:34 PM M BALAC BCS, PL
+1827 Jun 10 12:48 IM M PALK BCH, PL
+1928 Jun 14 01:21 PM Inconteg
+1029 Jun 10 01,25 EM BOCA RATON, PL
+1930 лл.
+10 01129 PR LEDELEgI
+1931 Jun 10 01:48 MInoleg
+1932 Jun 10 01,54 PM N BALK BCH, PL
+1933 Jun 10 02:05 # Incaleg
+1934 Jun 10 02:07 PM M PALA BCH, PL
+1935 Jun 10 02:30 IM Inconleg
+1036 Jun 10 02:42 PM M BALK BCH, PL
+1937 Ju 10 02:4E IN Iscoeleg
+Min: Sec
+561-659-4020 FP
+561-478-4188 VP/NN
+561-582-1964
+FP
+561-502-5123
+FP
+561-659-3452
+561-662-3098
+561-478-4188
+FP
+561-262-0911
+561-662-EGE8
+561-478-4822
+FP
+561-502-5123
+561-502-5123
+561-723-1821
+561-659-4069
+561-502-5123
+561-827-2542
+S61÷428-418m
+561-476-41-
+561-202-8497
+561-964-1125
+561-502-5123
+561-478-4188
+561-502-5212
+561-478-4188
+561-827-2542
+561-625-3319
+561-502-7753
+561-202-8497
+561-502-7753
+561-582-1964
+561-502-7753
+561-445-0690
+563-445-0690
+954-345-8788
+561-868-3479
+561-86E-3479
+561-729-1821|
+561-502-5212
+561-478-4188
+561-478-6188
+PP/CS
+PP
+PP
+FP
+PP
+FP
+PP
+FP
+FP
+PP
+FP
+FF
+PP
+FP
+FF
+Usage
+4:00
+1:00
+2:00
+SECU
+1:00
+4:00
+2:00
+SLUU
+1:00
+2:00
+1:00
+2:00
+1:00
+1:00
+2:00
+2:00
+2:00
+1:00
+3:00
+TROU
+4:00
+2:00
+1,00
+1:00
+1:00
+3:00
+2:00
+2:00
+1:00
+1,00
+2:00
+6:00
+2: 00
+8: 00
+3:00
+2:00
+4:00
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+0.0D
+$.00
+6.0D
+6.00
+0.0D
+•.00
+$,0B
+0.0D
+6.00
+0.0D
+•.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+C (561) 662-6688 continued...
+Telecommunications Services Call Detail (561) 662-6688
+See
+Number
+Footnote
+Item # Date Time
+Call To
+1938 Jun 10 03:24 EM W PALA BCH, PL
+1939 Jun 10 09:49 IM NPALM BCH, PL
+1940 Jun 10 03:52 PM N PALE RCH, PL
+1941 Jun 10 03,58 FM PALA BCH,PL
+1942 Jun 10 04:05 IN SALE BCH, PL
+1943 Jun 10 64:44 I Inconing
+1944 Jun 10 05:22 PM PILAUDERDG, PL
+1945 Jun 10 05151 EM Incondng
+1946 Jun 10 06:02 W Inconing
+1947 Jun 10 07:14 PM Inconing
+1948 Jun 10 07:16 EM Inconing
+1949 Jun 1007:19 SALE BCH,L
+1900 Jun 10 07:27 IM W PALA BCH, PL
+TOTAL
+Min: Sec
+Long
+Distance
+561-965-5507 PP
+561-662-6688P0
+561-723-3440 FF
+561-236-6852 PP
+561-352-700D FD
+561-722-0047 PP
+954-658-8974
+FF
+561-502-5212
+PP
+561-856-430E
+561-865-5507
+FF
+561-577-6425 PP
+361-329-0783 FF
+561-236-6852 PP
+1100
+4: 00
+5:00
+1,00
+1:00
+15:00
+1:00
+2,00
+1:00
+2:00
+1,00
+1:00
+2:00
+4661,00
+Usage
+9.00
+0.0D
+B.DD
+0.0D
+B. DD
+0.0D
+80.00
+Footnote
+Features
+CW-Call Wating
+CF-Call Forwarding
+3WThree Viay Cal
+DS-Dialup Service
+Networks
+Services
+N-National Network
+- Alternate L
+-Canadian Network PU-Plan/Promotional Usa
+Wl-Nedel Worldwide PF-Partial Free
+WD-Worldwide Discount FC-Free Call
+TJ Tuana Network
+Time Period
+PP-Peak Period
+OP-Off Peak Period
+MP-Muticle Period
+(561) 662-6813
+Telecommunications Services Call Detail (561) 662-6813
+See
+Item # Date Time Call To
+Number
+Footnote
+1 Kay 18 03:48 PM Cuatcear Care
+611
+2 Kay 18 03:48 PM Custoeer Care
+611
+3 Key 20 03:39 PM Deergency
+911
+4 Jun oe 04:45 IM teargency
+FP/PC
+PP/PC
+p/PC
+TOTAL
+Min: Sec
+1:00
+5133
+1111
+1:55
+9:39
+Usage
+Long
+Distance
+0.0D
+0.DD
+0.0D
+80.00
+Footnote
+Features
+CW-Call Wating
+CF-Call Forwarding
+JWThree Viay Call
+DS-Dialup Servie
+Networks
+Services
+NN-National Network
+L » Alternate Li
+V-Canadian Network PU-Plan/Promotional Usa
+WiNedel Worldwide PF-Partial Free
+WD-Worldwide Discount FC-Free Call
+Til Tuana Network
+Time Period
+PP. Peak Period
+OP-Off Peak Period
+MP-Mutiple Period
+Total
+Charges
+U .UU
+Total
+Changes
+
+
+
+May 11 - June 10, 2004
+UNIT 5
+(561) 719-9544
+Telecommunications Services Call Detail (561) 719-9544
+See
+Item # Date Time Call To
+Number
+Footnote
+Min: Sec
+1 Key 11 DE:58 AN Inconieg
+2 Kay 11 10:32 AN INCORINg
+561-729-3440 VP/PU
+3:00
+3 Кау 11 10:47 3М Inconleg
+561-723-3440
+IPP/FU
+1:00
+4 May 12 01,53 PN Inconleg
+561-723-3440 FP/FU
+1:00
+5 May 11 01:57 IN Incoming
+561-723-3440 PP/PU
+1:00
+5 Kay 11 01:59 IN M PALE BOE, PL
+561-723-3440 09/BU
+LEOU
+7 Кау 12 08:25 ГМ РОМРАКОВСН, РС
+954-942-5959
+PP/PU
+1:00
+8 Kay 17 03152 PN Incoeleg
+918-340-0248
+PP/NS/FU
+3:00
+9 May 13 10:14 IN POMPANCECH, PL
+954-942-5959
+OP/PU
+2:00
+10 Кау 14 05:47 IM РОМРАОВСН, РС
+954-942-5959 PP/PU
+3:00
+11 Kay 15 03122 FM Inconleg
+954-448-2120 OP/FU
+2:00
+12 May 15 01:55 IN STUART, PL
+772-631-9612 OP/PU
+2:00
+13 May 19 03:52 IM INconleg
+954-448-2120
+0P/BU
+2:00
+14 May 15 07:04 PM Incoming
+772-631-9612
+OP/PU
+1:00
+15 Kay 15 07,17 PM Incoming
+954-448-2120
+OP/FU
+1:00
+16
+May 16 11:35 3M Inconing
+754-235-7624
+OP/PU
+2:00
+17
+954-410-7475
+2:00
+18
+Kay 16 02:08 PM BRISTON, OK
+414-467-4654
+OP/PU
+19 May 16 02:30 IN Incoming
+754-235-7628
+OP/PU
+20
+May 14 02:30 IN Inconleg
+754-235-7628
+Kay 16 03:25 PM Incoming
+754-295-7628
+22
+Kay 17 07,12 PM POMPANORCH, PL
+954-946-4833
+23 May 14 12,51 PM POMPANCECH,PL
+954-942-5959
+24
+May 17 12:48 IN Incoleg
+877-326-8500
+25
+Kay 20 03:38 PM Incoming
+954-764-3002
+25
+Kay 20 08122 PM
+POMPANORCH, PL.
+954-942-5959
+OP/PU
+PP/FU
+PP/PU
+SP/BU
+PP/PU
+FP/FU
+27 кау 21 06:09 AN MIA:, FL
+305-825-9800
+2:00
+1:00
+1:00
+2:00
+1:00
+8:00
+2:00
+2:00
+28 Kay 21 06:40 3М M PALK BCH, PL
+561-547-7171
+2:00
+20
+Kay 21 01,47 FN Inconleg
+954-468-2120
+30
+May 21 02112 IN
+Incoming
+FP/FU
+PP/FU
+7,00
+31
+Kay 21 02:13 IN Inconleg
+954-448-2120
+954-448-2120
+1:00
+1:00
+32 May 21 09:05 IM POMPANOBCH, PL
+26a-tkk-AR2%
+OP/PU|
+33 May 22 08:51 PM POMPANORCH, PL
+1:00
+1,00
+34 May 23 05,34
+IN POMPANCECH, PL
+35 May 24 06:37 PM POMPANCBCH, PL
+35 May 24 07,07 PM POMPANORCH, PL.
+37 May 25 06,09 PM POMPANCECH, PL
+35 MAY 25 07:05 IN POMPANDECE, FL
+39
+Kay 25 07:44 PM
+POMPANCBCH, PL
+40 May 25 08103 PM M PALK BCH, PL
+41 May 26 05126 EN Inconing
+954-942-5959
+OP/FU
+954-946-4833
+OP/PU
+954-942-5959
+PP/PU
+954-942-5959
+PP/FU
+954-942-5959
+PP/PU
+954-942-5959
+954-942-5959
+561-541-5449
+954-448-2120
+PP/PU
+PP/FU
+PP/PU
+1:00
+SHOU
+1:00
+2:00
+2:00
+2:00
+6:00
+$100
+Usage
+0,0D
+6.00
+•,0D
+0.0D
+$.00
+$.00
+9,00
+4.00
+Long
+Distance
+D.D0
+D.DO
+D.D0
+D.D0
+cortinued...
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+UNIT 5 (561) 719-9544 continued...
+Telecommunications Services Call Detail (561) 719-9544
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+42 May 27 06136 EM POMPANOBCH, PL
+43 Kay 28 05:29 IM POMPANCECH, PL
+44 May 28 05:39 FM POMPANORCH, PL
+45 May 28 06137 FM POMPANOBCH, PL
+40 Kay 28 01:15 IN A BALE RCH, PL
+47 May 29 05:24 I Incoming
+48 Kay 29 04:14 PM Inconing
+49 May 29 09.56 EM Inconing
+50 Kay 23 09:57 IN POMPANCE, PL
+51 Kay 30 12:45 PM Inconing
+52 May 30 09.36 PM Inconing
+53 Kay 31 12:26 m Inconing
+54 Kay 31 64:08 I Incoming
+55 Kay 31 06:45 PM Inconing
+56 May 31 08.59 PM Inconing
+57
+Jun 01 09:20 AM POMPANCECH, PL
+58 Jun 01 07:42 IM POMPANCECH, PL
+50
+Jun 02 09.05 AM Inconing
+60
+Jun 05 07:22 IN POMPANOECH, PL
+Jun 05 08:00 IM POMPANCECH, PL
+82
+Jun 05 09:03 PM Inconing
+63
+Jun 05 09:10 PM POMPANOBCH,PL
+64
+Jun os 08:15 In Inconing
+65
+Jun 05 09:44 IM Incoming
+Jun 0509:00 PM POMPANORCH,PL
+87 Jun 09 06:15 PM POMPANOBCH,PL.
+08 Jun 09 06:36 IM POMPANCECH, PL
+TOTAL
+Pootnote
+Min: Sec
+954-942-5959 PP/PU
+954-942-5959 PD/PU
+954-942-5959 FF/FU
+954-342-5959 PP/PU
+561-341-3449 CD/FU
+561-541-5449 00/PU
+954-946-4833
+De/FU
+954-448-2120
+ce /PU
+354-342-5959
+DE /FU
+954-449-2120
+Ce /FU
+561-541-5449
+ce /PU
+954-410-3475
+FD/FU
+954-448-2120
+PD/PU
+954-346-4833
+PP/PU
+954-448-2120
+PP/PU
+954-742-5959
+FF/FU
+954-942-5959
+PP/PU
+3:00
+4:00
+3:00
+5:00
+1:00
+1:00
+2:00
+1,00
+2:00
+2:00
+3:00
+2:00
+2:00
+2:00
+1,00
+1:00
+2:00
+1,00
+254-342-5959
+954-942-5959
+0P / PU
+916-340-0248
+954-342-5959 CP/PU
+254-448-2120 DE/FU
+561-644-1121 00/PU
+954-946-4833 D8/PU
+954-342-5959 PP/PU
+954-942-5959 PP/PU
+1:00
+5:00
+1,00
+2:00
+2:00
+1:00
+2100
+2:00
+147,00
+Usage
+9.00
+80.00
+Features
+CV-Call Wating
+CF-Call Forwarding
+3W-Three Way Call
+DS-Dialup Service
+Networks
+Services
+NN-National Network
+AL - Alternate Line
+CN-Canadian Network
+*U-Plan Promotional Usage
+W-Nectel Workwide
+*F-Partial Fres
+WD-Worldwide Discount FC-Free Call
+TJ-Tijuana Network
+Long
+Distance
+0.0D
+0.0D
+0.0D
+Time Period
+PP-Peak Period
+OP-Off Peak Period
+MP-Multiple Period
+Total
+Charges
+0.0D
+
+
+May 11 - June 10, 2004
+(561) 723-1821
+Telecommunications Services Call Detail (561) 723-1821
+See
+Item # Date Time Call To
+Number
+Footnote
+Min: Sec
+1 Key 11 10,09 AM Inconleg
+2:00
+2 Kay 11 12:10 IN INconleg
+561-373-5776
+7:00
+3Кау 11 12:57 PM I PALA BCH, PL
+561-662-6688
+IPP
+1:00
+4 May 12 01,38 PN Inconleg
+561-662-66E8
+FP
+9:00
+5 May 11 01:52 IN Incoming
+561-662-6688
+PP
+6:00
+5 Kay 11 02:18 IN M PALE BOE, PL
+561-790-5465
+1:00
+7 Kay 11 02:19 PM S PALK BCH, PL
+561-775-5178
+PP
+1:00
+$ Kay 12 03,52 IN Inconleg
+561-577-6425
+FP
+10:00
+9 May 11 04:21 IN Incoming
+561-202-8497
+FP
+1:00
+10 Kay 11 04:26 IM Inconleg
+561-662-6688
+PP
+4:00
+11 May 12 04:48 PM Inconleg
+2:00
+12 May 11 04:50 IN M PALA BCN, PL
+561-662-6682
+FP
+1:00
+13 Kay 11 04:51 IM M PALE BOTE, PL
+561-662-6682
+1:00
+14 May 11 04:53 PM N BALM BCH, PL
+561-662-6688
+1:00
+15 Kay 11 05120 PM Incoming
+1:00
+16
+Kay 11 05:34 IN Inconing
+561-790-5465
+5:00
+17
+Kay 12 07:45 AM I BAL BOTE, FL.
+5634718-4005
+2:00
+18
+Kay 12 09:27 3М Incoming
+561-740-5465
+LEOU
+19
+May 12 09:30 AM Incoming
+20
+Kay 12 09:42 AM M PALK BO, PL
+21
+Nay 12 10:05 3М Incoming
+22 May 12 10108 300 M PALE BCS, PL
+23 May 17 10,17 AM NORTH DADE, PL
+24 May 12 10:37 M Incoelag
+25 Кау 12 10:59 3М Інсоміва
+25
+Kay 12 12125 AM M PALE BCH, PL
+27 Kay 12 11:29 лм Inconleg
+28 Kay 12 12:01 PM Inconleg
+561-718-4005
+561-662-6688
+561-202-8497
+561-968-5075
+786-251-1276
+561-503-5930
+561-842-6414
+561-373-5776
+561-373-5776
+561-747-2467
+PP
+PP
+FF
+PP
+FP
+2:00
+1:00
+2:00
+1:00
+1:00
+5:00
+1:00
+4:00
+3:00
+20 Kay 12 12/14 PM Inconleg
+561-662-6688
+30
+May 12 12148 IN JUPITER, PL
+FP
+FP
+31
+Kay 12 12:59 IN Inconleg
+561-747-2467
+561-391-0611
+32 May 12 01:00 IM BOCA RATON, PL
+561-194-7894
+1:00
+2:00
+1:00
+1:00
+33 May 12 03,04 PM MEAL BCH, PL
+34 May 12 01,27 PM BOCA RATON, PL
+3:00
+1:00
+35 Kay 12 01:48 PM Incoming
+38 Kay 12 02,07 PN M PALE BCH, PL
+37 May 17 03.32 #M Incoming
+35 May 12 03:38 IN M PALE BOE, FL
+39 Kay 12 03:40 PM & PALK BCH, PL
+40 May 12 03141 PM M PALK BCH, PL
+41 May 17 03:50 EN COCOA. FL
+561-193-7894
+561-662-6688
+561-662-6688
+772-734-5179
+561-478-4188
+561-662-6688
+561-352-7000
+321-243-0056
+PP
+$:00
+2:00
+1E00
+PP
+PP
+1:00
+3:00
+2:00
+Usage
+0,0D
+D.D0
+D.DO
+6.00
+•,0D
+9,00
+4.00
+Long
+Distance
+D.00
+D.D0
+0.DO
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+9.00
+
+May 11 - June 10, 2004
+SUNSHINE SVCS UNLIMITED (561) 723-1821 continued....
+Telecommunications Services Call Detail (561) 723-1821
+See
+Number
+Footnote
+Min: Sec
+Item # Date
+Time
+Call To
+42 May 12 03:53 EM WINTERPARK, PL
+43 Kay 12 03:55 IM Incoming
+44 May 12 03:58 IM BOCA RATON, PL
+45 May 12 03:59 FM N PALA BCH, PL
+40 Kay 12 04:19 IM N BALE BCH, PL
+47 Kay 12 64:23 IM N PALA BCH,PL
+48 Kay 12 04:26 PM N PALE BCH, PL
+49 May 12 04:43 EM BOCA RATON, PL
+50 Kay 12 04:46 IN N FALE BCH, PL
+51 Kay 12 04:53 PM N PALE BCH, PL
+52 May 12 04:56 PM Inconing
+54 Kay 19 07:41 AM N PALA BCH, PL
+55 Kay 13 09:49 AM N PALE BCH, PL
+56 May 13 09,54 AM W PAL BCH, PL
+57Кау 13 09:59 2М N N BCH, PL
+58 Kay 13 10:03 AM Inconing
+May 13 10.12 AM Inconing
+60 May 13 10:48 AM BOCA RATON, PL
+61 Kay 13 11:18 AM N PALA BCH, PL
+82
+Kay 13 12:01 PM Inconing
+63 May 13 12:03 EM 1 PALA BCH ,PL
+64 Kay 13 12:09 им вотомиси, кс
+05 Kay 13 12:31 I Incoming
+86 Kay 13 12:59 IN N FACE BCH, PL
+87 May 13 01,10 EM N PALM BCH,PL
+08 May 13 01:56 IM BOCA RATON, PL
+00 Kay 13 01:57 IM BOCA RATON, PL
+70
+May 13 02:00 IM BOCA RATON, PL
+71 Kay 13 02:02 PM BOCA RATON, PL
+72 Kay 13 02:51 IM Incoring
+73 Kay 13 03:31 PM Inconing
+74 May 13 03,34 EM N PALM BCH,PL
+75Киу 13 03:35 PM N FAL RCH, PL
+76 May 13 03:34 PM N FALA BCH, PL
+77
+May 13 03:46 EM W PALA BCH, PL
+78 Кну 13 06:12
+™ Inconing
+79 Kay 13 06:30 IM N PALA BCH,PL
+80 May 13 06:31 IM Inconing
+81 May 13 06132 EM W PALM BCH, PL
+82 Кму 14 08:21 ММ ВОСЯ RATON, PL.
+407-916-7235 PP
+561-662-6688 PP
+561-322-7000
+FF
+561-352-7000 PP
+561-662-6688PP
+561-352-7000
+561-391-0611
+FF
+PP
+561-662-6688
+561-662-6638
+FF
+561-662-6698
+PP
+361-662-6688 FF
+561-662-6668 PD/NN
+561-662-6684 PR
+561-662-6648
+561-478-58PD
+561-662-6668
+561-202-4497
+PP/NN
+361-393-7920
+561-662-6688
+PP
+561-478-4188
+561-478-5890
+PP
+561-737-3115 FD
+954-914-4070
+561-478-5890
+561-662-6688
+561-361-9771
+561-361-9171
+561-361-9171
+FF
+PP
+PP
+FF
+PP
+561-393-7834
+561-476-4188
+PD
+561-462-6688
+561-662-6698
+PP
+561-790-6644
+561-762-1439
+561-723-1421
+361-189-2003
+FF
+561-662-6688P0
+561-202-4497 PP
+561-722-2942 PP
+561-393-7920 FF
+Usage
+2100
+2:00
+1:00
+4: 00
+3: 00
+1:00
+3,00
+1:00
+1100
+2:00
+2:00
+2:00
+1:00
+1,00
+5:00
+2,00
+5: 0D
+1:00
+1:00
+6:00
+2:00
+1:00
+5:00
+2100
+1:00
+2:00
+2,00
+2:00
+1:00
+4:00
+1,00
+21 DO
+1:00
++: 00
+3:0D
+1:00
+2:00
+4:00
+3:0D
+9.00
+Long
+Distance
+Total
+Charges
+0.0D
+0.0D
+0.0D
+0.DD
+0.DD
+0,00
+U .UU
+0.OO
+0.0D
+0,00
+
+
+May 11 - June 10, 2004
+(561) 723-1821 continued...
+Telecommunications Services Call Detail (561) 723-1821
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+83 May 14 09,18 AM Inconing
+561-659-3770PP
+1:00
+84 May 14 09:22 AM Incoming
+561-202-8497 0P
+2:00
+85 May 14 09:32 1М Incoming
+561-732-6405
+FP
+SIgU
+88 May 14 09:42 AM Inconing
+224-627-9132
+FP
+5:00
+87 кау 14 09:58 ЛИ И PALE ВСП, РС
+5E1-662-6GB8
+3E0U
+88 May 14 10:27 3M Incoming
+561-478-5890
+4:00
+89 May 14 10:47 1М Incoming
+561-202-8497
+FP
+1:00
+90 May 14 11:18 AM Incoming
+561-202-8497
+FP
+1,00
+91 Kay 14 12:01 IN M FALE ECH, FL
+561-662-6GE8
+FF
+1:00
+92 May 14 01/11 EM Inconieg
+561-478-4188
+PP
+2:00
+93 May 14 01,29 IN M BALA BCH, FL
+561-662-6688
+FP
+4:00
+94 May 14 04:21 PM M PALIE BCE, VL.
+561-662-6688
+1:00
+85 May 14 04:23 PM Incoming
+561-662-6688
+1:00
+95 May 14 04:41 PM Inconleg
+561-964-5511
+5:00
+97 May 14 05:45 EM
+Inconing
+561-202-8497
+FP
+2:00
+95 May 14 05:48 IN M PALA BCH, FL
+561-641-7202
+May 14 05:54 IM M PALK BCH, PL
+561-644-7447
+3:00
+100 May 14 05,56 IN M BALK BCH, PL
+561-501-448
+PP
+101 May 15 01:28 IN M PALE BCH, VL.
+102 Kay 17 12:25 I Incoming
+103 Kay
+17 03:14 PM M PALE BCH, PL
+104 Kay 17 06158 PM M BALK BCH, FL
+105 Kay 18 DE:23 UN M PALE BCH, FL
+105 Kay 14 07:18 DM VERO BEACH, PL
+107 Kay 19 06:50 IN M BALE BCH, PL
+105 Jun 01 05154 PM M BALA BCH,PL
+109 Jun 02 12:58 IN Tell Pree
+110 Jun 0a 12:59 PM Inconteg
+561-371-1767
+561-723-1821
+561-723-1821
+561-634-8487
+772-719-7015
+561-662-6688
+561-723-1821
+888-546-0314
+757-223-8310
+FP
+111 Jun 02 03/24 PM W PALA BCH,FL
+FP
+PP
+VP/PC
+FP
+FP
+1:00
+7:00
+1:00
+4:00
+1:00
+1:00
+1,00
+1:00
+1:00
+112 Jur
+02
+03:47
+Incoeleg
+561-723-1821
+561-202-8497
+20:00
+2:00
+113 Jun 02 06:14 IN Incoming
+561-202-8497
+1:00
+114 Jun 62 06:29 PM DELAY BCH, PL.
+1:00
+115 Jun 03 07,48 AM N BALA BCH, PL
+561-615-0011
+PP
+2:00
+116 Jun
+561-191-063
+TrOO
+117 Jun 03 08:12 AN M BALK BCH, PL
+118 Jun 03 08115 AN N BALK BCH, PL
+119 Jun 01 08:50 AN M PALE BCH, FL
+120 Jun
+03 09:47 AM M PALA BCH, PL
+121 Jun 03 10:32 AM M PALE BCN, PL
+122 Jun 03 10,53 AM M BALK BCH, FL
+123 Jun 03 10:56 AM M PALE RCH, PL
+561-718-4222
+561-718-4005
+561-964-5511
+561-718-0878
+561-793-4372
+561-793-4372
+561-793-4372
+1:00
+2400
+FF
+PP
+FP
+FF
+1: 00
+4: 00
+1:00
+2:00
+1:00
+Usage
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+0.0D
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+0000
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+continued..
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+SUNSHINE SVCS UNLIMITED (561) 723-1821 continued...
+Telecommunications Services Call Detail (561) 723-1821
+See
+Number
+Footnote
+Min: Sec
+Item # Date
+Time
+Call To
+124 Jun 03 10:57 AM W PALA BCH, PL
+125 Jun 03 11:35 AM Incoming
+126 Jun 03 11:39 AM Inconing
+127 Jun 03 11:45 AM Inconing
+128 Jun 03 12:15 I Inconing
+129 Jun 03 12:19 IM N PALM BCH, PL
+130 Jun 03 12:20 PM N FACE BCH, PL
+131 Jun 03 12132 EM Inconing
+132 Jun 03 01:59 IN Inconing |
+133 Jun 03 02:06 PM Inconing
+134 Jun 03 02:12 FM
+W PALA BCH,PL
+135 Jun 03 02:33 IN DELAY BCH, PL
+136 Jun 03 02:42 IM N PALA BCH, PL
+137 Jun 03 03:50 PM JUPITER, PL
+138 Jun 03 04:04 EM W PALA BCH, PL
+130 Jun 04 08:24 AM Inconing
+140 Jun 04 09:24 AM W PALA BCH, PL
+141 Jun 04 09,33 AM W PALM BCH, PL
+142 Jun 06
+09:45 AM N BALE NCH, PL
+143 Jun
+04 10:06
+AM W PALM BCH, PL
+144 Jun 04 10:51 AM BOCA RATON, PL.
+145 Jun 04 11:04 AM
+Inconing
+146 Jun 04 12:0€ M N BALA RCH, PL
+147 Jun 04 12:29 W
+Inconing
+148 Jun 04 01:43 #
+Inconing
+149 Jun 04 02:18 PM
+Incordng
+150 Jun 04 02:30 IN N PALA BCH, PL
+151 Jun 04 02:34 PM
+BOYTONBCH , PL
+152 Jun 04 02:35 PM
+Inconing
+153 Jun
+04
+02:41 PM
+BOCA RATON, PL
+154 Jun 07
+06:49 AM N PALA BCH, PL
+155 Jun 07 07:15 AM N PALA BCH, PL
+156 Jun 07 09:40 AM Inconing
+157 Jun 07 09:01 AM N FALA NCH, PL
+158 Jun 07 09:05 AM W PALM BCH, PL
+150 Jun 07 09,08 AM N PALM BCH, PL
+160 Jun 07
+09:08 AM BOCA RATON, PL
+161 Jun
+07
+10:05 AM W PALM BCH, PL
+162 Jun
+AM BOCA RATON, PL
+163 Jun
+10,54 AM W PALM BCH,PL
+164 Jun 07
+10:59 AM BOCA RATON, PL
+561-474-4148 PP
+561-471-0395P0
+561-478-4168 FF
+561-474-4148 PP
+361-862-6688 FD
+561-662-6688PP
+561-721-1940
+FF
+561-714-9226
+PP
+757-377-529D
+561-379-3816
+FP
+561-920-4659
+PP
+361-441-8028
+FF
+561-820-4659 P8
+561-747-2467
+561-662-6648
+561-798-6037
+561-655-3000
+PP
+361-844-9122
+561-718-4005
+PP
+561-305-1272
+561-305-1272
+PP
+361-662-6E0E FD
+561-478-4188
+561-478-4188
+561-662-6688
+561-784-1570
+561-577-6425
+561-577-6425
+FF
+PP
+PP
+FF
+PP
+561-368-3326
+561-662-6688
+OP
+561-462-6688
+PP
+561-662-6698
+PP
+561-478-4188
+561-723-1421
+PP
+561-764-1574
+FF
+561-373-5776
+PP
+561-662-6684 PP
+561-477-7880 FF
+Usage
+2100
+2:00
+1:00
+1:00
+1:00
+4: 00
+2,00
+5:00
+5:00
+1,00
+3: 00
+2:00
+2:00
+8:00
+3:00
+5: 0D
+2:00
+2:00
+2,00
+7:00
+2:00
+1:00
+3,00
+2:00
+1:00
+6:00
+4:00
+4: 00
+4:00
+2100
+3:00
+1,00
+1:00
+4: 00
+3:00
+2,00
+1:00
+9.00
+Long
+Distance
+0.0D
+0.0D
+0.0D
+0.DD
+0,00
+0-O0
+Total
+Charges
+U .UU
+0.OO
+0,00
+
+
+May 11 - June 10, 2004
+(561) 723-1821 continued...
+Telecommunications Services Call Detail (561) 723-1821
+See
+Item # Date Time
+Call To
+185 Jun 07 11/03 AM M BALA BCH, FL
+105 Jun 07 11:05 AM ВОУТОНЕСН, PL.
+187 Jun 07 12:11 AN M BALE BCH, PL
+165 Jun 07 11/11 AM M BALK BCH, FL
+109 Jun 07 11:11 AM INCelag
+170 Jun 07 11:15 AM W PALK BCH, PL
+171 Jun 07 12:17 AM BOCA RATON, PL
+172 Jun 07 11:24 AM BOTTONBCH, FL
+173 Jun 07 11:26 A BOTTONICH, FL.
+174 Jun 07 13:33 AM BOTTONECH, PL
+175 Jun 07 11,35 AM M PALA BCH, FL
+176 Jun 07 11:36 AM M BALE BCH, FL
+177 Jun 07 11:38 2M N PALA BCH, PL
+178 Jun 07 12:59 AN M BALE BCH, PL
+179 Jun
+12,02
+I PALA BCH, PL
+IN M PALE BCH, PL
+Number
+Footnote
+Min:Sec
+561-723-1821 FP
+561-742-2363 0P
+561-723-1821
+FP
+2100
+3:00
+1:00
+561-723-1821
+FP
+CEOU
+5E1-662-6GB8
+561-723-1821
+561-477-7880
+FP
+561-577-6425
+561-577-6425
+561-577-6425
+561-820-4609
+PP
+FP
+561-820-4659
+561-662-6688
+2:00
+4:00
+3:00
+1:00
+1:00
+1:00
+1:00
+1:00
+561-723-1821
+S6-662-6R
+1:00
+1:00
+181 Jun
+07 12:08
+182
+07 12,09 IN M BALK BCH, PL
+183 Jun
+154 Jun 07 01:03
+IN S PALM BCH,PL
+185 Jun
+• PALE BCH, PL
+188 Jun 07 01,34 PM M BALK BCH, FL
+187 Jun 07 01:38 UN M PALE BCH, FL
+188 Jun 07 01:40 IM BOYTONBCH, PL
+189 Jun 07 02:42 PM BOCA RATON, PL
+190 Jun 07 01:48 PM M BALA BCH, PL
+191 Jun 07 01:50 IN W PALK BCH, PL
+192 Jun 07 01:53 PN
+BOCA RATON, PL
+193 Jun 07 02147 PM W BALA BCH,FL
+07 02:49
+BOTTONECH, FL.
+195 Jun 07 02:50 IM BOYTONBCH, PL
+195 Jun 07 05:25 PM M BALE BCH, PL
+197 Jun 07 05,46 PM Inconleg
+195 Jun.
+199 Jun 04 08:46 AM Incoming
+200 Jun 09 08:59 AM Inconleg
+201 Ju 08 02:01 AN M PALE BCH, FL
+202 Jun 04 09:12 AM M PALA BCH, PL
+203 Jun 04 09:21 AM M PALE BCH, PL
+204 Jun 04 10,52 M M BALK BCH, FL
+S61-725-1M2
+561-723-1821
+561-478-4188
+561-478-4822
+561-662-6688
+561-820-4659
+561-577-6425
+561-447-7880
+561-379-8816
+561-694-8487
+PP
+FP
+PP
+561-477-7880
+FP
+FP
+561-478-4188
+561-577-6425
+561-577-6425
+561-694-8487
+PP
+561-965-5600
+561-662-6688
+561-313-8018
+561-478-4822
+561-478-4188
+561-723-1821
+561-996-6571
+FF
+PP
+FP
+FF
+Usage
+1:00
+1:00
+1:00
+SLUU
+1:00
+1:00
+3,00
+3:00
+1:00
+2:00
+1:00
+3:00
+2:00
+1,00
+2:00
+2:00
+3: 00
+2:00
+2:00
+3:00
+2:00
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+6.00
+6.00
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+
+May 11 - June 10, 2004
+SUNSHINE SVCS UNLIMITED (561) 723-1821 continued....
+Telecommunications Services Call Detail (561) 723-1821
+See
+Number
+Footnote
+Min: Sec
+Item # Date
+Time
+Call To
+206 Jun 08 11:03 AM BOCA RATON, PL
+207 Jun 08 11:08 AM W PALM BCH, PL
+208 Jun 08 11:09 AM N PALE BCH, PL
+200 Jun 08 11/13 AM 1 PALA BCH, PL
+210 Jun De 12:42 IM Inconing
+211 Jun 08 12:45 I Inconing
+• Jun 08 12:50 IN N PALE BCH, PL
+213 Jun 08 12151 EM Inconing
+214 Jun 08 12:57 PM N FALE NCH, PL
+215 Jun 08 01:09 PM W PALA BCH, PL
+218 Jun 08 01,19 PM
+HOLLYNOOD. PL
+217 Jun De 01:26
+Inconing
+218 Jun 08 01:43 IM Incoring
+219 Jun 08 01:53 PM N PALE BCH, PL
+220 Jun 08 01:54 EM W PALA BCH, PL
+221 Jun 08 01:58 PM N FALL BCH, PL
+222 Jun 08 62:04 I
+HOLLYNGOD, PL
+223 Jun 08 02:08 EM Inconing
+224 Jun De 02:20 m
+HOLLYNOOD, Fu
+225 Jun 08 02:55 I Incoming
+228 Jun 08 04:04 PM N FAIR BCH, PL
+227 Jun 09 07:29 AM Inconing
+228 Jun 03 08:11 AM N SALE RCH, PL
+229 Jun 09 09:05 AM DELRAY BCH, PL
+230 Jun 09 09:38 AM BOYTONBCH, PL
+231 Jun 09 09:42 AM Inconing
+232 Jun 09 09:57 AM Inconing
+233 Jun 09 10:15 AM Inconing
+234 Jun 09 10:43 AM W PALM BCH,PL
+235 Jun 03 10:46 AM X BALA RCH, PL
+236 Jun 09 10:47 AM N PALA BCH, PL
+237 Jun 09 10:49 AM N PALE BCH, PL
+238 Jun 09 11:41 AM BOCA RATON, PL
+230 Jun 08 12:31 PM
+Inconing
+240 Jun 09 12:34 PM
+Inconing
+241 Jun 09 12:37 PM N PALM BCH, PL
+242 Jun
+03 12:48 PM N FAL ACH, PL
+243 Jun 09 01:05 IM W PALM BCH, PL
+244 Jun
+09
+01:34
+Inconing
+245 Jun 09 01,39 #M
+W PALM BCH,PL
+246 Jun 03 01:40 PM N FALA NCH, PL
+561-305-1272 PP
+561-478-4188P0
+561-352-7000
+FF
+561-662-6448 PP
+561-202-8497 FD
+561-478-4188P0
+561-313-8014 FP
+561-313-9018 PP/CH
+561-313-8014 FE
+561-662-6638 FF
+954-558-5006
+PP
+361-379-8816 FF
+561-202-8497 P0
+561-654-3457 PR
+...
+561-202-4497
+PP
+254-358-500€
+561-613-2400
+PP
+561-379-2816
+561-315-0345
+PP
+561-842-6414 FD
+561-276-7707
+561-523-3258
+561-202-9497
+561-202-8497
+561-613-2400
+561-626-3495
+FF
+PP
+PP
+FF
+PP
+561-791-4482
+561-723-1621
+561-477-7880
+561-202-8497
+561-202-4497
+FF
+561-723-1421
+361-642-648E
+FF
+561-662-6688
+PP
+561-430-4891 PP
+561-662-6684 PP
+561-630-4891 FF
+Usage
+2100
+2:00
+3:00
+2:00
+3: 00
+2:00
+1,00
+1:00
+2:00
+3:00
+3: 00
+2:00
+1:00
+1,00
+1:00
+2:00
+3: 00
+1:00
+5:00
+1:00
+4:00
+1:00
+1,00
+1:00
+1:00
+2,00
+1:00
+3:00
+4:00
+4,00
+1:00
+2,00
+4: 00
+1:00
+5:00
+1,00
+2:00
+9.00
+Long
+Distance
+Total
+Charges
+0.0D
+0.0D
+0.0D
+0.DD
+0.DD
+0,00
+0-O0
+U .UU
+0.OO
+0.0D
+0,00
+
+
+May 11 - June 10, 2004
+(561) 723-1821 continued...
+Telecommunications Services Call Detail (561) 723-1821
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+247 Jun 09 01141 IN M BALA BCH, FL
+561-662-6688 P
+1:00
+248 Jun 09 01:44 PM N PALK BCH, PL
+561-662-6688PP
+1:00
+249 Jun 09 01:59 EN M BALK BCH, PL
+561-662-6688
+FP
+7:00
+250 Jun 09 02.06 PM PALM BCH,PL
+561-630-4891
+FP
+SLUU
+251 Jun 07 02:17 IN Incoeleg
+5E1-662-6GB8
+252 Jun 09 02:41 PM Incoming
+561-662-6688
+4:00
+253 Jun 08 04:28 PM Inconleg
+561-202-8497
+FP
+2:00
+254 Jun 09 04:29 PM M BALA BCH, FL
+561-798-2100
+FP
+2:00
+255 Ju: 09 04:33 IN Incoaleg
+561-662-6GE8
+FF
+2:00
+256 Jun 09 04:35 PM M PALE BCH, PL
+561-798-2100
+PP
+2:00
+257 Jun 09 04:56 EM Inconleg
+561-662-6688
+FP
+1:00
+258 Jun 03 04:57 m Incoeleg
+561-662-6688
+1:00
+259 Jun 10 07:13 ZM N PALK BCH, PL
+561-478-4822
+2:00
+260 Jun 10 07:40 AN M BALE BCH, PL
+281 Jun 10 07,52 AM Inconing
+282 Jun 10 D8:21 A M PALAC BCH, FL.
+561-842-6414
+321-229-2595
+561-718-4005
+FP
+2:00
+1:00
+3:00
+263 Jun 10 08:24 AM M DALK BCH, PL.
+S61÷428-4M22
+1:00
+254 Jun 10 08127 AN M BALK BCH, PL
+265 шл 10 08:28 AN СОСОЛ , FL.
+200 Jun 10 09:50 AM Incoming
+287 Jun 10 10:49 1M Inconleg
+285 Jun 10 12:04 EM Inconing
+269 Jun 10 12:22 PM Incoalag
+270 Jun 10 01:48 IM Incoming
+271 Jun 10 02:06 IN M PALE BCH, PL
+272 Jun 19 02:08 PM Inconing
+273 Jun 10 02:58 IN N PALK BCH, PL
+274 Jun 14 03:05 PM M BALE BCH, PL
+275 Jun 10 03,07 PM W PALA BCH,FL
+561-842-6414
+PP
+321-243-0056
+561-478-4833
+561-662-6688
+FP
+561-625-3319
+FP
+561-202-8497 P
+561-202-8497
+561-662-6688 FP
+561-662-6688
+561-964-0958
+561-379-8816
+FP
+561-379-8816 FP
+1:00
+1:00
+276 Jul 10 03:09 IM воУтонаСта, Г.
+561-503-5930 F
+2:00
+1:00
+1:00
+1:00
+8:00
+1:00
+3:00
+2:00
+2:00
+TOTAL
+667: G0
+Usage
+•.00
+6.00
+6.00
+0.0D
+•.00
+6.00
+0.0D
+$.00
+6.00
+6.00
+0.0D
+Footnote
+Features
+CWCall Waiting
+CF-Call Forwarding
+JW-Three Way Call
+DS-Dialup Service
+Networks
+Services
+N-National Network
+AL - Alternate Line
+CN-Canadian Network
+PU-Plan/Promotional Usage
+WW-Neel Worlswide
+Pr-Partial Free
+WD-Worldwide Discount FC-Free Cal
+TJ-Tijuana Network
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+Time Period
+PP-Peak Period
+OP-Off Peak Period
+MP-Muliple Period
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+UNIT 4
+(561) 723-3440
+Telecommunications Services Call Detail (561) 723-3440
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+1 Kay 11 06:54 AM NFACE RCH, PL
+11DD
+2 Кау 11 10:22 ЛИ N PALE BOI, PL
+561-462-6688 PD/PU
+3: 00
+3 May 11 10:31 AM PILAUDERDC, PL
+954-295-6132 PP/PU
+1:00
+4 Nay 11 10,72 AM N FAIA RCH, PL
+561-719-9544 FF/FU
+3,00
+5 May 11 10:47 AM W PALA BON, PL
+561-719-9544 PP/PU
+1:00
+6 Kay 11 12:00 I Inconing
+561-616-8240 BE
+3: 0D
+7 May 11 12:16 IM Inconing
+561-502-7753 PP
+1:00
+8 May 11 01,53 PM NFALL RCH, PL
+561-719-9544 FF/FU
+1,00
+• Ney 11 01.57 FM N PALA BOH, PL
+561-719-9544 PP/PU
+1:00
+10 May 11 05:35 PM Inconing|
+561-616-8240 PP
+1:00
+11 Kay 11 06:04 PM Inconing
+561-503-5930
+FP
+11 DD
+12 Kay 11 07:07 I Incoming
+561-333-7530 PP
+2:00
+361-478-4188 PD
+1:00
+Kay 12
+12:39
+W PALM
+BCH, PL
+561-352-7000
+PP/PU
+2:00
+15
+Kay
+12
+02:57 |
+Inconing
+561-616-4240
+FF
+2,00
+16
+Key 12
+04:35
+Inconing
+561-662-6688
+4:00
+1f Kay
+12 04:46 101
+Inconing
+1100
+18 Kay 12 05:10 I
+Inconing
+19 Key 12 07.33 PM
+W PALE BOIL,PL
+20 кау 12 08:07
+21 May 13 10:13 AM I PALM BCH, PL
+22 Киу 13 12:20 гМ
+Inconing
+23 Key 13 01:15 IN
+N PALA BCH, PL
+24 Kay 13 02:14 IN A BALE BCH, PL
+25
+May 14 07:30 AM N PALM BCH, PL
+26
+Kay 14 07131 AM I PALE RCH, PL
+27 Kay 14 07:53 AM Inconing
+28 Kay 14 08:36 AM Inconing
+29 Kay 14 04:54 AM N PALA RCH,PL
+30 Kay 14 08:55 AM
+N PALE BCH.PL
+31 кау 14 08:36
+32 Kay 14 08:57 AM Inconing
+33
+Kay 14 09,31 AM Inconing
+34 May 14 09:46 AM Inconing
+35 May 14 09:46 AM Inconing
+36Киу 14 09:50 1М Inconing
+37 May 14 10:21 AM Incoming
+38
+Kay 14 10:46 AM Inconing
+39
+Kay 14 11:26 AM I PALA BCH, PL
+40 Kay 14 02127 PM Inconing
+41 Key 14 03:29 IM N PALA BCH, PL
+561-616-8240
+S61-616-4240
+eP
+PP / PU
+561-616-8240
+561-616-9240
+PP/PU
+561-662-6644 FP
+561-662-6668 PP/PU
+561-687-3636 FD/FU
+561-616-8240 PP/PU
+561-687-3436 FP/FU
+561-541-544980
+561-662-6688 PP
+561-662-6688 FP/FU
+561-842-6414 PP/PU
+254-914-4070 PD/PU
+561-662-6688 PP
+561-662-6448 PP
+561-662-6684 PP
+561-662-6688 PP
+561-662-6648 PP
+561-474-4144 PP
+561-478-4188 PO
+561-753-9991 PP/PU
+561-662-6444 FP
+561-714-4005 PP/PU
+1:00
+2:00
+3:00
+2:00
+1,00
+2,00
+6: 0D
+1:00
+1100
+1:00
+4: 00
+1,00
+1:00
+1:00
+2:00
+2:00
+1,00
+4: 00
+1,00
+1,00
+2:00
+2:00
+1,00
+Usage
+Long
+Distance
+Total
+Charges
+0.DD
+0.0D
+0.DD
+D. DD
+0.0D
+D. DD
+0.0D
+0.DD
+0.0D
+0.0D
+0.DD
+0.0D
+0.0D
+0.0D
+0.00|
+0,00
+0,00
+
+
+May 11 - June 10, 2004
+UNIT 4 (561) 723-3440 continued...
+Telecommunications Services Call Detail (561) 723-3440
+See
+Number
+Footnote
+Item # Date Time
+Call To
+42 May 15 09,23 AM M BALA BCH, FL
+43 May 15 08:24 AM Incoming
+44 May 15 08:51 AN Incoming
+45 May 15 09,11 AM I PALA BCH, PL
+45 кку 15 09:12 АМ ВОСА ДАТОМ, FL.
+47 May 15 09:40 3M W PALA BCH, PL
+45 May 15 12:41 PM Incoming
+49 May 15 02:16 PM Incoming
+50 May 15 02:17 IN Incoeleg
+51 May 15 02:45 PM M BAL BCH, PL
+52 May 15 02,52 EM Inconing
+53 May 15 04:05 PM M PALE BCS, VL.
+54 May 15 04:09 PM Incoming
+55 May 16 04:27 PM Inconleg
+58 May 17 07.10 AM M BALA BCH, FL
+57 May 17 07:26 A Incaleg
+58 May 17 07:43 AM M PALK BCH, PL
+50 May 17 08,37 AM Incoming
+60 MaY 17 10:10 AM M PALE BCH, FL
+61 Kay 17 10:11 AM M PALA BCH, PL
+62 May 17 10:24 AM Incoming
+83 May 17 11:23 AM M BALK BCH, PL
+84 May 17 11:39 AN M PALE BCH, FL
+65 Kay 17 01:26 PM M PALK BCH, PL
+65 May 17 03:37 #M M BALK BCH, PL
+87 May 17 01:45 PM M BAIR BCH, FL
+68 Kay 17 01:50 PM Inconieg
+89 May 17 02:56 PM M BALE BCH, PL
+70 May 17 03,32 EM Incoring
+71 May 17 04:08 PM M BALAC BCTE, FL.
+72 Kay 17 04:09 PM M DALK BCH, PL
+73 May 17 05:43 PM Inconleg
+74 May 17 05:44 PM Inconleg
+75
+May 17 05145 IN LECL
+76|
+Pay 19 07191 A8 SECOLET
+77 May 19 07,12 AM Inconing
+78 Kay 18 07:26 / Inconleg
+79 Kay 1e 07:40 AM Incoming
+80 Kay 14 09:43 AM I BALE BCH, PL
+81 May 19 10:24 AM Inconing
+82 Kay 1a 10:40 sh Inconleg
+Min: Sec
+561-616-8240 OP/PU
+561-616-8240 OP
+Unavaliahle
+OP
+561-385-1272 OP/FU
+561-303-1272
+OP/BU
+561-616-8240
+OP/U
+561-616-8240
+OP
+561-662-6688 0P
+561-662-EGE8
+OF
+561-502-7753
+OP/FU
+561-502-7753
+561-616-8240
+OP
+OP/sU
+561-662-6688 0P
+561-667-4222
+OP
+5614718-4005
+PP/PU
+954-295-6132
+561÷616-8240
+#P/Р0
+S6-62-6R
+561-723-3440
+561-729-3440
+DP/P0
+561-718-4005
+561-662-6688
+RP/PU
+561-616-8240
+pP/sU
+561-662-6688
+0P/90
+561-662-6688
+FP/PU
+561-324-1491|
+RP/FU
+561-827-2542
+561-324-1491
+PP/PU
+FP
+561-667-4222
+561-723-3440
+561-686-2246
+09/90
+561-503-8429
+PP
+561-503-6429
+561-964-5511
+PP
+561-667-4222
+561-662-6688
+FF
+561-662-6688
+561-616-8240
+PP/FU
+561-503-5930
+FP
+561-662-66E8
+FF
+Usage
+1:00
+1:00
+1:00
+2:00
+2:00
+1,00
+1:00
+2:00
+1:00
+1:00
+1:00
+3:00
+1:00
+2:00
+2:00
+2: 00
+1:00
+3:00
+2:00
+7:00
+2:00
+2:00
+1:00
+1:00
+1:00
+2:00
+1:00
+1:00
+1:00
+2:00
+3: 00
+1:00
+1:00
+1:00
+1:00
+•.00
+6.00
+6.00
+0.0D
+•.00
+6.00
+6.00
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+UNIT 4 (561) 723-3440 continued...
+Telecommunications Services Call Detail (561) 723-3440
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+83 May 18 02:00 EM Incoming
+84 May 18 66:05 I Incoming
+$5 May 18 06:06 FM NPALA BCH, PL
+88 May 18 06:55 FM 1 PALA BCH ,PL
+88 ay 19 07:18 AM N PALA BCH, PL
+89 Kay 19 07:20 1М Inconing
+90 May 19 07:27 AM Inconing
+92 May 19 12:04 FM N PALA BCH, PL
+93 May 19 01152 FM W PACH BCH, PL
+94 Kay 19 01:55
+m Inconing
+90 Kay 19 01:57 IN N PALA BCH, PL
+96 Kay 19 02:25 PM N PALE BCH, PL
+97 May 19 02131 EM Inconing
+Kay 13 05:11
+Inconing
+99 Kay 19 05:41 IM N PALA BCH, PL
+100 May 19 05,50 EM W PALA BCH, PL
+101 Kay 13 08:05 PM N FAL NCH,PL
+102 Kay 19 09:24 IM N PALA BCH, PL
+103 Kay 20 05:42 AM Inconing
+104 May 20 07:05 AM Inconing
+105 Kay 20 07:36 AM N FALE RCH, PL
+106 Kay 20 09:23 AM N PALA BCH, PL
+107 Kay 20 09:49 AM Inconing
+108 My 2010:05 M
+Inconing
+109 Kay 20 10:42 AM
+Inconing
+110 Kay 20 11:43 1м
+W PALE BCH, PL
+111 May 20 11:44 2M
+Inconing
+112 Kay 20 12:14 m
+Inconing
+113 Kay 20 02:48 I Inconing |
+114 Kay 20 07:50 IM Inconing
+115 May 20 07:57 PM N PALM BCH,PL
+116 кку 20 08:24 М РОМАСЯСИ, PL.
+117 Kay 21 12:34 PM PILAUDERD, PL
+118 May 21 12:49 EM W PALM BCH, PL
+119 Kay 21
+12:53
+Inconing
+120 Kay 21 01:04 m
+Inconing
+121 Kay
+21
+01:41
+Inconing
+122 May 21 02:49 PM Inconing
+123 Kay 21 03:56 m
+Inconing
+Min: Sec
+UnavalTable
+PP
+561-616-8240P0
+561-616-4240
+FF /FU
+561-647-3636 PP/PU
+561-723-3440 FD/FU
+561-616-8240 PD/PU
+561-616-4240
+FF
+561-503-5930 PP
+561-616-8240
+FE /FU
+561-352-7000
+FF /FU
+561-662-6616 PP/PU
+561-616-8240
+561-662-6616 PD/PU
+561-585-3660
+FE /FU
+561-662-6616
+PP/PU
+361-E62-8C8E
+561-667-4222
+561-502-5212
+ce
+561-502-5212 PP
+561-723-3440 FF/FU
+561-662-6668 PD/PU
+561-662-6688 PP
+561-616-9240 PP
+561-503-4429
+PP
+561-616-4240
+561-616-9240 PP
+561-502-5212 FE
+561-616-4240 PP
+561-503-5930 Pe
+561-616-9240 PP/PU
+354-342-5958 FD/FU
+954-295-6132 PP/PU
+561-616-8240 PP/PU
+361-616-8240 FF
+561-502-7753P0
+615-324-2054 PP
+561-616-4240 PP
+561-478-4188 FF
+Usage
+19,00
+1:00
+1:00
++:00
+2:00
+1:00
+1:00
+2,00
+1:00
+1100
+1,00
+2:00
+1:00
+1:00
+2:00
+1:00
+1,00
+25:00
+7:00
+1:00
+1,00
+1:00
+1:00
+6:00
+3,00
+2:00
+1:00
+1,00
+1:00
+1:00
+1:00
+1,00
+5:00
+2,00
+1:00
+1:00
+1:00
+1,00
+2:00
+9.00
+Long
+Distance
+0.0D
+0.0D
+0.0D
+0. 00
+0.DD
+0.DD
+0,00
+Total
+Charges
+U .UU
+0.OO
+0,00
+
+
+
+May 11 - June 10, 2004
+UNIT 4 (561) 723-3440 continued...
+Telecommunications Services Call Detail (561) 723-3440
+See
+Number
+Footnote
+Item # Date Time
+Call To
+124 May 21 04:17 EM Inconing
+125 Kay 21 05:27 PM I PALA BCH, PL
+126 Kay 22 D8:08 AM I PALE BCH, PL
+127 May 22 08133 AM FTLAUDERDG, PL
+128 Kay 22 08:45 AM M PALE BCH, FL
+129 Kay 22 03:09 PM W PALA BCH, PL
+130 Kay 22 04:30 PM I PALE BCH, PL
+131 Kay 22 05:15 PM Inconing
+132 Kay 22 DE:14 IN Incoaleg
+133 Kay 22 07:20 PM Inconleg
+134 May 22 07,29 PM Inconing
+135 Kay 22 08:28 IN FTLAUDEAD, FL
+135 Kay 22 09:24 PM PILAUDERDL, PL
+137 Kay 22 09:25 F Inconleg
+138 May 22 09:45 PM
+PILAUDERDG, PL
+130 кау 22 10:38 m/
+Incoeleg
+140 Kay
+22
+10:45 PM Incoeing
+141 Kay 23 09,19 AM M PALA BCH, FL
+142 кау
+23 TELE AN SECUELES
+143 Kay 29 12:59 PM M PALK BCH, PL
+144 Kay
+23 02:00 PM M BALE BC, PL
+145 May 23 01:06 EM Inconing
+145 ay 23 03:10 IN Incoeleg
+147 Kay 23 03:56 IM Incoming
+145 Kay 23 04:14 PM Inconleg
+149 May 23 04,35 PM FTLAUDERDG, PL
+150 Kay 23 05:38 IN Incoming
+151 Kay 23 06:53 PM Inconleg
+152 Kay 23 07,06 PM W BALK BCH, FL
+153кку 23 07:50 IN TAUDEAD, FL
+154 Kay 23 08:11 IN M PALK BCH, PL
+155 Kay 23 08:50 PM Inconteg
+150 May 24 07,00 AM N BALA BCH,PL
+157 Kay 24 07:09 AN M PALE BCH, FL
+158 Kay 24 07:52 AN I BALK BCH, PL
+150 Kay 24 07,55 M Inconing
+100 Kay 24 08:00 A Incoaleg
+161 Kay 24 09:02 AM M PALK BCH, PL
+162 Kay 2409:07 1M Inconleg
+183 May 2409,15 Inconing
+154 Kay 24 02:09 PM M PALAC BCH, PL
+Min: Sec
+561-478-4188 FP
+561-662-6688 VP/PU
+561-616-8240
+OP/FU
+954-295-6132
+OP/FU
+561-61E-8240
+OP/BU
+561-616-8240
+OP/PU
+561-723-3440
+OP/FU
+561-502-7753
+561-667-4222
+OF
+561-667-4222
+OP
+561-965-0976
+OP
+954-295-6132
+OP/SU
+954-295-6132
+OP/PU
+954-295-6132
+954-295-6132
+OP
+OP/FU
+561-616-8240
+561-827-2542
+5614728-1440
+561-856-4306
+561-729-3440
+561-723-3440
+561-667-4222
+561-541-5443
+561-541-5449
+561-616-8240
+954-295-6132
+954-295-6132
+561-616-8240
+561-616-9240
+954-295-6132
+561-616-8240
+OP
+OP/FU
+OF
+0P/PU
+OP/FU
+OP
+OP
+OP
+OP
+OP/FU
+OP
+OP
+OP/PU
+OP/SU
+561-662-6688
+OP
+PP/PU
+5E3-616-0240
+FP/FU
+561-616-8240
+561-827-2542
+561-827-2542
+561-827-2542
+561-827-2542
+561-502-386E
+FF
+PP
+FP
+Usage
+1:00
+5:00
+2:00
+SEUU
+3E0U
+1:00
+1:00
+2:00
+SLUU
+1:00
+2:00
+4:00
+2:00
+2:00
+3,00
+2:00
+2:00
+1:00
+7,00
+2:00
+1:00
+2:00
+7:00
+4:00
+3:00
+14:00
+5:00
+2:00
+5:00
+1:00
+2:00
+2400
+1: 00
+2:00
+2:00
+1:00
+•.00
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+0000
+D.D0
+D.D0
+0.00|
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+UNIT 4 (561) 723-3440 continued...
+Telecommunications Services Call Detail (561) 723-3440
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+165 May 24 02:13 EM Inconing
+160 Kay 24 02:34 IM N PALA BCH, PL
+167 Kay 24 02:35 PM I PALES BCH, PL
+168 May 24 02137 FM 1 PALA BCH ,PL
+160 Kay 24 02:58 I 1 BALE BCH, PL
+170 Kay 24 03:01 IN N PALE BCH, PL
+171 Kay 24 03:10 PM N PALE BCH, PL
+172 May 24 04.01 EM Incondng
+173 Kay 24 04:16 IN BALE BC, PL
+174 Kay 24 04:50 PM Inconing
+175 May 24 05.15 PM Inconing
+176 ay 24 09:30 m Inconing
+177 Kay 24 05:38 IM N PALA BCH, PL
+178 Kay 24 07:19 PM N PALE BCH, PL
+179 Kay 24 09.34 FM NPALA BCH, PL
+180 кку 25 07:60 лм х кАки всн, PL.
+181 Kay 25 08:52 AM N PALA BCH, PL
+182 May 25 09:09 AM NPALA BCH, PL
+183 Kay 25 09:22 1М Inconing
+184 Kay 25 10:13 AM N PALA BCH, PL
+185 Kay 25 10:26 AM N FALK BCH, PL
+186 May 25 10:24 AM Inconing
+187 Kay 25 02:55 PM N FAL/ RCH, PL
+188 Kay 25 05:59 IM Inconing
+180 Kay 25 06:41 PM N FALK BCH, PL
+190 May 25 06:42 PM N PALM BCH, PL
+191 Kay 25 09:36 IN PLAUDERD, PL
+192 Kay 25 09:44 PM Inconing
+193 May 26 09:09 AM BOXTONCH, PL
+194 Кку 26 09:12 1М
+Inconing
+195 Kay 26 09:16 AM BOYTONBCH, PL
+190 May 26 09:19 AM N PALA BCH, PL
+197 May 26 09:21 AM N PALM BCH,PL
+198 кку 26 09:47 мм
+Inconing
+190 Kay 26 09:54 AM
+Inconing
+200 May 26 10123 AM Inconing
+201 Ka 26 10:24 AM N FACE RCH, PL
+202 Kay 26 11:39 AM N PALA BCH, PL
+203 Kay 26
+12:21
+204 May 26 12136 #M Inconing
+205 Kay 26 12:41 PM Inconing
+Min: Sec
+561-502-3466 PP
+561-502-7753 PD/PU
+561-502-7753 FF/FU
+561-502-7753 PP/PU
+561-302-7753 FD/FU
+561-502-3866 PD/PU
+561-502-7753 FP/FU
+Uneva Liable
+PP
+561-502-366E FF/FU
+561-502-3866 FF
+561-616-9240
+PP
+361-302-38CE FF
+561-662-6688 PD/PU
+561-662-6688
+PF / PU
+561-798-9500
+PP/PU
+PP/PU
+Fe /FU
+561-662-6688 PP
+561-E1E-8240 FD/FU
+561-616-824000
+561-723-3440 FP/PU
+561-502-7753
+PP/PU
+954-295-6132
+0P/PU
+954-295-6132
+561-503-5930
+FP/PU
+561-478-4188
+561-503-5930 PD/PU
+561-723-3440 PP/PU
+561-723-3440
+PP/PU
+561-503-5910
+FF
+561-503-5930
+PP
+561-503-5930 PP
+361-722-1631 FF/FU
+561-352-7000 PD/PU
+954-295-4132 FP/PU
+561-503-5930 PP
+561-303-3930 FF
+Usage
+1100
+1:00
+1:00
+1,00
+2:00
+3: 00
+2:00
+1,00
+1:00
+1100
+2:00
+2:00
+1:00
+4: 00
+1,00
+1:00
+1,00
+1:00
+1:00
+2:00
+1,00
+4: 00
+2:00
+1:00
+2100
+1:00
+2:00
+3,00
+2:00
+1:00
+2:00
+1,00
+2:00
+3:00
+1,00
+2:00
+1:00
+2:00
+2,00
+1:00
+9.00
+Long
+Distance
+0.0D
+0.0D
+0.0D
+0.DD
+0,00
+Total
+Charges
+0.OO
+0,00
+
+
+May 11 - June 10, 2004
+UNIT 4 (561) 723-3440 continued...
+Telecommunications Services Call Detail (561) 723-3440
+See
+Number
+Footnote
+Item # Date Time
+Call To
+208 Kay 26 01,20 EM Inconing
+207 Kay 26 02:06 PM 5 PALA BCH, PL
+205 May 26 02:24 PM IncoRiNg
+209 May 26 03116 EM I PALA BCH, PL
+210 Kay 26 06:08 IN M PALE BCS, FL
+211 Kay 26 04:46 PM Incoming
+Kay 26 05:37 PM I PALE BCH, PL
+213 Kay 26 05,39 PM Inconing
+214 Kay 27 07:42 A M FALL BCH, FL
+215 Kay 27 12:12 PM M PALE BCH, PL
+216 Kay 27 12/14 PM M PALA BCH, FL
+217 Kay 27 12:18 IN M BALE BCH, FL
+218 Kay 27 12:20 PM N PALK BCH, PL
+219 Kay 27 12:22 IN M BALK BCH, PL
+220 Kay 27 12/23 EM M BALK BCH, FL
+221 Kay 27 12:26 IN M BALA BCH, FL.
+222 Kay 27 03:44
+Incoeing
+223 Kay 27 04:10 PM Incoming
+224 Kay 27 04:30 IN Incoeleg
+225 Kay 24 08:12 AM M PALK BCH, PL
+226 Kay 24 08:32 AM M BALK BCH, PL
+227 May 24 11,57 AM Inconing
+228 ay 28 01:03 N M PALE BCH, FL.
+229 Kay 24 02:39 PM I PALK BCH, PL
+230 Kay 24 03:30 PM PTIMDEAD, PL
+231 May 29 07:18 PM Inconing
+232 Kay 29 08:39 AM N PALK BCH, PL
+233Кау 29 09:30 AN PLAUDERD, PL
+234 Kay 29 09,36 AM Inconleg
+235кку 22 03:50 3М M BALL BCH, FL
+235 Kay 29 10:55 AM Inconieg
+237 Kay 29 12:07 PM Inconteg
+235 May 29 01,08 PM Inconleg
+230 Kay 23 01:22 PM Incoaleg
+240 Kay 27 02:18 PM I BALK BCH, PL
+241 May 29 02120 EM Inconing
+242 Kay 29 02:51 m Incaleg
+243 Kay 29 03:03 PM M PALK BCH, PL
+244 May 29 05:22 PM M PALE BCH, PL
+245 Kay 29 06,37 PM FTLAUDERDG, FL
+248 Kay 29 09:10 PM M PALAC BCH, FL.
+Min: Sec
+561-503-5930 FP
+561-248-3883
+561-616-8240
+FP
+561-248-3883
+PP/FU
+561-248-38E3
+PP/BU
+561-502-5212 P9
+561-662-6688
+FP/FU
+561-616-8240 FP
+561-718-4005
+FP/BU
+561-616-8240 PP/FU
+561-662-6688
+FP/PU
+561-686-8906|
+P/SU
+561-662-6688
+19/90
+561-662-6688
+561-964-5511
+PP/PU
+PP/PU
+S63-016-0240
+FP/FU
+561÷502÷7255
+5614508-5980
+PP
+561-616-8240
+561-616-8240
+561-616-8240
+561-616-8240
+561-662-66E8
+561-616-8240
+954-444-6836
+561-333-7530
+561-616-8240
+954-295-6132
+954-548-8594
+561-616-8240
+DP/P0
+PP
+pP/sU
+0P/90
+FP/FU
+OP/PU
+OP/PU
+OP
+OP/SU
+561-616-8240
+561-844-3057
+OP
+OP
+S61-776-1005
+954-295-6132
+561-502-7753
+561-399-7530
+561-723-3440
+954-295-6132
+561-723-3440
+OP/FU
+OP
+OF
+0P/PU
+OP/FU
+OP/FU
+OP/SU
+Usage
+1:00
+2:00
+1:00
+3:00
+1:00
+1:00
+1,00
+3:00
+2:00
+3:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+1:00
+2:00
+1:00
+2:00
+10,00
+2:00
+4:00
+3:00
+1:00
+2:00
+1:00
+3:00
+1:00
+2:00
+3,00
+JE0O
+2:00
+1:00
+2:00
+2:00
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+6.00
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+UNIT 4 (561) 723-3440 continued...
+Telecommunications Services Call Detail (561) 723-3440
+See
+Number
+Footnote
+Item # Date Time
+Call To
+247 May 29 09.11 EM W PALM BCH, PL
+248 Kay 30 06:52 AM Incoming
+240 May 30 06:55 AM Inconing
+250 May 30 07.01 AM Inconing
+251 кку 30 07:26 ЛИ N RALE BCH, PL.
+252 Kay 30 07:33 2M Inconing
+253Кау Кaу 07:37 AM N PALE BCH, PL
+254 May 30 09138 AM I PALA BCH,PL
+256 Кку 30 08:38 ЛИ И РАБИ ПСИ, Р
+256 Kay 30 10:35 AM PILAUDERD, PL
+257 May 30 10151 AM Inconing
+258 Kay 30 12:26 m Inconing
+259 Kay 30 12:29 IM PILAUDERD, PL
+280 Kay 30 05:14 PM Incoming
+281 May 30 05130 EM Incondng
+282 Kay 30 06:02 PM N FAL2 BCH, PL
+283 Kay 31 12:20 IN PILAUDERDG, PL
+284 May 31 01,10 #M Incondng
+265 Kay 31 01:38 IM Inconing
+200 Kay 31 08:36 IM N PALA BCH, PL
+287 May 31 09:36 PM N FACE BCH, PL
+288 Jun 01 09:09 AM W PAL/ BCH, PL
+200 Jun 01 09:50 AM N SALE RCH, PL
+270 Jun 01 09:58 AM N PALA BCH, PL
+271 Jun 01 10:03 AM Inconing
+272 Jun 01 10:30 AM Inconing
+273 Jun 01 10:38 AM N PALA BCH, PL
+274 Jun 01 11:14 M
+Inconing
+275 Jun 01 11:21 AM W PALA BCH,PL
+270 Jun 01 07:04 MY BALA RCH, PL
+277 Jun 01 07:20 IN N PALA BCH, PL
+278 Jun 01 07:21 PM Inconing
+279 Jun 01 07:27 PM N PALM BCH,PL
+280 Jun 01 09:20 PM
+Inconing
+281 Jun 02 06:52 MM Inconing
+282 Jun 02 07:03 AM Inconing
+283 Jun 02 07:53 AM Inconing
+284 Jun 02 C8:01 AM Incoming
+285 Jun 02
+09:50
+Inconing
+28฿ Jun 02 09:25 AM W PALM BCH,PL
+287 Jun 02 09:35 AM Inconing
+Min: Sec
+561-333-7530 08/PU
+561-502-7753 0P
+561-502-7753 OF
+561-502-7753 OP
+361-8E2-6E8E DE/FU
+561-662-668800
+561-502-7753
+De/FU
+561-723-3440 0P/PU
+561-123-3440
+DE /FU
+954-295-6132 CP/FU
+561-333-7530 CP
+954-295-613208
+954-295-6132 00/PU
+561-502-5212 CR
+954-295-6132
+561-502-5212
+OF /FU
+954-295-6132
+561-333-7530
+PP
+361-E6T-4222
+561-723-3440
+PP/PU
+561-723-3446
+Fe /FU
+561-616-4240 PP/PU
+561-E1E-8240 FD/FU
+561-616-8240 P0/PU
+561-616-4240 PP
+407-509-6377 PP
+561-662-6616
+PP/PU
+239-695-2051 PF
+561-662-6166 PP/PU
+561-123-3440 FF/FU
+561-478-5222 PD/PU
+561-616-4240 PP
+561-721-5959 PP/PU
+561-721-3959
+407-509-6377
+ce
+561-242-6019 PP
+407-309-6377 FF
+561-541-5449 P0
+561-474-5890 PP
+561-352-7000 PP/PU
+561-478-4188 FF
+Usage
+4:00
+3:00
+1:00
+2:00
+1:00
+4: 00
+2:00
+1,00
+1:00
+4:00
+11,00
+1:00
+1:00
+1:00
+2100
+1:00
+51 00
+3,00
+2:00
+1:00
+4: 00
+1,00
+5:00
+1:00
+1:00
+3,00
+2:00
+3:00
+1,00
+2:00
+1:00
+1:00
+1,00
+1:00
+2,00
+4: 00
+1:00
+1:00
+5,00
+2:00
+9.00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0.DD
+0.DD
+0,00
+Total
+Charges
+U .UU
+0,00
+
+
+May 11 - June 10, 2004
+UNIT 4 (561) 723-3440 continued...
+Telecommunications Services Call Detail (561) 723-3440
+See
+Item # Date Time
+Call To
+Number
+Footnote
+Min: Sec
+268 Jun 02 09:45 MInconing
+239-695-1573 FP
+2100
+269 Jun 02 09:55 AM MIAMI, PL
+305-592-3480 VP/PU
+1:00
+200 Jun 02 05:48 EN M BALK BCH, PL
+561-616-8240
+FP/FU
+2:00
+291 Jun 02 06:09 PM M BALK BCH, FL
+561-662-6688
+PP/FU
+292 Jun 02 D6:49 PM INcoRleg
+561-634-8487
+1:00
+293 Jun 02 08:09 PM W PALK BCH, PL
+561-723-3440 09/90
+3:00
+204 Jun 03 08:35 AM M BALE BCH, PL
+561-616-8240
+FP/FU
+1:00
+205 Jun 03 12:55 PM Inconing
+561-662-6688
+2:00
+296 Ju: 03 04:50 IN Incoaleg
+561-616-8240
+2:00
+207 Jun 03 05:59 PM M PALE BCH, PL
+561-502-5212
+PP/PU
+2:00
+295 Jun 03 06129 EM M PALA BCH, FL
+561-616-8240
+FP/PU
+1:00
+200 Jun 04 03:07 A Incoeleg
+561-502-5212
+1:00
+300 Jun 04 09:21 2M N PALK BCH, PL
+561-616-8240
+1:00
+301 Jun 04 09:33 1M Inconleg
+561-753-2000
+1:00
+302 Jun C4 09,50 AM Inconing
+561-616-8240
+PP
+2:00
+303лив 04 08:52 A M PALE BC, FL.
+S63-016-0240
+FP/FU
+1:00
+304 Jun 04 10:30 AM Incoming
+S61÷428-418m
+3:00
+305 Jun 04 10:43 AN N BALK BCH, PL
+561-842-6414
+PP/FU
+2:00
+305 Ju: 04 11:13 AN M PALE BC, VL.
+307 Jun 04 11:14 AM PLAUDERDL, PL
+305 Jun 04 03:30 EM M BALK BCH, PL
+309 Jun C4 02/15 EM Inconing
+310 Jur 05 07:42 AM M PALE BCH, FL
+311 Jun 05 07:45 AM Incoming
+312 Jun 05 07:50 2M M PALE BCH, PL
+313 Jun 05 12:11 PM Inconleg
+314 Jun 05 01:41 IN Iecoeieg
+315 Jun O5 03:10 PM Inconleg
+316 Jun 05 03128 EN Inconleg
+561-842-6414
+954-814-9070
+561-662-6688
+561-616-8240
+561-616-8240
+561-616-8240
+561-616-8240
+561-502-7753
+561-616-8240
+561-502-5212
+561-662-6688
+DP/P0
+FP
+OP/SU
+OP
+OP/FU
+OP
+OP
+OP
+OP
+1:00
+3:00
+1:00
+1:00
+2:00
+1:00
+1,00
+2:00
+1:00
+317 Jut O5 D5:08 IN M PALAC BOT, FL
+561.216-2240
+2:00
+1:00
+318 Jun 05 05:18 PM Incoming
+561-616-8240
+1:00
+319 Jun 04 02:36 PM FTLAUDERD, PL
+OP/FU
+2:00
+320 Jun 06 04.10 PM Inconleg
+561-502-5212
+OP
+321 Jun.
+D6:54 PR LECDELEG
+322 Jun 07 07:02 AN M BALK BCH, PL
+2:00
+2:00
+1:00
+323 Jun 07 07:05 /M Inconleg
+324 Jun 07 07:22 A Incaleg
+325 Jun 07 07:55 AM M PAL/ BCH, PL
+326 Jun 07 08:00 AM Inconley
+327 Jun 07 09:18 M Inconing
+328 Jun 07 08:40 AM Iscoeleg
+561-723-3440
+561-502-5212
+561-502-5212
+561-616-8240
+561-616-8240
+561-662-6688
+561-662-66E8
+PP/FU
+FF
+FP
+FP
+FF
+1: 00
+1:00
+1:00
+1:00
+1:00
+Usage
+•.00
+6.00
+6.00
+•.0D
+•.00
+6.00
+0.0D
+6.00
+6.00
+0.0D
+6.00
+0.0D
+6.00
+Long
+Distance
+D.D0
+D.D0
+D.D0
+0000
+D.D0
+D.D0
+0,00
+D.00
+D.00
+D.D0
+continued.
+Total
+Charges
+9.00
+9.00
+9.00
+9.00
+May 11 - June 10, 2004
+UNIT 4 (561) 723-3440 continued...
+Telecommunications Services Call Detail (561) 723-3440
+See
+Number
+Footnote
+Item # Date
+Time
+Call To
+329 Jun 07 11:23 AM Incondng
+330 Jun 07 11:28 AM Inconing
+331 Jun 07 11:57 AM W FACE BCH, PL
+332 Jun 07 01:03 PM Inconing
+333 Jun 07 01:37 IN N BALA BCH, PL
+334 Jun 07 01:39 IN N PALE BCH, PL
+335 Jun 07 01:39 PM Inconing
+338 Jun 07 01:40 EM N PALM BCH,PL
+337 Jun 07 01:40 PM N FALE RICH, PL
+338 Jun 07 03:01
+#M Inconing
+330 Jun 07 04:11 PM W PALA BCH,PL
+340 Jun 07 04:13 m Inconing
+341 Jun 07 64:24 IM Incoring
+342 Jun 07 04:33 IM Inconing
+343 Jun 07 04:45 EM W PALA BCH, PL
+344 Jun 07 09:14 m Inconing
+345 Jun 07 07:43 m
+Incoming
+348 Jun 07 09:42 IM W PALM BCH, PL
+347 Jun 07 09:46 IN Inconing
+348 Jun 08 06:50 AM N PALA BCH, PL
+340 Jun 08 08:52 AM Incoming
+350 Jun 08 01155 EM Inconing
+351 Jun D8 05:64 PM N SALE RCH, PL
+352 Jun 08 07:04 IM PILAUDERDL, PL
+353 Jun 08 07:17 PM N FALK BCH, PL
+354 Jun 09
+11:08 AM Inconing
+355 Jun 09 11:21
+AM
+Inconing
+356 Jun 09 12:00 PM N PALE BCH, PL
+357 Jun 09 12:01 PM W PALA BCH,PL
+358 Jun 03 12:11 m
+Inconing
+359 Jun 09 01:46 IM N PALA BCH, PL
+380 Jun 09 03:50 IM Inconing
+301 Jun 10 07:32 AM N PALM BCH,PL
+382 Jun
+0:16 101 N FALE RCH, PL
+383 Jun
+04:19 AM N PALA BCH,PL
+384 Jun
+08,21 AM N PALM BCH, PL
+365 Jun
+AM I FALE RICH, PL
+306 Jun 10
+10:47 AM N PALA BCH, PL.
+367 Jun 10
+02:43
+Inconing
+368 Jun 10 02:44 EM Incoming
+380 Jun 10 02:47 PM Inconing
+Min: Sec
+561-722-7428 PP
+561-616-8240P0
+561-442-6414 FF/FU
+561-666-9906 PP
+361-8E2-6E8E FD/FU
+561-662-6688 PD/PU
+561-662-6668 FP
+561-541-4051 PP/PU
+561-541-4051
+FE /FU
+561-502-5212 FF
+561-616-9240
+PP/PU
+561-616-8240 FF
+561-662-6668 P8
+561-662-6684 PR
+
+PP/PU
+FF
+561-662-6648
+PP/PU
+361-E62-8C8E
+561-662-6688
+561-694-2497
+561-723-1421 PP
+561-E1E-8240 FD/FU
+954-295-6132 PD/PU
+561-616-4240
+FF /PU
+561-616-9240
+PP
+561-478-4188
+PP
+561-352-3000
+FF/PU
+561-474-4148
+PP/PU
+561-478-4188
+561-723-3440 PD/PU
+561-616-8240 PP
+561-541-4051
+PP/PU
+561-723-3440
+FF /FU
+561-723-3440
+PP/PU
+561-723-3440 PP/PU
+361-718-4005 FF/FU
+561-662-6688 PD/PU
+561-616-4340 PP
+561-616-9240 PP
+615-324-2054 FF
+Usage
+1100
+2:00
+1:00
+1,00
+2:00
+1:00
+1:00
+1,00
+1:00
+1100
+1,00
+1:00
+3:00
+4: 00
+2:00
+1:00
+21O0
+9,00
+1:00
+2:00
+1:00
+1,00
+1:00
+4:00
+1:00
+1,00
+1:00
+1:00
+4:00
+1:00
+1:00
+1:00
+3,00
+1:00
+1,00
+2:00
+1:00
+1:00
+1,00
+1:00
+9.00
+Long
+Distance
+0.0D
+0.0D
+B. DD
+0.0D
+0. 00
+0.DD
+0.DD
+0,00
+0-O0
+Total
+Charges
+0.OO
+0,00
+
+
+Statement Cate
+June 15,2004
+May 11 - June 10, 2004
+UNIT 4 (561) 723-3440 continued...
+Telecommunications Services Call Detail (561) 723-3440
+Item # Date Time
+Call To
+370 Tun 10 03,52 PN Ieconlng
+371 Jun 10 04:14 IM W PALA BCH, PL
+TOTAL
+Footnote
+Services
+Usage
+561-662-6688 FP
+561-616-8240 VP/PU
+Min: Sec
+5100
+2:00
+745,00
+Long
+Distance
+Total
+Charges
+80.00
+Features
+CVCall Wating
+CF-Call Forwarding
+3W-Three Way Call
+DS-Dialup Service
+Networks
+NN-National Network
+Time Period
+TJ-Tijuana Network
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/3934cce5acb172644b4d25af00be2acd061b2640bbf980a10a43cbf73ba5f1f7.receipt.json b/vision-fixhub/ds9-unparsed-06/3934cce5acb172644b4d25af00be2acd061b2640bbf980a10a43cbf73ba5f1f7.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..111c6a1bcddac6f98122351386ee316b7225189f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3934cce5acb172644b4d25af00be2acd061b2640bbf980a10a43cbf73ba5f1f7.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -61263,
+  "dataset": "marble-joined",
+  "doc_id": "3934cce5acb172644b4d25af00be2acd061b2640bbf980a10a43cbf73ba5f1f7",
+  "engine": "marble-apple-vision",
+  "event_count": 96,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "f3bd75cdf19b1eeaca81e9484f93240400aba106c384e535cc7194e470ee7d1f",
+  "output_sha256": "08419fc593bdec79ee20cbce9534132b43091b38f2460b9c6bb4c32456bdd851",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/394b491f7bf9cd6bbcb886d4fed25ddf61edc64a431362b8534c6e8bdaade91c.md b/vision-fixhub/ds9-unparsed-06/394b491f7bf9cd6bbcb886d4fed25ddf61edc64a431362b8534c6e8bdaade91c.md
new file mode 100644
index 0000000000000000000000000000000000000000..41c92781b0bb7557740397b305e502110c57e102
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/394b491f7bf9cd6bbcb886d4fed25ddf61edc64a431362b8534c6e8bdaade91c.md
@@ -0,0 +1,46 @@
+From:
+To:
+Subject: Activity in Case 9:08-cv-80893-KAM Doe I. Epstein Order on Motion for Protective Order
+Date: Tue, 14 Sep 2010 12:48:14 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 9/14/2010 at 8:48 AM EDT and filed on 9/14/2010
+Case Name:
+Doe | Epstein
+Case Number:
+9:08-cv-80893-KAM
+Filer:
+WARNING: CASE CLOSED on 07/20/2010
+Document Number: 218
+Docket Text:
+ORDER Denying Without Prejudice [214] Motion for Protective Order; Denying Without
+Prejudice [214] Motion for Leave to File. Signed by Magistrate Judge Linnea R. Johnson on
+9/14/2010. (sa)
+9:08-cv-80893-KAM Notice has been electronically mailed to:
+Bradley James Edwards
+Jack Alan Goldberger j
+Katherine Warthen Ezell
+Lilly Ann Sanchez Isan
+Michael James Pike M
+Paul G. Cassell
+Robert Deweese Critton,
+
+
+9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP dcecfStamp_ID=1105629215 [Date=9/14/2010] [FileNumber=7993999-0
+][9c078264607f4bb2a43b82ee3е255f9a361c19c9f39d3ee9eaб6196af475c62c0c5
+3f31bbeca37e3еа3f1Oafa79568cdb7e14b1cdffecee99fd6bfbd377c9a84]]
diff --git a/vision-fixhub/ds9-unparsed-06/394b491f7bf9cd6bbcb886d4fed25ddf61edc64a431362b8534c6e8bdaade91c.receipt.json b/vision-fixhub/ds9-unparsed-06/394b491f7bf9cd6bbcb886d4fed25ddf61edc64a431362b8534c6e8bdaade91c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f9349dacff05ae590fa353c6f72c39b2061068db
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/394b491f7bf9cd6bbcb886d4fed25ddf61edc64a431362b8534c6e8bdaade91c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "394b491f7bf9cd6bbcb886d4fed25ddf61edc64a431362b8534c6e8bdaade91c",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "dad5360ebbf71b8dce0fe619cf33bdf5208db4dab2cc053b4f63aa1f7889c127",
+  "output_sha256": "a3241a03b2a89e17e1c2d3ccd128f07a93efb7775ef977193986830382ccdc7d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/39c2cd506409e2e753c1b9957943045207c5c98e033f26cbc72cbef821a65005.md b/vision-fixhub/ds9-unparsed-06/39c2cd506409e2e753c1b9957943045207c5c98e033f26cbc72cbef821a65005.md
new file mode 100644
index 0000000000000000000000000000000000000000..eb55c4c3da5b75c0f54d9c67350c1d5ace167c8a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/39c2cd506409e2e753c1b9957943045207c5c98e033f26cbc72cbef821a65005.md
@@ -0,0 +1,178 @@
+X cingular
+Questions or Changes?
+cingular.com
+* Toll Free 1 866 293-4634
+* 611 from your wireless phone
+TTY users - 1 866 429-7TTY
+SUMMARY OF MONTHLY CHARGES FOR ACCOUNT
+Previous
+Balance
+0.58
+Payments
+Received
+0.00
+Late Payment
+Charge
+0.00
+Total
+Adjustments
+0.00
+Your billing cycle began on April 12, 2005 and ended on May 11, 2005
+Current Monthly Charges
+Monthly Service
+Monthly Usage
+Charges
+Credits
+Government Fees and Taxes
+Total Current Monthly Charges
+TOTAL AMOUNT - Due Upon Receipt
+Date of Invoice: May 13, 2005
+Balanc
+orward
+0.58
+0.00
+0.00
+0.00
+0.00
+0.00
+0.00
+Current Monthly
+Charges
+0.00
+Total
+Amount Due
+0.58
+0.58
+CINGULAR EXCLUSIVE! OFFICIAL STAR WARS (TM) RINGTONES,
+GRAPHICS & GAMES ARE NOW AVAILABLE FOR YOUR PHONE.
+PICK RINGTONES AND MORE FROM STAR WARS EPISODE III:
+REVENGE OF THE SITH, THE NEW BIG-SCREEN STAR WARS
+MOVIE IN THEATERS MAY 19, OR MAKE YOUR SELECTION FROM
+THE 5 PAST STAR WARS BLOCKBUSTERS. TO LOAD YOUR PHONE
+WITH EXCLUSIVE STAR WARS RINGTONES, GRAPHICS AND GAMES,
+GO TO MMODE, HIT WHAT'S HOT AND SELECT STAR WARS.
+cingular
+Account Name:
+Please Return This Portion With Your Paymen
+Jse of service or payment of this invoice
+indicates concions for viteless servilterms
+Date Due
+UPON RECEIPT
+Note:
+=>
+We Print on
+Front and Back
+Service #
+Account #|
+Total
+Amount Due
+0.58
+Crackes secretse.
+Amount
+Paid
+.5.01.01.1011.0000
+CINGULAR WIRELESS
+PO BOX 8229
+AURORA IL 60572-8229
+
+
+
+Recurring Electronic Fund Transfer (REFT): To enroll: sign below, check the REFT box on the reverse side and
+remit with this month's payment. Keep paying your bill until your statement indicates "Do Not Pay". REFT
+Agreement: I authorize my financial institution to deduct the amount of my monthly wireless phone bill from the
+account associated with the enclosed check and remit payment to Cingular Wireless. This authority will be effective
+until I notify Cingular Wireless to terminate it. I agree that I may be assessed a service charge (up to $20) or late
+tee or both it a payment is returned by my bank. For more information visit cingular.com/myaccount or call 1 866
+293-4634. Please keep a copy of the form below and this REFT Agreement for your records or retain a copy of the
+blank form from next month's invoice.
+Questions? We can help: Cingular Wireless appreciates your business and welcomes the opportunity to assist
+you. Visit our website at cingular.com or contact Customer Care by dialing 611 from your wireless phone or 1 866
+293-4634. ¿ Sabías que también ofrecemos servicio al cliente en tu idioma? Marca 611 desde tu teléfono
+inalambrico ó 1 866 293 4634 desde cualquier teléfono y oprime el *.
+Driving Wireless Safety: Your wireless phone gives you the freedom and flexibility to stay in touch when you
+travel, but don't let a phone call distract you from driving safely. Use hands-free device if allowed or required by
+law. Call Carefully, Arrive Safely.
+Cingular Wireless Processing Fees: Accounts suspended for non-payment will be subject to a $25 reactivation
+fee per line and may be assessed a security deposit prior to reinstatement. Checks returned for non-sufficient funds
+will be charged up to a $30.00 fee.
+Local Tax: Local taxes are based on local government boundaries, the address information you provide for your
+account and/or your wireless telephone number. Please review the local tax charges on your bill. If you believe
+there is an error in the local tax charge, please contact us immediately at 1 866 293-4634. Please note that some
+local or state laws may require you to follow special procedures when notifying us about a local tax dispute. You
+may also use the form below to notify us of any change to your taxing address. Thank you for your cooperation.
+Early Termination Fee (ETF): If you cancel service before your contract end date (including if you switch your
+wireless number to another carrier), you will be charged an Early Termination Fee of up to $200.
+Please Send Correspondence To:
+Cingular Wireless Next Generation Correspondence
+P.O. Box 68056
+Anaheim Hills, CA 92817-8056
+0.000014659.2
+Accoung Name and transier Financial Responsibless clearly and check the box on the reverse side. Please contact Customer Care to change the
+New Billing Address
+City
+State
+Zip
+Home Phone (.
+_)
+Work Phone (_
+If your billing address is NOT your Tax Address, please enter the Tax Address below. (Multi-line accounts should attach a list of each wireless number
+and the respective Tax Address.)
+New Tax Address
+City
+Wireless Number (
+State
+Zip
+Recurring Electronic Fund Transfer (REFT) Enrollment. Please read the agreement on the top portion of this page, sign below and check
+he "REFT Registration" box on the reverse side
+Financial Account Holder Signature
+• + I do not wish to receive email notification of special ofter avalable to Cingular Wireless customers.
+
+
+* cingular
+raising the bar
+Account Number
+Account Name
+Date of Invoice
+May 13, 2005
+
+ACCOUNT DETAILS
+Current Subscriber Monthly Charges and Credits
+Subscriber Number
+Subscriber Name
+Total Current Subscriber Monthly Charges and Credits
+Total Current Monthly Charges
+SUMMARY OF CURRENT ACTIVITY
+FOR
+Monthly Service Charges
+Item Description
+Service Dates
+04/12/05 - 05/11/05
+3 FARE WE EL ME PLENISHMENT
+04/12/05 • 05/11/05
+04/12/05 • 05/11/05
+04/12/05 • 05/11/05
+5 GO PHONE UNLIMITED NIGHTS AND WEEKENDS 04/12/05 • 05/11/05
+6 DETAIL BILLING
+Total Monthly Service Charges
+TOTAL CURE CHAS ON M
+Charge
+0.00
+Charge
+0.00
+0.00
+0.00
+** THIS SPACE INTENTIONALLY LEFT BLANK ***
+0.00
+0.000014560
+
+
+x cingular
+g the
+Account Number
+Account Nama
+Date of Invoice
+May 13, 2005
+
+*** THIS SPACE INTENTIONALLY LEFT BLANK ***
+***THIS SPACE INTENTIONALLY LEFT BLANK ***
+0.000014660
diff --git a/vision-fixhub/ds9-unparsed-06/39c2cd506409e2e753c1b9957943045207c5c98e033f26cbc72cbef821a65005.receipt.json b/vision-fixhub/ds9-unparsed-06/39c2cd506409e2e753c1b9957943045207c5c98e033f26cbc72cbef821a65005.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..730b10fb50182d72ee1202435d6d593b29171440
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/39c2cd506409e2e753c1b9957943045207c5c98e033f26cbc72cbef821a65005.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -112,
+  "dataset": "marble-joined",
+  "doc_id": "39c2cd506409e2e753c1b9957943045207c5c98e033f26cbc72cbef821a65005",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "e6dbe953aba333e89448d8ea522b1080764c7dfe591ea7ba8d81e8f94a0ad9a4",
+  "output_sha256": "32572a1da20ba89fd263505987ac2e523bb996e9dee27e39e3bbcf9e61e6f1fe",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/39f18e34ec3a0822660a6772e04f192cab72dfc110606dc43e430425a27cbc58.md b/vision-fixhub/ds9-unparsed-06/39f18e34ec3a0822660a6772e04f192cab72dfc110606dc43e430425a27cbc58.md
new file mode 100644
index 0000000000000000000000000000000000000000..5f30c1e6d44fc285fc77c80aef723bd8cd5a50fb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/39f18e34ec3a0822660a6772e04f192cab72dfc110606dc43e430425a27cbc58.md
@@ -0,0 +1,5 @@
+subject, Epsrensane Doe sunr
+Date: Thu, 20 Jun 2013 14:26:42 +0000
+Importance: Normal
+Judge Marra just ruled against the US in the victims' rights suit. Our office hasn't decided how it will handle this yet,
+but please continue to maintain all evidence and electronic files. Thanks.
diff --git a/vision-fixhub/ds9-unparsed-06/39f18e34ec3a0822660a6772e04f192cab72dfc110606dc43e430425a27cbc58.receipt.json b/vision-fixhub/ds9-unparsed-06/39f18e34ec3a0822660a6772e04f192cab72dfc110606dc43e430425a27cbc58.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..77c2be5a2461e6a9d0fd1be0c08736eec42076c3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/39f18e34ec3a0822660a6772e04f192cab72dfc110606dc43e430425a27cbc58.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "39f18e34ec3a0822660a6772e04f192cab72dfc110606dc43e430425a27cbc58",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "ae0fcbbced716676fc42aa73fc6efec6b639898f32b8f0ed798d017c8ab4db2d",
+  "output_sha256": "3526efcc47ac3a6db96054d1f06ce9cd35e00faddb86c5de1558464a20f824a7",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3a5add977d3cd3e455cefa08c6f1924d96dd40e32ba829474efd2693e72e6ad6.md b/vision-fixhub/ds9-unparsed-06/3a5add977d3cd3e455cefa08c6f1924d96dd40e32ba829474efd2693e72e6ad6.md
new file mode 100644
index 0000000000000000000000000000000000000000..a98470374f6a03769f9cbc97c8d24c86e74704d3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3a5add977d3cd3e455cefa08c6f1924d96dd40e32ba829474efd2693e72e6ad6.md
@@ -0,0 +1,46 @@
+From:
+To:
+(USAFLS)" <
+| (USAFLS)" <
+Subject: RE: Your response
+Date: Thu, 26 Jan 2012 16:01:49 +0000
+Importance: Normal
+Attachments: Response_to_Remedies_-_MFK_-_1-24-2012_639p.doex
+I don't think I would do that. Here's what
+wrote.
+undertook to review and edit the section
+Tuesday night. He just gave me some (3 or 4) minor cosmetic edits. I have never really read it through fully, but
+I had planned to change the intro to say it is a brief, non-comprehensive treatment of issues the court need not
+reach. In any event, I have to get on a conference call. Let me know what you think.
+From:
+(USAFLS)
+Sent: Thursday, January 26, 2012 10:47 AM
+To:
+(USAFLS)
+Subject: RE: Your response
+I think I would have to see the rest of the other response first. I might then cut and paste one small
+portion of it into this response.
+Assistant U.S. Attorney
+Fax
+From:
+(USAFLS)
+Sent: Thursday, January 26, 2012 10:46 AM
+I. (USAFLS)
+Subject: RE: Your response
+If you have any thoughts, suggestions, additions, etc., l am open to them.
+-
+From:
+I. (USAFLS)
+Sent: Thursday, January 26, 2012 10:38 AM
+To: l
+(USAFLS)
+Subject: Your response
+Hi
+- Sorry, I just realized that I forgot to respond about your email from last night. I think it
+looks fine. I am not crazy about the fact that we don't cite any law, but they don't cite anything
+either.
+
+
+Thank you so much for your help on that case!
+Assistant U.S. Attorney
+Fax
diff --git a/vision-fixhub/ds9-unparsed-06/3a5add977d3cd3e455cefa08c6f1924d96dd40e32ba829474efd2693e72e6ad6.receipt.json b/vision-fixhub/ds9-unparsed-06/3a5add977d3cd3e455cefa08c6f1924d96dd40e32ba829474efd2693e72e6ad6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..acb4f63bd6078868d6d6db0d6ee307ee66b112ef
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3a5add977d3cd3e455cefa08c6f1924d96dd40e32ba829474efd2693e72e6ad6.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "3a5add977d3cd3e455cefa08c6f1924d96dd40e32ba829474efd2693e72e6ad6",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "efb728ee95d0515b75ca72de5d92c064b86fcbac676c41ff715082af4f423e16",
+  "output_sha256": "7b511a529aabe40ccb347d5d63fe70352718b69854754be9d2d708a28a5d3151",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3aec8f6a768c6ba454b076dde6a97f2dd01c47892457a9c70580e309d2422590.md b/vision-fixhub/ds9-unparsed-06/3aec8f6a768c6ba454b076dde6a97f2dd01c47892457a9c70580e309d2422590.md
new file mode 100644
index 0000000000000000000000000000000000000000..217106fea9823886757c6e075e6217155d218498
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3aec8f6a768c6ba454b076dde6a97f2dd01c47892457a9c70580e309d2422590.md
@@ -0,0 +1,48 @@
+From:
+To:
+Subject: Activity in Case 9:08-cv-80736-KAM Doe I. United States of America Order on Motion for
+Extension of Time to File Response/Reply
+Date: Mon, 19 Sep 2011 19:03:55 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 9/19/2011 at 3:03 PM EDT and filed on 9/19/2011
+Case Name:
+Doe | United States of America
+Case Number:
+9:08-CV-80736-KAM
+Filer:
+Document Number: 97
+Docket Text:
+ORDER granting [95] Motion for Extension of Time to File Response/Reply to [93] MOTION to
+Intervene For Limited Intervention by Jeffrey Epstein. Signed by Judge Kenneth A. Marra on
+9/19/2011. (ir)
+9:08-cv-80736-KAM Notice has been electronically mailed to:
+Bradley James Edwards
+Bruce Reinhart
+Dexter Lee
+dext
+Jacqueline Perczek
+Jay C. Howell
+Jay P. Lefkowitz
+Martin G. Weinber
+
+
+Paul G. Cassell
+9:08-cv-80736-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+The following document(s) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=9/19/2011] [FileNumber=9254595-0
+][5fl2029e18ab06041278ddb07f1916572e311247474b9603e40d0ac7ca7028aa852
+eacb0cd4ee0296693ba8904652972112df3551df954c3997ba13666a83667]]
diff --git a/vision-fixhub/ds9-unparsed-06/3aec8f6a768c6ba454b076dde6a97f2dd01c47892457a9c70580e309d2422590.receipt.json b/vision-fixhub/ds9-unparsed-06/3aec8f6a768c6ba454b076dde6a97f2dd01c47892457a9c70580e309d2422590.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..762f4b87cb67263e36d718c279bdbc09181da472
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3aec8f6a768c6ba454b076dde6a97f2dd01c47892457a9c70580e309d2422590.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "3aec8f6a768c6ba454b076dde6a97f2dd01c47892457a9c70580e309d2422590",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "4da5569d6f1d18190bdbc131ad867ed0decdab4eb34e386bb1a6ebdb7fa64f44",
+  "output_sha256": "4b117a2cde988a772a5f96f784fc4aca85a171f6e68cc5869bc0d863ca600440",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3b1f9926a4981f804e83b09b67b9e32130bad5b3de0dea4125c3e700cb76f96d.md b/vision-fixhub/ds9-unparsed-06/3b1f9926a4981f804e83b09b67b9e32130bad5b3de0dea4125c3e700cb76f96d.md
new file mode 100644
index 0000000000000000000000000000000000000000..2b411c5a24d292d6ece6cdc43e64963cae2ef346
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3b1f9926a4981f804e83b09b67b9e32130bad5b3de0dea4125c3e700cb76f96d.md
@@ -0,0 +1,17 @@
+From: "
+• (USAFLS)"
+To: "
+(USAFLS)" <
+Cc: "l
+| (USAFLS)" •
+Subject: Revised Indictment
+Date: Mon, 07 May 2007 19:40:57 +0000
+Importance: Normal
+Attachments: 070507_Indictment.wpd
+Hi
+the counts)
+- I caught a few typos today in the indictment, so here is a revised version (they didn't change any of
+I don't think you sent the indictment to
+know. Thank you.
+yet, but if you want me to send it to him, please let me
+Assistant U.S. Attorney
diff --git a/vision-fixhub/ds9-unparsed-06/3b1f9926a4981f804e83b09b67b9e32130bad5b3de0dea4125c3e700cb76f96d.receipt.json b/vision-fixhub/ds9-unparsed-06/3b1f9926a4981f804e83b09b67b9e32130bad5b3de0dea4125c3e700cb76f96d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7bdcb9339817a0f0deb3b839609f010edfd116ea
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3b1f9926a4981f804e83b09b67b9e32130bad5b3de0dea4125c3e700cb76f96d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "3b1f9926a4981f804e83b09b67b9e32130bad5b3de0dea4125c3e700cb76f96d",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "75512a030379669df8428e1d83f7bf5af351032be558038902f0e900334774b0",
+  "output_sha256": "c8d836665cfb847c5c88d0fbb1e8dbb04cc2274592171d70eba26f75b2344359",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3b36edd88ba562c2a9af95e9e6a1909e5786eb3af03e375aaacaf402929dd670.md b/vision-fixhub/ds9-unparsed-06/3b36edd88ba562c2a9af95e9e6a1909e5786eb3af03e375aaacaf402929dd670.md
new file mode 100644
index 0000000000000000000000000000000000000000..e0c20e6bdc7340b9c96950dbd85ad449e21b9e42
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3b36edd88ba562c2a9af95e9e6a1909e5786eb3af03e375aaacaf402929dd670.md
@@ -0,0 +1,9 @@
+Subject: FW: Epstein
+Date: Fri, 27 Aug 2010 21:14:04 +0000
+Importance: Normal
+Ms. Sarnoff has called former U.S. Attorney Acosta with some information. Can we all talk on Monday?
+Thanks.
+Sent: Fridav Aunust 27 2010 4-07 ₽M
+Subject:
+Conchita Sarnoff: 2
+hanks.
diff --git a/vision-fixhub/ds9-unparsed-06/3b36edd88ba562c2a9af95e9e6a1909e5786eb3af03e375aaacaf402929dd670.receipt.json b/vision-fixhub/ds9-unparsed-06/3b36edd88ba562c2a9af95e9e6a1909e5786eb3af03e375aaacaf402929dd670.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e31d0e24842354f49bfbd707934183952e970cff
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3b36edd88ba562c2a9af95e9e6a1909e5786eb3af03e375aaacaf402929dd670.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "3b36edd88ba562c2a9af95e9e6a1909e5786eb3af03e375aaacaf402929dd670",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "363eb0bb3b60f6e3ae55be629389488ec0cbaca91b3e35be9c66d676d30afffd",
+  "output_sha256": "cd7ecbe5cb6c6788cc069c8ce776e1233d09d8a7700c7466c0d52544ede9e65b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3b573d80c2aa6c92c223720f92f6ae863272ebf0a50a6b253080d118ed86a497.md b/vision-fixhub/ds9-unparsed-06/3b573d80c2aa6c92c223720f92f6ae863272ebf0a50a6b253080d118ed86a497.md
new file mode 100644
index 0000000000000000000000000000000000000000..c6aa50ced9d087022733fcdf068cdba3dd83a183
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3b573d80c2aa6c92c223720f92f6ae863272ebf0a50a6b253080d118ed86a497.md
@@ -0,0 +1,11 @@
+Event: Accepted: Meeting re: Jane Does |. United States aka Epstein Matter
+Start Date: 2013-06-20 20:00:00 +0000
+End Date: 2013-06-20 21:00:00 +0000
+Location: Executive Conference Room
+Class: X-PERSONAL
+Comment:
+Date Created: 2013-06-25 14:19:17 +0000
+Date Modified: 2013-06-25 14:23:21 +0000
+Priority: 5
+DTSTAMP: 2013-06-20 19:03:02 +0000
+Attendee: Sanchez, Eduardo (USAFLS) <ESanchez1@usa.doj.govs
diff --git a/vision-fixhub/ds9-unparsed-06/3b573d80c2aa6c92c223720f92f6ae863272ebf0a50a6b253080d118ed86a497.receipt.json b/vision-fixhub/ds9-unparsed-06/3b573d80c2aa6c92c223720f92f6ae863272ebf0a50a6b253080d118ed86a497.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c5764a4ac436884c603bd78c6c2599f80b96686b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3b573d80c2aa6c92c223720f92f6ae863272ebf0a50a6b253080d118ed86a497.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "3b573d80c2aa6c92c223720f92f6ae863272ebf0a50a6b253080d118ed86a497",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "94d319bcb046adb6d78b5c7810c432b192a1925ed7d224f9bfd638de0c53609f",
+  "output_sha256": "1bd9cef2d10eeeee15b82384c1ab157e8ecf0104620d9fc6f9cd5ab64029f086",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3b6b8740db1892dfa805c33fbc957ae5d0a227b697b542545cf7afc844bd37cb.md b/vision-fixhub/ds9-unparsed-06/3b6b8740db1892dfa805c33fbc957ae5d0a227b697b542545cf7afc844bd37cb.md
new file mode 100644
index 0000000000000000000000000000000000000000..4956652108354b5108747c047f0f4fb9dc9bc357
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3b6b8740db1892dfa805c33fbc957ae5d0a227b697b542545cf7afc844bd37cb.md
@@ -0,0 +1,33 @@
+From:
+To:
+Subject: Re: E-mail questions from Newsweek.
+Date: Wed, 20 Jul 2011 21:22:03 +0000
+Importance: Normal
+Thanks. I will review the email and we can discuss tomorrow.
+---- Original Message -...-
+From: L
+Sent: Wednesday, July 20, 2011 05:15 PM
+Ce: Atkinson, Karen (USAFLS), Garcia, Rolando (USATLS), Nucci, Edward (USATLS), Stamm, Edward (USATLS), Sanchez, Eduardo
+(0941L9), Елееность, Венунии (9847 66)
+Subject: FW: E-mail questions from Newsweek.
+Hi Alicia -- Here is the email from Newsweek. Please respond as the Office sees fit.
+Assistant U.S. Attorney
+561-209-1047
+-Original Message-
+From: Barrett, Wayne [mailto: Wayne. Barrett@newsweekdailybeast.com]
+Sent: Wednesday, July 20, 2011 4:58 PM
+To:D
+Subject:
+Hi Ma. Villaima,
+This is Jacob Albert, research assistant for Wayne Barrett, at Newsweek. I know you've said that you wouldn't comment on our questions,
+but I wanted to give you the chance to hear what we're asking before declining. If you'd rather speak by phone, on or off record, I'm
+1) The nonprosecution deal that you worked out specified that Epstein would do 30 months in jail? What's your understanding of why he
+did only 13 of the 18mo of his jail sentence, and why was he excused from the carrying out the remainder of his sentence? Who approved
+the sentence reduction, at state or federal level, and why?
+2) Do you have any knowledge of how Jeffrey Epstein was able to preserve personal and corporate tax benefits/exemption in the Virgin
+Islands, in 2009, which requires residency (183 days) that Epstein was unable to meet, as he was under house arrest during that period? Do
+you know whether VI residency requirements for tax benefits/exemptions are waived if you're in prison or under house arrest in another
+If you still have no comment, please let me know; the article running in Newsweek will state that your office wouldn't comment.
+Thanks,
+Jacob Albert
+Research Assitant for Wayne Barrett
diff --git a/vision-fixhub/ds9-unparsed-06/3b6b8740db1892dfa805c33fbc957ae5d0a227b697b542545cf7afc844bd37cb.receipt.json b/vision-fixhub/ds9-unparsed-06/3b6b8740db1892dfa805c33fbc957ae5d0a227b697b542545cf7afc844bd37cb.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e611ca876700595b200e860db0139a3226cf3f4a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3b6b8740db1892dfa805c33fbc957ae5d0a227b697b542545cf7afc844bd37cb.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "3b6b8740db1892dfa805c33fbc957ae5d0a227b697b542545cf7afc844bd37cb",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "2a7a49563c4c91ed940f9e2a87992516c4fad71b39d47883c9fc2ae8fdc61104",
+  "output_sha256": "413b37463db6453384896dac93f03650f14a1f834290bf29b4a0d44457ffacaa",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3b86b010eb43e46afd7228ef9a63e9500ce26ccd1b4f35b9473eac5090a5c60d.md b/vision-fixhub/ds9-unparsed-06/3b86b010eb43e46afd7228ef9a63e9500ce26ccd1b4f35b9473eac5090a5c60d.md
new file mode 100644
index 0000000000000000000000000000000000000000..69267a1620a445e73117ee745fc2972aaa4e2b91
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3b86b010eb43e46afd7228ef9a63e9500ce26ccd1b4f35b9473eac5090a5c60d.md
@@ -0,0 +1,43 @@
+From:
+To:
+Subject: Activity in Case 9:08-cv-80893-KAM Doe v. Epstein Answer to Amended Complaint
+Date: Fri, 12 Mar 2010 20:39:49 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. Distriet Court
+Southern Distriet of Florida
+Notice of Electronic Filing
+The following transaction was entered by Pike, Michael on 3/12/2010 at 3:39 PM EST and filed on 3/12/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 131
+Doe v. Epstein
+9:08-cv-80893-KAM
+Jeffrey Epstein
+Docket Text:
+Defendant, Epstein's, ANSWER and Affirmative Defenses to Amended Complaint by Jeffrey
+Epstein. (Pike, Michael)
+9:08-cv-80893-KAM Notice has been electronically mailed to:
+Bradley James Edwards
+Jack Alan Goldberger
+Michael James Pike
+Paul G. Cassell
+Robert Deweese Critton, Jr
+9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+The following documents) are associated with this transaction:
+
+
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=3/12/2010] [FileNumber=7355030-0
+][4a738f02ab43616bdadfбc40c2cb3b3b285d4994a086ce9307cc4dd188ddb376398
+451fb9f1526f68c8a1ce58644cbbdf8d3da2c258fd676fc9104d54a49d311]]
diff --git a/vision-fixhub/ds9-unparsed-06/3b86b010eb43e46afd7228ef9a63e9500ce26ccd1b4f35b9473eac5090a5c60d.receipt.json b/vision-fixhub/ds9-unparsed-06/3b86b010eb43e46afd7228ef9a63e9500ce26ccd1b4f35b9473eac5090a5c60d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..13df29541798932fe7747dda6c31bd0b9fa71c50
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3b86b010eb43e46afd7228ef9a63e9500ce26ccd1b4f35b9473eac5090a5c60d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "3b86b010eb43e46afd7228ef9a63e9500ce26ccd1b4f35b9473eac5090a5c60d",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "bb7fffaf4bcc82d554abed791fe5c50d29aa3cfe882100f8265a9548cbeb87aa",
+  "output_sha256": "09d2abfdc2cf3bd25285cb3f9be3d1bfd3880870fb9dc13511e9bffe8bdd7a7e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3b8dd5f00a3dd8d084c1723b748b6be87dc61e4111435c7e3f7a34d5b0393784.md b/vision-fixhub/ds9-unparsed-06/3b8dd5f00a3dd8d084c1723b748b6be87dc61e4111435c7e3f7a34d5b0393784.md
new file mode 100644
index 0000000000000000000000000000000000000000..105163e3c5d0b766807d571a0004fb6b09683b89
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3b8dd5f00a3dd8d084c1723b748b6be87dc61e4111435c7e3f7a34d5b0393784.md
@@ -0,0 +1,4791 @@
+Biling Cycle Date:
+Account Number:
+21505-031405
+How To Contact Us:
+• 1-800-331-0500 or 611 from your wireless phone
+• For Deaf / Hard of Hearing Customers (TTY/TDD)
+1-866-241-6567
+Wireless Number
+Previous Balance
+Payments Posted
+PAST DUE BALANCE
+Payable Immediately
+Monthly Service Charges
+Usage Charges
+Credits/Adjustments/Other Charges
+Government Fees and Taxes
+TOTAL CURRENT CHARGES
+Due Apr 06, 200:
+Late fees assessed after Apr O
+Total Amount Due $179.96
+96.22
+96.22
+45.98
+11.18
+16.74
+9.84
+83.74
+***This Bill Includes A Past Due Balance***
+or www.cingular.com. If your service is suspended, a reconnection fee will apply. If you
+have questions regarding your account, contact us at 1-800-947-5096.
+PO BOX 772349 - (MIA)
+OCALA, FL 34477-2349
+#BWNHHBD
+#05725942030013*
+eturn the portion below with payme
+to Cingular Wireless onl
+Account Number: 05725942-001-0:
+Total Amount Due:
+$179.96
+Amount Paid:
+$
+* Please do not send correspondence wish paymens.
+Please Make Check Payable To:
+Box 3148
+Tampa, FL 33631-3488
+
+
+
+Billing Cycle Date:
+Account Number:
+2 of 2
+02/15/05 - 03/14/0
+General Information
+• Terms: The past due amount is due immediately. Late payment charges of 1.5% may be
+applied to any unpaid balance as of your next billing date. When you send us a
+check as payment, you authorize us to clear your check electronically. Electronic
+payments may clear the same day we receive payment. Returned checks or other
+negotiable instruments may result in the maximum processing charge allowed by law.
+Notations made on checks or accompanying materials will not secure your rights.
+• The 'Recurring Monthly Charges' can be billed in advance or arrears based on
+selected services. Usage and toll charges are billed in arrears. Certain usage
+and toll charges may appear more than one month in arrears. Prorated monthly
+charges may apply for new services or changes to existing services during a
+billing period. These will appear in the Monthly Service Charges sections of the
+bill.
+• Please do not enclose correspondence with your payment for we cannot guarantee
+receipt. Address all correspondence to the following: Cingular Wireless,
+PO BOX 772349 - (MIA). OCALA. FL 34477-2349.
+• Calls to our Customer Service Centers may be monitored to ensure high quality
+service to our customers.
+• Questions on accessibility by persons with disabilities: 1-866-241-6568
+• Cingular Wireless Tax ID # 74-2955068 / Cingular Wireless DUNS # 003548489
+********************************************************************
+Auto Pay Authorization Agreement - For use only with Auto Pay phone enrollment
+If I enroll, I authorize Cingular Wireless to pay my bill monthly by debiting my
+bank account. I can cancel authorization by notifying Cingular at
+www.cingular.com, by calling 1-800-331-0500, or by dialing 611 from my wireless
+phone. If my bank rejects a payment, I may be charged a return fee.
+How To Pay
+Check and savings account payments, debit cards,
+credit cards are accepted.
+Payments made with a representative may be subject to
+Note: There is no fec for choosing any of the following payment channels:
+Pay using your wireless phone for free
+- Dial *PAY (*729), then hit send.
+- Make a one time payment following the instructions provided.
+Pay using any landline phone - Dial 1-800-331-0500
+- Enter your wireless number and billing ZIP Code and follow the prompts
+- Go to www.cingular.com
+Recurring Credit Card Paymen
+- Also sign up to receive your wireless bill online at no additional charge.
+Pay by Mail
+- Mail your remittance stub and a check or money order in the envelope provided.
+- It may take up to 7 - 10 days for the payment to post.
+DST X280-9900 (10/03)
+
+
+-
+Prior Activity
+Previous Balance
+TOTAL PAST DUE BALANCE
+Account Charges
+Credits, Adjustments & Other Charges
+Late Payment Fee
+ACCOUNT CREDITS, ADJUSTMENTS & OTHER CHARGES
+Government Fees and Taxes
+FEDERAL EXCISE TAX
+ACCOUNT GOVERNMENT FEES AND TAXES
+Wireless Line Summary For:
+User Name:
+Monthly Service Charges
+Rate Plan
+Current Rate Plan:
+/RGNP 600 UMM 5KNW
+Includes:
+- /WRLSS INTRNT XPRS PAY PER USE
+- BASIC VOICEMAIL-N/C
+- CALL FORWARDING N/C
+- CALL WAITING N/C
+- CALLER ID N/C
+- DATA VOLUME DETAILED BILLING
+- DETAILED BILLING N/C
+- MULTIMEDIA PAY PER USE
+- TEXT MSG PAY PER USE
+- THREE PARTY CALL N/C
+Optional Services
+15000 NIGHT/WKND MINS CTH
+1600 ANYTIME MINS
+/REGION GSM
+JUNLIMITED EXPANDED M2M-N/C
+/UNLIMITED M2M EXPND MINS
+CINGULAR NATIONWIDE TOLL FREE
+FL ROAM WITH HOME
+NATIONWIDE $.79/MIN ROAMING
+ROAMER ADMIN FEE EXCLUSION
+WIRELESS PHONE INS. & SVC FEE
+WIRELESS PHONE INS. & SVC FEE
+TOTAL MONTHLY SERVICE CHARGES
+Usage Charges
+(See Usage Charge Details)
+illing Cycle Date
+ccount Numbe
+3 of 20
+02/15/05 - 03/14/05
+05725942-001-03
+96.22
+$96.22
+05725942-001-03
+1.44
+$1.44
+0.01
+$0.04
+Period
+03/15-04/14
+Prorater
+Charge
+Monthly
+Charge
+39.99
+Total
+Charge
+39.99
+03/15-04/14
+03/15-04/14
+03/15-04/14
+03/15-04/14
+03/15-04/14
+03/15-04/14
+03/15-04/14
+03/15-04/14
+03/15-04/14
+02/28-03/14
+03/15-04/14
+2.00
+3.99
+3.99
+$45.98
+
+
+*cingular
+Wireless Line Summary For (Continued):
+User Name:
+TOTAL USAGE CHARGES
+Credits, Adjustments & Other Charges
+DirectBill Charges - 4 (To view detail go to www.cingular.com/db)
+FED UNIVERSAL SVC CHARGE
+911 MONTHLY
+REGULATORY COST RECOVERY FEE
+TOTAL CREDITS, ADJUSTMENTS & OTHER CHARGES
+Government Fees and Taxes
+FEDERAL EXCISE TAX
+LOCAL COMMUNICATION TA
+TOTAL GOVERNMENT FEES and TAXES
+TOTAL AMOUNT DUE
+Usage Charge Details
+User Name:
+Summary of
+Usage Charges
+Peak
+UNLIMITED EXPANDED M2M-N
+15000 NIGHT/WKND MINS CTH
+Long Distance
+Domestic
+Roaming
+Subtotal
+Summary of
+Wireless Data
+Text Messaging
+- CINGULAR MOBILE TO MOBILE Outgoing
+- CINGULAR MOBILE TO MOBILE Incoming
+- OTHER MOBILE TO MOBILE Outgoing
+- OTHER MOBILE TO MOBILE Incoming
+/WRLSS INTRNT XPRS PAY PER USE
+Subtotal
+DST X280-9900 (10/03)
+Minutes
+Included
+In Plan
+600
+5000
+Msg/KB
+Included
+In Plan
+Billing Cycle Date
+Iccount Number
+421305 - 031405
+$11.18
+12.96
+1.28
+0.50
+0.56
+1-30
+3.56
+$15.30
+$9.80
+$82.26
+Minutes Billed
+Used
+Minutes
+Billed
+Rate
+338
+246
+888
+126
+See Call Details
+See Call Details
+Msg/KB Billed
+Used
+Msg/KB
+Billed
+Rate
+1
+168
+4
+168
+Total
+Charge
+$0.00
+Total
+Charge
+1.40
+1.60
+1.68
+$11.18
+
+
+ling Cycle Dat
+count Numbe
+5 of 20
+02/15/05 - 02/14/05
+Usage Charge Details (Continued)
+User Name:
+TOTAL USAGE CHARGES
+$11.18
+Call Detail
+User Name:
+Call Location(CL): AU=Aucilla, BR=Bristol, BU=Bushnell, CH=Chiefland, CL=Clewiston, DB=Daytona, FL=Flagler,
+FK=Florida Keys. FM=Fort Myers, FP=Fort Pierce, FW=Fort Walton, GV=Gainesville, JX=Jacksonville, L.C=Lake City.
+LB=Leesburg, MI=Miami, MA=Marianna, MB=Melbourne, MX=Mexico Beach, OC=Ocala, OR=Orlando, PI.=Palatka, PC=Panama City,
+PS=Pensacola, PJ=Port St Joe, SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa, VB=Vero Beach, NA=Naples,
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM 5KNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls:
+I=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Home:
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Item
+Day
+Mon
+CL
+Called
+Pd
+Rate Fea- Airtime
+ture Charge
+IRM
+R
+Tue
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+26
+27
+28
+29
+30
+31
+12
+33
+34
+35
+36
+Wed
+Date
+02/14
+02/14
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/16
+02/16
+02/16
+02/16
+Time
+03:02PM
+03:13PM
+12: 40PM
+12:48PM
+02: 57PM
+02: 58PM
+02:59PM
+03:00PM
+03:10PM
+03:30PM
+03:48PM
+04:18PM
+05: :03PM
+05:47PM
+05:49PM
+05: 56PM
+06: 02PM
+06: 03PM
+06: 53PM
+06:54PM
+07:10PM
+07:42PM
+07:47PM
+07: 50PM
+08: 26PM
+08:27PM
+08:29PM
+08: 29PM
+08:29PM
+08:36PM
+08:44PM
+10:32PM
+12:48AM
+12: 52AM
+12:54AM
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+MIAMI,
+W PALM FL
+INCOMI CL
+MIAMI,
+MIAMI,
+MIAMI,
+INCOMI CL
+MIAMI,
+INCOMI
+CL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+" PALM FL
+W PALM FL
+INCOMI CL
+MIAMI,
+MIAMI,
+W PALM FL
+INCOMI
+INCOMI
+CL
+PALM
+FL
+PALM
+FL
+PALM
+FL
+INCOMI
+CL
+DELRAY
+FL
+DELRAY FL
+DELRAY
+FL
+DELRAY
+FL
+W PALM
+FL
+W PALM
+EL
+INCOMI
+CL
+" PALM FL
+W PALM FL
+W PALM FI
+INCOMI
+CL
+Rate
+Min
+Code
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+RSD1
+RSD1
+RSD1
+P
+16
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+RSD1
+RSD1
+RSD1
+P
+RSD1
+RSD1
+P
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+LD
+DA
+IM
+R
+R
+R
+IR
+RM
+M
+IN
+M
+M
+I
+IM
+M
+CH
+IW
+Total
+Charge
+
+
+Billing Cycle Date:
+Account Number:
+6 of 20
+02/15/05 - 03/14105
+Call Detail (Continued)
+User Name:
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+S-Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+37
+02/16
+01: 02AM
+38
+02/16
+01: 22AM
+39
+02/16
+01:37AM
+40
+02/16
+03:47AM
+41
+02/16
+04: 02AM
+42
+02/16
+10:35AM
+43
+02/16
+11:12AM
+02/16
+11:18AM
+02/16
+02:48PM
+46
+02/16
+03:06PM
+47
+02/16
+03:26PM
+48
+02/16
+03:27PM
+49
+02/16
+03:28PM
+50
+02/16
+03:42PM
+51
+02/16
+03: 47PM
+52
+02/16
+04: :12PM
+53
+02/16
+04:36PM
+54
+02/16
+05: :33PM
+55
+02/16
+06:23PM
+56
+02/16
+07:14PM
+57
+02/16
+07:14PM
+58
+02/16
+07:35PM
+59
+02/16
+07:41PM
+60
+02/16
+07:48PM
+61
+02/16
+08:17PM
+62
+02/16
+10: 59PM
+63
+02/16 11:10PM
+64
+02/16
+11:12PM
+65
+02/16
+11:19PM
+66
+02/16
+11:27PM
+67
+Thu
+02/17
+12: 07AM
+68
+02/17
+12: 18AM
+69
+02/17
+12: 20AM
+70
+02/17
+12:29AM
+71
+02/17
+12:34AM
+72
+02/17
+12:44AM
+73
+02/17
+07: 26AM
+74
+02/17
+03: 50PM
+75
+02/17
+05:13PM
+76
+02/17
+05:14PM
+77
+02/17
+05:19PM
+78
+02/17
+05:21PM
+79
+02/17
+05: 23PM
+DST X280-9900 (10/03)
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+INCOMI CL
+W PALM FL
+MIAMI,
+MIAMI,
+W PALM FI
+W PALM FL
+W PALM EL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM EL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FI
+W PALM
+FL
+W PALM
+FL
+INCOMI
+CL
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+Min Cade Rade Fire Altime
+ture
+RSD1
+RSD1
+IN
+IN
+RSD1
+IN
+RSD1
+RSD1
+IN
+16
+RSD1
+RSD1
+RSD1
+R
+R
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+4
+10
+RSD1
+RSD1
+RSD1
+IM
+I
+IN
+IN
+IN
+IN
+ICH
+IN
+RSD1
+41
+RSD1
+IW
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+10
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+RSD1
+Total
+Charg
+. 00
+.00
+.00
+
+
+Billing Cycle Date:
+Account Number:
+7 of 20
+02/15/05 - 03/14/05
+Call Detail (Continued)
+User Name
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa, VB=Vero Beach, NA=Naples,
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting: D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+I=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Item Day Date Time
+CL
+Called
+Call To
+Min Code
+ture
+80
+02/17
+06: 02PM
+MI
+INCOMI CL
+RSD1
+81
+02/17
+06: 08PM
+MI
+W PALM FL
+RSD1
+82
+02/17
+06:09PM
+MI
+INCOMI CL
+RSD1
+83
+02/17
+06: 12PM
+MI
+INCOMI CL
+RSD1
+84
+02/17
+07 :11PM
+INCOMI
+CL
+RSD1
+IR
+85
+02/17
+07:12PM
+MIAMI
+RSD1
+86
+02/17
+07:30PM
+MI
+INCOMI
+CL
+RSD1
+87
+02/17
+08: 09PM
+MI
+W PALM FL
+RSD1
+88
+02/17
+08:12PM
+MI
+INCOMI
+CL
+RSD1
+89
+02/17
+08:15PM
+MI
+W PALM FL
+RSD1
+M
+90
+02/17
+08:16PM
+91
+02/17
+09: 04PM
+MI
+W PALM FL
+RSD1
+92
+MI
+INCOMI CL
+RSD1
+IN
+Fri
+02/18
+01:01AM
+MI
+W PALM FL
+RSD1
+93
+02/1฿
+01: 07AM
+MI
+W PALM FL
+RSD1
+94
+02/18
+10:13AM
+MIAMI,
+RSD1
+95
+02/18
+02: 50PM
+MI
+NEW YO NY
+RSD1
+96
+02/18
+03:41PM
+MI
+QUEENS NY
+RSD1
+97
+02/18
+04: 03PM
+MI
+QUEENS NY
+RSD1
+98
+02/18
+05:08PM
+MI
+QUEENS NY
+RSD1
+99
+02/18
+05:38PM
+MI
+QUEENS NY
+RSD1
+100
+02/18
+05: 50PM
+MI
+INCOMI
+CL
+RSD1
+101
+02/18
+05: 51PM
+MI
+INCOMI
+CL
+RSD1
+102
+02/18
+05: 53PM
+MI
+NORTH
+FL
+RSD1
+103
+02/18
+06:17PM
+MI
+NEW YO NY
+RSD1
+104
+02/18
+06:25PM
+MI
+NEW YO NY
+RSD1
+105
+02/18
+06: 40PM
+106
+02/18
+06:45PM
+MI
+NEW YO NY
+RSD1
+107
+Mon
+02/28
+05:29PM
+MI
+NEW YO NY
+RSD1
+MI
+W PALM FL
+RSD1
+108
+02/28
+05: 39PM
+MI
+INCOMI CL
+22
+RSD1
+109
+02/28
+06:15PM
+MI
+W PALM FI
+RSD1
+110
+02/28
+08:13PM
+MIAMI,
+RSD1
+111
+02/28
+08:14PM
+MIAMI,
+RSD1
+R
+112
+02/28
+08:17PM
+MIAMI,
+RSD1
+113
+02/28
+08:25PM
+MI
+W PALM FI
+RSD1
+114
+Tue
+03/01
+06:15AM
+MI
+W PALM FL
+RSD1
+115
+03/01
+06:24AM
+MI
+W PALM FL
+RSD1
+116
+03/01
+06: :35AM
+MI
+W PALM FL
+RSD1
+117
+03/01
+06: 35AM
+MI
+W PALM FL
+RSD1
+118
+03/01
+06: 39AM
+119
+03/01
+MI
+W PALM FL
+RSD1
+07: 04AM
+120
+03/01
+MI
+W PALM EL
+RSD1
+07: 06AM
+MI
+W PALN FL
+RSD1
+121
+03/01
+07:19AM
+MI
+W PALM FL
+RSD1
+122
+03/01
+07: 51AM
+MI
+W PALM FL
+RSD1
+P
+bA
+Total
+Charg
+
+
+Billing Cycle Date:
+Account Number:
+8 of 20
+02/15/05 - 03/14/05
+Call Detail (Continued)
+User Name:
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+eature: B=Direct Asst Call Complete: C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Call
+-Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Hon
+S=Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Balladi
+Item Day Date
+Time
+123
+03/01
+07:51AM
+124
+03/01
+08: 03AM
+125
+03/01
+08:11AM
+126
+03/01
+08:11AM
+127
+03/01
+08:17AM
+128
+03/01
+08: 23AM
+129
+03/01
+10:10AM
+130
+03/01
+10: 20AM
+131
+03/01
+10: 21AM
+132
+03/01
+12:01PM
+133
+03/01
+12:15PM
+134
+03/01
+12:17PM
+135
+03/01
+12:19PM
+136
+03/01
+12:20PM
+137
+03/01
+12: 41PM
+138
+03/01
+12: 45PM
+139
+03/01
+12:47PM
+140
+03/01
+12:49PM
+141
+03/01
+12:51PM
+142
+03/01
+12: 51PM
+143
+03/01
+12:58PM
+144
+03/01
+12: 58PM
+145
+03/01
+01:05PM
+146
+03/01
+01:13PM
+147
+03/01
+03:00PM
+148
+03/01
+03:14PM
+149
+03/01
+03:15PM
+150
+03/01
+03:23PM
+151
+03/01
+03:27PM
+152
+03/01
+03:29PM
+153
+03/01
+03:29PM
+154
+03/01
+03:31PM
+155
+03/01
+03:39PM
+156
+03/01
+03:50PM
+157
+03/01
+03:55PM
+158
+03/01
+04: 00PM
+03/01
+04:01PM
+160
+161
+162
+163
+164
+165
+03/01
+04:02PM
+03/01
+04: 35PM
+03/01
+04:35PM
+03/01
+04: 36PM
+03/01
+04:37PM
+03/01
+05: 28PM
+DST X280-9900 (10/03)
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+INCOMI CL
+MIAMI,
+MIAMI,
+MIAMI,
+MIAMI,
+MIAMI,
+W PALM FL
+MIAMI,
+MIAMI,
+MIAMI,
+MIAMI,
+INCOMI CL
+INCOMI CL
+MIAMI,
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+MIAMI,
+INCOMI CL
+W PALM FI
+W PALM FL
+W PALM
+BOYTON FI
+W PALM EL
+W PALM FL
+W PALM FL
+W PALM FI
+INCOMI CL
+PERRIN FL
+BOYTON
+FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+W PALM FI
+W PALM FL
+INCOMI CL
+W PALM FI
+Min Code Rade Fure Alrige
+ture
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RM
+RM
+RM
+RSD1
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IRM
+IRM
+R
+M
+M
+M
+M
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+IR
+RSD1
+RSD1
+IR
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+P
+M
+RSD1
+RSD1
+P
+M
+RSD1
+11
+RSD1
+P
+RSD1
+I
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+M
+M
+IM
+M
+Total
+Charg
+
+
+Pring Cycle Date:
+Account Number:
+9 of 20
+02/15/05 - 03/14/05
+Call Detail (Continued)
+User Name:
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+eature: B=Direct Asst Call Complete: C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Call
+-Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Hom
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+ture
+Item Day Date
+166
+03/01
+167
+03/01
+168
+03/01
+169
+03/01
+170
+03/01
+171
+03/01
+172
+03/01
+173
+03/01
+174
+03/01
+175
+03/01
+176
+03/01
+177
+03/01
+178
+03/01
+179
+03/01
+180
+03/01
+181
+03/01
+182
+03/01
+183
+03/01
+184
+03/01
+185
+03/01
+196
+03/01
+187
+03/01
+188
+03/01
+189
+03/01
+190
+03/01
+191
+Wed
+03/02
+192
+03/02
+193
+03/02
+194
+03/02
+195
+03/02
+196
+03/02
+197
+03/02
+198
+03/02
+199
+03/02
+200
+03/02
+201
+03/02
+202
+03/02
+203
+03/02
+204
+03/02
+205
+03/02
+206
+03/02
+207
+03/02
+208
+03/02
+Time
+06: 00PM
+06: 02PM
+06:17PM
+06:29PM
+06: 31PM
+06:36PM
+06:37PM
+06:41PM
+06: 44PM
+06:44PM
+06: 45PM
+06: :47PM
+06: 49PM
+06:57PM
+07:03PM
+07:19PM
+07:20PM
+07:23PM
+08: 33PM
+08: 51PM
+09:05PM
+09:11PM
+09:18PM
+11:01PM
+11: 03PM
+06:20AM
+11: 32AM
+11:32AM
+12: 29PM
+12:48PM
+03:03PM
+03: 06PM
+03:34PM
+04: 05PM
+04:22PM
+06: 03PM
+07:44PM
+07:46PM
+07: 47PM
+07:57PM
+08:04PM
+08:06PM
+08:22PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM EL
+W PALM FL
+W PALM FL
+INCOMI CL
+PERRIN FL
+W PALM FL
+DELRAY
+FL
+INCOMI
+CL
+W PALM FI
+W PALM FL
+W PALM EL
+W PALM FL
+INCOMI CL
+INCOMI CL
+INCOMI CI
+INCOMI CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI CL
+W PALM FL
+DELRAY FI
+MIAMI.
+MIAMI,
+INCOMI CL
+MIAMI,
+INCOMI CL
+W PALM FI
+INCOMI
+CL
+INCOMI
+CL
+W PALM
+EL
+PERRIN FI
+W PALM FL
+W PALM FI
+BOYTON FL
+INCOMI CL
+W PALM FL
+Min Code
+2
+RSD1
+P
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+10
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+RSD1
+RSD1
+RSD1
+RSD1
+P
+P
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+RSD1
+M
+M
+M
+IM
+IM
+M
+M
+M
+IR
+M
+M
+IN
+ICH
+IW
+IN
+M
+R
+IRM
+M
+M
+IN
+Tota
+Charg
+. 00
+.00
+1.00
+
+
+Billing Cycle Date:
+Account Number:
+10 of 20
+02/15/05 - 03/14/05
+Call Detail (Continued)
+User Name
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Encoming Cal Kara Cal MMe To Mobile Dicent: SPoil Alces Service: -Can Within Mobile Calls:
+S=Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+209
+03/02
+09:10PM
+210
+Thu
+03/03
+06: 01AM
+211
+03/03
+06: 49AM
+03/03
+10: :22AM
+213
+214
+215
+216
+217
+218
+219
+220
+221
+222
+223
+224
+225
+226
+227
+228
+229
+230
+231
+232
+233
+234
+235
+236
+237
+238
+239
+240
+241
+242
+243
+244
+03/03
+10: 30AM
+03/03
+11:50AM
+03/03
+11: 55AM
+03/03
+02:11PM
+03/03
+03:17PM
+03/03
+03:29PM
+03/03
+04:47PM
+03/03
+07:17PM
+03/03
+07:18PM
+03/03
+09:40PM
+03/03
+09: 42PM
+03/03
+09:44PM
+03/03
+09:53PM
+03/03
+09: 53PM
+03/03
+09: 54PM
+03/03
+10: 00PM
+03/03
+10:07PM
+03/03
+10:12PM
+03/03
+10:14PM
+03/03
+11:13PM
+03/03
+11: 38PM
+03/03
+11: 43PM
+03/03
+11:49PM
+Fri
+03/04
+04:49AM
+03/04
+05:19AM
+03/04
+06:13AM
+03/04
+06:14AM
+03/04
+06: 20AM
+03/04
+06: 24AM
+03/04
+06: 26AM
+03/04
+06: 56AM
+03/04
+12:39PM
+293
+246
+247
+248
+249
+250
+251
+03/04
+02:43PM
+03/04
+02: 43PM
+03/04
+03: 01PM
+03/04
+03:04PM
+03/04
+03: 06PM
+03/04
+03:07PM
+03/04
+03: 08PM
+DST X280-9900 (10/03)
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+INCOMI CL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+PALM FL
+PALM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+MIAMI,
+INCOMI CL
+MIAMI,
+W PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM FI
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+INCOMI CL
+MIAMI,
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FI
+INCOMI
+CL
+W PALM FL
+DELRAY EL
+W PALM FL
+MIAMI,
+MIAMI,
+MIAMI,
+MIAMI,
+INCOMI CL
+Min Code Rade Fure Alrie
+ture
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+IN
+M
+13
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+17
+RSD1
+RSD1
+I
+IC
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RH
+IRW
+RW
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+25
+RSD1
+RSD1
+IW
+IN
+1
+RSD1
+RSD1
+30
+RSD1
+RSD1
+W
+IN
+IN
+RSD1
+RSD1
+IRN
+RSD1
+RSD1
+RSD1
+RSD1
+IRW
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+R
+IR
+bA
+Total
+Charg
+.00
+. 00
+.00
+.00
+.00
+
+
+*cingular
+Billing Cycle Date:
+Account Number:
+11 of 20
+02/15/05 - 03/14/05
+Call Detail (Continued)
+User Name:
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting: D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+I=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount; P=Priority Access Service, R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+CL
+Called
+Item Day Date Time
+252
+253
+254
+255
+256
+257
+258
+259
+260
+261
+262
+263
+264
+265
+266
+267
+268
+269
+270
+271
+272
+273
+274
+275
+276
+277
+278
+279
+280
+281
+282
+283
+284
+285
+286
+287
+298
+289
+290
+291
+292
+293
+294
+03/04
+03:09PM
+03/04
+03:11PM
+03/04
+03:20PM
+03/04
+03: :32PM
+03/04
+03: 41PM
+03/04
+04:09PM
+03/04
+04:09PM
+03/04
+04:15PM
+03/04
+04:30PM
+03/04
+04:40PM
+03/04
+04: 53PM
+03/04
+04:54PM
+03/04
+05: 05PM
+03/04
+05:16PM
+03/04
+05: 23PM
+03/04
+05: 41PM
+03/04
+09:58PM
+03/04
+11: 04PM
+03/04
+11:16PM
+03/04
+11:20PM
+03/04
+11:24PM
+03/04
+11:34PM
+03/04
+11: 40PM
+03/04
+11:47PM
+03/04
+11:48PM
+03/04
+11: 49PM
+Sat
+03/05
+12: 03AM
+03/05
+12:25AM
+03/05
+12: 35AM
+03/05
+01:31PM
+03/05
+01:33PM
+03/05
+01:47PM
+03/05
+01:48PM
+03/05
+01: :52PM
+03/05
+02: 01PM
+03/05
+02:13PM
+03/05
+02:14PM
+03/05
+02:14PM
+03/05
+02:16PM
+03/05
+02:19PM
+03/05
+02:28PM
+03/05
+02:54PM
+03/05
+03: 06PM
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+MIAMI,
+MIAMI,
+INCOMI CL
+W PALM FL
+INCOMI
+CL
+" PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+INCOMI CL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM EL
+W PALM FL
+INCOMI CL
+INCOMI CL
+INCOMI
+CL
+W PALM FL
+W PALM
+FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM
+FL
+N PALM EL
+W PALM EL
+W PALM FI
+W PALM FL
+W PALM FI
+W PALM FI
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+INCOMI CL
+N PALM FL
+Min Code Rade Fre Arie
+ture
+RSD1
+RSD1
+RSD1
+IRM
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IM
+IM
+IRM
+M
+RSD1
+R8D1
+RSD1
+RSD1
+M
+IN
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+IN
+IW
+IRW
+W
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+W
+IRW
+RSD1
+RSD1
+RSD1
+N
+RSD1
+RSD1
+RSD1
+RSD1
+N
+N
+N
+RSD1
+IW
+RSD1
+RSD1
+RSD1
+RSD1
+N
+N
+RSD1
+RSD1
+RSD1
+RSD1
+Total
+Charge
+.00
+1.00
+.00
+.00
+
+
+Billing Cycle Date:
+Account Number
+12 of 20
+02/15/05 - 03/14/05
+Call Detail (Continued)
+User Name
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+eature: B=Direct Asst Call Complete: C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Call
+-Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Hon
+S=Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+295
+03/05
+04: 43PM
+296
+03/05
+04:47PM
+297
+03/05
+05:17PM
+298
+03/05
+05: 31PM
+299
+03/05
+05: 32PM
+300
+03/05
+09:39PM
+301
+Sun
+03/06
+12: 13AM
+302
+03/06
+12:16AM
+303
+03/06
+12: 30AM
+304
+03/06
+12:35AM
+305
+03/06
+01: 13AM
+306
+03/06
+01: 21AM
+307
+03/06
+01: 23AM
+308
+03/06
+01: 23AM
+309
+03/06
+01: 36AM
+310
+03/06
+01: 55AM
+311
+03/06
+02: 49AM
+312
+03/06
+03: 05AM
+313
+03/06
+03: 42AM
+314
+03/06
+03: 43AM
+315
+03/06
+09:18AM
+316
+03/06
+09: 25AM
+317
+03/06
+10: 04AM
+318
+03/06
+10: 06AM
+319
+03/06
+10: 31AM
+320
+03/06
+10: 32AM
+321
+03/06
+10:56AM
+322
+03/06
+11:10AM
+323
+03/06
+11: 27AM
+324
+03/06
+12: 02PM
+325
+03/06
+12:22PM
+326
+03/06
+12:29PM
+327
+03/06
+12: 37PM
+328
+03/06
+12:49PM
+329
+03/06
+12: 50PM
+330
+03/06
+12: 53PM
+331
+03/06
+01:05PM
+332
+03/06
+01:11PM
+333
+03/06
+01:16PM
+334
+03/06
+01:22PM
+335
+03/06
+01:27PM
+336
+03/06
+01:31PM
+337
+03/06
+01:31PM
+DST X280-9900 (10/03)
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+PERRIN FL
+W PALM FL
+PERRIN FL
+INCOMI CL
+W PALM FL
+MIAMI,
+W PALM FL
+PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PALM EL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+" PALM FL
+INCOMI
+CL
+W PALM
+FL
+PALM
+FL
+W
+PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM FI
+W PALM FL
+INCOMI
+CL
+W PALM EL
+INCOMI
+CL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM
+FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+INCOMI CL
+INCOMI CL
+Min Code Rade Fure Alrige
+ture
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+20
+10
+RSD1
+RSD1
+ICW
+RSD1
+RSD1
+RSD1
+RSD1
+CH
+IN
+IN
+RSD1
+RSD1
+13
+RSD1
+RSD1
+27
+RSD1
+IW
+RSD1
+RSD1
+17
+RSD1
+RSD1
+CH
+IW
+RSD1
+N
+RSD1
+11
+R8D1
+RSD1
+CK
+IN
+RSD1
+RSD1
+15
+RSD1
+RSD1
+IW
+CH
+IN
+RSD1
+RSD1
+RSD1
+12
+RSD1
+RSD1
+IW
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+zzzz
+ICH
+IN
+Total
+Charge
+.00
+1.00
+.00
+
+
+Billing Cycle Date:
+Account Number:
+13 of 20
+02/15/05. 02/14/05
+Call Detail (Continued)
+User Name
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa, VB=Vero Beach, NA=Naples,
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+338
+03/06
+01:34PM
+339
+03/06
+01:42PM
+340
+03/06
+01:48PM
+341
+03/06
+342
+03/06
+343
+03/06
+344
+03/06
+345
+03/06
+346
+03/06
+347
+03/06
+348
+03/06
+349
+03/06
+350
+03/06
+351
+03/06
+352
+03/06
+353
+03/06
+354
+03/06
+355
+03/06
+356
+03/06
+357
+03/06
+358
+03/06
+359
+03/06
+360
+03/06
+361
+03/06
+362
+03/06
+363
+03/06
+364
+03/06
+365
+03/06
+366
+03/06
+367
+03/06
+368
+03/06
+369
+03/06
+370
+03/06
+371
+03/06
+372
+03/06
+373
+03/06
+374
+03/06
+375
+03/06
+376
+03/06
+377
+03/06
+378
+03/06
+379
+03/06
+380
+03/06
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+EM
+FM
+FM
+EN
+EM
+FM
+FM
+FM
+FM
+FM
+EM
+EM
+EM
+Call To
+W PALM FL
+INCOMI CL
+" PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+MIAMI,
+MIAMI,
+MIAMI,
+MIAMI,
+MIAMI,
+MIAMI,
+MIAMI,
+MIAMI,
+MIAMI,
+W PALM FL
+# PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM
+FL
+MIAMI,
+MIAMI,
+MIAMI,
+INCOMI CL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FI
+MIAMI,
+MIAMI,
+INCOMI CL
+W PALM FL
+INCOMI CL
+MIAMI,
+MIAMI,
+MIAMI,
+INCOMI CL
+Min Rade Rate Fure Alaine
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IN
+IRM
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+13
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RK
+RW
+20
+RSD1
+RSD1
+RSD1
+IRW
+IRW
+RSD1
+RSD1
+RSD1
+7
+10
+RSD1
+RSD1
+IRN
+RSD1
+N
+RSD1
+RSD1
+N
+RSD1
+RSD1
+RSD1
+13
+RSD1
+RSD1
+N
+N
+RSD1
+RSD1
+IRN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+N
+IRW
+bA
+Total
+Charg
+
+
+Billing Cycle Date:
+Account Number:
+190120-021405
+Call Detail (Continued)
+User Name
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Encoming Cal Kara CalM Me To Mobile Dicent: SProin Alces Service: -Can Within Mobile Calls:
+S=Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+CL
+Called
+Item Day Date
+Time
+381
+03/06
+05: 55PM
+382
+03/06
+06: 07PM
+383
+03/06
+06:30PM
+384
+03/06
+06: 36PM
+385
+03/06
+06: 39PM
+386
+03/06
+06: 45PM
+387
+03/06
+06: 49PM
+388
+03/06
+07: 00PM
+389
+03/06
+07:14PM
+390
+03/06
+07:34PM
+391
+03/06
+07:39PM
+392
+03/06
+07: 48PM
+393
+03/06
+08:35PM
+394
+03/06
+08:36PM
+395
+03/06
+09:13PM
+396
+03/06
+09: 27PM
+397
+03/06
+09:39PM
+398
+Mon
+03/07
+07: 36AM
+399
+03/07
+10:19AM
+400
+03/07
+12:34PM
+401
+03/07
+12:39PM
+402
+03/07
+12:44PM
+403
+03/07
+12: 45PM
+404
+03/07
+12:52PM
+405
+03/07
+12:53PM
+406
+03/07
+01:39PM
+407
+03/07
+03:22PM
+408
+03/07
+04:23PM
+409
+03/07
+04: 32PM
+410
+03/07
+10:17PM
+411
+03/07
+10:27PM
+412
+03/07
+11:10PM
+413
+Tue
+03/08
+06: 25AM
+414
+03/08
+06: 34AM
+415
+03/08
+06:39AM
+416
+03/08
+06:48AM
+417
+03/08
+06:53AM
+418
+03/08
+07: 00AM
+419
+03/08
+03: 07PM
+420
+03/08
+03: 11PM
+421
+03/08
+03:22PM
+422
+03/08
+06:11PM
+423
+03/08
+06: 25PM
+DST X280-9900 (10/03)
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+MIAMI,
+MIAMI,
+MIAMI,
+W PALM FL
+INCOMI
+CL
+W PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FI
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FI
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+MIAMI,
+MIAMI,
+MIAMI
+INCOMI
+CL
+MIAMI,
+INCOMI
+CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM
+FL
+INCOMI
+CI
+W PALM FI
+W PALM FL
+W PALM FL
+W PALM FL
+" PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+" PALM FI
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+21
+10
+20
+10
+Min Cade Rade Fire Alrig
+ture
+RSD1
+N
+RSD1
+RSD1
+RSD1
+RSD1
+IW
+RSD1
+RSD1
+RSD1
+IN
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+N
+IN
+RSD1
+RSD1
+RSD1
+N
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+IR
+RSD1
+RSD1
+RSD1
+RSD1
+IRM
+IR
+I
+RSD1
+RSD1
+RSD1
+M
+IN
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+I
+IN
+RSD1
+RSD1
+M
+bA
+Total
+Charg
+.00
+.00
+.00
+1.00
+
+
+Billing Cycle Date:
+Account Number:
+15 of 20
+02/15/05 - 03/14/05
+Call Detail (Continued)
+User Name:
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+I=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Hone
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date Time
+424
+425
+426
+427
+428
+429
+430
+431
+432
+433
+434
+435
+436
+437
+438
+439
+440
+441
+442
+443
+444
+445
+446
+447
+448
+449
+450
+451
+452
+453
+454
+455
+456
+457
+458
+459
+460
+461
+462
+463
+464
+465
+466
+03/08
+06:28PM
+03/08
+06:28PM
+03/08
+06:56PM
+03/08
+07: 02PM
+03/08
+07:15PM
+03/08
+07:23PM
+03/08
+07:49PM
+03/08
+10:24PM
+03/08
+10:44PM
+03/08
+11:24PM
+Wed
+03/09
+03:22PM
+03/09
+03: :45PM
+03/09
+04:26PM
+03/09
+08:21PM
+03/09
+08: :32PM
+03/09
+08:41PM
+03/09
+08:45PM
+03/09
+08: 46PM
+03/09
+09:49PM
+Thu
+03/10
+09: 23AM
+03/10
+09:34AM
+03/10
+10: 13AM
+03/10
+03: 02PM
+03/10
+03:14PM
+03/10
+03:26PM
+03/10
+03:27PM
+03/10
+04:25PM
+03/10
+10:05PM
+03/10
+10:07PM
+03/10
+10:23PM
+03/10
+10:31PM
+03/10
+11: 05PM
+03/10
+11:08PM
+Fri
+03/11
+06: 38AM
+03/11
+06:40AM
+03/11
+06:41AM
+03/11
+03:03PM
+03/11
+03:05PM
+03/11
+03: 07PM
+03/11
+03:10PM
+03/11
+03:20PN
+03/11
+04:12PM
+03/11
+05: 40PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM EL
+W PALM FL
+INCOMI CL
+BOYTON FL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+INCOMI CL
+W PALM EL
+W PALM FL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PALM FL
+PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+DELRAY
+FL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM EL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FI
+W PALM
+FL
+INCOMI
+CL
+W PALM FL
+DELRAY FL
+W PALM FL
+W PALM EL
+W PALM FL
+W PALM FL
+DELRAY FL
+Min Rade Rate Fire Alaine
+ture
+RSD1
+M
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+IN
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+M
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+P
+RSD1
+RSD1
+M
+IN
+IN
+RSD1
+34
+RSD1
+ICH
+RSD1
+13
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+M
+RSD1
+RSD1
+RSD1
+RSD1
+P
+RSD1
+bA
+Total
+Charge
+. 00
+1.00
+.00
+.00
+
+
+Billing Cycle Date:
+Account Number:
+16 of 21
+02/15/05 - 03/14/0
+Call Detail (Continued)
+User Name:
+L.K=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Encoming Cal aFa CalM Me To Mobile Dicent: SProin Access Service: -Can Minion Mobile Calls:
+S=Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Called
+Item Day Date
+Time
+467
+Bat
+03/12
+04:39PM
+468
+03/12
+04: 43PM
+469
+Sun
+03/13
+01:54PM
+470
+03/13
+01:57PM
+471
+03/13
+01: 59PM
+472
+03/13
+02: 43PM
+473
+03/13
+09:15PM
+474
+03/13
+09:26PM
+475
+03/13
+10:08PM
+476
+03/13
+10:17PM
+477
+03/13
+10:18PM
+478
+03/13
+11:18PM
+479
+Mon
+03/14
+03:34PM
+480
+03/14
+03:35PM
+481
+03/14
+03: 56PM
+482
+03/14
+04: 07PM
+483
+03/14
+04:18PM
+484
+03/14
+09: 33PM
+485
+03/14
+09:37PM
+486
+03/14
+10: 05PM
+Totals
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Call To
+W PALM FL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+INCOMI
+CL
+INCOMI
+CL
+" PALM
+FL
+INCOMI
+CL
+W PALM FI
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+" PALM FL
+W PALM FL
+Min Rade Rate Fure Alaine
+RSD1
+RSD1
+N
+RSD1
+RSD1
+IN
+IN
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+IN
+RSD1
+RSD1
+12
+RSD1
+N
+R8D1
+W
+RSD1
+20
+RSD1
+RSD1
+M
+RSD1
+P
+RSD1
+IM
+RSD1
+RSD1
+RSD1
+= z
+Roaming Call Detail
+User Name:
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls
+I=Incoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service: R=Roam with Home
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Item Day Date
+Time
+Number
+Rate
+Fea- Airtime
+LD
+Called
+Call To
+Min
+Code
+ture
+Charge
+Charge
+Charges Incurred While Roaming in Tampa, FL -- System ID #85037-A
+Sun 03/06
+02:20PM
+5
+RSD1
+03/06
+02:28PM
+MIAMI,
+1
+RSD1
+03/06
+02: 32PM
+MIAMI,
+1
+R8D1
+4
+5
+6
+03/06
+02: 32PM
+MIAMI,
+RSD1
+03/06
+02:32PM
+MIAMI,
+RED1
+03/06
+02:32PM
+MIAMI,
+13
+RSD1
+03/06
+02: 45PM
+MIAMI,
+4
+RSD1
+03/06
+02: 51PM
+MIAMI,
+1 RSD1
+03/06
+02: 52PM
+MIAMI,
+RSD1
+Charges Incurred While Roaming in FT MYERS, FL - System ID #05547-A
+DST X280-9900 (10/03)
+Total
+Charge
+Intl
+Tax
+Total
+Chargi
+
+
+Billing Cycle Date:
+Account Number:
+17 of 20
+02/15/05 - 03/14/05
+Roaming Call Detail (Continued)
+User Name:
+Rate Code: RSD1=/RGNP 600 UMM 5KNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+ature: B=Duect Asst Call Complete, C=Call WE
+encoring Call K-Far CalM biE To Mobile Discount: Prior Access SerVice: -Gean witHon Mobile Cal
+S=Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Number
+Item Day
+Date
+Time
+10
+03/06 02:57PM
+11
+03/06 03:06PM
+12
+03/06 03:47PM
+Charges Incurred While R
+13
+03/06
+03: 54PM
+14
+03/06
+03:55PM
+15
+03/06
+Charges Incurred
+16
+03/06
+04: 26PM
+17
+03/06
+04: 43PM
+18
+03/06
+04: 49PM
+19
+03/06
+04: 50PM
+20
+03/06
+04: 55PM
+21
+03/06
+05:07PM
+Charges Incurred While R
+22
+03/06 05:21PM
+23
+03/06 05:24PM
+Charges Incurred While R
+24
+03/06 05:32PN
+Charges Incurred While R
+25
+03/06
+05: 42PM
+26
+03/06
+05: 42PM
+27
+03/06
+05: 43PM
+28
+03/06
+05: 55PM
+29
+03/06
+06: 07PM
+30
+03/06
+06:30PM
+Charges Incurred While R
+31
+Mon
+03/07
+12: 45PM
+Totals
+Called
+Call To Min Cade
+Fea- Airtime
+LD
+ture
+Charge
+Charge
+N PALM EL 3 RSD1
+W PALM FL 20 RSD1
+M PAIN FL
+RSD1
+ba, FL - System ID #85037-A
+MIAMI,
+1 RSD1
+MIAMI,
+RSD1
+MIAMI,
+RSD1
+IYERS, FL --System ID #05547-A
+W PALM FL
+RSD1
+W PALM FL
+RSD1
+PALM
+FL
+RSD1
+PALM FL
+R8D1
+W PALM FL
+RSD1
+PALM FL
+RSD1
+pa, FL. --System ID #85037-A
+MIAMI,
+RSD1
+MIAMI,
+2
+RSD1
+IYERS, FL - System ID #05547-A
+N PALM EL
+2
+RSD1
+oa, FL -- System ID #85037-A
+MIAMI
+RSD1
+MIAMI,
+RSD1
+MIAMI,
+RSD1
+MIAMI,
+RSD1
+MIAMI,
+21
+RSD1
+MIAMI,
+RSD1
+ni, FL --System ID #85029-A
+MIAMI
+1 RSD1
+126
+Inti
+Tax
+Total
+Charge
+Wireless Data Datail
+User Name:
+Rate Code: RSD1=/RGNP 600 UMM 5KNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Feature: B=Direct Asst Call Complete; C=Call Waiting; D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Calls:
+I=Incoming Call; K=Fax Call; M=Mobile To Mobile Discount: P=Priority Access Service; R=Roam with Home:
+S=Shared Minutes; T=Three Way Calling: W=Nights and Weekends
+Item
+Day
+Mon
+Tue
+Date
+02/14
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+Time
+08: 58AM
+10: 56AM
+10: 56AM
+10:58AM
+10:58AM
+10: 59AM
+11: 00AM
+11: 01AM
+11: 02AM
+To/From
+Type
+3 OTHER MOBILE
+6 OTHER MOBILE
+6 CINGULAR MOB
+3 CINGULAR MOB
+6 CINGULAR MOB
+3 CINGULAR MOB
+6 CINGULAR MOB
+3 CINGULAR MOB
+3 CINGULAR MOB
+Msg/KB
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+Rate
+Code
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+R.BD1
+RSD1
+RSD1
+RSD1
+Rate Fea- Incoming/ Tota
+Pd
+ture
+utgoing Charg
+Out
+In
+In
+Out
+In
+out
+In
+Out
+Out
+
+
+Billing Cycle Date:
+Account Number:
+18 of 20
+02/15/05 - 03/14/05
+Wireless Data Detail (Continued)
+User Name:
+Rate Code: RSD1=/RGNP 600 UMM SKNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Fincoming Cal, -Fad Cal, MEMbeTo Mobile Discoent: SPrior Ales Service: -Coam within Mobile Calls:
+S=Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Item Day
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+26
+27
+28
+29
+30
+31
+32
+33
+34
+35
+36
+37
+38
+39
+40
+41
+42
+43
+44
+45
+46
+47
+48
+49
+50
+51
+52
+53
+54
+Wed
+Thu
+Fri
+55
+56
+57
+Tue
+58
+Date
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/15
+02/16
+02/17
+02/18
+02/18
+02/18
+03/01
+03/01
+DST X280-9900 (10/03)
+Time
+11: 02AM
+11: 03AM
+11: 04AM
+11: 07AM
+11: 09AM
+11:12AM
+11:13AM
+11:13AM
+11:14AM
+11:16AM
+11:16AM
+11:18AM
+11:18AM
+11: 20AM
+11:21AM
+11:22AM
+11: 26AM
+11: 26AM
+11:27AM
+11:28AM
+11: 28AM
+11:29AM
+11:31AM
+11:31AM
+11: 32AM
+11: 33AM
+11: 33AM
+11: 36AM
+11: 37AM
+11: 38AM
+11:38AM
+11: 44AM
+11:46AM
+11:47AM
+11:48AM
+11:49AM
+11: 49AM
+11:59AM
+01:15PM
+03:09PM
+03:14PM
+03:15PM
+07:57AM
+10:07PM
+10:04AM
+11: 04AM
+03:40PM
+08: 37AM
+08: 39AM
+TolFrom
+Type
+CINGULAR MOB
+CINGULAR MOB
+CINGULAR MOB
+CINGULAR MOB
+CIRCULAR MOB
+CINGULAR
+МОВ
+CINGULAR
+МОв
+CINGULAR
+MOB
+CINGULAR
+Мов
+CINGULAR
+MOB
+CINGULAR
+мОв
+CINGULAR
+МОВ
+CINGULAR MOB
+CINGULAR
+МОВ
+CINGULAR
+МОВ
+CINGULAR
+мов
+CINGULAR
+МОв
+CINGULAR
+МОВ
+CINGULAR
+MOB
+CINGULAR
+Мов
+CINGULAR
+МОВ
+CINGULAR
+МОВ
+CINGULAR
+мов
+CINGULAR
+МОВ
+CINGULAR
+MOB
+CINGULAR
+МОВ
+CINGULAR
+MOB
+CINGULAR
+МОв
+CINGULAR
+МОВ
+CINGULAR
+мов
+CINGULAR
+MOB
+CINGULAR MOB
+CINGULAR MOB
+CINGULAR MOB
+CINGULAR MOB
+CINGULAR
+МОВ
+CINGULAR
+MOB
+CINGULAR
+МОВ
+CINGULAR
+МОВ
+OTHER MOBILE
+CINGULAR MOB
+CINGULAR MOB
+CINGULAR MOB
+OTHER MOBILE
+OTHER MOBILE
+CINGULAR MOB
+CINGULAR MOB
+CINGULAR MOB
+CINGULAR MOB
+Msg/KB
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+Mag
+1
+Mag
+1
+1
+1
+1
+1
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+Mag
+1 Mag
+1 Mag
+1 Mag
+Rate
+Pd
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RBD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RBD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+RSD1
+Fea- Incoming/ Total
+ture
+Outgoing Charge
+In
+Out
+In
+Out
+In
+In
+Out
+Out
+In
+In
+.10
+Out
+In
+8 = 8=
+.10
+In
+Out
+Out
+In
+Out
+In
+Out
+Out
+In
+Out
+In
+Out
+In
+In
+Out
+In
+In
+Out
+Out
+Out
+In
+In
+Out
+Out
+Out
+In
+In
+Out
+.10
+0.
+.10
+
+
+WIRELES5
+Billing Cycle Date:
+Account Number:
+19 of 20
+02/15/05 - 03/14/05
+Wireless Data Detail (Continued)
+User Name:
+Rate Code: RSD1=/RGNP 600 UMM 5KNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+sature: B=Direct Asst Call Complete; C=Call Waiting: D=Data Call; F=Call Forwarding: H=Group Mobile to Mobile Ca
+ncoming Call; K=Fax Call: M=Mobile To Mobile Discount: P=Priority Access Service: R=Roam with Hor
+S=Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Item Day
+59
+60
+61
+62
+63
+64
+65
+66
+67
+68
+69
+70
+71
+72
+73
+Wed
+Fri
+74
+75
+Sat
+76
+77
+Sun
+78
+79
+80
+81
+Mon
+82
+83
+84
+85
+Tue
+86
+87
+88
+89
+90
+91
+92
+93
+94
+95
+Wed
+Fri
+96
+97
+98
+99
+100
+101
+102
+103
+104
+105
+106
+Mon
+Sun
+Wed
+Fri
+Date
+Time
+03/01
+08: 43AM
+03/01
+08: 44AM
+03/01
+03/01
+08: 45AM
+08: 46AM
+03/01
+08: 47AM
+03/01
+09: 00AM
+03/01
+09: 01AM
+03/01
+09:16AM
+03/01
+09: 39AM
+03/01
+09: 40AM
+03/01
+09: 40AM
+03/01
+12:06PM
+03/01
+12:57PM
+03/02
+02: 31PM
+03/04
+01:23PM
+03/04
+03:10PM
+03/05
+07:18PH
+03/05
+09:28PM
+03/06
+02: 48AM
+03/06
+02:54AM
+03/06
+02:59AM
+03/06
+02: 59AM
+03/07
+10:12AM
+03/07
+10:17AM
+03/07
+10: 34AM
+03/07
+10:50AM
+03/08
+01:14AM
+03/08
+01:14AM
+03/08
+01:15AM
+03/08
+01:16AM
+03/08
+01:20AM
+03/08
+01:23AM
+03/08
+01:30AM
+03/08
+01: 33AM
+03/08
+01:44AM
+03/09
+02:26PM
+03/11
+03:33PМ
+SubtotalondIsg's
+02/07
+02:42PM
+02/13
+09:16PM
+02/13
+09:40PM
+02/16
+03:35PM
+02/18
+02:07PM
+02/18
+02:12PM
+02/18
+02:55PM
+02/18
+02:59PM
+02/18
+03:55PM
+02/18
+03:55PM
+02/18
+05: 00PM
+To/From
+Type
+CINGULAR MOB
+CINGULAR MOB
+CINGULAR MOB
+CINGULAR MOB
+CINGULAR MOB
+CINGULAR
+МОВ
+CINGULAR
+МОв
+CINGULAR
+MOB
+CINGULAR
+Мов
+CINGULAR
+MOB
+CINGULAR
+мОв
+CINGULAR
+МОв
+CINGULAR MOB
+CINGULAR
+MOB
+CINGULAR
+МОВ
+CINGULAR
+мов
+CINGULAR
+CINGULAR
+МОв
+CINGULAR
+MOB
+CINGULAR
+Мов
+CINGULAR
+МОВ
+CINGULAR
+MOB
+CINGULAR
+мов
+CINGULAR
+МОВ
+CINGULAR
+MOB
+CINGULAR
+МОВ
+CINGULAR
+МОВ
+CINGULAR
+МОв
+CINGULAR
+МОВ
+CINGULAR
+мов
+CINGULAR
+МОВ
+CINGULAR MOB
+CINGULAR MOB
+CINGULAR MOB
+CINGULAR MOB
+CINGULAR MOB
+CINGULAR MOB
+9.50
+Data Transfe wireless int
+Data Transte wireless int
+Data Transfe wireless int
+Data Transfe wireless
+int
+Data Transfe wireles
+int
+Data Transie wire
+int
+Data Transfe wireles
+int
+Data Transfe wireles
+Data Transte
+Data Transfo
+Data Transfo
+int
+int
+int
+Msg/KB
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1
+1
+1
+1
+#a000000000000nnns
+1
+1
+1E100SE
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+1 Mag
+8 KE
+0 KE
+0 KE
+0 кВ
+0 KB
+143 KB
+0 кВ
+1 KB
+2 KE
+0 KB
+2 KB
+Rate
+Fea- Incoming/ Total
+Pd
+ture
+Outgoing Charge
+In
+Out
+In
+In
+Out
+RSD1
+RBD1
+RSD1
+RSD1
+RSD1
+Out
+In
+Out
+Out
+In
+Out
+Out
+Out
+In
+In
+Out
+Out
+In
+Out
+Out
+Out
+In
+Out
+In
+Out
+In
+Out
+In
+In
+In
+Out
+Out
+Out
+Out
+Out
+Out
+Out
+Out
+Out
+Out
+Out
+.10
+.10
+.10
+.10
+0.
+.10
+0.08
+1.43
+0.01
+0.02
+0.02
+
+
+Billing Cycle Date:
+Account Number:
+20 of 20
+02/15/05 - 03/14/05
+Wireless Data Detail (Continued)
+User Name:
+Rate Code: RSDI=/RONP 600 UMM SKNV
+tate Period (Pd.): P=Peak, O=Off Peak, N=Night:
+alure: B=Dect Asst Call Complete: C=Call Wa
+nooning Call K-Fac Call M-MC-To Mobile Discount ProFit Access Service: -Roam With Hom Mobile Ca
+S=Shared Minutes: T=Three Way Calling: W=Nights and Weekends
+Rate
+Rate
+Fea- Incoming/ Total
+20m Day D/18
+02/18
+Time
+To/From
+Type
+06: 32PM Data Transfe wireless int
+SubtotahedKB's
+Msg/KB
+12 KB
+Code
+RSD1 P
+Pd
+ture
+Outgoing Charge
+Out
+Totals
+11.18
+PLEASE READ!
+Please note you may see some charges or credits on your account, which were not billed on
+our prior month's invoice. We apologize for these delayed charges/credits and regre
+my inconvenience. If you have any questions, please feel free to contact customer servic
+at 1-800-331-0500 or *611.
+Official American Idol Ringtones!
+Ringtones of the chart-topping songs from your favorite Idols - Kelly, Ruben, Clay and
+Fantasia are now available. Starting at just $1.99 each, you can download them all and
+set your phone to play a different one every week. Or get the American Idol show theme
+song. Pick your favorites at www.cingular.com/idol.
+Looking for a great job? Check out Cingular!
+Great pay, excellent benefits, flexible hours, full and part time possible
+Visit Cingular.com, click on Careers, and apply online. EOE AA/M/F/D/
+¿ Desea recibir su cuenta en español?
+Llame al 611 y marque el 2 para hablar con una operadora en español.
+DST X280-9900 (10/03)
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/3b8dd5f00a3dd8d084c1723b748b6be87dc61e4111435c7e3f7a34d5b0393784.receipt.json b/vision-fixhub/ds9-unparsed-06/3b8dd5f00a3dd8d084c1723b748b6be87dc61e4111435c7e3f7a34d5b0393784.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6c1fce87adf7ca3ee114168abb30d8882511fd35
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3b8dd5f00a3dd8d084c1723b748b6be87dc61e4111435c7e3f7a34d5b0393784.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -3617,
+  "dataset": "marble-joined",
+  "doc_id": "3b8dd5f00a3dd8d084c1723b748b6be87dc61e4111435c7e3f7a34d5b0393784",
+  "engine": "marble-apple-vision",
+  "event_count": 22,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "5561386d80a7bf6a63ee441cfe08e6aa3192f2af6612ed5985d1cbf5f4a7bc11",
+  "output_sha256": "a5a179b4c2802bf9e01ffa071647e8460455485d78495eea392b15a63d7c4101",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3bba7e708c8d35ddc0c43c61f2001858f8a1d51e041cb07c183248003e345a68.md b/vision-fixhub/ds9-unparsed-06/3bba7e708c8d35ddc0c43c61f2001858f8a1d51e041cb07c183248003e345a68.md
new file mode 100644
index 0000000000000000000000000000000000000000..6937bc6d9cde066fd4c4aa44bd4e41f499cca971
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3bba7e708c8d35ddc0c43c61f2001858f8a1d51e041cb07c183248003e345a68.md
@@ -0,0 +1,21 @@
+From:
+To: "
+Subject: Re: Epstein
+Date: Fri, 27 Aug 2010 21:50:23 +0000
+Importance: Normal
+Sure. Whenever is fine.
+From:
+Sent: Fridav, August 27. 2010 05:48 PM
+To: V
+Subject: Re: Epstein
+Sure. We're going to be out on surveillance first thing Monday morning. Would late morning / early afternoon be ok?
+From:
+To:
+Sent: Fri Aug 27 17:14:04 2010
+Subject: FW: Epstein
+Ms. Sarnoff has called former U.S. Attorney Acosta with some information. Can we all talk on Monday?
+Thanks.
+Assistant U.S. Attorney
+From: Greenberg, Benjamin (USAFLS)
+Conchita Sarnoff:
+Thanks.
diff --git a/vision-fixhub/ds9-unparsed-06/3bba7e708c8d35ddc0c43c61f2001858f8a1d51e041cb07c183248003e345a68.receipt.json b/vision-fixhub/ds9-unparsed-06/3bba7e708c8d35ddc0c43c61f2001858f8a1d51e041cb07c183248003e345a68.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..26fac0e7183d3a06a678e51eea8ebe8bd4eabab2
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3bba7e708c8d35ddc0c43c61f2001858f8a1d51e041cb07c183248003e345a68.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "3bba7e708c8d35ddc0c43c61f2001858f8a1d51e041cb07c183248003e345a68",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "d03112e7dc5432d1c2b187fcc155cf0d3f1bb3e44ff732d497a73f75f41d90c7",
+  "output_sha256": "c5936a6d871426a9413dceb1cb953b832e18b34eb8e4da5bfcabccee828b1c5b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3c2eb41b8faf320b60e679f9dd5875d00985dc5218a2fea01772ada42aa66526.md b/vision-fixhub/ds9-unparsed-06/3c2eb41b8faf320b60e679f9dd5875d00985dc5218a2fea01772ada42aa66526.md
new file mode 100644
index 0000000000000000000000000000000000000000..fc6ddb82bbffc740f00aada2e5fd999935541e04
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3c2eb41b8faf320b60e679f9dd5875d00985dc5218a2fea01772ada42aa66526.md
@@ -0,0 +1,14 @@
+From:
+To:
+Ce:
+Subject: Epstein Response
+Date: Tue, 09 Feb 2010 17:52:22 +0000
+Importance: Normal
+Attachments: 20100209
+Ltr_to_Black.wpd
+Hi all - Here is a proposed response. In addition to substance, please let me know whether you agree with
+ending a copy of the letter to Mr. Josefsberg. Thanks
+<<20100209
+Ltr to Black.wpd>>
+Assistant U.S. Attorney
+Ft Lauderdale, FL 33394
diff --git a/vision-fixhub/ds9-unparsed-06/3c2eb41b8faf320b60e679f9dd5875d00985dc5218a2fea01772ada42aa66526.receipt.json b/vision-fixhub/ds9-unparsed-06/3c2eb41b8faf320b60e679f9dd5875d00985dc5218a2fea01772ada42aa66526.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f955235a303b4c0084f271e92919f0e8fb5697eb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3c2eb41b8faf320b60e679f9dd5875d00985dc5218a2fea01772ada42aa66526.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "3c2eb41b8faf320b60e679f9dd5875d00985dc5218a2fea01772ada42aa66526",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "4ebf4fee1e16895a94e9e96ae39516a6879e2ee7c233ea977cdb7c257d188721",
+  "output_sha256": "ce2fa710d773d7f936d8aa2374143a5eb3434575c0385406890246ac6631e702",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3ca8c37075ca626e62903faf0f326e4d06e1c178269fe9541437c30c4ece9afa.md b/vision-fixhub/ds9-unparsed-06/3ca8c37075ca626e62903faf0f326e4d06e1c178269fe9541437c30c4ece9afa.md
new file mode 100644
index 0000000000000000000000000000000000000000..95d28c0ccbfe144a19cf356cacb195b2b9c427c6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3ca8c37075ca626e62903faf0f326e4d06e1c178269fe9541437c30c4ece9afa.md
@@ -0,0 +1,59 @@
+From: '
+(USAFLS)"
+To:
+(USAFLS)" <SBall@usa.doj.gov>
+Subject: FW: Jeffrey Epstein
+Date: Thu, 05 Jul 2007 11:12:42 +0000
+Importance: Normal
+Hi
+- I got a message from
+that she is out of the office. Can you give her a call on her cell phone
+) and just give her the gist of this e-mail?
+Thanks.
+Assistant U.S. Attorney
+-----Original Message---.
+From:
+(USAFLS)
+Sent: Wednesday, July 04, 2007 4:07 PM
+To:
+Cc:
+Subject: RE: Jeffrey Epstein
+Dear
+: Thank you for your e-mail and your message. This e-mail was supposed to have gone out
+yesterday while I was in trial. I have no objection to the two-week extension with respect to NES, New York
+Strategy Group, and Epstein Virgin Islands Foundation.
+With respect to the subpoena to the investigator, I would like to get the computer equipment as soon as possible.
+If you prefer to simply turn over the equipment without anyone appearing before the grand jury that is fine. If we
+proceed that way, we can defer litigating the issue of the applicability of the attorney-client and/or work product
+privilege to information related to how and why the equipment was removed. I will be in trial this week, so
+please contact
+at the FBI directly at
+I look forward to your July 11th submission. If you would like to discuss the possibility of a federal resolution of
+Mr. Epstein's case that could run concurrently with any state resolution, please leave a message on my voicemail
+at the office
+) and I will get back to you after trial has ended for the day.
+Thank you.
+Assistant U.S. Attorney
+----Original Message-..--
+From:
+Ann Sanchez [mailto:LAS@FOWLER-WHITE.COM]
+Sent: Friday, June 29, 2007 4:05 PM
+To:
+(USAFLS)
+Ce:
+Subject: Jeffrey Epstein
+
+
+As i stated in my earlier voicemail today, we were calling to request a two-week extension on the return date of
+the following outstanding subpoenas:
+1. NES
+2. NY Strategy
+3. Investigator Riley
+4. Certification for St. Thomas entity
+We will be providing an additional submission to the Office by July 11 and hope to be able to reach a state-based
+resolution shortly thereafter.
+as your voicemail to me indicted, you would not oppose a one to two-week extension. accordingly, we would
+like to extend the return date two weeks-- to July 24.
+regards
+FOWLER WHITE BURNETT P.A.
+Espirito Santo Plaza, 14th Floor
diff --git a/vision-fixhub/ds9-unparsed-06/3ca8c37075ca626e62903faf0f326e4d06e1c178269fe9541437c30c4ece9afa.receipt.json b/vision-fixhub/ds9-unparsed-06/3ca8c37075ca626e62903faf0f326e4d06e1c178269fe9541437c30c4ece9afa.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b2e200af50caf58a3afeb79eaa2593e236764014
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3ca8c37075ca626e62903faf0f326e4d06e1c178269fe9541437c30c4ece9afa.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "3ca8c37075ca626e62903faf0f326e4d06e1c178269fe9541437c30c4ece9afa",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "cef3247771144f303eccdc514e9dfb977db3593969f15fb7fa504d130ee0bb9c",
+  "output_sha256": "f77c9d980c5919c1e6987aef293d4a59959944e62e4d677675cfb2fd9fcdcf95",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3d0c14e3f94f1da1a41f5b63be4edfc5720fd34266e29bc6d3f423d80f7eb632.md b/vision-fixhub/ds9-unparsed-06/3d0c14e3f94f1da1a41f5b63be4edfc5720fd34266e29bc6d3f423d80f7eb632.md
new file mode 100644
index 0000000000000000000000000000000000000000..ecde7704ca0324bfde7c32a671add4b420535497
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3d0c14e3f94f1da1a41f5b63be4edfc5720fd34266e29bc6d3f423d80f7eb632.md
@@ -0,0 +1,27 @@
+From: "
+To: "
+(USAFLS)"</O=USA/OU=FLS/CN=RECIPIENTS/CN=DLEE>
+- (USAFLS)" <|
+',"
+(USAFLS)"
+Cc: "l
+• (USAFLS)" <
+(USAFLS)"
+Subject: Conversation with Cassell and Edwards - Bruce Reinhart's Motion to Intervene/Sanctions
+Date: Tue, 10 May 2011 20:38:57 +0000
+Importance: Normal
+and
+I just spoke with Cassell and Edwards about their upcoming response to Bruce Reinhart's motion to intervene and motion
+for sanctions. Cassell had previously written to OPR seeking access to information to respond to the motion for
+sanctions. I told
+at OPR to refer Cassell back to me, and she did.
+I suggested to Cassell that, since the victims were opposing the motion to intervene, they should await a ruling by the
+court on that issue. By doing so, we could avoid, for now, a dispute over the victims' right to government information
+regarding Reinhart's claim that the allegations against Reinhart for improperly representing Epstein's associates was not
+well-founded and/or based on a good faith belief. If the court denies the motion to intervene, we would not have to
+resolve that issue. Cassell and Edwards thought that was a good resolution of the issue.
+Cassell and Edwards also brought up the government's non-opposition to Reinhart's motion to intervene. They viewed it
+as an implicit endorsement of the intervention motion. I told them the government viewed this matter as a dispute
+Cassell and Edwards want to incorporate some language in their opposition to Reinhart's motion, to clarify that the
+government's non-opposition does not necessarily mean agreement with the motion. They will be sending me a draft so
+I can circulate it among us.
diff --git a/vision-fixhub/ds9-unparsed-06/3d0c14e3f94f1da1a41f5b63be4edfc5720fd34266e29bc6d3f423d80f7eb632.receipt.json b/vision-fixhub/ds9-unparsed-06/3d0c14e3f94f1da1a41f5b63be4edfc5720fd34266e29bc6d3f423d80f7eb632.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..607cacab7c54ae6e0f14d6f08662528126be7c82
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3d0c14e3f94f1da1a41f5b63be4edfc5720fd34266e29bc6d3f423d80f7eb632.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "3d0c14e3f94f1da1a41f5b63be4edfc5720fd34266e29bc6d3f423d80f7eb632",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "0a5a1a2caf16c6837b0c7b25a2bccc5be6da7c73c9ddce7e6e31c8a215ff39d7",
+  "output_sha256": "cba6e0c0e88378fee50dd72551c7f6c44dde3698817cd56516109cb34c68cdfb",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3d4bb5355d0a5c96660994d0f654243d72918a9ffb9315838520badc03cac1a1.md b/vision-fixhub/ds9-unparsed-06/3d4bb5355d0a5c96660994d0f654243d72918a9ffb9315838520badc03cac1a1.md
new file mode 100644
index 0000000000000000000000000000000000000000..cc5848192d013d5fbac3d880b04361f1eef01d44
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3d4bb5355d0a5c96660994d0f654243d72918a9ffb9315838520badc03cac1a1.md
@@ -0,0 +1,30 @@
+MARTIN G. WEINBERG, P.C.
+ATTORNEY AT LAW
+EMAIL ADDRESSES:
+owimch@att.net
+owlmgw@att.net
+(617) 227-3700
+FAX (617) 338-9338
+NIGHT EMERGENCY:
+(617) 901-3472
+July 22, 2011
+Southern District of Florida
+500 S. Australian Ave. Suite 400
+West Palm Beach, Florida 33401
+Re:
+Jeffrey Epstein
+Dear
+Roy Black forwarded to me your letter to him dated July 21, 2011, from the District
+Attorney of the County of New York. We thank you for providing notice of the intended
+disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related
+list of witness/victims on the basis of the confidentiality provisions of paragraph 13. Absent an
+enforceable subpoena - which we would have the right to move to quash in the Court from which
+it was issued - there exists no right or duty to disclose the confidential Non-Prosecution
+Agreement or the non-public witness/victim list which was referenced in paragraph 7 of the
+NPA. Further, given that the witness/victim list was compiled based on the federal grand jury
+investigation, we object under Fed. R. Crim. P. 6(e) to its disclosure absent an appropriate court
+order.
+Very truly yours,
+Mate Is Warly 120
+Martin G. Weinberg
+ce: Roy Black
diff --git a/vision-fixhub/ds9-unparsed-06/3d4bb5355d0a5c96660994d0f654243d72918a9ffb9315838520badc03cac1a1.receipt.json b/vision-fixhub/ds9-unparsed-06/3d4bb5355d0a5c96660994d0f654243d72918a9ffb9315838520badc03cac1a1.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..32f68512be2a532cef7f463df6bda7f515712751
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3d4bb5355d0a5c96660994d0f654243d72918a9ffb9315838520badc03cac1a1.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "3d4bb5355d0a5c96660994d0f654243d72918a9ffb9315838520badc03cac1a1",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "cbfe1cc8d8235357331499d091bcec8c1c39776f6f6340bd284a0b93aa76bcfe",
+  "output_sha256": "1bd31bc73e047d3f26732240a975ff8391e4500b7c4c61cd2d973637c8367aa5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3d5e775b887560659b0d807608211f5265edf2334dc9f26adc531e81c4c1f0ce.md b/vision-fixhub/ds9-unparsed-06/3d5e775b887560659b0d807608211f5265edf2334dc9f26adc531e81c4c1f0ce.md
new file mode 100644
index 0000000000000000000000000000000000000000..724a87085b1bccf7940685015297c3b6f15c8475
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3d5e775b887560659b0d807608211f5265edf2334dc9f26adc531e81c4c1f0ce.md
@@ -0,0 +1,34 @@
+From: Jackie Perczek <|
+To:
+• (USAFLS)".
+Subject: Doe I. USAO
+Date: Fri, 14 Oct 2011 20:48:01 +0000
+Importance: Normal
+Inline- ATTOOOO
+mages:
+Hi
+In a little while, I will be filing Epstein's omnibus reply in support of his motion to intervene. It is one pleading.
+hat replies to your response and to Cassell's response. It was better and more efficient to do one pleading.
+rill be 19 pages. Do vou oppose a motion to file an overlong pleading? Cassell says he opposes anything longr
+Also, my reply to Cassell's response to the supplemental briefing filed by the would-be intervenor lawyers is due
+early next week. I will be filing a motion for an extension until October 31. Cassell has no objection. Can I say
+the govt has no objection either?
+Thanks,
+Jackie Perczek, Esq.
+BLACK
+SREBNICK
+KORNSPAN
+STUMPF
+TRIAL ATTORNEYS
+201 South Biscayne Boulevard
+Suite 1300
+Miami, Florida 33131
+O: (305) 371-6421
+Fax: (305) 358-2006
+www.royblack.com
+**************************************************************
+The information in this email transmission is privileged and confidential. If you are not the intended recipient, nor
+the employee or agent responsible
+for delivering it to the intended recipient, you are hereby notified that any dissemination or copying of this
+transmission (including any attachments) is strictly prohibited. If you have received this email in error, please
+notify the sender by email reply. Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/3d5e775b887560659b0d807608211f5265edf2334dc9f26adc531e81c4c1f0ce.receipt.json b/vision-fixhub/ds9-unparsed-06/3d5e775b887560659b0d807608211f5265edf2334dc9f26adc531e81c4c1f0ce.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0f356bb6f79ac0a73a3e2602080adad59466d1ae
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3d5e775b887560659b0d807608211f5265edf2334dc9f26adc531e81c4c1f0ce.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "3d5e775b887560659b0d807608211f5265edf2334dc9f26adc531e81c4c1f0ce",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "c2bd0c573d7752c05a5181cbc2f92f584cafd1a975a18b71e2255ccf780f80f2",
+  "output_sha256": "687b9b238d9c19d898d640d1c1bf8ef16f295e864a1fee13e9a49cac9371d220",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3d83b5a168266a23f4269ef934647df7133685cae8c1c8f869751c2f96237d94.md b/vision-fixhub/ds9-unparsed-06/3d83b5a168266a23f4269ef934647df7133685cae8c1c8f869751c2f96237d94.md
new file mode 100644
index 0000000000000000000000000000000000000000..409e2a989d20101b278bfc69d78419d9af4e15eb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3d83b5a168266a23f4269ef934647df7133685cae8c1c8f869751c2f96237d94.md
@@ -0,0 +1,122 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Misc-Marra/Matthewman
+JANE DOE #1 and JANE DOE #2,
+Petitioners,
+I.
+UNITED STATES OF AMERICA,
+Respondent.
+RESPONDENT'S ANSWERS TO PETITIONERS' FIRST REQUESTS FOR
+ADMISSIONS
+1. Admit.
+2. (a) Cannot admit or deny. Jeffrey Epstein's ("Epstein") attorneys learned of the
+notifications that were planned to be provided to persons designated as victims when
+contact was made with the attorney who was then representing Jane Doe #2' to
+determine how she wanted to be notified. At that time, Epstein's attorneys contacted
+the U.S. Attorney's Office ("USAO") and stated their objections to the procedure for
+notification and the legal bases therefore. Epstein's attorneys also objected to the
+designation of Jane Doe #2 as a victim because she had self-reported that she was not
+a victim. Members of the USAO considered those objections.
+(b) Admit.
+' This attorney was being compensated by Epstein to represent Jane Doe #2.
+
+
+(c) Cannot admit or deny. As a result of the objections lodged by Epstein's attorneys,
+in particular with regard to Jane Doe #2, Epstein's attorneys sought review of the case
+in Washington, D.C. which halted all proceedings with the USAO.
+(d) Deny. Notifications prior to signing the agreement were not contemplated.
+3.
+Deny.
+4. Deny.
+5. Admit.
+6. (a) Deny. [These all need to be confirmed.]
+(b) Deny.
+(c) Admit.
+(d) Admit.
+(e) Admit to the extent this is meant to refer to Lilly Ann Sanchez.
+(f) Admit.
+(g) Admit.
+7. Admit; however, on or about January 10, 2008, Epstein was challenging the
+legitimacy of the non-prosecution agreement and the FBI and the USAO were
+preparing for the possibility that the non-prosecution agreement might be set aside
+and a federal prosecution might proceed; thus, the case was, in fact, "currently under
+investigation."
+8. Deny.
+9. (a) Admit.
+(b) Admit.
+(c) Deny.
+
+
+(d) Deny.
+(e) Deny. [Need to explain.]
+10. (a) Admit.
+(b) Admit in part and deny in part. The agents explained to Jane Doe #1 that Epstein
+would plead guilty to state charges for procuring minors to engage in prostitution
+for which he would be required to register as a sex offender; and that Jane Doe #1
+would be entitled to seek damages from Epstein and that, if she desired, Jane Doe
+#1 would be entitled to use the services of an attorney at no expense to her in
+seeking those damages from Epstein. The agents did not explain that the state
+charges "involv[ed] another victim."
+(c) Deny.
+The agents explained that an agreement had been signed and they were
+explaining the terms of that agreement to Jane Doe #1. They further explained
+that the agreement resolved the investigation of her case.
+(d) Deny.
+(e) Deny.
+(f) Deny.
+(g) Deny.
+11. [I can't certify to the date.] Admit in part and deny in part. The Respondent admits
+that, following that correspondence, Epstein's counsel asked to have the case
+reviewed by attorneys at the Justice Department in Washington, D.C., and,
+accordingly, the U.S. Attorney's Office did not, at that time, send the proposed victim
+notification letter because it was unclear whether the Non-Prosecution Agreement
+would, in fact, go into effect.
+
+
+12. Admit.
+13. (a) Deny as to Jane Doe #1; admit as to Jane Doe #2. Please see response to Request
+#10.
+(b) Admit. [Can we add: Members of the Executive Division at the USAO
+determined that attorneys for the USAO and the FBI agents would not confer with
+Jane Doe #1 prior to the USAO's decision to enter into the non-prosecution
+agreement. Jane Doe #2 had already informed the attorney for the government
+and the FBI agents that she did not believe that Epstein should be prosecuted.]
+(c) Cannot admit or deny. Information lies within the possession of Epstein's
+defense attorneys.
+(d) Deny. The Non-Prosecution Agreement contains a confidentiality provision that
+keeps the document confidential. It does not govern conferring with victims prior
+to entering into the Agreement nor does it govern advising them regarding its
+terms.
+14. Admit in part.
+The parties sought to keep the document confidential, not its
+existence, which was disclosed to the state court judge during the change of plea.
+15. (a) Admit in part. While he was an Assistant U.S. Attorney, Bruce E. Reinhart
+learned confidential, non-public information about the Epstein matter.
+(b) Admit in part. While he was an Assistant U.S. Attorney, Bruce E. Reinhart
+discussed the Epstein matter with another Assistant U.S. Attorney working on the
+Epstein matter.
+(c) Deny.
+
+
+16. [I haven't completed the review yet. So far there may be some personal emails with
+Jack Goldberger only. We don't have any telephone logs or other documents.]
+17. [You need to check with DC about this. Does DC have my emails by any chance?]
+Deny-
+18. [I don't know how to answer this. "improper communication or influence" is so
+vague and potentially broad that a denial is problematic. I also have never seen all of
+the emails between Guy and Lilly Ann and Alex, Jeff, Matt, Andy, and Rolando (and
+any others in DC).]
+19. [Again, I don't know how to answer this. The RFA does not use the word "former,"
+so it would seem to only cover personal or business relationships between Epstein
+himself and persons who were then-employees of the USAO. I am unaware of any
+such relationships with Epstein directly. We will need to review emails and possibly
+interview Alex/Jeff/Matt/Andy J
+20. Admit. [I know that Menchel now has a business relationship with Epstein. I don't
+have any documentary evidence, but I have been told this by Jeff Sloman.]
+21. [I don't know.]
+22. [OPR needs to answer these.]
+23. Admit.
+24. [I don't know what "valuable consideration" means. I had heard a rumor that Epstein
+was a cooperator in the Bear Stearns investigation but this was never confirmed.]
+25. Deny?
+26. Admit.
diff --git a/vision-fixhub/ds9-unparsed-06/3d83b5a168266a23f4269ef934647df7133685cae8c1c8f869751c2f96237d94.receipt.json b/vision-fixhub/ds9-unparsed-06/3d83b5a168266a23f4269ef934647df7133685cae8c1c8f869751c2f96237d94.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b3f2cfbbcff75ba80b2dc6dea985cd123da71550
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3d83b5a168266a23f4269ef934647df7133685cae8c1c8f869751c2f96237d94.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -60,
+  "dataset": "marble-joined",
+  "doc_id": "3d83b5a168266a23f4269ef934647df7133685cae8c1c8f869751c2f96237d94",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "6c15584914bda48b65ae1ac7582344fbe230e2fcf0044e21ce540a283a52ecd9",
+  "output_sha256": "9e919fe6f3176beb209c78cc61e494f11fda88014622eb4ea19a13be09dd51cd",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3df480e8a20145837744f6209c09e3642cc30adfe8e2b1d6023690bc2f5ea42f.md b/vision-fixhub/ds9-unparsed-06/3df480e8a20145837744f6209c09e3642cc30adfe8e2b1d6023690bc2f5ea42f.md
new file mode 100644
index 0000000000000000000000000000000000000000..32850bc93c1ab1d576f7b1104075f7e89a193a21
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3df480e8a20145837744f6209c09e3642cc30adfe8e2b1d6023690bc2f5ea42f.md
@@ -0,0 +1,61 @@
+Case 9:08-cv-80736-KAM Document 105 Entered on FLSD Docket 10/10/2011 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOE #1 and JANDE DOE #2
+V.
+UNITED STATES
+JANE DOE #1 AND JANE DOE #2'S UNOPPOSED MOTION FOR FIVE EXTRA
+PAGES TO RESPOND TO SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTION
+TO INTERVENE BY ROY BLACK ET AL.
+COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and
+through undersigned counsel, to move this Court to allow them five extra pages beyond the
+twenty-page limit to respond to the Supplemental Briefing in Support of Motion to Intervene of
+Roy Black, Martin Weinberg, and Jay Lefkowitz (DE 94) and the government response thereto
+(DE 100). The motion is unopposed.
+In support of the motion, the victims note that initial Supplemental Briefing from Epstein
+they are responding to (DE 94) is 23 pages long. The Government's response (DE 100) supports
+many of Epstein's arguments and is 11 pages long. As a result, the victims have a total of 33
+pages that they need to respond to. The victims require 25 pages to set forth all of their
+arguments and authorities on the issues addressed in the briefs. The victims have discussed this
+motion with counsel for Epstein and the Government, and they do not oppose the motion.
+1
+
+
+Case 9:08-cv-80736-KAM Document 105 Entered on FLSD Docket 10/10/2011 Page 2 of 3
+CONCLUSION
+For all the foregoing reasons, the Court should allow Jane Doe #1 and Jane Doe #2 an
+additional five pages (a total of 25 pages) to respond to the Supplemental Briefing in Support of
+Motion to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz (DE 94) and the
+government response thereto (DE 100).
+DATED: October 10, 2011
+Respectfully Submitted,
+s/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+Fort Lauderdale, Florida 33301
+and
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utah
+Salt Lake City, UT 84112
+Attorneys for Jane Doe #1 and Jane Doe #2
+2
+
+
+Case 9:08-cv-80736-KAM Document 105 Entered on FLSD Docket 10/10/2011 Page 3 of 3
+CERTIFICATE OF SERVICE
+The foregoing document was served on October 10, 2011, on the following using the
+Court's CM/ECF system:
+A. Marie Villafaña
+Assistant U.S. Attorney
+West Palm Beach, FL 33401
+Attorney for the Government
+Roy Black, Esq.
+Jackie Perczek, Esq.
+Black, Srebnick, Kornspan & Stumpf, P.A.
+Miami, FL 33131
+Attorneys for Proposed Intervenors Roy Black et al.
+3
diff --git a/vision-fixhub/ds9-unparsed-06/3df480e8a20145837744f6209c09e3642cc30adfe8e2b1d6023690bc2f5ea42f.receipt.json b/vision-fixhub/ds9-unparsed-06/3df480e8a20145837744f6209c09e3642cc30adfe8e2b1d6023690bc2f5ea42f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..45ba4a2ea6e61b56fee9e88dff60357e5d1ef814
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3df480e8a20145837744f6209c09e3642cc30adfe8e2b1d6023690bc2f5ea42f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "3df480e8a20145837744f6209c09e3642cc30adfe8e2b1d6023690bc2f5ea42f",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "56a89193262d72f3e01aff56012c87d47862323747d8e56779c8dbe2da0a25f5",
+  "output_sha256": "ae446cd7d2b6220dd2b066f95ad345d9a5a17f4e5dbdb5bce6c648e86311f412",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3e0f9949395cdd740ff3abd210bef518f5b4b3cf10752244bc0d61561bc918a3.md b/vision-fixhub/ds9-unparsed-06/3e0f9949395cdd740ff3abd210bef518f5b4b3cf10752244bc0d61561bc918a3.md
new file mode 100644
index 0000000000000000000000000000000000000000..de5511a0ef52fe6e0712ca82919280f7015b454f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3e0f9949395cdd740ff3abd210bef518f5b4b3cf10752244bc0d61561bc918a3.md
@@ -0,0 +1,24 @@
+To: "Roy Black" <RBlack@royblack.com>
+Subject: Re: Epstein
+Date: Thu, 20 Jun 2013 14:10:35 +0000
+Importance: Normal
+Inline-Images: image001 jpg; image002.jpg; image003.jpg
+Hi Roy: I have been in debriefings so our team hasn't had a chance to meet yet. I will give you a call to advise as
+soon as we do. Thank you.
+On Jun 20, 2013, at 9:57 AM, "Roy Black" <RBlack@royblack.com> wrote:
+[left a message with you yesterday about Judge Marra's orders entered on Tuesday. I need to know when or if you
+intend to file the plea bargain materials because we are going to file for a stay of the order per rule 410 etc. Please let
+me know the government's position on the materials. Also let me know if the government will oppose or not our
+Roy Black, Esq.
+<image001.jpg>
+The information in this email transmission is privileged and confidential. If you are not the intended recipient, nor the
+employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any dissemination or
+copying of this transmission (including any attachments) is strictly prohibited. If you have received this email in error
+lease delete all copies of this email and any attachments and notify us immediately. Thank you
+<image003.jpg>
+BLACK
+SREBNICK
+KORNSPAN
+STUMPF
+TRIAL ATTORNEYS
+• Legal Statement
diff --git a/vision-fixhub/ds9-unparsed-06/3e0f9949395cdd740ff3abd210bef518f5b4b3cf10752244bc0d61561bc918a3.receipt.json b/vision-fixhub/ds9-unparsed-06/3e0f9949395cdd740ff3abd210bef518f5b4b3cf10752244bc0d61561bc918a3.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ab12050488706e5c9a8efb8ed964b1a3f2e74591
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3e0f9949395cdd740ff3abd210bef518f5b4b3cf10752244bc0d61561bc918a3.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "3e0f9949395cdd740ff3abd210bef518f5b4b3cf10752244bc0d61561bc918a3",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3a8f83b9f0b229aebf4ece2ee20fe4f49356fc8b4a6f361b1e177c4212a5fbae",
+  "output_sha256": "9678d256459a5b12bd44e162a94aae1b24943b89c03e1375eebab48a376f589a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3e24954ed96a947be00a342b46c3956f71a78bb75297d159722f8760c7a6e858.md b/vision-fixhub/ds9-unparsed-06/3e24954ed96a947be00a342b46c3956f71a78bb75297d159722f8760c7a6e858.md
new file mode 100644
index 0000000000000000000000000000000000000000..3f5ae88a1d09c1af27c616c58d43bc58eccbd4b6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3e24954ed96a947be00a342b46c3956f71a78bb75297d159722f8760c7a6e858.md
@@ -0,0 +1,29 @@
+From:
+(USAFLS)"
+To:
+(USAFLS)" ≤
+Subject: RE: Epstein
+Date: Wed, 04 Jul 2007 20:05:47 +0000
+Importance: Normal
+I - Can you review this? I am livid.
+- I am in trial, so I just got this message. Why would you enter into plea negotiations without consulting
+with me? This makes my investigation look like a joke and completely undermines my ability to deal with
+Epstein's attorneys directly. We left the meeting on June 26th in a stronger position than when we entered, an
+our statement that a state resolution would satisfy us takes away that advantage. If you make it seem like th
+U.S. Attorney doesn't have faith in our investigation, Epstein has no incentive to make a deal.
+My trial should end early next week. I would like to make a presentation to the U.S. Attorney and you and
+with our side of the investigation. It will address the points raised by Epstein's counsel and should convince you
+all of the strength of the case. In the meantime, please do not discuss this case with opposing counsel without
+consulting with me.
+Assistant U.S. Attorney
+-----Original Message-...-
+From: Sloman,
+(USAFLS)
+Sent: Tuesday, July 03, 2007 1:47 PM
+To:
+(USAFLS)
+Subject: Epstein
+•. my blackberry is giving me trouble so i'm using _
+•. I told lily that a state plea with jail time and sex
+offender status may satisfy the usa. It was a non-starter for them
+Sent from my GoodLink synchronized handheld (www.good.com)
diff --git a/vision-fixhub/ds9-unparsed-06/3e24954ed96a947be00a342b46c3956f71a78bb75297d159722f8760c7a6e858.receipt.json b/vision-fixhub/ds9-unparsed-06/3e24954ed96a947be00a342b46c3956f71a78bb75297d159722f8760c7a6e858.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ba118b43734aa82671ab27083e9026d5516911c8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3e24954ed96a947be00a342b46c3956f71a78bb75297d159722f8760c7a6e858.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "3e24954ed96a947be00a342b46c3956f71a78bb75297d159722f8760c7a6e858",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "908ac3971c4bd35032750d9205234739f8cf9b631a1fa26e730944f12d6806ec",
+  "output_sha256": "43c39ffa1d3ec20e74ed0881d549a4243de6479f1d1def66c6e8ad0295d84698",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3eb9b7169c7d2a82723139af3c7deb6878130331a5ffaab75b25e07bf3e43800.md b/vision-fixhub/ds9-unparsed-06/3eb9b7169c7d2a82723139af3c7deb6878130331a5ffaab75b25e07bf3e43800.md
new file mode 100644
index 0000000000000000000000000000000000000000..293e2884b060db4c5c0ecfbac3e8d9c8540e44fb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3eb9b7169c7d2a82723139af3c7deb6878130331a5ffaab75b25e07bf3e43800.md
@@ -0,0 +1,20 @@
+From: "
+To: "
+(USAFLS)" ‹|
+Subject: Epstein
+Date: Mon, 18 Jun 2007 21:03:59 +0000
+Importance: Normal
+￾ (USAFLS)"</O=USA/OU=FLS/CN=RECIPIENTS/CN=|
+(USAFLS)" <
+',"
+(USAFLS)" ‹
+| (USAFLS)"
+P,
+I just received a call from the FBI telling me that Vanity Fair is sniffing around again. The reporter is a former
+detective. He told the FBI agent that his sources tell him "the State has been bought off," and asked if our
+responded, "All I can tell you is that we have an open
+On another note, I am going to see the grand jury tomorrow and I anticipate a number of questions regarding the
+status of the indictment. I'm not sure what, if anything, I can tell them.
+And I did not hear back regarding making changes to the indictment. Can I get some feedback on that?
+Thank you.
+Assistant U.S. Attorney
diff --git a/vision-fixhub/ds9-unparsed-06/3eb9b7169c7d2a82723139af3c7deb6878130331a5ffaab75b25e07bf3e43800.receipt.json b/vision-fixhub/ds9-unparsed-06/3eb9b7169c7d2a82723139af3c7deb6878130331a5ffaab75b25e07bf3e43800.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7c6ced482e99eb6ff02b73349e50a6182a987dec
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3eb9b7169c7d2a82723139af3c7deb6878130331a5ffaab75b25e07bf3e43800.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "3eb9b7169c7d2a82723139af3c7deb6878130331a5ffaab75b25e07bf3e43800",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "9cb12af34f64cb6579d70704cd9204071fc082050953d7c112dd059e71dd199a",
+  "output_sha256": "29e2e90cf40f480dfa1380cee480f322800804428bd521d90c44bcc61397f7ed",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3ee7c85050c340528db5cc0df28a930c1f6fbb4ab5019ca06ce0466884e1b43d.md b/vision-fixhub/ds9-unparsed-06/3ee7c85050c340528db5cc0df28a930c1f6fbb4ab5019ca06ce0466884e1b43d.md
new file mode 100644
index 0000000000000000000000000000000000000000..0a9b9761234102502fa43a1b27ac02a0dac354f5
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3ee7c85050c340528db5cc0df28a930c1f6fbb4ab5019ca06ce0466884e1b43d.md
@@ -0,0 +1,490 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE No. 08-80736-CIV-MARRA/JOHNSON
+JANE DOE 1 AND JANE DOE 2,
+Plaintiffs
+UNITED STATES OF AMERICA,
+Defendant
+INTERVENORS' MOTION FOR STAY PENDING APPEAL
+Intervenors Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epstein hereby
+request that this Honorable Court stay its order of June 18, 2013 (Doc. 188), denying their
+Motion for a Protective Order and ordering disclosure to plaintiffs of the intervenor attorneys"
+written communications with federal prosecutors in the Southern District of Florida made with
+the specific purpose of obtaining a favorable resolution of the criminal investigation of Mr.
+Epstein through attorney-to-attorney settlement negotiations. In determining whether to grant a
+stay pending appeal, the Court is to consider four factors: "(1) the likelihood that the moving
+party will ultimately prevail on the merits of the appeal; (2) the extent to which the moving party
+would be irreparably harmed by denial of the stay; (3) the potential harm to opposing parties if
+the stay is issued; and (4) the public interest." Florida Businessmen for Free Enterprise I City of
+Hollywood, 648 F.2d 956, 957 (11th Cir. 1981). See, e.g., In re Federal Grand Jury Proceedings
+(FG.J 91-9), Cohen, 975 F.2d 1488, 1492 (11th Cir. 1992). Those factors are amply satisfied in
+this case: there is a strong likelihood that intervenors will prevail on appeal (or at a minimum,
+
+
+they have a "substantial case on the merits," and the "harm factors" militate in favor of granting
+a stay, Merial Ltd. I. Cipla Ltd., 426 Fed.Appx. 915 (11th Cir. 2011), citing Hilton |
+Braunskill, 481 U.S. 770, 778 (1987)); they will be immediately and irreparably harmed by the
+disclosure of the communications at issue; the plaintiffs will suffer no harm from the granting of
+a stay until these critically important issues can be resolved by the Eleventh Circuit; and to the
+extent that the public has an interest in the matter, it would favor considered appellate resolution
+of the issues presented prior to the release of the communications at issue.
+The Court's order is the first decision anywhere, insofar as undersigned counsel are
+aware, which has ordered disclosure to third party civil litigants of private and confidential
+communications between attorneys seeking to resolve a criminal matter favorably to their clients
+and government prosecutors. While framed as a disclosure order in this particular case, the
+Court's decision, which drastically reshapes the landscape of criminal settlement negotiations
+and sets at nought expectations of privacy, confidentiality, and privilege on which criminal
+defense attorneys have reasonably relied for many decades in negotiating with government
+attorneys on behalf of their clients,
+has potentially far-reaching and, intervenors contend,
+seriously deleterious consequences for the ability of attorneys nationwide to effectively represent
+their clients through open and candid communication with government counsel. The decision
+will have a predictably chilling effect on attorneys around the country, if they can no longer
+expect privacy and confidentiality in their written communications with prosecutors aimed at
+reaching a negotiated resolution to the case. Such communications often necessarily involve
+explicit or implicit admissions regarding their client's conduct - what he did, what he did not do,
+what he knew, what he intended, and the like - and the attorney's opinions regarding acceptable
+2
+
+
+resolutions of the matter, admissions and opinions which attorneys in many cases will be loath to
+commit to written form if they may be subject to later disclosure to civil adversaries of the
+attorney's client. This case is far from sui generis - the cases are legion in which there is related
+civil litigation seeking damages or other recovery from an individual who was the subject of
+criminal investigation or prosecution and in which, after becoming aware of this Court's
+decision, plaintiffs will begin clamoring for access to communications between defendants'
+counsel and prosecuting authorities in the belief that it may help support their civil case against
+the defendant. In addition to the stay factors addressed below, the importance of these issues for
+the functioning of the criminal justice system counsels in favor of granting the requested stay.
+Intervenors have standing under Perlman 1. United States, 247 U.S. 7 (1918), to pursue
+an interlocutory appeal of the Court's order, and questions of privilege and confidentiality
+asserted by non-parties to the litigation are paradigmatic examples of circumstances in which
+interlocutory appeals are allowed, yet the value of that appeal will be severely undercut, if not
+destroyed entirely, if a stay pending appeal is not granted. Forced disclosure of confidential or
+privileged communications cannot be undone on appeal; the protections afforded the documents
+will have been irretrievably lost before the appellate court can pass on the matter, to the
+intervenors' irremediable prejudice. For all the reasons addressed herein, the Court should grant
+the requested stay.
+1.
+LIKELIHOOD OF SUCCESS ON THE MERITS.'
+" Intervenors incorporate by reference herein the arguments set forth in their Motion for a
+Protective Order and Opposition to Motions of Jane Doe 1 and Jane Doe 2 for Production, Use, and
+Disclosure of Settlement Negotiations (Doc. 160); Supplemental Briefing of Intervenors Roy Black,
+Madictibe, and Disclosure or insa Negor theis Moe. Prerveivor Previvor Order Concerning
+3
+
+
+A. The Applicability of Rule 410.
+Any assessment of the merits of the intervenors' contentions must begin with an
+understanding of the central role of plea bargaining and settlement negotiations in our criminal
+justice system and the Sixth Amendment protections which surround them. "Plea bargains are . .
+• central to the administration of the criminal justice system" because ours is *a system of pleas, not
+a system of trials":
+ninety-four percent of state convictions are the result of guilty pleas. The reality is that plea
+bargains have become so central to the administration of the criminal justice system that
+defense counsel have responsibilities in the plea bargain process, responsibilities that must
+be met to render the adequate assistance of counsel that the Sixth Amendment requires in
+the criminal process at critical stages. Because ours "is for the most part a system of pleas,
+not a system of trials," it is insufficient simply to point to the guarantee of a fair trial as a
+backstop that inoculates any errors in the pretrial process.
+Lafler I. Cooper, 132 S. Ct. 1376, 1388 (2012); Missouri |. Frye, 132 S. Ct. 1399, 1407
+(2012).
+In Lafler and Frye, the Supreme Court ruled that the Sixth Amendment right to effective assistance
+of counsel "extends to the plea bargaining process" and that defendants are entitled to "the
+effective assistance of competent counsel" during plea negotiations. Lafler, 132 S. Ct. at 1384;
+Frye, 132 S.Ct. at 1407-09 (2012). Under Lafler and Frye, counsel have an ongoing obligation to
+provide effective representation in plea bargaining and to engage in communications with the client
+and the prosecutor to discharge that obligation. Even before formal charges are brought, counsel
+Motion for a Protective Order and Opposition to Motions of Jane Doe 1 and Jane Doe 2 for
+4
+
+
+representing a client under federal investigation have an obligation to secure the best possible
+outcome for their clients, whether it be one which results, as here, in no charges being brought
+by the prosecuting authority conducting the criminal investigation or the bringing of fewer, or
+less serious,
+charges against the client. Defense counsel
+cannot fulfill their professional
+obligations to their clients if they must temper their communications with the prosecution in the
+criminal settlement negotiation context for fear that disclosures made now will later enure to the
+clients' severe detriment in other litigation contexts. Defendants and people under criminal
+investigation would not engage in plea negotiations and waive their Fifth Amendment rights if
+they believed that statements made during those negotiations could be used against them later in
+litigation with third parties. Candid discussions simply cannot take place if defendants or persons
+under criminal investigation fear that statements made during negotiations can be divulged to
+third parties in other proceedings and used to harm them, send them to prison, or invalidate their
+bargains years after they have served prison sentences and suffered all the consequences of their
+deals. Few if any lawyers would engage in candid and open discussions with a prosecutor if their
+statements could later be used against their clients. The professional, ethical, and constitutional
+obligations of attorneys representing persons under investigation for, or charged with, crimes are
+terribly at odds with any ruling which exposes those negotiations to public scrutiny (or to the
+scrutiny of later litigation adversaries of the client) and makes them admissible in evidence to be
+used as ammunition to harm the clients, yet that is the very result which this Court's Order
+enshrines. The strong policy considerations mitigating against the result reached by the Court
+weigh heavily in favor of the likelihood of intervenors' success on appeal.
+5
+
+
+Contrary to the result reached by this Court, the settlement negotiations at issue here lie
+well within the heartland of Rule 410's prohibition against the admissibility of plea negotiations
+"against the defendant who was a participant in the plea discussions" "in any civil or criminal
+proceeding". The cases on which the Court relied in concluding that the settlement negotiations
+at issue here do not fall within Rule 410 are uniformly inapposite and do not support the
+proposition that the settlement negotiations in this case are not subject to the protections of Rule
+410. United States | Merrill, 685 F.3d 1002, 1013 (11th Cir. 2012), concerned statements
+made by the defendant himself in informal meetings with the prosecution prior to his scheduled
+grand jury testimony, see id. at 1007-08. The only discussions of leniency involved the
+government's generalized statement to the defendant that if he cooperated, the government
+would recommend leniency when he was sentenced. Id. Notably, the Court's ruling that the
+rict court had not erred in refusing to supress the defendant's statements rested on its
+conclusion that, given the circumstances, the defendant could not have reasonably believed that
+he was engaged in plea negotiations. Id. at 1013. The case does not stand for the general
+proposition advanced by the Court that settlement discussions in advance of the return of an
+indictment categorically do not fall within Rule 410.- Moreover, the circumstances present here
+were dispositively different from those in Merrill. Here, the communications were made
+attorney-to-attorney under circumstances which leave no room to doubt that the parties were
+engaged in serious negotiations to resolve the federal criminal investigation of Epstein. United
+- In any event, there was, as the Court notes elsewhere in its opinion, an indictment pending in
+6
+
+
+States | Adelman, 458 F.3d 791 (8th Cir. 2006), also involved statements made by the
+defendant to federal prosecutors; the defendant's statements were made in meetings at which she
+was told, according to the government, that she was a "prime suspect" in criminal wrongdoing
+and that any statements she made could be used against her. Id. at 805. In United States I. Hare,
+49 F.3d 447 (8th Cir. 1995), like the other two cases, the statements at issue were made by the
+defendant to prosecutors voluntarily and unconditionally in the unilateral hope of bettering his
+chances. Id. at 451.
+Under the Court's ruling, the attorneys for a person under federal criminal investigation
+may never enter into negotiations with the government with the primary aim of avoiding federal
+indictment entirely, no matter how serious and good faith those negotiations, without risking that
+anything they say on behalf of their clients in seeking to arrive at a negotiated settlement may in
+the future be used, either by the government or by adversarial third parties, to the severe
+detriment of their client. This is not and cannot be the law and is certainly unsound policy, and
+there is a substantial likelihood that the Eleventh Circuit will agree. Indeed, the Court's opinion
+creates an incentive for attorneys not to do precisely what Hickman I. Taylor, 329 U.S. 495
+(1947), was intended to encourage attorneys to do: reduce facts, ideas, and opinions to writing. A
+return to the days of settlement/plea negotiations conducted through oral, rather than written,
+communications, which the Court's decision will encourage whenever the progress of the
+negotiations or the attainment of the desired objective require the attorney to communicate
+information which, if disclosed in another context, would be detrimental to the client's interests
+would serve no one's interests - not the defendant's, not the government's, not the judicial
+system's, and not the public's.
+
+
+The Court also rejected the applicability of Rule 410 because the communications
+between Epstein's counsel and the government led to Epstein's plea of guilty in state court. In
+the sole case cited by the Court for this proposition, United States | Paden, 908 F.2d 1229 (5th
+Cir. 1990), the defendant pled guilty to federal charges pursuant to his plea agreement. That Mr.
+Epstein entered into a plea in state court to state offenses is irrelevant to the Rule 410 analysis.
+The plain meaning of Rule 410(4) is that the defendant must enter a plea in federal court relating
+to the federal offenses under investigation. If Congress had intended to include state court pleas
+in subsection (4), it would have expressly done so, as it did in subsection (3). There, Congress
+expressly provided for change-of-plea proceedings in federal court and "comparable state
+procedures." FED.R.EVID. 410(3). Congress did not provide for state court pleas in subsection (4)
+of the rule, and "where Congress includes particular language in one section of a statute but
+omits it in another ... it is generally presumed that Congress acts intentionally and purposely in
+the disparate inclusion or exclusion." Keene Corp. I. United States, 508 U.S. 200, 208 (1993).
+Even when plea negotiations result in a guilty plea, not all statements made during those
+negotiations are thereby subject to disclosure. The plain meaning of Rule 410 is that any
+disclosure of plea negotiations must relate to the plea that was actually entered. The broad
+reading adopted by the Court would frustrate the purpose and policy of Rule 410. In this case,
+there was no plea to the offenses that the government was investigating or to the matters
+discussed in the plea negotiation letters and emails. There was never a federal plea that closed
+out all the federal issues that were the subject of the continuing exchanges of letters and memos
+in which Mr. Epstein's counsel addressed the reasons why Mr. Epstein should not be federally
+prosecuted
+
+
+The "central feature" of Rule 410 "is that the accused is encouraged candidly to discuss
+his or her situation in order to explore the possibility of disposing of the case through a
+consensual arrangement." United States I. Herman, 544 F.2d 791, 797 (Sth Cir. 1977). The Rule
+is derived from "the inescapable truth that for plea bargaining to work effectively and fairly, a
+defendant must be free to negotiate without fear that his statements will later be used against
+him." Id. at 796 (emphasis added). Thus, the most reasonable construction of Rule 410 is that all
+plea discussions in this case were about offenses for which there was no plea of guilty, and
+therefore Rule 410 facially and fully applies. Any other reading would render Rule 410
+ambiguous and would violate Mr. Epstein's Fifth Amendment rights.
+The rule's central feature is that the accused is encouraged candidly to discuss his or her
+situation in order to explore the possibility of disposing of the case through a consensual
+rrangement. Such candid discussion will often include incriminating admissions ... T
+llow the government to introduce statements uttered in reliance on the rule would be ti
+use the rule as a sword rather than a shield. This we cannot allow; the rule was designed
+only as a shield.
+Id. at 797. "Where an otherwise acceptable construction of a statute would raise serious
+constitutional problems, the Court will construe the statute to avoid such problems unless such
+construction is plainly contrary to the intent of Congress ... The elementary rule is that every
+reasonable construction must be resorted to, in order to save a statute from unconstitutionality."
+DeBartolo Corp. I. Florida Gulf Coast Trades Council, 485 U.S. 568, 575 (1988).
+B.
+Recognition of a Privilege Under Rule 501.
+The Court rejected intervenors' contention that the Court should recognize a privilege for
+communications in the course of settlement/plea negotiations on the ground that Congress has
+9
+
+
+already addressed the issue in Fed. R. Crim. P. 11(f) and Fed. R. Evid. 410 and did not see fit to
+recognize a privilege for plea negotiation communications. Neither the Rules of Evidence nor
+the Rules of Criminal Procedure, however, have ever dealt with specifying the privileges which
+will and will not be recognized; instead, they leave that function to the courts under Rule 501.
+Nothing in Rules 11(f) or 410 suggest that Congress rejected (or even thought about) a privilege
+for attorney settlement/plea negotiation communications when framing those provisions. Rules
+11(f) and 410 deal only with what is admissible; they do not purport to extend to what is
+discoverable. Rule 410 begins with the assumption that a litigant is in possession of plea
+negotiation materials, and thus the Rule describes the circumstances in which those materials
+may either be admitted or excluded from consideration at trial. It says nothing, however, about
+whether a nonparticipant in the plea negotiations is entitled to obtain those materials in discovery
+in the first instance. That question must be answered by reference to Fed. R. Civ. P. 26, which
+refers to Federal Rule of Evidence 501, which "empower[s] the federal courts to 'continue the
+evolutionary development of [evidentiary] privileges.'" Adkins I. Christie, 488 F.3d 1324, 1328
+(11th Cir. 2007), quoting Trammel | United States, 445 U.S. 40, 47 (1980).
+The "central feature" of Rule 410 "is that the accused is encouraged candidly to discuss his
+or her situation in order to explore the possibility of disposing of the case through a consensual
+arrangement." United States I. Herman, 544 F.2d 791, 797 (5th Cir. 1977). The Rule is derived
+from "the inescapable truth that for plea bargaining to work effectively and fairly, a defendant must
+be free to negotiate without fear that his statements will later be used against him." Id. at 796. The
+legislative history, too, "shows that the purpose of Rule 410 and Rule 11(e)(6) is to permit the
+10
+
+
+unrestrained candor which produces effective plea discussions between the .... government and the
+... defendant." Committee on Rules of Practice And Procedure of The Judicial Conference of The
+United States, Standing Committee On Rules of Practice And Procedure, 77 F.R.D. 507
+(February 1978) (emphasis added). For these reasons, criminal defense lawyers negotiate with
+prosecutors in an environment of confidentiality, fostered by the protections of Rules 410 and 11.
+These rules encourage a process of searching and honest disclosures, and parties expect that their
+negotiations, and the information they exchange, will be protected from future use by an adversary.
+And because criminal defense lawyers are required, by ethical and constitutional considerations, to
+engage in plea negotiations to discharge their duty to represent the client's best interest, they do so
+with the well-founded expectation that communications made during those negotiations will not
+later be used to harm the client.
+The Supreme Court has recognized that "Rules 410 and 11(e)(6) 'creat[e], in effect, a
+privilege of the defendant
+.."" Mezzanatto, 513 U.S. at 204.This privilege encourages
+disposition of criminal cases by plea agreement, which is essential to the administration of justice:
+The disposition of criminal charges by agreement between the prosecutor and the accused,
+sometimes loosely called "plea bargaining," is an essential component of the administration
+of justice. Properly administered, it is to be encouraged. If every criminal charge were
+subjected to a full-scale trial, the states and the federal government would need to multiply
+by many times the number of judges and court facilities.
+Santobello I. New York, 404 U.S. 257, 260 (1971). "[T]he fact is that the guilty plea and the
+often concomitant plea bargain are important components of this country's criminal justice system.
+Properly administered, they can benefit all concerned." Blackledge I. Allison, 431 U.S. 63, 71
+(1977). Those
+sentiments are just as true today. The Bureau of Justice Statistics of the
+11
+
+
+Department of Justice reports that in 2005, 96.1% of federal criminal cases were resolved by way
+of a plea bargain. www.ojp.usdoj.gov/bjs/pub/html/tjsst/2005/tjs05st.htm. That today's justice
+system depends on plea negotiations is a monumental understatement.
+Whether to negotiate a plea or contest a criminal charge "is ordinarily the most important
+single decision in any criminal case." Boria I. Keane, 99 F.3d 492 (2d Cir. 1996). In the age of
+the Sentencing Guidelines, with the severe sentences called for in federal criminal cases, minimum
+mandatories, and the abolition of parole, engaging in meaningful and effective plea negotiations is
+perhaps one of the most important roles of a criminal defense attorney. Today, the lawyer's "ability
+to persuade the judge or the jury is ... far less important than his ability to persuade the
+prosecutor" during plea negotiations. United States I. Fernandez, 2000 WL 534449 (S.D.N.Y.
+May 3, 2000) at *1. Counsel's failure to discharge his duties during plea negotiations is
+malpractice: "[t is malpractice for a lawyer to fail to give his client timely advice concerning"
+pleas. Id. It also constitutes ineffective assistance of counsel, and violates the Constitution. Thus,
+counsel has a duty to advise clients fully on whether a particular plea is desirable, since "[e]ffective
+assistance of counsel includes counsel's informed opinion as to what pleas should be entered."
+United States I. Villar, 416 F. Supp. 887, 889 (S.D.N.Y. 1976); Boria I. Keane, 99 F.3d 492,
+497 (2d Cir. 1996), citing ABA Model Code of Professional Responsibility, Ethical Consideration
+7-7 (1992). Counsel also has a constitutional obligation to seek out information from the
+government, especially information that the government intends to use against the client. Failure to
+do so constitutes ineffective assistance of counsel. ain Rompilla I. Beard, 545 U.S. 374 (2005).
+12
+
+
+"The notion that defense counsel must obtain information that the state has and will use against the
+defendant is not simply a matter of common sense, ... it is the duty of the lawyer ...." Id. at
+387, citing 1 ABA Standards for Criminal Justice 4-4.1 (2d ed. 1982 Supp). The Constitution
+also requires that criminal defense lawyers conduct "a prompt investigation of the circumstances of
+the case," and this includes making every effort to secure information directly from the prosecutors:
+The Supreme Court has "long
+•.. referred [to these ABA Standards] as 'guides in determining
+what is reasonable.** Id. at 387.
+It is the duty of the lawyer to conduct a prompt investigation of the circumstances of the
+constituting guilt or the accused's stated desire to plead guilty.
+Id. at 386, citing 1 ABA Standards for Criminal Justice 4-4.1 (2d ed. 1982 Supp). The lawyer's
+duty to investigate and obtain information from the prosecutor goes hand-in-hand with the lawyer's
+additional duty to "make suitable inquiry" to determine whether valid defenses exist. Jones I.
+Cunningham, 313 F.2d 347 (4th Cir. 1963) ("Of course, it is not for a lawyer to fabricate
+defenses, but he does have an affirmative obligation to make suitable inquiry to determine whether
+valid ones exist"). And regardless of whether valid defenses exist, counsel has a duty to initiate plea
+negotiations if he is to discharge his duty to faithfully represent the client's interests. Hawkman I.
+Parratt, 661 F.2d 1161, 1171 (8th Cir. 1981)(counsel's "failure to initiate plea negotiations
+concerning the duplicitous felony counts constituted ineffective assistance of counsel which
+prejudiced Hawkman").
+Reason and experience tell us that the system we have in place of sentencing laws, ethical
+13
+
+
+rules, federal court dockets, and constitutional considerations, will not function if plea negotiations
+are not privileged. After all, "it is immediately apparent that no defendant or his counsel [would]
+pursue [plea negotiations] if the remarks uttered during the course of it are to be admitted in
+evidence as proof of guilt." Herman, 544 F.2d at 797. Plea negotiations are "rooted in the
+imperative need for confidence and trust," Jaffee I. Redmond, 518 U.S. 1, 10 (1996), and
+maintaining their confidentiality advances significant public and private ends. Discovery and use of
+plea negotiations will cause "a meaningful and irreparable chill" to the "frank and complete
+disclosures" that result in negotiated resolution of criminal matters. In re Air Crash Near Cali,
+Colombia, 957 F.2d at 1533. For these reasons, plea negotiations are properly subject to a
+common law privilege under Rule 501.
+II.
+THE SEVERE AND IRREMEDIABLE PREJUDICE TO INTERVENORS FROM
+DISCLOSURE OF THE COMMUNICATIONS
+The communications which would be disclosed under the Court's order were made by
+intervenor attorneys on behalf of their client, intervenor Epstein as part of a full, open, and frank
+negotiation with government counsel directed toward resolving the federal criminal investigation
+of Mr. Epstein on the most favorable terms possible. Those communications were made with
+complete confidence that their contents would remain confidential, known only to counsel for
+the government and intervenors, and would not be subject to possible future disclosure to third
+parties,
+certainly not to third parties seeking to use the contents of their attorney
+communications to harm their client. That belief was eminently reasonable and based on
+established practice and understandings regarding the confidentiality of such communications on
+which they relied in making
+communications. The attorney intervenors' decisions
+14
+
+
+regarding the content of the communications sent to the government in the effort to fulfill their
+professional and ethical obligations to their client - what to say, how much to say, when to say
+it, and how to say it - were made in reliance upon those communications not being disclosed
+outside the attorney-to-attorney settlement negotiation process. Indeed, for the reasons addressed
+in the preceding section, the settlement/plea negotiation process so central to our system of
+criminal justice cannot function in the absence of counsel's ability to represent their clients
+vigorously in pursuing a favorable resolution for them through confidential communications
+with government counsel.
+Now, without persuasive precedent, the Court has drastically reshaped the settlement
+negotiation landscape to retroactively eliminate the reasonable expectation of confidentiality
+generated by Rule 410 and the work product privilege, in reliance on which these
+communications were authored by competent and responsible attorneys, that settlement
+communications between counsel would remain confidential and not be subject to disclosure to
+third parties seeking to harm their client and ordering the disclosure of the communications to
+Mr. Epstein's civil adversaries. If such communications are ultimately found on appeal to be
+entitled to remain confidential under Rule 410 and the work product privilege and/or found to be
+subject to Rule 501 common law privilege, as intervenors have every confidence they will be,
+their disclosure in advance of appellate resolution of the important issues raised in this case will
+infliet immediate and completely irremediable harm on intervenors, as, if disclosure is not stayed
+pending appeal, the protections of privilege and confidentiality will have been irretrievably lost.
+What has been disclosed cannot be undisclosed and returned to its protected state; the damage
+against which privilege and confidentiality rules are designed to protect will have been done.
+15
+
+
+The value to intervenors of their appeal to the Eleventh Circuit would be entirely vitiated, as,
+absent a
+stay, a victory on appeal cannot ever undo the injury already caused. And the
+anticipated damage here is not simply limited to disclosure to plaintiffs and their counsel, serious
+as that damage would be; as past is prologue, there can be little doubt, based on the prior conduct
+of plaintiffs and their attorneys, that these communications, if disclosed to them, will quickly
+make their way into the public press for wide-ranging dissemination.
+Because it is impossible for appellate courts to undo the damage caused by forced
+disclosure of privileged or confidential communications or information, courts have consistently
+recognized that the harm caused by an erroneous order to disclose privileged or confidential
+information is irreparable. See, e.g., In re Professionals Direct Ins. Co., 578 F.3d 432, 438 (6th
+Cir. 2009)(finding risk of irreparable harm because "a court cannot restore confidentiality to
+documents after they are disclosed"); Gill 1. Gulfstream Park Racing Ass'n, Inc., 399 F.3d 391,
+398 (Ist Cir. 2005)("once the documents are turned over to Gill with no clear limitation on what
+he may do with them, the cat is out of the bag, and there will be no effective means by which
+TRPB can vindicate its asserted rights after final judgment"); In re Perrigo Co., 128 F.3d 430,
+437 (6th Cir.1997)("We find ... that forced disclosure of privileged material may bring about
+irreparable harm"); In re Grand Jury Proceedings, 43 F.3d 966, 970 (5th Cir. 1994) (forced
+disclosure of privileged documents would cause irreparable harm). The serious and irreparable
+injury to intevenors from the Court's order weighs profoundly heavily in favor of granting a stay
+pending appeal.
+Ill.
+THE ABSENCE OF PREJUDICE TO THE PLAINTIFFS.
+16
+
+
+In stark contrast to the severe risk of serious and irreparable injury which the failure to
+grant a stay pending appeal would cause to intervenors stands the clear absence of prejudice to
+plaintiffs if a stay is granted. The plaintiffs commenced this action in 2008; they did not even
+seek disclosure of the communications at issue until two and a half years later, in March, 2011
+(Doc. 51). Before doing so, plaintiffs had already moved for summary judgment (Doc. 48), a
+riling conveying plaintifs" belief that the record as it existed at that juncture was suficien
+demonstrate their entitlement to the requested relief. That motion remains pending, and no trial
+date has been set. Indeed, the plaintiffs knowingly sat on their CVRA claims for years as Mr.
+Epstein served a prison sentence in solitary confinement and as he satisfied all the requirements
+of his non-prosecution agreement. Rather than seek emergency relief from the Court, the
+plaintiffs appeared at a status conference on July 11, 2008, knowing that Mr. Epstein was in
+prison, and they told the Court that they saw no reason to proceed on an emergency basis.
+[Trans. July I1, 2008 at 24-25]. In a hearing one month later, the plaintiffs specifically asked
+that the Court not invalidate the non-prosecution agreement because they wanted to make sure
+not to undo any benefits they could gain from it. [Trans. August 14, 2008 at 4]. There will be no
+prejudice to plaintiffs from waiting until an appellate court can address the critically important
+issues at stake here. If they are entitled to relief - something intervenors strenuously deny - they
+will obtain it, and the timing of that relief matters little, if at all. Having been in no hurry to seek
+rescission of the non-prosecution agreement, plaintiffs should not now be heard to contend that
+the time awaiting appellate resolution really matters.
+To the extent that communications authored by Mr. Epstein's counsel and sent to federal
+prosecutors during settlement negotiations could ever, arguendo, be deemed relevant to
+17
+
+
+plaintiffs' action against the government for alleged breaches of their rights under the CVRA, a
+dubious proposition at best, any such relevance could be no more than tangential. Plaintiffs
+already know full well what the government did or did and did not do with respect to
+communicating with them during the course of the negotiations; the communications of Mr.
+Epstein's counsel could add little, or, more likely, nothing to the plaintiffs' quantum of proof.
+Moreover, the government has made it abundantly plain that, whatever the outcome of
+this litigation, the agreement it made with Mr. Epstein will stand. Indeed, controlling Supreme
+Court case law prevents it from doing otherwise. Mr. Epstein has fully performed his side of the
+bargain with the government, and when a bargain is based on a promise or agreement of the
+prosecutor, so that it can be said to be part of the inducement or consideration, such promise
+must be fulfilled." Santobello |. New York, 404 U.S. 257 (1971). Failure to enforce the
+government's side of a plea bargain violates Due Process. United States Il. Yesil, 991 F.2d 1527,
+1532-33 (11th Cir. 1992). Mr. Epstein has a Due Process right to the continued specific
+performance and enforcement of the non-prosecution agreement. United States I. Haber, 299
+Fed. Appx. 865, 867 (11th Cir. 2008). Rescission of the non-prosecution agreement at this
+juncture would, moreover, undermine Mr. Epstein's reasonable expectations of finality in a
+contract into which he entered with the government, a particularly inequitable result where it was
+the government, alone, which had duties to third parties under the CVRA. Relying on the nonprosecution agreement, Mr. Epstein served his state sentence in a county jail, served community
+control probation, paid huge legal fees under his obligation to the attorney representing certain
+3 The Court's order expressly did not rule on whether any particular piece of correspondence
+was relevant or admissible. Doc. 188 at 10.
+18
+
+
+alleged victims who were relying on the non-prosecution agreement to seek damages under 18
+U.S.C. §2255, and paid civil
+settlements to these claimants because the non-prosecution
+agreement precluded his contesting liability. The rescission remedy sought by plaintiffs could
+never restore
+the status quo to Mr. Epstein or to the third-party beneficiaries of the
+agreement. Other civil settlements would also not have occurred but for the non-prosecution
+agreement." Even if the Court could validly set aside the non-prosecution agreement based on the
+alleged violations of the CVRA, which intervenors maintain that it cannot, although they
+acknowledge that the Court has ruled otherwise (Doc. 189), the ultimate result under both
+contract and constitutional law would be the re-entry of the non-prosecution agreement after
+compliance by the government with its obligations under the CVRA. The confidentiality and
+privilege rights of intervenors should not be destroyed, as they would be by the failure to grant a
+stay pending appeal, for so little reason.
+IV.
+THE PUBLIC INTEREST.
+There is no interest of the public which will be harmed by the granting of the requested
+stay. Ordinarily the public may have little interest at all in a dispute between private civil
+litigants regarding access to documents. IThe public does, however, have a great interest in the
+fair conduct of plea negotiations - an interest that is profoundly affected by the Court's Order of
+June 18, 2013. Since more than 95% of all criminal cases are resolved by pleas, the public must
+have an interest in how the courts function in regard to pleas. The public needs to see that justice
+not only is done but appears to be done in the courts and would likely regard the Court's new
+* In addition, the State Attorney relied on the non-prosecution agreement when returning a
+criminal charge that resulted not from the actions of the grand jury but instead as a corollary of
+the non-prosecution agreement.
+19
+
+
+rule of disclosure to private litigants as introducing injustice and unfairness into the
+settlement/plea negotiation process. The public's interest strongly lies in awaiting appellate
+resolution of the important issues raised in this case before forcing disclosure of documents
+which there is a substantial likelihood the appellate court will rule are not subject to disclosure
+and where the implementation of an un-stayed district court order will risk a change in the way
+draf
+in which attorneys provide effective assistance of counsel to defendants in the pivotal plea
+bargaining stages that are at issue in this matter.
+20
diff --git a/vision-fixhub/ds9-unparsed-06/3ee7c85050c340528db5cc0df28a930c1f6fbb4ab5019ca06ce0466884e1b43d.receipt.json b/vision-fixhub/ds9-unparsed-06/3ee7c85050c340528db5cc0df28a930c1f6fbb4ab5019ca06ce0466884e1b43d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..82402bd450e0a50ede4297011ffd8cd40fa7fb5c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3ee7c85050c340528db5cc0df28a930c1f6fbb4ab5019ca06ce0466884e1b43d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -242,
+  "dataset": "marble-joined",
+  "doc_id": "3ee7c85050c340528db5cc0df28a930c1f6fbb4ab5019ca06ce0466884e1b43d",
+  "engine": "marble-apple-vision",
+  "event_count": 21,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "01e8e8503bd3116e09a595777ff3290713816c6d8b01905abe80c667e157c808",
+  "output_sha256": "fa601c920ab33783f565774782a40206295860fdaa7307c716e7d9d0b9103310",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3f9aa42e9c5b8aa4f3831a3e4633cf479b14336e336e14a024d15d8c7a9bcf75.md b/vision-fixhub/ds9-unparsed-06/3f9aa42e9c5b8aa4f3831a3e4633cf479b14336e336e14a024d15d8c7a9bcf75.md
new file mode 100644
index 0000000000000000000000000000000000000000..196daa45fc48eb35b42e0ade27272ee3b9cea382
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3f9aa42e9c5b8aa4f3831a3e4633cf479b14336e336e14a024d15d8c7a9bcf75.md
@@ -0,0 +1,2301 @@
+Questions or Changes?
+• attwireless.com
+Toll Free 1 866 293-4634
+611 from your wireless phone
+• TTY users - 1 866 4-AWS-TTY
+SUMMARY OF MONTHLY CHARGES FOR ACCOUNT 0031035751
+Previous
+Payments
+Account
+Balance
+Received
+Adjustments
+69.50
+-69.50
+0.00
+Balance
+Forward
+0.00
+Your billing cycle ended on April 14, 2004
+Current Monthly Charges
+Subscriber Adjustments
+Monthly Service
+Monthly Usage
+Charges
+Credits
+Taxes, Surcharges & Regulatory Fees
+Total Current Monthly Charges DUE UPON RECEIPT
+TOTAL AMOUNT DUE
+Date of Invoice: April 15, 2004
+Current Monthly
+Charges
+86.01
+Total
+Amount Due
+86.01
+0.00
+54.97
+16.35
+0.00
+0.00
+14.69
+86.01
+86.01
+PLAY GAMES FOR FREE!*
+DOWNLOAD GREAT GAMES AND PLAY FREE FOR A WEEK.
+GET ALL TYPES OF GAMES - FROM CARD GAMES AND
+PUZZLES TO SPORTS AND ACTION GAMES.
+GO TO ATTWIRELESS.COM/GAMEOFFER
+ON YOUR PC TO FIND OUT MORE.
+*NOTE: OFFER AVAILABLE FOR LIMITED TIME AND LIMITED
+HANDSETS. STANDARD DATA CHARGES APPLY FOR DOWNLOADS.
+AT&T WIRELESS APPRECIATES YOUR BUSINESS
+2 ATST Wireless
+Account Name: |
+Note: =>
+We Print on
+Front and Back
+Service # 5613797824
+Account # 0031035751
+Total
+Amount Due
+86.01
+Chack her for charge.
+Amount
+Paid
+#BWNHNGB
+#0000000310357512# w
+2003069 02 AT 0.517 "AUTO TO 0 041433411.S.42.01.1034.0000
+Yes ataly deduled from accounto my closed check
+see reversé - signature required
+Date Due
+UPON RECEIPT
+AT&T WIRELESS
+PO BOX 8229
+AURORA IL 60572-8229
+0000000000•0•00000003103575120000000086013
+
+
+REFT (Recurring Electronic Fund Transfer): To enroll: sign below, check the REFT box on the reverse side and
+remit with this month's payment. Keep paying your bill until your statement indicates "Do Not Pay."
+REFT Agreement: 1 authorize my financial institution to deduct the amount of my monthly wireless phone bill from
+the account associated with the enclosed check and remit payment to AT&T Wireless. This authority will be
+effective until | notify AT&T Wireless to terminate it. I agree that I may be assessed a service charge (up to $20) or
+late fee or both if a payment is returned by my bank. For more information visit attwireless.com or call 1 866
+293-4634.
+Questions? We can help: AT&T Wireless appreciates your business and welcomes the opportunity to assist you.
+As part of our commitment to you, we are always adding new calling plans and promotions to match your individual
+needs. Visit our website at attwireless.com or contact our Customer Care at 1 866 293-4634 or dial 611 from your
+wireless phone. ¿Sabias que también ofrecemos servicio al cliente en tu idioma? Marca 611 desde tu teléfono
+inalámbrico, o 1 866 293-4634 desde cualquier teléfono y oprime el *.
+Driving Wireless Safety: Your wireless phone gives you the freedom and flexibility to stay in touch when you
+travel, but don't let a phone call distract you from driving safely. Use hands-free device if allowed or required by
+law. Call Carefully, Arrive Safely.
+AT&T Wireless Processing Fees: Accounts suspended for non-payment will be subject to a $25 reactivation fee
+per line and may be assessed a security deposit prior to reinstatement. Checks returned for non-sufficient funds will
+be charged up to a $20 fee.
+Local Tax: Local taxes are based on local government boundaries, the address information you provide for your
+account and/or your wireless telephone number. Please review the local tax charges on your bill. If you believe
+there is an error in the local tax charge, please contact us immediately at 1 866 293-4634. Please note that some
+local or state laws may require you to follow special procedures when notifying us about a local tax dispute. You
+may also use the form below to notify us of any change to your taxing address. Thank you for your cooperation
+Please Send Correspondence To:
+AT&T Wireless Next Generation Correspondence
+P.O. Box 68056
+Anaheim Hills, CA 92817-8056
+2003089.000022444.7
+Change of Address Only. Please print address clearly and check the box on the reverse side. Please contact Customer Care to change the
+Name and transfer Financial Responsibility.
+New Billing Address
+City
+State
+Zip
+Home Phone (
+Work Phone (.
+If your billing address is NOT your Tax Address*, please enter the Tax Address below. (Multi-line accounts should attach a list of each wireless number and
+the respective Tax Address.)
+New Tax Address*
+Wireless Number (
+City
+State
+Zip
+Under Federal laws, your Tax Address must be: your primary place of use, your residential or business address, and located within AT&T Wireless
+censed service area. Non-business customers on AT&T Digital One Rate, Regional Advantage or Shared Advantage plans must use their residenti
+address as their tax address.
+Recurring Electronic Fund Transfer (REFT) Enrollment. Please read the agreement on the top portion of this page, sign below and check the
+"REFT Registration" box on the reverse side.
+6.1 - 3G
+Financial Account Holder Signature
+• I do not wish to receive email notilication of special ofers avalable to AT&T Wireless customers.
+
+
+
+ON 6/1/04, WE'RE MAKING IMPROVEMENTS TO OUR ONLINE
+CUSTOMER CENTER AND MMODE ACCOUNT ACTIVITY IN ORDER TO
+PROVIDE YOU WITH MORE UP TO DATE INFORMATION ABOUT YOUR
+DATA USAGE. DATA USAGE WILL BE ROUNDED AND RATED HOURLY
+IF YOUR USAGE EXCEEDS 10 KB DURING THAT TIME PERIOD.
+YOUR DATA USAGE WILL BE RATED AND BILLED AT LEAST ONCE
+EVERY 24 HOURS EVEN IF USAGE DOES NOT REACH 10 KB. FOR
+DETAILS VISIT HTTP://SUPPORT.ATTWIRELESS.COM/RATING/
+IMPORTANT ACCOUNT INFORMATION:
+IF YOU CANCEL SERVICE BEFORE YOUR CONTRACT END DATE
+(INCLUDING IF YOU SWITCH YOUR WIRELESS NUMBER TO
+ANOTHER CARRIER), YOU WILL BE CHARGED AN EARLY
+TERMINATION FEE OF UP TO $200.
+ACCOUNT DETAILS
+Detail of Payments - Thank You!
+Item Description
+Date Applied/Reversed Payment Amount
+Total of Payments
+Current Subscriber Monthly Charges and Credits
+Subscriber Number
+Total Current Monthly Charges
+SUMMARY OF CURRENT ACTIVITY
+Monthly Service Charges
+1 CALL WAITING
+2 AT&T TEXT MESSAGING
+3 CALLER ID
+4 AT&T VOICEMAIL
+5 DETAIL BILLING
+6 $39.99 CHARTER OFFER
+7 1000 NIGHT AND WEEKEND MINUTES
+03/15/04 - 04/14/04
+03/15/04 - 04/14/04
+03/15/04 - 04/14/04
+03/15/04 - 04/14/04
+03/15/04 - 04/14/04
+03/15/04 - 04/14/04
+03/15/04 - 04/14/04
+-69.50
+86.01
+86.01
+0.00
+4.99
+0.00
+0.00
+0.00
+39.99
+9.99
+
+SUMMARY OF CURRENT ACTIVITY - CONTINUED
+Monthly Service Charges - Continued
+8 CALL FORWARDING
+9 THREE WAY CALLING
+Monthly Usage Charges
+1 500 ADD'L ANYTME MIN
+2 100 INCL. MSGS SENT
+3 MESSAGE RETRIEVAL
+4 1000 NIGHT/WKEND MIN
+5 CALL WAITING
+6 AT&T CONNECT
+7 CALL COMPLETION
+8 INCLUDED MINUTES
+9 TEXT MESSAGES SENT
+10 DROP CALL CREDIT
+11 ADDITIONAL MINUTES
+12 INCL. IN PLAN DATA
+1,024 Kilobytes (KB) = 1 Megabyte (MB)
+Taxes, Surcharges and Regulatory Fees
+1 UNIVERSAL CONNECTIVITY CHARGE
+2 STATE COMM SERVICE TAX
+3 LOCAL COMM SERVICE TAX
+4 COUNTY 911 TAX
+5 FEDERAL TAX
+03/15/04 - 04/14/04
+03/15/04 - 04/14/04
+500 MIN
+100 EVT
+33 EVI
+881 MIN
+22 EVT
+2 EVT
+2 EVT
+500 MIN
+61 EVT
+31 MIN
+4 KB
+0.00
+0.00
+0.00
+0.00
+0.00
+0.00
+0.00
+2.50
+0.00
+0.00
+6.10
+0.00
+7.75
+0.00
+1.80
+6.68
+3.81
+0.50
+1,90
+DETAIL OF CURRENT ACTIVITY
+VOICE USAGE FOR (561)379-7824
+2 0315 12-1FP (861)827-493
+0315 12-18P (561)236-329
+03/15 02:18P (561315-747
+9 03/13 02.22P 381 879-6422
+8 03/15 02:27P (561)379-6422
+• 03/15 02:30F
+10 03/15 03:46P (561)792-637:
+I1 03/15 03:47P
+12 03/15 05:39P (561)379-7824
+NORBEACH F
+AKE WORTH F
+WPALMBEACH FL
+COMIN
+VPALMBEACH F
+INCOMING
+WPALMBEACH FL
+THING
+2MIN
+SO ADEL ANTHE MIN
+ABBE
+ADD'L
+HERE RETREATE
+
+
+2003069.000022445
+
+Item Date Time
+Called
+Onty
+Used
+14 83/15 06:04P
+(82730-2742
+15 03/15 06:05P
+(772 219-4743
+9 03/13 06:18P 1961662-212
+3/15 06:18
+18 03/15 06:22P
+20 03/15 06:43P (561)236-3299
+03/15 06:45P
+(877)746-9244
+24
+87:18P
+•18P
+877)746-924
+61|236-329
+03/15 07:18P
+561)309-1375
+Calls To
+BELRAY BCH FL
+STUART FL
+WRA MACH FAL
+WPALMBEACH FL
+WPALMBEACH FI
+ICOMIN
+Toll Free CL
+W ALMBEACH EL
+WPALMBEACH FL
+03/15 87:360
+11236-328
+:11236-324
+27
+03/15 08:21P
+28
+03/15 08:23P
+29
+(561)792-6375
+03/15 09:29P
+(561)792-6375
+03
+/15
+09:30P
+(561)379-7824
+COMIN
+PALMBEACH F
+WPALMBEACH FL
+WPALMBEACH FL
+(561)315-7476
+)317-2428
+(581)
+chon
+(561)
+379.
+-6422
+vún c vón vvă
+M480BRPRẢ
+Ґữuüďťťťť …
+LEUUUU
+2MIN
+2MIN
+2MIN
+16MIN
+MIl
+MIl
+MIl
+....
+Rate Description
+500 ABB'L ANYTME MIN
+500 ADD'L ANYTME MIN
+00 ADD'L ANYTME MI
+O ADD'L ANYTME MI
+500 ADD'L ANYTME MIN
+SOO ABB ANIME MIN
+500 ADD'L ANYTME MIN
+J0 ADD'L ANYTME MI
+I0 ADD'L ANYTME MI'
+500 ADD'L ANYTME MIN
+D ADD'L ANYTME MI
+
+Item Date Time
+Called
+Calls To
+03/18 03:4
+80 03/18 03:48P (561|236-3299
+03/18 03:55P (561)315-74
+83 03/18 05:02P (561)236-3299
+85 03/18 05:04P (561)827-4493
+83 03/18 0535P (561)379-6422
+89 03/18 06:10P
+91 03/18 09:18P (561)315-7476
+93 0319 91:044
+94
+
+
+hàn hn chà c t ci
+
+
+và à à qà và qà và qú qầ
+-02 02
+D LC
+(561)315-7476
+(561)792-
+-6375
+56
+113
+02 gr
+WPALMBEACH FL
+AKE WORTH FI
+NCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+AKE WORTH F
+JCOMIT
+NOOMING
+
+WPALM
+NOOMIN
+Onty
+Used
+IMIN
+3MIN
+I MIN
+I MIN
+TAIN
+2MIN
+.....!
+Rate Description
+500 ABB'L ANYTME MIN
+500 ADD'L ANYTME MIN
+500 ABB'L ANYTME MIN
+500 ADD'L ANYTME MIN
+500 ADD'L
+_ ANYTME MIN
+00 ADDL ANYTME MIN
+500 ADD'L ANYTME MIN
+OO ADD'L ANYTME MIN
+OO ADD'L ANYTME MIN
+500 ADD'L ANYTME MIN
+00 ADD'L ANYTME MIN
+000 NIGHT/WKEND MIN
+1000 NIGHT/WKEND MIN
+500 ADD'L ANYTME MIN
+*24530
+
+
+
+Item Date Time
+Called
+142 03/20 07:20₽
+145 03/20 03:15P (561)601-6282
+146 03/20 03:30P (561)313-1542
+148 03/20 04:04P
+149 03/20 04:45P
+50 03/20 04:48P (561)315-7476
+151 03/20 04:53P
+152 03/20 04:53P
+153
+03/20 05:29P
+154
+03/20 05:32P
+155 03/20 05:32P
+Calls To
+COMIN
+COMIN
+LAKE WORTH FL
+INCOMING
+LAKE WORTH FL
+NCOMING
+ICOMINC
+AKE WORTH FI
+INCOMING
+NCOMING
+INCOMING
+INCOMING
+INCOMING
+159 03/20 08:37P
+: 861733-0768
+158
+03/
+20
+(561)753-0169
+VPALMBEACH F
+YPALMBEACH FI
+WPALMBEACH FL
+
+N C H ÀNT TÀ H TÀ HÀ TÀ TÀ TÀ T TÀ TÀ TÀ TÀ TÀ TÀ TÀ TÀ T T T T TẤ
+(561)358-5498
+(561)379-6422
+12:19A
+12:28A (561)379-6422
+1235A
+NOOMING
+WPALMBEACH FL
+INCOMING
+VPALMBEACH F
+ICOMI
+NOOMING
+11:05A
+(561)379-6422
+IN
+(561)798-8807
+ICOMIÍ
+11:34A
+==
+(561)379-6422
+1:344
+(561)379-6422
+FL
+FL
+(561)379-6422
+WPALM
+15P
+..........
+(561)662-6615
+(561)379-6422
+(561)315-7476
+(561)792-6375
+INCO
+INCO
+(561)379-6422
+5611315-7476
+Bogggus
+(561)79
+15-
+-7774
+(561
+)315-7476
+Qnty
+Used Rate Description
+MIR
+1000 NIGHT/WKEND MIN
+DO NIGHT/WKEND M
+DO NIGHT WKEND M
+1000 NIGHT/WKEND MIN
+DOO NIGHIEWKEND MI
+DO0 NIGHT/WKEND MI
+1000 NIGHT/WKEND MIN
+DO NIGHT/WKEND M
+DO NIGHT/KEND M
+1000 NIGHT/WKEND MIN
+1000 NIGHT/WKEND MIN
+CALL WAITING
+D0 NIGHT/WKEND M
+DO NIGHT WKEND M
+END
+8 888888888888888888888888888888888888
+
+Item Date Time
+Called
+Calls To
+39 03/21 87:13P 961379-64
+o noir
+210 03/21 07:22P
+INCOMING
+03/21 07:24P
+03/21 07:30₽
+3 03/21 07:31P (561)379-6422
+214 03/21 07:32P (561)798-8807
+215 03/21 07:32P (561)798-8807
+216 03/21 07:34P
+03/21 07:54P (561)310-6943
+03/21 07:57P
+03/
+121
+07:57P
+32. 08:006 (561)309-137
+1 08:01
+/21
+08:03P
+/21 08:04P (5611310-6943
+WPALMBEACH FL
+WALNEACHL
+INCOMING
+WPALMBEACH FL
+NGOMING
+INCOMING
+VPALMBEACH FI
+NCOMING
+NOOMIN
+VPALMBEACH F
+/21
+08:06P
+Onty
+Used
+Rate Description
+O NGHTWKENBN
+1000 NIGHT/KEND MIN
+DD NIGHT/WKEND M
+IMIN
+DO NIGHTWKEND M
+1000 NIGHT/KEND MIN
+OOD NIGHTEWKEND MIN
+ODO NIGHT/KEND MIT
+1000 NIGHT/KEND
+J0 NIGHWKEND
+1000 NIGHT/KEND MIN
+J00 NIGH PVVKEND M
+DO NIGHT/WKEN
+1 MN
+00 NGH-KENR M
+NIGHTAWKEND M
+10
+HIN
+8888
+NANS
+8888
+
+NNNNANNNNNNNNNNNNNNNNNN
+03
+120
+BARANONONONNNONNNE
+
+18888 358
+1326
+tripo
+1992-
+(305)
+)555-
+-1212
+(407)
+)884
+-2009
+ěẻěě9ě9ě§
+FL
+es003gcgg0geg
+2003069.000022446
+
+
+2003069.000022446
+
+Item Date Time Called
+Onty
+Used
+271 03/22 08:57P (561)753-0169
+272 03/22 09:12P (561)601-6282
+273 03/22 09:12P
+274฿
+03/22 09:16P
+5611601-6282
+5611601-6282
+275 03/22 09:42P (561|601-6282
+276 03/22 09:44P
+03/22 10:06P (7701657-1020
+278 03/22 10:07P (706|593-8744
+279)
+280
+83/22 11:20P (561|662-6615
+281 03/22 11:23P
+93/23 1723A (561)315-7476
+93/23 0909A
+Calls To
+WPALMBEACH FL
+LAKE WORTH FL
+LAKE WORTH FL
+LAKE WORTH FL
+LAKE WORTH FL
+INCOMING
+ATLANTA NW GA
+COLUMBUS GA
+WPALMBEACH FL
+INCOMING
+INCOMING
+AKE WORTH F
+COMIN
+NOOMING
+COMING
+IMIN
+4 MIN
+2MIN
+EMIN
+286 03/23 09:04A (561)317-2428
+(561)792-6374
+56
+(561)662-6615
+88888888888 8 8 9899989
+121
+88888 g933333399ggggg9393.33989333
+08:0
+08:06A
+08:10A
+SCRE
+00008
+(561)795-7774
+561 379-7824
+1792-6375
+0-6942
+Rate Description
+INCOMING
+WP.
+ALI
+WPALA
+EACH
+WPALMB
+MPAIN
+FL
+*24540703D00*
+IN
+OFF-MA
+8MIN
+FFFFV-
+1000 NIGHT/KEND
+SHT/WKEN
+1000 NIGHT/KEND
+OD NIGHT/WKE!
+0O NIGHT WKEN
+1000 NIGHT/KEND
+O0 NIGHT/WKEN
+DO NIGHTAWKE:
+1000 NIGHT/KEND
+DO NIGHT/WKEN
+!!!!!
+DD'L ANYT
+00 ADD'L ANYT
+X ADD'L ANYTME MIl
+sssssssa888S88SSSSS8S8888SSSSS888888{88888{88Ï>
+Onty
+Calls To
+
+Item Date Time Called
+334 03/24 08:25A (351)319-7824
+335 03/24 08:30A (561)379-7824
+336 03/24 08:37A (561)317-2428
+398 03/24 08 37A 581 286-5239
+339 03/24 09:09A (561)310-6943
+340 03/24 09:11A (561379-7824
+341 03/24 11:12A (5611315-7476
+343 03/24 11 38A (561)317-2428
+14 03/24 12:31
+5 03/24 12-41
+346 03/24 12:42P
+
+P558888888
+8888888888888 88 8 88 88 8 88 8 88 8 88 8888
+)236
+3299
+1792-
+88
+07 02 C
+BRRRR
+88
+WPALMBEACH FL
+WPALMBEACH FL
+WALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+LAKE WORTH FI
+WPALMBEACH FL
+NCOMING
+COMING
+COMIN
+INCOMING
+Used Rate Description
+SMIN
+500 ABBL ANYTE MIN
+1 EVT
+MESSAGE RETRIEVAL
+3 MIN
+EMIN
+500 ADD'L ANYTME MIN
+500 ABBIL ANYTME MIN
+500 ADD'L ANYTME MIN
+) ADD'L ANYTME N
+SSAGE RETRIEV
+500 ADD'L ANYTME MIN
+500 ABBL ANYTME MIN
+00 ADDL ANYIME MI
+0 ADD'L ANYTME MI
+500
+
+
+
+Item Date Time
+Called
+393 03/26 06:29P
+394 03/26 06:31P (561)315-7476
+395 03/26 06:32P (561)791-3394
+396 03/26 08:07P
+397 03/26 08:11P (561)662-7668
+398 03/26 08:59P
+399 03/26 09:40P
+400 03/26 10:01P
+401
+03/26
+402 03/
+10:06P
+(561)791-3394
+03/
+126
+10:23P
+403
+126
+(561)662-7668
+10:27P (561)662-2721
+404|
+03/26 10:28P
+405
+03/
+26
+10:30P (561)315-7476
+Calls To
+INCOMING
+LAKE WORTH FL
+WPALMBEACH FL
+NCOMING
+WPALMBEACH FL
+NCOMING
+COMING
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+AKE WORTH FL
+406 03/26 11:10P (305)555-1212
+407 03/26 11:11P (407)886-4231
+APOPKA FL
+Qnty
+Used Rate Description
+
+7808฿4
+
+
+49830
+56
+379.
+-6422
+«ийии £ґЕ
+moon choo
+I WAITIN
+INCLUDED MINUTES
+3 MIN
+NCLUDED MINUTES
+3 MIN
+NCLUDED MINUTES
+INCLUDED MINUTES
+INCLUDED MINUTE:
+1000 NIGHT/WKEND MIN
+1000 NIGHT/WKEND MIN
+AMIN
+DO NIGHTWKEND A
+O NIGHTWKEND M
+1000 NIGHT/WKEND MIN
+2MIN
+000 NIGHT/KEND MI
+DO NIGHT WKEND MIN
+000 NIGHT/WKEND MIN
+TEVT 1.25 AT&T CONNECT
+1001
+....
+1.25
+Item Date Time
+Called
+Calls To
+156 03/28 12:04P (S61/201-6282
+457 03/28 12:09P (561)798-8807
+WPALMBEACH FL
+158 03/28 12:11P (561)790-1060
+159 03/28 12:16P (407|886-4231
+460 03/28 12:56P (561j379-7824
+WPALMBEACH FL
+461 03/28 01:39P (561)324-9012
+462 03/28 01:40P (561|324-9012
+163 03/28 0220P 807888-5651
+465 03/28 03:20P (407)886-4231
+466 03/28 03:20P (561)379-7824
+467 03/28 03:20P
+468 03/28 03:21P (561)379-7824
+VPALMBEACH F.
+MPALMBEACH FI
+AKE WORTH P
+OPKA P
+APOPKA FL
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+5 MIN
+1 EVT
+EVT
+EVT
+2MN
+476
+3:24P
+8888
+8888
+5000
+03:
+
+
+1M..0
+(561)379-
+08:1
+6A
+561)37
+70-
+489
+
+702
+7E
+(561)
+2
+3391
+- mu
+Onty
+Used
+Rate Description
+WPALMBEACH FL
+ACH
+ACH
+25
+
+ILI
+TAL
+D MIN
+
+
+
+2003069.000022447
+
+Item Date Time Called
+12 03/28 07 35B (561)792-637
+514 03/29 09:08P (561)379-6422
+Calls To
+PALMBEACH I
+COMIN
+WPALMBEACH FL
+• U3/28 U8.1E
+(561)315-7476
+6 03/29 09-24
+611309-1375
+517 03/29 09:25P (561|309-1375
+WPALMBEACH FL
+8 03/29 09:37
+/29 10:17P (561)379-782
+Onty
+Used
+1 EVT
+520 03/28 10:33P (854253-1444
+522 03/29 10:49P
+FTLAUBERBL FL
+INCOMING
+23 03/30 06:37A
+03/30 07:24A (561)317-2428
+525 03/30 07 49A 561379-7824
+526
+03/30
+08:19A
+
+
+158128-2399
+(561)792-6375
+(561)379-6422
+(561)255-7643
+1587)
+1378-
+-7020
+EA
+EA
+535
+03/30 02:42P
+(561)379-7824
+-0480
+WPALN
+WPALMBEACH FL
+VPALM
+3299
+-6375
+
+.......
+(561)791-3394
+WP
+Al
+INC
+COMING
+BEACH FL
+MING
+OMING
+OMING
+IP
+ALMBEACH
+WPALMBEACH
+INCOMING
+*24550704D00+
+Rate Description
+INCLUBED MINUTES
+1000 NIGHT/KEND
+TAWKEN
+1000 NIGHT/KEND
+1000 NISHTWKEND MIN
+MESSAGE RETRIEVAL
+1000 NIGHT/KEND MIN
+INCLUDED MINUTES
+ESSAC
+THAN
+
+Onty
+Item Date Time Called
+Calls To
+Used Rate Description
+573 03/31 04:29P (561)801-3590
+PALMBEACH F
+COMING
+INCLUBEB MINUTES
+576 03/31 05:15P (561)791-3394
+WPALMBEACH FL
+INCLUDED MINUTES
+7 03/31 05:17P (561)309-137
+CLUDED MINUTI
+8 08/31 06 51P 561236-321
+PALMBEAC
+LUDED MINUTI
+579 03/31 06:55P
+580 03/31 07:04P (5611379-7824
+INCOMING
+INCLUDED MINUTES
+WPALMBEACH FLI
+MESSAGE RETRIEVAL
+581 03/31 07:06P (561)379-7824
+WPALMBEACH FL
+INCLUDED MINUTES
+ESSAGE RETRIEVA
+WPALMBEACH FL
+CLUDED MINUTE
+LAKE WORTH FL
+INCLUDED MINUTES
+KE WORTH.
+I MIN
+›ALMBEACH
+VIN
+GLOBER MINT
+I MINUTE
+COMIN
+PALMBEACH F
+CLUDED MINUTE
+) MINUTE
+FL
+582 03/31 07:07P (561)792-6375
+583 03/31 07:39P 561601-6282
+584 03/31 87.42P 581579-6232
+587 03/31 07:43P
+03/31 07:44P (561)310-6943
+588 03/31 07:44P (561310-6943
+8888886 8888888888
+117-
+2428
+(561)902-7339
+(561)795-0859
+(561)902-7339
+12 0202
+220
+бõõõ55õ5§
+3:988939
+(561)379-7824
+(561)324-1517
+BRRE
+бõõõõ5õ558558888888
+
+(561)
+1902-7339
+(561)
+1313-5654
+)379-6422
+FL
+INCOMING
+INCOMING
+NCOMING
+NOOM NC
+4 MIN
+NCLUD
+IN BEE
+NCLUD
+NCLUD
+NUTES
+INCLUD
+VCLUD
+ED
+INCLU
+INCLUD
+INCLU
+NC
+NUTE
+NUTE
+
+
+
+Item Date Time
+Called
+35 04/02 11:11
+36 04/02 11:30А (561)801-359
+637 04/02 12:14P
+638 04/02 01:22P
+639 04/02 04:14P
+640 04/02 05:01P
+(561)310-6943
+641 04/02 05:30P
+642 04/02 05:38P 661385-3428
+643 04/02 05:50P
+04/02 05:51P
+646 04/02 06:01P
+(561)379-6422
+647 04/02 06:92P
+61282-889
+09-137
+648 04/02 06:33P
+650฿
+161|310-694
+611902-733
+651 04/02 06:38P
+(561)662-7668
+
+:51P
+561)753-0169
+5611902-7330
+:08:17P
+08:15
+83308
+
+753-01
+·28-9
+Calls To
+COMING
+NPALMBEACH FL
+INCOMING
+INCOMING
+INCOMING
+WPALMBEACH FL
+PALMBEACH
+•ALMBEACH
+INCOMING
+INCOMING
+INCOMING
+WPALMBEACH FL
+WALMBEACH EL
+WPALMBEACH FL
+PAHOKEE FI
+WPALMBEACH FL
+COMING
+COMIN
+INCOMING
+NCOMING
+INCOMING
+INCOMING
+WPALMBEACH FL
+PAHOKEE FL
+INCOMING
+WPALMBEACH
+99!
+
+N
+
+88888
+
+ALM
+23
+310-6943
+VPAL
+(561)310-6943
+•CAD
+(561)714-5714
+10:03A
+(561)902-7339
+(561)902-7339
+--------
+
+4369
+1802-
+:48P
+11:52P
+236-2293
+561 379-7824
+680
+686
+687
+
+/03
+13.00A
+688
+689
+04/
+(561)902-7339
+561)308-9208
+5611309-1375
+01:17A
+690
+691
+692
+693
+88888
+01
+1:20
+02:07A
+02:52A
+02:57A
+(561\317-2428
+694
+08:33A
+695
+04.
+03
+:33A
+561,393
+- 7922
+697
+598
+8888
+:37A
+561|310-6943
+:59A
+(561|236-3299
+09:17A
+INCOMING
+РАНОКЕЕ
+РАНОКЕЕ
+PANSKEE
+ДАД7
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+MPAI MRFACH C
+INCOMING
+INCOMING
+РАНОКЕЕ FL
+INCOMING
+WPALMBEACI
+МРДІ МРЕДСН
+INCOMING
+INCOMIN
+WPALMBE
+РАНОКЕЕ
+WPALMB
+EACH
+PALMB
+ACH
+INCOMING
+NCOMIN
+NPALMBEACH FI
+Qnty
+Used
+Rate Description
+CLUDED MINUT
+LUDED MINUT
+INCLUDED MINUTES
+ICLUDED MINUTE
+ICLUDED MINUTE
+INCLUDED MINUTES
+NCLUDED MINUTE:
+VOLUDED MINUTES
+INCLUDED MINUTES
+3MIN
+INCLUBED MINUTES
+2MIN
+INCLUDED MINUTES
+3 MIN
+ICLUDED MINUTE
+) MINUTE
+INCLUD
+NOLUI
+INCLU
+1000
+
+Onty
+Item Date Time
+Called
+Calls To
+Used
+Rate Description
+00 040309:37 561371-5465
+701 04/03 09:51A (561|310-6943
+WPALMBEACH FL
+703 04/03 09:57A (561)379-6422
+'ALMBEACH
+04/03 09:57A
+COMIN
+IMIN
+704 04/03 09:58A (561)236-3299
+WPALMBEACH FL
+706 04008 10:20A 561/236-3299
+04/03 10:50A
+INCOMING
+040310524 5811232-6398
+04.
+/03
+11:01A
+WALMBEACH FE
+INCOMING
+04/03 02:21P 1561878-335
+88
+08:15P
+611818-333
+WALMEAN
+1MIN
+(561)792-6375
+NPALMBEACH FI
+NCOMING
+1000 NIGHT/KEND MIN
+DD NIGHT/WKEND M
+DO NIGHTWKEND M
+1000 NIGHT/KEND MIN
+1000 NIGHT/KEND MIN
+OD NIGHT/WEND MIN
+1000 NIGHT/KEND
+JD NIGHTWKEND
+1000 NIGHT/KEND
+ODD NIGHT/WKENL
+000 NIGHT WKENI
+DO NIGHT/WKEN
+DO NIGHTAWKEND H
+
+
+88888 c
+
+
+/03
+1000 NIGHT/KEND MIN
+ND
+(56
+61)81
+18-
+-3331
+00 cos C
+9900
+
+стіст спі сді
+
+IN
+6-
+561):
+236-3200
+(561)282-8891
+FACH FI
+2003069.00002244B
+
+
+
+Item Date Time Called
+Onty
+Used
+2 04/04 01:35
+8 0404 01-38
+764 04/04 08:54A
+766 04/24 00:454 (561317-2428
+10:47A
+767 04/04 10:47A (561)795-3210
+768 04/04 10:48A
+769 04/04 10:49A (561)795-3210
+770 04/04
+10:58A
+771
+04/04 11:09A
+772 04/04 11:56A
+561309-1375
+74 04/04 1258P
+12•50P
+V04 12:51
+15811236-3299
+76
+4004 12:34P 1381|236-32
+777 04/04 12:59P
+04/04
+04/04 01
+04
+01-200
+04
+01:
+02:14P
+04/04
+12:47P
+Calls To
+NCOMING
+JCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+NOOMING
+WPALMBEACH FL
+WPALMBEACH FL
+VPALMBEACH F
+VPALMBEACH F
+/PALMBEACH F
+VPALMBEACH H
+INCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+NOMIN
+INCOMING
+VALINE
+ACH H
+TEVT
+2MIN
+IMIN
+I MIN
+EMIN
+
+02:52P
+
+88
+(561)310-6943
+(561)385-0480
+INCOMING
+99983
+1902-7339
+385-0480
+(561)385-0480
+05:37P
+07:49P
+08
+:05P
+5611309-1375
+561j310-6943
+08:21P
+INCOMING
+WPALMBEACH FL
+NCOMING
+INCOMING
+WALKE A HEL
+INCOMING
+08:28P (561)309-1375
+| 09:18P
+09:19P
+10:28P
+06:20A
+0:231
+11:04A
+11:11A
+1-4FA
+5611801-3590
+561)753-0169
+5611317-2428
+12:30P
+12
+:32P
+01:58P
+02:07P
+(561)902-7339
+15611902-7339
+05:
+:DOP
+03:21P
+03:25P
+04:12P
+(561)902-7339
+04/05 04:13P
+04/05 04:39P
+(561)902-7339
+04/05 05:31P (561j309-1375
+04/05 05:32P
+88889
+105
+:34P
+(561)902-7339
+35P
+49P
+(561|236-3299
+52P (5611848-5502
+NCOMING
+NGON
+INCOMING
+COMIN
+COMIN
+WPALMBEACH FL
+WPALMBEACH FI
+MPALMBEACH FI
+INCOMING
+INCOMING
+PAHOKEE FL
+PAHOKEE FL
+INCOMING
+INCOMING
+INCOMING
+PAHOKEE FL
+INCOMING
+PAHOKEE FL
+WPALMBEACH FL
+INCOMING
+PAHOKEE FL
+WPALMBEACH FL
+WPALMBEACH FI
+WALME EACH FL
+IMIN
+MIL
+MIl
+MIt
+MIL
+MI
+' MI
+3MIN
+Rate Description
+1000 NIGHTWEEN MIN
+1000 NIGHT/KEND
+100 NIGHT WHEN
+1000 NIGHT/KEND
+CAL WATINREND MIN
+1000
+2
+IGHT/KEND
+1000 NIGHT/WIENB
+1000 NIGHT/KEND
+1000 NIGHT WIEND
+1000 NIGHT/WREND
+GHT
+.....
+
+Item Date Time
+Called
+Calls To
+828 04/05 05:18P 561)235-7699
+827 04/05 06:37P
+28 04/05 06:40P (561)792-6375
+829
+14/05 06:42P
+830 04/05 07:04P
+831
+V/05 07:27
+51)309-137
+832
+L05 07-30
+51902-73
+833
+04/05 07:36P (561309-1375
+INCOMING
+VPALMBEACH FI
+COMING
+INCOMING
+WPALMBEACH FL
+PAHOKEE
+WPALMBEACH FL
+834
+04/05 07:40P
+835
+04/05 07-42P
+836
+04/05 07:42P
+04/05 09:20P
+561)379-6422
+838 04/05 09-21P
+839 04/05 09:28P (561)379-7824
+COMING
+COMIN
+WPALMBEACH FL
+Onty
+Used
+Rate Description
+IMIN
+INCLUBED MINUTES
+INCLUDED MINUTES
+JCLUDED MINUTE
+JCLUDED MINUTE
+3 MIN
+INCLUDED MINUTES
+JCLUDED MINUTE
+ICLUDED MINUTE
+INCLUDED MINUTES
+NELUBER MINUTE
+D MINUTES
+INCLUDED MINUTES
+> MIN
+• RETRIEVAL
+840 04/05 09:46P
+
+51)236-3299
+- - 0-0-1
+BSESSES
+2MIN
+C
+(954)258-2985
+(561)379-7824
+
+(551)
+1309-
+coco
+
+
+(954)
+)433-
+-OB
+78
+99489
+(56
+282-8891
+INCOMING
+COMIN
+NCOMING
+FTLAUDERDL FL
+WPALMBEACH FL
+WHAMBER HEL
+WPALMBEACH FL
+VPALMBEACH F
+INCOMING
+INCOMING
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+NOOMING
+NOOMING
+NOOMING
+PAHOKEE FL
+/PALMBEAC
+IPALMBEACH F
+NOOMING
+HOL YWOOD FL
+INCOMING
+WALMBEACH FI
+NORMACHEL
+1EVT
+INCLUDED MINUTES
+NCLUDED MINUTE:
+INCLUDED MINUTE
+ICLUREL
+B MINUTE
+*24560705D00*
+
+
+
+Item Date Time
+Called
+888 04/07 06:23P (561)204-4902
+889 04/07 06:33P
+890 04/07 07:36P
+891
+(561)282-8891
+04/07 07:45P
+892 04/07 07:58P
+894 04/07 18:32P
+894
+895 04/08 06:05A (954)258-2985
+897 84/08 08.384
+897
+2611313-383
+14146
+898 04/08 06:42A (561\236-3299
+99 04/08 07:01A (561)236-329:
+300 04/08 07:07A
+902 04/08 10:904 (561)282-8891
+903 04/08 11:11A (561)308-9208
+805 04108 02:40P
+906 04/08 03:07P (561)317-2428
+908
+04/
+03.
+6P
+909
+04
+04:391
+910
+04/
+04:54P
+04/
+08
+06:02P
+5611662-1629
+911
+06:04P
+962-1628
+912
+08
+04/08 07:38P
+(561)379-7824
+913
+04/08 07:40P (561)383-5513
+04/08 08:27P
+916
+04/
+08
+18
+888
+08:37P
+08
+08:47P
+108
+09:17P
+08
+10:30P
+(56 1)393:
+04/08
+10:30P
+-5935
+919
+92D 04/08 10:36P
+04/08 10:40P
+(561)379-7824
+823 40g 10:50A
+61)662-162
+3611379-642
+924
+04/09 18:530
+04/09
+161102-102
+52.
+926
+04/09 10:54A
+(561
+1310-6943
+927
+04/09
+10:57A
+928
+04/09 10:58A
+1961)
+1236-
+929
+(561)
+930
+04/09 10:59A
+931
+04/09
+11:02A
+04/09
+11:02A
+932
+04/09 11:07A
+933 04/09 11:15A
+934 04/09 11:16A
+935 04/09 11:20A (561)310-6943
+36 04/09 11:22
+27 04mo 11.07
+Calls To
+WPALMBEACH FL
+INCOMING
+NCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+INCOMING
+NCOMING
+FTLAUDERDL FL
+AKE WORTH EL
+TLAUDERDL FL
+WPALMBEACH FL
+WPALMBEACH FL
+NCOMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+NOOMING
+NCOMING
+WPALMBEACH FL
+NCOMING
+INCOMING
+INCOMING
+WPALMBEACH FL
+WPALMBEA
+WPALMBEACH FL
+WPALMBEACH FL
+NCOMING
+WPALMBEACH FL
+INCOMING
+/PALMBEACH F
+AKE WORTH P
+INCOMING
+NCOMING
+WPALMBEACH FI
+WALM EACH
+WPALMB
+WPALM
+WPALMBEACH
+WPALMBE
+WPALMeR
+WPALMBEACH
+FTLAUDERDL
+HOLLYWOOD
+INCOMING
+INCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+Qnty
+Used
+IMIN
+2
+3MIN
+1-D-------
+FETERE
+2MIN
+10 MIN
+4 MIN
+16V
+3 MIN
+6MIN
+1 EVT
+4 MIN
+3MIN
+--
+NCLUD
+INCLU
+CLU
+938 04/09 11:30A (561)310-6943
+939 04/09 11:44A
+940 04/09 11:48A (561)236-3299
+941 04/09 11:50A
+942 04/09 11:51A
+943 04/09 11:52A
+(561)313-5654
+944
+04/09 11:53A
+S81 662:1628
+662-1628
+945 04/09
+(561,264-7568
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+LAKE WORTH FL
+VPALMBEACH
+FL
+VPAIMBEACH
+WALMBEACH FL
+Rate Description
+INCLUDED MINUTES
+INCLUDED MINUTES
+CLUDED MINUTE
+CLUDED MINUTE
+INCLUDED MINUTES
+INCLUDED MINUTES
+1000 NIGHT/WKEND MIN
+INCLUDED MINUTES
+NCLUDED
+CLUDED MINUTE
+INCLUDED MINUTES
+CLUDED MINUTE
+CLUDED MINU
+NOLUBED MINUTES
+•D MINUTE:
+ES
+
+Item Date Time
+Called
+948 0409 11:38A (561/282-3898
+949 04/09 12:02P (561 317-2428
+04/09
+04/09
+12:05P
+12:35P
+04/09 12:47P
+04/09 01:46P (561)379-6422
+04/09 02:55P
+15611662-2721
+04/09 02:59P (561)309-1375
+04/09 03:21P
+04/09 03:51P
+04/09 04:33P (954)253-1444
+Calls To
+WALMBEACH EL
+WPALMBEACH FL
+COMIN
+COMIN
+INCOMING
+WPALMBEACHFL
+WPALMBEACH FL
+COMIN
+COMIN
+FTLAUDERDL FL
+04/09 05:00P
+04/09 05:07P (954)253-1444
+14/09 05:10P
+04/09 05:10P
+COMIN
+COMIN
+Onty
+Used
+Rate Description
+3 MIN
+INCLUBED MINUTES
+2MIN
+INCLUDED MINUTES
+4 MIN
+CLUDED MINUTE
+2MIN
+CLUDED MINUTE
+INCLUDED MINUTES
+3MIN
+1MN
+2MIN
+2MIN
+INCLUDED MINUTES
+INCLUDED MINUTES
+INCLUDED MINUTES
+2MIN
+IN BED MINUTES
+1 EVT
+
+88888888®
+спіст со сісті
+61
+99 99999
+
+
+(561)795-7774
+30500
+(561\202-7395
+8888
+888
+(561)313-5654
+INC
+INC
+2003069.000022449
+
+
+2003069.000022449
+
+Item Date Time
+Called
+Onty
+Used
+1812 04/10 11:354
+1013 04/10 12:45P
+14 04/10 12:5
+1016 04/10 02:11P (561)792-6375
+Calls To
+COMI
+COMIN
+INCOMING
+COMIN
+COMIN
+WPALMBEACH FL
+017 04/10 02:131
+018 04/10 02:43
+1019 04/10 03:30P (561\662-1628
+3MIN
+2MIN
+2MIN
+1021 84/18 0314P (561)379-6422
+22 04/10 04:20
+23 04/10 04-
+61662-1628
+> 954 253-1444
+1024 04/10 04:42P
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+NPALMBEACH FL
+-TLAUDERDL FL
+INCOMING
+INCOMING
+INCOMING
+1/10 05:238
+1027 04/10 05:34P
+
+/10
+
+561)662-1628
+(561)753-0169
+(561)662-7668
+(5611379-7824
+BP
+M8110800030100
+(772)219-4743
+(561)
+1282-
+11282
+Rate Description
+UL
+EACH FL
+FL
+NCOMING
+WPALMBEACH FL
+INCO
+MIr
+MAIN
+!!!!!!!!
+1000 NIGHT/KEND MIN
+O0NGHTWKEN
+HEWKEND MI
+1000 NIGHT/WKEND MIN
+J00 NIGHT/WKEND M
+DO NIGHT/KEND M
+1000 NIGHT/WKEND MIN
+-TANKEND MIN
+JWKEND S
+1000 NIGHT/KEND MIN
+00 NIGHT/WKEND M
+N
+1000 NIGHT/KEND MIN
+1000 NIGHT/WKEND MIN
+1000 NIGHT WHEN MIN
+1000 NIGHT/WKEND MIN
+1000 NIGHT/WKEND MIN
+1000 NIGHT/WKEND MIN
+DO NIGH LWKEND N
+J0 NIGHTTWKEND M
+1000 NIGHT/WKEND MIN
+TONIGHT TREND MIN
+1000 NIGHT WIEND MIN
+1000 NIGHT/WKEND MIN
+INCLUDED MINUTES
+CLUDED MINUT
+LUDED MINUT!
+INCLUDED MINUTES
+INCLUDED MINUTES
+1000 NIGHT/WEND MIN
+INCLUBED MINUTES
+NCLUDED MINUTES
+CLUDED MINUTE
+*2457
+
+Item Date Time Called
+Calls To
+Onty
+Used
+1876 04/13 08:22A 1561 309-1375
+1077 04/13 12:20P (954 253-1444
+079 04/13 12:341
+04/13 12:341
+1080 04/13 12:34P (561)827-3571
+1082 0413 02 35
+1083 04/13 02:51P (561)317-2428
+084 04/13 02:22
+504/13 02:32P 361/317-212
+FTLAUDERDL FL
+COMIN
+WPALMBEACH FL
+COMING
+COMING
+WPALMBEACH FL
+PALMBEACH
+PALMBEACH
+1087 0413 02 38P 351)319-2458
+1088 04/13 03:45P
+INCOMING
+189 04/13 03:55
+90 04/13 04:33P 5611379-642
+1082 04/13 08 318
+COMIN
+VOOMINI
+1093 04/13 06:04P
+INCOMING
+94 04/13 06:24
+95 04/13 06:25P 581/662-16
+"ALMBEACH
+1096 04/13 06:27P
+PALMBEACH
+INCOMING
+1098 04/13 06.37P
+COMIN
+ICOMINI
+1000 04/13 07:08P (561)791-3394
+/PALMBEACH F
+ICOMIN
+1101 04/13 07:02P (561)798-7486
+WPALMBEACH FL
+1102 0413 02
+08-26P (5611313-5654
+WORTH FL
+1104 04/13 09:01P (561)662-1628
+WPALMBEACH FL
+105 04/13 09:091
+NCOMING
+106 04/13 09:17P (561)324-1517
+NPALMBEACH FI
+1107 04/13 09:39P
+(561)662-1628
+WPALMBEACH FL
+MIr
+MIT
+13MIN
+I MID
+3 MIN
+SMIN
+7MIN
+1 SAIN
+6 MIN
+2MIN
+8 MIN
+BMIN
+7MIN
+1108 04 13 10:05P (561,662-1628
+PALMBEACH
+COMIN
+1119 0474 06:30A (561813-2464
+WALMACH
+1112 04/14 06:34A (954)258-2985
+FTLAUDERDL FL
+1114 04/14 07:12A (561)792-6372
+INCOMMINEACH F
+1115 04/14 12:44P
+INCOMING
+16 04/14 03:10
+COMI
+117 04/14 05:31
+COMIN
+1118 04/14 06:15P
+INCOMING
+119 04/14 09:00P
+COMIN
+120 04/14 09:15P
+COMIN
+1121 04/14 09:21P
+22 04/14 09:31P (561)309-137
+INCOMING
+02 04/14 10-2
+WPALMBEACH FL
+INCOMING
+1124 04/14 10:43P
+INCOMING
+2MIN
+TOTAL VOICE USAGE FOR (561)379-7824
+Rate Description
+INCLUDED MINUTES
+INCLUDED MINUTES
+CLUDED MINUTE
+CLUDED MINUTE
+INCLUDED MINUTES
+NOLUBEB MINUTE R
+D MINUTE
+INCLUDED MINUTES
+NELUBEB MINUTE
+D MINU
+CLUBED MINUTE
+D MINUTE
+INCLUDED MINUTES
+INCLUBED MINUTES
+0.25 ADDITIONAL MINUTES
+0.22 ADDITIONAL MINUTE:
+.25 ADDITIONAL MINUTES
+0.25 ADDITIONAL MINUTES
+ABBITIONAL MINUTES
+ADDIT
+0.25 ADDITIONAL MINUTES
+0.25
+ABBTIONAL MINUTES
+00
+0.25 ADDITIONAL MINUTES
+0.25 ABBITIONAL MINUTES
+5 ADDI
+1000 NIGHT/KEND MIN
+1000 NIGHT/WKEND MIN
+1000 NIGHT REND MIN
+TAIN
+0.25 ADDITIONAL MINUTE MIN
+0.25 ADDITIONAL MINUTES
+25 ADDITIONAL MINUTE
+25 ADDITIONAL MINUTE
+0.25 ADDITIONAL MINUTES
+25 ADDITIONAL MINUTE
+125 ADDITIONAL MINUTE
+2MIN 0.25 ADDITIONAL MINUTES
+10MIN
+1000 NIGHT/WKEND MIN
+00 NIGHT/KEND N
+000 NIGHT/KEND N
+1000 NIGHTAWKEND MIN
+Charge Description
+INCL. IN PLAN DATA
+0.25
+0.29
+0.25
+0.25
+0.25
+0.25
+0.25
+8.25
+0.50
+10.25
+DATA USAGE FOR (561)379-7824
+Item Date
+Qnty Used
+1 04/14
+TOTAL DATA USAGE FOR (561379-7824
+0.00
+
+
+
+TEXT/MULTIMEDIA MSGS FOR (561)379-7824
+Item Date
+Time
+Sent To/Revd From
+1 03/15
+02:20P
+2 03/15
+05:38P
+
+4 03/15
+1.30
+S 03/17
+9 03/17
+9 03713
+10 03/18
+Charge Description
+100 INCL MSGS SENT
+03.
+13 03/19
+4 03/1|
+15 0922
+16 03/20
+103.
+
+
+12:18P
+(561)236-2293
+1224P 361/236-2283
+085A 51810-6009
+01:33P
+1:38
+07:01A
+661315-3476
+02:15A
+161)315-747
+611379-642
+02:52A
+87:368
+: 581)801-6282
+98888888 888838388888888338888388398838888998
+10 IN MS SENT
+
+....
+
+TEXT/MULTIMEDIA MSGS FOR (561)379-7824 - Continued
+Item Date
+68 03/26
+69 03/26
+71 03/26
+72 03/26
+Time
+07:38P
+08:13P
+09:00P
+09:03P
+06:338
+Sent To/Revd From
+Charge Description
+(561\601-6282
+(561)601-6282
+100 INC. MSGS SENT
+51601-6282
+100 INEL MSS SENT
+(561)601-6282
+581236-3299
+100 IN MS SENT
+
+77 03/27
+100 INCL: MAGS SENT
+80 03/28
+82 03/28
+83 03/28
+84 03/28
+8888588188888588888889=##PP=##808888808885888
+09:27P
+921
+1:53
+12:12P
+1218P
+01:17P
+81:230
+(561)601-6282
+561601-628
+61310-69
+(561)310-6943
+61)310-694
+61310-694
+(561)601-6282
+681/601-6282
+88838839998988889888888888388888BARRRRRRRRRR
+100 INCE MISS SENT
+
+
+
+
+
+TEXT/MULTIMEDIA MSGS FOR (561)379-7824 - Continued
+Item Date
+135 04/08
+136 04/08
+137 04/08
+138 04/08
+139 04/08
+40 04/06
+41 0AMA
+143 04/08
+14/08
+144 04/09
+45 04/1
+147 04/11
+148 04/12
+149 04/12
+150 04/12
+51 04/1:
+62 04/13
+Time
+Sent To/Rcvd From
+Charge Description
+07:02A
+1561\236-3299
+06:15P
+TEXT MESSAGES SENT
+TEXT MESSAGES SENT
+09:390
+61|309-137
+S11309-137
+TEXT MESSAGES SENT
+07:39P
+09:16P
+TEXT MESSAGES SENT
+09:30P
+10:13F
+1561309-1375
+TEXT MESSAGES SENT
+10:19A
+1561309-1375
+12:44A
+(561)662-1628
+TEXT MESSAGES SENT
+TEXT MESSAGES SEN
+12:27P
+SENT
+1561300-135
+TEXT MESSAGES SE
+09:03P
+(561\309-1375
+TEXT MESSAGES SENT
+12:03P
+12:16P
+5130-137
+TEXT MESSAGES SEN
+07:384
+1561309-1373
+TEN MESAGE ENT
+TEXT MESSAGES
+1 DA
+161 04/14
+TOTAL TEXT/MULTIMEDIA MSG USAGE FOR (561)379-7824
+2003089.000022450
+*24580707D00*
+
+1.10
+*** THIS SPACE INTENTIONALLY LEFT BLANK ***
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/3f9aa42e9c5b8aa4f3831a3e4633cf479b14336e336e14a024d15d8c7a9bcf75.receipt.json b/vision-fixhub/ds9-unparsed-06/3f9aa42e9c5b8aa4f3831a3e4633cf479b14336e336e14a024d15d8c7a9bcf75.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..757645993ff8dc589a2c1c86ee590bead5527018
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3f9aa42e9c5b8aa4f3831a3e4633cf479b14336e336e14a024d15d8c7a9bcf75.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -6337,
+  "dataset": "marble-joined",
+  "doc_id": "3f9aa42e9c5b8aa4f3831a3e4633cf479b14336e336e14a024d15d8c7a9bcf75",
+  "engine": "marble-apple-vision",
+  "event_count": 90,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "403756397648f65d8f814f9ab826cf29d3533681cfc345caf93eceea20469b6a",
+  "output_sha256": "495de533c1654b2e4898398105355c94e1713a182799cee281fb3608adccae90",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/3fba6623beb36411f0f5083af5374f663290411f3b6af8683c52d5355a2eed21.md b/vision-fixhub/ds9-unparsed-06/3fba6623beb36411f0f5083af5374f663290411f3b6af8683c52d5355a2eed21.md
new file mode 100644
index 0000000000000000000000000000000000000000..8847e1ab9278a1cb7b0bd3967197bdfbdbd71852
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3fba6623beb36411f0f5083af5374f663290411f3b6af8683c52d5355a2eed21.md
@@ -0,0 +1,2011 @@
+LEFEREY E EPSTEIN
+Questions or Changes?
+: Tole t
+attwireless.com
+:
+611 from your wireless phone
+TTY users - 1 866 4-AW S-TTY
+SUMMARY OF MONTHLY CHARGES FOR ACCOUNT 0043811863
+Previous
+Payments
+Late Payment
+Balance
+Received
+879.45
+-879.45
+0.00
+Account
+Adjustments
+0.00
+Your billing cycle began on September 03, 2004 and ended on October 02, 2004
+Current Monthly Charges
+Subscriber Adjustments
+Monthly Service
+Monthly Usage
+Charges
+Credits
+Taxes, Surcharges & Regulatory Fees
+Total Current Monthly Charges DUE UPON RECEIPT
+TOTAL AMOUNT DUE
+Date of Invoice: October 06, 2004
+Balance
+Forward
+0.00
+0.00
+186.68
+326.17
+0.00
+0.00
+109.88
+622.73
+Current Monthly
+Charges
+622.73
+Total
+Amount Due
+622.73
+622.73
+GET IM TO GO
+BE THERE FOR YOUR BUDDIES WHEN YOU'RE AWAY FROM YOUR PC
+-GET INSTANT MESSAGES VIA TEXT MESSAGING ON YOUR
+WIRELESS PHONE. START NOW! SEND A BLANK TEXT MESSAGE
+TO 2650 FOR AOL(R) INSTANT MESSENGER (TM) OR TO 92466000
+FOR YAHOO!(R) MESSENGER. STANDARD TEXT MESSAGING
+CHARGES APPLY.
+AT&T WIRELESS APPRECIATES YOUR BUSINESS
+Please Retur This Portion With Your Payment
+Use ore General Terms and Condions or wies see.
+Account Name: JEFFREY E EPSTEIN
+Yes aalty deduled rom the have to my i loser
+(see reverse - signature required
+Date Due
+UPON RECEIPT
+Note:
+=>
+We Print on
+Front and Back
+Service #
+Account
+Chack res see chaese.
+Total
+Amount Due
+622.73
+Amount
+Paid
+#BWNHNGB
+#0000000
+
+H1 1 1002 10022.5.21.01.1034.0000
+AT&T WIRELESS
+PO BOX 8229
+AURORA IL 60572-8229
+000000000000000000•
+
+
+Recurring Electronic Fund Transfer (REFT): To enroll: sign below, check the REFT box on the reverse side and
+remit with this month's payment. Keep paying your bill until your statement indicates "Do Not Pay". REFT
+Agreement: I authorize my financial institution to deduct the amount of my monthly wireless phone bill from the
+account associated with the enclosed check and remit payment to AT&T Wireless. This authority will be effective
+until I notify AT&T Wireless to terminate it. I agree that I may be assessed a service charge (up to $20) or late fee
+or both if a payment is returned by my bank. For more information visit attwireless.com/ocs or call 1
+Please keep a copy of the form below and this REFT Agreement for your records or retain a copy of the blank form
+from next month's invoice.
+Questions? We can help: AT&T Wireless appreciates your business and welcomes the opportunity to assist you.
+As part of our commitment to you, we are always adding new calling plans and promotions to match your individual
+needs. Visit our website at attwireless.com or contact Customer Care by dialing 611 from your wireless phone or 1
+1. ¿Sabias que también ofrecemos servicio al cliente en tu idioma? Marca 611 desde tu teléfono
+inalámbrico ó 1
+desde cualquier teléfono y oprime el *.
+Driving Wireless Safety: Your wireless phone gives you the freedom and flexibility to stay in touch when you
+travel, but don't let a phone call distract you from driving safely. Use hands-free device if allowed or required by
+law. Call Carefully, Arrive Safely.
+AT&T Wireless Processing Fees: Accounts suspended for non-payment will be subject to a $25 reactivation fee
+per line and may be assessed a security deposit prior to reinstatement. Checks returned for non-sufficient funds will
+be charged up to a $20.00 fee.
+Local Tax: Local taxes are based on local goverment boundaries, the address information you provide for your
+account and/or your wireless telephone number. Please review the local tax charges on vour bill. If you believe
+here is an error in the local tax charge, please contact us immediately at 1
+local or state laws may require you to follow special procedures when notifying us about a local tax dispute. You
+may also use the form below to notify us of any change to your taxing address. Thank you for your cooperation.
+Early Termination Fee (ETF): If you cancel service before your contract end date (including if you switch your
+wireless number to another carrier), you will be charged an Early Termination Fee of up to $200.
+Please Send Correspondence To:
+AT&T Wireless Next Generation Correspondence
+P.O. Box 68056
+Anaheim Hills, CA 92817-8056
+1001B01.000005046.5
+Change of Address Only. Please print address clearly and check the box on the reverse side. Please contact Customer Care to change the
+Account Name and transfer Financial Responsibility
+New Billing Address
+City
+State
+Zip
+Home Phone (
+Work Phone (.
+If your billing address is NOT your Tax Address*, please enter the Tax Address below. (Multi-line accounts should attach a list of each wireless number
+and the respective Tax Address.)
+New Tax Address*
+Wireless Number (
+Jnder Federal laws, your Tax Address must be: your primary place of use, your residential or business address, and located within AT&T Wireless
+censed service area. Non-business customers on AT&T Digital One Rate, Regional Advantage or Shared Advantage plans must use their residentia
+address as their tax address.
+Recurring Electronic Fund Transfer (REFT) Enrollment. Please read the agreement on the top portion of this page, sign below and check
+the "REFT Registration" box on the reverse side.
+Financial Account Holder Signature
+- 6.1 - 3G
+• + I do not wish to receive email notification of special oilers avalable to AT&T Wireless customers.
+
+
+
+INTRODUCING THE TRAVEL PACKAGE FROM AT&T WIRELESS. THE
+PACKAGE THAT ALLOWS YOU PEACE OF MIND WHILE ON THE GO.
+COMBINING THE COMFORT OF ROADSIDE ASSISTANCE AND THE
+CONVENIENCE OF 411 INFO AT YOUR FINGERTIPS, ALL FOR A
+GREAT LOW RATE. TO FIND OUT MORE GO TO YOUR NEAREST
+AT&T WIRELESS STORE TODAY.
+ACCOUNT DETAILS
+Detail of Payments - Thank You!
+Item Description
+1 PAYMENT
+Total of Payments
+Date Applied/Reversed Payment Amount
+09/28/04
+-879.45
+Current Subscriber Monthly Charges and Credits
+Subscriber Number
+Subscriber Name
+Total Current Subscriber Monthly Charges and Credits
+Total Current Monthly Charges
+SUMMARY OF CURRENT ACTIVITY
+Monthly Service Charges
+Item Description
+1 CALL WAITING
+2 AT&T TEXT MESSAGING
+3 CALLER ID
+4 EARLY EVENING
+5 ENH DISCOUNT INTL DIAL
+6 MULTIMEDIA MESSAGING $2.99
+7 AT&T VOICE MAIL
+B MMODE/DATA SERVICE (4MB)
+9 NATIONAL PLAN $149.99
+10 THREE WAY CALLING
+11 REGULATORY PROGRAMS FEE
+12 VOICEDIAL SERVICE $3.99
+13 DETAIL BILLING
+14 DISCOUNTED INTERNATIONAL ROAMING
+Total Monthly Service Charges
+Service Dates
+09/03/04 - 10/02/04
+09/03/04 - 10/02/04
+09/03/04 - 10/02/04
+09/03/04 - 10/02/04
+09/03/04 - 10/02/04
+09/03/04 - 10/02/04
+09/03/04 - 10/02/04
+09/03/04 - 10/02/04
+09/03/04 - 10/02/04
+09/03/04 - 10/02/04
+09/03/04 - 10/02/04
+09/03/04 - 10/02/04
+09/03/04 - 10/02/04
+09/03/04 - 10/02/04
+-879.45
+-879.45
+622.73
+622.73
+622.73
+0.00
+4.99
+0.00
+0.00
+3.99
+2.99
+0.00
+12.99
+149.99
+0.00
+1.75
+3.99
+0.00
+5.99
+186.68
+
+SUMMARY OF CURRENT ACTIVITY - CONTINUED
+Monthly Usage Charges
+Item Description
+1 400 ADD'L ANYTME MIN
+2 UNLIM MOBL TO MOBL
+3 ENH DISC INT DL
+4 MESSAGE RETRIEVAL
+5 EARLY EVENING N/WKND
+6 UNLIMITED NAKND MIN
+7 DISCOUNT INTL ROAM
+8 INTL ROAM TEXT MSG
+9 ROAM CALL WAITING
+10 CALL WAITING
+11 INTL TEXT MSG
+12 100 INCL. MSGS SENT
+13 411 INFO
+14 DROP CALL CREDIT
+15 INCLUDED MINUTES
+16 CALL FORWARDING
+Total Monthly Usage Charges
+Onty Used
+93 MIN
+639 MIN
+336 MIN
+11 EVT
+2 EVT
+20 EVT
+12 EVT
+7 EVT
+1 EVT
+2 MIN
+299 MIN
+0.00
+0.00
+5.03
+0.00
+1.01
+310.24
+5.50
+0.00
+0.00
+3.00
+858
+0.00
+0,90
+326.17
+Taxes, Surcharges and Regulatory Fees
+Item Description
+1 LOCAL WIRELESS SURCHARGE
+2 MCTD SURCHARGE
+3 FEDERAL TAX
+4 TELECOM EXCISE TAX
+§ ST WIRELESS COMM SURCHARGE
+7 UNIVERSAL CONNECTIVITY CHARGE
+8 NY CITY UTILITY G.R. SUR
+Total Taxes, Surcharges and Regulatory Fees
+TOTAL CHARGES FOR
+0.30
+4.38
+15.88
+17.55
+46.31
+13:70
+10.48
+109.88
+622.73
+DETAIL OF CURRENT ACTIVITY
+Item Date Time Called
+1 09/03 09:07A
+3 09/03 11:13A
+4 09/03 11:46A
+: 09003 01:00
+7 09/03 01:01P
+9090301-05
+10
+09/03 01:08P
+09/03 01:18F
+10/03 01:19P
+09/03 01:20P
+09/03 81 10P
+03 01:40P
+INCOMING
+INCOMING
+NWYRCYZN02 NY
+Onty
+Used Rate Description
+11 MIN
+400 ADDL ANYTME MIN
+400 ADD LANY ME MIN
+2 MIN
+400 ADD'L ANYTME MIN
+NCOMING
+JUEENS NY
+CASTER VI
+2 MIN
+EMIN
+2 MIN
+IMIN
+2 MIN
+EMIN
+400 ADD'L ANYTME MIN
+400 ADD'L ANYTME MIN
+SALARMOBLTO MOBIL
+400 ADDL ANYTME MIN
+1001801.000005047
+
+
+1001B01.000005047
+Iter Date Time
+Called
+16 09/03 01:51P
+17 09/03 02:58P
+9V0B 03:59
+9 09/03 06:02
+20 09/03 06:07P
+21 09/03 06:19P
+22 09/03 07:18P
+23 09/04 10:07/
+24 09/04 01:34F
+25 09/04 01:45P
+29 09(04 02-29
+28 09/04 05:04P
+Arman
+88888
+V04 05:07P
+FEEI
+11
+1998A
+11:23A
+34 09/11 11:24A
+35
+09/11 11:25A
+mm
+09/11 11:31A
+09/11 11:5BA
+38
+09
+/11
+12:07P
+88888
+¡9N00555
+RASCA
+09
+/11
+111
+
+
+NY ZONE 1 NY
+INCOMING
+INCOMING
+COMING
+nobile UI
+mobile UK
+EW YORK N
+COMIN
+NWYRCYZN01 NY
+NEW
+YORK
+NY
+NEW
+YORK
+INCOMING
+mobile UK
+mobile UK
+NY ZONE 1 NY
+mobile UK
+INCOMING
+NCO
+ZONE INT
+69958
+: NY
+- Continued
+Qnty
+Used Rate Description
+14 MIN
+100 ADD'L ANYTME MIN
+1 MIN
+100 ADD'L ANYTME MIN
+00 ADD'L ANYTME MI
+J0 ADD'L ANYTME M
+4 MIN 0.06 ENH DISC INT DL
+EV
+1 MIN
+MIT
+VLIM MOBL TO MOB
+ESSAGE RETRIEVA
+UNLIM MOBL TO MOBL
+JEV
+W
+NEW
+NWY
+(Z001 NY
+NEW
+INC
+ORK N
+NY
+ESSAGE RETRIEVA
+LIMITED NWKND MI
+1 MIN
+UNLIMITED N/WKND MIN
+SMIN
+. INT D
+0.23 ENLIMITED NAWKND MIN
+3MIN 0.28 ENH DISC INT DL
+LIMITED N/WKND MI
+2 MIN
+1 MIN
+7 MIN
+2 MIN
+1 MIN
+IMIN
+1 MIN
+MIN
+MIN
+1 MIN
+3 MIN
+IN
+3MIN
+1 MIN
+EMIN
+0.2
+0.2
+0.2
+СТЕБЕТ ВЕРИВЕНИ!
+!!!!!!!!
+0.24
+0.28
+0.84
+0.84
+
+Item Date Time
+Called
+71 09/11 10:47P
+72 09/11 10:49P
+73 09/11 11:00₽
+75 09/12 10:22A
+76 09/12 10:29A
+77 09/12 10:35A
+78 09/12 10:37A
+09/12 10:3
+0077 105
+81 09/12 11:23A
+83 09/12 1128A
+84 09/12 11:29A
+NWYRCYZNO1 NY
+INCOMING
+mobile UK
+mobile UK
+QUEENS NY
+EW YORK N
+COMIN
+INCOMING
+W YORK i
+W YORK i
+INCOMING
+- Continued
+Onty
+Used Rate Description
+1 MIN
+UNLIMITED N/WKND MIN
+1 MIN
+UNLIMITED N/WKND MIN
+EMIN
+UNLIMITED WINDMIN
+1 MIN
+UNLIMITED N/WKND MIN
+1 MIN
+NLIMITED NWKND MI
+1 MIN
+28 ENH DISC IN
+DL
+1 MIN
+UNLIMITED N/WKND MIN
+AMIN
+INT
+0.28 ENLMITEDNTWKND MIN
+7MIN
+IN
+3MIN
+EMIN
+1MIN
+UNLIMITED N/WKND MIN
+UNLIMITED WE MIN
+UNLIMITED N/WKND MIN
+CALMTED NO
+ED NKND MIN
+0.2B
+0.28
+85 09/12 11:30A
+86 09/12 11:32A
+87 09/12 11:33A
+НЕ008888888 88 8888
+13P
+NY ZONE 1 NY
+NEWYORKZNI NY
+INCOMING
+RK
+NY
+NEV
+GAR
+099c
+22222
+NY
+NY
+• NY
+101
+NY
+101
+NY
+INCOMING
+NWVYRCYZNO1 NY
+NCOMING
+NEWYORKZNI NY
+IEW YORK N°
+WYRCYZN02 N
+1MIN
+2 MIN
+SMIT
+1MIN
+UNLIMITED N/WKND MIN
+CALMERING ND MIN
+TING
+UNLIMITE
+N
+UNL
+U
+00000
+22
+30
+5555
+N
+009
+ND
+OC
+ND
+INLIMI
+JNU
+UNL
+
+KND
+KNI
+MIN
+N/W
+KND
+ED
+22222
+MIN
+VKND
+MI
+VKND
+MIN
+MI
+MIN
+MIN
+IN(
+G
+2222
+NKND
+MIN
+I/WKND
+MIN
+NOV KND
+MIN
+N/WKND MIN
+UNLI
+UNLIMITED N/WKND MIN
+UNLIMITED N/WKND MIN
+UNLIMIT
+ED NANKN
+D
+0.14 ENH DISC INT DL
+0.14
+
+
+Called
+Item Date Time
+127 09/12 06:43P
+128 09/12 07:03P
+L29 09/12 07:05P
+130 09/12 07:09P
+131 09/12 07:10P
+07:138
+8888
+12
+17:13P
+07:15P
+87:29P
+38
+88
+10:19P
+0:56P
+139
+09/13 08:50A
+_41
+09/13 09
+142 09/13 09:17A
+03
+- Continued
+Qnty
+INCOMING
+EW YORK A
+EWYORKZNI N
+NY ZONE 1 NY
+YORK NY
+INCOMING
+NOO MING
+NCOMING
+NEWT
+ORK NY
+COMING
+INCOMING
+Used Rate Description
+1 MIN
+UNLIMITED N/WKND MIN
+1 MIN
+UNLIMITED N/WKND MIN
+UNLIM
+ED N/WKND MIl
+1 MIN
+UNLIM
+1 MIN
+UNLIM
+ED N/WKND MIN
+1 MIN
+UNLIM
+. MIN
+UNLIM
+EB NWIND MIN
+3 MIN
+UNLIM
+ED NWKND MIN
+1 MIN
+1 MIN
+UNLIMITE WIND MIN
+UNLIM
+1 MIN
+MIN
+UNLIMITER NWN MIN
+KND
+2 MIN
+1 MIN
+100 ADD'L
+1 MIN
+2 MIN
+1 MIN
+34440
+IG
+IN
+NY
+(ZN01
+NCOMING
+VPALMBEACH FL
+INCOMING
+NEW
+1Z
+63000
+ORK
+INCOMING
+NCOMING
+NWYRCYZNO1 NY
+INCOMING
+NEW
+ORK NY
+INCOM
+NEW
+NEW
+00002
+NE
+manğanimammann
+IN
+AD
+INL
+LIM
+100
+00
+UNLIM
+INLIM
+INCOMING
+NEW YOR
+ORK NY
+NEW YORKZNI NY
+INCOMING
+NCOMING
+ORK NY
+NEW
+ORK NY
+22222
+400 AD
+
+Called
+Item Date Time
+193 09/14 10:38A
+194 09/14 11:57A
+195 0924 12298
+197 09/14 12:50P
+0924 D2
+200
+09/14 03:17P
+202
+9/24 04:24
+09
+14 05:03
+ROOKLYN N
+PALMBEACH F
+INCOMING
+NEWYORKZNI NY
+INCOMING
+NY ZONE 1 NY
+- Continued
+Qnty
+Used Rate Description
+1 MIN
+400 ADD'L ANYTME MIN
+1 MIN
+400 ADD'L ANYTME MIN
+-111
+MI
+400 ALANE MIN
+2MIN
+400 ADD'L ANYTME MIN
+5 MIN
+1 MIN
+100 ALANYTE MIN
+1 MIN
+400 ADD'L ANYTME MIN
+3 MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+205 09/14 07:43P
+206 09/14 07:45P
+207 09/14 09:11P
+209 09/14 09:59г
+09/14 09:59P
+
+VILLOUGHBY OH
+1 MIN
+1 MIN
+4 MIN
+J ADD'L ANTIME N
+EARLY EVENING N/WKND
+ARLY EVENING N/WKN
+UNLIMITED N/WKND MIN
+UNLINTEB NAWKNB MIN
+1.50
+NY
+•••
+NY
+NY
+888888888888888888888888888g
+IN
+1001801.000005048
+
+
+1001801.000005048
+Item Date Time Called
+257 09/16 01:21P
+258 09/16 01:21P
+259 09/16 01:23P
+260 09/16 01:24P
+09/16 01:25P
+09/16
+01:27P
+263 09/16 01:32P
+266 08 16 8136P
+09/16
+01:39P
+26B 09/16 01:40P
+269 09/16 01:42P
+270 09/16 01:43P
+0/16 01-47
+88888
+09,
+88g
+09,
+09,
+09,
+03
+:43P
+06:45P
+06:47P
+06:49P
+6F
+chai
+06.
+mmma
+688-
+07:19P
+09/16
+07:21P
+09/16
+07:24P
+38
+9-712:09
+mom
+9/1
+011
+09/17 01:50P
+NEWYORKZN1 NY
+INCOMING
+JEW YORK NY
+V PALMBEACH FL
+NCOMING
+NO MINT
+COMIN
+INCOMING
+NEWYORKZN1 NY
+PALMBEACH FL
+WPALMBEACH FL
+WALMACH FE
+37
+BEAC
+FL
+NEW
+YORK NY
+MING
+MING
+MING
+g
+NOR KZNI NY
+RKZN1 NY
+- Continued
+Qnty
+Used Rate Description
+1 MIN
+UNLIM MOBL TO MOBL
+2 MIN
+400 ADD'L ANYTME MIN
+Z MIN
+00 ADD'L ANYTME MI
+1EVT
+ALL WAITIN
+1 MIN
+400 ADD'L ANYTME MIN
+2 MIN
+2 MIN
+2 MIN
+400 ADD'L ANYTME MIN
+MI
+MIl
+L MIN
+> MIN
+1 MIN
+VLIM MOBL TO MOE
+O ADD'L ANYTME MI
+400 ADD'L ANYTME MIN
+NY
+INCOMING
+NEWTORI
+WPALMB
+N
+00020
+NY
+R
+999
+RK
+2222=
+WILLOUGHBY OH
+COMIN
+INCOMING
+NEW ORK NY
+WPALMBEACH FL
+3MIN
+EMIN
+1 MIN
+SMIN
+2 MIN
+IMIN
+1 MIN
+IMIN
+2 MIN
+1 MIN
+2 MIN
+MIN
+. MIN
+MIN
+2 MIN
+1MIN
+2 MIN
+10 MIN
+MIN
+_MIN
+1 MIN
+1 MIN
+2M
+3MIN
+IEVT
+2 MI
+2 MIN
+IEVT
+EMIN
+1 MIN
+400 ADD'L ANYTME MIN
+NLIM MOBL TO MOB
+IE MIN
+100
+UNL
+-2
+UNLIM
+400
+100
+400
+400
+400
+100
+400
+100
+MIN
+WKND
+KN
+KND
+KNI
+MIN
+IN
+I IM
+
+Item Date Time
+Called
+18 09/17 01:54P
+19 09/17 01:55P
+320 09/17 02:02P
+321 09/17 02:05P
+322 09/17 02:10P
+23 09/17 02:18
+24 09/17 02•70
+- Continued
+Used Rate Description
+2 MIN
+400 ADD'L ANYTME MIN
+8 MIN
+100 ADD'L ANYTME MIN
+326 09/7 8230
+327 09/17 02:33P
+28 09/17 02:34
+29 09/17 02:35
+30 09/17 02:39
+31 09/17 03:32
+332 09/17 03:33P
+mmi
+335
+888
+03:36P
+03:39P
+04:40P
+336 09/17 04:59P
+337 09/17 08:53P
+338 09/17 08:55P
+339 09/17 09:10P
+
+g88
+09/18
+
+09/18
+09:55P
+
+366
+09/20 10:55A
+QUEENS NY
+IN COMING
+INCOMING
+INCOMING
+JEW YORK N
+NCOMING
+INCOMING
+INCOMING
+IN COMING
+mobile UK
+ICOMING
+IPALMRFACH F
+ICOMIN(
+ICOMINI
+IN COMING
+INCOMING
+NCOMING
+COMIN
+PALMREACH
+NWYRCYZN01 NY
+INCOMING
+ZONE 1 NY
+NEWYORKZNI NY
+NEWYORKZNI NY
+IN COMING
+COMING
+ICOMING
+BROOKLYN NY
+5 MIN
+11 MIN
+400 ADD'L ANYTME MIN
+MESSAGE RETRIEVAL
+400 ADD'L ANYTME MIN
+EMIN
+1 MIN
+HENN
+3 MIN
+LENT
+1 MIN
+400 ABBL ANY TME MIN
+UNLIM MOBL TO MOBL
+400 ADD'L ANYTME MIN
+COOTTA THE MIN
+UNLIM MOBL TO MOBL
+LEV
+MIN
+2 MIN
+AMIN
+LEV
+1 MIN
+400 ADD'L ANYTME MIN
+NLIM MOBL TO MOE
+ESSAGE RETRIEVA
+UNLIM MOBL TO MOBL
+L MIN
+LEV
+1 MIN
+EARLY EVENING N/WKND
+1MIN I
+1 MIN
+0.28 ENLIMITED NAVKND MIN
+1EVT
+MESSAGE RETRIEVAL
+20 MIN
+1 MIN
+UNLIMITEB WINB MIN
+INLIMITA
+1 MIN
+1 MIN
+INLIMIT
+4 MIN
+UNLIMITED N/KND MIN
+L MIN
+1EVT
+UNLIMITED
+NA
+WKND I
+MIN
+SSAGE RETRIEV
+EVAL
+2 MIN
+UNLIMITED N/KND MIN
+1 MIN
+JNLIMITED NAWKND MIN
+2 MIN
+INLIMITED NAWKND MIN
+1EVT
+MIN
+MESSAGE RETRIEVAL
+2 MIN
+UNLIMITED
+LEV
+MESSAGE RETRIEVAL
+1 MIN
+2 MIN
+UNLIMITI
+UNI
+IMIT
+EB NAW KND MIN
+2 MIN
+UNLIMITED N/WKND MIN
+LMIR
+UNLIMITEB
+UNLIMITED N/WKND MIN
+UNLIMITED NAND MIN
+MESSAGE RETRIEVAL
+INLIMITEL
+IN
+UNLIMITED N/WKND MIN
+UNLIMITE NAND MIN
+2 MIN
+400 ADD'L ANYTME MIN
+UNLIM MOBL TO MOBI
+MESSAG
+E RETRIEVAL
+400 ADD'L ANYTME MIN
+0.28
+
+
+Item Date Time
+Called
+367 09/20 10:56A
+368 09/20 10:59A
+9 09/20 11:00
+0 09/20 11:1
+371 09/20 11:18A
+2 09 20 11:1
+2 0020117
+374 09/20 11:23A
+375 09/20 12:38P
+020 17:55
+378 09/20 01:01P
+
+381 09/20 01:20P
+52 09/20 01:20
+22 00120 01:27
+384 09/20 01:43P
+386 03/20 8L.358
+
+8e9*
+
+388838g
+26F
+18F
+1109
+09/
+®GRARONESI
+
+
+
+(SOP
+:55P
+08R
+• 21P
+:49p
+:1OP
+06:20P
+
+:24P
+CHTAMSTTHS VI
+INCOMING
+- Continued
+Qnty
+Used Rate Description
+4 MIN
+400 ADD'L ANYTME
+1 MIN
+400 ADD'L ANYTME
+18 MIN
+100 ADD'L ANYTME
+1MIN
+1OD ADD'LANYIME
+1 MIN
+400 ADD'L ANYTME
+1 MIN
+400 ADD'L ANYTME
+2 MIN
+400 ADD'L AN
+2 MIN
+400 ADD'L ANYTME MIN
+ORKN
+COMIN
+INCOMING
+QUEENS NY
+NEW
+ORK NY
+BROOKLYN NY
+RK NY
+NEW
+2Z
+mmi
+22:
+FL
+NY ZONE 1 NY
+NEW
+mmi
+IN
+3302
+12000
+ORK
+233
+ICITIES MN
+INC
+G
+INCOMING
+NWYRCYZNO1 NY
+INC
+MING
+YRCYZNO1 NY
+YORK NY
+INCOMING
+INCOMING
+NCOMING
+MING
+INCOMING
+WPALMBEACH FL
+NEW
+NY
+EW
+YORKZNI NY
+2132
+LEIG
+I NY
+NEW Y
+ORK NY
+1 MIN
+2 MIN
+4 MIN
+MI
+MIl
+1 MIN
+1 MIN
+2 MI
+ONNEEEENENE
+3 MIN
+AMIN
+12 MIN
+2 MIN
+13 MIN
+1 MIN
+2 MIN
+400 ADD BATT ME MIN
+400 ADD'L ANYTME MIN
+480 ABB'LANYTME MIN
+400 ADD'L ANYTME MIN
+MO BL
+10D ADDLANTME MI
+NL
+INCI
+
+
+Item Date Time
+Called
+429 09/20 11:49P
+430 09/21 12:10A
+132 09/21 13:124
+433 09/21 12:21A
+434 09/21 12:22A
+435 09/21 12:46A
+136 09/21 01:030
+non
+1 01:10P
+139 09/21 04:59P
+04:59P
+440
+09/21 05:17P
+112
+88
+121 08:46₽
+443
+09/21 08:47P
+09:51P
+NY ZONE ANY
+INCOMING
+- Continued
+Qnty
+Used Rate Description
+1 MIN
+DROP CALL CREDIT
+2 MIN
+UNLIMITED N/WKND MIN
+6 MIN
+3MIN
+2 MIN
+ALEKEA HI
+INCOMING
+EV
+1 MIN
+6 MIN
+1 MIN
+2 MIN
+1 MIN
+4 MIN
+11 MIN
+IMIN
+1 MIN
+4MIN
+LIMITED NAWKND M
+UNLIMITED NWKND MIN
+UNLIMITED NWKND MIN
+WAITING
+UNLIMITED N/WKND MIN
+CLUDED MINUTE
+CLUDED MINULE
+INCLUDED MINUTES
+EARLY EVENING NWNB
+EARLY EVENING N/WKND
+......
+1 MIN
+
+1
+IMIN
+4 MIN
+TIN
+MIN
+1001801.000005049
+
+
+Item Date Time
+Called
+404 09/23 05:39P
+495 09/23 05:39P
+9b 09/23 05:401
+07 09/23 05:43
+NY ZONE 1 NY
+NY ZONE 1 NY
+COMIN
+499 092305:58
+500 09/23 06:16P
+501 09/23 06:17P
+583 89/23 06 31P
+06:31P
+504 09/23 06:32P
+- Continued
+Qnty
+Used Rate Description
+1 MIN
+INCLUDED MINUTES
+1 MIN
+INCLUDED MINUTES
+3 MIN
+MINUTE
+2 MIN
+CLUDED MINUTE
+IEVT
+CALL WAITING
+EMIN
+LUDED MINUTI
+LIM MOBL TO MO
+1 MIN
+INCLUDED MINUTES
+OBL TO MO
+09/23 06:52P
+
+123
+09380
+N23 07:14P
+1B3 8735Р
+124
+12:51P
+09/24 01:20P
+517 09/24 01:21P
+518 09/24 01:26P
+09
+124 02:28Р
+COMIN
+EW YORK N
+INCOMING
+IRMINGHAM A
+EW YORK MY
+BIRMINGHAM AL
+ORK N
+EW YORK N
+INCOMING
+WTORK 1
+NEWYORKZNI NY
+COMING
+COMING
+OMING
+INCOMING
+INCOMING
+EMIN
+1 MIN
+EMIN
+2 MIN
+. MIN
+MIN
+1 MIN
+EMIN
+MIl
+1 MIN
+INCLUDED MINUTES
+INCLUBEB MINUTES
+INCLUDED MINUTES
+O
+30
+0.3
+5MIN
+1EVT
+1MIN
+COMING
+COMING
+1001801.000005049
+09
+09,
+/24
+02:
+522 09724 08 59P
+09/24 10:20P
+09/25
+092
+07:46A
+0:17A
+52B
+09/25
+10:22A
+529
+09/2
+530
+0925
+7:48A
+1.507
+11
+09
+09/25
+8888฿
+125
+02:10P
+02:11P
+188
+02.
+mir
+09
+16P
+03:35P
+888
+03
+182
+03-41P
+546 09/25 03:42P
+547 09/25 03:46P
+548 09/25 07:27P
+INCOMING
+NCOMING
+NY
+ZONE 1 NY
+INCOMING
+MIAMI FL
+INCOMING
+MIAMI F
+NY ZONE 1 NY
+SEWORKS VI
+NEW YORK
+WALYBEACH FL
+NY
+ZONE
+I NY
+NEW
+7N1 NY
+NEW YO
+RK NY
+NY ZONE 8 NY
+EHTAMSTTHS
+CHTAMS
+55
+NY ZONE 1 NY
+CHTAMSTTHS VI
+COMIN
+COMIN
+mobile UK
+mobile UK
+NY ZONE 1 NY
+INCOMING
+IMIN
+1 MIN
+15 MIN
+2 MIN
+2 MIN
+3 MIN
+1 MIN
+2 MIN
+2 MIN
+2 MIN
+1EVT
+MI
+1 MIN
+EV
+2 MIN
+1 MIN
+2 MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+3 MIN
+2 MIN
+2 MIN
+13 MIN
+0.28 ENLI
+8:30
+0.30
+
+Item Date Time Called
+549 09/26 11:55A
+550 09/26 11:56A
+1 09/26 01:2
+2 09/26 03:3
+0-5=
+555 09/27 08:55A
+
+10 09/21 08:59
+177 08-50
+560 09/27 09:01A
+561 09/27 09:02A
+562 09/27 09:35A
+563 09/27 11:00A
+cabanaaaaaan
+88888
+8889
+88g
+88
+888
+19/
+128
+80658
+688 89
+: 27Р
+19219
+CHTAMSTTHS VI
+CHTAMSTTHS VI
+ONE IN
+EW YORK N
+INCOMING
+- Continued
+Onty
+Used Rate Description
+1 MIN
+UNLIMITED N/WKND MIN
+1 MIN
+UNLIMITED N/WKND MIN
+EMIN
+UNLIMITED MAN MIN
+IEVT
+MESSAGE RETRIEVAL
+EMIN
+LIMITED NAVKND M
+LUDED MINUT
+1 MIN
+EMIN
+INCLUDED MINUTES
+INCLUBEB MINUTES
+EMIN
+INCLUBEB MINUTES
+1 MIN
+INCLUDED MINUTES
+LUDED MINUTI
+|I WAITI
+UNLIM MOBL TO MOBL
+TORK
+YOR
+K MY
+INCOMING
+NEWYORKZNI NY
+TW
+IN
+ITI
+IES
+MN
+YORK NY
+CHTAMSTTHS VI
+CHTAMSTTHS VI
+INCOMING
+INCONS
+NCOMING
+NCOMING
+NCOMING
+CINGPRUSSI PA
+mobile ISR
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+IN COMING
+2 MIN
+LEIN
+1EVT
+2MIN
+1 MIN
+HMIN
+3 MIN
+3 M
+4 MIN
+3 MIN
+LENT
+L MIN
+L MIN
+1EVT
+4 MIN
+1 MIN
+1 MIN
+2 MIN
+i MIN
+1EVT
+EMIN
+L MIN
+L MIN
+1 MIN
+Tall
+4 MIN
+2 MIN
+Mil
+1 MIN
+MESSAGE
+DETRICUSI
+LU
+22
+JUU
+4000
+IN
+D
+LU
+33
+IN
+000
+ШІ
+E
+D
+MIN
+CLUDED
+IN
+MI
+LU
+NC
+D
+LU
+INCLUD
+UN
+INCLUDI
+IN
+LU
+NUTES
+NC
+LU
+NUTES
+CLUDED MINUTE
+INLIM MORI TO MOR
+MESSAGE RETRIEVAL
+EARLY
+D
+EARLY EVENING N/WKND
+EVENING NANKI
+CALL WAITING
+EARLY EVENING N/WKND
+UNLIMITED N/KND MIN
+D
+UNLIMITED N/WKND MIN
+AG
+INCLUDED MINUTES
+INCLIM MOBLITO MOBL
+MESSAGE RETRIEVAL
+• MOB
+INCLUDED MINUTES
+INCLUBEB MINUTES
+LUDED MINUTI
+LINED MINUT
+UNLIM MOBL TO MOBL
+ESSAGE RETRIEVA
+NIIM MOI
+O MOBI
+INCLUDED MINUTES
+0.16
+
+
+Item Date Time
+Called
+603 09/29 04:54P
+604 09/29 07:21P
+605 09/30 11:06A
+606 09/30 11:08A
+607 09/30 11:
+608 09/30 11:37.
+618 09/38
+3 85:38F
+8L2 18/00 18:732,
+613 10/01 12:28P
+614 10/01 12:43P
+615 10/02 12:08P
+616 10/02 01:56P
+618 10/02 02:81P
+619 10/02 02:02P
+620 10/02 02:05P
+621 10/02 02:59P
+622 10/02 03:50P
+623 10/02 06:09P
+TOTAL VOICE USAGE FOR
+Item
+Called
+INCOMING
+INCOMING
+QUEENS NY
+YORK NY
+NCOMING
+COMING
+INCOMING
+CHTAMSTTHS VI
+mobile FRA
+INCOMING
+PALMBEACH I
+COMIN
+NCOMING
+- Continued
+Qnty
+Used Rate Description
+1MIN
+INCLUDED MINUTES
+1 MIN
+1EVT
+EARLY EVENING N/WKND
+SSAGE RETRIEVE
+3 MIN
+CLUDED MINUTE
+1MIN
+UNLIM MOBL TO MOBL
+2 MIN
+UNLIM MOBL TO MOBL
+IMIN
+UNLIM MOBL
+TO MOBL
+1EVT
+MESSAGE RETRIEVAL
+2 MIN
+2MIN
+3MIN
+1 MIN
+2 MIN
+1 MIN
+1 MIN
+1EVT
+1 MIN
+CARLY EVENING N/WKND
+NCLUDED MINUTES
+INCLUDED MINUTES
+29 ENH DISC INI.
+CLUDED MINUTE
+UNLIMITED N/WKND MIN
+BREATED NO MIN
+1EVT
+2 MIN
+IMIN
+2 MIN
+3 MIN
+2 MIN
+1EVT
+1 MIN
+1EVT
+IMIN
+WHILE IN UK ---
+Qnty Used
+tion
+INTL
+NY
+NY
+DL FL
+
+UK
+222
+Б25000E5
+ZONE
+YORK
+OMING
+oi
+309Br
+
+0.29
+7.43
+Char
+FONNOOOOONOOWOODAHIONNNNAOOOO
+
+Called
+Item Date Time
+31 09/09 04:364
+32 09/09 04:39A
+3 09/09 09:04A
+14 09/09 09:11A
+35 09/09 10:07A
+36 09/09 10:17A
+37
+09/09 11:42A
+38 09/09 12:24P
+41 09/09 02:40P
+42 09/09 03:00P
+43 09/09 03:51P
+44 09/09 04:14P
+45 09/09 04:14P
+46 09/09 04:34P
+47 09/09 04:44P
+48 09/09 05:09P
+B[0[2565988999
+ğšв§ğ8ğ88888в8$
+BEPDEДЕ250650508658588588 88888
+
+88888
+
+UK
+NY ZONE 1 NY
+INCOMING
+UK
+NW YRCYZNO1 NY
+NWYRCYZN01 NY
+COMIN
+COMIN
+INCOMING
+INCOMING
+COMIN
+INCOMING
+INCOMING
+WHILE IN UK --- - Cont.
+Onty Used
+1 MIN
+23 MIN
+Description
+DISCOUNT INT'L ROAM
+DISCOUNT INT'L ROAM
+DISCOUNT INT'L
+BISCOUNT INT RAM
+1 MIN
+6 MIN
+MI
+1 MIN
+3 MIN
+1 MIN
+MIN
+MI
+MIN
+1 MIN
+L MIN
+1 MIN
+4 MIN
+3 MIN
+DISCOUNT INT'L ROAM
+DISCOUNT
+DISCOUN
+INT'L ROAM
+DISCOUNT
+BIE
+COUNT
+COUNT
+DISCOUNT
+DISC
+DISCOUNT
+ROAM
+BISEOUNT INT'L ROAM
+DISCOUNT INT'L ROAM
+DISCOUNT INT'L ROAM
+DISCOUNT INT'L ROAM
+INT'L
+ROAM
+INTE
+AM
+IN
+
+
+UN
+UN
+NEW
+RK NY
+UNT
+UNT
+OAM
+DA
+DAM
+AM
+AV
+INT'L
+FF
+AM
+AM
+ROAM
+8AM
+IN
+8
+INT'L
+ROAM
+INTE
+8AM
+00000
+22222R
+AM
+20.47
+1.98
+5.34
+2:89
+2.98
+2.89
+
+OOOONOOHOMIOONOO
+
+
+Item Date Time Called
+94 09/11 06:36A
+TOTAL ROAMER USAGE FOR
+Item Date Time Called
+
+3 09/11 08:22A
+TOTAL ROAMER USAGE FOR
+Called
+Item Date Time
+
+89999
+40P
+
+:04P
+:04P
+TOTAL
+INCOMING
+WHILE IN UK --
+WHILE IN UK -- - Cont.
+Onty Used
+1 MIN
+Description
+DISCOUNT INT'L ROAM
+WHILE IN UK ---
+Description
+COMING
+QUEENS NY
+WHILE IN UK -
+Onty Used
+MIN
+2 MIN
+3 MIN
+DISCOUNT INT'L ROAM
+INCOMING
+NEW
+YORK NY
+INC
+IN
+NE
+W
+G
+RK NY
+INCOMIN
+INCOMING
+INC
+OMING
+IN
+G
+INCOI
+NEW
+0200
+NY
+NY
+RK NY
+G
+G
+NC
+NEV
+NEW
+WWY
+WHILE IN SPAIN --
+Onty Used
+2 MIN
+2 MIN
+4 MIN
+TIN
+MIN
+MIN
+MIN
+MIN
+MIN
+Description
+UNT INT'L
+D
+102 8035030828353558853030806233533.
+IS
+
+
+C
+ELLIES
+
+•¡ґ÷|
+05 5 55 5
+
+) AM
+WHILE IN SPAIN -
+
+189.57
+1.98
+2.62
+5.34
+
+Item Date Time Called
+1 09/10 06:36P
+2 09/10 06:50P
+3 09/10 06:50₽
+| 0910 06:518
+5 09/10 06:51P
+TOTAL ROAMER USAGE FOR
+WHILE IN UK -
+INCOMING
+INCOMING
+INCOMING
+WHILE IN UK --
+Onty Used
+1 MIN
+Description
+1 MIN
+1 MIN
+1 MIN
+BISCOUNT INTERN
+DISCOUNT INT'L ROAM
+TEXT/MULTIMEDIA MSGS FOR
+Item Date
+Time
+Sent To/Rcvd From
+2 09105
+09:01P
+3 09/08
+05:44P
+
+6 09/09
+87:24P
+08:02P
+Charge Description
+INTL ROAM TEXT ME&
+INTL ROAM TEXT MSG
+EXT MS
+IN
+MS
+0.89.
+0,89
+4.45
+8:58
+
+) P
+
+TEXT/MULTIMEDIA
+MSG
+USAGE
+FOR
+8.50
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/3fba6623beb36411f0f5083af5374f663290411f3b6af8683c52d5355a2eed21.receipt.json b/vision-fixhub/ds9-unparsed-06/3fba6623beb36411f0f5083af5374f663290411f3b6af8683c52d5355a2eed21.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a233b0710b57c66f6b321a50e2d7e7122bb2e02a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/3fba6623beb36411f0f5083af5374f663290411f3b6af8683c52d5355a2eed21.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -3910,
+  "dataset": "marble-joined",
+  "doc_id": "3fba6623beb36411f0f5083af5374f663290411f3b6af8683c52d5355a2eed21",
+  "engine": "marble-apple-vision",
+  "event_count": 57,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "7fb9e346537f70dd4221c159b12b900cac95cd139b67ba75c0ddc16340973cba",
+  "output_sha256": "1687046e08a87673afae7e0a73aae4cee824c90916da01876cfead2c495b67aa",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/405d0263cbb230f1569132d7f6fd54bed27529432a312684007ee639ce23eb86.md b/vision-fixhub/ds9-unparsed-06/405d0263cbb230f1569132d7f6fd54bed27529432a312684007ee639ce23eb86.md
new file mode 100644
index 0000000000000000000000000000000000000000..e6e7e0c913cbcc31601beed9adee4832e9d7e9a6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/405d0263cbb230f1569132d7f6fd54bed27529432a312684007ee639ce23eb86.md
@@ -0,0 +1,12 @@
+Subject: Non-Prosecution Agreement re Epstein Case
+Date: Wed, 12 Oct 2011 22:05:43 +0000
+Importance: Normal
+Attachments: Fully_executed_NPA.pdf
+Sorry to inundate you. I now understand a bit better wha
+Special Counsel to the U.S.
+Attorney, who is also working on the victims" suit) wants to discuss. He wants to discuss how the Non-
+Prosecution Agreement may limit your ability to prosecute some of Epstein's crimes.
+I have attached a copy of the Non-Prosecution Agreement for you to review, so you will know what we are
+talking about. If you could give us 15-25 minutes tomorrow, it would be most appreciated. Ed is free between
+9:00 and 2:30.
+<<Fully executed NPA.pdf>>
diff --git a/vision-fixhub/ds9-unparsed-06/405d0263cbb230f1569132d7f6fd54bed27529432a312684007ee639ce23eb86.receipt.json b/vision-fixhub/ds9-unparsed-06/405d0263cbb230f1569132d7f6fd54bed27529432a312684007ee639ce23eb86.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a25094aaf467877de1e4bbde03771dcde45b2d63
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/405d0263cbb230f1569132d7f6fd54bed27529432a312684007ee639ce23eb86.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "405d0263cbb230f1569132d7f6fd54bed27529432a312684007ee639ce23eb86",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "08b3d7f55943ceb845eca9d3f083661169c5731e30eeebdf43c7dcd10ab4bd51",
+  "output_sha256": "30ffbaee532d5048172a9272f3ebcd75ac9d8629731cf0cacfce36b5146af949",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/411bdc75f46a846f6bcc7466b75695a38e219628d5d30365fa7e90b02de92bc4.md b/vision-fixhub/ds9-unparsed-06/411bdc75f46a846f6bcc7466b75695a38e219628d5d30365fa7e90b02de92bc4.md
new file mode 100644
index 0000000000000000000000000000000000000000..434de88f8f27063f49a8e2ccd0051b7ba23c6586
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/411bdc75f46a846f6bcc7466b75695a38e219628d5d30365fa7e90b02de92bc4.md
@@ -0,0 +1,55 @@
+From: Paul Cassell <
+To: "
+(USAFLS)" ≤
+P.
+Ce: Brad Edwards <
+Subject: RE: Government's position on two motions
+Date: Wed, 01 Feb 2012 22:30:23 +0000
+Importance: Normal
+(USAFLS)"
+|. (USAFLS)"
+Dear
+Thank you for sending the seal pleading to us electronically last weekend. We really appreciate it.
+We are now working on responding to your reply on the issue of remedies. As you know, the Government has placed the
+entire reply under seal.
+With all due respect, we believe that placing the entire document under seal is inappropriate. The vast majority of the
+issues and arguments in the pleading are not confidential. We believe that placing them under seal violates DOJ policy as
+well as constitutional First Amendment principles.
+Placing the document under seal also creates significant problems for the victims. Just as you have been consulting your
+colleagues in Washington, D.C., on these issues, we have been consulting with our friends in the victims' rights movement
+around the country. Because your document is entirely under seal, it appears that send it to them for their review would
+violate the sealing order.
+In view of these facts, we are writing to ask whether the Government would oppose a motion by the victims that the
+Government file a redacted pleading in the open court file, redacting only information that refers directly and specifically
+to grand jury proceedings. We are planning on filing on unsealed motion to that effect shortly.
+We are also writing to ask what would be the Government's position on an additional motion, asking for unsealing of all
+information mentioned at page 32 n.20 of the Government's pleading (information regarding Epstein's offenses
+committed in other jurisdictions).
+Thank you in advance for providing the Government's position on these issues.
+Paul and Brad
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only
+for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended
+recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error,
+please immediately notify the sender by reply electronic mail and delete the original message. Thank you.
+
+
+From: Paul Cassell
+Sent: Friday, January 27, 2012 1:14 PM
+To:
+(USAFLS) (I
+Cc: 'Brad Edwards'
+Subject: can you send ...?
+(USAFLS) (
+Hey
+I gather from your public filing yesterday you have a sealed response on the remedies issue - which is presumably
+heading towards us in snail mail. Would you be able to send Brad and me an electronic copy today? I want to read it this
+weekend, because I'm pretty jammed up next week.
+Thanks in advance for any help you can extend. Paul
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only
+for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended
+recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error,
+please immediately notify the sender by reply electronic mail and delete the original message. Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/411bdc75f46a846f6bcc7466b75695a38e219628d5d30365fa7e90b02de92bc4.receipt.json b/vision-fixhub/ds9-unparsed-06/411bdc75f46a846f6bcc7466b75695a38e219628d5d30365fa7e90b02de92bc4.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0fdb7e0da09a27347491cf108e45e4c4c9732e75
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/411bdc75f46a846f6bcc7466b75695a38e219628d5d30365fa7e90b02de92bc4.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "411bdc75f46a846f6bcc7466b75695a38e219628d5d30365fa7e90b02de92bc4",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3bb126869d1079da1715ccbe6b0ccc9cf00302c7bb0d3c420ab8065169e70c41",
+  "output_sha256": "18ed23211aaa666700ac2e71b531ee85274eca028ac67263b2501692d568ab70",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/41405fd135c1e4434d149aec7d05b93ff6f070ec2a3bcc6ca4ac91b3e413f651.md b/vision-fixhub/ds9-unparsed-06/41405fd135c1e4434d149aec7d05b93ff6f070ec2a3bcc6ca4ac91b3e413f651.md
new file mode 100644
index 0000000000000000000000000000000000000000..83f3b6a84d8aa5697115862dbdd0a64e84bdf232
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/41405fd135c1e4434d149aec7d05b93ff6f070ec2a3bcc6ca4ac91b3e413f651.md
@@ -0,0 +1,36 @@
+From:
+To:
+Subject: FW: Jeffrey Epstein
+Date: Tue, 22 May 2007 22:33:06 +0000
+Importance: Normal
+(USAFLS)" </0=USA/OU=FLS/CN=RECIPIENTS/CN=
+(USAFLS)"
+fyi
+From:
+(USAFLS)
+Sent: Tuesday, May 22, 2007 6:32 PM
+To:
+Subject: RE: Jeffrey Epstein
+I have your letter. I think we are on the same page, but to be sure I do want to clarify that we spoke the other week and I
+did say that if you want to meet with me again, 1 am ready to do so. The wording of your letter, however, suggests
+implicitly that I agreed to contact you before a decision is made to seek an indictment of Mr. Epstein. If that was your
+understanding, then please allow me to clarify. Our investigation is ongoing and if we decide to seek an indictment, we
+don't intend to call Mr. Epstein's representatives to let him know that. Of course, in the interim, if you would like to make
+a presentation to us, we are willing to listen.
+Along those lines, given the fact that we have already met once, with schedules being what they are, it makes sense for
+our criminal chief, l
+•. to be included when you make another presentation, rather than working up the chain
+incrementally. I realize you were being respectful in not attempting to leapfrog over me, which | appreciate. I will pass
+on your request to meet with the U.S. Attorney as well, but can't commit for him one way or another. When you have
+some dates in mind, let me know and I will try to set up a meeting in Miami.
+From:
+To:
+Cc: |
+[mailto:
+Sent: Tuesday, May 22, 2007 2:05 PM
+(USAFLS)
+I (USAFLS):|
+Subject: Jeffrey Epstein
+attached is a letter seeking meetings, as discussed with you, but with others if it is not resolved. Thanks for your
+attention. Could you email back so that I know you have received this letter?
+Gerald B. Lefcourt, P.C.
diff --git a/vision-fixhub/ds9-unparsed-06/41405fd135c1e4434d149aec7d05b93ff6f070ec2a3bcc6ca4ac91b3e413f651.receipt.json b/vision-fixhub/ds9-unparsed-06/41405fd135c1e4434d149aec7d05b93ff6f070ec2a3bcc6ca4ac91b3e413f651.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..744ffcff206dc2b0fec54cc7084f60ce3801f5ba
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/41405fd135c1e4434d149aec7d05b93ff6f070ec2a3bcc6ca4ac91b3e413f651.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "41405fd135c1e4434d149aec7d05b93ff6f070ec2a3bcc6ca4ac91b3e413f651",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "7e61fc868fd40d658337862118f2ad92e2b63dc32bcae2d524f30192f5715749",
+  "output_sha256": "9fc119d81a76dfcdb5f3b4e17682f3856370b062ead578805217ec43728a30df",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/41468e2f05c63a0f9872ee055ded450b74ada0e33f4f6de32bcab4ec14d3732c.md b/vision-fixhub/ds9-unparsed-06/41468e2f05c63a0f9872ee055ded450b74ada0e33f4f6de32bcab4ec14d3732c.md
new file mode 100644
index 0000000000000000000000000000000000000000..0ddd3b05103db5607da25d642b6276dc61aaacb5
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/41468e2f05c63a0f9872ee055ded450b74ada0e33f4f6de32bcab4ec14d3732c.md
@@ -0,0 +1,18 @@
+From: "Faith A. Friedman"
+To:
+Cc: "Gerald Lefcourt" ≤
+Subject: Subpoenas dated May 31, 2007, to J. Epstein Virgin Islands Foundation, Inc.; J. Epstein &
+Co., Inc.; Epstein Interests; and Financial Trust Company, Inc.
+Date: Tue, 12 Jun 2007 21:44:32 +0000
+Importance: Normal
+Attachments: 2007-06-12
+• to
+w_subpoena_material.pdf
+Dear
+At Mr. Lefcourt's request, I hereby provide you with responses to the subpoenas served on the above entities all
+of which were dated May 31, 200 7. I note that the original, along with the documents referenced therein, was
+sent to your office this afternoon by Federal Express. If you do not receive these items or have any questions
+please do not hesitate to contact Mr. Lefcourt.
+Very truly yours,
+Law Offices of Gerald B. Lefcourt, P.C.
+New York, New York 10021
diff --git a/vision-fixhub/ds9-unparsed-06/41468e2f05c63a0f9872ee055ded450b74ada0e33f4f6de32bcab4ec14d3732c.receipt.json b/vision-fixhub/ds9-unparsed-06/41468e2f05c63a0f9872ee055ded450b74ada0e33f4f6de32bcab4ec14d3732c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..5abb1d9f39e251edc9c12de5c33600c2fbb6468b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/41468e2f05c63a0f9872ee055ded450b74ada0e33f4f6de32bcab4ec14d3732c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "41468e2f05c63a0f9872ee055ded450b74ada0e33f4f6de32bcab4ec14d3732c",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "d0c1b87c16599e779eae905f9e7bb38c8fb5138e327f941f71e689d60dcf28fa",
+  "output_sha256": "cb486365f9a8adf8264b7ccddcbec0f640600b899b959ce3ac3048d2812cf9a5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/41c496f98546e20b831295654268382356e86c3f9a76c4871363dcdb34974e89.md b/vision-fixhub/ds9-unparsed-06/41c496f98546e20b831295654268382356e86c3f9a76c4871363dcdb34974e89.md
new file mode 100644
index 0000000000000000000000000000000000000000..3c46082c2e3e9443cd964cea1d5fd4cd4fba6664
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/41c496f98546e20b831295654268382356e86c3f9a76c4871363dcdb34974e89.md
@@ -0,0 +1,53 @@
+From:
+To:
+Subject: Activity in Case 9:08-cv-80119-KAM Doe |. Epstein Notification of Ninety Days Expiring
+Date: Tue, 23 Feb 2010 15:56:47 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Mermelstein, Stuart on 2/23/2010 at 10:56 AM EST and filed on
+2/23/2010
+Case Name:
+Case Number:
+Filer:
+Doe _ Epstein
+9:08-CV-80119-KAM
+Jane Doe
+Document Number: 474
+Docket Text:
+Notification of Ninety Days Expiring by Jane Doe re [333] Plaintiff's MOTION to Compel
+Responses to Requests for Net Worth Discovery and Incorporated Memorandum of Law filed
+by Jane Doe (Mermelstein, Stuart)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+Bradley James Edwards
+Isidro Manuel Garcia
+Jack Alan Goldberger
+Jack Patrick Hill
+Jeffrey Mare Herman
+Katherine Warthen Ezell
+
+
+Michael James Pike
+Paul G. Cassell
+Richard Horace Willits
+Robert C. Josefsberg
+Robert Deweese Critton, Jr
+Stuart S. Mermelstein
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP dcecfStamp_ID=1105629215 [Date=2/23/2010] [FileNumber=7286946-0
+][2228c25fb7e0d377995631ccea339cf54bb0ea5dd3db2e04b994edac81cбс31f3d2
+fa51b713e3а0dedc47399677e744b373746007bd9dfd892c0f2e9d64893c3]]
diff --git a/vision-fixhub/ds9-unparsed-06/41c496f98546e20b831295654268382356e86c3f9a76c4871363dcdb34974e89.receipt.json b/vision-fixhub/ds9-unparsed-06/41c496f98546e20b831295654268382356e86c3f9a76c4871363dcdb34974e89.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1d0d98f20a41c66af55011d3bd589e2283c6d02a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/41c496f98546e20b831295654268382356e86c3f9a76c4871363dcdb34974e89.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "41c496f98546e20b831295654268382356e86c3f9a76c4871363dcdb34974e89",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "71d90e9f6749d30e2ec0249fba2427e0bccb0108e7ff69dff23ef88a6b1c450d",
+  "output_sha256": "81a3054e624bccc242de12c79526cacb2610956516a2c8e2b2309eb420677979",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/41fb76a9afb6ea735bff888c99e8e3805d6efbac41737e2af514b0183fd22860.md b/vision-fixhub/ds9-unparsed-06/41fb76a9afb6ea735bff888c99e8e3805d6efbac41737e2af514b0183fd22860.md
new file mode 100644
index 0000000000000000000000000000000000000000..34ad729797c7258d3d88db2443a881be1c2aa32f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/41fb76a9afb6ea735bff888c99e8e3805d6efbac41737e2af514b0183fd22860.md
@@ -0,0 +1,54 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov»
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80736-KAM Doe |. United States of America Notice of Supplemental
+Authority
+Date: Wed, 12 Jun 2013 15:38:26 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Edwards, Bradley on 6/12/2013 at 11:38 AM EDT and filed on
+6/12/2013
+Case Name:
+Case Number:
+Filer:
+Document Number: 185
+Doe | United States of America
+9:08-cv-80736-KAM
+Jane Doe
+Docket Text:
+Notice of Supplemental Authority re [180] Clerks Notice of Docket Correction and Instruction to
+Filer - Attorney, Jane Doe #1 and Jane Doe #2 Supplemtnal Authority in Support of Motion for
+Court to Deny the Government's Motion to Dismiss Based on Existing Pleadings or, at the
+Minimum, Allow Leave to File A Sur-Reply by Jane Doe (Edwards, Bradley)
+9:08-cv-80736-KAM Notice has been electronically mailed to:
+Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov, shawn.ball@usdoj.gov
+Bradley James Edwards brad@pathtojustice.com, ecf@pathtojustice.com
+Bruce Reinhart breinhart@mcdonaldhopkins.com, asabater@mcdonaldhopkins.com,
+bschwartz@mcdonaldhopkins.com
+Dexter Lee dexter.lee@usdoj.gov, Elda.Louis-Charles@usdoj.gov, grazy.banegas@usdoj.gov, USAFLS-
+HQDKT@usdoj.gov
+Jacqueline Perczek pleading@royblack.com, JackieP@royblack.com
+Jay C. Howell jay@jayhowell.com
+
+
+Jay P. Lefkowitz lefkowitz@kirkland.com
+Martin G. Weinberg owlmgw@att.net
+Paul G. Cassell cassellp@law.utah.edu
+Roy Eric Black pleading@royblack.com
+9:08-cv-80736-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP dcecfStamp_ID=1105629215 [Date=6/12/2013] [FileNumber=11428590-
+0] [6512372fla18d36c99ce25fc24445674f990cd5022c58517824150abb6494f0a2d
+96cefcd743880961fc9c6b53820f3638dae4973ef6f16e500d8d86665681d6]]
diff --git a/vision-fixhub/ds9-unparsed-06/41fb76a9afb6ea735bff888c99e8e3805d6efbac41737e2af514b0183fd22860.receipt.json b/vision-fixhub/ds9-unparsed-06/41fb76a9afb6ea735bff888c99e8e3805d6efbac41737e2af514b0183fd22860.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d2200131ea10561fb2ac7a407dcf37bb3e6f5916
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/41fb76a9afb6ea735bff888c99e8e3805d6efbac41737e2af514b0183fd22860.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "41fb76a9afb6ea735bff888c99e8e3805d6efbac41737e2af514b0183fd22860",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "07463fe28fa90344e6a7262e612f68d868c3673ae8c6aa534bb1cd324a3853e2",
+  "output_sha256": "1ca1bb8701179a70cc869ba35baf3860432ea3d510a15fdb617a6419b2cee287",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/421829e851c189afc434fbb5c19c488fff0977ea8b090b3f2201df1c11cca8dc.md b/vision-fixhub/ds9-unparsed-06/421829e851c189afc434fbb5c19c488fff0977ea8b090b3f2201df1c11cca8dc.md
new file mode 100644
index 0000000000000000000000000000000000000000..488235ff3bf9e04ea390c6624a56eb5ef86123df
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/421829e851c189afc434fbb5c19c488fff0977ea8b090b3f2201df1c11cca8dc.md
@@ -0,0 +1,46 @@
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+DELIVERY BY FACSIMILE
+Martin G. Weinberg, Esq.
+20 Park Plaza, Suite 1000
+Boston, MA 02116
+Re:
+Jeffrey Epstein
+Dear Mr. Weinberg:
+Thank you for your letter of July 22, 2011. In order to review and address the objections that
+you raised in that letter, the Office deferred making its planned disclosure to the District Attorney
+of the County of New York of the Non-Prosecution Agreement ("Agreement"') and the list of
+identified victims that was provided to Mr. Epstein pursuant to the Agreement. Nonetheless, after
+completing a full review of your objections, the Office still intends to proceed with the planned
+disclosures.
+The Agreement requires the Office only to provide Mr. Epstein with notice prior to a
+disclosure of the Agreement "i]f the United States receives a Freedom of Information Act request
+or any compulsory process"; the Agreement does not require Mr. Epstein's concurrence in any
+disclosure. Contrary to your suggestion, the Agreement (including paragraph 13) also does not make
+the Agreement itself "confidential." On the contrary, the Agreement expressly contemplates that
+disclosures of the Agreement may be made, and the Agreement further contemplates, contrary to
+your suggestion, that such disclosures of the Agreement may be made other than in response to
+"compulsory process." Here, moreover, the District Attorney of the County of New York, as a local
+law enforcement agency, has provided a legitimate request for disclosure of the requested
+information, as well as a promise to maintain the confidentiality of the information, particularly the
+names of the minor victims.
+Your objection pursuant to Federal Rule of Criminal Procedure 6(e) also does not impact the
+planned disclosures. The victim list itself is not grand jury material, and, thus, disclosure of that list
+to the District Attorney's Office will not violate Rule 6(e).
+If you wish to supply any additional authority (other than citation to Rule 6(e) and to
+paragraph 13 of the Agreement) for your claims that the Office cannot disclose the Agreement and
+
+
+MARTIN WEINBERG, ESQ.
+JULY 27,2011
+
+the victim list to the District Attorney of the County of New York, we would be willing to consider
+those authorities before making any disclosure, provided that any such authorities are furnished to
+us before 5:00 p.m. on July 29, 2011. Otherwise, seeing no obstacle to the previously-planned
+disclosures, the Office will be disclosing copies of both the Non-Prosecution Agreement and the list
+of identified victims that was provided to Mr. Epstein to the District Attorney of the County of New
+York at 5:00 p.m. on July 29, 2011.
+Sincerely,
+Wifredo A. Ferrer
+United States Attorney.
diff --git a/vision-fixhub/ds9-unparsed-06/421829e851c189afc434fbb5c19c488fff0977ea8b090b3f2201df1c11cca8dc.receipt.json b/vision-fixhub/ds9-unparsed-06/421829e851c189afc434fbb5c19c488fff0977ea8b090b3f2201df1c11cca8dc.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ad24c92731fbf40084d5189d02ec5b6db680f314
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/421829e851c189afc434fbb5c19c488fff0977ea8b090b3f2201df1c11cca8dc.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -35,
+  "dataset": "marble-joined",
+  "doc_id": "421829e851c189afc434fbb5c19c488fff0977ea8b090b3f2201df1c11cca8dc",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "a9b2fe97d9b28045ef1044cbbfba41ca09f1fc8f3a659d152c030d3fbfd8ddb2",
+  "output_sha256": "e4c5e38301cfd426df3ee597fd4b91b246a1667b7c32ebbda0815100973994c7",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4225adcc6e46d75329963062230d9b34155acfb6b9afa42b2776d653b05a64d6.md b/vision-fixhub/ds9-unparsed-06/4225adcc6e46d75329963062230d9b34155acfb6b9afa42b2776d653b05a64d6.md
new file mode 100644
index 0000000000000000000000000000000000000000..14f1c682fb3a598a001280b50c012d43b1323a4f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4225adcc6e46d75329963062230d9b34155acfb6b9afa42b2776d653b05a64d6.md
@@ -0,0 +1,11 @@
+To: Roy BLACK <RBLACK @royblack.com»
+Subject: RE: Jeffrey Epstein -- CORRECT ATTACHMENT
+Date: Tue, 23 Feb 2010 20:25:13 +0000
+Importance: Normal
+Dear Roy:
+Thank you for your letter.
+Regards,
+From: Roy BLACK [mailto:RBLACK@royblack.com]
+Sent: Friday, February 19, 2010 8:05 PM
+Subject: Jeffrey Epstein -- CORRECT ATTACHMENT
+Attached please find the correct attachment of the pdf of a letter being mailed today.
diff --git a/vision-fixhub/ds9-unparsed-06/4225adcc6e46d75329963062230d9b34155acfb6b9afa42b2776d653b05a64d6.receipt.json b/vision-fixhub/ds9-unparsed-06/4225adcc6e46d75329963062230d9b34155acfb6b9afa42b2776d653b05a64d6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..95ecb36e16815b165c557ef429d19e51963baa78
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4225adcc6e46d75329963062230d9b34155acfb6b9afa42b2776d653b05a64d6.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "4225adcc6e46d75329963062230d9b34155acfb6b9afa42b2776d653b05a64d6",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "a02366c1b1396f8679be9f5a3f3a38f430a743e5b5b48aeb843011ce2870039e",
+  "output_sha256": "3e62fcc43999c6823dd67e21d08da4185971d72bed0c7bc95e3d17e5324d5329",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/44c2689f3e729197bf811647b66ea529f2d715c9b23f24eac33012971465b1fe.md b/vision-fixhub/ds9-unparsed-06/44c2689f3e729197bf811647b66ea529f2d715c9b23f24eac33012971465b1fe.md
new file mode 100644
index 0000000000000000000000000000000000000000..daa4672f2bc671a70d1b1afb05965a43d9fc3a35
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/44c2689f3e729197bf811647b66ea529f2d715c9b23f24eac33012971465b1fe.md
@@ -0,0 +1,60 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80119-KAM Doe |. Epstein Order
+Date: Tue, 09 Mar 2010 15:19:48 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. Distriet Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 3/9/2010 at 10:19 AM EST and filed on 3/9/2010
+Case Name:
+Doe | Epstein
+Case Number:
+9:08-cv-80119-KAM
+Filer:
+Document Number: 482
+Docket Text:
+JOINT AGREED ORDER on [405] MOTION For Order for the preservation of evidence filed by
+Jeffrey Epstein. Signed by Magistrate Judge Linnea R. Johnson on 3/9/2010. (sa)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+ahorowitz@sexabuseattorney.com
+Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com
+Isidro Manuel Garcia
+isidrogarcia@bellsouth.net
+Jack Alan Goldberger jagesq@bellsouth.net, nalanis@agwpa.com
+Jack Patrick Hill
+jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com,
+sas@searcylaw.com, vat@searcylaw.com
+Jeffrey Mare Herman
+jherman@hermanlaw.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+Michael James Pike MPike@bclclaw.com, bobbie@bclclaw.com, jcadwell@bclclaw.com
+
+
+Paul G. Cassell cassellp@law.utah.edu
+Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com
+Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton@podhurst.com,
+mestrada@podhurst.com
+Robert Deweese Critton, Jr rerit@belclaw.com, bobbie@bclelaw.com
+Stuart S. Mermelstein ssm@sexabuseattorney.com, jarbour@sexabuseattorney.com,
+Irivera(@sexabuseattorney.com
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+Martin G. Weinberg
+20 Park Plaza
+Boston, MA 02116
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=3/9/2010] [FileNumber=7336772-0]
+[5847a42231d33f2cleb797057121cd0f001bc3b49b9cca832bb5elc01be9081455bc
+e3b711617a7bb8bea493ca5e56027bbd12c35af83f9e46c97a6la09d855c]]
diff --git a/vision-fixhub/ds9-unparsed-06/44c2689f3e729197bf811647b66ea529f2d715c9b23f24eac33012971465b1fe.receipt.json b/vision-fixhub/ds9-unparsed-06/44c2689f3e729197bf811647b66ea529f2d715c9b23f24eac33012971465b1fe.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a7c6c83988086f67f42ba517db1d9972fe518af3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/44c2689f3e729197bf811647b66ea529f2d715c9b23f24eac33012971465b1fe.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "44c2689f3e729197bf811647b66ea529f2d715c9b23f24eac33012971465b1fe",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e3987d8ec697d83bc7c3ef33e40213877940fd7620524ac93e80d90e26ad1250",
+  "output_sha256": "a3139dd01db5628e16466632a599f5c4e2fd8c4bfe32f3fe6ee41334cd16b536",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/451609479066534abd2440759cc099de494aae5bfc764c814c225a5b4489498c.md b/vision-fixhub/ds9-unparsed-06/451609479066534abd2440759cc099de494aae5bfc764c814c225a5b4489498c.md
new file mode 100644
index 0000000000000000000000000000000000000000..ddb5e73418b4cc8255333976efc8b2acb1e0ad5c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/451609479066534abd2440759cc099de494aae5bfc764c814c225a5b4489498c.md
@@ -0,0 +1,254 @@
+Case 9:08-cv-80736-KAM Document 41 Entered on FLSD Docket 10/27/2010 Page 1 of 9
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOES #1 and #2
+V.
+UNITED STATES
+JANE DOE #1 AND JANE DOE #2'S STATUS REPORT AND RESPONSE TO
+COURT'S ORDER TO SHOW LACK OF PROSECUTION
+Jane Doe #1 and Jane Doe #2 ("the victims"), through counsel, file the response to
+Court's order to file a status report and show cause regarding prosecution of the case (DE 40).
+BACKGROUND
+As the Court is aware, it entered an order administratively closing this case on September
+9, 2010 (DE 38). That order recited the fact that Jane Doe #1 and Jane Doe #2 had recently
+settled their civil cases with Jeffrey Epstein as the basis for closure. On September 13, 2010, the
+victims promptly filed a notice that, while they had settled their case with Jeffrey Epstein, they
+had reached no settlement with the U.S. Attorney's Office and intended to make filings in this
+case shortly (DE #39). The victims requested administrative reopening of the case and, if the
+Court deemed it advisable, a prompt scheduling conference with the U.S. Attorney's Office
+regarding the case. The victims also advised that they had only recently received important
+correspondence between the U.S. Attorney's Office and Epstein proving that there had been an
+orchestrated decision to deny them their rights.
+On October 8, 2010, the Court entered an order directing the victims to file a status report
+and show cause why the case should not be dismissed for want of prosecution.
+1
+
+
+Case 9:08-cv-80736-KAM Document 41 Entered on FLSD Docket 10/27/2010 Page 2 of 9
+STATUS REPORT
+As the Court is aware from the victims' filing on September 13, 2010 (DE 39), the
+victims have now received important evidence that allows them to file a comprehensive motion
+explaining the factual background underlying the denials of their rights under the Crime Victims
+Rights Act and the legal reasons for concluding that their rights under the Act have been
+violated. Over the last several weeks, the victims have prepared a full motion to that effect -
+accompanied by a detailed factual and legal memorandum. They planned to file the motion and
+memorandum today, simultaneously with this pleading. The motion they have fully prepared is
+in the nature of summary judgment motion (with a proposed set of undisputed facts), although
+the exact procedures for CVRA cases are unclear.
+In an effort to narrow and resolve disputes in this case, the victims had previously
+notified the U.S. Attorney's Office that it was going to be filing such a motion and
+accompanying statement of facts. They had requested the U.S. Attorney's Office review the
+facts and identify which ones were disputed. On October 22, 2010, the U.S. Attorney's Office
+responded with an e-mail: "The government will review your statement of facts and we will
+agree to a factual assertion if we believe it is correct." On October 23, 2010, the victims e-
+mailed to the U.S. Attorney's Office a detailed proposed statement of facts, with many of the
+facts documented by correspondence between the U.S. Attorney's Office and Epstein's counsel.
+The victims requested that the U.S. Attorney's Office identify which facts it would agree to and
+which it would not. In a letter to the U.S. Attorney's Office, the victims stated:
+If you believe that any of the facts they propose are incorrect, Jane Doe #1 and
+ine Doe #2 would reiterate their long-standing request that you work with us 1
+rrive at a mutually-agreed statement of facts. As you know, in the summer c
+2O0s Jane Doe #l and Jane Doe #2 were working with you on a stipulation o
+acts when you reversed course and took that position that no recitation of th
+facts was necessary (see doc. #19 at 2). In particular, on July 29, 2008, you filed
+2
+
+
+Case 9:08-cv-80736-KAM Document 41 Entered on FLSD Docket 10/27/2010 Page 3 of 9
+a Notice to Court Regarding Absence of Need for Evidentiary Hearing (DE. 17).
+At that time, you took the position that, because no federal criminal charges had
+been filed in the Southern District of Florida, no additional evidence was required
+to decide the victims' petition that was before the Court. I hope that your e-mail
+means that you will at least look at our facts and propose any modifications that
+you deem appropriate. Having that evidence quickly available to the Court could
+well help move this case to a conclusion.
+As you also know, because of the Government's decision not to work with
+us on agreed facts, we have had to secure information regarding the basis for your
+Office's treatment of the victims from other sources. This has been an arduous
+process, since the only remaining source for much of the information was Jeffrey
+Epstein. As you know, he is a politically-connected billionaire that employs
+legions of attorneys to obstruct any efforts to obtain information from him.
+Fortunately, after extended litigation, on June 30, 2010, we obtained information
+from him that was highly relevant to the treatment of Jane Doe #1 and Jane Doe
+#2 in the criminal justice system - namely, correspondence between your Office
+and legal counsel for Jeffrey Epstein during the negotiations surrounding the nonprosecution agreement. Many of our "facts" come straight from these e-mails. I
+trust that you will agree that our recitations of the e-mails are correct and that they
+accurately reflect communications between your Office and Epstein's legal
+counsel during the plea negotiation process.
+That same day, the U.S. Attorney's Office agreed to forward the proposed statement of facts to
+the appropriate Assistant U.S. Attorney for review.
+On October 26, 2010, rather than stipulate to undisputed facts, the U.S. Attorney's Office
+contacted the victims' attorneys and asked them to delay the filing of their motion for a twoweek period of time so that negotiations could be held between the Office and the victims in an
+attempt to narrow the range of disputes in the case and to hopefully reach a settlement resolution
+without the need for further litigation. Negotiations between the victims and the U.S. Attorney's
+Office then followed over the next two days. However, at 6:11 p.m. on October 27, 2010 - the
+date on which this pleading is due - the U.S. Attorney's Office informed the victims that it did
+not believe that it had time to review the victims' proposed statement of facts and advise which
+were accurate and which were inaccurate. The Office further advised the victims that it believed
+that the victims did not have a right to confer with their Office under the CVRA in this case
+3
+
+
+Case 9:08-cv-80736-KAM Document 41 Entered on FLSD Docket 10/27/2010 Page 4 of 9
+because in its view the case is "civil" litigation rather than the criminal litigation. The Office,
+however, indicated it was willing to nonetheless meet with the victims.
+Purely as an accommodation to the U.S. Attorney's Office, the victims have therefore
+agreed to delay filing their motion for up to two-weeks to see if negotiations can resolve (or
+narrow) the disputes with the U.S. Attorney's Office. The U.S. Attorney's Office has
+represented that settlement discussions would be more difficult if the victims filed their motion
+today. The victims, however, have requested that the U.S. Attorney's Office immediately begin
+preparing their response to the motion so that it can file a response without any further delay.
+The victims also further state that they reserve the right to immediately file their motion and
+memorandum as soon as they believe that further negotiations are not productive.
+If no resolution of the case is achieved in the next two weeks - and if the Court does not
+direct a more expedited schedule in the meantime'
+-- the victims would propose the following
+schedule for bringing this case to a conclusion:
+November 10, 2010 (or earlier if directed by the Court or decided by the victims) - Victims file
+their comprehensive motion and supporting memorandum.
+November 24, 2010 -- U.S. Attorney's Office files response to the victims" motion.
+December 3, 2010 - Victims' file Reply to the U.S. Attorney's Response.
+Evidentiary Hearing (if facts contested) - early December, at a time convenient to the Court.
+January 1, 2011 - Court issues ruling on whether victims' rights were violated.
+If the Court enters a finding that the victims' rights were violated, then ....
+January 14, 2011 - Victims brief on the appropriate remedy for a violation;
+1 The victims understand the Court's show cause order to require them to file today a pleading
+explaining the status of the case and showing why the case should not be dismissed for failure to
+prosecute - not a comprehensive motion for resolution of all claims. If the victims are mistaken
+and the Court is directing that they file a comprehensive motion by today's date, the victims
+would respectfully ask leave to promptly make such a filing on any date the Court may direct.
+The victims would note that the U.S. Attorney's Office has also indicated its understanding that
+no such comprehensive motion need be filed by the victims today to comply with the Court's
+order.
+4
+
+
+Case 9:08-cv-80736-KAM Document 41 Entered on FLSD Docket 10/27/2010 Page 5 of 9
+January 28, 2011 -- U.S. Attorney's Office (and any other interested person) files response to
+victims' remedy brief.
+February 4, 2011 - Victims reply on remedy issues.
+Hearing if necessary - mid-February, at a time convenient to the Court.
+This proposed schedule would allow Jane Doe #1 and Jane Doe #2 to have their case
+fully resolved on the merits within the next few months. The victims would have no objection to
+the Court accelerating the schedule. The victims understand that the U.S. Attorney's Office
+would like a slower schedule to resolve this matter - specifically 30 days for them to file a
+response.
+THE CASE SHOULD NOT BE DISMISSED FOR LACK OF PROSECUTION
+Jane Doe #1 and Jane Doe #2 should not have their case dismissed for lack of prosecution
+for the simple reason that they have not failed to prosecute it. To the contrary, as will be
+recounted more fully in the statement of facts contained in their motion for a finding of violation
+of their rights, they have been attempting to secure information that would help prove their case.
+(If the Court wishes, the victims are prepared to file immediately more information on this
+point.)
+Although the victims will rely on all of the information contained in the statement of facts
+that they are preparing to file, in the interest of a brief summary the victims would note that they
+have been diligently attempting to secure correspondence between Epstein and the U.S.
+Attorney's Office regarding the non-prosecution agreement reached in this case. After the U.S.
+Attorney's Office declined to provide the information, the victims sought to secure that
+information as part of their civil lawsuits against Epstein. Because of protracted litigation from
+Epstein's battery of lawyers, the victims did not secure any of the correspondence they sought
+until June 30, 2010. Even then, they secured only part of that correspondence - litigation to
+secure the rest of that correspondence continues to this day.
+5
+
+
+Case 9:08-cv-80736-KAM Document 41 Entered on FLSD Docket 10/27/2010 Page 6 of 9
+The victims have also never been asked by the U.S. Attorney's Office to accelerate the
+resolution of this case. During the last year, the victims' counsel have been in contact with the
+U.S. Attorney's Office on numerous matters related to Jeffrey Epstein, including contacts with
+the two attorneys who appear to be
+handling this CVRA matter for the U.S. Attorney's Office. At no time did anyone in the U.S.
+Attorney's Office ask the victims to begin moving more quickly to resolve this case. Counsel for
+the U.S. Attorney's Office have never contacted the victims about any problems that any delay
+was causing.
+During the last two days, the victims have asked the U.S. Attorney's Office
+whether they have been prejudiced by the passage of time in this case. The U.S. Attorney's
+Office has declined to explain how (if at all) it has been prejudiced.
+The victims would also note that the Court has never advised them of a deadline for
+moving forward with their CVRA case. The victims also knew that the Court was aware of the
+intense and protracted litigation what was proceeding with Epstein in the various civil cases
+against him. It seemed reasonable to the victim to resolve those cases first and then turn to the
+CVRA case - and the victims assumed that the Court was also proceeding on this approach, as
+the victims never received any inquiry from the Court about their CVRA case until the
+September 2010 order "administratively" closing the case. Within 5 days of receiving that
+communication from the Court, the victims promptly advised the Court of their intent to continue
+moving forward with the case and suggesting a scheduling conference if the Court deemed it
+advisable.
+The victims have now proposed a specific schedule that will bring this matter to a final
+conclusion in the next few months.
+In fact, the victims feel their case is strong and were
+prepared to file the equivalent of a Summary Judgment Motion today and only delayed that filing
+6
+
+
+Case 9:08-cv-80736-KAM Document 41 Entered on FLSD Docket 10/27/2010 Page 7 of 9
+at the insistence of the U.S. Attorney's Office. There is no reason to dismiss the case
+precipitously now on the eve of a final resolution.
+The Eleventh Circuit has repeatedly noted that dismissal with prejudice is an "extreme
+sanction" and "is plainly improper unless and until the district court finds a clear record of delay
+or willful conduct and that lesser sanctions are inadequate to correct such conduct." Betty K
+Agencies, Ltd. |. M/| MONADA, 432 F.3d 1333, 1338-39 (11th Cir.2005). In this case, there is
+no clear record of delay or willful conduct. To the contrary, there is a pattern of the victims
+diligently attempting to secure evidence (i.e., the correspondence) vital to their case in the face of
+determined opposition from both the U.S. Attorney's Office and a billionaire sex offender
+represented by a battery of attorneys. The Eleventh Circuit has held that simple negligence in
+meeting a court-imposed deadline is not sufficient to warrant dismissal. See McKelvey v. AT & T
+Techs, Inc., 789 F.2d 1518, 1520 (11th Cir.1986) (per curiam). Here, there is not even
+negligence, as the victims have not failed to meet any deadline that the Court has set.
+In addition, the victims today stand ready to bring the case to an expeditious conclusion
+on the schedule they propose. On September 13, 2010, the victims also suggested to the Court
+that a scheduling conference would be one way to proceed in this case - a suggestion that they
+continue to offer to the Court. The Government - the other party in the case - has asked the
+victims to move more slowly on this matter and has (as of yet) declined to indicate which facts it
+is disputing in this case and which facts it is stipulating to. The victims continue to actively
+participate in on-going settlement negotiations with the U.S. Attorney's office to resolve this
+case, and should those negotiations break down, then the victims are prepared to litigate the
+issues raised in this action on an expedited schedule. In view of these circumstances, there is no
+basis for dismissing the case.
+7
+
+
+Case 9:08-cv-80736-KAM Document 41 Entered on FLSD Docket 10/27/2010 Page 8 of 9
+CONCLUSION
+The Court should establish the schedule proposed by the victims and bring this case to a
+conclusion on the merits as the victims propose.
+DATED: October 27, 2010
+Respectfully Submitted,
+s/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+and
+Paul G. Cassell
+Pro Hac Vice
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Attorneys for Jane Doe #1 and Jane Doe #2
+8
+
+
+Case 9:08-cv-80736-KAM Document 41 Entered on FLSD Docket 10/27/2010 Page 9 of 9
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on October 27, 2010 I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document
+is being served this day on all parties on the attached Service List in the manner specified, either
+via transmission of Notices of Electronic Filing generated by CM/ECF or in some other
+authorized manner for those parties who are not authorized to receive electronically filed Notices
+of Electronic Filing.
+Attorney for United States
+U.S. Attorney's Office
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401
+/s/ Bradley J. Edwards
+Bradley J. Edwards
+SERVICE LIST
+Jane Does 1 and 2 v. United States
+United States District Court, Southern District of Florida
+Case No. 08-80736-CIV-MARRA/JOHNSON
+Attorney for United States
+United States Attorney's Office
+99 N.E. 4" Street
+Miami, FL 33132
diff --git a/vision-fixhub/ds9-unparsed-06/451609479066534abd2440759cc099de494aae5bfc764c814c225a5b4489498c.receipt.json b/vision-fixhub/ds9-unparsed-06/451609479066534abd2440759cc099de494aae5bfc764c814c225a5b4489498c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a62f00d601028e70191c6800c09e94db02307019
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/451609479066534abd2440759cc099de494aae5bfc764c814c225a5b4489498c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -112,
+  "dataset": "marble-joined",
+  "doc_id": "451609479066534abd2440759cc099de494aae5bfc764c814c225a5b4489498c",
+  "engine": "marble-apple-vision",
+  "event_count": 11,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "c3030f2c0207112588c7384cc1b360a4fb97eb73c7d78c200e693abd226367c2",
+  "output_sha256": "bf9bb080732bd729af3ffadcc232109f407c8999f9cb7f93ac8f20c9078f5f0a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/458729f3673c49b849360bb85da0424295a656ce42b88e1e4fd5ef1fe8e7788e.md b/vision-fixhub/ds9-unparsed-06/458729f3673c49b849360bb85da0424295a656ce42b88e1e4fd5ef1fe8e7788e.md
new file mode 100644
index 0000000000000000000000000000000000000000..c752106014098e5cf4fd78749b0c72866afc0e2b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/458729f3673c49b849360bb85da0424295a656ce42b88e1e4fd5ef1fe8e7788e.md
@@ -0,0 +1,14 @@
+Subject: FOIA Request
+Date: Wed, 20 Jul 2011 01:30:21 +0000
+Importance: Normal
+Attachments: 20110720113911.pdf; 20110719_
+_tr_ to
+_Black.wpd
+I received the attached letter from an Assistant District Attorney in New York regarding the
+investigation of Jeffrey Epstein. She is asking for two discrete items that she needs to prepare her response to an
+appeal of his sex offender registration status in New York, which is directly related to these items. I have
+prepared the attached letter to Mr. Epstein's counsel regarding Section 552.
+Can you review and give me your position?
+Thank you.
+<<20110720113911.pdf>> <<20110719
+_tr to Black.wpd>>
diff --git a/vision-fixhub/ds9-unparsed-06/458729f3673c49b849360bb85da0424295a656ce42b88e1e4fd5ef1fe8e7788e.receipt.json b/vision-fixhub/ds9-unparsed-06/458729f3673c49b849360bb85da0424295a656ce42b88e1e4fd5ef1fe8e7788e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ae2d8415f3fa59282aef647bd521e6c8f423059e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/458729f3673c49b849360bb85da0424295a656ce42b88e1e4fd5ef1fe8e7788e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "458729f3673c49b849360bb85da0424295a656ce42b88e1e4fd5ef1fe8e7788e",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "9d86c97610ed07a89e10b742688b6dd4bc366c7f0ea7f3955610a57efd86d839",
+  "output_sha256": "96285c5cd74c6de2a80a3896813a85e6f1ce2c99951485afeb5c8c75aa14c46a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/45f1df04c2885df955ec06ab9a13e2ee0e1fbac8937f465b8d141b99528478cb.md b/vision-fixhub/ds9-unparsed-06/45f1df04c2885df955ec06ab9a13e2ee0e1fbac8937f465b8d141b99528478cb.md
new file mode 100644
index 0000000000000000000000000000000000000000..1a910556453347974636dc5712075cf01628b3ed
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/45f1df04c2885df955ec06ab9a13e2ee0e1fbac8937f465b8d141b99528478cb.md
@@ -0,0 +1,21 @@
+From:
+To:
+Subject: RE: Epstein
+Date: Tue, 12 Jan 2010 15:41:32 +0000
+Importance: Normal
+Yes, I was aware. The Judge was going to allow him to travel to New York to meet with attorneys on his civil lawsuits. I
+wanted restrictions and got them.
+From:
+- (USAFLS) [I
+Sent: Tuesday, January 12, 2010 10:22 AM
+To:
+Subject: Epstein
+Hi
+- This was just sent to me by someone in my office. In light of other instances where Mr. Epstein's
+counsel has falsely represented that something was agreed to, I just wanted to check with you to make certain
+that you were aware of, and joined in, the motion. Can you let me know?
+Thank you. (And Congratulations on your promotion!)
+<<20100111143503.pdf>>
+Assistant U.S. Attorney
+500 E. Broward Blvd, 7th Floor
+Ft Lauderdale, FL 33394
diff --git a/vision-fixhub/ds9-unparsed-06/45f1df04c2885df955ec06ab9a13e2ee0e1fbac8937f465b8d141b99528478cb.receipt.json b/vision-fixhub/ds9-unparsed-06/45f1df04c2885df955ec06ab9a13e2ee0e1fbac8937f465b8d141b99528478cb.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2ff65c17a5b6c62f9158b18f18be79b9cf071bb5
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/45f1df04c2885df955ec06ab9a13e2ee0e1fbac8937f465b8d141b99528478cb.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -291,
+  "dataset": "marble-joined",
+  "doc_id": "45f1df04c2885df955ec06ab9a13e2ee0e1fbac8937f465b8d141b99528478cb",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.disclaimer-removal.please-note-florida\"]",
+  "idempotent": true,
+  "input_sha256": "5720369cd600c071b774b3e0be4054ed9a288a56a9f5a117be02297032535b25",
+  "output_sha256": "8346859b071f0ffbca6670730ca973e73642d2d2efe0377a725b0136cab0b25e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/45f7117f9177dd23c5707343135b9daf2d1eabe4747fc6a446a3761ea72ef273.md b/vision-fixhub/ds9-unparsed-06/45f7117f9177dd23c5707343135b9daf2d1eabe4747fc6a446a3761ea72ef273.md
new file mode 100644
index 0000000000000000000000000000000000000000..c5af6318bf728053cc4df614827815d554af395a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/45f7117f9177dd23c5707343135b9daf2d1eabe4747fc6a446a3761ea72ef273.md
@@ -0,0 +1,20 @@
+From: Jackie Perczek <JPerczek@royblack.com>
+ATION N
+i TELL C
+Subject: Doe |. USAO
+Date: Fri, 14 Oct 2011 20:48:01 +0000
+Importance: Normal
+Inline-
+Images: ATT00001
+411 C
++
+Also, my reply to Cassell's response to the supplemental briefing filed by the would-be intervenor lawyers is due
+early next week. I will be filing a motion for an extension until October 31. Cassell has no objection. Can I say
+the govt has no objection either?
+Thanks,
+Jackie Perczek, Esq.
+The information in this email transmission is privileged and confidential. If you are not the intended recipient, nor
+the employee or agent responsible
+for delivering it to the intended recipient, you are hereby notified that any dissemination or copying of this
+transmission (including any attachments) is strictly prohibited. If you have received this email in error, please
+notify the sender by email reply. Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/45f7117f9177dd23c5707343135b9daf2d1eabe4747fc6a446a3761ea72ef273.receipt.json b/vision-fixhub/ds9-unparsed-06/45f7117f9177dd23c5707343135b9daf2d1eabe4747fc6a446a3761ea72ef273.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c9247471651e95795d0581194799b2dd7a8c536b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/45f7117f9177dd23c5707343135b9daf2d1eabe4747fc6a446a3761ea72ef273.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "45f7117f9177dd23c5707343135b9daf2d1eabe4747fc6a446a3761ea72ef273",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "9959f16d333cb05bd9290484909f58ae8a17f02d3ab5723a5a59bc6e77a18bda",
+  "output_sha256": "633e5fe121e8faad7832d7f905b4cc1e9b4e7a6db2c121c305ca8ed605d8a5b7",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/45faa9d33ab82866d85e8fa8ca5c4fcd413763e7e92d0adea639b39ef0e7b2e5.md b/vision-fixhub/ds9-unparsed-06/45faa9d33ab82866d85e8fa8ca5c4fcd413763e7e92d0adea639b39ef0e7b2e5.md
new file mode 100644
index 0000000000000000000000000000000000000000..2281c32af91a3d58467753cc84984ccdaca20eeb
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/45faa9d33ab82866d85e8fa8ca5c4fcd413763e7e92d0adea639b39ef0e7b2e5.md
@@ -0,0 +1,82 @@
+From:
+To:
+Cc:
+Subject: Re: Jane Does |. U.S. (re Jeffrey Epstein) - Litigation Hold - Additional
+Date: Thu, 04 Nov 2010 14:19:29 +0000
+Importance: Normal
+P.s. I think you have to take your start date back much further -- 2005 or 2006.
+From:
+Sent: Tuesday, November 02, 2010 06:01 PM
+Subject: RE: Jane Does |. U.S. (re Jeffrey Epstein) - Litigation Hold - Additional
+Good Afternoon:
+In furtherance of the Lit Hold materials I sent to you, please know that I have to inform the National
+Preservation Officer at EOUSA in Washington as well as
+(here in the S.D. Fla) of the Lit Hold and
+inform them of key names.
+To that end, I gathered from the unsealed Court filings the names set forth below. Please let me know if there
+are any other names that should be identified. Please let me knov
+first name.
+I will also need the names of the victims that would be Jane Doe # 1 and Jane Doe #2 for preservation
+purposes. This information will be kept confidential. If the USAO-SDFLA Lit Hold efforts are ever the subject of
+discovery, we can redact the victim names...as was done in the letters filed with AUSA Villafana's first
+declaration.
+Also, I will need your assistance in preparing letters to the FBI and Palm Beach P.D. to urge them to place a Hold
+on any documents that they may have. unless you advise that a hold is already in place.
+Finally, please let me know if the Lit Hold Time Frame I suggested is correct, or if it should commence with an
+earlier date.
+•
+•
+(Jane Doe Petitioner in Civil action ???)
+(Jane Doe Petitioner in Civil action ?77)
+(Jane Doe Petitioner in Civil action ???)
+Bradley J. Edwards, Esq, Counsel for
+Paul G. Cassell, Counsel
+Jay C. Howell, Counsel for
+??
+
+
+•
+•
+Agreement
+•
+•
+James Eisenberg, Esq., Original counsel fo
+22227?
+Jeffrey Epstein, Defendant in state criminal action and party to USAO-SDFLA Non-Prosecution
+Lilly Ann Sanchez, Counsel For Epstein
+Jack Goldberger, Counsel for Epstein
+Assistant United States Attorney
+Special Agent, F.B.I.
+•
+Special Agent
+. F.B.I.
+•
+:
+•
+, Assistant United States Attorney
+Federal Bureau of Investigation ("FBI")
+h, FBI Victim Specialist
+Palm Beach Florida Police Department
+-
+-
+From:
+To:
+Sent: Tuesday, November 02, 2010 5:48 PM
+Cc:
+Subject: Jane Does U.5. (re Jellrey Epstein) - Litigation Hold
+Importance: High
+« File: Re.Jeffrey Epstein.Jane Does I. U.S. - 11.2.2010 JAW Lit Hold Ltr to Individual in USAO.SD.Fla.pdf >> «
+File: Re.Jeffrey Epstein.Jane Does I, U.S. - Typable 3-13.300.003 Attachment.1.pdf »
+As a follow-up to your recent meeting concerning the above-referenced case, I write this letter in my capacity as
+the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the
+Southern District of Florida (USAO-SDFLA) to advise you of the USAO-SDFLA's legal obligation to preserve
+documents and data relevant to the lawsuit and to enlist your assistance in this regard.
+I request that you please read and acknowledge your receipt and agreement to the terms of this letter. I also
+ask that you please complete and sign the form accompanying this letter. Please return the originals of both
+documents to me by November 9, 2010.
+Should you have any questions, please let me know.
+Assistant United States Attorney
+Office of the United States Attorney
+Southern District of Florida
+
+
diff --git a/vision-fixhub/ds9-unparsed-06/45faa9d33ab82866d85e8fa8ca5c4fcd413763e7e92d0adea639b39ef0e7b2e5.receipt.json b/vision-fixhub/ds9-unparsed-06/45faa9d33ab82866d85e8fa8ca5c4fcd413763e7e92d0adea639b39ef0e7b2e5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ef8bf1e99288a3bbfd1d841f4bd086771011cf0c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/45faa9d33ab82866d85e8fa8ca5c4fcd413763e7e92d0adea639b39ef0e7b2e5.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "45faa9d33ab82866d85e8fa8ca5c4fcd413763e7e92d0adea639b39ef0e7b2e5",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "a269e7eb8e429a11c4ec97d335badf46f26e40bb8dec0e1eebe94ca22c9e81cb",
+  "output_sha256": "b92756608172a4c9e17dc8073b79354465c0335b22e901b2e62e9f9c06446df9",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4666ac88a0777a204830ae8e84b59c3d804456bd63b27d08989969e1b8c73adb.md b/vision-fixhub/ds9-unparsed-06/4666ac88a0777a204830ae8e84b59c3d804456bd63b27d08989969e1b8c73adb.md
new file mode 100644
index 0000000000000000000000000000000000000000..daa6689b35d62b536f7d97d314b2338171a597c3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4666ac88a0777a204830ae8e84b59c3d804456bd63b27d08989969e1b8c73adb.md
@@ -0,0 +1,67 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80119-KAM Doe L. Epstein Motion for Miscellaneous Relief
+Date: Fri, 19 Feb 2010 17:04:53 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+pply to all other users. To avoid later charges, download a copy of each document during this firs
+iewing. However, if the referenced document is a transcript, the free copv and 30 page limit do not appli
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Pike, Michael on 2/19/2010 at 12:04 PM EST and filed on 2/19/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 471
+Doe | Epstein
+9:08-cv-80119-KAM
+Jeffrey Epstein
+Docket Text:
+Defendant's MOTION Attend Mediation and Memorandum in Support Thereof as to Jane Doe,
+08-80893 by Jeffrey Epstein. (Attachments: # (1) Text of Proposed Order Proposed Agreed
+Order)(Pike, Michael)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz ahorowitz@sexabuseattorney.com
+Ann Marie C. Villafana
+ann.marie.c.villafana@usdoj.gov
+Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com
+Isidro Manuel Garcia
+isidrogarcia@bellsouth.net
+Jack Alan Goldberger
+jagesq@bellsouth.net, nalanis@agwpa.com
+Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com,
+sas@searcylaw.com, vat@searcylaw.com
+Jeffrey Mare Herman jherman@hermanlaw.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+
+
+Michael James Pike MPike@bclclaw.com, bobbie@bclelaw.com, jcadwell@bclelaw.com
+Paul G. Cassell cassellp@law.utah.edu
+Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com
+Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton@podhurst.com,
+mestradal@podhurst.com
+Robert Deweese Critton, Jr rcrit@belclaw.com, bobbie@belclaw.com
+Stuart S. Mermelstein ssm@sexabuseattorney.com, jarbour@sexabuseattorney.com,
+Irivera@sexabuseattorney.com
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+Martin G. Weinberg
+20 Park Plaza
+Boston, MA 02116
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=2/19/2010] [FileNumber=7276642-0
+151eb11228c6bdd10989722d1f3e910370fc0a78480e9639bfc01f55194a8]]
+Document description:Text of Proposed Order Proposed Agreed Order
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=2/19/2010] [FileNumber=7276642-1
+][63003357fe3603fбеa4c1b795071ed0e75ba2d6dc8878282bb2d2c2ae19abc12441
+89cbd8f1 de041b4c289e0084c9ba94ffa7300569c0de8b3f1cff70b655264]]
diff --git a/vision-fixhub/ds9-unparsed-06/4666ac88a0777a204830ae8e84b59c3d804456bd63b27d08989969e1b8c73adb.receipt.json b/vision-fixhub/ds9-unparsed-06/4666ac88a0777a204830ae8e84b59c3d804456bd63b27d08989969e1b8c73adb.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d4026a978cec2b6b27fba34b186ebf53c161af15
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4666ac88a0777a204830ae8e84b59c3d804456bd63b27d08989969e1b8c73adb.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "4666ac88a0777a204830ae8e84b59c3d804456bd63b27d08989969e1b8c73adb",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "1e06d4bb48c290eb5274004f63cdaf022ec351d874423dccee8c1d09c1d6e94d",
+  "output_sha256": "e6582b8c3163b57336debb42be0cfd3c57842566c6216e3e21beb1f7af22ac46",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/467896486f44022dc2c5ff372b8238c4c75e40dffc943f4a3b5e6e47bde9e54c.md b/vision-fixhub/ds9-unparsed-06/467896486f44022dc2c5ff372b8238c4c75e40dffc943f4a3b5e6e47bde9e54c.md
new file mode 100644
index 0000000000000000000000000000000000000000..177105d4de22d17d45f80e08639eb88d20822a66
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/467896486f44022dc2c5ff372b8238c4c75e40dffc943f4a3b5e6e47bde9e54c.md
@@ -0,0 +1,21 @@
+From:
+To:
+(USAFLS)" <
+Subject: RE:
+Date: Tue, 27 Mar 2007 18:32:17 +0000
+Importance: Normal
+| (USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN= |
+Hi
+- Thank you. The letter went out earlier today. I put a copy in your box.
+Assistant U.S. Attorney
+From:
+Sent:
+To:
+Subject:
+issues with the letter.
+| (USAFLS)
+Monday, March 26, 2007 4:21 PM
+I (USAFLS)
+Also, I was thinking that seniors in High School start turning 18 in January. So that if you are getting massages from High
+School students during a school year between September and January, you can be assured none of them are 18. And
+even by graduation in June, 5/6 of the students in a Highschool will be under 18.
diff --git a/vision-fixhub/ds9-unparsed-06/467896486f44022dc2c5ff372b8238c4c75e40dffc943f4a3b5e6e47bde9e54c.receipt.json b/vision-fixhub/ds9-unparsed-06/467896486f44022dc2c5ff372b8238c4c75e40dffc943f4a3b5e6e47bde9e54c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6c304c97368dbfa4540e712523441db71a306afe
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/467896486f44022dc2c5ff372b8238c4c75e40dffc943f4a3b5e6e47bde9e54c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -10,
+  "dataset": "marble-joined",
+  "doc_id": "467896486f44022dc2c5ff372b8238c4c75e40dffc943f4a3b5e6e47bde9e54c",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.flight-log-tables.normalize\"]",
+  "idempotent": true,
+  "input_sha256": "70e806a33cbe415cf137ef5a71e3ef84402cc6f6ce7201dd27427ce19d7a035d",
+  "output_sha256": "1ed47f7b8f754b86a86d07359f59c7a0b34d8f98c5effe4c13f82849884999de",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4786c98c0a884ee6e4e658c11a4f7b5c38931bf6d0b6bb5b365eef69a288236d.md b/vision-fixhub/ds9-unparsed-06/4786c98c0a884ee6e4e658c11a4f7b5c38931bf6d0b6bb5b365eef69a288236d.md
new file mode 100644
index 0000000000000000000000000000000000000000..3e49b1c941ed878a9528cc2aa1441c7c1d13c032
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4786c98c0a884ee6e4e658c11a4f7b5c38931bf6d0b6bb5b365eef69a288236d.md
@@ -0,0 +1,33 @@
+Subject: RE: Jane Does |. US -- Sealed Response to Motion to Dismiss
+Date: Thu, 08 Dec 2011 21:26:21 +0000
+Importance: Normal
+Mid morning is fine for me.
+Subject: Re: Jane Does |. US -- Sealed Response to Motion to Dismiss
+Would mid-morning (about 10:30) work for everyone, or do you have another preference?
+Subject: Re: Jane Does | US - Sealed Response to Motion to Dismiss
+Let me know what time
+Subject: RE: Jane Does |. US -- Sealed Response to Motion to Dismiss
+Let's do it tomorrow. I will have my Blackberry on. I believe our replies are due on December 15.
+I am set to go to trial before Judge Ungaro during the two week term commencing January 16, 2012. She just denied my
+motion for continuance, so it looks like the case is going forward.
+Sent: Thursday, December 08, 2011 4:02 PM
+Subject: Re: Jane Does L US -- Sealed Response to Motion to Dismiss
+I'm actually out of the office today on sick leave. If you want to talk today, I can call in, but I have not yet had a chance to
+review the sealed pleading and I was not inclined to forward the sealed document to my gmail account.
+Let me know what you both prefer.
+Sent: Thursday, December 08, 2011 03:54 PM
+
+
+Subject: RE: Jane Does |. US -- Sealed Response to Motion to Dismiss
+I will be out of the office tomorrow, but I can call in. Do you want to try something today?
+Sent: Thursday, December 08, 2011 3:39 PM
+subjectiRe: Jane Does A US- Sealed Response to Moton to Dismiss
+Can all three of us get together on the phone tomorrow?
+From: Villatana, Ann Marie C. (USAFLS)
+Sent: Thursday, December 08, 2011 11:47 AM
+To: Sanchez, Eduardo (USAFLS); Lee, Dexter (USAFLS)
+Subject: Jane Does I. US -- Sealed Response to Motion to Dismiss
+Hi Ed and Dexter - Here is the sealed portion of their response. Judge Marra's clerk called to confirm that we
+had no objection to the Motion to Seal. I stated that we had no objection.
+I am on vacation next week. We really HAVE to get this file transferred to the Middle District.
+<<20111206 Sealed Response to Motn to Dismiss.pdf>>
diff --git a/vision-fixhub/ds9-unparsed-06/4786c98c0a884ee6e4e658c11a4f7b5c38931bf6d0b6bb5b365eef69a288236d.receipt.json b/vision-fixhub/ds9-unparsed-06/4786c98c0a884ee6e4e658c11a4f7b5c38931bf6d0b6bb5b365eef69a288236d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c81eb496208f91bce60d7e8d471ee1a0f0df388d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4786c98c0a884ee6e4e658c11a4f7b5c38931bf6d0b6bb5b365eef69a288236d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "4786c98c0a884ee6e4e658c11a4f7b5c38931bf6d0b6bb5b365eef69a288236d",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3b935ec580c88e454d9321b9ec5ae27b09dda3ef2f12ead99bd9dcfa76849843",
+  "output_sha256": "d2536649d825f058d7d13da13cc2193dabdab1366b6c086f60bb1450348c0da5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/47a3a1b6b5d06e872db04b5a25da2d8272ecc2fb793ccffe7d80c01200cd8445.md b/vision-fixhub/ds9-unparsed-06/47a3a1b6b5d06e872db04b5a25da2d8272ecc2fb793ccffe7d80c01200cd8445.md
new file mode 100644
index 0000000000000000000000000000000000000000..8dfa751d0f6faf4852189e23ce73dd1491abe38e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/47a3a1b6b5d06e872db04b5a25da2d8272ecc2fb793ccffe7d80c01200cd8445.md
@@ -0,0 +1,280 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs
+UNITED STATES,
+Defendants
+JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR ADMISSIONS
+TO THE GOVERNMENT REGARDING QUESTIONS RELEVANT TO THEIR
+PENDING ACTION CONCERNING THE CRIME VICTIMS RIGHTS ACT
+COME NOW Jane Doe #1 and Jane Doe #2 ("the victims"), by and through undersigned
+counsel, and request the defendant United States (hereinafter "the Government") to admit or
+deny the following facts:
+BACKGROUND
+As the Government will recall, the victims have asked the Government to stipulate to
+undisputed facts in this case. The Government has declined. Accordingly, the victims filed their
+Motion for Finding of Violations of the Crime Victims' Rights Act and Request for a Hearing on
+Appropriate Remedies (DE 48) (the victims" "summary judgment motion") along with a Motion
+to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts
+(DE 49).
+On September 26, 2011, the Court denied the victims' motion to have their facts accepted
+(DE 99 at 11). At the same time, however, the Court has ordered discovery to develop the
+factual record concerning the summary judgment motion (DE 99 at 11). The Court reserved
+
+
+ruling on the victims" motion for an order directing the Government not to suppress relevant
+evidence (DE 99 at 11). The Court allowed the victims to propound requests for admission to
+the Government.
+DISCOVERY REQUESTED
+The numbered requests for admissions below should all be construed in light of the
+definitions of terms provided at the end of the requests. Where the request for admission has
+separate, lettered sub-parts, please admit or deny each separate sub-part:
+1. The FBI and the U.S. Attorney's Office for the Southern District of Florida's
+investigation into Jeffrey Epstein developed a case for a federal prosecution against
+Epstein for many federal sex offenses.
+2. Regarding notifications provided to victims of Jeffrey Epstein's sexual abuse:
+(a)
+The U.S. Attorney's Office negotiated with Jeffrey Epstein's defense attorneys
+concerning the notifications to be provided to victims of Epstein's abuse;
+(b)
+It is not standard practice for the U.S. Attorney's Office to negotiate with defense
+attorneys about the extent of notifications provided to crime victims;
+(c)
+As a result of those negotiations or requests received from Epstein, the U.S.
+Attorney's Office stopped making notifications to some crime victims;
+(d)
+The language used in the notifications to Jane Doe #1 and Jane Doe #2 were
+affected by the negotiations with Epstein's defense lawyers;
+(e)
+At least in part as a result of the negotiations, Jane Doe #1 and Jane Doe #2 were
+not told that the U.S. Attorney's Office had entered into a non-prosecution
+agreement with Epstein until after the agreement was executed.
+3. Because of a confidentiality provision in the non-prosecution agreement signed by the
+J.S. Attorney's Office, it would have been a breach of the agreement for the U.i
+ttorney's Office to inform Jane Doe #1 and Jane Doe #2 of the existence of the terms o
+that non-prosecution agreement barring prosecution of certain sex offenses.
+4. During its negotiations with Jeffrey Epstein's defense attorneys, the U.S. Attorney's
+Office was aware that publicly disclosing the non-prosecution agreement with Jeffrey
+Epstein would likely have led to public criticism of the agreement.
+
+
+5. During negotiations with Jeffrey Epstein regarding the non-prosecution agreement, it was
+the position of at least one experienced attorney within the U.S. Attorney's Office that the
+Crime Victims' Rights Act required notifications to the victims in this case.
+6. The Justice Department possesses documents, correspondence or other information
+reflecting contacts with the Department between May 2007 and September 2008 on
+behalf of Jeffrey Epstein by:
+(a) President Bill Clinton;
+(b) Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York);
+(c) Harvard Law Professor Alan Dershowitz;
+(d) Ken Starr;
+(e) Lillian Sanchez;
+(f) Jay Lefkowitz; and
+(g) Roy Black.
+7. On about January 10, 2008, when Jane Doe #1 and Jane Doe #2 were sent letters advising
+them that "this case is currently under investigation," the U.S. Attorney's Office had
+already entered into a non-prosecution agreement with Jeffrey Epstein.
+8. In September 2007 when the U.S. Attorney's entered into the non-prosecution agreement
+with Epstein, it did not inform FBI agents of the details of the disposition of the case in
+the way that it ordinarily informed them of dispositions of other cases.
+9. With regard to the non-prosecution agreement between Epstein and the Government:
+(a) Epstein insisted on, and the U.S. Attorney's Office agreed to, a provision in the
+non-prosecution agreement that made the agreement secret;
+(b) In particular, the agreement stated: "The parties anticipate that this agreement will
+not be made part of any public record;*
+(c)
+By entering into such a confidentiality agreement, the U.S. Attorney's Office put
+itself in a position that conferring with the crime victims (including Jane Doe #1
+and Jane Doe #2) about the non-prosecution agreement would violate certain
+(d)
+(e)
+Even notifying the victims about the agreement would have violated the
+confidentiality provision; and
+From September 24, 2007 through June 2008, the U.S Attorney's Office did not
+notify Jane Doe #1 and Jane Doe #2 of the existence of the non-prosecution
+agreement.
+
+
+10. With regard to contact between the Government and the victims:
+(a)
+(b)
+(c)
+On about October 26, 2007, FBI agents met with Jane Doe #1;
+The agents explained that Epstein would plead guilty to state charges involving
+another victim, he would be required to register as a sex offender, and he had
+made certain concessions related to the payment of damages to the victims,
+including Jane Doe #1;
+During this meeting, the agents did not explain that an agreement had already
+been signed that precluded any prosecution of Epstein for federal crimes
+committed against Jane Doe #1;
+(d)
+The agents could not have revealed this part of the non-prosecution agreement
+without violating the terms of the non-prosecution agreement;
+(e)
+The agents themselves had not been informed of the existence of the provision in
+the non-prosecution agreement barring Epstein's prosecution for various federal
+crimes or sex offenses at that time;
+Because the non-prosecution agreement had already been reached with Epstein,
+the agents made no attempt to secure Jane Doe #I's view on the proposed
+resolution of the case; and
+(g)
+The agents never explained that the non-prosecution agreement would ultimately
+bring to an end the federal investigation in the case.
+11. On about November 29, 2007, the U.S. Attorney's Office sent a draft of a crime victim
+notification letter to Jay Lefkowitz, defense counsel for Jeffrey Epstein. The notification
+letter would have explained: "I am writing to inform you that the federal investigation of
+Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have
+reached an agreement containing the following terms ...." Because of concerns from
+Epstein's attorneys, the U.S. Attorney's Office never sent the proposed victim
+notification letter to the victims.
+12. On July 3, 2008, when Bradley J. Edwards was working on a letter to the U.S. Attorney's
+Office concerning the need to federally prosecute Epstein for sex offenses committed
+against Jane Doe #1 and Jane Doe #2, the U.S. Attorney's Office had already entered into
+a binding non-prosecution agreement with Jeffrey Epstein.
+13. When Jeffrey Epstein pled guilty to state charges on June 30, 2008,
+(a)
+Jane Doe #1 and Jane Doe #2 had not been informed by the U.S. Attorney's
+Office of the existence of the non-prosecution agreement.
+
+
+(b)
+The U.S. Attorney's Office had not conferred with either Jane Doe #1 or Jane Doe
+#2 about the non-prosecution agreement;
+(d)
+Epstein's defense attorneys were aware that the U.S. Attorney's Office had not
+conferred with Jane Doe #1 and Jane Doe #2 about the agreement; and
+Epstein's defense attorneys had negotiated for a confidentiality provision in the
+non-prosecution agreement that barred conferring with victims about the
+agreement.
+14. When Epstein was pleading guilty to the state charges discussed in the non-prosecution
+agreement, both the U.S. Attorney's Office and Epstein's defense attorneys were working
+to keep the existence of the non-prosecution agreement confidential.
+15. Defense attorney Bruce E. Reinhart:
+(a)
+learned confidential, non-public information about the Epstein matter;
+(b)
+discussed the Epstein matter with an attorney working on the case for the U.S.
+Attorney's Office; and
+(c)
+was involved in decision-making with regard to the Epstein matter.
+16. The Government possesses information (including telephone logs and emails) reflecting
+contacts between Bruce E. Reinhart and persons/entities affiliated with Jeffrey Epstein
+(including Jeffrey Epstein, the Florida Science Foundation, Jack Goldberger, Harvard
+Law Professor Alan Dershowitz, Roy Black, Ken Starr, Lily Ann Sanchez) before
+Reinhart left the employment of the U.S. Attorney's Office.
+17. The Government possesses information (including telephone logs or emails) reflecting
+contacts between Bruce E. Reinhart and persons working at or for the Department of
+Justice or United States Attorney's Office that related to Jeffrey Epstein or the
+investigation into Jeffrey Epstein and other potential co-conspirators of Jeffrey Epstein.
+18. The government possesses, or has knowledge or information (including telephone logs or
+photographs or emails) reflecting improper communication or influence made or
+attempted with the Government, on Jeffrey Epstein's behalf by:
+(a)
+(b)
+Guy Lewis
+LilyAnn Sanchez
+19. The government possesses, or has knowledge or information (including telephone logs,
+
+
+20. The government possesses, or has knowledge or information (including telephone logs,
+photographs, emails or statements) of other credible sources) about a personal or
+business relationship between Jeffrey Epstein and Matthew Menchel.
+21. The government possesses, or has knowledge or information (including telephone logs,
+photographs, emails or statements) of other credible sources) about a personal or
+business relationship between Jeffrey Epstein and Alex Acosta.
+22. The Justice Department's Office of Professional Responsibility and/or other Government
+entities have collected information about:
+(a) Bruce Reinhart's possible involvement in the Epstein matter;
+(b)
+Other government attorney's possible improper behavior in the Epstein matter;
+and
+(c)
+A conflict of interest regarding the U.S. Attorney's Office for the Southern
+District of Florida handling issues relating to the Epstein matter.
+23. The non-prosecution agreement signed by the U.S. Attorney's Office and Jeffrey Epstein
+currently blocks the U.S. Attorney's Office from prosecuting sex offenses committed by
+Epstein against Jane Doe #1 and Jane Doe #2 in the Southern District of Florida.
+24. The Justice Department possesses information that Epstein, himself or through his
+attorney's or acquaintances, has provided or offered to provide to the federal government
+(or an individual within the Government, in his official or private capacity) valuable
+consideration.
+25. The Justice Department's Office of Professional Responsibility's investigation/inquiry
+into alleged misconduct relating to the negotiation and consummation of the Epstein nonprosecution agreement has relevance to issues pending in this case.
+26. The Government possesses evidence, not covered by grand jury secrecy rules, that
+reveals that districts outside the Southern District of Florida share jurisdiction and venue
+with the Southern District of Florida over potential federal criminal charges based on the
+alleged sexual acts committed by Epstein against Jane Doe #1 and/or Jane Doe #2.
+DEFINITIONS
+For the purpose of construing the foregoing discovery requests, the following terms are
+defined:
+The term "documents" means and includes, without limitation, all writings of any kind,
+including the originals and all non-identical copies or drafts, whether different from the original
+by reason of any notation made on such copy or draft or otherwise including, without limitation,
+correspondence, memoranda, notes, diaries, statistics, letters, e-mails, electronic computer files,
+
+
+telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries,
+pamphlets, books, prospectuses, interoffice communications, offers, notations of any sort of
+conversation, telephone calls, meetings or other communications, bulletins, printed matter,
+computer print-outs, teletypes, facsimiles, invoices, work sheets and all drafts, alterations,
+modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records
+or representations of any kind including, without limitation, photographs, charts, graphs,
+microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or
+electric records or representations of any kind including, without limitation, tapes, cassettes and
+dise recordings, and writings and printed material of every kind.
+The term "correspondence" means any tangible object that conveys information or
+memorializes information that was conveyed in tangible or oral form including, but not limited
+to, writings, letters, memoranda, reports, notes, e-mails, telephone logs, telephone billing
+information, telephone recordings, and interoffice communications.
+The term "Epstein's victims" means any person that the Government identified as a
+possible victim of a sex offense committed by Jeffrey Epstein, including Jane Doe #1, Jane Doe
+#2, all victims identified in attachment to the non-prosecution agreement entered into by Epstein,
+and another person that the Government investigated as a possible victim of Epstein's sex
+offenses.
+The term "Government" means the federal government, including all employees of and
+components of the United States Department of Justice (such as, the Office of the Attorney
+General, the Office of the Deputy Attorney General, the Criminal Divisions, the Office of
+Professional Responsibility, the Child Exploitation and Obscenity Section, the U.S. Attorney's
+Offices for the Southern District and Middle District of Florida, and the Federal Bureau of
+Investigation) and other federal government agencies with law enforcement responsibilities
+related to the Epstein case (such as the Internal Revenue Service). This request for production
+seeks all documents, correspondence, and other information held by all of these entities,
+including all employees of and components of the Justice Department that worked on or were in
+any way involved the Epstein investigation and/or that possess information relevant to the
+victims' claims.
+The term "including" means containing within the request, but not limiting the request.
+The term "U.S. Attorney's Office" means the U.S. Attorney's Office for the Southern
+District of Florida and includes all branch offices within the Southern District of Florida.
+PRIVILEGE LOG
+If you believe that any request for admission is subject to a privilege and if you intend to
+includita a prescription a document a is consisten con Local Rule 2lB Vol
+privilege log should include a specific identification of the privilege being asserted and the basis
+
+
+DATED: December 1, 2011
+Respectfully Submitted,
+s/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+Telephone (954) 524-2820
+icsimile (954) 524-282
+orida Bar No.: 54201
+E-mail: brad@pathtojustice.com
+and
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City. UT 84112
+Telephone: 801-585-5202
+Facsimile: 801-585-6833
+E-Mail: cassellp@law.utah.edu
+Attorneys for Jane Doe #1 and Jane Doe #2
+CERTIFICATE OF SERVICE
+The foregoing document was served on December 1, 2011, on the following persons via US Mail
+and electronic mail to:
diff --git a/vision-fixhub/ds9-unparsed-06/47a3a1b6b5d06e872db04b5a25da2d8272ecc2fb793ccffe7d80c01200cd8445.receipt.json b/vision-fixhub/ds9-unparsed-06/47a3a1b6b5d06e872db04b5a25da2d8272ecc2fb793ccffe7d80c01200cd8445.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1d5f30a1e4f88907308bc2edfaddf6ef324a6bdf
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/47a3a1b6b5d06e872db04b5a25da2d8272ecc2fb793ccffe7d80c01200cd8445.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -98,
+  "dataset": "marble-joined",
+  "doc_id": "47a3a1b6b5d06e872db04b5a25da2d8272ecc2fb793ccffe7d80c01200cd8445",
+  "engine": "marble-apple-vision",
+  "event_count": 9,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "f593c930cefd4efef430a3bdb5f4ea2ad5f0e275ab7401a1f1a21c2fc72a1bc4",
+  "output_sha256": "6c61f12f5d5d5879b96dcb42f003ec921afc9488d8744e52f4894994d32876cc",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/48072af676338c26323440e2a6e1cd42ce485b6735e62146e48dcf290bf3c7a2.md b/vision-fixhub/ds9-unparsed-06/48072af676338c26323440e2a6e1cd42ce485b6735e62146e48dcf290bf3c7a2.md
new file mode 100644
index 0000000000000000000000000000000000000000..e09d801d61453648ee2f3741c66c3a456d2638f3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/48072af676338c26323440e2a6e1cd42ce485b6735e62146e48dcf290bf3c7a2.md
@@ -0,0 +1,17 @@
+To: "KATHERINE W. EZELL" <KEZELL@PODHURST.com>
+Subject: RE: Epstein--NPA
+Date: Tue, 16 Feb 2010 23:46:18 +0000
+Importance: Normal
+Attachments: Signed_epstein_addendum_10_30.pdf
+Here is the signed addendum. Ilooked through my electronic files but couldn't find that original
+NPA with my signature on it. The original document is up in WPB and I won't be up there until Friday. Can you
+wait until then?
+As to question 2, I believe that Lilly was in Florida (Miami), I was in Florida (WPB), and the others were in New
+York, but I don't know that for certain. I was the last to sign.
+You are welcome. Have a good night.
+Cc: ROBERT C. JOSEFSBERG; Amy Ederi
+Subject: Epstein--NPA
+Hi Marie, I know you are busy and hate to bother you, but I have a question and a request.
+2) Question—Where were the various signers of the NPA when they signed it, i.e., West Palm Beach, Miami, etc., and
+who and where was the last signer. (I am assuming that would have been you)?
+I hope all is well. Thank you as always, Kathy
diff --git a/vision-fixhub/ds9-unparsed-06/48072af676338c26323440e2a6e1cd42ce485b6735e62146e48dcf290bf3c7a2.receipt.json b/vision-fixhub/ds9-unparsed-06/48072af676338c26323440e2a6e1cd42ce485b6735e62146e48dcf290bf3c7a2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..12d7c913eeede06b9c4381f7b1e70aa653410f13
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/48072af676338c26323440e2a6e1cd42ce485b6735e62146e48dcf290bf3c7a2.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "48072af676338c26323440e2a6e1cd42ce485b6735e62146e48dcf290bf3c7a2",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "5d22a476d4f583c292e46c4b0d2e3bbaca7d955fa973686fe0606860214a1e20",
+  "output_sha256": "f4ce3c968db012a75097d27dc41e89d49799d7cf2cc11953ee50104a7221b57d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/484bc547dd138ffb5888ea86033c29b8f51065f584be51256d229609e6c26c07.md b/vision-fixhub/ds9-unparsed-06/484bc547dd138ffb5888ea86033c29b8f51065f584be51256d229609e6c26c07.md
new file mode 100644
index 0000000000000000000000000000000000000000..73cabbbebbf3740a1072ba1fafbf4dd5f62d6c9e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/484bc547dd138ffb5888ea86033c29b8f51065f584be51256d229609e6c26c07.md
@@ -0,0 +1,8716 @@
+1 of 34
+03/01/06 - 03/28106
+How To Contact Us:
+• 1-800-331-0500 or 611 from your wireless phone
+• For Deaf / Hard of Hearing Customers (TTY/TDD)
+1-866-241-6567
+Wireless Number with Rollover
+Previous Balance
+Payments Posted
+Adjustments to Previous Balance
+PAST DUE BALANCE
+Payable Immediately
+Monthly Service Charges
+Credits/Adjustments/Other Charges
+Government Fees and Taxes
+TOTAL CURRENT CHARGES
+ue Apr 20, 200
+ate fees assessed after Apr
+Total Amount Due $449.02
+336.74
+-89.85
+246.89
+69.98
+99.22
+1.81
+31.12
+202.13
+***This Bill Includes A Past Due Balance***
+If payment has already been made, thank you, please disregard. If not, payment must be made
+mmediately. Please send your payment, including current charges, in the enclosed envelope
+You may also pay 24 hours a day, by major credit card or electronic check at 1-800-331-0500
+r www.cingular.com. If your service is suspended, a reconnection fee will apply. If yo
+ave questions regarding your account, contact us at 1-800-947-509
+PO BOX 772349 - (MIA)
+OCALA, FL 34477-2349
+*BWNHHBD
+#06091813030015*
+Return the portion below with payment
+to Cingular Wireless only
+Account Number:
+Total Amount Due:
+$449.02
+Amount Paid:
+$
+* Please do not send correspondence wish paymens.
+Please Make Check Payable To:
+10g Box 3148les
+Box 31481
+Tampa, FL 33631-3488
+
+
+Billing Cycle Date:
+Account Number
+200306-03728106
+General Information
+• Terms: The past due amount is due immediately. Late payment charges of 1.5% may be
+applied to any unpaid balance as of your next billing date. When you send us a
+check as payment, you authorize us to clear your check electronically. Electronic
+payments may clear the same day we receive payment. Returned checks or othe
+negotiable instruments may be represented electronically and may result in the
+selected services. Usage and toll charges are billed in arrears. Certain usage
+and toll charges may appear more than one month in arrears. Prorated monthly
+charges may apply for new services or changes to existing services during a
+billing period. These will appear in the Monthly Service Charges sections of the
+• Please do not enclose correspondence with your payment for we cannot guarantee
+• Calls to our Customer Service Centers may be monitored to ensure high quality
+service to our customers.
+• Questions on accessibility by persons with disabilities: 1-866-241-6568
+• Cingular Wireless Tax ID # 84-1659970 / Cingular Wireless DUNS # 003548489
+***********************************************************************
+Auto Pay Authorization Agreement - For use only with Auto Pay phone enrollment
+If I enroll, I authorize Cingular Wireless to pay my bill monthly by debiting my
+bank account. I can cancel authorization by notifying Cingular at
+www.cingular.com, by calling 1-800-331-0500, or by dialing 611 from my wireless
+phone. If my bank rejects a payment, I may be charged a return fee.
+How To Pay
+Checking and savings account payments, check cards, credit cards are accepted.
+Payments made with a representative may be subject to a service fee.
+Note: There is no fec for choosing any of the following payment channels:
+Pay using your wireless phone for free
+- Dial *PAY (*729), then hit send.
+- Make a one time payment following the instructions provided.
+Pay using any landline phone - Dial 1-800-331-0500
+- Enter your wireless number and billing ZIP Code and follow the prompts
+- Go to www.cingular.com/
+- Mail your remittance stub and a check or money order in the envelope provided.
+- It may take up to 7 - 10 days for the payment to post.
+DST X280-9900 (10/03)
+
+
+X
+cingular
+300106-0328106
+Prior Activity
+Previous Balance
+Adjustments to Previous Balance
+CITY UTILITY USER TAX ADJUSTMENT
+CREDIT FOR LOCAL AIRTIME
+FED UNIVERSAL SVC CHARGE ADJUSTMENT
+FEDERAL EXCISE TAX
+STATE TELE SALES TAX ADJUSTMENT
+TOTAL PAST DUE BALANCE
+Account Charges
+Credits, Adjustments & Other Charges
+Late Payment Fee
+ACCOUNT CREDITS, ADJUSTMENTS & OTHER CHARGES
+Government Fees and Taxes
+FEDERAL EXCISE TAX
+ACCOUNT GOVERNMENT FEES AND TAXES
+Wireless Line Summary For:
+User Name: MARTIN GOLICK
+Monthly Service Charges
+Rate Plan
+Current Rate Plan:
+NATP9DORUMMUNW
+• BASIC VOICEMAIL-NA
+- CALL. FORWARDING N/C
+- CALL WAITING N/C
+- DATA VOLUME DETAILED BILLING
+- DETAILED BILLING N/C
+- MULTIMEDIA PAY PER USE
+• THREE PARTY CALL N/C
+- WRLSS INTRNT XPRS PAY PER USE
+Other Services
+/900 ANYTIME MINS
+JANYTIME MIN ROLLOVER
+/EXPANDED INTL ROAMG SVC
+JINTLRM AUSTRALIA $1.69
+/INTLRM MEX/CAN S.79
+/INTLRM PREMIUM $3.99
+/INTLRM W.EUR $1.29
+JINTLRME.EU AS/PA $1.99
+/INTLRMMIDE/AFR $2.49
+/INTLRMS/C AM/CAR $1.99
+336.74
+-4.21
+-74.20
+-2.15
+-2.29
+-7.00
+$246.89
+3.70
+0.11
+$3.70
+$0.11
+Period
+02/28-03/28
+Monthly
+Charge
+59.99
+Total
+Charge
+59.99
+-
+02/28-03/28
+02/28-03/28
+02/28-03/28
+02/28-03/28
+02/28-03/28
+02728-03/28
+02/28-03/28
+02/28-03/28
+002/28-03/28
+02/28-03/28
+
+
+* cingular
+Billing Cycle Date:
+Account Number:
+4 of 34
+03/01/06 - 03/28106
+Wireless Line Summary For (Continued):
+User Name: MARTIN GOLICK
+/NATION GAITIGSM
+JUNLIMITED EXPANDED M2M-N/C
+UNLIMITED NIGHT & WEEKEND CTH
+CINGULAR NATIONWIDE TOLL FREE
+FL. ROAM WITH HOME
+OFF-NETWORK ROAM
+Wireless Data
+TEXT MESSAGING 1000
+TOTAL MONTHLY SERVICE CHARGES
+Usage Charges
+(See Usage Charge Details)
+TOTAL USAGE CHARGES
+Credits, Adjustments & Other Charges
+INSTALLMENT - CREDIT
+FED UNIVERSAL SVC CHARGE
+REGULATORY COST RECOVERY CHARGE
+TOTAL CREDITS, ADJUSTMENTS & OTHER CHARGES
+Government Fees and Taxes
+FEDERAL EXCISE TAX
+STATE COMMUNICATIONS TAX
+LOCAL COMMUNICATIONS TAX
+911 MONTHLY
+TOTAL GOVERNMENT FEES and TAXES
+TOTAL AMOUNT DUE
+Usage Charge Details
+User Name: MARTIN GOLICK
+Summary of
+Usage Charges
+Minutes
+Included
+In Plan
+Peak
+/UNLIMITED EXPANDED M2M-N
+/UNLIMITED NIGHT & WEEKEN
+Long Distance
+Domestic
+Roaming
+DST X280-9900 (10/D3)
+900
+02/28-03/28
+02/28-03/28
+02/28-03/28
+02/28-03/28
+02/28-03/28
+02/28-03/28
+02/28-03/28
+9.99
+3.00
+9.99
+$69.98
+$99.22
+-7.00
+1.55
+0.56
+1.81
+16.09
+9.61
+0.50
+$-1.89
+$31.01
+$198.32
+Minutes
+Used
+1148
+176
+734
+597
+Billed
+Minutes
+248
+Billed
+Rate
+0.40
+See Call Details
+See Call Details
+Total
+Charge
+99.20
+
+
+-
+Billing Cycle Date:
+Account Number
+5 of 34
+03/01/06 = 03/28/06
+Usage Charge Details (Continued)
+User Name: MARTIN GOLICK
+Subtotal
+$99.20
+Summary of
+Wireless Data
+Text Messaging
+- Incoming
+- AOL TXT Incoming
+- CINGULAR MOBILE TO MOBILE Outgoing
+- CINGULAR MOBILE TO MOBILE Incoming
+- MTM Other Incoming
+- OTHER MOBILE TO MOBILE Outgoing
+PRISS INTRNT XPRS PAY PER USE
+Msg/KB/Min
+Included
+Msg/KB/ Billed
+Billed
+In Plan
+Min Used Msg/KB/Min Rate
+Total
+Charge
+7
+2.00
+35
+38
+2
+2
+0.02
+Subtotal
+$0.02
+TOTAL USAGE CHARGES
+$99.22
+Summary of Rollover Minutes
+User Name: MARTIN GOLICK
+Previous Rollover Balance
+Rollover Minutes Expired (*)
+Current Rollover Balance
+(*) Unused Package Minutes Expire After 12 Billing Periods
+Call Detail
+User Name: MARTIN GOLICK
+Call Location(CL): AU=Aucilla, BR=Bristol, BU=Bushnell, CH=Chiefland, CL=Clewiston, DB=Daytona, FL.=Flagler,
+FK=Florida Keys, FM=Fort Myers, FP=Fort Pierce, FW=Fort Walton, GV=Gainesville, JX=Jacksonville, LC=Lake City
+.B=Leesburg, MI=Miami, MA=Marianna, MB=Melbourne, MX=Mexico Beach, OC=Ocala, OR=Orlando, PL=Palatka, PC=Panama City
+PS=Pensacola, PJ=Port St Joe.
+•SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa, VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Feature: 1=PTT One-to-One event: a=Automated Call Retum; B=Direct Asst Call Complete; C=Call Waiting; D=Data Call;
+d=Directory Assistance Call; F=Call Forwarding: g=PTT Group event; H=Group Mobile to Mobile Calls; I=Incoming Call;
+K=Fax Call; M=Mobile To Mobile Discount; N=Off-Network; O=Auto Dropped Call Credit; P=Priority Access Service; Q=|-VPN;
+R=Roam with Home; S=Shared Minutes; T=Three Way Calling: 1= Voice Activated Dialing; W=Nighti and Weekends
+Number
+Item
+Day
+Tue
+Date
+02/27
+02/27
+02/28
+02/28
+02/28
+Time
+08:24PM
+08:39PM
+08: 40AM
+08: 58AM
+09:05AM
+Rate Rate Fea- Airtime
+CL
+TH
+TH
+TH
+TH
+TH
+Called
+Call To
+W PAIM FL
+INCOMI CL
+W PAIM FL
+INCOMI CL
+W PAIM FL
+Min Code Pd ture Charge
+2 NPA2 P
+5 NPAZ P
+1 NPAZ P
+2 NPA2 P
+4 NPA2 P
+LD
+Total
+DA
+Charge
+
+
+6 of 34
+03/01/06 - 03/28106
+User Name: MARTIN GOLICK
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+Day
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+26
+27
+28
+29
+30
+31
+32
+33
+34
+35
+36
+37
+38
+39
+40
+41
+42
+43
+44
+45
+46
+47
+Wed
+Thu
+Date
+02/28
+02/28
+02/28
+02/28
+02/28
+02/28
+02/28
+02/28
+02/28
+02/28
+02/28
+02/28
+03/01
+03/01
+03/01
+03/01
+03/01
+03/01
+03/01
+03/01
+03/01
+03/01
+03/01
+03/01
+03/01
+03/01
+03/01
+03/02
+03/02
+03/02
+03/02
+03/02
+03/02
+03/02
+03/02
+03/02
+03/02
+03/02
+03/02
+03/02
+03/02
+03/02
+DST X280-9900 (10/03)
+Time
+10:00AM
+10: 02AM
+11: 01AM
+11:25AM
+11: 55AM
+06:17PM
+08: 51PM
+08:52PM
+09: 05PM
+09:19PM
+09:34PM
+09:35PM
+09:43AM
+10:35AM
+10: 50AM
+10: 56AM
+11:29AM
+02:17PM
+03:09PM
+03:20PM
+06:51PM
+07:58PM
+08:11PM
+08:45PM
+10:00PM
+10:12PM
+10:22PM
+12:50AM
+08:38AM
+11: 38AM
+11:50AM
+11:55AM
+12:11PM
+12:24PM
+02:25PM
+03: 51PM
+03:55PM
+04:10PM
+05:08PM
+05:16PM
+05:23PM
+05:36PM
+CL
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+Called
+Call To
+W PAIM FL
+W PAIM FL
+STUART FL
+INCOMI CL
+INCOMI
+CL
+INCOMI
+CL
+W PAIM FL
+W PALM FL
+W PAIM FL
+W PAIM FL
+W PALM FL
+W PALM FL
+W PAIM FL
+DEEREL FL
+INCOMI CL
+W PAIM FL
+INCOMI CL
+FORT M FL
+INCOMI CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+W PAIM FL
+INCOMI
+CL
+N PALM FL
+W PALM FL
+FILAUD FL
+INCOMI CL
+INCOMI CL
+FORT M FL
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PAIM FL
+INCOMI
+CL
+DEERFL
+W PALM
+FL
+DEEREL
+FL
+FIWALT FI
+INCOMI CL
+W PAIM FL
+W PAIM FL
+Min Code
+Pd
+2
+NPA2 P
+3 NPA2
+P
+6
+NPA2
+NPA2
+NPAZ
+NPAZ
+2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+2
+1
+NPA2
+NPA2
+NPAZ
+NPAZ
+NPA2
+ture Charge
+R
+R
+IRM
+IR
+IR
+IR
+R
+IR
+RM
+10
+NPAZ
+NPA2
+10
+NPA2
+NPAZ
+NPAZ
+4
+NPA2
+2
+NPA2
+NPA2
+NPA2
+NPA2
+1
+NPA2
+NPA2
+14 NPA2
+2 NPA2
+1 NPA2
+1
+NPA2
+NPA2
+2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+IRM
+IR
+R
+IRM
+IRM
+IR
+EM
+R
+IR
+IRM
+IRM
+R
+R
+IRM
+P
+P
+P
+DA
+Total
+Charge
+
+
+7 of 34
+03/01/06 = 03/28106
+User Name: MARTIN GOLICK
+PS=Pensacola, PJ=Port St Joe, SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa, VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+48
+49
+50
+51
+52
+53
+54
+55
+56
+57
+58
+59
+60
+61
+62
+63
+64
+65
+66
+67
+68
+69
+70
+71
+72
+73
+74
+75
+76
+77
+78
+79
+80
+81
+92
+83
+84
+85
+86
+87
+88
+89
+Day
+Eri
+Sat
+Sun
+Mon
+Date
+03/02
+03/02
+03/02
+03/02
+03/03
+03/03
+03/03
+03/03
+03/03
+03/03
+03/03
+03/03
+03/03
+03/03
+03/04
+03/04
+03/05
+03/05
+03/05
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+Time
+05:46PM
+06:16PM
+06:19PM
+10:15PM
+10: 42AM
+11:04AM
+12: 21PM
+02:14PM
+03:18PM
+05:14PM
+05:58PM
+07:45PM
+07:46PM
+09:32PM
+05:07PM
+09:18PM
+06: 56PM
+08:25PM
+08:28PM
+09:49AM
+11:33AM
+11:49AM
+12:25PM
+12:32PM
+01:20PM
+01:33PM
+01:49PM
+01: 50PM
+03:03PM
+03:57PM
+05:22PM
+05: 44PM
+06: 01PM
+06:04PM
+06:05PM
+06:05PM
+06:06PM
+06:07PM
+06:09PM
+06:10PM
+CL
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+IX
+IX
+JX
+TA
+TA
+TA
+TA
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Called
+Call To
+INCOMI CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+STUART
+FL
+INCOMI
+CL
+INCOMI
+CL
+OPE ST
+FILAUD FL
+OPE ST
+OPE ST
+W PAIM FL
+800 BE CL
+STUART FL
+W PALM FL
+W PALM
+I FL
+PALM FL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+W PALM FI
+W PAIM FL
+W PAIM FL
+N PALM FL
+W PAIM FL
+INCOMI CL
+W PALM FL
+W PAIM EL
+INCOMI
+CL
+INCOMI
+CL
+STUART
+STUART
+FL
+STUART
+FL
+STUART
+FL
+W PALM FL
+W PAIM FL
+DELRAY FL
+Rate Rate Fea-
+Min Code
+Pd
+ture Charge
+14
+NPA2 P
+IR
+2 NPA2
+P
+IR
+14
+NPA2
+IR
+2
+NPA2
+NPAZ
+NPAZ
+NPA2
+NPA2
+P
+IR
+IR
+IR
+IR
+NPAZ
+NPA2
+NPA2
+P
+IR
+IR
+NPAZ
+NPA2
+6
+NPA2
+NPA2
+18
+NPAZ
+NPAZ
+NPA2
+NPA2
+53
+NPA2
+NPA2
+NPAZ
+NPA2
+2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+2
+NPA2
+NPA2
+1 NPA2
+1 NPA2
+1 NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+P
+P
+P
+P
+IR
+IR
+R
+M
+M
+M
+M
+M
+M
+DA
+Total
+Charge
+
+
+8 of 34
+03/01/06 - 03/28106
+User Name: MARTIN GOLICK
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+90
+91
+92
+93
+94
+95
+96
+97
+98
+99
+100
+101
+102
+103
+104
+105
+106
+107
+108
+109
+110
+111
+112
+113
+114
+115
+116
+117
+118
+119
+120
+121
+122
+Day
+Tue
+124
+125
+126
+127
+128
+129
+130
+111
+Date
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/06
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+DST X280-9900 (10/03)
+Time
+06:14PM
+06:38PM
+09: 41PM
+09:42PM
+11: 03PM
+11:04PM
+11:20PM
+11:30PM
+11:37PM
+11:59PM
+12:00AM
+12:17AM
+12:19AM
+12:20AM
+12: 25AM
+09:19AM
+10:11AM
+10:12AM
+10: 13AM
+10:13AM
+10:15AM
+10:17AM
+10:18AM
+10: 40AM
+10: 49AM
+11: 03AM
+11:15AM
+11:21AM
+01:02PM
+01:03PM
+01:23PM
+01:32PM
+02: 00PM
+03:43PM
+05:52PM
+06: 22PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Called
+Call To
+W PAIM FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+INCOMI
+CL
+W PAIM FL
+PALM FL
+PALM
+FL
+PALM
+FL
+W PAIM FL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PAIM FL
+W PAIM FL
+W PAIM FL
+W PAIM FL
+W PALM FL
+W PAIM FL
+INCOMI
+CL
+W PALM
+EL
+BOYTON
+FL
+W PAIM FL
+W PALM FL
+W PALM FL
+BOYTON FL
+INCOMI CL
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PAIM EL
+INCOMI
+CL
+W PAIM
+I FL
+STUART
+FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+W PAIM FL
+INCOMI CL
+Min Code
+2
+NPA2
+1 NºA2
+NPA2
+NPA2
+NPAZ
+NPAZ
+1
+1
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+1
+NPA2
+NPAZ
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+1
+NPA2
+NPA2
+NPA2
+P
+P
+P
+NPA2
+NPA2
+2
+NPA2
+9
+NPA2
+1 NPA2
+15 NPA2
+2 NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+P
+NPAZ
+NPA2
+Pd
+ture Charge
+DA
+IW
+ICH
+IN
+I
+Total
+Charge
+
+
+9 of 34
+03/01/06 = 03/28106
+User Name: MARTIN GOLICK
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+132
+133
+134
+135
+Day
+137
+138
+139
+140
+141
+142
+143
+144
+145
+146
+147
+148
+149
+151
+152
+153
+154
+155
+156
+157
+158
+159
+160
+161
+162
+163
+164
+Hed
+167
+168
+169
+170
+171
+172
+173
+Date
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/07
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+Time
+07:33PM
+07:34PM
+07:36PM
+07: 36PM
+07:36PM
+07:37PM
+08:33PM
+09:09PM
+09:09PM
+09:19PM
+09:46PM
+09: 47PM
+09:49PM
+09:53PM
+09:53PM
+09: 55PM
+09:57PM
+09:57PM
+09:59PM
+10: 01PM
+10: 03PM
+10:04PM
+10: 05PM
+10:06PM
+10:08PM
+10:09PM
+10:15PM
+10:16PM
+10:19PM
+10:26PM
+10: 40PM
+11:17PM
+11:28PM
+08:11AM
+10:42AM
+10:43AM
+10:55AM
+11:47AM
+12:37PM
+01:16PM
+01:26PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Called
+Call To
+W PAIM FL
+W PAIM FL
+W PAIM FL
+W PALM FL
+BOYTON FL
+W PAIM FL
+INCOMI
+CL
+W PAIM FL
+INCOMI
+CL
+W PAIM FL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+W PAIM FL
+W PAIM FL
+W PAIM FL
+W PAIM FL
+W PAIM FL
+PAIM FL
+PALM FL
+PALM
+EL
+PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM FI
+W PAIM FI
+INCOMI CL
+INCOMI CL
+W PAIM FL
+W PALM FL
+INCOMI CL
+INCOMI CL
+W PALM FI
+INCOMI
+CL
+W PAIM FL
+W PALM FL
+STUART
+FL
+STUART FI
+STUART FL
+W PALM FL
+INCOMI CL
+Min Code
+1
+NPA2
+NPAZ
+P
+NPA2
+NPA2
+NPAZ
+2
+1
+1
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+1
+2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+N
+NPA2
+NPA2
+NPAZ
+NPA2
+1
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+1
+NPA2
+1 NPA2
+2 NPA2
+2 NPA2
+NPA2
+NPA2
+2
+NPA2
+NPA2
+4
+NPA2
+NPA2
+NPA2
+NPA2
+P
+P
+P
+Pd
+ture Charge
+DA
+IN
+ICH
+IW
+ICW
+IN
+IW
+Total
+Charge
+
+
+10 of 34
+03/01/06 - 03/28106
+User Name: MARTIN GOLICK
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+174
+175
+176
+177
+Day
+179
+180
+191
+182
+183
+194
+185
+186
+187
+198
+190
+191
+192
+193
+194
+195
+196
+197
+198
+199
+200
+201
+202
+203
+204
+205
+206
+207
+208
+209
+210
+211
+Thu
+213
+214
+215
+Date
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+DST X280-9900 (10/03)
+Time
+01:31PM
+01:37PM
+02: 36PM
+02: 55PM
+02:55PM
+03:04PM
+03: 05PM
+03:29PM
+04:17PM
+04:18PM
+04:21PM
+04:55PM
+05:08PM
+05: 09PM
+05:11PM
+05: 41PM
+06:37PM
+08:45PM
+08:47PM
+08:48PM
+09:19PM
+09:19PM
+09:21PM
+09:29PM
+09:31PM
+09:38PM
+09: 38PM
+10:15PM
+10:29PM
+11:21PM
+11:31 PM
+11:48PM
+12: 02AM
+01:27AM
+08: 58AM
+09: 06AM
+09:14AM
+11: 21AM
+11:21AM
+11:22AM
+11:24AM
+11: 29AM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Called
+Call To
+INCOMI CL
+INCOMI CL
+W PALM FL
+BOYTON FL
+W PAIM FL
+W PAIM FL
+INCOMI
+CL
+W PAIN FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+FILAUD FL
+W PALM FL
+W PAIM FL
+W PAIM FL
+W PAIM FL
+W PALM FL
+W PAIM FL
+DELRAY
+FL
+PALM FL
+INCOMI
+CL
+BOYTON
+FL
+W PALM
+FL
+INCOMI CL
+W PAIM
+I FI
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PAIM FL
+INCOMI CI
+INCOMI CI
+INCOMI CL
+INCOMI
+CL
+W PALM
+FL
+INCOMI
+CL
+INCOMI
+CL
+DELRAY
+EL
+W PALM FL
+W PALM FL
+W PAIM FL
+BOYTON FL
+Rate Rate Fea-
+Min Code
+Pd
+ture Charge
+1
+NPA2 P
+IM
+1 NPAZ
+I
+NPA2
+NPA2
+NPAZ
+NPA2
+1
+2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+M
+IM
+ICM
+I
+NPA2
+P
+P
+NPA2
+2
+2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+M
+NPA2
+NPA2
+N
+NPA2
+NPAZ
+NPAZ
+1
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+2 NPA2
+1 NPA2
+1 NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+P
+P
+P
+M
+ICW
+IN
+IN
+IN
+IN
+DA
+Total
+Charge
+
+
+11 of 34
+03/01/06 - 03/28/06
+User Name: MARTIN GOLICK
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa, VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+216
+217
+218
+219
+220
+221
+222
+223
+224
+225
+226
+227
+228
+229
+230
+231
+232
+233
+234
+235
+236
+237
+238
+239
+240
+241
+242
+243
+244
+245
+246
+247
+248
+249
+250
+251
+252
+253
+254
+255
+256
+Day
+Date
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+Time
+11:35AM
+11:42AM
+11:54AM
+12: 02PM
+12: 33PM
+01:14PM
+01:57PM
+02:13PM
+02: 24PM
+02:34PM
+02:40PM
+02: 41PM
+02:53PM
+03:07PM
+03: 08PM
+03:12PM
+03:13PM
+03:25PM
+03:48PM
+03:54PM
+03:58PM
+04:07PM
+04: 09PM
+05:14PM
+05:16PM
+05:21PM
+05: 36PM
+05: 59PM
+06:08PM
+07:07PM
+07:12PM
+07:14PM
+07:22PM
+07:22PM
+07: 43 PM
+07:49PM
+07:52PM
+08:26PM
+08:34PM
+08:44PM
+08:57PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Called
+Call To
+INCOMI CL
+DELRAY FL
+W PALM FL
+INCOMI CL
+W PAIM FL
+INCOMI
+CL
+W PAIM FL
+INCOMI
+CL
+W PAIM FL
+W PAIM FL
+BOYTON FL
+W PAIM FL
+INCOMI
+CL
+PAHORE FL
+INCOMI CL
+W PAIM FL
+W PAIM FL
+INCOMI CL
+W PAIM FL
+W PAIM FL
+INCOMI
+CL
+W PALM
+FL
+W PAIM FL
+W PAIM FL
+BOYTON FL
+INCOMI CL
+INCOMI
+CL
+INCOMI
+CL
+DELRAY FL
+W PAIM FL
+W PALM FI
+W PALM FL
+W PALM FL
+W PALM FL
+ORANGE
+EL
+INCOMI
+CL
+W PALM FI
+W PALM FL
+DELRAY FI
+BOYTON FL
+W PAIM FI
+INCOMI CL
+Rate Rate Fea-
+Min Code
+Pd
+ture Charge
+2 NPA2 P
+I
+2 NPA2 P
+M
+2 NPA2 P
+1 NPA2 P
+IN
+1
+NPAZ
+2
+NPAZ
+IM
+2
+NPA2
+NPA2
+P
+NPAZ
+NPA2
+NPA2
+NPA2
+P
+P
+2
+3
+3
+NPA2
+NPA2
+NPA2
+I
+M
+ICM
+NPAZ
+NPAZ
+NPA2
+P
+I
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+1
+NPA2
+2 NPA2
+NPA2
+NPA2
+NPA2
+1
+NPA2
+2
+NPA2
+6 NPA2
+1 NPA2
+2 NPA2
+NPA2
+NPA2
+NPA2
+2
+2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+P
+P
+P
+P
+P
+I
+I
+M
+DA
+Total
+Charge
+
+
+12 of 34
+03/01/06 - 03/28106
+User Name: MARTIN GOLICK
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+258
+259
+260
+261
+262
+263
+264
+265
+266
+267
+268
+269
+270
+271
+272
+273
+274
+275
+276
+277
+278
+279
+280
+281
+292
+283
+284
+285
+286
+287
+288
+289
+290
+291
+292
+293
+294
+295
+296
+297
+298
+299
+Day
+Fri
+Date
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/09
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+DST X280-9900 (10/03)
+Time
+08:59PM
+09:03PM
+09:17PM
+09:33PM
+09:37PM
+09:40PM
+10:17PM
+10:18PM
+10: 30PM
+10: 35PM
+10:38PM
+10:40PM
+10:42PM
+10:55PM
+10: 56PM
+11: 02PM
+11:08PM
+11:09PM
+11:14PM
+11: 31PM
+11:39PM
+11:45PM
+01:05AM
+01: 36AM
+01:40AM
+01:44AM
+01: 49AM
+02:12AM
+10:20AM
+10:24AM
+11: 21AM
+12:02PM
+12:04PM
+12:09PM
+12:12PM
+12:16PM
+12:55PM
+12:58PM
+01: 43 PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Called
+Call To
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PAIM FL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+W PAIM
+EL
+W PAIM FL
+W PAIM FL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+W PAIM FL
+INCONI CL
+INCOMI CL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PAIM FL
+PALM FL
+PALM FL
+PAIM FL
+W PAIM FL
+INCOMI CL
+W PALM FI
+DELRAY FL
+W PAIM FL
+W PAIM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PAIM FL
+INCOMI
+CL
+W PAIM FL
+W PAIM
+INCOMI
+CL
+W PALM FL
+W PALM
+FL
+INCOMI
+CL
+INCOMI CL
+Rate Rate Fea-
+Min Code
+Pd
+ture Charge
+5
+NPA2
+IM
+4 NºA2
+ICH
+13
+NPA2
+1 NPA2
+NPAZ
+NPAZ
+IN
+1
+2
+NPA2
+NPA2
+NPAZ
+2
+2
+NPA2
+NPA2
+NPA2
+NPA2
+ICH
+IN
+NPA2
+2
+NPA2
+NPAZ
+IN
+IN
+NPAZ
+NPA2
+ICH
+NPAZ
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+1
+NPA2
+IN
+4 NPA2
+NPA2
+NPA2
+1
+NPA2
+1
+NPA2
+1 NPA2
+IN
+M
+2 NPAZ
+2 NºA2
+P
+1 NPA2
+3 NPAZ
+NPA2
+2
+2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+P
+P
+P
+IN
+I
+DA
+Total
+Charge
+. 00
+
+
+13 of 34
+03/01/06 = 03/28106
+User Name: MARTIN GOLICK
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+300
+301
+302
+303
+304
+305
+306
+307
+308
+309
+310
+311
+312
+313
+314
+315
+316
+317
+318
+319
+320
+321
+322
+323
+324
+325
+326
+327
+328
+329
+330
+331
+332
+333
+334
+335
+336
+337
+338
+339
+340
+341
+Day
+Sat
+Date
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/10
+03/11
+03/11
+03/11
+03/11
+03/11
+03/11
+03/11
+03/11
+Time
+01:56PM
+02: 05PM
+02:19PM
+03:15PM
+03:21PM
+03:45PM
+04:01PM
+04:14PM
+04:18PM
+04: 39PM
+04:44PM
+04:47PM
+05: 06PM
+05:15PM
+05: 28PM
+05:37PM
+05: 52PM
+05: 58PM
+06:04PM
+06:06PM
+06: 50PM
+06:50PM
+06: 54PM
+07:07PM
+07:15PM
+07:17PM
+07:24PM
+07:26PM
+07:30PM
+07:43PM
+07:48PM
+08: 09PM
+08:29PM
+05: 13AM
+10:38AM
+11: 20AM
+11:22AM
+11:24AM
+11:25AM
+12:01PM
+01:27PM
+CL
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+MI
+Called
+561-722-1627
+Call To
+INCOMI CL
+INCOMI CL
+INCOMI CL
+W PALM FL
+W PAIM FL
+W PAIM FL
+W PAIM FL
+INCOMI
+CL
+W PAIM FL
+INCOMI
+CL
+W PALM FL
+W PAIM FL
+INCOMI
+CL
+INCOMI
+CL
+W PAIM FL
+INCOMI CL
+INCOMI CL
+INCOMI CL
+INCOMI
+INCOMI
+CL
+W PALM
+FL
+INCOMI
+CL
+W PALM
+FL
+W PAIM FL
+N PALM FL
+W PALM FL
+W PAIM FL
+INCOMI
+CL
+INCOMI
+CL
+W PAIM FL
+W PAIM FL
+W PALM FL
+W PAIM EL
+INCOMI CL
+MIAMI
+FL
+W PAIM FL
+W PAIM
+FL
+INCOMI
+CL
+W PALM FL
+W PALM
+FL
+W PAIM FL
+W PAIM FL
+Rate Rate Fea-
+Min Code
+Pd
+ture Charge
+1
+NPA2 P
+1 NPA2 P
+IM
+I
+2 NPA2
+1 NPA2
+1
+NPAZ
+M
+2
+NPAZ
+2
+NPA2
+M
+NPA2
+NPAZ
+NPA2
+NPA2
+NPAZ
+P
+P
+M
+IN
+M
+M
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+IM
+NPAZ
+NPA2
+1
+2
+NPA2
+NPA2
+P
+P
+M
+NPA2
+M
+NPA2
+3
+NPA2
+NPA2
+NPA2
+NPA2
+1 NPA2
+5
+NPA2
+IM
+NPA2
+N
+1
+NPA2
+NPA2
+NPA2
+IN
+NPA2
+NPA2
+N
+NPA2
+NPA2
+DA
+Total
+Charge
+
+
+User Name: MARTIN GOLICK
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+342
+343
+344
+345
+346
+347
+348
+349
+350
+351
+352
+353
+354
+355
+356
+358
+359
+360
+361
+362
+363
+364
+365
+366
+367
+368
+369
+370
+371
+372
+373
+374
+375
+376
+377
+378
+379
+380
+382
+393
+Day
+Sun
+Mon
+Date
+03/11
+03/11
+03/11
+03/11
+03/11
+03/11
+03/11
+03/11
+03/11
+03/11
+03/11
+03/11
+03/11
+03/11
+03/11
+03/12
+03/12
+03/12
+03/12
+03/12
+03/12
+03/12
+03/12
+03/12
+03/12
+03/12
+03/12
+03/12
+03/12
+03/12
+03/13
+03/13
+03/13
+03/13
+03/13
+03/13
+03/13
+03/13
+03/13
+03/13
+03/13
+03/13
+DST X280-9900 (10/03)
+Time
+01:43PM
+03:14PM
+04:15PM
+05: 38PM
+05: 48PM
+05:59PM
+07:10PM
+07:58PM
+09: 39PM
+09:41PM
+09:43PM
+09:44PM
+09:59PM
+10:04PM
+10:14PM
+02: 30AM
+02: 33AM
+01: 30PM
+06:36PM
+07:46PM
+07:47PM
+07: 52PM
+09:26PM
+10:03PM
+10:07PM
+10:18PM
+10:19PM
+10:20PM
+10:29PM
+12:39AM
+12: 47AM
+07: 34AM
+08:23AM
+09:54AM
+09:56AM
+09: 57AM
+10:05AM
+10:58AM
+11:18AM
+CL
+MI
+TA
+TA
+Called
+IX
+JX
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+Call To
+INCOMI CL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PAIN FL
+INCOMI
+CL
+W PAIM FL
+W PALM FL
+INCOMI
+CL
+W PAIM FL
+JACKSO FL
+W PAIM FL
+INCOMI CL
+INCOMI CL
+JACKSO FL
+W PAIM FL
+INCOMI CL
+W PAIM FL
+INCOMI
+OPE
+ST
+INCOMI
+CL
+FORT M FL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+W PALM FI
+W PAIM FL
+INCOMI CL
+W PALM FL
+W PAIM FI
+TALLAH FL
+TALLAH FL
+INCOMI CL
+W PAIM FL
+INCOMI
+CL
+INCOMI
+CL
+W PAIM
+FL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+TALLAH
+FL
+INCOMI CL
+14 of 34
+03/01/06 - 0312810
+Rate Rate Fea-
+Min Code
+Pd
+ture Charge
+2
+1
+NPA2 N
+IN
+NPA2
+N
+NPA2
+IRW
+NPA2
+NPAZ
+NPA2
+RW
+IRM
+2
+NPA2
+NPA2
+NPAZ
+IRN
+NPA2
+NPA2
+NPAZ
+NPA2
+N
+N
+N
+RK
+NPA2
+IRN
+IRW
+2
+2
+NPA2
+NPAZ
+NPAZ
+IRM
+NPA2
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+2
+2
+NPA2
+NPA2
+: NPA2
+1 NPA2
+1 NºA2
+2 NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+N
+N
+N
+N
+P
+P
+P
+IRW
+IRW
+IRM
+IRM
+IR
+IR
+IR
+IR
+DA
+Total
+Charge
+
+
+15 of 34
+03/01406 = 03/28106
+User Name: MARTIN GOLICK
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+384
+385
+386
+387
+Day
+389
+390
+391
+392
+393
+394
+395
+396
+397
+398
+Tue
+400
+401
+402
+403
+404
+405
+406
+407
+408
+409
+410
+411
+412
+413
+414
+415
+416
+417
+418
+419
+420
+421
+422
+423
+424
+Date
+03/13
+03/13
+03/13
+03/13
+03/13
+03/13
+03/13
+03/13
+03/13
+03/13
+03/13
+03/13
+03/13
+03/13
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+Time
+12:02PM
+05:05PM
+05: 06PM
+05:12PM
+05:12PM
+05:47PM
+09:01PM
+09: 02PM
+09:08PM
+09:12PM
+09:31PM
+09:49PM
+10:03PM
+10:58PM
+02: 19AM
+10: 58AM
+10:59AM
+11: 05AM
+11:16AM
+12: 31PM
+12:31PM
+12:33PM
+12:43PM
+12:55PM
+12:59PM
+01:19PM
+01:31 PM
+01:38PM
+01:40PM
+01:41PM
+02: 46PM
+02:49PM
+02:55PM
+04:30PM
+05:18PM
+05: 53PM
+06:09PM
+07:03PM
+07:07PM
+07:15 PM
+CL
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+Called
+Call To
+INCOMI CL
+W PALM FL
+MIAMI
+FL
+FTLAUD FL
+INCOMI
+CL
+INCOMI
+CL
+W PAIM FL
+W PALM FL
+W PAIM FL
+INCOMI
+CL
+INCOMI CL
+INCOMI
+CL
+W PAIM FL
+W PAIM FL
+TALLAH FL
+W PAIM FL
+INCOMI CL
+W PALM FL
+INCOMI
+PENSAC FL
+W PALM FL
+W PALM FL
+INCOMI
+CL
+W PALM
+FL
+INCOMI CL
+W PALM FI
+JACKSO FL
+INCOMI
+CL
+W PALM FL
+W PAIM FI
+INCOMI CL
+INCOMI CL
+W PAIM EL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PAIM FL
+W PALM FL
+INCOMI CL
+INCOMI CL
+FILAUD FL
+Rate Rate Fea-
+Min Code
+Pd
+ture Charge
+17
+NPA2 P
+2 NPAZ
+P
+NPA2
+NPA2
+NPAZ
+NPA2
+IR
+R
+RM
+RM
+IR
+IR
+1
+N
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+IRW
+IRW
+IRW
+NPA2
+NPA2
+1
+NPA2
+NPAZ
+NPA2
+R
+IR
+NPA2
+NPA2
+NPA2
+N
+NPA2
+NPAZ
+NPA2
+1
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+1
+3
+NPA2
+NPA2
+NPA2
+2 NPA2
+4 NPA2
+NPA2
+NPA2
+2
+3
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+P
+P
+P
+P
+R
+IR
+IR
+IR
+R
+IR
+IR
+R
+IR
+IR
+IR
+IRM
+IR
+IR
+DA
+Total
+Charge
+
+
+16 of 34
+03/01/06 - 03/28106
+User Name: MARTIN GOLICK
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+426
+427
+428
+429
+430
+431
+432
+433
+434
+435
+436
+437
+438
+439
+440
+441
+442
+443
+444
+445
+446
+447
+448
+449
+450
+451
+452
+453
+454
+455
+456
+457
+458
+459
+460
+461
+462
+463
+464
+465
+466
+467
+Day
+Hed
+Date
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/14
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+DST X280-9900 (10/03)
+Time
+07:37PM
+07: 45PM
+07: 53PM
+08:10PM
+08:29PM
+08:30PM
+08: 30PM
+08:51PM
+09: 55PM
+10:04PM
+10:08PM
+12:19AM
+12:59AM
+09:55AM
+10:53AM
+11:37AM
+11:42AM
+11:50AM
+12:28PM
+06:37PM
+08: 00PM
+08:03PM
+08:19PM
+08:20PM
+08:26PM
+08:27PM
+08:34PM
+08:46PM
+09: 00PM
+09:10PM
+09:21PM
+09:30PM
+09: 50PM
+09:53PM
+10:13PM
+10:13PM
+11:10PM
+11: 40PM
+CL
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+Called
+Call To
+INCOMI CL
+W PAIM FL
+W PAIM FL
+INCOMI CL
+TALLAH FL
+OPE ST
+INCOMI
+CL
+W PAIM FL
+W PAIM FL
+W PAIM FL
+INCOMI CI
+INCOMI CL
+TALLAH FL
+INCOMI CL
+W PAIM FL
+TALLAH FL
+TALLAH FL
+HOLLYW FL
+INCOMI CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+FORT M FL
+W PAIM FL
+W PALM FL
+W PAIM FI
+INCOMI CL
+JACKSO FL
+W PALM FL
+INCONI CL
+JACKSO FL
+W PALM FL
+INCOMI CL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+INCOMI
+CL
+FORT M FL
+INCOMI CI
+INCOMI CL
+W PAIM FL
+INCOMI CL
+Rate Rate Fea-
+Min Code Pd
+ture Charge
+2
+NPA2 P
+1 NºA2
+P
+2 NPA2
+1 NPA2
+IR
+R
+R
+IRM
+1
+NPAZ
+NPAZ
+1
+NPA2
+IR
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+IRW
+IRW
+NPA2
+NPA2
+4
+NPA2
+IR
+R
+NPAZ
+NPAZ
+NPA2
+R
+R
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+1
+NPA2
+NPA2
+NPA2
+NPA2
+2
+4
+NPA2
+NPA2
+• NPA2
+1 NPAZ
+NPA2
+1 NPA2
+NPA2
+NPA2
+2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+P
+P
+P
+IR
+IRM
+IR
+R
+IR
+R
+IR
+R
+IRW
+IRM
+IRW
+IRM
+DA
+Total
+Charge
+
+
+17 of 34
+03/01/06 - 03/28/06
+User Name: MARTIN GOLICK
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+468
+469
+470
+471
+472
+473
+474
+475
+476
+477
+478
+479
+480
+481
+492
+493
+495
+486
+487
+498
+489
+490
+491
+492
+493
+494
+495
+496
+497
+498
+499
+500
+501
+502
+503
+504
+505
+506
+507
+508
+509
+Day
+Thu
+Fri
+Date
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/16
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+Time
+09:04AM
+11:43AM
+11:52AM
+11:57AM
+12:18PM
+01: 09PM
+01:16PM
+01:45PM
+04:08PM
+04:10PM
+04:16PM
+04:19PM
+04:25PM
+04:27PM
+04: 29PM
+04: 34PM
+04:44PM
+04:49PM
+06:09PM
+08: 52PM
+09:51PM
+10:13PM
+12: 31AM
+09:48AM
+09:49AM
+09: 49AM
+09: 50AM
+09:52AM
+09:56AM
+10: 47AM
+10:47AM
+10:48AM
+10: 52AM
+11:05AM
+11: 49AM
+12:09PM
+12:15PM
+01:16PM
+02:13PM
+CL
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+Called
+Call To
+INCOMI CL
+W PAIM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PAIM FL
+W PAIM FL
+W PALM FL
+PERRIN
+FL
+W PALM FL
+W PALM FL
+W PAIM FL
+MIAMI
+FL
+INCOMI CL
+JACKSO FL
+W PAIM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+W PAIM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+TALLAH
+FL
+W PALM FL
+W PALM FI
+ORANGE FL
+W PALM FL
+W PAIM FL
+INCOMI CL
+W PALM FL
+ORANGE FL
+W PAIM FI
+W PALM
+FL
+W PAIM FL
+TALLAH
+FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+Rate Rate Fea-
+Min Code
+Pd
+ture Charge
+1
+NPA2 P
+1
+NPAZ
+P
+NPA2
+18
+NPA2
+IR
+R
+R
+IR
+2
+3
+2
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPAZ
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+1
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+1
+1
+NPA2
+NPA2
+NPA2
+1
+NPA2
+3 NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+4
+NPA2
+NPA2
+NPAZ
+NPA2
+P
+P
+P
+P
+P
+R
+IR
+IR
+IR
+IRW
+IRW
+IR
+IRM
+IR
+IR
+IR
+DA
+Total
+Charge
+
+
+18 of 34
+03/01/06 - 03/28106
+User Name: MARTIN GOLICK
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+510
+511
+512
+513
+514
+515
+516
+517
+518
+519
+520
+521
+522
+523
+524
+525
+526
+527
+528
+529
+530
+531
+532
+533
+534
+535
+536
+537
+538
+Day
+540
+541
+542
+543
+544
+545
+546
+547
+548
+549
+550
+551
+Date
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+DST X280-9900 (10/03)
+Time
+02:20PM
+02: 31PM
+02: 34PM
+02:57PM
+02:58PM
+03:11PM
+03:42PM
+03:43PM
+03:52PM
+03:58PM
+05:45PM
+07:11PM
+07:39PM
+07:43PM
+07:44PM
+08: 01PM
+08:34PM
+09:15PM
+09:25PM
+09: 43PM
+09:46PM
+09: 54PM
+10:13PM
+10:14PM
+10:15PM
+10:18PM
+10:21PM
+10:27PM
+01:43AM
+10:19AM
+11:00AM
+11:22AM
+11: 30AM
+11:54AM
+11:59AM
+12:01PM
+12:03PM
+12:07PM
+12:14PM
+12:49PM
+CL
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+Called
+Call To
+PERRIN FL
+FILAUD FL
+W PAIM FL
+W PALM FL
+W PAIN FL
+INCOMI
+CL
+W PAIM FL
+INCOMI
+CL
+W PAIM FL
+W PALM FL
+W PALM FL
+JACKSO FL
+VERO B FL
+STUART FL
+INCOMI CL
+JACKSO FL
+JACKSO FL
+CLEARN FL
+W PALM FL
+VERO
+FL
+INCOMI
+CL
+VERO
+W PAIM FL
+INCOMI
+CL
+VERO B FL
+W PALM FI
+INCOMI
+CL
+W PAIM FL
+INCOMI CL
+INCOMI CL
+VERO B FL
+INCOMI CL
+VERO B EL
+INCOMI CL
+JACKSO
+FL
+JACKSO
+W PALM
+FL
+FINALT
+FL
+INCOMI
+CL
+W PALM
+1 FL
+800 8E
+CL
+INCOMI CL
+Rate Rate Fea-
+Min Code
+Pd
+ture Charge
+2
+NPA2
+3 NPA2
+P
+NPA2
+NPA2
+R
+2
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+2
+2
+NPA2
+NPA2
+NPA2
+NPA2
+1
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+N
+N
+N
+N
+N
+N
+IR
+IR
+IR
+IRW
+IRM
+IRM
+IRW
+IRM
+IRW
+IRW
+IRW
+IRM
+DA
+Total
+Charge
+
+
+19 of 34
+03/01/06 - 03/28/06
+User Name: MARTIN GOLICK
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+552
+553
+554
+555
+556
+557
+558
+559
+560
+561
+562
+563
+564
+565
+566
+567
+568
+569
+570
+571
+572
+573
+574
+575
+576
+577
+578
+579
+580
+581
+582
+593
+584
+586
+597
+588
+589
+590
+591
+592
+Day
+Sun
+Mon
+Date
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+03/18
+03/19
+03/19
+03/19
+03/19
+03/19
+03/19
+03/19
+03/19
+03/19
+03/19
+03/19
+03/19
+03/19
+03/19
+03/19
+03/19
+03/20
+03/20
+03/20
+03/20
+03/20
+03/20
+03/20
+03/20
+03/20
+03/20
+Time
+01:10PM
+01:20PM
+01: 33PM
+02: 05PM
+02: 43PM
+03:01PM
+03:30PM
+03:32PM
+04: 55PM
+05:15PM
+06:33PM
+06:35PM
+06:44PM
+09:34PM
+09:36PM
+09:46PM
+08:23PM
+08:25PM
+08:25PM
+08:28PM
+08:51PM
+09:03PM
+09:03PM
+09: 04PM
+09:04PM
+09:05PM
+09: 05PM
+09:10PM
+09:11PM
+09:47PM
+09: 55PM
+10:27PM
+10:18AM
+10: 34AM
+11:09AM
+02:31PM
+04:21PM
+04:21PM
+04:33PM
+04:34PM
+09: 05PM
+09: 12PM
+CL
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+Called
+Call To
+INCOMI CL
+INCOMI CL
+PICHAR FL
+INCOMI CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+STUART
+FL
+FORT M FL
+INCOMI CL
+INCOMI CL
+INCOMI
+CL
+INCOMI
+CL
+MIAMI
+FL
+MIAMI
+FL
+MIAMI
+FL
+800 SE CL
+TALLAH FL
+TALLAH FL
+FORT
+M FL
+TALLAH
+FL
+TALLAH
+TALLAH
+FL
+TALLAH FL
+TALLAH FL
+TALLAH FI
+TALLAH
+FL
+TALLAH FL
+TALLAH FL
+TALLAH FL
+TALLAH FL
+TALLAH FL
+INCOMI CL
+INCOMI
+CL
+W PAIM
+FL
+STUART
+INCOMI
+CL
+INCOMI
+CL
+TALLAH
+FL
+TALLAH FL
+W PAIM FL
+VERO B FL
+Min
+Rate Rate Fea-
+Code
+Pd
+ture Charge
+4
+NPA2 N
+IRM
+2
+NPAZ
+N
+IRW
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+IRW
+IRW
+IRM
+IRW
+NPA2
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+N
+N
+IRW
+IRW
+IRW
+IRN
+2
+1
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+1
+NPA2
+NPA2
+NPA2
+1 NPA2
+6 NPA2
+3
+NPAZ
+NPA2
+1
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+2
+NPA2
+N
+N
+IRM
+IRM
+R
+IRM
+IRM
+DA
+Total
+Charge
+
+
+20 of 34
+03/01/06 - 03/28106
+User Name: MARTIN GOLICK
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+594
+595
+596
+597
+598
+599
+600
+601
+602
+603
+604
+605
+606
+607
+608
+609
+610
+611
+612
+613
+614
+615
+616
+617
+618
+619
+620
+621
+622
+623
+624
+625
+626
+627
+628
+629
+630
+631
+632
+633
+634
+635
+Day
+Tue
+Wed
+Date
+03/20
+03/20
+03/20
+03/20
+03/20
+03/20
+03/20
+03/20
+03/20
+03/21
+03/21
+03/21
+03/21
+03/21
+03/21
+03/21
+03/21
+03/21
+03/21
+03/21
+03/21
+03/21
+03/21
+03/21
+03/21
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+DST X280-9900 (10/03)
+Time
+09:27PM
+09:29PM
+09:30PM
+09:33PM
+09:34PM
+09:47PM
+10:01PM
+10:22PM
+11:56PM
+12: 43AM
+02:17AM
+10:09AM
+10:10AM
+10:12AM
+10: 23AM
+07: 02PM
+07:03PM
+08:00PM
+08:50PM
+08:52PM
+09:22PM
+09:39PM
+09:41PM
+10:00PM
+10:27PM
+12:06AM
+12: 06AM
+12:07AM
+12:09AM
+11:17AM
+11:24AM
+11:25AM
+02:15PM
+02:32PM
+02: 41PM
+03:16PM
+03:34PM
+03: 56PM
+05: 20PM
+06: 37PM
+CL
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+Called
+Call To
+W PAIM FL
+JACKSO FL
+DEEREL FL
+FTLAUD FL
+W PALM FL
+VERO B FL
+TALLAH FL
+VERO B EL
+FIWALT FL
+VERO B FL
+TALLAH FL
+N PAIM FI
+W PAIM FL
+W PALM FL
+W PAIM FL
+MIAMI
+FL
+VERO B FL
+VERO B FL
+W PAIM FL
+VERO
+B FL
+INCOMI
+CL
+800
+CL
+INCOMI
+CL
+JACKSO
+FL
+INCOMI CL
+VERO B FL
+VERO B FL
+VERO B EL
+FORT M FL
+W PAIM FI
+INCOMI CL
+INCOMI CL
+FIWALT EL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+W PAIM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+Rate Rate Fea-
+Min Code
+Pd
+ture Charge
+2
+NPA2
+1 NPA2
+NPA2
+NPA2
+NPAZ
+RW
+NPA2
+1
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+1
+NPA2
+R
+NPAZ
+NPA2
+NPA2
+NPA2
+N
+NPA2
+NPA2
+NPAZ
+NPAZ
+1
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+1
+NPA2
+6
+NPA2
+1 NPA2
+1 NPA2
+2 NPA2
+NPA2
+12
+2
+10
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+IRW
+IRN
+INN
+IR
+IRM
+P
+IR
+IR
+R
+IR
+IR
+IR
+IR
+DA
+Total
+Charge
+
+
+21 of 34
+03/01/06 = 03/28106
+User Name: MARTIN GOLICK
+PS=Pensacola, PJ=Port St Joe, SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa, VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+636
+637
+638
+639
+640
+641
+642
+643
+644
+645
+646
+647
+648
+649
+650
+651
+652
+653
+654
+655
+656
+657
+658
+659
+660
+661
+662
+663
+664
+665
+666
+667
+668
+670
+671
+672
+673
+674
+675
+676
+677
+Day
+Thu
+Fri
+Date
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/22
+03/23
+03/23
+03/23
+03/23
+03/23
+03/23
+03/23
+03/23
+03/23
+03/23
+03/23
+03/23
+03/23
+03/23
+03/23
+03/23
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+Time
+06:44PM
+07: 00PM
+08: 05PM
+08:07PM
+08:08PM
+08:22PM
+08:23PM
+08:29PM
+08:34PM
+09:08PM
+09:30PM
+09:36PM
+09:52PM
+12:51AM
+10:41AM
+11: 05AM
+11:12AM
+03:38PM
+04
+05
+07
+09
+09
+09
+09
+10
+12
+02
+08
+09
+09
+11
+11
+11
+12
+12
+
+CL
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+Called
+Call To
+W PAIM FL
+INCOMI CL
+VERO B FL
+FTLAUD FL
+VERO B FL
+W PAIM FL
+INCOMI CL
+W PAIM FL
+FILAUD FL
+FILAUD FI
+INCOMI CI
+INCOMI CL
+VERO B FL
+INCOMI CL
+W PAIM FL
+W PAIM FL
+INCOMI CL
+STUART FL
+W PAIM FL
+Min Code
+Pd
+2
+NPA2 P
+1 NPA2
+P
+NPA2
+1
+NPA2
+NPAZ
+13
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPAZ
+NPA2
+ture Charge
+IR
+RM
+IR
+RM
+IRW
+IRW
+IRW
+R
+IR
+DA
+Total
+Charge
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+W PAIM FL
+INCOMI
+CL
+INCOMI
+CL
+W PAIM FL
+VERO B
+FL
+INCOMI CI
+VERO B FL
+W PAIM FI
+W PAIM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+W PALM FL
+INCOMI CL
+STUART
+FL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+INCOMI
+CL
+W PALM FL
+W PALM FI
+INCOMI CL
+NPA2
+NPA2
+NPA2
+NPAZ
+NPAZ
+1
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+2
+NPA2
+NPA2
+1 NPA2
+1 NºA2
+1 NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+IR
+IRM
+IRW
+P
+IRW
+IRM
+P
+P
+P
+IRM
+IR
+IR
+
+
+User Name: MARTIN GOLICK
+22 of 34
+03/01/06 - 03/28106
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+678
+679
+680
+681
+692
+683
+684
+685
+686
+687
+698
+689
+690
+691
+692
+693
+694
+695
+696
+697
+698
+699
+700
+701
+702
+703
+704
+705
+706
+707
+708
+709
+710
+711
+712
+713
+714
+715
+716
+717
+718
+719
+Day
+Sat
+Date
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/25
+03/25
+03/25
+03/25
+03/25
+03/25
+03/25
+03/25
+03/25
+03/25
+03/25
+03/25
+03/25
+03/25
+DST X280-9900 (10/03)
+Time
+03:13PM
+03:49PM
+04:13PM
+04:23PM
+04:25PM
+05: 01PM
+05: 03PM
+05: 04PM
+05:40PM
+06:11PM
+06:14PM
+06:15PM
+06: 30PM
+06:47PM
+07:12PM
+08:07PM
+08: 09PM
+08:26PM
+08:27PM
+08:30PM
+08:35PM
+08:46PM
+08:48PM
+08: 50PM
+09:10PM
+09:11PM
+09:36PM
+04:19PM
+04: 20PM
+04:22PM
+04:23PM
+04:23PM
+04:43PM
+04:45PM
+05:22PM
+05: 30PM
+05:34PM
+05: 36PM
+05:55PM
+06:18PM
+07:29PM
+CL
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+Called
+Call To
+W PAIM FL
+W PALM FL
+INCOMI CL
+W PALM FL
+HOLLYW FL
+W PAIM FL
+W PAIM FL
+FIWALT
+EL
+INCOMI
+CL
+STUART
+FL
+FIWALT FL
+VERO B FL
+FILAUD FL
+INCOMI CL
+W PAIM FL
+INCOMI CL
+INCOMI CL
+VERO B FL
+VERO B FL
+INCOMI
+CL
+VERO
+FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+VERO B FL
+W PAIM FI
+INCOMI CL
+W PALM FL
+MIAMI
+FL
+W PALM FL
+W PALM FL
+INCOMI CL
+W PAIM FL
+FIWALT
+FL
+W PAIM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+W PAIM FL
+INCOMI CL
+Min
+Code
+1
+NPA2
+2
+NPA2
+P
+11
+NPA2
+10
+NPA2
+NPAZ
+NPAZ
+2
+2
+36
+31
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPAZ
+P
+P
+2
+12
+1
+14
+NPA2
+NPA2
+NPA2
+NPAZ
+NPAZ
+NPA2
+4
+1
+19
+1
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+N
+N
+N
+N
+Pd
+ture Charge
+R
+IR
+R
+IR
+R
+IR
+R
+IR
+IR
+R
+IR
+IR
+IR
+IR
+R
+IRM
+1.60
+12.40
+1.20
+0.80
+0.80
+4.80
+0.40
+5.60
+1.20
+0.80
+0.40
+0.80
+0.40
+3.60
+1.
+60
+0.80
+1.60
+IRW
+IRN
+IRW
+IRW
+IRW
+DA
+Total
+Charge
+1.60
+12.40
+1.20
+0.80
+0.80
+4.80
+0.40
+5.60
+1.20
+0.80
+0.40
+0.80
+0.40
+3.60
+1.60
+0.80
+1.60
+
+
+23 of 34
+03/01/06 - 0322806
+User Name: MARTIN GOLICK
+PS=Pensacola, PJ=Port St Joe, SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa, VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+720
+721
+722
+723
+724
+725
+726
+727
+728
+729
+730
+731
+732
+733
+734
+735
+736
+737
+738
+739
+740
+741
+742
+743
+744
+745
+746
+747
+748
+749
+750
+751
+752
+753
+754
+755
+756
+757
+758
+759
+760
+761
+Day
+Sun
+Mon
+Date
+03/25
+03/25
+03/25
+03/25
+03/25
+03/25
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/26
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+Time
+07:37PM
+07: 51PM
+07:51 PM
+09:23PM
+09: 42PM
+12:56AM
+02:08AM
+02: 20AM
+11:10AM
+01:45PM
+01:56PM
+02: 04PM
+02:13PM
+02: 43PM
+02: 58PM
+03:11PM
+03:14PM
+04:08PM
+04:19PM
+07:18PM
+07:39PM
+07: 40PM
+07:44PM
+08:01PM
+08:20PM
+08:47PM
+10:36PM
+11:23PM
+11:53PM
+12: 07AM
+11: 50AM
+11:50AM
+11:51AM
+11: 53AM
+12:13PM
+12:16PM
+12:33PM
+12:35PM
+02:20PM
+CL
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+Called
+850-576-1890
+Call To
+TALLAH FL
+VERO B FL
+INCOMI CL
+VERO B FL
+INCOMI CL
+VERO B FL
+W PAIM FL
+W PALM FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI CL
+INCOMI CL
+VERO B FL
+W PAIM FL
+VERO B FL
+INCOMI CL
+8OO SE CL
+INCOMI CL
+W PALM FL
+W PAIM FL
+PALM FL
+W PALM FL
+MIAMI
+FL
+W PALM
+FL
+INCOMI CL
+W PAIM FI
+TALLAH
+FL
+INCOMI
+CL
+W PALM FL
+W PAIM FL
+FORT M FL
+INCOMI CL
+W PALM FL
+W PAIM FL
+ORANGE
+FL
+W PAIM FL
+INCOMI
+CL
+FORT M FL
+W PALM FI
+INCOMI
+CL
+INCOMI CL
+W PALM FL
+Min
+Code
+2
+NPA2
+N
+1
+NPAZ
+N
+NPA2
+N
+NPA2
+2
+N
+17
+18
+2
+3
+2
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPAZ
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+N
+N
+P
+P
+Pd
+ture Charge
+IRW
+IRM
+IRN
+IRW
+IRW
+IRW
+IRN
+IRW
+DA
+INN
+IRM
+IRW
+IR
+R
+IR
+IRM
+0.40
+0.40
+0.40
+0.40
+2.40
+0.40
+3.60
+0.B0
+Total
+Charge
+0.40
+0.40
+0.40
+0.40
+2.40
+0.40
+3.60
+0.80
+
+
+User Name: MARTIN GOLICK
+LK=Lakeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+762
+763
+764
+765
+766
+767
+768
+769
+770
+771
+772
+773
+774
+775
+776
+777
+778
+779
+790
+781
+792
+783
+784
+785
+786
+797
+788
+789
+790
+791
+792
+793
+794
+795
+796
+797
+798
+799
+800
+801
+802
+803
+Day
+Tue
+Date
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+DST X280-9900 (10/03)
+Time
+02:23PM
+02:25PM
+02:25PM
+03:28PM
+03:29PM
+04:41PM
+04:49PM
+05:19PM
+05: 20PM
+05: 22PM
+06: 06PM
+08:04PM
+09:08PM
+09:35PM
+10:00PM
+10: 06PM
+10:07PM
+10: 08PM
+10:15PM
+10:25PM
+10: 36PM
+10: 43PM
+10: 52PM
+11:26PM
+11:32PM
+11:51PM
+11:57PM
+12:01AM
+09:07AM
+10:41AM
+10: 51AM
+10: 53AM
+10: 56AM
+11:28AM
+11: 38AM
+11:38AM
+11: 38AM
+11: 42AM
+12: 01PM
+12: 02PM
+12:51PM
+12:52PM
+CL
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+Called
+Call To
+FILAUD FL
+STUART FL
+STUART FL
+W PALM FL
+INCOMI CL
+MIAMI
+FL
+W PAIM FL
+DELRAY
+FL
+DELRAY
+FL
+INCOMI
+CL
+INCOMI CL
+W PAIM FI
+W PAIM FL
+W PAIM FL
+W PAIM FL
+W PAIM FL
+ORANGE FL
+W PAIM FL
+W PALM FL
+W PAIM FL
+W PALM FL
+INCOMI
+INCOMI
+CL
+800 8E
+CL
+TALLAH FL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI
+CL
+INCOMI CL
+W PAIM FL
+W PALM FL
+INCOMI CL
+W PAIM FL
+DELRAY
+FL
+DELRAY
+DELRAY
+FL
+W PAIM FL
+FORT M FI
+INCOMI CL
+MIAMI
+FL
+TALLAH FL
+Min
+Code
+1
+NPA2
+P
+1
+NPA2
+P
+NPA2
+NPA2
+NPAZ
+NPA2
+2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPAZ
+P
+P
+NPA2
+23
+1
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+11
+NPA2
+NPA2
+N
+NPA2
+NPAZ
+NPA2
+1
+NPA2
+3
+NPA2
+NPA2
+21
+NPA2
+1
+NPA2
+2
+NPA2
+1 NPAZ
+1 NPA2
+27 NPA2
+2 NPAZ
+NPA2
+1
+NPA2
+NPA2
+18
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+P
+Pd
+ture
+R
+IRM
+RM
+RM
+IR
+IR
+IRW
+IRM
+IRM
+IRM
+IRM
+IR
+IR
+IR
+RM
+RM
+R
+IR
+R
+24 of 34
+03/01/06 - 03/28106
+Charge
+0.40
+1.20
+0.40
+0.80
+0.80
+2.40
+0.40
+DA
+0.40
+0.80
+0.40
+0.40
+10.80
+0.80
+7.20
+1.20
+3.20
+Total
+Charge
+0.40
+1.20
+0.40
+0.80
+0.80
+2.40
+0.40
+0.40
+0.80
+0.40
+0.40
+10.80
+0.80
+7.20
+1.20
+3.20
+
+
+25 of 34
+03101/06 - 03/28106
+User Name: MARTIN GOLICK
+PS=Pensacola, PJ=Port St Joe. SD=SanDestin, SA=Sarasota, TH=Tallahassee, TA=Tampa. VB=Vero Beach, NA=Naples,
+L.K=L.akeland, TV=Thomasville, SB=Sebring
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+804
+805
+806
+807
+808
+809
+810
+811
+812
+813
+814
+815
+816
+817
+818
+819
+820
+821
+822
+Day
+Date
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+Time
+01:04PM
+01:36PM
+01: 43PM
+01: 52PM
+04:33PM
+05:01PM
+05:29PM
+05: 31PM
+05: :33PM
+06:12PM
+06:17PM
+06:33PM
+06:52PM
+06:53PM
+07:47PM
+08:28PM
+09:48PM
+11:13PM
+CL
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+TH
+Called
+TH
+TH
+TH
+TH
+TH
+Call To
+W PAIM FL
+INCOMI CL
+INCOMI CL
+W PALM FL
+MIAMI
+FL
+CLEARN
+FL
+INCOMI
+CL
+W PAIM
+EL
+INCOMI
+CL
+INCOMI
+CL
+W PALM FL
+INCOMI
+CL
+W PAIM FL
+N PAIM FL
+INCOMI
+CL
+CLEARN FL
+INCOMI CL
+W PALM FL
+INCOMI CL
+Min
+Code
+1
+NPA2
+P
+2 NPAZ
+P
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+2
+NPA2
+P
+NPAZ
+NPA2
+23
+NPA2
+NPAZ
+P
+P
+NPA2
+NPA2
+1
+2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+Pd
+R
+IR
+IR
+R
+RM
+ture
+Charge
+0.40
+0.80
+1.60
+0.40
+DA
+IR
+IR
+IR
+IR
+IR
+R
+IRM
+1.60
+0.40
+0.80
+0.40
+2.00
+9.20
+0.40
+0.40
+0.40
+0.40
+0.80
+IRM
+Subtotal Minotas
+Totals
+93.20
+99.20
+0.00 99.20
+0.00 99.20
+Roaming Call Detail
+User Name: MARTIN GOLICK
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+ature: 1=PTT One-to-One event; a=Automated Call Return; B=Direct Asst Call Complete; C=Call Waiting; D=Data Ca
+Directory Assistance Call; F=Call Forwarding: g=PTT Group event; H=Group Mobile to Mobile Calls; I=Incoming Ca
+-Roam i Home: S-Shared Minutes: TeThree Vay Calling. Vone Activated Dating: W= Night and Weekende: 0-# VPN;
+Number
+Item Day
+Date
+Time
+Called
+Call To Min Rade Fire Anarge Charge
+Intl
+Tax
+Charges Incurred While Roaming in TALLAHASSEE (PCS), F
+1
+Mon
+02/27 08:25PM
+N PALM FL
+1 NPA2
+Tue
+02/28
+08:40AM
+W PALM FL
+1 NPA2
+02/28
+09: 05AM
+W PALM FL
+3 NPA2
+02/28
+10: 00AM
+W PALM FL
+1 NPAZ
+02/28
+10: 02AM
+W PALM FL
+3 NPA2
+02/28
+11:01AM
+STUART FL
+5
+NPA2
+02/28
+08: 51PM
+W PALM FL
+1
+NPA2
+Total
+Charge
+0.40
+0.80
+1.60
+0.40
+1.60
+0.40
+0.80
+0.40
+2.00
+9.20
+0.40
+0.40
+0.40
+0.40
+0.80
+Total
+Charge
+
+
+Roaming Call Detail (Continued)
+User Name: MARTIN GOLICK
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item Day
+Date
+Time
+Called
+02/28
+08:53PM
+02/28 09:05PM
+10
+02/28 09:19PM
+11
+02/28
+09:34PM
+12
+02/28
+09: 35PM
+13
+Ked
+03/01
+09:43AM
+14
+03/01
+10: 36AM
+15
+03/01
+10: 56AM
+16
+03/01
+02:17PM
+17
+03/01
+07:58PM
+18
+03/01
+08:11PM
+19
+03/01
+10:00PM
+20
+03/01
+10:12PM
+21
+03/01
+10:22PM
+22
+Thu
+03/02
+11:38AM
+23
+03/02
+11: 51AM
+24
+03/02
+12:24PM
+25
+03/02
+03: 51PM
+26
+03/02
+03: 56PM
+27
+03/02
+04:10PM
+28
+03/02
+05: 08PM
+29
+03/02
+05:23PM
+30
+03/02
+05: 36PM
+31
+03/02
+10:15PM
+32
+Fri
+03/03
+03:18PM
+Charges
+Incurred
+33
+While
+Roaming
+in JAI
+03/03
+07:46PM
+34
+35
+Sat
+Sun
+03/04
+09:18PM
+03/05
+08:25PM
+36
+03/05
+08:28PM
+37
+Mon
+03/06
+08: 33AM
+Charges
+Incurred
+While
+Roaming
+in
+TA
+38
+03/06
+09:49AM
+39
+03/06
+11:33AM
+40
+03/06
+12:32PM
+41
+Sat
+03/11
+03:14PM
+Charges
+Incurred
+While
+Roaming
+in JAI
+42
+03/11
+05: 38PM
+43
+03/11
+05: 49PM
+44
+03/11
+07:10PM
+45
+03/11
+07:59PM
+46
+03/11
+09: 42PM
+47
+03/11
+09:44PM
+48
+Sun
+03/12
+02:30AM
+49
+03/12
+01:31PM
+50
+03/12
+07: 52PM
+Charges
+Incurred
+While
+Roaming
+in
+TA
+DST X280-9900 (10/03)
+N PALM FL
+N PALM FL
+W PALM FL
+W PALM FL
+N PALM FL
+PALM FL
+DEERFL
+FL
+W PALM FL
+FORT M FL
+W PALM FL
+W PALM FL
+W PALM FI
+PALM FL
+FTLAUD FL
+FORT M FL
+W PALM FL
+W PALM FL
+DEERFL FL
+W PALM FL
+DEERFL FL
+FIWALI FL
+PALM FI
+PALM FL
+W PALM FL
+STUART FL
+Charge
+1
+NPA2
+7
+NPA2
+4
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+53
+1
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+4
+NPA2
+1
+NPA2
+26 of 34
+03/01/06 - 03/28106
+Charge
+Total
+Chargi
+.00
+
+
+Billing Cycle Date:
+Account Number:
+27 of 34
+03/01/06 - 03/28106
+Roaming Call Detail (Continued)
+User Name: MARTIN GOLICK
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+ature: 1=PTT One-to-One event; a=Automated Call Return; B=Direct Asst Call Complete, C=Call Waiting; D=Data C
+Directory Assistance Call: F=Call Forwarding: g=PTT Group event: H=Group Mobile to Mobile Calls: I=Incoming C
+Fax Call; M=Mobile To Mobile Discount, N=Off-Network; O=Auto Dropped Call Credit; P=Priority Access Service; Q=VE
+Roam with Home; S=Shared Minutes; T=Three Way Calling: =Voice Activated Dialing: W=Night and Weeken
+Number
+late
+Item Day
+Date
+Time
+Called
+Call To
+Min
+Code
+51
+03/12
+10:07PM
+W PALM FL
+1
+NPAZ
+52
+03/12
+10:19PM
+W PALM FL
+NPA2
+53
+03/12
+10:19PM
+W PALM FL
+NPA2
+54
+03/12
+10:29PM
+W PALM FL
+2
+NPA2
+55
+03/12
+10:55PM
+N PALM FL
+NPA2
+56
+Mon
+03/13
+07: 48AM
+PALM FL
+NPAZ
+57
+03/13
+09:57AM
+PALM
+FI
+NPA2
+58
+03/13
+10: 59AM
+PALM FL
+NPA2
+59
+03/13
+05: 05PM
+PALM FL
+NPAZ
+60
+03/13
+05:07PM
+MIAMI
+FI
+NPA2
+61
+03/13
+05: 12PM
+FTLAUD FL
+NPA2
+62
+03/13
+09: 02PM
+W PALM FI
+1
+NPA2
+63
+03/13
+09:03PM
+W PALM FL
+NPAZ
+64
+03/13
+09:08PM
+PALM FL
+NPA2
+65
+03/13
+10: 03PM
+PALM FL
+NPA2
+66
+03/13
+10:58PM
+W PALM FL
+NPA2
+67
+Tue
+03/14
+10:58AM
+W PALM FL
+NPA2
+68
+03/14
+11:06AM
+W PALM FL
+NPA2
+69
+03/14
+12:31PM
+PENSAC FL
+NPA2
+70
+03/14
+12:32PM
+PALM FL
+NPA2
+71
+03/14
+12: 33PM
+FI
+NPA2
+72
+03/14
+12:56PM
+FI
+NPA2
+73
+03/14
+01:19PM
+FL
+NPA2
+74
+03/14
+01:31PM
+JACKSO
+FL
+NPAZ
+75
+03/14
+01: 40PM
+W PALM FI
+NPA2
+76
+03/14
+01:41PM
+W PALM FI
+NPA2
+77
+03/14
+02:55PM
+W PALM FL
+NPA2
+78
+03/14
+06:09PM
+PALM FL
+NPA2
+79
+03/14
+07:04PM
+W PALM FL
+NPA2
+80
+03/14
+07:16PM
+FILAUD FL
+NPA2
+81
+03/14
+07:45PM
+W PALM FL
+NPA2
+82
+03/14
+07: 53PM
+W PALM FL
+NPA2
+83
+03/14
+08: 51PM
+NPA2
+84
+03/14
+09:56PM
+W PALM EL
+NPA2
+85
+03/14
+10:05PM
+PALM FL
+NPA2
+86
+Hed
+03/15
+10: 54AM
+PALM FL
+NPA2
+87
+03/15
+11: 42AM
+HOLLIN
+FL
+NPAZ
+88
+03/15
+08:00PM
+FORI M FL
+NPA2
+89
+03/15
+08: 03PM
+W PALM FL
+NPA2
+90
+03/15
+08: 20PM
+W PALM FL
+NPA2
+91
+03/15
+08:20PM
+W PALM FL
+NPA2
+92
+03/15
+08:27PM
+JACKSO FL
+NPA2
+93
+03/15
+08:27PM
+W PALM FL
+NPA2
+94
+03/15
+08:47PM
+JACKSO FL
+NPA2
+95
+03/15
+09:00PM
+W PALM FL
+NPA2
+96
+03/15
+09:21PM
+W PALM FL
+NPA2
+97
+03/15
+09:51PM
+W PALM FL
+NPA2
+Total
+Chargi
+.00
+. 00
+1.00
+.00
+
+
+28 of 34
+03/01/06 - 03/28106
+Roaming Call Detail (Continued)
+User Name: MARTIN GOLICK
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item Day
+98
+99
+100
+Thu
+101
+102
+103
+104
+105
+106
+107
+108
+109
+110
+111
+112
+113
+Fri
+114
+115
+116
+117
+118
+119
+120
+121
+122
+123
+124
+125
+126
+127
+128
+129
+131
+132
+134
+135
+136
+137
+138
+139
+140
+141
+142
+143
+144
+Date
+Time
+03/15
+10:13PM
+03/15 11:12PM
+03/16 11:44AM
+03/16 11:53AM
+03/16
+12:18PM
+03/16
+12:30PM
+03/16
+01: 45PM
+03/16
+04:09PM
+03/16
+04:10PM
+03/16
+04:16PM
+03/16
+04:19PM
+03/16
+04:27PM
+03/16
+04:45PM
+03/16
+04: 50PM
+03/16
+06:09PM
+03/17
+09: 49AM
+03/17
+09:49AM
+03/17
+09: 49AM
+03/17
+09: 50AM
+03/17
+09:52AM
+03/17
+10:47AM
+03/17
+10: 48AM
+03/17
+10: 48AM
+03/17
+10: 53AM
+03/17
+11: 05AM
+03/17
+02:14PM
+03/17
+02:21PM
+03/17
+02:31PM
+03/17
+02:34PM
+03/17
+02:58PM
+03/17
+02:59PM
+03/17
+03:43PM
+03/17
+03:52PM
+03/17
+03:59PM
+03/17
+05: :45PM
+03/17
+07:11PM
+03/17
+07:39PM
+03/17
+07:43PM
+03/17
+08: 01PM
+03/17
+08: :35PM
+03/17
+09:15PM
+03/17
+09:25PM
+03/17
+09:44PM
+03/17
+09:54PM
+03/17
+10:13PM
+03/17
+10:16PM
+03/17
+10:18PM
+DST X280-9900 (10/03)
+Called
+FORT M FL
+N PALM FL
+W PALM FL
+W PALM FL
+N PALM FL
+PALM FL
+PERRIN
+FI
+PALM FL
+PALM FL
+W PALM FL
+MIAMI
+FL
+JACKSO FI
+W PALM FL
+PALM FL
+PALM FL
+W PALM FL
+W PALM FL
+ORANGE FL
+W PALM FL
+PALM FL
+PALM FL
+FL
+PALM FI
+W PALM FL
+W PALM FL
+W PALM FL
+PERRIN FL
+FTLAUD FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+W PALM FL
+PALM FL
+JACKSO
+FL
+VERO B
+FL
+STUART FL
+JACKSO FL
+JACKSO FL
+CLEARN FL
+W PALM FL
+VERO B FL
+VERO B FL
+W PALM FL
+VERO B FL
+W PALM FL
+Call To Min Rade fure Aarge charge Tax
+1
+NPA2
+2
+NPA2
+1
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPAZ
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+NPA2
+Total
+Charg
+.00
+. 00
+1.00
+. 00
+1.00
+. 00
+
+
+Billing Cycle Date:
+Account Number:
+29 of 34
+03101/06 - 03/28/06
+Roaming Call Detail (Continued)
+User Name: MARTIN GOLICK
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+ature: 1=PTT One-to-One event; a=Automated Call Return; B=Direct Asst Call Complete, C=Call Waiting; D=Data C
+Directory Assistance Call: F=Call Forwarding: g=PTT Group event: H=Group Mobile to Mobile Calls: I=Incoming C
+Fax Call; M=Mobile To Mobile Discount, N=Off-Network; O=Auto Dropped Call Credit; P=Priority Access Service; Q=VE
+Roam with Home; S=Shared Minutes; T=Three Way Calling: =Voice Activated Dialing: W=Night and Weeken
+Number
+Item Day
+Date
+Time
+Called
+Call To
+Min Code
+145
+03/17 10:27PM
+W PALM FL
+1
+NPA2
+146
+Sat
+03/18 11:00AM
+VERO B FL
+1
+NPA2
+147
+03/18
+11:30AM
+VERO B FL
+1
+NPA2
+148
+03/18
+11: 54AM
+JACKSO FL
+1
+NPA2
+149
+03/18
+12: 00PM
+JACKSO FL
+NPA2
+150
+03/18
+12:00PM
+W PALM FL
+NPAZ
+151
+03/18
+12:01PM
+FIWALT
+FI
+NPA2
+152
+03/18
+12:07PM
+N PALM FL
+NPA2
+153
+03/18
+01: 33PM
+PTCHAR
+FL
+NPAZ
+154
+03/18
+03: 32PM
+STUART FL
+NPA2
+155
+03/18
+04:55PM
+FORT M FL
+NPA2
+156
+03/18
+09: 34PM
+MIAMI
+FL
+2
+NPA2
+157
+03/18
+09:36PM
+MIAMI
+FL
+NPA2
+158
+03/18
+09:46PM
+MIAMI
+FL
+NPA2
+159
+Sun
+03/19
+08:28PM
+FORT M FL
+NPA2
+160
+Mon
+03/20
+02:31PM
+STUART FL
+NPA2
+161
+03/20
+09:05PM
+W PALM FL
+NPA2
+162
+03/20
+09:13PM
+VERO B FL
+NPA2
+163
+03/20
+09:28PM
+W PALM FL
+NPA2
+164
+03/20
+09:29PM
+JACKSO FL
+NPAZ
+165
+03/20
+09:30PM
+DEERFL
+FI
+NPA2
+166
+03/20
+09:33PM
+FTLAUD
+FI
+NPA2
+167
+03/20
+09:34PM
+N PALM FI
+NPA2
+168
+03/20
+09:47PM
+VERO B FL
+NPA2
+169
+03/20
+10:23PM
+VERO B FL
+NPA2
+170
+03/20
+11:57PM
+FIWALT FL
+NPA2
+171
+Tue
+03/21
+12: 44AM
+VERO B FL
+NPAZ
+172
+03/21
+10:09AM
+W PALM FL
+NPA2
+173
+03/21
+10:10AM
+W PALM FL
+NPA2
+174
+03/21
+10:12AM
+W PALM FL
+NPA2
+175
+03/21
+10:23AM
+W PALM FL
+NPA2
+176
+03/21
+07: 02PM
+MIAMI
+FL
+NPA2
+177
+03/21
+07:04PM
+VERO B FL
+NPA2
+178
+03/21
+08:00PM
+VERO
+FL
+NPA2
+179
+03/21
+08: :51PM
+PALM FL
+NPA2
+180
+03/21
+08: 52PM
+VERO
+FL
+NPA2
+181
+03/21
+10: 00PM
+JACKSO
+FL
+NPAZ
+182
+Wed
+03/22
+12: 06AM
+VERO B FL
+NPA2
+183
+03/22
+12: 07AM
+VERO B FL
+NPA2
+184
+03/22
+12:08AM
+VERO B FL
+NPA2
+185
+03/22
+12:09AM
+FORT M FL
+NPA2
+186
+03/22
+11:17AM
+W PALM FL
+NPA2
+187
+03/22
+02:16PM
+FIWALT FL
+NPA2
+03/22
+02:23PM
+W PALM FL
+NPA2
+189
+03/22
+03:17PM
+W PALM FL
+NPA2
+190
+03/22
+06:37PM
+W PALM FL
+NPA2
+191
+03/22
+06:44PM
+N PALM FL
+NPA2
+Total
+Chargi
+.00
+1.00
+
+
+Billing Cycle Date:
+Account Number
+30 of 34
+03/01/06 - 03/28106
+Roaming Call Detail (Continued)
+User Name: MARTIN GOLICK
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item Day
+192
+193
+194
+195
+196
+Fri
+197
+198
+199
+200
+201
+202
+203
+204
+205
+206
+207
+208
+Sat
+209
+210
+211
+213
+214
+215
+216
+217
+218
+219
+220
+221
+222
+223
+224
+225
+226
+227
+228
+229
+230
+231
+232
+233
+234
+235
+236
+237
+238
+Sun
+Mon
+Date
+Time
+03/22 08:05PM
+03/22 08:07PM
+03/22
+08:08PM
+03/22
+08: 09PM
+03/24
+09: 41AM
+03/24
+09:48AM
+03/24
+11:50AM
+03/24
+12:14PM
+03/24
+03:14PM
+03/24
+03:14PM
+03/24
+04:13PM
+03/24
+08: 26PM
+03/24
+08:30PM
+03/24
+08:50PM
+03/24
+09:11PM
+03/24
+09:12PM
+03/25
+04:20PM
+03/25
+04:23PM
+03/25
+04: 45PM
+03/25
+06:19PM
+03/26
+02:04PM
+03/26
+02:13PM
+03/26
+02: 43PM
+03/26
+04:08PM
+03/26
+04:19PM
+03/26
+07:39PM
+03/26
+07:41PM
+03/26
+08:01PM
+03/26
+10:36PM
+03/26
+11:23PM
+03/27
+11:50AM
+03/27
+11: 50AM
+03/27
+11: 51AM
+03/27
+11: 51AM
+03/27
+12:13PM
+03/27
+12:17PM
+03/27
+02:20PM
+03/27
+02:23PM
+03/27
+02:25PM
+03/27
+02: 26PM
+03/27
+03:28PM
+03/27
+04:41PM
+03/27
+05:19PM
+03/27
+05:20PM
+03/27
+08:04PM
+03/27
+09:08PM
+03/27
+09: 35PM
+DST X280-9900 (10/03)
+Called
+VERO B FL
+2 NPA2
+FILAUD FL
+NPA2
+VERO B FL
+NPA2
+W PALM FL
+12
+NPA2
+STUART FI
+NPA2
+PALM FL
+NPAZ
+PALM FI
+NPA2
+PALM FL
+NPA2
+PALM FI
+NPAZ
+N PALM FL
+NPA2
+W PALM FL
+10
+NPA2
+VERO B FL
+NPA2
+VERO B FL
+NPAZ
+W PALM FL
+NPA2
+VERO B FL
+NPA2
+W PALM FL
+NPA2
+MIAMI
+FL
+NPA2
+W PALM FL
+NPA2
+FIWALT FL
+NPA2
+W PALM FL
+NPAZ
+VERO
+B FI
+NPA2
+N PALM FL
+NPA2
+VERO B FI
+NPA2
+N PALM FI
+NPAZ
+W PALM FL
+NPA2
+MIAMI
+FL
+NPA2
+W PALM FL
+NPAZ
+W PALM FL
+18
+NPA2
+W PALM FL
+NPA2
+W PALM FL
+3
+NPA2
+W PALM FL
+1
+NPA2
+W PALM FL
+NPA2
+NPA2
+W PALM FL
+NPA2
+FORT M FL
+NPA2
+W PALM FL
+NPA2
+W PALM FL
+NPAZ
+FTLAUD FL
+NPA2
+STUART FL
+NPA2
+STUART FL
+NPA2
+W PALM FL
+NPA2
+MIAMI
+FL
+NPA2
+DELRAY FL
+NPA2
+DELRAY FL
+NPA2
+W PALM FL
+NPA2
+W PALM FL
+NPA2
+W PALM FL
+23
+NPA2
+Total
+Chargi
+.00
+. 00
+1.00
+1.00
+
+
+Billing Cycle Date:
+Account Number
+31 of 34
+03/01/06 = 03/28/06
+Roaming Call Detail (Continued)
+User Name: MARTIN GOLICK
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item Day
+239
+240
+241
+242
+243
+244
+245
+Tue
+246
+247
+248
+249
+250
+251
+252
+253
+254
+255
+256
+257
+258
+259
+260
+261
+262
+263
+Totals
+Date
+03/27
+03/27
+03/27
+03/27
+03/27
+03/27
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+03/28
+Time
+10:00PM
+10:07PM
+10:07PM
+10:08PM
+10:15PM
+10:25PM
+10: 52AM
+10: 53AM
+11:28AM
+11: 38AM
+11: 38AM
+11:39AM
+11:42AM
+12:01PM
+12: 51PM
+01:05PM
+01: 52PM
+04:33PM
+05: 01PM
+05:31PM
+06:18PM
+06: 53PM
+06:53PM
+08:28PM
+11:14PM
+Called
+Call To
+Min Rade Fure Altige Charge TaX
+W PALM FL
+1
+NPA2
+W PALM FL
+1
+NPA2
+ORANGE FL
+NPA2
+W PALM FL
+1
+NPA2
+W PALM FL
+NPA2
+W PALM FL
+11
+NPAZ
+PALM FL
+NPA2
+PALM FL
+NPA2
+W PALM FL
+NPA2
+DELRAY FL
+NPA2
+DELAY FL
+NPA2
+DELRAY FL
+NPA2
+W PALM FL
+18
+NPA2
+FORT M FL
+NPA2
+MIAMI
+FL
+NPA2
+W PALM FL
+NPA2
+W PALM FL
+NPA2
+MIAMI
+FL
+NPA2
+CLEARN FL
+NPA2
+W PALM FL
+NPA2
+W
+PALM FL
+23
+NPA2
+PALM FL
+NPA2
+W PALM FL
+NPA2
+CLEARN FL
+NPA2
+W PALM FL
+NPA2
+597
+Data Detail
+User Name: MARTIN GOLICK
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Feature: 1=PTT One-to-One event; a=Automated Call Return; B=Direct Asst Call Complete; C=Call Waiting; D=Data Call
+I=Directory Assistance Call; F=Call Forwarding: g=PTT Group event; H=Group Mobile to Mobile Calls; I=Incoming Call
+K=Fax Call; M=Mobile To Mobile Discount; N=Off-Network; O= Auto Dropped Call Credit; P=Priority Access Service: Q= -VPN;
+R=Roam with Home; S=Shared Minutes; T=Three Way Calling: = Voice Activated Dialing: W=Nighti and Weekends
+Msg/KB/ Rate Rate Fea- In/
+Item
+Day
+Tue
+Wed
+Date
+02/28
+02/28
+02/28
+02/28
+03/01
+03/01
+03/01
+03/01
+Time
+09:29PM
+09:34PM
+10:41PM
+10:41PM
+12:44AM
+10: 26AM
+10:26AM
+03:53PM
+To/From
+Type
+OTHER MOBILE 10
+Min
+Code Pd
+ture Out
+1 Mag NPA2
+Out
+1 Mag NPA2
+In
+OTHER MOBILE TO
+OTHER MOBILE TO
+MIM Other
+OTHER MOBILE TO
+OTHER MOBILE 2O
+CINGULAR MOBILE
+1 Mag NPA2
+out
+1 Mag NPA2
+Out
+1 Mag NPA2
+1 Mag NPA2
+In
+Out
+1 Mag NPA2
+out
+1 Mag NPA2
+In
+Total
+Chargi
+Total
+Charge
+
+
+X
+cingular
+Billing Cycle Date:
+Account Number:
+32 of 34
+03/01/06 - 03/28106
+Data Detail (Continued)
+User Name: MARTIN GOLICK
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+Item
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+26
+27
+28
+29
+30
+31
+32
+33
+34
+35
+36
+37
+38
+39
+40
+41
+42
+43
+45
+46
+47
+48
+49
+50
+51
+52
+53
+54
+55
+Day
+Date
+Thu
+03/02
+03/02
+Wed
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+03/08
+Thu
+03/09
+03/09
+03/09
+03/09
+03/09
+Fri
+Sat
+Mon
+03/10
+03/11
+03/13
+03/13
+03/13
+03/13
+Tue
+03/14
+03/14
+03/14
+03/14
+Wed
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+03/15
+DST X280-9900 (10/03)
+Time
+12: 02PM
+12:10PM
+11:15AM
+11:15AM
+11:16AM
+11:16AM
+11:16AM
+11:32AM
+11:58AM
+02:34PM
+09: 00AM
+09: 01AM
+07:10PM
+07:48PM
+07:49PM
+10:25AM
+05:17AM
+08: 30AM
+12: 58PM
+05:11PM
+06:47PM
+09:16AM
+08: 44PM
+09:54PM
+10:04PM
+09:58AM
+10:17AM
+10:19AM
+10:19AM
+01:26PM
+01:28PM
+01:33PM
+04:52PM
+04:53PM
+07:44PM
+07:47PM
+07:48PM
+07:48PM
+09:56PM
+10:03PM
+10:05PM
+10:06PM
+10:06PM
+10: 07PM
+10:08PM
+11:19PM
+11:21PM
+To/From
+Type
+CINGULAR MOBILE
+CINGULAR MOBILE
+NOL TXT
+OTHER MOBILE TO
+AOL TXT
+AOL IXI
+AOL IXT
+OTHER MOBILE TO
+OTHER MOBILE TO
+OTHER MOBILE TO
+MIM Other
+OTHER MOBILE TO
+CINGULAR MOBILE
+MTM Other
+OTHER MOBILE TO
+MIM Other
+MIM Other
+OTHER MOBILE TO
+CINGULAR MOBILE
+OTHER MOBILE TO
+OTHER MOBILE TO
+MIM Other
+OTHER MOBILE TO
+MIM Other
+MIM Other
+MIM Other
+OTHER MOBILE TO
+MTM Other
+OTHER MOBILE TO
+MIM Other
+OTHER MOBILE TO
+MIM Other
+MIM Other
+OTHER MOBILE TO
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+MIM Other
+MIM Other
+OTHER MOBILE TO
+MIM Other
+CINGULAR MOBILE
+OTHER MOBILE TO
+CINGULAR MOBILE
+CINGULAR MOBILE
+CINGULAR MOBILE
+Code Pd
+1 Msg NPA2
+1 Mag NPA2
+NPA2
+NPA2
+NPA2
+In
+Out
+1
+In
+Out
+Out
+1
+1
+1
+1
+1
+1
+1
+1 Mag
+NPA2
+1 Mag
+NPA2
+1 Mag
+NPA2
+1 Mag
+NPA2
+1 Mag
+NPA2
+1 Mag
+NPA2
+1 Mag
+NPA2
+1 Mag
+NPA2
+1 Mag NPA2
+1 Mag
+NPA2
+1 Mag
+NPA2
+1 Mag
+NPA2
+1 Mag NPA2
+1 Mag NPA2
+1 Msg NPA2
+1 Mag NPA2
+Out
+In
+Out
+In
+In
+Out
+In
+Out
+In
+Out
+In
+In
+Out
+In
+In
+Out
+Out
+In
+Out
+Total
+Chargi
+
+
+Billing Cycle Date:
+Account Number:
+33 of 34
+03101/06 - 03/28/06
+Data Detail (Continued)
+User Name: MARTIN GOLICK
+Rate Code: NPA2=NATP900RUMMUNW
+Rate Period (Pd.): P=Peak, O=Off Peak, N=Nights
+Call To: ** = International Call Terminated To Mobile
+eDurectory Ariance Cal Feal Forwarning Cal Group even HAGroup Come to Cale Cals, Encoming Call.
+= Directory Assistance Call: F=Call Forwarding: g=
+EFax Call; M=Mobile To Moble Discount; N=Off-Network; O=Auto Dropped Call Credit; P=Priority Access Service; Q÷-VPN
+=Roam with Home; S=Shared Minutes; T=Three Way Calling: =Voice Activated Dialing: W=Night and Weekend:
+Item
+56
+57
+58
+59
+60
+61
+62
+63
+64
+65
+66
+67
+68
+69
+70
+71
+72
+73
+74
+75
+76
+77
+78
+79
+80
+81
+82
+83
+84
+85
+86
+Day
+Thu
+Sat
+Mon
+Tue
+Date
+03/15
+03/16
+03/16
+03/16
+03/16
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/17
+03/18
+03/18
+03/18
+03/20
+03/20
+03/21
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+03/24
+Time
+11:23PM
+11: 55AM
+11: 55AM
+12:26PM
+04: 01PM
+01:04AM
+01:49AM
+01:50AM
+01:51AM
+01:52AM
+01:53AM
+12:26PM
+12:29PM
+07:42PM
+07:43PM
+03:59PM
+06:59PM
+07:00PM
+08: 03PM
+08:14PM
+11: 06PM
+09: 33AM
+09: 45AM
+11: 05AM
+11: 05AM
+11: 58AM
+01:37PM
+02: 02PM
+02:37PM
+02: 42PM
+02:43PM
+02: 43PM
+To/From
+Type
+CINGULAR MOBILE
+MIM Other
+OTHER MOBILE IO
+MIM Other
+MIM Other
+OTHER MOBILE 20
+MIM Other
+OTHER MOBILE TO
+MIM Other
+OTHER MOBILE TO
+MIM Other
+OTHER MOBILE TO
+MIM Other
+OTHER MOBILE TO
+MIM Other
+CINGULAR MOBILE
+MIM Other
+OTHER MOBILE TO
+OTHER MOBILE TO
+MIM Other
+CINGULAR MOBILE
+MIM Other
+MIM Other
+OTHER MOBILE TO
+OTHER MOBILE TO
+MIM Other
+MTM Other
+MIM Other
+OTHER MOBILE TO
+OTHER MOBILE TO
+MIM Other
+Code Pd
+1 Mag NPA2
+1 Mag NPA2
+In
+In
+1
+1
+1
+1
+1
+... . ..
+In
+Out
+In
+In
+In
+Total
+Chargi
+87
+88
+89
+90
+91
+92
+93
+94
+95
+96
+97
+Totals
+Sun
+Mon
+Tue
+Sat
+03/24
+03/24
+10: 42PM
+03/24
+10:43PM
+03/26
+03/26
+02: 49AM
+03: 26AM
+03/26
+11: 58AM
+03/26
+02:11PM
+03/27
+02:40PM
+03/28
+12: 38AM
+SubtotaletiMsgs
+03/10
+02: 48AM
+03/18
+09:49PM
+Subtotal ENsKBs
+OTHER MOBILE TO
+OTHER MOBILE IO
+MIM Other
+MIM Other
+OTHER MOBILE TO
+MIM Other
+OTHER MOBILE TO
+CINGULAR MOBILE
+OTHER MOBILE TO
+Jata Transf
+Data Transfe
+MyWirelessWind
+0.02
+0.02
+1 Mag NPA2
+1 Mag NPA2
+1 Mag NPA2
+1 Mag NPA2
+1 Mag NPA2
+1 Mag NPA2
+1 Mag NPA2
+1 Mag NPA2
+1 Mag NPA2
+1 KB
+1 KB
+NPA2 P
+NPA2 P
+Out
+Out
+In
+Out
+Out
+In
+In
+Out
+In
+Out
+In
+Out
+out
+Out
+0.
+- 00
+0.01
+
+
+illing Cycle Date
+ccount Numbe
+34 of 34
+03/01/06 - 03/28106
+Regulatory Cost Recovery Fee
+Beginning with your April bill, the Regulatory Cost Recovery Charge (RCRC) may change but
+will not exceed $1.25. The RCRC helps to defray costs incurred in complying with obligations
+id charges imposed by State and Federal telecom regulations, including Telecommunication
+elay Service Fund, Wireless number pooling and portability, E911 and the Federal Regulato
+ce. Costs may be incurred and charged prior to initiation of any of the respective servic
+› learn more, log on to http://www.cingular.com/rcrc or call 1-866-246-485
+Wireless AMBER Alerts
+Sign up to receive Wireless AMBER Alerts at www.cingular.com/amberalerts or by sending
+a text message with up to 5 zip codes to the short code AMBER (i.e. send SUBSCRIBE 12345
+to short code 26237). Customers capable of receiving text messages can receive these
+geographically specified alerts. There is no charge to sign up or to receive AMBER alerts.
+Normal airtime charges will apply if you place a call in response to an AMBER alert message.
+One Time Checking Account Payment Authorization Agreement (for use with kiosk payment):
+I authorize Cingular Wireless to pay my bill by debiting my bank account. I can cancel
+authorization by contacting an in-store sales person. If my bank rejects a payment.
+I may be charged a return fee. (
+Looking for a great job? Check out Cingular!
+Great pay, excellent benefits, flexible hours, full and part time possible
+/isit Cingular.com, click on Careers, and apply online. EOE AA/M/F/D/
+DST X280-9900 (10/03)
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/484bc547dd138ffb5888ea86033c29b8f51065f584be51256d229609e6c26c07.receipt.json b/vision-fixhub/ds9-unparsed-06/484bc547dd138ffb5888ea86033c29b8f51065f584be51256d229609e6c26c07.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..5cb1186615e8a2488f996511f74e204a227fd2dc
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/484bc547dd138ffb5888ea86033c29b8f51065f584be51256d229609e6c26c07.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -7063,
+  "dataset": "marble-joined",
+  "doc_id": "484bc547dd138ffb5888ea86033c29b8f51065f584be51256d229609e6c26c07",
+  "engine": "marble-apple-vision",
+  "event_count": 36,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "d4a14ff212c38c244a03f46bb6192b25ab1ebe61b7b1bd872873721b62586daa",
+  "output_sha256": "e00c34d7555643577dee17a0e700b1087aafbe770c58ed5c93720b37ac1ac2d5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4863094806bbb6d86777e64f2eb2c7d4493602bc3d2149cf5f3e21e3d019a84e.md b/vision-fixhub/ds9-unparsed-06/4863094806bbb6d86777e64f2eb2c7d4493602bc3d2149cf5f3e21e3d019a84e.md
new file mode 100644
index 0000000000000000000000000000000000000000..cf0ceaa01e99e174890db946a44abdd63ecc8827
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4863094806bbb6d86777e64f2eb2c7d4493602bc3d2149cf5f3e21e3d019a84e.md
@@ -0,0 +1,52 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov»
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80119-KAM Doe |. Epstein Sealed Document
+Date: Thu, 04 Mar 2010 22:44:37 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 3/4/2010 at 5:44 PM EST and filed on 3/4/2010
+Case Name:
+Case Number:
+Filer:
+Doe | Epstein
+9:08-cv-80119-KAM
+Document Number: 481(No document attached)
+Docket Text:
+Sealed Document (sa)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+ahorowitz@sexabuseattorney.com
+Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com
+Isidro Manuel Garcia
+isidrogarcia@bellsouth.net
+Jack Alan Goldberger
+jagesq@bellsouth.net, nalanis@agwpa.com
+Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com,
+sas@searcylaw.com, vat@searcylaw.com
+Jeffrey Mare Herman
+jherman@hermanlaw.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+Michael James Pike MPike@bclclaw.com, bobbie@bclelaw.com, jcadwell@bclelaw.com
+
+
+Paul G. Cassell cassellp@law.utah.edu
+Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com
+Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton@podhurst.com,
+mestrada@podhurst.com
+Robert Deweese Critton, Jr rcrit@bclclaw.com, bobbie@belclaw.com
+Stuart S. Mermelstein ssm@sexabuseattorney.com, jarbour@sexabuseattorney.com,
+Irivera @sexabuseattorney.com
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+Martin G. Weinberg
+20 Park Plaza
+Boston, MA 02116
diff --git a/vision-fixhub/ds9-unparsed-06/4863094806bbb6d86777e64f2eb2c7d4493602bc3d2149cf5f3e21e3d019a84e.receipt.json b/vision-fixhub/ds9-unparsed-06/4863094806bbb6d86777e64f2eb2c7d4493602bc3d2149cf5f3e21e3d019a84e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f6a839369c67798913928cd86fdcf72f4b0f1854
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4863094806bbb6d86777e64f2eb2c7d4493602bc3d2149cf5f3e21e3d019a84e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "4863094806bbb6d86777e64f2eb2c7d4493602bc3d2149cf5f3e21e3d019a84e",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "ce0485af649d5fc3ec97da395acce0a64e2cf4888628fbde62dea2c763b7bfee",
+  "output_sha256": "be0f1ee0525627815c2ea701e8347c537dfb7b529d8b3f3c00fa7d78152f73d3",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/487635fae12a971811d278d9294c5c36003c63eb1806aab80a10c0b558aff044.md b/vision-fixhub/ds9-unparsed-06/487635fae12a971811d278d9294c5c36003c63eb1806aab80a10c0b558aff044.md
new file mode 100644
index 0000000000000000000000000000000000000000..a85152dd4304f3cd9638a2c2de02a0c2d1f15169
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/487635fae12a971811d278d9294c5c36003c63eb1806aab80a10c0b558aff044.md
@@ -0,0 +1,150 @@
+Calls to Destination SB
+× cingular®
+08/17/2006
+From: 01/01/2006 12:00 AM
+To:
+08/01/2006 11:59 PM
+Number Called:
+MobileId
+Call Date
+Call Time
+HR: MN: SC
+Call Duration
+HR: MN: SC
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+*
+*
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000)000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(000) 000-0000
+(561) 792-6375
+(000) 000-0000
+07/21/2006
+07/21/2006
+07/21/2006
+07/23/2006
+07/23/2006
+07/23/2006
+07/24/2006
+07/24/2006
+07/25/2006
+07/27/2006
+07/27/2006
+07/28/2006
+07/28/2006
+07/28/2006
+07/29/2006
+07/29/2006
+07/29/2006
+07/29/2006
+08/01/2006
+09:14:58 AM
+09:15:31 AM
+10:15:26 AM
+01:57:47 PM
+04:23:17 PM
+04:53:19 PM
+09:45:06 AM
+11:51:25 AM
+10:04:26 AM
+10:48:43 AM
+04:39:05 PM
+09:50:46 AM
+09:59:43 AM
+05:09:16 PM
+12:23:27 PM
+12:26:51 PM
+01:32:03 PM
+02:59:45 PM
+11:18:17 AM
+00:00:04
+00:00:19
+00: 00:34
+00: 01:29
+00:00:43
+00:00:33
+00:00:04
+00:00:04
+00:00:27
+00:02:48
+00:00:17
+00:00:15
+00:02:03
+00:05:05
+00:00:10
+00:16:03
+00:00:44
+00:00:37
+00:01:36
+* - indicates the first time the calling number appears on the report
+All "Calls to Destination" and "subscriber Activity" reports are recorded In Local switch Time.
+This data provided may be in pre-bill format. Due to possible data losses it is not necessarily a complete record of all calls, and is not the
+oa a Corplete secord of a11 calls, and la not the
+same as an invoice received by a subscriber.
+JJ
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless and its Affiliates
+except under written agreement.
+Page
+1
+
+
+Calls to Destination SB
+08/17/2006
+Xcingular®
+MobileId
+Call Date
+Call Time
+HR : MN: SC
+Call Duration
+HR : MN: SC
+20
+21
+(000) 000-0000
+(000) 000-0000
+08/01/2006
+08/01/2006
+11:52:57 AM
+01:23:37 PM
+00: 00:06
+00: 00:39
+JJM
+* - indicates the first time the calling number appears on the report
+All "Calls to Destination" and "subscriber Activity" reports are recorded in Local Switch Time
+his data provided may be in pre-bill format. Due to possible data losses it 1s not necessarily a complete record of all calls, and 1s not thi
+same as an Invoice received by a subscriber.
+PROPRIETARY AND CONFIDENTIAL
+Not for use or disclosure outside Cingular Wireless and its Affiliates
+except under written agreement.
+Page 2
diff --git a/vision-fixhub/ds9-unparsed-06/487635fae12a971811d278d9294c5c36003c63eb1806aab80a10c0b558aff044.receipt.json b/vision-fixhub/ds9-unparsed-06/487635fae12a971811d278d9294c5c36003c63eb1806aab80a10c0b558aff044.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b2c81568930373dc1709998bf63e565b4b5d7302
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/487635fae12a971811d278d9294c5c36003c63eb1806aab80a10c0b558aff044.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "487635fae12a971811d278d9294c5c36003c63eb1806aab80a10c0b558aff044",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "58c7bf1c3af30364d91b0d9576c5af8f6e40b139eb098ab55dde9e3c47602790",
+  "output_sha256": "7cbd13903c829bca09ddbd13f1d5cc9677a74b2f76b5720ce63f0160a13562d6",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/488eb22b8f4aa976875c275bee01b7a0cf4b147bd0d7bcf8238a42029476d230.md b/vision-fixhub/ds9-unparsed-06/488eb22b8f4aa976875c275bee01b7a0cf4b147bd0d7bcf8238a42029476d230.md
new file mode 100644
index 0000000000000000000000000000000000000000..e14149a99c862109578153beff0f1974c66606be
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/488eb22b8f4aa976875c275bee01b7a0cf4b147bd0d7bcf8238a42029476d230.md
@@ -0,0 +1,10 @@
+Subject: RE: Congratulations on a Trial Victory!
+Date: Mon, 08 Mar 2010 19:43:26 +0000
+Importance: Normal
+Hi Barbara -- Where can I call you?
+- Original Message.....
+Subject: RE: Congratulations on a Trial Victory!
+Hey, I never heard back from you on a Jeffrey Epstein email I sent a couple of weeks ago. I need to update my boss on what position you
+have on Epstein early terminating his probation. We, of course, are objecting. Please let me know. Thanks!!!!
+
+
diff --git a/vision-fixhub/ds9-unparsed-06/488eb22b8f4aa976875c275bee01b7a0cf4b147bd0d7bcf8238a42029476d230.receipt.json b/vision-fixhub/ds9-unparsed-06/488eb22b8f4aa976875c275bee01b7a0cf4b147bd0d7bcf8238a42029476d230.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..fb20e7c021718c50fc7fa4cf484fc615b9d33284
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/488eb22b8f4aa976875c275bee01b7a0cf4b147bd0d7bcf8238a42029476d230.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "488eb22b8f4aa976875c275bee01b7a0cf4b147bd0d7bcf8238a42029476d230",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3a1d9dd9a4c8011c686d6b62d6de0dd4d716a136eaa86fc5d188cd70855a8e61",
+  "output_sha256": "4e50d440a4fb59f81c9dceafde5eb74be9ec5d726ce4196f857694421260c952",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/49413d67d710a1e18ec3a90a5bfca901658910873c72a8d6f03ebf569aec3d0e.md b/vision-fixhub/ds9-unparsed-06/49413d67d710a1e18ec3a90a5bfca901658910873c72a8d6f03ebf569aec3d0e.md
new file mode 100644
index 0000000000000000000000000000000000000000..5ab86e66843e037e84537c3f83d7bb8dd98027fc
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/49413d67d710a1e18ec3a90a5bfca901658910873c72a8d6f03ebf569aec3d0e.md
@@ -0,0 +1,1111 @@
+Questions or Changes?
+• attwireless.com
+Toll Free 1 866 293-4634
+611 from your wireless phone
+• TTY users - 1 866 4-AWS-TT
+SUMMARY OF MONTHLY CHARGES FOR ACCOUNT 0035224228
+Previous
+Payments
+Balance
+Received
+-35.35
+-66.07
+Account
+Adjustments
+0.00
+Balance
+Forward
+-101.42
+Your billing cycle ended on May 11, 2004
+Current Monthly Charges
+Subscriber Adjustments
+Monthly Service
+Monthly Usage
+Charges
+Credits
+Taxes, Surcharges & Regulatory Fees
+Total Current Monthly Charges DUE UPON RECEIPT
+TOTAL CREDIT AMOUNT
+CREDIT BALANCE - DO NOT PAY
+NO DOMESTIC US DATA ROAMING CHARGES:
+AS OF APRIL 18, WE HAVE ELIMINATED ALL DOMESTIC US DATA
+ROAMING CHARGES ON ANY MMODE, MOBILE INTERNET DATA PLAN
+OR BLACKBERRY ACCESS PLAN. THIS MEANS YOU CAN STAY
+CONNECTED ON ANY COMPATIBLE DATA CAPABLE DEVICE
+INCLUDING PHONES, PDAS, AND WIRELESS PC CARDS IN THE US
+WITHOUT A ROAMING CHARGE. NOTE: CANADA AND
+INTERNATIONAL ROAMING CHARGES STILL APPLY.
+AT&T WIRELESS APPRECIATES YOUR BUSINESS
+Please Retum This Portion With Your Payment.
+Use of service and payment of this invoice indicates agreement
+with the General Terms and Conditions for wireless service.
+→ AT&T Wireless
+Account Name:
+Date of Invoice: May 13, 2004
+Current Monthly
+Charges
+49.69
+Total
+Credit Amount
+-51.73
+0.00
+0.00
+16.47
+21.13
+0.00
+12.09
+49.69
+-51.73
+Note: =>
+We Print on
+Front and Back
+Service # 5613080282
+Account # 0035224228
+(see reverse - signature required).
+THIS IS NOT AN INVOICE
+- DO NOT PAY
+#BWNHNGB
+#0000000352242283# w
+.5.01.02.0011.0000
+AT&T WIRELESS
+PO BOX 8229
+AURORA IL 60572-8229
+00000000••••••0000003522422830000000051735
+
+
+*29700301C 0*
+REFT (Recurring Electronic Fund Transfer): To enroll: sign below, check the REFT box on the reverse side and
+remit with this month's payment. Keep paying your bill until your statement indicates "Do Not Pay."
+REFT Agreement: 1 authorize my financial institution to deduct the amount of my monthly wireless phone bill from
+the account associated with the enclosed check and remit payment to AT&T Wireless. This authority will be
+effective until | notify AT&T Wireless to terminate it. I agree that I may be assessed a service charge (up to $20) or
+late fee or both if a payment is returned by my bank. For more information visit attwireless.com or call 1 866
+293-4634.
+Questions? We can help: AT&T Wireless appreciates your business and welcomes the opportunity to assist you.
+As part of our commitment to you, we are always adding new calling plans and promotions to match your individual
+needs. Visit our website at attwireless.com or contact our Customer Care at 1 866 293-4634 or dial 611 from your
+wireless phone. ¿Sabias que también ofrecemos servicio al cliente en tu idioma? Marca 611 desde tu teléfono
+inalámbrico, o 1 866 293-4634 desde cualquier teléfono y oprime el *.
+Driving Wireless Safety: Your wireless phone gives you the freedom and flexibility to stay in touch when you
+travel, but don't let a phone call distract you from driving safely. Use hands-free device if allowed or required by
+law. Call Carefully, Arrive Safely.
+AT&T Wireless Processing Fees: Accounts suspended for non-payment will be subject to a $25 reactivation fee
+per line and may be assessed a security deposit prior to reinstatement. Checks returned for non-sufficient funds will
+be charged up to a $20 fee.
+Local Tax: Local taxes are based on local government boundaries, the address information you provide for your
+account and/or your wireless telephone number. Please review the local tax charges on your bill. If you believe
+there is an error in the local tax charge, please contact us immediately at 1 866 293-4634. Please note that some
+ocal or state laws may require you to follow special procedures when notifying us about a local tax dispute. You
+nay also use the form below to notify us of any change to your taxing address. Thank you for your cooperatior
+Please Send Correspondence To:
+AT&T Wireless Next Generation Correspondence
+P.O. Box 68056
+Anaheim Hills, CA 92817-8056
+0.000032970.3
+Change of Address Only. Please print address clearly and check the box on the reverse side. Please contact Customer Care to change the
+Name and transfer Financial Responsibility.
+New Billing Address
+City
+State
+Zip
+Home Phone (
+Work Phone (.
+If your billing address is NOT your Tax Address*, please enter the Tax Address below. (Multi-line accounts should attach a list of each wireless number and
+the respective Tax Address.)
+New Tax Address*
+Wireless Number (
+City
+State
+Zip
+Under Federal laws, your Tax Address must be: your primary place of use, your residential or business address, and located within AT&T Wireless
+censed service area. Non-business customers on AT&T Digital One Rate, Regional Advantage or Shared Advantage plans must use their residenti
+address as their tax address.
+Recurring Electronic Fund Transfer (REFT) Enrollment. Please read the agreement on the top portion of this page, sign below and check the
+"REFT Registration" box on the reverse side.
+6.1 - 3G
+Financial Account Holder Signature
+• I do not wish to receive email notilication of special ollers avalable to AT&T Wireless customers.
+
+
+
+IMPORTANT ACCOUNT INFORMATION:
+IF YOU CANCEL SERVICE BEFORE YOUR CONTRACT END DATE
+(INCLUDING IF YOU SWITCH YOUR WIRELESS NUMBER TO
+ANOTHER CARRIER), YOU WILL BE CHARGED AN EARLY
+TERMINATION FEE OF UP TO $200.
+ACCOUNT DETAILS
+Detail of Payments - Thank You!
+Item Description
+1 PAYMENT
+Date Applied/Reversed Payment Amount
+05/05/04
+-66.07
+Total of Payments
+Detail of Other Account Charges
+Item Description
+1 30 DAY BALANCE EXPIRATION
+Total of Other Account Charges
+Detail of Account Taxes, Surcharges and Regulatory Fees
+Item Description
+1 UNIVERSAL CONNECTIVITY CHARGE
+2 FEDERAL TAX
+3 COUNTY 911 TAX
+4 LOCAL COMM SERVICE TAX
+5 STATE COMM SERVICE TAX
+Total Account Taxes, Surcharges and Regulatory Fees
+Current Subscriber Monthly Charges and Credits
+Subscriber Number
+Subscriber Name
+
+Total Current Subscriber Monthly Charges and Credits
+Total Current Monthly Charges
+SUMMARY OF CURRENT ACTIVITY
+Monthly Service Charges
+Item Description
+1 CALL WAITING
+2 CALLER ID
+3 GO PHONE $53,98 REPLENISHMENT
+4 THREE WAY CALLING
+Service Dates
+04/12/04 - 05/11/04
+04/12/04 - 05/11/04
+14/12/04 - 05/11/0.
+14/12/04 - 05/11/0.
+-66.07
+-66.07
+21.13
+21.13
+1.34
+1.68
+0.50
+3.50
+5.07
+12.09
+16.47
+16.47
+49.69
+0.00
+0.00
+0.00
+0.00
+
+SUMMARY OF CURRENT ACTIVITY - CONTINUED
+Monthly Service Charges - Continued
+Item Description
+5 GO PHONE UNLIMITED NIGHTS AND WEEKENDS
+6 DETAIL BILLING
+Total Monthly Service Charges
+Service Dates
+04/12/04 - 05/11/04
+4/12/04 - 05/11/04
+Monthly Usage Charges
+Item Description
+1 AIRTIME MINUTES
+2 UNLIMITED N/WKND MIN
+3 MESSAGE RETRIEVAL
+4 CALL WAITING
+5 411 INFO
+6 TEXT MESSAGES SENT
+7 DROP CALL CREDIT
+Total Monthly Usage Charges
+Onty Used
+168 MIN
+550 MIN
+10 EVT
+6 EVT
+1 EVT
+1 EVT
+2 MIN
+TOTAL CHARGES FOR (561)308-0282
+DETAIL OF CURRENT ACTIVITY
+VOICE USAGE FOR (561)308-0282
+Item Date Time
+Called
+1 04/12 03:04P (561)793-9291
+2 04/12 03:26P (561|252-4753
+: 04/12 04:07
+| 04/12 05:32
+5 04/12 09:50P (561)798-3650
+044209 561) 798-3650
+8 04/12 10:46P
+10 04/13 04:09A
+Calls To
+NPALMBEACH FL
+WPALMBEACH FI
+COMIN
+COMIN
+NPALMBEACH F.
+WPALMBEACH F
+INCOMING
+INCOMING
+INCOMING
+NCOMING
+12 04113 09:02 (861,308-8282
+13 04/13 09:05A (561)308-0282
+14 04/13 09:08A (561)308-0282
+15 04/13 09:09A (561)308-0282
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+19 0413 11:224 (881333-0180
+18 04/13 08 23P (561)313-2432
+20 04/13 06:08P (561)333-0180
+PALMBEACH
+PALMBEACH
+LAKE WORTH FL
+WPALMBEACH FL
+Qnty
+Used
+Rate Description
+2MIN
+0.09 AIRTIME MINUTES
+1 MIN
+0.09 AIRTIME MINUTES
+WPALMBEACH FL
+UNLIMITED N/WKND MIN
+1 MIN
+4MIN
+INLIMI
+/WKND MIN
+2MIN
+UNLIMITED N/WKND MIN
+1 MIN
+1 MIN
+LIMITED NAWKNO N
+LIMITED NWKND M
+1 MIN
+3MIN
+O.09 ANTIME MINUTEND MIN
+1 EVT
+MESSAGE RETRIEVAL
+TE 0.09 AIRTIME MINUTES
+MESSAGE RETRIEVAL
+1 MIN 0.09 AIRTIME MINUTES
+1 EVT
+1 EVT
+MESSAGE RETRIEVAL
+EMIN 0:09 AIRTIME MINUTES
+I MIN 0.09 AIRTIME MINUTES
+1 MIN 0.09 AIRTIME MINUTES
+MIN 0.09 AIRTIME MINUTES
+1 MIN
+0.09 AIRTIME MINUTES
+24
+INCOMING
+29 MIN
+UNLIMITED N/WKND MIN
+2 MIN
+27 MIN
+UNLIMITED NIWKND MIN
+1 MIN 0.09 AIRTIME MINUTES
+0.00
+0000
+15.12
+0.00
+0.00
+1.25
+0.10
+16.17
+16.47
+0.18
+0.18
+0.27
+8.09
+009
+D.000032971
+
+
+L262600000
+
+Item Date Time
+Called
+Calls To
+: 04/14 83:04P (561)313-6730
+33 04/14 03:38P
+34
+
+04/14 09:11P
+84/15 08:03P 1561/255-9697
+39
+04/15
+40
+04/15 07:45P
+41
+04/
+04/15 09:34P
+42 04/16 11:32A
+43
+44
+84/18 1133A
+04/16
+16 04/18 1313P (561)333-0180
+47 04/16 01:11P (561)793-9291
+INCOMING
+COMIN
+COMIN
+INCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+NCOMING
+INCOMING
+INCOMING
+NCOMING
+NCOMING
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+18 04/16 01:13P
+49 04/16 81:20Р (561)993-3791
+50 04/16 01:26P
+04/16
+01
+04/16
+:40P
+(561)793-3615
+03:00P
+04/16 03:05P
+INCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+04/16
+04/16
+3:31|
+3.567
+04.
+/16
+04:40P
+04/16
+04:44P
+(561)723-9357
+04/16 05:42P
+04/16 06:00P
+04/16
+08:20P
+04/16 08:25P
+04/16 08:45P
+04/16 08:54P 581|723-9337
+64
+04/16 10:14P
+04/16 11:51P
+12:53A (561)255-9697
+04/17 01:35A
+B4117 83:03A (861/602-8566
+04/13
+04/1Z 03:05A (561)313-6730
+04/17 03:25A
+04/17 03:26A
+04/17 05:35A (561)308-0282
+74 04/17 05:36A (561)308-0282
+75 04/17 06:20A
+76 04/17 03:32P
+(561)308-0282
+04/17 03:34P
+561)313-6730
+04/17
+03:36P
+561)313-6730
+04/17
+03:39₽
+561|793-7719
+04/17 03:45P
+(917)B55-3363
+28090
+04/17 03:46P
+(561)793-7719
+03:47P
+5611313-6730
+04/17 03:48P
+5611798-8887
+04/17 03:52P
+(561|602-9566
+04/17
+86
+04:05P
+04/17 04:58P
+04/17 06:26P
+04/17
+06 51P
+NCOMING
+VPALMBEACH FI
+INCOMING
+NCOMING
+NCOMING
+INCOMING
+PALMBEACH I
+INCOMING
+COMIN
+PALMBEACH I
+INCOMING
+LAKE WORTH FL
+LAKE WORTH FL
+INCOMING
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+LAKE WORTH FL
+LAKE WORTH FI
+WPALMBEACH FI
+NEW YORK NY
+VPALMBEACH F
+AKE WORT
+WPALMBEACH FL
+LAKE WORTH FL
+INCOMING
+INCOMING
+COMIN
+ICOMIN
+2MIN
+1 EVT
+3MIN
+SMIN
+1 MIN
+6MIN
+1 MIN
+89 04/17 06:52P
+99 84/18 02:08А (561)255-9697
+INCOMING
+PALACHEL
+4MIN
+9MIN
+RMIN
+1 MIN
+26MIN
+1 MIN
+1 EVT
+8 MIN
+IEVT
+2 MIN
+2 мг
+*29710302C 0*
+Onty
+Used
+Rate Description
+EMIN 0.09 AIRTIME MINUTES
+1 MIN
+0.09 AIRTIME MINUTES
+2 MIN 009 AIRTIME MINUTES
+21 MIN
+UNLIMITED N/WKND MIN
+11 MIN
+UNLIMITED N/WKND MIN
+MIN 0.09 AIRTIME MINUTES
+12 MIN
+0.09 AIRTIME MINUTES
+1 MIN
+0.09 AIRTIME MINUTES
+SMIN
+UNLIMITED N/WKND MIN
+1 MIN 0.09 AIRTIME MINUTES
+MIl
+3.09 AIRTIME MINUTE.
+MIR
+09 AIRTIME MINUTE
+EMIN
+0.09 AIRTIME MINUTES
+2 MIN
+0.
+1 MIN
+2 MIN
+gg
+2 MIN
+1 MIN
+0.0
+1 MIN
+1 MIN
+1 MIN
+1 MAIN
+2 MIN
+1 MIN
+1 MIN
+0:09 AIRTI
+0.09 AIRTI
+0.
+3 MIN
+2MIN
+2MIN
+09
+2MIN
+1MIN
+2MIN
+2 MIN
+UNL
+EMIN
+MIl
+MAI
+2MIN
+UNLIMIT
+UNISMATEL
+UNLI
+UNLI
+CALL
+UNLIM
+CALL
+NLIM
+ALIM
+NOWAD MIN
+8.09
+0.18
+1.08
+0:29
+0.18
+00
+
+
+Onty
+Item Date Time Called
+Calls To
+Used Rate Description
+83 04/1809:734 561)813-6730
+LAKE WORTHEL
+UNEMITE WIND MIN
+94 04/18 09:45A
+INCOMING
+1 MIN
+UNLIMITED N/WKND MIN
+36 04/18 10:09A 561)653-762
+6 04/18 10:09A
+NLIMITEB NAWKND MI
+KND MI
+97 04/18 10:23A (561)723-7752
+WPALMBEACH FL
+04/18 10:53A 1561723:79
+2MIN
+UNLIMITED N/WKND MIN
+04/18 10 598
+EMIN
+LIMITED NWND M
+LIMITED N/WKND M
+100 04/18 11:26A (561)723-7752
+WPALMBEACH FL
+1 MIN
+UNLIMITED N/WKND MIN
+101 04/18 11:38A (305)555-1212
+INLIMITED N/WKND MIl
+102 04/18 11:38A
+INCOMING
+1 MIN
+UNLIMITED N/WKND MIN
+ILL WAITIN
+103 04/18 12:07P (561)723-7752
+WPALMBEACH FL
+ILIMITED N/WKND M
+105 04/18 12:39P 561 723-9933
+05 04/18 12:39P
+106 04/18 12:44P (561)723-9357
+2MIN
+1.25
+
+
+(561)252-4753
+8888
+(561)255-9697
+(561)541-5577
+(561)333-0180
+(561 333-0180
+1333
+(561)346-1086
+(S81) 883-0225
+(561|313-6730
+(561)723-7752
+1851853-2730
+--
+000
+
+
+
+
+Called
+Item Date Time
+155 04/22 81:23P
+(561)255-9697
+157 04/22 01:26P
+(561)856-2974
+158 04/22 01:32P
+159
+04/23 06:11A (561)793-9291
+160 04/23 04:26P
+161
+04/23 05:40P
+04/
+10:08P (561)255-9697
+04/23
+041
+10:09P
+10:18P (561)723-9357
+165
+04
+08
+10:25P
+166
+04/23 10:45P
+167
+68
+01/21
+| 10:51P
+03A
+561333-0181
+561|255-9697
+04/24 03:28A
+160 04/24 03:33A
+(561)723-9357
+171 04/24 03:39A (561)723-9357
+172 04/24 03:504
+(561)644-4580
+73 04/24 11:104
+174 04/24 11:37A (561)313-6730
+04/
+24
+12:18P
+(917)855-3363
+28
+188
+88
+1260P
+(56 1)887:
+-6732
+182
+04.
+124
+12:52P
+88
+2:54H
+(561)255-9697
+185
+04/
+124
+OOF
+01:01P
+185
+81:13P
+(561)687-2122
+188
+04/
+24
+28
+03.26P
+04:22P
+(561)798-3650
+04:37P
+191
+04/
+124
+04:38P
+192 04/24 04:40P
+193 04/24 04:42P (561)644-8153
+04/24 04:43P
+
+10:01F
+0:02
+10:03P
+-
+10
+988
+561) 793-7719
+5611255-9697
+(561 723-9357
+798-
+(561,798
+-3650
+798.
+-3650
+4 10:16F
+:D4P
+10:37P
+(561)723-7752
+10:59P
+(561)313-6730
+11:35P
+(561 723-9357
+(561)313-6730
+12:13A
+2:33A
+02:37A (561)313-6730
+02:25P
+:28P
+
+:41P
+(561)255-9697
+Calls To
+NCOMING
+NPALMBEACH FL
+PALM BEACH FL
+NCOMING
+NPALMBEACH FL
+INCOMING
+NGOMING
+NPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+WHALESHEL
+WPALMBEACH FL
+INCOMING
+LAKE WORTH FL
+INCOMING
+INCOMIN
+NEW YORK NY
+COMIN
+COMIN
+ORTH FL
+INCOMING
+WPALMBEACH FI
+NCOMIN
+INCOMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FI
+MOOMING
+INCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+WPALMB
+INCOMING
+NOOMING
+WPALMBEACH FL
+INCOMING
+LAKE WORTH FL
+WPALMBEACH FL
+LAKE WORTH FL
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+LAKE WORTH FL
+INCOMING
+MPAI MREACH FIl
+INCOMING
+INCOMING
+INCOMING
+NCOMING
+INCOMIN
+IG
+Qnty
+Used
+Rate Description
+MIl
+I MIN
+8.09 AIRTIME MINUTES
+1 MIN
+0.09 AIRTIME MINUTES
+1 MIN
+09 AIRTIME MINUTE
+2 MIN
+09 AIRTIME MINUTE
+1 MIN
+0.09 AIRTIME MINUTES
+2 MIN
+0.09 AIRTIME MINUTES
+1 MIN
+UNLIMITED N/WKND MIN
+1 MIN
+UNLIMITED N/WKND MIN
+1 MIN
+JNLIMITED
+N/WKND
+MIN
+1 MIN
+JNLIMITED N/WKND MIN
+1 MIN
+UNLIMITED N/WKND MIN
+1 MIN
+NIMITED N/WKN
+2 MIN
+VLIMITE
+N/WKND
+1 MIN
+INLIMITE!
+N/WKND
+2 MIN
+INLIMITED N/WKNI
+1 MIN
+UNLIMITED N/WKND
+1 MIN
+MIN
+2MIN
+MIN
+2MIN
+MIN
+LO
+MIN
+MIN
+OMIN
+5MIN
+33
+EVT
+MIN
+SMIN
+2 MIN
+1 MIN
+3MIN
+MIN
+MIN
+N
+N-
+MIN
+2MIN
+3MIN
+1 MIN
+2 MIN
+7 MIN
+2MIN
+2MIN
+2 MIN
+6MIN
+MIN
+333
+
+8.26
+0.18
+0.18
+Called
+Calls To
+Onty
+Used
+Rate Description
+Item Date Time
+220 04/25 1021P
+221 05/05 04:49P
+222 05/06 11:20A (561)333-0180
+223 05/06 05:02P
+224 05/06 06:16P
+226 05108 09:08P
+227 05/06 09:45P (561)255-9697
+228 05/07 09:07P
+(561)255-9697
+229
+05/07 09:08P 75611308-0282
+MIN
+INCOMING
+PALMBEACH I
+COMIN
+INCOMING
+COMIN
+COMIN
+WPALMBEACH FL
+PALMBEACH E
+/PALMBEACH
+2 MIN
+09
+AIRTIME
+3 MIN
+IMIN
+0.091
+AIRTIME
+3MIN
+2 MIN
+AIRTIME
+3MIN
+1 MIN
+UNLIMITE
+1 MIN
+NLIMITE
+2 MIN
+NLIMITE
+1 EVT
+230 05/07 09:11P (561)308-0282
+WPALMBEACH FL
+1 MIN
+MESSAG
+1EV
+UNLIMITE
+MESSA
+231 05/07 09:12P (561)308-0282
+WPALMBEACH FL
+1 MIN
+1EVT
+232 05/07 09:18P
+1 MIN
+88888
+$9088
+-9697
+UNLIMITE
+
+66
+ND
+MIN
+MI
+Mil
+VAL
+JD MIN
+VAL
+ND MIN
+VAL
+MIN
+0.18
+0.27
+0.27
+
+$89÷3892g6
+1992-
+9519
+9697
+INCON
+TH
+ACH
+9697
+5611793-7719
+(561)723-7752
+(561)644-8153
+(561)723-7752
+
+00888808888808888888888888888888-88888888888288881
+H10100210000102000
+
+D.000032972
+
+
+Onty
+Item Date Time
+Called
+Calls To
+Used
+Rate Description
+280 0508 00164
+05/09 01:14A
+NCOMING
+(561)255-9697
+282 05/09 01:35A
+561|255-9697
+MPALMBEACH FL
+MIN
+WPALMBEACH FL
+1 MIN
+283
+UNLIMITED N/WKND MIN
+284฿
+05 09 81 36A (551/253-9697
+NPALMBEACH Fl
+MPALMBEACH FI
+285 05/09 02:08A
+INCOMING
+1 MIN
+1 MIN
+IT WEND MIN
+286
+287
+8509 02:09A 1381|233-9697
+1 MIN
+05/09 02:09A
+IMIN
+UNINTER NANN
+289
+05/09 02:09A
+61255-9697
+05/09 02 10A
+611255-9697
+WPALMBEACH FL
+WPALMBEACH FI
+KND N
+290 05/09 02:20A (561]255-9697
+WPALMBEACH FL
+1 MIN
+282
+05/09 02-28A
+NOOMING
+05/09 03:18A (561)255-9697
+MPALMBEACH FI
+293
+05/09 03:50A
+INCOMING
+1 MIN
+UNLIMITED N/WKND MIN
+05/09 03:58A
+INCOMING
+05/09 04:31A
+NCOMING
+295
+297
+05/09 07:20A
+INCOMING
+05/09 10:47P
+NCOMING
+298
+290
+B588B
+05/10 03:14A
+NOOMING
+85/18 83:07P (561)687-2122
+WPALMBEACH FL
+NCOMING
+05/10 06:37P
+INCOMING
+0511
+10 06:40P
+06:40P
+304
+05/1
+INCOMING
+JING
+10 09:23P
+INCOMING
+85/18
+9411
+05/10 11:45P
+INCOMING
+05119:330
+310
+05
+(561)255-9697
+/11 11:47A
+(561)255-9697
+WPALMBEACH FL
+312
+11 0437P
+314 85/11 0431P 1561/687:3122
+315 05/11 04:57P
+WALNEACHL
+INCOMING
+319 85/11 10:14P (561)255-9697
+318 05/11 10:24P
+328 0511 19:20P (561/602-9566
+INCOMING
+AKE WORTH F
+COMIN
+1 MIN
+UNLIMITED N/WKND MIN
+3 MIN
+2 MIN
+UNET AWN MING
+2MIN 0:08 AIRTIME MINUTES
+1 MIN
+0.09 AIRTIME MINUTES
+1 MIN
+9MIN
+8.08 AIRTIME MINUTES
+UNLIMITED N/WKND MIN
+UNLINE NAMIN
+1 MIN
+UNLIMITED N/WKND MIN
+O.O9 ANTIME MINUTES MIN
+2MIN
+0.09 AIRTIME MINUTES
+3MIN 0.09 AIRTIME MINUTES
+I MIN 0.09 AIRTIME MINUTES
+1 MIN 0.09 AIRTIME MINUTES
+1 MIN
+UNTED AND MIN
+3MIN
+UNLIMITED N/WKND MIN
+8 MIN
+EMIN
+TOTAL VOICE USAGE FOR (561)308-0282
+TEXT/MULTIMEDIA MSGS FOR (561)308-0282
+Item Date
+1 04/21
+Time
+Sent To/Revd From Charge Description
+09:09A 561)876-2208
+TEXT MESSAGES SENT
+TOTAL TEXT/MULTIMEDIA MSG USAGE FOR (561)308-0282
+0.000032972
+*29720303C 0=
+
+*** THIS SPACE INTENTIONALLY LEFT BLANK ***
+16.37
+0.10
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/49413d67d710a1e18ec3a90a5bfca901658910873c72a8d6f03ebf569aec3d0e.receipt.json b/vision-fixhub/ds9-unparsed-06/49413d67d710a1e18ec3a90a5bfca901658910873c72a8d6f03ebf569aec3d0e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..69c2b9788fb89c2f18224d65f3382c9375a9b08f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/49413d67d710a1e18ec3a90a5bfca901658910873c72a8d6f03ebf569aec3d0e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1336,
+  "dataset": "marble-joined",
+  "doc_id": "49413d67d710a1e18ec3a90a5bfca901658910873c72a8d6f03ebf569aec3d0e",
+  "engine": "marble-apple-vision",
+  "event_count": 26,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "a591585aa95df0a4a45f754e79422b4faa680d04f1bee3379fc5b2fd437bf3c1",
+  "output_sha256": "0601fe065cb3abd50e7d44f0cb989987ec903a7d640fe2188ddc130a6365c7a7",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/494381d73c534c8a6b5455085b431183e68b129a745d50720bc9eb761804b3d8.md b/vision-fixhub/ds9-unparsed-06/494381d73c534c8a6b5455085b431183e68b129a745d50720bc9eb761804b3d8.md
new file mode 100644
index 0000000000000000000000000000000000000000..728b6e5c48f64b0ee51b3979e7f28fccb35a1d58
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/494381d73c534c8a6b5455085b431183e68b129a745d50720bc9eb761804b3d8.md
@@ -0,0 +1,34 @@
+From:
+To: Paul Cassell
+Cc:
+Subject: Government Position
+Date: Fri, 03 Feb 2012 16:10:25 +0000
+Importance: Normal
+Brad Edwards
+Paul and Brad,
+I am responding to your e-mail on February 1, 2012 regarding our filing the entire reply under seal. We respectfully
+disagree that such a filing was inappropriate, a violation of DOJ policy, and/or a violation of First Amendment principles.
+Our filing the entire reply under seal is based upon the November 7, 2011 Order from Judge Middlebrooks, permitting
+the government to make limited disclosure of Grand Jury matter. Judge Middlebrooks permitted disclosure under thre
+conditions, including that "the disclosure of the aforementioned grand jury information shall be limited to filings made
+under seal in Case No. 08-80736-CIV-MARRA."
+We understand your desire to share the government's filing with your colleagues in the victims' rights community.
+However, the November 7, 2011 Order also limits service of filings to counsel for petitioners
+Distributing these government's filings, which were filed under seal, would not be permitted under the November
+7, 2011 order.
+While we appreciate all the courtesies both of you have extended to us over the course of this litigation, and particularly
+over the last two months, we would oppose a motion that the government file a redacted pleading in the open court
+file. I think we have a fundamental disagreement over the what constitutes protected Grand Jury material, and how
+readily such protected material can be segregated from non-protected information.
+As far as the information at page 32 n.20, of the government's reply, the government would need to obtain additional
+authorization from the Court under Fed.R.Cr.P. 6(e) to disclose the information supporting jurisdiction and venue in the
+Southern District of New York and the District of New Jersey. When you refer to "unsealing of all information," if you
+mean that such information would be publicly disclosed, we would oppose such a motion. If authorization were obtained
+under Rule 6(e) for additional disclosures as to venue in those two jurisdictions, we would expect that such material
+would only be disclosed under the same conditions in the November 7, 2011 Order.
+As far as your proposed motion for the court to deny the motion to dismiss without requiring additional pleadings from
+the victims, we don't see how such a motion is necessary. Since the motion is now fully briefed, the court can grant or
+deny the motion to dismiss without requiring additional pleadings from any party, unless the court believes it needs more
+briefing. Normally, sur-replies are not permitted unless the reply has gone beyond responding to the issues raised in
+the response. We don't believe our reply brought forward new issues not raised in our motion to dismiss.
+I'll be here all day. Thanks.
diff --git a/vision-fixhub/ds9-unparsed-06/494381d73c534c8a6b5455085b431183e68b129a745d50720bc9eb761804b3d8.receipt.json b/vision-fixhub/ds9-unparsed-06/494381d73c534c8a6b5455085b431183e68b129a745d50720bc9eb761804b3d8.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6bcac20b6c487e52eee42a4601e24fb74665ba00
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/494381d73c534c8a6b5455085b431183e68b129a745d50720bc9eb761804b3d8.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "494381d73c534c8a6b5455085b431183e68b129a745d50720bc9eb761804b3d8",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "953304dc1079a6581a175111f26b066394ded3be358bf6442932267946a2fdfc",
+  "output_sha256": "4d0b71f586cfb868989ea91ce1ee14ad619e34c4982a643749a24537117a9dca",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/49992ab7c1e6091db0842eb5176a47c9483743931a3dbded750a8796bbb21a46.md b/vision-fixhub/ds9-unparsed-06/49992ab7c1e6091db0842eb5176a47c9483743931a3dbded750a8796bbb21a46.md
new file mode 100644
index 0000000000000000000000000000000000000000..d6fff7877a2150122b9e166ad482393b35d01e2c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/49992ab7c1e6091db0842eb5176a47c9483743931a3dbded750a8796bbb21a46.md
@@ -0,0 +1,73 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov»
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80893-KAM Doe |. Epstein Response in Opposition to Motion
+Date: Mon, 05 Jul 2010 19:16:58 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Pike, Michael on 7/5/2010 at 3:16 PM EDT and filed on 7/5/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 200
+Doe | Epstein
+9:08-cv-80893-KAM
+Jeffrey Epstein
+Docket Text:
+RESPONSE in Opposition re [190] Plaintiff's MOTION for ContemptPlaintiff's MOTION for
+Sanctions and Defendant's Motion for Sanctions and Incorporated Memorandum of Law filed
+by Jeffrey Epstein. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D)
+(Pike, Michael)
+Bradley James Edwards
+brad@pathtojustice.com. beth@pathtojustice.com
+Jack Alan Goldberger
+jagesq@bellsouth.net, nalanis@agwpa.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+Michael James Pike
+MPike@bclclaw.com, bobbie@bclclaw.com, jcadwell@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Robert Deweese Critton, Jr rcrit@bclclaw.com, bobbie@bclclaw.com
+9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+
+
+The following document(s) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=7/5/2010] [FileNumber=7754608-0]
+[69cb126d79493d1cb078e29а90а99eЗfc4f195f7bb768401306d06f2ac795a4a408e
+86aa84b376d2722601c0e83b58c07eb214b22026d538fad0d8f50f648f62]]
+Document description:Exhibit A
+Original filename:n/a
+Electronic document Stamp:
+[STAMP dcecfStamp_ID=1105629215 [Date=7/5/2010] [FileNumber=7754608-1]
+[8285ccd03254e5a189efcd75416c31c9322041 faaff1 db49b54215fd67710f192e79
+23eb0d985384399cb49082db2f2d32ad6eafb35114a5c4faf38422b000dc]]
+Document description:Exhibit B
+Original filename:n/a
+Electronie document Stamp:
+STAMP deeciStamp_ID=1105629215 |Date=7/5/2010] [FileNumber=7754608-2
+220ec657516b17b3215ed2b03fb1f791b466c886882ddf8c3fe2c6bbeb459d94196
+eaaa39852798135e55f7afac3fb648678931e495acc876cc9b4b98e9c65b]]
+Document description: Exhibit C
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=7/5/2010] [FileNumber=7754608-3]
+[3c7330a1d4d848d0f8b2fa17fe1a947c4e61e96f4c7435e35ееc9f10e4c248f55de8
+404dbfda7a525e765a7bad0636d32357ff6333df96be0273055059e3c81d]]
+Document description: Exhibit D
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=7/5/2010] [FileNumber=7754608-4]
+[650b9a980388ee5437ee005dfec410425cf7a0e4b59a25b5b0dd67a67882251b05e1
+13320c3ca123e8cbe6bc000727c9fa5195a32f27f7bd324a48cbf6e14c62]]
diff --git a/vision-fixhub/ds9-unparsed-06/49992ab7c1e6091db0842eb5176a47c9483743931a3dbded750a8796bbb21a46.receipt.json b/vision-fixhub/ds9-unparsed-06/49992ab7c1e6091db0842eb5176a47c9483743931a3dbded750a8796bbb21a46.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c278d79043209390e88f110eccde00faffb589b8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/49992ab7c1e6091db0842eb5176a47c9483743931a3dbded750a8796bbb21a46.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "49992ab7c1e6091db0842eb5176a47c9483743931a3dbded750a8796bbb21a46",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "8611a7e01b1d105ce2600a57dd7b8753080b8a6a20ffe3a6bf525f676e95fa83",
+  "output_sha256": "5c11bd1da958854f10d22776b45f570a8bca1d4ec0ccc3456b05ae372a3ce84a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/499ed74bbe83b0122c58572a6ce600b5294b250262d6af097739dabd7ff8c2fa.md b/vision-fixhub/ds9-unparsed-06/499ed74bbe83b0122c58572a6ce600b5294b250262d6af097739dabd7ff8c2fa.md
new file mode 100644
index 0000000000000000000000000000000000000000..a79cad7c76a136388c9e6bad8264a51f44db1cce
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/499ed74bbe83b0122c58572a6ce600b5294b250262d6af097739dabd7ff8c2fa.md
@@ -0,0 +1,47 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov»
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80893-KAM Doe |. Epstein Response in Opposition to Motion
+Date: Tue, 06 Jul 2010 15:13:09 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Pike, Michael on 7/6/2010 at 11:13 AM EDT and filed on 7/6/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 201
+Doe | Epstein
+9:08-cv-80893-KAM
+Jeffrey Epstein
+Docket Text:
+RESPONSE in Opposition re [175] Plaintiff's MOTION for Writ of Habeas Corpus ad
+testificandum Alfredo Rodriguez filed by Jeffrey Epstein. (Pike, Michael)
+9:08-cv-80893-KAM Notice has been electronically mailed to:
+Ann Marie C. Villafana
+ann.marie.c.villafana@usdoj.gov, fran.prager@usdoj.gov
+Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com
+Jack Alan Goldberger jagesq@bellsouth.net, nalanis@agwpa.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+Michael James Pike MPike@bclclaw.com, bobbie@bclclaw.com, jcadwell@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Robert Deweese Critton, Jr rcrit@bclclaw.com, bobbie@bclclaw.com
+9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+The following documents) are associated with this transaction:
+
+
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=7/6/2010] [FileNumber=7755889-0]
+[2808da3e57c4145900b157c4bd7924eb6d01ce00f61ccf622ecf873ca262a70bebe9
+65e43130edaf7alef2fa61b58ffeaf197b64b9acbeead3f063b7d7bb34bd]]
diff --git a/vision-fixhub/ds9-unparsed-06/499ed74bbe83b0122c58572a6ce600b5294b250262d6af097739dabd7ff8c2fa.receipt.json b/vision-fixhub/ds9-unparsed-06/499ed74bbe83b0122c58572a6ce600b5294b250262d6af097739dabd7ff8c2fa.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..5f52c5d0b4e1b649b516a18a8508c7960bd4dbd4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/499ed74bbe83b0122c58572a6ce600b5294b250262d6af097739dabd7ff8c2fa.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "499ed74bbe83b0122c58572a6ce600b5294b250262d6af097739dabd7ff8c2fa",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "f16770f22551a4083b83976ae5af2c00d3ebc548300fe24468fcad146e87fe04",
+  "output_sha256": "8a792c6de086beb732f6c3a4a475c445f687033e03e3f4556617e15a0e074ce0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/49ead23c90502ad7f18f813a3e1cb52cb7a8170489c712123ef8a4225e67b79f.md b/vision-fixhub/ds9-unparsed-06/49ead23c90502ad7f18f813a3e1cb52cb7a8170489c712123ef8a4225e67b79f.md
new file mode 100644
index 0000000000000000000000000000000000000000..acabd784dbc80d0b284a58a8b2362fd24dafdf15
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/49ead23c90502ad7f18f813a3e1cb52cb7a8170489c712123ef8a4225e67b79f.md
@@ -0,0 +1,241 @@
+From:
+To:
+(USAFLS)" <
+(CRM)" <
+2: <00.p.m.@hp-s0-71-2.usa.doj.gov»;
+Subject: RE: Jane Does 1 and 2 |. United States - Hearing on Friday, August 12, 2011, at 2:00 p.m.
+Date: Tue, 16 Aug 2011 23:02:58 +0000
+Importance: Normal
+, at
+Thank you, Mike. I really appreciate it.
+Assistant U.S. Attorney
+Fax
+Sent: Tuesday, August 16, 2011 6:38 PM
+1. (USAFLS)
+Subject: Re: Jane Does 1 and 2 |. United States - Hearing on Friday, August 12, 2011, at 2:00 p.m.
+I admire you for how hard you've fought this case. Stay strong.
+• (USAFLS) <
+Sent: Tue Aug 16 17:39:59 2011
+Subject: FW: Jane Does 1 and 2 |. United States - Hearing on Friday, August 12, 2011, at 2:00 p.m.
+Hi Mike - Can you start with L
+email down at the bottom and then read mine? Also, I was reading
+3771(d)(3) [the venue provision] for the 1000* time, and I wonder - could it refer to habeas proceedings?????
+Assistant U.S. Attorney
+Fax
+From:
+- (USAFLS)
+Sent: Tuesday, August 16, 2011 5:32 PM
+To: Lee,
+(USAFLS)
+Cc:
+I (USAFLS)
+Subject: RE: Jane Does 1 and 2 1. United States - Hearing on Friday, August 12, 2011, at 2:00 p.m.
+Hi
+and I have been bouncing some ideas around and wanted to share them with you before we
+shared them with the whole group.
+It seems that there were two points that were left hanging that were not completely answered during the
+argument. One was Judge Marra's repeated questions about "how would this really impact the government's
+discretion," alternatively phrased as, "couldn't you just have picked up the phone and called them?" The second
+was Cassell's claim that "the floodgates hadn't opened" since the decision in In re Dean.
+
+
+As to the first, I don't think that Judge Marra truly grasped the magnitude of what he was suggesting and certain
+examples would seem to bring the issue into clearer focus. For example, the position of the movants would
+require AUSAs (not agents, not vietim-witness coordinators, not secretaries), to personally "consult" with every
+victim in advance of declining a case or deferring to a state prosecution. Imagine how burdensome this would
+be in cases like these:
+• A credit card "skimmer" case, where the defendant may have "skimmed" the credit card numbers
+of hundreds of victims.
+• A child pornography case, where the defendant may have up to a million images of child
+pornography on his computer.
+• A theft of mail case where the defendant may have stolen dozens or hundreds of pieces of mail.
+• A white collar fraud case with a large number of victims.
+The court also should consider a situation, like the one here, where one of the "victims" is essentially in the
+defense camp. By consulting with him/her, especially in a case where we plan to defer to the State, we would be
+disclosing what could be a confidential investigation.
+The Court asked Cassell "how far back does it go?" The distinction between pre-charge and post-charge is the
+clearest line, and a line is necessary. It also is an appropriate line for two reasons. First, as I mentioned during
+the hearing, the United States has sovereign immunity from suit. We waive that immunity when we submit to
+the court's jurisdiction - via the filing of a criminal complaint or an indietment. Thus, drawing the line at the
+point of filing a charge is consistent with separation of powers principles. Second, prior to the filing of a public
+charge, there are constitutional due process principles (as incorporated in part in Rule 6(e)) governing the
+defendant's right not to be publicly accused of a crime without the opportunity to defend himself. By waiting
+until there is a public charge, there can be no claim of violation of grand jury secrecy. Also by waiting until there
+is a public charge, there can be no claim of the type of "conflict of interest" that has arisen in this case - where
+Epstein could manufacture a claim that we are investigating him due to pressure brought to bear by the victims'
+As to the second point, Cassell's claim that the "floodgates hadn't opened," I beg to differ. I spent about 4 hours
+esterday going through district court filings on Lexis Courtlink, and although I wasn't able to review each an
+very one, 1 did find several good examples:
+• Thibeaux | Doherty, 08-CV-61848, S.D. Fla. (Judge Cohn). Plaintiff sued 2 U.S. District
+Judges, several AUSAs, the clerk of court, and 2 U.S. Magistrate Judges claiming that they
+committed the crime of obstruction of justice in connection with his 2255 Petition. The plaintiff
+asked for relief pursuant to 3771(d)(3).
+• Piskanin |. Cameron, 11-CV-76 (W.D. Pa.) Plaintiff sued the Superintendent and Warden of the
+Prison along with the Pennsylvania Board of Probation and Parole. Plaintiff asked the court to
+order the USAO to "meet and confer with this crime victim to determine the procedure and need
+to initial Federal Criminal Prosecutions against petitioner's retaliators."
+• Hentges | State of Minnesota, et al., 10-CV-4081 (D. Minn.) Plaintiff sued State of Minnesota,
+Minnesota Attorney General, 2 Minnesota trial court judges, 1 Minnesota appellate judges, the
+child support enforcement unit officers in Colorado and Minnesota, and various County
+Attorneys. Plaintiff demanded immediate "federal protection, including restraining orders" and
+issuance of arrest warrants, and crime victim compensation. Plaintiff claimed that the defendants
+violated 18 USC 514 "Presentation of Fictitious Obligations" by forcing him to pay child support
+that he claimed he had previously paid. Plaintiff demanded the issuance of arrest warrants and
+charges based on 377l.
+Do you think it is worth asking Judge Marra for permission to file supplemental briefing addressing these two
+discrete issues?
+
+
+Assistant U.S. Attorney
+Fax
+From: Lee,
+(USAFLS)
+Sent: Tuesday, August 16, 2011 9:39 AM
+To:
+- (USAFLS);
+(USAFLS); I
+(USAFLS);
+Cc: |
+1. (USAFLS); L
+| (USAFLS)
+Subject: RE: Jane Does 1 and 2 |. United States - Hearing on Friday, August 12, 2011, at 2:00 p.m.
+(USAFLS)
+The hearing last 2.5 hours. Judge Marra first heard from the proposed intervenors, Bruce Reinhart and Roy Black. Bruce
+seeks to intervene to move for sanctions against the victims' attorneys for making baseless allegations against Reinhart for
+purported violations of DOJ and Florida Bar rules. Black seeks to intervene to prevent the unsealing and use of Epstein's
+defense attorneys' work product, as referenced in the series of one-sided e-mails provided to the victims' attorneys in the
+civil litigation against Epstein. Judge Marra gave Black and the government two weeks to submit additional briefing on
+the issue, with an opportunity for the victims to respond. Marra questioned how a matter could still be protected
+attorney work-product if it had been revealed to the government, the opposing side, in the Epstein criminal
+investigation. Black argued that criminal defense attorneys should be allowed to be candid and frank with prosecutors,
+free from any fear that their thoughts and impressions will be made public at some future time.
+The court denied the victims' motion to accept facts. Judge Marra said the victims had not denominated their motion as
+one for summary judgment, recognized that many of the alleged "facts" were opinions and conclusions, and said it was
+unfair to make the government stipulate or disagree with those "facts." The Court heard argument on the motion to
+compel the government to provide relevant information helpful to their case, and the motion for a finding that the CVRA
+had been violated.
+During our portion of the argument, I emphasized section 3771(d)(6)'s admonition that "Injothing in this chapter shall be
+construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction." I suggested
+that, if the court was faced with two possible interpretations of a provision, and one would impair the A/G's prosecutorial
+discretion and one would not, the court was obligated to choose the one that would not.
+Judge Marra was skeptical that applying 3771(a)(5), the right to reasonably consult with the attorney for the government
+in the case, would really impair prosecutorial discretion. At one point, he stated that, if the government had consulted
+with the victims prior to entering into the non-prosecution agreement, while the victims may not have agreed with that
+course of action, there was nothing they could do. He asked how that would impair prosecutorial discretion. I argued
+that U.S. Attorney's Offices decline prosecutions frequently, and that construing 3771(a)(5) to apply prior to the filing of a
+formal charge, would require the government to consult with identified victims prior to declining a case for prosecution.
+Additionally, I expressed pessimism that victims would not try to seek court intervention in the event an unfavorable
+decision had been made by the U.S. Attorney's Office.
+The Court inquired about an evidentiary hearing. I told the Court that the government had asserted a 'best efforts"
+defense, and that the resolution of that issue would require an evidentiary hearing. On the issue of discovery, the Court
+asked me if it had the authority to permit discovery. I said yes, if the court believed discovery was necessary to resolve
+disputed factual issues in the case. (
+I do not expect the court to rule until the round of briefing on the work-product issue is completed. I have included
+Marie and
+Lon this e-mail. They both attended the hearing and I welcome any comments they might want to add.
+
+
+From:
+• (USAFLS)
+Sent: Tuesday, August 16, 2011 9:02 AM
+To: L
+(USAFLS);
+(USAFLS); Lee, I
+I (USAFLS);
+Subject: RE: Jane Does 1 and 2 . United States - Hearing on Friday, August 12, 2011, at 2:00 p.m.
+What happened at the hearing?
+(USAFLS)
+From:
+(USAFLS)
+Sent: Friday, August 12, 2011 9:16 AM
+To:
+• (USAFLS);
+(USAFLS); Lee,
+(USAFLS);
+1. (USAFLS)
+Cc:
+(USAFLS);
+(USAFLS);
+| (USAFLS)
+Subject: RE: Jane Does 1 and 2 . United States - Hearing on Friday, August 12, 2011, at 2:00 p.m.
+Good luck. Let me know what happens after the hearing. Sure to get press calls.
+Alicia
+(USAFLS);
+From:
+• (USAFLS)
+Sent: Friday, August 12, 2011 9:07 AM
+To:
+(USAFLS); Lee,
+Cc:
+(USAFLS);
+(USAFLS);
+(USAFLS);
+(USAFLS);
+I (USAFLS)
+Subject: Re: Jane Does 1 and 2 | United States - Hearing on Friday, August 12, 2011, at 2:00 p.m.
+(USAFLS)
+Best of luck, l
+, We're in good hands with you there. Thanks for all your hard work in this difficult matter.
+From:
+(USAFLS)
+Sent: Friday, August 12, 2011 12:06 AM
+To: Lee,
+(USAFLS); I
+(USAFLS);
+(USAFLS);
+Cc: L
+I (USAFLS);
+I (USAFLS);
+(USAFLS)
+Subject: Re: Jane Does 1 and 2 . United States - Hearing on Friday, August 12, 2011, at 2:00 p.m.
+• (USAFLS)
+I agree that we should go forward with our best efforts defense, at least at this point.
+Good luck tomorrow,
+any evidentiary hearing.
+Hopefully, the judge will realize that he never needs to get to the best efforts defense or to
+From: Lee,
+• (USAFLS)
+Sent: Thursday, August 11, 2011 07:38 PM
+To: |
+- (USAFLS); |
+• (USAFLS);
+- (USAFLS)
+CC:
+(USAFLS);
+(USAFLS);
+(USAFLS);
+Subject: Jane Does 1 and 2 |. United States - Hearing on Friday, August 12, 2011, at 2:00 p.m.
+(USAFLS)
+Colleagues,
+Judge Marra will be holding a hearing tomorrow, August 12, at 2:00 p.m., on the victims four (4) motions. In
+the court's order, he stated he would be asking for the parties' positions on whether an evidentiary hearing is
+necessary. For our part, on the legal issue of whether rights under the Crime Victims Rights Act attached prior
+to the filing of a formal charge, the government does not believe any evidentiary hearing is necessary. The only
+two facts which are relevant are not disputed by the victims: (1) no formal charge was ever filed against Epstein
+in the S.D.Fla.; and (2) Epstein entered pleas of guilty to state charges on June 30, 2008, in Palm Beach County
+Circuit Court.
+
+
+If the court were to find that CVRA rights did attach in the absence of a formal charge against Epstein, the
+government has asserted that it used its "best efforts" to comply with the CVRA. In October 2007, after the
+non-prosecution agreement was signed, FBI agents met with four victims and advised them of the agreement.
+There is a dispute over what was told to these individuals, and the reasons why notifications to other victims
+did not occur. The victims also claim that CVRA letters sent to them by the FBI in January 2008 and May 2008
+were deceptive, since an agreement with Epstein had already been reached (although not fully approved by
+Main Justice).
+I believe an evidentiary hearing would be necessary for the government to present its "best efforts" defense.
+This would involve the government calling witnesses, including Marie, the FBI agents, and other current and
+former DOJ employees with relevant knowledge of our efforts to comply with the CVRA.
+We need to decide whether to maintain our best efforts defense, since it exposes us to an opportunity for the
+victims to probe what we did, and why we did it, and provide a platform for making us look bad. One
+consideration is whether our chances of prevailing, e.g. convincing the Court that we did use our best efforts, is
+sufficiently great to justify the effort and ordeal.
+I believe we should go forward with our best efforts defense. Our office did its best to ensure the victims
+were apprised of events in the matter involving Epstein, despite howls of protest coming from Epstein's
+attorneys. Our office had to walk a narrow path between perceived CVRA responsibilities, the incessant
+complaining from Epstein's legal camp, and preserving what might still have been a federal prosecution of
+Epstein had he gotten the agreement overturned at DOJ, or reneged on it completely. Giving up on the best
+efforts defense would be conceding too much.
+Alicia: We will call you tomorrow after the hearing, to let you know about what went on, and the press
+coverage.
+I will be leaving here at 9:00 a.m. and hope to be at the West Palm Beach office by 11:00 a.m. Thanks.
diff --git a/vision-fixhub/ds9-unparsed-06/49ead23c90502ad7f18f813a3e1cb52cb7a8170489c712123ef8a4225e67b79f.receipt.json b/vision-fixhub/ds9-unparsed-06/49ead23c90502ad7f18f813a3e1cb52cb7a8170489c712123ef8a4225e67b79f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..dc7cbb94cbe4a1c2b5ed8b119251b815ad177cae
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/49ead23c90502ad7f18f813a3e1cb52cb7a8170489c712123ef8a4225e67b79f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -60,
+  "dataset": "marble-joined",
+  "doc_id": "49ead23c90502ad7f18f813a3e1cb52cb7a8170489c712123ef8a4225e67b79f",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "d965aa3c6a794538f37e37a84dc3fbfa7fda4ab91ec06bccdb943175f5f4c914",
+  "output_sha256": "8c3c33d9cdf9926e4494fe6463a7c0493ff99e2a507223cad59e10fe22251dff",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/49ec8d5d2484b0f9a1a48f509b6e9581659a1bd4c7a69fa2d4948cd3095f9e3f.md b/vision-fixhub/ds9-unparsed-06/49ec8d5d2484b0f9a1a48f509b6e9581659a1bd4c7a69fa2d4948cd3095f9e3f.md
new file mode 100644
index 0000000000000000000000000000000000000000..418fd318da1922034760a36c0a03165fb9ad3a67
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/49ec8d5d2484b0f9a1a48f509b6e9581659a1bd4c7a69fa2d4948cd3095f9e3f.md
@@ -0,0 +1,10 @@
+Subject: RE: Press Coverage re Op Stolen Globe/Epstein
+Date: Tue, 26 Jan 2010 16:46:59 +0000
+Importance: Normal
+What a charmed existence you lead!
+Subject: Press Coverage re Op Stolen Globe/Epstein
+I have suspicions about who tipped off the press given my recent back and forth with some of the plaintiffs'
+attorneys, but in any event, this appeared in this morning's Palm Beach Post.
+Drew - Can we set up the meeting with the AUSAs in California and New Mexico some time soon?
+<< File: ex-epstein-worker-faces.pdf >>
+Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/49ec8d5d2484b0f9a1a48f509b6e9581659a1bd4c7a69fa2d4948cd3095f9e3f.receipt.json b/vision-fixhub/ds9-unparsed-06/49ec8d5d2484b0f9a1a48f509b6e9581659a1bd4c7a69fa2d4948cd3095f9e3f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..34d69ac77e1d6672b8d1580fdd4b605c6ce543ca
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/49ec8d5d2484b0f9a1a48f509b6e9581659a1bd4c7a69fa2d4948cd3095f9e3f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "49ec8d5d2484b0f9a1a48f509b6e9581659a1bd4c7a69fa2d4948cd3095f9e3f",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "54f8fe67d41a1b28474552d25ee1665ce7677a23069d7d7cb94bf4a8e3a71e74",
+  "output_sha256": "7e3c8a59b80ec533ced6ba35fc67cf6a6134529ef3b893fc155211f9978d2c51",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4a2fbb615c945590192f6ec103b394fc5743cc83647000a09a319db80fad8914.md b/vision-fixhub/ds9-unparsed-06/4a2fbb615c945590192f6ec103b394fc5743cc83647000a09a319db80fad8914.md
new file mode 100644
index 0000000000000000000000000000000000000000..b640bd926ee84f4cacf1a21fc11a1dcfbf2ec429
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4a2fbb615c945590192f6ec103b394fc5743cc83647000a09a319db80fad8914.md
@@ -0,0 +1,15 @@
+From: "Barrett, Wayne" <Wayne.Barrett@newsweekdailybeast.com>
+Date: Wed, 20 Jul 2011 20:58:20 +0000
+Importance: Normal
+This is Jacob Albert, research assistant for Wayne Barrett, at Newsweek. I know you've said that you wouldn't comment on our questions,
+but I wanted to give you the chance to hear what we're asking before declining. If you'd rather speak by phone, on or off record,
+1) The nonprosecution deal that you worked out specified that Epstein would do 30 months in jail? What's your understanding of why he
+did only 13 of the 18mo of his jail sentence, and why was he excused from the carrying out the remainder of his sentence? Who approved
+the sentence reduction, at state or federal level, and why?
+2) Do you have any knowledge of how Jeffiey Epstein was able to preserve personal and corporate tax benefits/exemption in the Virgin
+Islands, in 2009, which requires residency (183 days) that Epstein was unable to meet, as he was under house arrest during that period? Do
+you know whether VI residency requirements for tax benefits/exemptions are waived if you're in prison or under house arrest in another
+If you still have no comment, please let me know; the article running in Newsweek will state that your office wouldn't comment.
+Thanks,
+Jacob Albert
+Research Assitant for Wayne Barrett
diff --git a/vision-fixhub/ds9-unparsed-06/4a2fbb615c945590192f6ec103b394fc5743cc83647000a09a319db80fad8914.receipt.json b/vision-fixhub/ds9-unparsed-06/4a2fbb615c945590192f6ec103b394fc5743cc83647000a09a319db80fad8914.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..45773c042ad8a5536156d5a36b49af861a8051e9
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4a2fbb615c945590192f6ec103b394fc5743cc83647000a09a319db80fad8914.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "4a2fbb615c945590192f6ec103b394fc5743cc83647000a09a319db80fad8914",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "37128c14fa551266096eb353683dcc8b993a70ec6e60eb96bd82cd9b9802380a",
+  "output_sha256": "056668c32541e6ea05170ae3a6efe63c059ed5e091d5876c65e5e968e7c5f741",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4a7b829ef91e0f1b756239a006d0f32080875f37f5fad5273ba62c38c0be064d.md b/vision-fixhub/ds9-unparsed-06/4a7b829ef91e0f1b756239a006d0f32080875f37f5fad5273ba62c38c0be064d.md
new file mode 100644
index 0000000000000000000000000000000000000000..714333c34bc7009d5599b4a43c9d3d3d4d202d17
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4a7b829ef91e0f1b756239a006d0f32080875f37f5fad5273ba62c38c0be064d.md
@@ -0,0 +1,43 @@
+From:
+Subject: Activity in Case 9:08-cv-80893-KAM Doe I. Epstein Response to Motion
+Date: Thu, 01 Jul 2010 16:38:39 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. Distriet Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Pike, Michael on 7/1/2010 at 12:38 PM EDT and filed on 7/1/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 191
+Doe | Epstein
+9:08-cv-80893-KAM
+Jeffrey Epstein
+Docket Text:
+RESPONSE to Motion re [187] Plaintiff's MOTION No Contact Order at Settlement Conference
+filed by Jeffrey Epstein. Replies due by 7/12/2010. (Pike, Michael)
+9:08-cv-80893-KAM Notice has been electronically mailed to:
+Bradley James Edwards
+Jack Alan Goldberger
+Katherine Warthen Ezell
+Michael James Pike
+Paul G. Cassell
+Robert Deweese Critton, Jr
+9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+The following documents) are associated with this transaction:
+
+
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=7/1/2010] [FileNumber=7745537-0]
+[2c300c7b196e778031a873ddfba74b1d13454d7bb535e00ff72a4e4d82593ca04b77
+0155b61e4efbe5fcd90cad5840a07ab520cf00035c49630b6c65c3736ec4]]
diff --git a/vision-fixhub/ds9-unparsed-06/4a7b829ef91e0f1b756239a006d0f32080875f37f5fad5273ba62c38c0be064d.receipt.json b/vision-fixhub/ds9-unparsed-06/4a7b829ef91e0f1b756239a006d0f32080875f37f5fad5273ba62c38c0be064d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d11bdfe76365c6a1dd4f77186128d5c571f051d2
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4a7b829ef91e0f1b756239a006d0f32080875f37f5fad5273ba62c38c0be064d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "4a7b829ef91e0f1b756239a006d0f32080875f37f5fad5273ba62c38c0be064d",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "5de5616faf03599db5e28a43ead3ad2fe13a0d5e1f3e00689b5b780e2752a099",
+  "output_sha256": "57460d30671d36fcdfdd11d8c45e2ddb5748f398f24503e09adaa6a08f28a999",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4a840d960cfdb17d5aa813e5404a8382206ecdce47fcabcbc42091303fd7d0a5.md b/vision-fixhub/ds9-unparsed-06/4a840d960cfdb17d5aa813e5404a8382206ecdce47fcabcbc42091303fd7d0a5.md
new file mode 100644
index 0000000000000000000000000000000000000000..9001b369836d991872c1c7579cc7276d312741c6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4a840d960cfdb17d5aa813e5404a8382206ecdce47fcabcbc42091303fd7d0a5.md
@@ -0,0 +1,34 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov>
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov»
+Subject: Activity in Case 9:08-cv-80893-KAM Doe |. Epstein Sealed Document
+Date: Fri, 02 Jul 2010 18:11:11 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 7/2/2010 at 2:11 PM EDT and filed on 7/2/2010
+Case Name:
+Doe | Epstein
+Case Number:
+9:08-cv-80893-KAM
+Filer:
+Document Number: 194(No document attached)
+Docket Text:
+Sealed Document (ots)
+9:08-cv-80893-KAM Notice has been electronically mailed to:
+Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com
+Jack Alan Goldberger
+jagesq@bellsouth.net, nalanis@agwpa.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+Michael James Pike MPike@bclclaw.com, bobbie@bclclaw.com, jcadwell@bclelaw.com
+Paul G. Cassell cassellp@law.utah.edu
+Robert Deweese Critton, Jr _rerit@bclclaw.com, bobbie@bclclaw.com
+9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
diff --git a/vision-fixhub/ds9-unparsed-06/4a840d960cfdb17d5aa813e5404a8382206ecdce47fcabcbc42091303fd7d0a5.receipt.json b/vision-fixhub/ds9-unparsed-06/4a840d960cfdb17d5aa813e5404a8382206ecdce47fcabcbc42091303fd7d0a5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..deb8d4feb6ae0f9bf787f3d271f4ef2c910a2184
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4a840d960cfdb17d5aa813e5404a8382206ecdce47fcabcbc42091303fd7d0a5.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "4a840d960cfdb17d5aa813e5404a8382206ecdce47fcabcbc42091303fd7d0a5",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "23e5b991acbafa2a4fbb5118cf8a1971d8c80caf83070a3cb7ccdf12b3984785",
+  "output_sha256": "fbe93edd5dc17bccdab92a7d268728985df42c8d0441808b406a27eb97671a83",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4acde7376db0b730302824d30c678452150b6a6e05f5e3b3cb090b4fffcb452c.md b/vision-fixhub/ds9-unparsed-06/4acde7376db0b730302824d30c678452150b6a6e05f5e3b3cb090b4fffcb452c.md
new file mode 100644
index 0000000000000000000000000000000000000000..308b47cb6f3c56da58d7827d4ff729af2c22ab11
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4acde7376db0b730302824d30c678452150b6a6e05f5e3b3cb090b4fffcb452c.md
@@ -0,0 +1,19 @@
+From:
+To:
+Cc:
+Subject: RE: Epstein
+Date: Fri, 07 Oct 2011 18:22:15 +0000
+Importance: Normal
+Thanks Doug. I am also including
+with some of the legal issues we face. Thanks.
+to the U.S. Attorney, on this e-mail given his familiarity
+From: Molloy, Douglas (USAFLM)
+Sent: Friday, October 07, 2011 2:20 PM
+Subject Epsten
+I am the AUSA from the MDFL assigned to the Epstein matter. In that regard,
+and I have
+arranged for a meeting in West Palm Beach for a full debriefing on all issues. I would like to include
+in that meeting, which we have set for October 27, 2011.
+Regards,
+Assistant U.S. Attorney
+Fort Myers Division, MDFL
diff --git a/vision-fixhub/ds9-unparsed-06/4acde7376db0b730302824d30c678452150b6a6e05f5e3b3cb090b4fffcb452c.receipt.json b/vision-fixhub/ds9-unparsed-06/4acde7376db0b730302824d30c678452150b6a6e05f5e3b3cb090b4fffcb452c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c6015b38d3044e1a7cb9b98134142c16f27b2658
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4acde7376db0b730302824d30c678452150b6a6e05f5e3b3cb090b4fffcb452c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "4acde7376db0b730302824d30c678452150b6a6e05f5e3b3cb090b4fffcb452c",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "4688ddc173be4a1dadf0b6cea3671cc8205bf325901f3aaad706279312b4b5b0",
+  "output_sha256": "0d6d1f0062a79df4ab0537ec590950e87e58daa94b3545ba2389591f907057be",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4ad867e50ee776d43841cd0f797e46df2ea3b0cb1cf72826385fef94d81be01d.md b/vision-fixhub/ds9-unparsed-06/4ad867e50ee776d43841cd0f797e46df2ea3b0cb1cf72826385fef94d81be01d.md
new file mode 100644
index 0000000000000000000000000000000000000000..ff3a521a8d9d47dd730d9278b877328b3c090d55
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4ad867e50ee776d43841cd0f797e46df2ea3b0cb1cf72826385fef94d81be01d.md
@@ -0,0 +1,26 @@
+From: "I
+To: "
+Subject: RE:
+Date: Thu, 10 May 2007 13:52:48 +0000
+Importance: Normal
+(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=L
+(USAFLS)" {
+This is so wrong - on so many levels - that I don't know where to begin.
+E.J.
+From:
+7. (USAFLS)
+Sent: Thursday, May 10, 2007 9:51 AM
+To: |
+- (USAFLS)
+Subject: FW:
+Your guidance is sorely needed.
+Assistant U.S. Attorney
+From:
+(USAFLS)
+Sent: Thursday, May 10, 2007 9:49 AM
+To: L
+1. (USAFLS)
+Subject:
+• Epstein has no doubt told them that there were
+many.
+Thoughts?
diff --git a/vision-fixhub/ds9-unparsed-06/4ad867e50ee776d43841cd0f797e46df2ea3b0cb1cf72826385fef94d81be01d.receipt.json b/vision-fixhub/ds9-unparsed-06/4ad867e50ee776d43841cd0f797e46df2ea3b0cb1cf72826385fef94d81be01d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..37f4c9e0e1034d82676ea729b25373d88e2102c5
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4ad867e50ee776d43841cd0f797e46df2ea3b0cb1cf72826385fef94d81be01d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "4ad867e50ee776d43841cd0f797e46df2ea3b0cb1cf72826385fef94d81be01d",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "8d06a8a659abcae29b7c9be74989ed34c3bd3ca677377bc9289eca627ef25bb6",
+  "output_sha256": "77aa39047716ae657946fa08b0954a50c25db8bc85fd6302cc318b5dadb3fcaf",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4b4d4120c0ce3fc9912c4c72aff93a6a9096da3819fc27f072bd6d9bffd2858c.md b/vision-fixhub/ds9-unparsed-06/4b4d4120c0ce3fc9912c4c72aff93a6a9096da3819fc27f072bd6d9bffd2858c.md
new file mode 100644
index 0000000000000000000000000000000000000000..eda9cce5cab81bb229f926f4735fe006d05c5c90
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4b4d4120c0ce3fc9912c4c72aff93a6a9096da3819fc27f072bd6d9bffd2858c.md
@@ -0,0 +1,56 @@
+From:
+(USAFLS)" <
+To:
+(USAFLS)" {
+Subject: Re: Jane Doe litigation
+Date: Sun, 08 Jan 2012 18:54:55 +0000
+Importance: Normal
+I will confirm for you. The other case I think is
+AUSA
+. Brad has represented at least a half dozen women who sued JE.
+From:
+(USAFLS)
+Sent: Sunday, January 08, 2012 12:17 PM
+To:
+(USAFLS)
+Subject: Re: Jane Doe litigation
+Is there some way we can make sure so we can get all of the Petitioners' complaints. It's an important part of the
+argument. You're sure only one of them sued in state court? Brad represented plaintiffs in both of the cases I forwarded to
+you.
+From:
+To:
+- (USAFLS)
+Sent: Sunday, January 08, 2012 11:16 AM
+(USAFLS); Lee,
+Subject: Re: Jane Doe litigation
+(USAFLS)
+: I am 90% sure that
+I is our Jane Doe #1. Jane Doe #2 did not sue in federal court. She sued in Palm Beach County
+state court. I am pretty sure I have her case number somewhere. I don't think I have ever seen her civil complaint.
+From:
+(USAFLS)
+Sent: Friday, January 06, 2012 06:32 PM
+To:
+1. (USAFLS); Lee,
+Subject: Re: Jane Doe litigation
+I (USAFLS)
+Were either of you able to confirm that these plaintiffs are our petitioners?
+From:
+(USAFLS)
+Sent: Wednesday, January 04, 2012 08:26 PM
+To:
+(USAFLS); Lee,
+Subject: Jane Doe litigation
+&
+(USAFLS)
+Can you confirm that the plaintiffs in the cases cited below are the petitioners in our CVRA matter?
+First Am. Compl. 11 32-33, Doe | Epstein, Case No. 08-80893-CIV-MARRA ("assert[ing] a cause of action against
+the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the [Non-Prosecution] agreement between the
+Defendant, Jeffrey Epstein, and the United States Government"); Compl. 11 19-20, L.M. | Epstein, Case No. 09-
+81092-CIV-Cohn (asserting that plaintiff was "covered by" provisions of the Non-Prosecution Agreement between
+the government and Epstein and that Epstein was thus "estopped by his plea and agreement with the Federal
+
+
+Government from denying the acts alleged in [the] Complaint, and must effectively admit liability to the Plaintiff,
+L.M., including admitting liability for all counts enumerated in this Complaint")
+Thanks,
diff --git a/vision-fixhub/ds9-unparsed-06/4b4d4120c0ce3fc9912c4c72aff93a6a9096da3819fc27f072bd6d9bffd2858c.receipt.json b/vision-fixhub/ds9-unparsed-06/4b4d4120c0ce3fc9912c4c72aff93a6a9096da3819fc27f072bd6d9bffd2858c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..006f7643b6830bc7ce99c3f2dd84ba63e1e88057
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4b4d4120c0ce3fc9912c4c72aff93a6a9096da3819fc27f072bd6d9bffd2858c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "4b4d4120c0ce3fc9912c4c72aff93a6a9096da3819fc27f072bd6d9bffd2858c",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "2b1a0a0bc2301d083ca2ceee6d69e3f57d01b0e5ee2bf17502745969ef83fa06",
+  "output_sha256": "c08ec8677a39eb4f1818ed8f7e4405acb906790dcecff1c42dee24ca20d0b711",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4b6c29d45aadf38a01b735807f9f0e8f181febf4354c293688c216ccc4fb2e51.md b/vision-fixhub/ds9-unparsed-06/4b6c29d45aadf38a01b735807f9f0e8f181febf4354c293688c216ccc4fb2e51.md
new file mode 100644
index 0000000000000000000000000000000000000000..f6a0eed1a2c8608b08d6038343915a5f9e88201f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4b6c29d45aadf38a01b735807f9f0e8f181febf4354c293688c216ccc4fb2e51.md
@@ -0,0 +1,45 @@
+From:
+To:
+Subject: Activity in Case 9:09-cv-80469-KAM Doe II |. Epstein et al Response to Order to Show Cause
+Date: Fri, 02 Jul 2010 17:57:05 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern Distriet of Florida
+Notice of Electronic Filing
+The following transaction was entered by Garcia, Isidro on 7/2/2010 at 1:57 PM EDT and filed on 7/2/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 81
+Doe II | Epstein et al
+9:09-cv-80469-KAM
+Jane Doe II
+Docket Text:
+RESPONSE TO ORDER TO SHOW CAUSE by Jane Doe II. (Garcia, Isidro)
+9:09-cv-80469-KAM Notice has been electronically mailed to:
+Bradley James Edwards
+brad@pathtojustice.com, beth@pathtojustice.com
+Bruce Reinhart
+Denise Kalland
+Isidro Manuel Garcia
+Jack Alan Goldberger
+Michael James Pike
+Robert Deweese Critton, Jr
+9:09-cv-80469-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+
+
+The following document(s) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP dcecfStamp_ID=1105629215 [Date=7/2/2010] [FileNumber=7751711-0]
+[570381d3a916ffc140f218a680b054f33894e41fd2477a65cddbde3fdc869d532c0e
+2d033502a11ba37f02dc29ee88d52704b5346d9a89ca0f54dce9edf2d314]]
diff --git a/vision-fixhub/ds9-unparsed-06/4b6c29d45aadf38a01b735807f9f0e8f181febf4354c293688c216ccc4fb2e51.receipt.json b/vision-fixhub/ds9-unparsed-06/4b6c29d45aadf38a01b735807f9f0e8f181febf4354c293688c216ccc4fb2e51.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3eb43a13002ac8627afdaa66a60639f5ae31f8ef
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4b6c29d45aadf38a01b735807f9f0e8f181febf4354c293688c216ccc4fb2e51.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "4b6c29d45aadf38a01b735807f9f0e8f181febf4354c293688c216ccc4fb2e51",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "fa90d3baecf1a28f4126f661bd8652613645d574442909556a119f657661f4ed",
+  "output_sha256": "dd4b5afaba989494d921868b42c43f302692bcf503e585344b9d2dba7eaa3bda",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4b94537cb308ddcd3424e5ada1f73acccc4a601e5f88a5b639c05b21437a5825.md b/vision-fixhub/ds9-unparsed-06/4b94537cb308ddcd3424e5ada1f73acccc4a601e5f88a5b639c05b21437a5825.md
new file mode 100644
index 0000000000000000000000000000000000000000..e2b11b82bd08279d01876b990955935aa437cea3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4b94537cb308ddcd3424e5ada1f73acccc4a601e5f88a5b639c05b21437a5825.md
@@ -0,0 +1,56 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOES #1 and #2
+Petitioners,
+UNITED STATES
+Respondent.
+GOVERNMENT'S RESPONSE TO PETITIONERS' REQUEST
+FOR NON-PROSECUTION AGREEMENT AND REPORT OF INTERVIEW
+Respondent United States, by and through its undersigned counsel, files its Response to Petitioners'
+Request for Non-Prosecution Agreement and Report of Interview, and states:
+In their Response to Government's Notice to Court Regarding Absence of Need for Evidentiary Hearing
+and Motion for Production of Non-Prosecution Agreement and Report of Interview (D.E. 19), petitioners seek an
+order compelling the Government to produce the Non-Prosecution Agreement with Jeffrey Epstein (D.E. 19 at
+11-13), and the Report of Interview with Jane Doe # 1 (D.E. 19 at 13-14).
+The Government is unable to voluntarily produce the Non-Prosecution Agreement because the
+Agreement contains a clause where the parties expressed their anticipation that the Agreement would not be
+made part of any public record. The Government believes this clause in the Agreement precludes it from
+voluntarily producing the Agreement, as requested by petitioners.
+As to petitioners' request for the Report of Interview with Jane Doe # 1, counsel for the Government has
+spoken with FBI Special Agents Nesbitt Kurykendall and Jason Richardson, who have advised that no Report of
+Interview was prepared subsequent to their meeting with Jane Doe # 1 in late September 2007, to discuss the
+Non-Prosecution Agreement entered into with Jeffrey Epstein.
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By: s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+Fla. Bar No. 0936693
+99 N.E. 4 i Street
+Miami, Florida
+33132
+(305) 961-9320
+Fax: (305) 530-7139
+E-mail: dexter.lee@usdoj.gov
+Attorney for Respondent
+CERTIFICATE OF SERVICE
+
+
+I HEREBY CERTIFY that on August
+Clerk of the Court using CM/ECF.
+_ 2008, I electronically filed the foregoing document with the
+s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+SERVICE LIST
+Jane Does 1 and 2 . United States,
+Case No. 08-80736-CIV-MARRA/JOHNSON
+United States District Court, Southern District of Florida
+Brad Edwards, Esq.,
+2028 at Of Street, Suite 202rds de Associates, LL C
+_Street, Suite 202
+Hollywood, Florida
+(954) 414-8033
+Fax: (954) 924-1530
diff --git a/vision-fixhub/ds9-unparsed-06/4b94537cb308ddcd3424e5ada1f73acccc4a601e5f88a5b639c05b21437a5825.receipt.json b/vision-fixhub/ds9-unparsed-06/4b94537cb308ddcd3424e5ada1f73acccc4a601e5f88a5b639c05b21437a5825.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4ad5b43120a96c0dd2f80930ec634d79957dbf7f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4b94537cb308ddcd3424e5ada1f73acccc4a601e5f88a5b639c05b21437a5825.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "4b94537cb308ddcd3424e5ada1f73acccc4a601e5f88a5b639c05b21437a5825",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "6c438b6c354172a67f37e4ae1ace2843eab46743033dc454657e2d37b6834d6e",
+  "output_sha256": "d6cc103bc363ed59b7ef7a22015a295ec46b8945d783412161adccfa49a6c6ca",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4c00225490447165a0dc4a1b499380a23631daa050b9b3dec8480c48671d79e4.md b/vision-fixhub/ds9-unparsed-06/4c00225490447165a0dc4a1b499380a23631daa050b9b3dec8480c48671d79e4.md
new file mode 100644
index 0000000000000000000000000000000000000000..74eb4ab78dd8b922ea72164b1c14a869b195a5ea
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4c00225490447165a0dc4a1b499380a23631daa050b9b3dec8480c48671d79e4.md
@@ -0,0 +1,24 @@
+From: Brad Edwards <
+To: "'
+(USAFLS)'" -
+Subject:
+Date: Tue, 04 Oct 2011 17:45:29 +0000
+Importance: Normal
+Attachments: NEW_YORK_SORA
+_ HEARING_JAN._18,_2011-401.PDF
+Inline-Images: image001 .jpg
+Here it is! If you have any information on the appeal that might be helpful. Thanks
+Brad Edwards
+Civil Justice Attorney
+Become our fan on Facebook
+S5T Please consider the environment before printing this e-mail.
+IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments hereto are not intended to constitute a
+"reliance opinion" under applicable Treasury Regulations, and accordingly are not intended or written to be used, and may not be used
+or relied upon, for the purpose of (i) avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or
+(i) promoting, marketing or recommending to another party any tax-related matters addressed herein.
+NOTICE: THE INFORMATION CONTAINED IN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND CONFIDENTIAL. IT IS
+INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT
+THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPY OF THIS
+COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US
+IMMEDIATELY BY TELEPHONE TOLL FREE I
+AND DELETE THE MATERIAL FROM ANY COMPUTER. THANK YOU.
diff --git a/vision-fixhub/ds9-unparsed-06/4c00225490447165a0dc4a1b499380a23631daa050b9b3dec8480c48671d79e4.receipt.json b/vision-fixhub/ds9-unparsed-06/4c00225490447165a0dc4a1b499380a23631daa050b9b3dec8480c48671d79e4.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0feda9d5c21133dba279eaff11a2ba20a80da43d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4c00225490447165a0dc4a1b499380a23631daa050b9b3dec8480c48671d79e4.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "4c00225490447165a0dc4a1b499380a23631daa050b9b3dec8480c48671d79e4",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "7037bd36cd4f2428717a999c85ab2b43f7acaabf021c0e2e082cac0c1bdbe375",
+  "output_sha256": "6b744779add334e044e0f970bd3354dd73913c35ac3cb78d0d4531429f812b10",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4c1c458c25b6f065a18e408041cf1c09a184a1d9e2cfdb201e70698aebea5017.md b/vision-fixhub/ds9-unparsed-06/4c1c458c25b6f065a18e408041cf1c09a184a1d9e2cfdb201e70698aebea5017.md
new file mode 100644
index 0000000000000000000000000000000000000000..d2539f16761c9d27e1c36f8ffd1ec4836f829bf4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4c1c458c25b6f065a18e408041cf1c09a184a1d9e2cfdb201e70698aebea5017.md
@@ -0,0 +1,77 @@
+From:
+To:
+Cc: "Sanchez Eduardo (SAELS" «ESanchezlamen doi aouz "'brad@nathtoinstice .com!"
+Subject: Re: Judge Marra's Order Granting the Victims' Motion to Compel Discovery Within 30 Days
+Date: Tue, 25 Jun 2013 00:54:26 +0000
+Importance: Normal
+Paul,
+We have not seen DE 123. In any event, thanks for the clarification. We will be in touch.
+From: Paul Cassell [1
+Sent: Monday, June 24, 2013 08:46 PM
+To:L
+,, Brad Edwards <brad@pathtojustice.com>
+Subject: RE: Judge Marra's Order Granting the Victims' Motion to Compel Discovery Within 30 Days
+[tried to send this earlier, but it may not have gone out]
+Dear
+We haven't seen the sealed order granting the Government's motion for stay either. (Have you?).
+But, in any event, Judge Marra's order on June 19, 2013 (DE 190) specifically stated that "The petitioners' motion to
+compel discovery from the Government [DE 130] is GRANTED. Within THIRTY (30) DAYS from the date of entry of this
+order, the Government shall ... [produce various discovery]." For your convenience, I attach a copy of DE 190 ordering
+the Government to produce discovery within 30 days.
+So we are expecting to see you produce the bulk of our discovery on July 19, 2013, as specifically directed in DE 190
+which granted our motion to compel.
+Looking forward to moving the case towards a resolution.
+Brad Edwards and Paul Cassell for Jane Doe #1 and Jane Doe #2
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+S.J. Quinney College of Law at the University of Utah
+You can access my publications on http://ssrn.com/author=30160
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee.
+If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in
+error, please immediately notify the sender by reply electronic mail and delete the original message. Professor Cassell is admitted to the Utah State
+Bar, but not the bars of other states. Thank you.
+From: •
+Sent: Monday, June 24, 2013 5:24 PM
+To: Paul Cassell; Villafana, Ann Marie C. (USAFLS) -
+
+
+; Brad Edwards
+Subject: RE: One additional discovery request in Jane Doe #1 and Jane Doe #2 vs. U.S., No. 08-80736
+Paul,
+You have addressed your additional discovery request to the correct person. In the Court's order denying the
+government's motion to dismiss, the Court referenced "It]he stay of discovery pending ruling on the government's motion
+to dismiss entered November 8, 2011 [DE #123] is LIFTED." I checked back into my CM/ECF notifications on Outlook,
+and did not find any for D.E. 123.I checked the docket sheet, which indicates a sealed order being entered on November
+9, 2011, which is D.E. # 123.
+I was under the impression the Court had not ruled on the government's motion to stay. On December 6, 2012, the
+petitioners filed their Motion for Prompt Ruling Denying Government's Motion to Stay (D.E. 179), in which the petitioners
+noted that, "It]he government's motion was filed more than one year ago, yet (presumably because of a flurry of other
+motions) the Court has yet to rule on this particular motion." From this, it appears petitioners also believed the Court
+had not ruled on the government's motion for stay.
+In any event, your e-mail states that "you look forward to receiving the discovery materials that the Court has ordered you
+to produce on the schedule that the Court has ordered them produced." What is your view as to the schedule that the
+Court has ordered the documents produced? Is that contained in D.E. 123? Thanks.
+Dexter
+From: Paul Cassell I
+Sent: Monday, June 24, 2013 4:07 PM
+To:
+Cc:
+Subject: RE: One additional discovery request in Jane Doe #1 and Jane Doe #2 vs. U.S., No. 08-80736
+Dear
+I am writing to confirm that you remain the person that we should be contacted with regard to the above-captioned
+case. If not, please advise as to who the appropriate contact person is (and please forward this message to that person).
+In light of the Court lifting the stay on discovery, we are writing send one additional discovery request. Of course, this
+request is in ADDITION to the requests previously sent. It should not be viewed as replacing the other discovery requests
+or extending the deadline for producing the materials covered by the other discovery requests.
+We look forward to receiving the discovery materials that the Court has ordered you to produce on the schedule that the
+Court has ordered them produced.
+Please let us know if you have any questions.
+Paul Cassell and Brad Edwards for Jane Doe #1 and Jane Doe #2
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+S.J. Quinney College of Law at the University of Utah
+25 Call 1100 Co Doom101 bloCk IT 01119,0500
+CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee.
+If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in
+error, please immediately notify the sender by reply electronic mail and delete the original message. Professor Cassell is admitted to the Utah State
+Bar, but not the bars of other states. Thank you.
diff --git a/vision-fixhub/ds9-unparsed-06/4c1c458c25b6f065a18e408041cf1c09a184a1d9e2cfdb201e70698aebea5017.receipt.json b/vision-fixhub/ds9-unparsed-06/4c1c458c25b6f065a18e408041cf1c09a184a1d9e2cfdb201e70698aebea5017.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1aa45d514efb278bc00042e22fb76a324a84051d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4c1c458c25b6f065a18e408041cf1c09a184a1d9e2cfdb201e70698aebea5017.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "4c1c458c25b6f065a18e408041cf1c09a184a1d9e2cfdb201e70698aebea5017",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "1681f40c02a170e8a152015b218303300004751320b4c56679c9c6d902687214",
+  "output_sha256": "33163989d3fa12e2c3db0af24ed2ea2914671284e6a098cae3a54f17e4803c95",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4cb47dac0136f972d1d0e78b110d2cc3c490c575694d3e0c0df1ca958eb9f4df.md b/vision-fixhub/ds9-unparsed-06/4cb47dac0136f972d1d0e78b110d2cc3c490c575694d3e0c0df1ca958eb9f4df.md
new file mode 100644
index 0000000000000000000000000000000000000000..a7a81194e3001f1e3507dedb7f1c0fd3b972cdc6
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4cb47dac0136f972d1d0e78b110d2cc3c490c575694d3e0c0df1ca958eb9f4df.md
@@ -0,0 +1,63 @@
+From:
+. (USAFLS)"
+To: "
+(USAFLS)" L
+Subject: RE: Meeting Next Week
+Date: Thu, 21 Jun 2007 19:24:28 +0000
+Importance: Normal
+Sounds good. I will stop by on Monday afternoon. Could you just let you assistant know that I may be stopping
+by to get a copy of whatever the defense sends over?
+Thanks.
+Assistant U.S. Attorney
+From:
+To:
+Cc:
+(USAFLS)
+Sent: Thursday, June 21, 2007 2:58 PM
+1. (USAFLS)
+| (USAFLS)
+Subject: RE: Meeting Next Week
+Meeting on Monday is fine. I have meetings with
+and
+till around 11 but after that I'm free. As for who is going to
+be at the meeting from our side, I thought you, me,
+• and I thought it best to leave out of it at this venture.
+As for the Epstein camp, I'm not entirely sure because I don't think was sure last time we spoke. Probably her,
+and maybe
+I told me that they wanted to present something in writing before the meeting which was why she was pushing us for
+the statutes. I view the meeting more as us listening and them presenting their position so I would say that you don't
+need to prepare anything (you are quite knowledgeable on the law in any event) but if you disagree we can discuss on
+Monday. As for the documents that they have yet to produce, I'II mention it to if you like or we can raise it with them
+at the Tuesday meeting.
+From:
+I. (USAFLS)
+Sent: Thursday, June 21, 2007 1:37 PM
+To:
+I (USAFLS)
+Cc:
+(USAFLS);
+Subject: Meeting Next Week
+Importance: High
+(USAFLS); I
+(USAFLS); Sloman, (USAFLS)
+: I would like to prepare for next week's meeting, and I am wondering if you can tell me who will
+attend, both from our side and for Mr. Epstein. I am hoping that we can meet on Monday to discuss any issues
+and/or strategy before the meeting on Tuesday, so please let me know when you will be available on Monday.
+Also, if there are any issues that you would like me to be prepared to address - either with you on Monday or
+with defense counsel on Tuesday - please give me a list and I will bring the appropriate items with me.
+
+
+Since
+has been communicating with you directly about the meeting, and I have given them the list of
+statutes that they have requested, perhaps you could ask her to reciprocate by providing us with their written
+analysis (or documents they want us to consider) prior to the meeting so we can address any issues then and
+there. Also, during a previous meeting, I asked
+for copies of Epstein (or his assistants") agendas
+and calendars to show that, as they claim, Epstein's travels to Florida were consciously coordinated so that he
+could maintain his Florida residency for tax purposes.
+said she would try to get them to us, but has never
+done so. I have subpoenaed all of the corporate entities with which Epstein is affiliated and they all claim that
+they do not have any responsive documents.
+I will plan to be in Miami by around 10:00 on Monday morning, so any time after that is fine.
+Thank you.
+Assistant U.S. Attorney
diff --git a/vision-fixhub/ds9-unparsed-06/4cb47dac0136f972d1d0e78b110d2cc3c490c575694d3e0c0df1ca958eb9f4df.receipt.json b/vision-fixhub/ds9-unparsed-06/4cb47dac0136f972d1d0e78b110d2cc3c490c575694d3e0c0df1ca958eb9f4df.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9050105946a18740eda30fd25c51e9b9b61fd109
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4cb47dac0136f972d1d0e78b110d2cc3c490c575694d3e0c0df1ca958eb9f4df.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "4cb47dac0136f972d1d0e78b110d2cc3c490c575694d3e0c0df1ca958eb9f4df",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "a0e5f5bb0941ee70ec54387d3d67bf40dcfd0108f65869bd29bf1ad80a6d89ae",
+  "output_sha256": "818f47655821bdc5553f5212ab438a595086fd4d54048bf21c3488273434675b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4cc912542472280535f59c6f893230a020089a37a01eb995dbb17e204f66383e.md b/vision-fixhub/ds9-unparsed-06/4cc912542472280535f59c6f893230a020089a37a01eb995dbb17e204f66383e.md
new file mode 100644
index 0000000000000000000000000000000000000000..c100dc336a75e833022917897b6e27d72e59f28d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4cc912542472280535f59c6f893230a020089a37a01eb995dbb17e204f66383e.md
@@ -0,0 +1,2093 @@
+Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 1 of 91
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON
+C.M.A.,
+Plaintiff(s),
+VS.
+JEFFREY EPSTEIN and
+Defendants).
+!
+FIRST AMENDED COMPLAINT
+Parties, Jurisdiction and Venue
+COMES NOW the Plaintiff, C.M.A., and brings this First Amended Complaint
+against the Defendants, JEFFREY EPSTEIN and
+and states as
+follows:
+1.
+This is an action for damages in excess of $75,000.00, exclusive of
+interest and costs.
+2.
+This Complaint is brought under a fictitious name in order to protect the
+identity of the Plaintiff, C.M.A., because this Complaint makes allegation of sexual
+assault and child abuse of a then minor.
+3.
+At all times material to this cause of action, the Plaintiff, C.M.A., was a
+resident of Palm Beach County, Florida.
+
+
+
+4.
+At all times material to this cause of action, the Defendant, JEFFREY
+EPSTEIN, had a residence located in Palm Beach County, Florida.
+5.
+At all times material to this cause of action, the Defendant, JEFFREY
+EPSTEIN, was an adult male, born in 1953.
+This Court has jurisdiction of this action and the claim set forth herein
+pursuant to 18 U.S.C. §2255.
+7.
+district.
+This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a
+substantial part of the events or omissions giving rise to the claim occurred in this
+At all times material, the Defendant, JEFFREY EPSTEIN, owed a duty
+unto Plaintiff, C.M.A., to treat her in a non-negligent manner and to not commit
+intentional or tortious illegal acts against her.
+Factual Allegations
+9.
+Upon information and belief, the Defendant, JEFFREY EPSTEIN, has
+demonstrated a sexual preference and obsession for minor girls. He engaged in a plan,
+scheme, and enterprise in which he gained access to economically disadvantaged
+minor girls, such as Plaintiff, C.M.A., sexually assaulted these girls, and/or coerced
+them to engage in prostitution, and in return gave these girls money.
+10. The Defendant's plan, scheme and enterprise included an elaborate
+system wherein the then minor Plaintiff and other minor girls were brought to the
+2
+
+
+
+Defendant, JEFFREY EPSTEIN'S, residence by the Defendant's employees and
+assistants. When the employees and assistants left the then minor Plaintiff and other
+minor girls alone in a room at the Defendant's mansion, the Defendant, JEFFREY
+EPSTEIN, himself would appear, remove his clothing, and
+He would then perform one or more lewd, lascivious, and
+sexual acts, including, but not limited to,
+Plaintiff's |
+touching of the then minor
+and solicitation and enticement of the then minor Plaintiff
+to engage in s
+I in JEFFREY EPSTEIN'S presence.
+11. The Plaintiff, C.M.A., was the first brought to the Defendant, JEFFREY
+EPSTEIN'S, mansion in late May or early June of 2002, when she was fifteen-years old
+and in middle school.
+12. The Defendant, JEFFREY EPSTEIN, a wealthy financier with a lavish
+home, significant wealth, a network of assistants and employees, used his resources
+and his influence over a vulnerable minor child to engage in a systematic pattern of
+sexually exploitive behavior.
+13.
+Beginning in approximately late May or early June of 2002, and continuing
+until approximately August of 2003, the Defendant coerced and enticed the
+impressionable, vulnerable, and economically deprived then minor Plaintiff to commit
+various acts of sexual misconduct. These acts occurred, on average, one to three times
+per week from late May or early June of 2002 until August of 2003. At a bare minimum,
+3
+
+
+Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009
+
+these acts occurred twice a month from June 2002 until August of 2003. While the
+precise dates these acts occurred are unknown to Plaintiff, including those weeks in
+which no acts occurred, these dates are known by Defendant, JEFFREY EPSTEIN, as
+he is reported to have kept a written log of each and every instance in which he
+engaged in these illegal acts with the then minor Plaintiff, C.M.A. and others. These
+acts included, but were not limited to, fondling and inappropriate and illegal sexual
+touching of the then minor Plaintiff, sexual misconduct and
+of the
+Defendant, JEFFREY EPSTEIN, in the presence of the then minor Plaintiff,
+the then minor Plaintiff to
+in
+JEFFREY EPSTEIN'S presence, and encouraging the then minor Plaintiff to become
+involved in prostitution; Defendant, JEFFREY EPSTEIN, committed numerous criminal
+sexual offenses against the then minor Plaintiff including, but not limited to, sexual
+battery, solicitation of prostitution, procurement of a minor for the purpose of
+prostitution, and lewd and lascivious assaults upon the person of the then minor
+Plaintiff.
+14.
+Defendant, JEFFREY EPSTEIN, used his money, wealth and power to
+unduly and improperly manipulate and influence the then minor Plaintiff.
+15. The acts referenced in paragraphs 9 through 14, committed by Defendant,
+JEFFREY EPSTEIN, against the then minor Plaintiff, C.M.A., were committed in
+violation of numerous criminal State and Federal statutes condemning the sexual
+4
+
+
+Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009
+
+exploitation of minor children, prostitution, sexual performance by a child, lewd and
+lascivious assaults, sexual battery, contributing the delinquency of a minor and other
+crimes, specifically including, but not limited to, those crimes designated in 18 USC
+§2241, §2242, §2243, §2421, and §2423, criminal offenses outlined in Chapter 800 of
+the Federal Codes, as well as those designated in Florida Statutes §796.03, $796.07,
+§796.045, §796.04, §39.01; and §827.04.
+16. The above-described acts took place in Palm Beach County, Florida, at
+the residence of the Defendant, JEFFREY EPSTEIN. Any assertions by the Defendant,
+JEFFREY EPSTEIN, that he was unaware of the age of the then minor Plaintiff are
+belied by his actions and rendered irrelevant by the provisions of applicable Florida
+Statutes concerning the sexual exploitation and abuse of a minor child. The Defendant,
+JEFFREY EPSTEIN, at all times material to this cause of action, knew and should have
+known of the Plaintiff, C.M.A.'s minority.
+17. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County,
+Florida, the Defendant, JEFFREY EPSTEIN, entered pleas of "guilty" to various Florida
+state crimes involving the solicitation of minors for prostitution and the procurement of
+minors for the purpose of prostitution.
+18.
+As a condition of that plea, and in exchange for the Federal Government
+not prosecuting the Defendant, JEFFREY EPSTEIN, for numerous federal offenses,
+Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the
+5
+
+
+Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009
+
+Federal Government to the following: "Any person, who while a minor, was a victim of
+an offense enumerated in Title 18, United States Code, Section 2255, will have the
+same rights to proceed under section 2255 as she would have had, if Mr. Epstein had
+been tried federally and convicted of an enumerated offense. For purposes of
+implementing this paragraph, the United States shall provide Mr. Epstein's attorneys
+with a list of individuals whom it was prepared to name in an indictment as victims of an
+enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision,
+including any authority determining evidentiary burdens if any a Plaintiff must meet,
+shall consider that it is the intent of the parties to place these identified victims in the
+same position as they would have been had Mr. Epstein been convicted at trial. No
+more; no less".
+19. The Defendant, JEFFREY EPSTEIN, is thus estopped by his plea and
+agreement with the Federal Government from denying the acts alleged in this
+Complaint, and must effectively admit liability to the Plaintiff, C.M.A.
+COUNT!
+Cause of Action Pursuant to 18 USC $2255
+May/June 2002
+20.
+The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+6
+
+
+
+21.
+In late May or early June of 2002, C.M.A. was first introduced to
+Defendant, JEFFREY EPSTEIN. C.M.A. was brought to JEFFREY EPSTEIN'S
+residence by a female friend of hers. C.M.A. sat on the couch while the female friend
+took off her own clothes, mounted JEFFREY EPSTEIN who was wearing only a towel
+and lying on a table, and performed a sexual act upon JEFFREY EPSTEIN in the
+presence of C.M.A. In exchange for her participation as an observer of JEFFREY
+EPSTEIN'S lewd and lascivious conduct, C.M.A. was paid $300 by JEFFREY
+EPSTEIN.
+22. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+7
+
+
+
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+23. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+24. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+25. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+8
+
+
+Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009
+
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT !!
+Cause of Action Pursuant to 18 USC $2255
+June 2002- Incident 2
+26. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+27.
+Approximately one week after the first incident, C.M.A. received a
+telephone call from JEFFREY EPSTEIN requesting that she return to his residence. On
+this occasion, JEFFREY EPSTEIN directed C.M.A to
+• and
+land to provide him with a massage. At the conclusion of the massage,
+JEFFREY EPSTEIN ..
+paid C.M.A. $300 for this encounter.
+
+
+Entered on FLSD Docket 02/09/2009 Page 10 of 91
+Case No.: 08-CV-80811-CIV-MARRA JOHNSON
+28.
+As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+29. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+10
+
+
+Entered on FLSD Docket 02/09/2009 Page 11 of 91
+30.
+Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+31. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+11
+
+
+
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT !!!
+Cause of Action Pursuant to 18 USC §2255
+July, 2002 - Incident 1
+32. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+• 33. In July of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence
+at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to undress to her
+underwear and to provide him with a massage. At the conclusion of the massage,
+JEFFREY EPSTEIN
+34. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN,
+additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+12
+
+
+Case 9:08-cv-80811-KAM Document 40 k
+Entered on FLSD Docket 02/09/2009 Page 13 of 91
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+35. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+36. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+37.
+As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+13
+
+
+• Entered on FLSD Docket 02/09/2009 Page 14 of 91
+CASANo. OB CV. B141-CIV-MARRAJOHNSON
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT IV
+Cause of Action Pursuant to 18 USC $2255
+July 2002 - Incident 2
+14
+
+
+Entered on FLSD Docket 02/09/2009 Page 15 of 91
+38.
+The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+39.
+For the second time in July of 2002, C.M.A. again returned to JEFFREY
+EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed
+C.M.A to L
+and to provide him with a massage. Defendant, JEFFREY
+EPSTEIN,
+of the massage, JEFFREY EPSTEIN
+of the then minor C.M.A. At the conclusion
+himself in C.M.A.'s presence.
+JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.
+40. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+15
+
+
+Entered on FLSD Docket 02/09/2009 Page 16 of 91
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+41. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+42. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+43. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering,
+emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+16
+
+
+Entered on FLSD Docket 02/09/2009 Page 17 of 91
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT V
+Cause of Action Pursuant to 18 USC $2255
+August of 2002 - Incident 1
+44. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+45. In August of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S
+residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to
+and to provide him with a massage. Defendant, JEFFREY EPSTEIN,
+of the then minor C.M.A. At the conclusion of the massage,
+JEFFREY EPSTEIN I
+17
+
+
+• Entered on FLSD Docket 02/09/2009 Page 18 of 91
+46.
+As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+47. The Plaintiff, C.M.A.., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+18
+
+
+Entered on FLSD Docket 02/09/2009 Page 19 of 91
+48. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+49. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+19
+
+
+
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT VI
+Cause of Action Pursuant to 18 USC $2255
+August of 2002 - Incident 2
+50. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+51. For the second time in August of 2002, C.M.A. again returned to
+JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN
+directed C.M.A to
+Defendant,
+JEFFREY EPSTEIN,
+of the then minor C.M.A. At the
+conclusion of the massage, JEFFREY EPSTEING
+himself in C.M.A.'s
+presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.
+52. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+20
+
+
+Entered on FLSD Docket 02/09/2009 Page 21 of 91
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+53. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+54. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+55.
+As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+21
+
+
+Entered on FLSD Docket 02/09/2009 Page 22 of 91
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT VII
+Cause of Action Pursuant to 18 USC $2255
+September of 2002 - Incident 1
+56.
+The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+22
+
+
+Entered on FLSD Docket 02/09/2009 Page 23 of 91
+57. In September of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S
+residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully
+and to provide him with a massage. Defendant, JEFFREY EPSTEIN, I
+of the then minor C.M.A. At the conclusion of the massage,
+JEFFREY EPSTEIN
+58. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+23
+
+
+Entered on FLSD Docket 02/09/2009 Page 24 of 91
+59. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+60. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+61. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+24
+
+
+Entered on FLSD Docket 02/09/2009 Page 25 of 91
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT VIII
+Cause of Action Pursuant to 18 USC $2255
+September of 2002 - Incident 2
+62. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+63.
+For the second time in September of 2002, C.M.A. again returned to
+JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN
+directed C.M.A tol
+and to provide him with a massage. Defendant,
+JEFFREY EPSTEIN,
+conclusion of the massage, JEFFREY EPSTEIN
+presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.
+of the then minor C.M.A. At the
+himself in C.M.A.'s
+25
+
+
+Entered on FLSD Docket 02/09/2009 Page 26 of 91
+64. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+65.
+The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+26
+
+
+Entered on FLSD Docket 02/09/2009 Page 27 of 91
+66.
+Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+67. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering,
+emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+27
+
+
+
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT IX
+Cause of Action Pursuant to 18 USC $2255
+October of 2002 - Incident 1
+68. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+69.
+In October of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S
+residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to
+and to provide him with a massage. Defendant, JEFFREY EPSTEIN,
+of the then minor C.M.A. At the conclusion of the massage,
+JEFFREY EPSTEIN
+70. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+28
+
+
+Entered on FLSD Docket 02/09/2009 Page 29 of 91
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+71. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+72. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+73.
+As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+29
+
+
+Entered on FLSD Docket 02/09/2009 Page 30 of 91
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,.
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT X
+Cause of Action Pursuant to 18 USC §2255
+October of 2002 - Incident 2
+30
+
+
+Entered on FLSD Docket 02/09/2009 Page 31 of 91
+74. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+75. For the second time in October of 2002, C.M.A. again returned to
+JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN
+directed C.M.A tol
+and to provide him with a massage. Defendant,
+JEFFREY EPSTEIN,
+of the then minor C.M.A. At the
+conclusion of the massage, JEFFREY EPSTEIN
+himself in C.M.A.'s
+presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.
+76. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+31
+
+
+
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+77. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+78. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+79. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+32
+
+
+Entered on FLSD Docket 02/09/2009 Page 33 of 91
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XI
+Cause of Action Pursuant to 18 USC $2255
+November of 2002 - Incident 1
+80. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+81.
+In November of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S
+residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to
+and to provide him with a massage. Defendant, JEFFREY EPSTEIN,
+of the then minor C.M.A. At the conclusion of the massage,
+JEFFREY EPSTEIN
+33
+
+
+• Entered on FLSD Docket 02/09/2009 Page 34 of 91
+82. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+83. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+34
+
+
+
+84.
+Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+85. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A..,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+35
+
+
+
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XII
+Cause of Action Pursuant to 18 USC §2255
+November of 2002 - Incident 2
+86. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+87. For the second time in November of 2002, C.M.A. again returned to
+JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN
+directed C.M.A to
+and to provide him with a massage. Defendant,
+JEFFREY EPSTEIN
+of the then minor C.M.A. At the
+conclusion of the massage, JEFFREY EPSTEIN
+himself in C.M.A.'s
+presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.
+88.
+As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+36
+
+
+Entered on FLSD Docket 02/09/2009 Page 37 of 91
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+89. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+90. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+91. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+37
+
+
+• Entered on FLSD Docket 02/09/2009 Page 38 of 91
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., Will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A.., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XIII
+Cause of Action Pursuant to 18 USC §2255
+December of 2002 - Incident 1
+92.
+The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+38
+
+
+Entered on FLSD Docket 02/09/2009 Page 39 of 91
+93.
+In December of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S
+residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A t.....,
+and to provide him with a massage. Defendant, JEFFREY EPSTEIN, I
+of the then minor C.M.A. At the conclusion of the massage,
+JEFFREY EPSTEIN
+himself. in C.M.A.'s presence. JEFFREY EPSTEIN
+94. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+39
+
+
+Entered on FLSD Docket 02/09/2009 Page 40 of 91
+95.
+The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+96. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+97. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+40
+
+
+Entered on FLSD Docket 02/09/2009 Page 41 of 91
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XIV
+Cause of Action Pursuant to 18 USC $2255
+December of 2002 - Incident 2
+98. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+99. For the second time in December of 2002, C.M.A. again returned to
+JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN
+directed C.M.A to fl
+and to provide him with a massage. Defendant,
+JEFFREY EPSTEIN,
+of the then minor C.M.A. At the
+conclusion of the massage, JEFFREY EPSTEIN
+himself in C.M.A.'s
+presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.
+41
+
+
+Entered on FLSD Docket 02/09/2009 Page 42 of 91
+100. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+101. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant,
+, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+42
+
+
+
+102. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+103. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+43
+
+
+
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XV
+Cause of Action Pursuant to 18 USC $2255
+January of 2003 - Incident 1
+104. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+105. In January of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S
+residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A tol
+and to provide him with a massage. Defendant, JEFFREY EPSTEIN,
+pf the-then minor C.M.A. At the conclusion of the massage,
+JEFFREY EPSTEIN
+106. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+44
+
+
+Entered on FLSD Docket 02/09/2009 Page 45 of 91
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+107. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+108. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+109. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+45
+
+
+• Entered on FLSD Docket 02/09/2009 Page 46 of 91
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XVI
+Cause of Action Pursuant to 18 USC $2255
+January of 2003-Incident 2
+110. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+46
+
+
+Entered on FLSD Docket 02/09/2009 Page 47 of 91
+111. For the second time in January of 2003, C.M.A. again returned to
+JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN
+directed C.M.A to
+and to provide him with a massage. Defendant,
+JEFFREY EPSTEIN,
+and buttocks of the then minor C.M.A. At the
+conclusion of the massage, JEFFREY EPSTEIN
+himself in C.M.A.'s
+presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.
+112. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+47
+
+
+Entered on FLSD Docket 02/09/2009 Page 48 of 91
+113. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+114. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+115. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+48
+
+
+Entered on FLSD Docket 02/09/2009 Page 49 of 91
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XVII
+Cause of Action Pursuant to 18 USC $2255
+February of 2003 - Incident 1
+116. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+117. In February of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S
+residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A totally
+and to provide him with a massage. Defendant, JEFFREY EPSTEIN,
+of the then minor C.M.A. At the conclusion of the massage,
+JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN
+49
+
+
+• Document 40
+Entered on FLSD Docket 02/09/2009 Page 50 of 91
+118. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+119. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+50
+
+
+
+C.M.A. VS. Epstein, et al.
+120. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+121. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+51
+
+
+
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XVIII
+Cause of Action Pursuant to 18 USC $2255
+February of 2003 - Incident 2
+122. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+123. For the second time in February of 2003, C.M.A. again returned to
+JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN
+directed C.M.A to
+and to provide him with a massage. Defendant,
+JEFFREY EPSTEIN
+of the then minor C.M.A. At the
+conclusion of the massage, JEFFREY EPSTEIN
+himself in C.M.A.'s
+presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.
+124. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+52
+
+
+• Entered on FLSD Docket 02/09/2009 Page 53 of 91
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+125. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+126. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+127. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+53
+
+
+• Entered on FLSD Docket 02/09/2009 Page 54 of 91
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XIX
+Cause of Action Pursuant to 18 USC $2255
+March of 2003 - Incident 1
+128. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+54
+
+
+Entered on FLSD Docket 02/09/2009 Page 55 of 91
+129. In March of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S
+residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to .....)
+coland to provide him with a massage. Defendant, JEFFREY EPSTEIN, L
+JEFFREY EPSTEIN
+lof the then minor C.M.A. At the conclusion of the massage,
+130. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+55
+
+
+Jase 9:08-CV-80811-KAM Document 40
+Entered on FLSD Docket 02/09/2009 Page 56 of 91
+131. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+132. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+133. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+56
+
+
+Entered on FLSD Docket 02/09/2009 Page 57 of 91
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XX
+Cause of Action Pursuant to 18 USC $2255
+March of 2003 - Incident 2
+134. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+135. For the second time in March of 2003, C.M.A. again returned to JEFFREY
+EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed
+C.M.A to
+Land to provide him with a massage. Defendant, JEFFREY
+EPSTEIN,
+of the then minor C.M.A. At the conclusion
+of the massage, JEFFREY EPSTEIN
+himself in C.M.A.'s presence.
+JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.
+57
+
+
+Entered on FLSD Docket 02/09/2009 Page 58 of 91
+136. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+137. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant,
+JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+58
+
+
+Entered on FLSD Docket 02/09/2009 Page 59 of 91
+138. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+139. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+59
+
+
+
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XXI
+Cause of Action Pursuant to 18 USC §2255
+April of 2003 - Incident 1
+140. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+141. In April of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence
+at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to
+and to provide him with a massage. Defendant, JEFFREY EPSTEIN,
+of the then minor C.M.A. At the conclusion of the massage,
+JEFFREY EPSTEIN I
+142. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+60
+
+
+Entered on FLSD Docket 02/09/2009 Page 61 of 91
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+143. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+144. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+145. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+61
+
+
+• Entered on FLSD Docket 02/09/2009 Page 62 of 91
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., Will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XXII
+Cause of Action Pursuant to 18 USC §2255
+April of 2003-Incident 2
+146. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+62
+
+
+• Entered on FLSD Docket 02/09/2009 Page 63 of 91
+147. For the second time in April of 2003, C.M.A. again returned to JEFFREY
+EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed
+EPSTEIN,
+C.M.A to-any amaroos and to provide him with a massage.
+Defendant, JEFFREY
+of the then minor C.M.A. At the conclusion
+himself in C.M.A.'s presence.
+of the massage, JEFFREY EPSTEIN
+JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.
+148. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+63
+
+
+Case 9:08-cv-80811-KAM Document 40 k
+Entered on FLSD Docket 02/09/2009 Page 64 of 91
+149. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+150. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+151. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+64
+
+
+Entered on FLSD Docket 02/09/2009 Page 65 of 91
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XXIII
+Cause of Action Pursuant to 18 USC $2255
+May of 2003 - Incident 1
+152. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+153. In May of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence
+at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to l
+and to provide him with a massage. Defendant, JEFFREY EPSTEIN,
+of the then minor C.M.A. At the conclusion of the massage,
+JEFFREY EPSTEIN
+65
+
+
+Entered on FLSD Docket 02/09/2009 Page 66 of 91
+154. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+155. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+66
+
+
+Entered on FLSD Docket 02/09/2009 Page 67 of 91
+156.
+Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+157. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+67
+
+
+
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XXIV
+Cause of Action Pursuant to 18 USC §2255
+May of 2003 - Incident 2
+158. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+159. For the second time in May of 2003, C.M.A. again returned to JEFFREY
+EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed
+C.M.A to
+and to provide him with a massage. Defendant, JEFFREY
+EPSTEIN, tontica ine bitadio ana pausons of the then minor C.M.A. At the conclusion
+of the massage, JEFFREY EPSTEIN
+himself in C.M.A.'s presence.
+JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.
+160. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+68
+
+
+Entered on FLSD Docket 02/09/2009 Page 69 of 91
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+161. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+162. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+163. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+69
+
+
+• Entered on FLSD Docket 02/09/2009 Page 70 of 91
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XXV
+Cause of Action Pursuant to 18 USC $2255
+June of 2003 - Incident 1
+164. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+70
+
+
+• Entered on FLSD Docket 02/09/2009 Page 71 of 91
+165. In June of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S
+residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to
+anarcoo and to provide him with a massage. Defendant, JEFFREY EPSTEIN,
+of the then minor C.M.A. At the conclusion of the massage,
+JEFFREY EPSTEIN
+166. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+71
+
+
+Entered on FLSD Docket 02/09/2009 Page 72 of 91
+167. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+168. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+169. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+
+
+Entered on FLSD Docket 02/09/2009 Page 73 of 91
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XXVI
+Cause of Action Pursuant to 18 USC $2255
+June of 2003 - Incident 2
+170. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+171. For the second time in June of 2003, C.M.A. again returned to JEFFREY
+EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed
+C.M.A to
+and to provide him with a massage. Defendant, JEFFREY
+EPSTEIN,
+of the then minor C.M.A. At the conclusion
+of the massage, JEFFREY EPSTEIN
+himself in C.M.A.'s presence.
+JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.
+73
+
+
+Entered on FLSD Docket 02/09/2009 Page 74 of 91
+Case No.: 08-CV-80811-CIV-MARRAJJOHNSON
+172. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+173. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+74
+
+
+Entered on FLSD Docket 02/09/2009 Page 75 of 91
+174. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+175. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., wili in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+75
+
+
+
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XXVII
+Cause of Action Pursuant to 18 USC $2255
+July of 2003 - Incident 1
+176. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+177. In July of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence
+at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to
+and to provide him with a massage. Defendant, JEFFREY EPSTEIN,
+of the then minor C.M.A. At the conclusion of the massage,
+JEFFREY EPSTEIN macinawa himself in C.M.A.'s presence. JEFFREY EPSTEIN
+178. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+76
+
+
+Entered on FLSD Docket 02/09/2009 Page 77 of 91
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+179. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+180. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+181. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+77
+
+
+• Entered on FLSD Docket 02/09/2009 Page 78 of 91
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A.., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XXVIII
+Cause of Action Pursuant to 18 USC $2255
+July of 2003 - Incident 2
+182. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+
+
+Entered on FLSD Docket 02/09/2009 Page 79 of 91
+183. For the second time in July of 2003, C.M.A. again returned to JEFFREY
+EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed
+C.M.A to
+and to provide him with a massage. Defendant, JEFFREY
+EPSTEIN,
+of the then minor C.M.A. At the conclusion
+of the massage, JEFFREY EPSTEIN
+himself in C.M.A.'s presence.
+JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.
+184. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+79
+
+
+Entered on FLSD Docket 02/09/2009 Page 80 of 91
+185. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+186. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+187. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering,
+emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+80
+
+
+Entered on FLSD Docket 02/09/2009 Page 81 of 91
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XXIX
+Cause of Action Pursuant to 18 USC $2255
+August of 2003 - Incident 1
+188. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+189. In August of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S
+residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to
+and to provide him with a massage. Defendant, JEFFREY EPSTEIN._
+of the then minor C.M.A. At the conclusion of the massage,
+JEFFREY EPSTEIN
+
+
+Entered on FLSD Docket 02/09/2009 Page 82 of 91
+190. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+191. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+82
+
+
+Entered on FLSD Docket 02/09/2009 Page 83 of 91
+192. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+193. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+83
+
+
+
+Case No.: 08-CV-80811-CIV-MARRAJJOHNSON
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XXX
+Cause of Action Pursuant to 18 USC §2255
+August of 2003 - Incident 2
+194. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
+195. For the second time in August of 2003, C.M.A. again returned to
+JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN
+directed C.M.A to
+and to provide him with a massage. Defendant,
+JEFFREY EPSTEIN
+of the then minor C.M.A. At the
+conclusion of the massage, JEFFREY EPSTEIN,
+himself in C.M.A.'s
+presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.
+196. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and
+in exchange for the Federal Government not prosecuting the Defendant for numerous
+federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an
+agreement with the Federal Government to the following: "Any person, who while a
+minor, was a victim of an offense enumerated in Title 18, United States Code, Section
+2255, will have the same rights to proceed under section 2255 as she would have had,
+84
+
+
+• Entered on FLSD Docket 02/09/2009 Page 85 of 91
+Case No.: 08-CV-80811-CIV-MARRAIJOHNSON
+if Mr. Epstein had been tried federally and convicted of an enumerated offense. For
+purposes of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an indictment as
+victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this
+provision, including any authority determining evidentiary burdens if any a Plaintiff must
+meet, shall consider that it is the intent of the parties to place these identified victims in
+the same position as they would have been had Mr. Epstein been convicted at trial. No
+197. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in
+Title 18, United States Code, Section 2255, and as such asserts a cause of action
+against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United
+States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the
+198. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the
+same position as if he had been tried and convicted of the sexual offenses committed
+against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the
+Plaintiff, C.M.A.
+199. As a direct and proximate result of the offenses enumerated in Title 18,
+United States Code, Section 2255, being committed against the then minor Plaintiff,
+C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
+85
+
+
+• Entered on FLSD Docket 02/09/2009 Page 86 of 91
+suffering, emotional distress, psychological trauma, mental anguish, humiliation,
+embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other
+damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and
+coercing her into a perverse and unconventional way of life for a minor. The then minor
+Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in
+the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A..,
+has suffered a loss of income, a loss of the capacity to earn income in the future, and a
+loss of the capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A.., will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XXXI
+Sexual Battery
+200. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 199
+86
+
+
+Entered on FLSD Docket 02/09/2009 Page 87 of 91
+201. Between late May or early June of 2002 and August of 2003, Defendant,
+JEFFERY EPSTEIN, engaged in dozens of illegal and depraved sexual acts against
+Plaintiff, C.M.A.
+202. As described more fully in the above paragraphs, Defendant, JEFFERY
+EPSTEIN, intentionally inflicted harmful and/or offensive sexual contact on the person of
+C.M.A.
+203. Defendant, JEFFREY EPSTEIN'S, tortuous commission of sexual battery
+upon C.M.A. were done willfully and maliciously.
+204. As a direct and proximate result of JEFFREY EPSTEIN'S battery on
+C.M.A., she has suffered and will continue to suffer severe and permanent traumatic
+injuries, including mental, psychological and emotional damages.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
+provided by law, punitive damages, attorney's fees, costs, and such other and further
+relief as this Court deems just and proper, and hereby demands trial by jury on all
+issues triable as of right by a jury.
+COUNT XXXII
+Conspiracy to Commit Tortious Assault Against Defendant,
+205. Plaintiff incorporates into this count the allegations of paragraphs 1
+through 19.
+87
+
+
+• Entered on FLSD Docket 02/09/2009 Page 88 of 91
+206. Defendant,
+is one of Defendant, JEFFREY EPSTEIN'S,
+employees/assistants referenced in paragraph 12 above.
+Defendant, JEFFREY
+EPSTEIN, Defendant,
+and others reached an agreement between
+themselves for the purpose of allowing Defendant, JEFFREY EPSTEIN, to commit the
+illegal acts described above upon Plaintiff, C.M.A.
+207. Many of the instances of illegal sexual conduct committed by Defendant,
+JEFFREY EPSTEIN, described above were perpetrated with the assistance, support,
+and facilitation by Defendant,
+In fact, Defendant,
+aided, assisted, and/or abetted Defendant, JEFFREY EPSTEIN, in his organized
+scheme and plan to sexually assault, and/or coerce Plaintiff, C.M.A., to engage in
+prostitution.
+208. Defendant,
+1, would often arrange times for C.M.A. to
+come to Defendant, JEFFREY EPSTEIN'S, residence, would escort C.M.A. to the room
+where Defendant, JEFFREY EPSTEIN, was waiting, would deliver cash from
+Defendant, JEFFREY EPSTEIN, at the conclusion of a session, and took nude
+photographs of Plaintiffs, C.M.A., for Defendant, JEFFREY EPSTEIN.
+209. As a direct and proximate result of Defendant,
+participation in the aforementioned conspiracy, Plaintiff, C.M.A, has suffered and will
+continue to suffer damages, including, but not limited to, pain, suffering, emotional
+distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
+88
+
+
+Entered on FLSD Docket 02/09/2009 Page 89 of 91
+self-esteem, loss of dignity, invasion of personal privacy and other damages associated
+with JEFFREY EPSTEIN'S controlling , manipulating, and coercing C.M.A. into a
+perverse and unconventional way of life for a minor. The then minor Plaintiff incurred
+medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer
+additional medical and psychological expenses. The Plaintiff, C.M.A., has suffered a
+loss of income, a loss of the capacity to earn income in the future, and a loss of the
+capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, C.M.A.,
+will continue to suffer these losses in the future.
+WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
+for compensatory damages of at least the minimum amount provided
+by law, punitive damages, attorney's fees, costs, and such other and further relief as
+this Court deems just and proper, and hereby demands trial by jury on all issues triable
+as of right by a jury.
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on the 9th day of February, 2009, I electronically filed
+the foregoing with the Clerk of the Court by using CM/ECF system, which will send a
+notice of electronic filing to all counsel of record on the attached service list.
+89
+
+
+
+
+Is/Jack P. Hill
+Jack Scarola
+Florida Bar No.: 169440
+Jack P. Hill
+Florida Bar No.: 0547808
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+West Palm Beach, Florida 33409
+Attorneys for Plaintiffs)
+90
+
+
+Entered on FLSD Docket 02/09/2009 Page 91 of 91
+.M.A. vs. Epstein, et a
+Case No.: 08-CV-80811-CIV-MARRA/JOHNSO
+
+COUNSEL LIST
+Richard H. Willits, Esquire
+Richard H. Willits, P.A.
+Lake Worth, FL 33461
+Robert Critton, Esquire
+Burman Critton Luttier & Coleman LLP
+West Palm Beach, FL KK454
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+West Palm Beach, FL 3340T
+Bruce E. Reinhart, Esquire
+Bruce E. Reinhart, P.A.
+e
+Suite 1400
+West Palm Beach. FL. 33401
+91
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/4cc912542472280535f59c6f893230a020089a37a01eb995dbb17e204f66383e.receipt.json b/vision-fixhub/ds9-unparsed-06/4cc912542472280535f59c6f893230a020089a37a01eb995dbb17e204f66383e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..8b355ae46ad64a9d02f4ab3798a9748ee6f40fd4
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4cc912542472280535f59c6f893230a020089a37a01eb995dbb17e204f66383e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -15551,
+  "dataset": "marble-joined",
+  "doc_id": "4cc912542472280535f59c6f893230a020089a37a01eb995dbb17e204f66383e",
+  "engine": "marble-apple-vision",
+  "event_count": 117,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "0c962fbbd76186e493a0cebf1a0269bd1c7f68ba660b9e7a4c20bcd17db3d18a",
+  "output_sha256": "dab9e169c04a06ceec50cebbff0be0c26ae51d9231be1e89ebe4755c3cabbf35",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4cf2f12d35917747aa00a8e28e94f2363a45b802be6a50b74335bdf858f95184.md b/vision-fixhub/ds9-unparsed-06/4cf2f12d35917747aa00a8e28e94f2363a45b802be6a50b74335bdf858f95184.md
new file mode 100644
index 0000000000000000000000000000000000000000..7953ff5962f8978306ebd5d504c5cb8b7679628b
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4cf2f12d35917747aa00a8e28e94f2363a45b802be6a50b74335bdf858f95184.md
@@ -0,0 +1,2519 @@
+Questions or Changes?
+attwireless.com
+: ToliFe 1 866 293-4634
+611 from your wireless phone
+TTY users - 1 866 4-AWS-TTY
+SUMMARY OF MONTHLY CHARGES FOR ACCOUNT 0031035751
+Previous
+Payments
+Balance
+Received
+323.87
+0.00
+Account
+Adjustments
+0.00
+Balance
+Forward
+323.87
+Your billing cycle ended on September 14, 2004
+Current Monthly Charges
+Subscriber Adjustments
+Monthly Service
+Monthly Usage
+Charges
+Credits
+Taxes, Surcharges & Regulatory Fees
+Total Current Monthly Charges DUE UPON RECEIPT
+TOTAL AMOUNT DUE
+Date of Invoice: September 19, 2004
+Current Monthly
+Charges
+136.53
+Total
+Amount Due
+460.40
+0.00
+59.96
+53.50
+0.00
+0.00
+23.07
+136.53
+460.40
+PLAY JUMBLE, THE GREAT SCRAMBLED WORD GAME, ON YOUR
+PHONE FOR FREE!*
+DOWNLOAD TODAY AND ENJOY 5 FREE* PLAY SESSIONS.
+AFTER YOUR 5 FREE PLAY SESSIONS, YOU CAN SUBSCRIBE FOR
+JUST $2.99/MONTH AND ENJOY OVER 4,000 MIND-BENDING
+PUZZLES, LIVE HIGH-SCORE COMPETITIONS, AND MORE.
+VISIT GAMEROOM.ATTWIRELESS.COM FOR MORE INFO
+*STANDARD DATA CHARGES APPLY FOR ALL DOWNLOADS.
+AT&T WIRELESS APPRECIATES YOUR BUSINESS
+Please Return This Portion With Your Payment.
+it he General terms and Contions for wires sere
+Account Name: MARTIN GOLICK
+see reverse - signature requires
+Date Due
+UPON RECEIPT
+Note:
+=>
+We Print on
+Front and Back
+Service # 5613797824
+Account # 0031035751
+Total
+Amount Due
+460.40
+Chack here for tha
+Amount
+Paid
+#BWNHNGB
+#0000000310357512# w
+2005763 02AT0.517 "AUTO AUTO TOO 091433411.5.42.02.1034.0000
+AT&T WIRELESS
+PO BOX 8229
+AURORA IL 60572-8229
+
+
+
+Recurring Electronic Fund Transfer (REFT): To enroll: sign below, check the REFT box on the reverse side and
+remit with this month's payment. Keep paying your bill until your statement indicates "Do Not Pay". REFT
+Agreement: I authorize my financial institution to deduct the amount of my monthly wireless phone bill from the
+account associated with the enclosed check and remit payment to AT&T Wireless. This authority will be effective
+until I notify AT&T Wireless to terminate it. I agree that I may be assessed a service charge (up to $20) or late fee
+or both if a payment is returned by my bank. For more information visit attwireless.com/ocs or call 1 866 293-4634.
+Please keep a copy of the form below and this REFT Agreement for your records or retain a copy of the blank form
+from next month's invoice.
+Questions? We can help: AT&T Wireless appreciates your business and welcomes the opportunity to assist you.
+As part of our commitment to you, we are always adding new calling plans and promotions to match your individual
+needs. Visit our website at attwireless.com or contact Customer Care by dialing 611 from your wireless phone or 1
+866 293-4634. ¿ Sabías que también ofrecemos servicio al cliente en tu idioma? Marca 611 desde tu teléfono
+inalámbrico ó 1 866 293 4634 desde cualquier teléfono y oprime el *.
+Driving Wireless Safety: Your wireless phone gives you the freedom and flexibility to stay in touch when you
+travel, but don't let a phone call distract you from driving safely. Use hands-free device if allowed or required by
+law. Call Carefully, Arrive Safely.
+AT&T Wireless Processing Fees: Accounts suspended for non-payment will be subject to a $25 reactivation fee
+per line and may be assessed a security deposit prior to reinstatement. Checks returned for non-sufficient funds will
+be charged up to a $20.00 fee.
+Local Tax: Local taxes are based on local government boundaries, the address information you provide for your
+may also use the form below to notify us of any change to your taxing address. Thank you for your cooperation.
+Early Termination Fee (ETF): If you cancel service before your contract end date (including if you switch your
+wireless number to another carrier), you will be charged an Early Termination Fee of up to $200.
+Please Send Correspondence To:
+AT&T Wireless Next Generation Correspondence
+P.O. Box 68056
+Anaheim Hills, CA 92817-8056
+2005763.000014551.7
+count ame and ranse an espires clearly and check the box on the reverse side. Please contact Customer Care to change the
+Name and transfer Financial Responsibility.
+New Billing Address
+City
+State
+Zip
+Home Phone (
+Work Phone (.
+If your billing address is NOT your Tax Address*, please enter the Tax Address below. (Multi-line accounts should attach a list of each wireless number
+and the respective Tax Address.)
+New Tax Address*
+Wireless Number (
+City
+State
+Zip
+Inder Federal laws, your Tax Address must be: your primary place of use, your residential or business address, and located within AT&T Wireless
+ensed service area. Non-business customers on AT&T Digital One Rate, Regional Advantage or Shared Advantage plans must use their resident
+address as their tax address.
+Recurring Electronic Fund Transfer (REFT) Enrollment. Please read the agreement on the top portion of this page, sign below and check
+the "REFT Registration" box on the reverse side.
+Financial Account Holder Signature
+6.1 - 3G
+• • I do not wish to receive email notlication of special ollers avallable to AT&T Wireless customers.
+
+
+
+APPLY NOW FOR THE AT&T UNIVERSAL CARD!
+CALL 1-800-426-3430 TODAY!
+*ENJOY A GREAT LOW APR ON BALANCE TRANSFERS
+*OPTIONS TO ENROLL IN CASH BACK OR REWARDS PROGRAM
+*ALL CARDMEMBERS ENJOY SPECIAL CALLING BENEFITS
+*NO ANNUAL FEE CREDIT CARD
+ACCOUNT DETAILS
+Current Subscriber Monthly Charges and Credits
+Subscriber Number
+Subscriber Name
+
+Total Current Subscriber Monthly Charges and Credits
+Total Current Monthly Charges
+SUMMARY OF CURRENT ACTIVITY
+Monthly Service Charges
+Item Description
+1 CALL WAITING
+2 AT&T TEXT MESSAGING
+3 CALLER ID
+4 WORLDCONNECT
+5 COM EOP 1.99EW/3.00INS $4.99
+6 AT&T VOICEMAIL
+7 DETAIL BILLING
+8 $39.99 CHARTER OFFER
+9 1000 NIGHT AND WEEKEND MINUTES
+10 CALL FORWARDING
+11 THREE WAY CALLING
+Total Monthly Service Charges
+Service Dates
+08/15/04 - 09/14/04
+08/15/04 - 09/14/04
+08/15/04 - 09/14/04
+08/15/04 - 09/14/04
+08/15/04 - 09/14/04
+08/15/04 - 09/14/04
+08/15/04 - 09/14/04
+08/15/04 - 09/14/04
+08/15/04 - 09/14/04
+08/15/04 - 09/14/04
+08/15/04 - 09/14/04
+Monthly Usage Charges
+Item Description
+1 500 ADD'L ANYTME MIN
+2 MESSAGE RETRIEVAL
+3 1000 NIGHT/KEND MIN
+4 100 INCL. MSGS SENT
+5 CALL WAITING
+6 DROP CALL CREDIT
+7 INCLUDED MINUTES
+3 411 INFO
+9 INCL. IN PLAN DATA
+136.53
+136.53
+136.53
+0.00
+4.99
+0.00
+0.00
+4.99
+0.00
+0.00
+39.99
+9.99
+0.00
+0.00
+59.96
+0.00
+0.00
+0.00
+0.00
+0.00
+0.00
+0.00
+6.00
+0.00
+
+SUMMARY OF CURRENT ACTIVITY - CONTINUED
+Monthly Usage Charges - Continued
+Item Description
+10 CALL COMPLETION
+11 ADDITIONAL MINUTES
+Total Monthly Usage Charges
+1,024 Kilobytes (KB) = 1 Megabyte (MB)
+Onty Used
+1 EV
+90 MIll
+Taxes, Surcharges and Regulatory Fees
+Item Description
+1 UNIVERSAL CONNECTIVITY CHARGE
+2 SALES TAX
+•STATE COMM SERVICE TA.
+• LOCAL COMM SERVICE TA'
+5 COUNTY 911 TAX
+6 FEDERAL TAX
+Total Taxes, Surcharges and Regulatory Fees
+TOTAL CHARGES FOR (561)379-7824
+DETAIL OF CURRENT ACTIVITY
+VOICE USAGE FOR (561)379-7824
+Item Date Time Called
+1 08/09 01:42P
+2 08/09 04:04P (954)559-9183
+08/10 09:54A (561 792-371
+08/10 10:46A (561/379-78:
+Calls To
+HOLLYWOOD FL
+WALMBEACH FL
+8 08/18 19S8A (800)742-9698
+3 08/10 02:17P (561379-7824
+18 08/13 07 36P (561714-5714
+11 08/13 07:59P
+(561 596-3561
+WPALMBEACH FL
+13 08/13 08:01P 581715-6303
+661)715-630:
+14 08/13 08:02P (561)541-6819
+5 08/13 10:34
+5 08/13 11:13P (561)379-78
+17 08/13 11:15P (561)385-0480
+18 08/13 11:36P
+19 08/14 01:34P
+20 08/15 12:15A (561)596-356
+21
+08/15 12:59A
+GENESS
+3/15 01:29
+3/15 01:35A (561)596-356
+08/15 01:39A
+8/15 02:09
+11511-46
+08/15 11:50A
+0813 12118 (5611596-3561
+88
+07230
+(561 309-8686
+WPALMBEACH FL
+COMIN
+/PALMBEACH B
+WPALMBEACH FL
+COMIN
+PALMBEACH I
+ICOMIN
+/PALMBEACH FL
+COMING
+WALMBEACH FL
+ALMREACH FL
+COMIN
+Qnty
+Used Rate Description
+2MIN I
+500 ADD'L ANYTME MIN
+1 MIN
+00 ADD'L A
+1 MIN
+2 MIN
+2MIN
+MIl
+1 MIN
+2 MIN
+3 MIN
+0.00
+47.50
+53.50
+2.99
+0.30
+10.23
+5.83
+0.50
+23.07
+136.53
+
+
+
+
+
+Called
+Item Date Time
+32 08/15 01-24P
+13 08/15 01-388 561/596-3560
+35
+08/15 01-478
+36 08/15 03:45P (561)715-6303
+37 08/15 06:07P 561379-7824
+38 08/15 06:14P
+12 0815 01:09P (561)301-2576
+43 08/15 11:33P (561|385-0480
+44 08/15 11:34P (561)379-7824
+45 08/16 12:16A (561)596-3561
+16 08/16 07:05A
+08/16 11:22A (561)596-3561
+
+15611714-2981
+
+31930-3439
+-3459
+)379-7824
+
+
+8000040393$
+:39P
+:40P
+(561)236-3299
+(561)385-0480
+1385-0480
+1596-
+6
+-8943
+(561)596-8943
+56117
+793-
+-7230
+-7230
+-2974
+(561)379-7824
+• 08/10
+10:43P
+10:51P
+(5811596 3561
+08/17 07:05A
+08/17 09:21A
+• (561)379-7824
+08/17 09:28A
+0556656665:
+Calls To
+DELRAY BCH FL
+WPALMBEACH FL
+COMIN
+COMIN
+COMIN
+(PALMBEACH R
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+COMIN
+EACH FI
+WPALMBEA
+WPALMBEACH
+WPALMBEACH FL
+VP
+Qnty
+Used
+Rate Description
+1 MIN
+1000 NIGHT/WKEND MIN
+1 MIN
+1000 NIGHT/KEND MIN
+1 MIN
+3 MIN
+1 MIN
+MIr
+EV
+2MIN
+1000 NIGHT/WKEND
+MESSAGE RETREA
+1000 NIGHT/WKEND
+1 MIN
+I MIN
+1 MIN
+1 MIN
+1 MIN
+3MIN
+2MIN
+1 MIN
+1 MIN
+TENT
+1 MIN
+1 MIN
+1 MIN
+2MIN
+1 MI
+1 EVT
+DOO N
+1000 NIGHT/KEND
+00 NIGHT/WKEND
+COCAGE RETRIEV
+1000 NIGHT/WKEND MIN
+888888888883m8888888888388833838383378888888888
+
+Onty
+Item Date Time Called
+Calls To
+Used Rate Description
+93 08/17 05:55P (917)855-3363
+NEW YORK NY
+1 MIN
+500 ADD'L ANYTME MIN
+94 08/17 06:50P
+95 08117 0651P
+1 MIN
+500 ADD'L ANYTME MIN
+JD ADD'L ANYIM
+97 08/17 07:06P (561)596-3561
+WPALMBEACH FL
+6MIN
+O ADD'L ANYTME M
+500 ADD'L ANYTME MIN
+98 08/17 07:10P
+500 ADD'L ANYTME MIN
+VAITING
+99 08/17 07:31P (561)792-6375
+WPALMBEACH FL
+3 MIN
+500 ADD'L ANYTME MIN
+D 08/17 07:34
+| 08/17 07:38
+11801-35
+1 506.05
+WPALMBEACH FL
+183 08/17 08:58P (561)801-3590
+AMIN
+00 A
+1 MIN
+1000 NIGHT/WKEND MIN
+105 08/17 08:24P (581)596-3561
+106 08/17 09:27P (561|596-3561
+WPALMBEACH FI
+IMIN
+1 MIN
+1000 NIGHT/WEND MIN
+107 08/17 09:27P (561)379-7824
+WPALMBEACH FL
+1000
+NIGH
+T/WKEND
+
+
+0000
+
+889
+
+98888
+0 00 0 0000 0000 00 000000
+
+
+
+2:08P
+1596-
+- 3561
+(561)379.
+7824
+(561)798-8570
+(561)
+379
+-782
+(56
+i1)722.
+22
+-8423
+(561)723-8702
+(561)385-0480
+FAI
+NCOM
+MPAL
+
+WPALMBEACH FL
+NPALMBEACH F
+MPALMRFACH F
+WPALMBEACH FL
+WPALMBEACH FL
+PALMBEACH
+COMIN
+NCOMING
+NCOMING
+NCOMING
+NPALMBEACH F
+WPALMBEACH FL
+WPALMBEACH FL
+OD ADD'!
+ANYTME
+1MIN
+2MIN
+1 MIN
+1EVT
+22
+VYTME N
+ANYTME
+500 ABB'L ANVIME
+00 AD
+ANYT
+CALL WAITING
+
+
+
+Item Date Time
+Called
+150 08/19 12:33P (561)379-7824
+Calls To
+WPALMBEACH FL
+08/19 12:358
+320819 15:078
+1581 308920
+153 08/19 12:37P (561)202-7395
+155 08/1813.32P 661307:2298
+156 08/19 12:45P (561)383-5513
+138 08/18 12:19P
+19P (917835-3363
+158 09/18 1322P 261317-2428
+160 08/19 1
+161 08/19 01:00P (561)722-8423
+162 08/19
+165 08/19 81:09P (561)818-3331
+164 08/19 01:19P (561)793-7230
+165 08/19 01:26P
+166 08/19 01:38P (561 818-3331
+167 08/19 01:48P (561|644-6565
+165 08/1981:59P (561)317-2428
+08/19
+88
+172
+173
+08
+·/19
+08/
+02
+19
+:21P
+(561)715-6303
+02:22P
+
+
+
+
+$300.98
+
+200
+08/19 03:58P
+
+
+
+S66 0000868668
+Qnty
+Used Rate Description
+1 MIN
+500 ADD'L ANYTME MIN
+1 EVT
+MESSAGE RETRIEVAL
+1 MIN
+JD ADD'L ANYIM
+O ADD'L ANYT
+WPALMBEACH FL
+1 MIN
+500 ADD'L ANYTME
+1 MIN
+DO ADDL ANTIM
+1 MIN
+00 ADD'L ANYTM
+WPALMBEACH FL
+1 MIN
+500
+ADD'L
+EMIN
+1 MIN
+1 MIN
+38
+ADDL
+WPALMBEACH FL
+1 MIN
+VPALMBEACH FI
+MIl
+COMINI
+WPALMBEACH FL
+1 MIN
+COMIN
+2 MIN
+(PALMBEACH A
+1 MIN
+WPALMBEACH FL
+WPALMBEACH FL
+NCOMING
+DELRAY BCH
+INCOMIN
+IP.
+ALM
+
+CELLEN
+7 999 99999999999
+O5S5555
+
+
+
+Item Date Time
+Called
+08/19 04:14P (561)662-4250
+08/19 04:15P 561)452-0654
+Calls To
+WPALMBEACH FL
+WPALMBEACH FL
+514 08/19 04:168
+08/19 04:18P 5611794-290
+215 08/19 04:17P (561)795-9877
+216 08/19 04:18-
+08/19
+04:20P 561)851-5858
+218 08/19 04:21P (561)596-3561
+08/19 04:28P 28P
+S611525
+08/19 04:29P
+08/19
+04:30P 561)991-8018
+08/19 04:31P
+08/19 04:325
+5611791-801
+WPALMBEACH FL
+WALNBEACH FE
+WPALMBEACH FL
+WALMBEACH EL
+WALMBEACH FL
+Qnty
+Used Rate Description
+1 MIN
+500 ADD'L ANYTME MIN
+1 MIN
+500 ADD'L ANYTME MIN
+500 ADD'L ANYTME MIN
+500 ADD'L ANYTME
+500 AD
+500 ADD'L
+ADD'L
+500 ADD'L
+500 ADD
+500
+ADD
+500 ADD'L
+08/19 04:43P
+5611951-585
+226 08/19 04:58P (561)818-3331
+08/19 04:59P
+226 08/19 06:00P 5611862:123
+CH
+ACH
+1 MIN
+1 MIN
+2 MIN
+1 MIN
+1 MIN
+2 MIN
+1 MIN
+1MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+2 MIN
+500 ADD'L ANYTME MIN
+00
+ADD'L
+ANYTME
+229 08/19 05:00P
+230 08/19 05:05P
+
+(561)315-4424
+(561)753-0169
+988 8858888
+999 9999999
+
+IT
+8.
+-3331
+
+3888g
+888
+1 MIN
+-8943
+ACH
+....!
+
+
+270
+08.
+/20
+10:
+:35A
+WPALMBEACH FL
+
+
+
+
+
+Item Date Time Called
+Calls To
+271 08/20 12:29P
+12:51P
+275 08 20 0130P
+274 08/20 02:31P
+275 08/20 03:14P (561)379-7824
+276 08/20 03:16P
+27 08/20 04-50₽
+270 08/20 04:02P (967)653-3753
+281 08/20 04:03P
+283 08/20 05:39 1561881-3590
+284 08/20 05:47P (561)715-6303
+286 08/20 0533P 1567)858-3363
+286 08
+287 08/20 06:03P (561|662-1291
+O 06:06P
+329NBB
+08
+08
+gg
+06:09P
+888
+06:
+/20
+:17P
+(561)309-8686
+07:03P
+20
+08/20 07:55P
+(561)351-4517
+Qnty
+Used Rate Description
+1 EVT
+MESSAGE RETRIEVAL
+1 MIN
+500 ADD'L ANYTME MIN
+1 MIN
+O ADOL ANYIME M
+3MIN
+O ADD'L ANYTME M
+500 ADD'L ANYTME MIN
+1 MIN
+EMIN
+1 MIN
+1 MIN
+1 MIN
+2 MIN
+EMIN
+1 MIN
+IMIN
+EMIN
+1 MIN
+2 MIN
+2 MIN
+1 MIN
+EVT
+2 MIN
+AMIN
+1 MIN
+: MIN
+500 ADD'L ANYTME MIN
+50 BATE MIN
+SO ABELANE MIN
+500 ADD'L ANYTME MIN
+500 ABBL ANYTE MIN
+500 ADD'L ANYTME MIN
+DD'L
+ANYTME
+1 MIN
+313
+08
+120
+08:15P
+08/20
+08:36P
+(561)351-4517
+08:55P
+08-568
+08
+/20 09:18P
+(561)722-8423
+09:
+561351-4517
+21P
+561
+1722
+-8423
+09:23P
+
+5611317-2428
+
+10
+
+(561)792
+-6375
+5611
+379
+-7824
+8/20 10:32
+8120 10-32
+23P
+NNNNNNNNNNNN
+goNg
+
+76
+4888
+NCOMING
+NCOMING
+WPALMBEACH FL
+COMIN
+COMIN
+DELRAY BCH FL
+NEW TORCHE
+WPALMBEACH FL
+WALMBEACH AL
+MING
+WPALMBEACH FL
+MPALMR
+CH
+WPALMB
+WPALA
+WPALMBEACH FL
+WPALMBEACH FL
+COMIN
+PALMBEACH
+COMIN
+WPALMBE
+
+P
+3999
+7999
+TELE
+
+Onty
+Item Date Time Called
+Calls To
+Used Rate Description
+331 08/20 11:09P (561)792-6375
+WPALMBEACH FL
+3 MIN
+1000 NIGHT/KEND MIN
+332 08/20 11:13P (561)596-8943
+WPALMBEACH FL
+1000 NIGHT/KEND MIN
+333 08/20 11:14P
+334 08/20 11:26P
+1 MIN
+1000 NIGHT/KEND MIN
+338 08/20 1132P (861)586-3561
+D MIN
+337 08/20 11:55P
+2 MIN
+1000 NIGHT/KEND MIN
+339 0820 1200 881)592-0843
+1 MIN
+1000 NIGHT WREN MIN
+340 08/21 12:034 (561)596-3561
+COMIN
+PALMBEACH R
+1 MIN
+342 08/21 12:13A
+2 MIN
+1000 NIGHT/KEND MIN
+344 0B21 1228A (561)792-6375
+WPALMBEACH FL
+EMIN
+345 08/21 12:34A (561)758-7140
+WPALMBEACH FL
+2 MIN
+1000 NIGHT/KEND MIN
+347 08210122A
+: 8889
+T MIN
+NONSENSEEN NONSENSEE
+
+1662
+-1291
+1790-
+2974
+33
+79.
+38880888888 388
+58 3888
+WP.
+HAN FETTE
+a PeP 20 A
+1 MIN
+2 MIN
+2MIN
+2 MIN
+1 MIN
++-N---NN------N--
+*CA
+
+
+
+Called
+Item Date Time
+393 08/21 11:02P
+394 08/21
+11:07P
+390 08 21 18 39
+397 08/21 11:18P (561)523-1740
+388 08/21 11:30P (561/309-1375
+4D0 08/21
+:32F (561)523-17
+1082114(561790-47
+104 08/22 1217A 5611867-2228
+405 08/22 12:18A (561)792-6375
+10 08/22 12204 581596-3581
+408 08/22 12:27A
+100 08/22 12:144
+411
+12:44A
+12:49A
+(561)818-3331
+12:924
+:03:11P
+03:37P
+:03:39P (561)541-6819
+:04:32P
+05:31P
+06:11P
+(561)306-2124
+:13P
+72 219-474
+:32P
+721210-474
+07:25P
+(561)792-3772
+08/
+07:30P
+61)596-356
+200
+5611379-7824
+425 08/22 07:40P (561)379-7824
+127 08/22 07:00P (561)662-1291
+428 08/22 08:01P
+429 08/22 08:12P
+430 08/22 10:45P
+431
+08/22 11:34P
+32
+087
+123
+434
+08/
+12:26A
+(561 596-3561
+08/
+12:39A
+23
+07:16A
+435
+08r
+23 08:55A
+436
+08/23 10:12A (561)379-7824
+437 08/23 10:14A (561)379-7824
+438
+888
+11:11A (917)855-3363
+441
+08/
+23
+12:43P
+(561)790-3459
+08
+441
+08
+2:54P
+561 596-356
+01:04F
+1611596-356
+08/23 01:08P
+(561)317-2428
+08/23 02:15
+02:16P
+448
+18
+23 03 02P
+449 08/23 04:14P (561)379-7824
+450 08/23 04:48P
+451
+08/23 04:56P
+Calls To
+BOYNTONBCH FL
+VPALMBEACH Fl
+COMIN
+IG
+OYNTONBCH F
+NOMINGCH F
+WPALMBEACH FL
+PALMACH FL
+WPALMBEACH FL
+COMIN
+COMIN
+INCOMIN
+WPALMBEACH FL
+DELRAY BCH FL
+TUART E
+TIAR
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+VPALMBEACH F
+VPALMBEACH F
+WPALMBEACH FL
+WPALMBEACH FL
+NEW YORK NY
+NCOMING
+NCOMING
+WPALMBEACH FL
+WPALMEACH FL
+NCOMING
+NOOMING
+COMINI
+WPALMBEACH FL
+Qnty
+Used Rate Description
+1 MIN
+1000 NIGHT/WKEND MIN
+2 MIN
+1000 NIGHT/WKEND MIN
+2 MIN
+1 MIN
+J0 NIGHT/KEND N
+1 MIN
+1000 NIGHT/WKEND MIN
+1 MIN
+D MIN
+1 MIN
+1000 NIGHT/KEND MIN
+1 MIN
+1 MIN
+2 MIN
+100 NIGHT KENNING
+1000 NIGHT/WKEND MIN
+1 MIN
+1 MIN
+MAIN
+2 MIN
+1000 NIGHT/WKEND MIN
+00
+NIGHT/WKEND
+KEND N
+1 MIN
+2 MIN
+2MIN
+OMIN
+2 MIN
+1 MIN
+SMIN
+2MIN
+3MIN
+1 MIN
+SMIN
+1 EVT
+1 MIN
+2MIN
+1 MIN
+1 MIN
+1 EVT
+4 MIN
+1 MIN
+1 MIN
+4 MIN
+1 MIN
+2 MIN
+2 MIN
+1 MIN
+1EVT
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+2 MIN
+1 MIN
+1 MIN
+1 MIN
+2MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+9 MIN
+1 MIN
+
+Called
+Item Date Time
+452 08/23 04:57P
+453 08/23 05:27P (561)596-3561
+Calls To
+WPALMBEACH FL
+(5611596-35611
+WALMBEACH EL
+456 08/23 06:10P (561)662-1291
+WPALMBEACH FL
+08/23 09 26P
+09:26P (561)793-7230
+459
+08
+08
+09:30P (561)714-5714
+18
+23 09:38P 581/392-2378
+09:38P
+WPALMBEACH FL
+WPALMBEACHEL
+09:52P 561596-356
+464
+10:12P
+5611767-065.
+08/23 11:18P (561)715-6303
+DELRAY BCH FL
+11:18P 561)596-3561
+08/24 09:24A 15611596-3561
+467 08/24 09:28A (561)801-3590
+468 08/24 09:34A (561)792-6375
+08/24
+09:35A
+5611317-2428
+WPALMBEACH FL
+WALNBEACH FL
+WPALMBEACH FI
+WP.
+ALMBE
+WPALMB
+NONNNON
+NANNONNE
+
+SZEEEEESEEE
+PALM
+PALA
+PALM
+EsIr
+OMING
+PALMBEACH
+55-
+(56
+18-
+VPALMBEACH F
+COMING
+
+
+
+0999NNN
+
+
+
+(561)753-4000
+88
+PALMBEACH I
+PALMREACH i
+WPALMBEACH FL
+NCOMING
+WPALMBEACH FL
+MPALMBEACH F
+WPALMBEACH FL
+JCOMIN
+BE RAY BEHAL
+NCOMING
+COMING
+Qnty
+Used Rate Description
+1 MIN
+500 ADD'L ANYTME MIN
+1 MIN
+500 ADD'L ANYTME MIN
+D ADDL ANTIME M
+2MIN
+O ADD'L ANYTME MI
+500 ADD'L ANYTME MIN
+2 MIN
+0 ADD'L ANYTME MI
+000 NIGHT/KEND MI
+2 MIN
+MIL
+1000 NIGHT/KEND MIN
+MI'
+1 MIN
+1 MIN
+1000 NIGHT/KEND MIN
+1 MIN
+1 MIN
+30 ADD'L ANYTME MIN
+DO ADD'L A
+1 MIN
+500 ADD'L ANYTME MIN
+1 MIN
+INCLUDE MINUTES
+TAL
+INCI
+1 MIN
+1 MIN
+1 MIN
+2MIN
+1 MIN
+EVT
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+2 MIN
+OMIN
+1 MIN
+2 MIN
+1 MIN
+INCI
+1 MIN
+SKIN
+1EVT
+1.50
+411
+1 MIN
+1 MIN
+2 MIN
+MINUTE
+1 MIN
+1 MIN
+1 MIN
+1EVT
+1 MIN
+2MIN
+3 MIN
+MARE
+MINUTES
+ITING
+MINUTES
+1 MIN
+INC
+1 MIN
+1 MIN
+6MIN
+EVT
+.50
+INC
+MINUTES
+3MIN
+INUTES
+1 MIN
+1 MIN
+1 MIN
+IN LUBED MINUTES
+2MN
+2MIN
+1 MIN
+IDED MINUTE
+1 MIN
+1.50
+1.50
+2005763.000014554
+
+
+
+Item Date Time Called
+513 08/24 04:21P
+514 08/24 05:27P (561)676-4062
+Calls To
+WESTPLMBCH FL
+216 08/24 07-31P (561)596-3561
+517 08/24 10:01P
+518 08/24 10:35P (561)379-7824
+519 08/25 07:11A (561)801-3590
+520 08/25 09254 561306-2724
+522 08/25 09:25A (561j379-7824
+523 08/25 09:26A (561)482-6100
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+DELAY BCH FL
+WPALMBEACH FL
+BOCA RATON FL
+1 MIN
+524 08/25
+12HP
+1581714-9711
+526 08/25 12:15P
+88/23
+(561)801-3590
+WPALMBEACH FL
+2 MIN
+1 MIN
+1 MIN
+12:19P (561|801-3590
+02:06P
+Qnty
+Used Rate Description
+1 MIN
+2 MIN
+1 MIN
+1 MIN
+D MINUTE:
+INCLUBED MINUTES
+1000 NIGHT/KEND MIN
+MESSAGE RETALIN
+INCLUBED MINUTES
+1 MIN
+INCLUBED MINUTES
+INCLUDE MINUTES
+INCLUBED MINUTES
+Item Date Time
+Called
+77 08/26 09:53A (561)281-017
+578 08/26 09:55A
+61291-017
+Calls To
+NPALMBEACH FL
+NPALMBEACH FL
+
+0 08/26 10:17A (5611281-011
+ACH F
+581 08/26 10:24A
+2 08/26 10:3
+76 10-2
+584 08/26 10:42A
+586 08/26 12-550
+588 08/28 03.22P (881)7-6375
+589 08/26 03:55P
+3 MIN
+1 MIN
+3 MIN
+1 MIN
+599 08/26 04-300
+592 08/26 04:59P
+53. 0828 0, P 1861801, 3580
+WPALMBEACH FL
+(917)855-
+3363
+1 MIN
+880
+Onty
+Used Rate Description
+1 MIN
+NCLUDED MINUTES
+2 MIN
+NCLUDED MINUTES
+2 MIN
+1 MIN
+I HINUT
+INCLUBEB MINUTES
+INCLUBER MINUTES
+I MINUTI
+INCLUBE MINUTES
+
+99055
+88
+(56
+79
+7824
+71
+855-
+-3363
+2005763.000014554
+NANN
+OBI
+V27
+04
+:27P
+88
+(561
+1379
+7824
+(91
+7)
+)855-3363
+WF
+2508
+WPALMBEACH FL
+NEW YORK NY
+1 MIN
+1 MIN
+CLU
+INELUDED MINUTESAL
+
+
+
+Item Date Time
+Called
+638 08/27 05:05P (561)379-7824
+Calls To
+WPALMBEACH FL
+3 08/27 05:25P (561)784-2719
+641 08/27 05:27P
+643 08/27 05: 40P 8611731-2088
+644 08/27 07:16P (561)317-2428
+15 08 27 07:28
+161517-242
+16 0807 07520
+611596-356
+647 08/27 08:06P
+648 08/27 08:08P (561)596-3561
+649 08/27 08:08P (561)596-3561
+831 08/27 09:17P (561)596-3561
+652 08/27 09:25P
+553 08/27 09:32
+54 08/27 09:37P (561)767-676
+655 08/27 11:29P (561)818-7247
+855 08/28 12:21A 661)293-4303
+i-6300
+658
+08/28 01:34A
+659 08/1
+01.074
+660 08/28 08:25A (561)792-6375
+08/28 08:29A
+662
+08/28 08:30A
+663
+08/28 08:30A
+664
+08/28 08:52A
+665
+08/28
+08:53A
+561\317-8856
+SA11370-792:
+NCOMING
+NOOMING
+WPALMBEACH FL
+WPALMBEACH FL
+WPAI MRFACI
+666
+08/28 10:44A
+6b7
+11:34A (561)596-3561
+668
+669
+08/28
+670
+08/
+11:47A
+11:48A
+(561)793-7230
+08/
+29
+11:51A
+COMI
+IPALMBEACH F
+Qnty
+Used Rate Description
+1 MIN
+1 EVT
+MESSAGE RETRIEVAL
+1 MIN
+2 MIN
+1 MIN
+1 MIN
+WPALMBEACH FL
+NPALMBEACH FI
+NGOLMBEACH F
+VPALMBEACH F
+WPALMBEACH FL
+BOYNTONBCH FL
+WPALMBEACH FL
+INCE MINES
+1 MIN
+1 MIN
+2 MIN
+2 MIN
+1 MIN
+1 MIN
+2 MIN
+1 MIN
+1000 NIGHT/WKEND MIN
+100 NIGHT WREND MIN
+NCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+1 MIN
+1 MIl
+1 MIN
+2 MIN
+1 EVT
+09 MIN
+1 MIN
+1 MIN
+2 MIN
+2 MIN
+02903
+1214P
+14P
+08/28 12:37P
+75
+08/28 04:42P
+08/
+28 05:15P
+08/28 06:20P
+08/28 10:025
+679
+08/29
+561)596-3561
+02:00P
+680
+08/
+129
+02:03P
+561)
+1596
+:02:03P
+08/28
+02:218
+(581)
+12•54:
+684
+08/29 03:12P
+685
+686
+08/
+03:
+(561
+jB01
+08/
+29
+790-
+129 03:20P
+1861,793
+687
+08/29 03:23P
+688 08/29 03:28P
+561)503-6282
+689 08/29 03:31P
+(561|379-7824
+690 08/29 03:41P
+B989
+08/29 03:44P
+08/29 03:45F
+08.
+129
+•50P
+88
+04:01P
+04:01P
+8888
+8888
+8866
+VOOMINO
+VPALMBEACH F
+WPALMBEACH FL
+WPALMBE
+WPALMB
+MPALM
+WPALMB
+MPALMB
+MPALME
+WPALME
+sergea
+WPALMB
+DELRAY
+BOYNTONBCH I
+WPALMBEACH FL
+1000
+MESSAGE RETRIEVA
+000 NIGHT/WKEND MI
+1000 NIGHT/WEND MIN
+1000 NIGHT/WKEND MIN
+1000 NIGHT/WKEND MIN
+
+Item Date Time
+Called
+O0 08/29 04:17P (561)792-3772
+701 08/29 04:18P (561)721-5182
+Calls To
+WPALMBEACH FL
+WPALMBEACH FL
+703 08/29 04:20P 561798-7730
+704 08/29 04:24P (561|790-0746
+706 08/29 0436P (981 585-7230
+707 08/29 04:38P (561)767-6762
+WPALMBEACH FL
+PALMBEACH
+SAI MIRE AN
+BOYNTONBCH FL
+709 08/29 04:52 561586-3561
+:54P 5611379-78
+713 08/29 04340 1561) 596-3561
+714 08/29 04:58P (561)596-3561
+715 08/29 05:00P (561j379-7824
+716 08/29 05:03P (561)767-676
+17 08/29 05:038
+718 08/29 05:24P
+08/29
+05:26P
+08/29 05:26P
+08/29 05:576
+08/29 05:58P
+9 05:58P
+(561
+
+1 05:58P
+06:05P
+06:09P
+(561)
+-3561
+(561
+-6212
+732 08/29 06:25P
+734 08/30 09:23P (561)379-7824
+735 08/30 02:29P (561)379-7824
+736 08/30 02:33P (561)379-7824
+737 08/30 03:10P
+738 08/30 04:25P (561)379-7824
+739 08/30 07:22P
+740 08/30 08:33P (561)379-7824
+741 08/31 07:40A (561)379-7824
+742 08/31 07:43A (561)379-7824
+744 08/31 09:34A (863)801-9153
+745 08/31 09:35A (561)379-7824
+746 08/31 09:36A (561)655-7629
+747
+08/31 10:32A
+48
+08/31 01:01P (561)715-6303
+08/31 02:10P (561)792-6375
+08312250561)792-6375
+08/31 02:41P (561)801-3590
+WALMBEACH FL
+WALBEACH L
+WPALMBEACH FL
+WPALMBEACH FL
+DYNTONBCH F
+COMIN
+COMIN
+VPALMBEACI
+VPALMBEACH
+WPALMBEACH
+BOYNTONBCH
+WAI MREACH
+WPALMBEACH
+WPALMBEACHI
+VPALMBEACH F.
+COMING
+WALACHEL
+WPALMBEACH FL
+WPALMBEACH FL
+NCOMING
+NPALMBEACH F
+NCOMING
+WPALMBEACH FI
+WPALMBEACH FL
+WPALMBEACH FL
+COMIN
+(EECHOBEE I
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+Qnty
+Used Rate Description
+1 MIN
+1000 NIGHT/KEND MIN
+1 MIN
+1000 NIGHT/KEND MIN
+1 MIN
+DO NIGHL WKEND M
+DO NIGHT/KEND M
+1 MIN
+1000 NIGHT/WEND MIN
+1 MIN
+1000 NIGHT/WKEND MIN
+1 MIN
+1000 NIGHT/KEND MIN
+1MIN
+1 MIN
+1 MIN
+1MIN
+1 EVT
+1000 NIGHT WREND MIN
+MESSAGE RETRIEVAL
+1 MIN
+1 MIN
+1 MIN
+1 MIN
+MAIN
+1 MIN
+1 KM
+1 MIN
+1 MIN
+7MIN
+1 MIN
+1 MIN
+3M N
+2 MIN
+2MIN
+7 MIN
+1EVT
+7MN
+1EVT
+1 MIN
+6MIN
+1EVT
+4 MIN
+1EVT
+2MIN
+4 MIN
+1FVT
+1 MIN
+2MIN
+1EVT
+1 MIN
+1EVT
+2 MIN
+1EVT
+1 MIN
+1MN
+2 MIN
+TENT
+3MIN
+2MIN
+1 MIN
+1 MIN
+1000 NIGHT/KEND MIN
+MESSAGE RETALI
+1000 NIGHT/KEND MIN
+CALL NAHTINGKEND MIN
+1000 NI
+1000
+GHT/KEND
+1000 NIGHT/KEND M
+1000 NIGHT/KEND
+1000 NIGHT/KEND
+1000
+000
+GHT/KEND
+GHT/KEND
+1000
+NIGHT/KEND
+1000 N
+1000 N
+HT/KEND
+1000 NIGHT/KEND
+1000 NIGHT/KEND
+1000 NIGHT/KEND MIN
+ALL WAITIN
+000 NIGHT/WKEND MIN
+CALL WAITING
+1000 NIGHT/KEND MIN
+NCLUDED MINUTE:
+MESSAGE RETRIEVAL
+ICLUDED MINUTE
+ESSAGE RETRIEV
+JESSAGE RETRIEV
+CLUDED MINUTE
+CLUDED MINUTE
+CRAGE RETRIEV
+MESSAGE RETRIEVAL
+CASE COMPLETIONAL
+CLUDED MINUTE
+CLUDED MINUTE
+2005763.000014555
+
+
+
+Item Date Time
+Called
+753 08/31 06:54P
+754 08/31 06:55P (561)856-2974
+
+757 08/31 09:42P
+738 08/31 0946P
+1 09:46P
+760 09/01 10:02A
+561)801-3590
+Calls To
+PALM BEACH FL
+COMIN
+COMING
+COMIN
+PALMBEACH I
+WPALMBEACH FL
+898118:02A 1561801-3590
+09/01
+765 09/01 11:16A (561)596-3561
+765
+8981 11:23A 561317-2423
+768 09/01 11:26A
+WPALMBEACH FL
+INCOMING CHEL
+1 MIN
+770
+09
+09
+8888
+09
+888
+:88
+09
+09
+09
+88
+Qnty
+Used Rate Description
+1 MIN
+2 MIN
+CLUDED MINUTE
+0 MINUTE
+1 MIN
+2 MIN
+1 MIN
+2MIN
+1 MIN
+EMIN
+1 MIN
+1000 NIGHT/WEND MIN
+100 NIGHT WREND
+INCLUBED MINUTES
+INCLUBED MINUTES
+8F
+(239)334-0603
+(561)818-3331
+WPALMB
+INCLUBEB
+INCLUDED
+9F
+:04P
+SA
+09
+09
+(561)801-3590
+(561)776-8748
+(561)309-1375
+561)790-3459
+(561)385-0480
+(561)309-1375
+(561)309-1375
+(581978-4303
+6303
+(561)801-3590
+(561)714-5714
+-5714
+WPALI
+NCOMING
+UT
+HOWDED
+2MIN
+EV
+2 MIN
+
+ICLU
+INCLUDI
+
+Item Date Time Called
+817 09/02 08:11P
+818 09/03 07:05P (561)723-8702
+820 09/03 07-01 1561)992-3112
+821 09/03 07:17P
+822 09/03 07:19P (561)379-7824
+823 09/03 07:20P (561)790-3459
+Calls To
+WPALMBEACH FL
+KE WORTH
+PALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+P (561)715-63
+828 09/03 07:38P (561)792-3772
+829
+830
+08/08 09:.13P (561)722-8423
+831 09/04 09:15A
+33
+9/04 06:45P (354|258-292
+NИ 0A-4C
+88881
+S0CD CO
+- 7724
+
+
+88888888 882888
+
+
+
+1/375
+
+(561)714-5714
+(561)856-6249
+
+
+1379-
+B209 2g
+88g
+(561)795-8480
+8888
+:03P
+(561)795-8480
+23P
+(718)397-0253
+:25P
+WPALMBEACH FL
+INCOLNEACH FLE
+COMIN
+'PALMBEACH |
+WPALMBEACH FL
+WPALMBEACH FL
+TLAUDERD
+FTLAUDERDL
+DELRAY BCH
+NOOMING
+DETRAY
+DELRAY B
+FTLAUD
+CH
+ERDU
+WPALMBEACH
+DEIRAY
+RCH FL
+WPALMBEACH FL
+WPALMBEACH FL
+PALM BEACH FL
+NOOMINO
+COMING
+NOOMING
+BERA
+RCH FL
+WPALMBEACH FL
+FTLAUDERDL
+LAKE WORTH FL
+NOOMING
+WPALMBEACH FL
+WPALMBEACH FL
+COMING
+JEENS N'
+Onty
+Used Rate Description
+1 MIN
+NCLUDED MINUTE
+4 MIN
+ICLUDED MINUTE
+2MIN
+2MIN
+1 MIN
+EMIN
+2 MIN
+2 MIN
+2 MIN
+1 MIN
+1 MIN
+3 MIN
+7 MIN
+1 MIN
+1 MIN
+1 MIN
+2 MIN
+1 MIN
+1 EVT
+5 HIN
+1 MIN
+2MIN
+1 MIN
+1 MIN
+2 MIN
+1 MIN
+5MIN
+1 EVI
+1 MIN
+1 MIN
+3 MIN
+AMIN
+4 MIN
+1 MIN
+1 MIN
+2 MIN
+LEVT
+2MIN
+1 MIN
+1 MIN
+4 MIN
+1 MIN
+EMIN
+1 EVT
+1 MIN
+1 MIN
+1 MIN
+3 MIN
+2 MIN
+I HINUT
+IMESSAGE RETHIEVAL
+INCLUDE MINUTES
+INCLUBED MINUTES
+1000 NIGHT/KEND MIN
+1000 NIGHT/KEND MIN
+1000 NIGHT
+END MIl
+100 NIGHT WREN
+1000 NIGHT/KEND MIN
+EVAI
+100 NIGHT TREND MIN
+1000 NIGHT/KEND MIN
+1000 NIGHT/WKEND MIN
+1000 NIGH
+TWKEND MIN
+MINUTES
+NELUBEB MINUTES
+CLUDED MINUTE
+CLUDED MINUTE
+10900
+MESSAGE RETRIEVA
+VCLUDED MINUTES
+INCLUBEB MINUTES
+INCLUBEB MINUTES
+CALL WAITING
+CHINE
+NCLUDED MINUTES
+CALI
+WAITING
+NELUBER MINUTES
+NCLUD
+
+
+
+Item Date Time
+Called
+Calls To
+876 09/07 08:26P (718)397-0253
+877 09/07 08:55P
+878 09/07 09:01P
+879 09/07 09:09P (561)379-7824
+880 09/08 11:04A (561)792-6375
+881 09/08 11:18A
+(954)776-4192
+882 09/08 1
+883 0908 11:204 581)317-2428
+E 00I08 11.90
+886 09/08 11:23A (954)776-4192
+88T D90 H36A
+889 09/08 11:36A (561)818-3331
+890 09/08 12:03P
+(561)309-1375
+
+33388
+4-2981
+8888888888888888888g
+
+
+G00088899
+49M 3038
+(365)
+2.
+-7155
+555-1212
+35
+1680-
+888
+88
+QUEENS NY
+WPALMBEACH FL
+WPALMBEACH FL
+FTLAUDERDL FL
+Qnty
+Used Rate Description
+1 EVT
+CALL WAITING
+8 MIN
+MIl
+2 MIN
+1000 NIGHT/WKEND MIN
+1 MIN
+FTLAUDERDL FL
+WPALMBEACH FL
+COMIN
+1 MIN
+1 MIN
+2 MIN
+2 MIN
+1 MIN
+2 MIN
+4 MIN
+2 MIN
+INCLUBED MINUTES
+PALMBE
+g96662966AF0225509
+ALM
+...
+ED
+300000oooooc
+00O000Or00000O
+
+Item Date Time Called
+938 09/08 10:06P (561)801-3590
+939 09/08 10:11P (954)680-5600
+1282-88
+942 09/09 10:43A (561)379-7824
+943 09/09 11:45A (561)715-6303
+944 09/09 11:52A
+346 090911574 365)233-9212
+947 09/09 12:00P (561)276-1344
+948 09/09 12:01P (561)276-1344
+• UNUS IE.
+0 09/09 12:17
+952 0909 0249P 581)309-6375
+Calls To
+WPALMBEACH FL
+FTLAUDERDL FL
+ELRAY BCH
+PALMBEACH P
+WPALMBEACH FL
+DELRAY BCH FL
+COMING
+VPALMBEACH FI
+DELRAY BCH FL
+DELRAY BCH FL
+COMIN
+COMIN
+WALMBEACH FL
+Qnty
+Used Rate Description
+3MIN
+1000 NIGHT/KEND MIN
+1 MIN
+1000 NIGHT/KEND MIN
+A 025 ADDTIONALNKEDTE
+D0O NIGHTWKEND MIT
+2 MIN 0.25 ADDITIONAL MINUTES
+0.25 ADDITONAL MINUTES
+1 MIN
+EMIN
+0.25 ADDITIONAL MINUTES
+8.25 ABBITIONAL MINUTES
+1.29 ADDITIONAL MINUTES
+4 MIN
+0.25 ADDITIONAL MINUTES
+8:23 ABBITIONAL MINUTES
+1 EVT
+CALL WAITING
+3MIN
+8.25 ABBITIONAL MINUTES
+0000 C
+2.50
+0.25
+0.25
+8:58
+1.28
+1.00
+1:25
+0:25
+561)723-8702
+(561)818-3331
+BB888
+9000 -
+(561)818-3331
+
+0OOOOOOOOG
+
+WEEEEE
+
+DOOOOOT
+15555
+
+
+
+0000000000000C
+Enli
+995710000 C929002
+
+
+2005763.000014556
+
+Item Date Time
+Called
+1000 09/10 07:12P (561)309-1375
+1001 09/10 07:14P
+(561)758-7140
+1005 09/10 08:08P
+09/10 08:08P 3811601-6282
+1004 09/10 08:32P
+1006 09/10 08:73P 581281-6212
+09/10 08:43P
+1007 09/10 08:47P (561)379-7824
+1008 09/10 09:03P (561)714-5714
+009 09/10 09:04
+61 714-571
+010 00/10 09:06
+611714-571
+1011 09/10 09:06P (561)714-5714
+18108789158(561 236-3299
+1014 09/10 09:17P (561j317-2428
+1013 09/10 09:367
+10/10 00-06R
+Calls To
+WPALMBEACH FL
+WPALMBEACH FL
+PALMBEACH_
+KE WORTH
+WALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WALMACHL
+WPALMBEACH FL
+INPALMBEACH FL
+WPALMBEACH FL
+COMIN
+PALMBEACH P
+WEAKERCH
+1 MIN
+1 MIN
+3 MIN
+I MIN
+
+(561)714-5714
+10
+09:46P
+(561
+:02P
+(561)723-8702
+561 818-3331
+5611236-3299
+3833
+38883
+
+008088EEEEEEEEEEEEE
+:31P
+:39P
+41P
+02:34A
+29000
+(561)723-8702
+(561)715-6303
+(561)715-6303
+(854)
+76-4192
+776-3707
+(561)379-7824
+EEEE BEEFE
+8338 88888
+EEEEEEEEEENE
+EA
+EACH
+EACH FL
+COMING
+WPALMBEACH FL
+DELRAY BCH FL
+RAV
+'BCH FL
+TLAUDERDL F
+TLAUDERDL F
+WPALMBEACH FL
+1 M
+1 MIN
+1 M
+1 MIN
+5611317-2378
+317-2428
+(561)379-7824
+S8383838
+WPALMRFACH
+MPALMBEACH FI
+4
+WESTPLMBCH FL
+WESTPLMBCH
+WPALMBEACH
+WPALMBEACH |
+(561)676-4062
+
+Qnty
+Used Rate Description
+2MIN 0.25 ADDITIONAL MINUTES
+0.25 ADDITIONAL MINUTES
+I MIN ABITAL MONTES
+2MIN 0.25 ADDITIONAL MINUTES
+1 MIN
+8:25 ABBITONAL MINUTES
+3 MIN
+0.25 ADDITIONAL MINUTES
+NIGHT KEN MIN
+1000 NIGHT/WKEND MIN
+1000 NIGHT/KEND MIN
+000
+100 N
+0.50
+0.25
+8.25
+0.50
+coi
+
+Item Date Time Called
+1062 09/12 03:01A
+1063 09/12 09:00A (561)379-7824
+1064 09/12 09:00A (561)379-7824
+Calls To
+WPALMBEACH FL
+WPALMBEACH FL
+1065 09/12 10:50A (561)379-7824
+066 09/12 10:51A (561)722-842
+067 09/12 02:17P (561\379-782
+Qnty
+Used Rate Description
+1 MIN
+1000 NIGHT/WKEND MIN
+1 MIN
+EV
+1000 NIGHT/WKEND MIN
+MESSAGE RETRIEVAL
+1000 NIGHT/KEND MIN
+1EVT
+MESSAGE RETRIEVAL
+1069 0912 02 33P (561)714-5714
+1070 09/12 02:55P
+1072 09112 0547P (561)317-2428
+1073 09/12 07:35P (561)379-7824
+WPALMBEACH FL
+PALMBEACH
+PALMBEACH
+NGALBEACH FL
+PALMBEACH FL
+WPALMBEACH FL
+3MIN
+1000 NIGHT/WKEND MIN
+1 MIN
+1 MIN
+AMIN
+1 MIN
+1000 NIGHT/WKEND MIN
+1876 09/12 99:57P (561)722-8423
+1878
+09/12
+(561)715-6303
+379-7824
+-FANFANT
+28888 38 28320223 8207228
+
+11722-8-
+988-8
+3-8702
+(561)723-8702
+(561)715-6303
+88
+08
+(561)379-7824
+(38172-7232
+8888 88888
+18.
+(561)818-3331
+(561)379-7824
+
+14 12:40P (561)792-6375
+12:48P
+01:08P
+5611233-0030
+02:57P
+03:24P
+(561)753-0169
+18:07P
+14 08:34P (561)801-3590
+25FF99222956201202
+INI
+33888
+CH
+CH
+CH
+WPALMBEACH FL
+WP
+P
+WPALMBEACH FL
+NOOMING
+NCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+VPALMBEACH F
+WPALMBEACH FL
+NCOMING
+WPALMBEACH FL
+1 MIN
+: MIN
+1 MIN
+1 MIN
+1 MIN
+2MIN
+1 MIN
+1000 NIG
+ADDIT
+0000 00
+6000
+DI
+80 880000
+OOOOOO
+ONAI
+óóóC
+0.
+0.2
+
+
+
+Item Date Time
+Called
+1118 09/14 08:37P (561)801-3590
+1119 09/14 08:53P
+1120 09/14 10:05P
+1121 09/14 10:27P (561)317-2428
+1122 09/14 10:57P
+Calls To
+WPALMBEACH FL
+INGOMING
+WPALMBEACH FLI
+TOTAL VOICE USAGE FOR (561)379-7824
+Qnty
+Used Rate Description
+1MIN 0.25 ADDITIONAL MINUTES
+SMIN 0.25 ADDITIONAL MINUTES
+1 MIN
+DOO NIGHLNVKEND MI
+MIN 1000 NIGHT/WKEND MI
+1 MIN
+1000 NIGHT/KEND MIN
+DATA USAGE FOR (561)379-7824
+Item Date
+Onty Used
+1 08/30
+3 KB
+TOTAL DATA USAGE FOR (561)379-7824
+Charge Description
+INCL. IN PLAN DATA
+TEXT/MULTIMEDIA MSGS FOR (561)379-7824
+Item Date
+500v0A0N-
+Sent To/Revd From
+
+:8888888888888R8888883RRPERAARABRRRRRBAARAARRRAR
+.....
+0.25
+1.25
+53.50
+0.00
+
+TEXT/MULTIMEDIA MSGS FOR (561)379-7824 - Continued
+Item Date
+Time
+Sent To/Rcvd From
+Charge Description
+48 09/01
+19 09/01
+03:26P
+100 INCL. MSGS SENT
+6:311
+561 596-356
+50 09/01
+52 0901
+13:37F
+61 596-356
+53 09/01
+88:500
+03:50P
+54 09/01
+04:00P
+561596-356
+100 INCL. MSGS SENT
+55 09/01
+04:00P
+5611596-356
+56 09/01
+04:25P
+(561596-3561
+7 09/01
+1:25
+58 09/0
+1-00
+59 09/01
+04:29P
+1080
+2 09/0
+04.30P
+14:41
+3 00/0
+4-411
+64 09/02
+04:07P
+561596-3561
+
+65 09/03
+16 09/03
+100 INCL. MSGS SENT
+100 INEL: MSGS SENT
+100 INCL. MSGS SENT
+100 INEL: MSGS SENT
+100 INCL: MSGS SENT
+100 INCL. MSGS SENT
+100 INCE. MAGS SENT
+07:13P
+87-05P
+07:10P
+17:141
+07:21P
+07:35F
+07:48P
+17:56P
+18:03P
+08:08P
+08:48P
+09:56P
+10:49A
+06:53P
+05:07P
+
+10:04P
+TOTAL TEXT MULTIMEDIA M
+0.00
+2005783.000014557
+
+
+
+• AT&T Wireless
+
+*** THIS SPACE INTENTIONALLY LEFT BLANK ***
+*** THIS SPACE INTENTIONALLY LEFT BLANK ***
+2005763.000014557
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/4cf2f12d35917747aa00a8e28e94f2363a45b802be6a50b74335bdf858f95184.receipt.json b/vision-fixhub/ds9-unparsed-06/4cf2f12d35917747aa00a8e28e94f2363a45b802be6a50b74335bdf858f95184.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..cf06bc9cdb9fca49153d15d0ae6030e17f4160f3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4cf2f12d35917747aa00a8e28e94f2363a45b802be6a50b74335bdf858f95184.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -6594,
+  "dataset": "marble-joined",
+  "doc_id": "4cf2f12d35917747aa00a8e28e94f2363a45b802be6a50b74335bdf858f95184",
+  "engine": "marble-apple-vision",
+  "event_count": 115,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "fd7cec23d48570f0abc2c419750a57e35e43d28d6c0af9e5b28d9d3075b79230",
+  "output_sha256": "4916723e702aef668476c0de89469344da23c48b4b3ee4368c4703a55c5df145",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4cf3fd9237cf53345135ff66231354576f0ebf6595e29613784e9f64c02b7547.md b/vision-fixhub/ds9-unparsed-06/4cf3fd9237cf53345135ff66231354576f0ebf6595e29613784e9f64c02b7547.md
new file mode 100644
index 0000000000000000000000000000000000000000..81abf82df275ee086de99e13716930f5855ea347
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4cf3fd9237cf53345135ff66231354576f0ebf6595e29613784e9f64c02b7547.md
@@ -0,0 +1,195 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/Johnson
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs
+UNITED STATES,
+Defendants
+JANE DOE #1 AND JANE DOE #2'S SUPPLEMENTAL REQUEST
+FOR PRODUCTION TO THE GOVERNMENT REGARDING NEW INFORMATION
+CONCERNING INVESTIGATION OF HANDLING OF EPSTEIN NON-
+PROSECUTION AGREEMENT
+COME NOW Jane Doe #1 and Jane Doe #2 ("the victims), by and through undersigned
+counsel, and request the defendant United States (hereinafter "the Government") to produce the
+original or best copy of the items listed herein below for inspection and/or copying, pursuant to
+the Court's Order (DE 99) directing discovery in this case, the Court's Order denying the
+Government's motion to dismiss and lifting stay of discovery (DE 189), and the Court's
+Omnibus Order (DE 190):
+BACKGROUND
+As the Government will recall, the victims have repeatedly asked the Government to
+stipulate to undisputed facts in this case. The Government has declined. Accordingly, the
+victims filed their Motion for Finding of Violations of the Crime Victims" Rights Act and
+Request for a Hearing on Appropriate Remedies (DE 48) (the victims" "summary judgment
+motion") along with a Motion to Have Their Facts Accepted Because of the Government's
+Failure to Contest Any of the Facts (DE 49).
+
+
+On September 26, 2011, the Court denied the victims' motion to have their facts accepted
+(DE 99 at 11). At the same time, however, the Court has ordered discovery to develop the
+factual record concerning the summary judgment motion (DE 99 at 11). The Court reserved
+ruling on the victims' motion for an order directing the Government not to suppress relevant
+evidence (DE 99 at 11).
+On September 28, 2011, the victims requested that the Government voluntarily provide
+documents concerning this case. The Government declined to provide even a single document.
+On October 3, 2011, the victims sent requests for production of documents relevant to
+this case.
+On November 8, 2011, the same day that the production of this discovery was due, rather
+than produce a single item of discovery or stipulate to a single fact, the Government filed a
+motion to dismiss the victims' case. The Government also filed an accompanying motion for a
+stay in this case.
+On November 8, 2011, the Government filed an ex parte, sealed motion to stay further
+discovery in this case. (DE 121). On November 9, 2011, the Court granted an ex parte, sealed
+order to stay. (DE 123).
+On December 5, 2011, the victims filed a response to Government's motion to stay. The
+victims strenuously objected to the Government's approach, alleging specifically that "delay
+appears to be the Government's motivation for filing the motion to dismiss." DE 129 at 2. The
+victims went on to recount the fact that the Government had waited three years to file a motion to
+dismiss, concluding that "as a practical matter, the Government's motion has had the desired
+effect of delay: While its motion remains pending, the victims have been effectively denied any
+ability to obtain discovery from the Government." DE 129 at 2-3. The victims also filed a
+
+
+protection motion to compel (DE 130) asking that the Court direct the Government to produce
+the requested materials.
+On January 24, 2012, the Government filed a reply in support of its motion to stay. DE
+140. In that reply, the Government represented that it would voluntarily be providing
+information to the victims:
+"IT]he United States has agreed to provide some information to [the
+victims] even during the pendency of the stay and is undertaking a search for that
+information." DE 140 at 4. Contrary to that representation, however, over the next seventeen
+months, the Government did not provide any information to the victims.
+A year after the Government's motion to dismiss, on December 6, 2012, the victims filed
+a Motion for a Prompt Ruling Denying the Government's Motion for a Stay (DE 179). The
+motion explained that it had been more than a year since the Government had filed its motion for
+a stay and that the Government's refusal to produce any information continues to effective block
+the victims from learning what happened during the Government's plea negotiations with the
+man who sexually abused them. The Government filed a response in opposition to that motion
+(DE 182).
+On February 25, 2013, counsel for the victims sent a request to the Government that, in
+view of that fact that its requested stay had never been granted, it should begin fulfilling its
+court-ordered discovery obligations:
+The victims believe that in view of fact that it has been more than fifteen
+months since the Government filed its motion for a stay of discovery and yet the
+Court has not granted that motion, the Court's discovery order is in effect and
+controlling. Accordingly, the victims respectfully request that by March 8, 2013,
+the Government produce all of the materials which is covered by the victims'
+liscovery requests. If the Government has not produced those materials b
+March 8, 2013, the victims may be forced to seek the intervention of the Court t
+order the Government to follow its obligations.
+If you would like to discuss this further, please feel free to set up a time
+where we can talk to you over the phone about all this. We are happy to work
+
+
+with you to try and minimize any unnecessary burden from your discovery
+obligations.
+E-mail from Paul G. Cassell & Bradley J. Edwards to Dexter Lee, et al., Counsel for the
+Government (February 25, 2013).
+The Government ignored the e-mail and did not respond in any way.
+Accordingly, in view of the Government recalcitrance and refusal to even discuss its
+discovery obligations, on March 14, 2013, the victims filed a motion to compel production of
+discovery materials. The Government did not respond to this motion.
+On June 1, 2013, the Court denied the Government's motion to dismiss. DE 189. That
+denial also lifted stay of discovery proceedings. DE 189 at 14 ("The stay of discovery pending
+ruling on the Government's motion to dismiss entered on November 8, 2011 [DE# 123] is also
+lifted."). The Court also entered an Omnibus Order (DE 190) that, among other things, granted
+the victim motion to compel (DE 130).
+SUPPLEMENTAL DISCOVERY REQUEST
+The victims now request one specific item of supplemental discovery relating to information
+that, in large measure, has come into existence since they filed the first request for production of
+documents on October 3, 2011:
+Jane Doe #1 and Jane Doe #2 have asked the Government to investigate their allegations that
+the U.S. Attorney's Office for the Southern District of Florida entered into a non-prosecution
+agreement with Jeffrey Epstein for sexual offenses committed against them and other victims
+based on considerations apart from the merits of the criminal case and also that violations of
+criminal law, rules of ethics, Justice Department policies (including policies on crime
+victims' rights), and the Crime Victims Rights Act occurred during the negotiations leading
+up to and surrounding the entry of the non-prosecution agreement. Please provide any
+information that the Government has developed concerning or relating to those allegations
+and the handling of the negotiations and consummation of the non-prosecution agreement,
+including any information developed by the Justice Department's Office of Professional
+Responsibility (OPR), the Federal Bureau of Investigation or other federal investigative
+entity, and any grand jury investigating these (or releated) allegations, including any grand
+jury meeting in the Southern District of Florida, the Middle District of Florida, the District of
+
+
+New Jersey, and/or the District of Columbia. For this one discovery request only, please
+include all relevant grand jury transcripts and evidence collected by the grand jury.
+DEFINITIONS
+For the purpose of construing the foregoing discovery requests, the following terms are
+defined:
+The term "documents" means and includes, without limitation, all writings of any kind,
+including the originals and all non-identical copies or drafts, whether different from the original
+by reason of any notation made on such copy or draft or otherwise including, without limitation,
+correspondence, memoranda, notes, diaries, statistics, letters, e-mails, electronic computer files,
+telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries
+pamphlets, books, prospectuses, interoffice communications, offers, notations of any sort of
+conversation, telephone calls, meetings or other communications, bulletins, printed matter,
+computer print-outs, teletypes, facsimiles, invoices, work sheets and all dratts, alterations,
+modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records
+or representations of any kind including, without limitation, photographs, charts, graphs,
+microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or
+electric records or representations of any kind including, without limitation, tapes, cassettes and
+dise recordings, and writings and printed material of every kind.
+The term "correspondence" means any tangible object that conveys information or
+memorializes information that was conveyed in tangible or oral form including, but not limited
+to, writings, letters, memoranda, reports, notes, e-mails, telephone logs, telephone billing
+information, telephone recordings, and interoffice communications.
+The term "Epstein's victims" means any person that the Government identified as a
+possible victim of a sex offense committed by Jeffrey Epstein, including Jane Doe #1, Jane Doe
+#2, all victims identified in attachment to the non-prosecution agreement entered into by Epstein,
+and another person that the Government investigated as a possible victim of Epstein's sex
+offenses.
+The term "Government" means the federal government, including all employees of and
+components of the United States Department of Justice (such as, the Office of the Attorney
+General, the Office of the Deputy Attorney General, the Criminal Divisions, the Office of
+Professional Responsibility, the Child Exploitation and Obscenity Section, the U.S. Attorney's
+Offices for the Southern District and Middle District of Florida, and the Federal Bureau of
+Investigation) and other federal government agencies with law enforcement responsibilities
+related to the Epstein case (such as the Internal Revenue Service). This request for production
+seeks all documents, correspondence, and other information held by all of these entities,
+including all employees of and components of the Justice Department that worked on or were in
+any way involved the Epstein investigation and/or that possess information relevant to the
+victims' claims.
+The term "including" means containing within the request, but not limiting the request.
+
+
+The term "witness statement" means any document or other recording in any form
+(including oral form) reflecting, recording, or otherwise memorializing a statement made or
+information conveyed by a potential witness, including for example FBI 302's.
+The term
+includes information collected by any law enforcement, prosecuting or government agency,
+including all federal, state, and local law enforcement agencies located in Washington, D.C., or
+PRIVILEGE LOG
+If you believe that any document, correspondence, or other information requested in this
+request is subject to a privilege and if you intend to assert that privilege, please provide a
+consistent with Local Rule 26.1(g), including a description a document that is
+consistent with Local Rule 26.1(g)(3)(B). Your privilege log should include the type of
+document, general subject matter of the document, date of the document, and author and
+addressee of the document or correspondence.
+REDUCING UNDUE BURDEN
+If you believe that complying with any of the foregoing requests would be unduly
+burdensomur please contact victims counsel - Bradley J. Edwards - to discuss ways to reduce
+DATED: June 24, 2013
+Respectfully Submitted,
+s/ Bradley J. Edwards
+Bradley J. Edwards
+FARMER, JAFFE, WEISSING,
+EDWARDS, FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+Telephone (954) 524-2820
+Florida BaSe: 54-07352
+E-mail: brad@pathtojustice.com
+and
+Paul G. Cassell
+Pro Hac Vice
+J. Quinney College of Law at th
+niversity of Uta
+332 S. 1400 E.
+
+
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile: 801-585-6833
+E-Mail: cassellp@law.utah.edu
+Attorneys for Jane Doe #1 and Jane Doe #2
diff --git a/vision-fixhub/ds9-unparsed-06/4cf3fd9237cf53345135ff66231354576f0ebf6595e29613784e9f64c02b7547.receipt.json b/vision-fixhub/ds9-unparsed-06/4cf3fd9237cf53345135ff66231354576f0ebf6595e29613784e9f64c02b7547.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d06e48e96da0b89476d942132965001cb6582433
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4cf3fd9237cf53345135ff66231354576f0ebf6595e29613784e9f64c02b7547.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -84,
+  "dataset": "marble-joined",
+  "doc_id": "4cf3fd9237cf53345135ff66231354576f0ebf6595e29613784e9f64c02b7547",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "133ef7e30c768b5108f5e6d07716d39239a56faeca45a0823393c0d325c9db0a",
+  "output_sha256": "202917f039ef52edf255e1e4ab46d16a5af165db3e16c3d66a4fed9d63e9ae96",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4d5a0456e0b82fa399a4b64639860aab230d7d5ebb026d431777c856398ab00c.md b/vision-fixhub/ds9-unparsed-06/4d5a0456e0b82fa399a4b64639860aab230d7d5ebb026d431777c856398ab00c.md
new file mode 100644
index 0000000000000000000000000000000000000000..3fe7bc08148a655c5dd9af35d233813515b774d7
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4d5a0456e0b82fa399a4b64639860aab230d7d5ebb026d431777c856398ab00c.md
@@ -0,0 +1,291 @@
+From: "
+• (USAFLS)" {
+To:
+I (USAFLS)" <
+Subject: RE: Voluntary Production of Materials?
+Date: Tue, 17 Jan 2012 05:21:02 +0000
+Importance: Normal
+Next Tuesday, but I think I am entitled to a few more days because he filed his stuff late.
+Yes, I can help.
+And I am pretty sure that I saw the motion and order. It has been a bit of a blur.
+Assistant U.S. Attorney
+(USAFLS)
+Sent: Tuesday, January 17, 2012 12:19 AM
+To:
+1. (USAFLS)
+Subject: RE: Voluntary Production of Materials?
+I think we have to file (under seal) by next Tuesday, but I have neither seen the motion
+filed requesting an
+extension nor an order addressing it. By the way, will you be able to help with the filing? My plan is to have everything
+finished before Tuesday morning. How, I don't know.
+When do you have to respond in
+I. (USAFLS)
+Sent: Tuesday, January 17, 2012 12:15 AM
+To:
+• (USAFLS)
+Subject: RE: Voluntary Production of Materials?
+Hopefully l
+. I will make sure that
+When is our deadline?
+• goes over first thing in the morning and gets a S$ figure.
+Assistant U.S. Attorney
+(USAFLS)
+Sent: Tuesday, January 17, 2012 12:14 AM
+To:
+1. (USAFLS); |
+Subject: RE: Voluntary Production of Materials?
+(USAFLS)
+I am clueless when it comes to these things, especially after my several years away from the Office. Can someone
+facilitate the process?
+? If you think my reaching out to them would help, let me know.
+• (USAFLS)
+Sent: Tuesday, January 17, 2012 12:03 AM
+
+
+To:
+(USAFLS); |
+| (USAFLS)
+Subject: RE: Voluntary Production of Materials?
+I will ask our court runner up here to try to get them. The problem is going to be getting the funds
+to pay for it quickly.
+Assistant U.S. Attorney
+(USAFLS)
+Sent: Monday, January 16, 2012 11:50 PM
+To:
+(USAFLS)
+Cc:
+1. (USAFLS)
+Subject: RE: Voluntary Production of Materials?
+Jor perhaps some paralegal in Civil have some idea how to get these materials? (I've never
+gotten anything like this directly through the office; it has always been through a case agent.) Or do you
+think we should perhaps go through Admin?
+Thanks,
+(USAFLS)
+Sent: Monday, January 16, 2012 12:47 AM
+To:
+\ (USAFLS);
+Subject: RE: Voluntary Production of Materials?
+(USAFLS)
+Attached are the two Palm Beach circuit court dockets. We need to get certified copies of the
+complaints in Case # 50-2008-CA-028051 (Docket Entries 1, 16, and 264) and Case # 50-2008-CA-
+028058 (Docket Entries 1, 23, and 221).
+Do either of you have any idea how we can get that done quickly?
+1. (USAFLS)
+Sent: Monday, January 09, 2012 5:53 PM
+To:
+I (USAFLS);
+Subject: RE: Voluntary Production of Materials?
+I (USAFLS)
+Yes, please.
+Also, L
+1. as to your question on the case numbers. Jane Doe #2's case number is
+50-2008-CA-028051 XXXX MB AB: L.M. vs. Jeffrey Epstein, In the Circuit
+Court of the Fifteenth Judicial Circuit in and for Palm Beach County. That case
+must have been removed to federal court (the Cohn case that you referenced in
+your email) and was then remanded to state court.
+Jane Doe #1 also filed her case in state court - E.W. |. Jeffrey Epstein, Case No. 50
+2008 CA 028058 XXXX MB AD, in the Fifteenth Judicial Circuit in and for Palm
+Beach County.
+
+
+Assistant U.S. Attorney
+Fax
+(USAFLS)
+Sent: Monday, January 09, 2012 3:43 PM
+1. (USAFLS);
+Subject: RE: Voluntary Production of Materials?
+(USAFLS)
+Should we talk about this? I really have no idea what we have or don't have that would
+be responsive to non-objectionable discovery, or what we could do in response to
+Cassell's request.
+From: Paul Cassell [mailto:
+Sent: Monday, January 09, 2012 3:31 PM
+To:
+(USAFLS)
+Cc:
+I- (USAFLS);
+bedwards@pathtojustice.com'
+Subject: RE: Voluntary Production of Materials?
+(USAFLS);
+Dear
+As mentioned last week, Brad and I wanted to chat with you about where we are
+on discovery in this case. I spoke with Brad, and while our recollection of what
+you promised you were going to do may be slightly different than ours, we
+believe there was at least a general agreement to the spirit of the voluntary
+production - that is, you were going to cooperate to the extent that you are able.
+As we explained on our phone call, we requested the things that we would like
+produced. While you may believe those requests to be overly broad and may
+assert that legal objection in your responses, you indicated that you would be
+willing to produce certain documents that may not be all the documents in your
+possession responsive to the request but that would amount to some documents
+or materials that we do not yet have. Without making us go through the
+unnecessary exercise of narrowing our requests, it would be most helpful if you
+would just shoot us over whatever documents or materials that you are willing to
+share with us voluntarily. We will agree that whatever production you make does
+not constitute a waiver of any legal objection you may have to any discovery
+So, are you willing to produce anything to us is, I guess, the bottom line. Thanks
+for any voluntary help you can extend.
+Paul Cassell
+Co-Counsel for Jane Doe #1 and Jane Doe #2
+Paul G. Cassell
+
+
+Ronald N. Boyce Presidential Professor of Criminal Law
+S.J. Quinney College of Law at the University of Utah
+Email:
+http://www.law.utah.edu/profiles/default.asp?PersonID=57&name=Cassell,Paul
+CONFIDENTIAL: This electronic message - along with any/all attachments -
+is confidential. This message is intended only for the use of the addressee. If you
+are not the intended recipient, the person responsible to deliver it to the intended
+recipient, you may not use, disseminate, distribute or copy this communication. If
+you have received this message in error, please immediately notify the sender by
+reply electronic mail and delete the original message. Thank you.
+| (USAFLS) [mailto:
+Sent: Saturday, January 07, 2012 8:08 AM
+To: Paul Cassell
+Cc:
+• (USAFLS);
+(USAFLS);
+'bedwards@pathtojustice.com'
+Subject: Re: Replies and Responses Due on January 6, 2012
+Thanks. Hope everyone has a great weekend.
+•
+From: Paul Cassell [mailto:
+Sent: Friday, January 06, 2012 07:00 PM
+To:
+Cc:
+(USAFLS)
+- (USAFLS);
+Subject: RE: Replies and Responses Due on January 6, 2012
+(USAFLS); Brad Edwards
+HiL
+1. Thanks for the clarification on the 90 day rule.
+2.
+Brad and I need to confer about the discovery issues, but that is not a basis
+for our withholding consent for an extension. So you may indicate that we
+consent to the extension. Brad and I have a different recollection about
+discovery issues than you do. But let's chat about that next week.
+Sorry to hear y'all are working at 7 PM on Friday night. Paul
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+S.J. Quinney College of Law at the University of Utah
+332 South 1400 East, Room 101
+Salt Lake City, UT 84112-0730
+Voice: 801-585-5202
+Email:
+http://www.law.utah.edu/profiles/default.asp?PersonID=57&name=Cassell,Paul
+
+
+CONFIDENTIAL: This electronic message - along with any/all attachments -
+is confidential. This message is intended only for the use of the addressee. If you
+are not the intended recipient, the person responsible to deliver it to the intended
+recipient, you may not use, disseminate, distribute or copy this communication. If
+you have received this message in error, please immediately notify the sender by
+reply electronic mail and delete the original message. Thank you.
+(USAFLS) [mailto:
+Sent: Friday, January 06, 2012 4:07 PM
+To: Paul Cassell
+Cc:
+1. (USAFLS);
+(USAFLS); Brad Edwards
+Subject: RE: Replies and Responses Due on January 6, 2012
+Hi, Paul.
+As always, we appreciate your efforts to be accommodating. With respect to the
+conditions that you have placed on your agreement to the requested extension:
+(1) No 90-day notice is called for by Local Rule 7.1(b)(4) for the
+motions/responses/replies connected to the requested extension
+because none is a "motion or other matter which has been pending and
+fully briefed" and none is a "motion or other matter as to which the
+Court has conducted a hearing." In any event, after the recent
+amendments to the Local Rules, the 90-day notices are only "serve[d] on
+all parties and any affected non-parties." Court filing of the 90-day
+notices is no longer contemplated by the Local Rules.
+(2) As to our discussion in early December, we have a different
+recollection. At that time, notwithstanding our motion to stay discovery,
+we expressed a willingness to work with you and Brad to attempt to
+identify items that might be producible by the government pursuant to a
+narrowed and specific request for production that seeks relevant items
+and where the production by the government would not be burdensome
+or otherwise objectionable. We remain willing to work toward such a
+goal, but have been waiting to hear from you or Brad to begin the
+process of identifying the items that would be the subject of such a
+narrowed request. In fact, Marie called Brad several weeks ago to discuss
+the requests for admissions, but they were unable to connect at that
+time.
+If the government's position on these two points causes you to withhold your
+agreement to our requested extension, we would be happy to inform the Court
+that you oppose our motion for extension of time. If we do not hear from you by
+7:00 pm Miami time that you agree to the requested extension notwithstanding
+the government's position on these two points, we will report to the Court that
+you object to the extension. Please be sure to send any reply concerning your
+position to l
+I as he will be filing the motion for extension this evening.
+Thanks, and have a nice weekend.
+1. Sanchez
+United States Attorney's Office
+
+
+E-mail:
+From: Paul Cassell [mailto:
+Sent: Friday, January 06, 2012 10:41 AM
+To:
+(USAFLS); Brad Edwards
+Cc:
+• (USAFLS);
+1. (USAFLS)
+Subject: RE: Replies and Responses Due on January 6, 2012
+Hey
+As you know, we're happy to try and be accommodating. We would be
+glad to consent to additional time, but would ask in exchange for two
+things:
+1. The various delays mean that several motions have now been (or
+will shortly be) pending for more than 90 days, triggering a 90 day
+report obligation under the local rules. We would trust you would
+be willing to file that with Judge Marra.
+2. When we finished our telephone call with you some weeks back,
+Brad and I understood that we would be receiving (a) some initial
+discovery in the case and (b) a list of additional discovery that we
+could expect if your motion to dismiss is denied. But we have yet to
+receive anything at all regarding discovery. We would trust that you
+will carry through on what we understood you had agreed to in the
+telephone call.
+Again, we are happy to help - but would ask you to help us on these two
+points. Thanks!
+Paul Cassell
+Co-counsel for Jane Doe #1 and Jane Doe #2
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+S.J. Quinney College of Law at the University of Utah
+Email: |
+http://www.law.utah.edu/profiles/default.asp?
+PersonID=57&name=Cassell,Paul
+CONFIDENTIAL: This electronic message - along with any/all
+attachments - is confidential. This message is intended only for the use of
+the addressee. If you are not the intended recipient, the person
+responsible to deliver it to the intended recipient, you may not use,
+disseminate, distribute or copy this communication. If you have received
+this message in error, please immediately notify the sender by reply
+electronic mail and delete the original message. Thank you.
+
+
+(USAFLS) [mailto:
+Sent: Thursday, January 05, 2012 5:24 PM
+To: Paul Cassell; Brad CUSAdS
+• (USAFLS);
+Subject: Replies and Responses Due on January 6, 2012
+.. (USAFLS)
+Paul and Brad,
+Happy New Year. I need to ask if you have an objection to the
+government seeking a second enlargement of time, up to Tuesday,
+January 24, 2012, to file replies to the victims' two responses to the
+government's motion to dismiss and motion to stay discovery, and
+responses to the victims' protective motion to compel and protective
+motion for remedies.
+Marie is preparing for an evidentiary hearing in a 28 U.S.C. 2255 motion,
+which is scheduled for January 24, 2012. I am scheduled to go to trial in
+a tort case sometime during the two week trial period commencing
+January 17, 2012. I have spent most of the preceding two weeks getting
+ready for the trial. My colleague •
+1. with sporadic assistance
+from Marie and I, will be preparing the responses and replies.
+Please let me know if you have any objections. Thanks.
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/4d5a0456e0b82fa399a4b64639860aab230d7d5ebb026d431777c856398ab00c.receipt.json b/vision-fixhub/ds9-unparsed-06/4d5a0456e0b82fa399a4b64639860aab230d7d5ebb026d431777c856398ab00c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..539696e5985890997a38639dd6fb9e6ecdee5555
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4d5a0456e0b82fa399a4b64639860aab230d7d5ebb026d431777c856398ab00c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -151,
+  "dataset": "marble-joined",
+  "doc_id": "4d5a0456e0b82fa399a4b64639860aab230d7d5ebb026d431777c856398ab00c",
+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "b41ec4cbac715e813f025ac0882cece951983682748d37830197a474ea4f8ab4",
+  "output_sha256": "7c12feb95cee8e4ad88d214fb90e9ee845b96d33d9a521c8f5e8681f091913ac",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4d9e4bee25a0f2180d2e3be27122c159992f8ad29e66c56b0f2d0206cfca1f50.md b/vision-fixhub/ds9-unparsed-06/4d9e4bee25a0f2180d2e3be27122c159992f8ad29e66c56b0f2d0206cfca1f50.md
new file mode 100644
index 0000000000000000000000000000000000000000..07e4d56346f7a341408ebaaf57598d2aad0bfd66
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4d9e4bee25a0f2180d2e3be27122c159992f8ad29e66c56b0f2d0206cfca1f50.md
@@ -0,0 +1,21 @@
+Formatted Name
+Gerald Lefcourt, Esq.
+Address • Work
+New York, NY 10021
+United States of America
+Address • Work
+New York, NY 10021
+United States of America
+Email
+Full Address • Work
+New York, NY 10021
+Full Address • Work
+New York, NY 10021
+Name
+Gerald Lefcourt Esq.
+Telephone Number • Work
+Telephone Number • Fax, Work
+VCard Version
+3.0
+COMPANY
+Gerald P. Lefcourt, P.C.;
diff --git a/vision-fixhub/ds9-unparsed-06/4d9e4bee25a0f2180d2e3be27122c159992f8ad29e66c56b0f2d0206cfca1f50.receipt.json b/vision-fixhub/ds9-unparsed-06/4d9e4bee25a0f2180d2e3be27122c159992f8ad29e66c56b0f2d0206cfca1f50.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6a70cd407cdbb7642a23343328c2e7fae413523f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4d9e4bee25a0f2180d2e3be27122c159992f8ad29e66c56b0f2d0206cfca1f50.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "4d9e4bee25a0f2180d2e3be27122c159992f8ad29e66c56b0f2d0206cfca1f50",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "db217a1d6bcbc949884876044d746bad5ffeb4ce76dd7117f948df3a3877a6c3",
+  "output_sha256": "32e04151638e993e189a268392d1b85bee2ecf8887e692b7062d70c77f9fec68",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4dcb51e0acccc4a0d7968355eee1b483b697c01254e221482ab42df1d63fb08c.md b/vision-fixhub/ds9-unparsed-06/4dcb51e0acccc4a0d7968355eee1b483b697c01254e221482ab42df1d63fb08c.md
new file mode 100644
index 0000000000000000000000000000000000000000..8fbd6fea165ba19f9d9c7637532caa3a4c5b66ab
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4dcb51e0acccc4a0d7968355eee1b483b697c01254e221482ab42df1d63fb08c.md
@@ -0,0 +1,53 @@
+From:
+To:
+Subject: Activity in Case 9:08-cv-80119-KAM Doe |. Epstein Order on Motion for Reconsideration
+Date: Thu, 01 Apr 2010 17:38:03 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. Distriet Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 4/1/2010 at 1:38 PM EDT and filed on 4/1/2010
+Case Name:
+Doe | Epstein
+Case Number:
+9:08-cv-80119-KAM
+Filer:
+Document Number: 513
+Docket Text:
+OMNIBUS ORDER Denying [477] Motion for Reconsideration ; Denying [488] Motion for
+Reconsideration. Signed by Magistrate Judge Linnea R. Johnson on 4/1/2010. (sa)
+9:08-cv-80119-KAM Notice has been electronically mailed to:
+Adam D. Horowitz
+Bradley James Edwards
+Isidro Manuel Garcia
+Jack Alan Goldberger
+Jack Patrick Hill
+Jeffrey Mare Herman
+Katherine Warthen Ezell
+Michael James Pike
+
+
+Paul G. Cassell
+Richard Horace Willits
+Robert. Josefsberg
+Robert Deweese Critton, Jr
+Stuart S. Mermelstein
+9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-
+Martin G. Weinberg
+20 Park Plaza
+Boston, MA 02116
+The following documents) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=4/1/2010] [FileNumber=7426396-0]
+[51afd9494c7a5f56fc52de780d34221b5bba75ab7aec11101cc4bd51d0474e79cbad
+f6d621882664c7e5fec6bdda9b3cd6765793450c917a9c5e77b9374e16f7]]
diff --git a/vision-fixhub/ds9-unparsed-06/4dcb51e0acccc4a0d7968355eee1b483b697c01254e221482ab42df1d63fb08c.receipt.json b/vision-fixhub/ds9-unparsed-06/4dcb51e0acccc4a0d7968355eee1b483b697c01254e221482ab42df1d63fb08c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..300ed65d6515e81a7c3f504555176541b6b4226e
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4dcb51e0acccc4a0d7968355eee1b483b697c01254e221482ab42df1d63fb08c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "4dcb51e0acccc4a0d7968355eee1b483b697c01254e221482ab42df1d63fb08c",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "c7d2b81733b4a27dc4815ea819829e9d477475ca3df5ddee968741969db02e50",
+  "output_sha256": "d05b3cb32bbf01874a4464a4faf36e0167ca1fd3749d8d7e138cdac630b09ac6",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4e12ccf3ce1273b134cfd5c4f3d90891e4947bec869148c25078fac6adfb0352.md b/vision-fixhub/ds9-unparsed-06/4e12ccf3ce1273b134cfd5c4f3d90891e4947bec869148c25078fac6adfb0352.md
new file mode 100644
index 0000000000000000000000000000000000000000..8190dc1d91810b914c42495f578c704209b2482a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4e12ccf3ce1273b134cfd5c4f3d90891e4947bec869148c25078fac6adfb0352.md
@@ -0,0 +1,10 @@
+From:
+To: Spencer Kuvin
+Subject:|
+v. Jeffrey Epstein
+Date: Fri, 22 Jan 2010 19:55:26 +0000
+Importance: Normal
+Attachments: 20100122_Kuvin_Ltr_re_Reiter_Deposition.pdf
+Dear Mr. Kuvin - A response to your letter is attached.
+<<20100122 Kuvin Ltr re Reiter Deposition.pdf>>
+Assistant U.S. Attorney
diff --git a/vision-fixhub/ds9-unparsed-06/4e12ccf3ce1273b134cfd5c4f3d90891e4947bec869148c25078fac6adfb0352.receipt.json b/vision-fixhub/ds9-unparsed-06/4e12ccf3ce1273b134cfd5c4f3d90891e4947bec869148c25078fac6adfb0352.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..33647b83155d6c864d305d1d0dea6ebf8e9661fc
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4e12ccf3ce1273b134cfd5c4f3d90891e4947bec869148c25078fac6adfb0352.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "4e12ccf3ce1273b134cfd5c4f3d90891e4947bec869148c25078fac6adfb0352",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "1feba2ccd1be424cbbc57b518b04178139736777d13846c73069d4a08e522355",
+  "output_sha256": "3c7ff2544df3e54d08ec51966e75cfb3bc68603628a2be70244c6c66927a5887",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4f495517afd15b5cf4f0708251f3ab679e995ed31f320a80bed0fe4e9d1d55ab.md b/vision-fixhub/ds9-unparsed-06/4f495517afd15b5cf4f0708251f3ab679e995ed31f320a80bed0fe4e9d1d55ab.md
new file mode 100644
index 0000000000000000000000000000000000000000..012379eac793c73ffbb47c59bc8ed19724ea3c9c
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4f495517afd15b5cf4f0708251f3ab679e995ed31f320a80bed0fe4e9d1d55ab.md
@@ -0,0 +1,13 @@
+From:
+Sent:
+To:
+Cc:
+Subject:
+- (USAFLS)
+Roy BLACK I
+Thursday, January 21, 2010 2:59 PM
+(USAFLS)
+Yesterday's Letter
+: On second thought my letter yesterday went too far in one respect. So that there is no misunderstanding of
+courts to resolve outstanding legal issues regarding the criteria for payment and the amount of payment owed. I hope
+this clarifies our concern in this one area. Thanks Roy
diff --git a/vision-fixhub/ds9-unparsed-06/4f495517afd15b5cf4f0708251f3ab679e995ed31f320a80bed0fe4e9d1d55ab.receipt.json b/vision-fixhub/ds9-unparsed-06/4f495517afd15b5cf4f0708251f3ab679e995ed31f320a80bed0fe4e9d1d55ab.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e011ef10201738969aae42b472d458975428a318
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4f495517afd15b5cf4f0708251f3ab679e995ed31f320a80bed0fe4e9d1d55ab.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "4f495517afd15b5cf4f0708251f3ab679e995ed31f320a80bed0fe4e9d1d55ab",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "27538552c78d1b466e7e41228e5072e6f83210c90cc291e93fd3320972322b46",
+  "output_sha256": "8c1f2b8b6ff63f038c83191dae4824bc85726a69c6e0e857c6f1e4c7adb46f02",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4f77f7fd89ae48cec4839cf564ca65e8541e8519410a4c6eda51833fdc244156.md b/vision-fixhub/ds9-unparsed-06/4f77f7fd89ae48cec4839cf564ca65e8541e8519410a4c6eda51833fdc244156.md
new file mode 100644
index 0000000000000000000000000000000000000000..8326ff860e908b0e4013bc24b51dc1520322ba1a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4f77f7fd89ae48cec4839cf564ca65e8541e8519410a4c6eda51833fdc244156.md
@@ -0,0 +1,36 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov»
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80893-KAM Doe |. Epstein Endorsed Order
+Date: Wed, 07 Jul 2010 21:16:29 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer: PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. Distriet Court
+Southern Distriet of Florida
+Notice of Electronic Filing
+The following transaction was entered on 7/7/2010 at 5:16 PM EDT and filed on 7/7/2010
+Case Name:
+Case Number:
+Filer:
+Doe | Epstein
+9:08-cv-80893-KAM
+Document Number: 203(No document attached)
+Docket Text:
+*Endorsed Order directing Clerk to restrict Doc No. 202 from public view due to confidental
+information. Signed by Sr. Magistrate Judge Peter R. Palermo on 7/7/2010. (ds)
+0-084cz 80802 KAN Notice has been doctronical mailed too
+Bradley James Edwards
+brad@pathtojustice.com, beth@pathtojustice.com
+Jack Alan Goldberger jagesq@bellsouth.net, nalanis@agwpa.com
+Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com
+Michael James Pike MPike@bclclaw.com, bobbie@bclclaw.com, jcadwell@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Robert Deweese Critton, Jr rcrit@bclclaw.com, bobbie@bclclaw.com
+9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
diff --git a/vision-fixhub/ds9-unparsed-06/4f77f7fd89ae48cec4839cf564ca65e8541e8519410a4c6eda51833fdc244156.receipt.json b/vision-fixhub/ds9-unparsed-06/4f77f7fd89ae48cec4839cf564ca65e8541e8519410a4c6eda51833fdc244156.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..89eb76b07c6c0d0c5864ab26b27ff15a36d9eb87
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4f77f7fd89ae48cec4839cf564ca65e8541e8519410a4c6eda51833fdc244156.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "4f77f7fd89ae48cec4839cf564ca65e8541e8519410a4c6eda51833fdc244156",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "192596d68790eb8ebee204f8c2319d719740db93697ceb33345c349b2b4036f5",
+  "output_sha256": "b0e611246573c2fe011621b22eb7d7cf26a351cf422213a673336e6a2713d0ca",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4fad279c5e614634da7110e96b7cae8fbcda0027319006daf63e9cfeaf90016e.md b/vision-fixhub/ds9-unparsed-06/4fad279c5e614634da7110e96b7cae8fbcda0027319006daf63e9cfeaf90016e.md
new file mode 100644
index 0000000000000000000000000000000000000000..d698390b7b022b5f982257a9a41a40dd58550f8d
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4fad279c5e614634da7110e96b7cae8fbcda0027319006daf63e9cfeaf90016e.md
@@ -0,0 +1,44 @@
+From:
+To:
+Subject: Activity in Case 9:08-cv-80893-KAM Doe I. Epstein Clerks Notice of Docket Correction and
+Instruction to Filer - Attorney
+Date: Tue, 07 Sep 2010 13:36:30 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered on 9/7/2010 at 9:36 AM EDT and filed on 9/7/2010
+Case Name:
+Doe L. Epstein
+Case Number:
+9:08-cV-80893-KAM
+Filer:
+WARNING: CASE CLOSED on 07/20/2010
+Document Number: 216(No document attached)
+Docket Text:
+Clerks Notice to Filer re [214] Defendant's MOTION for Protective Order and Objection to
+Disclosure of Certain Documents with Integrated Memorandum of Law MOTION for Leave to
+File. Motion with Multiple Reliefs Filed as One Relief; ERROR - The Filer selected only
+one relief event and failed to select the additional corresponding events for each relief
+requested in the motion. The docket entry was corrected by the Clerk. It is not necessary to
+refile this document but future filings must comply with the instructions in the CM/ECF
+Attorney User's Manual. (tp)
+9:08-ev-80893-KAM Notice has been electronically mailed to:
+Bradley James Edwards
+Jack Alan Goldberger
+Katherine Warthen Ezell
+Lilly Ann Sanchez
+
+
+Michael James Pike
+Paul G. Cassell
+Robert Deweese Critton, Jr
+9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
diff --git a/vision-fixhub/ds9-unparsed-06/4fad279c5e614634da7110e96b7cae8fbcda0027319006daf63e9cfeaf90016e.receipt.json b/vision-fixhub/ds9-unparsed-06/4fad279c5e614634da7110e96b7cae8fbcda0027319006daf63e9cfeaf90016e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..5ef842dd3be110e98d45c16e88a82b5933ce65f3
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4fad279c5e614634da7110e96b7cae8fbcda0027319006daf63e9cfeaf90016e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "4fad279c5e614634da7110e96b7cae8fbcda0027319006daf63e9cfeaf90016e",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "c2d4145aa2c749726c68fe36ea886590707d9514f7cd7b9aee74b81674322215",
+  "output_sha256": "3c260dceaa793a7ff5a0f8e85499ce813c025cf3d1e165f5f72736bc98ab6fae",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/4ff550263b1010380aeb0ec2498f5f0c6be3a89dc776ad0be014e31cbf04d6ea.md b/vision-fixhub/ds9-unparsed-06/4ff550263b1010380aeb0ec2498f5f0c6be3a89dc776ad0be014e31cbf04d6ea.md
new file mode 100644
index 0000000000000000000000000000000000000000..5913b4208f9a256834ce1523d9fbd3271b76e224
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4ff550263b1010380aeb0ec2498f5f0c6be3a89dc776ad0be014e31cbf04d6ea.md
@@ -0,0 +1,1850 @@
+Questions or Changes?
+• attwireless.com
+Toll Free 1 866 293-4634
+611 from your wireless phone
+• TTY users - 1 866 4-AWS-TTY
+SUMMARY OF MONTHLY CHARGES FOR ACCOUNT 0031035751
+Previous
+Payments
+Balance
+Received
+66.50
+-66.50
+Account
+Adjustments
+0.00
+Balance
+Forward
+0.00
+Your billing cycle ended on June 14, 2004
+Current Monthly Charges
+Subscriber Adjustments
+Monthly Service
+Monthly Usage
+Charges
+Credits
+Taxes, Surcharges & Regulatory Fees
+Total Current Monthly Charges DUE UPON RECEIPT
+TOTAL AMOUNT DUE
+Date of Invoice: June 15, 2004
+Current Monthly
+Charges
+69.82
+Total
+Amount Due
+69.82
+0.00
+54.97
+2.75
+0.00
+0.00
+12.10
+69.82
+69.82
+ALL MONTHLY CHARGES IN YOUR BILL ARE DUE & PAYABLE FOR
+THE ENTIRE BILLING CYCLE COVERED BY THE BILL. FOR ANY
+TERMINATION (INCLUDING WHEN YOU SWITCH YOUR WIRELESS
+NUMBER TO ANOTHER CARRIER), YOU WILL BE RESPONSIBLE FOR
+PAYMENT FOR ALL FEES AND CHARGES THROUGH THE END OF THE
+BILLING CYCLE. FOR MORE INFORMATION ABOUT BILLING AND
+YOUR RIGHTS AND OBLIGATIONS, PLEASE CONSULT THE TERMS
+AND CONDITIONS OF SERVICE IN YOUR SUBSCRIBER AGREEMENT.
+AT&T WIRELESS APPRECIATES YOUR BUSINESS
+lease Retum This Portion With Your Paymen
+sit the General Terms and Contions to wireles some.
+AT&iT Wireless
+Account Name:
+Date Due
+UPON RECEIPT
+Note: =>
+We Print on
+Front and Back
+Service # 5613797824
+Account # 0031035751
+Total
+Amount Due
+69.82
+Chack her for change.
+Amount
+Paid
+#BWNHNGB
+#0000000310357512# w
+2003254 02 AT 0.517 "AUTO T20 061433411.S.42.01.1034.0000
+AT&T WIRELESS
+PO BOX 8229
+AURORA IL 60572-8229
+
+
+
+Recurring Electronic Fund Transfer (REFT): To enroll: sign below, check the REFT box on the reverse side and
+remit with this month's payment. Keep paying your bill until your statement indicates "Do Not Pay". REFT
+Agreement: 1 authorize my financial institution to deduct the amount of my monthly wireless phone bill from the
+account associated with the enclosed check and remit payment to AT&T Wireless. This authority will be effective
+until I notify AT&T Wireless to terminate it. I agree that I may be assessed a service charge (up to $20) or late fee
+or both if a payment is returned by my bank. For more information visit attwireless.com/ocs or call 1 866 293-4634.
+Please keep a copy of the form below and this REFT Agreement for your records or retain a copy of the blank form
+from next month's invoice.
+Questions? We can help: AT&T Wireless appreciates your business and welcomes the opportunity to assist you.
+As part of our commitment to you, we are always adding new calling plans and promotions to match your individual
+needs. Visit our website at attwireless.com or contact Customer Care by dialing 611 from your wireless phone or 1
+866 293-4634. ¿ Sabías que también ofrecemos servicio al cliente en tu idioma? Marca 611 desde tu teléfono
+inalámbrico ó 1 866 293 4634 desde cualquier teléfono y oprime el *.
+Driving Wireless Safety: Your wireless phone gives you the freedom and flexibility to stay in touch when you
+travel, but don't let a phone call distract you from driving safely. Use hands-free device if allowed or required by
+law. Call Carefully, Arrive Safely.
+AT&T Wireless Processing Fees: Accounts suspended for non-payment will be subject to a $25 reactivation fee
+per line and may be assessed a security deposit prior to reinstatement. Checks returned for non-sufficient funds will
+be charged up to a $20.00 fee.
+Local Tax: Local taxes are based on local government boundaries, the address information you provide for your
+account and/or your wireless telephone number. Please review the local tax charges on your bill. If you believe
+there is an error in the local tax charge, please contact us immediately at 1 866 293-4634. Please note that some
+local or state laws may require you to follow special procedures when notifying us about a local tax dispute. You
+may also use the form below to notify us of any change to your taxing address. Thank you for your cooperation.
+Early Termination Fee (ETF): If you cancel service before your contract end date (including if you switch your
+wireless number to another carrier), you will be charged an Early Termination Fee of up to $200.
+Please Send Correspondence To:
+AT&T Wireless Next Generation Correspondence
+P.O. Box 68056
+Anaheim Hills, CA 92817-8056
+2003254.000023825.6
+Change of Address Only. Please print address clearly and check the box on the reverse side. Please contact Customer Care to change the
+Name and transfer Financial Responsibility.
+New Billing Address
+City
+State
+Zip
+Home Phone (
+Work Phone (.
+If your billing address is NOT your Tax Address*, please enter the Tax Address below. (Multi-line accounts should attach a list of each wireless number and
+the respective Tax Address.)
+New Tax Address*
+Wireless Number (
+City
+State
+Zip
+Inder Federal laws, your Tax Address must be: your primary place of use, your residential or business address, and located within AT&T Wireless
+censed service area. Non-business customers on AT&T Digital One Rate, Regional Advantage or Shared Advantage plans must use their residenti
+address as their tax address.
+Recurring Electronic Fund Transfer (REFT) Enrollment. Please read the agreement on the top portion of this page, sign below and check the
+"REFT Registration" box on the reverse side.
+6.1 - 3G
+Financial Account Holder Signature
+• • I do not wish to receive email notilication of special ofers avalable to AT&T Wireless customers.
+
+
+
+ACCOUNT DETAILS
+Detail of Payments - Thank You!
+Item Description
+1 PAYMENT
+Total of Payments
+Date Applied/Reversed Payment Amount
+06/13/04
+-66.50
+Current Subscriber Monthly Charges and Credits
+Subscriber Number
+Subscriber Name
+
+Total Current Subscriber Monthly Charges and Credits
+Total Current Monthly Charges
+SUMMARY OF CURRENT ACTIVITY
+Monthly Service Charges
+Item Description
+1 CALL WAITING
+2 AT&T TEXT MESSAGING
+3 CALLER ID
+4 WORLDCONNECT
+5 AT&T VOICEMAIL
+6 DETAIL BILLING
+7 $39.99 CHARTER OFFER
+8 1000 NIGHT AND WEEKEND MINUTES
+9 CALL FORWARDING
+10 THREE WAY CALLING
+Total Monthly Service Charges
+Service Dates
+05/15/04 - 06/14/04
+05/15/04 - 06/14/04
+05/15/04 - 06/14/04
+05/15/04 - 06/14/04
+05/15/04 - 06/14/04
+05/15/04 - 06/14/04
+05/15/04 - 06/14/04
+05/15/04 - 06/14/04
+05/15/04 - 06/14/04
+05/15/04 - 06/14/04
+Monthly Usage Charges
+Item Description
+1 500 ADD'L ANYTME MIN
+2 1000 NIGHT/WKEND MIN
+3 MESSAGE RETRIEVAL
+4 100 INCL. MSGS SENT
+5 CALL WAITING
+6 ROAM TEXT MSG
+7 DROP CALL CREDIT
+8 411 INFO
+9 INCLUDED MINUTES
+Total Monthly Usage Charges
+Onty Used
+500 MIN
+871 MIN
+24 EVT
+331 MIN
+Taxes, Surcharges and Regulatory Fees
+Item Description
+1 UNIVERSAL CONNECTIVITY CHARGE
+2 STATE COMM SERVICE TAX
+3 LOCAL COMM SERVICE TAX
+4 COUNTY 911 TAX
+-66.50
+-66.50
+69.82
+69.82
+69.82
+0.00
+4.99
+0.00
+0.00
+0.00
+0.00
+39.99
+9.99
+0.00
+0.00
+54.97
+0.00
+0.00
+0.00
+0.00
+0.00
+onc
+
+SUMMARY OF CURRENT ACTIVITY - CONTINUED
+Taxes, Surcharges and Regulatory Fees - Continued
+Item Description
+5 FEDERAL TAX
+Total Taxes, Surcharges and Regulatory Fees
+12.68
+TOTAL CHARGES FOR (561)379-7824
+69.82
+DETAIL OF CURRENT ACTIVITY
+VOICE USAGE FOR (561)379-7824
+Item Date Time Called
+1 05/14 06:19P
+2 05/14 06:22P (561)662-7668
+Calls To
+INCOMING
+WPALMBEACH FL
+3 85/14 06.250
+05/15 12:42A (561)379-7824
+05/15 01234
+7 05/15 01:42A
+INCOMING
+15/15 11:04A
+5/15 02:15F
+23
+CH
+10 05/15 03:00P (561\282-8891
+11 05/15 04:02P
+12
+561|310-6943
+13
+05/15 06:15P (561)236-3299
+05/15 06:16P
+Onty
+Used
+Rate Description
+500 ADD'L ANYTME MIN
+500 ADD'L ANYTME MIN
+0515 06:31P
+/15
+06:37P
+06:47P (561)317-2428
+B8888998
+(561)662-1628
+IN
+(561)662-1628
+(561)644-6817
+1954
+1)776-4192
+
+(551776-4782
+1776-4192
+
+
+
+
+Item Date Time Called
+Onty
+Used
+49 05/12 10:580
+10-59P
+51 05/15 10:56P
+52
+05/15 10:58P (561)601-8413
+53
+05/15 10:59P
+54
+05/15 11:36P (561)644-6817
+05/18
+J1:01A (581723-3702
+01:01A
+57
+16 04:13A
+59
+05/16
+09:05A
+05/16 17
+1:05A (5611309-1375
+60
+05/16 11:05A
+61 05/16 11:36A
+62
+05/16 01:58P
+63
+05/16 02:00P
+Calls To
+COMIN
+COMIN
+INCOMING
+AKE WORTH FL
+WPALMBEACH FL
+WALMBEACH FL
+INCOMING
+NOOMING
+VPALMBEACH FL
+INCOMING
+INCOMING
+NCOMING
+NCOMING
+64 05/16 03:28P
+2 MIN
+2MIN
+LEVT
+3 MIN
+2MIN
+(561)790-3459
+(561)790-3459
+5611317-2428
+Rate Description
+1000 NIGHT KEN
+1000 NIGHT/KEND
+000 NIGHT/WKEN
+000 NIGHT/WK:
+1000 NIGHT/WKE!
+000 NIGHT/WKE
+OÓO NIGHT/W
+1000 NIGHT/WKEN
+NIGHT/WKEND
+1000 NIGHT/WKEND
+ALL WAILIN
+00 NIGHT/KEN
+D00 NIGHL/WKEN
+00 NIGHTWKEN
+10
+FL
+2MIN
+2MIN
+2 MIN
+1 MAIN
+2MIN
+TEVT
+4 MIN
+2003254.000023826
+:13P
+зg8ğ9ğ
+/17 07:19P
+88568
+
+(631)252-7243
+(561j818-3331
+(561)644-6817
+
+(954)776-3707
+(561)662-6615
+(561)324-1517
+SISTE
+WPALI
+MPA
+
+Item Date Time Called
+Onty
+Used
+H13 05/19 11:304
+1-302
+114 05/19 11:45A
+(561)202-7395
+115 05/19 01:04P
+116 05/19 03:04P
+17 05/19 03:11P (561)236-3299
+18 05/19 03:188
+119 05/19 03:45P
+05/19 04:18P
+05/19 04:54P
+Calls To
+COMIN
+COMIN
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+COMING
+COMING
+INCOMING
+05/19 08:02P 561)818-3531
+05/19 05-26P
+19
+611317-2428
+127 05/19 05:53P
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+88858 88885
+99889
+88888
+2MIN
+IMIN
+2 MIN
+I MIN
+2 MIN
+IMIN
+EV
+888
+3MIN
+2MIN
+4MIN
+88888
+'5617
+1317
+-2428
+INCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+8895997799998083788090808838 8088
+38588
+(561)
+1379-
+-7824
+(561)282-
+-8891
+
+IMIN
+2MIN
+1561/378-
+6-2903
+COMIN
+ICOMIN
+(561)792
+-63
+175
+COMIN
+LAUDERDLI
+4 MIN
+2 MIN
+13 MIN
+4 MIN
+VPALMBEACH F
+(PALMBEACH F
+(561)
+1379-
+COMING
+VPALMBEACH FI
+5888
+25
+(561)
+1317-2428
+WPALMBEACH FL
+EMIN
+2MIN
+EMIN
+3MIN
+1EVT
+3MIN
+1EV
+36.
+10P
+Rate Description
+500 ABBL ANYTE MIN
+500 ADD'L ANYTME MIN
+500 ADD'L ANYTME MIN
+00 ABB'L ANYTIME MI
+DD'
+500 ADD'L ANYTME MIN
+500 ABBL
+NYTME MI
+ANYTME MI
+ZZ
+500 ADD'L ANYTME MIN
+BABBIL ANYIME M
+50 ABBL ANYTE MIN
+500 ADD'L ANYTME MIN
+MESSAGE RETRIEVA
+00 ADD'L ANYTME MIl
+500 ADD'L ANYTME MIN
+000 NIGHT WRENB ME
+TAWKEND MI
+CALL WAILING
+000 NIGH
+WKEND MIN
+500 ADD'L ANYTME MIN
+500 ADD'L ANYTME MIN
+500 ADDL
+500 ADD'
+ANY ME MIN
+500 ADD'L ANYTME MIN
+500 ADBL ANTME MIN
+500 ADD'L ANYTME MIN
+ALANE MIN
+SO ABLANYME MIN
+500 ADD'L ANYTME MIN
+500
+500 ABBIL ANYTME MIN
+500 ADD'L ANYTME MIN
+BADD'L ANYTEL
+500 ADDL ANYME MIN
+SALAME MIN
+500 ADD'L ANYTME MIN
+500 ABB'L ANYTME MIN
+500 ADD'L ANYTME MIN
+100 ADD'L
+ANYTME MIN
+MESSAGE RETRIEVAL
+X00 NIGHTWKEND M
+OO NIGHT/KEND M
+100 NAMED MINU
+
+
+
+Item Date Time
+Called
+172 05/22 02:13P (561)379-7824
+Calls To
+WPALMBEACH FL
+173 05/22 02:20P
+174 05/22 02:24P
+175 05/22 02:36P (561)790-3459
+176 05/22 02:37P (561)790-3459
+177 05/22 04:09P
+178 05/22 04:11F
+179 05/22 04:12P (561)790-3459
+I8D 05/22 04:14P
+61)790-479
+182
+05/22 06:48P
+611798-944
+05/22 06:50P
+183
+05/22 07:04P
+(561)790-4794
+(561)662-7668
+184
+02 07:06P
+185 05/22 07:30P
+186
+05/22 09:27P (561)790-4794
+187 05/22 09:47P
+190 05/22 10:43P (561)379-7824
+191
+05/22 10:55P (954)303-7533
+192 05/22 11:20P
+
+(561)715-6303
+161317-2426
+561 792-6375
+954)776-4192
+5611792-6375
+1861)397-2428
+(561|317-2428
+(561)792-6375
+199
+INCOMING
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+NCOMING
+NCOMING
+WPALMBEACH FL
+PALMBEACH
+WPALMBEACH FL
+NPALMBEACH FL
+NCOMING
+COMIN
+PALMBEACH R
+INCOMING
+INCOMING
+WPALMBEACH FL
+FTLAUDERDL FL
+WPALMBEACH FL
+TLAU!
+INCON
+FTLAUD
+WPALM
+WPALM
+FTLAUD
+FTLAUD
+FiLAUD
+Qnty
+Used Rate Description
+DO N
+2 MIN
+2 MIN
+2 MIN
+3MIN
+1000 NIGHT/WKEND MIN
+00 NIGHT WKEND M
+DO NIGHT WKEND M
+1000 NIGHT/WKEND MIN
+DD0 NIGHT/WKEND M
+1000 NI
+HT/WKEND M
+1000 NIGHT/WKEND MIN
+DDO NIGHTWKEND MIN
+DO NIGHT/WKEND MIl
+1000 NIGHT/WKEND MIN
+000 NIGHT/WKEND MIN
+1000 NIGHT/WKEND MIN
+000 NIGHTWKEND MIN
+000 NIGHT/WKEND MIN
+2
+IN
+2 MIN
+3MIN
+1000 N
+1000 MI
+1000 NI
+1000 N
+1000 N
+1000 NIG
+BRENNONE I
+PRR88888888
+
+14
+(954)549-5982
+8888
+
+Item Date Time
+Called
+234 05/23 08:17P (561)790-4794
+235 05/23 08:18P (561 310-9164
+236 05/23 08:38P (561)790-4794
+: 05/23 09:02P (561)596-3561
+240 05/23 18:31P
+05/24 09:43A (561)792-9082
+05/24 01:18P (561)317-2428
+05/24 04:01F
+244 05/24 05:05P
+811236-3299
+05-290
+(561)662-1628
+Calls To
+WPALMBEACH FL
+WPALMBEACH FL
+'ALMBEACH
+COMIN
+WPALMBEACH FL
+COMING
+COMING
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+INCOMING
+WALMEAL
+FL
+(561)310-6943
+(561|662-6615
+(561)310-6943
+(561)310-6943
+(561)236-3299
+561)422-7006
+561379-7824
+279
+05/25
+05:00P
+02P
+BEENEYENE
+
+NONNANANN
+
+20:8408880988
+(861,599-3588
+chos
+Onty
+Used Rate Description
+ALL WAITIN
+000 NIGHT/KEND MIN
+2 MIN
+14 MIN
+7MIN
+3 MIN
+2 MIN
+3 MIN
+3MIN
+....
+000 NIGHT/WKEND M
+00 NIGHT WKEND M
+500 ADD'L ANYTME MIN
+500 ADD'L ANYTE MIN
+OO ADD'L ANYTME MIN
+500 ADD'L ANYTME MIN
+TME
+:MIN
+OD ADD'L ANYTME MIN
+00 ADD'L ANYTME MIN
+50
+2003254.000023827
+
+
+2003254.000023827
+
+Item Date Time
+Called
+6 04:52Р (561)596-3561
+298 05/26 04:53P
+299 05/26 05:34P
+300 05/26 05:41P (561)792-6375
+302 0526 05445
+26 05:468
+303 05/26 07:59P
+305
+05/26 07:59P (561)662-2721
+05/26 08:00P
+307
+83/26 08:05P (561)795-6137
+08:05P
+05/26 08:11P
+05/26 08:125 561/397-2328
+310 05/26 08:14P
+10:
+1:58P
+54P
+11-58P
+12:00A
+(5611818-3331
+2:06A
+18 Д
+18:03A
+10:09A
+(561)282-8891
+10:13A
+101
+•ERI
+(561)282-8891
+10:54A
+11:00A
+02:06P
+03:03P
+
+
+02:38A
+
+(561)310-6943
+5611818-333
+61801-359
+
+
+1861818.
+356
+-356
+:30P
+3331
+19189
+(561)310-6943
+15611599-
+-3561
+Calls To
+INCOMING
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+NOOMING
+COMING
+INCOMING
+WPALMBEACH FL
+NCOMING
+WPALMBEACH FL
+NCOMING
+INCOMING
+COMING
+JCOMIN
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+EACH
+INCOM
+WPALMBEACH FL
+WALNES
+ACH
+EACH
+COMING
+COMING
+WALNBEACH EL
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+MING
+99983
+OMING
+3022
+MINE
+INC
+EACH FL
+Onty
+Used
+MI
+2 MIN
+1 EVI
+IMIN
+2MN
+1 EVT
+IMIN
+Rate Description
+500 ABBY ANY ME MIN
+500 ADD'L ANYTME MIN
+WAITING
+BOO ADDI ANY ME MIN
+500 ADD'L ANYTME MIN
+500 ABB'L ANYTME MIN
+500 ADD'L ANYTME MIN
+0 ADD'L ANYTME MI
+J0 ADD'L ANYTME MIl
+CALL WAITING
+500 ABBL ANYTE MIN
+00 ADD'L ANYIME MIl
+0 ADD'L ANYTME MIl
+500
+FF
+2 MIN
+FF
+ID
+ABBE
+.....
+
+Item Date Time
+Called
+359 05/28 05.06P (854) 48-5882
+360 05/28 06:54P (561 317-2428
+361 05/28 06:55P
+362 05/28 07:11P (561)715-6303
+364 05/28 0728Р
+365 05/28 09:30P
+§ 05/28 10:1
+128 11:10
+05/28 11:18P
+05/28
+H1:44P
+• 11:49P
+05/28 11:49Р
+51 236-329
+51310-694
+Calls To
+(PALMBEACH F
+OLLYWOO
+FL
+WPALMBEACH FL
+INCOMING
+DELRAY BCH FL
+MING
+INCOMING
+COMIN
+COMIN
+INCOMING
+NOOMING
+MPALMBEACH FL
+NPALMBEACH FI
+MPALMBEACH FL
+Onty
+Used
+SMIN
+THING
+EMIN
+Rate Description
+500 ABBIL ANYTME MIN
+500 ADD'L ANYTME MIN
+• ADD'L ANYTME M
+ILL WAITIN
+500 ADD'L ANYTME MIN
+00 ABBL ANYTIME MI
+DD'L ANYTME MIT
+00 NIGHT/WKEND MI
+0O NIGHTWKEND MI
+100 NIGHT WREN MIN
+D MIN
+3 MIN
+
+
+
+
+BREAS
+(56
+1818-3331
+(954)
+549-5982
+BRAR
+88888
+(561)662-7668
+(561)790-4794
+BARR
+1000
+ICOMIN
+WANDASHF
+INCOMING
+1 M
+NIG
+
+
+
+Item Date Time
+Called
+122 08/30 11:12P (954)309-1796
+423 05/30 11:49P
+424฿
+05/
+425
+'31
+12:54A (561)596-3561
+05/
+31
+09•51A
+426 05/31
+10:54A
+427
+050
+428
+15
+31
+(561)282-8891
+10:56A
+429
+31
+11:03 A
+S81 596-396
+11596-3561
+430
+05/
+31
+431
+09
+131
+11:19A
+11:23A
+561 818-3331
+432
+05/31
+11:41A
+433
+11:46A
+Calls To
+TLAUDERDL F
+ICOMINC
+NCOMING
+WPALMBEACH FL
+NCOMING
+WPALMBEACH FL
+PALMBEACH I
+PALMBEACI
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+INCOMING
+434
+08/3112:29P 1229P 561396-3268
+435 05
+9541549-598
+436 05
+8P
+541549-598
+OLLYWOOD E
+LLYWOO
+437 05/31 01:19P (954)549-5982
+
+
+00008893993390629590200288903000880699$08
+(954)
+1549-
+-5982
+(954)549-5982
+549-5982
+(954)549-5982
+829
+$1819
+929 12
+1596-
+1-53982
+
+19-
+485
+06/01 04:50P
+INCOMING
+Qnty
+Used Rate Description
+2 MIN
+00 NIGHT/WKEND M
+00 NIGHT WKEND N
+4 MIN
+1000 NIGHT/WKEND
+500 ADD'L ANYTME
+500 ADD'L ANYTME
+3MIN
+500 ADD'L ANYIM
+500 ADD'L ANY
+2 MIN
+2 MIN
+500 ABBE
+3MIN
+I ADD'L
+
+ADD'L
+
+Item Date Time
+Called
+Calls To
+Onty
+Used
+Rate Description
+486 06/01 04:56P (954)435-7760
+487 06/01 05:16P (954)303-7531
+488 06/01 05:17P
+489
+06/01 05:25P (954|648-9500
+490 06/01 05:26P 3051555-1212
+491 06/01 05:32P
+492 06/01 05:51P (561)317-2428
+HOLLYWOOD FL
+-TLAUDERDL FI
+LAUDERDL
+NCOMING
+WPALMBEACH FL
+500 ADD'L ANYTME MIN
+EMIN
+00 ADD'L ANYTME MIN
+2MIN
+00 ADD'L ANYTME MIN
+500 ADD'L ANYTME MIN
+1EVT 1.25 411 INFO
+500 ADD'L ANYTME MIN
+500 ADD'L ANYTME MIN
+1.25
+
+6/01 05:56
+1/01 05:59P 9541435-776
+5/01
+06:01P
+(954)435-7760
+01 07:08P (561)792-6375
+07:08P /561 790-4794
+07:11P (954)648-9500
+17:13P
+07:14P (561)644-6817
+
+17-
+24.
+(954)549-5982
+WPALMBEACH FL
+HOLLYWOOD FL
+HOLLYWOOD FL
+PALMBEACH F
+PALMBEAC
+TLAUDERDL FI
+COMING
+FL
+2MN
+2MIN
+299 999 79999999999 999
+00 ADD'L ANYIME MIN
+ADD'L ANYTME
+500 ADD'L ANYTME MIN
+500 ADD'L ANYIME MIN
+ADD'L AN
+ADD'L ANYTME
+ADD'L ANYTME
+DELETE BEEEEEEEEEEEEEEEEEE GODDED TERRETEERE
+2003254.000023B2B
+
+
+
+Item Date Time Called
+Onty
+Used
+550 06/02 10:02P
+551 06/02 10:15P
+552
+06/02 10:19P
+06/02 10:28P
+5611644-6817
+5611371-8664
+лесслі
+OSAS
+06/02 10:29P (561|596-3561
+06/02 10:46P
+06/03 12:23A
+06/03 01:09A (561)596-3561
+06/03
+01:26A (561)818-3331
+5588
+06/08 01-50A
+06/03 02:11A
+06/03 06:58A
+06/03
+10-5
+06/03
+11:30A
+06/03 12:57P
+56115
+96-3561
+565 06/03 01:04P
+(208)323-2551
+06/03 01:04P (800)474-6836
+06/03 02-33P
+568 06/03 03:00P
+569
+06/03
+03:06P
+570
+06/03 06:04P
+571
+06/03 07:47P
+(561j379-7824
+06л
+07
+53F
+06/
+10-26P
+06/03 10:29P
+06/03 10:40P
+
+
+10:42P
+(561)793-7230
+80823
+Calls To
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+COMING
+MING
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+INCOMING
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+BOISE ID
+COMING
+INCOMING
+INCOMING
+WPALMBEACH FL
+WPALMBEACH FL
+NCOMING
+MPALMBEACH FI
+INCOMING
+INCOMING
+WPALMBEACH FL
+INCOMING
+NCOMING
+INCOMING
+e999E
+99999
+4 MIN
+1MIN
+2 MIN
+14 MIN
+I MIN
+2MIN
+2 MIN
+3MN
+and ma mama
+13 MIN
+IEVT
+9MIN
+4 MIN
+5 MIN
+
+
+86800386386%
+(561)715-6303
+(561)790-3459
+
+
+1782
+(961)
+1818
+Rate Description
+CALL NAHTINGKEND MIN
+1000 NIGHT/KEND
+1000 NIGHT/WIEND
+1000 NIGHT/KEND
+1000 NIGHT/WIENB
+1000
+NI
+IGHT/WKEND
+500 ABBL ANYTME MIN
+500 ABBLANE MIN
+INCLUD
+CALL W
+INCLUDED
+LUD:
+ESSAI
+UT
+NI
+VCLUDE
+UTES
+INUTE:
+MINUT
+1.25
+
+Onty
+Item Date Time
+Called
+Calls To
+Used Rate Description
+0 06/04 07:2
+COMIN
+COMIN
+INCLUBEB MINUTES
+612 06/04 10:05P (561)792-2994
+WPALMBEACH FL
+2 MIN
+13 06/04 10:19P
+614
+06/04 10:23P
+COMIN
+COMIN
+617 0605 12:354 (561)792-6375
+INCOMING
+3 MIN
+615 06/04 10:26Р
+2MIN
+1000 NIGHT/WKEND MIN
+COMING
+(PALMBEACH F
+2 MIN
+618 06/05 01:02A
+INCOMING
+2 MIN
+619 06/05 01:20A (561)596-3561
+WPALMBEACH FL
+620
+06/05 01:52A
+INCOMING
+EMIN
+TINKEND MIr
+621 06/05 01:57A
+INCOMING
+5 MIN
+LL WAITIN
+INCOMING
+00 NIGHTANKEND M
+(581798-7230
+ALBEARE E
+PALMBEACH
+2 MIN
+
+(561 793-7230
+657 оБоБ 11 ЗВА (561)8183331
+06/06 11:3BА
+659 0606 81-58P
+01:50P (561)596-3561
+660 06/06 02:22P
+06/06 02:24F
+06/06 02:441
+: 06/06 02:55P (561)793-7230
+664
+06/06 02:56F
+665
+06/06 07:41P
+666
+06/06 08:13P
+668
+/06 08:35P
+88:
+08:49P (561)793-7230
+09:09P
+561 790-4794
+06/06 09:17P /
+561596-3561
+
+
+
+Called
+Item Date Time
+74 06/06 09:388
+75 06/06 10:12P (561)790-479
+676 06/06 10:14P (561 790-4794
+77 06/07 02:00A (561)596-3561
+678 06/07 10:34A
+561596-3561
+679 06/07 10:47A
+30 06/07 11:07
+31 06/07 01:42
+682 06/07 02:36P (561)596-3561
+6B3 06/07 82:32P 854543-5982
+685 06/07 02:43P
+6 06/07 03:04
+J07 02.1
+6B9 06/07 08:58P 581)790-3459
+689 06/07 03
+690 06/07 03:59P (561)790-3459
+
+04
+04:1
+04
+4F
+4:46F
+6P
+(561)793-7230
+1:53R
+15:28.5
+05:30P
+05:30P
+•33P
+56178
+1611
+33
+06:29P
+06:30P
+06:51P
+:57P
+
+:19P
+08:51P
+08:53P
+08:57P
+09:08P
+(561)792-6375
+561 818-3331
+1888
+20000
+I CO DO 00
+(561)792-6375
+
+
+88868436%
+(561)
+)596-8943
+
+Qnty
+Calls To
+Used Rate Description
+INCOMING
+WALMBEACH FL MIN
+WPALMBEACH FL
+PALMBEACH
+PALMBEACH i
+INCOMING
+INCOMING
+NCOMING
+2MIN
+2 MIN
+WPALMBEACH FL
+LLYWOOD
+LLYWOOD
+INCOMING
+COMIN
+COMIN
+SMIN
+WALMBEACH FL
+1 MIl
+IMIN
+WPALMBEACH FL
+000 NIGHT/WKEND MIN
+NCLUDED MINUTES
+INCLUDED MINUTES
+CLUDED MINUT
+CLUDED MINUT
+INCLUDED MINUTES
+CLUBEB MINUTE
+› MINUT:
+INCLUDED MINUTES
+INCLUDED MINUTES.
+CLUBED MINUTE
+CLU
+DROP CALL CREDIT
+WPALMBEACH FL
+INCOMING
+INCOMING
+INCOMING
+WPALMBEACH
+WPALM
+МРдІ МВ
+ДД ДДДД
+ДД ДДА
+INCI
+SEEEE 29
+
+4MIN
+
+Called
+Item Date Time
+39 06/09 06:10
+9 06:10P (561)793-723
+740 06/09 06:17P
+742 06/09 06:26Р (561)317-2428
+743 06/09 09:22P
+45 06 09 09:48P (361)793-723
+45 06/09 09:487
+746 06/09 10:58P
+47 06/09 11:008
+48 06/10 02:16A (561)596-356
+749 06/10 11:13A
+730 06/10 12:35₽ (561)795-9876
+10 12:51P
+10 01:26P
+06
+/10 03:53P
+06
+/10
+:03P
+06/10
+05:06P
+
+(561)790-4794
+(561)793-7230
+(561)793-7230
+:22P
+11:35P (561)596-3561
+776 06/10 11:55P
+06/11 01:48A
+06/11
+12:46P
+90-3459
+06/11 03:04P
+(561|792-6375
+06/11 04:59P
+
+05:12P
+(561)793-7230
+05:12P (561)596-3561
+05:16P
+07:38P
+561)793-
+07:40P
+07:48P
+561j827-4493
+(561|317-2428
+
+08:08P
+08:17P
+9:31P
+01:43A
+(561|317-2428
+:17A
+02:31A (561)379-7824
+797 06/12 02:46A
+Calls To
+WPALMBEACH FL
+INCOMING
+PALMBEACH I
+COMIN
+INCOMING
+WALMBEACH FL
+INCOMING
+COMIN
+PALMBEACH P
+INCOMING
+COMIN
+INC
+FL
+FL
+FL
+FL
+INCOMING
+VPALMBEACH F
+VPALMBEACH F
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FI
+INCOMINEACH FL
+WPALMBEACH F
+NPALMBEACH FI
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+INCOMING
+/PALMBEACH F
+WPALMBEACH FL
+INCOMING
+WPALMBEACH FL
+INCOMING
+Onty
+Used
+2 MIN
+2MIN
+2 MIN
+2 MIN
+3 MIN
+3MIN
+2 MIN
+2MIN
+1MIN
+Rate Description
+INGLUBED MINUTES
+INCLUDED MINUTES
+CLUDED MINUTE
+CLUDED MINUTE
+DOD NIGHT/KEND MI
+DOO NIGHT WKEND MI
+DO NIGHT/KEND M
+DO NIGHTWKEND M
+INCLUDED MINUTES
+ВІДНИНІ
+1MIN
+1KIN
+1 EVT
+VOLUBEB MINUTE
+D MINUTE
+300 N
+NCLUDE!
+NCLUDED
+MINUT
+2003254.000023829
+
+
+
+Item Date Time
+Called
+Onty
+Used
+798 06/12 02:47A
+799 06/12 09:01A (561)827-4493
+800
+06/12 09:10A
+801
+06/12 10:16A
+802 06/12 10:17A
+804
+06/12 10:58A
+2 11:00A
+06/
+11:49A
+Calls To
+INCOMING
+WPALMBEACH FL
+NCOMING
+NCOMING
+INCOMING
+INCOMING
+NCOMING
+INCOMING
+1:57A
+12:02P
+809
+1581)586 3561
+12:28P
+109
+06/1
+12-30P
+810
+06/
+12:40P (561|596-3561
+12
+06/
+06/1
+12:45P
+02:09P
+06/12 02:42P
+NOOMING
+MPALMBEACH FI
+WPALMBEACH FL
+INCOMING
+NCOMING
+INCOMING
+03-54P
+06/1
+2 04:13P
+561|282-8891
+06/1
+06/1
+650P
+06/11
+12
+6208.
+561)790-3459
+561|790-3459
+WPALMBEACH FL
+NOOMING
+NCOMING
+WPALMBEACH FL
+INCOMINEACH FL
+2MIN
+2 MIN
+2 MIN
+2MN
+2 MIN
+2 MIN
+MAIN
+Rate Description
+DO NIGHTAWKEND MI
+ALL WAITIN
+000 NIGHT/WKEN
+1000 NIGHT/KEND
+X00 NIGHT/WK
+0O NIGHT/KEN
+1000 NIGHT/KEND
+1000 NIGHT/WIENB
+1000 NIGHT/WIENB
+1000 NIGHT/KEND
+OD NIGHT/WKEN
+OO NIGHTAWKEN
+
+Item Date Time
+Called
+Calls To
+862 06/14 05 59P (561)313-5654
+• 06/14 05
+863
+06/14 06:28P
+INCOMING
+864
+
+06/
+14 08:31P
+06/
+14 08-53P
+06/14 08:54P
+869
+
+/14
+14 09]
+09:238
+14 09:49P
+14
+10:03P (561)596-3561
+14 10:06P
+10:09P
+10:11P
+10:12P
+(561)310-9164
+15P
+(561)383-6763
+(561
+310-9164
+5611383-6763
+8E990
+INCOMING
+COMIN
+COMIN
+INCOMING
+WPALMBEACH FL
+INCOMING
+COMING
+PALMBEACH F
+WPALMBEACH FL
+PALMBEACH I
+PALMBEAC
+WPALMBEACH FL
+WALMBEACH FEN
+WPALMBEACH FL
+WALMBEACH FL
+INCOMING
+COMIN
+COMIN
+Onty
+Used
+EMIN
+8 MIN
+2MIN
+2MIN
+3 MIN
+2 MIN
+2 MIN
+3 MIN
+MIl
+2 MIN
+Rate Description
+INCLUBED MINUTES
+INCLUDED MINUTES
+CLUDED MINUTE
+CLUDED MINUTE
+INCLUDED MINUTES
+TOTAL VOICE USAGE FOR (561)379-7824
+TWIKEND MI
+WKEND MIN
+OO NIGHT/WKEND MI
+00 NIGHT/KEND MI
+TEXT/MULTIMEDIA MSGS FOR (561)379-7824
+Item Date
+Time
+Sent To/Rcvd From
+- 1628
+Charge Description
+100 INCL. MSGS SENT
+100
+INCL
+MSGS
+SENT
+2003254.000023829
+98988
+06/1
+3
+-FO
+CUCU
+03:53A
+
+9988898888889g
+
+(561)790-3459
+561)317-2428
+5611317-2428
+05:24P
+772219-4743
+15611379-7824
+
+05:43P
+(561)324-1517
+
+18P
+(7721219-4743
+9P
+:01P
+15811596-3561
+11:09A
+561)793-7230
+561)662-6615
+1561
+1596-3561
+(561)792-6375
+INCOMING
+INCOMING
+INCOMING
+VINC
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+NCOMING
+WPALMBEACH FL
+NCOMING
+INCOMING
+INCOMING
+INCOMING
+INCOMING
+VPALMBEACH F
+VPALMBEACH F
+STUART FL
+WPALMBEACH FL
+WPALMBEACH FL
+INCOMING
+STUART
+COMIl
+COMIN
+INCOMING
+WALNBEACH AL
+INCOMING
+WPALI
+WPALME
+EACH FL
+EACH FL
+INCOMING
+WPALMB
+WP
+SACH Fi
+INCOMIN
+INCOMING
+NCOMING
+WPALMBEACH FL
+2 MIN
+2MIN
+MI
+2 MIN
+1MIN
+6MIN
+• EVT
+3 MIN
+2 MIN
+OMIN
+3 MIN
+2 MIN
+IMIN
+2 MIN
+AMN
+2 MIN
+2.50
+61
+
+GS
+0.25
+
+
+
+TEXT/MULTIMEDIA MSGS FOR (561)379-7824 - Continued
+Item Date
+35 05/28
+36 05/28
+37 05/29
+38 05/29
+39 05/29
+Time
+Sent To/Revd From
+Charge Description
+11:09P
+100 INCL. MSGS SENT
+11:58P
+DO INCL. MSGS SENT
+61236-329
+2:S1P 934/540.598
+10 IN MS SENT
+12:54P
+(954)549-5982
+100 INCL. MSGS SENT
+81:02P 952519-3962
+7954 549-5982
+2 05/30
+13 05/31
+11:55P
+200A85309-179
+44 05/31
+12:04A
+954\309-179
+(954)309-1796
+100 INCL. MSGS SENT
+45 05/31
+16 05/31
+22BP 961509-338
+61596-356
+47 05/31
+07:35P
+(561 596-3561
+18 05/31
+07:41P
+19 05/3
+10:06P
+611596-35
+S0 05/31
+10:09P
+100 INCL. MSGS SENT
+100 INCH MESSENT
+100 INCL. MSGS SENT
+52 05/31
+18:12P 1561596-3561
+
+...
+
+
+TOTAL TEXT/MULTIMEDIA MS
+G
+FOR (561)379-7824
+
+2003254.000023830
+
+
+
+
+2003254.000023B3D
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/4ff550263b1010380aeb0ec2498f5f0c6be3a89dc776ad0be014e31cbf04d6ea.receipt.json b/vision-fixhub/ds9-unparsed-06/4ff550263b1010380aeb0ec2498f5f0c6be3a89dc776ad0be014e31cbf04d6ea.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..bbcd4d30ca52ee7a752bf551519741a1f99ae50f
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/4ff550263b1010380aeb0ec2498f5f0c6be3a89dc776ad0be014e31cbf04d6ea.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -5865,
+  "dataset": "marble-joined",
+  "doc_id": "4ff550263b1010380aeb0ec2498f5f0c6be3a89dc776ad0be014e31cbf04d6ea",
+  "engine": "marble-apple-vision",
+  "event_count": 85,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "d58ee6b6113b46c3720f992470eb2628bfc09d921aad5b2e5de4c8d96d3ecc26",
+  "output_sha256": "f3bfb89ce1e05e29a9a78c55e845f0685cb252c0cdae078a68992c1ea1d4fc49",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/503674552644338ded0100aef66de6490eba271df54334bdcd9711e5c735b488.md b/vision-fixhub/ds9-unparsed-06/503674552644338ded0100aef66de6490eba271df54334bdcd9711e5c735b488.md
new file mode 100644
index 0000000000000000000000000000000000000000..70736ea9c15734248e49961843ed32a6784ca515
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/503674552644338ded0100aef66de6490eba271df54334bdcd9711e5c735b488.md
@@ -0,0 +1,56 @@
+From:
+To:
+Authority
+Date: Wed, 18 Apr 2012 15:33:05 +0000
+Importance: Normal
+Subject: Activity in Case 9:08-cv-80736-KAM Doe v. United States of America Notice of Supplemental
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Perczek, Jacqueline on 4/18/2012 at 11:33 AM EDT and filed on
+4/18/2012
+Case Name:
+Case Number:
+Filer:
+Doe v. United States of America
+9:08-cv-80736-KAM
+Roy Black
+Jeffrey Epstein
+Jay Lefkowitz
+Martin G. Weinberg
+Document Number: 163
+Docket Text:
+Notice of Supplemental Authority re [160] MOTION for Protective Order by Intervenors Black,
+Weinberg and Lefkowitz and Opposition to Motions of Jane Doe 1 and Jane Doe 2 For
+Production, Use, and Disclosure of Settlement Negotiations, [162] MOTION for Protective Order
+by Limited Intervenor Jeffrey Epstein And Opposition To Motions of Jane Doe 1 And Jane Doe
+2 For Production, Use, And Disclosure Of Plea Negotiations, [161] MOTION for Protective Order
+Supplemental Briefing Of Intervenors Black, Weinberg, And Lefkowitz In Support Of Their
+Motion For A Protective Order Concerning Production, Use, And Disclosure Of Plea
+Negotiations by Roy Black, Jeffrey Epstein, Jay Lefkowitz, Martin G. Weinberg (Perczek,
+Jacqueline)
+9:08-Cv-80736-KAM Notice has been electronically mailed to:
+Bradley James Edwards
+Bruce Reinhart
+
+
+Jacqueline Perezek
+Jay C. Howell
+Jay P. Lefkowitz
+Martin G. Weinberg
+Paul G. Cassell
+Roy Eric Black
+9:08-cv-80736-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at
+1.:
+The following document(s) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
diff --git a/vision-fixhub/ds9-unparsed-06/503674552644338ded0100aef66de6490eba271df54334bdcd9711e5c735b488.receipt.json b/vision-fixhub/ds9-unparsed-06/503674552644338ded0100aef66de6490eba271df54334bdcd9711e5c735b488.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..75d3a4a33edf900c0617e6c18dbe4dc59ddf6f1a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/503674552644338ded0100aef66de6490eba271df54334bdcd9711e5c735b488.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "503674552644338ded0100aef66de6490eba271df54334bdcd9711e5c735b488",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "f488e3b3bd38770ded25e2553d557be55afc44a8d3f3dd2a1ed2fb23031ff542",
+  "output_sha256": "31ae886dc6ec737d0b7ca1d12725543ae38abeaf37c0d9f1065af093e7efdaff",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/509713f1aed02da0f8cadf77bd193b7e5c4ee52dd819d243b0c698122e1ef1a1.md b/vision-fixhub/ds9-unparsed-06/509713f1aed02da0f8cadf77bd193b7e5c4ee52dd819d243b0c698122e1ef1a1.md
new file mode 100644
index 0000000000000000000000000000000000000000..0260f7f7a38d92fe43a329391e4502b222a2be84
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/509713f1aed02da0f8cadf77bd193b7e5c4ee52dd819d243b0c698122e1ef1a1.md
@@ -0,0 +1,45 @@
+From: "emecfautosender@flsd.uscourts.gov" <cmecfautosender@flsd.uscourts.gov»
+To: "flsd_cmecf_notice@flsd.uscourts.gov" <flsd_cmecf_notice@flsd.uscourts.gov>
+Subject: Activity in Case 9:08-cv-80893-KAM Doe |. Epstein Notification of Ninety Days Expiring
+Date: Wed, 27 Jan 2010 20:34:28 +0000
+Importance: Normal
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
+e-mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
+attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
+all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
+apply to all other users. To avoid later charges, download a copy of each document during this first
+viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of Florida
+Notice of Electronic Filing
+The following transaction was entered by Pike, Michael on 1/27/2010 at 3:34 PM EST and filed on 1/27/2010
+Case Name:
+Case Number:
+Filer:
+Document Number: 124
+Doe | Epstein
+9:08-cv-80893-KAM
+Jeffrey Epstein
+Docket Text:
+Notification of Ninety Days Expiring by Jeffrey Epstein re [87] Defendant's MOTION to Dismiss
+[38] Amended Complaint filed by Jeffrey Epstein (Pike, Michael)
+9:08-cv-80893-KAM Notice has been electronically mailed to:
+Ann Marie C. Villafana
+ann.marie.c.villafana@usdoj.gov
+Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com
+Jack Alan Goldberger jagesq@bellsouth.net, nalanis@agwpa.com
+Michael James Pike MPike@bclclaw.com, bobbie@bclclaw.com, jcadwell@bclclaw.com
+Paul G. Cassel cassellp@law.utah.edu
+Robert Deweese Critton, Jr rcrit@bclclaw.com, bobbie@bclclaw.com
+9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided
+by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:
+The following document(s) are associated with this transaction:
+
+
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP deecfStamp_ID=1105629215 [Date=1/27/2010] [FileNumber=7197886-0
+1 [64608342614d4c6989c7e3dcd65c7f6c7922644847949ebace40fd2766d7b0e5ec1
+4d40f61618c2abb80c50d68bcea15d8060c247545928282e338ec42b2edff]]
diff --git a/vision-fixhub/ds9-unparsed-06/509713f1aed02da0f8cadf77bd193b7e5c4ee52dd819d243b0c698122e1ef1a1.receipt.json b/vision-fixhub/ds9-unparsed-06/509713f1aed02da0f8cadf77bd193b7e5c4ee52dd819d243b0c698122e1ef1a1.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..dd9c9cb3a148348bc70d1817c2458001c9b4b8a8
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/509713f1aed02da0f8cadf77bd193b7e5c4ee52dd819d243b0c698122e1ef1a1.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "509713f1aed02da0f8cadf77bd193b7e5c4ee52dd819d243b0c698122e1ef1a1",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "a947143a355735931eae60dbaa1cae833591888f9c6c1d35e5dd629cd2c2cfb3",
+  "output_sha256": "f4eb13c36eea019ecae90bd2fcdbb55abede99595dbd5e0c93e314a161aae89e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/5173623a6fe9fd0c09752644def389ae539f5c743199bc237c4f6d2def86e491.md b/vision-fixhub/ds9-unparsed-06/5173623a6fe9fd0c09752644def389ae539f5c743199bc237c4f6d2def86e491.md
new file mode 100644
index 0000000000000000000000000000000000000000..cd71f6121a64b3570767f145bd78d445ed9b2950
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/5173623a6fe9fd0c09752644def389ae539f5c743199bc237c4f6d2def86e491.md
@@ -0,0 +1,66 @@
+STATE OF FLORIDA
+VS.
+Jeffre, Epsten
+• Defendant.
+IN THE CIRCUIT COURT OF THE FIFTEENTH
+JUDICIAL CIRCUIT IN AND FOR PALM BEACH
+COUNTY, FLORIDA - CRIMINAL DIVISION
+CASEND: 206889381AX14M
+FILED
+Circuit Criminal Department
+Der: 1 8 2009
+SHARON R. BOCK
+Clerk & Comptroller
+Paim Beach County
+THIS MATTER comes before the Cout upon D mots for tove!
+The Court, having been made aware that both counsel have agreed to sald motion..
+Accordingly, it is hereby:
+ORDERED and ADJUDGED hat D° matur is sated under.
+DONE and ORDERED in Chambers, West Palm Beach, Palm Beach County,
+Florida, this
+_ day of
+12/18/0
+
+
+IN THE CIRCUIT COURT OF THE FIFTEENTH
+JUDICIAL CIRCUIT, IN AND FOR PALM BEACH
+COUNTY, FLORIDA
+CASE NO. 2008CF009381A
+STATE OF FLORIDA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+MOTION FOR AUTHORIZATION TO TRAVEL
+COMES NOW the Defendant, JEFFREY EPSTEIN, by and through his undersigned
+attorney and moves this Honorable Court to enter an Order authorizing the Defendant's
+travel for business purposes related to ongoing litigation. In support thereof the Defendant
+would state as follows:
+1. The Defendant has been on community control since July 22, 2009.
+2. The Defendant has been in complete compliance with his conditions of
+community control since being placed on supervision.
+3. The Defendant was given permission to travel to New York on December 3, 2009
+for the purposes of meeting with his attorney, Harry Susman.
+4. After being granted permission, the Defendant arranged his travel plans with his
+community control officer, Carmen Sloane, and traveled to New York in complete
+compliance with the rules set forth by his community control officer.
+5 The Defendant needs to travel out of state for additional meetings with his
+attoreys to continue to review documents. See letter from Harry Susman attached hereto
+as Exhibit "A".
+6. Given the Defendant's complete compliance with the terms of supervision since
+being placed on community control on July 22, 2009, the Defendant's community control
+
+
+officer, Carmen Sloane, has no objection to the Defendant being given permission to travel
+for purposes related to his ongoing litigation as long as the dates and times of travel are
+cleared in advance and approved by his community control officer.
+WHEREFORE, the Defendant moves this Honorable Court to enter an Order
+authorizing the Defendant to travel for business purposes related to ongoing litigation as
+long as it is approved in advance by his community control officer.
+1 HEREBY CERTIFY that a copy of the foregoing has been furnished by fax and
+mail to Barbara Burns, Esquire, State Attorney's Office, 401 North Dixie Highway, West
+Palm Beach, Florida 33401 and to Carmen Sloane, Department of Corrections, 3444 South
+Congress Avenue, Lake Worth, Florida 33461, this 16" day of December, 2009.
+IKA GOLDBERGER, ESQ.
+Atterbüfy, Goldberger & Weiss, P.A.
+(561) 659-08300
+Florida Bar No. 262013
diff --git a/vision-fixhub/ds9-unparsed-06/5173623a6fe9fd0c09752644def389ae539f5c743199bc237c4f6d2def86e491.receipt.json b/vision-fixhub/ds9-unparsed-06/5173623a6fe9fd0c09752644def389ae539f5c743199bc237c4f6d2def86e491.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3a4e0d55f2771569a6f3f5a406f1c09a30ddfd36
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/5173623a6fe9fd0c09752644def389ae539f5c743199bc237c4f6d2def86e491.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "5173623a6fe9fd0c09752644def389ae539f5c743199bc237c4f6d2def86e491",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "dfa5ba5afc2a69838677101920f5dc8942946bfd79549daa5883f540833001f4",
+  "output_sha256": "08ef970380f7b1986bf608ce749b561c868dc400ef3a67b892322f91858b0d72",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/ds9-unparsed-06/51895c4b10da08f3ab4ecc2922fcb3f590a968219540a7f1400893cfce84a1c1.md b/vision-fixhub/ds9-unparsed-06/51895c4b10da08f3ab4ecc2922fcb3f590a968219540a7f1400893cfce84a1c1.md
new file mode 100644
index 0000000000000000000000000000000000000000..f68ba3c9a8e83c65b9dcb1348d3c699d6a9cd174
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/51895c4b10da08f3ab4ecc2922fcb3f590a968219540a7f1400893cfce84a1c1.md
@@ -0,0 +1,50 @@
+Subject: RE: Jane Does |. U.S. (re Jeffrey Epstein) - Litigation Hold - Additional
+Date: Thu, 04 Nov 2010 14:20:37 +0000
+Importance: Normal
+Thank you very much
+Enjoy your cruise!
+Subject: Re: Jane Does L: U.S. (re Jeffrey Epstein) - Litigation Hold - Additional
+P.s. I think you have to take your start date back much further -- 2005 or 2006.
+Subject: RE: Jane Does |. U.S. (re Jeffrey Epstein) - Litigation Hold - Additional
+Good Afternoon:
+In furtherance of the Lit Hold materials | sent to you, please know that I have to inform the National
+Preservation Officer at EOUSA in Washington as well as Jacquie Varela (here in the S.D. Fla) of the Lit Hold and
+inform them of key names.
+To that end, I gathered from the unsealed Court filings the names set forth below. Please let me know if there
+are any other names that should be identified. Please let me know st Rich
+• first name.
+I will also need the names of the victims that would be Jane Doe # 1 and Jane Doe #2 for preservation
+purposes. This information will be kept confidential. If the USAO-SDFLA Lit Hold efforts are ever the subject of
+discovery, we can redact the victim names...as was done in the letters filed with
+declaration.
+Also, I will need your assistance in preparing letters to the FBI and Palm Beach P.D. to urge them to place a Hold
+on any documents that they may have. unless you advise that a hold is already in place.
+Finally, please let me know if the Lit Hold Time Frame I suggested is correct, or if it should commence with an
+earlier date.
+
+
+Bradley J. Edwards, Esq, Counsel for
+Paul G. Cassell, Counsel for
+Jay C. Howell, Counsel for
+James Eisenberg, Esq., Original counsel for
+27?
+Jeffrey Epstein, Defendant in state criminal action and party to USAO-SDFLA Non-Prosecution
+Agreement
+Lilly Ann Sanchez, Counsel For Epstein
+Jack Goldberger, Counsel for Epstein
+Palm Beach Florida Police Department
+Subject: Jane Does | U.S. (re Jeffrey Epstein) - Litigation Hold
+Importance: High
+« File: Re.Jeffrey Epstein.Jane Does |. U.S. - 11.2.2010 JAW Lit Hold Ltr to Individual in USAO.SD.Fla.pdf >> «
+File: Re.Jeffrey Epstein.Jane Does I. U.S. - Typable 3-13.300.003 Attachment.1.pdf »>
+As a follow-up to your recent meeting concerning the above-referenced case, I write this letter in my capacity as
+the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the
+Southern District of Florida (USAO-SDFLA) to advise you of the USAO-SDFLA's legal obligation to preserve
+documents and data relevant to the lawsuit and to enlist your assistance in this regard.
+I request that you please read and acknowledge your receipt and agreement to the terms of this letter. I also
+ask that you please complete and sign the form accompanying this letter. Please return the originals of both
+documents to me by November 9, 2010.
+Should you have any questions, please let me know.
+
+
+omey
\ No newline at end of file
diff --git a/vision-fixhub/ds9-unparsed-06/51895c4b10da08f3ab4ecc2922fcb3f590a968219540a7f1400893cfce84a1c1.receipt.json b/vision-fixhub/ds9-unparsed-06/51895c4b10da08f3ab4ecc2922fcb3f590a968219540a7f1400893cfce84a1c1.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..24f18e84a414a6afd7e662ef2a2a2ed66ee9c90a
--- /dev/null
+++ b/vision-fixhub/ds9-unparsed-06/51895c4b10da08f3ab4ecc2922fcb3f590a968219540a7f1400893cfce84a1c1.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -69,
+  "dataset": "marble-joined",
+  "doc_id": "51895c4b10da08f3ab4ecc2922fcb3f590a968219540a7f1400893cfce84a1c1",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "14dd492730f45e685b0891d23ba4df70c986fdd916173f35a78519ae2a247372",
+  "output_sha256": "6635e75a637b723e1ee8d5650aed8a6626be81afe0a9cb2538cbc71c1fa33253",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}